EXHIBIT
17-B
DRAFT
October 10, 2006
Jensen Uchida, Deputy Project Manager
California Public Utilities Commission
Energy Division, Room 4A
505 Van Ness Avenue
San Francisco, CA 94102
Subject: Coastal Water Project (Application No. A.04-09-019)
Dear Mr. Uchida:
The Monterey Peninsula Water Management District (MPWMD or District) appreciates the opportunity to comment on the Notice of Preparation (NOP) of an Environmental Impact Report (EIR) for the Coastal Water Project (CWP) proposed by California American Water (CAW or Cal-Am). The District is responsible for the integrated management of water resources within its boundaries, which includes almost all of the service area of Cal-Am’s main water distribution system in the Monterey Peninsula area. This system is regulated by the District and, if expanded as proposed, will require a water distribution permit amendment. The District’s comments are presented below and correspond to sections in the NOP.
Page 1, third paragraph: The EIR should clarify which systems in Cal-Am’s Monterey District will be served by the CWP. The discussion in Section 2 seems to focus on Cal-Am’s “main” water distribution system that presently produces water from wells in the Carmel Valley Alluvial Aquifer and wells in the coastal area of the Seaside Groundwater Basin. Cal-Am also owns and operates three systems in the Laguna Seca Subarea of the Seaside Basin: Ryan Ranch Unit, Bishop Unit, and Hidden Hills Unit. The EIR should describe these smaller “units” and indicate whether or not they will be served by the CWP.
Page 2, second paragraph: As discussed above, references to Cal-Am’s “Monterey District” should be clarified in the EIR. The 10,730 acre-feet per year (afy) amount the SWRCB found in Order 95-10 that was being diverted without a valid basis of right was specific to Cal-Am’s main system and did not apply to the other systems in Cal-Am’s Monterey District.
Page 2, fourth paragraph: The EIR should provide background on the Seaside Groundwater Basin adjudication and its limits on current and future extractions from the basin.
Project Objectives
Page 4, second paragraph: The EIR should clarify whether or not the CWP is designed to protect the long-term reliability of the coastal subareas, inland subareas, or both, of the Seaside Basin.
Applicant’s Proposed Project
Page 4, third paragraph: As described, the proposed seawater desalination plant would produce a total of 11,730 afy, with 10,730 afy for customers within Cal-Am’s main system and an additional 1,000 afy to restore the Seaside Groundwater Basin. Since Cal-Am submitted its application in 2004, the magnitude of the overdraft condition in the Seaside Basin has increased. Based on the final decision in the adjudication, the current overdraft is approximately 2,600 afy[1]. The EIR should account for this updated information.
Desalinated Water Conveyance System
Page 7, fourth paragraph: The EIR should clarify the conditions under which desalinated water would be pumped to the ASR system and confirm that this water would be injected into the basin.
Aquifer Storage and Recovery
Page 8, third paragraph: The EIR should distinguish between the capacity of the ASR system and the expected yield of the ASR system. Specifically, the basis that the “minimum capacity of the ASR system would be 1,300 afy” should be explained and substantiated.
Alternative Project Size
Page 9, seventh paragraph: As discussed above, the EIR needs to specify which systems within Cal-Am’s Monterey District will receive water from the CWP. Similarly, in summarizing “existing and planned water demand”, the EIR should explain and substantiate the basis for the different demand levels that are assumed. The water demand analysis in the EIR should utilize the information developed by the District and presented at a March 23, 2006 workshop, Water Needs Analysis: Existing Setting and Demand, and at a May 18, 2006 workshop, Water Needs Analysis: Future Water Needs.
Also, as part of “identifying existing conservation practices and recycled water project and other water supply projects proposed to meet water demand within the CAW service area”, the EIR should include an estimate of the likelihood that these projects will be implemented and perform as proposed in a timeframe comparable to the CWP.
The CWP should be sized to meet the dry-year demands of (1) customers in Cal-Am’s main system that derives its sources of supply from the Carmel River system and coastal subareas of the Seaside Groundwater Basin and (2) customers in Cal-Am’s smaller systems that derive their source of supply from the Laguna Seca Subarea of the Seaside Groundwater Basin. In estimating existing water demand, the EIR should consider recent actual production.
Population and Housing
Page 13, ninth paragraph: This section suggests that the proposed project could be growth inducing. The EIR should include a separate section on growth-inducing impacts that discusses how the proposed project could directly or indirectly lead to economic, population, or housing growth. The EIR should also include a separate section on cumulative impacts that assesses the change in the environment that results from the incremental impact of the project when added to other, closely related past, present, or reasonably foreseeable future projects.
Thank you for the opportunity to comment on the Notice of Preparation of an Environmental Impact Report for the Coastal Water Project proposed by California American Water. We trust that our comments will be addressed in the Draft EIR for the project. If you have any questions or would like to discuss our comments, please contact our Project Manager, Henrietta Stern, at 831/658-5621.
Sincerely,
David A. Berger
General Manager
cc: MPWMD Board of Directors
MPWMD General Counsel David Laredo
MPWMD Project Manager Henrietta Stern
U:\staff\word\boardpacket\2006\2006boardpackets\20061016\ActionItems\17\item17_exh17b.doc
[1] This estimate of current overdraft is based on the Operating Safe Yield (5,600 afy) specified in the decision minus the Natural Safe Yield (3,000 afy) initially assumed in the decision.