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PROPOSED NEW MONTEREY COUNTY DESALINATION PLANS


Monterey Peninsula Water Management District Scoping Report

SCOPING COMMENTS ON ALTERNATIVES - 10/OCT/97

Topic

Scoping Comment

Response to Scoping Comment

Update alternatives analysis with new project purposes

Update alternatives to reflect the no-growth character and requirements of the proposed project.

III; the EIR will screen alternatives based on project objectives in accordance with State CEQA Guidelines Section 15126 (d); because no growth (i.e., no increase in water production) is a stated project objective by Cal-Am, this purpose will be used to screen alternatives.

Alternative screening

Unresolved technical uncertainty (related to the mitigation measure addressing changes in the river channel) should exclude the dam as an alternative.

V; the mitigation measure referred to is not considered technically uncertain or too costly to implement (MPWMD final EIR/EIS, March 1994); therefore, applying the referenced screening criteria does not exclude the dam as an alternative.

The stated project purposes artificially justify a mainstem project.

III; State CEQA Guidelines Section 15124(d) requires that the project description contain a statement of the objectives sought by the project proponent. The project objectives stated in Chapter 2 of this scoping report are those sought by Cal-Am. According to the State CEQA Guidelines, the EIR need only examine in detail the alternatives that the lead agency determines could feasibly attain most of the project objectives. If a "non-mainstem" alternative is determined feasible, able to meet most of the project objectives, and able to reduce or avoid a significant impact caused by the proposed project, it should be reviewed in the EIR. Therefore, these objectives do not preclude review of non-mainstem projects and do not justify a mainstem project.

Water use

The project should be sized such that all people who are entitled to water would be able to reasonably use water, including remodels, additions, building on each legal lot of record, and commercial businesses. Subdivisions do not need to be included. How will Cal-Am provide for legal lots of record and remodels (if 1,600 af that is available is not used)?

V; Cal-Am's project objectives do not include providing water for legal lots of record, remodels, and commercial businesses from the CRDRP; the EIR will address whether water is available from other sources to provide for these uses in the analysis of growth inducement and cumulative impacts.

Desalination

Desalination plants in Seaside and Monterey; include accurate (not overinflated) cost information; use medium-sized desalination plant for water supply protection and to allow for moderate growth

III, I; the EIR will contain an updated alternatives analysis that evaluates the feasibility (including cost) of desalination as a stand-alone project or in combination with other projects in meeting project objectives. The MPWMD undertook a review of various non-dam-related alternatives, including desalination, when the electorate voted down the NLP project; this information will be reviewed during preparation of the supplemental EIR.

The Regional Water Quality Control Board (RWQCB), in a resolution to the SWRCB, stated that desalination discharges do not contribute the type of pollutants that are a concern in the Prohibition Zone, which extends from Point Pinos to the Salinas River; a Basin Plan amendment is necessary to allow desalination in Monterey Bay; proposals must satisfy CEQA and complete the National Pollutant Discharge Elimination System process; SWRCB adopted and approved RWQCB's resolution

I; this aspect of desalination will be reviewed when considering the feasibility of desalination.

Seaside Basin

Consider injecting surplus water from the Carmel River during winter months in the Seaside Basin to provide more yield

IV; this alternative will be reviewed for feasibility either as a separate project or in combination with other alternatives.

Other Individual Alternatives

Pebble Beach Reclamation project of 800 af

V; MPWMD staff is participating in technical and financial evaluations of projects that could result in the expansion of the reclamation project to Pacific Grove; this alternative has been previously reviewed for feasibility and has been rejected as not feasible; it will be determined if there is any new information available that would change the previous conclusion.

Use of the two Cal-Am reservoirs in Pacific Grove

V; this alternative is related to the Pebble Beach Reclamation project; this alternative has been previously reviewed for feasibility and has been rejected as not feasible; it will be determined if there is any new information available that would change the previous conclusion.

Use water banks (voluntary transfer of water rights held by farmers and golf courses in the valley to Cal-Am)

IV; this alternative will be reviewed for feasibility.

Dredging the two dams in service (San Clemente and Los Padres)

V; this alternative has been previously reviewed for feasibility and has been rejected as not feasible as a stand-alone project; it may be reviewed in a combination alternative (2a) described below.

Assertion of Pueblo water rights

V; this alternative has been previously reviewed for feasibility and has been rejected as not feasible; it will be determined if there is any new information available that would change the previous conclusion.

Challenging the state's assertion that the river is a subterranean stream

V; this alternative has been previously reviewed for feasibility and has been rejected as not feasible; it will be determined if there is any new information available that would change the previous conclusion.

Digging more wells in other areas than the river

V; this alternative has been previously reviewed for feasibility and has been rejected as not feasible; it will be determined if there is any new information available that would change the previous conclusion.

Ocean-going water bags that can transport water from northern areas rich in rainfall

IV; this alternative will be reviewed for feasibility.

Buying water from Rancho San Carlos

IV; this alternative will be reviewed for feasibility.

Cisterns

V; this alternative has been previously reviewed for feasibility and has been rejected as not feasible as a stand-alone project; it may be evaluated in a combination alternative (3).

Storm drain recovery

V; this alternative has been previously reviewed for feasibility and has been rejected as not feasible as a stand-alone project; it may be evaluated in a combination alternative (3).

SAMDA proposal of 1,000 af per year; deep drilling and fractured rock sources

IV; this alternative will be reviewed for feasibility.

Build a pipeline from San Luis Reservoir to the Seaside aquifer to enable the transport and storage of water

V; this alternative has been previously reviewed for feasibility and has been rejected as not feasible; it will be determined if there is any new information available regarding this alternative that would change the previous conclusion.

Combination alternatives

Combination Alternative 1: Desalination plant (3,000 af) to operate 12 months per year and water injected into the Seaside aquifer

IV; the EIR will evaluate the feasibility of a combination alternative. CEQA does not require the lead agency to examine every possible permutation or combination, but rather states that the range of alternatives is governed by a "rule of reason" that requires an EIR to set forth only those alternatives necessary to permit a reasoned choice.

Combination Alternative 2a: Retrofit existing water appliances with water-saving counterparts (2,160 af savings); progressive rate schedule (500-1,500 af savings); pump more water from Seaside Peralta well (500-1,000 af); buy Fort Ord's water rights (2,000-6,600 af); dredge existing reservoirs (2,400 af); require all peninsula golf courses to use reclaimed wastewater (2,000-2,350 af); reduce water pressure to reduce leakage (500-1,500 af); dual plumbing, including retrofitting and new construction (1,000-3,000 af); pump water out of Carmel River during winter rains and force it into Seaside underground basin, to be pumped out in the summer and fall (1,500 af); No Dam, No Desalination Alternative: 12,500-22,450 af

IV; the EIR will evaluate the feasibility of a combination alternative; CEQA does not require the lead agency to examine every possible permutation or combination but rather states that the range of alternatives is governed by a "rule of reason" that requires an EIR to set forth only those alternatives necessary to permit a reasoned choice.

Combination Alternative 2b: Add to Combination Alternative 2a - Rent or purchase a desalination plant (1,000-3,000 af) for use on standby basis; No Dam Alternative: 13,500-23,450 af

Combination Alternative 3: Repair leaking pipes (500-1,500 af); buy Fort Ord's water rights (2,800-6,600 af); dredge Los Padres and San Clemente Dams (2,400 af); use reclaimed wastewater on all existing golf courses on the peninsula (2,000-2,500 af); retrofit water appliances at Cal-Am's expense (2,100 af); establish progressive rate schedule (500-1,500 af); equip new construction with dual plumbing, cisterns, and underground water tanks (1,000-3,000 af)

IV; the EIR will evaluate the feasibility of a combination alternative. CEQA does not require the lead agency to examine every possible permutation or combination but rather states that the range of alternatives is governed by a "rule of reason" that requires an EIR to set forth only those alternatives necessary to permit a reasoned choice.

Use: 3,376 af Cal-Am rights from the river; 2,964 af Cal-Am rights provided by the state; 6,000 af desalination plant; and 4,700 af from the Seaside Basin, for a total of 16,340 af/yr; determine if 2,964 af can be used outside of the basin; if not, transfer water; if so, include another well in Seaside (may produce 1,000 af)

IV; the EIR will evaluate the feasibility of a combination alternative. CEQA does not require the lead agency to examine every possible permutation or combination but rather states that the range of alternatives is governed by a "rule of reason" that requires an EIR to set forth only those alternatives necessary to permit a reasoned choice.

No-Project Alternative

The EIR must evaluate the No-Project Alternative as that amount of water available based on Cal-Am's existing water rights; the EIR should evaluate all impacts of the No-Project Alternative, including social and economic impacts

V; the No-Project Alternative is defined under CEQA as existing conditions; thus, the existing water production limit of approximately 17,640 af/yr will be used in the EIR, which is substantially the same as was used in the NLP EIR/EIS. The EIR will evaluate the reasonably foreseeable socioeconomic effects of the No-Project Alternative but will not engage in speculation or attempt to forecast unforeseeable consequences of not building a water supply project.

Costs for alternatives

Provide cost comparison of all alternatives; use chart

V; cost information will be provided for alternatives evaluated in detail in the EIR; a chart may be used to present this information if it is determined to be useful and aid in decision making.



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