water credit transfers
Carmel River activists have filed a second lawsuit challenging the Peninsula water district's right to allow the transfer of "paper water" credits into city water banks. The lawsuit alleges that the Monterey Peninsula Water Management District improperly allowed the Seaside Redevelopment Agency to transfer water credits to the city of Seaside, which will in turn issue them back to the redevelopment agency. The transfer, approved in late December, prevented the expiration and loss of the credits.
the background of the case is discussed in the article as well:
A district ordinance allows the creation of water credits when a building is demolished or its use is changed to reduce water consumption. Under the regulation, unused water credits can be transferred to a city for distribution to commercial ventures on that city's waiting list, but credits that remain unused after 10 years expire and essentially move back into the Carmel River.
In Seaside's case, commercial properties at the southwest corner of Fremont Boulevard and Broadway Avenue were transferred to the redevelopment agency in 1994. The buildings, which included the Del Rey Theater, a salon and restaurant, were razed and the properties have remained vacant since.
At some point, the water district assigned more than two acre-feet of water credits -- enough to supply eight Peninsula homes -- to the property. Those credits were set to expire in December but instead were transferred to the city for safekeeping. The move was approved 4-2 by the district on Dec. 13.
Transferring water into a city water bank to avoid expiration, Bernardi said, goes against the intent of the law.
"They're basically doing an end-run around an ordinance," she said. "From my perspective it's just manipulating."

