May 18, 2015
Ventura City Council
501 Poli St
Ventura CA 93001
Sent via e-mail
RE: 2015 COMPREHENSIVE WATER RESOURCES REPORT
Dear Ventura City Council;
The Ventura County Chapter of the Surfrider Foundation has been engaged in local water issues for almost two decades. We recognize that waste equals pollution, which directly affects the health of our coast and those of us who enjoy ocean recreation. We believe that a truly integrated water management plan is desperately needed so that the City of Ventura can become sustainable within the limits of our local water supply.
The current drought has exposed the vulnerability of the City of Ventura to uncontrolled variations in water supply. Ventura has reached what some call “Peak Water.” Water supply is the most critical issue our community faces, and future generations depend on today’s decisions.
Unfortunately, our review of the 2015 COMPREHENSIVE WATER RESOURCES REPORT reveals some glaring errors and omissions that not only represent undisclosed limits to our water supply, but also missed opportunities in attaining sustainable water management.
We recommend that City Council:
• Reject the 2015 COMPREHENSIVE WATER RESOURCES REPORT until these errors are resolved, and
• Impose a building moratorium during the current severe drought.
The following are some of our concerns with the 2015 COMPREHENSIVE WATER RESOURCES REPORT:
1. Casitas Municipal Water District (Casitas)
The report does not mention transfers outside the CMWD district boundary to the east side of Ventura. Under current drought conditions this transfer will likely have to be eliminated. Also, the report assumes a drought reduction of the City’s supply from Casitas of 20%, while CMWD is mandated to reduce overall demand by 32%
2. Ventura River Surface Water Intake and Upper Ventura River Groundwater Basin/Subsurface Intake and Wells (Foster Park)
Currently flows have dropped to a historic low at Foster Park. The report notes that the City’s ability to draw water from the Ventura River has been significantly impacted by the current drought. However, the long-term estimates for increased yield from 4200 to 6700 acre feet per year yield from Foster Park are not realistic due to physical and legal constraints.
1. Future water supply estimates from Foster Park are based on the wettest years, which in reality only occur once every 7 to 10 years. Therefore, the expectation for increased yield from Foster Park do not account for the physical limitations of a variable climate – many years there simply will not be that much water to extract.
2. In the future, extractions at Foster Park are likely to be legally constrained. Reduction and elimination of surface flows in the “Live Reach” of the Ventura River threaten the endangered steelhead as well as recreation and water quality. Ongoing litigation by Santa Barbara Channelkeeper questions Ventura’s water right with regard to instream flows and the public trust.
3. East side groundwater supply:
Aquifers on the east side are impacted by overdraft and subject to long-term salt-water intrusion. Poor water quality necessitates blending to achieve potable water standards. The City of Ventura is just one of many users of these aquifers. Depending on future drought and urban and agricultural uses these sources may also become more limited.
4. Recycled Water:
The report only anticipates a small increase of 700 AFY in reclaimed water for the 2025 water budget. Reclaimed water is the city’s best opportunity to enhance water supply reliability.
Ventura Water Reclamation Facility (VWRF)
The city is bound under under the Wishtoyo/HTB legal settlement to increase reuse of VRWF effluent to at least 50% by 2025. This could yield a significant increase in water supply while at the same time reducing the impact to the estuary and McGrath State Beach, which has been closed due to flooding.
Ojai Valley Sanitary District (OVSD)
In contrast, reclamation of OVSD effluent will greatly reduce flows in the lower Ventura River. Currently, in dry years, nearly 100% of the flow in the lower Ventura River is OVSD effluent. Removing this effluent from the river will further compound the impacts from over-extraction at Foster Park and result in a dry river. Therefore we do not anticipate that this is a viable future source of water for Ventura.
5. What population may be supported by the current and future supply?
This is the most important question facing the city today. It appears that Ventura is overestimating the current and future water supply in order to justify continued urban growth. This places an undue burden on current and future residents. We recommend that a building moratorium be enacted until this question is answered and a clear plan for future water management is developed.
6. How can Ventura better plan for the future?
Why did Ventura miss out on Prop 40 IRWMP funding?
The County-run Watersheds Coalition of Ventura County (WCVC) program has successfully secured millions of dollars in state funding for local projects. Despite investing thousands of hours of staff time as well as fiscal sponsorship for WCVC, the City of Ventura did not submit any proposals for IRWMP grant funding.
Surfrider has consistently advocated that Integrated Water Management is the key to attracting grant funding to achieve optimum use of available water supplies. This is best achieved on multiple scales using a watershed planning approach. Coordination with other local agencies, and capturing and using resources near their source are essential to provide resiliency to future changes.
An Ocean Friendly Garden is a small-scale example of this strategy. Water that runs off roofs and driveways is captured in the landscape providing an adequate supply of water for native plants as well as reducing flooding and water quality problems downstream. Greywater may be used on-site to support fruit trees. By capturing and using water onsite, wasteful irrigation is eliminated and water that used to run off the landscape is captured so as to contribute to the local aquifer. Many small Ocean Friendly Gardens add up to neighborhood-scale benefits.
On a larger scale, water that is currently channeled off the landscape by the storm drain system should also be captured and utilized. Such improvements to the urban landscape provide an even greater opportunity to capture and infiltrate stormwater and eliminate the liability from polluted runoff. This could be highly beneficial in stressed aquifers such as those in East Ventura.
Similarly, wastewater may be captured in locations with reuse opportunities through small local “scalping plants.” Such plants should be planned for East Ventura where groundwater recharge or direct reuse can help maintain depleted aquifers.
We join with other members of our community and encourage you to make the right decisions to ensure Ventura’s prosperous and sustainable future.
Chair - Surfrider Foundation Ventura County Chapter
click here to download the letter
click here to download 2015 COMPREHENSIVE WATER RESOURCES REPORT pdf
click here to download the City's response