Will extensions leave town thirsty?
On Wednesday, Feb. 11, the Mammoth Lakes Planning Commission granted Ward Jones’s Holiday Haus project a time extension request (the use-permit is now good until 2016). It did so despite a comment submitted by the Mammoth Community Water District (MCWD)which gave all the commissioners reason for pause.
MCWD warns (and the full text of the letter appears later in this article) that if the Town continues to approve projects at densities greater than anticipated by the General Plan, MCWD may be forced into initiation of costly infrastructure improvements.
As MCWD board member Gordon Alper said Thursday, “For some time, the Water District didn’t pay attention to what the Town was doing with respect to density.”
That clearly has changed.
“The big thing,” said Alper, “is that the sewer system won’t be able to handle it [the increased density] … we’ve been told that the sewer main on Main Street won’t be able to handle the volume of effluent if the Village builds out to approved density … and the Dempsey corner (at Main and Minaret) hasn’t even been added to the mix yet.
They’re heading far beyond the [52,000] buildout density [in the General Plan,” concluded Alper.
Fellow Board member Tom Cage added, “The Board doesn’t want to go back to rate increases for connection fees, but if they [the Town] keep granting these approvals [for density above what was contemplated in the General Plan] we may have no choice.
We’re trying to drill home the point that it’s [water] not an unlimited resource.”
Planning Commissioner Tony Barrett said a key legal question is whether or not the granting of a use-permit guarantees a developer water rights
Any future Holiday Haus project is subject to conditions outlined by future ordinances as well as any building permit conditions imposed by the Planning Commission.
Now the MCWD letter, sent to Jen Daugherty in the Town’s Community Development Dept. by Irene Yamashita, MCWDs Public Affairs and Environmental Specialist.
Dear Ms. Daugherty:
Thank you for the opportunity to comment on the request for a time extension for Holiday Haus.
Meeting water demand
The Water District’s 2005 Urban Water Management Plan (UWMP) describes a projected water shortafge under multiple dry-year conditions as the town approaches build-out. The UWMP applied the Holiday Haus site past water use to project future water demand for this site. To my knowledge, there has not been a comparison of the site’s historic water demand against projected demand from the new development. Until this is completed, the degree of change in water demand is unknown. It is possible that changes in technology for water fixtures could result in little to no change to the site’s water demand. The District is investing in increasing water supplies to help offset future demands; however, reducing demand is an effective method. Therefore, the District strongly encourages the Town to require the installation of water-efficient appliances and fixtures which meet or exceed the U.S. EPA (Environmental Protection Agency) Watersense program guidelines.
The District sent the Town a letter (May 23, 2008) stating water supplies and wastewater capacity is available for the development of the project. Please note, the letter cautions the availability of both services are provided on a “first-come, first-served basis and only to the extent that there is then remaining available water supply and capacity in the physical facilities needed to provide water and sewer service to the proposed development …”
In addition, the District recommends provisions in the Town’s soon-to-be-adopted revised landscape ordinance and anticipated revised State plumbing codes are included as conditions of granting a time extension.
Sewer infrastructure
The sewer infrastructure is currently adequate for this project; however, future developments that do not comport with the zoning maps contained in the TOML 2005 General Plan Update could create problems with projected infrastructure improvements. Therefore, the Town should insure that at the time of construction, the necessary wastewater infrastructure to service the project is in place prior to occupancy of any buildings.
Implementation of mitigation
The District requests clarification on how the General Plan and the Project mitigation measures are intended to be implemented to address cumulative water supply impacts.
The General Plan EIR includes the mitigation measure 4.11-1, which requires:
“The Town shall not approve new development applications that would result in a water demand in excess of available supplies based on the multiple drought year scenario … the Town shall work with MCWD (Mammoth Community Water District) to ensure that land-use approvals are phased in tandem with the development of necessary water supply sources. This shall be made a policy of the updated General Plan.
The General Plan EIR mitigation measure is applied in the context of buildout conditions and not an undetermined intermediate planning horizon … the water supply mitigation measure for the [Holiday Haus] project reflects the General Plan mitigation measure but is less specific about the scenario of projected water supply availability …
The District has commented on five proposed projects since late 2008. Three of the proposed projects at least double the densities described in the General Plan EIR that the District used as the basis for future water supply planning. The current process does not address cumulative impacts in a reasonable manner. Therefore, the District’s resource projections are based on a “moving target” of land-use plans.
Water supply development
The District has been successful at constructing the necessary infrastructure to supply a limited amount (400 acre feet) of recycled water and developed a new groundwater production well since the UWMP was completed. This new production well was necessary as a backup well to ensure the reliability of our current groundwater supply and should not be considered as increasing net current groundwater supplies/. These and any future supply and infrastructure improvements are based on meeting the demand projections of the 2005 UWMP … so they do not reflect net increase in demand that may add to forecasted supply shortages.
