On October 27, the Well #8 Neighbors Group filed 39 comments on the City’s Initial Study and draft Mitigated Negative Declaration for the Well #8 permit application. A permit may not be granted until the disclosure defects are remedied. Here, in three parts, we publish only the comments themselves, grouped by subject. The entire 21-page document includes text and graphics supporting the comments.
MISLEADING PROJECT DESCRIPTION
Comment #1. The Applicant’s project description (copied verbatim from the Application into the MND/IS) misrepresents Well #8 as augmenting water supply to its own shareholder/customers, which it cannot do. Instead, the purpose of Well #8 is to supply water to Calleguas Municipal Water District (“Calleguas”), which is paying for the Project, so it can provide the water to the City of Oxnard in the event of a catastrophic interruption of imports from northern California.
Comment #2. The project description falsely claims that Well #8 will enhance Crestview’s ability to provide fire protection water.
Comment #3. The Project Description in the MND/IS fails to disclose that Well #8 will pump–and make noise–round the clock for six months if there is a blockage of water imports into Ventura County, and that Crestview may pump regularly at night if electricity rates change again.
Comment #4. The MND/IS is deficient because it does not disclose and consider important direct offsite impacts of the Project.
Comment #5. The Applicant’s Environmental Assessment Questionnaire contains numerous errors because it refers in many places to a previous site instead of the site for which the CUP is being sought, making it unreliable for permit processing purposes.
Comment #6. The MND/IS is deficient because it does not consider the potential environmental impacts of discharging 11.5 million gallons of wastewater through a 24” pipe into the barranca, about 75 percent of it in a 72-hour period.
Comment #7. The MND/IS is deficient because it does not consider the potential environmental impacts on water resources and soils of contaminants in the wastewater.
Comment #8. The MND/IS is deficient because it does not consider the potential environmental impacts of accidental and emergency releases of produced groundwater.
Comment #9. The MND/IS is deficient because it does not consider the potential impact on biota caused by wastewater discharges. For details, please see the Comments under Biological Impacts.
Comment #10. The MND/IS is deficient because it does not adequately consider Project impacts on stormwater flows, and its assumptions about Crestview’s stormwater management plans are unsupported by the record.
Comment #11. The MND/IS incorrectly states (page 70) that “the well would not increase the amount of groundwater that Crestview is allowed to pump from the aquifer.”
SEPTIC SYSTEMS IMPACTS
Comment #12. The existence of Well #8 would force up to 19 homeowners out of the City permitting process for repairs and replacements of their seepage pits and into the more costly, months-long process run by the State’s Regional Water Quality Control Board in Los Angeles, (“LARWQCB”). Also, the LARWQCB process would impose on homeowners annual operating permit fees of at least $1,727, making the total incremental cost over 20 years at least $34,000 and possibly more than $200,000.
Comment #13. The risk of having to go to LARWQCB for a permit to repair a septic system would make a property less marketable and lower its market value.
Comment #14. Crestview’s February 24, 2023 “commitment letter” about paying permitting costs at LARWQCB is deceptive and illusory, and Crestview has refused to answer basic clarifying questions from the Well #8 Neighbors Group.
Comment #15. If Crestview proposes to mitigate the septic system problem by connecting the dry sewer in the neighborhood to the active sewer main between La Marina and the barranca, that would have potentially significant environmental impacts in the barranca on water, soils, and biological resources that have not been assessed.
Look for Part 2 tomorrow.
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