Another concern is with the ability of the City of Trinidad to provide the water the
hotel will require. The exact usage is a moving target with the original EA saying it
would be more than 18,000 gallons per day, which was magically and mysteriously
reduced to 3,000 to 3,500 gallons per day (Trinidad Rancheria presentation to
Trinidad City Council, March 13, 2019) with no explanation of how they arrived at
this figure. At full occupancy that would amount to 30 gallons per room per day, an
unrealistically low figure. The City is currently conducting testing to determine the
maximum volume of water that the plant can produce and the system can deliver.
The City has had many problems with its drinking water treatment facility and there
are times during the rainy season when turbidity in the creek and in the City’s raw
water intake (perforated pipes buried in a gravel journal within the bed of
Luffenholtz Creek) exceeds the level of turbidity that the system can treat, meaning
the City has to rely on the reserves in its water tanks until it can process water to
refill the tanks. While a member of the Trinidad Volunteer Fire Department I
witnessed an event where a City water line broke during a hard freeze, draining the
water tanks and creating a water emergency. Such an event left the City extremely
vulnerable for a fire emergency. Adding a 100-room hotel to the system would put
many people in peril in such a situation. If it happened once, it can happen again.
The project does not adequately address worst case scenarios yet common sense
dictates that planning must consider the worst case, which the EA does not.
The project should be planning for the driest possible water year, such as the
drought of 1976-77. A drought of similar proportion today would require the City to
use all of its allocation to supply existing customers. The City also has an obligation
to provide water to un-built lots within the City and to customers within its service
area. The assumption that the City can provide the needed water at all times of year
and in all types of water years is speculative and not supported by the data. In fact
the data suggests that the City may not be able to provide the water during summer
low flow periods, and definitely not during extreme drought conditions. With global
warming our weather is predicted to become warmer and dryer and more frequent
and severe droughts should be anticipated. The EA does not address the worst case
scenario and is inadequate in its assessment of the City’s ability to provide the
required water. A more thorough analysis, which the City is currently conducting,
needs to be completed and the City needs to receive and approve an application for
new service before approving the proposed hotel. A better analysis of alternatives,
including rain water collection, water storage, and reducing demand needs to be
conducted.
Waste water treatment is another concern. The EA contains misleading and
contradictory information in this regard. At one pint the EA states that the proposed
hotel will connect to the City’s sewer system, which does not exist. A 2004
wastewater investigation conducted by Winzler & Kelly, consulting engineers, notes
that there have been problems with the existing leach fields serving the casino,
including construction of decks, a driveway, and a large-above-ground-swimming
pool over septic tanks. Only 7 of 25 septic tanks had access ports, meaning they
could not be inspected nor pumped out as required for regular maintenance. Other
problems identified in the report included high ground water levels, inadequate
setbacks from steep slopes and bluffs, inadequate stream setback, unstable
landforms, and shallow depth to bedrock. Adding more effluent into leach fields will
overwhelm the ability of the leach fields and result in polluted water being
discharged into waters of the United States. A more thorough analysis and
consideration of alternatives needs to be conducted.