1. Test Slant Well Project Permit Amendment (Coastal Commission Agenda Item Tu 15a)
Date: Oct. 6, 2015
Presented by CAW at the Oct. 6, 2015, California Coastal Commission hearing

2. Cal-Am Concurs with Staff
Cal-Am fully supports the Commission’s Staff Report, recommended actions and findings
Cal-Am also agrees with all of the expert conclusions of the Commission’s independent hydrogeologist

3. Court Fully Upheld Test Slant Well CDPs
Commission unanimously approved the CDPs for this temporary scientific test project project in Nov. 2014
Two lawsuits challenged the Commission’s approval
Santa Cruz Superior Court fully upheld the Commission's approval and its CEQA review of the Project
The Court fully rejected each of the opponent’s claims
The Court found the Project would not result in groundwater impacts

4. Approved Project Goals
Gather important data re: geologic, hydrogeologic, and water quality characteristics in the underlying aquifers
Key to determining the feasibility of slant wells for water production in the area of the Monterey Bay
Subsurface intakes are the preferred method of seawater intake by coastal regulators
Monterey Bay National Marine Sanctuary requires that the feasibility of such intakes be investigated
Subsurface intakes require research to establish a location with ample water supply and acceptable water quality that will not impact inland groundwater supplies

5. Test Well Construction and Operation
Monitoring well data showed that regional groundwater levels declined in Spring 2015, prior to Project pumping
Major construction completed in Feb. 2015; finishing work and initial tests occurred in March 2015, and pumping began in April and continued until June 5, 2015
From April to June, water levels continued the downward trend at MW-4 and approached a 1.5 foot decline
Pumping stopped on June 5 to comply with Special Condition 11
Based on data from when the test well was both on and off, the Hydrogeologic Working Group determined that the test well may have contributed (if at all) to at most a ¼ foot drop at MW-4
This is less than groundwater modeling projected

6. Regional Groundwater Trends
HWG determined that downward trends in water levels were due to factors other than the test slant well
Since June 5, MW-4 continues to decline in response to regional groundwater pumping inland
“These seasonal declines are not a result of the cone of depression from one or a few wells, but rather a cumulative decline in groundwater levels and groundwater storage from tens to hundreds of pumping wells. . .”
HWG Letter to Charles Lester (July 23, 2015)

7. Proposed CDP Amendment is Narrow
The proposed CDP amendment does not re-open the Commission’s prior findings concerning the Project as a whole
The amendment is narrowly focused on a single condition
To ensure that the condition governing groundwater monitoring is protective and can be practically implemented given observed changes in regional groundwater levels

8. Amendment to Special Condition 11
Intent of Special Condition 11 was to establish a performance standard to ensure that test well would not cause water level decreases or salinity increases greater than modeling results
In order for these performance standards to work in practice, they must be applied against regional trends in water levels and salinity not caused by the test well
The amendment would retain previously approved numerical standards, but would compare monitoring results to observed regional trends
The Commission’s independent hydrogeologist confirmed that in the proposed language for Special Condition 11, “the threshold values and monitoring approach are appropriate for preventing impacts to agricultural groundwater”

9. Opponent Claims are Not Supported
Monitoring well data shows no measurable effects from the test well outside 2,500 feet
Data shows no effect in 400 Foot Aquifer
Data confirms test slant well pumps water from Dune Sand and 180 Foot Aquifers – both intruded with seawater in capture zone
Expert analysis confirms that Special Condition 11’s standards will protect groundwater and that no adverse impacts will occur

10. Broad Community Support
Surfrider Foundation
Sierra Club
Salinas Valley Water Coalition
Planning and Conservation League Foundation
Monterey Regional Water Pollution Control Agency
Monterey Peninsula Water Management District
Monterey Peninsula Regional Water Authority
Monterey County Water Resources Agency
Monterey County Farm Bureau
LandWatch Monterey County
County of Monterey
Coalition of Peninsula Businesses
CPUC Office of Ratepayer Advocates
City of Pacific Grove
California American Water
All support the test slant well at the CEMEX site
(Signatories to CPUC Settlement)

11. Recommendation
Cal-Am respectfully requests that the Commission approve the permit amendment and adopt the findings in the Staff Report