1. From the Staff Report to the Planning Commission:
   

“A use with the potential to adversely affect groundwater levels would not be considered compatible with existing, neighboring, or adjoining land uses, especially when there is no public water source available and all surrounding properties are or would be served by groundwater wells.” 2.9.09 Staff Report, p.28

1. The project relies on precious groundwater from a diminishing aquifer, not public water or surface water. Some local homeowners whose wells have gone dry are forced to truck in water for daily survival; others face significant expenses to redrill wells with sinking water levels, mounting electric bills for pumps running longer, or costs of installing holding tanks to have water available for normal uses. Many have cut back on landscape watering to conserve. Meanwhile, Trinitas consumes 113 million gallons of groundwater annually irrigating turf grass for an unapproved private membership golf course. With the aquifer declining and California experiencing a record drought, is this the most beneficial use of precious local resources? 
   

2. It could seriously impact the aquifer and surrounding wells. Despite KIRC’s year-long call for a pumping draw-down test or other reliable method of determining whether or not such adverse impacts are already occurring, no such field testing has been conducted. The FEIR does not substantiate developer claims that irrigation watering has not or will not harm other local wells.
   

3. A Trinitas consultant suggests project wells draw from a “deeper” aquifer than neighbor wells, and therefore will not affect them. This theory has not been substantiated by well depth data on the project site and surrounding area. KIRC hydrogeologist Kenneth Schmidt has outlined the information necessary to verify or deny this theory, including a pumping test. The consultant for the County states: “There is not adequate data to characterize the possible impacts to existing water levels.” (Geocon 1.20.09) It is essential that data and testing resolve this issue before making a decision on the project.
   

4. “…at least five years of additional data are necessary to adequately evaluate trends in groundwater levels. …it cannot be concluded with any degree of certainty that continued pumping of groundwater to serve the proposed project will not adversely affect groundwater levels. Geocon Consultants has concluded that pumping of groundwater to serve the additional proposed uses of the project or any additional uses on surrounding properties will impact existing groundwater levels.” RDEIR, p.3.7-15
   

5. RDEIR Mitigation #3.11-5a includes bringing surface water to the site and irrigating the golf course with reclaimed water instead of groundwater. However, CCWD has indicated it has no reclaimed water to provide Trinitas, nor means of delivering it, if it was available. Until recently, they said it could take ten years or more and up to $30,000,000 to bring surface water to the area. Unless CCWD wins federal infrastructure incentive funding, the chance of doing so in the foreseeable future without a taxpayer subsidized bond measure or public assessment is slim. 
   

6. FEIR Mitigation Measure PUBLIC #3.11-5a recognizes the problem, and limits water use to current levels.
   

“Until such time as a public water supply is brought to the project site or the results of at least five years of the water supply monitoring, identified in HYDRO #3.7-2(a-b) confirm there is sufficient water available through on-site well production to serve an expanded project footprint the amount of water withdrawn from the existing and future wells to serve the project shall be limited to the amount currently being used to irrigate the golf course, serve the existing residences, and maintain the olive orchard. Should the applicant choose, a reduction in the amount of water used to irrigate the golf course, by eliminating some fairway greens and utilizing more native landscaping within the golf course, could result in a sufficient supply to serve the proposed new home sites and clubhouse.”

1. FEIR: Mitigation Measure PUBLIC #3.11-5b states:
   

“Concurrent with the requirements of MM HYDRO #3.7-2(a-b), the project owner shall refrain from developing any additional uses that would require the use of additional water until at least one year’s worth of baseline water usage has been provided. Additional uses (permitted or conditional) would then be subject to maintaining a level of water usage, consistent with the baseline levels, until such time as a public water supply is brought to the project site or the results of the water supply monitoring, identified in HYDRO #3.7-2(a-b), confirms there is sufficient water available to serve the proposed uses without significantly impacting local groundwater supplies beyond the project owner’s reasonable share. Water usage would be verified by monthly metering reports for all wells and an annual water use summary, which shall be provided to the Planning Department by the 5th of each month, as required in HYDRO #3.7-2(a-b).”

1. The project should not be approved on a long-shot hope of future surface water, when the best that can be said now is that there “appears” to be sufficient water to sustain current levels of use.