Let's Preserve the Ecological Balance of Our Sensitive Watershed Inheritance

In my last blog, we looked at financial information that factually identifies the remodeling and development activities that SLVWD (District) engaged in from 2004 through 2013.  What does that tell us?  Mainly, that the intent to develop the Campus has been a primary activity for which the District has been willing to engage even though there were other projects listed in their Capital Improvement Program that may have required more immediate attention.  This approach towards making management decisions also reveals a perspective that may not be compatible with accepted best practices.  However, one thing that was not touched on by the financial discussion, were much more critical issues that have to do with the preservation of the ecological balance of our sensitive watershed inheritance.

What will be the impact of development in that sensitive wetland area on which the Campus is to be built?  I do not have the professional qualifications to claim expertise as an environmentalist.  The only recourse immediately accessible to me is to look at the Initial Study/Mitigated Negative Declaration ( IS/MND) and its' Appendix which were issued for the Campus project.  By doing so, I can determine what the environmental issues are by noting the mitigating measures listed which could be taken to lessen an environmental impact of intrusive development.  When they applied for Proposition 50 Grant money to fund the Intertie system they also prepared an IS/MND.  However, since my neighborhood was described incorrectly in that IS/MND and several descriptive sections were just plain false, I discovered that you cannot always depend on such a document to provide all of the truth about an area or situation.   I also realize that just because that a particular IS/MND study may not accurately represent the conditions of a given area, it does not mean that this one carries the same kind of error. Never-the-less, I have reason to be cautious about the level of accuracy in the Campus IS/MND  based on prior experience. 

One point that I noted in the IS/MND, is that the portion of the property that is nearest the water way, has standing water during several months during   the year.  A drainage system would have to be built to mitigate this problem.  What I did not see listed is the impact that this mitigation would have to the overall environment which would include the steelhead fish which are an endangered species. Additionally, what would the impact be to altering the streambed by constructing a drainage system to clear standing water from the building site?  How would this effect the fish life?  What is the impact of draining water from a site where heavy chemicals are used and stored? Could the standing water be contaminated that will ultimately drain from the property into the stream ?

I have another question that so far, I have been unable to find any evidence that it has even been considered.  I want to know if there are other options that could be pursued as an alternative to building the Campus on wetlands? What other solutions to obtaining suitable facilities could have been considered that would not require the vast investment as the Campus requires?  With over $3 million spent and $6 million yet required, it seems that a significant amount of rate payer investment could be saved by choosing a more economical solution.

I don't know about what kind of house you live in, but I know that many people who live in the San Lorenzo Valley do not have brand new houses.  It is typical for many of the homes to be older structures that need maintenance, such as reroofing, or re-flooring or some other expensive work.  Not all of us can afford to attend all of these issues at the same time.  You tend to see tarps on roofs as evidence that re-roofing is being deferred to a future time.  Many families are accustomed to these circumstances and although we might like to move into a different house, we are reluctant to leave our beloved property site, or we cannot afford to do so. We cannot always see financial alternatives for ourselves much less grasp the magnitude of spending $9 million to create a new Campus facility for SLVWD.

We can certainly understand anyone's desire to move into better facilities and we do not fault SLVWD for cultivating that dream. When the well-being of one's employees is at stake, then an employer should be looking for a safer place. We consider it to be very bad taste to expose one's employees to an unsafe and perhaps life threatening work environment. 

A friend of mine recently had business to conduct in the SLVWD office.  She was appalled when an employee described their 'pre-renovation' work conditions when the floors were sloped so badly that the office safe had to be shored up on one side and the rooms were obviously moldy.  I have heard rumors from other people that the staff currently is nervous that an earthquake could bring the building down on them.

 I think that SLVWD should find more suitable office space.  However, I still question the wisdom of spending about a half million dollars on remodeling if the results yielded an unsafe condition and did not fix obvious problems.  If you know that you have a building that is 100 years old, then you should realize that it may have some serious structural issues... particularly when the floor is not even and your safe is leaning over.  Would it have been better to move into a different building instead of remodeling the old one, or set remodeling priorities to begin with the structural flaws first so that it would be safer should an earthquake occur? 

Staff already stated that there was no investment analysis performed on the Campus Project.  That being the case, I would suspect that little if any effort was given to finding alternative solutions for the Campus Project.  Now, it seems that they  are publishing statements  to justify their actions.  Instead of providing a financial analysis to support the reason for further development of this property compared to other options, they resort to relying on multiple emotional claims for how this investment will benefit the community.  It is interesting to note that some of the arguments offered are contrary to Proposition 218 requirements.  Many of their justifications for the decision to create the Campus have nothing to do with the delivery of water.  Should ratepayers challenge these uses, how would a court decide the outcome?  I suspect that It might be difficult for the District to justify their position.  What an awful thing to have happen. Pondering that possibility, I am left with these additional questions: Is there a more rational course that could be taken?  Do we really need a 9 million dollar facility that is located on a wetland area, or is there a much less expensive set of alternatives?



Letter to SLVWD about Proposed Increases

Thanks for all the informative blogs.  The expenditures on the campus are obviously not justified, but I have concerns about the intertie system as well and SLVWD's ultimate agenda for it.  Here's the letter I plan to send to SLVWD:


This letter is being written to officially oppose the rate increases that SLVWD has proposed to fund a centralized SLVWD campus and the emergency intertie system with the Santa Cruz, Scotts Valley, Lompico, and Mt. Herman water systems.

I believe any credible return-on-investment analysis would show that centralizing the SLVWD is a very poor use of rate payer money, especially in light of all the money already spent to remodel the existing facilities, and that is probably why no ROI analysis has been presented to the served communities.  The compounding effect of the rate increases should also be disclosed to the rate payers so they fully understand that SLVWD is proposing rate increases which total 65%.

The utility of the emergency intertie system is dubious, given the emergencies it is being designed to address:

  1. The most effective countermeasure for preventing aquifer or bioterrorism contamination from spreading through the water system is to keep the water systems isolated as they are today.
  2. The low flow rates provided by the pumping stations – especially northern SLVWD area - would be inadequate for fighting a major fire, and ironically, the above-ground HDPE sections of the intertie system are unlikely to survive a major fire.
  3. The 550 gpm flow rate of the emergency pump station supplying the North SLVWD area could only provide its residents with 50 gal/person/day if this pump station was capable of operating at maximum capacity during an emergency.

Given the engineering design, the most effective use of the intertie system would be to deliver water from higher elevation sources to users at lower elevations.  The 12” diameter Intertie 1 would be capable of supplying 4200gpm at 100psi to Santa Cruz, but only a sixth of this amount the other direction due to the limited flow provided by the pumping station located at this intertie.

Since only discretionary approval and CEQA compliance of the involved water agencies is required to re-purpose the intertie, it seems likely that the intertie system will ultimately be used for routine water delivery to Scotts Valley and Santa Cruz.  Since these communities would be the primary beneficiaries, a more equitable plan would be to have the beneficiaries shoulder more of the financial burden of this expansion rather than the current SLVWD rate payers whose water resources will ultimately be exploited.




I believe that you are correct in your observation.  It sounds very like what they have stated, in other terms, in their Water Supply Master Plan which is posted under Public Documents on the SLVWD. COM website.


Thank you for your expressing your views.


Suellene Petersen

Prop 50 State Funding Eligibility

Great points Lance!  However i would like to carry your point out a little further.  If the intertie system is to be used for routine water transfers, then it would seem like that would disqualify it for Prop 50 $3.9 million grant support from the state.  For this current Prop 50 initiative, SLV WD will be building three pumping stations and is counting on this support to get it done.  However, the pumping stations are spec'd for conjunctive use, not for emergency use.  If they were to be used for just emergency use only then the pumps would not have to be as robust and therefore wouldn't be as expensive.  As these intertie stations are currently spec'd, I don't believe that SLV WD is eligible for state funds.  Of course the state is unlikely to find out about this.

Thanks for your response.  I wholeheartedly agree with all your points.


Intertie Project and prop. 50

I quite agree with your views regarding the absent financial analysis and lack of a credible ROI.  But I wanted to comment on some of the points you made about the dubious "emergency intertie system".  The Watchdogs came into being as one of the social side effects of this project because of the effect that building Intertie-5 would specifically have on our neighborhood. I analyzed the associated Draft IS/MND (no longer on the District's website) and filed critical comments as a Professional Engineer primarily establishing the inadequacy of their sound study. It was a white-wash and they knew it. But something else surfaced in the IS/MND, and that was the point related to "emergency use" vs. full-time use.    

At the end of my engineering statement I offered several common-sense engineering observations that stuck with me about the anomalous over-design of several  of the proposed pumping stations. Applying basic physics led me to the conclusion that several stations were deliberately being designed, not for emergency-only use, but for eventual conversion to later full-time use. My engineering statement is bundled along with the other comments responding to the IS/MND, and is included as Appendix-F to the Final IS/MND. In particular, look at James Bentley's and mine. Your observation about bio-terrorism bothers me as well and brings another dimension to this discussion that warrants more exposure.

I posted a blog entry on 6.14.2013 on this site about my perception of the Board's mishandling of the Intertie project and what, in my opinion, is an ethical error in their subterfuge to conflate emergency use with "conjunctive" use.  "Conjunctive use" was coined and defined in their Master Plan, where: "... conjunctive use is broadly defined as the optimized sustainable use of multiple sources of water throughout annual and long-term climatic-cycles". This is clearly synonymous with planned usage, not emergency-only use.

After that blog entry, I brought the ethical issue up at a board meeting: "isn't it unethical to seek money from the State for emergency-use only, when the intent is to seriously be considering the pump stations for later full-time operational use."  The board president, Terry Vierra, basically said that it wasn't on the premise it wasn't yet confirmed they would do that, and added "what do you want us to do? Tell the truth"?  I answered "Yes". I believe the hydraulic engineering design tips the scale to their real intentions. If so, they should quit telling the public it's only for emergency use. It's interesting to note that in the Final IS/MND, several of the hydraulic designs were scaled down.  Intertie-5 was deleted and so none of my comments about this had to really be addressed.