RESPONSE TO COMMENTS IN MAY NOTICE OF INCOMPLETE …...the supporting authorization were included in our May 31, 2011 response regarding the overall Regional Desalination Project CDP

Page 1 of 214.1.B Response to CCC Slant Well CDP comment letter.docx

RESPONSE TO COMMENTS IN MAY 13, 2011 NOTICE OF INCOMPLETE PERMIT APPLICATION

FOR SLANT TEST WELL PROJECT

Comment 1: Page 2 – As you know, agreement to conduct the consolidated permit process requires

concurrence from the applicant, the local jurisdictions within which a CDP would be required, and the

Coastal Commission. The application included concurrence in the form of letters by officials within

the invoiced jurisdictions. Please provide evidence that the Local Coastal Programs, ordinances or

other authorities of these jurisdictions allow these officials to provide the necessary concurrence, or

alternatively, provide a resolution from the governing body of each jurisdiction providing the

necessary concurrence.

There are four Local Coastal Programs (LCPs) in which the Regional Desalination Project will be located;

of these, the City of Monterey’s LCP is a partially‐approved LCP and requires the Coastal Commission

approval of Coastal Development Permit (CDP) applications. Evidence that the LCPs have allowed these

officials to provide the necessary concurrence have been included in the overall CDP application

submitted on March 31, 2011 (Application No. E‐11‐009). Additional copies of those concurrences and

the supporting authorization were included in our May 31, 2011 response regarding the overall Regional

Desalination Project CDP application. Additionally, copies of City of Marina documents have been

included here as Attachment A. The City of Marina is the LCP in which the Slant Test Well is located.

Comment 2: Page 2 –The Commission’s consolidated permit process also requires that public

participation not be substantially impaired due to the consolidation. As part of our consideration of

the requested consolidated review, please identify all measures that have or will be taken to

maximize public participation within each affected jurisdiction, including all required public noticing

requirements and public hearings for discretional approvals, solicitation of comments, etc.

The following summarizes public participation activities that have been conducted to date for the overall

Monterey Bay Regional Desalination Project (which includes the Test Well Program) and those

anticipated to be implemented in the future.

Public Participation in Coastal Water Project EIR Process

Pursuant to the California Environmental Quality Act (CEQA), Public Resources Code Sections 21000 et

seq. and the CEQA Guidelines, California Code Regulations, Title 14, Sections 15000 et seq. (collectively

“CEQA”), the California Public Utilities Commission (CPUC) prepared an Environmental Impact Report

(EIR) that analyzes the environmental effects of Project. For the purposes of CEQA, the CPUC is the lead

agency for the EIR, and Monterey County Water Resources Agency (MCWRA) and Marina Coast Water

District (MCWD) are responsible agencies. Pursuant to CEQA Guidelines Section 15096, MCWRA and

MCWD responded to consultation from the CPUC, attended meetings to discuss the scope and content

of the EIR, and commented on the Draft EIR.


A Notice of Preparation (NOP) was prepared by the CPUC pursuant to CEQA to notify interested parties

that it was preparing an EIR to evaluate potential environmental impacts of the Coastal Water Project

(CWP). (The Regional Desalination Project was an alternative to the CWP.) On September 28, 2006, the

NOP was mailed to approximately 230 interested parties, including local, state, and federal agencies;

news publication; and other groups or individuals who had previously expressed interest in the project.

Comments were requested by November 9, 2006. A Notice of Availability (NOA) was also prepared by

the CPUC, (in English, Spanish, and Mandarin) in order to notify potentially interested members of the

public about the availability of the NOP. On October 4, 2006, approximately 38,000 copies of the NOA

were distributed by mail to all California American Water Company (CAW) and Marina Coast Water

District (MCWD) ratepayers, and to owners of properties adjacent to some of the proposed facilities.

The 30‐day project scoping period, which began with the distribution of the NOP and NOA, remained

open through November 9, 2006. During the scoping period, the CPUC held a series of four scoping

meetings in Monterey County including the cities of Castroville, Seaside and Monterey. The meetings

were held as follows:

October 24, 2006, 7:00 P.M. at North Monterey County High School (13990 Castroville Boulevard, in Castroville)

October 25, 2006, 1:30 P.M. at Hyatt Monterey (1 Old Golf Course Road, in Monterey)

October 25, 2006, 7:00 P.M. at Hyatt Monterey (1 Old Golf Course Road, in Monterey)

October 26, 2006, 1:30 P.M. at Embassy Suites (1441 Canyon Del Rey Boulevard, in Seaside)

The CPUC placed display ads for the scoping meetings in four newspapers, in three languages, on several

different days, as follows:

The Carmel Pinecone, October 20, 2006

El Sol, October 17, 2006



The Salinas Californian, October 19, 2006

The Salinas Californian, October 23, 2006

The Monterey Herald, October 19, 2006

The Monterey Herald, October 22, 2006

At each scoping meeting, CPUC staff and consultants gave presentations on CAW’s application, the

proposed action, and potential alternatives. Following these presentations, meeting participants were

invited to visit one or more of five different stations around the room. Each station involved a different

aspect of the project. Participant questions and comments were recorded on flip charts, and comment

cards were also available for participants to fill out at the meeting or to send in at a later date.


On December 22, 2006, the CPUC issued a scoping report, summarizing issues and concerns identified

by the public and various agencies during the scoping project. The scoping report was available for

review on the Internet and was mailed to agencies and individuals who requested copies

Work Group Meetings

Starting in January 2007, the Division of Ratepayer Advocates (DRA) of the CPUC worked in conjunction

with the University of California Santa Cruz, Center for Integrated Water Research (CIWR) to evaluate

whether there was an alternative regional approach to the CWP that would be less expensive for

ratepayers and that could be presented as an alternative to the CWP. The DRA and the CIWR viewed

public participation as critical to the development of an implementable water supply program and

facilitated a series of public meetings which led to the establishment of the Regional Plan Technical

Work Group, Public Information and Involvement Work Group, and Regional Plenary Oversight Group

(REPOG). The meetings for each group were attended by a wide range of agencies, general public,

interest groups, and other parties and provided a forum for identifying project components, confirming

criteria, evaluating alternatives, assembling portfolios, and establishing a preferred community‐based

regional water supply alternative that addresses the regulatory replacement needs of SWRCB Order 95‐

10 and the Seaside Basin Adjudication.

Many meetings were held in 2007, including a series of three meetings of the Monterey Regional Plan

Work Group (Work Group) facilitated by DRA/UCSC CIWR, four Regional Plenary Oversight Group

(REPOG) meetings, and two meetings of the managers of the local water and wastewater agencies1.

Meeting dates were as follows:

Work Group Meeting 1 July 18, 2007

Work Group Meeting 2 August 22, 2007

REPOG Meeting August 29, 2007

Work Group Meeting 3 September 19, 2007

REPOG Meeting September 26, 2007

Water Managers Meeting October 24, 2007

REPOG Meeting October 31, 2007

Water Managers Meeting December 10, 2007

REPOG Meeting December 18, 2007

The meetings provided a forum for identifying project components, confirming criteria, evaluating

alternatives, assembling water project portfolios, and establishing a preferred local regional water

supply alternative that addresses both the “replacement needs” (Order 95‐10 and Seaside Adjudication)

and the “regional needs.” Presentations and materials are available at the DRA project website2.

1 Castroville Water District (Eric Tynan), Marina Coast Water District (Jim Heitzman), Monterey County Water Resources Agency (Curtis Weeks), Monterey Peninsula Water Management District (Dave Berger and Andy Bell), Monterey Regional Water Pollution Control Agency (Keith Israel) 2 http://ciwr.ucsc.edu/monterey/supply/index.html


Prior to Work Group Meeting 1, project descriptions were gathered from existing documents and from

discussions with community and agency leaders to draft a Project Information table describing each of

the projects and relevant information. A condensed set of project and program evaluation criteria was

established from the Draft Plan of Study prepared by the Work Group on May 25, 20073 and from the

Monterey Peninsula Integrated Regional Water Management Plan (IRWMP).

Draft and Final CWP EIR

As previously mentioned, one result of the Work Group and REPOG meetings was the formation of an

alternative to CAW’s CWP. Presented as the Monterey Regional Water Supply Program (or Regional

Program), the resulting alternative consisted of a portfolio of projects that included desalination,

recycled water use, aquifer storage and recovery, and conservation. The Monterey Bay Regional

Desalination Project is one of the components of the Phase 1 Regional Program evaluated in the CWP

EIR. The Draft EIR was circulated for public review and comment in accordance with CEQA. The Draft EIR

was released on January 30, 2009 with a 75‐day review period that ended on April 1, 2009. During the

review period, the CPUC conducted four public participation meetings: on March 2, 2009 in Seaside (in

both the afternoon and evening), on March 3, 2009 in Castroville, and on March 4, 2009 in Carmel.

Following circulation of the Draft EIR and incorporation of public comments and responses to

comments, the CPUC published the Final EIR on October 30, 2009. The Final EIR was then reviewed by a

CPUC administrative law judge, who submitted a proposed decision to the CPUC concerning certification

of the Final EIR. On December 17, 2009, the CPUC issued Decision D.09‐12‐108, certifying the Final EIR.

Project Website

A project website was launched in 2008 that served to help inform the public regarding the REPOG

process. That website was located on the Internet at www.waterformontereycounty.org. Recently, that

website has been converted into a more project‐specific website that is located on the Internet at

http://mryrdp.org/. The revised website was initiated on May 10, 2011 and currently contains a project

description, project history, project library, cost and schedule information, information on the

Community Involvement Forum (discussed further below) and a means for contacting someone about

the project. Documents relating to the Regional Desalination Project are currently being uploaded to

the project website. Documents currently available include the Water Purchase Agreement, Settlement

Agreement, Coastal Development Permit (CDP) Application and the Coastal Commission response to the

CDP Application. Additional documents will be uploaded as they are completed and become available.

Community Involvement Forum

In addition to the scoping, Work Group and REPOG meetings, as well as the public participation

meetings, held prior to and as part of the EIR review process, a Community Involvement Forum (CIF) has

3 http://ciwr.ucsc.edu/monterey/meetings/DraftPlanofStudyv2.pdf


been established to help the public learn about the design and construction of the Regional Desalination

Project. In these forums, the public is invited to voice their concerns and learn the various aspects of the

Regional Project plan. The Regional Desalination Project CIF meets quarterly on the Monterey

Peninsula, is open to everyone, and provides an opportunity to get involved and learn more about

regional supply issues. The first CIF meeting was held on March 31, 2011 in Pacific Grove. Details of

that meeting, including meeting agenda, presentation and summary, are available at the Project

website4. A second meeting is scheduled for June 15, 2011 in Seaside.

Public Information Specialist

On May 2, 2011, a Request for Statement of Qualifications was issued for the services of a Public

Information Specialist to provide public information services for the Regional Desalination Project.

Statement of Qualifications (SOQ) were submitted on May 23, 2011. The Regional Desalination Project

team is presently reviewing those qualifications, and it is expected a public information specialist will be

retained with Notice to Proceed in late June of 2011.

The objectives of the public information services consist of the following: 1) providing timely and

accurate information about the Project to the public and various stakeholders, 2) coordinating outreach

communications across the multiple Owners’ component projects to provide consistent and responsive

channels for communication with the public, and 3) providing coordination/support materials to a

Community Involvement Forum(CIF) Facilitator who, under a separate subconsultant agreement, is

leading the CIF described above.

The Public Information Consultant will be expected to provide the following:

Development of a Public Communications Plan to guide communications about the project with

the public and stakeholder groups, including identification of key stakeholders, community

education/outreach efforts, and coordination with other outreach activities by the Owners, to

effectively communicate Project goals and status, and address needs of stakeholder groups.

Development and dissemination of general informational materials about the project such as

newsletters, information packets, news releases

Development of technical information for outreach or response to media

Presentations or other support for public meetings

Updating and maintaining the project website.

4 http://www.waterformontereycounty.org/community_forum.php


Comment 3: Page 2 – We would also appreciate identification of any commitment by the involved

jurisdictions to conduct, if deemed necessary by Commission staff, a public hearing to receive

comments and information about the proposed project.

As noted in the previous response, the Project Partners are committed to providing timely public

information and opportunities for public comment. To that end, and in coordination with the City of

Marina, the Partners agree to hold a public hearing on behalf of the Commission on the Monterey Bay

Regional Desalination Project Coastal Development Permit application and the Test Well Program‐

specific Coastal Development Permit applications, if so requested by the Coastal Commission.

Comment 4: Page 2 – Please provide copies of all those permits already approved and a list of all other

discretionary permit and approvals needed to construct and operate elements of the facility located

within the coastal zone.

Table 1, presented below, shows all permits and approvals required for proposed construction and

operation of the Slant Test Well included in the Monterey Bay Regional Desalination Project – Test Well

Program. The application for the State Lands Commission (SLC) lease is presently being prepared; we

are actively coordinating with SLC to obtain the required lease. The remaining permits to be obtained

are ministerial in nature, and will be submitted following receipt of the Coastal Development Permit.

Table 1: Permits Required for Construction and Operation of Slant Test Well Program

Agency or Department Permit or Approval

State Water Resources Control Board, Central Coast Regional Water Quality Control Board

General Construction Activity Storm Water Permit (WQO 99‐08‐DWQ)

General Permit ‐ Waste Discharge Requirements. (Water Code 13000 et seq.) for low threat discharges to land

California Coastal Commission Coastal Development Permit (Public Resources Code 30000 et seq.)

California State Lands Commission Lease for portion of Slant Test Well west of Mean High Tide Line

Monterey County Health Department, Environmental Health Division

Well Construction Permit (MCC, Title 15 Chapter 15.08, Water Wells)

Comment 5: Page 2 – Please also provide completed Local Agency Review Forms (Appendix B of the

CDP Application), including the status of any CEQA analysis along with any CEQA documentation, form

each of the local jurisdictions within which the project‐related development would be located.

A completed Local Agency Review Form for the City of Marina, the LCP in which the Slant Test Well is

located, is included in Attachment B of this letter. The corresponding CEQA documentation was included

with the overall CDP application submitted on March 31, 2011 and the Test Well CDP application

submitted on April 11, 2011.


Comment 6: Page 2 – The proposed wells would intersect an aquifer in an overdrafted groundwater

basin. Please describe whether MCWRA or other entity will need to acquire water rights to use water

from this source. If water rights are needed, please provide evidence demonstrating that MCWRA has

obtained such rights or that it has the ability to acquire such rights (e.g., through eminent domain or

other means). If water rights are needed but cannot be obtained, please describe how absence of

those rights would affect this proposed project – e.g. changes to the proposed well locations, designs,

or operations, whether there are other feasible means to obtain source water, etc.

The response to this comment was provided in our May 31, 2011 submittal on the overall Regional

Desalination Project CDP application. A copy of this response is included as Attachment C to this letter.

Comment 7: Page 2 – Please also demonstrate how the proposed water withdrawals are consistent

with agreements developed to manage the nearby affected surface water and groundwater sources,

including the Seaside Basin Adjudication, the Salinas Basin Management Plan, and any other relevant

provisions of surface water or groundwater management agreements.

The Slant Test Well is expected to extract approximately 95% seawater and only 5% seawater‐intruded

groundwater and will only be operated periodically over a three‐to‐six month period. Therefore, the

Slant Test Well will have no appreciable or long‐term impact on the groundwater basin.

The following discussion pertains to the overall Regional Desalination Project, of which the Slant Test

Well would be one component:

The Seaside Groundwater Basin is distinct from the Salinas Valley Groundwater Basin. The Seaside

Groundwater Basin is located approximately five miles south from the proposed Brackish Source Water

Wells. All of the analyses conducted to date indicate that there will be no impact on groundwater

conditions within the Seaside Basin. Groundwater modeling performed through the North Marina

Groundwater Model (NMGM) shows groundwater levels are nearly identical between the baseline

conditions and proposed project conditions at the southwestern boundary of the model (See DEIR

Appendix E, Figures 12 and 17). The southwestern boundary of the NMGM is located just to the

northeast of Light Fighter Drive. The boundary between the Salinas Valley Groundwater Basin aquifer

system and the Seaside Groundwater Basin is located further to the southwest, with a northeastern

boundary near the Bayonet Golf Course. Since the analyses show minimal change in groundwater

elevations near the southeastern boundary of the NMGM area, and there is a physical boundary

between the Salinas and Seaside Groundwater Basins, there is no evidence there will be any impacts to

the Seaside Basin.

The purpose of the Salinas River Basin Management Plan is to eliminate the seawater intrusion problem

which affects the Salinas River Basin and to provide adequate water supply to meet anticipated water

needs within the Basin through the year 2030.

In the Salinas River Basin, groundwater management activities are led by the Monterey County Water

Resources Agency. MCWRA has a mission and purpose of managing, protecting, and enhancing the


quantity and quality of water and providing specified flood control services for present and future

generations of Monterey County. MCWRA has implemented a number of water resource management

strategies and projects that address the overall health of the Salinas Valley Groundwater Basin, including

water balance, water quality, and seawater intrusion. Initially, MCWRA, through its predecessor agency,

constructed and has since operated Nacimiento and San Antonio Dams and Reservoirs. These two

projects have allowed MCWRA to conserve winter runoff for release during the summer irrigation

season, thereby increasing groundwater recharge via the Salinas River. Through this management

strategy, groundwater levels have been raised above the levels they would have been without the

reservoir operations.

Additionally, the Castroville Seawater Intrusion Project (CSIP) was implemented in 1998 to reduce

groundwater pumping in the greater Castroville area by delivering recycled water for agriculture.

Through implementation of CSIP, MCWRA was able to address approximately 40 to 45% of the

remaining seawater intrusion problem caused by pumping near the coastal zone. The Salinas Valley

Water Project (SVWP) was implemented in 2010 to address the remaining 55 to 60% of the seawater

intrusion problem. Collectively, these two projects, along with other management strategies, have

provided MCWRA a basis to manage the Salinas Valley Groundwater Basin to stop seawater intrusion

and to provide a hydrologically‐balanced basin

The Regional Desalination Project (of which the Test Well Program is part) builds upon the success and is

consistent with the Salinas Basin Management Plan. The Regional Desalination Project will extract a

combination of ocean water and seawater intruded brackish water through the proposed Brackish

Ground Water Wells. The siting and performance of the Brackish Groundwater Wells has been

thoroughly analyzed through the use of existing and enhanced groundwater models to establish their

consistency with the Salinas River Basin Management Plan. The Regional Desalination Project enhances

water quantity through the utilization of a combination of ocean water and groundwater that is too

saline for other uses and enhances water quality through reduction of salinity concentrations in the

intruded aquifer.

Finally, the Regional Desalination Project includes an aquifer storage and recovery component that will

allow for storage of seasonal (wintertime) Carmel River water and desalinated water in the Seaside

Groundwater Basin. As part of the Seaside Basin adjudication, a safe yield was calculated for the basin.

However, as the Regional Desalination Project will not extract groundwater from the Seaside Basin, the

project is aligned with that adjudication agreement. The Seaside Basin adjudication decision also

determined that augmenting the total yield of the basin through artificial groundwater recharge, storage

and recovery served the public interest. To that end, the adjudication decision allocated storage in the

basin to basin users using a formula that involved multiplying each producer’s storage allocation

percentage by the total useable storage space, less space reserved by the Wastermaster. The Regional

Desalination Project will facilitate CAW’s use of this storage space, thereby making the project

consistent with the terms of the Seaside Basin Adjudication and providing direct benefits to the basin

through supplemental groundwater recharge and maintenance of groundwater elevations.


Comment 8: Page 2 – Please also identify/describe any expected effects of the proposed withdrawals

on coastal resources, including those related to agricultural activities and local and regional efforts to

reduce seawater intrusion in this area.

The Slant Test Well is one of two test wells and eight clusters of monitoring wells proposed for

installation as part of the Regional Desalination Project. The Slant Test Well and adjacent monitoring

wells will be constructed and operated to gain valuable information on the hydrologic and hydraulic

characteristics of the basin as well as additional intake water quality data for use in design of the reverse

osmosis treatment system. Pumping from the Slant Test Well will be intermittent and temporary in

nature will not have any long‐term or significant impacts on the groundwater basin.

The overall proposed Regional Desalination Project has an expected benefit to agricultural activities and

to local and regional efforts to reduce seawater intrusion, and no expected effect on environmental

groundwater users. The proposed withdrawals will reduce groundwater levels in (extract from) the 180‐

Foot Aquifer in the immediate vicinity of the wells. This decline in groundwater levels is a key

component of the overall proposed project to protect against seawater intrusion. The reduced

groundwater levels immediately adjacent to the wells will create a trough of lower groundwater levels

near the coast. As groundwater flows from areas of high groundwater to areas of low groundwater

levels (at the well sites), saline groundwater with a source from Monterey Bay will flow toward the

trough and be captured by the proposed wells. The lowered groundwater levels in the immediate

vicinity of the extraction wells eliminates the potential for seawater to be drawn further inland towards

municipal and agricultural supply wells. Thus, the wells create a barrier to seawater intrusion, which has

impacted the basin since the early to mid‐20th century.

Under current conditions, and without the proposed project, the combined operations of Nacimiento

and San Antonio Reservoirs and operations of CSIP and SVWP have resulted in a reversal of the

groundwater gradient, aiding in returning the groundwater flow from the Salinas Valley Groundwater

Basin towards Monterey Bay, which was the historical direction of flow. Until implementation of the two

Reservoirs, CSIP, and later SVWP, seawater intrusion was drawn inland toward agricultural and

municipal production wells, with brackish groundwater reaching nearly as far as the City of Salinas.

Through the operation of the proposed project wells, the project will extract groundwater flows that

have been reversed as a result of CSIP and SVWP. This will result in the gradual lowering of salinity in

the impacted aquifer over a period of decades as low salinity groundwater recharge in the inland

Forebay Area flushes the aquifer, eventually returning portions of the impacted aquifer back to

conditions suitable for beneficial uses by agriculture or others.

While the proposed project wells lower groundwater levels when creating a trough, this condition will

not impact coastal resources as there are no production wells in the area near the wells due to high

salinity in the groundwater; environmental groundwater users, if any, would be sensitive to changes in

the overlying “A” Aquifer, which is above the Salinas Valley Aquitard and is not pumped by the deeper

proposed project wells.


Comment 9: Page 3 – Please clarify whether the information provided with the April 14, 2011 CDP

application submittal is consistent with that contained in the MCWRWA’s April 7, 2011 Coastal Water

Project EIR Addendum.

Included in the April 14, 2011 Test Well CDP application (CDP Application No. 3‐11‐036) was the

Monterey Bay Regional Desalination Project Addendum to the Coastal Water Project – Environmental

Impact Report for the Test Well Program, prepared by MCWRA and dated April 7, 2011. This Addendum

was slightly different than the one included with the CDP application for the overall Regional

Desalination Project (CDP Application No. E‐11‐009) only in that it incorporates information from an

additional biological survey of the MCWD Reservation Road site, conducted in April of 2011. Specifically,

the April 2011 survey identified Monterey spineflower at the MCWD site (the site of the slant test well),

and therefore the corresponding section in Appendix 3 of the Addendum was revised to reflect this

information. The Test Well CDP application submittal is, however, consistent with what is contained in

the Test Well Program Addendum.

Comment 10: Page 3 – The application states that the project expects to determine optimal pumping

rates and confirm long‐term sustainable rates for proposed permanent wells that may be developed

to provide source water for the Regional Desal Project. The full‐scale project assumes development of

up to six wells, which could include a slant well with an expected yield of between 2,600 and 3,000

gallons per minute (gpm). Please identify the basis for this expected yield and provide documentation

used to develop this expected yield.

In order to produce 10,500 AF of potable water supply per year, assuming that the treatment facility will

operate at a recovery rate of 44%, 22.7 million gallons per day (mgd) of raw water supply is required. To

achieve this, the project assumed (as described in the CWP EIR) that six wells pumping at up to 2,800

gallons per minute (gpm) would be required (Table 5‐3A on page 5‐22 of the CWP FEIR). Further, the

FEIR also states that the project would be operated, such that on an average annual basis, the project

would produce and deliver the 10,500 AFY of water. While six wells pumping continuously at 2,800 gpm

produces more than the stated 22.7 mgd, the assumed pumping rate of 2,800 gpm was selected to

provide some flexibility in the operational rates of the wells once installed. This flexibility is required

because the actual pumping rate of the wells may vary from the 2,800 gpm assumed based on actual

well capacity (as determined following well installation and development) and because the recovery rate

will be based in part on the salinity concentrations produced at the well sites. Once in operation, the

Brackish Source Water Wells will be operated to meet a flow set point at the desalination plant, and the

volume pumped will be controlled using a combination of Variable Frequency Drive (VFD) pumping

systems and cycling wells on and off.

The assumption of the wells operating at 3,000 gpm is required to meet regulatory requirements for

stressing the aquifer during well testing to determine the zone of influence. So while this production

rate was assumed for testing purposes, the Brackish Source Water Wells will not be operated at this

higher pumping rate.


Our May 31, 2011 response to the Commission’s letter dated April 29, 2011 regarding the CDP

application for the overall Regional Desalination Project included a detailed discussion of the numerical

modeling that was conducted to site the proposed Brackish Source Water Wells (and therefore the

locations of the proposed test wells) and to determine the estimated rate at which the wells would be

pumped. Based on the large amount of hydrogeologic data that is available for the Salinas Valley

Groundwater Basin and the numerical modeling conducted to date, the Partners believe that the model

results provide a high degree of certainty as to the selected/final well locations, the rates at which the

wells would likely be operated, and the usability of those wells as intended for this project.

Comment 11: Page 3 – The application states the water produced during well construction would be

temporarily stored to reduce turbidity and then discharged into an existing injection well. It also

states that the applicant has not yet identified a method to dispose of water that would be extracted

from the well during a long‐term (i.e. 3‐6 month) pump test. Please identify methods considered for

discharge, the status of obtaining the necessary approvals to dispose of pump test water, and provide

the selected or preferred discharge methods, along with any impacts to coastal resources associated

with that method.

At this time, a long‐term pump test is not planned for the Slant Test Well. Necessary data and

information will be gathered from the Slant Test Well during and following well development and from a

short‐term (approximately 24‐hour) aquifer pumping test. As stated in the Slant Test Well CDP

application, water developed during the construction and testing activities will be temporarily stored to

reduce turbidity and then will be discharged to land via an existing on‐site injection well.

Multiple alternatives were considered for on‐ and off‐site water disposal prior to selection of the

existing injection well for water disposal. These other alternatives included:

Ocean disposal from the bluff

Ocean disposal with a water monitor (water cannon)

Ocean disposal via a beach‐based diffuser

Disposal into the local sanitary sewer

Onsite percolation through the existing onsite clarifiers

Onsite percolation through percolation ponds

Offsite disposal via offsite transport/trucking

Offsite disposal into the MRWPCA Outfall via a temporary pipeline along the shoulder of

Highway 1

Offsite disposal into the MRWPCA Outfall via a temporary pipeline located to the east of

Highway 1

Offsite disposal into the MRWPCA Outfall via a temporary pipeline along to the west of Highway

1 (along Dune Road and the Armstrong Ranch property)

Piping from the MCWD Reservation Road site through existing, un‐used piping to a location east

of Del Monte Boulevard where the test water would be either discharged into the existing sewer

system for transport to the Monterey Regional Water Pollution Control (MRWPCA) Agency plant


or discharged via a temporary pipeline installed in existing disturbed rights‐of‐ways for

connection to the MRWPCA outfall.

Each of these options was considered in discussions with the Coastal Commission and Central Coast

Regional Water Quality Control Board (RWQCB) staff, and the selected alternatives (use of the onsite

injection well) was determined to be the most benign disposal method. Further, per discussions with

the Central Coast RWQCB, disposal via the existing on‐site injection well can be achieved via compliance

with the State’s existing General Permit for low threat discharges to land (Order No. 2003‐0003). This

compliance entails preparation and submittal of a Notice of Intent to comply with the General Permit

(which was included in the Slant Test Well CDP Application), and followed by preparation and submittal

of a report following completion of testing. Additionally, recommendation of this permit by the Central

Coast RWQCB (and compliance thereunder) demonstrates that the anticipated impacts from this

discharge are not significant. Should it become necessary to address long‐term operation of the Slant

Test Well, we will return to the Coastal Commission to address any additional permitting issues that

would accompany that operational and test well water disposal scenario.

Comment 12: Page 3 –It appears that portions of the proposed project would be located near areas of

environmentally sensitive habitat, including coastal dune habitat, and the application identifies

several sensitive species that could be present near the project site. Please identify any proposed

locations for project components – e.g., monitoring wells, test equipment, etc. – that have been

identified as ESHA in LCPs or other documents.

Attachment D to this letter identifies where Slant Test Well components will be located relative to

identified environmental sensitive habitat areas (ESHAs) and other sensitive species. The proposed

location of the Slant Test Well has been selected to avoid identified environmentally sensitive habitat

areas.

Comment 13: Page 3 – Please also identify all feasible alternatives to locating the proposed project

developments within the ESHA (e.g. locating within existing disturbed areas instead of non‐developed

areas) and identify any alternative construction and operations methods that would avoid impacts to

ESHA (e.g. directional drilling instead of trenching).

The Regional Desalination Project components have been sited to avoid ESHA and other sensitive

habitats whenever possible, siting facilities in disturbed areas or in or adjacent to paved roadways. As

can be seen in Figure 1, the construction areas required for the Slant Test Well have been relocated at

the MCWD Reservation Road site to avoid sensitive species and habitats. The areas containing sensitive

species, as shown in Figure 1, will be cordoned off to clearly establish those areas as off‐limits to

construction. The environmentally sensitive habitat areas will be clearly designated (and fenced) in the

field to protect these species and critical habitat areas from disturbance during construction activities.

Further, a Restoration Plan has been prepared for the Regional Desalination Project as a whole, defining

an approach for mitigation to reduce the impacts to specific biological resources, as well as various

mitigation measures and recovery plans identified in the EIR (p. 6.4‐8). A copy of this Restoration Plan is


included as Attachment E to this letter. The Restoration Plan supplements the information provided in

the CWP FEIR and provides for the mitigation of potential impacts to the following biological resources:

Monterey spineflower (Chorizanthe pungens var. pungens) – FE/1B5,

Hooker’s manzanita (Arctostaphylos hookeri) – 1B,

Monterey ceanothus (Ceanothus cuneatus var. rigidus) – 4

Coast wallflower (Erysimum ammophilum) – 1B

Sandmat manzanita (Arctostaphylos pumila) – 1B

Kellogg’s horkelia (Horkelia cuneata ssp. sericea) – 1B

Smith’s blue butterfly (Euphilotes enoptes smithi) habitat (buckwheat) – FE

Mitigation goals and methods were developed for both temporary and permanent impacts with an

overall mitigation approach emphasizing onsite mitigation whenever possible. Offsite mitigation is

considered only when necessary as an alternative to, or in conjunction with, onsite restoration. Success

criteria, as defined in the Restoration Plan, are presented for both the temporary and permanent impact

areas and varies depending on the mitigation approach taken.

In addition to the Restoration Plan, the CWP FEIR contains mitigation strategies for each potentially

significant impact to ESHA in the project corridor, including various methods to avoid construction

impacts and implementing water quality improvement measures for coastal discharge.

5 FE: species listed as Federally Endangered under the Endangered Species Act; 1B: California Native Plant Society (CNPS) List 1B, Rare, Threatened or Endangered plants in California and elsewhere; 4: CNPS List 4 – plants of limited distribution

Page 14 of 21 4.1.B Response to CCC Slant Well CDP comment letter.docx

Figure 1: Location of Construction Area at MCWD Reservation Road Site


Comment 14: Page 3 – The application states that the expected project life is up to 50 years and cites

two separate coastal erosion rates for the proposed project location – a 2.7 foot per year rate

identified by the USGS and a 5.5 foot per year rate identified by the Coastal Regional Sediment

Management Project (CRSMP). However, it uses the lesser of the two rates as the basis for its project

siting. Please provide an analysis of the proposed project location based on the CRSMP findings,

including anticipated rates of sea level rise and including a safety factor of at least 1.5.

The Slant Test Well component of the Regional Desalination Project is expected to have a project life of

up to 30 years. Over the 30‐year life of the well, the estimated setback distance is 227 feet from the

current bluff edge, resulting in a safety factor of 2.2. This is explained in more detail in the following

paragraphs.

The California Coastal Commission (CCC) guidelines (Establishing Development Setbacks from Coastal

Bluffs, California Coastal Commission Memorandum W11.5, January 16, 2003) call for an estimation of

bluff edge position projected into the future a minimum of 50 years (CCC‐W11.5, Table 2, Point 1). The

CCC guidelines require that the 50‐year projected bluff edge is determined by a long‐term erosion rate,

based on data with a period of record exceeding 50 years (CCC‐W11.5, Table 2, Point 5). This includes

quiet erosional periods (e.g. 1950’s to 1960’s) as well as more erosive periods (e.g., the 1982‐1983 and

1997‐1998 El Nino events). The long‐term erosion rate used in our analysis to determine the well

setback from the bluff edge was calculated in the United States Geological Survey (USGS) Open File

Report‐1251 (2006) and is based on data from 1910 to 2002, satisfying CCC guidelines. A Technical

Memorandum (TM) entitled Summary of Historical Erosion Rates in the Vicinity of the Marina Coast

Water District Marina State Beach (MCWRA, 2010) was developed to determine an adequate set‐back

distance from the existing coastal bluff for a proposed Slant Test Well entry point which will be

constructed in the vicinity of the MCWD Office Site, located near Marina State Beach, Marina, California.

The location of the proposed test well represents the southern‐most location of the proposed well field,

and is one of the project locations closest to the shoreline. A copy of this TM is included as Attachment

F.

As part of the TM, a literature review of existing published erosion rates in the Project area was

conducted. Results of the review are summarized in Table 1 below. A coastal erosion study by the USGS

and published in the Journal of Coastal Research is entitled Rates and Trends of Coastal Change in

California and the Regional Behavior of the Beach and Cliff System (Hapke, et al, 2009). This study

calculated an average long‐term shoreline erosion rate for Monterey Bay of 1.97 ft/yr using Light

Detection and Ranging (LIDAR) remotely sensed data. The 2009 publication was based on the USGS

Open File Report‐2006‐ 1219 (Hapke, et al, 2006) where the average long‐term shoreline erosion rate of

1.97 ft/yr based on remotely‐sensed LIDAR data was first reported. More detailed studies have shown

that the long‐term shoreline erosion rate varies along the coast of Monterey Bay, from an average of

1.97 ft/yr to a maximum of 5.9 ft/yr (see Table 2). However, neither the average nor the maximum long‐

term shoreline erosion rates accurately represents the potential erosion at the proposed Slant Test Well

site. In order to estimate long‐term erosion at the site and in the immediate area, long‐term erosion

transects (vectors) from the USGS Open File Report (OFR) 2006‐ 1251, entitled USGS National


Assessment of Shoreline Change: A GIS Compilation of Vector Shorelines and Associated Shoreline

Change Data for the Sandy Shorelines of the California Coast, were used. These long‐term coastal

erosion rate transects are shown on Figure 2.

Table 2: Published Bluff/Cliff Erosion Rates

Source of Information

Location/Description

Erosion Type

Erosion Rates

m/yr ft/yr

USGS OFR 2007‐1112 (Cliff Edges)

Short Term Maximum Transects near MCWD Site Area

Bluff/Cliff Edges

0.45 1.48

USGS OFR 2007‐1133, Table 4 Average Cliff Retreat Rate for Monterey Bay

Bluff/Cliff Edges

0.4 1.31

Surfrider Foundation At the erosion “hotspots” area located at Opal Cliffs, Depot Hill and Manresa in Santa Cruz County

Bluff/Cliff Edges

0.2 to 0.63

0.66 to 2.0

City of Santa Cruz ‐Personal Communication with Laura Moore

Bluff retreat for City of Santa Cruz Bluff/Cliff Edges

0 to 0.63

0 to 2.0

Journal of Coastal Research Volume 25 Issue 3, Pages 603‐615, May. 2009

Average Long‐Term Shoreline Erosion for Monterey Bay Shoreline 0.6 1.97

USGS OFR 2006‐1219, Page 47 Average Long‐Term Shoreline Erosion for Monterey Bay

Shoreline 0.6 1.97

USGS OFR 2007‐1133, Page 18 Long‐Term Maximum Erosion at Sand City near Fort Ord

Shoreline 1.8 5.9

USGS OFR 2006‐1219, Page 47 Long‐Term Maximum in Monterey Bay at Indian Head Beach

Shoreline 1.3 4.3

USGS OFR 2006‐1251 (Sandy Shorelines)

Short‐Term Maximum Transects for the MCWD Site Area

Shoreline 1.31 4.3

CRSMP Table 11, November 2008

Short‐Term Adjusted for Anticipated Seawater Level Rise

Shoreline 1.67 5.5

USGS OFR 2006‐1251 (Sandy Shorelines)

Long‐Term Maximum Transects for the MCWD Site Area

Shoreline 0.81 2.7

Source: Summary of Historical Erosion Rates in the Vicinity of the Marina Coast Water District Marina State Beach, Marina, CA (MCWRA,2010)

1. Range of Short-Term Erosion Rates for Area of MCWD Site is 0.17 to 0.60 m/yr 2. Surfrider Foundation’s State of the Beach Report 3. Range of Short-Term Erosion Rates for Area of MCWD Site is 0.78 to 1.31 m/yr 4. Range of Long-Term Erosion Rates for Area of MCWD Site is 0.64 to 0.81 m/yr


Figure 2: Long Term Average Erosional Rates


Figure 2 shows the site‐specific long‐term shoreline erosion rates as calculated by the USGS along

equally spaced transect lines near the MCWD Reservation Road site. Of the four transects (which

intersect the MCWD property), the transect having the highest erosion rate (i.e. 0.81 m/yr ‐‐ 2.7 ft/yr)

was selected to estimate the 50‐yr set‐back CCC requirement. Using a long‐term erosion rate of 2.7

ft/yr, the estimated 50 year setback distance is 135 feet from the current bluff edge. The proposed slant

test well entry point is 227 feet from the bluff edge, which allows a 92‐foot buffer zone (based on the

projected 50‐year bluff edge location). To account for uncertainties in the analysis, CCC suggests using a

safety factor of at least 1.5 (CCC‐W11.5, Page 14). The estimated 92 foot buffer zone allows for a safety

factor of 1.7, providing a sufficient buffer zone to cover uncertainties inherent to the analysis. This

assessment does not, however, account for projected future sea‐level rise.

The Association of Monterey Bay Area Governments report Coastal Regional Sediment Management

Plan for Southern Monterey Bay [CRSMP] (Philip Williams and Associates, November 2008) included an

assessment of future sea‐level rise on Monterey Bay erosional rates. In this report, the CRSMP

evaluated increases in erosional rates based on a sea level rise rate of 3.0 ft/century (one foot over the

next 50 years, assuming an exponentially accelerating rise). As noted in the document, this estimate is

considered precautionary for long‐term planning for sea‐level rise and is in line with Coastal Commission

measures which require consideration of a three‐foot sea‐level rise over the next century. This

estimated 50‐year sea level rise resulted in corresponding incremental shoreline recession rate of

approximately 0.8 feet per year, averaged over the next 50 years. Therefore, using the long‐term

erosion rate of 2.7 ft/yr (as established above) with an incremental increase of 0.8 ft/yr to account for

future projected sea level rise, results in an estimated yearly erosional rate of 3.5 ft/yr. Based on this

rate, the estimated 50 year setback distance becomes 175 feet from the current bluff edge. As noted

above, the proposed slant test well entry point is 227 feet from the bluff edge, which allows for a 52‐

foot buffer zone (based on the projected 50‐year bluff edge location). This corresponds to a factor of

safety (FS) of 1.3. While this FS is less than the 1.5 recommended by the CCC, the anticipated life of this

well is 30 years and the distance projected above is for a 50‐year period. For comparison purposes, using

the erosion rate of 3.5 feet per year and a well setback of 227 feet from the bluff edge (as noted above),

it will take approximately 65 years for the bluff erosion to reach the wellhead location (corresponding to

a factor of safety of 2.2). If the conservative erosion rate of 5.5 ft/yr is used instead (as noted in Table 11

of the CRSMP), which is already adjusted for anticipated sea level rise, it will take approximately 41

years for the bluff erosion to reach the wellhead location (corresponding to a factor of safety of 1.4);

well beyond the anticipated 30‐year operating life of the well.


Comment 15: Page 3 ‐ If the analysis shows that any proposed project components could be affected

by coastal erosion during the anticipated project life, please identify measures, such as relocation of

project components or planned retreat that would avoid or reduce that risk. These measures should

also address potential impacts to coastal resources – e.g., effects of relocation or planned retreat on

ESHA, access, etc. Please note that the project should not rely on shoreline protective devices or bluff

armoring to address coastal erosion impacts.

As described above, the Slant Test Well currently proposed for the Regional Desalination Project at the

MCWD Reservation Road site is situated far enough from the coastal bluff as to be protected through its

operating life of 30 years. When (and if) this well is replaced in 30 years, the well’s location will be re‐

evaluated with respects to coastal erosion and, if found in danger of future erosion, will be relocated

further inland in another location. Such relocation would be subject to environmental review and the

corresponding permitting process at that time.

Comment 16: Page 4 – Please identify the total expected energy use during well construction and

testing and the associated direct and indirect GHG emissions. This should include those associated

with construction vehicle use and those associated with electricity used during pumping.

The proposed Slant Test Well Program has both construction‐ and operation‐related emissions.

Construction emissions are associated with site preparation, drilling and well construction; operational

emissions are associated with pumping for well sampling, and aquifer pumping tests. Because pumping

will involve the use of electricity generated offsite, there are both direct emissions associated with

construction and indirect emissions associated with operations. For purposes of this analysis, the

construction and operational emissions were calculated using separate models.

Construction‐related Emissions

Construction emissions are associated with site preparation, drilling and well construction. To account

for both direct and indirect emissions associated with these activities, the CalEEMod model was used

(CalEEMod Version: CalEEMod 2011.1). The CalEEMod is a statewide land use emissions computer

model designed to provide a uniform platform for government agencies, land use planners, and

environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions

associated with construction from a variety of land use projects. The following inputs were used to run

CalEEMod:

Land Use / Construction Phases

o Land use ‐ light industrial

o Land affected ‐ 28,700 square feet (Slant Test Well Project Description, March 2011)

o Construction schedule – 4 months (Slant Test Well Project Description, March 2011)

o Construction will have two phases: Site Preparation and Drilling/Well Construction

Off Road Vehicles

o Drilling schedule – 120 days

o Site Preparation estimated to use tractors/loaders/backhoes for a single 8 hour period


o Drill rig estimated at 600 HP and drilling estimated at 8 hours per day, 5 days per week

o Fork lift estimated at 4 hours a day

o Trips and Vehicle Miles Traveled (VMT) ‐ Total of 5 hauling trips

Also associated with construction is final well development, which has indirect emissions associated

with electricity usage; final well development inputs assumed that 70 hours of pumping were required

for the latter stages of well development.

The results of the CalEEMod model for construction‐related emissions are included in Attachment G to

this letter.

Operations‐related Emissions

Operational emissions for the Slant Test Well are associated with pumping operations during the

planned short‐term aquifer pumping test and a three‐ to six‐month test operations period. The pumps

that would be used for well development will be powered by electricity, not combustion onsite. As a

result, the emissions are indirect as they are generated by the power producer. In order to obtain an

accurate emission estimate based on specific pumping data, the Local Government Operations Protocol

(Protocol) was used (Local Government Operations Protocol, Version 1.1, May 2010). The Protocol was

designed to provide a standardized set of guidelines to assist local governments in quantifying and

reporting GHG emissions associated with operations. The Protocol was developed in partnership by the

California Air Resources Board (CARB), California Climate Action Registry (CCAR), and ICLEI – Local

Governments for Sustainability (ICLEI), in collaboration with The Climate Registry and dozens of

stakeholders.

The Protocol recommends two approaches to determining emissions associated with electricity use:

1. Utility‐specific emission factors that have been third party verified to the standard of the CCAR

Power/Utility Protocol or The Climate Registry Electric Power Sector Protocol; or

2. eGRID regional default emission factors (by subregion) or California Grid Average Factors

(eGRID2010 Version 1.1, Year 2007 Summary Tables (created May 2011).

The use of eGRID default emissions factors were deemed more appropriate for this application since the

utility specific emission factors provided overall emissions and not a clearly defined emissions per power

unit used. eGRID emission factors for California were provided by eGRID2010 Version 1.1 Year 2007

Summary Tables. The subregion used was CAMX, which includes Western Electricity Coordinating

Council (WECC) California and the region for this project.

Emissions Summary

Emissions were calculated for both construction and operation. Emissions were quantified as carbon

dioxide equivalent (CO2e) and presented in units of metric tons (MT). CO2e the industry standard

measure for describing how much global warming a given amount of GHG may cause, using the

functionally‐equivalent amount of carbon dioxide (CO2) as the reference. The units of MT are the


industry standard unit of measure for GHG presented as CO2e (Emission Facts: Metrics for Expressing

Greenhouse Gas Emissions: Carbon Equivalents and Carbon Dioxide Equivalents, EPA420‐F‐05‐002,

February 2005). Table 3 summarizes the GHG emissions associated with the proposed Slant Test Well.

Detailed emission information is provided in Attachment G.

Table 3: Slant Test Well Direct and Indirect GHG Emissions

Description GHG Emissions (MT CO2e)

Construction 274.35

Operations 64.13

Total 338.48

As a reference, CEQA analyses use significance thresholds to evaluate project impacts, but there is

significant uncertainty about significance thresholds for GHG. In response to uncertainty about GHG

standards for new projects, CARB developed statewide interim thresholds of significance for common

project types that, collectively, are responsible for substantial GHG emissions. In applying these interim

thresholds, CARB developed a preliminary threshold of 7,000 MT CO2e/yr for industrial projects.

However, this applies to only operations and not construction. CARB is not establishing thresholds for

construction projects, but rather is proposing mandatory performance standards. This threshold,

however, helps to put into perspective the operational emissions associated with the Slant Test Well

project, with an estimated GHG emissions of 388 MT, which is approximately 5% of the CARB

significance threshold of 7,000 MT CO2e/yr.

Attachment A – City of Marina City Council Action and Consolidated Permit

Approach Concurrence Letter

Attachment B – City of Marina Local Agency Review Form

Attachment C – Water Rights Issues Related to the Monterey Regional

Desalination Project (Downey Brand LLP, 2011)

Attachment D – Location of Slant Test Well Facilities relative to ESHAs

Attachment E – Monterey Bay Regional Desalination Project Conceptual Draft

Rare Plant and Habitat Restoration Plan (DD&A, 2011)

Attachment F – Summary of Historical Erosion Rates in the Vicinity of the

Marina Coast Water District Office, Marina State Beach, Marina, California

(Geoscience, 2010)

Attachment G – GHG Emission Results

Attachment H – Updated Slant Test Well CDP Application Materials

Attachment I – Revised Addendum to the Coastal Water Project – Environmental

Impact Report for the Test Well Program (June 6, 2011)