Fred Allebach
8/16/24
Regarding the VOMWD (Valley of the Moon Water District) Trinity Oaks annexation proposal at SoCo LAFCO
It seems all are in agreement with an annexation to serve the few parcels that have legitimate water-needs issues. This annexation however, has opened a window to Sonoma Valley (SV) land use and planning wars centered around SDC, the Hanna project, and the Springs Specific Plan.
LAFCO gets pulled into local power struggles when questions arise about services in potential annexations. How services affect social fabric is part of annexation and municipal service reviews. The CALAFCO site says, “LAFCO decisions form the basis of sustainable regional planning and strive to balance the competing needs in California for efficient services, affordable housing, economic opportunity, and conservation of natural resources.”
Given that affordable housing is a legit LAFCO consideration, there is a nexus between ag and open space preservation and accounting for local DUCs and social and economic communities of interest.
A core question: is the SV urban service area (USA), one of 12 in SoCo, a legitimate land use unit to see as appropriate for infill, smart growth, and conforming to the SoCo RHNA allocation? USA infill to address the the SoCo Housing Element, AFFH, and RHNA seems to meet needed housing supply objectives that impact affordability and to not qualify as “sprawl.”
Sprawl is more at development into greenfields where there is not a USA present.
LAFCO staff report language in the Trinity Oaks annexation, concerning the condition of SV water supply context, both groundwater and aqueduct water, is now a pawn in this above-noted SV land use battle. What we have is a framing and messaging struggle over water supply that plays into what I call the Green Checkmate, where tremendous pressure is put to not expand any boundaries but where locals heavily resist any dense infill as well.
With land use being so heavily constricted in SV, housing prices have gone through the roof. LAFCO has a role here to balance the municipal service forces in play. LAFCO policy decisions have to account for DUCs and housing affordability. This is why I suggested at the August 2024 LAFCO Board meeting, that an appropriate and pragmatic water policy is not to be exclusive and build a wall and allow no more new users but to have an inclusive, efficient policy of “the more straws (into water supply), the less each.” This means all have to sacrifice for the greater good.
As I see it, at the August LAFCO Board meeting, successful pressure was brought by some Board members and by Norman Gilroy of SDC Next100 and Mobilize Sonoma etc., to make the language about VOMWD water capacity more stringent and to set verbal precedents re: SV water conditions that will serve to work against approval of and/ or water service to: SDC, Hanna, the Springs Specific Plan, and even 100% affordable housing projects. This even though Director Bramfitt felt he had already accurately described local water conditions.
Part of the issue here is that groundwater (GW) makes up a portion of VOMWD’s supply. Sonoma Valley has a state Department of Water Resources high-risk GW basin with a Groundwater Sustainability Agency. Gilroy et al are making a case that the percent of overall VOMWD supply that constitutes GW may not be or is not adequate when the overall water demand from SDC, Hanna, the SSP, the Krug hotel, the MidPen 100% affordable housing project, and from projected RHNA numbers, and when the effect of state housing laws are all considered in aggregate. Gilroy et al don’t see all these projects etc. accounted for in the VOMWD UWMP (Urban Water Management Pan.)
This is basically a CEQA cumulative impact argument that is being made, and CEQA lawsuits are the tool being used to fight SV urban service area infill projects. CEQA reform has been called for because of the negative effect it has had on state housing production and resultant high prices, especially in coastal California.
The Sonoma Water UWMP does say there is enough water and top Sonoma Water staff have recently said as much to the SV Community Advisory Commission. Whether or not there is enough water depends on who you are talking to and what spin they are bringing to the table, even at the highest levels of regional water management.
It is reasonable to have GW supply and demand figures align, and it is also reasonable to weigh this in the context of supply and demand for housing in SV and SoCo. IMO, water scarcity cannot end up as a reason to build a wall and maintain SV as an elite location that has increasingly displaced DUCs and DACs. This kind of consideration is on LAFCO’s turf. My own 2020 US Census, 2022 American Community Survey update studies indicate that if one were to take the most liberal (but literal) SB-244 interpretation in counting/ locating local SV DACs and DUCs, there are a lot, and contiguous to the city of Sonoma.
Any LAFCO Trinity Oaks annexation analysis that sets precedents for SV water supply overall, IMO, should grasp the full subtlety of the local GSP (Groundwater Sustainability Plan) and whether the Gilroy scarcity argument really holds water in the context of the GSP, VOMWD supply, and the Sonoma Water UWMP.
There is a deep aquifer depletion area (one of two) near the golf course on Arnold Drive but the most serious depletion area is nowhere near VOMWD supply wells, and the deep aquifer is not like a big underground lake that is all at the same level. The SV basin surface aquifer system is sustainable in the sense that it recharges quickly with rain. All in all, California has had periodic drought for 1000s of years, and inhabitants adapt during those periods by curtailing use.
The SV GSP also has built-in growth rates and accounts for future uses, has sustainability metrics etc. that may not all conform to a simple GW accounting. VOMWD itself, by its very existence, offsets GW use to a high level.
So, an appeal is now made to LAFCO to, in the Trinity Oaks annexation analysis, to put a negative, more severe spin on the impact of SV USA (urban service area) infill, and on state housing laws, and link these to VOMWD water supply capacity and GW use.
If housing impact issues are to be brought up, I suggest LAFCO must also include and address points about water capacity related to SV disadvantaged unincorporated communities (DUCs) and housing supply for them. Is it legal to use water scarcity rationales to bypass RHNA, and Housing Element/ General Plan-required laws State laws like AFFH (Affirmatively Furthering Fair Housing. These laws and policies are necessary to address the cumulative negative impact of CA housing underproduction and for social justice. There are also a variety of CA fair-use water laws and policies to protect DAC’s and DUCs interests. Water has to be portioned so everyone gets a share, not so some sequester the supply to keep an elite lifestyle and have more than their fair share.
As well, the Green Checkmate has resulted in a sitiation where pretty much only market rate housing can be built. In many cases all that gets done for affordability stems from project inclusionary requirements. In Sonoma from 2000 - 2020 there is a demonstrable RHNA underproduction deficit for Moderate, Low and Very Low-income units. Mod, L, and VL underproduction by 263 units and market rate overproduction by 296 units, see ABAG RHNA production website.
Even though the Springs has take proportionally more 100% affordable projects than Sonoma, as we look at SV as a whole, when water limits are considered to maybe foretell more development, as I suggested at the August LAFCO Board meeting, to account for local DUC’s/ essential workers/ BIPOC protected class’s place in the community, a water-use placeholder needs to be maintained so that by the time any 100% affordable projects come along, those DUCs will not be pre-displaced by an argument that there is not enough water to go around and only the wealthy can live here.
Here we see CEQA and environmental considerations ending up in tension and conflict with RHNA and AFFH. What takes priority over what? My ask here to LAFCO staff and the LAFCO Board, is that if water is to be used as a political football: address the full scope of laws and policies that impact and are impacted by local water use and supply. LAFCO should be fair and address all possible sides of this calculus, and not end up as a proxy agent of any one side or the other in SV land use wars.
If laws and policies conflict, that needs to be noted. In sustainability, there is a triple bottom line for which there needs to be full cost accounting. Economic, environmental, and social pillars are all equal and necessary legs to support a balanced policy stool. Equity and social factors for the little guys can't always come in last place. When LAFCO considers services allocation and annexations, the triple bottom line and full cost accounting should be in play in your calculus.
A full spectrum analysis by LAFCO of water and other services includes impacts that affect a pro-housing agenda as reflected in state housing laws. West-of-Arnold property owners are not the only community stakeholders and interests here. If we have water used as a political football, the spin needs to also include the displacement effects of a limited growth, austere water policy on DACs and DUCs in SV. And include a presumption that state housing laws are for the benefit of housing-burdened renters and lower-income, essential worker people, many of whom are BIPOC, protected classes, EJ communities, and DUCs. These people need water too and should have their place held for future water use here in SV.
It can’t be fair that land use is all framed from a pull-up-the-drawbridge, environmental issues-only standpoint because this then amounts to using water scarcity alarmism as a reason for that ends up being modern redlining.
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