January 22, 2010

Monterey Peninsula Water Management District
P.O. Box 85
Monterey, CA 93942-0085

Subject: Updating Water Needs

Dear Ladies and Gentlemen:

The League of Women Voters of the Monterey Peninsula (LWVMP) supports continuing evaluations of policies and programs that affect land and resource use. This applies particularly to current plans for new water supplies that will terminate illegal pumping from the Carmel River resource.

Various new water sources have been identified. Three specific proposals have a Final EIR (FEIR) and are under active California Public Utilities Commission (CPUC) deliberation for a decision in 2010.

All three water supply proposals have been based on the MPWMD water needs assessment completed in 2006. This assessment was based on analyses of municipal and county general plans, and information from Cal Am and MPWMD.

Now that a decision by the CPUC appears to be forthcoming in mid-2010, the managing agencies and providers are gearing up for detailed planning for implementation. LWVMP requests that MPWMD update its water needs assessment to reflect recent decisions and the latest information. Our request is fourfold:

1. Reflect all the relevant data that apply strictly to 95-10 compliance;
2. Reflect the demands of state regulators (CPUC and SWRCB)
3. Avoid overbuilding a desal supply facility
4. Avoid unnecessary and inappropriate costs to ratepayers

Recent data and decisions include the following:

1. Los Padres Dam capacity data, developed by MPWMD and Cal Am in 2008, reflects perhaps 400 AF more than that contained in the water needs assessment that reflected data and projections from 1998.
2. Cal Am is actively pursuing 125 AFY of Pebble Beach Community Service District recycled water to replace potable water use at Pacific Grove Golf Course. This effort is consistent with a recent CPUC General Rate Case decision that orders Cal Am to pursue small projects
3. Although conservation estimates were quantified and discussed in the Draft EIR (DEIR) and FEIR, none of this data has been included in the equations to determine water need. Both the CPUC and the State Water Resources Control Board (SWRCB) have identified and expected results from conservation efforts. The best guess of these savings should be included in an update.
4. Cal Am has been pressured by CPUC and SWRCB to reduce water loss by fixing more leaks. Specifically CPUC has granted Cal Am the resources (in 2009 General Rate Case A0108024) for three projects:
   1. Replace water mains in Seaside and Pacific Grove
   2. Replace polybutylene connections
   3. Replace meters

All three were proposed by Cal Am to reduce water loss. Since they were approved and funded by CPUC, anticipated savings must be calculated and included in an update.

1. Steeper water rates will become effective in early 2010. Excessive irrigation has been regularly pinpointed as a major cause of needless water waste. Cal Am and MPWMD have targeted such users for water audits and aggressive follow up. Impacts from these efforts should be identifiable by mid-2010. These projections should be included in new water need calculations.
2. MPWMD has a long track record of identifiable water savings from retrofits and rebates. Recent MWD expansions should generate new water savings. These should be calculated and projected in new assessment.
3. We take issue with MPWMD inclusion of a drought reserve in the calculations for current needs in compliance with Order 95-10. We can understand the desire for a level of protection, but the conservation stages do the same thing, at far less cost. The intent to comply with 95-10 must conform to the original intent of 95-10—to reduce illegal pumping. A reserve is not a use, and falls outside 95-10. It seems the MPWMD is trying to insert a use factor that is not included in the purpose of 95-10. Therefore we hope the MPWMD can exclude this factor, and not burden the ratepayer for costs that are outside Order 95-10

Marina Coast Water District (MCWD) and Monterey Regional Water Pollution Control Agency (MRWPCA) are expanding Recycled Urban Water Augmentation Project (RUWAP) beyond what is addressed in the FEIR for the Coastal Water Project. The Hybrid RUWAP, which is actively being pursued, would produce 3,000 AFY instead of the 1,000 AFY identified in the FEIR. The Monterey Peninsula would receive 300 AFY of this amount at a cost less than estimated desal costs. This project is on a time line very similar to the regional desal solution, and therefore should be included.

The timing of any update will be critical. The very expensive desalination facility will be based on your data. Lack of a recalculation may lead to sizing and construction that go beyond the requirements of Order 95-10. This could lead surreptitiously to water for growth, which would be a cynical outcome after all agencies assert that all current plans are for no-growth.

At this late stage, a recalculation is necessary for all agencies involved. Planning assumptions are being made. It is critical for all agencies to use all relevant and the most current information possible. This should include all reasonable calculations made by state agencies, expectations for funded projects, and it should exclude factors that are outside Order 95-10 compliance requirements. Only then can ratepayers be expected to understand the enormously high costs coming from the regional desal solution. And only then can providers plan properly to meet the urgent and legally required water needs.

Sincerely yours,

Dennis Mar, President
LWV of the Monterey Peninsula