Public Statement on Clos Del La Tech Draft EIR
The following statement was the basis of the oral statement presented to the San Mateo County Planning Commission at the public hearing on August 27th.
Cuesta La Honda Guild
Public Statement on Clos Del La Tech Draft EIR
Good morning. The Cuesta La Honda Guild would like to thank Lisa Grote, Mike Schaller, the county planning staff, and also Supervisor Rich Gordon for your hard work on this issue over the past four years.
It is the responsibility of the Cuesta La Honda Guild to protect the quality and quantity of our municipal water supply. We provide water to 280 households and the La Honda Elementary School, serving approximately 1000 people in total. Our water supply is obtained from diversion points in the San Gregorio watershed, which was fully adjudicated in 1992. One of these diversion points is in Mindego Creek, which is only available to the Guild from October through May, and two of these diversion points are in Woodhams creek, whose flow is maintained by springs, such as Tunnel Spring, in the dry months. The Woodhams Creek flow is critical to the Guild, without it we would run out of water in our two primary drinking water reservoirs at the end of the summer.
The Clos De La Tech winery project and associated ’Scenic Winery’ zoning text amendment have the potential to significantly impact our water supply. The primary issues of concern to the Guild include depletion of our water supply, and drinking water contamination. The proposed land swap is a big step in the right direction in terms of ensuring the protection of our drinking water, but our preliminary analysis of the DEIR has raised a number of concerns. Full written comments will be submitted by September 5, but I would like to summarize the Guild’s current concerns regarding the draft EIR. These concerns fall under three categories: analysis, monitoring and mitigation.
Concerns with analysis
1. The report does not mention that the San Gregorio watershed is an adjudicated basin with legal restrictions on water use. This is a significant oversight.
2. The likely hydrological connection between springs in Woodhams, including Tunnel Spring, and the aquifer feeding the wells continues to cause great concern for impacts on water supply in Woodhams. Therefore, it is of special concern to us that the role of springs in Woodhams in supplying the Guild is not analyzed and there is no indication of how critical this water is to the Guild water supply. In addition, there is no comprehensive analysis of the effects of the project on the groundwater budget or discussion of the relative scale of the proposed pumping to flows in Woodhams.
3. The cumulative affect of the ZTA on watersheds County wide is not evaluated. This analysis was specifically listed in the revised notice of preparation from September 2007. This issue is of particular concern to the Guild because the ZTA also impacts the Mindego Watershed, which is also an important part of the Guild’s drinking water supply.
4. The 55% slope limit in alternative two is inconsistent with regulations in other counties such as Napa and Sonoma, where any planting of slopes over 5% is regulated, and planting above 50% slope is not allowed.
Concerns with monitoring
1. While it is recommended that flow in Woodhams creek is monitored, no specific means of quantifying a significant affect on flow in Woodhams is provided. This is critical. Any loss of flow is contrary to the terms of the San Gregorio adjudication.
2. There is no requirement that monitoring of the flow of springs and creeks should be conducted by an independent hydrogeologist.
3. The chemical monitoring plan needs more frequent sampling of runoff, timed to chemical applications and coincident with rainfall events.
Concerns with mitigation
1. The proposed mitigation measures are vague and inadequate. A proposal for a future study runs contrary to County practice, and ignores pertinent data that already exist from the Guild’s 3 year hydrology study.
2. No specifics regarding mitigation in the event of pesticide, herbicide, or fertilizer contamination are included.
In Summary
Our preliminary analysis indicates the current DEIR does not adequately analyze and address the impacts of the project on the water supply of 1000 people. The Guild would like to see the DEIR revised to address these major concerns and to be recirculated for public comment.
Thank you very much.
The Cuesta La Honda Guild Board of Directors
