Monterey Peninsula Water Supply Project: EIR Scoping Report

MONTEREY PENINSULA WATER SUPPLY PROJECT
EIR Scoping Report
Prepared for California Public Utilities Commission
November 2012
MONTEREY PENINSULA WATER SUPPLY PROJECT

EIR Scoping Report
Prepared for California Public Utilities Commission
November 2012
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205335.01
TABLE OF CONTENTS
Monterey Peninsula Water Supply Project EIR Scoping Report

Page 1. Introduction ......................................................................Error! Bookmark not defined.1 2. Purpose of Scoping Process ........................................................................................2 3. Overview of Scoping Process for MPWSP EIR ...........................................................1 4. Summary of Scoping Comments..................................................................................6 5. Consideration of Issues Raised in Scoping Process ...............................................28 6. Scope of Alternatives Analysis...................................................................................29
Appendices A. B. C. D. E. F G. H. Notice of Preparation ..................................................................................................A Notice of Preparation Postcard ...................................................................................B Newspaper Notices.................................................................................................... C Project Website.......................................................................................................... D Scoping Meeting Attendance Sheets .........................................................................E Scoping Meeting Presentation ....................................................................................F Scoping Meeting Flipcharts........................................................................................ G Scoping Period Written Comments ............................................................................ H
List of Tables Table 1 Summary of Mailing List Contacts .......................................................................... 3 Table 2 Parties Submitting Comments during the Monterey Peninsula Water Supply Project EIR Scoping Process ................................................................................. 6
CalAm Monterey Peninsula Water Supply Project Scoping Report
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EIR SCOPING REPORT
Monterey Peninsula Water Supply Project

1. Introduction
The California Public Utilities Commission (CPUC) is preparing a Draft Environmental Impact Report (EIR) for the California American Water Company (CalAm) Monterey Peninsula Water Supply Project (MPWSP or proposed project) in accordance with California Environmental Quality Act (CEQA) requirements. The Draft EIR will assess the potential impacts of the proposed project on the physical environment. The CPUC formally began the process of determining the scope of issues and alternatives to be evaluated in the Draft EIR (a process called scoping) when it issued a Notice of Preparation (NOP) of an EIR for the proposed project on October 10, 2012. This report provides an overview of the scoping process for the MPWSP and summarizes the comments received during the scoping period. The project proponent, CalAm, is an investor-owned utility under the CPUCs jurisdiction. CalAm submitted an application to the CPUC for a Certificate of Public Convenience and Necessity (CPCN) under Public Utilities Code Section 1001 to build, own, and operate all elements of the MPWSP, and also for permission to recover present and future costs for the project through short-term rate increases. 1 The CPUC administrative law judge will review the reports prepared as part of the CEQA process (including this scoping report, which will inform preparation of the EIR) and will ultimately prepare a proposed decision for consideration by the full Commission regarding certification of the MPWSP EIR and approval of the MPWSP. This report is intended to summarize and document the comments received during the scoping period. It includes verbal and written comments received during the scoping period (October 10, 2012 to November 9, 2012). Pursuant to CEQA Guidelines Section 15082, the CPUC will use this report as a tool to ensure that scoping comments are considered during preparation of the Draft EIR. In addition, this report may be used by parties to the proceeding in their preparation of testimony.
California American Water (CalAm), Application of California American Water Company (U210W) for Approval of the Monterey Peninsula Water Supply Project and Authorization to Recover All Present and Future Costs, Application A.12-04-019, filed April 23, 2012.
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2. Purpose of Scoping Process

CEQA Guidelines Section 15083 provides that a Lead Agency mayconsult directly with any person or organization it believes will be concerned with the environmental effects of the Project. Scoping is the process of early consultation with the affected agencies and public prior to completion of a Draft EIR. Scoping can be helpful to agencies in identifying the range of actions, alternatives, mitigation measures, and significant effects to be analyzed in depth in an EIR and in eliminating from detailed study issues found not to be important (CEQA Guidelines Section 15083(a)). Scoping is an effective way to bring together and consider the concerns of affected federal, state, regional, and local agencies, the project proponent, and other interested persons, including those who may not be in accord with the action on environmental grounds (CEQA Guidelines Section 15083(b)). The comments provided by the public and agencies during the scoping process will help the CPUC identify pertinent issues, methods of analyses, and level of detail that should be addressed in the EIR. The scoping comments will also assist the CPUC in developing a reasonable range of feasible alternatives that will be evaluated in the EIR. The scoping comments will augment the information developed by the project proponent, the CPUC, and the EIR preparers, which includes specialists in each of the environmental subject areas covered in the EIR. This combined input will result in an EIR that is both comprehensive and responsive to issues raised by the public and regulatory agencies, and that satisfies all CEQA requirements. Scoping is not conducted to resolve differences concerning the merits of a project or to anticipate the ultimate decision on a proposal. Rather, the purpose of scoping is to help ensure that a comprehensive EIR will be prepared that provides an informative basis for the decision-making process.
3. Overview of Scoping Process for MPWSP EIR

3.1 Mailing List
Prior to the scoping period, the CPUC developed a mailing list of potentially affected persons and agencies that would have an interest in or jurisdiction over actions taken within the project area. The mailing list included all federal, state, responsible, and trustee agencies involved in approving or funding the project, as well as relevant local agencies and special districts with jurisdiction in the project area. The mailing list also included organizations, members of the public, and local, regional, and state agencies who commented on, or were involved in, the CalAm Coastal Water Project Draft EIR (State Clearinghouse No. 2006101004, concerning the predecessor proposed project to the MPWSP), or who have expressed interest in participating in the CEQA process for the MPWSP. In addition, although not required by CEQA, Property owners and occupants of parcels located within 300 feet of proposed project components were identified and included in the mailing list.
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3.2 Notice of Preparation

On October 10, 2012, the CPUC published and distributed two forms of notification for the proposed project: the NOP and the NOP postcard. The NOP included a description of the proposed project, the project location, a summary of the probable environmental effects of the project, and a preliminary list of project alternatives (see Appendix A). A hardcopy of the NOP was sent to federal and state permitting agencies; regional and local agencies/jurisdictions; organizations and individuals who commented on the Coastal Water Project Draft EIR or who expressed interest in the CEQA process for the MPWSP; and local libraries. A postcard notification providing an abbreviated description of the project and identifying where interested parties could view or obtain a copy of the NOP (see Appendix B) was sent to the property owners and occupants of parcels within 300 feet of proposed project components. Both the NOP and the NOP postcard solicited comments on the scope of the EIR during the 30-day public scoping period and provided information regarding the dates, times, and locations of public scoping meetings. Table 1, below, summaries the categories of recipients who were mailed the NOP and NOP postcard. 2
TABLE 1 SUMMARY OF NOP MAILING LIST
Number on Mailing List 70 135 3,003 352 13 3,575
Recipient Type Federal and State Permitting Agencies Regional and Local Agencies/Jurisdictions Property Owners and Occupants of Adjacent Parcels Other Interested Parties Libraries
Notification Type NOP NOP NOP Postcard NOP NOP Total Number of Mail Notifications
The NOP was also posted and made available for public review at the following local libraries: Monterey County Free Library, Pajaro Branch, 29 Bishop Street, Pajaro, CA, 95076 Monterey County Free Library, Prunedale Branch, 17822 Moro Road, Salinas, CA, 93907 Monterey County Free Library, Castroville Branch, 11160 Speegle Street, Castroville, CA, 95012 Monterey County Free Library, Marina Branch, 188 Seaside Circle, Marin, CA, 93908 Monterey County Free Library, Buena Vista Branch, 18250 Tara Drive, Salinas, CA, 93908 Monterey County Free Library, Carmel Valley Branch, 65 W. Carmel Valley Road, Carmel Valley, CA, 93924
Approximately 37 NOPs and 420 NOP postcards were returned by the U.S. Postal Service as being undeliverable.
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Monterey County Free Library, Seaside Branch, 550 Harcourt Avenue, Seaside, CA 93955 Monterey City Library, 625 Pacific Street, Monterey, CA 93940 Pacific Grove City Library, 550 Central Avenue, Pacific Grove, CA 93950 John Steinbeck Library/Salinas Public Library, 350 Lincoln Avenue, Salinas, CA 93901 Cesar Chavez Library, 615 Williams Road, Salinas, CA 93905 El Gabilan Library, 1400 North Main Street, Salinas, CA 93906 CSU Monterey Bay, 100 Campus Center Bldg. 508, Seaside, CA 93955
3.3 Other Notifications

In addition to mailing the NOP and the NOP postcard, the CPUC also published newspaper display and legal advertisements (see Appendix C) and developed a project-specific website (see Appendix D). The CPUC published display and legal advertisements in the following local newspapers: Monterey Herald on October 10, October 21, and October 24, 2012. The legal publication on October 24, 2012 was published in English and Spanish to reach additional members of the community. Salinas Californian on October 10 and October 25, 2012. Carmel Pine Cone on October 12, 2012. El Sol on October 12, 2012. This display publication was published in Spanish.
3.4 Public Scoping Meetings

The CPUC held a total of three scoping meetings, each of which was open to the general public: Wednesday, October 24, 2012 6:30 p.m. 8:30 p.m. Rancho Canada Golf Club, 860 Carmel Valley Road, Carmel, CA 93923 Thursday, October 25, 2012 1:30 p.m. 3:30 p.m. Oldemeyer Center, Blackhorse Room, 986 Hilby Avenue, Seaside, CA 93955 Thursday, October 25, 2012 6:30 p.m. 8:30 p.m. Oldemeyer Center, Laguna Grande Hall, 986 Hilby Avenue, Seaside, CA 93955
The three scoping meetings had approximately 50 attendees. Andrew Barnsdale (CPUC Energy Division), two representatives of the CPUCs Public Advisors Office, and members of Environmental Science Associates (ESA) CEQA team were also in attendance to facilitate the meetings. Sign-in sheets from the scoping meeting are provided in Appendix E. Meeting
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attendees were asked to (but were not required to) sign in and were provided with materials including the NOP, project location map, and comment cards. The scoping meetings were conducted using an open house format. Project poster boards were set up around the room, accompanied by CPUC staff and members of the EIR team, to encourage and engage in discussion with the public about the proposed project. The poster boards included: an overview of the CEQA process, an overview of the proposed project, preliminary project alternatives, schematics of various seawater intake technologies, and proposed MPWSP facilities located north and south of Reservation Road. CPUC staff and the EIR team gave a presentation (Appendix F) that provided an overview of the environmental review process, the regional context, project background, project objectives, project description, project alternatives, and purpose of the scoping process. The presentation was followed by breakout sessions, where the meeting attendees could discuss their concerns about the project with CPUC staff and EIR team members. The EIR team recorded the publics concerns as scoping comments on flip charts. All attendees were informed they could also submit written comments electronically or by mail up until the close of the scoping period at 5:00 p.m. on November 9, 2012. Comments that were recorded on the flip charts during the scoping meetings are provided in Appendix G. This report provides an overview of the comments received during the scoping period (October 10, 2012 to November 9, 2012). This scoping report will assist the EIR team in addressing the scoping comments during preparation of the EIR. Pursuant to CEQA Guidelines Section 15084(c).
4. Summary of Scoping Comments

During the scoping meetings held on October 24 and 25, 2012, participants commented on the proposed project. Written comments were also collected throughout the public comment period (Appendix H). Forty-one written letters were received during the scoping period. Commenting parties and summaries of the comments received are provided below. Comment letters received during the scoping period were reviewed, bracketed, and coded. Each comment letter was given a unique letter code that corresponds to the type of commenter (i.e., Federal Agency [F], State Agency [S], Local Agency [L], Group [G], Individual [I], or Scoping Meeting [ScopingMTG]); an acronym for the agency or organization (or, in the case of individuals, their last name); and the sequentially numbered, bracketed comment from that commenter. These comment identifiers are used as a cross-reference to the topical codes. The individual comments were then summarized by topical areas.
4.1 Commenting Parties

The following individuals and parties submitted comments on the scope of the EIR. These comments are organized affiliation type.
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TABLE 2 PARTIES SUBMITTING COMMENTS DURING THE MONTEREY PENINSULA WATER SUPPLY PROJECT EIR SCOPING PROCESS
Comment Letter Code
Affiliation
Name
Date/Received Date
Federal Agencies
NOAA Monterey Bay National Marine Sanctuary U.S. Fish and Wildlife Service Paul Michel Diane K. Noda November 9, 2012 November 9, 2012 F_MBNMS F_USFWS
State Agencies
Division of Ratepayer Advocates California Public Utilities Commission California State Lands Commission Diana S. Brooks Cy R. Oggins November 9, 2012 November 13, 2012 S_CPUC_DRA S_CSLC
Local and Regional Agencies

County of Monterey Department of Public Works Monterey Bay Unified Air Pollution Control District Monterey County Resource Management Agency Monterey County Water Resources Agency City of Monterey Monterey Peninsula Water Management District City of Pacific Grove Raul Martinez Amy Clymo Jacqueline R. Onciano Robert Johnson Fred Meurer David Stoldt Thomas Frutchey Molly Erickson Tim Miller Bob Mckenzie and John Narigi George Riley and Ed Mitchell John H. Farrow Tom Rowlet Jonas Minton Karin Locke Gabriel Ross and Edward Schexnayder Nancy Isakson Nancy Isakson Ron Weitzman Dick Rotter Ron Weitzman Ron Weitzman Dick Rotter John and Marion Bottomley George Brehmer Bill Carrothers Roger J. Dolan November 14, 2012 November 6, 2012 November 9, 2012 November 9, 2012 October 25, 2012 November 8, 2012 November 8, 2012 November 9, 2012 November 9, 2012 November 9, 2012 November 8, 2012 October 1, 2012 October 25, 2012 October 24, 2012 October 24, 2012 November 9, 2012 October 2, 2012 November 11, 2012 October 4, 2012 October 25, 2012 October 31, 2012 November 9, 2012 November 6, 2012 November 2, 2012 November 9, 2012 October 29, 2012 November 6, 2012 L_CoMontereyPW L_MBUPCD L_MCRMA L_MCWRA L_Monterey L_MPWMD L_PacGrove G_AgLandTrust G_CalAm G_CPB G_CPW G_LandWatch G_MPTA G_PCL G_SPG G_Surfrider G_SVWC1 G_SVWC2 G_WaterPlus1 G_WaterPlus2 G_WaterPlus3 G_WaterPlus4 G_WaterPlus5 I_Bottomley I_Brehmer I_Carrothers I_Dolan
Group
Ag Land Trust California American Water Company Coalition of Peninsula Businesses Citizens for Public Water LandWatch Monterey County Monterey Peninsula Taxpayer Association Planning and Conservation League Sustainable Pacific Grove Surfrider Foundation Salinas Valley Water Coalition Salinas Valley Water Coalition WaterPlus and LandWatch Monterey County WaterPlus WaterPlus WaterPlus WaterPlus
Individuals
Individual Individual Individual Individual
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TABLE 2 (Continued) PARTIES SUBMITTING COMMENTS DURING THE MONTEREY PENINSULA WATER SUPPLY PROJECT EIR SCOPING PROCESS
Comment Letter Code
Affiliation
Name
Date/Received Date
Individuals (cont.)
Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Individual Ken Ekelund Manuel and Janine Fierro Mike Fillmon Ray M. Harrod Jr. Chris Herron Christina W. Holston Hebard and Peggy Olsen Robert Siegfried Robert Siegfried Robert Siegfried Roy L. Thomas Unknown verbal commenter Unknown verbal commenter Unknown verbal commenter November 2, 2012 November 8, 2012 October 24, 2012 November 8, 2012 October 24, 2012 October 24, 2012 October 19, 2012 October 24, 2012 October 27, 2012 October 27, 2012 November 15, 2012 October 24, 2012 October 25, 2012 October 25, 2012 I_Ekelund I_Fierro I_Fillmon I_Harrod I_Herron I_Holston I_Olsen I_Siegfried1 I_Siegfried2 I_Siegfried3 I_Thomas ScopingMTG1 ScopingMTG2 ScopingMTG3
Scoping Meeting Comments

Not Given Not Given Not Given
4.2 Summary of Scoping Comments

The following bullet points summarize both the oral and written comments received during the scoping period. For more detailed information, please see Appendix G, which contains all comments received during the scoping meetings, and Appendix H, which contains all written comments submitted during the scoping period. EIR staff reviewed all of the scoping comments, bracketed and categorized the individual comments under various topical areas, and prepared a one to two-sentence summary of each comment. The purpose of the comment summaries is to provide an overview of the range of comments provided, and to facilitate consideration of the comments by EIR analysts during preparation of the EIR. The comment summaries seek to capture the essence of every comment in a way that is meaningful for EIR preparers such that the comment can be addressed in the EIR. The full comment letters are provided Appendix H; readers of this scoping report are encouraged to refer to Appendix H for the full text of the comment letters. Specific comments are categorized by topical area to facilitate review of the comments. Naturally, some comments apply to multiple topical areas, and they will be considered by the EIR analysts in all pertinent topical areas.
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Issues to Be Considered under CEQA

Water Demand
Water demand estimates for the Monterey District should consider non-residential water use (associated with hospitality and tourism) following economic recovery. [L_MPWMD08] Future demand estimates should consider proposed development projects in the City of Seaside. [G_SPG-02] The demand estimates should consider conservation and demand offset. [G_SPG-09] The EIR should consider rainwater harvesting and greywater systems for demand management and supplemental sources of supply. [I_Brehmer-01] The EIR should address whether the proposed project would supply Clark Colony or whether Clark Colony would need to purchase other supplies. [ScopingMTG1-06] Further consideration should be given to the size of conveyance facilities given the potential reduction in CalAm Carmel River diversions below their existing entitlements (i.e., if Los Padres Dam were removed). The EIR should evaluate whether the conveyance pipelines would need to be increased in capacity. [ScopingMTG1-08] The EIR should evaluate whether there is enough capacity to pump from Carmel River to aquifer storage and recovery. Additionally, the EIR should evaluate the capacity of the pipeline system. [ScopingMTG1-10] The EIR should properly identify the demand the project is intended to serve. The EIR should evaluate the impacts of downsizing and upsizing the capacity. [ScopingMTG2-19] The EIR should consider that the per capita demand is declining and that tiered rates have had a significant effect on the elasticity of water. If the proposed project assumes todays demand, it will be off. [ScopingMTG2-21] The EIR should evaluate the implementation of larger pipelines and additional water treatment capacity for the growing needs on the Peninsula. [ScopingMTG2-42] The EIR should address the maintenance of the facilities and the examination of water leaks in the system. [ScopingMTG2-45]
Project Description
The MPWSP will need to receive approvals from CSLC for all project components within CSLC jurisdiction. [S_CSLC-01] The Project Description in the EIR should be as precise, thorough, and complete as possible to facilitate meaningful environmental review. [S_CSLC-02] The EIR should clearly explain the relationship between the Coastal Water Project and the MPWSP, and the relationship between the MPWSP and the Deepwater Desal Alternative and the People's Moss Landing Desal Alternative. [S_CSLC-03]
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The EIR should provide a detailed evaluation of the pre-treatment and post-treatment systems of desalination so that the impact analyses can evaluate any associated environmental effects. [S_CSLC-07] Production capacity should be based on the replacement water supplies associated with the legal restrictions on CalAms Carmel River and Seaside Groundwater Basin supplies, while providing sufficient capacity and flexibility for replenishment of the Seaside Groundwater Basin, economic recovery, and water system reliability. [L_MPWMD-06] The proposed desalination plant should be designed with sufficient redundancy to meet outages and required maintenance activities, and to satisfy peak day and peak month demand. [L_MPWMD-09] Although the production capacity for the MPWSP should be based on replacement supply needs, conveyance facilities should be sized to accommodate future growth, general plan build out, and unforeseen changes in the availability of CalAms existing water supplies. [L_MPWMD-10] The EIR should clearly describe the location and composition of the proposed project facilities. [L_PacGrove-02] The MPWSP should provide CalAm with the flexibility to deliver MPWSP water supplies to the Ryan Ranch, Bishop, and Hidden Hills distribution systems (located outside of the Monterey District service area). [G_CalAm-05] It is likely that CalAm will be required to cease pumping in the Laguna Seca subarea under the Courts adjudication of the Seaside Groundwater Basin. As a result, the MPWSP should include the provision of water supplies to these areas. [G_CalAm-06] The EIR should evaluate pipeline alignments that would facilitate the delivery of water to the Ryan Ranch, Bishop, and Hidden Hills distribution systems. [G_CalAm-07] The availability of Carmel River supplies for injection into the ASR system is unreliable given that these supplies rely exclusively on excess winter flows in the Carmel River. Therefore, the CPUC should not depend on ASR product water for meeting customer demand. [G_CPB-02] The proposed desalination plant should be sized such that it can meet customer water needs when operated at 80 percent of capacity. [G_CPB-04] The EIR should describe how brine from the desalination plant would be discharged. The EIR should also evaluate available capacity in the MRWPCA ocean outfall for brine discharges. [G_CPW-09] The EIR should describe the project purpose and need as it relates to the region. [G_CPW-11] The EIR should state the maximum volume of water that would be drawn via the proposed slant wells, and evaluate the environmental impacts of these withdrawals on marine resources. [G_CPW-23] The MOU between MRWPCA and the MCWD states that MCWD has the right to use a portion of the MRWPCA outfall capacity. [G_CPW-39]
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The EIR should describe the sustainability and annual reliability of the proposed improvements to the ASR system. [G_MPTA-01] The EIR should clarify the advantages of slant wells over other intake technologies. [G_SPG-03] The project objectives should be tailored to facilitate the evaluation of a broad range of alternatives capable of meeting the Peninsulas water supply needs. [G_Surfrider-07] The EIR should be clear about the project purpose and need, and specify whether the project would be limited to replacement supplies or if the project would also provide additional water supplies. In addition, the EIR should include a map of the Monterey District service area. [G_SVWC2-01] The EIR should specify the nature and frequency of maintenance activities associated with the proposed facilities, and as a condition of project approval, require that CalAm conduct these maintenance activities to avoid excessive costs to ratepayers associated with failing infrastructure. [G_WaterPlus5-02] The EIR should consider a variety of energy sources and configurations to reduce the cost of operating the proposed desalination plant. [I_Dolan-04] The MPWSP should include additional water supplies to serve lots of record. [I_Harrod-01] The desalination plant should be designed to facilitate future increases in production capacity. [I_Siegfried3-04] The MPWSP project area should be expanded to encompass the entire CalAm service area. [I_Siegfried3-05] Further consideration should be given to the size of conveyance facilities given the potential reduction in CalAm Carmel River diversions below their existing entitlements (i.e., if Los Padres Dam were removed). The EIR should evaluate whether the conveyance pipelines would need to be increased in capacity. [ScopingMTG1-08] The EIR should evaluate whether there is enough capacity to pump from Carmel River to aquifer storage and recovery. Additionally, the EIR should evaluate the capacity of the pipeline system. [ScopingMTG1-10] The project area should include the entire existing CalAm service area as it relates to the degradation of soils, water quality, and salt balance/salinity. [ScopingMTG1-11] The EIR should included discussion of the electric power (PG&E) transmission lines and associated construction impacts. [ScopingMTG2-01] The EIR should address all of the required federal permitting.[ScopingMTG2-04] In terms of project, governance; keep the County in control. [ScopingMTG2-08] The slant wells would require coordination with the City of Marina as to its Local Coastal Program. [ScopingMTG2-15] Would the test wells be transitioned into production? [ScopingMTG2-17]
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The footprint of the slant wells on the beach should be included in the EIR. The EIR should address open space, beach access, and a reduced footprint to minimize intrusion in beach areas. The EIR should examine future zoning conflicts. [ScopingMTG2-22] The EIR should evaluate discharge in anticipation of future/expected regulations. [ScopingMTG2-27] The EIR should examine the potential to expand facilities and increase water availability without increasing the project footprint. [ScopingMTG2-29] The appearance of injection wells and buildings need City Planning approval. [ScopingMTG2-40] The EIR and proposed project should include the use of sustainable design elements. [ScopingMTG2-47]
Surface Water Hydrology and Water Quality

The EIR should evaluate the effects of mixing brine with wastewater effluent and ensure that effluent concentrations are consistent with the SWRCB Ocean Plan requirements. [F_MBNMS-04] The EIR should address the potential for the MPWSP to change the interfaces and mixing zones for saltwater, brackish water, and freshwater. [S_CPUC_DRA-03] The EIR should address impacts to water quality. [G_AgLandTrust-06] The EIR should evaluate project consistency with water quality regulations. [G_AgLandTrust-12] The alternatives analysis should consider direct and cumulative impacts to marine resources associated with brine discharge from alternative desalination projects. [G_CPW-26] The EIR should identify the waste discharge requirements for brine disposal. [G_SPG-07] The EIR should evaluate impacts associated with brine discharge, including impacts within the zone of initial dilution as well as long-term impacts from brine accumulation in the farfield benthic environment. [G_Surfrider-03] The EIR should evaluate the effects of irrigating with desalinated product water on soil infiltration rates in the CalAm service area. [I_Siegfried1-01] The project area should include the entire existing CalAm service area as it relates to the degradation of soils, water quality, and salt balance/salinity. [ScopingMTG1-11] The EIR should evaluate the effects of irrigating with desalinated product water on terrestrial biological resources and soil infiltration rates in the CalAm service area. [I_Siegfried3-06]
Groundwater Resources
The EIR should evaluate the potential for the proposed slant wells to exacerbate seawater intrusion. [S_CPUC_DRA-01]
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The EIR should specify the methodology used to evaluate seawater intrusion impacts. [S_CPUC_DRA-02] The EIR should address the potential for the proposed slant well configuration to affect freshwater and seawater gradients in the aquifer. [S_CPUC_DRA-04] The EIR should evaluate how the injection of desalination product supplies into the Seaside Groundwater Basin would affect groundwater quality. [S_CSLC-08] The EIR should require the development and implementation of a monitoring well network to evaluate project effects on seawater intrusion and the Salinas Valley Groundwater Basin. [L_MCWRA-01] The EIR should address Salinas Valley Groundwater Basin groundwater rights as they relate to operation of the proposed MPWSP slant wells. [L_MCWRA-02; G_CPW-06; G_CPW-16; G_CPW-18; G_CPW-19; G_CPW-21; G_MPTA-03] The MCWRA requests that any modeling data and supporting information that is developed for the groundwater analysis be provided to MCWRA. [L_MCWRA-05] The EIR should evaluate how the injection of desalination product supplies into the Seaside Groundwater Basin would affect groundwater quality. [L_MPWMD-12] The EIR should evaluate the seawater intrusion and groundwater quality effects associated with extracting banked ASR water supplies via the ASR injection/extraction wells versus from CalAm production wells at different locations. [L_MPWMD-13] The EIR should address Salinas Valley Groundwater rights as they relate to the West Armstrong Ranch (owned by Ag Land Trust). [G_AgLandTrust-01] The EIR should acknowledge that groundwater cannot be pumped from the Salinas Valley Groundwater Basin without prescription. [G_AgLandTrust-02] The EIR should provide a detailed analysis of Salinas Valley Groundwater Basin water rights issues, including an analysis of existing water rights and impacts to agricultural land associated with the transfer of water rights to CalAm. [G_AgLandTrust-03] The EIR should evaluate potential impacts related to seawater intrusion. [G_AgLandTrust09] The EIR should evaluate impacts associated with screening the proposed slant wells in the Sand Dunes aquifer, as proposed in CalAms contingency plan. [G_AgLandTrust-10] The EIR should clearly state the volume of water that would be drawn from the slant wells under various scenarios, and the anticipated percentage of freshwater versus saltwater under each scenario. [G_AgLandTrust-19] It is likely that CalAm will be required to cease pumping in the Laguna Seca subarea under the Courts adjudication of the Seaside Groundwater Basin. As a result, the MPWSP should include the provision of water supplies to these areas. [G_CalAm-06]
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The MPWSP EIR should consider the Monterey County Superior Courts ruling on the CWP EIR, which determined that water rights were not adequately addressed in the CWP EIR. [G_CPW-01] The EIR should specify the volume of water that would need to be returned to the Salinas Valley Groundwater Basin. [G_CPW-07] The EIR should evaluate the potential for operation of the proposed slant wells to exacerbate seawater intrusion in the Seaside Groundwater Basin and adversely affect upgradient wells. [G_CPW-20] The EIR should quantify the amount of groundwater that must be returned to the Salinas Valley Groundwater Basin and evaluate the potential adverse effects of borrowing/returning such water. [G_CPW-22] The EIR should evaluate the potential for operation of the proposed slant wells to exacerbate seawater intrusion in the Seaside Groundwater Basin. [G_CPW-24] The EIR should evaluate the potential for operation of the proposed slant wells to adversely affect up-gradient wells. [G_CPW-25] The EIR should provide a clear explanation of the updated groundwater modeling efforts used to evaluate project impacts. [G_SPG-06] As part of EIR preparation, the CPUC should develop an updated groundwater model that accurately represents the hydrogeologic setting and baseline conditions, and simulates future conditions with project implementation. [G_SVWC2-02] The EIR should address the direct impacts to Salinas Valley Groundwater Basin associated with operation of the proposed slant wells, and the utilization of desalinated product water that is returned to the CSIP storage pond. [G_SVWC2-03] The EIR should evaluate impacts to agricultural lands associated with any adverse effects on water rights held by agricultural water users. [G_SVWC2-04] The EIR should consider potential reliability and sustainability issues associated with groundwater replenishment and aquifer storage and recovery. Such issues include the potential to exacerbate seawater intrusion, the reliability of Carmel River diversions for injection into ASR, and the availability of reclaimed wastewater for groundwater replenishment. [G_WaterPlus3-01] The EIR should evaluate project consistency with the Agency Act, which prohibits the exportation of groundwater from the Salinas Valley Groundwater Basin, as well as the potential for the project to exacerbate seawater intrusion. [G_WaterPlus4-01] The EIR should include an assessment of the percent saltwater versus freshwater that would be drawn from slant wells at the CEMEX property. [I_Dolan-01] The EIR should evaluate project impacts related to seawater intrusion, groundwater levels, and effects on non-CalAm groundwater production wells. [I_Herron-01] The EIR should evaluate the potential for the injection of desalinated product water into the Seaside Groundwater Basin to degrade water quality in the aquifer. [I_Siegfried3-01]
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The EIR should evaluate the effects of injecting desalinated product water into the ASR system on boron concentrations in the CalAm water supply. [I_Siegfried3-03] The EIR should consider Salinas Valley groundwater issues. [ScopingMTG1-01] The EIR should clearly identify the difference between fresh versus brackish groundwater. [ScopingMTG2-12] The EIR should consider the amount of water that will be taken out of the Seaside aquifer, because the aquifer leaks. The EIR should evaluate the use of the aquifer by multiple projects. Examination of the rate at which water is being lost from the aquifer and how long water will be stored should be included in the EIR. [ScopingMTG2-31] The Ghyben-Herzbergt theory should be considered. [ScopingMTG3-01]
Marine Resources
The MBNMS has developed guidelines (Desalination Action Plan) for the siting, design, and operation of desalination plants along the sanctuary. In addition, the sanctuary has three regulations relevant to desalination projects: (1) it is prohibited to discharge or deposit any material within sanctuary boundaries, (2) it is prohibited to discharge material outside of sanctuary boundaries that will subsequently enter the sanctuary and negatively impact marine resources, and (3) it is prohibited to alter submerged lands of the sanctuary. [F_MBNMS-01] The EIR should evaluate the effects of mixing brine with wastewater effluent and ensure that effluent concentrations are consistent with the SWRCB Ocean Plan requirements. [F_MBNMS-04] The EIR should evaluate potential impacts to the sanctuary associated with installation of the proposed slant wells. [F_MBNMS-05] The EIR should address the potential for the MPWSP to change the interfaces and mixing zones for saltwater, brackish water, and freshwater. [S_CPUC_DRA-03] The EIR should evaluate the potential for project construction and operation to generate undewater noise or vibration that has the potential to impact marine biological resources. [S_CSLC-06] The EIR (and the NEPA document for the MPWSP) should evaluate impacts to the Monterey Bay National Marine Sanctuary. [G_AgLandTrust-18] The EIR should state the maximum volume of water that would be drawn via the proposed slant wells, and evaluate the environmental impacts of these withdrawals on marine resources. [G_CPW-23] The alternatives analysis should consider direct and cumulative impacts to marine resources associated with brine discharge from alternative desalination projects. [G_CPW26] The EIR should evaluate the long-term effects of brine discharge on marine resources and habitats. [G_SPG-01]
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The EIR should evaluate potential effects on marine resources and coastal ecosystems related to brine discharge, the proposed seawater intake system, and greenhouse gas emissions associated with powering the desalination plant. [G_Surfrider-01] The EIR should evaluate impacts associated with brine discharge, including impacts within the zone of initial dilution as well as long-term impacts from brine accumulation in the farfield benthic environment. [G_Surfrider-03] The EIR should include well-defined mitigation measures to prevent erosion and preserve sensitive coastal habitat. [G_Surfrider-05] The EIR should consider the effects of salt removal associated with desalination on marine organisms. [I_Olsen-05] The EIR should evaluate the cumulative impacts of brine from many desalination plants in the Monterey Bay region. [ScopingMTG1-17] The EIR should evaluate whether higher salinity would produce more red tide and algal blooms. [ScopingMTG1-18] The commenter states that the diffusion of brine would be complicated by addition of Marina Coast outflow. [ScopingMTG2-10] The EIR should address the impacts slant wells could have on marine biological species, including birds and seals and their migratory habitat and variable habitat by season and year. [ScopingMTG2-23] The EIR should examine the impacts of the concentration of brine discharge. Questioned if the EIR would have a comparative study of brine discharges at existing plants? [ScopingMTG2-24] Commenter questioned whether there are relevant studies to be able to evaluate the effects of discharge. [ScopingMTG2-30]
Terrestrial Biological Resources

The EIR should evaluate impacts to Smiths blue butterfly, Menzies wallflower, Monterey gilia, Western snowy plover, and Monterey spineflower associated with installation and maintenance of the proposed slant wells. [F_USFWS-01] The EIR should evaluate cumulative impacts to Western snowy plover associated with the proposed seawater intake system and CEMEX mining activities. [F_USFWS-02] The EIR should address impacts to California red-legged frog associated with construction, operation, and maintenance of the proposed desalination plant. [F_USFWS-03] The EIR should evaluate impacts to federally listed species resulting from construction of proposed conveyance pipelines. [F_USFWS-04] The EIR should present responses from CDFG, CNDDB, and USFWS that identify any special-status plant and wildlife species that may occur in the project area. [S_CSLC-05]
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The EIR should evaluate the effects of irrigating with desalinated product water on terrestrial biological resources and soil infiltration rates in the CalAm service area. [I_Siegfried3-06] The EIR should evaluate impacts on snowy plover. [ScopingMTG1-12; ScopingMTG2-13; ScopingMTG2-14]
Geology, Soils, Seismicity

The EIR should evaluate potential impacts related to sea level rise. [S_CSLC-13] The project area should include the entire existing CalAm service area as it relates to the degradation of soils, water quality, and salt balance/salinity. [ScopingMTG1-11] The EIR should address the longevity of wells relative to corrosion and whether the wells must be moved often. [ScopingMTG1-13] The EIR should evaluate whether well intake would erode or move soil. [ScopingMTG1-14]
Hazards and Public Health and Safety

The EIR should evaluate the public health and safety risk of private ownership of the MPWSP. [ScopingMTG2-25] The EIR should evaluate the safety of the Fort Ord area and its use for park and residential uses. Commenter recommends developing Terminal Reservoir area as park space. The EIR should coordinate with FORA on the status, schedule, and extent of cleanup efforts. [ScopingMTG2-39] The EIR should address the timeframe of cleanup of Fort Ord relative to construction of the Terminal Reservoir (area is currently not planned for cleanup for some time). [ScopingMTG2-41]
Land Use and Recreation

The EIR should discuss the potential for project implementation to affect land use and recreational resources. The EIR should also describe how the CPUC and CalAm will notify the public about activities happening in the project area that could affect land use and recreational resources. [S_CSLC-09] The EIR should evaluate the needs and benefits to pedestrian and bicycle facilities. [L_CoMontereyPW-08] The EIR should evaluate land use impacts associated with facility siting and the annexation of land. [G_AgLandTrust-08] The footprint of the slant wells on the beach should be included in the EIR. The EIR should address open space, beach access, and a reduced footprint to minimize intrusion in beach areas. The EIR should examination future zoning conflicts. [ScopingMTG2-22] The EIR should consider the road construction in Seaside (La Salle Avenue, Hilby Avenue). Including road repaving, not just patching. [ScopingMTG2-32]
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The EIR should address staging and parking areas for construction workers as parking is an issue for the neighborhoods south of La Salle Avenue. There is the potential to use local school parking lots during summer (first week in June to first week in August; no summer school sessions). [ScopingMTG2-33] The EIR should address access for residents during construction. [ScopingMTG2-35] The EIR should address the aesthetics impacts of the Terminal Reservoir. The Terminal Reservoir should be set back off of General Jim Moore Boulevard and be partially submerged underground. [ScopingMTG2-36] The EIR should incorporate a detention basin in the design for the overflow capacity for the Terminal Reservoir. The City of Seaside worked with CalAm on a park conceptual design for area around Terminal Reservoir to integrate park space and address aesthetic impacts. Bureau of Land Management owns land behind the Terminal Reservoir site. [ScopingMTG2-37] The EIR should evaluate the City of Seaside General Plan for conflicts with zoning and land use designation. [ScopingMTG2-38] CalAm would need a right of entry permit from Fort Ord Reuse Authority (FORA) for access. The EIR should evaluate the safety of the Fort Ord area and its use for park and residential uses. Commenter recommends developing Terminal Reservoir area as park space. The EIR should coordinate with FORA on the status, schedule, and extent of cleanup efforts. [ScopingMTG2-39] The EIR should address the timeframe of cleanup of Fort Ord relative to construction of the Terminal Reservoir (area is currently not planned for cleanup for some time). [ScopingMTG2-41]
Traffic
The EIRs mitigation measures should conform to regional planning documents. [L_CoMontereyPW-01] The EIR methods by which the Level of Service is calculated should be consistent with the methods in the latest editions of the Highway Capacity Manual. [L_CoMontereyPW-02] The EIRs Traffic Studies should identify mitigation measure for all traffic circulation impacts on County roads. [L_CoMontereyPW-03] The EIR should address all impacts on county, regional, and city roadways. [L_CoMontereyPW-04] The EIR cumulative scenarios should be consistent with regional traffic model projections. [L_CoMontereyPW-05] The EIR should evaluate existing conditions, background and cumulative project scenarios. [L_CoMontereyPW-06] The EIR should include a pavement condition analysis. The EIR should evaluate impacts from the amount of heavy truck traffic. [L_CoMontereyPW-07]
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The EIR should evaluate the needs and benefits to pedestrian and bicycle facilities. [L_CoMontereyPW-08] The traffic reports should include access points and analyze the impacts on county, cities, and regional roadways. [L_CoMontereyPW-09] The EIR should consider the road construction in Seaside (La Salle Avenue, Hilby Avenue). Including road repaving, not just patching. [ScopingMTG2-32] The EIR should address staging and parking areas for construction workers as parking is an issue for the neighborhoods south of La Salle Avenue. There is the potential to use local school parking lots during summer (first week in June to first week in August; no summer school sessions). [ScopingMTG2-33] The EIR should evaluate emergency response times for the Seaside Fire Department (station at Yosemite and Broadway, Seaside). [ScopingMTG2-34] The EIR should address access for residents during construction. [ScopingMTG2-35]
Air Quality The EIR should use the MBUAPCDs 2008 CEQA Guidelines to evaluate air quality impacts. [L_MBUAPCD-01] Greenhouse Gases The EIR should evaluate impacts to GHG levels. The evaluation should identify a threshold of significance, provide an estimate of GHGs that would be emitted as a result of project construction and operations, and determine the significance of those GHG emissions. [S_CSLC-12]
The EIR should address the energy needs related to increased pipeline conveyance and the associated effects on carbon footprint. [L_MPWMD-11]
Noise and Vibration The EIR should evaluate the potential for project construction and operation to generate underwater noise or vibration that could potentially impact marine biological resources. [S_CSLC-06] Public Services and Utilities
The EIR should describe how brine from the desalination plant would be discharged. The EIR should also evaluate available capacity in the MRWPCA ocean outfall for brine discharges. [G_CPW-09] MOU between MRWPCA and the MCWD states that MCWD has the right to use of a portion of the MRWPCA outfall capacity. [G_CPW-39] The EIR should evaluate emergency response times for the Seaside Fire Department (station at Yosemite and Broadway, Seaside). [ScopingMTG2-34] The EIR should evaluate the reduction in wastewater volume going to the recycling facility. [ScopingMTG2-43]
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Aesthetics
The EIR should address the aesthetics impacts of the Terminal Reservoir. The Terminal Reservoir should be set back off of General Jim Moore and be partially submerged underground. [ScopingMTG2-36] The EIR should incorporate detention basin in the design for the overflow capacity for the Terminal Reservoir. The City of Seaside worked with CalAm on a park conceptual design for area around Terminal Reservoir to integrate park space and address aesthetic impacts. The Bureau of Land Management owns land behind the Terminal Reservoir site. [ScopingMTG2-37]
Cultural Resources
The EIR should evaluate impacts to cultural resources, including shipwrecks and any submersed archaeological sites or historic resources that have remained in State waters for more than 50 years. [S_CSLC-11]
Agriculture and Forestry

The EIR should provide a detailed analysis of Salinas Valley Groundwater Basin water rights issues, including an analysis of existing water rights and impacts to agricultural land associated with the transfer of water rights to CalAm. [G_AgLandTrust-03] The EIR should evaluate impacts to agricultural lands resulting from facility siting. [G_AgLandTrust-04] The EIR should evaluate impacts to preserved agricultural lands. [G_AgLandTrust-15] The EIR should evaluate impacts to agricultural lands associated with any adverse effects on water rights held by agricultural water users. [G_SVWC2-04]
Energy
The EIR should address the energy needs related to increased pipeline conveyance and the associated effects on carbon footprint. [L_MPWMD-11] The EIR should evaluate the beneficial/negative effects of reclaimed methane gas as an energy source. [G_CPW-10] The EIR should consider the use of green or sustainable energy sources for operation of desalination facilities. [G_SPG-08] The EIR should include a discussion on the electric power (PG&E) transmission lines and associated construction impacts. [ScopingMTG2-01]
Cumulative Impacts
The EIR should evaluate cumulative impacts to Western Snowy Plover associated with the proposed seawater intake system and CEMEX mining activities. [F_USFWS-02] The EIR should consider public participation proposals for small water projects that have been submitted to the CPUC, both with respect to potential cumulative impacts and as project alternatives. [L_PacGrove-05]
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The EIR should describe all proposed desalination projects in the area, including the status of environmental review, associated impacts, and the status of mitigations adopted. [G_AgLandTrust-05] The EIR should evaluate cumulative impacts. [G_AgLandTrust-14] The cumulative analysis should consider the effects of the proposed MPWSP desalination plant in combination with other future desalination projects in the Monterey Bay area. [G_SPG-05] The EIR cumulative analysis should address the impacts of both the MPWSP and the Peoples Project being approved (cumulative, growth inducing). [ScopingMTG1-05] The EIR should address cumulative projects and actions impacts. [ScopingMTG1-09] The EIR should evaluate the cumulative impacts of brine from many desalination plants in the Monterey Bay area. [ScopingMTG1-17] The EIR should address cumulative effects of incremental projects like Groundwater Replenishment, ASR, and others. [ScopingMTG2-20]
Alternatives
Project alternatives should be evaluated at a sufficient level of detail to accurately determine the relative environmental impacts associated with each alternative. [F_USFWS03] The alternatives analysis should provide a full comparative analysis of the effects of each alternative on federally listed species. [F_USFWS-05] The EIR should consider locational alternatives that would place all facilities outside of Western Snowy Plover habitat. [F_USFWS-06] The EIR should clearly explain the relationship between the Coastal Water Project and the MPWSP, and the relationship between the MPWSP and the Deepwater Desal Alternative and the People's Moss Landing Desal Alternative. [S_CSLC-03] The EIR should evaluate a full range of project alternatives. [L_Monterey-01] The EIR should evaluate project alternatives at the same level of detail as the proposed project. [L_Monterey-03; L_MPWMD-02; L_PacGrove-06; G_CPW-02] The descriptions of project alternatives in the EIR should be based on the most current information available. [L_MPWMD-03] The alternatives analysis should identify and consider the environmental impacts and benefits associated with groundwater replenishment. [L_MPWMD-05] If it is determined that CalAms current allocation of Seaside Groundwater Basin supplies still exceeds the safe yield of the groundwater basin, these supplies could be further reduced to prevent seawater intrusion. The EIR should consider project alternatives that would provide sufficient supplies to serve customers and allow for aquifer recovery in the
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event CalAm is required to cease all pumping from the Seaside Groundwater Basin. [L_MPWMD-07] The EIR should evaluate the seawater intrusion and groundwater quality effects associated with extracting banked ASR water supplies via the ASR injection/extraction wells vs. from CalAm production wells at different locations. [L_MPWMD-13] The EIR should consider public participation proposals for small water projects that have been submitted to the CPUC, both with respect to potential cumulative impacts and as project alternatives. [L_PacGrove-05] The EIR should evaluate a locational alternative that would site the desalination plant at the former National Refractories site in Moss Landing. [G_AgLandTrust-17] The alternatives analysis should evaluate the commercial project alternatives (i.e., Peoples Moss Landing Desal, DeepWater Desal) but without mention of the commercial ventures. In addition, the EIR should evaluate a variety of design alternatives (i.e., facility locations, brine discharge facilities, pipeline alignments) that could be mixed and matched to address environmental impacts, project costs, and schedule considerations. [G_CalAm-03] The alternatives analysis should consider the modified design options and locational alternatives presented in CalAms Contingency Plan dated November 1, 2012. [G_CalAm04] To expedite permitting and project construction, the EIR should evaluate alternative alignments for the Monterey Pipeline and transfer pipeline that would move these pipelines outside of the Coastal Zone. [G_CalAm-08] The EIR should evaluate a project alternative sized with sufficient production capacity to meet future water demand under general plan build-out conditions. Future demand under the general plan build-out alternative should account for: (a) existing legal lots of record; (b) increased demand resulting from general plan build-out; and (c) non-residential (associated with hospitality and tourism) water use under recovered economic conditions. [G_CPB-01] Alternatives involving groundwater replenishment may not be feasible given lack of funding and concerns related to water rights. [G_CPB-03] As part of the MPWSP EIR efforts, the CPUC should conduct the environmental studies necessary for implementation of a general plan build-out alternative. [G_CPB-05] The descriptions of project alternatives in the EIR should be based on the most current information available. The CPUC should give the proponents of project alternatives a deadline for providing up to date alternatives information for incorporation into the EIR. [G_CPW-03] The description of the Peoples Moss Landing Desalination project presented in the NOP should be updated to reflect the most recent project information. Commenter is in favor of Peoples Moss Landing Desalination project. [G_CPW-04] Project alternatives involving groundwater replenishment may not have a reliable source of reclaimed water during all water year types. [G_CPW-08]
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The EIR should evaluate project alternatives with respect to required approvals and overall feasibility. [G_CPW-12] The alternatives analysis should describe the desalination technologies proposed by each alternative. [G_CPW-13] The alternatives analysis should consider the impacts of the various intake structures/technologies proposed by each alternative. [G_CPW-14] The alternatives analysis should consider drought reliability. [G_CPW-15] The alternatives analysis should consider direct and cumulative impacts to marine resources associated with brine discharge from alternative desalination projects. [G_CPW26] The alternatives analysis should consider the technical feasibility, implementation schedule, and overall risk associated with alternative projects. [G_CPW-27] The alternatives analysis should consider the likelihood for the desalination alternatives to be legally challenged in court. [G_CPW-28] The EIR should compare the cost of implementing the alternative desalination projects, as well as the degree of regional economic benefit associated with each. [G_CPW-29] The Moss Landing alternatives would result in different significant environmental impacts, avoid significant legal challenges, and result in cost savings for ratepayers when compared to the MPWSP. [G_CPW-32] The EIR should assess the near- and long-term regional economic benefits associated with each project alternative. [G_CPW-35] The alternatives analysis should provide a comparison of the MPWSP and the desalination alternatives based on: infrastructure feasibility, environmental impacts associated with the seawater intake/brine discharge, feasibility/risk comparison, rough order of magnitude cost comparison, and overall project comparison. [G_CPW-36] The EIR should consider locational alternatives for the proposed seawater intake system that are outside of the Salinas Valley Groundwater Basin. [G_LandWatch-01; G_SVWC101; G_SVWC2-06; G_WaterPlus1-01] The feasibility of the Groundwater Replenishment alternative is speculative due to uncertainties regarding reclaimed water availability. [G_MPTA-02] The evaluation of the No Project Alternative should address compliance with the SWRCBs Cease and Desist Order. [G_PCL-01] Commenter expressed support for alternatives that involve Groundwater Replenishment. [G_SPG-03] Commenter expressed support for project alternatives that include publicly owned and operated water supply infrastructure. [G_SPG-10; I_Fierro-01]
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The alternatives analysis should evaluate entrainment and impingement impacts associated with open water intakes, and evaluate the level of mortality of marine resources associated with each desalination alternative. [G_Surfrider-02] The EIR should evaluate the environmental impacts of CalAms contingency options so that these options can move forward in the event that the MPWSP and other desalination alternatives are determined to be infeasible. [G_Surfrider-06] Commenter expressed support for alternatives that would reduce the capacity of the desalination plant and/or that would meet water needs without desalination. [G_Surfrider08] The alternatives analysis should evaluate a stand-alone conservation alternative that would meet water needs by implementing strategies such as grey water systems, rainwater collection, landscape modifications, and water audits that reduce demand for potable water supplies. [G_Surfrider-09] Commenter expressed support for alternatives that involve reclaimed wastewater and groundwater replenishment. [G_Surfrider-10] The EIR should consider a reduced-capacity desalination alternative that incorporates maximum achievable conservation measures. [G_Surfrider-11] The EIR should evaluate the potential impacts to groundwater associated with the installation of shallower seawater intake wells that are screened in the sand-dune aquifer, as described in CalAms contingency plan. [G_SVWC2-05] The EIR should consider potential reliability and sustainability issues associated with groundwater replenishment and aquifer storage and recovery. Such issues include the potential to exacerbate seawater intrusion, the reliability of Carmel River diversions for injection into ASR, and the availability of reclaimed wastewater for groundwater replenishment. [G_WaterPlus3-01] Commenter expressed support for project alternatives that include facilities that are publicly owned and operated. [G_WaterPlus3-03] The EIR should consider rainwater harvesting and greywater systems for demand management and supplemental sources of supply. [I_Brehmer-01] The alternatives analysis should consider open water intakes and shallow horizontal collectors (i.e., Ranney collectors) as design alternatives to the proposed seawater intake system. [I_Dolan-02] The EIR should consider a variety of energy sources and configurations to reduce the cost of operating the proposed desalination plant. [I_Dolan-04] The EIR should confirm the applicability/feasibility of the lower cost energy sources associated with the Deepwater Desalination project. [I_Dolan-05] The EIR should include a thorough evaluation of the project alternatives proposed by other entities, including hybrid alternatives that incorporate some of the design aspects of the competing alternatives. [I_Ekelund-01]
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The EIR should clearly describe how the CPUC intends to address the various permitting obstacles and regulatory hurdles, and consider project alternatives that circumvent these issues so that the project can move forward. [I_Ekelund-02] Commenter expresses support for the Peoples Moss Landing Desalination project. [I_Olsen-04] EIR should consider an alternative involving desalination by the Carmel Area Wastewater District (CAWD). If an alternative project involving desalination by CAWD appears feasible, CalAm should be obligated to purchase water from CAWD or make the CalAm distribution system available to CAWD for delivery of potable water to Carmel and the Carmel Valley. [I_Siegfried2-01] The EIR should examine of the No Project Alternative and identify potential impacts of implementing the No Project Alternative, including vegetation loss, housing, agriculture, water supply, employment/hospitality, vehicle miles traveled. [ScopingMTG1-02] Coordination with other CEQA Lead agencies, i.e. Pacific Grove and DeepWater Desalination should be conducted. [ScopingMTG1-03] The EIR cumulative analysis should address the impacts of both the proposed project and the Peoples Moss Landing Project being approved (cumulative, growth inducing). [ScopingMTG1-05] The EIR analysis should compare alternative projects. [ScopingMTG1-07] Further consideration should be given to recycled water so desalinated water does not have to be used. [ScopingMTG1-16] The EIR should include an accurate description of Peoples Moss Landing Project. Commenter is concerned about the available water to North County. [ScopingMTG2-02] The EIR should include an accurate description of the DeepWater Desalination Project. [ScopingMTG2-03] The EIR should evaluate all alternatives at the highest level of detail so those projects do not have to go through the CEQA process again. [ScopingMTG2-06] The EIR should include the Marina Coast Water District 1.5 3.0 MGD desalination plant. [ScopingMTG2-09] The EIR should rename Peoples Project to Pacific Grove Project. [ScopingMTG2-11] Further consideration should be given to well and treatment plant relocations in Seaside to reduce pipeline length. [ScopingMTG2-44] The EIR should evaluate better/more effective use of CalAms existing systems. [ScopingMTG2-46] The EIR should evaluate a solution to reduce water consumption to 4,500 acre-feet. [ScopingMTG3-02]
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The EIR should address the pros and cons of each alternative, using parameters like technical feasibility, cost, and location. [ScopingMTG3-03] The EIR should evaluate an alternative that involves a water transfer from the Central Valley. [I_Thomas-01]
Growth Inducing Effects

Although the production capacity for the MPWSP should be based on replacement supply needs, conveyance facilities should be sized to accommodate future growth, general plan build out, and unforeseen changes in the availability of CalAms existing water supplies. [L_MPWMD-10] Further consideration should be given to the size of conveyance facilities given the potential reduction in CalAm Carmel River diversions below their existing entitlements (i.e. if Los Padres Dam were removed). The EIR should evaluate if the conveyance pipelines would need to be increased in capacity. [ScopingMTG1-08] The EIR should identify the demand the project is intended to serve. The EIR should evaluate the impacts of downsizing and upsizing the capacity. [ScopingMTG2-19] The EIR should evaluate the implementation of larger pipelines and additional water treatment capacity for the growing needs on the Peninsula. [ScopingMTG2-42] The EIR should address the maintenance of the facilities and the examination of water leaks in the system. [ScopingMTG2-45]
CEQA/NEPA Process
The MBNMS would like to meet with CPUC and all pertinent regulatory agencies to identify roles and responsibilities related to oversight and permitting, including NEPA requirements. [F_USFWS-02] Mitigation measures should be feasible, specific, and enforceable, or should be presented with specific performance standards that can be accomplished in more than one specified way. [S_CSLC-04] The MPWMD will rely on the certified MPWSP Final EIR when considering the amendment to CalAms water distribution permit for the MPWSP. [L_MPWMD-01] The CPUC should determine NEPA requirements early in the environmental review process. [L_MPWMD-04] The CPUC should confirm the appropriate level of CEQA environmental review (i.e., project-level EIR versus Programmatic EIR). [L_Monterey-02] The EIR should be clear about the NEPA requirements relevant to the MPWSP. If NEPA environmental review is required, the CPUC should prepare a joint CEQA/NEPA document to minimize schedule delays. [L_Monterey-04; L_PacGrove-03] The NOP should have been more explicit about the environmental effects of the MPWSP; this would allow responsible and trustee agencies to provide more meaningful comments. [L_PacGrove-04]
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It is imperative that the CEQA environmental review process stay on schedule in order to meet the SWRCBs Cease and Desist Order. [G_CalAm-01] MPWSP EIR should consider the Monterey County Superior Courts ruling on the CWP EIR, which determined that water rights were not adequately addressed in the CWP EIR. [G_CPW-01] The descriptions of project alternatives in the EIR should be based on the most current information available. The CPUC should give the proponents of project alternatives a deadline for providing up to date alternatives information for incorporation into the EIR. [G_CPW-03] CEQA requires the evaluation of feasible project alternatives and the consideration of economic benefits and costs associated with a project and its alternatives. [G_CPW-37] The EIR should coordinate with the Monterey Bay National Marine Sanctuary during the NEPA process. [ScopingMTG1-04] The commenter questioned if the environmental review is a program and project level. [ScopingMTG2-05] The EIR should address impacts related to NEPA. The National Marine Sanctuaries representative is Brad Damitz and was part of State Desal Task Force. [ScopingMTG2-16] The EIR should include a NEPA evaluation since the slant wells are within National Marine Sanctuaries jurisdiction. The appropriate NEPA lead agency should be identified early in the EIR process to avoid project delay. [ScopingMTG2-18] Timing of the NEPA lead agency determination is relevant to the timing of EIR preparation. [ScopingMTG2-26]
Consistency with Plans and Polices

The EIR should evaluate conflicts with plans and policies related to the MBNMS and Marine Protected Areas. [S_CSLC-10] The EIR should evaluate project consistency with the Monterey County General Plan and the Monterey County Local Coastal Program. [L_MCRMA-01] The EIR should evaluate project consistency with the Agency Act. [L_MCRMA-03] The EIR should evaluate the MPWSPs consistency with the Coastal Act, North County Land Use Plan, Coastal Implementation Plan, Monterey County General Plan, and plans and policies related to farmland preservation, water quality, and contamination of potable water supplies. [G_AgLandTrust-07] The EIR should evaluate project consistency with land use zoning. [G_AgLandTrust-13] The EIR should address the legal feasibility of the proposed project in light of the Monterey County ordinance prohibiting the private ownership of desalination facilities. [G_CPW-05]
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The EIR should evaluate project consistency with North County Local Coastal Plan. [G_CPW-17]
General Comments
The CPUC should require the development of a contingency plan in the event the slant wells are not viable. [L_MCWRA-04] Commenter requests that the CPUC provide a list of the specific non-environmental issues that will be addressed in the CPCN process. [L_PacGrove-01] The EIR should map all areas that would be potentially affected by the proposed project. [G_AgLandTrust-11] The CPUC should require that CalAm conduct a water supply assessment for the MPWSP. [G_AgLandTrust-20] Mitigation measures should be clearly described, measurable, and achievable. [G_AgLandTrust-21] Commenter requests that measurements of water be provided in acre feet. [G_AgLandTrust-22] Commenter requests that EIR tables be formatted with numbers vertically aligned. [G_AgLandTrust-23] The EIR should evaluate project impacts as early as possible. [G_AgLandTrust-24] The EIR should address the environmental issues identified by the Ag Land Trust in its briefing to the Monterey Superior Court with regard to the Coastal Water Project Final EIR. [G_AgLandTrust-25] The CPUC should consider that diluting brine with wastewater effluent affects the ability to reuse the effluent as an alternative water source. [G_Surfrider-04] A substantial amount of water is lost through leaks in the CalAm water system. These losses could be avoided if CalAm maintained the system properly. [G_WaterPlus2-01] Comment unclear - please refer to comment letter. [I_Olsen-06] The EIR should include numeric values of water in acre-feet per year, in addition to description of million gallons, so there are comparable units of measurement. [ScopingMTG2-07]
Issues Not Analyzed under CEQA

The EIR will be used to guide decision-making by the CPUC by providing an assessment of the potential environmental impacts that may result from the proposed project. The weighing of project benefits (environmental, economic, or otherwise) against adverse environmental effects is outside the scope of the CEQA process. (Public Resources Code Section 21100; CEQA Guidelines Section 15002(a).) When the CPUC meets to decide on CalAms application for the proposed project, the CPUC will consider the EIR (which will disclose potential environmental
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effects of the proposed project and the Project Alternatives) along with other, non-environmental considerations. Then it will decide whether or not to approve or deny the proposed project. The EIR will not consider comments related to water rates. Further, pursuant to CEQA, the EIR will not consider comments that relate to potential economic impacts. Although not a part of the EIR or the CEQA process, economic considerations will be taken into account by the CPUC as part of its decision-making process for the application.
Water Rates
The EIR should evaluate impacts on water prices. [ScopingMTG1-15] The commenter questioned how the capital cost (and subsequent rates) will be affected by not having a power source near the desalination plant site. [ScopingMTG2-28]
Drinking Water Quality

The EIR should evaluate any potential health risks associated with drinking desalinated product water. [I_Siegfried3-02]
Economics
The EIR should evaluate secondary economic impacts associated with loss of agricultural land. [G_AgLandTrust-16] The EIR should provide cost information for each project component, including the costs associated with mitigation measures. [G_ CPW-30] CalAm should establish cost controls and performance incentives and disincentives advantageous to the ratepayer. The MPWSP EIR should avoid costly legal challenges. [G_ CPW-31] The Moss Landing alternatives would result in different significant environmental impacts, avoid significant legal challenges, and result in cost savings for ratepayers when compared to the MPWSP. [G_CPW-32] The EIR should assess the regional economic benefits of the MPWSP, not only for Marina, the Monterey Peninsula, and Carmel, but also for coastal communities in northern Monterey County located east of the Salinas River. [G_ CPW-34] The EIR should assess the near- and long-term regional economic benefits associated with each project alternative. [G_CPW-35] The Division of Ratepayer Advocates provided comments on the Settlement Agreement suggesting that the agreement failed to address costs and risks to ratepayers. [G_ CPW-38] The EIR should describe project cost and financing. [G_WaterPlus3-02] CalAm should improve maintenance of its water supply infrastructure to better manage ratepayer costs. [G_WaterPlus5-01; I_Olsen-02] CalAm unfairly requires that ratepayers pay for costly improvements to CalAm infrastructure that benefits only a small portion of the service area. [I_Holston-01]
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CalAm should conduct public surveys to identify the types of water supply projects that have public support and better manage ratepayer costs. [I_Olsen-01]
Opinions on the Proposed Project

The information developed for the Coastal Water Project Final EIR, when updated to reflect current conditions and legal requirements, serves as a good basis for preparation of the MPWSP EIR. [G_CalAm-02] Neither the Regional Water Project nor the MPWSP consider regional solutions that include a diverse group of beneficiaries, not just CalAm ratepayers. [G_CPW-33] Commenter is opposed to the MPWSP project. [G_MPTA-04] CalAm should improve maintenance of its water supply infrastructure to better manage ratepayer costs. [G_WaterPlus5-01; I_Olsen-02] Commenter expressed concern regarding the MPWSP implementation schedule and CalAms ability to meet the SWRCBs Cease and Desist Order. [I_Bottomley-01; I_Olsen-03] Commenter expressed doubts about the efficiency of the project review process, project implementation schedule, the potential for legal challenges to the MPWSP, and increased costs for ratepayers. [I_Bottomley-02] Commenter encourages responsible and trustee agencies, local government agencies, agricultural interests, and decision makers to assist in developing supplemental supply solution and streamlining the project review process. [I_Bottomley-03] Commenter expressed support for MPWSP. [I_Carrothers-01; I_Fillmon-01] Commenter encourages CalAm to consider expanding the MPWSP to include water supplies for CalAm customers in the Toro basin, a tributary basin to the Salinas Valley Groundwater Basin, and that these customers pay the full production cost of the water. [I_Dolan-03] CalAm unfairly requires that ratepayers pay for costly improvements to CalAm infrastructure that benefit only a small portion of the service area. [I_Holston-01] CalAm should conduct public surveys to identify the types of water supply projects that have public support and better manage ratepayer costs. [I_Olsen-01]
5. Consideration of Issues Raised in Scoping Process

A primary purpose of this Scoping Report is to document the process of soliciting and identifying comments from interested agencies and the public. The Scoping Process provides the means to determine those issues that interested participants consider to be the principal areas for study and analysis for purposes of preparation of the MPWSP EIR. Every issue that has been raised during the Scoping Process that falls within the scope of CEQA will be addressed and/or will be considered in the EIR.
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6. Scope of Alternatives Analysis

CEQA Guidelines Section 15126 requires EIRs to describe and evaluate a reasonable range of alternatives to a project, or to the location of a project, which would feasibly attain most of the basic project objectives and avoid or substantially lessen significant effects of the project. The EIR will describe the development and screening of potential project alternatives, present the selected project alternatives, evaluate the alternatives for consistency with stated project objectives, and summarize and compare the environmental impacts and trade-offs of the alternatives, in order to identify the environmentally superior alternative.
6.1 Types of Alternatives

In addition to the No Project alternative, there are two types of alternatives that are typically reviewed in an EIR: (1) alternatives to the project as a whole, that are other projects entirely, or other approaches to achieving the project objectives rather than the project or a modified version of the project; and (2) alternatives to project elements, that include modified project components, such as alternative desalination plant sites or processes and/or modified facilities, layout, size, and scale (such as alternate well configurations and locations or alternate pipeline routes). The EIR will evaluate both types of alternatives in order to provide a reasonable range of alternatives for comparison. The EIR will focus specifically on alternatives that could reduce the impacts of CalAms proposed project.
6.2 Alternatives Screening

As defined by CEQA Guidelines 15126.6(a), an EIR need not consider every conceivable alternative to a project, but must consider a reasonable range of alternatives that will foster informed decision-making and public participation. The range of alternatives that will be examined in the EIR will be consistent with the rule of reason established by CEQA, and will focus on feasible alternatives capable of meeting the project objectives. As the CEQA Lead Agency, the CPUC is responsible for selecting the range of project alternatives for examination and must publicly disclose its reasons for selecting those alternatives. The reasonable range of alternatives includes those that are likely to be feasible based on technical, economic, and environmental factors. In preparing the range of alternatives, the CPUC will consider: (a) whether the alternative would meet the MPWSP objectives; (b) whether preliminary data indicate that the alternative is feasible; (c) whether the alternative would reduce any significant impact(s) likely to result from implementation of the MPWSP; and (d) whether the alternative has been developed at a level of detail sufficient for meaningful evaluation and comparison among alternatives. An EIR need not consider an alternative whose impact cannot be reasonably ascertained and/or whose implementation is remote and speculative. Alternatives suggested by various public agencies and stakeholders during the CEQA scoping process will be included in the initial screening analysis to allow the CPUC to ascertain which alternatives are feasible and which planned water supply projects could potentially be substituted
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for, incorporated into or executed in coordination with the MPWSP. Many of the alternatives that have been suggested and will be evaluated were similarly discussed in the CWP Final EIR, Chapter 7, Section 7.6.2; however, all screening tools and results will be updated, applied, and documented in the MPWSP EIR. In assessing whether the alternatives being screened meet project objectives in order to be carried forward for more detailed analysis, the EIR will consider whether each alternative to the project as a whole and each alternative to project elements can feasibly attain most of the basic project objectives, even if that alternative may impede any project objective to some degree. Factors that may be considered when addressing the feasibility of an alternative include site suitability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, economic viability, and whether the proponent can reasonably acquire, control, or otherwise have access to an alternative site. As provided for in 15126.6(b), any alternatives identified but not found to be capable of meeting basic project objectives or to be feasible will be presented briefly in the Draft EIR, along with the reasons they were eliminated from further analysis. Alternatives to the Project as a Whole: Alternatives to the project represent other opportunities to meet the MPWSP objectives, including, but not limited to, a 5.4-mgd Desalination Plant with Groundwater Replenishment, and other commercial desalination proposals such as The Peoples Moss Landing Water Desalination Project (Peoples Project), and the Deep Water Desal Project. In addition, the EIR will evaluate a conservation/demand reduction alternative that could include local recycled water projects. In the event that entire alternatives to the project as a whole are eliminated on any basis during the preliminary screening process, the individual components of such comprehensive alternatives may well provide a broad, varied, and useful choice of elements to represent a hybrid alternative. Alternatives to the Project Elements: The components of the alternatives to the project as a whole could become alternatives to isolated (but integrated) components of the MPWSP. These alternatives could include intake locations or technologies, desalination plant locations, or pipeline routes, similar to the discussion in the CWP Final EIR, Section 7.5.
To the extent that projects are eliminated during the preliminary screening process, these projects may still be considered in the cumulative analysis if it is reasonably foreseeable that the projects may be independently implemented within the cumulative horizon.
6.3 Alternatives Analysis

Once the screening process is complete, the EIR will have identified and honed in on a range of alternatives whose environmental impacts will be evaluated at a detailed level so as to enable comparison to the MPWSP and among alternatives.
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In addition to the alternatives identified through the screening process described above, the EIR will (as required by CEQA) evaluate the environmental effects associated with the No Project Alternative. Discussion of the No Project Alternative will examine the environmental effects of continuation of existing conditions, as well as reasonably foreseeable future conditions that would exist if the project were not approved (CEQA 15126.6(e)), to allow decision-makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project. In this case, the No Project Alternative would include enforcement of the SWRCB Cease and Desist Order on the Carmel River, which is expected to severely limit the availability of Carmel River water supplies for use in CalAms Monterey District service area.
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Monterey Peninsula Water Supply Project: EIR Scoping Report

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MONTEREY PENINSULA WATER SUPPLY PROJECT

EIR Scoping Report

Prepared for California Public Utilities Commission