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Desal Alternatives Letter to Santa Cruz City Council
On September 16, Desal Alternatives drafted a letter on the Mayor and City Manager’s proposal that calls for SHIFTING FOCUS TO CONSERVATION AND ADDITIONAL PUBLIC INPUT TO CRAFT A NEW VISION FOR THE CITY’S WATER SUPPLY after the city announced it put a hold on the proposal for a Desal facility in the City of Santa Cruz.
Dear Mayor Bryant and City Councilmembers,
Santa Cruz Desal Alternatives welcomes the Mayor and City Manager's recent statement about the need to suspend the desalination project timeline and to further involve the community in decisions about how to secure a sustainable water supply. We strongly agree that the City's process of water planning needs a "reset."
We encourage a broadening of the discussion to include all constructive and innovative measures, large and small, with the common goal of strengthening our water security. For too long, the debate has been limited to provoking drought fears and promoting the idea that a desal plant is the only solution. Our community can do better than that.
Santa Cruzans are primed to help. No other issue in recent times has so quickly galvanized locals to become politically active as we have seen with the desal proposal over the past year. The City Council has the opportunity to turn this interest into a resource for good decision-making.
Our group and many other residents are willing to knuckle down and work toward our common goal. Let’s join together to make future generations proud of our efforts to create a secure water future. Let’s make Santa Cruz that place where government and community can put polarizing politics aside and find solutions to make the difference.
To proceed on a constructive course, we recommend that the City Council take the following actions:
Stop all work on the desal project, including the EIR;
Engage the community in an open process of deciding the City's water future;
Act now on immediate measures to enhance water supply.
Santa Cruz Desal Alternatives urges the City Council to take these actions in the interest of finding genuine solutions that fit Santa Cruz’s needs and values, and we are committed to working constructively to achieve that outcome.
Stop all work on the desal project, including the EIR.
With the desal project timeline suspended, the City should also stop work on the current desal project EIR, which can only be used for development of the proposed desal plant. We take this position for the following reasons:
Unfinished City Plans that Will Affect Water Supply and Demand
One of the most troubling aspects of the desal project EIR is that the City has pushed ahead with the desal proposal without completing three major City plans that will materially affect water supply and future demand:
The long-delayed Habitat Conservation Plan (HCP);
The new City Master Conservation Plan; and
Inter-agency planning for water transfers among districts.
Instead of using these plans as the basis for analysis, the EIR settled for guesswork, incomplete data, and questionable projections. An EIR for a desal plant or any other significant water project should be based on these plans, rather than ignoring them or speculating about what they might contain when done.
Challenges by Responsible State & Federal Agencies
State and federal agencies with responsibilities for coastal development, water quality, wildlife habitat, and the marine environment have stated that the project description is inaccurate and that the City has not, in fact, tried some of the alternatives these agencies themselves had identified as long as several years ago. For example, the National Marine Fisheries Service stated:
"Unfortunately the Alternatives Analysis does not appear to thoroughly evaluate alternatives recommended ... in the development of a permitable HCP [Habitat Conservation Plan]." (Source: NOAA/National Marine Fisheries Service EIR Comment, p. 4)
The desal project EIR is invalid on its face if it did not in fact adequately evaluate identified alternatives.
Inconsistent City Policies for Tolerable Drought Cutbacks
The desal project EIR assumes a goal of 15% maximum tolerable curtailment during a drought; this is inconsistent with the long-standing policy in the City's adopted Integrated Water Plan, which states that the maximum tolerable curtailment should be 25%.
Credibility and Fiscal Responsibility
The Mayor and City Manager's proposal offers a fresh opportunity to get things right without more conflict and expense. Further expenditures for the EIR will not yield useful final products. Stopping work on the desal project EIR will save money and show good faith that the City genuinely seeks full discussion and broad community support for measures to secure water supply.
Engage the community in an open process of deciding the City's water future.
The City's further deliberations about water security should shift to a higher level of public engagement.
Complete Crucial Conservation Plans
The first order of business for the City and the community must be the completion of the new Master Conservation Plan, the Habitat Conservation Plan, and the plan for water transfers among districts. The City should ensure that these three planning processes are widely publicized, are accessible for participation by all members of the community, and are conducted with full transparency in their proceedings and documents. The discussions should be fact-based, and independent of the control of single-minded desal proponents.
These plans will provide answers to central questions about the City's water future. For example:
The Habitat Conservation Plan will set the minimum level of streamflow in the San Lorenzo River for in-stream habitat; instead of guessing how much river water might have to be returned for the fish, we will know how much, for now and into the future.
The City Master Conservation Plan's goals and programs for reducing water usage will make projections of future water needs more realistic and will identify productive best practices that we expect Santa Cruz businesses, schools, and residents will be eager to adopt. The City Council should ensure that this plan is not limited to the portrayal of conservation only as personal hardship.
The inter-agency planning for water transfers will identify specific feasible opportunities for "mutual aid" among districts and clarify any needed changes in water rights, so that the City and other districts can proceed appropriately to support each other's water security.
The decisions and policies in these plans will provide a sound basis for the City's further water planning; therefore they have to be completed before any major water projects are considered. For these plans and subsequent water decisions, it will be important to include the following elements:
Objectively Examine Needs and Supplies
Review assumptions and data concerning Santa Cruz's current needs and projected demand for water, and review the capacity and management practices of existing available sources of supply. Identify gaps in data and check methods and assumptions for projecting future needs and supplies. The goals of these reviews are to establish an accepted factual basis for understanding present conditions and to adopt scientifically valid methodologies for projections into the future.
Set Meaningful and Measurable Goals
With a factual basis for understanding local conditions, Santa Cruz can set goals to achieve leadership in sustainable water usage. Lack of information has left Santa Cruzans unclear about how we are doing or what our goals should be for sustainable water use.
For example, success in water stewardship can be roughly gauged by average consumption, as measured in the City's total usage divided by our population (gallons per capita per day —gpcd). We have been flattered by reports that we do well by this measure and that we have little more room to improve. However, while our average of 113 gpcd is low compared to the statewide average of 198, we are NOT exceptional compared to a variety of cities with comparable foggy climates:
(Source: http://www.water.ca.gov/urbanwatermanagement/docs/Report to Leg on2010 UWMPs-6-25-2012.pdf).
Thoroughly Explore Alternatives
Consider a full range of ways to strengthen Santa Cruz's water security. Members of the public as well as responsible agencies should be invited to submit or re-submit suggestions for discussion, including measures that are broadly applicable and also those that address specific vulnerabilities. Consistent evaluation criteria should be applied in discussions about alternatives. Alternatives should be considered in aggregate as well as separately, so that measures with modest yields are not unfairly judged against large-scale facilities such as desalination or recycled water plants. The goal of considering a full range of water security alternatives is to provide the community a common array of reliable choices for achieving water security.
Plan for Water Security
With a factual assessment of needs and supplies, and in light of full consideration of available measures, the City and its residents should devise a plan shaped by the overriding goal of achieving environmentally and economically sustainable water security.
Such a plan should identify specific shortfalls or vulnerabilities to our water security that could be individually addressed independently of other projects, along with challenges that would require system-wide improvements. A plan for water security should recognize that conserving water is the most efficient way to improve supply, and that water conservation can be achieved not only through sensible household practices but also by large-scale actions such as sharing water regionally, using recycled water where appropriate, and protecting the watersheds and ecosystems from which we draw water.
Take immediate actions to enhance our water supply.
With the desal project timeline suspended, the City should now devote attention to acting on immediate feasible steps that can be done regardless of future actions. These steps include:
Obtain Water Rights to Allow Inter-District Transfers
Actively pursue water rights to enable water transfers of excess winter flows for groundwater re-charge in neighboring districts;
Make New Development Water-Neutral
Adopt a policy of water-neutral development, and instruct City commissions and staff to come back with implementation in zoning, building codes, and water department policies and fees;
Help Households, Businesses, and Schools Save More Water
Expand the City's programs to cut toilet, washing machine, and landscaping water consumption; provide tenants and visitors information about their water usage;
Allow Recycled Water for Golf Courses
Act on the request of Scotts Valley and the Pasatiempo Golf Course for use of Scotts Valley's recycled water on the golf course.
Santa Cruz Desal Alternatives welcomes this fresh opening for full consideration of approaches to water security. We are prepared to participate in good faith and to seek the common good for our own and future generations.
Rick Longinotti, Chair
Bruce Van Allen, Vice-Chair
cc: City Manager, City of Santa Cruz
Board of Supervisors, County of Santa Cruz