NOP, scoping questions answered

Deborra Brannon

Concerns raised about the Notice of Preparation recently released by the City of Mount Shasta prompted the city to contact North State Resources project manager Wirt Lanning for answers to specific questions.

The NOP is part of the scoping process for environmental review of the city’s proposed sewer line upgrade.

A memo containing both the questions and Lanning’s responses is posted on the city’s website at, according to mayor Tim Stearns.

Scoping meeting

Lanning was asked to summarize the format for the public scoping meeting to be held tonight, Wednesday, Nov. 12, from 5:30 p.m – 7:30 p.m. in the Mount Shasta Community Center at 629 Alder Street.

He explained in the memo that there will be “no formal presentation by the consultant team” at the meeting.

According to Lanning, three stations will be set up for the public to speak to experts relevant to different aspects of the CEQA process, as follows:

• Project Formulation and Engineering Design – PACE engineering will describe how the proposed project was formulated, what criteria were used to select the sewer line improvement alternatives, and design and construction methodologies for the Mount Shasta Sewer Line Improvements Project;

• Environmental Review Process – North State Resources staff will describe the CEQA process, the role of participating agencies, and opportunities for public involvement; and,

• Environmental Issues – North State Resources staff will answer questions related to key environmental issues, including those identified early in the process such as cumulative impacts associated with Crystal Geyser operations, biological resources, and water quality.

At a fourth station, members of the public may sign up to be included on the project mailing list and may submit written comments.


In response to concerns raised “regarding the Crystal Geyser facility not having enough reference in the NOP,” Lanning was asked to provide background for the document.

Lanning responded in the memo that proposed improvements to the city sewer system is the discretionary action being considered by the city and the focus of EIR evaluation.

He stated that “re-operation of the bottling facility by Crystal Geyser is not a discretionary action under the city’s jurisdiction and, as such, is not part of the proposed project.”

However, Lanning continued, since the sewer project is linked to facility re-operation due to partial funding by Crystal Geyser, “related impacts” will have to be evaluated in the EIR as part of the “cumulative impacts analysis.”

The scoping process will determine the “scope and breadth” of that analysis, he wrote.

Lanning pointed out that Crystal Geyser’s bottling facility operation is included in the NOP’s project description; the company’s funding support for the project is mentioned; the project purpose includes Crystal Geyser’s projected effluent as part of the reason for the project; and the project background “notes when and how Crystal Geyser became involved in the process.”

Start of facility operations

Lanning was asked to clarify whether or not Crystal Geyser can begin operations before the sewer improvement project CEQA process is completed.

He stated that Crystal Geyser cannot begin operations before CEQA is completed if the company uses its connection to the city’s sewer system “as originally planned.”

Asked whether Crystal Geyser would need to go through a CEQA process of its own should they elect to treat their effluent onsite, Lanning indicated he could only offer an opinion, not an answer.

He stated in the memo that, in his opinion, the Regional Water Quality Control Board would have to determine if the quantity or quality of the effluent was “consistent with prior permit conditions” in place for the facility’s previous tenants and what regulatory and environmental processes might be required if the existing permit was invalid.

Lanning added that nothing in the city’s EIR process prohibits or prevents Crystal Geyser from establishing onsite effluent treatment “now or in the future,” rather than connecting to the city’s sewer system.