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Posted September 12, 2017

Siskiyou County releases a flawed Final EIR

On Friday, September 8th, Siskiyou County released to the public its Final Environmental Impact Report (FEIR) on the Crystal Geyser bottling plant project.  Even a brief examination of the 64 pdf documents that comprise the FEIR shows that almost all of the concerns and objections of the over 150 comments submitted on the Draft EIR were inappropriately deemed to be wrong, without merit, or misconceived and given no serious response.  Where a few comments were found to be “with merit,” changes were made but without an analysis of the original flaws in the Draft EIR, merely stating that these changes make the issues raised “no longer relevant.”  This treatment of public comment violates the CEQA Guidelines that mandate responses are to be "addressed in detail giving reasons why specific comments and suggestions were not accepted."  The FEIR found that no mitigations of any sort were needed on issues of air quality, traffic effects, visual aesthetics, aquifer protection, water quality, plastic pollution or hours of operation.  In addition, several mitigations from the original DEIR were modified to be less stringent.
Water issues not addressed
The community-wide concern about water and the health and sustainability of the local aquifer was a large portion of the public comments submitted.  The FEIR continues to declare that these concerns have no merit.  Concrete testimonials from homeowners about actual well issues while Danone/Coca Cola operated the plant were dismissed as “anecdotal.”  No mitigations, restrictions on pumping or safeguards for neighboring domestic wells are proposed in the FEIR.  Unfortunately, the FEIR contains many unsubstantiated assumptions and biases in the theoretical models used to argue that neighboring wells would not be impacted.  Because of past homeowner well issues, we continue to insist that only by directly monitoring homeowner wells during any and all hydro-geologic testing and during plant operation can these effects be realistically determined, monitored and mitigated. 
Waste water treatment
The FEIR eliminates wastewater disposal Option 4, which would have allowed the disposal of on-site treated effluent via irrigation of the surrounding land.  However, the FEIR still proposes Option 3, to release to the on-site leach field the industrial process and rinse wastewater from production of flavored sparkling water without any pre-treatment other than pH adjustment.  This untreated effluent, containing cleaning agents, boiler discharge, cooling tank discharge, floor wash, filter backwash and equipment rinse, would percolate into our shared and pure groundwater aquifer.  This option is not acceptable under any circumstances.  In the DEIR, wastewater disposal options that would send industrial wastewater to the Mt. Shasta City wastewater treatment plant were capped at a maximum of 24,000 gallons per day.  The FEIR now says a maximum of 50,000 gallons per day will be allowed under certain conditions.  Why is there now a softening of the cap to allow doubling of the allowed daily maximum?
Traffic issues
Whereas the DEIR indicated that noise from truck traffic was a significant but unavoidable impact, the FEIR declares that truck traffic noise is a less than significant impact.  Was this reduction in impact level because there was a reduction in truck traffic or a reduction in the noisiness of the trucks?  No, it appears to have been done by taking background noise levels nearer the train tracks, so the baseline noise level would be higher, and shifting night time truck trips to the daytime, which lowers the estimate for truck noise levels (due to the way the average of day- and night-time noise is calculated).  The result is that the calculation of the estimated noise appears to be less without actually reducing the total traffic noise nearby homeowners will experience.  This manipulation of noise calculations violates CEQA Guidelines that require responses to public comment be in "good faith."  The FEIR did reduce the hours of truck loading operations to be from 7am to 10pm.  While this is a much-needed change to the project, it was added with no mention of the DIER’s obviously flawed analysis that predicted no significant nighttime disturbance of residents by truck traffic.
Plastic pollution
The issue of plastic pollution is whitewashed by claiming that no plastic is manufactured at the plant. Although the FEIR does not say how many bottles per day the plant will produce, conservative estimates based on amounts of water to be bottled indicate the plant could be processing a million or more PET bottles a day.   This is a significant pollution threat!  Although Crystal Geyser is expecting the consumer to be responsible for recycling their PET bottles, they are committing to only a 50% recycling rate of solid waste at the plant, reduced from 75% originally stated in the DEIR.  Why the reduced commitment to recycling at their own plant?
Flaws in modeling
The FEIR contains many other major flaws, including errors in statements of fact, unsupported conclusions, and unsubstantiated choices of modeling procedures, all issues we are continuing to study.  The limitations of the modeling programs used can be seen in the analysis done in the Draft EIR on noise from plant HVAC and manufacturing cooling systems.  After numerous public comments noting the flaws and biased assumptions, the EIR authors did actual noise testing of the equipment systems and found that there were significant noise problems with the plant equipment, in direct contradiction to their previous modeling assumptions that found no significant noise effects. These new findings require stronger mitigations to lower noise emissions.

In Comments on the DEIR, W.A.T.E.R., the Gateway Neighborhood Association, lawyers, experts and many others called for the Draft EIR to be re-circulated to address many of the faults and omissions found in the draft.  We again call for recirculation of the revised DEIR.  The FEIR includes significant new data, analyses and alteration of conclusions, including new noise tests and calculations, a new pump test on their Domestic well #1, well pumping with accompanied hydro-geologic studies, new pavement impact studies, new green house gas calculations and additional information on chemicals used in manufacturing systems.  CEQA requires recirculation of the DEIR when significant new information is added to the FEIR, otherwise there will be no opportunity for thorough review by the public.  We request that the County recirculate the revised EIR and a new comment period be implemented!  Only with this procedure can the public fully understand the accuracy and completeness of the new studies and information supplied in the FEIR.

We continue to study the entire FEIR for more issues and problems and will bring them to the County Planning Commission public hearing tentatively scheduled for September 20, at the Miner’s Inn in Yreka at 9 am.  W.A.T.E.R. encourages all of the concerned public to attend this hearing and voice their concerns about the many flaws and omissions still in the FEIR.

FEIR Documents can be found on the County web site:

(at bottom, beginning on tab 6)


WIN-WIN for W.A.T.E.R. Raffle 2017

The Gateway Neighborhood Association (GNA) is holding a raffle to raise funds for the next round of expert and legal expenses needed to keep pressing for a complete Environmental Impact Review with enforceable mitigations regarding the Crystal Geyser bottling plant.
Click HERE for more info


Posted July 22, 2017

Critical Examination of a Crystal Geyser Economic Study

To gain further understanding of the real costs of a bottling plant in our community, W.A.T.E.R. commissioned Noah Enelow, Ph.D, senior economist, Ecotrust, Portland, Oregon to provide a an analysis of the economic effects of the Crystal Geyser plant. You can see the report <HERE>

Over a year ago, in March, 2016, an Arizona consulting firm, Applied Economics released a report titled Economic Impacts of Crystal Geyser on Siskiyou County, California, (AE Study).  Shortly thereafter, March 30, 2016,  the CEO of Crystal Geyser Water Company (CGWC), Yasu Iwamoto, in a guest opinion column, sited this study as an independent economic analysis. These reports are expensive and someone with a vested interest in the plant had to pay for the report. Why not say who? And on May 4, 2016,  a corporate public relations advertisement was placed in the paper using the report to taut much-exaggerated potential economic gains.

The AE Study uses inaccurate and inflated assumptions including those concerning wages.  Why not use actual figures, which are much lower?  Will the jobs be full time with benefits or will CG be hiring part time employees or use a staffing service through an employment agency? Will there be an additional 1.4 jobs for every CGWC job created as their advertising claims?

The report provided no example of where a water bottling plant has helped a community economically.  Again, why use ambiguous and questionable assumptions as to the effects CG will have on our county when it could use actual examples of the CG Roxane plant in Weed and CG plant in Olancha Point, CA?  Probably because there is no benefit to a corporation extracting water for free and not being responsible for its costly negative impacts on the community and environment - which can include waste water treatment, damaged roads, heavy truck traffic, visual blight, and air, water, and noise pollution. Small businesses, property values, and tourism can be damaged by all of these factors as well as causing a decline in quality of life and health. (128)

Just as the community has strongly questioned the draft EIR with more than 150 submitted comments, the We Advocate Thorough Environmental Review (WATER) group and many other residents of Siskiyou County question many of the assumptions and claims made by the AE Study.

To gain further understanding, WATER commissioned Noah Enelow, Ph.D, senior economist, Ecotrust, Portland, Oregon to provide a critical examination of the AE study. He commented on many aspects of the report and concluded that “Crystal Geyser's promises of jobs and economic revitalization cannot be taken at face value. Its  leading economic study is riddled with errors, omissions, and questionable assumptions; and it has failed to take account of the economic costs of the project's environmental impacts...the benefits claimed by the AE study are almost certainly overstated; and the costs to private and public property, health, and the natural environment are ignored.”

Noah Enelow states the AE Study “is not a good guide to decision-making around the proposed plant.” W.A.T.E.R. secured this critique and in addition has demanded a full EIR so that our public officials will make an informed decision that will protect their constituents, our community, and our environment. As elected officials, that is their responsibility. Once an international corporation establishes itself in a community, local control of its practices is lost.

Posted June 28, 2017

W.A.T.E.R. and the Gateway Neighborhood Association, six hired experts, two attorneys, the City of Mt. Shasta and 150 community members put in smart and exacting comments related to the Crystal Geyser Water Company proposal to open a bottling plant in town. The comments showed the many deficiencies that were found in the Draft EIR (DEIR) on the Crystal Geyser bottling plant. However the County has chosen to not resubmit a new DEIR to the public, but we have have been told that a Final EIR will be released in August of 2017 for the Siskiyou County Planning Commissions recommendations and then it will go the Board of Supervisors for approval. We will need to be at these meetings to make sure the truth about Crystal Geyser's environmental impacts is heard. Sign up for our newsletter to get the latest news! (<--- Link at left) 

We are in the process of insuring our hired experts and attorneys are available for the work necessary to continue the fight to safeguard our local water sources, community and surround neighborhood who rely on our pure water. Crystal Geyser admits in the DEIR that they plan to pollute the local groundwater by using the leach field to dump their effluent, rather than using the Mt. Shasta wastewater treatment plant. 

We are planning on fighting this, every step of the way and we need your help to do so. We are submitting grants to help raise funds. But we also need your help! We must raise an additional $35,000-$45,000 in order to pay for attorney and expert expenses. See our PayPal donation button on the upper left of this page.  It’s continuing to be a long fight but the plant is still not open so we are hopeful to force the company to do the right thing by our community or they can go away.

Posted March 28, 2017

Thank You Mount Shasta !
A big Thank You to everyone who wrote comments, attended meetings and contributed funds to this effort to have a real and effective EIR for Crystal Geyser.


Community Comments on the Crystal Geyser EIR

An amazing 150 comments were submitted to the County commenting on the Crystal Geyser draft EIR. The draft EIR was a poorly written and inadequate document that overlooked many of the harmful effects that this plant will cause. Concerned community members pointed this out again and again in an outpouring of thoughtful and well researched comments. The City of Mount Shasta held two meetings to discuss the City's response, and adopted a much stronger statement after numerous comments received from the public.  W.A.T.E.R. and the Gateway Neighborhood Association (GNA) also hired lawyers and expert consultants to forcefully respond to the legal and technical issues around this draft EIR. 
See the entire list of comments submitted HERE
Links to specific comments:
GNA attorney Marcia Burch
W.A.T.E.R. attorney Don Mooney
Hydrogeologic expert Tim Parker, Parker Groundwater
Traffic expert Tom Brohard, Brohard and Associates
Waste water treatment expert Peter Martin
Air Quality expert Greg Gilbert, Autumn Wind Associates
Noise expert Geoffrey Hornek
Comments by the City of Mount Shasta


The Real Crystal Geyser Project Revealed
The comment period for the Crystal Geyser Plant Draft Environmental Impact Report (DEIR) is now complete. If you look at what Crystal Geyser disclosed during this process, you will notice that the project is much larger and its impact on both the environment and our community is much greater than what the company originally told the public, the City, our County Supervisor and the Chamber of Commerce at the community meeting on March 24th, 2014.  
The Gateway Neighborhood Association (GNA) and W.A.T.E.R. fought hard to get a full EIR because we knew that the public was not being told the truth. Here are a few project changes, undisclosed to the public until the DEIR:


W.A.T.E.R. receives a $20,000 grant!

W.A.T.E.R. has received a generous grant from LUSH Handmade Cosmetic's Charity Pot non-profit funding effort. Charity Pot looks for projects that create long-term systematic change and address the root cause of the problem, which aim to alter opinion and behavior through raising awareness of issues, activism, education and campaigning. This grant helped us pay for the attorneys and environmental experts comments on the Crystal Geyser EIR. Thank you Lush Cosmetics!


W.A.T.E.R. educational meeting
on the Crystal Geyser DEIR
Thursday, February 9, 2017 at 6pm
Mt. Shasta Library
515 Alma Street, Mt.Shasta, CA

This meeting will help define all the areas of the document that are of serious concern, and ask you to review the DEIR and send in your comments to the County.  We will have a handout with links to our County Supervisors, Planning Commissioner contacts, the newspaper (for letters to the editor) and how to mail in your own personal comments.
Please let your friends and neighbors know about this opportunity to see and discuss the plans that Crystal Geyser has for its business and our community.

Tips on how to make effective EIR comments can be found HERE

Access the Draft EIR documents themselves HERE

Crystal Geyser draft EIR released by Siskiyou County.

Posted January 14,2017

The draft Environmental Impact Report on the Cyrstal Geyser project has been released by the County. The entire report can be downloaded at the County project web site HERE. Scroll to the bottom of the page to see the files. This is a lot of stuff to read, pick the area you are concerned about and please study. We are now going over these finding carefully and forwarding to our consultants and lawyers. W.A.T.E.R. is planning to have a community forum soon to go over these reports and discuss the findings and how we should respond.


See "History" tab for earlier postings




Welcome and thank you for checking out our website!

We Advocate Thorough Environmental Review (W.A.T.E.R.) is a group of Mt. Shasta area citizens who are concerned about maintaining a healthy environment and a desirable and sustainable community for future generations.

W.A.T.E.R.’s mission includes:

  • monitoring various development project applications

  • educating the public about environmental issues of local importance

  • support other local agencies in similar goals

W.A.T.E.R. has a State of California 501(c)3 non-profit status.

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