Position of Ventura

Ventura argues that Valencia's WMP constitutes a "project" within the meaning of CEQA. According to Ventura, the Program requires the approval of the Commission and once approved, will serve as the basis for issuance of future advice letters that will allow Valencia to add new customers and extend its service areas. Ventura points out that the Commission has discretion to approve the Program and for how long. It also has discretion to impose conditions on Valencia. (See, e.g., Pub. Util. Code §§ 761 and 770.) Further, Ventura contends that Valencia's proposed groundwater use may cause a direct or reasonably foreseeable indirect change in the environment because Valencia proposes to provide more water and serve more customers than it currently does. Ventura asserts that these changes to the environment are potentially significant in at least the following ways: (1) increased groundwater pumping may cause a decrease in water quality; (2) increased groundwater pumping may exacerbate the spread of ammonium perchlorate contamination in the acquifers; ⁷ (3) increased groundwater pumping could detrimentally impact groundwater and surface water flow to down-gradient basins in Ventura County; (4) increased water production could induce additional growth in the area; and (5) overestimation of both groundwater and water from the State Water Project could result in greater and more frequent water shortages. Consequently, Ventura asserts that CEQA requires that an Environmental Impact Report (EIR) be prepared analyzing all the program's environmental effects.