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Pure Water Monterey Expansion (PWM-E) Versus �Cal-Am Desalination

How Recycled Water Can Reduce Coastal Impacts, Comply with the CDO, Save $1 Billion, and Meet the Monterey Peninsula’s Water Needs for 30 Years or More

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What is the Problem?

State Water Resources Control Board’s cease-and-desist order (CDO) requires by Dec. 31, 2021 a new water supply to comply with the CDO and allow for growth.
HOWEVER, as a result of many years of mandatory water conservation and higher water costs, the Peninsula’s collective consumption has significantly decreased.
Complying with the CDO requires a trivial 81 AFY of water—less than 1% of ~9,800 AFY water budget.
A billion-dollar water project is unnecessary.

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Important Context: �The Carmel River is NOT Threatened

Using the five-year average pumping through 2019, 3,500 AFY from Pure Water Monterey, already online, ends illegal pumping.

A new water supply is unnecessary to end illegal Carmel River withdrawals, but is necessary to meet demands for future growth.

Water for Carmel River	AFY
5-Year Average Pumping	6,314
Legal Right to Pump	3,376
Illegal Withdrawals	2,938

Pure Water Monterey	3,500
Excess (Safety Margin)	562

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Trivial Water Needed to �Comply with CDO

Water to Comply with CDO	AFY
Carmel River Supply	3,376
Seaside Basin Supply	1,474
ASR Supply	1,300
Sand City Desal Supply	94
Pure Water Monterey Supply	3,500
Total Supply	9,744

5-Year Average Customer Demand	9,825
Additional Water Needed to Comply	81

An inconsequential new water supply is needed to address current customer demand and comply with the CDO.

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What is the Best Solution to Remedy CDO?

For whom?
Principle stakeholders

Monterey Peninsula ratepayers & residents
“Communities of concern” in Monterey County
State of California and state resources

Two options:

Expand the Pure Water Monterey (PWM-E) advanced wastewater recycling expansion from 3,500 AFY to 5,750 AFY
California American’s 7,200 AFY desalination plant

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How Do They Compare?

Factor	PWM Expansion	Cal-Am Desalination
Technology	Proven water recycling in operation today	Unproven slant wells
Environmental Impact	Inconsequential	Numerous and severe
Risks	Insignificant, largely political	Legal (water rights), technology, financial, political
Capacity	2,250 AFY	7,200 AFY (6.4 mgd)
Total Cost (30 Yrs.)	~$200M	$1.2B
Cost/Acre-Foot	$2,600 - $3,000	$5,500 - $15,400
Increase in Average Monthly Water Bill	~$5	~$40 (Cal-Am estimate, real increase unknown)
Time to Water Delivery	20-24 months	30-36 months, assuming no litigation (Cal-Am est.)

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PWM Expansion (PWM-E) Is The Best Solution!

Less environmentally damaging
Lower risks: technology, legal, and operating
Fastest
Less costly
More environmentally just

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PWM-E Has Fewer Environmental Impacts

Impacts	PWM Expansion	Cal-Am Desalination
Terrestrial ESHA	None	Impacts to dozens of acres inconsistent with Marina LCP and Coastal Act policies
Fill in coastal waters	None	Project components in coastal waters do not conform to Section 30233
Wetlands & vernal pools	None	Foreseeable drawdown impacts inconsistent with Marina LCP and Section 30231
Groundwater	None	Current evidence cannot support Section 30231 consistency finding
Energy consumption	Only 45 MWh/yr comes from grid, 23,000 MWh/yr from local biogas facility	52,000 MWh/y – uses twice as much energy as PWM-E, denying offsets or renewables to other users
Greenhouse gas emissions (GHG)	Negligible – 34 MT/yr	Problematic – requires 8,000 MT/yr of offsets or renewable power. Carbon offsets may not be real, permanent, verifiable, and enforceable

From staff report

GHG for PWM-E - 23,000 megawatt hours per year (MWh/yr.) of electricity, almost all from landfill gas that would otherwise be released to the atmosphere, as well as 45 MWh/yr. from the grid

GHG for desal - 52,000 MWh/yr. potentially from grid-based electricity that currently represents production of about 8,000 metric tonnes of CO2 equivalent per year

Substantial impact to dozens of ESHA acres is inconsistent with Marina LCP and Coastal Act's ESHA policies. (Staff Rpt. at 47.)

Project components in coastal waters do not conform to Section 30233. (CCC Staff Rpt. at 66-67.)

Likely impacts from foreseeable groundwater drawdowns are inconsistent with Marina LCP and Section 30231. (Staff Rpt. at 53.)

Without additional modeling and analysis, current evidence does not support a finding of consistency with Section 30231 re groundwater protection.

Problematic: massive 52,000 megawatt hours per year requires carbon offsets, which "does not necessarily result in real, permanent, verifiable, and enforceable greenhouse gas mitigation." (Staff Rpt. at 77, 134.)

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PWM-E Has Much Lower Risk

Risks	PWM Expansion	Cal-Am Desalination
Sea level rise	None	Cal-Am has no easement to relocate wells inland after their expected 20-25 year lives to avoid expected erosion and dune recession; so Project may then be infeasible.
Technology	Proven water recycling	Unproven slant wells, 20-25 year life before replacement.
Return water	N/A	“return water requirements may be greater for the desal than identified in the FEIR. This means that there may not be sufficient water from the desal project to meet demand.”
Legal		“Desal has been and will be the subject of many lawsuits,” e.g., water rights, appropriative rights, etc.
Regulatory & operating	PWM has overcome the startup issues with two additional deep injection wells. It is currently in operation and producing water.	No pipeline to deliver water between desalination facility and service area. No approval to use a pipeline Cal-Am anticipated No approvals to build another pipeline that could distribute the water. Cal-Am must also obtain additional approvals and permits, possibly including additional CDPs, to install a corrosion-resistant liner inside the Monterey One Water outfall it proposes to use.

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PWM-E Is Lower Cost, By Far

Why is Cal-Am’s desal plant so expensive?

Desal far too big for the current and reasonably expected demand.
Desal capital costs greatly exceed PWM-E’s. Cal-Am generates profit on those costs.
Desal subsidizes return water to Castroville by charging Peninsula ratepayers.
Desal requires twice as much energy as PWM-E.

$40 is Cal-Am’s estimate

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Desal Increases Average Monthly Water Rates by at Least $40 (But Who Knows?)

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PWM-E Addresses CDO

PWM-E sufficient for 30+ years
PWM-E addresses CDO sooner considering potential desal litigation
Desal can’t address CDO because of many potential delays— legal, construction, operating

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PWM-E Meets Growth for 30+ Years

Desal would provide excess supply for 80-200 years

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PWM-E Addresses CalAm’s Objections

PWM-E is modest expansion of existing, operating wastewater facility. How can that be infeasible?
PWM-E source water is secure & drought proof (SEIR).
PWM-E relies entirely on excess wastewater, not Salinas Valley groundwater (SEIR).

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PWM-E Source Water is �Secure & Drought-Proof

Source Water	AFY
Total Available	14,448
Less Contingent Supplies	(3,344)
Required for PWM Phase 1	(4,320)
Required for PWM-E	(3,081)
	________________
Excess Source Water	3,703
Excess Source Water with Contingent Supplies	7,047

Ample source water is available to provide 3,081 AFY for PWM-E

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PWM-E Addresses Environmental Justice

Communities of concern are significantly negatively impacted by Cal-Am’s desal project. CCC staff report:

“Cal-Am’s proposed Project would be sited in part within the community of Marina, which is not in Cal-Am’s service area but would be burdened with the adverse coastal resource impacts as discussed above and receive none of the Project benefits.”
“The community of Marina [and Ord] is already disproportionately burdened by many other industrial uses and would receive none of the project benefits. There is a long history of government institutions allowing unwanted industrial development to be concentrated in underserved communities of color without their consent.”

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PWM-E Lower Cost is Most Environmental Just

“Additionally, water from Cal-Am’s desalination facility is expected to cost two to three times as much as the recycled water from the Pure Water Expansion. Water from Cal- Am’s proposed Project could significantly raise water rates for low-income ratepayers in Seaside and other low-income ratepayers throughout the service area …”

- CCC Staff Report

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Cal-Am Project Hurts Low-Income Families on the Monterey Peninsula

Seven times as many low income individuals in Cal-Am’s service area (Monterey, Seaside, etc.) would be burdened by Cal-Am’s desalination facility as those in Castroville that would benefit.
PWM-E benefits communities of concern by avoiding adverse impacts to the City of Marina and by reducing cost burdens to underserved Cal-Am ratepayers.

Disadvantaged Community Data California Department of Water Resources Disadvantaged Communities Mapping Tool https://gis.water.ca.gov/app/dacs/ Block Group Method

Seaside - 33,025

Marina - 22.,781

%69�

pg 9 CCC Aug 25 staff report

Seven times as many low income individuals in Cal-Am’s service area (Marina, Monterey, Seaside, etc.) would be burdened by Cal-Am’s desalination facility as those in Castroville that would benefit (based on a federal low income threshold)

Slide 16 Cal-Am Hurts Low-Income Families

pg 9 CCC Aug 25 staff report�

"...staff found that there were seven times as many individuals in Marina and in Cal-Am’s service area that would be burdened by the desalination facility as those in Castroville that would benefit (based on a federal low income threshold). The Pure Water Expansion, with its water costs of one-third to one-half of Cal-Am’s proposed Project, would benefit the communities of concern by not causing adverse environmental impacts to the City of Marina and by reducing the cost burdens to Seaside and other

pg. 97 CCC Aug 25 staff report

"The discount to Castroville would also not offset impacts to the underserved communities of Marina, Seaside, and others throughout the service area. Although Castroville has 3,742 individuals with income below 200 percent of the federal poverty level, the number of individuals with income below the same poverty guideline in Marina and the Cal Am service area is 27,525, or approximately 7 times greater (see Table 2-pg 89)."

�

Bruce's note: Table 2 and the 3742 vs 27525 Source: U.S. Census Bureau 2014-2018 American Community Survey Data, 5-year estimate. This source is included underneath Table 2 on pg. 89.

�

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Other Environmental Justice Factors

PWM-E doesn’t threaten Marina Coast Water District groundwater supplies.
Cal-Am’s desal plant is a private option driven by corporate shareholder interests.
PWM-E is a public option driven by ratepayer interests.

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Elected Officials Endorsing PWM-E

Senator Bill Monning, California State Senate
Assemblymember Mark Stone, California State Assembly
Jane Parker, Monterey County Supervisor
Clyde Roberson, Mayor of Monterey
Ian N. Oglesby, Mayor of Seaside
Bruce Delgado, Mayor of Marina
Alison Kerr, Mayor of Del Rey Oaks
Jason Campbell, Seaside City Council
Jon Wizard, Seaside City Council
Jenny McAdams, Pacific Grove City Council
Tyller Williamson, Monterey City Council
Alan Haffa, Monterey City Council
Jeff Baron, Carmel City Council
Steve McShane, Salinas City Council
George Riley, Monterey Peninsula Water Management District
Alvin Edwards, Monterey Peninsula Water Management District
Tom Moore, Marina Coast Water District Board

Jan Shriner, Marina Coast Water District Board
Herbert Cortez, Marina Coast Water District Board
Matthew Zefferman, Marina Coast Water District Board
Lisa A. Berkley, Marina City Council
Gail Morton, Marina City Council, Mayor Pro Tem
Wendy Root Askew, Monterey Peninsula Unified School District Trustee
Veronica Miramontes, Monterey Peninsula Unified School District Trustee
Debra Gramespacher, Monterey Peninsula Unified School District Trustee
Alana Myles, Monterey Peninsula Unified School District Trustee
Yuri Anderson, Monterey Peninsula College Trustee
Rosalyn Green, Monterey Peninsula College Trustee
Regina Gage, Salinas Valley Memorial Hospital Board, Anthony Rocha, Salinas Union High School District

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Others Endorsing PWM-E

Public Agencies

City of Marina
Marina Coast Water District
Monterey Peninsula Water Management District

Community Organizations

Ag Land Trust
California Surfrider Foundation
Carmel Valley Association
Center for Biological Diversity
Citizens for Just Water
Citizens for Sustainable Marina
Communities for Sustainable Monterey County

Community Organizations

CURE (unions)
Democratic Women of Monterey County
Endangered Habitats League
LandWatch Monterey County
League of Women Voters of Monterey County
Planning and Conservation League
Public Water Now
Save Our Shores
Sierra Club
Sustainable Monterey
Sustainable Seaside
Sustainable Del Rey Oaks
Western Alliance for Nature

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Conclusion

81 AFY is a trivial amount of water.
PWM-E is least damaging, least risky, least costly and most socially just option for addressing CDO.
PWM-E is faster because it is an “add-on” to an existing facility.
PWM-E is supported by majority of elected officials in diverse communities.

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CCC Staff Conclusion

“Staff believes, after weighing the evidence in the record at this time, that the Pure Water Expansion is a feasible alternative to Cal-Am’s Project, will allow Cal-Am to cease its illegal water withdrawals from the Carmel River and meet the region’s water needs, and is the preferable, least environmentally damaging alternative. The Pure Water Expansion would also result in fewer environmental and economic burdens to the communities of concern within Cal-Am’s service area, would avoid environmental burdens to the City of Marina, and appears to have fewer significant hurdles to clear before it could be implemented.”

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Questions?

.

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References

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Source Waters Available for PWM in General

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Example of Source Waters for PWM-E