Opinion: Fire Suppression In Laguna Beach Using Recycled Water


By Roger Butow

Logistical and economic feasibility matter. Creating a separate recycled water system for fire suppression in our canyons fails both metrics. More importantly, water quality regulatory compliance limits Laguna’s utility options.

These advocates ignore industry analytical maxims like risk-benefit and/or cost-benefit ratios. Contrary to their false, propagandistic narrative, elected officials and staff aren’t profiting by saying “no.” This is about public agency accountability and fiduciary responsibility, not political will.

Advocates won’t be the ones breaking the news to ratepayers of double-digit increases, not have to write IOU checks in the tens of millions of dollars range, or justify increasing debt service per customer. Nor will the advocates have to defend these increases when predictable Prop 218 legal challenges are filed.

Like Mickey Mouse (The Sorcerer’s Apprentice) in Disney’s 1940 classic animation film FANTASIA, fantasy-driven advocates demand the waving of a magic wand: Water for fire suppression in our major canyons can be produced at the Coastal Treatment Plant (CTP) in Aliso Canyon, easily transported to a cluster of multi-million-gallon reservoirs on ridgelines, then distributed via gravity feed to the zones below.

These advocates conveniently leave out minor details like the enormous, related expenditures: planning and design, permitting processes, installations, infrastructural material, easements and encroachments, weather delays, contingency allowances, plus ongoing operation and maintenance costs.

I interviewed the CTP utility players: It would take about $10 million to fully convert the Coastal Treatment Plant in Aliso Canyon to a modern Advanced Waste Treatment System (tertiary) meeting Title 22 compliance standards. For details, see waterboards.ca.gov/laws_regulations.

Total wastewater flow to the CTP is about 3.3 million gallons per day (MGD), but SCWD already uses about 2.3 MGD of that for recycled during non-rainy and drought periods. Only one MGD is available for presently non-existent storage reservoirs, plus a transmission and distribution system.

You need about one pump station per 300 to 400 feet of elevation climb plus relay/slave stations, and they cost about $500,000 unit. So add another $5 million.

Advocates believe that at minimum three such hilltop reservoirs, storing approximately 10 MG total would suffice. One above Aliso, one at Top-Of-The-World, and one on the ridge above Emerald Bay. Reservoirs cost about $2.50/gallon of storage capacity, our running total is $35 million. That doesn’t include construction costs, complex water transport, etc.

The E-Bay ridge one would require ripping up PCH for about 5 miles, dislocating via lane closures, a disrupting traffic circulation nightmare. Planners estimate roughly a $400 to 500 per lineal foot operation. Then add significant patching and re-paving operations.

Conservatively add another $3+ million in today’s dollars, and as for commuters? Think about a fun redux of the Caltrans downtown project.

Another element being pushed is a satellite cistern system underneath Coast Highway intersections or adjacent streets. Fighting dense neighborhood fires with recycled water production, gravity doing the replenishing work from the reservoir supplies above. 30 sites with a 100,000-gallon capacity each have been proposed by said advocates.

Pre-fab cisterns would cost around $500,000 each, plus we’d need to excavate a hole the size of a school bus, taking up a minimum one lane plus the sidewalk to install new, separate fire hydrants at 30 intersections. So $1+ million per cistern, total holding capacity 3 MG. We’re now up to at least $70 million and climbing.

State regulations prohibit mixing Title 22 water with Title 17 (domestic) supplies and omitted by proponents is a simple fact: You can’t dump either to the municipal storm drain system that discharges into the Pacific Ocean. Recycled has a 7-10 day shelf life, and hence storage must re-sterilized in place or be used.

All of the system elements could be filled in about two weeks. What if we had no fires that year? Since you can’t discharge the water, can’t send it back to the plant, cleansing and distribution offline, now stranded assets, what then? 

Updated, Direct Potable Reuse regulations by the State are expected in late 2023 or early 2024. Converting the CTP to DPR is projected at $25 million. Maybe two years of the usual bureaucratic wrangling later, and it’s a total no-brainer decision.

Within the same projected construction timeline as the fire suppression system advocates propose (five to seven years), using existing plumbing, no excavating, no vehicular distress, no need to repave, at 1/3 the cost of an unnecessary recycled system.

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  1. Due to space restraints I was unable to include some additional information that might assist readers:
    Potable (Title 17 domestic supply, drinking water) gets the highest level of treatment, hence Direct Potable Reuse will cleanse wastewater to safe, healthy, acceptable regulatory standards.
    Non-Potable (Title 22 purple pipe, irrigation and landscape water as advocates propose) by State law cannot be allowed to co-mingle, contaminate Potable.
    Hence only a problematic dual system is possible unless as I propose we wait a few years, convert the Aliso Plant and tie it into our domestic system. That’s where I came up with the estimated $25 million, 1 time cost.
    No environmental damage because no extensive clearing of habitat for reservoirs or cutting impervious surface asphalt roads up to our hilltops for O&M.
    Then we’d have ≈1 MGD more locally produced, make us resilient, more independent from MET suppliers. No need to buy Poseidon or SCWD desalinated @ $2000+/acre foot. Nearly 100% autonomous.
    In fact, if a fire truck with a 500 gallon reservoir or hooked up to a Title 22 fire hydrant ran Title 22 thru its system, it would then need to sterilize, de-contaminate that truck’s system—by using another 500 gallons of Title 17 with disinfectants! And the truck would need to discharge its capacity after cleaning directly into the sewer system.
    Also, if the Coastal Treatment Plant WAS converted to an Advanced Waste Treatment Systems (Third level/Tertiary Title 22), the water unneeded because reservoirs/cisterns are full, no fires, it would have to be dumped into the Aliso Creek Ocean Outfall Pipe.
    Except WHOA!
    The same rookie, non-professional “citizen scientists,” also propose Zero Liquid Discharges (ZLD)—–So where will that 1 MGD of production go? The ocean.
    Perhaps more importantly, an AWTS will generate a lot of briney waste due to the purification/sterilization processes, in this case laced with forever chemicals.
    These have to be disposed of, and these rookie analysts usually pull a NIMBY: Regardless of what level of treatment happens at the CTP, send it all (waste and surplus) in a circuitous manner down to the San Juan Creek Ocean Outfall just off of Doheny State Beach.
    Pontius Pilate, wash their hands of it, somebody else’s contamination, problem solved.

  2. After forwarding my column & addenda comments, several of the major staff for the water utilities edified and clarified for me as follows:
    (1) The reservoir footprints + surface roads necessary to access the reservoirs for construction, then O&M, will undoubtably require mitigation.
    As I already knew of the minimal standard, a 1:1 ratio, then the total displacement acreage of Environmentally Sensitive Habitat (ESHA) for both reservoirs & impervious surfaced roads will require acquisition and maintenance of like ESHA somewhere. Either in proximity or nearby.
    So those that wrap themselves in the “green flag” don’t seem interested in telling us how/where this can be accomplished. Would our City have to purchase ESHA, or provide off-site mitigation?
    (2) I under-estimated the costs regarding the construction, conversion and distribution system of the AWTS in Aliso Creek Canyon (CTP): More like $100 million by the several years time it could take to get all of the permits in place.
    (3) The cost of a Direct Potable Reuse conversion @ the CTP would be more in the range of $35–40 million. So my 1/3 of the cost computation is correct, but obviously more $$$ required.
    (4) As Moulton Niguel Water District is pulling out of the CTP, the other 2 remaining utilities (Emerald Bay Community Services District & SCWD) would have to be aboard and unanimously agree to partner/underwrite in either case. That could be a deal breaker. SCWD already has all of the recycled/irrigation water and distribution system it wants/needs, so good luck with a Title 22 conversion.
    SCWD MIGHT be interested in a Title 17 DPR conversion, especially if it’s unable to construct its desalination plant @ Doheny.

  3. A fire suppression recycled water system on the perimeter of Laguna Beach watershed would be hugely capital intensive and invasive. The best watershed fire mitigation is achieved by removing the fuel – already performed by Agutilio, Dennis, Shandu and the Laguna Goats. Recycling the Aliso Outfall is best done at Aliso CTP, salvaging grey-water is best done at the residence. To supplement the Laguna Goat crew, volunteers can buy a weed-whacker, $199 at Ganhal or The Home Depot. Cheap and very effective for creating defensive space between residences and watershed.

    If the western drought plus climate change plays out (as I expect it will) then a $10million investment at CTP for recycled water enhancement will be a bargain.


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