New Subdivisions Could Be Allowed To Make Overdraft Worse

June 1, 2003

Supervisor Fernando Armenta, Chair
[Sent By Email and FAX: 831-755-5888]
Monterey County Board of Supervisors
240 Church Street
Salinas, CA 93901

RE: Proof of Water Supply and Water Quality

Board Meeting of June 3, 2003, Agenda Item #S-7

Dear Chairperson Armenta and Members of the Board:

LandWatch Monterey County strongly urges your Board to continue to require proof of water for new subdivisions according to current Title 19 requirements. This is policy option #1, as outlined in Attachment A to the report from the Director of Environmental Health that you are reviewing at your June 3, 2003 meeting.

We would like to highlight the following points:

1. As the materials before your Board make absolutely clear, North Monterey County is in a condition of critical groundwater overdraft. Every new or increased withdrawal from the aquifer directly harms existing water users.
   
   
2. Solutions to the current overdraft conditions can be found, and implemented, but they will be difficult to accomplish, and they are certainly not yet in place.
   
   
3. Abandoning the current Title 19 requirements prior to the implementation of a real solution to the current groundwater overdraft condition would be worse than negligent. The Board well understands that such a policy decision would be an intentional decision to promote new development at the expense of current water users.
   
   
4. A decision to allow new development to make the current groundwater overdraft situation worse would be unfair to current water users, including both residential users and farmers. In addition, such a decision would inflict known environmental damage.
   
   
5. 5. Current Title 19 standards reflect the extensive investigation and discussion carried out by this Board several years ago. Reversing a thoughtful and well founded decision, with no new evidence to justify that policy reversal, will convince the residents of Monterey County that this Board is not willing or able to make tough decisions and stick to them. Undermining the credibility of local government is not in the best interests of the citizens and residents of Monterey County.
   
   
6. Option #2 suggests that Monterey County should encourage the conversion of North County farmlands to residential subdivisions. This is a bad idea, both as a matter of water policy, and as a matter of general land use policy.
   
   
7. In a drought or water emergency, agricultural water uses can be temporarily suspended. That’s not possible for residential uses. Option #2, which will transform agricultural water uses into residential water uses, is a bad idea where water policy is concerned.
   
   
8. Increased residential development in the North County area, which would be stimulated by Option #2, will have extremely negative traffic, public service, and environmental impacts, and will put the future health of Elkhorn Slough at risk. Option #2 is a bad idea in terms of basic land use policy.
   
   
9. Option #3 suggests that the Board could “define away the problem,” by suddenly claiming that continued groundwater overdraft is “not a significant adverse impact.” Who do you think will be fooled by that? The groundwater overdraft problem is a real problem. It can’t be defined away.
   
   
10. Finally, as I am sure the Board realizes, any attempt to modify the current provisions of Title 19 will require full environmental analysis, according to the provisions of the California Environmental Quality Act.

The Monterey County Board of Supervisors has been honest, and courageous, in recognizing the consequences of the severe groundwater overdraft condition that exists in North Monterey County. Current Title 19 requirements for subdivisions reflect that courage and honesty.

Please don’t backtrack now!

cc: LandWatch Members
Other Interested Persons

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06.02.03