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City of Santa Ana—Cabrillo Town Center Project May 16,2023 Page 9of12 IV. THE WATER ASSESSMENT SUPPLY ASSESSMENT FAILS TO ADEQUATELY CONSIDER ALL PERTINENT FACTORS California Water Code Section 10910, PRC section 21151.9, and SB 610 require large projects be reviewed individually for water supply sufficiency via a Water Supply Assessment document. SB 610 takes a significant step toward managing the demand of California's water supply as it provides regulations and incentives to preserve and protect future water needs. The intent of this bill is to coordinate local water supply and land use decisions to help provide California's cities, farms, and industrial developments with adequate water supplies. Accordingly, the City must concur that adequate water supply exists for residential development projects consisting of 500 dwelling units or more before development may proceed. Here, separate from the fact that the Water Supply Assessment constituted piecemealed environmental review and post hoc rationalization as noted above, it also remains manifestly inadequate for several reasons. First, although the Project intends to incorporate amenities such as a pool, fitness room, and a spa (Water Supply Assessment at 6), it appears as though the water consumption for these amenities were not considered in the Project's estimated water use. Rather, the Assessment provides that: The total project residential water demands include estimates of both indoor and outdoor water demands. Indoor water demands include toilet-flushing, showers, baths, dishwashers, washing machines, faucets, and leakage. Outdoor water demands include landscape irrigation estimates. Water Supply Assessment at 11. Accordingly, the assessment's estimate of water consumption for the Project fails to include critical water consuming elements, thereby significantly underestimating the Project's water use. Second, the Water Assessment appears to calculate the Project's water demand per dwelling unit, disregarding its size. See Water Supply Assessment at 31. Such method of calculation is flawed because as the Water Assessment acknowledges in the table below, not every unit contains the same amount of bedrooms.