Subject: Support of the MPWMD Desalination Project

February 28, 2008

Chair
Monterey Peninsula Water Management District
P.O. Box 85
Monterey, CA 93942

Subject:  Support of the MPWMD Desalination Project

Dear Chair and Members of the Board of Directors:

Based on water studies conducted by the League of Women Voters of the Monterey Peninsula in 1982 and 1995, we support development of a long-term water supply with priority given to sustainable growth, protecting the Carmel River and meeting the needs of existing customers.   In consideration of our water position and analysis of the current water crisis, the League urges the Monterey Peninsula Water Management District (MPWMD) to pursue with all deliberate speed its resurrected desalination plant. The advantages are enormous for water users and ratepayers, the economy, the environment, and the entire Monterey Peninsula community.

In 1995, the State Water Resources Control Board (SWRCB)  issued Order WR 95-10, which demanded a halt to the overdraft of the Carmel River for Monterey Peninsula water use.  Full implementation of the Order was delayed to give time for  California American Water (Cal Am) and the MPWMD to develop water supply alternatives.  Since 1995, the two entities have pursued numerous water supply options, all without success.   After defeat of efforts to build a dam on the Carmel River, attention was given to desalination of seawater.  Specific proposals were initiated by MPWMD and Cal Am.  The process for a  MPWMD desalination plant to be located  at Sand City was 80% completed when a new majority on the District Board of Directors placed it on hold  in 2004.  It was re-activated in January 2008.  In the meantime, Cal Am in response to State legislation and the California Public Utilities Commission (CPUC) pursued the Coastal Water Project which includes building a desalination plant in Moss Landing or other north coastal areas and transporting water to the Peninsula.

In addition, there have been other proposals: a) Pajaro Sunny Mesa desalination plant  to substitute for Cal Am's proposal; and b) an offshore desalination vessel to pipe or barge water ashore. There are also small desalination proposals to provide water for local growth rather than to address Order WR 95-10.   They include: a) City of Sand City plant;  b) City of Monterey plant for the Ocean View Plaza development; c) another City of Monterey plant for future development.  Adding further complexity (yet some call it clarity) are plans to locate a desalination plant in Marina near the Monterey Regional Water Pollution Control Agency wastewater treatment and reclamation plant to address countywide needs including needs for the Monterey Peninsula.

Water issues are not simple and never have been. However a new urgency has developed with the SWRCB’s January 2008 announcement to issue a “cease and desist” order setting a new schedule for compliance with Order WR 95-10 and including possible penalties for failure to meet deadlines. The order is directed to Cal Am.  Financial penalties can be passed on to consumers with approval of the CPUC, which it has done so in the past.
All the desalination proposals mentioned above are active.  However the recent cease and desist order now focuses urgent attention on the Carmel River. The only desalination proposals capable of competing with these new deadlines are the MPWMD’s proposal, the Cal Am Coastal Water Project, and the emerging “countywide plan” centered near Marina.  Of the three, only the MPWMD proposal is sharply focused on resolving Order WR 95-10.  Also, it might avoid delays related to complexity due to many participating agencies, project size, and the attempt to address many issues at one time.

The LWVMP recommends all possible effort be made to complete the MPWMD proposed desalination project in Sand City. The League has come to this conclusion for many reasons.

1. A sharply focused desalination program to directly address Order WR 95-10 demands has the greatest possibility to be processed quickly and successfully because it is simple, clear, unencumbered by other issues, and could fold into a larger regional effort that will take longer.

2. The smaller size of the MPWMD proposal may have cost advantages.

3. In contrast to other proposals, a sharply focused plan is unlikely to draw litigation because it is restorative and necessary, thus speeding the process.

4. This plan places the responsibility clearly in local hands.

5. The significant early MPWMD investment in this project will not be wasted.

6. This sharply focused plan can proceed rapidly because it will minimize contentious and potentially litigious elements related to population growth.

7. This has the potential to avoid extraordinary customer costs related to delays and litigation.

8. Other advantages include:

    a. Water conservation can likely increase with a fully local effort. Water conservation should receive greater emphasis since a paradigm shift in attitudes about water use in a water scarce environment is essential.
    b. There is a great distaste by customers to continue to pay to Cal Am needless charges for failed attempts, and for paying for a proposed desalination in North Monterey County (or Marina) which may not come to pass.
    c. A countywide plan premised on a Marina location may take longer than necessary because the issue of growth is integral to it, and the plan may attract litigation.
    d. There is unanimous agreement of the MPWMD Board to proceed.

The cease and desist order points out that the Monterey Peninsula population has increased by about 12,000 persons since 1995, without any increase in water supply.  It further concludes that it appears that water savings resulting from conservation efforts have been redirected to support marginal increases in development. These factors demonstrate a substantial risk that Cal Am will continue its unauthorized diversions unless the State Water Board takes further action (State Water Board Cease and Desist Order pp. 4-5).  Swift and deliberate action by the MPWMD is needed now.

Sincerely,

Janet Brennan, President
LWV of the Monterey Peninsula