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A.4 ALTERNATIVE WATER RESOURCE PLANS This section focuses on feasibility and environmental characteristics of alternative water resource plans derived from the qualitative review presented in Section A.3, in compliance with CEQA. As described in Section 15126(d) of the State CEQA Guidelines, an EIR should: describe a range of reasonable alternatives to the [proposed] project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. "Feasible" is defined in Section 15364 as "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social and technological factors". Section 15126(d)(5) of the State CEQA Guidelines states: The range of alternatives required in an EIR is governed by a "rule of reason" that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Section 15126(d)(3) notes that "the significant effects of the alternative shall be discussed, but in less detail than the significant effects of the project as proposed." Section 15126(d)(5)(B) describes when an EIR may rely on previous evaluations of alternatives; Section 15126(d)(5)(C) asserts that "an EIR need not consider alternatives whose effect cannot be reasonably ascertained and whose implementation is remote and speculative." Section 15126(d)(5)(A) of the State CEQA Guidelines describes six factors that may be taken into account in a discussion of feasibility:
California AB 1182, signed into law in September 1998, requires the CPUC to identify an alternative "contingency plan" that would be implemented if the CRDRP does not come to fruition. Preliminary comparative environmental, drought protection, cost, and feasibility information for selected alternative resource plans has been analyzed in accordance with CEQA and is provided in this appendix. These data could serve as a springboard for more detailed future evaluations by the CPUC and other entities that are beyond the scope of this SEIR. In compliance with CEQA, the following tasks were performed with relation to the CRDRP and alternatives that could address adverse effects of the project:
This section and supporting documentation also provide basic comparative data for the options evaluated. Any conclusion about a preferred alternative water resource plan is beyond the scope of this SEIR. As part of this process, more than 100 computer simulations were performed for individual and combination projects, including desalination projects of various sizes, injection/recovery in the Seaside Basin, dredging Los Padres Reservoir to full capacity, and increasing conservation and reclamation efforts to permanently reduce community water use. The goal of the simulations was to determine which individual and combination projects could result in no more than 3,376 af/yr of diversions by Cal-Am from the Carmel River Basin, unless noted otherwise. This amount is Cal-Am’s recognized water right under SWRCB Order WR 95-10. Unless noted otherwise, all simulations assumed that community water demand was at the existing Cal-Am total system production limit of 17,641 af/yr set by MPWMD as part of its Water Allocation Program. All simulations assumed that no water would be available for new construction on legal lots of record or remodels. The first set of simulations focused on individual desalination projects. The second set of simulations combined desalination and Seaside Basin injection/recovery (with existing and expanded Cal-Am facilities for treating and transferring water from Carmel Valley to the Seaside Basin). The third set of simulations combined desalination, Seaside Basin injection/recovery, and dredging Los Padres Reservoir to its original capacity (an increase in storage capacity of 854 af). The fourth set of simulations combined desalination, Seaside Basin injection/recovery, dredging Los Padres Reservoir, and additional conservation and reclamation above and beyond existing efforts to result in a permanent 800-af reduction in community water use (i.e., a Cal-Am system production amount of 16,850 af/yr rather than the existing limit of 17,641 af/yr). Based on these efforts, the following options were selected for more detailed evaluation and discussion (the order of the options is not intended to suggest any preference): Option 1: – 10.5-MGD stand-alone desalination project in either Marina or Moss Landing – 17,641 af/yr of Cal-Am system production – 3,376 af/yr of maximum Cal-Am diversions from Carmel River Basin for municipal supply Option 2: – 9.0-MGD desalination project in either Marina or Moss Landing – Injection/recovery in Seaside Basin with existing Cal-Am facilities for treating and transferring water from Carmel Valley to the Seaside Basin – 17,641 af/yr of Cal-Am system production – 3,376 af/yr maximum of Cal-Am diversions from Carmel River Basin for municipal supply and up to 3,780 af/yr for injection/recovery Option 3: – 8.0-MGD desalination project in either Marina or Moss Landing – Injection/recovery in Seaside Basin with existing Cal-Am facilities for treating and transferring water from Carmel Valley to the Seaside Basin – Dredging Los Padres Reservoir to original capacity (gain of 854 af storage) – 17,641 af/yr of Cal-Am system production – 4,230 af/yr maximum of Cal-Am diversions from Carmel River Basin for municipal supply (this higher number reflects assumed water rights gained from increased reservoir storage) and up to 3,780 af/yr for injection/recovery Option 4: – 7.5-MGD desalination project in either Marina or Moss Landing – Injection/recovery in Seaside Basin with existing Cal-Am facilities for treating and transferring water from Carmel Valley to the Seaside Basin – Dredging Los Padres Reservoir to original capacity (recovery of 854 af storage) – 16,850 af/yr of Cal-Am system production derived from additional reclamation and conservation efforts that permanently reduce water use by 800 af – 4,230 af/yr maximum of Cal-Am diversions from Carmel River Basin for municipal supply and up to 3,780 af/yr for injection/recovery For all of the options listed above, large quantities of water produced by a desalination plant or recovery of injected water would enter the north end of the Cal-Am distribution system. As a result, substantial improvements would be required to enable the Cal-Am system to receive, treat, and store this water and distribute it to the rest of the Monterey Peninsula. Simulations of injection/recovery with expanded Cal-Am facilities for treating and transferring water from Carmel Valley to the Seaside Basin indicated that gains in reliable yield were modest compared to injection/recovery with existing Cal-Am water transfer facilities and did not warrant the significantly increased cost of the new Cal-Am pipelines, pump station, expanded water treatment plant, and other capital facilities that would be needed. Thus, this variation was not included in any option. A.4.3 DISCUSSION OF ALTERNATIVES AS A MEANS TO REDUCE ADVERSE IMPACTS OF THE CRDRP A.4.3.1 Reduction of CRDRP Impacts Table A-16 summarizes 36 significant (or potentially significant) adverse effects of the CRDRP before mitigation, reviews mitigation measures identified in the NLP EIR and this SEIR, identifies whether the mitigation measures are permit conditions, and notes the level of significance of the impact after mitigation. Of the 36 adverse impacts identified, 23 could be mitigated to a less-than-significant level based on required measures identified in SWRCB and Section 404 permits. For 13 adverse impacts, either recommended mitigation measures were not included as permit conditions or the required action would not reduce the impact to a less-than-significant level. Table A-17 summarizes whether any of the alternatives could reduce the level of significance of the 13 adverse impacts of the CRDRP that are not already mitigated by permit conditions or for which no permit conditions are required. These impacts are:
Refer to Table A-17 for information on each impact. In general, for the hydrology, fishery, and wildlife impacts, the four alternative options evaluated would reduce the CRDRP impact but would not fully mitigate for the adverse effect. For example, in drought years, adverse effects would be associated with lack of streamflow or groundwater drawdown under Options 1-4 as well as under the CRDRP, but the intensity or duration of the effect would be less severe under the alternatives. Construction-related impacts in the Cachagua/Carmel Valley area could be avoided under Options 1 and 2, but these effects may occur elsewhere (e.g., at desalination or injection sites). Construction impacts would likely be exacerbated under Options 3 and 4, which involve dredging of the existing Los Padres Reservoir. Automobile and truck traffic–related impacts (e.g., on noise, air quality, visual resources, and recreation in Cachagua and Carmel Valley) would likely be worse with dredging (Options 3 and 4) than with the CRDRP because of the extremely high density and duration of truck traffic associated with dredging (see Section A.3.3). The four options evaluated would avoid CRDRP impacts on Esselen Native American cultural resources but could affect cultural resources at the alternative site locations. Options 3 and 4 with dredging could affect listed resources known to occur in the existing Los Padres Reservoir inundation area. All four options could result in growth-inducing impacts similar to those of the CRDRP. Assuming that a reliable source of power is available, Options 1-4 would provide superior drought protection that exceeds existing standards. This could indirectly facilitate allocation of 778 af of Cal-Am metered sales for new connections and remodels that are presently unallocated or are set aside as drought reserve. The CRDRP could indirectly result in an allocation of up to 799 af of metered sales, as described in Chapter 10 of this SEIR. A.4.3.2 Feasibility and Environmental Issues Related to Alternative Options Table A-17 summarizes feasibility issues (including economic viability) and environmental concerns relating to the four alternative options. This section expands aspects of that summary. Economic Viability (Cost). Table A-18 provides an overview of estimated costs for the CRDRP and Options 1-4 in terms of capital and O&M costs (in 1998 dollars), total net present value (i.e., funding of all capital and O&M costs through 90 years of project operation, brought back to 1998 levels), and the expected increase in average monthly residential water bill. Table A-19 provides a breakdown of estimated capital and O&M costs for the various project components included in Options 1-4. Capital costs at 1998 price levels were escalated at 3% per year to 2004, the assumed midpoint of project construction. O&M costs were escalated at 3% per year to 2006, the assumed first year of project operation. The cost escalation rates are based on historical cost trends for construction, operation, and maintenance of water supply projects. (Refer to Tables 2-4 and 2-5 in Chapter 2, "Project Description", in this SEIR for a breakdown of costs and estimated annual project costs for the CRDRP.) Capital Costs. As shown in Table A-18, capital costs for Options 1-4 range from $115.5 million to $135 million, or about 8–25% higher than the CRDRP capital cost of $107.4 million (in 1998 dollars). O&M Costs. Estimated O&M costs for the alternatives are about five to six times higher than those for the CRDRP, largely as a result of the extremely high energy use associated with desalination and the substantial amount of pumping involved with injection/recovery. O&M costs for Options 1-4 range from $8.1 million to $9.7 million per year compared to $1.6 million per year with the CRDRP (in 1998 dollars). Net Present Value. For each alternative listed in Table A-18, the total net present value (NPV) was calculated for all project costs from final design and construction through 90 years of project operation (the proposed financing period for the CRDRP). The NPV calculation is a method of comparing costs for projects with different service lives. For example, a dam and reservoir project has a service life of more than 100 years, whereas pumps and wells must typically be replaced every 15–30 years. Comparing the CRDRP with project alternatives that include components with service lives shorter than 90 years requires that those components be replaced during the period of analysis. For the NPV calculation of the alternatives listed in Table A-18, based on typical utility standards for useful service life of water supply facility components, 60% of the facilities (on average) required for a desalination project, a Seaside Basin injection/recovery project, and improvements to the Cal-Am system were estimated to need replacement every 25 years. These components include reverse-osmosis desalting units, pumps, motors, and wells. For purposes of this analysis, the remaining 40% of capital facilities associated with these projects (e.g., distribution mains, storage tanks, and rights-of-way) were estimated to have service lives approaching 90 years or more and not to require replacement during the period of analysis. Capital and O&M costs were projected to increase at 3% per year throughout the analysis period. For all project alternatives, the NPV analysis assumes financing and ownership of the project by Cal-Am. Future annual revenue requirements for funding all capital and O&M costs associated with each alternative were brought to 1998 levels using a 5% discount rate. As shown in Table A-18, the total NPV for the alternative options would be about 2.6–2.8 times the NPV for the CRDRP. The NPV for the CRDRP is about $239 million compared to an NPV ranging from $631 million to $670 million for Options 1-4. Detailed spreadsheets available at the MPWMD office provide supporting documentation for these results. Increase in Water Rates. The expected water bill increases associated with these projects would differ substantially. The typical residential bill is presently about $27 per month. Over the first 30 years of project operation, the average increase in the typical residential water bill expected with the CRDRP is $18.64 per month. The monthly average residential water bill increases associated with Options 1-4 would range from $41.04 to $43.50 per month, or more than double that with the CRDRP. For years 31–90 of project operation, the surcharge to fund any of the project alternatives would increase. The rate of increase would be much greater under Options 1-4 than under the CRDRP because of the continued escalation throughout the 90-year period of the high O&M costs for those alternatives. For example, in the last year of the proposed financing period (2095), the cost to a residential customer for Options 1-4 would be approximately six times more expensive than would the CRDRP. The economic viability of Options 1-4 is questionable. Using $27 per month as a base amount for the average residential water bill, the CRDRP would result in a 69% increase to water bills in this simplified example. Options 1-4 would result in a minimum 152%–161% increase in residential water bills. It should be noted that the costs for Options 1-4 are probably underestimated because they assume the less expensive desalination project location, do not include capital and O&M costs for environmental mitigation, and do not include O&M costs associated with Cal-Am system improvements required with these projects. Site Suitability. As described in Sections A.3.2 and A.3.4, previous studies have indicated that the feasibility of desalination projects larger than 6 MGD within MPWMD is questionable because of site constraints, impacts on existing ocean outfalls, and other concerns. For Seaside injection/recovery, an estimated six new well sites are needed that meet the desired hydrogeologic characteristics; the number of suitable sites may be limited, however, because of the urban setting and land ownership concerns. For dredging, a major concern is location of adequately sized disposal areas for spoils. Thus, Options 1-4 all involve concerns about site suitability that may be difficult or costly to surmount. Infrastructure Availability. Large desalination projects and injection/recovery require significant new Cal-Am water treatment and distribution facilities. As described in Section A.3.2 and elsewhere in this SEIR, the Cal-Am system is presently not built to receive significant quantities of water from outside the Carmel River Basin. Thus, significant investment in capital improvements would be needed with Options 1-4. These costs are included in the project costs discussed above. In addition, desalination projects in Marina or Moss Landing would require lengthy water pipelines to delivery water to the Cal-Am system because no water connection currently exists between those areas and the Monterey Peninsula. For large desalination projects, new power substations and transmission lines could be needed. Thus, major infrastructure improvements would be needed for Options 1-4. These are viewed as substantial disadvantages when considering project feasibility. Consistency with Regional Plans. Previous environmental documents for MPWMD’s 3-MGD desalination project proposed in 1993 noted that such a project would not comply with the regional air quality management plan promulgated by the Monterey Bay Unified Air Pollution Control District. Air quality impacts stemming from the extensive energy use required for desalination are the primary concern. It is assumed that the large desalination projects (7.5–10.5 MGD) included in Options 1-4 would be similarly noncompliant. Reducing these adverse impacts on air quality may not be possible without a major, costly mitigation program. Location within Jurisdiction Boundary. Options 1-4 involve large desalination projects in Marina or Moss Landing that are outside the MPWMD boundary and Cal-Am service area. This limits MPWMD’s powers of eminent domain, if needed, and conflicts with the policy direction of state legislation that created MPWMD—to develop feasible water augmentation resources within the MPWMD boundary before searching outside of the boundary. However, Cal-Am as a private company may be able to obtain such sites. Property Ownership. Desalination projects in Marina or Moss Landing are outside the MPWMD and Cal-Am boundaries, and neither entity owns desalination facilities, new injection well sites, or dredging spoils disposal areas. Other agencies, such as FORA and the Cities of Marina and Sand City, currently employ or anticipate a greater need for desalination to meet local community water needs. Thus, there may be competition for coastal sites, and MPWMD and Cal-Am may be at a disadvantage compared to local agency property owners. This would affect the feasibility of Options 1-4. Cal-Am owns the CRDRP dam site and inundation area, several major mitigation areas, and nearly all lands needed for the project. Environmental and Water Supply Concerns. Table A-17 and Section A.4.3.1 review the environmental effects of Options 1-4 with respect to various issues relating to the Carmel River, Cachagua, and Carmel Valley. More detailed evaluations and data from CVSIM model runs in support of these conclusions are available for review at the MPWMD office. Options 1-4 rely on desalination, which may involve impacts on energy use, air quality, coastal dune habitats and dependent special-status species, coastal wetlands and sloughs, sewage dispersal, and ocean species near brine discharge outlets. A major concern associated with Options 3 and 4 is the substantial, long-term (more than 5 years’ duration) truck traffic impacts associated with dredging. As noted in Section A.3.3, non-vehicle, pipe-based means to transport dredged spoils would use more water per year than would be produced by the dredging effort. Options 1-4 all rely on a large desalination project or a combination of desalination and injection/recovery as the primary sources of water. Because water delivery from desalination and injection/recovery is electrical power based, as opposed to a dam, which is gravity based, reliability becomes a concern in the event of an extended loss of power, such as following a major earthquake. The Loma Prieta event in 1989 resulted in a 3-day loss of power on the Monterey Peninsula but no loss of water because of gravity flow from Los Padres and San Clemente Reservoirs. Taking into consideration the need for adequate water pressure to fight fires and provide minimal supply to the community in an earthquake event, redundant backup systems would be needed for Options 1-4 for the desalination and injection components, which would increase costs above those presented here. Assuming that a reliable power source is available, Options 1-4 would provide better drought protection than would the CRDRP. No rationing of any kind would occur under Options 1-4 in the 39 simulated years (1958-1996) evaluated. In contrast, the CRDRP would involve 32 months of voluntary 10% reductions in the 39-year simulated period, but no mandatory rationing (20% reduction). A.4.4 SUMMARY AND RECOMMENDATIONS Thirteen unmitigated adverse effects specific to the CRDRP can be avoided or reduced (in some cases, fully mitigated) by water supply alternatives, particularly Options 1 and 2. Conversely, these options involve adverse impacts on the environment, some of which may not be mitigable. The identified hydrologic, fishery, and vegetation impacts of the CRDRP cannot be fully mitigated by any of the alternative options, but certain construction effects and cultural resources effects of CRDRP could be fully mitigated. The dredging component of Options 3 and 4 could result in construction impacts similar to or more severe than those of the CRDRP, particularly those impacts related to truck traffic. Growth-inducing effects would be similar under Options 1-4 and the CRDRP. Options 1-4 would involve potential impacts on ocean biota, coastal dune habitats and dependent species, wetland and slough environments, and energy use and related air quality impacts because of the large desalination project that forms the cornerstone of each option. The water supply reliability of Options 1-4 is of concern in an extended power outage because these options depend on electricity. Assuming power can be produced reliably, Options 1-4 provide superior levels of drought protection to the CRDRP, but at much higher cost. In conclusion, the alternative options (particularly Options 1 and 2) would provide a lawful water supply in compliance with SWRCB Order WR 95-10, provide superior drought protection (assuming the availability of reliable power), and avoid or reduce nearly all adverse impacts of the CRDRP. However, the feasibility of Options 1-4 is questionable to such a degree that these options may not be reasonably considered as viable. This recommendation is based on extremely high costs (more than double the NPV of the CRDRP) and the resulting hardship to ratepayers; questionable site suitability for large desalination projects; lack of supporting infrastructure; noncompliance with regional air quality plans; location outside MPWMD or Cal-Am boundaries; lack of property ownership with potential competition for desalination sites (and possibly well sites) from other agencies; and environmental concerns related primarily to brine discharge, energy consumption, and habitat impacts.
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