LWVMP and LWVSV

March 27, 2009

Andrew Barnsdale
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102

Subject: DEIR for Coastal Water Project

Dear Mr. Barnsdale:

The League of Women Voters of the Monterey Peninsula and the League of Women Voters of the Salinas Valley have reviewed the DEIR for the Coastal Water Project and have the following comments:

  1. P. ES-14. Unresolved issues identified in the DEIR include relationships and working agreements between agencies involved in the Regional Project and the future of once through cooling at Moss Landing Power Plant. The following additional issues are unresolved and should be added to the FEIR:

    Timing of the water supply projects based on potential delays. Approval of the desalination project may be problematic since it would be subject to litigation by Salinas Valley property owners with groundwater rights. Project timeliness is critically important to meeting water requirements for the Monterey Peninsula and must be considered in determining the feasibility of water supply alternatives.

    Comparative costs of the projects. Such an analysis is critical to determining the feasibility of water supply alternatives. For example, what are comparative costs for treatment of Salinas River water for 6 months of the year compared to costs for treating wastewater for 12 months of the year for the Seaside Groundwater Replenishment project?

    Public access to setting rates. What options are available to the public to participate in setting rates for the various projects?

  2. P. 2-14, Table 2-5. The table has numerous errors of addition. Footnotes "f" and "g" are reversed. Regarding the line item for Sand City desalination, the chart suggests that 300 AFY water source will be available in 2030. All current plans suggest that 206 AFY will definitely revert to the City of Sand City with some portion of this starting by 2025. This should be noted in the table and also in the narrative.

  3. P. 2-15, Potential Future Supplies. This section identifies sources in Table 2-5 that are "at various stages of planning, and none of them have been approved." The MPWMD 95-10 desalination project is not identified, yet it has the potential to substitute for a great deal of the supply planned for in all three projects evaluated in the DEIR. It should be evaluated in the FEIR.

  4. P. 2-16. Unaccounted for Water Recovery of 300 AFY is based on an assumption rather than specific findings. What are the options available to CalAm to support inclusion of this estimate in the DEIR?

  5. P. 4.2-14. The diversion facility is identified as being on the Salinas River near Spreckels. The correct location should be identified.

  6. P. 5-3. The DEIR states that none of the three projects analyzed in the EIR standing alone would have sufficient capacity to meet total demand. Later the DEIR states (P. 5-3) implementation of feasible water conservation measures and improved inspection and maintenance of water mains to reduce current leakage and evaporative losses would help achieve total water supply objectives for the service area. Based on this information, we assume that all three projects would not meet Order 95-10 and Seaside Basin adjudication requirements. The DEIR should identify how much water is needed to meet regulatory requirements in addition to that supplied by the three projects and how much would be supplied by conservation and maintenance. It should also identify the feasibility of achieving these numbers.

  7. P. 5-7. We urge you to expand Phase I projects to include MRWPCA’s groundwater replenishment program. We think this water source is far more certain than the 2,980 AFY that would come from the Salinas River. We also urge you to make these additional evaluations in this phase: a) stormwater runoff programs as originally included in Phase I of the regional effort, and b) the desalination plant of Monterey Peninsula Water Management District (MPWMD).

  8. P. 7-59. In the Section "Lack of Committed Consumers" there is the statement "…the use of recycled water as potable water source is currently rare in California…". We believe the reference should be to "indirect potable use" and that while it may be rare, it is a viable option for the future. To denigrate the idea in the DEIR is to dampen any interest in the option. There is currently a successful project by Orange County Water District using advanced treated recycled water for groundwater recharge. It behooves the CPUC to not make a misrepresentation that may suggest a bias, since indirect potable use via groundwater recharge is a realistic option in stressed water source environment. Additionally, if groundwater recharge were added to Phase I, the desalination component could be reduced in scale, thus reducing environmental impacts and costs to the consumer.

  9. Section 6.8. The Air Quality Analysis fails to address the impact of diesel exhaust from pipeline construction activities on sensitive receptors.

  10. Section 7. The DEIR fails to identify an alternative that would reduce the projects’ significant adverse impact on Climate Change as required by CEQA. Specifically, the DEIR should identify GHG emissions related to an alternative that includes groundwater recharge as part of the RUWAP (up to a maximum of 6,000 AFY), ASR, treatment of stormwater runoff, conservation, and a desalination plant sized to address the remaining needs.

  11. P. 7-60. The analysis of the environmentally superior alternative finds the CalAm and Regional Project similar in impacts. Why does this analysis exclude findings that Phases 1 and 2 of the Regional Project would result in unavoidable significant impacts on facilities resulting from a major earthquake in areas susceptible to liquefaction and unavoidable significant impacts on air quality from increases in emissions of ozone precursors?

  12. P. 8-33. The buildout data for the Monterey County General Plan is 5 years old and should be updated. The DEIR for the Coastal Water Project identifies 2,115 units (1,231 undeveloped residential parcels and 884 major pending residential projects) for the unincorporated portion of the CalAm service area. Table 3-8 of the DEIR for 2007 Draft County General Plan identifies the following new units by 2030:
               Carmel Valley                            251 units
               Greater Monterey Peninsula     1,510 units
               Total                                     1,761 units

    Of this number, 635 are identified as vacant residential lots. It should be noted that a small portion of these numbers are outside the CalAm service area, e.g., Santa Lucia Preserve, unincorporated portions around Marina, etc. and Del Monte Forest.

  13. P. 8-40. The DEIR identifies 3,577 new residents in North Monterey County. Table 3-8 of the DEIR for 2007 Draft County General Plan identifies the following new units by 2030 for this area:
               North County      436 units
               Pajaro                259 units
               Total                  625 units

    Table 3-8 also identifies 625 new units by 2030 for the Castroville Community Plan.

Thank you for the opportunity to comment on the Coastal Water Project DEIR.

Sincerely,

Janet Brennan, President                              MaryEllen Dick, President
LWV of the Monterey Peninsula                      LWV of the Salinas Valley