Petition for Writ of Mandate (December 16, 2015)
For failure to comply with CEQA
- Inadequate Project Description and Analysis — No Operational Plan.
- Inadequate Project Description and Analysis — Improper Segmentation and Deferral of CEOA Analysis.
- Inadequate Project Description — No Description of the Severance of Yermo.
- Inadequate Project Description — No Disclosure of Impacts from Regulatory Changes.
- Inadequate Project Description — Future Construction of a New O&M Facility in Apple Valley and Planned System Upgrades.
- Inadequate Discussion of Alternatives.
- Bias in Precommitment to the Town’s Own Project.
- Inadequate Hydrology and Water Quality Analysis.
- Failure to Discuss the Main Replacement Program Has Transportation, Traffic and Public Safety Impacts.
- Loss of the Current System’s Check and Balance Approach to Stormwater Conveyance.
- Inadequate Discussion of Potential Growth Inducing Impacts of Town Ownership.