When addressing formal comments to local jurisdictions, state agencies usually adopt a certain tone. It is formal, courteous, and rife with helpful suggestions and supportive statements of hopeful collaboration.
When it comes to development proposals in Cambria and the question of how water will be found to serve those developments, there was once a time when the California Coastal Commission addressed the county of San Luis Obispo in that manner. That was a long time ago.
For the reason why, one need look no further than the commission's Oct. 8, 2020, staff report on the appeal of SLO County's decision to grant a permit for "construction of a 2,170-square-foot two-story single-family residence with a 540-square-foot attached garage, and other site improvements on a 13,220-square-foot vacant parcel in the community of Cambria."
Herewith, one of the introductory paragraphs from the report ("LCP" refers to the Local Coastal Plan, the policies by which the county implements the California Coastal Act) (italics are in the original document):
"The county's action raises substantial LCP water resource and sensitive habitat issues because: (1) the county did not determine that there was an adequate sustainable water supply to serve the project, as is required by the LCP, but rather relied solely on a Cambria Community Services District (CCSD) intent-to-serve (or "will serve") letter for this purpose; (2) there is not an adequate sustainable water supply at this time to provide new water service to serve new development in Cambria (and it is not adequate even for existing development), a factual finding that has been repeatedly made by the commission in relation to development in Cambria across multiple actions, including certification of LCP provisions (specific to the present lack of available water and imposing specific water supply requirements) and CDP [coastal development permit] actions; (3) the sources of Cambria's water supply (i.e., Santa Rosa and San Simeon creeks) are environmentally sensitive habitat areas (ESHA) that are currently being adversely affected by existing water extractions to support existing development in Cambria; and (4) the county found that the project could be served by the community's already oversubscribed water supply because the project would be required to comply with the CCSD's retrofit program designed to offset water use, but such offsets would be inadequate to meet LCP standards with respect to adequate sustainable water supply, and the CCSD's program does not appear to actually offset such water use even if it were to be deemed an appropriate tool to meet LCP standards, which it is not."
(Commission staff made the same comments, virtually word for word, a month later in response to appeals of two more permits issued by the county, and underscored the county's reliance on intent-to-serve letters from the CCSD—simply statements of intent from "a water purveyor that sells water"—as proof of an adequate water supply.)
It goes on like that for 37 pages—a state agency that cannot believe what it's seeing. The report does not fail to mention Cambria's reliance on future water from its moribund (don't call it a) desal plant—planned in haste, repented at leisure—pointing out that no fewer than five different agencies "have raised concerns regarding the likely environmental resource impacts from the proposed water supply project and its likely nonconformity with various elements of the LCP. There is currently no established timeline for when the CCSD might complete its CDP application, when the county might take action on it, and then when potential appeals of a county decision might be made to the commission. Thus, it is not clear when, or even if, a facility such as is currently proposed may eventually come online, and it is not appropriate to countenance it in relation to whether such a water source (if ultimately approved) could provide for new water connections to serve development, including the current proposal, in an LCP-consistent manner."
That project and its application for a permit have received multiple time extensions. In August 2020, the CCSD was given a list of missing documents it needs to include with its application, plus a list of Coastal Plan policies for which it must supply written justifications showing how the project would comply with them.
Ten months later, on June 10, the CCSD accepted the public draft of an Urban Water Management Plan that distinctly overestimates water supply and underestimates demand and is based on the assumption that the district will have a permit in hand for its desal facility within five years, and growth will resume.
In its 2020 report, because it needed to be said, the Coastal Commission said this when denying a development permit for each of the new residences that the county approved for a permit in a town that doesn't have the water to serve them:
"Denial of the project is due to the factual circumstance of lack of adequate water, rather than a regulatory prohibition."
The county and the Cambria Community Services District may some day choose to let that sink in. Or they may continue to prefer to let that reality sizzle and burn away on impact, evaporating into the sky. Δ
Andrew Christie is the director of the Santa Lucia Chapter of the Sierra Club. Send a response for publication to email@example.com.