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HomeMy WebLinkAbout05-25-2016 PC Correspondence Item 01 (Cooper)From: Allan Cooper < Sent: Sunday, May 22, 2016 7:25 PM To: Floyd, Aaron; Metz, Jennifer; Advisory Bodies Subject: Review and Provide Recommendations on Amendments to the General Plan - Chapter 8 Attachments: 105_22_16... waterreport.pdf Dear Aaron and Jennifer - You both did a commendable job revising and adding to the Water and Wastewater Management Plan! As you would expect, I still have a few suggestions to make. In this regard, would you kindly forward the attached letter to the Planning Commission before their meeting on Tuesday? Thanks! - Allan Date: May 22, 2016 To: Planning Commission Re: Review and provide recommendations on amendments to the General Plan, Chapter 8, Water and Wastewater Management Element and the 2015 Urban Water Management Plan From: Allan Cooper I would like to commend the City's Utilities Department for their extraordinary efforts in drafting this Water and Wastewater Management Element Amendment and 2015 Urban Water Management Plan. I believe that we should anticipate a future where uncertainty and extreme weather will become the norm (if it hasn't already) and I, like the Utilities Department, believe that the long-term historical record should no longer be considered a good indicator of future conditions. I am, therefore, asking for a more conservative approach in addressing our water shortage contingencies. My recommendations involve ratcheting up the constraints that this draft document has placed on future water consumption and future development. The major thrust of my critique is of the "Water Shortage Response Stages" though these "stages" have been modified and much improved since they were first made available to the public. Because this is a rather complex and formidable report, I am formatting my critique as follows: The following text in quotation marks comes directly out of staff's recommendations and follows the chronology of this report. These are followed by my comments in bold type. "This water use rate (gpcd) includes all existing water demand (residential, commercial, institutional, landscaping, water used for firefighting, and water loss within the water distribution system) in the City for the year divided by the City's population. The current rate is 114.4 gpcd, down from 123.2 gpcd in 2009, as cited in the 2010 WWME. Using the per capita potable water use rate allowed by SB X7-7 (117 gpcd) is a more conservative approach as the 10 -year average will be influenced by drought years where the City can experience a significant reduction in potable water demand, such as 2015 when the City reduced its per capita usage to 92 gpcd under the statewide drought declaration." Wouldn't we want the 10 -year average to be influenced by drought years? Wouldn't the 10 -year average be more conservative (i.e., more conservative than the previous 10 -year average of 123.2 gpcd) because drought related rationing would result in water demand less than 117 gpcd? Even though 117 gpcd is the maximum allowed per capita water use under Senate Bill X7-7 and is also the lowest in the State, Target Method 1 of 98 gpcd ought to be used instead in light of future extreme drought scenarios. " The City will continue to use groundwater for domestic purposes when available., but will not Gonsider this c0-1irnc..-f 661pply as mart of ,tom ,..tet©,.-re,eavailability. Groundwater "...remains a viable option for future use and proposes the following policy language" Why? Wouldn't elevated nitrate and tetrachloroethylene levels combined with costly treatment be sufficient deterrents to using well water? "Mandatory water conservation measures as described in the City's Water Shortage Contingency Plan will be implemented when the City's water supplies are projected to last three five years or less." I support the change from 3 to 5 years. .«7:T.T�►.�r. e - - 2112111 e] 2C= •• .3 1911-M72 .1 I support this deletion. "In the future, recycled water will be delivered to development in the Airport, Margarita, and Orcutt specific plan areas and is being considered with development proposals for the Avila Ranch, San Luis Ranch, and Madonna on LOVR specific plans." All future developments should pay for the costs of increasing our recycling capacity through water offsets and development fees. "The upgrade will enable the City to consider potable reuse, part of a One Water concept, in the future." Why use the words "consider" or "explore"? Aren't we committed to this concept? "In response to the Governor's Emergency Drought Declaration, the City Council authorized $100,000 in support of effective rebate programs in June 2015. $100 dollar rebates were provided for qualified toilet and washing machine replacements. Going forward, staff will be examining the expansion of these rebate programs to include other types water demand reductions." Why not incorporate some of these additional rebate programs into this report? Why wait until we're in the Watch Stage (unless we're there already!) before the City begins drafting ordinance revisions and code changes that would go into effect in subsequent water shortage stages? Regarding the "Water Shortage Response Stages": Mandatory measures can be implemented at the Watch Stage. Also implement rebate programs and increase leak detection, water meter testing, and water meter replacement. Decrease allowable time for repairing leaks in distribution system - Good! Consider Water Offsets at the Warning Stage. Also require hotels/motels/inns to offer the option to opt out of laundry services and require restaurants to only serve water upon request - Good! Increase Water Offsets at Severe through Extreme Stages - Good! Prohibition of of all outdoor irrigation at the Extreme Stage - Trees sequester carbon and therefore should be preserved even through to the Critical Stage Cessation of all new connections at Extreme Stage - Cessation of water connections should be tiered (similar to that being used in Pismo Beach) starting at the earlier Severe Stage. This could be described as follows: At the Severe stage or "tier one" the City would allow water connections for projects that are currently processing their planning and building permits with the exception of projects that are seeking planning permits for vacant parcels. At the Extreme stage or "tier two" the City would continue allowing water connections to projects that are processing building permits but no water connections would be allowed for projects that are processing planning permits. And at the Critical stage or "tier three" the City would deny water connections to projects that are processing building or planning permits.