RECYCLED WATER FEASIBILITY STUDY
CITY OF FORT BRAGG
ADMINISTRATIVE DRAFT FINAL
JANUARY 2026
Prepared for:
U.S. Bureau of ReclamaƟon
Title XVI Water ReclamaƟon and Reuse Program
Prepared By:
City of Fort Bragg
416 North Franklin St
Fort Bragg, CA 95437
fortbraggca.gov
Hoch ConsulƟng, APC
804 Pier View Way, Suite 100
Oceanside, CA 92054
hochconsulƟng.com
Trussell Technologies, Inc.
4350 ExecuƟve Drive, Ste 300
San Diego, CA 92121
trusselltech.com
HELIX Environmental Planning
7578 El Cajon Blvd
La Mesa, CA 91942
helixepi.com
TABLE OF CONTENTS
EXECUTIVE SUMMARY ............................................................................................................. 1
1. INTRODUCTORY INFORMATION ......................................................................................... 3 (a) Non-Federal Project Sponsor ......................................................................................................................... 3 (b) Description of the Study Area ........................................................................................................................ 3 (c) Water System ................................................................................................................................................. 5 (d) Wastewater System ....................................................................................................................................... 6
2. STATEMENT OF PROBLEMS AND NEEDS ............................................................................. 7 (a) Problems and Needs ...................................................................................................................................... 7 (b) Current and Projected Water Supplies .......................................................................................................... 9 (c) Current and Projected Water Demand ........................................................................................................ 11 (d) Water Quality Concerns for Current and Projected Water Supply .............................................................. 13
3. WATER RECLAMATION, RECYCLING OR DESALINATION OPPORTUNITIES ......................... 14 (a) Reclaimed or Desalinated Water Uses ......................................................................................................... 14 (b) Available Water Market ............................................................................................................................... 14 (c) Market Assurances ...................................................................................................................................... 15 (d) Discussion of Considerations ....................................................................................................................... 16 (e) Water and Wastewater Agency Identification ............................................................................................. 17 (f) Source Water Description ............................................................................................................................ 18 (g) Location of Source Water Facilities .............................................................................................................. 18 (h) Current Water Reclamation Description...................................................................................................... 21 (i) Current and Projected Wastewater and Disposal Options .......................................................................... 23 (j) Summary of Technology Currently in Use ................................................................................................... 23
4. DESCRIPTION OF PROPOSED PROJECT AND ALTERNATIVES ............................................. 25 (a) Non-Federal Funding Condition ................................................................................................................... 25 (b) Planning for Treatment Upgrades ............................................................................................................... 25 (c) Project Objectives ........................................................................................................................................ 27 (d) Project Description ...................................................................................................................................... 27 (e) Project Costs ................................................................................................................................................ 35 (f) Discharge and Disposal Description ............................................................................................................. 36 (g) Alternative Technologies Description .......................................................................................................... 38 (h) Regulatory Requirements for Potable Reuse ............................................................................................... 39
5. ECONOMIC ANALYSIS ...................................................................................................... 40 (a) Current and Projected Conditions of Alternatives ....................................................................................... 40 (b) Cost Comparison of Alternatives ................................................................................................................. 41 (c) Description of Other Water Supply Alternatives ......................................................................................... 41 (d) Comparison of Project Service Levels Between Chosen Project and Top Alternative ................................. 43 (e) Qualitative Benefits ..................................................................................................................................... 43
6. SELECTION OF THE PROPOSED WATER PROJECT .............................................................. 45 (a) Justification .................................................................................................................................................. 45 (b) Affirmative Statement ................................................................................................................................. 45
7. ENVIRONMENTAL CONSIDERATIONS AND POTENTIAL EFFECTS ....................................... 47 (a) Compliance with NEPA and Other Federal Law ........................................................................................... 47 (b) Project Timeline in Regard to Environmental and Cultural Compliance ...................................................... 51
8. LEGAL AND INSTITUTIONAL REQUIREMENT ..................................................................... 52 (a) Analysis of Water Rights .............................................................................................................................. 52 (b) Legal and Institutional Requirements .......................................................................................................... 52 (c) Multi-Jurisdictional and Interagency Activities ............................................................................................ 53 (d) Permitting Procedures ................................................................................................................................. 53 (e) Unresolved issues ........................................................................................................................................ 55 (f) Wastewater Discharge Requirements ......................................................................................................... 55 (g) Rights to Wastewater Discharges ................................................................................................................ 56
9. FINANCIAL CAPABILITY OF SPONSOR ............................................................................... 57 (a) Proposed Schedule ...................................................................................................................................... 57 (b) Non-Federal Project Sponsor Funding ......................................................................................................... 57 (c) Funding Plan ................................................................................................................................................ 58 (d) Sources of Funding ....................................................................................................................................... 59
10. RESEARCH NEEDS ............................................................................................................. 61 REFERENCES .......................................................................................................................... 63 APPENDICES*
Appendix A. Secondary Wastewater Characterization Technical Memorandum Appendix B. Treatment Technology Evaluation Technical Memorandum Appendix C. Regulatory and Permitting Summary Technical Memorandum Appendix D. Pipeline Alignment Analysis Technical Memorandum Appendix E. Recycled Water, IPR and DPR Feasibility Evaluation Technical Memorandum Appendix F. Market Assurances Technical Memorandum
* The appendices are provided in a separate document.
TABLES
Table ES-1 Summary of Potable Reuse Alternatives Considered ................................................... 2 Table 2-1 Existing and Future Storage Facilities .......................................................................... 11 Table 2-2 Current and Projected Demand ................................................................................... 12 Table 3-1 WWTP NPDES Compliance and Performance Summary .............................................. 20 Table 3-2 Proposed Feedwater Quality ....................................................................................... 22 Table 4-1 Implementation Characteristics of the IPR Alternative ............................................... 28 Table 4-2 Design Flows for Proposed Project .............................................................................. 29 Table 4-3 Capital Cost Estimate for Proposed Project ................................................................. 33 Table 4-4 Annual OM&R Cost Estimates for Proposed Project ................................................... 34 Table 4-5 Component Replacement Schedule for Proposed Project ........................................... 34 Table 4-6 Comparison of Potable Reuse Alternatives ................................................................. 35 Table 4-7 Summary of Key Distinctions Between IPR and DPR Alternatives ............................... 38 Table 5-1 Cost Summary of Potable Reuse Alternatives ............................................................. 41 Table 5-2 Planning Level Estimates of No Project Strategies ....................................................... 42 Table 7-1 Potential Environmental Impacts of Pipeline Alignment D .......................................... 49 Table 8-1 Permits and Plans Required for Proposed Project ....................................................... 54 Table 9-1 Proposed Project Schedule .......................................................................................... 57 Table 9-2 Proposed Project Funding Strategy ............................................................................. 60
FIGURES
Figure 1-1 Map of Northern California .......................................................................................... 3 Figure 1-2 Map of Study Area ....................................................................................................... 4 Figure 2-1 Existing and Projected Water Supplies ....................................................................... 10 Figure 3-1 Wastewater Treatment Plant ..................................................................................... 18 Figure 3-2 WWTP Simplified Process Flow Diagram .................................................................... 19 Figure 3-3 Total Daily Flows to WWTP 2020 to 2024 .................................................................. 19 Figure 3-4 Diurnal Effluent Flow Trends ...................................................................................... 21 Figure 4-1 Treatment Train for Proposed Project ....................................................................... 30 Figure 4-2 AWPF Layout for Proposed Project ............................................................................ 31 Figure 4-3 Conveyance Pipeline Alignment D for the Proposed Project ...................................... 32 Figure 4-4 Pathogen Removal Credits for Proposed Project ....................................................... 39
ACRONYMS
AB – assembly bill
ADWF – average dry weather flow
AF – acre-foot
AFY – acre feet per year
AOP – advanced oxidation process
AWPF – advanced water treatment facility
AWT – advanced water treatment
BAC - biologically activated carbon
CCB – chlorine contact basin
cBOD – carbonaceous biochemical oxygen demand
CCR – California Code of Regulations
CCRO – closed-circuit reverse osmosis
CDFW – California Department of Fish and Wildlife
CEC – constituent of emerging concern
CEQA – California Environmental Quality Act
CFS – cubic feet per second
CIP – capital improvement program
COSS – cost-of-service and rate study
CRA – Colorado River Aqueduct
CTR – California Toxics Rule
DAC – disadvantaged community
DBPs – disinfection byproducts
DDW – Division of Drinking Water
DiPRRA – direct potable reuse responsible agency
DPR – direct potable reuse
DWR – Department of Water Resources
EBCT – empty bed contact time
EQ – flow equalization
EIR – environmental impact report
EIS – environmental impact statement
FAT – fully advanced treatment
FRRO – flow reversal reverse osmosis
FTUs - filter treatment units
FY – fiscal year
GAC – granular activated carbon
GMF – granular media filtration
GRW – groundwater recharge
GRRW – groundwater recharge with recycled water
GSA – Groundwater Sustainability Agency
HCP – habitat conservation plan
HERO – high efficiency reverse osmosis
HPRO – high-pH reverse osmosis
HRT – hydraulic retention time
IPR – indirect potable reuse
IX – ion exchange
LCP – Local Coastal Program
LOX – liquid oxygen
LRV – log10 removal unit
MCL – maximum contaminant level
MF - membrane filtration
MGD – million gallons per day
MHI – median household income
MID – municipal improvement district
MSCP – Multiple Species Conservation Program
NCCP – Natural Community Conservation Planning
NDMA – N-nitrosodimethylamine
NEPA – National Environmental Policy Act
NL – notification level
NPDES – National Pollutant Discharge Elimination System O3/BAC – ozone and biologically activated carbon
O3:TOC - mass ratio of applied ozone to the total organic carbon present OM&R – operations, maintenance, and replacement
PRFO – pulse flow reverse osmosis
RL – response level
RO – reverse osmosis
ROWD – report of waste discharge
RUWMP – Regional Urban Water Management Plan
RWA – raw water augmentation
RWC – recycled water contribution
RWQCB – Regional Water Quality Control Board
SAT – soil aquifer treatment
SDAC – severely disadvantaged community
SGMA – Sustainable Groundwater Management Act
SMCL – secondary maximum contaminant level
SRT – sludge retention time
SVI – sludge volume index
SWA – surface water augmentation
SWP – State Water Project
SWRCB – State Water Resources Control Board
SWTP – surface water treatment plant
T22 – Title 22 recycled water (California)
TC – total coliform
TCDD – tetrachlorodibenzo-p-dioxin
TDS – total dissolved solids
TM – technical memorandum
TOC – total organic carbon
TSS – total suspended solids
TWA – treated water augmentation
UV – ultraviolet light
UVT – UV transmittance
WRF – water reclamation facility
WWTP – wastewater treatment plant
City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Executive Summary Page | 1
EXECUTIVE SUMMARY
The City of Fort Bragg is located on the Mendocino Coast of northern California and is home to approximately 7,114 residents. The City’s water supply relies entirely on three local surface water sources: the Noyo River and two spring-fed tributaries, Waterfall Gulch and Newman Gulch. Over the last decade, these water sources have been severely impacted by drought, forcing the City to rely more heavily on the Noyo River. In 2021, the City declared a Stage 4 emergency water crisis due to critically low water levels.
The City currently operates a wastewater treatment plant (WWTP) with an average daily flow of
0.8 million gallons per day (MGD), which serves the entire City and nearby areas. Currently, treated wastewater is discharged into the Pacific Ocean via a 690-foot ocean outfall pipeline and no recycled water is presently being utilized. In light of the City’s vulnerability to drought and its status as a Severely Disadvantaged Community (SDAC), the City is seeking to implement a recycled water project to enhance water security by treating and reusing effluent as potable water.
This Recycled Water Feasibility Study (Study) aligns with the City’s environmental goals and seeks to bolster the City’s water supply by adding a resilient and stable source of local water. It will focus on identifying and prioritizing the most viable recycled water supply and use alternatives, providing a strategic plan for implementing cost-effective treatment technologies that comply with current regulations. Recycled water, as used in this Study, refers to municipal wastewater that has been treated to a level suitable for beneficial reuse in accordance with Title 22 (T22) of the California Code of Regulations and applicable State Water Resources Control Board (SWRCB) potable reuse regulations. This includes non-potable reuse (NPR) applications such as landscape or agricultural irrigation, industrial uses, and environmental enhancement, as well as potable reuse applications achieved through advanced treatment processes that produce water suitable for Indirect Potable Reuse (IPR) or Direct Potable Reuse (DPR).
Key project elements include assessing customer demands through customer engagement, available sources and volumes of recycled water, cost estimates and project feasibility, system hydraulics and capacity, pollution control alternatives, potential environmental and regulatory impacts (both beneficial and adverse), pipeline locations, and the feasibility of serving customers.
This study builds upon several technical memoranda (TM) and planning studies which evaluated potential reuse alternatives. These documents are listed in the References section of this study.
Alternatives Considered
Fort Bragg considered three alternative reuse options: recycled water, IPR, and DPR. Based on a market analysis, T22 recycled water was determined to be economically infeasible due to its relatively low demand and the extensive infrastructure required to deliver it to geographically dispersed user locations. Reuse strategies in this Study will therefore focus on IPR and DPR technology. More discussion of the market analysis is included in Chapter 3.
Four water reuse alternatives were evaluated to improve long-term water supply reliability and resilience. The alternatives reflect varying approaches to integrating treated water into the City’s existing water supply system and differ in treatment, conveyance, and regulatory considerations.
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1. IPR via Surface Water Augmentation (SWA) to the Summers Lane Reservoirs. SWA, a form of IPR, is the planned practice of adding purified recycled water into a reservoir that serves as a permitted drinking water supply. In this alternative, secondary effluent from the City’s wastewater treatment plant (WWTP) would undergo full advanced treatment (FAT) at a proposed advanced water purification facility (AWPF). Purified water from the AWPF would be conveyed to the expanded Summers Lane Reservoirs, where it would blend with surface water supplies prior to treatment at the City’s surface water treatment plant (SWTP).
2. DPR via Raw Water Augmentation (RWA) to Raw Water Storage Ponds. This alternative is a form of RWA in which purified water from the proposed AWPF would be introduced into the City’s existing raw water storage ponds at the SWTP, which currently blend supplies from the Noyo River and spring-fed tributaries before treatment. Use of the ponds would reduce the need for the construction of new raw water storage facilities, expanded surface water intake infrastructure, and associated conveyance and pumping facilities.
3. DPR via RWA to Reservoir. Raw water augmentation (RWA) is a form of DPR that occurs when advanced treated wastewater is used to augment an existing source water prior to final treatment and distribution. In this alternative, purified water from the proposed AWPF would be conveyed to the expanded Summers Lane Reservoirs, where it would blend with surface water supplies prior to treatment at the City’s SWTP.
4. DPR via Treated Water Augmentation (TWA) to Finished Water Storage. This alternative is a form of DPR in which purified water would be introduced directly into the City’s finished water storage tanks downstream of the SWTP. Blended water from these tanks would then be delivered into the potable distribution system.
Table ES-1 Summary of Potable Reuse AlternaƟves Considered Alternative Capital Cost Capital
Cost/AF O&M Cost AFY Produced
1 IPR via SWA to Reservoirs $55,863,000 $2,307 $1,895,000 807 2 DPR via TWA to Finished Water Storage $71,418,000 $2,950 $2,078,200 807 3 DPR via RWA to Storage Ponds $71,318,000 $2,946 $1,980,200 807 4 DPR via RWA to Reservoirs $74,806,000 $3,090 $1,980,200 807 Proposed Project
After reviewing the treatment, environmental, and regulatory analyses, the City has identified Alternative 1 IPR via SWA to the Summers Lane Reservoirs for further development. This alternative offers the best combination of cost-effectiveness, environmental compatibility, regulatory feasibility, and long-term operational resilience.
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1. INTRODUCTORY INFORMATION
This chapter introduces the City of Fort Bragg, the Municipal Improvement District, and the physical and institutional context for the study. It describes the service area, the existing water and wastewater systems, and the regulatory and organizational framework within which the City operates. The chapter is intended to introduce the project sponsor, where the system is located, and what infrastructure exists today, providing the factual foundation for the problem statement and project evaluation that follow.
(a) Non-Federal Project Sponsor
Identification of the project sponsor.
The City of Fort Bragg, California, the project sponsor, is located on the Mendocino Coast in northern California, as shown in Figure 1-1, and is home to approximately 7,117 residents. Fort Bragg serves as the largest population center on the Mendocino coast and experiences significant seasonal population increases associated with tourism.
Water and wastewater services are
provided through Fort Bragg Municipal
Improvement District No. 1 (MID), which
is governed by the Fort Bragg City
Council acting as the MID Board of
Directors. The MID is responsible for
ownership, operation, and long-term
management of the City’s water and
wastewater infrastructure, including
supply, treatment, storage, distribution,
collection, and disposal facilities.
This Study evaluates options for
improving the long-term reliability of
the City’s potable water supply through
water reuse. The operational and
regulatory drivers for this effort,
including hydrologic variability and
system vulnerability, are discussed in
detail in Chapter 2.
(b) Description of the Study Area
Describe both the site-specific project area where the
water supply will be needed and developed and any
recycled water distribution systems.
Location. The City of Fort Bragg is a general law city located 165 miles north of San Francisco, and 188 miles west of Sacramento on the Pacific coast. The City occupies 2.7 square miles, one-third of which is zoned industrial, consisting primarily of property owned and operated by Georgia Pacific Corporation. Fort Bragg is the largest city on the Mendocino coast. The mild climate and picturesque coastline make Fort Bragg a popular tourist and recreational area.
Figure 1-1 Map of Northern California
City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 1 Page | 4
Figure 1-2 Map of Study Area
City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 1 Page | 5
The study area corresponds to the municipal sewer and water service area managed by Fort Bragg MID No. 1, as shown in Figure 1-2. The MID includes the City limits and adjacent unincorporated areas within the City’s sphere of influence. The MID was formed in 1969 for the purpose of acquiring, constructing, and operating wastewater and water system improvements.
Economic conditions within the City reflect long-term structural change following the closure of the Georgia-Pacific mill and the growth of tourism and service industries. Fort Bragg’s median household income remains well below the statewide average, qualifying the City as a Severely Disadvantaged Community under California Water Code. These conditions influence both infrastructure planning and affordability considerations and are discussed further in Chapter 2 and Chapter 9.
(c) Water System
The City’s water distribution system operates primarily as a gravity-fed system, using elevation differences between storage tanks and the service area to convey water and maintain system pressure. Finished water is pumped to elevated storage tanks and then distributed by gravity throughout the service area, which reduces the need for continuous pumping and minimizes energy needs. This configuration supports reliable pressure control, diurnal demand balancing, fire protection, and emergency response, and enhances system resilience during power outages or other operational disruptions. One area of the City, referred to as the East Fort Bragg Pressure Zone, is served by a pump station since elevations are too high to be served by gravity. The City’s water treatment and storage infrastructure include:
Water Treatment Plant. The City’s Water Treatment Plant (WTP), located at the Corporation Yard at 31301 Cedar Street, was originally constructed in 1958. A major treatment process upgrade was completed in 1986, increasing the plant’s nominal treatment capacity to approximately 2.2 MGD. This upgrade replaced the original treatment process with two packaged Trident® filter treatment units (FTUs).
Since that time, the core treatment process at the SWTP has remained largely unchanged. The most recent significant improvement project at the SWTP was completed in 2004 and involved modifications to the existing raw water storage ponds to repurpose them as backwash water storage ponds. No subsequent major process upgrades have been implemented at the facility.
Currently the SWTP relies on the two FTUs installed in 1986. Raw water is pumped from two unlined raw water storage ponds to the FTUs, where treatment is provided through integrated adsorption, clarification, and filtration processes within the packaged units. Following filtration, treated water is disinfected and conveyed to the finished water clearwell. Finished water is then pumped to the City’s storage tanks for distribution throughout the service area.
Raw Water Storage. The Summers Lane Reservoir is an engineered raw water storage facility located at the southern extent of the City’s water system. The reservoir currently provides 45 AF of raw water storage and serves as an important operational asset for managing seasonal variability in surface water supplies. Waterfall Gulch serves as the City’s primary supply source through a dedicated conveyance pipeline, with the associated reservoir operated as supplemental storage to support the system during periods of low streamflow, planned or unplanned outages, and other operational constraints affecting the City’s surface water supplies.
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The City is in the process of expanding the Summers Lane Reservoir system through construction of three additional 45 AF reservoirs, which will be hydraulically connected in series with the existing reservoir. This expanded storage is intended to enhance drought resilience, improve operational flexibility, and reduce vulnerability to short-term supply interruptions and to provide seasonal storage and operational flexibility. Their role in drought management and potable reuse integration is discussed in Chapter 2 and Chapter 4.
Finished Water Storage. The City maintains four finished water storage tanks that provide operational storage, pressure regulation, and system reliability across the distribution system.
Three tanks, each with a capacity of approximately 4.6 AF each, are located adjacent to the SWTP and primarily serve the lower elevation pressure zones. A fourth finished water tank, with a capacity of approximately 9.2 AF, is located just outside the City limits and serves higher elevation areas, providing additional hydraulic head and pressure stabilization for upland portions of the service area.
Collectively, the finished water storage system provides approximately 23 AF of total storage capacity. The finished water tanks support diurnal demand balancing, emergency response, fire protection, and operational flexibility, and play a critical role in maintaining system pressure and reliability during peak demand periods or treatment plant outages. (d) Wastewater System
The City’s wastewater system consists of a network of gravity sewers, pump stations, and force mains that collect and convey wastewater from residential, commercial, and public users throughout the service area to the City’s Wastewater Treatment Plant (WWTP). The system is designed to efficiently transport wastewater while minimizing pumping requirements through the use of topography and strategically located lift stations.
Wastewater Treatment Plant. The WWTP employs an extended-aeration activated sludge process with secondary clarification and disinfection. Treated effluent is discharged through a permitted ocean outfall extending approximately 690 feet offshore. Residual solids are stabilized, dewatered, and managed in accordance with regulatory requirements. Upgrades completed in 2020 improved treatment reliability, solids handling, and wet-weather performance. The facility currently treats an average dry-weather flow of approximately 0.8 MGD and produces secondary effluent of consistent quality suitable for advanced treatment. The WWTP represents a key asset for potable reuse planning by providing a continuous, locally controlled source of municipal wastewater. The implications of this resource for long-term water supply reliability are addressed in Chapter 2 and Chapter 4.
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2. STATEMENT OF PROBLEMS AND NEEDS
Describe key water resource management problems and needs for which the project will provide a solution, including the following information. All projections shall be reasonable and applicable for a minimum of 20 years.
This chapter establishes why a new water supply is needed. It documents Fort Bragg’s reliance on highly variable local surface water, the physical and environmental limits on alternative sources, and the community’s constrained financial capacity. Together, these conditions create a structural vulnerability that cannot be resolved through conservation, storage, or emergency measures alone. The chapter frames potable reuse as a resilience strategy focused on reliability under drought and climate variability rather than growth, and defines the core problem the Proposed Project is intended to solve.
(a) Problems and Needs
Description of the problem and need for a water reclamation, recycling, or desalination project.
Fort Bragg faces persistent challenges associated with limited and highly variable water supplies due to its exclusive reliance on three local surface water sources: the Noyo River, Newman Gulch, and Waterfall Gulch. These sources are strongly dependent on seasonal rainfall and exhibit pronounced fluctuations in both quantity and quality. During drought conditions, available flows can diminish significantly, leading to water shortages and mandatory restrictions. Unlike many communities in California, Fort Bragg does not receive imported water from State or Federal projects and therefore lacks access to supplemental supplies during dry periods. This complete dependence on local surface water increases the City’s vulnerability to hydrologic variability and climate-driven extremes.
The City has experienced long-standing water supply challenges since the 1990s, driven by fluctuations in available source water that are expected to become more pronounced as climate change impacts increase. Fort Bragg’s climate is coastal and Mediterranean, with most precipitation occurring between October and April, with some rainfall during summer months.
Since the early 2000s, Mendocino County has endured frequent and intense drought conditions, including an extended period from 2020 through 2022 that prompted a statewide drought emergency. Although periods of heavy precipitation can temporarily improve conditions, the region remains highly susceptible to rapid transitions between wet and dry cycles. These patterns make reliance on short-term emergency measures an unsustainable long-term strategy.
Accordingly, the City is prioritizing projects that expand and diversify its water supply to provide citywide drought resilience
Operationally, the City’s water system is supplied primarily via gravity flow from the three surface water sources. During winter and spring, Waterfall Gulch and Newman Gulch typically provide the majority of supply and generally produce higher-quality raw water due to gravity conveyance.
As summer progresses and tributary flows diminish, the City increasingly relies on the Noyo River diversion, which must be pumped and is subject to both quantity and quality constraints. The Noyo River serves as the City’s primary source of drinking water, providing approximately 64 percent of total supply. Historically, this source has been affected by insufficient flows during summer and fall drought periods and by high turbidity during winter storms. In late summer, river flows can become so low that even at low tide the volume available for diversion is limited, while City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 2 Page | 8
at high tide salinity levels may exceed the City’s treatment capabilities. This variability compromises supply reliability and places the City at risk of being unable to meet essential demands, including firefighting flows.
In response to these constraints, the City has explored interim and innovative measures. Since fall 2021, Fort Bragg has operated a pilot-scale desalination demonstration project using the existing Noyo River intake to pump brackish water during periods of low streamflow and high tides. This pilot treats water prior to discharge to the raw water storage ponds, where it is blended and subsequently treated through conventional processes. The demonstration project is intended to evaluate feasibility under local conditions; it is not designed to provide a reliable or continuous water supply and cannot resolve the City’s long-term vulnerability.
Several structural conditions further constrain the City’s ability to address these challenges through conventional means.
Limited groundwater availability. Groundwater in the Fort Bragg area is stored primarily in fractured bedrock aquifers with low permeability and limited storage capacity, resulting in generally low well yields. Natural recharge is limited and seasonal, and coastal wells are vulnerable to saltwater intrusion. As a result, groundwater cannot serve as a viable long-term supplemental supply.
Limited storage. Prior to 2015, the City’s system could store only small volumes sufficient to maintain pressure and provide minimal fire protection. Since then, the City has made significant progress by constructing a 1.5 MG finished water tank and the Summers Lane Reservoir, increasing total storage to approximately 22.6 MG. In November 2022, the City Council approved acquisition of land for three additional 4.6 MG reservoirs, which will further improve seasonal flexibility. Even with these investments, the City remains dependent on variable surface inflows to fill storage and requires a firm, controllable source to convert storage into true drought resilience.
Seasonal precipitation patterns. Most rainfall occurs during winter months, requiring supplies collected during wet periods to last through long, dry summers. During drought years, surface water levels drop, leading to restrictions and potential shortages. Climate change is expected to increase the frequency and severity of these conditions.
Environmental Impairment. The Noyo River is listed under Clean Water Act Section 303(d) as impaired. These impairments affect both municipal use and aquatic habitat, including threatened salmonids. Reducing reliance on this sensitive source during critical periods is an important management objective. Key impairments on the Noyo River include:
• Sedimentation: Excessive sediment from logging, erosion, and development reduces water clarity, fills spawning beds, and degrades habitat for fish and other aquatic species. • High Water Temperature: Deforestation, reduced riparian vegetation, and shallow water flow increase temperatures, making the river less hospitable for cold-water fish species. • Flow Reduction: Water diversions and seasonal drought conditions contribute to low streamflow, further stressing aquatic ecosystems.
• Nutrient and Pollution Concerns: Runoff from agricultural and urban sources may introduce excess nutrients or pollutants that degrade water quality.
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Fort Bragg’s challenges are compounded by community conditions. The City’s economic base has undergone a long-term transition since the closure of the Georgia-Pacific mill, with tourism and service industries now predominating. Over this period, the City has experienced little to no net population growth, underscoring that water infrastructure planning is driven by reliability and resilience rather than growth accommodation. The City’s 2024 median household income is approximately 55 percent of the statewide median, qualifying Fort Bragg as a Severely Disadvantaged Community. This designation reflects limited ratepayer capacity to absorb large cost increases and constrains the range of feasible solutions. Investments must protect public health and system reliability while remaining affordable and operationally realistic, with external funding playing a critical role.
Taken together, these conditions define the City’s central water-supply problem: Fort Bragg requires a reliable, locally controlled source of water that is less sensitive to hydrologic variability, protects environmental resources, and can be implemented in a manner consistent with community affordability. Emergency measures and incremental storage alone cannot resolve this structural vulnerability. The need is therefore for a durable solution that converts existing local resources into a firm supply and provides long-term drought resilience. (b) Current and Projected Water Supplies
Description of current and projected water supplies, including water rights, and potential sources of additional water other than the proposed water reclamation, recycling or desalination project, and plans for new facilities other than the proposed project.
Current Supplies. The City’s water supply relies entirely on three local surface water sources:
Waterfall Gulch, Newman Gulch, and the Noyo River. Fort Bragg holds both appropriative and pre-1914 water rights to support its municipal water supply. Appropriative rights, which are granted by the State Water Resources Control Board (SWRCB) through permits and licenses, authorize the use of water on non-riparian lands or for uses beyond natural flow conditions. The City holds SWRCB-issued appropriative rights for Waterfall Gulch (480 AFY) and the Noyo River (2,172 AFY); however, total appropriative use is limited to 1,500 acre-feet per year under regulatory constraints. These rights establish the City’s legal entitlement to divert water, but do not ensure that physical supplies will be available during drought conditions, when streamflows may fall below diversion thresholds. This makes existing physical production potential of 1,500 to 1,600 AF.
In 2025, 688 AF were delivered to customers for beneficial use, while an estimated 900 AF were discharged to the ocean outfall due to limited storage and system capacity. This operational pattern illustrates that Fort Bragg’s constraint is not legal entitlement, but the ability to capture, store, and manage variable surface water supplies. Accordingly, existing “supply” for planning purposes is represented by delivered water in 2025 (688 AF), while the difference between production and use reflects the volume of water that could be converted into a reliable resource through additional storage and potable reuse infrastructure.
To address long-standing supply vulnerabilities, the City has proactively evaluated multiple strategies to enhance reliability, including assessment of existing surface water sources, infrastructure performance, emergency storage needs, and innovative technologies such as pilot desalination. These efforts reflect an incremental, risk-based approach to strengthening the system under increasing hydrologic variability.
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At the outset of the 2015 drought emergency, the City’s system lacked adequate storage, providing only minimal reserves necessary to sustain pressure and meet fire flow requirements.
To improve drought resilience, the City constructed the Summers Lane Reservoir in 2016, providing 45 acre-feet of raw water storage for supply diverted primarily from Waterfall Gulch.
This facility marked a significant shift toward seasonal water management, allowing the City to capture excess winter flows and carry them into the dry season. The City also implemented major capital improvements, including construction of a 1.5 MG finished water storage tank. These investments increased total storage to approximately 22.6 million gallons, representing roughly 45 days of emergency supply based on an average daily demand of 500,000 gallons. This expanded storage capacity and substantially improved drought preparedness and operational flexibility, but did not change the City’s fundamental dependence on variable surface inflows.
Projected Supplies. With the Proposed Project, projected water supplies are expected to increase substantially by 2040, from 688 AFY to approximately 1,495 AFY based on current planning estimates (see Figure 2-1). To support this growth in supply and meet hydraulic retention time (HRT) requirements for indirect potable reuse, the City is in the design phase for three additional 45 AF off-stream reservoirs that will expand the City’s storage capacity (see Table 2-1). In addition to expanding seasonal storage, the new reservoirs are a critical component of the City’s potable reuse framework. For IPR, State regulations require a minimum hydraulic retention time (HRT) between advanced treatment and reintroduction to the drinking water system to provide environmental buffering and operational response time. The off-stream reservoirs provide this required detention volume, allowing advanced-treated water to be stored for the prescribed period before recovery. Without dedicated off-stream storage, the City would be unable to meet HRT requirements for IPR, effectively constraining or precluding potable reuse implementation.
Figure 2-1 ExisƟng and Projected Water Supplies
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These new facilities are planned adjacent to the existing Summers Lane Reservoir and are designed to be filled during high-flow winter periods using surface water diverted from the Noyo River and gravity-fed from Waterfall Gulch, thereby minimizing ecological impacts during lowflow summer periods. Stored water will be available for use during drier months, reducing withdrawals from ecologically sensitive surface waters. The design includes associated inlet and outlet piping and integration with the City’s existing system infrastructure. The reservoir embankments are being sized so that they remain outside the jurisdiction of the California Division of Safety of Dams.
Table 2-1 ExisƟng and Future Storage FaciliƟes
Storage Facility Status
Year
Complete
Storage
Capacity
(AF)
Storage
Capacity
(MG)
Pre-2016 Existing -- 20 6.4
Summers Lane Reservoir Existing 2016 45 14.7
Finished Water Storage Tank Existing 2021 4.6 1.5
Planned Reservoir 1-3 Planned 2032 135 44.1
2035 Total Storage Capacity 204.3 60.3
In parallel, the City is undertaking a comprehensive SWTP modernization project. Improvements include upgrades to filtration systems, chemical feed pumps, process piping, valves, meters, and Supervisory Control and Data Acquisition (SCADA) systems. The project also involves rehabilitation of treatment tanks, relocation and modernization of the laboratory, and construction and repair of facility buildings. These upgrades will enhance operational efficiency, support regulatory compliance, reduce water losses, and improve labor productivity at the SWTP. Construction is anticipated to be completed in Spring 2026.
Collectively, these investments strengthen the City’s ability to capture, treat, and manage local surface water. However, even with expanded storage and modernized treatment facilities, the system remains constrained by the availability of surface water to fill reservoirs during drought years. Storage alone cannot create supply when inflows are insufficient. The City therefore continues to face a structural gap between legal water rights and physically available water during extended dry periods, underscoring the need for a new, reliable source that is less dependent on hydrologic conditions.
(c) Current and Projected Water Demand
Description of current and projected water demands, including a description of the current and projected water supply and demand imbalances.
The City’s total water demand in 2025 was approximately 688 acre-feet per year. The majority of water use is residential, accounting for approximately 82 percent of total demand, while commercial and industrial uses comprise the remaining 18 percent. These demands are met entirely with local surface water supplies.
Fort Bragg’s reliance on surface water makes its ability to meet demand highly sensitive to annual weather patterns. Surface water flows are dependent on seasonal precipitation and are expected City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 2 Page | 12
to become more variable as a result of aridification and climate change. Without adequate snowpack and rainfall, the City’s existing sources may not produce sufficient flows to meet demands, even under normal operating conditions. During extended dry periods, the City is forced to operate under emergency conditions, imposing restrictions that burden residents and businesses in an already severely disadvantaged community. A new, reliable water supply would allow the City to continue meeting demands entirely with local resources while reducing dependence on emergency measures. By providing a firm source that is not tied to surface hydrology, the Proposed Project would enable the City to maintain essential service levels during drought conditions and protect public health, safety, and economic stability.
Current and projected demand is shown in Table 2-2. Population-related demand projections assume a conservative annual growth rate of 0.5 percent to account for modest, project-specific increases in demand associated with two planned developments on Main Street and Hazelwood Drive and the phased redevelopment of the Mill Site, which is expected to commence around 2030. This assumption does not reflect broad population growth, but rather accommodates incremental demand associated with known development activity.
Table 2-2 Current and Projected Demand
Baseline
Demand
Development
Demand
(AFY)
Total
Demand
Year (AFY) (AFY)
2025 688 0 688
2030 703 +13.4 716
2035 721 +15 749
2040 739 +30 798
2045 758 +30 848
2050 870 0 870
Based on anticipated development at S Main/Hazelwood and Mill Site and a normal growth rate of 0.5%
Under these assumptions, total demand is projected to increase from approximately 688 AFY in 2025 to approximately 870 AFY by 2050. Although this growth is modest, it compounds the City’s existing supply vulnerability. Even under current demand levels, the City experiences constraints during dry years. As demand gradually increases, the margin between available surface water and system needs will narrow further, increasing the frequency and severity of shortages absent a new, drought-resilient supply.
The imbalance between variable surface water availability and relatively fixed municipal demand highlights the City’s core planning challenge. Demand for potable water is continuous and nondiscretionary, while supply is seasonal and increasingly unpredictable. Without diversification of supply, this mismatch will continue to expose the community to service interruptions, emergency response measures, and escalating operational risk.
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(d) Water Quality Concerns for Current and Projected Water Supply Description of any water quality concerns for the current and projected water supply.
The Noyo River is the City’s primary water source and an essential ecological resource for the region. However, it faces persistent water quality challenges that affect both municipal use and the health of the river ecosystem. As a result of these conditions, the Noyo River is listed on the 2024 Clean Water Act Section 303(d) list as an impaired water body. Sedimentation is a primary concern, driven by a long history of logging, road construction, and erosion within the watershed.
Elevated sediment loads reduce water clarity, fill pools, degrade spawning habitat, and increase turbidity, complicating treatment at the City’s water plant. These impacts reduce habitat quality for native fish species, including coho salmon and steelhead trout, and increase operational challenges for municipal treatment.
During the dry summer months, the river also experiences elevated temperatures and low dissolved oxygen levels, conditions that further stress cold-water species and reduce overall aquatic health. Nutrient inputs from erosion and runoff can contribute to algal growth and localized eutrophication, exacerbating oxygen depletion and harming sensitive habitats.
Another critical issue is saltwater intrusion. In late summer, when freshwater flows drop to very low levels, tidal influence can push saline water upstream into the City’s intake. During these periods, raw water salinity can exceed the treatment capabilities of the City’s Surface Water Treatment Plant, threatening the reliability of the municipal supply. This risk prompted Fort Bragg to deploy portable desalination units during recent drought emergencies to maintain drinking water quality and continuity of service.
These water quality challenges underscore the importance of reducing dependence on the Noyo River during critical low-flow periods and protecting instream conditions. Continued reliance on a single, impaired surface water source concentrates both operational and environmental risk.
By investing in water reuse, the City of Fort Bragg can reduce withdrawals from sensitive surface waters, support aquatic habitat health, and build resilience against drought and climate change impacts while maintaining safe and reliable potable service.
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3. WATER RECLAMATION, RECYCLING OR DESALINATION OPPORTUNITIES Address the opportunities for water reclamation, recycling, and desalination in the study area, and identify the sources of water that could be reclaimed or desalinated, including the following sections.
This chapter describes the range of alternative water supply opportunities available to the City, including non-potable reuse, potable reuse, and desalination. It summarizes prior planning efforts, pilot projects, and regulatory considerations, and places Fort Bragg’s options within a broader technical and policy context. The chapter clarifies why non-potable reuse and emergency desalination alone are insufficient to meet the City’s long-term needs and establishes potable reuse as a viable and scalable pathway for achieving drought resilience. (a) Reclaimed or Desalinated Water Uses
Description of all uses for reclaimed or desalinated water, or categories of potential uses, including but not limited to environmental restoration, fish and wildlife, groundwater recharge, municipal, domestic, industrial, agricultural, power generation, and recreation. Identify any associated water quality, and associated treatment requirements.
The City evaluated multiple water reuse alternatives to identify the most cost-effective solution to improve the long-term reliability and drought resilience of its potable supply for the residents and businesses of Fort Bragg. The alternatives considered included non-potable recycled water for irrigation use and three methods to produce potable water: surface water augmentation, raw water augmentation, and treated water augmentation. A market analysis determined that nonpotable recycled water is economically infeasible due to its relatively low demand and the extensive infrastructure required to deliver it to geographically dispersed user locations. A detailed discussion and comparative analysis of the remaining alternatives is provided in Chapter
4. The remaining potable reuse options were further evaluated because they can directly augment the City’s drinking water supply.
Water reuse through IPR and DPR represent opportunities to bolster reliability, diversify supply, enhance drought resilience, and support growth and land use goals. All end uses are ultimately potable water supply applications, serving domestic, commercial, industrial, and fire-protection demands through the City’s water system.
(b) Available Water Market
Describe the water market available to utilize reclaimed, recycled, or desalinated water, including:
(i) Existing and Potential Users
Identification of existing and potential users, expected use, peak use, on-site conversion costs, if necessary, desire to use reclaimed, recycled, or desalinated water, including letters of intent if available.
All applications of project water will supplement potable (drinking) water supplies. (ii) Customer Consultation
Description of consultation with potential reclaimed, recycled, or desalinated water customers. Letters of intent must be included, if applicable.
The City completed a comprehensive stakeholder communication and outreach program to establish a transparent framework for engaging residents, businesses, and community organizations on the evaluation of recycled water alternatives. Through a town hall meeting, digital outreach, and public surveys, the City built broad community awareness and support for recycled water as a sustainable, locally controlled supply that enhances drought resilience and long-term water security. Educational materials, including a project flyer, website, and City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 3 Page | 15
other online resources, helped increase public understanding of alternative treatment processes, project costs, and the environmental and sustainability benefits for the community.
This proactive communication effort strengthened community confidence in the City’s planning process and demonstrated the value of structured, two-way engagement in advancing complex water infrastructure initiatives within a small coastal community.
Additional details on the City’s outreach program are included in Chapter 7. (iii)Market Assessment Procedures
Description of the market assessment procedures used.
A market analysis was conducted in 2025 to determine the potential use of non-potable recycled water in the Fort Bragg service area. For this analysis, the City identified its five largest irrigation customers—two schools, a mobile home park, and two commercial properties. Using irrigation meter data from the schools and assuming 30 percent of total water use at the unmetered sites would be for irrigation, the total potential non-potable recycled water demand was estimated at approximately 0.02 MGD.
A subsequent analysis expanded the evaluation to include the original five sites plus nine additional locations identified through a visual assessment of irrigable areas typically suitable for non-potable recycled water use. Applying the same methodology, the total potential demand increased to approximately 0.08 MGD. A third evaluation applied irrigation requirements derived from the California Department of Water Resources (DWR 2000) guidance for landscape plantings to estimate a theoretical non-potable recycled water demand of approximately 0.17 to 0.20 MGD.
Although 17 potential sites were identified, their dispersed locations would necessitate extensive conveyance and distribution infrastructure. Given the relatively low aggregate demand and the high cost of system development, implementation of a non-potable reuse system was determined to be economically infeasible. This assessment procedure is documented in Appendix C Recycled Water, IPR, and DPR Feasibility Evaluation TM. No further studies were conducted.
(c) Market Assurances
Strategies and commitments to ensure the viability of demand for recycled water.
Non-potable recycled water was eliminated as an alternative due to limited local demand, the need for extensive new distribution infrastructure, and the relatively low reliability and cost effectiveness compared to potable reuse options. Prior to that assessment, market assurances for non-potable recycled water were evaluated. These assurances involve strategies and commitments to ensure the viability and demand for recycled water and help mitigate risks for utilities by ensuring there will be a stable and sufficient market for the non-potable recycled water produced. The three market assurance strategies analyzed are defined in the Market Assurances TM. However, because the proposed project advances potable water reuse, the City does not need to implement a strategy to establish or secure non-potable recycled water demand.
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(d) Discussion of Considerations
Discussion of considerations (for example: physical, converting systems for reused water, or public acceptance) which will prevent implementing a water reclamation, recycling, or desalination project. Identification methods or community incentives to stimulate reclaimed, recycled, or desalinated water demand, and methods to eliminate obstacles which will inhibit the use of reclaimed, recycled, or desalinated water, including pricing.
The City conducted a survey to assess community awareness and opinions regarding the City's current water supply and potential alternative water sources. The survey gauged public understanding of the current water conditions and drought risk, evaluate community receptiveness to alternative water supply options, and identify key factors that influence public acceptance of advanced water treatment technologies.
The survey found strong community support for exploring additional local water supply options and non-potable recycled water, but only moderate acceptance of potable reuse, with significant portions of respondents needing more information about that alternative. To build community support for a potable reuse project, the City would need to educate their customers about treatment process and leverage trusted information sources, such as healthcare professionals, scientists, and regulators, to build trust in this type of project. The City would also need to redirect support from the popular but financially unviable recycled water option to IPR and communicate how the preferred alternative better serves Fort Bragg's specific circumstances.
A major concern with building an alternative water source project is cost and rate increases to pay for the project. If the City moves forward with its preferred alternative, it must demonstrate the current value customers receive for their water costs, explaining long-term cost benefits of proactive infrastructure investment, and actively pursuing alternative funding sources including grants and low-interest loans to offset ratepayer costs.
Respondents’ top priority is that the project produce clean and safe water, so the City must communicate information about treatment technologies and rigorous monitoring protocols.
Additionally, the City could showcase successful project implementation in other communities, documenting operational history, safety performance data, and regulatory compliance records.
These findings underscore that public acceptance of potable reuse is not a box to be checked during planning, but a condition that must be actively maintained over time.
Ongoing Community Engagement and Acceptance
Potable reuse raises a different set of community concerns than most other water projects, particularly in a small, close-knit community like Fort Bragg. While the City’s initial outreach and survey work show growing interest in alternative supplies, they also make clear that comfort with potable reuse varies and cannot be assumed. Acceptance is not something that is achieved once during planning and then carried forward automatically. It must be built, reinforced, and sustained over time.
For that reason, implementation of the Proposed Project will require an ongoing, transparent engagement program that continues well beyond this feasibility study. Regular public updates, clear and accessible reporting of water quality results, facility tours, and coordination with trusted local voices—such as healthcare providers, educators, and regulators—will be essential.
This type of sustained engagement helps shift potable reuse from being perceived as a novel or abstract concept to being understood as a normal, well-managed part of the City’s water system.
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Recognizing community acceptance as a long-term operational responsibility, rather than a onetime planning task, strengthens the City’s ability to implement the Proposed Project in a way that is durable, trusted, and aligned with community values. (e) Water and Wastewater Agency Identification
Identification of all the water and wastewater agencies that have jurisdiction in the potential service area or over the sources of reclaimed, recycled, or desalinated water.
Fort Bragg Municipal Improvement District No. 1
The Fort Bragg MID No. 1 is a legally established special district formed to manage and finance essential public utility services within the City. Governed by the Fort Bragg City Council acting in its dual capacity as the MID Board, the MID serves as the operating entity for the City’s wastewater and water utilities.
The MID’s primary responsibilities include:
Wastewater Collection, Treatment, and Disposal: The MID owns and operates the City’s wastewater treatment plant and collection system, which provides secondary treatment and ocean outfall disposal for municipal and commercial sewage. The District ensures regulatory compliance with the Clean Water Act through adherence to its NPDES permit and all applicable regional and State water quality standards.
Potable Water Supply, Treatment, and Distribution: The MID operates the City’s surface water supply system, including raw water intakes on the Noyo River and tributary creeks, the Fort Bragg Water Treatment Plant, and the potable water distribution network. The MID ensures reliable delivery of safe drinking water to the community in accordance with all regulations enforced by the SWRCB Division of Drinking Water.
Capital Project Delivery and Infrastructure Planning: The MID is responsible for planning, financing, and implementing capital improvement projects to maintain, upgrade, and expand its water and wastewater infrastructure. These efforts are guided by long-term strategic planning documents, such as the Water Master Plan and Wastewater Facilities Plan.
Environmental Stewardship and Resilience Planning: Recognizing the environmental sensitivity of Fort Bragg’s coastal location, the MID prioritizes climate resilience, water conservation, and habitat protection in its infrastructure and operational strategies. Projects frequently incorporate green infrastructure, energy efficiency measures, and adaptation to sea-level rise and drought.
Financial Management: As an enterprise-funded entity, the MID is financially self-supporting through user fees, connection charges, and service revenues. The MID prepares independent budgets and rate studies to ensure fiscal sustainability and appropriate cost allocation among system users.
The MID plays a vital role in protecting public health, supporting economic development, and ensuring environmental sustainability through the delivery of essential water and wastewater services to the Fort Bragg community.
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(f) Source Water Description
Description of the potential sources of water to be recycled, including impaired surface or ground waters.
The source of project water is the wastewater treated at the Fort Bragg Wastewater Treatment Plant (WWTP), which is generated from customers connected to the wastewater collection system within city limits and MID No. 1. Wastewater generation in Fort Bragg is directly tied to potable water use, which relies primarily on surface water supplies from the Noyo River and its tributary sources at Waterfall Gulch and Newman Gulch.
(g) Location of Source Water Facilities
Description and location of the source water facilities, including capabilities, existing flows, treatment processes, design criteria, plans for future facilities, and quantities of water available to meet new reclaimed, recycled, and desalinated water demands.
The City owns and operates a municipal wastewater treatment facility located near the City’s coastline. This facility, shown in Figure 3-1, serves as the City’s primary wastewater treatment plant, treating both residential and commercial wastewater flows. Treated effluent is discharged into the Pacific Ocean via a permitted ocean outfall pipeline that extends about 690 feet offshore.
Figure 3-1 Wastewater Treatment Plant
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The WWTP includes preliminary headworks for initial screening and grit removal, followed by biological treatment using an Aero-Mod SEQUOX extended aeration activated sludge system, and a chlorine disinfection/dechlorination process utilizing sodium hypochlorite and sodium bisulfite, respectively. The Aero-Mod system consists of a selector tank, first-stage aeration (nitrification) tanks, second-stage aeration (denitrification) tanks, and clarifiers for liquid-solids separation.
Sludge generated from this process undergoes aerobic digestion and is subsequently dewatered and stored prior to final disposal. The process flow diagram in Figure 3-2 shows these steps.
The plant was upgraded in 2020 to treat an average dry weather flow (ADWF) of 0.8 MGD and peak wet weather flows of up to 4.9 MGD. Under normal conditions, the facility treats approximately 0.64 MGD. However, during heavy rainfall events, infiltration and inflow can temporarily exceed the plant’s hydraulic capacity, posing operational and environmental challenges. Figure 3-3 shows the total daily flow entering the WWTP between 2020 and 2024 as well as local rainfall totals.
Figure 3-2 WWTP Simplified Process Flow Diagram
Figure 3-3 Total Daily Flows to WWTP 2020 to 2024
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The WWTP monitors influent flows at two locations. INF-001 measures raw influent upstream of the headworks, representing the total flow entering the treatment plant prior to screening and grit removal. INF-002 measures flow after the influent pump station, reflecting conditions following preliminary treatment. The two influent flow meters generally track together, although operators have observed some inconsistencies in flow measurements particularly at low and high flows. INF-001 readings are less accurate at low flows, making influent volume assessments less precise. Conversely, during high-flow events, rapid hydraulic shifts can affect the accuracy of INF002. Therefore, INF-001 is more representative during peak flow events, while INF-002 is more accurate at capturing dry weather conditions.
Overall, the WWTP has demonstrated consistent and reliable performance, effectively removing organic matter and solids while maintaining stable effluent quality. As summarized in Table 3-1, treated effluent water quality data from 2020–2024 show that BOD, TSS, and turbidity concentrations are consistently well within applicable NPDES effluent limitations, with high removal efficiencies, stable pH, and effective control of ammonia, chlorine residual, and total coliform bacteria. Historical performance indicates that nitrification and denitrification processes are functioning as intended, resulting in low effluent nitrogen concentrations and an average effluent turbidity of approximately 4.6 NTU, supporting the suitability of the treated effluent as feedwater for the proposed advanced treatment application.
Table 3-1 WWTP NPDES Compliance and Performance Summary Effluent flow data from 2021 to 2024 analyzed in 15-minute intervals is presented in Figure 3 4 as the four-year median value. The figure shows the diurnal flow variation through the WWTP over the course of a day as well as by season. The flow patterns during dry weather months (MayNovember) are relatively consistent, with wet weather months (December-April) having higher and more variable flow rates. Based on diurnal flow variability and seasonal variability due to infiltration and inflow (I&I), flow equalization is included in the proposed project 2020-2024 NPDES Effluent Limitations
Parameters Units Avg 95th
Percentile
Max
Daily
Avg
Monthly
Avg
Weekly
Max
Daily
Instant
Min
Instant
Max
6-Mo.
Median
BOD mg/L 5.9 9.8 29 30 45 -- -- -- --
BOD Removal % 97 -- -- 85 -- -- -- -- --
TSS mg/L 6.7 13 33 30 45 -- -- -- --
TSS Removal % 97 -- -- 85 -- -- -- -- --
Turbidity NTU 4.6 8.7 99.4 75 100 -- -- 225 --
pH - 6.9 7.2 7.4 -- -- -- 6 9 --
Ammonia mg/L-N 0.95 1.7 56.5 -- -- 122 -- 306 30.6
Total Chlorine
Residual µg/L 2.6 4.8 8.8 -- -- 408 -- 3,060 102
Total Coliform
Bacteria
MPN/100
mL 64 175 1,600 -- -- -- -- 230 --
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.
(h) Current Water Reclamation Description
Description of any current water reclamation, recycling or desalination taking place in the study area, including a list of reclaimed water uses, type and amount of reuse, and a map of existing pipelines and use sites.
Currently there is no water reclamation or recycling taking place in the study area. In response to recurrent droughts and declining surface water reliability from the Noyo River, particularly during 2015 and 2021, Fort Bragg is pursuing water reuse strategies as sustainable solutions to augment its water portfolio.
The WWTP serves as the City’s primary wastewater treatment plant, processing an average of
0.8 MGD of wastewater for discharge to the Pacific Ocean via a permitted ocean outfall pipeline.
The WWTP has demonstrated consistent performance, effectively removing organic matter and solids while maintaining stable effluent quality. The proposed feedwater quality for reuse planning based on historical effluent water quality from the WWTP is summarized in Table 3-2.
The data indicate low to moderate concentrations of organic matter and suspended solids, low nutrient levels, stable pH, and relatively low turbidity under typical conditions. Overall, the results reflect consistent influent water quality suitable for conventional and advanced treatment processes.
Figure 3-4 Diurnal Effluent Flow Trends
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Table 3-2 Proposed Feedwater Quality
Parameters Units Average Min 95th
Percentile
BOD mg/L 5.9 5 9.8
TSS mg/L 6.7 3 13
Turbidity NTU 4.6 0.9 8.7
Ammonia mg/L-N 0.5 0 1.5
Nitrite mg/L-N 0 0 0.2
Nitrate mg/L-N 1 0 3.1
Phosphate mg/L-PO4 7.9 0.7 16
pH - 6.9 6.1 7.2
Temperature °C 18.9 13.2 24.2
In addition to pursuing water reuse, the City has evaluated wave-powered and portable desalination solutions. In 2023, the City received a $1.49 million DWR grant to pilot a buoy-based desalination system developed by Oneka Technologies, the first CEQA-approved, wave-powered desalination pilot project in California. Operating solely on wave energy, the offshore buoy produces about 13,200 gallons per day (0.013 MGD) of potable water without external power.
The 12-month pilot, located near the wastewater treatment plant, began in November 2025 to evaluate performance, environmental effects, and regulatory feasibility.
The City deployed portable containerized reverse osmosis units during the 2021 drought, when tidal intrusion raised salinity levels in the Noyo River and threatened the municipal supply.
Installed near the Matson Hole diversion site, these emergency systems provided reliable drinking water and maintained regulatory compliance during extreme low-flow conditions.
The City’s desalination efforts are intended to serve as emergency or exploratory measures rather than as a scalable, long-term water supply solution. The portable reverse osmosis units deployed during the 2021 drought were implemented as a temporary response to acute salinity intrusion in the Noyo River and were not designed for continuous operation, system-wide integration, or long-term affordability. Similarly, the wave-powered desalination buoy is a pilot project intended to evaluate technical feasibility, environmental effects, and regulatory considerations under local conditions. Its production capacity is small relative to Citywide demand and is not sufficient to provide a firm, system-scale supply.
These initiatives demonstrate the City’s willingness to innovate and respond to emergencies, but they are not substitutes for a permanent, reliable water supply. In contrast, potable reuse converts an existing, continuous wastewater flow into a controllable resource that can be integrated with storage and treatment infrastructure and operated at scale during drought and emergency conditions. Accordingly, desalination is best understood as an emergency or research tool within Fort Bragg’s water portfolio, while the Proposed Project represents the City’s longterm strategy for drought resilience and supply reliability.
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(i) Current and Projected Wastewater and Disposal Options Description of current and projected wastewaters and disposal options other than the proposed water reclamation, recycling or desalination project, and plans for new wastewater facilities, including projected costs, if any.
The City of Fort Bragg, operating as the Fort Bragg MID No. 1, manages all municipal wastewater collection, treatment and disposal within the City.
Current Wastewater and Disposal PracƟces. Wastewater collected from users is treated at the City’s wastewater treatment plant. The plant provides secondary treatment and disinfecƟon prior to discharge through a 690-foot ocean ouƞall extending into the Pacific Ocean. The exisƟng ocean ouƞall remains the sole disposal method for treated effluent.
Projected Wastewater Management. The City completed a comprehensive Wastewater Treatment Facility Study in 2022 to assess system condiƟons, regulatory compliance, and longterm capacity needs. The study found that the exisƟng treatment and disposal infrastructure had adequate capacity to meet projected wastewater flows associated with planned growth, including redevelopment of the former Georgia-Pacific mill site. The report also idenƟfied the need for modernizaƟon of the exisƟng treatment faciliƟes to improve reliability, reduce blending during wet-weather events, and replace aging mechanical and electrical equipment.
Future ConsideraƟons. No new or alternaƟve wastewater disposal faciliƟes are planned, and the City will conƟnue to rely on the exisƟng ocean ouƞall for treated effluent disposal. OpportuniƟes for recycled water use are being evaluated to reduce the volume of future discharges. (j) Summary of Technology Currently in Use
Summary of any water reclamation, recycling, or desalination technology currently in use in the study area, and opportunities for development of improved technologies.
Currently, the City of Fort Bragg does not operate any full-scale water reclamation, recycling, or desalination facilities. Treated effluent from the City's wastewater treatment plant is discharged to the Pacific Ocean under the terms of an NPDES permit, and no recycled water is presently produced for beneficial reuse.
Water Treatment Plant. The City’s SWTP was originally built in 1958 and has a 2.2 MGD capacity and ensures safe drinking water through proper treatment. The facility also includes a 45-acrefoot reservoir for raw water storage and utilizes two Filter Treatment Units (FTUs) that were installed in 1986. These FTUs process raw water pumped from two unlined storage ponds. The treated water is then disinfected and stored in a clear well before being pumped to storage tanks for distribution.
The City has initiated a comprehensive Water Treatment Plant Overhaul project to enhance efficiency, conserve water, and reduce labor requirements. As part of this effort, the City is rehabilitating the existing FTUs to meet current standards, ensuring improved filtration and treatment performance. Upgrades to plant piping, including flow meters and valves, will enhance system monitoring and control, while repairs and modifications to plant buildings, such as the addition of a new blower room, will improve operational functionality. The project also includes rehabilitating a 1.5 million gallon water storage tank to ensure adequate supply and system resilience. Additionally, approximately 560 linear feet of piping will be relocated and repaired to optimize system performance. To further improve water storage and quality, the city plans to City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 3 Page | 24
dredge and line raw water storage ponds, increasing capacity and preventing seepage. These improvements collectively aim to strengthen the water treatment plant’s capacity and reliability, ensuring it can effectively meet both current and future water demands.
Wastewater Treatment Plant. The WWTP employs an advanced secondary treatment process to remove solids, organic matter, and contaminants from wastewater before final discharge into the Pacific Ocean. This multi-stage treatment process ensures compliance with regulatory standards and minimizes environmental impacts. Preliminary treatment removes large debris, grit, and inorganic materials to protect downstream equipment and prevent system blockages.
In primary treatment, sedimentation tanks separate solids from liquids, forming sludge, while grease and oils are skimmed from the surface, significantly reducing suspended solids and organic load.
The secondary treatment phase utilizes an Aero-Mod SEQUOX activated sludge system, where microorganisms biologically break down organic matter in an oxygen-rich environment, enhancing nutrient removal and treatment efficiency. Following this, disinfection eliminates pathogens and harmful bacteria before the treated effluent is safely discharged via a submerged outfall pipeline extending 690 feet into the Pacific Ocean, ensuring proper dilution and environmental protection.
Recent upgrades, including improvements to pumping stations, flow equalization, and sludge dewatering, have enhanced the plant’s resilience and capacity to manage peak flows during wet weather. While the current system primarily relies on ocean discharge, potential future upgrades could incorporate advanced treatment technologies to facilitate water reclamation and reuse, reducing marine disposal and improving long-term water sustainability.
Opportunities for Technological Advancement. This Recycled Water Feasibility Study presents a significant opportunity to introduce advanced water reuse technologies in Fort Bragg. Several treatment options under consideration include:
• Tertiary and Advanced Treatment Upgrades: Integration of membrane filtration (e.g., microfiltration or ultrafiltration), UV disinfection, and advanced oxidation processes (AOP) to enable production of disinfected tertiary recycled water suitable for non-potable reuse.
• Modular Treatment Systems: Containerized or small-footprint systems could offer costeffective, scalable solutions for a small, dispersed customer base, particularly beneficial for a Severely Disadvantaged Community (SDAC).
• Onsite Reuse for Municipal Applications: Opportunities exist to treat and reuse water for irrigation of parks, landscaping, or other municipal properties, reducing demand on potable sources.
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4. DESCRIPTION OF PROPOSED PROJECT AND ALTERNATIVES
This chapter includes a description of the non-Federal funding condition, the planning criteria for evaluation, recommended alternatives for further analysis and discusses a no-project alternative.
This chapter defines the Proposed Project and the potable reuse alternatives evaluated in the feasibility study. It explains how each alternative would operate, how it would integrate with the City’s existing infrastructure, and the regulatory and operational implications of each configuration. The chapter establishes the technical assumptions used in subsequent analyses and describes how the City’s system would function under normal, drought, and emergency conditions. It provides a technical backbone for comparing alternatives and understanding how potable reuse would be implemented in Fort Bragg.
(a) Non-Federal Funding Condition
Description of the non-Federal funding condition. The reasonably foreseeable future actions that the City would take if Federal funding were not provided for the proposed water reclamation, recycling, or desalination project, including estimated costs.
The Proposed Project is intended to be implemented in a manner consistent with the non-Federal funding condition applicable to Reclamation Title XVI feasibility studies. The City anticipates that project costs would be supported through a combination of local funding sources and external funding opportunities, including potential State and Federal grants. No Federal funds are assumed to be committed to project implementation at this stage. The purpose of this feasibility study is to evaluate the technical, regulatory, and economic feasibility of potable reuse alternatives and to support future funding and implementation decisions by the City. If Federal funding is not secured, the City would be unable to advance the proposed recycled water project and would be forced to continue implementing the No Project alternative.
Under this scenario, the City would remain reliant on its existing surface water supplies and face escalating challenges in maintaining water reliability. Continued dependence on diminishing surface water sources would increase the City’s exposure to seasonal and long-term hydrologic variability, undermining its ability to meet current and future water demands. The lack of a diversified supply portfolio would not only reduce system resilience, but also lead to higher operational costs, increased vulnerability to regulatory non-compliance, and potential service disruptions during extended dry periods.
(b) Planning for Treatment Upgrades
The City’s evaluation of potable reuse alternatives builds upon a broader planning context that includes recent and ongoing efforts to modernize water and wastewater infrastructure, improve system resilience, and evaluate long-term water supply options. These planning initiatives, described below, provide the foundation for the Proposed Project and inform the selection and configuration of potable reuse alternatives evaluated in this study.
Policy and Planning Consistency. The Proposed Project is a direct extension of the City’s existing water-supply policies and planning efforts. The City’s Water Master Plan emphasizes the need to diversify local supplies, expand storage, and reduce reliance on the Noyo River during critical lowflow periods. Those priorities were underscored during the 2015 and 2021 drought emergencies, when the City implemented emergency conservation measures, deployed portable desalination units, and declared a Stage 4 water shortage in response to historically low river flows.
In the years since, the City Council has consistently directed staff to move beyond short-term City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 4 Page | 26
fixes and pursue durable, locally controlled solutions that improve drought resilience. That direction is reflected in Council actions authorizing expansion of the Summers Lane Reservoir system, modernization of the Water Treatment Plant, CEQA review of recycled water planning, and participation in alternative-supply pilot projects. The Proposed Project builds on this foundation by converting an existing wastewater resource into a reliable potable supply that can be deployed during seasonal shortages and drought emergencies.
By aligning with the City’s Water Master Plan, emergency drought response framework, and prior Council direction, the Proposed Project represents the next logical step in Fort Bragg’s long-term water strategy, rather than a departure from it.
CEQA Review of Recycled Water Facility Planning Study. In 2024, the City completed CEQA review for a Recycled Water Facility Planning Study, documenting the City’s intent to evaluate recycled water as part of its long-term water supply strategy. The planning study was explicitly scoped to evaluate recycled water service areas, potential treatment and conveyance alternatives, demands, costs, hydraulic capacity, pollution control benefits, and environmental considerations.
From a potable reuse perspective, this type of facilities planning study represents a foundational planning step. Although the study itself does not commit the City to potable reuse, it establishes the analytical framework necessary to assess whether advanced treatment pathways, such as Advanced Water Treatment (AWT) suitable for indirect or direct potable reuse, could be feasible in the future. Key elements relevant to potable reuse planning include:
• Identification of wastewater source reliability and volumes, which are prerequisites for any potable reuse program.
• Evaluation of treatment facility siting, which is critical for advanced treatment trains that require redundancy, monitoring, and residuals management. • Consideration of water quality objectives and regulatory pathways, which informs whether non-potable reuse alone is sufficient or whether potable reuse may be warranted to meet long-term supply deficits.
• Integration of recycled water planning with pollution control and environmental objectives, aligning with State expectations for multi-benefit water supply projects.
The planning study positioned Fort Bragg to formally investigate potable reuse as an option, as non-potable reuse alone has been found to be insufficient to meet drought resilience and reliability goals. In parallel with recycled water planning, the City has advanced several system reliability and supply diversification initiatives that are commonly considered enabling conditions for future potable reuse.
Water Treatment Plant Modernization. The City has undertaken major water treatment plant modernization efforts, including upgrades to treatment processes, mechanical and electrical systems, SCADA, and supporting facilities. These investments strengthen operational reliability, regulatory compliance, and operator capacity, each of which is essential if advanced treatment or potable reuse were to be considered in the future. A modernized treatment plant also provides greater flexibility for integration with advanced treatment facilities or blending strategies.
Storage and Operational Resilience Improvements. The City has also evaluated improvements to storage facilities and operational strategies to enhance resilience during drought and emergency conditions. These efforts include assessment of reservoir operations, storage City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 4 Page | 27
flexibility, and system redundancy to improve the City’s ability to manage variable hydrologic conditions. Potable reuse is being considered as a complementary strategy that would provide a drought-resilient supply independent of surface water availability, thereby strengthening overall system reliability when combined with existing storage and conveyance assets.
Desalination Pilot and Alternative Supply Evaluation. In addition to potable reuse planning, the City has evaluated other alternative water supply options, including non-potable reuse and desalination, through pilot testing and conceptual studies. These efforts have helped characterize the technical feasibility, cost, and operational considerations associated with alternative supply sources and provide important context for comparison with potable reuse alternatives. The results of these evaluations support the conclusion that potable reuse represents a more scalable and cost-effective long-term strategy for improving water supply reliability relative to other alternative supply options.
(c) Project Objectives
Statement of the specific objectives all alternatives, including the water reclamation, recycling, or desalination project, are designed to address.
The four alternatives evaluated for this feasibility study are:
1. IPR via Surface Water Augmentation (SWA) to Summers Lane Reservoirs
2. DPR via Raw Water Augmentation (RWA) to Raw Water Storage Ponds
3. DPR via RWA to Summers Lane Reservoirs
4. DPR via Treated Water Augmentation (TWA) to Finished Water Storage The primary objective of these alternatives is to improve long-term water supply reliability and drought resilience for the City through beneficial reuse of treated municipal wastewater as a potable water source. The alternatives would supplement existing surface water supplies, reduce vulnerability to hydrologic variability, and provide a more reliable supply that is less dependent on climate conditions.
Additional objectives include maximizing use of existing infrastructure where feasible, maintaining compatibility with ongoing water treatment plant modernization efforts, and ensuring the project can be operated in coordination with the City’s existing water supply system.
The evaluation of each alternative also considered regulatory feasibility, operational complexity, and long-term cost sustainability to confirm that any future project is technically sound and appropriate for a small water system with a limited rate base. (d) Project Description
Description of the proposed project including detailed project cost estimate; annual operation, maintenance, and replacement cost estimate; and life cycle costs shall be provided with sufficient detail to permit a more in-depth evaluation of the project, including non-construction costs. In this regard, the cost estimates should clearly identify expenditures for major structures and facilities, as well as other types of construction and non-construction expenses based on calculated quantities and unit prices.
The City of Fort Bragg is the project proponent and will remain the long-term owner, operator, and legally responsible enƟty for the Proposed Project. The City, through Fort Bragg Municipal Improvement District No. 1, will be accountable for regulatory compliance, public health protecƟon, system operaƟon, reporƟng, and ongoing performance of the advanced treatment and potable reuse faciliƟes. This responsibility extends across the full project lifecycle, including design, permiƫng, construcƟon, commissioning, and long-term operaƟon.
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Consultants engaged by the City support this role by providing planning, engineering, environmental review, and implementaƟon services under City direcƟon. Their role is advisory and project-based; they do not assume operaƟonal or regulatory responsibility for the facility.
Similarly, regulatory agencies, including the SWRCB’s Division of Drinking Water and the RWQCB, establish performance standards, permiƫng requirements, and oversight frameworks, but do not parƟcipate in project operaƟon.
Clear delineaƟon of these roles is essenƟal for potable reuse projects, where public health protecƟon depends on conƟnuous local control and accountability. The Proposed Project is therefore structured to ensure that the City retains full operaƟonal authority and insƟtuƟonal ownership, with consultants providing technical support and regulators providing independent oversight, consistent with State and Federal expectaƟons for potable reuse implementaƟon.
The Proposed Project, IPR via surface water augmentaƟon, consists of development of an AWPF at the exisƟng WWTP to produce purified water for potable reuse. The WWTP currently treats approximately 0.8 MGD of municipal wastewater and produces secondary effluent of sufficient quality and reliability to serve as influent to advanced treatment processes. The Proposed Project would beneficially reuse this exisƟng wastewater resource to improve long-term water supply reliability and drought resilience while reducing reliance on variable surface water sources.
The choice of potable reuse alternaƟves is influenced by how the AWPF would be operated in coordinaƟon with the City’s exisƟng local water supplies. The City is expected to conƟnue relying on its surface water sources for much of the year, with potable reuse intended to provide a reliable, drought-resilient supplemental supply. Accordingly, the operaƟonal strategy for the AWPF, whether operated seasonally to supplement local supplies during periods of high demand or low supply, or operated conƟnuously throughout the year, plays an important role in determining the feasibility and suitability of individual potable reuse alternaƟves.
The Proposed Project is the preferred alternaƟve based on its technical feasibility, regulatory framework, and compaƟbility with the City’s exisƟng water supply and treatment infrastructure.
The IPR alternaƟve relies on full advanced treatment followed by an environmental buffer prior to convenƟonal drinking water treatment, providing operaƟonal flexibility and alignment with established regulatory requirements for potable reuse integraƟon. Table 4-1 indicates that the proposed IPR alternaƟve represents a feasible and implementable approach that balances system complexity, regulatory requirements, and long-term operability.
Table 4-1 ImplementaƟon CharacterisƟcs of the IPR AlternaƟve Proposed
Project
Technical
Difficulty
Permitting
Timeline
Relative
Cost
O&M
Intensity Benefits
IPR via Surface
Water
Augmentation
Moderate Moderate Moderate Moderate Includes an environmental buffer and fewer AWPF
treatment processes, resulting
in a smaller facility footprint.
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The Proposed Project includes reverse osmosis (RO) as a core advanced treatment process. RO performance is a key factor influencing system recovery, concentrate management, and overall operaƟonal reliability. Preliminary RO modeling based on effluent sampling indicates that high recovery rates are achievable; however, addiƟonal water quality data collecƟon and targeted pilot tesƟng will be required to confirm performance under seasonal variaƟons and to support regulatory approvals for IPR.
Post-treatment stabilizaƟon of RO permeate is also required due to the low alkalinity and corrosive nature of the product water. StabilizaƟon is necessary to ensure compaƟbility with downstream treatment faciliƟes and the exisƟng water distribuƟon system and is a required element of potable reuse regulatory approval. In addiƟon, the Proposed Project would generate reverse osmosis concentrate (ROC), which would be managed through discharge via the City’s exisƟng ocean ouƞall, subject to compliance with California Ocean Plan requirements, applicable NPDES permit provisions, and CEQA review.
Common design assumptions for the Proposed Project include use of secondary-treated effluent from the WWTP as source water, an average AWPF production capacity of approximately 0.72 MGD, and evaluation of capital, operation, maintenance, and replacement costs over a 30 year planning horizon.
IPR Project ConfiguraƟon and Environmental Buffer. In the Proposed Project, secondary effluent from the WWTP undergoes full advanced treatment at an AWPF, aŌer which purified water is conveyed to the Summers Lane Reservoirs and blended with surface water supplies prior to treatment at the SWTP and delivery to the potable distribuƟon system. Reservoir storage serves as an environmental buffer providing at least 60 days of retenƟon Ɵme, diluƟon, and mixing before the purified water enters the SWTP. This surface water augmentaƟon approach qualifies as indirect potable reuse and allows the City to integrate purified water into its exisƟng water supply system while maintaining compaƟbility with current treatment and operaƟonal pracƟces, reducing regulatory complexity and providing operaƟonal flexibility. By selecting an IPR configuration that integrates with existing treatment facilities and operations, the Proposed Project minimizes operational complexity while improving overall system reliability.
Design Criteria. The assumed design flows for the Proposed Project are shown in Figure 4-2.
AWPF influent includes 0.84 MGD of secondary effluent from the WWTP plus return flows from the AWPF. The membrane filtraƟon (MF) process has an assumed recovery of 95% based on an assumpƟon of 5% downƟme to perform rouƟne maintenance and cleaning. Based on previous modeling, a 90% RO recovery rate was assumed, resulƟng in 0.72 MGD of product water.
Flow Stream Process
Recovery
Flow Value
(MGD)
AWPF Influent -- 0.84
MF Feed 95% 0.84
RO Feed 90% 0.80
RO Permeate -- 0.72
RO Concentrate -- 0.08
UV/AOP Feed -- 0.72
Chlorination Feed -- 0.72
Stabilization Feed -- 0.72
Table 4-2 Design Flows for Proposed Project
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OrganizaƟonal Readiness and Operator Burden
Implementation of the Proposed Project represents not only a capital investment, but a fundamental expansion of the City’s operational responsibilities. Operation of an AWPF will require a higher level of technical oversight, regulatory documentation, and real-time process control than is currently required for the City’s conventional water and wastewater systems. Over the long term, the City will need to plan for additional certified operators with experience in advanced treatment processes, expanded SCADA and alarm management capabilities, and formalized redundancy and cross-training protocols to ensure continuous compliance and system reliability.
These needs are especially important for a small utility with limited staffing depth. The AWPF will operate as critical public health infrastructure, and its reliability cannot depend on a single individual or informal knowledge transfer. Staffing plans will therefore need to provide for overlapping certifications, routine training, and clear operational roles across both water and wastewater functions. Expanded SCADA systems will be required to support continuous monitoring, automated alarms, and remote response capability, reducing operator burden while maintaining regulatory confidence.
These organizational requirements are reflected in the project’s O&M assumptions and underscore why the Proposed Project is configured as a buffered IPR system rather than a continuously coupled DPR system. The IPR approach allows the City to integrate advanced treatment in a way that is achievable for a small, resource-limited organization, while still providing a firm and resilient supply during drought and emergency conditions.
Treatment FaciliƟes and Processes
The Proposed Project uƟlizes a full advanced treatment train at a new AWPF, including secondary effluent flow equalizaƟon, MF, RO, ultraviolet/advanced oxidaƟon (UV/AOP), post-treatment stabilizaƟon, and an engineered storage buffer. These processes collecƟvely provide mulƟple physical, chemical, and biological mechanisms for pathogen and contaminant removal consistent with potable reuse requirements. The complete treatment train is illustrated in Figure 4-1. The new AWPF will be constructed adjacent to the WWTP and integrated with existing utilities and site infrastructure. A conceptual layout of the AWPF is shown in Figure 4-2.
Figure 4-1 Treatment Train for Proposed Project
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Conveyance and Storage
Purified water produced by the AWPF would be conveyed from the WWTP to the Summers Lane Reservoirs via a dedicated pipeline. This pipeline is known as Alignment D and is shown in Figure 4-3. Once discharged to the reservoir, purified water would be retained for a regulatory-approved residence Ɵme prior to conveyance to and treatment at the SWTP. This configuraƟon allows purified water to be blended with exisƟng surface water supplies and provides operaƟonal buffering during variable demand and hydrologic condiƟons.
The cost esƟmate for Pipeline Alignment D is $4,400,000. This esƟmate includes equipment, materials, excavaƟon costs, access roads, traffic control, utility exploratory excavation and demolition. Also included is the trenchless pipe installation expense for the Noyo River crossing.
Costs associated with obtaining easements, electrical, and vault structures are not included.
Figure 4-2 AWPF Layout for Proposed Project
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OperaƟonal Sequencing Under Normal, Drought, and Emergency CondiƟons Under normal hydrologic conditions, the City would continue to rely primarily on its existing surface water sources to meet system demands. During these periods, the AWPF would operate in a reduced or standby mode, producing only limited volumes of purified water needed for system testing, regulatory compliance, and operator training. This approach maintains operational readiness without displacing lower-cost surface water supplies and helps minimize energy use and O&M costs when natural sources are sufficient. The facility remains integrated into day-to-day operations, but its role is supportive rather than central, ensuring that staff, equipment, and monitoring systems are always prepared for more intensive use when conditions change.
As surface water availability declines, most commonly in late summer and fall, or during extended dry periods, the AWPF would transition into a supplemental operating mode. Triggers for this shift include sustained reductions in tributary flows, increasing dependence on the Noyo River diversion, declining reservoir storage, or entry into a declared water shortage stage. In this mode, advanced treatment would operate seasonally or episodically to augment raw water storage at the Summers Lane Reservoirs, offsetting shortfalls in natural inflow and stabilizing overall system supply. During drought emergencies, such as those experienced in 2015 and 2021, the facility would be operated at or near its design capacity on a continuous basis, with purified water becoming a primary source of supply. This tiered operating strategy of baseline readiness, seasonal or episodic augmentation, and full-capacity emergency operation allows the Proposed Project to function as a resilience asset rather than a constant replacement for existing sources.
The AWPF is therefore sized and configured not only to meet average supplemental needs, but Figure 4-3 Conveyance Pipeline Alignment D for the Proposed Project City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 4 Page | 33
to provide a firm, drought-proof supply during extreme hydrologic conditions, converting variable wastewater flows into a reliable and controllable water resource.
Capital Cost EsƟmate
Planning-level capital costs were developed using calculated quanƟƟes, conceptual layouts, and unit pricing from comparable potable reuse projects. Major capital components include the AWPF, process faciliƟes and equipment, conveyance pipelines, electrical and instrumentaƟon systems, site improvements, and integraƟon with exisƟng infrastructure. Non-construcƟon costs consist of engineering and design, environmental documentaƟon, permiƫng and regulatory coordinaƟon, construcƟon management and inspecƟon, startup and commissioning, contractor overhead and profit, and conƟngency allowances appropriate for the planning level of design. A capital cost esƟmate for the Proposed Project is presented in Table 4-3.
Item Cost Estimate1
Item Cost Estimate1
Flow EQ Basin $1,500,000
MF $2,000,000
RO2 $1,430,000
AOP $430,000
Post-Stabilization $695,000
Engineered Storage Buffer $1,900,000
Chemical Feed System Improvements $998,000
Conveyance Piping $4,400,000
AWPF Building, Yard Piping, Valves & Appurtenances, E&I $12,000,000 AWPF Pump Station (wet well, conveyance pumping) (7x23 basin) $450,000 Project Costs Subtotal $25,803,000
Site Allowances3 (10%) $2,581,000
Construction Subtotal $28,384,000
Overhead (10%) $2,581,000
Contractor Profit (10%) $2,581,000
Mobilization/Bond/Insurance (4%) $1,033,000
Contingency (30%) $7,741,000
Total Construction Cost $42,320,000
Permitting (2%) $847,000
Engineering (10%) $4,232,000
CM&I (10%) $4,232,000
Commissioning & Startup (10%) $4,232,000
Total Capital Cost $55,863,000 1AACE Class 5 Estimate with accuracy range -30% to +50% 2Includes RO Feed/MF Backwash Tank and RO Flush Tank
3Site allowances include site work, demolition, soil conditions, larger electrical upgrades, and specialty disposal Table 4-3 Capital Cost EsƟmate for Proposed Project
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Annual operaƟon, maintenance, and replacement (OM&R) costs include energy consumpƟon, treatment chemicals, rouƟne maintenance, and periodic replacement of major equipment such as membranes and ultraviolet systems. The costs in Table 4-4 were esƟmated based on process design criteria, equipment power demands, and representaƟve unit costs.
Item Cost Estimate1
Equipment Replacement $199,100
Equipment Electrical $966,400
Building HVAC Electrical $89,100
Chemicals $640,400
Total Costs $1,895,000
1OM&R costs for equipment and consumable replacements do not include labor costs.
Component Replacement Schedule
Life cycle costs for the Proposed Project were evaluated over a 30-year planning horizon and include iniƟal capital investment, annual OM&R costs, and periodic major equipment replacement. These costs form the basis for the normalized unit cost metrics presented in SecƟon (e). Table 4-5 lists the replacements that roll up to the “Equipment Replacement” line item reported in Table 4-4.
Component (Replacement Item) Replacement
Cycle (yrs)
MF membrane modules 8–10
RO membrane elements 6–8
RO cartridge filters 0.25–0.5
UV/AOP lamps 1
UV quartz sleeves 3–5
UV ballasts / power supplies 7–10
AOP chemical injection equipment (pumps, seals) 5–7
CIP system (cleaning tank linings, pumps) 10–15
Post-stabilization media (calcite/contact media) 2–5
Chemical storage and feed (tank coatings, mixers) 10–15 Process instrumentation (online analyzers, probes) 3–7
Conveyance pumping equipment (pump/motor
rehab) 8–12
Valves and actuators (critical service) 10–20
Total Lifetime Replacement Costs $5,973,000
Table 4-5 Component Replacement Schedule for Proposed Project Table 4-4 Annual OM&R Cost EsƟmates for Proposed Project City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 4 Page | 35
(e) Project Costs
The estimated costs shall also be presented in terms of dollars per million gallons, and/or dollars per AF of capacity, to facilitate comparison of alternatives described in Paragraph 4.B.(5). References, design data, and assumptions must be identified. The level of detail shall be as required for feasibility studies in RM D&S, Cost Estimating (FAC 09-01).
Four potable reuse project alternaƟves were studied to improve long-term water supply reliability and drought resilience for the City through beneficial reuse of treated municipal wastewater. The alternaƟves include one IPR configuraƟon and three DPR configuraƟons that differ by point of integraƟon within the City’s water supply system. Each alternaƟve assumes advanced treatment of secondary-treated effluent at a proposed AWPF and delivery of purified water for potable use.
These alternaƟves are:
1. IPR via Surface Water AugmentaƟon to Reservoirs (Proposed Project)
2. DPR via Raw Water AugmentaƟon to Reservoirs
3. DPR via Raw Water AugmentaƟon to Raw Water Storage Ponds
4. DPR via Finished Water AugmentaƟon
All alternaƟves were evaluated at a feasibility level, consistent with ReclamaƟon’s RM D&S, Cost EsƟmaƟng (FAC 09-01) guidance. Capital and O&M costs are planning-level esƟmates (AACE Class 5) based on conceptual layouts, vendor budgetary pricing, and standard unit costs. Costs are expressed in 2025 dollars and normalized to dollars per acre foot of annual potable reuse capacity to facilitate comparison among alternaƟves. Project descripƟons, treatment configuraƟons, design assumpƟons, and cost esƟmates summarized in this secƟon are based on the supporƟng technical memoranda prepared for the City.
The following assumpƟons apply to all four alternaƟves:
• Secondary treated effluent from the exisƟng WWTP is used as source water. • Average AWPF influent flow of approximately 0.8 MGD.
• RO recovery of approximately 90 percent.
• Net potable reuse producƟon of approximately 0.72 MGD, equivalent to 807 AFY. reflecƟng treatment losses associated with membrane filtraƟon and reverse osmosis. • RO concentrate disposal via the exisƟng ocean ouƞall, subject to applicable NPDES permit provisions, California Ocean Plan requirements, and CEQA review. • A 30 year planning horizon for evaluaƟon of capital, operaƟon, maintenance, and replacement costs.
Using a consistent post-treatment producƟon value allows for direct comparison of cost, complexity, and permiƫng consideraƟons among the alternaƟves.
The IPR alternaƟve has the lowest capital intensity and permiƫng complexity while providing a comparable potable reuse yield. DPR alternaƟves require addiƟonal treatment processes, monitoring, and regulatory approvals, resulƟng in higher capital costs and greater implementaƟon complexity.
Table 4-6 summarizes the relaƟve cost, technical complexity, and permiƫng consideraƟons for each alternaƟve, normalized to a potable reuse producƟon of approximately 807 AFY. The IPR alternaƟve has the lowest capital intensity and permiƫng complexity while providing a comparable potable reuse yield. DPR alternaƟves require addiƟonal treatment processes, monitoring, and regulatory approvals, resulƟng in higher capital costs and greater implementaƟon complexity.
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Table 4-6 Comparison of Potable Reuse AlternaƟves
Alternative Technical
Complexity
Permitting
Complexity Capital Cost Capital Cost/AF
IPR via SWA to Reservoirs Moderate Moderate $55,863,000 $2,307 DPR via RWA to Reservoirs Moderate–High High $71,418,000 $2,950 DPR via RWA to Storage Ponds Moderate–High High $71,318,000 $2,946 DPR via Finished Water Augmentation High High $74,806,000 $3,090 (f) Discharge and Disposal Description
Description of waste-stream discharge treatment and disposal water quality requirements, if applicable, for the proposed water reclamation, recycling, or desalination project.
The WWTP has a design average daily flow of 0.8 MGD and a maximum wet-weather capacity of
4.9 MGD. All flow is currently discharged to the Pacific Ocean and not earmarked for other uses, so all flow is assumed to be available for either potable reuse. The Proposed Project treats secondary effluent through full advanced treatment and integrates the purified water into the City’s surface water supply via surface water augmentation. By diverting treated wastewater for potable reuse, the project reduces the volume of effluent discharged through the existing ocean outfall and does not introduce new pollutants, resulting in no increase in pollutant loading to receiving waters.
Discharges from the WWTP are regulated by the North Coast Regional Water Quality Control Board (RWQCB) under the authority of the Federal Clean Water Act and California’s PorterCologne Water Quality Control Act. The primary basis for establishing effluent limitations is the State Ocean Plan, which sets water quality objectives to protect the beneficial uses of ocean waters, including recreation, marine life, and shellfish harvesting. The RWQCB incorporates the Ocean Plan, along with guidance from the U.S. Environmental Protection Agency (EPA), into Fort Bragg’s National Pollutant Discharge Elimination System (NPDES) permit. This permit is reissued every five years, during which new regulatory requirements may be adopted. Due to the Federal anti-backsliding provisions, once effluent limits are established in a permit, they generally cannot be relaxed in subsequent renewals unless specific regulatory exceptions are met.
During the 2004 NPDES permit reissuance, the City obtained approval to revise its total coliform bacteria effluent limit, shifting from a recycled water-based standard to the more appropriate and stringent Ocean Plan limit for shellfish protection. However, the RWQCB declined to revise several other effluent limits, despite allowable flexibilities under Federal regulations and the Ocean Plan for facilities using trickling filter treatment processes. Fort Bragg’s wastewater discharge limits are more stringent than the statewide minimums, reflecting the protective requirements established in the City’s NPDES permit and the California Ocean Plan for coastal discharges. Therefore, the City has to clean its wastewater more and follow tighter rules before releasing it to the ocean. Notably, the Ocean Plan also requires agencies to evaluate and implement the least toxic, most protective disinfection alternatives to safeguard ocean water quality and sensitive marine ecosystems.
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The California Ocean Plan states that “disinfection procedures that do not increase effluent toxicity and that constitute the least environmental and human hazard should be used.” In alignment with this policy, this wastewater treatment facility study includes an evaluation of ultraviolet (UV) disinfection as a safer and more environmentally protective alternative to conventional chlorination and dechlorination, which can introduce toxic byproducts and pose operational risks.
In recent years, enforcement of NPDES permit violations has become increasingly stringent, particularly with the implementation of Mandatory Minimum Penalties (MMPs) of $3,000 per qualifying violation under California Water Code §13385. These automatic penalties apply to effluent limit violations, late reporting, and other non-compliance events. The heightened regulatory enforcement environment underscores the importance of incorporating reliability, redundancy, and robust process controls in the design of treatment and pumping systems to minimize the risk of permit violations and associated penalties.
Blending, defined as the diversion of flows around secondary treatment processes during peak wet weather events, is a longstanding but increasingly scrutinized regulatory issue. In California, the State and Regional Water Boards are placing heightened emphasis on blending practices during NPDES permit reissuance, with a focus on ensuring compliance with effluent limitations and protection of receiving water quality. As such, blending-related provisions are expected to receive detailed review and conditions in future permit updates. Blending at the Fort Bragg WWTF now occurs only when influent flows exceed the plant’s upgraded peak wet weather capacity of 4.9 MGD. Under these extreme conditions, specifically those associated with intense or prolonged storm events, portions of the flow may bypass secondary treatment processes to prevent hydraulic overloading of the facility. While the upgraded plant significantly reduces the frequency and volume of blending events, further infrastructure improvements may be considered to fully eliminate blending and ensure continued compliance with NPDES permit requirements.
In the upcoming NPDES permit cycle, it is anticipated that the RWQCB will place increased emphasis on source control measures and the development of Pollutant Minimization Plans (PMPs). Source control focuses on reducing or eliminating pollutants at their point of origin before they enter the wastewater collection system and is increasingly important for managing emerging contaminants such as pharmaceuticals, antibiotics, endocrine-disrupting compounds, and personal care products. These constituents are often persistent, biologically active at low concentrations, and not fully removed through conventional treatment processes. Once discharged, they can accumulate in marine sediments and biota and have the potential to affect coastal ecosystems and food webs over time. These concerns are based on the behavior of these contaminants in the marine environment, rather than a generalized notion of ocean sensitivity, and have led regulatory agencies to place greater emphasis on preventing pollutants from entering the wastewater stream rather than relying solely on end-of-pipe treatment.
Additionally, the treatment facility must either seek coverage under the Statewide General Industrial Stormwater Permit or implement infrastructure to capture and return stormwater runoff to the treatment process. Stormwater from paved surfaces, chemical storage areas, or sludge handling zones may contain pollutants that could adversely impact receiving waters if discharged untreated.
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(g) Alternative Technologies Description
Description of one of more alternative technologies that could be used in the proposed water reclamation, recycling, or desalination project under consideration. Where a project only consists of reclaimed, recycled, or desalinated water distribution, alternative plans for distribution or implementation will be provided. These alternatives must be approvable by the state(s) or tribal authorities in which the project will be located.
Alternative treatment and implementation technologies were evaluated to identify options that are technically feasible, regulatory approvable, and compatible with the City’s existing infrastructure. The evaluation focused on proven advanced treatment technologies currently recognized by the State of California for potable reuse, including membrane filtration, reverse osmosis, ultraviolet advanced oxidation, ozone, and biologically activated carbon.
Technologies requiring extensive basic research or development of new regulatory pathways were screened out and not advanced for further consideration. Certain treatment processes, such as ozone and biologically activated carbon, were also excluded from some configurations where they were not required to meet applicable regulatory requirements or where equivalent public health protection could be achieved through other treatment barriers. This screening reduced capital cost, facility footprint, and operational complexity while maintaining regulatory compliance.
Alternative approaches for integrating treated water into the potable system, including surface water augmentation, raw water augmentation, and finished water augmentation, were evaluated for feasibility and permitting complexity. Configurations requiring the highest levels of treatment redundancy and monitoring were identified as having greater implementation risk for a small system and were not selected as the preferred approach. All technologies advanced for further evaluation are expected to be approvable by applicable State regulatory agencies, subject to final design and permitting. Table 4-7 summarizes key distinctions between IPR and DPR.
Table 4-7 Summary of Key DisƟncƟons Between IPR and DPR AlternaƟves Evaluation Factor IPR via Surface Water Augmentation
(Proposed Project) DPR Alternatives (RWA and TWA)
Regulatory
Pathway
Established framework with defined
environmental buffer requirements;
lower uncertainty
Emerging framework with evolving
requirements; higher approval risk
and longer permitting timelines
Regulatory Risk Moderate and well understood High, particularly for treated water augmentation
Capital Cost Lowest of potable reuse alternatives 30–40% higher than IPR O&M Intensity Moderate; aligns with existing
operations
Higher due to continuous advanced
treatment and monitoring
Operational
Complexity
Integrates with existing storage and
treatment processes
Requires continuous, tightly
controlled operation and real-time
integration with potable system
System Resilience Provides buffered, flexible supply Provides unbuffered or minimally buffered supply
Suitability for Small
System
Well matched to staffing and rate
base
Challenging for a small, resourcelimited utility
City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 4 Page | 39
While all potable reuse alternatives evaluated are technically feasible, the IPR alternative offers a substantially more balanced risk profile for a small, resource-constrained system. DPR alternatives introduce higher regulatory uncertainty, greater operational intensity, and increased cost without providing commensurate resilience benefits. The IPR configuration achieves the City’s drought-resilience objectives while maintaining compatibility with existing infrastructure, staffing capacity, and regulatory frameworks. For these reasons, DPR alternatives were not advanced as the Proposed Project despite their ability to produce potable water. (h) Regulatory Requirements for Potable Reuse
The discharge and beneficial reuse of recycled water in California for both potable and nonpotable applications is regulated under Title 22 of the CCR and enforced by the SWRCB. These regulations are inextricably tied to the selection and sizing of the treatment train.
Surface Water Augmentation. Under the Proposed Project, surface water augmentation requires full advanced treatment prior to discharge to the reservoir. State regulations require a minimum reservoir retention time prior to withdrawal for treatment at the surface water treatment plant, with pathogen removal requirements based on reservoir dilution and hydraulic retention time.
Reservoirs must meet minimum dilution thresholds and retention time criteria, which determine the required log removal values for viruses, Giardia, and Cryptosporidium and the number of treatment barriers needed. Pathogen removal credit may be distributed across the advanced treatment processes, the surface water reservoir, and the surface water treatment plant, consistent with Division of Drinking Water requirements. Figure 4-4 illustrates the allocation of pathogen removal credit across the treatment train.
Chemical Control. An SWA project must comply with all chemical water quality standards applicable to GWR projects, including adherence to all MCLs, notification levels, and implementation of a comprehensive source control program. In addition, SWA projects are generally subject to the California Toxics Rule (CTR), which regulates discharges to the State's surface waters such as inland waters, bays, and estuaries. However, because the Summers Lane Reservoir is an engineered, non-navigable water body, it is unlikely to be classified as a CTRregulated surface water. As a result, CTR requirements may not apply to the discharge of purified water into this specific reservoir.
Figure 4-4 Pathogen Removal Credits for Proposed Project City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 5 Page | 40
5. ECONOMIC ANALYSIS
A water reclamation, recycling or desalination feasibility study report must include an economic analysis of the proposed water reclamation, recycling or desalination project relative to other water supply alternatives that could be implemented by the nonFederal project sponsor in lieu of a water reclamation, recycling or desalination project. This assessment needs to identify the degree to which the water reclamation, recycling or desalination project alternative is cost-effective, and the economic benefits that are to be realized after implementation. The study lead must submit the following information for the economic analysis in a water reclamation, recycling or desalination feasibility study report.
This chapter evaluates the economic performance of the Proposed Project and alternatives, including capital costs, operation and maintenance costs, life-cycle costs, and cost effectiveness.
It also discusses qualitative benefits that are not fully captured in monetary terms, such as drought resilience, environmental protection, and public health reliability. The chapter provides the analytical basis for understanding the financial implications of each alternative and how costs align with the benefits delivered.
(a) Current and Projected Conditions of Alternatives
The report shall describe the conditions that exist in the area and provide projections of the future with, and without, the project.
Emphasis in the analysis must be given to the contributions that the plan could make toward alleviation of economic problems and the meeting of future water demand.
The following points summarize existing water supply conditions in Fort Bragg, the anticipated challenges under the No Project condition, and the benefits of the Proposed Project. Together, they provide context for why development of a locally controlled potable reuse supply is critical to improving long-term water supply reliability, drought resilience, and affordability for the community.
• High reliance on variable local surface water supplies. Fort Bragg depends entirely on local surface water sources, including the Noyo River and spring-fed tributaries, which are highly sensitive to seasonal precipitation, drought, and climate variability. The City has no access to imported water and limited groundwater options, leaving the system vulnerable during extended dry periods.
• Increasing risk under the No Project condition. Without the Proposed Project, water supply would remain constrained, with firm supply estimated at approximately 1,500 to 1,600 AFY in normal years and substantially less during dry years. As modest growth and redevelopment proceed, particularly at the former mill site, the City would face more frequent shortages, emergency conservation measures, and operational uncertainty. • Creation of a new, drought-resilient local supply. The Proposed Project would develop approximately 807 AFY of new potable water supply by beneficially reusing treated municipal wastewater that is currently discharged to the ocean. This would increase total firm supply to approximately 2,300 to 2,400 AFY and reduce reliance on variable surface water sources during low-flow periods.
• Improved reliability and community resilience. Improved reliability and community resilience. By enhancing drought resilience rather than supporting growth, the Proposed Project would reduce the frequency and severity of water shortages, improve reliability for essential services such as public health and fire protection, and support the City’s tourismbased economy. Improved water supply reliability would also reduce the risk of supplyrelated disruptions to residential and commercial activity, helping stabilize the local economy City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 5 Page | 41
while meeting future water demands under increasingly variable hydrologic conditions. • Stabilizing long-term costs and affordability. Stabilizing long-term costs and affordability.
Fort Bragg faces rising water costs due to regulatory requirements, aging infrastructure, and climate impacts. The Proposed Project would reduce dependence on costly emergency measures and, by leveraging external funding such as Title XVI assistance, help moderate future rate increases for a Severely Disadvantaged Community with a small rate base. (b) Cost Comparison of Alternatives
A cost comparison of alternatives that would satisfy the same demand as the proposed water reclamation, recycling, or desalination project. Alternatives used for comparison must be likely and realistic, and developed with the same standard Other Water Supply Alternatives.
A comparative evaluation was conducted to assess other potable reuse supply alternatives capable of providing a level of firm supply comparable to the approximately 807 AFY produced by the Proposed Projects. Alternatives selected for comparison represent realistic and technically feasible options for the City, considering local hydrologic conditions, regulatory constraints, infrastructure limitations, and community affordability. All alternatives were developed using a consistent planning horizon, demand basis, and feasibility-level cost methodology consistent with Reclamation guidance and the approach used for the Proposed Project. A comparison of the project costs is shown in Table 5-1.
Table 5-1 Cost Summary of Potable Reuse AlternaƟves
Alternative Capital Cost Capital
Cost/AF O&M Cost AFY Produced
1 IPR via SWA to Reservoirs $55,863,000 $2,307 $1,895,000 807 2 DPR via TWA to Finished Water Storage $71,418,000 $2,950 $2,078,200 807 3 DPR via RWA to Storage Ponds $71,318,000 $2,946 $1,980,200 807 4 DPR via RWA to Reservoirs $74,806,000 $3,090 $1,980,200 807 The Proposed Projects provide a locally controlled, drought-resilient supply of approximately 807 AFY through beneficial reuse of treated municipal wastewater currently discharged to the ocean.
These projects exhibit planning level capital costs of $2,220 to $2,946 per AF, reflecting lower life cycle costs, reduced exposure to hydrologic variability, and reduced reliance on emergency response actions. When evaluated alongside other realistic water supply alternatives using the same planning assumptions and level of analysis, the Proposed Project represents the most costeffective and reliable means of meeting future water supply needs for the City. (c) Description of Other Water Supply Alternatives
Description of other water supply alternatives considered to accomplish the objectives to be addressed by the water reclamation, recycling, or desalination project, including benefits to be gained by each alternative, total project cost, life cycle cost, and corresponding cost of the project water produced expressed in dollars per MG, and/or dollars per AF. An appraisal level cost estimate, or better, is acceptable for these alternatives.
Water supply strategies such as emergency drought response measures (including expanded surface water storage or increased diversion capacity) and seawater desalination were evaluated at a screening level due to significant technical, regulatory, and economic uncertainties and were not advanced for full feasibility-level design. Nevertheless, to support a meaningful comparison, City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 5 Page | 42
each strategy was reviewed at an appraisal level or better to identify the principal benefits that could be achieved, estimate total costs, and characterize the corresponding unit cost of water produced in $/AF.
The resulting planning-level cost ranges presented in Table 5-2, are provided to illustrate relative cost, operational considerations, and feasibility among alternatives. These estimates are not project-specific and are not intended to support detailed ranking or selection; rather, they provide context for evaluating the comparative benefits, cost drivers, and limitations of each strategy relative to the Proposed Projects.
Table 5-2 Planning Level EsƟmates of No Project Strategies Strategy Supply Type Yield (AFY) Cost*/AF
Emergency
Conservation Non-firm <500 $2,000–$4,000+
Expanded Surface
Water Storage Non-firm 300–1,000 $3,000–$6,500
Increased Diversion
Capacity Non-firm 200–1,200 $2,500–$6,000
Seawater
Desalination Firm 1,000–5,000 $4,500–$8,000+
* Includes levelized capital and O&M costs.
Supply reliability differs across these strategies: emergency measures provide episodic, droughtperiod benefits; expanded storage or diversion remains dependent on hydrologic conditions; and desalination represents a firm, climate-resilient supply. Key constraints and uncertainties also differ. Emergency measures do not create a new water supply, tend to exhibit diminishing effectiveness over time, and can impose social and economic impacts on the community.
Expanded storage or diversion is constrained by environmental permitting requirements, instream flow protections, and increasing hydrologic variability. Desalination is associated with high energy intensity and significant regulatory challenges related to marine permitting, intake structures, and brine disposal.
Seawater desalination and stormwater diversion structures were found to have significantly higher capital costs compared to potable reuse alternatives. Seawater desalination requires construction of specialized intake and discharge facilities, high-pressure treatment systems, and supporting energy infrastructure, which substantially increase upfront costs. Similarly, stormwater diversion and capture projects typically require large conveyance structures, storage facilities, and flow control improvements to manage short-duration, high-volume events, resulting in high capital investment with variable water yield. In contrast, potable reuse leverages existing wastewater infrastructure and provides a more cost-effective means of developing reliable water supply at a lower capital cost.
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(d) Comparison of Project Service Levels Between Chosen Project and Top Alternative When a water reclamation project provides supplies for municipal and industrial use, the benefits of the project can be measured in terms of the cost of the alternative most likely to be implemented in the absence of the project. This is assuming that the two (2) alternatives would provide comparable levels of services. This comparison must be provided, if applicable.
This comparison is not applicable. The potable reuse alternatives presented in this Study are based on production at the City’s WWTP which treats an average daily flow of 0.8 MGD or 896 AF. Each alternative would produce 0.72 MG or 807 AF of reuse water. (e) Qualitative Benefits
Some water reclamation, recycling or desalination project benefits will be difficult to quantify, for example, a drought tolerant water supply, reduced water importation, and other social or environmental benefits. These benefits shall be documented and described qualitatively as completely as possible. These qualitative benefits can be considered as part of the justification for a water reclamation, recycling, or desalination project in conjunction with the comparison of project costs described.
The Proposed Project provides a range of qualitaƟve benefits that directly support the City’s water supply, reliability, and public health objecƟves. Key benefits include the following:
• Improves water supply reliability by providing a locally controlled potable water source that reduces reliance on hydrologically variable surface water supplies. • Enhances drought resilience through development of a climate-resilient supply that can be operated during dry and criƟcally dry condiƟons.
• Protects public health by incorporaƟng advanced treatment processes and mulƟple, redundant barriers prior to potable use.
• Diversifies the water supply porƞolio, reducing vulnerability to single-source failures and improving overall system redundancy.
• Supports long-term sustainability by establishing a potable reuse framework that can be phased, expanded, or adapted over Ɵme as regulatory requirements and community needs evolve.
• Improves community water security by reducing the likelihood and severity of droughtrelated water use restricƟons, helping maintain quality of life and economic stability. • Enhances public confidence in the long-term reliability of essenƟal water services through development of a locally controlled supply.
• Reduces pressure on sensiƟve watersheds and ecosystems by decreasing reliance on hydrologically constrained surface water sources, parƟcularly during dry and criƟcally dry years.
• Promotes sustainable water management by beneficially reusing treated wastewater that would otherwise be discharged.
• Supports long-term environmental stewardship and climate resilience through efficient use of local water resources and reduced vulnerability to future climate variability.
In addiƟon, reducing the discharge of treated wastewater to the Pacific Ocean by implemenƟng potable reuse provides measurable water quality, environmental, regulatory, and resourceefficiency benefits. • Reduces nutrient, organic, and trace consƟtuent loading to nearshore waters, supporƟng healthier marine water quality condiƟons.
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• Decreases potenƟal cumulaƟve impacts to sensiƟve coastal habitats, including kelp forests and nearshore benthic communiƟes.
• Reduces long-term reliance on ocean ouƞalls and associated NPDES permiƫng, monitoring, and reporƟng requirements.
• Retains water within the local hydrologic system rather than permanently exporƟng it to the ocean, improving resilience during drought and sea-level rise condiƟons. • Converts treated wastewater from a disposal stream into a producƟve supply, improving overall water use efficiency.
• PotenƟally lowers long-term maintenance, rehabilitaƟon, and vulnerability of coastal ouƞall infrastructure to corrosion, storms, and seismic events. • Aligns with California policies promoƟng water recycling, potable reuse, and reduced reliance on ocean discharge.
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6. SELECTION OF THE PROPOSED WATER PROJECT
This chapter brings together the technical, regulatory, operational, and economic findings of the study to compare alternatives and identify a preferred approach. It explains the criteria used for evaluation, distinguishes differences in regulatory risk, operational complexity, and suitability for a small utility, and documents why the IPR via Surface Water Augmentation alternative is recommended. The chapter frames project selection as a risk-balanced planning decision rather than a cost-only choice.
(a) Justification
Provide a justification of why the proposed water reclamation, recycling, or desalination project is the selected alternative in terms of meeting objectives, demands, needs, cost effectiveness, and other criteria important to the decision.
The Proposed Water Project was selected as the preferred alternative because it most effectively meets the project objectives of improving long-term water supply reliability, enhancing drought resilience, reducing reliance on environmentally constrained supplies, and doing so in a costeffective and operationally feasible manner. Compared to the other alternatives evaluated, the Proposed Project provides a locally controlled, climate-resilient water supply that directly addresses existing and projected demands while aligning with State and Federal water management priorities.
The Proposed Project leverages advanced treatment and reuse of existing wastewater flows to produce a high-quality, reliable water supply without the need for new raw water sources or significant expansion of upstream diversions. This approach maximizes beneficial reuse of an existing resource, improves system redundancy, and reduces vulnerability to hydrologic variability, regulatory constraints, and supply interruptions. From a cost-effectiveness perspective, the Proposed Project offers favorable life-cycle costs relative to alternatives that require new conveyance, storage, or imported water infrastructure, while also providing measurable non-monetary benefits such as improved system reliability, regulatory compliance, and environmental protection.
In addition, the Proposed Project is technically feasible, scalable, and consistent with evolving State and Federal potable reuse frameworks. It can be implemented in phases, allowing the City to match investments to demand growth and funding availability while minimizing near-term financial impacts on ratepayers. Collectively, these factors support selection of the Proposed Project as the most balanced and prudent alternative.
(b) Affirmative Statement
(i) Reduction, Postponement or Elimination of New or Expanded Supplies Reduction, postponement, or elimination of new or expanded supplies.
The Proposed Project would postpone the need for new or expanded conventional water supplies by developing a reliable local reuse supply that offsets demand otherwise met through additional groundwater development or other undeveloped local sources. By augmenting the existing water supply portfolio with purified recycled water, the Project decreases dependence on future supply expansions that are increasingly costly, uncertain, and subject to environmental and regulatory constraints. As a result, the City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 6 Page | 46
Project defers the need for additional groundwater development or other new conventional water supplies while improving overall supply resilience. (ii) Reduction or Elimination of Existing Diversions
Reduction or elimination of the use of existing diversions from natural water courses, or withdrawals from aquifers.
The Proposed Project would reduce reliance on existing diversions from natural watercourses and withdrawals from groundwater aquifers by substituting recycled water for potable demand that would otherwise be met by these sources. Over time, this reduction in diversion pressure supports improved watershed conditions, helps stabilize groundwater basins, and contributes to more sustainable long-term resource management. While not eliminating existing diversions entirely, the Project provides a measurable reduction in their use during both average and drought conditions. (iii) Reduction of Demand on Federal Facilities
Reduction of demand on existing Federal water supply facilities.
The City’s water and wastewater systems are locally owned and operated and are not connected to any Federal water supply facilities. Therefore, the Proposed Project would not directly reduce demand on existing Federal facilities. Nevertheless, the Project is fully consistent with the objectives of the Water Reclamation and Reuse Program under Title XVI by expanding the beneficial reuse of locally generated wastewater to improve water supply reliability, drought resilience, and long-term sustainability within the City’s service area. By strengthening local water self-sufficiency and reducing vulnerability to hydrologic variability and emergency supply disruptions, the Project helps defer or avoid the need for future regional or Federally supported water supply development. In doing so, the Project advances Federal priorities to promote water reuse, optimize existing local resources, reduce long-term infrastructure and energy demands, and improve system resilience in water-stressed coastal communities, even where no Federal water supply facilities are currently in use.
(iv) Reduction, Postponement, or Elimination of New or Expanded Wastewater Facilities Reduction, postponement, or elimination of new or expanded wastewater facilities.
By diverting a portion of treated effluent for potable reuse, the Proposed Project would reduce the overall volume of wastewater requiring discharge and disposal. This reduction in effluent volumes decreases hydraulic loading on existing wastewater treatment, conveyance, and discharge facilities, including ocean outfalls and associated disposal infrastructure. Over time, lower discharge demands can postpone or eliminate the need for future expansion of treatment capacity, conveyance improvements, or outfall upgrades that would otherwise be required to accommodate population growth, regulatory changes, or increased wet-weather flows.
In addition, integrating potable reuse into the wastewater system improves overall operational efficiency by transforming a treated waste stream into a beneficial water supply, rather than requiring additional infrastructure solely for disposal purposes. This approach aligns wastewater management and water supply planning objectives, supports long-term regulatory compliance, and reduces capital and lifecycle costs associated with stand-alone wastewater facility expansion.
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7. ENVIRONMENTAL CONSIDERATIONS AND POTENTIAL EFFECTS
The review of a water reclamation, recycling or desalination feasibility study report does not require National Environmental Policy Act (NEPA) compliance. The Department of the Interior categorical exclusion 1.11 “Activities which are educational, informational, advisory, or consultative to other agencies, public and private entities, visitors, individuals or the general public” applies to Reclamation’s consultative review, and preparation of the water reclamation, recycling, or desalination feasibility study report.
As stated in Paragraph 1, Scope, Reclamation is not making a recommendation to go forward with the proposed water reclamation, recycling, or desalination project, nor is Reclamation using the water reclamation, recycling, or desalination feasibility study report to propose an action to the Congress.
This chapter summarizes the environmental setting, potential impacts, and regulatory pathways associated with the Proposed Project. It identifies key resource areas, outlines anticipated CEQA and NEPA requirements, and discusses how the project supports broader environmental objectives, including protection of sensitive surface waters. The chapter demonstrates that environmental review and resource protection are integral components of project implementation.
A preliminary environmental assessment was conducted to identify whether the proposed water reclamation project could result in potentially significant environmental impacts or involve unique or undefined environmental risks. The assessment evaluated biological resources, cultural resources, regulated waters, public health and safety, and other environmental considerations across treatment alternatives, pipeline alignments, and storage options.
The review determined that potential impacts are primarily associated with construction-related ground disturbance and conveyance infrastructure and are highly dependent on the final selection of treatment alternative and associated facilities. Project components located within existing, highly disturbed operational footprints, such as the WWTP, SWTP, and existing Summers Lane Reservoir, present low environmental risk. Components proposed in undeveloped areas, including certain pipeline alignments and new reservoir sites, present higher constraints due to the presence or potential presence of sensitive biological habitats, jurisdictional waters, and undocumented cultural resources. These impacts are anticipated to be temporary and can be reduced to less-than-significant levels through avoidance, design refinements, and implementation of mitigation measures.
(a) Compliance with NEPA and Other Federal Law
The water reclamation, recycling or desalination feasibility study report must include sufficient information on the proposed water recycling or desalination project to allow Reclamation to assess the potential measures and costs that will be necessary to comply with NEPA, and any other applicable Federal law. The following is required:
This feasibility study includes sufficient environmental information to allow Reclamation to assess the potential measures, regulatory requirements, and costs that would be necessary to comply with NEPA and other applicable Federal laws should Federal funding for construction be pursued in the future. Environmental considerations associated with Pipeline Alignments D and F are summarized below.
(i) Endangered or Threatened Species
Discussion of whether, and to what extent, the proposed water reclamation, recycling, or desalination project will have potentially significant impacts on endangered or threatened species, public health or safety, natural resources, regulated waters of the United States, or cultural resources.
Pipeline Alignment D has the potential to affect endangered or threatened species due City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 7 Page | 48
to its crossing of the Noyo River and its location within undeveloped habitat. The Noyo River supports a documented steelhead run (Northern California DPS, winter-run), and portions of the alignment intersect habitat suitable for the northern red-legged frog, a California Department of Fish and Wildlife (CDFW) species of special concern. In addition, Alignment D intersects documented occurrences of Bolander’s beach pine and Mendocino pygmy cypress forest, a CDFW-designated sensitive natural community. As a result, implementation of Alignment D could require focused biological surveys, Endangered Species Act consultation, and avoidance or mitigation measures to address potential impacts.
Pipeline Alignment F follows the same western corridor as Alignment D but terminates at the Potable Water Treatment Plant and does not extend into undeveloped areas or cross the Noyo River. The alignment is largely confined to existing paved roadways within an urban setting and lacks suitable habitat for special-status wildlife species. While special-status plant species have been documented in the broader vicinity, impacts are expected to be limited if construction remains within existing disturbed rights-of-way.
Therefore, Alignment F is not anticipated to result in significant impacts to endangered or threatened species.
(ii) Potentially Significant Environmental Effects
Discussion of whether, and to what extent, the project will have potentially significant environmental effects or will involve unique or undefined environmental risks.
Pipeline Alignment D presents the greatest potential for significant environmental effects among the evaluated pipeline options due to its interaction with sensitive biological resources and regulated waters. Potential impacts include disturbance to riparian and aquatic habitat associated with the Noyo River, effects on sensitive vegetation communities, and increased regulatory permitting requirements. While these impacts are anticipated to be temporary and mitigable through project design refinements, focused surveys, and implementation of mitigation measures, they represent a higher level of environmental risk relative to other pipeline alternatives.
Pipeline Alignment F presents substantially fewer environmental risks. By remaining within developed areas and avoiding jurisdictional waters, Alignment F minimizes the potential for significant biological and aquatic impacts and reduces permitting complexity. Environmental effects associated with Alignment F are expected to be limited, temporary, and reducible to less-than-significant levels through standard construction practices and mitigation measures. The potential environmental impacts of both alignments are described in .
(iii) Status of Environmental Compliance Measures
Description of the status of required Federal, state, tribal, and/or local environmental compliance measures for the proposed water reclamation, recycling or desalination project, including copies of any documents that have been prepared, or results of any relevant studies.
No CEQA document has yet been prepared for the selected pipeline alignment. Based on the preliminary environmental assessment, preparation of an Initial Study/Mitigated Negative Declaration is anticipated to be sufficient for environmental compliance. If Pipeline Alignment D is selected, additional regulatory coordination and permitting City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 7 Page | 49
related to biological resources and regulated waters would be required, including Clean Water Act and Endangered Species Act compliance. The potential environmental impacts of the Proposed Project using Pipeline Alignment D are detailed in Table 7-1.
Potential Environmental
Impacts Impact Rating Description
Agricultural and Forestry
Resource Low
Alignments traverse urbanized or previously disturbed
areas; no conversion of agricultural or forestry land
anticipated.
Air Quality Low Short-term construction emissions only; no long-term operational emissions anticipated.
Greenhouse Gas
Emissions Low Temporary construction-related emissions; project supports long-term water supply resilience.
Biological Resources High Alignment D intersects sensitive habitats and specialstatus species habitat.
Cultural Resources Moderate
Both alignments traverse areas within known historic
and archaeological districts, requiring standard
mitigation and monitoring.
Energy Low Energy use limited to pumping requirements; no unusual or undefined risks identified.
Hydrology and Water
Quality High Alignment D crosses the Noyo River.
Groundwater Low No groundwater extraction or recharge impacts associated with pipeline construction.
Hazards and Hazardous
Materials (used during
construction and operation)
Low Standard construction materials and practices; no
long-term hazards anticipated.
Noise Low Temporary construction noise only.
Public Health or Safety Low Construction impacts manageable; long-term operation improves water supply reliability.
Transportation (Traffic
impacts during
construction)
Low–Moderate Temporary traffic disruptions during construction within roadways.
(iv) Other Information
Any other information available to the study lead that would assist with assessing the measures that will be necessary to comply with NEPA, and other applicable Federal, state, or local environmental laws such as the Endangered Species Act or the Clean Water Act.
Environmental review conducted for this feasibility study provides sufficient detail to inform future NEPA and CEQA compliance efforts. The analysis identifies specific areas where focused biological surveys, aquatic resource delineations, cultural resource Table 7-1 PotenƟal Environmental Impacts of Pipeline Alignment D City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 7 Page | 50
assessments, and tribal consultation may be required, allowing the City to anticipate regulatory timelines and costs during subsequent project phases. (v) Impact on Water Supply and Water Quality
Discussion of how the proposed water reclamation, recycling or desalination project will affect water supply and water quality from the perspective of a regional, watershed, aquifer, or river basin condition.
Both pipeline alignments would support delivery of advanced treated recycled water, improving long-term water supply reliability and resilience in the regional watershed.
Alignment F achieves these benefits while minimizing interaction with sensitive surface waters, whereas Alignment D introduces additional risk to water quality during construction due to its crossing of the Noyo River. With appropriate controls, neither alignment is anticipated to result in long-term adverse effects on regional water quality. (vi) Public Involvement
Discussion of the extent to which the public was involved in the feasibility study, and a summary of comments received, if any.
The City of Fort Bragg engaged its residents and businesses through educational outreach about recycled water benefits, safety, and environmental sustainability. The City wanted to ensure that diverse community voices were heard and incorporated into the planning process. The City leveraged current awareness of regional drought challenges to demonstrate how recycled water provides a reliable, locally controlled water source. It provided transparent information about costs, treatment processes, and safety measures to build trust and understanding of the City’s water management approach. Help stakeholders understand how this initiative fits into Fort Bragg’s longterm water security strategy.
Targeted communication tools that facilitated two-way dialogue made it easy for community members to participate in the planning process. Consistent, clear communication channels were maintained as described below. • Community Town-Hall Meetings: The City hosted two community town hall meetings strategically scheduled based on project milestones and community feedback, ensuring the City was responsive to stakeholder needs Each session included a presentation and a general Q&A from the public. • Online Survey: A project-specific survey was developed to provide stakeholders with the opportunity to provide feedback on the City’s project and suggested alternatives.
• Project Flyer. A project-specific flyer was created to provide a general overview of the project alternatives and outlined future supply needs for the City. The flyer was included with utility bills and emailed to community groups. • Project Website: The City developed a project specific website that it updated as the project progressed. Community members were able to review the project alternatives, as well as provide active and on-going feedback and the respective options.
• Social Media. The City posted study updates about the study on its social media accounts.
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(vii) Potential Effects on Historic Properties.
Description of the potential effects the project will have on historic properties. Discussion must include potential mitigation measures, the potential for adaptive reuse of facilities, an analysis of historic preservation costs, and the potential for heritage education, if necessary.
Pipeline Alignment D passes through areas within the Georgia-Pacific Lumber Mill Historic District and the Fort Bragg Native American Archaeological District. However, construction would be limited to previously disturbed corridors, and no contributing historic features or known archaeological resources would be directly affected. No historic properties eligible for listing on the National Register of Historic Places have been identified within the alignment footprints. If previously unknown or unmarked cultural resources are encountered during construction, appropriate mitigation measures, including work stoppage, evaluation, and consultation, would be implemented in accordance with applicable regulations.
(b) Project Timeline in Regard to Environmental and Cultural Compliance If, at a later date, Reclamation provides funds for construction, all appropriate NEPA and other environmental and cultural compliance must be completed prior to any ground disturbing activities beginning in order for the project to be eligible.
If Reclamation provides funds for construction at a later date, all applicable NEPA, CEQA, and other environmental and cultural compliance requirements would need to be completed prior to initiation of ground-disturbing activities in order for the project to remain eligible for Federal funding.
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8. LEGAL AND INSTITUTIONAL REQUIREMENT
The water reclamation feasibility study shall identify any legal or institutional requirements, or barriers to implementing the proposed project.
This chapter addresses governance, permitting, interagency coordination, and implementation sequencing. It clarifies the City’s role as project proponent and long-term compliance entity, distinguishes consultant and regulatory roles, and outlines the steps required to move from feasibility to construction. The chapter emphasizes that potable reuse is not only an engineering project, but an institutional commitment requiring sustained local capacity. (a) Analysis of Water Rights
Analysis of any water rights issues potentially resulting from implementation of the proposed water reclamation, recycling desalination project. All proposed water reclamation, recycling or desalination projects must comply with state water law.
The Fort Bragg’s domestic water system is supplied by local surface water diversions from the Noyo River, Newman Gulch (a tributary to the Noyo River), and an unnamed stream locally known as Waterfall Gulch, a tributary to Hare Creek. The City’s surface water supplies are governed by a combination of appropriative and pre-1914 water rights, which define the conditions under which surface water may be diverted and used in California.
The City holds post-1914 appropriative water rights issued by the SWRCB for diversions from both Waterfall Gulch and the Noyo River. These rights authorize diversions of up to 480 AFY from Waterfall Gulch and 2,172 AFY from the Noyo River. However, the State authorized those rights with an annual aggregate diversion limit of 1,500 AFY. This cap represents the maximum total volume the City may appropriate annually across its post-1914 surface water rights, rather than a simple sum of the individual source entitlements.
As a result, the City is not able to fully exercise the nominal entitlement associated with each individual source concurrently, particularly during dry hydrologic conditions. To support operational reliability and seasonal storage within this regulatory framework, the City constructed the 45 AF Summers Lane Reservoir in 2016 to store water diverted from Waterfall Gulch under its permitted Noyo River appropriative rights.
In addition, the City holds pre-1914 appropriative water rights for Newman Gulch, which authorize the diversion and storage of up to 300 AFY. These senior rights are not subject to the same permitting and annual diversion limits, and provide an important supplemental supply within the City’s surface water portfolio. After accounting for applicable regulatory limitations, the City’s existing water rights authorize a maximum annual diversion of 1,800 AFY. (b) Legal and Institutional Requirements
Discussion of legal, institutional, state and/or local requirements with the potential to affect implementation of the project. Water reclamation, recycling or desalination projects using Reclamation project water must address contractual requirements as described in RM D&S, Reuse of Reclamation’s Project Water (PEC 05-09).
Diversions. Noyo River diversions are constrained by the SWRCB, requiring that the City must allow (“bypass”) 3 cubic feet per second (cfs) of water to continue flowing downstream during the summer (June-September) and 10 cfs during the winter (October-May), whenever the tide is equal to or less than 2’. During these periods, reservoir storage is vital to meeting the City’s water supply demands.
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Waterfall Gulch diversions are restricted by the U.S. Fish and Wildlife Service through a Streambed Alteration Agreement when Summers Lane Reservoir was constructed. The agreement requires the City to bypass 25% of the flow from Waterfall Gulch, unless the City is in a drought situation when the bypass can be reduced to 10%.
Local Coastal Zone. Project components located within the California Coastal Zone must comply with the County of Mendocino Local Coastal Program (LCP) and associated development standards. The LCP implements the California Coastal Act and establishes policies related to protection of coastal resources, public access, visual quality, and environmentally sensitive habitats. Compliance with the LCP could influence project siting, design, construction methods, and permitting timelines. However, water and wastewater infrastructure projects that serve public health and resource protection objectives are generally allowable under the LCP when designed to minimize coastal impacts and avoid sensitive resources. Coordination with Mendocino County and the California Coastal Commission would be required to ensure consistency with applicable LCP policies.
Timber Harvest Plan. If the project is anticipated to include the removal of trees, a Timber Harvest Plan (THP) must be submitted to the California Department of Forestry and Fire Protection (CAL FIRE) under the California Forest Practice Rule. A THP is the functional equivalent of a CEQA Environmental Impact Report (EIR) and must be prepared and submitted by a Registered Professional Forester (RPF).
(c) Multi-Jurisdictional and Interagency Activities
Discussion of the need for multi-jurisdictional or interagency agreements, coordination undertaken, and any planned activities.
Implementation of the Proposed Project will require coordination with multiple Federal, State, regional, and local agencies to ensure regulatory compliance. The City will serve as the lead agency, with coordination anticipated with Reclamation, the SWRCB (including the DDW), the RWQCB, CDFW, and Mendocino County, particularly for project components located within the California Coastal Zone. Tribal consultation will also be conducted, as appropriate, to address potential cultural resource considerations.
To date, coordination has focused on early consultation and identification of environmental constraints and permitting requirements. Planned coordination activities include continued City engagement during environmental review, preparation of required permits and approvals, and execution of any necessary interagency or access agreements as the Project advances. (d) Permitting Procedures
Discussion of permitting procedures required for the implementation of water reclamation, recycling or desalination projects in the study area, and any measures that the City can implement that could speed up the permitting process.
Obtaining a permit for a recycled water facility in California requires navigating several essential steps and meeting specific requirements, which are primarily overseen by the SWRCB and the local RWQCB. The North Coast Water Board is the local entity with permitting authority over the City’s treatment plant and future recycled water programs. These requirements fall under two separate classifications: permitting for the treatment facility itself and permitting a water recycling program including the issuance of water recycling permits to end users. A summary of these permits is shown in Table 8-1.
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Table 8-1 Permits and Plans Required for Proposed Project Agency Permit / Plan Trigger Applicability Timing/Lead Time City of Fort Bragg Building,
Encroachment, and
Right-of-Way Permits
Construction within
City facilities,
streets, or rights-ofway
Required 1–3 months
Mendocino County Coastal Development
Permit (CDP)
Project components
located within the
California Coastal
Zone
Required 3–6 months
California Coastal
Commission
CDP Appeal (if
applicable)
Appealable
development within
Coastal Zone
Possible +1–3 months if
appealed
California Department
of Fish and Wildlife
(CDFW)
Section 1602
Streambed Alteration
Agreement
Work within a
stream, river, or
riparian habitat
Required 3–6 months
City of Fort Bragg
(CEQA Lead Agency)
CEQA Compliance
(IS/MND anticipated)
State or local
discretionary
approvals
Required 6–9 months
RWQCB, North Coast
Region (Region 1)
NPDES Wastewater
Discharge Permit
(Ocean Outfall/CA
Ocean Plan)
Continued
discharge of treated
wastewater
Required
(existing permit)
Renewed every 5
years
Clean Water Act
Section 401 Water
Quality Certification
Discharge or fill
affecting waters of
the State
Required
(reservoir or
conveyance
work)
3–6 months
SWRCB – Division of
Drinking Water
Title 22 Potable Reuse
Requirements
(SWA/RWA/TWA) and
Recycled Water
General Order (Order
WQ 2016-0068-DDW)
Use of recycled
water for IPR
Required 6–12 months
(NOI review)
SWRCB – Division of
Water Rights
Wastewater Change
Petition
Change in place of
use of treated
effluent
Required 3–5 years
Tribal Governments Tribal Consultation Ground-disturbing activities in
sensitive areas
Required Ongoing /
parallel
U.S. Army Corps of
Engineers (USACE)
Clean Water Act
Section 404 Permit
Placement of fill or
structures in U.S.
waters
Required
(if applicable)
6–12 months
U.S. Bureau of
Reclamation
(if Federal funding)
NEPA Compliance Federal funding or
Federal action
Required 9–18 months
U.S. Fish and Wildlife
Service/ NOAA
Fisheries
Endangered Species
Act Consultation
Potential effects on
listed species or
habitat
Likely 6–12 months
CAL FIRE Timber Harvesting Plan
(THP)
Tree removal in
State Responsibility
Areas
Possible Prior to
construction
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The pipeline alignment selected for the Proposed Project (shown in XXXXX) includes a crossing of the Noyo River, which would trigger environmental review and permitting at the local, State, and Federal levels. Coordination with the California Department of Fish and Wildlife (CDFW) and the U.S. Army Corps of Engineers (USACE) would be required, particularly if Federally listed species or designated critical habitat could be affected. In addition, this alternative would require access and encroachment agreements for construction within City, County, and State rights-of-way.
The pipeline alignment generally parallels the City’s existing raw water pipeline between the SWTP and the Summers Lane Reservoir, as identified in the City’s Raw Water Line Replacement Project Initial Study/Mitigated Negative Declaration (May 2023) and confirmed through Cityprovided GIS data. Portions of this alignment will require easements for access along Noyo Point Road, where ownership is currently unclear and additional investigation will be necessary. In addition, the City’s 2019 Raw Water Line Replacement Project Existing Conditions and Constraints identifies existing ten-foot easements along the current raw water alignment. The alignment could be constructed within those easements, or the City could seek to expand the existing easements as needed to accommodate the new pipeline. (e) Unresolved issues
Discussion of any unresolved issued associated with implementing the proposed water reclamation, recycling, or desalination project, how and when such issues will be resolved, and how the project would be affected if such issues are not resolved.
Several issues associated with implementation of the proposed water reclamation and recycling project remain to be resolved beyond the feasibility level. These include completion of environmental review under CEQA (and NEPA, if Federal funding is pursued), confirmation of permitting requirements and regulatory approvals, and finalization of project design details.
Resolution of these issues will occur during subsequent phases of project development through preparation of environmental documentation, completion of supporting technical studies, and continued coordination with regulatory agencies.
Funding availability and implementation timing also remain unresolved and will be addressed through continued pursuit of Federal, State, and local funding sources and refinement of project phasing to align scope with available resources. If these issues are not resolved, project implementation could be delayed or require modifications to schedule or phasing; however, none of the identified issues are expected to preclude implementation of the proposed project. (f) Wastewater Discharge Requirements
Identification of current and projected wastewater discharge requirements resulting from the proposed water reclamation, recycling, or desalination project (e.g., brine disposal) Under existing conditions, discharge from the Fort Bragg wastewater treatment plant is regulated by the RWQCB, North Coast Region, through Waste Discharge Requirements that also serve as the facility’s NPDES permit. The permit establishes effluent limits, monitoring, and operational requirements for treated wastewater discharged to the ocean, consistent with the California Ocean Plan and applicable Federal Clean Water Act requirements.
Implementation of the proposed potable reuse project would alter discharge conditions by diverting a portion of treated effluent from ocean discharge to beneficial reuse. As a result, overall wastewater discharge volumes are expected to decrease relative to existing conditions, City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 8 Page | 56
while the existing NPDES permit would remain in effect. Future permit renewals or modifications may be required to reflect changes in average and peak discharge flows, discharge timing, and monitoring requirements associated with reduced effluent volumes.
The Proposed Project would generate residual waste streams associated with advanced treatment processes, including reverse osmosis concentrate, membrane backwash, and cleaning residuals. These residuals are anticipated to be managed through the City’s existing wastewater treatment system and discharged via the existing ocean outfall in accordance with the City’s NPDES permit, rather than requiring new or separate discharge facilities. Management of these residuals would be further evaluated during detailed design and coordinated with the RWQCB to ensure continued compliance with applicable permit requirements and water quality standards. (g) Rights to Wastewater Discharges
Description of rights to wastewater discharges resulting from implementation of the proposed water reclamation, recycling, or desalination project.
The City of Fort Bragg owns and operates the municipal wastewater collection, treatment, and disposal system serving the community. All wastewater generated within the City’s service area is conveyed to the City’s WWTP, which is owned and operated by the City under NPDES permit.
As the owner and operator, the City retains authority over the management, treatment, reuse, and discharge of treated effluent produced at the facility, subject to applicable State and Federal regulatory requirements. Implementation of the Proposed Project would not alter the City’s rights or responsibilities with respect to wastewater discharges. Rather, the project would redirect a portion of treated effluent from the existing permitted discharge for beneficial reuse, while maintaining compliance with the City’s NPDES permit and other applicable approvals.
Any treated effluent not diverted for reuse, as well as residual waste streams generated by advanced treatment processes, would continue to be managed and discharged through the existing, permitted ocean outfall. No other public agencies or third parties hold ownership interests in or competing claims to the City’s wastewater discharges. The City would retain full authority to determine how treated wastewater is managed, reused, or discharged, consistent with applicable permits and regulatory oversight.
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9. FINANCIAL CAPABILITY OF SPONSOR
At the water reclamation, recycling or desalination feasibility study stage, Reclamation must request enough information to determine that the City is likely to demonstrate financial capability if the project moves to construction. Reclamation will require more detailed information to make a determination that the City is financially capable of funding the non-Federal share of the project’s costs before a funding agreement covering construction can be executed. Accordingly, the following information is required to be included in the water reclamation, recycling, or desalination feasibility study report.
This chapter evaluates the City’s financial capacity to implement and operate the Proposed Project. It describes rate structures, revenue constraints, and affordability considerations, and distinguishes between technical feasibility and financial feasibility. The chapter establishes that implementation is fundamentally dependent on external grant and low-interest financing and identifies funding dependency as a key project risk. It explains why Federal participation is essential for a Severely Disadvantaged Community.
(a) Proposed Schedule
Insert proposed schedule for project implementation.
The five-year Proposed Project schedule includes commencement of activities at the beginning of 2032 with completion by end of 2036. The schedule, shown in Table 9-1, encompasses key steps: completing the design process, finalizing CEQA/NEPA documentation, initiating the required permits, soliciting bids, securing authorization to award construction contracts, awarding contracts, issuing notices to proceed and construction.
Table 9-1 Proposed Project Schedule
(b) Non-Federal Project Sponsor Funding
Discussion of the willingness of the City to pay for its share of capital costs and the full operations, maintenance, and replacement costs.
The City of Fort Bragg is committed to funding its non-Federal share of capital cost and to fully funding the long-term operations, maintenance, and replacement (OM&R) costs associated with the Proposed Project. The City has an established utility enterprise structure, which provides it with the legal authority to set and adjust water and wastewater rates, collect capacity fees, and issue debt for major capital programs.
The City has a demonstrated history of taking necessary financial actions to responsibly maintain its utility systems. Previous rate studies (2016 and 2022) were conducted to ensure revenues were aligned with operational needs, regulatory requirements, and capital improvement priorities. Historically, the City Council has supported water and wastewater rate adjustments over the past decade to address infrastructure needs, regulatory compliance, and financial sustainability. In addition, the City has adopted a formal Debt Management Policy and has successfully issued debt in the past to support large capital improvements at the wastewater treatment facility, demonstrating the City’s ability to leverage financing when appropriate.
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While the City is committed to funding its non-Federal share, the scale of a potable reuse project relative to the City’s small rate base makes Federal participation essential to maintain customer affordability and overall project feasibility. As such, the City will pursue a balanced cost-share approach that combines grants, low-interest financing, and rate-based revenues. (c) Funding Plan
Funding construction, operation, maintenance, and replacement costs including an analysis of how the non-Federal project sponsor will pay for construction, annual operation, maintenance, and replacement costs The City intends to implement a balanced funding strategy to support both project construction and long-term operation of its recycled water facilities. Capital costs are anticipated to be funded through a combination of Federal and State grant programs, low-interest financing, potential bond issuance, and pay-as-you-go contributions from existing enterprise revenues and reserves.
The City’s Water and Wastewater Enterprise Funds provide dedicated, self-sustaining financial mechanisms that ensure all revenues including those derived from user service charges, connection fees, and other utility income remain within each enterprise and are reinvested in system maintenance, replacement, and expansion. Surplus fund balances and reserves are allocated to finance capital improvements, provide local match funding for external grants, and stabilize utility rates over time.
Operations, maintenance, and replacement (OM&R) costs will be funded through water enterprise rates collected from customers over the life of the project. To ensure long-term financial sustainability, the City will incorporate project costs into future water and wastewater rate studies and adjust rates as necessary to fully support OM&R, reserve targets, and asset replacement planning. This approach ensures that the City maintains full funding responsibility for long-term operations, as required by Reclamation, and demonstrates the City’s fiscal capability to finance, operate, and maintain recycled water facilities through prudent financial management and sustainable enterprise fund practices.
Funding Dependency and Financial Feasibility Risk
Although the Proposed Project is technically feasible and provides substantial reliability and resilience benefits, its implementation is fundamentally dependent on external grant and lowinterest financing. As a Severely Disadvantaged Community, Fort Bragg has limited ratepayer capacity to absorb the full capital and operating costs associated with advanced treatment and potable reuse. Absent significant State and Federal funding, the Proposed Project would not be financially viable without imposing rate increases that are inconsistent with community affordability and equity objectives.
In this context, project feasibility falls into two tiers:
(1) Technically feasible and implementable with grant support; and (2) Not financially feasible if funded solely through local rates.
The purpose of this Feasibility Study is not to commit the City to construction regardless of funding conditions, but to position the Proposed Project for competitive funding programs such as Reclamation’s Title XVI program and complementary State grant opportunities. Securing external funding is a prerequisite for implementation.
Funding dependency should be recognized as a key project risk. Delays or shortfalls in grant City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 9 Page | 59
availability would defer implementation and prolong reliance on vulnerable surface water supplies and emergency response measures. Conversely, successful grant awards would enable the City to deliver a durable, drought-resilient supply without imposing unsustainable financial burdens on a severely disadvantaged community.
(d) Sources of Funding
Description of all Federal and non-Federal sources of funding and any restrictions on such sources, for example, minimum or maximum cost-share limitations. Generally, for water reclamation, recycling or desalination projects, the Federal cost share is limited to 25 percent, or $30M, whichever is less.
The proposed project is anticipated to be funded through a combination of Federal, State, and local sources, as shown in Table 9-2. Federal participation is expected primarily through Reclamation’s Title XVI Water Reclamation and Reuse Program. Consistent with Federal policy, the City anticipates a maximum Federal cost share of up to 25 percent of eligible project costs, not to exceed $30 million. Federal investment would play a key role in reducing the financial burden on local ratepayers while supporting development of a resilient, locally controlled water supply. In addition, the City plans to evaluate the use of the U.S. Environmental Protection Agency’s Water Infrastructure Finance and Innovation Act (WIFIA) loan program, which can finance up to 49 percent of total project costs at favorable, long-term, Treasury-based interest rates.
State participation is also expected under the SWRCB’s Water Recycling Funding Program (WRFP), which supports water recycling and advanced treatment projects that improve water supply reliability, enhance drought resilience, and reduce treated wastewater discharges. The Proposed Project aligns with WRFP objectives by advancing potable reuse using proven technologies to augment local water supplies and optimize existing water and wastewater infrastructure. As the Project advances beyond feasibility, completion of CEQA compliance, engineering documentation, and regulatory approvals would position the City for consideration under applicable WRFP planning or construction funding opportunities. The City is an eligible public agency and owner/operator of the relevant water and wastewater systems, and the Project supports Statewide WRFP priorities to expand water recycling, improve system reliability, and enhance climate resilience.
Non-Federal funding is also expected to include support through programs administered by the Department of Water Resources, including the Clean Water State Revolving Fund (CWSRF) and Drinking Water State Revolving Fund (DWSRF), which provide below-market interest loans for water reuse and potable supply reliability projects. Depending on eligibility and funding availability, these programs may also offer principal forgiveness, which the City will actively pursue to further reduce financing costs. Additional State grant opportunities include the Integrated Regional Water Management (IRWM) Program and other State resilience and climate adaptation funding programs.
The remaining non-Federal share of project costs will be funded through local revenue sources, including water and wastewater enterprise rates, connection and capacity fees, reserves, and potential future debt. The City maintains a Debt Management Policy and has demonstrated a willingness to adjust rates, consistent with applicable legal requirements, to ensure the long-term financial health of its utility systems. All operations, maintenance, and long-term replacement City of Fort Bragg Recycled Water Project Feasibility Study DRAFT FINAL January 2026 Hoch Consulting Chapter 9 Page | 60
costs associated with the project will be funded locally through utility rate revenues once the project is placed into service.
Funding Source Type Estimated
Share Notes
Water and
Wastewater
Enterprise Funds
City funds TBD
(portion of nonFederal share)
Used to provide required local
match, cash contributions, and to
support debt service; funded
through adopted rate-setting and
enterprise fund policies.
USBR Title XVI Water
Reclamation and
Reuse Program
Federal grants Up to 25% of
eligible
project costs
(not to exceed
$30M)
Primary Federal program supporting
water reclamation, recycling, and
potable reuse projects; Federal
share limited by statute.
EPA WIFIA Low-interest Federal
loan
Up to 49% of
total project
costs
Long-term financing at U.S. Treasury
rates; repayment may be deferred
up to five years after substantial
completion; can be combined with
grants but cannot exceed total
project cost limits.
State Revolving Fund
(SWRCB CWSRF & DWSRF)
State low-interest
loan + potential
principal forgiveness
Approximately
25–40% of
remaining
eligible costs
Below-market financing
administered by the State Water
Resources Control Board; principal
forgiveness subject to eligibility
criteria and available funding.
State Grants
(WRFP, IRWM, DWR
Programs)
State grants TBD
(competitive)
Competitive grant programs
supporting recycled water, potable
reuse, drought resilience, and
regional water supply projects;
funding caps and cost-share
requirements vary by program.
Local Share
(Rates,
Connection/Capacity Fees,
Reserves, Future Debt)
Local revenue Remainder of
project costs
Covers required non-Federal share
of capital costs and 100% of
operations, maintenance, and
replacement costs; supported
through rates, reserves, and future
debt as needed.
Table 9-2 Proposed Project Funding Strategy
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10. RESEARCH NEEDS
At a minimum, the report must include a statement on whether the proposed water reclamation, recycling or desalination project includes basic research needs, and the extent that the proposed water reclamation project will use proven technologies and conventional system components. The following information is required only if further research is necessary to implement the proposed water reclamation, recycling, or desalination project:
This chapter identifies the studies required to advance the Proposed Project from feasibility to implementation. It distinguishes between regulatory prerequisites, such as pilot testing and pathogen validation, and optional optimization efforts that may be pursued as resources allow.
The chapter clarifies the critical path for regulatory approval and positions future research as a structured, phased program aligned with permitting and design milestones. Certain targeted studies may be required to confirm site-specific performance, support regulatory documentation, and reduce implementation risk, consistent with the requirements of the Title XVI Program. This chapter does not include basic or experimental research.
Required Studies for Regulatory Approval
These are on the critical path for DDW approval of an IPR project and would be required before final design and construction:
1. Advanced Treatment Pilot/Demonstration Testing (RO, UV/AOP, Ozone/BAC) Research need: Applied pilot or demonstraƟon tesƟng may be conducted at a reduced scale to confirm site-specific advanced treatment performance, recovery rates, operaƟonal reliability, and compaƟbility with local wastewater quality condiƟons. TesƟng would support final design assumpƟons and confirm treatment robustness under seasonal variability for the IPR via SWA configuraƟon.
Basis for ReclamaƟon parƟcipaƟon: Pilot tesƟng supports implementaƟon of proven water reclamaƟon technologies and is a standard, eligible acƟvity under Title XVI to advance water reuse, drought resilience, and sustainable local supplies.
Research parƟes: City of Fort Bragg (lead), design engineer, specialty pilot vendors; coordinaƟon with DDW.
Timeframe: Approximately 12–24 months, including tesƟng, analysis, and reporƟng.
2. Pathogen Validation Studies
Research need: Pathogen validaƟon studies are required to demonstrate compliance with regulatory log-reducƟon requirements for viruses, Giardia, and Cryptosporidium using ozone, biologically acƟvated carbon, and advanced oxidaƟon processes. These studies are a prerequisite for potable reuse approval and confirm performance of established treatment processes under local operaƟng condiƟons.
Basis for ReclamaƟon parƟcipaƟon: ValidaƟon studies directly support implementaƟon of potable reuse using proven technologies and are consistent with Title XVI objecƟves to protect public health while expanding water reuse.
Research parƟes: City of Fort Bragg, qualified validaƟon consultants, treatment technology vendors; oversight and review by DDW.
Timeframe: Approximately 12–18 months, coordinated with pilot or demonstraƟon tesƟng.
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3. Operations, Monitoring, and Water Safety Planning
Research need: Development of operaƟons, monitoring, and water safety plans are required to define treatment control points, monitoring protocols, operator response acƟons, and long-term operaƟonal reliability for IPR via SWA.
Basis for ReclamaƟon parƟcipaƟon: OperaƟonal planning supports sustainable implementaƟon of water reuse faciliƟes and is consistent with Title XVI goals to ensure longterm project performance and protecƟon of public health.
Research parƟes: City of Fort Bragg, design engineer, operaƟons staff; coordinaƟon with DDW and RWQCB as appropriate.
Timeframe: Approximately 6–12 months, concurrent with engineering and regulatory studies.
OpƟonal OpƟmizaƟon and ImplementaƟon Support Studies
These efforts support implementation, reduce risk, or improve constructability and cost control, but they are not prerequisites for potable reuse regulatory approval:
4. Pipeline and Conveyance Investigations (Geotechnical & Subsurface Utility Engineering) Research need: Applied engineering invesƟgaƟons are required to confirm constructability of conveyance infrastructure supporƟng the Proposed Project, including geotechnical condiƟons, groundwater, and potenƟal uƟlity conflicts along the proposed pipeline alignment.
Basis for ReclamaƟon parƟcipaƟon: Preliminary engineering invesƟgaƟons reduce project risk and support cost-effecƟve implementaƟon of water reuse infrastructure, consistent with Title XVI feasibility and planning objecƟves.
Research parƟes: City of Fort Bragg, civil/geotechnical engineers, uƟlity coordinaƟon agencies.
Timeframe: Approximately 6–12 months, prior to final design.
5. Environmental and Cultural Resource Studies (CEQA/NEPA Compliance) Research need: Focused environmental and cultural resource studies are required to support CEQA and, if applicable, NEPA compliance. These studies include biological surveys, cultural resources invesƟgaƟons, and tribal consultaƟon associated with project-related faciliƟes and conveyance infrastructure in sensiƟve areas.
Basis for ReclamaƟon parƟcipaƟon: Environmental review is a necessary component of advancing Federally assisted water reuse projects and is eligible under Title XVI as part of feasibility and implementaƟon planning.
Research parƟes: City of Fort Bragg (CEQA lead), environmental consultants, tribal governments; coordinaƟon with State and Federal resource agencies.
Timeframe: Approximately 9–18 months, depending on survey windows and consultaƟon requirements.
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REFERENCES
California Code of Regulations (CCR), Title 22, Division 4. Environmental Health.
California Department of Fish and Wildlife (CDFW). 2025a. California Natural Diversity Database (CNDDB) and RareFind. California Department of Fish and Wildlife, Sacramento, California.
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