1 Xavier Mota
From: Marc Verville <[email protected]>
Sent: Saturday, October 7, 2023 6:03 PM
To: Gleam Davis; Caroline Torosis; Jesse Zwick; Phil Brock; Oscar de la Torre; Christine Parra; Lana Negrete
Cc: councilmtgitems
Subject: SMCC 10-10-2023 Item 10.D. - Introduction and First Reading of Water and Wastewater Capacity Study Ordinances
EXTERNAL
Dear City Council,
The staff report for this item does not menƟon any process to incorporate pending state water usage cutbacks that will be especially substanƟal in Southern California.
The AssociaƟon of California Water Agencies’ (ACWA) “Making ConservaƟon a California Way of Life” (MCACWOL) program implemented under the 2018 statutes AB 1668 and SB 606, would require urban retail water suppliers to meet an agency‐specific urban water use objecƟve starƟng in 2025. In total, about 80% of water agencies in California will be forced to cut back within the next 12 years, according to state esƟmates. It is esƟmated that larger proporƟonal cuts will be required in Southern California, where a drier climate generally yield greater water use. In some cases in the state, reducƟons of more than 50% will be mandated by 2035.
This means that the City’s Water Neutrality ordinance will require ongoing adjustment to account for the state‐mandated cuts. Cuts to Citywide usage to comply with the MCACWOL program will severely restrict, if not eliminate, the amount of water available for incremental new developments. And these cuts will be phased in over Ɵme, compounding the problem of meeƟng the new lower standards as thousands of new housing units hit the city every year. None of these issues are addressed in the staff report.
Moreover, the DraŌ Ordinance ‐ SMMC 7.04.880 Wastewater Capacity Study notes in §1.g.ii ExempƟons that if the requirements would stop development, then it can be approved regardless under “hardship”. This effecƟvely negates any developer restricƟons.
Since the city has not objected to the nominal RHNA allocaƟon of 8,895 units, and since an overwhelming number of projects are being approved with an effecƟve 10% inclusionary rate, the actual number of units being contemplated by the city is 50,000 or more. Water neutrality will be impossible by definiƟon. ExisƟng residents will be required to substanƟally subsidize development’s impact on water demands by even steeper cuts than the state mandates.
ITEM 10.D.
October 10, 2023
ITEM 10.D.
October 10, 2023
2 The absence of mechanisms in this item to address both the coming mandated state reducƟons and the effecƟve number of units the city is effecƟvely approving makes no sense.
This item must be reworked to provide clarity on how these significant risk issues will be addressed.
Respecƞully,
Marc Verville
Sunset Park
ITEM 10.D.
October 10, 2023
ITEM 10.D.
October 10, 2023