HomeMy WebLinkAbout07/19/1988, 8 - WATER ALLOCATION ORDINANCE u �
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COUNCI AGENDA REPORT '��"
FROM: Michael Multari, Community Development Director; BY: Glen Matteson, Assoc. Planner
SUBJECT: Water Allocation Ordinance
CAO RECOMMENDATION
1. Certify the environmental impact report (EIR) for the water allocation ordinance.
2. Introduce the attached water allocation ordinance, which would determine the
distribution of allowed water-use increases among proposed projects. -�
3. Either:
A. Amend the general plan Water and Wastewater Management Element to allow for an
additional increase in water use equivalent to one percent of safe yield (this
quantity would be deducted from water available for allocation as additional
yield is obtained); or
B. Do not amend the element to allow such an increase.
(Option A, allowing the increase, would help avoid a short-term moratorium while,
further work on obtaining groundwater is underway. Option B, not allowing the
increase, raises the likelihood of a short-term moratorium on the issuance of
building permits. However, even with the one-percent increase, a short-term
moratorium is possible depending'on the time needed to approve environmental review
and plans for production wells. The implications of these alternatives are discussed
in following sections. Also, note that option A was the recommendation of staff to
the Planning Commission, while option B is the recommendation of the Planning
Commission to the City Council.)
4. Amend the water element to:
A. Allow continuous rather than once-a-year accounting of new .supplies added;
B. Allow new supplies to be counted sooner during project development than under
current policies;
C. Create a special, one-time reserve for large, phased projects (such as
Edna-Islay) equal to two percent of current safe yield, in addition to any
increase allowed under 3.A above;
D. Exempt from the allocation regulations projects which make one-to-one rather
than two-to-one offsets in water use;
E. Separate Cal Poly's water use and supply figures when determining the city's
water use/supply conditions.
5. Keep the provisions requiring no more than one-half of any added supply to be
available to new development and no more than two percent increases in annual water
use --exclusive of the one-time allowance for large, phased projects-- so long as
water use exceeds safe yield.
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COUNCIL AGENDA REPORT
Water Regulations
Page 2
INTRODUCTION
Backeound
The council faces two fundamental questions. First, should development continue before
new water sources are obtained, bringing supplies and use into an acceptable balance?
Second, if some water is made available for development, how should it be divided among
those wanting to develop?
City water use exceeds safe yield of supplies, requiring water-use restrictions during
years with low rainfall. Over the next several years, new water supplies may not be
sufficient to keep pace with added demands due to development, worsening the imbalance
between use and supply. In February 1987 the City Council adopted the Water Management
Element of the general plan, setting maximum acceptable levels of risk in exceeding the
safe yield of water supplies and calling for a water allocation ordinance to limit demand
when supplies are short.
The Planning Commission and staff recommended a draft ordinance last spring. The council
first considered the draft ordinance in July and August 1987. Councilmembers suggested
several changes in response to public comment, and ordered an EIR to be prepared. The
EIR has been written and circulated for public comment. The council must consider the
EIR's analysis of significant issues which have been raised and certify that the EIR is
adequate before adopting the regulations.
Under the current water element policies, the present water situation would lead to a
moratorium on most new construction this summer. At its May 10 study session on this
topic, however, the council expressed interest in an option that would avoid or delay a
moratorium: allowing a one percent increment of development now, in anticipation of
groundwater wells producing supplemental supplies later this year. A general plan
amendment reflecting this option was drafted.
The Planning Commission considered the amendment June 29 and unanimously recommended
against it. Commissioners said the city should carry out its current policy to bring use
and supply back into balance sooner, considering the current reservoir conditions and
because of questions about the quantity, quality, and environmental impacts of using
groundwater.
Staff recommends that, considering previous council direction and the groundwater
information available now, some small increment of development (one to three percent) be
allowed. Staff also recommends that the allocation ordinance be adopted now, to
establish the mechanism for allocating water to limited new development until supply and
demand are again in balance.
Staff would note that allowing the one percent increase does not assure avoiding a
short-term moratorium. As this is written, about 11 acre-feet remain from the July 1987
through June 1988 water-use increase which is allowed under the current water-element
policies. Adding 74 acre-feet (an increase of one percent of current safe yield) would
result in 85 acre-feet. However, applications needing about 60 acre-feet of water are in
plan check. Subtracting water demands of projects in plan check leaves only 24 acre-feet
for new applications, which may be used up before the proposed ordinance could take
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effect in about six weeks. This amount is likely to be used quickly as people submit
plans, hoping to use any available water before the moratorium takes effect Therefore,
staff sees the question of allowing a one-percent increase as having little practical
effect.
The moratorium probably will not last long, but its duration depends on some unknowns:
how much groundwater is actually available to the city and how quickly environmental
review and construction plans for the production wells can be completed.
The likelihood and duration of a moratorium could be reduced by raising the allowable
general increase above one percent. Staff does not support this approach. Also, a
moratorium might be avoided by shifting some of the recommended set-aside for Edna-Islay
to the general category. Staff could support doing so, though the shift could put the
city in an uncomfortable position if groundwater is not available soon and if the
Edna-Islay developers, who have spent millions of dollars on facilities, pressure the
city for relief as their diminished reserve runs out.
Significant imuacts
The EIR discusses potentially significant environmental and fiscal impacts from a
construction slowdown or a moratorium lasting as long as ten years. City costs and
revenues would both decline slightly. Some environmental impacts due to growth pressures
probably will be reduced, while others will be displaced to locations outside the city
with fewer development limits.
If the city does not regulate increases in water demand and new supplies do not become
available soon, the community will experience significant water-service impacts. On
balance, it appears that the desire to protect public health, safety, and welfare by
having adequate water supply warrants some additional controls on demand, even if some
financial and other environmental impacts occur in the short term.
Consequences of not takingaction
If development-limiting regulations are not adopted and sufficient supplemental water
sources are not obtained, water use will continue to exceed safe yield of supplies. As a
result, people would face increasingly disruptive water-saving measures to avoid running
out of water during dry periods.
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COUNCIL AGENDA REPORT
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REPORT OUTLINE
Page
EVALUATION
A. Water Situation
1. Safe yield and use 5
2. Levels of service 6
3. Prospective additional supplies 6
B. Policy Background
1. Water Operations Plan 7
2. Water Element 7
3. Previous Regulations 7
4. Most recent council direction 7
C. Policy Choices (Alternatives)
1. Water relationships
a. Amount of increase 8
b. Definiteness of new sources 10
c. Timing of evaluations 10
d. Duration of regulations 11
2. Allocation priorities and procedures (Alternatives)
a. Categories or contests 11
b. Exemptions 12
c. Eligibility & cut-off point 13
D. Environmental impact report 14
CITIZEN PARTICIPATION
A. Planning Commission recommendation 14
B. Testimony at Planning Commission 15
C. Previous testimony before council 15
OTHER DEPARTMENT COMMENTS 15
ALTERNATIVE ACTIONS 15
RECOMMENDATION 16
ATTACHMENTS
A. Draft ordinance adopting Water Allocation Regulations with synopsis
B. Draft resolution amending the Water and Wastewater Management Element
C. Initial environmental study for element amendment
D. Errata, comments, and responses for EIR (EIR distributed previously)
E. Draft Planning Commission minutes 6-29-88 (forthcoming)
F. List of potential, additional water-saving features for new development
G. Correspondence
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EVALUATION
Water Situation
1. Safe yield and use
Safe annual yield is the amount of water the city can draw from its reservoirs year after
year and still have sufficient water during a drought like the worst one experienced
since rainfall records have been kept. Safe yield is based on reservoir and watershed
characteristics and long-term weather data; it does not change substantially from year to
year, unless sources are gained or lost (though there is a gradual reduction due to silt
filling the reservoirs). The amount of water in the reservoirs, which depends on
relatively short-term weather conditions and water use, does change substantially during
each year and from one year to another.
City water use exceeded safe yield in 1984. Water use peaked at nearly 16 percent above
safe yield in early 1987 (13 percent if Cal Poly use and yield are included), and is now
about nine percent above safe yield (six percent with Cal Poly). The improvement
relative to last year is due to increased yield from "cooperative use" of the two
reservoirs and, apparently, reduced consumption resulting from conservation programs.
Here is a summary (all numbers are in acre-feet per year):
(City with Cal Poly City only
Safe yield, May 1, 1988: 8,180 7,357
Measured water use in
year ending May 1, 1988: 8,710 (a) 8,042 (a)
Projected water use in
year ending June 30, 1989:
(base demand) 8,830 (b) 8,162 (b)
(use with 25% drought-
response conservation) 6,223 6,122
(a) Sales of city-entitlement water to Cuesta College included.
(b) May 1988 use plus 60 AFY due to projects receiving permits 1/88 thru 6/88, and
60 AFY due to projects in plan check 6-30-88. This calculation assumes no new
supply and no allocations to projects beyonds those approved, but not built, or
in plan check.
Staff estimates that in the last four years, the annual increase in demand for water due
to additional development has averaged about three percent per year; it will be just
under two percent this year. We expect annual increases in base demand of about two
percent during the next several years if the city sets no limits. Actual water use may
vary from these projections due to water-use restrictions imposed in response to drought
conditions.
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2. Levels of service
The Water and Wastewater Management Element (pages 15 and 16, and Appendix B) explains
how often, how much, and how long city residents and businesses would have to cut back
from normal water use to avoid running out of water when normal use exceeds safe yield by
various amounts. According to the Annual Water Operations plan adopted by the council in
May, the city water supply is in a "moderate" shortage condition and is moving quickly
toward a "severe" condition, requiring 25 percent reductions from normal use.this year
and possibly 40 percent next year.
3. Prospective additional supplies
In recent years, no substantial new sources have been obtained, though several sources
with time frames of a few months to seven years are under development or consideration.
Generally, the potential sources with the larger yields would be available farther in the
future.
The supplemental source most likely to be.available within one year is groundwater. The
city has completed the first phase of a groundwater study, which concluded that as much
as 1,500 acre-feet may be available in the San Luis Obispo area. So far in the second
phase of the study, nine test borings and one test well have been completed. Three
borings encountered shallow bedrock. Only the test well at the city corporation yard has
shown potential for added yield at this time. If water quality proves satisfactory, that
well could increase city supplies by about 200 AFY. In order to make this potential
source available, the city must complete environmental review, approve plans and
specifications for a production well and a connection to the city water system, and then
install the well, pipelines, and any required treatment facilities.
Other test wells may be completed within the next several weeks. Depending on the
results at individual sites, and whether the council wishes to proceed with individual
wells or a group of well projects, there may be a gap of up to several months between the
effective date of the recommended ordinance and when additional yield will be available
for allocation.
This situation means that if an additional increment in water use is not allowed now,
limits on issuance of building permits may begin in late August or early September and
last until environmental review and construction plans for production wells are
complete. However, even with an additional increment in allowed water use, some limit on
building-permit issuance is possible, depending on how many permit applications are
submitted and how long it takes to finalize plans for the new wells.
Policy background
1. Water Operations Plan
The Water Operations Plan includes a moratorium as one potential means of dealing with
"moderate," "severe," and "critical" water shortages.
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COUNCIL AGENDA REPORT
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2. Water element
Last year the City Council adopted the Water Management Element of the general plan.
This element outlines the city's efforts to obtain additional water supplies and to use
water more efficiently. It also sets acceptable levels of risk in exceeding the safe
yield of water supplies. The element calls for specific regulations to eventually bring
water use and supply back into balance, by controlling increases in water demand from new
development. The regulations were to have been in effect July 1987. The adopted
policies limited the increase in water use from July 1987 through June 1988 to 149
acre-feet per year (AFY). Of this allowed increase, 138 AFY have been used by projects
receiving building permits during that time. Under the adopted policies, no water will
be available for nonresidential projects until at least July 1989, when a portion of the
added yield from any successful new wells could be allocated. At the end of June, 11 AFY
remained for residential projects.
The allocation ordinance is one component in a larger plan to get out of the current
water bind and avoid similar situations in the future. All three components --obtaining
additional supplies, conservation in existing development, and managing new development--
are likely to be needed. While attention has focused on a "yes/no" decision on a
moratorium, the ordinance would actually translate general plan policies into a specific
amount of water available to development and how it would be allocated, with increases in
water use ranging from none to two percent --nearly as much as recently experienced--
depending on the water supply/demand situation.
3. Previous draft regulations
The Planning Commission and staff have previously recommended a draft ordinance. A copy
was included as an appendix of the EIR.
4. Most recent council direction
In May the council held a study session and discussed policy alternatives intended to
avoid a moratorium, in anticipation of obtaining groundwater. The policy changes
discussed included:
a. Counting new sources toward total city supply before they actually produce
water, if they appeared to be assured. (The recommended amendment would do this.)
b. Continuous rather than once-a-year accounting for use and supply changes. (The
recommended amendment would so this.)
C. Allowing an increment of water use beyond the current limit now, before
colleting environmental review and construction plans for production wells. (Doing
this may be necessary to avoid a moratorium this summer, unless items "a" and "b"
above are adopted and plans for production wells are approved within the next six
weeks or so. If the council favors a special reserve for large, phased projects
(Edna-Islay) separate from any allowed water-use increases in the rest of the city,
that special reserve would become an increment of use beyond the current limit, even
if no additional supply is obtained.)
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Nis COUNCIL AGENDA REPORT
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The council also expressed support for:
d. A simpler approach to determining allowed water-use increases, in comparison
with the current illustration in the Water and Wastewater Management Element. (The
recommended amendment would do this.)
e. Additional incentives for water conservation in projects wanting water
allocations. (See item "c" on page 13 for further discussion of this issue.)
f. Granting water allocations more on the basis of a project's merits and less on
the order in which applications are received. (Staff would prefer that this be
accomplished by revising the recommended categories of projects and the relative
amounts of water available for each, rather than saving up batches of applications
for competitive rankings.)
In last year's study sessions, the council supported these features, previously
recommended by the Planning Commission:
g. Special consideration for projects which are part of large, phased developments
that have made subtantial commitments to public facilities in anticipation of
development, once referred to as "pipeline projects". (The recommended ordinance
addresses this concern by creating a special reserve for such projects, along with
tenant occupation of and use changes in existing buildings, in addition to the amount
available elsewhere in the city. An alternative would be to create a category within
the amount available citywide.)
h. Not allowing any one project to use the whole amount of water available for
allocation. (The ordinance includes staff's recommendation that a project could get
more than 50 percent of the available water in its category only with special council
approval.)
Policy Choices
1. Water relationships
a. Amount of increase.
In staff's view, the main issue to be decided is: How much, if any, should water use
be allowed to increase, until new supplies allow safe yield to at least.equal normal
water use levels?
Existing policies were adopted when water use was about ten percent above safe yield
(including city and Cal Poly use and supply). Use was expected to reach 13 percent
above safe yield within a year, the maximum level determined acceptable by the
council at that time, as a one-time response to avoid a moratorium. That upper limit
was adopted with the understanding that the city would follow a definite formula in
regaining a use-supply balance as additional sources were obtained. Following that
formula leads to a moratorium this summer. The Planning Commission recommends that
the formula be followed.
city of san tuis oBispo
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COUNCIL AGENDA REPORT
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Current policies allow only one-half of any new supplies to be used for development;
the other half must be credited to bringing use and supply back into balance.
Therefore, if the corporation yard well yields 200 AFY, under this approach, 100 AFY
would be available for allocation to development --about 1.4 percent of the city's
current safe yield. Considering the intent of the current policies and the actual
water situation, staff thinks water use should not increase by more than two percent
per year until base demand is again below safe yield. If the city wants to have a
larger "safety margin," smaller or no increases would be appropriate: more than
one-half of added yield would be credited to regaining a balance, and less would be
available for allocation to development.
For example, instead of one-half being available for development, only one-third
might be used for this purpose, with two-thirds going towards reducing the supply
"deficit." In the case of the corporation-yard well, then, 67 AFY would be available
for development, with 133 AFY held in reserve.
To balance use and safe yield, the city would have to obtain 1,610 AFY additional
yield, assuming that one-half of additional supply goes to development and one-half
to achieving a closer balance.* Due to the distribution of groundwater, obtaining
the full 1,500 acre feet which may be available from groundwater without also
accepting additional customers (demand) may be difficult.
As noted above, the Water and Wastewater Management Element contains an assessment of
service impacts (water-use reductions needed) due to exceeding safe yield by various
amounts for various durations. That assessment indicates that the proposed
stretching of available supplies would not significantly impair the city's ability to
provide water during a drought, if additional supplies are developed within the next
year. However, avoiding a development moratorium may hinder obtaining broad and
lasting public support for water savings. People will be less inclined to reduce
water use if they believe the savings are simply cancelled by allowing additional
development. (The recent general plan opinion survey found that 85% of respondents
supported "keep growth within available resources" as an approach to determining
allowable growth in the city, while by far the item most frequently mentioned as San
Luis Obispo's greatest problem was excessive growth.)
Also, staff expects that citizens will question why anticipated groundwater supplies
could be judged adequate for additional development but not sufficient to avoid the
requested water-use reductions. As we have discussed before, the choices the city
faces are judgements about acceptable levels of service and of risks, and how the
burdens of dealing with limited water supplies should be shared by those advocating
development and by water users generally. Also, the 25 percent reduction is dictated
by immediate reservoir conditions and needed conservation levels if we are to have
water after another year or two of dry weather. Groundwater sources probably cannot
be added quickly enough to avoid the need for substantial, short-term water savings.
.... .. ... ... . . ... .. ..... ..... ..... ..... ..... ..... ... .. ... .. .. ... ... .. ........ . . .. . .. ...
' May 1988 city water use plus use due to projects recently approved or in plan check,
minus current safe annual yield, times two: [(8,042 + 60 + 60) - 7,357] X 2 = 1,610.
Use and safe yield would balance at 8,967 AFY.
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COUNCIL AGENDA REPORT
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However, it is true that reductions from normal water use needed now would not be so
large if demand did not exceed safe yield, through limited development or other
means.
To accurately determine the allowed water use increases considering the city's use
and entitlement, Cal Poly's use and entitlement should be excluded. The attached
amendment exhibit reflects staff's recommendation that this be done.
Here is a recap of the likely worst case conditions under the recommended policy
amendments and proposed allocation ordinance, and assuming the corporation yard well
adds 200 AFY to city supplies (all figures are in acre-feet per year):
May 1988 Added June 198
Safe yield 7,357 one well: 200 7,557
Use 8,042 1/2 well yield: 100 8,343
recent permits: 60 (w/ 2% limit,
pending permits: 60 151 max.)
Edna-Islay res: 150
Ratio use/yield 1.093 1.104'
• If the corporation yard well cannot be added for some reason, the ratio of use
to safe yield would reach a worst-case peak of 1.12 to 1.13, depending on the
projects which enter plan check before the regulations takes effect.
b. Definiteness of new sources
Under existing policies, sources cannot be counted toward supply unless they are
actually providing water (or, by interpretation, capable of providing water
immediately) when the evaluation is conducted. Under the proposed amendment, a new
source could be counted if environmental review had been completed, the City Council
had approved construction documents, and the source could actually deliver water
within one year. (As this agenda report is prepared, for example, the added yield
from the corporation yard well could not be counted because environmental review has
been done for a test well only --not a production well-- and plans and specifications
for connection to the city water system have not been approved.)
C. Timing of water evaluations
Existing policies require an annual determination in May of the amount of water
available for development, coinciding with consideration of the Water Operations
Plan. The proposed change would allow a continuous accounting of additional water
obtained, available, and allocated. This change is intended to keep the city moving
toward a closer balance between water use and supply, a primary goal of the Water and
Wastewater Management Element, while minimizing delays for those proposing
developments.
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FC?UNCIL AGENDA REPORT
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d. Duration of regulations
At the previous council meeting, a speaker said the regulations should include a
"sunset clause," so that if the city does not obtain additional supplies by a certain
date, the regulations would automatically be repealed. Staff cannot support such a
provision because it would cancel the regulations when they are most needed.
2. Allocation procedures and priorities
a. Categories or contests
In most allocation systems, preference is given to certain favored uses. For
example, low-income housing is frequently given some preference over market-rate
proposals. Basically, there are two ways to favor certain uses:
(1) The uses can be divided into categories with set-asides for favored categories
(such as a reserve for affordable housing). Within each category, applications
may proceed on a first-come, first-served basis. This approach was used in the
original draft ordinance and was recommended by staff and the Planning
Commission. Advantages of this approach are administrative simplicity and
minimum delay for projects in the favored categories. A disadvantage is that if
no project is proposed in a certain category, the reserve in that category
cannot be made available to other projects, unless there is a periodic
reassignment of the unused reserve.
Staff still strongly recommends this approach.
(2) Alternatively, water could be allocated based on ranking, with points awarded
for certain preferred characteristics in competing projects. The current
Residential Growth Management Regulations use this approach; projects are held
each calendar quarter and, if there are more requests than allowed units, the
projects are ranked according to how many points they earn for various features,
such as affordability, location, energy savings, public improvements, and so on.
A disadvantage of this approach is that, when competition is high,
administration can become difficult, with pressures for subjectivity in the
ranking process. Also, there are delays while projects are being "batched" and
ranked.
A related question: How much water, if any, should be reserved for special
categories of projects, such as large phased developments, beyond that available to
the city generally? (So far, only the Edna-Islay area appears to qualify under this
provision.) In response to previous council and commission direction, staff
recommends a special reserve amount of one to two percent of current safe yield --say
75 to 150 AFY-- for large, phased projects which have made substantial commitments to
public facilities in anticipation of development.
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This special reserve would be shared with applications for changes of use in existing
buildings, expected to be an insignificant amount. The special reserve would be
available to separate developers in the large-project areas and to new tenants of
existing building on a first-come, first-served basis. Under staff's recommended
ordinance, eligible projects would have to use this reserve before using or getting
in line to use the general reserve, and once this reserve is used, such projects
would be eligible only for the citywide categories in which they fit. However, the
allocation of the special reserve would not be subject to the two-percent annual
limit on water-use for development elsewhere in the city. Alternatives to staff's
suggested approach include:
(1) Have the special reserve, but make the projects subject to the two-percent
annual limit on increases citywide;
(2) Create a category for such projects within the citywide limit, which would
remain available so long as it was needed;
(3) Assign larger or smaller amounts to the special reserve (or category within
the citywide limit. One percent of current safe yield (about 74 AFY)
translates into about 200 typical single-family houses, more if significant
reductions in potable water use were made. About 400 dwellings could be
built under remaining phases of the Edna-Islay Specific Plan.
Staff has discussed but is not recommending subcategories within the nonresidential
category, to distinguish between downtown (C-C zone) projects and those outside the
downtown. In staff's view, this distinction has some merit, based on the
general-plan preference for downtown retailing and offices. If the council wants to
favor downtown projects by this means, staff would suggest reserving one-quarter to
one-half of the nonresidential amount for C-C zone projects.
b. Exemptions
The council has previously discussed exempting affordable housing projects,
government projects, and individually built houses in existing subdivisions. Staff
recommends that the regulations exempt only (1) government projects, many of which
the city cannot control anyway and which make up a very small part of expected
additional demand, and (2) those projects which will not increase water use. Other
exemptions simply make it harder to be equitable and would defeat the purpose of the
regulations.
The current policy allows projects providing their their own acceptable water supply
and those making offsetting reductions in other buildings of facilities to proceed
independently from the regulations. However, a project would have to save two AFY
elsewhere for each one AFY it would use. The proposed amendment would allow projects
with one-to-one offsets to proceed.
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C. Eligibility and cut-off point
At the last study session, the council favored requiring projects to include more
than the current minimum conservation features in order to be eligible for
allocations within their categories. Staff favors simply raising the standards for
all new construction. The draft ordinance includes a provision that would allow
requirements beyond minimum, citywide standards to be imposed by the council through
separate ordinance or resolution. The attached list includes some potential
measures; staff has not evaluated their cost-effectiveness, and suggests that action
on such measures be taken separately from consideration of the water policy
amendments and water allocation ordinance, perhaps before the allocation ordinance
takes effect.
Staff is often asked at what point in project approval a development could proceed
without being subject to the regulations. Options include:
(1) When all discretionary (planning) approvals have been granted, but not
neccessarily after a building-permit application has been submitted. This is
the most encompassing approach. It would amount to a broad exemption, probably
allowing several hundred acre-feet of water use.
(2) When a complete building-permit application has been accepted by the city's
Building Division. Currently, this would include about 90 applications
representing roughly 60 AFY of water demand.' Staff recommends this approach,
out of consideration for those who have submitted plans and to put the time
burden on future applicants rather than Building Division staff. (Under the
draft ordinance, water needed for projects in plan check would be subtracted
from water available for allocation to later applicants. This approach would
reduce the capacity of the one-percent increase to avoid a moratorium, but it
would also help the city keep control of water-demand increases pending the
ordinance taking effect.)
(3) When a building permit has been issued.
Environmental Imnact Report
The draft EIR looks primarily at how the proposed regulations would influence the amount
and distribution of development in the county as a whole. The EIR evaluated various
combinations of water availability and approaches to regulating development. It
concludes that the proposed regulations will have no significant impacts. It says the
impacts which would occur follow from the water situation, not from the mechanisms for
allocating available water. It points to more aggressive conservation programs and
obtaining additional water sources as mitigation measures.
.... .. ... .... . .... . .. .. . ..... ... .. .. ........ .. ........ .... . ... .. .. .. . .. . .. .. ... ..... .... .
" 250 applications were in plan check at the end of June, including 90 permits which
would be subject to the regulations (43 houses, 55 residential condominiums, 47
apartments; 5 office, 15 industrial, and 3 retail buildings; 72 motel rooms).
C
����►�► ►��IIIII����� ►�����I� City of san Luis oBispo
GOtojNCIL AGENDA REPORT
Staff and the environmental consultants have compiled comments received and have prepared
responses (attached). Some of the comments (primarily from Clinton Milne) concern issues
of water rights or other matters not directly related to environmental impacts, so staff
will respond to them separately.
In staff's view, the most important environmental issue raised was this: Will there be
significant impacts if the proposed mitigation (additional water supplies and
conservation) are not carried out, and how can the mitigation be required as part of
adopting the regulations? As discussed in the EIR and responses to comments, the
significanse of the impacts is largely a matter of judgment and perspective. Assuming
that there would be some significant impacts if the city did not obtain additional water
rapidly enough to sustain recent levels of development, staff believes the city is still
justified in adopting the regulations upon finding that there is an "overriding
concern." This finding is required under state environmental rules if the city chooses
to approve a project having impacts that will not be mitigated to insignificant levels.
Specifically, staff believes that there is an overriding public health, safety, and
welfare concern that the city would not be able to provide an acceptable level of water
service, particularly during droughts, if water demand continues to grow faster than
supply.
CITIZEN PARTICIPATION
Planning Commission recommendation
At its June 29 hearing, the Planning Commission voted seven to zero to deny the general
plan amendment to allow an increase,in water use of one percent to three percent before
additional supplies are actually available. Commissioners stated these concerns in
denying the change:
1. The approach of setting resource thresholds and then changing them when they are
reached undermines the city's credibility and its apparent commitment to regaining a
balance between water use and supply.
2. Considering that the city is approaching a "severe" water supply situation due to
current reservoir levels, and that the situation may worsen due to factors beyond the
city's control (weather and Cal Poly enrollment increases), it would not be prudent
to loosen the adopted policy.
3. Progress toward meeting the desired conservation levels has not been demonstrated.
Achieving the desired conservation levels will be difficult if residents believe that
water savings beyond efficiency improvements are cancelled by additional water demand
from new development.
4. Studies and experience have not demonstrated that groundwater will solve the city's
water-supply problem. Reliance on groundwater may lead to reduced water quality and
to overdrafting the water basin, with resulting harm to creeks, lake, and marsh.
�►►Ni���ulllllllllll ��UJlI city of San tuts OBISpo
Ni& COUNCIL AGENDA REPORT
Page 15
On a separate, unanimously approved motion, the commission recommended that the council:
1. Have use balance with safe yield as soon as possible. (This implies a change from
current policies, but in the opposite direction from that outlined in the proposed
amendment: the total of any added safe yield would be allocated to achieving a
closer balance, until the balance is reached; only afterward would added yield be
available to new development.)
2. Not rely on groundwater as a permanent source of potable supply until more is known
about water quality, when overdrafting would occur, and what the results of
overdrafting would be.
3. Try to develop a respect for the city's resource limits among state-level officials
deciding on Cal Poly enrollment levels.
The commission also suggested that part of the proposed amendment be clarified if it was
to be adopted. (Staff has done so.)
Testimony ajt, Planning Commission
One citizen spoke at the hearing, urging the city to regain a balance between use and
safe yield as soon as possible. He also disputed the practice of including Cal Poly's
entitlement and use figures in the city's evaluation of water conditions, since currently
that approach makes the situation appear less serious.
Previous testimony before council
Over the last 18 months, the council has received extensive testimony and correspondence
representing widely different viewpoints on water issues. The meetings have been well
attended by those most immediately affected by a development slowdown, who generally have
advocated getting as much water as possible as soon as possible and aiming for additional
conservation, to avoid a moratorium.
OTHER DEPARTMENT COMNIENTS
The basic features of the Water and Wastewater Management Element, previously drafted
regulations, and proposed changes resulted from cooperative efforts of planning, public
works, and administrative staff. The city attorney has reviewed the draft regulations.
ALTERNATIVES
To recap the action alternatives available, the council may:
A. Continue action. Council should identify any additional information or changes
desired.
B. Keep the present policies on water use and supply relationships and introduce an
ordinance to carry them out.
'�11111$10111 1111111 city of San LUIS OBISp0
lam
COUNCIL AGENDA REPORT
Water Regulations
Page 16
C. Change the policies on water use and supply and introduce an ordinance to carry them
out. The changed policies could be either more strict in achieving a balance between
use and supply, as the Planning Commission recommends, or more lenient, as staff
recommended to the Planning Commission. If the policies are to be more lenient, the
additional flexibility could be achieved by allowing an increment of development
regardless of actual added yield, accelerating the accounting for added yield, or
both. These options were discussed in detail above.
RECOMNENDATION
I. Certify the environmental impact report (EIR) for the water allocation ordinance.
(Introducing the attached ordinance will do so.)
2. Introduce in summary form the attached water allocation ordinance, which would
determine the distribution of allowed water-use increases among proposed projects,
with a special reserve for large, phased projects. Determine whether the recommended
amounts of water-use increase and of reserves for categories of projects, as
indicated by brackets [] in the draft regulations, are appropriate.
3. Either:
A. Amend the general plan Water and Wastewater Management Element to allow for an
additional increase in water use equivalent to one percent of safe yield, to be
deducted from water available for allocation as additonal yield is obtained; or
B. Do not amend the element to allow such an increase.
4. Amend the water element to:
A. Allow continuous rather than once-a-year accounting of new supplies added;
B. Allow new supplies to be counted when environmental review and engineering
design are complete and they can deliver water within one year, rather than when
they are actually capable of providing water;
C. Create a special, one-time reserve for large, phased projects (Edna-Islay) equal
to two percent of current safe yield, in addition to any increase allowed under
2.A above;
D. Exempt from the allocation regulations projects which make one-to-one rather
than two-to-one offsets in water use;
E. Separate Cal Poly's water use and supply figures when determining the city's
water use/supply conditions.
5. Keep the provisions requiring no more than one-half of any added supply to be
available to new development and no more than two percent increases in annual water
use --exclusive of the one-time allowance for large, phased projects-- so long as
water use exceeds safe yield.
►►��►��►��IIIIIII�p ��lU city of San tins OBlspo
INIGe COUNCIL AGENDA REPORT
Water Regulations
Page 17
If the council favors the Planning Commission's recommendation, it would not adopt the
resolution but it would introduce the ordinance without the bracketed [] statements and
amounts in Section 17.89.050.A and without Sections 17.89.050.B and 17.89.060.D, which
allow an increase in water use beyond current policies and which create a special reserve
category for large projects.
ATTACHMENTS
A. Draft ordinance adopting Water Allocation Regulations, with synopsis
B. Draft resolution amending the Water and Wastewater Management Element
C. Initial environmental study for element amendment
D. Errata, comments, and responses for EIR (EIR distributed previously)
E. Draft Planning Commission minutes 6-29-88 (forthcoming)
F. List of potential, additional water-saving features for new development
G. Correspondence
gm4/ccregrep
U � �
ORDINANCE NO. (1988 Series)
AN ORDINANCE OF THE CITY OF SAN LUIS OBISPO
ADOPTING WATER ALLOCATION REGULATIONS
BE IT ORDAINED by the Council of the City of San Luis Obispo as follows:
SECTION 1. Findines The Council makes the following findings.
1. This city is taking steps to obtain additional water sources, to conserve water, and
to manage growth of water demand by means other than these regulations. However,
water demands have increased faster than supplies. In the future, total water
supplies may not be sufficient to meet demands from all potential development.
2. The council has adopted a Water and Wastewater Management Element of the general
plan, to guide the conservation, use, and development of water supplies, consistent
with goals of the general plan. These regulations are consistent with the general
plan.
3. The Council has evaluated existing and potential water sources and water demands, and
the environmental, economic, and ppblic-service impacts of exceeding the safe annual
yield of available supplies by various levels. The Council has determined that these
regulations are necessary to protect the public health, safety, and general welfare.
Specifically, these regulations are necessary to assure that increased water use due
to additional land development will not jeopardize adequate water service to both
existing users and new users. These regulations are needed to assure minimum
acceptable amounts of water for fire protection, personal consumption and sanitation,
the operations of businesses, industries, and public services, and landscape
irrigation.
4. The city has prepared and the Council has considered an environmental impact report
(EIR), including comments and responses, in accordance with the California
Environmental Quality Act and state and city environmental impact procedures and
guidelines. The EIR observes that impacts on distribution of development actually
result from the water situation rather than the regulations, which are a mechanism
for allocating available water. Further, the EIR concludes that all potentially
significant adverse impacts of the regulations can be mitigated to acceptable levels.
SECTION 2. Environmental determination.
1. The council hereby certifies that the Environmental Impact Report, including
comments and responses, on the Draft Water Allocation Regulations is adequate.
2. The council further determines that potentially significant impacts of growth
displacement can be avoided or mitigated by conserving water and obtaining
additional water supplies.
3. However, if the proposed mitigation cannot be carried out as anticipated, there
exists an overriding concern to provide adequate water service which justifies
adoption of the regulations despite other potentially significant impacts.
Ordinance No. . . .... ..... (1988 Series)
If the city experiences uncontrolled development during times of drought,
without the regulations the city would not be able to provide minimum acceptable
amounts of water for fire protection, personal consumption and sanitation, the
operations of businesses, industries, and public services, and landscape
irrigation, thereby jeopardizing public health and safety and community
welfare..
SECTION 3. Adoption. Chapter 17.89, Water Allocation Regulations, fully contained
in the attached Exhibit A and included herein by this reference, is added to the
Municipal Code.
SECTION 4. Publication and effective date. A summary of this ordinance, approved by
the City Attorney, together with the names of councilmembers voting for and against,
shall be published once, at least three (3) days prior to its final passage, in the
Telegram-Tribune, a newspaper published and circulated in this city. A copy of the full
text of this ordinance shall be on file in the office of the City Clerk on and after the
date following introduction and passage to print and the copy shall be available to any
interested member of the public. This ordinance shall go into effect thirty days after
final passage.
INTRODUCED AND PASSED TO PRINT in summary form by the Council of the City of Sa.
Obispo, at its meeting held on the . day of . . .. .. . ... .
1988, on motion of . . . . ... _
. . . ..... ..... . , seconded
by . . .. . . . .... . .. ... .. ........ ..... ... .. . and on the following roll call vote:
AYES:
NOES:
ABSENT:
.. .. . .. ... . . .. .. . ... . ... . .. . ... . .. . . .
Mayor
ATTEST:
. . .. ... .. .. . . . .. ... .. ... . . . . ... .
City Clerk
8-�y
Ordinance.. No.. (1988 Series)
APPROVED:
City Att ---eY .
..... ..... ..... ....... .. ... ...... .... -
Community Development Director
Utilities Manager
City Administrative Officer .
EXHIBIT A
WATER ALLOCATION REGULATIONS
Sections:
17.89.010 Purpose.
17.89.020 Definitions.
17.89.030 Requirement for water allocations.
17.89.040 Eligibility for water allocations.
17.89.050 Allowed water-use increases.
17.89.060 Procedures for assigning water allocations.
17.89.070 Administration.
17.89.080 Fees.
17.89.090 Enforcement; Penalties.
17.89.100 Extension of planning and building approvals.
17.89.010 Purpose.
These regulations are to ensure that increased water use due to additional development
and changes in the use of land and buildings will not jeopardize adequate water service
to both existing users and new users. They are to help the city regain and then maintain
a balance between water use and reliable levels of supply, so the city can provide
adequate water service, consistent with the goals and policies of the general plan.
17.89.020 Definitions.
As used in this chapter, the following terms shall have the indicated meanings:
A. "Affordable residential development" means a development having at least twenty-five
percent of total dwellings affordable to low-income or moderate-income residents, as
provided in Chapter 17.90 of this Code.
B. "City water use" means the amount of water, from all sources to which the city is
entitled, drawn annually for use by the agencies and customers which the city
serves. It shall include sales of untreated water to Cuesta College, but not
transfers of treated water to California Polytechnic State University. The
determination of city water use shall employ estimates updated from a base year or
years, to avoid incorporating extreme fluctuations in measured water use due to
short-term weather or economic conditions.
C. "Government development" means the construction of a building or other facility
serving a public function and owned by a government agency, such as the city, the
county, the state, the federal government, or a public school district. "Government
development" does not include governmentally assisted private development or private
development in partnership with or on land purchased or leased from a government
agency.
D. "Residential development" means a development containing dwellings or group living
quarters, including manufactured housing or mobile homes, convalescent hospitals and
intermediate-care facilities, and emergency or temporary shelters. "Residential
development" does not include hotels, motels, hospitals, or recreational camps.
a`/
Ordinance No.
Exhibit A
Page 2
E. "Safe annual yield" means the amount of water which the city is entitled to and which
can be withdrawn from reservoirs or groundwater sources annually, without depleting
the reservoirs or overdrafting the groundwater basin, as determined by the city
Utilities Manager according to the principles of hydrology and the best available
long-term weather and recharge data.
17.89.030 Requirement for water allocations.
A. A water allocation shall be required for all actions within the city which would
increase water use, except as provided in part B of this section or elsewhere in this
chapter. A water allocation shall be required to: obtain a connection to the city
water system for a structure or facility not previously connected; change the use of
land or buildings, whether or not a construction permit is also required; obtain a
construction permit.
B. A water allocation shall not be required for the following:
(1) Building or enlarging a garage, storage shed, or other accessory structure which
would not increase water use, as determined by the Community Development
Director;
(2) Modifying or enlarging any building, provided that the modification or
enlargement does not:
(a) Create a greater number of dwellings;
(b) Increase the occupant capacity of any group-quarters or congregate
residential facility;
(c) Create additional hotel or motel units;
(d) Increase the floor area of a nonresidential building by fifty percent (50%)
or one-thousand (1,000) square feet, whichever is greater.
(3) Building a new structure or facility which replaces a structure or facility
having substantially the'same type of use and size, or equal or less water use,
as determined by the Community Development Director.
(4) Building a new structure or facility which is provided with its own water supply
which is approved by the city.
(5) Building a new structure or facility which (a) through retrofit of permanent
water-saving devices reduce use of city water in existing structures or
facilities by an amount at least equal to the estimated water use of the
proposed development, as determined by the Community Development Director, or
(b) funds the capital and any excess operating costs to provide permanent
sources of non-potable water to replace city water sources in existing
facilities.
Ordinance No.
Exhibit A
Page 3
(6) Carrying out a government development (though the expected use of city water by
government developments shall be included at the time of construction when
determining the cumulative total of assigned, nonresidential water allocations).
C. These regulations shall remain in effect only so long as city water use exceeds the
city's safe annual yield.
D. Any other provision of these regulations notwithstanding, a project for which a
complete construction-permit application was received by the city prior to the
effective date of these regulations shall be allowed to proceed whether or not an
allocation under this chapter is provided.
17.89.040 Eligibility for water allocation.
Water allocations shall be assigned to specific construction permits or requests to
connect specific structures or facilities. A structure or facility shall be eligible for
a water allocation only when each of the following has occurred:
A. All required city discretionary approvals have been obtained.
B. A complete construction permit application, request for connection, or other
applicable request for entitlement has been received by the Community Development
Department.
C. Construction plans, or the structure or facility to be connected, include all
applicable water-saving features required by this code when the allocation is
requested plus any additional features required by ordinance or resolution of the
council.
17.89.050 Allowed water-use increases.
A. General reserve categories
The following general reserve categories are created: general residential, affordable
residential, nonresidential (see Section 17.89.020 for definitions).
(1) Initial reserve amounts: Upon July 1, 1988, the reserves shall have the
following amounts.
(a) Residential development, exclusive of part 2 below: 18 [plus 42]
acre-feet].
(b) Affordable residential development .3 [plus 7] acre-feet.
(c) Nonresidential development: [25] minus 10 acre-feet.
Ordinance No.
Exhibit A
Page 4
(2) Deletions from these reserves shall be made as follows:
(a) Upon the effective date of these regulations, the amount of any allocations
for developments which obtain construction permits after July 1, 1988, and
before the effective date of these regulations.
(b) Whenever an allocation is made after the effective date of these
regulations.
(3) Additions to these reserves shall be made as increases in safe annual yield are
obtained, according to the following factors times one-half the added safe yield
(,provided, however, that the first increments equal to the quantities in
brackets in part A.1 above must be withheld]
(a) Residential.- .56;
(b) Affordable residential: .10;
(c) Nonresidential: .34.
Additions may also be made pursuant to Section 17.89.060.C.
B. Special reserve category
Upon the effective date of these regulations there shall be available 150 acre-feet for
allocation to tenant improvements and changes of use, within buildings under construction
or completed before the effective date of these regulations, and applications within
large, phased developments which have made substantial committments to public facilities,
as designated by resolution of the council. No additions to this reserve shall be made.
So long as sufficient amount remains in this category, projects in this category shall
use only this reserve. Once this reserve is completely allocated, projects shall be
eligible only for the general categories of reserves.
C. Any allocation forfeited pursuant to subsection 17.89.060.G shall be added to the
reserve for the corresponding category.
D. The safe yield of a new source shall be added to the reserves only when all of the
following have occurred with respect to the project which would actually deliver
water from the source to the city water system:
(1) Environmental review has been completed;
(2) The Council has approved plans and specifications;
(3) The city Utilities Manager determines that the source is expected to deliver the
yield to be counted within one year.
8'a 41/
Ordinance No.
Exhibit A
Page 5
17.89.060 Procedure for assigning water allocations.
A. Water shall be allocated from the appropriate available reserves, in the order
complete construction-permit applications are received, until the next eligible
application would deplete the appropriate reserve category. Applications shall then
be held, with assignment of any future reserve amount in the order complete
construction permit applications have been received.
B. Total water allocations from the general categories of reserves shall not exceed a
two percent increase in the then-current safe annual yield during any year from July
1 to June 30.
C. Affordable housing applications shall be allocated water from the general residential
category until that reserve is exhausted, after which such applications shall be
eligible for allocations from the affordable housing reserve. During any July the
City Council may reassign all or part of any unused reserve from the affordable
residential category to the general residential category, upon determining that there
is no forseeable need for the amount to be reassigned.
D. Projects in the special category shall be eligible for allocations only from the
special reserve, until the special reserve is depleted. Once the special reserve is
depleted, such applications shall be eligible for allocations from remaining
categories, in the order complete construction permit applications are received.
E. Developments with components in exclusive categories which cannot feasibly be
separated must obtain any required water allocation for each applicable category.
F. No project shall be allocated more than [501 percent of the available reserve within
the appropriate category, provided that upon request by an applicant and upon finding
that a larger allocation to the certain project would further the intent of these
regulations, the Council may permit a larger portion of the available reserve to be
allocated to that project. For the purposes of this section, "project" means the
smallest, whole development approved as a single discretionary action by the city,
including the construction within the area of a certain parcel map, tract map,
planned-development, use permit, or architectural approval. "Project" does not
include an entire specific plan area.
G. A water allocation shall be forfeited upon expiration of any building permit
application or any valid building permit, or extension thereto, approved by the Chief
Building Official. The Chief Building Official shall consider lack of water
available for allocation a valid reason to extend a building permit application,
without payment of additional fees.
H. An allocation shall not be transferred from one site or development to another, but
it may be otherwise transferred among parties.
Ordinance No.
Exhibit A
Page 6
17.89.070 Administration
A. During any calendar quarter in which water-use increases are limited pursuant to
these regulations, the Residential Growth Management Regulations (Chapter 17.88 of
this Code) shall be suspended.
B. These regulations shall be administered by the Community Development Department. The
Community Development Director may prepare administrative procedures for this
purpose. These procedures may be reviewed and modified by the City Council at any
time.
The Community Development Director shall establish the amount of required water
allocations for specific types of development. These allocations shall reflect the
expected net increase in water use on a development site. They shall be based
whenever possible on evaluation of water use records for similar types of development
within the city, and may take into account specific proposed features which would
result in a development using more or less water than generally estimated for its
category. The estimates shall be expressed as the number of acre-feet per year a
certain type of development is expected to use.
17.89.080 Fees.
No fee shall be charged for the administration of these regulations. The council may, by
separate action, establish capital facility fees to fund water conservation and supply
projects, or revise water rates, as deemed appropriate.
17.89.090 Enforcement; Penalties
The following violations of these regulations shall be a misdemeanor, punishable as
provided in Chapter 1.12 of this Code:
A. Connection to the city water system or beginning construction of a development
without first obtaining any required water allocation;
B. Constructing or operating a structure or facility which has obtained an allocation
pursuant to these regulations in a manner that would have resulted in its not having
obtained the allocation.
17.89.100 Extension of Planning approvals.
While these regulations are in effect, any use permit, variance, or architectural
approval which expires pursuant to this code shall automatically be extended for two
years. Upon written request by an applicant prior to expiration of the automatic renewal
period, the Community Development Director, upon finding that conditions relevant to the
approval have not substantially changed, may grant extensions not to exceed one year
each.
gm4/war-rec
V ��
[SYNOPSIS]
Ordinance No.
WATER ALLOCATION REGULATIONS
On . .. .. . .. . .... . ... . . . , the San Luis Obispo City Council voted to
introduce Ordinance No. , .. ... ,. (1988 Series). This ordinance establishes regulations
to control increases in water use due to development, as outlined in the water management
section of the city's general plan.
Primary provisions of the ordinance are as follows:
The regulations are to assure that the city can provide acceptable water service,
while facing the situation of water demand from new development increasing faster than
additional supplies. The regulations would remain in effect so long as the level of
normal city water use exceeds the safe yield of city water supplies.
Beginning on July 1, 1988, about (85] acre-feet of water will be available for
allocation to development. Water needed for projects receiving building permits issued
after July I and for building applications in plan check before the regulations take
effect would be subtracted from this initial amount. Once a certain amount of the
current water-use deficit is "payed back," one-half of any additional water supply
obtained after July 1 would be added to the initial amount. The resulting quantity of
water would be available for allocation to development.
Synopsis
Page 2
The amount available for allocation would be divided among certain categories of
projects. Overall, residential projects would receive about 66 percent of the water
available for allocation. Nonresidential projects would receive about 34 percent.
Housing projects affordable to low-income or moderate-income residents would have a
separate reserve within the residential category, to assure that at least 15 percent any
water available for residential allocation would be available for affordable projects.
So long as water use exceeds safe yield, no matter how rapidly additional supplies
are obtained, water use due to development would be allowed to increase no faster than
two percent of safe yield each year.
Projects in the Edna-Islay area and those changing the use of existing buildings would
have a special, one-time reserve of 150 acre-feet, which would not be subject to the
two-percent annual limit.
Before getting a building permit for a new building, major addition, or change in
building use to one requiring more water, a water allocation would have to be obtained.
Several types of minor projects (such as house additions), projects supplying all their
own water, and projects making reductions in water use elsewhere in the city to offset
their expected water use, would be exempt from the limits and would not need water
allocations. Complete building-permit applications received before the regulations take
effect would not have to obtain allocations (though their expected water use would be
deducted from reserves available for allocation to later applications).
Synopsis
Page 3
Projects would receive water allocations within their categories in the order
complete building permit applications are received. No project could use more than 50
percent of the year's allowed increase for its land-use category, unless the council
approved an exception.
A project would be eligible for a water allocation after all discretionary (planning)
approvals had been granted and a complete building-permit application was submitted to
the city.
A development could lose its water allocation if it did not begin construction within
one year from receiving the allocation (or within an approved extension), or if
reasonable progress toward completion was not made within one year of starting
construction.
The council must vote again to approve the ordinance before it can take effect. That
action is tentatively scheduled for . .. . .. . .. .. . .. ... . . at a regular City Council
meeting to begin at 7:00 p.m. in the Council Chamber of City Hall, 990 Palm Street.
Copies of the complete ordinance are available in the City Clerk's Office at City
Hall, 990 Palm Street. For more information, contact the Community Development
Department at 549-7160.
Pamela Voges, City Clerk
(Approved by City Attonery: .. . . .. . , , .. ) gm4/war-syn
$aC
RESOLUTION NO. (1988 Series)
A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISPO
AMENDING THE WATER AND WASTEWATER MANAGEMENT ELEMENT
OF THE GENERAL PLAN (GP 1384)
WHEREAS, the Planning Commission and the City Council have held public hearings on
the proposed amendments in accordance with the California Government Code; and
WHEREAS, the potential environmental impacts of the amendments have been evaluated in
accordance with the California Environmental Quality Act and the city Environmental
Guidelines.
NOW, THEREFORE, the council resolves as follows:
SECTION 1. Finding.
The amendments to the Water and Wastewater Management Element are consistent with other
elements of the general plan.
SECTION 2. Environmental determination.
An initial environmental study (ER 29-88) has been prepared and considered, and the
council hereby determines that there will be no significant impacts and affirms the
action of the Community Development Director to approve a negative declaration.
SECTION 3. Adoption of amendment.
I. The Water and Wastewater Management Element is hereby amended as described in the
attached Exhibit A.
2. The Community Development Director shall cause the amended element to be published
and distributed to appropriate city officials, public agencies, and libraries, and to
be available to the public at a cost not to exceed the city's expense for
reproduction.
Resolution No. (1988 Series)
Page 2
On motion of ..., . . ._. . _ , seconded by . ..
and on the following roll call vote:
AYES:
NOES:
ABSENT:
the foregoing resolution was passed and adopted this . .. day of ., ,,... ,. . . . 1988.
.. . .. .. . . . .. . . . .. . . . ... .. .. . .. .. . . . .. . . ..
Mayor
ATTEST:
. .... . .. .. . .. ...
City Clerk
APPROVED:
City Administrative Officer
City Atto ey
.... .. . .. .. . . . ..... ... . . ..... .. . . . .....
Community Development Director
EXHIBIT "A"
[Combine/simplify policies 2.2, 2.3, and 2.4; eliminate Figure 7; revise Program 2.4]
Policy 2.2 The city will manage water demand so it can continue to provide a high
level of water service. In the long term, demand management should set
limits on new development to assure that additional water requirements will
not exceed available supply. Responding to shorter-term weather
conditions, the Annual Water Operational Plan should focus on how much and
in what manner people in existing development should reduce water use from
normal levels to assure adequate supplies during droughts.
When development approvals must be limited to avoid excessive increases in
water use, the allowed increase in water use should be allocated to new
development according to a system which provides for balanced growth
consistent with other general plan elements and adopted policies.
Program 2.4 The city will adopt regulations which establish allowed increases in water
use for new development and which allocate any allowed increase, consistent
with this element.
(1) So long as normal city water use exceeds safe yield, the amount of
water available for allocation to new development will not exceed:
[74 acre-feet (about one percent of July 1988 safe yield); plus]
I I acre-feet (remaining from the 1987-88 allocation); plus
One-half of any additional safe yield obtained after July 1, 1988
[,less 74 acre feet]; minus
All water allocated after July 1, 1988.
(2) So long as water use exceeds safe yield, all allocations of water to
new development will not exceed an increase in city water use during
any year (July I to June 30) greater than two percent of then-current
safe annual yield.
(3) The regulations may provide a special, one-time reserve for tenant
improvement and use changes in existing buildings and for development
in large, phased projects which have made substantial commitments to
public facilities in anticipation of development, not to exceed 150
acre-feet, separate from the limitations of parts I and 2 above.
(4) The safe yield of a supplemental source will be included only when
each of these has occurred: environmental review has been completed;
the City Council has approved construction documents; the new source
could deliver water within one year.
(6) The estimation of city water use will employ additions of allocated
water to use levels of an average, base year, to avoid fluctuations in
measured water use due to relatively short-term economic or weather
conditions.
The regulations will allocate water-use increases to specific developments,
within various land-development categories. Residential uses will be
provided at least 66 percent of total water capacity to be allocated.
Within the residential category, projects affordable to low- or
moderate-income households will have highest priority. Further, the
regulations will assure that no single project can receive all available
water and that projects which make offsetting water-use reductions in
existing development may proceed independently from the allocation system.
The regulations will take priority over previously adopted regulations or
specific-plan provisions concerning growth management.
Time frame: Regulations in effect by September 1988
Responsible agencies: City Council
Funding: General fund
�'3 3
l
Citi/ O� san WIS 0131SPO
��►►�►�►IIIIIIIiIII��il�uu'll����l
INITIAL STUDY OF ENVIRONMENTAL I M PACT
sITE LocnnoN
Citywide APPLICATION NO. ER 29-88
PROJECT DESCRIPTION n A
rt,o oanaral nla» [y'a r ann WAmtEwA Prn r�vw»t Fle nt concemiri$
rplat-in"ghip-q hptwapn mal" ?Ica
APPLICANT
STAFF RECOMMENDATION:
Y_NEGATIVE DECLARATION
MITIGATION INCLUDED
EXPANDED INITIAL STUDY REQUIRED ENVIRONMENTAL IMPACT REPORT REQUIRED
r-121-0 p DATE--I--Ll--a&
PREPARED BY 5-25-88
COMMUNITY DEVELOPMENT DIRECTOR'S ACTION
DATE
Negative Declaration
SUMMARY OF INITIAL STUDY FINDINGS
I.DESCRIPTION OF PROJECT AND ENVIRONMENTAL SETTING
POSSIBLE ADVERSE EFFECTS
IL POTENTIAL IMPACT REVIEW YES*
A. COMMUNITY PLANS AND GOALS ................................................... NO
B. POPULATION DISTRIBUTION AND GROWTH........................................... NO
C. LAND USE ................................................
.....................• NO
D. TRANSPORTATION AND CIRCULATION ..............................................
VFS*
E PUBLIC SERVICES ................
YES*
F. UTILITIES.......................................
................................ NO
G. NOISE LEVELS ........................................ NO
H. GEOLOGIC&SEISMIC HAZARDS&TOPOGRAPHIC MODIFICATIONS ...................... NO
I. AIR QUALITY AND WIND CONDITIONS.................................:. NO
J. SURFACE WATER FLOW AND QUALITY .............................................. NO
KPLANT LIFE........................................................................ NO
.....................................
L ANIMALLIFE.................................. NO
M. ARCHAEOLOGICALIHISTORICAL...................................................
NO
N. AESTHETIC . ....................................... YES*
OC ENERGYIRESOURCEUSE ........................................
P. OTHER ......................................
............................
III.STAFF RECOMMENDATION
Wo
•SEE ATTACHED REPORT
�'3 y
ER 29-88
INITIAL ENVIRONMENTAL STUDY - WATER POLICY CHANGE
PROJECT/SETTING DESCRIPTION
POTENTIAL IMPACT REVIEW
A. Community plans and goals
E. Public services
F. Utilities
O. Resource use
Existing policies were adopted when water use was about ten percent above safe yield,
with use expected to reach 13 percent above safe yield within a year, the maximum
level determined in the general plan to be acceptable as a one-time response to
anticipated short-term conditions. Under existing policies and water conditions,
water-use due to additional development would not be allowed to increase above the
current level, about six percent above safe field. The proposed change would allow a
further "stretching" of available supplies, in anticipation of additional supplies
being obtained in the coming year.
Existing policies require an annual determination of water available for development,
while the proposed change would allow a continuous "bookkeeping" of additional water
obtained, available, and allocated. The change is intended to keep the city moving
toward a closer balance between water use and supply, a primary goal of the Water and
Wastewater Management Element, while minimizing delays for those proposing
developments. The change would allow an increment of development corresponding to
water use increasing by one to three percentage points above current use (to seven to
nine percent above safe yield). Under both existing and proposed policies, one-half
of any additional water obtained would be made available to development and one-half
would be credited to achieving a closer balance between use and safe yield.
A groundwater study indicates that up to 1,500 acre feet annually may be available
from potential well sites in and near the city. Drilling of test wells is underway.
At current rates of use, in order to balance use and safe yield, the city would have
to obtain 960 acre-feet additional annual yield. Due to the distribution of
groundwater, obtaining the full 1,500 acre feet without also accepting additional
customers (demand) may be difficult.
The Water and Wastewater Management Element contains an assessment of service impacts
(water-use reductions needed) due to exceeding safe yield by various amounts for
various durations. That assessment indicates that the proposed stretching of
available supplies would not significantly impair the city's ability to provide water
during a drought, particularly if additional supplies are developed within the next
year.
The proposed changes would avoid or delay a moratorium at a time when the city is
seeking substantial water savings from existing customers (15 to 25 percen-t
reductions). Getting broad and lasting public support for substantial water
conservation will be difficult if people perceive that water savings beyond
efficiency improvements are simply cancelled by allowing additional development.
The proposed change is not expected to substantially influence pressures to connect
sources of lower quality or reliability.
STATUS: Not significant
gm3/er29-88
ERRATA 0
The following represents necessary changes to the Draft
Environmental Impact Report for the Draft Water Allocation
Regulations (DEIR) in addition to the responses to public
comments provided in Appendix G of the document:
1. Page 4 , Table . l. Percent change in population between
1985 and 8/1987 should be 3.0 percent rather than 0.4
percent.
2 . Page 11, Table 2. Entry under Class II, Description of
Impacts, first paragraph, should read:
About 1,641 persons who. would have located in the
City would locate elsewhere in the County.
rather than "in the City" as in the original text.
3 . Page 15, fourth paragraph. Text should read:
Since 1960, the population of the City of San Luis
Obispo has increased at an average annual rate of
2.41 percent.
rather than 2.54 percent as in the original text.
4. Page 18, last paragraph. The City has water rights
permits to the Salinas and Whale Rock Reservoirs with
the Water Resources Control Board rather than the State
Department of Water Resources as indicated in the
original text.
5. Page 20, second-to-last paragraph reads:
Total storage capacity of the basin is
estimated at 67, 000 AFY with a usable storage
capacity of 22, 000 AF. . . The County's Master
Water Plan has estimated current agricultural
water demand on the basin to be approximately
91200 AFY. 39
Recommended textual changes are highlighted below:
Total storage capacity of the basin is
estimated at 67, 000 AF with a usable storage
capacity of 22, 000 AF. . . The County's Master
Water Plan has estimated current agricultural
water demand by the San Luis Obispo Planning Area
on the San Luis Obispo Creek and Pismo Creek
groundwater basins to be approximately 91200 AFY.
39
6. Page 25, first paragraph, text reads:
Housing Element. The City growth projections in
this document are based upon housing construction
averaging 300 dwellings per year during the 1980's
with a resultant 1990 population of 42, 000.
Recommended textual changes are highlighted below:
Housing Element. The City growth projections in
this document are based upon housing construction
averaging 300 dwellings per year during the 1980's
with a resultant 1990 population of 43,030 (see
Table 4 of the Housing Element) .
7. Page 37, first paragraph, text reads:
o The historical revenues for the City from
1977 to 1986 were analyzed and are used as a
basis for projecting revenues under each
scenario. Future revenues reflect a four
percent annual inflation rate, except for
property taxes which increase two percent
annually.
Recommended textual changes are highlighted below:
o The historical revenues for the City from
1977 to 1986 were analyzed and are used as a
basis for projecting revenues under each
scenario. Future revenues reflect a four
percent annual inflation rate, except for
property taxes which reflect an annual
inflation rate of 7.65 percent for property
valuation (see June 30, 1987 Comprehensive
Annual Financial Report) .
The results of the original fiscal impact analysis were
reassessed using the revised annual inflation rate of
7.65. The revised tables from Appendix E of the DEIR
follow this text. Although application of the revised
rate to each scenario in this analysis results in
increasing City revenues by $2.1 to $2 .3 million in FY
1996-97, the general conclusion that no growth periods
would result in less affected revenues to the City than
the City would accrue under continued growth remains
the same.
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19
�- y
8. Page 47, fifth paragraph. The first sentence should
read:
In order to accommodate the population and other
non-residential growth projected in the scenario,
the City will have to increase its existing SAY by
21291 AF by FY 1997-98.
rather than FY 1997-88 as in original text.
9. Page 52, first paragraph, second-to-last sentence
should read:
(If growth, for example, continued under this
scenario at an annual rate of 2. 0 percent, the
1987 SAY would need to be increased by 21129 AF by
FY 1996-97. . . )
rather than "to a total of 2, 129 AF. "
10. Page 65, last paragraph. First sentence should read:
Under this scenario, water use would reach 115
percent of SAY in FY's 1990-91 [rather than
190-91] , 1992-93 , 1993-94 and 1996-97.
Bracketed text not intended for inclusion in EIR.
11. Page 65, last paragraph, last sentence should read:
Furthermore, allowing water use to exceed SAY on
[rather than or] a continuous basis would
jeopardize adequate water service to existing and
new developments.
Bracketed text not intended for inclusion in EIR.
12 . Page 70, endnote 34 should have a preparation date of
December 16, 1985 rather than December 16, 1987.
13 . The last page of references is missing from the
original text and is included at the end of the Errata.
14 . Appendix F, fifth page, third paragraph. The potential
reservoir site on Santa Rita Creek was evaluated by the
State Department of Water Resources (rather than the
State Water Resources Board) and San Luis Obispo
County.
15. Appendix F, sixth page, second paragraph reads:
In 1979, the San Luis Obispo FCWCD contracted
with Bookman-Edmonston Engineering, Inc. to
develop a plan for water distribution from the
Nacimiento Reservoir. The firm concluded that the
inclusion of water from the reservoir into the
County would be easily accomplished; however,
public support for the needed financing for
construction of the transportation and treatment
facilities was lacking. 16
The last sentence should be changed as follows:
The firm concluded that the inclusion of water
from the reservoir into the County would be easily
accomplished; however, public support for the
needed financing for construction of the
transportation and treatment facilities is
required. 16
CW1370.MIS
B. REFERENCES (cont. )
"Water Allocation Regulations; Social and
Economic Changes. "
Water and Wastewater Management Element, adopted
October 26, 1987.
"Water Source Augmentation Study - Final Draft, "
December 16, 1985.
"Water Use Estimates: 1987-88 New Development, "
(prepared by the Community Development Department) .
"Water Use Factors, " May 1987.
San Luis Obispo, City of, and Angus McDonald & Associates.
Strategic Planning Program; Summary Report: A Survey
of Economic Resources, September 1983 .
Strategic Planning Programs; Technical Report: A
Survey of Economic Resources, September 1983 .
San Luis Obispo, County of. "San Luis Obispo County -
Population Projections, " (prepared by the Department of
Planning and Building) , January 1987.
Master Water Plan Update (prepared by the
Department of Water Resources, Southern District, in
cooperation with San Luis Obispo Flood Control and
Water Conservation District) , March 1986.
TEM Associates, Inc. A Study of the Job Generation Process
in San Luis Obispo County. California (Berkeley,
California) January 1985.
Urban Research Associates. Industrial Sector Analyses: San
Luis Obispo County Airport Area Industrial Specific
Plan (Fullerton, California) July 1986.
Westec Services, Inc. Final Environmental Impact Report:
Edna-Islay Specific Plan.
Willdan Associates. San Luis Obispo County Airport Area
Specific Plan: Water Supply. Ouality and Sewage
Disposal (Ventura, California) July 1987.
CWI371.MIS
-75- (j���
DEIR: COMMENTS RECEIVED AND RESPONSE TO COMMENTS
List of Commentators Page_
Clinton Milne, Deputy County Engineer 2
San Luis Obispo County Engineering Dept.
Conrad Byars, Chamber President 12
San Luis Obispo Chamber of Commerce
William J. Coghlan, Vice President/Project Director 16
The Pacifica Corporation
Westlake Village, California
John D. French 24
Santa Lucia Hills
San Luis Obispo, California
Dennis W. Tewes, Registered Professional Engineer 40
San Luis Obispo, California
CWI365.MIS
S9 LUIS OBISPO COURTY
COUNTY GOVERNMENT CENTER • SAN LUIS OBISPO,CAUFORNIA 93408 • (805)549-5252
VAL
GEORGE C. PROTOPAPAS
County Engineer
Dow"CO1'"""4D1 RECEIVED ENGINEERING
UNTY
NM WaftTOM ADA 4SMAYM DEPARTMENT
April 15, 1988 APR 18 1988 NUM
TRMtPME4710N
Cny of Sen dun Maw FUM CONTROL
Community Devebpmew WAM COWMAWN
Glen Matteson, Associate Planner CaUNn'wRYEXx
Community Development Department SK-OAL067=
City of San Luis Obispo SOUR WASTE
P. 0. Box 8100
San Luis Obispo, CA 93403-8100
Subject : Draft EIR for Proposed Water Allocation Regulations
Dear Mr. Matteson :
Thank you for sending the Draft EIR for Proposed Water Allocation
Regulations of the City of San Luis Obispo to us for comment. After
reviewing the draft, I was pleased to see that it is quite
comprehensive with a lot of good information.
In my review, I have the following comments and/or questions :
1. Page 1, paragraph 3. . The sentence concerning the average
annual growth rate shows a figure of 2. 54% since 1960. My
calculation would indicate the figure to be 2. 41%, using 26 1/2
years as the period of growth and the numbers from Table 1.
2. Page 4, Table 1 , last item. The percent change column from
1985 through August 1987 reflects . 3% rather than . 4% according 2
to my calculation.
3. Page 18, last paragraph. The sentence that reads "The City has
water rights permits to both reservoirs with the State
Department of Water Resources. " is incorrect. The permits are
issued by the State Water Resources Control Board not the State
Department of Water Resources. The last sentence in that
paragraph also says "The City also has undeveloped
appropriative rights on Hansen and Gularte Creeks. " I would
suggest the City show some kind of due diligence in putting c
that water right to beneficial use, otherwise, the State Water
Resources Control Board may well rescind the water rights
permits.
4. Page 209 next to last paragraph, last sentence says "The
County ' s Master Water Plan has estimated current agricultural
water demon on the basin to be approximately 9, 200 AFY. " That
is a misinterpretation, the Master Water Plan Update evaluated
-2- e?_ys
demand by agriculture on the basis of planning areas. The San
Luis Obispo Planning area encompasses more than just the San
Luis Obispo Creek Groundwater Basin; in fact, it includes the
Pismo Creek Groundwater Basin. I would refer you to Figure 1,
page 4 of the San Luis Obispo County Master Water Plan Update
to see a map of the planning areas.
5. Page 21, last paragraph. There is obviously an error. It
shows that the " . . .Cooperative Use will serve to increase the
net yield of the reservoirs to , possibly 10,500 AFY (compared
to the current safe yield annual yield of 99200 AFY) with an r
average yield ranging from 9, 500 to 10,000 AFY. " Never would J
the safe yield exceed the average yield.
6. Page 22, paragraph titled "Wells" indicates that "The City has
constructed a well at the municipal golf course which may be
used to irrigate the golf course , the ,junior high school
grounds and Laguna Lake Park. Attached to this letter is a
Figure titled "Rights to Groundwater" which was taken from
Bulletin 118 published by the Department of Water Resources .
It privides an excellent explanation of rights to groundwater.
Note that if a basin is in an overdraft condition , then no
water is available for export by appropriators to nonoverlying
lands. My interpretation would be that clearly the City could
use the golf course well for irrigation on the parcel of land
that encompasses the golf course , but it may well be vulnerable
if it tried to export it for use on nonoverlying land at times J
when the groundwater basin is in an overdraft condition.
7. Page 23, the paragraph titled "Groundwater" explains that the
City has awarded a contract to a consultant to prepare a
groundwater development and management study. If the study
reveals that the groundwater basin is an overdraft condition,
then the City would be very vulnerable if it pumped water for
use on nonoverlying land. Perhaps the City will wish its water
rights attorney to address this issue?
8. Page 29, Table 4. The amount shown for additional yield by
cooperative use at both reservoirs is 500 AFY. I understand
that such figure is based upon meager information.
Intuitively, I am sure that cooperative use of Salinas and
Whale Rock will provide additional yield, but 500 AFY seems to
be too high. I talked to Bill Hetland about this and he was
going to see what the City ' s consultant, CH2M Hill, had to say J
about it.
-3- �—y(G
9. Page 30, the section on Exceptions talks about additions to
nonresidential buildings of less than 50% of the floor area or
1, 000 square feet whichever is greater. My comment here is
that it could be that water use would be reduced if a building
addition replaces irrigated landscaping. In which case, if
water use is the important item, then it ' s possible that
encouraging additions would result in reducing the water need
under certain circumstances. The point here is that it may be
desirable for the City to be more flexible about what additions
might be accepted.
10. Page 37, top paragraph, last sentence. It says future revenues
reflect a four percent annual inflation rate except for
property taxes which increase two percent annually. That isn' t 1
likely correct for a. 2% increase. The 2% is applicable if
homes were not sold, but if they are sold, then there is at new
tax rate in which case the "two percent annually" is too low.
11 . Page 47, first paragraph, under Mitigation Measures. The "FY �L
1997-88" is obviously a typographical error.
12. Page 52, top paragraph, sentence within the parentheses. I
would revise it to read, "If growth, for example, continued
under this scenario at an annual rate of 2%, the 1987 SAY would 1:
need to be increased by 21129 AF by FY 1996-97. " (The 2129 AF
is not "to a total of. " ) Last sentence under same paragraph, I _
would note that water conservation does not increase the water
supply, it results in more efficient use and therefore makes
the water go further. My comment is predicated on water
reclamation not being deemed to be water conservation.
13. Page 59, last paragraph. I would revise the paragraph to read
"The County Master Water Plan Update proposes pursuing
additional water sources including the State Water Project,
Nacimiento Reservoir, enlargement of the Salinas Dam, Lopez
Dam, Nacimiento Dam, desalinization/demineralization, expanded
use of wastewater reclamation, artificial recharge of
groundwater, interception of subsurface outflow to the ocean
watershed management and weather modification, new local
reservoirs (Bald Top, Upper Ragged Point, Yellow Hill, San
Simeon, Santa Rosa, Lower Jack and Santa Rita) . The Master
Water Plan Update also recommends strong water conservation
goals in both the urban sector and the agricultural sector. "
I would recommend the addition of the following paragraph.
"The County has requested the State Department of Water
Resources to prepare an environmental impact report on the
Coastal Branch of the State Water Project. The County is also
pursuing water conservation as an important means of partially
offsetting the need for supplemental water. These are the
first priority items under the recommendations of the Master
Water Plan Update. " -
-4- �_y7
14. Page 62, under the Rate Structure Section. The second item
says "Change Rate so that it rises with consumption. " I have
the philosophy that a rate structure should be designed to
achieve water conservation goals. It may be that merely
changing the rate so that it rises with consumption would not
be equitable. For example , a large water user may be very
efficient in his water use, but is penalized because of the
amount used. A smaller user might be very inefficient ,
and would not be penalized. I think perhaps this could be
offset by adding another item under the rate structure category
and that would be "Rebate for efficient water use. "
15. Page 63, under the sink faucet flow reducers, the last item is
"instant" hot water. It should be recognized that there is a
trade-off , though this would save water it would most likely 1
use more energy. The decision then is which is more important ,
to save water or energy.
16. Appendix F, the fifth unnumbered page which concerns Santa Rita
Reservoir. The reference should not be to the State Water U
Resources Board, but to the State Department of Water Resources.
17. Appendix F, the sixth unnumbered page. In the two paragraphs
under the Nacimiento Reservoir, it talks about distribution
facilities. Technically , it would be better if the word
"distribution" were changed to "transmission" . The
transmission line is what is not in. Distribution systems are
normally considered those distributing water within a service
area, not conveying the water to the service area. Part of the
last sentence in the second paragraph under that heading, says
" . . .however, public support for the needed financing for
construction of the transportation and treatment facilities was
lacking. " That is not the case. In fact, the matter was not
presented for public consideration. The situation was : that
just before the Board of Supervisors was ready to act on
calling an election to consider the financing by a revenue bond
issue, Santa Barbara County interests changed direction and
resumed active study of the State Water Project. San Luis
Obispo County staff was concerned that if Santa Barbara County
went ahead with the State Water Project and at the same time
San Luis Obispo County had gone ahead with the Nacimiento
Project, then San Luis Obispo County would be forced to
withdraw from the State Water Project, and in light of the
County' s General Plan, this would not prove prudent.
Accordingly, the County Water Advisory Committee, along with
the County staff recommended that the Board of Supervisors not
go forward with an election . on the Nacimiento Project ; the
Board of Supervisors agreed.
-5-
18. Same page, next paragraph under Groundwater. I would recommend
that the City have its water rights attorney consider the
matter of pumping from the groundwater basin and using such 1
water on nonoverlying land. In the case of an overdrafted
basin, I suspect that this would not prove to be a reliable or
even an emergency supply during an extended drought .
19. Appendix F, unnumbered page 7, first paragraph, last sentence
says The City views these streams as back-up sources for times
of emergency as defined in the Annual Water Operational Plan,
and retains their appropriative rights. " I would suggest that
the City have its water rights attorney also look into the
vulnerability of the City not putting the water to beneficial
use as it is possible that the State Water Resources Control
Board could rescind the City ' s water rights on those streams.
Should you have any questions about my comments, please call.
Sincerely ,
GEORGE C. PROTOPAPAS
County Engineer
CLINTON MILNE
Deputy County Engineer
M/nt
1513x
-6- �- y9
RIGHTS TO GROUND WATER
FULL BASIN
r•�^ OVERLYING LANDOWNERS SHARE
E* -OF-OVERLP IVO ftgp FOR BENEFICIAL USES ON CORRELATIVELY OVER
U ORT'.ED;FROM�j-�b0'ROR LYING LANDS RiTHOUT REGARD
`F1R3T�IN-TfsIF�Ff STy4 C*, TO TIME OF USE.
"POC,h cid t
�`'B '•?P" WATER LEVEL
RHAR
ECGE:.FROM;NAT URAL'
�i ,.`SOURCES1SUFF(CIENT�kT
q.y
�F.KEEKBASlN.,7ULL';
OVERDRAWN BASIN
IMPORTED NATER MAY USE STORAGE SPACE
NOT NEEDED FOR NATURAL RECHARGE
PaO�ECt
C,,V.ERLYfJi6 LANDtlM11ERS SNARLS
'7lAtURALaVATFlL4d0E0UALLYY$ -
;sPRtoRJT7, G4.: ..................
41
MPORTEO Wi1TER RECAPTURED FfRST fip
IMPORTED WATER PROJECT Ri04i
OPERATOR AND CUSTOMERS
EMPTY STORAGE SPACE WATER LEVEL
RECHARGE FROM NATURAL
SOURCES INSUFFICIENT.TO.
KEEP BASIN FULL
' COM(NGLED.IMPORTED&NAit1RJll WATERS°+
F` I
NOCCS:
no which will not do pormonent damage to basin or haw adverb*effects on dto basins
• Total uses of.star limited o•steu
long-tons supply.
• Old Posed i-"—*
v Alhambra 'mutual proscription' rule which apportioned water among all users both overlying end
appropriativo an basis of uses during the last 5 years of Overdraft prior o filing adjudicatory action Is no longer the
law. The ease of ■ An 6-k—s "Sort Fernando overturned the 'Mutual Proscription' doctrine and held prescriptivs
rights do not apply against Rrblie entities.
fopri-
• Also the old Pasadenasafe
YI vs ,* that is, thwhich average annualnd natural rndt•recharge of thooverlying
basi". has been wodifl•da oPallow
son to the 'sof• yields, .
withdrawals in amounts which will net•dwrsly effect the basin.
Figure 26. Rights to Ground Water
—7— ig,5
RESPONSE TO LETTER FROM: Clinton Milne, Deputy County
Engineer
County Engineering Department
April 15, 1988
DEIR Section Numbers Applicable to Comment: I-A, III-A,
IV-C, VI-C, VI-F, VIII-B, Appendix F
1. Using the population figure provided for the City of
San Luis Obispo in Table 1, the average annual growth
rate of 2.41 percent is accurate. The average annual
growth rate of 2. 54 percent used in the document
reflects the 1985 population figure of 37,800 provided
by the San Luis Obispo County Department of Planning
and Building for January 1987.
The 1985 figure provided in Table 1 is from the
Department of Finance (DOF) Population Research Unit
and is also a projection (using a demographic cohort
survival model) since more recent census figures are
not yet available. The DOF is probably more accurate
than the County projection and the average annual
growth rate of 2.41 percent is more likely appropriate
for this analysis.
2 . Comment noted; see Errata.
3 . The source for this comment is the City's Draft Water
Management Plan (April 1986) , page III-I. Comment
noted; see Errata.
4 . Consistent with Sections 15132 and 15088 of the CEQA
Guideline, this section responds to those comments and
questions pertinent to the DEIR. This comment is more
appropriately deferred to the City Attorney.
5. Comment noted; see Errata.
6. These findings are from the Draft Water Management Plan
(April 1986) , page IV-4 and the "Water Source
Augmentation Study - Final Draft" by CH2M HILL
(December 16, 1985) , page 4. According to these
reports the gross yield from the two reservoirs,
excluding downstream releases, could be 10, 500 afy
based on annual data from 1940 through 1973 and that
monthly flow data would probably be lower than this
estimate and result in an average yield ranging from
9, 500 to 10, 000 afy.
7 . The source for this comment is the City's Water and
Wastewater Management Element (page 18) . The
appropriateness of using this well for other than the
gold course is not an issue of the Draft EIR and is
best addressed by the City's Utility Division and/or
City Attorney.
8 . This comment was deferred to the City Attorney.
9. This comment was deferred to Bill Hetland.
10. Comment noted.
11. The June 30, 1987 Comprehensive Annual Financial Report
shows an average annual increase in property tax
revenues of 7. 65 percent between 1980 and 1987. The
County of San Luis Obispo is permitted to increase
property valuation by 2 . 0 percent annually to adjust
for inflation. The 7 . 65 percent annual increase in
property tax revenues between 1980 and 1987 reflects
the increase in housing valuation for resales, new
construction and the annual 2 . 0 percent inflation rate.
The affected revenues for each scenario were reassessed
using the adjusted inflation rate of 7.65 percent. The
revised tables are appended to the Errata and show the
following for affected revenues under each scenario for
FY 1996:
DEIR Revised
Scenario Revenues Revenues Difference
I $ 34,337,944 $ 36,722, 568 $ 2 ,3841624
II $ 31, 353, 844 $ 33,809,871 $ 2,456, 027
III $ 29,951,936 $ 32 , 054,778 $ 2, 102 , 842
12 . Comment noted; see Errata.
13 . Comment noted; see Errata.
14. In the DEIR, water conservation is meant to be the
implementation of those measures that are designed to
improve water use efficiency, increase water reuse and
recycling, and minimize the waste of water.
15. Comment noted.
16. This summary of Alternative Water Conservation Measures
is from a City document entitled, Recommended Water
Conservation Plan (ca. 1983) .
It is true that a flat or uniform commodity rate
structure has inherent inequities in the allocation of
service costs. The preferred rate structure would be
an excess use structure to reduce seasonal peak water
demands. Under this scheme, one set of commodity rates
is set for a base allotment of water use, generally
corresponding to normal interior water use plus a
modest amount of seasonal water use. A higher
commodity rate is then charged for all use over the
base allotment. This method avoids penalizing
customers with little or no seasonal water use while
providing a strong economic incentive for other
customers to reduce seasonal use. In some
applications, an excess use rate is simply a two-tiered
increasing block rate structure. Additional rate
blocks can be added, with higher unit costs for
consumption exceeding the base allotment. Another
variation is to allow the individual utility customer
to establish a unique base allotment. Typically, the
base allotment is calculated using each customer's
average consumption during the winter months plus a
percentage of the winter average for modest seasonal
uses. Higher rates are then charged for use in excess
of the individual customer's unique base allotment.
This approach avoids penalizing households with higher
than average occupancy (e.g. , large families) and
creates a direct link between the individual customer's
water use patterns and utility service costs. However,
individualized base rates can potentially penalize
customers who have historically been water-conserving,
but who have a sudden conservative increase in water
use either on an infrequent or consistent basis.
Implementation of this approach requires a relatively
sophisticated utility billing system and may prove
difficult to explain to customers.
Another water-pricing concept that has been employed is
to incorporate punitive rate increases in a drought
management contingency plan. When supply and/or demand
conditions dictate, the unit cost of water above a base
allotment is set at a very high punitive rate. Such an
approach is often described as "price rationing" and
may be used with regulatory measures to reduce water
use during drought conditions.
17. Comment noted. Verification of this comment requires
special consideration outside the scope of this DEIR.
18. Comment noted; see Errata.
19. Comment noted. The word "distribution" rather than
"transmission" was selected based upon the following
excerpt from the County's Master Water Plan Update
(page 34) : " . .the County Flood Control and Water
Conservation District contracted with Bookman-Edmonston
Engineering, Inc. to develop a plan to distribute
Nacimiento water to various areas in the County. "
(Emphasis added. )
20. The DEIR would be more accurate in stating "however,
public support for the needed financing for
construction of the transportation and treatment
facilities is required. " See Errata.
21. Comment noted. This comment is deferred to the City
Attorney.
22. Comment noted. This comment is deferred to the City
Attorney.
deur• .:GI.! VJ•JY .. . .• .rr _____ . .__. _-
. , 'REtI`ING AGENDA /S
DATE rV
San Luis Obispo Chamber of Commerce
IM0 Ghe)"n Streel . Sun UM Oasc+o Califanla 93.401 • (805) 543.1323
Cavia E Garth • E.ec;rrlve Manager 14- A(ill7th;
02). ,Pdirr d�10
,6.,� ..
RECEIVED -r`.�
April 29, 1988 IPPR 2 9 1983 &449 `&OL
nT.clt4«
SAN LUIS COS C.CA
Honorable Mayor and City Council Members
City of San Luis Obispo
P.O. Box 8100
San Luis Obispo, CA 03403-8100
Dear Rayor and Council Members:
The San Luis Obispo Chamber of Commerce appreciates the
Opportunity to respond to the EIR for the proposed Water
Allocation Ordinance. I regret that more of oar members
cannot be present at the May 3rd Council meeting to respond
in person, but as you know, our 20 person contingent will be
in Sacramento presenting local concerns to State
deeisionmakera.
The Chamber remains opposed to tha adoption of a Water
Allocation Ordinance and urges you to reject such an
ordinance. The ordinance, with its provision for a 1
constriction slowdown, would have a devastating affect on
our local economy and is a dangerous solution to our current
water problems. We feel it conflicts with the provisions of
the existing Growth Management ordinance.
The Growth Management Ordinance is an agreement to
accommodate a certain level of growth in our community. In
adopting that ordinance, the Council accepted the
responsibility for providing services for the agreed upon 2
growth. Until such time as every er effort has been made to
develop the water needed to meat those needs, we feel tke
proposed Water Allocation Ordinance should not even be
conal idered.
We are heartened by the results of the preliminary
groundwater studies and are confident that our water
problems can be resolved without a water allocation
ordinance. The allocation ordinance EIR raises several
key points which further indicate the damage such an 3
ordinance could do.
SGC R ED�TCO
The EIR makes reference to the urban sprawl impact of the �•••••••�.�
ordinance. Ours '-s a community already struggling with th
-12-
�s:
25-'33/1986 0531 "1TY o+ bLU vU»wVIIVQ� row
z —
Council letter re: avatar Ordinance page 2 4/28/88
urban spravl issue, and yet we are looking at adoption of an 3
ordinance which would undeniably aggravate the sprawl
situation. This is not acceptable.
The LIR mitigates the loss of construction in our city by
stating it will be absorbed by cther areas of the county.
This premise is also dangerous, given the moratoria
conditions already present in other local co=unities, as 4
well as the threat to San Luis Obisno's identity as the
"hub" of the county_ Every defection of business or service
from San Luis Obispo must be seen as a permanent loss and an
eroding cf our business vitality.
The EIR speaks to the "temporary" nature of the ordinance,
yet the ordinance itself has no sunset clause nor any
real explanation of what makes it temporary.
In short, the EIR points out the inescapable impacts of a
water allocation ordinance: its contribution to urban
sprawl; its-
s cost in the loss of const--action and jobs, and 6
its ability to destroy San Luis Obispo's role as the
economic center of the county. While we have no substantive
objections to the Elft, we do oppcse the water Allocation
ordinance. we urge your continued persuit of supplemental
water; and encourage you to utilize our existing growth
managment ordinance for shaping growth around oar resources.
Lastly, we most urgently ask you to reject the proposed
dater Allocation Ordinance.
Best regards,
Conrad Byars
chamber President
i
i
T07P.L P.03
-13- �/��
RESPONSE TO LETTER FROM: Conrad Byars, Chamber President
San Luis Obispo Chamber of
Commerce
April 29, 1988
DEIR Section Numbers Applicable to Comment: IV-C, Appendix A
1. Comment noted.
2 . Comment noted.
3 . The negative impacts identified in the DEIR, such as
urban sprawl, are more the result of lack of water
availability than the proposed Water Allocation
Regulations. The allocation procedures in the proposed
regulations may result in constraining non-residential
growth and stimulating residential growth in the City
by allocating proportionately less water to
non-residential uses and more to residential uses. The
proposed regulations will not result in the
displacement of population growth elsewhere in the
County - this is more a function of water availability.
The proposed regulations could either result in the
displacement of non-residential uses in the County or
existing businesses could remain in the City and become
more efficient in terms of achieving their market
thresholds and conserving water. Economic data is not
available to support either of the last two scenarios
for non-residential uses.
4 . Although economic data is lacking to support some of
the assumptions made in the DEIR, City staff and
consultants concluded that it is reasonable to assume
that the entire County is the trade-area for
construction-related goods and services and that any
growth displaced from the City will remain within the
County. Given these assumptions, a short-term building
moratorium should not result in a permanent loss of a
significant number of businesses and/or jobs in the
County. Again, a building moratorium would be more the
result of a lack of water availability than the
proposed regulations themselves.
5. The intent of the proposed regulations is that they
would be in effect until substantial sources of water
supply would become available to the City. This intent
is reflected in the EIR several times.
o The draft regulations in Appendix A state (Section
17.89.050) : "During any year in which water-use
increases are limited pursuant to Section
17.88. 020, the Residential Growth Management
Regulations shall be suspended. " This
suggests that the City's water supply conditions
must meet specific criteria prior to
implementation of the proposed regulations.
-14- � -s�
o Page 28 of the EIR: "The Water Allocation
Regulations translate the policies of the Water
and Wastewater Management Element into an
implementation mechanism which would determine
which projects could be built if the City did not
have enough water to serve all proposed
development projects. Because major sources of
water needed to support significant expansion of
the City are not expected to be available until
the 1990's, this interim means to allocate water
to new development is needed. " (Emphasis added. )
o Page 28 of the EIR: "The purpose of the Water
Allocation Regulations is to . . . prevent water use
from exceeding safe annual yields . and . . . [to]
eventually bring water demand within reliable
yields as new sources of water become available. "
Once water demand in the City is at or below 100
percent of the City's safe annual yield, the
proposed Water Allocation Regulations will not be
required.
6. The proposed regulations, as identified above, will not
be the cause of urban sprawl or a building moratorium.
Rather, these impacts are a result of lack of water
availability in the City. One purpose of the proposed
regulations is to keep water demand from exceeding 113
percent of safe annual yield and eventually bring it
down to 100 percent of safe annual yield.
-15- �-��
THE PACT FICA CORPORATION
April 26, 1988
Michael Multari
Community Development Director
CITY OF SAN LUIS OBISPO
P.O. Box 8100
San Luis Obispo, California 93403-8100
Subject: Water Allocation Regulation Draft EIR
Dear Mr. Multari:
Thank you for the opportunity to review and
respond to the City' s Draft Environmental Impact Report on
the City"s "Water Allocation Regulations" .
We have, of course, thoroughly reviewed this EIR.
While it is clear that it represents a strong effort on the
City' s part to evaluate the impacts of these regulations, it
nonetheless presents some serious concerns that we feel must
be addressed in the final EIR.
Please know that we make these comments as
constructive criticisms. By responding to our points and
those raised by others, this EIR could be a most valuable
tool and informational document that could be of great
assistance to the City as it makes some of the most critical
decisions that it will face in the future.
In forwarding our comments, our intent is that
this EIR be an instrument of information rather than an
instrument of obstruction. The strength and seriousness of
our concerns are directed to that end.
Attached is an outline of our comments to and
concerns with the assurance they will be addressed by your
consultant and the City staff.
200 NORTH WESTIAKE BLVD..SUITE 200•WESTLAKE VILLAGE.CALIFORNIA 91 362 -(805)495-9494
-16-
Michael Multari
April 26, 1988
Page Two
If you have any questions regarding our concerns
or intentions, please do not hesitate to give us a call.
Regards,
THE PA CORPORATION
illi J. Coghlan
vice President/Project Director
WJC:bb
Enclosure
l'
-17- r�/
The Pacifica Corporation's Comments to Draft EIR
Water Allocation Regulations
After a thorough review of the City's draft EIR on its proposed Water
Allocation Regulations as published and distributed by the City in
March 1988, we find that the report is generally a thorough one and
one that has strived to address our appeal .
There are, however, still some points that received scant attention
or were simply unaddressed in this EIR -- points we feel critical
ones that deserve to be addressed before the Council can make an
intelligent decision on its Water Allocation Regulations.
Rather than quibble with details, our concerns with the EIR are
conceptual and it is these concerns we express below:
1. Project Mitigation Measures
The "mitigation measures" section on page 57 (which allow the EIR
to make the statement that are "no significant impacts which
cannot be mitigated") sets forth a series of potential measures
that the City could adopt to mitigate the impacts of these
regulations. However, there are no guarantees that these
mitigation measures will indeed be accepted or incorporated into
a City action on the EIR. The EIR should clearly stipulate that
the Council shall take or has taken binding affirmative actions
to adopt these mitigation measures at the same time or before, the
City considers adopting its water allocation regulations. If
there is no guarantee that the City will indeed mitigate these 2
impacts, then the impacts remain significant, unmitigated, and
serious. If the City cannot make such a finding or take such an
action as outlined in the mitigation measures, then these impacts
should be addressed as Class I impacts which are significant,
unavoidable, and adverse..
Impacts of Deflected Growth
The discussion on possible impacts under "Scenario II°on page 50
mentions that approximately 1,600 people would be deflected into
County areas such as "The Airport Specific Plan Area, Paso
Robles, Atascadero, North Coast, and unincorporated County
areas While we agree it will affect the Airport Area, we just
don't see how the rest of this conclusion can be reached. $
Without addressing the "numbers" , we question the methodology
used in the EIR to say that the majority of displaced units would
be located in areas north of Cuesta Grade rather than the more
attractive coastal and South County areas that are more conducive
to the development pressures caused by the City of San Luis �.
Obispo. —
—18— �_/-/
3. Affects of Outside "State" Agency Growth on San Luis Obispo
The displaced growth figures do not seem to take into account the
problem of future expansion of Cal Poly or other nearby State
agencies. The figures for future Cal Poly enrollment have ranged
anywhere between 2,000 to 6,000 new students by the year 2000
(not including the additional academic support staff and their
families that would come into San Luis Obispo via Cal Poly. A
decision to increase enrollment at Cal Poly is one that will be 4
by the the "State" -- a decision that would be beyond the City's
control . The impacts resulting from Cal Poly expansion as well
as other expansion by State agencies (i .e. California Men's
Colony) on this limited growth area should be thoroughly assessed
in the body of this EIR before any decision is made on the Water
Allocation Regulations.
4. Need to Evaluate the Cumulative Impacts; of ForthcomingGrowth
Management Reau ation Proposals
Since this EIR was undertaken, there have been subsequent
discgssions in both the City and the County regarding numerous
proposals and methods to regulate growth, both in the City and
County. Indeed, the County is currently reviewing a proposal put
forth by a group of citizens which will severely restrict growth
in unincorporated County areas. Before these regulations are 5
adopted, the EIR should examine the cumulative impacts associated
with the City's Water Allocation Regulations in combination with
these new measures to control growth. The associated impacts on
the economy, housing, opportunities, etc. and the growth inducing
impacts on other incorporated communities that would likely
absorb the growth deflected by such an interaction of growth
control ordinances.
5. Need to Study Additional Alternatives
The alternatives evaluated by the EIR should include:
A. An alternative that would leave the City's existing growth s
management regulations in place without adopting the Water
Allocation Regulations,
B. An alternative that would have the City adopt the Water
Allocation Regulations and the County adopt the growth 7
management regulations recently proposed to the Board of
Supervisors.
C. Al alternative that would have the City commit to bringing
substantial new supplemental water sources on line in a time
line quicker than the Water Management Element proposes to 8
help allay the impacts of forcing growth that would
otherwise locate in the City into other incorporated and
unincorporated areas within the County.
V5/KG-Comments
RESPONSE TO LETTER FROM: William J. Coghlan, Vice
President/Project Director
The Pacifica Corporation
April 26, 1988
DEIR Section Numbers Applicable to Comment: Executive
Summary, III-A-4, VI-A, VI-B, VII-A, VIII-A
1. Comment noted. The purposes of the environmental
review process are to:
(1) Inform governmental decision-makers and the public
about the potential, significant environmental
effects of proposed activities.
(b) Identify the ways that environmental damage can be
avoided or significantly reduced.
(c) Prevent significant, avoidable damage to the
environment by requiring changes in projects
through the use of alternatives or mitigation
measures when the governmental agency finds the
changes to be feasible.
(d) Disclose to the public the reasons why a
governmental agency approved the project in the
manner the agency chose if significant
environmental effects are involved.
(See Section 15002 of the CEQA Guidelines. ) It is not
the purpose of the EIR to condition a project prior to
its approval or to enforce these conditions.
2. Consistent with 1(d) above, City staff has indicated it
will make written findings for all mitigated
significant effects (pursuant to Section 15091 of the
CEQA Guidelines) and recommend a Statement of
Overriding Considerations to justify adoption of the
regulations if all potential impacts of the project are
not mitigated to a point of insignificance (Section
15093 of the Guidelines) .
3 . This conclusion was drawn based upon two studies
performed for the County of San Luis Obispo in 1985 and
1986 by TEM Associates, Inc. and Applied Development
Economics. The general conclusions of these studies as
well as County population projections for incorporated
cities show Paso Robles, Atascadero, the North Coast
and unincorporated areas to have the greatest growth
potential within San Luis Obispo County. Furthermore,
the Technical Report for the City's Strategic Planning
Program (September 1983) indicates that 56.6 percent of
all persons employed in the City are residents of the
City. All other employees are commuters from Arroyo
Grande (17.5 percent) , the North Coast (15.5 percent) ,
Atascadero (9 . 1 percent) and Paso Robles (1.3 percent) .
-21-
These figures are based on the 1980 census and reflect
the only reliable information currently available.
4. Cal Poly received 1,272 AFY of water from the Whale
Rock Reservoir; this is an entitlement separate from
that of the City's entitlement of 2, 057 AFY.
Furthermore, the Men's Colony also has a separate
entitlement of 411 AFY (see Section III-A-4 of the
DEIR) . As a result, the City is not responsible to
serve these State institutions with water.
Cal Poly has not .definitely decided, as yet, to expand
enrollment as identified in comment #4 . Expansion
plans for the Men's Colony are also not definite. If
these institutions do expand their capacities, the new
capacities would also have to be matched by additional
site improvements (i.e. , buildings, roadways,
water/wastewater infrastructure, etc. ) which would come
under the influence of local conditions, including City
policies and water availability. The water-related
issues and impacts related to the expansion of Cal Poly
and the Men's Colony are best addressed at the time the
expansions are proposed in a separate environmental
document.
The expansion of these institutions would place
increased growth pressures on the City; however, due to
lack of water availability the City will be constrained
in accommodating additional City residents. One
purpose of the proposed Water Allocation Regulations is
to prevent water consumption in the City from exceeding
113 percent of SAY and to eventually achieve a balance
in the City between consumption and supply. The
proposed regulations would also result in allocating
more water to residential uses than residential uses
currently consume.
5. As indicated in the Executive Summary of the DEIR,
growth displacement from the City will be as a result
of lack of water availability rather than the proposed
regulations themselves. Due to the uncertainty of
future growth policies of the County and other
jurisdictions in the County as well as lack of economic
data, it is not possible to quantify the
growth-inducing effects of Scenario II and III on other
jurisdictions. As a result, a number of assumptions
were made in Section VI-B of the DEIR to define the
parameters of each scenario. There is no reliable data
available to dispute the validity of these assumptions.
6. This alternative has been addressed in Section VII-A,
as "No Project. "
7. Due to the early date of the preparation of this EIR,
evaluation of this alternative was not possible.
-22-
Furthermore, the May 17 Board of Supervisors meeting
concluded with the decision not to .put this proposal on
the November ballot. The Board has asked the County
Planning Director to put together a Blue Ribbon
Committee to evaluate all growth control proposals in
the County and to report back to the Board on June 17 .
The status of the proposal is, therefore, too
speculative to evaluate in terms of its relationship to
the proposed regulations.
Any effort made by the County, however, to control
growth in unincorporated areas in concert with growth
management policies in other jurisdictions would
ultimately slow population growth County-wide and
lessen the population growth pressures on the City of
San Luis Obispo. The reasoning behind this evaluation
is that as the growth in demand for the goods and
services provided in the City slows down,
non-residential and employment growth in the City would
also slow down. Since most persons try to locate in
the same communities in which they are employed, the
slow down in the City's employment growth would result
in a natural decrease in population growth and housing
demand in the City.
8. In the case of this alternative, the City would
continue to grow consistently with the Residential
Growth Management Regulations. This alternative is
identified in the DEIR as Scenario I and as the "No
Project" alternative.
-23- �^
SAi
LUCIA HILLS
May 31 1988
Mr. Mike Multari
Community Development Director
Community Development Department
P.O. Box 8100
San Luis Obispo, CA 93403-8100
Dear Mr. Multari:
For Your review please find enclosed questions and comments on
the March 1988 City of San Luis Obispo Environmental Impact
Report for the the Draft Water Allocation Regulations. I will be
at the public hearing on this matter to receive further
information from staff and the consultant. However, my initial
reactions are that it would be more effective to modify the
existing Growth Management Regulation than to create a new
ordinance. This is because existing regulations restrict growth
(water consumption) nearly as much as this allocation ordinance
would, and secondly the duration of water shortage is currently
unclear.
A year or two from now the general plan update, the airport area
specific plan, annexation policy review, ground water study
(phase 3 & 4) , Salinas Reservoir enhancement study, and the state
water project coastal branch EIR will be complete. With this
information coordinated policies for a long range strategy of
water conservation and development could be formulated.
I- feel .a comprehensive program of water conservation should be a
more significant part of the proposed ordinance. It should be
directed at both new and existing housing and commercial uses `
based on their proportion of water use.
If you have any questions prior to the hearing please feel free
to contact me at (805) 544-3613.
Sincerely,
PD. French _
JDF/po
-24- -6 7
THE CITY OF SAN LUIS OBISPO
Environmental Impact Report
Ref. Executive Summary - Scenarios
COMMENT: SCENARIOS SHOULD BE LABELED ACCORDING TO WHAT THEY
WOULD DO. FOR EXAMPLE:
Scenario I (NO PROJECT) : "Growth would occur within the
City consistent with the Residential Growth Management. . .
Scenario II (PROPOSED PROJECT) : "Growth would occur with
the proposed Water Allocation Regulations in force. . "
Scenario III (WORST CASE) : " Growth would occur with the
proposed water Allocation Regulations. . . "
Ref. Executive Summary - Paragraph 3
"The findings of this study revealed that the proposed Water
Allocation Regulations would have some (WHAT IS SOME?) rj
growth-inducing impacts. . "
COMMENT: 1641 PEOPLE OVER THE NEXT EIGHT YEARS EQUATES TO 700
HOMES OR 80+ HOMES PER YEAR WHICH WOULD BE' TRANSFERRED TO s
OTHER AREAS OUTSIDE THE CITY.
Ref. Executive Summary - Paragraph 5
"For these same reasons (the short-term nature of the
periods of "no growth") the effect of the proposed regula-
tions on the City (GOVERNMENT) economy would be insig-
nificant. ."
QUESTION: WHAT IF THE "NO GROWTH" PERIODS WERE LONGER TERM?
Ref. Executive Summary - Paragraph 6
"While the periods of no growth are actually a result of
lack of water availability rather than the proposed regula-
tions, the Water Allocation Regulations would result in nar-
rowing the existing gap between housing and employment op-
portunities in the City by about 10 percent. "
QUESTION: HOW CAN REDUCING THE SUPPLY OF HOUSING WHILE THE
"COUNTY TRADE AREA" EFFECT TENDS TO INCREASE JOBS NARROW THE
:-� GAP? SEE ALSO COMMENT ON PAGE 39 REGARDING CALCULATION OF
J 10% FIGURE.
Ref. Pg. 1; Para.3
" . . Since 1984, the City has been using more water each
year than its existing sources of supply can provide in a
long drought.
COMMENT: ALARMIST WAY OF SAYING OUR WATER SUPPLY, ALTHOUGH ADE-
QUATE DURING NORMAL RAINFALL YEARS, MAY FALL SHORT DURING
PROLONGED DROUGHT YEARS.
Ref. Pg. l; Para.4
If growth continues unchecked, demand will exceed safe an-
nual yield. . .
COMMENT: POOR CHOICE OF WORDS CONSIDERING WE HAVE A GROWTH
MANAGEMENT ORDINANCE, AND MAJOR PROJECTS HAVE BEEN SUBJECTED
TO GROWTH REGULATION, PLUS THE CITY HAS GROWN AT A RATE LESS
THAN THE COUNTY WIDE RATE OF GROWTH.
Ref. Pg.4 ; Table 1.
COMMENT: IT WOULD HELP TO COMPARE THE RELATIONSHIP OF GROWTH TO
LOCAL, NATIONAL AND INTERNATIONAL EVENTS; I.E. , CAL POLY
EXPANSION, CALIFORNIA MEN'S COLONY EXPANSION, RECESSIONS, 1
ETC.
Ref. Pg. 5
" . . .means .to expand its water resources; however, a sub-
stantial (i.e. , 1, 300 acre-feet per year (AFY) ] increase in
its source of supply is not expected until the 19901s.
COMMENT: WHEN? TWO YEARS OR TEN YEARS? THE LENGTH OF RESOURCE
LIMITATION IS IMPORTANT.
Ref. Pg. 5; Para. 3
" . . . Of the total increase, 66 percent would be reserved
for residential projects (15 percent of this would be allo-
cated to affordable housing projects) and 34 percent would
be allocated to non-residential projects. . "
COMMENT: SHOULDN'T THIS REFER TO EXISTING SUPPLY AS OF 1988?
Ref. Pg-7; Degree of Specificity.
". To work within the time frame for this environmental
impact analysis (ten years) a number of assumptions were
developed to describe existing and future conditions in the
City -and County for which limited data are available. These
assumptions are outlined in Section VI-B. "
QUESTION: IS THERE REALLY A LACK OF DATA ON WHAT DEVELOPMENT
PROJECTS ARE LIKELY IN 1988-1998? THE HOUSING ELEMENT
CONTAINS INVENTORY OF DEVELOPABLE AND POTENTIALLY
DEVELOPABLE GROUND AS WELL AS PROJECTIONS FOR EXPANSION
AREAS. IS THE CITY IN CONTROL OF WHAT HAPPENS IN THESE
AREAS?
-26-
Ref. Pg.10; Table 2. Impact Summary Table
"Scenario I Description" (NO PROJECT ALTERNATIVE) : .
"Water consumption would exceed 110 percent of 1987 SAY by
FY 1990-91 which could eventually jeopardize adequate water
service to existing and new customers. "
COMMENT: DURING PROLONGED PERIODS OF DROUGHT.
"Increase City's long-term sources of water supply by 21291
AFY by FY 1996-97. .to increase water allocation to
residential uses. "
COMMENT: DOES THIS MEAN UNDER SCENARIO II, PROPOSED PROJECT
MITIGATION WILL REQUIRE DEVELOPMENT OF THE COASTAL BRANCH OF
THE STATE WATER PROJECT?
Ref. Pg. 11; Table 2 (cont'd. )
"Scenario II Description" (PROPOSED PROJECT ALTERNATIVE) :
. . . sources of supply. Reference Section IV-C-2.
"Affected revenues are 10 percent less than what the City
would accrue if growth were to continue in the City at an 1
annual average rate of 3.0 percent. "
QUESTION: WHERE DOES THE 3% COME FROM, AND WHY WASN'T THE RATE
IN THE GENERAL PLAN USED, i. e. , 2% DECLINING TO 1% IN THE
1990'S?
"D. CLASS IV - BENEFICIAL PROJECT IMPACTS
. The regulations would achieve a closer balance between 1
housing and employment opportunities in the City.
QUESTION: HOW?
Ref. Pg. 12; Table 2 (cont'd. )
"Scenario III Description" (WORST CASE ALTERNATIVE) : . . . 119
Ref. Pg. 13, Table 2 (cont'd. )
"D. CLASS IV - BENEFICIAL PROJECT IMPACTS
A better balance between housing and employment oppor-
tunities would reduce the number of workers commuting to 2
work in the City. "
COMMENTS: WATER CONSUMPTION IN COMMERCIAL USES IS NOT AN INDICA-
TION OF EMPLOYMENT.
"1/ Implementation of regulations. residential and 39
percent non-residential. " 121
QUESTION: WHO SAYS?
-27- X74
Ref. Pg. 15; Para. 4
"Over the past fifteen years. . .it is reasonable to assume
much of the incoming population settled in and around the
City. "
COMMENTS: WHAT IS THE ORIGINAL SOURCE OF THIS QUOTE? WOULD BE
HELPFUL TO RELATE THIS TO STATEWIDE RATE OF GROWTH AND COM-
PARABLE COUNTY RATE OF GROWTH; i.e. , HOW LONG AND TO WHAT
EXTENT HAS THE CITY BEEN DEFLECTING RESIDENTIAL DEVELOPMENT
TO OTHER AREAS OF THE COUNTY. WON'T THIS EVENTUALLY RESULT
IN LEAKAGE OF COMMERCIAL ACTIVITY WHEN OTHER RESIDENTIAL
AREAS OF THIS COUNTY ARE LARGE ENOUGH TO DEVELOP THEIR OWN
COMMERCIAL CENTERS?
Ref. Pg. 16; Table 3
"City 2/ Percent of Total" (POOR LABELING) 2,
QUESTION: DOES THIS CHART REFER TO JOBS OR RESIDENTS?
Ref. Pg. 17; Para. 2
"Affordability of housing in San Luis Obispo is less than in
the county as a whole. "
COMMENT: HOW DOES THIS DIFFER FROM GOALS OF THE WATER ALLOCATION
ORDINANCE? SEE EXHIBIT A - ORDINANCE.
HOW MUCH LESS AFFORDABLE IS THE HOUSING IN SAN LUIS OBISPO
THAN IN THE COUNTY AS A WHOLE?
Ref. Pg.23 ; Para. Landscape Water Audit.
"Since an inefficient irrigation have been trained to
perform audits. " 2:
COMMENTS: HOW DO YOU CONTACT THESE FOLKS?
"B. PROJECTED CONDITIONS"
COMMENTS: TO REACH THIS POPULATION YOU WOULD NEED APPROXIMATELY
6300 DWELLINGS. WHERE ARE THEY PLANNED? THE 1% HOUSING
ELEMENT SHOWS 1899 UNITS REMAINING IN EXISTING CITY LIMITS
AND 3200 UNITS IN THE EXPANSION AREAS; I.E. , 5100 D.U.
WHERE ARE THE OTHER 1300 UNITS? ALSO DURING THE 40 YEARS IT
WOULD TAKE TO CONSTRUCT 6300 UNITS 775 D.U. WOULD BE LOST
USING HISTORICAL DATA IN YOUR HOUSING ELEMENT. THIS WOULD
TRANSLATE TO 1/3 LESS UNITS THAN YOUR PROJECTIONS ARE BASED
ON.
Ref. Pg. 24; table
Year City Population For Period DU/yr
Pop. Inc.
7/1987 38, 450
1/1990 1.42 yr. 41,212 2767 847
1/1995 5 yr. 43, 314 2102 182
-28- b
O "7I
1/2000 5 yr. 45,524 2210 192
QUESTION: WHY DO YOU PROJECT 847 UNITS PER YEAR BETWEEN 1987-
1990? WHAT WOULD BE THE EFFECT OF CHANGES IN PERSONS PER
DWELLING? I.E. , 10% FALL IN PERSONS PER UNIT WOULD RESULT 2'
IN A 12% REDUCTION IN THE PROJECTED POPULATION GROWTH. IS
THIS CORRECT?
Ref. Pg. 25; Housing Element
"The City growth projections. with a resultant 1990
population of 42, 000. " 2
COMMENTS: THE HOUSING ELEMENT DID NOT MAKE THIS PROJECTION! THE '
HOUSING ELEMENT SAID "ANY PROJECTION BEYOND THE YEAR 1990 OR
ABOVE A POPULATION OF 42, 000 ARE SPECULATIVE. "
"City planning staff anticipates the housing stock will in-
crease annually by 2 . 0 percent from 1987 through 1989 ; 1. 5
percent (263 UNITS) from 1990 through 1992 ; and 1.0 percent
(187) after 1992 due to construction of projects subject to
Regulations. Exempt projects, including Edna-Islay, are an- 12
ticipated to result in an annual additional increase of 100
housing units THROUGH 1992. "
COMMENT: THESE PROJECTIONS SEEM VERY HIGH GIVEN AVAILABLE
DEVELOPABLE GROUND.
Ref. Pg. 25 ; Table
Year Housing Units* HU/Yr for period POP**
r 1986 16, 253 323 .75 38, 195
1990 17, 548 330.00 41, 238
1995 19, 198 2.97. 8 45, 115
2000 20, 637 48 , 497
* Assumes there will be no housing losses. (Not historically
correct. 1987 housing element indicates 19 per year or 266
units 1986-2000. )
** Assumes 2.35 persons per housing unit based on 1985 data in
Housing Element.
COMMENTS: IF PERSONS PER DWELLING WERE TO DROP BY 20% AND THAT
RATE WERE TRANSLATED INTO THE CITY AS A WHOLE THE 4384 UNITS
YOU PROTECT WOULD NOT HOUSE THE EXISTING POPULATION.
Ref. Pg. 26; Para. 3. Projected Water Demand
single family: .40 AFY/unit
multi family: .23 AFY/unit
COMMENTS: 1 DU CURRENTLY REQUIRES .31/AFY. THIS EQUATES TO 1359
AFY TO MEET HOUSING PROJECTION OF 4383 UNITS BY THE YEAR
2000. IF CONSUMPTION DROPPED THE NEED FOR ADDITION OF WATER
WOULD ALSO DROP. SEE ACCOMPANYING TABLE. WOULD ALSO. DROP.
FOR EXAMPLE THE CONSERVATION MEASURES IN APPENDIX "D" WOULD
RESULT IN A SAVINGS OF .08 AFY IN THE SWITCH TO 1.5 GALL-ON
TOILETS VS THE CURRENT MIX OF 3 .5 AND 5.5 GALLON UNITS.
THIS IS A 25.81 SAVINGS. WHEN FIGURES ARE AVAILABLE FOR
LANDSCAPE METHODS EVEN GREATER SAVINGS COULD BE MADE.
-29- �7— 7;z
Reduction AFY/Unit Needed Water 3
10% . 279 1308
20% . 248 1087
30% .217 951
40% . 137 600
Ref. Pg. 31
"application of regulations to government projects. " 132
COMMENTS: SCHOOLS?
Ref. Pg. 32, Para. 3
"Developing housing which is affordable to low and
moderate-income residents rather than more expensive housing
(Housing Element) . " 3^.
COMMENTS: GROWTH IN NUMBER OF DWELLING UNITS DOES NOT CORRESPOND y
TO INCREASE IN POPULATION. NEW HOUSEHOLD FORMATIONS ARE A
MORE ACCURATE INDICATION OF HOUSING DEMAND.
QUESTION: WHAT HAPPENS TO THE PEOPLE WHO DON'T QUALIFY FOR THE
15% AFFORDABLE PROVISIONS BUT CAN'T AFFORD TO PAY THE 30%
PREMIUM LIVING IN SAN LUIS OBISPO NOW REQUIRES OVER OTHER A
AREAS OF THE COUNTY.
Ref. Pg. 35
"Morro Bay. "
COMMENTS: "Integrity of community's character. " PERSONAL 35
OPINION OF MOTIVES.
Scenario I (NO PROJECT ALTERNATIVE) :
Scenario II (PROPOSED PROJECT) :
Scenario III (WORST CASE ALTERNATIVE) : 36
COMMENTS: ADD TITLE FOR CLARITY.
Ref. Pg.36
"Taxes"
QUESTION: ARE PIAN CHECK FEES AND INSPECTION FEES INCLUDED? 37
Ref. Pg. 37
"The historical revenues. . . four percent annual inflation
rate, except for property taxes which increase two percent
annually. " 3F
COMMENT: I QUESTION THIS. COMPREHENSIVE ANNUAL FINANCIAL REPORT
AS OF JUNE 30, 1987 SHOWS 7. 65% ANNUAL INCREASE 1980-87 IN
PROPERTY TAX REVENUES. �-
"For comparison purposes, . .average annual growth rate of
3 . 0 percent for the city. . " 39
QUESTION: WHY DID YOU USE 3%?
. -30- f_ 73
"This analysis will discuss the growth-inducing effects. 40
"
COMMENT: PLEASE EXPLAIN "GROWTH-INDUCING. "
"In calculating water availability . .unpredictable
decreases in water availability. " 41
COMMENTS: WHAT IS THE PROBABILITY OF A SEVERE DROUGHT DURING
THIS PERIOD OF TIME?
Ref. Pg. 38
"The trade area for construction-related businesses. . . in
the short run until the City's water supplies are increased
substantially. " 4
COMMENTS: THIS MAY BE TRUE, BUT EVENTUALLY THEY WILL. MOVE CLOSER
TO THE ACTIVITIES THAT DRIVE THEIR BUSINESS. WHAT HAS HAP-
PENED TO THE CONTRACTORS ASSOCIATION IN SANTA BARBARA?
Ref. Pg. 39
"An analysis of building permit fee. . . This would suggest
that the residential growth section is, and will continue to 4
be '. (as a result of the Regulations) , the best business for
the construction industry. "
COMMENTS: DON'T UNDERSTAND
"Summary. Growth-inducing impacts. The results of the
fiscal analysis should only be used to estimate the mag-
nitude of the fiscal effects of the proposed regulations 4
rather than as absolute values. "
COMMENTS: NOT A VERY CONFIDENT COMMENT.
"Figure 4 illustrates population growth for each scenario
between 1985 and 1997. Scenario I shows the greatest amount
of population growth between FY 1987-88 and FY 1996-97 when
compared to the other two scenarios: 19. 1 percent, while
Scenario III "
COMMENTS: THIS EQUATES TO 345 DU/YR - ABSOLUTELY IMPOSSIBLE
WITHOUT MANY OTHER ACTIONS BY THE CITY.
. . shows the least amount of growth with the implementa-
tion of the Water Allocation Regulations and no increases in
the City's SAY: 5.9 (106 DU/Yr) percent. . . .
"Figure 5 illustrates. . .Although population growth would
stop after 1989 under Scenario III, " 4
QUESTION: HOW CAN POPULATION STOP AFTER 1.5 YEARS AND AVERAGE
5.9% INCREASE FOR 9 YEARS?
"Implementation of the Water Allocation Regulations would
result in mitigating. . . The water Allocation Regulations,
and increases in water availability for new development as
shown in Scenario II, would result in narrowing the gap be-
tween housing and employment opportunities to . 66: 1 (by 10
percent) by 1997."
-31- �� ��
i
COMMENTS: THIS WOULD BE TRUE ONLY FOR THE NEW HOUSING/EMPLOYMENT A
GROWTH NOT FOR EXISTING POPULATION AT 19.1% GROWTH RATE FOR
9 YEARS YOU WOULD HAVE TO CREATE 2820 FEWER JOBS. SURELY
THAT IS NOT WHAT YOU ARE SUGGESTING.
Ref. Pg. 42; Para. 2
"Under Scenario I. . . . growth-related impacts of scenario
I over time. "
COMMENTS: NON-RESIDENTIAL WATER USE AT HIGHER THAN HISTORIC 48
LEVELS. THIS WOULD ASSUME 3229 NEW D.U. OR 358 DU/YR - NO
WAY.
C
-32- __nS
RESPONSE TO LETTER FROM: John D. French
Santa Lucia Hills
May 3, 1988
DEIR Section Numbers Applicable to Comment: Executive
Summary, I-B, III-A-5, III-B, VI-C, VI-D
1. The existing residential Growth Management Regulations
do not have a direct effect on non-residential growth
and have exemptions for some residential developments
(see Section III-B of the DEIR . In 1983, it was
estimated that 39 percent of annual water consumption
was by non-residential uses which are not regulated by
the Residential Growth Management Regulations.
Furthermore, continued development under the
Residential Growth Management Regulations (Scenario I
of the DEIR) would result in greater water consumption
than if development were allowed based upon local water
availability conditions. See Section VI-C of the DEIR
for complete discussion on this issue.
2. Comment noted. The City recognizes the need for the
Water Allocation Regulations in the immediate future
and City staff hopes to implement the regulations in
July. While these suggested studies would shed light
on future water availability conditions of the County,
they remain incomplete. As discussed in Section I-B of
the DEIR, Section 15151 of the CEQA Guidelines requires
that the potential environmental impact of the proposed
regulations be made based on fact rather than
speculation. This approach serves one of the purposes
of CEQA: to assist local decision-makers in making
intelligent decisions on controversial issues.
3 . Such a program currently exists within the City and its
implementation is estimated to result in an annual
water savings of 250 AF. The 1988-89 Annual Water
Operational Plan also includes a five-year water
Conservation Program. In light of pre-existing
measures to conserve water in the city, it is not
necessary to incorporate them within the proposed
regulations. See Section III-A-5 of the DEIR for a
detailed discussion on current City activities to
increase water supply.
4 . Suggested labeling for Scenarios II and III is
misleading. Scenario II simply describes the proposed
project (the Water Allocation Regulations) in a
probable water availability circumstance for the City
over the next nine years. Scenario III describes the
proposed project under an unlikely circumstance of no
new supplemental water sources over the next nine
years.
-33- ���/
5. Paragraph 3 of the Executive Summary continues:
Assuming growth would occur over the next ten
years consistent with the Residential Growth
Management Regulations if the proposed regulations
were not adopted (as indicated in Scenario I) ,
population would be 45,783 in FY 1996-97. The
population difference between Scenario I and
Scenario II is 1, 641 persons. If the Water
Allocation Regulations were adopted, 1,641 persons
who would have located in the City would locate
elsewhere in the County by FY 1996-97. [Emphasis
added. ]
This growth displacement, however, is more a result of
lack of water availability as described under Scenario
II than it is a result of the proposed regulations.
It is possible that some non-residential uses that
would have located in the City of San Luis Obispo would
locate elsewhere in the County as a result of the
regulations; however, there is no economic data
available to support this conclusion.
6. Comment noted. The Water Allocation Regulations would
result in allocating more water to residential uses
than is currently consumed by residential uses in the
City, thus possibly stimulating residential growth.
7 . A longer "no growth" period is described in the DEIR as
Scenario III. Please refer to Section VI-C of the
DEIR.
8 . Non-residential (and employment) growth in the city, in
this analysis, is presumed to be a function of water
availability rather than a function of population size.
[This is a reasonable assumption to make in light of
the fact that today's industries (including retail and
service industries) are becoming more capital-intensive
than labor-intensive. ] Based on the assumptions
identified in the DEIR, the water allocation provisions
of the regulations would result in less water being
allocated to non-residential uses and employment growth
would slow down to a rate below the current estimated
annual rate of 3 . 0 percent. Concurrently, the
residential growth rate would also drop below the
current rate, but not as rapidly as the non-residential
growth rate because the proposed regulations allocate
more water to residential uses than they currently
consume. As a result, the gap between employment
opportunities and housing opportunities in the City is
reduced. See Figure 7 in Section VI of the DEIR.
-34- ?-77
Another scenario that may be considered is the
possibility that, as the City's trade area (the County)
continues to grow at a faster rate than the City, local
businesses would hire more •employees to meet increases
in demand for local goods and services. In this
regard, employment growth would be a function of the
County's population grwoth.
The economic data to support this scenario does not
exist. A market study to assess local thresholds of
demand and business efficiency would shed a great deal
of light on the real impacts of the proposed
regulations on the City's economy. Furthermore,
implementation of the regulations is expected to be of
short duration until new water sources become available
to the City. Significiant local employment growth to
meet demand of the trade area in this short time frame
may not be required.
9. Please refer to the 1988-89 Annual Water Operational
Plan for further discussion and explanation of this
concept; Discussion of this concept herein falls
outside of the scope of this EIR.
10. The City's Residential Growth Management Regulations do
not address non-residential growth in the City and have
exemptions for some residential uses (see Section III-B
of the DEIR) .
11. If such comparisons were made, conclusions drawn would
yield little benefit to this analysis due to the
unpredictability of local, national and international
events on the economy during this and the next state
and federal administrations.
12. It is unknown when substantial sources of supply will
become available to the City.
13. In 1983 it was estimated that water consumption in the
City was 61 percent residential and 39 percent
non-residential; it is presumed that this estimate is
still accurate and will be until the proposed
regulations are implemented. Only new water sources
will be subject to the 66/34 percent water allocation.
14 . The list of assumptions listed in Section VI-B of the
DEIR relate more to the economic characteristics of the
City than to its geographic characteristics and
development policies. The existing and future
conditions for which limited data are available are
those related to City employment, the City's trade
1 area, the inventory of existing City businesses and
,J their patronage, etc. There is control over future
development of the City; however, data that can shed
light on the impacts of development on the City's
private and public sector economies are not available.
-35- ,Q�7�
15. If water consumption were to continuously exceed 110
percent of the 1987 SAY while growth was allowed to
continue, adequate water service to existing and new
customers would be- jeopardized under any climatic
condition. For instance, to support 3 .0 percent
residential and non-residential growth rates, water
demand would also increase 3 .0 percent annually. If
water supplies are not concurrently increased, water
service to all customers would be jeopardized.
16. The Coastal Branch of the SWP would be one means by
which the City may increase its long-term source of
supply out of all those identified in Section VI-D of
the DEIR.
17. Refer to Section VI-B-1 of the DEIR. For comparison
purposes, affected revenues for the City were also
projected assuming a continuous average annual growth
rate of 3 . 0 percent for the City (see Appendix E) .
This growth rate more closely reflects a continuation
of the City's historical growth rate for
non-residential development without consideration for
existing growth management policies.
18. See Section VI-C of the DEIR and comment #8 above.
19 . See discussion for comment #4 above.
20. In general this is true; however, analysis of the
City's employment and non-residential water consumption
for the past ten years has demonstrated a correlation
between non-residential water consumption in the City
and job opportunities. Since the DEIR assumes that the
employment profile of the City will remain unchanged
for the time frame of this analysis, the abovementioned
correlation between water consumption and employment is
justified in the study.
21. In 1983 City staff estimated water consumption to be 61
percent residential and 39 percent non-residential.
Refer to Section III-A-C of the DEIR. The Water
Allocation Regulations propose a 66/34 percent
allocation split for supplemental water resources.
22. This quote is a reasoned deduction of the
aforementioned references in paragraph 4. This quote
is also supported by historical population data of each
incorporated City within the County between 1960 and
1985.
Analysis of historical growth patterns and growth
inducement on other areas of the County as a result of
City policies is outside of the scope of this EIR.
-36- O _�C
23 . The entire table, entitled "Employment Estimates . . . "
refers to the number of employees in the City as
compared to the number of employees in the County.
Labeling is standard practice for all documents per A
Manual for Writers by Kate L. Turabian.
24 . The Water Allocation Regulations will help to
facilitate construction of affordable housing in the
City by setting aside 15 percent of the residential
allocation for affordable housing projects. It is not
the goal of the proposed regulations to achieve more
affordable housing in the City although it may be a
by-product of the regulations. Detailed analysis of
affordable housing in the City is outside the scope of
this EIR.
25. Contact City Hall.
26. City staff has determined that an additional 5, 700
dwelling units would be required to serve a population
of 53 ,000. According to the Housing Element, these
dwelling units could be accommodated as infill projects
and through City expansion into the Urban Reserve.
27. This comment is outside the scope of this EIR and is
deferred to City staff.
28 . Comment noted.
29. Based on the General Plan and projected population
densities, the Urban Reserve and the City is estimated
to accommodate a population of 53, 000 (see Section
III-B of the DEIR and comment #26 above) .
30. Comment unclear. This projection assumes a population
increase of 10,302 persons between 1986 and 2000 with
an associated increase in 4,384 housing units. The
number of persons per unit is assumed to remain a
constant 2.35. This analysis assumes all housing units
destroyed will be replaced and not result in any
increases in population or water demand.
31. Comment noted.
32 . Public schools would be exempt from the proposed
regulations.
33 . The analysis assumes a constant vacancy rate and
household size for all housing types, so the number of
dwelling units in the analysis is a function of
population. In reality, the rate and size may change
slightly over time; however, within the short time
frame of this analysis, the change would be
insignificant.
-37- Q� O�
34 . City staff determines that there would be a
continuation of recent trends whereby the market guides
housing costs in the City. Adoption of the Water
Allocation Regulations, however, could provide a
stimulus for producing housing for low and moderate
income persons that does not now exist.
35. Comment noted.
36. See comment #4 for discussion on this issue.
37. Such fees are nested within the City's budget under the
category of "charges for current services" and could
not be broken out as a separate line item. It should
be noted, however, that the DEIR emphasized the
magnitude of difference in revenues between the
scenarios rather than the absolute value of the
revenues under each scenario.
38. The County of San Luis Obispo is permitted to increase
property valuation by 2. 0 percent annually to adjust
for inflation. The 7. 65 percent annual increase in
property tax revenues between 1980 and 1987 reflects
the increase in housing valuation upon resale as well
as the annual 2.0 percent inflation rate. See Errata.
39. This figure was provided to the consultant by the City
to use for comparison purposes and reflects the average
non-residential growth rate in the City during recent
years. This figure also reflects a potential maximum
growth scenario for the City which would not be
constrained by water supply.
40. As discussed in Section III of the DEIR, Section
15126 (g) of the CEQA Guidelines defines growth-inducing
impacts of a project as those project-related impacts
which may directly or indirectly foster population and
economic growth as well as housing demand elsewhere in
the City and surrounding area.
41. City staff has determined that the probability of a
severe drought lasting for six years is one-in-ten and
one lasting for three years is a certainty.
42 . Any reduction in the City's growth rate, including no
growth periods, would be the result of lack of water
availability rather than the proposed Water Allocation
Regulations. The DEIR suggests that, in Scenario II,
the periods of no growth are so short that local
businesses would not find it economically advantageous
to leave the City and relocate elsewhere in the County.
-38- �j�/
43 . Historically, housing development proceeded at a more
rapid rate than non-residential development; analysis
of the City's building permit fee records suggest that
the focus of the local construction has been on
residential uses.
44 . Comment noted. The lack of economic data on the City
makes it very difficult to assess the fiscal impacts of
a development moratorium or growth slow-down on the
City. A thorough survey of local businesses and their
trade areas would shed more light on the fiscal impacts
of no growth on the City.
45. This equates to [ ( (45,783 - 38,450)/9)/2 .35] 347
dwelling units per year for Scenario I. Scenario I is
characterized by growth within the City consistent with
the Residential Growth Management Regulations (see
Section III-B-2 of the DEIR .
46. The percent change in population between FY's 1987 and
1996 for Scenario III is [ (40,737-38,450)/38,450 =
0.059] 5.9 percent. Please refer to Table 11 of DEIR.
47 . The 19. 1 percent change in population for the time
frame of this analysis is only for development under
Scenario I in which the Water Allocation Regulations
would not be in effect (see Table 7 of the DEIR) . See
comment #8 above for discussion on the effects of the
Water Allocation Regulations on future residential and
employment growth in the City.
48 . Refer to Section III-B-2 of the DEIR for a description
of residential growth in the City under the Residential
Growth Management Regulations. This description
reflects the potential outcome of housing development
in the City if it is consistent with the Residential
Growth Management Regulations.
-39-
MF�NG ' AGENDA
RECEIVED DA �w20 les M
E C E I V E &AY 91988 to ,� T.;u' n
cera .L—o Q �e
� MAY 181088 �.,T,n,,,, �, Dennis W. Tewes '^r'•�,�-7'
1690 Cordova Drf�wlp
WILLDAN ASSOCIATES San Luis Obispo, California 93401
VENTURA B y/6Mai1v
City of San Luis Obispo
We attended the City Council meeting on Tuesday, May 3, 1988, specifically to
comment on the Environmental Impact Report (E.I.R.) for the Draft Water
Allocation Regulations; however, time ran out before it could be discussed.
Therefore, I will try to put my comments in writing for the City Council's
consideration.
First, I would like to provide some thoughts on water conservation/alternatives
as discussed by the Council Tuesday night.
1. From figures provided in your E.I .R. , San Luis Obispo uses an average
of 7,720,000 gallons of water per day (page 29 - 8,650 AFY) . Residential
use is 61% of consumption (page 18) and outside use is 42% of that
(Appendix D, Paragraph H) ; then 26% of all water consumed in S.L.O. is
for landscaping and other outside uses. This amounts to approximately
2,000,000 gallons per day. A savings of only 1% (25% versus 26%)
represents 77,000 gallons per day, so you can see it would mount quickly.
Now, several people addressed this at the Council meeting, odd and even
watering days, sprinklers aimed in the proper direction, etc . But no
one addressed not watering during the day when the sun and the wind cause
unnecessary evaporation. Why not limit whatever landscape watering that
is allowed, to nighttime only:
In addition, we have excellent experts in agriculture and irrigation at
Cal Poly, why not consult with them for watering durations (i.e. are
two 5 minute durations better than one 15 minute duration) , best times of
the day for watering, durations between watering (i.e. 2 days, 3 days,
whatever) , etc .
2. All restaurants in S.L.O. should discontinue serving water unless
specifically requested.
3. Ornamental fountains and drinking fountains should be shut off.
4 . Other cities in California have implemented water saving ideas. Ask
them which are most effective and, if they apply to our city, either
implement them or keep them in reserve for possible additional (future)
savings.
Next, I would like to address your E.I.R. which, by the way, was well written
and informative. However, as I read the E.I.R. , questions arose that were not
covered, and in order to properly integrate all the facts and data and arrive
at the correct conclusion, these questions should be answered.
1 . Accuracy of present reservoirs capacity and S.A.Y. require that siltation
be addressed, or if soundings were taken recently, when were they.
Confidence in our water supply estimates must be established and then
2
-40- � �r.
v
Page 2
2
the top bullet item listed on page 38 could be eliminated.
2. Our present water treatment facility was sized for a certain capacity--
what is it and what is our current load on it? Can it handle the
increased usage?addressed in the E.I.R. without capital improvements?
Will existing transmission lines from the reservoirs and the distribution
lines from the water treatment facility handle water increase? If capital
improvements are required, what is their estimated costs and how will the
revenue be covered (i.e. will the city pay for them out of their increased
fiscal revenues from additional housing/employment?) The second bullet
item, page 37, states most costs to develop new supplies would be borne
by new development" but "operations and maintenance costs will be borne
by all customers."
3. Adjust your assumptions to account for present drought conditions. Page 4
37, bottom bullet states "There will be no severe drought conditions
between 1988 and 1997."
4. Total projected water use for May 1, 1988, page 29, is 8,650 AFY.
Preliminary figures should be available now for comparison to see if
we're on, over or under projected usage. As 8,650 AFY is the starting
point for your various scenario projections, it's important to verify
it's accuracy. Then, too, while construction has been active, what with
new motels, the new mall and all the new housing; is it still bearing
out your projected use of 250 AFY as shown on page 29.
5. Based on my calculations using figures from the E.I.R. , 8,650 AFY current
usage (page 29) equates to an average of 7, 720,000 gallons per day, every
day of the year. Subtraction of outside residential water use for
landscaping, etc. , 2,000,000 gallons per day, leaves us with 5,720,000
gallons per day. Estimated additional outside water usage for commercial ,
hotels/motels, etc. is another 10% of our total consumption, leaving us
with approximately 5,000,000 gallons per day of waste water that our
sewage treatment facility must process. As our sewage treatment facility
is sized for processing 5,000,000 gallons per day then it only stands to
reason--increasing our water supply/consumption will directly affect
capital improvements at our sewage treatment plant.
Once again, will the city pay for the necessary increase in sewage capacity 1 7
out of their increased fiscal revenues? (Same question as in item 2.) Jj
I would appreciate you making the Council aware of these questions as well as
your responses. If I can be of any further value, please feel free to call on
me.
Respectfully,
ennis W. Tewes
Registered Professional Engineer
—41— �_ p�
RESPONSE TO LETTER FROM: Dennis W. Tewes, P.E.
San Luis Obispo, California
DEIR Sections Applicable to Comment:
1. Comments noted.
2. The issue of siltation is addressed in the City's Water
and Wastewater Management Element. Siltation was not
addressed in the EIR because its annual effect on water
availability for new development would have been
minimal for Scenarios I and II. The siltation factor
would have had a more detrimental effect on the results
of Scenario III and length of the no-growth period
identified in the scenario.
3 . Since the EIR focuses on the growth-inducing effects of
the Water Allocation Regulations, this comment is
outside the scope of the EIR. Furthermore, the
regulations are designed to allocate increases in the
City's water resources as they become available and
will not, themselves, generate demand for water.
4 . This assumption was developed in order to simplify the
preparation of this environmental report for a complex
problem. . In so doing, the consultant and City staff
developed parameters for this study in order to avoid
speculation on the year-to-year availability and demand
for water under adverse conditions. Available past and
present data on water usage and availability in the
City were used for this report. Although the City may
currently be in a drought condition, it would be too
speculative to project this condition beyond 1988 .
5. This report was prepared in the fall of 1987 using the
projected water demand for fiscal year 1987-88 of 8, 650
AFY. City staff has recently determined that water
consumption for FY 1987-88 was 8,658 AF (8 AF greater
than projected) . Nonetheless, this figure is not
relevant to the EIR which is to assess the
growth-inducing impacts of the Water Allocation
Regulations.
6. Comment noted.
7 . General discussion provided under comment #3 above
applies herein.
-42-
1 .
p4Yj
POTENTIAL WATER-SAVING FEATURES
(In additional to those required by codes effective 7-1-88)
All Applications
Ultra-low-flush toilets (maximum 1.5 gallons) or use of non-potable water for
flushing
Probited: a water body, supplied by potable sources, with a surface area greater than
1,000 square feet exposed directly to the atmosphere
Aoolications with g_n irrigated turf area greater than 10.000 souare feet gr li total
irrigated landscape area greater than 40.000 s ware feet
A water source for irrigation other than potable city supply
Applications for single-family dwellings
Lawn area not to exceed 500 (or 1000?) square feet, or use of non-potable water for
irrigation
Applications for multifamily dwellings
Lawn area not to exceed 250 square feet per dwelling, or use of non-potable water for
irrigation
Applications for hotels. motels, rou quarters. congregate housing
Circulating hot-water system
gm4/war-wsf
THE PACIFICA CORPORATION
July 8 , 1988
The Honorable Mayor and City Councilmembers
City of San Luis Obispo
990 Palm Street
San Luis Obispo, Ca. 93401
Subject: Water Allocation, Islay Hill Development
Dear Councilmember:
In view of the upcoming City Council meeting on July 19 , 1988,
concerning water allocation issues, which include the possibility
of a moratorium, the Pacifica Corporation has several major
concerns that we wish to express.
Although we are certainly concerned about possible water shortages
and the detrimental effects of a moratorium on the City as a whole,
we will specifically address only those issues related to the Islay
Hill development projects.
As you are aware, the projects at Islay Hill are part of the
approved Edna-Islay Specific Plan which was approved in 1982 . This
plan called for the orderly buildout of the area over an 11 year
period and called for very substantial public improvements to
insure the development entitlement delineated in the seven phases
of the plan. At this point in time nearly six years after approval
of the plan, The Pacifica Corporation will soon build its first
homes . Tract 1376,. a 131 unit residential subdivision, is the
first phase of the Islay Hill project and is due to record next
month. Our primary concern is that sufficient water be allocated
at the present time for Tract 1376, and that a phased water
allocation be provided for the remainder of the development.
As a part of the Islay hill projects, the Pacifica Corporation has
expended nearly $3 million in the construction of major public
improvements which benefit the City as a whole. These improvements
include:
-a new arterial connection from Highway 227 to Orcutt Road;
-a railroad overpass for Tank Farm Road;
-the Bullock Lane waterline; and a
-regional stormwater detention basin.
200 NORTH WESTLAKE BLVD..SUITE 200•WESTLAKE VILLAGE.CALIFORNIA 91 362 •(805). 495-9494 —V
The Pacifica Corporation has committed its financial resources to
the installation of these public improvements in return for the
construction of future housing for City residents. We believe that
the City, through its approval of the Specific Plan, tentative
tract map, and the public improvement plans, has in turn committed
itself to the Islay Hill project. We ask that this commitment be
honored by providing present and future water allocations .
During past deliberations on water issues, Staff has consistently
recommended that a basic amount of water be set aside for the Edna-
Islay area. If the Council cannot at this time guarantee a full
set-aside allocation for the entire development, it is imperative
that Tract 1376 proceed at this time while an allocation plan is
refined for the Edna-Islay Area. With progress being made in
developing groundwater as an additional source, and other studies
showing promise with the Coastal Streams Diversion Project and the
Salinas Dam Enlargement Project, a moratorium at this time is
uncalled for .
To assist in the overall effort of water conservation, we will
voluntarily investigate innovative measures in our development,
and in the near future will be submitting a set of proposed
specific plan amendments to the City. As a part of these
amendments we will include measures which the Pacifica Corporation
will employ to reduce water use, and a plan for the City to
consider in relation to a phased program of water allocations.
We appreciate this opportunity to provide input to this important
issue. We know that there is much for the City to consider and it
is important to us that a cooperative and realistic attitude
towards resolving the water and growth issues be maintained. Thank
you for your consideration of our viewpoint in this matter.
Sincerely,
i
�' Q'ti`RS
J
William J. Coghlan
Vice President ; Projects Director
8�U
Vul� /, lIVJ
Mayor Dunin and City Cot 1 Members,
I find that I must recormend to you an immediate moratorium on supplying City water
to new landscaping and to new building projects that will take additional City water, for
reasons that will be explained below. For 11 years, I have worked to get enough water
to allow development of essentially all land within the City Limits through good planning,
grater conservation, good water management, and the drilling of wells,. and I have looked at
a variety of other options. But I largely failed in my goal as indicated above, and below.
Eleven years ago, City Staff stated all the land within, the City limits could be
developed with: only a 94 conservation, or by the drilling of wells. (Water for 42,000
people, land for 46,0CC. people )
Now it appears that we have water for 40,000 people, and land for 48,000. people,
or a water shortage of 204 (1,471. Ac Ft. ), so a long term moratorium appears necessary
in addition to a short term moratorium. (Plus we need water for growth in tourism R• b+isines;
. The City is in a serious short term and a long term water crisis, with no significant
solutions to the problem in sight for the next ten years. The City's well drilling
program doesn't seem to be working out as expected, and the City's water conservation
program has been worse than nullified by the City's mismanagement of its growth and
its water consumption, as will be explained below. The City's pro-growth City Council
turned down its chance to wet Kacimiento water in 1974, in favor of a long shot on
State Water. Santa Barbara County voters rejected State water in 1979 by votes of
2/1 to 3/1 in opposition and prevented our County from getting it. FLO County is
unlikely to wet State hater in less than 12 years, and we may never get it. Nacimiento
is our best potential Vater source, is popular with the public, is the -most reliable and
of the best quality, and it would be under local control. But it takes the cooperation
of County Ooverrment, who is putting all its eggs in the State Water project at this time.
The City's water supply is in a critical condition for both the short term as well
as the long term even though we have had only 1i years of semi-drought conditions, while
37 years ago we had a similiar drought which lasted 6 years. The City's 45,643 acre-feet
of reservoir storage has gone from full to about 22,500 acre-feet in about 15 months, and
5,250 acre feet of that must not be used as it must be saved for fish and wildlife, and
it has poor quality. So the City has about 17,251 acre feet of useable water left to
last 4J years, if we were to have the drought continue as it did 37 years ago. The City
is using water at a rate of about 8114 acre feet per year plus a large evaporative loss
off the reservoirs, so the City now has less than a 2 year water supply left.
Your staff's 1988-1989 Annual Water Operation Plan indicates that under such condition:
the City should go to 50% water conservation (rationing) within another 12 months unless
the rainfall is much improved over what it has been the last two years. That would mean
r
no water for irrigation of landscaping except for the reuse of bath and other household
water. It would mean we would have to discourage tourists and others from visiting the
City.
If we didn't get better rains the 4th winter of a drought, then the City would �(
pretty much close down except for bare survival. State Water has a similar problem. U
The City was supposes to have a water supply wMah era.- supposed to last 6 ,years
without conservation. What happened to it?
1) Three years ago the City :Taff informed the Council that the -City was exceeding
it 's safe annual yield and that ;.here was no more water left for buildirp that took
more water. City Council proceeded to allow as much as 1133 of over draft per year, and
it is now at 1103 + level if Cal Poly water is not used for City development purposes.
2) The new growth is reported to be requiring about 503 more water per capita because
of a large increase in water use by non—residents (tourists, :Hotels, resttlrants, new
,jobs, and new shoppers),
3) The City does not allow drought resistant plant m to be used in 803 of the
front yards of the several hundred new homes being. built and occupied in the Fdna—Islay
Summerhills tracts, but instead requires that 803 of the front yards be put into
water hungry plants, and the developer gives a rebate of $500. if they put the grass
in within 6 months. This is entirely contrary to a good water conservation program.
In this drought year, the City converted a new park from natural vegetation to a
all developed park with a large amount of irrigated grass, supe"ed by City water.
This action is contrary to good management in the second year of a drought, and contrary
to 25% and 50% water conservation requirements. Well water or recycled water should be
be considered. (Park at end of San ndriano St. )
This year the City plans to develope a new 10 acre park in the Bina—Islay area using
City water, as well as other landscaping in that area. This should be deferred unless
can be put on well water or recycled water. To develope it otherwise would be contrary
to critical City conservation objectives.
The City should have a policy of not mismanaging it 's water resources, the above
are only examples, and probably the tip of the iceberg.
The City's water supply is as follows:
Salinas R. 4800. AF (probably over rated because of two errors in the safe
annual yield report (Down Stream release error; and error
assuming that one should drain reservoir dry. )
Whale Rock 2057 AF (In 1974, a new eele arnaal yield report indicated that
SLO should only expect 42% of what had been previously
promised)
Coop Use 500 AF
7357. AF (Not courting Cal Poly water for which SLO has no rights. )
The City is using 8114 AF (Not 'eourting Cal Poly water) Overdraft of 757 AF/yr, (110'
So I strongly recommend that the City's Mayor and City Council immediately bite the
bullet and make some good decisions for a moratorium, as have Santa Barbara, Goleta,
Pismo Beach, and the Board of Fupervisors for Avila, Cayucos, San Simeon; and they are
in process for Cambria and Templeton.
�Sincernel'y,
NX. .
Do__n�a�llddd I.
1.111 Vista Lago
SLO, Ca. 93401 Tel. 543-1343
U. DANN TORRANCE N!t r I INU AULAIVA Y
Professional Enuineer D; _ JUL 19 Be ITEM # d
July 16, 4�notes action by law Person
Resvond by:
i
Mayor Ron Dunin and Council Members ��R
City of San Luis Obipo R E C E I �04
San Luis Obispo, California
JUL 18 1 �'��'� '
CITY CLERK
Dear Mayor Dunin and Council Members:----.----,
embers:--_,\ SAN LUIS OBISPO,CA
BUILDING MORATORIUM
I believe it to be mandatory that_a. building moratorium be placed
in effect until absolute knowledge is available on water supplies,
AND the ability of the city to properly handle sewerage and wastes
for the present population of this city. This would 'include the
manner in which needed improvements are to be made, and a
reasonable method of financing these needs.
It is not acceptable to allow continued new construction without
knowing precisely how water and sewerage will be handled, the
assets required, and the financing method.
I am sure most residential property owners, who do not have a
personal financial interest, would share this view.
I would appreciate it actions of the City Council would support
this view.
Sincerely,
Z
U. Dann Torrance
CONSULTING
ALL PHASES OF
INDUSTRIAL ENGINEERING AND PRODUCTION MANAGEMENT 77 HIGHLAND DRIVE
REAL ESTATE. APPRAISALS SAN LUIS OBISPO. CA 93401 905/541-2033
MEETIk AGENDA
DATE J°Le 88 ITEM #
/ San Luis Obispo Chamber of Commerce
1039 Chorro Street • San Luis Obispo, California 93401 • (805) 543-1323
David E. Garth • Executive Manager
*Denotes action by Lead Person
RECEIVED Respond by:
Council
J U L 15 1988 CAO
July 14, 1988 CITY CLERK A,eCrty Atty.
SAN LUIS OBSPO.CA Clerk-orifi.
00716VD
Honorable Mayor and Councilmembers
City of San Luis Obispo
P.O. Box 8100
San Luis Obispo, CA 93403-8100
Dear Mayor and Councilmembers:
The San Luis Obispo Chamber of Commerce concurs with City
staff in its recommendations re: the Water Allocation
Ordinance, scheduled on your,agenda of July 19th. We feel
it is prudent to certify the EIR for the Allocation
Ordinance and adopt the ordinance. We also approve of
staff's sentiment that groundwater not be counted as a
source of additional supply until any necessary
environmental review has been completed and plans and
specifications approved. We additionally request that the
ordinance be adopted with a built-in review of it scheduled
for your first meeting in January of 1989.
We come to our position of support with great reluctance.
While we are encouraged by the City's current aggressiveness
in groundwater development and sympathetic to the shortage
situation, we are nonetheless disheartened by the lack of
committed planning that has brought us to this point.
Over the last decade, City staff has continually devised
long range planning policies which could plot out a firm
future for San Luis Obispo. City councilmembers
historically have chosen to accept philosophical rates of
growth for the community, yet have not taken the steps
necessary to plan for the resource needs of that growth.
Repeatedly, councilmembers have disregarded staff
suggestions and have refused to commit to the actions
necessary to fortify our future.
While a building moratorium may be inevitable, we ask you t
direct staff to do everything possible to avoid one.
Specifically, we are proposing four points of action for yo
to undertake:
ACCREDITED
Cn�YB[q Of CW11[•Ci
c..o,.o• co,...uu
SLO Mayor and City Council Page 2 July 14, 1988
1. Expedite the development of all groundwater sources.
2. Aggressively work on the possible expansion of Salinas
Reservoir.
3. Immediately begin discussion with Cal Poly to "borrow"
surplus capacity from them for the near term.
4. Investigate the coastal stream diversion possibilities.
We believe that the Council must accept its role as the
policy makers of San Luis Obispo and take the necessary
steps to keep San Luis Obispo healthy. We implore you to
keep us from a building moratorium, and we feel that the
four steps outlined above provide a mechanism for achieving
that end.
San Luis Obispo needs to take a hard look at its future
needs and plan now for them. Let's decide what our future
is to look like, then devise the means to achieve it. We
hope that the current revision of the General Plan will be
seen as an opportunity to achieve these ends. We are
anxious to help in any way we can.
Best regards,
6#t4- 17
4Byrs Conrad
Chamber Presient
MEETIP' AGENDA
Band delivered by Don Smith DATE JUL to 88
Tuesday, July 19, 1988 ITEM #
(Dene Lead Personater given TT
to developers ►'dTo theeditor: oRECEIVED � • Mayor Duma and the City Council
I : have taken away 10 percent of the
JUL 9 ia water rights of each resident and
Crry CLERK most businesses In San Luis Obispo
SM LUIS r0Sao.CA � ./ in order to give those rights to
1 developers. I
There are indications that poor
city management has allowed even
more of our water to disappear.
-.More Letters
I
Water rates have doubled to eacoar-
age as to reduce our water coo-
sumption by 25 percent, and we
may need water rationing next year
in the hope that our reservoirs won't
run dry if the drought continues.
The city's water conservation pro-
gram has come too late to achieve
real effectiveness at minimum coat,
because of inadequate attention by
city management, Mayor Danin, j
- and the City Council
For years, Mayor Dunin and the
manager of the city's Public Works
Department have argued that the
-city has plenty of water for more
development,and that the city could
obtain adequate �oand water from
beneath the qty!t
an extended drought. The city's
recent well drilling program has not
proven very successful,
The Community Development De-
partment seems to be continually
advocating giving developers more
water for speculative growth than
the city has by taking It away from
all existing residents of the city. Do
YOU want to give up more of your
water to developers? Do you want
to pay higher water bills and forced
conservation to faster more mis-
management and a lack of good
planning? Mayor Dunin and the City
Council should make some difficult,
` but very important decisions start-
ing July 19. They need to bear from
the general public, because the de-
velopers and Chamber of Com-
merce will be there wanting more of
your water.
Donald I.Smith
San Luis Obispo
v"-7ING AGENDA
lltl fE JM 19 ,86
THE PACIFICA CORPORATION
Denotes action by Lead Person I
RECEIVED I Respond by:
Lo-ff Council
July 8, 1988 JUL 0 b 1988 M
CITY CLERK So ff CAy AlrY'
9AN LUIS OBISPO.CA Clark-o j8_
The Honorable Mayor and City Councilmembers &: � ro
City of San Luis Obispo 0. �aAa�
990 Palm Street
San Luis Obispo, Ca. 93401
ni/e�
Subject: Water Allocation, Islay Hill Development
Dear Councilmember:
In view of the upcoming City Council meeting on July 19, 1988,
concerning water allocation issues, which include the possibility
of a moratorium, the Pacifica Corporation has several major
concerns that we wish to express.
Although we are certainly concerned about possible water shortages
and the detrimental effects of a moratorium on the City as a whole,
we will specifically address only those issues related to the Islay
Hill development projects.
As you are aware, the projects at Islay Hill are part of the
approved Edna-Islay Specific Plan which was approved in 1982 . This
plan called for the orderly buildout of the area over an 11 year
period and called for very substantial public improvements to
insure the development entitlement delineated in the seven- phases
of the plan. At this point in time nearly six years after approval
of the plan, The Pacifica Corporation will soon build its first
homes. Tract 1376, a 131 unit residential subdivision, is the
first phase of the Islay Hill project and is due to record next
month. Our primary concern is that sufficient water be allocated
at the present time for Tract 1376, and that a phased water
allocation be provided for the remainder of the development.
As a part of the Islay hill projects, the Pacifica Corporation has
expended nearly $3 million in the construction of major public
improvements which benefit the City as a whole. These improvements
include:
-a new arterial connection from Highway 227 to Orcutt Road;
-a railroad overpass for Tank Farm Road;
-the Bullock Lane waterline; and a
-regional stormwater detention basin.
200 NORTH WESTLAKE BLVD.,SU ITE 200 •WESTLAKE VILLAGE.CALIFORNIA91362 •(805)495-9494
The Pacifica Corporation has committed its financial resources to
the installation of these public improvements in return for the
construction of future housing for City residents. We believe that
the City, through its approval of the Specific Plan, tentative
tract map, and the public improvement plans, has in turn committed
itself to the Islay Hill project . We ask that this commitment be
honored by providing present and future water allocations.
During past deliberations on water issues, Staff has consistently
recommended that a basic amount of water be set aside for the Edna-
Islay area. If the Council cannot at this time guarantee a full
set-aside allocation for the entire development, it is imperative
that Tract 1376 proceed at this time while an allocation plan is
refined for the Edna-Islay Area. With progress being made in
developing groundwater as an additional source, and other studies
showing promise with the Coastal Streams Diversion Project and the
Salinas Dam Enlargement Project , a moratorium at this time is
uncalled for.
To assist in the overall effort of water conservation, we will
voluntarily investigate innovative measures in our development,
and in the near future will be submitting a set of proposed
specific plan amendments to the City. As a part of these
amendments we will include measures which the Pacifica Corporation
will employ to reduce water use, and a plan for the City to
consider in relation to a phased program of water allocations .
We appreciate this opportunity to provide input to this important
issue. We know that there is much for the City to consider and it
is important to us that a cooperative and realistic attitude
towards resolving the water and growth issues be maintained. Thank
you for your consideration of our viewpoint in this matter.
Sincerely,
William J. Coghlan
Vice President ; Projects Director