Opinion: Concerns to Address in Proposed Expansion of Coaches Field
An Opinion from a Piedmont Resident regarding Best Management Practices (BMP) and the proposed expansion of Coaches Field:
Blair Park-Coaches Field & Untreated Water Costs
Before obtaining a building permit for construction of the Blair Park (BP) project, PRFO and the City of Piedmont have to meet the Regional Water Quality Control Board (RWQCB) C-3 provisions and obtain a National Pollutant Discharge Elimination System (NDPES) permit from the RWQCB. The NDPES permit entails how all storm water runoff and discharge from the BP project will be handled into the existing storm culvert water infrastructure system, eventually reaching Lake Merritt (LM). The Piedmont Blair Park-Coaches Field projects will need specialized solutions to meet C-3 requirements to properly discharge their storm water to match pre-construction flow rates. PRFO design is to use massive wet vaults or cisterns.C-3 wet vaults or cisterns are not the optimal BMP practice. Many municipalities and agencies that have used this method have now categorically discouraged this practice:
- City of Milipitas web site, C-3 Storm water Guidebook states: “Underground wet vaults, settlement devices, deflection separators are strongly discouraged”.
- California Department of Health Services says in June 2002 BMP handbook: “Vaults, pumps and sumps are discouraged because they reduce reliability, increase maintenance, and create potential vector problems”.
- Contra Costa County Official’s web site states from their Sept 5, 2006 Clean Water Program Draft that wet vaults: “Pumped systems are expensive, require more maintenance, are prone to untimely failures and overflow spills, and cause vector control problems, besides having corrective maintenance in perpetuity”. EPA/RWQCB has mandatory minimum penalties for the discharge of untreated waters. Fines are based on “ability to pay” and can be $10,000 per day-$10 per gallon for unintentional violations, and $25,000 per day-$25 per gallon for negligent violations. Blair Park wet vault capacity is 172,040 gallons, Coaches Field vault capacity is 71,060 gallons.
MORAGE CANYON SPORTS FIELD WET VAULTS WILL SPILL UNTREATED WATER!
- A 1% “unintentional spill” (2431 gallons) of untreated water from either Blair Park or Coaches Field wet vaults could result in a EPA/RWQCB/NPDES Board discharge violation
- fine of $ 34,300.00 for a one-time event.
- A 1% “negligent spill” could cost Piedmonters $ 49,700.00
- A 10% “unintentional spill” could cost Piedmonters $ 253,000.00 (24310 gallons)
- A 10% “negligent spill” could cost Piedmonters $ 395,000.00
City Administrator Geoffery Grote and PRFO are proposing that Piedmont taxpayers will be forever saddled with a spill-prone, complex, expensive and vector host hydrology system. Piedmont will have a contractual burden/liability of maintaining, what is basically a risky (35,500 cu. ft) 4-zone cistern water treatment plant, 3 (100 year old) earthen dam reservoirs – all under the watchful eye, rules and fines of the EPA & Regional Water Quality Control Board.
Neil Teixeira
Piedmont
(This letter expresses the personal opinions of the author. All statements made are the opinion of the writer and not necessarily those of the Piedmont Civic Association.)
