Petition for Writ of Mandate (December 16, 2015)

AVRWC - Apple Valley Ranchos Water Company

For failure to comply with CEQA

  1. Inadequate Project Description and Analysis — No Operational Plan.
  2. Inadequate Project Description and Analysis — Improper Segmentation and Deferral of CEOA Analysis.
  3. Inadequate Project Description — No Description of the Severance of Yermo.
  4. Inadequate Project Description — No Disclosure of Impacts from Regulatory Changes.
  5. Inadequate Project Description — Future Construction of a New O&M Facility in Apple Valley and Planned System Upgrades.
  6. Inadequate Discussion of Alternatives.
  7. Bias in Precommitment to the Town’s Own Project.
  8. Inadequate Hydrology and Water Quality Analysis.
  9. Failure to Discuss the Main Replacement Program Has Transportation, Traffic and Public Safety Impacts.
  10. Loss of the Current System’s Check and Balance Approach to Stormwater Conveyance.
  11. Inadequate Discussion of Potential Growth Inducing Impacts of Town Ownership.