PWM Final Eir September 2015

FINAL ENVIRONMENTAL IMPACT REPORT
FOR THE
PURE WATER MONTEREY

GROUNDWATER REPLENISHMENT PROJECT
September 2015
Prepared for:
Monterey Regional Water Pollution Control Agency

in partnership with
Monterey Peninsula Water Management District
Prepared by:
Denise Duffy & Associates, Inc.

Environmental Consultants Resource Planners
947 Cass Street, Suite 5
Monterey, CA 93940
(831) 373-4341
FINAL
ENVIRONMENTAL IMPACT REPORT
for the
Pure Water Monterey Groundwater

Replenishment Project
September 25, 2015

(SCH#2013051094)
Prepared for:
MONTEREY REGIONAL WATER POLLUTION CONTROL AGENCY
in partnership with:
Prepared by:
DENISE DUFFY & ASSOCIATES, INC.
Monterey, CA 93940
TABLE OF CONTENTS
Chapter 1.
1.1.
1.2.
1.3.
1.4.
1.5.
1.6.
Background ............................................................................................................................ 1-1

Project Overview ................................................................................................................... 1-1
Public Review of Draft EIR ................................................................................................... 1-3
Final EIR Certification ........................................................................................................... 1-4
Organization of the Final EIR ................................................................................................ 1-4
Master Response to Comments .............................................................................................. 1-5
Chapter 2.
2.1
2.2
3.11
3.12
Master Responses to Comments ................................................................................... 3-1
Master Response #1: Adequacy of Draft EIR ........................................................................ 3-2

Master Response #2: Substantial Evidence ........................................................................... 3-3
Master Response #3: Availability, Reliability, and Yield of Source Water Supplies ............ 3-4
Master Response #4: Reduction of Surface Water Flows ...................................................... 3-7
Master Response #5: Fisheries By-Pass Analysis................................................................ 3-16
Master Response #6: Nutrients in Recycled Water and Ocean Outfall Discharges............. 3-20
Master Response #7: Development/Construction Water Use and Discharge ...................... 3-28
Master Response #8: Well Maintenance & Back-flushing Water Amounts and Discharge 3-31
Master Response #9: Fort Ord Environmental Issues at the Injection Well Facilities......... 3-34
Master Response #10: Marina Coast Water District and City of Marina Water Supply
Issues .............................................................................................. 3-40
Master Response #11: Proposed Projects Relationship to the Monterey Peninsula Water
Supply Project ................................................................................ 3-45
Master Response #12: Adequacy of Scope and Range of Alternatives ............................... 3-48
Chapter 4.
4.1
4.2
List of Comments ........................................................................................................... 2-1
Introduction ............................................................................................................................ 2-1

List of Comments ................................................................................................................... 2-1
Chapter 3.
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
Introduction to the Final EIR ....................................................................................... 1-1
Comments and Responses on the Draft EIR ............................................................... 4-1
Introduction ............................................................................................................................ 4-1

Comment Letters and Responses to Comments ..................................................................... 4-1
Chapter 5.
Changes to the Draft EIR .............................................................................................. 5-1
Changes to Executive Summary

Changes to Chapter 1, Introduction ....................................................................................... 5-1
Changes to Chapter 2, Project Description ............................................................................ 5-2
Changes to Chapter 3, Water Quality, Statutory and Regulatory Compliance Overview ... 5-13
Changes to Chapter 4, Environmental Setting, Impacts, and Mitigation Measures............. 5-14
Changes to Chapter 5, Growth and Irreversible Commitment of Resources ....................... 5-72
Changes to Chapter 6, Alternatives to the Proposed Project ............................................... 5-73
Changes to Chapter 7, List of Preparers .............................................................................. 5-74
Changes to the Appendices .................................................................................................. 5-75
Chapter 6.
References and Persons Contacted............................................................................... 6-1
6.1
Sources Cited ......................................................................................................................... 6-1
6.2
Persons Contacted .................................................................................................................. 6-6
Pure Water Monterey GWR Project
Final EIR
September 2015
Table of Contents
Chapter 7.
Report Preparation ........................................................................................................ 7-1
7.1
Lead Agency .......................................................................................................................... 7-1
7.2
Partner Agency....................................................................................................................... 7-1
7.3
EIR Consultants ..................................................................................................................... 7-1
7.4
Lead and Partner Agency Consultant Team........................................................................... 7-2
APPENDICES
B-Revised
C-Revised
AA
BB
CC
DD
EE
Proposed Source Water Availability, Yield, and Use

Amended Water Rights Analysis
Salinity Impacts to Elkhorn Slough Resulting from Surface Water Diversion
for the Pure Water Monterey Groundwater Replenishment Project
Future RUWAP Urban Recycled Water Irrigation Water Use and
Implications for CSIP Yields
Fish Passage Analysis, Reclamation Ditch at San Jon Road and Gabilan
Creek at Laurel Road
Consideration of Water Right Application 32263 in the Pure Water
Monterey Project EIR
Resumes and Qualifications from Key EIR Contributors

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September 2015
Table of Contents
LIST OF FIGURES
Figure 3-A. Agricultural Wash Water Projection .......................................................................3-5
Figure 4-A. Elkhorn Slough Salinity Measurements at LOBO Sampling site L01 ................4-81
Figure 2-3 rev. Seaside Groundwater Basin Boundaries ........................................................5-105
Figure 2-4 rev. Seaside Groundwater Basin Groundwater Levels ........................................5-106
Figure 2-7 rev. Salinas Valley Groundwater Basin Seawater Intrusion ...............................5-107
Figure 2-7a new. Salinas Valley Groundwater Levels and Flow Directions .........................5-108
Figure 2-16 rev. Blanco Drain Storm Maintenance District...................................................5-109
Figure 2-32a rev. Injection Well Site Plan ..............................................................................5-111
Figure 4.1-1 rev. Cumulative Projects Location Map .............................................................5-112
Figure 4.5-3 new. Surface Water Features in Northern Salinas Valley Tributary to Lower
Elkhorn Slough ..............................................................................................................5-113
Figure 4.10-5 rev. Seaside Groundwater Basin .......................................................................5-114
Figure 4.10-7 rev. Proposed Injection Wells and Existing Vicinity Wells .............................5-115
Figure 4.10-9a new. Detailed Map of CSIP Area Wells and System Components ...............5-116
Figure 4.18-1 rev. Marina Coast Water District Boundaries and Service Areas .................5-117
LIST OF TABLES
Table 2-A. List of Comments.........................................................................................................2-1
Table 3-A. Salinas River Lagoon Stage (feet) ............................................................................3-12
Table 3-B. Plant Food Utilization by Various Crops ................................................................3-24
Table 3-C. Fraction of Nitrogen Provided by Recycled Water During a Growing Season ...3-25
Table 3-D. Estimated Annual Recycled Water Yields Under Various Scenarios of MCWD
Demand and Pipelines ...........................................................................................................3-44
Table S-1Revised. Summary of Project-Level Impacts and Mitigation Measures ...................5-5
Table 4.4-10 Revised. Predicted Changes to Steelhead Passage Flow Thresholds in the Salinas
River (Scenario C)..................................................................................................................5-49
Table 4.5-11a. Salinas River Lagoon Stage (feet) ......................................................................5-59
Table 4.10-9 Revised. Seaside Basin Water Balance .................................................................5-67

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CHAPTER 1
1.1
INTRODUCTION TO THE FINAL EIR
BACKGROUND
In April 2015, the Monterey Regional Water Pollution Control Agency (MRWPCA), as Lead Agency,
circulated a Draft Environmental Impact Report (Draft EIR or DEIR) prepared under the California
Environmental Quality Act (CEQA), Public Resources Code 21000 et seq. The Draft EIR was prepared
to provide the public and responsible and trustee agencies with information on the potential
environmental effects of implementation of the Pure Water Monterey Groundwater Replenishment Project
(Proposed Project or GWR Project). The Draft EIR was circulated for a 45-day public review period,
between April 22 and June 5, 2015.
As Lead Agency, MRWPCA has prepared this document pursuant to CEQA Guidelines Section 15132
which specifies the following requirements for a Final EIR:
The Final EIR shall consist of:
a) The Draft EIR or a revision of the draft.
b) Comments and recommendations received on the Draft EIR either verbatim or in
summary.
c) A list of persons, organizations, and public agencies commenting on the Draft EIR.
d) The responses of the Lead Agency to significant environmental points raised in the
review and consultation process.
e) Any other information added by the Lead Agency.
This Final EIR contains a list of the comments submitted on the Draft EIR, copies of the comment letters
received on the Draft EIR during the public review period, responses to the environmental points raised in
those comments, and revisions to the Draft EIR made as a result of the public review process. This
document, together with the Draft EIR, constitute the Final Environmental Impact Report for the Pure
Water Monterey Groundwater Replenishment Project.
1.2
PROJECT OVERVIEW
The Proposed Pure Water Monterey Groundwater Replenishment Project is a water supply project that
would serve northern Monterey County. The Proposed Project would provide: 1) purified recycled water
for recharge of a groundwater basin that serves as drinking water supply; and 2) recycled water to
augment the existing Castroville Seawater Intrusion Projects agricultural irrigation supply.
Replenishment of the Seaside Groundwater Basin. The project would enable California
American Water Company (CalAm) to reduce its diversions from the Carmel River
system by up to 3,500 acre-feet per year by injecting the same amount of purified
recycled water into the Seaside Basin. The purified recycled water would be produced at
a new facility at the MRWPCA Regional Wastewater Treatment Plant (Regional
Treatment Plant) and would be conveyed to and injected into the Seaside Groundwater
Basin via a new pipeline and new well facilities. The injected water would then mix with
the existing groundwater and be stored for future urban use by CalAm, thus enabling a
reduction in Carmel River system diversions by the same amount.
Additional recycled water for agricultural irrigation in northern Salinas Valley. An existing
water recycling facility at the Regional Treatment Plant (the Salinas Valley Reclamation
Plant) would be provided additional source waters in order to provide additional recycled

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September 2015
Chapter 1. Introduction to the Final EIR
water for use in the Castroville Seawater Intrusion Projects agricultural irrigation system.
It is anticipated that in normal and wet years approximately 4,500 to 4,750 acre-feet per
year of additional recycled water supply could be created for agricultural irrigation
purposes. In drought conditions, the Proposed Project could provide up to 5,900 acre feet
per year for crop irrigation.
The Proposed Project would also include a drought reserve component to support use of the new supply
for crop irrigation during dry years. The project would provide an additional 200 acre-feet per year of
purified recycled water that would be injected in the Seaside Basin in wet and normal years for up to five
consecutive years. This would result in a banked drought reserve totaling up to 1,000 acre feet. During
dry years, the project would provide less than 3,500 acre feet of water to the Seaside Basin; however,
CalAm would be able to extract the banked water to make up the difference to its supplies, such that its
extractions and deliveries would not fall below 3,500 acre-feet per year. The source waters that are not
sent to the advanced treatment facility during dry years would be sent to the Salinas Valley Reclamation
Plant to increase supplies for the Castroville Seawater Intrusion Project.
The Proposed Project components include: conveyance of five potential types of source water to the
Regional Treatment Plant for treatment; a new Advanced Water Treatment (AWT) Facility and other
improvements to the Regional Treatment Plant; treated water conveyance system, including pipelines
and booster pump stations; groundwater injection wells; and potable water distribution system
improvements. Construction of the project is anticipated to require approximately 18 months, plus three
months of testing and start-up. MRWPCA is evaluating the use of alternative construction approaches,
such as design-build, to expedite the construction schedule.
The new source waters would supplement the existing incoming wastewater flows, and would include the
following: 1) water from the City of Salinas agricultural wash water system, 2) stormwater flows from the
southern part of Salinas and the Lake El Estero facility in Monterey, 3) surface water and agricultural tile
drain water that is captured in the Reclamation Ditch and Tembladero Slough, and 4) surface water and
agricultural tile drain water that flows in the Blanco Drain. Most of these new source waters would be
combined within the existing wastewater collection system before arriving at the Regional Treatment
Plant; water from Blanco Drain would be conveyed directly to the Regional Treatment Plant.
The Proposed Project would require modifications to existing facilities and construction of new physical
facilities, briefly listed below.
Source water diversion and storage. New facilities would be required to divert and convey
the new source waters through the existing municipal wastewater collection system and
to the Regional Treatment Plant.
Treatment facilities at the Regional Treatment Plant. A new advanced water treatment
facility would be constructed at the Regional Treatment Plant site. This facility would
include a state-of-the-art treatment system that uses multiple membrane barriers to purify
the water, product water stabilization to prevent pipe corrosion due to water purity, a
pump station, and a brine and wastewater mixing facility. There would also be
modifications to the existing Salinas Valley Reclamation Plant to optimize and enhance
the delivery of recycled water to growers.
Product water conveyance. A new pipeline, a pump station and appurtenant facilities
would be constructed to transport the purified recycled (product) water from the Regional
Treatment Plant to the Seaside Groundwater Basin for injection.
Injection well facilities. The injection facilities would include new wells (in the shallow and
deep aquifers), back-flush facilities, pipelines, electricity/power distribution facilities, and
electrical/motor control buildings.
Distribution of groundwater from Seaside Basin. CalAm water distribution system

improvements would be needed to deliver the extracted groundwater to CalAm
customers.

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September 2015
1.3
PUBLIC REVIEW OF DRAFT EIR
CEQA Guidelines Section 15087(a) requires that a Notice of Availability (NOA) of a Draft EIR be mailed to
the last known name and address of all organizations and individuals who have previously requested
such notice in writing. Section 15087(a) also requires that in addition to the above notifications, at least
one of the following procedures be implemented:
Publication at least one time by the public agency in a newspaper of general circulation in
the area affected by the proposed Project;
Posting of notice by the public agency on and off the site in the area where the Project is to
be located; or
Direct mailing to the owners and occupants of property contiguous to the parcel or parcels
on which the Project is located.
Section 15087(d) requires the NOA be posted for at least 30 days in the office of the county clerk of each
county in which the project will be located. Section 15087(f) requires that an NOA be sent to state
agencies through the State Clearinghouse. Section 15087(g) states that lead agencies should place
copies of the Draft EIR in public libraries. The method by which these requirements were satisfied is
provided below:
On April 21, 2015, the NOA and Notice of Completion were sent to the State
Clearinghouse/Governors Office of Planning and Research, along with electronic copies
of the Draft EIR. In addition, MRWPCA distributed the NOA for the Draft EIR to
approximately 800 interested responsible and trustee agencies, interested groups,
organizations, and individuals. The distribution list included all parties that commented on
the Notice of Preparation (NOP) and all parties that contacted MRWPCA requesting to be
notified about the project.
The NOA was published in two newspapers, the Monterey County Herald and the Salinas
Californian, on April 23, 2015.
A hard copy of the Draft EIR was made available for review during normal business hours
at the MRWPCA Administrative Office, 5 Harris Court, Bldg. D, Monterey, CA 93940 and
at the MPWMD Offices, 5 Harris Court, Bldg. G, Monterey, CA 93940. The Draft EIR was
available online at the GWR Project website at: www.purewatermonterey.org. The Draft
EIR was also available at the following libraries: Seaside Public Library, Marina Public
Library, Salinas Public Libraries, Castroville Public Library, Monterey Public Library,
Carmel Valley Public Library, and Harrison Memorial Library (Carmel).
On April 22, 2015, MRWPCA posted the NOA at the following locations: the Regional
Treatment Plant, the MRWPCA and MPWMD offices, and near the Injection Well
Facilities site at the corner of General Jim Moore Boulevard and Eucalyptus Avenue.
MRWPCA held two public meetings during the Draft EIR review period to inform the public of the content
of the Draft EIR and CEQA process and to provide an opportunity for the public to ask questions and to
submit comments. The first meeting was held on May 20, 2015 from 6:00 p.m. to 8:00 p.m. at the
Oldemeyer Center (986 Hilby Avenue, Seaside, CA 93955). The second meeting was held on May 21,
2015 from 4:00 p.m. to 6:00 p.m. at Hartnell College, Room B-208 of the Student Services Building (411
Central Avenue, Salinas, CA 93901). Spanish translation was available, and both venues were accessible
under the Americans with Disabilities (ADA). The NOA (described above) contained information about the
meetings.

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September 2015
1.4
FINAL EIR CERTIFICATION
The MRWPCA Board of Directors will review and consider the Final EIR prior to taking an action on the
Proposed Project. The Final EIR will be made available to agencies who provided comments on the Draft
EIR a minimum of ten days prior to the Boards consideration of the Final EIR. If the Board finds that the
Final EIR reflects the MRWPCAs independent judgment and has been prepared in accordance with
CEQA and the CEQA Guidelines, the MRWPCA will certify the adequacy and completeness of the Final
EIR. A decision to approve the project would be accompanied by written findings prepared in accordance
with CEQA Guidelines Section 15091, and if applicable, Section 15093. For each significant effect
identified in the Final EIR, the findings will describe whether the effect can be reduced to a less-thansignificant level through feasible mitigation measures.
If in approving the Proposed Project, the MRWPCA adopts mitigation measures to reduce significant
effects, it also will adopt a Mitigation Monitoring and Reporting Program (MMRP), as required by Section
15097 of the CEQA Guidelines. The MMRP describes how each of the mitigation measures will be
implemented and provides a mechanism for monitoring and/or reporting on their implementation. If the
MRWPCA approves the Proposed Project or an alternative with associated significant effects on the
environment that cannot be feasibly avoided or reduced to less-than-significant levels, the MRWPCA
must also adopt a Statement of Overriding Consideration that explains how the benefits of the project
outweigh the significant unavoidable environmental effects, in accordance with Section 15093 of the
CEQA Guidelines.
1.5
ORGANIZATION OF THE FINAL EIR
This Final EIR is organized into the following sections:
Chapter 1.0, Introduction to the Final EIR, contains this introduction to the Final EIR,
including a discussion of the background of the environmental review, a description of the
contents of the Final EIR, a summary of the project decision-making process, and an
introduction to the master responses.
Chapter 2.0, List of Comments, contains a list of all written comments received on the
Draft EIR.
Chapter 3.0, Master Responses to Comments, contains master responses to common

topics raised by the commenters.
Chapter 4.0, Comments and Responses on the Draft EIR contains copies of all
comment documents received on the Draft EIR, and responses to each identified
comment within the comment documents.
Chapter 5.0, Changes to the Draft EIR, contains revisions to the text of the Draft EIR
made in response to the public review process.
Chapter 6.0, References and Persons Contacted, contains a list of sources cited for
the Final EIR and persons contacted.
Chapter 7.0, Report Preparers, contains a list of agencies and consultants and their
staff that assisted with preparation of this Final EIR.
Appendices, including the following:

The following appendices from the Draft EIR have been revised and replaced in this Final EIR:
Appendix B-Revised
Appendix C-Revised
The following new appendices have been added in this Final EIR:

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September 2015
1.6
Appendix AA
Salinity Impacts to Elkhorn Slough resulting from Surface Water Diversions

for the Pure Water Monterey Groundwater Replenishment Project
Appendix BB
Future RUWAP Urban Recycled Water Irrigation Water Use and Implications
for CSIP Yields
Appendix CC
Fish Passage Analysis, Reclamation Ditch at San Jon Road and Gabilan
Creek at Laurel Road
Appendix DD
Consideration of Water Right Application 32263 in the Pure Water Monterey

Project EIR
Appendix EE
Resumes and Qualifications from Key EIR Technical Contributors
MASTER RESPONSE TO COMMENTS
Chapter 3 of this document contains master responses that address some common topics raised by the
commenters. The intent of a master response is to provide a comprehensive response to an issue so that
multiple aspects of the issue can be addressed in a coordinated, organized manner in one location. This
ensures that each topic is thoroughly addressed and reduces repetition of responses. Responses to
individual comments cross-reference the appropriate master response when the comment is pertinent to
the master response.

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CHAPTER 2
2.1
LIST OF COMMENTS
INTRODUCTION
This section provides the list of comments on the Draft EIR in accordance with CEQA Guidelines Section
15088. A total of 26 comment letters were received on the Draft EIR during the 45-day public review
period, including two comment cards that were received at the May 20, 2015 public meeting (these
comments are identified by an asterisk * in the list below). Three additional letters from agencies were
received after the close of the 45-day review period and are also included on the list and responded to in
this Final EIR.
2.2
LIST OF COMMENTS
Table 2-A, below, identifies the comment letters received on the Draft EIR for the Proposed Project. Each
of the comment letters has been assigned a letter designation or identifier (ID); this letter designation
corresponds to the organization of Chapter 4 of the Final EIR, which includes copies of the comments
and responses to identified comments.
Table 2-A
List of Comments
Comment
Letter ID
Agency/Organization (if applicable)
Date
Written
Author
Federal and State Agencies

A
California Office of Planning and Research
6/8/2015
Scott Morgan
California Department of Transportation
5/20/2015
John J. Olejnik
State Water Resources Control Board
6/4/2015
Justine Herrig
California State Lands Commission
6/5/2015
Cy R. Oggins
National Oceanic and Atmospheric Administration National Marine

Fisheries Service
6/3/2015
Alecia Van Atta
Central Coast Regional Water Quality Control Board
6/5/2015
Kenneth A. Harris
Jr.
California Department of Fish and Wildlife
6/5/2015
Gerald Hatler
Regional and Local Agencies

H
Marina Coast Water District
6/4/2015
Howard Gustafson
6/4/2015
David J. Stoldt
City of Marina
6/5/2015
Layne Long
K*
City of Marina
5/20/2015
Farhad Montazavi
City of Seaside
6/5/2015
Diana Ingersoll
Monterey County Water Resources Agency
6/5/2015
Robert Johnson

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Chapter 2. List of Comments
Table 2-A
List of Comments
Comment
Letter ID
Agency/Organization (if applicable)
Date
Written
Author
Seaside Basin Watermaster
6/4/2015
Dewey D. Evans
City of Salinas
6/1/2015
Gary E. Petersen
City of Monterey
6/2/2015
Clyde Roberson
Organizations and Individuals

Q
California American Water Company
6/5/2015
Ian Crooks
LandWatch Monterey County
5/20/2015
Amy L. White
Monterey County Farm Bureau
6/1/2015
Norman C. Groot
Salinas Valley Water Coalition
6/1/2015
Nancy Isakson
Water Ratepayers Association of the Monterey Peninsula
6/2/2015
Ron Weitzman
Surfrider Foundation
6/5/2015
Staley Prom
Fort Ord Community Advisory Group
6/5/2015
Mike Weaver
The Otter Project
6/5/2015
Steve Shimek
Individual
4/28/2015
Michelle Long
Z*
Individual
5/20/2015
Peter B. Kaiser
Comments Received After the Close of the Public Review Period

AA
California Coastal Commission
6/8/2015
Mike Watson
BB
California Office of Planning and Research
6/26/2015
Scott Morgan
CC
6/22/2015
Susan L. Stewart
* = These comments were in the form of comment cards that were received at the May 20, 2015 public meeting.

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CHAPTER 3
MASTER RESPONSES TO COMMENTS
The master responses in this chapter address comments related to topics that are common to several
comment letters. The intent of a master response is to provide a comprehensive response to a topic in a
coordinated, organized manner in one location that clarifies and elaborates on the analysis in the Draft
EIR. The following master responses are included in this chapter (listed by section number):
3.1
Master Response #1:
Adequacy of the Draft EIR
3.2
Master Response #2:
Substantial Evidence
3.3
Master Response #3:
Availability, Reliability, and Yield of Source Water Supplies
3.4
Master Response #4:
Reduction of Surface Water Flows
3.5
Master Response #5:
Fisheries Impact Analyses
3.6
Master Response #6:
Nutrients in Recycled Water and Ocean Outfall Discharges
3.7
Master Response #7:
Well Development/Construction Water Use and Discharge
3.8
Master Response #8:
Well Maintenance and Back-flushing Water Amounts and Discharge
3.9
Master Response #9:
Fort Ord Environmental Issues at the Injection Well Facilities
3.10
Master Response #10:
Marina Coast Water District and City of Marina Water Supply Issues
3.11
Proposed Projects Relationship to the Proposed Monterey Peninsula

Water Supply Project
3.12
Adequacy of Scope and Range of Alternatives

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Chapter 3. Master Responses to Comments on the Draft EIR
3.1
MASTER RESPONSE #1: ADEQUACY OF THE DRAFT EIR
This master response addresses comments that relate to adequacy and recirculation of the Draft EIR,
including the following: G-3 and G-4.
3.1.1
Adequacy of the Draft EIR
The Draft EIR has been prepared with sufficient analysis to provide decision makers with information to
enable them to make a decision on project approval that takes into account environmental consequences.
CEQA Guidelines Section 15151 says that [a]n evaluation of the environmental effects of a proposed
project need not be exhaustive, but [rather] the sufficiency of an EIR is to be reviewed in the light of what
is reasonably feasible.
3.1.2
Recirculation
CEQA and the CEQA Guidelines provide that a Draft EIR needs to be recirculated only if significant new
information is added to an EIR after notice of public review has been given, but before certification of the
Final EIR. (Pub. Res. Code, Section 21092.1; CEQA Guidelines Section 15088.5; Vineyard Area Citizens
for Resp. Growth Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412,447.) The critical issue in this
inquiry is whether any new information added is "significant"; if so, recirculation is required. (Pub. Res.
Code, Section 21092.1). CEQA Guidelines, Section 15088.5(a) states "new information added to an EIR
is not 'significant' unless the EIR is changed in a way that deprives the public of a meaningful opportunity
to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or
avoid such an effect (including a feasible project alternative) that the project's proponents have declined
to implement."
In four situations, recirculation is required:
a) A new significant environmental impact would result from the project or from a new mitigation
measure proposed to be implemented.
b) A substantial increase in the severity of an environmental impact would result unless
mitigation measures are adopted that reduce the impact to a level of less than significant.
c) A feasible project alternative or mitigation measure considerably different from others
previously analyzed would clearly lessen the environmental impacts of the project, but the
project's proponents decline to adopt it.
d) The Draft EIR was so fundamentally and basically inadequate and conclusory in nature that
meaningful public review and comment were precluded.
Responses to comments provided in this document address significant environmental issues raised by
commenting public agencies, organizations and individuals. New information provided in response to
comments on the Draft EIR contained in this document clarifies or amplifies information in the Draft EIR.
The new information does not reveal that the project would cause new significant impacts not previously
identified in the Draft EIR, or a substantial increase in the severity of impacts identified in the Draft EIR.
Also, no significant new information has been added that changes the EIR in a way that deprives the
public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the
project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that
the projects proponents have declined to implement.
The information added to the EIR supports the existing analysis and conclusions, and clarifies information
in response to the comments on the Draft EIR (see Chapter 5, Changes to the Draft EIR, of this Final
EIR). Modifications to the Draft EIR as presented in Chapter 5, Changes to the Draft EIR and responses
in this Final EIR do not constitute significant new information as defined in Section 15088.5 of the CEQA
Guidelines.
Therefore, in accordance with CEQA Guidelines Section 15088.5 (b), no recirculation of the Draft EIR is
required.

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3.2
MASTER RESPONSE #2: SUBSTANTIAL EVIDENCE
This master response provides general information regarding the definition of substantial evidence to
aid the reader.
CEQA Guidelines Section 15384 states: (a) Substantial evidence as used in these guidelines means
enough relevant information and reasonable inferences from this information that a fair argument can be
made to support a conclusion, even though other conclusions might also be reached. . (b) Substantial
evidence shall include facts, reasonable assumptions predicated upon facts, and expert opinion
supported by facts. Argument, speculation, unsubstantiated opinion or narrative, evidence which is clearly
inaccurate or erroneous, or evidence of social or economic impacts which do not contribute to, or are not
caused by, physical impacts on the environment, is not substantial evidence."
While the CEQA lead agencys decisions regarding the significance of environmental effects addressed in
an EIR must be based on substantial evidence, the CEQA Guidelines recognize that other evidence
suggesting a different conclusion may exist. The Draft EIR and this Final EIR present substantial
evidence to support the conclusions drawn within these documents regarding the significance of the
projects environmental effects. When a point of evidence is provided by a commenter to support a
disagreement with the EIRs conclusion, the evidence is summarized and considered in reaching the
EIRs conclusion. This Final EIR including the master responses, additional or supplements to technical
reports presented and individual responses, are also provided to substantiate the conclusions reached in
the Draft EIR regarding significance of impacts. The MRWPCA, as lead agency, will ultimately determine
which conclusion is appropriate, based on the substantial evidence presented in the EIR and other
documents in the whole of the record. The lead agency will review and consider all the substantial
evidence in the whole of the record in making its decisions about the project and its environmental
effects.

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3-3
September 2015
3.3
MASTER RESPONSE #3: AVAILABILITY, RELIABILITY, AND

YIELD OF SOURCE WATER SUPPLIES
This master response addresses comments related to source water availability for the Proposed Project,
including the following: C-5, H-51, H-65, Q-2, S-3 to S-12, and S-15, T-4 or T-9, T-12 and U-6. This
response is organized by subtopics within this larger topic. Several of the supporting technical reports
have been updated to prepare this response, and are noted in the text.
3.3.1
Existing Use of Recycled Water in Castroville Seawater

Intrusion Project Area
Several comments (S-5, S-6, S-9, T-4, T-5, and T-6) asked that the EIR provide a better description of the
existing use of recycled water for the Castroville Seawater Intrusion Project (CSIP) and/or how that use
would be maintained or altered. Municipal wastewater treated at the MRWPCA Regional Treatment Plant
(RTP) is used as influent to the Salinas Valley Reclamation Plant (SVRP), which produces recycled water
for the CSIP. Treated wastewater which is not used to produce recycled water is discharged to the ocean.
During the period 2009-2013, an average of 21,764 acre feet per year (AFY) of wastewater was received
at the RTP, 12,955 AFY was recycled at the SVRP, and 8,809 AFY was discharged to the ocean
(monthly averages are tabulated in Appendix B-Revised). In the Draft EIR Chapter 2, Project
Description, Table 2-12, and in the supporting technical reports, including Draft EIR Appendix B, the
average monthly flows discharged through the ocean outfall during the period of 2009 through 2013 (last
line of Table 1) were included as potentially available to use as source water for the Proposed Project, but
the data and analysis about historic and future recycled water use by CSIP of the existing municipal
wastewater inflows were omitted. The discussion in Appendix B-Revised has been expanded to
describe all of the wastewater flows into the MRWPCAs RTP and the past and assumed future SVRP
production of recycled water for CSIP. These updates do not affect the conclusions in the Draft EIR
regarding the significant effects of the Proposed Project and the alternatives. See Appendix B-Revised
in this Final EIR. Tables 7 through 10 of Appendix B-Revised show that the use of recycled water by
CSIP would be maintained and increased by the Proposed Project.
3.3.2
Agricultural Wash Water Yield Projection
Comments Q-2 and S-4 on the Draft EIR questioned the estimation of agricultural wash water availability.
The City of Salinas owns and operates an industrial wastewater collection and treatment system, which
serves approximately 25 agricultural processing and related businesses located in the southeast corner of
the City. These flows, referred to as agricultural wash water, are conveyed in a network of gravity
pipelines to the Salinas Treatment Facility. The facility has operated for over 50 years. To estimate the
flow in the estimated year of project implementation (2017), recorded monthly inflows for calendar years
2007-2013 were tabulated and the annual averages plotted (see Figure 3-A, below). A linear trend line
was used to estimate future flows, and the projected annual average of 3.37 million gallons per day (mgd)
in 2017 was used in the project analysis. Actual recorded agricultural wash water flows in calendar year
2014 (included on Figure 3-A, below) fell on the trend line, which provides support for the estimation
used in the Draft EIR. An expanded explanation of this estimation method has been added to Appendix
B-Revised to the Draft EIR. It also bears noting that agricultural wash water flows processed at the
Salinas Treatment Facility peak in the summer months when much of the produce is harvested and
processed; therefore, the amount of water available from this source is highest during the summer
months, corresponding to the time period when irrigation demands are highest.

Final EIR
3-4
September 2015
Ag Wash Water (avg mgd)
SIWTF Inflows
4.00
3.50
3.00
2.50
2.00
1.50
1.00
2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
Year
Recorded Inflows
Flow in 2014
Projected Flow in 2017
Figure 3-A. Agricultural Wash Water Projection
3.3.3
Reliability of Source Water Supplies
Several comments (S-4, S-5, S-6, S-7, S-8, S-12, T-4 and T-6) suggest that the proposed surface water
diversions should not be relied upon as sources for municipal water supply because the availability of
those sources may fluctuate over time. One comment (S-4) added that agricultural wash water should
also be considered interruptible, although the recent data (presented in Section 3.3.2 above) show those
flows to be increasing and no data or analyses have been presented to indicate that those flows would
cease or decrease in the future.
To accomplish the project objectives, the component of the Proposed Project that is designed to replenish
the Seaside Groundwater Basin (the GWR Facilities) requires 4,320 AFY of influent supply to produce
3,500 AFY of advanced treated recycled water for indirect potable reuse (municipal supply), representing
an average in-flow rate of 6 cubic feet per second (cfs). The Proposed Project would develop
infrastructure to divert and transport multiple water sources to the RTP and Advanced Water Treatment
(AWT) Facility, with the potential for the AWT to process inflows up to 14 cfs during peak months. This
processing capability ensures that sufficient amounts of purified recycled water will be produced for
injection into the Seaside Groundwater Basin, despite the annual and seasonal variability in the
availability of source waters.
Those source water flows that are not required for treatment at the AWT Facility and injection into the
Seaside Groundwater Basin would be routed to the Salinas Valley Reclamation Plant for tertiary
treatment and use as recycled water provided to growers in the CSIP area.
The Proposed Project would not need the full amount of water available from the proposed source water
diversions to meet the AWT influent and CSIP demands, therefore, it is assumed one or more source
waters would not be diverted when water from that source is not needed. As discussed in the Draft EIR
pages 2-40 through 2-42, MRWPCA proposes to divert Tembladero Slough only as needed (that is, the
source that is used least frequently) due its limited yield and high salinity.
During the peak irrigation demand period of April to September, the primary source of supply for the
Proposed Project would be agricultural wash water. The projected yield from this source would be 7.2 cfs
including the recovery of stored winter flows at the Salinas Treatment Facility for summer use (as
described in the Draft EIR Project Description on page 2-45, in Appendix O and shown in Appendix B,
Tables 7 through 10). Surface water diversions would provide redundancy and additional flows:
Final EIR
3-5
September 2015
Reclamation Ditch would provide an average of 2 cfs, the Blanco Drain would provide an average of 4.6
cfs, and the Tembladero Slough would provide an average of 1 cfs. All of these summer surface water
flows are primarily agricultural return flows, which are considered to be as reliable as the CSIP irrigation
demand. Increases in CSIP irrigation directly results in increases in agricultural return flows.
During October to March, the primary source of supply for the Proposed Project would be the excess
secondary treated municipal effluent that is not used by the CSIP. Based on measured historic monthly
records of SVRP recycled water produced and the amount of water discharged to the ocean outfall
(average of the data for the years 2009 through 2013), there is substantial flow available beyond CSIP
demands. In an average year, there is sufficient unused municipal effluent in these months to supply the
AWT Facility, including the additional amounts needed to produce water for the drought reserve that is
part of the Proposed Project. The proposed surface water diversions also could provide up to 7 cfs of
source water during the wet season, but are expected to be used only during drought years to meet early
and late season irrigation demands.
The fact that a given source may be referred to as interruptible does not mean it is not reliable. Several
of the Proposed Project water sources may be interruptible in that MRWPCA would be able to reduce or
eliminate those flows when wastewater flows within its existing facilities approach capacity. These source
waters, including agricultural wash water, would be curtailed whenever too much water is available or
flowing in the wastewater collection system. The term interruptible does not imply that the water source
will sometimes not exist, but rather that sometimes there will be more than the amount needed by
recycled water users or more than can be accommodated by the existing and proposed collection and
treatment systems.
3.3.4
Drought Year vs. Average Year Conditions
One comment (S-8) asked about the effect of the current drought condition on source water supplies. The
current drought has curtailed precipitation-based surface water supplies and it has accelerated the
installation of water-conserving plumbing fixtures, reducing wastewater flows. However, based on the
best available scientific information, it will rain again and the region will experience a range of wet, normal
and dry years. The California Department of Water Resources (DWR) has published guidelines for use in
water planning documents (Urban Water Management Plans, Water Supply Assessments and Written
Verifications of Supply). The DWR requires planning studies to consider normal years, single-dry years
and multiple-dry years. The planning guidelines for Urban Water Management Plans define these years
as follows: Normal Years are the average or median condition for a period of record of at least 30 years;
Single-Dry Year is the driest year on record, which was 2013; and Multiple-Dry Years is the three year
period with the lowest average supply availability or rainfall. The drought of 1988-1990 is currently used
for multiple-dry year analysis. These designations would potentially be updated in the next Urban Water
Management Plan cycle to reflect more recent years, such as 2014 and 2015, as drier years.
The California State Water Resources Control Board (SWRCB) issues surface water rights and publishes
guidelines for surface and stormwater management. The SWRCB does not use the terms wet, normal
and dry consistently, but in the Salinas River watershed, the MCWRA water rights for San Antonio and
Nacimiento Reservoirs define wet years as the 75th percentile flows (exceeded only 25% of the time), dry
years as the 25th percentile flows (exceeded 75% of the time) and normal flows being the range between
wet and dry.
New development is occurring in portions of the project area, which will produce additional municipal
wastewater flows, albeit at lower per capita rates than in the past. Even if average precipitation declines
in the near or long term, the Proposed Project does not rely upon the use of stored surface water as
influent to the AWT Facility. The flows proposed to be captured are irrigation return flows and processing
water (agricultural wash water), both of which have continued to flow during the current drought and no
data or analysis presented demonstrate that those flows would cease or be measurably reduced in the
future. The Proposed Project includes the development of a drought reserve or water bank in the Seaside
Groundwater Basin that would accommodate reduced AWT Facility operation during drought periods.
Final EIR
3-6
September 2015
3.4
MASTER RESPONSE #4: REDUCTION OF SURFACE WATER

FLOWS
This master response addresses comments related to the Proposed Projects impacts on surface water
flows, water levels, water quality, and downstream beneficial uses, habitats, ecosystems, and other
biological resources, including the following:
Several comments (T-7, T-8, and T-9) asked if reducing inflows to the Salinas River would
impact the yield of the Salinas River Diversion Facility.
Several comments (C-5, E-2, E-4, E-5, E-7 to E-10, F-6, F-8, F-9, F-9a to f, G-2 to G-12, G13, S-8, V-5 V-10, X-6, and AA-8) asked if the individual and/or combined surface water and
other diversions would reduce flows or water levels (surface elevations), or harm water
quality in downstream water bodies resulting in effects on habitats, ecosystems, and/or
biological resources. Specific comments asked about impacts of diversions on the resources
within the Salinas River Lagoon, Old Salinas River, Tembladero Slough, Moro Cojo Slough,
and the Elkhorn Slough.
This master response was prepared with assistance from the hydrology and hydraulic engineering firm of
Schaaf & Wheeler Consulting Engineers whose qualifications are attached to this Final EIR as Appendix
EE.
3.4.1
Yield for the Salinas River Diversion Facility (SRDF)
Impacts to surface water hydrology in the water bodies affected by the Proposed Project diversions are
discussed in the Draft EIR in Section 4.11, Hydrology and Water Quality: Surface Water as amended in
this Final EIR (see Chapter 5, Changes to the Draft EIR). The Draft EIR provides a quantitative,
technical analysis of changes in flow quantities, relative flow quantities (by season), and water levels
within the downstream water bodies by affected reach for each water body due to the combined
maximum potential diversions from all proposed points of diversion associated with the Proposed Project.
The additional information in the Final EIR reinforces the assessments and conclusions in the Draft EIR.
See Appendices N, O-Revised, and Q-Revised, for additional detail on the results of the analyses of
existing and Proposed Project hydrology and water quality conditions of the Salinas River.
Some comments on the Draft EIR asked how Proposed Project diversions could affect the yield from the
Salinas River Diversion Facility (SRDF). As explained in Appendix O-Revised, MCWRAs water right for
the SRDF is not for run-of-river flows, but instead is a right to redivert flows first captured at Nacimiento
and San Antonio Reservoirs. Flows are released from the reservoirs, conveyed using the bed and banks
of the Nacimiento, San Antonio and Salinas Rivers, and then rediverted at the SRDF north of Marina for
use in the CSIP irrigation system. Capturing flows that otherwise would enter the Salinas River below
Spreckels as source water for the Proposed Project (Salinas agricultural wash water, Salinas municipal
stormwater runoff, and Blanco Drain flows) would not affect the yield of the SRDF.
The SRDF water right does include requirements for minimum by-pass flows at the SRDF for habitat
maintenance in the Salinas River Lagoon (Lagoon) and for seasonal migratory fish passage. The Salinas
River Inflow Impacts Report (Appendix O-Revised) analyzed the potential impacts of the Proposed
Projects diversions on achieving these required by-pass flows, as discussed below.
The bypass flow analysis assumed the extreme case of full diversion of agricultural wash water plus full
diversion of flows from the Blanco Drain and Salinas stormwater runoff. Agricultural wash water treated at
the Salinas Treatment Facility and discharged via percolation ponds, migrates into the Salinas River at an
estimated rate of 3 cfs when the ponds are holding water. Under the proposed seasonal storage and
diversion schedule, the Salinas ponds would contain water from October through June and continue to
Final EIR
3-7
September 2015
provide seepage flows to the river during those months. The months when seepage from the ponds would
be eliminated due to Proposed Project diversions are July, August and September, which are outside the
adult and juvenile fish migration windows and are the months within which the minimal SRDF bypass
requirement of 2 cfs is required by National Oceanic and Atmospheric Administration (NOAA) National
Marine Fisheries Service (NMFS). Metered releases during July through September typically exceed 10
1
cfs , so this diversion will not affect the SRDF operation.
The Blanco Drain diversion may capture an average of 4.6 cfs, up to a peak rate of 6 cfs, so it has the
potential to affect the daily SRDF bypass releases, particularly in the spring months. The MCWRA and
project proponents would coordinate the operations of the Blanco Drain diversion and SRDF. The SRDF
diversion decisions are currently and would continue to be made depending upon the CSIP demand (i.e.,
if the SVRP storage pond is full, diversions would cease until the pond has capacity available). As such,
the two diversions will be operated by the MRWPCA and MCWRA as a single system and the Blanco
Drain diversion rate managed so it does not adversely affect the SRDF operation and CSIP growers.
3.4.2
Impacts to Downstream Water Resources due to Proposed

Source Water Diversions
3.4.2.1 Overview of Surface Waters in the Lower Salinas Valley

Figure 4.5-3new provides an overview of the surface water bodies and tidal and flood control facilities in
the lower Salinas Valley that are the subject of this Master Response. The Proposed Project would divert
water from two separate, but interconnected watersheds, the Salinas River and the Reclamation Ditch /
Tembladero Slough (the Reclamation Ditch is tributary to the Tembladero Slough). Commenters
requested information about impacts to water bodies downstream of these watersheds at the Salinas
2
River Lagoon, Old Salinas River Channel (OSR Channel), Elkhorn Slough, and Moro Cojo Slough.
During the dry season when the Lagoon is not open to the ocean, the Lagoon flows into the OSR
Channel. MCWRA controls the water surface elevations using a slide gate separating the Lagoon from
the OSR Channel on the northern side of the lagoon. The tidal influence of the ocean also exerts its
influence on water levels through surface / groundwater interaction. During and after large storm events
when the sand bar at the lagoon is naturally or artificially breached, the Lagoon flows directly into the
Monterey Bay. In addition to dry season flow from the Lagoon when the sand bar is present separating
the Lagoon from the ocean, the OSR Channel also receives inflow from local drainage areas (primarily,
surface runoff and tile drain water from agricultural land) and the Tembladero Slough before flowing into
Moss Landing Harbor and thence to the Elkhorn Slough and/or Monterey Bay. Because of the flat
topography in the OSR Channel, existing low dry season flows (such as those proposed for diversion) in
the OSR Channel water bodies result in consistently low velocity flows with ebbing and receding tidally
influenced flows within and between water bodies, such as the Tembladero Slough. The quantity of inland
surface water inflows might be expected to have effects on water surface elevations; however, in the
absence of precipitation, changes in inland surface flows have not been documented to effect water
levels (Casagrande and Watson, 2006, Nicol, et al, 2010, and Inman, et al, 2014). Instead, ocean tidal
cycles tend to dominate surface water elevation changes in the OSR Channel and lower Tembladero
Slough during periods with no precipitation.
MCWRA, Salinas Valley Water Project, Annual Flow Monitoring Reports for Water Years 2010, 2011, 2012, and
2013.
2
In this master response, the Old Salinas River Channel, or OSR Channel, is assumed to terminate at the Potrero
Tide Gate at its northern end. In some literature, maps, and studies the channel continues to be referenced as the
Old Salinas River between the Potrero Tide Gate and the Moss Landing Harbor, further to the north. The Potrero Tide
Gate causes a distinct hydrologic change between the portion north of and the portion south of the Potrero Tide Gate.
The hydrologic conditions in the portion of the channel north of the Potrero Tide Gate to the Moss Landing Harbor are
consistent with the Moss Landing Harbor; therefore, in this analysis, this northern portion of the OSR Channel is
described as part of the Moss Landing Harbor.
Final EIR
3-8
September 2015
Dry season water levels in the OSR Channel (Tembladero Slough to Moss Landing Harbor) and the lower
Tembladero Slough are controlled by the operation of the Potrero Tide Gate (that separates the OSR
Channel from Moss Landing Harbor) and the tidal influence. Water surface elevations rise with rising tides
and fall with receding tides (Nicole et al., 2010 and Inman, et al. 2014). See also Draft EIR pages 4.5-100
to 4.5-101. The OSR Channel receives some surface water flow from surrounding land runoff and
agricultural tile drainage; however, most of its inflows are from the Lagoon, the Harbor, and the
Tembladero Slough. Water levels in this channel may also be affected by subsurface (surface /
groundwater) interaction, in particular by the ocean, and potentially by saturated upper-soils in adjacent
agricultural land. During the dry season, inland surface water inflows are almost exclusively agricultural
irrigation runoff and tile drainage that are, by nature, unpredictable and high in pollutants. Agricultural
runoff/drainage can vary significantly day to day and by season based on agricultural irrigation schedules
of land within the watershed. Despite the variability of the surface flows throughout the dry season, the
lower watershed areas in the OSR Channel see extremely stable average water surface elevations
(beyond the tidal fluctuations) in times with no precipitation.
3.4.2.2 Relevant Draft EIR Contents

The Draft EIR analyzes operational impacts of the total, combined project-related reduced flows in the
waterbodies downstream of all of the proposed diversions (as detailed in the following paragraphs): (1)
the surface waters proposed for Salinas Valley area diversion (Reclamation Ditch, Tembladero Slough,
and Blanco Drain), (2) the City of Salinas storm water diversion, and (3) the wastewater diversions (i.e.,
the impacts of reducing the discharge of wastewater at the Salinas Treatment Facility). In response to
comments on the Draft EIR, this Master Response provides additional discussion of combined impacts
from all proposed diversions.
Surface Water Hydrology and Water Quality
Impacts to hydrology and water quality in water bodies downstream of the proposed diversions
are discussed in the Draft EIR, Section 4.11. Response to Comment G-3 in Chapter 4,
Comments and Responses on the Draft EIR, describes the Draft EIRs study areas for surface
3
water hydrology and water quality analyses. Draft EIR pages 4.11-64 through 4.11-75 present
the analysis of the Proposed Project impacts according to the significance criteria and approach
presented on pages 4.11-53 through 4.11-55. This section summarizes and expands upon the
technical analysis by Schaaf & Wheeler in Appendices N, O-Revised, P, Q-Revised, and R.
Water quality impacts resulting from the inter-related salinity and water level impacts during
source water diversion operations on downstream waterbodies are analyzed in the Draft EIR on
pages 4.11-71 through 4.11-72 and the Draft EIR determined that the Proposed Project (including
all diversions) would have a less than significant impact on water quality. This conclusion is
supported by additional information provided in Section 3.4.2.3 below. Draft EIR pages 4.11-72
through 4.11-74 analyze the potential for erosion and sedimentation due to rapid water level
fluctuations adjacent to diversion facilities. The potential for channel bank failure due to the
Reclamation Ditch diversion was found to be potentially significant and mitigation measure HS-4
(as amended in this Final EIR, see Chapter 5, Changes to the Draft EIR) is required to reduce
the impact to a less-than-significant level.
Fisheries
Impacts to fisheries in the water bodies affected by the diversions are discussed in the Draft EIR
in Section 4.4, Biological Resources: Fisheries, as amended in this Final EIR (see Chapter 5,
Changes to the Draft EIR). The Draft EIR fisheries setting section on pages 4.4-9 to 4.4-18
describes the habitat in the lower Salinas River watershed where the Salinas River Lagoon
periodically drains into the Old Salinas River, and the connection with the Reclamation Ditch
3
The surface water bodies at, and downstream of, the diversions (i.e., the project study area for the Hydrology and
Water Quality analysis in Draft EIR Section 4.11) include: Salinas River (from just east of the Davis Road bridge to
the Lagoon), Salinas River Lagoon, Old Salinas River, Reclamation Ditch, Tembladero Slough, Moss Landing
Harbor, Elkhorn Slough, and Monterey Bay/Pacific Ocean, as identified on page 4.11-1 of the Draft EIR.

Final EIR
3-9
September 2015
watershed which ultimately drains into Moss Landing Harbor. Draft EIR Figure 4.4-3 illustrates
these watershed connections and Table 4.4-3, Fish Species Observed in Salinas River Lagoon
(2002-2013) describes habitat in the areas downstream of the Proposed Project diversions.
Specifically, Response to Comment G-3 in Chapter 4, Comments and Responses on the Draft
EIR, describes the Draft EIRs study areas for biological resource - fisheries. Impact analyses in
Appendices F and G of the Draft EIR are summarized in Section 4.4.4.4 (see pages 4.4-44
through 4.4-53) as amended in this Final EIR (see Chapter 5, Changes to the Draft EIR). This
section focuses on providing passage in critical areas in the Reclamation Ditch and lower Salinas
River watersheds and provides mitigation measures BF-1a, BF-1b, BF-1c, and BF-2 or Alternate
BF-2 to reduce all significant impacts on fisheries resources. The impact areas include the
immediate vicinity of the diversion site and upstream and downstream areas that could be
influenced by diversion actions associated with the Proposed Project. The analysis presents
impacts of diversions at each location and discusses downstream impacts of reduction of flows;
the analysis concludes that fish passage in Tembladero Slough (and downstream) is not
expected to be influenced by diversion due to the tidal influence up to this area and backwatering
of the channel which would ensure suitable water surface elevation and depths for passage at all
times. Combined diversion impacts from all proposed diversions at the OSR Channel at the
confluence of the Tembladero Slough would also be tidally influenced and not considered an
impact to fisheries and habitat as noted in Response to Comment G-3 in Chapter 4.
Wetland and Riparian Habitat and Other Aquatic Wildlife
Impacts to other (non-fish) biological resources that use or benefit from the water bodies
downstream of the proposed diversions are discussed in the Draft EIR, Section 4.5, Biological
Resources: Terrestrial (also amended as shown in Chapter 5, Changes to the Draft EIR).
Response to comment G-3 in Chapter 4, Comments and Responses on the Draft EIR, also
describes the Draft EIRs study areas for biological resource terrestrial. Draft EIR Section
4.5.4.4 (pages 4.5-96 through 4.5-106) is based on detailed biological resource characterizations
in Draft EIR Appendices H and I combined with the analysis of hydrology provided by Schaaf &
Wheeler in Draft Appendices N, O-Revised, P, and Q-Revised. See further descriptions about the
methodology, analysis, and conclusions of the Draft EIR impact analysis on biological habitat and
species below.
The text on Draft EIR pages 4.5-98 to 4.5-101 provides a detailed technical analysis of the
riparian and wetland impacts of the Proposed Project diversions on the affected reaches in the
Proposed Project area, including the Reclamation Ditch from the proposed diversion point to its
confluence with Tembladero Slough (only the Reclamation Ditch diversions would affect flow
here), the Tembladero Slough from the Reclamation Ditch confluence to the OSR Channel
confluence (only the Reclamation Ditch and Tembladero Slough diversions would affect flow
here), and the OSR Channel downstream to the Potrero Tide Gate. For the analysis of the OSR
Channel between its confluence with Tembladero Slough and the Potrero Tide gate, the Draft EIR
assumes and includes the flow effects of diverting waters within the Salinas River watershed, in
addition to proposed diversions from the Reclamation Ditch and Tembladero Slough diversions.
The Draft EIR presents the results of the wetland analysis on pages 4.5-98 through 4.5-101 and
concludes with the following:
The most important factor influencing hydrologic conditions in the Tembladero Slough
and Old Salinas River Channel is the presence and function of the Gate. The Gate opens
twice a day as a result of the tidal cycle in the harbor. During the dry season, the surface
water elevation changes very little between cycles relative to water surface elevation in
4
the Old Salinas River Channel and Tembladero (text added) Slough (Inman et al., 2014) .
During the wet season, the water surface elevation can and does rise dramatically in the
Tembladero Slough and Old Salinas River Channel and annually exceeds its banks and
floods adjacent lands (Casagrande and Watson, 2006). This predictable hydrologic
The study by Inman et al. 2014 was conducted in a dry year following an extended dry period.

Final EIR
3-10
September 2015
condition, or hydroperiod, consists of a stable summer surface water elevation that

fluctuates very little and winter condition with large variation in surface water elevations.
The proposed diversions would occur almost exclusively during the dry season and
would not significantly alter the existing hydroperiod within the Tembladero Slough and
Old Salinas River Channel as the surface water elevation in this area is moderated by the
tidal cycle of the harbor. Large wet season flows associated with storm events are of a
magnitude that the diversion will have no measurable effect of the rise in surface water
elevation and associated inundation of wetland adjacent to the channel. Therefore, the
proposed diversions would not impact wetlands adjacent to the Tembladero Slough and
Old Salinas River Channel.
The Draft EIR presents the riparian analysis of the Reclamation Ditch and Tembladero Slough on
page 4.5-101 and concludes the following:
. As described above, the proposed diversions include maintaining a minimum flow
throughout the dry season operation, which would facilitate the dry season soil saturation
necessary to sustain riparian habitat. In addition, the Tembladero Slough is subject to the
hydrological effects of the Gate resulting in stable dry season hydrology. Therefore, the
proposed diversion would not have a significant impact on the identified riparian habitat
within the Tembladero Slough.
The analysis in the Draft EIR summarized in this section applies to the individual and combined
diversions from the separate, but interconnected, watersheds of the Salinas River and the Reclamation
Ditch/Tembladero Slough, because the Proposed Project would not measurably affect water levels in the
Lagoon, nor in the OSR Channel or Tembladero Slough.
The Draft EIR has been updated to state explicitly that the EIR assumes all proposed diversions would
occur in accordance with the Proposed Project diversion descriptions in Section 2.7.1 on Draft EIR pages
5
2-36 through 2-42. The analysis in this Master Response (see below) explains why the diversions from
both watersheds would not have an additive effect on downstream water levels in the interconnected
parts of the system (i.e., OSR Channel, Tembladero Slough, Moss Landing Harbor, Elkhorn Slough, and
6
the Monterey Bay/Pacific Ocean). The additional information and description herein and inserted in the
Draft EIR clarifies the assumptions that were used in the biological and hydrologic analyses in the Draft
EIR in Sections 4.4, 4.5 and 4.11.
3.4.2.3 Water Level and Flow/Salinity Changes due to Proposed Diversions

Potential changes to water bodies that may adversely impact aquatic habitat, ecosystems, and species in
the affected reaches include: (1) water flow or water surface elevation reductions that may also reduce
the amount and duration of fish passage and wetted habitat, soil saturation and moisture, and/or plant
uptake of water, and (2) water quality worsening, in particular for this analysis, potential increases in
salinity (and in particular, the inter-related effects of inland surface water flow inputs and salinity in the
lower watershed). See Draft EIR, pages 2-5, and 4.11-64 through 4.11-71 and Master Response #6,
Nutrients in Recycled Water and Ocean Outfall Discharges (see Section 3.6.1 of this chapter), for a
discussion of the overall water quality benefits of the Proposed Project with regard to other pollutants.
As stated on the first full paragraph on page 2-42 of the Draft EIR, the Proposed Project description of yield and the
assumed diversions for the impact analyses (i.e., biological resources and surface water hydrology) assumes some
water would be left in the Reclamation Ditch and Tembladero Slough for fisheries resources. Specifically, flows of
0.69 cfs and 2.0 cfs are proposed to be left in the Reclamation Ditch at Davis Road from June through November and
December through May, respectively. A minimum flow of 1 cfs is proposed to remain in the Tembladero Slough year
round; however much more than that is anticipated to be present even under Proposed Project diversions. These
proposed by pass flows may be increased due to the requirements of NOAA NMFS and implementation of Mitigation
Measure BF-2a.
6
The surface water bodies potentially affected by the Proposed Project are not tributary to the Moro Cojo Slough. As
described in this Master Response, Moro Cojo Slough, like the Moss Landing Harbor and the Elkhorn Slough (see
Appendix AA), would not be affected by any increases in salinity or decreases in water surface elevations nor
changes to flows in the Old Salinas River Channel.
Final EIR
3-11
September 2015
The following analysis clarifies the Draft EIR approach, assumptions, and technical analysis summarized
in Section 3.4.2.1 related to flows, water surface elevations, and salinity. The Master Response also
clarifies the Draft EIR conclusions about how the Proposed Project would not result in significant habitat
or species impacts due to changes to water flows and surface elevations, or due to increases in salinity
as discussed further below (Schaaf & Wheeler, 2015).
Salinas River Watershed to Salinas River Lagoon

Water levels/flows. The proposed diversions of all three proposed source waters in the Salinas River
watershed (Salinas urban runoff, agricultural wash water, and Blanco Drain) would reduce flows in the
Salinas River by less than 1% total on an annual average basis, and would not affect water levels in the
Lagoon. United States Geological Society (USGS) data and county gage data demonstrate that even with
the Salinas River dry during the driest year on record (2014), the water levels in the Lagoon were
consistent with historic water levels. Table 3-A, below, shows the average monthly water level in the
Lagoon during 2013 and 2014. Note that even when the Salinas Treatment Facility ponds were dry (July
to November 2014), the average lagoon water levels were comparable to the previous year when the
ponds were full.
Table 3-A
Salinas River Lagoon Stage (feet)
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
2013
9.7
10.2
10.3
10.3
10.5
10.3
10.3
10.4
10.4
10.1
10.1
10.1
2014
10.1
10.3
10.7
10.4
10.3
10.3
10.6
10.5
9.7
9.5
10.0
11.8
Notes:
1. CDEC Station SLG, maintained by MCWRA, datum not specified
2. Lagoon was open to the ocean from 12/12/2013 to 1/28/2013, and remained closed through September 2015 or later.
Daily average flow at Spreckels gage was 0 cfs from 11/11/2013 to 12/12/2014.
3. Salinas River Diversion Facility operated 4/8/2013 to 11/8/2013, but not in 2014.
4. Salinas Treatment Facility flows diverted to MRWPCA 4/2/2014 to 11/26/2014. Ponds were empty by 7/1/2014.
The proposed agricultural wash water, Salinas stormwater, and the Blanco Drain diversions would reduce
some inputs to the Salinas River and Lagoon upstream of the Salinas River Diversion Facility (SRDF).
The proposed diversions in the Reclamation Ditch and Tembladero Slough watersheds would not result in
any changes to water surface elevation in, or flows to or from, the Salinas Lagoon due to the operation of
the slide gate and the relative elevations and flows of the two water bodies (i.e., flow from Tembladero
Slough into OSR to the south of their confluence toward rarely occurs) as discussed in detail above.
Salinity. Due to the very small percentage change in total Lagoon inflows due to the Proposed Project
(less than 1%), no measurable salinity changes to the Lagoon would occur.
Tembladero Slough and the OSR Channel

Water Levels/Flows. The proposed diversions in the Reclamation Ditch and Tembladero Slough would
result in reduction in flows to the Tembladero Slough and OSR Channel as acknowledged in the Draft
EIR, but this reduction would not be additive to flow reductions in the Salinas River or Salinas River
Lagoon because the Tembladero Slough and Reclamation Ditch watershed are not tributary to the
Salinas River or to the Lagoon. The proposed diversions of agricultural wash water, Blanco Drain, and
Salinas urban stormwater to the RTP would constitute less than one percent of the average annual flows
within the Salinas River. Based on the information in Section 3.4.2.1, above (minor amounts of inland
surface water flows, the beach berm, and the operation of the slide gate at the Lagoon), the proposed
flow reductions to the Salinas River, would not result in detectable changes in water levels during the dry
season in the Lagoon even in dry years with minimal surface water flow inputs as demonstrated by Table
3-A. See page 4.5-97 of the Draft EIR.
The combined diversions from the Reclamation Ditch and Tembladero Slough system represent less than
one percent of the average annual flow entering Moss Landing Harbor and Elkhorn Slough due to the
tidal action of the ocean on those waterbodies. The combined diversions from the Salinas River
watershed and from the Reclamation Ditch and Tembladero Slough would have no detectable effect on
Final EIR
3-12
September 2015
the flows nor water surface elevations in any water bodies north of the Potrero Tide Gate (see discussion
below under Moss Landing Harbor, Elkhorn Slough, and Moro Cojo Slough and Figure 4.5-3new).
As discussed above in Section 3.4.2.1, the Lagoon flows through the Lagoon slide gate and the
Reclamation Ditch/Tembladero Slough system are tributaries to the OSR Channel. The Lagoon flows into
the OSR Channel (at its southern terminus) through the Lagoon slide gate, and Tembladero Slough flows
into the OSR Channel approximately 1.5 miles north. See Figure 4.5-3new. The only water bodies that
would have any potential additive water surface elevation changes due to diversions from both
watersheds would be the OSR Channel and to a lesser extent the lowest reach of the Tembladero Slough
due to the tidal gate and tidal flow backwater effect.
The amount of surface water that flows into the OSR Channel from the south is controlled by a slide gate
at the Lagoon (called the Salinas Lagoon Gate on Figure 4.5-3new at the end of Chapter 5). Near the
northern end, the OSR Channel experiences a diurnal backwater cycle due to the rising and falling tides
and the operation of the Potrero Tide Gate. Because of the tidal control and the Lagoons stable dry
season water levels described above, water levels would not be affected by the Proposed Project under
conditions wherein all Proposed Project diversions (from both watersheds) would occur. The Proposed
Project would not result in any loss of inundation in the OSR Channel and therefore, the combination of
all proposed diversions would have less-than-significant impacts on water levels and the associated
beneficial uses and habitats that rely upon those water levels because there would be no measurable
loss of inundation nor reduced soil moisture.
Salinity. Diverting freshwater from the OSR Channels tributaries may increase the salinity within the OSR
Channel, which is currently a brackish water body due to leakage through soils and the Potrero tide gate
and the Lagoon slide gate (Nicole et al., 2010 and Inman et al., 2014). There is a potential for increases
in salinity near the water surface, and/or longer periods of salinity accumulation in the Tembladero Slough
and the OSR Channel before seasonal flushing by winter runoff. This potential water quality impact is
analyzed in the Draft EIR on pages 4.11-71 through 4.11-72 where the Draft EIR concludes that the
Proposed Project would have a less-than-significant impact on the water quality because the salinity
changes would be within the range of salinities that are currently found in these water bodies every year.
Species and habitats relying upon the OSR and Tembladero Slough waters have demonstrated their
tolerance for high salinity waters. In particular much higher salinity levels (above 15 ppt) are seen during
prolonged drought periods, such as late summer and fall of 2013 through 2015. (Inman et al, 2014 and
Nicole, et al., 2010) Conversely, even moderate precipitation events during the Inman and Nicole studies
resulted in drops of salinity to below 1 ppt. These precipitation events that result in flushing flows would
continue to occur under Proposed Project operations.
Diversions from the Reclamation Ditch and Tembladero Slough would be most needed by the Proposed
Project during dry years when irrigation demands are highest; during and after storm events Proposed
Project source water requirements are expected to be met by municipal wastewater flows. Due to the tidal
influence, water levels in the Tembladero Slough would not be noticeably affected by the Proposed
Project, so wetland species would not see a loss of wetted habitat due to salinity changes, only an
increase in the duration of periods of higher salinity. The existing system exhibits a wide variation of
salinities due to the influence of the ocean tidal fluctuations, storm surges, agricultural tile drain and
surface runoff, and urban runoff; therefore, based on the above information, these changes would result
in a less-than-significant impact on surface water quality in the affected reaches of the Reclamation Ditch,
Tembladero Slough and the OSR Channel.
Large rain events produce flushing flows through the OSR Channel, which push the brackish water past
the tide gates and into the Moss Landing Harbor. These flows occur during storm events in the winter
months, when project diversions would be much lower than during the dry season, and if diversions do
occur would be a very small fraction of the surface water flows. Summer rain events can and do generate
flows up to 70 cfs in the Reclamation Ditch/Tembladero Slough system. The Proposed Project would
divert up to 9 cfs from the Reclamation Ditch and Tembladero Slough, leaving sufficient flow for thorough
flushing of brackish water. In addition, as discussed above, the Proposed Project Salinas River watershed
diversions would not result in measurable reduction in surface water elevation in the Salinas Lagoon and
the OSR Channel, and thus no measurable change in flow through the Salinas Lagoon slide gate to the
OSR Channel. During these rain events the diversions would be reduced due to corresponding reduction

Final EIR
3-13
September 2015
of recycled water demand by agricultural irrigators, therefore, combined diversions would not prevent dryseason brackish water flushing from occurring in the lower watershed consistent with the existing
conditions.
Moss Landing Harbor, Elkhorn Slough, and Moro Cojo Slough

Water Levels/Flows. Due to the tide gate controls on the OSR Channel, incoming fresh water mixes with
the impounded, brackish water during rising tide cycles, and the brackish water moves through the
Potrero Road tide gates into Moss Landing Harbor and the Monterey Bay on falling tides. A portion of the
water from the OSR Channel is pushed back into Elkhorn Slough on the rising tide. The Moro Cojo
Slough flows into the Moss Landing Harbor through a separate tide gate. The average tidal cycle in
6
Elkhorn Slough is 122 x 10 cubic-feet of water (800 acres of surface area and an average tidal change of
3.5 feet). Assuming two cycles per day, the average inflow rate (over 6 hours) to Elkhorn Slough from the
harbor and ocean is 5,670 cfs. The typical freshwater inflow rate to the OSR Channel in summer is 10 to
7
15 cfs (combined Salinas River plus Tembladero Slough ). Doubling the typical peak rate to account for
the tidal cycle, 30 cfs is about 0.5% of the average inflow rate for Elkhorn Slough.
As discussed in Response to Comment G-3 and this master response, Moss Landing Harbor and Elkhorn
Slough were appropriately included as part of the project study area in Section 4.11, Hydrology and
Water Quality: Surface Water due to the potential for changes to quantities, qualities and timing of
inflows. However, the the EIRs biological resources analyses determined that Elkhorn Slough would not
to be a waterbody within which biological species, ecosystems, or habitats would be potentially affected
by the Proposed Project diversions (i.e., outside the project study area for terrestrial biological resources).
This conclusion was based on the findings in the hydrologic analysis and considered impacts of combined
diversions of all Proposed Project source waters, storm runoff, and daily tidal cycles. The analysis of
hydrology and water quality showed that the Potrero Tide gate is the farthest point downstream where
biological species might have any potential effect from combined project diversions. As described above
in Draft EIR Section 4.5.4.4, the effect of water flow/level changes due to all Proposed Project diversions
on biological resources (including fisheries and terrestrial/aquatic species) in the affected portions of the
Reclamation Ditch, Tembladero Slough, and the OSR Channel would be less than significant (with
Mitigation Measure BF-2a or Alternate Mitigation Measure BF-2a for fish passage in the Reclamation
Ditch). In addition, the Proposed Project would result in no impact due to water level/flow changes within
the tributaries to the Reclamation Ditch, Moss Landing Harbor, Elkhorn Slough, Monterey Bay, or to other
connected water bodies. The analysis in this Master Response and Appendix AA also describes how
storm runoff and the daily tidal cycles provide several orders of magnitude (more than 100 times) greater
flow in the Elkhorn Slough and Moss Landing Harbor than any flow changes in the OSR Channel due to
the Proposed Project diversions from the Salinas River and the Tembladero Slough/Reclamation Ditch
watersheds.
The Moro Cojo Slough flows into the Moss Landing Harbor through a separate channel; similar to the
OSR Channel, it is also protected with a tide gate. Moro Cojo flows would not be affected at all because
its water surface elevations and flows are not affected by any increases or decreases in water surface
elevations nor flows in the OSR Channel. Moro Cojo Slough is tributary directly to the Moss Landing
Harbor and inflows from the Harbor are controlled by another tide gate. The Proposed Project would not
divert any flows from the Moro Cojo Slough and would not change the amount of flow into or out of the
Moro Cojo Slough.
Salinity. A comment letter questioned how the Draft EIR addressed impacts to the water quality Elkhorn
Slough and the implications on the extent of the biological study area (comment letter G from the
California Department of Fish and Wildlife). In response to the comment, additional analysis was
prepared (see above and Appendix AA, Salinity Impacts to Elkhorn Slough Resulting from Surface
Water Diversions). The analysis in Appendix AA shows that the Proposed Project would cause less
than 0.8% salinity increase at Elkhorn Slough and 0.8% would occur only in a peak event using
conservative assumptions such as drought conditions with low tidal influence. On a daily, weekly and
7
Flows from Moro Cojo Slough are omitted from the estimate because (1) salinity data was not available, and (2)
these flows will be unaffected by the Proposed Project.

Final EIR
3-14
September 2015
monthly average, the Proposed Project would cause changes of even less than that amount (i.e., an
undetectable change given the wide variations of salinity in the slough caused by the tidal cycle each
day). Salinity levels (including measurements of electroconductivity and total dissolved solids
concentrations), are used as the primary indicator of the relative amounts of freshwater versus saline
ocean water in a water body. See also responses to comments G-2 and G-3. Information in this Master
Response reinforces the Draft EIRs conclusions that the Proposed Project would not result in an adverse
impact on the biological resources or other beneficial uses within the Elkhorn Slough. In fact, the
Proposed Project would result in a reduction in pollutant loading (including nutrients, such as
nitrate/nitrogen and orthophosphate/phosphorous) in the Moss Landing Harbor and Elkhorn Slough as
described on pages 2-5, and 4.11-64 through 4.11-75 of the Draft EIR, and reiterated by comments on
the Draft EIR summarized in Section 3.6.1, below.
3.4.3
Conclusions Regarding Biological Resources Impacts
Based on the analysis herein that clarifies the Draft EIR evaluation, implementation of all proposed
source water diversions would not result in measurable or detectable water level changes in the Salinas
River Lagoon, Old Salinas River Channel, Moss Landing Harbor, Elkhorn Slough, Moro Cojo Slough, and
Monterey Bay/Pacific Ocean. The EIR found that stable water surface elevations would be maintained
and thus proposed changes to flow would not adversely affect biological resources (habitat, species, and
other ecosystem services) in downstream water bodies that support habitat, even during the summer
months and drought years when all or a large majority of the proposed diversions would occur.
Specifically, no detectable changes in the amount or areas of inundation (and corresponding soil
saturation/moisture and plant uptake) would occur in these water bodies; therefore no adverse impacts on
aquatic habitats (including wetland and riparian), and no reduction in fish passage or habitat, are
anticipated due to the combined diversions from the Proposed Project. The proposed diversions would
reduce the volume of freshwater entering the system, particularly in the dry summer months, and could
result in increased salinity within these already brackish channels. The Proposed Project includes
minimum in-channel by-pass flows for habitat protection. These minimum flows are consistent with the
actual flows measured during the late summer and fall seasons of the current drought (2013-2015). The
slight increase in salinity that would occur in some months of each year is within the normal fluctuation of
the existing, background conditions.
The additional technical analysis in Appendix AA and this Master Response clarify the assumptions in
the hydrology, water quality, and biological resources impact analyses and confirm the appropriateness of
the impact conclusions in the Draft EIR. Specifically, diverting all Proposed Project source waters in the
Salinas Valley would result in less-than-significant impacts on the riparian and wetland habitats in and
near the waterbodies of the lower watersheds of the Salinas River and the Reclamation Ditch/Tembladero
Slough, including the following water bodies: the Salinas River, Salinas River Lagoon, the Reclamation
Ditch (from Davis Road to its confluence with Tembladero Slough), the Tembladero Slough, and the Old
Salinas River Channel. The Proposed Project would have no impact on riparian and wetland habitat in
and near the following water bodies: tributaries to the Reclamation Ditch, the Reclamation Ditch
upstream of Davis Road, the Moss Landing Harbor, Moro Cojo Slough, Elkhorn Slough, and Monterey
Bay/Pacific Ocean.

Final EIR
3-15
September 2015
3.5
MASTER RESPONSE #5: FISHERIES IMPACT ANALYSES
This master response addresses comments that relate to fisheries impact analyses in the Draft EIR,
including the following: C-5, D-3, E-4 to E-11, F-8, F-9c, G-2, G-3, G-4, G-9, H-33/34, M-1, M-30, M-31,
V-8, V-10, AA-6, AA-7, and AA-8. This master response was prepared with assistance from William
Snider, PhD, fisheries biologist with HDR Engineering Inc. whose resume is included in Appendix EE.
3.5.1
Adequacy of Fisheries Impact Analysis
The Draft EIR, in Section 4.4, provides descriptions and analyses of the potential impacts (including
individual and combined, and direct and indirect) to fisheries resulting from changes in bypass flows due
to the source water diversions for the Proposed Project. This section is based on the analyses prepared
by fisheries biologists from HDR Engineering and Hagar Environmental Science, and three technical
reports included in the Draft EIR in Appendices F and G. Schaaf and Wheeler provided baseline and
simulated river flows as a result of proposed diversions, which were used in the assessment of potential
impacts to fish species in the Salinas River and Reclamation Ditch (Draft EIR Appendices O, P and Q).
The technical studies included in the Draft EIR are the following (some of these studies have been
revised or are new for inclusion in this Final EIR, as indicated):
HDR Engineering, January 2015. Salinas River Steelhead Habitat and Passage Effects
Assessment Technical Memorandum. Prepared for Denise Duffy & Associates. (See
Appendix F-Revised).
Hagar Environmental Science. February 28, 2015. Pure Groundwater Replenishment

(GWR) Project Reclamation Ditch and Tembladero Slough Source Water Diversion
Fisheries Effects Analysis. Technical Memorandum, prepared for Denise Duffy &
Associates. (See Appendix G-1).
Hagar Environmental Science. February 27, 2015. Estimation of Minimum Flows for
Migration of Steelhead in the Reclamation Ditch. Technical Memorandum, prepared for
Denise Duffy & Associates. (See Appendix G-2).
Schaaf & Wheeler studies regarding source water yields and impacts:
o
December 2014. Blanco Drain Yield Study (see Appendix Q-Revised).
December 2014. Reclamation Ditch Yield Study (see Appendix P).
February 2015. Salinas River Inflow Impacts (including the impacts of changes
in percolation at the Salinas Treatment Facility on Groundwater and the Salinas
River (see Appendix O-Revised).
July 2015. Fish Passage Analysis: Reclamation Ditch at San Jon Rd. and
Gabilan Creek at Laurel Rd. (see Appendix CC of this Final EIR)
For the Draft EIR, the effect of Proposed Project diversions on bypass flows for steelhead migration within
the Salinas River and Reclamation Ditch were analyzed using standard protocols as described by
California Department of Fish and Wildlife (CDFW, 2013). The focus of the analysis was adult and
juvenile (smolt) migration, since the affected reaches of the Salinas River and Reclamation Ditch are
critical habitat for Federal Endangered Species Act (FESA) listed South-Central California Coast (S-CCC)
steelhead, and the primary constituent element (i.e., habitat feature essential to the conservation of the
species) within these reaches is migration to and from upstream areas that have been designated critical
habitat for steelhead spawning and rearing. Section 3.5.2 below further discusses criteria and data used
to analyze fish passage within the affected reaches of the Salinas River, and Section 3.5.3 discusses
similar information for the Reclamation Ditch. The analysis in the Draft EIR has been expanded in this
Final EIR by also evaluating the Proposed Projects effects on by-pass flows as specified by National
Marine Fisheries Service (NMFS) in its 2007 Biological Opinion for the Salinas Valley Water Project
(SVWP), and by conducting additional modeling of fish passage constraints in the Reclamation Ditch. The

Final EIR
3-16
September 2015
expanded analysis improves the accuracy of the Draft EIRs analysis, and confirms the conclusions that
the Proposed Projects effects on fisheries would be less than significant with mitigation.
3.5.2
Salinas River
Prior to preparation of the Draft EIR for the Proposed Project, steelhead fish passage evaluations in the
Salinas River had only addressed conditions upstream of the Proposed Project area (upstream of
Spreckels) (MCRWA 2001, 2005, NMFS 2007, MCWRA/Cardno-Entrix, 2014). The channel and related
passage flow conditions within the Proposed Project area differ from those upstream of Spreckels
(MCWRA/Cardno-Entrix, 2014). Accordingly, the fish passage analysis reported in Section 4.4. of the
Draft EIR was based on the results of several studies to provide a more site-specific evaluation of
potential effects on steelhead from the Proposed Project. Some of the comments on the Draft EIR stated
the opinion that the approach used in the Draft EIR was incomplete, and requested further evaluation
based on the flow data found in NMFS 2007 Biological Opinion for the Salinas Valley Water Project
(referred to as the NMFS 2007 SVWP BO in this section).
The data used in the Draft EIR to analyze fish passage within the affected reaches of the Salinas River
was acquired from the MCRWA 2001 EIR/Environmental Impact Statement (EIS) for the SVWP, as well
as other sources that reported fish passage conditions using standard procedures for determining
passage flows at critical riffles. The procedures used to collect and calculate the data used for the Draft
EIR are currently considered standard operating procedures (SOPs) by CDFW (2013) and the SWRCB
(2014), but were modified per the NMFS 2007 SVWP BO for evaluations pertaining to the Salinas Valley
Water Project.
In 2002, the Monterey County Water Resources Agency (MCWRA) developed the SVWP in an effort to
reduce Salinas Valleys dependence on groundwater through balancing the rate of groundwater
withdrawal and recharge. The SVWP is comprised of operational changes to the Nacimiento and San
Antonio Dams, modifications to the Nacimiento Dam, and construction and operation of the Salinas River
Diversion Facility (SRDF). During evaluation of potential environmental impacts of the SVWP, NMFS
developed a Flow Prescription to minimize impacts to S-CCC steelhead and their critical habitat. This
Flow Prescription relies on triggers based on a combination of reservoir conditions and stream flow to
initiate and provide fish passage flows to facilitate the upstream migration of adult steelhead between
February 1 and March 31 (MCWRA, 2005). In 2007, NMFS issued a Biological Opinion regarding the
potential effects of the construction and operation of the SRDF on threatened S-CCC steelhead and their
critical habitat in accordance with Section 7 of the Endangered Species Act of 1973 (NMFS 2007 SVWP
BO).
Essentially, the NMFS 2007 SVWP BO increased the minimum depth required for adult passage from 0.6
feet to 1.0 foot as compared to the depth used by MCWRA in its EIR for the project, and the location of
the depth in relation to the riffle transect was restricted to the riffle crest instead of the entire cross section
of the riffle. As a result, the flow criteria identified for fish passage at Spreckels (closest location to the
Proposed Project area) increased from 72 cfs to 150 cfs.
Additionally, minimum flow conditions required for downstream migration of smolts was determined based
on historic frequency of flows when emigration was considered by NMFS to occur rather than the physical
conditions at the critical riffles that influence fish passage, as determined using the MCRWA 2001 results
obtained per implementing the SOP for evaluation of fish passage at critical riffles.
In comparison to the NMFS 2007 SVWP BOs approach, which covers a greater extent of the Salinas
River, the fish passage evaluation reported in the Draft EIR for the Proposed Project is site specific. The
geomorphology of the Salinas River in the Proposed Project area is narrower and more suitable for use of
the critical riffle SOP than the much greater extent of the river evaluated for the SVWP. Also, the
evaluation used in the Draft EIR for the Proposed Project provided a much more conservative approach
to determining direct effects to passage; evaluation of true minimum flow conditions at which passage is
more likely to be affected by the low diversion rate associated with the Proposed Project. The evaluation
used in the Draft EIR provides the maximum effect of Proposed Project diversions to fish passage.
Similarly, the time frame evaluated for both up and downstream migration as discussed in the Draft EIR is

Final EIR
3-17
September 2015
greater than the timeframe considered under the NMFS 2007 SVWP BO, and provides a more inclusive
evaluation of effects on passage.
Nevertheless, to address the requests in comments on the Draft EIR, the analysis was expanded in the
Final EIR to further evaluate potential project-related effects to fish passage based on the NMFS 2007
SVWP BO requirements. Using the NMFS 2007 SVWP BO flows of 150 cfs and 300 cfs for January
through mid-March, and mid-March through May, respectively, the expanded analysis shows that the
Proposed Project would not change the frequency or duration of suitable fish passage conditions. See
response to comments E-4 and E-7 and Chapter 5, Changes to the Draft EIR in the section titled
Changes to 4.4: Biological Resources: Fisheries (see changes to Draft EIR pages 4.4-7 and 4.4-37).
This expanded analysis confirms the Draft EIRs conclusions that the Proposed Project would not
significantly affect steelhead in the Salinas River.
3.5.3
Reclamation Ditch
The analysis of the Proposed Project effects on steelhead in the Reclamation Ditch watershed focused on
fish passage constraints, primarily at the San Jon weir. As discussed in Section 4.4 of the Draft EIR and
Appendix G, the evaluation was based on results of hydraulic modeling that included uncertainties that
could affect the characterization of passage conditions. To improve the precision of the analysis, an
updated analysis of the Proposed Projects effect on fish passage in the Reclamation Ditch was
conducted by Schaaf and Wheeler and is included in this Final EIR as Appendix CC, Passage Flow
Technical Memorandum. The results of the updated analysis are summarized in the Final EIR in the
responses to comment E-10, and reaffirm the Draft EIRs conclusions that the Proposed Project would
not significantly affect steelhead in the Reclamation Ditch with implementation of identified mitigation
measures.
3.5.4
Fisheries Impacts and Mitigation Measures during Construction

and Operation
Potentially significant impacts to fisheries due to construction were identified in the Draft EIR on pages
4.4-41 through 4.4-44 and mitigation measures to reduce significant impacts to a less-than-significant
level were provided on page 4.4-44, including Mitigation Measures BF-1a and BF-1b (as revised in this
Final EIR in Chapter 5, Changes to the Draft EIR) that require construction to be timed to occur outside
of both adult and smolt steelhead migration periods (i.e., between June and November) and relocation of
aquatic species during construction. Commenters requested clarification and amplification on the
reference to best management practices (BMPs) on page 4.4-42. The text of page 4.4-44 has been
revised to include the requirement to implement Mitigation Measure BT-1a from the Draft EIR Section 4.5,
which would further reduce impacts to aquatic species during construction. Further, additional specified
BMPs for fisheries have been included as supplementary mitigation in the Fisheries section; please refer
to Chapter 5, Changes to the Draft EIR, under Section 4.4.
Regarding operational impacts of diverting water, impacts of the diversions on the Salinas River were
analyzed on pages 4.4-44 and 4.4-45 of the Draft EIR and a detailed analysis was provided in Appendix F
that found the change in flows under the Proposed Project would not result in significant impacts to
steelhead migration in the Salinas River, as discussed above in Section 3.5.2.
The potential impacts to fisheries due to diverting water from the Tembladero Slough were analyzed in
the Draft EIR on pages 4.4-45 through 4.4-48; this discussion summarizes the detailed analysis in
Appendix G. Mitigation measures to reduce the potentially significant impacts to a less-than-significant
level were provided on Draft EIR pages 4.4-48 to 4.4-49, as modified in this Final EIR, including Mitigation
Measure BF-2a and Mitigation Measure Alternate BF-2a.
Some comments on the Draft EIR requested additional detail on mitigation requiring pre-construction
surveys for tidewater goby at the Tembladero Slough diversion facility, suggesting that there may be an
issue of deferral of mitigation if additional detail on the mitigation is not provided in the EIR. Mitigation BF1c (added to the EIR in this Final EIR in Chapter 5, Changes to the Draft EIR) addresses tidewater goby
Final EIR
3-18
September 2015
and steelhead impact avoidance and minimization at the Reclamation Ditch and Tembladero Slough
diversion facilities and requires a dewatering/diversion plan, with specific plan elements to be refined
through consultation with USFWS, NMFS and CDFW. The mitigation also requires the pre-construction
surveys identified in Mitigation Measure BF-1b to be consistent with requirements and approved protocols
of the applicable resource agencies and performed by a qualified fisheries biologist. There are certain
cases when deferral of the specific details of mitigation may be allowable under CEQA, including in this
instance, when consultation under the California Endangered Species Act (CESA) and FESA has not yet
been completed, as is the case for tidewater goby and steelhead. It is therefore impractical or infeasible
to fully formulate the details of the mitigation measure at the time of Final EIR certification and project
approval; however, the mitigation applies appropriate protocols and the lead agency commits to mitigation
that would minimize and avoid impacts to the protected species. Specific mitigation has been included for
BMPs, which include monitoring and compliance with standards in permits. In addition, the project
proponent must consult with the U.S. Fish and Wildlife Service (USFWS) and NMFS concerning the
Proposed Projects direct or indirect effects on federally listed threatened, endangered, or candidate
species at project sites and surrounding areas and identity measures to reduce such effects. Consultation
with the CDFW also is required both under the CESA and in the mitigation measure. Therefore, the
mitigation will be finalized during the consultation process. As these agencies are integral in the process,
the Proposed Project is not able to devise final mitigation measures until consultation is completed. The
consultation will also ensure the lead agency is committed to performance criteria identified in the
measure and also to be applied during consultation.
As noted above, clarification and amplification have been provided as appropriate for mitigation measures
and BMPs. Provision of additional detail on mitigation for the diversion facility construction will be
conducted as part of the consultation and approval process pursuant to FESA and CESA. The added
mitigation requires MRWPCA and/or implementing entity to obtain resources agency permits (i.e., either
an Incidental Take Permit or written concurrence that implementation of the Proposed Project will not
result in take for steelhead and tidewater goby as required by FESA). This and measures above are
proposed for avoidance and minimization of impacts to tidewater goby and steelhead and must be
reviewed, modified and/or approved as part of the CESA and FESA consultation process. Additionally, in
response to concerns raised by the resource agencies to ensure impacts to species are minimized,
Mitigation Measure BT-2c: Avoidance and Minimization of Construction Impacts Resulting from Horizontal
Directional Drilling under the Salinas River (Applies to Blanco Drain Diversion) has been revised and
expanded to require completion and implementation of a Frac-Out Plan to avoid or reduce accidental
impacts resulting from horizontal directional drilling (HDD) beneath the Salinas River. The Frac-Out Plan
shall be prepared and submitted to United State Fish and Wildlife Service, California Department of Fish
and Wildlife, NMFS/NOAA and the Regional Water Quality Control Board during the project permitting
and may be subject to approval by those agencies as part of permitting process prior to commencement
of HDD activities for the Blanco Drain Diversion construction.
The reader is also directed to the Final EIR responses to individual comments involving fisheries in
Chapter 4, including C-5, D-3, E-4 to E-11, F-9c, G-2, G-3, G-4, H-33/34, M-9 to M-18, V-8, V-10, AA-6,
and AA-7 and Chapter 5, Changes to the Draft EIR.

Final EIR
3-19
September 2015
3.6
MASTER RESPONSE #6: NUTRIENTS IN RECYCLED WATER AND

OCEAN OUTFALL DISCHARGES
This master response addresses comments regarding nutrient/nitrogen issues due to discharge of these
pollutants into groundwater basins, surface waters, and the ocean environment, including the following:
X-1, X-4, X-5, and X-10 to X-18. This master response was prepared with assistance from Trussell
Technologies (Gordon Williams, Ph.D., P.E.), Bahman Sheikh, Ph.D., P.E., Distinguished Fellow at
Center for Integrated Water Research at University of California at Santa Cruz, Schaaf & Wheeler
(Andrew Sterbenz, P.E.) and Nellor Environmental Services (Margaret H. Nellor, P.E.). Resumes for
these technical experts are provided in Appendix EE in the Final EIR.
3.6.1
Beneficial Water Quality Impacts due to Nutrient Removal from

Surface Waters
As documented in Chapter 2, Project Description (page 2-5) and in Section 4.11 of the Draft EIR (pages
4.11-69 through 4.11-71), the Proposed Project would result in beneficial impacts related to reduction in
pollutant loads downstream of points of diversion on the impaired surface waters (Reclamation Ditch,
Tembladero Slough, Blanco Drain, and the Salinas River), including ongoing annual removal of an
estimated 286,000 pounds (143 tons) of Nitrate as N, and 6,000 pounds (3 tons) of Orthophosphate as P
(assumes diverting 6-months/year, not including removal related to stormwater diversions and agricultural
wash water to the RTP).
The Draft EIRs conclusions about beneficial impacts of the Proposed Project are further supported by
comments submitted on the Draft EIR, including the following:
Comment E-7 from NOAA NMFS states: NMFS is very supportive of removing agricultural runoff
high in pesticides and nutrients from entering the Salinas River. For years, we have requested
MCWRA to either implement actions to improve water quality in the Blanco Drain (i.e., vegetated
treatments) or divert the Blanco Drain runoff so it does not enter the river.
Comment G-13 from the CDFW states: Water from the lower Salinas/Tembladero Slough is
highly polluted and the dominant source of nitrate loading to the Elkhorn Slough, with the
Tembladero Slough accounting for two orders of magnitude more nitrate than the Old Salinas
River Channel. This proposal proposes to reduce nitrate load to Elkhorn Slough by reducing flow
of Tembladero Slough.
Comment O-2 (item #4) from the City of Salinas states: The GWR would accept diverted storm
water for treatment and reuse, both flows to the Reclamation Ditch from the Citys northern areas
and to the Salinas River from the Citys southern third. This project aspect has two benefits; it
creates more water supply for the GWR with benefits described elsewhere in this list while
decreasing the potential discharge of contaminants to both the Salinas River and to Monterey
Bay. This results in an overall benefit of the environment.
Comment O-2 (item #7) from the City of Salinas states: The new operational mode for the
Salinas Treatment Facility Ponds will decrease the amount of water that infiltrates locally into the
shallower aquifer. This change will have a minor, insignificant impact on local groundwater levels
with a lowering of average groundwater elevations of approximately 1.3 feet but will decrease the
release of somewhat impaired water into the aquifer, resulting in a net overall benefit.
Comment V-1 from the Surfrider Foundation states: Surfrider Foundation supports the beneficial
objectives the Project seeks to advance, such as maximizing use of recycled water, reducing
urban stormwater and agricultural pollutant loading to the nearshore, and reducing the volume of
discharges to Monterey Bay.

Final EIR
3-20
September 2015
3.6.2
Technical Information in the RWQCBs Relevant Total

Maximum Daily Load (TMDL) Project Report Supporting the
Beneficial Water Quality Impact Conclusions
The opinions stated in Section 3.6.1 above, and the analysis in the Draft EIR demonstrating the Proposed
Project would result in beneficial impacts are further supported by information and analysis in the report
Total Maximum Daily Loads for Nitrogen Compounds and Orthophosphate for the Lower Salinas River
and Reclamation Canal Basin, and the Moro Cojo Slough Subwatershed, Monterey County, California
(California Regional Water Quality Control Board, 2013) (hereafter referred to as the
Nitrogen/Orthophosphate TMDL Report). Specifically, the following findings from
the
Nitrogen/Orthophosphate TMDL Report are repeated here to demonstrate the Proposed Projects
benefits and lack of significant impacts related to nutrients and nitrogen impacts.
Concentrations of Nitrogen in Source Waters Compared to U.S. Environmental Protection Agencys
(USEPAs) Reference Conditions. The USEPAs 25th percentile concentration (representing unimpacted
reference conditions for the Proposed Project area) of total nitrogen is 0.52 milligram per liter (mg/L) as N
(see Nitrogen/Orthophosphate TMDL Report on page 37, Table 2-7). As shown on pages 4.11-70 and
4.11-71 of the Draft EIR, the average concentrations of nitrate as N (which represents only a portion of
total nitrogen) in the Reclamation Ditch, Tembladero Slough, and Blanco Drain were found to be 13, 29,
and 65 mg/L as N, respectively, and are 25 to 260 times higher than the USEPAs unimpacted reference
conditions. As described on page 4.10-66 of the Draft EIR, the nitrate concentration in Salinas Treatment
Facility pond water (i.e., the treated agricultural wash water) was found to be between 4.5 and 5.9 mg/L
nitrate as N, which is two to three times greater than the existing ambient groundwater concentration and
eight to 11 times greater than the unimpacted reference condition. Recharge from Salinas Treatment
Facility pond percolation presently tends to exacerbate existing degraded conditions in both the
groundwater and, during some times of the year, in the Salinas River during low flow/dry periods due to
connectivity between groundwater and the river. Therefore, a decrease in pond percolation enabled by
the diversions, treatment and reuse of agricultural wash water, would have a beneficial impact on nitrate
concentrations in the groundwater and the river.
Concentrations of Phosphorous in Source Waters Compared to USEPAs Reference Conditions. The
th
percentile concentration of total phosphorous is 0.03 mg/L as P (see
USEPAs 25
Nitrogen/Orthophosphate TMDL Report on page 37, Table 2-7). Average concentrations of orthophospate
as P (which represents only a portion of total phosphorous) in the Reclamation Ditch, Tembladero
Slough, and Blanco Drain were found to be 0.65, 0.43, and 0.85 mg/L as P, respectively, and more than
14 to 28 times the unimpacted reference conditions. As described on page 4.10-69 of the Draft EIR, the
RWQCB has not adopted a water quality objective for phosphorus in groundwater. It is not a constituent
regulated by drinking water standards or addressed for the agricultural supply beneficial use in the Basin
Plan, but would be subject to the State Anti-Degradation Policy. Therefore, changes in phosphorus
concentrations in the 180-Foot Aquifer caused by decreased Salinas Treatment Facility pond percolation
would not affect beneficial uses according to the Basin Plan; however, the phosphorus concentrations in
treated water are higher than in the groundwater so reducing the pond percolation would also be
expected to lower phosphorous levels in the groundwater. In addition, as stated on pages 4.11-66
through 4.11-67 of the Draft EIR, the existing Salinas Treatment Facility pond percolation may degrade
river water quality with respect to phosphorous because median concentrations of phosphorous are
higher in the treated pond water (27 mg/L as P) than in the Salinas River (0.01 mg/L P) and the water
quality objectives for the Salinas River below Spreckels are 0.07 to 0.13 mg/L.
Benefits to Water Quality of Diverting Polluted Surface Waters.
Nitrogen/Orthophosphate TMDL Report, it states (emphasis added):
On
page
285
of
the
In a letter to Water Board staff dated Nov. 3, 2011, the Monterey County Water Quality
and Operations Committee reported that the Salinas River Diversion Facility (SRDF)
became operational in 2010, and reportedly has significantly changed summer flow
conditions in the lower Salinas River, and reduced nutrient loads downstream of
the SRDF compared to pre-2010 data. In a letter dated March 7, 2012 the Monterey

Final EIR
3-21
September 2015
County Water Quality and Operations Committee (MCWQOC) provided water quality
information associated with the SRDF to staff for inclusion in this project report.
According to the data summary provided by MCWQOC, the amount of nitrate-N load
being diverted from the Salinas River and the Blanco Drain during 2010 and 2011 and
subsequently used for irrigation (after dilution with recycled water) ranged from 66,220
pounds to 205,958 pounds per year. Future diversions of water column nitrate-N loads in
future years are projected by MCWQOC to be on the order of 200,000 to 244,000 pounds
per year. Based on the estimates provided, diversion of water column nitrate-N loads
from the Blanco Drain should be very helpful in protecting and enhancing aquatic
habitat in the Salinas River Lagoon and lowermost Salinas River. Additionally, as
previously noted in Section 3.11.2, recent monitoring data from LOBO sensor L03143 at
the Old Salinas River (OSR Channel) estuary has indicated drops in nitrate
concentrations during the years 2010 and 2011 (see Figure 7-3). These happen to be the
years the SRDF went into operation. Note that the OSR Channel receives flow inputs
from the Salinas River lagoon via the slide gate near Mulligan Hill. While definitive
conclusions cannot be drawn about the nature of the recent apparent drop in nitrate
concentrations in the OSR Channel, Staff speculates that it may be partially
attributable to operation of the Salinas River Diversion Facility, and the nitrate load
reductions/diversions as reported by MCWQOC.
The Proposed Project would further enhance these benefits on the lower Salinas River, the Lagoon and
the Old Salinas River Channel by diverting a majority of dry-season flows directly from the Blanco Drain
for treatment at the RTP and subsequent reuse.
High nitrogen and phosphorous concentrations are not sufficient by themselves to create a risk of
eutrophication. Except in extreme cases, nutrients alone do not impair beneficial uses. Rather, they cause
indirect impact through algal growth, low dissolved oxygen, and the biostimulatory effects of stream
hydraulics, geomorphology, geology, and sunlight and canopy conditions (RQWCB, 2013). As described
in the Nitrogen/Orthophosphate TMDL Report, these conditions are known to exist in the freshwater and
estuarine conditions of the Salinas River, Lagoon, Old Salinas River Channel, Tembladero Slough, and
the Reclamation Ditch. These conditions do not exist in the Pacific Ocean. The following section
summarizes the Draft EIRs analysis of Proposed Projects impacts related to nutrient and nitrogen
discharges to the ocean.
3.6.3
Ocean Discharges of Nitrogen and Phosphorous
Some of the new raw source waters have higher concentrations of nutrients than the RTP raw
wastewater. At times when the agricultural tile drainage and surface runoff waters would be diverted to
the RTP collection system, the total nitrogen concentration in the raw wastewater would marginally
increase. For example, based on the 2014 source water monitoring conducted for the Draft EIR and the
source water flow analysis provided in the Draft EIR, the total nitrogen in the secondary effluent was
projected to increase from an average of 44 to 49 mg-N/L for times when the agricultural drainage waters
would be diverted to the RTP. The primary, secondary, tertiary and AWT Facility processes do not
remove substantial amounts of nitrogen from the wastewater stream. Most nitrogen is contained in the
soluble form (i.e., ammonia, nitrate, and nitrite) and only the fraction bound to solids (i.e., a portion of
organic nitrogen) would be removed through settling or filtration in the primary, secondary, tertiary
systems at the RTP or the membrane filtration step at the AWT Facility. Similarly, at times when the
agricultural wash water is diverted to the RTP, the phosphorus concentration in the raw wastewater would
increase, and while removal of particulate-bound phosphorus would still be high, removal of dissolved
phosphorus would be low (e.g., when the agricultural wash water was diverted to the RTP in 2014, the
concentration of orthophosphate in the secondary effluent was observed to increase from 3 to 6 mg-P/L).
For recycled water to be used for groundwater replenishment, these soluble forms of nitrogen and
phosphorus would be effectively removed through the AWT Facilitys reverse osmosis membrane
treatment (e.g. during the AWT Facility pilot testing, average removals of 94.3% and greater than 96.7%
were observed for total nitrogen and phosphate, respectively), such that the recycled water produced by
the AWT Facility would meet all applicable drinking water quality regulations. The nitrogen and

Final EIR
3-22
September 2015
phosphorus removed by the reverse osmosis membranes would be contained within the reverse osmosis
concentrate stream discharged through the existing ocean outfall. Thus, while nitrogen and phosphorus
are effectively removed through the AWT Facility, the loading of nitrogen and phosphorus discharged to
the ocean from the MRWPCA outfall would be the same or increase (due to the higher nitrogen
concentrations in agricultural drainage and higher phosphorus concentrations in the agricultural wash
water).
While nitrogen and phosphorus are both components that have the potential to contribute to algae
growth, the dynamics of harmful algal blooms are complex and a causative linkage between
anthropomorphic nutrient discharges (such as a wastewater discharge) and the formation of harmful algal
blooms in the open ocean is still unclear (Anderson et al., 2008; Kudela et al., 2008; Caron et al., 2010).
Several factors affect algal blooms, including the right combination of temperature, light intensity,
flow/mixing, salinity, trace metal availability (iron, copper, and selenium), macronutrient availability
(silicate, nitrogen, and phosphorus), cellular elemental levels, and physiological stress (Caron et al.,
2010). Along the California coast (including Monterey Bay), the dynamics of harmful algal blooms appear
to be dominated by oceanic forces, such as occurrence during upwelling currents, but this does not rule
out that anthropomorphic nutrient sources could exacerbate an algal bloom (Anderson et al. 2008; Caron
et al., 2010; Horner et al., 1997).
Further, while the concentrations of nitrogen and phosphorus in the MRWPCA ocean discharge would
increase, it is important to note that the net nutrient loading to the ocean from the region would decrease
due to the Proposed Project, taking into account the diversion of the agricultural drainage waters and the
reduction of agricultural fertilizer use (as described in Section 3.6.4 of this master response). This
condition is notable, as the effects of nutrients on ocean eutrophication and algal blooms are a function of
the nutrient flux rate (i.e. loading) and not the nutrient concentration (Anderson et al., 2008).
Although the link between wastewater and open ocean algal blooms is still unclear, there have been
documented impacts of nutrient loading to the beneficial uses in the lower Salinas River watershed water
bodies. Thus the diversion of some of the nutrient-laden waters from Salinas River and Reclamation
Ditch/Tembladero Slough watersheds to the RTP and ultimately to the MRWPCA ocean outfall would
reduce the impact to the Salinas River watershed.
The existing MRWPCA ocean outfall extends approximately 11,260 feet offshore into the Monterey Bay
with diffusers that release the discharge at a depth of approximately 100 feet below the surface of the
ocean. Conditions in and near the ocean outfall are not conducive to algal growth or eutrophication, as
the sunlight, geochemical, and hydrologic conditions that create algal blooms do not exist within the
ocean outfalls dilution zone. Concentrations of nutrients are too low at the edge of the zone of initial
dilution. More importantly high concentrations of nutrients would occur well below the photic zone, and
the conditions near the outfall are not low velocity or stagnant. Neither the California Ocean Plan nor the
RWQCB National Pollutant Discharge Elimination System (NPDES) permit contain numeric objectives or
effluent limitations for total nitrogen or phosphorous. Instead, the California Ocean Plan includes a
narrative water quality objective (II.D.6) whereby nutrient materials shall not cause objectionable aquatic
growths or degrade indigenous biota (see 2012 California Ocean Plan page 6). The NPDES permit for
the RTP includes receiving water limitation IV.A.12, which states: Nutrient levels shall not cause
objectionable aquatic growths or degrade indigenous biota (see Order No. R3-2014-0013, page 11).
Thus, protections are in place to address nutrient discharges to the ocean. Ammonia is included in the
California Ocean Plan for its impacts on aquatic life, but as described in the Draft EIR (Appendix U), the
concentrations of ammonia resulting for the Proposed Project discharge would comply with the Ocean
Plan objective.
It is important to note that the Nutrient and Orthophosphate TMDL Report states denitrification and
retention of nitrogen in the lower Salinas Valley do not occur at rates that would substantially mitigate the
risk of nitrogen loading to surface waters and to affected downstream receiving waters. Therefore, if the
Proposed Project is not implemented almost all of the nitrogen loading from the Reclamation Ditch,
Tembladero Slough, Blanco Drain, and the Salinas Pump Station and Treatment Facility diversions would

Final EIR
3-23
September 2015
continue to flow downstream, affecting water quality in those areas as they do under current conditions.
Without substantial denitrification and retention of nitrogen in the lower Salinas Valley, the majority of
nitrogen in the various surface waters are currently released to the Monterey Bay either via the Old
Salinas River Channel to Moss Landing Harbor or, during times that the Salinas River sand bar is
breached, the Blanco Drain waters would flow directly to the Bay. The exception to this is the amount
diverted for treatment and reuse at the SRDF (and these diversions are anticipated to continue at the
same amounts as under existing conditions based on the MCWRA water rights). The Proposed Project
would divert, treat, and reuse large volumes of the impaired surface waters and agricultural wash water,
while also substantially reducing municipal wastewater disposal and ocean pollutant loading through
increased use of the existing unused municipal wastewater year-round. The total nitrogen pollutant
loading on the ocean would be substantially reduced compared to the existing and future background
conditions. The Proposed Project would have a quantifiable beneficial impact related to the total pollutant
load to the ocean.
3.6.4
CSIP Additional Use of Tertiary Treated Recycled Water

Containing Nitrogen and Phosphorous
With the diversion of the agricultural drainage waters and agricultural wash water into the RTP collection
system, the total nitrogen (specifically nitrate) and total phosphorus concentrations, respectively, would
increase in the non-potable recycled water used for irrigation of CSIP land. One comment notes concerns
about the nutrient/nitrate loading on CSIP agricultural land, and the potential for a subsequent increase in
runoff of polluted waters to surface water and groundwater resulting from the use of these new sources of
raw waters to the existing municipal wastewater system. Other comments allude to future CSIP
expansion; however, the Proposed Project does not include a potential future expansion of the CSIP area
(see response to comments X-7, X-8, and X-9). The following explanation is provided to document why
diversion of the source waters for production of recycled water used for irrigation would not tend to
increase the total load of nutrients that would be disposed or discharged to the environment within or
downgradient of the existing CSIP area:
Nitrogen is an essential nutrient for plant growth--in fact, it is a macro-nutrient, required in

substantial quantities to produce commercially viable crop yields on farmland. Table 3-B shows
the typical amount of macronutrients used (taken up from the soil solution) by the crops typically
grown in the CSIP service area during each growing cycle. Because of the inefficiency of nutrient
uptake by crops, growers typically apply twice these amounts (or more) in order to obtain optimal
yields from their harvest.
Table 3-B.
Plant Food Utilization by Various Crops
Uptake of Nutrient Per Season (Pounds per Acre)
Nitrogen (N)
Phosphate (P2O5)
Potassium (K2O)
Artichokes
353
63
506
Broccoli
80
30
75
Cabbage
270
65
250
Celery
280
165
750
Lettuce
95
30
200
Tomatoes
180
50
340
Strawberries
200
--SOURCES: Adapted from Western Plant Health Association, 2002, page 97 (except artichokes and strawberries). Source for
artichokes: Rincon et al., 2007. Source for strawberries: Bottoms et al., 2013. Data were converted from metric (in the
source) to English units.
Crop
In 2014 and 2015, agricultural wash water has been diverted to the RTP for treatment and reuse for agricultural
irrigation. These diversions were completed due to the lack of adequate Salinas River water related to the historically
low rainfall and that resulted in the lack of operation of the Salinas River Diversion Facilities to augment recycled
water for CSIP irrigators.
Final EIR
3-24
September 2015
Recycled water can only supply some of the nutrient needs of the crop, with the fraction varying
from 25% to close to 100% of the needs of the crop. Thus, nutrients in recycled water would need
to be supplemented with commercial (chemical, organic or manure) fertilization. Because growers
incur substantial cost to purchase and apply fertilizers, it is reasonable to presume based on
economics, that growers would reduce the use of fertilizers if irrigation water provided a
significant portion of the required macro-nutrients for optimal plant growth (Cahn, 2013). The
amount of nitrogen supplied by the RTP recycled water (at 44.2 mg/L as N) can be calculated
thusly:
Total N = 44.2 mg/L *0.001 g/mg *3.785 L/gallon *325,850 gallon/AF *0.0022046 Lb/g = 120 Lb/AF
Where:
g/mg is grams per milligram, L is liter, Lb/g is pounds per gram, and Lb/AF is pounds per acre foot
At this concentration, recycled water (that has not been diluted with Salinas River water diverted
from the Salinas River Diversion facility), used for one crop of lettuce at the rate of 1.5 AF per
acre per season, with an uptake efficiency of 50%, would provide about the same amount of
nitrogen as the growers normal chemical fertilization program would provide. For other crops, the
corresponding fraction of nitrogen provided by recycled water is calculated in Table 3-C, using
the same assumptions used for lettuce.
Table 3-C.
Fraction of Nitrogen Provided by Recycled Water During a Growing Season
Average Depth of
Irrigation Water,
Acre-Inches per year
per Acre*
30
Total Nitrogen
Delivered in
Recycled
Water**
300
Broccoli
16
Cabbage
Nitrogen Uptaken by Crop

from Recycled Water at
50% Uptake Efficiency
Fraction of Nitrogen
Demand Provided by
Recycled Water***
150
42%
160
80
100%
24
237
118
44%
Celery
24
237
118
42%
Lettuce
18
180
90
95%
Tomatoes
25
246
123
68%
Strawberries
28
283
142
71%
Crop
Artichokes
* SOURCE: For cabbage and celery, Montgomery-Watson, 1997. For artichoke, broccoli, lettuce, tomatoes and strawberries
based on average-year local crop evapotranspiration calculations.
** = table 1 column 1 value multiplied by table 2 column 1 value
***These percentages must be considered conservatively under-estimates, because the normal practice at CSIP is to blend
recycled water with Salinas River water, which contains almost no nutrients.
In a field trial of nitrogen uptake conducted in the CSIP service area (Cahn, 2013), the following
conclusion was reported:
The results of the 2 field trials demonstrated that ambient N in irrigation water has fertilizer value
for shallow rooted vegetable crops such as lettuce, even when the N concentration in the water
was low (< 20 ppm N). The trials also showed that the source of N (NH4 vs NO3) did not affect
crop recovery. Presumably NH4 would quickly transform to NO3 when added to the soil. Also, the
volume of water applied did affect the recovery rate of N, suggesting that all water applied
containing N had fertilizer value to the crop.
All fertilization, whether with commercial fertilizers or in recycled water, involves uptake
inefficiencies (sometimes as high as 50% of the applied amount) (Hodge et al, 2000). These
inefficiencies result from losses of nitrogen, including transformation into organic forms,
denitrification, volatilization as nitrogen gas, and some leaching below the root zone. Nitrogen
in recycled water is more efficiently taken up than side-dressed (i.e., placed on or in the soil
near the roots of a growing crop) or broadcast commercial fertilization because it is
immediately available to the root system and arrives at a steady and available form with each
irrigation event (Cahn, 2013)

Final EIR
3-25
September 2015
The fraction of nitrogen applied by fertilization that is not taken up by crops or lost in other
ways (mostly in the form of nitrate), is eventually leached below the root zone and travels
downward (Provin and Hossner, 2001).
Because of the confined nature of groundwater underlying the CSIP service area, and
because of the under-drained character of most of the fields, the nitrogen not taken up by
plants does not reach groundwater and thus does not impact groundwater quality. According
to numerous hydrogeologic studies of the lower Salinas Valley, in the Pressure Subarea (the
part of the Salinas Valley Groundwater Basin over which the CSIP service area overlies), a
regionally extensive clay layer (the Salinas Valley Aquiclude), greatly restricts the downward
movement of recharge from rainfall, irrigation, and to a lesser extent, the Salinas River, to the
underlying water supply aquifers. See Response to Comment Q-14 and Draft EIR page 2-13
as amended in this Final EIR. The nitrogen in the tile drainage water can impact nitrogen
levels in the downstream surface water, including the Monterey Bay/Pacific Ocean. The
Proposed Project would not adversely impact nor, in fact, increase the amount of nitrogen
discharged to surface waters because a large portion of the drainage water would be diverted
to the RTP for treatment and water recycling. Nitrogen removed at the RTP and AWT Facility
would be discharged to the ocean as previously discussed. There would be a net reduction in
the nitrogen loading on water bodies downstream of the points of diversion (i.e., both from
Blanco Drain and from Tembladero Slough).
Introduction of recycled water to the CSIP service area has had the benefit of contributing
some of the nitrogen needs of the crops grown in that area.
The agricultural fields in the CSIP service area are (and have been for a long-time) underdrained with perforated tiles. These drain-tiles take drainage water, leached out of the root
zone, and transfer it into surface drainage channels, which normally would end up in
Monterey Bay. However, as indicated above, the Proposed Project would divert the drainage
water to the RTP and reuse a portion of the tile drain water, thereby resulting in a net
reduction in the nitrogen loading on water bodies downstream of the points of diversion (i.e.,
both from Blanco Drain and from Tembladero Slough).
CSIP area growers that receive nearly 100% recycled water have cut back their nitrogen
fertilization quantities to account for the nitrogen in recycled water. Growers in areas where
recycled water was heavily supplemented with well-water have not been able to cut back
their fertilizer applications. With the Proposed Project, most supplemental well water use
would be replaced by additional recycled water use, thus fertilizer applications would be
expected to be reduced. (Bob Holden, personal communication, August 2015)
Currently, all growers in the CSIP service area receive the same (uniform) blend of recycled
water and Salinas River water, with a nitrogen content that is significantly lower than what is
in the present in recycled water alone.
Providing treatment to remove nitrogen from the recycled water intended for irrigation of
crops would require energy and costly additional processing, and would result in an increase
in greenhouse gases (i.e., carbon dioxide) released into the atmosphere. It also takes energy
and additional processing (and corresponding greenhouse gas release) to produce the
nitrogen fertilizer that would have to be applied to make up for the nitrogen that is removed.
Thus, nitrogen removal from recycled water intended for irrigation would have a doubly
negative impact on greenhouse gas emissions into the atmosphere.
Groundwater quality in the CSIP area due to recycled water use is protected via a RWQCB permit issued
to the Monterey County Water Resources Agency: Order No. 97-52 Recycled Water User Requirements
for CSIP. This permit states that the discharge shall not cause (1) a significant increase of mineral
constituent concentrations in underlying groundwater and (2) the concentration of chemicals in
A confined groundwater is an aquifer holding water under pressure by an impermeable geologic layer above it that
does not allow water to pass through.

Final EIR
3-26
September 2015
groundwater to exceed drinking water standards. Nitrate is considered to be a mineral and is regulated
under state and federal drinking water standards. Thus, based on these permit provisions and the
characteristics of the groundwater system in the CSIP area, there is no need to remove nitrogen in
recycled water used for irrigation.

Final EIR
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September 2015
3.7
MASTER RESPONSE #7: WELL DEVELOPMENT/CONSTRUCTION

WATER USE AND DISCHARGE
This master response addresses comments related to water use and discharge from development and
construction of the proposed injection wells, including the following: L-11, L-23, L-24, L-41, and N-12.
The use and discharge of groundwater during well construction (drilling) and well development represent
a one-time use of a relatively small amount of water, most of which will be recharged to the Seaside
Groundwater Basin. Water use and discharge methods relating to the injection well construction are
discussed in the Draft EIR (see pages 2-75 through 2-76 and 4.10-53 and 4.10-54; also, see Appendix L,
pages 41 through 47) and are summarized below.
During well drilling, water is circulated in the borehole and combined with inert substances such as
bentonite or gels to control density and viscosity (referred to as drilling fluids or mud). The purpose of the
drilling fluids is to lubricate the drilling bit and transport cuttings of the natural geologic sediments to the
surface. The amount of water required for each well will vary with the volume of the borehole and the
amount of fluid loss (recharge) to the formation during the drilling process. Well drilling for four deep
injection wells and four deep monitoring wells is expected to take approximately 5 days to complete for
each well and is expected to require about 2,500 gallons of water per day for a total of 12,500 gallons
(0.04 AF) of water per well for the deep injection wells. Water use will likely be less than one-half of that
amount for the four shallow vadose zone wells. Total construction water is estimated at less than 1 AF for
all project wells.
The source of the construction water for well drilling has not yet been identified, but it would likely be
pumped from local groundwater, conveyed from a local fire hydrant, or hauled in from an out-of-basin
source. After the well has been drilled, the drilling fluids will be flushed from the well and either disposed
offsite or partially applied to the local land surface in compliance with Regional Water Quality Control
Board (RWQCB) regulatory requirements. Water quality impact analyses of construction related
discharges are provided on pages 4.10-55 through 4.10-56 and 4.11-56 through 4.11-62 of the Draft EIR.
After the wells have been drilled and installed, each well will be developed in order to maximize well yield.
Well development consists of applying energy to the well-aquifer interface via both mechanical methods
such as swabbing and pumping methods. Well development activities are conducted typically on all
production and injection wells and have been performed on most, if not all, production wells in the
Seaside Groundwater Basin. Pumping for well development serves two purposes: (1) it repairs clogging
that may have occurred during drilling to restore the natural hydraulic properties, and (2) it alters the
physical characteristics of the aquifer near the wellbore so that water flows more freely into the well. This
process does not rely on an external water source and is accomplished by pumping local groundwater.
Almost all of the water pumped for well development can be conserved through land application, allowing
the water to infiltrate into the local permeable soils at the drill sites and to percolate back into the
groundwater system. This discharge method is considered to be a best management practice by the
RWQCB and has been used by most of the nearby production wells and nearby Monterey Peninsula
Water Management District Aquifer Storage and Recovery (ASR) wells drilled in the Seaside
Groundwater Basin. For the Proposed Project, such discharge will be conducted in compliance with a
RWQCB General Waste Discharge Requirement (WDR) order (General Order 2003-003) for Discharges
to Land with a Low Threat to Water Quality (including well development water). The Order requires
identification of any potential pollutants associated with the discharge and a monitoring program.
For the Proposed Project, well development will only apply to the four deep injection wells; vadose zone
wells are not subject to the same type of well development requirements as the deep injection wells.
Based on a reasonable assumption of the amount of time required to develop the four deep injection
wells, approximately 3,600,000 gallons (11 AF) will be pumped from each well during development (Draft
EIR, page 4.10-54).
The Seaside Basin Adjudication defines the de minimus amount for production as 5 AFY. While the
estimated amount for well production for the Proposed Project is 11 AF per well, unlike production, the

Final EIR
3-28
September 2015
groundwater pumped for development is not removed permanently from the groundwater basin. Through
land discharge, the development water would be returned to the basin through local infiltration and
percolation. In addition, any extra water pumped for aquifer testing and/or groundwater sampling would
also be percolated back into the groundwater basin. Given the permeable soils at the Proposed Project
site, only very small amounts of water would be lost to evaporation and actual consumption would be well
below the estimated de minimus amount (see pages 16 and 37 in Appendix L, Draft EIR).
The option of discharging the development water into the Seaside Golf Course reservoir was raised as
part of the public comments. Although technically feasible, that transport/conveyance would add
unnecessary energy use and associated greenhouse gas emissions, potentially contributing to climate
change impacts of the Proposed Project. It would also add to the Proposed Project cost. Because this
potential alternative component (discharge of well construction and development water to the Seaside
golf course reservoir) could result in increased environmental impacts and would not better meet the
project objective to produce reasonably-priced water, it is not considered further in this EIR. Other
production wells drilled in the Seaside Basin to date have used similar amounts of water during
construction and development and have successfully discharged development water to the land surface
for infiltration. Specifically, all of the ASR wells have employed this method (Joe Oliver, personal
communication, ongoing).
Naturally-occurring hydrogen sulfide (H2S) gas has been detected in low concentrations up to about
0.75 mg/L in several local Santa Margarita wells (Fugro, 1997). During construction of a nearby ASR
well (ASR 3) drilled near the Seaside Middle School, development water was conveyed offsite to another
discharge location due to the short-term odor problems associated with naturally-occurring H2S. The
Monterey Peninsula Water Management District monitors H2S in the ASR wellfields; detections to date
have been similar or lower than published values (Pueblo Water Resources, 2014). These concentrations
are not a health concern for drinking water or as an air pollutant, but can affect the taste and odor of the
10
water . The dissolved H2S can volatilize when development water is exposed at the surface. This
volatilization created a localized short-term nuisance for odor during discharge of development water at
the ASR 3 wellsite. The remote location of the Proposed Project injection well sites would eliminate this
public concern. Specifically, as shown and described in the Draft EIR on pages 4.3-26 through 4.3-28 and
pages 4.14-29 through 4.14-41, the nearest sensitive receptors to this site are residences located west of
General Jim Moore Boulevard at distances of 500 to 700 feet from the nearest proposed well sites and
about 1,200 feet from the proposed back-flush facility. The Seaside Middle School is located
approximately 700 feet northwest of the Injection Well Facilities site. Given the low H2S concentrations,
the distance to receptors, and the fact that nearby ASR 1 and ASR 2 wells (located within 300 feet of
residences in the City) did not experience problems with H2S odor nuisances during development water
discharge, there is no need to mitigate or treat development water at the Proposed Project site.
Nonetheless, monitoring for H2S gas will be part of the health and safety program during the well
construction field program and will be considered for the groundwater monitoring program to be
developed for the Proposed Project Engineering Report.
In response to this comment regarding H2S emissions, the text of the air quality impact analysis on page
4.3-28 for odors during construction has been revised to further explain the conclusion that odor impacts
during construction would be less than significant. See Chapter 5, Changes to the Draft EIR.
Development discharge composed of groundwater from the deeper aquifer will be recharged into and
primarily replenish the shallow aquifer. This would, in effect, transfer a small amount of groundwater from
the deeper aquifer to the shallow aquifer, which are hydraulically connected. As stated on page 4.10-19 of
the Draft EIR, most of the recharge to the Santa Margarita Aquifer is assumed to occur by leakage from
the overlying Paso Robles Aquifer, especially in areas where the lower part of the Paso Robles Aquifer is
relatively permeable. As discussed in the Draft EIR (pages 4.10-18 through 4.10-19), both aquifer
10
Taste and odor complaints have not occurred for the water quality of potable water that is sourced from the ASR
wells due to dilution by the injected water from the Carmel River system. Although odor issues can result from
release of H2S, H2S was only detected in low concentrations. Humans detect the odor of H2S at very low
concentrations, where there are no known health issues (U.S. Department of Labor, Occupational Safety and Health
Administration, Hydrogen Sulfide Information found at: https://www.osha.gov/SLTC/hydrogensulfide/hazards.html,
accessed August 2015).
Final EIR
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September 2015
systems have been over-drafted historically. The replenishment of the shallow aquifer will increase water
levels locally, which may increase local rates of vertical leakage into the deeper aquifer. Water remaining
in the shallow aquifer would be available for extraction by downgradient production wells, many of which
are at least partially screened in the Paso Robles Aquifer, including the nearby Paralta well. A recent
study (Yates, et al., 2005) estimated that approximately 15% of the production in the Paralta well is from
the shallow Paso Robles Aquifer. Although the percolating water will require a lag time (up to about 200
days) prior to reaching the water table, the transport time will be shortened with additional recharge and a
steady state condition of replenishment will occur at the water table. A recent field program documented
highly permeable sands throughout the vadose zone. Importantly, all of the percolating water will be
conserved in the basin.
This one-time movement of water pumped from the deeper Santa Margarita Aquifer into the shallow Paso
Robles Aquifer is too small to have a significant impact on deeper water levels according to the
significance criteria for groundwater impacts (see page 4.10-45 in the Draft EIR). Nonetheless, because
the Proposed Project has injection capacity for both aquifers, an equivalent amount of injection water
previously targeted for the shallow aquifer could be re-allocated to the deeper aquifer, if warranted.
Ongoing monitoring of water levels by the Monterey Peninsula Water Management District including
before, during, and after construction of the Proposed Project will allow for real-time adjustments to be
made to the amounts injected into either of the two Seaside Basin aquifers as needed.

Final EIR
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September 2015
3.8
MASTER RESPONSE #8: WELL MAINTENANCE

BACKFLUSH WATER AMOUNTS AND DISCHARGE
AND
This master response addresses comments related to amount and discharge of well maintenance and
backflush water, including the following: L-12, M-21, and N-4.
Operation of the Proposed Project will involve maintenance of the deep injection wells through a process
referred to as backflushing. Backflushing consists of periodic pumping of deep injection wells for the
purpose of maintaining injection capacity (see pages 35 to 38 in Appendix L of the Draft EIR). As
described in the Draft EIR, injection rates typically decrease because of numerous factors such as air
entrainment, filtration of suspended or organic material, bacterial growth, precipitates due to geochemical
reactions, swelling of clay colloids, dispersal of clay particles due to ion exchange, and/or mechanical
compaction of aquifer materials. Pumping the injection well (backflushing) reverses the flow in the well,
alters the geochemical environment, and dislodges clogging particles. In this manner, backflushing
repairs some of the wellbore damage that occurs over time and restores injection rates.
Optimal backflushing rates and schedules are best determined once the project is in operation and actual
injection rates can be monitored. Backflushing would be conducted only as needed, based on injection
rate monitoring. The project proponent would not backflush unnecessarily as it would result in additional
costs that could be avoided. Backflushing operations at the nearby Monterey Peninsula Water
Management District ASR wellfield include weekly pumping of each well for several hours at twice the
original injection rate. For planning purposes, these operations have been assumed to be applicable to
the Proposed Project injection wells. Assuming a maximum injection design of 1,000 gallons per minute
(gpm) for the deep injection wells, a maximum backflushing design of 2,000 gpm has been assumed.
This is considered a maximum amount of backflushing because the highly treated (purified recycled)
water injected by the Proposed Project will likely result in lower clogging rates than the water injected into
the ASR wells and may require less frequent backflushing. In addition, only two to three wells will operate
at any given time to accommodate the monthly injection schedule envisioned for the Proposed Project,
with at a minimum one back-up well (see Draft EIR Appendix L page 30; see also Draft EIR Table 2-9).
Only active wells will be subject to periodic backflushing. Further, if the Proposed Project wells are
injecting at rates lower than the design rate of 1,000 gpm (which will occur during most months), the
extraction for backflushing would be conducted a rate lower than the design rate of 2,000 gpm. To
estimate the maximum weekly amount for purposes of designing the backwash discharge facilities (i.e.,
percolation basins), the Proposed Project assumes up to four hours of weekly backflushing at up to 2,000
gpm, producing approximately 480,000 gallons (1.47 AF) per well per week (page 36, Appendix L, Draft
EIR). For three active wells, backflushing would produce a maximum of about 229 AFY, which is less than
but close to the amount of Proposed Project water allocated for the Paso Robles Aquifer for some years
(Table 2-9, Draft EIR).
Water pumped for backflushing would be discharged into a small surface basin constructed near the
injection wellfield as part of the Proposed Project. The basin would be located on the Aromas Sand,
which comprises the upper 300- to 400-feet of vadose zone beneath the Proposed Project Injection Well
Facilities area. This geologic unit was determined to be highly permeable in a recent nearby field
investigation (see page 16 in Appendix L). Water will be conveyed from the well to the basin and allowed
to infiltrate into the permeable site sediments and percolate to the water table. By allowing the water to
recharge, pumped water would be conserved in the groundwater basin. This approach for infiltration of
back-flushed water was conceptually approved by the SWRCB Division of Drinking Water (DDW) (June
2014).
Discharge of groundwater backflushed from the deeper aquifer will be recharged into and primarily
replenish the shallow aquifer. Although this removes a small amount of groundwater from the deeper
aquifer, replenishment of the shallow aquifer is beneficial to the basin. As discussed in the Draft EIR
(pages 4.10-18 to 4.10-19), both aquifer systems have been over-drafted historically. The replenishment
of the shallow aquifer will increase water levels locally, which may increase local rates of vertical leakage
into the deeper aquifer. Water remaining in the shallow Paso Robles Aquifer will be available for

Final EIR
3-31
September 2015
extraction by downgradient production wells that are at least partially screened in the Paso Robles
Aquifer, including the nearby Paralta well. A recent study (Yates, et al., 2005) estimated that
approximately 15% of the production in the Paralta well is from the shallow Paso Robles Aquifer.
Although the percolating water will require a lag time (up to about 200 days) prior to reaching the water
table, the transport time will be shortened with continued recharge and a steady state condition of
replenishment will occur at the water table. Importantly, all of the percolating water will be conserved in
the basin.
This transfer of water pumped from the deeper Santa Margarita Aquifer into the shallow Paso Robles
Aquifer is too small to have a significant impact on deeper water levels according to the groundwater
significance criteria (see page 4.10-45 in the Draft EIR). Except for the short amount of time when wells
are pumped, water will be continually injected into Proposed Project wells, which will more than
compensate for any short-term lowering of water levels.
Further, because the Proposed Project has injection capacity for both aquifers, an equivalent amount of
injection water previously targeted for the shallow aquifer could be re-allocated to the deeper aquifer, if
warranted. Ongoing monitoring of water levels by the Monterey Peninsula Water Management District will
allow for real-time adjustments to be made to the amounts injected into either of the two Seaside Basin
aquifers as needed.
The option of discharging the backflush water into the Seaside Golf Course reservoir was raised in a
comment on the Draft EIR. Although technically feasible, the transport/conveyance associated with this
concept would add unnecessary costs to the Proposed Project, as well as increase energy use,
potentially increasing the impact of greenhouse gas emissions. Further, if the water is not recharged back
into the basin, the well maintenance may complicate the amount of downgradient extraction planned as
part of Proposed Project operations and result in a reduced ability for the Proposed Project to meet its
objectives. An additional comment suggested re-routing the backflushed water through the sanitary sewer
to the RTP and AWT Facility then, after treatment, returning it to the Seaside Basin via injection as an
offsetting flow. This would amount to treating the same water twice, would require a substantial use of
energy to convey the water to and from the treatment plant (increasing impacts related to greenhouse gas
emissions and energy demand), and is not warranted given the planned operation of the Proposed
Project. Because these potential alternative components (discharge of well backflush water to the
Seaside golf course reservoir or back to the RTP) would result in increased environmental impacts and
would not better meet the project objective to produce reasonably-priced water, they are not considered
further in this EIR.
Finally, a comment suggested that the backflush water be considered for mitigation and treatment relating
to H2S gas. As previously discussed in Master Response #7: Well Development/Construction Water Use
and Discharge, naturally-occurring H2S gas has been detected in low concentrations up to about 0.75
mg/L in groundwater samples from local Santa Margarita wells (Fugro, 1997). These concentrations
could potentially result in a short-term odor when H2S volatilizes from groundwater in the back-flush
basin, but would result in a less-than-significant odor nuisance impact and would not create or increase
human health or ecological risks for the following reasons:
The injection well sites are located a minimum of 500 feet from any sensitive receptors (i.e., City
of Seaside residences). Most wells are more than 1,000 feet from potential receptors.
The backflush water will be composed mostly of the highly-treated purified recycled water that
does not contain H2S.
Nearby ASR wells are operated in the same manner related to routine well backflushing and
discharge of backflush water to a similar surface basin. These facilities are located in closer
proximity to residences in the City of Seaside with no complaints from nearby residents.
Given the initial low H2S concentrations, the distance to sensitive receptors (closest residences located
more than about 500 to 600 feet away), and the dilution of H2S with Proposed Project water, there is no
need to mitigate or treat development water at the Proposed Project site. Nonetheless, monitoring for H2S
gas will be part of the health and safety program during the well construction field program and will be
considered for the groundwater monitoring program to be developed for the Proposed Project
Engineering Report.
Final EIR
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September 2015
In response to this comment, the text of the air quality impact analysis on pages 4.3-30 through 4.3-31 for
odors during construction has been revised to further clarify the less than significant impacts of odors
during construction. See Chapter 5, Changes to the Draft EIR.

Final EIR
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September 2015
3.9
MASTER RESPONSE #9: FORT ORD ENVIRONMENTAL ISSUES

AT THE INJECTION WELL FACILITIES
This master response addresses comments related to Fort Ord environmental issues, including the
following: W-1 through W-15e.
3.9.1
Introduction
The Proposed Project is being developed, in part, on lands associated with the former Fort Ord Military
Base. In particular, the Injection Well Facilities area in the Seaside Groundwater Basin overlaps a small
portion of Site 39, a large area of the former base referred to as the Inland Ranges. Site 39 was defined
by the U.S. Army to address environmental investigations and cleanup associated with Inland Range
activities, including training for small arms and high explosive ordnance using rockets, artillery, mortars
and grenades.
Historical activities at Fort Ord, including Site 39, and environmental response actions are summarized in
the Draft EIR (Section 4.9 Hazardous Materials; see pages 4.9-12 through 4.9-16). Areas of groundwater
contamination from former Fort Ord activities are shown on Figure 4.9-3 of the Draft EIR; these areas are
outside the Seaside Groundwater Basin and several miles north of the Injection Well Facilities site (Figure
4.9-2 of the Draft EIR).
Activities related to Site 39 with a particular focus on the portions overlapping the Injection Well
Facilities site are discussed in a Recharge Impacts Assessment Report, provided in the Draft EIR as
Appendix L (see pages 13 and 14 in Appendix L, Draft EIR). The boundaries of Site 39 and the locations
of the Proposed Project injection wells are shown on Figure 4 in Appendix L. Groundwater quality in the
Proposed Project area of the Seaside Groundwater Basin is discussed in Section 7.3 of Appendix L (see
pages 56 to 74, Appendix L, Draft EIR). A field program conducted for the Proposed Project analyzed the
potential for soil and groundwater pollutants from Fort Ord activities to the Proposed Project area; results
of that program are presented in a separate report referenced in the Draft EIR (page 4.10-80, Todd
Groundwater, 2015) and summarized in the Draft EIR Appendix L (pages 65 to 67 and 72 to 77).
As discussed in the Draft EIR, the Injection Well Facilities site and vicinity is also located within the former
Fort Ord Seaside Munitions Response Area (pages 4.9-39 and 4.9-40) where the U.S. Army found
munitions and explosives of concern in the uppermost soil profiles as a result of former military
operations. The parcels associated with the Injection Well Facilities site have already been cleared of
unexploded ordnance (see page 4.9-40 of the Draft EIR). Nonetheless, Proposed Project construction
and operation on these parcels will be required to comply with the Fort Ord Reuse Authority Right-ofEntry process and the City of Seaside Municipal Code Chapter 15.34 (i.e., the Ordnance Remediation
District Regulations of the City, Ordinance 924) (page 4.9-40 of the Draft EIR). These regulations require
certain procedures with respect to Proposed Project construction and operation activities on Fort Ord
lands to ensure worker safety and to mitigate the potential for impacts from hazardous materials including
munitions and explosives. Finally, mitigation measures for impacts related to hazardous materials
releases during construction are provided in the Draft EIR (pages 4.9-37 through 4.9-39).
3.9.2
Site 39 Environmental Activities and Cleanup
Site 39 covers about 8,000 acres of upland, largely-undeveloped lands that are bounded by Eucalyptus
Road to the north, Barloy Canyon Road to the east, South Boundary Road to the south, and General Jim
Moore Boulevard to the west (Figure 4, Appendix L, Draft EIR). The site overlies portions of the Seaside
Groundwater Basin including most of the Northern Inland Subarea and the western half of the Laguna
Seca Subarea. Site 39 extends to the east and northeast, covering lands outside the Seaside
Groundwater Basin (compare Figures 1 and 4, Appendix L, Draft EIR).
The Proposed Project Injection Well Facilities site is located on the northwestern corner of Site 39 where
remediation has been completed to a level acceptable to the USEPA and California Department of Toxic
Final EIR
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September 2015
Substances Control (DTSC) for planned urban development (see proposed well locations and Site 39 on
Figure 4, Appendix L, Draft EIR). The property has been transferred to the Fort Ord Reuse Authority
(FORA), the organization responsible for planning, financing, and implementing the conversion of former
Fort Ord military lands to civilian activities, and is scheduled to be annexed into the City of Seaside. The
perimeter area identified for redevelopment is shown in blue on Figure 4 (Appendix L, Draft EIR).
Development associated with the Proposed Project involves the installation and operation of injection
wells and related facilities.
Site 39 contained at least 28 firing ranges that were used for small arms and high explosive ordnance
training using rockets, artillery, mortars and grenades. Range 18 (HA-18) and Range 19 (HA-19) are the
closest ranges to the Proposed Project Injection Well Facilities site (approximately 200 feet south and
east), with Range 48 (HA-48) about one-half mile to the northeast. The range fans for HA-18, HA-19, and
HA-48 (along with numerous other Site 39 range fans) are shown on Figure 4 (in Appendix L of the Draft
EIR). As shown on the figure, the proposed injection wells and facilities are on a perimeter road along the
outer edge of HA-18 and HA-19; proposed well sites are not located in the direction of firing (which was
toward the upland central area of Site 39).
Considerable munitions and explosives of concern (MECs) have been documented in various areas of
Site 39. The specific ordnance types include rounds from shotguns, mortars, M74 rockets, recoilless
rifles, aircraft, grenades, artillery, howitzers, mines, anti-tank weapons (bazookas), bombs, naval
ordnance, Bangalore torpedoes, C-4, TNT, military dynamite, and shaped charges. Functions for these
items included high explosives, heat generating, armor piercing, white phosphorous, smoke tracer,
illumination, incendiary, and photo flash devices. As a result of the spontaneous ignition of a white
phosphorous grenade in August 2009, an MEC sweep was conducted at Range 48. This surface sweep
removed MEC or MEC-like items using physical and demolition methods.
Since 1978, Fort Ord has been participating in the Installation Restoration Program (IRP). The purpose of
this program is to identify, investigate, and remediate any contamination from chemical use and
hazardous materials. There are no IRP sites in the vicinity of the Proposed Project Injection Well
Facilities, indicating a lack of heavy chemical usage in this area.
Initial environmental investigations began on Site 39 around 1984. Since that time, numerous
investigation and remediation activities have occurred. During these investigations, metals and various
compounds associated with explosives have been detected in soil, along with MEC. Soil remediation,
including MEC clearance, has been more extensive in areas targeted for redevelopment. As previously
mentioned, the portions of Site 39 targeted for redevelopment are shown in blue on Figure 4 (in Appendix
L, Draft EIR). No groundwater contamination has been documented on Site 39.
Remediation for HA-18 and HA-19 was considered complete in 2010 and consisted of soil removal
(largely for lead and copper) and clearance of potential MEC. A geophysical survey conducted in and
near the Proposed Project area (LFR and Weston, 2011) encountered only one MEC and one discarded
military munitions close to the utility corridor (also referred to as the Borderland Area along the Natural
Resource Management Area owned by the Bureau of Land Management) perimeter fence. As of 2014,
the U.S. Armys remedial activities located near the Proposed Project Injection Well Facilities site involved
habitat restoration (www.fortordcleanup.com). On-going contaminant investigations are being conducted
in other areas of Site 39 by the U.S. Army BRAC (2014) and others with oversight by the USEPA and
DTSC (EPA, 2015d).
Most of the lands targeted for redevelopment but requiring contaminant cleanup and investigation in the
City of Seaside and other jurisdictions, including the parcels associated with the Proposed Project wells
are now owned by the FORA. FORA has signed an Environmental Services Cooperative Agreement
(ESCA) with the U.S. Army to allow transfer of approximately nine parcels (3,340 acres) that were
associated with military munitions. Under ESCA, FORA is responsible for addressing munitions response
actions. FORA and their contractors are working with regulatory agencies including the DTSC and
USEPA to conduct additional munitions remediation activities, scheduled for completion in 2015.
Most of the ESCA parcels, including the area containing the Injection Well Facilities, will ultimately be
transferred to the City of Seaside. The ESCA parcels that contain the Injection Well Facilities were less
impacted by former Fort Ord activities than other areas of Site 39, and have already been cleared of MEC

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September 2015
and approved for future development. Nonetheless, the parcels remain within the former Fort Ord
Seaside Munitions Response Area and are subject to restrictions by the FORA Right-of-Entry process
and the Seaside Municipal Code regarding land disturbance and safety precautions regarding ordnance
(see pages 4.9-39 and 4.9-40 of the Draft EIR).
3.9.3
General Information on Fort Ord Environmental Investigation

and Remediation
To provide context for responding to comments in letter W regarding the appropriateness or adequacy of
the U.S. Armys investigation and remedial activities, the Fort Ord Superfund process is summarized
below. The U.S. Armys remedial actions have been conducted in compliance with Superfund
requirements and under USEPA (and other regulatory) oversight. The Draft EIR focuses on soil and
groundwater conditions in the vicinity of the Proposed Project and reports on field investigations and
technical analyses conducted specifically to support analysis of the Proposed Projects environmental
setting and potential impacts, not to provide overall former Fort Ord information.
The former Fort Ord Military base was designated a Superfund site in 1990 (i.e., it was placed on the
11
for cleanup). In compliance with Superfund requirements, potentially
National Priorities List
contaminated sites were identified and characterized during a Remedial Investigation (RI), and cleanup
alternatives were evaluated in an initial Feasibility Study (FS) (HLA, 1995) and subsequent studies.
These documents were prepared under regulatory agency oversight and have received public review.
Cleanup remedy decisions are documented in the USEPA Records of Decision (RODs). Regulatory
agencies overseeing the Fort Ord cleanup include USEPA (Region 9), DTSC, and the RWQCB. Remedial
actions are being, or have been implemented at the former Fort Ord sites in accordance with the RODs.
Individual sites included in Operable Units (OUs) either have or will have reports specific to those areas.
Such reports will be or have been placed in information repositories at specific locations as part of the
Fort Ord Administrative Record, a specialized file required by Superfund that contains all information
considered or relied on to select the cleanup remedy at the former Fort Ord sites. It also contains key
technical reports and administrative guidance for the cleanup of this National Priorities List cleanup site
(U.S. Army 2011a, 2014; U.S. Army Corps of Engineers, 2007 and 2012).
Since the RI study in 1995, additional base-wide environmental assessments have been conducted for
the former Fort Ord base (Fort Ord Cleanup, 2015). As with other Superfund sites, Fort Ord has been
divided into soil and groundwater cleanup sites including those requiring no action, interim action, and/or
remedial action. This is done to expedite site cleanup and closure under Superfund. Additionally, there
are three OUs that are designated as such due to the considerable investigations and ongoing remedial
actions to address groundwater contamination. Finally, there are Military Munitions Response Program
sites including munitions response sites (MRSs) that have been identified from archive searches,
interviews, and visual inspections.
Soil investigations continue to be conducted by the U.S. Army and FORA. These are periodically updated
in five-year reports (U.S. Army Corps of Engineers, 2007 and 2012). Regarding the concerns expressed
in comment letter W about the Parker Flats area that is the site of a proposed Monterey Horse Park,
Artillery Hill, and the Veterans Cemetery, it is noted that all of these areas are outside of the Injection
Well Facilities site and implementation of cleanup activities and proposed projects at those sites have no
impact on the Proposed Project. The U.S. Army is continuing to evaluate all additional lands in Site 39 as
the MEC are cleared from the site and will remediate soil contamination where present in concentrations
above established permissible levels.
11
The National Priorities List is the list of national priorities among the known releases or threatened releases of
hazardous substances, pollutants, or contaminants throughout the United States and its territories. The National
Priorities List is intended primarily to guide the USEPA in determining which sites warrant further investigation.

Final EIR
3-36
September 2015
3.9.4
Fort Ord Groundwater Contamination North of the Injection

Well Facilities Site
Groundwater contamination on the Fort Ord Superfund site is largely confined to areas in the northern
and northwestern portions of the Fort Ord facility, located several miles north of the Proposed Project
Injection Well Facilities site (see Figures 4.9-2 and 4.9-3, Draft EIR). Areas of contamination have been
designated as specific Sites and OUs for purposes of response and remedial actions. Four such areas,
OU-1, OU-2, Sites 2/12, and the OU Carbon Tetrachloride (OUCTP), contain groundwater plumes
contaminated with volatile organic compounds (VOCs). One VOC plume near the City of Marina has been
remediated with no further action required. For other areas, groundwater treatment systems have been
constructed and are currently operational. Contaminated groundwater at Fort Ord is not being used as a
drinking water source (Fort Ord Clean Up, 2015; Fort Ord BRAC, 2014; EPA, 2015d). There are no
groundwater impacts related to Fort Ord activities that have been identified close to the Injection Well
Facilities site and there is no risk that operation of the proposed wells will be impacted by, or will interfere
with the groundwater remediation to the north.
3.9.5
Chemical Risk and Analytical Methods
The USEPA requires adherence to specific regulations and procedures for Superfund and other
environmental investigations. These are governed by USEPA documents including SW-846 Methods
(EPA, 1986 (revised 2005), 2015a, 2015b, and 2015c). Additionally, California requires that
environmental testing laboratories conducting USEPA Methodology be approved under the
Environmental Testing and Accreditation Program (ELAP) and the National Environmental Laboratory
Accreditation Program (NELAP) (SWRCB, 2015a). For munitions or explosive chemical analysis, there
are two currently approved USEPA Methods: 8330A and 8330B (EPA, 2015c).
These approved USEPA analytical methods have been developed specifically to test for contaminants
related to explosives being released to soil or water. Documentation for USEPA Method 8330 states the
following:
This method is intended for the trace analysis of explosives and propellant residues by
high performance liquid chromatography (HPLC) using a dual wavelength UV detector.
This method provides a direct injection procedure for high level water samples, an
extraction procedure for soils and sediments as well as a low level method for the
extraction of water samples. The use of solid-phase extraction, Method 3535, has been
shown to provide equal or superior results and is preferred for low level aqueous
samples. All of these compounds are either used in the manufacture of explosives or
propellants, are impurities in their manufacture, or they are the degradation products of
compounds used for that purpose. Stock solutions for calibration are available through
several commercial vendors.
These methods allow for the detection of the munitions and explosive chemicals at very low levels. The
current reporting limit in soils for USEPA Method 8330 is 0.080 mg/kg (0.080 parts per million or 80 parts
per billion). For groundwater collected as part of the Proposed Project field program, monitoring and
production wells reporting limits for USEPA Method 8330B varied from 0.098 to 0.49 micrograms per liter
(g/L) or parts per billion (ppb) (see Appendix D in Appendix L of the Draft EIR).
Determination of chemical risk is commonly evaluated as part of a risk assessment that includes a
chemical exposure assessment; low-level concentrations of numerous different constituents cannot
simply be added together to produce a high level of risk (see EPA, 1986). For information on baseline
human health and ecological risks at the Fort Ord site, please refer to the final base-wide remedial
action/feasibility study (Fort Ord Cleanup, 2015). For the area of the Proposed Project, no chemicals have
been detected at sufficient concentrations in groundwater that would trigger an assessment for human
health or ecological risk.

Final EIR
3-37
September 2015
3.9.6
Field Program for the Proposed Project
In order to evaluate soil and groundwater conditions for the Proposed Project Injection Well Facilities,
MRWPCA conducted a hydrogeologic investigation and field program in 2013-2014 (Todd Groundwater,
2015; see reference on pages 4.10-70 and 4.10-80 in the Draft EIR). One objective of the field program
was to evaluate the potential for recharge from the Proposed Project to leach legacy Fort Ord chemicals
remaining in the soil, which may result in impacts to groundwater. In addition, the field program was
designed to evaluate the potential for the Proposed Project wells to be impacted by, or cause migration
of, any existing groundwater contamination from former Fort Ord activities. The field program is
summarized in Appendix L of the Draft EIR (pages 56 through 74).
The field program involved soil and groundwater sampling in the vicinity of the Injection Well Facilities
site, including geologic coring and sampling throughout the 400-feet thick vadose zone, installation of a
new monitoring well, and sampling and analysis of about 300 constituents in groundwater from six
monitoring and production wells surrounding the Injection Well Facilities site (including the new
monitoring well). Both upgradient and downgradient wells were included. Field methods, analyses, and
results associated with the field program were presented in a hydrogeological report (Todd Groundwater,
2015), which is referenced in the Draft EIR and summarized in Appendix L (pages 3, 57 to 58, 60 to 77,
especially pages 65 to 67 and 72 to 74 in Appendix L, Draft EIR). Analytical results of groundwater
sampling are summarized as Appendix D in Appendix L.
As presented in Appendix L (see Appendix D within Draft EIR Appendix L), groundwater samples were
analyzed for constituents with drinking water standards (under California Code of Regulations (CCR) Title
22) and numerous other constituents and parameters to characterize local groundwater (about 300 total
constituents, see Todd Groundwater, 2015). The analyses also included constituents of concern identified
with former Fort Ord activities including explosives, pesticides, and metals. These analyses included 137
individual chlorinated pesticides and polychlorinated biphenyl (PCB) using USEPA Method 508 (see
Table D-1D in Appendix L of the Draft EIR), nitrogen and phosphorous pesticides using USEPA Method
507 (Table D-1E), explosives using USEPA Method 8330B (Table D-1M), and CCR Title 22 metals with
USEPA Method 200.7, 200.8, 218.6, and 245.1 (Table D-1B). Additional analyses included chlorinated
acids (EPA Method 515.1), other organic compounds (diquat, entdothall and glyphosate by USEPA
Methods 549.2, 548.1, and 547, respectively), VOCs (EPA Method 524.2), semi-volatile organic
compounds (SVOCs) (EPA Method 525.2), haloacetic acids (EPA Method 522.2), pharmaceutical and
personal care products (PPCPs) (EPA Methods 1625M and 1694M), and radiogenic elements (various
analytical methods).
Regarding the constituents listed in attachments to comment letter W, the Draft EIR analyses included
almost all of the VOCs, explosives, and metals that were provided as an Attachment (Table 2) in the
comment letter. In addition, analyses included more than one-third of the SVOCs provided in Tables 1
and 2 in the comment letter. Because SVOCs are less mobile, analyses focused on key indicator SVOCs.
About one-half of the munitions chemicals on Tables 4 and 5 were included, along with many of the
pesticides on Table 6. The field program focused specifically on indicator constituents for which analytical
methodologies had been developed and approved by USEPA and constituents that are more soluble and
mobile in the environment, and were suitable for determining baseline groundwater chemistry and
potential impacts of the Proposed Project on Seaside Basin groundwater.
The analyses indicated that groundwater beneath the Proposed Project area had not been impacted by
Fort Ord constituents of concern. None of the pesticides were detected above method detection limits or
above maximum contaminant levels (MCLs) (for those constituents with established MCLs). None of the
explosives were detected above the Method Reporting Limit (MRL). One munitions compound, 2,6
dinitrotoluene (2,6-DNT) was detected at low levels (too low to be quantified by the laboratory) in three
groundwater samples, but was also detected in laboratory blank samples at similar or higher levels.
Laboratory blanks contain no groundwater and consist of in-laboratory water only. These blanks are used
for quality assurance and quality control (QA/QC) purposes, and detections in the blanks indicate
laboratory contaminants. This indicates that 2,6-DNT was inadvertently introduced into the samples in the
laboratory and does not occur in groundwater. Elevated turbidity in samples from two wells resulted in
some elevated concentrations of naturally-occurring metals and naturally-occurring radiogenic
constituents, but overall, data indicated that groundwater had not been contaminated. Except for these
Final EIR
3-38
September 2015
metals and radiogenic elements influenced by turbidity, all constituents met drinking water standards (see
Table 14, page 64, Appendix L of the Draft EIR). The samples with elevated turbidity indicate the
presence of small particles of aquifer material or pre-development solids that were entrained in the
groundwater sample during collection. These particles cause laboratory analysis interference by not
allowing measurement of the dissolved concentrations constituents in groundwater on which compliance
with water quality standards are based. Therefore, the concentrations of these metals and radiogenic
parameters are not representative of actual concentrations in groundwater.
The field program also evaluated the potential for the Proposed Project to leach any legacy chemicals
from the soil and vadose zone into groundwater (Todd Groundwater, 2015; summarized on pages 72 to
74 of Appendix L in the Draft EIR). Analytical data from soil core samples and detailed geochemical
modeling did not identify any significant impacts associated with this migration pathway.
Collectively, the results of the field program indicate that the Proposed Project will not impact, or be
impacted by, Fort Ord constituents of concern (pages 75 to 77, Appendix L, Draft EIR).
3.9.7
Proposed Project Mitigation and Monitoring
During the development and construction of the Proposed Project Injection Well Facilities, several
mitigation measures have been identified to mitigate Impact HH-2: Accidental Release of Hazardous
Materials during Construction pursuant to the Seaside Municipal Code. Mitigation Measure HH-2c
requires detailed descriptions of the disposal method for soil, the approved disposal site, and written
documentation that the disposal site will accept the waste. For areas within the Seaside Munitions
Response Area Site 39, the materials disposal plans will be reviewed and approved by FORA and the
City of Seaside. The contractor will develop a groundwater dewatering control and disposal plan
specifying how the contractor will remove, handle, and dispose of groundwater impacted by hazardous
substances in a safe, appropriate, and lawful manner. The plan must identify the dewatering locations at
which potential contaminated groundwater is likely to be encountered (if any), the method to analyze
groundwater for hazardous materials, and the appropriate treatment and/or disposal methods.
Regional groundwater monitoring is ongoing. The Monterey Peninsula Water Management District
conducts a basin-wide groundwater monitoring program with support from the Seaside Basin
Watermaster. Components of the program also serve as the monitoring program for the ASR Project.
Additionally, the California American Water Company (CalAm) monitors the water quality from their
production wells in the basin in compliance with drinking water requirements per CCR Title 22
requirements including analysis of organochlorine pesticides in groundwater.
Monitoring wells will be constructed as part of the Proposed Project and will provide ongoing monitoring in
the Seaside Groundwater Basin as described in the Draft EIR (page 2-74; see also pages 38 to 40 and
Figure 10 in Appendix L). These wells will also provide baseline data prior to project implementation. A
detailed monitoring program will be developed in compliance with the Final Groundwater Replenishment
Regulations (SWRCB, 2015b) and in coordination with the State Division of Drinking Water as part of the
required Engineering Report for the Proposed Project. For more detailed information on these regulatory
requirements, please see Appendix D, Pure Water Monterey Groundwater Replenishment Project Water
Quality Statutory and Regulatory Compliance Technical Report, in the Draft EIR.

Final EIR
3-39
September 2015
3.10 MASTER RESPONSE #10: MARINA COAST WATER DISTRICT

AND CITY OF MARINA WATER SUPPLY ISSUES
This master response addresses comments related to Marina Coast Water District and City of Marina
water supply issues, including the following: H-1, H-2, H-3, H-4, H-5, H-6, H-7, H-8, H-9, H-10, H-11, H12, H-13, H-14, H-15, H-16, H-17, H-18, H 19, H-20, H-21, H-42, H-49, H-51, H-58, H-60, H-62, H-64, H65, H-66, J-1, J-2, J-3, K-1, K-2, K-3, K-4, S-6, T-3, T-4, and T-5. This master response was prepared
with assistance from Schaaf & Wheeler Consulting Engineers and Perkins Coie, CEQA and water rights
attorneys for MRWPCA.
MRWPCA is in discussions with Marina Coast Water District (MCWD) regarding the potential use of the
RUWAP alignment for the proposed Product Water Conveyance Pipeline, and the terms and conditions
under which this alignment could be utilized. The potential environmental impacts of constructing the
pipeline in the RUWAP alignment are discussed in this EIR.
MRWPCA and the Monterey Peninsula Water Management District are seeking to achieve agreement
with all parties with potentially affected water rights through the Definitive Agreement or another
instrument, as contemplated in the 2014 Source Waters Memorandum of Understanding (Source Waters
MOU), to which MCWD is a party. It is expected that the Definitive Agreement will be executed after the
certification of the Final EIR.
In the 2014 Source Waters MOU, the parties specifically acknowledged (1) the 1989 Annexation
Agreement by which MCWD became a member entity of MRWPCA, (2) the 1992 Agreement between
MRWPCA and Monterey County Water Resources Agency, and its amendments in May 1995 (First
Amendment), February 1998 (Second Amendment), and May 2002 (Third Amendment).
As discussed in Draft EIR Section 4.18.3.4, MCWD has recycled water rights arising from the 1989
MRWPCA Annexation Agreement. MCWD does not question the EIRs characterization of its recycled
water right under this agreement. However, MCWD does have concerns about how the EIR addresses its
right to recycled water arising from two additional agreements: (1) a 2009 MOU between MRWPCA and
the MCWD relating to recycled water for the RUWAP MOU executed in June 2009; and (2) a Three-Way
MOU between MRWPCA, Monterey County Water Resources Agency, and MCWD relating to the
abandoned Regional Water Supply Program (2009 Three-Way MOU). MCWD also is concerned about its
obligations to the former Fort Ord. Each of these issues is discussed in greater detail below.
MCWD also inquired whether the Proposed Project is consistent with the Fort Ord Reuse Plan. The 1997
Fort Ord Base Reuse Plan was not specific on the source for augmented water supply, but the FORA
Board approved the RUWAP hybrid alternative in 2005, and later allocated recycled water supply from
the RUWAP to the member jurisdictions (2007). As discussed in this master response, the MCWD
recycled water rights discussed in this EIR address both the City and the FORA assumptions for recycled
water use. The Proposed Projects implementation would not affect the ability of MCWD to implement an
augmentation project for its customers, and thus the Proposed Project would be consistent with the Fort
Ord Reuse Plan.
The City of Marina has inquired into the Proposed Projects potential impacts on the water allocations for
the City of Marina and the former Fort Ord (herein referred to as the Ord Community, consistent with
MCWDs documents), and has asked whether there will be a mechanism to protect the City of Marinas
and the Ord Communitys allotment from assignment to another party. Both the City of Marina and Ord
Community are served by the MCWD, and thus the water available to these areas depends on the water
received by MCWD. MRWPCA and the Monterey Peninsula Water Management District do not control
how MCWD distributes recycled water it receives under the 1989 Annexation Agreement, the 1996
Annexation Agreement, and the RUWAP MOU.

Final EIR
3-40
September 2015
3.10.1
RUWAP MOU
MCWD suggests that the Draft EIR does not acknowledge MCWDs right to recycled water under the
RUWAP MOU. While the Draft EIR acknowledges these rights (see Draft EIR at 4.18-21 to 4.18-22),
language has been added to provide additional detail. See Chapter 5, Changes to the Draft EIR. MCWD
and MRWPCA entered into a MOU in 2009 providing that MRWPCA and MCWD would supply up to
1,427 AFY to the RUWAP. For the summer months of May through August, MRWPCA would commit 650
AFY of recycled water from MRWPCA entitlements for the RUWAP. From April to September, MCWD
would commit an additional 300 AFY from its entitlements for the RUWAP, for a total of 950 AFY of
recycled water in the summer that would be available to the RUWAP Recycled Water Project should that
project be completed. The recycled waters allotted to MCWD are a portion of MRWPCAs entitlements to
recycled water in the Third Amendment of the 1992 Agreement between MRWPCA and Monterey Count
Water Resources Agency (Third Amendment).
Certain parties have disputed the validity of the Third Amendment. If the Third Amendment, or portions of
the Third Amendment, were to be found invalid, the assignment of MRWPCAs recycled waters to MCWD
in the RUWAP MOU may also be found to be invalid. However, for purposes of the analysis in this EIR,
MRWPCA assumes the Third Amendment is valid and enforceable and that MCWD has an existing right
to 650 AFY of recycled water from MRWPCA in the months of May through August.
The EIR recognizes that the RUWAP Recycled Water Project is a reasonably foreseeable future project
for purposes of its cumulative impacts analysis, rather than as an existing condition or a future
background condition. This determination in the EIR considers that the RUWAP MOU entitles MCWD to
the recycled water addressed in that MOU only if the RUWAP improvements are completed and MCWD
pays the capital and operational costs including loan repayment to the U.S. Bureau of Reclamation for
construction of the SVRP. The RUWAP MOU does not require MRWPCA or any other entity to contribute
to the cost of completing such improvements. Because the RUWAP Recycled Water Project has not been
finished and there does not appear to be a plan for completing the RUWAP Recycled Water Project
12
improvements in the near term. Specifically, no budget exists for construction, recycled water
distribution system improvements are not funded, and user agreements have not been drafted or signed.
Thus, the EIR analyzes the RUWAP Recycled Water Project as a cumulative project.
As shown in Table 3-D, the Proposed Project would not prevent MRWPCA from delivering to MCWD the
full amount of water contemplated by the 1989 MRWPCA Annexation Agreement and the RUWAP MOU.
If MCWD completes construction of the RUWAP Recycled Water Project, pays for the capital, operational,
and loan repayment costs, and is then able to exercise its rights under these agreements, less of the
existing quantity of recycled water would be available for irrigation through CSIP during some months.
This effect would result from MCWDs exercise of its senior water right regardless of whether the
Proposed Project is constructed and implemented. At this time, MCWDs urban irrigation customer
demands are estimated to be approximately 360 AFY between April and September of each year and 540
AF total annually (MCWD, personal communication, Andy Sterbenz with Bill Kocher, July 2015). Table 3D show this short-term interim demand and its effects on average annual recycled water deliveries to the
CSIP distribution system based on a month-by-month analysis of supplies and demands data. Similarly,
Table 3-D shows the effect on availability of water to the growers through the CSIP should MCWD
ultimately exercise the full amount of its rights under its existing agreements.
It is possible that a modification of the amount of recycled water committed to MCWD could be made in
connection with the Definitive Agreement contemplated by the 2014 Source Waters MOU. Both MCWD
and MRWPCA are parties to the Source Waters MOU. The Source Waters MOU states that the Definitive
Agreement may result in an Amendment to the 1992 Agreement and the amendments thereto and that
any remaining applicable terms of the Third Amendment would be restated in the Definitive Agreement. A
change in the terms of the Third Amendment could necessitate a change in the terms of the RUWAP
MOU.
MRWPCA and the Water Management District may pursue a shared easement to accommodate the
Proposed Project Product Water Conveyance pipeline in some portions of the RUWAP alignment while
12
The RUWAP recycled water project is not included for funding in MCWDs 5-year Capital Improvement Program.

Final EIR
3-41
September 2015
also leaving space for completion of the planned separate RUWAP pipeline. It is also possible that in the
future these agencies may decide to jointly use a single pipeline for both the Project Water Conveyance
and the RUWAP Recycled Water Project by Marina Coast Water District.
Joint use of a shared pipeline is beyond the scope of the Proposed Project. Pursuant to the State Water
Resources Control Board Groundwater Replenishment Regulations (June 2014), recycled water used for
subsurface application must undergo advanced treatment (e.g., beyond tertiary treatment) such as that
proposed for the AWT Facility. Thus, tertiary recycled water and purified recycled water cannot mix
together in the same pipeline without compromising the regulatory compliance aspects of the
groundwater replenishment component of the Proposed Project. Joint use of the Product Water
Conveyance pipeline with the RUWAP Recycled Water Project would necessitate that MCWD receive
purified recycled water from the proposed AWT Facility (taking into consideration a 19% loss of water that
occurs through the reverse osmosis system as part of the separation process; this process loss is called
reject) rather than tertiary treated recycled water from the SVRP (which does not result in a reject loss in
its process). In the event that the agencies choose to explore this option in the future, it is confirmed that
there would be sufficient source water to accommodate this potential configuration. However, this
configuration could reduce total availability of recycled water by up to 270 AFY (with 180 AF of the total
occurring in April through September) compared to scenarios in which either the Coastal Alignment or a
separate parallel pipeline following the RUWAP alignment were used for Product Water Conveyance for
the Proposed Projects objectives. Table 3-D shows the total amount of recycled water that would be
available to MCWD and the growers served by CSIP if (a) a single pipeline were used both for the
RUWAP and Product Water Conveyance (see Shared Pipeline Scenarios columns); and (b) MCWD
urban irrigators receive the full amount of recycled water contemplated by the 1989 Annexation
Agreement and the RUWAP MOU (see Product Water = RUWAP MOU Quantities columns). Under this
scenario, MCWD would receive its full allocation but approximately 220 AFY less recycled water would be
available to CSIP compared to the Separate Pipeline scenarios depicted in Table 3-D, in which the
Product Water Conveyance pipeline is separate from the RUWAP pipeline.
Table 3-D also shows the total amount of recycled water that would be available to MCWD and the
growers served by the CSIP if (a) a single pipeline were used both for the RUWAP and Product Water
Conveyance (see Shared Pipeline Scenarios columns); and (b) the amount of water contemplated by
the 1989 Annexation Agreement and RUWAP MOU were reduced to account for the approximately 19%
reverse osmosis reject loss that would occur at the AWT Facility (See AWT Influent Flows = 2009
RUWAP MOU Quantities columns). Under this scenario, MCWD would receive approximately 19% (or
270 AFY, with 180 AF in April through September) less water, but the same amount of recycled water
would be available to CSIP as compared to the scenario where MCWD receives its full allocation of
treated recycled water from the SVRP using a separate pipeline.
If a single pipeline were used both for the RUWAP and the Product Water Conveyance, there may be
upgrades needed to the system, such as modifications to the Advanced Water Treatment Facility. Any
such modification would be analyzed in a separate CEQA process if such a project were proposed. In
addition, MCWD and MRWPCA would need to enter into an agreement for completion and joint use of the
RUWAP pipeline. Through that agreement, the parties may also agree to reduce the amount of water
committed to MCWD under the RUWAP MOU. Alternatively, the parties may agree to commit additional
secondary wastewater as influent to the AWT Facility to enable the AWT Facility to deliver up to the
MCWD full allotment of planned recycled water demands (and no more than the RTP receives as influent
from MCWD).
3.10.2
2009 Three-Way MOU
The Draft EIR does not refer to the 2009 Three-Way MOU between MRWPCA, MCWD, and MCWRA
because the 2009 Three-Way MOU recitals provide that the underlying basis for the MOU was the
Regional Water Supply Program (also known as the Regional Desalination Project), and that the MOU
was focused on only planning-level activities relating to the Regional Desalination Project. The planning
process for this project was terminated (California Public Utilities Commission Decision 12-07-008).
Because the basis for the 2009 Three-Way MOU no longer exists, the 2009 Three-Way MOU can no
longer serve its intended purpose and is thus without further force and effect. MCWD is therefore not
Final EIR
3-42
September 2015
entitled to additional recycled water from MRWPCA or MCWRA under the 2009 Three-Way MOU, and
thus the Three-Way MOU need not be discussed in this EIR.
3.10.3
Agreements between MCWD and Fort Ord Reuse Authority
MCWD is concerned that changes to its recycled water rights could impact its ability to deliver recycled
water as obligated under agreements between MCWD and FORA for water demands within the former
Fort Ord area, such as Monterey Downs and Monterey Horse Park. At the core of MCWDs concerns is
the viability of its right to recycled water under the RUWAP MOU. MRWPCAs intentions regarding the
RUWAP MOU are discussed above.
To the extent that MCWD will develop other projects to make up for any shortfall in its obligations to
FORA, those projects are speculative at this point and are not impacts of the Proposed Project. Thus,
these speculative future projects need not be evaluated in this EIR.

Final EIR
3-43
September 2015
Table 3-D.
Estimated Annual Recycled Water Yields Under Various Scenarios of MCWD Demand and Pipelines
Stwed Pipeline Scent~los
No PI'OI)OlWid Pl'ojolt
hfU~
wlttl l~Tem
...
"-os--ed~oje(twith MI)MCWO
M;\VOUMINQt
"'
VnrTypoc (Notes 4 & S)
~~to September
Nror'miVv:tt b\lid:nt rtwrVe
N'ormaY.,.'d rHer~ 1\111 ~

Dr~ln )'N"f u-.e re~ fotCSlP
WAP IO(.SIP
S\11\Pto
SVI\Pto
(MOll' t)
M(\\11
(_'j!P
-- r--l Q.)IO-- ;;!;.,
~Ar~nu.l
N'orma~'d buU inc r~e
Hot tNY.."' ~e full (Note 61

o..WQht
use res.uve forCStP
10,460
..,,.,.
1 4?0
.,.
l,.t.27
1 "
9~-40
.....
1>100
""'~
..
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,.~(YO(I
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...
1,7.55
""'
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(~j... t Q<t
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"""
l.7SS
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.,
1&,.410
uoo
2'-100
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Sep., te Plpel tnes Sun..rlos
Shott>-ti!'IIIIMCWO Product W1t~ Ro~ Awrlnfl""'"t Row

~ t~m
2009 Rt.mAP MOU !009 RUWAP MOU Short.aoem.'.~ MCWOOremilncl
Demand (Note kl
(tlote 111)
<).l.llntttt~(Hote 21)
C)Jantiti C\ (Note 2b)
(r~te2t)
""
A'ltrto
SVRP to
A'N1to
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'"'
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..
,""
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u ,no
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no
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360
1Ml0
,....,
1.427
17.150
16,110
US6
1,156
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1-;:;o-
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,,..
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13110
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".... ... ,.,.. ..,
""
1'-'10
17,950
"" ' ""

""
SVII/'to
1 10
11,.630
U.fi:10
.... -l'*-t-'....
1.427 I IU10
17,S30
10:no
20.<190
11. Tl!k .Kenartos ~ MCWO loll"termd-Nn~ncls f 1-CCOidlnu wittl1he appl'O'>..cl R\1\Yo\P titee~foed W1ter P~t~il!ct a f14 2CIOtRtJ'I/A1 MOU) 1.nd tfle rewltft.t~fd S:vRPd'"''"'rlestoCSIPv.lttlout the ProPOW'd Project ~eMtd.
illiJ "k.I!'M$ the $\'liP t.tCidifiCitiOnl VI'Ould be ~r'11td " Pill't of tllot JltJWAP. TMSVRPModfk#tjflf'$ ~ 1'0! J'tf OfWI bl.liit tw! ti'IVI ~ 01$0 0 ~ cf !MPJ'OPf>#d Jlt'Ojf(t , 8eCflo!Je ttltre r.'OI.Ad be 110 4~ ttit!M \llldtr
til~ e~, al f\Ofi'NI~ ytltdtlrtlt~i ....-ould M tlle ume.
lb. This 'l!nrlo~o-.o.-. MCWD*rtttrm6enwndsandthe ape<ttd SVIU'6el;teiiu to (SIP th-11,.,.. oc:CI.It1ill~ln the fnt 2 vu... oloperWon of'IMGWR Prcjl!d. with a pipeline sh.aredv.i!hltU'NAP. The uti!N(ed f.tCWOdotma~ s
~don ~t iiJC~Oilltfl.lor;i tfw: AUWAP pipdinedprnellt spe<ificaUy. foe Sqonte ilr\d ~r't GoiCouf'Sd..CSUM6sp(lrtS rttlcls, eriC! Ma!Wia Ke'!aflli Strttt1Cipt:I(MC:WO, l015J..
lc. TIIk \CtnlfiC)~'I tte\VO drlortttrmdtft'll.tlds Jfld t h r.w ii\1 $VRJ>dtll#tdt$ toCSIP 11u'! ml&lltOOCI.f'Nlthln til flm 2 yeJrs of Q9t~tlon of tht <iWR ProtKt 't.'CitH~ratt pl.,_h i f.ot Al.IWAP and ff"opoMld Ptoftct. The
utfmattd MCWOdtMI.nd I$ ~td on t:l.thlcunomen aloflt: 1ht IUJWAJ' pipelee l>li(IIMtflt ~aflca!ly, IOf 61)'onet and &ladhorst Gol Courses,CSUMB spons fields, a ~ Mai'Wo Htlehts meetwope$ \MCWO,lOl!ij.
2. This sce-narto Nws the upectl!d d etveryto C'."Odll\lll'rlptlon tlltou.JII tsll"pkn: ptaMPedfproposed 6el'tlllndsftom MCWOwllen adequltew.st~e.riflfbi.<Jfrom MC\Y() ut sent to R1Pto j)fOduce the full 2009RVWIIU' MOU
1l~rnent (Jssum1ncsl!u~ plpeiMfotRUWAI>a~ PTCiposed ProjQ. U~et this soenario, 1,'1(.1 MY of MCWO-s.te..."ater Inflows needed foot t.'t:W06t!N~s ~ 1,421 ~due to 1~ 0'1 tre.atedWI1U bt!ll(dlsdllf(ed as revetM
OJMCniJ ooncelltrttll' to tt.e ouctn. Spe(ltalty;
.......
...
A.Wf fktowi
P f'*-:1
An.$0' ('""'
AnSf:'
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.,.,.
{notu)
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wNKA
"'~
> .
un
~-
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m
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'"' ""
v
.wn f;Jdll!vhocluttw.." ~ ~ o~
J 1fJ
I( Uldn t lrio. ...fnllt~ 1~1$JI.WI\td dftNi:ty IO Uln~l iflftJotlol\ ttltOv(tl CSI P pll.lll)llifllltd/~dtMWIIi$WIItn 9'SOAFY~Mte\l...teth1\owsforc.m M0A1)1f41 M ilt to ATP. llndtt ttlI$ $Notfoo,l,4l7 AFY of $0trC* 11\'Utt Is net-dtd fot
MCWOclemanlbof J...U MY bt<aU51!tllls uMrio af.S.On.u MC'At>~ted ....-.tl!t' tomes trom ttle SI/It~and kdtltlver< UJI~~g$epame pipellnu.
4. Undtttlll009 iiU\\1.\P,_.tOU, MCWO COIM'IIt'ltdlO provide 300MYfroMJ.ptil toSI!ptef'l'lber whlle MR'NPC.\COI'M'IItred fO (lt(l'llde 650AFY ftOM May10~. Tiles. ealw~Uii)IIJ &HVMtf!rof950NY$j'lt tad INOS$Aptl1tOStJI'Itf'tbet
tncl1.hlt MCVItrs lOOAIY commll.meMwou!d be used fn Aprihnd SePt'trnber.
!>.. Sin~tbtCSIP9{Uem ...,ubuU\, CSIP !trlptors have abo tec.eiWd S141Pivfl'om CSIPWP9'1ctnel'olal ~'ltetwtlls (openttdbyMRWPCJ.) and, Slt\Ct 1.00'), hom the Salinn Rlwf Divtrsion fv.illty~IIDF) . ~ sourmwo...td COfltifl~~t
to be av..table h tbe:hAu~ uncler al sc:Mario1 (Lt .,with no dta~ d~.~t to RUWII# nor thl!' P'roi)OSC.d Ptojed.). Tile S11:0f Is e:xPI!'(ttd to ~~t01116tapprwlrr.ltet( 1.0:2.1 AFVtoCSIP ~~on tile full lli!Aorlttl record of nlllbilty {l s--.'tlr
11\'traa.t.l~tll.~ lOll). 6e(:IIIM t!1.t ~ed y!eldJ tOCSII' from SAOfwou'd IIQII bt afftcttd b-itll@ Pf~d ~not by Rt.AVAP,tiiHeyaddS 1,_ nee lnclt.lkd In 111t tocalt. Sln&ltdtOUCIIt~lt frcmSRQFtoCSIP(lOU) w.s &.C$4
J.FY; how~vtt.ln muA:Iplt dt01.9!t ~rs f\0\lfl!tr lsel(ptCitdto be 11\'l llbltftom tilt SRllf ~dtmon$tnttd byy~ rt l014and l Ol!IJ.

Final EIR
3-44
September 2015
3.11 MASTER
RESPONSE
#11:
PROPOSED
PROJECTS
RELATIONSHIP TO THE PROPOSED MONTEREY PENINSULA
WATER SUPPLY PROJECT
This master response addresses comments related to the Proposed Projects relationship to the
Monterey Peninsula Water Supply Project, including the following: L-21, P-10, P-11, P-12, S-13, S-14, T2, V-6, and V-7.
3.11.1
Overview of the Proposed Monterey Peninsula Water Supply

Project
As described on pages 2-11 through 2-12 of the Draft EIR, CalAm, working with local agencies, has
proposed construction and operation of a CalAm-owned and operated desalination project (known as the
Proposed Monterey Peninsula Water Supply Project (Proposed MPWSP). CalAm is an investor-owned
utility that is regulated by the California Public Utilities Commission (CPUC); the Proposed MPWSP is
identified as CPUC Application A.12-04-019. The Proposed MPWSP is designed to provide the
replacement water CalAm needs to comply with the State Water Resources Control Board Cease and
Desist Order and the Seaside Groundwater Basin Adjudication, and to satisfy forecasted demand.
In its application to the CPUC for approval of the Proposed MPWSP, CalAm proposed a three-pronged
approach. The three prongs, or components, consist of: (1) desalination, (2) groundwater replenishment,
and (3) ASR. The CPUC is the CEQA lead agency for the Proposed MPWSP, and published a Notice of
Preparation of an EIR in October 2012. The Notice of Preparation identified Proposed MPWSP facilities
and improvements, including: a seawater intake system; a 9 mgd desalination plant; desalinated water
storage and conveyance facilities; and expanded ASR facilities.
The Proposed MPWSP Notice of Preparation also explains that if the groundwater replenishment project
component of the Proposed Project is timely approved and implemented, CalAms proposed desalination
plant would be a smaller, a 5.4 mgd plant and CalAm would enter into an agreement to purchase 3,500
AFY of purified recycled water from the Proposed GWR Project. After publication of the Notice of
Preparation, CalAm stated that, to fully satisfy their Proposed MPWSP objectives, the full-sized
desalination plant would need to be a 9.6 mgd plant, and the smaller desalination plant, proposed to be
constructed if the MRWPCA Proposed Project is implemented, would need to be a 6.4 mgd plant.
The Proposed MPWSP Draft EIR was released in April 2015 and it addresses both the proposed 9.6 mgd
desalination plant and a proposed MPWSP Variant, which assumes a 6.4 mgd desalination plant and
purchase of 3,500 AFY of purified recycled water for groundwater replenishment from the Proposed
Project.
3.11.2
Relationship of the Proposed Project to the Proposed MPWSP
The Proposed Project is designed to provide part of the replacement water needed for CalAm to comply
with the Cease and Desist Order and the Seaside Groundwater Basin Adjudication. The Proposed Project
would not produce all of the needed replacement water; the primary goal of the Proposed Project is to
produce 3,500 AFY and deliver the water to the Seaside Basin where CalAm can extract the same
amount and also reduce its Carmel River diversions by that same amount. The Proposed Project could
provide this quantity of replacement water even if the CPUC denies CalAms application to construct and
operate a desalination plant. In other words, the Proposed Project could accomplish its objective, and be
useful in reducing Carmel River diversions, independent from approval of CalAms proposed desalination
plant.

Final EIR
3-45
September 2015
While the Proposed Project could proceed as an independent project, the Proposed GWR Project is
related to CalAms project in that the groundwater replenishment component of the Proposed Project
would reduce the size of CalAms proposed desalination plant if such plant is approved by the CPUC. As
explained in the preceding section, if the Proposed Projects groundwater replenishment component is
timely approved and implemented, CalAms proposed desalination plant would be reduced in size from a
9.6 mgd plant to a 6.4 mgd plant.
3.11.3
Proposed Project Components in Common with the Proposed

MPWSP
The Draft EIR on page 2-78 describes how both the Proposed GWR Project and the Proposed MPWSP
Project include some of the same CalAm Distribution System components (referred to as the Transfer
and Monterey pipelines in this EIR).
CalAm would use existing Seaside Groundwater Basin wells, in addition to existing treatment facilities
and existing pipelines in its Monterey District Service area, to recover, treat and deliver potable water
from the Seaside Groundwater Basin to its customers; the water that CalAm extracts would include a
blend of the Proposed GWR Project purified recycled water along with other groundwater from the Basin.
In addition to using existing wells, treatment facilities, and pipelines, CalAm would need to construct
additional pipeline segments to deliver the full amount of extracted water to its customers. Because the
CalAm system was initially built to deliver water from Carmel Valley to the Monterey Peninsula cities, a
hydraulic trough currently exists in the CalAm peninsula distribution system that prevents water delivery at
adequate quantities from the Seaside Groundwater Basin to most of Monterey, and all of Pacific Grove,
Pebble Beach, Carmel Valley, and the City of Carmel areas. The hydraulic trough is an area of the CalAm
distribution system with very small pipe diameters and very low elevation such that the required high flow
rates of water and high pressures needed to convey water from the north between two pressure zones of
the system cannot be achieved with the current infrastructure. This system deficiency would need to be
addressed regardless of whether the Proposed GWR Project is implemented by itself, the Proposed
MPWSP with the full-size desalination plant is implemented without the Proposed GWR Project, or the
variant to the Proposed MPWSP that includes both a smaller desalination plant and the Proposed GWR
Project is implemented. Under all three of these scenarios, for CalAm to be able to deliver increased
quantities of water extracted from the Seaside Groundwater Basin to its customers, the company would
need to construct pipeline improvements to bridge this trough.
As part of the Proposed MPWSP, CalAm is proposing to construct two new pipelines--the Transfer and
Monterey pipelines--to bridge this trough. In addition, CalAm is proposing to construct a new Terminal
Reservoir to add storage and pressure equalization within the water supply system; however, MRWPCA
understands that the Terminal Reservoir would not be needed if the Proposed GWR Project is
implemented by itself. Therefore, the Transfer and Monterey Pipelines are the only CalAm Distribution
System components proposed to be built by CalAm and included in the analysis of impacts of the
Proposed GWR Project.
While MRWPCA would not be approving, constructing or operating the CalAm distribution improvements,
the improvements would be needed for full operation of a stand-alone Proposed GWR Project, and
therefore they are included in the environmental evaluation of the Proposed GWR Project. These same
CalAm improvements are also included in the Proposed MPWSP as a component of that project. The
proposed alignment of these pipelines is shown in Figures 2-38, CalAm Distribution System Pipeline:
13
Eastern Terminus, and 2-39, CalAm Distribution System Pipeline: Western Terminus of the Draft EIR.
Chapter 6 of the Draft EIR (see pages 6-36 to 6-44) also describes and analyzes alternatives to the
proposed CalAm Distribution System Pipeline alignments presented in Chapter 2 and analyzed in
Chapter 4.
13
Alternative routes for the Monterey and Transfer Pipelines have been submitted to the CPUC by CalAm. The
alternative routes are addressed in this EIR within Chapter 6, Alternatives to the Proposed Project, of the Draft EIR
on pages 6-36 to 6-44.
Final EIR
3-46
September 2015
3.11.4
Treatment of the Proposed MPWSP in this EIR
This EIR assumes that the Proposed GWR Project would be built with or without implementation of the
desalination plant that is part of the Proposed MPWSP. If the Proposed GWR Project is built, then a
desalination plant constructed by CalAm would be built at the smaller size of 6.4 mgd rather than the
larger 9.6 mgd size that also is undergoing evaluation in the Proposed MPWSP EIR. The Proposed GWR
Project EIR, therefore, considers the version of the Proposed MPWSP that includes the smaller (6.4 mgd)
CalAm desalination plant as a cumulative project.
CalAms CPUC Application A.12-04-019 calls the project scenario that includes a smaller (6.4 mgd)
desalination plant scenario the MPWSP Variant, and states that the smaller desalination plant along
with the Proposed GWR Project would be capable of meeting the total demand of 15,296 AFY for
CalAms Monterey District service area (Monterey District) as well as all other project objectives for the
Proposed MPWSP. Under the Proposed MPWSP Variant, the total water produced by the CalAm
desalination plant would be 6,252 AFY, compared to 9,752 AFY if CalAm were to construct the larger
desalination plant. The Proposed MPWSP Variant would require fewer subsurface slant wells (seven
wells) for the seawater intake system as compared to the larger desalination plant that requires ten wells.
Notably, both the Proposed MPWSP (with a 6.4 mgd desalination plant) and the Proposed GWR Project
include the CalAm Distribution System: Monterey and Transfer Pipelines. The CalAm Distribution System
Pipelines are needed to supply water from the Seaside Basin to CalAm customers whether either the
Proposed MPWSP or the Proposed GWR Project is implemented, and also is needed if both the
Proposed MPWSP (with a 6.4 mgd desalination plant) and the Proposed GWR Project is implemented. A
summary of the facilities required to be built and operated for the MPWSP Variant are provided in
Appendix Y of the Draft EIR.
Regardless of the size of the desalination plant, the Proposed MPWSP would also include improvements
to existing Seaside Groundwater Basin ASR system facilities to enable CalAm to inject desalinated
product water into the groundwater basin for subsequent extraction and distribution to customers.
CalAms proposed improvements to the ASR system would also increase the efficiency and long-term
reliability of the ASR system for injecting Carmel River water into the groundwater basin. Approximately
1,300 AFY of water would be produced by the ASR system according to the CPUC and CalAm
documents. The Proposed MPWSP also includes over 30 miles of pipelines, two pump stations, and
water storage tanks. The Proposed MPWSP area extends approximately 14 miles, from the proposed
CalAm desalination plant site located in unincorporated Monterey County in the north to the western
terminus of the proposed Monterey Pipeline in the City of Pacific Grove, and east approximately 8 miles
to the unincorporated community of Hidden Hills along Highway 68. See Figure 4.1-2, Proposed MPWSP
Location Map, in the Draft EIR for Proposed MPWSP facilities shown overlain with the GWR Facilities that
would be built if the Proposed MPWSP with a 6.4 mgd desalination plant were built.
Cumulative analyses within each resource topic section of Chapter 4 of the Proposed GWR Project Draft
EIR address a cumulative scenario of combined implementation of the Proposed GWR Project plus the
Proposed MPWSP (with 6.4 mgd desalination plant). The cumulative sections also include an analysis of
the Proposed GWR Project combined with all other cumulative projects listed in Table 4.1-2 as applicable
to each resource area and geographic area of study.

Final EIR
3-47
September 2015
3.12 MASTER RESPONSE #12: ADEQUACY OF SCOPE AND RANGE

OF ALTERNATIVES
This master response addresses comments related to the adequacy of the scope and range of
alternatives, including the following: H-20, H-21, H-65, H-66, H-67, L-11, L-12, L-16, L-17, L-21, L-35, P10, P-12, R-7, S-12, S-13, S-14, U-2, U-3, U-4, U-6, V-3, V-4, V-10, Z-3a through Z-3e, AA-11, AA-13,
and AA-14.
3.12.1
CEQA Requirements for Alternatives
CEQA Guidelines Section 15126.6 requires the consideration of a range of reasonable alternatives to the
proposed project. The purpose of the alternatives analysis, according to CEQA Guidelines Section
15126.6(a), is to describe a range of reasonable alternative projects that could feasibly attain most of the
objectives of the proposed project and to evaluate the comparative merits of the alternatives. The
Guidelines further require that discussion focus on alternatives capable of eliminating significant adverse
impacts of the project or reducing them to a less-than-significant level, even if the alternative would not
fully attain the project objectives or would be more costly.
The range of alternatives evaluated in an EIR is governed by a rule of reason, which requires the
evaluation of alternatives necessary to permit a reasoned choice. An EIR need not consider alternatives
that have effects that cannot be reasonably ascertained and/or are remote and speculative. Alternatives
considered must include those that offer substantial environmental advantages over the proposed project
and may be feasibly accomplished in a successful manner considering economic, environmental, social,
technological, and legal factors. In accordance with the CEQA Guidelines, the alternatives considered in
the Draft EIR included a reasonable range of alternatives that could: (1) accomplish most of the basic
objectives of the project and (2) avoid or substantially lessen one or more of the significant effects of the
project.
3.12.2
Draft EIR Alternatives
Chapter 6, Alternatives to the Proposed Project, of the Draft EIR provides a discussion of the following
alternatives:
Alternatives Considered but Eliminated

No Project
Alternatives to Proposed Project:
o Reduced Seaside Basin Replenishment Alternative
o Component by component alternatives for Source Water Diversion and Use, for Product
Water Conveyance, and for CalAm Distribution System Improvements
o Three overall alternatives to the Proposed Project were considered, that combined
component by component alternatives into overall alternatives. Table 6-6 of the Draft EIR
provides an overview of environmental impacts of the following overall alternatives
compared to the Proposed Project:
Alternative A: Reduced Seaside Basin Replenishment and Alternative Monterey
Pipeline
Alternative B: Reduced Source Water Alternative # 2 (No Tembladero Slough)
and Alternative Monterey Pipeline
Alternative C: Reduced Source Water Alternative # 7 (Salinas Source Waters
Only) and Alternative Monterey Pipeline
The CEQA Guidelines state that an EIR need not consider every conceivable alternative to a project, and
that an EIR need not consider an alternative whose effect cannot be reasonably ascertained and whose
implementation is remote and speculative. However, it must consider a reasonable range of potentially
feasible alternatives that will foster informed decision making and public participation.
Final EIR
3-48
September 2015
The lead agency is responsible for selecting a range of project alternatives for examination and must
publicly disclose its reasoning for selecting those alternatives. On pages 6-24 to 6-52 of the Draft EIR,
under the Alternatives Section, each of the selected alternatives is described, evaluated, and compared
to the Proposed Project. The Draft EIR contains a description of the alternative followed by an evaluation
of each alternative.
The Draft EIR also discusses the alternatives that were considered, but eliminated from further analysis,
including water supply alternatives and alternatives to components of the Proposed Project (Section 6.2.1
Alternative Water Supplies Considered but Eliminated and Section 6.2.2 Alternative Components of the
Proposed Project Considered but Eliminated). The Draft EIR reviewed previous water supply projects in
the Monterey Peninsula, the former Fort Ord, and Salinas Valley areas in order to document past efforts
at developing water supplies that were intended to achieve similar objectives of the Proposed Project, as
well as to address specific comments raised in response to the Notice of Preparation for this EIR. The
Draft EIR (pages 6-7 to 6-24) discusses the alternatives eliminated from the detailed analysis, referencing
an explanation of the alternatives considered and the rationale for elimination of the particular alternative
from more detailed evaluation.
In addition, for those alternatives selected for further evaluation, the ability of each alternative to reduce
potential impacts is discussed. The Draft EIR identifies that the alternatives chosen for this analysis were
developed to avoid or substantially reduce the significant impacts associated with the Proposed Project.
Chapter 6 of the Draft EIR consists of a detailed analysis of the potential environmental impacts of each
alternative project component and each overall project alternative, including a separate discussion of
each environmental issue area for each alternative, and provides sufficient information about each
alternative to allow meaningful analysis in comparison with the Proposed Project. While an EIR must
include sufficient information about each alternative to allow meaningful evaluation, analysis, and
comparison with the proposed project (See CEQA Guidelines 15126.6(d)), [t]he discussion of
alternatives need not be exhaustive. The Draft EIR provides both a discussion on the comparison of
the impacts for each alternative and further presents this comparison in a matrix format on pages 6-47 to
6-52 of the Draft EIR, (Tables 6-6). The use of a matrix format is expressly authorized by CEQA
Guidelines 15126.6, (d), which states a matrix displaying the major characteristics and significant
environmental effects of each alternative may be used to summarize the comparison.
In accordance with the CEQA Guidelines, the alternatives in the Draft EIR and this document include
those that 1) could accomplish most of the basic objectives of the project and 2) could avoid or
substantially lessen one or more of the significant effects of the project. To implement the Proposed
Project and enable the MRWPCA to achieve its objectives, the MRWPCA will make a decision to approve
the Proposed Project, an alternative to the Proposed Project or to not approve the project (i.e., no project
action) and not achieve the Proposed Project objectives.
See Section 3.12.3 below for a discussion of the basic objectives of the Proposed Project.
3.12.3
Alternatives Ability to Meet Project Objectives
Several comments on the Draft EIR expressed their preference for specific alternatives or requested that
additional alternatives be reviewed. Under CEQA Guidelines Section 15126.6(a), an EIR must describe a
range of reasonable alternatives which would feasibly attain most of the basic objectives of the project,
but would avoid or substantially lessen any of the significant effects of the project. The range of
alternatives examined in the Draft EIR necessarily is focused on those alternatives capable of meeting
the project objectives.
As stated on pages 2-17 through 2-18 of the Draft EIR (and presented in the 2013 Notice of Preparation
and its 2014 supplement in Draft EIR, Appendix A), the Proposed Projects primary objective is to
replenish the Seaside Groundwater Basin with water to replace a portion of CalAms water supply as
required by state orders. Another objective of the Proposed Project is to provide additional water to the
RTP that could be used for crop irrigation through the Salinas Valley Reclamation Plant and Castroville
Seawater Intrusion Project (CSIP) system. Project objectives are restated below:

Final EIR
3-49
September 2015
The primary objective of the Proposed Project is to replenish the Seaside Groundwater Basin with
3,500 AFY of purified recycled water to replace a portion of CalAms water supply as required by
state orders. The Draft EIR further identifies that to accomplish this primary objective, the
Proposed Project would need to meet the following objectives:
Be capable of commencing operation, or of being substantially complete, by the

end of 2016 or, if after 2016, no later than necessary to meet CalAms
14
replacement water needs;
Be cost-effective such that the project would be capable of supplying reasonablypriced water; and
Be capable of complying with applicable water quality regulations intended to
protect public health.
Secondary objectives of the Proposed Project are also identified:
Provide additional water to the Regional Treatment Plant that could be used for
crop irrigation through the Salinas Valley Reclamation Plant and CSIP system;
Develop a drought reserve to allow the increased use of Proposed Project source
waters as crop irrigation within the area served by the CSIP during dry years;
Assist in preventing seawater intrusion in the Seaside Groundwater Basin;
Assist in diversifying Monterey Countys water supply portfolio.
No new alternatives suggested or recommended in comments on the Draft EIR are capable of meeting
the project objectives to the extent that the Proposed Project would; although some would meet one or
more to a lesser degree.
As noted above, alternatives considered must include those that offer substantial environmental
advantages over the proposed project and may be feasibly accomplished in a successful manner
considering economic, environmental, social, technological, and legal factors. The new alternatives
suggested in comments were reviewed against these established guidelines. No new alternatives
suggested in comments on the Draft EIR meet these criteria as discussed below.
3.12.4
New Alternatives Suggested or Recommended by Commenters
Certain comment letters expressed their preference for an alternative to the Proposed Project or
components thereof. Some comments express the need to add a project alternative or to consider
alternatives to individual components of the Proposed Project. This section addresses the following
comments: H-20, H-65, H-66, H-67, L-11, L-12, L-16, L-17, L-10, L-21, P-10, P-12, R-7, S-14, U-2, U-3,
U-4, U-6, V-3, V-4, and V-10, Z-1, and Z-3a through Z-3e, AA-9 through AA-14. See also the individual
responses to the above comments in Chapter 4, Comments and Responses on the Draft EIR for
specific responses.
3.12.4.1 Alternatives to Project Components Suggested by Commenters

Alternatives to Product Water Conveyance Pipeline
Comments H-20, H-66, H-67, J-5, L-16, L-17, V-4, AA-9, and AA-10 relate to alternatives for product
water conveyance pipeline alignments, including comments on the two primary options (the RUWAP
alignment option and the Coastal alignment option) and recommendations for new alternatives for
15
portions of the proposed alignments.
14
The Draft EIR clarifies that the Proposed MPWSP has been delayed to the point where it is not possible for CalAm
to meet the State Water Resources Control Board Cease and Desist Order 2009-60 deadline of December 31, 2016.
15
Comments P-10, P-12, L-21, AA-13 and AA-14 address alternatives to the CalAm Distribution System: Monterey
Pipeline and are addressed below.
Final EIR
3-50
September 2015
Certain comments identify a preference for the Regional Urban Water Augmentation Project (RUWAP)
alignment option over the Coastal alignment option for the Product Water Conveyance pipeline. The Draft
EIR provides a comparison of environmental impacts of the RUWAP alignment to the impacts of the
Coastal alignment, including the ability to avoid impacts to coastal resources, such as impacts to the
riparian, wetland, and coastal dune resources. Some comments identify a rationale for selection of other
alignments over the Coastal Alignment including identifying that the product water conveyance pipelines
would be close to, or near, resources or would impact coastal resources (see comments V-4, V-10, AA-9
through A-11). For these comments, Chapter 4 of this Final EIR provides individual responses regarding
environmental issues of the alternatives and the ability of the alternative to meet project objectives.
Comments that express an opinion on which alternative in the Draft EIR is preferred by the commenter
are referred to decision makers (H-66, H-67, J-5, V-4, and AA-11). Chapter 6, Alternatives to the
Proposed Project, in the Draft EIR fully addresses the various alignments and rationale for alternative
conveyance alignments. The Draft EIR, page 6-34, concludes the RUWAP alignment is environmentally
superior to the Coastal alignment alternative, consistent with the above comments.
Comments L-16 and L-17 suggest alternative alignments for the Product Water Conveyance pipeline
between General Jim Moore Boulevard and the Injection Well Facilities in the City of Seaside area.
Although alternatives to the proposed alignment were identified during project planning (including use of
Eucalyptus Road from its intersection with General Jim Moore Boulevard to the Injection Well Facilities
well cluster sites), the current proposed alignment (following an existing access road to the Blackhorse
Reservoir site and then to Eucalyptus Road) is the preferred alignment because it would result in the least
environmental impacts and would meet all of the project objectives. Comments L-16 and L-17 suggest
alternative alignments that would follow General Jim Moore Boulevard further south before turning toward
the Injection Well Facilities at either Eucalyptus Road or near the southernmost injection wells. In both of
these two alternatives, the pipeline would be longer than the Proposed Project alignment. Using General
Jim Moore to Eucalyptus Road would be approximately 600 feet longer than the Proposed Project
alignment, and would require additional grade change beyond the proposed alignment. Following General
Jim Moore to the southernmost injection well site would be approximately 2,500 feet longer than the
Proposed Project alignment in General Jim Moore; although it may eliminate the pipelines between
Eucalyptus Road and the injection well cluster sites, if the co-located electrical conduit can also follow
General Jim Moore Boulevard to the southernmost Injection well site. The construction of either of these
alternative pipelines would occur in much closer proximity to the sensitive receptors located near General
Jim Moore Boulevard within the City of Seaside.
These suggested alternative alignments would have increased environmental impacts during construction
in comparison to the Proposed Project including: greater amount and more severe dust, air pollution, and
noise impacts on sensitive receptors, such as residences in the City of Seaside and the Seaside Middle
School, due to the location being closer to the receptors and more construction activities occurring. In
addition, a longer route would have incrementally greater impacts during construction due to ground
disturbance on the less-than-significant impacts of hydrology and water quality, and traffic/transportation
impacts during construction would be greater. During operation these alternative alignments would have
greater electricity demand (and the associated greenhouse gas emissions to produce the electricity) due
to the more steep and varying hydraulic grade lines. For these reasons, the recommended alternative
pipeline routes between General Jim Moore Boulevard and the Injection Well Facilities are not considered
in detail in the EIR.
Alternatives to Disposal of Well Maintenance Back-flush Water

In comments L-11 and L-12, the City of Seaside requests that well construction/development and well
maintenance (back-flush) water be conveyed to Seasides Bayonet and Blackhorse water supply
reservoir (referred to as the Seaside golf course reservoir), north of Eucalyptus Road and east of General
Jim Moore Boulevard. As discussed in Master Responses #7 and #8 above, although technically feasible,
discharge of these waters to the Seaside golf course reservoir would require additional energy for
transport/conveyance adding unnecessary energy use and associated greenhouse gas emissions,
potentially contributing to greater climate change impacts of the Proposed Project. In addition,
groundwater sent to the golf course reservoir would not re-enter the groundwater basin, requiring
additional product water to be produced by the Proposed Project, which in turn would necessitate a larger

Final EIR
3-51
September 2015
AWT Facility using more power to produce the net amount of 3,500 AFY for the Seaside Basin. This
suggested alternative would also add to the Proposed Project cost. Because this potential alternative
component (discharge of well construction and development water to the Seaside golf course reservoir)
would not reduce the environmental impacts of the Proposed Project and would not better meet the
project objective to produce reasonably-priced water, it is not considered further in this EIR.
Alternatives to CalAm Distribution System: Transfer and Monterey Pipelines

Comments AA-13 and AA-14 discuss the Monterey Pipeline and state a preference that an alternative to
that pipeline be implemented. The Proposed Projects Monterey Pipeline would potentially be located
within an Ecologically Sensitive Habitat Area (ESHA); specifically, central dune scrub (silver dune lupine
mock heather scrub) that supports habitat for Smiths blue butterfly and eucalyptus trees that provide
habitat for Monarch butterflies as identified on page 4.5-92 of the Draft EIR. The alternatives analysis in
the Draft EIR describes and evaluates an alternative to the Monterey Pipeline and determines that the
Alternative Monterey pipeline would avoid the significant impacts related to impacts to sensitive habitats
(see page 6-41, Table 6-5), and thus the Alternative Monterey Pipeline would achieve the requested
avoidance of ESHA.
The Draft EIR also explains that the proposed Monterey Pipeline would be within an area that is subject
to shoreline hazards, such as flooding due to coastal erosion and sea level rise (see Draft EIR pages 4.838 and 4.11-92). The alternatives analysis in the Draft EIR describes and evaluates an alternative to the
Monterey Pipeline and determines that the Alternative Monterey pipeline would avoid the significant
impacts related to impacts to flooding and coastal erosion/sea level rise (see page 6-41, Table 6-5), and
thus the Alternative Monterey Pipeline would achieve the requested risk minimization. The Draft EIR page
6-46 concludes that implementation of the Alternative Monterey Pipeline would be environmentally
superior to the Proposed Project.
In addition, comments P-10, P-12, and L-10 note that CalAm has presented an alternative to the
Proposed Project version of the CalAm Distribution System: Transfer and Monterey Pipelines. See the
individual responses to those comments and Master Response #11: Proposed Projects Relationship to
the Proposed Monterey Peninsula Water Supply Project.
3.12.4.2 Alternatives to the Proposed Project Suggested by Commenters

Reduced Seaside Basin Replenishment Alternative
Comment H-65 questions the conclusion in the Draft EIR about the environmental impacts of the
Reduced Seaside Basin Replenishment Alternative being the same as those of the Proposed Project.
The alternatives analysis in the Draft EIR presents a comparison of these impacts to support this
conclusion in Section 6.3.1.1 on page 6-24. The analysis provided in Master Response #10 and in
Appendix BB clarifies and supports the conclusions about the effects that would occur on the amount of
recycled water available to CSIP in the event that the RUWAP Recycled Water Project is implemented.
Under the scenarios when the Proposed Project is implemented, if MCWD implements the RUWAP
Recycled Water Project, it would not change the Proposed Projects use of source waters.
Increased Proposed Project Yield or AWT Facility Size Alternatives

Comments U-3 and U-6 recommend larger project alternatives with increased AWT Facility annual yield,
or with increased AWT Facility yield to deliver the same amount of water to the Seaside Groundwater
Basin only during winter months. Comment U-3 requests that the EIR consider an alternative to the
Proposed Project that could provide all the water demands projected by CalAm for their service area. Per
the Draft EIR (Chapter 2), the amount of new supply proposed to be supplied for the groundwater
replenishment part of the Proposed Project is an average of 3,500 AFY, to reduce Cal-Ams use of the
Carmel River system by the same amount. A larger AWT Facility with a capacity to produce more than
3,500 AFY on average and up to 14,000 AFY or more was not analyzed in this EIR as it would not reduce
any significant effects of the Proposed Project.

Final EIR
3-52
September 2015
A larger AWT Facility with a capacity to produce the entire 3,500 AF during the winter months was not
analyzed in this EIR because it also would not reduce the significant environmental effects of the
Proposed Project. In addition, the scenario of using the AWT Facility only during the winter months was
determined to be infeasible by the MRWPCA during early project planning due to engineering and
operational considerations.
Alternative Water Supply Sources

Comments U-2 and U-3 suggest including analyses of alternative desalination projects, including the
Monterey Bay Regional Water Project, proposed by DeepWater Desal, LLC, and the Peoples Moss
Landing Water Desalination Project. As stated on page 6-10, the Monterey Bay Regional Water Project,
proposed by DeepWater Desal, LLC, and the Peoples Moss Landing Water Desalination Project are not
considered to be alternatives to the Proposed Project. They would not achieve the objective of providing
replacement water for the Monterey District service area customers within the timeframe specified in the
Proposed Project objectives. Neither of the proposed desalination projects would be alternatives that
would avoid or reduce the environmental effects of construction or operation of the Proposed Project.
Neither the Monterey Bay Regional Water Project (DeepWater Desal, LLC) nor the Peoples Moss
Landing Water Desalination Project would be implemented by the MRWPCA.
Comment U-4 requests that the EIR consider the use of slant or slope wells in the Carmel Bay as an
alternative water supply. Although not explicitly stated in the comment, it is assumed that the comment
intended that the slant wells would be built to collect seawater or brackish groundwater for a desalination
plant. The range of alternatives considered as stated above are considered reasonable. Designs and
locational information about any potential slant well near Carmel Bay (in addition to the required
desalination plant, brine disposal, pipelines and pumps) have not been presented; however, it is a
reasonable assumption that such a project would have additional environmental impacts, and the amount
of analysis, planning and permitting needed to implement a new potential slant well and the required
associated collection and distribution infrastructure preclude that component from meeting the basic
project objective of timing. For the reasons stated above, this alternative seawater desalination alternative
(i.e. one with slant wells collecting water from Carmel Bay) is not analyzed further in this EIR.
Comments V-3 and Z-3a suggest that additional storm water capture opportunities should be considered
as a primary alternative to source waters. A thorough evaluation and constraints analysis was conducted
during project planning to determine the most appropriate source waters for the Proposed GWR Project,
as detailed in Chapter 6, pages 6-15 through 6-20. The Draft EIR documents why no other stormwater or
urban diversions were pursued as source water for the Proposed Project and how the yields of any
potential capture of these sources is far less than the amount required to meet the project objectives.
Comments Z-3b, Z-3d, and Z-3e propose alternatives such as urban recycled water projects, which have
been considered by other local agencies (see Alternatives Considered but Eliminated in Section 6.2 of the
Draft EIR). The cost of centralized urban reuse projects for residential and commercial land uses is very
high due to the amount of new treatment systems and/or pipelines and pumps needed to collect
wastewater, recycle wastewater, and return it to customers as urban irrigation water. These types of
alternatives would not reduce environmental impacts because the amount of new infrastructure (including
at a minimum, distribution pumps and pipelines) needed to meet the basic project objectives would
dramatically increase the construction and operational impacts of the Proposed Project. Because the
environmental impacts would be much greater and these alternatives are not considered to be feasible
they are not considered further in this EIR.
Comments Z-3b, Z-3d, and Z-3e suggest capturing untreated wastewater (i.e., not sending the
wastewater to the RTP), and treating it to a level needed to reuse and recycle it within the Monterey
Peninsula. Local jurisdictions that collect wastewater do not currently have the capacity, treatment or
distribution system in place nor (with the exception of Pacific Grove) are any such projects in the planning
stages such that these can be evaluated as an alternative to the Proposed Project (i.e., projects that
would capture Monterey Peninsula wastewater flows, treat/recycle it for use locally); therefore, they are
not considered to be feasible and are not considered further in the EIR. Pacific Grove is planning a
project to capture untreated wastewater, but that water is proposed to meet a different objective

Final EIR
3-53
September 2015
(replacing their golf course and cemetery potable water irrigation). Accordingly, the Pacific Grove project
would not accomplish any of the project objectives for the Proposed GWR Project.
Comment Z-3c suggests upgrading the Los Padres Dam and Reservoir including potentially increasing
storage at the reservoir. The Monterey Peninsula, Carmel Bay and Southern Monterey Bay Integrated
Water Management Plan (Monterey Peninsula Water Management District, 2014) states that: Enlarging
the capacity of Los Padres Reservoir (e.g., dredging or building a higher spillway) or construction of a
new reservoir is limited by economic, safety, and environmental constraints and is not considered to be
feasible at this time. The permitting obstacles of this type of project may also deem it to be infeasible.
Maintenance dredging of the Los Padres Reservoir to retain existing storage capacity has been
considered as an option, however, according to MPWMD staff summary prepared for the July 21, 2014
16
MPWMD Board meeting : Los Padres Reservoir is a more difficult and expensive site to address
sediment issues than at the San Clemente Reservoir, where a unique situation allowed sediment to
remain in place. A fundamental issue with Los Padres Dam that needs to be addressed with any
proposed project is both short term and long term management of sediment. The long term average
sediment inflow is about 20 AFY or the equivalent of about 2,200 tandem truckloads of sediment
annually. Sediment starvation downstream of the dam continues to degrade the river through the
armoring effect (winnowing of spawning gravel) and downcutting into the riverbed. Failure to address this
degradation will compromise efforts to improve habitat for steelhead by reducing diversions and may lead
to further destabilization of streambanks in the lower 15 miles of the river.
Request for the Proposed Project to be Considered an Independent Project

Comments S-13, S-14, and T-2 suggest that the Draft EIR for the Proposed Project should analyze the
Proposed Project as an independent project from the Monterey Peninsula Water Supply Project
(desalination project). The Proposed Project is separate and independent from the Monterey Peninsula
Water Supply Project, and can go forward without the Monterey Peninsula Water Supply Project. The
EIRs cumulative impacts sections recognize the potential that the Monterey Peninsula Water Supply
Project also might be approved and implemented, and the EIR discloses the combined effects of the two
projects along with other past, present and reasonably probable future projects. However, the Draft EIR
evaluates independently the potential environmental effects of constructing and operating the
infrastructure needed to divert the proposed new source waters to the RTP, treat those source waters,
use tertiary treated irrigation water within the area served by the Castroville Seawater Intrusion Project,
convey purified water to Injection Well Facilities, inject purified water into the Seaside Basin, and convey
extracted water to CalAm customers. See also Master Response #11: Proposed Projects Relationship to
the Proposed Monterey Peninsula Water Supply Project, above. See also Additional No Project
Alternative in Section 3.12.5 below.
3.12.4.3 Summary of Why the EIR does not Include the Suggested New or
Different Alternatives in the EIR
In accordance with Section 15126.6 of the CEQA Guidelines, the range of potential alternatives to the
proposed project shall include those that could feasibly accomplish most of the basic objectives of the
project and could avoid or substantially lessen one or more of the significant effects. Among the factors
that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet
most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental
impacts. Based on the discussions above, no additional alternatives were considered necessary to be
added in the Final EIR because the alternatives suggested either would not reduce identified significant
impacts and/or would increase the significant project impacts, or would not feasibly meet most of the
basic project objectives.
16
http://www.mpwmd.dst.ca.us/asd/board/boardpacket/2014/20140721/02/item2.htm

Final EIR
3-54
September 2015
3.12.5
Additional No Project Alternative Requested
Comment R-7 requests that the EIR include a No Project Alternative scenario to address the potential for
the larger desalination project proposed by Cal Am moving forward if the Proposed Project is not
implemented. Other comments state that the Draft EIR should explore additional analysis specific to the
No Project alternative, including other projects identified that could occur if the Proposed Project is not
implemented.
CEQA Guidelines Section 15126.6(e)(2) states that the No Project alternative shall discuss the existing
conditions, as well as what would reasonably be expected to occur in the foreseeable future if the project
were not approved based on current plans and consistent with available infrastructure and public
services.
The Draft EIR accordingly addresses the No Project Alternative as a no build alternative whereby the
Proposed Project would not be built and no impacts would occur due to construction and operation of the
Project in comparison with current conditions. The MPWSP has not been approved for implementation,
and development of the MPWSP would necessitate substantial infrastructure improvements. The MPWSP
is a separate project, undergoing its own CEQA review. Accordingly, it is considered throughout the
analysis of cumulative impacts in the EIR for the Proposed Project.
CEQA Guidelines Section 15126.6(e)(3)(B) states If the project is other than a land use or regulatory
plan, for example a development project on identifiable property, the no project alternative is the
circumstance under which the project does not proceed. This subsection of the CEQA Guidelines goes
on to state that if disapproval of the project under consideration would result in predictable actions by
others, such as the proposal of some other project, this no project consequence should be discussed."
Here, the MPWSP has been proposed by CalAm independent from the Proposed Project, and the
MPWSP is not a consequence of disapproval of the Proposed Project. Nevertheless, the Draft EIR
discusses the potential for the desalination component of the MPWSP to be a smaller capacity if the
Proposed Project is approved and implemented. This Master Response provides additional information
comparing the impacts of the MPWSP to a scenario under which the Proposed Project is constructed
along with a smaller desalination plant (called the MPWSP Variant in the EIR for the MPWSP).
3.12.6
Comparison of the Impacts of the MPWSP to the Impacts of the

MPWSP Variant
As explained in Master Response #11, if the Proposed GWR Project is approved and implemented,
CalAms Proposed MPWSP with a 6.4 mgd desalination plant (MPWSP Variant) may be approved by
the CPUC rather than the MPWSP that includes a desalination plant sized at 9.6 mgd. While neither the
MPWSP or the MPWSP Variant is considered to be an alternative to the Proposed Project (as discussed
on page 6-9 and 6-10 of the Draft EIR), the following text provides an additional discussion of the
MPWSP based on the information recently published in the Draft EIR for the MPWSP.
The Proposed MPWSP (9.6 mgd plant) is described in the Draft EIR for the Proposed GWR Project on
pages 2-11 through 2-12. The total water produced by the 9.6 mgd MPWSP desalination plant would be
9,752 AFY (compared to 6,252 AFY with the 6.4 mgd desalination plant). All of CalAms proposed
facilities located south of Reservation Road would be constructed, identical for both desalination plant
sizes. The 9.6 mgd MPWSP desalination plant would require three more subsurface slant wells than the
MPWSP Variant with the 6.4 mgd desalination plant (10 versus 7 for the 6.4 mgd plant) for the Seawater
Intake System. The 9.6 mgd desalination plant would have a larger capacity than the 6.4 mgd
desalination plant, and the MPWSP with the 9.6 mgd plant would require more electricity, maintenance
activities, and larger brine disposal facilities than the MPWSP Variant.
If the Proposed MPWSP (9.6 mgd plant) identified above is implemented, this would result in a greater
severity of some impacts compared to MPWSP Variant, particularly related to marine water quality and
marine biological resources. The Proposed MPWSP (9.6 mgd plant) would have greater marine water

Final EIR
3-55
September 2015
quality and biological impacts than the MPWSP Variant because the mixing water from the Proposed
Project would not be available to dilute the desalination plant brine before the brine is discharged to the
ocean outfall. Potential biological and other construction impacts related to slant well construction would
also be increased due to the additional slant wells proposed, compared to the number of slant wells that
would be constructed under the MPWSP Variant. Potential operational impacts to the Salinas Valley
Groundwater Basin would be increased also due to the slant well operation and related impacts,
compared to the MPWSP Variant. Construction impacts of the 9.6 mgd desalination plant would be
greater than construction of the MPWSP Variant. Timing for approval and implementation of the MPWSP
and the MPWSP Variant are unknown.
See http://www.cpuc.ca.gov/Environment/info/esa/mpwsp/index.html for more information on the
Proposed MPWSP planning schedule. This link also contains a link to download a copy of the Draft EIR
for the Proposed MPWSP and the MPWSP Variant.

Final EIR
3-56
September 2015
CHAPTER4
COMMENTS AND RESPONSES ON THE

DRAFTEIR
4.1 INTRODUCTION
This section provides responses to the comments received on the Draft EIR. A list of the comment letters
is presented in Section 2.2, and copies of each of the comment letters are included in this section, with
responses to each comment provided following the letter.
4.2 COMMENTLETTERSANDRESPONSESTOCOMMENTS
Each letter and comment card received as a comment on the Draft EIR is included herein and assigned a
letter of the alphabet. Within that letter or card, all individual comments are assigned numbers located in
the right-hand margin of the letter. Responses to each comment are provided immediately following each
comment letter. In those instances in which a comment states an agency position or opinion and does not
comment on issues relevant to the environmental analysis presented in the Draft EIR, the response
reads: "No response is required. If the comment is directed at Monterey Regional Water Pollution Control
Agency Board regarding the decision on the project, the response reads: "The comment is referred to the
decision makers for their consideration." Typically, these comments do not raise issues relevant to the
environmental analysis. Where the response notes an addition or deletion to the text, tables, or figures in
the Draft EIR, the reader is directed to Chapter 5, Changes to the Draft EIR.

Final EIR
4-1
September 2015
-,
Letter A
..
SlATE OF CALIFO' R NI A
Gove-rnor's Office ofPlanning and .Research
I
~------~;~~~~a~t~e~~~~~~u~s~e~a~n~d~~~~~1J~n~i~t~------~~~~----~--i
~--1!-d-m-un....:d G. Brown Jr.
..
Director
Governor
June 8, 2015
Bob Holden
S Harris Court, Building D
Monterey, CA 93940
Subject: Monterey Peninsula Groundwater Replenishment (Pure Water Monterey) Project
SCH#: 2013051094
Dear Bob Holden:
The State Clearinghouse submitted the above named Draft EJR. to selected state agencies for review. On
lhe enclosed Documel)t Details Report please note that the Clearinghouse bas listed the state agencies that
reviewed your document. The review period closed on JuneS, 2015, and the comments from the
responding agency (ies) is (are) enclosed. Ifthis cOmment package is not in order, please notify the State
Clearinghouse immediately. Please refer to the project's teo-digit State Clearinghouse number in furure
correspondence so that we may respond promptly.
A-1
'
Please note that Section 21104(c) of the California Public Resources Code states that:
"A responsible or other public agency shaU only make substantive comments regarding those
activities involved in a project which are within an area of expertise of the agency or which are
required to be carried out or approved by the agency. Those comments shall be supported by
specific documentation."
These comments are forwarded for usc in preparing your final environmental document. Should you need
more infonnation or clarification of the enclosed comments, we reconunend that you contact the
commenting agency directly.
This letter acknowledges that you have complied with tb.e State Clearinghouse review requirements for
draft environmental-documents, pursuant to the California Environmental .Quality Act. Please contact the
State Clearinghouse at (916) 445~613 if you have any questions regarding the environmental review
process.
----------~~Scott~----:o-ce~~=cy~~~------------------------------~--------~
Director, State Clearinghouse
Enclosures
cc: Resources Agency
1400 TENTH STREET P.O. BOX 3044 SACRAMENTO, CALIFORNIA 96812-3044

TEL (916) 445-0613 FAX (916) 3233018 www.opr.ca.sov
Final EIR
4-2
September 2015
Document Details Report

State C!earjnghouse Data Base
=:J
2013051094
SCH#
Monterey Peninsula Groundwater Repleoj&hment (Pure Water Monterey) Project

Monterey Regional Water Pollutlon Control Agency
Projact Tit/a
I
I
I
I
Lead Agency
Typo
en~
Dn1ft EIR
The proposed Pure Water Monterey Groundwater Replenishment Project would divert new source
waters to the MRWPCA Regional Treatment Plant for two purposO$: 1) to croata purifocd recycled
water for recharge of the Seaside Groundwater Basin to raplaoo 3,500 acre--feet per year 9f CalAms
current water supplies. enabling CalAm to.reduoo its diversions from the Carmel River by the .same
amount, and 2) to provide addillonal recycled water to growers w~hin the existing Castroville Seawater
lnttusion Project's service area for crop irrigation. Water sources prop0$ed to be recycled, treated and
reused by tho GWR Project include municipal wastewater.
Description
Lead Agency Contact

Namo
Agency
Phone
ema//
Address
City
Boo Holden
831 645 4834
Fax
5 Harris Court, Building 0

Monterey
Stato CA
Zip 93940
Project Location
County
City
Monterey
Seaside, Marina
Region
Lat/Long
Cross Street$
Pa~el No.
Township
Major streets indude Hwy 1

numerous
Rongo
Base
Soctfon
Proximity to:
Highways
Alrports
Railways
Waterways
Schools
Land Uso
Projoct Issues
Hwy 1,156, 68, 183

Monterey Peninwla, Marina
Setinas and Carmel Rivers, OlhOf creeks/ditches, stoughs
numerous
Various
Archaeolegle-Histo~c: Air Quality: Biological Resources: Coastal Zone: Dn~inage/Absorption;
Economics/Jobs: Flood Plain/Flooding: Geologic/Seismic: Minemls: Noise: PopulatiocYHousing

Balanc&: Public Services: Recreation/Parks: Schools/Universities: Sewer Capacity; Soli
Erosion/Compadion/Grading: Solid Waste: Toxic/Hazardous: Traffic/Circulation; VegetaUon: Weier
Quality: Water Suwly; WeUand/Riparian: Growth Inducing; Landuse; Cumu1ative Effeels;
-,----------,AestheticiVisuai~Foresltand!FireHazard;-Agliculturaltan<t------------------+
Reviewing Resources Agency; California Coastal Commls$1on: Department of Fish and Wildlne. Region 4:
Agoncics Department of Parks and RecreaUon: Department of Water Resources; Office of Emergency Setvices.
California; Caltrans, DistrictS: Air Resources Board; State Water Resources Conuol6oard. Divison of
Financial Assistance: Stale Weier Resources Control Board. Division of Water Quality; State Waler
Resources Control Board, Division of water Rights: Native AmeriCan Heritage Commission: State
lands Commission
Data Recelvod
04l2212015
Start of Review 0412212015
End of Rovicw 08/0512015
Note: Btanh in deta fields result from insufficient information provided by lead agency.
Final EIR
4-3
September 2015
See Letter D
!sTATE OF cALIFORNIA
EOMUND G. BROWN J R., Governor

JENNIFER LUCCHESI,
CALIFORNIA STATE LANDS COMMISSION

100 Howe Avenue, Suite 100.South
574-1800
Officer
574-1810
E~ecutive
Fax (91
Contact Phone: (916) 674-1890

Contact FAX: (916) 57~1885
JUN -4 2015
File Ref: SCH #2013051094
STAlE CLEARING H0USE
Bob Holden
Principal Engineer
.
5 Harris Court, Building D
Monterey,
CA 93940
I
Subject: Draft Environmental. impact Report (EIR) for Pure Water Monterey
Groundwater Replenishment Project, Monterey County
Dear Mr: Holden:
The Galifomia State Lands Commission (CSLC) staff has reviewed the subject Draft
EIR for the Pure Water Monterey Groundwater Replenishment Project {Project), which
is being prepared by the Monterey Regional Water Pollution Control Agency
(MRWPCA). The MRWPCA, as a ptlbllc agency proposing to carry out a project, .is the
lead agency under the California Environmental Quality Act (CEQA) (Pub. Resou rces
. Code, 21000 et seq.). The CSLC is a trustee agency for projects that could directly or
indirectly affect sovereign lands and their accompanying Public Trust resources or uses.
Additionally, because the Project involves work on sovereign lemds, the CSLC will act as
aresponsible agency.
.
CSLC Jurisdiction and Public Trust Lands
..
The CSLC ~as jurisdiction and management authority over all ungra.nted tidelands, .
submerged lands, and the beds of navigable lakes and waterways. The csLC also has
certain res.idual and review authority for tidelands and submerged lands legislatively
1
t-
-------~~rair~t~!~d~i~n~tcru~s~t~ro~lo~ca~l~ju~r~isd~i~ct~io;;n~s~(P~u~b~.~R~e~so~1u~~~e~s~C~o~dTe,~~~6~3~0~1~,6~3~0~6~).~A~I~I~ 1Jd_____~---~--~
waterways, are subject to the protections of the
..
As general background, the S~t~ of CaliforniE\ acquired sovereign ownership of all

tidelands and submerged lands and beds of navigable lakes and waterways upon its
admission to the united States 1n 1850. The State holds these lands for the benefit of
all people of the State for statewide Public Trust purposes, which Include but are not
limitE;~d to waterborne commerce, n'avigation, fisheries, water-related recreation,. habitat
preservation, and open space. On navigable non-tidal waterways, including lakes, the
State holds fee ownership ofthe .bed of the waterway landWard to the ordinal low

Final EIR
4-4
September 2015
..
'
Bob Holden
.,
I
. Page 2
See Letter D
June 5, 2015
water mark and a Public Trust easement landward to the ordinary high water mark, .
_ ex.cept wbe(!il_tbe boMn.c:Lar:yj)as_beenJixedjly_agreement OLB__CQ.l![t._~ucl:l bound):lries
may not be readily app<;~rent from present day site inspections.
Based on a review of our records, the proposed source water pipeline crossing near the
Blanco Drain Diversion will extend across the bed of the Salinas River which at this
location is natural, navigable, tidal, and meandered on both banks of the Rancho Plat.
The MRWPCA will be required to obtain a lease for the portion of pipeline crossing the
Salinas River. Please contact Drew Simpkin, Public Land Management Specialist (see
eontact information below), for more information regarding CSLC jurisdiction and
leasing requirements.
Project Description
The MRWPCA proposes.to provide purified recycled water to recharge a groundwater
basin and augment the existing Castroville Seawater Intrusion Projecfs crop irrigali9n
supply. M~WPCA's objectives and needs for the Project are as follows:
.Replenish the seaside groundwater basin with 3,500 acre-feet per ye~:~r;
Commence operation of tlie Project by the end of 2016;
.. Supply reasonably-priced water to end users; and

Comply with water quality regulations.
From the Project Description, CSLC staff understands that the Project would include the
following components.
..
..
,..----
Source Water Diversion and Storage. New facilities would be constructed to

divert and convey new sour.ce water through theexisti_ng municipal wasteV!{!'lter
eollection system to the Regional Wastewater Treatment Planl One of the
pipelines for conveyance would be placed under. the Salinas River, using
directional drilling methods.
Treatment Facilities at the Regional Wastewater Treatment Plant. A h~w

advanced water trea,tment plant would be construct~d at the existing Regional
Wastewater Treatment Plant site.
Product Water Conveyance. New pipelines, a pump statiori and appurtenant

facilities would be constructed to move the product water from the Regional
Wastewater.Treatment Plant to the Seaside Groundwater Basin for Injection.
Injection Well Facilities. New injection well facilities would be constructE;!d
including back-flush facilities, pipelines, electricity distribution facilities, and
. electrical or motor control building.
Distribution of Groundwater from seaslcleE!asin. lWo new California American
Water Company (CaiAm) water distribution pipelines would be constructed to
deliver the .extracted .groundwater to CaiAm
. customers.
The Draft EIR identifies Alternative B as the Environmentally Superior Alternative.

Alternative B would-eliminate using ~ource water from Tembladero Slough, which would
avoid significant and unilvoidaJJre noise Impacts, al]d would require an alternative route
for' the Monterey Pipeline, which would reducesignificant construction impacts,
including the need for a transfer pipeline.

Final EIR
4-5
September 2015
i
I
I
i
--!
I ..
See Letter D
Holden
- - . .. .. .....:Bob
........ .. .... - .... .... _.. . -.
---- Environmental Review.
'-
-:
Page 3-
...
. .
---'--------- -
CSLC staff requests that the MRWPCA consid~r the following comments on the
Project's Draft EIR.
---
Biological Resources
1.. Drilling Noise:TM EIR evaluates the impacts of noise ahd vibration impacts on birds
from directional drilling and.associated ~~eel pile driving activities during ..
construction of the Monterey pipeline. In addition to assessing noise impacts on
birds, the EIR should be revisedto disclose whether sheet pile driving will be needed
for the other area of directional drilling to take place under the Salinas River, and
'then evaluate the significance of noise and vibration impacts on fish from both the
directional d~lling and p!)SSib~e pile driving. If lmpacJs are found to be ~lgnlficant,
mitigation measures could include species-specific work windows as defined by the
California Department of Fish and Wildlife, U.S. Fish and Wildlife Service, and the 1
National Oceanic and Atmospheric Administration's National Marine Fisheries
Service. CSLC staff rec;:orrimends that the EIR discuss any consultation that has
taken place with these agencies to minimize the impacts of the Project on sensitive
specle.
s, and the outcome .of those consultations.
.
Thank you for the'opportunity to comment on the. Draft EIR for the Project. As a
.responsible agency, the CSLC will need to rely on the Final E!R for the issuance of any
. .
new lease as specified above and, therefore, we request thal you consider our
comments prior to certification of the EIR.
Please send copies of future Project-related documents, Including electronic copies of
the .Final EIR, Mitigation Monitoring and Reporting Program (MMRP), Notice of
beterminatio'! (NOD), CEqA Findings and, If applicable, Statement of Overriding
Considerations when they become avail~ble, and.refer qi.Jestiohs concerning
.
environmental review to Holly Wyer, Environmental Scientist, at (916) 574-2399 or via
e-mail at Holly.Wyer@slc.ca.gov. For questions concerning CSLC leasing jurisdiction,
please contact Drew Simpkin, Public Land. Management Specialist, at (916) 574-2275,
or via email at J?rew.Simpkin@slc.ca.gbv. .
~~erelYr
~-----~~~~
~~~~-J~y,~~,=--~--~~-+
R.
Cy Oggin.sNfhlef
..
.
.Division of Environmental Plallning
and Management
cc: Office of Planning arid Research

' H, Wyer, CSI...C
D. Simpkin, CSLC
.. J. Rader, CSLC

Final EIR
...
.
4-6
September 2015
See Letter C
JUN -5 2015
STATE CLEAf\ING
JUN 0~ - 2015
In Reply Rl'!fer to:

JMH:32263
Monterey Regional Water Pollution Control District

c/o Mr. Bob Holden
gwr@mrwoca,com
Dear Mr. Holden:
NOTICE OF COMPLETION FOR THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR PURE
WATER MONTEREY GROUNDWATER REPLENISHMENT PROJECT OF MONTEREY COUNTY
WATER POLLUTION CONTROL AGENCY (SCH # 2013051094) IN MONTEREY COUNTY
The State Water Resources Control Board (State Water Board), Division of Water Righ~s (Division).
has received the Notice of Completion for the Draft Environmental impact Report (DEIR) fo~ the Pure
Water Monterey Groundwater Replenishment Project (Project).
The purpose of this letter is to make you aware that portions of the Proj<?ct may require a water right
approval from the State Water Board and provide comments on the DEIR for you to consider related
to any such approval.
Portions of the Project that may require a water right approval include (1) the diversion of surface
water from four locations (Tembladero Slough, Reclamation Ditch, Blanco Drain, and Lake El
Estero) and (2) a reduction In discharge of treated wastewater to the Salinas Industrial Wastewater
Treatment Facility evaporation/percolation ponds.
If a w,ater right approval is needed, the State Wa!er Board will act as a Responsible Agency for this
projecl Accordingly, the State Water Board may need to rely on your California Environmental
Qualny Act (CEQA) document for the Project to support the Division's evaluation of the requested
approval. Therefore, you should ensure that any CEQA document prepared for the project
considers all potential direct and indirect environmental impacts associated with the diversion and
use of water.
Diversion of Surface Water
Diversion and use of surface water from the four locations listed in the DEIR (Tembladero Slough ,
.j__ _ _ _IR~cllllmltion-Ditch;-Biam:o-Dra1n:-an"d-take-EIEstero}reqoires-arrappropriativewaterright-permir.- - - - - -j(Wal Code, 1200 et seq.) The first step to acquiring an approp(iative water right permit Is to file
an Application to Appropriate Water by Permit
To authorize the portions of the project that propose the diversion of surface water from three of the
four locations listed in the DEIR (Tembladero Slough, Reclamation Dnch, and Blanco Drain), the
Monterey County Water Resources Agency has filed Water Right Application 32263 with the State
Water Board. The proposed Lake El Estero point of diversion is not included in any water right filing
with the State Water Board.

Final EIR
4-7
September 2015
JUN 0 It 20~
-:- - - -c/oMr:-Bob-Holden,- - - - - - - --3-- - - - - - - - - - - - - - ;l======;-- -- ;

1
See Letter C
~~
I
I
Qrder in response to an unauthorized diversion or threatened unauthorized diversion pursuant to

Water Code section 1831.
If you have any questions, .please contact me at Justine.Herrig@waterboards.ca.gov or

(916) 341 -5759. Written correspondence or-inquiries should be addressed as follows: State Water
Resources Control Board, Division of Water Rights, Attn: Justine Herrig, P.O. Box 2000,
Sacramento, CA. 95812-2000.
Sincerely,
~jJ-t~
Justine Her(ig
Environmental Scientist
Coastal Lahontan Unit
Division Water Rights
of

c/o David Chardavoyne
chardavoynede@co.monterey.ca.us
c/o Brent Buche
bucheb@co.monterey.ca.us
c/o Shaunna Juarez

juarezsl@co.monterey.ca.us
Central Coast Water Regional Water Quality Control Board
c/o L.isa McCann
Lisa.McCann@waterboards.ca.gov
c/o Harvey Packard
Harvey.Packard@waterboards.cil.gov
Department of Fish and Wildlife
c/o James Rosauer .
James.Rosauer@wildlife.ca.gov
Depanment .of Fish and Wildlife
c/o Annette Tenneboe
Annette.Tenneboe@wildlife.ca.gov

Final EIR
4-8
J,
__ _
-~
_S
_t_a_ff_C_o-nt-a-c t- - - - - - - - - - - - - - - - - - - -
ec:
September 2015
Chapter4.CommentsandResponsesontheDraftEIR
LetterA: GovernorsOfficeofPlanningandResearch,StateClearinghouse#1
A-1
The letter states the State Clearinghouse submitted the Draft EIR to selected state agencies for
review, and has attached the two letters of comment that the State Clearinghouse received
during the public review period. Specifically, the California State Lands Commission (see letter
D) and the State Water Resources Control Board (see letter C) submitted their letters to the
State Clearinghouse. No further response is required. The Monterey Regional Water Pollution
Control Agency has complied with the State Clearinghouse review requirements as required
pursuant to CEQA.

Final EIR
4-9
September 2015
EDMUND G BROWN Jr. . Governor
STATE OF CALIFORNIA-CALIFORNIA STATE TRANSPORTATION AGENCY
DEPARTMENT OF TRANSPORTATION
Letter B
50 HIGUERA STREET
SAN LUIS OBISPO, CA 93401-5415
PHONE (805) 549-3101
FAX (805) 549-3329
TTY711
Serwus drought
Help save water '
http://www.dot.ca.gov/dist05 /
May 20, 2015

MON-1-Var.
SCH# 2013051094
Bob Holden
Salinas, CA 93940
Dear Mr. Holden:
COMMENTS TO PURE WATER MONTEREY PROJECT
The California Department of Transportation (Caltrans), District 5, Development Review, has
reviewed the above referenced project and offers the following comment.
Any work within the State right-of-way will require an encroachment permit issued from
Caltrans. Detailed information such as complete drawings, biological and cultural resource
findings, hydraulic calculations, environmental reports, traffic study, etc., may need to be
submitted as part of the encroachment permit process.
If you have any questions, or need further clarification on items discussed above, please don't
hesitate to call me at (805) 542-4751.
Sincerely,
Jl2fek-
JOHN 1. OLEJNIK
Associate Transportation Planner
District 5 Development Review Coordinator
john.olejnik@dot.ca.gov
"Provide a safe, sustainable, integrated and efficient transportation system

to enhance California's economy and livability"
Final EIR
4-10
September 2015
B-1
LetterB: CaliforniaDepartmentofTransportation(Caltrans)
B-1
The comment provides information on potential permit requirements of any project components
within the State right-of-way; an encroachment permit would be obtained prior to any work
within the State right-of-way.

Final EIR
4-11
September 2015
Letter C
JUN 04 2015
In Reply Refer to:
JMH:32263
Monterey Regional Water Pollution Control District
c/o Mr. Bob Holden
gwr@mrwpca.com
Dear Mr. Holden:
NOTICE OF COMPLETION FOR THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR PURE
WATER MONTEREY GROUNDWATER REPLENISHMENT PROJECT OF MONTEREY COUNTY
WATER POLLUTION CONTROL AGENCY (SCH # 2013051094) IN MONTEREY COUNTY
The State Water Resources Control Board (State Water Board), Division of Water Rights (Division)
has received the Notice of Completion for the Draft Environmental Impact Report (DEIR) for the Pure
Water Monterey Groundwater Replenishment Project (Project).
The purpose of this letter is to make you aware that portions of the Project may require a water right
approval from the State Water Board and provide comments on the DEIR for you to consider related
to any such approval.
Portions of the Project that may require a water right approval include (1) the diversion of surface
water from four locations (Tembladero Slough, Reclamation Ditch, Blanco Drain, and Lake El
Estero) and (2) a reduction in discharge of treated wastewater to the Salinas Industrial Wastewater
Treatment Facility evaporation/percolation ponds.
C-1
If a water right approval is needed, the State Water Board will act as a Responsible Agency for this
project. Accordingly, the State Water Board may need to rely on your California Environmental
Quality Act (CEQA) document for the Project to support the Division's evaluation of the requested
approval. Therefore, you should ensure that any CEQA document prepared for the project
considers all potential direct and indirect environmental impacts associated with the diversion and
use of water.
Diversion of Surface Water
Diversion and use of surface water from the four locations listed in the DEIR (Tembladero Slough,
Reclamation Ditch, Blanco Drain, and Lake El Estero) requires an appropriative water right permit.
(Wat. Code, 1200 et seq.) The first step to acquiring an appropriative water right permit is to file
an Application to Appropriate Water by Permit.
To authorize the portions of the project that propose the diversion of surface water from three of the
four locations listed in the DEIR (Tembladero Slough, Reclamation Ditch, and Blanco Drain), the
Monterey County Water Resources Agency has filed Water Right Application 32263 with the State
Water Board. The proposed Lake El Estero point of diversion is not included in any water right filing
with the State Water Board.

Final EIR
4-12
September 2015
C-2
c/o Mr. Bob Holden
-2-
JUN 04 2015
Lake El Estero is a surface water body that collects water from four tributary streams and a portion
of the City of Montereys stormwater collection system. The City of Monterey operates Lake El
Estero to manage excess stormwater by pumping water from the lake to Del Monte Beach to
accommodate stormwater inflow to the lake. The proposed diversion from Lake El Estero would
operate either by modification of the existing pump utilized by City of Monterey or installation of a
new gravity system on the lake bank, both of which would divert water, up to 87 acre-feet per year,
into the municipal wastewater system adjacent to Lake El Estero. Diversion and use of water from
Lake El Estero, as proposed in the DEIR, will require an appropriative right from the State Water
Board.
To ensure that the portions of the Project involving Lake El Estero comply with water rights
requirements, the Project should either 1) be designed to avoid diversion of water from Lake El
Estero by altering the Citys stormwater collection facilities to capture stormwater before it enters
Lake El Estero or 2) establish a valid basis of right for diversion and use of water in Lake El Estero,
either by including the Lake El Estero point of diversion in Water Right Application 32263 or by filing
a separate water right application.
C-2
Con't
C-3
More information regarding water right applications is available at:

http://www.waterboards.ca.gov/waterrights/
Reduction in Discharge of Treated Wastewater
Any owner of a wastewater treatment plant that proposes to change the point of discharge, place of
use, or purpose of use of treated wastewater must obtain approval of the State Water Board if the
change will result a decrease in flow in any portion of a watercourse. (Wat. Code, 1211 et seq.)
The Project proposes to include, as a source of water, a portion of the agricultural wash water that is
currently treated at the Salinas Industrial Wastewater Treatment Facility. After treatment, the treated
wastewater is discharged into percolation ponds adjacent to the Salinas River. These ponds
primarily function via percolation through seepage into the Salinas River with an estimated flow of
3 cubic feet per second into the Salinas River. Under the Project, an estimated 3,733 acre-feet
per year of treated wastewater may be redirected to the municipal wastewater collection system,
therefore reducing flow into the Salinas River by up to 2,170 acre-feet per year. Changing the place
of use and purpose of use for treated wastewater, as proposed in the DEIR, will require the approval
of the State Water Board because the change will result in a reduction of the discharge of treated
wastewater to the Salinas River. More information regarding wastewater change petitions is
available at:
http://www.waterboards.ca.gov/waterrights/water_issues/programs/applications/wastewaterchange/
C-4
Comments Regarding the Draft Environmental Impact Report

The DEIR should ensure consideration of all potential direct and indirect environmental impacts
associated with the diversion and use of water including, but not limited to, analyzing the availability
of unappropriated water; impacts of the diversion of water to instream resources including
development of mitigation measures that may include fish screens and bypass flows, and; impacts of
reducing the discharge of treated wastewater to the Salinas River.
C-5
Notes Regarding Compliance with California Water Rights Law

Unauthorized diversion and use of water is considered a trespass and subject to enforcement action
under Water Code sections 1052 and 1831. Pursuant to Water Code section 1052, any diversion of
water not covered by a valid basis of right may be subject to Administrative Civil Liability of up to
$500 per day without further notice. The State Water Board also may issue a Cease and Desist

Final EIR
4-13
September 2015
C-6
c/o Mr. Bob Holden
-3-
JUN 04 2015
Order in response to an unauthorized diversion or threatened unauthorized diversion pursuant to

Water Code section 1831.
Staff Contact
If you have any questions, please contact me at Justine.Herrig@waterboards.ca.gov or
(916) 341-5759. Written correspondence or inquiries should be addressed as follows: State Water
Resources Control Board, Division of Water Rights, Attn: Justine Herrig, P.O. Box 2000,
Sacramento, CA, 95812-2000.
Sincerely,
ORIGINAL SIGNED BY:
Justine Herrig
Coastal Lahontan Unit
Division of Water Rights
ec:

c/o David Chardavoyne
chardavoynede@co.monterey.ca.us
c/o Brent Buche
bucheb@co.monterey.ca.us
c/o Shaunna Juarez
juarezsl@co.monterey.ca.us
c/o Lisa McCann
Lisa.McCann@waterboards.ca.gov
c/o Harvey Packard
Harvey.Packard@waterboards.ca.gov
c/o James Rosauer
James.Rosauer@wildlife.ca.gov
c/o Annette Tenneboe
Annette.Tenneboe@wildlife.ca.gov

Final EIR
4-14
September 2015
C-6
Con't
LetterC: StateWaterResourcesControlBoard
C-1
The State Water Resources Control Board (State Board) provides information on components
of the project that may require water rights approval by the State Board and describes the
requirement for the CEQA document to consider all potential direct and indirect environmental
impacts associated with diversion and use of the water. The Draft EIR, as modified herein,
provides information and analysis necessary for the State Boards review and approval of water
rights applications for the Proposed Project. See also Master Response #3: Availability,
Reliability, and Yield of Source Waters in Chapter 3, Master Responses to Comments.
C-2
The State Board clarifies that the proposed point of diversion at Lake El Estero would require
an appropriative right from the State Board to divert up to 87 AFY into the municipal wastewater
system. This correction has been made in the EIR, and such an application will be pursued if
the proposed Lake El Estero diversion is implemented as part of the project. This application
would be separate and apart from Application 32263 (and the sub-applications) filed by
MCWRA. In response to this comment, changes have been made to Section 4.18 (see
changes to pages 4.18-24, 4.18-32, and 4.18-34 of the Draft EIR in Chapter 5, Changes to the
Draft EIR).
C-3
See the response to comment C-2, above.
C-4
The State Board clarifies that the proposed reduction of discharge of treated wastewater at the
Salinas Industrial Wastewater Treatment Facility (Salinas Treatment Facility) to percolation
ponds adjacent to the Salinas River would require the State Boards approval of a wastewater
change petition. A wastewater change petition will be pursued for the proposed reduction in
wastewater discharge. In response to this comment from the State Board, changes have been
made to Section 4.18 (see changes to pages 4.18-15, and 4.18-30 of the Draft EIR in Chapter
5, Changes to the Draft EIR).
C-5
The Draft EIR, in Sections 4.4, 4.5, 4.10, and 4.11 and accompanying technical reports,
provides description and analysis of the potential impacts (including individual and combined,
and direct and indirect) related to instream resources and surface water flows due to the
Proposed Project. The following sections of the Draft EIR as modified in this Final EIR (see
Chapter 5, Changes to the Draft EIR) analyze operational impacts of reduced flows in the
waterbodies downstream of the surface water (Reclamation Ditch Tembladero Slough, Blanco
Drain and Lake El Estero) and wastewater diversions (i.e., the impacts of reducing the
discharge of wastewater at the Salinas Treatment Facility):
Fisheries: See Appendices F-Revised and G that are summarized as relevant to the
Proposed Project in Section 4.4.4.4 (see pages 4.4-44 through 4.4-53 of the Draft EIR).
This section provides mitigation measures BF-1a, BF-1b, BF-1c, and BF-2 or Alternate
BF-2 for all significant impacts on fisheries resources.
Other aquatic/riparian habitat and wildlife: See Section 4.5.4.4 (pages 4.5-96 through
4.5-106 of the Draft EIR) that is based on detailed biological resource characterizations
in Appendices H and I and related hydrologic analyses in the next bullet.
Hydrology and water quality: See Appendices N, O-Revised, P, Q-Revised, and R (that
assess the availability of unappropriated water) which are summarized in the Draft EIR
on pages 4.10-57 through 4.10-64 (effects on groundwater systems in the Salinas
Valley), 4.11-64 through 4.11-75 (surface water quality and related hydrologic impacts).

Final EIR
4-15
September 2015
In addition to the Draft EIR parts above, see also response to comment F-5, F-8, G-3 through
G-13, and Master Response #3: Availability, Reliability, and Yield of Source Water Supplies,
Master Response #4: Reduction in Surface Water Flows, and Master Response #5: Fisheries
Impact Analyses in Chapter 3, Master Responses to Comments.
C-6
The State Board notes the importance of compliance with California water rights law and
potential consequences for non-compliance. The Draft EIR acknowledges the need to obtain
water rights in Chapter 2 (see page 2-88), in Section 4.18, Water Supply and Wastewater
Services (see page 4.18-13 through 4.18-15 as amended in this Final EIR), and in Appendix
C-Revised (as replaced in this Final EIR). In response to comments on the Draft EIR, some of
these sections have been modified as shown in Chapter 5, Changes to the Draft EIR of this
document.

Final EIR
4-16
September 2015
Letter D
!sTATE OF CALIFORNIA
EDMUND G. BROWN JR., Governor

JENNIFER LUCCHESI, Executive Officer
(916) 574-1800
Fa>< (916) 574-1810
California Relay Service TDDPhone 18007352929
from Voice Phone 1800-735-2922
CALIFORNIA STATE LANDS COMMISSION
100 Howe Avenue, Suite 100-5outh

Sacramento, CA 95825-8202
~u/t;,tf/,,/,:,. (p.U
Contact Phone: (9 16) 574-1890

Con ~ct FAX: (91 6) 574-1885
June 5, 2015
File Ref: SCH #2013051094
Bob Holden
Principal Engineer
Monterey, CA 93940
'
Subj ect: Draft Environmental Impact Report (EIR) f or Pure Water Monterey
Groundwater Replenishment Project, Monterey Coun ty
Dear Mr. Holden:
The California State Lands Commission (CSLC) staff has reviewed the subject Draft
EIR for the Pure Water Monterey Groundwater Replenishment Project (Project), which
is being prepared by the Monterey Regional Water Pollution Control Agency
(MRWPCA). The MRWPCA, as a public agency proposing to carry out a project, .is the
lead agency under the California Environmental Quality Act (CEQA) (Pub. Resources
. Code, 21000 et seq.). The CSLC is a trustee agency for projects that could directly or
indirectly affect sovereign lands and their accompanying Public Trust resources or uses.
Additionally, because the Project involves work on sovereign lands, the CSLC will act as
a responsible agency.
CSLC Jurisdiction and Public Trust Lands

'The CSLC has jurisdiction and management authority over all ungranted tidelands,
submerged lands, and the beds of navigable lakes and waterways. The CSLC also has
certain residual and review authority for tidelands and submerged lands legislatively
granted in trust to local jurisdictions (Pub. Resources Code, 6301 , 6306). All
tidelands and submerged lands, granted or ungranted, as well as navigable lakes and
waterways, are subject to the protections of the Common Law Public Trust.
As general background, the State of California acquired sovereign ownership of all
tidelands and submerged lands and beds of navigable lakes and waterways upon its
admission to the United States in 1850. The State holds these lands for the benefit of
all people of the State for statewide Public Trust purposes, which include but are not
limited to waterborne commerce, navigation, fisheries, water-related recreation, habitat
preservation, and open space. On navigable non-tidal waterways, including lakes, the
State holds fee ownership of the bed of the waterway landward to the ordir:~ar.y low
Final EIR
4-17
September 2015
D-1
Bob Holden
Page2
June 5, 2015
water mark and a Public Trust easement landward to the ordinary high water mark,
except where the boundary has been fixed by agreement or a court. Such boundaries
may not be readily apparent from present day site inspections.
Based on a review of our records, the proposed source water pipeline crossing near the
Blanco Drain Diversion will extend across the bed of the Salinas River which at this
location is natural, navigable, tidal, and meandered on both banks ofthe Rancho Plat.
The MRWPCA will be required to obtain a lease for the portion of pipeline crossing the
Salinas River. Please contact Drew Simpkin, Public Land Management Specialist (see
contact information below), for more information regarding CSLC jurisdiction and
leasing requirements.
D-1
Con't
Project Description
The MRWPCA proposes to provide purified recycled water to recharge a groundwater
basin and augment the existing Castroville Seawater Intrusion Project's crop irrigation
supply. MRWPCA's objectives and needs for the Project are as follows:
Replenish the Seaside groundwater basin w ith 3,500 acre-feet per year;
Commence operation of the Project by the end of 2016;
Supply reasonably-priced water to end users; and
Comply with water quality regulations.
From the Project Description, CSLC staff understands that the Project would include the
following components.
..
Source Water Diversion and Storage. New facilities would be constructed to

divert and convey new source water through the existing municipal wastewater
collection system to the Regional Wastewater Treatment Plant. One of the
pipelines for conveyance would be placed under the Salinas River, using
directional drilling methods.

Treatment Facilities at the Regional Wastewater Treatment Plant. A new
advanced water treatment plant would be constructed at the existing Regional
Wastewater Treatment Plant site.
Prod uct Water Conveyance. New pipelines, a pump station and appurtenant
facilities would be constructed to move the product water from the Regional
Wastewater Treatment Plant to the Seaside Groundwater Basin for injection.
Injection Well Facilities. New injection well f acilities would be constructed
including back-flush facilities, pipelines, electricity distribution facilities, and
electrical or motor control building.
Distribution of Groundwater from Seaside Basin. Two new California American
Water Company (CaiAm) water distribution pipelines would be constructed to
deliver the extracted groundwater to CaiAm customers.
The Draft EIR identifies Alternative B as the Environmentally Superior Alternative.

Alternative B would eliminate using source water from Tembladero Slough, which would
avoid significant and unavoidable noise impacts, and would require an alternative route
for the Monterey Pipeline, which would reduce significant construction impacts,
including the need for a transfer pipeline.
Final EIR
4-18
September 2015
D-2
Bob Holden
Page 3
June 5, 2015
Environmental Review .
CSLC staff requests that the MRWPCA consider the following comments on the
Projecfs Draft EIR.
Biological Resources
1. Drilling Noise: The EIR evaluates the Impacts of noise and vibration impacts on birds
from directional drilling and associated sheet pile driving activities during
construction of the Monterey pipeline. In addition to assessing noise impacts on
birds, the EIR should be revised to disclose whether sheet pile driving will be needed
for the other area of directional drilling to take place under the Salinas River, and
then evaluate the significance of noise and vibration impacts on fish from both the
directional drilling and possible pile driving. If impacts are found to be significant,
mitigation measures could include species-specific work windows as defined by the
California Department of Fish and Wildlife, U.S. Fish and Wildlife Service, and the .
National Oceanic and Atmospheric Adm inistration's National Marine Fisheries
Service. CSLC staff recommends that the EIR discuss any consultation that has
taken place with these agencies to minimize the impacts of the Project on sensitive
species, and the outcome of those consultations.
Thank you for the opportunity to comment on the Draft EIR for the Project. As a
responsible agency, the CSLC will need to rely on the Final EIR for the issuance of any
'new lease as specified above and, therefore, we request that you consider our
comments prior to certification of the EIR.
Please send copies of future Project-related documents, including electronic copies of
the Final EIR, Mitigation Monitoring and Reporting Program (MMRP), Notice of
Determination (NOD), CEQA Findings and, if applicable, Statement of Overriding
Considerations when they become available, and refer questions concerning
environmental review to Holly Wyer, Environmental Scientist, at (916) 574-2399 or via
e-mail at Holly.Wyer@slc.ca.gov. For questions concerning CSLC leasing ju'risdiction,
please contact Drew Simpkin, Public Land. Management Specialist, at (916) 574-2275,
or via email at Drew.Simpkin@slc.ca.gov.
Cy R. Oggins,
Division of Environmental Planning
and Management
cc: Office of Planning and Research
H. Wyer, CSLC
D. Simpkin, CSLC
J . Rader, CSLC

Final EIR
4-19
September 2015
D-3
LetterD: CaliforniaStateLandsCommission
D-1
The California State Lands Commission provides background information about the California
State Lands Commissions jurisdiction and identifies the specific project component that would
require a lease from this agency. The project proponents will obtain the required lease before
constructing the pipeline crossing the Salinas River near the Blanco Drain diversion.
D-2
No response is necessary; the comment reiterates information presented in the Draft EIR,
describing the Proposed Project (consistent with Chapter 2 of the Draft EIR) and the
Environmentally Superior Alternative (consistent with Chapter 6 of the Draft EIR).
D-3
According to E2 Consulting Engineers, the engineers that provided preliminary design services
for the proposed Blanco Drain diversion pipeline that would be drilled beneath the Salinas
River, no sheet pile driving would be needed for the directional drilling to take place under the
Salinas River. MRWPCA has begun consultation with the United States Fish and Wildlife
Service (USFWS) (email correspondence dated June 24, 2015 between Erin Harwayne, DD&A,
and Douglass Cooper, USFWS) and the National Oceanic and Atmospheric Administration,
National Marine Fisheries Service (NMFS) (telephone conversation between William Snider,
HDR, and Joyce Ambrosius, NMFS, June 20, 2015). The Proposed Project would have no
impact on fish due to noise during construction. The short duration of construction and the lack
of fish in the vicinity of the construction site during the directional drilling construction phase
would ensure that the construction would result in less-than-significant impacts. To ensure that
construction would be adequately protective of fish in the unlikely event that any are within the
Salinas River near the site of the construction, Mitigation Measure BF-1a on page 4.4-44 of the
Draft EIR has been amended to limit directional drilling construction under the Salinas River to
the months of June through November, which are outside of the South-Central California Coast
steelhead migration. See changes to page 4.4-44 of the Draft EIR in Chapter 5, Changes to
the Draft EIR. See also Master Response #5: Fisheries Impact Analyses in Chapter 3, Master
Responses to Comments.

Final EIR
4-20
September 2015
Letter E
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NAT ONAL MAR NE F SHEA ES SERV CE
West Coast Region

777 Sonoma Avenue, Room 325
Santa Rosa, Calilornia 95404
June 3, 2015
Bob llolden, Principal Engineer

Administration Office
llarris CourL, Auilding D
Monterey, California 93940
Dear Mr. Holden:
Thank you for the opportunity to comment on the Monterey Regional Water Pollution Control
Agcncis (MRWPCA) Draft. Environmental Impact Report (DEIR) for the Pure Water Monterey
Groundwater Replenishment Project (Project). MR WPC A is the Lead Agency under the
California Environmental Quality Act (CEQA).
E-1
The project includes the collection of a variety of ne\\ source waters and conveyance of that
water to the Regional Wastewater Treatment Plant for treatment and recycling. The water would
then be used for two purposes: replenishment of the Seaside Groundwater Basin with purified
recycled water to replace some of California American Water's (CAW) existing drinking water
supplies; and provision of additional recycled water supply for agricultural irrigation in northern
Salinas Valley. The new source waters would supplement the existing incoming wastewater
llows, and would include the following: I) water from the City of Salinas agricultural wash
water system, 2) stormwater llows from the southern part of Salinas and the Lake El Estero
facility in Monterey, 3) surface water and agricultural tile drain water that is captured in the
Reclamation Ditch and Tembladero Slough, and 4) surface water and agricultural tile drain water
that flows in t!1e Rlanco Drain.
NOAA s National Marine fisheries Service (NMf'S) is responsible for the administration of the
f'ederal Endangered Species Act (ESA) as it applies to threatened and endangered anadromous
salmonids. South-Central California Coast (S-CCC) steelhead Distinct Population Segment
(DPS) are listed as threatened under the ESA and are present in the Carmel River and the Salinas
River. Populations of steelhead within the S-CCC DPS are at critically low levels. NMFS
recently completed its recovery plan for S-CCC steelhead (NMFS 2013) and determined
steelhead in the Salinas River (including Gabilan Creek) is an essential population to recover for
the viability of the S-CCC DPS. Surface water diversions and passage impediments were
identified as a significant threat to steelhead survival and recovery in the Salinas River
E-2
~
.....
.,

Final EIR
4-21
September 2015
watershed. NMFS's primary concerns are impacts that may affect the S-CCC steelhead DPS and
their designated critical habitat including decreased flows in the Salinas River and the
Reclamation Ditch/Tembladero Slough. Any adverse impacts must be minimized to assure this
species does not become extinct. Decreasing flows can delay the migration of upstream adults
and downstream juveniles within the system. Decreased flows can contribute to increased water
temperatures and a decrease in water quality, both detrimental to salmonids. Demands on water
resources (i.e., groundwater and surface water) in the Salinas River and Gabilan Creek
watersheds have dramatically altered each system's hydrology and therefore have impaired
historical passage flows and the number of days available for migration of S-CCC steel head.
Any additional decrease in flows could result in jeopardy to the species.
NMFS applauds the Pure Water project to address CAW's overdrafting of the Carmel River
causing adverse impacts on S-CCC steclhcad. NMFS has been working with CAW to find an
alternate source of water for municipal use for many years. NMFS supports using recycled water
to reduce CAW's diversions from the Carmel River system by up to 3,500 acre-feet per year.
E-2
Con't
E-3
NMFS has provided only broad, general comments focused primarily on Section 4.4 Biological
Resources: Fisheries and Appendix G. Our comments are as follows:
Sali11as River:
In 2007, NMFS consulted with the U.S. Army Corps of Engineers on Monterey County Water
Resources Agency's (MCWRA) Salinas Valley Water Project (SVWP). In our 2007 Biological
Opinion (BiOp) (NMFS 2007), we established a flow prescription MCWRA is required to
follow. Minimum migration flows were established for this flow prescription. On Page 4.4.5 of
the DEIR under Flow Considerations, there are multiple references to MCWRA' s 2001 Draft
Environmental Impact Report/Environmental Impact Statement for the SVWP as the citation to
determine what flows are needed for steelhead migration in the Salinas River for the Pure Water
project. During consultation on the SVWP, NMFS rejected these flows because they were
inadequate for steelhead passage. The DEIR's Table 4.4-2 provides source documents for flow
thresholds for migration of different life stages of steelhead. The table uses MCWRA 2001 to
establish the flow criteria while only citing NMFS 2007 for timing of migration. It is unclear
why the DEIR chose to use MCWRA 2001 instead ofNMFS 2007. Using this obsolete data
causes an inherent flaw in the flow analysis for the DEIR. Determining impacts to S-CCC
steelhead based on this data is misleading and inaccurate. Unless there is better data available
that NMFS is unaware of, Pure Water DEIR needs to use flow criteria based on the flow data
found in NMFS 2007 to complete a robust analysis of impacts from changes in stream flow that
may interfere with fish migration.
The DEIR states that flow into the Salinas River may decrease due to withdrawals from the
various sources for the Project. MCWRA is required to meet the flow prescription in NMFS'
2007 SVWP BiOp even if a decrease in flow is due to the Pure Water Project. We recommend
you coordinate with MCWRA to ensure they are willing to provide additional flows from their
reservoirs if needed for the Project to be implemented.
Section 2.7.2.7 describes the need to install a pipeline under the Salinas River from Blanco
Drain. NMFS agrees using a trenchless method to install the pipe under the river can minimize

Final EIR
4-22
September 2015
E-4
E-5
E-6
affects to S-CCC steelhead habitat. llowcvcr, trcnchlcss construction can potentially result in
frac outs releasing drilling muds into rivers and causing adverse impacts to habitat. NMFS is
concerned the trench less method may not be the proper construction method due to the sandy
nature ofthe Salinas River. Please ensure this construction method would result in the least
amount of impacts to listed species.
NMFS is very supportive of removing agricultural runoff high in pesticides and nutrients from
entering the Salinas River. For years we have requested MCWRA to either implement actions to
improve water quality in the Blanco Drain (i.e., vegetated treatments) or divert the Blanco Drain
runoff so it does not enter the river. However, removing storm water runoff that historically
entered the river and provided additional winter flows for steelhead migration is a concern to
NMFS. The Project must ensure that flows are not decreased to a point that would impact
migration of S-CCC steel head.
Rec/amatio11 Ditclt am/ Temhladero S/ouglt:

In Appendix G, Hagar Environmental Science (liES) acknowledges there are inherent errors
associated with the methods used to assess minimum passage flow estimates which would yield
an accuracy of+/- 30%. More data, particularly those that address California Department of Fish
and Wildlife protocols for passage suitability, must be collected and analyzed to provide a better
assessment of potential impacts to fish passage from surface water diversions at the two
locations, Reclamation Ditch and Tembladero Slough (particularly the Davis Road location).
The DEIR is relying on limited and potentially inaccurate data to determine impacts to steelhead
migration in the Reclamation Ditch and Tembladero Slough. NMFS does not agree the bypass
flows for the Reclamation Ditch or the Tcmbladero Slough are adequate for passage of adult
steelhead and recommends working with NMFS to identifY needed flows for steelhead
migration, especially in the Reclamation Ditch.
On pages 48-49 of Appendix G, HES assumes steelhead will not be in the Reclamation Ditch
when flows are below a certain flow threshold, which may not be accurate. It is possible that
adult steelhead enter the system on the declining hydrograph of a storm when flows then recede
to levels lower than these thresholds. For example, diverting up to 6 cubic feet per second (cfs)
from the Reclamation Ditch during March (Table 8) would leave only 2 cfs (or less) in the
channel and would therefore potentially expose adult steelhead to stranding, poaching or
predation and/or poor water quality. The diversions would expose steelhead to these threats in
the Reclamation Ditch until (and if) subsequent storms improved passage.
In conclusion, NMFS disagrees with the identified minimum flows for steel head passage in both
the Salinas River and the Reclamation Ditch/Tembladero Slough since they were determined
from an incomplete analysis. Because of this, it is difficult to assess if the effects and mitigation
determination in the DEIR is accurate or adequate to protect steelhead. We recommend the
DEIR reevaluate impacts to listed species with more accurate passage flow data that are
acceptable to NMFS.
The Pure Water Project will most likely need a U.S. Army Corps of Engineers Clean Water Act
(Section 404) permit. To issue a permit, the Corps must consult with NMFS under the ESA.
NMFS strongly recommends MRWPCA work with us early on in the development/design phase

Final EIR
4-23
September 2015
E-6
Con't
E-7
E-8
E-9
E-10
E-11
to ensure the project will avoid impacts to listed species and their designated critical habitat,
while improving groundwater replenishment within Monterey County.
Please contact Ms. Joyce Ambrosius at (707) 575-6064, or via email at
joycc.ambrosius@noaa.gov should you have any questions regarding this letter.
Sincerely,
{j:::f'- 0-....S... ""'-r~

~:r--Aiecia Van Alta
Acting Assistant Regional Administrator

California Coastal Office
cc:
Julie Vance, CDFW, Fresno

Rich Svindland, CAW, Sacramento
Copy to Chron File
Literature Cited
Monterey County Water Resources Agency. 2001. Draft Environmental Impact

Report/Environmental Impact Statement for the Salinas Valley Water Project. Online at:
http://www.mcwra.co.montcrey.ca.us/SVWP/DEIR_EIS_2001/index.htm.
National Marine Fisheries Service (NMFS). 2007. Biological opinion issued to the U.S. Army
Corps of Engineers for the Monterey County Water Resources Agency's Salinas Valley
Water Project in Monterey County, California. National Marine Fisheries Service, Long
Beach, California. SWR/2003/2080. ARNI51422SWR2003SR8711. June 21,2007.
122 pages.
NMFS. 2013. South-Central California Coast Steel head Recovery Plan. West Coast Region,
California Coastal Area Office, Long Beach, California.

Final EIR
4-24
September 2015
E-11
Con't
LetterE: NationalOceanicandAtmosphericAdministration
E-1
The National Oceanic and Atmospheric Administration, National Marine Fisheries Service
(NMFS) reiterates information presented in the Draft EIR describing the Proposed Project; no
response necessary.
E-2
NMFS presents background information regarding its jurisdiction and the status of the SouthCentral California Coast (S-CCC) steelhead Distinct Population Segment (DPS). The
information provided by NMFS is consistent with the description in the Draft EIR in Sections
4.4.2.2 and 4.4.3.1. Comments regarding NMFS responsibility for the administration of the
Federal Endangered Species Act (FESA) are acknowledged. Further, MRWPCA understands
that NMFS' primary concerns are impacts that may affect the S-CCC steelhead DPS and its
designated critical habitat including decreased flows in the Salinas River, the Reclamation
Ditch, and Tembladero Slough.
The EIR recognizes a variety of existing man-made alterations in the Salinas River and
Reclamation Ditch watersheds, including surface water diversions, passage barriers, and
channel alterations that have substantially degraded habitat conditions. The analysis in the
Draft EIR (Section 4.4.4.4 under Impact BF-2, as amended in this Final EIR) shows that
potential impacts to S-CCC steelhead and its habitat from Proposed Project flow diversions
would be less than significant in the Salinas River and less than significant with implementation
of recommended mitigation measures in the Reclamation Ditch.
While there is evidence to show that a population of steelhead exists in the Salinas River
watershed, it should be noted there is no evidence of a population in the Reclamation Ditch
watershed. Nonetheless, the analysis for the Draft EIR and Final EIR conservatively assumes
S-CCC could be present downstream of the Proposed Project diversion at Davis Road in the
Reclamation Ditch and in the Tembladero Slough.
As noted in the Draft EIR Section 4.4, the United States Fish and Wildlife Service (USFWS),
NMFS and CDFW will be consulted about the Proposed Projects potential direct or indirect
effects on federally-listed threatened, endangered, or candidate species at the Proposed
Projects sites and surrounding areas and to identify measures to reduce such effects. The goal
of this process is to address NMFS's primary concerns of potential effects on the S-CCC
steelhead DPS and its designated critical habitat, which include decreased flows in the Salinas
River and the Reclamation Ditch/Tembladero Slough. The lead agency agrees that adverse
impacts must be minimized.
See also Master Response #4: Reduction of Surface Water Flows and #5: Fisheries Impact
Analyses in Chapter 3, Master Responses to Comments, and Chapter 5, Changes to the
Draft EIR (specifically, changes within Draft EIR section 4.4).
E-3
NMFS commends the Proposed Project for addressing the overdrafting of the Carmel River and
adverse impacts on S-CCC steelhead in the Carmel River. NMFS states support of the use of
recycled water to reduce Cal-Ams diversions from the Carmel River system by up to 3,500
AFY. The comment is referred to the decision makers for their consideration as it states an
opinion of the Proposed Project.
E-4
As stated in this comment, the Biological Opinion (BO) for the Salinas Valley Water Project
SVWP (NMFS, 2007) includes prescriptions that are to be implemented to enhance upstream
migration of adult steelhead and downstream migration of juvenile, smolt and kelt steelhead
within the Salinas River essentially between San Antonio River and the Pacific Ocean. NMFS
notes that the Draft EIR does not reference the 2007 flow prescriptions from the BO for the

Final EIR
4-25
September 2015
SVWP (NMFS, 2007). Additional language has been added to the Draft EIR to identify the 2007
flow prescriptions. In this response, HDR, fishery biologists for the Draft EIR, provides the
rationale for the flow passage requirements used in the Draft EIR analysis and also addresses
the NMFS 2007 criteria, as discussed below and in Chapter 5, Changes to the Draft EIR,
under the section titled Changes to Section 4.4, Biological Resources: Fisheries. The 2007
criteria compliance point is upstream of the Proposed Project for both migration life stages. The
criteria were based on evaluation of flows required to provide suitable conditions to
accommodate S-CCC steelhead migrations past channel conditions that were considered
unique to the Salinas River and required river-specific hydraulic passage criteria. The rationale,
development, and identification of these conditions and flows required to meet those criteria
within the Salinas River are reported by NMFS (2005)1 and were the basis for the flow
prescriptions provided in the BO (NMFS, 2007).
The Draft EIR recognized the required flow prescriptions (see Page 4.4-6 of the Draft EIR) but
did not include those criteria in the evaluation of project effects on migration within the
Proposed Project area for several reasons, as discussed below. Nonetheless, this Final EIR in
Chapter 5, Changes to the Draft EIR, Section 4.4, now includes an evaluation of the
Proposed Projects potential effects on the flow prescriptions in the 2007 NFS BO based on
NMFS comment letter. The evaluation concludes that the Proposed Projects diversions would
not significantly affect the conditions for upstream and downstream migration as defined in the
2007 BO.
The Draft EIR included passage criteria developed by MCWRA (MCWRA, 2001) for the lower
Salinas River to assure a comprehensive evaluation of fish passage within the range of
conditions that would be affected by implementation of the Proposed Project based on the
following:
The study reach addressed by NMFS to assess channel conditions and relevant
passage criteria did not include the reach downstream of Spreckels and therefore
did not directly address channel conditions in the Salinas River that would be
affected by the Proposed Project.
The maximum potential reduction in flow to the Salinas River resulting from the
Proposed Project is 9 cfs, from a combination of direct diversion of up to 6 cfs in
the Blanco Drain and the cessation of 3 cfs of percolation into the river from the
SIWTF ponds. The maximum diversion would occur between July through
September when the SIWTF ponds are dry. This is outside the S-CCC steelhead
migration windows. The maximum potential reduction in flow to the river
downstream of the confluence with Blanco Drain during the migration period
(October through June) is 6 cfs. Based on an evaluation threshold of 10 percent,
the Proposed Project Draft EIR found that significant impacts could occur when
baseline flows are 65 cfs or less within the Salinas River. Inasmuch as the BO
prescriptions are several fold greater than the flows potentially affected by the
Proposed Project, the Draft EIR focused on potential conditions within the Project
area that might be affected by the Proposed Projects maximum diversion rate.
Although the conditions assessed in the MCWRA 2001 SVWP EIR were rejected as
representative of conditions being addressed in the BO for the SVWP, the biologists who
prepared the Draft EIR determined that including the evaluation of the Proposed Project effects
NMFS. 2005. Salinas Valley water project flow proposal for the biological needs of steelhead in the Salinas River.
Report prepared by the Santa Rosa office of NMFS, Southwest Region for MCWRA, Santa Rosa, California

Final EIR
4-26
September 2015
on migration conditions as described in the MCWRA 2001 SVWP EIR would provide a
comprehensive assessment of potential Proposed Project effects on steelhead within the study
area. Channel conditions downstream of Spreckels potentially differ from those evaluated for
fish passage upstream of the Proposed Project diversions due to variation in channel geometry
(width), vegetation, flood facilities and flow. The Draft EIR considers these variations as
sufficient reason to address fish passage within this reach using standard passage criteria as
provided in Table 4.4-7 of the Draft EIR as modified in this Final EIR. See changes to page 4.437 of the Draft EIR in Chapter 5, Changes to the Draft EIR.
To respond to the comment, additional evaluation of the Proposed Project effects, using the
prescribed flows specified in the NMFS 2007 SVWP BO, has been performed for this Final EIR.
The additional analysis confirms the conclusions in the Draft EIR and augments the Draft EIRs
assessment of flow conditions required for upstream and downstream steelhead passage in the
Project area. See also Master Response #4: Reduction of Surface Water Flows and Master
Response #5: Fisheries Impact Analyses in Chapter 3, Master Responses to Comments.
E-5
MRWPCA agrees with the comment and will continue coordination with MCWRA to ensure flow
prescriptions in the NMFS 2007 SVWP BO are met. See also comment M-36, response to
comment T-9, and Master Response #4: Reduction of Surface Water Flows, and Master
E-6
The proposed approach for drilling under the Salinas River will comply with NMFS request to
ensure impacts to species are minimized. Mitigation Measure BT-2c: Avoidance and
Minimization of Construction Impacts Resulting from Horizontal Directional Drilling under the
Salinas River (Applies to Blanco Drain Diversion) requires completion and implementation of a
Frac-Out Plan to avoid or reduce accidental impacts resulting from horizontal directional drilling
(HDD) beneath the Salinas River. Mitigation Measure BT-2c from the Draft EIR Biological
Resources, Terrestrial Section, has been revised and expanded in this Final EIR to explain
when and how the plan would be prepared and reviewed, and to describe the contents.
Mitigation Measure BT-2c requires that the Frac-Out Plan be submitted to CDFW, NMFS,
USFWS, and the Regional Water Quality Control Board during the project permitting and may
be subject to approval by those agencies prior to commencement of HDD activities for the
Blanco Drain Diversion construction. See revisions to page 4.5-94 of the Draft EIR in Chapter
5, Changes to the Draft EIR to see the full text of this mitigation measure including required
biological monitoring. See also response to comment H-36 and Master Response #5: Fisheries
E-7
The comment states NMFS support for proposed removal of agricultural runoff carrying high
levels of pesticides and nutrients that would otherwise enter the Salinas River. NMFS' primary
concerns are impacts that may affect the S-CCC steelhead DPS and their designated critical
habitat including decreased flows in the Salinas River. See the response to comment E-2,
Master Response #4: Reduction of Surface Water Flows and Master Response #5: Fisheries
E-8
NMFS identifies the statement in Appendix G to the Draft EIR that acknowledges there are
inherent errors associated with the methods and models standardly used to assess fish
passage and notes that the analysis assumes a +/- 30% accuracy to account for this. NMFS
does not agree the amount of data used to evaluate the potential effects of Proposed Projects
two diversions on fish passage in Reclamation Ditch is adequate and suggests the evaluation
would benefit from working with NMFS to identify more precise flow recommendations.
As described in Appendix G, there are no critical passage sections downstream of the
Proposed Project diversion near Castroville. As further described in Master Response #4 to
clarify the Appendix G conclusions, this reach is tidally influenced and a set of tide gates just

Final EIR
4-27
September 2015
upstream of Moss Landing Harbor influences water levels up to the Highway 183 crossing
upstream of the point of diversion. Based on the technical analysis and mitigation measures
prepared by HDR and Hager Environmental Science (HES) fisheries biologists, the Draft EIR
found that project impacts to fisheries from diversions at this location would be less than
significant; however barriers upstream of the proposed Castroville diversion point pose more of
a challenge.
In response to NMFS concerns, Schaaf and Wheeler conducted detailed supplemental
analysis of passage at two locations in the watershed one at the USGS Reclamation Ditch
gage at San Jon Road and the other near the mouth of Gabilan Creek within the City of Salinas
(see Appendix CC in this Final EIR and response to comment E-10 below). Although the latter
passage impediment is not affected by the proposed diversion in the Reclamation Ditch at
Davis Road, the analysis in Gabilan Creek helps illuminate just one of the many constraints in
this sub-watershed to establishing a persistent population of steelhead. See Figures 4.4-6a and
4.4-6b on pages 4.4-67 and 4.4-68 of the Draft EIR. The results of the passage analysis show
that the flow rate necessary to provide passage near the mouth of Gabilan Creek into the upper
reaches of the watershed is more than two times the flow required for passage downstream of
Davis Road in the Reclamation Ditch. No anadromous steelhead spawning and rearing have
been recorded in this sub-watershed and there is evidence to suggest the potential historic
spawning and rearing habitats near the headwaters of Gabilan Creek may be inaccessible due
to numerous barriers at road crossings and the presence of a stock pond at the base of the
headwaters.
Nonetheless, the Final EIR conservatively assumes S-CCC could be present in the
Reclamation Ditch below the proposed diversion site at Davis Road, and determines that it is
possible to divert low and high seasonal flows from the Reclamation Ditch (with well-defined
rules to protect passage windows) without further reducing the possibility of fish passage
downstream of the proposed Davis Road diversion.
The reach in the Reclamation Ditch that will be affected by Proposed Project diversions
includes two known fish passage impairments downstream of the Davis Road point of
diversion, as described on page 4.4-39 of the Draft EIR and in Appendix G. The Schaaf and
Wheeler Technical Memo on Fish Passage included as Appendix CC in this Final EIR focuses
on the more severe of the two barriers studied in Appendix G the weir at the USGS
Reclamation Ditch gage at San Jon Road. The analysis allows for a more accurate
characterization of passage flow thresholds based on current passage criteria and concludes
that the Proposed Project could adversely affect passage of adult and juvenile (smolt)
steelhead when flows at the weir are in a range of 75 to 81 cfs for adult passage and 40 to 46
cfs for juvenile passage. The Proposed Projects diversions at Davis Road will be operated to
avoid reducing passage opportunities as required by Mitigation Measures BF-2a (or alternate
Mitigation Measure BF-2b) as amended in this Final EIR (see changes to pages 4.4-48 and
4.4-49 of the Draft EIR in Chapter 5, Changes to the Draft EIR). In order to divert up to 6 cfs
of flow while still maintaining the required 75 and 40 cfs instream, flow diversions could occur
when flows are below 75 cfs or in excess of 81 cfs (during adult migration season), and below
40 cfs or in excess of 46 cfs (during juvenile migration season). According to Schaaf &
Wheeler, these passage flows could be feasibly implemented while still achieving the Proposed
Project objectives, see Appendix CC.
The Proposed Project will be operated to provide passage and to avoid reducing flow below the
identified passage thresholds. The project proponents are required to work with NMFS to
confirm needed flows for steelhead migration in the Reclamation Ditch. To ensure adequate
passage flows in the Reclamation Ditch, the final facility design and flows would be approved
by NMFS in accordance with Mitigation Measure BF-2a, or Alternate Mitigation Measures BF2a (see pages 4.4-48 through 4.4-50 of the Draft EIR, as amended in Chapter 5 Changes to
the Draft EIR, and Master Response #5: Fisheries Impact Analyses). The lead agency is
committed to working with NMFS to confirm needed flows for steelhead migration in the
Reclamation Ditch.
Final EIR
4-28
September 2015
E-9
Based on the best available information, there is no established population of steelhead in the
Reclamation Ditch or its tributaries. The Proposed Project is not likely to adversely affect the
opportunity or likelihood of a population becoming established. (HDR, 2015).
The potential for the Proposed Project to result in additional occurrences of migrating adults
being stranded on the declining limb of a storm hydrograph, as suggested in this comment, is
extremely low. Post-storm flow recessions in the Reclamation Ditch watershed typically occur
within hours. The statement in Appendix G of the Draft that steelhead will not be in the
Reclamation Ditch when flows are below a certain flow threshold is based in part on the
expectation that adult steelhead would not hold in the stream as flows rapidly decline to near 8
to 14 cfs. However, as stated above in the response to comment E-2, the Proposed Project will
be operated according to well-defined rules to avoid creating conditions that would strand or
otherwise harm adult steelhead if they were present.
The final facility design and flows would incorporate passage flows acceptable to NMFS (see
last paragraph on page 4.4-50 of the Draft EIR), Master Response #4: Reduction of Surface
Water Flows, and Master Response #5: Fisheries Impact Analyses in Chapter 3, Master
E-10
This Final EIR contains the requested evaluation of impacts to steelhead in the Salinas River to
include evaluation of the Proposed Projects effects on the flow prescriptions identified in the
2007 SVWP BO (NMFS). As reported in Appendix O of the Draft EIR (which has been revised
in this Final EIR document as shown in Appendix O revisions in Chapter 5, Changes to the
Draft EIR) and in Master Response #4: Reductions in Surface Water Flow, the Proposed
Project will not affect the frequency or duration of flows prescribed in the SVWP BO for
enhancement of adult upstream migration and juvenile, smolt and kelt downstream migrations.
Schaaf & Wheeler has also prepared a technical memorandum, attached as Appendix CC to
this Final EIR, containing the results of further analysis of passage flow at the USGS gage at
San Jon Road (Schaaf and Wheeler, 2015). This technical memo assesses hydraulic
conditions through structures that may present obstacles to upstream and downstream
anadromous fish migration in the Reclamation Dich/Gabilan Creek watershed. Two sites are
analyzed: the Reclamation Ditch at the San Jon Road bridge/weir, and Gabilan Creek at the
Laurel Road culvert; however, only the analysis of the San Jon Road weir is relevant to
potential impacts from the Proposed Project. The purpose of the analysis is to determine (1)
whether the weir poses an obstacle to fish passage, and if so, under what range of flows, (2)
whether withdrawals of up to 6 cfs from the Reclamation Ditch at Davis Road for the Proposed
Project will reduce the likelihood of fish passage downstream of the proposed diversion point,
and (3) if withdrawals will reduce the likelihood of fish passage downstream of the diversion
point, the range of flows at which withdrawals should be curtailed in order to maintain fish
passage.
Initially, Schaaf and Wheeler applied FishXing v3.0, a publicly available modeling program from
the US Forest Service, to assess passage flow requirements. The program allows the user to
model flow through various stream/road crossing structures. It also allows the user to evaluate
the ability of fish and other aquatic species to navigate these structures based on speciesspecific physiological parameters such as minimum required water depth, swimming speed and
endurance. FishXing was initially used to calculate water surface profiles through the San Jon
Road weir to determine what ranges of flows might allow for successful upstream passage of
adult steelhead and downstream passage for juveniles.
Due to the complexity of the San Jon Road barrier and limitations of the FishXing model,
Schaaf and Wheeler has since created a more detailed and reliable Hydrologic Engineering
Centers River Analysis System (HEC-RAS) model to more precisely determine passage flows

Final EIR
4-29
September 2015
in this area. The results of the HEC-RAS model are suitable for identifying minimum flows
required for fish passage in the affected reach of Reclamation Ditch and evaluating potential
effects on steelhead passage conditions. See also the response to comment E-11, Master
Response #4: Reduction of Surface Water Flows and Master Response #5: Fisheries Impact
Analyses in Chapter 3, Master Responses to Comments.
E-11
It is acknowledged that the Proposed Project will require federal actions that are subject to
consultation under the federal Endangered Species Act and MRWPCA will work with NMFS as
early as necessary to avoid impacts to listed species and their designated critical habitat. See
also Master Response #5: Fisheries Impact Analyses in Chapter 3, Master Responses to
Comments.

Final EIR
4-30
September 2015
Letter F
June 5, 2015
Bob Holden, Principal Engineer

Monterey Regional Water Pollution Control
Agency
gwr@mrwpca.com
Dear Mr. Holden:

DRAFT EIR FOR PURE WATER MONTEREY GROUNDWATER REPLENISHMENT
PROJECT
The Central Coast Regional Water Quality Control Board appreciates the opportunity to review
and comment on the draft environmental impact report for the Pure Water Monterey
Groundwater Replenishment Project. We have the following comments:
1. The project would rely upon supply water from multiple sources, including domestic
wastewater, industrial wastewater, agricultural return waters, and storm water, all
conveyed to the treatment facility via existing municipal wastewater collection and
conveyance systems. The draft EIR does not directly address the possibility of sanitary
sewer overflows (SSOs), except to say in section 4.18.2.2 that:
Local cities and sanitation districts are responsible for maintenance and extension of
sewer lines, and the Monterey Regional Water Pollution Control Agency (MRWPCA) is
responsible for development and operation of treatment facilities, trunk main pipelines
and pump stations.
This is contradicted to some degree in section 2.7.2.7 where it is explained that:
F-1
The Blanco Drain Pump Station would be similar to the Reclamation Ditch and
Tembladero Slough Pump Stations, configured to operate autonomously based upon
diversion settings. A system operator would visit the site once a day to check for alarms,
vandalism and to visually inspect the intake screen for clogging. The site is adjacent to
the Monterey County Water Resources Agencys Blanco Drain Pump Station, and may
require separate visits by operators from the two agencies or the two agencies can enter
into an agreement for shared maintenance responsibilities.
And in section 2.7.2.8, which states:
The Lake El Estero diversion pump station would operate autonomously, based upon
lake levels and water levels in the receiving sanitary sewer. System operators from the
City would visit the site with the same frequency as operators visit the existing pump

Final EIR
4-31
September 2015
Mr. Bob Holden

MRWPCA
-2-
June 5, 2015
station, approximately once per week when not operating and multiple times per day
while in operation.
As the already complex MRWPCA system becomes even more complicated,
responsibilities for dealing with SSOs need to be unambiguous whenever and wherever
they might occur. To that end, please add a section in the EIR that clearly delineates
which public entities are responsible for both maintaining the infrastructure and
responding to and cleaning up SSOs that may occur anywhere in the sanitary sewer
systems connected to the proposed project.
2. In the Wetland Delineation section in section 4.5.2.1 Biological Project Study Area, the
list of agencies with jurisdiction over the potential wetlands in affected reaches should
include the Central Coast Water Board. Wetlands are considered waters of the state
and are protected by the Central Coast Water Board. Please identify the Central Coast
Water Board along with the other agencies with jurisdiction over wetlands.
F-1
Con't
F-2
3. Central Coast Water Board staff found several errors in the DEIRs section 4.11.3.1
Federal and State Regulations, regarding Central Coast Water Board requirements and
authorities as they relate to the Clean Water Act. Please edit the text to reflect the
following statements.
a. Section 401 Water Quality Certifications are issued to protect water quality and
the beneficial uses of water from projects that may result in discharges of dredge
and fill.
b. The Central Coast Water Board does not issue waivers of Section 401 Water
Quality Certifications.
c. The Central Coast Water Board only issues Section 401 Water Quality
Certifications for projects that may discharge dredge of fill to waterbodies that are
under the jurisdiction of the USACOE.
d. The Central Coast Water Board may issue other waste discharge requirements
(permits) for discharges of dredge or fill to waterbodies not under the jurisdiction
of the USACOE, but that are waters of the state.
4. The discussion in section Impact BT-2 Construction Impacts to Sensitive Habitats
regarding the Tembladero Slough Diversion Affected Reaches insufficiently identifies
potential threats to state waters. The State has jurisdiction over any surface water or
groundwater, including saline waters, within the boundaries of the state (California
Water Code section 13050(e)), a broader definition than waters of the U.S.
Please edit this discussion to identify the approximately 0.2 acres of permanent impacts
to other waters of the U.S. and 0.01 acres of impacts to coastal wetlands as impacts to
waters of the state that require mitigation to protect water quality and beneficial uses,
and to reduce impacts to a less-than-significant level.
Central Coast Water Board staff finds that additional discussions regarding impacts,
within section Impact BT-2 Construction impacts to Sensitive Habitats, also fail to identify
impacts to waterbodies and wetland or riparian habitats as impacts to waters of the
state. Please also edit these sections to identify impacts to waterbodies and wetland or
riparian habitats as impacts to waters of the state.

Final EIR
4-32
September 2015
F-3
F-4
Mr. Bob Holden

MRWPCA
-3-
June 5, 2015
5. Permanent structures or hardscapes located within a waterbody can cause erosional

problems within these sensitive habitats downstream, upstream, or at the location of the
structure/hardscape.
The DEIR should include an assessment of potential impacts to fluvial geomorphological
processes in sensitive habitats due to construction of permanent structures or hardscape
in a waterbody. The fluvial geomorphological assessment should include:
F-5
a. Assessment of the potential for undercutting or erosion to upstream, opposite,

and/or downstream banks and bed.
b. Assessment of the response of the waterbody morphology to changes in flow
velocity and channel capacity, cross section, length, or gradient.
Should potentially negative impacts on fluvial geomorphological processes in the
sensitive habitats be discovered based on the assessment, mitigation identified in the
EIR should include assessment of structure or hardscape redesign to alleviate the
potential negative fluvial geomorphological impacts.
6. Mitigation Measure BT-2a Avoidance and Minimization of Impacts to Riparian Habitats
and Wetland Habitats is not sufficient to reduce the potential impacts to riparian and
wetland habitats to a less than significant level because:
a. The mitigation measure identifies placing construction fencing around these
habitats to protect the habitats from construction activities. While construction
fencing is necessary, it is insufficient to prevent impacts from construction
activities that involve the movement and use of materials such as sediment,
concrete, hazardous chemicals, and fluids, including water, that may discharge to
riparian and wetland habitats.
To sufficiently protect water quality and the beneficial uses of water and reduce
impacts from construction areas to a less than significant level, mitigation should
be included such as:
i.
ii.
F-6a
To protect against spills and fluids leaking from equipment, the project
should maintain an on-site spill plan and on-site spill containment
measures that can be easily accessed.
Refueling or maintaining vehicles and equipment should only occur within
a specified staging area that is at least 100 feet from a waterbody
(including riparian and wetland habitat) and that has sufficient
management measures that will prevent fluids or other construction
materials including water from being transported into waters of the state.
Measures should include confined concrete washout areas, straw wattles
placed around stockpiled materials and plastic sheets to cover materials
from becoming airborne or otherwise transported due to wind or rain into
surface waters.
b. Impacts to riparian and wetland habitat that are proposed to be mitigated must be
identified as either temporary or permanent. A 1:1 replacement-to-loss ratio is

Final EIR
4-33
September 2015
F-6b
Mr. Bob Holden

MRWPCA
-4-
June 5, 2015
insufficient to mitigate permanent impacts to less-than-significant levels for this

habitat, and may also be insufficient for temporary impacts.
The states goal is that there be no net loss of wetlands. To meet this goal the
state issued a policy, commonly referred to as the No Net Loss Policy for
wetlands. To uphold the policy and to protect waters, permanently impacted
wetland and riparian habitat should be replaced at a higher ratio than 1:1. A
higher ratio is necessary because re-established or rehabilitated habitat may fail
to provide the same functions as the impacted habitat, and the additional reestablished habitat that is the result of a higher mitigation ratio may serve to
offset the loss of functions in the impacted habitat.
F-6b
Con't
Permanent impacts should be mitigated at a ratio of at least 2:1. A larger

replacement ratio should be required if any of the following apply:
i. There is a lag between the time of impact and time of replacement.
ii. The mitigation site is not at or near the impact site.
iii. The replacement habitat will be of lesser quality than the impact habitat
considering characteristics such as species diversity and abundance,
physical and chemical characteristics.
iv. The replacement habitat will provide less ecological function than the
impact habitat.
v. Other differences between the two habitats that may lead to a
replacement habitat of lesser value than the impact habitat.
Temporary impacts should be mitigated at a 1:1 replacement-to-loss ratio, or
greater, taking into consideration the reasons for increasing the permanent
impact ratio.
c. The DEIR mentions preservation as a means of mitigation. Using preservation for
mitigation of permanent loss of habitat results in a net loss of habitat.
Preservation should not be used as mitigation for permanent impacts.
F-6c
If preservation of habitat were to be used as mitigation for temporary impacts,

development of the mitigation ratio should take into consideration the above
reasons for increasing the permanent impact ratio.
7. The discussion regarding regulatory requirements in Impact Statement HS-2:
Construction Impacts to Surface Water Quality due to Earthmoving, Drainage
Alterations, and Use of Hazardous Chemicals (p.4.11-61) is insufficient. The All Project
Components discussion appropriately includes identification of the NPDES Construction
General Permit and Municipal Stormwater Permit requirements. However, the
discussion lacks identification of the requirements of the Central Coast Water Board for
discharges of dredge and fill to waters of the state.
The action of moving earth within waters of the state (such as with trenching or
excavation) is considered a discharge and requires a permit. If the U.S. Army Corps of
Engineers (USACOE) claims jurisdiction in the subject waterbody where the discharge
may occur, the Central Coast Water Board also will need to review the action and
potential discharge and issue a Clean Water Act Section 401 Water Quality Certification
if the Central Coast Water Board can determine that the action will be protective of water

Final EIR
4-34
September 2015
F-7
Mr. Bob Holden

MRWPCA
-5-
June 5, 2015
quality and the beneficial uses of water. If the USACOE does not take jurisdiction, the
Central Coast Water Board may issue waste discharge requirements (a permit) for
impacts to waters of the state.
8. The DEIR should ensure consideration of all potential direct and indirect environmental
impacts associated with the diversion and use of water including, but not limited to,
analyzing the availability of unappropriated water; impacts of the diversion of water to
instream resources including development of mitigation measures that may include fish
screens and bypass flows; and impacts of reducing the discharge of treated wastewater
to the Salinas River, reduction in flows to both the Salinas River and the coastal sloughs
in the area (e.g., Elkhorn Slough (a National Estuarine Reserve), and Moro Cojo Slough.
9. The DEIR includes and relies on technical reports and analyses evaluating the potential
environment effects of the various proposed surface-water diversions due to reduced
flows in portions of the watershed, with an emphasis on fisheries beneficial uses. The
appendices include independent analyses of the potential downstream effects for the
following diversions: the Reclamation Ditch and Tembladero Slough, the Blanco Drain,
and the Salinas Industrial Wastewater Treatment Facility. The appendices also include
analyses of the combined potential effects of the Salinas Industrial Wastewater
Treatment Facility, City of Salinas (southwest portion) stormwater runoff, and Blanco
Drain diversions on the Salinas River at a point just downstream of the Salinas River
Diversion Facility rubber dam, as well as water supply yield studies for the Reclamation
Ditch and Blanco Drain diversions, and an urban runoff capture/yield study for the Lake
El Estero diversion (not tributary to the Salinas River or Sloughs).
However, the DEIR does not appear to include analyses of the potential cumulative
effects of all the proposed diversions on downstream portions of the watershed due to
reduced flow. More specifically, the DEIR and supporting technical documents provided
within the appendices do not appear to contain analyses of the cumulative decrease in
surface water flows to downstream portions of the watershed, particularly the Old
Salinas River, Tembladero Slough, and Elkhorn Slough, due to all of the proposed
project diversions. This portion of the watershed consists of a complex and
interconnected system of brackish tidal and wetland habitats supporting a variety of
social and environmental functions, not the least of which is providing habitat to state
and federally listed species. Potential short- and long-term effects of decreased surface
water flows and shallow groundwater recharge in the coastal portions of the watershed
do not appear to be adequately evaluated in the DEIR and could result in potentially
significant impacts associated with the following CEQA environmental resource topics:
a. Aesthetic (AE-3) impacts associated with the degradation of visual quality of sites
and surrounding areas due to the reduction of brackish tidal and wetland habitats
and associated vegetation.
b. Air Quality and Greenhouse Gas (AQ-9C) impacts. The loss of coastal wetland
and tidal ecosystems can result in decreased carbon sequestration due to
reduced vegetative growth and the release of potentially significant amounts of
carbon dioxide through mineralization of organic matter buried in saturated,
anaerobic sediment as it is dried out and exposed to oxygen. Coastal wetland
and tidal ecosystems play a significant role in regional and global carbon cycles
because they are an important sink for and can store large amounts of
atmospheric carbon in the form of vegetation and soil organic matter.

Final EIR
4-35
September 2015
F-7
Con't
F-8
F-9
F-9a
F-9b
Mr. Bob Holden

MRWPCA
-6-
June 5, 2015
c. Biological Resources Fisheries (BF-2 and BF-3) and Marine Biological

Resources (MR) impacts associated with interference with fish migration and
reduction in fish habitat or fish populations due to reduced flow and loss of
habitat or changes in brackish habitat due to insufficient freshwater flows and
mixing.
d. Biological Resources Terrestrial (BT-5, BT-6 and BT-7) impacts associated
with the loss of sensitive habitat and native wildlife nursery sites, the loss/taking
of special-status species, and the inhibited movement of native wildlife due to
changes in wetland and tidal habitat.
Analyses of cumulative flow diversion and watershed habitat response are needed to
more definitively evaluate potential impacts in downstream portions of the watershed.
These analyses will need to account for seasonal variations in diversion and instream
flows with respect to the most critical physical, chemical, and biological habitat and fish
and wildlife needs. This is particularly true during the dry season when natural flows are
the lowest and recycled water needs are the highest.
Although the project benefits outlined in section 2.1.2 of the DEIR are very significant,
the report relies heavily on them in support of the proposed project in the absence of
more robust analyses of potential watershed-scale cumulative impacts associated with
reduced flow due to the multiple proposed diversions. In particular, the potential benefits
of diverting low-quality or polluted water from the watershed appear to be more heavily
weighted in the DEIR, primarily via qualitative analyses and comparisons, than reduced
flow and associated habitat impacts. More robust analyses of potential cumulative
impacts may show that water quality improvements via the proposed diversions are less
meaningful in the greater context due to the loss or modification of critical habitat as a
result of reduced flows. Any projects in the watershed should achieve co-equal goals of
protecting or improving water quality and maintaining, if not increasing, natural flows
necessary to support viable freshwater, brackish tidal, and wetland habitats associated
with the Salinas River, Old Salinas River, Tembladero Slough, and Elkhorn Slough.
10. Its clear that the agencies involved have carefully studied the effects of the injection and
extraction of potable water and recycled water in the Seaside groundwater basin as part
of this project and as part of the ongoing aquifer storage and recovery project. Although
there are some uncertainties associated with the potential geochemical effects of
injecting highly treated and subsequently stabilized recycled water into the aquifer (short
circuiting, for example), the project proponents are well versed on these and other
related issues, have a good monitoring program in place, and will ultimately be injecting
better quality water overall into an existing trough in the basin. We expect that any
additional issues that come up can be dealt with via our permitting authority over the
project, including permits for the advanced treatment facility and ocean outfall.
Overall, we are supportive of the goals of this project, especially its ability to lessen the impacts
of CalAms proposed desalination project by decreasing the size of that facility. We look forward
to working with MRWPCA as this project advances.

Final EIR
4-36
September 2015
F-9c
F-9d
F-9e
F-9
Con't
F-9f
F-10
Mr. Bob Holden

MRWPCA
-7-
June 5, 2015
If you have any questions, please contact Jon Rokke of Water Board staff at (805) 549-3892 or
jon.rokke@waterboards.ca.gov.
Sincerely,
Digitally signed by Harvey C. Packard

Date: 2015.06.05 15:04:05 -07'00'
for Kenneth A. Harris Jr.
Executive Officer
cc:
Matthew Keeling, Water Board Staff

Kim Sanders, Water Board Staff
p:\wdr\wdr facilities\monterey co\monterey regional wpca pure water\ceqa\deir comments.docx

ECM# 805968

Final EIR
4-37
September 2015
LetterF: CentralCoastRegionalWaterQualityControlBoard
F-1
The Proposed Project would include new pump stations and wet wells at the proposed source
water diversion sites at the Reclamation Ditch at Davis Road, Tembladero Slough at the
Castroville Pump Station, Blanco Drain near the Salinas River, and potentially, at Lake El
Estero. These new facilities would divert source waters to the existing sewer systems when
capacity is available and if needed to meet project objectives. The Proposed Project would
include level sensors in the receiving manholes, enabling automatic shut off of diversion pumps
before any sanitary sewer system overflows (SSOs) occur or upon any overflow elsewhere
downstream in the system. When this shutoff occurs, water would remain in the relevant water
body (Reclamation Ditch, Tembladero Slough, Blanco Drain, and Lake El Estero); accordingly,
the new source waters would cease to contribute to sanitary sewer flows if an overflow occurs
in the system. The MRWPCA operations and maintenance staff would have responsibility for
maintenance and operation of all pump stations except Lake El Estero, which would be
operated by the City of Monterey.
The current and proposed responsibility for sanitary sewer system operations and maintenance
and overflows are described in the MRWPCAs Sewer System Management Plan (SSMP)
found at: http://mrwpca.org/ssmp/MRWPCA_Combined_SSMP_2013_Final.pdf and in the Draft
EIR, on pages 2-48, 2-53, 2-55, and 2-57 (under the subheadings Operations and
Maintenance). The SSMP is a summary of the policies, procedures, and activities that apply to
the planning, management, operation, and maintenance of the MRWPCA sanitary sewer
system. This SSMP is intended to meet the requirements of the State Water Resources Control
Board. The structure (section numbering and nomenclature) of the SSMP follows the General
Waste Discharge Requirements for Wastewater Collection Agencies, State Water Resources
Control Board Order Number 2006-0003 dated May 2, 2006. The SSMP provides information
on existing procedures to prevent and respond to SSOs. In addition, MRWPCA is in the
process of updating the 2013 Sewer System Management Plan including making changes to
better address interruptible sewer flows and the update is anticipated to be completed by the
end of 2015 or early 2016 (Garrett Haertel, MRWPCA, September 11, 2015).
F-2
Section 4.5.2.1, Biological Project Study Area, does not identify any jurisdictional agencies.
However, the text on page 4.5-4 of the Draft EIR (in Section 4.5.2.2) has been amended in
Chapter 5, Changes to the Draft EIR to include the RWQCB as an agency with jurisdiction over
wetlands. The EIR describes the jurisdiction of the Central Coast RWQCB over wetlands and
waters of the state under Section 401 of the Clean Water Act and the Porter-Cologne Water
Quality Control Act of 1969 in the following sections: Section 4.5.3.2, Regulatory Framework:
State (on pages 4.5-40 through 4.5-43 of the Draft EIR), and Section 4.11.3.1, Regulatory
Framework: Federal and State (on page 4.11-30 through 4.11-31 and 4.11-36 of the Draft EIR),
as amended in this Final EIR in Chapter 5, Changes to the Draft EIR.
F-3
The text in Table 4.5-5 and Section 4.11.3, Regulatory Framework, have been clarified to
reflect the regulatory authority of the RWQCB related to the Clean Water Act. Specifically, the
last full paragraph on page 4.11-30 of the Draft EIR has been amended in response to this
comment (see Chapter 5, Changes to the Draft EIR).
F-4
The construction impacts discussion in Section 4.5.4.3 (i.e., Impact BT-2: Construction Impacts
to Sensitive Habitats) on pages 4.5-87 through 4.5-94 of the Draft EIR have been amended in
accordance with this comment. See Chapter 5, Changes to the Draft EIR.
F-5
The proposed diversion structures for the Reclamation Ditch, Tembladero Slough, and Blanco
Drain would not change the cross-section of the channel. They consist of a screened channelbottom inlet to a pump station wet well located in the bank. The area around the inlet will be
hardscaped to prevent erosion and scour, as described and shown in Draft EIR Appendix P,

Final EIR
4-38
September 2015
(on page 21 and Appendix C of Appendix P) and Draft EIR Appendix Q-Revised (on page 16
and Appendix C of Appendix Q-Revised), as amended in this Final EIR. Proposed hardscaping
(grouted riprap) to protect diversion facilities and adjacent streambanks from erosion are
proposed to have similar roughness to existing conditions (weathered uniform channel), so that
there would not be a significant change in flow velocity near the proposed diversion facilities.
The Draft EIR described permanent diversion facilities consistent with the technical design in
Appendices P and Q-Revised on pages 2-51 through 2-52 of the Draft EIR in Chapter 2,
Project Description. The Draft EIR presents analyses of the impacts of the diversions on the
channel hydrology and erosion characteristic (i.e., fluvial geomorphology) on pages 4.11-64
through 4.11-75 (in particular, see the bottom of page 4.11-72 through the top of 4.11-74). This
section summarizes the conclusions from Appendix P of the Draft EIR (page 33), and identifies
a potential impact that may occur due to rapid water level fluctuations triggered by diversions at
the Reclamation Ditch diversion site. The presence of diversion structures and the operation of
diverting water at the Tembladero Slough Diversion site would not result in substantial erosion
or sedimentation because maximum diversions would rarely affect water levels due to the
pooling, backwater effect of the Potrero Tide Gates and wide channel in this reach of the water
body. The flow rate of water within the area of the Tembladero Slough diversion is very low
(relatively small diversions compared to total flows are proposed), and therefore, risks of
adverse fluvial geomorphological changes are considered less than significant. Mitigation
Measure HS-4 (Management of Surface Water Diversion Operations) on page 4.11-75 of the
Draft EIR would reduce the impact at the Reclamation Ditch Diversion site to less than
significant. The comment requests that if negative impacts on fluvial geomorphological
processes occur during operation, the structures and hardscapes shall be redesigned to
alleviate the negative impacts. Based on this comment, Mitigation Measure HS-4 on page 4.1175 of the Draft EIR has been modified as shown in Chapter 5, Changes to the Draft EIR.
In addition, the Draft EIR analyzes operational impacts of the surface water diversions on fish
and other aquatic habitat and wildlife in Section 4.4.4.4 (see pages 4.4-44 through 4.4-53) and
Section 4.5.4.4 (pages 4.5-96 through 4.5-106), respectively, as modified in this Final EIR (see
Chapter 5, Changes to the Draft EIR).
F-6a
In response to this comment, page 4.5-92 of the Draft EIR has been amended to include the
requirement for Mitigation Measure BT-1a to be implemented to reduce Impact BT-2 to a lessthan-significant level (see Chapter 5, Changes to the Draft EIR). In addition, Mitigation
Measures BT-1a on pages 4.5-75 and 4.5-76 of the Draft EIR has been amended as shown on
Chapter 5, Changes to the Draft EIR.
F-6b
Mitigation Measure BT-2a on page 4.5-92 of the Draft EIR has been modified as shown in
Chapter 5, Changes to the Draft EIR in response to this comment and Comment F-6c.
F-6c
The intention of the preservation requirement within Mitigation Measure BT-2a, above, is to
minimize the construction footprint and prevent impacts to nearby, off-site habitat. As shown
above, in response to comment F-6b, the language of Mitigation Measures BT-2a on page 4.592 of the Draft EIR has been clarified to describe the intention of the preservation requirement.
See Chapter 5, Changes to the Draft EIR.
F-7
The discussion on page 4.11-62 of the Draft EIR has been modified to describe the RWQCBs
jurisdiction over waters of the state as provided and the potential for the RWQCB to issue
waste discharge requirements (a permit) for impacts to waters of the state. See Chapter 5,
Changes to the Draft EIR.
F-8
The Draft EIR analyzes potential direct and indirect environmental impacts of diversion and use
of water. Specifically, the items listed in the comment are addressed as follows in this EIR:

Final EIR
4-39
September 2015
Availability of unappropriated water: The State Water Resources Control Board

determines the availability of unappropriated surface flow. Therefore, water rights
applications 32263A, 32263B. 32263C for permits to divert source waters to the
Proposed Project have been submitted to the SWRCB. The detailed technical analyses
of water availability (i.e., estimated yield) is provided in the following locations in the
Draft EIR (as modified in this Final EIR) in Appendices B-Revised, F-Revised, G, ORevised, P, and Q-Revised.2 For a summary of the analyses, see Draft EIR, Chapter 2,
Project Description on pages 2-23 through 2-26 (existing data related to flow quantities
in each proposed source water), and 2-42 through 2-57 (estimated yields and
methods/timing of diversion of each source water, which are inter-related) as amended
in this EIR (see Chapter 5, Changes to the Draft EIR).
Impact of the diversion of water to instream resources including development of

mitigation measures that may include fish screens and bypass flows, including the
following specific issues as requested in the comment:
o
Development of mitigation measures for fisheries: The Draft EIR includes an analysis
and mitigation measures for impacts to fisheries, including the requirements for fish
screens and bypass flows, in sections 4.4.4.2 through 4.4.4.4 of the Draft EIR, as
modified in this Final EIR (see pages 4.4-38 through 4.4-51 of the Draft EIR). The
final facility design and flows will incorporate passage acceptable to NMFS (see last
paragraph on page 4.4-50 of the Draft EIR) and Master Response #5: Fisheries
Impact Analyses. The Project will require federal actions that are subject to
consultation under the Endangered Species Act and the MRWPCA proposes to
begin working with NMFS as early as necessary to avoid impacts to listed species
and their designated critical habitat. See also Master Response #5: Fisheries Impact
Impacts of reducing the discharge of treated wastewater to the Salinas River: The
Draft EIR contains detailed hydrogeologic, hydrology, and water quality analyses of
loss of percolated wastewater to the Salinas River in Appendices N and O-Revised.
These technical analyses are summarized in the Draft EIR on pages 4.10-57 through
4.10-64 (effects on groundwater systems in the Salinas Valley), 4.11-64 through
4.11-75 (surface water quality and related hydrologic impacts). In addition, Appendix
F-Revised provides detailed analyses of the impacts of the diversion on fisheries
resources in the Salinas River, which is summarized in the Draft EIR on pages 4.438 through 4.4-53 (fisheries). Based on the above information and detailed species
and habitat surveys of the affected reaches of water bodies downstream in
Appendices H and I, pages 4.5-60, 4.5-97 through 4.5-105 of the Draft EIR provide
an analysis of the reduction in discharge to the Salinas River on other aquatic
species and habitat (including all the proposed flow reductions combined). The
analysis of flow reduction in the Salinas River used conservative assumptions to
determine the impacts of loss of percolated agricultural wash water to the river.
Specifically, the Draft EIR analyses of effects on the beneficial uses in the Salinas
River and Old Salinas River channel assume year-round loss of percolation from the
Salinas Treatment Facility ponds, when the Proposed Project would continue to use
the ponds for storage and percolation in the winter months and divert the water to
the Regional Treatment Plant only in the summer. Operational impacts to hydrologic
function, and biological species and habitat in the Salinas River were determined to
be less than significant as described in the Draft EIR. See also response to comment
Changes to the Appendices indicated with Revised have been amended or replaced in this Final EIR as shown in

Final EIR
4-40
September 2015
G-2, G-3 and Master Response #4: Reduction in Surface Water Flows in Chapter 3,
Master Responses to Comments. It is noted that the State Water Resources
Control Board has jurisdiction over changes to points of discharge for wastewater. A
wastewater change petition is being prepared for submittal to them.
o
F-9
Reduction in flows to the coastal sloughs in the area (e.g., Elkhorn Slough (a
National Estuarine Reserve), and Moro Cojo Slough. See the response to comment
G-2, G-3 and Master Response #4: Reduction in Surface Water Flows in Chapter 3,
Master Responses to Comments. The Proposed Project impacts, including the
combined impacts of all proposed surface water, urban runoff, and wastewater
diversions, would not have a significant adverse impact on brackish tidal and wetland
habitat the downstream portions of the watershed including Old Salinas River
channel, Tembladero Slough, Elkhorn Slough, and Moro Cojo Slough during project
operations as documented on pages 4.5-97 through 4.5-105 of the Draft EIR. The
final facility design and flows will incorporate passage acceptable to NMFS (see last
paragraph on page 4.4-50 of the Draft EIR) and Master Response #5: Fisheries
The RWQCB notes that the Draft EIR relies on technical reports and analyses evaluating the
potential environment effects of the various proposed surface water diversions due to reduced
flows in portions of the watershed. The Draft EIR and appendices include analyses of the
potential downstream effects for the combined diversions at the Reclamation Ditch, Tembladero
Slough, Blanco Drain, Salinas stormwater, and the Salinas Industrial Wastewater Treatment
Facility (Salinas Treatment Facility). As recognized by the comment, the technical analysis
addresses the combined potential effects of the Salinas Treatment Facility, City of Salinas
(southwest portion) stormwater runoff, and Blanco Drain diversions on the Salinas River at a
point just downstream of the Salinas River Diversion Facility rubber dam, as well as water
supply yield studies and impact analyses for the Reclamation Ditch, Tembladero Slough, and
Blanco Drain diversions, and an urban runoff capture/yield study for the Lake El Estero
diversion.
The RWQCB states that the Draft EIR does not appear to include an analysis of the cumulative
effects of all Proposed Project diversions on downstream portions of the Salinas River,
particularly the Old Salinas River, Tembladero Slough and the Elkhorn Slough. See individual
responses below (F-9a through F-9e) addressing this comment by topical area. The Draft EIR
analyzes the combined impacts of all proposed surface water, urban runoff, and wastewater
diversions, and concludes that the Proposed Project would not have a significant adverse
operational impact on brackish tidal and wetland habitat in the downstream portions of the
watershed including Old Salinas River channel, Tembladero Slough, Moss Landing Harbor, and
the Elkhorn Slough. See Draft EIR pages 4.5-97 through 4.5-105 as amended in this Final EIR
in Chapter 5, Changes to the Draft EIR and Master Response #4: Reduction of Surface Water
Flow in Chapter 3, Master Responses to Comments that provides clarification about the
assumptions and rationale for the hydrology and biological resources analysis in the Draft EIR
to address this comment.
F-9a
The combined diversions from all Proposed Project components would have a less-thansignificant impact on the brackish tidal and wetland habitats and associated vegetation as
discussed in response to comment F-8, F-9, G-2, and G-3, and Master Response #4:
Reduction in Surface Water Flows in Chapter 3, Master Responses to Comments.
Accordingly, the Proposed Project would not result in a significant impact on these habitats
downstream of the Proposed Project diversion facilities and thus would not result in a
significant aesthetic or visual impact.
F-9b
As described in the Drat EIR ages 4.5-97 through 4.5-105 and in Master Response #4:
Reduction in Surface Water Flows in Chapter 3, Master Responses to Comments, the

Final EIR
4-41
September 2015
combined diversions from all Proposed Project components would have a less-than-significant
impact on coastal wetland and tidal ecosystems and thus no measurable or detectable change
to air quality or climate change related to loss of coastal wetland and tidal ecosystem carbon
cycle influences. See also responses to comments F-8, F-9 and F-9a, G-2 through G-13, and
Appendix AA.
F-9c
The Draft EIR addresses potential short- and long-term effects of decreased surface water
flows and shallow groundwater recharge in the coastal portions of the watershed in the
following sections (as amended in this Final EIR):
Biological Resources: Fisheries (see Section 4.4),
Biological Resources: Terrestrial (see Section 4.5),
Hydrology/Water Quality: Groundwater (see Section 4.10), and
Hydrology/Water Quality: Surface Water (see Section 4.11)
These sections account for seasonal variations in diversions from all source waters and
instream flows for biological habitat and fish and wildlife needs based upon accepted fish
passage requirements as clarified in Master Response #4: Reduction of Surface Water Flows
and Master Response #5: Fisheries Impact Analyses in Chapter 3, Master Responses to
Comments. The Draft EIR addresses the potentially significant impacts to habitat based upon
variable flow criteria and combined project diversions and proposes mitigation measures to
reduce potential impacts including direct and indirect and impacts to fisheries/aquatic
resources. As discussed in the Draft EIR (Impact BF-2), the Proposed Project would result in a
minor reduction to flows in the Salinas River. This reduction would not reduce fish habitat, and
changes to steelhead migration flows would result in less-than-significant impacts on fisheries
in the Salinas River. See also changes to Section 4.4 in Chapter 5, Changes to the Draft EIR
that provides additional and amended mitigation measures for fisheries in response to
comments.
F-9d
The Draft EIR found that Proposed Project construction impacts to special-status species and
habitat, and construction impacts to riparian, federally protected wetlands as defined by Section
404 of the Clean Water Act, or other sensitive natural community would be less-than-significant
with mitigation. See the responses to comments F-8, F-9, F-9c, G-2, G-3, and Master
Response #4: Reduction in Surface Water Flows in Chapter 3, Master Responses to
Comments. In the response to comments and additional technical analyses contained herein,
this Final EIR supports and clarifies the findings in the Draft EIR that the proposed source water
diversions would not result in a measurable / detectable change in the features downstream of
the points of diversion that are important to the health and viability of biological resources and
ecosystem services (flows, quality/salinity, water levels, surface/groundwater interaction).
F-9e
See the responses to comments F-8, F-9, F-9a through F-9d, G-2, G-3, and Master Response
#4: Reduction in Surface Water Flows in Chapter 3, Master Responses to Comments.
F-9f
See the responses to comments F-8, F-9, F-9a through F-9d G-2, G-3, and Master Response
#4: Reduction in Surface Water Flows in Chapter 3, Master Responses to Comments.
F-10
The RWQCBs permitting jurisdiction is acknowledged. The comment is supportive of the

analysis of groundwater impacts on the Seaside Groundwater Basin; no further response is
necessary. The final paragraphs state an opinion of the Proposed Project and these statements
are referred to decision makers for their consideration.

Final EIR
4-42
September 2015
EDMUND G. BROWN JR.. Governor~

-
CHARLTON H. BONHAM, Director
1
State of California- Natural Resources Agency
DEPARTMENT OF FISH AND WILDLIFE
I Letter G I
Central Region
1234 East Shaw Avenue
Fresno, California 93710
(559) 243-4005
www.wildlife.ca.gov
, -
June 5, 2015

Attention: Bob Holden, Principal Engineer
E-mail: gwr@mrwpca.com
Subject: Draft Environmental Impact Report, SCH# 2013051094
Pure Water Monterey Groundwater Replenishment Project
Dear Mr. Holden:
The California Department of Fish and Wildlife (Department) has reviewed the Draft
Environmental Impact Report (DEIR) for the Pure Water Monterey Groundwater
Replenishment Project (Project).
According to the DEIR, the Project would divert new source waters to the Monterey
Regional Water Pollution Control Agency (MRWPCA) Regional Treatment Plant for two
purposes: 1) to create purified recycled water for recharge of the Seaside Groundwater
Basin to replace 3,500 acre-feet per year of California American Water Company's
(CaiAm) current water supplies, enabling CaiAm to reduce its diversions from the
Carmel River by the same amount, and 2) to provide additional recycled water to
growers within the existing Castroville Seawater Intrusion Project service area for crop
irrigation. Water sources proposed to be recycled, treated and reused by the GWR
Project include municipal wastewater, City of Salinas industrial wastewater, City of
Salinas and City of Monterey urban storrnwater runoff, and surface water diversions
from El Estero Lake, Blanco Drain, Reclamation Ditch and Tembladero Slough. Purified
water from a new Advanced Water Treatment Facility at the Regional Treatment Plant
would be conveyed through a new Product Water Conveyance pipeline and booster
pump station to new Injection Well Facilities in the City of Seaside for recharge to the
Seaside Basin. CaiAm would extract water from its existing wells, and would deliver the
water to its customers via two new pipelines and its existing distribution
system. Recycled water produced for crop irrigation would be distributed through the
existing Castroville Seawater Intrusion Project system. The Project is being proposed by
the MRWPCA in partnership with the Monterey Peninsula Water Management District
(MPWMD).
The Project would be located within northern Monterey County and would include new
facilities located within unincorporated areas of the Salinas Valley and within the cities
Conserving Ca(ijomia.'s WiUCife Since 1870

Final EIR
4-43
September 2015
G-1
Bob Holden
June 5, 2015
Page 2
of Salinas, Marina, Seaside, Monterey, and Pacific Grove, and within former Fort Ord
areas in Seaside and Marina.
G-1
Con't
The following provides the Department's comments and recommendations

regarding the Draft EIS/61R.
Elkhorn Slough:
The Lower Salinasffembladero Slough is an important freshwater and sediment source
for the Elkhorn Slough estuary. Estuaries by definition are a mixture of freshwater and
marine habitats, and one of the last remaining sources of freshwater for Elkhorn Slough
is the Old Salinas River channel, which conveys both Salinas River and Tembladero
Slough flows. Freshwater pulses have been documented as originating in the Old
Salinas River channel and moving far up into Elkhorn Slough with incoming tides.
Further loss of freshwater inputs into Elkhorn Slough is a significant adverse impact as it
would likely lead to additional loss of fresh/brackish water habitats and negatively
impact the biological resources dependent upon these habitats.
The DEIR Is Incomplete In that it did not analyze direct, indirect, and cumulative Impacts
to the Lower Salinas River and Elkhorn Slough estuary resulting from proposed surface
water diversions from the Salinas River, Tembladero Slough, Blanco Drain, and
Reclamation Ditch (whic~ is historically the lower portion ofGabilan Creek and tributary
to Tembladero Slough thence Lower or Old Salinas River). Due to this omission It Is
unlikely that the true geographic extent of direct and cumulative impact analysis has
been determined for the DEIR.
G-2
G-3
The omission of analysis of impacts to Elkhorn Slough does not serve the full public
disclosure intent'of the California Environmental Quality Act (CEQA). CEQA Guidelines
Section 15088.5 (a) states that significant new information requiring recirculation of an
Environmental Impact Report (EIR) includes:
(1)
A new significant environmental impact would result from the project or from a
new mitigation measure proposed to be implemented.
(2)
A substantial Increase In the severity of an environmental impact would result

unless mitigation measures are adopted that reduce the impact to a level of
insignificance.
(3)
A feasible project alternative or mitigation measure considerably different from

others analyzed would clearly lessen the significant environmental impacts of
the project, but the project's proponents decline to adopt it.
(4)
The draft EIR was so fundamentally and basically inadequate and

conclusionary in nature that meaningful review and comment were precluded.

Final EIR
4-44
September 2015
G-4
Bob Holden
June 5, 2015
Page 3
Based on the omission of any discussion or analysis of impacts to Elkhorn Slough in the
DEIR, the Department believes that all four of the above mentioned criteria that
necessitate recirculation of an EIR have been met.
The Department recommends recirculating the DEIR with a thorough analysis of
impacts to the Elkhorn Slough estuary. The DEIR should address the following
information:
G-4
Con't
G-5
The percentage of Elkhorn Slough's freshwater inputs, in a variety of climate and

irrigation scenarios, that will be removed by the range of alternatives considered
in the proposed project.
How the proposed removal of freshwater from Tembladero Slough and the
Salinas River will affect the biota and ecosystem services of Elkhorn Slough.
How the proposed Project will guarantee continued adequate provision of

freshwater to maintain the historical baseline extent of estuarine habitats in
Elkhorn Slough.
The specific analyses, including what flow data, used to determine effects of the
proposed Project on the biota and ecosystem services of Elkhorn Slough.
Project-related impacts to foraging and refugia habitat of young out-migrating

steel head.
G-9
Minimum flow requirements in Old Salinas River, Reclamation Ditch, Tembladero

Slough, and Blanco Drain that are necessary to avoid or minimize impacts to the
Elkhorn Slough estuary.
G-10
What information will be submitted to the State Water Resources Control Board
(SWRCB) pursuant to Water Code Section 1260 0), to address potential effects
on fish and wildlife in the Old Salinas River, Reclamation Ditch, Tembladero
Slough, Blanco Drain and the Elkhorn Slough estuary.
How information on minimum flow requirements in the above mentioned water

bodies is addressed in any Water Rights application submitted to the State Water
Quality Control Board.
Water from the Lower Salinas/Tembladero Slough is highly polluted and the dominant
source of nitrate loading to Elkhorn Slough, with the Tembladero Slough accounting for
two orders of m<Jgnitude more nitrate than the Old Salinas River channel. This proposal

Final EIR
4-45
September 2015
G-6
G-7
G-8
G-11
G-12
G-13
Bob Holden
June 5, 2015
Page4
proposes to reduce nitrate load to Elkhorn Slough by reducing flow of Tembladero

Slough. Reduction of fresh water flow to an estuary negatively Impacts brackish water
habitats and the species that exist there. The DEIR should provide an analysis of the
impacts of reduced flow to Elkhorn Slough.
Lake El Estero: The DEIR states that the diversion and use of surface water from
Tembladero Slough, Reclamation Ditch, and Blanco Drain will require an appropriative
water right permit pursuant to Water Code Section 1200 et seq. Lake El Estero is a
historic water body that collects surface water from tributaries and a portion of the City
of Monterey's stormwater collection system. The DEIR should be changed to reflect
that the proposed diversion and use of up to 87 .acre-feet per year (afy) of water from
Lake El Estero will require an appropriative right from the State Water Resources
Control Board (SWRCB).
Tricolored Blackbi rd: According to the DEIR, tricolored blackbirds (Agelaius tricolor)
have been documented to occur immediately adjacent to the Project Study Area along
the Product Water Conveyance: Coastal alignment option. Suitable habitat is also
present at the Salinas Treatment Facility site, Blanco Drain Diversion site, Lake El
Estero, and the three Affected Reaches. Page 4.5-25 of the DEIR states that the
tricolored blackbird is a California Department of Fish and Wildlife species of special
concern. The tricolored blackbird was listed by the Fish and Game Commission as
State endangered on an emergency basis and the DEIR should be updated to reflect
the correct listing status.
G-13
Con't
G-14
G-15
Department Jurisdiction
Trustee Agency Authori ty: The Department is a Trustee Agency with responsibility
under CEQA for commenting on projects that could impact plant and wildlife resources.
Pursuant to Fish and Game Code Section 1802, the Department has jurisdiction over
the conservation, protection, and management of fish, wild life, native plants, and the
habitat.necessary for biologically sustainable populations of those species. As a
Trustee Agency for fish and wildlife resources, the Department is responsible for
providing, as available, biological expertise to review and comment upon environmental
documents and impacts arising from project activities, as those terms are used under
CEQA (Division 13 (commencing with Section 21000) of the Public Resources Code}.
Responsible Agency Authority: The Department also has regulatory authority over
projects that could result in the "take" of any species listed by the State as threatened or
endangered, pursuant to Fish and Game Code Section 2081. If the Project could result
in the take" of any species listed as threatened or endangered under the California
Endangered Species Act (CESA), the Department may need to issue an Incidental Take
Permit for the Project. CEQA requires a Mandatory Finding of Significance if a project
is likely to substantially impact threatened or endangered species (Sections 21001{c},

Final EIR
4-46
September 2015
G-16
G-17
Bob Holden
June 5, 2015
Page 5
21083, Guidelines Sections 15380, 15064, 15065). Impacts must be avoided or

mitigated to less than significant levels unless the CEQA Lead Agency makes and
supports Statement of Overriding Consideration (SOC). The CEQA Lead Agency's
SOC does not eliminate the Project proponent's obligation to comply with Fish and
Game Code Section 2080.
Lake and Streambed Alteration Agreement: The Department has regulatory

authority over activities occurring in streams and/or lakes along with riparian habitat
associated with and supported by watercourses, that could adversely affect any fish or
wildlife resource, pursuant to Fish and Game Code sections 1600 et seq. If a Project
could substantially divert or obstruct the natural flow of any river, stream or lake;
substantially change or use any material from the bed, channel, or bank of, any river,
stream, or lake; or deposit or dispose of debris, waste, sediment, or other material
containing crumbled, flaked, or ground pavement where it may pass Into any river,
stream, or lake, notification of Lake or Streambed Alteration to the Department is
required.
G-17
Con't
G-18
Acquisition of a Lake and Streambed Alteration Agreement (LSAA) for this Project is
required for surface water diversion and rediversion, in addition to stream crossings and
other jurisdictional features. For projects of this nature, consultation with the
Department is recommended well in advance of Project implementation. A substantial
diversion of water from a jurisdictional feature is subject to Fish and Game Code (Code)
sections 1600 et seq., and failure to notify is a violation of the Code. It is important to
note that the Department is required to comply with CEQA in the issuance or extension
of an LSAA. For this particular Project, the Department would be acting as a
Responsible Agency and would need to rely upon the CEQA document prepared for the
Project. If the CEQA document prepared by the Lead Agency (MRWPCA) is insufficient
for the Department to make its own Findings or Notice of Determination, the Department
might need to assume the role of Lead Agency and prepare a subsequent CEQA
document. The LSAA process is administered through the Central Region Office in
Fresno and can be initiated by contacting the Lake and Streambed Alteration Program
at (559) 243-4593.
Water Rights
The diversion and use of surface water from Tembladero Slough, Reclamation Ditch,
Blanco Drain, and El Estero Lake will require an appropriative water right permit from
the SWRCB pursuant to Water Code Section 1200 et seq.
As proposed In the DEIR, the Project may redirect an estimated 3, 733 afy of treated
wastewater to the municipal wastewater collection system, thus reducing flow into the
Salinas River by up to 2,170 afy. Changing the place of use and purpose of use for

Final EIR
4-47
September 2015
G-19
Bob Holden
June 5, 2015
Page 6
treated wastewater will require approval of the SWRCB under a waste water change
petition pursuant to Water Code Section J21 1.
The Department, as Trustee Agency, is consulted by .t he SWRCB during the water
rights permit application and change petition process to provide terms and conditions
designed to protect fish and wildlife prior to appropriation of the States water resources.
Certain fish and wildlife are reliant upon aquatic ecosystems, which in tum are reliant
upon adequate flows of water. The Department therefore has a material interest in
assuring that adequate water flows within streams for the protection, maintenance and
proper stewardship of those resources. The Department provides, as available,
biological expertise to review and comment on environmental documents and impacts
arising from project activities.
If you have any questions regarding these comments, please contact
Annette Tenneboe, Senior Environmental Scientist (Specialist), at (559) 243-4014,
extension 231; annette.tenneboe@wildlife.ca.gov, or by writing to the California
Department of Fish and Wild life at 1234 East Shaw Avenue, Fresno, California 93710.
erald Hatler
Acting Regiona
ec:
anager
See Page Seven

Final EIR
4-48
September 2015
G-19
Con't
G-20
Bob Holden
June 5, 2015
Page 7
ec:
Office of Planning and Research

State Clearinghouse
Paul Forsberg
James Rosauer
Terry Palmisano
Julie Vance
Dave Feliz
Andy Gordus
Annette Tenneboe
Eric Wilkins
California Department of Fish and Wildlife
Justine Herrig, Environmental Scientist (justine.herriq@waterboards.ca.gov)
State Water Resources Control Board, Division of Water Rights
Lisa McCann (lisa.mccann@waterboards.ca.gov)
Harvey Packard (harvey.packard@waterboards.ca.gov)
Steve Saiz (steve.saiz@waterboards.ca.qov}
Central Coast Regional Water Quality Control Board

David Chardavoyne, General Manager (chardavoynede@co.monterey.ca.us)
Brent Buche, Deputy General Manager (bucheb@co.monterey.ca.us)
Rob Johnson, Deputy General Manager (iohnsonr@co.monterey.ca.us)
Wini Chambliss, Clerk to the Board (chamblissws@co.monterey.ca.us)
David Stoldt, General Manager (dstoldt@mpwmd.net)
Stephanie Locke, Water Demand Manager (s.locke@mpwmd.net).

Final EIR
4-49
September 2015
LetterG: CaliforniaDepartmentofFishandWildlife
G-1
The California Department of Fish and Wildlife (CDFW) accurately summarizes the project
features; no response is necessary.
G-2
The Elkhorn Slough is considered an estuary. Freshwater inflows typically enter estuaries from
the top of the basin and move through the system toward the ocean, creating and maintaining a
brackish environment with salinities lower than that of seawater (which has salinity of about 34
ppt). Direct tributaries to Elkhorn Slough include Carneros Creek (located at the
northeasternmost portion of the Elkhorn Slough) and several unnamed smaller streams, all of
which are seasonal. As explained below, due to the system geometry, Elkhorn Slough also
receives some freshwater from the Moss Landing Harbor (that receives flows from the Moro
Cojo Slough and the Old Salinas River Channel) on rising tides. As opposed to most estuaries,
freshwater mixed with seawater in the harbor is pushed up into Elkhorn Slough. Figure 4.53new provided at the end of Chapter 5, Changes to the Draft EIR shows the key surface
water features discussed in this response.
The Proposed Project would divert flows from the Reclamation Ditch/Tembladero Slough
system and reduce inflows to the Salinas River. The Tembladero Slough and, at times, Salinas
River flows into the Old Salinas River channel, which also receives inflows as surface and
agricultural land tile drainage water from surrounding agricultural lands. The Old Salinas River
connects to the Moss Landing Harbor through a tide gate (called the Potrero Road Tide Gate),
which limits the upstream transportation of seawater on rising tides. Similarly, Moro Cojo
Slough connects to Moss Landing Harbor through a separate tide gate. On falling tides, water
from the Old Salinas River and from Moro Cojo Slough moves through their respective tide
gates and into the Moss Landing Harbor and then into the Monterey Bay. The Elkhorn Slough
connects to the Moss Landing Harbor at the harbor inlet channel, and drains into the Monterey
Bay on falling tides (see Figure 4.5-3new). On rising tides, the blended water in the harbor
mouth (flows from the Old Salinas River, Moro Cojo Slough and Elkhorn Slough) is carried back
into Moss Landing Harbor and Elkhorn Slough.
The Proposed Project would typically divert flows during the months of April through
September, with peak flow diversions occurring during the months of July through September.
The average salinity of the Elkhorn Slough near its confluence with the Moss Landing Harbor
(as measured at the LOBO sampling site, L01, mile east of the Highway 1 bridge) in the dry
summer months equals the salinity of the Monterey Bay (between 33 and 35 ppt). At site L01,
dry season salinities (July through September) are shown in Figure 4-A, Elkhorn Slough
Salinity Measurements at LOBO Sampling Sites, below.

Final EIR
4-50
September 2015
Figure4A.ElkhornSloughSalinityMeasurementsatLOBOSamplingSiteL01(JulySeptember2014)(Source:
MBARI,2015at:http://www.mbari.org/lobo/loboviz.htm)
Freshwater inflows from the Old Salinas River account for less than one percent of the total
flow exchanged in Elkhorn Slough during a tidal cycle (see Appendix AA) and do not affect the
water levels or temperature in the slough due to the overwhelming influence of the ocean tides.
As documented in Appendix AA, the maximum possible effect of diverting a portion of these
freshwater flows would be a less than 1% salinity increase (i.e., the difference in salinity at the
confluence of the slough with the harbor would be approximately 0.40 ppt or 400 mg/L
according to Appendix AA). This change in salinity is much lower than the typical range of
salinities in the ocean environment and greater changes in salinities are seen in the Elkhorn
Slough on a daily basis during the summer months as shown in Figure 4-A, above. In
comparison, typical storm events (which occur ten or more times in most years) drop the
salinities in Elkhorn Slough at the L01 sampling site down to lows on the order of 8,000 to
9,000 mg/L, a reduction of 75% in salinity. These storm events are a far more important
contributor to salinity variation in the Slough than the agricultural tile drainage and crop land
surface runoff that the Proposed Project would divert. Given the existing conditions of salinity
and freshwater contributions to the slough, the ecosystems, plants, and animals in the Elkhorn
Slough would not be impacted by the Proposed Project diversions.
During the wet winter season, extended higher flows in the Reclamation Ditch/Tembladero
Slough can occasionally push through a rising tide and continue to contribute freshwater to
Moss Landing Harbor and indirectly to Elkhorn Slough. During these wet periods, Carneros
Creek and the other direct tributaries to Elkhorn Slough would also be contributing flows. The
Proposed Project would not typically be diverting substantial quantities of surface water from
October through March, so these seasonal inflows would not be interrupted. During dry-season
rain events, flows in the Reclamation Ditch rise and fall quickly due to the rapid response of
urban drainage area. These storm peaks exceed the proposed diversion rates by several
orders of magnitude, so these storm pulses of freshwater would be reduced by Proposed
Project diversions by only a small amount, if at all.
The proposed dry-season diversions do not have the potential to substantially change the water
levels nor salinity of Elkhorn Slough (even with a reduction of freshwater input) as discussed in
this response. Evaluation of the potential direct and indirect hydrology and water quality
impacts to the Elkhorn Slough is included in the Draft EIR in section 4.11 which is clarified in
Master Response #4: Reduction in Surface Water Flows in Chapter 3, Master Responses to
Comments. Based on these analyses, the Project Study area for the fisheries and terrestrial
biological resources analyses is considered to be appropriate. See also response to comment

Final EIR
4-51
September 2015
G-3, below, and Master Response #5: Fisheries Impact Analyses in Chapter 3, Master
Chapter 3, Master Responses to Comments, and the Schaaf & Wheeler technical memo in
Appendix AA of this Final EIR provide detailed water flow and quality analysis.
G-3
CDFW states that the Draft EIR is inadequate in that it did not analyze direct, indirect, and
cumulative impacts to the Lower Salinas River and Elkhorn Slough estuary resulting from
proposed surface water diversions from the Salinas River, Tembladero Slough, Blanco Drain,
and Reclamation Ditch.
Master Response #6: Nutrients in Recycled Water and Ocean Outfall Discharges in Chapter 3,
Master Responses to Comments, notes numerous comments on the Draft EIR that echo the
Draft EIRs conclusions regarding the Proposed Projects water quality benefits, including
comments from National Oceanic and Atmospheric Administration, National Marine Fisheries
Service (NMFS), CDFW, the City of Salinas, and Surfrider.
To put project impacts in perspective, overall past activity of Moss Landing Harbor dredging,
tide gates, development and farming of land in the Elkhorn Slough watershed are the major
contributors to impacts to environment as documented in the watershed assessments and
studies by various academic and institutional organizations, including MBARI and CCOWS
(Casagrande and Watson, 2006; Nicol et al., 2010; Inman et al. 2014). As a result of the
previous modifications, dry-weather flows in and out of the Elkhorn Slough are dominated by
ocean
tides
entering
and
leaving
via
the
harbor
mouth.
See
http://oceanservice.noaa.gov/education/kits/estuaries/media/supp_estuar01a_tide.html for a
photo documentation of the effects of tidal flows in the Elkhorn Slough. The Elkhorn Slough
Tidal Wetland Project Team stated the following in their 2007 Elkhorn Slough Tidal Wetland
Strategic Plan:
Over the past 150 years, human actions have altered the tidal, freshwater, and sediment
processes that are essential to support and sustain Elkhorn Sloughs estuarine habitats.
Approximately 50 percent, or 1000 acres, of the tidal marsh in Elkhorn Slough has been lost
since 1870 due to human activities. Major physical modifications to the estuary have caused
and are currently causing high rates of habitat loss and degradation in Elkhorn Slough. Human
impacts have resulted in ongoing marsh loss and estuarine habitat erosion, degraded water
quality conditions, increased levels of pollution, eutrophication, and increased numbers of
invasive species. Almost 73,250 cubic yards of sediment are exported each year from Elkhorn
Slough into Monterey Bay from habitat erosion. Bank erosion rates along the main channel of
Elkhorn Slough range from 1 to 2 feet per year. These rapid changes not only affect the
estuarys animals and plants, but also impact neighboring private lands, public access sites,
and railroad and road infrastructure. (Elkhorn Slough Tidal Wetland Project Team, 2007)
In addition, the Draft EIR (pages 4.5-106 through 4.5-108) assesses cumulative impacts on
terrestrial biological resources, including wetlands and riparian habitats. The Draft EIR found
that the Proposed Project would not considerably contribute to significant cumulative impacts to
terrestrial biological resources, and would result in less than significant cumulative impacts.
Information provided in Master Response #4, responses to comments F-8, F-9, F-9a-f, G-2,
above, and in this response provide additional evidence to support and clarify the cumulative
impact conclusion that the Proposed Project would not have a considerable contribution to any
cumulative impacts on the biological resources and ecosystems of the lower Salinas Valley
watersheds. The Proposed Project would not have a considerable contribution to any
cumulative impacts on the biological resources and ecosystems of the lower Salinas Valley
watersheds, including the Elkhorn Slough. In addition to information provided in this response,
this conclusion is also supported by information in the responses to comments F-8, F-9, G-2,

Final EIR
4-52
September 2015
and Master Response #4: Reduction in Surface Water Flows. Together with the analysis in the
Draft EIR, this evidence shows the lack of changes to hydrology and water quality in the
Elkhorn Slough and thus the lack of adverse hydrology/water quality and biological
resources/ecosystem services impacts to the Elkhorn Slough due to the Proposed Project.
Additional information is included in Master Response #1: Adequacy of the Draft EIR, and
Master Response #5: Fisheries Impact Analyses in Chapter 3, Master Responses to
Comments and in Appendix AA.
Draft EIR Proposed Project Study Areas for Relevant Topics (Hydrology/Water Quality,
Biological Resources: Fisheries, and Biological Resources: Terrestrial)
The Draft EIR addresses hydrology and water quality of surface water, fisheries, and terrestrial
habitat and species in three sections (4.11, 4.4, and 4.5). This section of the response presents
the study area considered for each relevant topical section relevant to this comment.
Hydrology and Water Quality of Surface Waters. Section 4.11 addresses water bodies within
the Tembladero Slough and Old Salinas River Channel including through and to the tide gates
at Potrero Road and downstream areas. Under Section 4.11.2, the Environmental Setting of the
Hydrology and Water Quality: Surface Water section addresses the following study area: This
section addresses natural drainages and water bodes (rivers and sloughs) and man-made
drainages (agricultural ditches drainages and urban stormwater systems). The geographic area
for these water systems, and thus the project area of impact for this topic is northern Monterey
County, including the watersheds of the Salinas River (and the inter-related watershed of the
Gabilan Creek/Reclamation Ditch system that includes the watersheds that feed the
Tembladero Slough and Blanco Drain), and smaller more urban watersheds in the Monterey
Peninsula area. The section details all of the study area for the analysis of impacts to surface
water hydrology and water quality and includes among other areas, the Old Salinas River
Channel between the Old Salinas River Channel gated outlet and the Potrero Tide Gate near
Moss Landing Harbor and the Moss Landing Harbor and Elkhorn Slough. Because some
change in water flow would occur to the Moss Landing Harbor and Elkhorn Slough (albeit less
than significant, as documented in the Draft EIR Section 4.11.4.4), these water bodies were
included in the study area for the analysis of Hydrology and Water Quality of Surface Waters.
Biological Resources: Fisheries. In Section 4.4 (Biological Resources: Fisheries), the study
area was defined as the immediate vicinity of each diversion site and upstream and
downstream areas that could be influenced by diversion actions associated with the Proposed
Project. The potentially affected water bodies included the Salinas River and the Salinas River
Lagoon. Fish habitat areas upstream of the immediate project vicinity that could be influenced
by Proposed Project diversion actions are the Arroyo Seco, San Antonio, and Nacimiento
Rivers. In addition, this section considers the Reclamation Ditch Diversion, which connects to
Tembladero Slough and ultimately the Old Salinas River, and upstream Reclamation Ditch
tributaries including Gabilan Creek. This section also considers Lake El Estero in Monterey and
upstream tributaries within the El Estero watershed. Based on the substantial evidence in the
hydrologic analyses in Appendices N, O, P, and Q and the expertise of the hydrologists at
Schaaf & Wheeler (Daniel Schaaf, P.E. and Andrew Sterbenz, P.E.), the fisheries biologist at
HDR (William Snider, PhD), wetland and terrestrial biologists at DD&A, less than significant
operational impacts to fisheries were identified in the downstream reaches at and below the
Tembladero Slough diversions and no impacts to fisheries would occur in the Moss Landing
Harbor nor in Elkhorn Slough or in the ocean. Therefore, based on the analysis presented in

Final EIR
4-53
September 2015
the Draft EIR, as clarified in this Final EIR,3 the fisheries impact analysis and study area are
appropriately defined.
Biological Resources: Terrestrial (including aquatic species and habitat, except fish). In Section
4.5 (Biological Resources: Terrestrial), the Biological Project Study Area was defined to include
areas where permanent and temporary impacts may occur to biological resources as a result of
project construction and operation. The Project Study Area was defined using input from the
project technical team, preliminary project plans, and assessor parcel information as well as
expert opinion of the biologists and hydrologists preparing the analysis. Relevant information
from these sources was combined using Geographic Information Systems (GIS) software to
create the final Project Study Area. In reference to the locations mentioned in the comment, the
surface areas and surrounding impact areas of the Old Salinas River Channel, Reclamation
Ditch, Tembladero Slough, and Blanco Drain were included. The analysis further defined
Affected Reaches as portions of the Reclamation Ditch, Tembladero Slough, and the Old
Salinas River Channel and adjacent habitat areas that would be subject to potential affects of
the operation of the project as a result of changes in hydrology and water quality due to the
proposed diversions. Based on the hydrologic analyses in Appendices N, O-Revised, P, and QRevised and the expertise of the hydrologists at Schaaf & Wheeler (Daniel Schaaf, P.E. and
Andrew Sterbenz, P.E.), wetland and terrestrial biologists at DD&A, less than significant
operational impacts to terrestrial (wetland/aquatic) habitat and non-fish species were identified
in the downstream reaches at and below the Reclamation Ditch and Tembladero Slough
diversions. In addition, as documented in the Draft EIR and clarified in Master Response #4:
Reduction in Surface Water Flows, no impacts to terrestrial (wetland/aquatic) would occur in or
near the following water bodies: tributaries to the Reclamation Ditch, Salinas River, Salinas
River Lagoon, Moss Landing Harbor, Elkhorn Slough, Moro Cojo Slough, and the
ocean/Monterey Bay. Therefore, based on the analysis presented in the Draft EIR, as clarified
4
in this Final EIR, the review of potential impacts to Moss Landing Harbor and Elkhorn Slough
and the determination of the study area for the biological resources: terrestrial analyses is
appropriate.
Responses to comments F-9, F-9a through F9-e, and G-2, above, Master Response #4:
Reduction in Surface Flows, and Appendix AA, in this Final EIR present descriptions,
analyses, and rationale regarding the water quality and hydrologic functions of the water bodies
(Tembladero Slough, Old Salinas River Channel, Moro Cojo Slough, Moss Landing Harbor, and
Elkhorn Slough) downstream of the proposed diversions. In these responses and the
accompanying technical analyses, the additional analysis in the Final EIR reinforces the Draft
EIRs findings that the proposed source water diversions would not result in a measurable /
detectable change in the features downstream of the points of diversion that are important to
the health and viability of biological resources and ecosystems (including flows, quality/salinity,
levels, surface/groundwater interaction, and plant uptake). Biological resources (including other
aquatic species/biota, habitat, and ecosystem services) in the water bodies (Salinas River,
Salinas River Lagoon, Old Salinas River Channel, Tembladero Slough, Moss Landing Harbor,
Elkhorn Slough, Moro Cojo Slough, Monterey Bay and the Pacific Ocean) would not be
significantly impacted by the Proposed Project diversions (individually and in combination), nor
would the diversions result in a considerable contribution to any cumulative impacts).
G-4
CDFW references the comments in G-2 and G-3 and concludes that Draft EIR requires
recirculation. See the responses to comments G-2 and G-3 above, and Master Response #1:
The information added about fisheries in this Final EIR supports the existing analysis and conclusions, and clarifies
inquiries within comments on the Draft EIR.
4
The information added about terrestrial biological resources in this Final EIR supports the existing analysis and
conclusions, and clarifies inquiries made within comments on the Draft EIR.

Final EIR
4-54
September 2015
Adequacy of the Draft EIR, Master Response #4: Reduction in Surface Water Flows (including
Appendix AA), and Master Response #5: Fisheries Impact Analyses in Chapter 3, Master
Responses to Comments. The information provided in the Final EIR does not constitute new
information triggering recirculation.
G-5
See the response to comment G-2 and G-3, above, Master Response #4: Reduction in Surface
Water Flows (including Appendix AA), and Master Response #5: Fisheries Impact Analyses in
Chapter 3, Master Responses to Comments.
G-6
See the response to comment G-2 and G-3, above, Master Responses: #4: Reduction in
Surface Water Flows (including Appendix AA), and Master Responses #5: Fisheries Impact
G-7
Master Response #4: Reduction in Surface Water Flows in Chapter 3, Master Responses to
Comments and Appendix AA of this document demonstrate that the Proposed Project would
not result in detectable changes to salinity and freshwater availability in the Elkhorn Slough on
an average daily, monthly, or annual basis and thus would have a less-than-significant impact
on the estuarine habitats in Elkhorn Slough.
G-8
See Master Response #4: Reduction in Surface Water Flows in Chapter 3, Master Responses
to Comments and Appendix AA of this document.
G-9
The biological resources sections of the Draft EIR (Section 4.4), as amended in this Final EIR
(see Chapter 5, Changes to the Draft EIR), adequately evaluate impacts to foraging and
refugia habitat of young out-migrating steelhead due to the Proposed Project. See Master
Response #4: Reduction in Surface Water Flows and Master Response #5: Fisheries Impact
Analyses, in Chapter 3, Master Responses to Comments.
G-10
See Master Response #4: Reduction in Surface Water Flows in Chapter 3, Master Responses
to Comments and Appendix AA of this document.
G-11
The proposed diversions will be subject of a water rights application process, including
submittal of information required by California Water Code Section 1260(j). In July 2015, the
MCWRA submitted amended applications for the water rights to divert from the three surface
water diversion points (i.e., Reclamation Ditch, Tembladero Slough, and Blanco Drain) for the
benefit of the Proposed Project (MCWRA, 2015). The State Board has clarified that an
additional application is required for diversions from Lake El Estero. Such an application will be
pursued if the Lake El Estero waters are used for the Proposed Project. The analysis of effects
of the Proposed Project diversions on fish and wildlife is contained within this EIR.
G-12
Minimum flow requirements likely will be determined based on the NMFS Biological Opinion for
the Proposed Project. Draft EIR Section 4.4, as modified in this Final EIR, provides a detailed
analysis of the potential effects on fisheries. Draft EIR section 4.5, as modified in this Final EIR,
provides a detailed analysis of the potential effects on other aquatic species habitat and
biological resources. Refer to Chapter 5, Changes to the Draft EIR, in the following sections:
Changes to 4.4 Biological Resources: Fisheries and Changes to 4.5 Biological Resources:
Terrestrial. See also Master Response #4: Reduction in Surface Water Flows (including
Appendix AA) and Master Response #5: Fisheries Impact Analyses in Chapter 3, Master
G-13
See Master Response #4: Reduction in Surface Water Flows (including Appendix AA) and
Master Response #5: Fisheries Impact Analyses in Chapter 3, Master Responses to
Comments.

Final EIR
4-55
September 2015
G-14
Pages 4.18-32 through 4.18-34 of the Draft EIR have been updated as requested in this
comment; see Appendix C-Revised and Chapter 5, Changes to the Draft EIR.
G-15
The Draft EIR on page 4.5-25 acknowledges that the tricolored blackbirds (Agelaius tricolor)
have been documented to occur immediately adjacent to the Coastal Alignment of the Product
Water Conveyance pipeline and that suitable habitat exists at the Salinas Treatment Facility,
Blanco Drain Diversion, Lake El Estero and the three Affected Reaches of water bodies
downstream of the proposed points of diversion. The text on page 4.5-25 of the Draft EIR has
been updated to reflect that the Fish and Game Commission recently listed this species as
endangered under the California ESA on an emergency basis. See Chapter 5, Changes to the
Draft EIR.
G-16
The comment states the CDFWs responsibility and authority as a Trustee agency. The relevant
text in this comment has been added to the Draft EIR on pages 4.4-31 and 4.5-42. See
G-17
The comment describes CDFWs role as a responsible agency under Fish and Game Code
2081. The Draft EIR also acknowledges this role on page 2-88 in Table 2-22 and on pages 4.541 and 4.5-42. No further response is necessary.
G-18
The comment states the CDFWs responsibility and authority under the Fish and Game Code
sections 1600 et seq and that the Proposed Project would be required to obtain a Lake and
Streambed Alteration Agreement. The project proponents will obtain Lake and Streambed
Alteration Agreements for surface water diversions, rediversions, and stream crossings.
G-19
Pages 4.18-32 through 4.18-34 of the Draft EIR have been updated as requested in this
comment; Appendix C-Revised and Chapter 5, Changes to the Draft EIR.
G-20
The comment provides information on the California Department of Fish and Wildlifes authority,
and expertise related to the water rights permit application process and is not a comment on
the environmental analysis in the EIR. No response is necessary.

Final EIR
4-56
September 2015
Letter H
DlnEC'l'OilS
MARINA COAST WATER DISTRICT

11 RF:SF.RV A'!'ION UOAD, MAIUNA, CA 93933-2099
Home PHgc: www.mcwcl.org
TEL: (831) 384-6131 FAX: (831) 883-5995
IIOWI\RO GUSTAFSON
Pt't'Sillt.,u
PETF.RW
Vice Prt:rklt.m
THOMAS P. MOORE
WILLIAM Y. LEE
JAN SIIRINER
June 4, 2015
VIA ELECTRONIC & RE GULAR MAIL

ATfN: Bob Holden, Principal Engineer
5 Harris Ct., Bldg D
Monterey, CA 93940
g\vrlitlmrwpca.com
Re: Pure Water Monterey Groundwater Replenishment Project (SCH No. 201305 1094) Marina Coast Water District's Comments on the Draft Environmental Impact Report
Dear Mr. Holden:
Thank you for the opportwlity to comment on the Pure Water Monterey Grow\dwatct
Replenishment Project (" GWR Project") and the associated Draft Environmental impact Report
("DElR"). The purpose of this letter is twofold.
First, this letter provides Marina Coast Water District's ("MCWD") comments on the proposed
water sources and Product Water Conveyance pipeline alignment for the GWR Project. As
explained below, MCWD supports the Monterey Regional Water Pollution Control Agency's
("MRWPCA' s") proposed use of agricultural wash water, Salinas City stonn water, and surface
water flows from the Reclamation Ditch, Blanco Drain, Tcmbladero Slough, and Lake El Estero
as source waters for the GWR Project MCWD also supports the use of"unused secondary treated
effiuent" as source water so long as MCWD's senior contractual rights to recycled water from
MRWPCA are fully protected or a mutually beneficial resolution of those rights is achieved that
allows MCWD to meet the present and planned future water supply needs of the City of Marina
and Ord Community. MCWD simi larly supports exploring mutually beneficial ly uses of the
Regional Urban Water Augmentation Project (RUWAP) pipeline alignment that can meet the
present and planned future needs of MCWD, the Fort Ord Reuse Authority (" FORA"), and the
GWR Project.
Second, this letter provides MCWD's comments on the adequacy of the DEI R under the California
Environmental Quality Act ("CEQA") (Public Resources Code 2!000 et seq.) and the CEQA

Final EIR
4-57
September 2015
H-1
H-2
MCWD Comments on GWR Project Draft EIR (SCH No. 2013051 094)
June4, 2015
Page2
Guidelines (Cal. Code Regs., titl.14, 15000 et seq.). As explained herein, MCWD believes
clarifications to the DEIR are necessary to ensure it complies with CEQA.
I.
H-2
Con't
GWR Source Waters and MCWD's Senior Contractual Rights to Recycled Water.
Section 4.18 of the DEIR (Water Supply and Wastewater Systems) accurately states that MCWD
has an existing agreement in place with MRWPCA that entitles it to receive tertiary treated
recycled water from the Regional Treatment Plant up to the volume of wastewater it conveys to
the treatment plant. (DEIR, p. 4.18-8.) While the DEIR recognizes MCWD's senior recycled
water rights, the EIR needs to clarify MRWPCA 's contractual obligation to provide 650 AFY of
MRWPCA's summer recycled water and 300 AFY ofMCWD's senior summer recycled water to
MCWD for the Ord Community as described below.
MRWPCA has already admitted to these cootractual obligations in related fil ings with the
California Public Utilities Commission ("CPUC"). 1 In MRWPCA's July 25, 2012 Reply Brief
"Regarding Water Rights for a Groundwater Replenishment Project," pages 3-4, filed with the
CPUC, MRWPCA's long-time water rights attorney, Martha H. Lctu1ihan, stated the following:
MRWPCA proposes to use unused flows into the Regional
Treatment Plant during a time when (1) the CSIP demand is fully
satisfied and (2) MCWD's firm right is untouched (keeping in mind
that MCWD does not have use for more than a fraction of that firm
right). MCWD is capped at 300 AF during the six month period
from April tluough September. MCWD can take the amount it
deferred taking during these montl1s during tl1e remaining six
months of October through March. This means that MCWD has the
most supply during months wben there is typically far less demand.
**
It meritS note that MR WPCA has already committed the majority of
its most valuable supply to the MCWD RUWAP, in the form of 650
AF of "summer" water that can be used during the period of May
through August. MRWPCA 's Opening Brief analysis further
assumes that MRWPCA wil l also provide most of the water needed
for RUWAl' dw"ing April and September, another significant
contribution to MCWD. Without tllis MRWPCA water, the
MCWD R UWAP would not be fettsible ... Jn addition to its own
Annexation Agreement water, MCWD now can use the most
valuable element ofMRWPCA's water right.
'MCWD understands that successful implementation of the GWR Project could affect the sizing ora desalination
facility proposed by the California-American Water Company ("Cal-Am") in CPUC Application ("A.") 12040 19,
as part of its Monterey Peninsula Water Suppty Project ("MPWSP"}. CPUC approval, in addition to other
applicable state and regulatory approvals, would be required in order for CaiAm, an investorowned regulated
public utility, to eonstructund operotc the MPWSP.

Final EIR
4-58
September 2015
H-3
MCWD Comments on GWR Project Draft EIR (SCI-I No. 2013051094)

June4, 2015
Page 3
(Exhibit "A", emphasis added.)
Tfte June 2009 MCWDIMRWPCA MOU.

DEIR Section 4.18.3.4 w1der "Marina Coast Water District's Legal Agreements" generally
discusses MCWD's contractual rights to recycled water. On June 5, 2009, MCWD and MR WPCA
entered into a 50-year Regional Urban Water Augmentation Project Memorandum of
Understanding ("RUWAP MOU"). (Attached as Exhi bit "B".) While the DEIR quotes Section
1.2 of the RUWAP MOU (DEIR, p. 4.18-22), Section 2 of the RUWAP MOU sets forth
MR WPCA's express contractual commitment to MCWD and RUW AP by stating:
H-4
The MR WPCA hereby commits 650 AFY of recycled water during the months of May
through August each year from MRWPCA entitlements. MCWD hereby comm its 300
AFY of recycled water during the months of April through September each year from
MCWD entitlements. The MR WPCA and MCWD commit additional quantities of
recycled water as needed during the months of September through Apri l from MRWPCA
enti tlement~ and October through March fTom MCWD entitlements to ao;sure del ivery of
the agreed water commitments to RUWAP.
While Section 1.1 of the 2009 RUWAP MOU has the standard CEQA language disclaiming an
irreversible conunitment of resources to actually construct t11e facilities necessary to implement
the recycled water allocation for the 300 AFY allocation to the Monterey Peninsula, Section 1.1
goes on to state:
MCWD has complied with the requirements of CEQA for a lead
agency and MRWPCA has complied with the requirements of
CEQA for a responsible agency in the consideration and approval of
this MOU. MCWD and the MRWPCA shall each comply with their
respective requirements under CEQA to implement the RUW AP in
accordance with the RUWAP ElR.
H-5
Thus, both MRWPCA and MCWD have fully complied with their obligations under CEQA in
order to support: (a) MRWPCA's commitment of650 AFY of summer recycled water to MCWD
for the Ord Community; {b) MCWD's separate commitment of 300 AFY of summer recycled
water to the Ord Community; and (c) the commitment by both agencies to supply 471 AFY
recycled water during other months to the Ord Community- for a total of I ,427 AFY. The ElR
should clarify that these senior contractual rights currently exist.
Tlte July 2009 MRWPCAIMCWDIMCWRA MOU.

TI1e DEIR fails to mention that one month later on July 1, 2009, MRWPCA, MCWD, and
MCWRA entered into a MOU ("Three-Way MOU", attached as Exhibit "C"), which referenced
the RUW AP EIR and in Exhibit B to the MOU provided for a "Seasonal Cap on Urban Tertiary
Treated Waste Water Allocations" of 766 AFY (exclusive of MCWD's 300 AFY summer
allocation) during the months of May tlu-ough August. Under the RUWAP MOU, MRWPCA
committed to provide 650 AFY during the months of April through September (6 months) of each

Final EIR
4-59
September 2015
H-6
MCWD Comments on G WR Project Draft EIR (SCH No. 20 13051 094)

June4,2015
Page4
year, whereas the Three-Way MOU committed both MRWPCA and MCWRA to provide more
recycled water over only four months.
H-6
Con't
Following the discussion in DEIR Section 4. 18.3.4 of "Marina Coast Water District's Legal
Agreements" and Monterey County Water Resources Agency's Rights," at the top of page 4.1824, the DEIR lists three contracts, which must be addressed in negotiating a "Definitive
Agreement", i.e., the 1989 MRWPCAIMCWD Annexation Agreement, the 1992
MRWPCA/Montercy County Water Resources Agency ("MCWRA ")Agreement as amended, and
the 1996 MRWPCA/MCWD Annexation Agreement. However, no mention is made of
MRWPCA's contractual commitments to MCWD under the 2009 RUWAP MOU and the 2009
Three-Party MOU. The DEIR's conclusion that the GWR Project would not adversely adverse
impact MCWD's ability to use its share of recycled water simi larly fails to mention and account
for MRWPCA's existing contractual commitment to provide at least 950 AFY of summer recycled
water to MCWD under these two MOUs and, therefore, the DEIR's conclusion is unsupportable:
impact of the Proposed Projec/ on MCWD Rights to Recycled
Water. The RUWAP Recycled Water Project is a cumulative project
because although portions have been constructed, it is not yet
operating because it lacks Funding for critical transmission
infrastructure and user agreements. Because the Proposed Project
would rely upon new source waters during the irrigation months of
Apri l through September to meet its needs (see Appendix 13), it
would not have an adverse impact on the abi lity of Marina Coast
Water District to use its share of recycled water from the existing
municipal wastewater flows as described in the 1989, and 1996
Agreements that are described above in Section 4.18.3.4. The MOU
indicates that the Proposed Project would not use secondary effluent
flows that represent the amount of wastewater committed to use by
Marina Coast Water District. In the future, when Marina Coast
completes construction of its recycled water system and enters into
user agreements with urban irrigators, the wastewater flows
committed to those demands would be provided.
H-7
(DEIR, p. 4.18.38.) While this could be considered an oversight on the DEIR's part, there is
significant evidence to the contrary.
During a May 13, 2015 meeting between MRWPCA management and MCWD management,
MRWPCA management stated that because of the insistence by MCWRA for MRWPCA to
provide all available recycled water to the Castroville Seawater lntn1sion Project ("CS!P"),
especially during the summer months, the I,427 AFY of recycled water allotted to MCWD for the
Ord Community, including the 650 AFY during the summer, could not be provided to MCWD.
In addition, DEIR Appendix B, Source Water Assumptions Memorandum, shows that MRWPCA
is committing all its summer-recycled-water to MCWRA and the CSIP. As listed at the top of
page 6 of Appendix B, the proposed priority of source water usage lists "unused secondary treated
effluent" as the first source water to use for the GWR Project. In other words, all secondary treated
effluent that is not currently being used is allocated first to the GWR Project. No reservation is

Final EIR
4-60
September 2015
H-8
H-9
June4, 2015
Page 5
made to later withdraw that recycled water from CSIP for delivery to MCWD pursuant to the 2009
RUWAP MOU or 2009 Tlu-ee-Party MOU. Therefore, it appears the GWR Project's use of
"unused secondary treated effluence" would result in MR WPCA being unable to meet its
contractual obligation to supply both MCWD's 300 AFY senior April through September
entitlement and the 650 AFY May through August water under the 2009 RUWAP MOU. If
MRWPCA believes this is not the case, a table showing the monthly total for each source ofGWR
Project water (including how much recycled water would be produced from each source) compared
with all proposed monthly distributions (e.g., CSTP, GWR Project Water, and MCWD full
allotment of recycled water for Central Marina and the Ord Community) under both baseline
scenarios should be added to the Final EIR. The table should show whether there are sufficient
source waters for the GWR Project to provide MCWD with its 1,427 AFY of recycled water and
meet all of the GWR Project's conunitments and objectives.
This analysis is of critical importance to MCWD because MCWD is contractually obligated under
its agreements with FORA- unless the FORA Board directs otherwise-- to require MR WPCA to
fully comply with MRWPCA's contractual obligation to provide 950 AFY of summer water plus
477 AFY water during the other months as explained in Section LA below. Otherwise, in
MRWPCA's own words: "Without this MRWPCA water, the MCWD RUWAP would not be
feasible." This in tum could result in potentially severe adverse impacts for recycled water supplies
needed for proposed and planned future developments in the Ord Conummity as described in
Section J.B below. Such a result would requiie substantial revisions to the DEIR as described in
Section Ill below.
H-9
Con't
H-10
H-11
A. MCWD 's Contr actual O bligation to P rovide Water Supplies for the Fort Or d R euse
Plan's P rojected 2030 Water S upply S hortfall of 2,400 AF.
Pursuant to the September 21, 1993 Agreement between the United States of America and the
MCWRA concerning A.lUlexation of Fort Ord into Zones 2 and 2A of the Monterey County Water
Resources Agency, the MCWRA allocated groundwater extraction rights of 6,600 AFY to the U.S.
Army. Under the Fort Ord Reuse Plan, the Army retained 1,582 AFY and the balance was
allocated by FORA to various local and State public agencies. The Reuse Plan projected a year
2030 water demand of 9,000 AFY. With only 6,600 AFY of groundwater available, the Ord
Community would be 2,400 AFY short of the projected 2030 demand. (See DEIR, pp. 4.18-22
and 6-11.)
H-12
F ORA's versus MCWD 's Responsibility for Atltfitional Water anti Sewer Facilities for tlte Ord
Community.
Under the 1998 Water/Wastewater Facilities Agreement (" 1998 Agreement"), FORA transferred
ownership of all of the then existing Ord water and sewer facilities to MCWD; title was transferred
in 2001. 2 Under Section 3.2 of the 1998 Agreement, FORA has the responsibility to detem1ine,
H-13
2
After MCWD acquired the water and sewer infrastructure in the former Fort Ord, MCWD and
MRWPCA have continually disagreed over whether MCWD's senior recycled water right
extended to MCWD's Ord Community sewer flows absent MCWD's annexation of the Ord
Community service area. (See DEIR Fig1tre 4.18-1 , Ord Community service area depicted as

Final EIR
4-61
September 2015
MCWD Comments on OWR Project Draft EIR (SCH No. 2013051094)

June 4, 2015
Page6
in consultation with MCWD, what add itional water and sewer facilities are necessary for MCWD's
Ord Community service ru-ea to meet the Reuse Plan requirements. Once FORA determines that
add itional water supply and/or sewer conveyance capacity is needed, it is MCWD' s responsibil ity
to plan, design, and construct such add itional water and sewer facilities (Section 3.2. 1). Section
7.1.2 requires FORA to insure that MCWD recover all of its costs offi.lrnishing the facilities to the
service ru-ea:
7 .1.2. MCWD Will Recover Costs. MCWD will recover all of its
direct and indirect, shon term and long term costs of furn ishing the
faci lities to the service area. MCWD shall not be required to take
any action in connection with furnishing the facilities to the service
area unless and until a source of funds is secured from the service
area to pay in full in a reasonable manner consistent with normal
accounting practices all of MCWD's direct ru1d indirect, short term
and long term costs of the action to be taken by MCWD, including
costs of administration, operation, maintenance and capital
improvements to provide adcq uate system capacity to meet existing
and anticipated service demands.
The division of responsibilities between FORA and MCWD is set forth in the
following table:
FORA's Responsibility
Determine what additional
water supply and sewer
f&cilities are necessary for the
Ord Community service area
Insure that MCWD recovers
all ofMCWD's costs of
furnishing the facilities,
including the capital and
rumual administration,
operation, and maintenance
costs of new additional
facilities.
MCWD's Responsibilities
Own, operate, and maintain all
of the water and sewer
facilities, including new
additional facilities, for the
Ord Community service area
Plan, design, and construct
additional water and sewer
facilities determined necessary
by FORA
Ord Development Areas.) As discussed above, the 2009 RUWAP MOU sidestepped that issue
and provided the Ord Community service area with I,427 AFY of recycled water.

Final EIR
4-62
September 2015
H-13
Con't
June4, 2015
Page 7
The development of the recycled water component of the Regional Urban Water Augmentation
Project (RUWAP) illustrates how joint FORA-MCWD planning for new additional facil ities has
been cooperatively carried out.
H-14
Regioual Urbau Wttler Augmenlatioll Project.

ln 2002, MCWD, in cooperation with FORA, initiated the RUW AP to explore water supply
alternatives to provide the additional 2,400 AFY of water supply needed for the Reuse Plan.
MCWD as the CEQA lead agency prepared a DEIR for RUWAP consisting of two primary
alternatives: a 3,000 AFY Recycled Water Altemative and a 3,000 AFY Seawater Desalination
Alternative. Additional alternatives analyzed included a Hybrid Altemative consisting of a 1,500
AFY of Recycled Water (allocating 1,200 APY to the Ord Community and 300 AFY to the
Monterey Peninsula) and 1,500 AFY of Seawater Desalination (allocating 1,200 AFY to the Ord
Community and 300 APY to replace MCWD's existing desalination plant).
H-15
During MCWD 's enviromnental review of the RUWAP, in August 2003, MCWD and MRWPCA
determined that up to 1,727 APY of recycled water could be provided by the Regional Urban
Recycled Water Distribution Project without the need for seasonal storage - allocating 1,427 AFY
to the Ord Community and 300 AFY to the Monterey Peninsula. (See DEIR Section 6.2. 1.2 for
general discussion; see also RUWAP Addendum No.2, p. 5.) 3
MCWD cenified the ElR for RUWAP in 2004 with Addendum No. I to the EIR was adopted in
2006 and Addendum No.2 was adopted in February 2007. Addendum No.2 designated a modified
Hybrid Altemative as the preferred alternative.
FORA Board Resolulio11 07-10.

Upon the adoption of the modified Hybrid Alternative, the FORA Board adopted Resolution 0710 (May 2007), which allocated 1,427 AFY of RUWAP recycled water to local and State public
agencies, including 453 AFY to the City of Seaside and 134 A FY to Monterey County. (See
FORA Board Resolution 07-10 attached as Exhibit " D" .) A Resolution recital stated that the
MCWRA and MRWPCA have entered into an agreement to provide up to 850 AFY of recycled
water from May through August that MRWPCA has agreed to dedicate to RUWAP. Resolution
07-10 was FORA's determination under Section 3.2.2 of the 1998 Agreement, which requires
MCWD to develop 1,427 AFY of recycled water for the Ord Community to help close the gap on
the projected 2,400 AFY 2030 shortfal l. Consequently, pursuant to Section 7.1.2 of the 1998
Agreement, FORA is obligated to approve MCWD's recovery of all ofMCWD direct and indirect
costs for furnishing that recycled water.
} MCWO assumes MRWPCA has the RUWAI' EIR and addendums in il$ files as they arc referenced in the DEIR.
If this is not the case, MCWO will provide these documents upon request.

Final EIR
4-63
September 2015
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MCWD Comments on GWR Project Draft EIR (SCI-I No. 20 13051094)

June4, 2015
PageS
B. Adverse Impacts on New Developments within the Ord Community if MRWI' CA
Cannot ot Will Not Deliver MCWD's Full Allotment of RUWAP Recycled Water.
If MRWPCA is unable or unwilling to ensure its contractual commitment to MCWD for its full
allotment of RUWAP recycled water, then there are immediate adverse impacts to new
developments wi thin the Ord Community. For example, the City of Seaside's DETR for Monterey
Downs and Monterey Horse Park has a projected non-potable (i.e., recycled) water demand for
Phases I to Ill of 145.7 AFY and a total non-potable water demand for all6 phases of302.S AFY.
(See
Monterey
Downs
and
Monterey
Horse
Park
DEIR
available
at
http:/fsensidemontereydownsandveteransccmctervspccillcplnn.com/ Documcnts/dcir/dcir/0 I%20
DRAD"%20E!R/Scc%2004 19 Water.ll.S!.f, including Table 4.19-11 on p. 4-19-23. Pages 4.1022 and 4.19-23 ofthe Monterey Downs DEIR also explain the uses for the recycled water supplies:
H-17
T he recycled water demand reflects exterior uses tor landscape irrigation and dust control.
The residential front yards would be maintained by a HOA; therefore, those inigation
demands are included in the recycled water demand totals.
Of the 587 AFY of future recycled water, FORA allocated 453 AFY to the Ci ty of Seaside
and 134 AFY to the Cotmty of Monterey pursuant to FORA Resolution 07-1 0. The City
of Seaside has in turn sub-allocated 430 AFY for Bayonet and Blaekhorse Golf Courses
with 157 AFY remaining wtallocatcd. 4
The unallocated 157 AFY would be allocated to Phases I to III of the Monterey Downs
Project.
According to the 20 I 0 UWMP, the water augmentation supply is expected to be on-line by
2016. s
IfMR WPCA does not deliver summer recycled water to MCWD, then MCWD would be unable
to provide recycled water to the Monterey Downs Project. If no recycled water is forthcoming
from MRWPCA, then it is uncertain what steps (if any) the City of Seaside can take to provide
potable water in substitution of the recycled water needed for Phases l to Ill in order to approve
the Monterey Downs Project. Notably, the State Water Resources Control Board through
emergency regulations due to the ongoing Drought has imposed severe limitations on the use of
potable water for new exterior uses. It is unknown at this time whether those and other potable
water usc limitations will continue after the cwTent drought emergency ends and thus constitute
U1e "new normal" for potable water usc.
Without that express reservation of contractual rights, one way that MRWPCA could meet its
RUWAP MOU contractual obl igation to MCWD would be to build new storage facilities to store
Advanced Treated Water for summer usc within the Ord Commtmity. Assuming it is feasible to
store but not use Advanced Treated Water from September through April, all of the cost for such
storage facilities would need to be borne by MR WPCA if that new arrangement is agreeable to
The City of Seaside has not officially allocated recycled water for irrigation of the two golf courses with a demand
of approximately 430 AFV or the remaining 157 AFV to this Project.
'The water augmentation supply discussed in the 2010 UWMP is based on the RUWAP hybrid alternative,
discussed above.

Final EIR
4-64
September 2015
H-18
H-19
MCWD Comments on GWR Project Droft EtR (SCH No. 2013051094)

June 4, 2015
Page9
FORA and to MCWD who would have to own, operate, and maintain those facilities. Another
way would be for MRWPCA and MCWD to reach a mutually beneficial resolution of those rights
acknowledged in the applicable Definitive Agreements, subject to FORA's approval.
II.
Comments on .RUWAP Alignment foa Product Water Conveyance pipeline

alignment.
Section 2.9.1.1 of the DEIR states "MRWPCA and the Water Management District may
pursue agreements and permits to use a portion or portions of the pipeline originally proposed
and/or constructed for the Recycled Water Project by Marina Coast Water District (i.e., converting
the purpose of the pipel ine for usc by the Proposed Project to convey advanced treated Product
Water from the AWT Facility to the Injection Well Facilities) or they may pursue a shared
easement to accommodate both pipelines in some portions of the alignment." (DEIR, p. 2-67 and
2-68.) As MCWD stated in its comments on the GWR Project's Notice of Preparation ("NOP")
requesting the DEIR include tltis alternative, MCWD is willing to discuss potential access to
RUWAP facilities for the GWR project. MCWD appreciates MRWPCA's inclusion of this
alternative in the DEIR and remains will ing to discuss potential mutually beneficial options for
use of the RUWAP facilities and/or alignment by the GWR Project. That said, such options must
ensure that MCWD can meet is contractual obl igations to provide water supplies to the Ord
Community as discussed above.
III.
H-19
Con't
H-20
H-21
Comments on GWR Project DEIR.
The following paragraphs detail MCWD's comments on the DEIR's compliance with CEQA and
the CEQA Guidelines.
A. Summary (Chapter "S")
CEQA Guidelines Section 15 123 states that the summary "shall identify: (1) (e]ach significant
effect with proposed mitigation measures and alternatives that would reduce or avoid that
effect; ... and (3) (i]ssues to be resolved including the choice among alternatives and whether or
how to mitigate the significant effects." (CEQA Guidelines, 15123, subd. (b), emphasis added.)
The DEIR's Summary does not identify or discuss alternatives that would reduce or avoid the
project's significant effects in the text or summary tables (Tables S-1 and S-2). Nor does the
DEIR's Summary include a discussion of the issues to be resolved. The Summary should be
revised to include the required information.
H-22
B. Introduction (Chapter 1)
Section 1.4 the DEIR on p. 1-5 should be clarified to note that the citations in the first paragraph
arc to the CEQA Guidelines and not the CEQA statute. This section should be further clarified to
note that a project's impacts must be reduced to a less than significant level where feasible or the
lead agency must adopt a Statement of Overriding Considerations for any impacts that remain
significant after all feasible mitigation is adopted. As the cited Section 15092 of the CEQA
Guidelines provides:

Final EIR
4-65
September 2015
H-23
H-24
MCWD Comments on GWR Project Draft EIR (SCH No. 20 I 305 I 094)
June 4, 2015
Page 10
(b) A public agency shall not decide to approve or carry out a project
for which an EIR was prepared unless either :
(1) The project as approved will not have a significant effect on the
enviroJUnent, or
(2) The agency has:
(A) Elimiunted or substantially lessened nll significant effects on
the environment where fcnsible as shown in findings under Section
l 5091 , and
H-24
(B) Determined that any remaining significant effects on the

environment found to be unavoidable under Section 15091 arc
acceptable due to overr iding concerns as described in Section
15093.
(CEQA Guidelines, 15092, subd. (b), emphasis added.) T he current wording in this section
suggests a statement of overriding considerations in not required under CEQA if a project's
impacts are substamially lessened. Therefore, the section needs to be clarified.
C. Project Description (Chapter 2)
Section 2.3.2.4 of the DEIR (p. 2- 10) states that in "recent submittals to the California Public
Utilities Commission, CaiAm estimates that it needs a total supply source of l 5,296 AFY to satisfy
the Cease and Desist Order and forecasted demand. In order to do this, Ca!Am will need to
augment its water supplies by 9,752 AFY, which includes water to satisfy a requirement to retum
water to tl1e Salinas Valley to offset the amount of fresh water in the feed water from the
desal ination plant's slanted coastal intake wells." There is no support for these statements. As the
GWR Project is not contingent on approval of Cal-Am's proposed desali nation plant's slanted
coastal intake wells, MCWD suggests removing the statements from the DEIR. MCWD will
provide separate comments regarding the larger MPWSP EIR, including its comments on the
required retum water to the Salinas Valley to offset the amount of grow1dwater in the feed water
from Cal-Am' s proposed desalination plant's slanted coastal intake wells should Cal-Am
demonstrate the right to take such water and should that alternative be approved, to the CPUC.
Section 2.3.3 of the DEIR (p. 2-1 0) states the geographic extent of seawater intmsion in Salinas
Valley Ground water Basin's 180-Foot and 400-Foot Aquifers is shown in Figure 2-7. The ETR
should clarify that substantial information gaps exist regarding the level of seawater intrusion into
the 180-Foot and 400-Foot Aquifers and that current data indicates the significant areas shown on
the Figure 2-7 maps as having chloride levels above over 500 mg/L actually do not. (See e.g.,
Draft Monterey Peninsula Water Supply Project Groundwater Modeling and Analysis, April 17,
2015,
Figures
43
and
44
[avai lable
at
Monterey
hup://www.cpuc.ca.guv/ En vi ronmcnt/inlolcsafmpwsp/dc ir/Appendix E2. pQj),
Peninsula Water Supply Project Baseline Water and Total Dissolved Solids Levels Test Slant Well
Area, April
20, 20 \ 5,
Figures
3-4,
3-5,
and Table 2
[available at
htlp ://www.warersuppl yproject.ori!/Wcbsites/coastalwater/ti les!C ontcnt/4?&5 953/H WG BA SEI,

Final EIR
4-66
September 2015
H-25
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H-27
MCWD Comments on GWR Project Draft ETR (SCH No. 201305 1094)
June 4, 2015
Page I I
INE TM-20-Apr-15 I I .pdO; DEIR, Table 4.10.6 (stati ng 100 mg!L median chloride level for
wells in 180-Foot and 400-Foot Aquifers at locations between Salinas and the Salinas River).)
This section further states that several projects have been developed to address this seawater
intrusion, but then only mentions projects implemented by MCWRA. MCWD, as well as other
others, have implemented numerous projects to el iminate the long-term overdraft condition of the
Sal inas Valley Groundwater Basin and address seawater intrusion. For example, between 1985
and 2000, the District constructed both a seawater desalination plant (cmrently inactive) and a
wastewater recycling facility (the recycling facility was retired when the MCWD connected to the
MRWPCA system). More recently MCWD has implemented numerous water conservation
programs, including, among others: (I) the Water Conservation Commission; (2) a conservation
rate structure; (3) an AMR meter reading system with leak detection; (4) the California State
University Monterey Bay student learning partnership and student internship programs; (5) free
conservation devices (showerheads, faucet aerators, leak detection tablets, etc.); (6) free water
conservation education materials (e-nyers, newslelter, magnets and stickers, Restaurant and
commercial business placards, water conservation website, etc.); (7) a landscape demonstration
garden; (8) high-efficiency clothes washer and toi let rebates; (9) leak and high water use and
detection notification procedures; (I 0) free property surveys; (II) landscape walk-throughs and
inigation system checks; ( 12) water use investigations, water use data logs, and water use charts
and tables; (13) property certification on resale; (14) in-school water education classes and
assemblies; ( 15) landscape building standards and plan check procedures; (16) water-wise
landscape incentives for turf removal, conversion from sprinkler to dri p irrigation, "smart"
controller replacement, rail and soil moisture shut-off switches, etc.; (17) regional pat1icipation in
Water Awareness Committee of Monterey County Inc. A sign ificant portion ofMCWD's budget
is allocated to water conservation programs. MCWD will spend approximately $465,155.00 on
its conservation programs over the next year alone. MCWD est imates that its conservation
programs reduce pumpi ng for the Sal inas Valley Groundwater Basin by approximately 520 to 600
acre-feet of water per year. In addition, MCWD entered into a recorded annexation agreement
with MCWRA, Resources Agency, the City of Marina, the J .G. Armstrong Family, and RMC
Lonestar dated March 1996 (Atmcxation Agreement). The Annexation Agreement binds the
current property owner (CEMEX) and anyone seeking to obtain pl'Operty from CEMEX to
pumping 500 acre/feet pet year for use on the property. MCWD has also adopted a Water Shortage
Contingency Plan for staged voluntary and mandatory conservation efforts. MCWD request the
EIR clarify that other entities, including MCWD, have developed projects and ptograms to address
this seawater intrusion that are not discussed in the DEIR. MCWD further requests the DEIR list
the Annexation Agreement as one of the projects addressing seawater intrusion in this section.
Table 2-22 in the Chapter (pp. 4.2-87 4.2-90) docs not appear to include contractual agreements
with local agencies for urban runoff water. (See the last paragraph on page 4.1 8-33 stating that
MRWPCA will need to obtain contractual water rights from the applicable local agencies for urban
n moff water.) The Table should be updated to include these agreements.

Final EIR
4-67
September 2015
H-27
Con't
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H-29
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MCWD Comments on GWR Project Draft EIR (SCH No. 2013051094)

June 4, 2015
Page 12
D. Environmental Setting, Jmpacts, and Mitigation Measures (Chapter 4)
Air Quality and Greenhouse Gas (Section 4.3)
The DEIR should expand its discussion of Greenhouse Gas (GHG) emissions to address why the
Project would not impede the attaimnent of the GHG reduction target provided for in Executive
Order B-30-15 (available at http:/!gov.ca.govincws.php?id= 1893&).
Biological Resources: Fisheries (Section 4.4)
The last paragraph of the "Reclamation Ditch" section on page 4.4-42 states potential constructionrelated impacts would be avoided and reduced to less-than-significant levels by Mitigation
Measures BF-Ia and BF-lb (4.4-44) and implementation of best management practices (BMPs).
There is no discussion of what BMPs would be applied. Applicable BMPs should be added to the
mitigation measures. In addition, Mitigation Measure BF-1b requires preconstruction surveys for
tidewater gobies or other fish species, but does not specify when and where the surveys will be
done. The mitigation should specify particular methods that will be used for surveys (i.e., are there
agency-approved protocols?). The mitigation also states that if fish are present, "appropriate
measures in consultation with applicable regulatory agencies" will be implemented. There docs
not appear to be a performance standard attached to BF-1 b or indicate whether an incidental take
permit would be required. Please clarify this mitigation measure.
Mitigation Measure BF-2a (4.4-48 and 4.4-49) requires diversions to maintain steelhead migration
flows. The mitigation shou ld specify what level of flows will be maintained (e.g., the flows
referenced in Table 4.4-8). Mitigation Measure Alternate BF-2a also requires modifications to the
existing San Jon weir. The DEIR should clarify whether the modifications would be in compliance
with specific design requirements such as NMFS' Anadromous Salmonid Passage Facility Design
criteria and specifications. The mitigation measure should also state when the modifications would
be built.
H-32
H-33
H-34
Biological n esources: T errestrial (Section 4.5)
As a general comment on Section 4.5, to the extent that mitigation measures derive from, or are
consistent with agency guidance the DEIR should cite and refer to such guidance. In addition, a
number of mitigation measures state that buffers will be provided around the species or area to be
protected. The mitigation measures should specify the distance of the buffer (e.g., a buffer of 100
feet from the protected area).
Mitigation Measure BT-2a (pp. 4.5-92 - 4.5-93) states that when designing the facilities at
component sites, the MRWPCA shall site and design project features to avoid impacts to the
riparian and wetland habitats shown in Attachment 8 of Appendix H and Appendix I, including
direct habitat removal and indirect hydrology and water quality impacts, to the greatest extent
feasible while taking into account site and engineering constraints. MCWD notes that the RUWAP
alignment for the Product Water Conveyance would avoid impacts to riparian and wetland habitats
from the Product Water Conveyance pipeline and therefore should be considered the
environmentally superior alternative/option. Mitigation Measure BT-2c (pp. 4.5-94 - 4.5-95)

Final EIR
4-68
September 2015
H-35
H-36
MCWD Comments on GWR Project Draft ElR (SCH No. 2013051094)

June 4, 2015
Page 13
requires the project proponents to prepare and implement a frack-Out Plan. The mitigation should
specify when the plan must be prepared and examples of actions that will be addressed in the plan.
As drafted, the mitigation appears to be vague and it is not clear if it will actual ly reduce these
impacts to less-than-significant levels.
H-36
Con't
Hyd tology and Water Quality: Groundwater (Section 4.10)
In Section 4.10.2.3 (Salinas Valley Groundwater Basin and Study Area) includes a nwnber of
statements regarding the Salinas Valley Groundwater Basin that must be clarified to provide an
adequate description of the environmental setting and evaluate the Project's potential direct and
cumulative impacts.
First, the DEIR states that Dune Sand Aquifer contains mostly saline to brackish water due to
proximity with the ocean and seawater intrusion and is consequently not used as a water supply.
(DEIR, p. 4.10-5, citing Kennedy/Jenks 2004.) T his statement should also be clarified to note that
the Dune Sand Aquifer recharges the 180-foot aquifer and tl1erefore provides an indirect source of
water supply in the Salinas Region as recognized later in the DEIR on p. 4.10-66. In addition, the
Final ErR should identify the geographic extent of seawater intrusion into the Dune Sand Aquifer
to the extent it is known and provide an estimate of groundwater within the aquifer that is not
seawater intruded.
Second, the DEfR states that "[w]atcr-lcvcl data from existing wells within the 180-Foot Aquifer
in the study area indicates that the direction of groundwater flow is from the ocean southeast
toward the City of Salinas ...." (p. 4.10-7). The DEIR, however, docs not appear identify the study
area for the EIR or include well data to support tl1is statement. A map showing the Salinas Valley
Groundwater Basin study area and wells levels within the 180-foot Aquifer in the study area
shou ld be included in the EIR to support this statement.
Third, the DEIR in this section also states the geographic extent of seawater intrusion in Salinas
Valley Groundwater Basin's 180-foot and 400-Foot Aquifers is shown in Figure 2-9. (DEIR, p.
4.10-9.) This appears to be typographical error; the DEIR is likely referring to f igure 2-7.
Asswning the reference is to the Figure 2-7 maps, as noted above, the EIR should clarify that
information gaps exist regarding the level of seawater intrusion into the 180-Foot and 400-Foot
Aquifers and that current data indicates significant areas shown on the Figure 2-7 maps as having
chloride levels above over 500 mg/L actually do not. (See e.g., Draft Monterey Peninsula Water
Supply Project Groundwater Modeling and Analysis, Apri l 17,2015, figures 43 and 44 [avai lable
at
http://www.cnuc.ca.gov/Environment/info/esa/mpw-sp!tt.:ir/Anpcndixl' 2.pdD,
Monterey
Peninsula Water Supply Project Baseline Water and Total Dissolved Solids Levels Test Slant Well
2015,
Figures
3-4, 3-5,
and
Table 2
[available at
Area, April 20,
http://W\\ w. watcrsupplypmiect.org/Wcbsi teslcoastalwaterfli lcs/Contentl4985953/ll WG BASEl,
lNE TM-20-Apr-15 I I .pd!J; DEIR, Table 4.10.6 [stating 100 mg/L median chloride level for
wells in 180-Foot and 400-Foot Aquifers at locations between Salinas and the Salinas River].) The
DEIR further states that seawater intrusion has resulted in degradation of gro\mdwatcr supplies,
requiring urban and agricultural wells within the affected area to be abandoned or destroyed.

Final EIR
4-69
September 2015
H-37
H-38
H-39
H-40
June 4, 2015
Page 14
(DEIR, p. 4.10-9 citing MCWRA, 2001.) The EIR should identify the affected area, the location
of wells that that EIR indicates were required to be abandoned or destroyed, and whether
conditions have changed within the affected areas since the 200 I report cited to support the DEIR's
statements.
The DEIR's Plans and Policies Consistency Analysis must also be clarified if implementation of
the Project could result in MCWD not bei ng provide its full allotment of recycled water for the
Marina and Ord communities as discussed above. For example, the DEIR states that the Project
is consistent with City of Marina Policy 3.3 (p. 4.10-30 [Table 4. 10-II]). Assuming all of
MCWD's recycled water rights are protected under the Project, MCWD agrees tbe Project is
consistent with ihis policy. If MCWD's recycled water rights are not protected, however, the
Project would conflict with the City's policy to minimize the consumption of water for urban
purposes and make maximum possible usc of recycled water. The Final ETR should confii111 the
Project is consistent with the City's J>Olicy.
Table 4. 10-9 (p. 4.10-43) includes the Seaside Basin water balance, but does not indicate whether
the numbers are based on a single year or averages over multiple years. The time-frame or year
used to calculate the water balance should be explained in the Final E!R.
As noted in the DEIR, comments on the NOP for the GWR project (including MCWD's NOP
comments) requested the ElR: (a) evaluate both the travel time and vo lume of water moved
between injection and extraction sites in order to determine what portion of injected water can be
safely extracted and when; (b) Confim1 with the State Water Resources Control Board (SWRCB),
Division of Drinking Water (formerly, California Depattment of Public Health) the required
residence time between injection and extraction for all proposed water sources prior to the
publication of the Ordft EIR; (c) Confirm the capacity of the Seaside Basin is sufficient, within
that predetermined residence time, for the injection of the Proposed Project purifi ed recycled
water; and (d) confirm witb the SWRCB, Division of Drinking Water (DOW) that the hori7..ontal
distance required between points of injection and extraction are adequate in the event those two
modes of operation are simultaneously occurring. (DEIR, p. 4.10-2.) While the DEIR
acknowledges the Final Groundwater Replcnisluncnt with Recycled Water Regulations
(''Grow1dwatcr Replenishment Regulations") went into effect Jw1e IS, 2014, it only provides a
generally description of the regulations in the DElR at pp. 4. 10-35 and 4.1 0-36. The DEIR's
analysis of Impact GW-6 (Operational Groundwater Quality: Seaside Basin) fai ls to discuss the
GW R Project's compliance with these regulations and ~imply concludes that based on an
assessment (included in Appendix D) that "the water quality results of the AWT Facility pilot plant
testing (using ozone, MF, and RO), the stabili7..Cd RO sample, information on the predicted
pcrfonnancc and water quality of the proposed full-scale AWT Facility based on other existing
groundwater replenislunent projects, and related research/studies ... the Proposed Project would
comply with . .. SWRCB Regulations (for groundwater replenishment), incl uding MCLs, NLs,
total organic carbon, and other numeric wuter quality-based requirements; and Central Coast Basin
Plan objectives .. .." The EIR should clarify how the project complies with the Groundwater

Final EIR
4-70
September 2015
H-41
H-42
H-43
H-44
H-45
June 4, 2015
Page 15
Replenishment Regulations and include mitigation ensuring compl iance with the Groundwater
Replenislunent Regulations.
On page 4.10-63, the DEIR references Figure 4.10-9 as showing wells in the CSil' area whose
production would be reduced or eliminated by delivering the additional crop irrigation water
produced by the Proposed Project. It is impossible to tell from Figure 4. I 0-9 where the production
or monitoring wells are located. A revised Figure should be included in the EIR where the location
of the wells are clearly marked. Notably, the current version of Figure 4.10-9 appears to show that
some of the CSIP production wells are within the portion of the 400-Foot Aquifer that is shown to
be seawater intruded based on Figure 2-7. On page 4. I 0-64, however, the DEIR indicates that all
of the CSJP wells are inland of the intrusion front in the 400-foot aquifer. A clear map is needed
to conftrm this information. In addition, historical and baseline information ofTDS and chloride
levels at the CSIP production and monitoring wells are needed to understand the environmental
setting and eval uate the Project's impact on the Salinas Val ley Groundwater Basin. MCWD
requests this information be provided in the Final EIR.
The DEIR analysis of Impact GW-3: Operational Groundwater Depletion and l-evels: Salinas
Valley Groundwater Basin concludes that the GWR Project would have a net beneficial impact
with respect to seawater intrusion and overall groundwater storage and levels in the Salinas Valley
Groundwater Basin. (DEIR, pp. 4.10-57- 4.10-64.) This conclusion is only suppotted ifMCWD's
rights to 1,727 AFY of recycled water (including 650 AFY of summer recycled water under the
2009 RUWAP MOU and MCWD separate right to 300 AFY of summer recycled water) arc fully
protected. If this is not the case, additional groundwater pumping in the Mari na and Ord portions
of the Salinas Valley Aqui fer will likely be necessary to support planned growth in these area as
discussed above. The DEIR does not address potential groundwater impacts in the Marina/Ord
p011ions of Salinas Valley Groundwater from additional groundwater pumping, therefore, the EIR
would be inadequate. The DEIR's analysis of Impact GW-5 - Operational Groundwater Quality:
Salinas Valley (pp. 4.1 0-65 - 4. 10-70) and its cumulative impacts ana.lysis (pp. 4. I 0-75- 4. I 0-78)
would be inadequate for these same reasons. Notably, the DEIR avoided any analysis of
cumulative groundwater impacts based on its conclusion that direct and indirect impacts of the
GWR Project would be beneficial (see pp. 4.10-65 - 4. I 0-70).
H-45
Con't
H-46
H-47
H-48
H-49
Chaptet 4.11 , Hydrology/Water Quality: Sutface Water

Mitigation Measure HS-4 states:
Rapid, imposed water-level fluctuations shall be avoided when operating the
Reclamation Ditch Diversion pumps to minimize erosion and fai lure of exposed (or
unvegetated), susceptible banks. This can be accompl ished by operating the pumps
at an appropriate flow rate, in conj unction with commenci ng operation of the pumps
only when suitable water levels or flow t'!lies are measured in the water body. Proper
control shall be implemented to ensure tbat mobilized sediment would not impair
downstream habitat values and to prevent ad verse in1pacts due to water/soil
interface adjacent to the Reclamation Di tch and Tembladero Slough.

Final EIR
4-71
September 2015
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MCWD Comment~ on GWR Project Draft EIR (SCHNo. 2013051094)

June 4, 2015
Page 16
(DEIR, p. 4.11-75.) The measure appears vague and unenforceable. The phrases "appropriate
flow rate" and "suitable water levels or flow rates" should be defined or tied to a quantifiable
performance standard.
Land Use, Agriculture, and For est Resources (Section 4.12)
The DEIR' s discussion of Impact LU-2: Operational Consistency with Plans, Policies, and
Regulations fails to address the Project's consistency with applicable plans, policies, and
regulations relating to groundwater resources and public services relating to water supply. (See
DEIR, pp. 4.12-37- 4.12-43.) As addressed above, ifMCWD's senior recycled water rights are
not protected, the GWR Project would conflict with the City of Marina's policy to minimize the
consumption of water for urban purposes and make maximum possible use of recycled water. The
OWR would also likewise conflict with the Fort Ord Reuse Plan if this was the case. The Final
ElR should confirm the Project is consistent with the plans, policies, and regulations of the City
of Marina and the Ord Community (e.g., Fort Ord Reuse Plan).
H-50
Con't
H-51
Noise and Vibration (Section 4.14)
The DEIR's Approach to Analysis states: "an exterior noise level that exceeds 70 dBA Leq during
the daytime is used as the threshold for substantial construction noise where the duration of
construction noise exceeds two weeks." (DEIR, p. 4.14-23.) What is the basis for selecting two
weeks to measure whether a noise impact is significant? Is there any support for this time frame?
Some of the noise impacts analyses rely on that time frame to conclude impacts would be less than
significant even though the construction noise level would exceed the threshold (e.g., discussion
of RUWAP Alignment construction on page 4.14 -34, discussion of Coastal Alignment
construction on page 4.14-36, discussion of Monterey Pipeline construction on pages 4.14-41 to
4.1 4-42) because constmction would affect sensitive receptors for less than two weeks. Without
support for the two-week time frame, the DEIR may be avoiding feasible mitigation measures that
could reduce construction noise. Notably, the RUWAP EIR determined that construction noise
impacts are potentially significant and includes the following noise mitigation for pipeline
construction:
4.1 1-Rl
The construction contractor shall limit exterior construction related activities

to the hours between 7:00 a.m. and 7:00 p.m. on weekdays and Saturdays,
and between 10:00 a.m. and 7:00p.m. on Sundays and hol idays.
4.11-R2
The contractor shall locate all stationary noise-generating equipment as far

as possible from nearby noise-sensitive receptors. Where possible, noisegenerating equipment shall be shielded from nearby noise-sensitive
receptors by noise-attenuating buffers. Stationary noise sources located 500
feet from noise-sensitive receptors shall be equipped with noise reducing
engine housings. Portable acoustic barriers shall be placed around noisegenerating equipment that is located less than 200 feet from noise- sensitive
receptors.

Final EIR
4-72
September 2015
H-52
H-53
H-54
June4, 2015
Page 17
4.1l-R3
The contractor shall assure that constmction equipment powered by gasoline

or diesel engines have sound control devices at least as effective as those
provided by the original equipment manufacturer (OEM). No equipment
shall be permitted to have an unmuffied exhaust.
4.11-R4
The contractor shall assure that noise-generating mobile equipment and

machinery arc shut-off when not in use.
4.llR5
Residences within 500 feet of a construction area shall be notified of the

construction schedule in writing, prior to construction. The Project Applicant
and contractor shal l designate a noise disturbance coordinator who would be
responsible for responding to complaints regarding construction noise. The
coordinator shall determine the cause of the complaint and ensure that
reasonable measures are implemented to correct the problem. A contact
number for the noise disturbance coordinator shall be conspicuously placed
on construction site fences and written into the construction notification
schedule sent to nearby residences.
Mitigation measure R-1 was subsequently modified to allow some nighttime construction along
specific roadways to reduce traffic impacts from construction where sensitive noise receptors arc
located an adequate distance (at least 1/4 mi le) from the construction activities and where approved
by the relevant local jurisdiction through their encroacluncnt pem1it process in an addendum to the
H-54
Con't
H-55
EIR:
4.11-R I: The construction contractor shall limit exterior construction related activities to the hours
of re:;trictlon consjstent with I he poise ordinance Q( and encroachment peqnjts js~ued. by tbfS
. -. n-week-EI~a~lifda-ys,and
releyapt land use jurjsdictions 9etwee
eetweea Hl:()() a.m. al'!a 7:()() p.m. 91'1 S~o~Raays aREI helieays. lfalternatjve traffic control measures
are unavailable and jf approved bY staff of the relevant City jdemjfied below thrQU&lLtbeir
cncrpacbmept pennit nighttitne construct jon p>ay be conducted for the following segtnents of road
(as jdepljfied jp rhe Higg igs Assocjares letter dated October 17 2006) groyided that sensitiye
7
receptors (jn this case refiidencs;. nqrsjpg homes. agd bote!sfmotelsl are located aq adegyate
distance from constructjon actjyjties (as determined by the relevant land yse jurjsdiction)~
Reseryation Road between Seacrest Ayenue and Crescent Ayenue [Marjna - preferred
alignment]
Frcmogt Street between Kimball Ayegue and Ajrport Bouleyard [easjde - preferred
aliggmegr}
Del Monte Ayenue between Park Ayenue and Camino Aguajito (Monterey- alternatjye
alignmentl
Jlel Monte Avenue. hetweep Camino Amwiitg and Figueroa Street [Monterey
preferred
alignmeptl

Final EIR
4-73
September 2015
H-56
MCWD Comments on GWRProject Draft EIR (SCH No. 2013051094)
Jw1e 4, 20 15
Page 18
If the RUWAP alignment is selected for the GWR Project, the foregoing mitigation should be
included in the EIR . The DEIR should also consider whether similar nighttime work is needed to
address the GWR Projects' traffic impacts through consultation with affected local jurisdictions.
As nighttime construction is not currently proposed as part of the GWR Project for the RUWAP
pipeline alternative, it does not appear such consultation has occurred to date.
Public Services, Utilities, and R ecreation (Section 4.16)
The DEIR's conclusion for Impact PS-4 (operational impacts on public services) appears to have
been cut and pasted without change from Impact PS-I. As a result, it does not address the OWR
Project's potential operational impacts to public services. (See DETR, p 4. 16-17.) Moreover, the
conelusory discussion of Impact PS-4 fails to mention, much Jess disclose, the GWR Project's
potential impacts to the public services of water supplies if MCWD's full al lotment of recycled
water is not provided. (See DETR, pp. 4.16-16 4.16-17.) lfMCWD 's senior recycled water rights
are not protected, MCWD would likely be required to cons!Iuct new facilities (or alter ex isting
facilities) to meet its contractual obligations to FORA as discussed above. Therefore, this potential
impact must be addressed in the EJR unless MRWPCA can demonstrate it can and will provide
MCWD's full allotment of recycled water.
H-57
H-58
Water S upply (Sect ion 4.18)
The DEfR incorrectly suggests that all of MCWD's water supply currently comes from
groundwater wells located in the 900-foot-deep aquifer of lhe Salinas Valley Groundwater Basin.
(DEIR, p. 4.18-8.) Historically, MCWD supplied its Marina service area with water from wells
screened in the 180-Foot and 400-Foot aquifers. Between 1960 and 1992, some of those wells
indicated varying degrees of seawater intrusion and were replaced, fust moving from the 180-Foot
aquifer to the 400-Foot aquifer, and later moving to the Deep Aquifer. The District currently
operates 4 wells in the Deep Aquifer Wells 10, 11 , 12 and 34. (See MCWD Service Area Map
for locations of these wel ls, attached as Exhibit " E" to the letter.) M CWD also operate.~ 4 wells
that draw from the 180-Foot and 400-Foot Aqu ifers - Wells 29, 30, 3 I , and 35. (See MCWD
Service Area Map for locations of these wells, attached as Exhibit "E" to the letter.
Table 4.18.5 (DETR, p. l.l8-19) in Section 4.18.3.4 (Memorandum of Understanding and Legal
Agreements) must be updated to acknowledge the 2009 RUW AP MOU attached as Exhibit "B"
and 2009 Three-Party MOU attached as Exhibit "C'' This section should also acknowledge under
the "Memorandum of Understanding Regarding Source Waters and Water Recycling (MOU)
(October 2014)" on tltis same page that MCWD's recycled water right entitlements may be made
contractually available by MCWD to another Party and may be made available to MCWRA for
the CSIP if not uti lized by MCWD, or its assignee, in any given year. (See DEIR Appendix B
including 2014 MOU, p. 2)
Section 4.l8.2.2's discussion of Municipal Wastewater Collection Systems suggests that MCWD
only maintains and operates wastewater collection systems in the former Fort Ord community.
(DEIR, pp. 4.18-11 and 4.18-12) The EIR should clarify that MCWD's service area includes both

Final EIR
4-74
September 2015
H-59
H-60
H-61
MCW D Comments on GWR Project Draft EIR (SCH No. 2013051094)

June 4, 2015
Page 19
the City of Marina and Ord Commw1ity and that MCWD is responsible for maintaining its service
area's sewer system, which includes 20 lift stations and II 0 miles of pipeline.
H-61
Con't
'I11e DEIR's Plans and Policies Consistency Analysis for Water Supply and Wastewater must also
be clarified if implementation of the Project could result in MCWD not being provided its full
allotment of recycled water. Like OE!R Section 4.10, this section also states that the Project is
consistent with City of Marina Policy 3.3 (p. 4.1 8- 17 [Table 4.18-4]). Again, assuming all of
MCWO's recycled water rights are protected, MCWD agrees the GWR Proj ect is consistent with
this policy. The Final EIR should confinn whether the Project is consistent with the City' s pol icy
here also. For the reasons noted above, this Section should also confinn the GWR Project is
consistent with the F01t Ord Reuse Plan.
H-62
In the last paragraph of 4. 18-33, the DEIR states that MRWPCA will need to obtain contractual
water rights from the applicable local agencies for urban runoff water. The project description
should be updated to include these water rights agreements as indicated in MCWD's comments on
that chapter.
H-63
As addressed in Section I of this letter, the DEIR's analysis of the GWR's Project's potential
impacts to MCWD 's senior rights to recycled water does not appear to include the 2009 RUWAP
MOU and the 2009 Three-Pmty MOU. For the same reasons outl ined in Section !, the "Cumul ative
Impact Conclusion" must be updated to reflect consideration ofthese MOUs and confirm adequate
supplies will be available to provide 950 AFY of sun1mer water plus 477 AFY water during the
other months. Without this recycled water, the MCWD RUWAP would not be feasible, which
would likely result in potentially severe adverse impacts for recycled water supplies needed for
proposed and future developments in the Ord Community as described in Section 1.8 above. It
wou ld also likely result in potentially severe adverse impacts to groundwater and likely force
MCWO to construct new facilities (or alter existing facilities) to meet its contracrual obligations
to FORA as discussed above. This would result in cumulative impacts that would need to be
addressed in the DElR under CEQA.
H-64
E. Alternatives (Chapter 5)
The DEIR concludes the Reduced Seaside Basin Replenislllllcnt Alternative will have "nearly the
same environmental impacts as the Proposed Project, since all faci lities are assumed to be
constructed under this alternative, eveo though there wou ld be a reduction of water provided to the
Seaside Groundwater Basi n." (DElR, p. 6-24.) Please confirm this conclusion is accurate for the
GWR Project's potential impacts to water supplies in light of the above comments.
H-65
If the MRWPCA cannot confinn adequate suppl ies will be available with implementation of the
GWR Project to meet all MCWD's senior recycled water rights (including provide 950 AFY of
summer water plus 477 AFY water during the other months for the Ord Community as explained
in Section LA above), the EIR must be revised to include an alternative that would provide
MCWD's full allotment of recycled water.
H-66

Final EIR
4-75
September 2015
MCWD Comments on GW R Project Dn1ft El R (SCH No. 2013051 094)

June 4, 2015
Page20
Finally, the DEIR's conclusion in Section 6.3.2.3 (Alternatives for Product Water Conveyance)
that the analysis of the potential impacts between the two alternative Product Water Conveyance
Systems (RUWAP alignment and Coastal aligJunent) shows that they are very similar does not
actually detern1ine whether either alternative is enviromnentally superior. li appears, however,
that the RUW AP alignment is the environmentally superior alternative based on the EIR 's
analysis. As the DEIR states:
H-66
Con't
.. .the primary difference in impacts is in construction and

operational impacts to riparian habitat and federally protected
wetlands as defined by Section 404 of the Clean Water Act;
specifically, the impacts of the RUWAP alignment option would be
less than significant while the Coastal alignment option would be
significant, but reduced to less than significant with mitigation in
this EIR (specifically, Mitigation Measures BT-2, and BT-6). The
Coastal alignment option of the Product Water Conveyance pipeline
could impact Locke Paddon Lake that contains wetlands and
riparian habitat in the City of Marina, and the RUWAP alignment
would not affect those habitats.
(DEIR, p. 6-34.) Therefore, it would appear to be beyond dispute that the RUWAP alignment is
the environmentally superior to the Coastal alignment alternative. (See also MCWO's comment
on Mitigation Measures BT-2 above). Given this conclusion, CEQA would require selection of
the RUWAP aligrm1ent alternative if it is feasible. As noted above, MCWD looks forward to
working MRWPCA assess whether a mutually beneficial use of the RUWAP pipeline or RUWAP
pipeline alignment is feasible.
* * *
MCWO hope these conunents assist MRWPCA in its evaluation of the DElR's compliance with
CEQA. MCWD continues to look forward to working with MR WPCA in advancing regional
goals through implementation of the GWR Project.
;- "; E
s
~ --...__,
Ho\ ard GustafSOn, Ptesident
Board of Directors

Final EIR
4-76
September 2015
H-67
Letter H Attachments
EXHIBIT "A"
BEFORE TH E PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA
In the Matter of" the Application of CaliforniaAmerican Water Company (U 210 W) for
Apt>roval of the Monterey Peninsula Water
Supply Project and Authorization to Recover
All Present and Future Costs in Rates
Application No. A.I2-04-0 19

(Fi led Apri123, 2012)
REI'LY BIUEFOFTHE
MONTER EY REGIONAL WAT ER POLLUTION CONTROL AGENCY
REGARDING WATER RIGHTS

FOR A GRO UNOWATER REPLENI SHME NT .P ROJECT
Martha H. Lcnnihan
LENNI HAN LAW
A Professional Corpoation
166 1 Garden l lighway, Suite 102
Sacramento, CA 95833
Date: July 25, 2012

Final EIR
4-77
September 2015
TABLE OF CONTENTS
Page
I.
INTRODUCTION ................ .. ... ... .............. .. .......... ........... .... .
II.
FURTil ER RESPONSES AND CLARI FICATION........... ........... .....
A. No Infringement on MCWD o r MCWRA Rights ..... .... ....... .. ........
B. MCWD Approval is Not Required Under the Three- Way MOU

or Otherwise......... .. .. ......... .... ..... .. .. ... .......... ............
C. Usc orthe SVRP....... ... ....... .. ........... .. ......... .. ... . ...... .. .........
Ill.
OUTFALL AGREEMENT....... ......... ............. .................... ... .....
IV.
CONCLUSfON........ .... ........ .. .......... ............ ............ ... ....... .....
-i-

Final EIR
4-78
September 2015
BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA
In the Matter of the Appl ication of Californ iaAmerican Water Compa ny (U 210 W) for
Approval of the Monterey Peninsula Water
Supply Project and A uthorization to Recover
All Present and Future Costs in Rates
Appl ication No. A.12-04-0 19

(Filed April23, 2012)
REPLY BIUEFOFTHE
MONTEREY REGI ONAL WATER POLLUTION CONTROL AGENCY
REGAR.01NG WATER R IGHTS
FOR A GRO UN DWATER REPLENISHMENT PROJECT
I.
INTRODUCTION
The Monterey Regiona l Water Pollution Control Agency (MRWPCA) files this Reply Brief in
response to the comments of others in their opening briefs on the water rights for a groundwater
replenishment (OWR) project.
MR WPCA 's Opening Brief provided a substantive evaluation of the water rights, including a
quantitative analysis. Responses to the vast maj ority of the comments made in the opening briefs of
others a re already contained in MRWPCA 's Opening Brief (which the others had not yet had the
opportunity to see d ue to the concurrent tiling.) To the extent there may now be substantive responses

Final EIR
4-79
September 2015
to MR WI'CA 's Opening l:lrief in the reply briefs of others, MR WPCA wil l need the oppot1unity to
respond to those reply briefs.
In addition to the content provided in MRWPCA 's Open ing Brief, below we provide responses
on additional issues raised in the open ing briefs of others.
II.
FURTHER RESPONSES AN D CLARIFI CATION

A.
No Infringement on MCWO or MCWRA
Righl~.
MRWPCA proposes to usc water for
the GWR project in a manner that docs not incur on the water rights of cithetthc MCWD or the
MCWRA. During the Initial Term, the bulk of the GWR water- 2,987 AFY or almost 70% of project
need- is proposed to be provided from the remainder of MR WPCA's 3,900 AFY right, aller deducting
the amount MR WPCA comm itted to the MCWD project referred to as the RUWAP 1 There is adequate
infl uent to satisfy both the MCWD and MRWPCA rights. Scction3 .03 (d) of the 1992 Agreement, as
amended, makes it c lear that MRWPCA 's commitment of its incoming wastewater flows to the SVRP
for the CSIP. up to 29.6 million gallons per day, excludes flows to which MCWD and MRWPCA are
entitled.
For a 3,500 AFY GW R project, a n additional approx imately 1,340 AFY would need to come
from unused water during the twenty-one years of the Initial Term when the project is anticipated to be
n,is is the amount for a 1,485 AFY RUWAP. MCWU currently proposes to proceed with either a 780 i\FY RUIVAP
(see MCWD 20 10 Urban Water Management Plan, Table 4.4), or a I ,000 i\FY RUWAP (sec Coastal Watc,-l'rojeet FEIR,
Table 5.2), therefore only a pU>tion of the MRWPCA commitment will be needed.

Final EIR
4-80
September 2015
in operation? MR WPCA proposes to use unused flows into the Regional Treatment Plant during a time
when (I) the CSIP demand is fully satisfied, and (2) MCWD's finn right is untouched (keeping in mind
that MCWD docs not have use for more than a fraction o f that fim1 ight). MCWD is capped at 300 AF
d uring the six month period fro m Apri l through September. MCWD can take the amount it defe.rred
ta king during these months during the remaining six months of October through March. This means that
MCWD has the most supply during months when there is typical ly far less demand. MRWI'CA's use of
SU11Jius water during the deepest of these winter months, targeted at November through February, is
feasible due to the storage provided by the Seaside Groundwater Basin. This design harms neither of the
other two agencies. Jt has the potential to significantly benefit the Monterey Peninsu la community
members.
During the Extended Term, no unused water would be required . In this context, opposition to
ncar tenn use of otherwise unused surplus winter water for a GWR project serves no purpose.
B.
MCWD Approval is Not Required Under the Three- Way MOU or Otherwise. In its
O pening BricfMRWPCA set forth a conservative analysis of water avai labi lity, which assumes that all
ofMCWO's water is used by MCW D, even though there is no evidence that th is will occur, particularly
during the remaining approximately twenty-one years of the Initial Term . The ana lytical approach
MRWI'CA has employed addresses any legitimate concern ofMCWD.
It merits note that MRWPCA has already committed the majority of its most valuable supply to
the MCWD RUWAP, in the form of650 AF of"summer" water that can be used during the period of
' Or a larger portion could easily come from the winter surplus, the lowest amount of which is 3,775 AI' (MRWPCA
Opening Brief, page I I.)

Final EIR
4-81
September 2015
May through August. MRWPCA's Opening Brief analysis ftu1hcr assumes that MR WPCA will also
provide most of the water needed for RUWAP during April and September, another significant
contribution to MCWD. Without this MRWPCA water, tl1e MCWD RUWAP would not be feasible. 3
In add ition to its own Annexation Agreement water, MCWD now can use the most valuable element of
MRWPCA 's water right. In spite of all this, MCWD now vehemently objects to MRWPCA's use of the
water remaini ng to it for the benefit of other members of the region. Th is is true even though the use is
proposed to be undertaken in a manner fully respecting MCWD's Annexation Agreement amount, only
a portion of which can actua lly be used by MCWD; and in spite of the severe need on the Monterey
Peninsula for that water. This is contrary to the publ ic interest, and connicts with the Constitutional
requirement to maximize the reasonable and beneficial uses of water.
MCWD does not have approval rights over any MR WPCA (or MCWRA) usc of water pursuant
to the 2009 Three-Way MOU. MCWD asserts that:
" ... [MCWD]'s 2009 Three-Way Recycled MOU4 with MRWPCA and MCWRA
governs the terms and conditions under which replenishment and recycling projects may
be undertaken with recycled water provided by MR WPCA, and the MOU requires
MCWD's approval for any such project or project components." (MCWD Opening
Brief, page 14.)
To !he contrary, this MOU is now moot. Even if it were not, MCWD rnischamcterizes the MOU, as set
forU1 below.
Ill/
' Theoretically, MCWD could undertake !he RUWAP using winter water if it constructed sufficient storage. However, this is
very expensive infrastructure with some considerable operational challenges.
The MOU is actually entitled "Monterey Regional Water Supply Program Recycled Water 'nlrce-Way Memorandum of
Understand ins:~ entered ifltO on June 1. 2009. A copy is attached hereto as Exhibit A.
4

Final EIR
4-82
September 2015
The 2009 Three-Way MOU recitals make clear that the predicate lor the MOU was the Regional
Water Supply Program (also known as the Regionall'rojcct or Regional Desali nation Project, or RDr.s-,,
and that the MOU focus wou ld be on planning-level activities relating to the RDP. Those recitals state
in relevant part:
"WHEREAS, the Regional Water Supply Program is an alternative analyzed in Cal ifbmiaAmerican Water Companys (Cal-Am) Coastal Water Project (CWP) Draft Environmental
Impact Report (DEIR), and has recycled water elements identified for urban reuse to benefit
Cities on the Monterey Peninsula, the northern communities of Monterey County, agricultura l
interests and the Un ited States Anny; and,
WHEREAS, the recycled water elements of the Regional Water Supply Progr.tm appear to be
cost effective for ratepayers and to reduce recycled water cost to the agricultural community;
and,
WHEREAS, the Participating Entities believe it is necessary and appropriate and that there is an
urgency to review and analyze the technical, managerial, financial and environmental feasibi lity
of the recycled water clements for a Final Environmental Impact Report for the Regional Water
Supply Program through the CWP process (FEIR); and,
WHEREAS, evaluation of the feasibil ity of the Regional Water Supply Pogam recycled water
elements requires coordination and collaboration between the Participating Entities; and,
WHEREAS, the Participating Entities signatory to this MOU desire to cooperatively engage in
recycled water supply planning and jointly analyze proposed project elements ...."
The MOU is specific that its very purpose is to eview and analyze "recycled water elements for
a Final Environmental Impact Report for the Regional Water Supply Program through the CWP
Process. . . " and that "ev<duation ofthe feasibility ofthe Regional Water Supply Program recycled
water elements requires coordination and collaboration between the Participating Entities. ... " The
MOU is dated after the Regiona l Water Supply Program DEIR was completed in January 2009. The
' The Regional Water Supply Program is also known as the Regional Project, or the RDP. See auached Memorandum of
Understanding Regarding Cooperative Planning and Joint Analysis ror a Monterey Regional Water Supply Program," entered
into on June I, 2009, rourth recital. A copy is attached hereto as Exhibit B.
5

Final EIR
4-83
September 2015
Final EIR was completed in October 2009. This process, referred to as the CWP Process in the MOU,
has been terminated . (CPUC Decision 12-07-008, July I 8, 2012, regard ing Application 04-09-0 19.)
The basis for the MOU no longer ex ists. The MOU can no longer serve its intended purpose,
and is without further force and etl"ect.6 This is reinforced by the fact that one of the three "Participating
Entities" is opposing rather than pmticipating in the current proposal, and is the only entity insisting that
the MOU has ongoing vitality.
Assuming solely for argument's sake that the MOU retains some viability, MCWD offers no
support for its position that the MOU "governs" terms and conditions of projects, and that MCWD
"approval" is required for the o ther parties' recycled water projects. The MOU was actually a planning
level MOU, to coordinate the parties' recycled water efforts in the context of the RDP and the Coastal
Water Project. MCWD's interpretation of the MOU to entitle MCWD to control, and have veto power
over', the other two parties' projects would be an invalid and clearly unintended delegation of the
parties' rights held per those existing agreements.
The MOU was not intended to change any existing agreements. The existing agreements speak
for themselves as to the rights, obl igations, lim itations, and responsibilities of the parties. Those
Whore an assumption ne<:cssary to a contract no longer exists through no fault of a party seeking to avoid performance,
three closely related dcfcoses wortc to excuse perrormance: an implied condition of the contract not met~ pcri'onnancc is
impossible; purpose oft he contract has been frustrated by an unanticipated supervening, circumstance to tJ1c extent lhat value
of performance is substantially destroyed. llabitat Tru$tfor Wildlife, Inc. v. City (2009} 175 Cai.App.4~ 1306, 1335-1336; I.a
Cumbre Golfand Coullfry Club v. Santa Barbara Hotel Co. ( 1928) 205 Cal. 422. 425-426; H. Hackfold & Co. 1./d v. C<IStlc
(1921) 186 Cal. 53,57-58.
' Jn its May 25, 20 12 filing entitled uMarina Coast Water District's Response in OpJ>OSition to the Motion of CaliiOmiaAmerican Water Company (U 210 W) to Deny Marina Coast Water District Party Status," at page 7, footnote 7, MCWD
states, "MCWD has an equal seat at the table in developing analytical criteria under the MOU." MCWD thus acknowledges
that the criteria need to be developed, that they are ''analytical" criteria, and that MCWD has an equal role. In MCWD's
present assertion of unilateral control MCWD has ramped up the "equal sea~' to the status of first among equals.

Final EIR
4-84
September 2015
agreements govern, and the MOU is explicit that it docs not amend them. 8 Projects must be measured
by their consistency with those agreements and other applicable law. If the committee or members
thereof were to attempt something more, such as assertion of the contro l MCWD claims, MRWPCA
wou ld have no choice but to terminate its participation in MOU process.
TI1ere is no suppot for MCWD's position. The MOU is null and void.
C.
Use of the SVRP. Some pa1ties have expressed concern regard ing MRWPCA 's use of
the SY KP for the GWR project. MRWPCA does not propose to use the SYRP for the GWR project. A
different treatment train, to be provided at a new advance treatment facility, wou ld be used for the GWR
project, as set fmth in our Opening Brief. This produces water of a quality e ligible for injection into the
Seaside Basin .
Ill.
OUTFALL AGREEMENT
MCWD asserts that it has priority rights to the full amount of capacity provided in the outfall
agreement for the RDP. TI1e issues regarding that outfall agreement are addressed in the Cal Am
Opening Brief.
w.
CONC LUSION
The GWR project has the potential to contribute significantly to a solution for the Monterey
Penin su la. To the extent reasonable, MRWPCA is will ing to put its resources to work in furtherance of
See 7"' Whereas clause in Exhibit A.

7

Final EIR
4-85
September 2015
a successful project. Those resources are the bulk of what is needed, but not all that is needed. Whether
the others whose collaboration is needed wi ll collaborate is yet to be seen. If they do, a GWR project
should be eminently feasible.
Dated: July 25,2012
Respectfully submitted,
lsi Martha 11. Lennihan

Manha J-1. Lennihan
LENN.IHAN LAW
A Professional Corporation
Attnmey tor Monterey Regional Water Pollution
Control Agency

Final EIR
4-86
September 2015
A lTACHMENTS
Exhibit A - Monterey Regional Water Supply Program Recycled Water Three- Way
Memorandum of Understanding
Exhibit 13 - Memorandum of Understanding Regarding Cooperative Planning and Joint Analysis
for a Monterey Regional Water Supply Program

Final EIR
4-87
September 2015
All coJTespondence, plead ings, orders and notices in this proceed ing should be dircclCd to the following:
Martha H. Lcnnihan
LENNIHAN LAW
1661 Garden Highway, Ste I02
Sacramento, California 95833
Telephone: (916) 646-4460
Email: mlennihnn@lennihan.net
Robert R. Wellington
George C. Thacher
WELLINGTON LAW OFFICES
857 Cass Street, SuiteD
Monterey, Californ ia 93940
Telephone: (83 1) 373-8733
Email: auys@wcllingtonlaw.com
Keith Israel
General Manager
Monterey l{egional Water Pollution Control Agency
5 Harris Court, Bldg. D
Telephone: (83 1) 372-3367
Email: keith@mrwpca.com
10

Final EIR
4-88
September 2015
EXHIBIT A

Final EIR
4-89
September 2015
Monterey Regional Water Supply Program

Recycled Water Three-Way
This Memorandum of Understanding (hereinafter referred to as "MOU") is made and entered
into as of the first day of .June ?OOQ. among the Monterey Regional Water Pollution Control
Agency (MRWPCA), Marina Coast Water District (MCWD), and Monterey County Water
Resources Agency (MCWRA), referred to collectively in this MOU as the "Participating
Entities."
WHEREAS, the Regional Water Supply Program is an alternative analyzed in CaliforniaAmerican Water Company's (Cal-Am) Coastal Water Project (CWP) Draft EnviroMlental
Cities on the Monterey Peninsula, the northern communities of Monterey County, agricultural
interests and the United States Army; and,
WHEREAS, the recycled water elements of the Regional Water Supply Program appear to be
and,
WH EREAS, the Participating Entities believe it is necessary and appropriate and that there is an
urgency to review and analyze the technical, managerial, financial and enviroMlental feasibility
of the recycled water elements for a Final Environmental Impact Report for the Regional Water
WHEREAS, evaluation of the feasibility of the Regional Water Supply Program recycled water
W HE REAS, the Participating Entities signatory to this MOU desire to cooperatively engage in
recycled water supply planning and jointly analyze proposed project elements; and,
WHEREAS, Participating Entities have previously entered into bi-lateral agreements with each
other concerning recycled water; and,
W HEREAS, Participating Entities recognize a need to memorialize a COfMlon interpretation of
their existing agreements without changing any existing agreements, to facilitate analyzing the
feasibility of proposed recycled water projects.
WHEREAS, this MOU is intended as a preliminary agreement for plaruting-level activities
relating to the Regional Water Supply Program. This Agreement is not intended to and shall not
be interpreted to constitute, directly or indirectly, a commitment by the Parties to undertake any
project or action, including but not limited to a project or action involving any element of the
Regional Water Supply Program. The Parties acknowledge and agree that no commitment to
undertake any project or action may occur until enviroMtental review bas been completed in
accordance with CEQA. The Parties specifically intend to avoid any commitments or actions
that would, in light of all surrounding circumstances, comm it the Parties as a practical matter to
any project or project element prior to the completion of environmental analysis in accordance
withCEQA.
NOW, THEREFORE, BE IT RESOLVED, that for purposes of evaluating the feasibility of
urban recycled water project elements of the Regional Water Supply Program for the FEIR, the
Participating Entities will use and encourage others to use the recycled water demand schedules
for irrigation season (typically March through October) recycled water supply and for recycled

Final EIR
4-90
September 2015
water supply during the non-irrigation season (typically November through February as shown
on Exhibit A and the schedule water for urban reuse as shown on Exhibit B (exclusive of the
MCWD 300 acft irrigation season allocation); and,
BE IT FURTHER RESOLVED, that the recycled water elements of the Regional Water
Supply Program shall be consistent with the Regional Urban Water Augmentation Project
Environmental Impact Report certified by MCWD on October 27, 2004, Addendum No. Ito the
RUWAP EIR certified on November 15,2006, and Addendum No.2 certified on February 14,
2007; and,
BE IT FURTHER RESOLVED, that in eval uating the feasibility of future urban recycled
water projects, the Participating Entities shall use and shall encourage others to use the concept
that in addition to the demand schedules shown on Exhibits A and B each of the Participating
Entities shall be able to make use of the available recycled water (approximately 6,500 afy
currently and up to approximately I 0,000 afy at plant capacity) from the remainder of the
irrigation and non-irrigation season available recycled water consistent with all other agreements
associated with recycled water allocations made between MCWD, MCWRA and MRWPCA.
Preference shall be given in analysis of furure projects for expansion of urban reuse to include
groundwater replenishment projects, additional irrigation project storage, or other urban reuse
projects. So long as non-irrigation season water is not used for urban reuse, then MCWRA may
plan and analyze the feasibility of using such water to develop additional irrigation projects
including storage for expansion of the existing Castroville Seawater Intrusion Project and other
prospective agricultural irrigation projects; and,
BE IT FURTHER RESOLVED, that for planning and feasibility analysis, each proposed
project that would use recycled water not allocated in schedules shown on Exhibits A and B shall
be required to satisfy criteria jointly developed by a committee consisting of the Board Chair and
General Manager from each Participating Entity that would include but not be limited to 1)
confirming customers for the recycled water, 2) having a completed project description, 3)
having completed environmental review under CEQA and 4) having an approved financing
mechanism for the prospective project. Every two years the joint committee will review and
recommend priorities and schedules for feasibility analysis; and,
BE IT FURTHER RESOLVED, that the payment of costs shall be consistent with Exhibit C
(actual costs will be paid by the customers who use recycled water whether MCWD or
MRWPCA) with the clarification that all infrastructure debt service paid prior to the date
recycled water is delivered for prospective projects described above will also be subject to the
same provisions for ongoing debt service payments identified in sections 3 and 4, of debt service
paid by MCWRA for the Salinas Valley Reclamation Project bridge financing. The Committee,
as referenced above, will review and clarify these costs to assure equity between all parties; and,
The Effective date shall be the date this MOU is last executed by any of the Parties.
Dated: _
_.Ctw/...,.1:..
8_
__,, 2009

Final EIR
4-91
September 2015
Dated: -~1j..,.UL.;o
::o___, 2009
tie]
USTAFSON, PRESIDENT
Dated:
7/IO
,2009

Agency
APPROVED AS TO FORM AND CONTENT

CHARLES MCKEE, Ge

Final EIR
al Counsel, Monterey County Water Resources Agency
4-92
September 2015
E XHIBIT A
MCWRA OEMANO SCHEDULE
Jt.l . PLANT
MONTH
WASTEWATER AVAILABLE
FOR RECYCLING
AT PLANT CAPACITY
(IN AC:~ FEET)
MCWRA'S DEMAND
SCHEDULE FOR RECYCLED
WATER
lt. I\J IIt.~y
~~--------+---~=----1----~~--~
~c~~~
~--------4-------~~------4-------~~w~----~
oc
~
10
1,650
E( ~
l ,4!i0
340
.!,370
250
T01 ~==~-----r----~
29,~~
0 ---+----=
t19~,
450 --~
I.
Souru: (MRWPCAJMC'\VRA - '-'16.192. d1ibt1 8)
2.
t xctprfon for frrication s.ttson sbown In txhlblfs B

Final EIR
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September 2015
EXHIBIT B
SEASONAL CAP ON URBAN
TERTIARY TREATED WASTE WATER ALLOCATION
MONTH
MAY
JUNE
JULY
AUGUST
TYPICAL MONTHLY
SEASONAL SPREAO
{AF)
163
202
218
183
CUMULATIVE SEASONAL
ALLOCATION
{AF)
766 AF
ExCUJSIW: OP' MCWD 300 AF ALLOCAT10N.

EXHIBrT 8 IS THE DESIGN NUMBER. SEASONAL VARIATION MAY
INCLUDE.
tt"
VARIANCii:
REV. 12120/ 01

Final EIR
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September 2015
EXHIBIT C
CALCULATION OF PAYMENTS FOR URBAN RECYCLED WATER

PURSUANT TO THIS MOO
Urban Recycled Water customers (URWC) sha.ll pay the Actual Costs of tertiary treated water to which it
takes delivery for its use. The Actual Costs will be calculated from the cost components which comprise
MRWPCA's exlstlng budget and actual spreadsheet model(s) for the annual SVRP and CSIP costs.
The four cost elements that comprise the Actual Costs will be computed as follows:
~~
SVRP O&M Costs: The SVRP O&M budget will be calculated based on the Total Tertiary
Treated Water Production needed to serve both the CSIP and M&l uses of tertiary treated
water. The amount to be paid by URWC will be computed using the formula below, in Which:
A= Total Tertiary Treated Water Production, AFY
B =Tertiary Treated Water Production delivered to URWC for URWC use, AFY
C=Total O&M Expenditures from the SVRP O&M budget, exdudlng debt service
D= Amount to be paid by URWC
D=_~xc
Supplemental Well Pumping Cost: The amount to be paid by URWC will be computed as
indicated In Section 2.G. of Amendment No. 3 of the Agreement between MRWPCA and
MCWRA.
S = Amount to be paid by URWC
PI
SWRCB loan Contract Debt Service: The amount to be paid by URWC will be computed
using the formula below, in which:
B= Tertiary Treated Water Production delivered to URWC for Its use, AFY
E= SVRP SWRCB loan Debt Service
F =Amount to be paid by URWC
F=
~XE
A
~~
Bureau loan Contract Debt Service: The amount to be paid by URWC will be computed
B =Tertiary Treated Water Production delivered to URWC for Its use, AFY
G = SVRP Bureau loan Debt Service, computed pursuant to Article 9 (b) (1) and 9 (c) of
Bureau loan Contract
H =Additional interest charged by the Bureau for the Bureau loan on the SVRP pursuant to
Article 9 (b) (2) of Bureau loan Contract
I =Amount to be paid by URWC
I=
~XG+H

Final EIR
4-95
September 2015
EXIIIBIT B

Final EIR
4-96
September 2015
MEMORANDUM OF UNDERSTANDING
REGARDI NG
COOPERATIVE PLANNING AND JOINT ANALYSIS
FORA
MONTEREY REGIONAL WATER SUPPLY PROGRAM
This Memorandum of Understanding ("MOU") is made and entered into as of
.June 1 .
, 2009, by and between the Monterey Regional Water Pollution Control
Agency ("MRWPCA"), Marina Coast Water District ("MCWD"), and Monterey County Water
Resources Agency ("MCWRA") (collectively, the "Parties").
RECITALS
WHEREAS, MCWRA is the lead agency and MRWPCA and MCWD are responsible
agencies for adopting this planning MOU; and
WHEREAS, the California Public Utilities Commission ("CPUC") is presently
considering a proposal from California American Water Company to construct the Coastal Water
Project ("CWP"), and a Draft Environmental Impact Report ("DEIR") has been prepared for
that project and is now under consideration by the CPUC for preparation and certification of a
Final Environmental Impact Report ("FEIR"); and,
WHEREAS, the CPUC is currently conducting two parallel proceedings for water supply
in Monterey County, an environmental impact report process and a rate proceeding (CPUC
proceeding number A.04-09-0 19 ("Proceeding")), and the Parties believe that the establishment
of a planning framework in accordance with this MOU will facilitate the resolution of issues now
pending before the CPUC; and
WHEREAS, the Monterey Regional Water Supply Project ("Regional Project,'~ has
been identified in the DEIR as an alternative to the CWP, with components that may benefit
cities on the Monterey Peninsula, the communities of North Monterey County; agricultural
interests in North Monterey County, and the United States Army; and
WHEREAS, the Parties believe that the Regional Project has potential for the most
benefit, least cost and least environmental impact of the alternatives being considered in the
DEIR; and
WHEREAS, the DEIR states that the Regional Project has the support of staff at the
CPUC; and
WHEREAS, the Parties support a collaborative institutional and political approach to
facilitating analysis of the environmental, technical, managerial and financial feasibility of the
Regional Project to foster and promote cost-effective, regionally beneficial and environmentally
sensitive regional water supply planning; and
l l o401)11ll\.42l999.6"6ll09

Final EIR
4-97
September 2015
WHEREAS, the Parties recognize that water supply issues confronting north Monterey
County and the Monterey Peninsula are significant, and re{]uire focused technical and
cooperative political effort to resolve; and,
WHEREAS, the Parties further recognize that there is an urgency to identify and
adequately analyze and plan, fully in accordance with all applicable laws, a water supply solution
for North Monterey County, the MCWD service area and the Monterey Peninsula; and,
WHEREAS, the Parties have, the ability to furnish financial resources and in-kind
assistance in support of the cooperative planning and joint analysis contemplated by this MOU ;
and,
WHEREAS, the Parties wish by this MOU to provide a common planning framework to
conduct planning-level analysis for the Regional Project and elements of the Regional Project,
excepting surface water diversion and/or groundwater for use outside MCWRA Zone 2C, as to
which the Parties have not yet analyzed and come to a common position; and
WHEREAS, nothing in this MOU is intended to infringe upon or otherwise restrict the
independent authority of each Party; and,
WHEREAS, this MOU is intended as a preliminary agreement for planning-level activities
relating to the Regional Project. This Agreement is not intended to and shall not be interpreted
to constitute, directly or indirectly, a commitment by the Parties to undertake any project or
action, including but not limited to a project or action involving any element of the Regional
Project. The Parties acknowledge and agree that no commitment to undertake any project or
action may occur until environmental review has been completed in accordance with CEQA.
The Parties specifically intend to avoid any commitments or actions that would, in light of all
surrounding circumstances, commit the Parties as a practical matter to any project or project
element prior to the completion of enviromnental analysis in accordance with CEQA.
NOW, THEREFORE, in considemtion of the mutual agreements made herein, and the
mutual benefits to be provided, the sufficiency of which is hereby acknowledged, the Parties
agree as follows:
1.
The Parties will negotiate in good faith agreements to analyze the feasibility of
a) bmckish water supply wells for a potential desalination plant; b) ocean outfall brine disposal;
and, c) urban reuse of recycled water so that the FEIR can be used for future decisions by the
Parties. The Parties' respective governing bodies may consider adoption of these agreements
within thirty (30) days after the Effective Date.
2.
If the CPUC certifies an FEIR for the Regional Project and approves a project
based on the certified FEIR, the Parties may cooperate and use the certified FEIR as the basis for
analyzing and acting on the implementation of a regional water supply project if in compliance
with all applicable laws.
2
Final EIR
4-98
September 2015
3.
The Parties shall further negotiate a cost sharing agreement for the equitable
sharing of expenses for technical support and provision of in-kind assistance necessary to
implement this MOU, the approval of such agreement to be a condition precedent to further
performance pursuant to their MOU. Such negotiations shall commence immediately upon the
Effective Date and either successfully conclude or terminate within sixty ( 60) days after the
Effective Date.
4.
The Parties support the negotiation and execution of an agreement between
MRWPCA and MCWD to implement the project described in the environmental impact report
certified by MCWD on October 27, 2004, by Resolution 2004-56 ("RUWAP EIR") for the
Regional Urban Water Augmentation Project in accordance with CEQA, and Addendum No. I
to the RUWAP EIR certified on November 15, 2006, and Addendum No. 2 certified on
February 14, 2007.
5.
Parties.
The Effective date shall be the date this MOU is last executed by any of the
Dated:....:..
~ fJ,
,l!.:..g_
2009
Dated: -~
7,1-/:tO
:. ;;:.,__,, 2009
Monterey
Name and title]

Marina Coast Water Di
y
[Name and
Dated: I l 10
HOWARD
. 2009
onal Water Pollution Control
by~:tlb~==:------2-~~:&~~=
[Name and title]
LOU CALCAGNO, CHAIR

CHARLES J.
I2400\ll l\421999.6:62209

Final EIR
ounsel, Monterey County Water Resources Agency
3
4-99
September 2015

Final EIR
4-100
September 2015
EXHIBIT "B"
6-5-09
MEMORANDUM OF UNDERSTANDING
Regional Urban Water Augmentation Project
This Memorandum of Understanding ('MOU') Is made by and between Marina Coast Water
District ("MCWD') and the Monterey Regional Water Pollution Control Agency (' the
MRWPCA"), individually each a Party and collectively the Parties to this MOU, who agree as
follows:
1.
Regional Urban Water Augmentation Project <RUWAPl.
1.1
RUWAP Planning. EIR. The Parties have been planning the Regional
Urban Water Augmentation Project ('RUWAP"), for which MCWD is the lead agency under
the California Environmental Quality Act (' CEQA' ). Under the RUWAP, MCWD would
provide recyCled and desalinated water service to areas on the former Fort Ord ('Ord Area' )
to meet the projected water demands of the redevelopment requirements of the former Fort
Ord as anticipated by the Fori Ord Base Reuse Plan and its accompanying EIR. MCWD
certified an environmental impact report ("EIR') for the RUWAP in accordance with CEQA on
October 27, 2004, by Resolution 2004-56, adopted Addendum No. 1 to the RUWAP EIR on
November 15, 2006, and adopted Addendum No. 2 on February 14, 2007. Collectively, lhe
EIR, Addendum No. 1 and Addendum No. 2 are referred to in this MOU as the "RUWAP
EIR." This MOU is not intended to and shall not be interpreted or implemented to make an
irreversible commitment of resources eilher formally or as a practical matter under the
circumstances for any activities mentioned In this Agreement that may result In changes to
the physical environment and that are not described and analyzed under the California
Environmental Quality Act. MCWD has complied with the requirements of CEQA for a lead
agency and MRWPCA has complied with the requirements of CEQA for a responsible
agency in the consideration and approval of this MOU. MCWD and the MRWPCA shall each
comply with their respective requirements under CEQA to implement the RUWAP in
accordance with the RUWAP EIR.
1.2
Prolect Description. The RUWAP EIR analyzes desalination and
recycled water project alternatives to provide up to 3,000 acrefeet per year (AFY) of water,
or 600 AFY more than the primary project objective of obtaining 2,400 AFY of water for
redevelopment of the former Fort Ord. Under the selected Hybrid Water Alternative, MCWD
would provide 2,400 AFY fO( redevelopment of the former Fort Ord, 300 AFY of recycled
water could be provided for the Monterey Peninsula and an additional 300 AFY of
desalinated water could be provided to supply MCWD's other service areas. As a result of
Addendum 2 to the RUWAP EIR, up to 1,727 AFY of recycled water would be used for the
project. The RUWAP EIR, in Section 3.2, anticipates that subsequent project-level
environmental review will be necessary prior to implementing the component to provide 300
AFY to the Monterey Peninsula.
1.3
FORA Water Allocation. The Fort Ord Reuse Authority ("FORA") Board
of Directors has allocated 1,427 AFY of recycled water expected to be produced by the
RUWAP to FORA's member jurisdictions with land use jurisdiction on the former Fort Ord.
FORA's Board has left open the possibility that an additional 300 AFY may be made
available from the MRWPCA, should the MRWPCA decide not to dedicate that recycled
water to the Monterey Peninsula area. For a 1,727 AFY project, approximately 1,150 AFY of
recycled water will be needed during the six months of April through September.
11400':0 11\12 371 S.4:l60!>

Final EIR
4-101
September 2015
6-5-09
1.4
Parties' Intent. MCWO and the MRWPCA each have contractual rights
to use recycled water from MRWPCA's regional treatment plant ("RTP"). MCWO has agreed
to defer taking more than 300 AFY of ils recycled water between April and September, and
may take the balance of its entitlement between October and March , Including the portion
deferred from the preceding April through September period. MRWPCA has access to an
additional 766 AFY of recycled water, with an agreed 11 percent variance, during the months
of May through August (exclusive of MCWD's entitlement), and certain adefitional amounts
during the months of September through April. Efforts will be made to not exceed the 766
AFY except during dry years. The RUWAP benefits from combining the rights of MCWD and
MRWPCA. The Parties Intend by this MOU to provide terms to Implement the recyCled water
portion of the RUWAP as analyzed in the RUWAP EIR, as efficiently and cost-effectively as
possible to benelit the customers and ratepayers of the Parties.
2.
Cooperative Use of Recycled Water. MCWD and the MRWPCA will supply
recycled water from MRWPCA's regional treatment plant r RTPi as described and analyzed
in the RUWAP EIR for the adopted Hybrid Alternative. The recycled water will be supplied
by direct delivery from the RTP by such means as the Parties may agree, consistent with the
RUWAP EIR. Under the adopted Hybrid Alternative, the MRWPCA and MCWD will supply
recycled water equivalent to the FORA recycled water allocations of 1.427 acre-feet per year
("AFY") . As discussed In the RUWAP EIR, MRWPCA will undertake project-level
environmental review of feasibil~y of providing 300 AFY to the Monterey Peninsula pursuant
to prior discussions and understandings. The MRWPCA hereby commits 650 AFY of
recycled water during the months of May through August each year from MRWPCA
entitlements. MCWO hereby commits 300 AFY of recycled water during the months of April
through September each year from MCWO entitlements. The MRWPCA and MCWO commit
additional quantities of recycled water as needed during the months of September through
April from MRWPCA e ntitlements and October through March from MCWO entitlements to
assure delivery of the agreed water commitments to RUWAP.
3.
Future Projects.
3. 1
The Parties will meet and confer in good faith to evaluate the
environmental, technical, managerial and financial feasibility of (a) a project to use the RTP
outfall to transport and discharge brine byproduct from a water desalination facility, and (b) a
ground water replenishment project to inject and store recycled water in the Seaside
Groundwater Basin, and (c) any other recycled water project mutually identified by the
Parties.
3.2
Concepts for all such discussions and negotiations wi!l Include that the
Parties will share use and the proportional operations and maintenance (O&M) and capital
costs of the MRWPCA's RTP outfall should MCWD need to dispose of desalination brine,
and the capital and O&M costs of any jointly used recycled water transmission/distribution
facilities.
3.3
MCWO and MRWPCA each may continue discussions and negotiations
with third parties about evaluating the feasibility of supplying recycled water to such third
parties notwithstanding the provisions of this section 3.

Final EIR
4-102
September 2015
6-5-09
4.
Treatment Plant Facilities.

4.1
The elements of the RUWAP EIR for facilities on the RTP site to deliver
recycled water for the RUWAP to the RTP site boundary ('RTP Additions") Include recycled
water pumping plant, tank modifications, flow metering and a pipeline to the MRWPCA
property line. Upon execution of this MOU, MRWPCA will analyze the feasibility of
MRWPCA implementing the elements of the RUWAP EIR for the RTP Additions. Based on
that analysis, MRWPCA will determine how to proceed with respect to the RTP Additions and
will notify MCWD of that determination Within 90 days after execution of this MOU. After
receiving notice of MRWPCA's determination, MCWD will notify the MRWPCA In writing
when MCWD has obtained a firm financing commitment for the Backbone Transmission
Facilities. Upon notification from MCWD, MRWPCA will seek a preliminary financing
commitment for the RTP Additions. MRWPCA must notify MCWD in writing that MRWPCA
has obtained a preliminary financing commitment for the RTP additions in writing within 90
days after MCWD has provided notification of its financing commitment for the backbone
facilities.
4.2
If MRWPCA obtains a preliminary financing commitment and determines
to finance, construct. own and operate and be responsible for the RTP Additions, MRWPCA
shall coordinate the construction schedule for the MRWPCA RTP Additions with the
construction schedule for MCWD's backbone transmission facilities. If any of the following
occurs: (a) MRWPCA does not obtain a financing commitment or (b) MRWPCA determines
not to construct the RTP Additions or (c) MRWPCA does not construct the RTP additions in
coordination with the construction schedule for the backbone transmission facilities, MCWD,
acting as lead agency under the RUWAP EIR may finance, construct, own and operate and
be responsible for, facilities on the RTP site, in close coordination and consultation and
cooperation with MRWPCA in connection with the location and operation of the RTP
Additions and their Interface With the RTP.
4.3
The costs of the RTP Additions will be invoiced with the wholesale cost
($/AF) of recycled water, including Municipal and Industrial charges for water in accordance
with U.S. Bureau of Reclamation loan procedures, treatment and operational costs (e.g.,
labor, power, repair and maintenance) Involved in pumping water to the MRWPCA property
line, and amortil:ed capital charges. MRWPCA and MCWD will consult wfth each other
regularly and will evaluate, plan, design and construct the RTP Additions in accordance with
the California Environmental Quality Act and other applicable provisions of law.
4.4
The agency that finances and constructs the RTP Additions shall be
responsible for obtaining permits and approvals and for complying with all laws to design and
construct the RTP Additions.
5.
Backbone Transmission Facilities. When MRWPCA has secured project
funding for the treatment plant facilities identified in paragraph 4, or if MCWD is obligated to
finance and construct the RTP Additions pursuant to section 4 of this MOU, MCWD will
proceed to finance, construct, own and operate, in consultation with MRWPCA, and have full
responsibility for, backbone transmission facilities ('the backbone' ) to deliver recycled water
for the RUWAP from the southern boundary of the RTP site to MCWD's retail users in the
Ord Area. The cost of these improvements will be included, along with the wholesale cost, in
the retail cost of the water. The retail cost will include labor, power, repair and maintenance
and amortized capital charges. MCWD will evaluate, plan. design and construct the

Final EIR
4-103
September 2015
6-5-09
backbone in accordance with the California Environmental Quality Act and other applicable
provisions of law. MCWD, as lead agency, is responsible for:
5.1
necessary environmental review and compliance.
5.2
obtaining necessary permits and approvals, and
5.3
complying with all laws to design and construct the backbone.
6.
Monterey Peninsula Elrtenslon Financing and Responsibility. MRWPCA will
finance, construct, own and operate, and be responsible for any transmission facilities
(' Monterey Peninsula extension") that MRWPCA decides after appropriate environmental
analysis and review to build to deliver recycled water from the southern boundary of the
former Ft. Ord to the Monterey Peninsula. The MRWPCA will include the cost of these
improvements and a proportional share of the backbone costs, along with the wholesale
cost, in the retail cost of the water. The retail cost of this water will include labor, power,
repair and maintenance and amortized capital charges for the backbone. MRWPCA will
evaluate, plan, design and construct the MRWPCA Recycled Water Facilities in consultation
with MCWD, and in accordance with the California Environmental Quality Act and other
applicable provisions of law. MRWPCA is responsible for necessary environmental review
and compliance, and for obtaining any necessary permits and approvals and agreements
and for complying with all laws to design and construct and operate the Monterey Peninsula
Extension.
7.
Recycled Water Deliverv.
7.1
MRWPCA will use its best efforts to meet all MCWD demands for
recycled water pursuant to this MOU. To help with water planning , MCWD will submit a
monthly usage report and an annual demand estimate to MRWPCA. MRWPCA shall be
liable to MCWD for actual damages and claims caused by non-permit compliant water quaJHy
as set forth below and the breach of this MOU, but shall not be liable to MCWD for damages
from failure, suspension, diminution, or other variations of service occasioned by any cause
beyond the control of MRWPCA. Such causes may indude, but are not restricted to, acts of
God, acts of war, or criminal acts of others, acts of MCWD, water shortages, power failures,
fires, floods, earthquakes, epidemics, quarantine restrictions, strikes, or failure or breakdown
of transmission or other facilities.
7.2
All water supplied from the RTP pursuant to this MOU shall meet all
applicable standards of quality prescribed by laws and regulations or by separate agreement
of the parties, so that the water may be used for the purposes specified herein. The Parties
acknowledge that recycled water may not be suitable for certain salt-sensitive plants and turf.
To aid in user education on water quality, MRWPCA will provide annual water quality reports
to MCWD for distribution by MCWD to current and prospective customers.
7.3
MCWD will use its best efforts to meet all MRWPCA's demands for
distribution of recycled water pursuant to this MOU. MCWD shall be liable to the MRWPCA
for damages from the breach of this Agreement, but shall not be liable to the MRWPCA for
damages from failure, suspension, diminution, or other variations of service occasioned by
any cause beyond the control of MCWD. Such causes may include, but are not restricted to,
acts of God, acts of war, or criminal acts of others, acts of the MRWPCA, water shortages,
fires, floods, earthquakes, epidemics, quarantine restrictions, strikes, or failure or breakdown
of transmission or other facilities.

Final EIR
4-104
September 2015
6-5-09
8.
Curtailment of Delivery During Maintenance Periods.
8.1
Except in emergencies, the Parties may interrupt service to maintain or
inspect the recycled water facilities only during the months of November through March.
MCWD and MRWPCA shall exchange authoriZed schedules of planned facility maintenance,
investigation, inspection and shutdown periods. Within 30-days of receipt of any such
schedule, MRWPCA and MCWD shall meet and confer to review and approve the schedule.
(a) Planned facility maintenance does not include service interruptions
due to emergency repairs.
(b) MRWPCA will make all reasonable effort to provide continuous
service to MCWD I n accordance with the approved schedule. If the supply of recycled water
is interrupted or reduced at any time, MCWD may elect to receive at another time during the
year, and the MRWPCA shall use its best efforts to provide the amount of recycled water not
received during the interruption or reduction.
9.
Time for Payment. Each Party shall Invoice the other Party monthly, on or
before the tenth day of each month, for charges under this MOU. The Parties shall pay
promptly all charges invoiced, such invoices to be rendered on or about the fifth day of each
month for charges incurred in the preceding month and to become due and payable within
forty-five (45) days from date of invoice. If the billed Party contests an invoice submitted
under this Section, it shall give the billing Party notice of the dispute at least ten (10) days
prior to the day upon which payment of the stated amount is due. To the extent that billing
Party finds the billed Party's contentions regarding the statement to be correct, it shall revise
the statement accordingly and the billed Party shall make payment of the revised amounts
within forty-five (45) days of receiving notice of the revised amount. If the billing Party rejects
the billed Party's contentions or where time Is not available for a review of such contentions
prior to the due date, the billed Party shall make payment of the invoiced amount on or
before the due date and maKe the contested part of such payment under protest and seek to
recover the amount thereof from the billing Party.
10. Notices. All notices or other writings in this MOU provided to be given or made
or sent, or which may be given or made or sent, by one party hereto to another. shall be
deemed to have been fully given or made or sent when made in writing and deposited in the
United States mail, registered, certified or first class, postage prepaid, and addressed as
follows:
ToMRWPCA:
General Manager
Monterey, Ca 93940
ToMCWD:
General Manager
Marina Coast Water District
11 Reservation Road
Marina, CA 93933
5
1 1~ 1 3\12J11S. .6<*

Final EIR
4-105
September 2015
6-5-09
The address to which any notice or other writing may be given or made or sent to any party
may be changed upon written notice given by such party as provided above.
11 . Severability. If a court of competent jurisdiction determines any term or

condition in this MOU to be unenforceable, then such term or condition shall be null and void
and shall be deemed severable from the remaining terms or conditions and shall not affect
the validity of the remaining provisions of this MOU.
12. Section Headings. Section headings In this MOU are tor convenience only and
are not to be construed as a part of this contract or in any way limiting or amplifying the
provisions hereof.
13. Waiver. None of these terms or conditions herein contained can be waived
except by mutual written consent. The waiver by either Party of any breach or breaches
hereof shall not be deemed, nor shall the same constitute. a waiver of any subsequent
breac11 or breaches.
14 . Use of Information. Both Parties shall have access to and any party may use
and have copies of any information and writings associated with performance of this MOU,
including but not limited to working papers. plans. specifications, designs. and environmental
data and documents, developed by or for either party relating to production and delivery of
recycled water pursuant to the RUWAP and as analyzed in the RUWAP EIR. One copy of
such information shall be provided to the requesting party at no cost. Agreements entered
into by either Party for the performance of this MOU will include a requirement that a copy of
all such information and writings be made available to the Party at the Party's office for use
by both Parties.
15. Counterparts. This MOU may be executed in counterparts, and each fully
executed counterpart shall be deemed an original document, constituting one agreement,
binding on and benefiting the psrties and their successors and assigns.
16. Effect' Amendment. This MOU constitutes the full and complete agreement of
the parties regarding its subject matter, and any prior agreements or arrangements are
hereby superseded. This MOU may be amended or modified only by a writing signed by the
parties.
17. Duty to Meet and Confer. If any dispute under this MOU arises, the Parties
shall first meet and confer, in an attempt to resolve the metter between themselves. Each
Party shall make all reasonable efforts to provide to the other party all the information that
the Party has in its possession that is relevant to the dispute, so that both Parties will have
ample information with which to reach a decision.
18. Disputes. The Parties must submit any disputes arising under this MOU to nonbinding mediation before filing suit to enforce or interpret this MOU. Upon request by either
Party, the Parties will within ten days select a single mediator to mediate the dispute within
fifteen days of such selection. If the Parties cannot agree on a mediator wfthln ten days,
either Party may ask the then presiding Judge of the Monterey County Superior Court to
select a mediator to mediate the dispute within fifteen days of such selection. If the dispute
is not resolved within forty-five days of such selection, either Party may file suit to specifically
enforce or interpret this MOU and to seek any damages to which the Party may be entitled.

Final EIR
4-106
September 2015
6-5-09
19. Administrators.
MRWPCA and MCWD hereby designate their respective
General Managers as their Administrators for this MOU. All matters concerning this MOU
shall be submitted to the MOU Administrators or such other representatives as the MOU
Administrators may designate for their respective agencies. Any Party may. in its sole
discretion , change its designation of the MOU administrator and shall promptly give written
notice to the other Parties of any such change.
20. Exhibits. Exhibits and Schedules attached to this Agreement are incorporated
into this MOU by reference.
21 . Assignment. MRWPCA and MCWD may assign their respective rights under
this MOU, but neither MCWD nor MRWPCA may assign any obligations under this MOU
without the prior written consent of the non-assigning party, which consent shall not be
unreasonably withheld. As a condition precedent to the effectiveness of any assignment of
obligations, the assignee shall agree in writing to perform the assigned obligations.
22. Reoorting to Fort Ord Reuse AuthOrity (FORA\. As long as requested by FORA.
MRWPCA and MCWD agree to report jointly to the Administrative Committee of FORA, or
other entity within FORA as determined by the FORA Executive Officer on a quarterly basis.
The subject of such reports will be the progress made under this MOU toward the objectives
stated in paragraphs 1 through 3.
23. Term of MOU. This MOU shall be effective upon the date of the last duly
authorized signature of the parties executing this MOU and shall remain in effect for a period
of fifty (50) years from the date hereof, unless terminated earlier by mutual agreement. This
MOU shall be automatically extended for successive ten (1 0) year terms after the initial fifty
(50) year term unless either party g ives written notice of termination not later than ftve (5)
years before the end of the initial term or later term as extended per this section.
WHEREFORE, the parties have caused this MOU to be executed by persons authorized to
execute the agreement on behalf of the parties, effective on the date of the last signature.
~~A:
I I
tv
CJl~.i
OUCalcagno, Chair
Date:
(p 1(p - 2.00 7

Final EIR
4-107
September 2015
6-509
APPROVED AS TO FORM:
Dated:
JtJ1 /f
,2009
NOLAND, HAMERLY , ETIENNE & HOSS

By
L/~d.-. L-~.
Lloyd . Lowrey, Jr.

Legal Counsel for MCWD
Dated:
~ 1> , 2009
8
11400'.01 3\12377S,4 ,60809

Final EIR
4-108
September 2015
Monterey Regional Wa ter Supply Program

Recycled Water T hree-Way
This Memorandum of Understanding (hereinafter referred to os "MOU'') is made and entered
into as of the first day of
, among the Monterey Regional Water Pollution Control
Agency (MRWPCA), Marina Coast Water District (MCWD), and Monterey County Water
Resources Agency (MCWRA), referred to collectively in this MOU as the "Participating
Entities."
WHEREAS, the Regional Water Supply Program is an alternative analyzed in CaliforniaAmerican Water Company 's (Cal-Am) Coastal Water Project (CWP) Draft Environmental
Cities on the Monterey Peninsula, the northern communities of Monterey County, agricultural
interests and the United States Army; and,
WHEREAS, the recycled water elements of the Regional Water Supply Program appear to be
and,
W HEREAS, the Participating Entities believe it is necessary and appropriate and that there is an
urgency to review and analyze the technical, managerial, financial and environmental feasibility
of the recycled water elements for a Final Environmental Impact Report for the Regional Water
WHEREAS, evaluation of the feasibility of the Regional Water Supply Program recycled water
WHEREAS, the Participating Entities signatory to this MOU desire to cooperatively engage in
recycled water supply planning and jointly analyze proposed project elements; and,
WHEREAS, Participating Entities have previously entered into bi-lateral agreements with each
other concerning recycled water; and,
WHEREAS, Participating Entities recognize a need to memorialize a common interpretation of
their existing agreements without changing any existing agreements, to facilitate analyzing tbe
feasibility of proposed recycled water projects.
WHEREAS, this MOU is intended as a preliminary agreement for planning-level activities
relating to the Regional Water Supply Program. This Agreement is not intended to and shall not
be interpreted to constitute, directly or indirectly, a commitment by the Parties to undertake any
project or action, including but not limited to a project or action involving any element of the
Regional Water Supply Program. Tite Parties acknowledge and agree that no commitment to
undertake any project or action may occur until environmental review has been completed in
accordance with CEQA. The Parties specificaUy intend to avoid any commitments or actions
that would, in light of all surrounding circumstances, commit the Part.ies as a practical matter to
any project or project element prior to the completion of environmental analysis in accordance
withCEQA.
NOW, THEREFORE, BE IT RESOLVED, that for purposes of evaluating the feasibility of
urban recycled water project elements of the Regional Water Supply Program for the FEIR, the
Participating Entities will use and encourage others to use the recycled water demand schedules
for irrigation season (typically March through October) recycled water supply and for recycled
Final EIR
4-109
September 2015
water supply during tl1c non-irrigation season (typically November through February as shown
on Exhibit A and the schedule water for urban reuse as shown on Exhibit B (exclusive of the
MCWD 300 acft irrigation season allocation); and,
BE IT FURTHER RESOLVED, tllat the recycled water elements of the Regional Water
Supply Program shall be consistent witl1 the Regional Urban Water Augmentation Project
Environmental. Impact Report certified by MCWD on October 27, 2004, Addendum No. I to the
RUWAP EIR certified on November I 5, 2006, and Addendum No. 2 certified on February 14,
2007; and,
BE JT FURTHER RESOLVED, that in evaluating the feasibility of future urban recycled
water projects, tlle Participating Entities shall use and shall encourage otllers to use the concept
that in addition to tlle demand schedules shown on Exhibits A and B each of tlle Participating
Entities shall be able to make use of the available recycled water (approximately 6,500 afy
currently and up to approximately I 0,000 afy at plant capacity) from tlle remainder of the
irrigation and non-irrigation season available recycled water consistent with all other agreements
associated with recycled water allocations made between MCWD, MCWRA and MRWPCA.
Preference shall be given in analysis of future projects for expansion of urban reuse to include
groundwater replenishment projects, additional irrigation project storage, or other urban reuse
projects. So long as non-irrigation season water is not used for urban reuse, then MCWRA may
plan and analyze the feasibility of using such water to develop additional irrigation projects
including storage for expansion of the existing Castroville Seawater Intrusion Project and other
prospective agricultural irrigation projects; and,
BE IT FURTHER RESOLVED, that for planning and feasibility analysis, each proposed
project that wou.ld use recycled water not allocated in schedules shown on Exhibits A and B shall
be required to satisfy criteria jointly developed by a committee consisting of the Board Chair and
General Manager from each Participating Entity that would include but not be limited to I)
confirming customers for the recycled water, 2) having a completed project description, 3)
having completed environmental review under CEQA and 4) having an approved financing
mechanism for the prospective project. Every two years tlle joint committee will review and
recommend priorities and schedules for feasibility analysis; and,
BE IT FURTHER RESOLVED, that the payment of costs shall be consistent with Exrubit C
(actual costs will be paid by the customers who use recycled water whether MCWD or
MRWPCA) with tl1e clarification that all infrastructure debt service paid prior to tlle date
recycled water is delivered for prospective projects described above will also be subject to the
same provisions for ongoing debt service payments identified in sections 3 and 4, of debt service
paid by MCWRA for tlle Salinas Valley Reclamation Project bridge financing. The Committee,
as referenced above, will review and clarify these costs to assu.-e equity between all parties; and,
The EtTcctive date shall be the date this MOU is last executed by any of the Parties.
Dated:
---=~:...}1--01-=-~-- 2009

Final EIR
4-110
September 2015
/to
,2009
Dated: I / 1II
2009
Dated:

Agency

Final EIR
4-111
September 2015
EXHIBIT A
MCWRA DEMAND SCHEDULE
MONTH
JANUARY
FEBRUARY
MARCH
APRIL
MAY
JUNE
JULY
AUGUST
SEPTEMBER
OCTOBER
NOVEMBER
DECEMBER
TOTAL
REGIONAL PLANT
WASTEWATER AVAILABLE
FOR RECYCLING
AT PLANT CAPACITY
(IN ACRE-FEET)
2390
2440
2 410
2410
2490
2480
2 500
2 520
2 520
2490
2450
2370
29 470
MCWRA'S DEMAND
SCHEDULE FOR RECYCLED
WATER
190
480
1620
2 410
2,490
2 480
2 500
2 520
2 520
1"650
340
250
19 450
I. Source: (MRWPCN'MCWQA- 6116192- tx.hibir ~)
2. Exctplion ror lrria,adOQ $tiii$0P tt\own ill lixhlbhs B

Final EIR
4-112
September 2015
EXHlBIT B
SEASONAL CAP ON URBAN
T ERT IARY T REATED WASTE WATER ALLOCATION
Month
MAY
JUNE
J ULY
AUGUST
Typical Monthly Seasona l

Spread (at)
163
202
218
183
Cumula tive seasonal

Allocation
(a f)
766 AF*
~cl~iveof MCWOJOOAFalloclltion.
Rxhll)il R i$ lht dHi&n n11mbtr, !lt:ason111 vtrilltion mly
hu:hu.lc 11% V'llrlncc
Re-<. 12120101

Final EIR
4-113
September 2015
EXIIIBJTC
CALCULATION OF PAYMENTS FOR URBAN RECYCLED WATER PURSUANT TO
THTSMOU
Urban Recycle<! Water customers (URWC) shall pay the Actual Costs of tertiary treated water to which it
takes delivery for its use. The Actual Costs will be calculate<! from the cost components which comprise
MRWPCA's existing budget and actual spreadsheet model(s) for the annual SVRP and CSIP costs.
The four cost elements that comprise the Actual Costs will be compute<! as follows:
111
SVRP O&M Costs: The SVRP O&M budget vAll be calculated based on the Total Tertiary
Treated Water Production needed to serve both the CSIP and M&l uses of tertiary treated
water. The amount to be paid by URWC will be compute<! using the formula below, in which:
B = Tertiary Treated Water Production delivered to URWC for URWC use, AFY
C =Total O&M Expenditures fromthe SVRP O&M budget, excluding debt service
D = Amount to be paid by URWC
D=_XC
A
c~
Supplemental Well Pumping Cost: The amount to be paid by URWC will be computed as
indicate<! in Section 2.G. of Amendment No. 3 of the Agreement between MRWPCA and
MCWRA.
S= Amount to be paid by URWC
SWRCB Loan Contract Debt Service: Th~ amount to be paid by URWC will be computed
B =Tertiary Treated Water Production delivered to URWC for its use, AFY
E =SVRP SWRCB Loan Debt Service
F =Amount to be paid by URWC
F=
~ XE
A
.-
Bureau Loan Contract Debt Service: The amount to be paid by URWC will be computed
using the formula below, In which:
B =Tertiary Treated Water Production delivered to URWC for its use, AFY
G = SVRP Bureau Loan Debt Service, compute<! pursuant to Article 9 (b) (1) and 9 (c) of
Bureau Loan Contract
H =Additional interest charge<! by the Bureau for the Bureau loan on the SVRP pursuant to
Article 9 (b) (2) of Bureau Loan Contract
I = Amount to be paid by URWC
I=~XG+H

Final EIR
4-114
September 2015
EXHIBIT"D"
R esolution 07-10
Resolution of the Authority Board
)
Allocating Recycled Water to Former )
Fort Ord Land Use Jurisdictions.
)
THIS RESOLUTION is adopted with reference to the following facts and circumstances:
WHEREAS, the Fort Ord Reuse Authority ("FORA") and Marina Coast Water District
("MCWD") Boards of Directors approved the recycled/desalinated two component recommendation to
implement the Fort Ord Water Augmentation Program ("Hybrid Altemative") June 10.2005 at a joint
meeting of the Boards, directing their respective sta!Tto scope the project; and
WHEREAS, the Recycled Water Component ("recycled water project") of the Hybrid
Alternative is approaching the bidding and constnction stage of the project; and
WHEREAS, FORA Board of Directors is infonned by MCWD and the Monterey Regional
Water Pollution Control Agency ("MRWPCA") that 1,427 acre feet per year ("AFY") of water is
available for making a commitment at the MRWPCA property line to the recycled water project of the
Hybrid Alternative; and
WHEREAS, Monterey County Water Resources Agency and MRWPCA have entered into an
Agreement, which allows up to 850 AFY of recycled water from May through August that MRWPCA
has agreed to dedicate to the recycled water project; and
WHEREAS, MCWD has agreed to provide 300 AFY of recycled water to the project from
April through September in addition to the 850 AFY described above; and
WHEREAS, 950 AFY of these summer time flows of the 1,427 AFYofrecycled water may be
made available for use as stated above with the remainder being used the rest of the year; and
WHEREAS, allocation of the 1,427 AFY of recycled water to fonncr Fort Ordj urisdictions is
an uppropriate means of providing initial assurance of access to the recycled water resource; and
WHEREAS, allocation of I,427 AFY will take e!Tect upon approval of this resolution by the
FORA Board of Directors; and
WHEREAS, FORA jurisdictions have agreed to reserve 5% of the recycled water for line loss
to be deducted from the total supply of recycled water available for distribution; and
WHEREAS, this 5% line loss factor may be adjusted in the future as further operational
information is provided; and
WHEREAS, MCWD advises, in order to avoid over allocati\g water and potential over use of
recycled water included in Exhibit A, a line loss of I 0% n1ay need to be applied in the future; and
WHEREAS, additional recycled water resources are anticipated to become available in the
future that may be used to offset future operational line loss factors; and
WHEREAS, 300 AFY of additional recycled water (less the 5% line loss as measured within
MCWD's service area) is currently proposed to be set aside to others by the MRWPCA; and

Final EIR
4-115
September 2015
WHEREAS, the FORA Board acknowledges that the entity or entities using all or portions of
the additional300 AFY arc required to pay an equitable prorata share of the cost of those Ord
Community facilities that are necessary for delivery of the resource; and
WHEREAS, all or a portion of that 300 AFY of recycled water may be made available by
MRWPCA action to fonner Fort Ord uses in the future; and
WHEREAS, moving forward with an allocation of recycled water at this time is essential for
reuse of the former Fort Ord; and
WHEREAS, FORA has received advice from counsel that adopting an allocation of recycled
water resource is appropriate given the pending agreements to deliver recycled water resources to
member jurisdictions' projects; and
WHEREAS, FORA is allowed under the California Environmental Quality Act to allocate
recycled water given that environmental impacts of the recycled water program (construct distribution
systems and provide recycled water from the existing MRWPCA wastewater treatment facility to
urban users within the Ord community) have been analy.:ed in a 2004 environmental impact report
("EIR") and two subsequent addenda; and
WHEREAS, the itnpacts of water allocations for redevelopment on Fort Ord were evaluated
under the 1997 Ba~e Reuse Plan ElR; and
WHEREAS, allocating recycled water resources to conserve potable water resources for such
purposes meets the spirit and letter of the Fort Ord Base Reuse Plan; and
WHEREAS, the FORA Administrative Conunittee recorrunends that the FORA Board adopt
the attached "List of Allocations" and criteria defined herein to implement a portion of the Hybrid
Alternative.
NOW, THEREFORE, BE IT RESOLVED by the FORA Board of Directors that:
The attached recycled water resource aJlocation "List of Allocations" (Exhibit A) is
l.
adopted.
2.
The prioritization/methodology/criteria for use of recycled water at the Ord Community
are adopted for allocating recycled water to projects in tbc following hierarchy:
a.
b.
c.
d.
c.
f.
g.
Existing development projects;

Development projects in the FORA Capital Improvement Program;
Development projects with Disposition and Development Agreements;
Development projects with Exclusive Negotiating Agre.,momt;;;
Development projects that are flagship projects;
Best available Water Conservation efficiencies employed; and
Agreement to pay capacity or other fixed cost charge for receipt and acceptance of this
recycled water.
3.
FORA shall allow its member jurisdictions and Ord Community developers the tight to
usc the recycled water set forth on Exhibit A at costs to be determined at a later date.
4.
This action docs not require any jurisdiction to accept recycled water resources beyond
that required under the terms of ex isting agreements.
5.
If a jurisdiction is unable to accept recycled water resources, those resources will be
returned for futme FORA Board allocation according to the principles noted in #2 above.
Final EIR
4-116
September 2015
6.
To allocate additional resources, if they become available, the FORA Board of
Directors may revisit this allocation in Spring of2008 or as a component of future plaMing.
7.
A 5% line loss factor will be applied to all recycled water within the MCWD service
area during the first 5 years of initial operation of the recycled water system, with future line loss
factors to be applied for subsequent years of operation based on evidence derived from the first five
years of operation. In the event line loss increases occur, additional recycled water resources are
expected to account for the increased demand.
8.
If the add itional 300 AFY of water proposed to be set aside for others becomes
available by MRWPCA action, the FORA Board will allocate those resources according to the same
criteria listed in #2 above.
Upon motion by Mayor Mettee-McCutchon, seconded by Mayor Rubio, the foregoing resolution was
pas~ed on this 11'11 day of May 2007, by the following vote:
AYES:
12
NOES:
ABSTENTIONS:
ABSENT:
.o.
- t-
Directors Russell, Della Sala, Mcttcc-McCutchon, Wilmot, Potter,

Salinas, Calcagno, Rubio, Mancini, Pendergrass, Davis, and McCloud
Director 13ames
-0-
I, Mayor Russell, Chair of the Board of Directors of the Fort Ord Reuse Authority of the County of
Monterey, State of California, do hereby certify that the foregoing is a true copy of an original order of
the said Board of Directors duly made and entered under Item 7c, Page 4, of the board meeting minutes
of May II, 2007 thereof, which are kept in the Minute Book resident in the offices of the Fort Ord
Reuse Authority.
6.::;,.c..B
~~!:....Afo
-"'_"~-'('
Date.__
re4~44deg
seph P. Russell
Chair, Board of Directors

Fort Ord Reuse Authority

Final EIR
4-117
September 2015
Exhibit A
List of Allocations 1
Jurisdiction
Acre-Feet per
Year
CSUMB
87
UC MBEST
60
County
134
Del Rey Oaks
280
Seaside
453
Marina
345
Subtotal (amount to
be allocated to Fort
Ord Jurisdictions}
1359
68
Line loss
Former Fort Ord Total2
1427
1. Please refer to paragraph #3 under the

discussion section of the staff report for a
description of how allocations were
determined.
2.
MRWPCA's planning efforts for recycled

water, supported by studies performed in
1992, 1996, and 2003, have accommodated
300 AFY of recycled water to be set aside by
MRWPCA for delivery south of the former
Fort Ord to Monterey County, the City of
Seaside, and the City of Monterey. Therefore,
this 300 AFY plus the 1427 AFY in this "List
of Allocations" equals a total of 1727 AFY.

Final EIR
4-118
September 2015
EXHIBIT "E"
MCWD Service Area Map

N

Final EIR
4-119
September 2015
LetterH: MarinaCoastWaterDistrict
H-1
See Master Response #10: Marina Coast Water District and City of Marina Water Supply
Issues in Chapter 3, Master Responses to Comments.
H-2
Each of Marina Coast Water Districts comments has been addressed in the individual
responses, below, and in Master Response #10: Marina Coast Water District and City of Marina
Water Supply Issues. Clarifications to the Draft EIR have been made where necessary. See
H-3 through H-19

See Master Response #10: Marina Coast Water District and City of Marina Water
Supply Issues in Chapter 3, Master Responses to Comments.
H-20
The text of Section 2.9.1.1 RUWAP Product Water Alignment on page 2-67 of the Draft EIR has
been amended in response to this comment. See Chapter 5, Changes to the Draft EIR. See
also Master Response #10: Marina Coast Water District and City of Marina Water Supply
Issues and Master Response #12: Adequacy of Scope and Range of Alternatives in Chapter 3,
Master Responses to Comments.
H-21
Issues and Adequacy of Range and Master Response #12: Adequacy of Scope and Range of
Alternatives in Chapter 3, Master Responses to Comments.
H-22
The Summary chapter of the Draft EIR identifies alternatives considered (see Draft EIR in
section S.5 on page S-5). The text of the Summary chapter of the Draft EIR has been amended
to present a more detailed description of those alternatives by including Sections 6.3.3 and 6.4
of the Draft EIR in their entirety, starting on page S-5. See Chapter 5, Changes to the Draft
EIR. The Summary section identifies areas of controversy (issues to be resolved) in section S.6
on page S-5 of the Draft EIR.
H-23
This comment requests a change to the first paragraph of section 1.4 Project Approval and
Understanding of the Draft EIR. The requested change has been made; see changes to page
1-5 of the Drat EIR within Chapter 5, Changes to the Draft EIR.
H-24
The comment is correct that a Statement of Overriding Considerations must be adopted for any
impacts that are found to be significant and not reduced to a less-than-significant level by
mitigation.
H-25
The last two sentences on page 2-10 of the Draft EIR have been amended to indicate the
source of the statements more clearly in response to this comment. See Chapter 5, Changes
to the Draft EIR.
H-26
No response necessary; the comment is not germane to environmental impacts of the

Proposed Project.
H-27
The comment states that the Figure 2-7 of the Draft EIR, showing the geographic extent of
seawater intrusion, is incorrect, and asserts that significant areas shown as having chloride
levels above 500 mg/L actually do not.

Final EIR
4-120
September 2015
Figure 2-7 of the Draft EIR (which has been updated in this Final EIR, Figure 2-7rev at the end
of Chapter 5, Changes to the Draft EIR) combines two figures prepared by the Monterey
County Water Resources Agency, which actively monitors seawater intrusion in the Salinas
Groundwater Basin. The basis of the assertion in the comment is from data contained in a
technical memorandum (Technical Memorandum - Monterey Peninsula Water Supply Project
Baseline Water and Total Dissolved Solids Levels, Test Slant Well Area). The interpretation of
that data appears to be incorrect for two reasons. First, the two MRWPCA Wells in the
referenced Figure 3-5 of the above memorandum are screened in the same formation (per
Table 1 of that report), but the monitor in Well No. 1 is set 20-ft deeper than the monitor in Well
No. 2. The results show increasing salinity with depth, with the deeper water exceeding 500
mg/L TDS. Second, the comment references to Table 2. The two wells in that table with
chloride levels below 500 mg/L (Wells MW-5M and MW-5S) also have nitrate levels over 10
mg/L, which indicates they may be partially screened in the A-Aquifer and not the 180-ft
Aquifer. The MCWRA Seawater Intrusion maps are consistent with the data in the referenced
Monterey Peninsula Water Supply Project Technical Memorandum.
H-28
The Draft EIR on page 2-15 has been updated to include information provided in this comment.
H-29
H-30
H-31
Table 2-22 in the Draft EIR on page 2-89 has been updated to include the requirement for
reaching agreements with local agencies for urban runoff water as discussed in this comment.
These agreements were described in the Draft EIR in Appendix C (which has been revised and
included in this Final EIR as Appendix C-Revised) and on page 4.18-24. See Chapter 5,
H-32
Executive Order B-30-15 was issued after the Draft EIR was published. The Executive Order
does not contain any mandates for local government (i.e., the MRWPCA, the lead agency, and
MPWMD, its project partner) nor for the implementation of water supply, water quality
enhancement, or wastewater reuse projects such as the Proposed Project. Rather, the effect of
the Executive Order will primarily be promulgation of new state regulations requiring an
increase in energy efficiencies and use of alternative fuels. Such regulations would be expected
to reduce GHG emissions associated with the Proposed Projects consumption of electricity. It
is not clear that new regulations mandating use of alternative fuels would be in effect prior to
project construction, but if such regulations were adopted prior to project construction, they
would reduce the GHG emissions associated with construction equipment and deliveries. Any
mandated energy/fossil fuel conservation and reductions in greenhouse gas emissions
resulting from the implementation of Executive Order B-30-15 would also apply to the Proposed
Project operations. In response to this comment, the Draft EIR text on page 4.3-9 has been
amended to include a description of the Executive Order. See Chapter 5, Changes to the
Draft EIR.
H-33
The project proponents will comply with consultation requirements with the United States Fish
and Wildlife Service (USFWS) and/or National Oceanic and Atmospheric Administration,
National Marine Fisheries Service (NMFS) to determine whether the project will have any direct
or indirect effects on federally listed threatened, endangered, or candidate species at project
sites and surrounding areas and identify measures to reduce such effects. The project
proponents will also comply with the California Department of Fish and Wildlife (CDFW)
consultation requirements. The key component of the proposed mitigation measures is

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coordination with appropriate resource agencies and acquiring necessary permits to assure
that the most protective measures are implemented during the construction phase to reduce
impacts to listed species and to comply with the Federal Endangered Species Act (FESA) and
California Endangered Species Act (CESA). This Final EIR contains changes to Mitigation
Measures BF-1a and BF-1b, and an additional mitigation measure (Mitigation Measures BF-1c)
for Impact BF-1 to enhance the requirements for avoidance and minimization of impacts to
Tidewater Goby and Steelhead (see changes to Draft EIR page 4.4-44 in Chapter 5, Changes
to the Draft EIR). The mitigation requires that pre-construction surveys identified in Mitigation
Measure BF-1b must be consistent with requirements and approved protocols of the applicable
resource agencies and performed by a qualified fisheries biologist. The current protocol can be
found
on
the
USFW
webpage
under
tidewater
goby
protocol:
http://www.fws.gov/arcata/es/fish/goby/goby.html.
The Draft EIR identifies potentially significant construction impacts to fisheries on pages 4.4-41
through 4.4-44 and mitigation measures that would reduce impacts to a less-than-significant
level are provided on page 4.4-44 of the Draft EIR. These mitigation measures include
Mitigation Measures BF-1a and BF-1b that require construction be timed to occur only outside
of both adult and smolt steelhead migration periods (i.e., between June and November) and
relocation of aquatic species during construction. The use of the term best management
practices on page 4.4-42 is correct; however, section 4.4 of the Draft EIR did not identify these
within the mitigation. BMPs are identified in section 4.5. The Draft EIR has been modified on
page 4.4-44 to include the requirement to implement mitigation measure BT-1a from Section
4.5 (page 4.5-75) that would further reduce impacts to aquatic species during construction.
Mitigation Measure BT-1a requires that the project proponent and its contractor implement
Construction Best Management Practices (BMPs) for all Proposed Project components.
Applicable BMPs as revised and expanded from page 4.5-75 of the Draft EIR are detailed in
the Changes to the Draft EIR Section of this Final EIR. See also Master Response #5:
Fisheries Impact Analyses in Chapter 3, Master Responses to Comments.
H-34
Modification to the San Jon weir would take place to mitigate for reduction in flows due to
project operations that would result in reduced access to and from the Reclamation Ditch
watershed, upstream of the Project. Bypass flow requirements have been developed to allow
adult and smolt steelhead migration to have adequate flow to travel past this obstacle. The
Proposed Project, with implementation of Mitigation Measure BF-2, will not cause flow to
decline below those levels defined as threshold fish passage flows (Table 4.4-8). The diversion
facilities are described and illustrated in Figure 1 and 2 of Appendix P, Reclamation Ditch Yield
Study. This information is also summarized in the Draft EIR text on page 2-51 and the proposed
site plans are shown on Figures 2-23 and 2-24 of the Draft EIR.
The flow requirements in this EIR may be further refined based on consultation with USFWS,
NMFS, and CDFW. As noted above and in the Draft EIR Section 4.4, consultation with the
USFWS, NMFS and CDFW is required. During such consultation, measures would be identified
to reduce effects which may include specified flow criteria and design revisions for diversion
facilities. Consultation may revise flow requirements as conditioned by agencies; if flow
requirements are altered resulting in potential Project-related reduction in steelhead migration,
the weir will need to be modified to allow steelhead passage. Any modifications would be
consistent with fish passage requirements in effect at the time of design/construction.
Consultation is a key component of the proposed mitigation measures; conditions of permits will
assure that the protective measures are implemented during the construction phase are in
compliance with the FESA and CESA. The final facility design for the diversion facilities will
incorporate fish screens acceptable to CDFW and NMFS (see last paragraph on page 4.4-50 of
the Draft EIR). This may require compliance with specific design requirements, such as NMFS'
Anadromous Salmonid Passage Facility Design criteria and specifications mentioned in this
comment letter; however, this will depend on requirements arising from the consultations with
the resource agencies.

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See also responses to letter E, response to H-33 above and Master Response #5: Fisheries
Impact Analyses in Chapter 3, Master Responses to Comments. Mitigation Measure BF-1c
cites requirements for consultation. To ensure compliance with FESA and CESA, the MRWPCA
and/or implementing entity will obtain either Incidental Take Permits or written concurrence that
implementation of the project will not result in take for steelhead and tidewater goby.
H-35
Each mitigation measure in the Biological Resource: Terrestrial section is based on one or
more of the following: current guidance documents and species specific protocols, site specific
considerations, professional experience of DD&A staff biologists with all aspects of project
planning, design, permitting, implementation and monitoring/reporting, and information provided
at the relevant agencies websites, including the following: U.S. Army Corps of Engineers
(www.usace.gov),
the
Regional
Water
Quality
Control
Boards
(http://www.swrcb.ca.gov/rwqcb3/), U.S. Fish and Wildlife Services (www.fws.gov), California
Department of Fish and Wildlifes (www.wildlife.ca.gov), California Coastal Commissions
(www.coastal.ca.gov), and National Oceanic and Atmospheric Administration National Marine
Fisheries Services (www.nmfs.noaa.gov). Where buffers are standard for specific species,
those were provided in the relevant mitigation measures (see the following locations where
buffers were defined):
Mitigation Measure BT-1i: Conduct Pre-Construction Surveys for Monterey Dusky-Footed
Woodrat (on page 4.5-82 of the Draft EIR): Surveys are to be conducted in a buffer zone 100
feet out from the limit of disturbance
Mitigation Measure BT-1j: Conduct Pre-Construction Surveys for American Badger (on page
4.5-82 of the Draft EIR): a minimum buffer of 200 feet in which no construction activities
shall occur shall be maintained around the den
Mitigation Measure BT-1l: Conduct Pre-Construction Surveys for Burrowing Owl (on pages 4.583 and 4.5-84 of the Draft EIR): a construction-free buffer of 250 feet shall be established
around all active owl nests
For special status bats (Mitigation Measure BT-1g on page 4.5-81 of the Draft EIR) and avian
species (Mitigation Measure BT-1K on page 4.5-83 of the Draft EIR), there is no standard buffer
and none can be assigned because each species and site warrants its own unique buffer that
should be developed by a qualified biologist in consultation with the relevant resource agency
or agencies if the pre-construction surveys identify the presence of a bat or nesting bird.
H-36
The comment notes that mitigation measure BT-2a requires avoidance of riparian and wetland
habitat to the extent feasible and that the RUWAP alignment option for the Product Water
Conveyance Pipeline avoids those habitats. See Draft EIR, pages 4.5-61, 4.5-91, 4.5-92, and
6-34 (comparative alternatives analysis). Table 6-4 has been edited to correct a typographical
error in the columns for Coastal Alignment versus RUWAP alignment on the line item for BT-2.
Mitigation Measure BT-2c on page 4.5-94 of the Draft EIR has been modified to address the
timing of implementation of a Frac-out Plan and to provide a list of Plan components. See
H-37
See the responses to comments H-38 through H-41.
H-38
The comment equates the dune sand aquifer near the coast with the shallow aquifer that
occurs discontinuously throughout the 180/400-Foot Aquifer Subbasin. The water quality and
recharge mechanisms associated with these two units differ, as the Draft EIR explains. The
Draft EIR (page 4.10-5) specifically characterizes the dune sand aquifer as consisting of
portions of sand dune deposits along the coast. In contrast, the Draft EIR (page 4.10-66)

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September 2015
discusses hydrogeologic conditions several miles inland near the Salinas Treatment Facility.
Although the Salinas Valley Aquiclude is absent in some areas along the coastlineallowing
greater vertical movement of groundwater from the dune sand aquifer to the 180-Foot Aquifer
that local detail is not particularly relevant to the Proposed Project. Lowering water levels in the
180-Foot Aquifer near the coast has and will cause saltwater to flow into that aquifer from the
coast. Whether the exact flow path are downward from dune sands near the coastline or
horizontally from offshore parts of the 180-Foot Aquifer and quantities of flow are not relevant to
the Proposed Projects potential environmental adverse impacts on the Salinas Valley
Groundwater Basin because groundwater interactions due to the Proposed Project do not
adversely affect the water levels in the aquifers near the coast. In fact, the Proposed Project
would result in a quantifiable benefit to the water levels and storage in the Salinas Valley
Groundwater Basin, pressure subarea as discussed in Draft EIR pages 4.10-57 to 4.10-64.
H-39
The seawater intrusion maps are provided in Figure 2-7 of the Draft EIR, as noted in comment
H-40. Figure 2-7 has been updated in the Final EIR to include the most recent maps from the
Monterey County Water Resources Agency. See Chapter 5, Changes to the Draft EIR,
Figure 2-7rev. Figure 4.10-1 in the Draft EIR shows the Project Study Area for Section 4.10,
Hydrology/Water Quality: Groundwater section and is referenced as such in the second
sentence of the section. To show water levels as requested by the comments, a new Figure 27a has been added and is provided at the end of Chapter 5, Changes to the Draft EIR.
H-40
As indicated in this comment, the Draft EIR contains a figure numbering error. Figure 2-7 of the
Draft EIR shows the intrusion maps for the 180-Foot and 400-Foot Aquifers as discussed on
page 4.10-10 of the Draft EIR, not Figure 2-9. In addition, newer seawater intrusion maps are
available than the map included in the Draft EIR; therefore, the newer maps are now provided
in Figure 2-7rev. See Chapter 5, Changes to the Draft EIR.
The comment asserts that significant areas shown on Figure 2-7 as having chloride levels over
500 mg/L actually do not. The comment cites Figures 43 and 44 in Geoscience Support
Services April 2015 groundwater modeling report for the slant-well desalination plant project as
illustrating gaps in the extent of intrusion. However, Geoscience Support Services Figures 43
and 44 show total dissolved solids (or TDS) concentrations, whereas the seawater intrusion
maps on Figure 2-7 (and Figure 2-7rev) prepared by MCWRA show chloride concentrations.
The two are not directly comparable, because the percentage of TDS contributed by chloride
changes during the course of intrusion. Despite this difference, wells that have a history of low,
steady concentration can easily be differentiated from the ones that have experienced rapidly
increasing concentrations, based on the chemographs in Geoscience Support Services
Figures 43 and 44. When the chemograph well locations on Figures 43 and 44 are placed on
Draft EIR Figure 2-7, wells that have low, steady concentrations fall outside the indicated
intruded area, and ones that fall within the indicated intruded area have a history of increasing
concentrations. Thus, to the extent that the figures can be compared, they are consistent. Also,
see the response to comment H-33.
H-41
The area where wells have been abandoned or destroyed is generally the same as the intruded
areas for the two aquifers. If a grower can use water with slightly elevated TDS by means of
blending or choice of crop, then the well might still be in service.
Regarding changes in conditions since 2001, MCWRA updates the intrusion maps every
several years. The current maps show intrusion fronts for 2005, 2007, 2009, 2011 and 2013.
Those all show a progressive advance of intrusion, albeit at a rate much slower in recent years
than in prior decades.
H-42
As discussed in the Master Response #10: Marina Coast Water District and City of Marina
Water Supply Issues, the Proposed Project may not impact MCWDs ability to deliver recycled

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water to users. The Proposed Project would be consistent with the City of Marina Policy 3.3, as
described on page 4.10-43 of the Draft EIR.
H-43
As noted in the Draft EIR, the water balance table (Table 4.10-9, page 4.10-30) was extracted
from the 2014 Salt and Nutrient Management Plan for the Seaside Groundwater Basin. In
compliance with the States Recycled Water Policy, the focus is on recent time periods.
Accordingly, the water balance combines annual averages from selected recent time periods
containing the most representative data for each component. Specifically, all of the inflows
except subsurface inflow represent average annual data from 2008 2012. Subsurface inflows
and outflows were averaged from 2003 2007 estimates. Pumping (including ASR wells) and
system losses are average annual amounts from 2011 - 2012. Dates have been added to the
table in this Final EIR. See Chapter 5, Changes to the Draft EIR.
H-44
Specific responses to each of the itemized portions of this comment are provided below:
(a) Evaluate both the travel time and volume of water moved between injection and extraction
sites in order to determine what portion of the injected water can be safely extracted and
when.
As explained in the Draft EIR (pages 4.10-47 and 4.10-48), the Watermasters Seaside Basin
Groundwater Model was used to simulate injection and extraction associated with the Proposed
Project. Results of the groundwater modeling and the evaluation of potential groundwater
impacts are discussed in the Recharge Impacts Assessment Report, which is included as
Appendix L in the Draft EIR (see pages 50-55, Appendix L). Details and results of the
groundwater modeling are included as Appendix C in the Recharge Assessment Report (see
Appendix C within Draft EIRs Appendix L).
Both the travel time and volume of water associated with the Proposed Project were simulated
in the modeling (see pages 50 52 of Appendix L of the Draft EIR). The analysis found that the
Proposed Project resulted in sufficiently long travel times to comply with the Final Groundwater
Replenishment Regulations while also contributing to groundwater in storage almost
immediately upon injection. The fastest travel times of about one year occurred between two
deep injection wells and downgradient extraction wells (371 days for DIW-2 and 327 days for
DIW-3, see Table 10 of Appendix L). Travel times from other deep injection wells were longer,
yet provided an immediate increase to the amount of groundwater in storage within the Santa
Margarita aquifer due to confined groundwater conditions. Injection into the Paso Robles
aquifer took longer to reach downgradient wells due primarily to lower groundwater velocities in
the shallow aquifer. Nonetheless, the analysis found that extraction could occur immediately
following injection for both aquifers without significant lowering of water levels on a 1:1
(extraction/injection) basis by volume.
In summary, the analysis concludes that the Proposed Project could be operated as intended to
replenish groundwater supplies in order to increase basin yield. Additional details of operation
and monitoring will be developed for the Engineering Report, as required by the Final
Groundwater Replenishment Regulations.
(b) Confirm with the SWRCB DDW regarding the required residence time between injection
and extraction for all proposed water sources prior to the publication of the Draft EIR.
MRWPCA and Proposed Project team members have been in communication with the SWRCB
DDW (formerly CDPH) over the past several years about the Proposed Projects development
and have specifically discussed the issue of underground retention time (residence time) with
staff. On June 5, 2014, SWRCB DDW (then CDPH) approved the conceptual design and
communicated details for inclusion in the required Engineering Report and monitoring program.
During meetings on the Proposed Project, SWRCB DDW staff confirmed the modeling

Final EIR
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September 2015
approach to estimate underground retention time. Staff has also reviewed results from the
particle tracking (travel time) simulations and discussed details and results with the team.
Additional details on operation of the Proposed Project and permit conditions will be developed
during preparation of the Engineering Report, which is required prior to project implementation.
(c) Confirm that the capacity of the Seaside Basin is sufficient, within that predetermined
residence time, for the injection of the Proposed Project purified recycled water.
The capacity of the basin was examined prior to preparation of the Draft EIR using the
Watermaster Seaside Basin Groundwater Model (see Appendix B within Appendix L of the
Draft EIR). That analysis was used to optimize injection between the two basin aquifers, while
minimizing outflow of Proposed Project water from the Seaside Basin to the ocean. The
minimized outflow was used as a primary criterion for project performance in order to evaluate
residence time and ensure that the Proposed Project water would remain in the basin to
support increased extraction and use (see page 4, Appendix B within Appendix L of the Draft
EIR).
Additional modeling conducted for the Draft EIR examined the capacity of the Seaside Basin
using water levels associated with the Proposed Project. For details of the modeling analysis,
see the memorandum included as Appendix C of the Recharge Assessment Report (Appendix
C within Appendix L of the Draft EIR). As summarized in the Draft EIR (page 4.10-47) and
discussed in the recharge impacts report (Appendix L, pages 50-55), the Proposed Project was
analyzed using the Watermasters Seaside Basin Groundwater Model over a 25-year period
(see Appendix L, pages 50 and 51). The period of analysis included simultaneous operation of
the ASR wellfields including periods of injection and recovery, as well as periods when ASR
wells were idle. Results of these analyses indicate that the capacity of the Seaside Basin is
sufficient for the operation of the Proposed Project.
(d) Confirm with the SWRCB DDW that the horizontal distance required between points of
injection and extraction are adequate in the event those two modes of operation are
simultaneously occurring (Draft EIR, p. 4.10-2).
As explained in the Draft EIR, the groundwater modeling simulated simultaneous injection and
extraction of the water from the Proposed Project (Draft EIR, page 4.10-48; also see Draft EIR,
Appendix L, pages 50-55). The modeling also included additional groundwater production in
compliance with the adjudication and ongoing operation of the ASR wellfields for storage and
recovery of water from the Carmel River system. The analysis indicated that the residence time
is adequate to meet the requirements of the Final Groundwater Replenishment Regulations
(See Appendix L, pages 50-52). The use of horizontal distance as a requirement is an artifact
of earlier versions of the draft recharge regulations (e.g., draft versions issued prior to August
2008), and is not part of the Final Groundwater Replenishment Regulations; therefore, a
specified horizontal distance is no longer applicable for groundwater replenishment projects.
For detailed modeling results, see also Appendix C within Draft EIR Appendix L.
These details have been discussed with the SWRCB DDW staff. For more information
regarding ongoing communication with SWRCB DDW, see the response in H-44(b) above.
H-45
Compliance with the Final Groundwater Replenishment Regulations is summarized in Chapter

3 of the Draft EIR and discussed in detail in Sections 13 and 17 of Appendix D, Pure Water
Monterey Groundwater Replenishment Project Water Quality Statutory and Regulatory
Compliance Technical Report, and in Sections 4, 5, and 7 of Appendix L, Recharge Impacts
Assessment Report for the Pure Water Monterey Groundwater Replenishment Project. The
Draft EIR concludes that the Proposed Project would meet the regulations. Compliance with the
regulations is a mandatory requirement so that the Proposed Project can obtain a permit and
remain in compliance, and not a mitigation measure as suggested by MCWD.

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H-46
The red stars in Figure 4.10-9 show the location of the Castroville Seawater Intrusion Project
(CSIP) supplemental wells that are used to pump groundwater into the recycled water
distribution system. Figure 4.10-1 was provided to show the Project Study Area for the
groundwater section. As requested in this comment, an improved map of CSIP supplemental
wells has been added to the EIR as Figure 4.10-9a new and text on Draft EIR page 4.10-46
has been amended. See Chapter 5, Changes to the Draft EIR.
H-47
Data about the groundwater quality relevant to the Proposed Project is provided in the Draft
EIR in the following locations: Page 4.10-9 (overview of groundwater conditions in the project
area within the Salinas Valley Groundwater Basin), and pages 4.10-16 through 4.10-68 of the
Draft EIR (regarding the groundwater conditions in the vicinity of the Salinas Treatment
Facility). In addition, a useful summary of salinity issues in the lower Salinas Valley (including
TDS and chloride data) was recently prepared by Tetra Tech and released by the U.S. EPA
and the Central Coast Regional Water Quality Control Board.(Tetra Tech, 2015)
H-48
The EIRs discussion of the RUWAP is consistent with the MCWD Urban Water Management
Plan (MCWD, 2011) and the RUWAP EIR (MCWD/DD&A, 2007). These documents describe
the Recycled Water Project as being built and operated to supply recycled water exclusively for
urban irrigation demands within the Ord Community (and to the areas of central Marina outside
of the former Fort Ord). The recycled water to be provided by MCWD would augment existing
groundwater supplies, not replace groundwater supplies. The use of additional recycled water
supplies to the Ord Community would not be in lieu of groundwater pumping which is limited to
6,600 AFY by several agreements by and between the Army, MCWD, FORA, and MCWRA
MCWD is within MCWRA Zones 2/2A, zones of benefit and assessment for the Nacimiento and
San Antonio Reservoirs. Under the terms of the Armys Agreement to annex into Zones 2/2A
(assumed by MCWD in 2001), MCWD may provide up to 6,600 AFY of Salinas Valley
Groundwater to the Ord Community. This amount is approximate to the historic demand from
Army uses at Fort Ord. Of this, MCWRA requires that not more than 5,200 AFY may be
pumped from the 180-Foot and 400-Foot aquifers, to reduce the risk of seawater intrusion.
MCWD may also provide up to 3,020 AFY of Salinas Valley Groundwater to customers in the
City of Marina, outside of the Ord Community.
H-49
As discussed above, the MCWDs allowable Salinas Valley Groundwater Basin pumping is
limited to 6,600 AFY (including no more than 5,200 AFY from the 180-Foot and 400-Foot
aquifers) for the former Fort Ord and 3,020 AFY for Central Marina; therefore, even if RUWAP
recycled water rights were not exercised, MCWD cannot increase pumping quantities of Salinas
Valley Groundwater beyond its rights for future development. As discussed in Master Response
#10: Marina Coast Water District and City of Marina Water Supply Issues, in Chapter 3, Master
Responses to Comments, the Proposed Project would not have an adverse impact on Marina
Coasts ability to implement its Recycled Water Project.
H-50
The proposed diversion structure would use a screened inlet in the channel bottom with a
gravity pipeline feeding to a pump station wet well located in the channel bank (see conceptual
layout in Appendix P). This configuration will not induce cross-currents towards the pump
station, and the channel will be lined around the inlet screen to prevent scour and suspension
of sediments. During low flows in the Reclamation Ditch, the effects of the pump starting and
stopping will not affect channel. At higher flows where the inlet is submerged and the gravity
pipeline is flowing full, the pump station will operate at a fixed speed. Any eddying near the inlet
screen will occur within the lined portion of the channel. It should be noted that the Reclamation
Ditch visibly carries sediment under the current condition at flows over 10 cfs. Mitigation
Measure HS-4 on page 4.11-75 of the Draft EIR has been amended in response to this
comment and comment F-5. See changes to page 4.11-75 in Chapter 5, Changes to the Draft
EIR.

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H-51
The Proposed Project does not affect MCWDs right to purchase recycled water, as discussed
in Section 2.7.1 of the Project Description. The tables used in Appendix B in the Draft EIR,
Source Water Assumptions showed the use of the new water supply sources only. Therefore, it
did not include the current CSIP use of recycled water, or the future urban use of recycled
water by MCWD. The source water analysis tables have been updated in the Final EIR to
include both of these supplies and uses, and are included in the Appendices to the Final EIR.
Specifically, Appendix B-Revised contains the current CSIP use and flows into and out of the
Regional Treatment Plant and Salinas Valley Reclamation Plant and Appendix BB shows the
various inflows and outflows from the Regional Treatment Plant under various scenarios of
implementation of the RUWAP urban recycled water system, including a No Proposed Project
Scenario. See Master Response #3: Availability, Reliability, and Yield of Source Water Supplies
and Master Response #10: Marina Coast Water District and City of Marina Water Supply
Issues in Chapter 3, Master Responses to Comments for more information.
H-52
The noise analysis summarized in Section 4.14 of the Draft EIR is based on a technical
analysis included in Appendix W of the Draft EIR by Illingworth and Rodkin, Inc. (experts in
acoustic and vibration analyses). Resumes of the key analysts are included in Appendix EE of
this Final EIR to demonstrate their expertise. As described on page 4.14-23 of the Draft EIR, a
substantial noise increase can be defined as an increase in noise levels that causes
sustained interference with activities normally associated with established nearby land uses
during the day and/or night. One indicator that noise could interfere with daytime activities
normally associated with residential and school land uses (for example) would be speech
interference; whereas, an indicator that noise could interfere with nighttime activities normally
associated with residential uses would be sleep interference. This analysis, therefore, uses the
following criteria to define whether a temporary or periodic increase in ambient noise levels in
the Proposed Project vicinity above levels existing without the project would be substantial:
Speech Interference. Noise generated by construction equipment could result in speech
interference in adjacent buildings if the noise level in the interior of the building were to exceed
5
45 to 60 dBA. Typical buildings can reduce interior noise levels by 25 dBA if windows are
closed. This noise reduction could be maintained only on a temporary basis in some cases,
since it assumes windows must remain closed while the loudest activity is occurring. Assuming
a 25 dBA reduction with the windows closed, an exterior noise level of 70 dBA (Leq) adjacent to
a building would maintain an acceptable interior noise environment of 45 dBA. In addition to the
decibel level of noise, the duration of exposure at any given noise-sensitive receptor is an
important factor in determining an impacts significance. Generally, temporary construction
noise that occurs during the day for a relatively short period of time (i.e., one construction
season) would not be significant because most people of average sensitivity who live or work in
suburban or rural agricultural environments are accustomed to a certain amount of construction
activity or heavy equipment noise from time to time. The loudest construction-related noise
levels would be sporadic rather than continuous because different types of construction
equipment would be used throughout the construction process. Therefore, an exterior noise
level that exceeds 70 dBA Leq during the daytime is used as the threshold for substantial
construction noise where the duration of construction noise exceeds two weeks.
Sleep Interference. An interior nighttime level of 35 dBA is considered acceptable for residential
uses (EPA 1974). Assuming a 25 dBA reduction for a residential structure with the windows
closed, an exterior noise level of 60 dBA adjacent to the building would maintain an acceptable
For indoor noise environments, the highest noise level that permits relaxed conversation with 100% intelligibility
throughout the room is 45 dBA. Speech interference is considered to become intolerable when normal conversation
is precluded at three feet, which occurs when background noise levels exceed 60 dBA.

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interior noise environment of 35 dBA. Thus, an exterior threshold of 60 dBA Leq during the
nighttime is a reasonable threshold for short term impacts resulting from construction activities.
Typically, temporary noise impact analyses do not use a time period that is considered when
determining whether a temporary exceedance of a daytime quantitative noise level threshold
would constitute a significant impact. Every construction project within an urban area would
affect one or more sensitive receptors that live or work within close proximity to the construction
site. In most environmental review documents, temporary noise impacts during construction
would only result in a significant impact if the construction results in unusually high noise levels
and/or occurs over a much longer time period than two weeks (for example, one construction
season or one year), or if construction would occur at nighttime. In this EIR, the lead agency, in
consultation with the noise consultant, Illingworth and Rodkin, Inc., chose to select a much
more conservative two week time period as one component of the determination of significance
to rigorously support the conclusions and the rationale for imposition of mitigation. In this case,
the key and only component of the project that would occur in close proximity (i.e., under 500
feet) from sensitive receptors would be pipeline construction that would occur near these
sensitive receptors for far less than the two weeks used in the approach to determining
significance (i.e., the pipeline construction would proceed at a rate of 150 to 250 feet per day
passing each receptor in 4 days or less). As stated on pages 4.14-34, 4.14-36, 4.14-40, and
4.14-42 of the Draft EIR regarding the noise impacts of construction of each of the pipelines,
the proposed pipeline trenching activities at any one location along the alignment would be
limited to approximately four days or less (one to three on page 4.14-42). Although,
construction noise would exceed the speech interference significance criteria at most locations
along the alignment, the duration would be less than two weeks at any one location, and
construction would be limited to daytime hours, except potentially along the CalAm Distribution
System: Monterey Pipeline that may require nighttime construction to minimize traffic impacts.
Implementation of Mitigation Measures NV-1b and NV-1c would reduce nighttime construction
noise, and limit evening construction times, but would not reduce the impact to a less-thansignificant level. Therefore, nighttime construction noise impacts along the CalAm Distribution
Monterey Pipeline would remain significant and unavoidable even with implementation of
mitigation measures.
H-53/54 See the response to comment H-52. As discussed in response to comment H-52, the lead
agency, in consultation with Illingworth & Rodkin, Inc. elected to adopt an approach to
determining significance for the temporary noise impacts due to daytime construction that
includes a timeframe consideration. Although construction activities would potentially exceed
70 dBA Leq (the speech interference threshold) at some receptors, the daytime pipeline
construction activities would not result in a significant impact and mitigation would not be
required because the duration of the temporary noise increase is relatively short. It follows that
the mitigation measures suggested for the RUWAP alignment option of the Product Water
Pipeline would not be required. In addition, the Proposed Project would not include nighttime
construction of pipelines, with the exception of the CalAm Distribution System: Monterey
Pipeline; therefore, the recommendations in the revisions to the mitigation measure in 4.11-R1
would not be required.
Although the mitigation measures are not required to be implemented to reduce a significant
impact for either Product Water Conveyance option, MRWPCA is willing to implement the
MCWD-recommended mitigation measures in response to this comment and in conformance to
the RUWAP EIR (if the MRWPCA chooses to pursue the RUWAP alignment option for the
Product Water Conveyance pipeline). The Draft EIR has been modified to incorporate the
recommended mitigation measure as Mitigation Measure NV-1d. See changes to page 4.14-43
of the Draft EIR in Chapter 5, Changes to the Draft EIR.

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H-55
This comment and H-56 describe and show how the RUWAP EIR was modified in an
addendum to provide consideration of use of nighttime construction for specific segments of the
RUWAP pipeline due to the potential for the project to affect traffic and circulation and thus
require traffic control measures that may not be feasible. The segments identified in the
requested mitigation language are not proposed as part of the RUWAP alignment option of the
Product Water Conveyance pipeline. In addition, the traffic control measures for the Proposed
Project (see Mitigation Measure TR-2 on page 4.17-37 of the Draft EIR, as modified in this Final
EIR) are considered to be feasible. Nighttime construction is not proposed nor recommended
as mitigation for the Product Water Conveyance system. Nighttime construction of the CalAm
Distribution System: Monterey pipeline is proposed by CalAm; therefore, a significant and
unavoidable impact was identified in the Draft EIR on page 4.14-42 and mitigation was
required.
H-56
See the response to comment H-55. No nighttime construction activities would occur along the
Product Water Conveyance RUWAP alignment.
H-57
See the responses to comments H-52 through H-56.
H-58
As stated on page 4.16-1 of the Draft EIR in the first paragraph: This section addresses
potential impacts to public services, recreation and specified public utilities that could occur if
the Proposed Project were to necessitate provision of new or substantially altered public
services facilities or cause substantial physical deterioration of a recreational facility. Public
services discussed in this section include fire and police protection services, emergency
services, schools, parks, and recreational facilities. Recreational resources include parks, trails,
beaches, and similar facilities. The public utilities discussed include solid waste facilities. Water
service and systems, wastewater service, and recycled water delivery are addressed under
Section 4.18, Water and Wastewater. Note: the typographical error on page 4.16-1 of the
Draft EIR has been corrected. See Chapter 5, Changes to the Draft EIR. Section 4.16 did not
address water supply issues that are covered in Section 4.18 as amended in this Final EIR.
See also Master Response #10: Marina Coast Water District and City of Marina Water Supply
H-59
The comment clarifies Marina Coast Water Districts groundwater sources. The EIRs
description of Marina Coast Water Districts groundwater sources has been amended
accordingly. See the revisions to page 4.18-8 of the Draft EIR in Chapter 5, Changes to the
Draft EIR.
H-60
H-61
The comment clarifies Marina Coast Water Districts municipal wastewater collection systems.
The Final EIRs description of Marina Coast Water Districts municipal wastewater collection
has been amended accordingly. See the revisions to pages 4.18-11 and 4.18-12 of the Draft
EIR in Chapter 5, Changes to the Draft EIR.
H-62
The 1997 Fort Ord Base Reuse Plan was not specific on the source for augmented water
supply, but the FORA Board approved the RUWAP hybrid alternative in 2005, and later
allocated recycled water supply from the project to the member jurisdictions (2007). As
discussed in the Master Response #10: Marina Coast Water District and City of Marina Water
Supply Issues, the MCWD recycled water rights discussed in this EIR address both the City
and the FORA assumptions for recycled water use and thus the Proposed Project would be
consistent with the Fort Ord Reuse Plan.

Final EIR
4-130
September 2015
H-63
Table 2-22 has been amended as requested in this comments. See Chapter 5, Changes to
the Draft EIR. See also response to comment U-5.
H-64
H-65
As discussed in Master Response #3: Availability, Reliability, and Yield of Source Water
Supplies to Source Water and Master Response #10: Marina Coast Water District and City of
Marina Water Supply Issues in Chapter 3, Master Responses to Comments, the Proposed
Project would not affect the ability of Marina Coast Water District to implement its RUWAP and
supply the planned recycled water to urban irrigators at the former Fort Ord (also referred to as
the Ord Community). The conclusion in the Draft EIR about the environmental impacts of the
Reduced Seaside Basin Replenishment Alternative being nearly the same as those of the
Proposed Project is correct. As identified on Draft EIR, Table 6-6, some impacts would be
reduced under this alternative compared to the Proposed Project. See also Master Response
#12: Adequacy of Range and Scope of Alternatives in Chapter 3, Master Responses to
Comments.
H-66
Issues and Master Response #12: Adequacy of Range and Scope of Alternatives in Chapter 3,
H-67
See Master Response #12: Adequacy of Range and Scope of Alternatives in Chapter 3,
Master Responses to Comments

Final EIR
4-131
September 2015
Letter I
PENINSULA
MANAGEMENT DISTRICT
June 4, 2015
**provided by e-mail and hand-delivered**
Monterey, CA 93940
SUBJECT: MPWMD COMMENTS ON DRAFT EIR FOR PURE WATER

MONTEREY GROUNDWATER REPLENISHMENT PROJECT;
SCH# 2013051094
Dear Mr. Holden:
This letter from the Monterey Peninsula Water Management District (MPWMD or District)
responds to the Notice of Completion of a Draft Environmental Impact Report (DEIR) by the
Monterey Regional Water Pollution Control Agency (MRWPCA) for the Pure Water Monterey
Groundwater Replenishment Project. The District will rely on the certified EIR for this Project
when it considers new or amended Water Distribution System (WDS) Permits within the Seaside
Groundwater Basin associated with this new source of supply. The District is a partner and cosponsor with MRWPCA, and fully supports the Project. For accuracy, we have a few clarifying
comments, as noted below:
Global. Since 1995, the correct name is the "Carmel Valley Alluvial Aquifer (CV AA),"
which is a specific mapped area adjacent to the Carmel River, rather than the term "Carmel
Valley aquifer" used in the DEIR, which is a more generic term that could refer to upland areas.
The DEIR should only refer to the CVAA to avoid confusion.
Page 2~6, Section 2.3.2 Header. For reference, MPWMD Rule 11 defines the proper
name as "Monterey Peninsula Water Resource System" (not "Resources").
I-1
I-2
Page 2-7, Section 2.3.2.1, MPWMD Description. The District requests that the text be
amended to include the following clarifications; new text is in bold italic:
First paragraph, 3rd line: Add text to read ..... created by the California Legislature in
1977 and endorsed by a public vote in 1978, for the purposes of.....
First paragraph, 9th line: Add text to read ..... and Sand City, the Monterey Peninsula
Airport District, and unincorporated communities ...
Add a new fourth paragraph to read: The Water Management District has played key
roles in several water augmentation projects, including completing planning and
technical studies, engineering and cost analyses, environmental review in compliance
with federal and state regulations, obtaining water rights and construction permits,
5 Harris Court, Building G, Monterey, CA 93940 P.O. Box 85, Monterey, CA 93942-0085
831-658-5600 Fax 831-644-9560 http://www.mpwmd.dst.ca.us
Final EIR
4-132
September 2015
I-3
Bob Holden, MR WPCA

June 4, 2015
Page 2 of2
facility construction and/or project financing.

The District has also analyzed
numerous water supply alternatives at varying degrees of specificity. The District was
an integral partner in development of the Paralta Well in Seaside, Pebble Beach
Reclamation Project, and Aquifer Storage and Recovery (Phases 1 and 2). The District
constructed and owns the two ASR Phase 1 wells at the Santa Margarita site.
Page 2-10, second full paragraph, 1st line. The reference to the "Carmel Valley
Groundwater Basin" is incorrect, and should be replaced by the term "Carmel Valley Alluvial
Aquifer." A June 1984 report by the USGS described the "Carmel Valley Alluvial Groundwater
Basin" but this term has not been used locally for decades. For reference, the District refers to
non-alluvial areas in the Carmel River Basin (watershed) as "Carmel Valley Upland" formations
for record-keeping purposes.
Page 2-27, Section 2.5.5.2, ASR Project. The third paragraph,
MPWMD injection/extraction wells at the Santa Margarita site ....
2nd
line should read .....
I-3
Con't
I-4
I-5
Page 4.18-4, Section 4.18.2.1, MPWMD Overview. Please see comments above for
Section 2.3.2.1. The District requests that the text be amended to include the following
clarifications; new text is in bold italic:
First paragraph, 3rd line: Add text to read ..... created by the California Legislature in
1977 and endorsed by a public vote in 1978, for the purposes of. ....
Last line at bottom: Add text to read ..... not provide water service to retail customers.
However, as described in Section 2.3.2.1, MPWMD either owns or is the financing
entity for certain water supply facilities operated by CaLAm or other agencies. The
Water Management District is responsible for .....
Thank you for your consideration of these comments. I can be reached at d. nldt@mpwtrnd.nel
or 831/658-5650 if you have questions.
Sincerely,
Cc~
Larry Hampson, MPWMD District Engineer

Henrietta Stem, MPWMD Project Manager
David Laredo, MPWMD Counsel
U:\Henri\wp\ceqa\2015\PureWater_DEIR_CommentLetter_20150604.docx
Prepared by Henrietta Stem on 6/4/2015 as reviewed by DS
Mctmi!D

Final EIR
4-133
P'IM'Gw.
T R
September 2015
I-6
LetterI:
I-1
MontereyPeninsulaWaterManagementDistrict
Throughout the Draft EIR, all references to Carmel Valley Aquifer have been update to read
Carmel Valley Alluvial Aquifer in response to this comment. See the revisions to the following
locations in Chapter 5, Changes to the Draft EIR:
Page 2-7 in the first paragraph under 2.3.2.1
Page 2-9 in the first paragraph under 2.3.2.3
Page 2-10 in the second full paragraph on the page and the first full paragraph under
2.3.2.4
Page 2-30 in Table 2-8
Page 4.11-9 in the last sentence
Page 4.18-5 in the first paragraph
I-2
The heading to Section 2.3.2 Monterey Peninsula Water Resources System has been
amended as shown in the changes to page 2-6 of the Draft EIR in Chapter 5, Changes to the
Draft EIR.
I-3
Section 2.3.2.1 MPWMD Description (page 2-7 of the Draft EIR) has been modified in response
to this comment. See the revisions to page 2-7 in Chapter 5, Changes to the Draft EIR.
I-4
Page 2-10 of the Draft EIR has been amended in response to this comment. See the revisions
to page 2-10 of the Draft EIR in Chapter 5, Changes to the Draft EIR.
I-5
The third paragraph of Section 2.5.5.2 Aquifer Storage and Recovery Project has been
amended in response to this comment as shown on the change to page 2-27 of the Draft EIR in
I-6
Section 4.18.2.1 Potable Water Service, under the subheading MPWMD Overview, has been
amended in response to this comment. See the revisions to page 4.18-4 of the Draft EIR in

Final EIR
4-134
September 2015
Letter J
CITY OF MARINA
211 Hillcrest Avenue
Marina, CA 93933
831-884-1278; FAX 831-384-9148
wv. w.ci.marina.ca.us
June 5, 2015

Attention: Bob Holden, Principal Engineer
Via email: gwr@mrwpca.com
Dear Mr. Holden,
Thank you for the opportunity to review the Monterey Regional Water Pollution Control Agency
(MRWPCA) Draft Environmental Impact Report (DEIR) for the Pure Water Monterey
Groundwater Replenishment Project (project); State Clearinghouse number SCH#2013051094.
City of Marina offers the following comments for all land within Marina's boundaries including
former Ford Ord:
1. Considering the MOU between MRWPCA and Marina Coast Water District (MCWD -
October 8, 2014) which, in part, stipulates "MCWD's recycled water right entitlement
may be made contractually available by MCWD to another party (non-specific) and may
J-1
be made available to WRA for CSIP if not utilized by MCWD, or its assignee, in any
given year"; the DEIR is not clear on what mechanism is there to protect City of
Marina's rights to its recycled water amount (both currently produced as well as
additional future wastewater produced in Marina boundaries including the former Fort
Ord area) per its wastewater contribution to the Regional Treatment Plant - City's
recycled water rights concern once/if the RTP's recycled water (City's portion) to
MCWD is sold to another party.
2. The DEIR does not show water rights (both current and future) are being reserved or
protected for the City of Marina Please identify if the proposed project will effect, in
any form, water allocations for City of Marina and the former Fort Ord including
returning gallon for gallon all wastewater generated within City of Marina.
J-2
3. Page 2-15 of the DEIR states that "The trunk main of the (MCWD's) RUWAP system is
coincident with the proposed project's RUWAP Pipeline alignment option"; please
provide details on how the proposed project corresponds and would impact with
MCWD's Regional Urban Water Augmentation Project recycled water distribution
system which has been partially constructed.
J-3
4. Proposed project's construction noise, effects on traffic and transportation, and aesthetic
end results are major concerns for City of Marina. Please address below concerns and
revise the DEIR as requested below:
J-4a
a) The construction activity in Marina's downtown could adversely impact Marina's

downtown businesses. The DEIR is silent in regards to the construction
activities' impacts to Marina's downtown businesses.
Serving a 'Wor(a Cfass Comm unity
Final EIR
4-135
September 2015
Mr. Bob Holden

June 5, 2015
Page
12
b) Table 4.17-1 on Page 4.17-4 of the DEIR references Marina's Crescent Avenue as
having no bike lanes. Please revise the relevant section(s) of the DEIR to include
Marina's Crescent Avenue as having a Class 2 Bike Lanes.
c) Page 4.17-16 of the DEIR indicates that "General work hours are assumed to be
between 7:00AM and 8:00PM, Monday through Saturday. Two work shifts (Shift
1: 7:00AM-3:00PM; Shift 2: 12:00 PM-8:00PM") and Mitigation Measure NV2b stipulates "Construction Hours. (Applies to Product Water Conveyance
Pipelines and Booster Pump Station in the City of Marina). The construction
contractor shall limit all noise-producing construction activities within the City of
Marina to between the hours of7:00 AM and 7:00PM on weekdays and between
9:00AM and 7:00PM Saturdays, except that construction may be allowed until
8:00 PM during daylight savings time". Marina Municipal Code Section
15.04.055 dictates construction hours are restricted between 7am and 7pm
Monday through Saturday. Please revise the relevant sections of the DEIR to
reflect Marina's allowed construction hours. Additionally, do not allow any flood
lights at night. If security is an issue, provide human security rather than lighting.
d) Page 4.17-17 of the DEIR indicates that "Most linear facilities (conveyance
pipelines) would be installed using conventional open-trench construction
techniques. However, trenchless technologies such as boring and jacking,
microtunneling, or horizontal directional drilling may be used where open-cut
trenching is not feasible or desirable (highway crossings, stream and drainage
crossings, and areas with high utility congestion) ". Marina Municipal Code
Section 12.20.100 does not allow trenchless activities under an encroachment
permit. Please revise the relevant section(s) of the DEIR to reflect Marina's
referenced Code.
e) Page 4.1 7.3 0 of the DEIR indicates that "The pipeline would be located primarily
along paved roadway rights-of-way. Construction of the conveyance system
would have the same general sequence ofconstruction for either alignment option
as follows: stake the alignment; where applicable, saw cut the pavement; string
out pipe joints along the alignment as limited by encroachment permit and
specifications". Due to the expected width of the open trench for construction in
Marina streets, please include the restoration to comprise the curb to curb width of
the roadway following City of Marina's design standards. Please revise the
relevant section(s) of the DEIR to reflect this requirement
t) Page 4.17.34 of the DEIR indicates that "Where feasible and appropriate,
construction contractors would install pipelines so as to avoid construction within
vehicle travel lanes and to minimize impacts on roadway capacity and function.
Detailed pipeline alignments and associated construction activities would be
developed during project design. This analysis assumes that pipeline installation
activities could require construction within or adjacent to vehicle travel lanes and
could require temporary lane closures and/or detours.,' A traffic control review
requirement by City of Marina Public Works (prior to issuance of an
encroachment permit) will require that "one-way traffic shall be limited to a
maximum of 5 minutes of traffic delay". Please revise the relevant section(s) of
the DEIR to reflect this requirement.
Final EIR
4-136
September 2015
J-4b
J-4c
J-4d
J-4e
J-4f
Mr. Bob Holden

June 5, 2015
Page
13
g) Mitigation Measure TR.-2 on page S-22 stipulates "After construction is
completed, the same roads shall be surveyed again to determine whether

excessive wear and tear or construction damage has occurred Roads damaged by
project-related construction vehicles shall be repaired to a structural condition
equal to that which existed prior to construction activities." Please revise the
referenced Mitigation Measure to include: shall be repaired to a structural
condition equal to, or greater than, that which existed prior to construction
activities.
5. City of Marina's optional preference for the proposed project is the RUWAP option.
6. City's General Plan requires connectivity of City's Open Spaces through the provision of
wildlife habitat corridors and/or recreational trails (OS); hence, a recreation path to OS is
needed from Windyhill Neighborhood Park to rural Monterey County (south/southeast
side of the park, near Quebrada Del Mar Road) - the proposed project's new RUWAP
trench should be covered for continuance of City of Marina's OS connectivity. Please
revise the relevant section) of the DEIR to reflect this requirement.
7. The new area for 2,100 sq. ft. booster pump station option (Figure 2-31) is adjacent to
City of Marina's corpyard and to CSUMB's planned student dormitory. Mitigation
Measure AE-3 stipulates "Provide Aesthetic Screening for New Above-Ground
Structures". Please revise the referenced Mitigation Measure to include; Screening and
Aesthetic Design Treatments shall be subject to review and approval of the City of
Marina.
8. City of Marina segment of the proposed project requires City's Coastal Development
Permit to be reviewed by City's Planning Commission.
Should you have any questions, please feel free to contact Farhad Mortazavi at (916) 492-2275.
City Manager
City of Marina

Final EIR
4-137
September 2015
J-4g
J-5
J-6
J-7
J-8
LetterJ:
CityofMarina
J-1
J-2
J-3
As noted in the Draft EIR (Section 2.9.1.1 on pages 2-67), the RUWAP Alignment would follow
a portion of the recycled water pipeline alignment of Marina Coast Water Districts previously
approved and partially-constructed Regional Urban Water Augmentation Program Recycled
Water Project. The proposed new product water conveyance pipeline would be located
primarily along paved roadway rights-of-way within urban areas. The Recycled Water Project
was approved by the Marina Coast Water District in 2005; however, only portions of the
recycled water distribution system have been built and no recycled water has been delivered to
urban users. MRWPCA and the Water Management District may pursue a shared easement to
accommodate both pipelines in some portions of the alignment.
In addition, Master Response #10: Marina Coast Water District and City of Marina Water
Supply Issues in Chapter 3, Master Responses to Comments clarifies this information by
stating that MRWPCA is in discussions with Marina Coast Water District (MCWD) regarding the
potential use of the RUWAP alignment for the proposed Product Water Conveyance Pipeline,
and the terms and conditions under which this alignment could be utilized. The description and
potential environmental impacts of constructing and operating the pipeline in this alignment are
discussed in this EIR. The description and potential environmental impacts of MCWD
constructing and operating their RUWAP Recycled Water Project are discussed in the certified
EIR for that project (Marina Coast Water District/DD&A, 2007). The cumulative analysis at the
end of each topical section of Chapter 4 addresses implementation of both projects and finds
that construction of the Proposed Project product water conveyance pipeline and the RUWAP
Recycled Water Project distribution system do not currently have overlapping construction
schedules. For a discussion of source water use/reliability and recycled water yields for
MCWDs urban irrigators, CSIP, and the Proposed Project if both the Proposed Project and the
MCWD RUWAP Recycled Water Project are implemented, see Master Response #10: Marina
Coast Water District and City of Marina Water Supply Issues in Chapter 3, Master Responses
to Comments and Appendix BB.
J-4a
The proposed Product Water Conveyance Coastal and RUWAP alignment options would be
located within the vicinity of Marinas downtown. As shown on Figure 4.12-3, a short segment of
the RUWAP option would be located along Crescent Avenue and would cross Reservation
Road near downtown areas of Marina. In addition, Figure 4.12-3 shows that the Coastal
alignment option would be located along the north side of Del Monte Boulevard from north of
Reservation Road to Highway 1. Construction at these component sites would be located in
close proximity to businesses and thus would result in construction near businesses for up to
one week (i.e., the construction would proceed at approximately 250 feet per day). Typical land
uses in these districts are commercial and industrial uses that are not considered sensitive
receptors for local air quality issues (including pollutant and odor emissions) and for noise and
vibration issues; however, visitor serving accommodations and some medical offices can be
located in these districts. Proposed construction activities associated with this pipeline were
described in Chapter 2 of the Draft EIR (see pages 2-69 through 2-71 and Tables 2-20 and 221 on pages 2-81 through 2-84). The impacts of this construction were evaluated in the Draft
EIR in the following sections (by topic mentioned in this comment): 4.2.4.3 aesthetics (see
pages 4.2-27 through 4.2-34), 4.14.4.3 noise and vibration (see pages 4.14-26 through 4.17-51
with specific analysis of noise impacts of the Product Water Conveyance options on 4.14-33
through 4.14-37), and 4.17.4.3 traffic and transportation (see pages 4.17-27 through 4.17-41).

Final EIR
4-138
September 2015
The potential product water pipelines (Coastal and RUWAP options) proposed to be located
within the roadway rights of way would be located entirely underground and therefore would not
have any noise (see pages 4.14-51 through 4.14-56 of the Draft EIR) or aesthetic (see pages
4.2-34 through 4.2-42 of the Draft EIR) impacts on the City of Marina after construction is
completed. Draft EIR pages 4.17-41 through 4.17-42 describe the less than significant traffic
and transportation impacts of the Proposed Project.
J-4b
Page 4.17-4 of the Draft EIR has been modified in response to this comment. See Chapter 5,
J-4c
Mitigation Measure NV-2b on page 4.14-49 and in Table S-1, page S-20, of the Draft EIR has
been modified in response to this comment. See Table S-1Revised and changes to page 4.1449 in Chapter 5, Changes to the Draft EIR. No nighttime lighting is proposed for construction
of facilities within the City of Marina (and would not be allowed per Mitigation Measure NV-2b).
To address the comment related to operational use of floodlights, Mitigation Measure AE-4 has
been modified as shown in Table S-1Revised and on changes to Draft EIR page 4.2-42 in
J-4d
Page 2-89 (Table 2-22) and page 4.17-17 (fourth bullet) of the Draft EIR have been modified in
response to this comment. See Chapter 5, Changes to the Draft EIR.
J-4e
Mitigation Measure TR-3 on page 4.17-39 and in Table S-1 (page S-22) of the Draft EIR has
been modified to require curb to curb restoration of roadways where applicable as requested in
this comment. See Table S-1Revised and changes to Draft EIR page 4.17-39 in Chapter 5,
J-4f
Mitigation Measure TR-2 on page 4.17-37 and in the Table S-1 (page S-22) of the Draft EIR
has been modified in response to this comment. See Table S-1Revised and changes to Draft
EIR page 4.17-37 in Chapter 5, Changes to the Draft EIR.
J-4g
Mitigation Measure TR-3 on page 4.17-39 and in the Table S-1 (page S-22) of the Draft EIR
has been modified to require curb to curb restoration of roadways where applicable as
requested in this comment. See Table S-1Revised and changes to Draft EIR page 4.17-39 in
J-5
The comment states an opinion about the Citys preference for the RUWAP option. The
comment is referred to decision makers for their consideration.
J-6
In accordance with the description in Chapter 2 of the Draft EIR (pages 2-69 through 2-71), all
proposed Product Water Conveyance pipelines would be constructed below ground and the
trenches will be backfilled to allow continued and/or future use of the land above the alignment
for roadways or trail uses at the discretion of the landowner during easement negotiations.
During the City entitlements/permitting process for the Proposed Project RUWAP alignment (if
the RUWAP alignment is selected as the preferred alignment), the City is able to add the
referenced trench coverage requirement as a condition on the Proposed Project.
J-7
Mitigation Measure AE-3 on page 4.2-40 and in the Table S-1 (page S-7) of the Draft EIR has
been modified to require review by the City of Marina of the screening and aesthetic design
features of the RUWAP Booster Pump Station as requested in this comment. See Table S1Revised and changes to Draft EIR page 4.2-40 in Chapter 5, Changes to the Draft EIR.

Final EIR
4-139
September 2015
J-8
The Citys permitting authority for a Coastal Development Permit and the Planning
Commissions review of the application is acknowledged. The only Proposed Project
component within the Citys jurisdiction for coastal permitting is the Coastal Alignment option for
the Product Water Conveyance pipeline. Table 2-22 has been amended to explicitly describe
this review and permitting authority. See revisions to page 2-89 of the Draft EIR in Chapter 5,

Final EIR
4-140
September 2015
Letter K
Pure Water Monterey Groundwater Replenishment Project
Draft Environmental Impact Report

Public Meeting Comment Card (May 20, 2015)
K-1
K-2
K-3
K-4
Typed version of above comment card:

Name: FARHAD MONTAZAVI, CSG CONSULTANTS
Affiliation: CITY OF MARINA
Email: farhadm@csgengr.com
Mailing Address: 1022 G STREET, SACRAMENTO, CA 95814
Phone Number: (916)492-2275
Comments: WOULD LIKE TO KNOW:
A) PROJECTS EFFECT ON MARINAS WATER ALLOCATION
B) PROJECTS EFFECT ON FORAS WATER ALLOCATION
C) PROJECTS CORRESPONDENCE W/ MCWDS PROJECT
D) CONSIDERING MCWDS RECYCLED WATER RIGHTS, HOW WOULD BE MARINAS RIGHT TO THE AMOUNT OF ITS
RECYCLED WATER PER ITS WASTEWATER CONTRIBUTION TO THE REGIONAL TREATMENT PLANT? WHAT MECHANISM IS
THERE TO PROTECT CITY OF MARINAS AMOUNT OF RECYCLED WATER BASED ON ITS WASTEWATER CONTRIBUTION?

Final EIR
4-141
September 2015
K-1
K-2
K-3
K-4
LetterK: City of Marina, (Farhad Montazi, City of Marina Consultant (Public

MeetingComment)
K-1
K-2
K-3
See the response to comment J-3.
K-4

Final EIR
4-142
September 2015
Letter L
RESOURCE MANAGEMENT SERVICES

440 Harcourt AvenueTelephone (831) 899-6825
Seaside, CA 93955FAX (831) 899-6211
June 5, 2015

5 HaiTis Court, Bldg D
Monterey, CA 93940
Subject:
Draft EIR Pure Water Monterey Groundwater Replenishment Project
Dear Mr. Holden,
The City of Seaside has reviewed the draft EIR for the subject project and offers the following
comments. Attached please find a detailed comment document (Attachment # 1) and a copy of
table S-1 from the EIR with city comments and edits in track changes (Attachment #2).
Of great concern to the City is "Proposed GWR Project Facilities Overview" map showing the
proposed groundwater replenishment facilities located in the City of Seaside. The proposed
facilities shown in this map raise some concerns that are outlined below.
L-A
City staff has met with the MRWPCA project team and have emphasized the need to properly
delineate the proposed project area and obtain entitlements from the City for the land where the
proposed facilities will be located (see attached letters from City of Seaside dated July 2, 2013,
February 6, 2015 and May 8, 2014).
The Proposed GWR Project Facilities Overview map raises concerns that the proposed facilities
within the City may unnecessarily impact large areas of the City's future development areas.
City staff has made recommendations on locating the proposed facilities in a manner that
minimizes the potential impacts to future development. Said map does not appear to follow
these recommendations.
L-B
Furthermore, the City will require the proposed project to obtain use permits for the proposed
work within the City. As this process is intricate and may be lengthy, it is important that the
MRWPCA start the process of obtaining entitlements from the City as soon as possible. It may
be prudent to obtain entitlements from the City prior to finalizing your environmental documents
and design. As of the date of this letter, the MRWPCA has not begun the process to obtain
entitlements for the land for the proposed facilities. City staff encourages MRWPCA to begin
this process by providing detailed information along with a request for entitlement.
L-C
IJ:\Uwrsllnwi/um'vlpfJ/Ja/al.Local\Temp\XPgrpwire\Ltr Dia11a to KcUh GWil comnumt150685_J.docx

Final EIR
4-143
September 2015
City of Seaside Comments

Draft BIR Pure \Vatu Monterey Groundwater Replenislunent l'roject
1une 5, 2015
I look forward to working with your staff to complete this process in a timely manner. Please
contact me if you have any questions or concerns.
Sincerely,
Q~
Diana Ingersoll, PB
Deputy City Manager - Resource Management Services
Copy Mayor and City Council

John Dunn, City Manager
Tim O'Hallorao, City Engineer/Public Works Services Manager
Lisa Brinton, Community Development Director
Attachments
Att #I
Att #2
Att #3
Att #4
Att #5
City of Seaside Comment docwnent

Redlines Table S-1, Summary of Projcct-Levellmpacts and Mitigation Measures
Letter from City of Seaside dated July 2, 2013
Letter from City of Seaside dated May 8, 2014
Letter from City of Seaside dated February 6, 2015

Final EIR
-2- 4-144
September 2015
ATTACHMENT 1
Letter L Attachment
City of Seaside Draft EIR Monterey Peninsula Pure Water Monterey Groundwater
Replenishment Project Comments
June 6, 2015
1.
The DEIR needs to be updated to indicate that the Monterey Regional Water
Pollution Control Agency (MRWPCA) must secure the necessary encroachment
agreements and/or easements for the installation of the pipelines and injection
wells on public agency lands.
2.
On Page S-7, Table S-1, the DEIR shall state that all pipelines placed within the
City of Seaside on General Jim Moore Boulevard shall be placed underground.
The EIR shall also state that MRWPCA shall coordinate with the City of Seaside
on the location of injection wells and booster pumps in order to reduce conflicts
with future commercial/residential development opportunities.
3.
On Page S-7, Table S-1, AE-3: Degradation of Visual Quality of Sites and
Surrounding Areas, the following statement should be deleted None required.
The following mitigation measure is recommended to be adopted due to City of
Seaside comments on the Notice of Preparation and the impact should be
changed from LS to LSM.
4.
On Page S-7, Table S-1, AE-3: Degradation of Visual Quality of Sites and
Surrounding Areas, the impact shown as LS* needs to be defined.
5.
On Page S-7, Table S-1, AQ-1: Construction Criteria Pollutant Emissions, the
impact statement should be changed from LS to LSM. Also, the mitigation
measures should be revised to be mindful not to waste water. See markups on
attached Table S-1 for suggestions.
6.
On Page S-7, Table S-1, AQ-1: Construction Criteria Pollutant Emissions, the
impact statement LSM* needs to be defined.
7.
On Page S-13, Table S-1, GS-2: Construction-Related Soil Collapse and Soil
Constraints during Pipeline Trenching, the impact statement LS should be
modified to LSM such that the backfilling of excavations shall be in accordance
with City of Seaside requirements. Fill materials and compaction requirements
shall be approved by the City Engineer.
8.
On Page S-15, Table S-1, HH-3: Construction of Facilities on Known Hazardous

Materials Site, the impact statement LS may need to be to modified to LSM
for the injection well site. In Table S-1, HH-2, the mitigation measure states For
areas within the Seaside munitions response areas called Site 39 (coincident with
the Injection Well Facilities component). Does this mean that ESCA clearance is
required for this area?
C:\Users\sottmar\Desktop\GWR EIR comments150604.docxPrint 06/05/2015

4-145
Final EIR
L-1
L-2
L-3
L-4
L-5
L-6
L-7
L-8
September 2015
ATTACHMENT 1
Pure Water EIR Comments
City of Seaside
Letter L Attachment
June 5, 2015
Page 2
9.
On Page S-16, Table S-1, GW-4: Operational Groundwater Depletion and Levels:
Seaside Basin, the impact statement LS may need to be to modified to LS/BI
for the injection well site if there are benefits to the Seaside Groundwater Basin.
10.
On Page S-17, Table S-1, GW-6: Operational Groundwater Quality: Seaside

Basin, the impact statement LS may need to be to modified to BI/LSM for the
injection well site to confirm that the injection water would be monitored for
drinking water standards and for constituents of Emerging Concern (e.g. MCL,
MCLG, MRDLG, MRDL, MTL) as described in Table 4.10-10. Also, the term LS*
needs to be defined.
11.
12.
13.
On Page S-17, Table S-1, HS-1: Construction Impacts to Surface Water Quality
due to Discharges, the impact statement LS should be modified to LSM for
the injection well site to confirm that the well development water would be
monitored and treated, if necessary, to abate possible hydrogen sulfide
emissions. Also, please consider disposing of development water at the Seaside
golf course reservoir.
On Page S-17, Table S-1, HS-3: Operational Impacts to Surface Water Quality
due to Well Maintenance Discharges, the impact statement LS should be
modified to LSM for the injection well site to confirm that the well water would
be monitored and treated, if necessary, to abate possible hydrogen sulfide
emissions. Also, please consider disposing of well water at the Seaside golf
course reservoir.
On Page S-19, Table S-1, NV-1: Construction Noise, the impact statement LS
should be modified to LSM for construction areas near residential receptors.
The noise abatement shall be performed in accordance with Seaside Municipal
Code Sections 9.12 (Noise Regulations), 17.30.060 (Noise Standards), and the
Noise Element of the Seaside General Plan. These documents use the community
Noise Equivalent Level CNEL, dB, from 55 to 80.
L-9
L-10
L-11
L-12
L-13
14.
On Page S-20, Table S-1, NV-2: Construction Noise That Exceeds or Violate Local
Standards, the impact statement LS should be modified to LSM for all areas
within the City of Seaside.
L-14
15.
On Page S-23, Table S-1, WW-1: Construction-Related Water Demand, the

impact statement LS should be modified to LSM for all areas within the City
of Seaside. Construction water shall be non-potable water, where feasible.
L-15
16.
On Page S-37, the Proposed GWR Project Facilities Overview map showing the
proposed groundwater replenishment facilities located in the City of Seaside
should be located to minimize impacts to future development. The proposed
product water pipeline should follow the Cal Am alignment in General Jim Moore
Boulevard. The pipeline could either turn up Eucalyptus Road or at a location
near the proposed well field and General Jim Moore Boulevard.
L-16
-2Pure Water Monterey GWR Project

Final EIR
4-146
September 2015
Letter L Attachment
ATTACHMENT 1
City of Seaside
17.
June 5, 2015
Page 3
On Page 2-129, Figure 2-32 Injection Well Site Plan is illegible. Please submit a
legible copy of this map showing or describe the following features;
a. Property lines and habitat buffer zone within the project area.
L-17
b. Existing utility easements (e.g. PG&E).

c. The proposed Cal Am alignment in General Jim Moore Boulevard.
d. Proposed area of potential effect coincident with the proposed product water
pipeline alignment(s).
e. The limits of the entire area of potential effect.
f. Describe what the solid red line means.
g. Alternative pipeline alignments, such as in Eucalyptus Road or at a location
near the proposed well field and General Jim Moore Boulevard.
h. All proposed facilities such as roadways, fences, monitoring wells, injection
well sites and back flushing basins.
18.
On Page 2-130, Figure 2-33 Injection Well Cross Section. Please describe what
is meant by Conceptual GWR Project Site and where this cross section is on a
map.
19.
On Page 2-132, Figure 2-35 Conceptual Site Plan and Schematic of Typical Well
Cluster. Page 2-74 states the back flushing basin [are] in the middle of the
injection well facilities site. Please show where the basins would be located in
this figure. Also, please describe any sanitary facilities, if any, which may be
available on-site.
20.
On Page 2-134, Figure 2-37 Vadose Zone Well Preliminary Design, please
confirm that the bentonite or cement grout seal is sufficient to counteract the
potential expansion in the filter pack.
21.
On Pages 2-79 and 2-135, Figure 2-38 CalAm Distribution System Pipeline:
Eastern Terminus, describes the CalAm pipeline alignment trough Seaside that L-21
is not a part of this project. Please confirm that changes to this alignment would
not affect this EIR. Otherwise, modify the alignment to show distribution piping
in accordance with CalAms proposal.
22.
On Page 4.10-43, Table 4.10-11 Applicable Local Plans, Policies, and Regulations
Hydrology and Water Quality: Groundwater, should a water storage allocation
be obtained from the Seaside Basin Watermaster?
L-22
On Page 4.10-54, the EIR states The volume of water pumped for development
of each well would be about 3,600,000 gallons Please describe how this
L-23
23.
L-18
L-19
L-20

Final EIR
4-147
September 2015
ATTACHMENT 1
City of Seaside
Letter L Attachment
June 5, 2015
Page 4
water would be disposed of. For the deeper wells, hydrogen sulfide emissions is
of concern.
24.
25.
On Page 4.10-54, the EIR states The Injection Well Facilities construction would
not use substantial amounts of groundwater that would not be returned to the
groundwater system and would not impact groundwater volume or levels due to
loss of recharge. And Impacts associated with groundwater depletion, levels
and recharge during the construction of the Proposed Project would be less than
significant. However, the proposed 3.6 million gallons, or 11 AF per well is
more than the de minimus production of 5 AFY as defined by the Seaside Basin
Adjudication (Monterey Superior Court Decision M66343, Paragraph II.C.3).
Therefore, the proposed amount of groundwater used for construction is more
than not substantial and would impact the Seaside Basin as defined by the
Adjudication.
On Page 4.10-88, Figure 4.10-7 Proposed Injection Wells and Existing Vicinity
Wells, shows the proposed monitoring wells located within the development
area. Please confirm that the monitoring well locations shown are approximate
and the monitoring wells and appurtenances would be located to minimize
impacts per the Citys discretion.
26.
Section 4.11-32, the DEIR shall clearly state the post construction requirements
that are applicable to the linear underground portions of the project.
27.
Section 4.11-34 and 4.11-107 reference an outdated Monterey Regional

Stormwater Management Program (MRSWMP) Guidance Document. The DEIR
shall consider and reference the most recent Guidance Document of the
Monterey Regional Stormwater Management Program to meet requirements
established by Order Number 2013-0001-DWQ of the State Water Resources
Control Board.
28.
29.
30.
L-23
Con't
L-24
L-25
L-26
L-27
Under section 4.11-43, the DEIR shall consider and reference Seaside Municipal
Code Section 15.32, Standards to Control Excavation, Grading, Clearing and
Erosion, along with Section 8.46, Urban Storm Water Quality Management and
Discharge Control.
L-28
Under Section 4.2 (Aesthetics), a Mitigation Measure should be included

requiring MRWPCA to provide fencing and landscaping to screen the potential
injection well facilities and booster pumps. The use of chain link fencing and
barbed wire should be discouraged.
L-29
Under the Land Use Section of the DEIR, a brief description on the location and
type of construction storage and parking needs for heavy machinery shall be
specified.
L-30

Final EIR
4-148
September 2015
ATTACHMENT 1
City of Seaside
31.
Letter L Attachment
June 5, 2015
Page 5
Under Mitigation Measure BT-1, it shall be stated that the MRWPCA and/or its
sub-consultants must coordinate with City of Seaside on the location of Injection
Well sites and the removal of sensitive biotic material.
L-31
32.
The DEIR shall specify that the injection wells on the eastern border of the
injection well field would be placed within the 150-foot Habitat border.
L-32
33.
MRWPCA must coordinate with the City of Seaside on the potential location of
Injection Well #5 and #6.
L-33
34.
The EIR shall specify the number of new deep and vadose wells that would be
installed.
L-34
35.
All proposed pipelines that bisect the lands on the north side of Eucalyptus
Avenue must be relocated within the right-of-way on General Jim Moore
Boulevard and Eucalyptus Avenue.
L-35
36.
The DEIR shall state that the design of the buildings for the booster pumps and
for any injection well sites shall consist of Monterey/Mission style architecture
to match the design of the structures that have been built on the Santa Margarita
ASR site and the Seaside Middle School ASR site.
37.
Under Section 2.10.1.3, the DEIR shall state that the MRWPCA would be required
to re-locate any monitor well that has been placed within the interior lands of
the Injection Well field that would interfere with future development
opportunities by the City of Seaside.
38.
On Table 22, replace the reference to the Redevelopment Agency with

Successor Agency.
39.
Under Section 4.2, the DEIR shall state that the installation of injection wells
within the undeveloped lands east of General Jim Moore could adversely affect
the natural terrain and coastal scrub if the injection well facilities and back flush
pit are not properly screened and/or graded to blend with the rolling terrain.
40.
The DEIR shall clarify what type of injection well facility is proposed at the
intersection of General Jim Moore Boulevard and San Pablo Avenue.
L-36
L-37
L-38
L-39
L-40

Final EIR
4-149
September 2015
Letter L Attachment
This Page Intentionally Left Blank

Final EIR
4-150
September 2015
ATTACHMENT 2
Letter L Attachment

SummaryoftheEnvironmental Impact Report
TableS1
SummaryofProjectLevelImpactsandMitigationMeasures
Project Overall
Monterey Pipeline
Injection Well Facilities
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Treatment Facilities at
Regional Treatment Plant
Lake El Estero
Blanco Drain (Pump

Station and Pipeline)
Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Facility Storage and
Recovery
Source Water Diversion and Storage Sites
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
KEY TO ACRONYMS: NI No Impact; LS Less than Significant; LSM Less than Significant with Mitigation; SU Significant and Unavoidable; BI- Beneficial Impact
Aesthetics (AE)
AE-1: Construction Impacts on Scenic Views,
Scenic Resources and Visual Quality of the
Surrounding Areas. Proposed Project construction
would not result in substantial effects on scenic views,
scenic resources or the visual character of the areas
surrounding Proposed Project facilities.
AE-2: Construction Impacts due to Temporary

Light and Glare. Proposed Project construction could
result in substantial, temporary sources of light or
glare.
AE-3: Degradation of Visual Quality of Sites and

Surrounding Areas. Proposed Project components
would not result in a substantial degradation of the
visual character of the project area and its
surroundings.
AE-4: Impacts due to Permanent Light and Glare

during Operations. Operation of Proposed Project
facilities may result in a substantial new source of light
or glare that would adversely affect day or nighttime
views in the area.
LS
NI
LS
LS
NI
LS
NI
LS
NI
LS
NI
LS
NI
NI
LS
LS
NI
LS
LS
LS
NI
NI
LS
LS
NI
LS
NI
LS
NI
LS
NI
LS
LS
LS
LSM
LSLSM
LSM
NI
LS
LSM
LSM
NI
LSM
*
NI
LSM
LS
LS
LSM
LS
NI
LSM
NI
None required.
Mitigation Measure AE-2: Minimize Construction Nighttime Lighting. (Applies to the Injection Well Facilities Site and CalAm Distribution
System: Monterey Pipeline). As part of its contract specifications, MRWPCA shall require its construction contractors to implement site-specific
nighttime construction lighting measures for nighttime construction at the proposed Injection Well Facilities site. The measures shall, at a
minimum, require that lighting be shielded, directed downward onto work areas to minimize light spillover, and specify that construction lighting
use the minimum wattage necessary to provide safety at the construction sites. MRWPCA shall ensure these measures are implemented at all
times during nighttime construction at the Injection Well Facilities site and for the duration of all required nighttime construction activity at this
location.
None required. The following mitigation measure is recommended to be adopted due to City of Seaside comments on the Notice of Preparation:
Mitigation Measure AE-3: Provide Aesthetic Screening for New Above-Ground Structures. (Applies to the following project components: Product
Water Conveyance Coastal Booster Pump Station and Injection Well Facilities). Proposed above-ground features at the Coastal option of
the Booster Pump Station and Injection Well Facilities (at a minimum, at the well clusters and back-flush basin), shall be designed to minimize
visual impacts by incorporating screening with vegetation, or other aesthetic design treatments, subject to review and approval of the City of
Seaside.
Mitigation Measure AE-4: Exterior Lighting Minimization. (Applies to the following project components: Product Water Conveyance Booster
Pump Station - (both Options) and Injection Well Facilities) To prevent exterior lighting from affecting nighttime views, the design and operation
of lighting at the Product Water Conveyance Booster Pump Station - RUWAP and Coastal Options and Injection Well Facilities, shall adhere to
the following requirements:
Use of low-intensity street lighting and low-intensity exterior lighting shall be required.
Lighting fixtures shall be cast downward and shielded to prevent light from spilling onto adjacent offsite uses.
Lighting fixtures shall be designed and placed to minimize glare that could affect users of adjacent properties, buildings, and roadways.
Fixtures and standards shall conform to state and local safety and illumination requirements.
Comment [R1]: Whatdoestheasteriskdenote?
Comment [R2]: Whatdoesthismean?
Air Quality and Greenhouse Gas (AQ)
AQ-1: Construction Criteria Pollutant Emissions.

Construction of the Proposed Project would result in
emissions of criteria pollutants, specifically PM10, that
may conflict with or obstruct implementation of the
applicable air quality plan and may violate an air quality
standard or contribute substantially to an existing or
projected air quality violation in a region that is nonattainment under State ambient air quality standards.
PureWaterMontereyGWRProject
DraftEIR
LSL
SM
LSL
SM
LSL
SM
LSL
SM
LSL
SM
LSLSM
LSL
SM
LSLSM LSLSM
LSL
SM
LSL
SM
S7
LSL LSM*
SM
Mitigation Measure AQ-1: Construction Fugitive Dust Control Plan. (Applies to all Project Component Sites where ground disturbance would
occur.) The following standard Dust Control Measures shall be implemented during construction to help prevent potential nuisances to nearby
receptors due to fugitive dust and to reduce contributions to exceedances of the state ambient air quality standards for PM10, in accordance with
MBUAPCDs CEQA Guidelines.
Water all active construction areas at least twice daily as required with water (preferably from non-potable sources); frequency should be based
on the type of operation, soil, and wind exposure.
Prohibit grading activities during periods of high wind (over 15 mph).
Cover all trucks hauling soil, sand, and other loose materials and require trucks to maintain at least 2 feet of freeboard.
Sweep daily (with water sweepers) all paved access roads, parking areas, and staging areas at construction sites.
Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent public streets;
Enclose, cover, or water daily exposed stockpiles (dirt, sand, etc.);
Replant vegetation in disturbed areas as quickly as possible.
Wheel washers shall be installed and used by truck operators at the exits of the construction sites to the AWT Facility site, the Injection Well
Facilities, and the Booster Pump Station.
Post a publicly visible sign that specifies the telephone number and person to contact regarding dust complaints. This person shall respond to
complaints and take corrective action within 48 hours. The phone number of the MBUAPCD shall also be visible to ensure compliance with
MBUAPCD rules.
April 2015
DeniseDuffy&Associates,Inc.
Comment [R4]: Thereisawatershortagethat

prohibitsnonessentialwateruse.
Comment [R5]: Whynogradingduringwinds
greaterthan15mph?
Comment [R3]: Whatdoesasteriskmeanon
LSM?Also,howissummarydifferentthanthe
parts?
Comment [R6]: Whatisawatersweeper?
Comment [R7]: Isitnecessarytowashwheels
duringnonrainevents?
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
AQ-2: Construction Exposure of Sensitive
Receptors to Pollutant Emissions. Construction of
the Proposed Project would not expose sensitive
receptors to substantial pollutant concentrations.
LS
AQ-3: Construction Odors. Construction of the

Proposed Project would not create objectionable odors
affecting a substantial number of people.
LS
AQ-5: Operational Air Quality Violation. Operation of
the Proposed Project would result in criteria pollutant

emissions, but would not violate air quality standards or
contribute substantially to an existing or projected air
quality violation.
AQ-6: Operational Criteria Pollutant Emissions.
Operation of the Proposed Project would result in a net

increase of criteria pollutants in a region that is nonattainment under State ambient air quality standards,
but the increase would not be cumulatively
considerable.
AQ-7: Operational Exposure of Sensitive Receptors
to Pollutants. Operation of the Proposed Project
would not expose sensitive receptors to substantial
pollutant concentrations.
AQ-8: Operational Odors. Operation of the Proposed
Project would not create objectionable odors affecting
a substantial number of people.
AQ-9C: Operational Greenhouse Gas Emissions.
Operation of the Proposed Project would generate

greenhouse gas emissions, either directly or indirectly.
These emissions would not exceed significance
thresholds such that they would result in a
considerable contribution to significant cumulative
impacts of greenhouse gas emissions and the related
global climate change impacts. In addition, the
Proposed Project would not conflict with applicable
plan, policy or regulation adopted for the purpose of
reducing greenhouse gas emissions.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
LS
NI
NI
NI
NI
NI
LS
None required.
DraftEIR
LS
None required.
AQ-4C: Construction Greenhouse Gas Emissions.

Construction of the Proposed Project would generate
greenhouse gas emissions, either directly or indirectly,
but would not make a considerable contribution to
significant cumulative impacts due to greenhouse gas
emissions and the related global climate change
impacts.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
S8
LS
None required.
LS
None required.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
Biological Resources: Fisheries (BF)
BF-1: Habitat Modification Due to Construction of

Diversion Facilities. Construction of the proposed
Reclamation Ditch and Tembladero Slough diversions
could indirectly result in habitat modifications for
endangered or threatened fish species as a result of
construction activities and dewatering the construction
sites.
NI
LS
BF-3: Reduction in Fish Habitat or Fish Populations

Due to Project Operations. Operation of the
Proposed Project diversions would not reduce the
habitat of a fish species or substantially affect fish
populations.
LS
DraftEIR
LSM
LSM
LSM
LSM
LSM
LSM
NI
LSM
LSM
NI
LSM
NI
NI
NI
LSM
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
LS
NI
LS
LS
LS
LS
LS
LSM
LSM
LS
LS
LSM
Biological Resources: Terrestrial (BT)

BT-1: Construction Impacts to Special-Status
Species and Habitat. Proposed Project construction
NI
BF-2: Interference with Fish Migration. Operation of

the Proposed Project would result in changes in stream
flows that may interfere with fish migration in the
Salinas River and Reclamation Ditch.
may adversely affect, either directly or through habitat

modification, special-status plant and wildlife species
and their habitat within the Project Study Area.
NI
S9
LSM
None required.
LSM LSM
LS
NI
Mitigation Measure BF-1a: Construction during Low Flow Season. (Applies to Reclamation Ditch and Tembladero Slough Diversions)
Conduct construction of diversion facilities during periods of low flow outside of the SCCC steelhead migration periods, i.e. between June and
November, which would be outside of the adult migration period from December through April and outside of the smolt migration period from
March through May.
Mitigation Measure BF-1b: Relocation of Aquatic Species during Construction. (Applies to Reclamation Ditch and Tembladero Slough
Diversions).
Conduct pre-construction surveys to determine whether tidewater gobies or other fish species are present, and if so, implement appropriate
measures in consultation with applicable regulatory agencies, which may include a program for capture and relocation of tidewater gobies to
suitable habitat outside of work area during construction.
Mitigation Measure BF-2a: Maintain Migration Flows. (Applies to the Reclamation Ditch Diversion) Operate diversions to maintain steelhead
migration flows in the Reclamation Ditch based on two criteria one for upstream adult passage in Jan-Feb-Mar and one for downstream
juvenile passage in Apr-May. For juvenile passage, the downstream passage shall have a flow trigger in both Gabilan Creek and at the
Reclamation Ditch, so that if there is flow in Gabilan Creek that would allow outmigration, then the bypass flow requirements, as measured at the
San Jon Gage of the Reclamation Ditch, shall be applied (see Hagar Environmental Science, Estimation of Minimum Flows for Migration of
Steelhead in the Reclamation Ditch, February 27, 2015, in Appendix G-2, of this EIR). If there is no flow in Gabilan Creek, then only the low flow
(minimum bypass flow requirement as proposed in the project description) shall be applied, and these flows for the dry season at Reclamation
Ditch as measured at the San Jon USGS gage shall be met.
Alternately, as the San Jon weir located at the USGS gage is considered a barrier to steelhead migration and the bypass flow requirements have
been developed to allow adult and smolt steelhead migration to have adequate flow to travel past this obstacle, if the weir were to be modified to
allow steelhead passage, the mitigation above would not have to be met. Therefore, alternate Mitigation Measure BF-2a has been developed, as
follows:
Mitigation Measure Alternate BF-2a: Modify San Jon Weir. (Applies to the Reclamation Ditch Diversion) Construct modifications to the existing
San Jon weir to provide for steelhead passage. Modifications could include downstream pool, modifications to the structural configuration of the
weir to allow passage or other construction, and improvements to remove the impediment to steelhead passage defined above.
LSM
See complete text following this table.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
BT-2: Construction Impacts to Sensitive Habitats.

Proposed Project construction may adversely affect
sensitive habitats (including riparian, wetlands, and/or
other sensitive natural communities) within the Project
Study Area.
BT-3: Construction Impacts to Movement of Native

Wildlife and Native Wildlife Nursery Sites. Proposed
Project construction would not adversely affect native
wildlife corridors and wildlife nursery sites.
DraftEIR
NI
NI
LS
LSM
LS
LSM
LS
LSM
LS
NI
LS
NI
LS
LS
LS
LSM
LS
LS
LS
NI
LS
LSM
LSM
LS
LS
S10
Mitigation Measure BT-2a: Avoidance and Minimization of Impacts to Riparian Habitat and Wetland Habitats. (Applies to Tembladero Slough
Diversion, Blanco Drain Diversion, and Product Water Conveyance: Coastal Alignment Option) When designing the facilities at these component
sites, the MRWPCA shall site and design project features to avoid impacts to the riparian and wetland habitats shown in Attachment 8 of
Appendix H and Appendix I, including direct habitat removal and indirect hydrology and water quality impacts, to the greatest extent feasible
while taking into account site and engineering constraints. To protect this sensitive habitat during construction, the following measures shall be
implemented:
Place construction fencing around riparian and wetland habitat to be preserved to ensure construction activities and personnel do not impact
this area.
All proposed lighting shall be designed to avoid light and glare into the riparian and wetland habitat. Light sources shall not illuminate these
areas or cause glare.
In the event that full avoidance is not possible and a portion or all of the riparian and wetland habitat would be impacted, the following
minimization measures shall be implemented:
Impacted riparian and wetland habitat shall be mitigated at a 1:1 replacement-to-loss ratio through restoration and/or preservation. The final
mitigation amounts shall be determined during the design phase but cannot be less than 1:1. It is expected that the mitigation can occur within
the Locke Paddon Lake watershed, along the Tembladero Slough, and within the Salinas River corridor near the Blanco Drain near where
impacts may occur. A Habitat Mitigation and Monitoring Plan (HMMP) shall be prepared by a qualified biologist to mitigate for impacts to riparian
and wetland habitat. The HMMP shall outline the details of a riparian and wetland habitat restoration plan, including but not limited to, planting
plan, success criteria, monitoring protocols to determine if the success criteria have been met, adaptive management protocols in the case that
the success criteria are not met, and funding assurances.
Mitigation Measure BT-2b: Avoidance and Minimization of Impacts to Central Dune Scrub Habitat. (Applies to CalAm Distribution System:
Monterey Pipeline) When designing the Monterey Pipeline, the project proponents shall site and design project features to avoid impacts to the
central dune scrub habitat shown in Attachment 8 of Appendix H, including direct habitat removal, to the greatest extent feasible while taking into
account site and engineering constraints. To protect this sensitive habitat during construction, the following measures shall be implemented:
Place construction fencing around central dune scrub habitat to be preserved to ensure construction activities and personnel do not impact this
area.
All proposed lighting shall be designed to avoid light and glare into the central dune scrub habitat. Light sources shall not illuminate central
dune scrub habitat areas or cause glare.
If full avoidance is not possible and a portion or all of the central dune scrub habitat would be impacted, the following minimization measures
shall be implemented:
Approximately 2.7 acres of central dune scrub habitat could be impacted by the project. Impacted central dune scrub habitat shall be mitigated
at a 1:1 replacement-to-loss ratio through restoration and/or preservation. The final mitigation amounts shall be determined during the design
phase. It is expected that the mitigation can occur onsite or within the immediate vicinity. A Habitat Mitigation and Monitoring Plan (HMMP) shall
be prepared by a qualified biologist to mitigate for impacts to central dune scrub habitat. The HMMP shall outline the details of a central dune
scrub habitat restoration plan, including but not limited to, planting plan, success criteria, monitoring protocols to determine if the success criteria
have been met, adaptive management protocols if success criteria are not met, and funding assurances.
Mitigation Measure BT-2c: Avoidance and Minimization of Construction Impacts Resulting from Horizontal Directional Drilling under the Salinas
River (Applies to Blanco Drain Diversion) The project proponents in coordination with the contractor shall prepare and implement a Frack-Out
Plan to avoid or reduce accidental impacts resulting from horizontal directional drilling beneath the Salinas River. The Frack-Out Plan shall
address spill prevention, containment, and clean-up methodology in the event of a frack out.
LS
None required.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
BT-4: Construction Conflicts with Local Policies,

Ordinances, or Approved Habitat Conservation
Plan. Proposed Project construction would potentially
conflict with local policies or ordinances protecting
biological resources. A conflict may occur if the HMP
plant species within the Proposed Project component
sites on the former Fort Ord that do not require a take
authorization from the Service or CDFW are impacted,
and seed salvage is not conducted. There are no
approved HCPs applicable to the Proposed Project.
LS
BT-5: Operational Impacts to Special-Status
Species. Proposed Project operations would not

adversely affect, either directly or through habitat
and their habitat.
BT-6: Operational Impacts to Sensitive Habitats.
Proposed Project operations may adversely affect

other sensitive natural communities) within and
adjacent to the Project Study Area.
BT-7: Operational Impacts to Movement of Native
Wildlife and to Native Wildlife Nursery Sites.

Proposed Project operations would not adversely affect
native wildlife corridors and wildlife nursery sites.
BT-8: Operational Conflicts with Local Policies,
Ordinances, or approved Habitat Conservation

Plan. Proposed Project operations would not conflict
with local policies or ordinances protecting biological
resources.
LS
LS
LS
LS
LS
LSM
LSM
LS
LS
None required.
LS
LS
Mitigation Measure BT-6. Implementation of Mitigation Measures BT-1a for Avoidance and Minimization of Operational Impacts to Sensitive
Habitat (Applies to Applies to Reclamation Ditch Diversion, Tembladero Slough Diversion, Blanco Drain Diversion, and CalAm Distribution
System: Monterey Pipeline) During operation and maintenance activities, implementation of Mitigation Measures BT-1a, which avoid and
minimize impacts through implementing construction best management practices and monitoring, would reduce potential impacts to sensitive
habitat to a less-than-significant level.
LS
None required.
LS
LS
Mitigation Measure BT-4. HMP Plant Species Salvage. (Applies to Product Water Conveyance: RUWAP and Coastal Alignment Options, and
Injection Well Facilities site within the former Fort Ord only) For impacts to the HMP plant species within the Project Study Area that do not
require take authorization from USFWS or CDFW, salvage efforts for these species shall be evaluated by a qualified biologist per the
requirements of the HMP and BO. A salvage plan shall be prepared and implemented by a qualified biologist, which shall would include, but is
not limited to: a description and evaluation of salvage opportunities and constraints; a description of the appropriate methods and protocols of
salvage and relocation efforts; identification of relocation and restoration areas; and identification of qualified biologists approved to perform the
salvage efforts, including the identification of any required collection permits from USFWS and/or CDFW. Where proposed, seed collection shall
occur from plants within the Project Study Area and topsoil shall be salvaged within occupied areas to be disturbed. Seeds shall be collected
during the appropriate time of year for each species by qualified biologists. At the time of seed collection, a map shall also be prepared that
identifies the specific locations of the plants for any future topsoil preservation efforts. The collected seeds shall be used to revegetate
temporarily disturbed construction areas and reseeding and restoration efforts on- or off-site, as determined appropriate in the salvage plan.
LS
LS
NI
LS
LSM
LS
LS
LS
LS
LS
LS
LS
LS
LS
LSM
LS
LS
LS
LS
LSM
LS
NI
LS
LS
LSM
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
Cultural and Paleontological Resources (CR)
CR-1: Construction Impacts on Historic Resources.

Proposed Project construction may result in a
substantial adverse change in the significance of a

known historic resource as defined in 15064.5 of the
CEQA Guidelines or historic properties pursuant to 36
CFR 800.5.
DraftEIR
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
LSM
S11
LSM
Mitigation Measure CR-1: Avoidance and Vibration Monitoring for Pipeline Installation in the Presidio of Monterey Historic District, and
Downtown Monterey. (Applies to portion of the CalAm Distribution System: Monterey Pipeline) CalAm shall construct the section of the Monterey
Pipeline located on Stillwell Avenue within the Presidio of Monterey Historic District and within W. Franklin Street in downtown Monterey as close
as possible to the centerlines of these streets to: (1) avoid direct impacts to the historic Presidio Entrance Monument, and (2) reduce impacts from
construction vibration to below the 0.12 inches per second (in/sec) peak particle velocity vibration PPV) threshold. If CalAm determines that
the pipeline cannot be located near the centerline of these street segments due to traffic concerns or existing utilities, the historic properties
identified on Table 4.6-2 of this EIR shall be monitored for vibration during pipeline construction, especially during the use of jackhammers and
vibratory rollers. If construction vibration levels exceed 0.12 in/sec PPV, construction shall be halted and other construction methods shall be
employed to reduce the vibration levels below the standard threshold. Alternative construction methods may include using concrete saws instead
of jackhammers or hoe-rams to open excavation trenches, the use of non-vibratory rollers, and hand excavation. If impact sheet pile installation
is needed (i.e., for horizontal directional drilling or jack-and-bore) within 80 feet of any historical resource or within 80 feet of a historic
district, CalAm shall monitor vibration levels to ensure that the 0.12-in/sec PPV damage threshold is not exceeded. If vibration levels exceed the
applicable threshold, the contractor shall use alternative construction methods such as vibratory pile drivers.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
CR-2: Construction Impacts on Archaeological

Resources or Human Remains. Proposed Project
construction may result in a substantial adverse
change in the significance of one known archaeological
resource and to unknown archaeological resources
during construction and/or encounter unknown human
remains.
CR-3: Construction Impacts on Unknown

Paleontological Resources. Proposed Project
construction would not result in damage to or
destruction of unknown paleontological resources.
DraftEIR
LSM
LSM
LS
LSM
LS
LSM
NI
LSM
NI
LSM
NI
LSM
NI
LSM
LS
LSM
NI
LSM LSM
NI
NI
LSM
LSM
LS
LS
S12
Mitigation Measure CR-2a: Archaeological Monitoring Plan. (Applies to the segment of the CalAm Distribution Pipeline through the Presidio of
Monterey and along W. Franklin Street and to the Lake El Estero Diversion Site) Each of the project proponents shall contract a qualified
archaeologist meeting the Secretary of the Interiors Qualification Standard (Lead Archaeologist) to prepare and implement an Archaeological
Monitoring Plan, and oversee and direct all archaeological monitoring activities during construction. Archaeological monitoring shall be
conducted for all subsurface excavation work within 100 feet of Presidio #2 in the Presidio of Monterey, in downtown Monterey on W. Franklin
Street between High and Figueroa Streets; and at potentially sensitive archaeological sites at Lake El Estero. At a minimum, the Archaeological
Monitoring Plan shall:
Detail the cultural resources training program that shall be completed by all construction and field workers involved in ground disturbance;
Designate the person(s) responsible for conducting monitoring activities, including Native American monitor(s), if deemed necessary;
Establish monitoring protocols to ensure monitoring is conducted in accordance with current professional standards provided by the California
Office of Historic Preservation;
Establish the template and content requirements for monitoring reports;
Establish a schedule for submittal of monitoring reports and person(s) responsible for review and approval of monitoring reports;
Establish protocols for notifications in case of encountering cultural resources, as well as methods for evaluating significance, developing and
implementing a plan to avoid or mitigate significant resource impacts, facilitating Native American participation and consultation, implementing a
collection and curation plan, and ensuring consistency with applicable laws including Section 7050.5 of the California Health and Safety Code
and Section 5097.98 of the Public Resources Code;
Establish methods to ensure security of cultural resources sites;
Describe the appropriate protocols for notifying the County, Native Americans, and local authorities (i.e. Sheriff, Police) should site looting and
other illegal activities occur during construction with reference to Public Resources Code 5097.99.
During the course of the monitoring, the Lead Archaeologist may adjust the frequencyfrom continuous to intermittentof the monitoring based
on the conditions and professional judgment regarding the potential to encounter resources. If archaeological materials are encountered, all soil
disturbing activities within 100 feet of the find shall cease until the resource is evaluated. The Lead Archaeologist shall immediately notify the
relevant Proposed Project proponent of the encountered archaeological resource. The Lead Archaeologist shall, after making a reasonable effort
to assess the identity, integrity, and significance of the encountered archaeological resource, present the findings of this assessment to the lead
agency, or CPUC, for the CalAm Distribution Pipeline. In the event archaeological resources qualifying as either historical resources pursuant to
CEQA Section 15064.5 or as unique archaeological resources as defined by Public Resources Code 21083.2 are encountered, preservation in
place shall be the preferred manner of mitigation.
If preservation in place is not feasible, the applicable project proponent(s) shall implement an Archaeological Research Design and Treatment
Plan (ARDTP). The Lead Archaeologist, Native American representatives, and the State Historic Preservation Office designee shall meet to
determine the scope of the ARDTP. The ARDTP will identify a program for the treatment and recovery of important scientific data contained
within the portions of the archaeological resources located within the project Area of Potential Effects; would preserve any significant historical
information obtained; and will identify the scientific/historic research questions applicable to the resources, the data classes the resource is
expected to possess, and how the expected data classes would address the applicable research questions. The results of the investigation shall
be documented in a technical report that provides a full artifact catalog, analysis of items collected, results of any special studies conducted, and
interpretations of the resource within a regional and local context. All technical documents shall be placed on file at the Northwest Information
Center of the California Historical Resources Information System.
Mitigation Measure CR-2b: Discovery of Archaeological Resources or Human Remains. (Applies to all Proposed Project components) If
archaeological resources or human remains are unexpectedly discovered during any construction, work shall be halted within 50 meters (160
feet) of the find until it can be evaluated by a qualified professional archaeologist. If the find is determined to be significant, appropriate mitigation
measures shall be formulated and implemented. The County Coroner shall be notified in accordance with provisions of Public Resources Code
5097.98-99 in the event human remains are found and the Native American Heritage Commission shall be notified in accordance with the
provisions of Public Resources Code section 5097 if the remains are determined to be of Native American origin.
Mitigation Measure CR-2c: Native American Notification. (Applies to all Proposed Project components) Because of their continuing interest in
potential discoveries during construction, all listed Native American Contacts shall be notified of any and all discoveries of archaeological
resources in the project area.
LS
None required.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
Energy and Mineral Resources (EN)
EN-1: Construction Impacts due to Temporary

Energy Use. Proposed Project construction could
result in wasteful or inefficient use of energy if
construction equipment is not maintained or if haul trips
are not planned efficiently. The Proposed Project would
not conflict with existing energy standards.
EN-2: Operational Impacts due to Energy Use.
Proposed Project operations would not result in the
consumption of energy such that existing supplies
would be substantially constrained nor would the
Project result in the unnecessary, wasteful, or
inefficient use of energy resources.
EN-3: Operational Impacts on Mineral Resources.
The Proposed Project would not result in a significant
impact due to the loss of availability of known mineral
resources of value to the region or to the state or to
any locally-important mineral recovery site.
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM LSM
LSM
LSM
Mitigation Measure EN-1: Construction Equipment Efficiency Plan. (Applies to all Proposed Project components) MRWPCA (for all components
except the CalAm Distribution System) or CalAm (for the Cal Am Distribution System) shall contract a qualified professional (i.e., construction
planner/energy efficiency expert) to prepare a Construction Equipment Efficiency Plan that identifies the specific measures that MRWPCA or
CalAm (and its construction contractors) will implement as part of project construction to increase the efficient use of construction equipment.
Such measures shall include, but not necessarily be limited to: procedures to ensure that all construction equipment is properly tuned and
maintained at all times; a commitment to utilize existing electricity sources where feasible rather than portable diesel-powered generators;
consistent compliance with idling restrictions of the state; and identification of procedures (including the use of routing plans for haul trips) that
will be followed to ensure that all materials and debris hauling is conducted in a fuel-efficient manner.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
None required.
Geology, Soils, and Seismicity (GS)

GS-1: Construction-Related Erosion or Loss of
Topsoil. Construction of the Proposed Project would

not result in substantial soil erosion or the loss of
topsoil.
GS-2: Construction-Related Soil Collapse and Soil
Constraints during Pipeline Trenching. Construction
of some Proposed Project pipeline components would
be located on geologic units or soils that are unstable,
or that may become unstable during project
construction, and potentially result in soil instability or
collapse; however, this exposure would not result in a
substantial risk to people or structures.
GS-3: Exposure to Fault Rupture. The Proposed
Project would be located in a seismically active area,

and portions of the Proposed Project may be affected
by fault rupture from an earthquake on local faults;
however, this exposure would not result in a substantial
risk to people or structures.
GS-4: Exposure to Seismic Ground Shaking and
Liquefaction. The Proposed Project would be located

in a seismically active area; however, Proposed Project
operations would not expose people or structures to a
substantial risk of loss, injury, or death involving
exposure to seismic groundshaking and liquefaction.
DraftEIR
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
NI
LS
LS
NI
LSLSM LSLSM
LSL
SM
LSL
SM
None required.
LSL
SM
LSL
SM
LS
LS
None required.Backfilling of excavations shall be in accordance with City of Seaside requirements. Fill materials and compaction requirements
shall be approved by the City Engineer.
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
S13
LS
None required.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
GS-5: Exposure to Coastal Erosion and Sea Level
Rise. The Proposed CalAm Distribution System
Monterey Pipeline would be exposed to substantial soil
erosion as a result of sea level rise.
GS-6: Hydro-Collapse of Soils from Well Injection.
Proposed Project operation would not create a
substantial risk to life or property due to its facilities
being located on a geologic unit or soils that are
unstable, or that would become unstable as a result of
hydro-collapse.
GS-7: Exposure to Expansive and Corrosive Soils.
The Proposed Project would not result in substantial
risks to the public or other facilities due to location on
expansive or corrosive soil types.
NI
NI
DraftEIR
NI
NI
NI
NI
NI
NI
NI
NI
LSM
LSM
Mitigation Measure GS-5: Monterey Pipeline Deepening. (Applies to CalAm Distribution System: Monterey Pipeline only). CalAm shall bury the
Monterey Pipeline segment that is within the pre-determined coastal erosion hazard zone to a depth of five feet below the depth of the 2060, 100year lower profile envelope. The extent of the coastal erosion hazard zone, length of affected pipeline section, and lower profile envelope for this
pipeline segment shall be determined as per the Analysis of Historic and Future Coastal Erosion with Sea Level Rise (ESA-PWA, 2014).
NI
NI
LS
LS
NI
LS
Hazards and Hazardous Materials (HH)

HH-1: Use and Disposal of Hazardous Materials
During Construction. Proposed Project construction

would not create a significant hazard to the public or
the environment through the routine transport, use, or
disposal of hazardous materials during construction.
NI
LS
LS
NI
LS
LS
NI
LS
LS
NI
LS
LS
NI
LS
LS
NI
LS
LS
NI
LS
LS
LS
LS
LS
NI
LS
LS
LS
NI
LS
S14
None required.
LS
LS
LS
None required.
LS
None required.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
HH-2: Accidental Release of Hazardous Materials

would potentially cause upset and accident conditions
involving the release of hazardous materials into the
environment.
HH-3: Construction of Facilities on Known

Hazardous Materials Site. Proposed Project
construction would occur on a known hazardous
materials site pursuant to Government Code Section
65962.5; however, the Proposed Project would not
result in a significant hazard to people or the
environment.
DraftEIR
LS
LS
LS
LS
LS
LSM
LS
LSM
LSM
LSM LSM
LSM
LSM
NI
NI
NI
NI
NI
NI
NI
LS
LS
LSL
SM
LS
LS
S15
LSL
SM
Mitigation Measure HH-2a: Environmental Site Assessment. (Applies to the Lake El Estero Diversion, Product Water Conveyance RUWAP and
Coastal Alignment Options, Injection Well Facilities and the CalAm Distribution System) If required by local jurisdictions and property owners
with approval responsibility for construction of each component, MRWPCA and CalAm shall conduct a Phase I Environmental Site Assessment in
conformance with ASTM Standard 1527-05 to identify potential locations where hazardous material contamination may be encountered. If an
Environmental Site Assessment indicates that a release of hazardous materials could have affected soil or groundwater quality at a project site, a
Phase II environmental site assessment shall be conducted to determine the extent of contamination and to prescribe an appropriate course of
remediation, including but not limited to removal of contaminated soils, in conformance with state and local guidelines and regulations. If the
results of the subsurface investigation(s) indicate the presence of hazardous materials, additional site remediation may be required by the
applicable state or local regulatory agencies, and the contractors shall be required to comply with all regulatory requirements for facility design or
site remediation.
Mitigation Measure HH-2b: Health and Safety Plan. (Applies to the Lake El Estero Diversion, Product Water Conveyance RUWAP and Coastal
Alignment Options, the Injection Well Facilities, and the CalAm Distribution System) The construction contractor(s) shall prepare and implement a
project-specific Health and Safety Plan (HSP) for each site on which construction may occur, in accordance with 29 CFR 1910 to protect
construction workers and the public during all excavation, grading, and construction. The HSP shall include the following, at a minimum:
A summary of all potential risks to construction workers and the maximum exposure limits for all known and reasonably foreseeable site
chemicals (the HSP shall incorporate and consider the information in all available existing Environmental Site Assessments and remediation
reports for properties within -mile using the EnviroStor Database);
Specified personal protective equipment and decontamination procedures, if needed;
Emergency procedures, including route to the nearest hospital;
Procedures to be followed in the event that evidence of potential soil or groundwater contamination (such as soil staining, noxious odors,
debris or buried storage containers) is encountered. These procedures shall be in accordance with hazardous waste operations regulations and
specifically include, but are not limited to, the following: immediately stopping work in the vicinity of the unknown hazardous materials release,
notifying Monterey County Department of Environmental Health, and retaining a qualified environmental firm to perform sampling and
remediation; and
The identification and responsibilities of a site health and safety supervisor.
Mitigation Measure HH-2c: Materials and Dewatering Disposal Plan. (Applies to the Lake El Estero Diversion, Product Water Conveyance
System Options, the Injection Well Facilities, and the CalAm Distribution System) MRWPCA and CalAm and/or their contractors shall develop a
materials disposal plan specifying how the contractor will remove, handle, transport, and dispose of all excavated material in a safe, appropriate,
and lawful manner. The plan must identify the disposal method for soil and the approved disposal site, and include written documentation that
the disposal site will accept the waste. For areas within the Seaside munitions response areas called Site 39 (coincident with the Injection Well
Facilities component), the materials disposal plans shall be reviewed and approved by FORA and the City of Seaside.
The contractor shall develop a groundwater dewatering control and disposal plan specifying how the contractor will remove, handle, and dispose
of groundwater impacted by hazardous substances in a safe, appropriate, and lawful manner. The plan must identify the locations at which
potential contaminated groundwater dewatering are likely to be encountered (if any), the method to analyze groundwater for hazardous
materials, and the appropriate treatment and/or disposal methods. If the dewatering effluent contains contaminants that exceed the requirements
of the General WDRs for Discharges with a Low Threat to Water Quality (Order No. R3-2011-0223, NPDES Permit No. CAG993001), the
construction contractor shall contain the dewatering effluent in a portable holding tank for appropriate offsite disposal or discharge (see Section
4.11, Hydrology and Water Quality: Surface Water, for more information regarding this NPDES permit). The contractor can either dispose of the
contaminated effluent at a permitted waste management facility or discharge the effluent, under permit, to the Regional Treatment Plant.
None requiredESCA clearance shall be obtained prior to construction of facilities.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
HH-4: Use of Hazardous Materials During
Construction Within 0.25-Miles of Schools.
Proposed Project construction would not result in nor

create a significant hazard to the public or the
environment due to handling of hazardous materials or
hazardous emissions within 0.25 mile of a school
during construction.
HH-5: Wildland Fire Hazard during Construction.

Proposed Project construction would not increase the
risk of wildland fires in high fire hazard areas.
During Operation. Proposed Project operations would
not create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials.
HH-7: Operation of Facilities on Known Hazardous
Materials Site. Proposed Project facilities would be

located on a known hazardous materials site; however,
the Proposed Project would not result in a significant
hazard to people or the environment.
NI
NI
LS
NI
LS
LS
LS
LS
LS
NI
LS
LS
LS
NI
LS
LS
LS
NI
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
LS
LS
LS
LS
None required.
LS
LS
LS
None required.
None required.
LS
LS
LS
LS
LS
NI
LS
None required.
Hydrology and Water Quality: Groundwater (GW)

GW-1: Construction Groundwater Depletion,
Levels, and Recharge. Construction of the Proposed
Project components would not deplete groundwater

supplies nor interfere substantially with groundwater
recharge such that there would be a net deficit in
aquifer volume or a lowering of local groundwater
levels.
GW-2: Construction Groundwater Quality. Proposed
Project construction would not violate any water quality
standards or otherwise degrade water quality.
GW-3: Operational Groundwater Depletion and
Levels: Salinas Valley Groundwater Basin.

Operation of the Proposed Project would not deplete
groundwater supplies in the Salinas Valley nor interfere

substantially with groundwater recharge such that there
would be a net deficit in aquifer volume or a lowering of
the local groundwater levels in the Salinas Valley
Groundwater Basin.
Levels: Seaside Basin. Operation of the Proposed

Project would not deplete groundwater supplies in the
Seaside Basin nor interfere substantially with
groundwater recharge such that there would be a net
deficit in aquifer volume or a lowering of the local
groundwater levels in the Seaside Basin.
DraftEIR
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
NI
LS
LS
LS
NI
NI
BI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
LS/
BI
NI
NI
BI
NI
NI
NI
None required.
None required.
LS
None required.
Comment [R8]: Aretherenobeneficialimpacts
duetoinjectionproject?
S16
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
GW-5: Operational Groundwater Quality: Salinas
Valley. Operation of the Proposed Project would not
degrade groundwater quality in the Salinas Valley.
GW-6: Operational Groundwater Quality: Seaside
Basin. Proposed Project operations would not degrade
groundwater quality in the Seaside Basin, including due
to injection of purified recycled water into the basin.
BI
BI
NI
LS
NI
LS
NI
LS
NI
NI
NI
BI
NI
NI
BI/LS *
NI
NI
NI
BI/
LS*
LS
M
NI
NI
BI
NI
NI
BI/
LS*
NI
None required.
None required.Injection water should be monitored for drinking water standards (e.g. MCL, MCLG, MRDLG, MRDL) for contaminants of concern
Comment [R9]: LS*isnotdefined.
Hydrology and Water Quality: Surface Water (HS)

HS-1: Construction Impacts to Surface Water
Quality due to Discharges. Proposed Project
construction involving well drilling and development,

and dewatering of shallow groundwater during
excavation would generate water requiring disposal.
Compliance with existing regulatory requirements
would ensure that water disposal during construction
would not violate any water quality standards or waste
discharge requirements, would not cause substantial
erosion or siltation, and would not otherwise
substantially degrade surface water quality.
Quality due to Earthmoving, Drainage Alterations,

and Use of Hazardous Chemicals. Proposed Project
construction would not violate any water quality
standards or waste discharge requirements, would not

cause substantial erosion or siltation, and would not
otherwise substantially degrade surface water quality
including marine water quality, due to earthmoving,
drainage system alterations, and use of hazardous
chemicals.
HS-3: Operational Impacts to Surface Water Quality
due to Well Maintenance Discharges. Proposed
Project operations would not violate any water quality

due to well maintenance discharges.
HS-4: Operational Surface Water Quality Impacts
due to Source Water Diversions. Proposed Project

diversions would result in water quality benefits due to
diversion and treatment of polluted waters; however,
rapid water fluctuation from diversions at the
Reclamation Ditch could induce erosion and
sedimentation in downstream waters.
DraftEIR
LS
LS
LS
LS
LS
LS
LS
LS
LS
LSL
SM
LS
LSL
SM
LS
None required.Please describe how groundwater would be disposed of (e.g. hydrogen sulfide abatement). Please consider disposing of purge
water in the Seaside Golf Course Reservoir.
Comment [R10]: Whatdoesthismean?
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
NI
NI
NI
NI
NI
NI
LSL
SM
NI
LSM
LS
LS
LS
NI
NI
NI
NI
NI
NI
S17
None required.
LSL
SM
NI
LS
LS
LS
NI
NI
LS
LSM
Please describe how groundwater would be treated to remove contaminants (e.g. hydrogen sulfide abatement).None required. Please consider
disposing of purge water in the Seaside Golf Course Reservoir.
Mitigation Measure HS-4: Management of Surface Water Diversion Operations (Applies to Reclamation Ditch Diversion, only) Rapid, imposed
water-level fluctuations shall be avoided when operating the Reclamation Ditch Diversion pumps to minimize erosion and failure of exposed (or
unvegetated), susceptible banks. This can be accomplished by operating the pumps at an appropriate flow rate, in conjunction with commencing
operation of the pumps only when suitable water levels or flow rates are measured in the water body. Proper control shall be implemented to
ensure that mobilized sediment would not impair downstream habitat values and to prevent adverse impacts due to water/soil interface adjacent
to the Reclamation Ditch and Tembladero Slough.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
HS-5: Operational Marine Water Quality due to
Ocean Discharges. Proposed Project operational
discharges of reverse osmosis concentrate to the
ocean through the MRWPCA outfall would not violate
water quality standards or waste discharge
requirements, or otherwise substantially degrade water
quality.
HS-6: Operational Drainage Pattern Alterations. The
Proposed Project would alter existing drainage patterns
of the component sites by increasing impervious
surfaces, but would not substantially increase the rate
or amount of runoff such that it would: (1) cause
erosion or siltation on- or off-site, (2) cause flooding onor offsite, or (3) exceed the existing storm drainage
system capacity.
HS-7: Operational Carmel River Flows. Proposed
Project operations would result in reduced pumping of
the Carmel River alluvial aquifer resulting in increased
flows in Carmel River that would benefit habitat for
aquatic and terrestrial species.
HS-8: Operational Risks due to Location within 100Year Flood Area. Portions of the Proposed Project
would be located within a 100-year flood hazard area
but would not impede or redirect flood flows.
HS-9: Operational Risks due to Flooding due to
Levee/Dam Failure, or Coastal Inundation. During
operations, some Proposed Project facilities may be
exposed to flooding due to failure of a levee or dam,
sea level rise, and storm surges/tides related to climate
change, but this exposure would not pose a substantial
nor significant risk of loss, injury, or death.
HS-10: Operational Seiche, Tsunami, or Mudflow
Risk. The Proposed Project operations would not
expose people or structures to substantial risk from
flooding due to a seiche, tsunami, or mudflow.
BI
BI
LS
LS
LS
NI
NI
NI
LS
NI
LS
LS
LS
LS
NI
LS
NI
NI
NI
NI
NI
NI
LS
NI
LS
None required.
LS
LS
None required.
LS
LS
None required.
LS
NI
LS
None required.
BI
NI
NI
LS
NI
LS
LS
None required.
LS
NI
LS
NI
LS
NI
LS
NI
LS
NI
NI
NI
LS
NI
LS
NI
LS
NI
LS
NI
LS
NI
LS
LS
LS
NI
LS
BI
LS
NI
LS
BI
LS
NI
LS
BI
LS
NI
BI
None required.
Land Use, Agriculture, and Forest Resources (LU)

LU-1: Temporary Farmland Conversion during
Construction. The Proposed Project would result in a
temporary disruption to agricultural production on
designated prime, unique and statewide important
farmlands during construction, but would not directly or
indirectly convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance to a nonagricultural use.
DraftEIR
NI
LSM
NI
NI
LSM
NI
NI
LS
LS
NI
NI
NI
S18
LSM
Mitigation Measure LU-1: Minimize Disturbance to Farmland. (Applies to the Salinas Treatment Facility and a portion of the Blanco Drain
Diversion) To support the continued productivity of designated Prime Farmland and Farmland of Statewide Importance, the following provisions
shall be included in construction contract specifications:
Construction contractor(s) shall minimize the extent of the construction disturbance, including construction access and staging areas, in
designated important farmland areas.
Prior to the start of construction, the construction contractor(s) shall mark the limits of the construction area and ensure that no
construction activities, parking, or staging occur beyond the construction limits.
Upon completion of the active construction, the site shall be restored to pre-construction conditions.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
LU-2: Operational Consistency with Plans, Policies,
and Regulations. The Proposed Project would have
one or more components that would potentially conflict,
or be inconsistent with, applicable land use plans,
policies, and regulations without implementation of
mitigation measures identified in this EIR.
LU-3: Operational Indirect Farmland Conversion.
The Proposed Project would not change the existing
environment such that Prime Farmland, Unique
Farmland, or Farmland of Statewide Importance is
converted to non-agricultural use.
LSM
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM
NI
LSM LSM
NI
NI
LSM
LSM
NI
LS
NI
All other mitigation measures (see Table 4.12-5 in Section 4.12, Land Use, Agriculture, and Forest Resources).
None required.
Marine Biological Resources (MR)

MR-1: Operational Impacts on Marine Biological
Resources. Operation of the Proposed Project would
not result in substantial adverse effects on candidate,
sensitive, or special-status species and would not
interfere substantially with the movement of any native
resident or migratory fish or wildlife species.
BI
BI
BI
BI
BI
BI
LS
NI
NI
NI
NI
NI
LS
None required.
SU
Mitigation Measure NV-1a: Drilling Contractor Noise Measures. (Applies to Injection Well Facilities) Contractor specifications shall include a
requirement that drill rigs located within 700 feet of noise-sensitive receptors shall be equipped with noise reducing engine housings or other
noise reducing technology and the line of sight between the drill rig and nearby sensitive receptors shall be blocked by portable acoustic barriers
and/or shields to reduce noise levels such that drill rig noise levels are no more 75 dBA at 50 feet. This would reduce the nighttime noise level to
less than 60 dBA Leq at the nearest residence. The contractor shall submit to the MRWPCA and the Seaside Building Official, a Well
Construction Noise Control Plan for review and approval. The plan shall identify all feasible noise control procedures that would be implemented
during night-time construction activities. At a minimum, the plan shall specify the noise control treatments to achieve the specified above noise
Mitigation Measure NV-1b: Monterey Pipeline Noise Control Plan for Nighttime Pipeline Construction. (Applies to CalAm Distribution System:
Monterey Pipeline) CalAm shall submit a Noise Control Plan for all nighttime pipeline work to the California Public Utilities Commission for
review and approval prior to the commencement of project construction activities. The Noise Control Plan shall identify all feasible noise control
procedures to be implemented during nighttime pipeline installation in order to reduce noise levels to the extent practicable at the nearest
residential or noise sensitive receptor. At a minimum, the Noise Control Plan shall require use of moveable noise screens, noise blankets, or
other suitable sound attenuation devices be used to reduce noise levels during nighttime pipeline installation activities.
Mitigation Measure NV-1c: Neighborhood Notice. (Applies to Injection Well Facilities and CalAm Distribution System: Monterey Pipeline)
Residences and other sensitive receptors within 900 feet of a nighttime construction area shall be notified of the construction location and
schedule in writing, at least two weeks prior to the commencement of construction activities. The notice shall also be posted along the proposed
pipeline alignments, near the proposed facility sites, and at nearby recreational facilities. The contractor shall designate a noise disturbance
coordinator who would be responsible for responding to complaints regarding construction noise. The coordinator shall determine the cause of
the complaint and ensure that reasonable measures are implemented to correct the problem. A contact number for the noise disturbance
coordinator shall be conspicuously placed on construction site fences and included in the construction schedule notification sent to nearby
residences. The notice to be distributed to residences and sensitive receptors shall first be submitted, for review and approval, to the MRWPCA
and city and county staff as may be required by local regulations.
Noise and Vibration (NV)
NV-1: Construction Noise. Construction activity

would result in a temporary increase in ambient noise
levels in the vicinity of all Proposed Project sites during
construction that would not be substantial at most
construction sites, except at the Injection Well Facilities
and CalAm Distribution Monterey Pipeline sites.
DraftEIR
LS
LS
LS
LS
LS
LS
LS
LS
LSLSM LSM
LS
SU
S19
April 2015
Comment [R11]: Thenoiseabatementshallbe

performedinaccordancewithSeasideMuniCode
Section9.12(NoiseRegulations),SeasideZoning
OrdinanceSection17.30.060(NoiseStandards),and
theNoiseElementoftheSeasideGeneralPlan.
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
NV-2: Construction Noise That Exceeds or Violate

Local Standards. Construction activity would result in
a temporary increase that at some locations could
generate noise levels in excess of standards
established in the local general plans and/or could
violate local regulations.
NV-3: Construction Vibration. Construction of the

Proposed Project would not expose sensitive receptors
to excessive groundborne vibration.
NV-4: Operational Noise. Operation of the Proposed
Project facilities would potentially increase existing
noise levels, but would not exceed noise level
standards and/or result in nuisance impacts at
sensitive receptors.
NI
NI
LSM
SU
LSM
NI
NI
LSM
LSM
LS
LS
LS
LS
LS
LS
LS
LS
LS
NIL NILSM NILSM SU

SM
Mitigation Measure NV-2a: Construction Equipment. (Applies to Source Water Diversion and Storage Sites Reclamation Ditch, Tembladero
Slough and Blanco Drain, Product Water Conveyance Pipeline segments within the City of Marina and RUWAP Booster Stationentire project)
Contractor specifications shall include a requirement that the contractor shall:
- Assure that construction equipment with internal combustion engines has sound control devices at least as effective as those provided by the
original equipment manufacturer. No equipment shall be permitted to have an un-muffled exhaust.
- Impact tools (i.e., jack hammers, pavement breakers, and rock drills) used for project construction shall be hydraulically or electrically powered
wherever possible to avoid noise associated with compressed air exhaust from pneumatically powered tools. Where use of pneumatic tools is
unavoidable, an exhaust muffler shall be placed on the compressed air exhaust to lower noise levels by approximately 10 dBA. External jackets
shall be used on impact tools, where feasible, in order to achieve a further reduction of 5 dBA. Quieter procedures shall be used, such as drills
rather than impact equipment, whenever feasible.
- The construction contractor(s) shall locate stationary noise sources (e.g., generators, air compressors) as far from nearby noise-sensitive
receptors as possible,
- For Product Water Conveyance pipeline segments within the City of Marina, noise controls shall be sufficient to not exceed 60 decibels for
more than twenty-five percent of an hour,
Mitigation Measure NV-2b: Construction Hours. (Applies to Product Water Conveyance Pipelines and Booster Pump Station in the City of
Marina). The construction contractor shall limit all noise-producing construction activities within the City of Marina to between the hours of 7:00
AM and 7:00 PM on weekdays and between 9:00 AM and 7:00 PM Saturdays, except that construction may be allowed until 8:00 PM during
daylight savings time.
NI
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
LS
NI
None required.
None required.
Population and Housing (PH)

PH-1: Construction-Related Growth Inducement.
Proposed Project construction would result in
temporary increases in construction employment, but
would not induce substantial population growth.
PH-2: Operations and Infrastructure-Related
Growth Inducement. Operation of the Proposed
Project would not directly result in population growth,
and would not indirectly result in inducement of
substantial population growth.
LS
LS
None required.
None required.
Public Services, Utilities, and Recreation (PS)

PS-1: Construction Public Services Demand.
Construction of the Proposed Project would not result
in public service demands for fire and police protection
services, schools, or parks that would result in the
need for new or physically altered facilities to maintain
service capacity or performance objectives.
DraftEIR
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
S20
LS
None required.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
PS-2: Construction Landfill Capacity. Construction
of the Proposed Project would result in generation of
solid waste; however, the solid waste would be
disposed at a landfill with sufficient permitted daily and
overall capacity to accommodate the projects solid
waste disposal needs.
PS-3: Construction Solid Waste Policies and

Regulations. Construction of the Proposed Project
would potentially conflict with state and local statutes,
policies and regulations related to solid waste.
PS-4: Public Services Demand During Operation.

Operation of the Proposed Project would not result in
public service demands for fire and police protection
PS-5: Landfill Capacity for Operations. Operation of
the Proposed Project would not result in adverse
effects on landfill capacity or be out of compliance with
federal, state, and local statutes and regulations
related to solid waste.
LS
LS
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM
LS
LSM LSM
LS
LS
LSM
LSM
None required.
Mitigation Measure PS-3: Construction Waste Reduction and Recycling Plan (relevant to all Proposed Project components). The construction
contractor(s) shall prepare and implement a construction waste reduction and recycling plan identifying the types of construction debris the
Proposed Project will generate and the manner in which those waste streams will be handled. In accordance with the California Integrated
Waste Management Act of 1989, the plan shall emphasize source reduction measures, followed by recycling and composting methods, to
ensure that construction and demolition waste generated by the project is managed consistent with applicable statutes and regulations. In
accordance with the California Green Building Standards Code and local regulations, the plan shall specify that all trees, stumps, rocks, and
associated vegetation and soils, and 50% of all other nonhazardous construction and demolition waste, be diverted from landfill disposal. The
plan shall be prepared in coordination with the Monterey Regional Waste Management District and be consistent with Monterey Countys
Integrated Waste Management Plan. Upon project completion, MRWPCA and CalAm shall collect the receipts from the contractor(s) to
document that the waste reduction, recycling, and diversion goals have been met.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
None required.
Traffic and Transportation (TR)

TR-1: Construction Traffic. Proposed Project
construction would result in a temporary increase in
traffic volumes on regional and local roadways due to
construction-related vehicle trips, which would not
result in conflicts with any applicable plan, ordinance,
or policy establishing measures of effectiveness for
performance of the circulation system.
LS
TR-2: Construction-Related Traffic Delays, Safety
and Access Limitations. Construction activities could

result in temporary traffic delays, safety hazards,
and/or disruption of access.
DraftEIR
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
LS
LS
LS
LSM
LS
NI
LS
LS
LSM
LS
LSM
LSM
S21
LSM
None required.
Mitigation Measure TR-2: Traffic Control and Safety Assurance Plan. Prior to construction, MRWPCA and/or its contractor shall prepare and
implement a traffic control plan or plans for the roadways and intersections affected by MRWPCA construction (Product Water Conveyance
Pipeline) and CalAm shall prepare and implement a traffic control plan for the roadways and intersections affected by the CalAm Distribution
System Improvements (Transfer and Monterey pipelines). The traffic control plan(s) shall comply with the affected jurisdictions encroachment
permit requirements and will be based on detailed design plans. For all project construction activities that could affect the public right-of-way
(e.g., roadways, sidewalks, and walkways), the plan shall include measures that would provide for continuity of vehicular, pedestrian, and
bicyclist access; reduce the potential for traffic accidents; and ensure worker safety in construction zones. Where project construction activities
could disrupt mobility and access for bicyclists and pedestrians, the plan shall include measures to ensure safe and convenient access would be
maintained.
The traffic control and safety assurance plan shall be developed on the basis of detailed design plans for the approved project. The plan shall
include, but not necessarily be limited to, the elements listed below:
General
a. Develop circulation and detour plans to minimize impacts on local streets. As necessary, signage and/or flaggers shall be used to guide
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
TR-3: Construction-Related Roadway Deterioration.

Construction truck trips could result in increased wear-
and-tear on the designated haul routes, which could
result in temporary impacts to performance of the
regional circulation system.
TR-4: Construction Parking Interference.

Construction activities may temporarily affect parking
availability.
DraftEIR
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM LSM
LSM
LSM
NI
NI
NI
NI
NI
LSM
NI
LSM
LSM
NI
LSM
LSM
S22
LSM
vehicles to detour routes and/or through the construction work areas.

b. Implement a public information program to notify motorists, bicyclists, nearby residents, and adjacent businesses of the impending
construction activities (e.g., media coverage, email notices, websites, etc.). Notices of the location(s) and timing of lane closures shall be
published in local newspapers and on available websites to allow motorists to select alternative routes.
Roadways
c. Haul routes that minimize truck traffic on local roadways and residential streets shall be used to the extent feasible.
d. Schedule truck trips outside of peak morning and evening commute hours to minimize adverse impacts on traffic flow.
e. Limit lane closures during peak hours. Travel lane closures, when necessary, shall be managed such that one travel lane is kept open at all
times to allow alternating traffic flow in both directions along affected two-lane roadways; the contractor shall use steel plates or trench backfilling
to restore vehicle access at the end of each workday.
f. Restore roads and streets to normal operation by covering trenches with steel plates outside of normal work hours or when work is not in
progress.
g. Comply with roadside safety protocols to reduce the risk of accidents. Provide Road Work Ahead warning signs and speed control (including
signs informing drivers of state legislated double fines for speed infractions in a construction zone) to achieve required speed reductions for safe
traffic flow through the work zone. Train construction personnel to apply appropriate safety measures as described in the plan.
h. Provide flaggers in school areas at street crossings to manage traffic flow and maintain traffic safety during the school drop-off and pickup
hours on days when pipeline installation would occur in designated school zones.
i. Maintain access to private driveways.
j. Coordinate with MST so the transit provider can temporarily relocate bus routes or bus stops in work zones as deemed necessary.
Pedestrian and Bicyclists
k. Perform construction that crosses on street and off street bikeways, sidewalks, and other walkways in a manner that allows for safe access for
bicyclists and pedestrians. Alternatively, provide safe detours to reroute affected bicycle/pedestrian traffic.
Recreational Trails
l. At least two weeks prior to construction, post signage along all potentially affected recreational trails; Class I, II, and II bicycle routes; and
pedestrian pathways, including the Monterey Peninsula Recreational Trail, to warn bicyclists and pedestrians of construction activities. The signs
shall include information regarding the nature of construction activities, duration, and detour routes. Signage shall be composed of or encased in
weatherproof material and posted in conspicuous locations, including on park message boards, and existing wayfinding signage and kiosks, for
the duration of the closure period. At the end of the closure period, CalAm, MRWPCA or either of its contractors shall retrieve all notice
materials.
Emergency Access
m. Maintain access for emergency vehicles at all times. Coordinate with facility owners or administrators of sensitive land uses such as police
and fire stations, transit stations, hospitals, and schools.
n. Provide advance notification to local police, fire, and emergency service providers of the timing, location, and duration of construction activities
that could affect the movement of emergency vehicles on area roadways.
o. Avoid truck trips through designated school zones during the school drop-off and pickup hours.
Mitigation Measure TR-3: Roadway Rehabilitation Program (applies to all Proposed Project components) Prior to commencing project
construction, MRWPCA (for all components other than the CalAm Distribution System Improvements) and CalAm (for CalAm Distribution
System Improvements) shall detail the preconstruction condition of all local construction access and haul routes proposed for substantial use by
project-related construction vehicles. The construction routes surveyed must be consistent with those identified in the construction traffic control
and safety assurance plan developed under Mitigation Measure TR-2. After construction is completed, the same roads shall be surveyed again
to determine whether excessive wear and tear or construction damage has occurred. Roads damaged by project-related construction vehicles
shall be repaired to a structural condition equal to that which existed prior to construction activities.
Mitigation Measure TR-4: Construction Parking Requirements.(Applies to Product Water Conveyance pipelines (RUWAP and Coastal
Alignments) in Marina and Seaside, and CalAm Distribution System: Transfer Pipeline and Monterey Pipeline). Prior to commencing project
construction, the construction contractor(s) shall coordinate with the potentially affected jurisdictions to identify designated worker parking areas
that would avoid or minimize parking displacement in congested areas of Marina, Seaside, and downtown Monterey. The contractors shall
provide transport between the designated parking location and the construction work areas. The construction contractor(s) shall also provide
incentives for workers that carpool or take public transportation to the construction work areas. The engineering and construction design plans
shall specify that contractors limit time of construction within travel lanes and public parking spaces and provide information to the public about
locations of alternative spaces to reduce parking disruptions.
April 2015
ATTACHMENT 2
Letter L Attachment

TableS1
Project Overall
Monterey Pipeline
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Impact Statement
Reclamation Ditch
Salinas Pump
Station
Salinas Treatment
Recovery
Coastal Alignment
Option
RUWAP Alignment
Option
Mitigation Measures
TR-5: Operational Traffic. Operation and
maintenance of the Proposed Project would result in
small traffic increases on regional and local roadways,
but would not substantially affect the performance of
the regional circulation system.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
Water Supply and Wastewater Systems (WW)

WW-1: Construction-Related Water Demand. The
Proposed Project would result in a temporary increase

in water use due to construction-related demands, but
existing water supplies would be sufficient to serve
construction-related demands and construction
activities would not require new or expanded water
supply resources or entitlements.
WW-2: Construction-Related Wastewater
Generation. The Proposed Project would result in a

temporary increase in wastewater generation due to
demand from construction workers, but existing
wastewater treatment facilities have sufficient capacity
to serve construction-related demands.
WW-3: Operational Water Supply and Entitlements.
Sufficient water supplies are available for operation of
the Proposed Project; prior to construction of each

source water diversion component and prior to
diversion of secondary treated effluent, the project
proponent would obtain applicable water rights,
permits, or agreements.
WW-4: Operational Wastewater Treatment
Capacity. Operation of the Proposed Project would not
result in a determination by the wastewater treatment

provider that would serve the project that it has
inadequate capacity to serve the projects projected
demand in addition to the providers existing
commitments.
LS
LS
LS
LS
LS
LS
LS
LSLSM LSLSM
LSL
SM
LSL
SM
LSL
SM
LSL
SM
None required.Construction water shall be non-potable water, where feasible.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
NI
LS
LS
None required.
None required.
LS
None required.
DraftEIR
S23
April 2015
Letter L Attachment
ATTACHMENT 3
Letter L Attachment
CITY OF SEASIDE
440 Harcourt Avenue
Telephone (831) 899-6736

FAX (831) 899-621 1
Seaside, CA 93955
July2, 2013
Mr. Bob Holden
Monterey, CA 93940
Via email gwr@mrwoca.com
Subject: Notice of Preparation of Environmental Impact Report for the Monterey Peninsula
Groundwater Replenishment Project, May 30,2013
The City of Seaside submits the following comments on the subject document:
I.
The project proposes to recharge the Seaside Groundwater Basin with treated water.
Could the project scope be expanded to also consider recharging the Carmel River as
either as an alternative or as an optiorn?
2.
The project ~roposes to use storm water as a potential water source. On page 131 the
NOP states, 'Other MRWPCA member entitles could also send stomt water to tne
Regi~mal Trlll!tment Plant for usc by t11c 0.\VR P~oj~ct by adding storm water into
ex1stmg p1pehnes, manholes, or pump statons wthm the MRWPCA wastewater
collection system." Does this project propose to revise the MR WPCA NPDES permit to
allow storm water to be conveyed an<! treated by the existing sewer facilities?
3.
The Product Water Conveyance Alig.mment Option 2 (see page 15) would more or Jess
follow Cal-Am's proposed pipeline alignme11t. Since available space is limited and the
installation of two large pipes within llhe public right of way in the City of Seaside
especially in La Salle Avenue, would be very disrul?tive, the installation of MRWPCA
and Cal-Am facilities should be coordinated to mimmize potential impacts.
4.
TI1cre are munerous statement~ in the NOP that are very specific as to project design
details that may adversely constrain llhc final project design. For example, on page 16
the NOI' states "The OWl{ Project would include subsurface groundwater recharge
facilities, including shallow (or vadose zone) and deep injection wells located at mland
and, if feasible, coastal locat1ons withtin the Seaside Basin." Could this statement be
revised to allow some flexibility in the final project design and implementation?
"TI1e 0\VR Project could include subsurface j!roundwater recharge facilities
including shallow (or vadose zone) and deep mjection wells located within the
Seaside Basin."
Another example of modifying the project description to facilitate project
implementation is incorporating the following changes on page 17:
"Coastal Reclrarte Facilities. The coastal recharge facilities would include u_p to
three deep injection wells and up to four vadose zone wells located east ofllghway
1 and wes! of the Bayonet and Black Horse Golf Course, as shown in Figure 2."

Final EIR
4-169
September 2015
ATTACHMENT 3
Letter L Attachment
Notice of Preparation of Environmental Impact Report for the Monterey Peninsula Groundwater Replenishment Project
July I, 20 13
5.
Please clarify which areas and how much land in the City of Seaside are being referred
to as the 'Coastal Recharge Facilities' and the 'Inland Recharge Facilities' as shown in
Figure 2.
6.
The inland recharge facilities location is described on page I 7 as " ... an acceptable
location for the proposed inland recharge facilities, ana the location that currently
appears to be feasiole is a City-planned utility corridor as shown in Figure 2." There is
no City-planned utility corridor in the area shown in Figure 2. Please clarify.
7.
Please clarify where the 4 deep injection wells noted under the description oflnland
Recharge Facilities on Page 17 would be constructed (e.g. area of well containment,
back flush pit, fencing, treatment facility, etc.).
8.
Provide information related to coordination with the City of Seaside regarding traffic
control and construction for the implementation of the underground pipeline within the
City of Seaside.
9.
On page 17, the following statement under 'Coastal Recharge Facilities' is unclear and
should either be removed or clarified. That is, the paragraph is describing the proposed
facilities but this statement seems to be trying to discount their value:
"Due to the shallower water table at the coast, vadose zone wells would be
shallower, and the longDterm ability of the coastal wells to replenish both the Santa
Margarita and Paso Robles aquifers would likely be less than the replenishment
ability ofthe inland wells."
10.
On pa9e 17, the following statement about 'available land' within the City of Seaside
under Coastal Recharge Facilities' is unclear and should clarified. For example,
"The locations for the proposed coastal recharge facilities were determined based on
an analysis of potentially available land and known aquifer characteristics."
II.
Table 1, "Potential Permits and Approvals Required" on page 20 should include Seaside
Highlands Homeowners AssociatiOn if some of the land being considered for Coastal
Injection Wells is within their jurisdiction.
The City of Seaside appreciates the opportunity to comment on the NOP and looks forward to
working with the MRWPCA on the subject project. Please contact the undersigned to discuss any
questions or comments.
S~re~~~
Tim O'Halloran
City Engineer I Public Works Services Manager
Copy Diana Ingersoll,' Deputy City Manager- Resource Management Services
Rick Riedl, Associate Civil Engineer
Rick Medina, Senior Planner

Final EIR
4-170
September 2015
ATTACHMENT 4
RESOURCE MANAGEMENT SERVICES

440 Harcoun Avenue
Seaside, CA 93955
Letter L Attachment
Telephone (831) 899-6215

FAX (831) 899-6311
May 8, 2014
Keith Israel, General Manager
S llnrris Coun, Bldg D
Monterey, CA 93940
Subject:
Proposed Grountlwalfr Rtpltnl$hn~tnt Project
Dear Mr. Israel.

I am in re~ipt of a project overview mop (auachcd) showing the proposed groundwater
replenishment facilities located in the City of Seaside. The proposed facilities shown in this mop
raise some concerns that arc outlined below.
City staff has met with your project team and have emphasized the need to properly delineate the
proposed project area and obtain entitlements from the City for the land where the proposed
facilities will be located. As this process is intricate and may be lengthy, it is important that the
MRWPCA stan the process of obtaining entitlements from the City as soon ns possible. It may
also be prudent to obtain entitlements from the City prior to finalizing your environmental
documents and design.
1 he project overview map also r~isc:s concerns that the proposed facilities within the City may
unn(()cssarily impact a large urea of the City's future development area. City staff has made
recommendations on locating the proposed facilities in a manner that minimi7.CS the potential
The attached map does not apJX.'llr to follow these
impacts to future development.
~mmendations.
As of the date of !his lcncr. the MRWPCA ha< not begun the process to obUiin entitlements for
the land for the proposed facilities. City staff encourages MRWPCA to begin this proces< by
providing detailed information along with a request for entitlement. This will allow the
MRWPCA to begin negotiating with the City Council. This negotiation process will involve
appraisal or the land defined by you in your OJ>plication as well as negotiations with the City
Council on terms and pr'icc.
I look forward to working with your staff to complete this process in a timely manner. Please
contact me if you have any questions or concerns.
\
crely,
~C?~
Tim O' Halloran.

City Engineer/Public Works Services Manager

Final EIR
4-171
September 2015
Letter L Attachment

Final EIR
4-172
September 2015
ATTACHMENT 5
Letter L Attachment
CITY OF SEASIDE RESOURCE MANAGEMENT SERVICES

440 Harcourt Avenue
Telephone (831) 899-6736
Seaside, CA 93955
FAX (831) 899-6211
February 6, 2015
Bob l lolden, Principal Engineer

5 Harris Court, Bldg. D
Monterey, CA 93940
Via Emai l: gwr@mrwpca.com
Subject :
NOP for S upp lement to M ay 2013 Notice of P r eparation of an E I R fo r th e

P ur e Water Monterey G r oundwater Replen ishment Project
Dear Mr. Holden,

This letter transmits comments for the proposed subject project. The City of Seaside respectfully
requests that the following comments be considered for incorporation into the environmental
documents.
I) The proposed monitoring wells wi ll be relocated, if necessary and at the owner's expense,
as soon as the City has approved development plans for the area. The monitoring wells
shall be relocated to be within a proposed future public right of way or an accessible publ ic
area.
2) The proposed monitoring wells should not include any above grade features.
3) Proposed above grade features, such as injection well appurtenances, shall be screened to
minimize visual impacts.
4) The proposed backwash pits should be designed to minimize visual impacts.
5) In the event that new underground piping is required, the City requests that the same route
be used as for the proposed Cal-Am Monterey Peninsula Water Supply Project.
6) MR WPCA shall coordinate with Cal-Am on work within the public right of way within the
City of Seaside, such as pipeline installation, so that all work is perfom1ed concurrently
with Cal-Am.
7) To the greatest extent possible, locate the facilities within the City of Seaside that catmot be
located within a public right of way to areas classified as the Utility Corridor or
Borderlands under the Habitat Management Plan.

Final EIR
4-173
September 2015
Letter L Attachment
ATTACHMENT 5
We look forward to working with your staff to complete the proposed project in a timely maMcr.
You may comnct me or Rick Riedl of my stall' at 831-899-6825 or RRicdJiilci.scaside.ca.us to
discuss any questions or commcms.
City Engineer I Public Works Services Manager

Cc: Diana Ingersoll. Deputy City Manager - Resource Management Services
Lisa Brinton, Community and Economic Development Services Manager
Rick Riedl, Senior Civil Engineer
Rick Medina, Senior l'lanncr

Final EIR
4-174
September 2015
LetterL: CityofSeaside
L-A
The comment asks about siting of the injection wells and facilities. In Figures S-1 and 2-18, a
large area east of General Jim Moore Blvd south of Eucalyptus Road south to near San Pablo
Avenue is shaded, but the facilities will not use all of that land. The shading indicates the area
of potential impact that was used for ensuring that biological and cultural resources field
surveys comprehensively included all potential areas that may contain Injection Well facilities.
As described in Chapter 2 of the Draft EIR (see pages 2-72 through 2-78), most of the site
would only contain up to six 4-foot diameter circular, or 4-foot by 4-foot square pads monitoring
well sites (all at-grade) and driveways to those wells. Specific facilities are shown on Figure 232rev provided herein at a higher resolution than in the Draft EIR. On Figure 2-32rev, the
physical facilities proposed are shown to be located along the edge of the boundary between
City land and Bureau of Land Management land (i.e., all within a 150-foot wide borderland area
adjacent to the property boundary). The only above-grade facilities would be the injection wells,
associated electrical/pump control buildings, and backwash percolation basin (albeit mostly
below grade). Specifically, the backflush basin will extend the width (approximately 150 feet)
within the borderland area next to the parcel boundary, the injection well facilities will extend
approximately 100 feet from the property boundary, and an at-grade roadway/pipeline corridor
would extend approximately 25 feet from the boundary. The monitoring wells would be located
more centrally within the parcel and will ultimately each only cover only a 4 foot by 4 foot
surface feature on the ground. Specific locations can be adjusted to correspond with planned
public rights-of-way to the extent that they are known at the time of construction, and will be
subject to City of Seaside and State Water Resources Control Board - Division of Drinking
Water approval. See Figure 2-32rev in Chapter 5, Changes to the Draft EIR.
L-B
See the response to comment L-A.
L-C
The project proponents will work with the City of Seaside to obtain all necessary approvals.
L-1
The Draft EIR indicates that the MRWPCA intends to secure encroachment agreements and/or
easements from the City of Seaside. The property is currently owned by the Fort Ord Reuse
Authority; therefore, their approval would be needed, also. See Draft EIR at page 2-89, Table 222.
L-2
The text on page S-7 of the Draft EIR, the last column of line item for AE-3 Degradation of
Visual Quality of Sites and Surrounding Areas and on page 4.2-40 of the Draft EIR has
been modified as requested in this comment and others. See changes to pages S-7 and 4.2-40
of the Draft EIR in Chapter 5, Changes to the Draft EIR.
L-3
The text on page S-7 of the Draft EIR has been modified as shown above in response
comment L-2. It is not necessary to modify the impact determination in Table S-1 on page S-7
of the Draft EIR. The conclusions for Impact AE-3 need not be changed because the analysis
and conclusions on pages 4.2-34 through 4.2-40 of the Draft EIR appropriately use the
operational impacts approach described on page 4.2-25 through 4.2-26 of the Draft EIR to
conclude that the Proposed Project would not substantially degrade the visual character or
quality of the surrounding area. Thus, the Proposed Project would have a less-than-significant
impact on the visual character of this project component area and its surroundings due to the
moderate visual change/contrast. Regardless of this significance determination, the MRWPCA
is willing to implement Mitigation Measure AE-3 (as modified in this Final EIR) to address the
aesthetic and visual quality concerns of the City of Seaside. See Table S-1Revised and
changes to page 4.2-40 in Chapter 5, Changes to the Draft EIR.

Final EIR
4-175
September 2015
L-4
Text on page S-7 of the Draft EIR has been modified to delete the * from the second to last
column of line item for AE-3 Degradation of Visual Quality of Sites and Surrounding Areas.
L-5
Table S-1 on page S-7 of the Draft EIR has been modified to explain why individual project
components would have a less-than-significant impact, while the project as a whole may result
in a significant impact that requires mitigation measures. In addition, Mitigation Measure AQ-1
(on pages S-7 and page 4.3-25 of the Draft EIR) has been modified as requested to require
minimization of water use. See Table S-1Revised and changes to Draft EIR page 4.3-25 in
L-6
Below Table S-1 on page S-7 of the Draft EIR, a footnote has been added in response to this
comment. Specifically, under impact AQ-1, the implementation of each component when
looked at individually would not a have a significant impact. It is only when all components are
implemented together (with overlapping construction schedules) that a significant impact would
occur, thus triggering mitigation to reduce the impact to less-than-significant level. See the
Table S-1Revised in Chapter 5, Changes to the Draft EIR.
L-7
For components within the City of Seaside, Impact GS-2 related to construction soil collapse
and soil constraints during pipeline trenching was found as a less-than-significant impact due to
the requirements in the State Building Code and City codes described on page 4.8-16 of the
Draft EIR, namely compliance with Chapter 15.32 (Standards To Control Excavation, Grading,
Clearing and Erosion) and Chapter 15.34 (Digging and Excavation on the Former Fort Ord).
During review of the City grading permit, the City of Seaside may condition the project to
receive approval from the City Engineer for fill material and compaction. No additional
mitigation is needed.
L-8
The Draft EIR evaluates the potential impacts related to construction on known hazardous
materials sites in Impact HH-3 and it evaluates the potential impacts related to a release of
hazardous materials (including those hazardous materials found on a construction site) in
Impact HH-2. The Draft EIR concludes that the Proposed Project would result in less-thansignificant impacts related to its location on the known hazardous materials site, Seaside
Munitions Response Area (MRS-15 SEA 03 and SEA 02) for the Superfund National Priority
List cleanup (Impact HH-3) and the potential for a risk associated with exposure to
contaminants at that site during construction (see page 4.9-40 of the Draft EIR) because:
In 2008, the Seaside Munitions Response Area (Phase II) removal action was
completed in accordance with the Environmental Services Cooperative Agreement.
This included significant grubbing and clearing in order for the land to be deemed
suitable. Therefore, the parcels on which the Injection Well Facilities are sited have
already undergone remediation actions.
For any ground disturbance activities, MRWPCA and its contractors must comply with
the Fort Ord Reuse Authority Right-of-Entry process and the City of Seaside Municipal
Code Chapter 15.34 (i.e., the Ordnance Remediation District Regulations of the City
in Ordinance 924). This ordinance establishes special standards and procedures for
digging and excavation on those properties in the former Fort Ord military base which
are suspected of containing ordnance and explosives (also called munitions and
explosives of concern). This ordinance requires that a permit be obtained from the City
for any excavation, digging, development, or ground disturbance of any type involving
the displacement of ten cubic yards or more of soil. The permit requirements include
providing each site worker a copy of the Ordnance and Explosives Safety Alert;
complying with all requirements placed on the property by an agreement between the
City, FORA, and DTSC; obtaining ordnance and explosives construction support;
ceasing soil disturbance activities upon discovery of suspected ordnance and notifying

Final EIR
4-176
September 2015
the Seaside Police department, the Presidio law enforcement, the Army and DTSC;
coordinating appropriate response actions with the Army and DTSC; and reporting of
project findings. Compliance with existing regulations for construction work at this site
would reduce the potential impact of encountering unexploded ordnance by
construction workers to less-than-significant.
The conclusions for Impact HH-3 need not be changed because the analysis and conclusions
above are appropriate and adequate. Regarding Impact HH-2, the Draft EIR concludes that the
Proposed Project construction activities, including at the Injection Well Facilities site, would
potentially cause upset and accident conditions involving the release of hazardous materials
into the environment. Soil disturbance during construction could disperse unknown
contaminants at the Injection Well Facilities site (if discovered during construction) into the
environment and expose construction workers and the public to hazards. This is considered a
potentially significant impact. Implementation of Mitigation Measures HH-2a (Environmental
Site Assessment), HH-2b (Health and Safety Plan), and HH-2c (Materials Disposal Plan) would
reduce the impact to a less-than-significant level. The comment references a component of
Mitigation Measure HH-2c, regarding the Seaside munitions response areas called Site 39.
That text was included in the measure to ensure the mitigation was consistent with the
requirements in the Seaside Municipal Code Chapter 15.34. The Draft EIR appropriately finds
that the mitigation measures would reduce the impact to a less-than-significant level.
L-9
Although the Proposed Project provides benefits to the yield of the Seaside Groundwater Basin
by supplying water for recharge, the associated increase in extraction will produce both higher
and lower groundwater levels near some producing wells during some periods of time.
Although the short-term lowering of water levels is not considered to be a significant impact
based on the approach to determining significance (i.e., thresholds) for the groundwater
depletion, levels, and recharge in the Seaside Groundwater Basin (see pages 4.10-47 through
4.10-48), a quantifiable beneficial impact regarding water levels was not possible to calculate.
With regard to the quantity of groundwater in the basin, the Proposed Project is considered
neutral because all of injected water is subsequently extracted. The Proposed Project neither
substantially removes nor adds to overall groundwater in storage. Based on this information,
the impact statement for GW-4 of less than significant (LS) has not been modified to
LS/beneficial impact (BI) on Table S-1 and the impact of LS is considered to be appropriate.
L-10
It is not necessary to modify the impact statement in Table S-1 on page S-17 of the Draft EIR
(GW-6: Operational Groundwater Quality: Seaside Basin) from BI/LS to BI/LSM for the
injection site based on the water quality monitoring that would be performed as required by
regulations. The monitoring required pursuant to the Final Groundwater Replenishment
Regulations would ensure the impacts on groundwater quality remain less than significant.
Compliance with the regulations is mandatory, and does not need to be included as a mitigation
measure. Regarding the request to define LS* on page S-17, the text of the Draft EIR has been
updated as requested and as shown in Table S-1Revised in Chapter 5, Changes to the Draft
EIR. Specifically, the * on the LS signifies: For concentrations of total dissolved solids and
chloride, the impact would be beneficial; for all other water quality parameters, the impact would
be less than significant.
L-11
Land discharge of development water will be conducted in compliance with RWQCB Order
monitoring requirements (General Order 2003-003) and does not require additional mitigation
for possible hydrogen sulfide (H2S) emissions. Thus, the impact statement HS-1 in Table S1Revised in the Final EIR has not been revised from LS to LSM. For more information on
the discharge process and H2S in discharged development water, see Master Response #7:
Well Development/Construction Water Use and Discharge and Master Response #12:
Adequacy of Scope and Range of Alternatives in Chapter 3, Master Reponses to Comments.

Final EIR
4-177
September 2015
L-12
Similar to previous comments, no treatment of the development water will be needed. Because
the backflush operation will pump the most-recently injected water back through the well, the
presence of naturally occurring H2S is not anticipated.
Discharge associated with well maintenance (backflushing) would occur during Project
operation to maintain injection capacity in active injection wells, but these operations would not
require monitoring or mitigation for hydrogen sulfide emissions as discussed in Master
Response #8: Well Maintenance and Backflushing Water Amounts and Discharge. Thus, the
impact statement HS-3 in Table S-1Revised in the Final EIR has not been revised from LS to
LSM. For additional information, See Master Response #8: Well Maintenance and
Backflushing Water Amounts and Discharge and Master Response #12: Adequacy of Scope
and Range of Alternatives in Chapter 3, Master Reponses to Comments.
L-13
In its discussion of Impact NV-1 on Summary Table S-1 (and on pages 4.14-38 through 4.14-43
of the Draft EIR), the Draft EIR identified that the proposed Injection Well Facilities would have
a significant impact requiring mitigation (specifically, Mitigation Measures NV-1a and NV-1c).
The Proposed Project pipelines within the City of Seaside (both options for Product Water
Conveyance and the Transfer Pipeline component of the CalAm Distribution System) would
have a less-than-significant impact on residential land uses in the City of Seaside because
pipeline construction would occur for four days or less in proximity to any one receptor and
would be limited to daytime hours. This is consistent with the approach and threshold for this
impact on pages 4.14-22 through 4.14-23 of the Draft EIR; specifically, an exterior noise level
that exceeds 70dBA Leq during the daytime is the threshold for substantial construction noise
where the duration of construction exceeds two weeks.
L-14
The Draft EIR presents the referenced City of Seaside noise standards (Chapter 9.12 of the
Municipal Code and Section 17.30.060 of the Zoning Ordinance) on pages 4.14-17 and 4.4-18,
and the City of Seaside Noise Element policies and implementation plans on page 4.14-20. The
analysis of construction noise impacts related to compliance with local general plans and/or
local regulations (Impact NV-2) on pages 4.14-43 through 4.14-49 of the Draft EIR found that
the Proposed Project would not violate the Citys noise standards or violate local regulations
because of the following exceptions/exemptions:
Chapter 9.12 of the City of Seaside Municipal Code establishes noise regulations within
Seaside. Pursuant to section 9.12.030.D: operation or use of a range of tools and power
equipment and any construction, demolition, excavation, erection, alteration, or repair activity is
declared to be unlawful and a nuisance if it occurs before 7:00 AM or after 7:00 PM daily
(except Saturday, Sunday, and holidays when the prohibited time shall be before 9:00 AM and
after 7:00PM) unless authorized in writing by a building official. Section 9.12.040D exempts
activities on or in publicly owned property and facilities, or by public employees or their
franchisees, while in the authorized discharge of their responsibilities, provided that such
activities have been authorized by the owner of such property or facilities or its agent or by the
employing authority. Seasides Municipal Code Section 17.30.060 of Title 17 (Zoning
Ordinance) establishes noise standards to implement policies of the Noise Element of the
General Plan and provides noise mitigation standards that are intended to protect the
community health, safety and general welfare by limiting exposure to the unhealthful effects of
noise. Section 17.30-060B3 states: No use, activity, or process shall exceed the maximum
allowable noise levels established in this section, except for construction, maintenance,
and/or repair operations by public agencies and/or utility companies or their contractors that are
serving public interest and/or protecting the public health, safety, and general welfare .
Because the Proposed Project will be undertaken by a public agency with authorization by the
applicable land owner, these exemptions apply to project-related construction activities.

Final EIR
4-178
September 2015
L-15
The Draft EIRs conclusion that Impact WW-1: Construction-Related Water Demand would be
less than significant is appropriate. A one-time water use of 70 acre-feet that would primarily be
non-potable would not be considered a significant impact in accordance with the thresholds of
significance. Specifically, existing water supplies would be sufficient to serve constructionrelated demands and the use would not require new or expanded water supply resources or
entitlements. However, Mitigation Measure AQ-1 (in Table S-1 and on page 4.3-25 of the Draft
EIR) has been amended as requested in this comment. See Table S-1Revised and changes to
page 4.3-25 in Chapter 5, Changes to the Draft EIR.
L-16
The comment suggests an alternative alignment for the Product Water Conveyance pipeline
between General Jim Moore Boulevard and the Injection Well Facilities. Alternatives to the
proposed alignment were evaluated during project planning (including use of Eucalyptus Road
from its intersection with General Jim Moore Boulevard to the Injection Well Facilities well
cluster sites). The currently proposed alignment was selected for analysis because it would
result in the least environmental impacts and would meet all of the project objectives. The
suggested alternative that would follow General Jim Moore farther south would have increased
environmental impacts relative to the Proposed Project alignment that follows an existing
access road to the Blackhorse Reservoir site that currently contains underground water supply
pipelines and then to Eucalyptus Road. Increased construction impacts would include greater
and more severe dust, air pollution, noise, hydrology and water quality, and
traffic/transportation impacts on sensitive receptors, such as residences in the City of Seaside
and the Seaside Middle School. During operation these alternative alignments would have
greater electricity demand (and the associated greenhouse gas emissions to produce the
electricity) due to the more steep and varying hydraulic grade lines. (Cole, 2015) For these
reasons, the suggested alternative pipeline routes are not considered in detail in the EIR. See
Master Response #12: Adequacy of Scope and Range of Alternatives in Chapter 3, Master
Reponses to Comments.
L-17
Figure 2-32 of the Draft EIR has been replaced with a more legible version showing property
lines and habitat buffer zones, the proposed CalAm alignment in General Jim Moore Boulevard,
the proposed area of potential effect, limits of the area of potential effect, a clear description of
the purpose of the solid red line, alternative pipeline alignments, and clear markings of the
locations of all Proposed Project facilities. See Figure 2-32rev in Chapter 5, Changes to the
Draft EIR. Additionally, the figure clearly identifies the backflush basin, per comment L-19. The
Figure does not include alternative pipeline alignments for the reasons stated in the response
to comment L-16, and in Master Response #12: Adequacy of Scope and Range of Alternatives
in Chapter 3, Master Reponses to Comments.
L-18
The label Conceptual GWR Project Site on Figure 2-33 (Injection Well Cross Section) in the
Draft EIR reflects the conceptualization of the Proposed Project onto a geologic cross section.
Although the actual cross section line does not cross the Injection Well Facilities site directly,
the general area and two conceptual injection wells (a deep injection well and a vadose zone
well) are projected onto the line. The wells are not projections of any particular injection well
site nor are they presented to scale across the generalized area; rather, the figure provides a
conceptualization of the subsurface relationships between the Injection Well Facilities site,
Proposed Project wells, geologic units, aquifers, and existing wells. The cross section location
is shown on Figure 2 of Appendix L of the Draft EIR. The cross section location has also been
added to Figure 2-32rev for the Final EIR in green, designated with the letters A-A. See
L-19
Figure 2-35 is a conceptual site plan for one of the four injection well facility clusters and the
backflush basin is not proposed to be located at this site. Figure 2-32rev (as modified in this
Final EIR, see Chapter 5, Changes to the Draft EIR) shows the proposed location of the
backflush basin (i.e., centrally located between injection well cluster #2 and #3). No sanitary
facilities are proposed at the Injection Well Facilities site because individuals accessing the site
for ongoing maintenance activities would only be at the site for several hours at most.

Final EIR
4-179
September 2015
L-20
The comment references the vadose zone well design shown on Figure 2-37 in the Draft EIR
and requests confirmation that the bentonite or cement grout seal is sufficient to counteract the
potential expansion of the filter pack. The comment appears to be referring to the potential for
entrapped air to expand upwards as the filter pack is wetted by the injected water. The
expansion of entrapped air could exert pressure on the filter pack/seal interface, and potentially
compromise the surface seal. However, such pressure would not occur. Given the high
permeability of the upper Aromas Sands, any displaced air would expand out into the
surrounding sediments without exerting pressure upward on the seal. In addition, given the
relatively low rates of injection needed to accommodate the Proposed Project recharge in the
vadose zone wells, the water level in the filter pack is not expected to rise close to the base of
the seal.
Nonetheless, two measures are being implemented to guard against potential impacts from
entrapped air. As described on pages 25 to 26 and 33 to 35 of Appendix L of the Draft EIR and
shown on Figure 2-37 of the Draft EIR, an air vent line has been incorporated into the vadose
zone well design. This line would allow escape to the surface of any upward movement of air
that could pressurize the base of the seal. To further prevent entrained air in the filter pack, the
screen and filter pack will be wetted slowly from the bottom of the well via an educator pipe,
also shown in the design on Figure 2-37.
L-21
The alternatives analysis in Chapter 6 of the Draft EIR describes and evaluates the current,
applicant-proposed, alternative pipeline alignments for the CalAm Distribution System Pipelines
(referred to as the Transfer and Monterey Pipelines) at a project-level on pages 6-36 through 652. See Master Response #11: Proposed Projects Relationship to the Proposed Monterey
Peninsula Water Supply Project and Master Response #12: Adequacy of Range and Scope of
L-22
Table 4.10-11 Applicable Local Plans, Policies, and Regulations Hydrology and Water
Quality: Groundwater on page 4.10-43 of the Draft EIR has been amended through the
insertion of the following footnote in response to this comment as shown in Chapter 5,
Changes to the Draft EIR. The footnote states that a water storage agreement with the
Seaside Basin Watermaster would be required to implement the Proposed Project.
L-23
Regarding the disposal of development water and potential hydrogen sulfide (H2S) emissions,
See Master Response #7: Well Development/Construction Water Use and Discharge in
L-24
Per Draft EIR page 4.10-54, the development water is not being pumped for use and would be
returned to the basin via surface discharge with minimal loss. See Master Response #7: Well
Development/Construction Water Use and Discharge in Chapter 3, Master Responses to
Comments for more information on this issue.
L-25
The monitoring well locations shown are approximate and the lead agency understands that
monitoring wells and appurtenances must be located to minimize impacts in consultation with
the City of Seaside. Figures 2-32 and 4.10-7 have been amended in response to this comment.
See Figure 2-32rev and Figure 4.10-7rev at the end of Chapter 5, Changes to the Draft EIR.
L-26
Post-Construction Requirements for linear underground portions of the project are described on
page 4.11-35 of the Draft EIR. In accordance with Resolution R3-2013-0032 c, the linear
underground portions of the Proposed Project if considered alone would be not be considered
Regulated Projects as stated on page 2 of Attachment 1 to Resolution R3-2013-0032c. All of
the linear underground portions of the project would be constructed such that the ground
surface disturbance would be restored to pre-construction conditions as stated on page 4.11-87
of the Draft EIR.

Final EIR
4-180
September 2015
L-27
Pages 4.11-34 and 4.11-107 of the Draft EIR have been edited to refer to the Monterey
Regional Stormwater Management Program website at: http://montereysea.org/programdocuments/ for current guidance documents. See Chapter 5, Changes to the Draft EIR.
L-28
Page 4.11-43 of the Draft EIR has been amended to refer to the Seaside Municipal Code
Section 15.32, Standards to Control Excavation, Grading, Clearing and Erosion, along with
Section 8.46, Urban Storm Water Quality Management and Discharge Control. See Chapter
5, Changes to the Draft EIR. Pages 4.8-16, 4.8-31, and 4.8-34 of the Draft EIR refer to the
requirements of Seaside Municipal Code Section 15.32 and on pages 4.11-50 and 4.11-51 also
refers to Section 8.46, Urban Storm Water Quality Management and Discharge Control.
L-29
On page 4.2-40, the Draft EIR includes a mitigation measure AE-3 that requires the project
proponent to screen all of the proposed above-ground features in the City of Seaside
(specifically, at the Coastal option of the Booster Pump Station and at the well clusters and
back-flush basin of the Injection Well Facilities component), to be designed to minimize visual
impacts by incorporating screening with vegetation, or other aesthetic design treatments,
subject to review and approval of the City of Seaside. This mitigation measure has been
amended in response to this comment and other comments from the cities of Marina and
Seaside. See Chapter 5, Changes to the Draft EIR.
L-30
The Draft EIR on page 4.12-29 has been amended to describe the location and type of
construction storage and parking needs for heavy machinery. This information is on pages 2-80
through 2-82 of the Draft EIR and is now repeated in the land use section as requested. See
L-31
Mitigation Measure BT-1a in the Draft EIR (in Table S-1Revised and on page 4.5-76) has been
amended to include the language requested in this comment. The language clarifies that the
project proponent and/or its contractors will coordinate with the City of Seaside on the location
of injection well sites and the removal of sensitive biotic material. See Table S-1Revised and
changes to page 4.5-76 in Chapter 5, Changes to the Draft EIR
L-32
The Draft EIR shows the location of the injection wells as on the eastern border of the site
within the 150 foot Habitat border in Figures 2-18, 2-32, 4.10-5 and 4.10-7. In addition, page 272 of the Draft EIR has been amended to further address this comment. See Chapter 5,
L-33
There are no injection wells #5 and #6 proposed (only Injection Well Clusters #1 through #4
from north to south); however, it is acknowledged that the project proponents must coordinate
with the City of Seaside regarding the location and aesthetic design and screening of the
injection wells. See changes to Table 2-22 (page 2-89) in Chapter 5, Changes to the Draft
EIR and Mitigation Measures AE-3 (pages S-7 and 4.2-40) and BT-1a (page S-25 and 4.5- 75
to 4.5-76) of the Draft EIR as shown in Table S-1Revised and Chapter 5, Changes to the
Draft EIR.
L-34
The Draft EIR contains descriptions of, and figures showing, the number of new deep and
vadose zone wells that would be installed on the first and second paragraphs of page 2-72,
then again on Figures 2-32, 4.10-5 and 4.10-7 of the Draft EIR. Figure 2-32 of the Draft EIR
has been revised as shown in Figure 2-32rev at the end of Chapter 5, Changes to the Draft
EIR in response to this and other comments from the City of Seaside.
L-35
See the response to comment L-16, above. See also Master Response #12: Adequacy of
Scope and Range of Alternatives in Chapter 3, Master Responses to Comments.

Final EIR
4-181
September 2015
L-36
Mitigation Measure AE-3 on pages S-7 and 4.2-40 of the Draft EIR has been amended in
response to this comment as shown in Chapter 5, Changes to the Draft EIR.
L-37
The paragraph in Section 2.10.1.3 on page 2-74 of the Draft EIR has been amended in
response to this comment as shown in Chapter 5, Changes to the Draft EIR.
L-38
The text in Table 2-22 List of Permits and Authorizations on the top row of page 2-89 of the
Draft EIR has been amended in response to this comment.
L-39
In response to this comment, page 4.2-39 of the Draft EIR has been amended. See Chapter 5,
L-40
The closest injection well cluster proposed to the intersection of General Jim Moore Boulevard
and San Pablo Avenue is the cluster referenced as DIW-4/VZW-4. The clusters are described
on pages 2-72 through 2-73 of the Draft EIR and shown in Figures 2-32 and 2-35.
L-41
Attachment 2 to this comment letter contains track changes showing edits to a copy of Table S1 from the Draft EIR. The following list of proposed edits in Attachment 2 have either been
addressed specifically above under previous individual responses, as indicated, or an
additional response is provided below:
Edits to the row for Impact Statement AE-3. See the responses to comments L-2, L-3
and L-4 and in Chapter 5, Changes to the Draft EIR (see changes to Draft EIR page
4.2-40). Although the determination of significance was not changed because it was
not warranted in accordance with the significance criteria and approach to analysis, the
asterisk was deleted and the language of Mitigation Measure AE-3 was enhanced to
respond to this proposed edit.
Question on the last bullet in Mitigation Measure AE-4. The referenced bullet item
means that the lighting fixtures and standards must comply with state and local safety
and illumination standards, including the California Building Code and local law
enforcement standards for safety.
Comments and questions on the row for Impact Statement AQ-1. See the responses to
comments L-5 and L-6, above. Grading during high winds can cause excessive
particulate matter emissions that may adversely affect regional air quality; and
therefore, the MBUAPCD recommends no grading when winds exceed 15 miles per
hour for all projects that may exceed their recommended thresholds of significance for
construction emissions of particulate matter. Water sweepers are high pressure
concrete surface cleaners or water brooms are powerful, reliable and universal in
pressure washing hard surfaces such as asphalt or concrete. Use of water sweepers
and wheel washers at the exit of construction sites are recommended by MBUAPCD in
their Air Quality CEQA Guidelines to reduce particulate matter emissions. Accordingly,
these measures were not revised as the comment suggested.
Edits to the row for Impact Statement GS-2. See the response to comment L-7.
Edits to the row for Impact Statement HH-3. See the response to comment L-8. ESCA
clearance is required and has been completed for Site 39. For any ground disturbance
activities, MRWPCA and its contractors must comply with the Fort Ord Reuse Authority
Right-of-Entry process and the City of Seaside Municipal Code Chapter 15.34 (i.e., the
Ordnance Remediation District Regulations of the City in Ordinance 924). These
requirements would ensure that impacts related to hazards to people or the
environment at the site would be less than significant.
Edits to the row for Impact Statement GW-4. See the response to comment L-9.

Final EIR
4-182
September 2015
Edits to row for Impact Statement GW-6. See the response to comment L-10.
Edits to the row for Impact Statements HS-1 and HS-3. See the responses to
comments L-11 and L-12, respectively. See also pages 4.11-56 through 4.11-64 of the
Draft EIR and Master Response #7: Well Development/Construction Water Use and
Discharge in Chapter 3, Master Responses to Comments.
Edits to the row for Impact Statement NV-1. See the response to comment L-13.
Edits to the row for Impact Statement NV-2. See the response to comment L-14. The
applicable components that would be required to implement Mitigation Measure NV-2a
have been appropriately identified as described on pages 4.14-43 through 4.14-49 of
the Draft EIR based on the applicability of the various noise standards, construction
time limits, and noise limits/requirements of the various jurisdictions.
Edits to the row for Impact Statement WW-1. See the response to comment L-15.

Final EIR
4-183
September 2015
Letter M
MONTEREY COUNTY
WATER RESOURCES AGENCY
PO BOX 930
SAliNAS , CA 93902
(831)755-<860
FAX (831) 424-7935
STREET ADORES$
893 BLANCO CIRClE
DAVID E CHAAOAVOYNE
SAUNAS, CA 93901-4455
GENERAL MANAGER
June 5, 2015
Administrative Office
ATTN: Bob Holden, Principal Engineer
5 Harris Ct., Bldg. D
Monterey, CA 93940
RE:
Pure Water Monterey Groundwater Replenishment (GWR) Project

Draft Environmental lmpact Report (DEl R) dated April2015
Dear Mr. Holden:

Thank you for the opportunity to comment on the DElR prepared for the Pure Water Monterey GWR
Project. The Monterey County Water Resources Agency (MCWRA) has reviewed the DElR, dated April
2015, and has broad project comments, as well as highlights of specific sections of the DElR which
should be revised.
As a project participant, our comments could have been most efficiently addressed through a courtesy
revlew of the AdmlnlstratJve DEIR for I he project. MCWRA recognizes your agency will likely not
produce a Revised DElR; however, we consider these comments important. All participants should be
involved to ensure the report contains information which is accurate and relevant. I' m providing this
explanatio1 to give the comment reader the understanding of why the comments are so extensive.
Global comments regarding facilities operated by MCWRA:
Nacimiento Dam impounds 377,900 acre-feet

San Antonio Dam impounds 335,000 acre-feet
Blanco Drain is considered waters of the State and is a 303d listed water body
MCWRA, 2001. Salinas Valley Water Project EIR/EIS (SCH" 97-121020), June 2001 contains
ou:dated information regarding operations of the reservoirs and the SRDF as it pertain.s to fish
pa>Sage, fish flows and monitoring. The Salinas Valley Water Project Flow Prescription for
Steelhead Trout in the Salinas River (2005) and subsequent errata is a more appropriate
reference. Document is available at www.mcwra.co.monterey.ca.us.
M-1
M-2
Text Figure 2.3. Seaside Groundwater Basin Boundaries. page 2-8:

The DWR Bulletin is a 2003 document, not 2004.
Montcrc) County W:ucr Resources /\gene) nusnagc. s. protcccs. and enhances thc quantil) and qu.alh) of \liSter and
p:ro\ tdc-s specifie-d llood control sentees for pre-se-nt and future generations of Muntcre) County
Final EIR
4-184
September 2015
2.3.3 Salinas River and Salinas Valley Groundwater Basin, page 2-13:
Paragraph 2, Sentence 4 should be revised to funher clarify which subareas provide recharge. The
sent ence reads "The groundwat er basin is recharged in all but the Pressure Subarea, which has a clay
layer above the major water bearing layers"; however, recharge in the East Side Subarea is also difficult
due to confined aquifer and clays.
2.3 Project Background, 2.3.3.1 MCWRA, page 214:
Paragraph 1 should be revised t o read the following: "The Monterey County Water Resources Agency is
a water and flood control agency with jurisdiction coextensive with Mont erey County and governed by
the Monterey County Water Resources Agency Board o f Directors and the Board Supervisors".
Table 2-13. Source Water Scenarios. including Priori ty. Seasonality. and Use by Project Phase and
Drought Reserve Status, page 2-41:
The Blanco Drain Pump Station flows have not been calculated during the winter months. Therefore,
there may be additional seasonal availability that is higher in October t hrough March than is stated
within t he tables' Seasonal Availability column.
2.7.2.6 Reclamation Ditch I Tembladero Slough. page 251:
The Diver!ion Methods and Facilities section states that the new intake structure would be on t he
channel bott om at both diversion sites. The MCWRA is concerned with excessive debris within the
channel collecting at the intake sit es and recommends that the final design consider alt ernative intake
methods to account for this.
2.7.2.7 Blanc,o Drain. page 254:
The Construction section mentions the M RWPCA Salinas Intercept or on the west-side of the Salinas
River. There is also a CSIP distribution pipe and the Salinas River Diversion Facility Pipe in close
proximity to the proposed Blanco Drain line that should be considered during the design phase.
M-3
M-4
M-5
M-6
M-7
Fi gure 2.16. Blanco Drai n Storm Drain Maintenance District . page 2-108:
1'he existing pumping station location is shown incorrectly. The MCWRA pump station is located on the
downstream section of the channel segment flowing into the Salinas River, southwest of where it is
shown.
4.4.2.1 Overview of Fish Soecies in Vicinitv of Proposed Project Components:

In reference to the following sentence, " Fish habitat areas upstream of the immediate project vicinity
t hat could be influenced by Proposed Pro ject diversion actions are the Arroyo Seco. San Antonio. and
M-8
M-9
Nacimiento Rivers", the M CWRA Senior Water Resources Hydrologist comments are ,..not sure how
these are affected by proposed project".

Page 4.4-3, In reference to the following sentence, The Santa Margarita Dam is operated so that a live
stream is maintained in the lower river from the dam to the confluence with the Nacimiento River.
which is about 46 miles downstream (FISHBIO. Februarv 2013)", the MCWRA Senior Water Resources
Hydrologist comments are "not sure this is an accurate statement".
Page 4.4-7, In reference to the following sentence, " In some years, flow releases for smolt migration
may not occur because triggers for those releases are not met. However, in those years National Marine
Fisheries Service required MCWRA to provide reservoir releases and SRDF bypass flows t o enhance
migrat ion opportunities for iuvenile steelhead and post-spawn adult steelhead fkelts) (National Marine
M-10
M-11
Monterey C(lunty W:.tcr Resources Agtncy tnunagt:s, protc."<'tS. and enhances the quaeuit) and quality of'' at(r nnd
pro(ide s specified Oood controlscr\'ices for present and ruturc gencr:~tton~ of Monterey County
Page2 of6
Final EIR
4-185
September 2015
Fisheries Service. 2007)" , t he MCWRA Senior Water Resources Hydrologist comments are "as part of
Salinas River Diversion Facility operations".
M-11
Con't
Page 4.4-9, In reference to the text in t he following sentence, At minimum release levels (25 to 30 cfsl.
water temperature can increase to as much as 73' F (22.8' C) within 5 miles of the Naci miento dam, and
75' F (23.9" C) within 10 miles of the dam. During the summer conservation release period (with flows of
300 ds or more), water t emperature is generally maintained at less than 64'F (17.8'C) withi1 5 miles of
t he dam, and 68' F (20' C) or less within 10 miles of the dam (Monterey County Water Resources Agency,
2001)", the MCWRA Senior Wat er Resources Hydrologist comments are " this is old data".
M-12
Page 4.4-10, In reference to the following sentence, "The MCWRA intervenes in the Salinas Lagoon each
year by u!ing equipment to either cause or assist the breach, and also manages t he lagoon water levels
as part of flood control activities (Monterey County Water Resources Agency, 2011), the MCWRA Senior
Water Resources Hydrologist comments are "not during drought years".
Page 4.4-12, In reference to the following sentence, " During non-event periods. the majority of fresh or
brackish water entering t he lagoon comes from the Blanco Drain, locat ed approximately five miles
upstream from the lagoon, which is an agricultural runoff canal" , t he MCWRA Senior Water Resources
Hydrologist comments are not sure what this means and in terms of the canal runoff is also waters of
the state 303d listed for chloropyrifos, diazinon, low DO, nitrate, pesticides, and turbidity .
Page 4.4-13, In reference to the following sentence, "The San Ant onio River is regulat ed by t he San
Antonio Dam, which impounds 350.00 acre-feet; The river is regulated by the Nacimient o Dam, located
10 miles upstream from t he confluence with the Salinas River. The dam, constructed in 1957, impounds
3SO.OOO acre-feet, and provides flood protection and aquifer recharge to the Salinas Valley (Monterey
County Wat er Resources Agency, 2001); Dam operation and flow releases on the Nacimiento River~
managed for the following purposes: {1} to facilitate and enhance passage for upstream migrating adult
steelhead on the Salinas River. etc", the MCWRA Senior Water Resources Hydrologist comments are
"the impoundments are 33S,OOO acre-feet and 377,900 acre-feet, respectively; and t he river is managed
lor additional reasons such as 1) flood control, 2) water conservation, 3) fish passage enhancement, and
4) recreation .
Page 4.4-14, In reference to the following sentence, "The Reclamation Ditch watershed has five main
tributaries including Gabilan, Natividad, Alisal and Santa Rita Creeks (see Figure 4.4-3, Reclamation Ditch
Tributaries) and t he Merritt Lake drainage. Gabilan, Natividad, and Alisal Creeks converge at Carr Lake.
The outlet from carr Lake forms the head of t he Reclamation Ditch" , t he MCWRA Senior Water
Resources Hydrologist comments are "this is not the head of t he Reclamation Ditch".
Page 4.4-26, In re ference to t he following sentence, " Due to mult iple factors, monitoring was not
cond ucted during t he entire t imef rame outlined i n the Biological Opinion (December 1 to March 31)",
the MCWRA Senior Water Resources Hydrologist comment s are "a DIDSON camera was installed on
February 24 and removed on March 20 and not reinstalled due to flood conditions".
Page 4.4-31, In reference to the followi ng sentence, "As stated above, the Salinas River. Reclamation
Ditch and Tembladero Slough are list ed as impaired waterbodies under section 303(d) of the Clean
Water Act, the MCWRA Senior Wat er Resources Hydrologist comments are and Blanco Drain".
M-13
M-14
M-15
M-16
M-17
M-18
Comments on Section 4.8 - Geology, Soils, and Seismicity:

Momcre) Counly \Vo.tcr Rcsourcc1o Agency m~ nagc!>. prO(ects, and cnhanC'esthe quantil) and quaht) ofwa1~r and
prov de~ specified flood control scn. ices rQr present and future generations of Momcrcy County
Page3 of6
Final EIR
4-186
September 2015
References related t o Project Consistency with Monterey County General Plan Policy S-1.7 including In
Table 4.82. the discussion of project consistency with Policy S1. 7 refers to "Section 4.X, Geology, Soils,
and Seismicity for a discussion of seismic hazards and pot ential mitigation." There is no Section 4.X in
the Draft EIR document . Table 4.82, in the discussion of project consistency with Policy S-1.7 also
reference Appendix K, citing a Ninyo and Moore report from January 2015. The report in Appendix K
has a date of December 2014. The report references should be consistent to avoid confusion.
M-19
Coastal Profile (Vertical Erosion Estimates)

The draft :JR mentions that "(t]he high and low rat es of sea level rise were estimated for each year f rom
2012 to 2073.. ." (page 4.827) but t here is no reference t o which model or dataset was used as a basis
for the estimates of sea level rise.
Back-flush ba.sin for Injection Well Faci liti es
The backOush basin project component is described inconsistently (page 4.839). Use of the basin is
described as having wat er discharged into i t several hours four times per week" and, later in t he same
paragraph, "a few hours per week." A more quantitative and consistent description should be available
in order to evaluate the risk of hydro-collapse from wetting the upper sediments in the vidnity of the
injection wells.
M-20
M-21
Comments on Section 4.10- Hydrology and Water Quality~ Groundwater include:
Definition of geologic periods: Section 4.10.2.3. defines t he delineation of t he Tert iary and Quat ernary
at occurring at 1.6 million years ago which is inconsistent with the USGS delineation between these two
periods, which occurs at 1.8 million years ago (reference: http:ljpubs.usgs.gov/fs/2007/3015/fs2007
301S.pdf).
M-22
Description and definition of Salinas Valley Groundwater Basin subbasins: Section 4.10.2.3. incorrectly
refers to the Salinas Valley Groundwater Basin has having four subareas. California DWR, in 6ulletin 118
(2003), divides the Salinas Valley Groundwater Basin into eight subbasins. In addit ion to the subbasins
listed in the report, the Salinas Valley Groundwat er Basin includes the Corral de Tierra, Langley, Paso
M-23
Robles$ and Seaside subbasins. W hat is the source for the approximate subbasin areas in Section
4.10.2.3? No reference is listed and the values in the report are different f rom those in Bulletin 118
(DWR, 2003).
General description of groundwater basin

The section "Salinas Valley Groundwater Basin Flow and Occurrence describes a groundwater basin as
being "much like a surface water reservoir." This description is overly simplistic and misleading because,
while water levels in an aquifer do decrease with water withdrawals, this comparison neglects potential
issues of land subsidence and the pot ential for very slow rat es of groundwater recharge that may occur
in areas with low vertical hydraulic conductivity and/or the presence of aquitards. Availability of
recharge in an area overlying an aquifer does not necessarily mean that all aquifers can or will receive
that recharge. Recharge may occur on an extremely slow time scale such t hat it is im~ractica l to
consider it as being available for the purposes of a project. Alternatively, an aquifer's storage capacity
may be permanently diminished if subsidence or land compaction has occurred. Some additi::>nal det ail
about the description of a groundwater basin should be considered.
Figure showing seawater intrusion in t he Salinas Valley Groundwater Basin
This sectio1 refers to a figure that illustrates "the seawater intrusion areas as of "20112013' (Figure 2
9). However, the seawater intrusion areas are shown on Figure 27, not Figure 2-9, and the seawa ter
Montt re) c.-.umy W{ltcr Resources Agency man3~es. protects. Md enhances che quantit)' and quality or .... attr und
provides specatied flood control str\'iCt! for ptescnt 3nd future generations of Monterey County
Page4 of6
Final EIR
4-187
September 2015
M-24
M-25
intrusion front is mapped through 2011, not 2013. Figures depicting the 2013 SWI fronts are available
on the MCWRA website.
Comments on Appendix C
~ The status of t he Water Rights has changed since the issuance of the subject memo. The St ate
Water Resources Control Board (State Board) issued a letter on March 25, 2015 accepting the water
rights application #32263. The State Board also requested additional information. The first was to
submit a description of how to split the application up into multiple applications to accommodate each
project using the water rights. The first project is the subject project and the revised application will
reflect the necessary water right to accommodate the project needs. The second request was an update
on the environmental document preparation. The State Board received a copy of the subject Draft EIR
for review.
Comments on Appendix F
f.&.b_ln reference to the following sentence, "The Monterey County Water Resources Agency int ervenes
in t he breaching of Salinas Lagoon each year by using equipment to either cause or assist the breach
(Casagrande et al. 2003)", the MCWRA Senior Water Resources Hydrologist comments are "does not
occur each year".
M-25
Con't
M-26
M-27
fB..j. In reference to the following sentence, "The San Antonio River is regulated by the San Antonio
Dam (RM 5), which impounds 350,000 acre-feet. The dam, constructed in 19S7 impounds 350,000 acre
feet, and provides flood protection and aquifer recharge to the Salinas Valley (MCWRA 2001)", the
MCWRA Senior Water Resources Hydrologist comments are "the impoundment is 335,000 acre-feet".
M-28
Comments on Appendix M
The discussion on modifications to the average monthly supply sources for years with constrained
supply in June includes a reference to a missing document.
Comments on Appendix 0
The target fish flows referred to on pages 2 and 23 of Appendix 0 and elsewhere in the document are
not consistent with f ish passage criteria developed by the NMFS in the Salinas Valley Water Project
(SVWP) Biological Opinion (BO).
The BO identifies the need for a stream passage corridor of 10 feet wide by 1 food deep and
prescribes corresponding flow rates at the Salinas River near Chualar and Salinas River near
Spreckels USGS streamflow gages. The BO requires fish passage flows in the Salinas River when
specific triggers are met that indicate the need for upstream migration of adult steelhead or
downstream misration of smolts and post spawn adults.
The following statement from paragraph 1 on page 17 could use clarification. "The decline in average
annual flows during the regulated period represents almost 90,000 AFY going int o groundwater
recharge."
If the statement refers to the increase in ground water recharge from the Salinas River between
pre and post dam conditions it is not consistent with the 30,000 AFY increase in ground water
recharge identified in the Salinas Valley Historical Benefits Analysis.
MMicrc)' Counly \V~tcr Rewurces Agency matl3SCS. ~lrOlects. and enhances the quanlil) and quaht~ ofwntcr and
prO\' ide-s Sp<'CifiCd nood control
str\'iCCS
rot prtse:m 3nd fucure gcncr:mons ()( MomcrC) Count)
Page 5 of6
Final EIR
4-188
September 2015
M-29
M-30
M-31
M-32
M-33
The follov.ing statement from paragraph 1 on page 19 is incorrect. "Reservoir releases were made from San
Antonio and Nacimiento Reservoirs for groundwater recharge, but no flow was recorded at the Spreckels
gage."
M-34
No conservation releases were made during the 2014 SRDF Operational Season. Minimum fish
releases were made from San Antonio and Nacimiento Reservoirs to meet requirements of the
California Department of Fish and Wildlife as well as the SVWP 80 for spawning and rearing habitat.
Comments on Appendix P
Nacimiento and San Antonio Reservoir Operations as described in the following statement in paragraph 1 on
page 6 require clarification. "Water is released from these reservoirs to maintain yearround flow in the
Salinas River for Aquifer recharge."
M-35
When reservoir elevations are above minimum pool at Nacimiento and above dead pool at San
Antonio, releases are made for downstream spawning and rearing habitat in accordance with
California Department of Fish and Wildlife and SVWP BO requirements. Reservoir releases are made
for SVWP operations and aquifer recharge during the SRDF operational season (April - Oct ober)
when water is available. Additional releases are made as required with consideration to the SVWP
80, California Department of Fish and Wildlife Regulations, FERC/DSOD Regulations, Col fornia DWR
Water Rights, and other considerations identified in the San Antonio and Nacimiento Dam Operation
Policy Documents.
Comments on Appendix Q
The Methodology Section on page 7 states that there is limited data available and only during the months of
April to October. Although the approach is relatively conservative in calculating dry-season available water,
additional studies may be beneficial to understand average and peak flows.
M-36
The following statement in paragraph 2 on page 10 requires clarification. "In each month, the bypassed flow
minus the Blanco Drain flow exceeds the required minimum release."
The statement is technically correct but the premise i.s incomplete.
Flow into the Salinas River
Diversion Facility (SRDF) is measured at the Salinas River near Spreckels USGS gage and bypass is
measured at the SRDF fish ladder and regulating weir. Blanco Drain flows are Intentionally excluded
from SRDF bypass and extraction accounting. MCWRA does not have a water right for the use of
Blznco drain water at the SROF and the water quality is not consistent with the intention of bypass
flows to the Salinas Lagoon.
Table 2-3 on page 10 contains outdated information. The Salinas Valley Water Project , Annual flow
Monitoring Report, Water Year 2012 was revised in March 2014. The average daily bypass flows in Table 2-3
do not reflect the revised Mean Monthly Discharge values for Blanco Drain.
Thank you for the opportunity to review the DEIR. If you have any questions, please feel free to contact me
at (831) 755-4860.
Monterey C:.unty Water Resources Agency managts. prOIC"ca. and enhances the qu::mtity and qu3lit)' of\\altr ~tnd
pro\' ides specified Oood control senices l'or pres-ent :,nd future sencr~ttons of Momcrc) Coum)
Page 6 of6
Final EIR
4-189
September 2015
M-37
LetterM: MontereyCountyWaterResourceAgency
M-1
Although the storage capacities of the Nacimiento and San Antonio Dams are correctly
identified on pages 2-13 and 2-15 of the Draft EIR, the text on page 4.4-13 of the Draft EIR has
been updated as requested. The status of the Blanco Drain as waters of the State and a 303dlisted water body is noted as it reiterates information provided in the Draft EIR description. Text
changes to Draft EIR have been made to further clarify the potential for waters of the State
designations. See revisions to pages 4.4-13. 4.5-87 through 4.5-92, 4.11-30, 4.11-36, and 4.1162 of the Draft EIR in Chapter 5, Changes to the Draft EIR. The fish passage analysis has
been updated to describe and analyze how the Salinas Valley Water Project Flow Prescription
for Steelhead Trout in the Salinas River relates to the Proposed Project. See the responses to
comments E-4 through E-6 and Master Response #5: Fisheries Impact Analyses in Chapter 3,
M-2
DWR Bulletin 118 is dated 2003, but the chapter of that document titled Salinas Valley
Groundwater Basin, Seaside Area Subbasin was last updated in February of 2004 (see
http://www.water.ca.gov/pubs/groundwater/bulletin_118/basindescriptions/3-4.08.pdf).
The
Draft EIR reference is correct.
M-3
The Draft EIR text in section 2.3.3 on page 2-13 has been amended as requested in the
comment. See Chapter 5, Changes to the Draft EIR.
M-4
The Draft EIR text in section 2.3.3.1 on page 2-14 has been amended as requested in the
M-5
The method to estimate winter flows in the Blanco Drain was designed to produce
conservatively low flows to prevent over-estimation of the potential yield of the Proposed
Project. Additional water availability during the months of October through March would
increase water available, but may also exceed the combined demands for irrigation water within
the CSIP area and source water for the influent requirements of advanced water treatment
plant resulting in additional ocean discharge of effluent. Source water would not be diverted
when it is not needed for the Proposed Project.
M-6
The diversion facilities were laid out conceptually using the same design as the current Blanco
Drain pump station. Alternative intake configurations could be considered during detailed
design in consultation with Monterey County, the State Water Resources Control
Board/Regional Water Quality Control Board, and National Oceanic and Atmospheric
Administration, National Marine Fisheries Service (NMFS). Debris removal from the
Reclamation Ditch and Tembladero Slough diversion structure would be necessary
approximately once per month as described in Chapter 2, Project Description at pages 2-53
and 2-55 of the Draft EIR. This assumed the maintenance activity that was included in the Draft
EIR impact analyses in Chapter 4.
M-7
The Draft EIR identifies the Salinas Interceptor as the receiving pipeline for the Blanco Drain
force main. All existing pipelines and utilities within the alignment will be considered during
design. The preliminary engineering design does not conflict with the CSIP or the Salinas River
Diversion Facility (SRDF) pipelines in proximity to Blanco Drain (E2 Consulting Engineers,
personal communication, July 2015).
M-8
Figure 2-16 was intended only to show the extent of the Blanco Drain drainage basin. It was
extracted from an earlier report, and shows the original pump station. A note has been added
explaining that the pump station shown has been replaced. See revisions to page 2-108 of the
Draft EIR in Chapter 5, Changes to the Draft EIR.

Final EIR
4-190
September 2015
M-9
The MCWRA Senior Water Resources Hydrologist questions whether the upstream fish habitat
cited (the Arroyo Seco, San Antonio, and Nacimiento Rivers) could be influenced by Proposed
Project diversion actions. Although the habitat in question would not be impacted by the
Proposed Project, the ability for fish to reach that habitat was analyzed in the EIR. As
discussed on pages 4.4-49 through 4.4-51 of the Draft EIR as amended in this Final EIR,
project operations would not result in reduction of fish habitat upstream of the Proposed Project
diversions.
M-10
The comment questions the accuracy of a statement from page 4.4-3 in the Fisheries Section
of the Draft EIR. The statement is correctly referenced from a monitoring report prepared by
FISHBIO in February 2013 for the MCWRA, and subsequently submitted to the National Marine
Fisheries Service NMFS (April 2013).
The report was accessed and can be found on the MCWRAs website:
http://www.mcwra.co.monterey.ca.us/fish_monitoring/documents/2012%20Annual%20Fisheries
%20Report%20with%20Appendices.pdf.
M-11
The comment clarifies a statement in the Fisheries Section on page 4.4-8 of the Draft EIR, top
of page, in reference to the following sentences, "In some years, flow releases for smelt
migration may not occur because triggers for those releases are not met. However, in those
years National Marine Fisheries Service required MCWRA to provide reservoir releases and
SRDF by-pass flows to enhance migration opportunities for juvenile steelhead and post-spawn
adult steelhead (kelts). The comment clarifies that this was part of SRDF operations. This
change has been made to page 4.4-8 in Chapter 5, Changes to the Draft EIR.
M-12
The comment questions the age of the data presented on page 4.4-9 of the Draft EIR, in
reference to minimum release levels and water temperature below Nacimiento Dam. In the
Draft EIR, minimum flows are stated to be (25 to 30 cfs), water temperature can increase to as
much as 73F (22.8C) within 5 miles of the Nacimiento dam, and 75F (23.9C) within 10 miles
of the dam. Current monitoring reports available from the MCWRA website identify temperature
of water released below the dam typically ranges between 52 and 54F in temperature, and
generally remains cooler than 64F within the first 5 miles below the dam, and below 68F
within the first 10 miles of the dam. However, under certain conditions (i.e. low summer flows
during dry years) temperatures reach 73F within 5 miles of the dam and 75F within 10 miles
below the dam (NMFS 2007). The source for this information is the Monterey County Water
Resources
website:
http://www.mcwra.co.monterey.ca.us/fish_monitoring/documents/2014_2%20Salinas%20Basin
%20Juvenile%20O.%20mykiss%20Downstream%20Migration%20Monitoring.pdf.
This
information although updated appears to be consistent with the text in the Draft EIR. However
the additional reference and updated information is also added to the Draft EIR; see Chapter 5,
M-13
A sentence has been added to this paragraph to clarify that the management of the Salinas
Lagoon specified on page 4.4-10 of the Draft EIR does not occur during drought years. See
M-14
The sentence notes that during non-event periods, referring to rainfall, the majority of fresh or
brackish water entering the lagoon comes from the Blanco Drain, located approximately five
miles upstream from the lagoon. The comment notes that the Blanco Drain is listed as impaired
water under Section 303(d) and the canal runoff is also considered waters of the state and is
also listed for various constituents, nitrate, pesticides, and turbidity; this information is noted in
the Draft EIR. Text changes to Draft EIR have been made to further clarify the potential for
waters of the State designations. See revisions to pages 4.4-13. 4.5-87 through 4.5-92, 4.1130, 4.11-36, and 4.11-62 in Chapter 5, Changes to the Draft EIR.

Final EIR
4-191
September 2015
M-15
The comment requests language changes on page 4.4-13 of the Draft EIR. Additional language
has also been added to note that dam operation and flow releases on the river are managed for
a variety of needs including 1) flood control, 2) water conservation, 3) fish passage
enhancement and 4) recreation. The revisions have been made; see Chapter 5, Changes to
the Draft EIR.
M-16
The comment requests language revisions to page 4.4-14 of the Draft EIR. The revisions have
been made; see Chapter 5, Changes to the Draft EIR.
M-17
M-18
M-19
The comment identifies two typographic errors in Table 4.8-2 on page 4.8-17 of the Draft EIR
regarding the consistency of the Proposed Project with Monterey County General Plan Policy
S-1.7. The first comment identifies that the reference to section 4.X Geology, Soils, and
Seismicity, which should be to Section 4.8, Geology, Soils, and Seismicity. The second
comment is in reference to the date for the report in Appendix K, the Preliminary Geotechnical
Evaluation. These errors have been corrected in Chapter 5, Changes to the Draft EIR.
M-20
The comment requests a reference for the model or dataset used as a basis for the estimates
of sea level rise described on page 4.8-27 of the Draft EIR. The source for the analysis in the
Draft EIR is provided on page 4.8-26, Analysis of Historic and Future Coastal Erosion with Sea
Level Rise (ESA-PWA, 2014). In that report, the source for the sea level rise data and modeling
was provided. Specifically, the analysis used a sea level rise projection of 15 inches by 2040
and 28 inches by 2060, relative to 2010. These projections are based on a 2012 study by the
National Research Council (NRC) which provided regional sea level rise estimates for San
Francisco (the closest projection to the Project). The 2040 and 2060 values were derived by
fitting a curve to the Average of Models, High projections for 2030, 2050, and 2100 published
in the NRC study (National Research Council, 2012).
M-21
In response to this comment, text on page 4.8-39 of the Draft EIR has been modified to provide
consistent quantified back-flush basin use amounts. See Chapter 5, Changes to the Draft
EIR. See also Master Response #8: Well Maintenance and Backflushing Water Amounts and
Discharge in Chapter 3, Master Responses to Comments.
M-22
The footnotes on page 4.10-4 of the Draft EIR have been revised to indicate the start of the
Pleistocene Epoch as 1.8 million years ago in response to this comment. See Chapter 5,
M-23
In response to this comment, the following has been added to the end of the first paragraph in
Section 4.10.2.3 on page 4.10-4 of the Draft EIR:
DWR (2003) recognizes four additional subbasins around the periphery of the main part
of the basin. These include the Seaside and Corral de Tierra subbasins between Salinas
and Monterey. The Seaside Basin as used in this report (see Section 4.10.2.4)
corresponds to parts of DWRs Seaside and Corral de Tierra subbasins.
In addition, the sizes of the subbasins mentioned on pages 4.10-4 through 4.10-6 of the Draft
EIR have been revised to be consistent with DWRs Bulletin 118 shapefile (180/400-Foot

Final EIR
4-192
September 2015
aquifers: 130 mi2; East Side: 90 mi2; Upper Valley + Forebay + East Side + 180/400-Foot: 520
mi2 ) in response to this comment. See Chapter 5, Changes to the Draft EIR.
M-24
In response to this comment, the first paragraph under the heading Salinas Valley
Groundwater Basin Flow and Occurrence on page 4.10-6 of the Draft EIR has been replaced
to provide more definition of groundwater basins as requested in this comment. See Chapter 5,
M-25
Figure 2-7 of the Draft EIR has been modified to replace the 2012 version of the seawater
intrusion maps with the more recent, 2014 seawater intrusion maps. See Figure 2-7revised in
M-26
The updated water rights information requested in this comment has been prepared and is
included in the changes to Section 4.18 in Chapter 5, Changes to the Draft EIR and
Appendix C-Revised.
M-27
Appendix F of the Draft EIR has been revised to update the incorrect text. See Appendix FRevised as shown in Chapter 5, Changes to the Draft EIR. It appears this comment identifies
an error from the Reclamation Ditch Watershed Assessment Report (Casagrande, et al, 2006)
report and not the technical content of Appendix F.
M-28
Appendix F has been revised to update the incorrect text regarding the amount of water
impounded behind the San Antonio Dam (335,000 acre-feet, instead of 350,000 acre-feet). See
Appendix F-Revised as shown in Chapter 5, Changes to the Draft EIR.
M-29
The reference on page 15 of Appendix M of the Draft EIR is intended to be a reference to Table
4 in that report. There is no missing document. Chapter 5, Changes to the Draft EIR, shows
this typographical correction to Appendix M of the Draft EIR.
M-30
The fish passage criteria developed by the fisheries biologist are specific to the river reach from
the project location downstream to the Salinas River Lagoon. Looking at the flow exceedance
tables in Appendix C within the Draft EIR Appendix O (Salinas River Inflow Impacts Report), the
percentile ranking of flows at 150 cfs and 300 cfs do not change in the months of December
through May. As discussed in the responses to comments E-4 and E-5, and Master Response
#5: Fisheries Impact Analyses in Chapter 3, Master Responses to Comments, the passage
flow analysis has been updated in response to this comment and others to add an analysis of
the fish passage criteria in the 2007 NMFS BO to the existing analysis in the Draft EIR. See
changes to the Draft EIR pages 4.4-37 through 4.4-49 in Chapter 5, Changes to the Draft
EIR.
M-31
See the response to comment M-30.
M-32
The Salinas Valley Historical Benefits Analysis (Montgomery Watson, 1997) estimated
groundwater recharge based on recorded groundwater levels and recorded and assumed
groundwater pumping amounts, among other factors, then modeled the same groundwater
pumping pattern but removed the regulated, year-round reservoir releases to simulate a
without reservoirs condition. The statement in Appendix O-Revised is simply a comparison of
measured flow at the Spreckels gage during two separate periods. The differences may be due
to increased riparian use in the later period, or to the decrease in the average precipitation
between the two periods. See Appendix O-Revised as shown in Chapter 5, Changes to the
Draft EIR under the section titled Changes to the Appendices.

Final EIR
4-193
September 2015
M-33
See the response to comment M-32.
M-34
The comment requests changes to the text of Appendix O of the Draft EIR. The Draft EIR has
been amended as requested; however, the change in text does not affect the analysis. The
relevant portion of the statement was that no flow was recorded at the Spreckels gage the 2014
operational season. See Chapter 5, Changes to the Draft EIR under the section titled:
Changes to the Appendices.
M-35
The statement in Appendix P of the Draft EIR is consistent with the 2006 Monterey County
Groundwater Management Plan. Plan Element 5, Continuation of Conjunctive Use Operations,
states: As described in other parts of this GWMP, MCWRA effectively began conjunctive use
operations in the late 1950s after construction of Nacimiento Dam and Reservoir. MCWRA
expanded those operations in the late 1960s after construction of San Antonio Dam and
Reservoir. Since then, conjunctive use of surface water and groundwater has been nontraditional in that surface water has not been directly used for irrigation or other water supply in
the basin; rather, surface water has been indirectly used by dedicating regulated releases from
the reservoirs for maintenance of Salinas River flow through most of the basin, promoting
groundwater recharge from the stream channel.
M-36
The information in the comment has been incorporated into the EIR as a change to Appendix
Q. See Appendix Q-Revised as referenced in Chapter 5, Changes to the Draft EIR under the
section titled: Changes to the Appendices.
M-37
Updating the return flow calculations with the corrected data from 2012, the return flow factor
changes from 17.3% to 16.8%. The report assumed a return flow factor of 17%, which remains
valid. See Appendix Q-Revised as referenced in Chapter 5, Changes to the Draft EIR under
the section titled: Changes to the Appendices.

Final EIR
4-194
September 2015
Letter N
Seaside Basin Watermaster

2600 Garden Road, Suite 228
Monterey, CA 93940
WN 05
MRWPCf>
June 4, 2015
Monterey, CA 93940
Subject: Comments from the Seaside Basin Watermaster on the Draft

Environmental Impact Report for the Pure Water Monterey Groundwater
Replenishment Project, dated April2015
Dear Mr. Holden:

The Seaside Basin Watermaster submits the following comments and questions regarding
the Subject document.
IN THE SUMMARY OF THE DEIR:

Page S-33, #4.10: When deciding whether a project could have an impact, the GWRP
should be considered to have the potential to have a Significant impact on the Seaside
Basin because injecting 3,500 AFY into the Basin constitutes adding a large new source
of water at a new location and will thus impact flow patterns in the aquifer and also
groundwater elevations. Currently the total amount of water pumped out of the Basin is
on the order of 4,000 AFY, so a 3.500 AFY new source would be a large one. Therefore,
its impacts should be evaluated before making a detem1ination of its significance in terms
of impacts. The Project would have the potential to significantly impact recharge to the
Seaside Groundwater Basin. contrary to the statement in the DEIR, so this wording
should be revised accordingly.
However, based on the description of the quality of the Project's recharge water, the
manner in which it would be injected into the Basin, and the findings of the studies you
performed, much of which is contained in the Appendices by Margie Nellor and the
company that performed the groundwater analyses, it does not appear that these impacts

Final EIR
4-195
September 2015
N-1
N-2
would be ham1ful to the Basin. Consequently. the determination that it would not have a
significant impact is reasonable.
N-2
Con't
IN THE BODY OF THE DEIR:

General Comment: In numerous places the acronym .. MPWSP"' is incorrectly spelled
'MPSWP." Suggest a Find and Replace.. be done to the document to correct these
typos.
Page 2-74: The statement is made on this page that "'Based on the experience of the
Water Management District in the operation of its nearby Aquifer Storage and Recovery
wells. back-flushing of each deep injection well would occur about weekly and would
require discharge of the back-flush water to a percolation basin (basin). with a storage
capacity of about 240,000 gallons. Water percolated through the basin would recharge the
Paso Robles aquifer: On an annual basis the volume of water that will be extracted from
the Santa Margarita aquifer by back llushing will be substantial. If that water is
percolated into the Paso Robles aquifer it would like!) not reach the Santa Margarita
aquifer for a long time. if ever. depending on the properties of the geologic layer that
separates these two aquifers. It would therefore seem that the volume extracted from the
Santa Margarita aquifer for back-nushing should be subtracted from the volume that is
recharged via the deep injection wells when determining the volume of water that Cal
Am would be entitled to pump from that aquifer. Another approach to address this
concern would be to send the back-llush water back to the MRWPCA"s Regional Plant
by disposing of it into the sanitary sewer. That volume could then be sent through the
A WT and come back to the Seaside Basin as an additional oflsetting flow that could be
injected back into the Santa Margarita aquifer to ensure thut this aquifer does not
experience any net depletion due to development activities.
N-3
N-4
These issues should be addressed in the design of the Project and should also be
addressed in the Watennaster's Storage Agreement with Cal Am for the recharged water
from the Project.
Page 2-77: In the last paragraph on this page the word "'or should be replaced with the
word "or."
N-5
Page 2-95, Figure 2-3: The Legend of this Figure is titled ..Adjudicated Seaside
Groundwater Basin Boundary." The boundary that is shown does not accurately match
the Adjudication Decision boundary, as noted in the comment above on Figure 4. 105.
The Legend title should be revised or the boundary shown should match the Adjudication
Decision boundary.
N-6
l)age 2-96, Figure 24: In the Legends for the two maps on this page please add a
footnote clarifying what is meant by "Deep Zone.'"
N-7

Final EIR
4-196
September 2015
Page 4.1-1: In the Table of Contents at the top of this page the Section number for
"'Hydrogeology/Water Quality-Groundwater" should be 4.1 0. not 4.1.
N-8
Section 4.10.2.4, page 4.10-16 (top paragraph): Please add that the southeasterly
boundary of the Seaside Basin is also a groundwater divide that is su~ject to movement.
N-9
Figure 4.10-5, page 4.10-86: The boundary lor the Seaside Basin in this Figure appears
to be approximately the same as the Court Adjudication boundary. except in the eastern
portion of the Basin. Since the Adjudication Decision imposes management and other
requirements on the area within the Adjudication boundary it would be good to also show
the exact Adjudication boundary on this Figure.
N-10
Page 4.10-40 (next to last paragraph): Please add that since the activities described in
the M&MP completed in September 2006 have been accomplished. the Watermaster has
prepared an updated M&MP each year to address changing conditions and issues of
concern. These are submitted to the Court each year as part of the Watermaster's Annual
Report.
N-11
Pages 4.10-54 and 55: These pages include the statements that:
( 1) "The volume of water pumped lor development or each well would be about
3.600,000 gallons. based on lour 10-hour days of development pumping at 1.500
gpm as estimated by Todd Groundwater. If the water used for development were
drawn from groundwater and not returned as recharge. aquifer volumes or
groundwater levels could be decreased; however. well development water at the
Injection Well Facilities would be allowed to percolate back to the groundwater
basin through on-site disposal resulting in a less-than-significant impact to aquifer
volumes and groundwater levels:
(2) "The Injection Well Facilities construction would not use substantial amounts of
groundwater that would not be returned to the groundwater system and would not
impact groundwater volume or levels due to loss of recharge.''
(3) "Impacts associated '"'ith groundwater depletion. ~~~'cis and recharge during the
construction of the Proposed Project would be less than significant."
(4) "Therefore, for the project us a \\hole, the potential construction impacts would be
less than significant relative to groundwater recharge. volume. or levels. and no
mitigation measures would be required.''
The Pr~ject proposes to develop four \\ells using this volume of water so collectively the
amount that would be pumped from the Seaside Basin lor well development would total
approximately 45 acre-feet. The Adjudication Decision does not appear to make any
provision for this pumping, and makes no allocation of groundwater pumping for this
purpose.
In addition surface recharge at the proposed development water percolation sites will take
a long period of time before the recharged \'vater reaches the Santa Margarita (and even
the Paso Robles) aquifers. Also, some of it may remain in the overlying Aromas Sands
and not reach either of the two other aquifers. Therefore. it is not reasonable to assume

Final EIR
4-197
September 2015
N-12
that allowing the development water to percolate through on-site disposal will have a less
than significant impact on groundwater levels or aquifer \olumes. This is particularly
true since the wells will be in close proximity to each other and the development water
pumping might produce a localized groundwater depression.
One approach that would address this concern would be to return the development water
to MRWPCA's Regional Plant by disposing of it into the sanitary sewer. That volume
could then be sent through the A WT and come back to the Seaside Basin as an additional
offsetting flow that could be injected back into the Santa Margarita aquifer to ensure that
this aquifer does not experience any net depletion due to development activities.
N-12
Con't
These issues should be addressed in the design of the Project and will need to be resolved
to the satisfaction of the Watermaster before well development can occur.
Page 4.10-76: The statement is made on this page that ..... all other cumulative projects
are approved or mandated by the Seaside Basin Watermastcr: One of the listed projects
is the MPWSP. While the Watermaster supports the MPWSP. it did not approve or
mandate this project.
Appendix D: At several places in this Appendix it is stated that one of the requirements
for the Project will for the proponents to submit. and receive approval from the
SWRCB's Division of Drinking Water (DDW). a Response Retention Time (RRT) Plan.
The purpose of this Plan is to provide measures to ensure that no water from the Project
is allowed to reach any drinking water supply well if the recharged water quality does not
comply with the required standards. Due to the critical nature of water quality and the
likelihood of public concern about possible contamination of drinking water supplies due
to recharging the Basin with treated wastewater, the Watennaster would like to have the
opportunity to review and comment on the Project's Response Retention Time Plan when
it is submitted to the DOW for its review.
Also in Appendix D. Attachment A (letter from California Department of Public llealth

dated JuneS. 2014 mention is made ofthc requirement for MRWPCA to submit both a
'Contingency Plan" (along with the Engineering Report) and a '"Response Plan." These
appear to be separate from the RRT Plan. The Contingency Plan. according to that
letter is to " ... ensure that no untreated or inadequately treated wastewater will be
delivered to the usc area:' The on-line sensors included in the design will presumably
identify some types of chemical-physical water quality deviations from the State's
requirements, but the water will have already left the A WT and gone into the delivery
pipeline once it passes through those sensors. An even more difficult issue is that the
wet-lab analytical work that will be necessary to confirm that the water produced by the
AWT meets State quality requirements (e.g. pathogens. primary and secondary MCLs,
lead, copper. total nitrogen. and TOC} will take some time to process and the water that is
tested will long since have left the A WT and be in the pipeline leading to the use area. As
there appears to be no storage facility included in the A WT design to contain the treated
water until its quality has been conlirmcd as meeting the State's requirements. what is the

Final EIR
4-198
September 2015
N-13
N-14
N-15
plan for complying with the requirement that no inadequately treated water is delivered to
the use ar~a?
With regard to the Statcs requirement that MRWPCA have an approved Response Plan,
the table in Appendix Don page 66 includes a statement that "Prior to start-up of the
GWR Prqjcct. MRWPCA will de\'clop and submit a plan to DDW to provide an
alternative source or water or a DD W -approved treatment system should the G WR
Project impact a drinking water well so that it cannot be used was a water supply or the
GWR Project fails to meet the pathogen control requirements." For the same reasons
stated above. the Watermaster \vould like to ha\'e the opportunity to review and comment
on the Project's Contingency and Response Plans when they arc submitted to the DOW
for its appro\ al.
If you have any questions regarding these comments. please contact Mr. Robert Jaques.
Technical Program Manager. at (831) 375-0517 or by email at hobj83 a comcast.nct.
Sins;erely.
~~)-~
Dewey D. Evan(;
~hief Executive Officer
Seaside Basin Watem1aster

Final EIR
4-199
September 2015
N-15
Con't
N-16
LetterN: SeasideBasinWatermaster
N-1
The Draft EIR conclusions related to the cumulative impact for topical Section 4.10
Hydrology/Water Quality: Groundwater in Table S-2, Summary of Cumulative Impacts and
Mitigation Measures, are supported by the information provided on pages 4.10-77 through
4.10-78 of the Draft EIR. The cumulative impact of the Proposed Project is LS because the
modeling conducted for the cumulative project scenarios show that Seaside Basin groundwater
conditions (water levels, protective elevations at the coast, storage capacity, and recharge) with
implementation of the cumulative projects would be the same or better than conditions without
implementation of the cumulative projects. Groundwater elevations generally would be higher
under the cumulative conditions than under the conditions without the cumulative projects.
These higher groundwater levels would tend to slow or stop seawater intrusion. For these
reasons, there would not be a significant cumulative impact on groundwater levels, recharge, or
storage with the Proposed Project injections of 3,500 AFY of water into the Seaside Basin.
Per Section 4.10.4 of the Draft EIR, pursuant to Appendix G of the CEQA Guidelines a project
would have a significant impact on hydrology if it would substantially deplete groundwater
supplies or interfere with groundwater recharge such that there would be a net deficit in aquifer
volume or a lowering of the local groundwater table. The Project operations would significantly
impact groundwater resources if operations were to result in groundwater mounding, changes
in groundwater gradients, or lowering of groundwater levels such that nearby municipal or
private groundwater production wells experience a substantial reduction in well yield or physical
damage due to exposure of well screens. Substantial reduction would occur if wells were to
become incapable of supporting existing land uses or planned uses for which permits have
been granted. More specifically, one of the following two conditions may occur that would
trigger this condition:
A decline in average groundwater level is significant if it would lower the water level to
a depth below the median depth to the top of the well screen in nearby wells.
A decline in average groundwater level is significant if it would decrease pump output

(in gallons per minute) by more than 10%.
The Proposed Projects impact assessment related to groundwater depletion, levels, and
recharge in the Seaside Basin is provided in Draft EIR Appendix L Recharge Impacts
Assessment Report and is summarized on pages 4.10-64 through 4.10-65 of the Draft EIR.
The modeling incorporated estimates of the delivery of the purified recycled water in various
year types and was conducted using the Seaside Basin Watermaster predictive model for
analyzing future conditions in the basin, reasonable assumptions of operation of the production
wells in the basin, and reasonable assumptions of the future operation of the Aquifer Storage
and Recovery project. The assessment concludes that there would be no significant operational
impact to groundwater levels, recharge or storage in the Seaside Groundwater Basin. Similarly,
the cumulative impacts of the Proposed Project combined with cumulative projects would have
a less-than-significant impact on groundwater levels, protective elevations at the coast, storage
capacity, and recharge.
N-2
The comment acknowledges and agrees with the impact conclusions of the Draft EIR related to
the impacts of the Proposed Project on the Seaside Groundwater Basin; no further response is
necessary.
N-3
The incorrect spelling of the MPWSP (Monterey Peninsula Water Supply Project) has been
corrected. See Chapter 5, Changes to the Draft EIR regarding pages S-35 and 4.11-101 of
the Draft EIR.

Final EIR
4-200
September 2015
N-4
See Master Response #8: Well Maintenance and Backflushing Water Amounts and Discharge
in Chapter 3, Master Responses to Comments.
N-5
The identified typographical error (last paragraph, last sentence on page 2-77 of the Draft EIR
changing the word of to or) has been corrected. See Chapter 5, Changes to the Draft EIR.
N-6
The Legend Title of Figure 2-3 on page 2-95 of the Draft EIR has been revised to indicate the
correct contents of the legend as requested in this comment. See Chapter 5, Changes to the
Draft EIR.
N-7
The terms deep zone and shallow zone in the Seaside Basin generally correlate to the
Santa Margarita Aquifer and Paso Robles Aquifer, respectively. Because contours extend into
areas where these formations do not exist, this generalized nomenclature developed by Yates
(et al., 2005) has been adopted by HydroMetrics, the Seaside Watermasters hydrogeologic
consultants that created the basin groundwater model and the source of the contours
(HydroMetrics Memorandum to Bob Holden; Subject: Groundwater Replenishment Project
Development Modeling, October 2, 2013; see Appendix C within the Draft EIRs Appendix L,
Figures 8 and 9 citing the original source). Although the two maps on Figure 2-4 in the Draft
EIR have been appropriately labeled as Paso Robles Water Levels and Santa Margarita Water
Levels, the legend on the top map has been incorrectly labeled as Deep Zone Water Elevation
contour in the legend (and should be labeled Shallow Zone water elevation). Both legends on
Figure 2-4 on page 2-96 of the Draft EIR have been revised to indicate the name of each
aquifer for the Final EIR in response to this comment. See Chapter 5, Changes to the Draft
EIR.
N-8
Page 4.1-1 of the Draft EIR has been modified to correct the typographic error as requested in
this comment. See Chapter 5, Changes to the Draft EIR.
N-9
The text in Section 4.10.2.4, page 4.10-16 (top paragraph) in the Draft EIR has been revised to
clarify that the southeasterly boundary of the Seaside Basin is also a groundwater divide that is
subject to movement. See Chapter 5, Changes to the Draft EIR.
N-10
Figure 4.10-5 has been replaced with a revised version (Figure 4.10-5rev) in response to this
N-11
Page 4.10-40 of the Draft EIR has been amended as requested in this comment to add the
following text: The activities described in the 2006 M&MP have been accomplished, and the
Watermaster has prepared an updated M&MP each year to address changing conditions and
issues of concern. These are submitted to the Court each year as part of the Watermasters
Annual Report. See Chapter 5, Changes to the Draft EIR.
N-12
See Master Response #7: Well Development/Construction Water Use and Discharge in
Chapter 3, Master Responses to Comments, for information regarding volumes and
discharge of development water pumped during construction of Proposed Project wells.
N-13
The comment references the following sentence (emphasis added):

The cumulative conditions considered for the Overall Cumulative Projects would be the same
as the combined analysis of implementation of the Proposed Project and the MPWSP with a
6.4 mgd desalination plant because all other cumulative projects are approved or mandated by
the Seaside Basin Watermaster so would occur both with the combined scenario and under
conditions expected with all other cumulative projects implemented.

Final EIR
4-201
September 2015
The sentence use of the words all other is intended to exclude the MPWSP as being one that
is approved or mandated by the Watermaster; so the Draft EIR is consistent with this comment.
N-14
Pursuant to the Final Groundwater Replenishment Regulations as discussed in Appendix D,

the project proponents must develop a proposed Response Retention Time (RRT) for inclusion
in the draft Engineering Report for the Project that will be submitted to the State Water
Resources Control Board Division of Drinking Water for approval and review by the Regional
Water Quality Control Board. A copy of the draft Engineering Report will be provided to the
Watermaster for review and comment.
N-15

the project proponents must develop a contingency plan for inclusion in the draft Engineering
Report for the Project that will be submitted to DDW for approval and review by the RWQCB.
The regulations do not specify what must be included in the Contingency Plan. Based on other
groundwater replenishment projects, typical elements of a Contingency Plan include the
following:
treatment system controls, reliability and redundancy,

critical control point monitoring,
operations during source control and treatment process upsets at the Regional Treatment
Plant and AWT Facility, and
an emergency response plan.
The regulations require the development of a response retention time (RRT), which is not a
plan, but as discussed in Appendix D, an estimate of the time needed to retain recycled water
underground to identify any treatment failure so that inadequately treated recycled water does
not enter a potable water system. Sufficient time must elapse to allow for a response that will
protect the public from exposure to inadequately treated water, and provide an alternative
source of water or remedial treatment at the wellhead if necessary. The RRT is the aggregate
period of time that includes: (1) time between treatment verification samples or measurements;
(2) time to make the measurement or analyze the sample; (3) time to evaluate the results; (4)
time to make a decision regarding the appropriate response; (5) time to activate the response;
and (6) time for the response to work.
A copy of the draft Engineering Report will be provided to the Watermaster for review and
comment. The regulations, as discussed in Appendix D, also include provisions for monitoring
and reporting to ensure that the quality of recycled water used for injection is safe the
regulations do not require storage and testing prior to injection. All of these requirements and
contingency provisions will be incorporated into the permit issued by the RWQCB for the
project.
N-16

prior to startup of operations, the project proponents must develop a plan to provide an
alternative source of water or treatment system should a groundwater replenishment project
impact a drinking water well so that it can no longer be used as a source of water supply. A
description of the plan will be included in the draft Engineering Report for the Project that will be
submitted to DDW for approval and review by the RWQCB. A copy of the draft Engineering
Report will be provided to the Watermaster for review and comment.

Final EIR
4-202
September 2015
Letter O
CITY OF SALINAS DEPARTMENT OF PUBLIC WORKS

200 Lincoln Avenue Salinas, California 93901 (831) 758-7241
June 1, 2015
Bob Holden, Principle Engineer
5 Harris Court Building D.
Monterey CA, 93940
RE: Comments on EIR for Pure Water Monterey Project
In response to the recent notification of the availability of the Pure Water Monterey DEIR, the City of
Salinas had reviewed this document particularly as they relate to the City of Salinas interests and concerns
as we know them.
This document presents our summary comments.
Overall, the document appears to be well and comprehensively prepared; it accurately represents and
describes the pertinent City of Salinas facilities, their past use and their intended future use. In Section
4.10 Hydrology and Water Quality: Groundwater, we note one possible inconsistency on page 4.10-67 at
the end of line 8 in the second full paragraph. The text refers to groundwater recharge under the City
percolation ponds at the Salinas Treatment Facility Ponds based on percolation when distributed over a
1.5-acre circular area centered at the ponds. Given that the ponds spread for over a mile along the
Salinas River and previous text in the same paragraph discusses potential water quality impacts over a
circle 1.5-mile radius surrounding the Salinas Treatment Facility. we suggest that paragraph likely needs
an editorial correction.
O-1
We note also that the proposed project and its component elements would have several positive impacts
on the local environment while benefiting the City, its residents and businesses. These benefits are
summarized below:
1.
Making more irrigation water available for the Castroville Seawater Intrusion Project (CSIP) would
decrease irrigation pumping close to Monterey Bay and hence reduce seawater intrusion trends.
Protecting the Salinas Valley groundwater basins protects the only water supply for City residents and
business, preserving public and economic health.
2.
Supporting produce production in the CSIP area will support job retention and potential job creation
for City residents and allows growing of produce that likely will be processed in some measure by the
Citys produce processing plants.
3.
Implementation of the Groundwater Replenishment Project (GWR) creates an outlet for the
increased agricultural wash water effluent. The Salinas Treatment Facility essentially had reached the
limits of its disposal capacity with recent increases in wash water influent. The additional GWR water

Final EIR
4-203
September 2015
O-2
demands will allow the City to continue expansion of its food processing industry, creating expanding
economic activity for the City and its residents.
4.
The GWR would accept diverted storm water for treatment and reuse, both flows to the Reclamation
Ditch from the Citys northern areas and to the Salinas River from the Citys southern third. This project
aspect has two benefits; it creates more water supply for the GWR with benefits described elsewhere in
this list while decreasing the potential discharge of contaminants to both the Salinas River and to
Monterey Bay. This results in an overall benefit of the environment.
5.
Helping to create a potable water supply through ASR in the Seaside Basin decreases withdrawals
from the Carmel River and creates an alternative supply for the Monterey Peninsula. This action in turn
sustains the tourist industry that employees many City residents and helps maintain the economic vitality
of Salinas.
O-2
Con't
6.
The City will divert sufficient wash water and storm water to the GWR, such that the aeration
lagoon and percolation ponds will dry completely, likely annually. This will allow the City to carry out
solids removal and other maintenance at significantly reduced cost and with greatly reduced
environmental impacts.
7.
The new operational mode for the Salinas Treatment Facility Ponds will decrease the amount of
water that infiltrates locally into the shallower aquifer. This change will have a minor, insignificant
impact on local groundwater levels with a lowering of average groundwater elevations of approximately
1.3 feet but will decrease the release of somewhat impaired water into the aquifer, resulting in a net
overall benefit.
This concludes our comments on the DEIR for this important projects. Should you have comments or
require further information, please contact me at 831-758-7390


Final EIR
4-204
September 2015
LetterO: CityofSalinas
O-1
The second full paragraph on page 4.10-67 of the Draft EIR has been amended in response to
this comment. The revision clarifies the statement in the Draft EIR that groundwater quality
impacts would be greatest near the Salinas Treatment Facility, and for this analysis the impact
area previously described for water level impacts was also used for water quality impacts: a
circle with a 1.5-mile radius centered at the Salinas Treatment Facility ponds.
O-2
The comment provides an overall opinion of project benefits and is referred to the decision
makers for their consideration.

Final EIR
4-205
September 2015
Letter P
June 2, 2015
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Mr.Robert Holden
Monterey, CA 93940
Dear Mr. Holden,
The City of Monterey has reviewed the Draft Environmental Impact Report for the Pure
Water Monterey Groundwater Replenishment Project proposed by the Monterey Regional
Water Pollution Control Agency in partnership with the Monterey Peninsula Water
Management District. Thank you for all your work on this important project for the
Monterey Peninsula.
The City fully supports this project to reutilize existing water to recharge the region's
aquifer and help to provide a long-term, safe water supply. The proposed project is a
key to helping resolve the peninsula's water supply issues The City offers the following
comments on the DEIR.
P-1
1. Table 2-22 needs to be amended to include required permits from the City of
Monterey. The table only currently recognizes permits are needed from Seaside,
Marina, Sand City and Salinas.
2. Appendix R currently illustrates the Figueroa Box Culvert Basin as flowing into Lake El
Estero (Lake), and the hydrology and hydraulic calculations appear to assume full
connection. At this time, larger flows mostly discharge to the gate valve on the eastern
side of Wharf II with only the ability for low flows to discharge to Lake. To support the
analyses in Appendix R, an infrastructure improvement to the box culvert is necessary
to allow larger flows from this Figueroa watershed to discharge to Lake. Any
improvement must still allow overflow of larger events to the Wharf II gate to prevent
localized flooding.
3. Appendix R (p.8) states that it's unclear if state water rights would be required for the
diversion of urban stormwater flows to the Proposed Project. It also states there exists
no regulatory prohibition requesting a water right from this [Lake El Estero} source.
DEIR p. 2-40 states that urban stormwater may be diverted to the sewer system
without a water rights permit. Request clarity in the Project Description on whether a
diversion from a lake system, such as Lake El Estero, requires a water right be
established, and if so, request engagement of City staff in any related water rights
discussions.
4. Currently, the EIR states various times of the year for diversion of flows- October to
April (Table 2-13), November through April (Table 2-10), and "Runoff from summer
storms would be diverted when available" (p.2-40). Clarity and internal document
consistency is needed on the parameters- volume, timing, duration, and any other
proposed parameters necessary to adequately characterize this diversion portion of
the Project Description for environmental review - are recommended. Such
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Final EIR
4-206
September 2015
parameters may also include minimum in-lake levels necessary during various
seasons to ensure habitat and vegetative protections in the lake and tributary
drainages.
5. The City is aware a relatively shallow, unconfined aquifer exists in the vicinity of Lake
El Estero, though its extent, surface connectivity/recharge, water quality, and seasonal
fluctuations are not documented nor well understood. However, recent and localized
geologic, soil, and groundwater level and quality data were collected and analyzed by
Trinity Source Group Inc. The data were collected as a result of on-going soil and
groundwater clean-up action related to legacy groundwater contamination at 951 Del
Monte Avenue, a City property located across Del Monte Avenue from the proposed
diversion facility. It's unknown, but possible that long-term and/or significant diversions
from the Lake may cause migrations of the contaminant plumes toward the lake. This
potential significant impact deserves examination and discussion in the DEIR.
6. Per City of Monterey General Plan EIR Figure 6 Major Habitat Types, the Lake El
Estero vicinity is mapped with riparian/wetland habitat. Also tributary drainages are
mapped to support Monterey Pine and Mixed Monterey Pine Forest habitat. In
association, the extent and connectivity of surface and groundwater resources and
associated environmental dynamics at work and resources present, including
watershed recharge areas and rates, potential necessary minimum in-lake water
levels and/or groundwater table elevations needed to healthfully maintain/sustain the
lake and associated drainages and biological resources should be wellunderstood/established in order to confirm no environmental impact of the proposed
project for the Lake El Estero watershed. No minimum lake elevations appear to be
defined for habitat purposes, and may be necessary for study in the DEIR.
7. The plan shows a 36-inch pipeline that wilt impact City infrastructure and require
possible relocation of storm drain and sewer lines. Be advised that significant portions
of the City's sewer system have exceeded their design life and some portions are in
excess of 100 years old. Great care will be needed in the vicinity of these pipelines.
These potentially conflicting pipeline design and relocation issues need to be
coordinated with the City.
8. The City of Monterey Public Works Encroachment Permit and/or design coordination
issues that are of concern to the City relative to construction of the proposed 36-inch
pipeline include, but are not limited to, the following:
Construction hours of work
Temporary and/or any permanent parking impacts
Staging areas and equipment/material storage areas
Haul roads
Dewatering methods and discharge plans
Vehicles , pedestrian and bicycle detours, including ADA-accessible paths
of travel during and post construction
Locations of above-ground water pipeline blow-offs and air release/air
vacuum valves
Final EIR
4-207
September 2015
P-4
Con't
P-5
P-6
P-7
P-8
Locations of any above-ground and/or surface-accessed pressure reducing

valve vaults. cathodic protection facilities, and/or other vaults
Compliance with all storm water regulations in effect at the time of permit
issuance
P-8
Con't
All Permit conditions shall be subject to approval of the City's Building Official. All
design coordination issues shall be subject to approval of the City Engineer.
9. The 17.5 MGD Monterey Pump Station identified in Figure 2-12 is not located on the
preliminary alignment plans or elsewhere in the DEIR document. Per a recent
meeting, the pump station is preliminarily planned to be located in the vicinity of the
Fairgrounds. Please include the proposed location of this pump station and analyze
any impacts in the EIR.
10. The Monterey Pipeline alignment shown in Figures S-1 and 2-39 and in the Project
Description on Page 2-79, Section 2.11 .2 (along Del Monte Boulevard and Franklin)
appears to be described in the DEIR as the preferred alignment. An alignment (along
Mark Thomas Drive, Fairground Road, and Fremont Street) is described as an
alternative in Section 6.3.2.4 on page 6-37. This alternative alignment appears to
match the alignment shown in the 2014 URS Plans available on the GWR Project
Website. Please provide updated alignment figures in the EIR and address all impacts
associated w ith the proposed pipeline alignment. Suggest that these alignments be
reversed in the DEIR such that the proposed alignment is shown in the body of the
DEIR as preferred, and the outdated alignment is included in Chapter 6 as an
alternative alignment that considered.
11 . Figure 4 .1-2 identifies the location of the "Ryan Ranch-Bishop Interconnection
Improvements (Proposedr within the City limits. The precise alignment and impacts
do not appear to have been addressed in the DEIR.
12. The preliminary plans, prepared by URS and dated May 2, 2014, identify that the
proposed pipeline wiil be installed in a bridge at the Mark Thomas/Highway 68
intersection, and that the pipeline will be installed via jacking and boring below Route
218/Fremont. However, it appears that the remainder of the alignment across the City
of Monterey will be via open cut trenching. The following locations should be
considered for jacking and boring as well:
Hartnell Gulch crossing
Intersection of Munras Avenue/Webster Street
Intersection of Fremont Street and Camino El Estero
Below Highway 1 bridge along Camino Aguajito between Glenwood Circle
and Mark Thomas Drive
Intersection of Fremont Street and Dela Vina Avenue
Intersection of Fremont Street and Ramona Avenue
Intersection of Fremont Street and Casanova Avenue
Other signalized intersections as appropriate

Final EIR
4-208
September 2015
P-
P-
P-
P-
P-
13. Please include the location, number, and types of street trees that will be removed as
part of construction and an appropriate mitigation measure for re-planting.
14. The Traffic and Transportation mitigation includes a requirement for a Traffic Control
and Safety Assurance Plan which is required to be coordinated with local agencies.
P- 4
The draft schedule shows pipeline installation from July 2016- June 2017 which will
overlap with the City of Monterey detours planned for the Highway 1/68 Roundabout
project and a major Sewer Rehabilitation project in the City of Monterey.
The construction management schedule will need to be carefully coordinated with the
City of Monterey to ensure adequate circulation during the construction period.
15. A major new pipeline will cause significant disturbance to existing paved areas
(streets, sidewalks, curbs and gutters, driveways, curb ramps, etc.). The City will
require that all surfaces be restored to existing conditions following current City
standards, including ADA requirements. Asphalt pavement will need to be restored
such that full travel lanes will be resurfaced without seams along wheel or bike paths.
16. The City also has several infrastructure repairs underway due to the passage of
Measure P and a major sewer rehabilitation project. All construction will also need to
be coordinated with these existing efforts.
17. Please coordinate with the military installations in the City of Monterey.
Thank you for this opportunity to comment on the DEIR for the Pure Water Monterey
Groundwater Replenishment Project.
Sincerely,
~~~
Mayor

Final EIR
4-209
September 2015
P- 5
P- 6
P- 7
LetterP: CityofMonterey
P-1
The Draft EIR text in Table 2-22 (page 2-89) has been updated in response to this comment.
P-2
Although Appendix R provides an analysis of the potential yield of reconfiguring/improving the

Figuero Box Culvert Basin to allow additional storm water to flow to Lake El Estero, the
Proposed Project description does not include this potential option. It was considered and
eliminated as a component due to the low yield and potential traffic and other construction
nuisance impacts of this potential source water component.
P-3
The State Board clarifies that the proposed point of diversion at Lake El Estero would require
an appropriative right from the State Board to divert up to 87 AFY into the municipal wastewater
system. Such an application will be pursued for the proposed Lake El Estero diversion if that
component is implemented as part of the Proposed Project. See changes to pages 4.18-32 and
4.18-34 of the Draft EIR in Chapter 5, Changes to the Draft EIR, wherein the relevant
changes to Section 4.18 were made to reflect the State Boards clarification on the need for
water rights for Lake El Estero.
P-4
As noted in Section 2.7.2.8 (page 2-56 of the Draft EIR), the Proposed Project would divert
stormwater flows only during any rain event in which the City would currently pump stormwater
to the outfall on Del Monte State Beach. These events may occur in any month, but are
predominantly in months of November to April. The text and tables have been updated for
consistency. See Chapter 5, Changes to the Draft EIR regarding changes to pages 2-34, 240, and 4.11-74 of the Draft EIR.
P-5
The Proposed Project would not lower the normal water level in Lake El Estero, so no change
in the relationship between shallow groundwater and surface water is anticipated. See footnote
23 on page 2-56 of the Draft EIR.
P-6
The Proposed Project would not lower the normal water level in Lake El Estero. The water
diversions to the project would be concurrent with or instead of the current diversion pumping of
stormwater to Del Monte State Beach (depending on the size of the rainfall event). See
footnote 23 on page 2-56 of the Draft EIR.
P-7
To comply with the City of Monterey municipal code, construction of the CalAm Distribution
System: Monterey Pipeline (referenced as a 36-inch pipeline in the comment) would require an
encroachment permit and/or design coordination from the City of Monterey. Prior to
implementing the proposed improvements, CalAm or its contractor would be required to receive
city approval and by doing so would be required to ensure that no unacceptable changes to the
Citys utility and infrastructure systems would occur.
P-8
The comment lists issues of concern. An impact analysis of the listed issues follows:
Proposed construction work hours are presented on pages 2-83 through 2-85 of the
Draft EIR by component of the Proposed Project. Specifically, in the City of Monterey,
the table shows the Lake El Estero source water diversion component of the Proposed
Project would be constructed during the work hours of 7 AM to 8 PM (two shifts), and
the CalAm Distribution System: Monterey Pipeline would be constructed mostly during
the daytime hours, with some nighttime construction to expedite pipeline construction
while minimizing traffic conflicts.

Final EIR
4-210
September 2015
The parking impact analysis on pages 4.17-39 through 4.17-41 of the Draft EIR shows
that there would be no parking impacts associated with operations of the Proposed
Project.
Traffic and transportation issues, including staging areas, equipment /material storage
areas, haul roads, vehicle, pedestrian and bicycle detours, during construction of the
Proposed Project are discussed and analyzed in Section 4.17 of the Draft EIR (see
pages 4.17-23 through 4.17-41).
The regulatory setting related to dewatering and discharge (including methods, plans,
and requirements) are presented on pages 4.11-32 through 4.11-37 of the Draft EIR.
The related impact analyses are presented on pages 4.11-56 through 4.11-62 of the
Draft EIR.
P-9
The comment references the 17.5-mgd Monterey Pump Station shown on Figure 2-12, an
existing wastewater pump station owned and operated by the MRWPCA. The Proposed Project
would not relocate or alter this facility. Figure 2-12 is intended to give an overview of the
MRWPCAs wastewater collection system.
P-10
See Master Response #11: Proposed Projects Relationship to the Proposed Monterey
Peninsula Water Supply Project and Master Response #12: Adequacy of Scope and Range of
Alternatives in Chapter 3, Master Responses to Comments. The analysis of the referenced
2014 URS Plans for a Monterey Pipeline located along Mark Thomas Drive, Fairground Road,
and Fremont Street, is provided in Chapter 6, Alternatives to the Proposed Project (called the
Alternative Monterey Pipeline) at a project level of detail enabling decision makers to approve it
based on this EIR. The conclusions in the Draft EIR state that the Alternative Monterey Pipeline
is environmentally superior to the construction of both the CalAm Distribution System: Transfer
and the Monterey pipelines (i.e., with the Alternative Monterey Pipeline, neither the proposed or
alternative Transfer Pipelines would be necessary).
P-11
The comment references Ryan Ranch-Bishop Interconnection Improvements, which is not a

component of the Proposed Project. The referenced improvements are a component of the
Proposed Monterey Peninsula Water Supply Project (MPWSP) (with 6.4 mgd desalination
plant) that is one of the cumulative projects considered in the Draft EIR for the Proposed
Project. The Draft EIR addresses the combined impacts of the Proposed MPWSP (with 6.4
mgd desalination plant) that includes the Ryan Ranch-Bishop Interconnection Improvements
component. See Master Response #11: Proposed Projects Relationship to the Proposed
Monterey Peninsula Water Supply Project in Chapter 3, Master Responses to Comments.
P-12
The requested additional jack and bore locations along the CalAm Distribution System:
Alternative Monterey Pipeline is referred to CalAm and decision makers for their consideration.
See also Master Response #11: Proposed Projects Relationship to the Proposed Monterey
Peninsula Water Supply Project and Master Response #12: Adequacy of Scope and Range of
P-13
The comment requests information on tree removal necessary for the Proposed Project. On
page 4.2-30, the Draft EIR shows that the Coastal Booster Pump Station construction could
result in removal of four to five mature cypress trees. No other tree removal is anticipated;
however, there is the potential for the need to remove or trim other trees at or near the
proposed construction sites. Therefore, page 4.5-95 of the Draft EIR states that construction of
the Proposed Project may result in tree trimming and/or removal, although the exact number of
trees will not be known until final engineering is completed. The components within the City of
Monterey include the Lake El Estero source water diversion that would not require any tree
removal and the CalAm Distribution System: Monterey Pipeline that is proposed to be
constructed within roadway rights of way and thus does not currently include any tree removal.
If final design of that component shows that tree removal would occur, then CalAm would be

Final EIR
4-211
September 2015
required to comply with the City of Monterey Municipal Code Chapter 37 (Preservation of Trees
and Shrubs) as described on page 4.5-45 of the Draft EIR.
P-14
As requested by the comment, the project proponents will work closely with the City of
Monterey to ensure adequate circulation during the construction phases.
P-15
The Draft EIR addresses restoration of roadway surfaces to pre-construction conditions in

project description at page 2-81. In addition, Mitigation Measure TR-3 on page 4.17-39 and in
summary Table S-1 (page S-22) of the Draft EIR has been modified to require curb to curb
restoration of roadways where applicable, and in the City of Monterey that asphalt pavement of
full travel lanes be resurfaced without seams along wheel or bike paths as requested in this
comment. See Table S-1Revised in Chapter 5, Changes to the Draft EIR.
P-16
See the response to comment P-14.
P-17
The project proponents will coordinate with the military installations and the City of Monterey for
those project components that are located within or adjacent to federal lands.

Final EIR
4-212
September 2015
Letter Q
Ian Crooks
P 831.646.3217
511 Forest Lodge Rd
F 831.646.4367
Suite 100
E Ian.Crooks@amwater.com
Pacific Grove, CA 93950

www.amwater.com/caaw
June 5, 2015
via e-mail to: gwr@mrwpca.com

Monterey, CA 93940
Re: Pure Water Monterey Groundwater Replenishment Project Draft Environmental Impact
Report (DEIR)
Dear Mr. Holden:

As a potential component of the potable water supply for the Monterey Peninsula, California
American Water has significant interest in the viability and reliability of the Pure Water Monterey
Groundwater Replenishment Project (Project). California American Water has been working for
nearly three decades on securing adequate, safe and reliable water supplies for the Monterey
Peninsula. While desalination will be the major new source of water for the Monterey Peninsula,
California American Water supports the goals of the State Water Resources Control Boards
Recycled Water Policy to increase the use of recycled water by 1 million acre-feet per year over
2002 volumes by the year 2020 and by 2 million acre-feet per year by the year 2030. The
Project, as described in the DEIR would be a small but important part of reaching that goal.
It is within that context that California American Water submits the following comments intended
to ensure that all components envisioned to provide the Monterey Peninsula with a diverse and
reliable water supply achieve their intended goals.
Source Water Availability
1. Please include in the Final EIR additional information on the water rights strategy
referenced in the Reclamation Ditch Yield Study. The Reclamation Ditch Yield Study
suggests multiple approaches to obtaining the required water rights, but provides little
detail.

Final EIR
4-213
September 2015
Q-1
2. Please include in the Final EIR the data and assumptions that were used to calculate the
estimated volumes of agricultural wash water that would supply the Advance Water
Q-2
Treatment facility. We were unable to find information on the agricultural wash water
volumes beyond the table in Appendix B.
Discussion of the Seaside Basin Adjudication
3. Please clarify in the Final EIR whether the Project (which will provide non-native water to
the basin) will result in replenishment as replenishment is defined in the judgment.
Under the decision adjudicating the basin, replenishment with non-native water occurs
when the water is added to: (a) offset overproduction; or (b) decrease the amount of
Q-3
water pumped under a production allocation. Here, the GWR water will not offset
overproduction or decrease the amount of water pumped under a production allocation.
Instead, it will augment the water supply by increasing the annual amount of water
available to CAWC for production. As described by Hydrometrics in its October 2, 2013
letter to Bob Holden of MRWPCA The GWR will recharge an average of 3,500 acre-feet
(AF) of water into the Seaside groundwater basin throughout the year. This recharge will
be matched by an increase of 3,500 AF per year of additional extraction from the basin
and the recharge of GWR water is intended solely for storage and reuse in the short
term
4. Please clarify in the Final EIR whether the Project will assist in preventing seawater
intrusion in the Seaside Basin. For example, see Todd Groundwater Proposed Project
Recharge Impacts Assessment Report (p. 53) (contained in Appendix L) which concludes
Q-4
the general rise in water levels occurs under both Project and No Project conditions due
to the decrease in overall basin pumping as required under the adjudication, but also
states that during drought cycles simulated water levels are 1-9 feet lower with the
Project than under No Project conditions.
5. Please clarify in the Final EIR that the Seaside Basin was adjudicated in 2006, not 2012,
Q-5
and triennial reductions began in 2009 not in 2012. The first paragraph on page 5-2
suggests the Seaside Basin was adjudicated in 2012.
6. Please clarify in the Final EIR the effects of the judgment on non-overlying appropriators.
Section 2.3.2.2 on page 2-9, second full paragraph should state that all pumpers except
overlying uses must reduce pumping through triennial ramp down, not just CalAm.

Final EIR
4-214
September 2015
Q-6
Discussion of the Carmel River

7. Please clarify in the Final EIR the basis for the conclusion that California American
Waters Carmel River well network was constructed in response to reservoir
sedimentation. We agree that there were significant increases in sedimentation as a
result of various episodic events, but we dont have information that correlates CPUC
Q-7
approval to construct additional wells to reservoir sedimentation. As was noted on Page

22 of Order 95-10 and supported by CalAms submissions to the State Water Resources
Control Board in that proceeding, much of the well network was constructed after 1960 in
response to growth. Many of the wells were drilled under order of the CPUC to ensure
CalAm had adequate supplies to serve its growing customer base.
8. Please clarify in the Final EIR the basis for the amount of non-CalAm diversions from the
Carmel River. The Draft EIR states that all other diversions from the Carmel River total
only 2,200 to 2,400 afa. Per Table 12 in Decision 1632, the SWRCB found that there
Q-8
were claims to over 3,000 afa for riparian users plus another 2,200 afa in Table 13 for
non-riparian claims over and above CalAms Table 13 claim. This far exceeds the 2,200
to 2,400 afa contained the Draft EIR.
9. Please clarify in the Final EIR the MPWMDs regulatory authority relating to the Carmel
River. CalAm agrees that the MPWMD is one of many agencies that regulate production
Q-9
and use of Carmel River water; however, CalAm has ultimate responsibility for the
management and operation of its water system.
Environmental Impacts
10. Please clarify in the Final EIR the sources of PCBs in the outfall effluent. The Draft EIR
could be construed as concluding that desalination creates the PCBs that are contained
Q-10
in the treatment plant effluent. The MPSWP standing alone would cause this significant
impact only because PCB levels currently existing in the ocean water exceed the Ocean
Plan limits, and the desalination process would concentrate the existing PCBs above
background ocean water in the desalination plant brine. The desalination process by itself
contributes no additional PCBs to the outfall effluent.
11. Please clarify in the Final EIR the surface disturbance for Injection Wells. In Section
2.10.2.3, the last paragraph seems to suggest that the only surface disturbance would be
for the 14-inch back flush pipeline, but then discusses the need for a foundation for the
electrical control building. Would there be surface disturbance for the electrical control
building foundation?

Final EIR
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September 2015
Q-11
12. Please clarify in the Final EIR the visual impacts associated with the Monterey Pipeline.
Q-12
Table 4.2-1 and the discussion on pages 4.2-13 and 4.2-14 seem to suggest that the
Monterey Pipeline would have permanent visual impacts, yet the pipeline would be buried
and not visible once construction is completed.
13. Please clarify in the Final EIR the source of visual impacts from the injection well
facilities. On Page 4.2-39, within the Injection Well Facilities paragraph, it is unclear
Q-13
which existing operations buildings are being referenced because both CalAm (next to
Seaside Middle School) and the MPWMD (next to the Santa Margarita wells) own
buildings that house operation and control equipment in that area.
14. Please provide additional information Salinas Valley Basin recharge. The last paragraph
on page 2-13 says there is no groundwater recharge in the Pressure Zone, but most of
Q-14
the pumping is in the Pressure Zone. If there is no recharge within that zone, what is the
original source of water that is pumped from that zone?
Regulatory Requirements Applicable To AWT Operation
15. Please provide additional information on the regulatory requirements applicable to AWT
backwash water disposition. Section 2.8.2.12 states that the AWT facility contemplates
backwashing certain treatment facilities and returning that water to the head of the
treatment plant, but does not specify the source of the backwash water. Because this
Q-15
system is using surface water, does the Filter Backwash Rule apply, limiting the reuse of
backwash water to the head of the plant? This source water stream would be highly
likely to accumulate Cryptosporidium oocysts.
16. Please provide additional detail on the AWT Facilitys design with regard to system
redundancy. Table 2-18 suggests that the AWT facility will have the ability to process a
greater volume of water on a daily basis than is necessary to meet the annual volume
commitment to CalAm. Please provide additional information on how that capacity will be
designed to maximize redundant treatment equipment such that supply interruptions due
to equipment failures and maintenance are minimized, thereby reducing the potential for
adverse impacts to the Seaside Basin, the Carmel River and other water supply facilities.

Final EIR
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September 2015
Q-16
Conclusion
We appreciate MRWPCA considering our comments and would be happy to meet with staff to
further discuss our comments.
Respectfully submitted,
Ian Crooks
Engineering Manager

Final EIR
4-217
September 2015
LetterQ: CaliforniaAmericanWaterCompany
Q-1
Section 4.18 and Appendix C of the Draft EIR as modified in this Final EIR (see Appendix CRevised in Chapter 5, Changes to the Draft EIR) provides additional detail about the water
rights strategy and status. The Reclamation Ditch Yield Study is a technical report addressing
how much water may be diverted from the Reclamation Ditch/Tembladero Slough system, and
the potential impacts of removing flows from the system. The water rights permitting process is
mentioned in that report only to explain why multiple diversion rates were used in the analysis
and to document that the technical analysis considered the potential for other legal diverters to
use water in the system. The MCWRA submitted a water right permit application (number
A032263) for diversions from the Reclamation Ditch/Tembladero Slough and from the Blanco
Drain, and in the July 29, 2015 amended applications were submitted to divide the water rights
application into five separate applications.
Q-2
The 2017 agricultural wash water flows were estimated by plotting the measured flows from
2007 to 2013, and calculating the trend line. This growth rate was then used to project forward
to 2017. The following text has been added to Appendix B (see Appendix B-Revised):
Annual inflows to the SIWTF were analyzed and a projection of year 2017 flows was prepared
by the MRWPCA1, as shown in the first row of Table 1, below. Recorded monthly inflows for
calendar years 2007-2013 were tabulated and the annual averaged plotted (see Figure 1). A
linear trend line was used to estimate future flows, and the projected annual average of 3.37
mgd in 2017 was used to scale the 2013 monthly inflow values. As expected, the recorded
agricultural wash water flows in 2014 (included on Figure 1) fell on the trend line.
The trend line and recorded flows (shown as a red circle) referenced in this text are on Figure
3-A within Master Response #3: Availability, Reliability, and Yield of Source Water Supplies in
Q-3
The judgment of the Seaside Basin adjudication defines both natural replenishment and
artificial replenishment. Portions of the judgment applicable to the comment are reproduced
below:
Artificial Replenishment means the act of Non-Native Water to be added to the Groundwater
supply of the Seaside Basin through Spreading or Direct Injection to offset the cumulative OverProduction from the Seaside Basin in any particular Administrative Year (Case M66343,
Decision, III., A., 3., March 27, 2006).
Because the Proposed Project will not offset production that is currently occurring, but will allow
for new additional production through extraction of injected water, it seems reasonable that the
Proposed Project would not be considered Artificial Replenishment as defined by this part of
the judgment.
The word replenishment was used in the Draft EIR in the title of the project for several
reasons, but not to imply that the Proposed Project would result in Artificial Replenishment that
would satisfy the above component of the judgment. Specifically, the term was intended to
maintain consistency with the relevant water quality regulatory programs under the jurisdiction
of the SWRCB DDW (i.e., this agency references the requirements as the Groundwater
Replenishment Regulations (or DPH-14-003E Groundwater Replenishment Using Recycled
Water). In addition, the name is consistent with a very similar project called Orange County
Water Districts Groundwater Replenishment System that has been operating for the last seven
years. The term replenishment has been clarified within the context of this project and its
difference from the Seaside Basin Adjudications use of the word. See the revision to page S-1
and 1-1 of the Draft EIR in Chapter 5, Changes to the Draft EIR.
Q-4
As stated in the Draft EIR, the Proposed Project does not prevent seawater intrusion in the
Seaside Basin (page 4.10-74). As discussed in Section 4.10 and Appendix L of the Draft EIR,
groundwater modeling indicates that resulting water levels from operation of the Proposed
Project are both lower and higher at various time periods than without the Proposed Project,

Final EIR
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September 2015
but that lower water levels are not significant and do not adversely impact the potential for
seawater intrusion. More information is provided in the Draft EIR as follows: threshold for
groundwater impacts were presented on page 4.10-45; approach on pages 4.10-47 to 4.10-48;
impact analyses on pages 4.10-64 through 4.10-65 and 4.10-74 through 4.10-75; detailed
groundwater analyses to support Draft EIR conclusions in Appendix L, Recharge Impacts
Assessment at pages 53-54 and 75-77; and groundwater modeling was done by Hydrometrics
and was included in Appendix C of Appendix L. The Proposed Project, as modeled in the Draft
EIR, does not appear to assist directly with the prevention of seawater intrusion in the Seaside
Basin; nor does it increase the risk. Local impacts to water levels are influenced by locations
and pumping rates of existing wells.
Q-5
Text of the Draft EIR has been updated in response to this comment. See changes to page 5-2
of Draft EIR (first paragraph) in Chapter 5, Changes to the Draft EIR.
Q-6
Text of the Draft EIR has been updated in response to this comment. See changes to page 2-9
of Draft EIR (second full paragraph) in Chapter 5, Changes to the Draft EIR.
Q-7
The second full paragraph on page 2-10 of the Draft EIR has been amended as follows in
response to this comment and comment I-4. See Chapter 5, Changes to the Draft EIR.
Q-8
The referenced sentence in section 2.3.2.4 on page 2-10 of the Draft EIR describes estimated
summer and fall extractions based on information provided by the Monterey Peninsula Water
Management District. To respond to this comment, the second paragraph of Section 2.3.2.4
has been amended. See changes to page 2-10 of the Draft EIR in Chapter 5, Changes to the
Draft EIR
Q-9
As requested in this comment, the third paragraph of section 2.3.2.1 on page 2-7 of the Draft
EIR has been amended in response to this comment. See changes to page 2-7 of the Draft EIR
in Chapter 5, Changes to the Draft EIR.
Q-10
This comment states the Draft EIR could be construed as concluding that desalination creates
the PCBs that are contained in the treatment plant effluent. The Draft EIR on page 4.11-98
states the following related to PCBs and ocean discharges:
three types of exceedances were identified:
(1) PCBs, which are present in relatively high concentrations in the worst-case ocean
water samples, were predicted to exceed the Ocean Plan objectives in several
scenarios for the discharges from GWR Project combined with the MPWSP 6.4 mgd
desalination plant at times when the desalination brine from the MPSWP represents a
relatively large fraction (approximately 40% or more) of the total discharge water,
The Proposed Project would not result in a considerable contribution to the significant
cumulative impact pertaining to discharge of PCBs. The MPSWP standing alone would cause
this potentially significant impact, due to PCBs in existing in ocean water, which would be
concentrated at levels above background ocean water in the desalination plant brine.
As indicated in the comment, the worst-case PCB concentrations as measured in the ocean by
the CCLEAN program exceed Ocean Plan objectives in the existing condition and that the
reverse osmosis process would increase concentrations in desalination brine even higher.
Additional water quality data or pilot testing may demonstrate that the desalination project brine
discharge would not result in concentrations of PCBs that would exceed ocean plan objectives

Final EIR
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September 2015
(i.e., 1.9x10-5 or 0.000019 ug/L at the edge of the zone of initial dilution). For example, if water
quality data from the test slant well showed lower PCB concentrations in the desalination plant
influent, this potential exceedance may not occur. In either case, the Proposed Projects
reverse osmosis concentrate would not contribute considerably to this potential significant
cumulative impact because it would increase dilution and reduce the overall concentration of
PCBs in the combined effluent stream (i.e., through both increasing the buoyancy of the
discharge plume and through in-pipe dilution).
Q-11
Page 2-77 of the Draft EIR has been modified to be more explicit about the construction
disturbance area for the ancillary facilities needed for the Injection Well Facilities. (i.e., the
sentence was intended to be related to the electrical conveyance facilities, only). The
electrical/pump motor control buildings at each site would require additional construction
disturbance area, as is shown in the changes to page 2-77 of the Draft EIR in Chapter 5,
Q-12
The Monterey Pipeline line item in Table 4.2-1, on page 4.2-7, and page 4.2-17 of the Draft EIR
describes the visual quality, affected viewers and exposure conditions and the overall visual
sensitivity of the Monterey Pipeline site as moderate in accordance with the approach to the
aesthetic impact assessment. The discussion on pages 4.2-13 and 4.2-14 of the Draft EIR is
related to the Coastal Alignment option of the Product Water Conveyance system that does
include a pump station, not the Monterey Pipeline. Permanent aesthetic impacts (in terms of
impacts on the visual character or quality of the sites) of the Monterey Pipeline were found to
have a less-than-significant impact related to scenic resources (see page 4.2-39 of the Draft
EIR) based on all facilities being buried and not visible once construction is complete. The Draft
EIR conclusion is, therefore, consistent with the comment.
Q-13
The discussion of the permanent visual impacts of the injection well facilities references a
nearby Aquifer Storage and Recovery Project operations building located nearby as an
example of the type of building (including the architectural treatment) proposed to be
constructed at each of the four (4) injection well facility clusters for the Proposed Project. Figure
4.2-2 of the Draft EIR shows a photosimulation of one of the proposed electrical control
buildings at the Injection Well Facilities site. The conclusion of the impact analysis is that the
Proposed Project would result in a less-than-significant impact on the visual character of the
area and surroundings due to the moderate visual change/contrast and moderate overall visual
sensitivity.
Q-14
The Draft EIR states the groundwater basin is recharged in all but the Pressure Subarea which
has a clay layer above the major water bearing layers. The third and fourth sentences in the
last paragraph on page 2-13 of the Draft EIR have been replaced in response to the question in
this comment as shown in Chapter 5, Changes to the Draft EIR.
Q-15
Per Section 2.8.1.1 of the Draft EIR (pages 2-58 to 2-19), the use of backwash water is
identified for the following treatment processes: (a) biologically active filtration, and (b)
membrane filtration. The backwash waters from the biologically active filters and the membrane
filters would be returned to the Regional Treatment Plant Headworks. The backwash water
would then be retreated through the primary and secondary treatment. As has been
demonstrated elsewhere (Rose et al., 2004), removal of Cryptosporidium oocysts through
primary and secondary wastewater treatment is expected to be more than 90% (1-log removal),
meaning the raw wastewater would be expected to have at least ten times more oocysts then
the treated secondary effluent. Hence, the backwash waste return flows are expected to have
Cryptosporidium oocysts that are less than or equal to the raw wastewater, and thus no
accumulation of oocysts are expected through the system.

Final EIR
4-220
September 2015
The U.S. EPA Filter Backwash Rule does apply to wastewater treatment or water recycling
facilities. California Code of Regulations, Title 22, Section 60320.208 specifies the pathogen
control criteria for subsurface application of recycled water, including Cryptosporidium oocysts.
As discussed in the Draft EIR (Chapter 3 and Appendix D), the Project meets these regulations,
and the AWT Facility alone would achieve pathogen reduction credits of 13.5 for virus, 11.5 for
Giardia cysts, and 11.5 for Cryptosporidium oocysts, which are greater than the credits required
by the Title 22 Criteria.
Q-16
This comment asks for additional detail on the AWT Facilitys design with regard to system
redundancy. As stated in the Section 2.8.1.1 of the Draft EIR:
The AWT Facility is expected to be able to produce water at up to 90% of design capacity, on
average, due to some anticipated down time for membrane clean in place practices and
repairs. The down time is assumed to be evenly distributed each month, though planned events
would be scheduled for times when the least source water is available.
Redundancy with respect to treatment capacity would be addressed through design by having
the ability to turn up the system capacity to compensate for system downtime for maintenance
activity and equipment failures. The Proposed Project would not need to meet demands on a
daily basis, as the product water would be stored in the groundwater aquifer for a period of
months. This storage time would act as a buffer between the short-term variances in production
rates and short-term variations in water demands. Each unit process would be designed to
operate at up to 4.0 million gallons per day when producing a peak capacity to compensate for
any downtime, whereas the overall average production is expected to be up to approximately
3.3 million gallons per day (3,700 acre-feet per year). In addition, to the degree reasonable,
redundant equipment and parts would be housed onsite to minimize the necessary downtime to
repair failed parts.

Final EIR
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September 2015
Letter R
May 20, 2015

Monterey, CA 93940
SUBJECT:
DEIR FOR PURE WATER MONTEREY GROUNDWATER

REPLENISHMENT PROJECT
Dear Mr. Holden:

LandWatch Monterey County reviewed the DEIR and has the following comments:
Cumulative Project List
1.
2.
Laguna Seca Villas (p.4.1-11) is no longer a pending or probable project having been
withdrawn in approximately 2010.
Harper Canyon adjacent to Ferrini Ranch for 27 units should be added to the list. The
project was approved in April 2015.
R-1
R-2
Air Quality and GHG Emissions

3.
Table 4.3-4, Air Quality Significance Thresholds shows the CO
threshold as 5502. This appears to be a typo since the threshold is 550 lbs/day.
Additionally, this threshold only applies to stationary sources, not indirect sources.
4.
R-3
The DEIR finds, Construction of the Proposed Project would result in a one-time
emission total of up to 6,039 MT of CO2eq during the 18 month construction period. The R-4
Monterey Bay Unified Air Pollution Control District (MBUAPCD) does not have
adopted nor recommended quantified thresholds for assessing the significance of GHG
emissions during construction. MBUAPCD staff recommended including construction
emissions within operational totals based on the 30-year amortization to provide a full
analysis of construction and operational GHG emissions (Clymo, 2014). (p. 4.3-29).

Final EIR
4-222
September 2015
We disagree with averaging GHG emissions over 30 years since the emissions would
actually occur during an 18 month period. This is the period during which emissions
would affect climate change. Averaging emissions over 18 months would exceed the
threshold of significance of 2,000 metric tons of CO2eq per year (p. 4.3-16). We also
note that the construction period is identified as 18 to 21 months on p. 4.15-6.
R-4
Con't
5.
The DEIR finds there are no locally adopted Greenhouse Gas Emissions Reduction Plans R-5
(p. 4.3-32). The City of Gonzales has an adopted Climate Action Plan.
6.
The DEIR finds the project would not result in a cumulatively considerable contribution
to GHG emissions and global climate change because project greenhouse gas emissions
would be below the significance threshold as discussed. As noted above, we disagree
that construction emissions should be averaged over 30 years, and we note that the
threshold of significance would be exceeded. Further, there is no de minimis level to
identify a substantial contribution to a cumulative GHG significant impact such as used
in the DEIR. At over 6,000 MT of CO2eq during the 18 month construction period, this
project when combined with all those identified on the cumulative project list would
result in a substantial contribution to climate change.
R-6
Alternatives
7.
The No Project alternative is defined as a continuation of existing conditions as well as

conditions that are reasonably expected to occur in the event that a Proposed Project is
not implemented. This definition appears to be based on the Monterey Peninsula Water
Supply project as a whole, and not just the Groundwater Replenishment Project. This
description is inconsistent with the DEIR description of the Proposed Project:
The Pure Water Monterey Groundwater Replenishment Project is a water supply
project that would serve northern Monterey County. The project would provide:
1) purified recycled water for recharge of a groundwater basin that serves as
drinking water supply; and 2) recycled water to augment the existing Castroville
Seawater Intrusion Project crop irrigation supply.(p. 1-2)
Since Cal-Am must develop a water supply alternative under orders from the State Water
Resources Control Board, the No Project Alternative to the project as described in the
DEIR would be a larger desalination plant. At a minimum, the No Project alternative
(larger desalination plant) as defined herein would have significantly larger impacts on
GHG emissions than the Proposed Project because of increased energy demands.
Additionally, the No Project Alternative would have greater impacts related to brine
disposal since under the Proposed Project (GWR), the desalination brine from the
desalination plant would be significantly diluted as a result of mixing with GWR brine.
Because GWR will probably be completed prior to the proposed desalination facility, the
likelihood of forestalling State penalties is increased. Finally, we expect that there may be
other benefits from the proposed project in comparison to a larger desalination plant.

Final EIR
4-223
September 2015
R-7
If this definition of a No Project Alternative is rejected, than an alternative based on a

larger desalination plant should be analyzed.
Thank you for the opportunity to review the referenced document.
Sincerely,
Amy L. White
Executive Director

Final EIR
4-224
September 2015
R-7
Con't
LetterR: LandWatch
R-1
Table 4.1-2 on page 4.1-11 and Figure 4.1-1 on page 4.1-21 of the Draft EIR have been
amended as requested. See Chapter 5, Changes to the Draft EIR.
R-2
Table 4.1-2 on page 4.1-11 and Figure 4.1-1 on page 4.1-21 of the Draft EIR have been
amended as requested. See Chapter 5, Changes to the Draft EIR. In addition, the cumulative
impact analyses on pages 4.9-49 and 4.14-58 of the Draft EIR was amended to reference the
Harper Canyon Project in addition to the Ferrini project as both projects should be referenced in
the same cumulative impacts discussion rather than just Ferrini (mentioned in both Section 4.14
Noise and Vibration and in the 4.9, Hazards and Hazardous Materials).
R-3
Table 4.3-4 on page 4.3-16 of the Draft EIR has been amended to address this comment. The
CO threshold is 550 lbs/day; the 2 in the number was intended to be a superscript identifying
that note 2 was applicable to that number. That note was also amended to clarify the
applicability of the threshold. See Chapter 5, Changes to the Draft EIR.
R-4
As discussed on page 4.3-15 of the Draft EIR (last paragraph, emphasis added), As of March
2015, MBUAPCD has not adopted significance thresholds for GHG emissions. In February
2013, MBUAPCD staff presented threshold options to the MBUAPCD Board and an analysis of
the options evaluated. In February 2014, MBUAPCD staff proposed the following options for
operational significance thresholds for land use projects: (1) a bright-line threshold of 2,000
metric tons CO2e per year, (2) incorporation of mitigation measures to reduce GHG emissions
by 16%, or (3) compliance with an applicable adopted GHG reduction plan/climate action plan
(Monterey Bay Unified Air Pollution Control District, 2014). There are no adopted GHG
reduction plans or climate action plans that would apply to the Proposed Project; therefore the
third option would not be applicable to the Proposed Project. A threshold of 10,000 metric tons
CO2eq per year was recommended for stationary source projects that are subject to MBUAPCD
permitting requirements; however, the Proposed Project is not considered a stationary source
project so this threshold would not be applicable to this analysis.
The evidence supporting the MBUAPCD staff recommendations in February 2013 and
February 2014 is considered by MRWPCA to constitute substantial evidence. Based on the
evidence provided by the MBUAPCD staff recommendation, this EIR first considers whether the
Proposed Projects GHG emissions would be below 2,000 MT of CO2e per year including
amortized construction emissions. If the Proposed Projects GHG emissions are determined to
be above 2,000 MT of CO2e per year, this EIR would then consider whether GHG emissions
have been reduced at least 16% below business as usual emissions due to alternative energy
use and energy efficiency measures. If project GHG emissions are below 2,000 MT of CO2e
per year, or if GHG emissions have been reduced at least 16% below business as usual
emissions, the project would be considered to have less-than-significant GHG emissions. A
less-than-significant impact would mean that the Proposed Project would not make a
cumulatively considerable contribution to the environmental effects related to emitting GHGs
(i.e., climate change and the associated adverse effects of climate change).
For this EIR, the lead agency, MRWPCA, chose to adopt the 2,000 metric tons CO2e per year
as the threshold of significance for this project based on the substantial evidence provided in
the MBUAPCD staff recommendations. These recommendations included the February 2013
and February 2014 staff reports, in addition to personal communication with District staff (Amy
Clymo, 2014) that supported the use of an operational bright line threshold of 2,000 MT CO2eq
including amortizing construction emissions. This methodology is the typical practice of land
use jurisdictions throughout California when preparing EIRs that use a bright line threshold for
operational significance thresholds. Furthermore, one-time construction emissions would not
have a considerable contribution to a cumulative (i.e., global) greenhouse gas emissions based

Final EIR
4-225
September 2015
on substantial evidence for thresholds recommended by numerous air districts throughout

California.
R-5
The text of the Draft EIR on page 4.3-32 has been amended to say that although no project
components are located in areas with adopted climate action plans, the City of Gonzales has
an adopted greenhouse gas reduction plan. See Chapter 5, Changes to the Draft EIR.
R-6
See the response to comment R-4.
R-7
The comment states that since Cal-Am must develop a water supply alternative under orders
from the State Water Resources Control Board, the No Project Alternative would be a larger
desalination plant. The comment further provides an opinion that this definition of the No
Project alternative (larger desalination plant) would have significantly larger impacts on GHG
emissions than the Proposed Project because of increased energy demands, greater impacts
related to brine disposal since under the Proposed Project, the desalination brine from the
desalination plant would be diluted as a result of mixing with Proposed Project brine.
The Draft EIR, Page 6-12, states that the Monterey Peninsula Water Supply Project
(Desalination Project) if implemented, could result in more severe adverse environmental
impacts compared to operation of the GWR Project in the areas of marine water quality and
marine biological resources, in particular because brine disposal from the desalination plant
would adversely affect ocean resources absent mitigation.
Discussion of the No Project Alternative is provided in Master Response #12: Adequacy of
Range and Scope of Alternatives in Chapter 3, Master Responses to Comments.
This comment also opines that the Proposed Project would likely be completed prior to the
proposed desalination facility, and thus, the likelihood of forestalling State penalties is
increased. The comment regarding the timing of the Proposed Projects impact on State
potential penalties is noted however is not a comment on the environmental impacts of the EIR
under CEQA. Additionally, the opinion expressed in the comment letter that there may be other
benefits from the Proposed Project in comparison to a larger desalination plant is referred to
decision makers for their consideration.

Final EIR
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September 2015
Letter S
FARM BUREAU
MONTEREY
June 1, 2015
Att: Robert Holden, Principal Engineer
Monterey, CA 93940
VIA E-mail: gwr@mrwpca.com
RE:
Pure Water Monterey Draft Environmental Impact Re port
Dear Mr. Holden:

Monterey County Farm Bureau represen ts family farmers and ranchers in the
interest of protecting and promoting agriculture throughout our County. We
strive to improve the ability of those engaged in production agriculture to provide
a reliable supply of food and fiber through responsible stewardship of our local
resources.
Monterey County Farm Bureau recognizes the benefits of any additional water
resource projects th at improve the reliability of water supplies not only for
irrigation purposes but also for municipal use in other areas of the County. A
cooperative attitude of developing these resources is important to security of our
future water supplies. The proposed project may contribute to stabilizing a
number of water supplies for various uses, if specific issues can be addressed,
as discussed in this comment letter. The example set by Orange County and
their groundwater recharge process defines the parameters of reclaiming water
for future use and provides insight into how multiple benefits can be gained for
both water supply and salt water intrusion reduction. We support the use of
groundwater replenishment as a further development of our combined water
resources .
The focus of our comments on the Pure Water Monterey Draft Environmental
Impact Report will be on three areas of project analysis: reliability of the source
water portfolio, capacity of the Castroville Seawater Intrusion Project (CSIP), and
S-1
S-2
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Final EIR
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FARM BUREAU
MONTEREY
reliance on the Brown and Caldwell "State of the Salinas River Groundwater
Basin" Report.
S-2
Con't
Source Water Reliability
Generally, the Draft Environmental Impact Report does not consider impacts if
there is a lack of water supply. Facilities will be built, pipelines installed to
transport water, and a smaller desalination facility will be built by California
American Water to accommodate the volume of water generated by this proposed
project. Specifically, California American Water will be spending earnest money
on connections to this project when there is no reliance that the source water
portfolio will supply water on a continuous basis. Because the proposed project
is tied into the Monterey Peninsula Water Supply Project as a component project,
mainly to determine the size of the desalination facility, the lack of a reasonable
reliance on source water puts the associated project at risk, and thus, the water
supply volume to be provided as replacement water for the Carmel River
diversions.
Salinas Industrial Wastewater Conveyance and Treatment System
The proposed project intends to make use of waters generated through this
system of capture from Salinas agricultural processing facilities that are
dependent on the local agricultural sector for vegetables and leafy greens packed
in their various processes. This element of the agricultural community came
about due to consumer demand for prepackaged solutions that afford
consumption of fresh vegetables and salads in a convenient, easy-to-prepare
package. While these products continue to be driven by consumer demand, the
processing of these products utilizes water that currently cannot be recycled or
reclaimed. Subject to changes in food safety measures and product handling,
the water utilized in these processes may become available for reuse through an
approved system that ensures pathogens are not transferred between process
cycles. Subject to these changes and the continuing public pressure to reduce
water use in processing of packaged foods, this water supply may at some point
in time be reduced or eliminated as techno:ogy advances the ability to clean this
water for reuse. The processing facilities currently discharging the 'wash water'
may determine that, in their best interest, it is of benefit to hold and recycle this
water rather than discharging it to the Salinas reclamation ponds.
S-3
S-4
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FARM BUREAU
MONTEREY
Thus, this water supply could become interruptible due to changing business
practices, consumer demand, and public perception of water recycling.
Additionally, the processing facilities are private enterprises subject to changes
in business trends and functionality. There is no guarantee that these
processing facilities will remain in the Salinas Valley area, will continue on a
year-round basis, or will process the same quantities of product as currently
managed.
S-4
Con't
This proposed project has no control over the amount of 'wash' waste water that
will be provided to the Salinas Reclamation Ponds, and thus, to the groundwater
replenishment facilities at MRWPCA. At best, this water can be considered a
temporary resource for the proposed project and should be termed ultimately as
interruptible.
Excess Waste Water intended for but not utilized by CSIP
Seasonally, water processed by MRWPCA intended for CSJP is not fully utilized
by farmers in the approximately 12,000 acres of this project, mostly due to winter
rains that reduce the need for irrigation and field preparation practices. The
proposed project intends to utilize this excess water for purposes of the
groundwater recharge process, which only happens consistently during wet
winter months. In view of the last four years of drought and the lack of rainfall,
demand for irrigation water has remained high during months which normally
are serviced by storm event months. Thus, this excess water is not really excess
in each and every year, and indeed has not been the case for the past four years.
Mild winter temperatures have allowed farming operations to prepare fields
earlier in the spring season, contributing to the demand for CSIP water during
winter months.
S-5
The proposed project intends to rely on this water supply as constant, when in
fact it should be termed as interruptible. CSJP has a contractual right to the
water first, before the proposed project, and determining how that level of service
is managed during any period when excess water may be available could become
problematic for both MRWPCA and CSIP participants. As farming operations in
the CSIP area are paying assessments for water delivered, as well as a standby
charge per acre, it is paramount that excess waters not be diverted to the
proposed project when irrigation demand is increased due to lack of rainfall.
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FARM BUREAU
MONTEREY
S-6
Under the 1992 agreement signed by MCWRA and MRWPCA, the construction
and operation of the Salinas Valley Reclamation Plant will provide treated water
at a quantity adequate for irrigation in the CSIP area as currently configured.
Section 3.03 commits all incoming wastewater flows, up to 29.6 MOD, for supply
to CSIP except for the allotment carved out for Marina Coast Water District. It
should be paramount that this agreement be maintained to provide a reliable
water supply source for CR TP >'lrP.>'~ nses when thP. rl.emand is there .
Stormwater Capture
Until agreements and infrastructure are ir. place to fulfill the desired capture of
stormwater, from Salinas or other mur:icipalities, this water is not to be
considered a reliable source for the proposed project. A number of technical and
legal agreements need to be codified prior to this water being captured and
treated. Additionally, capture of this water will require significant investment in
facilities and pipelines that require cooperation between MRWPCA and several
municipalities; contemplation of these various capture projects through multiple
agreements may add significant costs to the process of reclaiming the
storm water.
S-7
Surface Water and Agricultural Tile Drain Water that flows into the Reclamation
Ditch. Tembladero Slough, and Blanco Drain
MCWRA has submitted an application for appropriative rights to waters found
in these three water ditches, which drain either into the Salinas River or the
Monterey Bay. Reclaiming the water in these ditches is important but cannot be
considered for future use in the proposed project if water quality objectives
imposed by the Central Coast Regional Water Quality Control Board (CCRWQCB)
reduce the amount of agricultural and municipal discharges into the ditches.
S-8
Increasing regulatory controls over discharges from agricultural operations,

including tile drain flows, may be intensified as the next CCRWQCB agricultural
discharge waiver is considered in the 2017-2018 timeframe. Already under
severe restrictions on the quality of water discharged from field operations,
irrigation practices are changing to ensure that end-of-field discharges will not
occur into impaired water bodies, such as the Salinas River.
Reliance on waters from these ditches may prove problematic as on-farm
solutions are realized through new technologies and practices. The framework
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FARM BUREAU
MONTEREY
of water reuse on crops is also under consideration as a modification to food
safety measures and some degree of water capture and reuse may ultimately be
allowed for crop production purposes. If this comes to fruition, tile drain flows
could be held on-farm as reclaimed water and not discharged to these ditches.
Additionally, diversions of water from these ditches may adversely impact the
remaining water quality for current beneficial uses. With tox icity a nd turbidity
issues on each ditch, reducing water flows to 1 cfs or 2 cfs will impact the ability
for dilution; these impacts will eventually determine the ability to achieve stated
Total Daily Maximum Load (TMDL) requirements as determined by CCRWQCB.
Recognition th at the proposed project could seriously alter th e water quality of
these ditches requires further environmental study and collaboration with
CCRWQCB on imposed TMDL standards.
S-8
Con't
Municipal discharges to these ditch es may similarly be reduced as regulatory

efforts to control and capture discharges, including stormwater, are further
pressed onto municipa]jties.
Potential reductions in source water contributions provide sufficient impacts to
term these ditch waters as interruptible. Diversions of water from these ditches
requires further environmental impact studies to determine how best to manage
any unintended consequences that may arise from changes in water quality.
Capacity of CSIP Project
The proposed project projects to supply approximately 4500-4750 acre feet of

water annually to CSIP for irrigation purposes in the existing 12,000 acres of the
northern Salinas Valley. While additional water would certainly be welcome
within the CSIP system, presumably to reduce supplemental well pumping, there
are limitations to the capacity of the CSIP project that should be considered.
S-9
First, the pond that is used by MRWPCA to blend reclaimed water from the
tertiary p lant and t he Salinas River Diversion Project (rubber dam) is limited to
a capacity of 80 acre feet at any time. Within that 80 acre feet pond is a certain
level of water required to provide gradient pressure within the CSIP pipeline
distribution network. Below a specified level in this pond the gradient is lessened
and water delivery to the coastal fields is diminished.
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FARM BUREAU
~ MONTEREY
Considering that the proposed project may generate an average of 12 acre feet
per day, the pond appears to then become a limiting factor in the operation of
CSIP in that the desired higher level of water capacity for gradient flow would
maximize the capacity of the pond. Combined with other potential sources of
water that may be contributing to the pond, including water from the rubber
dam, the need to expand the pond should be considered as an extension of the
S-9
Con't
proposed project.
Expansion of the CSIP project into Phase II has been contemplated since the
original EIR was approved, as well as in the Engineering Repor t for the project.
Additional flows into CSIP would indicate that an expansion of the irrigated lands
serviced by CSIP may need to be contemplated as part of the proposed project.
Combined with expansion of the pond and increased gradient management, CSIP
could be used to reduce supplemental groundwater extractions as well as expand
the area of service to further reduce well water reliance.
An additional benefit of the proposed project could be to positively impact salt
water intrusion by expanding CS!P to the level originally anticipated with Phase
II.
Reliance on Brown and Caldwell "State of the Salinas River Groundwater

Basin" Report
In 2014, the Monterey County Board of Supervisors commissioned a report to

assess the current state of the Salinas River Groundwater Basin (SRGB),
primarily due to the continuing drought. This report, presented in December
2014 to the Supervisors, collated a number of source information points on wells,
hydrology, and water extractions into a 'snapshot' of the groundwater basin.
S-10
After examining this report more closely, the data sets used to report conditions
in the SRGB do not include improvements made by the Salinas Valley Water
Project, Salinas River Diversion Facility, or Castroville Seawater Intrusion
Project. Many of the data sets used to prepare this report predate these projects,
including years prior to 1997 only; influences on groundwater conditions are
NOT taking into account the operation of these projects for the findings of this
report.
Brown and Caldwell notes this disclaimer on the title page of their report:
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Final EIR
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September 2015
FARM BUREAU
MONTEREY
This document was prepared solely for Monterey County Resource
Management Agency (County) in accordance with professional standards at
the time the services were performed and in accordance with the
Professional Services Agreement between the County and Brown and
Caldwell. This document is governed by the specific scope of work
authorized. We have relied on information or instructions provided by the
County, the only intended beneficiary of this work. Except a.s expressly
agreed to between Brown and Caldwell and County, no other party should
rely on the information presented herein.
S-10
Con't
Thus, reliance on this report for specific environmental impacts cannot be made,
per statement by Brown and Caldwell and the data sets presented that are n ot
relevant to the proposed project. Any and all reference to this report in the draft
EIR document should be removed.
Conclusion
Monterey County Farm Bureau supports the concept of groundwater

replenishment as a method of developing future water resources, particularly as
the on-going d rough t impacts existing wa:er resources and projects already in
operation.
S-11
Due to a lack of lon g-term reliability of the source water portfolio, limited capacity
of CSIP project, and the reliance of environmental impact information from the
Brown and Caldwell basin report, the proposed project has impacts that are n ot
yet considered or contemplated in the Draft Environmental Impact Report.
As a separate, stand-alone project, groundwater replenishment would have merit
if the impacts discussed in this comment letter could be mitigated or managed.
By coupling the proposed project to the Monterey Peninsula Water Supply Project
as a component of the larger water supply project for the Monterey Peninsula,
primarily to determine the size of the cesalination facility to be built, the
repercussions of a failure of the proposed project would lead to a water supply
shortage, once again, for the Monterey Peninsula. The impacts to the reduction
of water diversions on the Carmel River watershed must be assured by new water
resource development that has reliable water sources for the term of the project's
operation.
S-12
S-13
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Final EIR
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September 2015
FARM BUREAU
MONTEREY
Consideration should be given to decoupt:ng this project from the desalination
project and allow the proposed project to supply a supplemental water supply,
allowing for the potential variability in source water supply.
S-14
Thank you for the opportunity to provide comment on the Draft Environmental
Impact Report for Pure Water Monterey.
Sincerely,
. Groot
T: (831) 751-3100 F: (831) 751-3167 931 Blanco Circle, Salinas, CA 93901 P.O. Bo 1449, Salinas. CA 93902-1449
www.montereycfb.com

Final EIR
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LetterS: FarmBureau
S-1
The comment states an opinion of the Proposed Project; the comment is referred to the
S-2
The comment provides an overview of the types of comments contained in the Farm Bureaus
letter. See the responses to comments S-3 through S-10, below.
S-3
The Draft EIRs supply analysis for the Proposed Project considered the reliability and seasonal
availability of the proposed sources of water. To address potential reliability concerns, the
Proposed Project would develop a diverse portfolio of sources that will result in more sources of
water supply than would be needed to provide the minimum quantities required for the
Proposed Project yield. The Proposed Project is also configured to produce and store
additional water in normal and wet years, so that production may be reduced in dry years. See
also Master Response #3: Availability, Reliability, and Yield of Source Water Supplies in
Chapter 3, Master Responses to Comments to address the comment on impacts to Carmel
River replacement water.
S-4
The City of Salinas has operated the Salinas Industrial Wastewater Treatment Facility (Salinas
Treatment Facility) for over 50 years. The flows to the Salinas Treatment Facility have
continually increased over the last 20 years, and the plant is approaching its permitted capacity.
While it is possible that some industrial customers may elect to convert to on-site treatment and
water recycling in the future, it is not likely that a majority of the dischargers would elect to do
so due to the known high costs of such treatment systems relative to the current rates for
groundwater use and wastewater treatment. Also, the City of Salinas has approved a specific
plan for an Agricultural-Industrial Complex which will bring new industrial customers to the area
that likely would generate additional industrial wastewater. To be conservative, additional flows
from these projected future customers were not included in the supply analysis. See also
Master Response #3: Availability, Reliability, and Yield of Source Water Supplies in Chapter 3,
Master Responses to Comments and Appendix B-Revised.
S-5
The seasonal availability of treated municipal wastewater was considered in the analysis for the
Proposed Project. Use of treated municipal wastewater is ranked first in order of preference,
because it requires no additional conveyance pumping to obtain it from the Regional Treatment
Plant when it is available. The Proposed Project will use the other sources of supply
(agricultural wash water and surface water diversions) when treated municipal wastewater is
being used for CSIP (or in the future for MCWD to supply urban demands as anticipated by the
RUWAP Recycled Water Project approvals). The Proposed Project will generate additional
water for groundwater injection in wet and normal rainfall years, so that its operation may be
reduced in dry years. Even during the recent extremely dry period, the Salinas Valley
Reclamation Plant was shut down for ten weeks (late November 2014 through mid-January
2015), during which time secondary-treated effluent was discharged to the ocean outfall. See
also Master Response #3: Availability, Reliability, and Yield of Source Water Supplies in
S-6
The source water supply analysis considered full use of all available municipal wastewater to
produce tertiary treated recycled water for the CSIP and urban use. However, these demands
are seasonal and decline in the winter months, leaving some secondary-treated municipal
wastewater unused. The Salinas Valley Reclamation Plant (SVRP) currently has a lower
production limit of about 5 million gallons per day (mgd). Under existing conditions, when CSIP
demands are lower than 5 mgd, groundwater is supplied to growers instead of recycled water.
The Proposed Project includes modifications to the SVRP that would facilitate the production of
recycled water at lower demand rates. That increased use of treated municipal wastewater to
produce winter recycled water was included in the supply analysis. See Master Response #3:

Final EIR
4-235
September 2015
Availability, Reliability, and Yield of Source Water Supplies and Master Response #10: Marina
Coast Water District and City of Marina Water Supply Issues in Chapter 3, Master Responses
to Comments.
S-7
All of the proposed sources of source water supplies involving stormwater will require either
State Board permits (for surface water diversions) and/or formal agreements between cities and
agencies (for stormwater and wastewater), and the MRWPCA is working diligently to coordinate
with other stakeholders to obtain the necessary permits and agreements. The facilities required
to capture and convey stormwater from the City of Salinas and from Lake El Estero will not be
prohibitively expensive, because those diversions may be made where the existing stormwater
system is close to the existing wastewater collection system. Each of these diversions requires
an agreement (between MRWPCA and Salinas, and between MRWPCA and Monterey,
respectively). See Master Response #3: Availability, Reliability, and Yield of Source Water
Supplies in Chapter 3, Master Responses to Comments, Appendix BB, and Revised
Appendices B and C in this Final EIR.
S-8
The comment opines that the Central Coast RWQCB regulation of municipal and agricultural
discharges may reduce the volume of flows in the Blanco Drain and Reclamation Ditch system,
and further claims that diverting flows will reduce the volume of water available to dilute
remaining pollutants. This latter claim is not borne out by the analysis in the Draft EIR
(Appendix N, O, and P and in Section 4.11). Specifically, the pollutant load and flows in the
water bodies would be reduced downstream of the diversion points, but the concentrations
would not be reduced on an average annual basis. The flows during the periods of the year
when demands for recycled water are highest and therefore, when diversions would occur
correspond to the times of year when the pollutant load in the waterbodies is also the highest.
During and for one to several days after the storm events when water bodies carry the least
polluted waters, the Proposed Project would reduce or stop diverting surface waters because
demands for recycled water would drop to almost zero.
If irrigators treat their own drainage water and reuse that water on-site as suggested by the
comment, there would be a corresponding reduction in water demand, either from CSIP and/or
from the Salinas Valley Groundwater Basin, whichever is the current source of irrigation supply
for that land. Closed-loop recycling (100% reuse with only a make-up water demand) is
impractical, however, because tile drainage carries salts which would concentrate in the
recycled water produced by closed-loop recycling, making it unsuitable for irrigation use after
several cycles. Irrigation practices could change, but there are no known, feasible near-term
solutions involving closed-loop systems and existing data show that irrigation return flows are
consistent over the long term.
The Blanco Drain is maintained as a drainage ditch with clean (unvegetated) sides and bottom,
and has been identified as an impaired water body. The proposed diversion from the Blanco
Drain at a point above the confluence with the Salinas River would not change the water quality
in the Blanco Drain, but would reduce the pollutant loading into the Salinas River and the
Monterey Bay. This is considered to be a more cost-effective means of protecting the existing
aquatic habitat in the River than capturing and recycling irrigation water at numerous locations.
The Proposed Project has a maximum diversion rate of 6 cfs, while seasonal storm flows in the
Reclamation Ditch typically exceed 20 cfs, so seasonal flushing will still occur. See also Master
Response #3: Availability, Reliability, and Yield of Source Water Supplies and Master
Response #4: Reduction of Surface Water Flows in Chapter 3, Master Responses to
Comments.
S-9
The comment states that expansion of the 80 acre-foot pond at the SVRP is required in order to
deliver the additional 4,500 to 4,750 AFY to CSIP, and should therefore be included in the

Final EIR
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September 2015
project description and analysis. The CSIP Phase II expansion is considered a separate project
from the Proposed Project, as it is not necessary for the Proposed Project to achieve its
objectives, specifically to provide additional water for irrigation during periods of very low (i.e.,
under 5 mgd) or very high irrigation demand. Modifications to the SVRP to allow production of
recycled water during low demand periods are included in the Proposed Project to serve CSIP
during time periods with low overall demand for recycled water. No plant modifications, or
reservoir expansion, are proposed to utilize additional source water during periods of average
or high irrigation demand. The SVRP/CSIP system was designed for a peak delivery rate of
29.6 mgd. In August 2013, it delivered 31.7 mgd (the peak historic combined Salinas Valley
Reclamation Plant and Salinas River Diversion Facility, or SRDF, production). The amount of
municipal wastewater influent limits the amount of recycled water available for CSIP during high
demand periods, not the current pond size.
S-10
The Brown & Caldwell State of the Salinas River Groundwater Basin Report is not the only
source used for the Draft EIRs conclusions regarding the Proposed Projects potential
environmental impacts. The Brown & Caldwell Report was published while the technical studies
for the EIR were being prepared. While it is cited as a reference in several portions of the Draft
EIR, it was not relied upon as the sole source of information for any conclusions. Therefore, its
inclusion in the Draft EIR as a reference report is appropriate.
S-11
The comment states an opinion of the Proposed Project; the comment is referred to the
S-12
See the responses to comments S-2 through S-10, above, and Master Response #3:
Availability, Reliability, and Yield of Source Water Supplies and Master Response #12
Adequacy of Range and Scope of Alternatives in Chapter 3, Master Responses to
Comments.
S-13
The EIR analyzes the Proposed GWR Project, independent from the Monterey Peninsula Water
Supply Project. The Proposed Projects EIR includes an evaluation of the potential
environmental effects of constructing and operating the infrastructure needed to divert the
proposed new source waters to the Regional Treatment Plant, treat those source waters, use
tertiary treated irrigation water within the area served by the Castroville Seawater Intrusion
Project, convey purified water to Injection Well Facilities, inject purified water into the Seaside
Basin, and convey extracted water to CalAm customers. The Proposed Project is separate and
independent from the Monterey Peninsula Water Supply Project, and can go forward without
the Monterey Peninsula Water Supply Project. The EIRs cumulative impacts sections
recognize the potential that the Monterey Peninsula Water Supply Project also might be
approved and implemented, and the EIR discloses the combined effects of the two projects
along with other past, present and reasonably probable future projects. Additional discussion
on this issue is available in the Draft EIR, Section 2.3.2.6 on pages 2-11 and 2-12 and Master
Response #12: Adequacy of Range and Scope of Alternatives and Master Response #11:
Proposed Projects Relationship to the Proposed Monterey Peninsula Water Supply Project in
S-14
See Response to comment S-13 and Master Response #12: Adequacy of Range and Scope of
Alternatives in Chapter 3, Master Responses to Comments and Master Response #11:
Proposed Projects Relationship to the Proposed Monterey Peninsula Water Supply Project.

Final EIR
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September 2015
Letter T
Corrected
Transmitted via Email to: gwr@mrwpca.com
Robert Holden, P.E., Principal Engineer

Monterey, Ca 93940
1 June, 2015
Re: DEIR Pure Water Monterey Groundwater Replenishment Project

Dear Mr. Holden;
The Salinas Valley Water Coalition (SVWC) is a not-for-profit organization
comprised of agricultural landowners, farmers and businesses within the Salinas Valley.
The SVWCs primary purpose is to participate in the various governmental processes in
order to preserve the water rights of its members, to protect their water resources and to
effect water policy decisions in a manner that provides this protection while sustaining
agricultural production and quality of life.
The SVWC has worked with, and supported, the Monterey County Water Resources
Agency and other agencies in their pursuit of long-term water supplies for urban and
agricultural needs. This support has been premised on the belief that they are committed
to developing a program that is cost-effective, reasonable, hydologically sound and
equitable to landowners and rate payers and protects existing water rights and needs,
particularly in the areas of the Salinas Valley.
Community participation is an essential element in any project, and critical to
obtaining support for that project. Toward this end, we appreciate the efforts made by the
various agencies to reach out to the Salinas Valley agricultural community, and a
willingness to discuss how these needs can continue to be best met.
The SVWC supports the consideration of this Project, but that support is predicated
on the resolution of several outstanding issues, including water rights and the successful
amendments to existing agreements along with new agreements. With this understanding,
we offer the following comments on the DEIR:
1
Final EIR
4-238
September 2015
T-1
General:
The DEIR states that the primary object of the proposed project is to replenish the
Seaside Groundwater Basin with 3,500 AFY of purified recycled water to replace a
portion of CalAms water supply as required by state orders. It goes on to say that
the proposed project would need to be capable of commencing operation, or of
being substantially complete, by the end of 2016 or, if after 2016, no later than
necessary to meet CalAms replacement water needs.
T-2
This seems to be very limiting and restrictive, and appears to rely solely on the
success of Cal-Am and their ability to utilize this project and its water resources. We
think this is short-sighted and that the proposed project should be considered within the
context of a stand-alone project; how could it work without Cal-Am, what would the
impacts be of such a project?
Source Water Rights, Appendix C:
The DEIR, appendix C, discusses the legal framework and various agreements in
place and those needed to be in place, to make this project work. It discusses the
Memorandum of Understanding (MOU) the stakeholder agencies entered into,
which also reaffirmed the Marina Coast Water District and Monterey County
Water Resources Agency with MRWPCA recycled water entitlements. The DEIR
further states that the MOU:
is intended to provide a framework for negotiation of a Definitive
Agreement and does not create a binding contractual obligation.
T-3
It is the Definitive Agreement (DA) that will establish the contractual rights and
obligations of the parties, and the DEIR recognizes that the DA has not yet been
completed, and further,
If a Definitive Agreement is reached, it would be approved after the EIR is
certified.
What would the impact(s) be to the Carmel River and its water resource system if this
project EIR is certified and there is a failure to successfully execute a Definitive
Agreement, hence causing a further delay in the reduction of pumping from the Carmel
River resource system?
Appendix C states that the City of Salinas has the exclusive right to the treated
wastewater it collects in its system and treats at the Salinas Treatment Facility. It
further states that since the City of Salinas has the exclusive right to its treated
2
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4-239
September 2015
T-4
wastewater, a contract would be needed between MRWPCA and the City of Salinas
for the diversion and use of agricultural waste water.
While the City of Salinas may have the exclusive right to the treated wastewater it
collects in its system, we believe, as stated in Appendix C of your DEIR:
The 1992 agreement between MRWPCA and Water Resources Agency
(including amendments)In particular, Section 3.03 of the 1992 Agreement
(Amendment 3) provides that the MRWPCA commits all of its incoming
wastewater flows to the treatment plant from sources within its 2001 MRWPCA
service area, up to 29,6 million gallons per day, . (emphasis added)
We believe that Amendment No. 3 modified Sec. 3.03 of the Original Agreement, in that
in Amendment No. 3 Sec. 3.03 which states the PCA will commit all of its incoming
wastewater flows to the regional treatment plant to the project1. (emphasis added) It
remains clear that within Amendment No. 3 the project is as defined in the 1992
Agreement; the construction of a 29.6 MGD tertiary treatment system (hereinafter
referred to as the project. (emphasis added)
T-4
Con't
While we have supported, and continue to support, the City of Salinas and PCAs
consideration of the further utilization of the Citys treated wastewater, it is essential that
the agricultural community and Water Resources Agency be part of the agreement. We
believe that Amendment No. 3 clarifies that it was the intent of the parties to commit all of
the wastewater (current and future) flows coming to the regional treatment plant to the
Castroville Seawater Intrusion Project (CSIP). Without further modification/amendment
to the existing Agreements, we believe the MRWPCA cannot simply take wastewater flow
coming into its existing system and by-pass the tertiary treatment plant and use these
flows for projects other than CSIP; this would equate to a taking of water not entitled to,
contrary to existing contracts.
The DEIR should evaluate the impacts to the existing CSIP if they are not provided
the recycled water pursuant to, and as committed to, in the existing 1992 Agreement and
its amendments. What is the potential for continued seawater intrusion because of the
continued reliance on supplemental well water rather than delivered recycled water as
agreed to?
The Pure Monterey Project relies on source water that should not be considered a
secure, stable and uninterruptible supply, and the environmental impacts of this instability
and interruptible source should be considered.
Id at Exhibit 3 p 1
3
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T-5
T-6
Unless and until these issues are resolved, the Pure Monterey GWR Project has the
potential to significantly impact the growers, ratepayers of the Salinas Valley, and the
projects they built to stop seawater intrusion, and thus potentially exacerbate seawater
intrusion.
T-6
Con't
Salinas River Inflow Impacts, Appendix O:

Appendix O provides an analysis of the potential impacts to the Salinas River flows
because of implementation of the Project, including an engineering analysis of the flow
reductions in the Salinas River due to diverting City of Salinas stormwater runoff,
agricultural wash water and Blanco Drain flows to the proposed project, and assess the
potential project impacts on the hydrology and water quality in the Salinas River.
T-7
What appears to be missing from the analysis is what is the impact to the availability
of Salinas river water to be diverted at the Salinas Rubber Dam Facility. The summary of
Appendix O states that:
diverting agricultural wash water and City of Salinas stormwater to the Proposed
Project would reduce average annual flows in the river by less than 1%. If water is
also diverted from the Blanco Drain, the average annual flow in the Salinas River
decreases by 1.7%.
Table 2-6 of Appendix O, details the average and median flow of the Salinas
River near Spreckels over different time periods. Based on Table 2-6, 1% (rounding up
because it is not clear what less than 1% is) of the average flow during the period of
2010-2013 when the SRDF was operating, would equate to 1,622 afy. This in turn equates
to 30% of the maximum amount diverted at the SRDF during this period. While 1% of the
overall Salinas River flow may seem to have a minimal impact to overall flows, it could be
a significant impact to the amount of Salinas river water that could be diverted at SRDF
and to the agricultural lands that rely on that water. This impact needs to be further
analyzed in the EIR.
T-8
Appendix O also states:

Due to the significant losses and travel time between the reservoirs and the
SRDF, flows reductions affecting the by-pass releases would likely be
addressed by temporarily reducing SRDF pumping before adjusting the
reservoir release schedule. A portion of the diversions made for the proposed
project will be used to augment the CSIP supply, off-setting the effect of any
temporary SRDF reduction.
4
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T-9
While the temporary SRDF reduction may be off-set with an augmentation of supply to
the CSIP area, this would significantly change the management and operation of the
Salinas Valley Water Project, the amount of river water contemplated to be delivered to
the CSIP agricultural users and would change the benefits of the SVWP because of this
reduction in water to be supplied by it. In otherwords, does the Pure Monterey GWR
Project simply exchange its project water for river water? To what extent would there be
an impact to the existing SVWP and its SRDF component and to the CSIP landowners?
What is the impact to seawater intrusion because of the reduction in river water that can be
delivered and utilized by the CSIP agricultural lands? We believe these could be
significant environmental impacts.
T-9
Con't
Brown and Caldwell, 2014 State of the Salinas River Groundwater Basin Report,
2014:
The Brown and Caldwell State of the Basin Report was prepared at the request of
one Monterey County Supervisor and was meant to provide a snapshot of the status of
the basin at a certain point in time; nothing further. Further, we learned at a workshop
held by Monterey County Water Resources Agency that the analysis in the report did not T-10
include existing projects in its analysis, such as the SVWP or the CSIP; so in reality, it
wasnt even a true snapshot of the basin except as what existing pre-CSIP and pre-SVWP.
The report has extremely limited value and should not be used to project future basin
conditions, and yet it is cited and utilized to some degree in your DEIR and its various
evaluations. Where it was used, should be re-examined and excluded from your report. It
should not be utilized to establish certain baseline conditions for the basin
Conclusion
The Salinas Valley Water Coalition supports full environmental review of the
proposed Project and the proposed alternatives. This DEIR does not fully analyze the
proposed project as a true stand-alone, and we believe it should as the reliance on
agreements that may not occur is a significant impact to the Carmel River water resources
system and its fishery resources and habitat. This DEIR does not fully analyze the
potential impacts to the SVWP, CSIP and seawater intrusion as discussed above, and the
impacts to these agricultural lands.
SVWC has actively supported the development of water projects within the Salinas
Valley, and continues to do so. Its members have built and paid, or continue to pay, for
two reservoirs, the Castroville Seawater Intrusion Project, The Salinas Valley
Reclamation Project and the Salinas Valley Water Projectall in an effort to solve its
basins water problems. They have worked with their neighbors to resolve their difference
so these projects could be successfully financed and implemented. The stability and
5
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T-11
T-12
security of their water resources and water rights are potentially at stake in the
implementation of this project, and these impacts must be fully evaluated and considered.
There may be adequate wastewater available to consider the development of a
Groundwater Replenishment Project, but the PCA does not currently hold the rights to do
so and the reliance on potential agreements is a great risk that the environment and
landowners cannot afford.
Lets work together to provide the best Plan possible for our community. Thank you for
your consideration of our comments and concerns.
Sincerely,
Nancy Isakson, President

Salinas Valley Water Coalition
6
Final EIR
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T-12
Con't
LetterT: SalinasValleyWaterCoalition
T-1
The opinion of the Proposed Project stated in the comment is referred to decision makers for
their consideration.
T-2
As stated on pages 2-17 through 2-18 of the Draft EIR (and as was presented in the 2013
Notice of Preparation and its 2014 supplement in Appendix A), the Proposed Projects primary
objective is to replenish the Seaside Groundwater Basin with water to replace a portion of
CalAms water supply as required by state orders. Another objective of the Proposed Project is
to provide additional water to the Regional Treatment Plant that could be used for crop
irrigation through the Salinas Valley Reclamation Plant (SVRP) and CSIP system. Project
objectives are sufficient if they help guide the development of alternatives. The comment does
not suggest that the project objectives are insufficient to help guide the formation of
alternatives. Here, the project objectives can be met regardless of whether the Cal Am
Monterey Peninsula Water Supply Project is implemented. The Proposed Project is a standalone project. See Master Response #11: Proposed Projects Relationship to the Monterey
Peninsula Water Supply Project in Chapter 3, Master Responses to Comments for additional
information.
T-3
Issues in Chapter 3, Master Responses to Comments. The comment also asks what the
impacts would be to the Carmel River and its water resource system if this EIR is certified and
there is a failure to execute a Definitive Agreement. The comment presumes that without a
Definitive Agreement, there would be a further delay in the reduction of pumping from the
Carmel River. The Draft EIR addresses the potential for this Proposed Project to not move
forward (either due to failure of the agencies to reach agreement on source waters, or other
constraints to implementation). Specifically, Chapter 6 contains a description and environmental
analysis of the No Project alternative on pages 6-22 through 6-24. Also, see response to letter
R-7.
T-4
See Section 4.18 (as amended in Chapter 5, Changes to the Draft EIR), Master Response
#3: Availability, Reliability, and Yield of Source Water Supplies and Master Response #10:
Marina Coast Water District and City of Marina Water Supply Issues in Chapter 3, Master
Responses to Comments. See also Appendices B-Revised and C-Revised of this Final EIR.
The 2014 Source Water MOU describes the parties existing rights, and expresses their
intention to work cooperatively to provide water for the Proposed Project.
T-5
The comment states that the Draft EIR should evaluate impacts to the CSIP if CSIP is not
provided with recycled water pursuant to the original 1992 Agreement (for Construction and
Operation of a Tertiary Treatment System). The Proposed Project would have junior rights to
CSIP with respect to the use of secondary treated effluent at the Regional Treatment Plant,
which is why the EIR only considers using the flows which are currently discharged to the
ocean. The Proposed Project would increase, not reduce, water available for recycling and use
by CSIP. Specifically, the Proposed Project would increase the delivery of recycled water to
CSIP by modifying the SVRP to meet recycled water demands during periods of time when
there is low demand (< 5 mgd) for irrigation water, and by developing new sources of water
supply to meet peak demands. In the future, if and when MCWD implements its RUWAP
Recycled Water Project, flows of recycled water available to CSIP during some months may be
reduced; however, this reduction would be less if the Proposed Project is implemented than if it
is not. See Appendix BB (Technical Memorandum: Future RUWAP Urban Recycled Water
Irrigation Water Use and Implications for CSIP Yields) and Master Response #3: Availability,
Reliability, and Yield of Source Water Supplies, and Master Response #10: Marina Coast
Water District and City of Marina Water Supply Issues in Chapter 3, Master Responses to
Comments.

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T-6
See Master Response #3: Availability, Reliability, and Yield of Source Water Supplies in
T-7
The Salinas River Diversion Facility (SRDF), sometimes referred to as the Rubber Dam, is
operated under Water Right Permits No. 10137 and No. 12261. These permits are for rediversion of flows captured in Nacimiento and San Antonio Reservoirs. The water right permits
do not permit the County to divert flows originating from down-stream sources, such as the
Blanco Drain and the Salinas Industrial Wastewater Treatment Facility at the SRDF. The
MCWRA releases flows at the San Antonio and Nacimiento Reservoirs, a portion of which
infiltrates into the Salinas Valley groundwater basin. Remaining flows at the SRDF may be
diverted, subject to in-stream flow requirements that define how much water must be allowed to
pass the SRDF.
The flows from the Blanco Drain and Salinas Treatment Facility make up a portion of the base
flow of the river at the Rubber Dam. The Proposed Projects water availability analysis therefore
examined the potential impact of the proposed diversions on the in-stream flows passing the
Rubber Dam, and not the yield of the SRDF. The method and assumptions used in the water
availability analysis in the EIR and the associated impact analysis are adequate for addressing
the potential environmental impacts of the Proposed Project in accordance with CEQA
6
Guidelines. Specifically, changes to Salinas River flows due to the Proposed Project would not
result in significant impacts in the terms of the significance criteria for the hydrology and water
quality. See Draft EIR, Section 4.11 at pages 4.11-64 through 4.11-79 (examining potential
impacts to surface waters), Section 4.4 at pages 4.4-44 through 4.4-49 (examining the potential
impacts to fisheries); Section 4.5 at pages 4.5-97 through 4.5-105 (examining potential impacts
to terrestrial and non-fisheries biological resources); Master Response #3: Availability,
Reliability, and Yield of Source Water Supplies in Chapter 3, Master Responses to
Comments.
T-8
The analysis of in-stream flow (i.e., hydrology and water quality) impacts shown in Table 3-3 of
Appendix O, Salinas River Inflow Impacts Report, uses an analysis of the flow reductions that
would be expected to occur in the river at a point downstream of the SRDF. The flow reductions
cited in comment T-7 occur at this point. This location was selected for the analysis for several
reasons, one of which was that the increased flows at the USGS Spreckels Gage due to
upstream releases from the Nacimiento and San Antonio Reservoirs for the SRDF, and the
corresponding rediversions at the SRDF, balance each other out. The SRDF releases will
continue to be available for diversion with implementation of the Proposed Project. The analysis
in Appendix O is based on a worst case scenario of fully diverting flows from the Salinas
Treatment Facility system (that is, leaving the ponds empty year-round), as noted at Appendix
O of the Draft EIR, page 25. The actual operational scenario for the Proposed Project is
discussed in Appendix B, Source Water Assumptions Memorandum, as revised in this Final
EIR (see Appendix B-Revised). The Proposed Project would use the Salinas Treatment
Facility ponds for seasonal storage of source water, and then recover the water to the Regional
Treatment Plant during the summer months when water demands peak. Keeping the ponds
wetted or partially wetted for nine months out of the year reduces the impact to the base flow of
An EIR should be prepared with a sufficient degree of analysis to provide decision makers with information which
enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of
the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be
reviewed in the light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate,
but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for
perfection but for adequacy, completeness, and a good faith effort at full disclosure. (14 CCR 15151 Standards for
Adequacy of an EIR)

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September 2015
the river by 1,629 acre-feet per year (= [3 cfs] x [724 afy/cfs] x [9mo/12mo]). See also Master
Response #3: Availability, Reliability, and Yield of Source Water Supplies in Chapter 3, Master
T-9
The comment asks how the system will operate with multiple diversions potentially affecting the
flow in the Salinas River at the SRDF. Under the Proposed Project operational conditions, four
potential reductions in river flow at the point of analysis (i.e., downstream of the SRDF site) may
occur concurrently: (1) SRDF diversions of flows released from the upstream reservoirs, (2)
diversion of flows from Blanco Drain to the Regional Treatment Plant, (3) diversion of
agricultural wash water directly to the Regional Treatment Plant or indirectly from the ponds to
the Regional Treatment Plant, and (4) diversion of stormwater runoff from the Salinas outfall to
the Regional Treatment Plant or indirectly to the Salinas Treatment Facility ponds. The portion
of the year when these diversions would potentially overlap would be late summer, when the
Salinas Treatment Facility ponds would be dry and would not be contributing flow to the Salinas
River. Rain events do not typically occur in late summer; therefore, the only additional
diversions that may be occurring would be the SRDF and the Blanco Drain diversions.
The SRDF is managed to provide flows to the CSIP system and allow the required in-stream
bypass. Water diverted from the river at the SRDF is pumped to the recycled water storage
ponds at the Salinas Valley Reclamation Plant, which supplies the CSIP system. Water diverted
at the Blanco Drain would be pumped to the Regional Treatment Plant, undergo primary and
secondary treatment with the existing municipal wastewater flows and all of the other GWR
inflows, and then be used as influent for the GWR Advanced Water Treatment Facility (AWTF)
and the SVRP. The MCWRA has submitted a water right permit application to the State Board
for the Blanco Drain diversion, so the same agency that operates the SRDF would control the
Blanco Drain diversion. If the combination of diversions affect the ability to make full SRDF
diversions and maintain the required in-stream flows, the MCWRA may reduce the diversion
rate at the Blanco Drain to ensure the by-pass flows are maintained, or the MCWRA may
reduce the SRDF diversion but direct that a portion of the water diverted from the Blanco Drain
be sent from the Regional Treatment Plant to the SVRP instead of to the AWTF. The net effect
at the Salinas Valley Reclamation Plant product water reservoir would be the same, and
deliveries to CSIP would be maintained. The MCWRA would adjust the reservoir releases as
needed to compensate for changing conditions, just as they do under the current condition. The
Proposed Project would increase, not reduce, water available for recycling and use by CSIP. In
the future, if and when MCWD implements its RUWAP Recycled Water Project, flows of
recycled water available to CSIP during some months may be reduced; however, this reduction
would be less if the Proposed Project is implemented than if it is not. See also Appendix BRevised. See also Master Response #3: Availability, Reliability, and Yield of Source Water
Supplies, and Master Response #4: Reduction of Surface Water Flows in Chapter 3, Master
T-10
See the response to comment S-10.
T-11
See the response to comment S-13.
T-12
The opinion of the Proposed Project stated in the comment is referred to the decision makers
for their consideration. Regarding the second paragraph, see responses to comments T-2
through T-11 above and Master Response #3: Availability, Reliability, and Yield of Source
Water Supplies in Chapter 3, Master Responses to Comments.

Final EIR
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September 2015
Letter U
From: Ron Weitzman [mailto:ronweitzman@redshift.com]

Sent: Tuesday, June 02, 2015 9:47 PM
To: GWR
Cc: waterplus@redshift.com; pwnaction@lists.riseup.net; Californian; Carmel Pine Cone; Cedar Street Times; Channel 11; Herald
City Editor; Jim Johnson; KION TV ; KSMS TV; MC Weekly Editor; Sara Rubin; Shanna McCord
Subject: Comments on the GWR DEIR

Dear Mr. Holden:
These comments apply to specific sections of the DEIR.
Section 4.9. Hazards and Hazardous Materials
My comments on the NOP referred to DDT and other such hazardous material in water sources proposed
for this project, including the Blanco Drain. The attached letter from Stephen Collins indicates that these
contaminants exist in such large amounts in some of the proposed water sources that they may be
untreatable for agricultural let alone potable use. Yet the DEIR has failed to
identify theseparticular contaminants and indicate how to deal with them. This excerpt from the letter by
Mr. Collins captures the magnitude of the problem::
U-1
Legacy Pesticides, as its name would suggest, are compounds, normally inorganic in nature, and the
result of chemical use from years ago that are still held in high concentrations in the soil. Examples
include: DDT, DDE, Arsenic, Boron, a number of heavy metals, etc. Here is a direct quote from the
Central Coast Region report: The Salinas River Lagoon Management and Enhancement Plan cites a
number of studies from the 1980s suggesting that soils in the northern Salinas Valley contain a reservoir
of DDT that will continue to release DDT into aquatic environments well into the 21stcentury. The
primary source of this pollution into the Reclamation Ditch, is the Blanco Drain. The DDT study was
performed using a normal study practice utilizing a living organism and measuring its body intake of the
pesticide in question, in this case Corbicula (clams) planted in the Blanco Drain. The result was the
highest concentration of Total DDT (and other chemicals) ever seen in California.
The FEIR must deal with this problem.
Section 6. Alternatives to the Proposed Project
This section dismisses the DeepWater and Peoples projects as not likely to be completed prior to the
CDO deadline. Cal Ams project, as well as the proposed GWR project, is certain not to be completed by
that date. Within the next few weeks, both DeepWater and Peoples will issue NOPs. Each has fewer
physical hurdles to overcome than Cal Ams or the proposed GWR project does, and Peoples has fewer
permitting obstacles before it since its intake and outfall pipes have been grandfathered. The FEIR must
includeconsideration of each of these projects as a whole.
Missing from the alternatives considered is a GWR project that would provide all the product water
projected by the combined Cal Am and GWR projects. Since the Cal Am component is based on an

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U-2
U-3
intake experiment that may fail, this alternative is at least as reasonable to consider as Cal Ams
alternative without GWR. The FEIR must consider this alternative.
Another alternative that the FEIR may well consider is the use of slant or slope wells in the Carmel
Bay. Though vertical wells may not work there, the chance that slant wells will work there would appear
to be at as least as great as in Marina. This is an important alternative to consider because its development
would preclude the need for the north-to-south pipes in the alternatives of Cal Ams desal alone or
combined with GWR. It would also eliminate the problem of source-water rights bedeviling both the Cal
Am desaland GWR projects.
U-3
Con't
U-4
Appendix C
The Summary Chart in Part E of this appendix shows that the proposed GWR project has no water rights
for any of the four sources of water needed for the project. The FEIR will have no practical
meaning unless a sufficient number of these rights have been obtained for the project to work prior to the
FEIRs issuance. This problem affects the very viability of the project as well as its timeliness in
comparison with alternative projects. In fact, because of this problem, the issuance of the DEIR appears
to be premature.
U-5
Two Other Critical Concerns
In its initial form, the GWR proposal was to use source water only from urban sewer water treated
for agricultural use but unused during the three or four winter months. If that proves to be the
only viable source of water, then the advanced-treatment facility needed to make the water
potable would have to have three-to-four times the production capacity of one that could
operate all year because it would have to produce the required 3,500 acre-feet per year in only
one-third or one-fourth of that time, when the source water is available. The treatment facility,
involving the same reverse osmosis as desalination, would have to have the capacity to produce
up to 14,000 acre-feet per year. A facility with that capacity could produce more than enough
water to meet the entire needs of the Monterey Peninsula if the remaining possible water sources
should prove viable. This is another reason the FEIR should consider as analternative a GWR
project that could meet all of the Monterey Peninsulas water needs without desalination.
The GWR project in Orange County uses settlement ponds as part of its recycling process. The
proposed GWR project does not; it uses direct injection into an aquifer from which water will
later be drawn for distribution to customers. State law requires that directly-injected water needs
an equal amount of potable water (called diluent) to accompany it. The DEIR does not indicate
where that supplemental potable water will come from. The FEIR must do that.
Respectfully,
Ron Weitzman
President, water Ratepayers Association of the Monterey Peninsula

Final EIR
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September 2015
U-6
U-7
STEPHEN P. COLLINS, M.S., C.P.A. (Inactive)

February 19, 2013
To:
Press, Friends and Public
From: Steve Collins

Re: Utilization of Reclamation Ditch, Blanco Drain and retention pond waters for recycle
With complete incredulity, I watched Supervisor Calcagno announce from the dais last week, that the
Monterey County Pollution Control District Board had overwhelming approved an olive branch
extended by the Ag Industry from the Salinas Valley, to allow waters from the Blanco Drain, the Salinas
Valley Reclamation Ditch and settling ponds off Davis Road to be used for recycling and ASR in the
Seaside aquifer. As bad an idea, of using recycled sewage for Seaside Basin recovery was, which the Ag
Industry squelched, this is even worse. Recycled sewage is pristine compared to what is being proposed
to the public, as a component of the Cal Am project. I will stay completely away from politics or musings
in this letter, and stick strictly with published documents, but I feel compelled to say something.
U-8
Included as attachments are:

1. Page 17 of the NOAA Fisheries Biological Opinion, dated June 21, 2007, reference Page 1;
2. A Study of DDT in the Salinas Valley, authors noted, Pages 2-6;
3. Page 139 from the Water Quality Control Board, Water Quality Assessment Study, Central Coast
Region, Fecal Coliform Log, page 7;
4. Page 141 of the same study as Number 3, showing the Legacy Pesticides, contained in
impaired waterways (Reclamation Ditch), Page 8;
5. Page 143 of the same study as Number 3, showing the Section 303d listings for various water
bodies within and adjacent to the Reclamation Ditch, and organic and inorganic compounds
contained therein;
6. Page 10 of the 2012 of the Central Coast Regional Water Quality Control Board TMDL report;
Page 10.
U-9
I went to two on-line sources, the Monterey County Water Resource Agency Water Quality
Assessment reports and the Central Coast Watershed Studies, authored as noted above.
The NOAA Fisheries Biological Opinion relates to the Salinas Valley Water Project diversion facility
and its impacts to the Salinas River, fish mitigations and the quality and use of Salinas River water for
irrigation. Here is a direct quote from the Opinion, The SRDF diversion site is located in the vicinity of
the Blanco Drain, which discharges to the Salinas River upstream of the SRDF site. Because water from
the Blanco Drain is considered unsuitable for irrigation, MCWRA proposes to divert the drains discharge
to a point downstream of the SRDF site whenever the SRDG facility is impounding water for irrigation

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U-10
use. This is the very water, which is deemed unsuitable to irrigate a crop for human consumption,
which is going to be purchased from the Salinas Valley, treated by MRWPCA and injected into the
Seaside Aquifer for potable Title 22 drinking water on the Peninsula.
Legacy Pesticides, as its name would suggest, are compounds, normally inorganic in nature, and the
result of chemical use from years ago that are still held in high concentrations in the soil. Examples
include: DDT, DDE, Arsenic, Boron, a number of heavy metals, etc. Here is a direct quote from the
Central Coast Region report: The Salinas River Lagoon Management and Enhancement Plan cites a
number of studies from the 1980s suggesting that soils in the northern Salinas Valley contain a reservoir
of DDT that will continue to release DDT into aquatic environments well into the 21st century. The
primary source of this pollution into the Reclamation Ditch, is the Blanco Drain. The DDT study was
performed using a normal study practice utilizing a living organism and measuring its body intake of the
pesticide in question, in this case Corbicula (clams) planted in the Blanco Drain. The result was the
highest concentration of Total DDT (and other chemicals) ever seen in California.
The area study map (titled Section 303d listings of various water bodies within and adjacent to the
Reclamation Ditch Watershed) that shows many of the additives flowing from the Salinas Valley,
through creeks, into the watershed include compounds such as Fecal Coliform, Nitrates, Priority
Organics, Pesticides, Heavy Metals, etc. See Page 7, noted above, the Salinas Reclamation Canal (aka
Ditch) has the highest concentration of Fecal Coliform in the entire study area.
U-10
Con't
U-11
U-12
Page 7 of the data is a graph (Figure 6.5) that shows the Mean fecal coliform at all CCAMP measured
waterbodies throughout the Central Coast Region; number one is the Salinas Reclamation Canal (ditch).
The final document for your review is the 2012 CCRWQCB report on TMDL for the Lower Salinas River
Watershed that states the following:
Discharges of nitrogen compounds and orthophosphate are occurring at levels in surface waters
which are impairing a wide spectrum of beneficial uses and, therefore, constitute a serious water quality
problem. The municipal and domestic drinking supply (MUN, GWR) beneficial uses and the range of
aquatic habitat beneficial uses are currently impaired; potential or future beneficial uses of the
agricultural irrigation water supply (AGR) for sensitive crops may be impaired. Et, al.
U-13
The report finds the Region in violation of three water quality area:
1. Violations of drinking water standards for nitrate;
2. Violations of the Basin Plan general toxicity objective for inland surface waters and estuaries
(violation of un-ionized ammonia objective);
3. Violations of the Basin Plan narrative general objective for biostimulatory substances in inland
surface waters and estuaries (as expressed by excessive nutrients, chlorophyll a, algal biomass
and low dissolved oxygen).
I cannot imagine this concept ever being approved by the State of California, but understand what is
going on here; the farming community is required by State law to clean up these water sources, at huge

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U-14
expense to themselves. You see the fight with the State Regional Water Quality Control Board routinely
reported in the paper. This is the very same water the Salinas Valley is offering the Peninsula for
recycling and ASR. The following questions should be considered, in my opinion, before this concept,
and $750,000 is spent doing this study for the third time:
1. Two prior EIRs have been performed in the past, one for the Salinas Valley Reclamation Project
and one for the Salinas Valley Water Project. Both times, the water quality of the Blanco Drain,
which drains into the Salinas River and has connectivity to the Reclamation Ditch have been
deemed unsuitable for irrigating a crop, in both instances.
a) Does the technology to clean this water to Title 22 Drinking Water Standard exist?
b) If so, what is the cost for doing so, and how does it compare to desalination costs?
c) Is it possible to completely eradicate all inorganic compounds from the source water or are
we simply trying to meet minimum standards?
2. These waters are deemed surface waters by the State of California, and, I believe a diversion
permit will be required by the State. Has the legal and biological implications of this been
considered?
3. The final destination for this water is recharge into the Seaside Basin aquifer for subsequent
withdrawal and distribution to the Peninsula residents. Has the Seaside Basin Water Master
weighed in on this process?
U-14
Con't
U-15
U-16
U-17
I believe the answer to many, if not all, of the above questions is no.
I know many of the Mayors, members of the Board of the MRWPCA, and others working to provide a
solution to the Peninsula water crisis are diligent, community minded individuals with a simple goal,
solve the issue before 2016. Spending $750,000 of public money on a recycling plan that has been
previously reviewed in EIRs before, and found wanting is not a good expenditure of time or resource.
My guess; they have not been provided the data included herein, and believe this water source has
value from a drinking water supply standpoint. The Monterey County Health Department must be
apoplectic.
Stephen Collins
See attachments

Final EIR
4-251
September 2015
U-18
Attachments to Letter U
from Nacimiento Reservoir beginning the eighth day after the first adult steelhead passage day
occurs on the Salinas River near Spreckels after January 1st. These flows will be continued
through May 31st. Until further studies are conducted to determine adequate rearing flows in the
Nacimiento River below the reservoir during summer and fall, MCWRA will release a minimum
of 60 cfs throughout the year as minimum rearing flow as long as the water surface elevation of
Nacimiento Reservoir is above the elevation 687.8 teet mean sea level (msl), the reservoir's
minimum pool.
d. Water Quality Improvements and Other Changes to the Blanco Drain

The SRDF diversion site is located in the vicinity of the Blanco Drain, which discharges to the
Salinas River upstream of the SRDF site. Because water from Blanco Drain is considered
unsuitable for irrigation, MCWRA proposes to divert the drain's discharge to a point
downstream of the SRDF site whenever the SRDF facility is impounding water for irrigation use.
The Blanco Drain drainage area consists of approximately 6,400 acres of farmland, scattered
rural housing, and county roads. Summertime drainage is primarily agricultural drain water.
Wintertime drainage is primarily storm runoff. MCWRA operates a pump during the summer to
discharge the drain water to the Salinas River.
The Central Coast Regional Water Quality Control Board (CCRWQCB) has listed Blanco Drain
as an impaired water body pursuant to Section 303(d) of the CWA for pesticides, with medium
priority. To reduce contaminant loads of diazinon and chlorpyrifos from reaching the Salinas
River, MCWRA proposes to create a vegetated treatment system within Blanco Drain. A
vegetated treatment system generally consists of vegetation throughout a reach of channel
bottom designed to reduce water velocity and retain poiJutants by various processes, such as
microbial degradation, plant uptake, sorption, chemical reactions, and sediment retention. The
specific design for the Blanco Drain vegetative treatment has not been completed, and the
specific location for the vegetated channel sections has not been identified. MCWRA will
monitor the vegetated treatment system to determine the efficacy of contaminant reduction.
In the event that the vegetated treatment system is inadequate to sufficiently reduce diazinon and
chlorpyrifos loads within the Blanco Drain, then MCWRA will pursue other options (see page 26
ofMCWRA (2005a)). Options include, though are not limited to, diverting the water to the
regional wastewater treatment plant for recycling, and diverting Blanco Drain water to Ali sal
Slough. A specific definition of"inadequate to sufficiently reduce diazinon and chlorpyrifos
loads" has not been provided to NMFS.
e. SRDF Maintenance
Maintenance of the SRDF will primarily consist of, but will not necessarily be limited to,
periodic removal of deposited sediment, periodic removal of debris, annual scour restoration,
annual pressure washing of fish screens, periodic maintenance and lubrication of equipment, and
3
The frrst day of passage is the beginning date of the frrst period with five consecutive days with flows of260 cfs or
higher at Chualar. The first potential spawning day in the Nacimiento River is assumed to be 8 days after the first
passage day.
hi:...c ~- 1
1\it,'~
h th.::~u:.:~
r-t-r't
0~---o 0u~6" Z 1
wfiD(
i(
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.f.3iot....ob.,C-4\-L 0~1'-Jt(!)~J
1
ll-.-1a...J. t.Jo. iSi4;.-z...SwK_;Aco3_~g<i]1( i
cD
Final EIR
4-252
September 2015
DDT IN THE SALINAS VALLEY
A Special Report on
the Probable Source of Technical Grade DDT
Found in the Blanco Drain Near Salinas, california
STATE OF CALIFORNIA
WATER RESOURCES CONTROL BOARD

EDWARD C. ANTON, CHIEF
DIVISION OF WATER QUALITY
HURT LININGER, CHIEF
HAZARDOUS WASTE SECTION
JOHN Mt YOUNGERMAN, CHIEF
SURVEILLANCE AND MONITORING UNIT
THIS REPORT WAS PREPARED BY
BRUCE A. AGEE
Special Water Quality Monitoring Report No. 86-2 WQ

Final EIR
4-253
September 2015
INTRODUCTION
The sale and use of DDT, once thought to be the ultimate pesticide, was banned
by the u. s. Environmental Protection Agency in 1972 after it was found to be
responsible for the rapid decline of several predator species in the
environment and questions were raised concerning potential effects on human
health. California had curbed the sale and use of DDT two years earlier in
December 1970.
The special characteristics that made DDT such a persistent and deadly
pesticide are also the characteristics that still make it a potent
environmental hazard. DDT, or dichloro-diphenyl trichloroethane, is a white
amorphous powder that is nearly insoluble in water, but readily soluble in
organic solvents. It has a low volatility and is not easily decomposed by
sunlight. 'When DDT does break down, it is converted initially to DDD or DDE.
Usually, DDE is the major initial breakdown product. However, in sediments,
DDD can also be a significant component. These products--DDD and DDE--are
also toxic and very persistent in the environment. DDE is the chemical linked
to the thinning or eggshells in birds and was responsible for the reproductive
failures of the Brown Pelican along the California coast.
DDT and its related products are found virtually everywnere on earth. Its
high solubility in (non-polar) organic mixtures such as oils or fats causes it
to have a high affinity for living organisms; once ingested by an organism,
DDT or its metabolites are not quickly lost, so they tend to accumulate. As
predator eats prey, DDT is passed upwards in the food chain in higher and
higher concentrations.
Although use of DDT was banned in California in 1970, it is still found in
high concentrations in fish from several California rivers and lakes. For
example, in 1983 DDT was found at levels exceeding National Acade~ of
Sciences (NAS) guidelines for predator protection in fish from seven rivers
and streams, including the Old Salinas River, the Salinas River at Blanco
Drain, Harbor Park Lake, San Joaquin River at Vernalis, Alamo River, New
River, and San Diego Creek.
As in previous years, speculation as to the possible sources of DDT included
old residues, continued illegal use, leaky waste dumps, or contamination from
use or a related pesticide, Kelthane (dicof'ol). In an attempt to identify the
possible sources of DDT, monitoring staff began to look more closely at DDT
isomers and breakdown products rather than simply at the total concentration
of DDT.
The term "Total DDT", as used in this report, refers to the sum of the
individual concentrations of DDT and its closely related breakdown products,
DDD and DDE. Some labol"atories (e.g., Department of Fish and Game) also
measQre two minor breakdown products, DDMU and DDHS, found in small amounts.
When found, these are also included in Total DDT (Figure 1). Each of these
-7-

Final EIR
4-254
September 2015
Breakdown
~ ~
DDT slowly breaks down in the Drain sediments; by the time it reaches the
Salinas River, it has broken down to about 20 percent Technical DDT, 35
percent DDD, and the remainder DDE. The major breakdown products, DDD and
DDE are as undesirable in the environment as the parent compound.
The persistence of DDT in the soils could not be determined by this study,
but it is probably very persistent. Earlier studies conducted in the
Salinas/Elkhorn Slough area reported lesser amounts of Total DDT in soils
than found in this study. Further study is needed to determine how
persistent DDT is in Salinas soils.
Salinas area agricultural soils contain a "reservoir" of DDT, which is

being released to the aquatic environment (drains, canals, rivers, bays,
etc.) through soil erosion due to agricultural practices and rainfall
runoff events. Considering the mixing of DDT into the soil column and
normal soil erosion rates, it is probable that this release of DDT into
the Salinas River will continue well into the 21st Century.
.--
Possible Transport Mechanisms

0
Fields on the east end of the Drain are literally plowed over the edge and
into the Drain. Sediments in the east end of the Drain contain the
unmistakable fingerprint of soil-based DDD and Technical DDT. In the
lower portions of the Drain, where berms exist, ODD and DDT ratios are
more characteristic of sediment. Staff are convinced that the observed
practice of plowing over the edge of the Drain is a major source of DDT to
the Drain. Other erosion events may also contribute to the DDT found in
the Drain.
Corbicula (clams) planted by State Mussel Watch in the Blanco Drain

contained the highest concentrations of Total DDT (and other chemicals)
ever seen in California; 3,800 ppb (3.6 ppm, wet weight). This indicates
that much of the transport of DDT is via very fine suspended materials
through and out of the Drain.
DFA regularly tests vegetables in the Salinas area and has reported
finding no (or extremely little) DDT in unwashed vegetables. This has
generally been true ever since the use of DDT was discontinued in 1972.
This strongly indicates that there has been no continued use of DDT in the
Salinas area for agricultural purposes.
Corrective Measures
o
Positive steps taken to reduce or eliminate soil erosion could result in

major reductions in the amounts of DDT input to the aquatic environment,
with increased water quality/aquatic life benefits. If these steps are
-12-

Final EIR
4-255
September 2015
One isomer of DDT, o-p'-DDT, was believed by scientists to be fairly unstable

and was expected to break down more rapidly than the p-p' isomer in the
aquatic environment. Dr. Risebrough found that in the soils contiguous to the
Blanco Drain the o-p' isomer was, if anything, breaking down less rapidly than
the p-p isomer and stated that the DDT was likely not fresh, simply well
preserved. (Risebrough, 1985).
After considering the preliminary results, Phase 2 of the study was initiated.
The purposes of the second phase study were to verifY the Phase 1 results and
to isolate and identifY possible sources of DDT to the Blanco Drain from
adjacent fields. In the second phase survey, sediment was collected from 23
locations while soil was collected from 13 locations.
FINDINGS
Soils from fields adjoining

5,000 ppb (5 ppm) Total DDT
soils from fields adjoining
ppb (3 ppm) DDT and average
the east leg of Blanco Drain contain up to

and average 3 1 100 ppb (3.1 ppm) DDT while
the west leg of the Drain contain up to 3,000
1,800 ppb (1.8 ppm) DDT.
With the exception of one sampling station, soils from fields adjoining
all parts of the Drain contain a nearly uniform 66 to 80 percent Technical
DDT (average 72 percent).
o
With the exception of the same sampling station, soils from fields
adjoining all parts of the Drain contain a uniform 1.4 to 5.6 percent DDD
(average 3:s-percent).
DDT and DDD from the exceptional station more closely resemble the DDT and
DDD found in the sediments in the Drain itself, and there is some
indication that the soils at that station were derived from sediment moved
when the Drain was physically relocated at that location.
Most of the soil samples also contain 15 to 20+ percent o-p'-DDT as a

percentage of Technical DDT (average 17 percent). This is very similar to
the original formulation of Technical DDT.
Sediments
o
Bottom sediments in the east leg of the Drain had levels of Total DDT
ranging from 800 ppb (0.8 ppm) to 6,200 ppb (6.2 ppm). The average
concentration was 2 1 200 ppb (2.2 ppm). Sediments in the west leg of the
Drain had levels of Total DDT ranging from 200 ppb (0.2 ppm) to 1,700 ppb
{1.7 ppm). The average was 800 ppb (0.8ppm). These levels are 200 to 400
times the levels measured in the Salinas River above the outfall of Blanco
Drain.
-10-
'
- -

Final EIR
'
"-
--
_...,_,._ _ _
4-256
16
ot e
lott_,
. . , , . ,.....
a.~a.
'\.IL
Lo.l.\0
September 2015
chemicals actuallY occurs in two closely related forms, or isomers. Most of a

given chemical is found in the "para-para" form (e.g., p,p'-DDT, p,p-DDD,
p,p'-DDB). However, often the "ortho-para" forms are also present (e.g.,
o,p'-DDT, o,p'-DDD, o,p'-DDE). The original formulation of DDT, as applied to
crops, is referred to as "Technical DDT" and is a mixture of roughly 80
percent p,p'-DDT and 20 percent o,p'-DDT. When DDT breaks down, the relative
amounts of DDD and DDE that are formed depend on environmental conditions.
Over time, DDD will break down to other products (e.g., DDMU and DDMS) and
eventually disappear from the environment. DDE is much more stable and
remains in the environment for a long time.
SUMMARY
DDT has been found in moderate to high concentrations in the Salinas River and
lower Moss Landing watershed for many years. In 1984, staff from the State
Water Resources Control Board (State Board) devised some simple criteria
designed to indicate how closely the Total DDT resembled Technical DDT as
compared to its breakdown products, DDD and DDE.
Upon analysis, staff found that fish from the Salinas area were among those
that had unusually high fractions of Technical or "fresh" DDT. In particular,
both fish and sediment samples from the Salinas River clearly indicated that
one source of this material was the Blanco Drain which empties into the
Salinas River. At the time, we considered any measurement greater than 10
percent Technical DDT (DDT only) as compared to Total DDT (DDT + DDD + DDE) as
high and worthy of further investigation. Approximately 25 percent of the
Total DDT found in sediments and fish from the mouth of the Blanco Drain was
Technical DDT. This value was about as high as had been found in the Toxic
Substances Monitoring Program.
These results provided the impetus for a special study in the Blanco Drain to
determine the probable source of the DDT found at the mouth of the Drain.
That study, coordinated by the State Board, involved the cooperation and
resources of several local and state agencies including the Monterey County
Agricultural Commissioner, the County of Monterey, the Central Coast Regional
Water Quality Control Board, the California Department of Fish and Game (DFG),
the California Department of Food and Agriculture (DFA), and the Moss Landing
Marine Laboratory.
The study was conducted in two phases. Phase 1 was intended to characterize
the Blanco Drain. Fifteen sediment samples were collected by staff and five
composite soil samples were collected by Dr. Robert Risebrough in cooperation
with State Board staff. The results were striking. Both the soils and
sediments of Blanco Dr.a in contained up to 5 parts per million (ppm) Total DDT
and up to 70 percent Technical DDT. The percent Technical DDT was the highest
ever measured in the TSM program. In addition, the sediment data indicated
that the highest values were confined to a few stations, possible "hot spots"
along the Drain.
-9-

Final EIR
4-257
September 2015
Ch. 6 water Quality Assessment 139
fecal Coliform log tMPN/1 OOmll
0.1
10
100
1000
10000
100000
Figure 6.5 Mean fecal colifom at all CCAMP measured waterbodles throughout the Central Coast Region 3. Waterbodies in the
Redamatlon Ditch Watershed are shown In dark red (Units: log scale MPN/1 00 mO.

Final EIR
4-258
September 2015
Ch. 6 Water Quality Assessment 141
Legacy pesticides
Legacy pesticides are those that are no longer used, but are persistent in the
environment. Many are organochlorine insecticide compounds that were banned
primarily in the 1970s. The best known Is DDT and its byproducts, DOE and DDT, us~eq
in the Reclamation Ditch Watershed apparently for mosquito abatement: agricultural,
and urban uses. These compounds are still found in the waters and sediments of the
Reclamation Ditch Watershed.
The Salinas River Lagoon Management and Enhancement Plan OGA et al., 1997) cites a
number of studies from the 1980s suggesting that soils in the northern Salinas Valley
contain a reservoir of DDT that will continue to release DDT into aquatic environments
'well into the 21st Century'. During relatively quiescent conditions in 1999, CCAMP
measured p,p'-DDE in sediments at above 35 !lgfkg at OlS-POT and GAB-BOR an
above 5 !lg/kg at REC-AIR, REC-BOR, and TEM-PRE (Worcester et al., 2000) (see Table 6.
for explanation of site codes). Four years later during a storm in March 2003, Kozlowski
et al., (2004b) measured p,p'-DDE in sediments at 65 !lgfkg at REC-JON, 61 !lg/kg at
OlS-POT, and 27 11g/kg at TEM-RAI. These concentrations fail to meet objectives
pertaining to biological toxicity. Long et al., (1995) define the biological effects range
median (ERM) for p,p'-DDE as 27 !19/kg . Kozlowski et al., (2004b) also detected DDT
byproducts and Dieldrin in the water column - calculating an export to Moss Landing
Harbor and the Monterey Bay National Marine Sanctuary of about 3 grams of DDT
byproducts per hour during the storm that was sampled.
The above data are not easily comparable over time because Worcester et al., sampled
during a quiescent period, and Kozlowski et al., sampled during a storm - when legacy
pesticides are expected to reach elevated levels due to the mobilization of the
sediments to which these compunds typically bind. There is however, some evidence
for a gradual decline in DDT byproducts levels in the neighboring Blanco Watershed.
Here, Mischke et al., (2003) reviewed total DDT levels in 1984 to average 2100 !lg/kg,
whereas Kozlowski et al.. measured levels of 256 and 305 !J.Q/kg respectively at two
sites in the watershed.
303d list of Impaired Waterbodles

Several water bodies of the Reclamation Ditch Watershed and others downstream have
been listed as having water quality that does not meet set water quality standards
Central Coast Watershed Studies (CCow.s)
(j)
Final EIR
4-259
September 2015
Ch. 6 Water Quality Assessment 143
8
Path
Pest
Sed
6
jDO*
l!Fee\.._
Nutr""-
Pest
5
Fee
Nutr
'-Pest
\ "t
3
DO*
Fee*
'\
...
2
Fee*
Nit*
Org
i1
Pest .
1. Upper Reclamation Ditch
(Aiisal Creek)
2. Gabilan Creek
3. Lower Reclamation Dilch
;,
4. Espinosa Slough
"'"
5. Tembladero Slaugh
6. Old Salinas River Channel
It
1
Fee
Nit
7. Mass Landing Hartlor

8. Elkhorn Slough
9. Monterey Bay South (Coastline)
2. 5
5 kilometers
Mop produced: Joel~& Frodv-.

SlrHrns: USGS NHD dMaSM
Roads: Marnn!v COu11ly
2.5
5 miles
i<:J ceow.s. 3XS4
Figure 6.6 Section 303(d) listings for various water bodies within and adjacent to the Reclamation Ditch
Watershed.
DO = Low dissolved oxygen
Fee = Fecal Coliform

Nit ~ Nitrate
Nutr = Nutrients
Org = Priority Organics
Pest = Pesticides
Sed = Sedimentation/Siltation
Met= Metals
" Ustings added in 2002 (approved by EPA, 2003). All others were Included In the 1998 listing.
Central Coast Watershed Studies (CCow.s)
(j)
Final EIR
4-260
September 2015
TMDL tor Nutrients in Lower Salinas River
Watershed~
Monterey county, camorrua- ~...
rage k
01
The TMDL progress report (http:/lwww.swrcb.ca.gov/centralcoast/water_issucs/programslbndVdocs/salinas/nutrientslsal_nut_dataanalyrpt_06141 O.pdt) dici
not address 'critical' environmental factors associated with nulrient loading in the Lower Salinas River Watershed, in which a slight increase in nutrients
could lead to exceedance of water quality objectives. However, the progress report does specifY some indicators that can impair the beneficial uses of the
regional water bodies.
Data analysis for the June 2010 California Regional Water Board Progress Report include4:
A delineation of watershed boundaries
A list of subwatersheds
Stream classification, which revealed in general low gradient streams on the valley floor were perennial, and many headwater streams tended to be
ephemeral.
An assessment of groundwater as bascflow. For the TMDL project area bascflow index values for groundwater ranged from 38 to 26 percent
An assessment of mean groundwater nitrate concentrations for the project area. Values reported ranged from 0.1-10.0 mg/1 to I 00.1-200.0 mg/1 of
nitrate.
An assessment of mean annual precipitation for the project area. For the project area values ranged between 11.1 inches to 33.5 inches on average
annually.
An analysis ofland use and land cover. In the project area, land uses include approximately 34% furmland, 31% grazing land, 8% urban, and 26%
undeveloped/forested/restricted.
2012 TMDL Report

The 2012 CCRWQCB project report draft ofTMDL for nutrients in the Lower Salinas River Watershed (LSRW) (Monterey County, CA)111 is titled: Total
MaJCimum Daily Loads for Nitrogen Compounds tznd Orthophosphate for the Lower Salinas River and Reclamation Canal Basin, and the Moro Cojo Slough
Subwatershed, Monlerey CounJy, California AND WAS COMPLETED/FILLED DATE. Nutrients are defined as biologically-accessible nitrogen
compounds and orthophosphate loading into waterways of the LSRW.
This draft report indicates a proposed geographic scope of around 405 acres in the Lower Salinas Valley of northern Monterey County, focused on the two
m~or drainages, the Reclamation Canal Drainage and the Lower Salinas River Drainage (pictured at right). The Moro Cojo subwatershed is identified as a
subwatershed in the repon.
The ultimate receiving body (drainage) of both waterways and tributaries is the Monterey Bay and the Monterey Bay National Marine Sanctuary. Pollutants
addressed by the proposed 2012 TMDL draft are nitrate, un-ionized ammonia, and orthophosphate. Reductions in pollutants are expected to target 303(d)listed impairments from low dissolved oxygen (DO) and chlorophyll-a within theproject area. These impairments relate to the biostimulatory effects of
nitrate and orthophosphate on freshwater systems.
According to the draft TMDL report (2012):
"Discharges of nitrogen compounds and orthophosphate are occurring at levels in surface waters which are impairing a wide spectrum of
beneficial uses and, therefore, constitute a serious water quality problem. The municipal and domestic drinking water supply (MUN, GWR)
beneficial uses and the range of aquatic habitat beneficial uses are currently impaired; potential or future beneficial uses of the agricultural
irrigation water supply (AGR) for sensitive crops may be impaired. A total of34 waterbody/pollutant combinations are impaired due to
exceedances of water quality objectives. The pollutants addressed in this TMDL are nitrate, un-ionized ammonia, and orthophosphate.
Orthophosphate is included as a pollutant due to biostimulatory impairments of surface waters. Reducing these pollutants is also anticipated to
address several303(d)-listcd dissolved oxygen and chlorophyll a impairments in the TMDL project area. As a result of these conditions,
beneficial uses are not being protected." tznd
"By developing TMDLs for the aforementioned pollutants, the water quality standards violations being addressed in this TMDL include:
Violations of drinking water standard for nitrate
Violations of the Basin Plan general toxicity objective for inland surface waters and estuaries (violations of un-ionized ammonia
objective)
Violations of the Basin Plan narrative general objective for biostimulatory substances in inland surface waters and estuaries (as expressed
by excessive nulrients, chlorophyll a, algal biomass, and low dissolved oxygen)"
According to the CCWRQCB draft TMDL nutrient report (2012):
"There does not appear to be a significant geologic reservoir in the project area that could contribute to elevated nitrogen loads to surface
waters."
Eutrophication of waterways may occur when excess nutrients are present and environmental conditions promote algal growth. Biologically-accessible
nitrogen and phosphorus are limiting nutrients in many ecosystems (CITE). 1n general, sources of nutrients in watersheds include: urban runoff, fertilizers,
groundwater, livestock, wastewater treatment plants, and septic systems. Specifically for the Lower Salinas River Watershed (Anderson et al. 2003) PI
identified irrigated agriculture as the dominant source of nutrients in watersheds in the region.
According to the SWRCB-contracted UC Davis report141 (Harter and Lund 2012) on nitrate in California's Drinking Water for the State Water Resources
Control Board (SWRCB), nitrates are reducing quality of drinking water from shallow wells. The report concludes that: "Most nitrate in drinking water
wells today was applied to the surface decades ago.
The report is part of a contracted study for the SWRCB as part of the Senate-mandated Groundwater Nitrate Project as part of biannual reporting on initial
studies into nitrate effects on drinking water in the Tulare Basin and Salinas Valley. The report also cites agriculture as the estimated source of96% of
nitrate loading to groundwatcr--200 GB/yr (1 Gg = 1100 tons) within these regions, with the next largest (estimated) source (wastewater treatment and food
processing wastes) loading 3.2 Gg nitratclyr to groundwater.
http://ecoviz.csumb.edu/wiki/index.phpffotal_ Maximum_Daily_Load_for_Nutrients_in_L... 2/18/2013

Final EIR
4-261
CLQ)
September 2015
LetterU: WaterRatepayersAssociationoftheMontereyPeninsula
U-1
As discussed in Chapter 3 of the Draft EIR and Appendix D Pure Water Monterey
Groundwater Replenishment Project Water Quality Statutory and Regulatory Compliance
Technical Report, planning for the Proposed Project included the following:
Characterizations of the quality of the new source waters to be diverted to the Regional
Treatment Plant and Advanced Water Treatment Facility. The list included general
water quality parameters (such as total nitrogen and total organic carbon), pathogens
and indicator bacteria, constituents with California drinking water standards (inorganic
chemicals, metals, organic chemicals, disinfection by-products, radionuclides),
constituents with California action levels for lead and copper, constituents with
California Notification Levels and archived Advisory Levels, United States
Environmental Protection Agency (EPA) Priority Pollutants, chemical constituents
included in the EPA Unregulated Contaminant Monitoring Rule Lists 1, 2 and 3,
pesticides of local interest based on the agricultural activity/usage in the area, and
constituents of emerging concern (pharmaceuticals, ingredients in personal care
products, etc.). The list specifically included DDT, DDE, arsenic, and boron.
A pilot study of some of the source waters and treatment technologies intended to be
part of the new Advanced Water Treatment Facility.
As described in the Draft EIR in Section 2.8, the proposed full-scale Advanced Water
Treatment Facility would consist of pre-treatment (using ozone, and potentially biologically
activated filtration); membrane filtration; reverse osmosis; advanced oxidation using
ultraviolet light and hydrogen peroxide; and post-treatment stabilization. The State Water
Resources Control Board - Division of Drinking Water (DDW), Regional Water Quality Control
Board (RWQCB), and a National Water Research Institute expert panel provided oversight for
the above technical studies, including water quality characterization, and project planning. The
DDW has conditionally approved the Projects design (see Draft EIR Appendix D). As
described in the Draft EIR in Chapter 3 and in Appendix D, the proposed treatment for the
purified recycled water for injection into the groundwater basin would remove pathogen and
bacterial indictors present in the wastewater and new source waters to levels below detection.
The Advanced Water Treatment Facility alone would achieve pathogen reduction credits of
13.5 for virus, 11.5 for Giardia, and 11.5 for Cryptosporidium, which are greater than the credits
required by the Final Groundwater Replenishment Regulations. The treatment to be provided
by the Proposed Project would effectively remove any chemical constituents present in the
wastewater and new source waters to levels below detection and/or safe levels prior to
groundwater injection. Based on the source water sampling, piloting testing results, information
on the predicted performance and water quality of the proposed full-scale Advanced Water
Treatment Facility based on performance and water quality monitoring of other existing
groundwater replenishment projects, and pertinent research, the purified recycled water that
would be produced by the Regional Treatment Plant and full-scale Advanced Water Treatment
Facility would meet DDW and RWQCB health and water quality regulations for groundwater
replenishment. See Chapter 3, Section 4.10, and Appendix D of the Draft EIR for more
information.
U-2
As stated on page 6-10 of the Draft EIR, the Monterey Bay Regional Water Project, proposed
by DeepWater Desal, LLC, and the Peoples Moss Landing Water Desalination Project are not
considered to be alternatives to the Proposed Project. They would not achieve the objective of
providing replacement water for the Monterey District service area customers within the
approximate timeframe specified in the Proposed Projects objectives, because they could not
be developed for several years. In addition, neither of the proposed desalination projects would
be alternatives that would avoid or reduce the environmental effects of construction of the

Final EIR
4-262
September 2015
Proposed Project because they would require a greater extent of new infrastructure (in
particular, pipelines) to be built compared to the Proposed Project. Seawater desalination
projects also require substantially more electricity per unit of water produced (due to the high
pressures required to desalinate ocean water) and therefore, the resultant greenhouse gas
emissions would be higher than under the Proposed Project. The Draft EIR text on page 6-10
has been amended to include this clarification regarding the potentially greater environmental
impacts of the two projects. See Chapter 5, Changes to the Draft EIR.
.
The comment suggests that the timing of the two desalination projects has changed and that
the desalination projects must be considered as alternatives to the Proposed Project in the
Draft EIR.
According to a report prepared for the MPRWA by SPI, Inc. in Jan 2013, the timeline from the
commencement of the Environmental Impact Report (EIR)/Environmental Impact Statement
(EIS) process for the Monterey Bay Regional Water Project (DeepWater Desal Project) to
completion of construction was estimated to be just over four years (see page 6-9 of the report)
(http://www.mprwa.org/wp-content/uploads/2013/01/MPRWA-Report.Update.Jan-2013.pdf).
The Notice of Preparation (NOP)/Notice of Intent (NOI) to Prepare an EIR/EIS for the
DeepWater Desal Project was published June 1, 2015 and can be viewed at the following
websites:
http://www.soquelcreekwater.org/sites/default/files/documents/Reports/DWD_NOPNOI%20June_2015_Final-1.pdf, and
https://www.federalregister.gov/articles/2015/06/01/2015-12877/proposedmonterey-bay-regional-water-project-desalination-facility-intent-to-prepare-a-draft).
Assuming publication of the NOP/NOI commences the Complete EIR/EIS task in the schedule
in the SPI report, the construction of the Deep Water Desal Project may be complete by the
middle of 2019. Based on this information, the Deep Water Desal Project would not meet the
timeframe objective of the Proposed Project.
According to a report prepared for the MPRWA by SPI, Inc. in Jan 2013, the timeline from the
commencement of the Environmental Impact Report (EIR)/Environmental Impact Statement
(EIS) process for the Peoples Moss Landing Water Desalination Project (Peoples Project) to
completion of construction was also estimated to be just over four years (see page 6-11 of the
report) as shown the
(http://www.mprwa.org/wp-content/uploads/2013/01/MPRWAReport.Update.Jan-2013.pdf). A NOP to Prepare an EIR for the Peoples Project was published
in
late
June
2015
and
can
be
viewed
at
the
following
website:
http://www.mosslandingharbor.dst.ca.us/downloads/NOP_Peoples%20Desal%20%20Final%20for%20Publication%20-%202015JUN25%20%282%29.pdf).
Assuming publication of the NOP commences the Complete EIR/EIS task in the schedule in
the SPI report, the construction may be complete by the middle of 2019. Based on this
information, the Peoples Project would not meet the timeframe objective of the Proposed
Project.
Also, neither desalination project would meet the following secondary project objectives:
Provide additional water to the Regional Treatment Plant that could be used for crop
irrigation through the Salinas Valley Reclamation Plant and Castroville Seawater
Intrusion Project system; and
Assist in preventing seawater intrusion in the Seaside Groundwater Basin.

Final EIR
4-263
September 2015
In accordance with Section 15126.6 of the CEQA Guidelines, the range of potential
alternatives to the Proposed Project shall include those that could feasibly accomplish most of
the basic objectives of the project and could avoid or substantially lessen one or more of the
significant effects. The EIR should briefly describe the rationale for selecting the alternatives to
be discussed. .Among the factors that may be used to eliminate alternatives from detailed
consideration in an EIR are:(i) failure to meet most of the basic project objectives, (ii)
infeasibility, or (iii) inability to avoid significant environmental impacts. Neither the Monterey
Bay Regional Water Project (DeepWater Desal, LLC) nor the Peoples Moss Landing Water
Desalination Project would be feasibly implemented by the MRWPCA, and neither are
considered alternatives that would avoid or reduce the significant effects of the Proposed
Project based on information provided. See Master Response #12: Adequacy of Range and
Scope of Alternatives in Chapter 3, Master Responses to Comments.
U-3
The comment states the Final EIR must consider an alternative to the Proposed Project that
could provide all the needed water supplies for the Cal Am Monterey District service area. A
larger AWT Facility is not needed to accomplish the project objectives. Further, a larger AWT
Facility would not reduce the significant effects of the Proposed Project. See also response to
comment U-6, and Master Response #12: Adequacy of Range and Scope of Alternatives in
U-4
The comments suggest the EIR consider the use of slant or slope wells in the Carmel Bay as
an alternative water supply and to preclude the need for the north-to-south pipes in the
alternatives of CalAms desalination project and address source-water rights for the Cal Am
desalination project and the Proposed Project. Although it does not say this explicitly in the
comment, it is assumed that the comment intends the slant wells be built to collect seawater or
brackish groundwater for a desalination plant. The scope and range of alternatives described
and evaluated in the Draft EIR are considered reasonable. Designs and locational information
about any potential slant well near Carmel Bay (in addition to the required desalination plant,
brine disposal, pipelines and pumps) have not been presented; however, it is a reasonable
assumption that such a project would have additional or more severe environmental impacts. In
addition, it is also reasonable to assume that the amount of analysis, planning, and permitting
needed to implement a new potential slant well and the required associated collection,
distribution, and treatment infrastructure would preclude that component from meeting the basic
project objective of timing. For the reasons stated above, this seawater desalination alternative
(i.e., one with slant wells collecting water from Carmel Bay) is not analyzed further in this EIR.
See Master Response #12: Adequacy of Range and Scope of Alternatives in Chapter 3,
U-5
This comment concerns the timing of the water right agreements. The agencies anticipate that
the source waters will be addressed through a Definitive Agreement, which likely will be
finalized after the certification of the EIR. To the extent that rights need to be obtained from the
State Board, such applications will be pursued after the certification of the EIR. The State
Board would act as a responsible agency and would be able to rely on this EIR for its
approvals. Publication of this EIR is not premature; rather an EIR is needed for the State Board
to act on the pending water rights applications.
U-6
The comment states the earlier versions of the Proposed Project assumed source waters only
from urban wastewater sources. The comment asserts that if wastewater is the only viable
water supply source, the Final EIR must consider an alternative to the Proposed Project that
could provide all the product water projected by the combined CalAm and Pure Water Monterey
projects year-round. See Master Response #3: Availability, Reliability, and Yield of Source
Water Supplies. The technical reports and documentation in this EIR identify source water
supplies and rationale for their inclusion. The EIR project objectives identify supplying 3,500
acre-feet of water to the Cal-Am system. Source water documentation and requirements for
agreements provide evidence that the sources of availability will not have to rely solely on the
urban wastewater supplies during the winter months as documented in the Draft EIR and in

Final EIR
4-264
September 2015
Master Response #3: Availability, Reliability, and Yield of Source Water Supplies. A larger AWT
Facility with a capacity to produce 3,500 AF all during the four winter months (i.e., to shut down
for 8 months every year) was not analyzed in this EIR because it would have greater
environmental impacts (including, but not limited to, larger plant footprint and process
equipment sizes, larger construction disturbance areas, larger product water conveyance
pumping and pipeline capacities, additional electricity use and greenhouse gas emissions). In
addition, the scenario of using the AWT Facility only during the winter months was determined
to be infeasible by the MRWPCA during early project planning due to engineering and technical
considerations of operations of an advanced water treatment plant. See Master Response #12:
Adequacy of Range and Scope of Alternatives in Chapter 3, Master Responses to
Comments.
U-7
The GWR project in Orange County (Groundwater Replenishment System or GWRS) uses both
surface spreading ponds and injection wells for groundwater replenishment. The recycled water
contribution for the GWRS is 100%, meaning no diluent water is required for either the surface
or subsurface application components of the project. As discussed in Appendix D of the Draft
EIR (the Water Quality Statutory and Regulatory Compliance Technical Report), the Final
Groundwater Replenishment Regulations allow for RWCs of 100% for injection projects that
use full advanced treatment (e.g., a treatment system with reverse osmosis and advanced
oxidation) that meets specific performance criteria. The Project will utilize a full advanced
treatment process as part of the AWT Facility that will meet the full advanced treatment criteria,
and thus will be allowed to use up to 100% purified recycled water for injection in accordance
with the regulations. The DDW has conditionally approved the Projects design.
U-8
See the responses to comments U-1 and Y-1.
U-9
This comment lists attachments to the letter that are provided herein; no response necessary.
U-10
U-11
See the response to comment U-1.
U-12
U-13
U-14
U-15
U-16
See the responses to comments C-1 through C-6.
U-17
The Seaside Basin Watermaster has been actively involved in development of the Proposed
Project and has reviewed the Draft EIR and provided comments. See letter N and responses to
that letter. The siting and operational methods of the Proposed Project Injection Well Facilities
were developed using the groundwater model developed by the Watermaster (i.e., the creator
of the model, HydroMetrics WRI conducted the modeling).
U-18
The comment states an opinion of the Proposed Project and is referred to decision makers for
their consideration. See the responses to comments U-1 and U-7.

Final EIR
4-265
September 2015

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Final EIR
4-266
September 2015
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Final EIR
4-267
September 2015
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Final EIR
4-268
September 2015
V-6
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Final EIR
+:.*++:,'#&:CAAC@AG@CI@$+@,*++)5'
4-269
September 2015
V-9
V-10
LetterV: SurfriderFoundation
V-1
V-2
No response is necessary; the comment expresses general opinion on environmental analysis

and on policy considerations (importance of continued water conservation).
V-3
The comment asks why capture and reuse of additional urban runoff is infeasible. The
Proposed Project would use the existing sanitary sewer collection system to convey flows from
the newly developed water sources to the MRWPCA Regional Treatment Plant. The
stormwater yield analysis therefore had to consider how much conveyance capacity exists
within the existing system under peak wet weather flow conditions. In older sewer systems, it is
not uncommon to have stormwater infiltrate into the sanitary sewer pipes during and following
rainfall events. It is imperative that the addition of captured stormwater to the sanitary sewer
system not result in system back-ups and overflows, which would violate SWRCB Order No.
WQ 2006-0003-DWQ, Statewide General Waste Discharge Requirements for Sanitary Sewer
Systems (with amendment Order WQ 2014-0058). While it is true that many of the MS4
discharges have water quality concerns, the risk of discharging untreated sewage is a
significantly greater concern. Therefore, the analysis focused on locations where the
stormwater system crossed or was close to the MRWPCA wastewater interceptor system,
which is relatively new gasketed pipe and actively monitored.
The Proposed Project could still accept first-flush flows, which occur at the beginning of rain
events and carry the majority of the surface pollutants, so long as they are diverted in advance
of the peak wet weather flows in the sanitary sewer system. However, the frequency and
volume of these small stormwater pulses would not result in significant yields that would assist
the project in meeting its objectives. Designing and constructing additional diversion facilities
for the Proposed Project was not considered to be feasible and would not meet project
objectives based on the cost and schedule implications of the design, permitting, and
construction compared to the other water supply sources considered.
Finally, the provisions of the California State Constitution and Water Code quoted in this
comment do not mandate the capture of stormwater, as implied. The prohibitions of waste or
unreasonable use apply to water that has been diverted, and are more typically understood to
mean that if the stormwater cannot be diverted to a beneficial use, it shall be left in the natural
watercourse. See also Master Response #12: Adequacy of Range and Scope of Alternatives in
V-4
The comment expresses a preference for the RUWAP Alignment Option for the Product Water
Conveyance Pipeline, instead of the Coastal Alignment and the desire for an alternative to the
Monterey Pipeline portion of the CalAm Distribution System. The opinions about alternatives to
the Proposed Project stated in the comment are referred to decision makers for their
consideration. The Draft EIR describes and evaluates an alternative to the Monterey Pipeline
on pages 6-36 through 6-52 and finds that the alternative Monterey Pipeline would be
environmentally superior to the proposed Monterey Pipeline partially due to the lack of impacts
to coastal resources. The significant impact related to exposure to coastal erosion and sea
level rise (Impact GS-5) would be eliminated with the alternative Monterey Pipeline (see last
line on page 6-42 of the Draft EIR) and no mitigation measures would be required. See also
Master Response #12: Adequacy of Range and Scope of Alternatives in Chapter 3, Master

Final EIR
4-270
September 2015
V-5
Regarding impacts related to the species and habitat in Tembladero Slough due to the
proposed diversions at that site, see the responses to comments F-9 through F-9e, G-2, G-3,
V-8 and V-9, below, and Master Response #4: Reduction of Surface Water Flows and Master
Response #5 Fisheries Impact Analyses in Chapter 3, Master Responses to Comments.
Specifically, these parts of the Final EIR summarize the Draft EIRs analysis of fisheries and
other special status aquatic wildlife and how the Proposed Project would be required to mitigate
the potential impacts on those species. In response to the concern for use of water within
mitigation measures, Mitigation Measure AQ-1 (on pages S-7 and 4.3-25 of the Draft EIR) has
been revised as requested, including adding language to minimize water use and to require
that contractors use non-potable water. See Table S-1Revised and changes to page 4.3-25 in
V-6
As described in the Draft EIR in section 4.11.4.5 (page 4.11-101), the strategies described in
Mitigation Measures HS-C would ensure that discharges of the waste stream from the
proposed Advanced Water Treatment Facility (called reverse osmosis, or RO, concentrate) in
combination with discharges of other wastes from cumulative projects through the Regional
Treatment Plant outfall would meet the California Ocean Plan objectives that were established
to protect human health and marine resources. Appendix V (which is summarized in Section
4.11.4.5 of the Draft EIR) provides the detailed analysis of the impacts and mitigation measures
for a range of flow and water quality scenarios that aimed to characterize the worst-case
conditions of outfall discharges to compare to the Ocean Plan objectives and thus to determine
the significance of impacts. Specifically, Trussell Technologies analyzed combined and
7
separate discharges of (1) future excess municipal wastewater, (2) trucked-in or hauled brine,
(3) reverse osmosis concentrate from the Proposed Project, and (4) ocean desalination brine
from the proposed Monterey Peninsula Water Supply Project (MPWSP) (See Master Response
#11: Proposed Projects Relationship to the Proposed MPWSP). As discussed in the Mitigation
Measure HS-C, MRWPCA will not accept the desalination brine discharge unless specific
design and operational measures are undertaken by the proponent of the desalination project,
individually or in combination, to reduce the concentration of constituents to below the Ocean
Plan water quality objectives at the edge of the zone of initial dilution (ZID). The specific
permitting requirements that would be established by the RWQCB would be based on
information collected and analyzed as part of the RWQCB permitting process. Prior to
establishing the detailed permitting requirements, the proponent of the desalination project
would conduct calculation of the allowable minimum probably initial dilution at the point of
discharge and water quality and flow characterizations for submittal to MRWPCA and the
RWQCB. Thus, these strategies would be implemented to the degree necessary to meet the
California Ocean Plan objectives and to receive approval/permits from MRWPCA and RWQCB,
thereby ensuring cumulative impacts on human health and marine resources would be reduced
to a less-than-significant level.
V-7
The evaluation of the impact of discharging the RO concentrate along with the MRWPCA
treated secondary effluent and the existing hauled brine waste is discussed in Appendix U of
the Draft EIR. Further, a cumulative analysis with MPWSP brine concentrate is evaluated in
Appendix V of the Draft EIR. For the trucked-in brine waste (also referred to as hauled brine
waste in Appendices U and V), the maximum amount of brine flow (i.e. worst-case flow) with
the maximum constituents concentrations observed in the hauled brine waste (i.e. worst-case
water quality) are used in the assessments. See also Master Response #11: Proposed
Projects Relationship to the Proposed Monterey Peninsula Water Supply Project in Chapter 3,
7
For the trucked-in brine waste (also referred to as hauled brine waste in Appendices U and V), the maximum
amount of brine flow (i.e. worst-case flow) with the maximum constituents concentrations observed in the hauled
brine waste (i.e. worst-case water quality) were used in the assessments.

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As for any potential desalination brine from other projects, the Draft EIR cumulative project list
on page 4.1-13 assumes that disposal of the MCWDs desalination brine would not be through
the outfall, but instead MCWD would inject it subsurface in the area of Marina
Dunes/Reservation Road area (per the approved RUWAP Hybrid Alternative). No application or
proposed project plans have been provided that would use the outfall for MCWDs desalination
brine. The geographic scope for the cumulative analysis of impacts to the marine environment
is the immediate vicinity of the ocean outfall because the analysis of the Proposed Projects
impacts shows that the Proposed Project discharges would meet Ocean Plan objectives at the
edge of the zone of initial dilution. Only those cumulative projects that would change the
condition of the marine environment within the zone of initial dilution were considered to be
additive to the less-than-significant impacts of the Proposed Project.
Regardless, if MCWD implements its RUWAP desalination plant or a similar project and its
brine is proposed to be discharged through the MRWPCA ocean outfall, the desalination brine
water quality would be comparable to the CalAm desalination brine, particularly relevant, if the
proposed desalination source water were from the near-shore subsurface area, as is the only
source previously considered in MCWD planning and environmental document. It then follows
that the same mitigation strategies as described in Mitigation Measure HS-C would likely be
applicable to other desalination plant brine discharges through the MRWPCA outfall. Future
implementation of another desalination project that would utilize the MRWPCAs existing ocean
outfall would require further CEQA documentation and analysis by MCWD prior to approval by
either agency.
V-8
The EIR includes mitigation measures to ensure special status species are not harmed by
diversion intakes and provides a description of fish screens to be used in the Reclamation Ditch
and Tembladero Slough diversions. The diversion facilities are described and illustrated in
Appendix P of the Draft EIR, Reclamation Ditch Yield Study on page 21 and Figure 1 and 2.
This information is also summarized in the Draft EIR text on page 2-51 and the proposed site
plans are shown on Figures 2-23 and 2-24. In the analysis of impacts on fisheries (Section 4.4
of the Draft EIR), the fisheries biologists uses the proposed initial sizing criteria that set a
maximum flow velocity of 1 foot per second (fps) at the inlet screen to assess entrainment and
impingement. Salmonids are capable of swimming at 4.5 fps for extended periods of time, as
stated in Appendix G of the Draft EIR, so 1 fps was not considered an
impingement/entrainment risk. The final facility design will incorporate fish screens acceptable
to California Department of Fish and Wildlife and the National Oceanic and Atmospheric
Administration National Marine Fisheries Services (see last paragraph on page 4.4-50 of the
Draft EIR). The tidewater goby is not expected to occur in the stream reaches with diversion
pump stations as described on page 4.4-50 of the Draft EIR, so they are not considered in the
impingement analysis.
No other special status aquatic species are known or documented to occur in the waterbodies
located where the Reclamation Ditch and Tembladero Slough diversions would occur as
documented on Table 4.5-4 (page 4.5-18) of the Draft EIR. Additional and revised mitigation
has been included in the Fisheries Section to insure special status species are not harmed (see
changes to 4.4 of the Draft EIR Chapter 5, Changes to the Draft EIR). See also Master
Also Chapter 5, Changes to the Draft EIR contains revisions to the analyses of biological
resources within the subsections titled: Changes to 4.4 Biological Resources: Fisheries and
Changes to 4.5 Biological Resources: Terrestrial.
V-9
Mitigation Measure AQ-1 (on pages S-7 and 4.3-25 of the Draft EIR) has been revised as
requested, including adding language to minimize water use and to require contractors to use
non-potable water. See Table S-1Revised and changes to page 4.3-25 in Chapter 5,

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V-10
See Master Response #5: Fisheries Impact Analyses, Master Response #12: Adequacy of
Range and Scope of Alternatives, and Master Response #4: Reduction of Surface Water Flows
in Chapter 3, Master Responses to Comments. Also refer to response to comment V-8,
above.

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September 2015
Letter W
"The Fort Ord Community Advisory Group is a public interest group formed
to review, comment and advise on the remediation (cleanup) of the Fort Ord
Army Base, Superfund Site, to ensure that human health, safety and the
environment are protected to the greatest extent possible." - Mission Statement.
Fort Ord Community Advisory Group (FOCAG)
PO Box 969
Seaside, CA 93955
Email: fortordcag@yahoo.com

Monterey, CA 93940
Re: Pure Water Monterey Groundwater Replenishment Project.
MRWPCA is the Lead Agency under the California Environmental Quality Act (CEQA).
The State Clearinghouse number for the project is SCH#2013051094.
June 5, 2015
Dear Mr. Holden,
There follows responses to the DEIR and a resubmittal:
The Fort Ord Community Advisory Group hand delivered extensive scoping comments and questions
to your MRWPCA Agency office. We have reviewed the Draft EIR and are disappointed at its weak
responses
to questions, concerns and suggestions made in our scoping submittal.
One of the largest, if not the largest U.S Army impact area, in the United States of America
is Site 39 on former Fort Ord. Site 39 is right over the Seaside Groundwater Basin.
We provided an overlay map to you.
W-1
W-2
Please identify the boundaries of Site 39 impact area and how they relate to the Seaside Aquifer.
Where did decades of military use chemicals go?
W-3
Where will these decades of use of military chemicals go when there is development above
the Seaside Aquifer?
W-4
Where will decades of military chemicals migrate to?
W-5
We are resubmitting our letter to you for the DEIR. Referenced attachments are on file with
your office. Please find letter attached. We look forward to substantive responses.

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September 2015
Fort Ord Community Advisory Group (FOCAG)

P.O. Box 969
Seaside, CA 93955
Phone: 831-484-6659
Email: focagemail@yahoo.com
The "Fort Ord Community Advisory Group is a public interest group formed
to review, comment and advise on the remediation (cleanup) of the Fort Ord
Army Base, Superfund Site, to ensure that human health, safety and the
environment are protected to the greatest extent possible." - Mission
Statement.
Monterey Regional Water Pollution Control Agency (MRWPCA)

ATTN: Bob Holden
5 Harris Court, Bldg D
Monterey, CA 93940
Via E-mail: GWR@mrwcpa.com, hard copy to follow via U.S. Mail
Re: Notice of Preparation, Scoping Comments
Monterey Peninsula Groundwater Replenishment Project Environmental
Impact Report
July 2, 2013
Dear Bob Holden,
The Fort Ord Community Advisory Group (FOCAG) offers the following
comments on the scope of environmental issues. The scope should include
existing hazards to drinking water and potential increasing hazards to the
drinking water supply due to the migration and leaching of toxic chemicals
from former Army training ranges. These would include proposed ground
disturbing activities including a horse park. The Seaside Aquifer lies directly
beneath the Army Training Ranges, known as Site #39 of former Fort Ord.
This area includes the area known as Parker Flats that had, among other
uses, Army tank training areas.
Fort Ord is a National Superfund Site, first put on the National Superfund
Priority List because of discovered contamination of area groundwater.

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September 2015
W-6
W-7
Page 2
There have been multiple issues with the Upper 180, the Lower 180, and the
400-foot aquifers beneath areas of former Fort Ord. Site #39, perhaps the
largest munitions impact/training area in the country, sits over the Seaside
Groundwater Basin. This should be of concern to MRWPCA and others for
the possibility of leaching and migration of chemicals into underground
aquifers.
It is understood residual munitions chemicals from 77-years of munitions
use, remain in Fort Ord training areas, including Site 39. The cleanup thus
far, has concentrated on remaining unexploded munitions, but failed to
identify many munitions constituents even though numerous munitions
chemistry books were and are readily available. How can the extent of
contamination be known unless all known munitions constituents are looked
for? The cleanup has used a sampling rationale of looking for a few
constituents but only reporting levels above a certain threshold. There
potentially are hundreds of chemicals below threshold levels. For example,
hypothetically, if there are two hundred chemicals each at 2 ppm, well below
the reporting level, there potentially could be a toxic chemical brew of 200400 ppm. Could the cumulative, low levels of chemicals potentially be
a health hazard? Are the human health risks known for this level of
exposure? What are the synergistic effects of munitions chemicals and
pesticides on organisms? Are there studies available on the effects of lowlevel exposure to these chemicals?
Hundreds of munitions chemicals and pesticides at very low levels may be a
potential toxic brew creating a health and safety hazard in the underground
water aquifers. The cleanup has failed to make the public aware of the actual
levels of munitions and pesticide contaminates throughout training areas.
a) What might be the justification for the cleanup failing to identify all the
munitions and pesticide chemicals in Tables 3,4,5, and 6? (See Attachment
2, Tables 1-7). The Army BRAC has been asked the following questions:
b) Because the Army kept abysmal records of training ranges, training areas
and specific activities, what is the justification for failing to look for all
munitions chemicals and pesticides in all training areas, including Site #39?
c) What is the justification for the cleanup failing to include all the
munitions and pesticide chemicals identified in Attachment 2, Tables 3,4,5,
and 6?
d) What is the extent of out-gassing from munitions and pesticide chemicals

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W-7
Con't
W-8
W-9a
W-9b
W-9c
W-9d
Page 3
in former training areas?
e) What is the justification for failing to report the actual levels of munitions
and pesticide chemicals in all training areas?
On 3-24-10 (fortordcleanup.com, Document BW-2532), and 2-7-11

(fortordcleanup.com, Document BW-2557), the FOCAG raised questions
regarding pesticide use at Fort Ord and in training areas. The
2-7-11 FOCAG letter specifically addresses Armys failure to thoroughly
investigate pesticides in training areas. Despite Armys claim that it has
thoroughly investigated pesticides in training areas, our review of the cited
cleanup documents did not support the Armys claim. The only sampling
we have found for pesticides in the Parker Flats and Site 39 training areas
was for a total of 4 sample locations that only looked for 8 organochlorine
pesticides.
It is our understanding Army BRAC remains responsible for identifying and
sampling for chemicals potentially used in training areas, including Site 39.
However, the chemicals being looked for in former Army training sites is
woefully inadequate. The FOCAG includes, with this letter, 7 Tables
of munitions chemicals and pesticides potentially found in former Fort Ord
including a list of Training Areas and the chemicals actually being looked
for in. (See attachment 2, Tables 1-7)
There are several hundred chemicals potentially leaching out of ordnance
into the ground as well as residual chemicals from decades of
weapons/ordnance training and pyrotechnics. Herbicides were used to keep
vegetation down and minimize threats of wildfires from munitions training
exercises. Attached are 6 Tables identifying munitions chemicals and
pesticides used in training areas include Table 1, is the Fort Ord Cleanup
1994 list of potential Training Range chemicals. Table 2 is the Fort Ord
Cleanup 2003 Sampling and Analysis list of potential Training Range
chemicals. Tables 3, and 4 are lists of munitions constituents found in
munitions chemistry books, many of which the cleanup has not included in
its list(s). Tables 5, and 6 are lists of pesticides; known and suspected as
being used at Fort Ord. Particularly alarming is Table 5 that identifies 23
munitions chemicals also known to be pesticides. This may explain why
some training areas are virtually devoid of insects and birds. Not only has

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September 2015
W-9e
W-10
W-11
W-12
Page 4
the cleanup thus far failed to identify all munitions chemicals and pesticides;
it has also failed to extensively look for all munitions chemical and
pesticides in all training areas.
The FOCAG is not aware of any Basewide training maps pre-1940. We do
know the entire pre-1940 Fort Ord footprint was the Gigling Artillery Range
1917-1940. It is understood this artillery range primarily trained with 37mm,
75mm, 105mm, and 155mm projectiles. These projectiles are found
throughout most of the pre-1940 footprint. One of the known impact areas
for the pre-1940s 37mm and 75mm projectiles is "Artillery Hill". This area,
OE-50 and OE-53 (Veterans Cemetery and Endowment Parcels), when
sampled and cleared to a depth of 4' discovered significant amounts of
37mm and 75mm fragments and unexploded projectiles. According to the
Archives Search Report and interviews with range control personnel, these
Sites were target areas for rifle grenades and shoulder launched projectiles in
the 1940s, 1950s and 1960s. Other projectiles found include 60mm,
81mm, 3 inch stokes, and 4.2 inch mortars, and Levins projectors. The latter
ground tube launched munitions range(s) was not known prior to the
sampling and removal actions. The FOCAG is unaware of historical
training maps showing the firing points, range fans, or target areas of any of
the ranges within or firing out of Sites OE-50 and OE-53 yet these areas
were obviously extensively used for munitions training.
The proposed Veteran's Cemetery site among other uses was a former 192030s; 37mm and 75mm artillery target range known as Artillery Hill. The
Veteran's site also includes a Chemical, Biological, Radiological, (CBR)
site. Training devices and munitions discovered nearby include non-metallic
landmines and Chemical Agent Identification Sets (CAIS) in glass vials. The
detection equipment used to clear this site is incapable of detecting nonmetallic, and deeply buried munitions. Although the munitions cleanup was
to a depth of 4.0, the 37mm has a maximum detection depth of 0.9 and the
75mm has a maximum detection depth of 2.5. There are other munitions
found onsite that cannot be reliably detected within 4 of the surface.
Again, there have been multiple issues with the Upper-180, the Lower-180,
and the 400-foot aquifers beneath areas of former Fort Ord. Site 39, perhaps
the largest munitions impact/training area in the country, sits over the
Seaside Groundwater Basin. This should be of concern to MRWPCA and

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September 2015
W-12
Con't
W-13
W-14
W-15
Page 5
others for the possibility of leaching chemicals into underground aquifers.
Project Scoping should include:
a) What is the migration and fate of munitions and pesticide chemicals into
this drinking water supply?
b) Where did all the chemicals go?
c) What Fort Ord document fully investigated the potential munitions and
pesticide contamination?
d) Is there ongoing monitoring and reporting of the potential munitions and
pesticide contamination of the Seaside Groundwater Basin? Where is it?
e) What might construction, development, and irrigating in the area above
the Seaside Groundwater Basin do for migrating chemicals?
Thank you for the opportunity to comment on this NOP/Scoping for the
EIR for the proposed Monterey Peninsula Groundwater Replenishment
Supply.
Respectfully,
Mike Weaver
Co-Chair, FOCAG
Attachment #1
Reference the following link:
http://fortordcleanup.com/adminrec/ar_pdfs/AR-ESCA-0100/ESCA0100.PDF
This link is regarding Site 39. August 12, 2008, Fort Ord Community
Advisory Group Position Paper
80-pages of research, statistics, commentary, analysis, and questions.
Attachment #2
(Reference the attachment to this letter sent via email. Hard copy to follow.)
Tables 1-7 (34 pages total)
Fort Ord known and suspected Munitions and Pesticide Chemicals used in
Training Areas

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September 2015
W-15
Con't
W-15a
W-15b
W-15c
W-15d
W-15e
LetterW: FortOrdCommunityAdvisoryGroup
W-1
Historical activities, hazardous materials, environmental investigations, and cleanup activities

associated with the Fort Ord lands were documented and evaluated in Sections 4.9 and 4.10,
and Appendix L in the Draft EIR. In addition to the review and summary of numerous
environmental documents at the site, as discussed in Appendix L, MRWPCA conducted a field
investigation program in the Seaside Basin to specifically evaluate the potential for leaching
Fort Ord legacy chemicals in soil or having the injection wells impact existing soil or
groundwater contamination (or having these contaminants adversely impact Proposed Project
injection water). The focus was on areas related to the Proposed Project and how the Proposed
Project facilities might be impacted from former Fort Ord activities. See Master Response #9:
Fort Ord Environmental Issues at the Injection Well Facilities, in Chapter 3, Master Response
Comments, for more information.
W-2
Site 39 (also known as the Inland Ranges) boundaries are shown on a map in the Recharge
Impacts Assessment Report (see Figure 4, Appendix L in the Draft EIR). The site of the
Proposed Project Injection Well Facilities overlaps a portion of the northwestern corner of Site
39 (see injection well locations on Figure 4, Appendix L). As discussed in the Draft EIR (page
4.10-16), the Proposed Project wells are located in the Northern Inland Subarea of the Seaside
Groundwater Basin (Figures 1 and 2, Appendix L). Site 39 overlies most of the Northern Inland
Subarea, the western half of the Laguna Seca Subarea, and extends to the northwest outside
of the Seaside Groundwater Basin (compare Figures 1 and 4, Appendix L, Draft EIR). See
Master Response #9: Fort Ord Environmental Issues at the Injection Well Facilities in Chapter
3, Master Responses to Comments for more information on Site 39 and former Fort Ord
lands.
W-3
The history of chemical use on Fort Ord can be obtained in documents available from the U.S.
Armys web site (see U.S. Army, 2015, Fort Ord Cleanup). Chemical usage locations and
remedial activities on the Fort Ord Superfund (also known as the Comprehensive
Environmental Restoration and Environmental Liability Act or CERCLA) site are documented in
the five-year review reports (see U.S Army Corp of Engineers, 2007 and 2012).
As described in the Draft EIR (pages 13-14, Appendix L), military activities in and adjacent to
the Proposed Project Injection Well Facilities site involve firing ranges that were used for small
arms and high explosive ordnance training using rockets, artillery, mortars and grenades.
These activities were not associated with large volumes of chemicals as were other operations
elsewhere on the Fort Ord lands. The Injection Well Facilities site is located along a perimeter
road adjacent to but not within the Inland Firing Ranges HA-18 and HA-19, which were used for
small arms fire. Range 18 (HA-18) and Range 19 (HA-19) are the closest ranges to the
Proposed Project (approximately 200 feet south and east), with Range 48 (HA-48) located
farther east (See Figure 4, Appendix L).
A hydrogeologic investigation and field program was conducted in 2014 by Todd Groundwater
in connection with the Proposed Project. Results of that program indicated that chemical use on
former Fort Ord lands has not significantly impacted soil or groundwater in the vicinity of the
Proposed Project Injection Well Facilities site (pages 65-67 and 72-77, Appendix L of the Draft
EIR). See Master Response #9: Fort Ord Environmental Issues at the Injection Well Facilities,
in Chapter 3, Master Responses to Comments, for more information on this issue.
W-4
As described in Section 4.9 and Appendix L in the Draft EIR, the Proposed Project Injection
Well Facilities are located on the northwestern portion of Site 39 where remediation has been
completed for development. The property has been transferred to the Fort Ord Redevelopment
Authority (FORA) and is scheduled to be annexed into the City of Seaside (See also reply to
comment W-15e). In addition, results of a hydrogeologic field program indicated that soil and

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September 2015
groundwater in the vicinity of the Proposed Project has not been adversely impacted (pages
65-77, Appendix L, of the Draft EIR). Development associated with the Proposed Project
involves only the installation and operation of injection wells and facilities. Given the lack of
chemical use in the area, the status of the remediation, the results of the field investigation, and
the relatively small amount of disturbance associated with the project, the Draft EIR (page 4.1070 through 4.10-75) found that development of the Proposed Project would not have a
significant impact related to exposure of the public to unacceptable risks due to contamination
at the former Fort Ord. See Master Response #9: Fort Ord Environmental Issues at the
Injection Well Facilities, in Chapter 3, Master Responses to Comments, for additional
information on this issue.
W-5
As described in Sections 4.9 and 4.10, and Appendix L in the Draft EIR, there is no evidence of
soil and or groundwater contamination associated with Fort Ord chemicals of concern in the
area of the Injection Well Facilities of the Proposed Project. See Master Response #9: Fort Ord
Environmental Issues at the Injection Well Facilities, in Chapter 3, Master Responses to
Comments, for additional information on this issue.
W-6
The Draft EIR identifies water quality standards, including drinking water standards, as the
primary criteria for the significance determination of an impact to water quality (page 4.10-45 of
the Draft EIR). Using these criteria, groundwater quality data were evaluated using existing
data and Proposed Project-derived data from the MRWPCA field program (Todd Groundwater,
2015; summarized in Appendix L of the Draft EIR, see pages 57-77; see also Appendix D in the
Draft EIR Appendix L). In particular, the field program evaluated the potential for impacts to
drinking water due to leaching and/or migration of toxic chemicals from former Army training
ranges in the Proposed Project area; no evidence of leaching and/or migration of chemicals
associated with former Fort Ord activities was found. For more detail on this issue, see Master
Response #9: Fort Ord Environmental Issues at the Injection Well Facilities, in Chapter 3,
Master Responses to Comments. Regarding the specific request to include proposed ground
disturbing activities at a horse park in an Army training area known as Parker Flats, the
proposed Monterey Horse Park within the Parker Flats Munitions Response Area (MRA) is
outside of the Seaside Groundwater Basin. Most of the Parker Flats MRA is also outside of the
Seaside Groundwater Basin (The Parker Flats MRA is shown on numerous FORA documents
for example see Arcadis, et al., 2015). Any activities in these areas outside of the basin would
not impact the Proposed Project Injection Well Facilities site, and groundwater conditions in
those areas would not be impacted by the Proposed Projects injection well operations.
W-7
As described in Section 4.9 and Appendix L in the Draft EIR, the groundwater contamination
areas associated with the Fort Ord Superfund site are located within the Salinas Valley
Groundwater Basin several miles north of the Proposed Project Injection Well Facilities site.
Although this Proposed Project area overlaps a small portion of the Site 39, there have not
been documented groundwater plumes associated with the former Fort Ord activities in the
area of proposed injection wells, nor in any part of the Seaside Groundwater Basin. Further,
groundwater samples do not indicate that groundwater in the vicinity of the Proposed Project
has been impacted by former Fort Ord activities. See Master Response #9: Fort Ord
Environmental Issues at the Injection Well Facilities, in Chapter 3, Master Responses to
Comments, for more detailed information regarding these issues.
W-8
See Master Response #9: Fort Ord Environmental Issues at the Injection Well Facilities in
Chapter 3, Master Responses to Comments, for a discussion of this issue. The Draft EIR
identified water quality standards, including drinking water standards, as the primary criteria for
the significance determination of an impact to water quality (page 4.10-45 of the Draft EIR).
Using these criteria, groundwater quality data were evaluated using existing data and Proposed
Project-derived data from the MRWPCA field program (Todd Groundwater, 2015; summarized
in Appendix L of the Draft EIR, see pages 57-77; see also Appendix D in the Draft EIR
Appendix L). In particular, the field program evaluated the potential for impacts to drinking
water due to leaching and/or migration of toxic chemicals from former Army training ranges; no

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evidence of leaching or migration of chemicals associated with former Fort Ord activities was
found in existing data including data from the field program that analyzed groundwater samples
for over 300 constituents and parameters. See Master Response #9: Fort Ord Environmental
Issues at the Injection Well Facilities, in for more information.
W-9a
Documents and data regarding onsite activities and environmental investigations on Site 39
dating back to 1994 were reviewed as part of the hydrogeologic study for the Proposed Project.
A Proposed Project-specific field program, including soil and groundwater sampling, indicate
that there are no adverse impacts to soil and groundwater in the vicinity of the Injection Well
Facilities site from these activities. On-going contaminant investigations are being conducted in
other areas of Site 39 by the U.S. Army BRAC (2014) and FORA with EPA (2015) oversight.
See the responses to comments W-1 through W-8 and Master Response #9: Fort Ord
Environmental Issues at the Injection Well Facilities in Chapter 3, Master Responses to
Comments for more information on these issues.
W-9b
As described in Sections 4.9 and 4.10, and Appendix L in the Draft EIR, as part of the
Proposed Project, a field program was conducted that included groundwater sampling on and
in the vicinity of Site 39 in wells near the Injection Well Facilities site. Samples were analyzed
for more than 300 separate constituents including EPA-approved analytical methods for
munitions, explosives, and pesticides (among other analyses). See Master Response #9: Fort
Ord Environmental Issues at the Injection Well Facilities in Chapter 3, Master Responses to
Comments, for more detailed information on this issue.
W-9c
See response to Comment W-9a and W-9b. Also See Master Response #9: Fort Ord
Environmental Issues at the Injection Well Facilities in Chapter 3, Master Responses to
Comments, for additional information on this issue.
W-9d
The issue of soil gas or soil vapor migration and the potential of soil gas exposure at Fort Ord
has been addressed for Operable Units (OUs) outside of the Proposed Project Injection Well
Facilities site, but has been limited to VOCs (U.S Army, 2011b). If present, pesticides can be
degraded by physical (e.g., volatilization or outgassing), chemical, and biological mechanisms.
Pesticide transformations also occur including oxidation, hydrolysis, reduction, hydration,
conjunction, isomerization, and cyclization (Coats, 1991). These occur over certain time periods
dependent on the particular pesticide chemical characteristics. Importantly, the Proposed
Project Injection Well Facilities site is located along a perimeter road outside of the primary
ranges associated with pesticide applications. As described in Sections 4.9 and 4.10 and
Appendix L in the Draft EIR, pesticides were not detected in groundwater near the Proposed
Project site, and it follows that volatilization would not occur in the vicinity of the Injection Well
Facilities site. See Master Response #9: Fort Ord Environmental Issues at the Injection Well
Facilities in Chapter 3, Master Responses to Comments, for additional information.
W-9e
It is beyond the scope of the Draft EIR to provide detailed justification for the analytical methods
employed in the remediation of the Fort Ord lands, including Site 39. Rather, soil and
groundwater were investigated in the vicinity of the Proposed Project injection well locations to
test for legacy contaminants from Fort Ord activities (see pages 57-77 in Appendix L of the
Draft EIR). These results did not indicate that local soil or groundwater had been impacted. See
3, Master Responses to Comments, for additional information.
W-10
For the Proposed Project, groundwater from six groundwater monitoring and production wells in
the Seaside Groundwater Basin were analyzed for 37 individual chlorinated pesticides and
PCB using EPA Method 508 (see Table D-1D in Appendix L of the Draft EIR). None of these
constituents were detected above method detection limits or above MCLs for the chemical
constituents that have established MCLs. Additionally, 12 nitrogen and phosphorous pesticides

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were analyzed using EPA Method 507 (Table D-1E in Appendix L of the Draft EIR). None of the
pesticides were detected above method detection limits or established MCLs. See Master
Response #9: Fort Ord Environmental Issues at the Injection Well Facilities in Chapter 3,
Master Responses to Comments, for additional information.
W-11
The U.S. Army (BRAC) and FORA continue to investigate the Fort Ord Superfund site,
including Site 39 (Fort Ord BRAC Office, 2014). On-going investigations also are continuing
with EPA (2015d) oversight. Munitions (explosive) chemicals, chlorinated (organochlorine)
pesticides/PCBs, and nitrogen and phosphorous pesticides were investigated using approved
EPA Methods and reported in Todd Groundwater (2015) as summarized in Appendix L of the
Draft EIR (also see Appendix D within Draft EIR Appendix L). All reported constituents for
groundwater samples collected in the six groundwater and production wells within the Seaside
Groundwater basin were below method reporting limits and below California MCLs for those
chemicals with established MCLs. See Master Response #9: Fort Ord Environmental Issues at
the Injection Well Facilities in Chapter 3, Master Responses to Comments, for more
information on these issues.
W-12
As described in Section 4.9, Section 4.10, and Appendix L in the Draft EIR, a hydrogeologic
investigation and field program were conducted as part of the Proposed Project to examine the
potential for chemical impacts from Fort Ord activities in the vicinity of Proposed Project wells.
As part of that program, groundwater wells surrounding the Proposed Project area of the
Seaside Groundwater Basin were sampled and analyzed for about 300 separate constituents
and parameters, including many of the constituents in the tables provided as part of this and
other comments from letter W. The Draft EIR analysis focused on the constituents most likely to
be associated with the Proposed Project area including pesticides and explosives.
Groundwater was analyzed for pesticides and PCBs using EPA Method 508 and for explosive
compounds (nitroaeomatics and nitramines) using EPA Method 8330B. None of these
pesticides and PCBs or nitroaromatics and nitramines were detected above minimum reporting
limits (MRL) and all levels were below California Primary MCLs for those constituents with
established MCLs. The analytical data indicate that migration of pesticides and explosive
chemicals to groundwater has not occurred within the Proposed Project area. See Master
Master Responses to Comments, for more information.
W-13
Artillery Hill (at 36.6360704o North Latitude and -121.7902279o West Longitude) is adjacent to
and west of the main Parker Flats area, but within the Parker Flats MRA, most of which resides
outside of the Seaside Groundwater Basin. Artillery Hill and the proposed Veterans Cemetery
are also located outside of the Seaside Groundwater Basin and therefore not in the vicinity of
the Proposed Project area. These areas do not require evaluation as part of the hydrogeologic
studies of the Proposed Project. A Record of Decision (ROD) for the Parker Flats MRA was
issued in June 2008 (U.S. Army, 2008), indicating that the area has been investigated and
remedial actions, if any, have been defined. See Master Response #9: Fort Ord Environmental
Issues at the Injection Well Facilities in Chapter 3, Master Responses to Comments, for
more information.
W-14
The Veterans Cemetery site is not in the vicinity of the Injection Well Facilities site; rather, it is
located north of the Proposed Project area in the Parker Flats MRA, most of which resides
outside of the Seaside Groundwater Basin. FORA and Fort Ord BRAC (2014) documents
indicate that, for the Veterans Cemetery, either the field investigation has been completed
and/or a ROD has been signed (see also response to Comment W-13 above). See Master
Master Responses to Comments, for additional information.
W-15
Documented groundwater impacts from former Fort Ord activities have been delineated in
operable units several miles north of the Proposed Project Injection Well Facilities site in the

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Seaside Groundwater Basin; the Proposed Project will have no impact on those areas. As
described in Todd Groundwater (2015), which is summarized in Appendix L of the Draft EIR,
the investigation included analysis of groundwater from six groundwater monitoring and
production wells in the Seaside Basin (also see Appendix D within Draft EIR Appendix L).
Groundwater analyses conducted in the vicinity of the Proposed Project do not indicate local
impacts to groundwater from this area of Site 39. Monitoring wells will be constructed as part of
the Proposed Project and will provide ongoing monitoring for the Proposed Project wells. See
3, Master Responses to Comments, for more information on this issue.
W-15a
As described in Sections 4.9 and 4.10, and Appendix L in the Draft EIR, groundwater sampling
was conducted in wells surrounding the location of Proposed Project wells to characterize
groundwater quality. Samples were specifically analyzed for constituents of concern associated
with former Fort Ord activities in the Proposed Project area, including pesticides and
explosives. None of the analyzed pesticides, PCBs, VOCs, semi-VOCs or nitroaromatic and
nitramines (explosive chemicals or munitions) were above minimum reporting and/or detection
limits/levels (RL/MDL) and were below California Primary MCLs for those constituents that have
established MCLs. The analytical data indicate that groundwater beneath the Proposed Project
area has not been impacted by any potential migration of former Fort Ord chemicals to
groundwater. See Master Response #9: Fort Ord Environmental Issues at the Injection Well
Facilities in Chapter 3, Master Responses to Comments, for more information on this issue.
W-15b
As described in Sections 4.9 and 4.10, and Appendix L in the Draft EIR, groundwater sampling
associated with the Proposed Project-specific field investigation did not find pesticide and
explosive compounds to have impacted groundwater in the Proposed Project area of the
Seaside Groundwater Basin. See Master Response #9: Fort Ord Environmental Issues at the
Injection Well Facilities in Chapter 3, Master Responses to Comments, for more information
on this issue.
W-15c
See responses to Comments W-9a, W-11, and Master Response #9: Fort Ord Environmental
additional information.
W-15d
We are unaware of any ongoing monitoring of chemicals associated with munitions in the
Proposed Project area of the Seaside Basin. As described in Section 4.9 and Appendix L in the
Draft EIR, MRWPCA installed a monitoring well on Site 39 adjacent to proposed locations of
Proposed Project wells in order to evaluate the potential for Fort Ord impacts to soil and
groundwater, and conducted groundwater sampling for munitions and pesticides in wells
surrounding the Injection Well Facilities site (Todd Groundwater, 2015). Water supply wells in
the basin are required to monitor groundwater for constituents with drinking water standards in
compliance with state and federal regulations, including pesticides. In addition, the Monterey
Peninsula Water Management District (MPWMD), with support from the Seaside Basin
Watermaster, conducts a basin-wide groundwater monitoring program including the ASR wells,
two of which are located within about 1,000 feet of the Proposed Project site. Finally, a
groundwater monitoring program will be established in the Proposed Project area to monitor the
ongoing operation of the Proposed Project. See Master Response #9: Fort Ord Environmental
more information on this issue.

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W-15e
As described in Section 4.9 and Appendix L in the Draft EIR, based on results of the
hydrogeologic investigation and field program associated with the Proposed Project, there is no
indication that chemicals associated with the former Fort Ord activities have contaminated the
Proposed Project area and therefore, such chemicals would not impact construction or
operation of the Proposed Project. See Master Response #9: Fort Ord Environmental Issues at
the Injection Well Facilities in Chapter 3, Master Responses to Comments, for additional
information.

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Letter X
P.O. Box 269
Monterey, CA 93942
831/663-9460
June 5, 2015
Administrative Office
5 Harris Ct. Bldg. D
Monterey, CA 93940
Re: Pure Water Monterey DEIR
Dear Mr. Holden and Pure Water Team:
Thank you for the opportunity to comment on the Pure Water Monterey Draft Environmental
Impact Report. The following comments are made on behalf of The Otter Project, our water
quality program Monterey Coastkeeper, our ~3000 members, and our board of directors.
The Otter Project supports the proposed project with modifications to remove nutrients from
all product waters (both GWR and CSIP) and from the ocean disposal waste stream.
X-1
The Otter Project exists to protect our watersheds and coastal oceans for the benefit of
California sea otters and humans through science-based policy and advocacy. California sea
otters are listed as threatened under the Endangered Species Act. The primary threats to sea
otters include contact with oil, loss of high quality habitat, fisheries interactions, and poor
water quality.
Sea otters specifically sea otters in Monterey Bay are impacted by a variety water quality
challenges.
x Legacy DDT. Lower Salinas Valley soils contain extremely high levels of DDT and
while this DDT is bound to soil particles, it is water that moves that DDT into
Monterey Bays nearshore environment where it is becomes available to sea
otters. The high DDT concentrations in Salinas Valley soils some of the highest
ever documented are documented in a 1986 report to the State Water
Resources Control Board, DDT in the Salinas Valley.
http://www.waterboards.ca.gov/publications_forms/publications/general/docs/
ddt_salinas_valley.pdf . Sea otters, feeding in the nearshore, bioaccumulate DDT
(and the breakdown product DDE), and the documented concentrations found in
Monterey Bay sea otter liver tissues are high enough to kill sea otters outright (in
extreme cases) or cause immune suppression. Kannan et. al. 2004.
http://www.otterproject.org/wpcontent/uploads/2012/05/Kannan_etal_2004_Profiles_of_polychlorinated_biph
enal_congeners_organochloride_pesticides.pdf .
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X-2
General Comment #1: While we do not believe the proposed project necessarily increases the
risk to sea otters from DDT exposure, we appreciate proposed project efforts to minimize soil
disturbance activities during project construction and to stabilize soils post-construction and
before the rainy season in the DDT-laden agricultural areas of the lower Salinas Valley.
x
Nitrates. Nitrate pollution is of critical concern to sea otters. Nutrient enriched

surface waters cause freshwater toxic blooms of the cyanobacteria Microcystis;
the microcystin toxin is flushed downstream into the nearshore, concentrated by
shellfish, eaten by otters, and ultimately leading to microcystin poisoning and
death of the otter. Miller et. al. 2010.
http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0012576 .
X-3
Sea otters also die from exposure to domoic acid poisoning caused by nutrient
enrichment and bloom of the marine toxic algae (actually a diatom) Pseudonitchia. Domoic acid poisoning kills many sea otters, scores of whales and
dolphins, hundreds of sea lions, and thousands of marine birds. The red tide
event in Monterey Bay at the moment of this writing is a bloom of Pseudonitchia. Dr. Clarissa Anderson, Post-Doctoral Sea Grant Fellow at U.C. Santa Cruz
has been studying toxic algal blooms along the California coast and gave this
quote to Sea Grant Bulletin, We have seen a 30- to 100-fold increase in domoic
acid in water samples in the last decade or so. We think that the toxicity of these
blooms is related to agricultural runoff. (An overview of the issue including
impacts on marine mammals and birds can be found in the nine-minute news
report found at https://vimeo.com/104728711).
General Comment #2: We believe nutrients, specifically nitrogen, must be removed from
source waters and product waters must meet drinking water, or better, standards before
discharge as groundwater replenishment or recycled agricultural water. Further, we believe
the project and ocean outfall will certainly need NPDES re-permitting and the permit should
reduce the annual load over what is currently permitted. In short, the project and PCA
general operations -- should remove as much nitrogen as feasible from all product and waste
streams.
X-4
X-5
Specific Comments
BT-2. Sensitive Habitats. The impact mitigation proposes a 1:1 replacement for sensitive
habitat loss. Wetland loss in the project area has been especially severe and we propose at
least a 2:1 mitigation. Further, the project should be responsible for ensuring any plantings and
revegetation survives for three years after project completion.
GW-3. Groundwater Depletion. Increased deliveries of recycled water will increase the size of
the Castroville Seawater Intrusion Project (CSIP) service area. It is well documented that sea
water intrusion is the consequence of groundwater pumping and the Salinas groundwater basin
is critically over-drafted. The over-draft of the basin was first noted in the late-1930s and the
predecessor agency of the Monterey County Water Resources Agency was created to address
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X-6
X-7
the issue, yet 75 years later sea water intrusion still progresses inland. Water supply projects
have served to grow the number of irrigated agriculture acres and have exacerbated the
intrusion problem instead of solving it. There is no evidence or commitment to suggest this
project will be any different.
The Salinas Valley Water Project (SVWP), including the rubber dam on the Salinas River near
Marina was intended to impound water to use as blend for the recycled water coming from the
PCA and the product water was to replace well water in the service area. Due to the prolonged
drought in 2014 and 2015, Salinas River Water was not available and many of the MCWRA and
agricultural supply wells were restarted. As a consequence, first-strike water in the
Castroville area fell from 8-feet to over 100, threatening drinking water supplies. The frequency
and severity of drought events is forecast to increase and enlarging the CSIP service area will
only enlarge the scope of the problem.
It is our understanding that in Santa Cruz County recycled water is delivered only to agricultural
customers willing to abandon and destroy their wells; a similar agreement should be required in
Monterey County and must be in place before any recycled water is provided. It is incorrect to
assume and state the project will have no or beneficial impact.
GW-5. Groundwater quality. General comment #2 is repeated here in full. Current and ongoing research shows that growers who practice precise nutrient balancing (accounting for
nutrients in irrigation water and soils) can reduce the amount of fertilizer they apply and
actually improve water quality, many (perhaps most) do not. The result is that nutrient
concentration literally compounds itself: Nutrients already in the water are not accounted for,
more nutrients are added, and the nutrient impairment becomes worse.
The impaired water will impact both surface and ground waters. While we understand the
lower Salinas below Chualar is generally considered to be not a groundwater recharge zone, we
believe that characterization is an over-generalization. Certainly, shallow groundwater is often
impacted by surface irrigation.
As stated in General comment #2, we believe nutrients (specifically nitrates and nitrogen
sources) must be removed. It is our understanding that technologies exist to remove the
nitrates and create a saleable fertilizer product. We certainly understand that the fertilizer
product may be applied, but it will be re-applied in an accounted for, measured, and monetized
way (the product will have a cost and will therefore be applied more efficiently).
HS-4 and HS-5. Marine water quality. General comment #2 and comment GW-3 are repeated
here in full. The DEIR seems to suggest that the net amount of nutrient discharge will be
unchanged or the nutrient load will be the same, only it will be discharged through the PCAs
outfall. The reality is that sea water intrusion will lead in the not too distant future to the idling
of some agricultural lands. This project will enlarge the CSIP service area and result in
prolonged and exacerbated nutrient discharges into Monterey Bay.

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X-7
Con't
X-8
X-9
X-10
X-11
X-12
X-13
We believe these critical agricultural areas should be kept in production. Product water
delivered to CSIP should have nutrients removed and the removed nutrients should not be part
of the effluent stream and left to impact ocean water quality.
X-14
MR-1. General comment #2 and comment GW-3 are repeated here in full. As stated in General
comment #2, discharged nutrients trigger toxic blooms that impact ESA listed sea otters and
other (some ESA and State listed) marine birds and mammals. If the proposed project were to
choose to not remove nutrients, a Section 7 consultation under the Endangered Species Act
would be required.
X-15
In conclusion
The Otter Project supports the proposed project with modifications to remove nutrients from
all product waters (both GWR and CSIP) and from the ocean disposal waste stream.
The mission statements of the critical project partners are stated as:
x Monterey Peninsula Water Management District: To manage, augment, and
protect water resources for the benefit of the community and the environment.
x Monterey Regional Water Pollution Control Agency: Is dedicated to meeting the
wastewater and reclamation needs of our member agencies while protecting the
environment.
x Monterey County Water Resources Agency: Manages, Protects, and Enhances
the Quantity and Quality of Water and Provides Specified Flood Control Services
for Present and Future Generations of Monterey County.
X-16
X-17
Nutrient pollution of Monterey Countys ground and surface waters are critically impaired.
Simply redistributing the pollution from one area to another is inconsistent with the stated
missions of the partner agencies and inconsistent with the goals of this project. Waste and
fertilizer laden source waters will be carried to the very water treatment facility where the
pollution problem can be solved and it would be an abuse of this special opportunity to not
deal with this countys this States -- nutrient pollution problem.
We urge the partner agencies to remove nutrients to at least drinking water standards from
all source waters and ocean outfall waste streams.
Please, feel free to contact me if you have questions or require clarifications.
Sincerely,
Steve Shimek
Executive Director
exec@otterproject.org
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X-18
LetterX: TheOtterProject
X-1
See the responses to comments X-3 through X-18 and Master Response #6: Nutrients in
Recycled Water and Ocean Discharge in Chapter 3, Master Responses to Comments.
X-2
Information about the Otter Projects mission and general threats to sea otters is provided in
this comment. No response is necessary.
X-3
The comment acknowledges that the Proposed Project would not increase the risk to sea otters
from DDT exposure and requests that the Proposed Project minimize soil disturbance during
construction and to stabilize soils post-construction and before the rainy season in the lower
Salinas Valley. The Draft EIR describes the existing regulatory requirements for construction
activities on pages 4.11-32 through 4.11-44. The Draft EIR provides an analysis of potential
construction impacts to surface water quality due to earthmoving / soil disturbance on pages
4.11-61 through 4.11-62. Specifically, all Proposed Project components would be subject to the
requirements National Pollutant Discharge Elimination System Construction General Permit
and Municipal Stormwater Permits (where applicable). The above pages of the Draft EIR detail
the regulatory requirements that would be implemented at all construction sites to prevent
significant water quality impacts from occurring due to soil disturbance.
X-4
This comment states an opinion that nutrients, specifically, nitrogen, must be removed from
source waters and that product waters must meet drinking water, or better, standards before
use for groundwater replenishment or for agricultural irrigation. This response addresses the
two product waters referenced in this comment separately as they are proposed to be produced
using two different treatment systems (see Figure 2-28 on page 2-125 and Figure 2-29 on page
2-126 of the Draft EIR for the relevant treatment flow diagrams).
Nutrient/Nitrogen in Water Produced for Groundwater Replenishment. As described in Chapter
3 of the Draft EIR (see specifically second bullet on page 3-5), the Proposed Project purified
recycled water (specifically, the AWT Facility product water produced through the treatment
system in Figure 2-28) would meet groundwater quality standards in the Water Quality Control
Plan (or Basin Plan) implemented by the Central Coast Regional Water Quality Control Board
and would meet drinking water quality standards. A monitoring program would document
project performance as required by the SWRCB Division of Drinking Water in the Groundwater
Replenishment Regulations. As documented in detail in Appendix D on page 57 and Appendix
L of the Draft EIR on page 75 in Section 7.4.2, ambient groundwater concentrations of nitrate
and chloride generally meet Basin Plan objectives. As documented in Appendix L, the study
that evaluated the water quality of the stabilized RO pilot water found that the concentrations of
TDS, nitrate, and chloride in the purified recycled water meet all Basin Plan objectives. Further,
these concentrations are generally lower than average concentrations in groundwater. As such,
replenishment of the Seaside Basin using the GWR Project purified water would not adversely
impact nutrient loading in the basin and would provide benefits to local groundwater quality
related to nitrogen.
Nutrient/Nitrogen Tertiary Treated Recycled Water for Crop Irrigation. Regarding the quality of
the recycled water produced by the Salinas Valley Reclamation Plant (SVRP) (Figure 2-29), the
Draft EIR Chapter 3, Water Quality Statutory and Regulatory Compliance Overview (page 3-1)
states: The recycled water produced by MRWPCA for crop irrigation is treated to a tertiary
level in accordance with the statutory and regulatory requirements of the California Water Code
Sections 13500 13577 and California Code of Regulations, Title 22, Sections 60301
60357. Master Response #6: Nutrients in Recycled Water and Ocean Outfall Discharges in
Chapter 3, Master Responses to Comments describes how the existing recycled water use
for crop irrigation (i.e., use of tertiarytreated recycled water within the CSIP area) has reduced
the use of fertilizers in that area due to the dissolved nitrogen content of the recycled water and

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the efficiency of root uptake of that nitrogen by plants. The farmers that use recycled water
desire to reduce their fertilizer use as much as possible due to the high costs associated with
purchasing and applying it to their land. For that reason, increased nitrogen and nitrate in
recycled water for crop irrigation is a benefit to growers; removal would be an inefficient use of
resources.
X-5
See Master Response #6: Nutrients in Recycled Water and Ocean Outfall Discharges in
Chapter 3, Master Responses to Comments in the section titled: Ocean Discharges of
Nitrogen and Phosphorous. This response describes how the Proposed Project would result in
a quantifiable beneficial impact related to the total pollutant load to the ocean. Specifically, the
Proposed Project would divert, treat, and reuse large volumes of the impaired surface waters
and agricultural wash water, while also substantially reducing municipal wastewater disposal
and ocean pollutant loading through increased use of the existing unused municipal wastewater
year-round. The total nitrogen pollutant loading on the ocean would be substantially reduced
compared to the existing and future background conditions.
X-6
The language of Mitigation Measure BT-2a on page 4.5-92 of the Draft EIR has been revised to
require no less than 2:1 replacement for permanent sensitive habitat loss and the requirement
to receive regulatory approval from the entity issuing the Coastal Development permit, amongst
other regulatory agencies. As requested, mitigation measure BT-2 has been amended to
require that the Proposed Project provide for monitoring and replacement of all planting and
revegetation for three years following construction completion. See changes to pages 4.5-92
through 4.5-93 of the Draft EIR in Chapter 5, Changes to the Draft EIR. See also Master
Response #4: Reduction of Surface Water Flows in Chapter 3, Master Responses to
Comments.
X-7
The comment states that increased deliveries of recycled water will result in expansion of the
CSIP service area, encouraging additional irrigated acreage. The expansion of the CSIP
service area is not included in the Proposed Project. On the following pages of the Draft EIR
this is explicitly stated:
Page 2-2, 1st sentence: The Proposed Groundwater Replenishment Project (GWR
Project or Proposed Project) consists of an enhanced agricultural irrigation (Crop
Irrigation) component that would increase the amount of recycled water available to the
existing Castroville Seawater Intrusion Project (CSIP) agricultural irrigation system in
northern Monterey County.. Emphasis added.
Page 2-65, 1st full paragraph, last two sentences related to the Salinas Valley
Reclamation Plant Modification: All of the modifications would occur within the existing
Salinas Valley Reclamation Plant footprint. This component is expected to facilitate the
delivery of up to 1,283 AFY of additional recycled water to the CSIP area. Emphasis
added. This reference is to the existing CSIP area, not another land area.
The Draft EIR Project Description does not contain any language that states or infers that the
CSIP area would be expanded, enlarged, or otherwise changed to provide more irrigated acres.
Modifications to the SVRP are proposed to allow the production of and delivery of recycled
water to CSIP at low flow rates. The SVRP was designed to treat up to 29 million gallons per
day (mgd), and requires a minimum flow of 5 mgd to operate. When CSIP system-wide
irrigation demands are less than 5 mgd, they are currently met using primarily groundwater
wells. Modifying the plant to allow recycled water production at lower flow rates will reduce the
use of groundwater to meet existing irrigation demands in the CSIP area. SVRP peak
production is currently limited by the volume of treated municipal wastewater available as
influent. Currently, when irrigation demands exceed the available volumes of recycled water
and Salinas River water, the remaining demand is met using groundwater. Providing additional
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inflows to the SVRP will also reduce the use of groundwater within the existing CSIP area
during peak demand periods.
X-8
The comment states that increased use of groundwater within the CSIP service area during the
drought has drawn down the water table, and expanding the CSIP service area will increase
the impact of drought pumping on the aquifer. The comment draws several incorrect
conclusions. First, the current CSIP service area is approximately 12,000 acres, while the total
irrigated area in northern Monterey County is approximately 64,000 acres (MCWRA 2013
Groundwater Summary Report, sum of reported acreage planted in berries, grapes and
vegetables, Pressure and East Side subareas). During 2014 and 2015, groundwater use from
the Salinas Valley groundwater basin has increased in all irrigated areas, therefore the CSIP
area would account for, at most, 20% of the impact. Note that the Salinas River Diversion
Facility (SRDF) was only recently completed, and started operation in 2010. Groundwater
pumping within CSIP in 2014, the first year without the SRDF, was 6,500 AF, which is less than
the peak CSIP groundwater use of 8,600 AF in 2009, before the SRDF was completed.
Second, the comment assumes that expansion of the CSIP would be into currently nonirrigated areas, increasing the total farmed acreage. If CSIP is expanded, all or most of the
added area would be converted from groundwater irrigation to recycled water irrigation, just as
the current CSIP service area was. This would decrease the annual usage of groundwater,
allowing the aquifers some recovery. However, expansion of the CSIP area is outside the
scope of the Proposed Project.
X-9
The agricultural land within the CSIP area receives irrigation water from the following sources:
Salinas Valley Reclamation Plant, the SRDF, supplemental wells within the CSIP area that are
operated by the MRWPCA, and some privately owned wells. Monterey County adopted
ordinance 3790 that requires well destruction, however, the ordinance has not resulted in well
destructions throughout the CSIP area and certain exemptions would apply when it is enforced
(Bob Holden, personal communication, August 2015). The Pajaro Valley Water Management
Agencys recycled water system (the only recycled water system in Santa Cruz County serving
agricultural land) also uses supplemental wells within their irrigation area, and private
landowners also operate wells within the area (Brian Lockwood, Pajaro Valley Water
Management Agency, personal communication, August 31, 2015). The Proposed Project does
not include expansion of the CSIP irrigation area. The Proposed Project would not trigger the
need to reach agreements with landowners to abandon their wells, because the Proposed
Project would only augment the amount of recycled water deliveries throughout the year. These
new quantities of recycled water would not only enable MRWPCA and MCWRA to reduce their
use of supplemental wells that they control, but would also potentially reduce, not increase, the
use of private wells within the CSIP area. The Proposed Project additional recycled water
supplies for agricultural irrigation will reduce the use of groundwater within the CSIP area and
thus would have a less-than-significant impact on groundwater levels and storage in the
Salinas Valley Groundwater Basin as documented in detail in the Draft EIR on pages 4.10-57
through 4.10-64.
X-10
See Master Response #6: Nutrients in Recycled Water and Ocean Discharges in Chapter 3,
Master Responses to Comments. In particular, see section 3.6.4, CSIP Additional Use of
Tertiary Treated Recycled Water Containing Nitrogen and Phosphorous that addresses this
comment. See also responses to comments X-4 and X-5.
X-11

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X-12
X-13
Master Responses to Comments. In particular, see section 3.6.3, Ocean Discharges of
Nitrogen and Phosphorous that addresses this comment. See also responses to comments X4, X-5, X-7, X-8, and X-9.
X-14
Master Responses to Comments. In particular, see section 3.6.3,
Ocean Discharges of
Nitrogen and Phosphorous that addresses this comment. See also responses to comments X4, X-5, X-7, X-8, and X-9.
X-15
X-16
Master Responses to Comments and responses to comments X-3 through X-9.
X-17
X-18

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Letter Y
From: Michelle Long [mailto:mlongmph@sbcglobal.net]

Sent: Tuesday, April 28, 2015 5:01 PM
To: GWR
Subject: oppose SCH#2013051094.
I strongly OPPOSE
SCH#2013051094. I am a Seaside resident that is already upset that so much of our

water was sold by former Mayor's who were less educated than the rest of the towns who can afford to water their
parks and pay less for our water than we do. I think it is WRONG to pump treated sewage water into our basin. Find a
Real WAter Solution. This is NOt one of them!
Sincerely,
Michelle Long
8 Lisbon Ct.
Seaside CA 93955

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September 2015
Y-1
LetterY: MichelleLong
Y-1
Comments stating opinions on preferred alternatives or development scenarios do not directly

raise an environmental issue that require a response. The opinion of the Proposed Project
stated in the comment is referred to decision makers for their consideration.
California has established numerous state laws, regulations and policies governing the use of
recycled water for groundwater replenishment to protect groundwater quality and the health of
individuals who drink groundwater that is replenished using recycled water. Studies have been
conducted for other similar potable reuse projects, including epidemiology studies, risk
assessments, and investigations that analyze and compare the toxicological properties of
recycled water to those of drinking water. These studies have shown that (1) there is no
association between the use of recycled water and adverse health outcomes in individuals
consuming groundwater containing recycled water; and (2) purified recycled water from an
appropriately designed and operated AWT Facility, such as that to be used for the Proposed
Project, presents less risk to human health in terms of regulated chemicals, pathogens, and
trace organics compared to the risk from conventional drinking water sources.
Based on the analytical results of monitoring the source waters to be used for the Proposed
Project, the water quality results of the pilot plant testing, information on the predicted
performance and water quality of the proposed full-scale AWT Facility, and based on other
existing groundwater replenishment projects and related research/studies:
The Proposed Project would comply with the Groundwater Replenishment Regulations
and would meet all Central Coast Basin Plan standards, objectives, and guidelines.
An independent advisory panel of experts (including experts in the areas of public

health, groundwater, treatment technologies and water recycling), and the DDW have
reviewed the Proposed Project concept. The DDW has conditionally approved the
Proposed Project proposal, pending submittal of the permit applications and associated
specific design and operational information required by the Final Groundwater
Replenishment Regulations.
The full-scale proposed AWT Facility and recharge of the purified recycled water would
provide reliability and redundancy through the use of multiple treatment barriers.

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Letter Z
Z-1
Z-2
Z-3

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Z-3a
Z-3b
Z-3c
Z-3d
Z-3e

Final EIR
4-297
September 2015
Typedversionofhandwrittencommentcard:
Name:PeterB.Kaiser
Affiliation:ConcernedCitizenLongTermObserver
Email:kaiserdom@redshift.com
MailingAddress:1949YosemiteSt.Seaside,CA93955
PhoneNumber:(831)8993627
Comments:1)WeneedachoiceputGroundwaterReplenishmentonthevoterstodecideyesor
no.
Z-1
2)ALLOWpeopletooptoutofdrinkingsewerwaterbysendingretreatedwateronlytothose
customerswhowantit.Dontsenditinpipestothosewhodontwantit.
Z-2
3)FormanyyearsIhavebeenaskingforseveralreforms&noneofthosehavebeendone:
Z-3
ReformsDenied:
a. addmanyholdingpondstokeepmostrainwateronland&goingtowatertable
Z-3a
b. treatsewerwater&senditbacktocustomersasgreywaterforlandscapes&agriculture
whichisIguess95%ofallwateruse
Z-3b
c. TakehighqualitymudoutofLosPadresDamanddryit&sellit&restoreourmajorwater
storagesupply!
Z-3c
d. keepoutwater&treatedwateronpeninsula&notsendtoCastroville&Salinasvalley
aquifers
Z-3d
e. alloweachcityonPeninsulatokeeporrestorecityssewertreatmentplantstotreatsewer
water&sendtohomesasgreywaterforlandscapeineachcity.
Z-3e

Final EIR
4-298
September 2015
LetterZ: PeterB.Kaiser
Z-1
Comments stating opinions on preferred alternatives or implementation or legislative policy

scenarios do not directly raise an environmental issue that require a response. The policy
decision whether to place a project on a ballot is one that relevant decision makers can make at
the time they consider project approvals. The comment is referred to decision makers for their
consideration as part of the deliberative process. See also responses to comments U-1 and Y-1
for more relevant information.
Z-2
If the Proposed Project is constructed, purified water would be injected into the Seaside Basin.
Once the purified water is in the Basin, it would mix with native groundwater in the Basin. The
combined purified water and native groundwater would then be extracted using CalAms
existing extraction wells and conveyed through CalAms Distribution System. It would not be
possible to segregate purified water from native groundwater for delivery to individual
customers. See also responses to comments U-1 and Y-1 for more relevant information.
Z-3
See the responses to comments U-1, Y-1, and Z-3a-e for more relevant information.
Z-3a-e
This list of comments includes the header Reforms denied: It is unclear whether the reforms
listed were provided to the MRWPCA and/or any private water purveyors or public water supply
management entities. See also Master Response #12: Adequacy of Scope and Range of
Alternatives in Chapter 3, Master Responses to Comments. Specific responses to the items
are provided below:
Z-3a.
An analysis of storm water capture opportunities and constraints was conducted during project
planning. See Chapter 6, Alternatives to the Proposed Project, in the Draft EIR on pages 6-15
through 6-20 regarding an analysis of potential other storm water capture alternatives and why
no other storm water or urban diversions were pursued as source water for the Proposed
Project. The Seaside Watermaster and local jurisdictions are investigating storm water capture
as a method to augment groundwater in the Seaside Basin; however, the yields of any potential
capture and recharge are far less than the amount of source water needed to meet the
Proposed Project Objectives and the impacts of the Proposed Project would not be reduced
despite significant new infrastructure that would be required to build such projects (see Seaside
Basin Watermaster Report by Robert Jaques, June 19, 2013).
Z-3b
Urban recycled water use has been considered by the local agencies, however, the cost of
centralized urban reuse for residential and commercial land uses is very high due to the
amount of new treatment systems and/or pipelines and pumps needed to collect wastewater,
recycle wastewater, and return it to private users as urban irrigation water. This alternative
would not reduce environmental impacts because the amount of new infrastructure (including at
a minimum, distribution pumps and pipelines) needed to meet the basic project objectives
would dramatically increase the construction and operational impacts of the Proposed Project.
Regarding greywater systems, the Monterey Peninsula Water Management District encourages
on-site greywater systems to reduce potable demand within their jurisdiction. See
http://www.montereywaterinfo.org/index.html.
The comment suggests that the wastewater not be sent to the Regional Treatment Plant, but
instead, wastewater should be captured and treated to a level needed to reuse/recycle it within
the Monterey Peninsula. The Carmel Area Wastewater District (CAWD) does have a recycled
water project that has been implemented to supply advanced treated recycled water to Pebble
Beach golf courses. The District has capacity to meet existing and projected future wastewater
treatment needs for its service area within the Carmel and Del Monte Forest areas. However,
the CAWD treatment plant does not have adequate influent or capacity, nor are there users

Final EIR
4-299
September 2015
identified to date that would be able to accept the recycled water. Use of wastewater for local
treatment and recycling as an alternative to (or to reduce the size of) the desalination plant is
being pursued by the City of Pacific Grove in their Local Water Supply Project (see
http://www.ci.pg.ca.us/index.aspx?page=534). This project would provide 100 to 125 AFY of
replacement supplies for CalAm (approximately 3% of yield of the Seaside Basin groundwater
replenishment component of the project). This alternative does not meet most of the basic
objectives of the Proposed Project and would not reduce the environmental impacts of the
Proposed Project so is not considered further in this EIR. No other jurisdictions have proposed
any other projects such as this and no known sites for treatment and distribution systems, and
no facility designs have been provided or submitted to a level of detail needed to evaluate the
proposal as an alternative to the Proposed Project (i.e., projects that would capture Monterey
Peninsula wastewater flows, treat/recycle it for use locally). Evaluation of other alternatives as
referenced in this comment would be speculative.
Z-3c.
The MPWMD is working with CalAm to investigate improvements to and uses for the Los
Padres Dam. In 2014, MPWMD completed the Los Padres Dam and Reservoir LongTerm
Strategic and ShortTerm Tactical Plan, and entered into a Settlement Agreement with CalAm
as part of the 201517 General Rate Case to plan for the longterm future of the dam and
associated reservoir. Areas of study will include: sediment management, improving upstream
fish passage, mitigating for downstream habitat impacts, and an evaluation of alternatives
ranging from complete dam removal to increasing storage at the reservoir. The recent update to
the Monterey Peninsula, Carmel Bay and Southern Monterey Bay Integrated Water
Management Plan (MPWMD/DD&A, 2014) stated that: Enlarging the capacity of Los Padres
Reservoir (e.g., dredging or building a higher spillway) or construction of a new reservoir is
limited by economic, safety, and environmental constraints and is not considered to be feasible
at this time. Maintenance dredging of the Los Padres Reservoir to retain existing storage
capacity has been considered as an option, however, according to MPWMD staff summary
prepared for the July 21, 2014 MPWMD Board meeting, Los Padres Reservoir is a more
difficult and expensive site to address sediment issues than at the San Clemente Reservoir,
where a unique situation allowed sediment to remain in place. A fundamental issue with Los
Padres Dam that needs to be addressed with any proposed project is both short term and long
term management of sediment. The long term average sediment inflow is about 20 AFY or the
equivalent of about 2,200 tandem truckloads of sediment annually. Sediment starvation
downstream of the dam continues to degrade the river through the armoring effect (winnowing
of spawning gravel) and downcutting into the riverbed. Failure to address this degradation will
compromise efforts to improve habitat for steelhead by reducing diversions and may lead to
further destabilization of streambanks in the lower 15 miles of the river.
Z-3d
See response to Z-3b above.
Z-3e
See response to Z-3b above.

Final EIR
4-300
September 2015
Letter AA
STATE Of CAllrOR NIA
NATURAl 1\[SOURCES AGENCY
CALIFORNIA COASTAL COMMISSION

CENTRAl. COAST I>ISTR ICT OFFICE
ns FJ\ONT STRI LT SUITI; JOO
s,\NT,\ Clll l. C \ 9S060
1'110:-lE (KH J 4~ 7 ~ Rb.l
F,\.'\
cKII)4 ~' 4R77
\\Ell W\\'W l 0 ,\ST \ I ( ,\ GO\'
June 8, 2015
Administrative Otlice
Monterey, CA 93940
Subject: Comments on the Draft Environmentul Impact Report (DEilt) for the Pure Water
Monterey Groundwater Replenishment Project (PWMGRP)
Dear Mr. llolden:
We received the DEIR for the proposed Pure Water Monterey Groundwater Replenishment
Project (PWMGRP). The PWMGRP is a major project that has the potential to replace the State
mandated reduction of water diversion from the Carmel River system. In general, the project
would serve the important goals of reducing pumping along Carmel River, replenishing the
Seaside Groundwater Basin. and augmenting the existing Castroville Seawater Intrusion
Project's crop irrigation supply.
As we understand it, the proposed groundwater replenishment project consists of several
components. This letter addresses our concerns with the following elements: the Tembladero
Slough water diversion, the Coastal Alignment Conveyance Pipeline, and the Monterey Pipeline.
The project would enable CaiAm to reduce its diversions from the Carmel River system by up to
3,500 acre-feet per year by injecting roughly the same amount of highly-treated stormwater and
agricultural runoff into the Seaside Basin. The three project components are located in the
coastal zone and within the coastal permitjurisdictions of Monterey County, and the cities of
Marina. Seaside, and Sand City. A portion of the project is located within the California Coastal
Commission's retained coastal pennittingjurisdiction. The Coastal Development Permit (COP)
would be subject to policies in the certified Local Coastal Programs (LCPs) of each local
jurisdiction andfor Chapter 3 of the California Coastal Act. Note that there may be elements of
the proposed project that also lie within the appeal jurisdiction of the Commission and thus those
aspects of the local approval may also be appealable to the Coastal Commission. Given the
diflerent jurisdictional boundaries, Commission staff suggests that the cities and Monterey
County request a consolidated COP process pursuant to Coastal Act Section 30601.3.
Overall, we are generally supportive of the proposed project as it would offset groundwater
diversions from the Carmel River and replenish the Seaside Groundwater Basin with purified
recycled water, provide additional recycled water for the Castroville Seawater Intrusion Project's
crop irrigation supply, develop drought reserves, prevent sea water intrusion. and diversify
Monterey County's water suppl) portfolio. Below arc comments regarding the three project
elements mentioned above:

Final EIR
4-301
September 2015
AA-1
AA-2
AA-3
AA-4
Hob Holden
Monterey Regionul Water Pollution Control Agency
.June 8, 2015
Pagc2
I. Tembhu.lero Slough Diversion Site

The Tembladero Slough Diversion project site is located adjacent to the existing Castroville
Pump Station. Construction wi II include minor grading, installation of a new wet well and
diversion structure, modification of the existing wet well at the Castroville Pump Station and
construction of a short pipeline from the wet well to the new pump station. A temporary colTer
dam would be required around the construction site, which will be drained using a dewatering
pumping system. Construction excm ation may be as large as I 00 feet long by l 0 feet wide.
Once the work is finished, channel protection, either concrete or riprap. would be installed.
One concern with the Tembladero Slough water diversion project is the impact it will have on
the migration of certain fish species, notably the steelhead salmon and the tidewater goby. The
DEIR indicates that water withdrawals from the slough will result in adverse impacts to these
species and proposes to address these concerns via Best Management Practices (BMPs). The
BMPs include timing of construction during low flow season and relocation of aquatic species
during construction. Although these measures may reduce the impacts of construction on the
identi lied species, Commission staff is concerned that the long-term effects of diverting water
from the slough will not sustain the biological productivity of slough waters as required by
Section 2.4 ofthe North Monterey County Land Use Plan.
LUP Policy 2.5.2.4 requires that adequate quantities of water be maintained instrcam to support
natural aquatic and riparian vegetation and wildlite during the driest expected year. The DEIR
indicates that the Tembladero Slough water diversion is not necessary to meet the primary
project objective of replenishment of the Seaside Basin, but would be necessary to fully
accomplish the project objectives for the Castroville Seawater Intrusion Project (CSIP) with
respect to crop irrigation in some drought years. More specifically, the DEIR states that the
proposed project, which would include the Tembladero Slough water diversion, would provide
up to 5,900 AFY of crop irrigation water in the CSIP area in certain drought years, compared to
5.200 AFY of crop irrigation water without the Tembladero Slough water diversion, a difference
of 700 AFY. Although the 700 AFY is substantial, it appears to only be necessary during
extreme drought years. llowever. the withdrawal ofthis water from Tembladero Slough may
have long-lasting adverse impacts on the biological productivity of the slough. The DEIR should
fully evaluate the impacts of the proposed Tembladero Slough water diversion on identified
sensitive species during drought years.
2. Coastnl Pipeline Alignment Option
The Coastal Pipeline Alignment option is a proposed sub-surface pipeline that would move
advanced treated product water from the Salinas Regional Treatment Plant to the Seaside
Groundwater Basins injection well facilities. Portions of this element ofthe project would be
located in the coastal zone, including areas within the City of Marina's permitting jurisdiction
and the Coastal Commissions retained permitting jurisdiction. The pipeline would occupy a
large portion of the Transportation Agency for Monterey County's (TAMC) right of way, and
would also pass through State Parks land at Fort Ord Dunes State Park in unincorporated

Final EIR
4-302
September 2015
AA-5
AA-6
AA-7
AA-8
AA-9
Bob Holden
Monterey Rcgionul Wntcr Pollution Control Agency
.June 8, 2015
Pngc 3
Monterey County. All development within the Park is within the Commission' s retained coastal
permitting jurisdiction and is subject to the Chapter 3 policies of the California Coastal Act.
Fort Ord Dunes State Park is comprised or some 900"1" acres of environmentally sensitive sand
dune habitat. Section 30240 of the Coastal Act provides that environmentally sensitive habitat
areas (ESilAs) shall be protected against any significant disruption of habitat values, and also
states that only uses dependent on those resources shall be allowed within ESHA. The proposed
pipeline would be installed in the sand dunes via open trenching. The pipeline would
subsequently be buried and the site restored with native dune species. Though several mitigation
measures are proposed, the project cannot be Jound consistent with Section 30240 of the Coastal
Act because the project is not a resource dependent use. rhc DElR identifies alternative
locations lor the pipeline that largely avoid dune ESHA. 1 here may be other locations within the
coastal zone that also avoid dunes (e.g., beneath existing roadways and paths). The proposed
project should be modified to include alternative pipeline locations that avoid ESHA.
AA-9
Con't
AA-10
AA-11
3. Monterey Pipeline
The proposed Monterey Pipeline is 36-inches in diameter. is roughly 5.4 miles long, and
generally tollows the Monterey Peninsula Recreational Trail and T AMC right-of-way through
Sand City. the City ofSeaside, the City of Monterey, and Pacitic Grove.
AA-12
The primary concerns with the installation of the Monterey Pipeline are that it would be located
within and disrupt environmentally sensitive habitat areas, including dune ESliA. As stated
above, Section 30240 of the Coastal Act restricts development within ESIIA to resource
dependent uses only. The proposed pipeline is not a resource dependent use; that is, it is not
dependent on sand dunes to exist or operate. Thus, we recommend that the DElR investigate
alternative sites lor the pipeline including those that avoid dune ESI-IA (i.e., road right-of-ways.
beneath existing paths, etc.).
AA-13
Additionally, the preferred location for the Monterey Pipeline is within an area that is subject to
shoreline hazards, such as flooding. The Coastal Act requires all development to be sited and
designed to minimize risks in areas of high flood hazard. We recommend that the DEIR evaluate
and choose a location that avoids flooding hazards and minimizes risks, as required by the
Coastal Act.
Conclusion
Thank you for the opportunity to comment on this signiticant public improvement project. If you
have any questions or would like to discuss the project or these comments. please contact me at
the address and phone number above.
Regard?f<J1
r/t_,i uJ~
Mike Watl/n [,-V(

Coastal Planner
Central Coast District Ot1ice

Final EIR
4-303
September 2015
AA-14
LetterAA:CaliforniaCoastalCommission
AA-1
The comment contains an overview of the Proposed Project; no response necessary.
AA-2
The comment identifies the components of the Proposed Project that are the subject of the
comments in the letter and contains a description of the location of the components within the
Coastal Zone. The comment is consistent with the contents of the Draft EIR.
AA-3
The comment provides information about the permitting authority and policies to which the
project would be compared. The comment is consistent with the contents of the Draft EIR.
AA-4
AA-5
The comment reiterates information about the project from the Draft EIR; no response is
necessary.
AA-6
See Master Response #5: Fisheries Impact Analyses in Chapter 3, Master Responses to
Comments.
Regarding construction phase impacts, potentially significant impacts to fisheries due to
construction are identified in the Draft EIR on pages 4.4-41 through 4.4-44 and mitigation
measures to reduce significant impacts to a less-than-significant level are provided on page
4.4-44 including Mitigation Measures BF-1a and BF-1b that require construction be timed to
occur only outside of both adult and smolt steelhead migration periods (i.e., between June and
November) and relocation of aquatic species during construction. The reference to best
management practices on page 4.4-42 of the Draft EIR is correct; however, Section 4.4 of the
Draft EIR did not identify these within the mitigation. Text of page 4.4-44 of the Draft EIR has
been modified to include the requirement to implement mitigation measure BT-1a from Section
4.5 that would further reduce impacts to aquatic species during construction. The construction
of the Tembladero Slough Diversion component would potentially impact 0.01 acres of coastal
wetlands (considered to be an environmentally sensitive habitat area) within the Countys North
Monterey County a certified local coastal land use program per the California Coastal Act.
Regarding operational impacts of diverting water from the slough, impacts of the diversions on
the Salinas River are analyzed on pages 4.4-44 and 4.4-45 of the Draft EIR and a detailed
analysis is provided in Appendix F-Revised. The number and percentage of days in each
month (over the entire 82-year period of record) are evaluated when the Proposed Project
would result in flows below a migratory flow threshold. The model results show that under the
Proposed Project, suitable adult migration flows would be reduced below each of the passage
flow indicator values less than 2.0% of the time and juvenile migration flows would be reduced
below each of the passage flow indicator values less than 3.0% of the time, both relative to
existing conditions, as summarized on Table 4.4-10, Predicted Changes to Steelhead Passage
Flow Thresholds in the Salinas River. Although the percent of flow reductions would vary by
month for all indicator flows, changes within any month all would be less than 6.7% with the
highest change in December. The change in flows under the Proposed Project would not result
in significant impacts to steelhead migration in the Salinas River.
The potential impacts to fisheries due to diverting water from the Tembladero Slough are
analyzed in the Draft EIR on pages 4.4-45 through 4.4-48, summarizing the detailed analysis in
Appendix G. Mitigation measures to reduce the potentially significant impacts to a less-than-

Final EIR
4-304
September 2015
significant level are provided on pages 4.4-48 to 4.4-49 of the Draft EIR including Mitigation
Measures BF-2a and Mitigation Measure Alternate BF-2a.
AA-7
Monterey
County
The text of the Draft EIR on page 4.4-33 has been amended to include an analysis of
consistency with North Monterey County Land Use Plan Policy 2.5.2.4 as follows:
North
County
Land
Use
Plan
Water
Resources
Tembladero
Slough
Policy 2.5.2.4 Adequate

quantities of water should be
maintained instream or supplied
to support natural aquatic and
riparian vegetation and wildlife
during the driest expected year.
Consistent with Mitigation: Operation of

the Proposed Project with Mitigation
Measures BF-2 would ensure adequate
quantities of water are maintained to support
federal and state-listed fish species during
the driest expected year. (See Impact BF-2)
See Chapter 5, Changes to the Draft EIR.. See also Master Response #5: Fisheries Impact
Worse-case
AA-8
The Draft EIR evaluates the operational (long-term) impacts of the proposed Tembladero
Slough water diversion on identified sensitive fish species on pages 4.4-45 through 4.4-48,
summarizing the detailed analysis in Appendix G. Mitigation measures to reduce the potentially
significant impacts to a less-than-significant level were provided on pages 4.4-48 to 4.4-49 of
the Draft EIR including Mitigation Measures BF-2a and Mitigation Measure Alternate BF-2a.
The analysis includes consideration of the worst-case hydrology and flow regimes and
therefore, addresses the driest (or drought) year scenarios. The Draft EIR evaluates the
operational (long-term) impacts of the proposed Tembladero Slough water diversion on
identified aquatic and riparian species on pages 4.5-96 through 4.5-101. This analysis relies on
habitat and species occurrence mapping in Appendices H and I. Based on the analysis,
operational impacts of the Tembladero Slough diversion on aquatic and riparian species and
habitat were found to be less-than-significant. Both of the analyses include consideration of the
worse-case hydrology and flow regimes; therefore, the Draft EIR adequately addresses the
impacts on species and habitat downstream of the diversion points in the Coastal Zone
including during driest (or drought) year scenarios. See also Master Response #5: Fisheries
Impact Analyses and Master Response #4: Reduction in Surface Water Flows in Chapter 3,
AA-9
necessary.
AA-10
The Proposed Projects Coastal Alignment Option for the Product Water Conveyance Pipeline
would pass through the coastal zone on the west side of Highway 1 near the Fort Ord Dunes
State Park. This portion of the alignment is proposed to be located entirely within the
Transportation Agency of Monterey County land that is outside of the Fort Ord Dunes State
Parks land with the potential exception of an approximate -acre site on the west side of the
Divarty Road undercrossing of Highway 1. At that location, the land has been designated as
development area by the Fort Ord Reuse Plan and the by the Fort Ord Dunes State Park
Master Plan. The site does not contain sensitive habitat (see Appendix H-8 Page 20 of the
Draft EIR) that would be considered environmentally sensitive habitat areas (ESHA) based on
habitat surveys by DD&A biologists. California Department of Parks and Recreations Final
Initial Study/Negative Declaration for the Fort Ord Dunes State Park Campground Project
documents that the site contains only ice plant, well-known to be non-native (exotic) species.
See Figure 4.3-3 of the Initial Study/Negative Declaration on the following page (California
Department of Parks and Recreation/Denise Duffy and Associates, Inc., 2013). Ice plant is not
considered to be sensitive habitat nor ESHA as defined in Section 230240 of the California

Final EIR
4-305
September 2015
Coastal Act. The Proposed Project would include removal of non-native iceplant species and
restoration of the site with native vegetation in accordance with Mitigation Measure BT-1c.
AA-11
The Proposed Project evaluates the RUWAP alignment option as another option that would
avoid the impacts identified for the Coastal alignment option. A comparison between the
Coastal and RUWAP alignment options is provided in the Draft EIR on pages 6-34 through 636. The RUWAP alignment option would avoid land located adjacent to and within the Fort Ord
Dunes State Park (including potentially avoiding Environmentally Sensitive Habitat Areas, or
ESHA) and would also avoid coastal resources (wetlands) at Locke Paddon Lake in the City of
Marina. See also Master Response # 12: Adequacy of Scope and Range of Alternatives in
AA-12
necessary.
AA-13
The Proposed Projects Monterey Pipeline would potentially be located within ESHA;
specifically, central dune scrub (silver dune lupine mock heather scrub) that supports habitat
for Smiths blue butterfly and eucalyptus trees that provide habitat for Monarch butterflies as
identified on page 4.5-92 of the Draft EIR. The alternatives analysis describes and evaluates an
alternative to the Monterey Pipeline and discloses that the Alternative Monterey pipeline would
avoid the significant impacts related to impacts to sensitive habitats (see Draft EIR page 6-41,
Table 6-5), and thus the Alternative Monterey Pipeline would achieve the requested avoidance
of ESHA. The Alternative Monterey Pipeline was found to be environmentally superior to any
alternative that would include the Monterey Pipeline on Draft EIR page 6-46. See also Master
Response # 12: Adequacy of Scope and Range of Alternatives in Chapter 3, Master
AA-14
The Draft EIR discloses that the Monterey Pipeline would be within an area that is subject to
shoreline hazards, such as flooding due to coastal erosion and sea level rise (see Draft EIR
pages 4.8-38 and 4.11-92). The alternatives analysis describes and evaluates an alternative to
the Monterey Pipeline and discloses that the Alternative Monterey pipeline would avoid the
significant impacts related to impacts to flooding and coastal erosion/sea level rise (see page 641 of the Draft EIR, Table 6-5), and thus the Alternative Monterey Pipeline would achieve the
requested risk minimization. The Alternative Monterey Pipeline was found to be environmentally
superior to any alternative that would include the Monterey Pipeline on page 6-46 of the Draft
EIR. See also Master Response # 12: Adequacy of Scope and Range of Alternatives in

Final EIR
4-306
September 2015
Letter BB
STATE OF CALIFORNIA
GOVERNOR'S OFFICE of PLANNING AND RESEARCH

STATE CLEARINGHOUSE AND PLANNING UNIT
EDMUND G. BROWN JR.
KEN ALEX
GOVERNOR
DIRECTOR
June 26,2015
Bob Holden
Monterey, CA 93940
Subject: Monterey Peninsula Groundwater Replenishment (Pure Water Monterey) Project
SCH#: 2013051094
Dear Bob Holden:
The enclosed comment (s) on your Draft EIR was (were) received by the State Clearinghouse after the end
of the state review period, which closed on June 5, 2015 . We are forwarding these cotmnents to you
because they provide information or raise issues that should be addressed in your final environmental
document.
The California Environmental Quality Act does not require Lead Agencies to respond to late cmmnents.
However, we encourage you to incorporate these additional cmmnents into your fmal envirorunental
document and to consider them prior to taking final action on the proposed project.
Please contact the State Clearinghouse at (916) 445-0613 ifyou have any questions concerning the
environmental review process. If you have a question regarding the above-named project, please refer to
the ten~digit State Clearinghouse number (20 13051 094) when contacting this office.
Sincerely,
~__,.-
//
~:y~/?f?A~~
?J
Scott Morgan
Director, State Clearinghouse
Enclosures
cc: Resources Agency
1400 lOth Street P.O. Box 3044 Sacramento, California 95812-3044

(916) 445-0613 FAX (916) 323-3018 www.opr.ca.gov
Final EIR
4-307
September 2015
BB-1
LetterBB: GovernorsOfficeofPlanningandResearch,StateClearinghouse#2
BB-1
The letter was a cover letter transmitting two comment letters that the State Clearinghouse
received after the public review period. Specifically, the State Water Resources Control Board
(see letter CC) and the California Coastal Commission (see letter AA) submitted their letters to
the State Clearinghouse after June 5, 2015. No further response to this letter or to the two
attachments are required; however, the two attachments have been included in the Final EIR
and responses to the comments related to the environmental review and EIR are provided
herein because the agencies that submitted the comments may be responsible agencies for the
Proposed Project. The Monterey Regional Water Pollution Control Agency has complied with
the State Clearinghouse review requirements as required pursuant to CEQA.

Final EIR
4-308
September 2015
Letter CC
Letter CC
fOMUND
G.
8RO~N
JR.
GOVERNOR
'
~
N
~~
Water Boards
MATIHEW R ODRIOUE.Z
SECRE1ARV FOR
ENVIRONMENTAL PROTECTION
/R~~;;;;o /
JUN z 2 -2015
Mr. Bob Holden
Monterey, CA 93940
ISTATE CLEARII\.\(3 I-lOUSE I

-------~~~---1
Dear Mr.Holden:
EIR FOR MONTEREY REGIONAL WATER POLLUTION CONTROL AGENCY (MRWPCA);
MONTEREY PENINSULA GROUNDWATER REPLENISHMENT PROJECT (PROJECT); MONTEREY
COUNTY; STATE CLEARINGHOUSE NO. 2013051094
We understand that the Agency is pursuing Clean Water State Revolving Fund (CWSRF) financing for
this Project (CWSRF No. C-06-8028-11 0). As a funding agency and a state agency with jurisdiction by
law to preserve, enhance, and restore the quality of California's water resources, the State Water
Resources Control Board (State Water Board) is providing the following information on the EIR to be
prepared for the Project.
The State Water Board, Division of Financial Assistance, is responsible for administering the CWSRF
Program. The primary purpose for the CWSRF Program is to implement the Clean Water Act and
various state laws by providing financial assistance for wastewater treatment facilities necessary to
prevent water pollution, recycle water, correct nonpoint source and storm drainage pollution problems,
provide for estuary enhancement, and thereby protect and promote health, safety and welfare of the
inhabitants of the state. The CWSRF Program provides low-interest funding equal to one-half of the
most recent State General Obligation Bond Rates with a 30-year term. Applications are accepted and
processed continuously. Please refer to the State Water Board's CWSRF website at:
www.waterboards.ca .gov/water issues/programs/grants loans/srf/index.shtml.
CC-1
The CWSRF Program is partially funded by the United States Environmental Protection Agency and
requires additional "CEQA-Pius" environmental documentation and review. Three enclosures are
included that further explain the CWSRF Program environmental review process and the additional
federal requirements. For the complete environmental application package, please visit:
http://www.waterboards.ca.gov/water issues/programs/grants loans/srf/srf forms.shtml. The State
Water Board is required to consult directly with agencies responsible for implementing federal
environmental laws and regulations. Any environmental issues raised by federal agencies or their
representatives will need to be resolved prior to State Water Board approval of a CWSRF financing
commitment for the proposed Project. For further information on the CWSRF Program, please contact
Mr. Ahmad Kashkoli, at (916) 341-5855.
It is important to note that prior to a CWSRF financing commitment, projects are subject to provisions of
the Federal Endangered Species Act (ESA), and must obtain Section 7 clearance from the United
States Department of the Interior, Fish and Wildlife Service (USFWS), and/or the United States
Department of Commerce National Oceanic and Atmospheric Administration , National Marine Fisheries
Service (NMFS) for any potential effects to special-status species.
FELICIA MARcus , CHA IR 1 TH OMAS
1001 I Street, Sacramento , CA 95814
exEcurPJE DIRECTOR
Mailing Address: P.O. Box 100, Sacr amento , Ca 958120100
c~

Final EIR
H owAI1D,
www.waterboar ds.ca. gov
RECYCLEO PAPER
4-309
September 2015
CC-2
2
Please be advised that the State Water Board will consult with the USFWS, and/or the NMFS regarding
all federal special-status species that the Project has the potential to impact if the Project is to be
financed by the CWSRF Program. The MRWPCA will need to identify whether the Project will involve
any direct effects from construction activities, or indirect effects such as growth inducement, that may
affect federally listed threatened, endangered, or candidate species that are known, or have a potential
to occur in the Project site, in the surrounding areas, or in the service area, and to identify applicable
conservation measures to reduce such effects.
In addition, CWSRF projects must comply with federal laws pertaining to cultural resources, specifically
Section 106 of the National Historic Preservation Act (Section 106). The State Water Board has
responsibility for ensuring compliance with Section 106, and must consult directly with the California
State Historic Preservation Officer (SHPO). SHPO consultation is initiated when sufficient information
is provided by the CWSRF applicant. If the MRWPCA decides to pursue CWSRF financing, please
retain a consultant that meets the Secretary of the Interior's Professional Qualifications Standards
(http://www.nps.gov/history/local-law/arch stnds 9.htm) to prepare a Section 106 compliance report.
Note that the MRWPCA will need to identify the Area of Potential Effects (APE), including construction
and staging areas, and the depth of any excavation. The APE is three-dimensional and includes all
areas that may be affected by the Project. The APE includes the surface area and extends below
ground to the depth of any Project excavations. The records search request should extend to a ~-mile
beyond the Project APE with the search area illustrated on detailed maps.
CC-3
CC-4
CC-5
Other federal environmental requirements pertinent to the Project under the CWSRF Program include
the following (for a complete list of all federal requirements please visit:
http://www.waterboards.ca.gov/water issues/programs/grants loans/srf/docs/forms/application environ
mental package.pdf):
A. Compliance with the Federal Clean Air Act: (a) Provide air quality studies that may have been
done for the Project; and (b) if the Project is in a nonattainment area or attainment area subject
to a maintenance plan; (i) provide a summary of the estimated emissions (in tons per year) that
are expected from both the construction and operation of the Project for each federal criteria
pollutant in a nonattainment or maintenance area, and indicate if the nonattainment designation
is moderate, serious, or severe (if applicable); (ii) if emissions are above the federal de minimis
levels, but the Project is sized to meet only the needs of current population projections that are
used in the approved State Implementation Plan for air quality, quantitatively indicate how the
proposed capacity increase was calculated using population projections.
B. Compliance with the Coastal Zone Management Act: Identify whether the Project is within a
coastal zone and the status of any coordination with the California Coastal Commission.
C. Protection of Wetlands: Identify any portion of the proposed Project area that should be
evaluated for wetlands or United States waters delineation by the United States Army Corps of
Engineers (USACE), or requires a permit from the USACE, and identify the status of
coordination with the USACE.
D. Compliance with the Farmland Protection Policy Act: Identify whether the Project will result in
the conversion of farmland. State the status of farmland (Prime, Unique, or Local and Statewide
Importance) in the Project area and determine if this area is under a Williamson Act Contract.
E. Compliance with the Migratory Bird Treaty Act: List any birds protected under this act that may
be impacted by the Project and identify conservation measures to minimize impacts.
F. Compliance with the Flood Plain Management Act: Identify whether or not the Project is in a
Flood Management Zone and include a copy of the Federal Emergency Management Agency
flood zone maps for the area.

Final EIR
4-310
September 2015
CC-6
3
G. Compliance with the Wild and Scenic Rivers Act: Identify whether or not any Wild and Scenic
Rivers would be potentially impacted by the Project and include conservation measures to
minimize such impacts.
CC-6
Con't
If applying for CWSRF financing for the Project, please consider the following comments:
1. Please complete an application package, including the Clean Air Act table in the Environmental
Package for air quality modeling data with construction and operational emissions in tons/year.
http://www.waterboards.ca.gov/water issues/programs/grants loans/srf/srf forms.shtml
2. In support of Section 106 documentation, include detailed, properly scaled maps indicating the
location of the half-mile search radius in relation to the Project APE. Provide labeled locations
of all of the archaeological properties located within the APE and search area.
3. Please provide copies of complete site records for all of the sites located within the APE and
within the half-mile radius of the APE to the State Water Board Archaeologist, Gary Scholze.
4. Page 4.6-5 of the EIR states that a background search of the California Historical Resources
Information System (CHRIS) database files found 20 recorded resources within or adjacent to
the Project Area of Potential Effects, as summarized in Table 4.6-1, Recorded Cultural Sites
within Vicinity of Proposed Project Sites; yet Table 4.6-1 lists 23 recorded resources. Please
clarify, and include the request letter and supporting information used to indicate the record
search area for the search of the CHRIS database.
5. Provide documentation of the cultural resources report authors' qualifications, and of those who
conducted the field surveys (Mary Doane, Patrick Cave, and Gina Kay) according to the
Secretary of the Interior's Professional Qualifications Standards:
http://www.nps.gov/history/local-law/arch stnds 9.htm for qualifications defining minimum
education and experience required to perform identification, evaluation, registration, and
treatment activities (36 CFR Part 61 ).
6. Please send a phone/cqntact log documenting the Native American consultation efforts within a
table for each attempted contact, including all responses, dates, and follow-up.
7. Please include the State Water board in all future consultation efforts, and address all
comments and concerns, including the response to the March 21, 2014 letter from
Louise J. Miranda Ramirez, Chairperson of the Ohlone/Costanoan-Esselen Nation. Provide all
of the records from the North Western Information Center records search for this project, as
requested, to the Ohlone/Costanoan-Esselen Nation, and plan to continue consultation while
observing the request that the Tribe's deceased are not disturbed.
8. Please clarify the consultation efforts in regards to the March 6, 2014 letter from the Native
American Heritage Commission responding to the request for a search of the Sacred Lands File
that states, "The search indicates the potential of Native American cultural resources in the
project vicinity that may be impacted on the Moss Landing USGS quadrangle, (T 13S, R 2E,
Sec 18). The site is described as the Elkhorn Slough. For specific information regarding this
site, please contact the Ohlone Indians. The contact information is on the attached Native
American Contacts List."

Final EIR
4-311
September 2015
CC-7
4
9. If applying for financing through the CWSRF Program, please provide a Draft SHPO
Consultation Letter which includes a detailed summary of the Cultural Report and an
assessment of the cultural sensitivity and the proximity of the historic properties to construction
activities within the half-mile search radius. Include a discussion of avoidance and appropriate
mitigation measures to avoid impacts, and the need for any further assessment of the historic
properties. In particular, discuss the risks to the historic properties listed in section 4.6.2.2 of
the Draft EIR due to construction of the following Project elements:
a) Tembladero Slough Diversion site mapped in an area of "high archaeological sensitivity";
b) Treatment Facilities at the Regional Treatment Plant site as being mapped in an area of
"moderate" archaeological sensitivity;
c) Lake El Estero Source Water Diversion and Storage site as being located within areas of
"High Probability of Pre-Historic Artifacts"
d) Monterey Pipeline portion of the CaiAm Distribution System as being located within areas
of "High Probability of Pre-Historic Artifacts"
e) The drainage area along the southern border of the City of Seaside, leading to and
including Laguna del Rey (the Monterey Pipeline passes through this area), as an area of
prehistoric archaeological sensitivity.
10. Please indicate a statement of findings in language appropriate to the Section 106 report
standards: 1) No historic properties affected, 2) No effect to historic properties. 3) No adverse
effect to historic properties, OR 4) Adverse effect to historic properties.
11 . Provide species lists and mapped areas of designated critical habitat for the Project from the
U.S. Fish and Wildlife Service (USFWS), National Oceanic and Atmospheric
Administration/National Marine Fisheries Service (NOAA/NMFS), and from the California Native
Plant Society (CNPS) Rare and Endangered Plant Inventory in preparation for Endangered
Species Act (ESA) compliance for Section 7 consultation.
Please provide us with the following documents applicable to the proposed Project following the
MRWPCA's California Environmental Quality Act (CEQA) process: (1) one copy of the draft and final
EIR, (2) the resolution certifying the EIR and making CEQA findings, (3) all comments received during
the review period and the MRWPCA's response to those comments, (4) the adopted Mitigation
Monitoring and Reporting Program (MMRP), and (5) the Notice of Determination filed with the Monterey
County Clerk and the Governor's Office of Planning and Research, State Clearinghouse. In addition,
we would appreciate notices of any hearings or meetings held regarding environmental review of any
projects to be funded by the State Water Board.
Thank you for the opportunity to review the MRWPCA's Draft EIR. If you have any questions or
concerns, please feel free to contact me at (916) 341-5879 or by email at
Susan.Stewart@waterboards.ca.gov, or contact Ahmad Kashkoli at (916) 341-5855, or by email at
Ahmad. Kashkoli@waterboards .ca.gov.
Sincerely,
~lii-cun_, L . 3!a)cvr_,l
Susan L. Stewart
Enclosures (3) see next page

Final EIR
4-312
September 2015
CC-7
Con't
5
Enclosures (3)
1. Clean Water State Revolving Fund Environmental Review Requirements

2. Quick Reference Guide to CEQA Requirements for State Revolving Fund Loans
3. Basic Criteria for Cultural Resources Reports
cc:
State Clearinghouse
(Re: SCH# 2013051094)
P.O. Box 3044
Sacramento, CA 95812-3044

Final EIR
4-313
September 2015
Letter CC Attachments
National Historic Preservation Act (NHPA)

Section 106 of the NHPA requires an analysis of the eects
on historic properties. The Section 106 process is designed
to accommodate historic preservation concerns for federal
actions with the potential to aect historic properties. Early
consultation with appropriate government agencies, Indian
tribes, and members of the public, will ensure that their
views and concerns are addressed during the planning phase.
Historic properties (i.e., buildings, structures, objects,
and archaeological sites 50 years or older) are properties
that are included in the National Register of Historic
Places or meet the criteria for the National Register.
ADDITIONAL INFORMATION
If your project has the potential to aect biological resources
or historic properties, the consultation process can be
lengthy. Please contact the State Water Board sta early
in your planning process to discuss what additional
information may be needed for your specic project.
Please contact your State Water Board Project Manager
or Mr. Ahmad Kashkoli at (916) 341-5855 or
Ahmad.Kashkoli@waterboards.ca.gov for more
information related to the CWSRF Program environmental
review process and requirements.
CLE AN WATER STATE REVOLVING FUND
Required Documents:
A draft State Historic Preservation Ocer consultation
request letter; and
A cultural resources report on historic properties conducted

according to the Secretary of the Interiors Standards,
including:
A clearly dened Area of Potential Eect (APE),
specifying the length, width, and depth of excavation,

with a map clearly illustrating the project APE;
A records search, less than one year old, extending to a
half-mile beyond the project APE;
Written description of eld methods;
Identication and evaluation of historic properties
within the projects APE; and
Documentation of consultation with the Native
American Heritage Commission and local Native
American tribes.

Division of Financial Assistance

Final EIR
4-314
REVISED: FEB. 2014
www.waterboards.ca.gov
September 2015
ENVIRONMENTAL REVIEW
REQUIREMENTS
The Clean Water State Revolving Fund (CWSRF) Program is
partially funded by the United States Environmental Protection
Agency (EPA), and is subject to federal environmental regulations
as well as the California Environmental Quality Act (CEQA).
All applicants seeking CWSRF nancing must comply with
both CEQA and the federal cross-cutting regulations. The
"Environmental Package" provides the forms and instructions
needed to complete the environmental review requirements
for CWSRF nancing. The forms and instructions are available
at: http://www.waterboards.ca.gov/water_issues/
programs/grants_loans/srf/srf_forms.shtml.
Lead Agency/Applicant
The applicant will generally act as the "Lead Agency" for
environmental review. It will prepare, circulate, and consider
the environmental documents prior to approving the
project. It also provides the State Water Board with copies
of the CEQA documents, and a completed Environmental
Evaluation Form for Environmental Review and Federal
Coordination (http://www.waterboards.ca.gov/
water_issues/programs/grants_loans/srf/docs/forms/
application_environmental_package.pdf) with supporting
documents as part of the "Environmental Package."
Responsible Agency/State Water Board

The State Water Board acts on behalf of EPA to review and
consider the environmental documents before approving
nancing. The State Water Board may require additional
studies or documentation to make its own CEQA ndings, as
well as circulate CEQA documents and other environmental
reports to relevant federal agencies for consultation before
making a determination about the project nancing.
The Applicant must address all relevant federal agencies'
comments before project nancing is approved.
Final EIR
FEDERAL CROSS-CUTTING REGULATIONS

The CWSRF Program requires consultation with
relevant federal agencies on the following federal
environmental regulations, if applicable to the project:
Clean Air Act
Coastal Barriers Resources Act
Coastal Zone Management Act
Endangered Species Act
Environmental Justice
Farmland Protection Policy Act
Floodplain Management
Magnuson-Stevens Fishery Conservation
and Management Act
Migratory Bird Treaty Act
National Historic Preservation Act
Protection of Wetlands
Safe Drinking Water Act,
Sole Source Aquifer Protection
Wild and Scenic Rivers Act
The following is a brief overview of requirements
for some of the key regulations.
Clean Air Act (CAA)

The CAA general conformity analysis only applies to
projects in areas not meeting the National Ambient Air
Quality Standards or subject to a maintenance plan.
If project emissions are below the federal de minimis levels
then:
A general conformity analysis is not required.
If project emissions are above the federal de minimis levels
then:
A general conformity determination for the project must
be made. A general conformity determination can be
made if facilities are sized to meet the needs of current
population projections used in an approved State
Implementation Plan for air quality.
4-315
Using population projections, applicants must explain

how the proposed capacity increase was calculated.
An air quality modeling analysis is necessary of
all projects for the following criteria pollutants,
regardless of attainment status:
Carbon monoxide
Lead
Oxides of nitrogen
Ozone
Particulate matter (PM2.5 and PM10)
Sulfur dioxide
Endangered Species Act (ESA)

The ESA requires an analysis of the eects on federally listed
species. The State Water Board will determine the projects
potential eects on federally listed species, and will initiate
informal/formal consultation with the United States Fish
and Wildlife Service (USFWS) and/or the National Marine
Fisheries Service, as necessary under Section 7 of the ESA.
Required Documents:
A species list, less than one year old, from the USFWS and
the California Department of Fish and Wildlifes Natural
Diversity Database;
A biological survey conducted during the appropriate
time of year;
Maps or documents (biological reports or biological
assessments, if necessary); and
An assessment of the direct or indirect impacts to any
federally listed species and/or critical habitat. If no eects
are expected, explain why and provide the supporting
evidence.
September 2015
The State Water Resources Control Board

(State Water Board), Division of Financial
Assistance, administers the Clean
Water State Revolving Fund (CWSRF)
Program. The CWSRF Program is partially
funded by grants from the United States
Environmental Protection Agency. All
applicants seeking CWSRF nancing
must comply with the California
Environmental Quality Act (CEQA), and
provide sucient information so that
the State Water Board can document
compliance with federal environmental
laws. The Environmental Package
provides the forms and instructions
needed to complete the environmental
review requirements for CWSRF Program
nancing. It is available at:
http://www.waterboards.ca.gov/
water_issues/programs/grants_
loans/srf/srf_forms.shtml
LEAD AGENCY
The applicant is usually the Lead Agency and
must prepare and circulate an environmental
document before approving a project. Only
a public agency, such as a local, regional or
state government, may be the Lead Agency
under CEQA. If a project will be completed by a
non-governmental organization, Lead Agency
responsibility goes to the rst public agency
providing discretionary approval for the project.
RESPONSIBLE AGENCY
The State Water Board is generally a
Responsible Agency under CEQA. As a
Responsible Agency, the State Water Board
must make ndings based on information
provided by the Lead Agency before nancing
a project.
ENVIRONMENTAL REVIEW
The State Water Boards environmental review
of the projects compliance with both CEQA
and federal cross-cutting regulations must be
completed before a project can be nanced by
the CWSRF Program.
DOCUMENT REVIEW
Applicants are encouraged to consult with
State Water Board sta early during preparation
of CEQA document if considering CWSRF
nancing. Applicants shall also send their
environmental documents to the State Water
Board, Environmental Review Unit during
the CEQA public review period. This way, any
environmental concerns can be addressed early
in the process.
REQUIRED DOCUMENTS
The Environmental Review Unit requires the
documents listed below to make ndings and
complete its environmental review. Once the
State Water Board receives all the required
documents and makes its own ndings, the
environmental review for the project will be
complete.
9 Draft and Final Environmental Documents:

Environmental Impact Report, Negative
Declaration, and Mitigated Negative Declaration as appropriate to the project
9 Resolution adopting/certifying the environmental document, making CEQA ndings,

and approving the project
9 All comments received during the public

review period and the Lead Agencys
responses to those comments
9 Adopted Mitigation Monitoring and

Reporting Plan, if applicable
9 Date-stamped copy of the Notice of

Determination or Notice of Exemption led
with the County Clerk(s) and the Governors
Oce of Planning and Research
9 CWSRF Evaluation Form for Environmental

Review and Federal Coordination with
supporting documents
Contact Information: For more information related to the CWSRF Program environmental
review process and requirements, please contact your State Water Board Project Manager
or Mr. Ahmad Kashkoli at 916-341-5855 or Ahmad.Kashkoli@waterboards.ca.gov
waterboards.ca.gov
REVISED: FEB. 2014

Final EIR
4-316
September 2015
Basic Crite
eria for
For Section 106 Consultation with the State Historic Preservation Officer (SHPO)
under the National Historic Preservation Act
CULTURAL RESOURCES REPORT
RECORDS SEARCH
The Cultural Resources Report must be prepared by a

qualied researcher that meets the Secretary of the Interiors
Professional Qualications Standards. Please see the
Professional Qualications Standards at the following website
at: http://www.cr.nps.gov/local-law/arch_stnds_9.htm
A records search (less than one year old) extending to a halfmile beyond the project APE from a geographically appropriate
Information Center is required. The records search should
include maps that show all recorded sites and surveys in
relation to the APE for the proposed project, and copies of the
condential site records included as an appendix to the Cultural
Resources Report.
The Cultural Resources Report should include one of the

four ndings listed in Section 106. These include:
The APE is three-dimensional (depth, length and width) and

all areas (e.g., new construction, easements, staging areas, and
access roads) directly aected by the proposed project.
No historic properties affected

(no properties are within the area of potential
eect (APE; including below the ground).
No effect to historic properties
(properties may be near the APE, but the
project will not have any adverse eects).
No adverse effect to historic properties
(the project may aect historic properties,
but the eects will not be adverse).
Adverse effect to historic properties
Note: Consultation with the SHPO will be required if a
no adverse eect to historic properties or an adverse
eect to historic properties determination is made,
to develop and evaluate alternatives or modications
to the proposed project that could avoid, minimize or
mitigate adverse eects on historic properties.

Final EIR
4-317
September 2015
NATIVE AMERICAN
and INTERESTED PARTY CONSULTATION
PRECAUTIONS
Native American and interested party consultation should

be initiated at the planning phase of the proposed project
to gather information to assist with the preparation of an
adequate Cultural Resources Report.
A nding of no known resources without supporting

evidence is unacceptable. The Cultural Resources Report
must identify resources within the APE or demonstrate
with sucient evidence that none are present.
The area is sensitive for buried archaeological
resources, followed by a statement that monitoring is
recommended. Monitoring is not an acceptable option
without good-faith eort to demonstrate that no known
resource is present.
If the area is already disturbed by previous
construction documentation is still required to demonstrate
that the proposed project will not aect historic properties.
An existing road can be protecting a buried archaeological
deposit or may itself be a historic property. Additionally,
previous construction may have impacted an archaeological
site that has not been previously documented.
The Native American Heritage Commission (NAHC) must be

contacted to obtain documentation of a search of the Sacred
Lands Files for or near the project APE.
All local Native American tribal organizations or individuals
identied by the NAHC must be contacted by certied mail,
and the letter should include a map and a description of the
proposed project.
Follow-up contact should be made by telephone and a phone
log maintained to document the contacts and responses.
Letters of inquiry seeking historical information on the
project area and local vicinity should be sent to local historical
societies, preservation organizations, or individual members
of the public with a demonstrated interest in the proposed
project.
SHPO CONSULTATION LETTER

Submit a draft consultation letter prepared by the qualied
researcher with the Cultural Resources Report to the State Water
Resources Control Board. A draft consultation letter template is
available for download on the State Water Board webpage at:
http://www.waterboards.ca.gov/water_issues/programs/
grants_loans/cwsrf_requirements.shtml
Copies of all documents mentioned above (project

description, map, phone log and letters sent to the
NAHC and Native American tribal organizations
or individuals and interested parties) must be
included in the Cultural Resources Report.
Contact Information: For more information related to the CWSRF Program
Cultural Resources and Requirments, please contact Mr. Ahmad Kashkoli at
916-341-5855 or Ahmad.Kashkoli@waterboards.ca.gov
waterboards.ca.gov
REVISED: JAN. 2014

Final EIR
4-318
September 2015
LetterCC:California State Water Resources Control Board Division of Financial

Assistance
CC-1
Comment is noted. In Chapter 1, Introduction, on page 1-5, the Draft EIR notes that the
Proposed Project may be financed in part by a Clean Water State Revolving Fund (CWSRF or
SRF) Loan, administered by the State Water Resources Control Board (SWRCB), Division of
Financial Assistance. As stated in the comment and in the Draft EIR, the CWSRF Program is
partially funded by the U.S. Environmental Protection Agency, and is subject to federal
environmental regulations. All applicants seeking CWSRF financing must comply with CEQA
and provide sufficient information so that the SWRCB can document compliance with federal
environmental laws. The SWRCB calls this federal compliance CEQA-Plus. The Draft EIR
has been prepared to meet the CEQA-Plus requirements in order to be eligible for CWSRF loan
funds. The letter provides enclosures and further guidance to further explain the CWSRF
Program environmental review process and the additional federal requirements. The comments
and guidance are appreciated and the MRWPCA intends to fully comply with the stated
requirements.
CC-2
The comment states that prior to a SRF financing commitment, projects are subject to
provisions of the Federal Endangered Species Act (FESA), and must obtain a Section 7
clearance from the United States Fish and Wildlife Service (USFWS), and/or the United States
Department of Commerce National Oceanic and Atmospheric Administration, National Marine
Fisheries Service (NMFS) for any potential effects to special status species. The MRWPCA
intends to fully comply with these requirements. See Sections 4.4 and 4.5 in the Draft EIR, as
revised in this Final EIR.
CC-3
See the response to comment CC-2 above. Sections 4.4 and 4.5 in the Draft EIR identify
Proposed Project effects from construction activities and indirect effects that may affect
federally listed threatened, endangered, or candidate species that are known, or have a
potential to occur in the project study area for each topic. Sections 4.4.2 and 4.5.2.1 of the Draft
EIR identifies the biological project study areas for fisheries and terrestrial/other aquatic
species. See also response to comment G-3 in this chapter for clarification about project study
area determinations. Applicable Mitigation Measures are identified to minimize, avoid or reduce
such effects in Sections 4.4 and 4.5 in the Draft EIR (Mitigation Measures BF-1, BF-2, and BT-1
through BT-6) as amended in this Final EIR. Specifically, additional mitigation measures and
amendments to Draft EIR mitigation measures are provided in the Summary section and in
Chapter 5, Changes to the Draft EIR. Additionally, information presented in the Draft EIR,
confirm the jurisdiction/responsibility of NMFS and that of the USFWS. The discussion provided
is consistent with the description in the Draft EIR Sections 4.4.2.2 and 4.4.3.1. Comments
regarding NMFS and USFWS responsibility for the administration of the FESA are
acknowledged.
CC-4
The comment notes that CWSRF projects must comply with federal laws pertaining to cultural
resources, specifically Section 106 of the National Historic Preservation Act (Section 106) and
that the State Water Board has responsibility for ensuring compliance with Section 106, and
must consult directly with the California State Historic Preservation Officer (SHPO). The
MRWPCA has retained a consultant that meets the Secretary of the Interior's Professional
Qualifications Standards and will work with the State Board to complete all required
consultation and application materials and processing.
CC-5
MRWPCA has retained a consultant and prepared mapping for the Area of Potential Effects
(APE), including construction and staging areas, and the depth of any excavation. The final
APE will comply with all applicable requirements regarding spatial dimensions and detail.

Final EIR
4-319
September 2015
CC-6
Federal environmental requirements pertinent to the Proposed Project under the CWSRF
Program are identified in this comment and the reader is directed to the complete list of all
federal
requirements
at
the
following
website:
http://www.waterboards.ca.gov/waterissues/programs/grantsloans/srf/docs/forms/applicationenvi
ronmentalpackage.pdf
The comments and guidance are appreciated and the MRWPCA intends to fully comply with
the stated requirements. The following specific requirements under the following categories are
noted in the comment letter:
A. Compliance with the Federal Clean Air Act: (a) Provide air quality studies that may have
been done for the Project; and (b) if the Project is in a nonattainment area or attainment area
subject to a maintenance plan; (i) provide a summary of the estimated emissions (in tons per
year) that are expected from both the construction and operation of the Project for each
federal criteria pollutant in a nonattainment or maintenance area, and indicate if the
nonattainment designation is moderate, serious, or severe (if applicable); (ii) if emissions are
above the federal de minimis levels, but the Project is sized to meet only the needs of current
population projections that are used in the approved State Implementation Plan for air quality,
quantitatively indicate how the proposed capacity increase was calculated using population
projections.
Chapter 4.3, Air Quality, states that the project partners intend to apply for a federal
Clean Water Act State Revolving Fund loan; therefore, the project proposed for funding in
the SRF loan application must comply with the Federal Clean Air Act. The North Central
Coast Air Basin is considered attainment or unclassified for all federally-regulated criteria
pollutants and is not subject to a maintenance plan with conformity requirements.
Therefore, the project proposed for funding in the SRF loan application would not be
subject to General Conformity compliance under the Federal Clean Air Act. Despite the
fact that the North Central Coast Air Basin is not subject to a maintenance plan with
conformity requirements, the SWRCB still requires submittal of construction and
operational emission calculations to demonstrate that the project conforms with the
federal standards. See the 2014 SRF Guidelines for Environmental Package included in
Comment CC, which requires the following documentation to support the Clean Air Act
federal coordination requirements:
Air quality modeling data
Complete air emissions chart
General conformity and/or air quality studies, as applicable
Compliance with the Federal Clean Air Act is discussed further in Section 4.3.3,
Regulatory Framework.
B. Compliance with the Coastal Zone Management Act: Identify whether the Project is
within a coastal zone and the status of any coordination with the California Coastal
Commission.
The Project Description in Chapter 2 and the Land Use Section of the Draft EIR
identify the project components within the coastal zone. The application for the SRF
funding will define status of coordination with the Coastal Commission. Letter AA of
this Final EIR identifies the staff comments on the Draft EIR from Coastal
Commission.
C. Protection of Wetlands: Identify any portion of the proposed Project area that should be
evaluated for wetlands or United States waters delineation by the United States Army Corps
of Engineers (USACE), or requires a permit from the USACE, and identify the status of
coordination with the USACE.

Final EIR
4-320
September 2015
Chapter 4.5, Biological Resources: Terrestrial, identifies the Project areas that have
been evaluated for wetlands or United States waters delineation in accordance with the
standards of the United States Army Corps of Engineers.
D. Compliance with the Farmland Protection Policy Act: Identify whether the Proposed
Project will result in the conversion of farmland. State the status of farmland (Prime,
Unique, or Local and Statewide Importance) in the project proposed for funding in the SRF
loan application area and determine if this area is under a Williamson Act Contract.
Chapter 4.12 contains the information needed to demonstrate compliance with the
Farmland Protection Policy Act. See the following pages in the Draft EIR:
4.12-9 through 4.12-10 for the environmental setting for agricultural resources,
4.12-30 through 4.12-33 for the methodology and assumptions of the impact
analysis (including No Impact determinations), and
4.12-34 through 4.12-36 for the relevant impact analysis.

E. Compliance with the Migratory Bird Treaty Act: List any birds protected under this act
that may be impacted by the Project and identify conservation measures to minimize
impacts.
Chapter 4.5, Biological Resources: Terrestrial, and the technical reports included in the
Draft EIR, provide compliance with the Migratory Bird Treaty Act, list any birds protected
under this act that may be impacted by the project proposed for funding in the SRF loan
application and identify mitigation measures to minimize impacts.
F. Compliance with the Flood Plain Management Act: Identify whether or not the Project
is in a Flood Management Zone and include a copy of the Federal Emergency Management
Agency flood zone maps for the area.
Section 4.11, Hydrology and Water Quality: Surface Water, describes the areas that
fall within flood hazard zones (see page 4.11-26 of the Draft EIR). Flood maps of the
Proposed Project area are provided in Figure 4.11-7 of the Draft EIR. MRWPCA
intends to provide FEMA Flood Insurance Rate Maps for all of the areas relevant to
the project proposed for funding in the SRF loan application.
G. Compliance with the Wild and Scenic Rivers Act: Identify whether or not any Wild and
Scenic Rivers would be potentially impacted by the Project and include conservation
measures to minimize such impacts.
Review of the references for the website above confirms that the project proposed for
funding in the SRF loan application is not within an area that would result in any impacts
on rivers governed by the Wild and Scenic Rivers Act.
CC-7
MRWPCA intends to fully comply with the stated requirements.

Final EIR
4-321
September 2015
CHAPTER 5
CHANGES TO THE DRAFT EIR
The following section provides revisions to the text of the Draft EIR, in amendment form. The revisions
are listed by page number. All additions to the text are presented in underline, and all deletions are shown
in strikeout.
CHANGES TO THE SUMMARY OF THE ENVIRONMENTAL IMPACT

REPORT
Page S-1
The following footnote reference and footnote have been added in response to comment
Q-5:
Footnote reference added to first sentence: This Environmental Impact Report (EIR) assesses the
1
potential environmental impacts of the Pure Water Monterey Groundwater Replenishment Project
proposed by .
Footnote at bottom of page S-1:
1
The term replenishment in the title of the project and elsewhere in the EIR was intended to maintain
consistency with the relevant water quality regulatory programs under the jurisdiction of the State Water
Resources Control Board (SWRCB) Division of Drinking Water (DDW) (i.e., this agency references the
requirements as the Groundwater Replenishment Regulations (or DPH-14-003E Groundwater
Replenishment Using Recycled Water)). Use of the word replenishment is not intended to be defined to
match the definition of artificial replenishment in the Seaside Groundwater Basin adjudication (Case
M66343, Decision, III., A., 3., March 27, 2006 at page 11) because as proposed, the project would not
offset the cumulative over production from the Seaside Basin by producers in the basin.
Page S-2
The following footnote reference has been added to the second sentence of the second
paragraph and the footnote shown below has been added to the bottom of the page in
response to comments M-3 and Q-14:
Footnote reference added to second sentence of second paragraph: The water would then be
used for two purposes: replenishment of the of the Seaside Groundwater Basin2
Footnote at bottom of page S-2:
2
A portion of the Seaside Area Subbasin of the Salinas Valley Groundwater Basin as defined by the
Department of Water Resources (DWR) that is referred to herein as Seaside Groundwater Basin or
Seaside Basin.

Final EIR
5-1
September 2015
Chapter 5. Changes to the Draft EIR
Page S-5
The following text has been inserted at the end of Section S.5 in response to comment H22:
The following sections provide an overview of the conclusions of the Alternatives to the Proposed Project
analyses.
Conclusion of Alternatives Analysis

This section summarizes the comparative environmental analysis of the No Project Alternative to the
Proposed Project and also discusses several combinations of alternatives that were found to reduce
environmental impacts while still meeting most of the project objectives. These are called Alternative A,
Alternative B, and Alternative C in Table 6-6 of the Draft EIR for brevity purposes.
Alternative A: Reduced Seaside Basin Replenishment and Alternative Monterey Pipeline
The Reduced Seaside Basin Replenishment Alternative would reduce the amount of water for Seaside
Basin replenishment by 500 AFY compared to the Proposed Project (i.e., 3,000 AFY rather than 3,500
AFY of purified recycled water would be produced, conveyed to, and injected into the Seaside Basin, for
later extraction by CalAm). The need to divert source waters would be reduced by approximately 600
AFY which could be achieved by eliminating one or more source water diversion sites, or by constructing
and operating all of the source water diversions, but operating them with a lower total diversion amount.
If the Reduced Seaside Basin Replenishment Alternative were combined with the Alternative Monterey
Pipeline (i.e., rather than the Proposed Transfer and Monterey Pipelines), numerous other significant
construction impacts would be reduced due to reduced construction areas and activities, and the
Proposed Project may be implemented more quickly, better meeting the project timeframe objective.
Table 6-6 of the Draft EIR provides an overview of environmental impacts of this combined alternative
(called Alternative A) compared to the Proposed Project.
Alternative B: Reduced Source Water Alternative #2 (No Tembladero Slough) and Alternative
Monterey Pipeline
Reduced Source Water Alternative # 2 was found to avoid the significant and unavoidable noise impact at
the Tembladero Slough diversion due to exceedances of the Countys noise level ordinance; however,
the alternative would not meet the project objectives as fully as the Proposed Project. Specifically, the
Reduced Source Water Alternative #2 would only provide up to 5,200 AFY for the proposed Crop
Irrigation component in some drought years (compared to up to 5,900 AFY under the Proposed Project).
If the Reduced Source Water Alternative #2 was combined with the Alternative Monterey Pipeline (i.e.,
rather than the Proposed Transfer and Monterey Pipeline), numerous other significant construction
impacts would be reduced due to reduced construction areas and activities. Because the Alternative
Monterey Pipeline avoids the Coastal Zone, it may be implemented more quickly than the Proposed
Monterey Pipeline, better meeting the project timeframe objective. Table 6-6 of the Draft EIR provides an
overview of environmental impacts of this combined alternative (called Alternative B) compared to the
Proposed Project.
Alternative C: Reduced Source Water Alternative #7 (Salinas Source Waters Only) and Alternative
Monterey Pipeline
Reduced Source Water Alternative #7 (Salinas Source Waters Only) was found to avoid the significant
and unavoidable noise impact at the Tembladero Slough Diversion, in addition to reducing environmental
impacts related to source water diversions from surface waters, such as changes in flow, induced water
level changes, and direct and indirect impacts on biological resources (albeit the latter would be lessthan-significant under the Proposed Project). The Reduced Source Water Alternative #7 would not meet
the Crop Irrigation objective to the extent that the Proposed Project would; in fact it would provide very
little or no augmentation of the existing supplies to the CSIP area.
If the Reduced Source Water Alternative #7 was combined with the Alternative Monterey Pipeline (i.e.,
rather than both the Proposed Transfer and Monterey Pipelines), numerous other significant construction
impacts would be reduced due to reduced construction areas and activities. Because the Monterey
Pipeline avoids the Coastal Zone, it may be implemented more quickly than the Proposed Project, better
Final EIR
5-2
September 2015
meeting the project timeframe objective. Table 6-6 of the Draft EIR provides an overview of environmental
impacts of this combined alternative (called Alternative C) compared to the Proposed Project.
Environmentally Superior Alternative

The CEQA Guidelines (Section 15126.6(e)(2)) require that an environmentally superior alternative be
identified among the alternatives considered. According to CEQA Guidelines section 15126.6(e), if the
environmentally superior alternative is the no project alternative, the EIR shall also identify an
environmentally superior alternative among the other alternatives. The environmentally superior
alternative is generally defined as the alternative that would result in the fewest adverse environmental
impacts on the project site and surrounding area.
Table 6-3 of the Draft EIR presents a comparison of impacts from eliminating each of the proposed new
source waters. Table 6-4 of the Draft EIR presents a comparison of impacts of the Product Water
Conveyance Options. Table 6-5 of the Draft EIR presents a comparison of impacts of the Proposed
CalAm Distribution System: Transfer and Monterey Pipelines to the Alternative Transfer and Monterey
Pipelines. Table 6-6 of the Draft EIR presents a comparison of impacts between the Proposed Project,
the No Project Alternative, the Reduced Seaside Basin Replenishment Alternative, Reduced Source
Water Alternative #2 (No Tembladero Slough) plus the Alternative Monterey Pipeline, and the Reduced
Source Water Alternative #7 (No Surface Water Diversions) plus the Alternative Monterey Pipeline.
Of the alternatives considered, the No Project Alternative would eliminate all the identified significant
impacts, but would not attain any of the project objectives. All of the impacts of the Proposed Project can
be reduced to less-than-significant levels with mitigation except for significant and unavoidable noise
impacts associated with construction of the Tembladero Slough Diversion and nighttime construction of
the CalAm Distribution System: Monterey Pipeline. The Reduced Source Water #2 (No Tembladero
Slough) would eliminate the significant and unavoidable noise impact associated with construction at that
site. The Alternative Monterey Pipeline would not necessarily eliminate the significant and unavoidable
noise impact from nighttime construction of the Monterey Pipeline; however, that alternative would
eliminate the need for the Transfer Pipeline, which would eliminate all impacts associated with
construction of the Transfer Pipeline. Accordingly, other than the No Project Alternative, the
Environmentally Superior Alternative would be the Reduced Source Water (No Tembladero Slough)
Alternative combined with the Alternative Monterey Pipeline.
Pages S-7 through S-24 Table S-1 has been revised as shown on the following pages in response to
comments received on the Draft EIR:

Final EIR
5-3
September 2015

Final EIR
5-4
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement
Salinas Pump Station
Treatment Facilities at Regional

Treatment Plant
Table S-1Revised
Summary of Project-Level Impacts and Mitigation Measures
Mitigation Measures
Aesthetics (AE)
AE-1: Construction Impacts on Scenic Views,
Scenic Resources and Visual Quality of the
Surrounding Areas. Proposed Project construction
would not result in substantial effects on scenic views,
scenic resources or the visual character of the areas
surrounding Proposed Project facilities.
AE-2: Construction Impacts due to Temporary
Light and Glare. Proposed Project construction could
result in substantial, temporary sources of light or
glare.
LS
LS
NI
NI
LS
NI
LS
NI
NI
LS
LS
LS
NI
LS
LS
NI
LS
NI
LS
LSM
LS
NI
LS
LSM
LS
LSM
AE-3: Degradation of Visual Quality of Sites and

Surrounding Areas. Proposed Project components
would not result in a substantial degradation of the
visual character of the project area and its
surroundings.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
NI
LS*
AE-4: Impacts due to Permanent Light and Glare

during Operations. Operation of Proposed Project
facilities may result in a substantial new source of light
or glare that would adversely affect day or nighttime
views in the area.
NI
NI
NI
NI
NI
NI
LS
LSM
LSM
LSM
NI
NI
LSM

Final EIR
5-5
None required.
Mitigation Measure AE-2: Minimize Construction Nighttime Lighting. (Applies to the Injection Well Facilities Site and CalAm Distribution
System: Monterey Pipeline). As part of its contract specifications, MRWPCA shall require its construction contractors to implement site-specific
nighttime construction lighting measures for nighttime construction at the proposed Injection Well Facilities site. The measures shall, at a
minimum, require that lighting be shielded, directed downward onto work areas to minimize light spillover, and specify that construction lighting
use the minimum wattage necessary to provide safety at the construction sites. MRWPCA shall ensure these measures are implemented at all
times during nighttime construction at the Injection Well Facilities site and for the duration of all required nighttime construction activity at this
location.
None required. The following mitigation measure is recommended will be adopted by the MRWPCA due to City of Seaside comments on the
Draft EIR and Notice of Preparation:
Mitigation Measure AE-3: Provide Aesthetic Screening for New Above-Ground Structures. (Applies to the following project components:
Product Water Conveyance Coastal and RUWAP Booster Pump Station and Injection Well Facilities). Proposed above-ground features at the
Coastal option of the Booster Pump Station and Injection Well Facilities (at a minimum, at the well clusters and back-flush basin), shall be
designed to minimize visual impacts by incorporating screening with vegetation, or other aesthetic design treatments, subject to review and
approval of the City of Seaside which has also requested that the buildings be designed with Monterey/Mission style architecture to match the
design of the structures that have been built on the Santa Margarita ASR site and the Seaside Middle School ASR Site. All pipelines placed
within the City of Seaside on General Jim Moore Boulevard shall be placed underground. MRWPCA shall coordinate with the City of Seaside on
the location of injection wells and booster pumps in order to reduce conflicts with future commercial/residential development opportunities.
Screening and aesthetic design treatments at the RUWAP Booster Pump Station component shall be subject to review and approval by the City
of Marina. Use of standard, commercial-grade, chain link fencing and barbed wire should be discouraged.
Mitigation Measure AE-4: Exterior Lighting Minimization. (Applies to the following project components: Product Water Conveyance Booster
Pump Station - (both Options) and Injection Well Facilities) To prevent exterior lighting from affecting nighttime views, the design and operation
of lighting at the Product Water Conveyance Booster Pump Station - RUWAP and Coastal Options and Injection Well Facilities, shall adhere to
the following requirements:
Use of low-intensity street lighting and low-intensity exterior lighting shall be required. No floodlights shall be allowed at night within the
City of Marina.
Lighting fixtures shall be cast downward and shielded to prevent light from spilling onto adjacent offsite uses.
Lighting fixtures shall be designed and placed to minimize glare that could affect users of adjacent properties, buildings, and roadways.
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
Air Quality and Greenhouse Gas (AQ)
AQ-1: Construction Criteria Pollutant Emissions.

Construction of the Proposed Project would result in
emissions of criteria pollutants, specifically PM10, that
may conflict with or obstruct implementation of the
applicable air quality plan and may violate an air quality
standard or contribute substantially to an existing or
projected air quality violation in a region that is nonattainment under State ambient air quality standards.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
AQ-2: Construction Exposure of Sensitive

Receptors to Pollutant Emissions. Construction of
the Proposed Project would not expose sensitive
receptors to substantial pollutant concentrations.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
AQ-3: Construction Odors. Construction of the

Proposed Project would not create objectionable odors
affecting a substantial number of people.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
AQ-4C: Construction Greenhouse Gas Emissions.

Construction of the Proposed Project would generate
greenhouse gas emissions, either directly or indirectly,
but would not make a considerable contribution to
significant cumulative impacts due to greenhouse gas
emissions and the related global climate change
impacts.
Mitigation Measure AQ-1: Construction Fugitive Dust Control Plan. (Applies to all Project Component Sites where ground disturbance would
occur.) The following standard Dust Control Measures shall be implemented during construction to help prevent potential nuisances to nearby
receptors due to fugitive dust and to reduce contributions to exceedances of the state ambient air quality standards for PM10, in accordance with
MBUAPCDs CEQA Guidelines.
Water all active construction areas at least twice daily as required with water (preferably from non-potable sources to the extent
feasible); frequency should be based on the type of operation, soil, and wind exposure and minimized to prevent wasteful use of
water.
Prohibit grading activities during periods of high wind (over 15 mph).
Cover all trucks hauling soil, sand, and other loose materials and require trucks to maintain at least 2 feet of freeboard.
1
LSM* Sweep daily (with water sweepers) all paved access roads, parking areas, and staging areas at construction sites.
Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent public streets.
Enclose, cover, or water daily exposed stockpiles (dirt, sand, etc.).
Replant vegetation in disturbed areas as quickly as possible.
Wheel washers shall be installed and used by truck operators at the exits of the construction sites to the AWT Facility site, the Injection
Well Facilities, and the Booster Pump Station.
Post a publicly visible sign that specifies the telephone number and person to contact regarding dust complaints. This person shall
respond to complaints and take corrective action within 48 hours. The phone number of the MBUAPCD shall also be visible to ensure
compliance with MBUAPCD rules.
LS
None required.
LS
None required.
LS
None required.
Under Impact AQ-1, the implementation of each component when looked at individually would not a have a significant impact; it is only when all components are implemented together (with overlapping construction schedules) that a significant impact
would occur triggering Mitigation Measures to reduce the impact to a less than significant (LS).

Final EIR
5-6
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Impact Statement
Salinas Treatment
Recovery

Treatment Plant
Table S-1Revised
Mitigation Measures
AQ-5: Operational Air Quality Violation. Operation of
the Proposed Project would result in criteria pollutant
emissions, but would not violate air quality standards or
contribute substantially to an existing or projected air
quality violation.
AQ-6: Operational Criteria Pollutant Emissions.
Operation of the Proposed Project would result in a net
increase of criteria pollutants in a region that is nonattainment under State ambient air quality standards,
but the increase would not be cumulatively
considerable.
AQ-7: Operational Exposure of Sensitive Receptors
to Pollutants. Operation of the Proposed Project
would not expose sensitive receptors to substantial
pollutant concentrations.
AQ-8: Operational Odors. Operation of the Proposed
Project would not create objectionable odors affecting
a substantial number of people.
AQ-9C: Operational Greenhouse Gas Emissions.
Operation of the Proposed Project would generate
greenhouse gas emissions, either directly or indirectly.
These emissions would not exceed significance
thresholds such that they would result in a
considerable contribution to significant cumulative
impacts of greenhouse gas emissions and the related
global climate change impacts. In addition, the
Proposed Project would not conflict with applicable
plan, policy or regulation adopted for the purpose of
reducing greenhouse gas emissions.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
NI
LS
NI
NI
NI
NI
NI
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
Biological Resources: Fisheries (BF)
BF-1: Habitat Modification Due to Construction of

Diversion Facilities. Construction of the proposed
Reclamation Ditch and Tembladero Slough diversions
could indirectly result in habitat modifications for
endangered or threatened fish species as a result of
construction activities and dewatering the construction
sites.

Final EIR
NI
NI
LSM
LSM
LS
NI
NI
NI
NI
NI
NI
5-7
NI
LSM
Mitigation Measure BT-1a (see below under Biological Resources: Terrestrial, Impact BT-1)
Mitigation Measure BF-1a: Construction during Low Flow Season. (Applies to Blanco Drain, Reclamation Ditch and Tembladero Slough
Diversions) Implement Mitigation Measure BT-1a.Conduct construction of diversion facilities, including the directional drilling under the Salinas
River, during periods of low flow outside of the SCCC steelhead migration periods, i.e. between June and November, which would be outside of
the adult migration period from December through April and outside of the smolt migration period from March through May.
Mitigation Measure BF-1b: Relocation of Aquatic Species during Construction. (Applies to Reclamation Ditch and Tembladero Slough
Diversions).
Conduct pre-construction surveys to determine whether tidewater gobies or other fish species are present, and if so, implement appropriate
measures in consultation with applicable regulatory agencies, which may include a program for capture and relocation of tidewater gobies to
suitable habitat outside of work area during construction. Pre-construction surveys shall be consistent with requirements and approved protocols
of applicable resource agencies and performed by a qualified fisheries biologist.
Mitigation Measure BF-1c: Tidewater Goby and Steelhead Impact Avoidance and Minimization. (Applies to Reclamation Ditch and
Tembladero Slough Diversions)
To ensure compliance with the federal Endangered Species Act (FESA) and the California Endangered Species Act (CESA), consultation with
NFMS/NOAA, USFWS, and CDFW shall be conducted as required, and any necessary take permits or authorizations would be obtained. If
suitable habitat for tidewater goby (Tembladero Slough) and steelhead cannot be avoided, any in-stream portions of each project component
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
(where the Proposed Project improvements require in-stream work) shall be dewatered/ diverted. A dewatering/diversion plan shall be prepared
and submitted to NMFS, USFWS, and CDFW for review and approval. Specific plan elements are noted below and will be refined through
consultation with USFWS, NMFS and CDFW:
Required Pre-Construction surveys identified in Mitigation Measure BF-1b shall be consistent with requirements and approved protocol
of applicable resource agencies and performed by a qualified fisheries biologist.
All dewatering/diversion activities shall be monitored by a qualified fisheries biologist. The fisheries biologist shall be responsible for
capture and relocation of fish species out of the work area during dewatering/diversion installation.
The project proponents shall designate a qualified representative to monitor on-site compliance of all avoidance and minimization
measures. The fisheries biologist shall have the authority to halt any action which may result in the take of listed species.
Only USFWS/NMFS/CDFW-approved biologists shall participate in the capture and handling of listed species subject to the conditions
in the Incidental Take Permits as noted above.
No equipment shall be permitted to enter wetted portions of any affected drainage channel. All equipment operating within streams shall
be in good conditions and free of leaks.
Spill containment shall be installed under all equipment staged within stream areas and extra spill containment and clean up materials
shall be located in close proximity for easy access.
Work within and adjacent to streams shall not occur between November 1 and June 1 unless otherwise approved by NMFS and the
CDFW.
If project activities could degrade water quality, water quality sampling shall be implemented to identify the pre-project baseline, and to
monitor during construction for comparison to the baseline. If water is to be pumped around work sites, intakes shall be completely
screen with wire mesh not larger than five millimeters to prevent animals from entering the pump system.
If any tidewater goby or steelhead are harmed during implementation of the project, the project biologist shall document the
circumstances that led to harm and shall determine if project activities should cease or be altered in an effort to avoid further harm to
the species.
Water turbidity shall be monitored by a qualified biologist or water quality specialist during all instream work. Water turbidity shall be
tested daily at both an upstream location for baseline measurement and downstream to determine if project activities are altering water
turbidity. Turbidity measures shall be taken within 50 feet of construction activities to rule out other outside influences. Additional
turbidity testing shall occur if visual monitoring indicates an increased in turbidity downstream of the work area. If turbidity levels
immediately downstream of the project rise to more than 20 NTUs (Nephelometric Turbidity Units) above the upstream (baseline)
turbidity levels, all construction shall be halted and all erosion and sediment control devices shall be thoroughly inspected for proper
function, or shall be replaced with new devices to prevent additional sediment discharge into streams.
The above mitigation is subject to review and approval for CESA and FESA requirements by approving agencies as identified above and may
be modified to further reduce, avoid or minimize impacts to species.
BF-2: Interference with Fish Migration. Operation of

the Proposed Project would result in changes in stream
flows that may interfere with fish migration in the
Salinas River and Reclamation Ditch.
LS
LS
LSM
LS
LS
NI
NI
NI
NI
NI
NI
NI
LSM
Mitigation Measure BF-2a: Maintain Migration Flows. (Applies to the Reclamation Ditch Diversion) Implement BF-1a, BF-1b, and BF1c. Operate diversions to maintain steelhead migration flows in the Reclamation Ditch based on two criteria one for upstream adult passage in
Jan-Feb-Mar and one for downstream juvenile passage in Apr-May. For juvenile passage, the downstream passage shall have a flow trigger in
both Gabilan Creek and at the Reclamation Ditch, so that if there is flow in Gabilan Creek that would allow outmigration, then the bypass flow
requirements, as measured at the San Jon Gage of the Reclamation Ditch, shall be applied (see Hagar Environmental Science, Estimation of
Minimum Flows for Migration of Steelhead in the Reclamation Ditch, February 27, 2015, in Appendix G-2, of thise Draft EIR and Schaaf &
Wheeler, Fish Passage Analysis: Reclamation Ditch at San Jon Rd. and Gabilan Creek at Laurel Rd. July 15, 2015 in Appendix CC of this Final
EIR). If there is no flow in Gabilan Creek, then only the low flow (minimum bypass flow requirement as proposed in the project description) shall
be applied, and these flows for the dry season at Reclamation Ditch as measured at the San Jon USGS gage shall be met. Note: If there is no
flow gage in Gabilan Creek, then downstream passage flow trigger shall be managed based on San Jon Road gage and flows.
Alternately, as the San Jon weir located at the USGS gage is considered a barrier to steelhead migration and the bypass flow requirements have
been developed to allow adult and smolt steelhead migration to have adequate flow to travel past this obstacle, if the weir were to be modified to
allow steelhead passage, the mitigation above would not have to be met. Therefore, alternate Mitigation Measure BF-2a has been developed, as
follows:
Mitigation Measure Alternate BF-2a: Modify San Jon Weir. (Applies to the Reclamation Ditch Diversion) Construct modifications to the existing

Final EIR
5-8
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
San Jon weir to provide for steelhead passage. Modifications could include downstream pool, modifications to the structural configuration of the
weir to allow passage or other construction, and improvements to remove the impediment to steelhead passage defined above.
The above mitigation is subject to compliance with CESA and FESA and appropriate approving agencies may modify the above mitigation to
further reduce, avoid, or minimize impacts to species.
BF-3: Reduction in Fish Habitat or Fish Populations
Due to Project Operations. Operation of the
Proposed Project diversions would not reduce the
habitat of a fish species or substantially affect fish
populations.
LS
LS
LS
LS
LS
NI
NI
NI
NI
LSM
LSM
LSM
LSM
LSM
NI
LSM
LSM
NI
NI
NI
LS
None required.
Biological Resources: Terrestrial (BT)

BT-1: Construction Impacts to Special-Status
Species and Habitat. Proposed Project construction
may adversely affect, either directly or through habitat
and their habitat within the Project Study Area.
BT-2: Construction Impacts to Sensitive Habitats.

Proposed Project construction may adversely affect
other sensitive natural communities) within the Project
Study Area.

Final EIR
LSM
NI
NI
LSM
LSM
LSM
NI
NI
LS
LSM
LSM LSM
LS
NI
5-9
LSM
LSM
LSM See complete text following this table.
LSM
Mitigation Measure BT-1a (see above under Biological Resources: Terrestrial, Impact BT-1)
Mitigation Measure BT-2a: Avoidance and Minimization of Impacts to Riparian Habitat and Wetland Habitats. (Applies to Reclamation Ditch,
Tembladero Slough Diversion, Blanco Drain Diversion, and Product Water Conveyance: Coastal Alignment Option) Implement Mitigation
Measure BT-1a. When designing the facilities at these component sites, the MRWPCA shall site and design project features to avoid impacts to
the riparian and wetland habitats shown in Attachment 8 of Appendix H and Appendix I, including direct habitat removal and indirect hydrology
and water quality impacts, to the greatest extent feasible while taking into account site and engineering constraints. To protect this sensitive
habitat during construction, the following measures shall be implemented:
Place construction fencing around riparian and wetland habitat (i.e., areas adjacent to or nearby the Proposed Project construction) to be
preserved to ensure construction activities and personnel do not impact this area.
All proposed lighting shall be designed to avoid light and glare into the riparian and wetland habitat. Light sources shall not illuminate these
areas or cause glare.
In the event that full avoidance is not possible and a portion or all of the riparian and wetland habitat would be impacted, the following
minimization measures shall be implemented:
Permanently impacted riparian and wetland habitat shall be mitigated at no less than a 12:1 replacement-to-loss ratio through restoration
and/or preservation. The final mitigation amounts for both temporary and permanent impacts to riparian and wetland habitat shall be determined
during the design phase but cannot be less than 2:1 for permanent impacts and 1:1 for temporary impacts, and must be approved by the
relevant permitting agencies (USACOE, RWQCB, CDFW, and the entity issuing any Coastal Development Permit). The preserved mitigation
land shall be managed to improve wetland and riparian conditions compared to existing conditions. It is expected that the mitigation can occur
within the Locke Paddon Lake watershed, along the Tembladero Slough, and within the Salinas River corridor near the Blanco Drain near where
impacts may occur. A Habitat Mitigation and Monitoring Plan (HMMP) shall be prepared by a qualified biologist to mitigate for impacts to riparian
and wetland habitat. The HMMP shall outline the details of a riparian and wetland habitat restoration plan, including but not limited to, planting
plan, success criteria, monitoring protocols to determine if the success criteria have been met, adaptive management protocols in the case that
the success criteria are not met, and funding assurances. Plantings and revegetation conducted in compliance with this mitigation measure shall
be monitored for a minimum of three years after project completion.
Mitigation Measure BT-2b: Avoidance and Minimization of Impacts to Central Dune Scrub Habitat. (Applies to CalAm Distribution System:
Monterey Pipeline) When designing the Monterey Pipeline, the project proponents shall site and design project features to avoid impacts to the
central dune scrub habitat shown in Attachment 8 of Appendix H, including direct habitat removal, to the greatest extent feasible while taking into
account site and engineering constraints. To protect this sensitive habitat during construction, the following measures shall be implemented:
Place construction fencing around central dune scrub habitat to be preserved to ensure construction activities and personnel do not
impact this area.
All proposed lighting shall be designed to avoid light and glare into the central dune scrub habitat. Light sources shall not illuminate
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
central dune scrub habitat areas or cause glare.
If full avoidance is not possible and a portion or all of the central dune scrub habitat would be impacted, the following minimization
measures shall be implemented:
Approximately 2.7 acres of central dune scrub habitat could be impacted by the project. Impacted central dune scrub habitat shall be mitigated at
a 1:1 replacement-to-loss ratio through restoration and/or preservation. The final mitigation amounts shall be determined during the design
phase. It is expected that the mitigation can occur onsite or within the immediate vicinity. A Habitat Mitigation and Monitoring Plan (HMMP) shall
be prepared by a qualified biologist to mitigate for impacts to central dune scrub habitat. The HMMP shall outline the details of a central dune
scrub habitat restoration plan, including but not limited to, planting plan, success criteria, monitoring protocols to determine if the success criteria
have been met, adaptive management protocols if success criteria are not met, and funding assurances.
Mitigation Measure BT-2c: The project proponents in coordination with the contractor shall prepare and implement a Frack-Out Plan to avoid or
reduce accidental impacts resulting from horizontal directional drilling (HDD) beneath the Salinas River. The Frack-Out Plan shall address spill
prevention, containment, and clean-up methodology in the event of a frack out. The proposed HDD component of the Blanco Drain diversion
shall be designed and conducted to minimize the risk of spills and frac-out events. The Frac-Out Plan shall be prepared and submitted to United
States Fish and Wildlife Services, California Department of Fish and Wildlife, National Marine Fisheries Services, and the Regional Water
Quality Control Board prior to commencement of HDD activities for the Blanco Drain Diversion construction. The following are typical contents of
a Frac-Out Plan:
Project description, including details of the HDD design and operations
Site description and existing conditions
Potential modes of HDD failure and HDD failure prevention and mitigation
Frac-out prevention measures (including for example, geotechnical investigations, planning for appropriate depths based on those
investigations, presence of a qualified engineer during drilling to monitor the drilling process, live adjustments to the pace of drill
advancement to ensure sufficient time for cutting and fluid circulation and to prevent or minimize plugging, maintaining the minimum
drilling pressure necessary to maintain fluid circulation, etc.)
Monitoring requirements (for example, monitoring pump pressure circulation rate, ground surface and surface water inspection, advancing
the drill only during daytime hours, on-site biological resource monitoring by a qualified biologist)
Response to accidental frac-out (including stopping drilling, permitting agency notification, surveying the area, containing the frac-out
material, contacting the project biological monitor to identify and relocate species potentially in the area, turbidity monitoring, procedures
for clean-up and mitigation of hazardous waste spill materials, preparation of documentation of the event, etc.)
Coordination plan and contact list of key project proponents, biological monitor, and agency staff in the event of an accidental frac-out
event.
BT-3: Construction Impacts to Movement of Native
Wildlife and Native Wildlife Nursery Sites. Proposed
Project construction would not adversely affect native
wildlife corridors and wildlife nursery sites.
BT-4: Construction Conflicts with Local Policies,
Ordinances, or Approved Habitat Conservation
Plan. Proposed Project construction would potentially
conflict with local policies or ordinances protecting
biological resources. A conflict may occur if the HMP
plant species within the Proposed Project component
sites on the former Fort Ord that do not require a take
authorization from the Service or CDFW are impacted,
and seed salvage is not conducted. There are no
approved HCPs applicable to the Proposed Project.

Final EIR
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LSM
LS
LSM
LS
LSM
LS
LS
5-10
LS
LS
LS
LSM
None required.
Mitigation Measure BT-4. HMP Plant Species Salvage. (Applies to Product Water Conveyance: RUWAP and Coastal Alignment Options, and
Injection Well Facilities site within the former Fort Ord only) For impacts to the HMP plant species within the Project Study Area that do not
require take authorization from USFWS or CDFW, salvage efforts for these species shall be evaluated by a qualified biologist per the
requirements of the HMP and BO. A salvage plan shall be prepared and implemented by a qualified biologist, which shall would include, but is
not limited to: a description and evaluation of salvage opportunities and constraints; a description of the appropriate methods and protocols of
salvage and relocation efforts; identification of relocation and restoration areas; and identification of qualified biologists approved to perform the
salvage efforts, including the identification of any required collection permits from USFWS and/or CDFW. Where proposed, seed collection shall
occur from plants within the Project Study Area and topsoil shall be salvaged within occupied areas to be disturbed. Seeds shall be collected
during the appropriate time of year for each species by qualified biologists. At the time of seed collection, a map shall also be prepared that
identifies the specific locations of the plants for any future topsoil preservation efforts. The collected seeds shall be used to revegetate
temporarily disturbed construction areas and reseeding and restoration efforts on- or off-site, as determined appropriate in the salvage plan.
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
BT-5: Operational Impacts to Special-Status
Species. Proposed Project operations would not
adversely affect, either directly or through habitat
and their habitat.
BT-6: Operational Impacts to Sensitive Habitats.
Proposed Project operations may adversely affect
other sensitive natural communities) within and
adjacent to the Project Study Area.
BT-7: Operational Impacts to Movement of Native
Wildlife and to Native Wildlife Nursery Sites.
Proposed Project operations would not adversely affect
native wildlife corridors and wildlife nursery sites.
BT-8: Operational Conflicts with Local Policies,
Ordinances, or approved Habitat Conservation
Plan. Proposed Project operations would not conflict
with local policies or ordinances protecting biological
resources.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
Mitigation Measure BT-6. Implementation of Mitigation Measures BT-1a for Avoidance and Minimization of Operational Impacts to Sensitive
Habitat (Applies to Applies to Reclamation Ditch Diversion, Tembladero Slough Diversion, Blanco Drain Diversion, and CalAm Distribution
System: Monterey Pipeline) During operation and maintenance activities, implementation of Mitigation Measures BT-1a, which avoid and
minimize impacts through implementing construction best management practices and monitoring, would reduce potential impacts to sensitive
habitat to a less-than-significant level.
LS
LS
LS
LS
LS
LS
NI
LS
LS
LS
NI
LSM
LSM
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
Cultural and Paleontological Resources (CR)
CR-1: Construction Impacts on Historic Resources.

Proposed Project construction may result in a
substantial adverse change in the significance of a
known historic resource as defined in 15064.5 of the
CEQA Guidelines or historic properties pursuant to 36
CFR 800.5.

Final EIR
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
5-11
LSM
LSM
Mitigation Measure CR-1: Avoidance and Vibration Monitoring for Pipeline Installation in the Presidio of Monterey Historic District, and
Downtown Monterey. (Applies to portion of the CalAm Distribution System: Monterey Pipeline) CalAm shall construct the section of the Monterey
Pipeline located on Stillwell Avenue within the Presidio of Monterey Historic District and within W. Franklin Street in downtown Monterey as close
as possible to the centerlines of these streets to: (1) avoid direct impacts to the historic Presidio Entrance Monument, and (2) reduce impacts
from construction vibration to below the 0.12 inches per second (in/sec) peak particle velocity vibration PPV) threshold. If CalAm determines that
the pipeline cannot be located near the centerline of these street segments due to traffic concerns or existing utilities, the historic properties
identified on Table 4.6-2 of this EIR shall be monitored for vibration during pipeline construction, especially during the use of jackhammers and
vibratory rollers. If construction vibration levels exceed 0.12 in/sec PPV, construction shall be halted and other construction methods shall be
employed to reduce the vibration levels below the standard threshold. Alternative construction methods may include using concrete saws
instead of jackhammers or hoe-rams to open excavation trenches, the use of non-vibratory rollers, and hand excavation. If impact sheet pile
installation is needed (i.e., for horizontal directional drilling or jack-and-bore) within 80 feet of any historical resource or within 80 feet of a historic
district, CalAm shall monitor vibration levels to ensure that the 0.12-in/sec PPV damage threshold is not exceeded. If vibration levels exceed the
applicable threshold, the contractor shall use alternative construction methods such as vibratory pile drivers.
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
CR-2: Construction Impacts on Archaeological

Resources or Human Remains. Proposed Project
construction may result in a substantial adverse
change in the significance of one known archaeological
resource and to unknown archaeological resources
during construction and/or encounter unknown human
remains.

Final EIR
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM LSM
5-12
LSM
LSM
Mitigation Measure CR-2a: Archaeological Monitoring Plan. (Applies to the segment of the CalAm Distribution Pipeline through the Presidio of
Monterey and along W. Franklin Street and to the Lake El Estero Diversion Site) Each of the project proponents shall contract a qualified
archaeologist meeting the Secretary of the Interiors Qualification Standard (Lead Archaeologist) to prepare and implement an Archaeological
Monitoring Plan, and oversee and direct all archaeological monitoring activities during construction. Archaeological monitoring shall be
conducted for all subsurface excavation work within 100 feet of Presidio #2 in the Presidio of Monterey, in downtown Monterey on W. Franklin
Street between High and Figueroa Streets; and at potentially sensitive archaeological sites at Lake El Estero. At a minimum, the Archaeological
Monitoring Plan shall:
Detail the cultural resources training program that shall be completed by all construction and field workers involved in ground disturbance;
Designate the person(s) responsible for conducting monitoring activities, including Native American monitor(s), if deemed necessary;
Establish monitoring protocols to ensure monitoring is conducted in accordance with current professional standards provided by the California
Office of Historic Preservation;
Establish the template and content requirements for monitoring reports;
Establish a schedule for submittal of monitoring reports and person(s) responsible for review and approval of monitoring reports;
Establish protocols for notifications in case of encountering cultural resources, as well as methods for evaluating significance, developing and
implementing a plan to avoid or mitigate significant resource impacts, facilitating Native American participation and consultation, implementing a
collection and curation plan, and ensuring consistency with applicable laws including Section 7050.5 of the California Health and Safety Code
and Section 5097.98 of the Public Resources Code;
Establish methods to ensure security of cultural resources sites;
Describe the appropriate protocols for notifying the County, Native Americans, and local authorities (i.e. Sheriff, Police) should site looting and
other illegal activities occur during construction with reference to Public Resources Code 5097.99.
During the course of the monitoring, the Lead Archaeologist may adjust the frequencyfrom continuous to intermittentof the monitoring based
on the conditions and professional judgment regarding the potential to encounter resources. If archaeological materials are encountered, all soil
disturbing activities within 100 feet of the find shall cease until the resource is evaluated. The Lead Archaeologist shall immediately notify the
relevant Proposed Project proponent of the encountered archaeological resource. The Lead Archaeologist shall, after making a reasonable effort
to assess the identity, integrity, and significance of the encountered archaeological resource, present the findings of this assessment to the lead
agency, or CPUC, for the CalAm Distribution Pipeline. In the event archaeological resources qualifying as either historical resources pursuant to
CEQA Section 15064.5 or as unique archaeological resources as defined by Public Resources Code 21083.2 are encountered, preservation in
place shall be the preferred manner of mitigation.
If preservation in place is not feasible, the applicable project proponent(s) shall implement an Archaeological Research Design and Treatment
Plan (ARDTP). The Lead Archaeologist, Native American representatives, and the State Historic Preservation Office designee shall meet to
determine the scope of the ARDTP. The ARDTP will identify a program for the treatment and recovery of important scientific data contained
within the portions of the archaeological resources located within the project Area of Potential Effects; would preserve any significant historical
information obtained; and will identify the scientific/historic research questions applicable to the resources, the data classes the resource is
expected to possess, and how the expected data classes would address the applicable research questions. The results of the investigation shall
be documented in a technical report that provides a full artifact catalog, analysis of items collected, results of any special studies conducted, and
interpretations of the resource within a regional and local context. All technical documents shall be placed on file at the Northwest Information
Center of the California Historical Resources Information System.
Mitigation Measure CR-2b: Discovery of Archaeological Resources or Human Remains. (Applies to all Proposed Project components) If
archaeological resources or human remains are unexpectedly discovered during any construction, work shall be halted within 50 meters (160
feet) of the find until it can be evaluated by a qualified professional archaeologist. If the find is determined to be significant, appropriate mitigation
measures shall be formulated and implemented. The County Coroner shall be notified in accordance with provisions of Public Resources Code
5097.98-99 in the event human remains are found and the Native American Heritage Commission shall be notified in accordance with the
provisions of Public Resources Code section 5097 if the remains are determined to be of Native American origin.
Mitigation Measure CR-2c: Native American Notification. (Applies to all Proposed Project components) Because of their continuing interest in
potential discoveries during construction, all listed Native American Contacts shall be notified of any and all discoveries of archaeological
resources in the project area.
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Impact Statement
Salinas Treatment
Recovery

Treatment Plant
Table S-1Revised
Mitigation Measures
CR-3: Construction Impacts on Unknown
Paleontological Resources. Proposed Project
construction would not result in damage to or
destruction of unknown paleontological resources.
LS
LS
NI
NI
NI
NI
LS
NI
NI
NI
LS
LS
LS
None required.
Energy and Mineral Resources (EN)

EN-1: Construction Impacts due to Temporary
Energy Use. Proposed Project construction could
result in wasteful or inefficient use of energy if
construction equipment is not maintained or if haul trips
are not planned efficiently. The Proposed Project would
not conflict with existing energy standards.
EN-2: Operational Impacts due to Energy Use.
Proposed Project operations would not result in the
consumption of energy such that existing supplies
would be substantially constrained nor would the
Project result in the unnecessary, wasteful, or
inefficient use of energy resources.
EN-3: Operational Impacts on Mineral Resources.
The Proposed Project would not result in a significant
impact due to the loss of availability of known mineral
resources of value to the region or to the state or to
any locally-important mineral recovery site.
Mitigation Measure EN-1: Construction Equipment Efficiency Plan. (Applies to all Proposed Project components) MRWPCA (for all components
except the CalAm Distribution System) or CalAm (for the Cal Am Distribution System) shall contract a qualified professional (i.e., construction
planner/energy efficiency expert) to prepare a Construction Equipment Efficiency Plan that identifies the specific measures that MRWPCA or
CalAm (and its construction contractors) will implement as part of project construction to increase the efficient use of construction equipment.
Such measures shall include, but not necessarily be limited to: procedures to ensure that all construction equipment is properly tuned and
maintained at all times; a commitment to utilize existing electricity sources where feasible rather than portable diesel-powered generators;
consistent compliance with idling restrictions of the state; and identification of procedures (including the use of routing plans for haul trips) that
will be followed to ensure that all materials and debris hauling is conducted in a fuel-efficient manner.
LSM
LSM
LS
LS
LS
None required.
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
None required.
NI
NI
NI
NI
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
None required.
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM LSM
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
NI
LS
LS
NI
NI
NI
NI
NI
NI
NI
LS
LS
LS
LS
LS
LS
Geology, Soils, and Seismicity (GS)

GS-1: Construction-Related Erosion or Loss of
Topsoil. Construction of the Proposed Project would
not result in substantial soil erosion or the loss of
topsoil.
GS-2: Construction-Related Soil Collapse and Soil
Constraints during Pipeline Trenching. Construction
of some Proposed Project pipeline components would
be located on geologic units or soils that are unstable,
or that may become unstable during project
construction, and potentially result in soil instability or
collapse; however, this exposure would not result in a
substantial risk to people or structures.
GS-3: Exposure to Fault Rupture. The Proposed
Project would be located in a seismically active area,
and portions of the Proposed Project may be affected
by fault rupture from an earthquake on local faults;
however, this exposure would not result in a substantial
risk to people or structures.
GS-4: Exposure to Seismic Ground Shaking and
Liquefaction. The Proposed Project would be located
in a seismically active area; however, Proposed Project

Final EIR
5-13
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
operations would not expose people or structures to a
substantial risk of loss, injury, or death involving
exposure to seismic groundshaking and liquefaction.
GS-5: Exposure to Coastal Erosion and Sea Level
Rise. The Proposed CalAm Distribution System
Monterey Pipeline would be exposed to substantial soil
erosion as a result of sea level rise.
GS-6: Hydro-Collapse of Soils from Well Injection.
Proposed Project operation would not create a
substantial risk to life or property due to its facilities
being located on a geologic unit or soils that are
unstable, or that would become unstable as a result of
hydro-collapse.
GS-7: Exposure to Expansive and Corrosive Soils.
The Proposed Project would not result in substantial
risks to the public or other facilities due to location on
expansive or corrosive soil types.
Mitigation Measure GS-5: Monterey Pipeline Deepening. (Applies to CalAm Distribution System: Monterey Pipeline only). CalAm shall bury the
Monterey Pipeline segment that is within the pre-determined coastal erosion hazard zone to a depth of five feet below the depth of the 2060,
100-year lower profile envelope. The extent of the coastal erosion hazard zone, length of affected pipeline section, and lower profile envelope for
this pipeline segment shall be determined as per the Analysis of Historic and Future Coastal Erosion with Sea Level Rise (ESA-PWA, 2014).
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
LSM
LSM
NI
NI
NI
NI
NI
NI
NI
NI
NI
LS
NI
NI
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
Hazards and Hazardous Materials (HH)

would not create a significant hazard to the public or
the environment through the routine transport, use, or
disposal of hazardous materials during construction.

Final EIR
LS
5-14
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
HH-2: Accidental Release of Hazardous Materials

would potentially cause upset and accident conditions
involving the release of hazardous materials into the
environment.
LS
LS
LS
LS
LS
LSM
LS
LSM
LSM
HH-3: Construction of Facilities on Known

Hazardous Materials Site. Proposed Project
construction would occur on a known hazardous
materials site pursuant to Government Code Section
65962.5; however, the Proposed Project would not
result in a significant hazard to people or the
environment.
NI
NI
NI
NI
NI
NI
NI
LS
LS

Final EIR
LSM LSM
LS
LS
5-15
LSM
LSM
LS
LS
Mitigation Measure HH-2a: Environmental Site Assessment. (Applies to the Lake El Estero Diversion, Product Water Conveyance RUWAP and
Coastal Alignment Options, Injection Well Facilities and the CalAm Distribution System) If required by local jurisdictions and property owners
with approval responsibility for construction of each component, MRWPCA and CalAm shall conduct a Phase I Environmental Site Assessment
in conformance with ASTM Standard 1527-05 to identify potential locations where hazardous material contamination may be encountered. If an
Environmental Site Assessment indicates that a release of hazardous materials could have affected soil or groundwater quality at a project site,
a Phase II environmental site assessment shall be conducted to determine the extent of contamination and to prescribe an appropriate course of
remediation, including but not limited to removal of contaminated soils, in conformance with state and local guidelines and regulations. If the
results of the subsurface investigation(s) indicate the presence of hazardous materials, additional site remediation may be required by the
applicable state or local regulatory agencies, and the contractors shall be required to comply with all regulatory requirements for facility design or
site remediation.
Mitigation Measure HH-2b: Health and Safety Plan. (Applies to the Lake El Estero Diversion, Product Water Conveyance RUWAP and Coastal
Alignment Options, the Injection Well Facilities, and the CalAm Distribution System) The construction contractor(s) shall prepare and implement
a project-specific Health and Safety Plan (HSP) for each site on which construction may occur, in accordance with 29 CFR 1910 to protect
construction workers and the public during all excavation, grading, and construction. The HSP shall include the following, at a minimum:
A summary of all potential risks to construction workers and the maximum exposure limits for all known and reasonably foreseeable site
chemicals (the HSP shall incorporate and consider the information in all available existing Environmental Site Assessments and remediation
reports for properties within -mile using the EnviroStor Database);
Specified personal protective equipment and decontamination procedures, if needed;
Emergency procedures, including route to the nearest hospital;
Procedures to be followed in the event that evidence of potential soil or groundwater contamination (such as soil staining, noxious odors,
debris or buried storage containers) is encountered. These procedures shall be in accordance with hazardous waste operations regulations and
specifically include, but are not limited to, the following: immediately stopping work in the vicinity of the unknown hazardous materials release,
notifying Monterey County Department of Environmental Health, and retaining a qualified environmental firm to perform sampling and
remediation; and
The identification and responsibilities of a site health and safety supervisor.
Mitigation Measure HH-2c: Materials and Dewatering Disposal Plan. (Applies to the Lake El Estero Diversion, Product Water Conveyance
System Options, the Injection Well Facilities, and the CalAm Distribution System) MRWPCA and CalAm and/or their contractors shall develop a
materials disposal plan specifying how the contractor will remove, handle, transport, and dispose of all excavated material in a safe, appropriate,
and lawful manner. The plan must identify the disposal method for soil and the approved disposal site, and include written documentation that
the disposal site will accept the waste. For areas within the Seaside munitions response areas called Site 39 (coincident with the Injection Well
Facilities component), the materials disposal plans shall be reviewed and approved by FORA and the City of Seaside.
The contractor shall develop a groundwater dewatering control and disposal plan specifying how the contractor will remove, handle, and dispose
of groundwater impacted by hazardous substances in a safe, appropriate, and lawful manner. The plan must identify the locations at which
potential contaminated groundwater dewatering are likely to be encountered (if any), the method to analyze groundwater for hazardous
materials, and the appropriate treatment and/or disposal methods. If the dewatering effluent contains contaminants that exceed the requirements
of the General WDRs for Discharges with a Low Threat to Water Quality (Order No. R3-2011-0223, NPDES Permit No. CAG993001), the
construction contractor shall contain the dewatering effluent in a portable holding tank for appropriate offsite disposal or discharge (see Section
4.11, Hydrology and Water Quality: Surface Water, for more information regarding this NPDES permit). The contractor can either dispose of the
contaminated effluent at a permitted waste management facility or discharge the effluent, under permit, to the Regional Treatment Plant.
None required.
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
HH-4: Use of Hazardous Materials During
Construction Within 0.25-Miles of Schools.
Proposed Project construction would not result in nor
create a significant hazard to the public or the
environment due to handling of hazardous materials or
hazardous emissions within 0.25 mile of a school
during construction.
HH-5: Wildland Fire Hazard during Construction.
Proposed Project construction would not increase the
risk of wildland fires in high fire hazard areas.
During Operation. Proposed Project operations would
not create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials.
HH-7: Operation of Facilities on Known Hazardous
Materials Site. Proposed Project facilities would be
located on a known hazardous materials site; however,
the Proposed Project would not result in a significant
hazard to people or the environment.
NI
NI
NI
NI
NI
NI
LS
LS
LS
LS
NI
NI
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
Hydrology and Water Quality: Groundwater (GW)

GW-1: Construction Groundwater Depletion,
Levels, and Recharge. Construction of the Proposed
Project components would not deplete groundwater
supplies nor interfere substantially with groundwater
recharge such that there would be a net deficit in
aquifer volume or a lowering of local groundwater
levels.
GW-2: Construction Groundwater Quality. Proposed
Project construction would not violate any water quality
standards or otherwise degrade water quality.
Levels: Salinas Valley Groundwater Basin.
Operation of the Proposed Project would not deplete
groundwater supplies in the Salinas Valley nor interfere
substantially with groundwater recharge such that there
would be a net deficit in aquifer volume or a lowering of
the local groundwater levels in the Salinas Valley
Groundwater Basin.
Levels: Seaside Basin. Operation of the Proposed
Project would not deplete groundwater supplies in the
Seaside Basin nor interfere substantially with
groundwater recharge such that there would be a net
deficit in aquifer volume or a lowering of the local
groundwater levels in the Seaside Basin.

Final EIR
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
NI
NI
BI
NI
NI
NI
NI
NI
BI
None required.
NI
NI
NI
NI
NI
NI
NI
NI
NI
LS
NI
NI
LS
None required.
5-16
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
GW-5: Operational Groundwater Quality: Salinas
Valley. Operation of the Proposed Project would not
degrade groundwater quality in the Salinas Valley.
GW-6: Operational Groundwater Quality: Seaside
Basin. Proposed Project operations would not degrade
groundwater quality in the Seaside Basin, including
due to injection of purified recycled water into the
basin.
BI
BI
BI
LS
LS
LS
NI
BI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
BI/
4
LS *
NI
NI
BI/
4
LS *
NI
NI
BI/
2 None required.
LS
None required.
Hydrology and Water Quality: Surface Water (HS)

Quality due to Discharges. Proposed Project
construction involving well drilling and development,
and dewatering of shallow groundwater during
excavation would generate water requiring disposal.
Compliance with existing regulatory requirements
would ensure that water disposal during construction
would not violate any water quality standards or waste
discharge requirements, would not cause substantial
erosion or siltation, and would not otherwise
substantially degrade surface water quality.
Quality due to Earthmoving, Drainage Alterations,
and Use of Hazardous Chemicals. Proposed Project
construction would not violate any water quality
including marine water quality, due to earthmoving,
drainage system alterations, and use of hazardous
chemicals.
HS-3: Operational Impacts to Surface Water Quality
due to Well Maintenance Discharges. Proposed
Project operations would not violate any water quality
due to well maintenance discharges.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
NI
NI
NI
NI
NI
NI
NI
NI
NI
LS
NI
NI
LS
None required.
For concentrations of total dissolved solids and chloride, the impact would be beneficial; for all other water quality parameters, the impact would be less than significant.

Final EIR
5-17
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
HS-4: Operational Surface Water Quality Impacts
due to Source Water Diversions. Proposed Project
diversions would result in water quality benefits due to
diversion and treatment of polluted waters; however,
rapid water fluctuation from diversions at the
Reclamation Ditch could induce erosion and
sedimentation in downstream waters.
HS-5: Operational Marine Water Quality due to
Ocean Discharges. Proposed Project operational
discharges of reverse osmosis concentrate to the
ocean through the MRWPCA outfall would not violate
water quality standards or waste discharge
requirements, or otherwise substantially degrade water
quality.
HS-6: Operational Drainage Pattern Alterations. The
Proposed Project would alter existing drainage patterns
of the component sites by increasing impervious
surfaces, but would not substantially increase the rate
or amount of runoff such that it would: (1) cause
erosion or siltation on- or off-site, (2) cause flooding onor offsite, or (3) exceed the existing storm drainage
system capacity.
HS-7: Operational Carmel River Flows. Proposed
Project operations would result in reduced pumping of
the Carmel River alluvial aquifer resulting in increased
flows in Carmel River that would benefit habitat for
aquatic and terrestrial species.
HS-8: Operational Risks due to Location within 100Year Flood Area. Portions of the Proposed Project
would be located within a 100-year flood hazard area
but would not impede or redirect flood flows.
HS-9: Operational Risks due to Flooding due to
Levee/Dam Failure, or Coastal Inundation. During
operations, some Proposed Project facilities may be
exposed to flooding due to failure of a levee or dam,
sea level rise, and storm surges/tides related to climate
change, but this exposure would not pose a substantial
nor significant risk of loss, injury, or death.
HS-10: Operational Seiche, Tsunami, or Mudflow
Risk. The Proposed Project operations would not
expose people or structures to substantial risk from
flooding due to a seiche, tsunami, or mudflow.

Final EIR
Mitigation Measure HS-4: Management of Surface Water Diversion Operations (Applies to Reclamation Ditch Diversion, only) Rapid, imposed
water-level fluctuations shall be avoided when operating the Reclamation Ditch Diversion pumps to minimize erosion and failure of exposed (or
unvegetated), susceptible banks. This can be accomplished by operating the pumps at an appropriate flow rate, in conjunction with commencing
operation of the pumps only when suitable water levels or flow rates are measured in the water body. Proper control shall be implemented to
ensure that mobilized sediment would not impair downstream habitat values and to prevent adverse impacts due to water/soil interface adjacent
to the Reclamation Ditch and Tembladero Slough. During planned routine maintenance at the Reclamation Ditch Diversion, maintenance
personnel shall inspect the diversion structures within the channel for evidence of any adverse fluvial geomorphological processes (for example,
undercutting, erosion, scour, or changes in channel cross-section). If evidence of any substantial adverse changes are noted, the diversion
structure shall be redesigned and the project proponents shall modify it in accordance with the new design.
LS
LS
LSM
LS
LS
LS
NI
NI
NI
NI
NI
NI
LSM
BI
BI
BI
BI
BI
BI
LS
NI
NI
NI
NI
NI
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
NI
BI
None required.
LS
LS
LS
LS
LS
LS
NI
LS
LS
LS
NI
NI
LS
None required.
LS
LS
NI
LS
LS
LS
NI
NI
NI
NI
LS
LS
LS
None required.
NI
NI
NI
LS
LS
LS
NI
NI
NI
NI
LS
LS
LS
None required.
5-18
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
Land Use, Agriculture, and Forest Resources (LU)

LU-1: Temporary Farmland Conversion during
Construction. The Proposed Project would result in a
temporary disruption to agricultural production on
designated prime, unique and statewide important
farmlands during construction, but would not directly or
indirectly convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance to a nonagricultural use.
LU-2: Operational Consistency with Plans, Policies,
and Regulations. The Proposed Project would have
one or more components that would potentially conflict,
or be inconsistent with, applicable land use plans,
policies, and regulations without implementation of
mitigation measures identified in this EIR.
LU-3: Operational Indirect Farmland Conversion.
The Proposed Project would not change the existing
environment such that Prime Farmland, Unique
Farmland, or Farmland of Statewide Importance is
converted to non-agricultural use.
NI
NI
LSM
NI
LSM
NI
NI
LSM
NI
NI
LS
LS
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LS
LS
LS
LS
LS
LS
LS
NI
NI
NI
NI
NI
LS
None required.
BI
BI
BI
BI
BI
BI
LS
NI
NI
NI
NI
NI
LS
None required.
SU
Mitigation Measure NV-1a: Drilling Contractor Noise Measures. (Applies to Injection Well Facilities) Contractor specifications shall include a
requirement that drill rigs located within 700 feet of noise-sensitive receptors shall be equipped with noise reducing engine housings or other
noise reducing technology and the line of sight between the drill rig and nearby sensitive receptors shall be blocked by portable acoustic barriers
and/or shields to reduce noise levels such that drill rig noise levels are no more 75 dBA at 50 feet. This would reduce the nighttime noise level to
less than 60 dBA Leq at the nearest residence. The contractor shall submit to the MRWPCA and the Seaside Building Official, a Well
Construction Noise Control Plan for review and approval. The plan shall identify all feasible noise control procedures that would be implemented
during night-time construction activities. At a minimum, the plan shall specify the noise control treatments to achieve the specified above noise
Mitigation Measure NV-1b: Monterey Pipeline Noise Control Plan for Nighttime Pipeline Construction. (Applies to CalAm Distribution System:
Monterey Pipeline) CalAm shall submit a Noise Control Plan for all nighttime pipeline work to the California Public Utilities Commission for
review and approval prior to the commencement of project construction activities. The Noise Control Plan shall identify all feasible noise control
procedures to be implemented during nighttime pipeline installation in order to reduce noise levels to the extent practicable at the nearest
residential or noise sensitive receptor. At a minimum, the Noise Control Plan shall require use of moveable noise screens, noise blankets, or
other suitable sound attenuation devices be used to reduce noise levels during nighttime pipeline installation activities.
Mitigation Measure NV-1c: Neighborhood Notice. (Applies to Injection Well Facilities and CalAm Distribution System: Monterey Pipeline)
Residences and other sensitive receptors within 900 feet of a nighttime construction area shall be notified of the construction location and
LSM LSM
NI
Mitigation Measure LU-1: Minimize Disturbance to Farmland. (Applies to the Salinas Treatment Facility and a portion of the Blanco Drain
Diversion) To support the continued productivity of designated Prime Farmland and Farmland of Statewide Importance, the following provisions
shall be included in construction contract specifications:
Construction contractor(s) shall minimize the extent of the construction disturbance, including construction access and staging
areas, in designated important farmland areas.
Prior to the start of construction, the construction contractor(s) shall mark the limits of the construction area and ensure that no
construction activities, parking, or staging occur beyond the construction limits.
Upon completion of the active construction, the site shall be restored to pre-construction conditions.
LSM
LSM All other mitigation measures (see Table 4.12-5 in Section 4.12, Land Use, Agriculture, and Forest Resources).
Marine Biological Resources (MR)

MR-1: Operational Impacts on Marine Biological
Resources. Operation of the Proposed Project would
not result in substantial adverse effects on candidate,
sensitive, or special-status species and would not
interfere substantially with the movement of any native
resident or migratory fish or wildlife species.
Noise and Vibration (NV)
NV-1: Construction Noise. Construction activity

would result in a temporary increase in ambient noise
levels in the vicinity of all Proposed Project sites during
construction that would not be substantial at most
construction sites, except at the Injection Well Facilities
and CalAm Distribution Monterey Pipeline sites.

Final EIR
LS
LS
LS
LS
LS
LS
LS
LS
LS
LSM
LS
5-19
SU
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
NV-2: Construction Noise That Exceeds or Violate

Local Standards. Construction activity would result in
a temporary increase that at some locations could
generate noise levels in excess of standards
established in the local general plans and/or could
violate local regulations.
NI
NI
LSM
SU
LSM
NI
NI
LSM
LSM
NI
NI
NI
SU
NV-3: Construction Vibration. Construction of the

Proposed Project would not expose sensitive receptors
to excessive groundborne vibration.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS

Final EIR
5-20
schedule in writing, at least two weeks prior to the commencement of construction activities. The notice shall also be posted along the proposed
pipeline alignments, near the proposed facility sites, and at nearby recreational facilities. The contractor shall designate a noise disturbance
coordinator who would be responsible for responding to complaints regarding construction noise. The coordinator shall determine the cause of
the complaint and ensure that reasonable measures are implemented to correct the problem. A contact number for the noise disturbance
coordinator shall be conspicuously placed on construction site fences and included in the construction schedule notification sent to nearby
residences. The notice to be distributed to residences and sensitive receptors shall first be submitted, for review and approval, to the MRWPCA
and city and county staff as may be required by local regulations.
Mitigation Measure NV-1d: RUWAP Pipeline Construction Noise. (Applies to the RUWAP Alignment Option of the Product Water Conveyance)
The following measures will be implemented by the project proponents in response to comments from the Marina Coast Water District if the
RUWAP alignment option of the Product Water Conveyance Pipeline is selected for implementation.
The construction contractor shall limit exterior construction related activities to the hours of restriction consistent with the noise
ordinance of, and encroachment permits issued by, the relevant land use jurisdictions.
The contractor shall locate all stationary noise-generating equipment as far as possible from nearby noise-sensitive receptors. Where
possible, noise generating equipment shall be shielded from nearby noise-sensitive receptors by noise-attenuating buffers. Stationary
noise sources located 500 feet from noise-sensitive receptors shall be equipped with noise reducing engine housings. Where possible
and required by the local jurisdiction, portable acoustic barriers shall be placed around stationary noise generating equipment that is
located less than 200 feet from noise-sensitive receptors.
The contractor shall assure that construction equipment powered by gasoline or diesel engines have sound control devices at least as
effective as those provided by the original equipment manufacturer (OEM). No equipment shall be permitted to have an unmuffled
exhaust.
The contractor shall assure that noise-generating mobile equipment and machinery are shut-off when not in use.
Residences within 500 feet of a construction area shall be notified of the construction schedule in writing, prior to construction. The
project proponent(s) and contractor shall designate a noise disturbance coordinator who would be responsible for responding to
complaints regarding construction noise. The coordinator shall determine the cause of the complaint and ensure that reasonable
measures are implemented to correct the problem. A contact number for the noise disturbance coordinator shall be conspicuously
placed on construction site fences and written into the construction notification schedule sent to nearby residences.
Mitigation Measure NV-2a: Construction Equipment. (Applies to Source Water Diversion and Storage Sites Reclamation Ditch, Tembladero
Slough and Blanco Drain, Product Water Conveyance Pipeline segments within the City of Marina and RUWAP Booster Station) Contractor
specifications shall include a requirement that the contractor shall:
- Assure that construction equipment with internal combustion engines has sound control devices at least as effective as those provided by the
original equipment manufacturer. No equipment shall be permitted to have an un-muffled exhaust.
- Impact tools (i.e., jack hammers, pavement breakers, and rock drills) used for project construction shall be hydraulically or electrically powered
wherever possible to avoid noise associated with compressed air exhaust from pneumatically powered tools. Where use of pneumatic tools is
unavoidable, an exhaust muffler shall be placed on the compressed air exhaust to lower noise levels by approximately 10 dBA. External jackets
shall be used on impact tools, where feasible, in order to achieve a further reduction of 5 dBA. Quieter procedures shall be used, such as drills
rather than impact equipment, whenever feasible.
- The construction contractor(s) shall locate stationary noise sources (e.g., generators, air compressors) as far from nearby noise-sensitive
receptors as possible,
- For Product Water Conveyance pipeline segments within the City of Marina, noise controls shall be sufficient to not exceed 60 decibels for
more than twenty-five percent of an hour,
Mitigation Measure NV-2b: Construction Hours. (Applies to Product Water Conveyance Pipelines and Booster Pump Station in the City of
Marina). The construction contractor shall limit all noise-producing construction activities within the City of Marina to between the hours of 7:00
AM and 7:00 PM on weekdays and between 9:00 AM and 7:00 PM Saturdays, except that construction may be allowed until 8:00 PM during
daylight savings time.
None required.
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
NV-4: Operational Noise. Operation of the Proposed
Project facilities would potentially increase existing
noise levels, but would not exceed noise level
standards and/or result in nuisance impacts at
sensitive receptors.
NI
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
NI
LS
None required.
LS
None required.
LS
None required.
Population and Housing (PH)

PH-1: Construction-Related Growth Inducement.
Proposed Project construction would result in
temporary increases in construction employment, but
would not induce substantial population growth.
PH-2: Operations and Infrastructure-Related
Growth Inducement. Operation of the Proposed
Project would not directly result in population growth,
and would not indirectly result in inducement of
substantial population growth.
Public Services, Utilities, and Recreation (PS)

PS-1: Construction Public Services Demand.
Construction of the Proposed Project would not result
in public service demands for fire and police protection
PS-2: Construction Landfill Capacity. Construction
of the Proposed Project would result in generation of
solid waste; however, the solid waste would be
disposed at a landfill with sufficient permitted daily and
overall capacity to accommodate the projects solid
waste disposal needs.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
PS-3: Construction Solid Waste Policies and

Regulations. Construction of the Proposed Project
would potentially conflict with state and local statutes,
policies and regulations related to solid waste.
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
PS-4: Public Services Demand During Operation.

Operation of the Proposed Project would not result in
public service demands for fire and police protection
LS
LS
LS
LS
LS
LS
LS
LS
LS

Final EIR
LSM LSM
LS
LS
5-21
LSM
LSM
LS
LS
Mitigation Measure PS-3: Construction Waste Reduction and Recycling Plan (relevant to all Proposed Project components). The construction
contractor(s) shall prepare and implement a construction waste reduction and recycling plan identifying the types of construction debris the
Proposed Project will generate and the manner in which those waste streams will be handled. In accordance with the California Integrated
Waste Management Act of 1989, the plan shall emphasize source reduction measures, followed by recycling and composting methods, to
ensure that construction and demolition waste generated by the project is managed consistent with applicable statutes and regulations. In
accordance with the California Green Building Standards Code and local regulations, the plan shall specify that all trees, stumps, rocks, and
associated vegetation and soils, and 50% of all other nonhazardous construction and demolition waste, be diverted from landfill disposal. The
plan shall be prepared in coordination with the Monterey Regional Waste Management District and be consistent with Monterey Countys
Integrated Waste Management Plan. Upon project completion, MRWPCA and CalAm shall collect the receipts from the contractor(s) to
document that the waste reduction, recycling, and diversion goals have been met.
None required.
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
PS-5: Landfill Capacity for Operations. Operation of
the Proposed Project would not result in adverse
effects on landfill capacity or be out of compliance with
federal, state, and local statutes and regulations
related to solid waste.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
Traffic and Transportation (TR)

TR-1: Construction Traffic. Proposed Project
construction would result in a temporary increase in
traffic volumes on regional and local roadways due to
construction-related vehicle trips, which would not
result in conflicts with any applicable plan, ordinance,
or policy establishing measures of effectiveness for
performance of the circulation system.
TR-2: Construction-Related Traffic Delays, Safety

and Access Limitations. Construction activities could
result in temporary traffic delays, safety hazards,
and/or disruption of access.

Final EIR
LS
LS
LS
LS
LS
NI
LS
LSM
LSM
NI
LSM
5-22
LSM
LSM
Mitigation Measure TR-2: Traffic Control and Safety Assurance Plan. Prior to construction, MRWPCA and/or its contractor shall prepare and
implement a traffic control plan or plans for the roadways and intersections affected by MRWPCA construction (Product Water Conveyance
Pipeline) and CalAm shall prepare and implement a traffic control plan for the roadways and intersections affected by the CalAm Distribution
System Improvements (Transfer and Monterey pipelines). The traffic control plan(s) shall comply with the affected jurisdictions encroachment
permit requirements and will be based on detailed design plans. For all project construction activities that could affect the public right-of-way
(e.g., roadways, sidewalks, and walkways), the plan shall include measures that would provide for continuity of vehicular, pedestrian, and
bicyclist access; reduce the potential for traffic accidents; and ensure worker safety in construction zones. Where project construction activities
could disrupt mobility and access for bicyclists and pedestrians, the plan shall include measures to ensure safe and convenient access would be
maintained.
The traffic control and safety assurance plan shall be developed on the basis of detailed design plans for the approved project. The plan shall
include, but not necessarily be limited to, the elements listed below:
General
a. Develop circulation and detour plans to minimize impacts on local streets. As necessary, signage and/or flaggers shall be used to guide
vehicles to detour routes and/or through the construction work areas.
b. Implement a public information program to notify motorists, bicyclists, nearby residents, and adjacent businesses of the impending
construction activities (e.g., media coverage, email notices, websites, etc.). Notices of the location(s) and timing of lane closures shall be
published in local newspapers and on available websites to allow motorists to select alternative routes.
Roadways
c. Haul routes that minimize truck traffic on local roadways and residential streets shall be used to the extent feasible.
d. Schedule truck trips outside of peak morning and evening commute hours to minimize adverse impacts on traffic flow.
e. Limit lane closures during peak hours. Travel lane closures, when necessary, shall be managed such that one travel lane is kept open at all
times to allow alternating traffic flow in both directions along affected two-lane roadways; the contractor shall use steel plates or trench backfilling
to restore vehicle access at the end of each workday. In the City of Marina, one-way traffic shall be limited to a maximum of 5 minutes of traffic
delay.
f. Restore roads and streets to normal operation by covering trenches with steel plates outside of normal work hours or when work is not in
progress.
g. Comply with roadside safety protocols to reduce the risk of accidents. Provide Road Work Ahead warning signs and speed control (including
signs informing drivers of state legislated double fines for speed infractions in a construction zone) to achieve required speed reductions for safe
traffic flow through the work zone. Train construction personnel to apply appropriate safety measures as described in the plan.
h. Provide flaggers in school areas at street crossings to manage traffic flow and maintain traffic safety during the school drop-off and pickup
hours on days when pipeline installation would occur in designated school zones.
i. Maintain access to private driveways.
j. Coordinate with MST so the transit provider can temporarily relocate bus routes or bus stops in work zones as deemed necessary.
Pedestrian and Bicyclists
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
TR-3: Construction-Related Roadway Deterioration.

Construction truck trips could result in increased wearand-tear on the designated haul routes, which could
result in temporary impacts to performance of the
regional circulation system.
k. Perform construction that crosses on street and off street bikeways, sidewalks, and other walkways in a manner that allows for safe access for
bicyclists and pedestrians. Alternatively, provide safe detours to reroute affected bicycle/pedestrian traffic.
Recreational Trails
l. At least two weeks prior to construction, post signage along all potentially affected recreational trails; Class I, II, and II bicycle routes; and
pedestrian pathways, including the Monterey Peninsula Recreational Trail, to warn bicyclists and pedestrians of construction activities. The signs
shall include information regarding the nature of construction activities, duration, and detour routes. Signage shall be composed of or encased in
weatherproof material and posted in conspicuous locations, including on park message boards, and existing wayfinding signage and kiosks, for
the duration of the closure period. At the end of the closure period, CalAm, MRWPCA or either of its contractors shall retrieve all notice
materials.
Emergency Access
m. Maintain access for emergency vehicles at all times. Coordinate with facility owners or administrators of sensitive land uses such as police
and fire stations, transit stations, hospitals, and schools.
n. Provide advance notification to local police, fire, and emergency service providers of the timing, location, and duration of construction activities
that could affect the movement of emergency vehicles on area roadways.
o. Avoid truck trips through designated school zones during the school drop-off and pickup hours.
Mitigation Measure TR-3: Roadway Rehabilitation Program (applies to all Proposed Project components) Prior to commencing project
construction, MRWPCA (for all components other than the CalAm Distribution System Improvements) and CalAm (for CalAm Distribution
System Improvements) shall detail the preconstruction condition of all local construction access and haul routes proposed for substantial use by
project-related construction vehicles. The construction routes surveyed must be consistent with those identified in the construction traffic control
and safety assurance plan developed under Mitigation Measure TR-2. After construction is completed, the same roads shall be surveyed again
to determine whether excessive wear and tear or construction damage has occurred. Roads damaged by project-related construction vehicles
shall be repaired to a structural condition equal to, or greater than, that which existed prior to construction activities. In the City of Marina, the
construction in the city rights-way must comply with the Citys design standards, including restoration of the streets from curb to curb, as
applicable. In the City of Monterey, asphalt pavement of full travel lanes will be resurfaced without seams along wheel or bike paths.
Mitigation Measure TR-4: Construction Parking Requirements.(Applies to Product Water Conveyance pipelines (RUWAP and Coastal
Alignments) in Marina and Seaside, and CalAm Distribution System: Transfer Pipeline and Monterey Pipeline). Prior to commencing project
construction, the construction contractor(s) shall coordinate with the potentially affected jurisdictions to identify designated worker parking areas
that would avoid or minimize parking displacement in congested areas of Marina, Seaside, and downtown Monterey. The contractors shall
provide transport between the designated parking location and the construction work areas. The construction contractor(s) shall also provide
incentives for workers that carpool or take public transportation to the construction work areas. The engineering and construction design plans
shall specify that contractors limit time of construction within travel lanes and public parking spaces and provide information to the public about
locations of alternative spaces to reduce parking disruptions.
LSM
LSM
LSM
LSM
LSM
LS
LS
LS
LS
None required.
LS
LS
LS
LS
None required.
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM
LSM LSM
TR-4: Construction Parking Interference.

Construction activities may temporarily affect parking
availability.
NI
NI
NI
NI
NI
LSM
NI
LSM
LSM
NI
TR-5: Operational Traffic. Operation and

maintenance of the Proposed Project would result in
small traffic increases on regional and local roadways,
but would not substantially affect the performance of
the regional circulation system.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
Water Supply and Wastewater Systems (WW)

WW-1: Construction-Related Water Demand. The
Proposed Project would result in a temporary increase
in water use due to construction-related demands, but
existing water supplies would be sufficient to serve
construction-related demands and construction
activities would not require new or expanded water
supply resources or entitlements.

Final EIR
LS
LS
5-23
September 2015
Project Overall
Monterey Pipeline
Coastal Alignment
Option
Transfer Pipeline
CalAm
Distribution
System
Product Water
Conveyance
RUWAP Alignment
Option
Lake El Estero
Blanco Drain (Pump

Tembladero Slough
Reclamation Ditch
Salinas Treatment
Recovery
Impact Statement

Treatment Plant
Table S-1Revised
Mitigation Measures
WW-2: Construction-Related Wastewater
Generation. The Proposed Project would result in a
temporary increase in wastewater generation due to
demand from construction workers, but existing
wastewater treatment facilities have sufficient capacity
to serve construction-related demands.
WW-3: Operational Water Supply and Entitlements.
Sufficient water supplies are available for operation of
the Proposed Project; prior to construction of each
source water diversion component and prior to
diversion of secondary treated effluent, the project
proponents would obtain applicable water rights,
permits, or agreements.
WW-4: Operational Wastewater Treatment
Capacity. Operation of the Proposed Project would not
result in a determination by the wastewater treatment
provider that would serve the project that it has
inadequate capacity to serve the projects projected
demand in addition to the providers existing
commitments.

Final EIR
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
None required.
LS
LS
LS
LS
LS
LS
LS
LS
LS
LS
NI
NI
LS
None required.
5-24
September 2015
Page S-25
Mitigation Measure BT-1a has been modified as follows in response to comment F-6a, L31, and L-33:
Mitigation Measure BT-1a: Implement Construction Best Management Practices. (Applies to

All Proposed Project Components)
The following best management practices shall be implemented during all identified phases of
construction (i.e., pre-, during, and post-) to reduce impacts to special-status plant and wildlife
species:
1. A qualified biologist must conduct an Employee Education Program for the construction
crew prior to any construction activities. A qualified biologist must meet with the
construction crew at the onset of construction at the site to educate the construction crew
on the following: 1) the appropriate access route(s) in and out of the construction area
and review project boundaries; 2) how a biological monitor will examine the area and
agree upon a method which would ensure the safety of the monitor during such activities,
3) the special-status species that may be present; 4) the specific mitigation measures
that will be incorporated into the construction effort; 5) the general provisions and
protections afforded by the USFWS and CDFW; and 6) the proper procedures if a
special-status species is encountered within the site.
2. Trees and vegetation not planned for removal or trimming shall be protected prior to and
during construction to the maximum extent possible through the use of exclusionary
fencing, such as hay bales for herbaceous and shrubby vegetation, and protective wood
barriers for trees. Only certified weed-free straw shall be used, to avoid the introduction of
non-native, invasive species. A biological monitor shall supervise the installation of
protective fencing and monitor at least once per week until construction is complete to
ensure that the protective fencing remains intact.
3. Protective fencing shall be placed prior to and during construction to keep construction
equipment and personnel from impacting vegetation outside of work limits. A biological
monitor shall supervise the installation of protective fencing and monitor at least once per
week until construction is complete to ensure that the protective fencing remains intact.
4. Following construction, disturbed areas shall be restored to pre-construction contours to
the maximum extent possible and revegetated using locally-occurring native species and
native erosion control seed mix, per the recommendations of a qualified biologist.
5. Grading, excavating, and other activities that involve substantial soil disturbance shall be
planned and carried out in consultation with a qualified hydrologist, engineer, or erosion
control specialist, and shall utilize standard erosion control techniques to minimize
erosion and sedimentation to native vegetation (pre-, during, and post-construction).
6. No firearms shall be allowed on the construction sites at any time.
7. All food-related and other trash shall be disposed of in closed containers and removed
from the project area at least once a week during the construction period, or more often if
trash is attracting avian or mammalian predators. Construction personnel shall not feed
or otherwise attract wildlife to the area.
8. To protect against spills and fluids leaking from equipment, the project proponent shall
require that the construction contractor maintains an on-site spill plan and on-site spill
containment measures that can be easily accessed.
9. Refueling or maintaining vehicles and equipment should only occur within a specified
staging area that is at least 100 feet from a waterbody (including riparian and wetland
habitat) and that has sufficient management measures that will prevent fluids or other
construction materials including water from being transported into waters of the state.
Measures shall include confined concrete washout areas, straw wattles placed around
stockpiled materials and plastic sheets to cover materials from becoming airborne or
otherwise transported due to wind or rain into surface waters.

Final EIR
5-25
September 2015
10. The project proponent and/or its contractors shall coordinate with the City of Seaside on
the location of Injection Well Facilities and the removal of sensitive biotic material.
Page S-35
The first paragraph has been changed as follows in response to comment N-1:
Mitigation Measure HS-C/MR-C: Implement Measures to Avoid Exceedances over

Water Quality Objectives at the Edge of the Zone of Initial Dilution
As part of the amendment process to modify the existing MRWPCA NPDES Permit (Order No. R3-20140013, NPDES Permit No. CA0048551) per 40 Code of Regulations Part 122.62, it would be necessary to
conduct an extensive assessment in accordance with requirements to be specified by the RWQCB. It is
expected that the assessment would include, at a minimum, an evaluation of the minimum probable initial
dilution at the point of discharge based on likely discharge scenarios and any concomitant impacts on
water quality and beneficial uses per the Ocean Plan. Prior to operation of the MPSWP MPWSP
desalination plant, the discharger(s) will be required to test the MPSWP MPWSP source water in
accordance with protocols approved by the RWQCB. If the water quality assessment indicates that the
water at the edge of the ZID will exceed the Ocean Plan water quality objectives, the MRWPCA will not
accept the desalination brine discharge at its outfall, and the following design features and/or operational
measures shall be employed, individually or in combination, to reduce the concentration of constituents to
below the Ocean Plan water quality objectives at the edge of the ZID:
a. Additional pre-treatment of MPWSP source water at the Desalination Plant: Feasible
methods to remove PCBs Polychlorinated Biphenyls (PCB) and other organic compounds
from the MPWSP source water at the desalination plant include additional filtration or use of
granular activated carbon (GAC). GAC acts as a very strong sorbent and can effectively
remove PCBs and other organic compounds from the desalination plant source water.
CHANGES TO CHAPTER 1, INTRODUCTION

Page 1-1
The following footnote reference and footnote have been added in response to comment
Q-5:
Footnote Reference in first sentence: The Monterey Regional Water Pollution Control Agency
(MRWPCA) has prepared this Draft Environmental Impact Report (DEIR) to provide the public and
responsible and trustee agencies with information on the potential environmental effects of
1
implementation of the Pure Water Monterey Groundwater Replenishment Project .
Footnote at bottom of page 1-1:
1
The term replenishment in the title of the project was intended to maintain consistency with the
relevant water quality regulatory programs under the jurisdiction of the State Water Resources Control
Board (SWRCB) Division of Drinking Water (DDW) (i.e., this agency references the requirements as the
Groundwater Replenishment Regulations (or DPH-14-003E Groundwater Replenishment Using Recycled
Water)). Use of the word replenishment is not intended to be defined to match the definition of artificial
replenishment in the Seaside Groundwater Basin adjudication (Case M66343, Decision, III., A., 3., March
27, 2006) because as proposed, the project would not offset the cumulative over production from the
Seaside Basin by producers in the basin.
Page 1-5
The first paragraph in Section 1.4 Project Approval and Understanding has been
changed in response to comments H-23 and H-24:
Subsequent to certification of the EIR, MRWPCA will act on the Proposed Project. It is anticipated that
EIR certification and action on the project will be scheduled for the same public hearing. CEQA requires
that a lead agency shall neither approve nor carry out a project as proposed unless the significant
environmental effects have been reduced to an acceptable level (CEQA Guidelines Sections 15091 and
15092) or the project objectives outweigh the unavoidable significant impacts (requiring the Lead Agency
to make a Statement of Overriding Considerations) (CEQA Guidelines Section 15093). An acceptable
level is defined as eliminating, avoiding, or substantially lessening the significant effects. A projects
impacts must be reduced to a less than significant level where feasible or the lead agency must adopt a
Final EIR
5-26
September 2015
Statement of Overriding Considerations for any impacts that remain significant after all feasible mitigation
is adopted. As the cited Section 15092 of the CEQA Guidelines provides:
(b) A public agency shall not decide to approve or carry out a project for which an EIR was prepared
unless either: (1) The project as approved will not have a significant effect on the environment, or (2) The
agency has: (A) Eliminated or substantially lessened all significant effects on the environment where
feasible as shown in findings under Section 15091, and (B) Determined that any remaining significant
effects on the environment found to be unavoidable under Section 15091 are acceptable due to
overriding concerns as described in Section 15093. (CEQA Guidelines, 15092, subd. (b), emphasis
added.)
CHANGES TO CHAPTER 2, PROJECT DESCRIPTION

Page 2-6
The heading for section 2.3.2 has been amended as follows in response to comment I-2:
2.3.2
Page 2-7
Monterey Peninsula Water Resources System
Section 2.3.2.1 MPWMD Description, first and second paragraphs have been amended
as follows in response to comment I-1 and I-3:
The Water Management District is partnering with MRWPCA to fund and manage the studies for the
Proposed Project. The Water Management District is a special district, with a seven-member Board of
Directors, created by the California Legislature in 1977 and endorsed by a public vote in 1978, for the
purposes of conserving and augmenting the water supplies by integrated management of ground and
surface water supplies; control and conservation of storm and wastewater; and promotion of the reuse
and reclamation of water. Approximately 104,000 people live within the jurisdictional boundary of the
Water Management District, which includes the six Monterey Peninsula cities of Carmel-by-the-Sea, Del
Rey Oaks, Monterey, Pacific Grove, Seaside, and Sand City, the Monterey Peninsula Airport District, and
unincorporated communities within Monterey County including Pebble Beach, the Carmel Highlands, a
portion of Carmel Valley, and areas adjacent to Highway 68 between Del Rey Oaks and the Laguna Seca
area.
The Water Management District manages production and use of water from the Carmel River stored in
Los Padres Reservoir, water production in the Carmel Valley Alluvial Aaquifer, and groundwater pumped
from municipal and private wells in Carmel Valley, the Seaside Groundwater Basin, and other areas
within the Water Management District boundary. The Water Management Districts jurisdictional area
includes portions of watersheds and groundwater basins that lie partially outside the Water Management
District political boundary. Activities affecting those areas of the watersheds and basins influence the
quantity and quality of water resources within the Water Management District boundary.
Page 2-7
The final paragraph (third paragraph) of Section 2.3.2.1 Monterey Peninsula Water
Management District has been amended as follows in response to comments I-3 and Q-9.
The Water Management District regulates public fresh water supply systems within its boundaries,
including systems owned by CalAm, the largest purveyor of water in the region, although CalAm has
ultimate responsibility for the management and operation of its water system. The Water Management
District also monitors the production of water from approximately 1,100 public and private wells, of which
approximately 800 are currently active. In addition, the Water Management District regulates the creation
of new water distribution systems and expansions, water connection permits, and allocation of water to
jurisdictions (cities and unincorporated areas). The Water Management District adopts and implements
water conservation ordinances, determines drought emergencies and can impose rationing programs.
The District also regulates activities within the streamside corridor of the lower 15.5 miles of the Carmel
River. The Water Management District has played key roles in several water augmentation projects,
including completing planning and technical studies, engineering and cost analyses, environmental
review in compliance with federal and state regulations, obtaining water rights and construction permits,
facility construction and/or project financing. The District has also analyzed numerous water supply
alternatives at varying degrees of specificity. The District was an integral partner in development of the
Peralta Well in Seaside, Pebble Beach Reclamation Project, and Aquifer Storage and Recovery (Phases
1 and 2). The District constructed and owns the two ASR Phase 1 wells at the Santa Margarita site.
Final EIR
5-27
September 2015
Page 2-7
The first sentence in Section 2.3.2.2 has been changed as follows in response to
comment Q-5:
Purified recycled water produced by the Proposed Projects Advanced Water Treatment Facilities would
be injected into the Seaside Groundwater Basin, which would enable CalAm to extract the water from the
Seaside Basin for delivery to its customers and also would replenish the Basin.
Page 2-8
The third paragraph, first sentence has been changed as follows:
Figure 2-3rev, Seaside Groundwater Basin (1) the Seaside Area Subbasin of the Salinas Valley
Groundwater Basin
Page 2-8/2-9
The last sentence on page 2-8 that continues onto 2-9 has been changed as follows:
Figure 2-4rev, Seaside Groundwater Basin Groundwater Levels, shows groundwater elevation contour
maps of the two aquifers and includes highlights the areas where water levels have fallen below sea level
(areas below 0-contour).
Page 2-9
The second full paragraph on this page has been amended as follows in response to
comment Q-6:
The adjudication requires all basin pumpers, except overlying users, to decrease their operating yield
from the Basin triennially until each requires CalAm to decrease its operating yield from the basin by 10%
triennially until it reaches its their allotted portion of the court-defined natural safe yield of 1,494 3,000
AFY beginning (expected to occur in Water Year 2021), as detailed in Table 2-1, CalAms Adjudicated
Allocation of Native Seaside Groundwater Basin: Water Years 2006 2026. This natural safe yield
was defined by the adjudication as the quantity of groundwater existing in the Basin that occurs solely as
a result of natural replenishment. In addition to these reductions in pumping, CalAm is required to pay
back historic over-pumping and plans to accomplish this by reducing its pumping from the Seaside
Groundwater Basin by an additional 700 AFY for 25 years.
Page 2-9
The last sentence of the first paragraph under 2.3.2.3 Carmel River System has been
amended as follows in response to comment I-1:
. The Carmel Valley Groundwater Basin Alluvial Aquifer lies along the downstream portion of the
Carmel River.
Page 2-10
The second full paragraph has been amended as follows in response to comment I-1, I-4,
and Q-7:
The Carmel Valley Groundwater Basin Alluvial Aquifer is primarily located on the valley floor, which is
about 16 miles long and varies in width from 300 to 4,500 feet. The groundwater basin consists of
younger alluvium and river deposits, and older alluvium and terrace deposits. These deposits are
primarily underlain by Monterey Shale and Tertiary sandstone units. The primary water bearing formation
is the younger alluvium with a typical thickness of 50 to 100 feet. The younger alluvium consists of
boulders, gravel, sand, silt, and clay. The thickness varies from approximately 30 feet in the upper basin
to about 180 feet near the mouth of the basin (California Department of Water Resources, 2004). As a
result of the significant reduction in usable storage in both reservoirs, CalAm currently relies entirely on
multiple wells in the alluvial aquifer along the lower Carmel River for its Carmel River supplies.
Page 2-10
The first paragraph of Section 2.3.2.4 State Orders to Reduce Carmel River Diversions
has been changed as follows in response to comments I-1, I-4 and Q-8:
The Carmel Valley Alluvial Aaquifer, which underlies the alluvial portion of the Carmel River downstream
of San Clemente Dam, is about six square-miles and is approximately 18 16 miles long. In the summer
and fall, other private pumpers extract approximately 2,200 to 2,400 AFY of water from the alluvial
aquifer, and CalAm extracts approximately 7,880 AFY. Historically, this combined pumping, including
authorized pumping in the summer and fall, has resulted in dewatering of the lower six miles of the river
for several months in most years and up to nine miles of the river in dry and critically dry years. Recharge
of the aquifer is derived primarily from river infiltration. The aquifer is replenished relatively quickly each
year during the rainy season, except during prolonged periods of extreme drought.

Final EIR
5-28
September 2015
Page 2-10
The last two sentences on this page have been changed as follows in response to
Comment H-25:
In their recent submittals to the California Public Utilities Commission, CalAm estimates that it needs a
total supply source of 15,296 AFY to satisfy the Cease and Desist Order and forecasted demand. In order
to do this, CalAm will asserted in its application submittals that it needs to augment its water supplies by
9,752 AFY, which they contend includes water to satisfy a requirement to return water to the Salinas
Valley to offset the amount of fresh water in the feed water from the desalination plants slanted coastal
intake wells.
Page 2-13
The last paragraph on this page has been amended as follows in response to the
comments M-3 and Q-14:
The Salinas Valley Groundwater Basin extends along the river valley floor from Bradley north to the
Monterey Bay. It is the primary source of water supply for Monterey County, providing approximately
500,000 acre-feet per year for agricultural, industrial and municipal use. The groundwater basin has four
designated subareas, the Upper Valley, Forebay, East Side and Pressure whose geographic extent is
shown in Figure 2-6, Salinas Valley Groundwater Basin. The groundwater basin is recharged in all but the
Pressure Subarea, which has a clay layer above the major water bearing layers. California Department of
Water Resources Bulletin 118 identifies nine sub-basins within the aquifer. Monterey County Water
Resources manages the seven interconnected sub-basins, but refers to them as four major areas: the
Upper Valley Area, the Forebay Area (includes DWR Forebay and Arroyo Seco Areas), the East Side
Area (includes DWR East Side and Langley Areas) and the Pressure Area (includes DWR 180/400 Foot
Area and Corral de Tierra Areas). The geographic extents of these areas are shown in Figure 2-6,
Salinas Valley Groundwater Basin. The Paso Robles Area and the Seaside Area are considered
separate formations. The Upper Valley and Forebay Subareas receive substantial recharge from river
percolation and infiltration of rainfall and irrigation water. The Salinas River does not cross the Eastside
Subarea, where recharge is primarily from rainfall, irrigation, and inflow from other subareas. In the
Pressure Subarea, a regionally extensive clay layer (the Salinas Valley Aquiclude) greatly restricts the
downward movement of recharge from rainfall, irrigation and the river to the underlying water supply
aquifers. Much of the recharge in that subarea is groundwater inflow from the Forebay Subarea. The
Pressure Subarea encompasses approximately 140 square miles, and consists of three primary aquifers:
the 180-Foot Aquifer, the 400-Foot Aquifer and the 900-Foot (Deep) Aquifer. The 180-Foot and 400-Foot
Aquifers connect to the Pacific Ocean, and have experienced seawater intrusion since the 1930s due to
groundwater pumping along the coast. The geographic extent of seawater intrusion in these aquifers is
shown in Figure 2-7rev, Salinas Valley Groundwater Basin Seawater Intrusion Maps. Several
projects have been developed to address this seawater intrusion, as discussed below.
Page 2-14
The first sentence has been amended as follows in response to comment M-4:
The Monterey County Water Resources Agency is a water and flood control agency with jurisdiction
coextensive with Monterey County and governed by the Monterey County Water Resources Agency
Board of Directors and Board of Supervisors.
Page 2-15
The following text has been added at the end of section 2.3.3.3 in response to comments
H-28, H-29 and H-30:
MCWD and others have implemented numerous projects to eliminate the long-term overdraft condition of
the Salinas Valley Groundwater Basin and address seawater intrusion. For example, between 1985 and
2000, MCWD constructed both a seawater desalination plant (currently inactive) and a wastewater
recycling facility (the recycling facility was retired when the MCWD connected to the MRWPCA system).
More recently MCWD has implemented numerous water conservation programs, including, among others:
(1) the Water Conservation Commission; (2) a conservation rate structure; (3) an automatic meter reading
(AMR) system with leak detection; (4) the California State University Monterey Bay student learning
partnership and student internship programs; (5) free conservation devices (showerheads, faucet
aerators, leak detection tablets, etc.); (6) free water conservation education materials (e-flyers, newsletter,
magnets and stickers, restaurant and commercial business placards, water conservation website, etc.);
(7) a landscape demonstration garden; (8) high-efficiency clothes washer and toilet rebates; (9) leak and
high water use and detection notification procedures; (10) free property surveys; (11) landscape walkthroughs and irrigation system checks; (12) water use investigations, water use data logs, and water use
charts and tables; (13) property certification on resale; (14) in-school water education classes and
Final EIR
5-29
September 2015
assemblies; (15) landscape building standards and plan check procedures; (16) water-wise landscape
incentives for turf removal, conversion from sprinkler to drip irrigation, "smart" controller replacement, rail
and soil moisture shut-off switches, etc.; (17) regional participation in Water Awareness Committee of
Monterey County. MCWD states that a significant portion of its budget is allocated to water conservation
programs, and that MCWD will spend approximately $465,155 on its conservation programs over the next
year alone. MCWD estimates that its conservation programs reduce pumping for the Salinas Valley
Groundwater Basin by approximately 520 to 600 acre-feet of water per year. MCWD has also adopted a
Water Shortage Contingency Plan for staged voluntary and mandatory conservation efforts.
In addition to the conservation programs listed above, MCWD states that various agreements have been
signed by MCWD, MCWRA, and MRWPCA to limit groundwater use and to address seawater intrusion in
the Salinas Valley, including for example, the Annexation Agreement and Groundwater Mitigation
Framework for Marina Area Lands (MCWD/MCWRA.J.G. Armstrong Family Members, RMC Lonestar
(now CEMEX), and the City of Marina, March 1996).
Page 2-15
The first paragraph under section 2.3.3.4 has been amended as follows in response to
comments H-28, H-29 and H-30:
In addition to the ongoing projects and programs by MCWD and other water users in the County to
implement water conservation and groundwater use reduction programs, Monterey County, acting
through the Monterey County Water Resources Agency, has implemented several projects to reduce
seawater intrusion along the coast and increase the reliability and availability of water supply. These
projects are described in the following sections.
Page 2-27
The third paragraph in Section 2.5.5.2 Aquifer Storage and Recovery Program has been
amended as follows:
Aquifer Storage and Recovery operations generally consist of three components or phases: (1) injection
of drinking-quality water into the aquifer through the Aquifer Storage and Recovery wells; (2) storage of
the injected water within the aquifer; and, (3) recovery of the stored water by pumping at one or more of
the Aquifer Storage and Recovery wells or at CalAm production wells within the basin. Periodic samples
of the injected, stored, and recovered waters are collected from the Aquifer Storage and Recovery wells
and associated monitoring wells and analyzed for a variety of water-quality constituents pursuant to
requirements of the Central Coast Regional Water Quality Control Board oversight of the Aquifer Storage
and Recovery Project and the extracted groundwater must also meet SWRCB Division of Drinking Water
drinking water regulations.
Page 2-27
The first sentence of the third paragraph in Section 2.5.5.2 Aquifer Storage and Recovery
Program has been amended as follows in response to comment I-5:
The first phase (Phase 1) of the Aquifer Storage and Recovery Project included two MPWMD
injection/extraction wells at the Santa Margarita site and was approved in 2006 and operational in 2007;
however, test injections began in 2001 and test extractions began in 2003.

Final EIR
5-30
September 2015
Page 2-30
Page 2-34
Table 2-8 has been amended as follows in response to I-1:
In Table 2-10, the row titled Lake El Estero Diversion has been amended as follows in
response to comment P-4:
Lake El Estero Diversion
Page 2-40
24 hours per day for urban runoff, wet season

(typically NovemOctober through April) dependent on
pipe and pump station capacity and weather. No new
operations and maintenance staff expected beyond
existing City of Monterey staff.
The last sentence on this page has been amended as follows:
Runoff from summer storms would be diverted from the City of Salinas stormwater system when
available.
Page 2-49
The last two paragraphs/subsections on this page have been amended as follows to
correct a typographical error:

Final EIR
5-31
September 2015
Construction
Construction of the Salinas Pump Station urban runoff diversion structure is discussed as part of the
Agricultural Wash Water facility construction in Section 2.7.2.42.
Operations and Maintenance

Operation of the Salinas Pump Station diversion structures is discussed as part of the Agricultural Wash
Water facility operation in Section 2.7.2.42.
Page-2-67
The second paragraph of Section 2.9.1 Design Criteria of Product Water Conveyance
has been amended as follows in response to comment L-36:
Other product water conveyance facility design provisions include standby pumping units for pump
stations; in-line isolation valves on the pipeline approximately every 2,000 feet, in case an unforeseen
leak occurs or subsequent construction activities result in damage to the pipeline; compliance with
pipeline separation requirement by the SWRCB Division of Drinking Water; and remote monitoring of the
Booster Pump Station performance and pipeline pressure via SCADA system. The design of any
buildings associated with the booster pumps shall consist of Monterey/Mission style architecture to match
the design of the structures that have been built on the Santa Margarita ASR site and the Seaside Middle
School ASR Site, per the City of Seasides comments.
Page 2-67
The first paragraph of Section 2.9.1.1 RUWAP Product Water Alignment has been
amended as follows in response to comment H-20:
The RUWAP Alignment would follow a portion of the recycled water pipeline alignment of Marina Coast
Water Districts previously approved and partially-constructed Regional Urban Water Augmentation
Program Recycled Water Project. The proposed new product water conveyance pipeline would be
located primarily along paved roadway rights-of-way within urban areas. The Recycled Water Project was
approved by the Marina Coast Water District in 2005; however, only portions of the recycled water
distribution system have been built and no recycled water has been delivered to urban users. MRWPCA
and the Water Management District may pursue a shared easement to accommodate both pipelines in
some portions of the alignment (i.e., leaving space for completion of the planned separate RUWAP
pipeline). It is also possible that in the future these agencies may decide to jointly use a single pipeline for
both the Product Water Conveyance and the RUWAP Recycled Water Project agreements and permits to
use a portion or portions of the pipeline originally proposed and/or constructed for the Recycled Water
Project by Marina Coast Water District (i.e., converting the purpose of the pipeline for use by both the
Proposed Project to convey advanced-treated Product Water from the AWT Facility to the Injection Well
Facilities as well as to convey water to MCWD pursuant to the 2009 RUWAP MOU) or they may pursue a
shared easement to accommodate both pipelines in some portions of the alignment. However, joint use of
a shared pipeline is beyond the scope of the Proposed Project. MCWD has stated that it appreciates
MRWPCA's inclusion of the Project Water Conveyance RUWAP Alignment Option in the Draft EIR and
remains willing to discuss potential mutually beneficial options for use of the RUWAP facilities and/or
alignment by the Proposed Project. That said, MCWD notes that such options must ensure that MCWD
can meet its contractual obligations to provide water supplies to the Ord Community.
Page 2-68
The second paragraph on this page has been amended as follows in response to letter
H:
If the RUWAP Alignment for the GWR product water conveyance pipeline is selected, the pipeline may be
constructed by Marina Coast Water District in accordance with the currently designed RUWAP or
MRWPCA may construct a separate pipeline parallel to the currently designed pipeline. Figure 2-30,
Product Water Conveyance Options near Regional Treatment Plant, shows the location of the AWT
Pump Station and the beginning portions of both product water alignment options.
Page 2-72
The first paragraph has been amended as follows in response to L-32:
Under the Proposed Project, product water would be injected into the Seaside Groundwater Basin using
new injection wells. The proposed new Injection Well Facilities would be located east of General Jim
Moore Boulevard, south of Eucalyptus Road in the City of Seaside, including a total of eight injection
wells (four deep injection wells, four vadose zone wells), six monitoring wells, and back-flush facilities.
Space would be included within the Injection Well Facilities area to accommodate the future construction
of replacement injection wells which would be built only if the adjacent deep injection well fails, which
Final EIR
5-32
September 2015
typically would occur after the wells estimated 20 to 30 year life. The proposed site plan for the new
injection wells and backflush facilities are shown in Figure 2-32rev, Injection Well Site Plan. As shown
on Figure 2-32rev, the injection wells, backflush facilities, and connecting driveway with pipelines and
electrical conduits below it, would be located within a 150-foot wide corridor along the City of Seasides
eastern border. This area is also referred to as the Borderland development area adjacent to the Natural
Resources Management Area owned by the U.S. Bureau of Land Management in the Fort Ord Habitat
Management Plan (USACOE, Sacramento District, 1997).
Page 2-73
The final paragraph of Section 2.10.1.1 Injection Wells has been amended as follows in
response to comment L-36:
Collectively, the four shallow and four deep injection wells represent a maximum injection capacity of
about 6,000 gpm. This capacity is well above the Proposed Project design flows of 3,700 AFY (with an
anticipated maximum daily flow rate of 2,780 gpm with no downtime), and thus would allow for backup of
pumping capacity if one or more wells are not functioning, well maintenance, and other operational
benefits. In addition, GWR product water could readily be re-allocated among the two well types and
aquifers as basin conditions change in the future and to ensure compliance with SWRCB Division of
3
Drinking Water requirements (i.e., response retention time). In addition, if there are future changes in the
daily flow rates, sufficient number and total capacities of wells would be available to accommodate peak
flows. Wells may be installed in a phased approach (from north to south) as actual well capacity and
required peak flow rates are more clearly defined. This EIR assumes all eight injection wells would be
built. The design of the buildings associated with the Injection Well Sites would consist of
Monterey/Mission style architecture to match the design of the structures that have been built on the
Santa Margarita ASR site and the Seaside Middle School ASR Site, as requested by the City of Seaside.
Page 2-74
Section 2.10.1.3 has been amended as follows as requested in comment L-25 and L-37:
Monitoring wells would be used to monitor project performance and compliance with State Board Division
of Drinking Water regulations. Because the Proposed Project would recharge two separate aquifers
(Paso Robles and Santa Margarita aquifers), monitoring wells would be installed in both. The monitoring
wells would also be used to satisfy regulatory requirements for monitoring of subsurface travel time, tracer
testing, and other requirements for a groundwater replenishment project. The City of Seaside has
indicated that its approval of the proposed Injection Well Facilities monitoring wells and roadway/pipeline
alignments would be conditioned to require that the project owner relocate any monitoring well within the
interior lands of the Injection Well Facilities site that would create a substantial interference with future
development opportunities in the City of Seaside. Based on current State Board regulations, a minimum
of four monitoring wells would be required: two for each of the two aquifers. One set of monitoring wells
would be located approximately 100 feet from the injection wells between the injection wells and the
nearest down-gradient water supply wells. The second set of monitoring wells would be located between
the project wells and the nearest down-gradient water supply wells. Figure 2-32rev, Injection Well Site
Plan shows the approximate location of the monitoring wells whose locations are subject to discretionary
approval by the City of Seaside and the State Water Resources Control Board and Regional Water
Quality Control Board.
Page 2-77
The first paragraph following the bullets on this page has been amended as follows in
response to comment Q-11:
The estimated construction period for these facilities is approximately 6 months. The temporary
construction area would be approximately 25 to 50 feet wide within the alignment of the 14-inch diameter
back-flush water pipeline, which is approximately 3,000 feet long.). There would be no additional surface
disturbance for construction of electrical conduits beyond that for the 14-inch back-flush water pipeline,
described in the previous section. Construction activities would include a buried electrical power conduit
and instrumentation conduits, all of which would be underground and encased in a concrete ductbank,
which would run in parallel and near the 14-inch back-flush pipeline. The depth of the ductbank trench
would be approximately 4.5 to 5 feet to allow for about 3 feet of cover material. The electrical control
building that would house the electrical and instrumentation (SCADA) transmission equipment would be
approximately 16 feet by 24 feet. Its foundation construction would be slab-on-grade; hence, excavation
This concept is defined in more detail in Chapter 3, Water Quality Permitting and Regulatory Overview.

Final EIR
5-33
September 2015
would be only about 3 feet deep. The construction surface area of each electrical building would be about
600 square feet.
Page 2-77
In the last paragraph, last sentence, the word of has been changed to or as follows in
response to comment N-5:
If the account balance is 800 AF of or less on October 1, then an additional 200 AF would be delivered
from October through March.
Page 2-88
Amend the first three lines of Table 2-22 on this page as follows in response to
comments C-1, C-2, and P-3:
Agency
/Entity
Permitting Regulation/Approval Requirement
Discussion
State Water
Resources
Control
Board
(SWRCB)
Water rights permit for development of new

surface water diversions (Water Code Section
1200 et seq) and wastewater point of discharge
change application/approval (Water Code Section
1211 et seq)
A water right permit is an authorization to develop a water diversion and

use project, including for diversions proposed at the Reclamation Ditch,
Tembladero Slough, Blanco Drain, and Lake El Estero. A wastewater
point of discharge change application would also be needed for the
diversions of agricultural wash water to the Regional Treatment Plant.
Page 2-89
Agency
/Entity
Cities of
Seaside,
Marina,
Sand
City,
Monterey,
and
Salinas
Table 2-22 has been amended as follows in response to comments H-31, J-4d, J-8, L-38,
and P-1:
Permitting Regulation/
Approval Requirement
Discussion
Use Permits,
encroachment/easement
permits, grading permits
and erosion control
permits may be required
pursuant to local
city/county codes.
The Cities of Seaside, Marina, Sand City, Monterey, and Salinas may require discretionary permits
for encroachment, tree removal or trimming, building permits, grading or variances. Note: City of
Marina does not allow trenchless construction under an encroachment permit; the project must
comply with Marina Municipal Code section 12.20.100. Excavations greater than 10 cubic yards
within an Ordinance Remediation District, in the Former Fort Ord areas, require a permit in
compliance with Chapter 15.34, Digging and Excavation, on the Former Fort Ord Ordinance
(Seasides Ordinance). Permit approval is subject to requirements placed on the property by an
agreement executed between the city, the citys redevelopment successor agency, Fort Ord Reuse
Authority, and California Department of Toxic Substances Control. In the event that the project
proponents do not pursue a consolidated permit as discussed in the above line item of this table
related to the Coastal Commissions permitting authority, local agency approvals of one or more
Coastal Development Permits may be required for one or project components in areas that are: (1) in
the Coastal Zone, and (2) governed by Coastal Commission-approved Local Coastal Programs/Land
Use Plans. The potential components/areas that may require local approval are: (1) the Tembladero
Slough diversion and a short segment of the Coastal alignment option of the Product water
Conveyance pipeline in the Monterey County North Land Use Plan area, (2) the Coastal alignment
option of the Product Water Conveyance pipeline in the City of Marina, and (3) the Monterey Pipeline
component of the CalAm Distribution System in Monterey, Sand City, and Seaside. Agreements
would be required with the County of Monterey for surface water diversions from the Reclamation
Ditch, Tembladero Slough, and Blanco Drain, with the City of Salinas for diversion of agricultural
wash water and urban runoff, and with the City of Monterey for diversion of Lake El Estero water.
See Appendix C and Section 4.18 of the Draft EIR for more information.
Page 2-95 and 2-96

Figures 2-3 and 2-4 have been revised in response to comments N-6 and N-7,
respectively. See Figures 2-3rev and 2-4rev at the end of Chapter 5.
Page 2-99
Figure 2-7 has been replaced with Figure 2-7rev and a new Figure 2-7a has been
inserted in response to comments H-39, H-40, and M-25. Both the revised Figure 2-7rev
and new Figure 2-7a are provided at the end of Chapter 5.
Page 2-108
Figure 2-16 has been replaced with Figure 2-16rev at the end of Chapter 5 in response
to comment M-8.
Page 2-129
Figure 2-32, Injection Well Site Plan has been replaced with a more clearly legible
version in response to comment L-17 (see Figure 2-32rev at the end of Chapter 5). The
figure now indicates property lines and borderland areas, the proposed CalAm alignment
in General Jim Moore Boulevard, a clear description of the purpose of the solid red line
(the proposed area of potential effect), and clear markings of the locations of all
Proposed Project facilities. A cross-section has been added to show the approximate

Final EIR
5-34
September 2015
location of the cross section of the subsurface in Figure 2-33. Additionally, the figure
more clearly identifies the backflush basin location and includes additional footnotes.
CHANGES TO CHAPTER 3, WATER QUALITY, STATUTORY AND

REGULATORY COMPLIANCE OVERVIEW
No changes required.
CHANGES TO CHAPTER 4, ENVIRONMENTAL SETTING, IMPACTS,

AND MITIGATION MEASURES
Changes to 4.1 Introduction
Page 4.1-1
In the Table of Contents at the top of the page, the section number for Hydrology and
Water Quality: Groundwater has been changed from 4.1 to 4.10 as follows in response to
comment N-28:
Sections
Tables
Figures
4.1 Introduction
4.2 Aesthetics
4.3 Air Quality and Greenhouse Gas
4.4 Biological Resources: Fisheries
4.5 Biological Resources: Terrestrial
4.6 Cultural Resources, and Paleontological
4.7 Energy and Mineral Resources
4.8 Geology, Soils, and Seismicity
4.9 Hazards and Hazardous Materials
4.10 Hydrology/Water Quality: Groundwater
4.11 Hydrology/Water Quality: Surface Water
and Marine
.
4.1-1
4.1-1 Cumulative Projects Location

Map
4.1-2 Monterey Peninsula Water
Supply Project Location Map
Page 4.1-11
6
Laguna
Seca Villas
(McIntosh
Villas, LLC)
Harper
Canyon
(Harper
Canyon
Realty LLC)
Page 4.1-21
4.1-2
Resource Topics/Sections and

Abbreviations Key
Project Considered for
Cumulative Analysis (listed by
primary geographic area in
which project is located)
Table 4.1-2, Projects Considered for Cumulative Analysis, has been revised as follows in
response to comments R-1 and R-2:
Construction of 20,306 square
feet of professional office space
on the Laguna Seca Office Park
subdivision (Monterey County
Planning Department, 2014).
Geographic scope and

location (Salinas Pump
Station, Salinas Treatment
Facility Source Water
Diversion and Storage Site,
Treatment Facilities)
The project consists of subdivision Geographic scope and
of 344 acres into 17 residential
location (Salinas Pump
lots ranging in size from 5.13
Station, Salinas Treatment
acres to 23.42 acres on 164 acres Facility Source Water
and one 180-acre remainder
Diversion and Storage Site,
parcel
Treatment Facilities)
Unknown
Highway 68 about 3 miles

from the Proposed Project
Injection Well Facilities site
Approved
South of State Highway 68,

Near intersection of Harper
Canyon and San Benancio
Road and about 3.5 miles from
the Salinas Pump Station
Figure 4.1-1 has been revised in response to comments R-1 and R-2. See Figure 4.11rev at the end of Chapter 5.

Final EIR
5-35
September 2015
Changes to 4.2 Aesthetics

Page 4.2-39
The text under the heading Impact Conclusion has been amended as follows in
Upon completion of construction, the proposed pipeline components of the Proposed Project would not
be visible, and structural above-ground development at the other Proposed Project sites would not
substantially degrade the visual character or quality of the surrounding area, resulting in a less-thansignificant impact. No mitigation measures are required. The City of Seaside has expressed concern
about the aesthetic quality of the proposed facilities for future land uses that are planned for the site.
According to their comments on the Draft EIR (See Letter L, comment L-39), the installation of injection
wells within the undeveloped lands east of General Jim Moore could adversely affect the natural terrain
and coastal scrub if the injection well facilities and back flush pit are not properly screened and/or graded
to blend with the rolling terrain. See Appendix A, Scoping Report (see letter from City of Seaside
dated February 2015 in Appendix F of the Scoping Report) and Letter L in the Final EIR. Based on this
input, the following site design measures are .
Page 4.2-40
Mitigation Measure AE-3 at the top of this page has been amended as follows in
response to comment J-7, L-2, L-3, L-29, L-36, and L-39:
Mitigation Measure AE-3: Provide Aesthetic Screening for New Above-Ground Structures. (Applies to
the following project components: Product Water Conveyance Coastal and RUWAP Booster Pump
Station and Injection Well Facilities).
Proposed above-ground features at the Coastal option of the Booster Pump Station and Injection Well
Facilities (at a minimum, at the well clusters and back-flush basin), shall be designed to minimize visual
impacts by incorporating screening with vegetation, or other aesthetic design treatments, subject to
review and approval of the City of Seaside, which has also requested that the buildings be designed with
Monterey/Mission style architecture to match the design of the structures that have been built on the
Santa Margarita ASR site and the Seaside Middle School ASR Site. All pipelines placed within the City of
Seaside on General Jim Moore Boulevard shall be placed underground. MRWPCA shall coordinate with
the City of Seaside on the location of injection wells and booster pumps in order to reduce conflicts with
future commercial/residential development opportunities. Screening and aesthetic design treatments at
the RUWAP Booster Pump Station component shall be subject to review and approval by the City of
Marina. Use of standard, commercial-grade, chain link fencing and barbed wire should be discouraged.
Page 4.2-42
Mitigation Measure AE-4 at the top of this page has been amended as follows in
response to comment J-4c:
Mitigation Measure AE-4: Exterior Lighting Minimization. (Applies to the following project
components: Product Water Conveyance Booster Pump Station - (both Options) and Injection Well
Facilities)
To prevent exterior lighting from affecting nighttime views, the design and operation of lighting at the
Product Water Conveyance Booster Pump Station - RUWAP and Coastal Options and Injection Well
Facilities, shall adhere to the following requirements:
Use of low-intensity street lighting and low-intensity exterior lighting shall be required. No
floodlights shall be allowed at night within the City of Marina.
Lighting fixtures shall be cast downward and shielded to prevent light from spilling onto
adjacent offsite uses.
Lighting fixtures shall be designed and placed to minimize glare that could affect users of
adjacent properties, buildings, and roadways.

Final EIR
5-36
September 2015
Changes to 4.3 Air Quality and Greenhouse Gas

Page 4.3-9
The following subsection has been added under the subsection titled: Senate Bill (SB)
375 (2008) in response to comment H-32:
Executive Order B-30-15

Governor Brown issued Executive Order B-30-15 on April 29, 2015, building on the targets in Executive
Order S-03-05 to guide Californias efforts in reducing statewide GHG emissions. Executive Order B-3015 sets an interim goal for California to reduce GHG emissions to 40% below 1990 levels by 2030 and
directs state agencies to establish measures to achieve this target. Executive Order B-30-15 also directs
ARB to incorporate the 2030 goal into the AB 32 Scoping Plan, requires state agencies to incorporate
climate change into their planning and investment decisions, and requires the California Natural
Resources Agency to update the states climate adaptation strategy every three years. This executive
order, in and of itself, does not establish any new mandates for local governments and does not impose
statutory, regulatory, or legal requirements.
Page 4.3-16
Table 4.3-4 has been changed as follows in response to comment R-3:
Table 4.3-4Revised
Air Quality Significance Thresholds
Construction Thresholds
Maximum Daily Emissions (lbs/day)
Operational Thresholds
Average Daily Emissions (lbs/day)
Volatile organic compound (VOC) or

Reactive Organic Gases (ROG)
Not applicable1
137
Nitrogen oxides (NOx)
Not applicable1
137
Carbon monoxide (CO)
Not applicable
55022
82 (on-site)2
82 (on-site)2
Not applicable
150
Criteria Pollutant
Criteria Air Pollutants
Particulate matter with aerodynamic

diameter < 10 micrometers (PM1010)
Sulfur dioxide (SO22)
Greenhouse Gas Emissions
Quantified GHG Annual Emissions
2,000 metric tons of Co2eq per year or failure to reduce GHG emissions by 16% using
3
alternative energy, energy efficiency, or other GHG reduction measures
Toxic Air Contaminants

Increased cancer risk due to exposure to
Greater than one incident per 100,000 population
toxic air contaminants
1
MBUAPCD applies the emission threshold of 137 pounds per day of ROG or NOx to construction activities that involve non-typical
equipment (i.e., grinders, and portable equipment). The District specifies examples of typical equipment as scrapers, tractors,
dozers, graders, loaders, and rollers (MBUAPCD, 2008; see page 5-3 at: http://mbuapcd.org/pdf/CEQA_full%20%281%29.pdf). For
this project, well construction was the only construction activity assumed to use non-typical equipment not normally used in the
District (e.g., drilling rigs).
2
Emissions exceeding these thresholds are considered significant if dispersion modeling shows that the ambient air quality standard
for that pollutant would be exceeded. Since air pollutant dispersion modeling was not conducted for this project, the emissions
thresholds are used to judge the significance. This threshold applies to stationary sources, not indirect sources.
3
See discussion above in Section 4.3.4.1. Based on the substantial evidence developed and presented by the MBUAPCD staff in
February 2013 and 2014, MRWPCA, as lead agency for this EIR, has elected to use these thresholds to determine if the Proposed
Project would make a considerable contribution to significant cumulative global climate change impacts. The Proposed Project
would not have any direct, stationary sources of greenhouse gas emissions during operations.

Final EIR
5-37
September 2015
Page 4.3-19
The third paragraph under Areas of No Impact has been revised as follows:
Pursuant to MBUAPCD policy, construction projects that use typical construction equipment such as
dump trucks, scrapers, bulldozers, and front-end loaders that temporarily emit precursors of ozone (i.e.,
ROG and NOx), are already accounted for in the emission inventories of state- and federally-required air
quality plans. In addition to typical construction equipment, the Proposed Project would also require some
less common construction equipment such as cranes, jack-and-bore rigs, and other various augers and
drill rigs. However, emissions associated with these equipment types would be minimal (see the
discussion under Impact AQ-1, below). Overall, emissions generated during construction of the Proposed
Project would be consistent with the Triennial Plan Revisions to the Air Quality Management Plan.
Page 4.3-24
Table 4.3-7 and the final paragraph, are revised as follows:
Table 4.3-7revised
Estimated Daily Construction Emissions
Daily Emissions (lbs/day)
Scenario
ROG
NOX
PM10
PM2.5
24
225
12
11
Maximum Daily Emissions (with RUWAP alignment)
66
547
28
24
Maximum Daily Exhaust Emissions for Well Sites
10
104
Maximum Daily On-Site Particulate Matter Emissions
--
145
41
137*
137*
82
No
No
Yes
No
Average Daily (lbs/day)

Average Daily Emissions (based on 378 construction days)
Maximum Daily (lbs/day)
MBUAPCD Thresholds
Exceed Threshold?
* Applies to non-typical construction equipment (i.e., well drilling site construction)
Construction of the Proposed Project would include the use of non-typical construction equipment (i.e.,
cranes, jack-and-bore rigs, and other various augurs and drill rigs); therefore, maximum daily construction
ROG and NOx emissions from these sources were compared to
Page 4.3-25
Mitigation Measure AQ-1 is revised as follows in response to comments L-15, and V-9:
Mitigation Measure AQ-1: Construction Fugitive Dust Control Plan. (Applies to all Project
Component Sites where ground disturbance would occur.)
The following standard Dust Control Measures shall be implemented during construction to help prevent
potential nuisances to nearby receptors due to fugitive dust and to reduce contributions to exceedances
of the state ambient air quality standards for PM10, in accordance with MBUAPCDs CEQA Guidelines.
a. Water all active construction areas at least twice daily as required with water (preferably from
non-potable sources to the extent feasible); frequency should be based on the type of
operation, soil, and wind exposure and minimized to prevent wasteful use of water.
b. Prohibit grading activities during periods of high wind (over 15 mph). .
Page 4.3-32
The first paragraph after Table 4.3-10 has been edited as follows in response to
comment R-5:
There are no locally adopted Greenhouse Gas Emissions Reductions Plans applicable to the Proposed
Project site or area (Gonzales is the nearest City that has adopted a climate action plan). The States AB
32 Scoping Plan .

Final EIR
5-38
September 2015
Changes to 4.4 Biological Resources: Fisheries

Page 4.4.2
The paragraph under Section 4.4.2 Environmental Setting section has been revised as
follows in response to comment M-9:
The potential area affected by these sites includes the immediate vicinity of the site and upstream and
downstream areas that could be influenced by diversion actions associated with the Proposed Project.
The potentially affected water bodies are the Salinas River and the Salinas River Lagoon. Fish habitat
areas upstream of the immediate project vicinity that could be influenced by Proposed Project diversion
actions are the Arroyo Seco, San Antonio, and Nacimiento Rivers. .
Page 4.4-7
Table 4.4-2 has been revised as shown on the following page in response to letter E-4.
Page 4.4-8
The sentence on this page in the first paragraph on page 4.4-8 has been changed to add
the following clarification in response to comment M-11:
In some years, flow releases for smolt migration may not occur because triggers for those releases are
not met. However, in those years National Marine Fisheries Service required MCWRA to provide reservoir
releases and SRDF bypass flows to enhance migration opportunities for juvenile steelhead and postspawn adult steelhead (kelts) as part of Salinas River Diversion Facility operations (National Marine
Fisheries Service, 2007/MCWRA, 2015).
Page 4.4-9
The following paragraph at the top of the page has been amended as follows in response
to comment M-12:
. During the summer conservation release period (with flows of 300 cfs or more), water temperature is
generally maintained at less than 64F (17.8C) within 5 miles of the dam, and 68F (20C) or less within
10 miles of the dam (Monterey County Water Resources Agency, 2001). Current monitoring reports
available from the MCWRA website identify temperature of water released below the dam typically ranges
between 52 and 54F in temperature, and generally remains cooler than 64F within the first 5 miles
below the dam, and below 68F within the first 10 miles of the dam. However, under certain conditions
(i.e. low summer flows during dry years) temperatures reach 73F within 5 miles of the dam and 75F
within 10 miles below the dam (NMFS, 2007). (See Monterey County Water Resources website:
http://www.mcwra.co.monterey.ca.us/fish_monitoring/documents/2014_2%20Salinas%20Basin%20Juven
ile%20O.%20mykiss%20Downstream%20Migration%20Monitoring.pdf).

Final EIR
5-39
September 2015
Table 4.4-2Revised
SCCC Steelhead Life Stage Flow Thresholds for Migratory Passage in the Salinas River
owy~- c~sl
Required
Life
stage
Time Period"
Downstream of
Spreckels Gage
for Migratory
March through
Notes"
- smMarcn ana
(Tit~oret al. 2002}.
June
NIA
NMF$2007,
Page 23
ends in late M ay or June
April through
June
NIA
N~: 2~7,
:'.'~~ ' o;~~les ~.-:..:; an4 June. '""""
March through
NIA
NMF$2007,
;;::;:7.;.., l fe
June
M arch thrQY:Qh
mlill
June
YeatR04.rld
....th peak
Smolt
Outmlgratln
Sou-co
Oocll11erc
Page 7
(late March through earty June).
NMFS 2007
Page 66
56
~~. -~~' ; R~ ~! foet i.~
April through
June
5.6
50
300 cfs
JatuJary
NIA
thrwgh .).me
: tl,;..,_
MCWRA
d 56 cfs
2001. section
emigration fr'om
I';::;';,~ ftows :~Of"''' Ph IOU or
;:
during the period o1
::._":~'
be 112cfs
Kit~ also58 fool ' "'auneu,~~~~~~c;;'_':,r_thechOfln<t~:'::.
;:::.,saJ;,
~
3-itB
1 of
f passage lraMts
fO<
e wwl~
<educe4 to 59 cfs "'"'""'" of
~.lJun eon
hyO:o';.:~n rrom
the receding linb
MCWRA
December 15
throu"' March
NfA
20 130, Page
31
3-119
~~~~~~;!~~~aunt of flow Is requ~r~~ ~oep~=e safe
ooastSI
~~..:.~ag~ ,
r~ri~h.;bit8t
i-~~-~e.~~-a~d;_sandy Salinas Mrbed and the mlorariCI'I from
1 s ~.Marco and ends n
March Uvough
NIA
June
Jan 15 through
NIA
May
~
3--i34
72
Oe<:embet 1
thrwgh Aprit
15
h tne eM or May).
MCWRA
the minlm~.m
o ~ne
of
mlg~tlon criteria
Ltm ~~=:=~~=~dO'M'Istreatn or ~ed<els since the

1more
;;,
1 or .
ci.annelis
5.6
~:~~~eft~~
; ~'in! "'-25%,
, a11enon "'-
~..ce<s
be94cfs
~-an-~~-
N/A
Oe<:ember
througn April
NIA
:::::::: L~::stospa'MI In SCC

M~~~:"_ ~between
upstream primarily
" '"'"
~in
-"'~
from December to April
{NMFS 2007)
through ~n e
NIA
;;~:;23 .
OEt'Oe'mber
throuQh April
NIA
Pf:CtOlbV
throuQh April
151Jds
Ft!2!l!i!!X tg:
~
~~~~!~
n~~'en~ -""";1.~~~_:~~;
; : ; a flow of 154 c:rs would
2001. 5eetion
60
lai ..May Of
.AJne. depending on flow and passaoe condil1ons.
~on tne
AdlAI
lmmtgration
greater1han 50miles. NMFS {2003, p. 24)
~31 ~s_lheJwenlle steelnead mlli'Otlon season,
260 cfs
3-i~
NMFS2007
Paae 69 70
N MES 2007
Page 66
NMF~agQ7
fi9.Ul1
,....!:.':'~e.~ h0;,;, t Ole ~oest ra~'i.!"..
.Tim~~=,:.::
f based on source

Final EIR
' """"'""
IF
~
I ~
I~
a coastal
"""
' fB.g.. NMFS 2<J07,
1cfs
>aa,.aae of
arme penoa
~:;;,'":.~~ei.deoinci~
5-40
o June. peaMg on
. annovgn rne source
may crte
September 2015
Page 4.4-10
The last paragraph has been amended as follows in response to comment M-13:
The lagoon is brackish in the fall due to the freshwater from the inflowing river and salt water from the
high ocean waves (Casagrande et al. 2003). During major runoff events, water elevations in the lagoon
rises and breaching events occur. During breaching events, both natural and artificial, anadromous fish
such as steelhead and Pacific lamprey are able to migrate. The MCWRA intervenes in the Salinas
Lagoon each year by using equipment to either cause or assist the breach, and also manages the lagoon
water levels as part of flood control activities (Monterey County Water Resources Agency, 2011). The
MCWRA Senior Water Resources Hydrologist notes, however, that this does not occur during drought
years (Monterey County Water Resources Agency, 2015).
Page 4.4-13
The second and third paragraphs have been changed to correct the impoundment
areas as noted below and identify dam operations management comments from
MCWRA as follows in response to comment M-15:
The San Antonio River is regulated by the San Antonio Dam, which impounds 350,000 335,000 acre-feet.
The dam was constructed in 1965 and is used for flood protection, aquifer recharge, and recreation. Prior
to construction of San Antonio Dam, the San Antonio River normally did not reach the Salinas River in
late summer (Monterey County Water Resources Agency, 2001)
The Nacimiento River drains 362 square miles and flows 53 miles from its headwaters in the Santa Lucia
Mountains within the Los Padres National Forest to the confluence with the Salinas River. Under natural
conditions, flow in the river is intermittent, drying during the summer months. The river is regulated by the
Nacimiento Dam, located 10 miles upstream from the confluence with the Salinas River. The dam,
constructed in 1957, impounds 350,000 377,900 acre-feet, and provides flood protection and aquifer
recharge to the Salinas Valley (Monterey County Water Resources Agency, 2001 and 2015). The dam
blocks passage of steelhead to the upper portion of the river basin. Dam operation and flow releases on
the Nacimiento River are managed for the following purposes: (1) to facilitate and enhance passage for
upstream migrating adult steelhead on the Salinas River; (2) to facilitate and enhance passage for
downstream migrating steelhead smolts and juveniles on the Salinas River; (3) to maintain the Salinas
River Lagoon; (4) to provide water for the Salinas River Diversion Facility; and (5) to maintain steelhead
rearing habitat below the dam. Below the dam, the Nacimiento River is characterized by a low gradient
and long, wide sections with sparse riparian vegetation. Typical substrate consists of gravel with lesser
amounts of sand and cobble (Monterey County Water Resources Agency, March 2013). Dam operation
and flow releases on the river are also managed for such as 1) flood control, 2) water conservation, 3)
fish passage enhancement and 4) recreation".
Page 4.4-14
The first full paragraph has been changed as follows in response to comment M-16:
The Reclamation Ditch watershed has five main tributaries including Gabilan, Natividad, Alisal and Santa
Rita Creeks (see Figure 4.4-3, Reclamation Ditch Tributaries) and the Merritt Lake drainage. Gabilan,
Natividad, and Alisal Creeks converge at Carr Lake. The outlet from Carr Lake forms the head of the
Reclamation Ditch.
Page 4.4-18
The second and third paragraphs on this page have been amended as follows:
In order to reach the spawning habitat upstream, steelhead would have to navigate through a series of
man-made obstructions that hinder fish passage. Most are passable during periods of prolonged stream
flow to achieve suitable flow depth and duration for passage (CCoWS, 2006). However, there are
passage obstacles at the San Jon stream gage site, which has a trapezoidal channel section and gaging
weir. (See photo on Figure 4.4-5, Photos of Reclamation Ditch and Tembladero Slough Gabilan
Creek Fish Passage Obstacles.) The concrete lip at the lower edge of the apron presents a jumping
obstacle at low flows without a pool at the base. The apron also creates uniformly very shallow flow. The
concrete lip is likely not a problem for upstream migrating adults when there is sufficient flow for passage
over the apron. The lip is also not considered problematic for downstream migrating smolts or adults. The
Boronda Road gage site has rock rip-rap fill in the channel downstream of the road bridge creating a
critical passage riffle (Hagar, February 27, 2015).
The middle reaches of the watershed (between the Gabilan Mountains and the City of Salinas) are
ephemeral and thus do not support fish. Some intermittent reaches support California roach
(Hesperoleucus symmetricus) and threespine stickleback (Gasterosteus aculeatus), which are both
tolerant of high temperature and low dissolved oxygen (Casagrande and Watson, 2006a). Some fish
Final EIR
5-41
September 2015
passage obstacles on Gabilan Creek are shown on photos on Figure 4.4-65a; location of the photos are
shown on Figure 4.4-65b.
Page 4.4-26
The third full paragraph has been amended as follows in response to comment M-17:
The 2007 NMFS Biological Opinion stated that one of the terms and conditions of the Biological Opinion
requested that adult steelhead escapement monitoring be conducted for a minimum of 10 years, unless
NMFS and MCWRA agree to an alternative timeframe. In 2011, an adult steelhead escapement
monitoring program was set up, but subsequently the weir system became inoperable. Due to multiple
factors (per MCWRA Senior Water Resources Hydrologist, a DIDSON camera was installed on February
24 and removed on March 20 and not reinstalled due to flood conditions), monitoring was not conducted
during the entire timeframe outlined in the Biological Opinion (December 1 to March 31)..
Page 4.4-31
The following has been added after the section titled California Fish and Game Code
Sections 1600-1616 in accordance with comments G-16 through G-20:
California Department of Fish and Wildlife Authority

CDFW is a Trustee Agency with responsibility under CEQA for commenting on projects that could impact
plant and wildlife resources. Pursuant to Fish and Game Code Section 1802, the CDFW has jurisdiction
over the conservation, protection, and management of fish, wildlife, native plants, and the habitat
necessary for biologically sustainable populations of those species. As a Trustee Agency for fish and
wildlife resources, the Department is responsible for providing, as available, biological expertise to review
and comment upon environmental documents and impacts arising from project activities, as those terms
are used under CEQA (Division 13 (commencing with Section 21000) of the Public Resources Code).
The Department also has regulatory authority over projects that could result in the "take" of any species
listed by the State as threatened or endangered. If the Project could result in the "take" of any species
listed as threatened or endangered under the California Endangered Species Act (CESA), an Incidental
Take Permit may need to be obtained for the Proposed Project. CEQA requires a Mandatory Finding of
Significance if a project is likely to substantially impact threatened or endangered species (Public
Resources Code Sections 21001(c), 21083, CEQA Guidelines Sections 15380, 15064, 15065). Impacts
must be avoided or mitigated to less than significant levels unless the CEQA Lead Agency makes and
supports a Statement of Overriding Consideration (SOC). The CEQA Lead Agency's SOC does not
eliminate the project proponent's obligation to comply with Fish and Game Code Section 2080.
Page 4.4-31/32 The Blanco Drain has been added to the last sentence on page 4.4-31 in response to
comment M-18:
As stated above, the Salinas River, Reclamation Ditch, Blanco Drain, and Tembladero Slough are listed
as impaired waterbodies under section 303(d) of the Clean Water Act.
Page 4.4-33
Monterey
County
The following text has been added to the bottom of Table 4.4-6 in response to comment
AA-7:
North
County
Land
Use
Plan
Page 4.4-37
Water
Resources
Tembladero
Slough

maintained instream or
supplied to support natural
aquatic and riparian vegetation
and wildlife during the driest
expected year.
Consistent with Mitigation:

Operation of the Proposed Project
with Mitigation Measures BF-2 would
ensure adequate quantities of water
are maintained to support federal and
state-listed fish species during the
driest expected year (See Impact BF2.)
The text in the second paragraph has been amended as follows in response to comment
E-4:
For the Salinas River, passage flow indicator values were evaluated based on past studies, including
thresholds developed by the Monterey County Water Resources as part of the Salinas Valley Water
Project Master EIR and the biological opinion of the effects of the Monterey County Water Resources
Agency, Salinas Valley Water Project in Monterey County, on California South-Central California Coast
Steelhead DPS and its critical habitat (NMFS 2007), discussed above in Section 4.4.2.1. Identified flows
for different life stages are summarized on Table 4.4-2. Based on this review, Table 4.4-7, Threshold
Final EIR
5-42
September 2015
Flows for Maintenance of Steelhead Migration the Lower Salinas River, Downstream of Spreckels
summarizes the passage flow indicator values considered in evaluating impact significance for
maintenance of steelhead migration in Salinas River.
Although the conditions assessed by MCWRA (2001) were addressed differently in the Biological Opinion
for the Salinas Valley Water Project (NMFS 2007 SVWP BO), MRWPCA and its biologists determined
that effects on migration conditions as described in MCWRA (2001) would provide an accurate
assessment of potential Proposed Project effects on steelhead within the Salinas River due to the
Proposed Project. The study reach addressed in the NMFS 2007 SVWP BO (NMFS, 2007; NMFS, 2005;
MCWRA, 2005) to assess channel conditions and relevant passage criteria did not include the reach
downstream of Spreckels and therefore did not directly address channel conditions in the Salinas River
that would be affected by the GWR Project. Channel conditions downstream of Spreckels differ from
those evaluated for fish passage upstream of the Proposed Project due to variation in channel geometry
(width), vegetation, flood facilities and flow (MCWRA 2013). MRWPCA and its consultants considered
these variations as sufficient reason to address fish passage within this reach using standard passage
criteria as provided in Table 4.4-7Rev of the Draft EIR.
Because the maximum potential diversion rate from the Salinas River resulting from the Proposed Project
is 6 cfs, based on an evaluation threshold of 10 percent, MRWPCA and its consultants determined that
significant impacts could occur when baseline flows are 65 cfs or less. Because the Biological Opinion
prescriptions are several fold greater than the flows potentially affected by the Proposed Project, the Draft
EIR focused on conditions within the Proposed Project area that might be affected by the Proposed
Projects maximum diversion rate at a more refined level of detail and specific to the affected reach below
the diversions points.
Nevertheless, to address requests in comments on the Draft EIR, the analysis was expanded in this Final
EIR to further evaluate potential project-related effects to fish passage based on the NMFS 2007 SVWP
BO requirements. Using the NMFS 2007 SVWP BO flows of 150 cfs and 300 cfs for January through midMarch, and mid-March through May, respectively, the expanded analysis shows that the Proposed
Project would not change the frequency or duration of suitable fish passage conditions, further supporting
the less-than-significant impact conclusions of the Draft EIR.
Page 4.4-37
Table 4.4-7 has been revised as follows in response to letter E:
Table 4.4-7Revised
Threshold Flows for Maintenance of Steelhead Migration in the Lower Salinas River, Downstream of Spreckels
Page 4.4-43/44
The last paragraph on page 4.4-43 through the end of page 4.4-44 has been
amended as follows, including changes to Mitigation Measures BF-1a, BF-1b, and the
addition of BF-1c, in response to letter E and comments D-3 and H-33:
Generally, dewatering the channel to complete construction of the in-channel structures would
represent a short-term temporary modification to aquatic habitat through alteration of the channel
and/or flows during construction, with potential harm to individual fish that may be present within
the construction area. Construction activities may also result in temporary degradation of water
quality due to erosion or other materials entering the water course, which is addressed in Section
4.11, Hydrology/Water Quality: Surface Water. With implementation of Mitigation Measure BFPure Water Monterey GWR Project
Final EIR
5-43
September 2015
1a: Construction during Low Flow Season potential impacts to migrating steelhead would be
avoided. Implementation of Mitigation Measure BF-1b, Removal of Aquatic Species during
Construction, would reduce impacts to a less-than-significant level for other aquatic fish species
that may be present at any of the sites, including conducting pre-construction surveys for
tidewater goby at the Tembladero Slough Diversion site. If present, appropriate measures would
be implemented in consultation with the regulatory agencies, and the impact would be reduced to
a less-than-significant level. Mitigation Measure BT-1a, as modified in this Final EIR (see
changes to pages 4.5-75 to 4.5-76 of the Draft EIR in Chapter 5, Changes to the Draft EIR) also
applies because it requires BMPs during construction.
Mitigation Measures
Implement Mitigation Measure BT-1a: Implement Construction Best Management

Practices. (Applies to All Proposed Project Components). See page 4.5-75 to 4.5-76 of the
Draft EIR (as amended in this Final EIR in Chapter 5, Changes to the Draft EIR) for details.
Mitigation Measure BF-1a: Construction during Low Flow Season. (Applies to Blanco
Drain, Reclamation Ditch, and Tembladero Slough Diversions)
Implement Mitigation Measure BT-1a. Conduct construction of diversion facilities, including the
directional drilling under the Salinas River, during periods of low flow outside of the SCCC
steelhead migration periods, i.e. between June and November, which would be outside of the
adult migration period from December through April and outside of the smolt migration period
from March through May.
Mitigation Measure BF-1b: Relocation of Aquatic Species during Construction.

(Applies to Reclamation Ditch and Tembladero Slough Diversions)
Conduct pre-construction surveys to determine whether tidewater gobies or other fish species are
present, and if so, implement appropriate measures in consultation with applicable regulatory
agencies, which may include a program for capture and relocation of tidewater gobies to suitable
habitat outside of work area during construction. Pre-construction surveys shall be consistent with
requirements and approved protocols of the applicable resource agencies and performed by a
qualified fisheries biologist.
Mitigation Measure BF-1c Tidewater Goby and Steelhead Impact Avoidance and
Minimization. (Applies to Reclamation Ditch and Tembladero Slough Diversions)
To ensure compliance with the federal Endangered Species Act (FESA) and the California
Endangered Species Act (CESA), consultation with NFMS/NOAA, USFWS, and CDFW shall be
conducted as required, and any necessary take permits or authorizations would be obtained. If
suitable habitat for tidewater goby (Tembladero Slough) and steelhead cannot be avoided, any instream portions of each project component (where the Proposed Project improvements require
in-stream work) shall be dewatered/ diverted. A dewatering/diversion plan shall be prepared and
submitted to NMFS, USFWS, and CDFW for review and approval. Specific plan elements are
noted below and will be refined through consultation with USFWS, NMFS and CDFW:
Required Pre-Construction surveys identified in Mitigation Measure BF-1b shall be

consistent with requirements and approved protocols of the applicable resource
agencies and performed by a qualified fisheries biologist.
All dewatering/diversion activities shall be monitored by a qualified fisheries biologist.

The fisheries biologist shall be responsible for capture and relocation of fish species
out of the work area during dewatering/diversion installation.
The project proponents shall designate a qualified representative to monitor on-site

compliance of all avoidance and minimization measures. The fisheries biologist shall
have the authority to halt any action which may result in take of listed species.

Final EIR
5-44
September 2015
Only USFWS/NMFS/CDFW-approved biologists shall participate in the capture and

handling of listed species subject to the conditions in the Incidental Take Permits as
noted above.
No equipment shall be permitted to enter wetted portions of any affected drainage

channel. All equipment operating within streams shall be in good conditions and free of
leaks.
Spill containment shall be installed under all equipment staged within stream areas and
extra spill containment and clean up materials shall be located in close proximity for
easy access.
Work within and adjacent to streams shall not occur between November 1 and June 1
unless otherwise approved by NMFS and the CDFW.
If project activities could degrade water quality, water quality sampling shall be
implemented to identify the pre-project baseline, and to monitor during construction for
comparison to the baseline. If water is to be pumped around work sites, intakes shall
be completely screen with wire mesh not larger than five millimeters to prevent animals
from entering the pump system.
If any tidewater goby or steelhead are harmed during implementation of the project, the
project biologist shall document the circumstances that led to harm and shall determine
if project activities should cease or be altered in an effort to avoid further harm to the
species.
Water turbidity shall be monitored by a qualified biologist or water quality specialist

during all instream work. Water turbidity shall be tested daily at both an upstream
location for baseline measurement and downstream to determine if project activities
are altering water turbidity. Turbidity measures shall be taken within 50 feet of
construction activities to rule out other outside influences. Additional turbidity testing
shall occur if visual monitoring indicates an increased in turbidity downstream of the
work area. If turbidity levels immediately downstream of the project rise to more than
20 NTUs (Nephelometric Turbidity Units) above the upstream (baseline) turbidity
levels, all construction shall be halted and all erosion and sediment control devices
shall be thoroughly inspected for proper function, or shall be replaced with new devices
to prevent additional sediment discharge into streams.
Page 4.4-46
Table 4.4-10 Predicted Changes to Steelhead Passage Flow Thresholds in the

Salinas River has been replaced with the following revised version:

Final EIR
5-45
September 2015
Table 4.4-10 Revised

Predicted Changes to Steelhead Passage Flow Thresholds in the Salinas River (Scenario C)
Change in
Reduction
Percent of potential
percentage of
in number
Reduction in
Number of days meeting
migration period meeting
potential
of
days
threshold
threshold
threshold
migration
meeting
occurrence
period
threshold
relative to
Scenario
Life stage/
meeting
relative to
baseline (%)
Baseline
Scenario C
Baseline
C
Period
threshold (%)
baseline
Adult Upstream Migration
60 cfs threshold
Dec
508
474
19.7
18.4
1.3
34
6.7
Jan
1,160
1,130
45.6
44.5
1.2
30
2.6
Feb
1,430
1,402
61.7
60.5
1.2
28
Mar
1,524
1,511
60
59.4
0.5
13
0.9
Apr
1,151
1,137
46.8
46.2
0.6
14
1.2
All
5,773
5,654
46.4
45.5
119
2.1
72 cfs threshold
Dec
467
441
18.2
17.1
26
5.6
Jan
1,111
1,083
43.7
42.6
1.1
28
2.5
Feb
1,397
1,373
60.3
59.3
24
1.7
Mar
1,498
1,484
58.9
58.4
0.6
14
0.9
Apr
1,125
1,107
45.7
45
0.7
18
1.6
All
5,598
5,488
45
44.1
0.9
110
260 cfs threshold

Dec
342
265
13.3
10.3
77
Jan
758
753
29.8
29.6
0.2
18
0.7
Feb
1,074
1,064
46.4
45.9
0.4
10
0.4
Mar
1,203
1,196
47.3
47
0.3
0.4
Apr
846
838
34.4
34.1
0.3
0.1
All
4,223
4,116
34
33.1
0.9
58
0.5
150 cfs threshold

Dec
342
337
13.3
13.1
0.2
0.2
Jan
919
903
36.2
35.5
0.6
16
0.6
Feb
1,220
1,202
52.7
51.9
0.8
18
0.8
Mar
1,363
1,353
53.6
53.2
0.4
10
0.4
Apr
997
987
40.5
40.1
0.4
10
0.4
All
4,841
4,782
190.4
188.1
2.3
59
0.5

Final EIR
5-46
September 2015

Predicted Changes to Steelhead Passage Flow Thresholds in the Salinas River (Scenario C)
Change in
Reduction
Percent of potential
percentage of
in number
Reduction in
Number of days meeting
migration period meeting
potential
of
days
threshold
threshold
threshold
migration
meeting
occurrence
period
threshold
relative to
Scenario
Life stage/
meeting
relative to
baseline (%)
Baseline
Scenario C
Baseline
C
Period
threshold (%)
baseline
Juvenile Downstream Migration
50 cfs threshold
Mar
1,555
1,530
61.2
60.2
25
1.6
Apr
1,179
1,158
47.9
47
0.9
21
1.8
May
762
716
30
28.2
1.8
46
Jun
284
272
11.5
11
0.5
12
4.2
All
3,780
3,676
37.8
36.8
104
2.8
56 cfs threshold
Mar
1,539
1,515
60.5
59.6
0.9
24
1.6
Apr
1,166
1,145
47.4
46.5
0.9
21
1.8
May
720
687
28.3
27
1.3
33
4.6
Jun
275
257
11.2
10.5
0.7
18
6.5
All
3,700
3,604
37
36
96
2.6
150 cfs threshold

Mar
1,363
1,353
53.6
53.2
0.4
10
0.4
Apr
997
987
40.5
40.1
0.4
10
0.4
May
455
444
17.9
17.5
0.4
11
0.4
June
154
148
6.3
6.0
0.2
0.2
2,969
2,932
29.7
29.3
0.4
37
0.4
All
300 cfs threshold

Mar
1,156
1,144
45.5
45.0
0.5
12
0.5
Apr
797
786
32.4
32.0
0.4
11
0.4
All
1,953
1,930
39.0
38.6
0.5
23
0.5

Final EIR
5-47
September 2015
Page 4.4-48
The text under Table 4.4-11 on this page has been amended as follows in response
to comments on the Draft EIR in letters E, F, and G:
Impact Conclusion
The Proposed Project diversions would result in a reduction of flows in the Salinas River and Reclamation
Ditch. Reduction of flows in the Salinas River due to diversions of City of Salinas stormwater and Salinas
Treatment Facility flows with diversions at Blanco Drain would result in reduction of flows during the
SCCC steelhead adult immigration period by 1.0 to 2.8% and during the juvenile outmigration period by
about 1.3 to 2.8%, relative to existing conditions, which is below the significance criteria for flow reduction
related to migration flows. Therefore, in consideration of the timing, frequency, magnitude, and duration of
flow changes, these changes would not result in substantial impacts on SCCC steelhead within the
Salinas River, and would not result in a significant impact on fish migration.
However, flow reductions in the Reclamation Ditch would result in potentially significant impacts to both
adult and juvenile steelhead migration due to flow reductions that exceed 10% and significant reductions
in the days in which fish passage could occur. Implementation of Mitigation Measure BF-2a: Maintain
Migration Flows or Mitigation Measure Alternate BF-2ba: Redesign Modify San Jon Weir to Improve Fish
Passage would reduce impacts to steelhead migration in the Reclamation Ditch to a less-than-significant
level.
The Proposed Project diversions, including all proposed surface water, urban runoff, and wastewater
diversions, were found to not have a significant adverse impact on brackish tidal and wetland habitat in
the downstream portions of the watershed including Old Salinas River channel, Tembladero Slough,
Elkhorn Slough, and Moro Cojo Slough during project operations as documented on pages 4.5-97
through 4.5-105 and 4.11-71 through 4.11-73 of the Draft EIR, as modified in this Final EIR. The final
facility design and flows will incorporate passage acceptable to NMFS. Tembladero Slough at the
diversion site and downstream is tidally influenced. Existing tide gates just upstream of Moss Landing
Harbor influence water levels up to the Highway 183 crossing upstream of the point of diversion at
Tembladero Slough. Based on the technical analysis and mitigation measures prepared by HDR and
Hager Environmental Science (HES) fisheries biologists, the Draft EIR found that project impacts to
fisheries from diversions at this location would be less than significant. Combined diversions from both
Salinas River and Tembladero Slough/Reclamation Ditch from project reduction in flows to the
downstream coastal sloughs in the area (e.g., Elkhorn Slough (a National Estuarine Reserve), and Moro
Cojo Slough downstream of the diversion will also have a less-than-significant impact on fisheries and
aquatic habitat.
Page 4.4-48/49
Mitigation Measure BF-2a has been amended as follows in response to comments E8, E-9, and E-10:
Mitigation Measure BF-2a: Maintain Migration Flows. (Applies to the Reclamation Ditch
Diversion) Implement BF-1a, BF-1b, and BF-1c. Operate diversions to maintain steelhead migration
flows in the Reclamation Ditch based on two criteria one for upstream adult passage in Jan-Feb-Mar
and one for downstream juvenile passage in Apr-May. For juvenile passage, the downstream passage
shall have a flow trigger in both Gabilan Creek and at the Reclamation Ditch, so that if there is flow in
Gabilan Creek that would allow outmigration, then the bypass flow requirements, as measured at the San
Jon Gage of the Reclamation Ditch, shall be applied (see Hagar Environmental Science, Estimation of
Minimum Flows for Migration of Steelhead in the Reclamation Ditch, February 27, 2015, in Appendix G-2,
of thise Draft EIR and Schaaf & Wheeler, Fish Passage Analysis: Reclamation Ditch at San Jon Rd. and
Gabilan Creek at Laurel Rd. July 15, 2015 in Appendix CC of this Final EIR). If there is no flow in Gabilan
Creek, then only the low flow (minimum bypass flow requirement as proposed in the project description)
shall be applied, and these flows for the dry season at Reclamation Ditch as measured at the San Jon
USGS gage shall be met. Note: If there is no flow gage in Gabilan Creek, then downstream passage flow
trigger shall be managed based on San Jon Road gage and flows.
Alternately, as the San Jon weir located at the USGS gage is considered a barrier to steelhead migration
and the bypass flow requirements have been developed to allow adult and smolt steelhead migration to
have adequate flow to travel past this obstacle, if the weir were to be modified to allow steelhead
passage, the mitigation above would not have to be met. Therefore, alternate Mitigation Measure BF-2a
has been developed, as follows:
Final EIR
5-48
September 2015
Mitigation Measure Alternate BF-2a: Modify San Jon Weir. (Applies to the Reclamation Ditch Diversion)
Construct modifications to the existing San Jon weir to provide for steelhead passage. Modifications could
include downstream pool, modifications to the structural configuration of the weir to allow passage or
other construction, and improvements to remove the impediment to steelhead passage defined above.
The above mitigation is subject to compliance with CESA and FESA and appropriate approving agencies
may modify the above mitigation to further reduce, avoid, or minimize impacts to species.
Page 4.4-53
The following citation on this pages has been changed as follows:
California Regional Water Quality Control Board (RWQCB), 2008 2015. CCAMP Home Page, Water
Quality Monitoring Fact Sheet. California Regional Water Quality Control Board, Central Coast
Region, San Luis Obispo, CA. November 30, 2008.
Page 4.4-55
The following references have been added within the list of Monterey County Water
Resources Agency references:
Monterey County Water Resources Agency (MCWRA)/FishBio, 2015. Salinas Basin Juvenile O. mykiss
Downstream Migration Monitoring, 2014 Annual Report - Final. Accessed August 25, 2015. See
following link:
http://www.mcwra.co.monterey.ca.us/fish_monitoring/documents/2014_2%20Salinas%20Basin%
20Juvenile%20O.%20mykiss%20Downstream%20Migration%20Monitoring.pdf
Page 4.4-56
The following references have been added at the bottom of this page:
U.S. Fish and Wildlife Service, 2006. Tidewater Goby Survey Protocol, available online at:
http://www.fws.gov/arcata/es/fish/goby/documents/USFWS%202006%20Tidewater%20Goby%20
Survey%20Protocol.pdf.
U.S. Fish and Wildlife Services, 2015.
Tidewater
http://www.fws.gov/arcata/es/fish/goby/goby.html.
Goby information available online
at:
Changes to 4.5 Biological Resources: Terrestrial

Throughout the chapter
The word frack-out has been replaced with the word frac-out.
Page 4.5-4
The first paragraph under the heading Wetland Delineation has been amended as
follows in response to comment F-2:
The entire Project Study Area, including the Affected Reaches, was evaluated to identify areas potentially
supporting coastal wetlands, state waters, and/or federal jurisdictional wetlands and other waters. A
wetland delineation is provided in Appendix I. The Reclamation Ditch Diversion site, Tembladero Slough
Diversion site, Blanco Drain Diversion site, Lake El Estero, Coastal conveyance pipeline alignment option
(Locke Paddon Lake), CalAm Monterey Pipeline (Roberts Lake), and all of the affected reaches were
identified as potentially containing wetlands under the jurisdiction of the United States Army Corp of
Engineers (USACOE), the State Water Resources Control Board (SWRCB)/Central Coast Regional
Water Quality Control Board (RWQCB), and/or the California Coastal Commission (CCC). .
Page 4.5-25
The first sentence under the heading Tricolored Blackbird has been amended as
follows in response to comment G-15:
The tricolored blackbird is a CDFW species of special concern was listed as endangered in 2015 by
CDFW on an emergency basis. This species is common locally and in coastal districts from Sonoma
County south.

Final EIR
5-49
September 2015
Page 4.5-37
Co mpo n ent Nam e
-4> ...
Sou rce Wat er

Diversi o n and St orage Sites
'0
...
c co>
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(in acres)
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--
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ou
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--
--
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--
--
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ac
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! Not e 11
--
--
--
--
0.7
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--
--
--
--
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--
N/A
--
0.01
1I
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11
--
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--
ac
ac
ac
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by Sen s itive
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-o
"'
- S::.
--
--
ac
ac
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sv s t em
0.6
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1I
u.-~
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o
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62.5
--
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"'4> ...C
......
"' 4>
=
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ac
ac
ac
ac
2.8 ac
13.0
ac
3.4 ac
6.0 ac
13.0 ac
4.8 ac
16.0 ac
September 2015
Potential
12.3
16.4
0.05
0.2
0.3
17.3
0.2
22.5
Jurisdictional W aters
-N/A
-----69.3 ac
ac
ac
ac
ac
ac
ac
ac
ac
LNot e 11
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2.2
Habitat (Potential
----
----------2.2 ac
ac
ESHAl
While riparian habitat is present adjacent to the Project Study Area at LaKe El Estero, it is not within the Project Study Area and, therefore, is not quantified.
No f ormal wetland delineation was conducted at the Salinas Treatnent Facility or at LaKe El Estero outside of the proposed Diversion .; ite where direct, permanent impacts would occur.
Potential coastal wetlands are areas that did not qualify as wetlands as defined by the USACOE, but did meet the conditions required to be considered a wetland as defined by the CCC or authorized local
authority.
""Areas that are located in the coastal zone and meet the criteria to be considered wetlands under the USACOE may also f all under the jurisdiction of the CCC or authorized local authority.
"'" Habitat and resources associated with the Product Water Conveyance Alignment Options within the Project Study Area from just south of j_jgh.!fig!J.!g.[ Drive to the Injection Well Facilities is accounted 'or
under the RUWAP Alignment option; however, this portion of the Project Study Area is part of both the RUWAP and Coastal Product Water Conveyance Alignment Options.
Note 1: This habitat !lll!!l would also be I!Qtentiat!ll considered waters of the state and regulated b~ the SWRCBIRWQ!;;B under the Porter-CotQgne Water Quat!!ll Control Act.
Table 4.5-5 has been amended as shown below in response to comments F-4:

Final EIR
Table 4.5-5
Sensitive Habitats within the Project Study Area
Page 4.5-42
The following has been added after the section titled Species of Special Concern and
prior to the section titled California Native Plant Protection Act (CNPPA) in accordance
with comments G-16 through G-20:
California Department of Fish and Wildlife Authority

CDFW is a Trustee Agency with responsibility under CEQA for commenting on projects that could impact
plant and wildlife resources. Pursuant to Fish and Game Code Section 1802, the CDFW has jurisdiction
over the conservation, protection, and management of fish, wildlife, native plants, and the habitat
necessary for biologically sustainable populations of those species. As a Trustee Agency for fish and
wildlife resources, the Department is responsible for providing, as available, biological expertise to review
and comment upon environmental documents and impacts arising from project activities, as those terms
are used under CEQA (Division 13 (commencing with Section 21000) of the Public Resources Code).
The Department also has regulatory authority over projects that could result in the "take" of any species
listed by the State as threatened or endangered. If the Project could result in the "take" of any species
listed as threatened or endangered under the California Endangered Species Act (CESA), an Incidental
Take Permit may need to be obtained for the Proposed Project. CEQA requires a Mandatory Finding of
Significance if a project is likely to substantially impact threatened or endangered species (Public
Resources Code Sections 21001(c), 21083, CEQA Guidelines Sections 15380, 15064, 15065). Impacts
must be avoided or mitigated to less than significant levels unless the CEQA Lead Agency makes and
supports a Statement of Overriding Consideration (SOC). The CEQA Lead Agency's SOC does not
eliminate the project proponent's obligation to comply with Fish and Game Code Section 2080.
Page 4.5-49
Monterey
County
North
County
Land
Use
Plan
Page 4.5-60
The following has been added to Table 4.5-6 between the analysis of Policy 2.3.3.C2 and
Key Policy 4.3.4 in response to comment AA-7:
Water
Resources
Tembladero
Slough

maintained instream or supplied
to support natural aquatic and
riparian vegetation and wildlife
during the driest expected year.
Consistent with Mitigation:

Operation of the Proposed Project
with Mitigation Measures BF-2a, BT1, and BT-2 would ensure adequate
quantities of water are maintained to
natural aquatic and riparian
vegetation and wildlife during the
driest expected year (See Impacts
BF-2, BT-1, BT-2 and BT-6)
The bulleted list on this page has been amended as follows (revisions to Appendices O
and Q are provided after the changes to Chapter 7 of the Draft EIR in this Final EIR):
Draft Technical Memorandum for the Pure Water Monterey Groundwater Replenishment
Project: Impacts of Changes in Percolation at the Salinas Industrial Wastewater
Treatment Facility on Groundwater and the Salinas River (Todd Groundwater, 2015c)
(Appendix N);
Draft Salinas River Inflows Impacts Report (Schaaf & Wheeler, 2015a) (Appendix ORevised);
Draft Reclamation Ditch Yield Study (Schaaf & Wheeler, 2015b) (Appendix P);
Draft Blanco Drain Yield Study (Schaaf & Wheeler, 2014a). (Appendix Q-Revised); and
Draft Urban Runoff Capture at Lake El Estero (Schaaf & Wheeler, 2014b) (Appendix R).
Page 4.5-75/76
Mitigation Measure BT-1a has been modified as follows in response to comment F-6a,
L-31, and L-33:
Mitigation Measure BT-1a: Implement Construction Best Management Practices. (Applies to

All Proposed Project Components)
The following best management practices shall be implemented during all identified phases of
construction (i.e., pre-, during, and post-) to reduce impacts to special-status plant and wildlife
species:

Final EIR
5-51
September 2015
8. A qualified biologist must conduct an Employee Education Program for the construction
crew prior to any construction activities. A qualified biologist must meet with the
construction crew at the onset of construction at the site to educate the construction crew
on the following: 1) the appropriate access route(s) in and out of the construction area
and review project boundaries; 2) how a biological monitor will examine the area and
agree upon a method which would ensure the safety of the monitor during such activities,
3) the special-status species that may be present; 4) the specific mitigation measures
that will be incorporated into the construction effort; 5) the general provisions and
protections afforded by the USFWS and CDFW; and 6) the proper procedures if a
special-status species is encountered within the site.
9. Trees and vegetation not planned for removal or trimming shall be protected prior to and
during construction to the maximum extent possible through the use of exclusionary
fencing, such as hay bales for herbaceous and shrubby vegetation, and protective wood
barriers for trees. Only certified weed-free straw shall be used, to avoid the introduction of
non-native, invasive species. A biological monitor shall supervise the installation of
protective fencing and monitor at least once per week until construction is complete to
ensure that the protective fencing remains intact.
10. Protective fencing shall be placed prior to and during construction to keep construction
equipment and personnel from impacting vegetation outside of work limits. A biological
monitor shall supervise the installation of protective fencing and monitor at least once per
week until construction is complete to ensure that the protective fencing remains intact.
11. Following construction, disturbed areas shall be restored to pre-construction contours to
the maximum extent possible and revegetated using locally-occurring native species and
native erosion control seed mix, per the recommendations of a qualified biologist.
12. Grading, excavating, and other activities that involve substantial soil disturbance shall be
planned and carried out in consultation with a qualified hydrologist, engineer, or erosion
control specialist, and shall utilize standard erosion control techniques to minimize
erosion and sedimentation to native vegetation (pre-, during, and post-construction).
13. No firearms shall be allowed on the construction sites at any time.
14. All food-related and other trash shall be disposed of in closed containers and removed
from the project area at least once a week during the construction period, or more often if
trash is attracting avian or mammalian predators. Construction personnel shall not feed
or otherwise attract wildlife to the area.
8. To protect against spills and fluids leaking from equipment, the project proponents shall
require that the construction contractor maintains an on-site spill plan and on-site spill
containment measures that can be easily accessed.
9. Refueling or maintaining vehicles and equipment should only occur within a specified
staging area that is at least 100 feet from a waterbody (including riparian and wetland
habitat) and that has sufficient management measures that will prevent fluids or other
construction materials including water from being transported into waters of the state.
Measures shall include confined concrete washout areas, straw wattles placed around
stockpiled materials and plastic sheets to cover materials from becoming airborne or
otherwise transported due to wind or rain into surface waters.
10. The project proponents and/or their contractors shall coordinate with the City of Seaside
on the location of Injection Well Facilities and the removal of sensitive biotic material.
Page 4.5-87
The first paragraph under Impact BT-2, Construction Impacts to Sensitive Habitats, has
been amended as follows in response to comment F-4:
Several sensitive habitats were identified within the Project Study Area (Table 4.5-5; Attachment 8 of
Appendix H; Appendix I). Construction of the Proposed Project may result in direct and indirect impacts
to sensitive habitats (defined herein to include any riparian, federally protected wetlands as defined by
Section 404 of the Clean Water Act, or other sensitive natural communities) within the Project Study Area
with the exception of the component specific study areas of the Salinas Pump Station, Treatment
Final EIR
5-52
September 2015
Facilities at the Regional Treatment Plant, and CalAm Distribution System: Transfer Pipeline. In
accordance with a comment from the RWQCB, impacts to other waters of the U.S. and coastal wetlands
would also constitute impacts to waters of the state. Impacts to sensitive habitats may include direct and
indirect impacts associated with construction activities that could result in the direct loss of habitat, soil
compaction, root damage, erosion, and introduction and spread of non-native, invasive species. These
are considered potentially significant impacts that can be reduced to a less-than-significant level with
implementation of the mitigation measures identified below.
Page 4.5-88
The first paragraph has been amended as follows in response to comment F-4:
Approximately 0.05 acre of other waters of the U.S., potentially under the jurisdiction of the USACOE, that
would also be waters of the state, occurs within the Project Study Area at the Reclamation Ditch
Diversion site (Appendix I). Construction activities would include the installation of permanent wet
well/diversion structure and pipeline, a portion of which would be located within the unvegetated
Reclamation Ditch banks and channel below ordinary high water. This analysis assumes that construction
of the diversion facility may result in up to 0.5 acre of permanent impacts to other waters of the U.S. and
waters of the state; however, the facility may be designed to impact less. Although the site is highly
disturbed, indirect water quality impacts affecting sensitive habitats at the site and within downstream
reaches of the Project Study Area, such as erosion and sedimentation, resulting from construction
activities may also occur due to earth moving/ground disturbance at this site. This is considered
potentially significant impact that can be reduced to a less-than-significant level with implementation of
Mitigation Measure BT-1a and BT-2.
Page 4.5-89
Approximately 0.2 acre of other waters of the U.S., potentially under the jurisdiction of the USACOE, and
0.01 acre of coastal wetlands potentially under the jurisdiction of the County under the CCA (both of
which are also considered to be waters of the state) occur within the Project Study Area at the
Tembladero Slough Diversion site (Appendix I, page 13). Construction activities include the installation of
new wet well/diversion structure and pipeline, a portion of which would be located within the unvegetated
Tembladero Slough banks and channel below ordinary high water. This analysis assumes that
construction of the diversion facility may result in up to 0.2 acre of permanent impacts to other waters of
the U.S. and waters of the state, and 0.01 acre of coastal wetlands potentially under the jurisdiction of the
County under the CCA; however, the facility may be designed to impact less area. Although the site is
highly disturbed, indirect water quality impacts affecting sensitive habitat at the site and within
downstream reaches of the Project Study Area, such as erosion and sedimentation, resulting from
construction activities may also occur at this site. Impacts to other waters of the U.S. and waters of the
state are considered potentially significant impact and can be reduced to a less-than-significant level with
implementation of Mitigation Measure BT-1a. Impacts to wetlands as defined by the USACOE,
SWRCB/RWQCB, and/or the CCC are considered potentially significant impact that can be reduced to a
less-than-significant level with implementation of the Mitigation Measures BT-1a and BT-2a identified
below.
Page 4.5-90
Approximately 0.3 acre of other waters potentially under the jurisdiction of the USACOE (Appendix I),
and 0.7 acre of riparian habitat (arroyo willow thickets) (Attachment 8 of Appendix H) (both of which
would also be considered waters of the state) exist within the Project Study Area at the Blanco Drain
Diversion site.
Page 4.5-90
The third paragraph has been amended as follows in response to comment F-4:
This analysis assumes that construction of the diversion facility may result in up to 0.3 acre of permanent
impacts to other waters of the U.S. and 0.7 acre of riparian habitat potentially under the jurisdiction of the
CDFW (both of which would also be considered permanent impacts to waters of the state); however, the
facility may be designed to impact less. . Impacts to other waters of the U.S. and waters of the state are
considered potentially significant impact and can be reduced to a less-than-significant level with
implementation of Mitigation Measure BT-1a. Impacts to riparian habitat (including waters of the state) are
considered potentially significant impact that can be reduced to a less-than-significant level with
implementation of the Mitigation Measures BT-1a and BT-2a identified below.

Final EIR
5-53
September 2015
Page 4.5-91
The section titled Coastal Alignment Option has been amended as follows in response
to comment F-4:
Riparian habitat (arroyo willow thickets) is present within the Project Study Area at Locke Paddon Lake
along the Product Water Conveyance: Coastal Pipeline alignment option (approximately 0.6 acre)
(Attachment 8 of Appendix H). This habitat type is considered a sensitive habitat by CDFW and is
regulated under Sections 1600-1616 of the Fish and Game Code. Approximately 0.3 acre of wetlands
potentially under USACOE jurisdiction was identified associated with the riparian habitat (Appendix I). In
addition, the entire 0.6 acre of riparian habitat meets the CCA definition of wetlands and may be under
the jurisdiction of the City of Marina under the CCA. These sensitive habitat areas would also be
considered waters of the state under the jurisdiction of the State Water Resources Control
Board/Regional Water Quality Control Board. Impacts to this sensitive habitat are considered potentially
significant impact that can be reduced to a less-than-significant level with implementation of the Mitigation
Measures BT-1a and BT-2a identified below.
Page 4.5-92
The section titled Impact Conclusions has been amended as follows:
The Proposed Project construction could result in impacts to sensitive habitat including wetlands, waters
of the U.S., and riparian areas (which would also be considered waters of the state), central dune scrub,
and eucalyptus grove due to construction activities at various project component sites. For components
located within former Fort Ord, impacts to sensitive habitat have been analyzed and addressed in the
HMP, therefore impacts are considered less-than-significant. Implementation of Mitigation Measures BT1a and BT-2a through BT- 2c, as specified for components located outside of former Fort Ord where
sensitive habitat occurs, would reduce potentially significant impacts to sensitive habitat during
construction to a less-than-significant level.
Page 4.5-92/93
The section titled Mitigation Measures has been amended as follows in response to
comments F-4, F-6a through F-6c, and X-6:
The following mitigation measures apply to the Proposed Project components identified. Implementation
of Mitigation Measure BT-1a (as amended in the Final EIR) and the following mitigation measures would
reduce Impact BT-2 to a less-than-significant level.
Mitigation Measure BT-2a: Avoidance and Minimization of Impacts to Riparian Habitat and Wetland
Habitats. (Applies to Tembladero Slough Diversion, Reclamation Ditch, Blanco Drain Diversion, and
Product Water Conveyance: Coastal Alignment Option.)
Implement Mitigation Measure BT-1a. When designing the facilities at these component sites, the
MRWPCA shall site and design project features to avoid impacts to the riparian and wetland
habitats shown in Attachment 8 of Appendix H and Appendix I, including direct habitat
removal and indirect hydrology and water quality impacts, to the greatest extent feasible while
taking into account site and engineering constraints. To protect this sensitive habitat during
construction, the following measures shall be implemented:
Place construction fencing around riparian and wetland habitat (i.e., areas adjacent to or
nearby the Proposed Project construction) to be preserved to ensure construction activities
and personnel do not impact this area.
All proposed lighting shall be designed to avoid light and glare into the riparian and wetland
habitat. Light sources shall not illuminate these areas or cause glare.
In the event that full avoidance is not possible and a portion or all of the riparian and wetland
habitat would be impacted, the following minimization measures shall be implemented:
Permanently impacted riparian and wetland habitat shall be mitigated at no less than a 12:1
replacement-to-loss ratio through restoration and/or preservation. The final mitigation
amounts for both temporary and permanent impacts to riparian and wetland habitat shall be
determined during the design phase but cannot be less than 2:1 for permanent impacts and
1:1 for temporary impacts, and must be approved by the relevant permitting agencies
(USACOE, RWQCB, CDFW, and the entity issuing any Coastal Development Permit). The
preserved mitigation land shall be managed to improve wetland and riparian conditions
compared to existing conditions. It is expected that the mitigation can occur within the Locke

Final EIR
5-54
September 2015
Paddon Lake watershed, along the Tembladero Slough, and within the Salinas River corridor
near the Blanco Drain near where impacts may occur. A Habitat Mitigation and Monitoring
Plan (HMMP) shall be prepared by a qualified biologist to mitigate for impacts to riparian and
wetland habitat. The HMMP shall outline the details of a riparian and wetland habitat
restoration plan, including but not limited to, planting plan, success criteria, monitoring
protocols to determine if the success criteria have been met, adaptive management protocols
in the case that the success criteria are not met, and funding assurances. Plantings and
revegetation conducted in compliance with this mitigation measure shall be monitored for a
minimum of three years after project completion.
Page 4.5-94
Mitigation Measure BT-2c has been changed as follows in response to comment E-6 and
H-36:
Mitigation Measure BT-2c: Avoidance and Minimization of Construction Impacts Resulting

from Horizontal Directional Drilling under the Salinas River (Applies to Blanco Drain
Diversion)
The project proponents in coordination with the contractor shall prepare and implement a FrackOut Plan to avoid or reduce accidental impacts resulting from horizontal directional drilling (HDD)
beneath the Salinas River. The Frack-Out Plan shall address spill prevention, containment, and
clean-up methodology in the event of a frack out. The proposed HDD component of the Blanco
Drain diversion shall be designed and conducted to minimize the risk of spills and frac-out events.
The Frac-Out Plan shall be prepared and submitted to United States Fish and Wildlife Services,
California Department of Fish and Wildlife, National Marine Fisheries Services, and the Regional
Water Quality Control Board prior to commencement of HDD activities for the Blanco Drain
Diversion construction. The following are typical contents of a Frac-Out Plan:
Project description, including details of the HDD design and operations
Site description and existing conditions
Potential modes of HDD failure and HDD failure prevention and mitigation
Frac-out prevention measures (including for example, geotechnical investigations,

planning for appropriate depths based on those investigations, presence of a qualified
engineer during drilling to monitor the drilling process, live adjustments to the pace of
drill advancement to ensure sufficient time for cutting and fluid circulation and to prevent
or minimize plugging, maintaining the minimum drilling pressure necessary to maintain
fluid circulation, etc.)
Monitoring requirements (for example, monitoring pump pressure circulation rate,

ground surface and surface water inspection, advancing the drill only during daytime
hours, on-site biological resource monitoring by a qualified biologist)
Response to accidental frac-out (including stopping drilling, permitting agency

notification, surveying the area, containing the frac-out material, contacting the project
biological monitor to identify and relocate species potentially in the area, turbidity
monitoring, procedures for clean-up and mitigation of hazardous waste spill materials,
preparation of documentation of the event, etc.)
Coordination plan and contact list of key project proponents, biological monitor, and
agency staff in the event of an accidental frac-out event.
Page 4.5-103
The following has been added after the first full paragraph, prior to the section titled
Treatment Facilities at the Regional Treatment Plant in response to comments C-5, E-2,
E-4, E-5, E-7 to E-10, F-6, F-8, F-9, F-9a to f, G-2 to G-12, G-13, S-8, V-5 V-10, X-6, and
AA-8:
Combined Impacts of Source Water Diversions on Sensitive Habitats due to Water Flow and
Level Changes
Potential changes to water bodies that may adversely impact aquatic habitat, ecosystems, and species in
the affected reaches include: (1) water flow or water surface elevation reductions that may also reduce
Final EIR
5-55
September 2015
the amount and duration of wetted habitat, soil saturation and moisture, and/or plant uptake of water, and
(2) water quality worsening, in particular for this analysis, potential increases in salinity (and in particular,
the inter-related effects of inland surface water flow inputs and salinity in the lower watershed).
Salinas River Watershed to Salinas River Lagoon
Water levels/flows. The proposed diversions of all three proposed source waters in the Salinas River
watershed (Salinas urban runoff, agricultural wash water, and Blanco Drain) would reduce flows in the
Salinas River by less than 1% total on an annual average basis, and would not affect water levels in the
Lagoon. United States Geological Society (USGS) data and county gage data demonstrate that even with
the Salinas River dry during the driest year on record (2014), the water levels in the Lagoon were
consistent with historic water levels. Table 4.5-11a, below, shows the average monthly water level in the
Lagoon during 2013 and 2014. Note that even when the Salinas Treatment Facility ponds were dry (July
to November 2014), the average lagoon water levels were comparable to the previous year when the
ponds were full.
Table 4.5-11a
Salinas River Lagoon Stage (feet)
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
2013
9.7
10.2
10.3
10.3
10.5
10.3
10.3
10.4
10.4
10.1
10.1
10.1
2014
10.1
10.3
10.7
10.4
10.3
10.3
10.6
10.5
9.7
9.5
10.0
11.8
Notes:
1. CDEC Station SLG, maintained by MCWRA, datum not specified
2. Lagoon was open to the ocean from 12/12/2013 to 1/28/2013, and remained closed through September 2015 or later.
Daily average flow at Spreckels gage was 0 cfs from 11/11/2013 to 12/12/2014.
3. Salinas River Diversion Facility operated 4/8/2013 to 11/8/2013, but not in 2014.
4. Salinas Treatment Facility flows diverted to MRWPCA 4/2/2014 to 11/26/2014. Ponds were empty by 7/1/2014.
The proposed agricultural wash water, Salinas stormwater, and the Blanco Drain diversions would reduce
some inputs to the Salinas River and Lagoon upstream of the Salinas River Diversion Facility (SRDF).
The proposed diversions in the Reclamation Ditch and Tembladero Slough watersheds would not result in
any changes to water surface elevation in, or flows to or from, the Salinas Lagoon due to the operation of
the slide gate and the relative elevations and flows of the two water bodies (i.e., flow from Tembladero
Slough into OSR to the south of their confluence toward the Salinas Lagoon rarely occurs) as discussed
in detail above.
Salinity. Due to the very small percentage change in total Lagoon inflows due to the Proposed Project
(less than 1%), no measurable salinity changes to the Lagoon would occur.
Tembladero Slough and the OSR Channel
Water Levels/Flows. The proposed diversions in the Reclamation Ditch and Tembladero Slough would
result in reduction in flows to the Tembladero Slough and OSR Channel as acknowledged in the Draft
EIR, but this reduction would not be additive to flow reductions in the Salinas River watershed as the
Reclamation Ditch watershed is not tributary to the Salinas River. The proposed diversions of agricultural
wash water, Blanco Drain, and Salinas urban stormwater to the Regional Treatment Plant would
constitute less than one percent of the average annual flows within the Salinas River. Based on the minor
amounts of dry-season, inland surface water flows, the beach berm, and the operation of the slide gate at
the Lagoon, the proposed flow reductions to the Salinas River, would not result in detectable changes in
water levels during the dry season in the Lagoon even in dry years with minimal surface water flow inputs
as demonstrated by Table 4.5-11a.
The combined diversions from the Reclamation Ditch and Tembladero Slough system represent less than
one percent of the average annual flow entering Moss Landing Harbor and Elkhorn Slough due to the
tidal action of the ocean on those waterbodies. The combined diversions from both the Salinas River
watershed and the Tembladero Slough/Reclamation Ditch watersheds would have no detectable effect on
the flows nor water surface elevations in any water bodies north of the Potrero Tide Gate (see discussion
below under Moss Landing Harbor, Elkhorn Slough, and Moro Cojo Slough and Figure 4.5-3new).

Final EIR
5-56
September 2015
The Lagoon flows that pass through the Lagoon slide gate and the Reclamation Ditch/Tembladero Slough
system are both tributary to the OSR Channel. The Lagoon flows into the OSR Channel (at its southern
terminus) through the Lagoon slide gate, and Tembladero Slough flows into the OSR Channel
approximately 1.5 miles north. See Figure 4.5-3new. The only water bodies that would have any
potential additive water surface elevation changes due to diversions from both watersheds would be the
OSR Channel and to a lesser extent the lowest reach of the Tembladero Slough due to the tidal gate and
tidal flow backwater effect.
The amount of surface water that flows into the OSR Channel from the south is controlled by a slide gate
at the Lagoon (called the Salinas Lagoon Gate on Figure 4.5-3new). Near the northern end, the OSR
Channel experiences a diurnal backwater cycle due to the rising and falling tides and the operation of the
Potrero Tide Gate. Because of the tidal control and the Lagoons stable dry season water levels
described above, water levels would not be affected by the Proposed Project under conditions wherein all
Proposed Project diversions (from both watersheds) would occur. The Proposed Project would not result
in any loss of inundation in the OSR Channel and therefore, the combination of all proposed diversions
would have less than significant impacts on water levels and the associated beneficial uses and habitats
that rely upon those water levels because there would be no measurable loss of inundation nor reduced
soil moisture.
Salinity. Diverting freshwater from the OSR Channels tributaries may increase the salinity within the OSR
Channel, which is currently a brackish water body due to leakage through soils and the Potrero tide gate
and the Lagoon slide gate (Nicole et al., 2010 and Inman et al., 2014). There is a potential for increases
in salinity near the water surface, and/or longer periods of salinity accumulation in the Tembladero Slough
and the OSR Channel before seasonal flushing by winter runoff. This potential water quality impact is
analyzed in the EIR (Draft EIR, pages 4.11-71 through 4.11-72) where the analysis concludes that the
Proposed Project would have a less-than-significant impact on the water quality because the salinity
changes would be within the range of salinities that are currently found in these water bodies every year.
Species and habitats relying upon the OSR and Tembladero Slough waters have demonstrated their
tolerance for high salinity waters. In particular much higher salinity levels (above 15 ppt) are seen during
prolonged dry periods, such as late summer and fall of 2013 through 2015. (Inman et al, 2014 and Nicole,
et al., 2010) Conversely, even moderate precipitation events during the Inman and Nicole studies resulted
in drops of salinity to below 1 ppt. These precipitation events that result in flushing flows would continue
to occur under Proposed Project operations.
Diversions from the Reclamation Ditch and Tembladero Slough would be most needed by the Proposed
Project during dry years when irrigation demands are highest; during and after storm events Proposed
Project source water requirements are expected to be met by municipal wastewater flows. Due to the tidal
influence, water levels in the Tembladero Slough would not be noticeably affected by the Proposed
Project, so wetland species would not see a loss of fresh water-wetted habitat due to salinity changes,
only an increase in the duration of periods of higher salinity. The existing system exhibits a wide variation
of salinities due to the influence of the ocean tidal fluctuations, storm surges, agricultural tile drain and
surface runoff, and urban runoff; therefore, based on the above information, these changes would result
in a less-than-significant impact on surface water quality in the affected reaches of the Reclamation Ditch,
Tembladero Slough, and the Old Salinas River Channel.
Large rain events produce flushing flows through the OSR Channel, which push the brackish water past
the tide gates and into the Moss Landing Harbor. These flows occur during storm events in the winter
months, when project diversions would be much lower than during the dry season, and if diversions do
occur would be a very small fraction of the surface water flows. Summer rain events can and do generate
flows up to 70 cfs in the Reclamation Ditch/Tembladero Slough system. The Proposed Project would
divert up to 9 cfs from the Reclamation Ditch and Tembladero Slough, leaving sufficient flow for thorough
flushing of brackish water. In addition, as discussed above, the Proposed Project Salinas River watershed
diversions would not result in measurable reduction in surface water elevation in the Salinas Lagoon and
the OSR Channel. In addition, during these rain events the diversions would be reduced due to
corresponding reduction of recycled water demand by agricultural irrigators, therefore, combined
diversions would not prevent dry-season brackish water flushing from occurring in the lower watershed
consistent with the existing conditions.

Final EIR
5-57
September 2015
Moss Landing Harbor, Elkhorn Slough, and Moro Cojo Slough

Water Levels/Flows. Due to the Potrero Tide Gate controls on the OSR Channel, incoming fresh water
mixes with the impounded, brackish water during rising tide cycles, and the brackish water moves through
the Potrero Road tide gates into Moss Landing Harbor and the Monterey Bay on falling tides. A portion of
the water from the OSR Channel is pushed back into Elkhorn Slough on the rising tide. The Moro Cojo
Slough flows into the Moss Landing Harbor through a separate tide gate. The average tidal cycle in
6
Elkhorn Slough is 122 x 10 cubic-feet of water (800 acres of surface area and an average tidal change of
3.5 feet). Assuming two cycles per day, the average inflow rate (over 6 hours) to Elkhorn Slough from the
harbor and ocean is 5,670 cfs. The typical freshwater inflow rate to the OSR Channel in summer is 10 to
4
15 cfs (combined Salinas River plus Tembladero Slough ). Doubling the typical peak rate to account for
the tidal cycle, 30 cfs is about 0.5% of the average inflow rate for Elkhorn Slough.
The Elkhorn Slough was determined not to be a waterbody within which biological species, ecosystems,
or habitats would be potentially affected by the Proposed Project diversions (i.e., outside the project study
area for terrestrial biological resources). However, Moss Landing Harbor and Elkhorn Slough were
appropriately included as part of the project study area in Section 4.11, Hydrology and Water Quality:
Surface Water due to the potential for changes to quantities, qualities, and timing of inflows. The study
area conclusion was based on analysis of combined diversions of all Proposed Project source waters,
storm runoff, and daily tidal cycles. The analysis of hydrology and water quality showed that the Potrero
Tide gate is the farthest point downstream where biological species might have any potential effect from
combined project diversions. As described above in Draft EIR Section 4.5.4.4, the effect of water
flow/level changes due to all Proposed Project diversions on biological resources (including fisheries and
terrestrial/aquatic species) in the affected portions of the Reclamation Ditch, Tembladero Slough, and the
OSR Channel would be less than significant (with Mitigation Measure BF-2a or Alternate Mitigation
Measure BF-2a for fish passage in the Reclamation Ditch). In addition, the Proposed Project would result
in no impact due to water level/flow changes within Moss Landing Harbor, Elkhorn Slough, Monterey Bay,
and other connected water bodies.
The Moro Cojo Slough flows into the Mos s Landing Harbor through a separate channel; similar to the
OSR Channel, it is also protected with a tide gate. Moro Cojo flows would not be affected at all because
its water surface elevations and flows are not affected by any increases or decreases in water surface
elevations nor flows in the OSR Channel. Moro Cojo Slough is tributary directly to the Moss Landing
Harbor and inflows from the Harbor are controlled by another tide gate. The Proposed Project would not
divert any flows from the Moro Cojo Slough and would not change the amount of flow into or out of the
Moro Cojo Slough.
Salinity. The analysis in Appendix AA shows that the Proposed Project would cause less than 0.8%
salinity increase at Elkhorn Slough and 0.8% would occur only in a peak event using conservative
assumptions such as drought conditions with low tidal influence. On a daily, weekly and monthly average,
the Proposed Project would cause changes of even less than that amount (i.e., an undetectable change
given the wide variations of salinity in the slough caused by the tidal cycle each day). Salinity levels
(including measurements of electroconductivity and total dissolved solids concentrations), are used as the
primary indicator of the relative amounts of freshwater versus saline ocean water in a water body. Thus,
the Proposed Project would not result in an adverse impact on the biological resources or other beneficial
uses within the Elkhorn Slough. In fact, the Proposed Project would result in a reduction in pollutant
loading (including nutrients, such as nitrate/nitrogen and orthophosphate/phosphorous) in the Moss
Landing Harbor and Elkhorn Slough as described on pages 2-5, and 4.11-64 through 4.11-75 of the Draft
EIR.
Conclusions Regarding Combined Impacts of Source Water Diversions on Sensitive Habitats and Species
due to Water Flow and Level Changes
Implementation of all proposed source water diversions would not result in measurable or detectable
water level changes in the Lagoon, OSR Channel, Moss Landing Harbor, Elkhorn Slough, Moro Cojo
Slough, and Monterey Bay/Pacific Ocean. The EIR found that stable water surface elevations would be
Flows from Moro Cojo Slough are omitted from the estimate because (1) salinity data was not available, and (2)
these flows will be unaffected by the Proposed Project.

Final EIR
5-58
September 2015
maintained and thus proposed changes to flow would not adversely affect biological resources (habitat,
species, and other ecosystem services) due to loss of inundation in downstream water bodies that
support habitat, even during the summer months and drought years when all or a large majority of the
proposed diversions would occur. Specifically, no detectable changes in the amount or areas of
inundation (and corresponding soil saturation/moisture and plant uptake) would occur in these water
bodies; therefore no adverse impacts on aquatic habitats (including wetland and riparian) due to the
combined diversions of the Proposed Project. The proposed diversions would reduce the volume of
freshwater entering the system, particularly in the dry summer months, and could result in increased
salinity within these already brackish channels. The Proposed Project includes minimum in-channel bypass flows for habitat protection. These minimum flows are consistent with the actual flows measured
during the late summer and fall seasons of the current drought (2013-2015). The slight increase in salinity
that would occur in some months of each year is within the normal fluctuation of the existing, background
conditions. The additional technical analysis in Appendix AA clarifies the assumptions in the hydrology,
water quality, and biological resources impact analysis and confirms the conclusions in the Draft EIR.
Specifically, operational impacts of diverting all Proposed Project source waters in the Salinas Valley
would result in less-than-significant impacts on the riparian and wetland habitats in and near the
waterbodies of the lower watersheds of the Salinas River and the Reclamation Ditch/Tembladero Slough,
including the following water bodies: the Reclamation Ditch (from Davis Road to its confluence with
Tembladero Slough), the Tembladero Slough, and the Old Salinas River Channel. The Proposed Project
would have no impact on riparian and wetland habitat in and near the following water bodies: Salinas
River, Salinas River Lagoon, tributaries to the Reclamation Ditch, the Reclamation Ditch upstream of
Davis Road, the Moss Landing Harbor, Moro Cojo Slough, Elkhorn Slough, and Monterey Bay/Pacific
Ocean.
Page 4.5-105
The following has been added to the first paragraph on this page prior to the heading
Mitigation Measure in response to comments: C-5, E-2, E-4, E-5, E-7 to E-10, F-6, F-8,
F-9, F-9a to f, G-2 to G-12, G-13, S-8, V-5 V-10, X-6, and AA-8.
As described in detail in the section titled Combined Impacts of Source Water Diversions on Sensitive
Habitats due to Water Flow and Level Changes, above, operational impacts of diverting all Proposed
Project source waters in the Salinas Valley would result in less-than-significant impacts on the riparian
and wetland habitats in the lower watersheds of the Salinas River and the Reclamation Ditch/Tembladero
Slough, including the following water bodies: the Reclamation Ditch (from Davis Road to its confluence
with Tembladero Slough), the Tembladero Slough, and the Old Salinas River Channel. The Proposed
Project would have no impact on riparian and wetland habitat in and near the following water bodies: the
Salinas River, the Salinas River Lagoon, tributaries to the Reclamation Ditch, the Reclamation Ditch
upstream of Davis Road, the Moss Landing Harbor, Moro Cojo Slough, Elkhorn Slough, and Monterey
Bay/Pacific Ocean.
Changes to 4.6 Cultural and Paleontological Resources

Changes to 4.7 Energy and Mineral Resources

Page 4.7-19
The following reference has been deleted:
California Geological Survey, 2006.
Changes to 4.8 Geology, Soils, and Seismicity

Page 4.8-17
Table 4.8-2 regarding the consistency of the Proposed Project with Monterey County
General Plan Policy S-1.7 (last column) has been amended as follows in response to
comment M-19:

Final EIR
5-59
September 2015
Consistent: The Proposed Project would comply with the California Building Standard Code and all other
county and state requirements for geologic hazards and geotechnical conditions. See Section 4.8X,
Geology, Soils, and Seismicity for a discussion of seismic hazards and potential mitigation. Also see
Appendix K, (Preliminary Geotechnical Evaluation Groundwater Replenishment Project EIR, Ninyo and
Moore, December 2014 January 2015).
Page 4.8-39
The last full paragraph on this page has been changed as follows in response to
comment M-21:
The only project component that would wet the upper sediments is the back-flush basin, a 5-foot deep
shallow dug-out basin (three feet water depth plus two feet free board) where water would be discharged
for several hours four three times per week for injection well maintenance (assuming one well is in
standby mode during any one week). Water percolated through the basin would recharge the Paso
Robles aquifer. The overall basin depth would be five feet. The embankment of the basin would have 3:1
side slopes and 12-foot wide perimeter access road, and it would not contain structures (except a
discharge pipe) or other features that would be negatively impacted from settlement or hydro-collapse.
The basin would not be located adjacent to the wells. The proposed back-flush basin may cause wetting
of the shallow eolian deposits. However, the back-flush basin is only expected to receive pumped water
for a few 3 to 4 hours approximately three times per week so settlement due to hydro-collapse is
anticipated to be relatively minor and limited to the footprint of the back-flush basin which can
accommodate minor settlement. As such, the impact of hydro-collapse resulting from use of the backflush basins would be less than significant.
Changes to 4.9 Hazards and Hazardous Materials

Page 4.9-49
The first bullet on this page has been amended as follows in response to comment R-2:
Salinas Area Salinas Pump Station Diversion and Salinas Treatment Facility sites. The
pump station site is located within the City of Salinas, and the treatment plant site is located
nearby within the unincorporated area of the county. No cumulative projects have been
identified in the vicinity of these two Proposed Project sites, except for several development
projects along Highway 68 to the west of the project sites (#6,7,8) within the Monterey County
area. The exact timing of construction is not known, but due to the distance from the
Proposed Project sites (about three miles to #6 and #8 [Harper Canyon and Ferrini Ranch] as
5
shown on Figure 4.1-1 rev ),and the other projects, there would be no overlapping
cumulative impacts related to transport or use of hazardous materials during construction or
operations. Furthermore, cumulative projects would be required to comply with the existing
and future laws
Page 4.9-53
References on this page have been amended as follows:
State Water Resources Control Board, 2014. Envirostor and Geotracker, accessed April 2014 and
February 2015.
Todd Groundwater, 2015. Draft Recharge and Impacts Assessment Report, Groundwater
Replenishment (GWR) Project. February March, 2015.
Changes to 4.10 Hydrology and Water Quality: Groundwater

Page 4.10-3
The first paragraph under the heading 4.10.2.1 Terminology and Concepts have been
amended as follows:
Groundwater is the water occurring beneath the earths surface and hydrogeology refers to the study of
how that water interacts with the underlying geologic units of rock and soil. Most groundwater occurs in
See Figure 4.1-1rev at the end of Chapter 5.

Final EIR
5-60
September 2015
material deposited by streams lakes, and oceans, generally called alluvium. Alluvium consists of sand
and gravel deposits and finer-grained deposits such as clay and silt. Fluvial deposits, although commonly
generically included with alluvium, more specifically refer to deposits laid down by rivers and streams as a
result of bank erosion, where the material is transported and redeposited in the form of bars, points, and
flood plains.
Page 4.10-4
The last paragraph has been changed as follows in response to comment M-23:
The main part of the Salinas Valley Groundwater Basin is occupies about 560 520 square miles beneath
the floor of Salinas Valley (MCWRA, 2006). The basin is a structural trough that and has been filled over
1
2
geologic time with up to 10,000 to 15,000 feet of Tertiary and Quaternary period marine and terrestrial
sediments (California DWR, 2004b). The main part of the Salinas Valley Groundwater Basin has been
divided into four subareas referred to as the 180/400-Foot, East Side, Forebay, and Upper Valley
Subareas or Subbasins, based on sources of recharge and stratigraphy (California DWR, 2003; MCWRA,
2006, 2013). The subbasins in the project area are shown on Figure 4.10-1. The DWR has redesignated
the previously named Pressure Subarea as the 180/400-Foot Aquifer Subbasin, and this EIR section
uses this updated terminology (California DWR, 2003). The 180/400-Foot Aquifer Subbasin also includes
shallower (Dune Sand Aquifer along the coast and Perched A Aquifer inland) and deeper (900-Foot
Aquifer) aquifers, as discussed below. DWR (2003) recognizes four additional subbasins around the
periphery of the main part of the basin. These include the Seaside and Corral de Tierra subbasins
between Salinas and Monterey. The Seaside Basin as used in this report (see Section 4.10.2.4)
corresponds to parts of DWRs Seaside and Corral de Tierra subbasins.
Page 4.10-4
1
2
Footnotes 1 and 2 have been changed as follows in response to comment M-22:
Tertiary time is from 1.86 to 65 million years ago.

Quaternary time is from the present to 1.86 million years ago.
Page 4.10-5
The first sentence under the heading 180/400 Foot Aquifer Subbasin and Aquifers on this
page has been changed as follows in response to comment M-23:
The 180/400-Foot Aquifer Subbasin encompasses approximately 140 130 square miles, beginning at the
coast and extending southeastward and inland to around the city of Gonzales.
Page 4.10-6
The first sentence under the heading East Side Subbasin and Aquifers on this page has
been changed as follows in response to comment M-23:
The East Side Subbasin is located inland to the northeast of the 180/400 Foot Aquifer Subbasin and
encompasses about 125 90 square miles along the northeastern side of the Salinas Valley from Gonzales
to east of Castroville.
Page 4.10-6
The first paragraph under the heading Salinas Valley Groundwater Basin Flow and
Occurrence on this page has been changed as follows in response to comment M-24:
A groundwater basin is much like a surface water reservoir. When water is removed from storage, the
water level drops until the supply can be replenished by inflow or recharged by rainfall or stream flow.
Recharge comes from the infiltration of water into the subsurface and the migration of water downward
into the aquifers. Along the coast, recharge can also come from the ocean, which in some cases, results
in the intrusion of seawater into coastal aquifers. When water is extracted from the basin, some inflows,
from head-dependent boundaries such as the ocean and the Salinas River, increase and thereby tend to
counteract the water-level decline.
A groundwater basin functions as a large storage container with inflows and outflows. Unlike surface
water reservoirs, however, flows into and out of a basin and flow within a basin are subject to physical
and practical limitations. Because water must move through tiny pores between mineral grains that
comprise the basin fill deposits, flows are much slower than in surface streams. Substantial amounts of
recharge to water supply aquifers derive from downward percolation of rainfall and applied irrigation water
that infiltrate through the ground surface. This source of recharge can be greatly reduced if extensive
layers of clay are present, such as in the 180/400-Foot Aquifer subarea. If the water table is near the
ground surface, groundwater can be hydraulically coupled vertically to surface water, with flow moving in
either direction depending on the relative elevations of the stream surface and water table. Thus,
groundwater pumping near the Salinas River lowers the water table and thereby increases the rate of
Final EIR
5-61
September 2015
percolation from the river. Similarly, groundwater pumping near the coast can lower groundwater levels to
below sea level and cause saltwater in offshore parts of the aquifer to flow inland (seawater intrusion).
Unlike the surface of a lake or reservoir, the water table (or potentiometric surface in deeper aquifers) is
not flat. When a well pumps, it creates a local depression in that surface, which causes groundwater from
surrounding areas to flow toward the well. A group of pumping wells can cause a regional water-level
depression commonly referred to as a pumping trough. A large trough is present in the East Side
subarea, for example. Another difference between groundwater basins and surface reservoirs is that
aquifer permeability is neither uniform nor in some cases permanent. Alluvial textures within the Salinas
Valley deposits range from clay to gravel, and most groundwater movement is through the relatively
coarse-grained deposits. Also, fine-grained deposits can compress when groundwater levels are lowered
by pumping from adjacent aquifers. This compaction yields a one-time release of stored water but also
results in subsidence at the land surface. Seawater intrusion, subsidence, dry wells and desiccation of
riparian vegetation impose practical limitations on the amount of groundwater that can be pumped from a
basin. Whereas a surface reservoir can usually be drawn down to nearly empty without significant
adverse effects, lowering of water levels in a groundwater basin is commonly limited to tens of feet or in
favorable areas perhaps more than 150 feet before adverse effects become unreasonable.
Page 4.10-9
The third paragraph under the heading Seawater Intrusion in the Salinas Valley
Groundwater Basin has been amended as follows:
Figures 2-9 Revised illustrates the seawater intrusion areas as of 2011-2013 within the 180-Foot and
400-Foot Aquifers, respectively (MCWRA, 2014). The 2011 estimates of seawater intrusion within the
180-Foot and 400-Foot Aquifers indicate that seawater has intruded to a maximum of approximately eight
miles and 3.5 miles inland, respectively, inferred from chloride concentrations greater than 500 mg/L. The
seawater intrusion has resulted in the degradation of groundwater supplies, requiring urban and
agricultural supply wells within the affected area to be abandoned or destroyed (MCWRA, 2001).
Seawater intrusion in the Salinas Valley Groundwater Basin was first detected in 1938 and documented
in 1946 when the State Department of Public Works (now known as DWR) published Bulletin 52
(California DWR, 2004b).
The footnote on this page is also amended, as follows:
1
This value represents the Recommended Upper Range Consumer Acceptance Contaminant Level Range pursuant
to Title 22 of the California Code of Regulation, Section 64449(a).
Page 4.10-15 to 4.10-16
The last sentence on page 4.10-15 has been changed as follows in

response to comment N-9:
The Proposed Project Injection Well Facilities would be located within a portion of the Seaside Area
Subbasin of the Salinas Valley Groundwater Basin as defined by DWR Bulletin 118 (California DWR,
2004a). The boundaries of the Seaside Area Subbasin and delineation of four subareas within the
subbasin have been redefined by Yates et al. (2005) based on a reinterpretation of geologic faulting and
groundwater flow divides. For example, tThe northern boundary and southeastern boundary are is based
on a groundwater divides that are is subject to movement with changing conditions in groundwater levels
(Yates, et al., 2005; HydroMetrics WRI, 2009).
Page 4.10-17
The first paragraph has been amended as follows:
Since 2008, groundwater pumping in the basin has declined primarily due to mandatory triennial
reductions. Pumping in coastal subareas averaged about 4,505 AFY from 1996 through 2008, but has
decreased to about 3,288 AFY from 2009 through 2013 (Watermaster production records). For
comparison purposes, a natural safe yield for the coastal subareas of between 1,973 AFY to 2,305 AFY
was established as part of the Seaside Basin adjudication (California Superior Court, 2006).
Page 4.10-17
The fourth paragraph has been amended as follows:
Beneath the Aromas Sand is tThe Paso Robles Formation is of Pliocene age. The formation is
heterogeneous and contains interbeds of sand, silt, and clay mixtures (Yates et al., 2005). These
continentally-derived deposits are discontinuous and difficult to correlate from well to well in the basin.
The formation is saturated in the proposed Injection Well Facilities area (and coastal areas) and forms the
shallow aquifer in the basin (referred to as the Paso Robles Aquifer herein). Several production wells
downgradient of the proposed Injection Well Facilities area are screened (i.e., perforated such that they
can extract water in at specific depths) in permeable units in the Paso Robles aquifer.
Final EIR
5-62
September 2015
Page 4.10-18
The second full paragraph on this page has been amended as follows:
Water levels in the Paso Robles Aquifer (as measured in the well called MSC Shallow) have fluctuated
between about minus three feet below mean sea level to about six feet above mean sea level over the
last 24 years. This well (MSC shallow) represents water levels near the coast. Water levels declined
below sea level in the mid-1990s in response to increases in groundwater extraction. Most of the
subsequent groundwater extraction occurred in the deeper Santa Margarita Aquifer and water levels in
the Paso Robles Aquifer rose near the coast. Since that time, water levels in the MSC Shallow well have
stabilized at about three to five feet above mean sea level. However, water levels remain below mean sea
level farther inland where a pumping depression persists.
Page 4.10-23
The second sentence in the paragraph beneath the heading Constituents Exceeding
California Primary MCLs has been changed to correct a typographical error.
. Specifically, all concentrations for 100 constituents analyzed with a primary MCL were found to meet
the regulatory limit, except for eight constituents in two wells that were apparently impacted by sample
turbidity as discussed below.
Page 4.10-30
Table 4.10-9 has been changed as follows to include a new footnote in response to
comment H-43:

Seaside Basin Water Balance
Water Balance Component
Inflows (AFY)
Precipitation
Groundwater Underflow
From Onshore
From Offshore
ASR Wells (Injection)
Water Distribution System Losses
Sewer Distribution System Losses
Septic Systems
Irrigation Infiltration
Golf Courses
Landscaping
Recycled Water Irrigation
Storm Water
Total Inflow
Outflows (AFY)
Groundwater Pumping
Groundwater Underflow
To Onshore
To Offshore
Total Outflow
Storage Change
(Inflow - Outflow)
Northern
Coastal
Northern
Inland
Southern
Coastal
Laguna
Seca
Basin
Total
78
1,450
30
700
2,258
2,850
100
625
411
77
0
0
0
0
0
0
0
450
0
0
21
9
5
180
0
0
46
19
22
180*
100
625
478
105
27
85
461
0
68
4,754
0
0
0
0
1,450
0
52
0
37
604
88
114
9
0
1,177
173
627
9
105
7,985
4,278
227
869
5,374
0
70
4,348
2,060
0
2,060
790
30
1,047
450
0
1,319
0*
100
8,774
406
-610
-443
-142
-789
* This value is not equal to the sum of the four subarea columns; it is a summary for the entire basin
which is made up of all four subareas combined. The subarea columns are a summary of the water
balance for each subarea. The four subarea columns include exchanges of groundwater between
subareas, as they are an important source of loading and removal of salts and nutrients for individual
subareas. The basin-wide value, however, only considers inputs to or outputs from the entire basin.
The net values (total groundwater inflow less total groundwater outflow) derived from each approach
are equivalent.
Note: Water Balance combines annual average values from selected recent representative time
periods as follows: Inflows (except Underflow) 2008 2012; Groundwater Underflow 2003 2007;
Groundwater Pumping 2011 2012. (Source: Hydrometrics, WRI, 2014)
Final EIR
5-63
September 2015
Page 4.10-40
The next to last paragraph has been changed as follows in response to comment N11:
In addition to the creation of a Watermaster, the court mandated a Monitoring and Management Plan
(M&MP) be developed; the M&MP was completed in September 2006. The purpose of the Seaside Basin
M&MP and its associated Implementation Plan (2007) was to establish a logical, efficient and costeffective work plan to meet the requirements of the Seaside Basin Adjudication. The Implementation Plan
contains a description of the phases identified for the Implementation Plan work effort, a detailed scope,
budget and schedule of tasks planned, as well as a summary of other projects underway that, in addition
to implementation of the M&MP, will develop solutions to the threat of seawater intrusion and establish a
maximum perennial yield for the producers who rely on the Seaside Basin for their water supply. The
activities described in the 2006 M&MP have been accomplished, and the Watermaster has prepared an
updated M&MP each year to address changing conditions and issues of concern. These are submitted to
the Court each year as part of the Watermasters Annual Report.
Page 4.10-41
The first paragraph on this page has been amended as follows:
seawater intrusion in the Seaside Basin, if and when it occurs. The Seawater Intrusion Response Plan
details both the indicators of seawater intrusion, and a list of recommended actions to be taken if
seawater intrusion is observed. The Basin Management Action Plan describes the existing condition,
identifies supplemental water supplies, groundwater management actions, and other recommendations,
including the recommendation for development and use of a hydrogeologic model to evaluate Proposed
Projects that may harm or benefit the basin. Since then a hydrogeologic model has been developed, and
this model has been used to assess the impacts of the Proposed Project on the Seaside Basin. See
discussions about the model in Section 4.10.4.2, under the section titled Groundwater Depletion, Levels
and Recharge: Seaside Basin. The Proposed Project would require that the project partners enter into a
water storage agreement with the Seaside Basin Watermaster.
Page 4.10-43
The following footnote has been added to the bottom of Table 4.10-11 Applicable
Local Plans, Policies, and Regulations Hydrology and Water Quality:
Groundwater in response to comment L-20:
* A water storage agreement with the Seaside Basin Watermaster would be required to implement the
Proposed Project.
Page 4.10-67
comment H-46:
Locally, it is unclear whether the decrease in 400-Foot aquifer pumping near the CSIP wells would raise
water levels in the 180-Foot aquifer beneath the Salinas Treatment Facility enough to completely offset
the effect of decreased recharge. The Castroville Seawater Intrusion Project wells are all screened in the
400-Foot aquifer or the East Side Subbasin and are located 2.75 to six miles north to northwest of the
Salinas Treatment Facility (between Salinas and Castroville). The Most CSIP wells are inland of the
intrusion front in the 400-Foot aquifer but beneath the intruded part of the 180-Foot aquifer. .
Page 4.10-67
comment O-1:
Groundwater quality impacts would be greatest near the Salinas Treatment Facility, and for this analysis
the impact area previously described for water level impacts was also used for water quality impacts: a
circle with a 1.5-mile radius surrounding centered at the Salinas Treatment Facility ponds. The 180/400
Foot Subarea water balance in the Salinas Valley Integrated Groundwater and Surface Water Model (the
only applicable groundwater model for most of the Salinas Valley Groundwater Basin) indicates that
groundwater recharge from rainfall and irrigation return flow averages 0.76 ft/yr, which is 38% of total
groundwater recharge. Groundwater recharge from Salinas Treatment Facility percolation averages 0.12
ft/yr when distributed over a 1.5-acre circular area centered at the ponds. Recharge from Salinas
Treatment Facility percolation therefore amounts to approximately six percent of total recharge. This
means that water quality impacts of changes in Salinas Treatment Facility percolation would be
substantially diluted by mixing with other sources of recharge.

Final EIR
5-64
September 2015
Page 4.10-69
The second paragraph under All Other Project Components/Overall Regional

Impacts on Salinas Valley Groundwater Basin has been changed:
As previously discussed, the Proposed Project would decrease CSIP pumping to zero in most years and
to a small fraction of existing pumping in the remaining years. The decrease in groundwater pumping in
the CSIP area would be about ten times greater than the decrease in recharge at the Salinas Treatment
Facility and therefore, the Proposed Project would have a net beneficial impact with respect to seawater
intrusion and overall groundwater storage and levels in the Salinas Valley Groundwater Basin. The
Proposed Project would increase the amount of irrigation water available to the growers. The tertiary
recycled water would comply with statutory and regulatory requirements for the production and use of
recycled water per California Water Code Sections 13500 13577 and California Code of Regulations,
Title 22, Sections 60301 60357 60355. In addition, the increased use of the tertiary-treated recycled
water on the existing CSIP area would not adversely affect the groundwater quality in the 180-Foot or
400-Foot Aquifers for the following reasons:
Page 4.10-74
The first bulleted paragraph under Impact Conclusions has been changed:
Stabilized pilot plant water samples and projected AWT Facility purified recycled water meet
SWRCB Regulations for groundwater replenishment projects and Basin Plan groundwater
quality standards, including drinking water MCLs. Further, the treatment processes that would
be incorporated into the proposed full-scale AWT Facility would be selected and meet the
requirements in the DDW Groundwater Replenishment Regulations and the AWT Facility
would be operated to ensure that all water quality standards would be met in both the purified
recycled water and groundwater. A monitoring program would document project
performance.
Page 4.10-86
Figure 4.10-5 has been replaced with a revised version in response to comment N-10 to
clarify the adjudication boundary. See Figure 4.10-5rev at the end of Chapter 5.
Page 4.10-88
Figure 4.10-7 has been replaced with a revised version in response to comment L-25 to
clarify the adjudication boundary. See Figure 4.10-7rev at the end of Chapter 5.
Page 4.10-90
A new figure showing groundwater levels and groundwater flow directions and
representing the groundwater project study area has been inserted at the end of Section
4.10 in response to comment H-46. See Figure 4.10-9a at the end of Chapter 5.

Final EIR
5-65
September 2015
Changes to 4.11 Hydrology/Water Quality: Surface Water

Page 4.11-9
The last sentence on this page has been amended as follows in response to I-1:
. Currently, CalAms Monterey District service area system relies upon withdrawals from the Carmel
River Valley Alluvial Aquifer through wells located in the lower part of the Carmel Valley and from wells
located in the Seaside Groundwater Basin.
Page 4.11-30
The last full paragraph on this page has been replaced as follows in response to
comment F-3:
Water bodies that may not be covered under USACOE jurisdiction may require a Section 401 Water
Quality Certification for impact on waters of the state. Placement of structures, fill, or dredged materials
into waters of the State requires Section 401 Water Quality Certification. Activities that require a federal
Section 404 permit also require a Section 401 Water Quality Certification. The RWQCB issues Section
401 Water Quality Certifications and waivers.
Section 401 Water Quality Certifications are issued by the RWQCB to protect water quality and the
beneficial uses of water from projects that may result in discharges of dredge and fill. The Central Coast
RWQCB only issues Section 401 Water Quality Certifications for projects that may discharge dredge of fill
to waterbodies that are under the jurisdiction of the USACOE. The Central Coast RWQCB may issue
other waste discharge requirements (permits) for discharges of dredge or fill to waterbodies not under the
jurisdiction of the USACOE, but that are waters of the state as defined by the Porter-Cologne Water
Quality Control Act.
Page 4.11-34
The following text is added to the bottom of this page as requested in comment L-27:
For current guidance information about stormwater management, see the Monterey Regional Stormwater
Management Program website at: http://montereysea.org/program-documents/.
Page 4.11-36
The following paragraph has been inserted at the end of the section titled PorterCologne Water Quality Control Act in response to comment F-2:
The term Waters of the State is defined by Porter-Cologne as any surface water or groundwater,
including saline waters, within the boundaries of the state. The RWQCB protects all waters in its
regulatory scope but has special responsibility for wetlands, riparian areas, and headwaters, including
isolated wetlands, and waters that may not be regulated by the USACOE under Section 404 of the CWA.
Waters of the State are regulated by the RWQCB under the State Water Quality Certification Program,
which regulates discharges of fill and dredged material under Section 401 of the CWA and PorterCologne.
Page 4.11-43
The following text has been added under the Seaside Municipal Code heading in
Seaside Municipal Code Section 15.32, Standards to Control Excavation, Grading, Clearing and
Erosion, sets forth guidelines, rules, regulations and minimum standards to control excavation, grading,
clearing, erosion control and maintenance, including cut and fill embankments; requires control of all
existing and potential conditions of accelerated erosion; establishes administrative procedures for
issuance of permits; and provides for approval of plans and inspections during construction and
maintenance.
Page 4.11-62
The end of section 4.11.4.3 has been amended as follows in response to comment F-7:
The construction contractor(s) would also be required to develop and implement a monitoring program as
required under the NPDES Construction General Permit. The contractor would be required to conduct
inspections of the construction site prior to anticipated storm events and after the actual storm events.
During extended storm events, the inspections would be conducted after every 24-hour period. The
inspections would be conducted to: identify areas contributing to stormwater discharge; evaluate whether
measures to reduce pollutant loadings identified in the SWPPP are adequate, were properly installed, and
are functioning in accordance with the Construction General Permit; and determine whether additional
control practices or corrective measures are needed.
Final EIR
5-66
September 2015
The action of moving earth within waters of the state (such as with trenching or excavation) is considered
a discharge and requires a permit. If the U.S. Army Corps of Engineers (USACOE) claims jurisdiction in
the subject waterbody where the discharge may occur, the Central Coast Regional Water Quality Control
Board (RWQCB) also will need to review the action and potential discharge and issue a Clean Water Act
Section 401 Water Quality Certification. If the RWQCB determines that the action will be protective of
water quality and the beneficial uses of water it can issue the 401 certification. If the USACOE does not
take jurisdiction, the RWQCB may issue waste discharge requirements (a permit) for impacts to waters of
the state.
Mandatory compliance with the NPDES Construction General Permit requirements, Section 404 and 401
of the Clean Water Act, and, if required, other Waste Discharge Requirements issued by the RWQCB due
to impacts to waters of the state would prevent significant construction-related impacts to surface water
quality during general construction activities. Therefore, the water quality impacts (including on inland
surface waters and marine waters) associated with general construction activities would be less than
significant.
Impact Conclusion
Prior to construction of any of the Proposed Project components, compliance with NPDES
Construction General Permit, Clean Water Act Sections 404 and 401, and other waste discharge
requirements of the Porter-Cologne Water Quality Control Act, would be required, including
implementation of erosion and stormwater quality control measures set forth in a SWPPP and a
Rain Event Action Plan that would prevent substantial adverse effects on water quality during
construction. The Proposed Project would have a less-than-significant impact on water quality
associated with increased soil erosion and sedimentation, and inadvertent releases of toxic
chemicals during general construction activities and no mitigation measures would be required.
Page 4.11-74
The text in the fourth sentence of the first paragraph of the Lake El Estero section
has been amended as follows in response to comment P-4:
. Lake El Estero Water is proposed to be diverted (when available and needed to meet Proposed
Project objectives, typically between November and April) by gravity or using a small pump to the
municipal wastewater collection system in the vicinity of the City of Montereys existing stormwater
management pump station at the northeastern corner of Lake El Estero. .
Page 4.11-75
Mitigation Measure HS-4 has been modified as follows in response to comment F-5
and H-50:
Mitigation Measure HS-4: Management of Surface Water Diversion Operations (Applies to

Reclamation Ditch Diversion, only)
Rapid, imposed water-level fluctuations shall be avoided when operating the Reclamation Ditch
Diversion pumps to minimize erosion and failure of exposed (or unvegetated), susceptible banks.
This can be accomplished by operating the pumps at an appropriate flow rate, in conjunction with
commencing operation of the pumps only when suitable water levels or flow rates are measured
in the water body. Proper control shall be implemented to ensure that mobilized sediment would
not impair downstream habitat values and to prevent adverse impacts due to water/soil interface
adjacent to the Reclamation Ditch and Tembladero Slough. During planned routine maintenance
at the Reclamation Ditch Diversion, maintenance personnel shall inspect the diversion structures
within the channel for evidence of any adverse fluvial geomorphological processes (for example,
undercutting, erosion, scour, or changes in channel cross-section). If evidence of any substantial
adverse changes are noted, the diversion structure shall be redesigned and the project
proponents shall modify it in accordance with the new design.
Page 4.11-101
The text of Mitigation Measures HS-C has been amended as follows in response to
comment N-3:
As part of the amendment process to modify the existing MRWPCA NPDES Permit (Order No. R3-20140013, NPDES Permit No. CA0048551) per 40 Code of Regulations Part 122.62, it would be necessary to
conduct an extensive assessment in accordance with requirements to be specified by the RWQCB. It is
expected that the assessment would include, at a minimum, an evaluation of the minimum probable initial
dilution at the point of discharge based on likely discharge scenarios and any concomitant impacts on
Final EIR
5-67
September 2015
water quality and beneficial uses per the Ocean Plan. Prior to operation of the MPSWP MPWSP
desalination plant, the discharger(s) will be required to test the MPSWP MPWSP source water in
accordance with protocols approved by the RWQCB. If the water quality assessment indicates that the
water at the edge of the ZID will exceed the Ocean Plan water quality objectives, the MRWPCA will not
accept the desalination brine discharge at its outfall, and the following design features and/or operational
measures shall be employed, individually or in combination, to reduce the concentration of constituents to
below the Ocean Plan water quality objectives at the edge of the ZID:
Page 4.11-107
The following text changes have been made to the references to update the
guidance documents as requested in comment L-27:
Monterey Regional Stormwater Management Program (MRSWMP), 20115. Stormwater Management

Program Documents at the Monterey Regional Stormwater Management Program website at:
http://montereysea.org/program-documents/. Revision 3. Revised June 2011.
Monterey Regional Stormwater Management Program (MRSWMP), 2014. Post-Construction
Requirements
At
A
Glance.
Available
online
at:
http://www.montereysea.org/resources_developers.php ccessed on June 26, 2014.
Changes to 4.12 Land Use, Agriculture, and Forest Resources

Page 4.12-29
The first paragraph under the Heading 4.12.4.2 Approach to Analysis, Land Use, has
been amended as follows in response to comment L-30:
This analysis evaluates short-term impacts resulting from temporary construction of Proposed Project
components, as well as long-term impacts resulting from the siting and operation of Proposed Project
components, either of which may result in potential conflicts or inconsistencies with existing adopted
plans and regulations. Construction equipment and materials associated with the various components of
the Proposed Project would be staged and stored within the respective construction work areas.
Construction equipment and materials associated with pipeline installation would be stored along the
pipeline alignments and at nearby designated staging areas. Staging areas would not be sited in sensitive
areas such as riparian areas or critical habitat for protected species. To the extent feasible, parking for
construction equipment and worker vehicles would be accommodated within the construction work areas
and on adjacent roadways.
Before construction mobilization for the source water diversion facilities, AWT Facility, pipeline
installation, and the proposed injection wells, the contractors would clear and grade construction areas
(including temporary staging areas), and remove vegetation and debris as necessary, to provide a
relatively level surface for the movement of construction equipment. Upon completion of construction
activities, the construction contractor would remove any added gravel, contour the construction work
areas and staging areas to their original profile, and hydro-seed or repave the areas, as appropriate.
Page 4.12-32
The following paragraph has been inserted between the first and second bullet:
(b) Conflicts with plans, policies or regulations during construction. Construction activities would not result
in land use impacts other than those identified elsewhere in this EIR. These potential inconsistencies
during construction were identified in Table 4.12-5 on pages 4.12-39 through 4.12-43. The temporary
potential inconsistencies with plans, policies and regulations and associated impacts have been identified
in Table 4.12-5 and addressed by environmental topic in the sections referenced above, and thus do not
result in any other conflicts with plans, policies, and programs adopted for the purpose of reducing an
environmental impact.
Page 4.12-52
Changes have been made to the following citations:
City of Monterey, 1981 2000. Land Use Plan for the Laguna Grande /Roberts Lake Local Coastal
Program, adopted December, 1981, updated November, 2000.
City County of Monterey, 2010. Final Environmental Impact Report for the General Plan, 2010
Page 4.12-53
The following citation has been deleted:
City of Seaside, 2010 Local Coastal Program Land Use Plan.

Final EIR
5-68
September 2015
Changes to 4.13 Marine Biological Resources


Final EIR
5-69
September 2015
Changes to 4.14 Noise and Vibration

Page 4.14-7
In Table 4.14-4 Summary, the following changes have been made:
Table 4.14-4
Summary of Short-Term Noise Measurements (dBA)
Noise Measurement Location-Project
Facility
ST-1-Injection Well Facilities:
GWR monitoring well drilling site in
Seaside. 75 feet from drill rig, 50 feet
from truck engine. [1]
ST-2-Injection Well Facilities:
Along Juarez Street, 315 feet from the
centerline of General Jim Moore Blvd. [1]
Date
Time
12/19/2013
9:40-10:00 AM
12/27/2013
11:00-11:10 AM
11:10-11:20 AM
ST-3-CalAm Distribution Transfer

Pipeline: Mescal Street, Residential
Leq
Lmax
L(10)
L(50)
L(90)
83
89
84
83
82
81
84
83
82
67
48
60
49
46
44
49
47
55
48
46
45
48
3/20/13
12:22 - 12:32 PM
59.1
70.9
NA
NA
NA
NA
ST-4-CalAm Distribution
Monterey Pipeline: Franklin Street,
3/20/13
1:36 - 1:46 PM
60.2
69.3
NA
NA
NA
NA
Private residence near Franklin

Street/Van Buren Street intersection in
Monterey, adjacent to Monterey Pipeline.
[1]
4/13/14
12:28 -12:38 AM
45.8
61.3
NA
NA
NA
NA
ST-5-CalAm Distribution
Monterey Pipeline: Franklin Street,
3/20/13
2:03 - 2:13 PM.
61.0
68.5
NA
NA
NA
NA
area in Seaside. [2]
10:00-10:10 AM
Ldn*
89
Private residence near Franklin

4/13/14
Street/Van Buren Street intersection in
45.8
63.4
NA
NA
NA
NA
12:48 - 12:3458 AM
Monterey, adjacent to Monterey Pipeline.
[1]
* Ldn levels at ST-1 assume continuous 24-hour operations of the drilling operation. Ldn levels at ST-2 were estimated based on
noise levels measured at LT-1 during corresponding interval.
NA = Not Available
[1] SOURCE: Illingworth & Rodkin (2014) CPUC/ESA, Draft EIR for the Monterey Peninsula Water Supply Project, April 2015.
Page 4.14-17
Table 4.14-7 City of Marina Allowable Noise Standards Measured in Ldn (dBA), has been
moved into the previous section, City of Marina, and is now on Page 4.14-16.
Page 4.14-43
The following mitigation measure has been added after Mitigation Measures NV-1c and
prior to the section addressing Impact NV-2 in response to comment H-54:
Mitigation Measure NV-1d: RUWAP Pipeline Construction Noise. (Applies to the RUWAP Alignment
Option of the Product Water Conveyance)
The following measures will be implemented by the project proponents in response to comments from the
Marina Coast Water District if the RUWAP alignment option of the Product Water Conveyance Pipeline is
selected for implementation:
The construction contractor shall limit exterior construction related activities to the hours of
restriction consistent with the noise ordinance of, and encroachment permits issued by, the
6
relevant land use jurisdictions.
The contractor shall locate all stationary noise-generating equipment as far as possible from
nearby noise-sensitive receptors. Where possible, noise generating equipment shall be shielded
from nearby noise-sensitive receptors by noise-attenuating buffers. Stationary noise sources
located 500 feet from noise-sensitive receptors shall be equipped with noise reducing engine
housings. Where possible and required by the local jurisdiction, portable acoustic barriers shall be
placed around stationary noise generating equipment that is located less than 200 feet from
noise-sensitive receptors.

Final EIR
5-70
September 2015
The contractor shall assure that construction equipment powered by gasoline or diesel engines
have sound control devices at least as effective as those provided by the original equipment
manufacturer (OEM). No equipment shall be permitted to have an unmuffled exhaust.
The contractor shall assure that noise-generating mobile equipment and machinery are shut-off
when not in use.
Residences within 500 feet of a construction area shall be notified of the construction schedule in
writing, prior to construction. The project proponents and contractors shall designate a noise
disturbance coordinator who would be responsible for responding to complaints regarding
construction noise. The coordinator shall determine the cause of the complaint and ensure that
reasonable measures are implemented to correct the problem. A contact number for the noise
disturbance coordinator shall be conspicuously placed on construction site fences and written into
the construction notification schedule sent to nearby residences.
Page 4.14-49
Mitigation Measures NV-2b has been changed as follows in response to comment J-4c:
Mitigation Measure NV-2b: Construction Hours. (Applies to Product Water Conveyance Pipelines
(RUWAP and Coastal Alignments) and RUWAP Booster Pump Station in the City of Marina)
The construction contractor shall limit all noise-producing construction activities within the City of
Marina to between the hours of 7:00 AM and 7:00 PM on weekdays and between 9:00 AM and
7:00 PM Saturdays, except that construction may be allowed until 8:00 PM during daylight
savings time.
Page 4.14-58
The last sentence on this page has been changed as follows in response to comment
R-2:
.The exact timing of construction is not known, but due to the distance from the Proposed Project sites
7
(about three miles to #6 and #8 [Harper Canyon and Ferrini Ranch] as shown on Figure 4.1-1rev ), there
would be no overlapping cumulative impacts related to construction or operational noise or vibration in
this area.
Page 4.14-61
The following citation under 4.14.5 References has been changed as follows:
City of Marina, 20050. City of Marina General Plan. Amended December 31, 20056.
Page 4.14-62
The following citation under 4.14.5 References has been changed:
City of Seaside, 20034. Seaside General Plan. Adopted August 5, 20034.
Changes to 4.15 Population and housing

Changes to 4.16 Public Services, Utilities, and Recreation

Page 4.16-1
The following change has been made to the first paragraph on this page in response to
comment H-58:
This section addresses potential impacts to public services, recreation and specified public utilities that
could occur if the Proposed Project were to necessitate provision of new or substantially altered public
services facilities or cause substantial physical deterioration of a recreational facility. Public services
discussed in this section include fire and police protection services, emergency services, schools, parks,
and recreational facilities. Recreational resources include parks, trails, beaches, and similar facilities. The
public utilities discussed include solid waste facilities. Water service and systems, wastewater service,
and recycled water delivery are addressed under Section 4.187, Water and Wastewater.
Figure 4.1-1rev is provided at the end of Chapter 5.

Final EIR
5-71
September 2015
Page 4.16-24
The following citations have been deleted.
White, K./ESA, personal communication, October 2014.

CPUC 2012
Changes to 4.17 Traffic and Transportation

Page 4.17-4
Page 4.17-17
Table 4.17-1 on this page has been modified as follows in response to comment J-4b to
indicate that Crescent Avenue has a Class 2 bike lane:
The fourth bullet on this page has been amended as follows in response to comment J4d:
Most linear facilities (conveyance pipelines) would be installed using conventional opentrench construction techniques. However, trenchless technologies such as boring and
jacking, microtunneling, or horizontal directional drilling may be used where open-cut
trenching is not feasible or desirable (highway crossings, stream and drainage crossings, and

Final EIR
5-72
September 2015
areas with high utility congestion). Note: City of Marina Municipal Code Section 12.20.100
does not allow trenchless activities under an encroachment permit.
Page 4.17-37
Mitigation Measure TR-2 has been amended as follows in response to comment J-4f:
Mitigation Measures
Mitigation Measure TR-2: Traffic Control and Safety Assurance Plan. (Applies to Product
Water Conveyance: Both Options, and CalAm Distribution System.)
Prior to construction, MRWPCA and/or its contractor shall prepare and implement a traffic control
plan or plans for the roadways and intersections affected by MRWPCA construction (Product
Water Conveyance Pipeline) and CalAm shall prepare and implement a traffic control plan for the
roadways and intersections affected by the CalAm Distribution System Improvements (Transfer
and Monterey pipelines). The traffic control plan(s) shall comply with the affected jurisdictions
encroachment permit requirements and shall be based on detailed design plans. For all project
construction activities that could affect the public right-of-way (e.g., roadways, sidewalks, and
walkways), the plan shall include measures that would provide for continuity of vehicular,
pedestrian, and bicyclist access; reduce the potential for traffic accidents; and ensure worker
safety in construction zones. Where project construction activities could disrupt mobility and
access for bicyclists and pedestrians, the plan shall include measures to ensure safe and
convenient access would be maintained.
The traffic control and safety assurance plan shall be developed on the basis of detailed design
plans for the approved project. The plan shall include, but not necessarily be limited to, the
elements listed below:
General
a. Develop circulation and detour plans to minimize impacts on local streets. As
necessary, signage and/or flaggers shall be used to guide vehicles to detour routes
and/or through the construction work areas.
b. Implement a public information program to notify motorists, bicyclists, nearby
residents, and adjacent businesses of the impending construction activities (e.g.,
media coverage, email notices, websites, etc.). Notices of the location(s) and timing
of lane closures shall be published in local newspapers and on available websites to
allow motorists to select alternative routes.
Roadways
c.
Haul routes that minimize truck traffic on local roadways and residential streets shall
be used to the extent feasible.
d. Schedule truck trips outside of peak morning and evening commute hours to
minimize adverse impacts on traffic flow.
e. Limit lane closures during peak hours. Travel lane closures, when necessary, shall
be managed such that one travel lane is kept open at all times to allow alternating
traffic flow in both directions along affected two-lane roadways; the contractor shall
use steel plates or trench backfilling to restore vehicle access at the end of each
workday. In the City of Marina, one-way traffic shall be limited to a maximum of 5
minutes of traffic delay.
f.
Page 4.17-39
Restore roads and streets to normal operation by covering trenches with steel plates
outside of normal work hours or when work is not in progress.
Mitigation Measure TR-3 has been changed as follows in response to comments J-4e,
J-4g, and P-15:
Mitigation Measure TR-3: Roadway Rehabilitation Program (applies to all Proposed
Project components)
Prior to commencing project construction, MRWPCA (for all components other than the
CalAm Distribution System Improvements) and CalAm (for CalAm Distribution System

Final EIR
5-73
September 2015
Improvements) shall detail the preconstruction condition of all local construction access
and haul routes proposed for substantial use by project-related construction vehicles. The
construction routes surveyed must be consistent with those identified in the construction
traffic control and safety assurance plan developed under Mitigation Measure TR-2. After
construction is completed, the same roads shall be surveyed again to determine whether
excessive wear and tear or construction damage has occurred. Roads damaged by
project-related construction vehicles shall be repaired to a structural condition equal to, or
greater than, that which existed prior to construction activities. In the City of Marina, the
construction in the city rights-way must comply with the Citys design standards, including
restoration of the streets from curb to curb, as applicable. In the City of Monterey, asphalt
pavement of full travel lanes will be resurfaced without seams along wheel or bike paths.
Changes to 4.18 Water Supply and Wastewater Systems

Page 4.18-4
The following changes have been made to the first two paragraphs under the heading
Monterey Peninsula Water Management District in response to comment I-6:
The Monterey Peninsula Water Management District (Water Management District) and MRWPCA are
partners in studying the Proposed Project (Proposed Project). As indicated in Section 2.3.2.1, the Water
Management District is a special district, created by the California Legislature in 1977 and endorsed by a
public vote in 1978, for the purposes of conserving and augmenting the supplies by integrated
management of ground and surface water supplies, for control and conservation of storm and
wastewater, and for promotion of the reuse and reclamation of water. Approximately 104,000 people live
within the jurisdictional boundary of the Water Management District, which includes the Monterey
Peninsula and unincorporated communities within Monterey County including Pebble Beach, the Carmel
Highlands, a portion of Carmel Valley, and areas adjacent to Highway 68.
The Water Management District is a water resource planning/management entity, and does not provide
water service to retail customers. However, as described in Section 2.3.2.1, the Water Management
District either owns or is the financing entity for certain water supply facilities operated by CalAm or other
agencies. Water Management District is responsible for the integrated management of water resources
within the Water Management Districts boundaries, while the California American Water Company
(CalAm) is responsible for providing water to customers in the Monterey Peninsula area.
Page 4.18-5
The second sentence in the first paragraph on this page has been amended as
follows in response to comment I-1:
. The Water Management District manages production and use of water from the Carmel River stored
in Los Padres Reservoir, water production in the Carmel Valley Alluvial Aaquifer, and groundwater
pumped from municipal and private wells in Carmel Valley, the Seaside Groundwater Basin (Seaside
Basin), and other areas within the Water Management District boundary.
Page 4.18-8
The second paragraph on this page has been amended as follows in response to
comment H-59:
The Marina Coast Water Districts water supply comes from groundwater wells located in the 900-footdeep aquifer of the Salinas Valley Groundwater Basin. Historically, MCWD supplied its Marina service
area with water from wells screened in the 180-Foot and 400-Foot aquifers. Between 1960 and 1992,
some of those wells indicated varying degrees of seawater intrusion and were replaced, first moving from
the 180-Foot aquifer to the 400-Foot aquifer, and later moving to the Deep Aquifer. The District currently
operates 4 wells in the Deep Aquifer-- Wells 10, 11, 12 and 34. MCWD also operates 4 wells that draw
from the 180-Foot and 400-Foot Aquifers-- Wells 29, 30, 31, and 35. (See attachment Exhibit "E" to Letter
H for locations of these wells). The Marina Coast Water District also has a desalination plant with a
capacity of 300 acre-feet per year; the plant is capable of providing up to 13 percent of the annual water
demand, but has not operated in recent years (Marina Coast Water District, 2013).
Page 4.18-8
The fourth paragraph has been amended as follows in response to comments in letter
H:

Final EIR
5-74
September 2015
As indicated in Section 2.3.3.3, water demands on the former Fort Ord are projected to increase with
development envisioned in the Fort Ord Base Reuse Plan and local plans. To address the need for
additional water supply, Marina Coast Water District is developing the Regional Urban Water
Augmentation Project (RUWAP) that would provide an additional 2,400 AFY of potable and/or recycled
water. The RUWAP recycled water distribution system has been designed and partially constructed, but is
not yet in operation. To date, the Marina Coast Water District has not delivered recycled water to its
irrigation users from the Regional Treatment Plant through the RUWAP recycled water distribution
system. (See Sections 4.18.2.2 and 4.18.3.4, below, for further discussion of the Regional Treatment
and Reclamation Plants and existing agreements.)
Page 4.18-11 to 4.18-12
The paragraph under Municipal Wastewater Collection Systems has been

amended as follows in response to comment H-61:
Marina Coast Water District maintains and operates the wastewater collection system in the former Fort
Ord community that currently includes urban development in the unincorporated Monterey County and
the cities of Marina and Seaside, including some areas under state and federal ownership, such as
California State Parks, California State University Monterey Bay, the University of California, and the U.S.
Army. MCWDs service territory also includes the City of Marina. MCWD is responsible for maintaining its
service areas sewer system, which includes 20 lift stations and 110 miles of pipeline. Through this
system, wastewater Wastewater is carried by the Marina Coast Water District sanitary collection system
to the MRWPCA pump stations. From local pump stations, the wastewater is transported to the MRWPCA
treatment plant north of Marina.
Page 4.18-15
The last paragraph on this page has been changed as follows in response to comment
C-4:
.New State Board guidance has clarified that a wastewater petition for change only needs to be filed
with the State Board Division of Water Rights if the owner of the wastewater treatment plant decreases
the amount of water in a stream or other waterway. The Proposed Project changes to the Regional
Treatment Plant that would result in reduced disposal of secondary effluent to the outfall would not
change the amount of water in a stream or other waterway. The diversion of agricultural wash water, an
industrial wastewater, to the Regional Treatment Plant using the Salinas Pump Station Diversion and the
Salinas Treatment Facility Storage and Recovery components of the project and its effects on water
levels or flows in the Salinas River are addressed in Section 4.11, Hydrology and Water Quality:
Surface Waters. The diversion of agricultural wastewater would reduce groundwater flow to the Salinas
River by reducing the amount of water percolating from the Salinas Treatment Facility to groundwater.
This flow reduction is relatively small and would not adversely affect beneficial uses or water quality in the
Salinas River. Accordingly, it is reasonable to conclude that the State Board Division of Water Rights
would approve the wastewater petition for change.
Page 4.18-19
Table 4.18-5 and the paragraph following it has been changed as follows in response
to letter H:

Final EIR
5-75
September 2015
Table 4.18-5
Summary of Relevant Local Agency Agreements
Name
Agencies
Date
Memorandum of Understanding Regarding

Source Waters and Water Recycling
Monterey Peninsula Water Management District, Marina Coast

Water District (MCWD), Monterey County Water Resources
Agency, Monterey Regional Water Pollution Control Agency,
City of Salinas
October 2014
(Amended April
2015 to provide
time extension
past March 31,
2015)
Annexation Agreement for MCWD into

MRWPCA
MCWD
April 1989
Annexation Agreement for MCWD into

MCWRA Zones 2 and 2A
Monterey County Water Resources Agency, et al.,
March 1996
Agreement between Monterey County

Water Resources Agency and Monterey
Regional Water Pollution Control Agency for
the Construction and Operation of a Tertiary
Treatment System and Amendments
Monterey County Water Resources Agency and Monterey

Regional Water Pollution Control Agency
June 1992
Memorandum of Understanding - Regional

Urban Water Augmentation Project
MCWD and MRWPCA
May 1995 (1st)

Feb 1998 (2nd)
May 2002 (3rd)
June 2009
Previous interagency agreements have established entitlements to recycled water produced from the
existing municipal wastewater flows to the Regional Treatment Plant. As source flows for the Proposed
Project were studied and the seasonal variability of each was understood, the stakeholder agencies
entered into a Memorandum of Understanding Regarding Source Waters and Water Recycling (Source
Waters MOU) (October 2014). The parties to the Source Waters MOU are the Monterey Regional Water
Pollution Control Agency, the Monterey County Water Resources Agency, the City of Salinas, the Marina
Coast Water District, and the Monterey Peninsula Water Management District (the Parties). The Source
Waters MOU is an agreement to negotiate a Definitive Agreement to establish contractual rights and
obligations of all Parties, that would include (1) protection of Marina Coast Water Districts recycled water
right entitlement under the April 25, 1989 Annexation Agreement, (2) provision of up to 5,292 AFY of
additional recycled water to Monterey County Water Resources Agency for the Castroville Seawater
Intrusion Project, and (3) provision of 3,500 AFY of purified recycled water for injection into the Seaside
Basin and extraction by CalAm. The Source Waters MOU also includes provisions for creation of a
8
drought reserve by allowing the GWR Features to produce, convey and inject up to 200 AFY of
additional purified recycled water during wet and normal years. The Source Waters MOU reflects the
stakeholder agencies positions regarding the combined benefits and conditions that would be required to
secure the necessary rights and agreements to use the source waters needed for the Proposed Project.
Page 4.18-21 The first paragraph has been changed as follows in response to letter H:
Marina Coast Water District possesses legal rights to use wastewater treated by the Salinas Valley
Reclamation Plant at the Regional Treatment for urban irrigation within areas that they serve. In 1989,
when Marina Coast Water District was annexed into the MRWPCA, they acquired contractual rights to
wastewater they would discharge to the system which are described below. In 1996, when Marina Coast
Water District was annexed into MCWRAs Zones 2 and 2A, their rights were clarified. The agreements
that established these rights are described in detail below. In 2009, Marina Coast Water District and
MRWPCA entered into a MOU concerning recycled water that would be allocated to Marina Coast Water
Districts RUWAP Recycled Water Project (RUWAP MOU). In the RUWAP MOU, the MRWPCA assigned
a portion of its allotment from the Third Amendment of the 1992 Agreement between MRWPCA and
Proposed Project improvements and operations that will develop high quality replacement water for existing urban
supplies in the CalAm Monterey District are referred to as the GWR Features. The provision of up to 5,292 AFY of
additional recycled water for irrigation of farmland within the Castroville Seawater Intrusion Project areas are referred
to as the Crop Irrigation component.

Final EIR
5-76
September 2015
Monterey Count Water Resources Agency, as discussed below. Certain parties have disputed the
validity of the Third Amendment. If the Third Amendment is considered invalid, the RUWAP MOU may
also be invalid. For purposes of this EIR, however, MRWPCA assumes the Third Amendment is valid
and enforceable and that Marina Coast has an existing right to 650 AFY of recycled water during the
9
summer months. Currently, Marina Coast Water District does not have approved funding, water
purchase/user agreements, or adequate physical distribution facilities to use the recycled water; thus
Marina Coast Water Districts water right to recycled water from the RUWAP MOU have not been
triggered. Marina Coast Water Districts proposed use of recycled water (as part of their approved
Regional Urban Water Augmentation Program, or RUWAP Recycled Water Project) is considered a
cumulative project in this EIR.
Page 4.18-22
The seventh complete paragraph (immediately before the heading: Monterey County
Water Resources Agencys Rights) has been amended as follows in response to letter
H:
MCWD has not yet proceeded to construct and operate the RUWAP Recycled Water Project, except for
several disconnected segments of distribution system pipeline that would not by themselves be able to
provide recycled water to users (Brian True, personal communication, August 2014). The MCWD has not
committed funding nor received financing toward construction of the facilities needed to deliver recycled
water to irrigation demands. No signed user agreements have been entered. If MCWD is able to obtain
financing, complete construction, and enter into user agreements, then MCWD would have a right to 650
AFY of recycled water during the summer months under the RUWAP MOU, unless the RUWAP MOU is
rendered invalid or is amended by the parties.
Page 4.18-23 to 4.18-24
The last paragraph on page 4.18-23 and several paragraphs on page 4.1824 have been changed as follows in response to comments in letter H and
comments C-2, C-3 and P-3:
Here, MRWPCA has entered into the following contracts, including contracts that assigned rights to
Marina Coast Water District and Monterey County Water Resources Agency (Water Resources Agency):
The 1989 Annexation Agreement between MRWPCA and the Marina Coast Water District
provides the Marina Coast Water District with the right to obtain treated wastewater from
MRWPCA. The Marina Coast Water District has not exercised its recycled water rights, but
may do so in the future.
The 1992 agreement between MRWPCA and Water Resources Agency (including
amendments) provides for the construction and operation of the Salinas Valley Reclamation
Plant by MRWPCA to provide water treated to a level adequate for agricultural irrigation for
use by the Castroville Seawater Intrusion Project. In particular, Section 3.03 of the 1992
Agreement (Amendment 3) provides that MRWPCA commits all of its incoming wastewater
flows to the treatment plant from sources within the 2001 MRWPCA service area, up to 29.6
million gallons per day, except for flows taken by the Marina Coast Water District under the
Annexation Agreements, losses, flows not needed to meet the Water Resource Agencys
authorized demand, and flows to which MRWPCA is otherwise entitled under the agreement.
In 1996, pursuant to another Annexation Agreement, the Marina Coast Water District
received the right to tertiary-treated water from the Salinas Valley Reclamation Plant, in
satisfaction of the 1989 agreement rights.
In 2009, the Marina Coast Water District and MRWPCA entered into an MOU relating to
Marina Coast Water Districts RUWAP Recycled Water Project, which provided that
MRWPCA would provide recycled water from MRWPCAs Regional Water Treatment Plant.
To address these and other certain water rights, the stakeholder agencies entered into a Memorandum of
Understanding (Source Waters MOU). The Source Waters MOU reaffirmed the Marina Coast Water
Districts recycled water right entitlement from the 1989 Annexation Agreement between MRWPCA and
The Source Waters MOU, to which both MCWD and MRWPCA are parties, provides that the Definitive Agreement
may result in an Amendment to the 1992 Agreement and the amendments thereto and that any remaining applicable
terms of the Third Amendment would be restated in the Definitive Agreement.
Final EIR
5-77
September 2015
Marina Coast Water District and the Water Resources Agencys recycled water entitlements, and
presented a proposal for collection of additional source waters to meet the Proposed Project objectives.
Importantly, the Source Waters MOU is intended to provide a framework for negotiation of a Definitive
Agreement and does not create a binding contractual obligation. The Definitive Agreement would
establish the contractual rights and obligations of the parties. To date, the Definitive Agreement has not
yet been completed. If a Definitive Agreement is reached, it would be is expected to be approved after the
EIR is certified (Perkins Coie, 2015). If a Definitive Agreement is not reached by all parties, MRWPCA
and the Water Management District will work to reach separate agreements with affected stakeholder
agencies as needed for the Proposed Project.
Legal Agreements/Permits for Diversions from Salinas and Monterey Stormwater

Collection Systems to MRWPCA Collection and Treatment Systems
To divert stormwater and dry weather flow from urban areas, agreements are needed between MRWPCA
and the local agencies that currently collect and convey the flows in man-made facilities for discharge to
surface waters, including These local agencies include the City of Salinas for urban runoff/stormwater
source water from the Salinas River. and the City of Monterey for the Lake El Estero source water that
otherwise would be discharged into the Monterey Bay. Stormwater runoff from urban areas through storm
drain infrastructure (i.e., in the City of Salinas or Monterey) does not become water of the state until it is
discharged into a river or channel. (Perkins Coie, 2015)
Page 4.18-29
The last paragraph has been changed on this page as follows in response to
comments in Letter H:
As discussed above, the Source Waters MOU reaffirmed Marina Coast Water District and Water
Resources Agencys recycled water entitlements under the 1989 Annexation Agreement and the 1992
Agreement and its subsequent amendments, respectively, and presented the proposal for collection of
additional source waters to recycle and use to meet the two Proposed Project objectives. The Source
Waters MOU is intended to provide a framework for negotiation of a Definitive Agreement and does not
create a binding contractual obligation.
Page 4.18-30
The last paragraph on this page has been amended as follows in response to comment
C-4:
The owner of a wastewater treatment plant, such as the MRWPCA for the Regional Treatment Plant, has
the exclusive right to the treated wastewater it produces as against anyone who has supplied the water
discharged into the wastewater collection and treatment system, including a person using water under a
service contract (Water Code section 1210). MRWPCA therefore, has the exclusive right to use municipal
wastewater that is discharged into the MRWPCA collection system, except (1) as that right has been
varied by contractual arrangements or (2) if a change of the point of discharge, place of use, or purpose
of use will result in a decrease in flow in any portion of a watercourse (Cal. Water Code 1211 et seq.).
MRWPCA has entered into a number of such contracts as described in Section 4.18.3.3, including
contracts that assigned rights to Marina Coast Water District and Monterey County Water Resources
Agency (Water Resources Agency). Any necessary wastewater change petitions will be submitted to the
State Board.
Page 4.18-31
The text on this page has been changed as follows in response to letter H:
To substantiate the adequacy of MRWPCAs legally-entitled wastewater rights for the Proposed Project
when taking into account and respecting the amounts to which Marina Coast Water District and Water
Resources Agency are entitled to use, the MRWPCA and MPWMD pursued a MOU Regarding Source
Waters and Water Recycling. As discussed above, the MOU reaffirmed Marina Coast Water District and
Water Resources Agencys recycled water entitlements, and presented the proposal for collection of
additional source waters to recycle and use to meet the two Proposed Project objectives. The MOU is
intended to provide a framework for negotiation of a Definitive Agreement and does not create a binding
contractual obligation. The 2014 Source Waters MOU affirms that Marina Coast Water Districts recycled
water right entitlement under the 1989 Annexation Agreement between MRWPCA and Marina Coast
Water District may be made contractually available by Marina Coast Water District to another party and
may be made available to MCWRA for CSIP if not utilized by Marina Coast Water District, or its assignee,
in any given year.
Final EIR
5-78
September 2015
The Marina Coast Water District has not exercised its RUWAP recycled water rights, but could in the
future, if water use agreements are obtained from urban irrigators and funding is made available for the
construction of the RUWAP recycled water distribution system.
.
Because the Source Waters MOU is not binding, the parties to the Source Waters MOU intend to address
rights to use wastewater in the forthcoming Definitive Agreement. Although the Definitive Agreement is
needed to secure these water rights, the Source Waters MOU demonstrates a reasonable likelihood that
this source of water can be obtained.
Page 4.18-32
The following section in the middle of the page has been changed as follows in
response to comments C-2, C-3, G-14, G-19, and P-3:
Rights to Surface Waters (Reclamation Ditch, Tembladero Slough, and Blanco Drain, and Lake El Estero
Diversions)
The Monterey County Water Resources Agency is seeking appropriative water rights permits from the
State Board to divert and use of several of the source waters. Water that enters surface streams and
rivers is considered water of the state. A water rights permit is required to impound or divert waters of the
state, except for certain riparian uses. Stormwater runoff from urban areas through storm drain
infrastructure (i.e., in the City of Salinas or Monterey) does not become water of the state until it is
discharged into a river or channel and rights to use that water are discussed separately below. Transfer of
surface water flows out of known and defined channels for recycling would be a consumptive use that
may come under the jurisdiction and regulation of the State Board. Three Four of the proposed source
waters the Lake El Estero, Blanco Drain, Reclamation Ditch, and Tembladero Slough diversion sites
would require appropriation of surface water under State Board jurisdiction. These source waters include
agricultural return flow (overland flow and tile drainage), stormwater flow, and urban runoff.
Page 4.18-33
The following section on this page has been changed as follows in response to
comments C-2, C-3, G-14, G-19, and P-3:
Rights to Urban Runoff Captured in Municipal Stormwater Infrastructure

As noted above, stormwater runoff from urban areas through storm drain infrastructure (i.e., in the City of
Salinas or the City of Monterey) does not become water of the state until it is discharged into a river or
channel. The proposed new stormwater runoff diversion at the Salinas Pump Station Diversion site (i.e.,
at the City of Salinas TP1 site) is upstream of any river or open channel in the City of Salinas storm
drainage system and therefore, the diversion of the Salinas stormwater would not occur where it would be
considered water of the state. In addition, the diversion of Lake El Estero water by diverting it to the
MRWPCA wastewater collection system rather than to the beach in Monterey would not be considered
water of the state because those same waters are being pump or are flowing from the lake to the beach
in city storm drainage system pipes. To divert stormwater and dry weather flow from urban areas,
agreements are required between MRWPCA and the local agencies that currently collect and convey the
flows in man-made facilities for discharge to surface waters, such as Salinas River for the City of Salinas
urban runoff/stormwater source water and Monterey Bay for the City of Monterey (for the Lake El Estero
source water). MRWPCA is developing an interruptible rate model and criteria which is anticipated to be
approved in 2015. The new rate will address capacity and user fees for the various source water within
the Proposed Project (Bob Holden, personal communication, January 2015).
Therefore, MRWPCA will need to obtain contractual water rights from the applicable local agencies,
including the City of Salinas and the City of Monterey. There are currently no contractual arrangements or
permits for the diversion of stormwater. However, the City of Salinas and the City of Monterey hasve been
working cooperatively with MRWPCA, demonstrating a reasonable likelihood that this source of water can
be obtained.
Page 4.18-34
The first paragraph on this page has been changed as follows in response to
comments C-2, C-3, G-14, G-19, M-26, and P-3:

Final EIR
5-79
September 2015
Impact Conclusion
The Proposed Project would result in minimal increased water demand due to employment of nine new
permanent workers, which could be served by existing water suppliers. The Proposed Project operations
would require substantial new source water supplies to meet its project objectives of recycling wastewater
for beneficial use as described in Chapter 2, Project Description. Technical reports supporting the
Proposed Project description and impacts analysis (i.e., those listed in Section 4.18.1) and other facts in
the record demonstrate that it is reasonably likely that approximately 16,000 to 17,000 AFY of surplus
waters can be feasibly be made available to meet Proposed Project demands of approximately 9,860
AFY. For each of the proposed source waters, entitlements or agreements would be needed. The
proposed diversions from Lake El Estero, Reclamation Ditch, Tembladero Slough, and Blanco Drain
would require new water rights entitlements from the State Board and contractual
arrangements/agreement(s) with Monterey County Water Resources Agency.
The Water Resources Agency has filed an application with the State Water Resources Control Board for
diversions from the Reclamation Ditch, Tembladero Slough, and Blanco Drain, and it is reasonably likely
that rights to these sources of water will be obtained. In considering an application to appropriate water,
the State Board considers a number of factors. (Cal. Water Code 1250, et seq.) The State Board
considers the relative benefit to be derived from (1) all beneficial uses of the water concerned including,
but not limited to, use for domestic, irrigation, municipal, industrial, preservation and enhancement of fish
and wildlife, recreational, mining and power purposes, and any uses specified to be protected in any
relevant water quality control plan, and (2) the reuse or reclamation of the water sought to be
appropriated, as proposed by the applicant. The board may subject such appropriations to such terms
and conditions as in its judgment will best develop, conserve, and utilize in the public interest, the water
sought to be appropriated. (Cal. Water Code 1257). The State Board is guided by the policy that
domestic use is the highest use and irrigation is the next highest use of water. The Proposed Project is
consistent with these factors and it does not appear that any of the factors considered would reduce the
likelihood of obtaining the necessary permits.
Similarly, proposed diversions of storm water and diversions of agricultural wash water would require
agreements with the City of Salinas and the City of Monterey. The proposed diversion from Lake El
Estero may require an agreement from the City of Monterey for use of its facilities. Those cities are
cooperating with the project partners in designing and evaluating the project components. In addition, the
project partners intend to enter into a binding agreement to replace the MOU addressing use of
wastewater, facilities at the Regional Treatment Plant, and provision of water supplies to the CSIP.
Page 4.18-38
The last two sentences on this page have been changed as follows in response to
letter H:
The MOU indicates that the Proposed Project would not use these secondary effluent flows that represent
the amount of wastewater committed to, and used use by, Marina Coast Water District under the 1992
and 1996 Agreements described above. In the future, when Marina Coast completes construction of its
recycled water system the RUWAP Recycled Water Project and enters into agreements with urban
irrigators, the wastewater flows committed to those demands the recycled water granted to Marina Coast
under the 2009 RUWAP MOU would be provided, unless the 2009 RUWAP MOU allocations are
amended or rendered invalid.
Page 4.18-41
Figure 4.18-1 on this page has been replaced with Figure 4.18-1rev at the end of
Chapter 5.
CHANGES TO CHAPTER 5,
COMMITMENT OF RESOURCES
Page 5-2
GROWTH
AND
IRREVERSIBLE
The first paragraph has been modified as follows in response to comment Q-5:
As discussed in Section 4.14, Population and Housing, the Proposed Project is an infrastructure project
to provide replacement potable water for a portion of CalAms withdrawals from the Carmel River system,
as explained in Chapter 2, Section 2.3.6 and to provide recycled water for agricultural irrigation in
Final EIR
5-80
September 2015
northern Monterey County as explained in Chapter 2. The Proposed Project would not extend roads or
public services into an unserved area. As explained in Chapter 2, Section 2.3.4, CalAm is under State
Orders issued in 1995 and 2009 by the State Water Resources Control Board to secure replacement
water supplies for its Monterey District service area by January 2017 and reduce its Carmel River
diversions to 3,376 AFY by 2016-2017. As described in Section 2.3.2.3, an adjudication process in 2006
(CalAm v. City of Seaside et al., Case No. M66343) led to the issuance of a court decision that created
the Seaside Groundwater Basin Watermaster and that requires all basin pumpers, except overlying users
to decrease their operating yield from the Basin triennially until each reaches its allotted portion of the
court-defined natural safe yield of 3,000 AFY. A 2012 adjudication of the Seaside Groundwater Basin
also requires CalAm to decrease its operating yield from the Basin by 10% triennially until it reaches its
allotted portion of the court-defined natural safe yield of 1,494 AFY beginning in 2012. In its recent
submittals to the California Public Utilities Commission, CalAm estimates that it needs 9,752 acre feet per
year (AFY) of additional water supplies for its Monterey District service area to reduce its Carmel River
diversions to the degree required by the State Water Resources Control Board, and to reduce its pumping
in the Seaside Groundwater Basin in accordance with the adjudication pumping mandates.
CHANGES TO CHAPTER 6, ALTERNATIVES TO THE PROPOSED

PROJECT
Page 6-10
The following has been inserted at the bottom of the page in response to comment U-2:
Greater and more severe environmental impacts in most topical areas would occur due to the length of
new pipeline needed to be built to deliver the desalinated water as replacement water to CalAm.
Seawater desalination projects also require substantially more electricity per unit of water produced and
therefore, the resultant greenhouse gas emissions would be higher than under the Proposed Project.
Page 6-10
The final paragraph has been amended as follows:
Rationale for elimination from more detailed evaluation in this EIR: These projects are not
considered to be alternatives to the Proposed Project. They would not achieve the objective of providing
replacement water for the Monterey District service area customers by the timeframe specified in the
Proposed Project objectives, because they could not be developed in time to meet the timeframe
objectives. In addition, the desalination projects would be expected to result in greater or more severe
environmental impacts than would occur under the Proposed Project.
Page 6-35
Table 6-4 on this page has been changed on the line for Impact BT-2 as follows in
response to comment H-36 (This was a typographical error is being edited to be
consistent with the text of the impact conclusions in the Draft EIR in Section 4.5,
Biological Resources: Terrestrial on pages 4.5-61, 4.5-91 and 4.5-92 and the text of the
comparative alternatives analysis on Page 6-34 describing the table):
Table 6-4
Summary of Significant Impacts of Product Water Conveyance Options: RUWAP and Coastal
(including Pipelines and Booster Pump Stations)
Coastal
RUWAP
Alignment Alignment
Impact Title
Option
Option
AE-4: Operation Impacts due to Permanent Light and Glare
Note: this impact is specific to the Booster Pump Station components of the
Product Water Conveyance system. The pipelines would not result in any new
sources of light and glare.
BT-1: Construction Impacts to Special-Status Species and Habitat
BT-2: Construction Impacts to Riparian, Federally Protected Wetlands as defined by
Section 404 of the Clean Water Act, or Other Sensitive Natural Community
Final EIR
5-81
LSM
LSM
LSM
LSM
LSLSM
LSLSM
September 2015
Page 6-41
The row for Impact BT-2 in Table 6-5 has been changed as shown on the following page
and a footnote has been added based on a biological survey of the Alternative Monterey
Pipeline alignment, as applicable to the Proposed Project, by DD&A (DD&A, 2014).

Final EIR
5-82
September 2015
Table 65Rcviscd
c alAm ostnouh o n
rlpCrlll C ArtgiHnen t AItern ah ves 0 verv1ew
(NOTE: Where the Proposed
CaiAm Oistribulion System would
res.tjt in no IJ'Il)acts or 5es-.s than

signtflcant impacts, such lmpacts
have not been inducted il"'l this
tabte if they wc.tJid be the same
for the CalAm Distribution

System: Monterey and Transfer
Pipeline Altematives.)
KEY TO ACRONYMS:
..
~
r::
!!
su
.,.> D.
Q..~
Q.
>.
--
e"
o.:
'i.f
-
Mitigation Measures
r:: ..
<; r::
r:: "
oo.
Change to impact significance and

mitigation measures applicable
::Eii:
Nl
;= ~
=SijJ'lificant Without Mitigation I Less ~thanSigrificant with Mitigation: LS =Lessltlan-significant Impact

"-" Reti.IC&d =lmoact is reduced comrHwed to oroiect imoacl tf neither"-" nor ..... is shown the imo.acl is the same similar comoared to the oroiect irooact.
LSM
Nl
Nl
Nl
LSM
LSM
LSM
LSM
Change to impact significance and mitigation measures applicable
r::
"
~ " r::
;= !'!
= Sigrjficant Unavoidable l ~act even Wth Mitigation;

Greater = lm act is areater comoared to oroiect irroact.
., n.
_.. .,
.~ >.
AE-2: Minimize Coostruc6oo Nighttime lighting.

(Arli:1ies lo the Monterey Pipeline)
BT-1a, BT-1b, BT-1c, BT-1d, BT-1e, BT-1g, BT

1h, BT-1k, BT-1 1, BT-1m, BT-1n, and BT-1o. See
ooffij:.iete text in Tal:le S-1. (Apples to Monterey
Pipeline, oriy)
BT-2a: Avoidence and Minimization of lmoacts to
RiQ!!rian Habitat and Weiand Habitats. IRtfllel!leAI
GeR&In~stieA Qesl MaAagemeRI f2Faeti&e&. (Applies
to both)
BT-2b: Avcidance and Mirimization of lrJl)acts to
Central Dune Sa-ub Habitat. (Arli:1ies to Monterey
Pipeline, oriy)
BT-6: tm;:lementation of Mitigation Measure BT-1a

for Avoidance and Minimization of Operational
Impacts to Sensitive Habitat (Applies to Monterey
Pipeline, oriy)
Same I No mitigation required
Nl
LSM
LS-
Same I No mi6gation required

bSM
~
Nl
Nl
N t-
The !'Jternalive Monterey Pipeline w:nld not avoid or reduce the i~Jlll!CI to a less-than-significant level
compared to the Propo$ed Project because nighllime lighting would stll be potentially used during
construction of for the !'Jternalive Monterey Pipeline. Mi6gation mtJd be required for the Propo$ed Prcject
and Alternalive Monterey Pipeline.
Mitiaation Measure AE-2wotJd be reauired for the Prooosed Pl'oiecl and Plternative,
The Plternative Monterey PipelinemtJd reduce the prcject impact to special slalus during construction to a
less-than-significant level because the pipeline wotJd be entirely with roatt..ay rights of way.
Mitigation Measures: None Reqtired
The Plternalive Monier!!): Pi~eline mud reduce the mgect im(l!!ct to sensitive habitats during construction to
aless-than-significant level because the gi~ine wotl d be entirelx v.ilh rom!! righls of 't!2J..
Mitigation Measures: None R!!gtired
+he ,~leFAal~re MeAie.:ey Pi~eliAe v~eY~ Rei aei ~ eF fe9wse lhe ilf!Jla&l ~e a less lhaA &igRi#ieaAI Ie\rel.
,6J t~9wgh the Plt9FRati9 Moot9F6y Pi~eliR9 W9 Y ~ ti3>,~R>8 dilleF9Rt at:ea6 aA~ ~i#81'9Rt l}jle691 ~allilals thaR
u~e Pu;;~gs'*' ~FaRGfeF aREI MeR&9F9')l Pi~eliR9, u~e GQR6lHIG~QR r9a~e~ i!J!f3ats UJ9WI9 Ge si~aF le lh9G9 ef
l~e Rmpgs~ ~FaR&~ aREI MeAI&r&)l PipS iRe& weYGtfa~~elhe sa!M 191.181 g~ if:RPQG
I &i!}RificaAGe as the
PFepe&QEI Prejest aigAJRBAt ~QI''e' 'QF, ''rt:l8F9 tli#8F9At f:e68W
F09&u~ewiEI ~a a9'8FGfly afJestetl, *feFeAt
MitigatieR M98$W ~9& 161:1EI a~y.
MitigatieRMeaSUF9 8T 2a aREI 8T 2b tN6l.EI Ge rtiEfUi,:eEI f&r ~9 PFSp9&9~ aREI ~terRafive M9At8F9')'
.
.
, DT
ih
.J!l
The Plternative Monterey Pipeline woud avoid the significant impact on sensitive habitats (Coastal Dune
Scrub and Monarth Butternies).
Mitigation Measures: None Req\ired
CR-1: Avadance and Vibration Monitoring for

Pipeline Installation in the Presido of Monterey
Historic District, and Do>Mltown Monterey. (Arli:1ies
to Monterey Pipeline, orly)
Nl
10
cr ~
~ =
.:..-;
Q.
ii:
Nl
BT-6: Operational lmpa.clsto

Sensitive Hatilats, inducing
Riparian, fedefally protected
weHands as defined by Section
404 of the Oean Water Acl, or
Other Sensitive Natural
Commuritv.
CR-1: Construction Impacts on
Historical Resources
..
"
AE -2: Conslruc6on Impacts due

lo Temp~ry Ugh! and GI!M"e
BT-2: Construction l~ts to

Sensitive Hatilats, inducing
Riparian, Federally Protected
Welands as defined tJf Section
404 of the Oean Water Act or
Other Sensitive Natural
Commurily.
Note: If Ahernative Monterey Pipeline is implemented, neither the Proposed nor the Alternative Transfer Pipeline would be buih and those impacts would be eliminated.
..-;
"'+..
BT-1: Construction l ~ts to

Special.Slat us Species and
Habitat
ALTERNATIVES
CaiAm Distribution System: Transfer and Monterey Pipelines
PROPOSED
CaiAm Distribution System
Impac-t T ille
LSM
Nl
LSM+
Project irJl)acts lo historical resources would be simiar v.ilh the Allernafive Monterey Pipeline as v.ilh the
Proposed Transfer and Mooterey Pipeline. Construction of the Alternative Mooterey Pipeline cOlld impact Ihe
entrance monument at the Presido of Mooterey. a significant impact that wotJd be reduced lo less than
significant>Mth Mitiga6on Measure CR-1 . The Alternative Monterey Pipeline mud pass acjacentto the
Spanish R<l'fal Presido and through the Monterey Old Town National Historic landmaii< District, adjacent to
the Stokes Adobe, the Gabriel dela Torre Adobe. the Fremont Adobe, Cd too Hall, and Friendy Aaza.
Although those poten6ally impacted resources mud be different historical resources than the Propo$ed
Monterey PipEline would pde11tially irJl)act, lhe severity of impacts on any one would be simiar wilh
impemenlalion of the Proposed a Plternalive Monterey Pipeline. The Alternative Monterey Pipeline wrud
also extend t~ough the Pl'esido of Monterey Histaic District aloog Stil~l Avenue. Potential drect and
f ()( the Mernative Monterey Pipeline Mitigation Measures BT-2a and BT-2b are not apolicable. See Oenise Ouffy & Associates Inc. memorandum dated November 24 2014 IDO&A 20141.

Final EIR
5-83
September 2015

Final EIR
5-84
September 2015
CHANGES TO CHAPTER 7, LIST OF PREPARERS

Page 7-1
The following has been added to Title: List of Preparers and Persons Consulted
Page 7-3
The heading Schaaf & Wheeler* and text under the heading has been amended as
follows.
Schaaf and Wheeler Consulting Civil Engineers*
Andrew Sterbenz, P.E., Project Engineer

Josh Tabije, Assistant Engineer
Andrew Racz, Junior Engineer
Separation Processes, Inc.
Alex Wesner, P.E., Project Manager

Brad Reisinger, Project Engineer (since publication of the Draft EIR, Mr. Reisinger has now
moved to Hazen Sawyer)
Page 7-3
The following new subheading and list have been added at the end of this page/chapter:
7.5 Persons Consulted

In addition to all of the above individuals, the following additional persons were consulted in the
preparation of this EIR:
Kashkoli, Ahmad, Senior Environmental Scientist, Division of Financial Assistance, State

Water Resources Control Board
Clymo, Amy, Supervising Planner, Monterey Bay Unified Air Pollution Control District
Riedl, Rick, Engineer, City of Seaside
Scholze, Gary, Archaeologist, Division of Financial Assistance, State Water Resources

Control Board
Stewart, Susan, Environmental Scientist, Division of Financial Assistance, State Water

Resources Control Board
True, Brian, Capital Improvement Projects Engineer, Marina Coast Water District
Watson, Fred, Associate Professor, Division of Science and Environmental Policy California
State University Monterey Bay
White, Kelly, and Zigas, Eric, Project Managers for the MPWSP Draft EIR, Environmental
Science Associates, Inc.

Final EIR
5-85
September 2015
CHANGES TO THE APPENDICES

The following appendices from the Draft EIR have been changed as identified in this section. If an
appendix from the Draft EIR is not listed below, the Draft EIR version has remained the same. In addition,
new appendices AA through EE have been added to the EIR and they are listed in this section below the
changes to the Draft EIR appendices and included at the end of this Final EIR.
Appendix B of the Draft EIR has been replaced with Appendix B-Revised attached to this Final EIR in
response to comments H-51, Q-2, S-5, S-6, S-9, T-4, T-5, and T-6.
Appendix C of the Draft EIR has been replaced with Appendix C-Revised attached to this Final EIR in
response to comment C-2, C-3, C-4, and letter H.
Appendix F has been modified as follows in response to comments M-27 and M-28:
Page 8, Fourth sentence has been edited as follows:

The Monterey County Water Resources Agency intervenes in the breaching of Salinas
Lagoon as needed to prevent flooding of nearby properties each year by using equipment to
either cause or assist the breach (Casagrande et al. 2003)
Page 9, the second sentence under the heading 3.0.1.4 San Antonio River has been
edited as follows:
The San Antonio River is regulated by the San Antonio Dam (RM 5), which impounds
350,000 335,000 acre-feet
Appendix H of the Draft EIR has been modified to include an updated Table A in Attachment 3 that is
provided on the following pages.

Final EIR
5-86
September 2015
Table A Revised: Special-Status Species Known or With the Potential to Occur Within the Pure Water Monterey GWR Project Vicinity
Species
Antrozous
pallidus
Pallid bat
Status
(USFWS/
CDFW/
CNPS)
--/
SSC/
--
General Habitat
Potential Occurrence within Project Study Area
MAMMALS
Occurs in a wide variety of habitats including grasslands,
shrublands, arid desert areas, oak savanna, coastal forested
areas, and coniferous forests of the mountain regions of California.
Most common in open, dry habitats with rocky areas for roosting.
Day roosts include caves, crevices, mines, and occasionally
hollow trees and buildings. Seems to prefer rocky outcrops, cliffs,
and crevices with access to open habitats for foraging. Similar
structures are used for night roosting and will also use more open
sites such as eaves, awnings, and open areas under bridges for
feeding roosts.
Common permanent residents of chaparral and foothill woodland
habitats within the Santa Cruz Mountains from 0-1799 meters. Use
well-drained loam or sandy loam soils for burrowing. Burrows are
typically shallow (2-20 inches below the surface) and simple with a
main chamber and few escape chambers.
Dipodomys
venustus
venustus
Santa Cruz
kangaroo rat
--/
CNDDB/
--
Lasiurus cinereus
Hoary bat
--/
CNDDB/
--
Prefers open habitats or habitat mosaics with access to trees for

cover and open areas or edge for feeding. Generally roost in
dense foliage of trees.
Neotoma
macrotis luciana
Monterey duskyfooted woodrat
--/
SSC/
--
Forest and oak woodland habitats of moderate canopy with

moderate to dense understory. Also occurs in chaparral habitats.
Reithrodontomys
megalotis
distichlis
Salinas harvest
mouse
--/
CNDDB/
--

Final EIR
Known only to occur from the Monterey Bay region. Occurs in

fresh and brackish water wetlands, and probably in the adjacent
uplands around the mouth of the Salinas River.
5-87
Moderate: The pallid bat may roost in trees within the Project Study
Area, most likely coast live oak trees and riparian forest, and may
forage over non-native grasslands, central coastal scrub, and central
maritime chaparral habitats. Therefore, it may occur at the Salinas
Treatment Facility site, Blanco Drain site, Product Water Conveyance:
RUWAP and Coastal alignment options, Injection Well Facilities site,
CalAm Distribution System: Monterey Pipeline, and the three Affected
Reaches. However, project components contain little to no habitat to
support day roosts.
Unlikely: Project Study Area is not located with the Santa Cruz
Mountains.
High: The hoary bat may roost in within the Project Study Area, most
likely coast live oak trees and riparian forest, and may forage over the
open habitats, including non-native grasslands, central coastal scrub,
and central maritime chaparral habitats. Therefore, it may occur at
the Product Water Conveyance: RUWAP and Coastal alignment
options, Injection Well Facilities site, and the three Affected Reaches.
There is a high potential for hoary bat to forage and roost within these
habitats, but maternity roosts are unlikely to occur.
High: Suitable habitat is present within the oak woodland, coastal
scrub, and maritime chaparral habitats within the Project Study Area.
Woodrat nests were observed during surveys in 2014 within the
Injection Well Facilities site. Suitable habitat occurs within the Salinas
Treatment Facility site, Blanco Drain Diversion site, along the Product
Water Conveyance: RUWAP and Coastal alignment options,
Injection Well Facilities site, CalAm Distribution System: Monterey
Pipeline, and the three Affected Reaches. The riparian habitat at
Roberts Lake and Locke Paddon Lake is likely not dense enough to
provide woodrat habitat and the species is unlikely to occur there.
Moderate: Three CNDDB occurrences of this species are recorded
within the Project Study Area, near Seaside Marina, and Armstrong
Ranch. Suitable habitat present at the SalinasTreatment Facility site,
Blanco Drain Diversion site, Lake El Estero, Locke Paddon Lake
(Product Water Conveyance: Coastal alignment option) (included in
CNDDB occurrence), Roberts Lake (adjacent to CNDDB occurrence)
(CalAm Distribution System: Monterey Pipeline) & the Affected
Reaches.
September 2015
Species
Status
(USFWS/
CDFW/
CNPS)
General Habitat

Moderate: Suitable habitat is present within the Project Study Area
along the Salinas River within the Salinas Treatment Facility and the
Blanco Drain Diversion sites, Product Water Conveyance: RUWAP
and Coastal alignment options, Injection Well Facilities site, CalAm
Distribution System: Monterey Pipeline, and the three Affected
Reaches. The CNDDB does not report any occurrences within the 16
Quads analyzed; however, this species is known to occur within the
vicinity of the Project Study Area (Bolster, 1998).
High: One CNDDB occurrence of this species is recorded within the
Project Study Area, near Seaside and Sand City. However, this is a
historic occurrence and the area has since been developed. Suitable
habitat within the Project Study Area is present within the non-native
grassland habitat within the Product Water Conveyance: RUWAP and
Coastal alignment options.
Sorex ornatus
salarius
Monterey ornate
shrew
--/
SSC/
--
Mostly moist or riparian woodland habitats, and within chaparral,

grassland, and emergent wetland habitats where there is a thick
duff or downed logs.
Taxidea taxus
American badger
--/
SSC/
--
Dry, open grasslands, fields, pastures savannas, and mountain

meadows near timberline are preferred. The principal
requirements seem to be sufficient food, friable soils, and relatively
open, uncultivated grounds.
--/
WL/
--
Resident throughout most of the wooded portion of the state.

Dense stands of live oak, riparian deciduous, or other forest
habitats near water used most frequently. Seldom found in areas
without dense tree stands, or patchy woodland habitats.
Nest in colonies in dense riparian vegetation, along rivers,
lagoons, lakes, and ponds. Forages over grassland or aquatic
habitats.
Moderate: Possible nesting and foraging habitat is present within the

Project Study Area.
Use rolling foot-hills, mountain terrain, wide arid plateaus deeply

cut by streams and canyons, open mountain slopes, cliffs, and
rocky outcrops. Nest in secluded cliffs with overhanging ledges as
well as large trees.
Usually found in open areas with few trees, such as annual and
perennial grasslands, prairies, meadows, dunes, irrigated lands,
and saline and freshwater emergent marshes. Dense vegetation
is required for roosting and nesting cover. This includes tall
grasses, brush, ditches, and wetlands. Open, treeless areas
containing elevated sites for perching, such as fence posts or
small mounds, are also needed. Some individuals breed in
northern California.
Year round resident of open, dry grassland and desert habitats,
and in grass, forb and open shrub stages of pinyon-juniper and
ponderosa pine habitats. Frequent open grasslands and
shrublands with perches and burrows. Use rodent burrows (often
California ground squirrel) for roosting and nesting cover. Pipes,
culverts, and nest boxes may be substituted for burrows in areas
where burrows are not available.
Low: Foraging habitat is present within the Project Study Area
BIRDS
Accipiter cooperii
Coopers hawk
Agelaius tricolor
Tricolored
blackbird
Aquila chrysaetos
Golden eagle
--/
SSC/
---/
FP/
--
Asio flammeus
Short-eared owl
--/
SSC/
--
Athene
cunicularia
Burrowing owl
--/
SSC/
--

Final EIR
5-88
High: The CNDDB reports an occurrence of this species at Locke

Paddon Lake.
Unlikely: This species does not breed within Monterey County and
only low quality overwintering habitat is present within the Project
Study Area. The Project is unlikely to impact this species, as
overwintering habitat is not typically protected.
High: Three CNDDB occurrences of this species are recorded within

the Project Study Area. Suitable habitat for this species is present
within the non-native grassland habitat along the Product Water
Conveyance: RUWAP and Coastal alignment options. Additionally,
this species may be present within the coastal dune scrub areas
within the CalAm Distribution System: Monterey Pipeline, based on
CNDDB observations within the area and despite the lack of typical
habitat for the species.
September 2015
Species
Brachyramphus
marmoratus
Marbled murrelet
(nesting)
Buteo regalis
Ferruginous hawk
Status
(USFWS/
CDFW/
CNPS)

Unlikely: No CNDDB occurrences within quads searched. No habitat
is present within the Project study area.
Charadrius
alexandrius
nivosus
Western snowy
plover
FT/
SSC/
--
Occur year-round in marine subtidal and pelagic habitats from the

Oregon border to Point Sal. Partial to coastlines with stands of
mature redwood and Douglas-fir. Requires dense mature forests
of redwood and/or Douglas-fir for breeding and nesting.
An uncommon winter resident and migrant at lower elevations and
open grasslands in the Modoc Plateau, Central Valley, and Coast
Ranges and a fairly common winter resident of grassland and
agricultural areas in southwestern California. Frequent open
grasslands, sagebrush flats, desert scrub, low foothills surrounding
valleys, and fringes of pinyon-juniper habitats. Does not breed in
California.
Sandy beaches on marine and estuarine shores, also salt pond
levees and the shores of large alkali lakes. Requires sandy,
gravelly or friable soil substrate for nesting.
Cypseloides niger
Black swift
--/
SSC/
---/
FP/
--
Regularly nests in moist crevices or caves on sea cliffs above the

surf, or on cliffs behind or adjacent to waterfalls in deep canyons.
Forages widely over many habitats.
Open groves, river valleys, marshes, and grasslands. Prefer such
area with low roosts (fences etc.). Nest in shrubs and trees
adjacent to grasslands.
Empidonax traillii
extimus
Southwestern
willow flycatcher
(nesting)
FE/
SE/
--
Eremophila
alpestris actia
California horned
lark
--/
WL/
--
Breeds in riparian habitat in areas ranging in elevation from sea

level to over 2,600 meters. Builds nest in trees in densely
vegetated areas. This species establishes nesting territories and
builds, and forages in mosaics of relatively dense and expansive
areas of trees and shrubs, near or adjacent to surface water or
underlain by saturated soils. Not typically found nesting in areas
without willows (Salix sp.), tamarisk (Tamarix ramosissima), or
both.
Variety of open habitats, usually where large trees and/or shrubs
are absent. Found from grasslands along the coast to deserts at
sea-level and alpine dwarf-shrub habitats are higher elevations.
Builds open cup-like nests on the ground.
Falco mexicanus
Prairie falcon
--/
WL/
--
Elanus leucurus
White-tailed kite
FT/
SE/
--
General Habitat
--/
CNDDB/
--

Final EIR
Associated primarily with perennial grasslands, savannahs,

rangeland, some agricultural fields, and desert scrub areas. Uses
open terrain for foraging; nests in open terrain with canyons, cliffs,
escarpments, and rock outcrops.
5-89
Low: A CNDDB occurrence of this species is recorded within the

Project Study Area near Armstrong Ranch. However, this species
does not breed in California and is, therefore, unlikely to be impacted
by the Project.
Unlikely: Three CNDDB occurrences are recorded within portions of

the Project Study Area. No suitable habitat for this species is present
within the Project Study Area. However, suitable habitat is present
immediately adjacent to the Project Study Area at the southern end of
Fort Ord, near the Highway One Fremont Street Exit in Seaside
(Seaside occurrence).
Unlikely: No suitable habitat present within the Project Study Area.
The nearest CNDDB occurrence is approximately five miles from the
Project Study Area.
High: Appropriate nesting and foraging habitat present within the
Project Study Area, particularly within the vicinity of Armstrong Ranch.
The nearest CNDDB occurrence is approximately seven miles from
the Project Study Area; however, an occurrence is also known within
Armstrong Ranch, immediately adjacent to the Project Study Area.
Unlikely: No CNDDB occurrences within quads searched. Habitat is
present within the Project Study Area. This species has a low
potential for occurrence as no breeding pairs have been seen in
recent decades and the species is unlikely to reoccupy this area until
brown-headed cowbirds, which parasitize the nest of other species,
are heavily controlled.
High: A CNDDB occurrence of this species is recorded within the

Project Study Area near Armstrong Ranch in Marina. Suitable habitat
is present within the Project Study Area within the non-native
grassland habitat at the Product Water Conveyance: RUWAP and
Coastal alignment options.
Low: May forage within Project Study Area, near Armstrong Ranch.
No suitable nesting habitat is present within the Project Study Area
and is, therefore, unlikely to be impacted by the Project. The nearest
CNDDB occurrence is within the Spreckels Quad (exact occurrence
location information not available).
September 2015
Status
(USFWS/
CDFW/
CNPS)
General Habitat
Oceanodroma
homochroa
Ashy storm petrel
Pelecanus
occidentalis
californicus
California brown
pelican
Rallus longirostris
obsoletus
California clapper
rail
Riparia riparia
Bank swallow
--/
SSC/
-FD/
SD,FP/
--
Tied to land only to nest, otherwise remains over open sea. Nests
in natural cavities, sea caves, or rock crevices on offshore islands
and prominent peninsulas of the mainland.
Found in estuarine, marine subtidal, and marine pelagic waters
along the California coast. Usually rests on water or inaccessible
rocks, but also uses mudflats, sandy beaches, wharfs, and jetties.
FE/
SE,FP/
--
Occur within a range of salt and brackish marshes.
Sterna antillarum
browni
California least
tern (nesting
colony)
Vireo bellii
pusillus
Least Bells vireo
FE /
SE,CFP/
--
Unlikely: Only low quality habitat is present within the Project Study
Area. This species is now likely restricted to the San Francisco Bay
area. Occurrences have been recorded at Elkhorn Slough; however,
this species has not been observed there since the 1980s.
The nearest CNDDB occurrence is approximately 3 miles from the
Project Study Area. An occurrence of this species was also reported
by California State Parks in 2008 on Fort Ord, approximately 2,000
feet from the Product Water Conveyance: Coastal alignment option.
Unlikely: No CNDDB occurrences within quads searched. No habitat
is present within the Project Study Area.
Species
--/
ST/
--
FE/
SE/
--
REPTILES AND AMPHIBIANS

Ambystoma
FT/
californiense
ST/
California tiger
-salamander
Ambystoma
macrodactylum
croceum
Santa Cruz longtoed salamander
FE/
SE/
--

Final EIR
Nest colonially in sand banks. Found near water; fields, marshes,

streams, and lakes.
Sea beaches, bays; large rivers, bars.
Area.
Riparian habitats. Breed in willow riparian forest supporting a

dense, shrubby understory. Oak woodland with a willow riparian
understory is also used in some areas, and individuals sometimes
enter adjacent chaparral, coastal sage scrub, or desert scrub
habitats to forage.
Area; considered extirpated in northern Monterey County.
Annual grassland and grassy understory of valley-foothill

hardwood habitats in central and northern California. Need
underground refuges and vernal pools or other seasonal water
sources.
Unlikely: No breeding habitat is present within the Project Study

Area. Several breeding locations are known within Fort Ord;
however, all of these are located 2.0 miles or greater from the Project
Study Area, outside of the known dispersal range for this species. A
tiger salamander breeding site is also known within Armstrong Ranch,
approximately 300 feet from the Project Study Area, and suitable
upland habitat is present within the Project Study Area in this area.
However, it was determined through genetic testing that the tiger
salamander population at this location was non-native.
Unlikely: No breeding habitat is present on the Project Study Area.
The nearest CNDDB occurrence is approximately five miles Project
Study Area, outside of the potential dispersal range for this species.
Preferred habitats include ponderosa pine, montane hardwoodconifer, mixed conifer, montane riparian, red fir, and wet
meadows. This is an isolated subspecies which occurs in a small
number of localities in Santa Cruz and Monterey Counties. Adults
spend the majority of the time in underground burrows and
beneath objects. Larvae prefer shallow water with clumps of
5-90
September 2015
Species
Status
(USFWS/
CDFW/
CNPS)
General Habitat
vegetation.
Requires moist, warm habitats with loose soil for burrowing and
prostrate plant cover, often forages in leaf litter at plant bases;
may be found on beaches, sandy washes, and in woodland,
chaparral, and riparian areas.
Anniella pulchra
California legless
lizard
(includes A. p.
nigra and A. p.
pulchra as
recognized by the
DFG)
Emys marmorata
Western pond
turtle
--/
SSC/
--
Phrynosoma
blainvillii
Coast horned
lizard
--/
SSC/
--
Rana boylii
Foothill yellowlegged frog
--/
SSC/
--
Rana draytonii
California redlegged frog
FT/
SSC/
--
Taricha torosa
Coast Range
newt
--/
SSC/
--
Thamnophis
hammondii
Two-striped
garter snake
INVERTEBRATES
Branchinecta
lynchi
Vernal pool fairy
--/
SSC/
--
Occurs mainly in valley-foothill hardwood, valley-foothill hardwoodconifer, coastal scrub, and mixed chaparral but is known to occur
in grasslands and mixed conifer types. Seek cover under rocks
and logs, in mammal burrows, rock fissures, or man-made
structures such as wells. Breed in intermittent ponds, streams,
lakes, and reservoir.
Associated with permanent or semi-permanent bodies of water
bordered by dense vegetation in a variety of habitats from sea
level to 2400m elevation.
FT/
--/
--
Require ephemeral pools with no flow. Associated with vernal

pool/grasslands from near Red Bluff (Shasta County), through the
central valley, and into the South Coast Mountains Region.
--/
SSC/
--

Final EIR
Associated with permanent or nearly permanent water in a wide

variety of habitats including streams, lakes, ponds, irrigation
ditches, etc. Require basking sites such as partially submerged
logs, rocks, mats of vegetation, or open banks.
Associated with open patches of sandy soils in washes, chaparral,
scrub, and grasslands.
Partly-shaded, shallow streams and riffles with a rocky substrate in

a variety of habitats, including hardwood, pine, and riparian
forests, scrub, chaparral, and wet meadows. Rarely encountered
far from permanent water.
Lowlands and foothills in or near permanent or late-season
sources of deep water with dense, shrubby, or emergent riparian
vegetation. During late summer or fall adults are known to utilize a
variety of upland habitats with leaf litter or mammal burrows.
5-91
High: Suitable habitat present within any of the undeveloped areas of

the Project Study Area. The CNDDB reports occurrences within six of
the 16 Quads analyzed. Additionally, a specific occurrence is
reported within the Project Study Area in Marina, near the Fort Ord
Natural Reserve (FONR).
High: Suitable habitat is present within the Project Study Area near
Locke Paddon Lake and Roberts Lake. The nearest CNDDB
occurrence is less than 100 feet from the Project Study Area.
High: Two CNDDB occurrences of this species are recorded within
the Project Study Area near Armstrong Ranch. Suitable habitat for
this species is present within the Project Study Area of the Product
Water Conveyance: RUWAP and Coastal alignment options, Injection
Well Facilities site, CalAm Distribution System: Monterey Pipeline,
Reclamation Ditch Affected Reach, and Old Salinas River Channel
Affected Reach.
Unlikely: No habitat is present within the Project Study Area.
High: The nearest CNDDB occurrence is located approximately one

mile from the Project Study Area along the Salinas River. CRLF were
observed breeding at this location in 2009. Appropriate breeding
habitat also includes Roberts Lake and Locke Paddon Lake; although
these resources are likely outside of the dispersal range for CRLF.
Moderate: Aestivation habitat is present within the Project Study
Area.
Moderate: Suitable habitat is present within the Project Study Area

near Locke Paddon Lake and Roberts Lake. The nearest CNDDB
occurrence is approximately 10 miles from the Project Study Area.
Unlikely: No CNDDB occurrences within quads searched. California

fairy shrimp (Linderella occidentalis) known to occur in vernal pools in
the vicinity of the Project Study Area, but no vernal pool fairy shrimp
September 2015
Species
Status
(USFWS/
CDFW/
CNPS)
shrimp
General Habitat
Require ephemeral pools with no flow.
have been identified. No habitat is present within the Project Study

Area.
Unlikely: Project Study Area is outside of the known current range.
Cicindela ohlone
Ohlone tiger
beetle
FE/
CNDDB/
--
Coelus globosus
Globose dune
beetle
--/
CNDDB/
--
Danaus plexippus
Monarch butterfly
--/
CNDDB/
--
Euphilotes
enoptes smithi
Smiths blue
butterfly
FE/
CNDDB/
--
Helminthoglypta
sequoicola
consors
Redwood
shoulderband
snail
Linderiella
occidentalis
California
linderiella
Optioservus
canus
Pinnacles
optioservus riffle
beetle
--/
CNDDB/
--
Known only from the south slope of San Juan grade, near foot, 8
miles northwest of Salinas.
--/
CNDDB/
--
Ephemeral ponds with no flow. Generally associated with

hardpans.
--/
CNDDB/
--
Species of this genus generally prefer gravelly or rocky streams

and some often occur on moss covered rocks. Both adults and
larvae crawl on rocks and gravel mostly in riffle areas.

Final EIR
Coastal terraces with remnant stands of open native grassland

with clay or sandy soils. Hunt, breed, and dig small vertical
burrows along sunny single-track trails and dirt roads (maintained
by cattle, hikers, etc.) in coast terrace meadows that still support
native grasses. Current range from the City of Scotts Valley to the
eastern edge of the City of Santa Cruz.
Coastal dunes. These beetles are primarily subterranean,
tunneling through sand underneath dune vegetation.
Overwinters in coastal California using colonial roosts generally

found in Eucalyptus, pine, and acacia trees. Overwintering habitat
for this species within the Coastal Zone represents ESHA. Local
ordinances often protect this species as well.
Most commonly associated with coastal dunes and coastal sage
scrub plant communities in Monterey and Santa Cruz Counties.
Plant hosts are Eriogonum latifolium and E. parvifolium.
5-92
Unlikely: Suitable habitat is present within the foredune habitat

adjacent to the Project Study Area. The nearest CNDDB occurrence
is approximately 1,000 feet from the Project Study Area, near the
Highway 1 Fremont Street Exit in Seaside. This species is restricted
to the foredunes within 100 feet of the wave wash zone. It has not
been collected from Monterey beaches for many years, and may have
been extirpated in the Project vicinity (Doyen, 1976).
High: A CNDDB occurrence of this species is reported within the
Project Study Area, located within the Eucalyptus grove across from
the Naval Post-graduate School in Monterey along the CalAm
Distribution System: Monterey Pipeline.
High: The CNDDB reports an occurrence of this species that ranges
from Seaside to Monterey and includes portions of the Project Study
Area. The host plants for this species were identified within the
Project Study Area, near Fort Ord Dunes State Park (Product Water
Conveyance: Coastal alignment option) and Window on the Bay
Waterfront Park (CalAm Distribution System: Monterey Pipeline). In
addition, the coastal scrub and coastal dune scrub habitats within the
Reclamation Ditch Affected Reach and Old Salinas Channel Affected
Reach may support obligate host species.
Unlikely: The only known occurrence of this species is not in the
vicinity of the Project Study Area.
September 2015
Species
Trimerotropis
infantilis
Zayante bandwinged
grasshopper
Tryonia imitator
Mimic tryonia
(=California
brackishwater
snail)
PLANTS
Agrostis lacunavernalis
Vernal pool bent
grass
Allium hickmanii
Hickmans onion
Artcostaphylos
andersonii
Andersons
manzanita
Artcostaphylos
edmundsii
Little Sur
manzanita
Arctostaphylos
hookeri ssp.
hookeri
Hookers
manzanita
Arctostaphylos
montereyensis
Toro manzanita
Arctostaphylos
pajaroensis
Pajaro manzanita
Arctostaphylos
pumila
Status
(USFWS/
CDFW/
CNPS)
FE/
CNDDB/
--
General Habitat
Open sandy areas with sparse, low annual and perennial herbs on
high ridges with sparse ponderosa pine. Often occurs with Ben
Lomond wallflower. Restricted to sand parkland habitat found on
ridges and hills within the Zayante sandhills habitat in Santa Cruz
County. Flight season extends from late May through August.
Inhabits coastal lagoons, estuaries and salt marshes. Found only
in permanently submerged areas in a variety of sediment types.
Tolerant of a wide range of salinities.
Unlikely: No suitable habitat present within the Project Study Area

and not identified during focused botanical surveys in 2014.
--/
CNDDB /
1B
Vernal pool mima mounds at elevations of 115-145 meters.

Annual herb in the Poaceae family; blooms April-May. Known only
from Butterfly Valley and Machine Gun Flats of Ft. Ord National
Monument.
Closed-cone coniferous forests, maritime chaparral, coastal
prairie, coastal scrub, and valley and foothill grasslands at
elevations of 5-200 meters. Bulbiferous herb in the Alliaceae
family; blooms March-May.
Openings and edges of broadleaved upland forest, chaparral, and
north coast coniferous forest at elevations of 60-760 meters.
Evergreen shrub in the Ericaceae family; blooms November-May.
--/
CNDDB/
1B
Coastal bluff scrub and chaparral on sandy soils at elevations of

30-105 meters. Evergreen shrub in the Ericaceae family; blooms
November-April.
Not Present: Not identified during focused botanical surveys in 2009,

2010, and 2014.
--/
CNDDB /
1B
Closed-cone coniferous forest, chaparral, cismontane woodland,

and coastal scrub on sandy soils at elevations of 85-536 meters.
Evergreen shrub in the Ericaceae family; blooms January-June.
Present: Observed near CSUMB and the Naval Post-Graduate

School in the City of Monterey during focused botanical surveys in
2009, 2010, and 2014.
--/
CNDDB
1B
--/
CNDDB
1B
--/
CNDDB
Maritime chaparral, cismontane woodland, and coastal scrub on

sandy soils at elevations of 30-730 meters. Evergreen shrub in
the Ericaceae family; blooms February-March.
Chaparral on sandy soils at elevations of 30-760 meters.
Evergreen shrub in the Ericaceae family; blooms DecemberMarch.
Closed-cone coniferous forests, maritime chaparral, cismontane
woodland, coastal dunes, and coastal scrub on sandy soils at

2010, and 2014.
--/
CNDDB/
--
--/
CNDDB /
1B
--/
CNDDB/
1B

Final EIR
5-93
Low: Marginal habitat is present within Roberts Lake and the Old
Salinas River Channel. There are no occurrences known for Roberts
Lake and the habitat present is marginal. A historic CNDDB
occurrence is present within the Affected Reaches Project Study Area
in the Old Salinas River Channel; however, this occurrence is from
1981 and presence at this location is listed as extirpated. The
nearest modern CNDDB occurrence is approximately 0.5 miles from
the Project Study Area within Elkhorn Slough.

2010, and 2014.

2010, and 2014.

2010, and 2014.
Present: Observed throughout Fort Ord Dunes State Park (Product
Water Conveyance: Coastal alignment option), and near California
September 2015
Species
Status
(USFWS/
CDFW/
CNPS)
General Habitat
Sandmat
manzanita
1B
elevations of 3-205 meters. Evergreen shrub in the Ericaceae

family; blooms February-May.
Arenaria
paludicola
Marsh sandwort
FE/
SE/
1B
Known from only two natural occurrences in Black Lake Canyon

and at Oso Flaco Lake. Sandy openings of freshwater of brackish
marshes and swamps at elevations of 3-170 meters.
Stoloniferous perennial herb in the Caryophyllaceae family;
blooms May-August.
Broadleaved upland forest, chaparral, and north coast coniferous
forest on granitic or sandstone souls at elevations between 305730 meters. Evergreen shrub in the Ericaceae family; blooms
January-April
Playas, valley and foothill grassland on adobe clay, and vernal
pools on alkaline soils at elevations of 1-60 meters. Annual herb
in the Fabaceae family; blooms March-June.
Coastal bluff scrub on sandy soils, coastal dunes, and mesic areas
of coastal prairie at elevations of 1-50 meters. Annual herb in the
Fabaceae family; blooms March-May.
Artcostaphylos
regismontana
Kings mountain
manzanita
Astragalus tener
var. tener
Alkali milk-vetch
Astragalus tener
var. titi
Coastal dunes
milk-vetch
Bryoria spiralifera
Twisted horsehair
lichen
--/
CNDDB/
1B
California
macrophylla
Round-leaved
filaree
Castilleja
ambigua var.
insalutata
Pink Johnny-nip
Ceanothus
cuneatus ssp.
rigidus
Monterey
ceanothus
--/
CNDDB/
1B
Centromadia
parryi ssp.
congdonii
Congdons
tarplant
--/
CNDDB/
1B
FE/
SE/
1B
State University at Monterey Bay (CSUMB) (Product Water

Conveyance: RUWAP alignment option) during focused botanical
surveys in 2014.
Unlikely: No CNDDB occurrences within quads searched. Suitable
habitat is present within the Project Study Area; however, the Project
Study Area is not located near the only two occurrences of this
species.
Unlikely: Project Study Area is outside of the species elevation
range.

2010, and 2014.
2010, and 2014.
California North Coast coniferous forest at an elevation of 0 30

meters. Often found on conifers, including Picea sitchensis, Pinus
contorta var. contorta, Pseudotsuga menziesii, Abies grandis,
and Tsuga heterophylla. Fruticose lichen in the Parmeliaceae
family.
Cismontane woodland and valley and foothill grassland on clay
soils at elevations of 15-1200 meters. Annual herb in the
Geraniaceae family; blooms March-May.
--/
CNDDB/
1B
Coastal prairie and coastal scrub at elevations of 0-100 meters.

Annual herb in the Orobanchaceae family; blooms May-August.

2010, and 2014.
--/
CNDDB/
4
Closed cone coniferous forest, chaparral, and coastal scrub on

sandy soils at elevations of 3-200 meters. Evergreen shrub in the
Rhamnaceae family, blooms February-April.
--/
CNDDB/
1B
Valley and foothill grassland on alkaline soils at elevations of 1230 meters. Annual herb in the Asteraceae family; blooms JuneNovember.
Present: Observed at the Injection Well Facilities site, throughout

Fort Ord Dunes State Park (Product Water Conveyance: Coastal
alignment option), within Sand City (CalAm Distribution System:
Monterey Pipeline), and near CSUMB (Product Water Conveyance:
RUWAP alignment option) during focused botanical surveys in 2009,
2010, and 2014.
2010, and 2014.
--/
CNDDB/
1B

Final EIR
5-94

2010, and 2014.
September 2015
Species
Chorizanthe
pungens var.
pungens
Monterey
spineflower
Chorizanthe
robusta var.
robusta
Robust
spineflower
Clarkia jolonensis
Jolon clarkia
Collinsia
multicolor
San Francisco
collinsia
Cordylanthus
rigidus ssp.
littoralis
Seaside birdsbeak
Delphinium
californicum ssp.
interius
Hospital Canyon
larkspur
Delphinium
hutchinsoniae
Hutchinsons
larkspur
Delphinium
umbraculorum
Umbrella larkspur
Ericameria
fasciculata
Eastwoods
goldenbush
Eriogonum
nortonii
Pinnacles
Status
(USFWS/
CDFW/
CNPS)
General Habitat
FT/
CNDDB/
1B
Maritime chaparral, cismontane woodland, coastal dunes, coastal

scrub, and valley and foothill grassland on sandy soils at
elevations of 3-450 meters. Annual herb in the Polygonaceae
family; blooms April-June.
Present: Observed throughout Fort Ord, near Armstrong Ranch, and

on the dunes at the Injection Well Facilities site during focused
botanical surveys in 2009, 2010, and 2014.
FE/
CNDDB/
1B
Openings in cismontane woodland, coastal dunes, and coastal

scrub on sandy or gravelly soils at elevations of 3-300 meters.
Annual herb in the Polygonaceae family; blooms April-September.

2010, and 2014.
--/
CNDDB/
1B
--/
CNDDB/
1B
Cismontane woodland, chaparral, riparian woodland, and coastal

scrub at elevations of 20-660 meters. Annual herb in the
Onagraceae family; blooms April-June.
Closed-cone coniferous forest and coastal scrub, sometimes on
serpentinite soils, at elevations of 30-250 meters. Annual herb in
the Scrophulariaceae family; blooms March-May.

2010, and 2014.
Closed-cone coniferous forests, chaparral, cismontane woodlands,

coastal dunes, and coastal scrub on sandy soils, often on
disturbed sites, at elevations of 0-425 meters. Hemi-parasitic,
annual herb in the Scrophulariaceae family; blooms April-October.
High:. There is a high likelihood Seaside birds beak may occur within
the unsurveyed portion of the Injection Well Facilities site.
--/
CNDDB/
1B
Openings in chaparral, coastal scrub, and mesic areas of

cismontane woodland at elevations of 230-1095 meters.
Perennial herb in the Ranunculaceae family; blooms April-June.

2010, and 2014.
--/
CNDDB/
1B
Broadleaved upland forest, chaparral, coastal scrub, and coastal

prairie at elevations of 0-427 meters. Perennial herb in the
Ranunculaceae family; blooms March-June.

2010, and 2014.
--/
CNDDB/
1B
Cismontane woodland at elevations of 400-1600 meters.

Perennial herb in the Ranunculaceae family; blooms April-June.

2010, and 2014
--/
CNDDB/
1B
Closed-cone coniferous forest, maritime chaparral, coastal dunes,

and openings in coastal scrub on sandy soils at elevations of 30275 meters. Evergreen shrub in the Asteraceae family; blooms
July-October.
Chaparral and valley and foothill grassland on sandy soils, often
on recent burns, at elevations of 300-975 meters. Annual herb in
the Polygonaceae family; blooms May-September.
Present: Observed at the Injection Well Facilities site and near

CSUMB (Product Water Conveyance: RUWAP alignment option)
during focused botanical surveys in 2014.
--/
SE/
1B
--/
CNDDB/
1B

Final EIR
5-95

2010, and 2014.

2010, and 2014
September 2015
Species
buckwheat
Erysimum
ammophilum
Sand-loving
(coast) wallflower
Erysimum
menziesii
Menzies
wallflower
Fritillaria liliacea
Fragrant fritillary
Status
(USFWS/
CDFW/
CNPS)
General Habitat
--/
CNDDB/
1B
Maritime chaparral, coastal dunes, and openings in coastal scrub

on sandy soils at elevations of 0-60 meters. Perennial herb in the
Brassicaceae family; blooms February-June.
Present: Observed near the Naval Postgraduate School (CalAm

Distribution System: Monterey Pipeline) during focused botanical
surveys in 2009, 2010, and 2014.
FE/
SE/
1B
Coastal dunes at elevations of 0-35 meters. Perennial herb in the

Brassicaceae family; blooms March-June.

2010, and 2014.
--/
CNDDB/
1B
Cismontane woodland, coastal prairie, coastal scrub, and valley

and foothill grassland, often serpentinite, at elevations of 3-410
meters. Bulbiferous perennial herb in the Liliaceae family; blooms
February-April.
Maritime chaparral, cismontane woodland, coastal dunes, and
openings in coastal scrub on sandy soils at elevations of 0-45
meters. Annual herb in the Polemoniaceae family; blooms AprilJune.
Closed-cone coniferous forest and maritime chaparral at
elevations of 30-300 meters. Evergreen tree in the Cupressaceae
family. Natively occurring only at Point Lobos near Gibson Creek
and the Huckleberry Hill Nature Preserve near Highway 68.
Closed-cone coniferous forest at elevations of 10-30 meters.
Evergreen tree in the Cupressaceae family. Natively occurring
only at Cypress Point in Pebble Beach and Point Lobos State
Park; widely planted and naturalized elsewhere.

2010, and 2014.
Gilia tenuiflora
ssp. arenaria
Monterey (sand)
gilia
Hesperocyparis
goveniana
Gowen cypress
FT/
CNDDB/
1B
Hesperocyparis
macrocarpa
Monterey cypress
--/
CNDDB/
1B
Holocarpha
macradenia
Santa Cruz
tarplant
Horkelia cuneata
var. sericea
Kelloggs horkelia
FT/
SE/
1B
Coastal prairies and valley foothill grasslands, often clay or sandy

soils, at elevations of 10-220 meters. Annual herb in the
Asteraceae family; blooms June-October.
--/
CNDDB/
1B
Closed-cone coniferous forests, maritime chaparral, and openings

in coastal scrub on sandy or gravelly soils at elevations of 10-200
meters. Perennial herb in the Rosaceae family; blooms AprilSeptember.
Mesic areas of valley and foothill grassland, alkaline playas,
cismontane woodland, and vernal pools at elevations of 0-470
meters. Annual herb in the Asteraceae family; blooms MarchJune.
Coastal dunes and coastal scrub on sandy soils at elevations of 060 meters. Annual herb in the Asteraceae family; blooms MarchJuly.
Vernal pools and wetlands at elevations of 1-880 meters. Annual
Lasthenia
conjugens
Contra Costa
goldfields
Layia carnosa
Beach layia
Legenere limosa
FE/
ST/
1B
FE/
CNDDB/
1B
FE/
SE/
1B
--/

Final EIR
5-96
High: There is a high likelihood sand gilia may occur within the
unsurveyed portion of the Injection Well Facilities site.
Not Present: Not identified during focused botanical survey in 2009,

2010, and 2014. Project Study Area it outside of currently known
range for this species.
Not Present: Project Study Area is outside of currently known range
for this species. Although several individuals of this species were
observed within the Project Study Area, these individuals are planted
specimens or volunteers from planted specimens and are not
considered special-status. Therefore, no natively-occurring Monterey
cypress trees are present within the Project Study Area.
2010, and 2014.
Present: Observed within the Product Water Conveyance: RUWAP

and Coastal alignment options and the Injection Well Facilities site
during focused botanical surveys in 2009, 2010, and 2014.
2010, and 2014.

2010, and 2014.
September 2015
Species
Legenere
Lupinus
tidestromii
Tidestroms
lupine
Malacothamnus
palmeri var.
involucratus
Carmel Valley
bush-mallow
Malacothamnus
palmeri var.
palmeri
Santa Lucia
bush-mallow
Malacothrix
saxatilis var.
arachnoidea
Carmel Valley
malacothrix
Microseris
paludosa
Marsh microseris
Monardella
sinuata ssp.
nigrescens
Northern curlyleaved
monardella
Monolopia
gracilens
Woodland
woolythreads
Pinus radiata
Monterey pine
Pedicularis
dudleyi
Dudleys
Status
(USFWS/
CDFW/
CNPS)
CNDDB/
1B
FE/
SE/
1B
General Habitat
herb in the Campanulaceae family; blooms April- June.
2010, and 2014
Coastal dunes at elevations of 0-100 meters. Perennial

rhizomatous herb in the Fabaceae family; blooms April-June. Only
Monterey County plants are state-listed Endangered as var.
tidestromii.
Chaparral, cismontane woodland, and coastal scrub at elevations
of 30-1100 meters. Deciduous shrub in the Malvaceae family;
blooms May-August.

2010, and 2014.
--/
CNDDB/
1B
Chaparral on rocky soils at elevations of 60-360 meters.

Deciduous shrub in the Malvaceae family; blooms May-July.

2010, and 2014.
--/
CNDDB/
1B
Chaparral and coastal scrub on rocky soils at elevations of 251036 meters. Perennial rhizomatous herb in the Asteraceae
family; blooms June-December (uncommon in March).

2010, and 2014.
--/
CNDDB/
1B
Closed-cone coniferous forest, cismontane woodland, coastal

scrub, and valley and foothill grasslands at elevations of 3-300
meters. Perennial herb in the Asteraceae family; blooms AprilJune (July).
Closed-cone coniferous forest, chaparral, coastal dunes, coastal
prairie, coastal scrub, and lower montane coniferous forest
(ponderosa pine sandhills) on sandy soils at elevations of 0-305
meters. Annual herb in the Lamiaceae family; blooms MaySeptember.

2010, and 2014.
Openings of broadleaved upland forest, chaparral, cismontane

woodland, North Coast coniferous forest, and valley and foothill
grassland on serpentinite soils at elevations of 100-1200 meters.
Annual herb in the Asteraceae family; blooms February-July.
Evergreen tree in the Pinaceae family. Only three native stands in
CA, at Ano Nuevo, Cambria, and the Monterey Peninsula;
introduced in many areas.

2010, and 2014.
--/
CNDDB/
1B
--/
CNDDB/
1B
--/
CNDDB/
1B
--/
--/
1B
--/
SR/
1B

Final EIR
Maritime chaparral, cismontane woodland, North Coast coniferous

forest, and valley and foothill grassland at elevations of 60-900
meters. Perennial herb in the Orbanchaceae family; blooms April5-97

2010, and 2014.

2010, and 2014.
Present: Several Monterey pine trees are present within the Project
Study Area; however, the majority of these individuals are planted
specimens or volunteers from planted specimens and are not
considered special-status. The only special-status individual of this
species is located within the Presidio of Monterey.
2010, and 2014.
September 2015
Species
Status
(USFWS/
CDFW/
CNPS)
lousewort
General Habitat
June.
Penstemon
rattanii var. kleei
Santa Cruz
Mountains
beardtongue
Pentachaeta
bellidiflora
White-rayed
pentachaeta
Piperia yadonii
Yadons rein
orchid
Plagiobothrys
chorisianus var.
chorisianus
Choris
popcornflower
Plagiobothrys
uncinatus
Hooked
popcornflower
Potentilla
hickmanii
Hickmans
cinquefoil
Ramalina
thrausta
Angels hair
lichen
--/
CNDDB/
1B
Chaparral and lower montane and North Coast coniferous forests

at elevations of 400-1100 meters. Perennial herb in the
Plantaginaceae family; blooms May-June.

2010, and 2014
FE/
SE/
1B
Cismontane woodland and valley and foothill grasslands, often on

serpentinite soils, at elevations of 35-620 meters. Annual herb in
the Asteraceae family; blooms March-May.

2010, and 2014.
FE/
CNDDB/
1B
--/
CNDDB/
1B
Sandy soils in coastal bluff scrub, closed-cone coniferous forest,

and maritime chaparral at elevations of 10-510 meters. Annual
herb in the Orchidaceae family; blooms May-August.
Mesic areas of chaparral, coastal prairie, and coastal scrub at
elevations of 15-160 meters. Annual herb in the Boraginaceae
family; blooms March-June.

2010, and 2014.
--/
CNDDB/
1B
Chaparral, cismontane woodlands, and valley and foothill

grasslands on sandy soils at elevations of 300-760 meters.
Annual herb in the Boraginaceae family; blooms April-May.

2010, and 2014

2010, and 2014.
Rosa pinetorum
Pine rose
--/
CNDDB/
1B
--/
CNDDB/
4
Coastal bluff scrub, closed-cone coniferous forests, vernally mesic

meadows, and freshwater marshes and swamps at elevations of
10-149 meters. Perennial herb in the Rosaceae family; blooms
April-August.
Found in California North Coast coniferous forest at an elevation
of 75 - 430 meters. Found on dead twigs, other lichen, and on
Alnus rubra, Calocedrus decurrens, Pseudotsuga
menziesii,Quercus garryana, and Rubus spectabilis. It has also
been found growing on and amid Ramalina
menziesii and Usnea spp. Fruticose lichen in the Ramalinaceae
family.
Shrub in the Rosaceae family; blooms May-July. Possible hybrid
of R. spithamea, R. gymnocarpa, or others; further study needed.
Broadleaved upland forest, coastal prairie, coastal scrub, north
coast coniferous forest, and riparian woodlands, often in disturbed
areas, at elevations of 2-700 meters. Perennial herb in the
Malvaceae family; blooms April-August.
Broadleaved upland forest, closed-cone coniferous forest,
chaparral, coastal prairie, coastal scrub, and openings in valley
Sidalcea
malachroides
Maple-leaved
checkerbloom
Stebbinsoseris
decipiens
FE/
SE/
1B
--/
CNDDB/
2B
--/
CNDDB/

Final EIR
5-98

2010, and 2014.

2010, and 2014.

2010, and 2014.
2010, and 2014.

2010, and 2014.
September 2015
Species
Santa Cruz
microseris
Tortula californica
California screw
moss
Trifolium
buckwestiorum
Santa Cruz clover
Trifolium
hydrophilum
Saline clover
Trifolium
polyodon
Pacific Grove
clover
Trifolium
trichocalyx
Monterey clover
Status
(USFWS/
CDFW/
CNPS)
1B
--/
CNDDB/
1B
--/
CNDDB/
1B
--/
CNDDB/
1B
--/
SR/
1B
FE/
SE/
1B

Final EIR
General Habitat
and foothill grassland, sometimes on serpentinite, at elevations of

10-500 meters. Annual herb in the Asteraceae family; blooms
April-May.
Valley and foothill grassland and chenopod scrub on sandy soils at
elevations of 10-1460. Moss in the Pottiaceae family.

2010, and 2014
Broadleaved upland forest, cismontane woodland, and margins of

coastal prairie on gravelly soils at elevations of 105-610 meters.
Annual herb in the Fabaceae family; blooms April-October.
Marshes and swamps, valley and foothill grassland (mesic,
alkaline), and vernal pools at elevations of 0-300 meters. Annual
herb in the Fabaceae family; blooms April-June.
Closed-cone coniferous forest, coastal prairie, meadows and
seeps, and mesic areas in valley and foothill grassland at
elevations of 5-120 meters. Annual herb in the Fabaceae family;
blooms April-June.
Sandy openings and burned areas of closed-cone coniferous
forest at elevations of 30-240 meters. Annual herb in the
Fabaceae family; blooms April-June.
5-99

2010, and 2014.
2010, and 2014.
2010, and 2014.

2010, and 2014.
September 2015
STATUS DEFINITIONS
U.S. Fish and Wildlife Service (USFWS)
FE
= listed as Endangered under the federal Endangered Species Act
FT
= listed as Threatened under the federal Endangered Species Act
FC
= federal Candidate under the federal Endangered Species Act
FD
= delisted under the federal Endangered Species Act
-= no listing
California Department of Fish and Wildlife (CDFW)
SE
= listed as Endangered under the California Endangered Species Act
ST
= listed as Threatened under the California Endangered Species Act
SC = state Candidate under the California Endangered Species Act
SR = listed as Rare under the California Endangered Species Act
SD = delisted under the California Endangered Species Act
SSC = California Department of Fish and Wildlife Species of Special Concern
FP
= California Fully Protected Animal
-= no listing
WL = California Department of Fish and Wildlife Watch List
CNDDB = This designation is being assigned to animal species that are not assigned any of the other status designations defined in this table. These animal species are included in the DFGs
CNDDB Special Animals list (2010), which includes all taxa the CNDDB is interested in tracking, regardless of their legal or protection status. This list is also referred to as the list of
species at risk or special-status species. The CDFG considers the taxa on this list to be those of greatest conservation need.
California Native Plant Society (CNPS)
1B
= List 1B species; Rare, Threatened or Endangered in California and elsewhere
2
= List 2 species; Rare, Threatened, or Endangered in California, but more common elsewhere
3
= List 3 species; plants about which more information is needed
4
= List 4 species; plants of limited distribution (CNPS Watch List)
-= no listing
POTENTIAL TO OCCUR
Present
= known occurrence of species within the site; presence of suitable habitat conditions; or observed during field surveys
High
= known occurrence of species in the vicinity from the CNDDB or other documentation; presence of suitable habitat conditions
Moderate
= known occurrence of species in the vicinity from the CNDDB or other documentation; presence of marginal habitat conditions within the site
Low
= species known to occur in the vicinity from the CNDDB or other documentation; lack of suitable habitat or poor quality
Unlikely
= species not known to occur in the vicinity from the CNDDB or other documentation, no suitable habitat is present within the site
Not Present
= species was not observed during surveys

Final EIR
5-100
September 2015
Appendix M has been modified as follows in response to comment M-29:
Page 15, last paragraph has been modified as follows:

Table 3 shows the modifications made to the average monthly supply sources for years when
capacity is constrained in June. Error! Reference source not found. Table 4 shows the
modifications made to the average monthly supply sources for years when pumping capacity
is constrained in both June and July. The cells highlighted in red show the changes from
CalAms original supply schedule.
Appendix O has been modified as follows in response to comments M-32, M-33 and M-34:
Page 17, Fifth sentence after Figure 2.4 has been replaced as follows:
The decline in average annual flows during the regulated period was approximately 90,000
AFY, due to a combination of increased groundwater recharge, increased evaporative losses
(from the reservoirs), lower average rainfall than the previous period and likely increases in
riparian water use due to year-round availability. The decline in average annual flows during
the regulated period represents almost 90,000 AFY going into groundwater recharge.
Page 19, Second sentence of the second paragraph has been replaced as follows:
Minimum fish releases were made from San Antonio and Nacimiento Reservoirs, but no
additional conservation releases. Measurable flow at the Spreckels gage was recorded only
on December 11-12 of that year. Reservoir releases were made from San Antonio and
Nacimiento Reservoirs for groundwater recharge, but no flow was recorded at the Spreckels
gage.
Appendix Q has been updated as follows in response to comments M-36 and M-37:
Revision Note: Updates were made to the following sections in response to comments M-36 and M-37
identifying that one of the referenced reports, Salinas Valley Water Project, Annual Flow Monitoring
Report, Water Year 2012, had been revised in May 2014. The revisions did not affect the yield or impacts
analysis results.
Section 2.1, page 7, the following text edit has been made to last paragraph:
The calculated return rates ranged from 3% to 25%, with an average return of 16.8% 17.3% (see Table
B-2: Blanco Drain Flows as Return Flows). The period with the most complete flow data for the Blanco
Drain was August to October 2013, with an average return rate of 16.9%. For this estimate, we assumed
a flat 17% return rate. The MCWRA CSIP records were combined with the Salinas rainfall records to
calculate the total estimated source flows (Table B-4: Applied Irrigation and Recorded Precipitation in the
CSIP Service Area). The return flows were estimated by month as shown below.
Section 2.2, page 10, the following text edit has been made to the second paragraph and
Table 2-3 has been updated as follows:
As a condition of operating the SRDF, MCWRA must maintain certain in-stream flows in the Salinas
River. When San Antonio and Nacimiento Reservoirs have a combined storage of 220,000 acre-feet, the
SRDF has a requirement to release (1) a minimum of 15 cfs downstream from April 1 to June 30, and (2)
a minimum of 2 cfs downstream from July 1 to the end of the SRDF operating season for maintenance of
the Salinas River Lagoon habitat. Higher block flow releases are triggered during steelhead migration
season if the Salinas Lagoon is open to the ocean. When the combined storage in the two reservoirs is
under 220,000 ac-ft, the minimum release requirement for Lagoon habitat maintenance is 2 cfs while the
SRDF is in operation. In Table 2-3, we compare the recorded daily by-passed flows at the SRDF (fish
ladder plus regulating weir, as shown in Figure 2-1) to the recorded Blanco Drain flows during year 2012.
Additional flow is reported to have spilled over the rubber dam during this period, but that volume was not
estimated. In each month, the by-passed flow minus the Blanco Drain flow exceeds the required minimum

Final EIR
5-101
September 2015

10
release. MCWRA manages releases to by-pass the required minimum plus the Blanco Drain flow , so
this proposed diversion should not impact SRDF operation.
Table 2-3:
SRDF By-Passed Flows, with and without Blanco Drain11
Month
Year
Avg Daily
By-Passed
Flow
Blanco
Drain
Flow
Average
minus
B.D.
Required
Minimum
By-Pass
cfs
cfs
cfs
cfs
2012
22.5
4.7 5.6
17.8 16.9
2.0
2012
18.6
5.2 5.0
13.4 13.6
2.0
2012
9.1
5.4 5.6
3.7 3.5
2.0
2012
10.1
5.2 5.3
4.9 4.8
2.0
2012
11.3
4.6 4.8
6.7 6.5
2.0
2012
18.3
3.5 3.6
14.8 14.7
2.0
10
2012
15.0
2.0 2.4
13.0 12.6
2.0
11
2012
57.3
1.0 1.1
56.3 56.2
Note: The triggers for a 15 cfs by-pass in April did not occur in 2012.
10
11
2.0
Table B-2 in Appendix B (of Appendix Q) has been replaced with the following:
Letter from Robert Johnson, MCWRA, June 5, 2015

Salinas Valley Water Project, Annual Flow Monitoring Report, Water Year 2012

Final EIR
5-102
September 2015
The following new appendices have been added to the EIR and are attached to this Final EIR:
Appendix AA, Technical Memorandum: Salinity Impacts to Elkhorn Slough

resulting from Surface Water Diversions for the Pure Water Monterey Groundwater
Replenishment Project, is added in response to comments F-8, F-9, G-2, G-3, G-4, G5, G-6, G-7, G-8, G-9, G-10, G-12 and G-13.
Appendix BB, Technical Memorandum: Future RUWAP Urban Recycled Water

Irrigation Water Use and Implications for CSIP Yields, is added in response to
comment letter H from the Marina Coast Water District.
Appendix CC, Technical Memorandum: Fish Passage Analysis, Reclamation Ditch

at San Jon Road and Gabilan Creek at Laurel Rd, is added in response to comments
E-8, E-9, E-10, F-8 and F-9.
Appendix DD, Technical Memorandum Consideration of Water Right Application

32263 in the Pure Water Monterey Project EIR, is added in response to comments C-2,
C-3, G-11, M-26, and Q-1.
Appendix EE, Resumes and Qualifications from Key EIR Contributors, in response
to comments related to adequacy of the EIR analyses and differences of opinion about
conclusions.

Final EIR
5-103
September 2015

Final EIR
5-104
September 2015
Adjudicated Seaside
Groundwater Basin Boundary
Adjudicated Basin Boundary
Subarea Boundary
Seaside Area Subbasin of
Salinas Valley Goundwater
Basin (DWR Bulletin 118)
Seaside Basin Boundary
per Monterey Peninsula
IRWMP
Seaside Groundwater Basin Boundaries

This figure has been revised in response to comment N-6.
September 2015
Figure

Final EIR
2-3 rev
2,000
Legend
-4
0
Scale in Feet
Shallow Zone Water Elevation Contour (feet MSL)

GWR Project Location
Basin Subarea Boundary
N
"
0
Legend
Legend
-20
Scale in Feet
Shallow
Zone
Water
Elevation
Contour
(feet
MSL)
Deep
Zone
Water
Elevation
Contour
(feet
MSL)
Deep
Zone
Paso
Robles
Water
Elevation
Contour
(feet MSL)
Legend
-40
0
0
20
GWR
Project
Location
GWR
Project
Location
of Injection Wells
GWR
Project
Location
Basin
Subarea
Boundary
Basin
Subarea
Boundary
Basin
Subarea
Boundary
20
Deep Zone Water Elevation Contour (feet MSL)

Basin Subarea
Boundary
April 2014
Figure 5
Santa2Margarita
0
Water Levels
July/August 2013
-40
60
20
2,000
Scale in Feet
-10
40
"N
-10
2,000
-2
N40
"
-2
April 2014
Figure 5
Santa40 Margarita
Water Levels
July/August
2013
Figure
N 4
"
-40
April
Deep2014
Zone Water Elevation Contour (feet MSL)
Paso Robles
Proposed Project Injection Well Facilities
-4
-2
0
60
Legend
40
2,000
Figure
4
Scale in Feet
Paso Robles
Deep Zone Water Elevation Contour
(feet MSL)
Water
Levels
Proposed Project Injection WellJuly/August
Facilities
2013
40
20
April 2014
Legend
Water Levels
0
2,000
July/August
2013
-4
Scale in Feet
Legend
DeepZone
Zone
Water
Elevation
Contour
(feetContour
MSL) (feet MSL)
Deep
Santa
Margarita
Water
Elevation
Legend GWR
GWR
Project
Location
Project
Location
of Injection Wells
BasinSubarea
Subarea
Boundary
Basin
Boundary
-4
0

20
Basin Subarea
Boundary
April 2014
40
Legend
60
20

April 2014
60
40
20
Figure 5
Santa Margarita
Water Levels
July/August 2013
Santa Margarita
Water Levels
July/August 2013
Source: Todd Groundwater, April 2014
April 2014 Levels FigureFigure

Figure
5
5
Seaside Groundwater Basin Groundwater
Santa Margarita
Santa Margarita
Water
Levels
Santa
Margarita
Water
Levels
2-4
rev
July/August 2013
July/August 2013
April 2014
September 2015
60
40
60
40
Final EIR
Water Levels
July/August 2013
Source: Geoscience Support Services, 2013
Salinas Valley Groundwater Levels and Flow Directions

This figure was added in response to comment H-39.
September 2015

Final EIR
Figure
2-7a new
The pump station shown has been replaced with a new one that is shown on Figure 2-25a.
Source: Schaaf & Wheeler Consulting Civil Engineers, 2014
Blanco Drain Storm Drain Maintenance District

This figure has been revised in response to comment M-8.
September 2015
Figure
Final EIR
2-16 rev
PROPOSEO PROOUCT WATER CONVEYAHa; PI>EL,IIIE

IJHOE.RG.ROUNO LCTRJCA1. COHOUITS
BACKFlUSH PIPEU'iE TO BACKFlUSH 8ASIH
BAO<FLUSH 8ASIN (INClUDES FENCE)
INJECTION WELL CLUSTER ~JJDrN-4)
INJECTION wet L CLUSTER: (VZW-3/0r'N-31"
INJECTION WELL CLUSTER (VZW'JJOrN-2)
INJECTION WElL CLUSTER (VZW-11DPN 1)
ACCESS ROAD
ACCESS ROAD TO CWR MONrTORINO WELL SrTt:S

GWR MOHITORlNG WEUS
MONJTORWG WEU SrTE lOCATIONS ME .AWROJUMATE A.~OSVBJECT TO

/!4PW;OV~>J.. 8Y JH STAT WATER RESOURCE:$ CONTROl &OAAO DMSIONOf
OfUNKIi WATER A.~O THE CITY OF $EASWE, M0N f()l'lr) WEU$ WCLWE NO
PEIU.tANEN'l ASOVI;oGROLINO COMPONENTS; EACH SUE WOULD ~SISl Of AH UP
lO TWO At GRADE., w.MfQLE 00\l'l;lRS ANOWOIJU) BE lOCATED TO ,...IUIZE
tuPACTi TO F\11\IRE 04i\l'l0P:UEN1 _.. (X)NSlA.TATlON YtiDI TIE aTY
Of SASIIlE.
..... ttte &OUNONff Of Tttf SUIV"AU MU.SINCt.lOfDWfnffl THf NV!AOf

POTENTlAL EFFECTS mD PROJECT IMPACT MEA THIS U~ BO'JM)SALL ~FACE
ARfAS TltAT MAY8 MfECTEO 8Y Tl1 PRO.ECT,INCL.UOING TIE PERMANENT,

T'EMPORAAY ~ON. EOOIPMENfiW.TEAW. STOCKPtl.fi..M'O $TAGI'i
AA:t.:AS. <H.Y I"HOSE FACti.Ill!;:$ $~ AHO l.A$1;1.9) WIIHN THIS NlD. 'lt'OI.A.D
DE ~M'HT NEW PHYSICAL FEAl\IRS. A MA.I()RJfV Of niE SII'E WOUlD
REMAIN IN ITS
FOI.~
~S:ENl COfiCitiOH OR
Agure
BE RESTORED TO ffS PRI:-SENf CQNDIUON
PROPOSED PROJECT CONSTRUCTIOH,
2 32 ID
Cumulative Project List
Tembladero Slough
Diversion
3 MILES
NORTH 4
Monterey County
1. CalAm Monterey Peninsula Water Supply Project
2. Salinas Valley Water Project Phase 2
3. East Garrison Specific Plan
4. DeepWater Desal
5. Interlake Tunnel
6. Laguna Seca Villas Harper Canyon
7. Corral De Tierra Road
8. Ferrini Ranch Subdivision
(
!
City of Sand City

9. Monterey Bay Shores Resort
City of Marina
10. The Dunes on Monterey Bay
11. Marina Airport
12. Marina Station: Armstrong Ranch
13. Rockrose Gardens
14. Cypress Knolls Senior Residential Project
15. Marina Heights
16. North Campus Housing Master Plan
17. ITCD Academic Building
18. Regional Urban Water Augmentation Project Desalination
19. Regional Urban Water Augmentation Project Recycled Water
20. Slant Test Well Project
Treatment Facilities
at the Regional
Treatment Plant
(
!
B AY
20
pt
p
ne O
eli
p
i
P
AP
W
19 RU
n
t io
ip e
lin
e
(
!
Reclamation Ditch
Diversion
(2
!
Co
as
ta
10
!
(
City of Pacific Grove

32. Local Water Project
33. Monterey-Pacific Grove Area of Special Biological Significance Stormwater Management Project
!!
(
(
1415
16
!
(
17
(
!
35
!
(
City of Salinas
34. City of Salinas Solar Project
Other Projects
35. Fort Ord Dunes State Park Campground
18
(
!
lP
MO
N
City of Monterey
30. 459 Alvarado Street
31. 480 Cannery Row
Blanco Drain
Diversion
12
!
(
i on
T ER
EY
City of Seaside
21. West Broadway Urban Village Specific Plan
22. Seaside Resort
23. 90-Inch Bay Avenue Outfall Phase 1
24. Monterey Downs and Horse Park and Central Coast Veterans Cemetery Specific Plan
25. Del Monte Blvd Dry Weather Diversion
26. West Broadway Stormwater Retention
27. Seaside Groundwater Basin Aquifer Storage and Recovery Phase 1
28. Seaside Groundwater Basin Aquifer Storage and Recovery Phase 2
29. Dredge Laguna Grande and Roberts Lake
!1
(
Coastal Booster
Pump Station Option
13
(
!
RUWAP Booster
Pump Station Option
11
!
(
Salinas Treatment
Facility
34
(
!
!3
(
24
!
(
32
!
(
!9
(
33
!
(
31
(
!
30
!
(
Monterey P ip el i n
23
!
(
25
(
!
26
21!
(
(
!
29
(
!
22
(
!
28
!
(
27
(
!
Tr ansfer Pipeline
Injection Well
Facilities
!8!
(
(6
Lake El Estero
Diversion
68
Laguna Seca Villas Project

no longer being pursued.
!6
(
(
!
7
Source: DD&A, 2014
Cumulative
Projects Location Map
This figure has been revised in response to comments R-1 and R-2.
September 2015
Salinas Pump
Station
(
!
New cumulative
project
APPROX. 80 MILES
SOUTHEAST
!5
(
Cumulative Projects
Proposed Project Components

0
Existing Project Facilities

1.75
3.5 MILES
Figure

Final EIR
4.1-1
rev
LOBO Sampling
Station L01
ho
lk
rn
Sloug h
Inlet
Moss
Landing
Harbor
M
or
o
h
ug
C o j o S lo
Ri e
v
h
rC
a nn
el
Potrera Road
Tide Gate
as
Te mblad
Slo
gh
ld
in
o
er
l
Sa
Proposed Tembladero
Slough Diversion
Salinas Lagoon
Gate
Sa
To Reclamation
Ditch
0.375
0.75
1.5 Miles
li n
as
R iv
er
Source: USGS, 2015
Surface Water Features in Northern Salinas Valley Tributary to Lower Elkhorn Slough
This figure has been added to the EIR to clarify the hydrologic and terrestrial biological resources analyses related to surface waters in
response to letters F and G.
September 2015

Final EIR
Figure
4.5-3
new
Legend
Proposed Project Location 2014
N
"
0
4,000
Adjudicated Basin Boundary
Northern Coastal
Subarea
Seaside Basin Well
Scale in Feet
Proposed Project Location

Southern
Coastal
Subarea
Seaside
Groundwater Basin
Laguna Seca
Subarea
Seaside Groundwater Basin
September 2015
Northern Inland
Subarea
Source: Todd Groundwater, 2015a

August 2015
Figure 1
Figure
Proposed Project
4.10-5
Seaside
Pure Water Monterey GWR ProjectGroundwater Basi
Final EIR
rev
Legend
Historic Seawater Intrusion Map
Historic Seawater Intrusion Map
Pressure 180 Foot Aquifer - 500 mg/L Chloride Areas
Pressure 400 Foot Aquifer - 500 mg/L Chloride Areas
Seawater Intrusion Levels by Year
Salinas Valley Groundwater Basin Seawater Intrusion

This figure has been revised in response to comment H-40.
September 2015
Figure

Final EIR
2-7 rev
FO-07 Shallow
ASR 4
ASR 3
400
Blv
Reservoir Well
SMS-Deep
d.
SMS-Shallow
ly
Rd
l J
im
Mo
M ilita ry Av e.
a
uc
s
tu
MRWPCA
MW-1
or e
Scale in Feet
A'
FO-07 Deep
PRTIW
Ge
ne
ra
Paralta
ASR-2
ASR MW-1
ASR-1
MMP
#
*
Ord Grove Test

Ord Grove
VZW-3
L a S a lle Av e.
San Pablo A
ve
GWR MW-6
VZW-2
#
*
W
X
DIW-1
Legend
Cross Section A - A' (See Figure 2-33)
GWR MW-1
#
*
W
X
Proposed GWR Deep Injection Well
X
W
#
*
DIW-2
Proposed GWR Vadose Zone Well

Proposed GWR Monitoring Well*
Proposed Project Location
#
* GWR MW-5
W DIW-3
X
Seaside Basin Production Well

Seaside Basin Monitoring Well
*Monitoring well locations shown are approximate and monitoring wells and appurtenances
would be located to minimize impacts in consultation with the City of Seaside.
VZW-4
W
#X
*
VZW-1
#
* GWR MW-2
DIW-4
GWR MW-3
Source: Todd Groundwater, 2015a
Proposed
Injection Wells and Existing Vicinity Wells
Seaside 4
Figure
GWR MW-4
This figure has been revised in response to comment L-25.
September 2015

Final EIR
4.10-7 rev
~.
'
-z.
....
t.
.,. t.
.L
...
.,.
-<.
---
!
~'!
.\
~ J
\
\
I! !
=''
Detailed Map of CSIP Area Wells and System Components

This figure has been revised in response to comments H-39 and H-40.
September 2015
Figure
4.10-9a
new
_____LI=---1

Final EIR
2.5 mi 0
1.25
1.25
2.5 mi
Seaside Groundwater Basin Seaside Groundwater Basin
2.5 km
Existing MCWD Sphere of Influence

ExistingBoundary
MCWD Sphere of Influence Boundary
Existing
Service Area
MCWD Existing LAFCO District
Area Existing
(Water &LAFCO
Wastewater)
MCWD
DistrictMCWD
Area (Water
& LAFCO
Wastewater)
2011) Area (Proposed 2013)

2011
Seaside
School2013)
Annexation
Seaside High School Annexation
AreaHigh
(Proposed
Ord Development
and MCWD
(Proposed 2013)
2011
Ord Development Areas and MCWD
AnnexationAreas
(Proposed
2013)Annexation
2011)
Fort Ord Boundary
Fort Ord Boundary

0
1.25
1.25
2.5 mi
Seaside Groundwater Basin
2.5 km
Existing MCWD Sphere of Influence Boundary

MCWD Existing LAFCO District Area (Water & Wastewater)
Seaside High School Annexation Area (Proposed 2013)
Ord Development Areas and MCWD Annexation (Proposed 2
All Boundaries
All Boundaries.mxd
ar k
F or
tO
F or
tO
rd D
rd D
une
s
une
s
Sta
Sta
te P
te P
ar k
ar k
Fort Ord Boundary
te P
BLM Field Office
F or
tO
rd D
une
s
Sta
BLM Field Office
BLM Field Office
^
Marina Coast Water District Boundaries and Service Areas
Monterey | San Jose
TheDate:
legend of5/6/2013
this figure has been revised due to receipt of new information.
Scale: 1 inch2015
= 1.53 miles
September
Project:
2012-44
Denise Duffy and Associates, Inc.
Figure

Environmental Consultants
Resource Planners
Final EIR
Monterey, CA 93940
(831) 373-4341
Figure
4.18-1
rev
CHAPTER 6
6.1
REFERENCES AND PERSONS CONTACTED
SOURCES CITED
Anderson, D., Burkholder, J., Cochlan, W., Gilbert, P., Gobler, C., Heil, C., Kudela, R., Parsons, M.,
Rensel, J., Townsend, D., Trainer, V., Vargo, G., 2008. Harmful algal blooms and eutrophication:
Examining linkages from selected coastal regions of the United States. Harmful Algae 8, 39-53.
Arcadis, et al, 2015. Final Interim Remedial Action Completion Report Volume 1 Interim Remedial
Action Field Activities and Results, Interim Action Ranges Munitions Response Area Phase II,
Former Fort Ord Monterey County, California. January 30.
Bottoms, Thomas G., Timothy K. Hartz, Michael D. Cahn, Barry F. Farrara, 2013. Crop and Soil Nitrogen
Dynamics in Annual Strawberry Production in California 48:1034-1039.
California Regional Water Quality Control Board Central Coast Region (RWQCB), 2013. Total Maximum
Daily Loads for Nitrogen Compounds and Orthophosphate for the Lower Salinas River and
Reclamation Canal Basin, and the Moro Cojo Slough Subwatershed, Monterey County,
California.
Cahn, Michael, Richard Smith, T. K. Hartz. 2013. Determining the Fertilizer Value of Ambient Nitrogen in
Irrigation Water. California Department of Food and Agriculture Fertilizer Research and Education
Program.
California Department of Fish and Game, 2012. Critical Riffle Analysis for Fish Passage in California.
California Department of Fish and Game Instream Flow Program Standard Operating Procedure
DFG-IFP-001. 24 p. Available at: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=57462
California Department of Fish and Wildlife (CDFW), 2013. Standard Operating Procedure for Critical Riffle
Analysis for Fish Passage in California. DFG-IFG-001. October 2012, updated February 2013.
California Department of Food and Agriculture, Fertilizer Research and Education Program, 2014. Annual
Report: January 1- December 31, 2013.
Caron, David A, Marie-Eve Garneau, Erica Seubert, Meredith D.A. Howard, Lindsay Darjany, Astrid
Schnetzer, Ivona Cetinic, Gerry Filteau, Phil Lauri, Burton Jones, Shane Trussell, 2010. Harmful
algae and their potential impacts on desalination operations off southern California. Elsevier,
Water Research 44, pp 385-416.
Casagrande, J. & Watson, F., 2006. Reclamation Ditch Watershed Assessment and Management
Strategy: Part A - Watershed Assessment. Monterey County Water Resources Agency and The
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http://www.mcwra.co.monterey.ca.us/documents/documents/Final_Rec_Ditch_Report.pdf
CEQAnet, 2015. Monterey Peninsula Groundwater Replenishment (Pure Water Monterey) Project,
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Coats, J.R., 1991. Pesticide Degradation Mechanisms and Environmental Activation. L. Somasundaram
and J.R. Coats (editors). Pesticide Transformation Products: Fate and Significance in the
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Cole, Gerald, 2015. Supplemental Memorandum: MRWPCA GWR Project AWT Product Water
Conveyance Facilities. Response to City of Seaside EIR Review Comment L-16.
Elkhorn Slough Tidal Wetland Project Team, 2007. Elkhorn Slough Tidal Wetland Strategic Plan. A report
describing Elkhorn Sloughs estuarine habitats, main impacts, and broad conservation and
restoration recommendations. 100 pp. Available at:
http://library.elkhornslough.org/twp/ESTWP/ESTWP_PLAN_050207_hres.pdf.
Final EIR
6-1
September 2015
Chapter 6. References and Persons Contacted
EPA (U.S. Environmental Protection Agency), 1986 (revised 2005). Test Methods for Evaluating Solid
Waste (SW-846): Physical/Chemical Methods: Office of Solid Waste: EPA 530-f-05-002.
Available at: http://www.epa.gov/waste/hazard/testmethods/sw846/index.htm
__________, 2015a. SW-846. Available at:
http://www.epa.gov/solidwaste/hazard/testmethods/sw846/online/8_series.htm
__________,2015b. Wastes Hazardous Wastes Test methods. Available at:
http://www.epa.gov/osw/hazard/testmethods/sw846/
__________, 2015c. Wastes Hazardous Wastes Test methods: Validated Methods. Available at:
http://www.epa.gov/osw/hazard/testmethods/pdfs/8330b.pdf
__________, 2015d. Fort Ord. Available at:
http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/ViewByEPAID/CA7210020676
ESA-PWA, 2014, Analysis of Historic and Future Coastal Erosion with Sea Level Rise
memorandum, Monterey Peninsula Water Supply Project: dated March 19.
Fishbio, 2014. Salinas Basin Juvenile O. mykiss Downstream Migration Monitoring 2014 Annual Report
Final.
Fort Ord BRAC Office, 2014. Fort Ord Environmental Cleanup 2013 Annual Report. Available at:
http://docs.fortordcleanup.com/ar_pdfs/factsheets/0205/Annual%20Report%20for%202013/2013%20Fort%20Ord%20Annual%20Report%20FS0205%2028JUL14.pdf
Fort Ord Cleanup. 2011. Understanding Soil gas at Former Fort Ord. Available at:
http://docs.fortordcleanup.com/ar_pdfs/factsheets/03-07/
Fort Ord Cleanup, 2014. Fort Ord Cleanup fact Sheet: Identification and Cleanup of Soil at Site 39, Inland
Ranges. Available at: http://docs.fortordcleanup.com/ar_pdfs/factsheets/03-06/
Fort Ord Cleanup, 2015. Groundwater. Available at: http://fortordcleanup.com/programs/groundwater/
Fugro West, Inc. (Fugro), 1997. Hydrogeologic Assessment, Seaside Coastal Groundwater Subareas,
Phase III Update, Monterey County, California. Prepared for Monterey Peninsula Water
Management District, September 1997.
Geoscience, 2015. Monterey Peninsula Water Supply Project Groundwater Modeling and Analysis. Draft
dated April 17, 2015.
Geoscience. 2015. Technical Memorandum: Monterey Peninsula Water Supply Project Baseline Water
and Total Dissolved Solids Levels Test Slant Well Area. April 20, 2015.
HDR Engineering, January 2015. Draft Salinas River Steelhead Habitat and Passage Effects Assessment
Technical Memorandum. Prepared for Denise Duffy & Associates. [See Draft EIR Appendix F]
HLA (Harding Lawson Associates), 1995. Basewide Remedial Investigation/Feasibility Study, Fort Ord,
California, Volume II Remedial Investigation. 4787 p. Available at:
http://fortordcleanup.com/reference-documents/basewide/
Hodge A, Robinson D, Fitter A. 2000. Are microorganisms more effective than plants at competing for
nitrogen? Trends in Plant Science 5: 304308. Available at:
http://www.ncbi.nlm.nih.gov/pubmed/10871903
Horner, R., Garrison, D., Plumley, G., 1997. Harmful algal blooms and red tide problems on the U.S. west
coast. Limnology and Oceanography 42(5): 1076-1088.
Inman J, Malik A, Missaghian J, Neill C, Noble S, Duffy D./California State University Monterey Bay Class
ENVS 660., 2014. Spatial and temporal variations in streamflow and water quality the
Reclamation Ditch and Tembladero Slough, Monterey County, California. The Watershed
Institute, California State University Monterey Bay, Publication No. WI-2014-14.

Final EIR
6-2
September 2015
Kudela, R., Lane, J., Cochlan, W., 2008. The potential role of anthropogenically derived nitrogen in the
growth of harmful algae in California, USA. Harmful Algae 8: 103-110.
LFR and Weston, 2011. Technical Information Paper, Phase II Seaside Munitions Response Area
Outside Roadway Alignment and Utility Corridor (Pollution Report and Removal Action Activity
Report), Former Fort Ord, Monterey County, California. Report prepared for Fort Ord Reuse
Authority, Marina, California.
Marina Coast Water District (MCWD), 1996. MCWD Annexation Agreement and Groundwater Mitigation
Framework for Marina Area Lands.
Marina Coast Water District/Denise Duffy & Associates, Inc. 2007. Regional Urban Water Augmentation
Project Final Environmental Impact Report, Addendum 1 and Addendum 2. June 2004, October
2005, and February 2007.
Marina Coast Water District (MCWD), 2011. 2010 Urban Water Management Plan
MCWD, 2015. Marina Coast Water District Website. Available at: www.mcwd.org
Marshack, J. 2011 and 2014. A Compilation of Water Quality Goals. Available at:
http://www.waterboards.ca.gov/water_issues/programs/water_quality_goals/
Monterey County Water Resources Agency/Cardno-Entrix. 2013. Salinas River Stream Maintenance
Program Draft EIR. Prepared for by Cardno-Entrix, Concord, CA. March 2013
Monterey County Water Resources Agency and Santa Clara Valley Water District, 2014. Using the Nitrate
Present in Soil and Water in Your Fertilizer Calculations.
Monterey County Water Resources Agency (MCWRA), 1994. Ordinance No. 3790.
__________, 2001. Salinas Valley Water Project, Website. Available at:
http://www.mcwra.co.monterey.ca.us/salinas_valley_water_project_I/salinas_valley_water_projec
t_I.php
__________, 2001. Salinas Valley Water Project EIR/EIS (SCH# 97-121020), June 2001. Available at:
http://www.mcwra.co.monterey.ca.us/salinas_valley_water_project_I/documents/Final%20EIREIS%20SVWP_RTC-Vol%201.pdf
__________, 2005. Salinas Valley Water Project Flow Prescription for Steelhead Trout in the Salinas
River. r, October 11.
__________, 2011a. Salinas Valley Water Project Annual Fisheries Report for 2010. Online at:
http://www.mcwra.co.monterey.ca.us/Agency_data/Fish_Monitoring/2010%20Salinas%20Basin%
20Rotary%20Screw%20Trap.pdf April
__________, 2011b. Salinas Valley Water Project Annual Flow Monitoring Report Water Year 2010.
Online at:
http://www.mcwra.co.monterey.ca.us/Agency_data/SVWP%20Annual%20Flow%20Reports/2010
%20Salinas%20Valley%20Water%20Project%20Annual%20Flow%20Monitoring%20Report.pdf,
July
__________, April 2012. Salinas Valley Water Project Annual Fisheries Report for 2011. Online at:
http://www.mcwra.co.monterey.ca.us/Agency_data/Fish_Monitoring/2011%20Annual%20Fisherie
s%20Report%20with%20Appendices.pdf
__________, April 2013. Salinas Valley Water Project Annual Fisheries Report for 2012. Online at:
http://www.mcwra.co.monterey.ca.us/Agency_data/Fish_Monitoring/2012%20Annual%20Fisherie
s%20Report%20with%20Appendices.pdf
__________, 2014. Floodplain Management Plan Monterey County 2014 Update.
__________, 2014a. Salinas Valley Water Project Annual Fisheries Report for 2013. Online at:
http://www.mcwra.co.monterey.ca.us/Agency_data/Fish_Monitoring/2013%20Fisheries%20Repor
t%20Final.pdf May

Final EIR
6-3
September 2015
__________, 2014b. Salinas Valley Water Project Annual Fisheries Report for 2014: Salinas Basin
Juvenile O. mykiss Downstream Migration Monitoring 2014 Annual Report - Final. Online at:
http://www.mcwra.co.monterey.ca.us/fish_monitoring/documents/2014_2%20Salinas%20Basin%
20Juvenile%20O.%20mykiss%20Downstream%20Migration%20Monitoring.pdf June
__________, 2015. JH: A032263 Water Rights Application 32263A-E for Monterey County Water
Resources Agency, July 29, 2015.
Monterey Peninsula Water Management District (MPWMD), 2014. Receipt of Los Padres Dam and
Reservoir Long-Term Strategic and Short-Term Tactical Plan.
Monterey Peninsula Water Management District/Denise Duffy & Associates, Inc., 2014. Monterey
Peninsula, Carmel Bay, and South Monterey Bay Integrated Regional Water Management Plan.
June 2014.
Monterey Regional Water Pollution Control Agency (MRWPCA), 2013. Sewer System Management Plan.
Section IV: Operation and Maintenance Program.
Montgomery Watson, 1997. Salinas Valley Historical Benefits Analysis.
National Oceanic and Atmospheric Administration, National Marine Fisheries Service (NMFS), 2005.
Endangered and Threatened Species; Designation of Critical Habitat for Seven Evolutionarily
Significant Units of Pacific Salmon and Steelhead in California. Federal Register 70: 5248852627.
__________, 2007. Biological Opinion for the Salinas River Diversion Facility. NOAA, National Marine
Fisheries Service's, Southwest Region, Long Beach, California, June 21, 2007.
National Research Council, 2012. Sea-Level Rise for the Coasts of California, Oregon, and Washington:
Past, Present, and Future. Prepublication. National Academy Press: Washington, D.C.
Nicol C, Brandt W, Clifton S, Nishijima D, Osiadacz M, Paddock E, Pristel V, Watson F., 2010. Spatiotemporal dynamics of salinity in the Old Salinas River and Tembladero Slough, Castroville,
California. The Watershed Institute, California State University, Monterey Bay. Available at:
http://ccows.csumb.edu/pubs/reports/CSUMB_ENVS660_ClassReport_TembladeroSlough_1103
09.pdf
OEHAA (Office of Environmental Health Hazard Assessment), 2015. Water. Available at:
http://www.oehha.ca.gov/water/phg/index.html
Pajaro Valley Water Management Agency, 2015. Distributor of Recycled Water Monitoring and Reporting
Program No. R3-2008-0039 Annual Report Cal. Yr. 2014.
Provin, T. L. and Hossner, L. R., 2001. What Happens to Nitrogen in Soils? Texas A&M Agrilife Extention
E-59: 6-01. Available at: http://soiltesting.tamu.edu/publications/E-59.pdf
Pueblo Water Resources, 2014. Summary of Operations, Monterey Peninsula ASR Project, Water Year
2013.
Rincn, L., Prez, A., Pellicer, C., Abada, A. and Sez, J. 2007. Nutrient Uptake by Artichoke. Acta
Hortic (ISHS) 730:287-292 Available at: http://dx.doi.org/10.17660/ActaHortic.2007.730.37
Rose, J.B., Farrah, S.R., Harwood, V.J., Levine, A.D., Lukasik, J., Menendez, P., Scott, T.M., 2004.
Reduction of Pathogens, Indicator Bacteria, and Alternative Indicators by Wastewater Treatment
and Reclamation Processes. Water Environment Research Foundation (WERF).
RWQCB. All references to citations with the acronym RWQCB can be found in this chapter underneath
the entry for California Regional Water Quality Control Board.
SPI, 2013. Evaluation of Seawater Desalination Projects Report Update. Prepared for the Monterey
Peninsula Regional Water Authority.

Final EIR
6-4
September 2015
State Water Resources Control Board, Water Quality Order No. 2003-0003-DWQ, Statewide General
Waste Discharge Requirements (WDRs) for Discharge to Land with a Low Threat to Water
Quality (General WDRs).
__________, 2014. Curtailment of Diversions due to Insufficient Flow for Specific Fisheries Emergency
Regulations Digest, May 13.
__________, 2014. Policy for Maintaining Instream Flow in Coastal Streams.
__________, 2015a. Environmental Laboratory Accreditation Program (ELAP). Available at:
http://www.waterboards.ca.gov/drinking_water/certlic/labs/index.shtml
__________, 2015b. Comparison of MCLs and PHGs for Regulated Contaminants in Drinking Water.
Available at:
http://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/MCLsandPHGs.shtml
Tetra Tech, 2015. Salinas River Watershed Area Salt Modeling. Prepared for Central Coast Regional
Water Quality Control Board and US Environmental Protection Agency, Region IX.
Thompson, K.E., 1972. Determining streamflows for fish life. Proceedings of the Instream Flow
Requirement Workshop, pp. 31-50. Pacific N.W. River Basins Commission. Portland, OR.
Todd Groundwater, 2015. Hydrologic Field Investigation: Monitoring Well Installation, Groundwater
Quality Characterization, and Geochemical Assessment: Report for Monterey Peninsula
Groundwater Replenishment (GWR) Project, 96 p., 14 figures and Appendix A-H.
University of California, Davis, United States Geological Survey, RWQCB. 2010. Watershed-scale
Evaluation of Agricultural BMP Effectiveness in Protecting Critical Coast Habitats: Final Report on
the Status of Three Central California Estuaries.
United States Department of the Army (US Army), 2008, Record of Decision Parker Flats Munitions
Response Area Track 2 Munitions Response Site Former Fort Ord, California Base Realignment
and Closure (BRAC) Former Fort Ord, California, June 24.
__________, 2011a. Fort Ord Superfund Site, 3rd Five-Year Review Fact Sheet. Available at:
http://docs.fortordcleanup.com/ar_pdfs/factsheets/02-03/
__________, 2011b. Understanding Soil Gas at Fort Ord: Fact Sheet FS-03-07. Available at:
http://fortordcleanup.com/factsheets/
__________, 2014. Fort Ord Administrative Record Fact Sheet. Available at:
http://docs.fortordcleanup.com/ar_pdfs/Factsheets/01-03/FINAL%20FS-0103%20Adminstrative%20Record%20v19SEP14%20with%20hyperlinks.pdf
__________, 2015. Fort Ord Cleanup. Available at:
http://fortordcleanup.com/about/cleanup-background/
http://fortordcleanup.com/about/environmental-setting/
http://fortordcleanup.com/documents/administrative-record/
http://fortordcleanup.com/factsheets/
U.S. Army Corps of Engineers, 2007. Final Second Five-Year Review Report, Fort Ord Superfund Site,
Monterey, California. Available at:
http://www.epa.gov/superfund/sites/fiveyear/f2007090001848.pdf
U.S. Army Corps of Engineers, 2012. Final 3rd Five-Year Review Report, Fort Ord Superfund Site,
Monterey, California. Available at: http://docs.fortordcleanup.com/ar_pdfs/ar-bw-2632/
U.S. Department of Labor, Occupational Safety and Health Administration, 2015. Hydrogen Sulfide.
Available at: https://www.osha.gov/SLTC/hydrogensulfide/hazards.html

Final EIR
6-5
September 2015
U.S. Fish and Wildlife Service (USFWS), 2006. Tidewater Goby Survey Protocol. Available at:
http://www.fws.gov/arcata/es/fish/goby/documents/USFWS%202006%20Tidewater%20Goby%20
Survey%20Protocol.pdf
USFWS, 2015. Tidewater Goby Species Profile. Available at:
http://www.fws.gov/arcata/es/fish/goby/goby.html
th
Western Plant Health Association, 9 Edition, 2002. Western Fertilizer Handbook. Interstate Publishers,
Inc.
6.2
PERSONS CONTACTED
Cooper, Douglass, Deputy Assistant Field Supervisor, North Coast Division, U.S. Fish and Wildlife
Service United States Fish and Wildlife Service, June 24, 2015.
Juarez, Shaunna, Associate Water Resources Engineer, Monterey County Water Resources Agency,
July and August 2015
Kocher, William, Interim General Manager, Marina Coast Water District, personal communication with
Andrew Sterbenz, August 2015.
Lockwood, Brian, Pajaro Valley Water Management Agency, September 2, 2015
Medina, Rick, Senior Planner, City of Seaside, September 8, 2015.
Novo, Mike, AICP, Planning Director, Monterey County Resource Management Agency, September 4,
2015.
Riedl, Rick, P.E., Associate Civil Engineer, City of Seaside, September 8, 2015.
Schubert, Bob, AICP, Senior Planner, Monterey County Resource Management Agency, September 9,
2015.

Final EIR
6-6
September 2015
CHAPTER 7
7.1
REPORT PREPARATION
LEAD AGENCY
7.2
Paul Sciuto, General Manager

Robert Holden, P.E., Principal Engineer/Project Manager
Mike McCullough, Government Affairs Administrator
Garrett Haertel, P.E., Compliance Engineer
James Dix, Wastewater Treatment Plant Operations Manager
Jennifer Gonzalez, P.E., Engineering Manager
PARTNER AGENCY
7.3
David Stoldt, General Manager

Larry Hampson, District Engineer
Joe Oliver, Water Resources Division Manager
Jonathan Lear, Senior Hydrologist
EIR CONSULTANTS
Prime Consultant: Denise Duffy and Associates, Inc.
Denise Duffy, Principal

Alison Imamura, AICP, Senior Project Manager
Diana Buhler, Deputy Project Manager
Erin Harwayne, AICP, Senior Planner/Scientist
Josh Harwayne, Senior Scientist
Matt Johnson, Associate Scientist
Jami Davis, Associate Scientist
Matt Kawashima, Assistant Planner
Shaelyn Hession, Assistant Scientist
Mary Echevarria, Contracts and Operations Manager
Robyn Simpson, Administrative Professional
DD&A Subconsultants
Archaeological Consulting
Gary S. Breschini, PhD, Principal Archaeologist
HDR, Inc.
William Snider, Senior Fish Biologist

Adrian Pitts, Fisheries and Aquatics Sciences Section Manager

Final EIR
7-1
September 2015
Chapter 7. Report Preparation
Illingworth and Rodkin, Inc.
Michael Thill, Principal Consultant, Noise Analyses

James Reyff, Principal Consultant, Air Quality/Greenhouse Gas Analyses
Ninyo and Moore
7.4
Peter Connolly, P.E., G.E., Geotechnical Engineer
LEAD AND PARTNER AGENCY CONSULTANT TEAM
Independent Consultants
Bahman Sheikh, Ph.D., P.E., Distinguished Fellow at Center for Integrated Water Research
at UCSC
Jerry Cole, P.E., BCEE, Pipeline Design Engineer
James Crook, Ph.D., P.E., Independent Consultant
E2 Consulting Engineers, Inc.
Loren Weinbrener, P.E., Engineer

Vinod Badani, Vice President
Hazen and Sawyer
Valerie Young, AICP, CEQA Program Manager
HydroMetrics WRI
Derrik Williams, P.G., C.H., President

Georgina King, P.G., C.H., Hydrologist
Stephen Hundt, Hydrologist
Nellor Environmental Associates, Inc
Margaret H. Nellor, P.E., President/Environmental Consultant: Water Quality
Perkins Coie
Barbara J. Schussman, Partner

Laura G. Zagar, Partner
Todd Groundwater
Phyllis Stanin, P.G., C.H., C.E.G., Vice President/Principal Geologist

Gus Yates, P.G., C.H.G., Senior Hydrologist
William Motzer, Ph.D., PG, CH, Senior Geochemist
Edwin Lin, P.G., C.H.G., Senior Hydrogeologist
Schaaf and Wheeler
Andrew Sterbenz, P.E., Project Engineer/Manager

Daniel Schaaf, P.E., Principal
Josh Tabije, Assistant Engineer
Andrew Racz, Junior Engineer

Final EIR
7-2
September 2015
Alex Wesner, P.E., Project Manager
Trussell Technologies
Gordon Williams, Ph.D., P.E., Principal Engineer

John Kenny, P.E., Engineer
Brie Webber, Associate Engineer

Final EIR
7-3
September 2015

Final EIR
7-4
September 2015
Appendices
to the
Pure Water Monterey
Groundwater Replenishment Project
Final Environmental Impact Report

Final EIR
September 2015

Final EIR
September 2015
Appendix B-Revised

Final EIR
September 2015

Final EIR
September 2015
Schaaf & Wheeler
3 Quail Run Circle, Suite 101

Salinas, CA 93907-2348
831-883-4848
FAX 831-758-6328
asterbenz@swsv.com
CONSULTING CIVIL ENGINEERS
MEMORANDUM
TO:
DATE:
March 26, 2015

Updated Sept. 23, 2015
CC:
Bob Holden, MRWPCA

Larry Hampson, MPWMD
Alison Imamura, Denise Duffy & Assoc.
FROM:
Andrew Sterbenz, PE
JOB #:
MRWP.01.14
SUBJECT:
Pure Water Monterey Groundwater Replenishment Project Proposed Source Water

Availability, Yield, and Use
The purpose of this memorandum is to summarize the source water availability and yield estimates for the
Pure Water Monterey Groundwater Replenishment Project (Proposed Project), to explain the seasonal
storage yield estimates, and to provide the proposed maximum and typical (or normal) water use
estimates for the Proposed Project. The Proposed Project will develop various source waters and convey
them to the MRWPCA Regional Treatment Plant (RTP) where they will undergo primary and secondary
treatment with the current municipal wastewater flows, and then undergo Advanced Water Treatment
before being conveyed for injection in the Seaside Groundwater Basin. Source waters conveyed to the
RTP which are not required for injection into the Seaside Basin will undergo tertiary treatment at the
Salinas Valley Reclamation Plant (SVRP) and be used to increase the recycled water supply provided to
the Castroville Seawater Intrusion Project (CSIP).
A number of technical documents were prepared to analyze and confirm available source supplies for the
Proposed Project. Source waters for the Proposed Project include new surface water diversions,
agricultural wash water, urban stormwater runoff and unused secondary-treated effluent from the RTP
which would otherwise be discharged to the ocean as further described, below. The source water
availability studies that have been used as the basis for estimating yield are cited throughout this report.
These reports and studies include:
1.
2.
3.
4.
Schaaf & Wheeler, Reclamation Ditch Yield Study, March 2015

Schaaf & Wheeler, Blanco Drain Yield Study, December 2014
Data on Source Water Estimates provided by Bob Holden, MRWPCA, February 2014
Todd Groundwater, Memorandum: Pure Water Monterey Groundwater Replenishment Project:
Impacts of Changes in Percolation at the Salinas Industrial Wastewater Treatment Facility on
Groundwater and the Salinas River, February 2015
5. Schaaf & Wheeler, Groundwater Replenishment Project, Salinas River Inflow Impacts, February
2015
6. Schaaf & Wheeler, Groundwater Replenishment Project, Urban Runoff Capture at Lake El
Estero, April 2014
7. Data from Monterey County Water Recycling Projects/Salinas Valley Water Project/Salinas
River Diversion Facility Update, MCWRA Board Packet, February 24, 2014
Among the Proposed Projects objectives is to provide high quality replacement water to allow California
American Water Company (CalAm) to extract 3,500 acre-feet per year (AFY) more water from the
To: Bob Holden & Larry Hampson
-2-
9/11/2015
Seaside Basin for delivery to its customers in the Monterey District service area and reduce Carmel River
system water use by an equivalent amount. To meet this objective, the Proposed Project would include
features that would create a reliable source of water supply by using source waters described below to
produce purified recycled water using existing secondary treatment processes and a new Advanced Water
Treatment (AWT) Facility at the MRWPCA Regional Treatment Plant. After treatment by the AWT
Facility, the purified recycled water would be conveyed to the Seaside Groundwater Basin for subsurface
injection using a series of shallow and deep wells. In the Seaside Groundwater Basin, the treated water
would mix with the groundwater present in the aquifers and be stored for future urban use. CalAm would
use existing wells and improved potable water supply distribution facilities to extract and distribute the
water produced by the Proposed Project, enabling CalAm to reduce its diversions from the Carmel River
system by this same amount.
Another purpose of the Proposed Project is to provide additional water to the Regional Treatment Plant
that could be recycled at the existing tertiary treatment facility (the Salinas Valley Reclamation Plant) and
used for crop irrigation using the CSIP system. The Salinas Valley Reclamation Plant produces tertiarytreated, disinfected recycled water for agricultural irrigation within the CSIP service area. Municipal
wastewater and certain urban dry weather runoff diversions treated at the Regional Treatment Plant are
currently the only sources of supply for the Salinas Valley Reclamation Plant. Municipal wastewater
flows have declined in recent years due to aggressive water conservation efforts by the MRWPCA
member entities. The new sources of water supply developed for the GWR Project would increase supply
available at the Regional Treatment Plant for use by the Salinas Valley Reclamation Plant during the peak
irrigation season (April to September). In addition, the Proposed Project would include Salinas Valley
Reclamation Plant modifications to allow tertiary treatment at lower daily production rates, facilitating
increased use of recycled water during the late fall, winter and early spring months when demand drops
below 5 million gallons per day (MGD).
Source waters for the Proposed Project include new surface water diversions, agricultural wash water,
urban stormwater runoff and unused secondary-treated effluent from the RTP which would otherwise be
discharged to the ocean.
Agricultural Wash Water
The City of Salinas owns and operates an industrial wastewater collection and treatment system, which
serves approximately 25 agricultural processing and related businesses located in the southeast corner of
the City. This wastewater collection system is separate from the Salinas municipal sewage collection
system. These flows, referred to as agricultural wash water, are conveyed in a network of gravity
pipelines to the Salinas Industrial Wastewater Treatment Facility (SIWTF), where it is treated using
aeration and disposed of using evaporation and percolation. These flows would be redirected into the
municipal wastewater system for conveyance to the RTP as a source of supply for the GWR Project.
Annual inflows to the SIWTF were analyzed and a projection of year 2017 flows was prepared by the
MRWPCA 1, as shown in the first row of Table 1, below. Recorded monthly inflows for calendar years
2007-2013 were tabulated and the annual averaged plotted (see Figure 1). A linear trend line was used to
estimate future flows, and the projected annual average of 3.37 mgd in 2017 was used to scale the 2013
monthly inflow values. As expected, the recorded agricultural wash water flows in 2014 (included on
Figure 1) fell on the trend line.
The SITWF consists of an aeration basin, three storage/percolation ponds covering 108 acres, drying beds
coving 67 acres and three rapid infiltration basins covering 1.3 acres. To assess the effects of diverting
Estimation by Bob Holden, MRWPCA, February 2014
Memo_Sources_and_Uses_20150923 rev
-3-
9/11/2015
flows treated at the SIWTF, Todd Groundwater 2 estimated the percentages of flows disposed as
evaporation, percolation from the main ponds, and disposal through the drying beds and rapid infiltration
basins (RIBs). These values are show in Table 1, below, and are used in the estimation of seasonal storage
losses discussed later in this memorandum. The State Water Resources Control Board has clarified that
this diversion will require a wastewater change petition for the SIWTF.
Table 1: Agricultural Wash Water (acre-feet)
Source \
Month
Ag. Wash
Water - 2017
Rainfall
Evaporation
Percolation
from ponds
1, 2, and 3
RIBs/Drying
Beds
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
156
26.4
-12
158
23.7
-16
201
21.3
-29
307
11.1
-41
311
3.0
-46
391
0.8
-52
435
0.2
-45
444
0.4
-43
-143
-129
-143
-138
-143
-138
-143
-28
-37
-51
-139
-125
-202
-247
Sep
Oct
Nov
Dec
Total
367
1.7
-32
410
5.7
-28
329
14.2
-15
223
23.7
-12
3,732
132
-372
-143
-138
-143
-138
-143
-1,680
-258
-198
-245
-190
-92
-1,812
Figure 1: Agricultural Wash Water Projection
Ag Wash Water (avg mgd)
SIWTF Inflows
4.00
3.50
3.00
2.50
2.00
1.50
1.00
2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
Year
Recorded Inflows
Flow in 2014
Projected Flow in 2017
Urban Stormwater Runoff

Urban stormwater runoff from two communities would be captured and used for the Proposed Project.
Stormwater and urban runoff from the southern portion of the City of Salinas is pumped to the Salinas
River (the rest of the City drains into the Reclamation Ditch system). Schaaf & Wheeler 3 estimated the
amount of stormwater flow which could be diverted to the municipal wastewater system or the SIWTF for
use in the Proposed Project. The estimated average annual yield is provided in Table 2, below.
Todd Groundwater, Memorandum: Pure Water Monterey Groundwater Replenishment Project: Impacts of
Changes in Percolation at the Salinas Industrial Wastewater Treatment Facility on Groundwater and the Salinas
River, February 2015
3 Schaaf & Wheeler, Groundwater Replenishment Project, Salinas River Inflow Impacts, February 2015
2
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9/11/2015
Stormwater and urban runoff from 2,400 acres within the City of Monterey flow to Lake El Estero, which
is maintained as part of El Estero Park. Excess stormwater is pumped to a discharge point on Del Monte
State Beach. Schaaf & Wheeler 4 estimated the amount of stormwater flow which could be diverted to the
municipal wastewater system for use in the Proposed Project. The estimated average annual yield is
provided in Table 2. Diverting from Lake El Estero will require a water rights permit.
Table 2: Urban Runoff Sources (acre-feet)
Source \ Month
South Salinas
Lake El Estero
Jan
52
24
Feb
41
15
Mar
34
14
Apr
16
5
May
2
1
Jun
0
0
Jul
0
0
Aug
0
0
Sep
2
1
Oct
8
4
Nov
23
10
Dec
47
13
Total
225
87
Surface Water Rights for Stream Flows

The Proposed Project would use three new surface water diversion sites to provide new source waters for
recycling. The first two are from the Reclamation Ditch system, which has a drainage area of 157 squaremiles. The Reclamation Ditch carries seasonal stormwater flows, urban runoff from the City of Salinas
and agricultural tile drainage flows. Diversion points are proposed on the Reclamation Ditch at Davis
Road, and on the Tembladero Slough at Castroville, based on the proximity of the channel to existing
wastewater conveyance facilities. Schaaf & Wheeler5 estimated the yield from this system, assuming a
maximum 6 cfs diversion rate at Davis Road, maximum 3 cfs diversion rate at Castroville, and leaving an
in-stream flow of 2 cfs at Davis Road in the winter, 0.7 cfs in the summer, and 1 cfs at Castroville yearround. The average annual yields from these diversions are shown in Table 3, below.
The third diversion is from the Blanco Drain, just above its confluence with the Salinas River. The
Blanco Drain conveys seasonal stormwater flows and agricultural tile drainage from 6,400 acres. Schaaf
& Wheeler 6 estimated the yield from this system, assuming a maximum diversion rate of 6 cfs, as shown
in Table 3.
All of these diversions would require water rights permits from the State Water Resources Control Board
(SWRCB), as would the Lake El Estero diversion discussed under Urban Stormwater Runoff.
Table 3: Surface Water Sources (acre-feet)
Source \ Month
Reclamation Ditch
Tembladero Slough
Blanco Drain
Jan
162
131
209
Feb
143
117
223
Mar
165
142
246
Apr
162
154
252
May
97
145
225
Jun
132
67
274
Jul
129
66
277
Aug
121
62
244
Sep
80
41
184
Oct
87
45
168
Nov
98
50
133
Dec
146
115
185
Total
1,522
1,135
2,620
Secondary Treated Effluent

Secondary treated municipal wastewater from the MRWPCA Regional Treatment Plant (RTP) is used as
influent to the Salinas Valley Reclamation Plant (SVRP), which produces recycled water for the CSIP.
Average recycled water production for the period 2009-2013 was 12,955 AFY. Average wastewater
inflow to the RTP during that period was 21,764 AFY. An average of 8,809 AFY of treated wastewater
in excess of what was delivered to the CSIP was discharged to the Monterey Bay through the
MRWPCAs ocean outfall. The average monthly inflows and outflows from the RTP are shown in Table
4, below.
Schaaf & Wheeler, Groundwater Replenishment Project, Urban Runoff Capture at Lake El Estero, April 2014
6 Schaaf & Wheeler, Blanco Drain Yield Study, December 2014
4
5
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9/11/2015
Table 4: Average RTP Inflows and Outflows, 2009-2013 7 (acre-feet)

Source/
Month
RTP
Inflows
SVRP
Deliveries
Ocean
Outfall
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Total
1,798
1,678
1,867
1,796
1,850
1,799
1,893
1,888
1,813
1,844
1,762
1,776
21,764
13
459
726
1,376
1,763
1,750
1,866
1,854
1,698
984
448
18
12,955
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809
The assumption that future CSIP recycled water demands would continue consistent with the recycled
water use in this time period is considered conservative, given that this period included one drought year
(2013) and that the Salinas River Diversion Facility (SRDF) operated for only four of the five years (the
SRDF was not placed into operation until the year 2010).
CSIP use of all water sources are shown in Table 5, below. Under current conditions, CSIP wells are
used to meet peak day demands that exceed the available recycled and river water supplies, and also to
meet small demands below the lower production limit of the SVRP. The CSIP groundwater use
conservatively includes one year when the SRDF didnt operate (similar to a multi-year drought condition
such as occurred in 2014 and 2015).
Table 5: Average CSIP Use by Source, 2009-2013 8 (acre-feet)
Source/
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Total
Month
CSIP448
195
304
412
324
606
519
504
300
75
233
352
4,271
Wells
SRDF0
0
0
100
561
819
886
739
266
56
0
0
3,427
River
SVRP5
483
733 1,383 1,738 1,748 1,843 1,853 1,698
984
452
18 12,939
Recycled
Note: The SVRP numerical difference between Tables 4 and 5 is due to rounding differences in the source reports.
Proposed Project and CSIP Demands

The Proposed Project goal is to produce 3,500 AFY of highly treated (or purified recycled) water for
injection in the Seaside Groundwater Basin to allow CalAm to extract the same amount for treatment and
distribution to their customers in their Monterey District service area. To produce that volume,
approximately 4,320 AFY of source water inflows are required at the AWT Facility. During wet or
normal water years, an additional 200 AFY may be produced and injected in the winter months to develop
a drought reserve. This would require an additional 248 AFY of source water. The monthly distribution
of this demand is shown in Table 6, below.
Source flows not required for the Proposed Project would be made available to create additional recycled
water for the CSIP. Table 6 includes an estimate of new source flows in excess of the AWT inflow needs,
assuming seasonal storage of agricultural wash water (discussed below), year-round diversion of surface
water, and AWT Facility demands for a normal year building a drought reserve.
Data provided by Bob Holden, MRWPCA, February 2014.

Data from MCWRA Monterey County Water Recycling Projects/Salinas Valley Water Project/Salinas River
Diversion Facility Update, February, 2014
7
8
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9/11/2015
The CSIP system distributes recycled water, Salinas River water and well water from the Salinas Valley
Groundwater Basin to agricultural irrigation demands in the northern Salinas Valley. Under existing
conditions, well water is used to meet peak summer demands in excess of the supply available from the
other sources, and also to meet low demands below the minimum production capacity of the SVRP
(currently 5 MGD). As part of the Proposed Project, the SVRP would be modified to meet recycled water
demands as low as 0.5 MGD. This modification would allow the MCWRA to reduce the use of the CSIP
wells, particularly in the winter months when secondary treated effluent is available. The average CSIP
well use for the period 2009-2013 9 is shown in Table 6. This provides a reasonable estimate of how
much additional recycled water could be used by CSIP in average year conditions.
Table 6: Monthly GWR and CSIP Use of New Supplies (acre-feet)
Use \ Month
Proposed Project
Demand
Drought Reserve
New Supplies in
excess of AWT 10
CSIP Wells Use
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
367
42
331
38
367
42
355
367
355
117
448
129
195
158
304
541
440
514
324
709
606
Total
367
367
355
367
42
355
41
367
42
4,320
248
540
476
504
504
320
300
0
76
0
233
50
354
3,582
4,260
Seasonal Storage at the SIWTF

To maximize the available supply during the peak irrigation months, the main ponds at the SIWTF would
be used for seasonal storage of agricultural wash water and Salinas urban stormwater. The analysis of
source water yield and proposed diversions assumes that during the months of October through March,
these flows would be directed to the SIWTF. In addition, for the source water assumptions, the use of the
drying beds and infiltration basins would be discontinued, so the only losses would be evaporation and
percolation from the main ponds. During the months of April through September, these flows would be
diverted to the municipal wastewater collection system for recycling and injection into the Seaside Basin
and tertiary treatment for CSIP. Stored water would also be pumped from the SIWTF ponds to the
municipal wastewater collection system.
Results of Source Water Availability Analysis
In the attached Table 7: Source Water Analysis, the existing inflows to the RTP are entered in the top line
under Sources. The monthly storage balance in the SIWTF ponds is calculated for a normal water year.
The inflow, rainfall, evaporation and percolation from Table 1 are shown in rows 1, 3, 4 and 5,
respectively. Urban Runoff from South Salinas is carried from Table 2 into line 2. Assuming the ponds
are empty at the start of October, they would remain wet for nine months a year, maintaining the
operational characteristics of the SIWTF and enabling continued contributions of seepage water to Salinas
River flows and recharge to the Salinas Valley Groundwater Basin 11. The net yield of agricultural wash
water and Salinas stormwater for the Proposed Project is shown on line 8. Other source flows from
Tables 2 and 3 are shown on lines 9 through 12, and the net new supply is shown on line 13. Under the
Demands heading are included the average SVRP deliveries to the CSIP and the average groundwater use
by the CSIP, as well as the AWT Facility feed-water demands. Line 21 shows the projected net supply to
Data from Monterey County Water Recycling Projects/Salinas Valley Water Project/Salinas River Diversion
Facility Update, MCWRA Board Packet, February 24, 2014
10 Excess supplies are calculated as the total of new water conveyed to the RTP (not including secondary
treated effluent) minus the AWT Facility demand
11 Full diversion of flows was analyzed in the report: Groundwater Replenishment Project, Salinas River
Inflow Impacts
9
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9/11/2015
the CSIP (sum of existing and augmented flows), and Line 26 shows the supply for the Proposed Project
while developing a drought reserve. Assuming the agencies divert all of the water shown on this table
(i..e, under an assumption that the Proposed Project would divert the maximum available source waters),
there would still be approximately 6,300 AFY of secondary-treated municipal wastewater discharged
through the ocean outfall (line 28) during normal rainfall years.
Diversion and Use Scenarios
The MRWPCA has a goal of reusing 100% of the secondary treated municipal effluent at the RTP (i.e.,
having no discharge to the ocean), and operating the system as efficiently as possible to reduce the energy
demand. Therefore, rather than divert all waters as described in the last section and in Table 7, the
Proposed Project would prioritize the use of secondary treated effluent above the diversion of surface
water sources, to the extent possible, which would minimize adverse environmental impacts and
maximize system efficiency. The proposed priority of source usage would be:
1.
2.
3.
4.
5.
6.
7.
Unused secondary treated effluent

Agricultural wash water
Salinas storm water
Reclamation Ditch
Blanco Drain
Tembladero Slough
Lake El Estero
In the attached scenario tables (Tables 8 through 10), the use of the various sources is reduced to just meet
the demands of the AWT Facility and offset the current CSIP groundwater use in the wet season (OCTMAR). During the dry season (APR-SEP), surface water diversions are shown meeting the monthly
AWT Facility demands and providing extra flow for the CSIP, such that the annual use of new sources
exceeds the annual AWT Facility demands. In practice, the surface water diversions could be reduced or
increased based on the actual CSIP system demands, up to the total yields shown in Table 7. The demand
scenarios considered are:
Table 8: A normal water year while developing a drought reserve (AWT Facility producing 3,700
AFY)
Table 9: A normal water year with a full drought reserve (AWT Facility producing 3,500 AFY)
Table 10: A drought year starting with a full reserve (AWT Facility producing 2,700 AFY)
In the normal year with a full reserve scenario, surface water diversions were only required from the
Reclamation Ditch and the Blanco Drain. Surface water diversions were only required between April and
October in both normal year scenarios.
In the drought year scenario, the stormwater and wastewater availability were reduced. Urban runoff
from Salinas was assumed to be one-third of the historic average. Rainfall on the SIWTF ponds used the
2013 rainfall record (critically dry year). The unused secondary treated effluent values from 2013 were
used, also the historic low. The CSIP groundwater well use from OCT 2013 to SEP 2014 was used as the
CSIP augmentation target. Under this scenario, surface water diversions were required from the
Reclamation Ditch, Blanco Drain and Tembladero Slough, and the diversions were needed from March
through November.
-8-
9/11/2015
References:
City of Salinas, Industrial Wastewater Treatment Facility, 2013 Annual Report, January 2014
Monterey County Water Resources Agency, Monterey County Water Recycling Projects/Salinas Valley
Water Project/Salinas River Diversion Facility Update, MCWRA Board Packet, February 24, 2014
Monterey County Water Resources Agency, Salinas Valley Water Project, Annual Flow Monitoring
Reports for Water Years 2010 2013.
Monterey County Water Resources Agency, Application to Appropriate Water, April 2014.
Monterey Peninsula Water Management District, Source Water Spreadsheet Analysis, March, 2015.
Monterey Peninsula Water Management District, Industrial Ponds Percolation and Evaporation
Technical Memorandum 2015-01, July 2015.
Schaaf & Wheeler, Groundwater Replenishment Project, Urban Runoff Capture at Lake El Estero, April
2014
Schaaf & Wheeler, Blanco Drain Yield Study, December 2014
Schaaf & Wheeler, Groundwater Replenishment Project, Salinas River Inflow Impacts, February 2015
Todd Groundwater, Memorandum: Pure Water Monterey Groundwater Replenishment Project: Impacts
of Changes in Percolation at the Salinas Industrial Wastewater Treatment Facility on Groundwater and
the Salinas River, February 2015
Table 7: Source Water Analysis for the Pure Water Monterey Groundwater Replenishment Project
Full Surface Water Yields, Normal Water Year, Building a Drought Reserve
All facilities built 1 - average water year conditions - all flows in acre-feet
SOURCES
Jan
Existing RTP Inflows (Average 2009 to 2013)
1,798
New Source Water
City of Salinas
2
1 Salinas Agricultural Wash Water
Agricultural Wash Water (AWW) to Ponds
AWW directly to RTP
4
2 Salinas Urban Storm Water Runoff
Urban runoff to ponds
Urban runoff to RTP
5
3 Rainfall (on SIWTF, 121 acre pond area)
6
4 Evaporation (from SIWTF, 121 acre pond area)
7
5 Percolation
8
6 SIWTF pond storage balance
7 Recovery of flow from SIWTF storage ponds to RTP
8 AWW and Salinas Runoff to RTP
Water Rights Applications to SWRCB
9
9 Blanco Drain
10
10 Reclamation Ditch at Davis Road
11
11 Tembladero Slough at Castroville
12 City of Monterey - Diversion at Lake El Estero
13 Subtotal New Waters Available
Total Projected Water Supply
Feb
1,678
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/14/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
(12)
(16)
(29)
(41)
(46)
(52)
14
24
132
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
0
0
435
0
0
444
0
0
369
(143)
(138)
(143)
(1,257)
253
0
0
466
0
0
605
0
0
304
2,579
209
223
246
252
225
274
277
244
162
143
165
162
97
132
129
121
184
168
133
185
2,620
80
87
98
146
131
24
526
117
15
498
142
14
567
154
5
928
145
1
881
67
0
1,036
66
0
907
1,522
62
0
871
41
1
675
45
4
304
50
10
291
115
13
459
1,135
87
7,943
2,324
2,176
2,434
2,724
2,731
2,835
2,800
2,759
2,488
2,147
2,053
2,235
29,707
DEMANDS
Average SVRP deliveries to CSIP (2009-2013)
14 FIVE YEAR AVERAGE CSIP AREA WELL WATER USE (2009-2013)
TOTAL CSIP Demand
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227
16 FEEDWATER AMOUNT AT RTP TO GWR PROJECT AWTF

17 FEEDWATER TO ESTABLISH CSIP AREA DROUGHT RESERVE
(200 AFY AWTF PRODUCT WATER) 14
18 TOTAL TO GWR ADVANCED WATER TREATMENT FACILITY
367
331
367
355
367
355
367
367
355
367
355
367
4,320
42
409
38
369
42
409
355
367
355
367
367
355
42
409
41
396
42
409
248
4,568
870
1,024
1,439
2,143
2,454
2,711
2,752
2,725
2,353
1,468
1,077
779
21,795
Total Projected Water Demand
Use of Source Water
Mar
Apr
Nov
Dec
461
0
461
654
0
654
1,030
0
1,030
1,788
573
2,361
1,850
514
2,364
1,799
681
2,480
1,893
540
2,433
1,888
504
2,392
1,813
320
2,133
1,059
0
1,059
681
0
681
370
0
370
15,287
3,132
18,419
5,463
Surface waters at RTP to AWT

Secondary effluent to AWT
AWW and Salinas urban runoff to AWT
Feedwater to AWT
409
0
0
409
369
0
0
369
409
0
0
409
0
0
355
355
0
0
367
367
0
0
355
355
0
0
367
367
0
0
367
367
0
0
355
355
304
105
0
409
291
105
0
396
409
0
0
409
2,191
210
2,166
4,567
Subtotal- all waters (including secondary effluent)
870
1,024
1,439
2,716
2,731
2,835
2,800
2,759
2,488
1,468
1,077
779
22,986
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809
1,337
1,024
837
679
976
1,407
6,267
117
78
129
70
158
78
573
67
514
70
681
67
540
70
504
70
320
67
(105)
78
(105)
75
50
78
3,375
868
12
19 Secondary effluent to SVRP for CSIP
13
20 New sources available to CSIP
21 Total Supply to CSIP
Net CSIP Increase
23
24
25
26
27 FIVE YEAR AVERAGE WASTE WATER EFFLUENT TO OCEAN OUTFALL

(2009-2013)15
28 WASTE WATER EFFLUENT TO OCEAN OUTFALL WITH PROPOSED
DIVERSIONS TO CSIP/AWT/RUWAP 16
29 NEW SUPPLIES IN EXCESS OF AWT DEMANDS 17
30 AWT BRINE TO OCEAN OUTFALL
Jan
Feb
May
June
July
Aug
Sep
Oct
Total
Notes
1 Presumes all facilities associated with diversions are completed.
2 Table 2-1, p. 5, Schaaf & Wheeler Consulting Engineers. Revised Draft, Groundwater Replenishment Project, Salinas River Inflow Impacts, Prepared for Denise Duffy & Associates, February 2015.
3 Volume of effluent from City of Salinas agricultural wash water to be directed into ponds 1,2,3, and the aeration pond for storage.
4 Average monthly flow from Revised Draft, Groundwater Replenishment Project, Salinas River Inflow Impacts, Prepared for Denise Duffy & Associates, February 2015.
5 Rainfall from Revised Draft, Groundwater Replenishment Project, Salinas River Inflow Impacts, Prepared for Denise Duffy & Associates, February 2015. Pond area presumed to be Ponds 1,2, 3 + Aeration lagoon.
No rainfall/evaporation or storage assigned to drying beds.
6 Table 3, Todd Groundwater, Draft Memorandum, Pure Water Monterey Groundwater Replenishment Project: Impacts of Changes in Percolation at the Salinas Industrial Wastewater Treatment Facility on
Groundwater and the Salinas River, February 11, 2015.
7 Table 4, Ibid. Also confirmed in MPWMD Industrial Ponds Percolation and Evaporation Technical Memorandum 2015-01, July 2015.
8 Ponds 1,2,3 and aeration basin hold up to 1,065 acre-feet (one foot of freeboard). If flow to ponds would exceed the maximum volume, it is presumed that excess flow can be diverted to the RIBs or drying beds
or flow can be diverted to the RTP. Presume that pond storage goes to zero sometime during the year (shown here starting in July).
9 Max diversion = 6 cfs diversion. See REVISED DRAFT BLANCO DRAIN YIELD STUDY, Schaaf and Wheeler, December 2014.
10 Max. diversion = 6 cfs. See REVISED DRAFT RECLAMATION DITCH YIELD STUDY, Schaaf and Wheeler, March 2015. Note that flow figures shown here are a combination of flow estimates in the S&W analysis made
for the 2 cfs instream requirement Jan-May and 1 cfs instream requirement for June-Dec.
11 Max. diversion = 3 cfs. See REVISED DRAFT RECLAMATION DITCH YIELD STUDY, Schaaf and Wheeler, March 2015. Figures shown here are the difference between the combined Davis Road/TS diverison with
Seasonal Bypass. This presumes the preference is to remove flow at Davis Road first, rather than bypass flow to Tembaldero Slough.
12 Unused secondary effluent waste water currently discharged to Monterey Bay would be used in conjunction with improvements at the RTP to provide additional flow to the Salinas Valley Reclamation Project
(SVRP) during periods of low demand (i.e., < 5 mgd).
13 New source waters not used by AWT in the summer months will be available to SVRP for CSIP.
14 A drought reserve of up to 1,000 AF would be created over five years by producing 200 AFY additional product water from the GWR Project AWTF during winter months and storing the water in the Seaside Basin.
This would establish a "water bank" that the CSIP can draw on in droughts. The drought reserve would allow flow at the RTP for the GWR Project to be temporarily reduced during critically dry periods, thus
freeing up more of the newly available inflows to the RTP to be sent to the CSIP area. Extraction from the Seaside Basin would continue at the average rate to supply the Monterey Peninsula.
15 Average monthly RTP discharge, 2009-2013 (reported by MRWPCA).
16 Secondary treated municpal effluent not used for SVRP/CSIP or the AWT.
17 Excess is calculated as Line 13 minus Line 23
CSIP-GWR-use16JUL15-No RUWAP.xlsx/DEIR Sources-No RUWAP
8/14/2015
Diversion Patterns for a Normal Water Year, Building a Drought Reserve
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5
6
7
5 Percolation
8
9
9 Blanco Drain
10
11
Feb
1,678
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/15/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
(12)
(16)
(29)
(41)
(46)
(52)
14
24
132
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
0
0
435
0
0
444
0
0
369
(143)
(138)
(143)
(1,257)
253
0
0
466
0
0
605
0
0
304
2,579
252
225
274
277
244
184
162
97
132
129
121
80
1,456
0
0
0
0
0
0
0
0
0
154
0
923
145
0
880
67
0
1,036
66
0
907
62
0
871
41
0
674
0
0
0
721
0
0
0
0
0
0
535
0
5,291
1,798
1,678
1,867
2,719
2,730
2,835
2,800
2,759
2,487
1,844
1,762
1,776
27,055
DEMANDS
TOTAL CSIP Demand
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227

367
331
367
355
367
355
367
367
355
367
355
367
4,320
42
409
38
369
42
409
355
367
355
367
367
355
42
409
41
396
42
409
248
4,568
870
1,024
1,439
2,143
2,454
2,711
2,752
2,725
2,353
1,468
1,077
779
21,795
Use of Source Water
Mar
Apr
Nov
Dec
461
0
461
654
0
654
1,030
0
1,030
1,788
568
2,356
1,850
513
2,363
1,799
681
2,480
1,893
540
2,433
1,888
504
2,392
1,813
319
2,132
1,059
0
1,059
681
0
681
370
0
370
15,287
3,125
18,412
5,456

Feedwater to AWT
0
409
0
409
0
369
0
369
0
409
0
409
0
0
355
355
0
0
367
367
0
0
355
355
0
0
367
367
0
0
367
367
0
0
355
355
0
409
0
409
0
396
0
396
0
409
0
409
0
2,401
2,166
4,567
870
1,024
1,439
2,711
2,730
2,835
2,800
2,759
2,487
1,468
1,077
779
22,979
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809
4,076
12
13
Net CSIP Increase
23
24
25
26

(2009-2013)15
Jan
Feb
928
655
428
(409)
78
(369)
70
(409)
78
May
June
July
Aug
Sep
568
67
513
70
681
67
540
70
504
70
319
67
Oct
375
685
998
(409)
78
(396)
75
(409)
78
Total
724
868
Notes
CSIP-GWR-use16JUL15-No RUWAP.xlsx/Normal_Building_No RUWAP
8/14/2015
Diversion Pattern for a Normal Water Year when the Drought Reserve is Full
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5
6
7
5 Percolation
8
9
9 Blanco Drain
10
11
Feb
1,678
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/15/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
(12)
(16)
(29)
(41)
(46)
(52)
14
24
132
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
0
0
435
0
0
444
0
0
369
(143)
(138)
(143)
(1,257)
253
0
0
466
0
0
605
0
0
304
2,579
252
225
274
277
244
184
162
97
132
129
121
80
1,456
0
0
0
0
0
0
0
0
0
0
0
769
0
0
735
0
0
969
0
0
841
0
0
809
0
0
633
0
0
0
721
0
0
0
0
0
0
0
0
4,756
1,798
1,678
1,867
2,565
2,585
2,768
2,734
2,697
2,446
1,844
1,762
1,776
26,520
DEMANDS
TOTAL CSIP Demand
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227

367
331
367
355
367
355
367
367
355
367
355
367
4,320
0
367
0
331
0
367
355
367
355
367
367
355
0
367
0
355
0
367
0
4,320
828
985
1,397
2,143
2,454
2,711
2,752
2,725
2,353
1,426
1,036
737
21,547
Use of Source Water
Mar
Apr
Nov
Dec
461
0
461
654
0
654
1,030
0
1,030
1,788
414
2,202
1,850
368
2,218
1,799
614
2,413
1,893
474
2,367
1,888
442
2,330
1,813
278
2,091
1,059
0
1,059
681
0
681
370
0
370
15,287
2,590
17,877
4,921

Feedwater to AWT
0
367
0
367
0
331
0
331
0
367
0
367
0
0
355
355
0
0
367
367
0
0
355
355
0
0
367
367
0
0
367
367
0
0
355
355
0
367
0
367
0
355
0
355
0
367
0
367
0
2,154
2,166
4,320
828
985
1,397
2,557
2,585
2,768
2,734
2,697
2,446
1,426
1,036
737
22,197
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809
417
726
1,040
4,323
(367)
70
(355)
67
12
13
Net CSIP Increase
23
24
25
26

(2009-2013)15
Jan
Feb
970
693
470
(367)
70
(331)
63
(367)
70
May
June
July
Aug
Sep
414
67
368
70
614
67
474
70
442
70
278
67
Oct
Total
(367)
70
436
821
Notes
CSIP-GWR-use16JUL15-No RUWAP.xlsx/Normal_Full_No RUWAP
8/14/2015
Diversion Pattern for a Drought Year Starting with a Full Reserve
SOURCES
Jan
Minimum Year RTP Inflows (2013)
1,725
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5
6
7
5 Percolation
8
9
9 Blanco Drain
Mar
1,645
Apr
1,657
May
1,722
June
1,675
July
1,748
Aug
1,773
Sep
1,715
Oct
1,690
158
201
307
311
391
435
444
367
410
329
223
3,732
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
17
17
0
14
14
0
11
11
0
5
0
5
1
0
1
0
0
0
0
0
0
0
0
0
1
0
1
3
3
0
8
8
0
16
16
0
76
69
7
11
(12)
(16)
(29)
(41)
(46)
(52)
36
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
550
0
0
584
0
0
628
0
0
452
0
312
163
100
412
(27)
0
391
0
0
435
0
0
444
0
0
368
(143)
(138)
(143)
(1,257)
245
0
0
433
0
0
521
0
0
100
2,362
246
252
225
274
277
244
165
162
97
132
129
121
184
168
133
2,003
80
87
98
0
0
0
0
0
0
142
0
553
154
0
880
145
0
879
67
0
864
66
0
907
1,071
62
0
871
41
0
673
45
0
300
50
0
281
0
0
0
772
0
6,208
1,725
1,494
2,198
2,537
2,601
2,539
2,655
2,644
2,388
1,990
1,915
1,612
26,297
Mar
1,558
221
1,779
Apr
1,669
242
1,911
May
1,799
1,197
2,996
June
1,675
1,261
2,936
July
1,786
1,303
3,089
Aug
1,803
1,025
2,828
Sep
1,725
453
2,178
Oct
1,548
165
1,713
Nov
1,127
35
1,162
Feb
692
9
701

367
331
367
133
137
133
137
137
133
367
0
367
0
331
0
367
133
137
133
137
137
133
876
1,032
2,146
2,044
3,133
3,069
3,226
2,965
2,311
Jan
Feb
May
June
July
Aug
Sep
Dec
88
730
818
Total
15,469
7,150
22,619
355
367
2,963
0
367
0
355
0
367
0
2,963
2,080
1,517
1,185
25,583
Mar
Apr
509
0
509
701
0
701
1,645
186
1,831
1,657
747
2,404
1,722
742
2,464
1,675
731
2,406
1,748
770
2,518
1,773
734
2,507
1,715
540
2,256
1,623
0
1,623
1,162
0
1,162
818
0
818
16,747
4,451
21,197
5,728

Feedwater to AWT
0
367
0
367
0
331
0
331
367
0
0
367
0
0
133
133
0
0
137
137
0
0
133
133
0
0
137
137
0
0
137
137
0
0
133
133
300
67
0
367
281
74
0
355
0
367
0
367
948
1,206
809
2,963
876
1,032
2,198
2,537
2,601
2,539
2,655
2,644
2,388
1,990
1,517
1,185
24,161
1,725
802
87
142
507
1,607
4,870
398
427
2,137
(67)
70
(74)
67
(367)
70
3,244
563
12
13
Net CSIP Increase
23
24
25
26
7/15/2015
Total
20,090
158
0
Jan
0
509
509
Use of Source Water
Dec
1,612
156
DEMANDS
Max Year SVRP deliveries to CSIP (2013)
14 PEAK CSIP AREA WELL WATER USE (10/2013-09/2014)
TOTAL CSIP Demand
Nov
1,634
156
0
10
11
Feb
1,494
Oct
Nov
Dec
Total
27 DRY YEAR WASTEWATER EFFLUENT TO OCEAN OUTFALL (2013) 15

849
462
(367)
70
(331)
63
186
70
747
25
742
26
731
25
770
26
734
26
540
25
Notes
4 Assume dry year at 1/3 the average monthly values from Revised Draft, Groundwater Replenishment Project, Salinas River Inflow Impacts, Prepared for Denise Duffy & Associates, February 2015.
15 Monthly RTP discharge during critically dry year (2013), reported by MRWPCA
CSIP-GWR-use16JUL15-No RUWAP.xlsx/Drought_FullResv_No RUWAP
8/14/2015
Appendix C-Revised

Final EIR
September 2015

Final EIR
September 2015
August 10, 2015

TO:
Bob Holden, MRWPCA
FROM:
Barbara Schussman, Laura Zagar and Anne Beaumont
RE:
Pure Water Monterey Groundwater Replenishment Project: Amended Water

Rights Analysis
Introduction
The Proposed Groundwater Replenishment Project (the Proposed Project) consists of two
components: the Pure Water Monterey Groundwater Replenishment improvements and
operations that will develop high-quality replacement water for existing urban supplies, and an
enhanced agricultural irrigation component.
The Proposed Project would recycle and reuse water from a number of sources, including:
A.
B.
C.
D.
Municipal wastewater,
Industrial wastewater (agricultural wash water),
Urban stormwater runoff, and
Surface water diversions.
Below is an analysis of each water source, including the legal framework and current status of
water rights for each source. A summary chart is included at the end.
A.
Municipal Wastewater Collection and Treatment System

1.
Brief Description of Project Use
The Monterey Regional Water Pollution Control Agency (MRWPCA) collects municipal
wastewater from communities in northern Monterey County and treats it at its Regional
Wastewater Treatment Plant (Regional Treatment Plant). Most of the wastewater is recycled for
crop irrigation at an onsite tertiary treatment plant called the Salinas Valley Reclamation Plant.
The tertiary-treated wastewater is delivered to growers through a conveyance and irrigation
system called the Castroville Seawater Intrusion Project. The treated wastewater that is not
recycled for crop irrigation is discharged to the ocean through MRWPCAs existing ocean
outfall. The Proposed Project would include improvements that would enable more of the
municipal wastewater to be recycled than is possible today; thus, less municipal wastewater
would be discharged through the ocean outfall.
2.
Legal Framework
Unless otherwise provided by agreement, the owner of a wastewater treatment plant has the
exclusive right to the treated wastewater it produces as against anyone who has supplied the
water discharged into the wastewater collection and treatment system, including a person using
water under a service contract. 1 MRWPCA therefore has the exclusive right to use municipal
wastewater that is discharged into its collection system, except as that right has been varied by
contractual arrangements. 2
Here, MRWPCA has entered into a number of relevant contracts, including contracts that
assigned rights to Marina Coast Water District and Monterey County Water Resources Agency
(Water Resources Agency). We understand MRWPCA has entered into the following:
The 1989 Annexation Agreement between MRWPCA and the Marina Coast Water
District provides the Marina Coast Water District with the right to obtain treated
wastewater from MRWPCA. The Marina Coast Water District has not exercised its
recycled water rights, but may do so in the future.
The 1992 agreement between MRWPCA and Water Resources Agency (including
amendments) (1992 Agreement) provides for the construction and operation of the
Salinas Valley Reclamation Plant by MRWPCA to provide water treated to a level
adequate for agricultural irrigation for use by the Castroville Seawater Intrusion Project.
In particular, Section 3.03 of the 1992 Agreement (Amendment 3) provides that
MRWPCA commits all of its incoming wastewater flows to the treatment plant from
sources within the 2001 MRWPCA service area, up to 29.6 million gallons per day,
except for flows taken by the Marina Coast Water District under the Annexation
Agreements, losses, flows not needed to meet the Water Resource Agencys authorized
demand, and flows to which MRWPCA is otherwise entitled under the agreement.
In 1996, pursuant to another Annexation Agreement, the Marina Coast Water District
received the right to tertiary-treated water from the Salinas Valley Reclamation Plant, in
satisfaction of the 1989 agreement rights.
In 2009, the Marina Coast Water District and MRWPCA entered into a Memorandum of
Understanding relating to the Regional Urban Water Augmentation Agreement (RUWAP
MOU). In the RUWAP MOU, the MRWPCA assigned a portion of its allotment from
the Amendment 3 of the 1992 Agreement between MRWPCA and Monterey County
Water Resources Agency. MRWPCA agreed to, among other things, provide 650 AFY of
Cal. Water Code 1210.

California Water Code 1211 requires the owner of a wastewater treatment plant to obtain approval of the State
Board for a change in the point of discharge of treated wastewater when the proposed change would result in
decreased flow in any portion of a watercourse. The proposed diversion of municipal wastewater from the Regional
Treatment Plant from communities in northern Monterey County would not impact the flows in a watercourse; thus,
approval from the State Board for this proposed diversion would not be needed.
-2-
recycled waters during the months of May through August each year from MRWPCA
entitlements. 3 Marina Coast Water District agreed to commit 300 AFY of recycled water
during the months of April through September from Marina Coast Water Districts
entitlements. Currently, Marina Coast Water District does not have approved funding,
water purchase/user agreements, or adequate physical distribution facilities to use the
recycled water; thus Marina Coast Water Districts water right to recycled water from the
RUWAP MOU have not been triggered.
To address certain water rights, the stakeholder agencies entered into a Memorandum of
Understanding (Source Waters MOU). The Source Waters MOU reaffirmed the Marina Coast
Water Districts and Water Resources Agencys recycled water entitlements, and presented a
proposal for collection of additional source waters to meet the Proposed Project objectives.
Importantly, the Source Waters MOU is intended to provide a framework for negotiation of a
Definitive Agreement and does not create a binding contractual obligation. The Definitive
Agreement would establish the contractual rights and obligations of the parties. To date, the
Definitive Agreement has not yet been completed. If a Definitive Agreement is reached, it would
be approved after the EIR is certified.
3.
Status of Water Rights
Because the Source Waters MOU is not binding, it is not sufficient to secure the water rights at
this time. Any outstanding water rights would need to be addressed and resolved in the
forthcoming Definitive Agreement. Until then, the existing agreements with the Marina Coast
Water District could impact the source water for the Proposed Project. Although the Definitive
Agreement is needed to secure certain water rights, the Source Waters MOU demonstrates a
reasonable likelihood that rights to that this source of water can be obtained from stakeholders
that send wastewater at the Regional Treatment Facility.
B.
Salinas Agricultural Wash Water System

1.
Water from the City of Salinas agricultural industries, 80% to 90% of which is water used for
washing produce, is currently conveyed to ponds at the Salinas Industrial Wastewater Treatment
Facility for treatment (aeration) and disposal by evaporation and percolation. The Proposed
Project would include improvements that would enable the agricultural wash water to be
conveyed to the Regional Treatment Plant to be recycled. The Proposed Project also includes
improvements at the Salinas Industrial Wastewater Treatment Facility to allow storage of
Certain parties have disputed the validity of Amendment 3. If Amendment 3 were to be found invalid, the
assignment of MRWPCAs recycled waters to Marina Coast Water District in the RUWAP MOU may also be found
to be invalid. For purposes of this analysis, however, it is assumed that Amendment 3 is valid and enforceable and
that Marina Coast Water District has an existing right to 650 AFY during the summer months.
-3-
agricultural wash water and south Salinas stormwater in the winter and recovery of that water for
recycling and reuse in the spring, summer and fall.
2.
Legal Framework
The City of Salinas has the exclusive right to the treated wastewater it collects in its system and
treats at the Salinas Treatment Facility, unless modified in a contractual agreement. 4 Prior to
making a change in the point of discharge of treated wastewater, the owner of a wastewater
treatment plant shall obtain approval from the State Board for that change if the proposed change
would result in decreased flow of any portion of a watercourse. 5 In reviewing a petition, the State
Board must find that the proposed change will not injure any other legal users of water and that
the change complies with the requirements of the California Fish and Game Code and the federal
Endangered Species Act. The petition would also require the issuance of the EIR.
The City of Salinas thus has an exclusive right to the agricultural wash water discharged to its
system, except (1) as that right has been varied by contractual arrangements or (2) to the extent
the diversion of that wastewater would decrease the flow of a watercourse.
3.
Since the City of Salinas currently has the exclusive right to its treated wastewater, a contract
would be needed between MRWPCA and the City of Salinas for the diversion and use of
agricultural wash water. Although no agreement for the use of agricultural wash water is yet in
effect, we understand that the City of Salinas has been working cooperatively with MRWPCA,
demonstrating a reasonable likelihood that this source of water can be obtained.
In addition, the State Board clarified in its comments on the Draft EIR that State Board approval
would be needed for diversion of wastewater that is currently discharged into percolation ponds
adjacent to the Salinas River, because such diversion would reduce the flow of the Salinas River.
We understand that such approval will be pursued for the diversions from the percolation ponds.
C.
Salinas Stormwater Collection System

1.
Stormwater from urban areas in southern portions of the City of Salinas is currently collected
and released to the Salinas River through an outfall near Davis Road. The Proposed Project
would include improvements that would enable Salinas Stormwater to be conveyed to the
Regional Treatment Plant to be recycled.
4
5

Cal. Water Code 1211(a), (b).
-4-
2.
Legal Framework
To divert stormwater and dry weather flow from urban areas, agreements are needed between
MRWPCA and the local agencies that currently collect and convey the flows in man-made
facilities for discharge to surface waters. These local agencies include the City of Salinas for
urban runoff/stormwater source water from the Salinas River. Stormwater runoff from urban
areas through storm drain infrastructure (i.e., in the City of Salinas) does not become water of the
state until it is discharged into a river or channel.
3.
MRWPCA would need to obtain water rights from the applicable local agencies, including the
City of Salinas. We understand that there are currently no contractual arrangements or permits
for diversion of stormwater or urban/agricultural runoff to the MRWPCA wastewater collection
and conveyance system. However, such agreements are being pursued by MRWPCA.
MRWPCA is also in the process of adjusting its connection fees and rates for discharges of
stormwater and urban runoff to the wastewater collection system. We understand that the City of
Salinas has been working cooperatively with MRWPCA, and agreement is reasonably likely.
This demonstrates a reasonable likelihood that this source of water can be obtained.
D.
Reclamation Ditch / Tembladero Slough, Blanco Drain, and Lake El Estero

Diversions
1.
The Reclamation Ditch is a network of excavated earthen channels used to drain natural, urban,
and agricultural runoff and agricultural tile drainage. The Proposed Project would include
improvements that would enable water from the Reclamation Ditch watershed to be diverted in
two locationsfrom the Reclamation Ditch at Davis Road and from Tembladero Slough (to
which the Reclamation Ditch is a tributary) near Castrovilleto be conveyed to the Regional
Treatment Plant to be recycled.
The Blanco Drain collects water from approximately 6,400 acres of agricultural lands near
Salinas. The Proposed Project would include improvements that would enable water in the
Blanco Drain to be diverted and conveyed to the Regional Treatment Plant to be recycled.
The City of Monterey actively manages the water level in Lake El Estero so that there is storage
capacity for large storm events. Prior to a storm event, the lake level is lowered by pumping or
gravity flow for discharge to Del Monte Beach. The Proposed Project would include
improvements that would enable water that would otherwise be discharged to the beach to
instead be conveyed to the Regional Treatment Plant to be recycled.
-5-
2.
Legal Framework
Water that enters surface streams and rivers is considered water of the state. A water rights
permit is required to impound or divert waters of the state, except for certain riparian uses.
Transfer of surface water flows out of known and defined channels for recycling would be a
consumptive use that may come under the jurisdiction and regulation of the State Board.
Water rights permits from the State Board would be required for surface water diversions from
the Reclamation Ditch, Blanco Drain, and Tembladero Slough. In its comments on the Draft
EIR, the State Board clarified that the proposed diversion from Lake El Estero would also
require an appropriative right from the State Board. These source waters include agricultural
return flow (overland flow and tile drainage), stormwater flow, and urban runoff. The State
Board will require a completed CEQA document before issuing a permit.
In considering an application to appropriate water, the State Board considers a number of
factors. 6 Specifically, the State Board considers the relative benefit to be derived from (1) all
beneficial uses of the water concerned including, but not limited to, use for domestic, irrigation,
municipal, industrial, preservation and enhancement of fish and wildlife, recreational, mining
and power purposes, and any uses specified to be protected in any relevant water quality control
plan, and (2) the reuse or reclamation of the water sought to be appropriated, as proposed by the
applicant. The State Board may subject such appropriations to such terms and conditions as in its
judgment will best develop, conserve, and utilize in the public interest, the water sought to be
appropriated. 7 The State Board is guided by the policy that domestic use is the highest use and
irrigation is the next highest use of water. 8 The Proposed Project is consistent with these factors
and it does not appear that any of the factors considered would reduce the likelihood of obtaining
the necessary permits.
The Water Resources Agency submitted an application in April 2014 to the State Board to
appropriate waters of the Blanco Drain, the Reclamation Ditch, and Tembladero Slough.
Specifically, it applied to divert up to 25,000 acre-feet per year from each of the two water
bodies at a combined rate of diversion of up to 100 cfs. On November 10, 2014, the State Water
Resources Control Board sent a letter stating that staff had found the application was incomplete
in several respects. In response, the Water Resources Agency submitted five separate
applications on July 29, 2015, three of which are related to the Proposed Project (Application
Nos. 32263A, 32263B, 32263C). 9 At the request of the State Board, the Water Resources
6
Cal. Water Code 1250 et seq.

8
9
The remaining two applications, Application Nos. 32263D and 32263E, relate to potential future diversions by the
Water Resources Agency. The Proposed Project is separate and has independent utility from these potential future
diversions. Such additional waters are not needed for the Proposed Project to proceed. While these additional waters
may receive tertiary treatment at the Salinas Valley Reclamation Plant, and may be distributed through the
Castroville Seawater Intrusion Project (CSIP) conveyance system that would be used by the Proposed Project, these
potential future diversions likely would require additional facilities for which the Water Resources Authority has not
7
-6-
Agency submitted amended applications with minor changes on July 29, 2015. The applications
remain pending before the State Board.
The Source Waters MOU specifies that these water rights would be retained exclusively by the
Water Resources Agency under the permits, but that all parties would pay pro rata costs
associated with the procurement and retention of these water rights. The parties also agreed to
work jointly on obtaining the needed water rights through amendments to the permit application.
In comments on the Draft EIR, the State Board clarified that an application would need to be
filed to divert water from Lake El Estero in advance of a storm event. In addition, MRWPCA
would need to obtain any needed agreements with the owners of the infrastructure that would be
used for this diversion, such as the City of Monterey.
3.
Several steps need to be taken to secure these water rights. As a preliminary matter, the State
Board would need to grant the water rights requested in Application Nos. 32263A, 32263B,
32263C. Second, the Source Waters MOU indicates that the Water Resources Agency would
hold all of the rights to these waters under the Definitive Agreement associated with Application
Nos. 32263A, 32263B, and 32263C, once issued. A separate agreement would therefore be
necessary between the Water Resources Agency and MRWPCA to ensure that the Proposed
Project has sufficient water rights associated with these applications. Therefore, these water
rights are not secured yet. However, because the Water Resources Agency has submitted an
application for water rights, and given the terms of the Source Waters MOU, there is a
reasonable likelihood that this source of water can be obtained.
An application would also need to be filed for the diversion of the Lake El Estero diversion,
should such waters be used for the Proposed Project. MRWPCA would need to obtain rights to
use the infrastructure that would be used by this diversion owned by local agencies, such as the
City of Monterey. It is our understanding that such rights would be pursued in due course if
Lake El Estero waters would be used by the Proposed Project.
yet performed engineering or feasibility studies. The environmental impacts of these potential future diversions
would be analyzed in a separate CEQA process.
-7-
E.
Summary Chart
Source of Water
Municipal Wastewater Collection and

Treatment System
The MOU is not binding; the forthcoming

Definitive Agreement would address and
resolve competing water rights of Marina
Coast Water District and Monterey County
Water Resources Agency.
Salinas Agricultural Wash Water System
A contract is needed between MRWPCA and

the City of Salinas for diversion and use of the
agricultural wash water. In addition, State
Board approval is needed for the diversion of
the agricultural wash water away from the
percolation ponds.
Salinas Stormwater Collection System and

Lake El Estero water
Contracts are needed between MRWPCA and

the applicable local agencies, including the
City of Salinas.
Reclamation Ditch / Tembladero Slough,

Blanco Drain, and Lake El Estero Diversions
State Board approval of the pending

applications is needed. An additional
application for the Lake El Estero diversion
would need to be filed. Because the Source
Waters MOU is not binding, the forthcoming
Definitive Agreement would further address
these water rights. The MOU suggests that the
Water Resources Agency will exclusively
retain the water rights under the permit, in
which case a separate agreement would be
needed between the Water Resources Agency
and MRWPCA.
-8-
AppendixAA
SalinityImpactstoElkhornSloughresultingfromSurfaceWaterDiversionforthe
PureWaterMontereyGroundwaterReplenishmentProject
FinalEIR
September2015

Final EIR
September 2015
3 Quail R
Run Circle, Suiite 101
Salinnas, CA 939077-2348
(831) 8333-4848
F
FAX (831) 8333-2424
swmb@swssv.com
TEC
CHNICALMEMOR
RANDUM
TO:BobH
Holden,MRW
WPCA
FROM: AndrewA.Ste
A
erbenz,PE;A
AndrewRacz,EIT
D
DATE:Septem
mber16,2015
JO
OB#:MRWP
P.01.14:004
SUBJECT:SalinityImp
pactstoElkho
ornSloughresultingfrom surfacewateerdiversionsforthePure
WaterMo
ontereyGrou
undwaterRep
plenishmentProject
________
____________
___________
____________
__________________________________________________
INTRODU
UCTION:
Thistechn
nicalmemoassessesthep
potentialimpaactofthediveersionofuptto16.6cfsoffreshwater
inflowsfo
orthePureW
WaterMontere
eyGroundwaaterReplenishhmentProjecct(Project)on
nthesalinityiin
ElkhornSlough.ElkhornSloughisaatidalestuaryy,receivingsaaltwatertidalinflowfromMontereyBaayat
theMossLandingharb
borinlet,asw
wellasfreshw
waterinflowfrromseveralssurfacestream
ms,thelargesstof
whichistheOldSalinasRiver.Thesseinputsmixwithintheesstuary,and,aalongwithpreecipitation,
evaporation,andgroundwaterexch
hange,determ
minesalinityllevelsinthesslough.Theffollowing
diversionssarepropose
edfromstreamsthatfeedtheOldSalinnasRiver:upto6cfsfromtheReclamaation
DitchnearSalinas,uptto3cfsfromTembladeroSloughnearCCastroville,an
naverageflowof4.6cfsfrom
olationpondinflowtothe SalinasRiverr.Theminimumflowbypaassing
BlancoDrrain,and3cfssoflostperco
thepropo
osedProjectw
wouldbe2.0cfsintheSaliinasRiverandd1.0cfsinth
heReclamatio
onDitch/
Temblade
eroSlough,althoughhighe
erflowsareexpectedinm ostmonths.
CURRENT
TSALINITYRA
ANGEANDDISTRIBUTIONINELKHORN
NSLOUGH
TheReclamationDitch
hdrainsawattershedofapproximately1157squarem
milesinandarroundSalinass.The
ReclamationDitchisatributaryofTTembladeroSSlough,whichhisitselfatrib
butaryoftheOldSalinasR
River
(OSR).Th
heOldSalinassRiver,whichalsoreceivesscontrolledfflowsofupto
o120cfsfrom
mtheSalinasR
River
Lagoon,d
dischargesintoElkhornSlo
oughattheso
outhernendoofMossLandiingharbor.
Asaresultofcomplexbranchingge
eometry,tidalinfluence,anndseasonallyyvariablefresshwaterinputs,
thesalinittyinElkhornSSloughvariesssignificantlywithbothtim
meandlocation.FreshwaterfromtheOSR
dischargesintoMossLLandingharbo
oratlowtide.Itmixeswitththeoutgoingtideintheemainchanneel
andiscarriedoutintoMontereyBaay.Whenthe
etidecomesbbackin,anyffresh/brackish
hwaterremaaining
inthemainchannelispushedsome
edistanceupElkhornSlouughbytherisiingtide,mixin
ngtovarying
degreesaasittravels.D
Dependingon
ntheseason,waterinthe mostinlandrreachesofthesloughcanbe
eitherfresherduetow
winterrunoff,orsaltierduetosummer evaporation,,thanwateriinMontereyBay,
erallsloughsalinitywhenmixingoccurss.TheLand/O
OceanBiogeo
ochemical
andalsoinfluencesove
Observato
ory(LOBO)attMBARIhase
establishedanetworkofflloatingsenso
orsthatcontin
nuouslyrecorrd
salinityattvariouslocattionsinandaaroundElkhorrnSlough(Figgure1).
BobHolden,MRWPCA
September16
6,2015
Monterey
M
Bay
ma
ainchannel
inlet
MossLandingharbor
PotrreroRd.
tidegate
Figure1:MapofElkho
ornSlough.SSignificantfeaaturesandLO
OBOsamplinggstations(pin
ns)areidentiffied.
MODEL:
MIXINGM
ElkhornSloughhasasurfaceareao
ofapproximattely1.25squaaremilesandanaveragettidalrangeof
f
about3.5feet,resultin
nginanaveraagedailytidallfluxofapprooximately14000cfs.Theactualtidalran
ngein
anygiventidecycleisggovernedbythepositiono
ofthemoon,sun,oceanccurrents,presssuresystemssand
winds,andcanvarybe
etweenextrem
mesofappro
oximately0.5 feetand7feeet.ElkhornSSloughtypically
experienccestwohighaandtwolowttidesperday,,suchthatthheminimum00.5foottidalcyclewillalw
ways
beaccompaniedbyasseconddailyttidewitharangeofatleasst2feet.Theemodelthereeforeusesa2
2foot
rangetoccalculatetheminimumtidalinflow:approximately8800cfs.Themaximummo
odeledtidalfflux
causedbyya7tideisapproximatelyy2800cfs.Th
hesalinityof inflowingMo
ontereyBayw
watervariesw
within
anarrowrangeof323
34partsperthousand(pptt).Theavera gevalueof33.4pptisuseedinthemod
del.
oMossLandinngharbor,butinflowstotheOSRfromthe
TheOldSalinasRiverissnotgagedatitsoutletto
SalinasRivverLagoonarreregulatedb
byaslidegate.Typicalsu mmerflowsaare<15cfs,andthegateis
2
BobHolden,MRWPCA
September16,2015
operatedsuchthathighflowsneverexceed120cfs.FlowsontheReclamationDitch/Tembladero
Slough(RD/TS)watershedarerecordedbyUSGSgage#11152650,locatedatSanJonRoadjustnorthof
Salinas.Ascalingfactorof1.44(basedonrelativewatershedareaandrunoffcharacteristics)isapplied
toreadingsfromthisgagetoestimatetotalflowinTSatitsconfluencewiththeOSR.Thepeak
instantaneousgagedflowmeasuredfortheRDis684cfs.Thisoccurredon12/12/14andwasonthe
orderofa100yearevent.TypicalmeandailyflowsontheRDare<50cfsduringthewetseasonand
<10cfsduringthesummermonths.FlowsintheRD/TSarefresh,andanaveragesalinityvalueof1.5
pptisusedinthemodel.
Amixingmodelwascreatedusingtheequation:Q1C1+Q2C2=(Q1+Q2)C3,whereQ1andQ2aretheflow
ratesoftwodifferentinflows,andC1andC2aretheirrespectivesalinities.ThemodelsolvesforC3,the
resultingsalinityofthemixedwaterbody.Table1listsmixingmodelinputsandresultsforatidalrange
of3.5feetandflowratesontheOSRrangingbetween3and1000cfs.Mixingassumesonlytwoend
members(MontereyBayInflowandOldSalinasRiverInflow)andispresumedtobeconservativeand
complete.FortheProjectscenario,theProjectDiversionissubtractedfromOSRInflowvaluespriorto
calculatingmixing.TheimpactoftheProjectonElkhornSloughsalinity(relativetoNoProject
conditions)isexpressedasbothanabsolutequantityandapercentagechange.DatafromTable1are
plottedinFigure2A.Figures2Band2Cshowmodelresultsfortidalranges7.0and2.0respectively.
Inflows
Tidal
OSR
(cfs)
(cfs)
1412
3
1412
4
1412
5
1412
6
1412
7
1412
8
1412
10
1412
15
1412
20
1412
30
1412
40
1412
50
1412
70
1412
100
1412
150
1412
200
1412
300
1412
400
1412
500
1412
700
1412
1000
Project
Diversion
(cfs)
0
1
2
3
4
5
7
12
16.6
16.6
16.6
16.6
16.6
16.6
16.6
16.6
16.6
16.6
16.6
16.6
16.6
Salinity:Inflows
Bay
OSR
(ppt)
(ppt)
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
33.4
1.5
Salinity:ElkhornSlough
NoProject
Project
(ppt)
(ppt)
33.33
33.33
33.31
33.33
33.29
33.33
33.26
33.33
33.24
33.33
33.22
33.33
33.18
33.33
33.06
33.33
32.95
33.32
32.74
33.10
32.52
32.88
32.31
32.66
31.89
32.24
31.29
31.62
30.34
30.65
29.44
29.73
27.81
28.07
26.36
26.59
25.06
25.26
22.83
22.99
20.17
20.30
Table1:Mixingmodelinputandresultsforattidalrangeof3.5feet.
SalinityDifference:
Projectvs.NoProject
(ppt)
(%)
0.00
0.00%
0.02
0.07%
0.04
0.14%
0.07
0.20%
0.09
0.27%
0.11
0.34%
0.16
0.47%
0.27
0.81%
0.37
1.12%
0.36
1.11%
0.36
1.10%
0.35
1.10%
0.34
1.08%
0.33
1.06%
0.31
1.02%
0.29
0.99%
0.26
0.93%
0.23
0.87%
0.21
0.82%
0.17
0.74%
0.13
0.64%
BobHolden,MRWPCA
September16
6,2015
wetconditions
w
his
istoric
hig
ghflow
tyypical
con
nditions
(A
A)
(B
B)
(C
C)
Figure2:ModeledsalinityinElkhornSloughverrsusOSRinfloow,fortidalrangesof(A)1
1412cfs[3.5tide,
average],(B)2823cfs[7.0tide,maaximum],and
d(C)807cfs[[2.0tide,min
nimum].
4
BobHolden,MRWPCA
September16,2015
DISCUSSION:
Duringmostoftheyear,therelativevolumeofinflowtoElkhornSloughfromtheOSRisverysmall(<15
cfs)comparedtoinflowsfromMontereyBay(approximateflowrangesindicatedonFigure2).Atsucha
smallmixingratio,thewaterinElkhornSloughwillnotbeappreciablyfreshenedbeyondbackground
seawatervalues.Eventhoughdiversionsmayrepresentalargeportionofthefreshwaterinflowsunder
suchconditions,theabsolutequantityoffreshwaterenteringElkhornSloughissosmallthatmeasurable
differencesbetweenProjectandNoProjectconditionsareundetectableduetobackgroundvariation.
Conversely,whenflowsfromtheOSRarehighenoughtoappreciablydrivedownthesalinityinElkhorn
Slough,the16.6cfsproposedtobedivertedfortheGroundwaterReplenishmentProjectcomprisesuch
asmallfractionoftotalfreshwaterinflowsastolikewisehavenodetectableinfluenceontheresulting
salinityinElkhornSlough.Furthermore,duringthetimeofyearwhenflowstendtobehigh(winterwet
season),demandforrecycledwaterforirrigationislow,andsurfacewaterdiversionswouldnotbe
required.
EvenatflowrangeswhereimpacttoElkhornSloughsalinityishighest(approximately1050cfs),the
magnitudeoftheimpactremainssmall:<0.4ppt(1%)ontheaveragetide,andinthemost
conservativecase(2.0tidalrange),still<0.7ppt(2%).Thesesalinityconcentrationsfallwithinthe
rangeofnaturalvariabilityofMontereyBaywater,andaresignificantlysmallerthantherangeof
observedsalinityconcentrationsinElkhornSlough.TheProposedProjectwouldnotdetectablychange
thesalinityofElkhornSloughonanaveragedaily,weeklyormonthlybasis.Theoverallimpactofthe
ProjectonElkhornSloughsalinityisdeterminedtobenegligible.
Thispageisintentionallyblank.
FinalEIR
September2015
AppendixBB
FutureRUWAPUrbanRecycledWaterIrrigationWaterUse
andImplicationsforCSIPYields
FinalEIR
September2015
FinalEIR
September2015

831-883-4848
FAX 831-758-6328
asterbenz@swsv.com
Schaaf & Wheeler
MEMORANDUM
TO:
Bob Holden, MRWPCA
DATE:
September 16, 2015
FROM:
Andrew Sterbenz, PE
Alison Imamura, AICP
JOB #:
MRWP.01.14
SUBJECT:
Future RUWAP Recycled Water Urban Irrigation Use and Implications for CSIP Yields
The purpose of this memorandum is to provide a discussion of the future Regional Urban Water
Augmentation Project (RUWAP) Recycled Water Project for urban irrigation and its effects on
Castroville Seawater Intrusion Project (CSIP) water supplies, with and without the Pure Water Monterey
Groundwater Replenishment Project (Proposed Project).
Municipal wastewater is currently collected and conveyed to the MRWPCA Regional Treatment Plant
(RTP) for primary and secondary treatment. The secondary-treated effluent is then either sent to the
Salinas Valley Reclamation Plant (SVRP) for tertiary treatment, or it is discharged to the ocean. The
tertiary-treated (recycled) water is supplied to the CSIP for agricultural irrigation. The Proposed Project
would develop additional sources of water supply which would be conveyed to the RTP, increasing the
supply of secondary treated effluent. A portion of this secondary-treated effluent would be sent to a new
Advanced Water Treatment Facility (AWT Facility), and the remainder would be available for use by the
SVRP/CSIP.
The Marina Coast Water District (MCWD) commented on the Draft Environmental Impact Report
(DEIR) for the Proposed Project that its future urban recycled water project should be included in the
supply analysis. The future RUWAP Recycled Water Project was addressed within the cumulative
analyses in the DEIR. Cumulative projects were not included in the calculations of the Proposed Projects
source water and use quantities. In the Proposed Project source water and use analysis, treated municipal
wastewater that would be used by CSIP and the future RUWAP Recycled Water Project is appropriately
assumed to not be available as influent for the AWT Facility during the peak irrigation demand months of
April through September. The CSIP and the MCWD have existing contractual rights to the treated
municipal wastewater, therefore the peak season volumes of water currently (i.e., based on the applicable,
recent, 2009-2013 of monthly average flow data) discharged to the ocean outfall were considered
available only to the SVRP for recycled water production. The average flows to the ocean outfall in the
months of October through March exceed the combined projected demands of the GWR, the urban
recycled water project, and the average CSIP groundwater use, and were therefore included in the
analysis as available supplies for the AWT Facility in those months.
MCWD and FORA have jointly pursued the Regional Urban Water Augmentation Project that includes
both a desalination component and a Recycled Water Project (the Recycled Water Project is herein
referred to as the RUWAP) to develop additional urban irrigation water supply for redevelopment of the
former Fort Ord. In accordance with existing agreements (see Table 4.18-5) among MRWPCA,
MCWRA, and MCWD, MCWD has the right to purchase recycled water from the SVRP, up to the annual
volume of municipal wastewater from MCWDs service area treated at the RTP. MCWD has agreed to
To: Bob Holden
-2-
9/16/2015
limit their use of recycled water to 300 acre-feet during the period of April through September.
MRWPCA had committed an additional 650 acre-feet during the period May through August in a
Memorandum of Understanding between MCWD and MRWPCA (2009 RUWAP MOU). In the 2009
RUWAP MOU, MCWD and MRWPCA each committed their respective recycled water rights to the
RUWAP. The RUWAP Recycled Water Project has not been implemented due to lack of funding, user
commitments and immediate need for additional water supply, although the system is designed and
sections of the recycled water pipeline have been installed in conjunction with road improvement
projects. In addition, budget for completing the RUWAP facilities is not included in the MCWD 5-Year
Capital Improvements Program. Therefore, the Draft EIR appropriately describes and analyzes the
RUWAP as a reasonably foreseeable future project for purposes of its cumulative impacts analysis, rather
than as an existing condition or a future background condition. A description of the proposed RUWAP
was provided on page 4.1-13 and a cumulative analysis was provided within each topical section of
Chapter 4; for example, combined impacts on water and wastewater systems are analyzed on pages 4.1837 through 4.18-38. For the purpose of the Proposed Projects EIR, the existing flows into and out of the
Regional Treatment Plant (RTP) are shown in Figure 1.
The RUWAP was originally planned and approved to provide 1,500 AFY of recycled water1 including
1,200 AFY to the former Fort Ord and 300 AFY to areas outside the former Fort Ord served by the City
of Seaside or CalAm. The RUWAP Project Description was updated in two EIR Addenda, including
Addendum #2 that enabled MCWD to increase the RUWAP Recycled Water Project potential yield to up
to 1,727 AFY of recycled water to provide the ability to serve more customers within their service area.
In 2013, MPWMD and MRWPCA partnered to pursue the Proposed Project in part because the urban
recycled water project was not scheduled for implementation, but primarily due to the issuance of a Cease
and Desist Order by the SWRCB2 regarding unauthorized diversions of Carmel River water by CalAm.
Based on the FORA recycled water allocation approval in Resolution 07-10 (May 2007), the MCWD
2010 UWMP (MCWD, 2011), and the MCWD customer demand analyses in the Recycled Water Project
Basis of Design Report (RMC, 2009), the RUWAP recycled water demand is assumed to be 1,427 AFY
for the purpose of the cumulative analysis of water supplies in this EIR, with contractual rights to
wastewater capped at the agreed upon 650 AF of MRWPCA rights and 300 AFY from MCWDs rights
during the months of April through September.
Under the Agreements listed in Table 4.18-5 as amended in this Final EIR to include the 2009 RUWAP
MOU, implementation of the RUWAP Recycled Water Project without implementation of the Proposed
GWR Project would change the monthly availability of recycled water for CSIP customers in the peak
demand months, as shown in Table 1. See Figure 2 for a RTP flow schematic of this scenario.
The RUWAP would require modifications of the SVRP to meet low winter demands, so the average
annual recycled water deliveries to CSIP would increase by 1,350 AFY (i.e., 14,345 AFY compared to
12,939 AFY). The remaining groundwater use within CSIP would shift from winter to summer.
1 Final EIR for the Regional Urban Water Augmentation Project, adopted 5/25/2005
2 SWRCB Order Number WR 2009-0060
Memo_Future Urban Recycled Use_20150911.docx
To: Bob Holden
-3-
9/16/2015
Table 1: Projected Recycled Water Use with RUWAP and No Proposed Project (acre-feet)
Source/
Month
RTP
Inflows1
RUWAP
CSIP2
Outfall
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Total
1,798
81
461
1,256
1,678
74
654
950
1,867
81
1,030
756
1,796
156
1,640
0
1,850
161
1,689
0
1,799
156
1,643
0
1,893
161
1,733
0
1,888
161
1,727
0
1,813
156
1,657
0
1,844
81
1,059
703
1,762
79
681
1,003
1,776
81
370
1,326
21,764
1,427
14,345
5,992
NOTES:
1. The RTP inflows have decreased from these values in 2014 and the first half of 2015 due to drought and associated
conservation. These averages may be adjusted in the future using newer data; however, for the purposes of this EIR, the
baseline wastewater flows were established as 2009 to 2013 as the Draft EIR preparation began in early 2014 and that was
the most recent data available at that time.
2. CSIP use in this table is the lesser of either (a) the average monthly SVRP and groundwater use, or (b) the RTP Inflow
minus RUWAP.
The Proposed Projects DEIR includes two product water pipeline options for conveying water from the
proposed AWT Facility to the Injection Well Facilities site (Sections 2.9 and 2.12). One option is to
follow the planned RUWAP recycled water main alignment, and the other follows the TAMC rail rightof-way through Marina into Seaside, and then uses street rights-of-way to General Jim Moore Blvd.
Under the RUWAP alignment option, parallel pipelines would be constructed (the RUWAP pipeline for
tertiary-treated recycled water delivery to urban irrigation customers and the Proposed Project pipeline for
advanced treated water conveyance for injection in the Seaside Groundwater Basin). Joint use of a shared
pipeline is beyond the scope of the Proposed Project. However, this memorandum analyzes the potential
yields a shared pipeline may have in the event that MRWPCA and MCWD pursue this configuration in
the future. Figures 3 and 4, attached, show conceptual flow diagrams of these two configurations. The
shared pipeline configuration would require MCWD to accept advanced treated water instead of tertiarytreated recycled water, which may affect the volume of water available for urban reuse. The reduction of
recycled water quantity compared to the full delivery is based on the planning assumption that a certain
amount of the wastewater influent to the AWT would be lost during the treatment process.
Approximately 19% of the influent treated wastewater would be discharged to the ocean as AWT Facility
by-product, called reverse osmosis concentrate.
The following monthly urban recycled water demand scenarios have been modeled to estimate the
quantities of recycled water available for CSIP and the RUWAP. These scenarios vary according to how
the recycled water (including quantity and quality) is produced and delivered. Table 2, below, shows the
results of the water quantity analysis in terms of RUWAP cumulative demands for each scenario, and
Table 3, attached, shows the resultant monthly CSIP flows for each scenario.
Recycled Water (RW) Scenario: In this scenario, the RUWAP pipeline and the Proposed
Project Product Water Conveyance pipeline are constructed separately, as contemplated in the
Proposed Projects EIR. MCWDs customers receive the full assumed urban irrigation demand
of 1,427 AFY produced by the SVRP and delivered with the RUWAP tertiary-treated recycled
water (purple) pipeline when the RUWAP is constructed. Values in the table reflect the
average monthly deliveries of urban recycled water. This scenario would require modifications to
the SVRP to meet low winter recycled water demands (<5 mgd and <460 AF/month).3 See
Figure 3, Conceptual Flow Schematic of Proposed Project plus RUWAP with Separate Pipeline,
for a conceptual flow diagram.
The proposed SVRP modifications would also be required for the Proposed Project and are thus included in
Chapter 2, Project Description (see pages 2-64 through 2-66).
To: Bob Holden
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9/16/2015
Advanced Water Treatment Product (AWT Product) Scenario: In this scenario, MCWD and
MRWPCA would agree in the future to share the Proposed Project Product Water Conveyance
pipeline, and the full assumed MCWD recycled water demand of 1,427 AFY would be produced
by the Proposed Project AWT Facility and delivered as purified recycled water, conveyed in the
same pipe with the product water intended for Seaside Basin subsurface application. Values in
the table reflect the average monthly influent required at the AWT Facility to produce the
quantities of delivered water reflected in the RW Scenario. Under the AWT Product scenario, the
AWT process loss associated with the RUWAP yield would need to be supplied from new
sources. This is referred to as the Shared Pipeline Scenario with Allocations met as Product
Water. See Figure 4, Conceptual Flow Schematic of Proposed Project plus RUWAP with Shared
Pipeline, for a conceptual flow diagram.
Advanced Water Treatment Influent (AWT Influent) Scenario: In this scenario, MCWD and
MRWPCA would agree to share a pipeline as shown in Figure 4, and the 1,427 AFY of RUWAP
supply would be used as influent to the AWT Facility, producing a net yield of 1,156 AFY of
purified recycled water (due to the 19% process loss as RO concentrate). This supply would be
conveyed in the same pipe with the Proposed Projects product water intended for Seaside Basin
subsurface application. Under this scenario, none of the new sources are used to supplement the
RUWAP production. Values in the table reflect the net monthly deliveries of urban recycled
water. This is referred to as the Shared Pipeline Scenario with Allocations met as AWT Facility
Influent.
Initial Recycled Water Demand (Init-RW) Scenario: This scenario shows initial RUWAP
deliveries of 540 AFY, delivered as tertiary-treated recycled water consistent with Figure 1. This
total only includes current urban irrigation demands at locations along the RUWAP trunk main
(i.e., the customers who could be served without constructing additional lateral pipelines). This
scenario is included to reflect that full RUWAP MOU deliveries are not required at this time. In
this scenario, the RUWAP pipeline and the Proposed Project Product Water Conveyance pipeline
are constructed separately. Values in the table reflect the average monthly deliveries of urban
recycled water. This scenario would require modifications to the SVRP to meet low winter
recycled water demands
Initial AWT Demand (Init-AWT) Scenario: In this scenario, MCWD and MRWPCA would
agree in the future to share a pipeline as shown in Figure 3, and the initial 540 AFY of recycled
water would be produced for existing MCWD customers that are immediately adjacent to the
proposed Product Water Pipeline alignment (i.e., the RUWAP pipeline option). Approximately
666 AFY of AWT Influent would be required to produce this water, accounting for the 19% loss
of RO concentrate as ocean discharge. Values in the table reflect the average monthly influent
that would be required at the AWT Facility to produce the quantities of delivered water reflected
in scenario Init-RW.
To: Bob Holden
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9/16/2015
Table 2: RUWAP Urban Recycled Water Use by Treatment and Delivery Scenario (acre-feet)
Scenario
RW 1
AWT Product2
AWT Influent1
Init-RW 1
Init-AWT2
Jan
81
100
66
31
38
Feb
74
91
60
28
35
Mar
81
100
66
31
38
Apr
156
192
126
59
73
NOTES:
1. Values reflect urban recycled water deliveries.
2. Values reflect influent supply to the AWT Facility
May
161
199
130
61
75
Jun
156
192
126
59
73
Jul
161
199
130
61
75
Aug
161
199
130
61
75
Sep
156
192
126
59
73
Oct
81
100
66
31
38
Nov
79
97
64
30
37
Dec
81
100
66
31
38
Total
1,427
1,761
1,156
540
666
The DEIR for the Proposed Project includes estimates of 4,750 AFY of additional water which would
become available for use in the CSIP in average years, and 5,290 AFY in drought years with a developed
reserve (Section 2.1.1.3 and Appendix B). Those estimations do not include the implementation of the
RUWAP. In accordance with the certified RUWAP EIR, existing MCWD and FORA RUWAP
approvals, and agreements listed in Table 4.18-5, the RUWAP would use the same supply of secondarytreated municipal wastewater as is used to supply recycled water to CSIP, so implementing the RUWAP
would reduce the supply available to CSIP in the peak demand months. The Proposed Pure Water
Monterey Project would more than offset these reductions (that is, the supply to CSIP from new sources
is two to three times greater than the volume used by RUWAP in any month). Table 3 (attached) shows
the MCWD and CSIP recycled water demands and use implications of the RUWAP Recycled Water
Project in combination with the Proposed Project under the various scenarios described above. As can be
seen, the AWT Influent scenario in which the pipeline would be shared has the same effect on CSIP
yields as the separate pipeline scenarios (which is also the current or No Project condition). If the
MRWPCA and MCWD were to agree in the future to share the pipeline under the AWT Product scenario,
the net new supply available to CSIP would be reduced compared to the Proposed Project without
RUWAP in the peak demand months by approximately 220 acre-feet; however, CSIP would still receive
2,370 acre-feet more recycled water in the peak demand months than without the Proposed Project, but
with RUWAP.
Figures 5 to 14 (attached) show the monthly flows into and out of the RTP under the scenarios shown in
Table 3. Each month is represented by two columns. The left column shows inflows to the RTP,
including municipal wastewater and new sources developed under the Proposed Project. The right column
shows outflows and uses, including recycled water from the SVRP to CSIP, recycled water from the
SVRP to RUWAP, Advanced Treated Water to GWR, and unused and/or brine flows to the ocean outfall.
The figures are stacked two per page, with the upper figure showing the scenario without the RUWAP,
and the lower figure showing the same scenario with the RUWAP. In Figure 7, the drought year CSIP
deliveries exceed the monthly RTP inflows due to differences in the way daily flows were calculated in
the data set. Data tables similar to the analysis Tables 8, 9 and 10 from Appendix B of the DEIR,
Memorandum: Pure Water Monterey Groundwater Replenishment Project Proposed Source Water
Availability, Yield, and Use, are attached with the supporting monthly calculations for each scenario.
Because the results are identical for the separate pipeline and the AWT Influent scenarios, tables are not
included for the AWT Influent scenario.
In Appendix B of the Draft EIR, as revised in this Final EIR, the Proposed Project source water analyses
assumed no use of any treated municipal wastewater as influent to the Advanced Water Treatment
Facility during the peak demand months of April through September, and prioritized use of existing
treated municipal effluent quantities by CSIP year round. Due to their contractual rights to municipal
wastewater, peak season volumes of water currently discharged to the ocean outfall were assumed to be
used exclusively as influent to the SVRP for CSIP irrigation. In addition, the EIR assumes that CSIP
could use additional source water flows for recycling up to the existing supplemental groundwater use
(based on monthly averages, 2009-2013). As described above, MCWDs RUWAP was described and
To: Bob Holden
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9/16/2015
analyzed as a cumulative project, and the Draft EIR considered whether the Proposed Project would have
a considerable contribution to any significant cumulative impacts of implementation of all past, present,
and reasonably foreseeable future projects. The analysis of the combined effects of the Proposed Project
plus cumulative projects was provided at the end of each topical section within Chapter 4 of the Draft
EIR. Implementation of the RUWAP would necessitate implementation of the SVRP modifications to
meet the urban irrigation demands, and the remainder of the Proposed Project improvements would
increase the availability of wastewater for recycling at the RTP; therefore, even considering any new
information about MCWD desiring to implement their RUWAP in their comments on the Draft, the
cumulative conclusions in the Draft EIR are adequate and appropriate.
The construction impacts of the Proposed Project plus cumulative projects in the Draft EIR assumes that
the RUWAP would not be built simultaneously with the Proposed Project due to schedule urgency of
completing the Proposed Project and the limited existing demand for urban recycled water (estimated to
be 540 AFY total or 360 AF during April through September). Therefore, the construction impacts of the
two projects would not be additive such that any construction impacts of either project would be
worsened by the other project. Overall construction impacts would be reduced if MRWPCA and MCWD
agree in the future to share a single pipeline compared to constructing separate pipelines for RUWAP and
the AWT product water. In particular, construction of a single pipeline for both uses would reduce
construction equipment and vehicle use, reduce timeframes during which sensitive receptors near the
RUWAP alignment would be exposed to construction impacts including air pollutants and
noise/vibration, and traffic impacts would be reduced in terms of duration of temporary increased
volumes and transportation disruptions. However, the Draft EIRs analysis (of both construction and
operational impacts) assumed that the Proposed Project product water conveyance pipeline would be built
sooner and that a potential future RUWAP pipeline would be constructed at a later date (i.e., not within
the same timeframe nor with any overlapping timeframes). The impacts of constructing the RUWAP
pipeline separately were addressed in the RUWAP EIR as amended in the two EIR Addenda
(MCWD/DD&A, 2004 with Addenda in 2005 and 2007). As requested in comments on the Draft EIR,
total recycled water yields for RUWAP customers and CSIP irrigators have been estimated under
numerous implementation scenarios. The potential environmental impacts of future operation with a
shared pipeline would be fully analyzed in a separate CEQA process.
To: Bob Holden
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9/16/2015
Attachments:
Figure 1, Existing Flows Into and Out of the RTP
Figure 2, Flows into and out of RTP with RUWAP and No Proposed GWR Project
Figure 3, Conceptual Flow Schematic of Proposed Project plus RUWAP with Separate Pipelines
Figure 4, Conceptual Flow Schematic of Proposed Project plus RUWAP with Shared Pipeline
Figure 5, Existing Condition with No Proposed Project (2009-2013)
Figure 6, Existing Condition with No Proposed Project plus RUWAP
Figure 7, Existing Condition with No Proposed Project, Drought Year (2013)
Figure 8, Existing Condition with No Proposed Project, Drought plus RUWAP
Figure 9, Proposed Project in a Normal Year Building a Drought Reserve
Figure 10, Proposed Project in a Normal Year Building a Drought Reserve plus RUWAP
Figure 11, Proposed Project in a Normal Year with a Full Reserve
Figure 12, Proposed Project in a Normal Year with a Full Reserve plus RUWAP
Figure 13, Proposed Project in a Drought Year
Figure 14, Proposed Project in a Drought Year plus RUWAP
Table 3, Estimated Annual Recycled Water Yields under Various Scenarios of MCWD Demand and
Pipelines
Table 4A, Source Water Analysis, Diversion Pattern for a Normal Year Building a Drought Reserve, Full
RUWAP Demand as Recycled Water
Table 4B, Source Water Analysis, Diversion Pattern for a Normal Year with a Full Reserve, Full
Table 4C, Source Water Analysis, Diversion Pattern for a Drought Year starting with a Full Reserve, Full
Table 5A, Source Water Analysis, Diversion Pattern for a Normal Year Building a Drought Reserve, Full
RUWAP Demand as AWT Product
Table 5B, Source Water Analysis, Diversion Pattern for a Normal Year with a Full Reserve, Full
Table 5C, Source Water Analysis, Diversion Pattern for a Drought Year starting with a Full Reserve, Full
Table 6A, Source Water Analysis, Diversion Pattern for a Normal Year Building a Drought Reserve,
Initial RUWAP Demand as Recycled Water
Table 6B, Source Water Analysis, Diversion Pattern for a Normal Year with a Full Reserve, Initial
Table 6C, Source Water Analysis, Diversion Pattern for a Drought Year starting with a Full Reserve,
Initial RUWAP Demand as Recycled Water
Table 7A, Source Water Analysis, Diversion Pattern for a Normal Year Building a Drought Reserve,
Initial RUWAP Demand as AWT Product
Table 7B, Source Water Analysis, Diversion Pattern for a Normal Year with a Full Reserve, Initial
Table 7C, Source Water Analysis, Diversion Pattern for a Drought Year starting with a Full Reserve,
Initial RUWAP Demand as AWT Product
To: Bob Holden
-8-
Figure 1. Existing Flows Into and Out of the RTP
Figure 2. Flows into and out of RTP with RUWAP and No Proposed Project
9/16/2015
To: Bob Holden
-9-
9/16/2015
Figure 3. Conceptual Flow Schematic of Proposed Project plus RUWAP with Separate Pipelines
Figure 4. Conceptual Flow Schematic of Proposed Project plus RUWAP with Shared Pipeline
* = RUWAP deliveries would not exceed either: (1) the amounts in agreements in EIR Table 4.18-5, and (2) MCWDs
municipal wastewater flows to the RTP. RUWAP urban irrigation deliveries are considered as part of a cumulative
project, not part of the Proposed Project.(Note applies to both Figure 3 and Figure 4)
Figure 5
Scenario: Existing Condition with No Proposed Project (2009-2013)

3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MCWD WW to RTP
MAR
APR
Other WW to RTP
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP
SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall
Left Column: RTP Inflows

Right Column: Uses and Outflows
Scenario 1 Existing.xlsx/Chart1
8/10/2015
Figure 6
Scenario: Existing Condition with No Proposed Project Plus RUWAP

3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MCWD WW to RTP
MAR
APR
Other WW to RTP
Scenario 1A Existing-RUWAP.xlsx/Chart1
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP

SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall
8/10/2015
Figure 7
Scenario: Existing Condition with No Proposed Project, Drought Year (2013)

3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MCWD WW to RTP
MAR
APR
Other WW to RTP
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP
SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall

Use exceeds supply in some months due to rounding errors.
Scenario 2 Ex Drought.xlsx/Chart1
8/10/2015
Figure 8
Scenario: Existing Condition with No Proposed Project, Drought Plus RUWAP

3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MCWD WW to RTP
MAR
APR
Other WW to RTP
Scenario 2A Ex Drought-RUWAP.xlsx/Chart1
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP

SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall
8/10/2015
Figure 9
Scenario: Proposed Project in a Normal Year Building a Drought Reserve

3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MCWD WW to RTP
MAR
APR
Other WW to RTP
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP
SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall

Scenario 3 Normal-Building.xlsx/Chart1
8/10/2015
Figure 10
Scenario: Proposed Project in a Normal Year Building a Drought Reserve plus RUWAP
3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MCWD WW to RTP
MAR
APR
Other WW to RTP
Scenario 3A Normal-Building-RUWAP.xlsx/Chart1
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP

SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall
8/10/2015
Figure 11
Scenario: Proposed Project in a Normal Year with a Full Reserve

3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MCWD WW to RTP
MAR
APR
Other WW to RTP
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP
SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall

Scenario 4 Normal-Full.xlsx/Chart1
8/10/2015
Figure 12
Scenario: Proposed Project in a Normal Year with a Full Reserve Plus RUWAP
3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MCWD WW to RTP
MAR
APR
Other WW to RTP
Scenario 4A Normal-Full-RUWAP.xlsx/Chart1
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP

SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall
8/10/2015
Figure 13
Scenario: Proposed Project in a Drought Year

3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MAR
MCWD WW to RTP
APR
Other WW to RTP
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP
SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall

Scenario 5 Drought.xlsx/Chart1
8/10/2015
Figure 14
Scenario: Proposed Project in a Drought Year Plus RUWAP

3000
2500
Acre-Feet
2000
1500
1000
500
0
JAN
FEB
MCWD WW to RTP
Scenario 5A Drought.xlsx/Chart1
MAR
APR
Other WW to RTP
MAY
JUN
New Sources to RTP
JUL
AUG
SVRP to RUWAP

SEP
SVRP to CSIP
OCT
NOV
AWT to GWR
DEC
Outfall
8/10/2015
Table 3. Estimated Annual Recycled Water Yields Under Various Scenarios of MCWD Demand and Pipelines
Existing
Year Type (Notes 4 & 5)
Shared Pipeline Scenarios

Separate Pipelines Scenarios
No Proposed Project
Proposed
with Long-Term
Proposed Project with No MCWD
Short-term MCWD Product Water Flows AWT Influent Flows =
Long-term
Short-term MCWD
Project with all
MCWD Use (Note
Use
Use
= 2009 RUWAP MOU 2009 RUWAP MOU
MCWD Demand
Demand (Note 1c)
MCWD Use
1a)
(Note 1b)
Quantities (Note 2a) Quantities (Note 2b)
(Note 2c)
Scenarios
SVRP to CSIP
(Note 3)
SVRP to
MCWD
SVRP to
CSIP
10,310
950
10,090
10,460
950
9,340
13,000
1,427
14,340
15,470
1,427
15,700
AWT to SGB
(injection
amount)
MCWD
SVRP to CSIP
AWT to SGB
(injection
amount)
AWT to
MCWD
SVRP to
CSIP
AWT to
MCWD
SVRP to CSIP
AWT to
MCWD
SVRP to CSIP
SVRP to
MCWD
1,755
1,755
855
0
0
0
14,160
13,620
14,560
1,755
1,755
855
360
360
360
13,720
13,190
14,110
950
950
950
12,990
12,460
13,380
770
770
770
13,210
12,680
13,610
360
360
360
13,810
13,270
14,200
950
950
950
13,210
12,680
13,610
3,700
3,500
2,500
0
0
0
18,410
17,880
21,200
3,700
3,500
2,500
540
540
540
17,980
17,440
20,680
1,427
1,427
1,427
17,250
16,710
19,830
1,156
1,156
1,156
17,470
16,940
20,090
540
540
540
18,060
17,530
20,780
1,427
1,427
1,427
17,470
16,940
20,090
SVRP to SVRP to SVRP to

CSIP
MCWD
CSIP
April to September
Normal/wet building reserve
Normal/wet reserve full (Note 6)
Drought year use reserve for CSIP
Total Annual
Normal/wet building reserve
Normal/wet reserve full (Note 6)
Drought year use reserve for CSIP
Notes:
1a. This scenarios shows MCWD long-term demands (in accordance with the approved RUWAP Recycled Water Project and 2009 RUWAP MOU) and the resulting expected SVRP deliveries to CSIP without the Proposed Project implemented.
This assumes the SVRP Modifications would be implemented as part of the RUWAP. The SVRP Modifications have not yet been built and thus are also a component of the Proposed Project . Because there would be no drought reserve under
this scenario, all normal/wet year deliveries would be the same.
1b. This scenario shows MCWD short-term demands and the expected SVRP deliveries to CSIP that might occur within the first 2 years of operation of the GWR Project with a pipeline shared with RUWAP. The estimated MCWD demand is
based on existing customers along the RUWAP pipeline alignment- specifically, for Bayonet and Blackhorse Golf Courses, CSUMB sports fields, and Marina Heights streetscapes (MCWD, 2015).
1c. This scenario shows MCWD short-term demands and the resulting SVRP deliveries to CSIP that might occur within the first 2 years of operation of the GWR Project with separate pipelines for RUWAP and Proposed Project. The
estimated MCWD demand is based on existing customers along the RUWAP pipeline alignment- specifically, for Bayonet and Blackhorse Golf Courses, CSUMB sports fields, and Marina Heights streetscapes (MCWD, 2015).
2a. This scenario shows the expected delivery to existing irrigation through CSIP plus planned/proposed demands from MCWD when adequate wastewater inflows from MCWD are sent to RTP to produce the full 2009 RUWAP MOU
allotment (assuming shared pipeline for RUWAP and Proposed Project). Under this scenario, 1,761 AFY of MCWD wastewater inflow is needed for MCWD demands of 1,427 AFY due to 19% of treated water being discharged as reverse
osmosis concentrate to the outfall. Specifically:
AWT Facility Product Water Flows to meet

2009 RUWAP MOU Quantities
MCWD
MRWPCA
Total
Influent
APR-SEP (note
4)
370
802
1,172
AWT Flows
Product
Influent
APR-SEP
(note 4)
Annual
300
959
650
802
950
1,761
Product
Annual
777
650
1,427
2b. This scenario shows the expected delivery to existing irrigation through CSIP plus planned/proposed demands when 950 AFY of wastewater inflows from MCWD are sent to RTP (assuming shared pipeline for RUWAP and Proposed
Project). Under this scenario 1,427 AFY of MCWD wastewater inflow is used to produce 1,156 AFY for MCWD due to 19% of treated water being discharged as reverse osmosis concentrate to the outfall (AWT inflow for MCWD limited to 950
AF for April - September). Specifically:
Influent
AWT Influent Flows limited to MCWD's 2009 APR-SEP (note
4)
RUWAP MOU Quantities
MCWD
300
MRWPCA
650
Total
950
AWT Flows
Product
Influent
APR-SEP
(note 4)
Annual
243
777
526.5
650
770
1,427
Product
Annual
629.37
526.5
1,156
2c. Under this scenario, the assumed delivery to existing irrigation through CSIP plus planned/proposed demands when 950 AFY wastewater inflows from MCWD are sent to RTP. Under this scenario, 1,427 AFY of source water is needed for
MCWD demands of 1,427 AFY because this scenario assumes MCWD recycled water comes from the SVRP and is delivered using separate pipelines.
3. Use of SVRP recycled water by CSIP irrigators for Normal/Wet years assumes the average SVRP deliveries to CSIP in 2009 2013. Use of SVRP recycled water for drought year conservatively assumes SVRP deliveries in 2013 as a baseline.
4. Under the 2009 RUWAP MOU, MCWD committed to provide 300 AFY from April to September while MRWPCA committed to provide 650 AFY from May to August. These calculations assume the 950 AFY spread across April to September
and that MCWD's 300 AFY commitment would be used in April and September.
5. Since the CSIP system was built, CSIP irrigators have also received supply from CSIP supplemental groundwater wells (operated by MRWPCA) and, since 2009, from the Salinas River Diversion Facility (SRDF). These sources would continue
to be available in the future under all scenarios (i.e., with no changes due to RUWAP nor the Proposed Project). The SRDF is expected to provide approximately 3,427 AFY to CSIP based on the full historical record of availability (a 5-year
average, 2009 through 2013). Because the expected yields to CSIP from SRDF would not be affected by the Proposed Project nor by RUWAP, these yields are not included in the totals. Single drought year from SRDF to CSIP (2013) was 6,094
AFY; however, in multiple drought years no water is expected to be available from the SRDF (as demonstrated by years 2014 and 2015).
6. This asumes no diversion of at Tembladero Slough when the drought reserve is full.
Table 4A: Source Water Analysis for the Pure Water Monterey Groundwater Replenishment Project
Diversion Patterns for a Normal Water Year, Building a Drought Reserve, Full RUWAP Demand as Recycled Water
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5
6
7
5 Percolation
6
7
8
SIWTF pond storage balance 8

Recovery of flow from SIWTF storage ponds to RTP
AWW and Salinas Runoff to RTP
Blanco Drain 9
9
10
11
DEMANDS
TOTAL CSIP Demand
18
15 MCWD RUWAP

Use of Source Water
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/28/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
14
24
132
(12)
(16)
(29)
(41)
(46)
(52)
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
(143)
(138)
(143)
(1,257)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
0
0
435
0
0
444
0
0
369
253
0
0
466
0
0
605
0
0
304
2,579
252
225
274
277
244
184
1,456
162
97
132
129
121
80
721
0
0
0
0
0
0
0
0
0
154
0
923
145
0
880
67
0
1,036
66
0
907
62
0
871
41
0
674
0
0
0
0
0
0
0
0
0
535
0
5,291
1,798
1,678
1,867
2,719
2,730
2,835
2,800
2,759
2,487
1,844
1,762
1,776
27,055
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227
81
74
81
156
161
156
161
161
156
81
79
81
1427
367
331
367
355
367
355
367
367
355
367
355
367
4,320
42
409
38
369
42
409
355
367
355
367
367
355
42
409
41
396
42
409
248
4,568
951
1,098
1,520
2,299
2,615
2,867
2,913
2,885
2,509
1,549
1,156
860
23,222
Jan
Feb
Mar
Apr
May
June
July
Aug
Sep
Nov
Dec
461
0
461
654
0
654
1,030
0
1,030
1,640
568
2,208
1,689
513
2,202
1,643
681
2,324
1,733
540
2,273
1,727
504
2,231
1,657
319
1,976
1,059
0
1,059
681
0
681
370
0
370
14,345
3,125
17,470
4,514
81
74
81
156
161
156
161
161
156
81
79
81
1,427

Feedwater to AWT
0
409
0
409
0
369
0
369
0
409
0
409
0
0
355
355
0
0
367
367
0
0
355
355
0
0
367
367
0
0
367
367
0
0
355
355
0
409
0
409
0
396
0
396
0
409
0
409
0
2,401
2,166
4,567
870
1,024
1,439
2,563
2,569
2,679
2,640
2,598
2,331
1,468
1,077
779
22,037
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809
3,591
12
13
Net CSIP Increase
22 Secondary effluent to SVRP for MCWD RUWAP

23
24
25
26
Feb
1,678

(2009-2013)15
29 NEW SUPPLIES IN EXCESS OF AWT DEMANDS FOR GWR 17
846
581
347
(409)
78
(369)
70
(409)
78
0
568
67
(0)
513
70
0
681
67
(0)
540
70
(0)
504
70
0
319
67
Oct
294
607
916
(409)
78
(396)
75
(409)
78
Total
724
868
Notes
8 Ponds 1,2,3 and aeration basin hold up to 1,065 acre-feet (one foot of freeboard). If flow to ponds would exceed the maximum volume, it is presumed that excess flow can be diverted to the RIBs or drying beds or
flow can be diverted to the RTP. Presume that pond storage goes to zero sometime during the year (shown here starting in July).
12 Includes secondary effluent wastewater currently used to produce recycled water at the Salinas Valley Reclamation Project (SVRP), and additional amounts which may be used during periods of low demand (<5
mgd) with the proposed improvements to the SVRP.
13 New source waters not used by AWT will be available to SVRP for CSIP.
This would establish a "water bank" that the CSIP can draw on in droughts. The drought reserve would allow flow at the RTP for the GWR Project to be temporarily reduced during critically dry periods, thus freeing
up more of the newly available inflows to the RTP to be sent to the CSIP area. Extraction from the Seaside Basin would continue at the average rate to supply the Monterey Peninsula.
16 Secondary treated municpal effluent not used for SVRP or the AWT.
17 Excess is calculated as Line 13 minus Lines 16 & 17
18 RUWAP supply comes from existing RTP inflows, demands reflect Phase 1 project.
CSIP-GWR-use28JUL15.xlsx/Normal_Building_RW RUWAP
8/14/2015
Table 4B: Source Water Analysis for the Pure Water Monterey Groundwater Replenishment Project
Diversion Pattern for a Normal Water Year when the Drought Reserve is Full, Full RUWAP Demand as Recycled Water
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5
6
7
5 Percolation
6
7
8

Blanco Drain 9
9
10
11
DEMANDS
TOTAL CSIP Demand
18
15 MCWD RUWAP

Use of Source Water
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/28/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
14
24
132
(12)
(16)
(29)
(41)
(46)
(52)
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
(143)
(138)
(143)
(1,257)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
0
0
435
0
0
444
0
0
369
253
0
0
466
0
0
605
0
0
304
2,579
252
225
274
277
244
184
1,456
162
97
132
129
121
80
721
0
0
0
0
0
0
0
0
0
0
0
769
0
0
735
0
0
969
0
0
841
0
0
809
0
0
633
0
0
0
0
0
0
0
0
0
0
0
4,756
1,798
1,678
1,867
2,565
2,585
2,768
2,734
2,697
2,446
1,844
1,762
1,776
26,520
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227
81
74
81
156
161
156
161
161
156
81
79
81
1427
367
331
367
355
367
355
367
367
355
367
355
367
4,320
0
367
0
331
0
367
355
367
355
367
367
355
0
367
0
355
0
367
0
4,320
909
1,059
1,478
2,299
2,615
2,867
2,913
2,885
2,509
1,507
1,115
818
22,974
Jan
Feb
Mar
Apr
May
June
July
Aug
Sep
Nov
Dec
461
0
461
654
0
654
1,030
0
1,030
1,640
414
2,054
1,689
368
2,057
1,643
614
2,257
1,733
474
2,207
1,727
442
2,169
1,657
278
1,935
1,059
0
1,059
681
0
681
370
0
370
14,345
2,590
16,935
3,979
81
74
81
156
161
156
161
161
156
81
79
81
1,427

Feedwater to AWT
0
367
0
367
0
331
0
331
0
367
0
367
0
0
355
355
0
0
367
367
0
0
355
355
0
0
367
367
0
0
367
367
0
0
355
355
0
367
0
367
0
355
0
355
0
367
0
367
0
2,154
2,166
4,320
828
985
1,397
2,409
2,424
2,612
2,574
2,536
2,290
1,426
1,036
737
21,255
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809
3,838
12
13
Net CSIP Increase

23
24
25
26
Feb
1,678

(2009-2013)15
889
619
389
(367)
70
(331)
63
(367)
70
0
414
67
(0)
368
70
0
614
67
(0)
474
70
(0)
442
70
0
278
67
Oct
336
648
959
(367)
70
(355)
67
(367)
70
Total
436
821
Notes
CSIP-GWR-use28JUL15.xlsx/Normal_Full_RW RUWAP
8/14/2015
Table 4C: Source Water Analysis for the Pure Water Monterey Groundwater Replenishment Project
Diversion Pattern for a Drought Year Starting with a Full Reserve, Full RUWAP Demand as Recycled Water
SOURCES
Jan
1,725
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5
6
7
5 Percolation
6
7
8

Blanco Drain 9
DEMANDS
TOTAL CSIP Demand
Use of Source Water
May
1,722
June
1,675
July
1,748
Aug
1,773
Sep
1,715
Oct
1,690
Nov
1,634
Dec
1,612
7/28/2015
Total
20,090
158
201
307
311
391
435
444
367
410
329
223
3,732
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
17
17
0
14
14
0
11
11
0
5
0
5
1
0
1
0
0
0
0
0
0
0
0
0
1
0
1
3
3
0
8
8
0
16
16
0
76
69
7
11
36
(12)
(16)
(29)
(41)
(46)
(52)
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
(143)
(138)
(143)
(1,257)
550
0
0
584
0
0
628
0
0
452
0
312
163
100
412
(27)
0
391
0
0
435
0
0
444
0
0
368
245
0
0
433
0
0
521
0
0
100
2,362
246
252
225
274
277
244
184
168
133
2,003
165
162
97
132
129
121
80
87
98
1,071
0
0
0
0
0
0
142
0
553
154
0
880
145
0
879
67
0
864
66
0
907
62
0
871
41
0
673
45
0
300
50
0
281
0
0
0
772
0
6,208
1,725
1,494
2,198
2,537
2,601
2,539
2,655
2,644
2,388
1,990
1,915
1,612
26,297
Jan
0
509
509
Feb
692
9
701
Mar
1,558
221
1,779
Apr
1,669
242
1,911
May
1,799
1,197
2,996
June
1,675
1,261
2,936
July
1,786
1,303
3,089
Aug
1,803
1,025
2,828
Sep
1,725
453
2,178
Oct
1,548
165
1,713
Nov
1,127
35
1,162
Dec
88
730
818
Total
15,469
7,150
22,619
81
74
81
156
161
156
161
161
156
81
79
81
1427
367
331
367
133
137
133
137
137
133
367
355
367
2,963
0
367
0
331
0
367
133
137
133
137
137
133
0
367
0
355
0
367
0
2,963
957
1,106
2,228
2,199
3,294
3,225
3,387
3,126
2,467
2,161
1,595
1,266
27,010
Jan
Feb
Mar
Apr
May
June
July
Aug
Sep
Nov
Dec
509
0
509
701
0
701
1,564
186
1,750
1,501
747
2,248
1,561
742
2,303
1,519
731
2,251
1,587
770
2,357
1,612
734
2,346
1,560
540
2,100
1,541
0
1,541
1,162
0
1,162
818
0
818
15,635
4,451
20,085
4,616
81
74
81
156
161
156
161
161
156
81
79
81
1,427

Feedwater to AWT
0
367
0
367
0
331
0
331
367
0
0
367
0
0
133
133
0
0
137
137
0
0
133
133
0
0
137
137
0
0
137
137
0
0
133
133
300
67
0
367
281
74
0
355
0
367
0
367
948
1,206
809
2,963
876
1,032
2,117
2,381
2,440
2,383
2,494
2,483
2,233
1,908
1,517
1,185
23,049
1,725
802
87
142
507
1,607
4,870
12
13
Net CSIP Increase

23
24
25
26
Apr
1,657
156
18
15 MCWD RUWAP

Mar
1,645
156
0
9
10
11
Feb
1,494
Oct
Total

768
388
(367)
70
(331)
63
186
70
747
25
(0)
742
26
0
731
25
(0)
770
26
(0)
734
26
(0)
319
346
1,822
540
25
(67)
70
(74)
67
(367)
70
3,244
563
Notes
CSIP-GWR-use28JUL15.xlsx/Drought_FullResv_RW RUWAP
8/14/2015
Diversion Pattern for a Normal Water Year Building a Drought Reserve, Full RUWAP Demand as AWT Product
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5

7
5 Percolation

9
9 Blanco Drain
10

11
Feb
1,678
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/28/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
(12)
(16)
(29)
(41)
(46)
(52)
(143)
(129)
(143)
(138)
(143)
(138)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
252
225
274
162
97
132
0
0
0
0
0
0
0
0
0
154
0
923
145
0
880
67
0
1,036
1,798
1,678
1,867
2,719
2,730
14
24
132
(28)
(15)
(12)
(251)
(143)
(138)
(143)
(1,257)
0
0
444
0
0
369
253
0
0
466
0
0
605
0
0
304
2,579
277
244
184
1,456
129
121
80
721
66
0
907
62
0
871
41
0
674
0
0
0
0
0
0
0
0
0
535
0
5,291
2,835
2,800
2,759
2,487
1,844
1,762
1,776
27,055
0
0
435
DEMANDS
TOTAL CSIP Demand
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227

14
(200 AFY AWTF PRODUCT WATER)
18
17 FEEDWATER TO AWT FOR MCWD RUWAP
367
331
367
355
367
355
367
367
355
367
355
367
4,320
42
38
42
42
41
42
248
100
509
91
460
100
509
192
547
199
566
192
547
199
566
199
566
192
547
100
509
97
493
100
509
1761
6,329
Use of Source Water
Feb
1,539
Mar
2,335
Apr
2,652
May
2,903
June
2,951
July
2,923
Aug
2,545
Sep
1,568
Oct
1,174
879
23,556
Nov
Dec
654
0
654
1,030
0
1,030
1,604
568
2,172
1,652
513
2,165
1,607
681
2,288
1,695
540
2,235
1,689
504
2,193
1,621
319
1,940
1,059
0
1,059
681
0
681
370
0
370
14,122
3,125
17,247
4,292

Secondary effluent to AWT for MCWD RUWAP
Feedwater to AWT
0
409
0
100
509
0
369
0
91
460
0
409
0
100
509
0
0
355
192
547
0
0
367
199
566
0
0
355
192
547
0
0
367
199
566
0
0
367
199
566
0
0
355
192
547
0
409
0
100
509
0
396
0
97
493
0
409
0
100
509
0
2,401
2,166
1,761
6,328
970
1,115
1,539
2,719
2,730
2,835
2,800
2,759
2,487
1,568
1,174
879
23,576
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809

(2009-2013)15
Jan
1,115
461
0
461
12
13
Net CSIP Increase
22
23
24
25
26
970
Total
827
563
328
(0)
275
588
897
3,479
(409)
97
(369)
87
(409)
97
568
104
513
107
681
104
540
107
504
107
319
104
(409)
97
(396)
94
(409)
97
724
1,202
Notes
7 Table 4, Ibid.
10 Max. diversion = 6 cfs. See REVISED DRAFT RECLAMATION DITCH YIELD STUDY, Schaaf and Wheeler, March 2015. Note that flow figures shown here are a combination of flow estimates in the S&W analysis
made for the 2 cfs instream requirement Jan-May and 1 cfs instream requirement for June-Dec.
CSIP-GWR-use28JUL15.xlsx/Normal_Building_AWT RUWAP
8/14/2015
Diversion Pattern for a Normal Water Year with a Full Reserve, Full RUWAP Demand as AWT Product
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5

7
5 Percolation

9
9 Blanco Drain
10

11
Feb
1,678
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/28/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
(12)
(16)
(29)
(41)
(46)
(52)
(143)
(129)
(143)
(138)
(143)
(138)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
252
225
274
162
97
132
0
0
0
0
0
0
0
0
0
0
0
769
0
0
735
0
0
969
1,798
1,678
1,867
2,565
2,585
14
24
132
(28)
(15)
(12)
(251)
(143)
(138)
(143)
(1,257)
0
0
444
0
0
369
253
0
0
466
0
0
605
0
0
304
2,579
277
244
184
1,456
129
121
80
721
0
0
841
0
0
809
0
0
633
0
0
0
0
0
0
0
0
0
0
0
4,756
2,768
2,734
2,697
2,446
1,844
1,762
1,776
26,520
0
0
435
DEMANDS
TOTAL CSIP Demand
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227

14
18
367
331
367
355
367
355
367
367
355
367
355
367
4,320
192
547
199
566
192
547
199
566
199
566
192
547
100
467
Use of Source Water
928
1,077
Feb
0
100
467
1,497
Mar
2,335
Apr
2,652
May
2,903
June
2,951
July
2,923
Aug
2,545
Sep
1,526
Oct
0
97
452
1,133
0
100
467
837
0
1761
6,081
23,308
Nov
Dec
654
0
654
1,030
0
1,030
1,604
414
2,018
1,652
368
2,020
1,607
614
2,221
1,695
474
2,169
1,689
442
2,131
1,621
278
1,899
1,059
0
1,059
681
0
681
370
0
370
14,122
2,590
16,712
3,757

Feedwater to AWT
0
367
0
100
467
0
331
0
91
422
0
367
0
100
467
0
0
355
192
547
0
0
367
199
566
0
0
355
192
547
0
0
367
199
566
0
0
367
199
566
0
0
355
192
547
0
367
0
100
467
0
355
0
97
452
0
367
0
100
467
0
2,154
2,166
1,761
6,081
928
1,077
1,497
2,565
2,585
2,768
2,734
2,697
2,446
1,526
1,133
837
22,793
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809

(2009-2013)15
Jan
0
91
422
461
0
461
12
13
Net CSIP Increase
22
23
24
25
26
0
100
467
Total
870
602
370
(0)
317
629
940
3,727
(367)
89
(331)
80
(367)
89
414
104
368
107
614
104
474
107
442
107
278
104
(367)
89
(355)
86
(367)
89
436
1,155
Notes
7 Table 4, Ibid.
CSIP-GWR-use28JUL15.xlsx/Normal_Full_AWT RUWAP
8/14/2015
Diversion Pattern for a Drought Year, Starting with a Full Drought Reserve, Full RUWAP Demand as AWT Product
SOURCES
Jan
1,725
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5

7
5 Percolation

9
9 Blanco Drain
July
1,748
Aug
1,773
Sep
1,715
Oct
1,690
Nov
1,634
Dec
1,612
7/28/2015
Total
20,090
201
307
311
391
435
444
367
410
329
223
3,732
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
17
17
0
14
14
0
11
11
0
5
0
5
1
0
1
0
0
0
0
0
0
0
0
0
1
0
1
3
3
0
8
8
0
16
16
0
76
69
7
11
(12)
(16)
(29)
(41)
(46)
(52)
(143)
(129)
(143)
(138)
(143)
(138)
550
0
0
584
0
0
628
0
0
452
0
312
163
100
412
(27)
0
391
0
0
435
0
0
444
0
0
368
246
252
225
274
277
244
165
162
97
132
129
121
0
0
0
0
0
0
142
0
553
154
0
880
145
0
879
67
0
864
66
0
907
1,725
1,494
2,198
2,537
2,601
2,539
Mar
1,558
221
1,779
Apr
1,669
242
1,911
May
1,799
1,197
2,996
June
1,675
1,261
2,936
Feb
692
9
701

14
18
367
331
22
23
24
25
26
June
1,675
158
Jan
0
509
509
12
13
Net CSIP Increase
May
1,722
158
0
DEMANDS
TOTAL CSIP Demand
Use of Source Water
Apr
1,657
156
10
Mar
1,645
156
0

11
Feb
1,494
0
100
467
976
Jan
0
91
422
1,123
Feb
367
36
(28)
(15)
(12)
(251)
(143)
(138)
(143)
(1,257)
245
0
0
433
0
0
521
0
0
100
2,362
184
168
133
2,003
80
87
98
1,071
62
0
871
41
0
673
45
0
300
50
0
281
0
0
0
772
0
6,208
2,655
2,644
2,388
1,990
1,915
1,612
26,297
July
1,786
1,303
3,089
Aug
1,803
1,025
2,828
Sep
1,725
453
2,178
Oct
1,548
165
1,713
Nov
1,127
35
1,162
133
137
133
137
137
133
367
192
325
199
336
192
325
199
336
199
336
192
325
100
467
0
100
467
2,247
Mar
2,236
Apr
3,332
May
3,261
June
3,424
July
3,164
Aug
2,503
Sep
2,180
Oct
355
0
97
452
1,614
Nov
Dec
88
730
818
Total
15,469
7,150
22,619
367
2,963
0
100
467
1,285
0
1761
4,724
27,344
Dec
Total
509
0
509
701
0
701
1,545
186
1,731
1,464
747
2,212
1,523
742
2,265
1,483
731
2,214
1,550
770
2,320
1,575
734
2,309
1,523
540
2,063
1,522
0
1,522
1,162
0
1,162
818
0
818
15,375
4,451
19,825
4,356

Feedwater to AWT
0
367
0
100
467
0
331
0
91
422
367
0
0
100
467
0
0
133
192
325
0
0
137
199
336
0
0
133
192
325
0
0
137
199
336
0
0
137
199
336
0
0
133
192
325
300
67
0
100
467
281
74
0
97
452
0
367
0
100
467
948
1,206
809
1,761
4,724
976
1,123
2,198
2,537
2,601
2,539
2,655
2,644
2,388
1,990
1,614
1,285
24,550
1,725
802
87
142
507
1,607
4,870

749
371
(0)
(0)
301
327
1,748
(367)
89
(331)
80
186
89
747
62
742
64
731
62
770
64
734
64
540
62
(67)
89
(74)
86
(367)
89
3,244
898
Notes
7 Table 4, Ibid.
CSIP-GWR-use28JUL15.xlsx/Drought_FullResv_AWT RUWAP
8/14/2015
Diversion Patterns for a Normal Water Year, Building a Drought Reserve, Initial RUWAP Demand as Recycled Water
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5
6
7
5 Percolation
6
7
8

Blanco Drain 9
9
10
11
DEMANDS
TOTAL CSIP Demand
18
15 MCWD RUWAP

Use of Source Water
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/28/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
14
24
132
(12)
(16)
(29)
(41)
(46)
(52)
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
(143)
(138)
(143)
(1,257)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
0
0
435
0
0
444
0
0
369
253
0
0
466
0
0
605
0
0
304
2,579
252
225
274
277
244
184
1,456
162
97
132
129
121
80
721
0
0
0
0
0
0
0
0
0
154
0
923
145
0
880
67
0
1,036
66
0
907
62
0
871
41
0
674
0
0
0
0
0
0
0
0
0
535
0
5,291
1,798
1,678
1,867
2,719
2,730
2,835
2,800
2,759
2,487
1,844
1,762
1,776
27,055
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227
31
28
31
59
61
59
61
61
59
31
30
31
540
367
331
367
355
367
355
367
367
355
367
355
367
4,320
42
409
38
369
42
409
355
367
355
367
367
355
42
409
41
396
42
409
248
4,568
901
1,052
1,470
2,202
2,515
2,770
2,813
2,785
2,412
1,499
1,107
809
22,335
Jan
Feb
Mar
Apr
May
June
July
Aug
Sep
Nov
Dec
461
0
461
654
0
654
1,030
0
1,030
1,737
568
2,305
1,789
513
2,302
1,740
681
2,421
1,833
540
2,373
1,827
504
2,331
1,754
319
2,073
1,059
0
1,059
681
0
681
370
0
370
14,935
3,125
18,060
5,104
31
28
31
59
61
59
61
61
59
31
30
31
540

Feedwater to AWT
0
409
0
409
0
369
0
369
0
409
0
409
0
0
355
355
0
0
367
367
0
0
355
355
0
0
367
367
0
0
367
367
0
0
355
355
0
409
0
409
0
396
0
396
0
409
0
409
0
2,401
2,166
4,567
870
1,024
1,439
2,660
2,669
2,776
2,740
2,698
2,428
1,468
1,077
779
22,627
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809
3,888
12
13
Net CSIP Increase

23
24
25
26
Feb
1,678

(2009-2013)15
897
627
397
(409)
78
(369)
70
(409)
78
0
568
67
(0)
513
70
0
681
67
(0)
540
70
(0)
504
70
0
319
67
Oct
345
656
967
(409)
78
(396)
75
(409)
78
Total
724
868
Notes
18 RUWAP supply comes from existing RTP inflows, demands reflect existing urban irrigation customers along trunk main.
CSIP-GWR-use28JUL15-Initial RUWAP.xlsx/Normal_Building_RW RUWAP
8/14/2015
Diversion Pattern for a Normal Water Year when the Drought Reserve is Full, Initial RUWAP Demand as Recycled Water
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5
6
7
5 Percolation
6
7
8

Blanco Drain 9
9
10
11
DEMANDS
TOTAL CSIP Demand
18
15 MCWD RUWAP

Use of Source Water
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/28/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
14
24
132
(12)
(16)
(29)
(41)
(46)
(52)
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
(143)
(138)
(143)
(1,257)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
0
0
435
0
0
444
0
0
369
253
0
0
466
0
0
605
0
0
304
2,579
252
225
274
277
244
184
1,456
162
97
132
129
121
80
721
0
0
0
0
0
0
0
0
0
0
0
769
0
0
735
0
0
969
0
0
841
0
0
809
0
0
633
0
0
0
0
0
0
0
0
0
0
0
4,756
1,798
1,678
1,867
2,565
2,585
2,768
2,734
2,697
2,446
1,844
1,762
1,776
26,520
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227
31
28
31
59
61
59
61
61
59
31
30
31
540
367
331
367
355
367
355
367
367
355
367
355
367
4,320
0
367
0
331
0
367
355
367
355
367
367
355
0
367
0
355
0
367
0
4,320
859
1,013
1,428
2,202
2,515
2,770
2,813
2,785
2,412
1,457
1,066
767
22,087
Jan
Feb
Mar
Apr
May
June
July
Aug
Sep
Nov
Dec
461
0
461
654
0
654
1,030
0
1,030
1,737
414
2,151
1,789
368
2,157
1,740
614
2,354
1,833
474
2,307
1,827
442
2,269
1,754
278
2,032
1,059
0
1,059
681
0
681
370
0
370
14,935
2,590
17,525
4,569
31
28
31
59
61
59
61
61
59
31
30
31
540

Feedwater to AWT
0
367
0
367
0
331
0
331
0
367
0
367
0
0
355
355
0
0
367
367
0
0
355
355
0
0
367
367
0
0
367
367
0
0
355
355
0
367
0
367
0
355
0
355
0
367
0
367
0
2,154
2,166
4,320
828
985
1,397
2,506
2,524
2,709
2,674
2,636
2,387
1,426
1,036
737
21,845
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809
387
696
1,009
4,135
(367)
70
(355)
67
12
13
Net CSIP Increase

23
24
25
26
Feb
1,678

(2009-2013)15
939
665
439
(367)
70
(331)
63
(367)
70
0
414
67
(0)
368
70
0
614
67
(0)
474
70
(0)
442
70
0
278
67
Oct
(367)
70
Total
436
821
Notes
CSIP-GWR-use28JUL15-Initial RUWAP.xlsx/Normal_Full_RW RUWAP
8/14/2015
Diversion Pattern for a Drought Year Starting with a Full Reserve, Initial RUWAP Demand as Recycled Water
SOURCES
Jan
1,725
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5
6
7
5 Percolation
6
7
8

Blanco Drain 9
DEMANDS
TOTAL CSIP Demand
Use of Source Water
May
1,722
June
1,675
July
1,748
Aug
1,773
Sep
1,715
Oct
1,690
Nov
1,634
Dec
1,612
7/28/2015
Total
20,090
158
201
307
311
391
435
444
367
410
329
223
3,732
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
17
17
0
14
14
0
11
11
0
5
0
5
1
0
1
0
0
0
0
0
0
0
0
0
1
0
1
3
3
0
8
8
0
16
16
0
76
69
7
11
36
(12)
(16)
(29)
(41)
(46)
(52)
(28)
(15)
(12)
(251)
(143)
(129)
(143)
(138)
(143)
(138)
(143)
(138)
(143)
(1,257)
550
0
0
584
0
0
628
0
0
452
0
312
163
100
412
(27)
0
391
0
0
435
0
0
444
0
0
368
245
0
0
433
0
0
521
0
0
100
2,362
246
252
225
274
277
244
184
168
133
2,003
165
162
97
132
129
121
80
87
98
1,071
0
0
0
0
0
0
142
0
553
154
0
880
145
0
879
67
0
864
66
0
907
62
0
871
41
0
673
45
0
300
50
0
281
0
0
0
772
0
6,208
1,725
1,494
2,198
2,537
2,601
2,539
2,655
2,644
2,388
1,990
1,915
1,612
26,297
Jan
0
509
509
Feb
692
9
701
Mar
1,558
221
1,779
Apr
1,669
242
1,911
May
1,799
1,197
2,996
June
1,675
1,261
2,936
July
1,786
1,303
3,089
Aug
1,803
1,025
2,828
Sep
1,725
453
2,178
Oct
1,548
165
1,713
Nov
1,127
35
1,162
Dec
88
730
818
Total
15,469
7,150
22,619
31
28
31
59
61
59
61
61
59
31
30
31
540
367
331
367
133
137
133
137
137
133
367
355
367
2,963
0
367
0
331
0
367
133
137
133
137
137
133
0
367
0
355
0
367
0
2,963
907
1,060
2,177
2,102
3,194
3,128
3,287
3,026
2,370
2,111
1,547
1,215
26,123
Jan
Feb
Mar
Apr
May
June
July
Aug
Sep
Nov
Dec
509
0
509
701
0
701
1,614
186
1,800
1,598
747
2,345
1,661
742
2,403
1,616
731
2,347
1,687
770
2,457
1,712
734
2,446
1,656
540
2,197
1,592
0
1,592
1,162
0
1,162
818
0
818
16,326
4,451
20,777
5,307
31
28
31
59
61
59
61
61
59
31
30
31
540

Feedwater to AWT
0
367
0
367
0
331
0
331
367
0
0
367
0
0
133
133
0
0
137
137
0
0
133
133
0
0
137
137
0
0
137
137
0
0
133
133
300
67
0
367
281
74
0
355
0
367
0
367
948
1,206
809
2,963
876
1,032
2,167
2,478
2,540
2,480
2,594
2,583
2,329
1,959
1,517
1,185
23,740
1,725
802
87
142
507
1,607
4,870
368
396
2,017
(67)
70
(74)
67
(367)
70
3,244
563
12
13
Net CSIP Increase

23
24
25
26
Apr
1,657
156
18
15 MCWD RUWAP

Mar
1,645
156
0
9
10
11
Feb
1,494
Oct
Total

819
434
(367)
70
(331)
63
186
70
747
25
(0)
742
26
0
731
25
(0)
770
26
(0)
734
26
0
540
25
Notes
CSIP-GWR-use28JUL15-Initial RUWAP.xlsx/Drought_FullResv_RW RUWAP
8/14/2015
Diversion Pattern for a Normal Water Year Building a Drought Reserve, Initial RUWAP Demand as AWT Product
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5

7
5 Percolation

9
9 Blanco Drain
10

11
Feb
1,678
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/28/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
(12)
(16)
(29)
(41)
(46)
(52)
(143)
(129)
(143)
(138)
(143)
(138)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
252
225
274
162
97
132
0
0
0
0
0
0
0
0
0
154
0
923
145
0
880
67
0
1,036
1,798
1,678
1,867
2,719
2,730
14
24
132
(28)
(15)
(12)
(251)
(143)
(138)
(143)
(1,257)
0
0
444
0
0
369
253
0
0
466
0
0
605
0
0
304
2,579
277
244
184
1,456
129
121
80
721
66
0
907
62
0
871
41
0
674
0
0
0
0
0
0
0
0
0
535
0
5,291
2,835
2,800
2,759
2,487
1,844
1,762
1,776
27,055
0
0
435
DEMANDS
TOTAL CSIP Demand
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227

14
18
367
331
367
355
367
355
367
367
355
367
355
367
4,320
42
38
42
42
41
42
248
38
447
35
404
38
447
73
428
75
442
73
428
75
442
75
442
73
428
38
447
37
432
38
447
666
5,234
Use of Source Water
Feb
1,477
Mar
2,216
2,529
Apr
May
2,784
June
2,827
July
2,800
Aug
2,426
Sep
1,506
Oct
1,114
817
22,462
Nov
Dec
654
0
654
1,030
0
1,030
1,723
568
2,291
1,775
513
2,288
1,726
681
2,407
1,818
540
2,358
1,813
504
2,317
1,740
319
2,059
1,059
0
1,059
681
0
681
370
0
370
14,851
3,125
17,976
5,020

Feedwater to AWT
0
409
0
38
447
0
369
0
35
404
0
409
0
38
447
0
0
355
73
428
0
0
367
75
442
0
0
355
73
428
0
0
367
75
442
0
0
367
75
442
0
0
355
73
428
0
409
0
38
447
0
396
0
37
432
0
409
0
38
447
0
2,401
2,166
666
5,234
908
1,058
1,477
2,719
2,730
2,835
2,800
2,759
2,487
1,506
1,114
817
23,210
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809

(2009-2013)15
Jan
1,058
461
0
461
12
13
Net CSIP Increase
22
23
24
25
26
908
Total
890
620
390
(0)
(0)
(0)
337
649
960
3,846
(409)
85
(369)
77
(409)
85
568
81
513
84
681
81
540
84
504
84
319
81
(409)
85
(396)
82
(409)
85
724
994
Notes
7 Table 4, Ibid.
CSIP-GWR-use28JUL15-Initial RUWAP.xlsx/Normal_Building_AWT RUWAP
8/14/2015
Diversion Pattern for a Normal Water Year with a Full Reserve, Initial RUWAP Demand as AWT Product
SOURCES
Jan
1,798
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5

7
5 Percolation

9
9 Blanco Drain
10

11
Feb
1,678
Mar
1,867
Apr
1,796
May
1,850
June
1,799
July
1,893
Aug
1,888
Sep
1,813
Oct
1,844
Nov
1,762
Dec
1,776
7/28/2015
Total
21,764
156
158
201
307
311
391
435
444
367
410
329
223
3,732
156
0
158
0
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
52
52
0
41
41
0
34
34
0
16
0
16
2
0
2
0
0
0
0
0
0
0
0
0
2
0
2
8
8
0
23
23
0
47
47
0
225
205
20
26
24
21
11
(12)
(16)
(29)
(41)
(46)
(52)
(143)
(129)
(143)
(138)
(143)
(138)
684
0
0
763
0
0
847
0
0
647
32
355
362
100
413
0
172
563
252
225
274
162
97
132
0
0
0
0
0
0
0
0
0
0
0
769
0
0
735
0
0
969
1,798
1,678
1,867
2,565
2,585
14
24
132
(28)
(15)
(12)
(251)
(143)
(138)
(143)
(1,257)
0
0
444
0
0
369
253
0
0
466
0
0
605
0
0
304
2,579
277
244
184
1,456
129
121
80
721
0
0
841
0
0
809
0
0
633
0
0
0
0
0
0
0
0
0
0
0
4,756
2,768
2,734
2,697
2,446
1,844
1,762
1,776
26,520
0
0
435
DEMANDS
TOTAL CSIP Demand
Jan
13
448
461
Feb
459
195
654
Mar
726
304
1,030
Apr
1,376
412
1,788
May
1,763
324
2,087
June
1,750
606
2,356
July
1,866
519
2,385
Aug
1,854
504
2,358
Sep
1,698
300
1,998
Oct
984
75
1,059
Nov
448
233
681
Dec
18
352
370
Total
12,955
4,272
17,227

14
18
367
331
367
355
367
355
367
367
355
367
355
367
4,320
73
428
75
442
73
428
75
442
75
442
73
428
38
405
Use of Source Water
866
1,020
Feb
0
38
405
1,435
Mar
2,216
2,529
Apr
May
2,784
June
2,827
July
2,800
Aug
2,426
Sep
1,464
Oct
0
37
392
1,073
0
38
405
774
0
666
4,986
22,214
Nov
Dec
654
0
654
1,030
0
1,030
1,723
414
2,137
1,775
368
2,143
1,726
614
2,340
1,818
474
2,292
1,813
442
2,255
1,740
278
2,018
1,059
0
1,059
681
0
681
370
0
370
14,851
2,590
17,441
4,485

Feedwater to AWT
0
367
0
38
405
0
331
0
35
366
0
367
0
38
405
0
0
355
73
428
0
0
367
75
442
0
0
355
73
428
0
0
367
75
442
0
0
367
75
442
0
0
355
73
428
0
367
0
38
405
0
355
0
37
392
0
367
0
38
405
0
2,154
2,166
666
4,986
866
1,020
1,435
2,565
2,585
2,768
2,734
2,697
2,446
1,464
1,073
774
22,427
1,785
1,219
1,141
420
88
49
27
34
114
859
1,314
1,759
8,809

(2009-2013)15
Jan
0
35
366
461
0
461
12
13
Net CSIP Increase
22
23
24
25
26
0
38
405
Total
932
658
432
(0)
(0)
(0)
380
689
1,002
4,093
(367)
77
(331)
69
(367)
77
414
81
368
84
614
81
474
84
442
84
278
81
(367)
77
(355)
74
(367)
77
436
947
Notes
7 Table 4, Ibid.
CSIP-GWR-use28JUL15-Initial RUWAP.xlsx/Normal_Full_AWT RUWAP
8/14/2015
Diversion Pattern for a Drought Year, Starting with a Full Drought Reserve, Initial RUWAP Demand as AWT Product
SOURCES
Jan
1,725
New Source Water
City of Salinas
2
AWW directly to RTP
4
Urban runoff to RTP
5

7
5 Percolation

9
9 Blanco Drain
July
1,748
Aug
1,773
Sep
1,715
Oct
1,690
Nov
1,634
Dec
1,612
7/28/2015
Total
20,090
201
307
311
391
435
444
367
410
329
223
3,732
201
0
0
307
0
311
0
391
0
435
0
444
0
367
410
0
329
0
223
0
1,477
2,255
17
17
0
14
14
0
11
11
0
5
0
5
1
0
1
0
0
0
0
0
0
0
0
0
1
0
1
3
3
0
8
8
0
16
16
0
76
69
7
11
(12)
(16)
(29)
(41)
(46)
(52)
(143)
(129)
(143)
(138)
(143)
(138)
550
0
0
584
0
0
628
0
0
452
0
312
163
100
412
(27)
0
391
0
0
435
0
0
444
0
0
368
246
252
225
274
277
244
165
162
97
132
129
121
0
0
0
0
0
0
142
0
553
154
0
880
145
0
879
67
0
864
66
0
907
1,725
1,494
2,198
2,537
2,601
2,539
Mar
1,558
221
1,779
Apr
1,669
242
1,911
May
1,799
1,197
2,996
June
1,675
1,261
2,936
Feb
692
9
701

14
18
367
331
22
23
24
25
26
June
1,675
158
Jan
0
509
509
12
13
Net CSIP Increase
May
1,722
158
0
DEMANDS
TOTAL CSIP Demand
Use of Source Water
Apr
1,657
156
10
Mar
1,645
156
0

11
Feb
1,494
0
38
405
914
Jan
0
35
366
1,066
Feb
367
36
(28)
(15)
(12)
(251)
(143)
(138)
(143)
(1,257)
245
0
0
433
0
0
521
0
0
100
2,362
184
168
133
2,003
80
87
98
1,071
62
0
871
41
0
673
45
0
300
50
0
281
0
0
0
772
0
6,208
2,655
2,644
2,388
1,990
1,915
1,612
26,297
July
1,786
1,303
3,089
Aug
1,803
1,025
2,828
Sep
1,725
453
2,178
Oct
1,548
165
1,713
Nov
1,127
35
1,162
133
137
133
137
137
133
367
73
205
75
212
73
205
75
212
75
212
73
205
38
405
0
38
405
2,184
Mar
2,116
3,208
Apr
May
3,142
June
3,301
July
3,040
Aug
2,384
Sep
2,118
Oct
355
0
37
392
1,554
Nov
Dec
88
730
818
Total
15,469
7,150
22,619
367
2,963
0
38
405
1,222
0
666
3,630
26,249
Dec
Total
509
0
509
701
0
701
1,607
186
1,793
1,584
747
2,331
1,647
742
2,389
1,602
731
2,334
1,673
770
2,443
1,698
734
2,432
1,643
540
2,183
1,585
0
1,585
1,162
0
1,162
818
0
818
16,228
4,451
20,678
5,209

Feedwater to AWT
0
367
0
38
405
0
331
0
35
366
367
0
0
38
405
0
0
133
73
205
0
0
137
75
212
0
0
133
73
205
0
0
137
75
212
0
0
137
75
212
0
0
133
73
205
300
67
0
38
405
281
74
0
37
392
0
367
0
38
405
948
1,206
809
666
3,630
914
1,066
2,198
2,537
2,601
2,539
2,655
2,644
2,388
1,990
1,554
1,222
24,308
1,725
802
87
142
507
1,607
4,870

811
428
(0)
(0)
(0)
361
389
1,990
(367)
77
(331)
69
186
77
747
39
742
40
731
39
770
40
734
40
540
39
(67)
77
(74)
74
(367)
77
3,244
690
Notes
7 Table 4, Ibid.
CSIP-GWR-use28JUL15-Initial RUWAP.xlsx/Drought_FullResv_AWT RUWAP
8/14/2015
FinalEIR
September2015
AppendixCC
FishPassageAnalysis,ReclamationDitchatSanJonRoad
andGalibanCreekatLaurelRd
FinalEIR
September2015
FinalEIR
September2015
3 Quail R
Run Circle, Suiite 101
Salinnas, CA 939077-2348
(831) 8333-4848
F
FAX (831) 8333-2424
swmb@swssv.com
TEC
CHNICALMEMOR
RANDUM
TO:BobH
Holden,MRW
WPCA
FROM: AndrewA.Ste
A
erbenz,PE;A
AndrewRacz,EIT
D
DATE:Septem
mber16,2015
JO
OB#:MRWP
P.01.14:004
SUBJECT:FishPassage
eAnalysis:R
ReclamationD
DitchatSanJJonRd.andG
GabilanCreekkatLaurelRd
d.
____________
___________
____________
__________________________________________________
________
INTRODU
UCTION:
Thistechn
nicalmemoassesseshydraaulicconditio
onsthroughsttructuresthatmayposeasobstaclesto
o
upstreamanddownstrreamanadram
mousfishmiggrationintheeReclamation
nDich/GabilanCreek
watershed
d.Twositesareanalyzed:theReclamationDitchatttheSanJonRoadbridge//weir,andGaabilan
CreekatttheLaurelRoaadculvert.Thepurposeo
oftheanalysissistodeterm
mine(1)wheth
herthese
structuressposeobstacclestofishpassage,andifso,underwhhatrangeofflows,(2)wheetherwithdrawals
ofupto6
6cfsfromtheReclamation
nDitchforthe
ePureWater MontereyGrroundwaterR
Replenishmen
nt
Projectwillreducethe
elikelihoodofffishpassage
ebetweenMoontereyBayaandupstream
mhabitat,and
d(3)if
thisisfoundtobethecase,therangeofflowsattwhichwithddrawalsshouldbecurtaileedinorderto
maintainfishpassage.
NDITCHATSA
ANJONROAD
SITE1:REECLAMATION
ThestructtureatSanJo
onRd.isasinglespanconccretebridgeooveratrapezzoidalconcrettelinedchannel.
Thelowchordoftheb
bridgesitsapp
proximately1
10abovetheechannelbed
d,andchanneelscrosssection
tapersfro
om40belowthebridgede
eckto12atiitsbase.Flow
wthroughtheeculvertisfu
urtherconstriccted
byaflowgage(USGS1
11152650)consistingofarectangularlyynotchedcon
ncreteweir,d
dimenstions8
8
pstreamsideooftheweir.O
Onitsdownsttreamside,th
he
widex2high.Thereisa0.6deeplipontheup
hargesontoaaconcreteaprronthatwide
ensfrom8too12andexperiencesaveerticaldropoff
weirdisch
approximately1.0ove
er20.5offlowdistance.TTheaprondisschargesonto
oariprap(1224boulders)
linedchan
nnel.Riprapextendsapprroximately24
4downstream
m,andthestrreambedelevvationdropsaan
additional2.4overthiisdistance.D
Downstreamo
oftheriprap,,thechannelbedtransitio
onstodepositted
peflattenssiggnificantly.
sediment,,andtheslop
FishXingM
Model:
FishXingvv3.0isapubliclyavailablemodelingpro
ogramfromttheUSForesttService.Theeprogramallows
theuserttomodelflow
wthroughvariousstream/rroadcrossinggstructures.Italsoallowsstheuserto
evaluatettheabilityoffishandothe
eraquaticspe
eciestonavigaatethesestru
ucturesbased
donspecies
specificphysiologicalp
parameterssu
uchasminimumrequired waterdepth,,swimmingspeedand
endurance.FishXingw
wasinitiallyussedtocalculaatewatersurffaceprofilestthroughtheSSanJonRoadweir
todeterm
minewhatran
ngesofflowsmightallowfforsuccessfullupstreampaassageofadu
ultsteelhead.
Foradultsteelhead,th
hefollowingd
defaultspecie
esparametersswereused:
To:BobHo
olden,MRWPC
CA
September16
6,2015
Le
ength:18
ProlongedSpe
eed:8ft/s;
Prolongedtimetoexhaustion:10min
16ft/s
BurstSpeed:1
Bursttimetoe
exhaustion:5
5s
Minimumdept
M
th:0.5ft
Maximumleap
M
pspeed:16fft/s
Asimplem
modelofflow
wthrouha2x8concretechannelreprresentingtheenotchoftheeweirwascreeated
inFishXing.Resultsind
dicatedthatm
migratingstee
elheadcould traversetheweiratflowssbetween45
5
150cfs.A
Atlowerflowrates,waterdepthwasin
nsufficientto allowfishpasssage.Athiggherflowratees,
highveloccitiesresulted
dinfishexhau
ustion.
ultsfor45cfssofflowthro ughtherectaangularweiraatSanJonRo
oad,
Figure1:Watersurfacceprofileresu
dbyFishXing..
generated
TheFishXingmodelisaanoversimpliificationofth
heSanJonRooadweirgeom
metry.Thissimplemodel
depictson
nlythenotchoftheweir.Itdoesnotaccuratelydeppictflowbehaaviorwhenbackwater
overtopsthenotch,no
ordoesitconsiderhowflo
owbehavessddownstreamoftheweirasitcrossesovver
theconcreteapronandriprap.Fielldobservationshaveshow
wnthat,begin
nningatappro
oximately70cfs,
eweirnotch,andbeginsooccupyingtheeentirecrosssectionalwid
dthof
flowovertopsthe2hiighwallofthe
heupperbou
undforfishpaassageascalcculatedbyFisshXing(150cffs)is
theculverrt(seeFigure2B).Thus,th
notareliaableresult.A
Atlowerflowss,theshallow
westwaterdeepthsthatimp
pedeupstreamfishmigrattion
havebeen
nobservedto
ooccurnotth
hroughthewe
eirnotch,buttoverthecon
ncreteapron.Inshort,thee
geometryyoftheSanJo
onRoadstrucctureistooco
omplicatedtoomodelusinggFishXing.In
nthefollowing
section,w
wecreateam
moredetailedandreliableH
HydrologicEnngineeringCeentersRiverA
AnalysisSystem
(HECRAS)modeltomorepreciselydeterminepassageflows..
2
To:BobHolden,MRWPCA
September16,2015
HECRASModelDesign:
Theweir,apronandriprapweresurveyedinthefield,andindividualcrosssectionsrepresentingthese
featuresgeometryandroughnesswerecreatedinthemodel.Thebridgeovertheweir/culvertwasnot
modeled,asflowratesinquestiondonotreachtheheightofthebridgedeckslowchord.Cross
sectionsapproximately500upstreamanddownstreamofthebridgewereimportedfromtheexisting
regionalmodeloftheReclamationDitchwatershed.Bedslopesattheseoutlyingcrosssectionswere
usedtodeterminethemodelsboundaryconditonsusingnormaldepth.Flowwasmodeledfor10flow
ratesbetween10and240cfs(Table1).Forreference,the10yearstormeventatthislocationis>600
cfs(FEMAFloodStudy).
ModelResults:
Weir:Atflowratesbelowapproximately70cfs,allflowpassesthroughtherectangularnotchofthe
weir.Whenflowsexceedthisvalue,theweirisovertoppedandflowoccupiestheentirechannelwidth.
Thisresultisinlinewithfieldobservations(seeFigure2Bbelow).
Apron:Inallcases,theconcreteaproncontainsthepointofshallowestflow.Atflowratesbelow
approximately240cfs,theshallowestflowisatthedownstreamlipoftheapron.Athigherflows,depth
isshallowestimmediatelybelowtheweir.Flowdepthovertheapronincreaseswithflowrate,froma
depthofabout2at10cfsto>1whenflowexceedsapproximately160cfs.
Atallflowrates,flowvelocityreachesitsmaximumatthedownstreamlipoftheapron.Flowvelocities
atthislocationrangefromapproximately5ft/satQ=10cfs,to>12ft/satQ=240cfs.Acrosssectional
profileofflowshowsthefastestvelocitiesalongthecenterlineoftheapron,whereflowremains
supercriticalforallflowrates.Flowtransitionstosubcriticalattheapronripraptransition,aswellas
alongthemarginsoftheapron(seeFigure2photos).Asaresultofthisphenomenon,theapronnever
becomesfullysumbergedbytailwaterinthedownstreamchannel,evenatveryhighdischargerates.
Riprap:Flowtransitionsfromsupercriticaltosubcriticalovertheripriplinedchannelimmediately
downstreamoftheweir.Thistransitionoccursclosertotheapronatlowflowsandfartherdownstream
athigherflows.Atflowratesbelowapproximately150cfs,thelongitudinalwatersurfaceprofileover
theriprapispositive,andwatercascadesdownstreamovertheriprap.Ataround150cfs,thewater
surfaceprofileovertheriprapisparalleltothatofthetailwater.Asflowratesincreasetoabove150cfs,
thehydraulicjumppropogatesdownstream,andthewatersurfaceprofileovertheripraptiltsupstream
towardthelipoftheapron.
FishPassageAnalysis:
TypicalflowvaluesintheReclamationDitchare<5cfs,withlargerflowsoccurringduringandafter
stormevents.Becauseurbanrunoffcomprisesasignificantportionoftheselargerflows,storm
hydrographsontheReclamationDitchexhibitcharacteristicallyflashybehavior,withstormpeaks
typicallyonlylastingfrom1248hours.FlowdepthscitedbyHagar(TechnicalMemo,2/28/15)forthe
passageofadultandjuvenilesalmonids(0.6and0.4respectively)occuratcorrespondingdischargesof
approximately75and40cfs(Figures3,4,6).Foradultupstreammigration,75cfsofflowcorresponds
toaflowvelocityof9ft/s(Figure5).Althoughthisflowistoorapidforsustainedupstreampropulsion,
highenoughspeedscanbeachievedforshortbursts(upto5secondstoclearthelengthofthe
approximately40footobstacle.Forthepurposesofthisstudy,wewillassumethatvelocitydoesnot
poseabarriertofishpassage,andwewillrelyonminimumflows.Inordertodivertupto6cfsofflow
whilestillmaintainingtherequired75and40cfsinstream,flowdiversionscouldoccurwhenflowsare
below75cfsorinexcessof81cfs(adultmigrationseason),andbelow40cfsorinexcessof46cfs
(juvenillemigration).
3
To:BobHo
olden,MRWPC
CA
September16
6,2015
(A)
(B)
Figure2:Fieldimagesofflowthrou
ughtheSanJonRoadweirratflowratessof(A)30cfssand(B)65cfs.
To:BobHolden,MRWPCA
September16,2015
Flowrate HECRAS
(cfs)
ID
10
PF1
20
PF2
30
PF3
50
PF4
70
PF5
100
PF6
130
PF7
160
PF8
200
PF9
240
PF10
Minimumflow
depth(ft)
0.17
0.27
0.35
0.48
0.58
0.72
0.85
0.97
1.12
1.22
Maximumflow
velocity(ft/s)
4.8
6.0
6.8
8.0
8.8
9.9
10.7
11.2
11.7
12.1
Table1:Minimumdepthsofflowandmaximumflowvelocitiesformodeledflowratesinthe
ReclamationDitchatSanJonRoad.
14.0
1.40
12.0
1.20
10.0
1.00
8.0
0.80
6.0
0.60
4.0
0.40
Maximumflowvelocity
2.0
Minimumflowdepth(feet)
Maximumflowvelocity(ft/s)
0.20
Minimumflowdepth
0.0
0.00
0
50
100
150
200
250
Discharge(cfs)
Figure3:Modeledratingcurvesforminimumflowdepthandmaximumflowvelocitiyinthe
ReclamationDitchatSanJonRoad.
To:BobHo
olden,MRWPC
CA
September16
6,2015
WEIR
R
DOWN
NSTREAM
RIPRAP
P
APR
RON
UPSTTREAM
Figure4:Longitudinal watersurfacceandenergyyprofilesforttenmodeledflowrates,10cfs240cffs.
SeeTable1forcorresp
pondingprofileIDflowrattes.
To:BobHo
olden,MRWPC
CA
September16
6,2015
WEEIR
DO
OWNSTREAM
RIIPRAP
APRON
U
UPSTREAM
Figure5:HECRASmo
odeloutputfo
orchannelvellocitythroughhweirstructu
ure.SeeTablle1for
ndingprofileIDflowrates..
correspon
To:BobHo
olden,MRWPC
CA
September16
6,2015
WEIR
UPSSTREAM
DOWNSTREAM
APRON
RIPRAP
Figure6:HECRASmo
odeloutputfo
orchannelflowdepththrooughweirstru
ucture.SeeTTable1for
correspon
To:BobHo
olden,MRWPC
CA
September16
6,2015
PARTII:G
GABILANCREEEKATLAUREELROAD
Theonlyiidentifiedhab
bitatintheRe
eclamationDitchwatersheedsuitablefo
orsteelheadsspawningisth
he
upper,un
ndevelopedre
eachofGabilaanCreekinth
hehillsnorth ofSalinas.G
GabilanCreekisaseasonall
stream,flowingonlyaffterraineven
ntsandduringgwetwinterssandsprings..Uponenterringthecity,
GabilanCreekpassestthroughaseriesofbridgessandculvertssandissurroundedbymo
ostlysuburban
nand
commercialdevelopmentandsome
egreenspace.Thisreachoofthecreekrreceivesurbanstormwater
omthesurrou
undingarea.GabilanCreeksconfluenccewiththeReeclamationDitchoccursin
n
runofffro
whatisth
hebedofnorm
mallydryCarrrLakeincenttralSalinas,juustdownstreeamofaseto
oftwinculvertts
beneathLLaurelRoad.BetweenLau
urelRoadandSanJonRoadd,allotherro
oadcrossingsareeitherbrridges
orlowslo
opeboxculve
ertsthatdono
otposeobstaaclestofishppassage.Asalogicalfollow
wingtotheSaanJon
Roadweirranalysis,we
eapplysimilarmethodstoexamineflow
wrequiremen
ntsforfishpaassagethrougghthe
LaurelRoaadculverts,thenextpossiibleupstream
mobstruction .
ThestructtureatLaurelRd.consistsoftwoelliptiicalcorrugateedsteelculveerts,dimensio
ons7.5x10..The
culvertsrunalengthofapproximattely100bene
eathLaurelRooad,droppingg0.45overtthisdistance
%).Theculve
ertsdischarge
eatgradetoafieldoflooselyspaced1
1224riprap
(averagesslopeof0.45%
boulderstthatlinethecchannelbedttoapproximaately24dow nstreamofth
heculvertouttlet.Thechannel
beddropssanadditonaal2.4overthisdistance.D
Downstream oftheriprap,,thechannelbedtransitio
onsto
coarsesan
ndandtheslo
opeflattensssignificantlyaasitapproachhestheCarrLLakebed.
Figure7:Imageofthe
eLaurelRoadculverts,dow
wnstreamendd,onSeptem
mber4,2014.
To:BobHolden,MRWPCA
September16,2015
FishXingModel:
PreliminaryanalysisusingFishXingindicatedupstreamfishpassagethroughtheculvertsmightbe
possiblebetweenflowsof18500cfs.AswasthecaseattheSanJonRoadsite,FishXingcalculates
flowsthroughtheculverts,butdoesnotmodeltheculvertsandriprap/channelasasinglesystem,andis
thusoflimiteduse.Thisisparticularlytrueatthiscrossing,asmaximumflowvelocitiesandminimum
flowdepthsoccurnotwithintheculverts,butovertheriprap.
HECRASModelDesign:
Theculvertsandripraplinedchannelweresurveyedinthefield,andindividualcrosssections
representingthesefeaturesgeometryandroughnesswerecreatedinthemodel.Crosssections
approximately2000upstreamanddownstreamofthebridgeweremodeledbasedonelevationand
surveydatafromthe2009FEMAFloodInsuranceStudyofMontereyCounty.Bedslopesatthese
outlyingcrosssectionswereusedtodeterminethemodelsboundaryconditonsusingnormaldepth.
Flowwasmodeledfor16flowratesbetween10and1000cfs(Table2).Forreference,the10year
stormeventatthislocationis600cfs(FEMAFloodStudy).
ModelResults:
Culverts:ThetwinculvertsbelowLaurelRoadhavethecapacitytoaccommodateflowsinexcessof800
cfsbeforebackwaterfullysubmergestheculvertentrance.Atallflowratesmodeled,flowthroughthe
culvertsremainssubcritical,onlytransitioningtosupercriticalattheculvertoutlet.
Riprap:Whenflowexitstheculvertsandbeginsflowingacrosstheriprap,flowbecomessupercritical,
increasinginvelocityanddecreasingindepth.Forallflowratesmodeled,themaximumflowvelocity
andminimumflowdepthisreachedatthedownstreamlimitoftheripraplinedchannel,approximately
24downstreamoftheculvertoutlet.Flowdepthovertheriprapincreaseswithflowrate,froma
minimumdepthofabout1at10cfsto>2whenflowexceedsapproximately800cfs.Flowvelocitiesat
thislocationrangefromapproximately5ft/satQ=10cfs,to17ft/satQ=1000cfs.
FishPassageAnalysis:
Flowdepthscitedforthepassageofadultandjuvenilesalmonids(0.6and0.4respectively)occurat
correspondingdischargesofapproximately180and110cfs(Figures8,9,11).Foradultupstream
migration,180cfsofflowcorrespondstoaflowvelocityof11.5ft/s(Figure10).Thisvalueistoolikely
toorapidforsustainedswimming,butmaybeacheivableforshortburststhroughtheriprapfield.
FishXingindicatedthatshouldafishsucceedinenteringtheculvert,itcouldcontinueupstreamwithout
succombingtoexhaustionsolongasflowsremainedbelowapproximately500cfs.Forthepurposesof
thisstudy,wewillassumethatvelocityisnotprohibitivetoupstreamfishpassage.
Duringanapproximatelysevenyearperiodfrom20072014,theUSGSmaintainedanoperablegage
(USGS11152600)onGabilanCreekatOldStageRoad,approximately3.5milesnorthoftheLaurelRoad
crossing(seeFigure12).Flowsatthatlocationaresporadic,andwereonlyrecordedtoexceed180cfs
ononeoccasionintherecord.GabilanCreekwatershedcomprisesapproximately40%ofthe
ReclamationDitchwatershedupstreamofSanJonRoad.Outmigrationofsmoltsridingonstormflows
shouldthereforenotbehinderedbya6cfsdiversionatDavisRoad,becauseastormproducinging110
cfsatLaurelDrivewouldexceed200cfsatSanJonRoad.Upstreammigrationofadultsismoregreatly
restrictedbyconditionsinGabilanCreekthanbyconditionsintheReclamationDitch.FishpassingSan
JonRoadandtheDavisRoaddiversionpointmaystillbestrandedinCarrLakeawaitingsufficientflows
toascendGabilanCreek.Thisistheexistingconditioninthesystem,andshouldnotbeaffectedby
diversionssolongaspassageattheSanJonRoadgageisaccomodated.
10
To:BobHolden,MRWPCA
September16,2015
Flowrate HECRAS
(cfs)
ID
10
PF1
20
PF2
30
PF3
50
PF4
70
PF5
100
PF6
130
PF7
160
PF8
200
PF9
240
PF10
300
PF11
400
PF12
500
PF13
600
PF14
800
PF15
1000
PF16
Minimumflow
depth(ft)
0.09
0.14
0.18
0.25
0.32
0.41
0.50
0.58
0.69
0.79
0.93
1.16
1.37
1.58
1.95
2.30
Maximumflow
velocity(ft/s)
4.7
6.2
7.2
8.5
9.4
10.3
11.1
11.6
12.2
12.8
13.4
14.2
14.9
15.6
16.4
17.1
Table2:MinimumdepthsofflowandmaximumflowvelocitiesformodeledflowratesforGabilan
CreekatLaurelRoadcrossing.
18.0
2.50
16.0
2.00
14.0
12.0
1.50
10.0
8.0
1.00
6.0
4.0
0.50
Maximumflowvelocity
Minimumflowdepth
2.0
0.0
Minimumflowdepth(ft/s)
Maximumflowvelocity(ft/s)
0.00
0
200
400
600
800
1000
Discharge(cfs)
Figure8:RatingcurvesforminimumflowdepthandmaximumflowvelocitiyatLaurelRoadcrossing.
11
To:BobHo
olden,MRWPC
CA
September16
6,2015
LAURELROAD
L
D
CULVERTT
DOWNSSTREAM
UPSTTREAM
RIPRAP
Figure9:Longitudinal watersurfacceandenergyyprofilesforssixteenmodeeledflowratees,10cfs10
000
profileIDflow
wrates.
cfs.SeeTTable2forcorrespondingp
12
To:BobHo
olden,MRWPC
CA
DOWNST
TREAM
September16
6,2015
RIPRAP
R
CULVERTT
Figure10:HECRASmodeloutputfforchannelflowvelocityt hroughLaureelRoadculverts.SeeTablee2
forcorresspondingproffileIDflowrates.
13
To:BobHo
olden,MRWPC
CA
September16
6,2015
RIPRAP
DOWNST
TREAM
CULVER
RT
Figure11:HECRASmodeloutputfforchannelflowdepththrroughLaurelRoadculvertss.SeeTable2
2for
correspon
14
To:BobHo
olden,MRWPC
CA
September16
6,2015
Figure12:USGSstreamgagerecorrdforGabilan
nCreek,10/1//20079/29//2014.
15
FinalEIR
September2015
AppendixDD
ConsiderationofWaterRightApplication32263inthe
PureWaterMontereyProjectEIR
FinalEIR
September2015
FinalEIR
September2015
Schaaf & Wheeler

831-883-4848
FAX 831-758-6328
asterbenz@swsv.com
MEMORANDUM
TO:
Bob Holden, MRWPCA
DATE:
August 10, 2015

Updated Sept. 23, 2015
CC:
Alison Imamura, Denise Duffy & Assoc.
FROM:
Andrew Sterbenz, PE
JOB #:
MRWP.01.14
SUBJECT:
Consideration of Water Right Application 32263 in the Pure Water Monterey Project EIR
The Monterey County Water Resources Agency (MCWRA) submitted Water Rights Application No.
32263 on April 9, 2014 to the State Water Resources Control Board (SWRCB), for a diversion of up to
25,000 acre-feet per year (AFY) from the Reclamation Ditch/Tembladero Slough (RD/TS) and the Blanco
Drain (combined total). On July 29, 2015, the MCWRA submitted Applications 32263A through
32263E, separating the request by diversion location and use. The purpose of this memorandum is to
relate applications 32263A through 32263E to the Pure Water Monterey Project, identify discrepancies
and discuss whether the revised applications need to be discussed in the final EIR.
The separate applications are listed in Table 1, below. Applications A, B and C are for the three surface
water diversions for the Pure Water Monterey (PWM) Project. The PWM values are included in the table
for comparison. The water right application values are the maximum annual diversions, while the PWM
values are the average annual diversions, so the values for A, B and C align correctly with the values in
the PWM DEIR. These applications refer to the yield studies included in the PWM DEIR as the basis for
the water availability. Therefore, there is no inconsistency between applications A, B and C and the
PWM DEIR.
Table 1, Applications 32263A-E and PWM GWR Use
Amount Maximum
(AFY)1
Rate (cfs)
3,000
6
2,000
6
1,500
3
PWM
(AFY)2
2,620
1,522
1,135
Application
32263A
32263B
32263C
Diversion Point
Blanco Drain
RD at Davis Rd
TS at Castroville
32263D
Multiple3
9,800
30
NA
32263E
Total
Multiple3
8,700
25,000
55
NA
5,277
PWM Max
Rate (cfs)
6
6
3
1. Water Right application value is maximum annual diversion

2. DEIR value is average annual diversion
3. Includes all three diversion points from 32263A-C
Applications 32263D and E are for the remaining flows in the Reclamation Ditch/Tembladero Slough and
the Blanco Drain. The estimation of total available flows in those streams was included as Attachment 3
to Application 32263D and as Attachment 1 to Application 32263E (same item, different sequential
To: Bob Holden, MRWPCA
-2-
8/10/2015
label). The estimates are shown in Table 2, below, in the column labeled MCWRA Estimate. These
values reflect average year conditions. As can be seen, the average year available flow is less than the
25,000 AFY requested in the water rights applications, indicating that proposed water rights, if approved,
would allow capturing all or most of the flows even during wet years. The MCWRA flow estimations
contained several mathematical errors (addressed in a separate memorandum to MCWRA). The Revised
Estimate column in Table 2 shows the corrected yields, using the methodology as explained in the
applications. This methodology is slightly different than the methodology used by Schaaf & Wheeler in
the water availability studies, so the results are similar but not equal.
Table 2: Estimated Available Flows, Average Year Conditions
MCWRA
Revised
Estimate
Estimate
Source
(AFY)
(AFY)
Blanco Drain
6,500
2,996
RD/TS at Castroville
15,937
10,064
Total
22,437
13,060
Making the correction above significantly reduces the estimation of flows available for water right
applications 32263D and E. Additionally, not all of the existing flow in the Reclamation
Ditch/Tembladero Slough system can be considered available for diversion. Several resource agencies
(the Coastal Commission, the Central Coast RWQCB and NOAA NMFS) commented on the PWM DEIR
that minimum flows must be maintained in the Reclamation Ditch and Tembladero Slough for steelhead
migration and maintenance of wetland habitats. This does not preclude the diversion of peak storm flows
when they occur, but would limit dry-season diversions under applications 32263D and E.
The PWM DEIR did not include a cumulative effects discussion of full use of water right application
32263 (25,000 AFY) because the original application did not provide any detail as to the place of use, the
location and methods of diversion nor the need for storage reservoirs. It would have been purely
speculative to discuss the portion of that water right application outside the PWM Project components.
Item 3, Project Description, of Applications 32263D and E, both include the statement: MCWRA has
not yet defined a final project proposal but will be exploring options and conduct a feasibility study to
determine the necessary course of action. A CEQA document would then be prepared for this project.
Based on those statements, there is still not enough information available to prepare a cumulative effect
analysis for inclusion in the Final EIR.
AppendixEE
ResumesandQualificationsfromKeyEIRContributors
FinalEIR
September2015
FinalEIR
September2015
List of Experts by Section

Air Quality and Greenhouse Gas:
Illingworth & Rodkin, Inc.
JamesAReyff
Biological Resources: Fisheries
Hydrology/Water Quality: Surface

Water

Schaaf and Wheeler Consulting Civil
Engineers
DanielSchaaf,P.E.,andAndrew
Sterbenz,P.E.
HDR Engineers, Inc.

WilliamM.SniderandAdrianE.Pitts
Noise and Vibration

Biological Resources: Terrestrial

DD&A
JoshHarwayne,ErinHarwayne,
MatthewJohnson
MichaelS.Thill
Water Quality Permitting and

Regulatory Compliance
Nellor Environmental Associates
Cultural Resources
Archaeological Consulting
GaryS.BreschiniPH.D.
Geology, Soils, and Seismicity

Ninyo & Moore
PeterConnolly,PG
Hydrology and Water Quality:

Groundwater
MargaretH.Nellor,P.E,.DBE,WBE,HUB
Water Resources and Water

Recycling Specialist
BahmanSheikh,PH.D.,P.E.
Water Treatment/Water Quality

Engineer
Trussell Technologies
GordonWilliams,PH.D.,P.E.
Todd Groundwater
PhyllisStanin,PG,CEG,CHG,andGus
Yates,CEG,CHG
FinalEIR
August 2015
FinalEIR
September2015
AirQualityandGreenhouseGas
JamesA.Reyff,Illingworth&Rodkin
FinalEIR
September2015
FinalEIR
September2015
1 Willowbrook Court, Suite 120

Petaluma, California 94954
Tel: 707-794-0400
www.Illingworthrodkin.com
Fax: 707-794-0405
jreyff@illingworthrodkin.com
JAMES A. REYFF
Mr. Reyff is a Meteorologist with expertise in the areas of air quality and acoustics. His expertise includes
meteorology, air quality emissions estimation, transportation/land use air quality studies, air quality field
studies, greenhouse gas studies and environmental noise studies. He is familiar with federal, state and local air
quality and noise regulations and has developed effective working relationships with many regulatory agencies.
During the past 26 years, Mr. Reyff has prepared Air Quality Technical Reports for over 20 major Caltrans
highway projects and conducted over 200 air quality analyses for other land use development projects. These
projects included microscale analyses, calculation of project emissions (e.g., ozone precursor pollutants, fine
particulate matter, diesel particulate matter, and greenhouse gases), health risk assessments, and preparation of
air quality conformity determinations. Mr. Reyff has advised decisions of federal and local air quality agencies
regarding impact assessment methodologies and air quality conformity issues. He has conducted air quality
evaluations for specific plans and General Plan updates and advised City and County staff on these topics.
Mr. Reyff has been responsible for a variety of meteorological and air quality field investigations in support of
air permitting and compliance determinations. He has conducted air quality analyses of diesel generators in
support of regulatory permitting requirements and environmental compliance issues. Mr. Reyff has designed
and implemented meteorological and air quality monitoring programs throughout the Western United States
including Alaska. Programs include field investigations to characterize baseline levels of air toxics in rural
areas, as well as regulatory air quality and meteorological monitoring. He was the Meteorologist involved in a
long-term monitoring program at the Port of Oakland that evaluated meteorological conditions and fine
particulate matter concentrations in neighborhoods adjacent to the Port.
Mr. Reyff has conducted over 15 major acoustical technical studies for transportation systems. He has managed
several research studies for Caltrans including a noise study that evaluated long-range diffraction and reflection
of traffic noise from sound walls under different meteorological conditions. Mr. Reyff has also evaluated noise
from power plants, quarries and other industrial facilities. He has also been actively involved in research
regarding underwater sound effects from construction on fish and marine mammals.
PROFESSIONAL EXPERIENCE
1995-Present
Senior Consultant
1989-1995
Project Meteorologist
1988-1989
Post Voyage Route Analyst

Petaluma, California
Woodward-Clyde Consultants (URS)
Oakland, California
Oceanroutes (Weather News)
Sunnyvale, California
EDUCATION
1986 San Francisco State University
B.S.
Major: Geoscience (Meteorology)
PROFESSIONAL SOCIETIES
American Meteorological Society
Institute of Noise Control Engineering
AWARDS
FHWA Environmental Excellence Award 2005
Caltrans Excellence in Transportation, Environment - 2005
FinalEIR
September2015
BiologicalResources:Fisheries
WilliamM.SniderandAdrianE.Pitts,HDR
FinalEIR
September2015
FinalEIR
September2015
William M. Snider
Senior Fisheries Biologist
Education
Bachelor of Science, Fishery Sciences,
University of California Davis, 1972
HDR Tenure
8 Years
Industry Tenure
40-plus Years
Professional Experience
Mr. Snider has 40 years experience as a fishery biologist with an emphasis in stream
habitat and fisheries assessments, stream habitat restoration, and fish-habitat
relationships, as well as related regulatory and permitting requirements, including ESA
consultation and water right procedures. Much of his experience is in development and
application of methods to assess and ameliorate the effect of water development projects,
stream flow allocations, habitat restoration, or related instream activities on fishery
resources. His work has emphasized evaluating the life histories, population needs, and
habitat requirements of federal- and state-listed anadromous and resident salmonids.
Project Experience
Monterey Regional Water Pollution Control Agency, Monterey Peninsula
Groundwater Replenishment Project. - Mr. Snider is the Consultant Team Lead for
the fish impact assessment and environmental document preparation for the Monterey
Peninsula Groundwater Replenishment Project. As technical lead, his responsibilities
included identifying potential impact mechanisms and species to be evaluated,
developing impact assessment methodologies, and evaluating operations-related impacts
on aquatic species in the Salinas River.
Carmel River Water Rights, Eastwood Project. Mr. Snider is the lead fishery
biologist in an ongoing water rights proceeding addressing potential effects of changes in
location and use of an existing water right on steelhead in the Carmel River.
Santa Felicia Dam Fish Passage Project United Water Conservation District. Mr.
Snider is the facilitator for a panel of experts in the fields of fishery biology and
engineering that is developing and evaluating alternative fish passage and related
restoration treatments for the Southern California Steelhead DPS pursuant to
requirements of a NMFS biological opinion for the Santa Felicia FERC relicensing on
the Santa Clara River, Ventura County. Mr. Snider brings over 35 years of experience
concerning salmonid stream habitat needs, including evaluation of habitat needs in
context of restoration options specific to local and population constraints and needs.
US Forest Service, Steelhead Monitoring, Tracking and Reporting Program for Los
Padres National Forest. HDR is supporting the FS with their Steelhead Monitoring,
Tracking, and Reporting Program (Program) for Los Padres NF, which is necessary to
prevent irreparable harm to the species by ensuring the adverse impact to steelhead will not
rise to the level of jeopardy, as defined under the federal ESA. HDR created a strategy to
develop and implement a forest-wide steelhead trout population monitoring, tracking, and
reporting program and to apply that strategy to define and implement the Program. Mr.
Snider served as the technical lead in developing the steelhead monitoring plan.
Merced River Hydroelectric Power Project Merced Irrigation District. Mr. Snider
is the lead fishery biologist in an ongoing FERC Relicensing process assisting the
Merced Irrigation District address a variety of fish and stream habitat issues on the
Merced River. Mr. Snider is leading the effort to prepare a biological assessment
pursuant to ESA Section 7 that addresses potential project effects on federal listed fish
populations and designated critical habitat. He is also leading the Merced River
Technical Advisory Committee that provides federal and state agencies and NGOs
opportunity to discuss fishery and related management activities on the Merced River,
including the Merced River Hydroelectric Project to acquire and apply information on
habitat and fish populations to address protection, mitigation and restoration options for
native and introduced fish species.
Longfin Smelt Incidental Take Permit and CEQA ComplianceCalifornia
Department of Water Resources. Mr. Snider was the Project Manager and technical
lead assisting DWR in obtaining an incidental take permit for longfin smelt, including
preparation and processing of supporting CEQA documents, for the continued operation
of the State Water Project. The project included development and application of an
effects analysis to identify and evaluate SWP-associated take of longfin smelt as it
relates to jeopardy of the longfin smelt populations to survive and recover.
Lower American River Instream Flow EvaluationCalifornia Department of Fish
and Game. Project Manager and Technical Lead of a long-term evaluation of the
instream flow requirements for Chinook salmon, steelhead, and other fishes of the lower
American River. Flow habitat relationships were evaluated using an IFIM approach that
included collecting and processing data to compare fish habitat availability as a function
of flow (PHABSIM) and evaluations to validate and calibrate these relationships by
conducting a suite of studies on the relationships among the species life stage
performance and habitat conditions primarily characterized by flow, temperature,
channel morphology. Mr. Snider authored numerous technical reports presenting the
results of these investigations that provided the foundation for the American River Water
Forum Aquatic Resources of the Lower American River: Baseline Report (February
2001) and ultimately the draft flow management standard.
Central Valley Chinook Salmon and Steelhead Recovery PlanNational Marine
Fisheries Service. Mr. Snider is assisting the National Marine Fisheries Service prepare
a recovery plan addressing the Central Valleys three protected salmonid populations:
winter-run Chinook salmon, spring-run Chinook salmon and steelhead. Preparation has
involved conducting public workshops, development of a threats assessment and
evaluation and identification of recovery actions to be considered for the SacramentoSan Joaquin Delta and its tributaries.
Klamath Water RightsSomach, Simmons and Dunn. Mr. Snider is providing
strategic assistance and technical support associated with the Klamath River Water
Rights Adjudication. The cases involve: (1) the Klamath River instream flows required
for anadromous salmonid passage between the Oregon-California border and Upper
Klamath Lake; and (2) the upper Klamath Lake water surface elevations required for six
target fish species, including Lost River sucker, shortnose sucker, Klamath largescale
sucker, rainbow trout, and Coho and Chinook salmon.
Instream Flow ProgramCalifornia Department of Fish and Game. Mr. Snider
evaluated existing, and developed and assessed new, instream flow investigation
procedures and conducted flow requirement investigations on streams throughout the
state. He provided technical support to CDFG staff regarding instream flow evaluation
methods and results. He initiated and led a coho salmon habitat needs investigation
incorporating a variety of investigative tools to Coho populations situated at the two
ends of their present range along the California coast. He also participated in a multiagency team to assist Alameda County Superior Court reduce uncertainties surrounding
the instream flow needs of salmon and steelhead in the lower American River. Mr.
Snider was the project manager and technical lead for flow and habitat evaluations on
the Carmel River (Monterey County), Brush Creek (Mendocino County), Lagunitas
Creek (Marin County), Scott Creek (Santa Cruz County), Sacramento River (Keswick
Dam to Red Bluff), Yuba River (lower Yuba County), lower Stanislaus River
(Stanislaus County), Merced River (Merced County), Alameda Creek (Alameda
William M. Snider - Page 2
County), Truckee River and tributaries downstream of Lake Tahoe to Nevada Stateline,
and all tributaries to Lake Tahoe.
Coastal Lagoon Dynamics, and Aquatic Habitat AssessmentCalifornia
Department of Transportation. Mr. Snider is the Task Order Manager and Technical
Lead for this Caltrans project. HDR is investigating the potential effects of bridge
replacement on aquatic habitat in two coastal lagoons in Santa Cruz County. HDR is
preparing a technical report to assist permitting and regulatory compliance requirements.
The report will address the potential relationships between bridge design and lagoon
dynamics as they relate to habitat requirements of species at risk within the Central
California Coast.
Lower American River Operations Group MemberCalifornia Department of
Fish and Game. Technical representative to the lower American River operation
advisory group. Provided expertise involving fishery flow requirements in the lower
American River to assist the Bureau of Reclamation identify real-time and short-term
planning needs for instream fishery resources relative to current hydrological, reservoir
storage, cold water pool, and fish population conditions.
Lower American River Fish and Habitat EvaluationsBureau of Reclamation and
the U.S. Fish and Wildlife Service. Project manager and technical lead of evaluations
of flow fluctuation effects on anadromous and resident fishes, instream flow
requirements, channel dynamics, and spawning gravel management and restoration
under contract with the Bureau of Reclamation and the U.S. Fish and Wildlife Service.
Authored technical reports addressing effect of flow fluctuation on rearing and spawning
within the lower American River, quantity, quality, and distribution and use of salmonid
spawning habitat in the lower American River.
Lower American River EDF v EBMUD Special Master Technical Team Member
California Department of Fish and Game. Technical representative to the fishery
technical team established as a result of the Hodge Decision, the Superior Court decision
addressing the fishery and other resource flow requirements in the lower American
River relative to EBMUD entitlement to divert water from the Folsom Dam Complex.
Mr. Snider was an expert witness for the Department of Fish and Game during the
SWRCB hearing and then the EDF v EBMUD litigation in the Alameda County
Superior Court. Project manager and technical lead for numerous, multi-year
investigations of lower American River fishery resources, identified and overseen by the
Special Master team, and under contract with the Sacramento County and EBMUD.
Evaluations included Chinook salmon and steelhead spawning population and habitat
evaluations, anadromous and resident rearing habitat requirements, and juvenile
salmonid emigration.
Coast-wide California Road Crossing and Fish Passage Survey and Evaluation
Caltrans. Program Manager and Technical Lead. Prepared information to assist in
development and application of protocols to assess fish passage for salmonids along
Californias coast.
BDCP EIR/EISCalifornia Department of Water Resources. Mr. Snider is the
technical lead for analyses being conducted to identify effects of the Bay Delta
Conservation Plan on fishery and aquatic resources within the San Francisco Bay Delta
and its tributaries. The BDCP includes major changes in the operation of water facilities
within the Delta and its tributaries, changes in water conveyance through the Delta, and
extensive restoration of aquatic habitats within the rivers, bays, floodplains and other
wetlands that adjoin the Delta and support unique and valuable fish and wildlife. The
analyses will include development and application of various methods to address a suite
of potential changes in habitat conditions on an assortment of listed fish species,
including Delta and longfin smelt, Chinook salmon, steelhead, sturgeon and native
minnows. Analyses will also address the influences of hydrology, hydrodynamics, and
other stressors associated primarily with water development, on the ecosystems of the
Delta, the estuary, and the tributary reservoirs and streams.
Statewide Fish Passage InventoryCalifornia Department of Transportation
(Caltrans). Mr. Snider is providing design guidance emphasizing a systematic approach
to evaluation, selection, and design of the preferred fish passage solution that helps to
streamline the environmental review and permitting processes. Additionally, HDR is
providing technical support in the areas of hydrology, hydraulics, geomorphology, civil
engineering, structural engineering, and technical writing.
Stream Evaluation ProgramCalifornia Department of Fish and Game. Mr. Snider
was the Senior Environmental Scientist and Supervisor responsible for managing the
state of Californias stream evaluation program to achieve its mission of developing,
implementing, and applying flow and other habitat investigation methods to improve
understanding of salmonid population and habitat needs.
Environmental Staff SupportCalifornia Department of Transportation. HDR
currently holds an on-call contract to provide environmental support services to Caltrans
through 2008. One of the current task orders includes support to the Caltrans Office of
Biological Studies and Technical Assistance in developing policy, guidance, and
documents. Mr. Snider oversees the environmental staff assigned to Caltrans.
Environmental Documentation for Sacramento-San Joaquin Delta Assessments
U.S. Bureau of Reclamation. Prepared environmental documents assessing the effects
of the Environmental Water Account on the fisheries and aquatic ecosystem of the
Sacramento-San Joaquin Delta and its tributaries. The assessments identified current
conditions limiting fishery resources, including federally and state listed fish
populations, including Chinook salmon, steelhead, green sturgeon, and delta smelt.
Established and applied approaches to assess effects and integrated the findings into
CEQA, NEPA and ESA required documents.
Coho Programmatic Documents for Permitting Highway Maintenance Projects,
Californias North CoastCaltrans. Program Manager and Technical Lead.
Developed information on effects and potential avoidance and mitigation measures
regarding various effects of highway maintenance and construction on fish populations.
The evaluated effects included noise and vibration, streambed alteration, water quality,
and fish passage.
Adrian E. Pitts
Northern California Fisheries Business Class Manager
Education
Bachelor of Science, Biology, University of
California Davis, 1997
Master of Science, Conservation/Renew
Nat Resrces, California State Univ Sac
(Degree not complete)
Professional Affiliations
American Fisheries Society
HDR Tenure
12 Years
Industry Tenure
17 Years
Mr. Pitts is an aquatic scientist who specializes fisheries biology with specific emphasis on
aquatic resources impact assessments. He has 15 years of experience in the areas of wetland
delineation, aquatic bioassessment, terrestrial and aquatic special-status species habitat
surveys, and terrestrial and fisheries impacts assessments. He has extensive knowledge of
the California and federal regulatory environment, including the California Environmental
Quality Act (CEQA), National Environmental Policy Act (NEPA), California and federal
Endangered Species Acts (ESAs), and the Clean Water Act (CWA).
HDR Project Experience
Monterey Regional Water Pollution Control Agency, Pure Water Monterey
Groundwater Replenishment Project. Mr. Pitts is the project manager and quality
control reviewer for the fish impact assessment and environmental document preparation
for the Pure Water Monterey Groundwater Replenishment Project that proposes
diverting surface water from several sources for groundwater replenishment. As the
project manager, Mr. Pitts managed HDRs technical staff and coordinated project
delivery with the client. As the quality control reviewer, Mr. Pitts supported HDRs
technical lead in identifying potential impact mechanisms and species to be evaluated,
developing impact assessment methodologies, and evaluating operations-related impacts
on aquatic species in the Salinas River.
Carmel River Water Rights, Eastwood-Odello Project. Mr. Pitts is the project
manager and quality control reviewer in an ongoing water rights proceeding addressing
potential effects of changes in location and use of an existing water right on steelhead in
the Carmel River. Mr. Pitts manages HDRs technical staff and coordinates project
delivery with the client. In his technical role, Mr. Pitts supports developing impact
assessment methodologies, and evaluating potential flow changes in the Carmel River.
US Forest Service, Steelhead Monitoring, Tracking and Reporting Program for Los
Padres National Forest. HDR supported the Forest Service by leading the development of
their Steelhead Monitoring, Tracking, and Reporting Program (Program) for Los Padres
National Forest (LPNF), which was necessary to monitor LPNF activities and prevent
irreparable harm to the species. HDR created a strategy to develop and implement a forestwide steelhead population monitoring, tracking, and reporting program and to apply that
strategy to define and implement the Program. Mr. Pitts served as the project manager for
HDR and served as a senior scientist working closely with HDRs technical lead and Los
Padres NF staff to develop the steelhead monitoring plan and present the proposed plan to
the National Marine Fisheries Service and California Department of Fish and Wildlife
California Department of Transportation, Statewide Fish Passage Inventory. Mr.
Pitts currently serves as a technical adviser to HDRs team that is conducting
reconnaissance and detailed fish passage assessment field surveys along the highways of
Santa Cruz, Marin, and San Mateo counties. Mr. Pitts also advises the HDR team on
field safety protocols and procedures, data management, data analysis, and GIS
activities.
Merced River Hydroelectric Power Project Merced Irrigation District. Mr. Pitts
serves as a senior scientist and endangered species advisor to HDRs team in an ongoing
FERC Relicensing process assisting the Merced Irrigation District address a variety of
fish and stream habitat issues on the Merced River. Mr. Pitts served a lead role in
preparing a biological assessment pursuant to ESA Section 7 that addresses potential
project effects on federal listed fish populations and designated critical habitat.
Additionally, Mr. Pitts served as a senior reviewer for development of study plans and
study plan reports evaluating Merced River aquatic resources.
USACE San Francisco District, South San Francisco Bay Shoreline Study. Mr. Pitts
served as the senior Quality Control reviewer for the the aquatic species analysis for a
programmatic Environmental Impact Statement (EIS) and Biological Assessment (BA) for
the San Francisco Corps of Engineers District's Shoreline Phase 1 Project. This project
includes construction of new levees and berms, replacement and installation of in-stream
structures, creation of new tidal salt marshes, importing and placement of dredged material,
tidal wetland creation and restoration, and creation of recreation facilities in the San
Francisco Bay. Fish species potentially affected by the project include state and federally
listed estuarine and anadromous species including longfin smelt and the Central California
Coast Distinct Population Segment of Steelhead.
USACE Sacramento District Folsom Water Control Manual Update. HDR is
supporting the USACE Sacramento District as they develop a new Water Control Manual for
the safe and efficient operation of Folsom Dam after the construction of the Joint Federal
Project auxiliary spillway. Doing so will require detailed analysis of impacts to seasonal
storage variations and how those impacts affect water supply, power generation, and critical
environmental factors such as temperature, sedimentation, water quality, etc. HDRs
resource specialists will utilize existing hydrologic, hydraulic, water temperature, and water
quality models, as well as develop, apply, and integrate, new models to evaluate the impacts
of implementing the new water control manual. Mr. Pitts is serving as the fisheries technical
lead. He and his team are developing new approaches to evaluating flow and water
temperature-related impacts on steelhead and fall-run Chinook salmon in the lower
American River.
Yuba County Water Agency, Lower Yuba River Accord. Lower Yuba River Accord
Environmental Impact Report/Environmental Impact Statement (EIR/EIS). Mr. Pitts
was part of the HDR team that provided environmental compliance services for the proposed
Lower Yuba River Accord (Yuba Accord), comprised of a coalition of over 15 agricultural,
environmental, and fisheries interests, including state and federal agencies. The proposed
Yuba Accord is a collaborative settlement initiative, which proposes new instream flow
requirements for the lower Yuba River that will significantly increase protection for the
rivers fisheries resources and will improve habitat conditions for lower Yuba River Chinook
salmon and steelhead. The proposed Yuba Accord also will represent the first major longterm water acquisition by the State of California for the CALFED Bay-Delta Program
Environmental Water Account, and will improve water supply reliability for the major
resource agencies. Mr. Pitts was responsible for and prepared the Terrestrial Resources
chapter of the EIR/EIS.
Yuba County Water Agency, River Management Team, Monitoring and Evaluation
Program. Following certification of the Yuba Accord EIR, on March 18, 2008, the State
Water Resources Control Board approved a consensus-based, comprehensive program,
known as the Lower Yuba River Accord (Yuba Accord). The Yuba Accord established a
River Management Team (RMT), which includes representatives of YCWA, NMFS,
USFWS, CDFG, PG&E, and NGOs. The RMT, through a consensus-based process, guides
the expenditure of over $6 million through 2016, primarily for monitoring and evaluation of
lower Yuba River fisheries and habitat. Mr. Pitts serves as HDRs project manager for the
program and assists HDRs technical lead and support team. Recently, Mr. Pitts supported
the development of the Monitoring and Evaluation (M&E) Program Interim Report that
presented over five years of monitoring data and ultimately intends on determining whether
Adrian E. Pitts - Page 2
implementation of the Yuba Accord is maintaining fish in good condition (consistent with
Fish & Game Code 5937) and achieving viable salmonid populations (VSP) (addressing
NMFS recovery planning).
California Department of Water Resources and US Bureau of Reclamation, North-ofDelta Offsite Storage (NODOS) Investigation. Mr. Pitts served as HDRs project manager
and the EIR/EIS Consultant Team Lead for the Fish and Aquatic Resources impact
assessment and environmental document preparation for the North of Delta Offstream
Storage (NODOS) Investigations Project conducted by DWR and the US Bureau of
Reclamation. As HDRs lead author, his responsibilities included identifying potential
impact mechanisms and species to be evaluated, developing impact assessment
methodologies, and evaluating operations and construction-related impacts on aquatic
species in the Sacramento River, Feather River, American River, and two intermittent creeks
in the construction area. Building on his previous experience, Adrians team refined and
updated the tools they developed for the Bay Delta Conservation Plan EIR/EIS to further
streamline the process of evaluating large amounts of empirical and modeled data, thereby
saving time and money during the NODOS Investigations Project evaluation.
Mr. Pitts also participated on the multi-agency, multidisciplinary Environmental
Coordination Advisory Team (ECAT) to identify resource agency concerns and act as a
liaison between DWR and the California Department of Fish and Game, US Fish and
Wildlife Service, and the National Marine Fisheries Service.
California Department of Water Resources, Bay Delta Conservation Plan
Environmental Studies. Mr. Pitts served two major roles on the Environmental Impact
Report/Environmental Impact Statement (EIR/EIS) consultant team. As the team lead for the
Fish and Aquatic Resources impact assessment, his responsibilities included identifying
species to be evaluated and issues of concern in the Sacramento-San Joaquin River Delta and
its major tributaries. Additionally, Mr. Pitts led the team in researching and developing life
history characterizations, developing impact assessment methodologies, and evaluating
operations, construction, and restoration-related impacts on aquatic species. Adrians team
developed previously unused tools to conduct evaluations of large amounts of empirical and
modeled data quickly, accurately, and cost effectively.
Prior to leading the Fish and Aquatic Resources team, Mr. Pitts led the consultant teams
support of DWRs survey efforts. As the environmental survey lead, he worked closely with
DWR senior staff and species experts to develop and implement a survey approach for
special status birds, mammals, reptiles, amphibians, plants, and invertebrates, and to provide
technical and administrative support to DWR survey teams.
El Dorado Irrigation District, Environmental Assessment for Long-Term Warren Act
Contract. Mr. Pitts served as HDRs technical lead conducting analysis of potential water
temperature and flow-related impacts on steelhead and fall-run Chinook salmon in an
Environmental Assessment/FONSI for the U.S. Bureau of Reclamation to enter into a longterm (40-year) contract with the El Dorado Irrigation District (EID) to facilitate the delivery
of up to 17,000 acre-feet per year non-Central Valley Project (CVP) water through Folsom
Reservoir for municipal and industrial uses in the western portion of El Dorado County. The
source of non-CVP water is EIDs direct diversion rights for waters of the South Fork
American River at the Kyburz diversion dam, and rights for diversion to storage from Caples
Lake in Alpine County, Silver Lake in Amador County, and Lake Aloha in El Dorado
County, granted in Water Rights Permit 21112 by the State Water Resources Control Board
(SWRCB). The water rights covered in Water Rights Permit 21112 are made available by
the operation of existing facilities of Federal Energy Regulatory Commission El Dorado
Hydroelectric Project No. 184 within the South Fork American River Basin.
California Department of Water Resources and US Bureau of Reclamation, Yolo
Bypass EIR/EIS. HDR is initiating preparation of the planning and environmental
documentation for NEPA/CEQA compliance for the Yolo Bypass Seasonal Floodplain
Habitat Restoration and Fish Passage Improvements Project. Specific tasks include
preparation of a Biological Assessment (BA), an Incidental Take Permit (ITP), and the
EIR/EIS, as well as agency coordination and permitting support, as necessary. Mr. Pitts is
currently serving as HDRs technical lead for fisheries and aquatic resources.
Mammoth Community Water District, Mammoth Creek Environmental Impact
Report. Mr. Pitts was the project manager for preparation of the Mammoth Creek EIR,
which addressed proposed changes in Mammoth Creek bypass flow requirements,
management constraints, point of measurement, and place of use. Mr. Pitts led the HDR
team to revise and update sections of a prior Draft EIR, which was issued in 2000. HDR was
responsible for developing and applying an operations model for the Districts surface water
diversions from Mammoth Creek.
As part of a collaborative effort led by the District, Mr. Pitts coordinated with key
stakeholders including the Los Angeles Department of Water and Power, California
Department of Fish and Game, California Trout, and the Town of Mammoth Lakes to ensure
that their concerns were addressed in the EIR and to help gain consensus regarding many
aspects of the project. Mr. Pitts also led HDRs internal team to provide support during the
public scoping process and aid the District in developing the Proposed Project and
Alternatives. Mr. Pitts participated in Mammoth Creek EIR Technical Committee meetings
to assist in the development of the hydrologic operations model, identify data and existing
studies for inclusion into the EIR, and to provide updates on the CEQA environmental
process. Additionally, Mr. Pitts assisted with an analysis of 16 years of fish population
survey data and authored a review of the Hot Creek Stressor Identification process, which
identified trends in trout populations, including the relationship of trout abundance to flows,
and evaluated the condition of Mammoth Creek benthic macroinvertebrates.
California Department of Water Resources, Oroville Facilities FERC Relicensing. Mr.
Pitts provided technical, analytical, and agency consultation support services for the Federal
Energy Regulation Commission (FERC) relicensing process for the hydroelectric facilities at
Lake Oroville. He assisted in the preparation of environmental documentation required to
support DWR's application for relicensing. Mr. Pitts prepared the aquatic resources sections
of the Preliminary Draft Environmental Assessment (PDEA), including assisting in the
development of the methodology for the aquatic resources analysis. He also assisted in the
analysis of potential protection, mitigation, and enhancement measures related to aquatic
resources, and evaluated issues associated with federally listed threatened and endangered
fish species, and fish and wildlife agency Section 10(j) recommendations. The PDEA
summarized and incorporated the analyses related to fish habitat, upstream passage,
predation, and disease prepared by HDR during completion of the study plan reports for
aquatic resources. r. Pitts contributed to the alternatives evaluation and the discussion of
unavoidable adverse and cumulative effects.
Prior to his work on the PDEA, Mr. Pitts led an internal team in the development and
implementation of fisheries resources and aquatic ecology study plans that were designed to
analyze potential project effects on Feather River and Lake Oroville fish habitat, fish disease,
fish passage, and fish predation. The study plans included tasks designed to investigate and
evaluate anadromous fish habitat requirements, distribution of anadromous fish in the
Feather River, resident fish habitat components, resident fish distribution, the feasibility of
providing fish passage above Oroville Dam, fish interactions, and predation. In addition to
his coordination role, Mr. Pitts responsibilities included authorship and implementation of
the study plans, including performing relevant literature reviews, analyzing data, developing
analysis strategies, conducting field studies, and drafting technical reports to satisfy the study
plans. Mr. Pitts authored study plans for anadromous salmonids, specifically, spring-run
Chinook salmon holding habitat characterization, steelhead spawning survey methodology,
and steelhead rearing temperatures.

Placer County Water Agency, Auburn Tunnel Outlet Modification Project. HDR
provided environmental services to support several phases of the Auburn Tunnel Outlet
Modification Project for the Placer County Water Agency. The project involves improving
the outlet structure for the Auburn Ravine tunnel to reduce the accumulation of fine
sediments entering Auburn Ravine.
Mr. Pitts served as the project manager leading the HDR team to complete the environmental
documentation under the California Environmental Quality Act and Endangered Species Act
compliance documentation. Additionally, Mr. Pitts assisted with strategic planning to refine
the design of the outlet structure and associated facilities, and provided support to the Placer
County Water Agency during the environmental permitting process.
Santa Clara Valley Water District, Anderson Dam Seismic Retrofit Planning and
Environmental Consultant Services. Assisted in the development and preparation of
planning study documents, including the Problem Definition Report, Planning Study Report,
and CEQA/NEPA documents, as well as permitting. The ultimate outcome of the planning
services will be to recommend a preferred alternative to: resolve the seismic deficiencies in
the dam embankment from the maximum creditable earthquake; resolve and remediate, if
necessary, the outlet works for the potential fault rupture risk from a maximum creditable
earthquake; and review and revise, as needed, the Probable Maximum Flood (PMF) and
routing study to address possible deficiencies with the spillway.
Santa Clara Valley Water District, Three Creeks Habitat Conservation Plan and
Fisheries and Aquatic Habitat Collaborative Effort (FAHCE) EIR. The Santa Clara
Valley Water District is preparing a Habitat Conservation Plan (HCP) pursuant to a multistakeholder settlement agreement, the FAHCE Settlement Agreement. Mr. Pitts served as
the project manager for the preparation of an Effects Assessment for the Three Creeks HCP,
and as a senior scientist leading the evaluation of fisheries resources in the FAHCE
Settlement Agreement EIR. The HCP was prepared to obtain incidental take authorization
under the federal Endangered Species Act for ongoing water supply operations in three
watersheds in Santa Clara County, CA. As the project manager for HDR, Mr. Pitts led the
team that developed the effects assessment approach and conducted the effects assessment
identifying the effects of water supply operations and conservation measures on Central
California Coast steelhead. Mr. Pitts also is leading the team conducting operations
modeling and evaluation of fisheries resources as part of the CEQA compliance process.
Somach, Simmons & Dunn, Bear Canyon Creek Fish Passage Project. Mr. Pitts was the
project manager for the preparation of an EA/IS and Endangered Species Act compliance
documentation for fish passage improvements and changes to reservoir operations on Bear
Canyon Creek, located on the Rubicon (formerly Niebaum-Copola) Estate Winery in the
Napa Valley.
As the project manager for HDR, Mr. Pitts coordinated with resource agency representatives,
including the California Department of Fish and Game and the National Marine Fisheries
Service, to facilitate collaboration among stakeholders and to support the project proponents
in development of the passage facility design and reservoir operations plan. Additionally,
Mr. Pitts led the HDR team that conducted analyses of potential environmental impacts
associated with construction of the fish passage facilities and reservoir operations, including
detailed analyses of potential effects on state and federally listed threatened and endangered
species.
Somach, Simmons & Dunn, Chico Ranch/Llano Seco Rancho Pumping Plant
Maintenance of Channel Alignment River Mile 192.5 EA/IS. Mr. Pitts served as the
project manager for the preparation of an Environmental Assessment/Initial Study (EA/IS)
and Action Specific Implementation Plan (ASIP) for the Rancho Llano Seco Channel
Alignment Temporary Maintenance Project on the Sacramento River. The project involved
placement of longitudinal rock toe and tree revetment on the west bank, and removal of a
debris island on the east bank of the Sacramento River near the confluence with Big Chico
Creek.
Mr. Pitts managed the efforts of HDR staff to update an existing EA/IS and ASIP to address
the potential environmental impacts associated with the project. Specifically, Mr. Pitts and
the HDR team, in cooperation with the California Department of Fish and Game, U.S. Fish
and Wildlife Service, and National Marine Fisheries Service, identified the analytical
methodology and conducted the analyses to address potential impacts on fisheries terrestrial
biological resources in and adjacent to the Sacramento River, including potential impacts on
several state and federally listed threatened and endangered species. Mr. Pitts also led the
team in the evaluation of non-biological resources in the EA/IS and diligently supported the
project proponent and their attorneys to allow for the timely completion of the environmental
permitting process. Construction of the M&T Ranch, Rancho Llano Seco Temporary
Channel Maintenance Project was completed during November 2007.
U.S. Bureau of Reclamation/Department of Water Resources/CDM, Action Specific
Implementation Plan for the Environmental Water Account EIS/EIR. Mr. Pitts assisted
in the preparation of the Action Specific Implementation Plan, which must be approved by
NMFS, USFWS and CDFG, to implement the Environmental Water Account. The EWA is
one component of the long-term comprehensive plan adopted in the CALFED Bay-Delta
Program Record of Decision. The overall purpose of the EWA is to increase water supply
reliability and to provide sufficient protections, combined with the Ecosystem Restoration
Program and the regulatory baseline, to address CALFED's ecosystem quality needs in the
areas of fishery protection, restoration, and recovery. The ASIP is a document established by
the CALFED Bay-Delta Program that will fulfill the requirements of, and initiate projectlevel compliance with, the federal and California ESAs and the Natural Community
Conservation Planning Act. Tiering off the CALFED Multi-Species Conservation Strategy,
Mr. Pitts assisted in preparation of environmental settings sections, specifically with regard
to spring-run Chinook salmon analyses in Butte Creek. Mr. Pitts also prepared water quality
settings for southern California reservoirs.
Yuba County Water Agency, Biological Assessment for Yuba River Development
Project Proposed License Amendment. Mr. Pitts assisted in the preparation of the fisheries
analyses for this project. YCWA is seeking to reduce flow fluctuations caused by
emergency outages at the Narrows II Powerhouse by installing a synchronous full-flow
bypass; reduced flow fluctuations would reduce stranding juvenile spring-run and steelhead
and dewatering redds of these species. YCWA also is seeking to extend the flow reduction
and fluctuation criteria to year-round to protect the steelhead/rainbow trout spawning life
stage. Mr. Pitts analyzed the impacts of constructing the bypass on spring-run Chinook
salmon and steelhead.
Yuba County Water Agency, Deadwood Creek Monitoring Project. Mr. Pitts assisted in
the preparation of the final report for a six-year monitoring program for Deadwood Creek.
Brown trout, rainbow trout, and benthic invertebrate populations were monitored, and
substrate characterization was performed. The monitoring was conducted to determine
whether the required minimum flows provide adequate protection for Deadwood Creek
fisheries resources, and to evaluate long-term project-caused effects to Deadwood Creek
trout populations.
Yuba County Water Agency, Biological Assessment for Yuba River Development
Project Proposed License Amendment. Mr. Pitts assisted in the preparation of the fisheries
analyses for this project. YCWA is seeking to reduce flow fluctuations caused by emergency
outages at the Narrows II Powerhouse by installing a synchronous full-flow bypass; reduced
flow fluctuations would reduce stranding juvenile spring-run and steelhead and dewatering
redds of these species. YCWA also is seeking to extend the flow reduction and fluctuation
criteria to year-round to protect the steelhead/rainbow trout spawning life stage. Mr. Pitts
analyzed the impacts of constructing the bypass to spring-run Chinook salmon and steelhead,
as well as the cumulative impacts to fisheries.
Non-HDR Project Experience
U.S. Forest Service, Eldorado National Forest, Section Dredge Monitoring. Mr. Pitts led
a team conducting a field investigation of the channel morphology and benthic invertebrate
communities of five streams in the upper Cosumnes River Watershed. On each of the study
reaches, affected areas were identified and mapped, and impacts to the physical habitat were
recorded. Following protocols outlined in the California Stream Bioassessment Procedure,
Mr. Pitts and his team then collected invertebrate samples from riffles upstream and
downstream from affected sites on two of the streams. Upon completion of the laboratory
analysis, Mr. Pitts analyzed the metrics produced by the laboratory in an attempt to
determine if suction dredging had adverse effects on the benthic populations downstream
from known mining claims within the study area.
FinalEIR
September2015
BiologicalResources:Terrestrial
JoshHarwayne,ErinHarwayne,MattJohnson,DD&A
FinalEIR
September2015
FinalEIR
September2015
Josh Harwayne
Senior Environmental Scientist / NRD Manager
Education
Master of Arts, Ecology and

Systematic Biology, San
Francisco State University, 1999
(course work)
Bachelor of Science, Botany, San
Francisco State University, 1997
Work Experience
Senior Project Manager - Natural

Resources Department Project
Manager, DD&A
Environmental Consultant, Wetland
Research Associates, Inc.
Laboratory and Field Manager,
Romberg Tiburon Center for
Environmental Studies Laboratory for Wetland and
Estuarine Biology
Mr. Harwayne serves as the Natural Resources Division Project Manager and is the
senior staff biologist for DD&A. In addition to directing biological data collection,
analysis and documentation, Mr. Harwayne is responsible for development and
management of new projects, document quality control, staff development,
marketing development, contracting, and maintaining project budgets and schedules.
With over 16 years of consulting experience, he brings to the firm the highest level
of technical, analytical and management skills.
His technical capabilities are as follows:
Initial Studies/Mitigated Negative Declarations (IS/MND)

Environmental Assessments/Finding of No Significant Impact (EA/FONSI)
Environmental Impact Reports (EIR)
Environmental Impact Statements (EIS)
Biological Assessments (BA)
Natural Environment Studies (NES)
Wetland Delineation Reports
1996 - 1999
Wetland Banking Documents
Mitigation Monitoring and Reporting Programs (MMRP)
Habitat Conservation Plans (HCP)
Expert botany, wildlife, and wetland science experience gained working on a

wide variety of projects involving special-status species and sensitive habitats.
Proficiency in conducting biological surveys, including protocol-level surveys

for special-status wildlife and plant species such as the California tiger
salamander, California red-legged frog, burrowing owl, sand gilia, Monterey
spineflower, and seaside birds beak.
Experience working closely with resource and regulatory agencies in permitting

projects of varying size and complexity, including:
Association of Environmental
Professionals
California Botanical Society
California Native Plant Society
Society of Wetland Scientists
Friends of the Jepson Herbarium
Society for Ecological Restoration
Registrations/Certificates
Advanced Habitat Restoration

Workshop for California Redlegged Frog (Elkhorn Slough
Coastal Training Program)
California Red-legged Frog
Workshop (Elkhorn Slough
California Department of Fish and Wildlife (DFW)

U.S. Fish and Wildlife Service (Service)
Regional Water Quality Control Board
Army Corps of Engineers (ACOE)
California Coastal Commission
Project Management with complex permitting processes, including Clean Water

Act Sections 401 and 404, DFG 1602, federal Endangered Species Act Section 7
and 10 consultation and permit processes, State Endangered Species Act Section
2081 Incidental Take Permit, and fully protected species.
Coastal Policy Workshop (Elkhorn

Slough Coastal Training
Program)
Wetland delineations per ACOE and Coastal Act criteria and the design of
wetland mitigation and restoration projects.
40-hour ACOE Wetland

Delineation Training (co-taught
course)
40-hour ACOE Advanced Wetland
Delineation Training
Native Grass Identification
(California Native Grass
Expertise in preparing scopes, managing subconsultants, and keeping projects

within established budgets and timeframes.
Regularly guest lectures on vernal pool ecology, wetland ecology,

environmental regulatory requirements, and native plant identification at
California State University Monterey Bay (CSUMB) and Monterey Peninsula
Community College (MPC).
California Tiger Salamander

Workshop (Elkhorn Slough
Josh Harwayne
Senior Project Manager / NRD Manager
Association)
Wetland Plant Identification
(Jepson Herbarium)
Vernal Pool Ecology (Jepson
Herbarium)
CEQA/NEPA Documentation
(UC Davis Extension)
Streambed Alteration Agreements
(UC Davis Extension)
USFWS Federal Recovery Permit
TE-091857-0 - California tiger
salamander and California redlegged frog
CDFW Scientific Collection Permit
006622
Project Experience:
Water Resources Projects:
Storm Drain Improvements Project IS, City of Carmel-by-the-Sea

Salinas River Vegetation Maintenance Project, Monterey County Water
Resources Agency
Castroville Storm Drain Master Plan Improvements Project, Monterey
County Department of Public Works
ESA Section 10 Permits and Section 7 Consultation Projects:
Santa Lucia Preserve Habitat Conservation Plan

Malcolm Ranch Habitat Conservation Plan
Fort Ord Habitat Conservation Plan Species Distribution and Impact
Analysis
ALBA Wetland Restoration Section 7 and State Safe Harbors Agreement
Carmel Hill Bike Trail Section 7
Garrett Road Rehabilitation and California Red-legged Frog Pond
Restoration Section 7
Educational Projects:
Endangered Species Act Workshop, MCWD

Guest Lecture on vernal Pool Ecology and Wetland Ecology and Regulatory
Environment, CSUMB
Guest Lecture on California Native Plant Identification, MPC
Biological and Wetland Assessment Projects:
The First Tee EIR, City of Seaside

Biological Report and Wetland Delineation, City of Seaside
Biological Assessment for General Plan Update, City of Monterey
Snowcreek Biological Assessment Town of Mammoth Lakes, Chadmar, Inc.
Thorne Road Bridge NES, Monterey County Department of Public Works
National Refractory Wetland Assessment
Permitting and Condition Compliance Monitoring Projects:
Bridge Improvement Projects, San Benito County Public Works

Highway 25, Quincy Engineering
Stone Creek Shopping Village, City of Del Rey Oaks
Seaside Highlands Housing Development, City of Seaside
Bayer Tank Demolition and Inertia Project, Marina Coast Water District
Erin Harwayne, AICP

Senior Environmental Scientist / Planner / Project Manager
Education
Bachelor of Science, Earth Systems
Science & Policy (Marine and
Coastal Ecology), California
State University Monterey Bay,
2000
Continuing
Education,
Land
Use/Natural Resources Topics,
through University of California
Extension Program and CLE
International
Experience
Environmental Scientist/Planner/
Project Manager, DD&A
Research Assistant, Monterey Bay
National Marine Sanctuary
With over 15 years at DD&A, Erin Harwayne, AICP, has managed and prepared
numerous environmental documents in compliance with CEQA and NEPA for a
wide variety of projects involving educational facilities, natural resources
management, water supply and distribution, military base reuse, public works, and
transportation and transit infrastructure. She has experience preparing all types and
levels of environmental documents, including:
Initial Studies/Mitigated Negative Declarations (IS/MND)

Environmental Assessments/Finding of No Significant Impact (EA/FONSI)
Environmental Impact Reports (EIR)
Environmental Impact Statements (EIS)
Mitigation Monitoring and Reporting Programs (MMRPs)
Integrating her extensive background in ecology with land use planning, Ms.
Harwayne utilizes an innovative approach toward solving complex environmental
issues.
Her technical capabilities are as follows:
Member, Association for

Environmental Professionals
Member, American Planning
Association
Member, California Native Plant
Society
Adeptness in regulatory permitting processes, including Clean Water Act

Section 401 and 404, California Department of Fish and Wildlife (DFW)
1602 Lake and Stream Alteration Program, Federal Endangered Species
Act Section 7 consultation and Section 10 permit processes, California
Endangered Species Act Section 2081 Incidental Take Permits, and Coastal
Development Permits.
Management and preparation of environmental documents in accordance

with CEQA and NEPA requirements and local, state, and federal policies
and regulations
Proficiency in conducting biological surveys, including protocol-level

surveys for special-status wildlife and plant species such as the San Joaquin
kit fox, California tiger salamander, black legless lizard, California redlegged frog, vernal pool crustaceans (fairy and tadpole shrimp), sand gilia,
Monterey spineflower, and seaside birds beak
Experience in conducting wetland delineations per United States Army

Corps of Engineers (ACOE) and California Coastal Act criteria
Expertise in the environmental review processes for the California State

University and University of California systems
Excellent communication and presentation skills
Highly skilled in technical writing and editing
Expertise in preparing scopes, managing sub-consultants, and keeping

projects within established budgets and timeframes
Registrations/Certifications
American Institute of Certified
Planners (AICP)
CEQA and NEPA Intensive
Workshop Certifications
Fairy and Tadpole Shrimp
Identification Class and Service
Test Certification
PADI Certified SCUBA Diver
Service Federal Recovery Permit
No. TE-091857-0 - California
tiger salamander
DFG Research Permit for Listed
Plant Species No. 04-08-RP Sand gilia
DFG Scientific Collection Permit
No. CS-007722 - Aquatic
invertebrates
Project Experience:
Fort Ord Habitat Conservation Plan EIR and EIS Fort Ord Reuse
Authority and the U.S. Fish and Wildlife Service
Monterey Bay Regional Desalination Project Biological Assessment
MCWD, Cal-American Water, and U.S. Bureau of Reclamation
Recycled Water Project Biological Assessment MCWD and U.S. Bureau
of Reclamation
Santa Lucia Preserve Habitat Conservation Plan EA Rancho San Carlos
Erin Harwayne, AICP

Senior Environmental Scientist /
Planner / Project Manager
Partnership and the U.S. Fish and Wildlife Service

Marina Heights DFG Incidental Take Permit The Chadmar Group
Endangered Species Act Educational Workshop and Staff Training
MCWD
Educational Facility Projects:

2007 Master Plan and Near-Term Projects EIR California State
University Monterey Bay/Board of Trustees
West Campus Building Demolition Project CSUMB
North Quad Student Housing IS/MND CSUMB
Outdoor Pool IS/MND CSUMB
North Campus Housing EIR CSUMB
Land Exchange Addendum to Master Plan EIR, CSUMB
Environmental and Constraints Analyses for Building Demolition Pilot
Project, Library Project, Visitors Center Project, Sports Complex Project,
Co-Generation Plant, and Telecommunications Infrastructure Upgrade
Project CSUMB
Biological, Wetland Assessment, and NES Projects:
Haskells Landing City of Goleta, The Chadmar Group
Veterans Cemetery Fort Ord Reuse Authority
Monterey Downs Horse Park Monterey Downs, LLC
Whispering Oaks Business Park and MST Facility Monterey Salinas
Transit
Regional Water Augmentation EIR MCWD
Marina Station EIR City of Marina
Seaside Main Gate EIR City of Seaside
LaTourette Subdivision EIR County of Monterey
Gilroy General Plan Update EIR City of Gilroy
Regency Center EIR City of Gilroy
Biological Assessment for the General Plan Update City of Monterey
Arroyo Seco Road Guardrail NES Monterey County Department of Public
Works
Highway 25 Safety Improvement NES - Caltrans District 4 and Council of
San Benito County Governments
Water Facilities Projects:
Storm Drain Improvements Project IS/MND City of Carmel-by-the-Sea
Tank Design and Improvements Project EA/IS MCWD
Water Supply Master Plan EIR MCWD
Castroville Storm Drain Master Plan Improvements Project Monterey
County Department of Public Works
Pond A-4 Sediment Storage Environmental Analysis Santa Clara Valley
Water District
Linear Projects:
Monterey Bay Peninsula Light Rail Project Transportation Agency for
Monterey County
Eastside Parkway Biological Study Fort Ord Reuse Authority
Uvas Creek Park Preserve Trail Improvements IS/MND City of Gilroy
Carmel Valley Class I Bicycle Trail IS/MND Monterey County
Department of Public Works
Carmel Valley Road Improvements IS/MND Monterey County
Matthew P. Johnson
Associate Environmental Scientist / GIS Manager
Education
Bachelor of Science, Earth Systems
Science and Policy, California
State University of Monterey
Bay, Seaside, California, 2001
Microsoft Certified Systems
Engineer, New Horizons
Computer Learning Center
Work Experience
Associate Environmental Scientist /
Geographic Information Systems
Manager, DD&A
Geographic Information Systems
Research Analyst, California
Department of Fish and Game,
Marine Region
Mr. Johnson has 14 years of experience working in the environmental field as an

Associate Environmental Scientist, with a background in environmental science and
policy. During his tenure at DD&A Mr. Johnson has also served as the manager of
the Geographic Information Systems (GIS) department. At DD&A his
responsibilities include project management, rare plant surveys, protocol-level
wildlife surveys, biological monitoring, and wetland delineations; preparation of
biological reports, Mitigation Monitoring and Restoration Plans, CEQA documents
and regulatory permit applications; Global Positioning System (GPS) data collection;
Geographic Information Systems (GIS) analysis; and graphics support for biological
and planning documents. Mr. Johnson holds state and federal permits to handle
multiple listed wildlife species and is expert in conducting protocol presence/absence
surveys for California red-legged for, California tiger salamander, and additional
wildlife species.
He has experience in several GIS software platforms and their application to land
planning policy and regulation. He has also worked with a variety of GIS datasets
from several different agencies including; USGS, CCC, SPOT, MBARI, Digital
Globe, several counties and cities, and several universities in the California State
system.
His technical expertise is demonstrated in his background projects and training:
Central Coast Joint Data Committee

Monterey Peninsula Audubon
Society
California Department of Fish and Wildlife (DFW)

U.S. Fish and Wildlife Service (Service)
National Marine Fisheries Service (NOAA Fisheries)
Army Corps of Engineers (ACOE)
Regional Water Quality Control Board
Extensive experience conducting biological
monitoring, pre-construction wildlife surveys on a variety of projects, and
biological trainings to inform construction crews and other project team
members of the sensitive resources present within project sites and the
protection measures afforded to them.
o
o
o
o
o
o
Registrations/Certificates
Trimble Certified GPS Operator
Wetlands Regulation and
Mitigation Training Seminar
Special Status Amphibians and
Reptiles of Northern California
The Western Section of Wildlife
Society Annual Meeting and
Symposium
USFWS Federal Recovery Permit
TE-091857-0 - California tiger
salamander and California redlegged frog (authorized
individual)
CDFG Scientific Collection permit
SC-007701 -: Mammals,
Reptiles, Amphibians, and
Freshwater/terrestrial
invertebrates
CEQA Basics Workshop (AEP)
40 Hour HAZWOPER Certification
ESRI User Conference
Navigating the Environmental
Compliance Process in Coastal
California,
Elkhorn
Slough
Workshop
Experience working closely with resource and regulatory agencies

in permitting projects of varying size and complexity, including:
Proficiency in conducting biological surveys, including protocollevel surveys for special-status wildlife and plant species such as the
California tiger salamander, California red-legged frog, sand gilia,
Monterey spineflower, and seaside birds beak.
Technical experience includes preparing

biological reports for a broad range of environmental documentation in
accordance with CEQA and NEPA requirements and local, State, and
federal policies and regulations, including the Clean Water Act and the
federal and state Endangered Species Acts, including:
o
o
o
o
o

Mitigation Monitoring and Reporting Programs (MMRP)
Permit Applications for CDFG, ACOE, USFWS, etc.
Botany, wildlife, and wetland science experience gained working on a

wide variety of projects involving special-status species and sensitive
habitats.
Matthew P. Johnson
Associate Environmental Scientist/GIS Manager
Project Experience:
Water Facilities Projects:
Tank Design and Improvements Project EA/IS MCWD
Montevina Water Treatment Plant IS/MND, San Jose Water Company
Rinconada Water Treatment Plant EIR, Santa Clara Valley Water District
Ostwald Pipeline Replacement Project IS/MND, San Jose Water Company
Pure Water Groundwater Replenishment Biological Surveys, Monterey
Regional Water Pollution Control Agency
Linear Projects:
Carmel Valley Class I Bicycle Trail IS/MND Monterey County
Carmel Valley Road Improvements IS/MND Monterey County
Highway 25 Safety Improvement NES - Caltrans District 4 and Council of
San Benito County Governments
Fort Ord Habitat Conservation Plan EIR and EIS Fort Ord Reuse
Authority and the U.S. Fish and Wildlife Service
Monterey Bay Regional Desalination Project Biological Assessment
MCWD, Cal-American Water, and U.S. Bureau of Reclamation
Santa Lucia Preserve Habitat Conservation Plan EA Rancho San Carlos
Partnership and the U.S. Fish and Wildlife Service
Biological, Wetland Assessment, and NES Projects:
Haskells Landing City of Goleta, The Chadmar Group
Whispering Oaks Business Park and MST Facility Monterey Salinas
Transit
Marina Station EIR City of Marina
Seaside Main Gate EIR City of Seaside
Mazda Raceway/Laguna Seca Recreation Area Protocol-level CTS Surveys,
Monterey County Department of Parks and Recreation
Ferrini Ranch Bio Assessment, Bollenbacker & Kelton, Inc.
Fort Ord Natural Reserve OU-1 Rare Plant Survey and Reporting, HGL,
Inc.
Fort Ord Wildlife Surveys, Shaw Environmental, Inc.
Fort Ord Dune State Park Rare Plant Surveys, California State Parks
Snowcreek Biological Assessment Town of Mammoth Lakes, Chadmar, Inc.
Thorne Road Bridge NES, Monterey County Department of Public Works
Los Gatos Creek Trail Reach 5B/C NES/BA, City of San Jose
Biological Monitoring Projects:
Sand Gilia Restoration Monitoring, UC MBEST
OU-1 FONR Well Removal Biological Monitoring Project, HGL Inc.
Implementation of the EIR Mitigation, Monitoring and Reporting Plan at
the Ridgemark Wastewater Treatment and Recycled Water Improvement
Project, Sunnyslope Water District
ITSI Biological Support Services, ITSI Gilbane
MCWD Well 32 & 33 Biological Monitoring, MCWD
Gilroy Three Trails Biological Monitoring, City of Gilroy
Raptor Nest Monitoring, CSUMB
Pre-Construction Surveys and On-Site Biological Monitoring Services for
CSUMB Demolition, CSUMB
Noble Gulch Sewer Improvement Project, HDR
CulturalResources
GaryS.Breschini,PH.D
FinalEIR
September2015
FinalEIR
September2015
GARY S. BRESCHINI, PH.D.

ARCHAEOLOGIST
Education
Ph.D.
Washington State University, 1983 (Anthropology)
M.A.
Washington State University, 1975 (Anthropology)
B.A.
University of California, Santa Barbara, 1971 (English)
Dr. Breschini is field director or principal investigator for over 4,500 archaeological
reconnaissance, excavation, evaluation, overview, mitigation, and research projects.
With extensive experience in archaeology, cultural resource management, rock art
documentation, and human osteology in Central and Northern California, Dr.
Breschini has been published and continues to publish in journals pertinent to his
profession, and has written the text for the archaeology sections of environmental
documents (NEPA and CEQA) since 1975.
Professional Certifications
Accredited expertise in Archaeological Field Research (Society of Professional
Archaeologists)
Accepted for inclusion in the Directory of California Archaeological
Consultants (Society for California Archaeology - 1979)
Life Credentials in Anthropology, Board of Governors, California
Community Colleges, 1975
Professional Memberships
American Association of Physical Anthropologists
Society for American Archaeology
Society for California Archaeology
Society of Professional Archaeologists
Teaching Experience
Washington State University
Hartnell Community College
Cabrillo Community College
Monterey Peninsula College
FinalEIR
September2015
HydrologyandWaterQuality:Groundwater
PhylissStanin,PG,CEG,CHG,ToddGroundwater
FinalEIR
September2015
FinalEIR
September2015
P h y l l i s S t an i n , P G , C E G , C H G
Vice President and Principal Geologist
EDUCATION
MS,EnvironmentalManagement,Hydrogeologythesis,
UniversityofSanFrancisco
BS,Geology,UniversityofNorthCarolina
REGISTRATIONS
ProfessionalGeologistCalifornia,No.5311
CertifiedEngineeringGeologistCalifornia,No.1899
CertifiedHydrogeologistCalifornia,No.482
RegisteredGeologistArizona,No.45605
PROFESSIONALSUMMARY
Phyllis Stanin has been a professional geologist for more than 35 years with expertise in
hydrogeologyandgroundwaterbasinmanagement,andaparticularemphasisonmanaged
aquifer recharge (MAR) and conjunctive use. She also has experience with groundwater
resource development including production and injection wells, geophysical applications,
aquifer testing, and monitoring. She has conducted numerous regional hydrogeologic
assessments using advanced analytical and numerical modeling tools. Her expertise also
includes fate and transport of contaminants in groundwater including constituents of
emergingconcern.ShehasperformedgeologicinvestigationsinsevenstatesacrosstheU.S.
andconductedindependentresearchonimpactstogroundwaterflowfromgeologicfaults.
Groundwaterprojectsdemonstratingthevarietyofherexperiencearedescribedbelow.
ManagedAquiferRecharge(MAR)
GroundwaterBankingandGroundwaterModelConstruction,KernCountyCA
Ms.StaninisProjectManagerforanevaluationofgroundwaterbankingoperationsinKern
County,California.Thisongoingprojectinvolvesthedevelopmentofaregionalgroundwater
flowmodeltoassesstheeffectsofthegroundwaterbankingprojectsontheKernFan.The
MODFLOWgroundwatermodelcoversa430squaremilearea,andcomprisesathreelayer
aquifersystemusingover1millionmodelcells.Calibrationtodynamicflowconditionsover
the period 19862010 was completed in 2013; as of 2015, a revised model calibration is
underway.
2490 Mariner Square Loop, Suite 215 | Alameda, CA 94501 | 510 747 6920 | toddgroundwater.com
Phyllis Stanin, PG, CEG, CHG
AquiferCharacterizationandRechargeFeasibilityStudy,CityofModesto,StanislausCounty,
CA
Ms. Stanin is the project manager for an ongoing groundwater study for the City of
Modesto. The project is the first step in the Citys Managed Aquifer Recharge (MAR)
Program to develop strategies for recharge of treated surface water for subsequent
recovery.Forpartoftherechargeanalysis,ToddGroundwaterismodifyingandapplyingthe
USGS MERSTAN model, a regional groundwater flow model developed by USGS using the
OneWaterHydrologicModelcode.Thisisoneofthefirstgroundwatermodelsconstructed
in this platform, which incorporates numerous modules for the improved simulation of
surfacewatergroundwaterinteraction.
Groundwater Replenishment Project, Monterey Regional Water Pollution Control Agency
(MRWPCA),MontereyCounty,CA
Ms.Staninhasservedastheprojectmanagerandleadhydrogeologistonthisproject,which
involves planned recharge of highly treated recycled water into the Seaside Groundwater
Basin. Detailed hydrogeologic assessments have been completed over several years
including the evaluation of target aquifers, recharge methods, and injection and recovery
sites. Todd Groundwater also completed a preliminary design for vadose zone wells to
recharge the shallow aquifer and deep injection wells for replenishment of the deeper
aquifer. The conceptual design was completed with the application of a steady state
numerical model constructed by Todd Groundwater. Ms. Stanin has worked with the
DivisionofDrinkingWater(DDW)onprojectdesignandthemonitoringwellprogram.CEQA
complianceisunderwaywiththepreparationofanEIRwithMRWPCAastheleadagency;
Ms.StaninisalsoprovidingtechnicalsupportfortheEIR(20082015).
RechargeOptimizationStudies,RanchoCaliforniaWaterDistrict,RiversideCounty,CA
Ms.StaninwasProjectManageroftwostudiestooptimizerechargebasin percolationfor
theRanchoCaliforniaWaterDistrictinRiversideCounty.Thestudieswereconductedonthe
LowerValleDeLosCaballos(VDC)andUpperVDCrechargebasins.TheLowerVDCproject
involved a field investigation of percolation basin properties, vadose zone testing and
impacts of groundwater elevations on percolation. A hydrogeologic conceptual model and
localscale groundwater model were used to optimize the amount of water that could be
rechargedundervaryinggroundwaterconditions.TheUpperVDCprojectalsoinvolvedthe
constructionandapplicationofalocalscalemodeltooptimizerechargeover110acresof
basins. The fate of recharge water including downgradient and vertical transport was
modeled to determine the amount of recharge being captured by local wells. Various
optimizationstrategiesweremodeledtobalanceshorttermtreatmentobjectiveswithlong
term storage. The project also involved the recommendation of a well maintenance
program and meetings with regulators from the Department of Public Health on the
Districtspermit(20092012).
Hydrogeologic Investigation of Recharge Potential, Western Municipal Water District,
RiversideCounty,CA
Ms. Stanin served as Project Manager for a hydrogeologic investigation to evaluate the
potential for recharge at five sites in the Arlington Basin for Western Municipal Water
District. Sites were evaluated for the enhancement of groundwater recharge with
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stormwater, recycled water, and/or imported water. The project involved the design and
implementationofafieldprogramtoassesslithology,textures,infiltrationrates,hydraulic
andgeotechnicalpropertiesofthevadosezonebeneaththesites.Analyticalmodelingwas
conductedtoexaminemoundingandtransmittingcapacities.Subsequently,twositeshave
beenselectedforadditionalinvestigationandpreliminarydesign(20112012).
EdwardsAquiferOptimizationStudy,EdwardsAquiferAuthority,SanAntonio,TX
Ms.Staninwasprojectmanagerandleadhydrogeologistforamultiyearstudyofenhanced
recharge strategies within this extensive karst aquifer system. The study applied a five
county MODFLOW groundwater model developed by the USGS to evaluate volumes and
sourcesofpotentialrecharge,wellfieldsitinganddesignforrecovery,andthepotentialfor
recirculating water through the aquifer to increase residence time in the aquifer (2006
2009).
RechargeFeasibilityandSaltLoadingStudies,CityofCorona,RiversideCounty,CA
Ms. Stanin has provided hydrogeologic support to the City on a variety of projects. In a
recharge feasibility study, she directed a hydrogeologic investigation of a property in the
city, which has been identified by the city and Western Municipal Water District as a
potential recharge site for imported water. The investigation involved soil borings,
laboratory analyses, and singlering infiltrometer testing. Groundwater modeling was
conducted to assess potential mounding and groundwater response to various enhanced
recharge scenarios. In a separate project, she also served as Technical Director for an
evaluation of salt loading associated with potential recharge projects involving imported
water.Thisstudycombineddetailsofthebasinwaterbudgetwithsourcesandsinksoftotal
dissolved solids (TDS) and nitrate in the Temescal Groundwater Basin in Riverside County.
TheprojectincorporatedanorganizedapproachtotheanalysisdevelopedbytheSantaAna
Regional Watershed Protection Agency (SAWPA) and the Regional Water Quality Control
Board.TDSmodelingindicatedthat,whilesaltloadingwouldincreaseonamassbasis,the
lowerconcentrationsofTDSinimportedwaterwouldbebeneficialoveralltoTDSlevelsin
groundwater(20092010).
Hayfield Groundwater Storage Project, Metropolitan Water District of Southern California,
RiversideCounty,CA
As Project Manager for Todd Groundwater, Ms. Stanin directed several phases of the
Hayfield Groundwater Basin Storage project for Metropolitan Water District. The storage
project involved recharge of excess Colorado River water into the basin for subsequent
recovery. Initial projects focused on planning and facilities feasibility studies. In order to
developahydrogeologicconceptualmodeloftheundevelopedbasin,Ms.Stanindesigned
andimplementedanexploratoryboreholeandtestwellprogram,involvinginstallationof9
test wells and two monitoring wells, geophysical and flow logging, aquifer testing, and
groundwater sampling. Ms. Stanin conducted the hydrogeologic assessment of the field
programresultsandwasabletoidentifyareasforoptimizedrecoveryofbankedColorado
Riverwater(20022004).
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GroundwaterBasinManagementPlans(GWMP)
GroundwaterManagementPlan,KernDeltaWaterDistrict,KernCounty,CA
Ms.StaninhasassistedtheKernDeltaWaterDistrictwithavarietyofgroundwatersupport
services. Recently, she was the project manager and primary author of the Districts
GroundwaterManagementPlanUpdate.Theprojectinvolvedareassessmentofaquifers,
developmentofawaterbudget,anddocumentationofnumerousconjunctiveuseactivities
including a formal groundwater banking project with the Metropolitan Water District of
SouthernCaliforniaandotherwateragencies.TheplanwasadoptedinSeptember2013.
GroundwaterManagementPlan,CityofCorona,RiversideCounty,CA
For the last 10 years, Ms. Stanin has assisted the City of Corona with a variety of
groundwaterprojects.ShewastheprimaryauthoroftheCitysfirstGWMP.TheCityrelies
ongroundwaterforaboutonehalfofthetotalwatersupplyandhadexperienceddeclining
water levels in some portions of their service area. The plan involved original geologic
mapping and delineation of the Citys most productive aquifers, characterization of
groundwaterquality,anddevelopmentofagroundwaterbalance.ShealsoservedasProject
Manager for the construction and application of a MODFLOW groundwater flow model,
whichwasappliedtoevaluatevariousmanagementstrategiesofmanagedaquiferrecharge.
Theresultsoftheanalysiswasthatthebasincouldbesustainablymanagedwithavarietyof
conjunctiveusestrategies.ThefinalGroundwaterManagementPlanwasadoptedin2008.
Groundwater Management Plan, Wheeler RidgeMaricopa Water Storage District

(WRMWSD),KernCounty,CA
Ms. Stanin assisted WRMWSD with the preparation of the Districts first GWMP. The plan
included a Districtwide assessment of recent and historical water levels and groundwater
quality.TheplanincludedananalysisoftheDistrictscontractfortheStateWaterProject
andvariousKernCountybankingprogramsinwhichtheDistricthadinvested.Theanalysis
recommendedconditionsunderwhichsurfacewater,bankedwater,orgroundwaterwould
beprioritizedforuse.TheplanwasadoptedinNovember2007.
DevelopmentofBasinWideMonitoringPlan,SanBenitoCountyWaterDistrict(SBCWD),CA
Ms. Stanin was Project Manager for the development of a basinwide water quality
monitoringprogramforSBCWD.TheprojectinvolvedthedevelopmentofaGIScompatible
database of current and historical water quality data from more than 50 water systems,
more than 30 facilities with groundwater monitoring, and other state and local agencies.
The database and GIS are being used to assess current and historical water quality
conditionsinthebasin.Theresultsofthewaterqualityassessmentalsoarebeingusedto
optimizegroundwatermanagementactivitiesandmonitoringinthebasin.Theprogramwas
funded by an AB303 grant, which was obtained through a joint effort by the SBCWD and
ToddGroundwater(20022004).
GroundwaterResourceDevelopment
GroundwaterExplorationStudies,CityofCorona,RiversideCounty,CA
Overthelastdecade,Ms.StaninhasprovidedhydrogeologicsupporttotheCityonavariety
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of projects. Recently, she served as Project Manager and Lead Hydrogeologist for an
exploratoryborehole/monitoringwellprogramtoidentifyfavorableareasforfuturewater
supplywellsfortheCityofCorona.Theprojectinvolvedthedesignandimplementationofa
fieldprogramtodrillsixboreholesandinstallfivemonitoringwellstodelineateaquiferunits
in areas of limited groundwater data. The successful drilling and testing program included
geologic and geophysical logging, aquifer thickness and elevation mapping, water level
monitoringandmapping,waterqualitysamplingandanalysis,andisotopicandgeochemical
analyses.Thestudyproducestargetareasforwatersupplywellsandrecommendationson
welldesign(20122013).
GroundwaterDevelopmentforEcosystemRestoration,CaliforniaDepartmentofFishand
Game,CampCady,SanBernardinoCounty,CA
Ms. Stanin was project manager for a groundwater investigation at Camp Cady, on the
Mojave River, east of Barstow, CA. The goal of the project was to determine if damaged
riparian vegetation that previously supported a thriving ecosystem could be restored by
groundwater irrigation. Declines in shallow groundwater levels, among other factors, had
eliminated vegetation in some areas. To evaluate if deep pumping could provide
supplementalsupplyduringcriticaldrytimeswithoutloweringshallowwaterlevels,aseries
of11shallowpiezometersandfourmonitoringwellclusterswereinstalled.Projectresults
indicatedthatgroundwaterpumpingbelowtheregionalaquitardwasfeasibleinfavorable
areas with careful planning. Recommended locations, well design, and project costs were
alsoprovided(20112013).
Hayfield Groundwater Storage Project, Metropolitan Water District of Southern California,
RiversideCounty,CA
Ms. Stanin served as Project Manager for the design, drilling, installation, and testing of a
largediameter production well to recover stored water in the western portion of the
groundwater basin. The project resulted in a highyielding well producing 3,000 gpm with
lessthan30feetofdrawdown(20092010).
Well231ReplacementProject,RanchoCaliforniaWaterDistrict,RiversideCounty,CA
Ms. Stanin is currently serving as PrincipalinCharge for an evaluation of groundwater
quality conditions in the Lower Pauba Valley to site a replacement municipal production
well. The District has lost production recently due to elevated total dissolved solids (TDS),
arsenicandfluorideconcentrations.ToddGroundwaterhasidentifiedstratigraphicintervals
associated with some of the elevated constituents and is preparing a Preliminary Design
Reporttotargetspecificaquiferzonesfordevelopment.ToddGroundwaterisalsodesigning
atestwelltoevaluatetheverticaldistributionofcertainconstituentsinmoredetail.That
well will serve as a future monitoring well for the replacement production well (2014
2015).
Groundwater Characterization of Mining Dewatering and Bedrock Wells, Idaho Maryland
MiningCorp.(IMMC),GrassValley,NevadaCounty,CA
Ms.StaninservedastheProjectManagerandleadhydrogeologistforanevaluationof
dewateringimpactsfromtheIdahoMarylandMineinNevadaCounty,CA.TheIMMChad
plannedtoreopenthepreviouslyabandonedmineforadditionalgoldminingoperations.
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ToddGroundwaterprovidedhydrogeologicsupporttoIMMCincludinganassessmentof
groundwaterconditionsandpotentialimpactsfromdewateringofmineworkingsonlocal
bedrockwells.Theassessmentsupportedthepreliminarydewateringdesignandprovided
animpactsanalysisfortheprojectEIR(20062011).
DepthSpecificMonitoringandAquiferCharacterization,SanBenitoCountyWaterDistrict
Ms.StaninservedasProjectManagerforanaquifercharacterizationanalysisincludingthe
installationandtestingofadeepnestedmonitoringwellintheGilroyHollisterGroundwater
Basin. The well was needed to characterize the vertical distribution of boron and other
constituents of concern with depth to identify future development areas. Todd
Groundwater designed, installed, and tested a 770foot nested monitoring well with five
depthdiscrete intervals. Depthspecific sampling and advanced geophysical logging,
including a combined magnetic resonance tool, allowed for the identification of depths to
avoidforfuturedevelopmentbasedonelevatedboronconcentrations(20052007).
GroundwaterCharacterizationandModeling,CityandCountyofHonolulu,Oahu,HI
Ms. Stanin was the Project Manager and lead hydrogeologist for the City and County of
Honolulu Hawaiis well optimization program. This study included the evaluation of the
aquifer system, a regional water balance, and detailed spatial and temporal correlation of
groundwater pumping and upconing in water supply wells. The project also involved
developmentofa3Dnumericalgroundwatermodeltobeusedasanongoingmanagement
toolbytheBoardofWaterSupply(20042006).
CityofDallas,LongRangeWaterSupplyPlan(LRWSP),DallasWaterUtilities,Dallas,TX
AsasubconsultanttoHDREngineering,Ms.Staninservedasprojectmanagerandlead
hydrogeologistforaregionalgroundwaterassessment.AlthoughtheCityhadhistorically
reliedexclusivelyonsurfacewaterreservoirsforwatersupply,optionsforsupplemental
groundwatersupplieswereevaluatedaspartoftheLRWSP.Theevaluationinvolvedmajor
andminoraquifersina13countyareaofnortheastTexas.Developmentstrategieswere
analyzedbyupdatingandapplyingtheWaterAvailabilityModels(WAMs),consistingoftwo
MODFLOWgroundwaterflowmodelsdevelopedbytheTexasWaterDevelopmentBoard.
Strategiesincludedpumpinggroundwaterfordirectuse,conveyancetosurfacewater
reservoirs,andnonpotableuseofshallowgroundwaterbeneaththeCity(20122015).
RegionalHydrogeologicCharacterization
Groundwater Basin Conceptual Model, BighornDesert View Water Agency and Mojave
WaterAgency,SanBernardinoCounty,CA
Ms. Stanin was project manager for development of regional hydrogeologic conceptual
modelsandassessmentofthefeasibilityofamanagedaquiferrecharge(MAR)projectfor
three high desert basins. Hydrogeologic data were used to estimate groundwater storage
andidentifyareaswithcoarsegrainedlithologyandfavorablegroundwaterquality.Water
levelsweremappedacrossthebasinswithaparticularemphasisonimpactsfromfaultingor
shallow bedrock. The study found that the Ames Valley basin would benefit most from a
MARproject,giventheoccurrenceofcoarsegrainedsedimentsbeneathtwomajorwashes
downgradientofgeologicfaults(20062007).
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Groundwater Basin Conceptual Model, Baja and Centro Subareas, Mojave River
GroundwaterBasin,MojaveWaterAgency,SanBernardinoCounty,CA
Ms. Stanin was project manager for a multiyear study of two subareas comprising over
2,000 acres in the lower portion of the adjudicated Mojave River Groundwater Basin. The
projectincludedsynthesizedfindingsfromhistoricalstudiesdatingbacktoearly1900swith
analysesofnewgeologic,groundwaterlevelandwaterqualitydataintoonecomprehensive
document, which will be used to support future groundwater management planning,
including managed aquifer recharge of imported State Water Project water. The project
included conceptual and numerical groundwater flow model development and review;
characterizationofbasingeometry,aquiferproperties,impactsofhydraulic(fault)barriers
ongroundwaterflow,groundwaterwaterleveltrendanalysis,evaluationofimpactsoflocal
and regional pumping and dam construction on surface water flows and downstream
recharge along Mojave River; transient basin subarea water balance development;
MODFLOW model water budget extraction and review; groundwater quality
characterization;andwaterdemandforecasting(20102013).
GroundwaterSupporttoEnvironmentalImpactReports(EIR)
Division of Oil, Gas, and Geothermal Resources (DOGGR) SB 4 EIR, Analysis of Oil and Gas
WellStimulationTreatmentsinCalifornia
As a subconsultant to Aspen Environmental Group, Ms. Stanin led the Todd Groundwater
analysis of groundwater impacts from well stimulation (including hydraulic fracturing) for
the statewide programmatic EIR. Working with DOGGR as the lead agency, Ms. Stanin
developedamethodologyfordescribingtheenvironmentalsettingandimpactsanalysisof
California groundwater from well stimulation including development and application of
significance criteria. She also assisted with the development of project standards and
alternatives.TheDEIRwasreleasedinJanuary2015.
KernRiverWaterAllocationPlan(WAP)EIR,KernDeltaWaterDistrict,KernCounty,CA
AsasubconsultanttoESAWater,Ms.Staninledtheanalysisofgroundwaterimpactsfrom
implementation of the Districts Kern River WAP. The WAP consisted of a series of
prioritized management actions for the full use ofthe Districts entitlement to river water
for irrigation and recharge in spreading basins. The EIR project involved a detailed
assessmentofriverdiversionsanduseoveran11yearstudyperiodandpotentialimpacts
to groundwater when other parties replaced previouslyreleased river water with
groundwater. The impacts analysis focused on water levels and water budgets north and
southoftheKernRiver.Asof2015,asupplementalEIRisinpreparation.
ContaminantHydrogeologyandGroundwaterQualityStudies
SouthBasinGroundwaterProtectionProjectforOrangeCountyWaterDistrict,CA
Ms.Stanindirectedthisassessmentofimpactstowatersupplywellsfromperchlorateand
volatile organic compounds (VOCs). Data from 55 potential contaminant sources within a
1.5mileradiusofthewellswereincorporatedintotheanalysis.Theevaluationalsoincluded
a regional assessment, documenting groundwater flow directions from the 1950s to the
present as pumping patterns changed throughout the groundwater basin. Capture zones
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wereanalyzedforimpactedwells.Ananalysisofinorganicwaterqualitydataandpumping
datarevealedthatcontaminantconcentrationswentupduringnonpumpingconditionsand
covaried with key inorganic constituents in shallow groundwater. These data led to a
preliminary assessment of contaminant migration pathways and identification of key data
gaps.Aworkplanwasdevelopedtoaddressdatagaps(20062007).
EvaluationofPerchloratePlume,RanchoCordova,CA
Ms. Stanin provided hydrogeologic and litigation support for an industrial facility near
RanchoCordova.Thisareaischaracterizedbycommingledperchlorateplumeswithimpacts
to offsite water supply wells. Technical evaluations directed by Ms. Stanin included
groundwater contaminant characterization, plume delineation, source identification, and
watersupplyimpacts.
EvaluationofPerchlorateImpactstoMunicipalWells,SantaClaritaValley,CA
Ms.Staninprovidedhydrogeologicandlitigationsupportforfourwateragencieswithwater
supply wells impacted by perchlorate near Santa Clarita in Southern California. Her work
involvedanevaluationofthefateandtransportofcontaminantsincludingperchloratefrom
a nearby industrial facility including impacts to surface water and groundwater. The study
also evaluated use of pumping water supply wells for plume containment and other
remedial strategies. Ms. Stanin has also served as a technical representative of the water
companies to state and local agencies. This work included a technical presentation of
perchlorate in water supply wells to Assemblyman Keith Richman and technical
presentationstoDTSCandworkingwithDTSCtodevelopremedialoptions.
FateandTransportofNDMAforWateReuseFoundation
Ms.StaninservedasLeadHydrogeologicInvestigatorforaresearchprojectonthefateand
transportofNDMAinthesaturatedzone.TheprojectwasfundedbytheWateReuse
Foundationandparticipatingwateragenciesandwasconductedinconcertwithresearchers
fromtheUniversityofCaliforniaBerkeley,UniversityofCaliforniaRiverside,ArizonaState
University,andToddEngineers(nowToddGroundwater).NDMAoccurrenceingroundwater
wasanalyzedatfoursitesinCaliforniatoanalyzeevidenceofdegradationorattenuationof
NDMAinthesaturatedzone.NDMAreleaseswerefromhistoricalindustrialsources,
artificialrechargeofchlorinatedwastewaterintospreadingbasins,andtheinjectionof
treatedwastewaterintohydraulicbarriersforseawaterintrusion.Resultswerepublishedin
WateReusepublicationInvestigationofNNitrosodimethylamine(NDMA)Fateand
Transport,2006(ISBN:0974758663).
EnvironmentalInvestigations,SanGabrielValleySuperfundSite,LosAngelesCounty,CA
Ms. Stanin served as project manager for environmental investigations and remedial
measures for a landfill site in the San Gabriel Basin. This included a regional groundwater
investigation over a 50 squaremile area of the basin, analysis of conjunctive use at the
Santa Fe Spreading Grounds, and evaluation of the impacts on local groundwater flow
directionsandcontaminant transport. The projectalsoinvolvedhydrogeologicsupportfor
constructionandcalibrationofathreedimensionalfinitedifferenceflowmodel.Workalso
included specific hydrogeologic evaluations, groundwater modeling, identification and
evaluationofPotentialResponsibleParties(PRPs),allocationalternatives,impactstowater
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supply wells, and support on numerous regulatory, technical, and Superfund issues. Todd
subsequentlyprovidedcompliancewiththesitesMonitoringandMitigationProgram.
UndergroundInjectionControl(UIC)ProgramExperience
ClassIUICPermit,CaliforniaSpecialtyCheeses,SanJoaquinCounty,CA
Ms. Stanin prepared a successful Class I UIC permit application package for California
Specialty Cheeses for deep injection of cheese processing wastes near Lathrop, CA. The
application included an independent geologic assessment of subsurface stratigraphy and
lithology, structural setting, target zones for injection, preparation of response plan, and
estimated injection capacity. The application was approved by the U.S. Environmental
ProtectionAgency,RegionIX,withonlyminormodification.TheClassIpermitwasonlythe
thirdsuchpermitthathadbeenissuedinCaliforniaatthattime.Followonworkincluded
planningforthedrillingandinstallationforinjectionwells(20052007).
DeepInjectionFeasibilityStudy,CityofGoodyear,MaricopaCounty,AZ
Ms.Staninwasprojectmanagerforafeasibilitystudyfordeepinjectionofbrinegenerated
fromtheCitysgroundwatertreatmentprogram.Thestudyinvolvedanassessmentofthe
regional geology and hydrogeology, including research on potential injection near a
subsurface salt deposit. The project also involved assessment of the U.S. Environmental
Protection Agencys (USEPA) UIC regulations for Arizona. Preliminary costs and
recommendations for additional investigation were provided. Limitations and data gaps
wereidentifiedtoassisttheCitywithadditionalevaluation,ifwarranted(2006).
GroundwaterExpertWitnessandPeerReviewExperience
ExpertonaConfidentialWellFailure,KernCounty,CA
Ms. Stanin provided expert witness and deposition testimony for a consulting firm being
suedforfailureofadeepirrigationwell.Thecaseinvolvedareviewofregionalgroundwater
conditions, construction, production, and specific capacity data for nearby irrigation wells,
anddailyrecordsofdrilling,development,andtesting.The casealsoinvolvedStandardof
Carepracticesforwelldrilling.Thecasesettledfavorablyforthedefendant.(20132014).
CourtappointedExpertonGroundwaterImpactsnearStockton,CA
Ms.StaninprovidedexperthydrogeologicsupporttotheEasternDistrictinUSDistrictCourt
duringasettlementconferencebetweenplaintiffsanddefendants.Thesupportinvolveda
writtenassessmentofthesourceofsoilandgroundwatercontaminationataformer
industrialsiteincludingtransportandtimingofrelease.Supportforthesettlement
conferenceincludeddevelopmentofatimelineforremedialactivitiesandregulatory
compliance(2012).
ExpertonGroundwaterFateandTransport,OrangeCountyWaterDistrict,OrangeCounty,
CA
Ms.StaninprovidedexpertwitnessandlitigationsupportservicestoOrangeCountyWater
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District regarding impacts to water supply wells from perchlorate and volatile organic
compounds (VOCs). The case, Orange County Water District, plaintiff, vs. Sabic Innovative
PlasticsUS,LLC,etal.,defendants,wasfiledinCaliforniaSuperiorCourt,CountyofOrange
in2008.Ms.StaninprovidedsixdaysofdepositiontestimonyfromAprilthroughNovember
2009regardingtheanalysisofpotentialsourcesofcontaminants.
ExpertonGroundwaterFateandTransport,SantaClarita,CA
Ms.Staninprovidedexpertwitnessandlitigationsupportservicestofourwatercompanies
with water supply wells impacted by perchlorate near Santa Clarita, California. The case,
Castaic Lake Water Agency, Newhall County Water District, Santa Clarita Water Company,
and Valencia Water Company, plaintiffs, vs. Whittaker Corporation; Santa Clarita, LLC;
RemediationFinancial,Inc.;andDoes110,Inclusive,defendants,wasfiledinUnitedStates
DistrictCourt,CentralDistrictofCalifornia.Projectworkinvolvedanevaluationofthefate
and transport of contaminants including perchlorate from a nearby industrial facility
includingimpactstosurfacewaterandgroundwater.Ms.Staninassistedwithpreparationof
anexpertreport,severalDeclarations,andprovideddepositiontestimony(20032007).
GroundwaterExpert/PeerReviewPanelforRedwoodCity,CA
Ms.Staninwasaskedtoevaluatethefeasibilityofdrillingwatersupplywellsassociatedwith
aproposeddevelopmentonSanFranciscoBay,referredtoastheSaltworksproject.The
evaluationprocessexaminedthefeasibilityoftheproposedsourcesofsupplytodetermine
iftheCityshouldproceedwiththedevelopmentofanEnvironmentalImpactReport(EIR)in
compliancewithCEQA.Ms.Staninalsoconductedanassessmentofpotentialgroundwater
useandwelllocationstoprovidebackupwatersupplytotheCity(20092011).
ExpertonLandfillLitigationLossofPermit,HarrisCounty,TX
Ms.Staninprovidedexpertwitnessandlitigationsupportforalawsuitagainstaninsurance
companyforgroundwatercontaminationandlossofanoperatingpermit(BrowningFerris
Industriesvs.CertainUnderwritersofLloydsofLondon,etal.).Projectworkinvolvedthe
examinationofCaliforniaChapter15permittingrequirementsovertimeandgroundwater
contaminantfateandtransportevaluations.Ms.Staninprovidedanexpertreport,
numerousaffidavits,anddepositiontestimony(20042008).
LitigationSupport,MunicipalLandfill,FresnoCounty,CA
Ms.StaninservedasanExpertWitnessongroundwatercontaminationinacivillitigation
againstahazardouswastehaulerforasbestosdisposalinalandfillinFresno,California.
Technicalcomponentsoftheprojectincludecharacterizationoflocalgroundwater
contamination,regionalgroundwaterflow,andvadosezonecontaminanttransport(1997).
PeerReviewofContaminationCharacterization,LosAngelesCounty,CA
Ms.Staninprovidedapeerreviewandhydrogeologicanalysisforametalsrecyclingfacility
in Los Angeles County. Analysis included groundwater elevation and contaminant plume
mapping, identification of chemicals of concern including VOCs and petroleum
hydrocarbons, evaluation of soil gas data, meeting with regulatory agencies, and
preparationofasitewidetechnicalreport.
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Publications/Panels/Presentations
ApproachtoGroundwaterImpactsAnalysis,DOGGRSB4EIR,InvitedSpeaker,Groundwater
ResourcesAssociationSymposium,OilGasandGroundwaterinCalifornia,WiseProduction
andProtectionofourValuableNaturalResources,February18,2015.
Groundwater Replenishment in the Seaside Basin: Increasing Basin Yield with Recycled
Water, 14th Biennial Symposium on Managed Aquifer Recharge, Groundwater Resources
AssociationandArizonaHydrologicalSociety,July31,2014.
RechargeintheAmesValley:MakingitHappen,withD.CraigandE.Lin,ToddEngineersand
M. West, BighornDesert View Water Agency, Managed Aquifer Recharge Symposium,
Increasing Opportunities for Groundwater Storage, National Water Resources Institute
(NWRI),January26,2011.
Deep Well Injection for Brine Disposal, invited Speaker on Challenges and Progress in
Developing Brackish Groundwater as a Sustainable Water Supply Panel, 9th Annual Multi
StateSalinityCoalitionSummit,January2009.
Benefits of Recycled Water Recharge of a Coastal Groundwater Basin, with T.G. Cole, R.B.
Chalmers,andR.B.Holden,proceedingsoftheWateReuseAssociationAnnualConference,
Seattle,WA,September2009.
ComplexitiesofUsingRecycledWatertoRechargeanOverdraftedGroundwaterBasin,with
T.G.Cole,R.B.Chalmers,andR.B.Holden,proceedingsoftheWateReuseAssociationAnnual
Conference,NewportBeach,CA,March2008.
StoringWaterinCaliforniaDesertBasins:SelectionofManagedAquiferRechargeSitesinthe
Ames Valley Groundwater Basin San Bernardino County, CA, with E. Lin, A. Garcia, and L.
Eckhart, at Increasing Groundwater Storage to Meet Californias Future Demand:
Challenges and Solutions, Groundwater Resources Association, 3rd Symposium in the
GroundwaterResourceSeries,June2007.
Investigation of NNitrosodimethylamine (NDMA) Fate and Transport, WateReuse
Foundation publication 0200201, IBSN: 0974758663, Copyright 2006 (Research Project
Team Member with Todd Engineers, University of California Berkeley, University of
CaliforniaRiverside,andArizonaStateUniversityfundedbyWateReuseFoundation).
Challenges for Recharge of Recycled Water, at Assessment, Use, and Management of
Groundwater in Areas of Limited Supply, Groundwater Resources Association (GRA) 15th
AnnualGRAMeetingandConference,SanDiego,California,September21,2006.
TheOccurrence,Fate,andTransportofNDMAinCaliforniaGroundwater,FiveCaseStudies,
Page 11 of 12
at Emerging Contaminants in Groundwater: A Continually Moving Target, Groundwater

Resources Association (GRA) 18th Symposium on Groundwater Contaminants, Concord,
California,June78,2006.
StableandOtherIsotopeTechniquesforPerchlorateSourceIdentification,withW.Motzer,
T.Mohr,S.McCraven,EnvironmentalForensics,v.7,no.4,pp89100,March2006.
Perchlorate:20thCenturyContaminant21stCenturySolutions,withW.Motzer,Southwest
Hydrology,v.2,n.6(November/December2003issue),pp.2426.
Hayfield Conjunctive Use, at Sustaining Groundwater Resources, the Critical Vision,
Groundwater Resources Association (GRA) 11th Annual GRA Meeting and Conference,
NewportBeach,California,September1819,2002.
East Meets West National Water Solutions, invited Speaker on Water Quantity Issues
Panel,WaterResourcesConference,Holland&Knight,UniversityofFlorida,October2001.
OptimizingGroundwaterManagementStrategiesintheEdwardsAquifer,withD.K.Todd,in
ProceedingsoftheWorldWaterandEnvironmentalResourcesCongress,May2024,2001,
Orlando,Florida,DonPhelpsandGeraldSehlke,editors.
ChallengestoConjunctiveUsePrograms,withD.K.ToddandI.Priestaf,invitedConference
Talk Conjunctive Use: Successful Experiences and New Frontiers, educational conference
sponsoredbyAssociationofGroundWaterAgenciesandtheAmericanGroundWaterTrust,
April1112,2001,Ontario,California.
ProfessionalContributions
ManagedAquiferRecharge(MAR)StandardsCommittee,AmericanSocietyofCivilEngineers
(ASCE)andEnvironmentalWaterResourcesInstitute(EWRI),MARGuidelinesDevelopment
Subcommittee,2004topresent.
AmericanWaterWorksAssociation(AWWA),MemberoftheWaterResourcesManagement
DelegationtoCuba,2002.
Page 12 of 12
HydrologyandWaterQuality:SurfaceWater
SchaafandWheelerConsultingCivilEngineers
(DanielSchaaf,P.E.andAndrewSterbenz,P.E.)
FinalEIR
September2015
FinalEIR
September2015
S c haa f & W he e le r F i rm P ro f i le
Schaaf & Wheeler

Schaaf&Wheelerisa32personcivilengineeringfirm,with17Californiaregisteredprofessional
engineers.Ourexperiencedengineerscomprehensivelyresolvewaterresourcesissues
throughoutCaliforniaandthewesternUnitedStates.Ourprojectsgenerallyrangefromlarge
floodcontrolprojectsandFEMAfloodinsurancestudiestolocalagencypublicworks
infrastructureprojectswater,recycledwater,sewer,andstormdrainplanninganddesign.
AlthoughcertifiedbytheStateofCaliforniaasasmallbusinessenterprise(certification#40527),
Schaaf&Wheelerhasabroadreach.Ourengineersoperatefromfourlocations:Salinas,Santa
Clara,SanFrancisco,andSantaRosa.
Schaaf&Wheelerranksamongthetop25engineeringfirmsinSiliconValley,ascompiledbytheSanJos
BusinessJournal(December2014)andistheonlyfirmlistedtofocusexclusivelyonwaterprojects.
AreasofFocus
Schaaf&Wheelerhastenareasoffocuswithinthewaterresourcesdiscipline.
Hydrologyandhydraulicsanalyses,includingsiteevaluationsandmodeling;
Floodcontrolanalyses,includingfloodplainstudiesandchanneldesign,filingofletters
ofmaprevision,andFEMAcoordination;
Watershedassessments,erosionandsedimentcontrol,andbioengineeredchannel
stabilization;
Stormwatermanagementanddrainageservices,includingmasterplanning,engineering,
anddesignofurbanstormdrainsystemsandpumpstations;
Waterquality,includingdesignorreviewofbestmanagementpractices(BMPs)for
stormwatertreatmentandhydromodificationflowcontrolfacilities;
Potablewatersystemmasterplanning,modeling,engineering;anddesignofsupply,
storage,collectionanddistributionsystems,includingtanksandboosterstations;
Wastewatersystemmasterplanning,engineering,anddesignofconveyancesystems,
includingliftstations;
Recycledwatersystemsplanning,engineering,anddesign;includingreclamation
feasibilitystudiesandcustomerretrofits;
Constructionmanagement,constructionsiteobservation,constructioninspection
services,valueengineering,constructioncostanalysis,andconstructabilityreviews;
Projectmanagement,includingmanagementofsubconsultants,containmentofschedule
andcost,andcommunicationswithclientandstakeholders.
8/25/2015
S c haa f & W he e le r F i rm P ro f i le
ExperienceinMontereyCounty
Schaaf&WheelerhaspreparednumerousreportsandstudiesinMontereyCounty:
ReclamationDitch:DevelopmentoftheHECRASmodeloftheReclamationDitchfor
theMontereyCountyWaterResourcesAgency.PreparedtheZone9ImpactFeeStudy
andNexusReportfordevelopmentstormwaterimpactfees.
SalinasRiverLagoonFishScreen,20092011,OldSalinasRiver
PotreroRoadTideGateConfigurationandPerformanceStudy,2000,OldSalinasRiver
CarrLakeMultiPurposeFloodControlStudy,2002,portionoftheReclamationDitch
system
BryantCanyonFloodControlImprovements(Soledad),20052007,tributarytothe
SalinasRiver
CastrovillePumpStation,2005,tributarytoMoroCojoSlough.
BlancoDrainPumpStation,2007,tributarytoSalinasRiver
EspinosaPumpStation,20072008,tributarytotheReclamationDitch
SantaRitaPumpStation,20032004,tributarytoReclamationDitch.
JarvisLateralErosionProtection,20072008,tributarytoSantaRitaCreek.
UpperMerrittLakeHydraulicAnalysis,2012,floodplainstudy.
CityofSeaside,DryWeatherStormwaterDiversionPumpStationDesign,20082010.
CSUMontereyBay,StormWaterMasterPlan,2005.
FortOrdStormwaterSystemAssessments,2000,preparedfortheFortOrdReuse
Authority.
8/25/2015
Daniel J. Schaaf, PE Vice President - Schaaf & Wheeler

Education
BSCE, San Jose State
University
MSCE (Water Resources
Engineering), San Jose State
University
Licenses
Registered Civil Engineer,
California #C57617
Affiliations
American Society of Civil
Engineers
Association
Daniel J. Schaaf, PE has 20 years of project experience

encompassing the areas of flood control and drainage,
surface water hydrology, and physical and numerical
modeling. Dan has managed several large
hydrology/hydraulics, flood control and drainage projects.
He is skilled in open channel hydraulics, coastal and
estuary processes, 1D and 2D modeling, floodplain
mapping and storm drain master planning. He is currently
working on implementing modeling projects that integrate pipe and
surface flows using sophisticated 2D modeling software. He has
performed several FEMA Flood Insurance Studies and Letters of Map
Revisions for clients throughout California. He is proficient in modeling
and GIS software: GeoHEC-HMS, GeoHEC-RAS, TRIM3D, RMA-2, RMA-10,
MIKE 11, MIKE 21, MIKE-URBAN, MOUSE, EPA SWMM, Cybernet,
InfoSWMM, InfoWorks, QUAL2E, EPA-Net, ArcGIS 10.0, Spatial Analyst, 3D
Analyst, AutoCAD Map and ArcIMS.
Major Project Accomplishments
Planning and Design

Storm Drain Master Plan City of East Palo Alto (2014)
North Bayshore Storm Drain Master Plan City of Mountain View (2014)
North San Jose Drainage Master Plan - City of San Jose (2013)
Stormwater Master Plan - City of Los Altos (2011)
Stormwater Master Plan - County of Santa Cruz (2009-2010)
El Charro Specific Plan Channel Design City of Livermore (2005-2010)
Northside Pump Station Design - City of Alameda, Public Works Department (2010)
Storm Drain Master Plan and Sea Level Rise Study City of Alameda (2008-2010)
Storm Drain Master Plan - City of Paso Robles (2007)
Program Management for Storm Drain CIP City of Belmont Public Works (2005)
Storm Drain Master Plan - City of San Mateo (2004)
Storm Drain Master Plan and Subsequent Update City of Livermore (2003)
Hydrology and Hydraulics
Hydrologic & Hydraulic Model for Zone 7 Watershed Zone 7 Water Agency (2014)
Greenwood Road Culvert Replacement Hydrologic Study County of Napa (2014)
Oakville Cross Road Bridge Replacement No-Rise Study - County of Napa (2014)
Groundwater Replenishment Project EIR Hydrology - Urban Runoff Capture at Lake El Estero City of
Monterey (2013 -2014)
Review of Hydraulic Model for Lower Carmel River Carmel Area Wastewater District (2013 2014)
City of Sebastopol Northeast Area Specific Plan EIR Placeworks (2005 2008)
Isabel Interchange, Livermore, Storm Drain Alignments Mark Thomas & Associates (2006)
Pajaro River Breaching Alternatives - County of Santa Cruz (2006-2007)
El Charro Specific Plan Hydrology Study - City of Livermore (2005-2009)
Napa Sonoma Salt Marsh Restoration - US Army Corps of Engineers (1999)
Highway 46/101 Drainage Study - City of Paso Robles (2008-2009)
Livermore Airport Flood Protection Planning City of Livermore (2015)
Dam Break Analyses and Inundation Mapping for Little Grass Valley, Sly Creek, and Lost Creek Dams
South Feather Water Agency (2015)
Bear Gulch Station 46 Tank Failure Inundation Study California Water Resource Company (2015)
Silicon Valley BART Extension Floodplain Study - Valley Transit Athority (2012)
San Tomas Aquino Flood Study - Santa Clara Valley Water District (2012)
Last Updated: August 25, 2015
Daniel J. Schaaf, PE Vice President - Schaaf & Wheeler

Salt Creek Floodplain Analysis - Private Owner Redding (2012)
Flood Analysis and Bayfront Levee Wave Analysis - City of San Mateo (2010)
Arroyo Las Positas and Arroyo Mocho CLOMR - City of Livermore (2011)
Southern California Wildfire Post Fire Flood Study - FEMA (2003 and 2007)
Phelps Creek LOMR - UC Sanata Barbara (2009); Soscol Gateway Drainage Study - City of Napa (2005)
Hooke Creek Flood Insurance Study - San Bernardino County, FEMA (2005)
Mint Canyon Flood Insurance Study - Los Angeles County, FEMA (2008)
River and Stream Enhancement
Altamont Creek Oil Removal Study - City of Livermore (2009-2010)
East Arm Mountain Lake Enhancement, San Francisco - The Presidio Trust (2005)
Reclamation Ditch Channel Study - Monterey County Water Resources Agency (Ongoing)
South Bay Pond Interim Management Plan - Cargill Salt (2000-2004)
Andrew A. Sterbenz, P.E. Senior Engineer Schaaf & Wheeler

Education
BSCE, Massachusetts
Institute of Technology
MSCE, University of Texas at
San Antonio
Licenses
Registered Civil Engineer
California #C69703
Texas #93537
Affiliations
American Water Works
Association
Society of American
Military Engineers
American Public Works
Association
Monterey Bay Water Works
Association
Andrew A. Sterbenz, P.E. has over 25 years of

experience managing engineering organizations and
solving engineering problems, and is recognized for
developing and implementing creative solutions to
complex problems. In 2006-2007 and 2012-2013 he
served as the full-time District Engineer for the Marina
Coast Water District, managing a $150 million water and
sewer capital improvements budget that includes the
development of new groundwater, recycled and desalinated water
supplies for the former Fort Ord. He has prepared long-range water
supply plans in California and Texas. Plans include the projection of
population and water demands, the assessment of current water
supply availability, and the analysis of water management strategies to
meet projected shortages. He is adept at analyzing, researching,
planning, coordinating and executing strategies to achieve
organizational goals. Andy has prepared detailed plans and
specifications for bidding and construction for public agencies, and
managed construction projects for the client agencies. He has
conducted environmental studies and remediation design, and
assisted with environmental permitting. He is well experienced with
state and federal environmental regulations.
Major Project Accomplishments
Water and Wastewater Systems Planning and Design

Pure Water Monterey Groundwater Replenishment Project Denise Duffy & Assoc. Monterey
County, CA (2013-2015)
Reclamation Ditch Yield Study Monterey Penninsula Water Management District - Monterey
County, CA (2013-2014)
Blanco Drain Yield Study Monterey Penninsula Water Management District - Monterey County, CA
(2013-2014)
Aptos Booster Pump Station Soquel Creek Water District Aptos, CA (2012-2015)
McGregor Drive Booster Pump Station Soquel Creek Water District Capitola, CA (2012-2015)Interim
District Engineer - Marina Coast Water District - Marina, CA (2006-2007, 2012-2013)
Soquel Drive Cast Iron Main Replacement-Soquel Creek Water District-Soquel, CA (2012)
Watkins Gate Well and Pipeline Marina Coast Water District Marina, CA (2011-2012)
Stonegate Water Supply Project San Benito County Public Works-Hollister, CA (2011-2013)
Castroville Community Plan Infrastructure Estimate Monterey County Redevelopment Agency
Monterey, CA (2009-2010)
Sewer Feasibility Study for Commercial Parkway Monterey County Redevelopment Agency
Castroville, CA (2010)
Boronda Meadows General Development Plan Peer Review PMC, Inc. Salinas, CA (2010)
Modular Wastewater Treatment System - LOGCAP Balkans, Yugoslavia (1999)
Water Delivery Systems
Raw Water Pump Station Design and Construction - Coastal Water Authority - Houston, Texas (2000)
Moses Bayou 84-Inch Siphon - Gulf Coast Water Authority - Texas City, Texas (2001)
System Water Audit - Gulf Coast Water Authority - Texas City, Texas (1999)
Water Supply Planning
2010 Urban Water Management Plan Marina Coast Water District Marina, CA (2010-2011)
Regional Urban Water Augmentation Project - Marina Coast Water District - Marina, CA (2006-2007)
Region H Water Plans (2001 and 2006) - San Jacinto River Authority - Conroe, Texas (1998-2001, 20022006)

Colorado River Water Availability Model - Texas Natural Resource Consv. Comm. Austin, TX (2002)
Stormwater Planning and Design
Bryant Canyon Channel Monterey County Water Resources Agency Soledad, CA (2013 2014)
Wrigley-Ford Creeks Maintenance Project City of Milpitas Milpitas, CA (2011-2012)
Reclamation Ditch Repair at Alisal St Monterey County Water Resources Agency Salinas, CA
(2009)
Pajaro River Levee Maintenance Design Monterey County Water Resources Agency Salinas, CA
(2009)
NoiseandVibration
MichaelS.Thill,Illingworth&Rodkin
FinalEIR
September2015
FinalEIR
September2015
1 Willowbrook Court, Suite 120

Petaluma, California 94954
Tel: 707-794-0400
www.Illingworthrodkin.com
Fax: 707-794-0405
mthill@illingworthrodkin.com
MICHAEL S. THILL
Mr. Thill is a principal of the firm with 17 years of professional experience in the field of acoustics. His
expertise includes performing field research, analyzing data, and noise modeling. He has conducted
numerous field surveys in a variety of acoustical environments to quantify airborne noise levels,
groundborne vibration levels, and hydro-acoustic noise levels. He has analyzed and summarized complex
sets of data for inclusion into noise models. Mr. Thill has been trained, and is a regular user of FHWAs
Traffic Noise Model (TNM), and is familiar with federal and State procedures for preparing highway
noise study reports.
Mr. Thill has authored technical noise reports for various land use proposals including residential,
commercial, educational, and industrial developments. He has managed the General Plan Update noise
studies for several communities in California and has recommended policy language in order to maintain
compatible noise levels community-wide. Some of his recent major projects have included the assessment
of noise and vibration from quarry expansion projects, groundwater recharge projects, and winery
projects where operations and special events have been of concern in rural settings. He has vast
experience explaining acoustical concepts and the results of his analyses in public forums to the general
public and project decision-makers.
Mr. Thill has also led traffic noise investigations for major transportation projects including the Route 4
Bypass project (2003 to 2013) and the I-680/Route 4 Interchange project (2014 to 2015) in Contra Costa
County, California. He managed the noise study reports the US Highway 101 and State Route 85 Express
Lanes projects for the Santa Clara County Valley Transit Authority (2011 to 2013), proposed along 66
miles, combined, of project study area between Mountain View and Morgan Hill, California. In 2015, Mr.
Thill is leading the analyses of noise impacts and noise abatement for the US Highway 101 / State Route
84 Interchange Project in Redwood City, California and the US Highway 101 / Hearn Avenue
Interchange Project in Santa Rosa, California.
2009 - Present
Principal

2005 - 2009
Senior Consultant

1998 - 2005
Staff Consultant

EDUCATION
1998
University of California at Santa Barbara

B.S., Major: Environmental Science
PROFESSIONAL SOCIETIES
Institute of Noise Control Engineering
Association of Environmental Professionals
FinalEIR
September2015
NutrientResponse
MargaretNellor,P.E.,D.B.E.,W.B.E.,H.U.B.GordonWilliams,PH.D,P.E.
BahmanSheikh,PH.D.,P.E.
FinalEIR
September2015
FinalEIR
September2015
MARGARET H. NELLOR, PE, DBE, WBE, HUB

NELLOR ENVIRONMENTAL ASSOCIATES, INC
4024 WALNUT CLAY DRIVE
AUSTIN, TX 78731
512.374.9330
margie@nellorenvironmental.com
SUMMARY
Ms. Nellor has over 38 years of professional experience in the environmental field including water and wastewater
quality management; water recycling (potable reuse and non-potable reuse); regulatory permitting and compliance;
regulatory and legislative policy development and analysis; research; and source control and pollution prevention.
She is also very active in professional activities related to the environmental profession.
2005 Present: Nellor Environmental Associates, Inc.
President, Nellor Environmental Associates, Inc. (NEA), an environmental engineering consulting firm that provides
technical services and assistance related to water reclamation and wastewater management. NEA has been certified
as a Disadvantaged Business Enterprise in Texas and California, and as a Womens Business Enterprise by the City
of Austin, Texas. Specific areas of experience include:
Permitting/Regulatory Assistance - Ms. Nellor has provided technical review and analysis, developed
formal regulatory comments, and prepared hearing testimony for numerous wastewater discharge and water
reuse permits, including the seven permitted potable reuse projects in California (Montebello Forebay
Groundwater Recharge Project, Chino Basin Groundwater Recharge Project, Groundwater Replenishment
System, West Coast Basin Barrier Project, Alamitos Barrier Project, Dominguez Gap Barrier Project, and the
Cambria Emergency Water Supply Project). Examples include:
- Engineering Report and water recycling permit for the expansion of the Alamitos Barrier Project
- NPDES Permits for the City of Los Angeles, CA: D.C. Tillman Water Reclamation Plant, Los
Angeles/Glendale Water Reclamation Plant, Terminal Island Water Reclamation Plant and
Hyperion Treatment Plant
- NPDES Permits for the County Sanitation Districts of Los Angeles Countys Joint Water Pollution
Control Plant and Whittier Narrows Water Reclamation Plant
- NPDES Permit for the West Basin Municipal Water Districts Demonstration Desalination Project
- NPDES Permit for the Las Virgenes Municipal Water District
- NPDES Permit, General Permit, and Los Angeles County Storm Water Permit for the Castaic Lake
Water Agency
- NPDES Permit for the Newhall Ranch Water Reclamation Plant
- Waste Discharge and Water Recycling Requirements for the City of Los Angeles, CA Donald C.
Tillman and Los Angeles Glendale Water Reclamation Plants
- Waste Discharge and Water Recycling Requirements and technical assistance for the West Basin
Municipal Water Districts West Basin Coast Basin Barrier Recycled Water Project Expansion
- Waste Discharge and Water Recycling Requirements for the for the County Sanitation Districts of
Los Angeles Countys Lancaster Water Reclamation Plant
- Permitting Issues Related to Groundwater Recharge for the for the County Sanitation Districts of
Los Angeles Countys Palmdale Water Reclamation Plant
- Mandatory Minimum Penalties for the County Sanitation Districts of Los Angeles Countys Valencia
Water Reclamation Plant
- Technical Assitance for Enforcement Actions or Litigation Related to NPDES Permits and Industrial
Waste Permits
- Regulatory Assistance for City of Phoenix 23rd Ave. and 91st Ave. Treatment Plants
- Regulatory Assistance for the City of Vacaville, CA
- Regulatory Options for Wet Weather Discharges for the Lake Arrowhead Community Services
August 2015
District
Policies/Regulations - Ms. Nellor has worked on numerous policies, regulations, and special studies
including water recycling criteria, water quality standards, salt nutrient management plans, antidegradation
regulations, whole effluent toxicity testing, impairment determinations, and total maximum daily loads. She
serves as an advisor to the California Division of Drinking Water for the development of Groundwater
Recharge and Reuse Regulations, has served as a technical advisor to WateReuse California for the
development of the Water Recycling Policy and the Scientific Advisory Panel for Constituents of Emerging
Concern (CECs), and was a co-author of Direct Potable Reuse: the Path Forward sponsored by the
WateReuse Association, the WateReuse Research Foundation, and the National Water Research Institute.
She is also providing technical advise to the Texas Commission on Environmental Quality regarding potable
reuse. Other examles include:
- U.S. EPAs Recreational Water Quality Criteria
- U.S. EPAs Draft Guidance for Implementing Methylmercury Water Quality Criterion
- California State Water Resources Control Board Recycled Water Policy and CEC Monitoring
- California State Water Resources Control Board General Irrigation Permit
- California State Water Resources Control Board Policy for Implementation of Toxics Standards for
Inland Surface Waters, Enclosed Bays, and Estuaries of California (SIP and Amendments)
- California State Water Resources Control Board Chlorine Residual Policy
- California State Water Resources Control Boards Effluent Dependent Water Bodies and Mercury
Workgroup
- California State Water Resources Control Board Ocean Plan Amendments and Triennial Reviews
(including the Brine Discharge Policy)
- California State Water Resources Control Board Proposed Methylmercury Water Quality Objectives
for Inland Surface Waters and Enclosed Bays and Estuaries
- California State Water Resources Control Board Proposed San Francisco Bay-Delta Mercury Offset
Policy
- Los Angeles Regional Water Quality Control Board Basin Plan and Triennial Reviews
Planning and Compliance Strategies Ms. Nellor has worked on numerous projects to identify, evaluate,
develop, and recommend the most cost effective options for water recycling and wastewater management.
She specializes in analyzing the impacts of regulations on compliance and implementation strategies,
including master planning studies for potable reuse projects, salt/nutrient management, source control,
CEQA/NEPA reviews, and antidegradation. Projects include:
- PURE Water Monterey Groundwater Replenishment Project Environmental Impact Report
- Texas Water Development Board Evaluating the Potential for Direct Potable Reuse in California
- Texas Water Development Board State of Technology of Water Reuse, 2011 Water Reuse
Research Agenda, and History of Water Reuse in Texas
- Texas Water Development Board Direct Potable Reuse Resource Document
- City of Lancaster, CA Groundwater Recharge Feasibility Study and Fatal Flaw Analysis
- City of Oceanside, CA Indirect Potable Reuse and Pathogen Removal Study
- Metropolitan Water District of Southern Californias Joint Groundwater Replenishment Feasibility
Study
- Alternatives Assessment and Preliminary Design for the Water Replenishment District of Southern
Californias Groundwater Reliability Improvement Program
- As-Needed Engineering Technical Services Consultant for Pure Water San Diego Program
- California Environmental Quality Act public health and regulatory assistance for the Central and
West Coast Basin Groundwater Master Plan and the Monterey Peninsula Groundwater
Replenishment Project
- City of Los Angeles Groundwater Recharge Master Planning Process
- City of San Diego Surface Water Augmentation Demonstration Project
- Eastern Municipal Water District Indirect Potable Reuse Phase I Facilities Planning Study
- East Valley Water District Indirect Potable Reuse Feasibility Study and Implementation Program
- Rancho California Water District Indirect Potable Reuse Conceptual Design Study
- South Sacramento County Agriculture & Habitat Lands Recycled Water Project Programmatic
August 2015
Feasibility Study
Upper San Gabriel Valley Water District Indirect Potable Reuse Feasibility Study
Santa Clara Valley Water District Potable Reuse Project Plan
Recycled Water Recharge Feasibility Study
Montebello Forebay Groundwater Recharge Project Expansion
Central and West Basin Salt Nutrient Management Plan
White Paper for the National Water Research Institute on the Status of the Water Recycling 2030:
Recommendations of Californias Recycled Water Task Force
White Paper for WateReuse California on Public and Political Acceptance of Direct Potable Reuse
California State Implementation Policy Database Development
Government Accounting Office Study on the Cost of Federal Water Requirements
San Jose / Santa Clara Salinity Study
Southern California Water Recycling Projects Initiative Water Quality Technical Memorandum No. 5
Potential Salinity Impacts to Recycled Water
Water Recycling Site Inspection Program, Regulations and User Handbook for the County
Sanitation Districts of Los Angeles County
Water Sofener Rebate Program for County Sanitation Districts of Los Angeles County
Upper Santa Clara River Chloride Total Maximum Daily Load
City of Austin TX Water Utility - Assessment of Requirements for Auxiliary Water
Copper Analytical Issues for the City of Santa Rosa, CA
Monograph on Adaptive Implementation of TMDLs
Source Control Ms. Nellor has worked on numerous projects to related to evaluating and recommending
source control strategies; Projects include:
- Review and evaluation of the City of Los Angeles source control program related to compliance
with California Department of Public Heath draft groundwater recharge regulations.
- Review and evaluation of the Orange County Water Districts source control program and Santa
Ana Watershed Project authoritys source control programs related to increased use of recycled
water for the Groundwater Replenishment Project.
- Development of national strategy for the National Association of Clean Water Agencies regarding
development of local limits for conventional and nonconventional pollutants.
Research - Ms. Nellor is involved with a number of research projects related to the use of recycled water
and management of wastewater, and serves on numerous project advisory committees. She was the
Principal Investigator for WateReuse Research Foundation projects WRF-06-018 Tools to Assess and
Understand the Relative Risks of Indirect Potable Reuse Projects and WRF-08-01 Developing
Standards/Criteria for Various End Uses of Recycled Water. She was on the research team for WRF
projects 09-02 Framework for Informed Planning Decisions Regarding Potable Reuse and Dual Pipe
Systems and 10-14 The Future of Purple Pipes: Exploring the Best Use of Non-Potable Recycled Water in
Diversified Urban Water Systems. She also participated as a contributor to the WateReuse Research
Foundations Best Practices for Developing Indirect Potable Reuse Projects. She has served on research
advisory committees for the WateReuse Research Foundation and the Water Environment Research
Foundation.
1995 2005: County Sanitation Districts of Los Angeles County

The Sanitation Districts provide for the wastewater and solid waste management needs of over 5 million people in 78
cities and portions of Los Angeles County, California. Ms. Nellor was the Assistant Department Head of Technical
Services. This position is responsible for the overall administration of the agencys water reclamation and research
programs and water quality permit and compliance programs for the agencys wastewater, biosolids, and solid waste
management facilities. She was responsible for managing all water recycling and wastewater permitting activities,
including permit amendments, revisions, petitions, and litigation. She was responsible for liaison activities with
federal, state and local governmental agencies on legislative and regulatory issues, including the Los Angeles Basin
Plan, the California Toxics Rule, the State Implementation Plan, the California Ocean Plan, and the State Mandatory
Minimum Penalty Program. Ms. Nellor was also the co-project manager for a Water Research Foundation $10 million
August 2015
water recycling research project related to the efficacy and sustainability of using recycled water for groundwater
replenishment.
1991 1995: Orange County Sanitation District
The District provides for the wastewater management needs of over 2 million people in Orange County, California.
Ms. Nellor was the Acting Head of the Technical Services Department, which was responsible for the agencys air
and wastewater quality, permitting and compliance programs, research programs, source control and pollution
prevention programs, and recycling activities (water and biosolids). She was also responsible for liaison activities
with federal, state and local governmental agencies on legislative and regulatory issues. During her tenure at the
District, she also served as the head of the agencys source control program.
1977 1991: County Sanitation Districts of Los Angeles County
Ms. Nellor was responsible for managing the agencys source control and industrial pretreatment program. During her
tenure at the Sanitation Districts, she held other positions responsible for water recycling permitting and
implementation; wastewater management, permitting and compliance activities; and water recycling research. Ms.
Nellor was the project manager of a $3 million water recycling research project related to the health effects of using
recycled water for groundwater replenishment.
EDUCATION:
M.S. Environmental Health Engineering
B.S. Civil Engineering, University of Texas at Austin
REGISTRATION: Registered Civil Engineer
California (No. 31997)
Texas (No. 95405)
CERTIFICATION:
Texas: Disadvantaged Business Enterprise and City of Austin Womens Business Enterprise
California: Disadvantaged Business Enterprise
AWARDS
Association of Metropolitan Sewerage Agencies Presidents Award
Order of the Silver Cover, California Water Pollution Control Association
University of Texas Civil and Architectural Engineering Academy of Distinguished Alumni
WateReuse Association, CA Section, Recycled Water Advocate of the Year, 2005
National Association of Clean Water Agencies, 2006 Distinguished Performance Award
National Association of Clean Water Agencies Hall of Fame
SOCIETIES
American Society of Civil Engineers
Association of Clean Water Agencies
Served on Board of Directors
Served as Chair Regulatory Policy Committee
Served as Co-Chair Mercury Workgroup, current member
Member Emerging Contaminants Workgroup
Member Pathogen Workgroup
Environmental Protection Agencys Effluent Guidelines Task Force
Served as Co-Chair
Served as member
Tri-TAC
Past Chair (1996-99)
Member
Water Environment Association of Texas
Water Environmental Federation
Water Reuse Committee
August 2015
Long Range Planning Committee (2005-2006)

Chair Pollution Prevention Committee (1993-1995)
Chair, Ad Hoc Source Control Committee (1991-1993)
Water Environment Research Foundation
Research Council (2001-2007)
Trace Organics Issue Area Team
WateReuse Association
Board of Directors (1997 2008)
Past President (2001 -2003)
Regulatory Committee
Potable Reuse Committee
WateReuse Foundation
Past Vice President Board of Directors (2000 2005)
Research Advisory Committee (2005-2010)
University of Texas Engineering Foundation Advisory Council of the College of Engineering (2005 2008)
PUBLICATIONS
Over 40 technical publications, papers, and contributions to books and manuals of practice (see attachment).
August 2015
Margaret H. Nellor
Papers and Publications
Nellor, M.H., Soller, J.A., McDonald, E.T., Cruz, C.J. (2015) Health risk associated with direct potable reuse
evaluation through quantitative relative risk assessment case studies. Environmental Science: Water
Research & Technology, DOI: 10.1039/C5EW00038F.
Chang, H.C., Fu, P.L.K, Nellor, M.H. (2014) Multi-barrier treatment makes a recycled water project possible in Los
Angeles County. WE&T, 27, 8, 64-68.
Chang, H.C., Fu, P.L.K, Nellor, M.H. (2014) A Case Study of Multi Barrier Treatment Based on the Expanded
Alamitos Barrier Recycled Water Project in Los Angeles County, California. Proceedings WEFTEC 2014,
Sept. 27-Oct.1, 2014, New Orleans, LA.
Chang, H.C., Fu, P., Johnson, T.A., Nellor, M.H. (2013) Implementing Californias New Draft Groundwater
Replenishment Reuse Regulations and 2013 Amended Recycled Water Policy, Los Angeles County CA.
Proceedings WEFTEC 2013, Oct. 5-9, 2013, Chicago, IL.
Chang, H.C., Fu, P., Johnson, T.A., Nellor, M.H. (2013) Implementing Californias New Draft Groundwater
Replenishment Reuse Regulations and 2013 Amended Recycled Water Policy, Los Angeles County,
California. Proceedings of the WateReuse 2013 California Annual Conference, March 17-19, 2013,
Monterey, CA.
Bickford, G. and Nellor, M. 2012 (but published 2013). The Future of Purple Pipes: Exploring the Best Use of Nonpotable Recycled Water in Diversified Urban Water Systems. WateReuse Research Foundation, Alexandria,
VA.
Nellor, M., Soller, J., Bruce, G., Fox, P, Skrepnek, G., Flander, L. (2013) Overview of WRF-06-16: Tools to Assess
the Risks of Indirect Potable Reuse Projects. WateReuse Research Foundation, Alexandria, VA.
Fox, P., Lim, S.J., Flander, L., Speirs-Bridge, A., Skrepnek, G., Soller, J., Nellor, M. (2012) Development and
Application of Tools to Assess and Understand the Relative Risks of Regulated Chemicals in Indirect
Potable Reuse Projects: Predicting Future Contaminants of Concern for Indirect Potable Water Reuse,
Volume 3, WateReuse Research Foundation, Alexandria, VA.
Soller, J.A. and Nellor, M.H. (2011) Development and Application of Tools to Assess and Understand the Relative
Risks of Regulated Chemicals in Indirect Potable Reuse Projects: the Chino Basin Groundwater Recharge
Project, Tools to Assess and Understand the Relative Risks of Indirect Potable Reuse and Aquifer Storage &
Recovery Projects, Volume 1b, WaterReuse Research Foundation: Alexandria, VA.
Soller, J.A. and Nellor, M.H. (2011) Development and Application of Tools to Assess and Understand the Relative
Risks of Regulated Chemicals in Indirect Potable Reuse Project: the Montebello Forebay Groundwater
Recharge Project, Tools to Assess and Understand the Relative Risks of Indirect Potable Reuse and Aquifer
Storage & Recovery Projects, Volume 1a, WaterReuse Research Foundation: Alexandria, VA.
Tchobanoglous, G, Leverenz, H., Nellor, M., Crook, J. (2011) Direct Potable Reuse: A Path Forward. WateReuse
Research Foundation, National Water Research Institute, WateReuse California, Alexandria, VA.
Bruce, G.M., Pleus, R.C., Peterson, M.K., Nellor, M.H. Soller, J.A. (2010) Development and Application of Tools to
Assess and Understand the Relative Risks of Drugs and Other Chemicals in Indirect Potable Reuse, Tools
to Assess and Understand the Relative Risks of Indirect Potable Reuse and Aquifer Storage & Recovery
Projects, Volume 2, WaterReuse Research Foundation: Alexandria, VA.
Nellor, M. and Larson, B. (2010) Assessment of Approaches to Achieve Nationally Consistent Reclaimed Water
Standards White Paper. WaterReuse Research Foundation: Alexandria, VA.
Nellor, M. and Larson, B. (2010) Assessment of Approaches to Achieve Nationally Consistent Reclaimed Water
Standards White Paper. Conference Proceedings, WateReuse Symposium, September 14, 2010,
Washington, D.C.
Nellor, M. H. and Millan, M. (2010) Public and Political Acceptance of Direct Potable Reuse, White Paper prepared for
WateReuse California, Sacramento, CA.
Soller, J., Nellor, M., Bruce, G., Fox, P., Skrepnek, G., Flander, L. (2010) Tools to Assess the Risks of Indirect
Potable Reuse Projects. Conference Proceedings, WateReuse Symposium, September 13, 2010,
Washington, D.C.
August 2015
Fox, P., Skrepnek, G., Flanders, L., Nellor, M., Soller, J., Bruce, G. (2009) Predicting Future Contaminants of
Concern for Indirect Potable Water Reuse. Conference Proceedings, WateReuse Symposium, September
13-16, 2009, Seattle, WA.
Aladjem, D., Bolland, D., Davis, M., Dembegiotes, G., Larson, R., Michalczyk, B., Nellor, M., Pawson, M.G. (2009)
Assuring a Clean Abundant Water Supply - Developing California's Recycled Water Policy through a
Stakeholder Process. Conference Proceedings, WateReuse Symposium, September 13-16, 2009, Seattle,
WA.
Nellor, M. H. (2009) Views on the Status of Water Recycling 2030: Recommendations of Californias Recycled Water
Task Force. NWRI White Paper, Fountain Valley, CA.
Nellor, M.H. and Daniel, U. (2008) When Policies Collide: The California Ocean Plan versus Water Reuse and
Desalination. Proceedings California Section WateReuse Association Conference, March 2008, Newport
Beach, CA.
Fox, P., Houston, S., Westerhoff, P., Nellor, M., Yanko, W., Baird, R., Rincon, M., Gully, J., Carr, S., Arnold, R.,
Lansey, K., Quanrud, D., Ela, W., Amy, G., Reinhard, M., Drewes, J. (2006) Advances in Soil Aquifer
Treatment for Sustainable Reuse. AWWA Research Foundation and American Water Works Association,
Denver, CO.
Kuo, J., Chen, C, Nellor, M. (2003), Standardized Collimated Beam Testing Protocol for Water/Wastewater Ultraviolet
Disinfection. Journal of Environmental Engineering, 129:774-779.
Fox, P., Drewes, J.E., Nellor M.H. (2000), Watershed Analysis of Water Reuse Systems. Proceedings Water Reuse
Conference of the American Water Works Association/Water Environment Federation, Water Reuse 2000,
San Antonio, TX.
Fox, P., Houston, S., Westerhoff, P., Drewes, J., Nellor, M., Yanko, W., Baird, R., Rincon, M., Arnold, R., Lansey, K.,
Bassett, R., Gerba, C., Karpiscak, M., Amy, G., Reinhard, M. (2001) An Investigation of Soil Aquifer
Treatment for Sustainable Water Reuse. AWWA Research Foundation and American Water Works
Association, Denver, CO.
Drewes, J.E., Fox, P., Nellor, M.H. (2000), Efficiency and Sustainability of Soil-Aquifer Treatment for Indirect Potable
Reuse of Reclaimed Water. Water, Sanitation and Health. London: IWA Publishing, 227-232.
Drewes, J.E., Rauch, T., Rincon, M., Nellor, M.H., Fox, P. (1999) A Watershed Guided Approach for Water Quality
Assurance in Indirect Potable Reuse Systems: Experiences from Field Studies in Arizona and California.
Proceedings WateReuse Foundations Annual Water Reuse Research Conference, Monterey, CA.
Drewes, J.E. Fox, P. Nellor, M.H. (1998), Efficiency and Sustainability of Soil-Aquifer Treatment for Indirect Potable
Reuse of Reclaimed Water. WHO Conference Water, Sanitation, and Health: Resolving Conflicts Between
Drinking Water Demands and Pressures From Societys Wastes, Germany.
Drewes, J.E., Fox, P. Nellor, M. (1998), Efficiency and Sustainability of Soil-Aquifer Treatment for Indirect Potable
Reuse of Reclaimed Water. Proceedings WateReuse Foundations Annual Water Reuse Research
Conference, Monterey, CA.
Hartling, E.C. and Nellor, M.H. (1998), Water Recycling in Los Angeles County. In Water Reclamation and Reuse.
Water Quality Management Library, Volume 10. Edited by Takashi Asano.
Leserman, J.R., Nellor, M., Fox, P., Arnold, R.G., Amy, G.L. (1997), Soil Aquifer Treatment of Reclaimed Wastewater.
Proceedings American Water Resources Association, Conjunctive Use of Water Resources: Aquifer
Storage and Recovery, Long Beach, CA, 321-329.
Tran, J.H. and Nellor, M.H. (1994) Direct Copper Plating Without the Electroless Copper Solution. Proceedings 67th
Annual Water Environment Federation Conference, Chicago, Illinois.
Baird, J.D., Renescu, A. and Nellor, M.H. (1993), Pollution Prevention Program in the Canning Industry. A Strategy
for Success. Proceedings 66th Annual Water Environment Federation Conference, Anaheim, California.
Renescu, A. and Nellor, M.H. (1993), Dynamic Pollution Prevention Program Provides Results. Industrial Wastewater,
1:2:46-51.
Renescu, A. and Nellor, M.H. (1992), Pollution Prevention Program - A Dynamic Process. Three Case Studies.
Proceedings 65th Annual Water Environment Federation Conference, New Orleans, Louisiana.
Rhee, C.H., Martyn, P.C., and Nellor, M.H. (1990), Removal of Toxic Organics from Wastewater Generated in Tank
Truck Washing Facilities. Proceedings of the 45th Industrial Waste Conference, Purdue University.
August 2015
Crook, J.T. Asano, T., and Nellor, M.H. (1990), Groundwater Recharged with Reclaimed Water in California. Water
Environment & Technology, 2:8:42-49.
Nellor, M.H., Miele, R.P., and Baird, R.B. (1990), Health Effects of Groundwater Recharge. In Artificial Recharge of
Groundwater, ASCE, New York, NY.
Carry, C.W., Miele, R.P., Horvath, R., and Nellor, M.H. (1989), An Update on Wastewater Reclamation Research and
Development in Los Angeles County. Water Science and Technology, 21:409-419.
Baird, R.B., Gute, J.P., Jacks, C.A. Jacks, Neisess, L.B., Nellor, M.H., and Smyth, J.R. (1987), GC/Negative Ion
CIMS and Mutagenicity Assays of Resin Concentrates of GAC Effluents from an Advanced Wastewater
Treatment Facility. In Organic Pollutants in Water. Advances in Chemistry, Series 214. M. Suffet and M.
Malaiyandi, eds. ACS, Washington, DC.
Nellor, M.H., Baird, R.B., and Smyth, J.R. (1985), Health Effects of Indirect Potable Water Reuse. Journal AWWA,
77:7:88-96.
Nellor, M.H., Baird, R.B., and Smyth, J.R. (1985). Health Effects of Potable Water Reuse. Proceedings of Water
Reuse Symposium III. AWWA Research Foundation, Denver, CO.
Nellor, M.H., Baird, R.B, and Smyth, J.R. (1984), Health Effects Study Final Report. Sanitation Districts of Los
Angeles County, Whittier, CA. National Technical Information Services No. PB84-191568.
Nellor, M.H., Baird, R.B., and Garrison, W.E. (1982), Health Effects of Water Reuse by Groundwater Recharge.
Proceedings of Water Reuse Symposium II. AWWA Research Foundation, Denver, CO.
Garrison, W.E., Nellor, M.H., Baird, R.B. (1980), A Study on the Health Aspects of Groundwater Recharge in
Southern California. In Wastewater Reuse for Groundwater Recharge. T. Asano and P.V. Roberts, eds.
State Water Resources Control Board. Sacramento, CA.
Nellor, M.H., Dryden, F.D., and Chen, C. (1979), Health Effects of Groundwater Recharge. Proceedings of Water
Reuse Symposium. AWWA Research Foundation, Denver, CO.
MISCELLANEOUS:
Contributing author for Direct Potable Reuse Research Document, prepared for the Texas Water Development Board,
May 1015.
Contributing author for State of Technology for Water Reuse, prepared for the Texas Water Development Board,
August 2010.
Contributing author for Using Reclaimed Water to Augment Potable Water Resources, prepared by a Joint Task
Force of Water Environment Federation and the American Water Works Association, 2008.
Contributing author for Adaptive Implementation of Water Quality Improvement Plans: Opportunities and Challenges,
Nicholas School of the Environment and Earth Sciences, Duke University, June 25, 2007.
Contributing author for Managing Wastewater in Coastal Urban Areas. National Research Council. National
Academy Press, Washington, D.C., 1993.
Contributing author for the 1980 and 1989 Editions of the Water Pollution Control Federations Water Reuse Manual
of Practice.
August 2015
Gordon Williams, Ph.D., P.E. Resume

Employment History
Trussell Technologies, Inc.
Principal Engineer I (01/15-present)
Supervising Engineer III (1/14-12/14)
Supervising Engineer II (01/12 12/13)
Supervising Engineer I (01/11 - 12/11)
Senior Engineer III (1/09 - 1/10)
Senior Engineer I, (11/08 12/08)
University of California at Berkeley
Gordon Williams, Ph.D., P.E.
Graduate Student Researcher, University of

California, Berkeley (2003-2008)
Graduate Student Instructor, University of
California, Berkeley (2005)
Education
Ph.D. Civil & Environmental Engineering,
University of California, Berkeley
M.S., Civil & Environmental Engineering,
University of California, Berkeley
B.S., Civil Engineering, Virginia Tech,
Blacksburg
Project Experience (Selected Projects)
Registration
Civil Engineer, State of California No. 78671
Summary
Dr. Gordon Williams is a Supervising Engineer
at Trussell Technologies, and a B.S. from
Virginia Tech and a M.S. and Ph.D. from the
University of California at Berkeley.
Dr.
Williams has 10 years wastewater and water
reuse experience. In his doctoral work, Dr.
Williams studied granular-media rapid-depth
filtration for water reuse and focused on
understanding how loading rate impacts tertiary
filter performance. As a result of his research,
several
California
wastewater
treatment
facilities are able to maximize their recycled
water production by operating at loading rates
up to 7.5 gpm/ft2, which is 50% higher than the
5 gpm/ft2 limit specified by the California Title22 Water Recycling Criteria. Williams also has
expertise in understanding pathogen reduction
through tertiary treatment and has identified
particle association as an important factor in the
removal of viruses through tertiary granularmedia filtration.
His recent projects have
included: increasing the filtration rate for the
Daly City water reclamation plant, determining
the media configuration for the City of Santa
Cruzs filter rehabilitation, and designing a new
tertiary filter filtration system for the City of
Corona.
WQTS / East Bay Municipal Utility District

(EBMUD)
Sobrante and Upper San Leandro Water
Treatment Plants Ozone Application Point
Study Year: 2014
The East Bay Municipal Water District
(EBMUD) was one of the pioneers in applying
ozone to municipal drinking water treatment for
reducing both disinfection by-products and taste
& odor compounds. When EBMUD installed
their existing ozonation systems at the
Sobrante and Upper San Leandro Water
Treatment Plants (WTPs) in the early 1990s,
the most common practice was to add ozone to
the settled water prior to filtration. More than
twenty years later, EBMUD is in the planning
phase of replacing the aging ozone generators
with new high-efficiency ozone generators, and
replacing the existing air feed systems with
liquid oxygen systems (LOX). As part of this
project, EBMUD is re-evaluating the ozone
addition point to determine if a change from
intermediate ozonation to pre-ozonation is in
the Districts best interest.
To make this
decision, EBMUD hired Trussell Technologies
(as a sub-consultant to WQTS) to provide
technical expertise, to review the situation, and
make a recommendation for the future ozone
siting.
Trussell Technologies developed a thorough
understanding of the needs and drivers for
ozone for both Sobrante and Upper San
Leandro WTPs through a review of historical
data, reports, and design documents, as well as
through site visits, interviews, and workshops
TRUSSELL TECHNOLOGIES, INC. | Gordon Williams, Ph.D., P.E. Resume

with plant staff. Trussell Technologies then
performed an independent evaluation of the
benefits and challenges of each siting location,
including the implications of the siting to the
product
water
quality,
plant
capacity,
operational difficulty, and cost. The evaluation
was performed considering the experiences at
other ozonation facilities (representing both preozonation
and
intermediate
ozonation),
technical literature, and previous project
experiences. Trussell Technologies and WQTS
presented their findings to EBMUD along with a
technical report making a final recommendation
for each facility.
Role: Project Engineer
Agency
Groundwater Recharge Project piloting
Year: 2013 Present
To meet water supply needs in the region, the
Agency
(MRWPCA)
consulted
Trussell
Technologies in developing an Advanced Water
Treatment (AWT) process for a Groundwater
Replenishment (GWR) project and to find new,
suitable source waters. Trussell Technologies
devised an extensive water quality monitoring
program for potential sources waters and
conducted bench-scale testing to determine
both the suitability of the sources for treatment
and to determine the most efficacious treatment
process.
After
bench-scale
testing,
Trussell
Technologies piloted specific processes of
preliminary AWT treatment train, namely ozone,
microfiltration, and reverse osmosis (RO), and
developed a water quality sampling campaign
for the pilot operation. With the operational and
water quality data from the pilot, a 10% level
design was developed for the whole AWT,
which also included advanced oxidation
(UV/AOP), and post-stabalization.
City of Daly City
Title: Tertiary Filter Capacity Evaluation and
Disinfection System Predesign
Date: 2012 present
The Daly City WTP discharges approximately
12 mgd of secondary effluent through an ocean
discharge. In 2004, the plant was upgraded to

enable the production of 2.7 mgd of tertiary
recycled water (granular media filtration and
chlorine disinfection). Demand for the recycled
water quickly exceeded this rated capacity, and
further upgrades to the existing facility were
considered infeasible due to the confined plant
footprint. Trussell Technologies is working to
rerate these continuously-backwashing upflow
filters (Dynasand) above the Tilte-22 limit of 5
gal/ft2-min, with a goal of increasing the tertiary
capacity by approximately 2 mgd tertiary. In
addition, Trussell Technologies is developing a
predesign of an extremely compact disinfection
system capability of treating the additional
water produced by the filters.
Role: Project Manager
Kennedy-Jenks/City of Santa Cruz
Title: Graham Hill Water Treatment Plant
Granular Media Filter Rehabilitation
Date: 2013 present
Last upgraded in 1986, the City of Santa Cruz
is in the process of rehabilitating their granular
media filters, which have a rated capacity of 24
mgd. During this rehabilitation period, several
improvements are being made to the to improve
the filter performance (media replacement,
underdrain replacement, air scour addition,
trough replacement).
Williams used a
modeling-based approach to determine the
optimal media configuration for the new filters,
based
on
historical
performance
and
performance goals set by the City. In addition,
Williams is conducting pilot testing of various
media configurations to verify the improvements
and demonstrate operation at increased
filtration rates.
Role: Project Manager Filter Media Expert
Dudek/City of Corona
Title: Corona Tertiary Filtration Project
Year: 2011-2012
Trussell Tech was hired to provide process
design for a new 4 mgd tertiary filtration system
for the City of Corona Department of Water and
Power. Williams was responsible for evaluating
process alternatives, developing the design
criteria for granular media filtration system,
including: media selection, backwash design,
and backwash waste treatment. Modeling of

various granular media designs were used to
develop a design well-suited to the Citys
needs. By optimizing granular media filter
design to maximize run times and treating
backwash wastewater through a repurposed
microfiltration system, the combined filtration
process boasts a 97% recovery rate and
minimizes loads on upstream process units.
Role: Process Engineer
Santa Ana Watershed Project Authority
(SAWPA)
Title: Inland Empire Brine Line Solids Formation
Study
Date: 2011 present
SAWPA manages a 73-mile pipleline that
conveys 12 mgd of mixed waste from brine,
domestic
wastewater,
commerical,
and
industrial dischargers. Over the past decade,
formation of solids in the Brine Line have lead
to more than $1M per year costs related to
excess treatment and disposal charges.
Trussell Technologies was hired to determined
the most likely causes of the solids formation
and evaluate options available for reducing the
size of the problem. Trussell Technologies
started with a detailed characterization of the
solids present at the end of the Brine Line to
determine the possible formation mechanisms.
Trussell Technologies made improvements to
the methods for sample collection, which
corresponded with a significant reduction in the
scale of the solids formation problem. The size
of the problem is currently being reassessed,
and Trussell Technologies is providing ongoing
support and evaluation of mitigation strategies.
Agency, City of San Jose, City of Santa
Rosa, Delta Diablo Sanitation District, Los
Angeles County Sanitation District
Title: Filter Loading Evaluation for Water Reuse
(FLEWR) Phase II, Full-Scale Filter Study
Date: 2006 present
Based on the findings from FLEWR Phase I
(see below), the California Department of
Public Health (CDPH) has allowed full-scale
granular-media tertiary filtration plants to test
loading rates above the Title-22 allowable limit
of 5 gpm/ft2. This study established a CDPH
approved procedure for treatment facilities to

obtain permanent exception to the Title-22 limit
through demonstration of equivalent filter
performance at higher loading rates. Based on
this work, CDPH has rerated three granularmedia tertiary facilities to a filtration rate of 7.5
gpm/ft2, increasing capacity by 50% and saving
more than $50M in construction costs. Williams
has played a key role in this multi-plant study
by designing all study protocols, analyzing all
results, and preparing final reports for facilities
as they complete testing.
Role: Project Manager, Project Engineer,
Doctoral Researcher
Agency
Title: Filter Loading Evaluation for Water Reuse
(FLEWR) Phase I, Pilot-Scale Filter Study
Date: 2003-2006
Due to an inadequate understanding of the
effect loading rate has on tertiary filter
performance, Californias Water Recycling
Criteria (Title-22) limit the maximum allowable
filter loading rate to 5 gpm/ft2.
Because
filtration is often the limiting process in terms of
treatment capacity, increasing the allowable
loading rate would free many California water
reclamation facilities to increase their
production of recycled water, without the need
of costly capital additions. This pilot-study
developed a better understanding of the role
loading rate plays on tertiary filter performance
and identified the factors necessary to achieve
equivalent treatment at higher rates. As part of
his doctoral research, Williams was integral to
the success of this project by designing the
pilot facility, overseeing pilot construction and
operation,
analyzing
all
results,
and
participating in discussions with the California
Department of Public Health.
Role: Doctoral Researcher
Title: Reclaimed Water Desalination
Technologies: Establishing Nitrification
Reliability Guidelines for Water Reuse
Date: 2011 Present
This study addresses regulatory limitations on
chlorine disinfection, through establishing
guidelines for nitrification reliability. When the

current California Water Recycling Criteria were
developed, nitrification was not considered a
reliability enough process to ensure ammonia
would be consistently removed from the product
water. As a result, disinfection CT values for
recycled water are based on the inactivation
rates of less reactive chloramines. The ability
of water reuse facilities to reliably nitrify has not
been documented to the satisfaction of the
California Department of Public Health, and
nitrification reliability features in place before
water reuse regulations will differentiate
between chloramine and chlorine disinfection.
This project involves the coordination of eight
recycled water facilities to document reliability
of nitrification in various secondary biological
processes, evaluate various online low-range
ammonia analyzers as tools for continuous
monitoring, and develop a guidance document
for ensuring reliable nitrification such that freechlorine disinfection CT values can be applied
to recycled water.
Role: Principal Investigator
Vallecitos Water District
Title: Meadowlark Operations
Year: 2009 2010
Vallecitos Water District owns and operates the
Meadowlark Water Reclamation Facility, which
is capable of treating up to 5 mgd of wastewater
to produce recycled water for local customers.
Historically coliform hits have been an issue at
Meadowlark. Trussell Tech assisted with
process modifications to reduce chemical
consumption and alleviate the coliform issues.
Trussell Tech diagnosed multiple issues with
the chlorination, filtration, and primary treatment
systems contributing to the problem. Trussell
Tech was able to cut chlorine consumption by
more than 50% with a new chlorine injection
system, while simulateously solving the coliform
exceedence problems. In addition, Trussell
Technologies implemented strategies to
minimize particle sloughing (shown to be the
cause of turbidity spikes and particle
breakthroughs), and ease coagulant dosing by
maximizing aeration basin efficiency for better
up stream turbidity removal.
Fallbrook Public Utilities District

Title: Tracer Study and CDPH Review
Date: 2009
Trussell Technologies was hired by Fallbrook
PUD to evaluate the chlorine contact basin
capacity of the Fallbrook Water Reclamation
Plant, in compliance with a request from the
California Department of Public Health. Trussell
Tech developed a plan, executed the tracer
study tests using the slug dose method,
analyzed the result, and prepared a draft report
summarizing the results for the District and
CDPH.
As a result of this study, CDPH
approved a new capacity rating and chlorine
equation for the Water Reclamation Plant.
Williams was responsible for design the plan,
executing the study, and coordinating with
CDPH.
San Elijo Joint Powers Authority
Title: Recycled Water Improvement and
Expansion
Date: 2008 - present
The San Elijo Water Reclamation Facility is in
the process expanding their recycled water
capacity and improving the water quality by
adding a partial RO system to lower the product
water salinity. Trussell Technologies, Inc. was
hired by the Joint Powers Authority to develop a
conceptual design for the RO treatment plant,
evaluate the capacity of the existing recycled
water system, and study the existing chlorine
contact basin to determine if the actual capacity
could be increased. Trussell performed a tracer
study on the chlorine contact basin to determine
the actual hydraulic capacity and analyzed
tracer study data to prepare reports to Regional
Water Quality Control Board and CDPH. As a
result of this study, the chlorine contact basin
was rerated to a larger capacity, such that no
additional
disinfection
was
needed
in
association with the MF/RO expansion.

Title: Reclaimed Water Desalination
Technologies: A Full-Scale Performance and
Cost Comparison between EDR and MF/RO
Date: 2009 - 2010
Many water reuse facilities are required to
reduce the product water salinity and RO
membranes have been the predominate
technology used to remove salt removal in
recycled water. However, because of its lower
capital cost, Electrodialysis Reversal (EDR) is
often proposed as an alternative to RO, but
rarely actually selected (only used for reuse by
two plants in US), because the actual life-cycle
costs for a reuse plant are unknown. Trussell
Technologies, Inc. compared the actual capital
and O&M costs of EDR and RO membranes
facilities used to remove salt from recycled
water. The final report from this project serves
as practical guide to water reuse utilities to
select of the most appropriate and economical
desalting technology based on the specifics of
their plant.
RMC/LADWP Recycled Water Master Plan
Title: Assessment of Effects of Temperature on
Recycled Water Treatment Processes
Date: 2009 2010
In their efforts to develop a recycled water
master plan, the City of Los Angeles looked for
additional reuse opportunities by evaluating
tertiary
treatment
of
high-temperature
secondary water that had been used as cooling
water. This high-temperature water presented
unique challenges for conventional tertiary
treatment. An evaluation of the impacts of
temperature on all recycled water treatment
processes was conducted, considering both the
positive and negative effects of temperature on
treatment
performance,
operations,
maintenance, energy use, and equipment life.
Williams responsibilities included developing
the
technical
approach,
evaluating
technologies, and project management.
RMC/LADWP Recycled Water Master Plan
Title: Satellite Reuse Technology Assessment
Date: 2009-2010
In their efforts to develop a recycled water

master plan, the City of Los Angeles looked to
maximize their opportunities for reuse through
satellite water treatment facilities. This project
focused
on
evaluating
all
treatment
technologies that had potential for use in
satellite facilities, considering performance,
cost, footprint, and reliability. Responsibilities
included evaluating technologies, technologies
selection, and partial project management.
RMC - Marina Coast Municipal Water
District
Title: Desalination Plant Predesign and
Permitting
Date: 2008 - 2011
After decades of unsustainable pumping of
fresh groundwater supplies, the fresh
groundwater supply below the Marina, CA
coastline was destroyed by seawater intrusion.
An RO drinking water treatment plant was being
developed to desalinate this saline groundwater
and supply a sustainable potable water source
for the community. The production capacity of
the desalination facility will be 10 mgd
expandable to 14 MGD. Trussell Technologies,
Inc was hired by RMC to prepare a conceptual
design of the plant, and assist with the process
selection, water quality goals, predesign, and
the Department of Public Health permitting,
including the preparation of the water quality
monitoring plan.
West Yost Associates Davis-Woodland

Water Supply Project Partners
Title: Davis-Woodland Water Supply Project
Pesticide White Paper
Date: 2010 2011
Working with the City of Davis, City of
Woodland, and UC Davis to develop a regional
water supply project that diverts Sacramento
River Water to meet the potable water supply
needs of the Davis-Woodland communities.
The proposed surface water treatment plant will
have the capacity to treat a proposed 53 mgd of
river water.
Responsibilities included
developing approach to determining pesticides

of concern, reviewing water quality results, and
project management.
chlorine residual. WateReuse California

Annual Conference, Monterey, CA. March 1719, 2013.
West Yost Associates Davis-Woodland

Water Supply Project Partners
Title: Davis-Woodland Water Supply Project
Predesign and permitting
Date: 2009 2012
The City of Davis, City of Woodland, and UC
Davis joined together to develop a regional
water supply project that diverts Sacramento
River Water to meet the potable water supply
needs of the Davis-Woodland communities. A
surface water treatment plant with the capacity
to treat 53 mgd has been proposed treat the
river water. Trussell Technologies, Inc. was
hired by West Yost Associates to assist in the
water supply permitting, preparing the water
quality monitoring plan, lead coordination with
the California Department of Public Health, and
to develop a predesign for the proposed facility.
Williams, Gordon (2012) Characterization of

the Suspended Solids in the Inland Empire
Brine Line and Approaches to Minimizing Solids
Formation.
27th
Annual
WateReuse
Symposium, Hollywood, FL. Sept 9-12, 2012.
Peer Reviewed Publications

Williams, G.J. (2015) Establishing Nitrification
Reliability Guidelines for Water Reuse. Water
Reuse Research Foundation, Alexandria, VA.
Williams, G.J. and Trussell, R.S. (2012)
Performance and cost comparison between
MF/RO and EDR membranes for reducing
recycled water salinity. WateReuse Research
Foundation, Washington, D.C.
Nelson, K.L, Williams, G., Sheikh, B., Holden,
B., Crook, J., and Cooper, R.C. (2011) Filter
Loading Evaluation for Water Reuse.
WateReuse Research Foundation, Washington,
D.C.
Williams, G.J., Sheikh, B., Holden, R.B.,
Kouretas, T.J. and Nelson, K.L., (2007). The
impact of increased loading rate on granular
media, rapid depth filtration of wastewater.
Water Research 41(19), 4535-4545.
Williams, Gordon (2012) The suitability of

nitrification for reliable disinfection of recycled
water
using
free-chlorine.
WateReuse
California Annual Conference, Sacramento, CA.
March 25-27, 2012.
de Barruel-Day Monique and Williams,
Gordon. (2011) Starting at One Drop
Water Quality Monitoring for New Surface
Water Treatment Facility. California-Nevada
AWWA Annual Fall Conference, Reno, NV.
October 17-20, 2011.
Williams, Gordon, Love, David C.,
Sheikh, Bahman and Nelson, Kara L. (2010)
Role of Coagulation and Particle Association in
Removal of Viruses in Tertiary Granular Media
Filters. WateReuse Symposium, Washington,
D.C. Sept 12-15, 2010.
Williams, Gordon (2010) PPCPs and
Pesticides: Significance and Implications for
Water Utilities. California-Nevada AWWA
Annual Fall Conference, Sacramento, CA
October 5-8, 2010.
Williams, Gordon, Rhodes Trussell, Eileen
Idica, Celine Trussell, Brett Faulkner (2013)
Use of Empirical Filter Models in Water
Treatment. AWWA Water Quality Technology
Conference, Long Beach, CA. November 5,
2013.
Select Non-Peer Reviewed Publications

Williams, Gordon (2013) Unlocking the
potential for low-CT tertiary disinfection:
Providing reliable nitrification to ensure a freeTRUSSELL TECHNOLOGIES, INC. | Gordon Williams, Ph.D., P.E. Resume
RESUM
BAHMAN SHEIKH, PH.D., P.E.
Water Resources and Water Recycling Specialist
Distinguished Fellow, Center for Integrated Water Research, University of California, Santa Cruz
http://www.bahmansheikh.com Bahman.sheikh@gmail.com
EXPERIENCE SUMMARY
Bahman Sheikh has over 30 years of domestic and international experience in research,
planning, and design of water resources projects, specializing in water conservation, reclamation,
reuse, and recycling (beneficial reuse of treated wastewater). His career began as a university
professor, teaching courses in water quality for various irrigation applications. Sheikhs academic career was followed by consulting, technical investigations, planning, and design of water resource facilities. Sheikhs water recycling experience includes service in the public sector with
goal-setting, project planning, regulatory liaison, public outreach, and implementation of public
policy programs. The focus of much of this work has been on public health and safety from the
microbiological and chemical quality of water used for irrigation and other applications. He has
served clients in 21 countries, including Peru, Bonaire, Mexico, South Korea, Australia, Saudi
Arabia, Egypt, India, Jordan, Kuwait, UAE, Syria, Bahrain, Morocco, and Tunisia.
Bahman Sheikh has extensive experience in all aspects of water resources management, water
use patterns and promotion of water use efficiency, water reclamation, recycling, and reuse, including the technical and regulatory issues, water quality, program management, alternatives
analysis, feasibility studies, and planning for long-term development of water recycling in large
and small communities. He conceived, planned, and conducted major long-term pilot studies of
pioneering water recycling programs in Monterey County, California, and in the City of Los Angeles, demonstrating the safety of regulated use of highly treated and disinfected reclaimed water.
Bahman Sheikh is a member of the Research Advisory Board of the National Water Research
Institute. He served on the Board of Directors of WateReuse Association and WateReuse Foundation. Highlights of Bahman Sheikhs specialized experience are briefly listed below:
Domestic
International
Denver Water2014-Ongoing
Preparation of documentation and presentations
to provide the basis for the Colorado public
health and water quality assurance authorities
to consider allowing more widespread uses of
highly-treated recycled water, especially for irrigation of edible crops.
Jaipur, Pune, Faridabad, India 2012-2013

Through subcontract with DAI: Prepared customized water use survey instruments for residential, industrial and commercial sectors of
the three cities and trained local interviewers
who completed hundreds of individual user
profiles. The statistical analysis of these audits
resulted in a series of recommendations for future water efficiency strategies and policies for
the three cities. Prepared water conservation
and reuse elements of Municipal Water Use Ef-

Currently serving on a consultant team planning a potable reuse project involving injection
Water Reuse Consultant
Domestic
of highly treated recycled water into the Seaside Aquifer, as part of a multi-faceted water
supply plan for the future of Monterey Peninsula.
San Francisco Public Utilities Commission2011Ongoing
As joint-venture partner with Kennedy/Jenks
Engineers, prepared master plan for development of recycled water project on the Eastside
of San Francisco. Customers include dualplumbed buildings prepared for switching to
recycled water for toilet flushing, parks and
landscapes switching to recycled water for irrigation, and other uses.
City of San Jos, California1997--Ongoing
Provides ongoing training for hundreds of newly assigned site supervisors for customers receiving recycled water from the SBWR network. Prevention of cross connection and
backflow in dual-plumbed buildings and dualuse sites is a major component of this project.
Provided expert consulting services throughout
the two decades of development of the South
Bay Water Recycling (SBWR) infrastructure.
Customers of SBWR include dual-plumbed
buildings using recycled water for toilet flushingsuch as the new San Jose City Hall and
the 49ers Levis Stadium in Santa Clara.
Created a mathematical model for projecting
the economic impact of salinity increases in recycled water due to industrial brine discharges
into the City sewers upon the customers of recycled water.
Conducted site investigations in response to recycled water customers concerns about water
quality and landscape impacts.
Reviewed and critiqued another consultants
study of impacts of recycled water on Santa
Clara and Llagas Groundwater subbasins, with
special emphasis on NDMA fate and transport.
Santa Clara Valley Water District2000--Ongoing
Currently, facilitating discussions among top
managers in the District regarding future potential strategies for eventual implementation of
potable reuse optionsindirect and/or direct.
Prepared a computational model to assess the
impact of irrigation with recycled water over
the unconfined aquifers in Santa Clara Valley,
with special emphasis on salinity.
Page 2
International
ficiency Guidelines for three cities in India:
Jaipur, Pune, and Faridabad.
German Government Development and Export Fund
(KFW)
2003, through Dorsch Consult. Provided expertise for the design of a water reclamation
and reuse treatment and distribution infrastructure for the Greater Gaza City, Palestinian Territory.
2005, through Dorsch Consult. Provided specialized engineering services for the design of
an efficient irrigation system using recycled
water for landscaping in hotels and government
buildings on the Island of Bonaire, in the
Netherland Antilles.
United Nations Food and Agriculture Organization
(FAO)
2013, Provided Study Tour of exemplary recycled water projects in the United States for a select group of officials from the Saudi Arabia
Ministry of Agriculture. The Study Tour
spanned major water reuse sites in Florida, California, and Virginia.
2009, Served as technical advisor for use of
recycled water (water reclaimed from
wastewater, locally referred to as Treated Sewage Effluent, or TSE) in irrigated agriculture
throughout the Kingdom by providing guidelines, leading training sessions.
Barwon Water, Victoria, Australia
2010-2013, Served as member of expert panel
independently evaluating planning efforts toward an indirect potable reuse project to be implemented as part of a multi-pronged approach
to future water supply security for the region.
Australian National Environmental Protection
Council Service Corporation
Peer reviewed draft of the Australian National

Guidelines for Water Recycling
Tunisia, Transfer of Recycled Water from Tunis to
Southern Tunisia
2009, Provided guidelines and case studies of
similar transfers over long distances for use in
irrigation, industry, and geothermal fields replenishment.
2007, Guided a group of Jordanian engineers in
Domestic
Facilitated discussions between the District and

the City of San Jose (SBWR) regarding future
form of collaboration between the two agencies
for delivery of recycled water to their service
areas. A forty-year agreement for joint development and operations resulted from the success of these negotiations.
City of Chula Vista2002

Investigated the feasibility and comparative
costs and benefits of a large number of water
demand management options, including residential water conservation, commercial and industrial measures to reduce demand, use of
gray water for landscape irrigation, and water
recycling.
Marin Municipal Water District2001
Investigated the comparative costs and benefits
of alternative sources of water supply for the
District including use of gray water, water recycling and desalination of seawater from the
San Francisco Bay or from the Pacific Ocean.
City of Los Angeles, California1991-1996
Developed achievable goals and a master planfor recycled water development that were
adopted by the City Council. Provided interdepartmental liaison that enabled planning and
ultimate implementation of several major water
recycling projects in cooperation with West
Basin Municipal Water District. Prepared policy analysis for control of salt discharges from
residential water softeners into the municipal
sewer system. Commissioned a city-wide survey of water softener use and salt purchase patterns of residents. Recommended adoption of
an ordinance for prohibition of use of selfregenerating water softeners, which involve
discharge of salts and wastage of water as brine
is periodically discharged into the sewers during the regeneration cycles.
Conducted a year-long graywater reuse pilot
project at eight residential locations throughout
the City of Los Angeles with monthly monitoring of soils, water, and vegetation for microbial, chemical and other characteristics.
Monterey Wastewater Reclamation Study for Agriculture1975-1986
Managed $7.2 million research and demonstration project on irrigation of raw-eaten vegeta-
Page 3
International
site visits to wastewater treatment plants in various parts of Tunisia, with an emphasis on beneficial uses of reclaimed water.
Amman, Jordan (Subcontract with various USAID
contractors)
2008, through DAI, Water Efficiency Recommendations for High Rise and High Density
Developments in the Greater Amman Municipality, developing best management practices
(BMPs) for water reuse and conservation.
2005, through Chemonics, Review of Aqaba
Watger Demand and Expanded Evaluation of
Water Resources.
2004, through ARD, Facilitated discussion
workshops for members of Water Reuse Standards Committee from the Ministry of Water and
Irrigation, Ministry of Health, and the Jordanian Institute for Standards and Metrology.
These workshop sessions led to formulation of
recommended water reuse standards for adoption by the government of Jordan.
King Saud University, Riyadh, Saudi Arabia2006Date
Retained as Senior Advisor to Prince Khaled
Chair for Water Research at the Department of
Civil Engineering.
Provides periodic workshops and seminars to
graduate students and government officials on
sustainable water policies and practices
Arriyadh Development Authority (ADA)
2000. Sheikh created a master plan for water,
wastewater and reclaimed water for the City of
Riyadh, Saudi Arabia, for the period to 2022 at
which time the Citys population would increase by 7,000,000 people.
2007. Assisted ADA in development of terms
of reference (TOR) for bidding for implementation of water reclamation facilities (treatment,
distribution, and retrofits) throughout the rapidly developing areas of the City of Riyadh.
2009. Oversaw and reviewed work products of
other consultants engaged to prepare water recycling facilities plans for the City of Riyadh
Kuwait Institute for Scientific Research
2008, Prepared recommendations for updating
of Kuwaits regulations and criteria for use of
reclaimed water in agriculture, landscape irriga-
Domestic
bles with recycled water, for over eleven years.

Planned scientific design of field experiments
to distinguish any impacts of use of reclaimed
water on plants, soils, crop yield, crop quality,
groundwater, and the environment.
Published reports of findings and obtained the
agreement of public health officials to permit
use of the reclaimed water on raw-eaten food
crops.
Performed liaison and facilitation services
among stakeholders, including farmers, public
health officials, water supply agencies, and
other environmental and citizen groups
West/Central Basin Municipal Water Districts

1986-1988
Provided technical input into the Districts extensive water reuse activities, analyzing alternatives, feasibility, economic viability, regulatory
compliance, and funding of numerous projects.
Participated in Districts public outreach functions, promoting recycled water use
Prepared the Districts Urban Water Management Plan
Conducted technical sessions for potential new
customers of recycled watergolf courses,
nurseries, parks, industries.
Co-chair of the International Committee, working to expand the reach of the Association into
the Middle East region.
Completed a White Paper on Graywater for the
Association Board of Directors policy decision
vis--vis inclusion of graywater in the Association portfolio.
Completed a national training manual for site
supervisors and users of recycled water.
Prepared and updated summary of Title 22 allowed uses of recycled water.
Served as chairman of Public Education Committee.
Collaborated in the preparation of an interactive compact disc for landscape users of recycled water for problem-solving and design of
new landscaped irrigated with recycled water.
Served on the video committeeWater In An
Endless Loop.
Prepared popular brochure on Graywater
Clear Facts about Gray Water.
Page 4
International
tion, industry, and groundwater recharge.
United Stated Agency for International Development
2006, through CDM and PA Consulting: Assisted local staffs in the cities of Nagpur and
Hyderabad, India, to develop industrial water
recycling and reuse programs, beginning with
pilot treatment systems.
2003, through ARD: Developed a new framework for Standards, Regulations, and Legislation for Water Reuse in Jordan.
2004, through CDM: Prepared Chapter 8 of
the USEPA/USAID Water Reuse Manual, describing international water reuse practices.
2003, through Chemonics: Reviewed Egyptian
proposed rules for use of reclaimed water in agriculture.
2004, through PA Consulting: Reviewed a
master plan for a swap of agricultural water
with urban reclaimed water in the metropolitan
Hyderabad, in the state of Andra Pradesh, India.
The World Bank2001
Prepared an extensive background document
and proceedings and provided technical resource to a regional water reuse workshop for
10 countries of the Middle East and North Africa (MENA) in Cairo, Egypt.
Jaffna Peninsula, Sri Lanka1983
Developed end user water use information database and recommended water conservation
policies and strategies in urban and agricultural
areas of Jaffna Peninsula including the most
cost-effective methods for reducing demand for
water, especially during the low-rainfall seasons.
Casablanca, Morocco. Use of Treated Wastewater
Effluent for Irrigation of Early-Season Vegetables
for the European Export Market
1990, Prepared economic feasibility analysis of
reclaiming wastewater from the CasablancaMohammediah areas for use for irrigation of
vegetables in the suburban agricultural region,
specifically for early-season export to the European market.
Author of Chapter 6 in Water Reuse for Irrigation
Edited by Valentina Lazarova and Akia Bahri,
CRC, 2005.
Domestic
Page 5
International
Author of Terra Linda Demonstration Garden for

Recycled Water-Irrigated Landscapes in Marin
County, for Marin Municipal Water District, June
2010
Author of White Paper on Graywater, a Policy
Analysis for WateReuse Association Board of Directors, April 2010
Author of Site Supervisor Training Manual: for
Users of Reclaimed Water, September 2006
Principal Author of Chapter 6 on Public Education
in AWWA/WEF Potable Reuse Book
Collaborated with 13 contributors to the Chapter content to provide a manual, complete with
examples of cases and lessons learned from water reuse ongoing projects.
Principal Author of Chapter 17 in Wastewater Reclamation and Reuse
Collaborated with three co-authors, documenting the results of the eleven-year pilot study investigating the safety of use of recycled water
for irrigation of food crops in Monterey County, California.
PROFESSIONAL HISTORY
1996-Date Independent Water Resources and Reuse Consultant, providing specialized services to public and private clients in their water reclamation projects.
Major current and recent clients include USAID, The World Bank, Petroleum
Institute of Mexico, Marin Municipal Water District, Metropolitan Water District of Southern California, Coachella Valley Water District, Las Virgenes
Municipal Water District, Monterey Regional Water Pollution Control Agency, the City of San Jose South Bay Water Recycling Program, West/Central
Basin Municipal Water Districts, Parsons Engineering Science, Harland Bartholomew, Harza Environmental Services, Bechtel International, ARD, Inc.,
City of Chula Vista, and Central Contra Costa Sanitary District. In addition to
numerous projects in California, Bahman Sheikh serves clients with water reclamation projects in various countries, including the Netherland Antilles
(Bonaire), Jordan, Kuwait, Saudi Arabia, Bahrain, Turkey, Peru, Tunisia, Morocco, and Egypt.
1994-1996
West Basin and Central Basin Municipal Water Districts. Water Resources and Wastewater Reuse Policy Specialist. In this capacity he advised the Districts management on water policy issues, represented the Districts at various State forums, interfaced with regulatory agencies, environ-
Page 6
mental groups, community organizations, and the public, and worked with
water customers and member utilities to solve issues and problems arising as
the District expanded its water reclamation service area. Representing the
Districts, Bahman Sheikh served on a number of Statewide committees working to manage the States water resources more efficiently, e. g.:
1989-1994
U.S. Bureau of Reclamation Executive Management Committee, overseeing the preparation of the Southern California Comprehensive Water
Reclamation and Reuse Study with federal-local partnerships.
State Potable Reuse Committee, convened by the Directors of the State

Department of Water Resources and the State Department of Health Services to develop and foster regulatory and public acceptance for safe augmentation of potable water supplies with potable reclaimed water.
Chair, Public Education Committee of WateReuse Association of California, planning and implementing public information and outreach programs
on water reuse for the Association.
City of Los Angeles. Executive Director, Office of Water Reclamation.

This Office was created within the Board of Public Works to bring into focus
the Citys basic goal of maximizing the reclamation of its wastewater resource. The City recognized the need for new water policy directions because
of the increasing vulnerability of its sources of imported water supply. Bahman Sheikh was recruited to set near- and long-term water reclamation goals,
bring together diverse decision-making bodies, help establish funding mechanisms, be a good-will ambassador to the public and to outside agencies, and
prepare plans and strategies to achieve the Citys basic goal. Policy analysis,
legislative recommendations, funding and financing, interagency coordination, and interdepartmental liaison were important aspects of Bahman
Sheikhs responsibilities.
Specific goals recommended by Bahman Sheikh were adopted as City goals
by the Council and by the Board of Water and Power Commissioners. Based
on these adopted goals, a number of water reclamation projects have been developed and are now being implemented. An important function of the Office
was coordinating the water reuse activities of the major water purveyor
(LADWP) and wastewater management entity (Department of Public Works)
in the City, and establishing an outreach program to make the public aware of
the safety and desirability of water reuse in all its forms. He designed and directed a yearlong pilot project demonstrating the safety of using gray water
systems for residential landscape irrigation. The results of this pilot project
were the technical basis for new regulations adopted Statewide for residential
gray water use. He provided testimony at numerous local and State hearings
before a variety of boards regarding reclaimed water policy.
The Office of Water Reclamation worked closely with the Mayors Office, the
City Council, and the Boards of Commissioners of Public Works and Water
and Power. Examples of initiatives presented to policy makers were the gray
water legalization policy and ordinances to control water softeners and to require dual plumbing in all new high-rise construction. The resultant policies
caused implementation of several water reclamation projects. Bahman Sheikh
represented the City of Los Angeles at numerous statewide water forums, including the following:
1987-1989
Page 7
Chair, Regulatory Committee of the WateReuse Association of California,

working with State Department of Health Services to revise regulations
governing water reuse.
Member, Bay Delta Oversight Council (BDOC) Technical Advisory Committee on Water Supply.
Chair, Survey Committee of the WateReuse Association of California. Prepared the 1993 estimate of Statewide water reuse potential in cooperation
with the State Department of Water Resources, Metropolitan Water District
of Southern California, San Diego County Water Authority, and numerous
other retail and wholesale water purveyors.
Member, California Ad-Hoc Gray Water Committee. Prepared Appendix J

to the State Plumbing Code to allow individuals to use gray water in residences, under special restrictions, to protect the public health and prevent
backflow into the community water supply.
Member, DWR/DOHS-sponsored committee to develop dual plumbing

standards for reclaimed water service inside high-rise buildings for toilet
flushing and other non-potable water uses.
Member, Legislative Committee of WateReuse Association of California,

preparing and supporting legislation to facilitate and expand uses of reclaimed water in the State.
Member, U.S. Bureau of Reclamation Executive Management Team for the

Southern California Comprehensive Water Reclamation and Reuse Study.
CH2M HILL. Civil/Environmental Engineer. Directed and managed major water reuse projects and contributed senior review and specialized expertise to the firms water supply and reclamation projects. Examples of his contributions include:
City of Ankara, Turkey: participated in developing a master sewerage

plan for the capital City of Ankara, Turkey, population 4 million, where he
directed the modeling of the wastewater collection system for the entire
City.
City of Los Angeles: Participated in the preparation of the Citys Advanced Planning Report by leading the water supply shortfall projections
and analyses that resulted in recommendations for full utilization of the
Citys reclaimed water potential. The Citys APR provides for wastewater
management planning for the next 100 years and the Citys needs for major
wastewater and water reclamation infrastructure facilities.
City of Santa Rosa: Analyzed nutrient balance in two basins proposed to

receive reclaimed water for irrigation of fodder crops.
San Jose/Santa Clara Treatment Plant: Analyzed opportunities for reclamation of the effluent from the plant and recommended a phased approach
including irrigation of parks, industrial cooling, recharge into groundwater
aquifers, and dilution of Leslie Salt Companys bittern before discharge.
1970-1987
Page 8
PARSONS Engineering-Science. Manager. He was Project Director and

oversaw the work of several project managers and engineers performing assignments on a variety of environmental engineering projects for diverse private and public sector clients. His projects are briefly highlighted below:
Areawide Water and Sewerage Master Plans: Managed comprehensive

areawide water and sewerage planning studies for mountainous, desert, and
metropolitan areas of San Bernardino, Napa, and El Dorado Counties under
a Farmers Home Administration planning grant program.
Monterey Regional Water Pollution Control Agency: Bahman Sheikh was
responsible for the conception, direction, and execution of the 11-year pilot
field demonstration project for Monterey Regional Water Pollution Control
Agency, investigating the feasibility of irrigating raw-eaten food crops with
disinfected, tertiary-treated reclaimed water. This project, known as the
Monterey Wastewater Reclamation Study for Agriculture (MWRSA), attracted worldwide interest and has been reported at many conferences and
professional publications. Bahman Sheikh led MWRSA from its inception
in 1976 continuously through the publication of its final report in April
1987. His effective communication of the technical intricacies of water reuse to the local farmers, local health authorities, and a score of different
governmental agencies was crucial to the successful completion of the project. Large-scale irrigation with recycled water on 12,000 acres in the
northern Monterey County is now routine, thanks in part to the success of
MWRSA, credibility of its results, and the need for sources of additional
water supply in the region.
1967-1970
Northglenn-Denver, Colorado: Performed a water exchange study for

Northglenn, Colorado, investigating use of reclaimed Denver wastewater
for irrigation of sugar beets in exchange for rights to ditch waters to be diverted for municipal supply.
Las Palmas Ranch, Salinas, California: Directed the evaluation of various irrigation systems, including drip irrigation, for application on a 60-acre
hillside for reuse of treated municipal effluent from Las Palmas Ranch, a
proposed housing development near Salinas, California.
Environmental Impact Studies: Was responsible for development of Environmental Impact Reports and Statements on a variety of projects including land application of effluents and wastewater biosolids, solid waste disposal, and wastewater treatment. Bahman Sheikh performed erosion, sediment transport, irrigation, and urban runoff investigations as part of a comprehensive water quality management study of the James River Basin in
Virginia.
University of Shirz, Assistant Professor. Bahman Sheikh taught technical

courses in water systems design, water resources and supply management, water
utility administration, irrigation, soils, hydrology and hydraulics at the University
of Shiraz, College of Agriculture (in Iran). He designed and supervised construction of a hydraulics teaching and research laboratory at the field campus of the
College.
Page 9
ACADEMIC ACTIVITIES
In recent years, Bahman Sheikh has taught classesas guest lecturer and seminar
presenterin topics related to California water, at several institutions of higher learning, including:
Department of Civil & Environmental Engineering, Woods Institute for
the Environment, Stanford University
Department of Civil Engineering University of California, Davis
Public Policy Program at Pomona College
School of Architecture at the University of Southern California
Environmental Engineering Program at the University of Southern California
Environmental Engineering at California State University at Long Beach
Occidental College Faculty Seminar
Extension Service of the University of California at Davis, Courses in Legal and
Regulatory Water Issues
Water Resources Short Course at UCLA for Water Officials of the Government of
Thailand
INTERNATIONAL CONSULTING:
Over the past two decades, Bahman Sheikh has completed numerous overseas missions
of varying duration. Typically, he provides expert and specialized consulting services in
water resource management, wastewater treatment, water reuse and related topics, to
governmental agencies in countries including Mexico, Peru, South Korea, Sri Lanka,
Turkey, Syria, Bahrain, Tunisia, Morocco, and most recently in India, Egypt, Jordan,
Kuwait, United Arab Emirates, and Saudi Arabia. Funding agencies for these projects
are the World Bank, USAID, Asia Development Bank, and the local government agencies.
EDUCATION
1967, Ph.D., Soil Physics (Soil-Water Relations), University of California, Davis
1964, M.S., Irrigation (Water Science and Engineering), University of California, Davis
1962, Pomona College (Interdisciplinary Studies in Liberal Arts), Claremont, CA
1957, B.Sc., Agricultural Engineering, American University of Beirut, Lebanon
AWARDS AND HONORS
Resolution of Appreciation in recognition of 27 years of service from Board of Directors,
Monterey Regional Water Pollution control Agency, March 29, 2004.
Outstanding Service Award, WateReuse Association, 2002
Presidents Award of Appreciation, WateReuse Association, 2002
Appointed to the Board of Directors of WateReuse Research Foundation, 2001, served
until 12/2007.
Appointed to the Research Advisory Board of National Water Research Institute, 1995.
Recognized by City of Los Angeles City Council for efforts and accomplishments,
1994
Page 10
Recognized by City of Los Angeles Board of Public Works for vision and commitment, 1994
Elected to Board of Directors, WateReuse Association, 1993, served until 2002.
Integrated Resource Management Award, Water Policy Conference III, 1993
Outstanding Service Award, WateReuse Association of California, 1991
REGISTRATION
Professional Engineer, Civil, California: C 26633
PROFESSIONAL MEMBERSHIPS
American Water Works Association
Water Environment Federation
California Water Pollution Control Association
National Water Research Institute, Research Advisory Board
PUBLICATIONS AND PRESENTATIONS:
Graywaters Future Role in Integrated Water Management Planning, Scheduled for
presentation at the IWA Efficient 2011 conference at Dead Sea, Jordan, March, 2011.
Is Graywater Another Flavor of Water Reuse?, Presented at WateReuse Association
Symposium 25, Washington, D. C., September 2010.
Terra Linda Demonstration Garden for Recycled Water-Irrigated Landscapes in Marin
County, prepared for Marin Municipal Water District, June 2010.
Graywater White Paper, prepared for WateReuse Association Board of Directors, April
2010.
Maximizing Filtration Capacity for Production of Tertiary Recycled Water, presented
at WateReuse Association Symposium 24, Seattle, Washington, September 2009.
Recycled WaterFit for the Use, presented at WEFTEC 2008 Workshop on Water
Reclamation and Reuse: The Big Picture: Reclaimed Water as a Water Resource, Chicago, Illinois, October 18, 2008.
Future Potential for Recycled Water, presented at WateReuse Association Symposium
22, Tampa, Florida, September 2007.
Socioeconomic Aspects of Wastewater Treatment and Water Reuse, presented at
EMWater (Efficient Management of Wastewater) Regional Conference in Amman, Jordan, October 2006.
Higher Filter Loading Rates for Greater Water Reuse Capacity, presented at WEFTEC
06, Dallas, Texas, October 2006
Page 11
National Training Manual for Commercial Recycled Water Users, presented at the 21st
Annual WateReuse Association Symposium, Hollywood, California, September 2006.
A Scientific Basis for Regulating Filter Loading Rate for Production of Recycled Water
in California, presented at the 21st Annual WateReuse Association Symposium, Hollywood, California, September 2006.
with Ken Tanji, A Landscape Guide For Irrigation With Recycled Water, presented at
the 21st Annual WateReuse Association Symposium, Hollywood, California, September
2006.
Site Supervisor Training Manual: for Users of Reclaimed Water, prepared for and published by WateReuse Association, September 2006.
U.S. and International Perspectives on Recycled Water Disinfection, presented at the
2006 California Section Annual Conference, Bridging the Gap with Recycled Water,
March 12-14, 2006, San Francisco.
Filter Loading Evaluation for Water Reuse Presented at WateReuse Association California Section 2005 Annual Conference in San Diego on February 28, 2005.
Institutional Requirements in California and Florida for Implementation of Water Recycling/Reclamation Projects, Presented at WateReuse Symposium XIX, Phoenix, Arizona, September 21, 2004.
Water Reuse: International Perspectives and Rationale for Hyderabad, presented at
Confederation of Indian Industry, Hyderabad, India, September 14, 2004.
Water Recycling Projects in California: Opportunities and Challenges, presented at
2004 Annual Conference of Victorian Farmers Federation in Melbourne, Australia, July
14, 2004
Impact of Institutional Requirements on Implementation of Water Recycling / Reclamation Projects, presented at the 2004 Water Sources Conference in Austin, Texas, January
11-14, 2004.
"Indirect Potable Reuse through Groundwater Recharge and Surface Water Augmentation: The Gold Standard of Water Recycling in California", invited keynote presentation
at the National Water Recycling in Australia Conference, September 1-2, 2003, Brisbane, Australia.
Efficacy of Pathogen Removal at Full-Scale Operational Water Reuse Facilities in Monterey, California, presentation at WateReuse Symposium XVIII, September 7-10, 2003,
San Antonio, Texas.
Rules and Regulations/Guidelines for Water Reuse Presentation at MED-REUNET
Seminar, September 25-26, 2003, Izmir, Turkey.
Water Reclamation World-Wide: Revisions to the International Guidelines, presented
to Third World Water Forum, USAID-Sponsored Session on Update of Water Reuse
Guidelines, March 16, 2003, Kyoto, Japan.
Page 12
Ethical Dilemmas in the Water Cycle in the Middle East and North Africa presented to
Third World Water Forum, San Francisco Public Utilities Commission-Sponsored Session on Ethics in Water Management, March 19, 2003, Kyoto, Japan.
Comparing and Contrasting Benefits and Costs of Water Use Efficiency Measures in
Marin County and in Chula Vista", presented at CALFED Science Conference, January
2003, Sacramento, California.
Comparing the Costs and Benefits of Water Recycling Options with Seawater Desalination and Gray Water, presented September 10, 2002, at WateReuse Association Symposium XVII, Orlando, Florida.
Economic Impacts of Salt from Industrial and Residential Sources, presented at
AWWA-WEF Joint Water Resources Conference, Reuse, Resources, Conservation,
January 2002, Las Vegas, Nevada.
Building Water Conservation into New Homes in Chula Vista, California, presented at
AWWA-WEF Joint Water Resources Conference, Reuse, Resources, Conservation,
January 2002, Las Vegas, Nevada.
Reclaimed Water: Benefits to Society Beyond Water Resource Value In Dry Regions of
the World, presented to The First International Conference on Economical and Social
Uses of Water in Arab Countries, June 18-21, 2001, Beirut, Lebanon.
with Anderson, J. et al., Climbing the Ladder: A Step-by-Step Approach to International Guidelines for Water Recycling presented at the 1st World Congress of the International Water Association (IWA), Paris, France, July 3, 2000.
Salt in Recycled Water: Agricultural and Landscape Limitations, presented at WateReuse Workshop on Salts In the Brine Stream, held in Phoenix, Arizona, March 29,
2000.
Riyadh, Kingdom of Saudi Arabia: A Vision of 2021: Introducing Water Reuse to A
World Capital, Presented to Water Reuse 2000, Joint AWWA-WEF Specialty Conference to be held in San Antonio, Texas, January 30-February 2, 2000.
The Importance of Reclaimed Water for Landscape Irrigation in the Arid Zone, keynote address to the First International Conference on Greenery and Environmental Beautification in Arid Zones, Sponsored by Kuwait Institute for Scientific Research, Kuwait
City, November 20-24, 1999.
Lessons From Abroad: Water Recycling Global Perspectives, presented at Symposium
XIV WateReuse Association, Long Beach, California, September 15, 1999.
with NWRI writing team, The Value of Water: Recognizing and Using the Full Potential of Your Water Supply, National Water Research Institute, Fountain Valley, California April 1999
Sustainable Use of Water, California Success Stories, Advisory Committee Member to
Pacific Institute for Studies in Development, Environment, and Security, Oakland, January 1999
Page 13
Hygienic Evaluation of Reclaimed Water Used To Irrigate Food CropsA Case

Study, Conference Proceedings, Advanced Wastewater Treatment, Recycling and Reuse, 2nd International Conference, IAWQ, Milan, Italy, September 14-16, 1998.
Tertiary Water Food Safety Study, report to the Monterey County Water Recycling
Projects Water Quality and Operations Committee, August, 1998.
Accounting for All the Benefits of Water Recycling with Eric Rosenblum, Steve
Kasower and Earle Hartling, Proceedings, Water Reuse 98, a joint specialty conference
of WEF and AWWA in Orlando, Florida, February 1-4, 1998.
Chapter 6, Public Information Programs, in joint publication of WEF and AWWA, Using Reclaimed Water to Augment Potable Water Resources, pp. 191-233, February
1998.
Chapter 17, Tertiary Reclaimed Water for Irrigation of Raw-Eaten Vegetables, in Reuse
of Wastewater edited by Prof. Takashi Asano, pp. 779-825, June 1998
Resolving Water Quality Concerns In Irrigation of Pebble Beach Golf Course Greens
with Recycled Water, in Proceedings of the Water Environment Federation 70th Annual
Conference (WEFTEC97), pp. 187-194, Chicago, Illinois, October 18-22, 1997.
International Practices In Water Reuse, in Proceedings of the Water Environment Federation 70th Annual Conference (WEFTEC97), pp. 281-284, Chicago, Illinois, October
18-22, 1997.
with Brock McEwen of CH2MHill and Tom Richardson of Montgomery Watson, Indirect Potable Reuse: State of the Art, presented to the Water Environment Federation
Specialty Conference on Beneficial Reuse of Water and Biosolids, Marbella, Spain, April
6-9, 1997.
An Informed Public Favors Water Recycling presented to the Florida Section/AWWA
Specialty Conference, Maitland, Florida, November 13-15, 1996.
with Eric Rosenblum, City of San Jose South Bay Water Recycling, Environmental Influences behind Water reclamation presented to the Florida Section/AWWA Specialty
conference, Maitland, Florida, November 13-15, 1996.
A Preview of the WEF/AWWA Guidance Manual on the Use of Reclaimed Water to
Augment Potable Water Resources, presented to WEFTEC96, Water Environment
Federation 69th Annual Conference, Dallas, Texas, October 5-9, 1996.
Global Perspectives on Water Reuse , presented to the Pacific Northwest Pollution
Control Association, Seattle, Washington, May 17, 1996.
Obstacles of Reuse Customers and their Resolution, presented to the Pacific Northwest
Pollution Control Association, Seattle, Washington, May 17, 1996.
Outreach and Public Education for Water Reuse presented to Water Reuse 96 a special
conference co-sponsored by WEF and AWWA, San Diego, February 25, 1996.
The Monterey StudyAgronomic Issues, presented to the California Irrigation Institutes 34th Annual Meeting, Sacramento, California, February 2, 1996.
Page 14
Uses of Recycled Water: Opportunities and Obstacles, presented to the 95 Statewide

Conference of the Association of Environmental Professionals, San Jose, California, July
15, 1995.
OWR NEWS, quarterly newsletter of the City of Los Angeles Office of Water Reclamation, was published regularly from 1990 through 1994, to communicate with City decision makers and the public, expanding public awareness of water recycling through dissemination of news and general information about the safety and necessity of uses of reclaimed water.
Future Water Recycling Potential in Southern California, presented to the American
Society of Civil Engineers Annual Meeting in Denver, May 23-26, 1994.
Status of Present and Future Water Recycling in California, presented to the Joint
AWWA/WEF Water Reuse Symposium, Dallas, Texas, February 27-March 2, 1994.
with James M. Kelly and Ronald E. Young, Emergence of Microbial Risk Assessment
as a Criterion in Regulating Water Reuse in California, presented to the Joint
AWWA/WEF Water Reuse Symposium, Dallas, Texas, February 27-March 2, 1994.
The City of Los Angeles Gray Water Pilot Project, presented at CONSERV93, cosponsored by ASCE, AWWA, and AWRA, Las Vegas, Nevada, December 12-16, 1993.
Back to the Future: Water Reclamation, panel participant at California Water Policy
III: Beyond Consensus conference, Los Angeles, October 21-22, 1993.
Direct Potable Reuse, Moderator of Panel of Experts at California Water Policy III:
Beyond Consensus conference, Los Angeles, October 21-22, 1993.
Survey of Future Water Recycling Potential in California, presented to the WateReuse
Association of California Symposium VIII, San Diego, California, October 13-15, 1993.
Results of the City of Los Angeles Gray Water Pilot Project, presented to the AWWA
Annual Conference and Exposition, San Antonio, Texas, June 6-10, 1993.
The City of Los Angeles Gray Water Pilot Project Shows Safe Use of Gray Water Is
Possible, presented to the ASCE Water Resources Planning and Management Divisions
20th Anniversary Conference, Seattle, Washington, May 3-5, 1993.
Removing Institutional Barriers to Water Reuse: A Three-Year Report Card, presented
to the AWWA-WEF Joint Management Conference, Atlanta, Georgia, March 2, 1993.
Water Reuse in Los Angeles, presented to Water Reuse Symposium, sponsored by Salt
River Project, Phoenix, Arizona, November 2, 1992.
Long-Range Planning for Water Reuse in the City of Los Angeles, in Wastewater Reclamation and Reuse, Water Science and Technology 24:9, pp. 11-17. Proceedings of International Symposium on Wastewater Reclamation and Reuse, Castell dAro, Costa
Brava, Spain, September 24-26, 1991.
Planning for Water Reuse to Meet the Growth Needs of the 21st Century for the City of
Los Angeles, Water Pollution Control Federation Conference, October 1990, Washington, D.C.
Page 15
Monterey Wastewater Reclamation Study for Agriculture, Research Journal, WPCF,

62:3:216-226, May-June 1990.
Use of Wastewater Effluent for Irrigation of Raw Eaten Vegetables: A Five-Year Field
Experiment Concludes It Is Feasible, Safe and Economical, presented at Water Pollution
Control Federation Annual Convention, Philadelphia, Pennsylvania, October 1987.
With R.G. Burau, Reclaimed Water for Irrigation of Vegetables Eaten Raw, California
Agriculture 41:7 and 8, pp. 4-7, July-August 1987.
Wastewater Effluent Reuse for Irrigation of Raw-Eaten Food Crops: A Five-Year Field
Study, presented at Water Reuse Symposium III, San Diego, California, August 1984.
Reused Tertiary Municipal Wastewater Effluent for Irrigation of Raw-Eaten Crops: A
Five-Year Study, presented at Water for the 21st Century: Will It Be There?, a symposium sponsored by Southern Methodist University, Dallas, Texas, April 1984.
Reused Tertiary Municipal Wastewater Effluent for Irrigation of Raw-Eaten Crops: A
Five-Year Study, presented to the California Water Pollution Control Association Water
Reuse Seminar, Emeryville, California. February 1984.
Treated Sewage for Crop Irrigation, presented to the Engineering Foundations Conference on Environmental and Energy Engineering in the Food Processing Industry XIV,
Santa Barbara, California, February 1984.
Possibilities for Reuse of Reclaimed Wastewater for the Hashemite Kingdom of Jordan, presented to the Jordanian Society of Engineers, Amman, Jordan, January 1984.
Monterey Agricultural Demonstration Project MWRSA, presented at California Association of Reclamation Entities of Water (CAREW) Conference, Santa Barbara, California, June 1980.
Reclaimed Wastewater for Food Crop Irrigation, presented at National Conference on
Environmental Engineering, American Society of Civil Engineers, San Francisco, California, July 1979.
Aerosol Generation in Sprinkler Irrigation, Proceedings, Water Reuse Symposium,
American Water Works Association Research Foundation, Washington, D.C., March
1979.
Food Crop Irrigation with Reclaimed Municipal Wastewater, Proceedings, Water Reuse Symposium, American Water Works Association Research Foundation, Washington,
D.C., March 1979.
FinalEIR
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PWM Final Eir September 2015

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FINAL ENVIRONMENTAL IMPACT REPORT

PURE WATER MONTEREY

Monterey Regional Water Pollution Control Agency

Denise Duffy & Associates, Inc.

Pure Water Monterey Groundwater

September 25, 2015

Monterey Peninsula Water Management District

Background ............................................................................................................................ 1-1

Master Responses to Comments ................................................................................... 3-1

Master Response #1: Adequacy of Draft EIR ........................................................................ 3-2

List of Comments ........................................................................................................... 2-1

Introduction ............................................................................................................................ 2-1

Introduction to the Final EIR ....................................................................................... 1-1

Comments and Responses on the Draft EIR ............................................................... 4-1

Introduction ............................................................................................................................ 4-1

Changes to the Draft EIR .............................................................................................. 5-1

Changes to Executive Summary

Proposed Source Water Availability, Yield, and Use

Pure Water Monterey GWR Project

Pure Water Monterey GWR Project

This page is intentionally blank.

Pure Water Monterey GWR Project

INTRODUCTION TO THE FINAL EIR

Pure Water Monterey GWR Project

Chapter 1. Introduction to the Final EIR

Distribution of groundwater from Seaside Basin. CalAm water distribution system

Pure Water Monterey GWR Project

Chapter 1. Introduction to the Final EIR

PUBLIC REVIEW OF DRAFT EIR

Pure Water Monterey GWR Project

Chapter 1. Introduction to the Final EIR

FINAL EIR CERTIFICATION

ORGANIZATION OF THE FINAL EIR

This Final EIR is organized into the following sections:

Chapter 3.0, Master Responses to Comments, contains master responses to common

Appendices, including the following:

Proposed Source Water Availability, Yield, and Use

Amended Water Rights Analysis

Pure Water Monterey GWR Project

Chapter 1. Introduction to the Final EIR

Salinity Impacts to Elkhorn Slough resulting from Surface Water Diversions

Consideration of Water Right Application 32263 in the Pure Water Monterey

Resumes and Qualifications from Key EIR Technical Contributors

MASTER RESPONSE TO COMMENTS

Pure Water Monterey GWR Project

Chapter 1. Introduction to the Final EIR

This page is intentionally blank.

Pure Water Monterey GWR Project

Agency/Organization (if applicable)

Federal and State Agencies

California Office of Planning and Research

California Department of Transportation

State Water Resources Control Board

California State Lands Commission

National Oceanic and Atmospheric Administration National Marine

Alecia Van Atta

Central Coast Regional Water Quality Control Board

California Department of Fish and Wildlife

Regional and Local Agencies

Marina Coast Water District

Monterey Peninsula Water Management District

Monterey County Water Resources Agency

Pure Water Monterey GWR Project