At its regular monthly meeting last week, the governing board of the Garberville Sanitary District unanimously approved the district’s official comments on proposed land-use designation changes at the Southern Humboldt Community Park.
The comments include an “opinion,” as the one-page letter signed by board chairperson Linda Brodersen put it, that the park should pay to be annexed into the district so that the district can provide drinking water to members of the public using the park.
“The community park should not provide potable water to the public unless, at their expense, they are annexed into Garberville Sanitary District, which will provide year-round potable water and ensure safe water for public consumption,” the June 21 letter stated.
GSD’s letter is just one of a number of written comments related to the community park that have been coming into the Humboldt County Planning Department of late from various agencies and individuals. The comments, which will be accepted through Thursday, pertain to an 852-page Draft Environmental Impact Report that came out in April.
Commissioned by the community park, a small nonprofit, the massive document evaluates a number of proposed land-use designation changes at the 405-acre property — including one that would allow for the staging of public festivals.
It also scrutinizes the potential impacts of rezoning the park to allow for athletic fields. Irrigating such fields is expected to substantially increase the amount of water the community park draws from the Eel River compared to what it draws now.
That’s an issue for GSD since its water intake is located roughly 400 yards downstream from the community park’s intake.
Which explains another “opinion” expressed in the GSD comment letter: That “all recreational irrigation [should] be discontinued when the river flow is below 30 cubic feet per second.”
The 30 cubic feet per second threshold comes from a recommendation made by one of the consultants hired by the park to work on the DEIR, Pacific Watershed Associates.
In a report, the firm said: “We suggest 30 cubic feet per second as an interim threshold, beyond which the sports field can only be irrigated with stored or recycled water.”
Brad Job, the Pacific Watershed civil engineer who headed up the study, pointed out in an interview earlier this month that at present the community park can legally withdraw water from the river when flows are as little as 2.6 cubic feet per second.
“We’re saying 30 cubic feet per second. So that’s an order of magnitude more protective,” he commented.
Speaking a couple of days after the meeting about the annexation opinion, GSD General Manager Ralph Emerson acknowledged that the park has its own water sources — such as a spring and a well at Tooby Memorial Park.
But he said: “We felt for the health and safety of the community it would be wiser [for the park] to have treated water from our district.”
For that to happen, Emerson said the park would either need to be annexed into the district or an “out of district service agreement” between the park and GSD would need to be reached.
Under such an agreement, Emerson said the park “would buy water from us rather than taking [water] out of [their] well.”
An annexation of the community park by GSD would be no small step. To become a reality, it would need to be approved by the Humboldt Local Area Formation Commission, a seven-member body that has authority over local governmental boundary changes.
In a two-page letter dated last Friday that constitutes LAFCo’s official comments on the environmental impact report, Chief Executive Officer George Williamson said there is a “need to evaluate annexation to GSD in the DEIR.”
“Expanding the project to include annexation would provide an appropriate level of environmental analysis that could support an application to LAFCo either submitted by resolution of application from GSD or by landowner petition by the park,” Williamson wrote.
“The park property is located adjacent to the GSD boundary, is within the district’s sphere of influence and has social, economic and historic ties to the district. Therefore, it is appropriate to expand the project description to evaluate annexation to the GSD,” he added.
Reached on Sunday, community park executive director Kathryn Lobato made clear that as far as the park is concerned, annexation is not on the table.
“We’ve got the water. We can go on our own. Our intention is not to [be annexed],” she said.
The chief reason is the expense. Lobato said that at one point early on in the environmental impact report effort, when the basic “project description” was being hammered out, the park applied for a $192,000 grant.
The grant would have covered the cost — such as “environmental work and going through the LAFCo process” — of getting annexed to GSD. But the park did not get the grant.
Given that the EIR process itself is costly — Lobato said earlier this month that the park has spent “upwards of $250,000” on a total of roughly 15 consultant studies for the EIR — she made clear on Sunday that ponying up almost as much money to cover the price-tag of getting annexed by GSD simply isn’t in the cards.
“We’re not opposed to being annexed. We just can’t afford it,” she said.
Money aside, Lobato said that as a practical matter she didn’t know how exactly a review of the impacts of annexation could be folded into the DEIR at this point given that the document has been in the works for some time.
“I don’t know how he thinks that would work,” Lobato remarked, referring to Williamson. “The project description has already been determined. [The DEIR] has been out for review a number of times. We should have heard about this before now.”