Agenda packet — Santa Cruz City Council, November 29, 2022 (part 2 of 4)

2.97 WHAT IS NOT COVERED
 DAMAGE DUE TO ACCIDENT, MISUSE, or ALTERATION — Defects and damage caused as the result of any of the following are not covered:
— Flood, collision, fire, theft, freezing, vandalism, riot, explosion, or objects striking the vehicle; — Misuse of the vehicle;
— Installation into unapproved applications and installations; — Alterations or modification of the transmission or the vehicle, and — Damage resulting from improper storage (refer to long-term storage procedure outlined in the applicable Allison Service Manual) — Anything other than defects in Allison Transmission material or workmanship NOTE: This warranty is void on transmissions used in vehicles currently or previously titled as salvaged, scrapped, junked, or totaled.  CHASSIS, BODY, and COMPONENTS — The chassis and body company (assemblers) and other component and equipment manufacturers are solely responsible for warranties on the chassis, body, component(s), and equipment they provide. Any transmission repair caused by an alteration(s) made to the Allison transmission or the vehicle which allows the transmission to be installed or operated outside of the limits defined in the appropriate Allison Installation Guideline is solely the responsibility of the entity making the alteration(s).  DAMAGE CAUSED by LACK of MAINTENANCE or by the USE of TRANSMISSION FLUIDS NOT RECOMMENDED in the OPERATOR’S MANUAL — Defects and damage caused by any of the following are not covered:
— Failure to follow the recommendations of the maintenance schedule intervals applicable to the transmission; — Failure to use transmission fluids or maintain transmission fluid levels recommended in the Operator’s Manual.  MAINTENANCE — Normal maintenance (such as replacement of filters, screens, and transmission fluid) is not covered and is the owner’s responsibility.
 REPAIRS by UNAUTHORIZED DEALERS — Defects and damage caused by a service outlet that is not an authorized Allison Transmission Distributor or Dealer are not covered.
 USE of OTHER THAN GENUINE ALLISON TRANSMISSION PARTS — Defects and damage caused by the use of parts that are not genuine Allison Transmission parts are not covered.  EXTRA EXPENSES — Economic loss and extra expenses are not covered. Examples include but are not limited to: loss of vehicle use; inconvenience; storage; payment for loss of time or pay; vehicle rental expense; lodging; meals; or other travel costs.  “DENIED PARTY” OWNERSHIP — Warranty repair parts and labor costs are not reimbursed to any participating or non-participating OEMs, dealers or distributors who perform warranty work for, or on behalf of, end users identified by the United States as being a “denied party” or who are citizens of sanctioned or embargoed countries as defined by the U.S. Department of Treasury Office of Foreign Assets Control. Furthermore, warranty reimbursements are not guaranteed if the reimbursement would be contrary to any United States export control laws or regulations as defined by the U.S. Department of Commerce, the U.S. Department of State, or the U.S. Department of Treasury.

OTHER TERMS APPLICABLE TO CONSUMERS AS DEFINED by the MAGNUSON-MOSS WARRANTY ACT This warranty gives you specific legal rights and you may also have other rights which vary from state to state.

Allison Transmission does not authorize any person to create for it any other obligation or liability in connection with these transmissions.

ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE APPLICABLE TO THESE TRANSMISSIONS IS LIMITED IN DURATION TO THE DURATION OF THIS WRITTEN WARRANTY.

PERFORMANCE OF REPAIRS AND NEEDED ADJUSTMENTS IS THE EXCLUSIVE REMEDY UNDER THIS WRITTEN WARRANTY OR ANY IMPLIED WARRANTY. ALLISON TRANSMISSION SHALL NOT BE LIABLE FOR INCIDENTAL OR

CONSEQUENTIAL DAMAGES (SUCH AS, BUT NOT LIMITED TO, LOST WAGES OR VEHICLE RENTAL EXPENSES) RESULTING FROM BREACH OF THIS WRITTEN WARRANTY OR ANY IMPLIED WARRANTY.** ** Some states do not allow limitations on how long an implied warranty will last or the exclusion or limitation of incidental or consequential damages, so the above limitations or exclusions may not apply to you.

OTHER TERMS APPLICABLE TO OTHER END-USERS

THIS WARRANTY IS THE ONLY WARRANTY APPLICABLE TO THE ALLISON TRANSMISSION MODELS LISTED

ABOVE AND IS EXPRESSLY IN LIEU OF ANY OTHER WARRANTIES, EXPRESS OR IMPLIED, INCLUDING ANY IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. ALLISON

TRANSMISSION DOES NOT AUTHORIZE ANY PERSON TO CREATE FOR IT ANY OTHER OBLIGATION OR LIABILITY IN CONNECTION WITH SUCH TRANSMISSIONS. ALLISON TRANSMISSION SHALL NOT BE LIABLE FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM BREACH OF THIS WARRANTY OR ANY IMPLIED WARRANTY.

QUESTIONS
If you have any questions regarding this warranty or the performance of warranty obligations, you may contact any Allison Transmission Distributor or Dealer or write to:

Allison Transmission, Inc.

P.O. Box 894
Indianapolis, IN 46206-0894
Attention: Warranty Administration PF-9
Form SE0616EN (201009)

Page 2 of 2 ends

2.98 Warranty Begins:

The transmission cooler shall be free from component or structural failures caused by defects in material and/or workmanship. Collateral damage up to $10,000 per
occurrence is available for the first three (3) years.
(b) any vehicle, chassis, or component, part, attachment or accessory damaged by misuse, neglect, fire, exposure to severe environmental or chemical conditions, acidic environment, improper maintenance, accident, crash, or force majeure such as natural disaster, lightning, earthquake, windstorm, hail, flood, war or riot; (d) products or parts which may in the ordinary course wear out and have to be replaced during the warranty period, including, but not limited to, tires, fluids, gaskets and light bulbs. Pierce assumes no responsibility for the assembly of its parts or subassemblies into finishing products or vehicles unless the assembly is performed by Pierce.

Five (5) Years on Oil Cooler and three (3) years on collateral damage coverage
Warranty Period
Ends After:

Fire and Rescue Apparatus
Coverage:

Five (5) Year Material and Workmanship - Transmission Oil Cooler Three (3) Year Collateral Damage Coverage

1. LIMITED WARRANTY
The original purchaser may void this warranty in part or in its entirety if the product is repaired or replaced (a) without prior written approval of the Pierce Customer Service Department; or (b) at a facility which has not been approved by Pierce as to technical Limited Warranty
Subject to the limitations and exclusions set forth below, Pierce Manufacturing provides the following warranty to the Buyer:
(c) any vehicle, chassis or component, part, attachment or accessory that has been repaired, altered or assembled in any way by any person or entity other than Pierce which, in the sole judgment of Pierce, adversely affects the performance, stability or purpose for which it was manufactured; or
(a) any integral parts, components, attachments or trade accessories of or to the product that are not manufactured by Pierce, including but not limited to engines, transmissions, drivelines, axles, water pumps and generators; with respect to all such parts, components, attachments and accessories, Pierce shall assign to Buyer the applicable warranties, if any, made by the respective manufacturers thereof; Notwithstanding anything to the contrary herein, Pierce makes no warranty whatsoever as to:

The date of delivery to the first retail purchaser.

This limited warranty shall apply only if the product is properly maintained in accordance with Pierce's maintenance instructions and manuals and is used in service which is normal to the particular model. Normal service means service which does not subject the product to stresses or impacts greater than normally result from careful use. If the Buyer discovers a defect or nonconformity, it must notify Pierce in writing within thirty (30) days after the date of discovery, but in any event prior to the expiration of the warranty period.

THIS LIMITED WARRANTY MAY NOT BE ASSIGNED OR OTHERWISE

TRANSFERRED BY THE BUYER TO ANY SUBSEQUENT USER OR PURCHASER OR TO ANY OTHER PERSON OR ENTITY.

This warranty does not cover repair due to accidents,
misuse, and excessive vibration, flying debris, storage damage (freezing), negligence or modification. This warranty is void if any modification or repairs are performed without authorization. This also voids any future warranty.

This warranty does not cover cost of maintenance or repairs due to lack of required maintenance services as
recommended. Performance of the required maintenance
and use of proper fluids are the responsibility of the owner.

Towing is covered to the nearest distributor or authorized dealer only when necessary to prevent further damage to your transmission.

Labor costs for the removal and reinstallation of goods may be covered when necessary to make repairs. Please contact your OEM for authorization.

Replacement of cooler during the warranty period is limited to 100% of reasonable labor costs up to a maximum of $700 to remove, replace, or repair the oil cooler.

Conditions and
Exclusions:

See Also
Paragraphs
2 thru 4

4. EXCLUSION OF CONSEQUENTIAL AND INCIDENTAL DAMAGES.

Notwithstanding anything to the contrary herein or in any agreement between Pierce and Buyer, IN NO EVENT SHALL PIERCE BE LIABLE FOR ANY CONSEQUENTIAL,

INCIDENTAL, SPECIAL, INDIRECT, OR PUNITIVE DAMAGES WHATSOEVER,

WHETHER ARISING OUT OF BREACH OF CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE AND STRICT LIABILITY) OR OTHER THEORY OF LAW

OR EQUITY, WITH RESPECT TO VEHICLES OR OTHER PRODUCTS SOLD BY

PIERCE, OR THEIR OPERATION OR FAILURE TO OPERATE, OR ANY DEFECTS

THEREIN, OR ANY UNDERTAKINGS, ACTS OR OMISSIONS RELATED THERETO,

3. BUYER'S EXCLUSIVE REMEDY.
(d) products or parts which may in the ordinary course wear out and have to be replaced during the warranty period, including, but not limited to, tires, fluids, gaskets and light bulbs. Pierce assumes no responsibility for the assembly of its parts or subassemblies into finishing products or vehicles unless the assembly is performed by Pierce.

One (1) Year & Five (5) Year Warranty Period
Ends After:

Note: Any Surety Bond, if a part of the sale of the vehicle as to which this limited warranty is provided, applies only to this Pierce Basic One Year Limited Warranty for such vehicle, and not to other warranties made by Pierce in a separate document (if any) or to the warranties (if any) made by any manufacturer (other than Pierce) of any part, component, attachment or accessory that is incorporated into or attached to the vehicle. 1/30/2013 WA0231
THE WARRANTY SET FORTH IN PARAGRAPH 1 IS THE SOLE AND EXCLUSIVE WARRANTY GIVEN BY PIERCE. PIERCE HEREBY DISCLAIMS AND EXCLUDES

ALL OTHER WARRANTIES, WHETHER EXPRESS, IMPLIED OR STATUTORY,

INCLUDING WITHOUT LIMITATION ANY WARRANTY OF MERCHANTABILITY, ANY

WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE.

Fire and Rescue Apparatus
Coverage:

One (1) Year Material and Workmanship Foam System & Five (5) Year Material and Workmanship Control Head
Limited Warranty
Notwithstanding anything to the contrary herein, Pierce makes no warranty whatsoever as to:

Limited warranty 1 year parts and labor for for the foam system and 5 years parts and labor for the control head.

1. LIMITED WARRANTY
(b) any vehicle, chassis, or component, part, attachment or accessory damaged by misuse, neglect, fire, exposure to severe environmental or chemical conditions, acidic environment, improper maintenance, accident, crash, or force majeure such as natural disaster, lightning, earthquake, windstorm, hail, flood, war or riot; Subject to the limitations and exclusions set forth below, Pierce Manufacturing provides the following warranty to the Buyer:
(c) any vehicle, chassis or component, part, attachment or accessory that has been repaired, altered or assembled in any way by any person or entity other than Pierce which, in the sole judgment of Pierce, adversely affects the performance, stability or purpose for which it was manufactured; or
(a) any integral parts, components, attachments or trade accessories of or to the product that are not manufactured by Pierce, including but not limited to engines, transmissions, drivelines, axles, water pumps and generators; with respect to all such parts, components, attachments and accessories, Pierce shall assign to Buyer the applicable warranties, if any, made by the respective manufacturers thereof; The date of the original purchase invoice (issued when the product ships from the factory). Warranty Begins:

2.108
Note: Any Surety Bond, if a part of the sale of the vehicle as to which this limited warranty is provided, applies only to this Pierce Basic One Year Limited Warranty for such vehicle, and not to other warranties made by Pierce in a separate document (if any) or to the warranties (if any) made by any manufacturer (other than Pierce) of any part, component, attachment or accessory that is incorporated into or attached to the vehicle. 2/8/2010 WA0057

1. LIMITED WARRANTY
THE WARRANTY SET FORTH IN PARAGRAPH 1 IS THE SOLE AND EXCLUSIVE WARRANTY GIVEN BY PIERCE. PIERCE HEREBY DISCLAIMS AND EXCLUDES ALL

OTHER WARRANTIES, WHETHER EXPRESS, IMPLIED OR STATUTORY,

INCLUDING WITHOUT LIMITATION ANY WARRANTY OF MERCHANTABILITY, ANY

WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE.

THIS LIMITED WARRANTY MAY NOT BE ASSIGNED OR OTHERWISE

TRANSFERRED BY THE BUYER TO ANY SUBSEQUENT USER OR PURCHASER OR TO ANY OTHER PERSON OR ENTITY.

This limited warranty is applicable to the vehicle in the following percentage costs of warranty repair, if any:

Topcoat Durability & Appearance: Gloss, Color Retention & Cracking
0-72 months 100%
73-96 months 50%
97-120 months 25%
Integrity of Coating System: Adhesion, Blistering/Bubbling 0-36 months 100%
37-84 months 50%
85-120 months 25%
Corrosion: Dissimilar Metal and Crevice
0-36 months 100%
37-48 months 50%
49-72 months 25%
73-120 months 10%
Corrosion Perforation
0-120 months 100%
This limited warranty applies only to exterior paint. Paint on the vehicle's interior is warranted only under the Pierce Basic One Year Limited Warranty.

Items not covered by this warranty include:
(a) Damage from lack of maintenance and cleaning (proper cleaning and maintenance procedures are detailed in the Pierce operation and maintenance manual).
(b) UV paint fade.
(c) Any cab not manufactured by Pierce.

Conditions and
Exclusions:

Fire and Rescue Apparatus
Coverage:

Ten (10) Year Pro-Rated Paint and Corrosion
Custom Body
Ten (10) Years Warranty Period
Ends After:

The date of the original purchase invoice (issued when the product ships from the factory). Warranty Begins:

Exterior surfaces of the body shall be free from blistering, peeling, corrosion or any other adhesion defect caused by defective manufacturing methods or paint material selection. (d) products or parts which may in the ordinary course wear out and have to be replaced during the warranty period, including, but not limited to, tires, fluids, gaskets and light bulbs. Pierce assumes no responsibility for the assembly of its parts or subassemblies into finishing products or vehicles unless the assembly is performed by Pierce. (b) any vehicle, chassis, or component, part, attachment or accessory damaged by misuse, neglect, fire, exposure to severe environmental or chemical conditions, acidic environment, improper maintenance, accident, crash, or force majeure such as natural disaster, lightning, earthquake, windstorm, hail, flood, war or riot;

4. EXCLUSION OF CONSEQUENTIAL AND INCIDENTAL DAMAGES.

Notwithstanding anything to the contrary herein or in any agreement between Pierce and Buyer, IN NO EVENT SHALL PIERCE BE LIABLE FOR ANY CONSEQUENTIAL,

INCIDENTAL, SPECIAL, INDIRECT, OR PUNITIVE DAMAGES WHATSOEVER,

WHETHER ARISING OUT OF BREACH OF CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE AND STRICT LIABILITY) OR OTHER THEORY OF LAW

OR EQUITY, WITH RESPECT TO VEHICLES OR OTHER PRODUCTS SOLD BY

PIERCE, OR THEIR OPERATION OR FAILURE TO OPERATE, OR ANY DEFECTS

THEREIN, OR ANY UNDERTAKINGS, ACTS OR OMISSIONS RELATED THERETO,

REGARDLESS OF WHETHER PIERCE HAS BEEN INFORMED OF THE POSSIBILITY OF ANY SUCH DAMAGES. Without limiting the generality of the foregoing, Pierce specifically disclaims any liability for property or personal injury damages, penalties, damages for lost profits or revenues, loss of vehicles or products or any associated equipment, cost of substitute vehicles or products, down-time, delay damages, any other types of economic loss, or for any claims by any third party for any such damages.

3. BUYER'S EXCLUSIVE REMEDY.

2.109
Note: Any Surety Bond, if a part of the sale of the vehicle as to which this limited warranty is provided, applies only to this Pierce Basic One Year Limited Warranty for such vehicle, and not to other warranties made by Pierce in a separate document (if any) or to the warranties (if any) made by any manufacturer (other than Pierce) of any part, component, attachment or accessory that is incorporated into or attached to the vehicle. 2/22/2010 WA0168

1. LIMITED WARRANTY
THE WARRANTY SET FORTH IN PARAGRAPH 1 IS THE SOLE AND EXCLUSIVE WARRANTY GIVEN BY PIERCE. PIERCE HEREBY DISCLAIMS AND EXCLUDES ALL

OTHER WARRANTIES, WHETHER EXPRESS, IMPLIED OR STATUTORY,

INCLUDING WITHOUT LIMITATION ANY WARRANTY OF MERCHANTABILITY, ANY

WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE.

THIS LIMITED WARRANTY MAY NOT BE ASSIGNED OR OTHERWISE

TRANSFERRED BY THE BUYER TO ANY SUBSEQUENT USER OR PURCHASER OR TO ANY OTHER PERSON OR ENTITY.

This warranty does not cover damage from lack of
maintenance and cleaning (proper cleaning and maintenance procedures are detailed in the Pierce operation and
maintenance manual).

Conditions and
Exclusions:

Fire and Rescue Apparatus
Coverage:

One (1) Year Material and Workmanship
Graphics Fading and Deterioration
One (1) Year Warranty Period
Ends After:

The date the apparatus is placed in service, or 60 days from the original buyer invoice date, whichever comes first. Warranty Begins:

Each graphic lamination shall be free from defects in material, workmanship, fading, and deterioration.
(d) products or parts which may in the ordinary course wear out and have to be replaced during the warranty period, including, but not limited to, tires, fluids, gaskets and light bulbs. Pierce assumes no responsibility for the assembly of its parts or subassemblies into finishing products or vehicles unless the assembly is performed by Pierce. (b) any vehicle, chassis, or component, part, attachment or accessory damaged by misuse, neglect, fire, exposure to severe environmental or chemical conditions, acidic environment, improper maintenance, accident, crash, or force majeure such as natural disaster, lightning, earthquake, windstorm, hail, flood, war or riot;

4. EXCLUSION OF CONSEQUENTIAL AND INCIDENTAL DAMAGES.

Notwithstanding anything to the contrary herein or in any agreement between Pierce and Buyer, IN NO EVENT SHALL PIERCE BE LIABLE FOR ANY CONSEQUENTIAL,

INCIDENTAL, SPECIAL, INDIRECT, OR PUNITIVE DAMAGES WHATSOEVER,

WHETHER ARISING OUT OF BREACH OF CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE AND STRICT LIABILITY) OR OTHER THEORY OF LAW

OR EQUITY, WITH RESPECT TO VEHICLES OR OTHER PRODUCTS SOLD BY

PIERCE, OR THEIR OPERATION OR FAILURE TO OPERATE, OR ANY DEFECTS

THEREIN, OR ANY UNDERTAKINGS, ACTS OR OMISSIONS RELATED THERETO,

REGARDLESS OF WHETHER PIERCE HAS BEEN INFORMED OF THE POSSIBILITY OF ANY SUCH DAMAGES. Without limiting the generality of the foregoing, Pierce specifically disclaims any liability for property or personal injury damages, penalties, damages for lost profits or revenues, loss of vehicles or products or any associated equipment, cost of substitute vehicles or products, down-time, delay damages, any other types of economic loss, or for any claims by any third party for any such damages.

3. BUYER'S EXCLUSIVE REMEDY.

2.110
City Council Special Meeting

AGENDA REPORT
DATE: 11/14/2022
AGENDA OF: 11/29/2022
DEPARTMENT: Water
SUBJECT: Securing Our Water Future Resolution and Policy Guidance for Water Supply Augmentation to Improve Water Supply Reliability for Santa Cruz Water Service Customers (WT)
RECOMMENDATION: Motion to:
1) Adopt a resolution establishing a policy on Securing Our Water Future that provides guidance and direction for the development and implementation of water supply augmentation projects needed to resolve Santa Cruz’s long-standing water supply reliability issue; and 2) Direct staff to add the policy direction included in the Securing Our Water Future resolution to the City Council’s Policy Manual as policy 34.7, Securing Our Water Future Policy Guidance for Water Supply Augmentation to Address Santa Cruz’s Water Supply Reliability Issue.

BACKGROUND: Beginning in April 2022, Water Department staff and Water Commissioners started working together to develop a policy framework for Securing Our Water Future (SOWF) for review and action by the Santa Cruz City Council before the end of 2022. During the policy development process staff and Water Commissioners worked together to consider and integrate into the proposed new policy content on a range of topics including supply augmentation project concepts and the evaluation criteria used for the side-by-side comparisons of these projects, assessing the vulnerability of the water system to a suite of contemporary and plausible climate change scenarios, hydrology, and water system modeling tools developed as part of the work to implement the Council accepted recommendations of the Water Supply Advisory Committee, and assessing the economic impacts of curtailments, should adequate additional supply not be available to meet customer demand. This work is summarized in the SOWF Summary Memos on attached to this agenda report.

About mid-way through the policy development process, in an August 16, 2022 City Council study session,1 Water Department staff summarized for Councilmembers:
 how water use has changed in the last 20 years,
 the 2015 recommendations of the Council appointed Water Supply Advisory Committee (WSAC) and how its recommendations have been implemented, 1 See: https://ecm.cityofsantacruz.com/OnBaseAgendaOnline/Meetings/ViewMeeting?id=1950&doctype=1

3.1  the goals and expected benefits of establishing and codifying a policy framework for water supply augmentation through the SOWF initiative, and
 an overview of how new work on the impacts of climate change are already being experienced and how, without action, longer and more frequent droughts increase our community’s vulnerability to significant and negative impacts of major water shortages.

Developing the SOWF Resolution and policy guidance has involved bringing together technical and analytical resources from multiple disciplines and preparing, presenting, and discussing topics ranging from project yields and costs to climate change hydrology to economic impacts of curtailments to communications and engagement with interest groups and the broader community. At its November 7, 2022, meeting the Santa Cruz Water Commission voted unanimously to recommend to the Council the adoption of the SOWF Resolution and policy direction.

DISCUSSION: The goal of setting a policy framework for SOWF is to codify guidance for selection and incremental implementation of the water supply augmentation projects needed to meet the water supply reliability standard that is included in Section 2 of the SOWF policy.

The attached SOWF Resolution provides a comprehensive set of recitals that describe Santa Cruz’s water supply augmentation journey over more than 50 years. These recitals provide important context that help readers understand some of the more recent twists and turns and successes and challenges that have brought us to where we are today. They provide a sound foundation for the findings and policy direction proposed.

The SOWF policy direction is based on both the work completed in implementing the WSAC recommendations over the last eight years as well as all of the work done during 2022 to bring the threads of this significant body of work together. The SOWF policy includes the following sections:

1. Statement of Findings;

2. Water Supply Reliability Goal

3. Santa Cruz’s Water Supply Portfolio

4. Considerations In Developing Water Supply Augmentation Projects; and

5. Policy Implementation
The Statement of Findings provides a fairly concise statement of our current knowledge on topics affecting water supply reliability. Each statement is based on substantial data and analytical work that has been completed and reviewed by and discussed with the Water Commission through work related to development of the 2020 Urban Water Management Plan, the 2021 update to the Water Shortage Contingency Plan, the 2021 update to the Long Range Financial Plan and Cost of Service Analysis, and the work completed in 2022 on the Securing Our Water Future policy.

The SOWF’s Water Supply Reliability Goal states that “The City of Santa Cruz’s water supply reliability goal shall be achieved by having an adequate supply to meet all customer demand under plausible, worst-case conditions. This goal has been specifically developed and recommended because the very large deficits associated with worst-case conditions are so large that they cannot be addressed through curtailments due to the very high level of efficiency already embraced by Santa Cruz’s water service customers that makes significant curtailments expensive and widely and seriously negatively impactful.

3.2 The policy direction includes a provision that the volume of water that is needed to meet the reliability goal be reviewed and potentially revised no less frequently than every five years based on ongoing research and monitoring of the impacts of climate change on local water conditions.

This “adaptive management” approach is critically important to support appropriate timing of implementation of water supply augmentation projects and help reduce the risks of over-building or under-building projects or over-investing or under-investing in supply.

Policy related to Santa Cruz’s Water Supply Portfolio is focused on sources of supply and acknowledges that we have limited sources of supply available to us and that all options will need to be considered for potential project implementation to meet future supply needs.

Development or recommendation of specific water supply augmentation projects is not covered in the SOWF policy because the SOWF’s goal was never to “pick a project.” Rather the goal of the SOWF policy is to answer the “how” and “how much” questions but not the “what” “when” or “where” questions. These latter questions will be answered through the planned development of the Water Supply Augmentation Implementation Plan (WSAIP) that will provide a detailed roadmap of project development and implementation that will be created in collaboration with the Water Commission and brought to the City Council for action when it is ready.

Section 4 of the SOWF policy direction sets out the guiding principles, and criteria that will be considered in selecting and implementing supply augmentation projects. Most of the provisions included in the SOWF policy come from the WSAC’s Final Report on Agreements and Recommendations. One important addition to the guiding principles for the SOWF policy is the new policy 4.1.2 Affordability and Equitable Access to Water Service. The City’s Health in All Policies framework calls for addressing public health, sustainability and equity in all City policies and actions and adding a specific policy that recognizes the importance of maintaining affordability and equitable access to water service is critical to community health and well-being.

Policy 4.1.2 is an important addition to the WSAC’s guiding policies that placed Public Health as its very first priority.

The inclusion of guiding principles, primary evaluation criteria, and identified additional criteria in the SOWF policy support transparency and accountability for decision-making, both of which are important to being able to move supply augmentation work from the planning stages to implementation.

The final section of the SOWF policy provides some specific Policy Implementation direction and guidance. The goal of this section is to set clear expectations about what the Water Department will do to implement SOWF guidance. For example, Section 5 makes it clear that, in addition to taking action on the WSAIP and any CEQA document related to the WSAIP, future Council actions related to water supply augmentation projects could be in the form of approving plans and specifications and any CEQA required environmental reviews for augmentation projects , as well as implementation actions such as contracts for engineering design, authorizations to advertise for competitive bids for construction or use other alternate project delivery methods, actions to approve loans or issue debt, and approvals for collaborative agreements or partnerships with other local utilities to develop or construct supply augmentation projects.

Completion of and Council action on the SOWF Resolution and policy guidance is an important step that supports resolving Santa Cruz’s long-standing water supply reliability issues. As

3.3 described in the ton Economic Impact Analysis of Curtailments included in the SOWF Summary Memos being provided in support of the SOWF Resolution and policy guidance, there are potentially large negative economic consequences to our local economy of failing to take action to improve system reliability, especially in the face of climate change. These negative economic consequences are avoidable and, in spite of the costs associated with all of the supply augmentation projects that have been evaluated, supply augmentation projects are significantly more cost effective to avoid the economic impacts of curtailments than to endure them as a result of ack of action.

FISCAL IMPACT: None.

Prepared By:

Heidi R. Luckenbach
Deputy Director/Engineering
Manager
Submitted By:

Rosemary Menard
Water Director
Approved By:

Matt Huffaker
City Manager
ATTACHMENTS:

1. Resolution

2. Summary Technical Memo Cover

3. Modeling and Hydrology Summary Memo

4. Water Supply Augmentation Project Concepts

5. The Economic Impacts of Water Supply Curtailments

3.4 RESOLUTION NO. NS-30,

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTACRUZ ESTABLISHING

POLICY DIRECTION FOR SECURING OUR WATER FUTURE AND GUIDANCE FOR

IMPLEMENTING WATER SUPPLY AUGMENTATION PROJECTS TO IMPROVE WATER

SUPPLY RELIABILITY AND DIRECTING THE CITY MANAGER TO ADD THIS POLICY TO THE COUNCIL’S POLICY MANUAL AS POLICY 34.7
WHEREAS, For more than 100 years the Santa Cruz water system has been providing residents and businesses in the City of Santa Cruz with drinking water and fire protection services; and
WHEREAS, Although water systems are often taken for granted, they are a primary example of critical infrastructure that, if it fails, seriously and negatively affects every aspect of our community, including threatening public health, fire safety, and economic sustainability; and WHEREAS, All water supplied to customers in the Santa Cruz water service area as well as in the service areas of adjacent water districts is and always has been limited to locally available surface and groundwater resources and no water facilities exist that could convey imported water for use by Santa Cruz County water service customers; and WHEREAS, In 1960 the water system was modified by the addition of raw water storage for seasonal supply by the construction of Newell Creek Dam, which created Loch Lomond Reservoir, specifically to respond to the area’s Mediterranean climate, which is typically characterized by a late fall, winter and early spring wet season and late spring, summer, early fall dry season and which requires a source of stored water to meet much of the dry season’s customer demand; and
WHEREAS, In the City’s process of designing the sizing and siting for Newell Creek Dam, historic weather conditions influenced assumptions about how much storage was needed and how the storage would be operated, including assumptions about how historic precipitation levels would allow for the annual replenishment of reservoir levels and, even in those occasional years when precipitation was lower than normal, would provide enough year-to-year carry-over supply to meet customer demand during drought conditions; and WHEREAS, Over many years Santa Cruz’s water service customers have actively embraced water use efficiency practices and behaviors to the degree that Santa Cruz’s residential gallons per person (per capita) per day (GPCD) for indoor and outdoor use is stable at 44 GPCD and is among the lowest in the state; and
WHEREAS, In the 60 years since the construction of Newell Creek Dam, multi-year droughts in 1976-1977, 1987- 1991, 2014-2015, and 2020-2021 have shown that, even with significant achievements by customers in adopting highly efficient water use practices, the amount of water storage in the system is inadequate to assure that all water system customers have reliable access to water during drought conditions without imposing burdensome and unsustainable levels of curtailment; and

3.5 RESOLUTION NO. NS-30,
WHEREAS, Following late 1960s construction of the Newell Creek Dam, the City last added to its supply resources with the construction of the Felton Diversion in the 1970s. The Felton Diversion was designed to support the diversion of water from the mainstem of the San Lorenzo River to improve the City’s ability to maximize stored water in drier years when flows from Newell Creek and the surrounding watershed lands are inadequate to fill Loch Lomond Reservoir; and
WHEREAS, More or less continuously since weathering the historical worst case (1976- 1977) drought, the city has been exploring, conducting feasibility analyses, and developing supply augmentation strategies with the most recent being the scwd2 desalination project. The scwd2 desalination project was undertaken as a partnership with the Soquel Creek Water District (District) to allow the City and the District to provide drought supply and an alternate source of water that would, among other goals, allow the District to reduce pumping in (and therefore protect from seawater intrusion) what is now called the Santa Cruz Mid-County Groundwater Basin; and
WHEREAS, In 2014 the Santa Cruz City Council addressed community concerns about the need for and advisability of constructing a desalination plant by appointing a diverse community group to evaluate the City’s water supply situation, and tasked it with defining the problem to be solved, identifying and evaluating alternative solutions, and developing recommendations to the City Council on water supply augmentation actions to be pursued; and WHEREAS, The City Council-appointed group that became known as the Water Supply Advisory Committee (WSAC) worked together between April 2014 and October 2015 and produced a set of agreements and recommendations to the Council including, in Section 3.08 of its 2015 Final Report on Agreements and Recommendations1 a Problem Statement that includes the following language (emphasis added):
“Santa Cruz’s water supply reliability issue is the result of having only a marginally adequate amount of storage to serve demand during dry and critically dry years when the system’s reservoir doesn’t fill completely. Both expected requirements for fish flow releases and anticipated impacts of climate change will turn a marginally adequate situation into a seriously inadequate one in the coming years.

Santa Cruz’s lack of storage makes it particularly vulnerable to multi-year droughts.

The key management strategy currently available for dealing with this vulnerability is to very conservatively manage available storage. This strategy typically results in regular calls for annual curtailments of demand that may lead to modest, significant, or even critical requirements for reduction. In addition, the Santa Cruz supply lacks diversity, thereby further increasing the system’s vulnerability to drought conditions and other risks.
1 See https://www.cityofsantacruz.com/government/city-departments/water/water-supply-advisorycommittee-recommendations

3.6 RESOLUTION NO. NS-30,
The projected worst-year gap between peak-season available supply and demand during an extended drought is about 1.2 billion gallons. While aggressive implementation of conservation programs will help reduce this gap, conservation alone cannot close this gap. The Committee’s goal is to establish a reasonable level of reliability for Santa Cruz water customers by substantially decreasing this worst-year gap while also reducing the frequency of shortages in less extreme years.”; and WHEREAS, Circumstances since the completion of the WSAC’s work continue to support the WSAC’s Problem Statement as an accurate assessment of the water system’s water supply reliability issues, even in the face of the substantial long-term demand reduction by existing customers through adoption of water use efficiency practices; and WHEREAS, As part of its recommendations to the City Council, which the Council unanimously accepted in November 2015, the WSAC recommended that the Water Department be directed to prepare information about a range of water supply augmentation projects that would allow the projects to be compared to each other and that would support data-driven decision-making about which options or portfolio of options to pursue to address the water system’s water supply reliability issues; and
WHEREAS, The WSAC’s recommended alternatives to be further considered included two strategies, 1) Development of groundwater storage using a combination of both passive and active recharge approaches and available surface water flows during the rainy season; and 2) Development of advanced treated recycled water or desalinated water if needed to address any remaining supply-demand gap; and
WHEREAS, An agreed upon diverse set of evaluation criteria rooted in and building on the WSAC’s recommendations and including the WSAC’s key decision criteria of cost, yield and timeliness and additional quantitative and qualitative criteria have been identified through the work completed following the WSAC process in 2015; and
WHEREAS, The WSAC’s intention was that its recommendations, upon acceptance by the City Council and integration into the Department’s 2015 Urban Water Management Plan, would not be self-executing but rather would have to be implemented through the development and implementation strategies and action such as the Water Supply Augmentation Strategies (WSAS) described below, and a more detailed Water Supply Augmentation Implementation Plan (WSAIP) to be developed in collaboration with the Water Commission for City Council review and action in 2023; and
WHEREAS, In 2014 the state of California adopted the Sustainable Groundwater Management Act (SGMA), which requires the development and implementation of Groundwater Sustainability Plans (GSPs) that will bring critically over-drafted, and high and medium priority groundwater basins into sustainability within 20 years; and WHEREAS, The City of Santa Cruz has participated in the development of two local GSPs, one in collaboration with Santa Cruz County and the Soquel Creek and Central Water Districts for the Santa Cruz Mid-County Groundwater Basin, and one in collaboration with Santa

3.7 RESOLUTION NO. NS-30,
Cruz County, Scotts Valley and San Lorenzo Valley Water Districts, the City of Scotts Valley and the Mt. Hermon Association for the Santa Margarita Groundwater Basin; and WHEREAS, These GSPs have greatly expanded our understanding of local groundwater resources and provided specific measurable criteria for their sustainable management and use which may, in addition to guiding actions to achieve sustainability in the basins, include use of these basins to store water for use by Santa Cruz as drought supply; and WHEREAS, Beginning late 2015 and continuing to the present, Water Department staff has implemented the WSAS envisioned by WSAC through, among other actions, 1) conducting follow up technical studies and feasibility analyses; 2) conducting detailed assessments of system irrigation demand and opportunities for developing recycled water as a source of supply; 3) conducting pilot testing for water transfers with the Soquel Creek Water District; 4) conducting pilot testing of aquifer storage and recovery technology at the Beltz 8 and Beltz 12 wells; 5) developing environmental analyses and cost information on a wide range of supply alternatives; and 6) providing detailed reports to the Water Commission on a quarterly basis on its progress; and
WHEREAS, In November 2019, in a joint meeting of the City Council and Water Commission, the Council approved a path toward implementation of the WSAC’s recommendations using the process included in the WSAC’s Final Report on Agreements and Recommendations and, in addition to extending the schedule for completion of the WSAC’s endorsed approach for comparative analysis of supply augmentation options, endorsed the concept of early action to develop an Aquifer Storage and Recovery project in the Beltz wellfield area of the Santa Cruz Mid-County Groundwater Basin; and WHEREAS, In parallel with its work implementing the WSAS, the Water Department has also completed other related work, such as preparing and submitting proposed water rights change petitions to the State Water Resources Control Board that, if approved, would 1) allow the City to deliver treated water to other regional providers as part of water transfer or exchanges; 2) extend the time limit for the development of water allocated to the City under its Felton Permits; and 3) add a point of diversion for water under the Felton Permits at the City’s Tait Street diversion. Taken together, all of these measures would substantially increase the City’s ability to use its water supplies in the future while still protecting flows in the Felton to Tait reach of the San Lorenzo River to support recovery of endangered coho salmon and threatened steelhead trout; and
WHEREAS, Beginning in early 2022, Water Department staff initiated the final phase of implementing the WSAC’s recommendations by working with the City Council-appointed Santa Cruz Water Commission to 1) complete the side-by-side comparison of the four main water supply augmentation strategies that have the potential to make a substantial contribution to improving the reliability of Santa Cruz’s supply; 2) develop recommended Securing Our Water Future policy direction for City Council consideration; and 3) initiate development of the WSAIP; and

3.8 RESOLUTION NO. NS-30,
WHEREAS, Because it is not feasible to complete the WSAC’s recommended side-byside comparison for every potential water supply option that could be implemented using available resources, the Department proposed, and the Water Commission accepted the suggestion that a set of four representative project concepts be compared during the Securing Our Water Future policy development process; and
WHEREAS, The WSAC’s work also considered the implications of climate change on water system reliability and included analysis of climate change scenarios that would result from increasing temperatures and changing precipitation patterns; and WHEREAS, The climate change assessments and actual experiences in recent years indicate that climate change effects, that include increasingly variable and extreme weather conditions, are already being experienced; and
WHEREAS, The existing and anticipated effects of climate change, particularly impacts from more frequent dry winters and increased instances of multi-year droughts, are serious threats to the City’s water system and add urgency to the City’s need to take action to improve its ability to provide a reliable supply for today’s customers as well as those of tomorrow; and WHEREAS, In addition to the anticipated impacts of climate change on water supply reliability, the increase in extreme wet weather conditions associated with atmospheric rivers also threatens key water system infrastructure; and
WHEREAS, Working with Professor Casey Brown of the University of Massachusetts at Amherst, Department of Civil Engineering and affiliated Hydrosystems Research Group and Professor Shawn Chartrand of Simon Fraser University’s School of Environmental Science, the Water Department developed new water system vulnerability assessment tools that make it possible to assess the reliability and resilience of the water system across more than 8,000 potentially plausible climate change scenarios in order to ascertain the water system’s vulnerability to climate change and the related temperature and precipitation changes projected to result therefrom; and
WHEREAS, Both analyses of historic hydrologic trends and potential future hydrologic conditions developed for the water system vulnerability analysis indicate that future conditions are likely to be more challenging for the Santa Cruz water system due to increasing frequency and duration of dry conditions, which stress systems with limited storage and that rely heavily on local precipitation such as Santa Cruz’s; and
WHEREAS, The Water Department and consultants specifically evaluated results of the vulnerability analyses, particularly as they relate to the availability and reliability of “wet season” water supply for development of a drought supply for Santa Cruz using aquifer storage and recovery, which diverts wet season water, treats it to drinking water standards and injects it into local groundwater aquifers for recovery during the annual dry season or during drought events; and

3.9 RESOLUTION NO. NS-30,
WHEREAS, The Water Department staff and consultants also specifically evaluated results of the vulnerability analysis of longer and more frequent drought conditions, and results of this analysis project increasing climate variability in the coming decades; and WHEREAS, Based on modeling results over a wide range of climate scenarios, Water Department staff and consultants have concluded that anticipated longer dry periods is the challenge driving the need to augment water supply, and that planned increases in housing in the Santa Cruz water service area, while included in the long-term demand forecast, is not by itself driving the size or timing of needed water supply augmentation projects; and WHEREAS, The City Council has determined that the adoption of this Resolution, which accepts the WSAC’s policy recommendations but does not commit the City to any specific future water supply augmentation WSAIP or water supply augmentation project, is not subject to CEQA because the Resolution, by itself, will not cause any direct or reasonably foreseeable indirect environmental effects; and
WHEREAS, A future WSAIP, if and when ultimately approved by the City Council, may include principles, policies, and other content that differ from those found in, or anticipated by, the findings, policy goals and statements, and actions set forth below and adopted through this Resolution, and may result in making revisions to the policy direction included here to ensure alignment of new information and findings developed as part of the WSAIP; and WHEREAS, Following consideration of all the relevant information developed by Water Department staff and presented to and discussed with Water Commissioners through an iterative process of publicly noticed meetings occurring beginning in the spring of 2022, the Water Commission at its regular publicly noticed meeting on November 7, 2022, unanimously approved the findings and policies recommended in this resolution for submittal to the City Council.

NOW THEREFORE, BE IT RESOLVED by the Santa Cruz City Council that City staff shall incorporate the findings, policy goals and statements, and actions set forth below into Section 34 of the City Council’s Handbook, as a new Policy 34.7, “Securing Our Water Future and Water Supply Augmentation Policy Guidance”:

1. Statement of Findings:

1.1 Water is essential to life. Managing Santa Cruz’s water resources in a manner that protects the watershed, respects wildlife and the habitats it depends on, and produces and delivers a high quality and reliable supply of water that protects public health and safety and supports economic prosperity will ensure a secure water future for our community.

1.2 Over many decades, Santa Cruz residents and water service customers have placed a high value on stewardship approaches for the management of our region’s natural resources and have expected publicly owned natural resources to be managed in a manner that ensures long-term sustainability, protection, and enhancement of ecosystems to support and restore threatened and endangered species, and to serve the needs of the community.

3.10 RESOLUTION NO. NS-30,

1.3 As identified by the WSAC in its 2015 report, inadequate water system storage is the critical limiting factor that exposes Santa Cruz water service customers to serious shortages and burdensome and unsustainable levels of curtailment should multi-year droughts deplete stored water in Loch Lomond reservoir. The WSAC explicitly acknowledged in its problem statement that long-term water conservation alone cannot ensure supply reliability for Santa Cruz water service customers.

1.4 Santa Cruz water service customers have embraced water use efficiency as a way of life, achieving an unprecedented level of residential indoor and outdoor use of 44 GPCD, with indoor only use stable at 35 GPCD and have taken actions to significantly reduce outdoor water use by more than 35% over the last two decades, which means that the opportunity to include further customer water use curtailments as key elements in Securing Our Water Future is severely limited.

1.5 Due to current customer water use practices, should curtailment of demand be required, mandatory water rationing will be needed. All stages of the City’s 2021 Water Shortage Contingency Plan (WSCP) include water rationing in which already highly efficient water use by residential and business customers would be curtailed. To protect the availability of water for public health and safety purposes under water shortage conditions requiring implementation of the WSCP, Section 16.01 of the Santa Cruz Municipal Code establishes significant excess use penalties and other actions for non-compliance with rationing allotments, which could further subject residential and business customers to financial hardship.

1.6 The results of the Economic Impacts of the Costs of Curtailments developed as part of the Securing Our Water Future process indicates that consequences of routine and potentially significant water use curtailments to water service customers and the impacts to the region’s economy and quality of life are both significant and seriously negative These consequences can be mitigated through expeditious action to add new resources to Santa Cruz’s water supply portfolio.

1.7 Climate change, which is already influencing weather patterns in Santa Cruz, is expected to increase the annual variability of Santa Cruz’s water supply. This means that more frequent and longer drought conditions are likely, that there will be fewer normal and moderately wet years and that wet conditions, when they occur, are likely to substantially increase flooding events because of a shift in the pattern of precipitation to shorter and significantly more intense storms. This increased variability is a substantial change from historic conditions and is the key driver of sizing supply augmentation projects.

1.8 Long-term demand projections for the Santa Cruz water service area include modest growth over the 25-year demand projection period and reflect water use required to accommodate increased housing, mostly in the form of multi-family housing, and the additional water that is needed to support student housing as identified by University of California at Santa Cruz’s 2020 Long Range Development Plan.

1.9 Even without additional modest growth in water demand, the Santa Cruz water system cannot provide reliable service to its customers because of its lack of storage and resulting vulnerability to severe water shortages should dry conditions persist over multiple years.

3.11 RESOLUTION NO. NS-30,

1.10 Because the impacts of climate change on Santa Cruz’s water resources are already being experienced, there is an urgent need for immediate and sustained action to implement additional supply augmentation projects as needed to meet the reliability goal established by this policy. Additionally, appropriate adaptive management tools and techniques need to be implemented over time to assure that, as climate impacts evolve, supply reliability will continue to be a focus of assessment and action.

1.11 Based on Climate Stress Testing and Vulnerability Analysis work completed by Dr. Casey Brown and the Water Department’s consultants, near term climate change trends indicate increasing variability will be more of a challenge than changes in mean annual precipitation. Longer term climate trends include both increased variability as well as reduced precipitation, resulting in significantly more challenging conditions of longer, more frequent, and deeper droughts.

1.12 Selecting an initial climate scenario for use in assessing the volume of water needed to meet the reliability goal described in Section 2.1 below involved looking at drought conditions across all 10 Climate Realizations identified and evaluated by Dr. Brown and his team and presented and discussed with the Santa Cruz Water Commission in the summer and fall of 2022. The worst-case conditions identified were from Realization 1270, which has a challenging fiveyear drought sequence, that turns out to be the worst-case drought for deficits under several different versions of assumptions about precipitation change, including no precipitation change and -10% precipitation change, and under 1.0,

1.1, and 1.2 Coefficients of Variability.

1.13 Our understanding of and need to continue our work to adapt to climate change is supported by the Vulnerability Analysis, Climate Stress Testing, Water Balance and Santa Cruz Water System modeling tools that have been developed by the Water Department and its consultants as part of the Securing Our Water Future and WSAIP work. Maintaining, updating, and using these tools to inform climate adaptation planning for water supply will be key to the timely development of needed water supply augmentation projects and climate adaptation strategies for ensuring the resilience of water system and its facilities in the face of climate change.

2. Water Supply Reliability Goal

2.1 The City of Santa Cruz’s water supply reliability goal shall be achieved by having an adequate supply to meet all customer demand under plausible, worst-case conditions.

2.2 The initial assessment of plausible worst-case conditions shall be based on the review of Water Supply Vulnerability Analysis and Climate Stress Test work completed by Dr. Casey Brown and his team in the summer and fall of 2022 using the following parameters:

2.2.1 Temperature Parameter: 2° C increase in temperature (dT = +2º C),

2.2.2 Precipitation Parameter: No change in precipitation (dP =100% of average), and

2.2.3 Coefficient of Variability Parameter: A +10% coefficient of variability (CV = 1.1).

3.12 RESOLUTION NO. NS-30,
In selecting these initial climate change parameters to use as the basis for nearterm planning for supply augmentation projects, staff has considered a wide range of climate scenarios and chosen parameters that are moderate, plausible, and attempted to choose parameters that do not either over- or under-estimate the potential implications of near-term impacts of climate change on local water resources and water supply reliability.

The parameters shall be reviewed and updated no less frequently than every five years as part of the regular update of the City’s Urban Water Management Plan.

The resulting review and revision may result in modifications to the volume of water that needs to be developed to meet the water supply reliability goal articulated in 2.1 above.

2.3 As curtailment of demand under the provisions of the state mandated Water Shortage Contingency Plan has been found not to be an effective tool for addressing anticipated water shortages for longer or more frequent dry conditions, its use shall be limited to the infrequent implementation of Stage 1 of the plan where the 10% demand reduction associated with Stage 1 curtailments is determined to be critically necessary to protecting supply availability for public health and sanitation purposes.

3. Santa Cruz’s Water Supply Portfolio

3.1 Resources available to achieve water supply reliability in Santa Cruz are limited to those available locally, including surface water flows from local rivers and streams during wet seasons, local groundwater resources, various forms of advanced treated recycled water, and seawater desalination.

3.2 These supply augmentation source options have been found to be technically viable and reliable from a long-term availability perspective considering the potential impacts of climate change. In various circumstances as they may develop into the future, development of one or more of these sources may be determined to be the most appropriate and effective way to ensure water is available to meet the City’s public health and safety and economic sustainability goals.

4. Considerations In Developing Water Supply Augmentation Projects As part of the Securing Our Water Future process, Water Department staff worked with Water Commissioners to use, adapt, and update as needed the evaluation criteria developed and recommended by the WSAC. This policy incorporates these criteria as updated by the Department’s active engagement with the Water Commission in the years following completion of the WSAC’s work.

The goal of integrating the guiding principles, key criteria and additional criteria in this policy is to confirm that these criteria are important to the consideration and selection of supply augmentation projects to pursue and to set an expectation for transparency.

Attachment A to this resolution and policy includes more detailed definitions of each of the criteria.

4.1 Guiding Principles

3.13 RESOLUTION NO. NS-30,

4.1.1 Public Health – Protecting public health is every water utility’s most fundamental duty. The Water Department as an organization, and its individual employees, work every day to produce and deliver an adequate supply of high-quality water that complies with numerous public health-based regulatory standards and is used for human consumption, sanitation, for other domestic and commercial use and for fire protection.

4.1.2 Affordability and Equitable Access to Water Service – Water service is critical to public health and community wellbeing. The City and Water Department recognize that rising costs of water to address system vulnerability, climate adaptation and supply reliability present affordability challenges to customers and, consistent with the City’s Health in All Policies policy, is committed to taking steps during the planning and implementation of projects to ensure a reliable water supply and equitable access to service for everyone. Given the limitations of Proposition 218 that prohibit directly subsidizing the cost of water service for those least able to pay, options for locally addressing water affordability are limited, but staff is committed to continuing to advocate for state and federally funded programs for those in need.

4.1.3 Public Acceptance – During the WSAC process and throughout the ensuing work in collaboration with the Water Commission over the intervening years, connecting with community interests, customers, and members of the public about the need for and the approach to improving the reliability of Santa Cruz’s water supply has been a key focus of the design and execution of the Department’s work. Along with the yield, costs, timeliness, and technical feasibility of various supply augmentation alternatives, the WSAC identified and applied criteria reflecting the community’s values, and also considered energy use, and environmental impacts of the alternatives. All the WSAC’s values and considerations have been carried forward in the work that has occurred following the end of the WSAC process and are recommended to be carried into future work as important criteria that, when objectively evaluated and transparently communicated, are aligned with the goal of establishing and maintaining public trust.

4.1.4 Regional Collaboration – Consistent with the goal of achieving a sufficient water supply, the City is committed to regional collaboration to improve water supplies, achieve groundwater sustainability, protect the Santa Cruz MidCounty Groundwater Basin from further seawater intrusion and support the protection and restoration of critical aquatic habitats and the resources dependent upon these ecosystems.

4.1.5 Incremental Implementation – The reality of developing a water supply augmentation project is that such projects take a long time to fully develop due to the required feasibility work, environmental reviews, design and permitting and what is often multi-year construction. Projects developed with regional partners also require development of agreements and funding arrangements at various stages of the work, which also requires time and effort. An incremental implementation strategy supports near-term progress that is important for reducing Santa Cruz’s vulnerability to water shortages caused by multi-year droughts while also allowing for simultaneous work on the often-time-consuming early planning and feasibility work to move forward with long-term projects.

3.14 RESOLUTION NO. NS-30,

4.1.6 Ongoing Community Engagement – The Santa Cruz Water Commission has a long history of engagement with the Water Department on supply augmentation planning and shall continue to be a forum for the active engagement of community interests and the public in this important work. A key goal of Water Commission engagement shall be to maintain transparency through the process of developing and implementing water supply augmentation projects.

4.2 Primary Evaluation Criteria

4.2.1 Cost Metric – Cost-effectiveness is an important consideration in decision-making about supply augmentation projects under development. Useful cost metrics include total capital costs, annualized capital costs, annualized operation and maintenance costs, and unit costs based on both average production and maximum production. To the degree feasible, cost-effectiveness data will be developed and compared for available supply augmentation alternatives at the time a decision is made to proceed forward with a project or pursue an alternative.

4.2.2 Yield Metric – The Yield Metric is the most straightforward and quantifiable of the evaluation criteria. The supply reliability goal described in Section 2 of this policy is used to define the yield needed to achieve reliability. Project yield analyses need to relate to the volume of water needed to meet the supply reliability goal, as it is defined and updated at least every five years as part of the update to the Urban Water Management Plan.

4.2.3 Timeliness Metric – Water projects typically take a decade or more to develop and implement. Planning work on supplemental water supply has been underway since completion of the WSAC work in late 2015. The WSAC’s timeliness metric set a 10-year target for achieving water supply sufficiency, with sufficiency defined as having a fully functional water system able to meet the supply-demand gap forecasted during extended droughts.

The Securing Our Water Future Policy acknowledges that, due to the length of time required to develop supply augmentation projects, and the need to use an ongoing and evolving understanding of the impacts of climate change on water supply reliability, incremental implementation of augmentation projects to address the supply deficit will be required. To reduce the vulnerability to nearer term droughts, however, supply augmentation producing at least 500 million gallons a year of additional supply by 2027 should be completed.

4.3 Additional Criteria – The following additional criteria are further characterized and defined in Attachment A-1 to this policy. These criteria are aligned with the criteria and values developed by WSAC for use in evaluating water supply augmentation projects and sharing those evaluation results with the community to support both data-driven and transparent decision-making:

4.3.1 Project’s supply contribution as a percent of worst year supply shortfall;

4.3.2 Increases resilience to climate change;

4.3.3 Is understood and accepted by the public and key stakeholders;

4.3.4 Scalable or can be implemented incrementally or in phases;

4.3.5 Technical feasibility;

4.3.6 Likelihood of project being funded by state or federal grants;

3.15 RESOLUTION NO. NS-30,

4.3.7 Opportunity for shared funding;

4.3.8 Greenhouse gas emissions (from both construction and operations);

4.3.9 Time required for implementation;

4.3.10 Operational complexity;

4.3.11 Energy use;

4.3.12 Potential impacts for CEQA-required mitigation;

4.3.13 Adaptable to future regulatory or source water changes; and

4.3.14 Degree of administrative complexity.

5. Policy Implementation
Subject to the same general terms and provisions for Council review and approval used for the development and implementation of capital investment projects in the City of Santa Cruz, the Santa Cruz Water Department is authorized to pursue any of the following or other similarly related activities in implementing this Policy:

5.1 Conduct planning, preliminary engineering, and technical feasibility analyses for supply augmentation alternatives;

5.2 Consider Primary and Additional Evaluation Criteria in Section 4, evaluate and select supply augmentation projects needed to achieve the Water Supply Reliability Goal described in Section 2 of this Policy;

5.3 Prepare project designs, environmental reviews, and complete project permitting activities;

5.4 Select and implement project development and construction delivery methods using any procurement method authorized by the City Charter and Municipal Code;

5.5 Recommend for Council consideration and action any other steps required to achieve compliance with Section 1431.3 of the City Charter (2012 Measure P requirement for a public vote prior to construction of a desalination plant); and

5.6 Develop and recommend to the City Council for consideration or action as appropriate any agreements with other regional water providers for partnerships, joint ventures, or other collaborative approaches to improving water supply reliability, groundwater sustainability, environmental, and natural resource management and protection, or mutually beneficial projects or partnerships in support of water supply and water system resiliency, and climate adaptation.

The Water Department will continue to actively engage with the Santa Cruz Water Commission and the public in the implementation of this Policy as well as inform and involve the larger community, customers, and interests as appropriate.

PASSED AND ADOPTED this 29th day of November 2022, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

3.16 RESOLUTION NO. NS-30,
APPROVED: ______________________________
Sonja Brunner, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator

3.17 RESOLUTION NO. NS-30,
Additional Supply Evaluation Criteria

WATER SUPPLY PROJECT EVALUATION CATEGORIES, SUB-CATEGORIES AND DEFINITIONS

QUANTITATIVE CATEGORIES
Criterion Definition or Explanation
The criterion provides information about:

Project Costs
 Annualized cost per million gallons (and acre
foot) of supply
 Full cost analysis of operating and capital costs
for the project
Project Yield
 Project supply contribution as a % of the
worst year supply shortfall
 The percent contribution to reducing the worst
year supply gap provides information about the
degree to which a project can contribute to
closing the supply gap
Energy Profile and Climate Mitigation
 Energy use (KWh/year)  The amount of energy required annually to operate the project.
 Greenhouse gas emissions associated with the
project (metric tons of carbon dioxide
equivalents released (MT of CO2e))
 The amount of greenhouse gases associated
with the construction and operation of a
project. (Similar to the energy version of
annualized or life-cycle cost)
Timeliness
 Time required to begin producing additional
an increment of water that makes a significant
contribution to improving the system’s water
supply reliability (months/years)
 The number of years required (from date of
evaluation and green light to proceed) to
complete technical feasibility work, pre-design,
design, CEQA, permitting, construction,
commissioning and start-up of a project that
produces additional water supply
Technical Feasibility
 Technical Feasibility (yes/no ratings for each
element that comprises a project’s technical
feasibility benchmarks)
o Example sub-elements for technical
feasibility can include constructability
 The technical and engineering aspects of a
project are realistic and achievable and can and
will contribute to improving supply reliability
 Operational complexity (high/medium/low)  Whether/how the project’s operation does or does not add significantly to the operational
complexity of the existing system

3.18 RESOLUTION NO. NS-30,
Qualitative Categories
Criterion Definition or Explanation
The criterion provides information about:

Environmental Impact
 Potential impacts of any CEQA-required
mitigation that could significantly affect
project cost, yield or timeliness parameters
(high/medium/low or additional gradations
of this scale)
 The likelihood for potentially large impacts
to cost, yield, or timeliness parameters
from CEQA required mitigation for the
supply augmentation project.

Funding and Financing
 Likelihood of the project being fundable
with federal or state grant funds (highly
likely/unlikely with gradations)
 The potential for the project to be grant
funded. An example is the US Bureau of
Reclamation’s Title XVI grant program
that is specifically designed to fund
recycled water projects.
 Opportunity for shared funding (yes/no)  The potential for shared funding through partnerships with other regional water
agencies.

Public Acceptability
 The degree to which there is public
understanding and acceptance for the
projects under consideration.
 Whether a project (or projects) is
understood and accepted by the public and
key stakeholders.

Administrative Feasibility
 Degree of complexity with respect to
regulatory, permitting, right of way, or
legal issues and the time required to
address and resolve the identified issues
(for complexity: high/ medium/low)
(for time requirement: number of months or
years)
 The complexity and time required to
address regulatory, permitting, right-ofway and/or legal issues related to a supply augmentation project and the amount of
time needed to address or resolve those
issues.

Adaptive Flexibility
 Increases resiliency to climate change
(high, moderate, low) specifically related
to:
o Certainty of supply during drought
o Certainty of supply during extreme wet
weather;
o Vulnerability to shifting patterns of
precipitation due to climate change;
o Seawater intrusion;
o Coastal inundation and sea level rise;
o Natural disasters (e.g., wildfire ,
seismic events, etc.)
 How a project may (or may not) be able to
adapt to changing conditions or be
functional in the face of climate change,
wildfire, seismic or other natural disasters.

Qualitative Categories
Criterion Definition or Explanation
The criterion provides information

3.19 RESOLUTION NO. NS-30,
about:
 Project includes characteristics that provide
for scalability or provide for it to be
implemented incrementally or in phases
over time (yes/no)
 The degree to which the project can be
relatively easily expanded or scaled up over
time or implemented in increments or
phases.
 Adaptability to future uncertainty from
regulations or source water changes
(yes/no)
 Whether or how well a project may (or may
not) be able to adapt to changing
regulations or source water quality
changes.

3.20 SUMMARY TECHNICAL MEMOS
The Santa Cruz Water Department is a municipal utility that is owned and operated by the City of Santa Cruz. With an estimated population of approximately 98,000, water service is provided within the City limits as well as areas of the County, a small part of the City of Capitola, and coastal agricultural lands north of the City.

The City water system is comprised of four main water supply sources: 1) the North Coast sources; 2) the San Lorenzo River; 3) Loch Lomond Reservoir; and 4) the Live Oak Wells. The system relies entirely on rainfall, surface runoff, and groundwater infiltration occurring within the watersheds located in Santa Cruz County. No water is purchased from state or federal sources or imported to the region.

One of the City’s major challenges in meeting current and future water supply needs is the lack of adequate water supply especially in dry years. Compounding this issue are the uncertainties that have the potential to reduce or otherwise impair the City’s water supplies: global climate change and the corresponding impact on local surface and groundwater supplies.

Enclosed in this Attachment A are summaries of the three pieces of technical work in support of the Securing Our Water Future policy. These three pieces answer the following three questions, respectively:

1. How vulnerable is the City to changes in temperature and precipitation because of climate change?

2. How could example projects using the local source water supplies available in Santa Cruz (i.e., surface water, recycled water, and seawater), meet demands resulting from the findings from above?

3. What is the economic impact of potential water supply curtailments that would be needed if significant droughts occur and water supply projects have not been implemented, and how does this compare with the various supply options from the findings in (2) above?

3.21 SECURING OUR WATER FUTURE
November 3, 2022 Page 1

SUMMARY MEMO
Santa Cruz Climate Vulnerability Assessment and Climate Stress Testing and
Effectiveness of Water Supply Augmentation Project Concepts in Addressing Shortages INTRODUCTION:

In water supply planning processes, modeling is a critical tool that supports assessing both the size of the water supply problem that needs to be addressed and how various supply options contribute to reducing or eliminating anticipated shortages. Historically the Santa Cruz Water Department has used the 1990s era Confluence® model for this purpose. Confluence served the City well until it became clear that there was a need to have a modeling system that provided a more robust capacity to evaluate potential future climate changes and their impact on water supply.

Water Department staff and a team of consultants led by Dr. Casey Brown from the University of Massachusetts at Amherst’s Hydrosystems Research Group and Dr. Shawn Chartrand formerly of the City’s long-time hydrology consultant, Balance Hydrologics, and now at Simon Fraser University’s School of Environmental Science in Vancouver, British Columbia, and including Gary Fiske with his long experience supporting water supply modeling for the Confluence model, has developed a new water supply planning model for the Santa Cruz water system that is now in use. This model is called the Santa Cruz Water System Model (SCWSM).

This memo provides a high-level overview of the components of the SCWSM and of key results of the water system vulnerability assessment and evaluation of the effectiveness of water supply augmentation project concepts developed to support the Securing Our Water Future policysetting process.

Referenced at the end of this Summary Memo are slides from several power-point presentations provided by Drs. Brown and Chartrand to the Santa Cruz Water Commission on May 2nd, July 21st, August 29th, and October 3rd, 2022. Audio and video files for these meetings are available at cityofsantacruz.com/AllMeetings/WaterCommission and links to each meeting are provided in the reference section to this Summary Memo.

VULNERABILITY ANALYSIS INPUTS TO THE SANTA CRUZ WATER SYSTEM MODEL:

Figure 1 is a schematic of the approach being used to conduct the climate vulnerability analysis using the new SCWSM. Two key inputs, the Santa Cruz Climate Scenario Generator and the Water Balance Model, are used together to create thousands of different climate scenarios that are then run through the SCWSM to see how the system performs across a large range of plausible future climate conditions. The product is a long-term vulnerability assessment where tipping points (or thresholds) are identified. Thresholds are defined as climate conditions (i.e.,

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future change in average change in precipitation and temperature) from which the system is no longer performing with the expected level of performance.

Figure 1 – SCWSM Key Inputs and Outputs
Each of the key vulnerability analysis inputs is discussed in more detail below.

Santa Cruz Climate Scenario Generator
Climate change is introducing new challenges for water suppliers. One of those challenges involves identifying climate scenarios to evaluate. Among other things, when choosing climate scenarios, it is important to ensure that those selected provide enough diversity so that planning addresses a reasonable range of potential futures.

The SCWSM’s Climate Scenario Generator creates a wide range of tailored climate change scenarios that are used for “stress testing”1 the water system. Five thousand plausible climate scenarios (hereafter called realizations) were created to represent the historical climate variability in terms of precipitation and temperature.

Among these 5,000 realizations, ten were selected for use in further detailed analyses (numbered colored dots in Figure 2.) The selected realizations best represent the historical climate variability; for instance, the blue and green colored dots Figure 2 shows the 10 selected realizations are clustered around the historical values. Next, future climate change scenarios are created from these 10 realizations by altering some of their statistics, namely the average 1 Stress testing involves assessing how the water system performs over a wide range of plausible future conditions and helps identify the specific conditions that are most challenging for the system.

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temperature (increases of zero to + 7 º C), the average precipitation (ranging from minus 40% to plus 40%) and annual precipitation variability (increase in coefficient of variation2 up to 50%).

Figure 2 – Climate Scenarios with Selected Realizations shown as Numbered Colored Dots3 Water Balance Model
Water systems that are dependent on surface water resources such as Santa Cruz’s will typically use hydrologic datasets (flow sets) as an integral input to water system planning. Santa Cruz Water Department has worked with Shawn Chartrand and Balance Hydrologics for decades on 2 The coefficient of variation is a relative metric that expresses how much a variable fluctuates around its means.

Higher coefficient of variation means that the variable fluctuates more. 3 The vertical axis in Figure 2 shows the monthly standard deviation of precipitation as a % of historic standard deviations.

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preparing flow sets4 for input to the Confluence model to support a wide range of analyses and planning products, including:
 Anadromous Salmonid Habitat Conservation Plan development;  Water Supply Advisory Committee water supply planning work (2014-2015), and  Santa Cruz Water Rights Project Change Petitions and Environmental Impact Report.

More recently, Dr. Chartrand has been supporting the water system vulnerability analysis through the development of thousands of new 100-year flow sets using the Climate Scenario Generator’s potential future climate options (combinations of future temperatures and precipitation) to be utilized in the water system vulnerability analysis.

Table 1 shows the full spectrum of the scenarios that have been developed, and an example of the 100-year flow sets is provided in Figure 3 below. The scenario in Figure 3 is for Climate Realization 1270, with a 2 degree C increase in temperature, a 10% decrease in annual precipitation, and no change in the coefficient of variability.

Table 1 – Full Range of Climate Change Scenarios for Use in Stress Testing 4 Flow sets are developed as a key input to modeling Santa Cruz’s surface water resources that are available for diversion to water supply. Available water is diverted up to various constraints such as water rights, hydraulic capacities of various system facilities, customer demand, etc. Since developing agreements with state and federal fishery agencies, flow sets for diversion to water supply are resources available after fish flow provisions have been met.

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Figure 3 – 100 Year Hydrology for Climate Realization 1270, dT= +2, dP = -10%, CV = 1.0 Running all climate scenarios described in Table 1 through the water balance model produced a wide range of new hydrologic sequences, each covering a 100-year period. This means the new robust set of potential hydrologic futures being used for planning is both varied and plausible.

Running the SCWSM with the new hydrologies’ modeling results provides insights into how the system performs, for example, during multi-year droughts and supports an ability to evaluate the occurrence of water shortages and their intensity for these future climate conditions, including for identified challenging sequences of back-to-back dry conditions.

Figure 3 provides an example of a challenging back-to-back critically dry year sequence shown in the red circled area of Figure 3. This scenario is a five-year drought that, without supply augmentation, produces three years of back-to-back significant shortages with year 3’s shortfall being 1 billion gallons, year 4’s being 1.1 billion gallons, and year 5’s being 200 million gallons, for a three-year cumulative total of 2.2 billion gallons. The shortages in the last three years of the five-year sequence are so significant because Loch Lomond storage is depleted during the first two years in the drought and precipitation during the subsequent winters wasn’t enough to even partially replenish storage.

SCWSM also provides a way to assess the benefit of supply augmentation options in reducing the occurrence and intensity of water shortages.

Climate Scenarios Peer Review Panel
Using climate scenarios that are plausible is important to establishing and maintaining the legitimacy of the water supply augmentation work. In his October 2022 Water Commission meeting presentation, Dr. Chartrand provided a detailed assessment of historic trends in local temperature and precipitation data that show that climate change is already occurring in Santa

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Cruz. This analysis provides a strong foundation for the approach to creating climate change scenarios for the SCWSM’s forward looking work on water supply planning.

Earlier in the development of SCWSM and related vulnerability analyses tools, a third-party peer review panel5 was convened to review the assumptions, methods, and products for the critical weather and hydrology inputs to the SCWSM that drive model outcomes. Excerpts of the peer review panel’s comments include:
 “The methods […] used to produce the weather generator flows (the Water Balance Model) are satisfactory, very thorough and rigorous.”
 “[…] provide a credible baseline dataset for stress testing”  “the climate perturbation range proposed […] provides an appropriate and adequately taxing range of conditions over which to test system reliability” Additionally, the review panel made the following recommendation:
 “an additional axis of uncertainty [should be] considered to test the system against changes in precipitation variability of up to +50% increase in the coefficient of variation of precipitation.”
Coefficient of Variation
This peer review panel’s recommendation on variability of precipitation relates to an emerging weather pattern often referred to as “whiplash weather,” in which year to year variability in yearto-year precipitation is increasing resulting in wetter wet years and dryer dry years. Dr.

Chartrand’s October 2022 Water Commission meeting presentation shows examples of whiplash weather from recent history as well highlighting similar conditions in some of the climate change hydrologies6 created by the Water Balance Model that are being used in supply planning.

Climate scenarios with increased variability basically result in the wet years getting wetter and the dry conditions becoming drier and longer lasting, although mean annual precipitation levels may not change or slightly deviate from the historic annual mean. For Santa Cruz, longer and more intense dry conditions are particularly challenging because of Santa Cruz’s limited ability to store water in wet years that can provide enough stored water for use during drier years or multi-year periods. Using one scenario presented to the July 2022 Water Commission meeting, a 10% increase in variability resulted in about a 20% increase in the volume of shortage over the 5 William Werick, Joseph Barsugli, and Andrew Schwarz P.E. were convened as the Peer Review Panel for the Weather Generator Model and Climate Change Stress Test, which produced its final report in September 2021. Mr.

Werick is a water resources planner Werick Creative Solutions LLC in Culpepper Virginia. Dr. Barsugli is a research scientist at the Cooperative Institute for Research in Environmental Sciences at the University of Colorado at Boulder. Andrew Schwarz is the State Water Project Climate Advisor for the California Department of Water Resources.
6 Climate change hydrologies are specific 100-year flow set for a climate realization, with specific assumptions about temperature change (from 0º C to 7º), precipitation change (from -40% to +40%) and coefficient of variation (from 1.0 to 1.5).

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three worst years. A 20% increase in variability of precipitation increased the volume of shortage estimated for the same condition by nearly 50%.

OUTPUTS OF THE SANTA CRUZ WATER SYSTEM MODEL
Those familiar with the decades-long water system planning work completed by the Santa Cruz Water Department will recognize the kinds of products typically produced by modeling exercises. Included are things like projections of the size and frequency or probability of shortages analyzed under base case conditions7 reflecting the existing water system, and under conditions in which identified supply augmentation options are implemented. These projections were made using historic hydrologic conditions and/or a limited number of climate change hydrologies. For example, Water Supply Advisory Committee and Water Commissioners have seen modeling work looking at how changes in the Graham Hill Water Treatment Plant treatment process could contribute to increased supply due to increased ability to treat more turbid water than the current plant can handle.

With the advent of increased computing speeds and modeling approaches, the new SCWSM has greatly expanded capability to look at varying conditions and options, including a much greater ability to consider how potential future climates could affect system performance without and with the benefit of various water supply augmentation strategies. The sections below briefly describe the key uses and results of the modeling work completed to date.

Climate Stress Testing
Climate stress testing is a major objective of the work done to develop the new SCWSM and vulnerability analysis tool. Stress testing allows planners to assess conditions such as changes in temperatures, precipitation, or variability associated with climate change and to projected demand to understand the condition changes that are most challenging. Specific objectives include:
 Simulate the widest range of plausible futures to understand sensitivity of the system to climate change conditions;
 Identify climate change conditions that are problematic for the system and are determined to be vulnerabilities of the system;
 Understand the probabilities and size of water supply shortages under various conditions to select climate scenarios to use for water supply planning and for setting a water supply reliability goal.

Climate stress test and vulnerability analyses results were presented at the July 2022 Water Commission meeting. Results were based on the worst year water supply shortage projected from the ten selected Realizations, which turned out to be a five-year drought sequence from Realization 1270. As noted earlier, when modeled, this drought sequence produces a total shortage of 2,200 MG, and shortages weren’t recorded for years one and two of the five-year 7 Base case conditions means conditions without the impacts of climate change.

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sequence because storage has been used to meet the deficits during the first two years of the drought. Table 2 summarizes the stress testing results for the last three years of the five-year drought for worst-case condition and for the 98th percentile shortage.8 Table 2 summarizes the results.

Table 2 Cumulative Shortages under No-Climate Change and Climate Change Scenarios Using 2020 Water System Demands of 2.6 billion gallons/year 98th percentile of deficit (MG) Maximum deficit (MG)
dP9
dT10
0%
0C
-10%
+2C
0%
0C
-10%
+2C
YR 3 27 (1%) 243 (9%) 923 (35%) 1065 (41%)
YR 4 139 (5%) 650 (25%) 1535 (59%) 2095 (80%)
YR 5 257 (10%) 840 (32%) 1561 (60%) 2205 (85%)
The results from Table 2 show the extreme sensitivity of the water system to worst year conditions, with significant increases in deficits between a 98th percentile calculated shortage and a maximum (worst case) shortage. Table 3 provides more detail.

Table 3 Comparison of Cumulative 98th Percentile and Worst-Case Deficits under No Climate Change and Climate Change Scenarios
No Climate Change -10% Precip +2ºC Climate Change
98th
percentile
deficit
(MG)
Maximum
deficit (MG)
98th percentile
deficit as a
percent of the
maximum deficit
98th
percentile
deficit (MG)
Maximum
deficit (MG)
98th percentile
deficit as a
percent of the
maximum deficit
YR 3 27 923 3% 243 1065 23%
YR 4 139 1535 9% 650 2095 31%
YR 5 257 1561 16% 840 2205 38%
8 The 98th percentile shortage has a 2% chance of occurring in any given year. Sizing a water supply augmentation strategy to meet the shortage deficit for the 98th percentile event requires a smaller volume solution but basically leaves the system exposed to low probability but, as it turns out, very high consequence shortage events be dealt with via other means such as curtailment of demand. Due to the highly efficient water use practices of Santa Cruz’s water users, demand curtailments are not a very effective options for dealing with large supply deficits as curtailments would need to be deep and potentially long-standing. 9 dP = assumption in the climate change hydrology about change in precipitation 10 dT = assumption in the climate change hydrology about change in temperature

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Even without the impacts of climate change, the 98th percentile 3-year cumulative shortage is just 16% of the maximum deficit. For the climate change scenario, the 98th percentile deficit is 38% of the maximum.

The results shown in Table 3 demonstrate what has generally been understood, which is that climate change is likely to make water supply deficits larger, but also show the significant difference between the size of shortages between a 98th percentile figure and the worst-case deficit. These results are important to consider when thinking about sizing water supply augmentation projects and making decisions about the system’s water supply reliability goal.

Adding a lower volume of additional supply and depending on curtailments to make up the difference may expose customers and the community of the potentially significant and unsustainable levels of curtailments than would be required if the amount of supply augmentation is larger.

Effectiveness of Water Supply Augmentation Project Concepts in Addressing Shortages To support the Securing Our Water Future policy setting process, Water Department staff has worked with the Kennedy Jenks consulting team led by Claudia Llerandi P.E. to develop a set of water supply augmentation project concepts to evaluate their ability to contribute to reducing or eliminating the water supply deficits identified in the vulnerability analyses and climate stress tests. The four project concepts11 that have been developed include:

1. Aquifer Storage and Recovery (ASR) in the Santa Cruz Mid-County Groundwater Basin;

2. Indirect Potable Reuse (IPR) of advanced treated wastewater in the Santa Margarita Groundwater Basin;

3. Direct Potable Reuse (DPR) of purified wastewater (advanced purified and disinfected); and

4. Seawater Desalination.

These four projects are examples of the kinds of water supply augmentation options that the City has available using local surface water, wastewater, and seawater resources. The four projects included differing assumptions and constraints, but the constraints are not based on typical constraints used in water system modeling, for example, pipeline hydraulic capacity. Rather, the constraints are based on what was known at the time about how the projects could be configured.

Other options exist for configuring projects or combining project types into water supply portfolios, and these options will be more fully explored in the planned Water Supply Augmentation Implementation Plan (WSAIP) process that will be completed in 2024.

In addition to using the four water supply augmentation project concepts to assess how they would reduce or eliminate supply deficits, a second goal was to compare these project concepts against the WSAC’s recommended key performance metrics and criteria such as cost, timeliness, yield, greenhouse gas production, operational complexity etc. The results of this comparative 11 See Attachment A-2 for the Water Supply Augmentation Project Concepts for details

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evaluation along with additional details for each project are covered in a separate Summary Memo. Here the focus is on how the projects contribute to deficit reduction.

In developing the project concepts, the ASR and IPR projects assume different volumes of both water available to store in the two local groundwater basins (the Santa Cruz Mid-County Groundwater Basin and the Santa Margarita Groundwater Basin, respectively) and different volumes of water that are available for withdrawal based on constraints associated with the Groundwater Sustainability Plans for each basin. For the DPR and Desal, both projects assume the construction and operation of treatment facilities with a 3 million gallon per day capacity, which is why the results for these two projects are shown together. Figure 4 summarizes the results of the analysis of how each project impacts deficit reduction.

Figure 4 Supply Augmentation Projects Impacts on Deficit Reduction12 Realization 1270, +2º C, -10% Precipitation, 1.0 Coefficient of Variation Figure 4 shows that both ASR and IPR have some impact on reducing the cumulative deficits in the climate change scenario being modeled. However, neither of the options, as configured in the project concepts can fully address the modeled deficits. It may be that other configurations of these options, or perhaps a combination of these options, would have a bigger impact, but that is not the question that is being evaluated at this time. The Water Supply Augmentation Implementation Plan (WSAIP) also under development will tackle those issues.

For DPR and Desal, both plants were modeled based on a 3 million gallon per (mgd) day facility operating at 1 mgd during the winter, 2 mgd during the summer and at 3 mgd when Loch 12 As noted earlier, the scenario being evaluated in this example is a 5-year drought sequence in which no shortages are recorded in years 1 and 2 (2056 and 2057) because available storage in Loch Lomond is being drawn down to cover customer demand.

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Lomond reservoir level falls to 2 billion gallons and run at 3 mgd until Loch Lomond recovers to full capacity. Clearly these operating assumptions influenced the unmet deficit show in Figure 6.

As work on the WSAIP proceeds, alternate operating assumptions for these two augmentation strategies will be evaluated to document their performance in reducing or eliminating deficits.

CLIMATE CHANGE SCENARIO TO USE IN SUPPLY PLANNING
Work presented to the Water Commission at its July, August and October meetings focused on looking at the worst year drought across all 10 climate realizations. Realization 1270 with its five-year drought sequence turns out to be the worst-case drought for deficits under several different versions of assumptions about precipitation change, including no precipitation change and -10% precipitation change, and under 1.0, 1.1, and 1.2 Coefficients of Variability.

Selecting an initial scenario for use in assessing the volume of water needed to reliably meet demand involved several iterations but ultimately resulted in identifying two scenarios with common outcomes:

1. Realization 1270, no precipitation change (dP = 100), +2° C temperature change (dT = +2° C) and a Coefficient of Variation of 1.1 (CV = 1.1); and

2. Realization 1270, -10% precipitation change (dP = 90%), +2° C temperature change (dT = 2° C) and a Coefficient of Variation of 1.0 (CV = 1.0).

These two scenarios both produce maximum deficits of 2.2 billion gallons over the last three years of the five-year drought sequence, which lends robustness to the results and supports using these moderate, plausible scenarios as the initial basis for supply augmentation planning. The policy section of the Resolution on Securing Our Water Future identifies the first scenario as the initial basis for planning for both better simplicity and clarity, choosing the scenario that doesn’t assume a change in precipitation but includes somewhat increased variability because these choices seem more aligned with recent experiences where precipitation patterns are changing more so than total precipitation.

Similar to Figure 4, Figure 5 shows augmentation impacts from the four project concepts but for the Realization 1270, +2° C temperature change (dT = +2° C), a Coefficient of Variation of 1.1 (CV = 1.1), but with no precipitation change (dP = 100),

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Figure 5 Supply Augmentation Projects Impacts on Deficit Reduction Realization 1270, +2º C, No Change in Precipitation, 1.1 Coefficient of Variation

USING THE SCWSM TO SUPPORT WATER SUPPLY AUGMENTATION PLANNING The new climate change and water system models that have been developed over the last couple of years provide the Water Department staff with powerful new tools to use in evaluating and selecting water supply augmentation projects for incremental implementation and ongoing application of adaptive management in the face of uncertainty. The SOWF policy guidance includes specific guidance about using these tools in supply planning and updating modeling results no less frequently than every five years as part of the update of the Department’s Urban Water Management Plan.

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References
May 2, 2022 Water Commission Meeting – Update on Vulnerability Analysis and Climate Change Stress Testing – Dr. Casey Brown
https://ecm.cityofsantacruz.com/OnBaseAgendaOnline/Meetings/ViewMeeting?id=1900 &doctype=1
July 21, 2022 – Workshop on Water Supply Vulnerability Assessment – Dr. Casey Brown https://ecm.cityofsantacruz.com/OnBaseAgendaOnline/Meetings/ViewMeeting?id=1932 &doctype=1
August 29, 2022 – Securing Our Water Future Additional Modeling Results for Supply Augmentation Projects – Dr. Casey Brown
https://ecm.cityofsantacruz.com/OnBaseAgendaOnline/Meetings/ViewMeeting?id=1952 &doctype=1
October 3, 2022 – Securing Our Water Future Additional Modeling Results for Supply Augmentation – Dr. Casey Brown; Presentation on Local Hydrology historic perspective and potential future climate hydrology – Dr. Shawn Chartrand https://ecm.cityofsantacruz.com/OnBaseAgendaOnline/Meetings/ViewMeeting?id=1980 &doctype=1

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City of Santa Cruz Water Department Securing Our Water Future 1

SUMMARY MEMO

2. Water Supply Augmentation Project Concepts

BACKGROUND/CONTEXT
The Securing our Water Future (SOWF) policy framework codifies guidance for selection and implementation of the water supply augmentation projects needed to meet water supply reliability standards as defined in the policy. While the policy characterizes the scale of the water supply shortage, addresses the role of curtailment during drought, and identifies the basic source water options that are available to develop supplemental supply, the project(s) and timing for implementation will be defined in the coming years within the Water Supply Augmentation Implementation Plan (WSAIP) that will be created in collaboration with the Water Commission and subsequently approved by City Council within the next 18-24 months.

To support development of the SOWF policy framework, Water Department staff and consulting team members used work completed over the last several years to create a set of four supply augmentation project concepts. These project concepts provided the information needed to complete the comparison of supply augmentation alternatives identified by the Water Supply Advisory Committee (WSAC).

Project concepts developed for the SOWF were selected because

1. They were identified by the WSAC as potentially feasible alternatives that should be scrutinized in further detail.

2. They demonstrated a degree of feasibility (or met various feasibility metrics) in solving the water supply gap during the intervening years of evaluation (WSAC and present).

3. They included a project concept for each potential source water resource available, providing relevant and comparable information about a full range of project types that could be developed if/when needed.

The project concepts developed for the SOWF do not

1. Include demand management, or water conservation, as this is an ongoing effort where the community has very successfully met and, in fact, substantially exceeded the goals recommended by the WSAC.

2. Include water transfers and exchanges because these alone cannot provide meaningful supply volumes to address Santa Cruz’s anticipated future shortages; however, these will be considered in future evaluations of alternative portfolios in the WSAIP.

3. Necessarily meet the water supply gap entirely, in part because of the focus on the basic sources of water but also because an equitable evaluation requires that concepts be based on similar levels of detail; together this limited the scale of some concepts.

4. Combine with other alternatives. Rather they consider only one source of water and one end use; larger projects or portfolios of projects will be considered during the development of the WSAIP.

5. Face the same regulatory and political challenges. For example, direct potable reuse appears to have regulatory support, but the regulations have not yet been finalized. Similarly, desalination support seems to vary depending on scope and scale of the project.

Attached to this memo are four fact sheets describing each project concept, including a map and description of how each alternative meets the various criteria developed by the WSAC and further vetted with the Water Commission.

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City of Santa Cruz Water Department Securing Our Water Future 2

ALTERNATIVES EVALUATED
The information below describes how and why each project concept was developed, and how they will be considered further in the WSAIP process. As shown in the figure below, these include Aquifer Storage and Recovery in the Santa Cruz Mid-County Groundwater Basin, Indirect Potable Reuse Groundwater Replenishment in the Santa Margarita Groundwater Basin, Direct Potable Reuse, and Desalination.

Aquifer Storage and Recovery (ASR) in the Santa Cruz Mid-County Groundwater Basin (MCGB) The WSAC contemplated the use of excess winter water in the City’s flowing sources, following compliance with instream flow requirements and meeting customer demands, for ASR in the MCGB and/or the Santa Margarita Groundwater Basin (SMGWB). In concept, ASR is used to store water when available from flowing sources in the groundwater basins and to extract it when needed to meet customer demands. For the City, ASR would be relied upon as a source of supply largely in dry summer months when flowing sources diminish and Loch Lomond storage is dropping. This source of supply is limited to available injection volumes, extraction rates and the volume stored in the basin.

As noted above, Santa Cruz County has two Groundwater Sustainability Agencies (GSAs) created because of the Sustainable Groundwater Management Act (SGMA) enacted in the State of California in January 2015, mandating sustainable groundwater resources management: MCGB and SMGWB.

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City of Santa Cruz Water Department Securing Our Water Future 3 The MCGB is classified by the California Department of Water Resources (DWR) as a high-priority groundwater basis in critical overdraft due to the threat of seawater intrusion. The MCGB Groundwater Sustainability Plan (GSP), as required by SGMA, was approved by DWR on June 3, 2021. Subsequent to WSAC’s consideration of ASR in the MCGB, staff has been evaluating the feasibility of ASR in the MCGB including but not limited to siting studies, geochemical analyses, groundwater modeling, and pilot testing. From this work a phased approach to implementing ASR in the MCGB was developed that currently includes:

1. The conversion of existing groundwater wells, known as the Beltz wells, to ASR wells.

2. Construction of 4 – 6 new wells in the City’s portion of the MCGB to build-out ASR in that basin.

The alternative considered in the SOWF is referred to as Alternative 11.2 because of its designation in the 40-plus groundwater modeling scenarios performed by Montgomery and Associates. Based on the studies described above, Alternative 11.2 has the potential to inject 2 million gallons per day (mgd), extract 3 mgd, and meet ½ of the City’s water supply gap during drought based on shortage numbers developed during WSAC of 1.2 billion gallons per year under climate scenario GFDL2.1 A2.1 This project is referred to as Concept 1 in the SOWF and includes conversion of existing wells, new wells, well head treatment and improvements to the existing Beltz Water Treatment Plant, and pipelines.

Next steps for evaluating ASR in the MCGB include additional modeling to refine the number and location of new wells, pilot testing of new wells, evaluation of ASR in combination with other alternatives such as additional ASR in the SMGWB as well as transfers and exchanges.

In addition, and a potential limiting factor to ASR in general, is the impact to the long-term reliable availability of surface waters as a result of a changing climate. The work being performed by others (Professor Casey Brown of the University of Massachusetts at Amherst, Department of Civil Engineering and affiliated Hydrosystems Research Group and Professor Shawn Chartrand of Simon Fraser University’s School of Environment Science) sheds significant light on the long-term reliability of surface water in the region experienced as potential decrease of surface water availability; this will play into the consideration of ASR as a future water supply project.

Indirect Potable Recharge/Groundwater Injection in the Santa Margarita Groundwater Basin (SMGWB) The WSAC contemplated the use of advanced treated wastewater for either indirect or direct end uses.

Indirect potable reuse, or IPR, is described here and direct potable reuse, or DPR, is described below.

Following the recommendations by the WSAC, the City conducted Phase 1 of the Recycled Water Feasibility Planning Study with the goal of identifying and evaluating beneficial uses of recycled water that either reduced demand (e.g., Non-potable reuse [NPR] that is largely comprised of irrigation) and/or offset water supply needs (e.g., DPR). To this end, a variety of projects were developed and evaluated including irrigation, lake augmentation, stream augmentation, groundwater injection, and direct potable reuse. While two very small NPR projects are currently being pursued that would offset irrigation at La Barranca Park (city-owned facility adjacent to the City’s Wastewater Treatment Facility [WWTF]) and provide bulk water through a new truck fill station also located adjacent to the WWTF, from a water supply perspective, only groundwater injection and DPR are capable of filling the water supply gap in a significant and reliable manner and were therefore developed further for the SOWF. 1 GFDL2.1 A2 was the first climate change projection used by the City in the supply planning process. It is based on CMIP3 (third phase of Coupled Model Intercomparison Project https://pcmdi.llnl.ov/mips/ ), version 2.1 of the Global Climate Model from the Geophysical Fluid Dynamics Lab, and emissions scenario A2.

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City of Santa Cruz Water Department Securing Our Water Future 4 The SMGWB is a groundwater basin classified by DWR as being a medium-priority basin. Like the MCGB GSP, the SMGWB GSP contains a set of projects and management actions (PMAs) that could potentially achieve the sustainability goals established by the GSA for that basin. Injection of advanced treated recycled water (indirect potable reuse or IPR) is among the PMAs having demonstrated a degree of feasibility and ability to meet the GSP goals.

IPR in the SMGWB would consist of the expansion of Soquel Creek Water District’s Pure Water Soquel (PWS) project, a groundwater replenishment and seawater intrusion prevention project currently in construction in the MCGB. Doubling the capacity of the PWS project would allow for ~1,500 acre-feet per year (afy) of purified water to be injected into the SMGWB with a portion available for extraction to be used as water supply. The concept developed for the purpose of the SOWF involves injecting 1,500afy (1.4mgd), with 20% left in storage in the summer (or 1.1 mgd extraction rate) and 50% left in storage in the winter (or 0.7 mgd). This alternative is referred to as Concept 2 in the SOWF.

Minimal groundwater modeling was performed in the development of the PMAs in the SMGWB; next steps in the development of the WSAIP include updated groundwater modeling, consideration of combining IPR with water transfers and exchanges as well as an ASR project in the MCGB.

Direct Potable Reuse
Direct Potable Reuse, or DPR, is the other recycled water alternative contemplated by the WSAC that may be effective at reducing the reliance on existing water supplies to meet customer demand. This concept would treat larger volumes of recycled water available from the City’s Wastewater Treatment Facility (larger than the built-out treatment capacity of the PWS project once expanded to 3,000afy therefore requiring an additional advanced purification facility capable of larger yields), pumping this water to the City’s surface water treatment plant, the Graham Hill Water Treatment Plant, for further treatment, followed by distribution to the City’s customers.

Because there is some flexibility in sizing a DPR project, limited primarily by the availability of source water, or treated wastewater, the DPR project for the SOWF was sized to match that of the desalination project at 3 mgd described below. This size is slightly larger than the scwd2 Desalination Project of

2.5 mgd to fill the worst year supply gap identified by WSAC of 1.2 billion gallons per year (bgy). (Note that the Desalination Feasibility Update Review performed in 2018 sized a desalination project at 3.3 mgd operating 365 days per year. For simplicity, 3 mgd was used for Concepts 3 and 4 for the SOWF. In practice the sizing of a DPR or desalination project would be scaled to meet the community’s water supply reliability goals.)
For the purposes of the SOWF, the following operating strategy of a DPR project was developed to retain storage in the Loch Lomond Reservoir while meeting the water demand needs of the City’s customers:
1 mgd production capacity from November through April; 2 mgd from May through October; 3 mgd year-round when the reservoir drops below 2.0 billion gallons (bg) and until it is full at 2.8bg. This alternative is referred to as Concept 3 in the SOWF.

Next steps in the evaluation of DPR includes assessing the long-term availability of wastewater to meet the supply needs as planned through this alternative; consideration of DPR together with ASR, IPR, desalination, water transfers and exchanges, and other partnerships; and, tracking the regulatory feasibility of DPR as it is yet not a permissible potable water source.

3.38 SECURING OUR WATER FUTURE
City of Santa Cruz Water Department Securing Our Water Future 5 Seawater Desalination
The WSAC recommended that seawater desalination be retained as a potential water supply for the city’s customers if other alternatives as described above were not successful at meeting the reliability goals of the city. In 2018, following WSAC recommendations to update the scwd2 Desalination Project scope to recognize 1) the new supply gap identified by WSAC and 2) new regulations put into place in the interim most notably being the 2016 Amendment to the Water Quality Control Plan for Ocean Waters of California Addressing Desalination Facility Intakes, Brine Discharges, and the Incorporation of Other Non-Substantive Changes included in the California Ocean Plan (SWRCB and CalEPA 2015). This update resulted in a 3.3 mgd project, with a reduced number of ocean intake locations for consideration.

Similar to the DPR operating strategy and for the purpose of the SOWF, a desalination project would be operated at 1 mgd from November through April, 2 mgd from May through October and 3 mgd yearround when the reservoir drops below 2.0 billion gallons, or bg, and until it is full at 2.8 bg. This concept is referred to as Concept 4 in the SOWF. (Again, for simplicity, the DPR and desalination concepts rounded to a 3 mgd project concept.)
Next steps in the evaluation of seawater desalination includes tracking existing projects on the state level for permitting feasibility and evaluating partnership opportunities.

GENERAL ASSUMPTIONS
 Cost metrics presented in the fact sheets include total capital costs, annualized capital costs, annualized operation and maintenance costs, and total unit costs.  Results for water supply shortage using the UMass Santa Cruz Water Supply Model are based on model results using climate realization 1270, +2 degrees Celsius warming, no change in precipitation, and a coefficient of climate variability of 1.1.  Costs are estimated at an AACE Class 5 level with -20 - -50% cost variation on the low end to +30 - +100% on the high end.
 Greenhouse Gas (GHG) calculations are based on average emission rates for PG&E (2014-2018).

Low emissions range based on energy use for an average extraction year, and high emissions range based on energy used for a max extraction year. PG&E increase in use of green energy sources in the future will reduce or eliminate GHG emissions. GHG emissions from pipelines represent 1-5% of the total emissions, with the rest being emissions due to energy use.  Energy use estimates and operational costs are based on the full treatment capacity of the alternative and not showing ranges for the annual variable operational levels.  Timelines for implementation include pilot testing, permitting, design, contractor procurement and bidding process, construction, and commissioning.
 All projects implemented within either the MCGB or the SMGWB must meet requirements of the respective GSPs. In addition, the City must still meet the requirements of the GSPs even if supply projects not directly impacting these basins are implemented (e.g., DPR and desalination).

SUMMARY OF RESULTS
The two figures below show 1) summary of the key criteria for each project concept and 2) summary of resulting costs for each project concept.

3.39 SECURING OUR WATER FUTURE
City of Santa Cruz Water Department Securing Our Water Future 6

3.40 SECURING OUR WATER FUTURE
City of Santa Cruz Water Department Securing Our Water Future 7

CONCLUSIONS

1. All water supply concepts evaluated can reduce peak drought supply deficits. o ASR is limited by surface water available and MCGB storage capacity. o IPR is limited by 1,500 afy production capacity of PWS and SMGWB storage capacity.

IPR is also limited by the amount of water required as “leave behind” in the basin to support the basin sustainability objectives. In the SMGWB, this number can be as high as 50%, and will need to be confirmed during further evaluation. o DPR is limited by wastewater availability after supply of PWS project. o Desal is not limited by source supply, but by ocean intake design.

2. Concepts evaluated can reduce the maximum supply deficit during a five-year drought from 32% up to 87%.
o Combination of supply concepts could meet 100% of the maximum supply gap.

3. There is high variability in water supply needs from average year to peak drought year. o Variability in supply needs makes it challenging to size projects. o Unit costs can vary from an average year to a peak drought year.

4. Supply concepts evaluated could increase water supply to minimize deficits during droughts, for under $12,000/AF or $36,000/MG.

3.41 SECURING OUR WATER FUTURE
City of Santa Cruz Water Department Securing Our Water Future 8

PROJECT CONCEPT FACT SHEETS
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3.42 City of Santa Cruz Water Department Securing Our Water Future 9 Concept 1
Aquifer Storage and Recovery (ASR) in Mid-County Groundwater Basin (MCGB)

Fact Sheet
Description
Available winter flows from the City’s surface water sources, treated at the Graham Hill Water Treatment Plant (GHWTP), would be injected into the Mid-County Groundwater Basin (MCGB) at four existing Beltz wells and four new wells, and recovered as a supplemental groundwater supply in dry summer periods. (Referred to as “Scenario

11.2” in prior ASR feasibility investigations and groundwater modeling efforts) 1 Water Source(s) Average Injection: 1.7 MGD (920 AFY / 300 MGY) of potable city water supply 2 Maximum Injection: 2.0 MGD (1,100 AFY / 360 MGY) of potable city water supply 2 Project Yield Average Extraction: 0.8 MGD (430 AFY / 140 MGY) of groundwater 3 Maximum Extraction: 3.0 MGD (1,630 AFY / 530 MGY) of groundwater 3 Evaluation Criteria 4
Project’s supply contribution as a %
of worst year supply shortfall
60% 5
Increases resilience to climate
change
Yes, the project would utilize available capacity in the MCGB for storing winter flows, to be recovered through additional groundwater extraction during dry periods, thereby increasing resilience to drought and the impacts of climate change.

Total Annualized Cost 6
Total Capital Cost: $96.1 M
Annualized Capital Cost: $4.2 M
O&M Annual Cost: $2.7 M
Total Unit Cost: $4,200 – $15,800 per AF ($13,000 - $48,300 per MG) Is understood and accepted by the
public and key stakeholders
Yes, this alternative is understood and continues to be viewed favorably as a viable alternative to address water shortages.

Scalable or can be implemented
incrementally or in phases
Yes, ASR can and in fact should be implemented over time to ensure predicted outcomes. ASR is limited by groundwater basin capacity, surface water availability, and influence of the Pure Water Soquel (PWS) injection to the MCGB.

Technical Feasibility Yes. Ongoing pilot testing demonstrated technical feasibility.

Likelihood project being funded by
state or federal grants
Likely. Funding from the Bureau of Reclamation and State Water Resources Control Board (SWRCB) is available for construction of new wells.

Opportunity for shared funding No, the City does not have a project partner and would likely assume all costs.

Greenhouse gas emissions 100 - 140 MT of carbon dioxide (CO2 ) emissions per year 7
Time required for implementation 8 to 10 years for complete implementation of all ASR wells8 Operational Complexity Low to Medium; would require minimal changes to current potable water supply operations, but increased effort for O&M of ASR wells.

Energy Use 630,000 – 930,000 KWh/yr 9

0.6 – 1.4 MWh/AF 9
Potential impacts for CEQA
required mitigations to impact
project cost or timeliness
Low. Preliminary analysis indicates that the project would not have significant environmental impacts due to limited footprint of new facilities. The first phase of this project (conversion of existing Beltz Wells) was evaluated in the Water Rights EIR.

Adaptable to future regulatory or
source water changes
Yes, for regulatory changes, and ability to adapt to source water changes relies on treatment elsewhere; e.g., GHWTP process improvements. Prior to source water changes, geochemistry, travel time, and post-recovery water treatment needs will need to be revisited.

Degree of administrative complexity Low. The project is located within the City of Santa Cruz water service area with no need for partnerships with outside agencies.

3.43 City of Santa Cruz Water Department Securing Our Water Future 10 Fact Sheet
Concept 1
Aquifer Storage and Recovery (ASR) in Mid-County Groundwater Basin (MCGB) NOTES:
1 Scenario 11.2 was performed by Pueblo Water Resources and Montgomery & Associates in their Phase 1 ASR Feasibility Investigation groundwater modeling (Pueblo, 2021). This scenario uses 2016-18 demands (2.6 bgy), the GFDL2.1A2 climate change scenario, the four existing Beltz wells plus four new wells. Does not include utilization of native groundwater supplies. 2 Average and Maximum daily injection rates used as modeled for Scenario 11.2 by Gary Fiske and Pueblo Water Resources (Pueblo 2021). 3 Average and Maximum annual extraction rates from Santa Cruz Water System Model results for ASR adaptation scenario under Realization 1270 (UMass, 2022).
4 Evaluation criteria listed in order of importance as ranked by Commissioners. 5 ASRProject can reduce the water supply shortage during the worst drought sequence projection, from 2,190 MG (cumulative shortage without adaptation project) to 870 MG (cumulative shortage with ASR project). Results for the water supply shortage are based on model results of the Santa Cruz Water Supply System Model for the worst drought sequence of 5 years, using Realization 1270, +2-degree Celsius warming, no change in average annual precipitation, and a change in climate variability coefficient of 1.1. 6 Costs are estimated at an AACE Class 5 level with -/+50% cost variation. Costs include conversion of 4 Beltz wells to ASR wells, 4 new ASR wells, modifications to wellhead treatment for Beltz 12 and wellhead treatment at new wells, upgrades to Beltz Water Treatment Plant, pilot testing, connections to/from water system, site acquisition, and additional facility costs. Costs also include markups, mobilization, contractor overhead, and a 30% estimate contingency. If additional new wells are required, infrastructure and treatment costs would be added accordingly.

Escalation of 7% used due to current supply chain impacts and inflation. The cost estimates should be revisited when more design details are available. O&M costs are based on full production capacity. Unit costs are estimated for average production capacity (high end) and max production capacity (low end). Cost sources: Santa Cruz ASR Project - Phase 1 Feasibility Investigation; Summary of Groundwater Modeling Scenario 11.2 Results (Pueblo, 2021); Beltz Treatment Plant Rehabilitation Project (CDM, 2008); Beltz 12 Capital Asset Record Construction & Treatment Cost (City, 2015), and estimates from the City for Beltz 12 ammonia treatment costs (Dec, 2021). 7 Based on average emission rates for PG&E (2014-2018). Low emissions range based on energy use for an average extraction year, and high emissions range based on energy used for a max extraction year. PG&E increase in use of green energy sources in the future will reduce or eliminate GHG emissions. GHG emissions from pipelines represent 1-5% of the total emissions, with the rest being emissions due to energy use. 8 Based on estimates from the City and Pueblo Water Resources of 1.5 years for pilot testing existing wells, 3 years for pilot testing new wells,

1.5 years per well for upgrading existing wells, 2.5 years for developing new wells, and assuming 2 years of injection before commencing extraction. Estimates include property acquisition, permitting, design, contractor procurement and construction. To date pilot testing of wells Beltz 8 and 12 has been completed. The rest of the implementation for ASR wells will occur in phases. 9 Energy estimates for injection and extraction based on pumping information provided by the City. Energy for treatment based on estimate of energy use from Beltz Treatment Plant Rehabilitation Project (CDM, 2008). Low range is based on energy use for an average extraction year and high range is for energy used for a max extraction year. Unit energy estimated based on average and max AFY extraction rates.

Evaluation Criteria (cont.) 4
Ancillary Benefits
 Contributes to groundwater replenishment
 May assist in limiting seawater intrusion and meeting GSP objectives  Adds to system supply portfolio
 Opportunity for regional collaboration
Ancillary Costs/Risks
 May mobilize constituents in basin
 Subject to leakage from groundwater basin, aka “losses”  Sufficient cumulative storage may not be available in time of need  Reliant on surface water availability
Assumptions
 Based on Scenario 11.2 and has not yet been modeled with the Pure Water Soquel project
 Pipelines sized for peak injection (2.0 MGD) and peak extraction (3.0 MGD)  Injection period = 6-month (Nov – Apr)
 Extraction period = 6-month extraction (May – Oct)

3.44 City of Santa Cruz Water Department Securing Our Water Future 11 Figure 1 - Concept 1 - ASR in the MCGB
Modified figure from “Santa Cruz ASR Project - Phase 1 Feasibility Investigation; Summary of Groundwater Modeling Scenario 11.2 Results (Pueblo, 2021)”

3.45 City of Santa Cruz Water Department Securing Our Water Future 12 Concept 2
Indirect Potable Reuse (IPR) in Santa Margarita Groundwater Basin (SMGWB) Fact Sheet
Description
Expansion of treatment capacity of the Pure Water Soquel (PWS) Advanced Water Treatment Facility (AWTF) and conveyance of purified water to Scotts Valley for injection into the Santa Margarita Groundwater Basin (SMGWB). This concept would require a purchase agreement with Soquel Creek Water District (SqCWD).

Water Source(s) 1.4 MGD (1,500 AFY / 510 MGY) of purified water 1 Project Yield

1.1 MGD (950 AFY / 310 MGY) extracted May – Oct (20% leave-behind to replenish SMGWB levels) 2

0.7 MGD (370 AFY /120 MGY) extracted Nov- Apr (50% leave-behind to replenish SMGWB levels) 2
Evaluation Criteria 3
Project’s supply contribution as a %
of worst year supply shortfall
32% 4
Increases resilience to climate
change
Yes, the project would utilize available capacity in the SMGWB for storing purified water to be recovered as additional groundwater source during dry periods, increasing resilience to drought and the impacts of climate change.

Total Annualized Cost 5
Total Capital Cost: $239.7 Mil
Annualized Capital Cost: $11.4 Mil
O&M Annual Cost: $ 4.7 Mil
Total Unit Cost: $10,800 per AF ($31,700 per MG)
Is understood and accepted by the
public and key stakeholders
Yes, this alternative is viewed somewhat favorably by the public as a way to address water shortages.

Scalable or can be implemented
incrementally or in phases
Yes, although limited by groundwater basin capacity and PWS AWTF expansion capacity unless additional AWTF capacity is added elsewhere.

Technical Feasibility
Yes, groundwater replenishment reuse projects have been succesfully implemented in Southern California for over 50 years. Additional groundwater modeling and/or pilot testing may be required to demonstrate feasibility for the SMGWB.

Likelihood project being funded by
state or federal grants
Likely. Funding from the Bureau of Reclamation and SWRCB is available for water reuse projects.

Opportunity for shared funding Yes, Scotts Valley Water District could provide cost-share, and potentially other member agencies of the Santa Margarita Groundwater Agency (SMGWA) Greenhouse Gas Emissions 1,180 MT of CO2 emissions per year 6 Time required for implementation 8 -10 years 7
Operational complexity High. The project would require coordination with multiple agencies to construct and operate the system and meet regulatory requirements.

Energy Use 8,000,000 KWh/yr 8

5.3 MHh/AF 8
Potential impacts for CEQA
required mitigations to impact
project cost or timeliness
High. Short-term construction-related impacts could likely be mitigated through alternative construction techniques, preconstruction surveys, and implementation of best management practices.

Adaptable to future regulatory or
source water changes
Yes, beneficial to meet groundwater sustainability goals as well as potential opportunity to blend surface water could be considered.

Degree of administrative complexity High; due to multi-agency involvement and complex regulatory requirements.

3.46 City of Santa Cruz Water Department Securing Our Water Future 13 Concept 2
Indirect Potable Reuse (IPR) in Santa Margarita Groundwater Basin (SMGWB) Fact Sheet
NOTES:
1 PWS project was designed to be able to expand production by an additional 1,500 AFY for a total project capacity of 3,000 AFY of purified water produced. PWS will inject 1,500 AFY of purified water into the MCGB. 2 Annual extraction rates from Santa Cruz Water System Model results for IPR adaptation scenario under Realization 1270 (UMass, 2022).

Assumed a 20% leave behind of the injected flows between May to October, increasing to 50% leave behind of the injected flows between November and April to replenish basin levels. SMGWB Groundwater Sustainability Plan (GSP) objective to restore groundwater levels require maintaining 710 AFY in the basin. The leave behind requirements would be updated in future phases of the work based on the requirements for the SMGWB.
3 Evaluation criteria listed in order of importance as ranked by Water Commissioners. 4 IPRProject can reduce the water supply shortage during the worst drought sequence projection, from 2,190 MG (cumulative shortage without adaptation project) to 1,480 MG (cumulative shortage with IPR project). Results for the water supply shortage are based on model results of the Santa Cruz Water Supply System Model for the worst drought sequence of 5 years, using Realization 1270, +2-degree Celsius warming, no change in average annual precipitation, and a change in climate variability coefficient of 1.1. 5 Costs are estimated at an AACE Class 5 level with -/+50% cost variation. Costs include expansion of PWS treatment capacity, conveyance to Scotts Valley, upgrading 2 wells for injection at El Pueblo, 7 new injection wells, 2 new extraction wells, conveyance of extracted water to Newell Creek pipeline connection, and additional facility costs. Costs also include markups, mobilization, contractor overhead, and a 30% estimate contingency. Escalation of 7% used due to current supply chain impacts and inflation. The cost estimates should be revisited often and when more design details are available. O&M costs and unit costs are based on full production capacity of 1,500 AFY. Cost sharing with SVWD is not accounted for. Costs based on Regional Recycled Water Alternatives Evaluation TM (KJ, 2021), escalated to 2022. 6 Based on average emission rates for PG&E (2014-2018). PG&E increase in use of green energy sources in the future will reduce or eliminate GHG emissions. GHG emissions from pipelines represent 1-5% of the total emissions, with the rest being emissions due to energy use. 7 Timeline for implementation includes permitting, environmental review, design, bidding, construction, and commissioning. 8 Energy estimates for treatment and conveyance. Energy estimates are based on total project capacity, not including variations due to seasonal operations.

Ancillary Benefits
 Source water supply not entirely reliant on surface water  Contributes to groundwater replenishment
 May assist with compliance with GSP objectives
 Adds storage water to system supply portfolio
 Opportunity for regional collaboration
 Provides foundational treatment infrastructure for potential future consideration of DPR
Ancillary Costs/Risks
 May mobilize constituents in basin
 Subject to leakage from groundwater basin, aka “losses”  Sufficient cumulative storage may not be available in time of need  Public acceptance of purified recycled water may be limited Assumptions  Injection of 1,500 AFY
 Leave behind of 20% May – Oct, and 50% Nov to Apr to replenish the SMGWB  Groundwater modeling required to confirm sustainable injection and extraction rates and well locations

3.47 City of Santa Cruz Water Department Securing Our Water Future 14 Figure 1 - Concept 2 - IPR in the SMGWB

3.48 City of Santa Cruz Water Department Securing Our Water Future 15 Concept 3
Direct Potable Reuse (DPR) via Raw Water Augmentation
Fact Sheet
Description Develop a new AWTF to treat effluent from the Santa Cruz WWTF and produce purifed water to be blended with raw surface water prior to additional treatment at the GHWTP.

Water Source(s) 4.2 MGD (4,670 AFY/ 1,520 MGY) of Santa Cruz WWTF effluent 1 Project Yield
3 MGD (2,700 AFY/ 880 MGY) of purified water production capacity 2 1 MGD produced Nov to April and 2 MGD produced May to October 3 MGD produced when Loch Lomond reservoir levels are below 2.0 billion gallons.

Evaluation Criteria 3
Project’s supply
contribution as a % of worst
year supply shortfall
87% 4
Increases resilience to
climate change
Yes, although wastewater flows are linked to customer demands, this project would provide a consistent supply of locally produced, purified water to directly supplement the City’s potable water system, increasing resilience to drought and the impacts of climate change.

Total Annualized Cost 5
Total Capital Cost: $163.2 Mil
Annualized Capital Cost: $6.6 Mil
O&M Annual Cost: $ 5.0 Mil
Total Unit Cost: $4,300 per AF ($13,200 per MG)
Is understood and accepted
by the public and key
stakeholders
Yes, this project type is generally understood by the public and key stakeholders; however, additional information would be needed about local understanding and acceptance of this form of water reuse.

Scalable or can be
implemented incrementally
or in phases
Yes, initial assessments show that the City has adequate source supply and can produce purified water incrementally to fill the water supply gap. Updated source supply assessment is needed.

Technical Feasibility Yes. The existing and proven treatment technologies are available to meet the proposed criteria and anticipated regulatory requirements for DPR.

Likelihood project being
funded by state or federal
grants
Likely. Funding from the Bureau of Reclamation and SWRCB is currently available for water reuse and demonstration projects, and additional future funding will likley be made available for DPR once regulations are finalized.

Opportunity for shared
funding
No, the City does not have a project partner identified and would likely assume all costs; however, future purchase agreement(s) may present an opportunity for water transfers and exchanges.

Greenhouse Gas Emissions 870 MT of CO2
emissions per year 6
Operational complexity High. This project would require operation of a new AWTF and meeting complex regulatory requirements, which are still in development.

Time required for
implementation
More than 10 years.7
Energy Use 6,100,000 KWh/yr 8

1.8 MWh/AF 8
Potential impacts for CEQA
required mitigations to
impact project cost or
timeliness
High. Short-term construction-related impacts could likely be mitigated through alternative construction techniques, preconstruction surveys and implementation of best management practices.

Adaptable to future
regulatory or source water
changes
Uncertain and may depend on adopted regulations by the SWRCB Division of Drinking Water, expected by December 2023. Potential opportunities to treat seawater, brackish water, or impaired groundwater at the AWTF could be considered.

Degree of administrative
complexity High due to complex regulatory requirements.

3.49 City of Santa Cruz Water Department Securing Our Water Future 16 Concept 3
Direct Potable Reuse (DPR) via Raw Water Augmentation
Fact Sheet
NOTES:
1 Wastewater availability will be further evaluated to refine sizing of DPR project based on effluent available from the Santa Cruz WWTF for production of purified water, with consideration of effluent required for the Pure Water Soquel project needs. 2 For modeling this alternative in the Santa Cruz Water Supply System Model, assumed 1MGD production November to April and 2 MGD production May to October. Assumed increased production of 3 MGD when levels at Loch Lomond reservoir are below 2.0 billion gallons and until reservoir levels reach 2.8 billion gallons.
3 Evaluation criteria listed in order of importance as ranked by Commissioners. 4 DPRProject can reduce the water supply shortage during the worst drought sequence projection, from 2,190 MG (cumulative shortage without adaptation project) to 280 MG (cumulative shortage with DPR project). Results for the water supply shortage are based on model results of the Santa Cruz Water Supply System Model for the worst drought sequence of 5 years, using Realization 1270, +2-degree Celsius warming, no change in average annual precipitation, and a change in climate variability coefficient of 1.1. 5 Costs are estimated at an AACE Class 5 level with -/+50% cost variation. Costs include new AWTF, conveyance to raw water blending station, and additional facility costs. Costs also include markups, mobilization, contractor overhead, and a 30% estimate contingency. Costs based on Recycled Water Facilities Planning Study RWFPS (KJ, 2018), escalated to 2022. Escalation of 7% used due to current supply chain impacts and inflation. The cost estimates should be revisited when more design details are available. O&M costs and unit costs are based on full production capacity.
6 Based on average emission rates for PG&E (2014-2018). PG&E increase in use of green energy sources in the future will reduce or eliminate GHG emissions. GHG emissions from pipelines represent 1-5% of the total emissions, with the rest being emissions due to energy use. 7 Timeline for implementation includes permitting, environmental review, design, bidding, construction, and commissioning. 8 Energy estimates for treatment and conveyance, based on RWFPS (KJ, 2018). Energy estimates are based on total project capacity, not including variations due to seasonal operations.

Evaluation Criteria (cont.) 3
Ancillary Benefits  Independent source from surface water although linked to water use  Relatively cost-effective compared to $/AF of other alternatives Ancillary Costs/Risks  Public acceptance of purified recycled water may be limited, especially for DPR  State regulations not yet in place (pending, anticipated December 2023) Assumptions
 New AWTF located near the Santa Cruz WWTF
 Treatment train based on draft DPR criteria but does not include nitrification of City effluent.

3.50 City of Santa Cruz Water Department Securing Our Water Future 17 Figure 2 - Concept 3 - DPR with Raw Water Augmentation

3.51 City of Santa Cruz Water Department Securing Our Water Future 18 Concept 4
Seawater Desalination
Fact Sheet
Description Construct a new, local seawater desalination facility and ocean intake (3 options considered).

Water Source(s) 6 MGD (5,400 AFY / 1,760 MGY) of seawater from Monterey Bay 1 Project Yield
3 MGD (2,700 AFY/ 880 MGY) of desalinated water production capacity. 1 MGD produced Nov to April and 2 MGD produced May to October 3 MGD produced when Loch Lomond reservoir levels are below 2.0 billion gallons 2 Evaluation Criteria 3
Project’s supply contribution as
a % of worst year supply
shortfall
87% 4
Increases resilience to climate
change
Yes. Project would provide a consistent supply of locally produced potable water to directly supplement the City’s potable water system, increasing resilience to drought and the impacts of climate change. The location of the seawater desalination facility would consider sea-level rise.

Total Annualized Cost 5
Total Capital Cost: $290.6 - $443.9 Mil
Annualized Capital Cost: $13.0 - $23.9 Mil
O&M Annual Cost: $ 6.8 - $7.1 Mil
Total Unit Cost: $7,400 - $11,500 per AF ($22,700 - $35,300 per MG) Is understood and accepted by
the public and key stakeholders
This project is generally understood by the public and key stakeholders. While desalination is recognized as a potential supply alternative, broad acceptance is unknown.

Scalable or can be implemented
incrementally or in phases
Yes. The desalination plant could be designed to be scalable to incrementally fill the water supply gap.

Technical Feasibility Yes. Although challenging to permit, desalination is technically feasible as demonstrated by projects implemented in the state of California and elsewhere.

Likelihood project being funded
by state or federal grants
Likely. Funding from the Bureau of Reclamation is available for desalination projects that have an approved Title XVI feasibility study. Additional future funding from the SWRCB could be available if drought persists.

Opportunity for shared funding
No, the City has not identified a project partner and would therefore likely assume all costs; however future purchase agreement(s) may present an opportunity for water transfers and exchanges.

Greenhouse Gas Emissions 2,500 MT of CO2 emissions per year 6 Time required for
implementation
More than 10 years. 7
Operational complexity High. Would require operation of a new desalination facility; balancing cost to operate versus ramping down or shutting down the plant in favor of less costly supplies.

Energy Use 17,500,000 KWh/yr 8

4.7 MWh/AF 7
Potential impacts for CEQA
required mitigations to impact
project cost or timeliness
High. In addition to short-term mitigations, desalination projects may result in additional required mitigations to protect marine life in Monterey Bay and the complex permitting process would impact timeline for construction.

Adaptable to future regulatory
or source water changes
Potentially. Although no current example exists in California, ocean water could potentially be blended with effluent from the Santa Cruz WWTF at the desalination plant to produced purified water to augment the potable water system; or the desalination plant could be converted to a DPR facility once DPR regulations are finalized.

Degree of administrative
complexity
High, due to complexity of regulations and permitting requirements.

3.52 City of Santa Cruz Water Department Securing Our Water Future 19 Concept 4
Seawater Desalination
Fact Sheet
NOTES:
1 Estimated assuming 50% recovery through desalination treatment process. 2 For modeling this alternative in the Santa Cruz Water Supply System Model, assumed 1 MGD production November to April and 2 MGD production May to October. Assumed increased production of 3 MGD when levels at Loch Lomond reservoir are below 2.0 billion gallons and until reservoir levels reach 2.8 billion gallons.
3 Evaluation criteria listed in order of importance as ranked by Water Commissioners. 4 Desalination Project can reduce the water supply shortage during the worst drought sequence projection, from 2,190 MG (cumulative shortage without adaptation project) to 280 MG (cumulative shortage with Desalination project). Results for the water supply shortage are based on model results of the Santa Cruz Water Supply System Model for the worst drought sequence of 5 years, using Realization 1270, +2-degree Celsius warming, no change in average annual precipitation, and a change in climate variability coefficient of 1.1. 5 Costs are estimated at an AACE Class 5 level with -/+50% cost variation. Cost range is based on 3 different Alternatives for ocean intake, SI-1, SI-2, and SI-3, per Desalination Feasibility Study by Dudek (August 2018). Costs were escalated to 2022 costs. Escalation of 7% used due to current supply chain impacts and inflation. The cost estimates should be revisited when more design details are available. O&M costs and unit costs are based on full production capacity.
6 Based on average emission rates for PG&E (2014-2018). PG&E increase in use of green energy sources in the future will reduce or eliminate GHG emissions. GHG emissions from pipelines represent 1-5% of the total emissions, with the rest being emissions due to energy use. 7 Timeline for implementation includes permitting, environmental review, design, bidding, construction, and commissioning. 8 Energy estimates based on SCWD Regional Desalination Plant Phase I Preliminary Design Report-Volume 1 Draft Report (2012, CDM Smith).

Unit energy estimated based on volume of water treated. Energy estimates are based on total project capacity, not including variations due to seasonal operations.

Evaluation Criteria (cont.) 3
Ancillary Benefits
 Reliable source water
 Independent from surface sources
 Potentially expandable if/as future needs arise
Ancillary Costs/Risks  Regulatory permitting timeline and feasibility is uncertain  Public acceptance of seawater desalination locally is uncertain Assumptions  Desalination treatment recovery of 50% (50% reject through membranes).

3.53 City of Santa Cruz Water Department Securing Our Water Future 20 Figure 3 - Concept 4 - Seawater Desalination

3.54 SECURING OUR WATER FUTURE

REFERENCES
To access the Water Supply Advisory Committee Final Report on Agreements and Recommendations:
https://www.cityofsantacruz.com/home/showpublisheddocument/84832/6375944976196 70000
For more information on the Mid-County Groundwater Agency:
https://www.midcountygroundwater.org/
For more information on the Santa Margarita Groundwater Agency:
https://www.smgwa.org/
To access the Santa Cruz Regional Recycled Water Facilities Planning Study:
https://www.cityofsantacruz.com/home/showpublisheddocument/84834/6375945022054 00000
To access the Desalination Feasibility Update Review:
https://www.cityofsantacruz.com/home/showpublisheddocument/84842/6375945077042 30000

3.55 The Economic Impacts of Water Supply Curtailments
as May Need to be Implemented by the
Santa Cruz Water Department
November 14, 2022
Prepared for:

City of Santa Cruz Water Department
Prepared by:

Robert Raucher
Raucher LLC
Carolyn Wagner
CW Research and Consulting
Colleen Donovan
Social Science Strategies LLC
Under Subcontract to Kennedy Jenks Consultants

3.56 Technical Memorandum November 14, 2022
Table of Contents
Executive Summary ................................................................................................................. i Background ............................................................................................................................ 1 Objective ................................................................................................................................ 1 Overview of Curtailment Policies............................................................................................ 2 Direct Costs Borne by SCWD ................................................................................................... 5 Lost revenues................................................................................................................................... 5 Administrative costs ........................................................................................................................ 5 Methodology for Economic Impact Analysis............................................................................ 6 Focusing on Water-Dependent Business Sectors.............................................................................. 6 Direct Economic Impact Scenarios by Business Sector...................................................................... 6 Nursery, landscape, and garden.......................................................................................................................... 8 Restaurants, manufacturing, and car washes..................................................................................................... 8 Tourism and recreation....................................................................................................................................... 9 Golf courses......................................................................................................................................................... 9 UCSC.................................................................................................................................................................... 9 North Coast Agriculture....................................................................................................................................... 9 Direct Economic Impacts on Household Customers........................................................................ 10 Indirect and Induced Economic Impacts (Applying the IMPLAN Model).......................................... 12 Economic Impact at County level ................................................................................................... 12 Key Findings......................................................................................................................... 13 High-Level Results.......................................................................................................................... 14 Key Results for Stage 3 Curtailments on Businesses and Other Non-Residential Customers............ 17 Key Results for Stage 4 Curtailments on Businesses and Other Non-Residential Customers............ 18 Key Results for Stage 5 Curtailments on Businesses and Other Non-Residential Customers............ 19 Caveats and Limitations ....................................................................................................... 19 Business Sectors Included or Excluded ........................................................................................... 19 Business Recovery after Peak Season............................................................................................. 20 New Businesses Attracted to the City............................................................................................. 20 Impacts from Penalty-Based Reductions in Household Disposable Income..................................... 20 References............................................................................................................................ 21

3.57 Technical Memorandum November 14, 2022 i
Executive Summary
The City of Santa Cruz is vulnerable to droughts, which are projected to become more frequent and severe under continuing climate change. Santa Cruz needs to supplement its water supply, otherwise demand curtailments are the only tool available to deal with the system’s vulnerability to drought (whether the city grows or not).

The water supply augmentation options available to the City are complex and expensive, raising the question about how much it may be worth to pursue supplemental water supply options.

Examining the economic cost of potential water supply curtailments provides one yardstick against which the adverse impacts of shortages may be compared to the expense of potential water supply enhancement options.

This Technical Memorandum (TM) provides findings from our analysis of adverse economic impacts associated with potential future water supply curtailments in Santa Cruz. Also presented are descriptions of the Santa Cruz Water Department (SCWD) plan for addressing water shortages and the methodology and data applied to our analysis.

Background and Objective
Water supply curtailments can be undesirable for many reasons, including their adverse impact on the local economy. SCWD’s 2021 Water Shortage Contingency Plan (WSCP) details five stages of curtailment, with Stage 1 aiming to reduce peak season use by 10%, Stage 2 targeting an overall 20% reduction, etc. (SCWD, 2021). This TM summarizes the projected adverse economic impacts arising from a potential need to implement Stages 3, 4, and 5 (with 30%, 40%, and 50% targeted reductions in overall peak season water use, respectively). Such curtailment stages are severe, yet they may be necessary given the water system’s vulnerability to drought conditions that may worsen under continuing climate change.

The economic analysis represents a “what if” assessment, intended to inform and support City of Santa Cruz deliberations on potential water supply investments aimed at avoiding the need to impose severe water curtailment stages. To the extent that water supply enhancement options reduce the likelihood and severity of future curtailments, the associated reduction in adverse community economic impacts represent an important portion of the benefits provided by augmenting the City’s water supply. These benefits – estimated here as avoided economic costs borne by the community – can then be compared to the expense of the associated water supply augmentation options.

Methods and Approach
The methodology applies a standard “regional economic impact analysis” approach and modeling tool (IMPLAN) to assess curtailment impacts on the City’s economy, and on Santa Cruz County as a whole. Text Box A provides an overview of the modeling approach, and a glossary defining key terms is provided at the end of this Summary.

The methodology focuses on water-dependent local businesses, the University of California at Santa Cruz (UCSC), golf courses, and the North Coast agriculture sector. These are business sectors for which access to a relatively large supply of water is essential to the ability to provide

3.58 Technical Memorandum November 14, 2022 ii
their goods and services (i.e., where reduced access to water will adversely impact the level of business operation or, perhaps, lead to business closure).

Sector-specific water supply cutbacks, per the SCWD’s WSCP, were translated into anticipated ranges of direct impacts on sector economic output (e.g., revenues), which are then input for modeled projections of direct, indirect, and induced impacts on regional economic output, labor income, jobs, and local tax revenues. Conservative assumptions were applied to avoid over-stating the estimated impacts (e.g., impacts were limited to a subset of business types).

High-Level Findings
An economic impact analysis is, by its nature, an imprecise exercise in which numerous uncertainties exist and many key assumptions need to be made. Nonetheless, the estimates developed are likely to be conservative, and are consistent with findings derived from investigations of the economic impacts of water supply shortages in other communities. 1 The
economic analysis developed a considerable amount of empirical findings. In this summary, we focus on high-level results. Additional detailed empirical information is provided in the full report.

Table ES1 reveals the economic impact on the City, should the SCWD need to implement Stage 3, 4, or 5 level water use curtailments. For example, at Stage 3, City-wide economic output (i.e., the value of industry production within the region) is projected to decline by $114 million to $243 million per year, reflecting a decline of 1.1% to 2.4% of total City economic output in a normal year. Also, between 1,146 and 2,428 jobs are estimated to be lost (a loss of approximately 2% to 4% of in-City jobs), and annual City tax revenues decline by an estimated $2.1 million to $5.4 million.
1 For example, an analysis of the economic impacts of water supply shortages for the East Bay Municipal Utility District developed estimates showing how lost economic output grows rapidly if curtailments rise above a 15% supply shortfall. The estimated loss of output was nearly $20 billion – or more than $2 million per MG of shortage – if a 15% shortage were to grow to a 25% curtailment level (estimates derived from M-Cubed, 2008a and 2008b; updated to 2022 dollars).

Text Box A: Regional Economic Impacts and the IMPLAN Model IMPLAN is an economic input-output (I-O) model, originally developed by the federal government.

The model contains information on the relationships within an economy, both between businesses, and between businesses and final consumers. IMPLAN predicts changes in overall economic activity resulting from a flow of money into and out of the local economy (e.g., visitor spending and the subsequent ripple of local "multiplier" effects). Widely used by academics and the public and private sectors, IMPLAN is generally accepted as the standard for economic I-O analysis. Additional detail is provided in the full report.

3.59 Technical Memorandum November 14, 2022 iii
Table ES1. City-level negative economic impacts (losses) from select business and other nonresidential curtailments Metric (Losses) Total impact at Stage 3 Total impact at Stage 4 Total impact at Stage 5 Output lost ($M)2 $114.4 – $242.9 $324.3 – $505.3 $578.5 – $789.9 Labor income lost ($M) $53.8 – $109.1 $141.0 – $218.6 $245.7 – $337.3 Value added lost ($M) $68.6 – $144.8 $192.2 – $299.3 $341.6 – $467.8 Employment (# of jobs lost) 1,146 – 2,428 3,236 – 5,066 5,752 – 7,902 Tax revenues lost: City of Santa
Cruz*($M) $2.1 – $5.4 $8.0 – $12.7 $15.5 – $21.1
Tax revenues lost: County ($M) $0.7 – $1.8 $2.7 – $4.3 $5.3 – $7.1 Tax revenues lost: State ($M) $3.0 – $7.5 $10.9 – $17.1 $20.6 – $28.0 Tax revenues lost: Federal ($M) $8.4 – $17.5 $23.0 – $35.8 $40.6 – $55.6 Total Tax Revenues Lost: Total ($M) $14.1 – $32.2 $44.6 – $69.8 $82.0 – $111.8 The estimated economic losses also can be interpreted relative to the amount of added water supply that would be needed to avoid a given level of curtailment [e.g., as a cost per million gallons (MG), or cost per acre-foot, of shortage]. The resulting “cost” of not having sufficient water can then be used as a benchmark against which to compare the expense of investments needed to secure that amount of water.

Table ES2 summarizes the estimated change in overall impact on City economic output from moving to increasingly more restrictive curtailment stages on businesses and other nonresidential sectors that are highly water dependent. Also shown is the implied economic cost per volume of water targeted overall for peak season use reductions.

For example, moving from Stage 3 to Stage 4 reduces estimated annual economic output within the City by between approximately $210 million and $262 million. This amounts to between $1.5 million and $1.9 million of lost economic output per MG of reduced water availability (based on 136 MG of additional water required to avoid moving from one curtailment stage to the next more severe curtailment stage for one water year peak period). 3 Another way of interpreting this finding is that if enough additional water supply was made available such that the City could avoid applying Stage 4 restrictions and instead implement the 2 Economic “output” predominantly reflects lost business revenues (less items such as net changes in manufacturers’ inventory). “Value added” is output, less intermediate goods. “Labor income” lost (employee plus proprietor) plus value added are partial subsets of output lost, but do not include all lost output (i.e., they do not sum to total output lost). The Glossary at the end of this Executive Summary provides additional definitional detail. 3 The 136 MG figure represents 10 % of total average peak season consumption for the 2016-2018 three-year base period SCWD uses for planning.

3.60 Technical Memorandum November 14, 2022 iv
less restrictive Stage 3 limits (e.g., adding the equivalent of 10% of normal peak season water usage, i.e., 136 MG), then the City would gain an estimated additional economic output of $210 million to $262 million. This translates to $1.5 million to $1.9 million of added economic output per MG added (compared to the water supply augmentation options currently being evaluated by the City, which are each expected to cost less than $36,000 per MG produced). This is one way of viewing the value added of developing an additional source of available water supply.

Table ES2. City-only incremental impacts from business curtailments (select industries only) Impact Change in output
($M)
$/MG**
($M)
$/AF
($M)
Stage 2* to 3 $114.4 – $242.9 $0.8 – $1.8 $0.3 – $0.6
Stage 3 to 4 $209.9 – $262.4 $1.5 – $1.9 $0.5 – $0.6
Stage 4 to 5 $254.2 – $284.6 $1.9 – $2.1 $0.6 – $0.7
* Assumes de minimis economic impact at Stage 2 for businesses ** Applies 136 MG need to meet each Stage’s 10% incremental reduction in total peak season demand The results above are considered conservative as they do not include all the business types that are likely to be adversely impacted by curtailments. Also not included in the results above are the impacts from reduced household disposable income (arising from excess use penalties and drought cost recovery fees). Those additional results are provided in the full report, and would increase the estimated economic output losses by approximately 14%.

Also provided in the full report are the results from an analysis of how the economic impacts arising in the City spill over to the broader county. In brief, county-wide impacts add approximately 10% more impact than experienced in the City alone.

3.61 Technical Memorandum November 14, 2022 v
Glossary of Key Economic Terms Used in this Report
Direct impacts are the initial changes in business revenues, such as the increased receipts from enhanced tourism, or a decrease in output when limited water availability constrains businesses operations. For example, direct expenditures include money tourists spend while visiting the area on food, lodging, and retail purchases.

Indirect impacts: Local businesses that benefit from direct spending then, in turn, spend additional (or reduced) revenues on goods and services that they need to operate their businesses. These are termed indirect expenditures.

Induced impacts: Direct and indirect spending generates employment in the local region, creating additional (or reduced) income for households, which generates further changes in local spending known as induced expenditures.

Economic Output refers to the value of industry production within the region. For manufacturers, output = sales plus/minus change in inventory; for service sector, output = production = sales; for retail and wholesale trade, output = gross margin (not gross sales).

Value Added refers to the difference between an Industry's or establishment's total Output and the cost of its Intermediate Inputs; it is a measure of the contribution to GDP.

Labor Income is defined as all forms of employment income, including Employee Compensation (wages and benefits) and Proprietor Income. Labor income is included within value added.

Employment includes an industry-specific mix of full-time, part-time, and seasonal employment.

Tax revenues accrued by various levels of government authorities, focusing here on local (i.e., city and county) governments and sub-county special districts.

Source: https://support.implan.com/hc/en-us/articles/360044986593-Glossary

3.62 Technical Memorandum November 14, 2022 1
The Economic Impacts of Water Supply Curtailments
as May Need to be Implemented by the
Santa Cruz Water Department
Background
The Santa Cruz Water Department (SCWD, Department) is evaluating several options to enhance the reliability of its water supply in the face of the system’s vulnerability to drought and other risks. Shortfalls in supply relative to the community’s already hardened demand are anticipated to become more frequent and more severe as the climate continues to change.

Santa Cruz needs to supplement its water supply, otherwise demand curtailments are the only tool available to deal with the system’s vulnerability to drought (whether the city grows or not).

This Technical Memorandum (TM) examines the economic cost to the City and the served community associated with potential future water supply shortfalls. To the extent that water supply enhancement options reduce the likelihood and magnitude of curtailments, the associated reduction in adverse community economic impacts represent a key portion of the benefits provided by the supply enhancements. These benefits (estimated as avoided economic costs borne by the community) can then be compared to the expense of the associated water supply enhancement alternatives.

Water supply shortages and resulting curtailments can have many adverse impacts on a community, including (but not limited to) negative economic impacts. As water-dependent businesses scale back operations (or close), there are resulting losses in regional output and business revenues, jobs, incomes, and local tax receipts. Many local households also suffer economic losses as lower incomes, drought-adjusted water rates, and excess use penalties reduce their disposable income and thus impact purchases of local goods and services.

This TM provides a summary of the findings of a “regional economic impact analysis” of potential water use curtailments that future conditions may necessitate being implemented by SCWD. SCWD’s 2021 Water Shortage Contingency Plan (WSCP) details five stages of curtailment, with Stage 1 aiming to reduce peak season use by 10%, Stage 2 targeting an overall 20% reduction, etc. (SCWD, 2021). This TM summarizes the projected adverse economic impacts arising from a potential need to implement Stages 3, 4, and 5 (with 30%, 40%, and 50% reductions in overall peak season water use, respectively).

Objective
This economic analysis represents a “what if” assessment, intended to inform City of Santa Cruz deliberations on potential water supply investments aimed at avoiding the need to impose severe water curtailment stages. The adverse economic consequences reported here – as well as the additional important community consequences of water supply curtailments, such as the loss of green spaces and their benefits – are a yardstick intended to help the City of Santa Cruz assess the beneficial value of its potential water supply augmentation options.

3.63 Technical Memorandum November 14, 2022 2
The SCWD is evaluating several options to enhance the reliability of its water supply in the face of the system’s vulnerability to climate change and other risks. Shortfalls in supply relative to the community’s already “hardened demand” are anticipated to become more frequent and more severe as the climate continues to change.

Options to enhance the reliability and security of the community’s water supply are relatively expensive and complex. However, water supply shortfalls are also costly in many ways, and the potential need to implement severe curtailment stages of the WSCP is the only response available unless the City augments its current water supply portfolio.

To the extent that water supply enhancement options reduce the likelihood and severity of curtailments, the associated reduction in adverse community economic impacts represent an important portion of the benefits provided by augmenting the City’s water supply. These benefits – estimated here as avoided economic costs borne by the community – can then be compared to the expense of the associated water supply augmentation options.

Overview of Curtailment Policies
SCWD has developed a detailed set of plans for how it will address various potential levels of water supply shortages, as detailed in its WSCP [located in Appendix O in the City of Santa Cruz 2020 Urban Water Management Plan (SCWD, 2021)]. There are several curtailment stages that may be implemented, depending on how much peak season water use needs to be scaled back [from a baseline of approximately 1,358 million gallons (MG)]. 4 The WSCP was developed to comply with state-imposed requirements, and the curtailment stages are intended to ensure that the system – given its current supply portfolio – does not run out of water when a drought or other event (e.g., wildfire) reduces its available supply.

Absent augmentation of the current water supply, these curtailments would be the only mechanism available to keep water flowing to the City’s taps. However, the Department’s staff does not view the curtailments as being realistically attainable as a water shortage management strategy, and there is concern that meeting the targeted allocations would put public health and safety at risk. And, as discussed below, even attaining compliance with the least restrictive curtailment levels – Stages 1 and 2 – will be very challenging given the level of water use efficiency and conservation that has already been adopted throughout the community.

The distribution of peak season water use across customer classes is shown in Figure 1. Each curtailment stage calls for an overall reduction of water use in 10% increments (e.g., Stages 1 and 2 aim for a 10% and 20% reduction in overall city-wide peak season water use, respectively). Stages 3, 4, and 5 present increasingly drastic cutback targets of 30%, 40%, and 50%, respectively. The amount of water targeted to be saved at each Stage is approximately 136 MG, based on 10% incremental cuts from total peak season demand. 4 Peak water use season is defined as the six-month period starting May 1 and ending October 31. These are also the months in which there typically is little rainfall, relatively higher (summer) temperatures and, hence, generally higher water demands.

3.64 Technical Memorandum November 14, 2022 3
Figure 1. Distribution of peak water use (1,358 MG)
Source: SCWD (2021)
Within each stage, the target allocation of cutbacks varies across different SCWD customer classes, as shown in Table 1. For example, at Stage 3, the overall 30% demand reduction target entails a targeted 32% water use reduction from single family residential households, 15% from business customers, and 55% from golf courses. Overall, the priority is on preserving public health and safety by ensuring adequate allocations meet essential human needs (e.g., drinking, cooking, cleaning, and sanitation) and fire protection. The largest cuts reflect a focus on outdoor irrigation.

The relatively moderate target reductions for businesses reflect a desire to support essential economic activity (recognizing that for many businesses, water use is primarily for on-site kitchen and restroom facilities and, therefore, a public health and safety use). Under Stages 1 and 2, business impacts are expected to be relatively modest, with much of the waterconserving burden placed on outdoor uses. Nonetheless, households may struggle to live within their Stage 1 and 2 allocations (as evident from recent Stage 1 experience, discussed below).

Stage 2 curtailments may not be realistically attainable, and impacts are likely to be very onerous at Stages 3 and higher.

Distribution of peak season water use (1.38 million gallons)

3.65 Technical Memorandum November 14, 2022 4
Table 1. Customer class reduction goals at each curtailment stage Customer class Stage 1 Stage 2 Stage 3 Stage 4 Stage 5
Single family residential 11% 21% 32% 42% 49%
Multi-family residential 8% 16% 24% 32% 41%
Business 5% 10% 15% 21% 40%
Golf courses 18% 36% 55% 74% 90%
UCSC 9% 19% 28% 38% 45%
North Coast agriculture 5% 10% 15% 25% 70%
Landscape irrigation 25% 50% 75% 100% 100%
Achieving even the Stage 1 and 2 targets are challenging given the extent to which the City’s water demands have already been “hardened” (i.e., demand has already been scaled back due to extensive and successful conservation and related demand management efforts by the SCWD and the Santa Cruz community). The City of Santa Cruz already has one of the lowest residential per capita water use outcomes in California, at 45 gallons per person per day as of 2021 for indoor and outdoor use combined, and 35 gallons per capita per day (GPCD) for indoor use alone (City of Santa Cruz, 2021). As an indicator of water efficiency embraced by the Santa Cruz community, note that the City’s per capita water use is well below the state’s current goal of 55 GPCD for indoor use only (and even less than the future state standard which is slated to move to 42 GPCD by 2030 for indoor use).
5 The first use of the updated WSCP was in 2021, when SCWD declared a water shortage and implemented Stage 1 water use curtailments. The updated plan replaced the 2009 WSCP and was revised to reflect substantial reductions in customer water use, resulting in a plan with stages with considerably more negative impacts to all classes of customers than the 2009 plan (e.g., Stage 3 allotments for single family residential properties has been reduced from 10 CCF to 4 CCF).
6 During the 2021 implementation of Stage 1 approximately 30% of households exceeded their Stage 1 allotment (5 CCF), revealing how inelastic water demand may be in the City, and suggesting how challenging meeting future curtailment targets may be. The challenge is likely to be even greater if circumstances require implementing curtailments beyond Stages 1 and 2 (e.g., by Stage 3, the City is looking to reduce household water use by 32%, nearly three times as much as the 11% cutbacks targeted under Stage 1).

In future years, when climate change-driven droughts may be more severe and/or of longer (multi-year) duration, without supply augmentation the potential need to implement more restrictive curtailment stages will create even greater challenges. Hence the desire to augment 5 Per the Senate Bill passed and signed into law on September 28, 2022, by Governor Newsom. 6 CCF = hundred cubic feet, or 748 gallons

3.66 Technical Memorandum November 14, 2022 5
the City’s water supply portfolio with additional reliable water sources through, for example, more storage via groundwater augmentation.

Direct Costs Borne by SCWD
There are two categories of costs borne by the SCWD: (1) lost revenue from decreased water sales and (2) administrative costs to implement the water curtailments.

Lost revenues
SCWD’s rates are structured to generate 90% of needed revenues through the sale of water that customers pay for according to the number of billing “units” used (1 unit = 748 gallons or one hundred cubic feet CCF). To offset the costs of lost revenues from decreased water sales during curtailments, SCWD imposes and collects drought cost recovery fees from its customers.

These fees will be collected as a monthly fixed fee based on meter size for an entire fiscal year (SCWD, 2021). The size of the fixed fee increases as the curtailment stage increases. This offset is assumed in our analysis to result in no change to an individual customer’s total annual water bill (i.e., that customers will pay the same amount for less water). However, the fixed rates are based on meter size and some customers may end up paying more than their customary use bills (especially the low volume users). These higher total water bill costs are not included in our analysis, though they could have a negative impact on household and business incomes and, thus, adversely impact the local economy.

Administrative costs
Implementing water curtailments will result in administrative costs for the SCWD to pay for additional staff, equipment, etc. The SCWD anticipates using reserve funds to pay for these added administrative costs and then replenishing reserves over time from ongoing rate revenues. Table 2 summarizes the total estimated costs at each curtailment stage, revealing how the cost rises at an increasing rate as the Department progresses to higher curtailment stages (e.g., added administrative cost at Stage 3 are nearly ten times the added cost at Stage 1). Although there might be a small boost to the local economy associated with SCWD staff growth, we do not factor these costs into this analysis as, ultimately, the expense will be borne by SCWD customers.

Table 2. Estimated additional administrative costs borne by the SCWD at each water curtailment stage
Water curtailment stage Additional administrative costs 1 $146,500
2 $704,900
3 $1,362,100
4 $1,759,200
5 $2,122,400

3.67 Technical Memorandum November 14, 2022 6
Methodology for Economic Impact Analysis
The methodology applies a standard “regional economic impact analysis” approach and associated modeling tool to assess curtailment impacts on the City’s economy, and on Santa Cruz County as a whole.

Focusing on Water-Dependent Business Sectors
The methodology focuses on local business, UCSC, golf course, and North Coast agriculture sectors that are highly water dependent (see Table 3 below for a full listing of sectors). These are business sectors for which access to a relatively large supply of water is essential to the ability to provide their goods and services (i.e., where reduced access to water will adversely impact the level of business operation or, perhaps, lead to business closure). These waterdependent business sectors were identified and assessed based on the SCWD’s water use data and are consistent with a prior analysis conducted for the City (Mitchell, 2015)7.

The analysis uses projected industry-level changes in economic output (e.g., business net revenues), based on scenarios of how businesses may respond to water curtailment levels of varying severity (as described in a subsequent section of this TM, and in Appendix A).

Within the analysis, multiple “industries” (business types) can be included in a “sector”. We applied the sector-level change to output to each industry within the sector. More specifically, the IMPLAN regional economic impact model we applied (as detailed further in a subsequent section of this TM) defines the Food Manufacturing sector as including 19 industries, each of which has a different multiplier effect and subsequent economic impact (e.g., a 20% decrease to output in the “creamery butter manufacturing” industry has a different multiplier effect than the “coffee and tea manufacturing industry”). We identified the individual industries following the same approach used to identify the sectors, as included in Appendix B.

Direct Economic Impact Scenarios by Business Sector
For each highly water-dependent sector, the direct impacts on business “output” at each potential curtailment stage were assigned based on available data and professional judgement.8
For example, the tourism-related business sectors include accommodations (e.g., hotels and motels) and food service providers (e.g., restaurants). Both business types are relatively large water users and highly dependent on water supply to operate at their desired levels. Under reduced water allotments, hotels and restaurants that need to significantly reduce their water consumption are likely to adjust their business operations in ways that reduce their revenues (output). For example, under Stage 4, local restaurants – which in Santa Cruz are already water efficient – may need to reduce their hours or days of operation, and/or limit how many tables they serve while open. Likewise, hotels may need to limit occupancy rates, close on-site restaurants, or take other steps that ultimately reduce their revenues. These revenue impacts are then will likely lead to the businesses reducing payroll to employees (through layoffs and/or 7 There are a few differences from the Mitchell (2015) analysis: Computer and electronic products were excluded from our main analysis and only included as part of the sensitivity analysis; UCSC and North Coast Agriculture were added.
8 Economic output in this type of analysis typically refers to the net revenues of a business (Demski, 2020).

3.68 Technical Memorandum November 14, 2022 7
scaling back hours), cutting back purchases of local services (e.g., laundry, foodstuffs), and so forth. The recent COVID pandemic provides useful insights into the relationship between key tourism-related businesses and the associated level of water use in those business types, per Text Box 1.

Given data limitations and uncertainties regarding how various businesses would respond (see section on Caveats and Limitations, as well as Appendix A), a range of direct impacts were assigned to each sector for each of potential curtailment Stages 3, 4 and 5. These percentage reduction “direct impact scenarios” for each water dependent business sector are shown in Table 3.

Text Box 1: Tourism Economic Impacts and Associated Water Use The pandemic had a significant impact on tourism and the economic returns that accommodation and food service businesses across Santa Cruz County, as documented by a report issued by the State of California’s Visit California program: The Economic Impact of Travel (Visit California, 2022). Comparing data from a “normal” 2019 to COVID-impacted 2020, total tourism spending in the county declined by nearly half, with associated negative impacts on business earnings (e.g., net revenues, output), employment, and local tax revenues declining by 23% to 28%.

Also shown is the associated similar decline of 28% in peak season water use by the restaurant and accommodation sectors combined, based on SCWD consumption and billing data. This comparison suggests that at a Stage 4 business-targeted water use reduction of 21%, for example, we might expect tourism-related business output to contract by roughly 20% to 30%.

Tourism-Sector Impacts and Water Use: 2020 v. 2019
Total Spending -47%
Earnings -23%
Jobs -23%
Local Tax Revenues -28%
Peak Season Water Use
(Hotels and Restaurants combined) -28%
Sources: Visit California, 2022; SCWD Billing Data

3.69 Technical Memorandum November 14, 2022 8
Table 3. Percentage output reduction scenarios for water dependent business sectors Sector Stage 3 Stage 4 Stage 5
Nursery, landscape, and garden 45% – 60% 50% – 70% 50% – 70% Food services and drinking places 5% – 15% 25% – 40% 50% – 65% Food manufacturing 5% – 15% 25% – 40% 50% – 65%
Breweries and distilleries 5% – 15% 25% – 40% 50% – 65% Car washes 5% – 15% 25% – 40% 50% – 65%
Cement/concrete manufacturing 5% – 15% 25% – 40% 50% – 65% Accommodation 5% – 15% 20% – 30% 40% – 60%
Amusement and theme parks 5% – 15% 20% – 30% 40% – 60%
Fitness and Recreational Centers 5% – 15% 20% – 30% 40% – 60% Tourism-supported retail 5% – 15% 20% – 30% 40% – 60%
UCSC 15% – 25% 30% – 65% 30% – 65%
Golf courses 25% – 35% 40% – 60% 65% – 85%
North Coast agriculture 5% – 15% 20% – 30% 40% – 60%
Nursery, landscape, and garden
These businesses will be hit hardest by any curtailments because their customer base is largely homeowners who will also have less capacity to water and purchase plants. We assume these businesses will already be hit hard at Stage 2, such that the incremental change of moving to Stage 3 will be modest.9
Restaurants, manufacturing, and car washes
These businesses are grouped together because the impacts of curtailments are likely going to be similar. Tourism-related economic data (Visit California, 2022) and SCWD water usage data from 2019 to 2022 demonstrates the food services sector suffered a 46% reduction in consumer spending during the pandemic year 2020, as compared to the previous year and used 42% less water. The Stage 4 curtailment is assumed to have a similar impact as that of the pandemic on water usage in the applicable sectors. Manufacturing and car washes are very water-dependent and are assumed to be similarly impacted by curtailments.10 9 Landscape service-providers and related businesses are likely to have seen a significant shift in their business sector as the result of the series of water supply shortfalls experienced over the past decade. Those landscape and garden businesses that have survived have likely done so by shifting to providing xeriscape and related water efficient goods and services compatible with a more water-constrained and water-conserving customer base. 10 It is unlikely many of the businesses in these sectors would make rapid recoveries at the end of the peak water use season, as it is likely to take many months to restore the SCWD’s reservoir levels, and multi-year drought periods are likely to reoccur periodically.

3.70 Technical Memorandum November 14, 2022 9
Tourism and recreation
The business sectors that fall into this category include accommodation, amusement and theme parks, fitness and recreational centers, and tourism-supported retail. Tourism-related economic data (Visit California, 2022) and SCWD water usage data demonstrates the accommodation sector endured a 34% reduction in consumer spending during the pandemic as compared to the previous year, and it ended up using 23% less water in the peak season. The impact on accommodation was not as severe as it was on the food service sector, which is why they are treated differently in this analysis. The Stage 4 curtailments (21% water use reduction) are assumed to have a similar impact as that of the pandemic on water usage (23%) and the associated impacts on the sector’s net revenues and the local economy. The same shock is assumed to occur with the other tourism-related businesses.

Golf courses
The SCWD provides water to two golf courses in its service area: the public DeLaveaga Golf Course and the private Pasatiempo Golf Course. The Pasatiempo Golf Course receives recycled water (secondary treated wastewater) from Scotts Valley for 90% of its irrigation needs, so will likely be relatively unimpacted by the curtailments. The DeLaveaga Golf Course, however, relies on SCWD water service and will likely be highly impacted by curtailments. We assume that DeLaveaga would have to close operations at a Stage 5 water curtailment (of 90%) because there will be insufficient water to irrigate the greens. The DeLaveaga Golf Course will likely need to take additional actions to remain in business during Stage 4 and 5 curtailments, such as actions taken by Australian golf courses because of the Millennium Drought, as well as similar actions taken by several California golf facilities.11
UCSC
UCSC’s water use is 23% for irrigation, and the balance for student housing, food services, and other indoor uses. By Stage 3, the targeted 28% reduction will need to cut into indoor uses. By Stages 4 and 5, cutbacks to meet the associated reduction targets of 38% and 45% may not be feasible if students remain residing or spending large portions of their days on campus.

SCWD water usage data demonstrates that UCSC’s water use went down significantly when students went remote during the pandemic, with a 39% reduction in peak season water use.

We assume the impact of a Stage 4 curtailment scenario would thus be similar the impact of the pandemic because UCSC would have to require students to go remote to avoid going over its water allocation. We assume no change between stages 4 and 5 because the big ‘hit’ comes when students go remote at stage 4.

North Coast Agriculture
Given the 12 farms in the service area receive water from multiple sources, we assumed a similar relationship to output as we did for the restaurant sector. We assume that over time with less water, farmers will be forced to irrigate fewer acres, or switch to less water-intensive crops.
11 Examples of golf course adaptations include installing liners in artificial lakes, turning off sprinklers in less trafficked areas, and investing in recycled water (including use of on-site treatment facilities) (Anderson, 2015).

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Direct Economic Impacts on Household Customers
The Water Shortage Contingency Plan (SCWD, 2021) outlines an excessive use penalty system to provide a financial incentive for customers to stay within their allocation. The inclusion of excess use penalties during water rationing is consistent with the same approach used in the 2009 WSCP and included in the City’s Municipal Code codifying WSCP provisions since that time.

Note that the Department does not wish to impose these penalties. Rather, under dire circumstance imposed on the system by severe or extended drought, the penalties serve as a necessary tool to incentivize everyone to do their part to ensure that scarce water is available for essential human health and safety purposes. The penalties are structured to disincentivize those who would otherwise ignore their allocations and instead opt to pay for their overuse of water. While the penalties might be viewed as draconian or as “punishment,” their necessary objective is to have everyone in the community share the real burden of keeping the taps from running dry. As noted in the Santa Cruz Municipal Code [Section 16.01.140 I] (SCWD 2021):

The city’s water is a scarce and irreplaceable commodity and [these penalties are] intended to equitably distribute that commodity among water department customers and to assure that, to the extent feasible, city water is conserved and used only for purposes deemed necessary for public health and safety… [T]he penalty schedule is not to be construed as creating a “water pricing” structure pursuant to which customers may elect to pay for additional water at significantly higher rates. To this end, a customer’s repeated violation of this chapter shall result in either the installation of a flow restriction device or disconnection of the customer’s property from the city’s water service system at the customer’s cost.

Excess use penalties are charged on a per unit basis based on the amount of customer water use over its allocation (see Table 4) and is applied on the customer’s monthly water bill. These penalties are additional costs customers will have to pay should their water use exceed their allocation and are therefore important to account for in this analysis as a reduction in disposable income. Disposable income is money that is available to be saved or spent (Clouse, 2021a). Reductions in household disposable income will in turn result in some reduced spending on locally provided goods and services, which in turn will work its way through the regional economy as indirect and induced impacts.

Table 4. Excess use penalties based on overage
Overage Excess use penalty per overage
1 CCF over allocation $25
2 CCF over allocation $75
3 CCF over allocation $125
The SCWD currently has 19,000 single family and 7,085 multifamily residential households (SCWD, 2021, and SCWD account data) – a total of 26,085 households in its service area. The

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2014 and 2015 water restrictions imposed by the SCWD resulted in an average of 5% of households exceeding their allocation. These restrictions were Stage 3 curtailments under the old Water Use Management Plan, which were 15-25% reduction of water use (SCWD, 2016).

SCWD’s former water restrictions (from 2016) were far less stringent than the current SCWD (2021) restrictions. For example, under Stage 3 of the 2016 policy, residential customers received a 10 CCF per month allocation.
12 In contrast, the 2021 plan limits the residential
allocation at Stage 1 to only 5 CCF per customer, and to 3 CCF at Stage 3 (based on a household size of three).

Additionally, over the past several years, the demand has become more hardened in the SCWD’s service area. As a result, we apply scenarios of the SCWD imposing the excess use penalty to 30% of households under a Stage 3 curtailment scenario (with a 4 CCF monthly limit for households of 3 persons), and 50% under Stage 4 and Stage 5 curtailment scenarios (with a water allotment of 3 CCF per household of 3 persons). These scenarios are based on the Department’s experiences with households exceeding their allotments during the 2021 Stage 1 curtailments.

Tables 5 and 6 present the specific assumptions at each stage and the associated costs assuming the full six months of the peak season. The total excess use penalties at each stage are used in the economic impact analysis to reflect the direct impact on disposable household income. The estimated total penalties amount to significant sums, and the Department hopes not to impose such penalties by augmenting its water supply to ensure the City does not run out of water in a multi-year drought.

Table 5. Scenario for excess use penalties on households for Stage 3 Overage
above 4 CCF
Excess use penalty
per overage
Percent of noncompliant
households
Number of noncompliant
households
Total excess
use penalty
1 CCF over $25 20% 5,217 $782,550
2 CCF over $75 10% 2,609 $1,173,825
Total 30% 7,826 $1,956,375
Table 6. Scenario for excess use penalties on households for Stages 4 and 5 Overage
above 4 CCF
Excess use penalty
per overage
Percent of noncompliant
households
Number of noncompliant
households
Total excess
use penalty
1 CCF over $25 10% 2,609 $391,275
2 CCF over $75 20% 5,217 $2,347,650
3 CCF over $125 20% 5,217 $3,912,750
Total 50% 13,043 $6,651,675
12 For a household of up to 4 people. Additional water was allocated to those customers with larger households.

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Indirect and Induced Economic Impacts (Applying the IMPLAN Model) The direct economic impacts from the scenarios described above were used as input for the widely applied and well-accepted regional economic impact, input-output (I-O) model, IMPLAN.
13 The IMPLAN model, and types of economic impacts it is used to analyze, are briefly described in Text Box 2. In essence, the IMPLAN model simulates how direct economic impacts in each sector work their way through the local economy in the form of indirect and induced economic impacts.

For example, reduced occupancy at local hotels means reduced hotel revenues (a direct impact), which is likely to result in reduced wages and salaries paid to hotel employees, reduced purchases of goods and services provided (in part) by local laundry and foodstuff vendors, etc. (indirect impacts). The indirect impacts in turn will reduce incomes in those affected local sectors, with subsequent reductions in expenditures on other local goods and services (induced impacts). Outputs from the IMPLAN simulations include reductions in regional economic output, employment, labor income, and tax revenues.

The IMPLAN analysis was conducted for two separate sets of Stage-specific impacts: (1) the impact on business activities of key water-dependent sectors14 and (2) the impact of reducing residential customers’ household disposable incomes due to anticipated excess use penalties. 15 IMPLAN uses zip code data. We included all zip codes included in the Santa Cruz Water SCWD, specifically 95060, 95062, 95064, 95065. The base year is 2019 and all dollars are reported in 2022 dollars.

Economic Impact at County level
Our economic analysis focuses primarily on the combined direct, indirect, and induced impacts within and to the City of Santa Cruz, as reflected by the SCWD service area. In addition, we explored how the economic impacts of a SCWD water shortage also extend beyond City boundaries and impact Santa Cruz County as a whole. That is, direct impacts created within the City also are magnified and distributed throughout the broader regional economies, specifically between the SCWD service area and the county outside the service area.

To assess County-wide impacts, we used IMPLAN’s Multi-Regional Input-Output Analysis (MRIO). “Multi-Regional Input-Output (MRIO) analysis makes it possible to track how an impact on any of the 546 IMPLAN Industries in a Study Area region affect the production of all 546 Industries and household spending in any other region in the US (state to state, county to county, zip code to zip code, county to multi-county, county to state, etc.)” (Clouse, 2022).

We defined our regions as follows:
• All zip codes within the SCWD service area; and
• All zip codes within Santa Cruz County, not including those within the SCWD service area.
13 IMPLAN was initially developed and applied by the federal government (see history of IMPLAN at https://implan.com/history/). 14 The impact on business was run as an “industry output event” following Clouse (2021b) 15 The impact on households were run as a change in household income, following Clouse (2021c) and discussions with IMPLAN staff.

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Key Findings
The economic analysis provides a considerable amount of empirical detail. In this section, we focus on some of the higher-level findings. Additional and more detailed empirical results are provided in Appendices C through F.

An economic impact analysis is, by its nature, an imprecise exercise in which numerous uncertainties exist and many key assumptions need to be made (as described throughout this TM and highlighted in the next section). Nonetheless, the estimates developed here may well Text Box 2: Regional Economic Impacts and the IMPLAN Model The IMPLAN model (IMpact Analysis for PLANning) is an economic input-output (I-O) model, originally developed by the federal government, that contains information on the relationships within an economy, both between businesses, and between businesses and final consumers.

IMPLAN uses this information to predict changes in overall economic activity resulting from a flow of money into and out of the local economy (e.g., a visitor spending). IMPLAN is widely used by academics and the public and private sectors, and it is generally accepted as the standard for economic I-O analysis.

To estimate regional economic impacts, IMPLAN constructs local level multipliers. Multipliers describe the response of the economy to a change in demand or production. Multipliers measure the economic impact of direct effects, as well as how the direct effects ripple through the economy to create indirect and induced impacts. The magnitude of indirect and induced effects depends on the propensity of businesses and households in the region to purchase goods and services from local suppliers. Purchases from local suppliers have ripple effects in the economy, whereas purchases from non-local (outside of the county in this case) suppliers do not result in ripple effects because the money spent for inputs leaves the local economy. IMPLAN accounts for this in the development of local multipliers by assigning regional purchase coefficients to goods and services purchased by individual sectors and households. IMPLAN also reports implications for state and local tax revenues.

IMPLAN measures the direct, indirect, and induced impacts of changes to a regional economy described as:
• Direct impacts are the initial changes in business revenues (“output") such as the increased receipts from enhanced tourism, or a decrease in receipts when limited water availability limits businesses operations. Direct impacts include money tourists spend while visiting the area on food, lodging, and retail purchases.
• Local businesses that benefit from direct spending then, in turn, spend additional (or reduced) money on goods and services that they need to operate their businesses. These are termed indirect expenditures.
• Direct and indirect spending generates employment in the local region, creating additional (or reduced) income for households, which generates further changes in local spending known as induced expenditures.

More information on IMPLAN can be found on their website: https://implan.com/.

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be conservative, and are consistent with findings derived from other investigations of water supply shortages (e.g., M-Cubed, 2008a, 2008b, for East Bay Municipal Water District). 16 As shown in the tables and associated text discussions that follow, water supply curtailments at Stages 3, 4 and 5 are anticipated to create significant economic losses to the community. These estimated losses in economic output, jobs, tax revenues, and other key metrics reveal how much value there is likely to be if/when the City makes investments to reduce the size of potential future water supply shortfalls.

For example, the estimated economic losses can be interpreted relative to the amount of added water supply that would be needed to avoid a given level of curtailment (e.g., as a cost per MG, or acre-foot, of shortage). The resulting “cost” of not having sufficient water can then be used as a benchmark against which to compare the expense of investments needed to secure that amount of water. That is, the economic cost of not having enough water may be viewed as the benefit (avoided cost) of acquiring the additional water. Further, by investing in a more secure and reliable water supply portfolio, the community may be able to attract businesses from locations in which the water supply is less secure and less reliable.

High-Level Results
Table 7 summarizes the estimated change in overall impact on City economic output from moving to increasingly more restrictive curtailment stages on businesses and other nonresidential sectors. Also shown is the implied economic cost per volume of water targeted overall for peak season use reductions.

For example, moving from Stage 3 to Stage 4 reduces estimated annual economic output within the City by between approximately $210 million and $262 million. This amounts to $1.5 million and $1.9 million of lost economic output per MG of reduced water availability (based on 136 MG of additional water required to avoid moving from one curtailment stage to the next more severe curtailment stage for one water year peak period).

Another way of interpreting this finding is that if enough additional water supply was made available such that the City could avoid applying Stage 4 restrictions and instead implement the less restrictive Stage 3 limits (e.g., adding the equivalent of 10% of normal peak season water usage, i.e., 136 MG), then the City would gain an estimated additional economic output of $210 million to $262 million. This translates to $1.5 million to $1.9 million of added economic output per MG added (compared to the water supply augmentation options currently being evaluated by the City, which are each expected to cost less than $36,000 per MG produced).

This is one way of viewing the value added of developing an additional source of available water supply.
16 For example, an analysis of the economic impacts of water supply shortages for the East Bay Municipal Utility District indicates that estimated lost economic output grows rapidly if curtailments rise above a 15% supply reduction. The estimated loss of output was nearly $20 billion – or more than $2 million per MG foregone – if a 15% shortage were to grow to a 25% curtailment level (derived from M-Cubed, 2008a and 2008b; updated to 2022 dollars).

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Table 7. City-only incremental impacts from business curtailments (select industries only) Impact Change in output
($M)
$/MG**
($M)
$/AF
($M)
Stage 2* to 3 $114.4 – $242.9 $0.8 – $1.8 $0.3 – $0.6
Stage 3 to 4 $209.9 – $262.4 $1.5 – $1.9 $0.5 – $0.6
Stage 4 to 5 $254.2 – $284.6 $1.9 – $2.1 $0.6 – $0.7
* Assumes de minimus economic impact at Stage 2 for businesses ** Applies 136 MG need to meet each Stage’s 10% incremental reduction in total peak season demand Table 8 provides the same information as Table 7 but includes County-wide economic impacts.

The results in Table 8 reflect the degree to which impacts generated within the City – by SCWDimposed water curtailments on its non-residential customers – “spill over” to also impact the broader county-level economy. In general, county-wide impacts on regional economic output from City-based curtailments are roughly 10% greater than the impacts experienced within the City itself.

Table 8. County-level incremental impacts from business curtailments (select industries only) Impact Change in output
($M)
$/MG**
($M)
$/AF
($M)
Stage 2* to 3 $126.1 – $266.8 $0.9 – $2.0 $0.3 – $0.6
Stage 3 to 4 $229.4 – $287.0 $1.7 – $2.1 $0.5 – $0.7
Stage 4 to 5 $277.8 – $311.2 $2.0 – $2.3 $0.7 – $0.8
* Assumes de minimus economic impact at Stage 2 for businesses ** Applies 136 MG needed to meet each Stage’s 10% incremental reduction in total peak season demand Economic output is only one measure of the losses incurred from water supply curtailments imposed on businesses and other non-residential water customers. Table 9 shows the losses estimated at each Stage from business and other non-residential sector impacts, stated in terms of number of jobs, labor income, value added, and tax revenues, as well as the economic output foregone.

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Table 9. City-level negative economic impacts (losses) from select business and other non-residential curtailments
Metric (Losses) Total impact at Stage 3 Total impact at Stage 4 Total impact at Stage 5 Output lost ($M) $114.4 – $242.9 $324.3 – $505.3 $578.5 – $789.9 Labor income lost ($M) $53.8 – $109.1 $141.0 – $218.6 $245.7 – $337.3 Value added lost ($M) $68.6 – $144.8 $192.2 – $299.3 $341.6 – $467.8 Employment (# of jobs lost) 1,146 – 2,428 3,236 – 5,066 5,752 – 7,902 Tax revenues lost: City of Santa Cruz*($M) $2.1 – $5.4 $8.0 – $12.7 $15.5 – $21.1 Tax revenues lost: County ($M) $0.7 – $1.8 $2.7 – $4.3 $5.3 – $7.1 Tax revenues lost: State ($M) $3.0 – $7.5 $10.9 – $17.1 $20.6 – $28.0 Tax revenues lost: Federal ($M) $8.4 – $17.5 $23.0 – $35.8 $40.6 – $55.6 Total Tax Revenues Lost: Total ($M) $14.1 – $32.2 $44.6 – $69.8 $82.0 – $111.8 Including household-driven economic impacts arising from reduced disposable incomes (due to excess use penalties), along with the non-residential sector impacts described above, increases the total amount of loss associated with water supply curtailments, but only to a very small degree (less than 1%). That is, the adverse economic impact of estimated excess use penalties on households has a relatively small impact on the community’s overall economy as shown in Table 10, although some economically challenged individual households may be burdened considerably.

Table 10. City-level negative economic impacts (losses) from residential curtailments Metric (Losses) Stage 3 Stages 4 and 5
Output lost $459,129 $1,561,038
Labor income lost $164,993 $560,975
Value added lost $302,657 $1,029,033
Employment (# of jobs lost) 3 10
Tax revenues lost: City of Santa Cruz* $11,222 $38,155
Tax revenues lost: County $7,818 $12,901
Tax revenues lost: State $16,457 $55,953
Tax revenues lost: Federal $29,866 $101,545
* Includes sub-county general and sub-county special districts (e.g., road maintenance, fire protection). 17 17 A complete list of the Santa Cruz Special Districts can be found at: https://www.co.santacruz.ca.us/Departments/AuditorControllerHome/CountySpecialDistricts/ListofSantaCruzCountySpecialDistricts.aspx

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Table 11 provides City-level impacts from the combined effects of curtailments on both the SCWD’s residential and non-residential customers.

Table 11. City-level negative economic impacts (losses) from combined business and residential curtailments
Metric (Losses) Total impact at Stage 3 Total impact at Stage 4 Total impact at Stage 5 Output lost ($M) $114.9 – $243.4 $325.9 – $506.9 $580.1 – $791.5 Labor income lost ($M) $54.0 – $109.3 $141.6 – $219.2 $246.3 – $337.9 Value added lost ($M) $68.9 – $145.1 $193.2 – $300.3 $342.6 – $468.8 Employment (# of jobs lost) 1,149 – 2,431 3,236 – 5,066 5,752 – 7,902 Tax revenues lost: City of Santa Cruz*($M) $2.1 – $5.4 $8.1 – $12.7 $15.6 – $21.1 Tax revenues lost: County ($M) $0.7 – $1.8 $2.7 – $4.3 $5.3 – $7.1 Tax revenues lost: State ($M) $3.0 – $7.5 $10.9 – $17.1 $20.7 – $28.0 Tax revenues lost: Federal ($M) $8.4 – $17.5 $23.1 – $35.9 $40.7 – $55.7 The sections below summarize key empirical results for each of Stage 3, 4 and 5. Further results and details are provided in Appendices C, D and E.

Key Results for Stage 3 Curtailments on Businesses and Other Non-Residential Customers Table 12. Range of negative economic impacts (losses) of Stage 3 water curtailments on included businesses: City/Service Area
Impact
type
Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs lost)
Direct $104.3 – $220.9 $50.0 – $100.8 $62.7 – $132.1 1,088 – 2,302 Indirect $6.8 – $15.3 $2.6 – $5.9 $3.7 – $8.3 37 – 82
Induced $3.3 – $6.7 $1.2 – $2.5 $2.1 – $4.4 21 – 43
Total $114.4 – $242.9 $53.8 – $109.1 $68.6 – $144.8 1,146 – 2,428

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Table 13. Range of In-City negative tax impacts (losses) of Stage 3 water curtailments on included businesses
Impact type
Tax revenues lost:

City of Santa Cruz*
($M)
Tax revenues
lost: County
($M)
Tax revenues
lost: State
($M)
Tax revenues
lost: Federal
($M)
Tax revenues
lost: Total
($M)
Direct $1.8 – $4.9 $0.6 – $1.7 $2.7 – $6.8 $7.7 – $16.0 $12.8 – $29.3 Indirect $0.1 – $0.3 $0.1 – $0.1 $0.2 – $0.5 $0.5 – $1.1 $0.9 – $1.9 Induced $0.1 – $0.2 $0.0 – $0.1 $0.1 – $0.2 $0.2 – $0.5 $0.4 – $0.9 Total $2.1 – $5.4 $0.7 – $1.8 $3.0 – $7.5 $8.4 – $17.5 $14.1 – $32.2 * Includes sub-county general and sub-county special districts (e.g., road maintenance, fire protection)18 Key Results for Stage 4 Curtailments on Businesses and Other Non-Residential Customers Table 14. Range of negative economic impacts (losses) of Stage 4 water curtailments on included businesses: City/Service Area
Impact
type
Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs lost)
Direct $294.6 – $458.8 $129.6 – $200.8 $175.0 – $272.4 3,067 – 4,802 Indirect $21.0 – $32.9 $8.2 – $12.8 $11.5 – $18.0 113 – 176 Induced $8.7 – $13.6 $3.2 – $5.0 $5.7 – $8.8 56 – 88
Total $324.3 – $505.3 $141.0 – $218.6 $192.2 – $299.3 3,236 – 5,066 Table 15. Range of negative tax impacts (losses) of Stage 4 water curtailments on included businesses
Impact type
Tax revenues lost:

City of Santa Cruz*
($M)
Tax revenues
lost: County
($M)
Tax revenues
lost: State
($M)
Tax revenues
lost: Federal
($M)
Tax revenues
lost: Total
($M)
Direct $7.5 – $11.7 $2.5 – $4.0 $9.9 – $15.6 $20.9 – $32.5 $40.8 – $63.8 Indirect $0.4 – $0.6 $0.1 – $0.2 $0.6 – $1.0 $1.5 – $2.4 $2.7 – $4.1 Induced $0.2 – $0.3 $0.1 – $0.1 $0.3 – $0.5 $0.6 – $0.9 $1.2 – $1.8 Total $8.0 – $12.7 $2.7 – $4.3 $10.9 – $17.1 $23.0 – $35.8 $44.6 – $69.8 * Includes sub-county general and sub-county special districts (e.g., road maintenance, fire protection) 19 18 Ibid.
19 Ibid.

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Key Results for Stage 5 Curtailments on Businesses and Other Non-Residential Customers Table 16. Range of negative economic impacts (losses) of Stage 5 water curtailments on included businesses: City/Service Area
Impact
type
Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs lost)
Direct $524.9 – $716.6 $225.0 – $308.9 $310.5 – $425.3 5,448 – 7,484 Indirect $38.3 – $52.3 $15.1 – $20.6 $21.1 – $28.7 206 – 282 Induced $15.3 – $21.1 $5.6 – $7.7 $10.0 – $13.7 99 – 136 Total $578.5 – $789.9 $245.7 – $337.3 $341.6 – $467.8 5,752 – 7,902 Table 17. Range of negative tax impacts (losses) of Stage 5 water curtailments on included businesses
Impact type
Tax revenues lost:

City of Santa Cruz*
($M)
Tax revenues
lost: County
($M)
Tax revenues
lost: State
($M)
Tax revenues
lost: Federal
($M)
Tax revenues
lost: Total
($M)
Direct $14.5 – $19.6 $4.9 – $6.6 $19.0 – $25.8 $36.8 – $50.4 $75.1 – $102.4 Indirect $0.7 – $0.9 $0.2 – $0.3 $1.1 – $1.5 $2.8 – $3.8 $4.8 – $6.5 Induced $0.4 – $0.5 $0.1 – $0.2 $0.6 – $0.8 $1.0 – $1.4 $2.1 – $2.9 Total $15.5 – $21.1 $5.3 – $7.1 $20.6 – $28.0 $40.6 – $55.6 $82.0 – $111.8 * Includes sub-county general and sub-county special districts (e.g., road maintenance, fire protection) 20 Caveats and Limitations
All economic impact analyses and forecasts – and the tools and data applied in developing such assessments – inevitably are subject to numerous uncertainties and by necessity include several assumptions. Nonetheless, with suitable care, use of conservative and transparent assumptions, and sensitivity analyses, the outcomes provide useful information. In this section, we aim to describe the key uncertainties we faced, articulate the key assumptions made in developing the analysis, and describe the impact they may have on our results.

Business Sectors Included or Excluded
Several types of water-dependent businesses were included in the analysis, and several excluded because of uncertainty about their relevance as potentially large water users within the SCWD service area. This is most evident in the food manufacturing and computer and electronics sectors. Appendix B provides details on the business types used within the core analysis, and Appendix C provides details on those added in our sensitivity analysis. 20 Ibid.

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Throughout this TM, we report the results from the more conservative, shorter list of businesses impacted (see Table B1). Adding in the additional business types increases the extent of economic loss. For example, at Stage 3, there is an increase in output lost ranging from $9.4 and $28.2 million annually and additional jobs lost ranging from 22 to 65. Additional detail is provided in Appendix B.

Additionally, we did not include non-residential water service customers in the medical facilities, nursing care, and related medical and elder-care service sectors because we assume they would take priority over other businesses in terms of water usage, even though they tend to be relatively high-volume water users. This is a conservative omission, and it assumes businesses will stay within their allocations. It is possible, however, that medical and related care services would need to be scaled back to meet curtailment targets, with an associated nonmonetary cost to the community (in terms of patient care) as well as a potentially large adverse economic impact (which likely would be significant, given the large revenues the sector earns from the services provided).

Business Recovery after Peak Season
In the analysis, we apply a business downturn for the full year, not just the six-month peak water use season. If some businesses can rebound quickly after a curtailment period, then our results might overstate the economic losses. However, many of the businesses most impacted – such as accommodations, restaurants, and other tourism-related sectors – have strong seasonal business patterns that match the peak water use period. Further, in the months following a drought-impacted peak water use period, the City is likely to still be in a water-short situation and seeking to refill Loch Lomond and hedge against the increasing likelihood of a multi-year drought continuing into the following year or beyond. And, after a year or two of water shortage-impacted business revenues, some businesses may choose to close entirely or relocate. Thus, we do not expect that our use of year-long impacts generates an overstatement of adverse economic impacts.

New Businesses Attracted to the City
Increased water supply reliability is likely to help attract new businesses to the region, whereas the risk of water shortages is likely to create a disincentive for new enterprises to locate (or existing companies to expand) in the City. We have not included such potential business location impacts within our analysis, which likely results in an underestimate of the adverse impacts of curtailments.

Impacts from Penalty-Based Reductions in Household Disposable Income Estimated levels of excess use penalties are applied in our analysis to assess the impact of reducing disposable income on those residential households projected to exceed their water use allotments in Stages 3, 4 and 5. There are several uncertainties associated with this aspect of the analysis, including how many households would actually exceed their water allotments, the degree to which the SCWD would apply and enforce collection of such penalties, and how the loss of disposable income would impact household spending patterns.21 However, the 21 From IMPLAN re: change in HH spending (Clouse, 2021c): “In the case of a rate hike, you would see a reduction or negative impact in households… Giving a household less disposable income doesn’t necessarily mean they won’t

3.82 Technical Memorandum November 14, 2022 21
adverse economic impact projected from household-level losses from the penalties is relatively very small (less than 1%), and we rely predominantly on the impacts on the non-residential customers in reporting our key findings (i.e., the household level impacts we develop do not affect our key outcomes and interpretations).

In addition, not included in our economic impact estimates are the adverse effects of the additional costs borne by SCWD customers due to increased administrative costs borne by the utility at high-level curtailment stages, or the impact of drought cost recovery fees. Ultimately, all these costs would be borne by the customers of the system, to cover the actual total costs of service incurred by the Department.

References
Anderson, M. Is your golf club ready for the next drought? Published in Golf Industry Central.

Available: https://www.golfindustrycentral.com.au/golf-industry-news/is-your-golfclub-ready-for-the-next-drought-2/. Accessed 10/14/22.

City of Santa Cruz. 2021. Understanding Per Capita Water Use. https://www.cityofsantacruz.com/government/citydepartments/water/conservation/more-information/per-capita-water-use.

Clouse, C. 2021a. Understanding types of income. IMPLAN Article. Available:
https://support.implan.com/hc/en-us/articles/360043625353-Understanding-Types-ofIncome#:~:text=Disposable%20income%20is%20household%20income,to%20be%20sav ed%20or%20spent. Accessed 10/10/22.

Clouse, C. 2021b. Examining a Total Economic Change. IMPLAN Article. Available:
https://support.implan.com/hc/en-us/articles/360059904933-Examining-a-TotalEconomic-Change. Accessed 10/10/22.

Clouse, C. 2021c. Utility Purchases and Energy Rebates. IMPLAN Article. Available:
https://support.implan.com/hc/en-us/articles/360035972973-Utility-Purchases-EnergyRebates. Accessed 10/10/22.

Clouse, C. 2022. MRIO: Introduction to Multi-Regional Input-Output Analysis. Avalable:
https://support.implan.com/hc/en-us/articles/115009713448-MRIO-Introduction-toMulti-Regional-Input-Output-Analysis. Accessed 10/10/2022.

Demski, J. 2020. Understanding IMPLAN: Direct, Indirect, and Induced Effects. IMPLAN Blog.

Available: https://blog.implan.com/understanding-implan-effects. Accessed 10/5/2022. pay their student loans or buy groceries. They may instead cut their utility usage or decrease their entertainment budget. If the increase is small enough it may have little to no impact on household spending for any group.

Remember, different households may respond differently, depending on the size of the rate increase, their needs, and income level. A larger increase will likely affect the spending of lower income households but may not affect the spending of higher income households as these payments may come from savings (leakages in IMPLAN).

Per conversations with IMPLAN, modelers are advised to add taxes and savings into the IMPLAN inputs to account for the fact they are removed during the model runs. However, to be conservative, we did not make assumptions on taxes and savings and therefore our results may be an underestimate of the impacts.”

3.83 Technical Memorandum November 14, 2022 22
M-Cubed. 2008a. Addendum to Shortage Cost Technical Memorandum. Prepared for the East Bay Municipal Utility District. M-Cubed, San Francisco, CA. February 6.

M-Cubed. 2008b. Cost of Water Shortage. Prepared for the East Bay Municipal Utility District.

M-Cubed, San Francisco, CA. March 14.

Mitchell, David; M. Cubed. 2015. Consumer Costs of Water Shortage: Overview and Empirical Evidence. Presentation to the Water Supply Advisory Committee. February 11, 2015.

Raucher, R.S., J. Henderson, J. Clements, M. Duckworth, J.C. Kiefer, and B. Dziegielewski. 2015.

The Value of Water Supply Reliability in the Commercial, Industrial, and Institutional (CII) Sectors. WateReuse Research Foundation. Alexandria, VA.

SCWD. 2016. 2015 Urban Water Management Plan. Available:
https://www.cityofsantacruz.com/home/showpublisheddocument/55168/6360842442 71470000. Accessed 10/14/22
SCWD. 2021. Appendix O: 2021 Water Shortage Contingency Analysis and Implementation. In 2020 Urban Water Management Plan.
https://www.cityofsantacruz.com/home/showpublisheddocument/86546/6376912755 58030000.

Visit California. 2022. The Economic Impact of Travel in California. Prepared by Dean Runyan Associates. April.

3.84 Technical Memorandum November 14, 2022 A1
Appendix A: Economic Impacts Grow Proportionally Greater as Curtailments get More Restrictive
The degree to which a business’ economic activity declines with water supply curtailments will vary according to many case-specific circumstances. Nonetheless, the level of adverse impact on a business is likely to grow at a proportionally increasing rate as curtailments get more severe (i.e., a 10% more restrictive curtailment is likely to lead to a greater than 10% impact on output). The following discussion explains this likely relationship of proportionally greater economic impacts as curtailment levels get more restrictive.

Some business customers may use all the water they purchase as essential inputs to their output production. In such cases, there is little or no room to accept water supply limitations without also cutting back on the level of production, and economists would say that output in this case is “inelastic” with respect to water availability. In such cases, a 20% reduction in water supply (for example) would likely result in a significant reduction in production levels, which in turn would likely translate into reduced payroll (workers laid off or hours scaled back), reduced business income, fewer tax revenues generated, and so forth.

In other and probably more typical circumstances, CII entities use water for a variety of purposes, including landscape irrigation, cleaning, cooling, and production processes. In such situations, a CII customer can probably accommodate a modest curtailment in water supply by eliminating or reducing nonessential water uses (e.g., landscape irrigation), and apply the remaining allocation to essential production processes without a loss of product output and income.

One way of visualizing this important relationship between CII output and water supply curtailment levels is shown in Figure A.1. The vertical axis represents the output of the firm, and the horizontal axis reflects the percentage of water use restrictions. With a full allotment of water (0% curtailment), the firm produces 100% of its targeted output, as shown at point “a” on the curve.

3.85 Technical Memorandum November 14, 2022 A2
Figure A.1. Relationship between business output and the level of water supply curtailment.

To the extent that the CII entity uses water in “nonproduction” activities (e.g., landscape irrigation around a factory or office building), it can incur some level of water-use curtailments without impacting output. Thus, there is some level of curtailment for which little or no impact on production output is anticipated. This is depicted as the CII entity being at point “b” in the graph, using up to X% less water but still able to produce 100% of its product output. For some CII customers, X% may be quite high—perhaps 10%, or even greater than 40%, depending on specific circumstances. This means that if water use restrictions of X% or less are placed on the entity, there would be little or no change in production and, hence, little or no regional economic impact. However, for some CII entities, X may be close to 0%, meaning that any level of water supply curtailment would have an adverse impact on production and, hence, a negative economic impact.

Beyond X% of normal year water consumption, the firm’s water use is directed at its main production processes. Thus, any curtailment greater than X% begins to have a negative impact on output and, hence, the regional economy. Thus, the output curve declines beyond an X% curtailment. This is shown in the figure by the decrease in production output as the CII entity faces curtailment levels greater than X%.

For curtailments exceeding X%, perhaps the CII entity has opportunities to make more efficient use of some of its water-consuming production activities. In such a case, output falls at a relatively modest rate relative to the water-use curtailment beyond X%, say up to a Y% curtailment, where the firm is operating at point “c.” In other words, the output impacts from a loss of water availability of between X% and Y% may be proportionately less than the additional water curtailment, for some productive water uses. This results in a relatively low level of output decline between points “b” and “c.”
However, beyond a Y% curtailment, the limited availability of water may have an increasingly significant impact on the ability (or willingness) of the firm to produce, resulting in Output
100%
0% X% Y% Z% % water
curtailment
100%
a
c
d
(5–10%)
b

3.86 Technical Memorandum November 14, 2022 A3
proportionately greater output impacts as less water is available. This is reflected where the output curve begins to decline more steeply at curtailments greater than Y%, as shown by the steeper slope between points “c” and “d.”
At some level of curtailment, Z%, the level of water supply reduction reaches a point where the firm is no longer able or willing to continue production. It may simply be physically impossible to operate their facility at water curtailment levels of Z% or greater, or it may no longer be economically viable to operate at production levels below what it is feasible to generate at Z%.

Or, it may become economically advantageous to relocate activities to another, more water abundant region (either temporarily or permanently). Thus, once a firm reaches point “d” in Figure A.1, output drops to zero (i.e., the local plant is shut down).

Naturally, the exact shape of the relationship shown in Figure A.1 will vary considerably across sectors, and even across entities within the same general business or industrial category.

However, the basic relationship is likely to be consistent across most CII entities. As water supply becomes less reliable, firms may be able to withstand initial small restrictions in water use with limited impacts on their levels of production, employment, and income. However, as curtailments increase in severity, it is increasingly likely that production will start to decline dramatically, and that at some level of water shortage, the facility may decide to shut down operations entirely. The value of water supply reliability to the firm, and to the greater community, will depend on the entity-specific shape of the generalized relationship depicted in Figure A.1.

Source: This graphic and associated discussion draws from Raucher et al. (2015).

3.87 Technical Memorandum November 14, 2022 B1
Appendix B: Business sectors and industries included in the analysis Table B1. Business sectors and industries included in the IMPLAN analysis Sector IMPLAN Industry
UCSC Junior colleges, colleges, universities, and professional schools Car Washes Car washes
Nursery, landscape, and garden
Greenhouse, nursery, and floriculture production
Landscape and horticultural services
Accommodation
Hotels and motels, including casino hotels
Other accommodations
Food Services and Drinking Places
Retail – Food and beverage stores
All other food and drinking places
Full-service restaurants
Limited-service restaurants
Amusement and Theme Parks Amusement parks and arcades
Golf Courses and Country Clubs Other amusement and recreation industries Fitness and Recreational Centers Fitness and recreational sports centers Food Manufacturing
Creamery butter manufacturing
Animal, except poultry, slaughtering
Seafood product preparation and packaging
Bread and bakery product, except frozen, manufacturing
Dry pasta, mixes, and dough manufacturing
Roasted nuts and peanut butter manufacturing
Coffee and tea manufacturing
Spice and extract manufacturing
North Coast Agriculture
Vegetable and melon farming
Fruit farming

3.88 Technical Memorandum November 14, 2022 B2
Table B1. Business sectors and industries included in the IMPLAN analysis Sector IMPLAN Industry
Breweries and distilleries
Breweries
Distilleries
Cement/concrete manufacturing
Cement manufacturing
Ready-mix concrete manufacturing
Tourism-supported retail
Retail – Food and beverage stores
Retail – Clothing and clothing accessories stores
Food manufacturing included in sensitivity
analysis
Dog and cat food manufacturing
Other animal food manufacturing
Nonchocolate confectionery manufacturing
Confectionery manufacturing from purchased chocolate
Frozen specialties manufacturing
Canned fruits and vegetables manufacturing
Frozen cakes and other pastries manufacturing
Meat processed from carcasses
Rendering and meat byproduct processing
Cookie and cracker manufacturing
All other food manufacturing
Computer included in sensitivity analysis Electronic computer manufacturing

3.89 Technical Memorandum November 14, 2022 C1
Appendix C: Sensitivity analysis
Table C1. Additional business sectors and industries included in the sensitivity analysis Sector IMPLAN Industry
Food manufacturing
Dog and cat food manufacturing
Other animal food manufacturing
Nonchocolate confectionery manufacturing
Confectionery manufacturing from purchased chocolate
Frozen specialties manufacturing
Canned fruits and vegetables manufacturing
Frozen cakes and other pastries manufacturing
Meat processed from carcasses
Rendering and meat byproduct processing
Cookie and cracker manufacturing
All other food manufacturing
Computer Electronic computer manufacturing
Table C2. Range of economic impacts of Stage 3 water curtailments with additional business sectors and industries: City impact only
Impact type Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs lost)
Selected industries $114.4 – $242.9 $53.8 – $109.1 $68.6 – $144.8 1,146 – 2,428 All industries identified
as potentially relevant $123.8 – $271.1 $55.2 – $113.4 $70.8 – $151.6 1,168 – 2,493 Difference $9.4 – $28.2 $1.4 – $4.3 $2.2 – $6.8 22 – 65

3.90 Technical Memorandum November 14, 2022 C2
Table C3. Range of economic impacts of Stage 4 water curtailments with additional business sectors and industries: City impact only
Impact type Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs lost)
Selected industries $324.3 – $505.3 $141.0 – $218.6 $192.2 – $299.3 3,236 – 5,066 All industries identified
as potentially relevant $369.2 – $576.3 $147.8 – $229.4 $202.9 – $316.2 3,344 – 5,237 Difference $44.9 – $71.0 $6.8 – $10.8 $10.7 – $16.9 108 – 171 Table C4. Range of economic impacts of Stage 5 water curtailments with additional business sectors and industries: City impact only
Impact type Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs lost)
Selected industries $578.5 – $789.9 $245.7 – $337.3 $341.6 – $467.8 5,752 – 7,902 All industries identified
as potentially relevant $668.3 – $909.9 $259.3 – $355.4 $363.0 – $496.7 5,967 – 8,185 Difference $89.8 – $120.0 $13.6 – $18.1 $21.4 – $28.9 215 – 283

3.91 Technical Memorandum November 14, 2022 D1
Appendix D: County-level results
Business
Table D1. Range of economic impacts of in-City Stage 3 water curtailments on included businesses, at the County-wide level
Impact
type
Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs lost)
Direct $104.3 – $220.9 $50.0 – $100.8 $62.7 – $132.1 1,088 – 2,302 Indirect $9.4 – $20.8 $3.5 – $7.8 $5.0 – $11.1 51 – 113 Induced $12.3 – $25.1 $3.9 – $8.1 $7.9 – $16.0 72 – 146 Total $126.1 – $266.8 $57.4 – $116.6 $75.6 – $159.3 1,211 – 2,561 Table D2. Range of economic impacts of in-City Stage 4 water curtailments on included businesses, at the County level
Impact
type
Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs lost)
Direct $294.6 – $458.8 $129.6 – $200.8 $175.0 – $272.4 3,067 – 4,802 Indirect $28.4 – $44.4 $10.8 – $16.8 $15.3 – $23.9 154 – 241 Induced $32.6 – $50.6 $10.5 – $16.2 $20.8 – $32.3 190 – 294 Total $355.5 – $553.8 $150.8 – $233.9 $211.0 – $328.6 3,411 – 5,337 Table D3. Range of economic impacts of in-City Stage 5 water curtailments on included businesses, at the County level
Impact
type
Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs lost)
Direct $524.9 – $716.6 $225.0 – $308.9 $310.5 – $425.3 5,448 – 7,484 Indirect $51.4 – $70.2 $19.6 – $26.8 $27.8 – $37.9 279 – 382 Induced $57.0 – $78.2 $18.3 – $25.1 $36.4 – $49.9 332 – 455 Total $633.3 – $865.0 $262.9 – $360.8 $374.6 – $513.2 6,058 – 8,322

3.92 Technical Memorandum November 14, 2022 D2
Residential
Table D4. Range of negative economic impacts (losses) of Stage 3 water curtailments on disposable household income at the County-wide level Metric Impact (losses)
Output lost $485,558
Labor income lost $173,006
Value added lost $319,392
Employment (# of jobs lost) 3
Tax revenues lost: City of Santa Cruz $11,958
Tax revenues lost: County $4,043
Tax revenues lost: State $17,548
Tax revenues lost: Federal $31,482
Table D5. Range of negative economic impacts (losses) of Stage 4 and 5 water curtailments on disposable household income at the County-wide level
Metric Impact (losses)
Output lost $1,655,497
Labor income lost $589,632
Value added lost $1,088,848
Employment (# of jobs lost) 10
Tax revenues lost: City of Santa Cruz $40,782
Tax revenues lost: County $13,789
Tax revenues lost: State $59,852
Tax revenues lost: Federal $107,320

3.93 Technical Memorandum November 14, 2022 E1
Appendix E: Sector-level results
Table E1. Range of negative economic impacts (losses) of Stage 3 water curtailments on included businesses by sector: City/Service Area.

Sector
Assumed
reduction
Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs
lost)
Tax revenues
lost: City of
Santa
Cruz*($M)
Nursery, landscape,
and garden 45% – 60% $53.6 – $71.4 $28 – $37.3 $32.5 – $43.4 506 – 675 $0.1 – $0.3 Food services and
drinking places 5% – 15% $29.7 – $89.1 $13.3 – $39.8 $18.8 – $56.5 330 – 990 $0.9 – $2.6 Food manufacturing 5% – 15% $5 – $15.1 $1 – $3 $1.5 – $4.5 23 – 69 $0.1 – $0.4 Breweries and
distilleries 5% – 15% $1.2 – $3.5 $0.1 – $0.4 $0.5 – $1.4 3 – 8 $0.1 – $0.3 Car washes 5% – 15% $1 – $2.9 $0.5 – $1.4 $0.7 – $2 6 – 19 $0.1 – $0.2 Cement/concrete
manufacturing 5% – 15% $1.1 – $3.4 $0.2 – $0.6 $0.4 – $1.1 3 – 8 $0 – $0.02 Accommodation 5% – 15% $4.2 – $12.6 $1.8 – $5.3 $2.6 – $7.9 37 – 112 $0.1 – $0.3 Amusement and
theme parks 5%-15% $2.9 – $8.8 $1.2 – $3.7 $1.9 – $5.7 37 – 111 $0.1 – $0.3 Fitness and
Recreational Centers 5%-15% $0.3 – $0.8 $0.1 – $0.3 $0.1 – $0.4 5 – 16 $0 – $0.01 Tourism-supported
retail 5%-15% $4.6 – $13.9 $1.9 – $5.6 $2.8 – $8.4 44 – 131 $0.2 – $0.7 UCSC 15% – 25% $4.3 – $7.2 $2.1 – $3.4 $2.8 – $4.6 64 – 107 $0.06 – $0.09 Golf courses 25%-35% $3.3 – $4.6 $1.7 – $2.4 $1.8 – $2.5 51 – 71 $0.04 – $0.07 North Coast
agriculture 5%-15% $3.2 – $9.6 $1.9 – $5.8 $2.1 – $6.3 37 – 110 $0.01 – $0.04 Total $114.4 – $242.9 $53.8 – $109.1 $68.6 – $144.8 1,146 – 2,428 $2.1 – $5.4 * Includes sub-county general and sub-county special districts (e.g., road maintenance, fire protection). 22 22 A complete list of the Santa Cruz Special Districts can be found at: https://www.co.santacruz.ca.us/Departments/AuditorControllerHome/CountySpecialDistricts/ListofSantaCruzCountySpecialDistricts.aspx

3.94 Technical Memorandum November 14, 2022 E2
Table E2. Range of negative economic impacts (losses) of Stage 4 water curtailments on included businesses by sector: City/Service Area.

Sector
Assumed
reduction
Output lost
($M)
Labor
income lost
($M)
Value added
lost ($M)
Employment
(# of jobs
lost)
Tax revenues
lost: City of
Santa
Cruz*($M)
Nursery, landscape,
and garden 45% – 60% $59.5 – $83.4 $31.1 – $43.6 $36.2 – $50.6 562 – 787 $0.4 – $0.5 Food services and
drinking places 5% – 15% $148.5 – $237.6 $66.3 – $106 $94.2 – $150.7 1,651 – 2,641 $4.3 – $6.8 Food manufacturing 5% – 15% $25.2 – $40.3 $5.1 – $8.1 $7.6 – $12.1 116 – 185 $0.6 – $1.0 Breweries and
distilleries 5% – 15% $5.8 – $9.3 $0.7 – $1 $2.3 – $3.7 13 – 21 $0.5 – $0.7 Car washes 5% – 15% $4.8 – $7.7 $2.3 – $3.7 $3.4 – $5.4 31 – 50 $0.3 – $0.4 Cement/concrete
manufacturing 5% – 15% $5.6 – $9 $1 – $1.6 $1.8 – $2.9 13 – 20 $0.03 – $0.06 Accommodation 5% – 15% $16.8 – $25.2 $7 – $10.5 $10.5 – $15.7 150 – 224 $0.4 – $0.5 Amusement and
theme parks 5%-15% $11.7 – $17.5 $5 – $7.5 $7.7 – $11.5 148 – 222 $0.4 – $0.6 Fitness and
Recreational Centers 5%-15% $1.1 – $1.7 $0.5 – $0.7 $0.6 – $0.8 21 – 32 $0.02 – $0.03 Tourism-supported
retail 5%-15% $18.5 – $27.8 $7.5 – $11.3 $11.2 – $16.7 175 – 262 $1.0 – $1.5 UCSC 15% – 25% $8.6 – $18.6 $4.1 – $8.9 $5.6 – $12 128 – 277 $0.1 – $0.2 Golf courses 25%-35% $5.3 – $8 $2.8 – $4.2 $2.9 – $4.3 82 – 122 $0.07 – $0.1 North Coast
agriculture 5%-15% $12.8 – $19.3 $7.8 – $11.6 $8.4 – $12.6 147 – 220 $0.06 – $0.1 Total $324.3 – $505.3 $141 – $218.6 $192.2 – $299.3 3,236 – 5,066 $8.0 – $12.7 * Includes sub-county general and sub-county special districts (e.g., road maintenance, fire protection). 23 23 Ibid.

3.95 Technical Memorandum November 14, 2022 E3
Table E3. Range of negative economic impacts (losses) of Stage 5 water curtailments on included businesses by sector: City/Service Area
Sector
Assumed
reduction
Output lost
($M)
Labor income
lost ($M)
Value added
lost ($M)
Employment
(# of jobs
lost)
Tax revenues
lost: City of
Santa
Cruz*($M)
Nursery, landscape,
and garden 45% – 60% $59.5 – $83.4 $31.1 – $43.6 $36.2 – $50.6 562 – 787 $0.7 – $1.1 Food services and
drinking places 5% – 15% $297 – $386.1 $132.5 – $172.3 $188.4 – $245 3,301 – 4,292 $8.5 – $11.1 Food manufacturing 5% – 15% $50.3 – $65.4 $10.1 – $13.1 $15.1 – $19.7 232 – 301 $1.2 – $1.6 Breweries and
distilleries 5% – 15% $11.6 – $15.1 $1.3 – $1.7 $4.7 – $6.1 27 – 35 $0.9 – $1.2 Car washes 5% – 15% $9.7 – $12.6 $4.6 – $6 $6.8 – $8.8 63 – 82 $0.6 – $0.7 Cement/concrete
manufacturing 5% – 15% $11.3 – $14.6 $2 – $2.6 $3.6 – $4.7 26 – 33 $0.06 – $0.09 Accommodation 5% – 15% $33.6 – $50.4 $14.1 – $21.1 $21 – $31.5 299 – 449 $0.7 – $1.1 Amusement and
theme parks 5%-15% $23.4 – $35.1 $9.9 – $14.9 $15.3 – $23 296 – 445 $0.9 – $1.3 Fitness and
Recreational Centers 5%-15% $2.2 – $3.4 $0.9 – $1.4 $1.1 – $1.7 43 – 64 $0.03 – $0.06 Tourism-supported
retail 5%-15% $37 – $55.5 $15 – $22.6 $22.3 – $33.5 350 – 525 $2.0 – $2.9 UCSC 15% – 25% $8.6 – $18.6 $4.1 – $8.9 $5.6 – $12 128 – 277 $0.1 – $0.2 Golf courses 25%-35% $8.6 – $11.3 $4.5 – $5.9 $4.7 – $6.1 133 – 173 $0.1 – $0.2 North Coast
agriculture 5%-15% $25.7 – $38.5 $15.5 – $23.3 $16.8 – $25.2 293 – 440 $0.1 – $0.2 Total $578.5 – $789.9 $245.7 – $337.3 $341.6 – $467.8 5,752 – 7,902 $15.5 – $21.1 * Includes sub-county general and sub-county special districts (e.g., road maintenance, fire protection). 24 24 Ibid.

3.96 1
Bonnie Bush
From: Jacquelyn Griffith <[email protected]>
Sent: Monday, November 28, 2022 12:00 PM
To: City Council
Subject: Agenda Item 3, "Securing Our Water Future..."
Dear City Councilmembers,
Please revise the goal of our new water provisioning plan to prioritize conservation of water and energy in the event of a five year drought. There is no point in continuing to fund studies of desalination or direct recycled sewage water. Instead, please prioritize “Aquifer Storage and Recovery”, injecting treated winter excess water into our aquifers.

Please also consider water conservation which has reduced our water use by 4 times what the proposed desalination plant would have produced. Businesses should be asked to make a water conservation plan to minimize the impact of less water use on local jobs.

Most CA governments curtail practices such as golf course irrigation during droughts as well and this plan to meet all customer demand in a 5 year drought is not the best plan.

Sincerely
Jacquelyn Griffith
Please revise the goal of our new water provisioning plan to prioritize conservation over this report's current stated goal of “an adequate supply to meet all customer demand" in the event of a five-year drought. Meeting all demands for water during a drought flies in the face of our water conservation ethic and of common sense; it would mean not curtailing, e.g., golf course irrigation during such a drought, contrary to the practices of most California local governments.

When considering new sources of water for Santa Cruz' future, please follow the Commission's guidelines and prioritize "Aquifer Storage and Recovery," or injecting water into the aquifer during the wet season, over other, much more expensive and energy intensive alternatives like desalination. Also consider another proven source of water supply for Santa Cruz: water conservation, which has reduced our water demand by 1.8 billion gallons since the desalination plant was proposed, 4 times the .45 billion gallons the desal plant would have provided.

Please consider asking businesses to cooperate in making a water conservationplan that will minimize the impacts of curtailing water use on sustaining and creating local jobs.

Overall, please make a plan for watering our community that will conserve both our water and our energy use, both of which are crucial to shaping our present and future sustainable community, and our livable world.

3.97 1
Bonnie Bush
From: Douglas Deitch <[email protected]>
Sent: Monday, November 28, 2022 11:29 AM
To: Padilla, Stephen@Coastal; Aminzadeh, Sara@Coastal; Zach Friend; 100-District 1 (831) 647-7991; 100-District 2 (831) 755-5022; 100-District 3 (831) 385-8333; 100-District 4 (831) 883-7570; 100- District 5 (831) 647-7755; Mark Primack; City Council; [email protected]; Bruce McPherson; [email protected]; [email protected]; [email protected]; Groom, Carole@Coastal; Turnbull-Sanders, Effie@Coastal; Luster, Tom@Coastal; Luce, Shelley@Coastal; [email protected]; Bradley Zeve; Steve Paolopoli; Ainsworth, John@Coastal; Sierra Ryan; Brownsey, Donne@Coastal; Greg Caput; Ryan Coonerty; Douglas Deitch; [email protected]; [email protected]; [email protected]; [email protected]; Howell, Erik@Coastal; [email protected]; [email protected]; [email protected]; Rice, Katie@Coastal; [email protected]; [email protected]; Sarah Easley Perez; Michael Turpin; Uranga, Roberto@Coastal; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Re: Public Comment on November 2022 Agenda Item Thursday 7a - Appeal No. A-3-MRA-19-0034 (California American Water Co., Marina)
Santa Cruz City Council Special Meeting 11/29/22: Re: Securing Our Water Future Resolution and Policy Guidance for Water Supply Augmentation to Improve Water Supply Reliability for Santa Cruz Water Service Customers (WT)
On Mon, Nov 14, 2022 at 2:46 PM Douglas Deitch <[email protected]> wrote:
(Please excuse if this is a repeated email to you )

3.98 2
MakeCaliforniaGreatAgain.democrat MakeCaliforniaGreatAgain.us MakeCaliforniaGreatAgain.net (Watch & Listen to Dr. Mount in 2014 on VICE Channel @ 5:41 @ sanfranciscorealestate.com telling us what damages even 1 foot of SLR will wreak in the Delta (and our local coastal aquifers here!) … @ https://twitter.com/DouglasDeitch/status/1374672809163550720 …

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Who is Dr. John Englander? …

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4 … and then listen,watch, and learn how that huge deep canyon in our bay was created?) *****
Sustainability, Rapid “SLR”, “ASR” or “DPR” H2O,
#NatureBasedSolutions, Our $5 billion+yr food production (10% of Cali’s $50 billion of total US $138 billion)?
Did we need either Cal Am or it’s coast front illegal slant welled desal plant in 2011 @ douglasdeitch.com
douglasdeitch.net
https://www.youtube.com/watch?v=ija6HUdPeY besameprimero.com then? … or now, any other/better alternatives, #nbs/nature based like mine run down in my comment right below and @
dougdeitch.com is or not?

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5 https://twitter.com/DouglasDeitch/status/1534167031377018881

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6 https://twitter.com/DouglasDeitch/status/1482497651098587136

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7 (April 29, 2016 LinkedIn article & Distributed documents in my hand…) Dear Coastal Commission, Governor Newsom, SWRCB, DWR,
Monterey and Santa Cruz County Supervisors and City of
Santa Cruz, et al…
The Monterey Bay Conservancy demands, for now the eighth time since the first on April 19, 2016 (@ 10:21) immediate SWRCB Emergency “Intervention” and takeover of all Monterey Bay Regional water management, sustainability planning and projects, and all other related control under direction of Governor Newsom’s Office.

Additionally, due to the recent shockingly high Monterey (and San Francisco ) Bay SLR Projections and the quickly approaching completed DPR (Direct Potable Reuse regs and, as I well over 2 and one half years ago advised the CCC @ 12:12),

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8 all “Pure Water” recycling “ASR/IPR” projects should be stopped and held in suspension until, due to DPR H2O which does not have to be injected and mixed in our coastal aquifers and can be used directly, all “ASR/IPR” injection will be abandoned and millions of dollars not imprudently spent on useless pipelines and other unneeded new infrastructure…
… particularly when 33000 acre feet of DPR H2O will be yearly available w/o any more “ASR/IPR” injection from the repurposed from Ag to Monterey Bay regional urban water needs of all our other humans and their activities and businesses here and best sustain and protect our $5 billion yearly food production here and so much more run down @ dougdeitch.com?

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9 https://twitter.com/DouglasDeitch/status/1577652083079008257

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10 https://twitter.com/DouglasDeitch/status/1482497651098587136

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11 https://twitter.com/DouglasDeitch/status/1587048714270429189

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12 Ourinconvenienttruth.org Ourinconvenienttruth.net Ourinconvenienttruth.com 2011 Desal @ CCC ?:

DouglasDeitch.com (douglasdeitch.net & https://www.youtube.com/watch?v=ija6HUdP-eY) 2010 besameprimero.com
Here’s Monterey Bay Conservancy’s 30 year old plus
#NatureBasedSolution (and 100% unconsidered and
DirectPotableReuse/”DPR” Recycled H2O) and best 33,000 acre feet/year new no shovel/build back better-Farmlands to wetlands infrastructure Monterey Bay Regional Urban Water Supply Alternative to best address Sea Level Rise, preserve and sustain us and our $5 billion year farm/food production, 90% water user …
And much, much more … ASAP
w/i 2 years by Governor Newsom’s Emergency Executive Order… after SWRCB “Intervention” in Monterey Bay Region …

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13 requested by Monterey Bay Conservancy continuously … Starting April 19, 2016 @
For a one time, “Show Me The Money” $2.5 billion (½ Federal/½ State) investment…

(i.e “OPM” @
https://twitter.com/DouglasDeitch/status/1417170870133399585) Run down @ dougdeitch.com & in the comment right below:

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14 Monterey County elected officials to debate a change in desal law

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15 https://twitter.com/DouglasDeitch/status/1534167031377018881 MakeCaliforniaGreatAgain.democrat

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16 https://twitter.com/DouglasDeitch/status/1374672809163550720

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17 Dear Chairman Esquivel & Ms. Bochco, et al @ SWRCB & California Coastal Commission,
(Please, for the now 8th time since 2016)…
INTERVENE NOW IN MONTEREY BAY @
thebestthatmoneycantbuy.org @ 11: 21 , 4/19/2016 !!!

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18 @It's past time for the State Water Resources Control Board to take control of our now predominantly below sea level Monterey Bay ground water commons
& @ dougforassembly.com
Does SqCWD have any water rights to do anything?

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19 lomejorqueeldineronopuedecomprar.com

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20 begentlewiththeearth.com (2005)
Query I: Our future water supply: Our most important
“Community” decision?
Query II: Will it be Desal, “ASR” (aquifer storage recovery with injection and later extraction)...
or 33000 a/ft/yr new Monterey Bay regional “DPR” (direct potable reuse) urban recycled H20 w/o any injection with 63000 a/ft/yr PERMANENT w/o EXTRACTION IN PERPETUITY passive strategic recharge through/and conservation (@ 3 afyr per acre) of #NatureBasedSolution ESHA 21000 acres of “farmlands back to wetlands”, the Monterey Bay Estuarine National Monument , like at Zmudowski Beach at 1992 43 acre Pilot Project Willoughby Ranch?

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21 https://twitter.com/DouglasDeitch/status/1482497651098587136/p hoto/4

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22 https://twitter.com/DouglasDeitch/status/1577652083079008257 @ dougdeitch.com (a fb page)
2020
“DPR vs “ASR”: All recycled water is not the same ?

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23 Please use your common sense and simple logic to understand why? Why?: The one foot of SLR will push into our and all coastside aquifers that are at or below sea level and force sea water and other pollutants into our still pristine for the most part local aquifers and pollute them too.

My 30+ year old ignored plan, the NATURE BASED SOLUTION/#nbs 21000 acre “Monterey Bay Estuarine National Monument”, including the repurposed to urban from ag 33000 acre feet/year of "DPR-Direct Potable Reuse" recycled water from the already but upgraded extant and online built in 1998 for $75 million Castroville Reclamation Plant, which also includes 63000 acre feet per year and then EVERY FOLLOWING YEAR IN PERPETUITY of permanent and not later extracted both strategically located and #nbs and passive Monterey Bay regional groundwater CONSERVATION and PERMANENT AQUIFER RECHARGE and 21000 NEW ACRES of new ”FARMLANDS BACK TO WETLANDS” (43 acre since 1995 Pilot Project @ Zmudowski Beach run down @ dougdeitch.com , a fb page, will solve all and best both sustain and preserve or increase our current $5 billion year (10% of Cali's total $50 billion year farm production of USA's total $136 billion!) and many other benefits for us here IN THE BIGGEST DROUGHT/FOOD/AIR/SAFETY/ALLLABSMATTER.INFO etc AND ALREADY SO MANY OTHER EMERGENCIES IN HUMAN HISTORY?, …
…for only a one time $2.1 billion build back better (one billion each State and Federal) infrastructure investment which will make us here in “our” (... fyi, one of my two “pronouns”) Monterey Bay Region where “we” all live (... fyi II, the second of my two “pronouns”)

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24 … “the global exemplar social economic and natural system for the rest of our planet to admire and emulate”, by Douglas Deitch (2007) www.begentlewiththeearth.com lomejorqueeldineroNOpuedecomprar.com ( a fb page)
“You can lead a horse or Governor Newsom, California Coastal Commission, SWRCB, DWR, “PUREWATER EVERYWHERE”, et al to “DPR” not “ASR” Recycled water and so much more (@
www.dougdeitch.com etc…) but you can't make them drink …” (That's why I am/was running for Congress to get us the $2.1 billion to fund this project WITH an immediate following emergency executive order from our Governor immediately authorizing, funding $ 1 billion for, and implementing my project, the 21000 acre “Monterey Bay Estuarine National Monument run down
@ https://twitter.com/DouglasDeitch/status/1482497651098587136 & www.dougdeitch.com for us/US ASAP !)
Problems solved!"

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25 @ 12:12 @ cal-span.org/meeting/ccc_20200312/ (2020)
& Repeating my CCC comment from 10 years ago, to the day, … “...made the Coastal Commission (et al) complicit … in the biggest environmental catastrophe, irremediable, in the history of the Monterey Bay Region. Please …”

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26 @ 3:25 @ besameprimero.com , March 11, 2010
(PLEASE NOTE: THIS March 11, 2010 CCC Meeting VIDEO,
APPARENTLY … @ https://cal-span.org/meeting/ccc_20100311/ …
HAS BEEN REMOVED, “LOST”, & REPLACED FROM OFFICIAL
CCC CAL_SPAN SITE along with video and other CCC records with an “Arana Gulch Field Trip” video !?
… just like the documents filed by me earlier w/ CCC @
begentlewiththeearth.org in 2009 and @ lawandorderliberal.net in 2016 for the matters therein referenced also mysteriously “DISAPPEARED”!? )

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27 2011
2011 “CalAm I Desal” CCC Hearing Comments of Douglas
Deitch and George Riley (@ 2:27:50)
“Water/Berry” (and now PureWaterMonterey & PureWaterSoquel) Ponzi Scheme?
Query/SqCWD: Does Soquel Creek Water District have any water rights? (Search @
https://ciwqs.waterboards.ca.gov/ciwqs/ewrims/EWServlet?Redir ect_Page=EWWaterRightPublicSearch.jsp&Purpose=getEWAppS earchPage )

1. Query/SqCWD: How much is “Pure Water Soquel” project now estimated to now cost , in total, and when is completion estimated?

2. Query/SqCWD: Does SqCWD need perfected and legal water rights? Why don’t they have them , if they don’t?

3. Is this a responsible and prudent business practice and a “safe harbor” manner of conducting business?

4. Query/”Pure Water” “ASR” Projects: After “DPR” is
approved, will injection of water cease and “DPR” recycled water be used directly instead?

5. Query: How did/does/will Pure Water Monterey project w/ expansion to 5+k/a/f/yr deal w/ account for new/increased since 2018 ag well pumping on 1800 acre Armstrong Ranch (@ 3 a/f/yr per acre +/- ) run down in MCWeekly’s Mr.

Schmaltz’ excellent 2018 article

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28 3.125
29 “We can’t print up any more
H20!”

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30 George Riley @ 2:27:50 @ https://calspan.org/meeting/ccc_20110812/

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31 https://cal-span.org/meeting/ccc_20200311/ @ 13:44
… (from CCC Meeting video of March 11, 2010 ten years ago, no longer to be found @ Cal-Span CCC site) !?
2019?
“Those who cannot remember (or never in the first place ever knew) the past …”?

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32 (“I was just up at the State Water Resources Control Board requesting they intervene in the Monterey Bay for the third time …” @ 29:02 @https://cal-span.org/meeting/ccc_20191113/ ) … are condemned to repeat it”?

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33 @ douglasdeitch.com (2011)
“November 12, 2019
Dear Ms. Bochco and CCC,
I am still waiting to hear or see one word of response from my invitation sent November 19, 2019 to you…?
(and also issued the same invitation to tour to SWRCB
Chair Esquivel, also ignored …

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34 https://twitter.com/DouglasDeitch/status/1482497651098587136/p hoto/3
Please respond.

Respectfully,
Douglas Deitch/Monterey Bay Conservancy” ….

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35 https://www.facebook.com/photo/?fbid=2705212229718138&set=p cb.2705216426384385
… to tour my alternative “Monterey Bay Regional Water Fixx aka “21000 acre Monterey Bay Estuarine National Monument”

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36 … which I have already run down for you in 2019 twice !? @5:15 cal-span.org/meeting/ccc_20191115/ & https://calspan.org/meeting/ccc_20191113/ and below & @ dougdeitch.com (fb page)

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37 SamFarr.info

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38 https://www.facebook.com/photo/?fbid=2705212923051402&set=p cb.2705216426384385

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39 sipodemos.democrat / thebestthatmoneycantbuy.com
CalAm I & Desal & Substance Abuse in 2011?

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40 @https://www.youtube.com/watch?v=ija6HUdP-eY & later@

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41 … “Water/Berry (&”Pure Water” Monterey&Soquel) Ponzi Scheme … We can’t “print up” any more water”! @ douglasdeitch.com & douglasdeitch.net

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42 3.139
43 https://twitter.com/DouglasDeitch/status/1424394937630527489

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44 https://www.youtube.com/watch?v=qRld8TH-KEs
begentlewiththeearth.org begentlewiththeearth.com
begentlewiththeearth.net ourinconvenienttruth.org
ourinconvenienttruth.net ourinconvenienttruth.com …
https://www.youtube.com/c/DouglasDeitch

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45 lawandorderliberal.net
"The mission of the Coastal Commission (CCC) is to: Protect, conserve, restore, and enhance environmental and human-based resources of the California coast and ocean for environmentally sustainable and prudent use by current and future generations… The CCC, Dr. Lester, and the late Dr. Douglas refused in 2009 and any time thereafter to this moment ... and here's what we here in Santa Cruz and the entire Monterey Bay ended up with instead, as I testified we would in 2010 ...
... The entire CCC was "complicit in the greatest environmental catastrophe (ie the tragic and permanent decimation and waste of our

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46 local coastal Monterey Bay ground water commons) in the history of the Monterey Bay"
... ( @ 1:54 “This is a food security problem…” @
https://www.youtube.com/watch?v=ccfaXnOF8ss )
https://twitter.com/DouglasDeitch/status/1374672809163550720

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47 (Doug talks desal w/ MZ & “Dr. Nano” on KSCO 5/19/2012 Sat. Special @ http://ksco.com/saturday-special-2/29670-2012-05-19mz-talksdesalination… … & “Our Inconvenient Truths” @ OurInconvenientTruth.com (2007) , OurInconvenientTruth.net (1999) , & OurInconvenientTruth.org 2009)

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1 Bonnie Bush
From: Douglas Deitch <[email protected]>
Sent: Monday, November 28, 2022 10:46 AM
To: Stephen@Coastal; Sara@Coastal; Zach Friend; 647-7991; 755-5022; 385-8333; 883-7570; 647-7755; Mark Primack; City Council; [email protected]; Bruce McPherson; [email protected]; [email protected]; [email protected]; Carole@Coastal; Effie@Coastal; Tom@Coastal; Shelley@Coastal; [email protected]; Bradley Zeve; Steve Paolopoli; John@Coastal; Sierra Ryan; Donne@Coastal; Greg Caput; Ryan Coonerty; Douglas Deitch; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Katie@Coastal; [email protected]; [email protected]; Sarah Easley Perez; Michael Turpin; Roberto@Coastal; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: Re: For City Council Meeting Tuesday, 11/29/2022 3. Securing Our Water Future Resolution and Policy Guidance for Water Supply Augmentation to Improve Water Supply Reliability for Santa Cruz Water Service Customers (WT)
whoops ......... http://makecaliforniagreatagain.democrat On Mon, Nov 28, 2022 at 10:41 AM Douglas Deitch <[email protected]> wrote:

Dear City Council,
Please add my "new" (to you) "Water Supply Augmentation Concept", the "DPR" 21000 acre "Monterey Bay Estuarine Monument" including 33,000 acre feet per year of recycled "DPR" water produced from the already extant and online "Castroville Reclamation Plant" repurposed from current ag use to regional Monterey Bay urban use, including and satisfying entirety of all Monterey and Santa Cruz Counties present and all future use and needs run down at page 933 of "Santa Cruz Water Rights Project" @
https://www.cityofsantacruz.com/home/showpublisheddocument/86973/637731697885370000 in 2021 and @ http://douglasdeitch.democrat , etc....

Be happy anytime to come and make a complete presentation to you.

Respectfully,
Douglas Deitch
Monterey Bay Conservancy
Aptos, Ca.
831.476.7662
http://makecaliforniagreatagain.demmocrat

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1 Bonnie Bush
From: Douglas Deitch <[email protected]>
Sent: Monday, November 28, 2022 10:42 AM
To: Stephen@Coastal; Sara@Coastal; Zach Friend; 647-7991; 755-5022; 385-8333; 883-7570; 647-7755; Mark Primack; City Council; [email protected]; Bruce McPherson; [email protected]; [email protected]; [email protected]; Carole@Coastal; Effie@Coastal; Tom@Coastal; Shelley@Coastal; [email protected]; Bradley Zeve; Steve Paolopoli; John@Coastal; Sierra Ryan; Donne@Coastal; Greg Caput; Ryan Coonerty; Douglas Deitch; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Katie@Coastal; [email protected]; [email protected]; Sarah Easley Perez; Michael Turpin; Roberto@Coastal; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: For City Council Meeting Tuesday, 11/29/2022 3. Securing Our Water Future Resolution and Policy Guidance for Water Supply Augmentation to Improve Water Supply Reliability for Santa Cruz Water Service Customers (WT)
Dear City Council,
Please add my "new" (to you) "Water Supply Augmentation Concept", the "DPR" 21000 acre "Monterey Bay Estuarine Monument" including 33,000 acre feet per year of recycled "DPR" water produced from the already extant and online "Castroville Reclamation Plant" repurposed from current ag use to regional Monterey Bay urban use, including and satisfying entirety of all Monterey and Santa Cruz Counties present and all future use and needs run down at page 933 of "Santa Cruz Water Rights Project" @
https://www.cityofsantacruz.com/home/showpublisheddocument/86973/637731697885370000 in 2021 and @ http://douglasdeitch.democrat , etc....

Be happy anytime to come and make a complete presentation to you.

Respectfully,
Douglas Deitch
Monterey Bay Conservancy
Aptos, Ca.
831.476.7662
http://makecaliforniagreatagain.demmocrat

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1 Bonnie Bush
From: linda murphy <[email protected]>
Sent: Sunday, November 27, 2022 8:18 PM
To: City Council
Subject: Water
Hello City Council,
I hope that you decide on options for water in Santa Cruz that do not include a desalinization plant. The electric energy it would need, coupled with the push for electric cars and all-electric homes, would be expensive, and overwhelming the grid. Additionally, our townspeople have shown a willingness to conserve water, reducing the demand over the years. The other options, including storing water in the aquifers, make a lot more sense and would be a solution more in keeping with our beautiful coastal city.

This is a brief note, but I did want to make my view known.

Thanks for reading this.

Sincerely,
Linda Murphy
Santa Cruz City Resident of 38+ years

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1 Bonnie Bush
From: Willow Katz <[email protected]>
Sent: Sunday, November 27, 2022 10:26 AM
To: City Council; Sonja Brunner; Bonnie Bush; Sandy Brown; Willow Katz Subject: Agenda Item 3, "Securing Our Water Future..." City Council Special Mtg, 11.29.2022 Agenda Item 3, "Securing Our Water Future..." City Council Special Mtg, 11.29.2022 Agenda Item 3, "Securing Our Water Future..." City Council Special Meeting, Nov. 29, 2022 City Council <[email protected]>
Sonja Brunner <[email protected]>
[email protected]
Sandy Brown <[email protected]>
Willow Katz <[email protected]>
SC City Council:

Please revise the goal of our new water provisioning plan to prioritize conservation over this report's current stated goal of “an adequate supply to meet all customer demand" in the event of a five-year drought. Meeting all demands for water during a drought flies in the face of our water conservation ethic and of common sense; it would mean not curtailing, e.g., golf course irrigation during such a drought, contrary to the practices of most California local governments.

Also consider another proven source of water supply for Santa Cruz: water conservation, which has reduced our water demand by 1.8 billion gallons since the desalination plant was proposed, 4 times the .45 billion gallons the desal plant would have provided.

Please consider asking businesses to cooperate in making a water conservation plan that will minimize the impacts of curtailing water use on sustaining and creating local jobs.

Thank you.

Sincerely,
Willow Katz
1230 Shaffer Rd #3103, Santa Cruz, CA 95060

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1 Bonnie Bush
From: Victor Aguiar <[email protected]>
Sent: Saturday, November 26, 2022 7:57 PM
To: City Council
Subject: RE Water Supply and Conservation
Dear Council -- As you make decisions concerning our water future, as you will attempt on Tuesday, I implore you to follow the guidance that Rick Longinotti offers in his published piece, which I've copied below. Aquifer Storage and Recovery stands as the most efficient and obvious first option for increasing supply, and thoughtful, aggressive conservation are always called for in the event of a drought. If any of you disagree, I'd really like to know why.

Thanks,
Victor Aguiar
Baldwin Street
Dear Friends,
Right now is a moment for the community to weigh in on future water policy for the City of Santa Cruz.

On Tuesday, the Santa Cruz City Council will set a goal for water supply reliability during worst‐case conditions. I think the proposed goal is problematic.

A 5‐year drought was chosen as the model worst‐case. The proposed goal is “an adequate supply to meet all customer demand” [emphasis added] This goal is a departure from previous policy. The plan for desalination plant proposed 15% curtailment of water use in a worst‐case drought scenario. The current proposal envisions no curtailment of irrigation for residential or commercial customers. Irrigation makes up a quarter of the City’s peak season water use.

If the goal to meet all customer demand were actually met, Santa Cruz would be a water oasis during a 5‐year drought afflicting California. Delaveaga and Pasatiempo golf courses would have the only green fairways in the state. Is this what we really want? Won't that erode the exemplary conservation ethic of Santa Cruz residents? An under‐appreciated fact is that our conservation ethic, combined with water‐efficient fixtures, have provided water security far better than a desalination plant. The desal plant was supposed to provide .45 billion gallons during a drought year. Conservation has reduced our normal water demand by 1.8 billion gallons since the desal plant was conceived.

That's four desal plants.

The goal of zero curtailment during a worst‐case drought is at odds with one of the guiding principles that the Council is being asked to adopt: Affordability and Equitable Access to Water Service. Customers of all income levels are going to be asked to pay for expensive projects. If the goal is no curtailment, perhaps the question should be, “Shouldn’t those who don’t want to cut back on irrigation or long showers shoulder the cost of implementing the goal of zero curtailment?”

The zero curtailment goal results from concern about the local economy. According to the study in the Council’s agenda packet, a Stage 3 curtailment is estimated to result in a loss of 1,149 – 2,431 jobs.

Wow, such a high job loss expected from a mere 15% cutback in water for businesses at Stage 3! That suggests to me that it’s time to study community resilience. The Water Department’s concepts for engineering our way to water security are marvels of ingenuity, but expensive and energy intensive. But what if we built in community resilience to our preparation for worst‐case events? What if businesses had a plan for how to cope with a 15% curtailment with a

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2 minimum of hurt to the bottom line? What if we drew on the community spirit that supported businesses after the 1989 earthquake? For example, we might find that residential customers would be willing to cut back more than expected in order to preserve jobs.

This kind of community spirit depends on trust in local government. I experience the Water Department under Rosemary Menard as a model of transparency and community engagement. (It’s a model for City officials who propose a new downtown parking garage but did not bring before the Council the Nelson\Nygaard report that recommends alternatives to a garage.)

Also in the Council’s agenda packet is a sample of water supply projects that the City could pursue if and when they are needed. Choosing among these and other options will take place within two years. With the current analysis it is already clear which options are superior according to the criteria proposed by the Water Commission that includes cost, yield, energy use, and operational complexity.

The era of cheap energy is ending. If the future is to be free of fossil fuel burning, we don’t want to saddle future generations with energy‐intensive projects. That rules out desalination, since the analysis reports it is 8 times as energy intensive and 18 times the annual energy use as injecting water into the aquifer during the wet season (Aquifer Storage and Recovery). Direct potable reuse (recycled wastewater) is not yet legal in California and public acceptance is a questionable due to health concerns. It also is energy intensive. A reverse osmosis plant for desalination or recycled water would operate 365 days a year‐‐‐even when it’s pouring rain‐‐‐boosting the annual energy use of those projects.

The Aquifer Storage and Recovery option is considerably less costly to build and operate than desalination or recycled water. That’s important for future generations too.

It’s not too soon to let the City Council know the community preference among these options. Write [email protected].

Happy Holidays,
Rick Longinotti
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1 Bonnie Bush
From: jarwoodsc Wood <[email protected]>
Sent: Saturday, November 26, 2022 11:53 AM
To: City Council; jarwoodsc Wood
Subject: Aquifer Storage Recovery
Dear City Council,
I urge you to support the Aquifer Storage Recovery option and stricter water conservation measures for Santa Cruz and NOT building a costly, environmentally dangerous De‐desalination plant. Conservation efforts have been working and more serious conservation efforts need to be undertaken in the City, County and State.

Please do everything you can to create water conversation measures and NOT a Desal plant! Sincerely,
Joy D. Wood
219 Merced Avenue
Santa Cruz, CA 95060
Get Outlook for iOS

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1 Bonnie Bush
From: Russell Brutsche <[email protected]>
Sent: Saturday, November 26, 2022 10:51 AM
To: City Council
Subject: aquifer storage
Hi City council,
The concept of zero water curtailment is part of a naive, forever-expanding Ponzi-scheme approach to living in harmony with our natural resources. Please support the Aquifer Storage and Recovery plan for our county.

Thank you
Russell Brutsché

3.153
1 Bonnie Bush
From: Douglas M Thomson Sr. <[email protected]> Sent: Saturday, November 26, 2022 9:38 AM
To: City Council
Subject: California Closed Loop Water Pipeline System
I propose that we conduct a study to determine the feasibility of creating a Statewide Closed Loop Water Pipeline System. (CLWPS)
The idea is to connect to the States major water supplies from existing lakes, streams, rain water and other natural resources including storm drain water where the water resources are located.

Waste water from local properties connected to existing sewer systems that are in place now, will continue to deliver wastewater to our treatment facilities.

From there current locations, the untreated water is pumped to and then connected to the States CLWPS pipeline. The CLWPS pipeline will then connect to every major water treatment facility in the State.

During drought years water can be delivered to areas within the State that are in need of water. Every County and other smaller Water Districts already have treatment plants in place to treat the water provided to them.

When water is not available to them from local sources, the States CLWPS will deliver water to the treatment facility as needed. Any remaining water contained in the system can be deposited back into our Aquafers, Reservoirs, Lakes and other Holding Facilities where water is needed.

The initial cost to create the CLWPS pipeline is an investment in our future water supply needs. I believe that a CLWPS can be installed relatively fast saving billions in the process.

Once we have made the initial investment to install the CLWPS pipelines, our State can shift its resources to improve or build new treatment plants using water from the closed loop system.

Another study should be conducted to see if newly installed engineered septic systems could be connected to a 7 stage water filtration system where it can be recycled back into the residents water supply rather then into leach fields.

Water from Engineered septic systems can be pumped offsite using a two inch schedule 40 PVC Pipe where it can connect to existing county water sewer lines located along our roads.

Where water is being provided from a local source a second 2 or 4 inch pressurized sewer line could be install beneath the water main where septic system water can be pumped back to the treatment plant under pressure.

Some properties use well water that is then connected to water treatment systems before human use.

This water if not connected the sewer system is delivered to septic system after use.

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2 The State could require that water from a well be treated to the States Drinking Water Standards.

Waste water from well or public water source must be treated using an engineered septic system where it is either pumped to a local sewer system or an approved leach field Once the State has satisfied its own water supply requirements, any surplus could be sold to neighboring States where water is needed.

Very Respectfully,
Douglas M. Thomson Sr.

Retired Distinguished Naval Veteran

3.155
1 Bonnie Bush
From: Christine Kirven <[email protected]>
Sent: Saturday, November 26, 2022 9:12 AM
To: City Council
Subject: Water Security Goal-Looking at the proposed goal for a 5 year drought/worst case scenario Dear Council,
Thanks to a timely letter from Rick Longinotti, I see that the proposal before you Tuesday suggests that meeting “all customer demand” during a big drought, is a proper goal. It’s the “all” that is being scrutinized by those of us who really thought the desalination plant idea was off course so long ago. In fact conservation has yielded much more water than the plant was proposed to provide.

Jobs would be lost if “all” demand were not met. Jobs are going to be lost for all sorts of reasons in the coming years. Do any of these jobs actually pay enough to pay rent in Santa Cruz? Rick argues that resilience is in order on this score but really I think resilience is a goal all the time, not just for a particular drought. More people want to live here all the time and wealthy retirees and remote workers are pouring in all the time. “All” demand flies in the face of real limits that we all have to accept. There is a plaintive voice from our children, “We were born here and can’t stay!” Well, we the parents were, on the whole, not born here and there is no guarantee anyone but very wealthy or lucky folks can stay. “Help Wanted” is everywhere for low paying jobs. Are we talking golf course maintenance and landscaping workers? Glass washers at the restaurants? Nothing is an excuse for building energy intensive infrastructure at this point. Nothing.

Sincerely, Christy Kirven
Santa Cruz

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1 Bonnie Bush
From: sheila carrillo <[email protected]>
Sent: Saturday, November 26, 2022 7:15 AM
To: City Council
Subject: Base Water future of Santa Cruz on community resilience Dear Council.

In considering our water future, please work from the standpoint of building community resilience. We have cut back our water usage respectfully before and can do so even more efficiently in the future. Building systems that require a lot of money and increased energy usage are backward thinking.

Initiate climate wise, forward thinking water policy!
And DON’T MOVE FORWARD WITH A 228 ROOM LUXURY HOTEL WITH 2 POOLS AND A SPA when it is a time to conserve water!!!!

3.157
1 Bonnie Bush
From: Carol Long <[email protected]>
Sent: Friday, November 25, 2022 9:50 PM
To: City Council
Subject: Agenda Item 3, "Securing Our Water Future..." City Council Special Meeting, Nov. 29, 2022 Please revise the goal of our new water provisioning plan to prioritize conservation over this report's current stated goal of “an adequate supply to meet all customer demand" in the event of a five-year drought. Meeting all demands for water during a drought flies in the face of our water conservation ethic and of common sense; it would mean not curtailing, e.g., golf course irrigation during such a drought, contrary to the practices of most California local governments.

Please consider asking businesses to cooperate in making a water conservation plan that will minimize the impacts of curtailing water use on sustaining and creating local jobs.

Thank you.

Carol Long
Finally

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1 Bonnie Bush
From: Sandra L. Cohen <[email protected]>
Sent: Friday, November 25, 2022 5:57 PM
To: City Council
Subject: Desal? Seriously?
Dear Mayor and City Council…..I am writing in dismay about the current talk I’m hearing about a return to the desal issue in order to supply ALL the water Santa Cruz needs. Why have we been conserving all these years? To have you now turn your back on conservation? Surely businesses can manage on 15% less water!
The Aquifer Storage and Recovery option is considerably less costly to build and operate than desalination or recycled water. That’s important for future generations too.

Please do not abandon the Aquifer Storage and Recovery Option as the best choice going forward.

Thank you.

Sandra Cohen
172 Peach Terrace
Santa Cruz

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1 Bonnie Bush
From: Barbara Riverwoman <[email protected]>
Sent: Friday, November 25, 2022 5:00 PM
To: City Council
Subject: Water proposal
Dear City Council Members,
I think we have all learned a lot as we have navigated the rapids of Measure O. One of the pieces that I hope we have all learned is how important authentic community dialogue is, especially at the early stages before staff planning for a project has gone so far that the main argument in its favor is that is has already gone too far to stop - no matter how problematic it is financially and environmentally. And no matter how much better environmentally the alternative would have been in solving the very problems it had hoped to address, i.e. parking.

The new City water proposal under consideration by the Council on Tuesday again sounds very short sighted from an environmental perspective.. I hope you make every effort to explore the feasibility of the environmentally far less damaging alternative of Aquifer Storage and Recovery. This option needs to be fully understood and explored before any commitment to other plans are adopted.

This time around can Santa Cruz lead on environmental ethics, rather than resist? Let’s do it right this time.

Thank you.

Barbara Riverwoman

3.160
1 Bonnie Bush
From: Dell Elliott <[email protected]>
Sent: Friday, November 25, 2022 11:07 AM
To: City Council
Cc: Rick Longinotti
Subject: WSAC
We had a system trade study conducted by the WSAC with agreed upon solutions. It appears this system trade study is being ignored.

A J Elliott
418 Walnut Ave
831 458 6487

3.161
1 Bonnie Bush
From: fred geiger <[email protected]>
Sent: Friday, November 25, 2022 10:55 AM
To: City Council
Subject: Water supply
The only reasonable - and affordable - means of securing our water needs is Acquifer Storage and Recharge.

Please keep this in mind and do not accept expensive and environmentally damaging choices Fred J. Geiger Santa Cruz Ca

3.162
1 Rosemary Balsley
From: Joan Timpany <[email protected]>
Sent: Monday, November 28, 2022 2:58 PM
To: City Council
Subject: Strategies for Water Security
Dear Mayor Brunner and SC City Council members,
Having seen so many of the ideas and strategies
while WSAC met, I feel we need to adopt the
compelling and best strategy of Aquifer Storage &
Recovery. Santa Cruz has shown that it's capable
of conserving and it's important to continue that
practice for future generations as well as now.

Avoid Desalination Plant at all costs ‐ it's an environ‐ mental disaster and the most expensive way to pro‐
duce water.

Select Aquifer Storage and Recovery as the preferred
strategy.

Sincerely,
Joan Timpany
Santa Cruz

3.163
1 Rosemary Balsley
From: Daniel Spelce <[email protected]>
Sent: Tuesday, November 29, 2022 1:40 AM
To: City Council
Subject: Support Water Conservation & Aquifer Storage
Dear members of the City Council,
As the human presence in Santa Cruz, California, and throughout the world continues growing ever more dense, imposing ever intensifying demands on ecosystems everywhere on the planet, including locally, please plan for the water implications of the human presence by rallying enthusiasm for water conservation and investing in infrastructure for aquifer storage and recovery.

Blithely investing in energy intensive, habitat disrupting measures, such as one or more desalination plants, hasten collapse of the planet’s ecosystems. No collection of industrial magic wands will abate the ecological challenges spawned by people's frenetic vigor of incessant activities outpacing human endeavors to ameliorate the rapid deterioration of the living systems essential to our well‐being, let alone minimal requisites for survival.

As evidenced by recent statements from the climate science community, humanity already surpassed its opportunity to moderate the consequences of our contamination of the biosphere—a biosphere that Santa Cruz relies integrally upon as a living tissue, part of a larger body whole. I urge you to embrace the imperative to plan our water future around water conservation and restoring the depleted aquifers beneath us.

Sincerely,
Daniel Spelce
Santa Cruz, California

3.164
1 Rosemary Balsley
From: Douglas Deitch <[email protected]>
Sent: Tuesday, November 29, 2022 3:46 AM
To: Stephen@Coastal; Sara@Coastal; Zach Friend; 755-5022; 385-8333; 883-7570; 647-7755; Mark Primack; City Council; [email protected]; Bruce McPherson; [email protected]; [email protected]; [email protected]; Carole@Coastal; Effie@Coastal; Tom@Coastal; Shelley@Coastal; [email protected]; Bradley Zeve; Steve Paolopoli; John@Coastal; Sierra Ryan; Donne@Coastal; Greg Caput; Ryan Coonerty; Douglas Deitch; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected];
[email protected]; Katie@Coastal;
[email protected]; [email protected]; Sarah Easley Perez; Michael Turpin; Roberto@Coastal; [email protected]; [email protected]; Alexander Henson; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; 100-District 1 (831) 647-7991 Subject: Fwd: FW: For City Council Meeting Tuesday, 11/29/2022 3. Securing Our Water Future Resolution and Policy Guidance for Water Supply Augmentation to Improve Water Supply Reliability for Santa Cruz Water Service Customers (WT) ---------- Forwarded message ---------
From: Douglas Deitch <[email protected]>
Date: Mon, Nov 28, 2022 at 7:24 PM
Subject: Re: FW: For City Council Meeting Tuesday, 11/29/2022 3. Securing Our Water Future Resolution and Policy Guidance for Water Supply Augmentation to Improve Water Supply Reliability for Santa Cruz Water Service Customers (WT)
To: 100-District 5 (831) 647-7755 <[email protected]> Cc: Hardgrave, Sarah <[email protected]>, Courtney, Colleen <[email protected]> Dear Supervisor Chair Adams,
When may we either meet in person or converse by phone @ 831.476.7662 to allow me opportunity, more than 2 minutes I hope, to fully explain my projects and approach ...living within our means, water and otherwise, and respond to your questions and any other concerns or suggestions or criticism, etc.? Respectfully,
Douglas Deitch
Monterey Bay Conservancy
Aptos, Ca.

On Mon, Nov 28, 2022 at 10:45 AM 100-District 5 (831) 647-7755 <[email protected]> wrote:

Mr. Deitch: Received by District 5---thank you.

3.165
2 Susan Moore
Executive Assistant to Supervisor Mary L. Adams
Scheduler & Office Manager for District 5
County of Monterey, District 5
1200 Aguajito Road, Suite #1
Monterey, CA 93940
Phone: 831-647-7755
Please consider the environment before printing this e-mail.

Please note: If a matter is to be heard at an upcoming Board of Supervisors’ meeting and you are sending an e-mail either the night before or the day of that meeting, please do not send correspondence to our office only as we may not see it prior to the BOS meeting. Instead, please send your e-mail to the Clerk of the Board at: [email protected] The Clerk will distribute your e-mail in a timely manner to all Monterey County Supervisors, their staff and other County employees associated with the matter. Thank you for your cooperation.

The Board of Supervisors’ agenda(s) and agenda packet(s) can be found online by visiting the following link:
https://monterey.legistar.com/Calendar.aspx
Public Works Road Traffic Advisories, Closures & Information:
https://www.co.monterey.ca.us/government/departments-i-z/public-works-facilities-parks/public-works/roadclosures-information The short term rental hotline offers two reporting options: by telephone at (831) 900-4441 or by submitting an online form at https://hostcompliance.com/tips

County Housing & Community Development has set up a Noise Complaint Hotline. To reach a Code Compliance Officer, please call 831-755-5177 on Fridays and Saturdays between the hours of noon and 10:00 p.m. When the hotline is not active, a caller may leave a voicemail message.

3.166
3 COVID vaccination sites: https://www.montereycountyvaccines.com/ Connect with Mary Adams:
 on Facebook
 via E-Newsletter
From: Douglas Deitch <[email protected]>
Sent: Monday, November 28, 2022 10:42 AM
To: Stephen@Coastal <[email protected]>; Sara@Coastal <[email protected]>; Zach Friend <[email protected]>; 100-District 1 (831) 647-7991 <[email protected]>; 100-District 2 (831) 755-5022 <[email protected]>; 100-District 3 (831) 385-8333 <[email protected]>; 100-District 4 (831) 883-7570 <[email protected]>; 100-District 5 (831) 647-7755 <[email protected]>; Mark Primack <[email protected]>; City Council <[email protected]>; [email protected]; Bruce McPherson <[email protected]>; [email protected]; [email protected]; [email protected]; Carole@Coastal <[email protected]>; Effie@Coastal <[email protected]>; Tom@Coastal <[email protected]>; Shelley@Coastal <[email protected]>; [email protected]; Bradley Zeve <[email protected]>; Steve Paolopoli <[email protected]>; John@Coastal <[email protected]>; Sierra Ryan <[email protected]>; Donne@Coastal <[email protected]>; Greg Caput <[email protected]>; Ryan Coonerty <[email protected]>; Douglas Deitch <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Katie@Coastal <[email protected]>; [email protected]; [email protected]; Sarah Easley Perez <[email protected]>; Michael Turpin <[email protected]>; Roberto@Coastal <[email protected]>; [email protected]; [email protected]; Alexander Henson <[email protected]>; [email protected]; [email protected]; [email protected]
Subject: For City Council Meeting Tuesday, 11/29/2022 3. Securing Our Water Future Resolution and Policy Guidance for Water Supply Augmentation to Improve Water Supply Reliability for Santa Cruz Water Service Customers (WT)

[CAUTION: This email originated from outside of the County. Do not click links or open attachments unless you recognize the sender and know the content is safe. ]
Dear City Council,

3.167
4 Please add my "new" (to you) "Water Supply Augmentation Concept", the "DPR" 21000 acre "Monterey Bay Estuarine Monument" including 33,000 acre feet per year of recycled "DPR" water produced from the already extant and online "Castroville Reclamation Plant" repurposed from current ag use to regional Monterey Bay urban use, including and satisfying entirety of all Monterey and Santa Cruz Counties present and all future use and needs run down at page 933 of "Santa Cruz Water Rights Project" @ https://www.cityofsantacruz.com/home/showpublisheddocument/86973/637731697885370000 in 2021 and @ http://douglasdeitch.democrat , etc....

Be happy anytime to come and make a complete presentation to you.

Respectfully,
Douglas Deitch
Monterey Bay Conservancy
Aptos, Ca.
831.476.7662
http://makecaliforniagreatagain.demmocrat

3.168
1 Rosemary Balsley
From: Mark Mesiti-Miller <[email protected]>
Sent: Tuesday, November 29, 2022 9:04 AM
To: Sonja Brunner; Martine Watkins; Sandy Brown; Justin Cummings; Renee Golder; Shebreh Kalantari-Johnson; Donna Meyers
Cc: City Council
Subject: 11/29 Agenda Item 3 - Support for “Securing Our Water Future Resolution and Policy Guidance for Water Supply Augmentation to Improve Water Supply Reliability for Santa Cruz Water Service Customers (WT) for Water Supply Policy” Dear Mayor Brunner and City Councilmembers:

An 18-month, million dollar process overseen by the fourteen members of the Water Supply Advisory Committee, established a clearly defined process for assuring a reliable and adequate source of water for the quality of life and economic needs of the City of Santa Cruz without depleting or minimizing the needs of the aquatic habitat that shares this invaluable resource.

The staff of the Water Department, charged with implementing the plan, has put forth a well supported and documented policy framework to complete that work and secure our water future.

Please do not make the mistake of now diminishing that plan by minimizing the scope of the system needed, or altering the process at this late hour. Current and future residents as well as businesses, have a reasonable expectation the City’s Water Department will continue planning for and constructing a system will fully meet future needs.

I urge you to adopt the staff’s recommendations and move us all toward a secure and resilient water supply.

Thank you,
Mark Mesiti-Miller
Water Supply Advisory Committee Member
CA Professional Civil Engineer
39 year resident of the City of Santa Cruz

3.169
1 SECURING OUR WATER
FUTURE

3.170

SECURING OUR WATER FUTURE
• Purpose: Create a sound, community
supported, adaptive policy framework for
improving the reliability and resiliency of
Santa Cruz’s water supply.
 Develop policy direction related to water supply
reliability, and phased water supply
augmentation project implementation; and
 Provide durable policy level direction for staff
to use in ongoing efforts to improve water
supply reliability

3.171 2
Presentation Overview

1. Key take aways from technical work
completed as part of the policy
development;

2. Summary of policy development process;

3. Summary of resolution and policy
elements;

4. Presentation on the economic impact
analysis of water curtailments as a
drought response tool.

5. Summary existing policy that is being
replaced and new policy.

3.172 3

1. KEY TAKE AWAYS FROM

TECHNICAL WORK COMPLETED

AS PART OF THE POLICY

DEVELOPMENT
4 3.173
A. Water supply planning is inherently uncertain and
climate change is increasing this uncertainty.

B. Robust climate modeling has been completed as
part of the work of developing the Securing Our
Water Future work and the projected increased
instances of longer periods of dry conditions add
significantly to the system’s vulnerability
resulting from limited storage.

C. Curtailment of demand as a drought response
tool in Santa Cruz has limited applicability due to
the community’s existing highly efficient water
use practices.

3.174 5
D. We have viable, technically feasible options to
resolve our water supply reliability problems.

Those options have been evaluated and
compared in a side-by-side analysis as
recommended by the WSAC.

E. None of the options are “low cost” or even “low
impact” with respect to energy intensity, for
example.

F. The “do nothing” or “use curtailments as a
drought response tool” options aren’t “low cost”
or “low impact” either .

3.175 6

2. 2022 SECURING OUR WATER

FUTURE DEVELOPMENT

PROCESS
7 3.176
A. Completed a “side-by-side” comparison of
alternatives called for in the WSAC’s
recommendations;
B. Explored the existing water supply reliability by
stress-testing the system with over 8,000 plausible
climate change scenarios to assess its vulnerability;
C. Evaluated how supply augmentation project
concepts would reduce supply deficits under
drought conditions;
D. Developed comprehensive and data-driven policy
direction for securing our water future through an
active and transparent public engagement process
beginning in the spring of 2022; and
E. Developed durable policy level direction for staff to use in the phased implementation of projects to
address Santa Cruz’s long standing water supply
reliability issues.

3.177 8
As part of this work,
Water Commissioners:
• Received, discussed and provided detailed
feedback on everything from:
– The evaluation criteria to be used with the side-by-side evaluation of project concepts, to
– Selection of project concepts to consider, to
– Trends in local historic hydrology and how those trends may evolve under climate change conditions, to
– Results of stress-testing the water system, to
– Supply modeling results for the augmentation project
concepts, to
– Economic impact analyses of water supply curtailments as a form of responding to drought conditions, to
– Resolution and policy language as it evolved over several meetings as a result of input received.

3.178 9

3. SECURING OUR WATER FUTURE

POLICY ELEMENTS
10 3.179
Policy Elements
A. Recitals: tell the story of where we are and how we
got here.

B. Findings: summarize what we know about our
situation and what it’s going to take to improve it.

C. Reliability Goal: gives us a clear, data-driven target that is purposefully designed to be updated over time.

D. Resource Portfolio: lists our sources of supply that are the raw materials of any additional supply
projects.

E. Criteria: reflect important community values and
priorities and establishes them as policy; and
F. Implementation Guidance: provides transparency
about how the policy will be implemented and what
actions are contemplated.

3.180 11
A. Recitals
• The issue of water supply reliability has a
long history in Santa Cruz.
• The recitals tell the story of recent history
of the challenges and complexities, and
failures and successes involved in water
supply planning, and
• The recitals provide an overview of the
recent work completed in the development
of the recommended Securing Our Water
Future Policy.

3.181 12
B. Statement of Findings
• The recommended Securing Our Water
Future Policy includes 13 findings that
articulate the community’s values and
priorities for how we plan for and manage
our natural resources and critical water
infrastructure and summarize key results
of analytical work completed as part of the
policy development process.
• Some findings of note include:

3.182 13
• Santa Cruz water service customers have
embraced water use efficiency to the
degree that its residential users have one
of the lowest levels of water use in the
state.
• Highly efficient water use means that there
is little discretionary water use to cut
should demand curtailments be required
during droughts. This reality significantly
limits the use of curtailment as a drought
response tool.

3.183 14
• Analysis of historic temperature and precipitation
data indicate that Santa Cruz is already
experiencing increased weather variability
resulting in wetter wet periods and longer and
drier dry periods.
• Increasing weather variability is the key driver
of sizing supply augmentation projects.
• Water demand growth associated with
increased population and housing, including
that associated with UCSC’s Long Range
Development Plan only marginally increases
projected over the next 25 years is projected
supply deficits

3.184 15
C. Water Supply Reliability Goal
• We need a Water Supply Reliability to:
– Guide the sizing of water supply
augmentation solutions for implementation;
– Help us determine the amount of risk of a
shortage we want to be exposed to against
the cost of the solutions; and
– Provide clarity about what steps we need to
take to respond to the supply shortages we
don’t plan projects to address.

3.185 16
Our Recommended Supply
Reliability Goal Is:
• Based on a data-driven analysis of water
supply vulnerability and an evaluation of
the size and probability of shortages that
could result from worst case conditions;
• Purposefully designed to be reviewed and
adapted as our understanding of climate
change and climate variability evolves over
time;
• Does not include the routine use of supply
curtailments as a drought response tool.

3.186 17
The Initial Climate Scenario Selected
for Use Water Supply Planning:
• Was selected from a range of plausible,
moderate options and assumes no change in
precipitation, a 2º C increase in temperature,
and a 10% increase in weather variability.
• Under the year worst-case drought conditions,
available storage is used up in the first 2 of
the 5-year sequence leaving a 3-year deficit of

2.2 billion gallons.
• Without supply augmentation, Stage 5+
curtailments (>50% reduction) would be
required for final 3 years of the drought.

3.187 18
D. Water Supply Portfolio
• Reflects the fact that our supply
development options are limited to what is
available locally, including surface and
groundwater water, recycled wastewater
and seawater; and
• Acknowledges that technically feasible
supply augmentation solutions exist for all
these sources and that, given our
vulnerability, it is important to keep all
options on the table.

3.188 19
E. Considerations in Developing
Water Supply Augmentation Project(s)
• This comprehensive list of Guiding
Principles, Primary Evaluation Criteria, and
Additional Considerations:
– Incorporates and builds on values, priorities,
and criteria developed by the WSAC; and
– Provides transparency and sets expectations on
the approach to be taken and the information
to be developed and considered in the process
selecting and incrementally implementing
supply augmentation projects.

3.189 20
• Includes a new policy statement on
Affordability and Equitable Access to
Water Service that reflects the City’s Health
in All Policy commitment;
• Sets a near-term goal under the Timeliness
Metric (4.2.3) of increasing supply by at
least 500 million gallons by 2027 as a
means of adding resiliency to the system
while work other projects that may have a
longer timeline for development occurs.

3.190 21
E. Policy Implementation Guidance
• The Policy Implementation Guidance is
designed to:
– Translate policy into action and make it clear to
policy makers and City staff what actions are
contemplated;
– Particularly want to emphasize the commitment
to exploring and pursuing partnerships with
other regional water providers also seeking to
increase water supply reliability and/or address
groundwater sustainability issues.

3.191 22

4. ECONOMIC IMPACT ANALYSIS

OF SIGNIFICANT DEMAND

CURTAILMENTS
23 3.192
• This analysis helps answer the inevitable
and always appropriate “compared to
what?” question associated with not
addressing supply reliability issues.
• Dr. Bob Raucher, an expert in water sector
economics with more than 35 years of
experience, include active work with Santa
Cruz through the WSAC and Securing Our
Water Future Policy development process
will present a summary of his work.

3.193 24

5. OVERVIEW OF EXISTING

POLICY THAT WOULD BE

REPLACED
25 3.194
2003 Integrated Water Plan (IWP)
• Developing the 2003 IWP took about 5
years and used a well-established “least
cost planning” approach that treats long
term demand management as a resource
along side of supply augmentation.
• Ultimately the plan recommended a 3-part
approach to addressing the Santa Cruz’s
long-standing supply reliability issues:

3.195 26
• The 3 parts of the plan were:

1. 300 million gallons of demand
reduction through long-term
conservation and efficiency
improvements;

2. Routine water demand curtailments of
up to 15% (Stage 2 in the 2009 Water
Shortage Contingency Plan – no
rationing); and

3. A 2.5 mgd capacity desalination plant
to be developed as a regional project
with Soquel Creek Water District.

3.196 27
• Since 2003….

1. Santa Cruz water service customers have
reduced water demand through long-term
conservation and efficiency improvements a
cumulative volume of nearly 1 billion gallons;

2. Highly efficient water use makes routine use
of curtailments, that now involve rationing at
every stage of the plan, an expensive and
impactful drought management tool; and

3. No supply augmentation project has been
built;

4. The water system is actuallymore vulnerable
to droughts now than earlier because it no
longer has much discretionary water use to
curtail.

3.197 28
In 2015 the Council Accepted the
WSAC’s Recommendations that:
• Establish a clear problem statement including
a need to plan for the worst-case drought with
a deficit of 1.2 billion gallons.
• Laid out an approach to achieving water
supply sustainability that involved another
200 to 250 million gallons in long term
demand reduction, which has been achieved
and is reflected in the cumulative 1 billion
gallons of demand reduction referenced
earlier.

3.198 29
• Laid out a process for evaluating and selecting
one or more supply augmentation projects
needed to meet the worst-case drought
conditions;
• Considered the impacts of climate change on
supply reliability;
• Provided direction on guiding principles,
primary evaluation criteria, and additional
values and considerations to be used in
transparently evaluating supply augmentation
options; and
• Created an adaptive management strategy to
allow new information to be considered and
incorporated into plan implementation.

3.199 30
The Securing Our Water Future Policy
• Establishes a clear, adaptable, and analysisdriven supply reliability goal; • Maintains and builds upon the WSAC work,
especially related to the basic problem
definition and the guiding principles and
criteria to be considered in selecting
supply augmentation projects;

3.200 31
• Replaces the now no longer practical 2003
IWP policy relative to routine use of
curtailments up to 15%; and
• Emphasizes moving from planning to
action, as is clearly needed in the face of
climate change that is already being
experienced in Santa Cruz.

3.201 32
This Policy Is:
• Responsive to plausible and moderate
assumptions about climate change that
increase our vulnerability to supply
shortages.
• Clear about what our water supply
reliability goal is why use of curtailments
as a shortage response tool should be
limited.
• Transparent about the process for
selecting and incrementally implementing
supply augmentation projects necessary to
meet the reliability goal.

3.202 33
This Policy Is Not:
• Based on the premise that Santa Cruz will
grow in an unplanned manner.
• Recommending selection of a supply
augmentation project to pursue or eliminating
further consideration of Aquifer Storage and
Recovery as a potential component of our
supply portfolio.
• Ignoring the relationship between increased
energy use for water treatment and some of
the supply augmentation options that are and
need to continue to be on the table.

3.203 34
Questions
35 3.204
The Economic Impact of
Water Supply Curtailments
(A Benefit of Water Supply Enhancements)
Review of Findings
Bob Raucher
Raucher LLC
Carolyn Wagner
CW Research and Consulting
Colleen Donovan
Social Science Strategies LLC
29 November 2022
1 3.205
What is the Value of Avoiding Water Shortages?
• Objectives and Approach
• Curtailment Stages
• Overview of impact types (households, businesses)
• Key Findings
• Q&A and Discussion
2 3.206
Risk = Probability * Consequences
• Probability (Likelihood)
• UMass modeling of shortage scenarios
• Limited ability of utility to control
• Consequences (Cost of Failure)
• Adverse impacts may be extremely large in some instances • Some degree of control over scale of adverse consequences 3 3.207
• Foregone regional economic activity
• Business revenues reduced
• Loss of economic output, jobs, incomes, tax revenues
• Loss to residential customers
• Drought impact fees, Excess use penalties
• Loss of enjoyment
• Reducing economic impact costs
• Benefit of supply augmentation
“When the well is dry, we know the worth of water”
Ben Franklin
Cost of Water Curtailments Can be Large
4 3.208
Methodology and Key Terms
• Modeling regional economic impact
• Input-Output model (e.g., IMPLAN)
• Tracks ripple effects through local economy
• Direct impact
• Restaurant scales back operation, reduces “output” and “value added” • Indirect impact
• Reduces purchases of labor, local foodstuffs, and other supplies • Reduces income earned by restaurant employees and owners • Induced impact
• Employees and owners reduce household purchases (due to lower income) • Supporting businesses face reduced output and lower earnings 5 3.209
Distribution of peak season water use (1.36 Billion gallons) Figure 1. Distribution of peak water use (1,358 MG)
Source: SCWD (2021)
The picture can't be displayed.
6 3.210
Curtailment Policy
• Updated in 2021 – Significantly more restrictive than 2016 version • Stage 3 household limit: 2016 = 10 CCF; 2021 = 4 CCF
• 2021 Stage 1 Experience: 30% of households over limit of 5 CCF • Curtailments only alternative to supply augmentation during drought • Prioritizes public health and safety
• Water savings likely inadequate to sustain supply through multi-year drought
• Excess use penalties can get large
• Intent to share the burden (disincentivize “I’ll just pay”) • Objective: Ensure water available for health and safety 7 3.211
Curtailment Reduction Goals by Customer Class
Customer class
(overall target)
Stage 1
(10%)
Stage 2
(20%)
Single family
residential 11% 21%
Multi-family
residential 8% 16%
Business 5% 10%
Golf courses 18% 36%
UCSC 9% 19%
North Coast
agriculture 5% 10%
Landscape irrigation 25% 50%
8 3.212
Curtailment Reduction Goals by Customer Class
Customer class
(overall target)
Stage 1
(10%)
Stage 2
(20%)
Stage 3
(30%)
Stage 4
(40%)
Stage 5
(50%)
Single family
residential 11% 21% 32% 42% 49%
Multi-family
residential 8% 16% 24% 32% 41%
Business 5% 10% 15% 21% 40%
Golf courses 18% 36% 55% 74% 90%
UCSC 9% 19% 28% 38% 45%
North Coast
agriculture 5% 10% 15% 25% 70%
Landscape irrigation 25% 50% 75% 100% 100%
9 3.213
Household Impacts
• Tight targets may result in a lot of “Excess Use Penalties” • 4 CCF at Stage 3
• 3 CCF at Stages 4 and 5
• Excess Use and associated penalties:
• $25 for 1 CCF over target
• $50 for additional 1 CCF over target
• Reduces disposable income of residents  Economic Impact • Separate from economic impact of business losses
• Small economic impact (<1% increase in lost economic output) • May be large impact for some households
10 3.214
Business sector overview
• Methodology
• Water use restrictions  Reduced economic “output” (net revenues) • Reduced output  IMPLAN  Reduced earnings, employment, tax revenues • Tourism-oriented businesses a key
• Accommodations and restaurants/food services as focal points • Data from pandemic provides insights
• Other sectors of interest
• Food product and other manufacturing
• Nurseries, landscaping, and related “green” businesses • UCSC, golf courses, agriculture
11 3.215
Water-dependent sectors for IMPLAN Analysis
• Accommodation
• Food services and drinking places
• Food manufacturing
• Car washes
• Nursery, garden center
• Flower, nursery stock wholesalers
• Amusement and theme parks
• Fitness and recreation centers
• Computer and electronic products
• UCSC
• Golf courses
12 3.216
Pandemic-based data: 2020 v. 2019
Tourism-Sector Impacts and Water Use: 2020 v. 2019
(Sources: Visit California, 2022; SCWD Billing Data)
Total Spending xxx -47%
Earnings xxx -23%
Jobs xxx -23%
Local Tax Revenues xxx -28%
Peak Season Water Use xxx
(Hotels and Restaurants) xxxx -28%
13 3.217
Impact on output: Approach and illustration
• Low and high impact scenario for each stage
• For example, Stage 4 for the hotel and restaurant sectors assumes impacts on output ranging from 20% to 30%
• Preliminary results assuming a 20% reduction in the hotel and restaurant sectors*
• Output reduced by $99.5M (a 1% reduction in total City-wide output) • Approximately 1,000 jobs lost
• City taxes reduced by $2.8 M
*City-wide results based on zip codes that fall within the city as a proxy 14 3.218 Results: City-level negative economic impacts (losses)
non-residential curtailments
Metric
(Losses)
Total impact at
Stage 3
Total impact at
Stage 4
Total impact at
Stage 5
Output lost ($M) $114.4 – $242.9 $324.3 – $505.3 $578.5 – $789.9 Percent of Output Lost 1% - 2.5% 3% – $5% 6% – 8%
Employment
(# of jobs lost) 1,146 – 2,428 3,236 – 5,066 5,752 – 7,902 Percent of Jobs Lost 2% - 4% 5% - 8% 9% - 12%
Tax revenues lost: City of
Santa Cruz*($M) $2.1 – $5.4 $8.0 – $12.7 $15.5 – $21.1
Percent of City Taxes Lost 2% – 5% 7% – 11% 14% – 19%
15 3.219
Sensitivity Analyses
(based on Stage 4 estimates for economic output lost)
• Including additional business sectors
• Economic impacts increase by ~ 14%
• Medical services sector assumed not to be impacted
• Including household impacts
• Economic impacts increase ~ 0.4% (excess use penalty impacts) • Including County-level impacts
• Economic impacts increase ~ 10%
• Cumulative Impacts > +25%
16 3.220
City-only incremental impacts from business curtailments Indicating the Value of Enhanced Supply
Incremental Impact
Change in output
($M)
$/MG**
($M)
$/AF
($M)
Stage 2* to 3 $114.4 – $242.9 $0.8 – $1.8 $0.3 – $0.6
Stage 3 to 4 $209.9 – $262.4 $1.5 – $1.9 $0.5 – $0.6
Stage 4 to 5 $254.2 – $284.6 $1.9 – $2.1 $0.6 – $0.7
* Assumes de minimus economic impact at Stage 2 for businesses ** Applies 136 MG need to meet each Stage’s 10% incremental reduction in total peak season demand
17 3.221
Interpreting Key Findings: Benefit of Additional Water
Avoiding a Stage 4 Curtailment (for example): Add 136 MG to remain at Stage 3 • Benefits (avoided in-City lost economic output): $210 B to $262+ B • Avoided in-City job losses of 2,100 to 2,500+ jobs
• Avoided City tax revenue losses of $6.1 M to $7.3+ M
• Amounts to $1.5M to $1.9M of “benefit” per MG added water • 15 to 20 jobs saved within City per MG added
• $44,000 to $52,000 added City tax revenues per MG added • Water supply augmentation options being evaluated by City all cost less than $36,000 per MG produced.
• Water costs are ~2% (i.e., ~1/50th) the potential benefit 18 3.222
Conservative Assumptions Applied
(Why Economic Impacts could be Larger than Estimated)
• Potential business relocations not included
• City-based businesses closing and/or relocating elsewhere (negative long-term impacts of water shortages)
• New or expanded businesses motivated to locate within City (positive long-term impacts of added water security and reliability) • Household disposable income-driven economic impacts not included:
• Covering increased administrative costs at SCWD
• Drought cost recovery fees
19 3.223
• Economic output lost
• 15% curtailment: $580 M (2022 $s)
• 25% curtailment: $20,240 M (2022 $s)
• 67% increase in water shortfall (8BG)
• 600% increase in job loss
• 3500% increase in economic output
lost (~$19.7B)
Adding 8BG of supply: $2.4M output saved per MG added
Similar Values Derived Elsewhere: Bay Area
Economic Impacts per Year of Water Shortage
(Mitchell, M-Cubed, 2008, for EBMUD)
20 3.224
Questions/discussion Questions & Discussion
21 3.225
City Council Special Meeting

AGENDA REPORT
DATE: 11/23/2022
AGENDA OF:

DEPARTMENT:
11/29/2022
Planning & Community Development
SUBJECT: Appeal of Planning Commission Approval of CP20-0068 Located at 126 Eucalyptus Avenue & 136 Pelton and Including a Non Residential Demolition Authorization Permit, Sequential Lot Line Adjustment, Special Use Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit to Reconfigure Five Lots into Two, Demolish Two Existing School Buildings (Approximately 28,417 Square Feet), Remove Six Heritage Trees, and Construct a 76-Unit (Including 13 Full Dwelling Units) Senior Housing Facility on a Site Listed on the Historic Building Survey (Vol. 1, p. 39) in the R 1 5/WCD O/CZ O/SP O (Single family residence/West Cliff Drive Overlay/Coastal Zone Overlay/Shoreline Protection Overlay) Zone District. (Environmental Determination: Categorical Exemption; Exempt under PRC CEQA Section 21083.3) Applicant: Roger Bernstein, Filed 8/10/2020 (PL)
RECOMMENDATION: Resolution denying the appeal of Anne and Robert Segal and upholding the appeal of Roger Bernstein, thereby adopting the resolution approving the NonResidential Demolition Authorization Permit, Sequential Lot Line Adjustment, Special Use Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit to reconfigure five lots into two, demolish two existing school buildings (approximately 28,417 square feet), remove six heritage trees, and construct a 76-unit (including 13 full dwelling units) senior housing facility as approved by the Planning Commission, but with the deletion of condition of approval 60.

BACKGROUND:

Project description
The project site is located on a 6.97-acre property at the northwest intersection of West Cliff Drive and Pelton Avenue. The site is currently developed with two residences, a carriage house, the Shrine of St. Joseph church, and two vacant school buildings that were last occupied by the Gateway School and have been vacant for a few years. The site has several heritage trees and is mapped for potential monarch butterfly habitat under the general plan and Local Coastal Program.

This project proposes to make the following changes to the site:
 Complete lot line adjustments to reconfigure five lots into two;  Demolish the former Gateway School buildings;
 Remove six heritage sized trees; and
 Construct a 76-unit senior community care facility consisting of 74,218 square feet of floor area in a two-story building with associated site improvements.

4.1  The floor plans shown on the project plans include studio, one-bedroom, and two-bedroom units and include 59 Assisted Living units with a total of 76 beds, 15 Memory Care units with a total of 19 beds, and two inclusionary units with a total of two beds. Eleven of the Assisted Living units and both inclusionary units are full dwelling units.

Required permits for this project include a Historic Alteration Permit, Non-Residential Demolition Authorization Permit, Lot Line Adjustment, Special Use Permit, Design Permit, Heritage Tree Removal Permit, and Coastal Permit. The Coastal Permit is appealable to the California Coastal Commission, as further discussed later in this section in more detail.

Previous hearings and appeal to City Council
The Historic Preservation Commission (HPC) heard the Historic Alteration Permit for the project on August 17, 2022. The HPC found that the project is compatible with the existing historic resources on the site and took action to approve the Historic Alteration Permit with a modified condition of approval requiring the applicant to provide window and stucco samples for Planning staff review and approval prior to building permit approval. The appeal period for this action ended on August 29, 2022, and no appeal was received. The City Council is not being asked to act upon the Historic Alteration Permit, as that permit is currently final. However, that permit cannot be implemented without final approvals being completed in the remaining permits.

The Planning Commission heard the rest of the permits associated with the project at the October 6, 2022 meeting. Commission discussion of the project centered on protections to ensure nighttime lights and landscaping were compatible with the adjacent monarch butterfly habitat and requirements to meet the City’s inclusionary housing ordinance. The Planning Commission approved the permits with several minor changes to the conditions proposed by staff and with the following additional conditions. See the following section for additional analysis of the conditions.  To the extent permitted by the Department of Public Works and the Fire Department, a more substantial traffic control device shall be installed to prevent vehicles from making a right turn when exiting the facility onto Pelton Avenue. The device shall be included on final building permit plans.
 The solar panel trellis may be retained on the building rooftop and exceed the height limit; Condition of Approval 42, point 7 regarding removal of the trellis shall be deleted.  As provided under Section 24.16.030.08 of the Zoning Ordinance, the Planning Commission as an approval body for the project, and based on substantial evidence, determines that the project includes congregate care living units and assisted living units and is therefore subject to the requirement that 15% of the congregate living or assisted living units shall be made available for rent to low-income households for an affordable rent.
 The applicant shall consult with a butterfly ecologist in preparing the landscaping and lighting plans to make every effort to make the landscaping and lighting support a thriving monarch butterfly population. Plans shall be reviewed and approved by Planning staff during building permit review.

A full analysis of the project is provided in the attached Historic Preservation Commission and Planning Commission agenda reports. Minutes from those meetings are attached as well.

Two parties appealed the Planning Commission decision during the 10-day appeal period following the October 6th meeting: project applicant Roger Bernstein, and Anne and Robert Segal

4.2 and Citizens from the Communities Adjacent to Lighthouse Field. Their respective appeal letters are attached. Both appeals were received in a timely manner and consistent with the appeal provisions of zoning ordinance section 24.04.180 et seq.

Coastal Commission appealability
The Coastal Permit associated with this project is appealable to the California Coastal Commission after all possible appeals are exhausted through the City. Such appeals must be filed with the Coastal Commission within 10 working days after the City transmits the final local action notice, which occurs after the City Council makes a decision on the project. Appeals may be submitted to the Coastal Commission in person, via email, or by mail using the form available on the Coastal Commission’s website. Additional information about the process is also available on the Coastal Commission’s website. Given the location of the Coastal Appeal Zone that bifurcates the site and based on the City’s latest communications with the Coastal Commission staff, project appealability is limited to the Sequential Lot Line Adjustment as well as the following portions of the project located within the SP-O (Shoreline Protection Overlay) zone district: 1) portion of the driveway on the senior housing part of the project; 2) new parking spaces/driveway between the existing church parking lot and the senior housing facility driveway; 3) a small portion of a 5-foot-wide accessway going from the housing parcel to the church parcel; 4) some landscaping around the new parking/driveway areas; and 5) the relocation of a meditation garden. Should substantial issue be found on appeal, the Coastal Commission would complete a de novo review of the entire Coastal Permit. Any potential appellants should coordinate with Coastal Commission staff to verify the applicable appealability and process.

DISCUSSION: This section focuses on analysis of the Planning Commission conditions, changes to conditions based on additional review by staff, and responses to the appeal contentions from each of the appellants. As noted above, a full analysis of the project and its consistency with applicable regulations is contained in the attached Planning Commission and HPC reports.

Analysis of Planning Commission Conditions
As described above, the Planning Commission added four additional conditions to the permit.

The first condition was for the project to include a more substantial traffic control device to direct traffic exiting the site to make a left turn only onto Pelton Avenue, in addition to the signage already required in the conditions of approval. Public Works staff has indicated they would support such a device if it is not within the public right of way, including the sidewalk or street. The Fire Department has expressed a concern that such a device may interfere with fire apparatus access, depending on the design. It is not clear at this time how such a structure would be designed. Staff is amenable to keeping the condition included by the Planning Commission. If the Council approves the proposal and includes the condition, then staff would require the applicant to present designs at the building permit stage, during which time Planning, Building, Fire, and Public Works staff would review the designs for consistency with applicable standards, incorporating the design into the final plans if such standards can be met.

Second, the Planning Commission supported retention of the rooftop trellis of which staff had initially recommended removal. Zoning ordinance section 24.12.150 allows architectural features to exceed the height limit, including “cupolas, scenery lofts, or other roof structures for the housing of elevators, stairways, tanks, ventilating fans, air conditioning, or similar equipment used solely to operate and maintain a building.” The agenda report for the Planning Commission had interpreted that the clause “used solely to operate and maintain a building” applied to any of the

4.3 structures listed under the height exception. Since the solar panels do not need to be placed atop a trellis to function, and the trellis itself was not needed solely to operate and maintain the building, the agenda report opined that the trellis would not be considered for a height exception. However, upon a more thorough consideration of the language of this height exception and consistent with previous interpretations of that code section, staff has now determined that the clause “used solely to operate and maintain a building” does not apply to all elements of the height exception and instead applies only to “similar equipment used solely to operate and maintain a building.” The solar panels are “equipment used solely to operate and maintain a building.” The roof trellis is not, as it is not used “solely to operate and maintain a building.” The trellis has two jobs: one is to house the solar panels, and the other job is to provide a non-essential amenity to the rooftop deck.

Non-essential amenities are not covered by the height exception, but in this instance, the trellis is supporting the “equipment used solely to operate and maintain a building” and can be accepted as a height exception because it is an “other” roof structure and because it is housing equipment used solely to operate and maintain a building. Therefore, staff agrees that the Planning Commission’s decision to retain the rooftop trellis is consistent with the height limits modifications of the zoning ordinance. Finding numbers 3 and 24 have been updated accordingly to reflect the above analysis.

Regarding the inclusionary housing condition, staff continues to take the position that the zoning ordinance requires this project to provide inclusionary units at the rate of 20-percent of the number of units that meet the definition of “dwelling unit.” See the Bernstein Appeal section below for a fuller discussion of this issue.

Staff has no issue with the condition to include a butterfly ecologist in the preparation of landscaping and lighting development plans.

Additional staff review
Additional staff review of the project has resulted in minor changes to the proposed project and proposed modifications to the conditions of approval since Planning Commission approval, relating to the assignment of inclusionary units, the protection of butterflies, access across Lot 1, and implications of the location of a sewer line to the north of the project site.

With regard to inclusionary units, zoning ordinance section 24.16.025.5 requires that for developments containing units with differing numbers of bedrooms, the inclusionary units shall represent the mix of market rate units. In the plans approved by the Planning Commission, the 13 dwelling units (with kitchens) include 11 two-bedroom assisted living units, a one-bedroom unit, and a studio unit. Typically, the inclusionary units are identified at the building permit stage when the applicant enters into a Participation Agreement with the City. A condition of approval required that the applicant comply with applicable inclusionary housing sections of the zoning ordinance and to enter into a Participation Agreement prior to building permit issuance. That said, the plans specifically label the one-bedroom unit and studio unit as the inclusionary units, so the unit mix is being considered now. The inclusionary units would need to be two-bedroom units to reflect the mix of dwelling units on the plans. To ensure consistency with section 24.16.025.5, the applicant is now proposing to change the mix of units with kitchens to three two-bedroom units, six onebedroom units, and four studio units as shown on the attached updated Project Information plan sheet G-001. The one-bedroom and studio unit inclusionary units would represent the new mix of dwelling units with full kitchens through compliance with sections 24.16.025.4 and 24.16.025.5.

In addition, since the two units labeled on the plans as inclusionary units were not identified with a particular use, conditions of approval #26 and #41 required the two units labeled as “inclusionary” to be either assisted living, independent living, or staff housing in order to ensure

4.4 they are consistent with the approved project. However, upon further analysis of this aspect of the project, staff prefers the inclusionary units to be designated for assisted living tenants and secondarily for independent living tenants if an assisted living tenant is not available. Staff experience with inclusionary assisted living units found that low income tenants cannot always afford all of the associated "assisted" services, and the City only regulates the rent, not the services. So, in an effort to ensure an inclusionary unit is not left vacant, staff wants to be flexible to allow for independent living tenants if needed. The inclusionary units should not be rented to staff since their purpose is to serve the low income senior population needing assistance. The conditions of approval are proposed to be revised accordingly to specify that the inclusionary units are for assisted living tenants and may only be considered for independent living tenants in the event a qualifying assisted living tenant is not available. As is typically the case, consistency with these provisions and all applicable provisions from the inclusionary housing section of the zoning ordinance will be confirmed as part of the Participation Agreement that the developer is required to enter into with the City prior to issuance of a building permit.

Regarding the protection of monarch butterflies, staff is concerned about the enforceability of two points of condition of approval 56, points 16 and 18, in the project approved by the Planning Commission. Point 16 seeks to prohibit vehicles exiting the site via the Pelton Avenue driveway from turning right onto Pelton Avenue, but it is not clear how that condition will be enforced. Staff proposes to modify this point to require the placement of signage indicating that the right turn is prohibited. Point 18 requires commercial delivery vehicles to enter and exit the site via the driveway on West Cliff Drive on lot 1. However, it is not clear how this requirement will be enforced given that delivery companies often have fixed routes, delivery drivers may change often, and neither the City nor the applicant has direct control over delivery companies. The proposed modification to the condition requires the project operator to provide written notice to delivery companies directing them to utilize the West Cliff Drive entrance through lot 1, along with signage at the driveway.

Regarding access through lot 1, condition #47 approved by the Planning Commission required the property owner to record a land use agreement allowing access to lot 1 for delivery vehicles, refuse service vehicles, and for the maintenance of stormwater facility infrastructure associated with the project. Staff proposes minor changes to the language of this condition to clarify the condition’s intent with regard to the location of access, to whom the access is granted, and the purpose of the allowed access.

It was brought to staff’s attention that the proposed property line wall along the northern side of the project site may be near or within a public sewer line to the north of the property. A new condition of approval (#60) requires the project to record an easement, change the proposed wall location, or otherwise comply with Public Works Department requirements if the sewer line is within five feet of the northern property line.

Finally, staff has determined that a portion of the project qualifies for a categorical exemption from CEQA under CEQA guidelines section 15305, Class 5, for Minor Alterations to Land Use Limitations, in addition to the other CEQA exemptions acknowledged by the Planning Commission. This additional exemption is discussed below under the Environmental Determination section of this report.

Bernstein Appeal

4.5 The appeal from the applicant, Roger Bernstein, seeks project approval with elimination of the inclusionary housing condition of approval added by the Planning Commission. The appeal letter asserts that the Planning Commission misapplied the inclusionary provisions of the municipal code and also stated concerns about the project’s financial feasibility given the additional requirement.

While the municipal code itself does not expressly consider financial feasibility in the application of inclusionary housing requirements, it does provide a clear pathway for determining the number of inclusionary units required to be provided.

Zoning ordinance section 24.16.020 defines the standard inclusionary housing requirements for developments that create two or more dwelling units. Zoning ordinance section 24.16.020.5(a) requires a development with five or more rental units to provide 20 percent of those units to low income households at an affordable rent. In this case, 13 of the proposed units have kitchens and therefore meet the zoning ordinance definition of a dwelling unit under zoning ordinance sections

24.22.320 and 24.22.372:

Section 24.22.320. Dwelling Unit. A dwelling unit is a building or portion of a building including one or more rooms which is/are designed or used as a residence by one family or housekeeping unit, with facilities for living, sleeping, eating, sanitation, and food preparation (emphasis added). A dwelling unit shall have only one domestic food preparation facility, except that a single-family dwelling may also include one area meeting the standards of a junior accessory dwelling unit complying with Section 24.16.170. A dwelling unit shall have interior access between all habitable spaces, except that a junior accessory dwelling unit containing all facilities necessary for living, sleeping, eating, food preparation and sanitation need not maintain interior access to the remainder of the dwelling unit.

Section 24.22.372. Food Preparation Facility, Domestic (Kitchen). Any room or portion of a room used or designed to be used for cooking and/or preparation of food and containing two or more of the following appliances and/or fixtures; any sink (larger than fourteen inches by fourteen inches and/or having a drain outlet larger than one and one-half inches in diameter), refrigerator (larger than two and one-half cubic feet), hot plate, microwave, burner, stove or oven.

To meet the inclusionary requirement, 20 percent of the 13 dwelling units, or two, will be restricted at an affordable rent for low income households. The remaining 63 units, which do not have full kitchens, do not meet the definition of dwelling unit under section 24.22.320 and therefore are not subject to the standard inclusionary requirements of 24.16.020. In the event of a proposal to increase the number of units with full kitchens in the future, condition of approval 42 requires such an increase to obtain approval of a permit modification that would require the number of inclusionary units to be based on the new number of units with full kitchens.

Zoning ordinance section 24.16.030 defines alternative methods to comply with the inclusionary housing requirements. Section 24.16.030.1 states that the project applicant must apply for an alternative method if they wish to use one of these methods rather than following the standard requirements of 24.16.020. Providing congregate/assisted living units as set forth in section

24.16.030.8 is one of several alternatives to meet the City’s inclusionary requirement (other alternatives include dedicating land or paying an in-lieu fee), for which the developer would need to submit an application per section 24.16.030.1. Under section 24.16.030.8, the developer “may

4.6 propose to satisfy the inclusionary housing requirements by providing congregate living units or assisted living units.” Applicable code excerpts follow:

24.16.030 Alternative Methods to Comply with Inclusionary Housing Requirements

1. Application Submittal. Any application to use an alternative method to meet inclusionary housing requirements shall be submitted as part of the first approval for any residential development subject to the inclusionary housing requirements. …

8. Congregate Living Units or Assisted Living Units. An applicant may propose to satisfy the inclusionary housing requirements of this chapter by providing congregate living units or assisted living units. If the approval body determines that a proposed residential development includes congregate living units or assisted living units, the following alternative requirements shall apply:
a. Fifteen percent of the congregate living or assisted living units shall be made available for rent to low income households at an affordable rent. Monthly charges for congregate living or assisted living services in addition to the affordable rent may not exceed thirty-five percent of fifty percent of area median income for a single person, divided by twelve, or forty-five percent of fifty percent of area median income for two persons, divided by twelve.
b. The proportion of studio or one-bedroom units that are designated to be shared by non-family-members shall not exceed the proportion of the number of market rate units designated to be shared by non-family-members to the total number of market rate units. Furthermore, no more than two persons may occupy a studio or one-bedroom unit. For purposes of affordable rent calculations, for any unit shared by non-family-members the portion of the unit occupied by each individual shall be treated like a studio apartment and the rent for one person shall be equivalent to the affordable rent for a studio apartment. This section should not be interpreted to create a bias for undesired double occupancy.

If a project applicant applies for an alternative method per 24.16.030.1 by providing congregate care or assisted living units under section 24.16.030.8, then per section 24.16.030.8, the hearing body must determine whether the development includes congregate care or assisted living units as asserted by the applicant. If the hearing body determines that the units can indeed be considered to be congregate care or assisted living units, then the lower inclusionary ratio of 24.16.030.8.a would apply, with 15 percent of the congregate living or assisted living units made available to low income households at an affordable rent.

If a project applicant does not apply for an alternative method per 24.16.030.1, then none of the subsequent language under 24.16.030, the Alternative Methods to Comply with Inclusionary Housing Requirements, apply. Therefore, as the applicant did not apply for an alternative method, the provisions of 24.16.030.8 do not apply, and the hearing body cannot require the alternative inclusionary ratio for congregate care or assisted living units. Staff therefore recommends removal of the inclusionary condition that had been added by the Planning Commission and application of

4.7 the standard inclusionary requirement of 24.16.020. The attached memo from the City Attorney’s Office provides further explanation on this point.

Segal Appeal
The Segal appeal does not seek denial of the project, but rather requests additional conditions of approval for “improvements and Code errors.”
The first point of the appeal questions finding number 32, a Design Permit finding that states: “The site plan shall reasonably protect against external and internal noise, vibration and other factors which may tend to make the environment less desirable. The site plan should respect the need for privacy of adjacent residents.” The appeal letter asserts the analysis of the finding contains errors and omissions but does not explicitly state what those are. However, the letter underlines the phrase “once constructed,” so it appears the argument is that activities during the construction phase that cause noise, vibrations, and other factors that may make the environment less desirable were not addressed in the analysis for this finding. To this first assertion, the letter makes four supporting points.

In point 1.a, the appellant asserts that vibrations associated with construction traffic utilizing Pelton Avenue will eliminate the monarch butterfly population at Lighthouse Field, and point 1.b indicates that there is access to the site from West Cliff Drive through the church parcel (Lot 1) and that construction traffic should therefore be routed through that access point. The appellant references as supporting evidence an August 2, 2018 article from the Sierra Club magazine Sierra titled “What’s Killing the Monarchs? Our Roads.” This article cited a study in the journal Biology Letters and stated that the study found that roadways are the largest cause of mortality for butterflies. However, the cited study (Davis et al., 2018. Effects of simulated highway noise on heart rates of larval monarch butterflies, Danaus plexippus: implications for roadside habitat suitability Biol. Lett. http://doi.org/10.1098/rsbl.2018.0018) did not make this finding, but rather studied the effect of vibrations on monarch butterfly larvae physiology. This study does not directly relate to the monarch population at Lighthouse Field because it is an overwintering site for mature monarch butterflies and not a location for egg laying and larval development. The introduction section of this study did mention that monarchs “perhaps are killed by cars while laying [eggs]” and referenced another study from the Journal of the Lepidopterists' Society (McKenna DD, McKenna KM, Malcolm SB, Berenbaum MR. 2001 Mortality of lepidoptera along roadways in central Illinois. J. Lepid. Soc. 55, 63–68.). This study estimated the number of butterflies killed by vehicle strikes on roadways in Indiana but did not address how mortality levels from vehicle strikes compares to other causes of mortality. The study focused on habitat areas that support butterfly nectaring and egg laying areas and found that up to a point, roadways with higher vehicle speeds resulted in a larger number of butterfly strikes. While it is not clear how such findings would translate to an overwintering site in Santa Cruz, one may hypothesize that due to the residential nature of Pelton Avenue, vehicle speeds tend to be low, and butterfly strikes therefore may be fewer than if the overwintering site were adjacent to a major arterial street.

Regardless, the Sierra article is misleading and the referenced study of vehicle strikes is not relevant to the question of construction traffic vibration raised by the appellant.

To put the question of vehicle impacts into further perspective, the project biologist communicated that butterfly deaths have been observed to occur at this location during winter storm events when the butterflies are blown out of the roosting grove onto the Pelton Avenue roadway and subsequently run over by passing vehicles. However, while noise, vibration, and strikes associated with passing traffic is considered to affect the butterflies, the population has nevertheless made

4.8 their home in this urban setting adjacent to Pelton Avenue for a number of decades. More significant factors affecting the monarch butterfly population at this location include the quality of habitat provided by the eucalyptus grove itself as well as the quality of habitat in other faraway locations associated with the population’s migratory cycle (Justin Davilla, Ecosystems West, personal communication, 11-9-22).

It should also be noted that the applicant anticipates an average of six to eight construction vehicle trips per day on Pelton Avenue during construction of the project. According to the traffic study submitted for the project, the overall daily vehicle trips on this segment of Pelton Avenue in 2019 ranged from approximately 561 (weekday in January) to 1,127 (weekend in October). Thus, the construction vehicle traffic will be a very small percentage (0.5-1.4%) of the overall daily traffic along this stretch of the street.

The supporting points brought by the appellant do not lend merit to the suggestion of routing all construction traffic through the church lot via West Cliff Drive. In contrast, the project approved by the Planning Commission already does protect monarch butterflies during construction as required by general plan and local coastal program (LCP). General plan policy-action NRC2.4.1 references Table 1 of the Natural Resources and Conservation element, which identifies four broad categories of avoidance and management strategies to be applied to projects where monarch butterflies are present:
 Avoidance – design plans to avoid take of individuals and habitat,  Buffers to maintain suitable habitat conditions,
 Conduct construction activities outside of winter roosting season or develop appropriate mitigation such as buffers to avoid disturbance such as smoke and fumes, and  Management to protect from indirect impacts.

Similarly, LCP policy EQ 4.5.3.2 requires development near monarch butterfly habitat to include an environmental impact analysis (i.e. biotic review) and to include management measures to preserve the habitat.

The biotic report prepared for the project included several recommendations for avoidance and management related to effects of construction on the butterflies. First, the report recommended starting daily construction after temperatures are above 55 degrees Fahrenheit, the temperature at which these cold-blooded insects would be able to fly and avoid being displaced by construction related vibrations. The report also recommended all construction vehicles enter and exit on Pelton Avenue from the east to avoid driving adjacent to the monarch overwintering site. In addition, the report recommended a 100-foot buffer from monarch roosts. Since the driveway entrance on Pelton Avenue is approximately 160 feet northeast of the monarch roost grove, construction vehicle traffic entering and exiting the site on Pelton Avenue from and to the east will avoid this buffer zone entirely. These recommendations are consistent with NRC2.4.1and EQ 4.5.3.2 and are included in the conditions of approval that were approved by the Planning Commission.

While the above discussion of consistency with the general plan and LCP policies has been included in the permit findings that focus on sensitive habitat areas, staff agrees that the issue of construction noise, vibration, or other factors as they relate to the nearby monarch butterfly habitat was not described within finding number 32. The analysis for this finding has been updated to include this information.

4.9 Appeal letter point 1.b questions the impact of construction vehicle traffic on the paving quality of Pelton Avenue. The Public Works Department believes the existing condition of the paving on Pelton Avenue is sufficient to support construction vehicle traffic for the project. The Public Works Department also has standard measures in place to ensure any damage to the road due to neglect by the contractor is fixed prior to final inspection of the building permit.

In point 1.c, the appellant correctly states that the church provided a parking and drop-off/pickup area for the Gateway School to reduce traffic congestion in the residential neighborhood. The dropoff/pickup location was created in response to a substantial amount of traffic congestion directly in front of the school on Eucalyptus Avenue caused by cars idling in the street at the start and end of the school day. The proposed project has fewer vehicle trips than the previous school use and congestion is not expected to occur at specific times in the day as with a school use. The Public Works Department therefore has not required any additional traffic management measures. In addition, the project does not provide any vehicular access along Eucalyptus Avenue, provides all parking and a drop-off/pickup zone on site, and directs vehicle traffic leaving the site in an eastward direction toward West Cliff Drive and away from the nearby residences. Therefore, the project will not create problems related to traffic congestion within the surrounding residential neighborhood.

Appeal letter point 1.d asserts that the project does not qualify as an “infill” project if it does not utilize the same vehicular circulation pattern as the previous use on the site. The Class 32 In-Fill Development exemption under the California Environmental Quality Act (CEQA) does not require a project to have the same vehicular circulation pattern as the previous use on the site. This exemption is discussed further in the discussion of the appeal letter’s third point below.

The second point of the appeal opines that there are “errors and omissions” regarding finding 11, a Coastal Permit finding that states: “Maintain public access to the coast along any coastline as set forth in the Local Coastal Land Use Plan.” The appeal letter lists several points to support this assertion.

First, the appellant states that project will require left-turn only egress onto Pelton but does not require ingress only from the east (appeal letter points 2.a and 2.b). These points do not relate to the ability of the public to access the coast and therefore does not relate to finding 11. In addition, the purpose of the left-turn exit requirement is to minimize headlights shining into the monarch roosting site at night. Vehicles entering the site from Pelton Avenue would not shine headlights into the roosting site regardless of the direction of travel.

The appellant also indicates that the proposed driveway is less than 100 feet away from the monarch butterfly roosting site (appeal letter point 2.c). While this point is irrelevant to the finding for public coastal access, it should be clarified that the westernmost edge of the driveway is approximately 160 feet away from the monarch roosting site.

The appellant states that the site plan provides an alternate entrance from West Cliff Drive that should be made the main entrance in order to avoid impacts to butterflies and to public parking along Pelton Avenue that are caused by the Eucalyptus Avenue driveway (appeal letter point 2.d).

The point about butterflies is irrelevant for a finding about public coastal access, and the relationship between the driveway, passing vehicles, and the monarch roost grove has been discussed above. The curb cut for this driveway currently exists on Eucalyptus Avenue, so

4.10 construction of a driveway to the new facility will not reduce the number of public parking spaces on Pelton Avenue.

Appellant letter point 2.e appears to refer to condition 48 originally proposed by staff in the packet published for the Planning Commission. The appellant did not indicate why they included a copy of this condition in the appeal letter. Staff had subsequently proposed a modified condition after packet production that was approved by the Planning Commission. The modified condition requires a land use agreement to allow commercial and refuse vehicles to access the site from the West Cliff Drive entrance on lot 1 and to eliminate language referring to an easement for all vehicles. The project operator will direct commercial vehicles to use the West Cliff Drive entrance exclusively as a management measure to reduce large vehicle traffic on Pelton near the monarch butterfly habitat area, and signage will be installed directing delivery drivers to use the driveway on West Cliff Drive. Refuse vehicles need to be able to use both the Pelton Avenue and West Cliff Drive entrances to perform refuse services efficiently. No valid basis exists to require all site visitors to enter and exit through an adjacent property, as the lot does, and must, have direct access to the street per subdivision ordinance section 23.24.030.5. Regardless, the condition of approval identified by the appellant is irrelevant to the issue of public coastal access.

Appeal letter point 2.f. asserts that City staff indicated that the “Cliff Avenue” (West Cliff Drive) entrance would not provide adequate fire access and then, as a supporting point, states that the fire access description described by Planning staff is different from the fire access described in the environmental document filed by the applicant. First, it should be noted that the environmental document was not filed by the applicant but was the CEQA exemption checklist produced by the Planning Department. The appellant is correct that the checklist erroneously omitted the Pelton Avenue entrance in the description of fire access locations; the attached checklist has accordingly been updated to include a description of both locations. Both the Eucalyptus Avenue and Pelton Avenue fire access routes are shown on the plans, and both are needed to meet fire access requirements for the project site. Including a description of the Pelton Avenue fire access route would not change the conclusion in the CEQA document that the project as designed would not result in impacts to emergency access. In addition, the discrepancy between the project plans and the description in the environmental checklist document is not related to the fact that the West Cliff Drive entrance would not provide adequate fire access since it would create a fire apparatus access route more than 150 feet long. Finally, none of the information or opinions included in appeal letter point 2.f relate to the issue of public coastal access.

The appellant suggests that the Eucalyptus Avenue driveway be retained only as a gated access for emergency vehicles (appeal letter points 2.e, 2.f, and 2.g). Again, this does not appear to be relevant to the issue of coastal public access since the driveway as designed does not impact public coastal access. In addition, staff does not support this suggestion for three reasons. First, given the frequency of calls expected to the site, repeatedly opening and closing a gate or removing and then replacing bollards would significantly delay response times and put further strain on the workload and efficiency of Fire Department personnel. Second, refuse service vehicles need to utilize both the Pelton Avenue and West Cliff Drive entrances to travel efficiently through the site and avoid completing a time-consuming and complicated turnaround to exit the site. Third, municipal code section 23.24.030.5 requires a new lot to have access to an abutting street. Limiting this access to emergency vehicles only would not comply with this Subdivision Ordinance standard.

Appeal letter point 2.g again speculates, without supporting evidence, that the location of the Pelton Avenue entrance would impact the butterfly roosting site at Lighthouse Field State Park via

4.11 traffic congestion, noise, exhaust fumes, and headlights. As discussed earlier, the driveway is outside of the 100-foot construction work buffer recommended by the biotic report, and the project approved by the Planning Commission included a prohibition on right turns from the site onto Pelton Avenue to eliminate the potential for vehicle headlights to shine onto the roosting site at night. The biotic review did not find that the Pelton Avenue driveway would otherwise negatively affect the monarch butterfly roosting site, and it should also be considered that the level of traffic generated by the project will be less than the previous use on the site. Again, the question of biotic impacts does not relate to the issue of public coastal access and is not relevant to the Coastal Permit finding in question.

Point 2.g also states that utilizing the Pelton Avenue driveway for emergency access only will lessen the impact on Pelton Avenue street parking and pedestrian usage. Since the curb cut already exists, creation of a driveway on Pelton, whether for emergency access or public access, would not affect the number of on-street parking spaces or pedestrian access along the sidewalk. It should also be noted that the project will include a new sidewalk along the north side of Pelton Avenue, improving pedestrian access near the coast.

Point 2.h of the appeal letter quotes several passages from the Planning Commission agenda report and asserts that these passages support the use of “West Cliff Avenue” (West Cliff Drive) as the primary entrance and exit for the project site. The first quoted passage refers to a condition of approval memorializing the number of employees approved for the site, as the number of required on-site parking spaces is calculated based on the number of employees. The number of required on-site parking spaces does not relate to the location of the primary entrance. The second and third passages state that the project provides all required parking on site and confirm that the project will not increase demand for on-street parking and therefore does not impact public coastal access.

None of the three passages indicate support for a primary entrance through the adjacent lot on West Cliff Drive.

The letter makes an additional, unnumbered point in bold text indicating that the use of delivery trucks on Pelton Avenue will require the City to repair the street. The Public Works Department has indicated that they find Pelton Avenue to be in adequate condition for the uses proposed.

Therefore, the project will not impact the ability of vehicles to utilize Pelton Avenue as it relates to coastal public access. In addition, the project approved by the Planning Commission includes a condition of approval, with further clarifications now proposed by staff as discussed above, requiring the project operator, Watermark, to instruct commercial vehicles visiting the site to use the West Cliff Drive driveway. Therefore, most commercial vehicles delivering to the site will be notified that they are not to utilize Pelton Avenue or the Pelton Avenue driveway.

Finally, the appellant recommends a new condition of approval to require all ingress and egress traffic to utilize the West Cliff Drive driveway. As the above-discussed points presented by the appellant do not support the idea that the project as designed affects public coastal access, this condition does not need to be added to make the Coastal Permit finding in question. In addition, as already discussed, the new lot must include access via either Eucalyptus Avenue or Pelton Avenue in order to have direct street access, and access only via West Cliff Drive through an adjacent lot would not be consistent with the street access standards of the Subdivision Ordinance.

The appeal letter’s third point questions the Planning Commission’s acknowledgement of the Class 32 categorical exemption from CEQA for In-Fill Development. The attached Notice of Exemption provides a full explanation of the project’s consistency with this categorical exemption.

4.12 CEQA guidelines section 15332 provides that, to qualify for an In-Fill Development exemption, the project must meet the following conditions:
(a) The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations. (b) The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses.
(c) The project site has no value as habitat for endangered, rare, or threatened species. (d) Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality.
(e) The site can be adequately served by all required utilities and public services.

First, appeal letter section 3.a indicates the Planning Commission agenda report states the project site is seven acres. While not explicitly stated in the appeal letter, it may be assumed that there is concern about the stated size of the lot since CEQA guidelines section 15332(b) limits a project site to no more than five acres. While the entire site is nearly seven acres in size, a large portion of the property will remain as is and will not be redeveloped. The proposed development area is approximately 3.3 acres, including development of the project on lot 2 and the additional parking, paving, and minor landscaping work on lot 1, which is less than five acres. In addition, the lot line adjustment is exempt under a Class 5 categorical exemption for minor alterations for land use limitations, and the lot line adjustment action will precede the project construction. As to whether the “project site” is seven acres, or five or fewer acres for the purpose of the CEQA exemption, recent case law focuses on the portion of the site being developed, not the underlying size of the affected assessor’s parcel. (Protect Tustin Ranch v. City of Tustin (2021) 70 Cal.App.5th 951, 960- 961 (Protect Tustin) [proposed Costco gas station was to be built on a 2.38-acre area within a larger 12-acre shopping center].)
Point 3.b. of the appeal letter adds emphasis to CEQA guidelines section 15332(c), which requires the project site to have no value as habitat for endangered, rare, or threatened species. While the appeal letter does not explain why the emphasis is added, this analysis is assuming that there is concern regarding the proximity of the project to the monarch butterfly roosting site at Lighthouse Field State Park. The operative phrase in CEQA Guidelines section 15332, subdivision (c), is that “[t]he project site has no value as habitat for endangered, rare or threatened species.” Staff interprets this language as dealing only with listed species, and the monarch butterfly is not formally listed as threatened or endangered on either the federal or state endangered species list.

Therefore, the monarch butterfly population does not rise to the level of “endangered, rare, or threatened” for the purposes of this CEQA exemption.

Point 3.c of the appeal letter quotes a couple of sentences from the Planning Commission agenda report that state the project would have no significant effects related to vehicle miles traveled (VMT), or related to noise, air quality, or water quality. While the appellant does not indicate what their concern is with this agenda report language or provide any rebutting information, it should be noted that substantial evidence is described in the CEQA checklist that supports the conclusion under CEQA guidelines section 15332(d) that “[a]pproval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality.” No additional analysis is required. (See Protect Tustin, supra, 70 Cal.App.5th at p. 960 [where “a public agency makes a factual determination that a project falls within a ... categorical exemption, we apply the substantial evidence standard in reviewing the agency's finding”].)

4.13 The appeal letter concludes point 3 by stating that the existing footprint as well as the existing entries and exits should remain the same as the previous use on the site in order for the project to qualify for an In-Fill Development exemption. None of the conditions for an In-Fill Development Exemption under CEQA guidelines section 15332 require the project to have the same vehicular circulation pattern or the same building footprint as the previous use on the site.

The fourth point of the appeal letter starts by quoting a passage from the Planning Commission agenda report regarding the project’s CEQA review. In this passage, the appeal letter underlines “unless substantial new information shows that the policies or standards would not substantially mitigate the environmental effect,” and emphasizes in bold part of the phrase stating the “General Plan 2030 EIR has adequately addressed most environmental issues related to the project.” The appeal letter does not explain the reason for quoting the passage or emphasizing these parts. To the extent that the underlining of this language is intended to imply or suggest that the General Plan development policies and standards relevant to monarch butterflies are somehow out of date, the letter does not offer any evidence or reasoning in support of such a potential contention. And the City is unaware of any such evidence or reasoning. The policies and standards remain current and effective. Further, a professional biologist has evaluated the site and reviewed the project plans and provided recommendations consistent with the categories of avoidance and management strategies included in the General Plan and types of actions suggested in the LCP. These recommendations were all included as conditions of approval. Nothing in the analysis concluded that any peculiar circumstances exist that require anything more than standard measures to apply as protections for the nearby monarch butterflies.

Appeal letter point 4.a states that findings 3, 7, and 24 are inaccurate because the project does not have an “Environmental Impact,” which perhaps refers to an Environmental Impact Report (EIR).

Findings 3, 7, and 24 are required for the Special Use Permit, Coastal Permit, and Design Permit, respectively. They each have slightly different wording, but the three findings generally require the project to be consistent with the general plan, any area plan, and the Local Coastal Program.

None of these three findings require the project to complete an Environmental Impact Report.

The appellant correctly states that the project must comply with CEQA. All projects are subject to CEQA; however, most projects do not require an EIR to comply with CEQA. A project is only required to complete an EIR if it does not qualify for an exemption from further CEQA review and if an initial study finds that the project may have a significant impact on the environment that cannot clearly be mitigated to a less than significant level. In this case, the project qualifies for a categorical exemption from CEQA review for an In-Fill Development project (Class 32, CEQA Guidelines section 15332), and is also exempt from CEQA pursuant to Public Resources Code section 21083.3 and the related CEQA Guidelines section 15183. A portion of the project also qualifies for a categorical exemption for Minor Alterations to Land Use Limitations (Class 5, CEQA Guidelines section 15305). The exemptions are discussed in more detail in the attached Planning Commission agenda report, the Notice of Exemption, and the CEQA review checklist.

Appeal letter point 4.b quotes a passage of the Planning Commission agenda report discussing LCP policy EQ 4.5.3.2 and the biotic review of the project in relation to monarch butterflies. The policy reads:

4.5.3.2 Require development in the vicinity of designated monarch sites to undergo environmental impact analysis and for development affecting sites prepare a

4.14 management plan addressing preservation of the habitat that includes criteria such as:
 Prohibiting the cutting, thinning, pruning or removal of any tree or shrub (especially nectar plants used by monarchs) except as necessary for safety of homes or persons and requiring replacement of comparable vegetation;  Prohibiting pesticide use and keeping all water sources clean;  Allowing construction only during the months when monarchs are not present; and
 Keeping smoke from infiltrating monarch roosting sites.

It should be noted that EQ 4.5.3.2 requires development near monarch butterfly habitat to include an “environmental impact analysis,” which the appellant may be confusing with an EIR. Rather, the purpose of this policy is to include a review of potential impacts of a development project on a nearby monarch butterfly habitat. The biotic report prepared for this project included a review of potential biotic impacts on the butterflies and recommended management measures similar to the examples provided in EQ 4.5.3.2 which were then included in the conditions of approval.

Therefore, the project review and resulting conditions of approval are consistent with this LCP policy. The project is also therefore consistent with Public Resources Code Section 21083.3 in that a project can be exempt from further review under CEQA when uniformly applied development standards would substantially mitigate the project’s environmental effects. In this case, the biotic review and resulting conditions of approval are consistent with the uniformly applied standards within the General Plan and LCP policies regarding development near monarch butterfly habitat.

Appeal letter point 4.c states that the monarch butterfly population at Lighthouse Field has increased since the Gateway School closed and links to a January 25, 2022 Santa Cruz Sentinel article as supporting evidence. The newspaper article describes a monarch population boom in 2021 compared to 2020. The article also quotes the Xerces Society monarch lead stating: “There are so many environmental factors at play across their range that there’s no single cause or definitive answer for this year’s uptick, but hopefully it means we still have time to protect the migration,” and “So this year is not a recovery, and it will take multiple more years to understand if this is the beginning of a trend or just a blip.” In addition, the Gateway School closed in 2019, so if the closing of the school had directly affected the monarch population, it may be reasonable to hypothesize that the population would have increased significantly in 2020, the year following the closure, rather than in 2021. Because a correlation between the closing of Gateway School and 2021 butterfly population increase does not appear to line up temporally, there is no evidence of causation between the school closing and the change in monarch population; and monarch experts at the Xerces Society have stated that no cause for the population change has been identified. The link suggested by the applicant between the school closing and the butterfly population increasing is speculative at best and does not appear to be supported by any scientific analysis.

In summary, the assertions presented in the Segal appeal are generally unsubstantiated, and staff continues to support the project as designed and with the conditions approved by the Planning Commission and as subsequently updated by staff with the exception of the condition added by the commission regarding inclusionary housing.

Health in All Policies (HiAP). HiAP is a collaborative approach to improving the health of all people by incorporating health considerations into decision-making across sectors and policy areas. HiAP is based on 3 pillars: equity, public health, and sustainability. The goal of HiAP is to ensure that all decision-makers are informed about the health, equity, and sustainability impacts

4.15 of various policy options during the policy development process. The project supports the pillar of equity by providing assisted living and memory care units on a site in a residential area that is improved with sidewalks, street trees, and that is near recreational areas. The project provides two inclusionary units that will be made available at an affordable rent to low income households for assisted living or independent living seniors or for staff. The project retains several heritage trees and will follow the City’s standard best management practices regarding the protection of nesting birds, roosting bats, and monarch butterflies, promoting sustainability of these natural resources.

Therefore, the project is consistent with the three pillars of the HiAP and is recommended as an efficient use of the land.

Environmental Determination. The project has been determined to be exempt from the California Environmental Quality Act (CEQA) under a Statutory Exemption pursuant to Public Resources Code Section 21083.3 and its parallel State CEQA Guidelines Sections 15183 (Projects Consistent with General Plan, Community Plan or Zoning), as well as pursuant to CEQA Guidelines Sections 15305 (Minor Alternations in Land Use Limitations) and 15332 (Categorical Exemption, Class 32, Infill Development Projects), as explained below. A copy of the Notice of Exemption is attached.

Public Resources Code Section 21083.3 allows a lead agency to avoid repeating analyses that were already provided in a certified general plan EIR for a development project that is consistent with the general plan. Public Resources Code section 21083.3 and its parallel CEQA Guidelines provision, section 15183, provide for streamlined environmental review for projects consistent with the general plan for which an EIR was certified. Subsection (d) further indicates that an effect of a project upon the environment shall not be considered “peculiar to the parcel or to the project…if uniformly applied development policies or standards” have been previously adopted by the city or county, with a finding based upon substantial evidence, that the development policies or standards will substantially mitigate that environmental effect when applied to future projects, unless substantial new information shows that the policies or standards would not substantially mitigate the environmental effect. Under these provisions of CEQA, the project has been found to be consistent with the General Plan. It has been determined that the City’s General Plan 2030 EIR has adequately addressed most environmental issues related to the project, and some site-specific project impacts have been analyzed and determined to be less than significant due to substantial mitigation resulting from General Plan policies, zoning regulations and/or development standards that are uniformly applied to development projects throughout the City. Therefore, no further environmental review is required pursuant to Public Resources Code section 21083.3 and section 15183 of the CEQA Guidelines, and the project is exempt from further CEQA review. An environmental checklist is attached that provides the explanations and support for this determination.

The lot line adjustment portion of the project is also exempt from CEQA review under Class 5 as a minor alteration in land use limitations. Examples provided for this class include minor lot line adjustments, side yard and setback variances, not resulting in the creation of any new parcel. The project includes a lot line adjustment reconfiguring five existing parcels to two, and would not create a new parcel as more than two parcels already exist Additionally, the project is exempt from CEQA review under Class 32 as an infill project. The project qualifies for this exemption because:
 The project is consistent with the general plan designation, applicable general plan policies, the zoning designation, and zoning regulations.

4.16  The development will take place within an area less than five acres on a site substantially surrounded by urban uses. While the entire site is nearly seven acres in size, a large proportion of the property will remain as is and will not be redeveloped. The proposed development area is approximately 3.3 acres, which is less than five acres.  The site has no value for endangered, rare, or threatened species based on results of a biotic resources report prepared for the project.
 The project would not result in significant effects related to traffic vehicle miles traveled (VMT) because the project use (assisted living and memory care facility) is considered non-significant and screened from further review. The project would not result in significant effects relating to noise, air quality, or water quality as discussed in the attached CEQA checklist.
 The site will continue to be served by utilities and public services.

None of the exceptions to the exemptions under Section 15300.2 apply to the project in that the project is not part of a larger project that could result in a cumulative impact, there are no unusual circumstances associated with the project or subject parcel, the project will not result in damage to resources associated with an officially designated scenic highway, the project site is not included on any lists compiled pursuant to Section 65962.5 of the Government Code related to Hazardous Waste Sites, and the project will not result in substantial adverse changes in the significance of a historical resource site based on a historical resources evaluation prepared for the project.

FISCAL IMPACT: The applicant has paid fees to compensate for costs associated with staff time processing this application. A condition of approval requires the applicant to reimburse the City for any outstanding fees, which includes consultant costs, associated with the processing of this application. The project, if approved, will contribute to increased property tax revenue to the City, and the project developer will be required to pay City impact fees, generating additional sources for funding of municipal services demanded by the project, the costs of which will generally be offset by the fees and taxes.

Prepared by:

Clara Stanger
Senior Planner
Submitted by:

Lee Butler
Director of Planning and
Community Development
Approved by:

Matt Huffaker
City Manager
ATTACHMENTS:
1) Resolution
2) Exhibit A: Conditions of Approval
3) Exhibit A: Conditions of Approval with Track changes 4) CEQA Notice of Exemption dated 11-17-22
5) CEQA Environmental Checklist pursuant to PRC 21083.3 dated 11-17-22 6) Memo from City Attorney’s Office regarding application of inclusionary ordinance 7) Appeal by Roger Bernstein
8) Appeal by Anne and Robert Segal and Citizens from the Communities Adjacent to Lighthouse Field
9) Historic Preservation Commission agenda report
10) Historic Preservation Commission conditions of approval 11) Historic Preservation Commission Meeting Minutes from 8-17-22 12) Planning Commission agenda report

4.17 13) Planning Commission conditions of approval
14) Planning Commission Meeting Minutes from 10-6-22
15) Updated sheet G-001 Project Information 11-16-22
16) Project Plans – Plans 1 - 5

4.18 RESOLUTION NO.

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CRUZ

ACKNOWLEDGING THE CEQA DETERMINATION, DENYING AN APPEAL OF THE PLANNING COMMISSION’S DECISION TO APPROVE BY ANNE AND ROBERT SEGAL

AND CITIZENS FROM THE COMMUNITIES ADJACENT TO LIGHTHOUSE FIELD, AND

UPHOLDING AN APPEAL FILED BY ROGER BERNSTEIN (APPLICANT) TO ELIMINATE

A CONDITION OF APPROVAL, THEREBY APPROVING A NON-RESIDENTIAL

DEMOLITION AUTHORIZATION PERMIT, SEQUENTIAL LOT LINE ADJUSTMENT,

SPECIAL USE PERMIT, COASTAL PERMIT, DESIGN PERMIT, HERITAGE TREE

REMOVAL PERMIT, AND HISTORIC ALTERATION PERMIT TO RECONFIGURE FIVE LOTS INTO TWO, DEMOLISH TWO EXISTING SCHOOL BUILDINGS (APPROX. 28,417 SQUARE FEET), REMOVE SIX HERITAGE TREES, AND CONSTRUCT A 76 UNIT (INCLUDING 13 FULL DWELLING UNITS) SENIOR HOUSING FACILITY ON A SITE LISTED ON THE HISTORIC BUILDING SURVEY (VOL. 1, P. 39) IN THE R-1-5/WCD-O/CZO/SP-O (SINGLE FAMILY RESIDENCE/WEST CLIFF DRIVE OVERLAY/COASTAL ZONE OVERLAY/SHORELINE PROTECTION OVERLAY) ZONE DISTRICT.
(APPLICATION NO. CP20-0068)
WHEREAS, On November 18, 2019, the applicant, Roger Bernstein, filed a preapplication for conceptual review of a project at the subject site; and WHEREAS, On August 10, 2020, the applicant, Roger Bernstein, filed an application for land use entitlements for the above-described project; and WHERAS, the project qualifies for a Categorical Exemption for Minor Alterations to Land Use Limitations pursuant to CEQA Guidelines Section 15035, a Categorical Exemption for In-Fill Development pursuant to CEQA Guidelines Section 15332, and an exemption from further CEQA review pursuant to Public Resources Code Section 21083.3 and related CEQA Guidelines Section 15183, as described fully in the staff report; and
WHEREAS, On August 17, 2022, the Historic Preservation Commission conducted a public hearing, and after hearing public testimony, approved the Historic Alteration Permit associated with the above-described project with a modification to condition of approval #6 requiring the applicant to submit a window sample and a 10’ x 10’ on-site stucco mock-up for review and approval by Planning staff prior to building permit issuance; and WHEREAS, On September 1, 2022, the Planning Commission conducted a public hearing and continued the hearing of the above-described project to the October 6, 2022 Planning Commission meeting due to a public noticing error; and
WHEREAS, On October 6, 2022, the Planning Commission conducted a public hearing, and after hearing public testimony, acknowledged the environmental determination with regard to CEQA Guidelines Section 15332 and Public Resources Code Section 21083.3 and approved the above-described project with several changes to the conditions; and

4.19 WHEREAS, On October 13, 2022, the City received an appeal of the Planning Commission decision involving a condition of approval related to application of the Inclusionary Housing Ordinance from Roger Bernstein within the 10-day appeal period following the Planning Commission hearing; and
WHEREAS, On October 17, 2022, the City received an appeal of the Planning Commission decision from Anne and Robert Segal and Citizens from the Communities Adjacent to Lighthouse Field within the 10-day appeal period following the Planning Commission hearing; and

WHEREAS, the City Council conducted a duly noticed public hearing on November 29, 2022 to consider the application and the full public record; and WHEREAS, the City Council now makes the following findings:

Lot Line Adjustment, Section 23.12.030.1b

1. The parcels resulting from the lot line adjustment will conform to the general plan, any applicable specific plan, any applicable coastal plan, zoning and building ordinances; and
The two resulting parcels conform to the general plan in that the existing parcels are below the density range for the Low Density Residential land use designation, the resulting Lot 1 is still below the density range but able to be developed to within the range in the future, and the resulting Lot 2 with the proposed new development is within the density range. The site is not located in the focus area of any specific plan. The two lots conform to the coastal plan in that a lot line adjustment requires a Coastal Permit in the Coastal Appeal Zone, and the project includes a Coastal Permit. The parcels resulting from the lot line adjustment conform to the zoning ordinance in terms of lot size, lot width, street frontage, FAR for existing buildings, and building setbacks. Conditions of approval require the overall site to meet the FAR limitation in the future. The lot line adjustment has been reviewed by the Building division and confirmed to meet California Building Codes.

2. A greater number of parcels than originally existed are not created by the lot line adjustment.

The lot line adjustment results in two lots, which is less than the five lots originally existing before the sequential lot line adjustment.

Special Use Permit, Section 24.08.050

3. The proposed structure or use conforms to the requirements and the intent of this title, and of the General Plan, relevant area plans, and the Coastal Land Use Plan, where appropriate;

4.20 The project is consistent with several general plan policies that promote housing for senior citizens and those with special needs (Housing Element Policy 3.1, 3.5, 3.6, 3.7; LU3.1) infill development that is compatible with the surrounding area (Housing Element Policies 1.1,

1.4, 5.3; LU 1.1; LU3.1; LU4.1.2; CD5.2; M3.3.5), protection of historic resources (HA1.8), and protection of sensitive biotic resources (Housing Element Policy 6.4, LU3.11.2, NRC2.2).

The project area has a general plan land use designation of Low-Density Residential, which accommodates single family residential neighborhoods, typically made up of detached homes. The corresponding R-1 zone districts in the zoning ordinance allow additional uses that are compatible with single family residential neighborhoods, such as community care facilities, churches, and bed and breakfasts, as long as approval of a Special Use Permit confirms that the use is compatible with the surrounding residential neighborhood.

Therefore, while the proposed senior housing community care facility is not the typical detached home found in the neighborhood, it is consistent with the neighborhood use envisioned in the general plan and as further defined in the zoning ordinance.

The Low-Density Residential designation allows a residential density range of 1.1 to 10 dwelling units per acre. The project results in two lots with two existing dwellings on the eastern lot (Lot 1) and the new senior housing facility on the western lot (Lot 2). The density of Lot 1 will continue to be less than the density range minimum; however, some development potential remains on the site that would allow it to be brought up to the density range in the future. The new senior housing facility on the western lot has 76 units, of which 13 have full kitchens and meet the definition of “dwelling unit” under the zoning ordinance.

These 13 units have a density of 4.3 dwellings per acre on the 3 acre lot, falling within the general plan density range.

The project site is not located within the focus area of any area or specific plan.

As conditioned, the project is consistent with the R-1-5 zone district and West Cliff Drive Overlay Zone District development standards and with the parking, signage, and inclusionary unit standards in the zoning ordinance. The following conditions ensure the project meets these standards:
 Final building permit plans shall show the arched architectural feature at the front of the building to be no more than 30 feet in height.
 Final building permit plans shall either show fireplaces on the floorplans below and connected to the proposed chimney or shall omit the over-height chimney.  A document (the document type be determined in coordination with the City Attorney’s Office) will be recorded on each of the two new lots ensuring that any future development does not exceed the overall FAR for the project site.  Final building permit plans shall include as-built drawings for all existing buildings on the church parcel in order to precisely calculate the remaining square footage available within the FAR limitation.
 Final building permit plans shall show any wall within the front yard setback to have a height of no more than three and a half feet.

4.21  Applicant shall obtain a Sign Permit and any necessary building permit prior to installing the proposed wall sign.
 Inclusionary units shall be either independent living, assisted living, or staff housing units.

The project is consistent with the Local Coastal Land Use Plan and the Local Coastal Implementation Program. LCP policy L 1.4 calls on projects to utilize the environmental review process to ensure protection of natural resources, wildlife habitats, archaeologically sensitive areas, and scenic views. The project was evaluated for effects on coastal resources such as biotic resources, potential archaeological resources, visual resources, and coastal access.

Biotic resources at and near the site include heritage trees and monarch butterfly habitat. The project is consistent with LCP policies CD 6.1.1 and CD 6.1.2, which require review of projects with heritage trees and replacement plantings at a two-to-one ratio. The Local Coastal Program defines the monarch butterfly as a “sensitive species” and includes policies to ensure their protection. Policy EQ 4.5.3 calls for protection of monarch butterfly overwintering habitat and requires development to be adequately buffered from these sites.

Policy 4.5.3.2 requires development near monarch butterfly habitat to include an environmental impact analysis and to include management measures to preserve the habitat.

Policy CR 1.2.2 requires projects to evaluate the extent of on-site archaeological and paleontological resources through archival research, site surveys and necessary supplemental testing as part of the initial environmental assessment on each potentially significant site.

The project has done this with an archaeological investigation as discussed above, and a standard condition will require the applicant to stop work in the event archaeological or paleontological resources are discovered.

The LCP calls for preservation of visual resources and especially those associated with open spaces (CD 1.4, CD 2.2.1, L 3.3, L 3.3.4), the shoreline (CD 3.4, LU 1.6), and areas designated by the LCP as scenic viewpoints (L 1.6). The proposed development has the building situated toward the north, with the southern end of the site in parking lot and landscaping. This arrangement creates a visual transition to the Lighthouse Field State Park across Pelton Avenue to the south. Since the new building it is west of the existing church and several trees to be retained on the site, and since the building at 30 feet tall is consistent with the height of buildings in the surrounding area, the view of the development from along the shoreline will be consistent with the view of other buildings in the neighborhood. The area of the project site is also within the viewshed of the end of the Santa Cruz Wharf, which is a designated viewpoint and panorama on LCP Map CD-3: Scenic Views. The new development may be partially visible from the wharf and will appear consistent with the surrounding area for the same reasons mentioned for the shoreline view.

4.22 The project is near several coastal access features shown on Map LCP-6: Coastal Recreation Areas and Access Routes (also shown as Map C-15: Visitor/Coastal Access Routes).

Therefore, the project will not affect any public parking spaces for those wishing to access the coast. In addition, the site does not have an existing public coastal access trail, so the project will not affect pedestrian or bicycle access to the coast. Policies CD 1.4 and L 5.6.2 call for development to maintain and provide public access to adjacent open space and coastal recreation areas. The proposed site plan includes a walkway that extends to the south of the site to the sidewalk along Pelton Avenue, giving people the ability to walk from the site to Lighthouse Field State Park or to West Cliff Drive and the shoreline access stairways. The site plan also includes a pedestrian walkway that connects to the walkway on the church parcel, providing access through that site to West Cliff Drive. Finally, the project itself will make coastal access possible for seniors with limited mobility, a demographic that may otherwise have limited access to this resource.

4. That any additional conditions stipulated as necessary in the public interest have been imposed;
The following conditions have been applied as they are necessary in the public interest:
 Based on the approved number of parking spaces, the number of employees on site at any given time shall not exceed 21. An increase in the number of employees on the site at a given time shall require approval of a modification to this permit and include an updated site plan to accommodate the increased parking requirement.  Prior to issuance of a building permit, the applicant, in conjunction with the property owner, shall submit a maintenance and management plan to address potential nuisance impacts associated with interior/exterior areas adjacent to the tenant space outlining measures to address trash/litter removal, graffiti, landscape maintenance, abandoned vehicles, noise and loitering, subject to approval by the Zoning Administrator.
 The management plan shall assign a “Neighbor Liaison” staff to provide a single point of contact between the community care facility and neighbors  The use shall operate in conformance with Chapter 9.36 of the Municipal Code (Noise).
 Any Public/Major Special Events on the premises shall be conducted in accordance with Chapter 10.64 of the Municipal Code, with requisite permit applications being filed in accordance with the timelines outlined therein.  Unless otherwise authorized by the City, all parking spaces shall be continuously maintained on the site in a condition that allows access by customers and employees of the use.

4.23  Prior to occupancy of the tenant space, the applicant shall file a trespass letter with the Santa Cruz Police Department (SCPD) in accordance with Santa Cruz Municipal Code section 9.60.012 providing SCPD the authority to remove trespassers on the premises.
 Final building plans shall include security alarms for the building that include motion activation and manual activation capabilities.
 Final building plans shall include exterior security lights that provide 360-degree coverage around the perimeter of all buildings while meeting the performance standards in the Zoning Ordinance.
 Final building plans shall include exterior security cameras that provide 360-degree coverage around the perimeter of all egress and ingress into the building. The security camera system shall have the capability to provide the recordings to police within 24 hours. In addition to the exterior security cameras, cameras need to be installed within the business itself and shall cover the doors and windows.  Prior to occupancy, the applicant shall obtain a Zoning Clearance from the Planning Department and a Business License from the Finance Department.  This use permit shall run with the land and shall be transferrable to a subsequent property owner or tenant upon confirmation that the subsequent use is in substantial compliance with the original use as verified through issuance of a Zoning Clearance.  This use permit shall expire and become void if the use has ceased for a period of six consecutive months, whether or not it is the intent to abandon said use.  Except for the stairs leading to the rooftop deck, all stairs leading to the roof shall be locked and accessible by staff only.
 The cafeterias/bar/cafe shall not be open to the public.  The use shall meet the standards and shall be developed within limits established by Chapter 24.14 of the Santa Cruz Municipal Code as to the emission of noise, odor, smoke, dust, vibration, wastes, fumes, or any public nuisance arising or occurring incidental to its establishment or operation.
 Inclusionary units shall be designated as either independent living, assisted living, or staff housing.
 Final building permit plans shall show the location, size, height, and content of signage at the Pelton Avenue exit prohibiting right turns onto Pelton and prohibiting the use of high beams until drivers are completely on eastbound Pelton Avenue.  Prior to building permit issuance, the applicant shall submit a review letter from the project biologist referring to the revision date of the final landscape plans and confirming that the new trees shown on the final landscape plan are located to avoid excess shading of monarch butterfly nectar resources.
 Final building permit plans shall show the location of an onsite water source, such as a fountain, for the monarchs near the nectar gardens.
 Prior to approval of any demolition, grading, or building permit, the applicant shall record in the Santa Cruz County Recorder’s office a land use agreement requiring:
o That commercial deliveries take access from West Cliff Drive,

4.24 o That refuse service vehicles be allowed to take access from West Cliff Drive, o That access is allowed to stormwater treatment and drainage facilities on Lot 1 for maintenance and repair purposes,
o That an easement for commercial and refuse service vehicles be recorded upon transfer of either Lot 1 or Lot 2 such that the owner of Lot 1 is not one and the same as the owner of Lot 2.
 Prohibit right-turns out of the Pelton Avenue driveway to divert outbound trips east of the existing monarch butterfly grove and avoid casting vehicle headlight glare into the grove.
 Install and maintain signage prohibiting high beams until drivers are completely on eastbound Pelton Avenue.
 All commercial deliveries shall use the West Cliff driveway for entering and exiting the site at all times.
 All exterior project lighting shall be shielded to contain the light source in a downward direction and avoid glare and illumination of adjacent properties and monarch butterfly grove at Lighthouse Field.
 Install and maintain predator proof waste bins.
 Eliminate populations of yellow jackets, eastern grey squirrels and rats on the property utilizing non-toxic methods.
 Restrict use of seed feeders that attract eastern grey squirrels and corvids.  Utilize leaf vacuums instead of blowers during maintenance operations.  Prohibit the use of neonicotinoids and other pesticides known to negatively impact monarchs.

5. That such use or structure will not constitute a nuisance or be detrimental to the public welfare of the community; and
The majority of the site will be a residential use that will be compatible with the surrounding residential, church, and open space uses. The site plan has placed operational uses as well as most of the residential amenities at the southeast corner of the building, away from both the surrounding residences and the open space to the south. This distance ensures compatibility with the surrounding uses. The memory care kitchen and cafeteria are located at the northern end of the building, which is closer to the residential uses. The kitchen will be required to meet any air quality standards as part of the building permit. In addition, standard conditions of approval requires the project to meet the performance standards relating to noise, odors, glare, and air pollutants.

4.25 6. That all thrift store uses shall include a management plan that identifies collection facilities for donated items, operating hours for donation facilities which discourage unsupervised dropoffs, adequate storage areas for sorting the materials, and provides a plan to properly dispose of unusable items in a timely, secure, and orderly fashion and maintains premises in a clean and attractive condition.

The project does not include a thrift store; therefore, this finding does not apply.

Coastal Permit, Section 24.08.250

7. The hearing body must find that the development is consistent with the General Plan, the Local Coastal Land Use Plan and the Local Coastal Implementation Program; The project is consistent with several general plan policies that promote housing for senior citizens and those with special needs (Housing Element Policy 3.1, 3.5, 3.6, 3.7; LU3.1) infill development that is compatible with the surrounding area (Housing Element Policies 1.1,

1.4, 5.3; LU 1.1; LU3.1; LU4.1.2; CD5.2; M3.3.5), protection of historic resources (HA1.8), and protection of sensitive biotic resources (Housing Element Policy 6.4, LU3.11.2, NRC2.2).

The Low-Density Residential designation allows a residential density range of 1.1 to 10 dwelling units per acre. The project results in two lots with two existing dwellings on the eastern lot (Lot 1) and the new senior housing facility on the western lot (Lot 2). The density of Lot 1 will continue to be less than the density range minimum, however, some development potential remains on the site that would allow it to be brought up to the density range in the future. The new senior housing facility on Lot 2 has 76 units, of which 13 have full kitchens and meet the definition of “dwelling unit” under the zoning ordinance. These 13 units have a density of 4.3 dwellings per acre on the 3 acre lot, falling within the density range.

4.26 such as biotic resources, potential archaeological resources, visual resources, and coastal access.

Policy 4.5.3.2 requires development near monarch butterfly habitat to include an environmental impact analysis and to include management measures to preserve the habitat.

The LCP calls for preservation of visual resources and especially those associated with open spaces (CD 1.4, CD 2.2.1, L 3.3, L 3.3.4), the shoreline (CD 3.4, L 1.6), and areas designated by the LCP as scenic viewpoints (L 1.6). The proposed development has the building situated toward the north, with the southern end of the site in parking lot and landscaping. This arrangement creates a visual transition to the Lighthouse Field State Park across Pelton Avenue to the south. Since the new building is west of the existing church and several trees are proposed to be retained on the site, and since the building at 30 feet tall is consistent with the height of buildings in the surrounding area, the view of the development from along the shoreline will be consistent with the view of other buildings in the neighborhood. The area of the project site is also within the viewshed of the Santa Cruz Wharf, which is a designated viewpoint and panorama on LCP Map CD-3: Scenic Views. The new development may be partially visible from the wharf and will appear consistent with the surrounding area for the same reasons mentioned for the shoreline view.

The project is near several coastal access features shown on Map LCP-6: Coastal Recreation Areas and Access Routes (also shown as Map C-15: Visitor/Coastal Access Routes).

4.27 wishing to access the coast. In addition, the site does not have an existing public coastal access trail, so the project will not affect pedestrian or bicycle access to the coast. Policies CD 1.4 and L 5.6.2 call for development to maintain and provide public access to adjacent open space and coastal recreation areas. The proposed site plan includes a walkway that extends to the south of the site to the sidewalk along Pelton Avenue, giving people the ability to walk from the site to Lighthouse Field State Park or to West Cliff Drive and the shoreline access stairways. The site plan also includes a pedestrian walkway that connects to the walkway on the church parcel, providing access through that site to West Cliff Drive. Finally, the project itself will make coastal access possible for seniors with assistance needs, a demographic that may otherwise have limited access to this resource.

8. Maintain views between the sea and the first public roadway parallel to the sea; The site is located on the inland side of West Cliff Drive, which is the first public road parallel to the sea, and therefore will not obstruct any views between the road and the sea.

9. Protect vegetation, natural habitats and natural resources consistent with the Local Coastal Land Use Plan;
Biotic resources at and near the site include heritage trees and monarch butterfly habitat. The project is consistent with LCP policies CD 6.1.1 and CD 6.1.2, which require review of projects with heritage trees and replacement plantings at a two-to-one ratio. The Local Coastal Program defines the monarch butterfly as a “sensitive species” and includes policies to ensure their protection. Policy EQ 4.5.3 calls for protection of monarch butterfly overwintering habitat and requires development to be adequately buffered from these sites.

Policy 4.5.3.2 requires development near monarch butterfly habitat to include an environmental impact analysis and to include management measures to preserve the habitat.

The biotic report prepared for the project evaluated the project’s potential impact to monarch butterflies and their adjacent roosting habitat and recommended management measures to ensure protection of the butterflies and the habitat during project construction. The report also included standard protection measures for nesting birds and roosting bats. A follow up biotic review of public comments received regarding the monarch butterfly habitat included several additional recommendations to protect and manage the butterflies. Conditions of approval require the applicant to adhere to the report recommendations and to the follow up recommendations that are consistent with the LCP and general plan.

10. Be consistent with any applicable design plans and/or area plans incorporated into the Local Coastal Land Use Plan;
The site is not located within the focus area of any design or area plan; therefore, this finding does not apply.

11. Maintain public access to the coast along any coastline as set forth in the Local Coastal Land Use Plan;

4.28 The site does not contain any existing coastal access way, although people parking on the street adjacent to the site may do so in order to access the coast. The project will provide all required parking on site and will not eliminate existing public parking adjacent to the site.

Therefore, the project is not expected to affect any public parking spaces for those wishing to access the coast. The project is near several coastal access features shown on Map LCP6: Coastal Recreation Areas and Access Routes (also shown as Map C-15: Visitor/Coastal Access Routes). According to the map, the site is near the West Cliff Drive, Lighthouse Point, and Cowell Beach coastal recreation areas. The map also designates West Cliff Drive as a coastal access route and identifies two sets of coastal access stairs along West Cliff Drive across the street from the north and south ends of the project site. The proposed site plan includes a walkway that extends to the south of the site to the sidewalk along Pelton Avenue, giving people the ability to walk from the site to Lighthouse Field State Park or to West Cliff Drive and the shoreline access stairways. The site plan also includes a pedestrian walkway that connects to the walkway on the church parcel, providing access through that site to West Cliff Drive.

12. Be consistent with the Local Coastal Land Use Plan goal of providing visitor-serving needs as appropriate;
The site is designated for residential development and not for development for visitor-serving needs, and visitor-serving uses are not proposed; therefore, this finding does not apply.

13. Be consistent with the Local Coastal Land Use Plan goal of encouraging coastal dependent uses as appropriate.

The project site is not located in an area designated for coastal dependent industries, and the project does not propose a coastal dependent use; therefore, this finding does not apply.

Shoreline Protection Overlay District Review Criteria, Section 24.10.2430

14. Protect trees and vegetation and sensitive wildlife habitat.

Policy 4.5.3.2 requires development near monarch butterfly habitat to include an environmental impact analysis and to include management measures to preserve the habitat.

4.29 approval require the applicant to adhere to the report recommendations and to the follow up recommendations that are consistent with the LCP and general plan.

15. Be consistent with the following criteria for bluff or cliff development:
a. The development is sited and designed to assure stability and structural integrity of its expected economic life span and minimize alterations to natural land forms.

The project site does not include any coastal bluffs or cliffs; therefore, this finding does not apply.
b. The development will not create or contribute significantly to problems of erosion or geologic instability on the site or on surrounding geologically hazardous areas.

The site is not located on a cliff or bluff; therefore, this finding does not apply. c. The development minimizes alteration of cliffs, bluff tops, faces or bases, and will not interfere with sand movement.

The project site is not located on a cliff, bluff top, face, or base, and is not located on the beach; therefore, this finding does not apply.
d. The development which proposes use of retaining walls shall be allowed only to stabilize slopes. Sea walls at the toe of sea cliffs to check marine erosion shall be allowed only where there is no less environmentally damaging alternative.

The proposed project does not include any retaining walls or sea walls; therefore, this finding does not apply.
e. The development within one hundred feet of any cliff or bluff line shall follow the recommendations of an approved geologic report by a registered geologist.

The area where such a report is required may be increased where the issue of slope stability requires a greater distance from any cliff or bluff line.

The proposed improvements are not within 100 feet of a cliff or bluff; therefore, this finding does not apply.

16. Provide maximum erosion protection, using accepted engineering practices and other methods and specifications set forth in this title.

During construction, the project proposes and will be required to follow Best Management Practices with regard to erosion and storm water control.

4.30 17. Maintain public view corridors between the sea and the first public roadway parallel to the sea and maintain natural views of the coastline; The site is located inland from West Cliff Drive, the first public road parallel to the sea, and therefore will not obstruct any public views of the coastline from that road.

18. Protect paleontological resources as prescribed in the Land Use Plan; A condition of approval requires the applicant to stop work and contact the proper authorities should any earth-disturbing work result in the discovery of a paleontological resource.

19. Protect and enhance free public access to or along the beach, and sign such access when necessary;
The site does not contain any existing public coastal access way, although people parking on the street adjacent to the site may do so in order to access the coast. The project will provide all required parking on site and will not reduce the number of existing public parking adjacent to the site. Therefore, the project is not expected to affect public parking spaces for those wishing to access the coast. The project is near several coastal access features shown on Map LCP-6: Coastal Recreation Areas and Access Routes (also shown as Map C-15:

Visitor/Coastal Access Routes). According to the map, the site is near the West Cliff Drive, Lighthouse Point, and Cowell Beach coastal recreation areas. The map also designates West Cliff Drive as a coastal access route and identifies two sets of coastal access stairs along West Cliff Drive across the street from the north and south ends of the project site. The proposed site plan includes a walkway that extends to the south of the site to the sidewalk along Pelton Avenue, giving people the ability to walk from the site to Lighthouse Field State Park or to West Cliff Drive and the shoreline access stairways. The site plan also includes a pedestrian walkway that connects to the walkway on the church parcel, providing access through that site to West Cliff Drive.

20. Include mitigation measures prescribed in any applicable environmental document; The project is exempt from CEQA review and therefore does not have an environmental document with mitigation measures. Conditions of approval require the project to follow recommended standard measures provided by the biotic, arborist, and archaeological consultants to protect resources consistent with the general plan, the LCP, and the zoning ordinance.

21. Be compatible with the established physical scale of the area; The proposed building is two stories and meets or exceeds all required setbacks for the West Cliff Drive Overlay zone district. The northern portion of the building is set back 56 feet from Eucalyptus Avenue, providing a substantial buffer between the building and the nearby residential buildings. When the site is considered as a whole, the development plus existing

4.31 buildings on the church property have an FAR of approximately 0.33, within the 0.35 limitation. Conditions of approval ensure that future development will keep the overall site FAR within this limitation. While the floor area of the proposed building is substantially larger than the single family homes in the area, the height, setbacks, and overall site FAR are within the range of the neighborhood’s established physical development.

22. Be consistent with the design review guidelines of this title and the policies of any applicable area plan;
The development meets the findings for a Design Permit in that the building has a comparable height to buildings in the surrounding area; the building’s large setbacks, modulated walls, and generous landscaping create a buffer to the street and soften the visual line of the building, the Mediterranean architectural style with proposed detailing and as conditioned create a high quality architectural design; the placement of amenities away from existing homes minimizes any impacts on those homes; the proposed setbacks ensure solar access and privacy for the residences to the north; and the site will blend in with the surrounding area from the viewpoint of the wharf, a designated panorama viewpoint in the general plan.

The site is not located within the focus area of any area plan.

23. Be consistent with the policies of the Local Coastal Program, the General Plan, and the California Coastal Act.

Policy 4.5.3.2 requires development near monarch butterfly habitat to include an environmental impact analysis and to include management measures to preserve the habitat.

The project has done this with an archaeological investigation as discussed above, and a

4.32 standard condition will require the applicant to stop work in the event archaeological or paleontological resources are discovered.

The project is near several coastal access features shown on Map LCP-6: Coastal Recreation Areas and Access Routes (also shown as Map C-15: Visitor/Coastal Access Routes).

Therefore, the project is not expected to affect any public parking spaces for those wishing to access the coast. In addition, the site does not have an existing public coastal access trail, so the project will not affect pedestrian or bicycle access to the coast. Policies CD 1.4 and L

5.6.2 call for development to maintain and provide public access to adjacent open space and coastal recreation areas. The proposed site plan includes a walkway that extends to the south of the site to the sidewalk along Pelton Avenue, giving people the ability to walk from the site to Lighthouse Field State Park or to West Cliff Drive and the shoreline access stairways.

The site plan also includes a pedestrian walkway that connects to the walkway on the church parcel, providing access through that site to West Cliff Drive. Finally, the project itself will make coastal access possible for seniors with limited mobility, a demographic that may otherwise have limited access to this resource.

The project is consistent with several general plan policies that promote housing for senior citizens and those with special needs (Housing Element Policy 3.1, 3.5, 3.6, 3.7; LU3.1) infill development that is compatible with the surrounding area (Housing Element Policies 1.1,

1.4, 5.3; LU 1.1; LU3.1; LU4.1.2; CD5.2; M3.3.5), protection of historic resources (HA1.8), and protection of sensitive biotic resources (Housing Element Policy 6.4, LU3.11.2, NRC2.2).

The project area has a general plan land use designation of Low-Density Residential, which accommodates single family residential neighborhoods, typically made up of detached

4.33 homes. The corresponding R-1 zone districts in the zoning ordinance allow additional uses that are compatible with single family residential neighborhoods, such as community care facilities, churches, and bed and breakfasts, as long as approval of a Special Use Permit confirms that the use is compatible with the surrounding residential neighborhood.

The Low-Density Residential designation allows a residential density range of 1.1 to 10 dwelling units per acre. The project results in two lots with two existing dwellings on the eastern lot (Lot 1) and the new senior housing facility on the western lot (Lot 2). The density of Lot 1 will continue to be less than the minimum of the range; however, there remains some development potential on the site that would allow it to be brought up to the density range in the future. The new senior housing facility on the western lot has 76 units, of which 13 have full kitchens and meet the definition of “dwelling unit” under the zoning ordinance. These 13 units have a density of 4.3 dwellings per acre on the 3 acre lot, falling within the density range.

The project is consistent with the California Coastal Act.

Design Permit, Section 24.08.430

24. The site plan and building design are consistent with design and development policies of the General Plan, any element of the General Plan, and any area plan, specific plan, or other city policy for physical development. If located in the Coastal Zone, the site plan and building design are also consistent with policies of the Local Coastal Program.

1.4, 5.3; LU 1.1; LU3.1; LU4.1.2; CD5.2; M3.3.5), protection of historic resources (HA1.8), and protection of sensitive biotic resources (Housing Element Policy 6.4, LU3.11.2, NRC2.2).

The Low-Density Residential designation allows a residential density range of 1.1 to 10 dwelling units per acre. The project results in two lots with two existing dwellings on the

4.34 eastern lot (Lot 1) and the new senior housing facility on the western lot (Lot 2). The density of Lot 1 will continue to have a density less than the minimum of the range; however, there remains some development potential on the site that would allow it to be brought up to the density range in the future. The new senior housing facility on the western lot has 76 units, of which 13 have full kitchens and meet the definition of “dwelling unit” under the zoning ordinance. These 13 units have a density of 4.3 dwellings per acre on the 3 acre lot, falling within the density range.

The project site is not located within the focus area of any area or specific plan.

As conditioned, the project is consistent with the R-1-5 zone district and West Cliff Drive Overlay Zone District development standards and with the parking, signage, and inclusionary unit standards in the zoning ordinance. The following conditions ensure the project meets these standards:
 Final building permit plans shall show the arched architectural feature at the front of the building to be no more than 30 feet in height.
 Final building permit plans shall either show fireplaces on the floorplans below and connected to the proposed chimney or shall omit the over-height chimney.  Prior to approval of any demolition, grading, or building permit, the applicant shall execute and record in the Santa Cruz County Recorder’s office a covenant or deed restriction, to the satisfaction of the City Attorney, documenting that Lot 2 shall not be approved for any additional Floor Area Ratio.
 Final building permit plans shall include as-built drawings for all existing buildings on the church parcel in order to precisely calculate the remaining square footage available within the FAR limitation.
 Final building permit plans shall show any wall within the front yard setback to have a height of no more than three and a half feet.
 Applicant shall obtain a Sign Permit and any necessary building permit prior to installing the proposed wall sign.
 Inclusionary units shall be either independent living, assisted living, or staff housing units.

Policy 4.5.3.2 requires development near monarch butterfly habitat to include an

4.35 environmental impact analysis and to include management measures to preserve the habitat.

The biotic report prepared for the project evaluated the project’s potential impact to monarch butterflies and their adjacent roosting habitat and recommended management measures to ensure protection of the butterflies and the habitat during project construction. A follow up biotic review of public comments received regarding the monarch butterfly habitat included several additional recommendations to protect and manage the butterflies. Many of these are consistent with LCP and general plan policies regarding monarch butterfly habitat.

Conditions of approval require the applicant to adhere to the report recommendations and to the follow up recommendations that are consistent with the LCP and general plan.

The project is near several coastal access features shown on Map LCP-6: Coastal Recreation Areas and Access Routes (also shown as Map C-15: Visitor/Coastal Access Routes).

According to the map, the site is near the West Cliff Drive, Lighthouse Point, and Cowell Beach coastal recreation areas. The map also designates West Cliff Drive as a coastal access route and identifies two sets of coastal access stairs along West Cliff Drive across the street from the north and south ends of the project site. LCP policy L 3.5.2 requires new development does not interfere with public access to the ocean. The project will provide all required parking on site and does not propose to eliminate existing public parking adjacent to the site. Therefore, the project is not expected to affect any public parking spaces for those wishing to access the coast. In addition, the site does not have an existing public coastal access trail, so the project will not affect pedestrian or bicycle access to the coast. Policies CD 1.4 and L 5.6.2 call for development to maintain and provide public access to adjacent open space and coastal recreation areas. The proposed site plan includes a walkway that extends to the south of the site to the sidewalk along Pelton Avenue, giving people the ability to walk from the site to Lighthouse Field State Park or to West Cliff Drive and the shoreline

4.36 access stairways. The site plan also includes a pedestrian walkway that connects to the walkway on the church parcel, providing access through that site to West Cliff Drive. Finally, the project itself will make coastal access possible for seniors with assistance needs, a demographic that may otherwise have limited access to this resource.

25. For non-residential projects, the project’s location, size, height, operations, and other significant features and characteristics are compatible with and do not adversely affect or further degrade adjacent properties, the surrounding neighborhood, or the public health, safety, and welfare. For residential projects, the project complies with the objective standards and requirements of the zoning district in which it is located, as well as any objective standards of any area plan or other regulatory document that applies to the area in which the project is located.

The proposal is a residential project but also has operational characteristics as it is a residential care facility. The development is adjacent to single family residences to the north and west, a church to the east, and the Lighthouse Field State Park open space to the south.

The development meets the required setbacks of the West Cliff Drive Overlay Zone District and exceeds the setbacks from Eucalyptus Avenue and Pelton Avenue, creating a substantial buffer between the development and the residential uses on Eucalyptus Avenue as well as the open space and monarch butterfly habitat south of Pelton Avenue. The new building is 74,218 square feet, substantially larger than the surrounding church buildings and single family homes. However, as the project site is nearly seven acres in size, the overall FAR is still within the maximum 0.35 allowed in the West Cliff Drive Overlay Zone District, and the size is therefore consistent with the FAR of surrounding development. The proposed building is two stories and 30 feet tall and is consistent with the height of the surrounding single family homes and adjacent church buildings. The site layout places the delivery and back-of-house operations area on the west side of the lot, adjacent to the church site and away from the residential uses to the north and west and the natural area to the south. This placement ensures compatibility with the neighborhood. As conditioned, the project complies with the applicable objective standards of the R-1-5 and West Cliff Drive Overlay zone districts and the objective standards of the zoning ordinance parking and signage regulations. The project site is not located within an area plan.

26. For non-residential projects, the project provides for an arrangement of uses, buildings, structures, open spaces, and other improvements that are compatible with the scale and character of the adjacent properties and surrounding neighborhood.

The proposal is a residential use but has some operational characteristics. The site layout places the delivery and back-of-house operations area on the west side of the lot, adjacent to the church site and away from the residential uses to the north and west and the natural area to the south. This placement ensures compatibility with the neighborhood. The kitchen and cafeteria associated with the memory care facility is not expected to generate nuisance features and will be required to meet the zoning ordinance’s performance standards with regard to noise, odors, and fumes.

4.37 27. The exterior design and appearance of buildings and structures and the design of the site plan shall be compatible with design and appearance of other existing buildings and structures in neighborhoods which have established architectural character worthy of preservation.

The development is located on a site that is listed on volume 1, page 39 of the City’s Historic Building Survey for the two historic residential buildings facing West Cliff Drive. The historic building survey identifies the architectural styles and pertinent design features on the buildings. While the new development has a Mediterranean architectural style, which is different from that of the historic buildings, the quality of the design will ensure compatibility with the historic resources. To meet this end, conditions of approval require windows to be recessed at least three inches, stucco to be hard trowel, smooth finish, and windows to be stained wood or baked enamel aluminum. The Historic Preservation Commission heard the item on August 17, 2022 to evaluate potential impacts on the historic resources and voted 6- 0-1 in favor of the development.

28. Design of the site plan respects design principles in terms of maintaining a balance of scale, form and proportion, using design components which are harmonious, and materials and colors which blend with elements of the site plan and surrounding areas.

Location of structures takes into account maintenance of public views; rooftop mechanical equipment is incorporated into roof design or screened from public rightsof-way to the extent possible. Utility installations such as trash enclosures, storage units, traffic-control devices, transformer vaults and electrical meters are accessible and screened.

While the building is quite large at 74,218 square feet, it maintains a balance of scale, form, and proportion in several ways. The building is two stories and 30 feet tall, a comparable height to the church and residence buildings on the east side of the project site as well as the single family homes in the surrounding areas. The building is sited to provide setbacks along Eucalyptus Avenue and Pelton Avenue that exceed the minimum required for the zone district including 29 feet and ranging up to 120 feet where 20 are required and 172 feet where 25 feet are required, respectively. The site plan includes substantial landscaping with many trees and shrubs to buffer the building and shows a conceptual layout. A condition of approval requires detailed landscape plans submitted for building permit review to include the number, size, and location of each plant. The building is modulated to create open courtyards, which softens the visual line of the building and separates the massing into smaller building segments that are more proportional to the size of single family homes. The building has a consistent Mediterranean architectural style, with a flat roof throughout; arched entry features; stucco siding; bronze-colored metal rooftop parapet copings, balcony railings, and window frames; and wood balcony trellises and walkway coverings. Terra cotta colored attic vents comprised of three circles arranged in a triangular formation add further detail consistent with the architectural style. To ensure a high quality and consistent architectural style throughout the development, conditions of approval require:
 All windows shall be recessed at least three inches,
 Window frames to be stained wood or baked enamel aluminum,  Stucco shall be hard trowel smooth finish

4.38  The trash enclosure walls shall have stucco and color to match the building, and the trellis-style roof shall be wood to match the trellis and covered walkway features throughout the site.
 The gate on the southwest side of the building shall be wood and the wall associated with the gate shall either be finished with stucco to match the building or shall be visually obscured with tall vines or other vegetation.
 Any rooftop elevator enclosure shall have the same exterior finish as the building.

The proposed development may be partially visible from the end of the wharf, which is designated as a panoramic view in Figure 4.3-1: Significant Views/Features of the general plan EIR. Because the building is two stories tall, because it is behind the church building from the view of the wharf, and because there are several large trees on the church property that will further screen the view of the building, it will blend in with the view of the existing development along the cliff from the perspective of the wharf.

A condition of approval requires building permit plans to show the height of rooftop mechanical equipment and to include sight lines to confirm whether the equipment is visible from the public right of way. Any screening needed to shield the equipment from the pedestrian view shall be screened with a color that matches the building color. The proposed transformer is located near the back of the parking area but would be visible from Pelton Avenue, so a condition of approval requires the southern and western sides of the transformer to be screened with landscaping. The plans include several water backflow prevention devices along the Eucalyptus Avenue frontage. A condition of approval requires landscaping between the backflows and the sidewalk to screen the public view of the backflows. A standard condition of approval requires all other utility installations and mechanical equipment to be accessible and screened.

29. Where a site plan abuts, or is in close proximity to, uses other than that proposed, the plan shall take into account its effect on other land uses. Where a nonresidential use abuts or is in close proximity to a residential use, the effect of the site plan should maintain the residential quality of adjacent or nearby areas.

The project site is surrounded by single family homes to the north and west, the church property to the east, and Lighthouse Field State Park to the south. The non-residential uses, such as back of house operations and deliveries, are located on the east side of the building and away from the residential uses, ensuring these activities will not affect the quality of the residential neighborhood. The proposed building exceeds the setbacks along Eucalyptus Avenue and Pelton Avenue, creating a landscaped buffer between the development and the residences on Eucalyptus Avenue as well as the open space and monarch butterfly habitat south of Pelton Avenue. The use is not anticipated to generate any nuisance features that would interfere with the residential uses, the open space, or the day-to-day activities of the adjacent church. To further discourage parking for the project along Eucalyptus Avenue and other nearby residential streets, a condition of approval requires the east-west pedestrian walkway directly north of 112 Eucalyptus Avenue to be omitted, with the landscape plan showing this area fully landscaped. To ensure a compatible relationship with the property at 112 Eucalyptus, which is directly adjacent to the project and closer to the parking, amenity,

4.39 and operational uses than the other single family homes in the area, the following conditions of approval apply:
 Applicant shall plant the proposed landscaping trees adjacent to the northern and eastern property lines of 112 Eucalyptus Avenue as early as practicable during the construction cycle.
 An additional arbor shall be constructed over the four parking spaces at the northwest corner of the parking lot. The arbor shall either be a continuation of the arbor in front of the building or shall be separated from that arbor by at least six feet. The arbor design and materials shall match that of the arbor in front of the building.  The western balcony wall at unit 236 shall have a privacy screen that extends to six feet above the floor of the balcony. The privacy screen color shall match the building.  Final landscaping plans shall show additional vegetation between the northeastern corner of 112 Eucalyptus Avenue and the southwestern corner of the balcony for unit 236. The additional vegetation shall have a mature height to contribute to visual screening between the balcony and 112 Eucalyptus Avenue.

30. To the extent feasible, the orientation and location of buildings, structures, open spaces and other features of the site plan maintain natural resources including significant trees and shrubs, minimize impacts to solar access of adjacent properties, and minimize alteration of natural land forms; building profiles, location, and orientation must relate to natural land forms.

The arborist report prepared by Nigel Belton on July 8, 2020 and update letter dated September 7, 2021 indicated the presence of 11 heritage trees and recommend removal of six of those trees. Of the six trees, the report recommended removal of one acacia due to poor health, two queen palms that are in good health but within the construction footprint, and three (a plum and two fruitless mulberry trees) with structural or health issues that are also within the construction footprint. Due to the size of the project, it is not feasible to re-orient the buildings to accommodate the two palms, which are the healthy trees, without substantially reducing the amount of open space facing Eucalyptus Avenue or affecting the project’s ability to meet the setback or height development standards. The City Urban Forester has reviewed the report and agrees with the recommendation. To meet Heritage tree removal standards as well as Coastal Policy CD6.1.2, replacement trees will be required at a ratio of either two 24-inch box trees or six 15-gallon trees for each tree to be removed.

Conditions of approval require the applicant to follow all recommendations in the arborist report and for the replacement trees species and location to be approved by the City Urban Forester.

The project site contains areas mapped as potentially containing sensitive habitat for monarch butterflies under the general plan. In addition, there is a known monarch butterfly habitat area approximately 200 feet to the southwest of the site within Lighthouse Field State Park.

A biotic report prepared by Ecosystems West Consulting Group on April 28, 2022 observed monarch butterflies flying on the project site and utilizing some flowering plants for nectaring. The report indicated that while some of these plants will be removed for the project, the project’s new landscaping includes species that can provide nectaring value to butterflies visiting the site. The report found no roosting habitat on the project site and limited

4.40 potential for roosting habitat in the trees on the remaining church property, and roosting was not observed on the property during any of the site visits. The report recommended standard measures to prevent any impacts to monarch butterflies during project construction. The report did not find the presence of other protected species or habitat but recommended additional standard measures to protect nesting birds or roosting bats during construction. A follow up biotic review of public comments received regarding the monarch butterfly habitat included several additional recommendations to protect and manage the butterflies.

Conditions of approval require the applicant to adhere to the report recommendations and to the follow up recommendations that are consistent with the LCP and general plan. The site is also within the area affected by the Planning Department’s bird- safe building design standards, and a condition of approval requires the project to meet these standards.

The shadow study submitted with the plans show that the site will not cast shade on adjacent properties during the summer months. On December 21st, when the shadows are anticipated to be the longest, the project will shade the back ends of the three houses at 103, 105, and 107 Manor Place at 9am, will not shade these houses at 12 noon, and will cast shade on the rear corner of the house at 103 Manor Place at 3pm. The shadow study showed that shadows will not reach the houses on Eucalyptus Avenue or shade buildings on the church property at any time between 9am and 3pm. Therefore, the proposal does not affect solar access to the surrounding properties. The project site is generally flat, and the proposed development will not change that landform.

31. The site plan ensures that the scale, bulk, and setbacks of new development preserves important public views along the ocean and of designated scenic coastal areas. Where appropriate and feasible, the project shall restore and enhance visual quality of visually degraded areas.

The site is on the inland side of West Cliff Drive and therefore will not affect public views of the ocean or other scenic coastal areas. The site is somewhat visually degraded as the existing school buildings are vacant and the site therefore is not maintained to its greatest potential. The new Mediterranean style building and ample landscaping will enhance the visual quality of the site and improve its visual compatibility with the surrounding neighborhood.

32. The site plan shall reasonably protect against external and internal noise, vibration and other factors which may tend to make the environment less desirable. The site plan should respect the need for privacy of adjacent residents.

Any noise or vibrations that may occur as a result of construction are temporary; once constructed, the units within the proposed senior housing and care facility will not cause any noise, vibrations, or other factors beyond those normally associated with a multi-family development that would make the environment less desirable. The residential amenities are all located at the southwestern end of the building, away from the existing single family homes in the area. The laundry facility and staff break room are in a small basement area that will not impact any residential uses. The memory care portion of the facility includes a kitchen, pantry, and dining room on the northern end of the building. While this is closer to the single family homes than other amenities, the kitchen will be required to meet any air

4.41 quality standards associated with exhaust fumes as part of building permit approval. Adjacent residents with potential privacy impacts include the three single family homes to the north of the proposed development. The second floor of the development has six memory care units along the north end of the building with windows and balconies facing the north. All elements of these units, including the balconies, meet or exceed the minimum 15 foot second floor interior side yard setback, and the wall of the building is set back 20 feet. This distance is typical of, or greater than, what would occur for single family development. A standard sized residential lot in the West Cliff Drive Overlay Zone District would have a minimum seven and a half foot interior side yard setback or a minimum 20 foot rear yard setback.

Therefore, the proposal has similar privacy impacts on adjacent properties to what would be expected with any kind of development in this neighborhood. In addition, the project will retain three heritage trees along the northern side of the property and plant 12 new trees along this side, which will help to create a visual buffer between the memory care units and the residences to the north. To ensure a sense of privacy for the single family home at 112 Eucalyptus, which is directly adjacent to the project and closer to the parking, amenity, and operational uses than the other single family homes in the area, the following conditions of approval apply:
 Applicant shall plant the proposed landscaping trees adjacent to the northern and eastern property lines of 112 Eucalyptus Avenue as early as practicable during the construction cycle.
 An additional arbor shall be constructed over the four parking spaces at the northwest corner of the parking lot. The arbor shall either be a continuation of the arbor in front of the building or shall be separated from that arbor by at least six feet. The arbor design and materials shall match that of the arbor in front of the building.  The western balcony wall at unit 236 shall have a privacy screen that extends to six feet above the floor of the balcony. The privacy screen color shall match the building.  Final landscaping plans shall show additional vegetation between the northeastern corner of 112 Eucalyptus Avenue and the southwestern corner of the balcony for unit 236. The additional vegetation shall have a mature height to contribute to visual screening between the balcony and 112 Eucalyptus Avenue.

General plan policy-action NRC2.4.1 references Table 1 of the Natural Resources and Conservation element, which identifies four broad categories of avoidance and management strategies to be applied to projects where monarch butterflies are present:
 Avoidance – design plans to avoid take of individuals and habitat,  Buffers to maintain suitable habitat conditions,
 Conduct construction activities outside of winter roosting season or develop appropriate mitigation such as buffers to avoid disturbance such as smoke and fumes, and
 Management to protect from indirect impacts.

The biotic report prepared for the project included several recommendations for avoidance and management related to effects of construction on the butterflies. First, the report

4.42 recommended starting daily construction after temperatures are above 55 degrees Fahrenheit, the temperature at which these cold-blooded insects would be able to fly and avoid being displaced by construction related vibrations. The report also recommended all construction vehicles enter and exit on Pelton Avenue from the east to avoid driving adjacent to the monarch overwintering site. In addition, the report recommended a 100-foot buffer from monarch roosts. Since the driveway entrance on Pelton Avenue is approximately 160 feet northeast of the monarch roost grove, construction vehicle traffic entering and exiting the site on Pelton Avenue from and to the east will avoid this buffer zone entirely. These recommendations are consistent with NRC2.4.1and EQ 4.5.3.2 and are included in the conditions of approval that were approved by the Planning Commission.

33. Building and structures shall be designed and oriented to make use of natural elements such as solar radiation, wind, and landscaping for heating, cooling, ventilation, and lighting.

The new building includes windows on all four elevations to allow light and air to pass through the building. Units have porches or balconies, giving residents access to private open space with fresh air and sunlight. Outdoor areas are landscaped and designed as useable open spaces for residents to spend time outdoors. Seven of the 11 heritage trees on the site will be retained, including two that will be removed and relocated on site, and the landscaping plan proposes several new trees that will provide shade. Ample landscaping throughout the site creates a natural cooling effect.

Nonresidential Demolition Authorization Permit, Section 24.08.1230.3

34. The cultural resources evaluation is accepted as accurate and complete; and the cultural resources evaluation concludes that the building or structure is not eligible for listing on the city historic building survey.

The historic evaluation of the two school buildings to be demolished, completed by Page & Turnbull, Inc. on April 19, 2022 on standard State of California Department of Parks and Recreation (DPR) 523 forms, found that neither building is eligible for listing on national, state, or local registers and they do not rise to the level of significance for the purposes of evaluation for consistency with CEQA. The evaluation is accurate and complete.

35. The project which will replace the demolished building or structure has been, or is concurrently being, approved by the city, and an appropriate building permit has been, or is concurrently being, issued; unless some other practical hardship can be documented rendering this requirement inappropriate.

The project also includes approval of a new residential senior care facility in the location of the existing buildings. A condition of approval requires the building permit to be issued concurrently with the demolition permit consistent with section 24.08.1230 of the zoning ordinance.

4.43 36. The property owner has been advised of the benefits of listing the property on the city historic building survey and incorporating the preservation of the historic resource into the proposed project.

The buildings to be demolished are not eligible for listing on the historic building survey; therefore, this finding does not apply.

37. The cultural resources evaluation determines that the resource is eligible for listing on the city historic building survey, appropriate environmental review has been completed in accordance with the California Environmental Quality Act, and the zoning administrator can make a finding of overriding consideration that the replacement project will have public benefits which will outweigh the impact of loss of the historic resource.

The buildings to be demolished are not eligible for listing on the historic building survey; therefore, this finding does not apply.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santa Cruz that it hereby acknowledges the CEQA determination, denies the appeal filed by Anne and Robert Segal and Citizens from the Communities Adjacent to Lighthouse Field, upholds the appeal filed by Roger Bernstein, and approves the Non Residential Demolition Authorization Permit, Sequential Lot Line Adjustment, Special Use Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit to reconfigure five lots into two, demolish two existing school buildings (approx. 28,417 square feet), remove six Heritage trees, and construct a 76 unit (including 13 full dwelling units) senior housing facility subject to the Findings listed above and the Conditions of Approval listed in Exhibit “A,” attached hereto and made a part hereof.

PASSED AND ADOPTED this 29th day of November 2022, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________
Sonja Brunner, Mayor
ATTEST: _________________________
Bonnie Bush, City Clerk Administrator

4.44 EXHIBIT "A"

CONDITIONS OF APPROVAL FOR THE PROJECT ON PROPERTY AT
126 Eucalyptus – CP20-0068
Non-Residential Demolition Authorization Permit, Sequential Lot Line Adjustment, Special Use Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit to reconfigure five lots into two, demolish two existing school buildings (approx. 28,417 square feet), remove six Heritage trees, and construct a 76 unit (including 13 full dwelling units) senior housing facility on a site listed on the historic building survey (Vol. 1, p. 39) in the R-1-5/WCD-O/CZ-O/SP-O (Single family residence/West Cliff Drive Overlay/Coastal Zone Overlay/Shoreline Protection Overlay) zone district. (Environmental Determination: Categorical Exemption & PRC/CEQA section 21083.3/15183) P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx

1. If one or more of the following conditions is not met with respect to all its terms, then this approval may be revoked.

2. All plans for future construction which are not covered by this review shall be submitted to the City Planning and Community Development Department for review and approval.

3. This permit shall be exercised within three (3) years of the date of final approval or it shall become null and void. When a building permit is required, a zoning permit shall be considered exercised following the issuance of a valid building permit. When only an occupancy permit is required, a zoning permit shall be considered exercised when the occupancy permit is issued.

4. If, upon exercise of this permit, this use is at any time determined by the Planning Commission to be incompatible with the surrounding neighborhood, revocation of, or amendment to, this permit by the Planning Commission could occur.

5. The use shall meet the standards and shall be developed within limits established by Chapter

24.14 of the Santa Cruz Municipal Code as to the emission of noise, odor, smoke, dust, vibration, wastes, fumes or any public nuisance arising or occurring incidental to its establishment or operation.

6. The applicant shall be responsible for the completeness and accuracy of all forms and supporting material submitted in connection with any application. Any errors or discrepancies found therein may result in the revocation of any approval or permits issued in connection therewith.

7. All final working drawings shall be submitted to the Zoning Administrator for review and approval in conjunction with building permit application. The plans submitted for building permits shall have the same level of articulation, detailing, and dimensionality as shown in the approved plans. All approved exterior finishes and materials shall be clearly notated on the building permit plans.

8. The applicant and contractor who obtains a building permit for the project shall be required to sign the following statement at the bottom of these conditions, which will become conditions of the building permit:
“I understand that the subject permit involves construction of a building (project) with an approved Design Permit. I intend to perform or supervise the performance of the work allowed by this permit in a manner which results in a finished building with the same level of detail, articulation, and dimensionality shown in the plans

4.45 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx submitted for building permits. I hereby acknowledge that failure to construct the building as represented in the building permit plans, may result in delay of the inspections process and/or the mandatory reconstruction or alteration of any portion of the building that is not in substantial conformance with the approved plans, prior to continuation of inspections or the building final.”
Signature of Building Contractor Date

9. The development of the site shall be in substantial accordance with the approved plans submitted and on file in the Department of Planning and Community Development of the City of Santa Cruz. All aspects of construction must be completed prior to occupancy. Major modifications to plans or exceptions to completion may be granted only by the City authority which approved the project.

10. All refuse and recycling activities during construction shall be done in accordance with Chapter

6.12 of the Santa Cruz Municipal Code. Be aware that private companies offering refuse or debris box services are not allowed to operate within the City limits, except under certain limited circumstances detailed in Chapter 6.12.160.

11. All requirements of the Building, Fire, Public Works, Housing, and Water Departments shall be completed prior to occupancy and continuously maintained thereafter.

12. Adequate provisions shall be made to supply water to each of the premises covered by this application. The design of water facilities shall be to standards of the Water Department, and plans therefore must be submitted to the Water Department Director for review and approval prior to the issuance of a building permit.

13. Plans submitted for building permit issuance shall include electric vehicle charging stations as required per Section 24.12.241 of the Zoning Ordinance.

14. Plans submitted for building permit issuance shall show all exterior site lighting locations and fixture details. All exterior building lighting shall be shielded and contained in a downward direction. No exterior lighting shall produce off-site glare.

15. Landscape and irrigation plans shall be submitted at the time of the building permit application and will be reviewed by both the Planning Department and Water Department.

The landscape and irrigation plans shall demonstrate compliance with all requirements of the City’s Water-Efficient Landscaping Ordinance in Chapter 16.16 of the Santa Cruz Municipal Code prior to issuance of the building permit.

16. All landscaping shall be installed prior to final utility release or issuance of occupancy permits.

17. All trees shall be a minimum 15-gallon size.

4.46 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx

18. Bike parking shall be provided in accordance with Section 24.12.250-252 of the City's Zoning Ordinance.

19. All utilities and transformer boxes shall be placed underground in accordance with the provisions of Section 24.12.700 through 24.12.740 of the Zoning Ordinance.

20. A drainage plan shall be submitted in conjunction with application for building permits.

21. Any person exercising a development permit or building permit who, at any time in the preparation for or process of excavating or otherwise disturbing earth, discovers any human remains of any age or any artifact or any other object which reasonably appears to be evidence of an archaeological/cultural resource or paleontological resource, shall:
a. Immediately cease all further excavation, disturbance, and work on the project site; b. Cause staking to be placed completely around the area of discovery by visible stakes not more than ten feet apart forming a circle having a radius of not less than one hundred feet from the point of discovery; provided, that such staking need not take place on adjoining property unless the owner of the adjoining property authorizes such staking; c. Notify the Santa Cruz County sheriff-coroner and the city of Santa Cruz planning director of the discovery unless no human remains have been discovered, in which case the property owner shall notify only the planning director; d. Grant permission to all duly authorized representatives of the sheriff-coroner and the planning director to enter onto the property and to take all actions consistent with this section.

22. Grading shall be done during periods of dry weather and protective measures shall be incorporated during grading to prevent siltation from any grading project halted due to rain.

23. Prior to site grading or any disturbance all trees and/or tree stands indicated for preservation or approved plans shall be protected through fencing or other approved barricade. Such fencing shall protect vegetation during construction and shall be installed to the satisfaction of the Director of Planning and Community Development.

24. All new mechanical equipment and appurtenances, including gas and water meters, electrical boxes, roof vents, air conditioners, antennas, etc. visible from the public way and from adjacent properties, shall be screened with material compatible with the materials of the building and shall be subject to the approval of the Zoning Administrator.

25. Final colors shall be approved by the Zoning Administrator prior to application for building permits.

26. The owner shall comply with the inclusionary housing requirements as outlined in Section

24.16.010 et seq. of the Zoning Ordinance. Specifically, two units shall be provided to low income households at an affordable rent. The inclusionary units shall be rented to qualifying assisted living tenants. An inclusionary unit may be rented to a qualifying independent living tenant in the event that a qualifying assisted living tenant is not available. Each inclusionary unit shall meet the definition of a dwelling unit per SCMC section 24.22.320, including a full kitchen. A Participation Agreement establishing compliance with inclusionary housing

4.47 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx requirements shall be entered into prior to building permit issuance and recorded prior to final occupancy of the first unit.

27. Construction activity resulting in a land disturbance of one acre or more, or less than one acre but part of a larger common plan of development or sale must obtain the Construction Activities Storm Water General Permit. Construction activity includes clearing, grading, excavation, stockpiling, and reconstruction of existing facilities involving removal and replacement. Construction activity does not include routine maintenance such as, maintenance of original line and grade, hydraulic capacity, or original purpose of the facility.

28. The applicant shall be responsible for filing a Notice of Intent (NOI) with the State Regional Water Quality Control Board (RWQCB) and for developing a Storm Water Pollution Prevention Plan (SWPPP) prior to commencement of any soil disturbing activities at the site.

Prior to issuance of a building permit, the applicant shall provide the City with proof of coverage under the state’s Construction Activities Storm Water General Permit, including a copy of the letter of receipt and Waste Discharger Identification (WDID) number issued by the State Regional Water Quality Control Board (SWQCB) that acknowledges the property owner’s submittal of a complete Notice of Intent (NOI) package.

29. Since the storm water BMP facility “SCM F” will be located on a separate adjacent parcel owned by Oblates of St. Joseph, the following shall be submitted to the City prior to issuance of the Building Permit:
a. Proof of a recorded land use agreement for the storm water BMP “SCM F” area including Watermark access and maintenance rights, and flow into the existing Oblates of St. Joseph storm drain line.
b. The recorded land use agreement shall be referenced on the Site Plan sheet, Sheet AS-100, and applicable Civil sheets including Sheet C1.1. If a final Lot Line Adjustment map, e.g. Sheet LLA1.0, is submitted with the Building Permit application, plans shall reference the land use agreement for the Watermark access and maintenance rights to the storm water BMP “SCM F” area. c. A signed Agreement between the Watermark Project and the Oblates of St.

Joseph regarding the storm water BMP “SCM F” area including Watermark access and maintenance rights. Since “SCM F” flows into an existing storm drain line on Church property, the Agreement shall include access and maintenance of that line from the point of connection to ensure that SCM F functions as designed long-term.
d. A drainage easement shall be recorded upon transfer of either Lot 1 or Lot 2 such that the owner of Lot 1 is not one and the same as the owner of Lot 2.

30. The property owner and/or project applicant agree(s) as a condition and in consideration of the approval of this discretionary development permit that it will, pursuant to agreement and/or statutory provisions as applicable, including but not limited to Government code Section 66474.9, defend, indemnify and hold harmless the City of Santa Cruz or its agents, officials, officers and employees from any claim, action or proceeding against the City or its agents, officials, officers or employees to attack, set aside, void or annul this approval, which action is brought within the time period provided for under law, including but not limited to,

4.48 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx Government Code Section 66499.37, as applicable. The property owner and/or project applicant will reimburse the City for any court costs and attorney’s fees, which the City may be required by a court to pay as a result of such action. City may, at its sole discretion, participate in the defense of such action; but such participation shall not relieve the property owner and/or project applicant of these obligations under this condition. An agreement to this effect shall be recorded upon demand of the City Attorney or concurrent with the issuance of building permits, use of the property, filing of the final map, whichever occurs first and as applicable. The City shall promptly notify the property owner and/or project applicant of any such claim, action or proceeding and the City shall cooperate fully in the defense thereof. If the City fails to promptly notify the property owner and/or project applicant of any such claim, action or proceeding or fails to cooperate fully in the defense thereof, the property owner and/or project applicant shall not thereafter be responsible to defend, indemnify or hold the City harmless.

31. Prior to the issuance of a building permit, the applicant shall pay the Park and Recreation Facility Tax pursuant to Chapter 5.72 of the City of Santa Cruz Municipal Code based on the final building permit plans.

32. The demolition permit to demolish the two school buildings shall be issued concurrently with the building permit for the new development consistent with section 24.08.1230 of the zoning ordinance.

33. Applicant shall implement all recommendations from the biotic report prepared by Ecosystems West Consulting Group dated April 28, 2022.

34. If project site work occurs anytime during the months of November through August, the applicant shall submit a pre-construction survey report by the project biologist prior to the start of work. The survey shall be completed as described in the biotic report prepared by Ecosystems West Consulting Group dated April 28, 2022, the survey shall be completed no more than seven days before the start of any project activities on the site and shall include observations of any nesting activities on the site. Site work may commence once the Planning Department has accepted the report and confirmed that there are no nesting birds on the site or that nesting birds are present and an appropriate buffer zone has been recommended by the biologist and physically established on the site.

35. Prior to the start of any project work on the site, the applicant shall submit a preconstruction roosting bat survey as described in the biotic report prepared by Ecosystems West Consulting Group dated April 28, 2022. If bats are found, the survey report shall include the appropriate measures described in the biotic report. These measures shall be implemented during project work.

36. The applicant shall follow all recommendations of the arborist report dated July 8, 2020 by Nigel Belton.

37. The applicant shall retain Nigel Belton as the project arborist to ensure the recommended measures from the report are implemented correctly. A change in project arborist shall require prior approval by the City Urban Forester.

4.49 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx

38. Final building permit plans shall show the new locations of the two heritage trees recommended by the arborist report for relocation. Applicant shall submit a review letter from the project arborist confirming approval of the new locations.

39. The applicant shall plant replacement trees at a ratio of two 24-inch box trees or six 15-gallon trees, or pay a comparable in lieu fee, as required by the City Urban Forester, for each heritage tree removed. If replacement trees are required, the final building permit plans shall include a replacement tree plan showing the number, size, species, and location of the replacement trees.

The plan shall be approved by the City Urban Forester prior to building permit approval.

40. Prior to building permit final, the applicant shall submit a follow up letter from the project arborist confirming that all recommendations from the arborist report have been implemented.

41. The following shall be shown on the final building permit plans:
 All windows shall be recessed at least three inches
 Window frames shall be stained wood or baked enamel aluminum.  Stucco shall be hard trowel smooth finish.
 The trash enclosure walls shall have stucco and color to match the building, and the trellisstyle roof shall be wood to match the trellis and covered walkway features throughout the site.
 The gate on the southwest side of the building shall be wood and the wall associated with the gate shall either be finished with stucco to match the building or shall be visually obscured with tall vines or other vegetation.
 All references to the second-story arched architectural feature at the front of the building shall show its height to be no more than 30 feet.
 Floorplans shall either show fireplaces on the floors directly below and connected to the chimney or shall omit the chimney feature.
 The height of the apparent wall feature within the front yard setback at the benches south of the meditation area next to memory care building shall be indicated and shall be no more than three and a half feet.
 The rooftop elevator enclosure shall have an exterior finish the same as the building.  Plans shall show the height of rooftop mechanical equipment and shall include sight lines to confirm whether the equipment is visible from the public right of way. Plans shall include any screening needed to shield the equipment from the pedestrian view. Color of such screening shall match the building color.
 Landscaping plans shall show plantings on the southern and western sides of the transformer with a height to screen the view of this equipment from the public right of way on Pelton Avenue. Plans shall indicate the number, species, and size of proposed plantings.  Landscape plans shall show plantings between the backflows and the sidewalk on Eucalyptus Avenue with a height to screen the view of this equipment from the public right of way. Plans shall indicate the number, species, and size of proposed plantings.  Landscape plans shall indicate the number, species, size, and location of proposed plants.  Site plan shall indicate the square footage available on Lot 1 for future development within the FAR limitation.

4.50 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx  Inclusionary units shall be designated as assisted living but may be rented to a qualifying independent living tenant if a qualifying assisted living tenant is not available.  The east-west pedestrian walkway adjacent to 112 Eucalyptus Avenue shall be omitted, and the landscape plan shall show this area fully landscaped.  An additional arbor shall be constructed over the four parking spaces at the northwest corner of the parking lot. The arbor shall either be a continuation of the arbor in front of the building or shall be separated from that arbor by at least six feet. The arbor design and materials shall match that of the arbor in front of the building.
 Building permit plans shall include visual screening on the west side of the balcony at unit 236. The screening shall extend the entire length of the western face of the balcony, shall reach a height of at least six feet from the floor of the balcony, and shall fully obscure the view to and from that side of the balcony. The screening shall be in the form of a continuation of the building wall finished the same as the building wall, or lattice and/or landscaping plants that create a fully obscure visual screen. Lattice shall be compatible with the exterior building materials and colors. If landscaping is used for screening, it shall be maintained in good condition to continuously provide full visual obscurity. Final landscaping plans shall show additional vegetation between the northeastern corner of 112 Eucalyptus Avenue and the southwestern corner of the balcony for unit 236. The additional vegetation shall have a mature height to contribute to visual screening between the balcony and 112 Eucalyptus Avenue.  Final building permit plans shall show how the project meets the bird-safe building design standards.
 Final building permit plans shall show the location, size, height, and content of signage at the Pelton Avenue exit prohibiting right turns onto Pelton and prohibiting the use of high beams until drivers are completely on eastbound Pelton Avenue.  Prior to building permit issuance, the applicant shall submit a review letter from the project biologist referring to the revision date of the final landscape plans and confirming that the new trees shown on the final landscape plan are located to avoid excess shading of monarch butterfly nectar resources.
 Final building permit plans shall show the location of an onsite water source, such as a fountain, for the monarchs near the nectar gardens.
 Final building permit plans shall include the permitted hours of construction consistent with Section 9.36 of the SCMC, on the front page of the plan set.

42. The approved project contains 13 dwelling units with kitchens as defined under zoning ordinance sections 24.22.320 and 24.22.272. Final building permit plans shall show sink dimensions and sink drain diameters, refrigerator sizes, and any other proposed appliances for each unit, including both the proposed dwelling units and units not proposed to meet the definition of dwelling unit. Units that do not meet the definition of dwelling unit shall not contain food preparation fixtures or appliances that would meet the definition of a kitchen. A change in the number of dwelling units would require approval of a permit to modify this approved permit, and all applicable standards, including, but not limited to, inclusionary housing requirements and general plan density limitations, shall apply.

43. Prior to building permit issuance, applicant shall submit a copy of the lease agreement for new tenants. The lease agreement shall include language limiting the size and number of appliances for the units that are not considered dwelling units to ensure they do not meet the

4.51 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx definitions of a dwelling unit with kitchen under zoning ordinance sections 24.22.320 and

24.22.372.

44. Applicant shall submit a window sample and a 10’ x 10’ on-site stucco mock-up for review and approval by Planning staff prior to building permit issuance.

45. Pursuant to Section 66412(d) of the California Government Code the following requirements have been imposed in order for the lot-line adjustment to conform with the City's Zoning and Building Ordinances, or to facilitate the relocation of existing utilities, infrastructure, or easements:
 The lot line adjustment shall be recorded as a sequential lot line adjustment, with each lot line adjustment involving no more than four lots;
 For each sequential lot line adjustment, a new property description shall be recorded with the County Recorder's office and a copy of the recorded description provided to the City Planning Department. The deed(s) of conveyance must contain the following statement after the description of the property(ies) or portion(s) of property to be transferred:
"The purpose of the deed is to adjust the boundary between Lots [insert lots here] as approved by the City of Santa Cruz under Application CP20-0068. This conveyance may not create a separate parcel and is null and void unless the boundary is adjusted as stated."

46. The sequential lot line adjustment shall be recorded prior to application of any demolition, grading, or building permit.

47. Prior to approval of any demolition, grading, or building permit, the applicant shall record in the Santa Cruz County Recorder’s office a land use agreement requiring:
 That commercial deliveries be allowed to take access to and from the site via the West Cliff Drive entrance on and driveway across Lot 1,
 That refuse service vehicles be allowed to take access from the West Cliff Drive entrance on and driveway across Lot 1,
 That access is allowed for the project operator to benefit from, operate, maintain, and repair stormwater treatment and drainage facilities on Lot 1,  That an easement for commercial and refuse service vehicles be recorded upon transfer of either Lot 1 or Lot 2 such that the owner of Lot 1 is not one and the same as the owner of Lot 2.

48. Prior to approval of any demolition, grading, or building permit, the applicant shall execute and record in the Santa Cruz County Recorder’s office a covenant or deed restriction, to the satisfaction of the City Attorney, documenting that allowable density shall be calculated across the entire Project site (Lot 1 and Lot 2), and notifying any future owners that development potential shall be shared between Lot 1 and Lot 2 and that any additional remaining density below the otherwise maximum allowable Floor Area Ratio for the site shall be allocated to Lot 1.

49. Prior to approval of any demolition, grading, or building permit, the applicant shall execute and record in the Santa Cruz County Recorder’s office a covenant or deed restriction, to the

4.52 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx satisfaction of the City Attorney, documenting the remaining floor area square footage available for development on Lot 1. The square footage shall be calculated as the total remaining square footage available within the allowed Floor Area Ratio for the entire site when counting existing construction on Lot 1 and the approved Project on Lot 2.

50. Final building permit plans shall include as-built drawings for all existing buildings on Lot 1 to precisely calculate the remaining square footage available for development within the Floor Area Ratio limitation.

51. Prior to installing the wall sign shown as S03 on the plans, applicant shall obtain a Sign Permit for the proposed wall sign and a building permit to install the sign.

52. Prior to building permit application, applicant shall pay any outstanding fees due for this permit.

53. Applicant shall plant the proposed landscaping trees adjacent to the northern and eastern property lines of 112 Eucalyptus Avenue as early as practicable during the construction cycle.

54. Prior to the demolition of any building, applicant shall complete any testing and removal of asbestos and lead-based paint as required by MBARD. If asbestos and lead-based paint removal requires demolition of the building, the demolition permit shall not be issued until the building permit is sufficiently ready to issue, as determined by the Director of Planning and Community Development.

55. Construction activities shall be in conformance with Chapter 9.36 of the Municipal Code (Noise). Prior to the start of site work, applicant shall notify the neighbors of work schedules and provide a contact and process for neighbors to submit complaints regarding noise.

56. Operational conditions:
 Based on the approved number of parking spaces, the number of employees on site at any given time shall not exceed 21. An increase in the number of employees on the site at a given time shall require approval of a modification to this permit and include an updated site plan to accommodate the increased parking requirement.  Prior to issuance of a building permit, the applicant, in conjunction with the property owner, shall submit a maintenance and management plan to address potential nuisance impacts associated with interior/exterior areas adjacent to the tenant space outlining measures to address trash/litter removal, graffiti, landscape maintenance, abandoned vehicles, noise and loitering, subject to approval by the Zoning Administrator.  The management plan shall assign a “Neighbor Liaison” staff to provide a single point of contact between the community care facility and neighbors.  The use shall operate in conformance with Chapter 9.36 and section 24.14.260 of the Municipal Code.
 Any Public/Major Special Events on the premises shall be conducted in accordance with Chapter 10.64 of the Municipal Code, with requisite permit applications being filed in accordance with the timelines outlined therein.

4.53 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx  Unless otherwise authorized by the City, all parking spaces shall be continuously maintained on the site in a condition that allows access by customers and employees of the use.
 Prior to occupancy of the tenant space, the applicant shall file a trespass letter with the Santa Cruz Police Department (SCPD) in accordance with Santa Cruz Municipal Code section 9.60.012 providing SCPD the authority to remove trespassers on the premises when closed to the public.
 Final building plans shall include security alarms for the building that include motion activation and manual activation capabilities.
 Final building plans shall include exterior security lights that provide 360-degree coverage around the perimeter of all buildings while meeting the performance standards in the Zoning Ordinance.
 Final building plans shall include exterior security cameras that provide 360-degree coverage around the perimeter of all egress and ingress into the building. The security camera system shall have the capability to provide the recordings to police within 24 hours. In addition to the exterior security cameras, cameras need to be installed within the business itself and shall cover the doors and windows.  Prior to occupancy, the applicant shall obtain a Zoning Clearance from the Planning Department and a Business License from the Finance Department.  This use permit shall run with the land and shall be transferrable to a subsequent property owner or tenant upon confirmation that the subsequent use is in substantial compliance with the original use as verified through issuance of a Zoning Clearance.  This use permit shall expire and become void if the use has ceased for a period of six consecutive months, whether or not it is the intent to abandon said use.  Except for the stairs leading to the rooftop deck, all stairs leading to the roof shall be locked and accessible by staff only.
 The cafeterias/bar/cafe shall not be open to the public.  Prior to occupancy, install signage to prohibit right-turns out of the Pelton Avenue driveway to divert outbound trips east of the existing monarch butterfly grove and avoid casting vehicle headlight glare into the grove. Such signage shall be maintained in good condition.
 Install and maintain signage prohibiting high beams until drivers are completely on eastbound Pelton Avenue.
 As part of their service request, the operator of the facility shall notify each commercial delivery entity that is either delivering or picking up items at the site to utilize the West Cliff Drive driveway through the church property for ingress/egress to the site. Said notification shall be in writing, and documentation shall be provided to the City upon request. Each agreement with clients who reside at the facility shall require that said clients similarly notify delivery companies should they order deliveries/pick-ups or should others order deliveries/pick-ups on their behalf. Prior to occupancy, signage shall be placed at the Pelton Avenue driveway indicating that commercial deliveries are to use the West Cliff Drive driveway for ingress and egress to/from the site.

4.54 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_clean.docx  All exterior project lighting, including security lighting, shall be shielded to contain the light source in a downward direction and avoid glare and illumination of adjacent properties and monarch butterfly grove at Lighthouse Field.  Provide and maintain an onsite water source, such as a fountain, for the monarchs near the nectar gardens.
 Install and maintain predator proof waste bins.
 Eliminate populations of yellow jackets, eastern grey squirrels and rats on the property utilizing non-toxic methods.
 Restrict use of seed feeders that attract eastern grey squirrels and corvids.  Utilize leaf vacuums instead of blowers during maintenance operations.  Prohibit the use of neonicotinoids and other pesticides known to negatively impact monarchs.

57. The facility may hold no more than six special events per year that result in staffing levels greater than the limit imposed in these conditions. Prior to building permit final, the applicant shall record in the Santa Cruz County Recorder’s Office a land use agreement describing an off-site parking and transportation plan to accommodate additional vehicle trips associated with these events.

58. To the extent permitted by the Department of Public Works and the Fire Department, a more substantial traffic control device shall be installed to prevent vehicles from making a right turn when exiting the facility onto Pelton Avenue. The device shall be included on final building permit plans.

59. Prior to building permit issuance, the applicant shall consult with a butterfly ecologist in preparing the landscaping and lighting plans to make every effort to make the landscape and lighting support a thriving monarch butterfly population. Plans shall be reviewed and approved by planning staff during building permit review.

60. Final building permit plans shall include a survey of the City Sanitary Sewer Main located on the Northern side of the project to avoid any conflicts with any of the project’s facilities or structures. This sanitary sewer line must retain accessibility at all times for maintenance and repairs. If the sanitary sewer is located within 5’ of the northern property line then the applicant shall grant a new utility easement to the City of Santa Cruz, which shall be recorded prior to building permit issuance. Final building permit plans shall locate all proposed structures outside said easement or otherwise propose construction of such structures in a manner consistent with the requirements of the Public Works Department.

4.55 EXHIBIT "A"

1. If one or more of the following conditions is not met with respect to all its terms, then this approval may be revoked.

2. All plans for future construction which are not covered by this review shall be submitted to the City Planning and Community Development Department for review and approval.

5. The use shall meet the standards and shall be developed within limits established by Chapter

4.56 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx submitted for building permits. I hereby acknowledge that failure to construct the building as represented in the building permit plans, may result in delay of the inspections process and/or the mandatory reconstruction or alteration of any portion of the building that is not in substantial conformance with the approved plans, prior to continuation of inspections or the building final.”
Signature of Building Contractor Date

10. All refuse and recycling activities during construction shall be done in accordance with Chapter

11. All requirements of the Building, Fire, Public Works, Housing, and Water Departments shall be completed prior to occupancy and continuously maintained thereafter.

13. Plans submitted for building permit issuance shall include electric vehicle charging stations as required per Section 24.12.241 of the Zoning Ordinance.

15. Landscape and irrigation plans shall be submitted at the time of the building permit application and will be reviewed by both the Planning Department and Water Department.

16. All landscaping shall be installed prior to final utility release or issuance of occupancy permits.

17. All trees shall be a minimum 15-gallon size.

4.57 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx

18. Bike parking shall be provided in accordance with Section 24.12.250-252 of the City's Zoning Ordinance.

19. All utilities and transformer boxes shall be placed underground in accordance with the provisions of Section 24.12.700 through 24.12.740 of the Zoning Ordinance.

20. A drainage plan shall be submitted in conjunction with application for building permits.

22. Grading shall be done during periods of dry weather and protective measures shall be incorporated during grading to prevent siltation from any grading project halted due to rain.

25. Final colors shall be approved by the Zoning Administrator prior to application for building permits.

26. The owner shall comply with the inclusionary housing requirements as outlined in Section

24.16.010 et seq. of the Zoning Ordinance. Specifically, two units shall be provided to low income households at an affordable rent. The inclusionary units shall be either rented to qualifying assisted living tenants., An inclusionary unit may be rented to a qualifying independent living tenant in the event that a qualifying assisted living tenant is not available., or staff housing, and eEach inclusionary unit shall meet the definition of a dwelling unit per SCMC section 24.22.320, including a full kitchen. A Participation Agreement establishing

4.58 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx compliance with inclusionary housing requirements shall be entered into prior to building permit issuance and recorded prior to final occupancy of the first unit.

4.59 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx Government Code Section 66499.37, as applicable. The property owner and/or project applicant will reimburse the City for any court costs and attorney’s fees, which the City may be required by a court to pay as a result of such action. City may, at its sole discretion, participate in the defense of such action; but such participation shall not relieve the property owner and/or project applicant of these obligations under this condition. An agreement to this effect shall be recorded upon demand of the City Attorney or concurrent with the issuance of building permits, use of the property, filing of the final map, whichever occurs first and as applicable. The City shall promptly notify the property owner and/or project applicant of any such claim, action or proceeding and the City shall cooperate fully in the defense thereof. If the City fails to promptly notify the property owner and/or project applicant of any such claim, action or proceeding or fails to cooperate fully in the defense thereof, the property owner and/or project applicant shall not thereafter be responsible to defend, indemnify or hold the City harmless.

33. Applicant shall implement all recommendations from the biotic report prepared by Ecosystems West Consulting Group dated April 28, 2022.

36. The applicant shall follow all recommendations of the arborist report dated July 8, 2020 by Nigel Belton.

4.60 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx

The plan shall be approved by the City Urban Forester prior to building permit approval.

40. Prior to building permit final, the applicant shall submit a follow up letter from the project arborist confirming that all recommendations from the arborist report have been implemented.

41. The following shall be shown on the final building permit plans:
 All windows shall be recessed at least three inches
 Window frames shall be stained wood or baked enamel aluminum.  Stucco shall be hard trowel smooth finish.
 The trash enclosure walls shall have stucco and color to match the building, and the trellisstyle roof shall be wood to match the trellis and covered walkway features throughout the site.
 The gate on the southwest side of the building shall be wood and the wall associated with the gate shall either be finished with stucco to match the building or shall be visually obscured with tall vines or other vegetation.
 All references to the second-story arched architectural feature at the front of the building shall show its height to be no more than 30 feet.
 The rooftop trellis shall be omitted from the plans.
 Floorplans shall either show fireplaces on the floors directly below and connected to the chimney or shall omit the chimney feature.
 The height of the apparent wall feature within the front yard setback at the benches south of the meditation area next to memory care building shall be indicated and shall be no more than three and a half feet.
 The rooftop elevator enclosure shall have an exterior finish the same as the building.  Plans shall show the height of rooftop mechanical equipment and shall include sight lines to confirm whether the equipment is visible from the public right of way. Plans shall include any screening needed to shield the equipment from the pedestrian view. Color of such screening shall match the building color.
 Landscaping plans shall show plantings on the southern and western sides of the transformer with a height to screen the view of this equipment from the public right of way on Pelton Avenue. Plans shall indicate the number, species, and size of proposed plantings.  Landscape plans shall show plantings between the backflows and the sidewalk on Eucalyptus Avenue with a height to screen the view of this equipment from the public right of way. Plans shall indicate the number, species, and size of proposed plantings.  Landscape plans shall indicate the number, species, size, and location of proposed plants.  Site plan shall indicate the square footage available on Lot 1 for future development within the FAR limitation.

4.61 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx  Inclusionary units shall be designated as either independent living, assisted living but may be rented to a qualifying independent living tenant if a qualifying assisted living tenant is not available., or staff housing.
 The east-west pedestrian walkway adjacent to 112 Eucalyptus Avenue shall be omitted, and the landscape plan shall show this area fully landscaped.  An additional arbor shall be constructed over the four parking spaces at the northwest corner of the parking lot. The arbor shall either be a continuation of the arbor in front of the building or shall be separated from that arbor by at least six feet. The arbor design and materials shall match that of the arbor in front of the building.
 Building permit plans shall include visual screening on the west side of the balcony at unit 236. The screening shall extend the entire length of the western face of the balcony, shall reach a height of at least six feet from the floor of the balcony, and shall fully obscure the view to and from that side of the balcony. The screening shall be in the form of a continuation of the building wall finished the same as the building wall, or lattice and/or landscaping plants that create a fully obscure visual screen. Lattice shall be compatible with the exterior building materials and colors. If landscaping is used for screening, it shall be maintained in good condition to continuously provide full visual obscurity. Final landscaping plans shall show additional vegetation between the northeastern corner of 112 Eucalyptus Avenue and the southwestern corner of the balcony for unit 236. The additional vegetation shall have a mature height to contribute to visual screening between the balcony and 112 Eucalyptus Avenue.  Final building permit plans shall show how the project meets the bird-safe building design standards.
 Final building permit plans shall show the location, size, height, and content of signage at the Pelton Avenue exit prohibiting right turns onto Pelton and prohibiting the use of high beams until drivers are completely on eastbound Pelton Avenue.  Prior to building permit issuance, the applicant shall submit a review letter from the project biologist referring to the revision date of the final landscape plans and confirming that the new trees shown on the final landscape plan are located to avoid excess shading of monarch butterfly nectar resources.
 Final building permit plans shall show the location of an onsite water source, such as a fountain, for the monarchs near the nectar gardens.
 Final building permit plans shall include the permitted hours of construction consistent with Section 9.36 of the SCMC, on the front page of the plan set.

43. Prior to building permit issuance, applicant shall submit a copy of the lease agreement for new tenants. The lease agreement shall include language limiting the size and number of

4.62 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx appliances for the units that are not considered dwelling units to ensure they do not meet the definitions of a dwelling unit with kitchen under zoning ordinance sections 24.22.320 and

24.22.372.

44. Applicant shall submit a window sample and a 10’ x 10’ on-site stucco mock-up for review and approval by Planning staff prior to building permit issuance.

46. The sequential lot line adjustment shall be recorded prior to application of any demolition, grading, or building permit.

47. Prior to approval of any demolition, grading, or building permit, the applicant shall record in the Santa Cruz County Recorder’s office a land use agreement requiring:
 That commercial deliveries be allowed to take access to and from the site via the from West Cliff Drive entrance on and driveway across Lot 1,  That refuse service vehicles be allowed to take access from the West Cliff Drive entrance on and driveway across Lot 1,
 That access is allowed for the project operator to benefit from, operate, maintain, and repair to stormwater treatment and drainage facilities on Lot 1 for maintenance and repair purposes,
 That an easement for commercial and refuse service vehicles be recorded upon transfer of either Lot 1 or Lot 2 such that the owner of Lot 1 is not one and the same as the owner of Lot 2.

4.63 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx

49. Prior to approval of any demolition, grading, or building permit, the applicant shall execute and record in the Santa Cruz County Recorder’s office a covenant or deed restriction, to the satisfaction of the City Attorney, documenting the remaining floor area square footage available for development on Lot 1. The square footage shall be calculated as the total remaining square footage available within the allowed Floor Area Ratio for the entire site when counting existing construction on Lot 1 and the approved Project on Lot 2.

51. Prior to installing the wall sign shown as S03 on the plans, applicant shall obtain a Sign Permit for the proposed wall sign and a building permit to install the sign.

52. Prior to building permit application, applicant shall pay any outstanding fees due for this permit.

53. Applicant shall plant the proposed landscaping trees adjacent to the northern and eastern property lines of 112 Eucalyptus Avenue as early as practicable during the construction cycle.

4.64 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx  Any Public/Major Special Events on the premises shall be conducted in accordance with Chapter 10.64 of the Municipal Code, with requisite permit applications being filed in accordance with the timelines outlined therein.
 Unless otherwise authorized by the City, all parking spaces shall be continuously maintained on the site in a condition that allows access by customers and employees of the use.
 Prior to occupancy of the tenant space, the applicant shall file a trespass letter with the Santa Cruz Police Department (SCPD) in accordance with Santa Cruz Municipal Code section 9.60.012 providing SCPD the authority to remove trespassers on the premises when closed to the public.
 Final building plans shall include security alarms for the building that include motion activation and manual activation capabilities.
 Final building plans shall include exterior security lights that provide 360-degree coverage around the perimeter of all buildings while meeting the performance standards in the Zoning Ordinance.
 Final building plans shall include exterior security cameras that provide 360-degree coverage around the perimeter of all egress and ingress into the building. The security camera system shall have the capability to provide the recordings to police within 24 hours. In addition to the exterior security cameras, cameras need to be installed within the business itself and shall cover the doors and windows.  Prior to occupancy, the applicant shall obtain a Zoning Clearance from the Planning Department and a Business License from the Finance Department.  This use permit shall run with the land and shall be transferrable to a subsequent property owner or tenant upon confirmation that the subsequent use is in substantial compliance with the original use as verified through issuance of a Zoning Clearance.  This use permit shall expire and become void if the use has ceased for a period of six consecutive months, whether or not it is the intent to abandon said use.  Except for the stairs leading to the rooftop deck, all stairs leading to the roof shall be locked and accessible by staff only.
 The cafeterias/bar/cafe shall not be open to the public.  Prior to occupancy, install signage to Pprohibit right-turns out of the Pelton Avenue driveway to divert outbound trips east of the existing monarch butterfly grove and avoid casting vehicle headlight glare into the grove. Such signage shall be maintained in good condition.
 Install and maintain signage prohibiting high beams until drivers are completely on eastbound Pelton Avenue.
 As part of their service request, the operator of the facility shall notify each commercial delivery entity that is either delivering or picking up items at the site to utilize the West Cliff Drive driveway through the church property for ingress/egress to the site. Said notification shall be in writing, and documentation shall be provided to the City upon request. Each agreement with clients who reside at the facility shall require that said clients similarly notify delivery companies should they order deliveries/pick-ups or should others order deliveries/pick-ups on their behalf. Prior to occupancy, signage shall be placed at the Pelton Avenue driveway indicating that commercial deliveries are to use

4.65 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx the West Cliff Drive driveway for ingress and egress to/from the site. All commercial deliveries shall use the West Cliff driveway for entering and exiting the site at all times.  All exterior project lighting, including security lighting, shall be shielded to contain the light source in a downward direction and avoid glare and illumination of adjacent properties and monarch butterfly grove at Lighthouse Field.  Provide and maintain an onsite water source, such as a fountain, for the monarchs near the nectar gardens.
 Install and maintain predator proof waste bins.
 Eliminate populations of yellow jackets, eastern grey squirrels and rats on the property utilizing non-toxic methods.
 Restrict use of seed feeders that attract eastern grey squirrels and corvids.  Utilize leaf vacuums instead of blowers during maintenance operations.  Prohibit the use of neonicotinoids and other pesticides known to negatively impact monarchs.

59. The solar panel trellis shall be retained on building permit plans; Condition 42, point 7 regarding removal of the trellis shall be deleted.

60. The Planning Commission determines, based on substantial evidence, that the project includes congregate living units or assisted living units, and the following alternative requirements shall apply: 15% of congregate care or assisted living units shall be made available at affordable rent to low income households.

59. 61. Prior to building permit issuance, Tthe applicant shall consult with a butterfly ecologist in preparing the landscaping and lighting plans to make every effort to make the landscape and lighting support a thriving monarch butterfly population. Plans shall be reviewed and approved by planning staff during building permit review.

4.66 CONDITIONS OF APPROVAL
For 126 Eucalyptus Ave – CP20-0068
P:\_Public\PACKETS\2022\CC\11-29-22\126 Eucalyptus\Exhibit A Conditions of Approval_redline.docx proposed structures outside said easement or otherwise propose construction of such structures in a manner consistent with the requirements of the Public Works Department.

4.67 FRM ENV-04 1 (Rev. 5/09)

CITY OF SANTA CRUZ
Notice of Exemption
To:  Clerk of the Board Office of Planning and Research County of Santa Cruz 1400 Tenth Street, Room 121
Governmental Center Sacramento, CA 95814
701 Ocean Street
Santa Cruz, CA 95060
From: City of Santa Cruz, Planning Dept., 809 Center Street, Room 206, Santa Cruz, CA 95060 Project Title: The Watermark at Santa Cruz
Project Address: 126 Eucalyptus Avenue
Assessor's Parcel No.: 004-571-02 and 004-571-04
Project Location: City of: Santa Cruz – see Figure 1. County of: Santa Cruz Project Description: The proposed project consists of a Non-Residential Demolition Authorization Permit, Lot Line Adjustment, Special Use Permit, Coastal Permit, Design Permit, and Historic Alteration Permit to reconfigure two APN parcels (five lots) into two lots, demolish two existing former school buildings, and construct a 76-unit senior housing facility that includes 59 assisted living units (with 76 beds), 15 memory care units (with 19 beds), and two inclusionary units (one studio and one 1-bedroom unit). Of the 59 assisted living units, 11 would be equipped with full kitchens; both of the inclusionary units also would have full kitchens and would be required to be either independent living, assisted living, or staff housing as a condition of approval. The facility would be constructed within two buildings with resident services, including dining, cafe/bar, lounge, multi-purpose, fitness, salon, office, and lobby.

The project also includes a proposed sequential lot line adjustment reconfiguring five existing lots into two that comprise the 6.97-acre site. Lot 1 would consist of a 3.97-acre parcel which would retain five existing buildings. Lot 2 would consist of a 3-acre parcel that would include the proposed senior housing facility. The only improvements to Lot 1 are addition of eight parking stalls, relocation of an existing meditation garden, and a new access driveway to be connected through Lot 2 off Pelton Avenue. No new structures would be built on Lot 1. Although the project site is 6.9 acres in size, the development area, including the limited changes made to Lot 1, would consist of only three acres.

Name of Person or Agency Carrying Out Project: Roger Bernstein Name of Public Agency Approving Project: City of Santa Cruz Exempt Status: (check one)
Ministerial Project (Section 21080(b)(1); 15268).
____ Statutory Exemption (Code/Section 21083.3).
____ Categorically Exempt (Section 15305 and Section 15332).

Declared Emergency (Section 21080(b)(3); 15269(a)).

Emergency Project (Section 21080(b)(4); 15269(b)(c)).

The project clearly will not have a significant effect on the environment (15061(b)(3)).

4.68 FRM ENV-04 2 (Rev. 5/09)
Reasons why project is exempt: The project has been determined to be exempt from the California Environmental Quality Act (CEQA) under a Statutory Exemption pursuant to Public Resources Code Section 21083.3 and State CEQA Guidelines Section 15183 (Projects Consistent with General Plan, Community Plan or Zoning) and pursuant to CEQA Guidelines Sections 15305 (Minor Alternations in Land Use Limitations) and 15332 (Categorical Exemption, Class 32, Infill Development Projects) as explained below.

Statutory Exemption – Public Resources Code Section 21083.3. The California Environmental Quality Act (CEQA) allows a lead agency to avoid repeating analyses that were already provided in a certified General Plan EIR (Public Resources Code Section 21083.3) for projects that are consistent with the General Plan for which an EIR was certified. Pursuant to section 21083.3(b), if a development project is consistent with the general plan of a local agency for which an environmental impact report was certified, the application of CEQA shall be limited to effects on the environment which are “peculiar to the parcel or to the project” and which were not addressed as significant effects in the prior environmental impact report, or which substantial new information shows will be more significant than described in the prior environmental impact report. Subsection (d) further indicates that an effect of a project upon the environment shall not be considered “peculiar to the parcel or to the project,” “if uniformly applied development policies or standards” have been previously adopted by the city or county, with a finding based upon substantial evidence, which need not include an environmental impact report, that the development policies or standards will substantially mitigate that environmental effect when applied to future projects, unless substantial new information shows that the policies or standards will not substantially mitigate the environmental effect.” CEQA Guidelines section 15183, subdivision (f), adds that “[w]here a city or county, in previously adopting uniformly applied development policies or standards for imposition on future projects, failed to make a finding as to whether such policies or standards would substantially mitigate the effects of future projects, the decision-making body of the city or county, prior to approving such a future project pursuant to this section, may hold a public hearing for the purpose of considering whether, as applied to the project, such standards or policies would substantially mitigate the effects of the project.” Under these provisions of CEQA, a project that is consistent with a General Plan that was adopted pursuant to a certified EIR, could be potentially partially or wholly exempt from CEQA.

Section 15183 of the State CEQA Guidelines provides further guidance related to Public Resources Code section 21083. Specifically, if a project is consistent with an agency’s General Plan for which an EIR has been certified, the agency shall limit its examination of environmental effects to those which the agency determines, in an initial study or other analysis:
(1) Are peculiar to the project or the parcel on which the project would be located, (2) Were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan, with which the project is consistent, (3) Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action, or
(4) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to

4.69 FRM ENV-04 3 (Rev. 5/09)
have a more severe adverse impact than discussed in the prior EIR. (State CEQA Guidelines section 15183(b).)
CEQA Guidelines section 15183, subdivision (c) further provides that “if an impact is not peculiar to the parcel or to the project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards,…, then an additional EIR need not be prepared for the project solely on the basis of that impact.” On June 26, 2012, the Santa Cruz City Council adopted the General Plan 2030 after certifying an EIR for the plan. The General Plan 2030 EIR (April 2012) includes the Draft EIR volume (September 2011) and the Final EIR volume (April 2012). The General Plan EIR reviewed all of the topics included on the Appendix G Environmental Checklist in the State CEQA Guidelines.

Santa Cruz City CouncilNovember 29, 2022

Santa Cruz City Council
November 29, 2022