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Home My WebLink AboutCDP 98-69; Saxony Pump Station Rehab; Coastal Development Permit (CDP) (17)DUDEK & ASSOCIATES, INC. Professional Teams for Complex Projects ing, Planning, Environmental Sciences and Management Services Corporate Office: 605 Third Street Encinitas, California 92024 760.942.5147 Fax 760.632.0164 May 24,1999 1493-60 Mr. Van Lynch Assistant Planner City of Carlsbad 2075 Las Palmas Drive Carlsbad, CA 92009-1576 Re: CDP 98-69 - Saxony Pump Station Rehabilitation Dear Mr. Lynch: This letter is sent to 1) Emphasize the importance of expedited approval of the Coastal Development Permit (CDP) 98-69 for the Saxony Pump Station. 2) Inform the Planning Commission as to the reliability, redundancy, and real time monitoring improvements to be made as part of the project. 3) Request that the CDP be modified in several regards. Importance of Expedited Approval The existing Saxony Pump Station was constructed by Leucadia County Water District (LCWD) in 1963, while the site was still unincorporated County of San Diego land. LCWD has had a prescriptive rights access to the Saxony Pump Station from the vicinity of the Saxony Road intersection with La Costa Avenue. This has recently been replaced with a new State Lands License for access and maintenance including all improvements proposed for Conditional Use Permit and Coastal Development Permit approvals. LCWD access to the Saxony Pump Station has been isolated from vehicle access since about May 1998 by the La Costa Avenue Widening Project. This restriction of access has significantly impaired LCWD's ability to maintain this pump station or to respond directly to potential emergencies at the site with vehicles. In addition, the Widening Project has also permanently removed LCWD's access corridor to the Saxony Pump Station. The opportunity to restore access on a new adjacent alignment has and will be a significant financial cost to LCWD for utility relocations, new access road and turnaround construction, retaining wall construction, State Lands License processing, and as yet to be determined wetland mitigation requirements and cost for impacts that will be caused by the new access road to the Saxony Pump Station. LCWD requests the approval of the CDP and CUP at the City's earliest opportunity. The earlier LCWD can regain construction and maintenance access, the lower the risk of potential uncontrolled sewage spills to Batiquitos Lagoon. Mr. Van Lynch May 24,1999 CDP 98-69 - LCWD Saxony PS Rehabilitation Page 2 of 4 Reliability Redundancy and Real Time Monitoring Improvements Pump station reliability is of the highest priority to LCWD. For your information, the LCWD Saxony Pump Station Project includes the following improvements: 1) A paved access road and truck turnaround to provide reliable all weather access for maintenance and emergency vehicles. (The Road Widening Project has precluded vehicular access since about May 1998). 2) A new standby emergency generator to provide electricity to the pumps during potential future power outages. 3) New underground power and telephone services, which will allow use of the prior overhead easements for the new access road alignment. This will also provide a more reliable power supply and telemetry system and will remove unsightly overhead facilities from the Batiquitos Lagoon area. 4) A new electrical transformer, which will improve power reliability. 5) A new emergency pipeline bypass connection, which will facilitate quick and reliable connection of a trailer mounted engine driven emergency pump connection that will be able to provide an entirely redundant bypass to the existing electric pump system. 6) A new electrical connection receptacle on the motor control center to facilitate a quick and safe connection of a standby trailer mounted electrical generator redundant to both the permanent electric supply and the permanent standby generator. 7) A new Supervisory Control and Data Acquisition (SCADA) system, which will provide constant real-time monitoring of the pump station. This will provide operators with early warning of any abnormal operations or problems at the station with the ability to remotely query the station for specific problems. 8) An overall rehabilitation of the mechanical, piping, and structural components of the entire pump station. Requested Modifications to CDP 98-69 We have received the proposed Carlsbad Planning Commission Agenda for the June 2, 1999 meeting. We have reviewed the documents and request the following changes: 1) Condition No. 2 requires compliance with all applicable provisions of federal, state, and local ordinances in effect at the time of building permit issuance. LCWD requests that the words "building permit issuance" be changed to "Coastal Development Permit 98-69 issuance." Mr. Van Lynch May 24,1999 CDP 98-69 - LCWD Saxony PS Rehabilitation Page 3 of 4 2) With regard to Conditions 4 and 5, we will comply, however, we request that our submittal reviews be expedited due to the enhanced protection of the Batiquitos Lagoon that will occur upon completion of construction of this project. 3) Condition No. 7 does not allow storage of materials unless " required by the Fire Chief." LCWD requests that this be changed to read " approved by the Fire Chief." 4) Condition No. 8 requires that "The applicant shall apply for and be issued building permits for this project within two (2) years of approval or this Coastal Development Permit will expire unless extended per Section 21.201.210 of the Zoning Ordinance." LCWD requests that Condition No. 8 be deleted in its entirety, since the improvements to Saxony Pump Station are not legally subject to the City of Carlsbad building code requirements, as follows: a) The California Government Code Article 5 Regulation of Local Agencies by Counties and Cities states that each local agency shall comply with all applicable building ordinances and zoning ordinances of the county or city in which the territory of the local agency is situated Section 53091 goes on to specify exemptions with building ordinances of a city as follows: "Building ordinances of a city shall not apply to the location or construction of facilities for the production, generation, storage, or transmission of water, wastewater or electrical energy by a local agency." b) In addition, the City Staff has already reviewed and approved the 100% submittal plans. Further these plans do not include any habitable structures. 5) Condition No. 10, we request that since the project is not legally subject to building permits, that the following portion of the Condition be deleted: "....deny or further condition issuance of all future building permits; deny, revoke or further condition all certificates of occupancy issued under the authority of approvals herein granted;" 6) Condition No. 12 does not allow any construction prior to completion of the La Costa Avenue Widening Project. We request that the following clause be added to the condition: "except that clearing, grubbing, and construction may occur, if coordinated with and to the extent allowed by the City of Carlsbad Principal Construction Inspector." There will be a period when paving on the north lanes is complete and access would be reasonable, but the entire Widening Project would not yet be complete. Again, please understand that completion of the Saxony Pump Station Improvements are critical to the improved reliability and redundancy of this station. Closing Please note that the Army Corps of Engineers has verbally agreed to negotiate an estimated mitigation value to be guaranteed by bond or letter of credit for future implementation of revegetation/restoration of wetland impacts. LCWD may be able to satisfy the wetland mitigation requirement in this manner coincident with City approval of the CUP/CDP. If the City and the Mr. Van Lynch May 24,1999 CDP 98-69 - LCWD Saxony PS Rehabilitation Page 4 of 4 City's Contractor would work cooperatively during the final stages of the La Costa Widening Project, then significant progress toward restoration of pump station access and improved reliability for protection of the Batiquitos Lagoon could be achieved this summer. This project is approaching a level of emergency need due to the long period that LCWD has been restricted from vehicular and construction/rehabilitation access. LCWD would very much appreciate timely approval of this important permit. We will be available to discuss the project and answer any questions at your convenience. Very truly yours, DUDEK & Associates, Inc. Steve Deering, PE LCWD District Engineer cc. Mr. Tim Jochem, LCWD General Manager Ms. Terry M. Gibbs, Worden, Williams, Richmond, Brechtel & Gibbs