The Environmental Health Bureau is the Department that handles Well Water Supervision.
Since the early 2000's they seem to have engaged in: 1) 20 year hoax on JC Milrod that devalued his 300k property and forced him to live in a trailer 2) the coliform testing hoax 3) the POU/POE hoax 4) the ADU permitting hoax and 5) the latest Hex Chrome 6 hoax.
Since the early 2010, the same three employees have been there overseeing these concerns:
Ric Encarnacion
Marni Flagg
Cheryl Sandoval
What they have been engaging in and covering up should be deemed criminal.
The EHB Demand affects HCD, thus they are presented together.
Demand 2 - EHB Director and Staff - Ric Encarnacion, Marni Flag, Cheryl Sandoval - view gDoc view pdf asWebPage (12/12/2025)
Demand 3 - HCD Director and Staff - Craig Spencer, Josh Bowling, Evan Nuckles, Elizabeth Gonzales - view gDoc view pdf (12/22/2025)
Exhibit - Pre-Notice Email sent 12/17/2025 view pdf
Exhibit - Proposed ADU/JrADU Guide view gDoc
Exhibit - Non-Email Exhibits view gDoc
Exhibit - Relevant Emails ( see below )
NOTE: These issues have been deeply frustrating and counterproductive, often requiring extraordinary applicant effort for basic progress. I have documented and shared the supporting emails publicly because the patterns are difficult to credit without direct evidence—and ultimate resolution requires transparency to drive meaningful reforms.
20 year permitting Hoax - Jewish Chiropractor JC Milrod was declined a building permit for his home. He had written permission to become the third connection on an existing two connection well system. The water test for the well return a high nitrates reading and the EHB and HCD declared that was enough to block his permit -- when no such law was on the books. We know that, because they created it with the POU/POE ordinance in 2023. During that process they were applying statutes that may or may not have applied to systems for 15 connections and above (public wells) to a private well. JC was first declined in the early 2000's and then again in the mid 2010s when Encarnaction, Flagg and Sandoval were all engaged. Nitrates are a disputed contaminate. One fix was to simply buy water at water kiosks as many people do. Another was to install a simple water filter, and neither were teh county's business given it was a well with 14 connections or less. The land was devalued without the ability to connect to water. He moved a trailer on, connected a hose to the well he was not allowed to connect to and he illegally lived on the lot, while accumulating fines for living on the lot for 20 years prior to passing in 2025 with the matter unresolved. Some might call this 'civil terrorism' . A demand for positions statements was sent and it was ignored.
Coliform Testing Hoax - Coliform is a non harmful bacteria. It is common like pollen in springtime. it is cheap to test for in water. They test well water for coliform and if it fails it suggests to them the system had lost it's seal. There are a lot of false positives. You have coliform on hands and on water screens that filter your water at the tap, so it is more sensitive than your hands. If/when there is a test fail, system members are told they must stop consuming the water, treat with Chlorine and retest and if the retest comes back positive, they are safe to drink again. The problem? If parasites', yeasts, mold or other fungus got into the system or were always in the system, that was not being tested for, and the EHB in a video specifically talks about parasite concerns. Nobody should have ever been "relying" on the EHB standards to ensure clean drinking water, and they certainly should not have been relying on this "testing process" to declare water safe to drink. They over regulated and under educated for decades.
POU/POE Hoax - Title 22 defines public water systems as those with more than 14 connections, and private water systems with 14 or less connections.
Title 22 currently requires "public wells" to provide "potable water" to all connections at all times. This is in fact illogical but they got trapped by title 22 regulation in 1995.
The average person only drinks 7 drops of water for every 1000 drops of water they use for all domestic activities.
Why would you require people to make sure all 1000 drops of water are treated when only 7 may be consumed
Why wouldn't you just allow people who are on a well to decide if/when and how they are going to treat their water?
The theory is they didn't want people drinking contaminated water -- the low cost solution for that is to educate people on water quality and tell them the risks of drinking non filtered water and that's where the state and federal government should have stopped. but they did not. Why?
If you saw the amount of money and control the for profit vendors, required "operators" for the systems, and the "spin off grants" that are being generated for making 1000 out of 1000 drops of water potable -- by regulation - not choice, it would make sense. It was a commercial bonanza.
But there is something worse -- i have discovered that the protocols the EHB was using to declare water unsave and save, via coliform testing are a hoax. 1) coliform is not harmful it's just in indicator something may have gotten into the system (ie a leak or a lid left off a tank). Think of it as non-harmful pollen. 2) the test itself was more like a pressure test not proof anything harmful got in 3) the fix for a bad coliform test is bleach to kill the bacteria -- but you are just resettting the control -- not necessarily killing all that mayhave gotten in (like parasites) 4) they are not doing nor requiring any testing for parasites, mold fungus (while stating outside of Title 22 that parasites are a concern). AND people have actually been "trusting" the EHB and this coliform testing for go-nogo on water quality when it was all a hoax -- and if parasites got into the water 20 years ago they my have happily played in it for 20 years with no oversight. (False sense of security was created by the oversight).
Title 22 currently does NOT require "private wells" to provide "potable water" to all connections at all times. The wording of it all is confusing but Grok has reviewed this three times and come up with same answer every time.
It requires courtesy testing and notice to well systems but no enforceable potable water requirement.
What they started out doing with this POU/POE ordinance in 2018 was bizarre.
They wanted to force potable water on well systems with 14 connections or less in violation of title 22 and they did it under the guise of "affordable water for all" and they claimed "bottled water" was too expensive, while excluding water kiosks completely (1, 3 and 5 gallon jugs refilled ) The entire community was up and arms and the EHB people were batting them around like slaves. It made no sense. They were being commercially driving in what appeared to be a fascist manner for some commercial interest ( filtration companies, farmers to relieve burden from polluting water with nitrates, to position people for grant money for full system filtration, etc) When the leader of the opposition when to the board meeting, which are only during day on Tuesdays so no normal people can participate, they made it such that her button to trigger the microphone and her turn in the queue didn't work. (these people are f--king evil).
HOWEVER, then something else stranger happened. After they got it through, there was a lawsuit that postponed it. And then covid hit and it was delayed. the outcome of that lawsuit was NOT what most of us thought. We thought they had stopped it due to violation of title 22, illogical use of "bottled water" for cost analysis, etc. NO. It was about what is described below -- which had to do with denying permits for wells that test "contaminated". The problem there is "contamination" happens to these things all the time -- and people work around it with minor things like bleach or more major systems like water filters OR they just buy water. So why were they doing it? Real estate owners and controllers in the Coastal Zone do NOT want more construction -- because without it their property values skyrocket. Others will say they don't want it because they are environmentalists -- but there's also "land use" issues -- if the land has "contaminated water" for drinking -- it's highest use is farmland....
So the bottom line is that wealthy landowners, farmers and corporations are using absurd water quality ordinances on well systems for burden and to suppress growth (and to increase housing stress).
ADU Permitting Hoax - Detailed above in the POU/POE Hoax in the last paragraph . This is where the POU/POE ordinandce was established with a caveat that could be used to block new develpment and ADU permits due to contaminents, including Nitrates, which are not, in fact part of standard testing for any wells with below 14 connections. In addition a 9 year delay transpired for an ordinance for ADUs in the Coastal Zone after a 2016 mandate was issued by the state to assist with house stress. That was resolved AFTER the odd hex Chrome 6 legislation was passed which added an additional faux contamination item to assist with further suppressing ADUs permits.
Hex Chrome 6 Hoax - In 2024, California passed a law adding Hex Chrome 6 to the list of drinking contaminates. The maximum permissible level for public water systems was set at 10ppb. That is 10x more stringent than any other specification for hex chrome in the country AND those are for all hex chrome, not just Hex Chrome 6. As it turns out, Hex Chrome 6 is not harmful to drink it's only harmful to smoke, yet this law was created to establish drinking water contamination limits. After establishing this outlandish specification, a grant was given to Monterey County to run testing on they wells they had access to, (2 connections and above) and because hex chrome 6 is found in red clay and there is a lot of red clay in North County, a lot of wells were black balled as contaminated. Only after this outlandish process for tagging wells was complete did Monterey County then approve the ADU in the Coastal Zone ordinance, 9 years late, and after having disqualified many homes from participating in the ADU buildout process.