7 June 2006

Borrego Springs, CA 92004

Mr. Jarrett Ramaiya, Project Manager

Regulatory Planning Division

Department of Planning and Land Use

5201 Ruffin Rd., Suite B

San Diego, CA 92123-0017

Re: Case Number: AD06-29; Project Name: Ellis Farms Agricultural Clearing Permit; APN 140-290-04

Dear Mr. Ramaiya:

Ellis Farms’ application for an Administrative Agricultural Clearing permit should be denied based on the following:

  • The parcel in question was a part of the now defunct DiGiorgio operation. It has not been in agricultural production for approximately 35 years.
  • Apparently, DPLU staff "believe… [the] project to be exempt from further environmental analysis…" On the contrary, the project should be subject to a full environmental review pursuant to the county’s grading and clearing ordinance (County Ordinance No. 7415 (New Series)); the intent of which clearly is that "…any area which has not been in agricultural production for at least one of the preceding five years" shall be treated as undisturbed land. The property in question fails to satisfy that condition and therefore should not be exempt.
  • An environmental review of the project will show that expanding agriculture in the Borrego Valley with its single, finite, and fast-dwindling water supply is unwise and untenable. The cumulative impact of this project will be considerable and will greatly accelerate the depletion of the Borrego Valley aquifer that has been in a state of overdraft for sixty years or more.
  • According to independent analyses by Jim Bennett, Hydrogeologist for the county of San Diego and Dr. Tim Ross, Engineering Geologist, California Department of Water Resources, of hydrologic data collected in the valley over the last 25 years, the annual decline in the groundwater level has doubled in the last quarter century. The majority of that increase occurred in just the last eight years; i.e., since 1998. The rapidly accelerating rate of decline is extremely ominous.
  • Both the Borrego Springs Community Sponsor Group (BSCSG) and the Borrego Water District (BWD) have recently taken actions to reduce the overdraft of our sole source aquifer. The most promising of these is a BWD program to purchase and fallow farm land currently in production. The BWD has implemented and the BSCSG has endorsed a 3:1 groundwater mitigation requirement for new construction in the district and the BWD is in the process of forming a Community Facilities District to raise a substantial amount of money for the purchase and fallow program, among others. Allowing any expansion of agriculture in the valley will negate the benefits of these and other costly water conservation programs, set back efforts to save the aquifer, and increase the likelihood of serious - probably irreversible - water shortages in the valley sooner than later.
  • For these reasons, an immediate moratorium be must be declared on such projects and this and all other applications to expand agriculture in the valley summarily denied.

    cc:         Kenneth J Brazell, Project Manager, Department of Public, M.S. 0336

                 Devon Muto, Planning Manager, Department of Planning and Land Use, M.S. 0650

                Gary L. Pryor, Director, Department of Planning and Land Use

                Aaron Barling, Department of Planning and Land Use,

                Bill Horn, 5th District Supervisor, County of San Diego

                Cheryl Jones, Planning Commission, County of San Diego

                Ivan Holler, Deputy Director, Department of Planning and Land Use

                Russ Forgarty, General Manager, Borrego Water District

                Bill Collins, Chairman, Borrego Springs Community Sponsor Group

               Jim Bennet, Hydrogeologist, County of San Diego                                                             06/15/2006


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