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The saga of San Juan Bautista’s wastewater issues continued as one of the main subjects of the April 21 City Council meeting with the release of a study indicating the possibility of fines being levied by Hollister for pollutants that exceed that city’s standards.
There were two presentations on the subject: one by Kari Wagner and Olivia Williams from Wallace Group on waste from local produce facilities, and one by Jordyn Arreola and Beth Reineke from MNS Engineering on the salt content in San Juan wastewater.
The Wallace Group study, Wagner said, was intended to evaluate the processing facilities at Coke Farms, Taylor Farms and True Leaf Farms for their potential to “discharge processed wastewater to the city sewer collection and conveyance system.”
Wagner and Assistant Resident Engineer Bill Callahan visited all three facilities on Dec. 10, 2025, after receiving questionnaire responses regarding the chemicals used on-site, where their processed water goes, their source water, and any pre-treatment systems they have.
On-site, they determined the following:
- True Leaf Farms: The facility uses a dedicated treatment system for its process water, which is eventually used for crop irrigation. There are no valves that would allow them to easily redirect industrial waste into the city’s domestic sewer system.
- Coke Farms: This smaller facility uses a wetland pond for disposal. “It appears,” Wagner said, “that the facility would have to go to significant lengths to bypass their treatment system to discharge processed wastewater to the city’s collection system.”
- Taylor Farms: While this facility previously discharged to the city with permission during heavy rains in 2018, Wagner said, “that connection has since been permanently disabled.”
The Wallace Group determined that, based on the site visit, “there was no evidence of the facility bypassing their process wastewater treatment system to the city’s domestic wastewater system.”
Renicki then presented the San Juan Bautista Salt Study, which examines how the city can meet stricter wastewater salinity requirements.
The study was occasioned by San Juan’s move to send its wastewater to Hollister, which meant that the city would have to adhere to the more recent salinity limits that had not applied when San Juan operated its own treatment plant.
Under the current standards, the limits were reduced as follows:
- Total Dissolved Solids: decreased from 1,400 milligrams per liter (mg/L) to 1,200 mg/L
- Chloride: decreased from 200 mg/L to 150 mg/L
- Sodium: decreased from 250 mg/L to 200 mg/L
The report outlines three main sources of added sodium: industrial and agricultural wastewater, the natural salinity of the local groundwater and, perhaps most significantly, the use of water softeners in the city.
Should the chloride and sodium levels not be reduced, the Regional Water Quality Control Board can fine the city, depending on the level and duration of the excesses. Between 2007 and 2022, the city incurred nearly $981,000 in penalties because of similar violations.
The report recommended a “source control” strategy including better monitoring of industrial flows, creating incentives for residents to remove old water softeners and eventually blending the city’s hard groundwater with softer imported water to reduce the need for softeners.
While not disputing the report’s findings, the council members ultimately found the charts confusing and identified significant assumptions and gaps.
Saying the report was “short of some finalized data,” Councilmember Scott Freels suggested tabling the vote on accepting the report pending a revision, which the council agreed to.
The final long presentation by Kushboo Ingle of the Matrix Consulting Group addressed their preliminary report on the current San Juan fee schedule, which has not been revised since 2013, and recommended it be revised to more fully cover the cost of city services.
“The purpose of these studies,” she said, “is to determine what the true cost is to the city of providing these services. This is just really helping to set a ceiling of what the maximum justifiable fee is.”
Ingle broke down the city’s fees as follows.
- Community Benefit: services such as park maintenance and law enforcement, which benefit the entire community and are primarily funded by taxes.
- Mixed Benefit: services such as code compliance, which have both individual and community benefits and are funded by a mix of taxes, grants and user fees.
- Individualistic Benefit: services like building permits, planning applications, and facility rentals primarily benefit the individual applicant.
Ingle said she took a bottom-up approach to assess the “fully burdened rate,” which includes direct costs, such as salaries and benefits, employee productive hours, adjusted for vacations, sick leave and training; and indirect costs, such as services, supplies and support and citywide overhead, including the costs for the city manager, human resources, finance and the city clerk.
By multiplying the average staff time devoted to a specific permit or task by an average of the above assumptions, the study then determined the “full cost of the service.” Ingel explained that California Propositions 218 and 26 limit what a jurisdiction can charge for services, and anything beyond that “full cost” is considered a tax.
The process involved reviewing over 200 fee line items and creating many new fee schedules for services, such as engineering and planning, which had not been set uniformly. The study also recommends an annual fee escalator to ensure fees keep pace with costs.
Because it was a draft proposal, no decision was required by the council. However, the council members will review the study to suggest changes. Ingle said, “It is the council’s choice and decision whether to set these fees at these amounts or not. This is just really helping kind of set that ceiling of what that maximum justifiable fee is.”
The next steps will be a public hearing and final approval by the council. Following acceptance, the development-related fees will require a 60-day waiting period, while most other fees will take effect 10-30 days after passage.
Related documents
MNS Collection System Salt Study.pdf
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