2023-06-05-Item-5-Supplemental-1 — Grover Beach City Council, June 5, 2023

CENTRAL

COAST BLUE

MEMORANDUM
TO: Arroyo Grande City Council
Grover Beach City Council
Pismo Beach City Council
Central Coast Blue Regional Recycled Water Authority Board FROM: Geoff English, General Manager
RE: Supplemental Information - Joint City Council/Board Meeting Agenda Item 5 - Central Coast Blue Regional Recycled Water Authority Status Report and Project Update
DATE: June 5, 2023
Attached is correspondence received from Jeff Edwards regarding the above referenced agenda item.

C: City Managers
Assistant City Managers
Administrative Services Directors
Public Works Directors
Attorneys
City Clerks
Public Review Binder
CCBRRWA website
M Gmail Kelly Wetmore <[email protected]>
FW: Jeff Edwards comments on Item 5, CCB status report and project update [email protected] <[email protected]> Mon, Jun 5, 2023 at 9:52 AM To: [email protected]
From: Jeff Edwards <[email protected]>
Sent: Friday, June 2, 2023 8:57 AM
To: [email protected]
Subject: Jeff Edwards comments on Item 5, CB status report and project update Good morning Geoff,
Please find attached the scoring sheets for the State Prop 1 Implementation Grant Review.

Please provide copies of this email and attachments to all invitees (and some copies for the public) to the Monday, June 5th Joint City Council / JPA Meeting.

A couple of reviewer comments tend to sum up CCB quite well in my view and I will quote.

1. "The project has a high capital cost and appears to benefit Well 22 [sic]. Limited improvement of seawater intrusion based on the no project model. Not clear on regional benefits." This is a typo and should read "Well 23".

2. "The proposal did not look at the potential for further conservation to reduce the need for groundwater extraction and to provide a drought buffer. Conservation is likely a much less expensive seawater intrusion prevention strategy." I have calculated that for a one-time cost of $15,000,000 the entire NCMA could be retrofitted as compared to CCB at $93,000,000 and rising.

Please confirm receipt and let me know if you have any questions.

Thanks,
Jeff
Julie Tacker
Administrative Assistant
J.H. Edwards Company
P.O. Box 6070
Los Osos, CA 93412
805.235.0873 - Jeff
805.235.8262 - Julie
805.528.3569 - Office
3 attachments
CCB Review Sheet _Kira Smith SWB Engineering Geologist.pdf 375K
2 365K CCB Review Sheet 2_Kira Smith SWB Engineering Geologist.pdf 3CB Review Sheet 3_Kira Smith SWB Engineering Geologist.pdf 3/8/23, 2:09 PM Review Sheet Details
Welcome Kira Smith of State Water Resources Control Board. If this is not your Account, please og Help | Logout ut.

Main Menu > Proposal Search > Review Sheet Details
Review Sheet Details
This page displays the selected review sheet details including each review questions and the review panels comments. To see the other review sheets of this proposal go back to the list and click on the required review sheet.

A general scoring range of 0 to 5 points is provided for most technical review questions, except where noted, and should be added to the first answer box after each question. These exceptions will consist of "Yes/No" questions, which are evaluated so that five points will be given for each "Yes" determination while "No" determinations will receive zero points (i.e., no other possible scores aside from zero or five points). Technical reviewer may provide comments for each question in the comment box provided.

Please note, character limit of some of the comments boxes was increased to anticipate detailed responses/justifications.

Project/Applicant Background - 55 Points Possible
1 Does the proposal provide the following to support and justify the project:

An accurate and complete summary of other work completed to address the groundwater contamination and the relation of this project to other efforts?
Answer: 3
Answer: The proposal states that seawater intrusion is predicted to occur based on modeling results included in the proposal. However, the modeling results are based on a 150% increase in extraction relative to current extraction rates. The Phase 1B modeling report states that under current pumping conditions, there is "minimal seawater intrusion potential". b Accurate and complete regional and project maps depicting the site location, lateral and vertical extent of contaminated groundwater, location of production wells, location of any injection wells and area to be remediated?
Answer: 3
Answer: The report includes maps of the project injection wells and has separate maps that show the location of seawater intrusion that was observed in 1970 and that which was observed in 2009.

However, because of the way the maps are presented, it's difficult to determine if the seawater https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetld=224317 1/6 3/8/23, 2:09 PM Review Sheet Details
intrusion that was observed in the 1970s is located in the same area as the proposed project. The 2009 seawater intrusion event is located south of the project area. c A description of the groundwater basin, beneficial uses, and groundwater quality issues especially related to chemicals of concern (COCs) and their impact on drinking water sources? (Yes = 5 points, No = 0 points)
Answer: 5
Answer: Yes
d Accurate and complete identification of contaminant source areas) associated with the project area? Answer: 3
Answer: The contaminant source area doesn't currently exist. The contaminant source area only exists in future modeling scenarios under substantial increases in pumping. e Accurate and complete summary of the data available on the COCs and any changes in the extent of the plume and COC levels over time?
Answer: 3
Answer: The model predicts impacts primarily at one supply well, PB well 23, with very minor impacts at Ocean Community Services District wells occurring after 35 years and only when extraction is increased 300% or more over current levels.
f Description of consistency with any applicable groundwater management plan, court decree (for an adjudicated basin), salt and nutrient management plan, and other regulatory orders or requirements? Answer: 3
Answer: For CCB to truly mitigate the potential for seawater intrusion, there needs to be an agreed-upon limit on groundwater extraction and that limit needs to be less than the true sustainable yield (including the additional yield provided by the project), not the sustainable yield identified by the adjudicated agreement because that yield is clearly not sustainable. A 2 Does the proposal:
a Provide a complete description of the extent to which a search for responsible partyies)/potentially responsible party(ies) has been conducted?
Answer: 5
Answer: NA
b Provide a complete and accurate description of the known responsible party/potentially responsible party(ies) in relation to the proposed project?
Answer: 5
Answer: NA
Project/Applicant Background - 55 Points Possible (Continued) 3 Has the applicant and its technical team (if identified) conducted similar projects and demonstrated an ability to complete projects on time and within scope and budget? Answer: 5
Answer: Yes
4 How well is the project coordinated with cooperating entities such as; a water master (for adjudicated basins); federal, state, and local regulatory agencies; and any community organizations and is there documented support for the project from cooperating entities?* Answer: 3
Answer: a. Project coordinates with the entities subject to the adjudication but doesn't attempt to resolve the fact that each of the entities is allowed to pump greater than they are currently pumping and greater than an amount that is actually sustainable (regardless of the sustainable yield identifies in https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224317 2/6 3/8/23, 2:09 PM Review Sheet Details
the adjudication, which doesn't appear to actually be sustainable based on observed response of the basin).
5 Does the applicant demonstrate the required technical, managerial, and financial (TMF) capacity necessary for successful long-term operation and maintenance (O&M) of the project?* Answer: 5
Answer:

Program Priorities, Requirements, and Preferences - 35 Points Possible 6 Does the proposal, including the identified project goals and purpose, provide sufficient justification that the project, as described:
a Address one or more Proposition 1 prioritization criteria (Water Code section 79771(b)(1-5) (see Guidelines Section 2.1)?*
Answer: 5
Answer: Yes
b Address the State Water Board requirements (see Guidelines Section 2.2)?* Answer: 4
Answer: The proposed project prevents modeled seawater intrusion. However, this seawater intrusion is simulated to occur only if current pumping volumes are increased by 150% or more. If pumping volumes remain as they currently are, the existing empirical and modeling data indicate that no seawater intrusion occur.
c Address one or more State Water Board preferences (see Guidelines Section 2.3)?* Answer: 4
Answer: Based on the modeling results, the only well impacted by seawater intrusion is Pismo Beache's PB Well 23. It is unclear how this project benefits Oceano, whose population is included in the benefits calculation in the proposal.
d Address a significant groundwater contamination problem based on best estimates of the anticipated project benefits (by prevention or cleanup of contamination)?* Answer: 3
Answer: The proposal includes numerical groundwater simulations that show seawater intrusion occurring for a variety of pumping regimes. However, all of the model scenarios included in proposal show that seawater intrusion occurs when pumping is increased by some amount above current baseline. There is no simulation included in the proposal to show that seawater intrusion occurs under current pumping amounts.
e Provide the lowest cost alternative for achieving the project purpose and adequately considered other alternatives?*
Answer: 2
Answer: As a water supply augmentation/enhancemet project, CCB appears to be a cost-effective approach and the proposal provides a detailed comparison of other water supply enhancing options. However, the grant is for seawater intrusion prevention and the proposal does not evaluate all the possible alternatives for seawater intrusion prevention under current conditions.

For example, no consideration was given to conservation in the report. 7 Does the project include the use of new and innovative technology (or approaches)? (Yes = 5 points, No = 0 points)
Answer: 5
Answer: Yes
8 Has the applicant estimated one or more of the metrics of success (see Guidelines Section 8) and are the estimates reasonable for the project? Are the goals and targets reasonable and feasible within the life of the project?
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224317 3/6 3/8/23, 2:09 PM Review Sheet Details
Answer: 2
Answer: In general, the metrics of success included in the proposal seem inflated or that the success metric is not consistent with the intent of the grant.

One of the metrics of success identified in the proposal is increasing groundwater extraction. The intent of this funding mechanism is to mitigate or prevent seawater intrusion, not increase water supply.

Scope of Work - 40 Points Possible
9 Does the proposal include sufficient justification and provide:
a A detailed description of the technology and practices the project is proposing to use and adequate justification for the technical basis of the approach?* Answer: 4
Answer: For the most part, the application includes adequate justification for the technical basis. However, the design for advanced purified water doesn't include pretreatment prior to microfiltration (MF).

Because the feed water is secondary treated effluent, there may need to be pretreatment via ozone or other means to reduce TOC and/or nitrate concentrations prior to MF. b The supporting engineering calculations to demonstrate that the project will achieve its purpose?* Answer: 5
Answer: Yes
c The detailed tasks and deliverables necessary to complete the project? Answer: 5
Answer: Yes
d Adequate technical justification that completion of the tasks are appropriate and necessary to achieve the project purpose?*
Answer: 5
Answer: Yes
e Adequate and appropriate stakeholder involvement and include sufficient public outreach? Answer: 5
Answer: Yes
f An adequate description of how the proposed project is consistent with or is the appropriate next phase to address the contamination?
Answer: 2
Answer: The contamination doesn't currently exist and the proposal does not adequately explain why seawater intrusion would occur under current conditions. g A discussion on the required permits, environmental documentation California Environmental Quality Act (CEQA)/ National Environmental Policy Act [NEPA]), and landowner/access agreements required to implement the project?
(Yes = 5 points, No = 0 points)
Answer: 5
Answer: Yes
h A description of the status of any design plans and specifications? (Yes = 5 points, No = 0 points) Answer: 5
Answer: Yes
Schedule - 20 Points Possible
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224317 4/6 3/8/23, 2:09 PM Review Sheet Details
10 Does the proposal include a description of any key decision points, milestones, or deliverables that could impact project scope, cost, and schedule?
Answer: 3
Answer: The proposal includes key decisions but no description of how these decisions may affect costs, milestones, or deliverables.
11 Will the project be completed in a timeframe required for the next phase of the overall project, if applicable?
Answer: 5
Answer: Yes
12 Does the proposal include a schedule that is consistent with and reasonable given the tasks described in the Scope of Work and the available budget?
Answer: 3
Answer: No, the time schedule does not seem to be achievable. Based on the documentation provided in the application, the Title 22 Engineering Report development and approval by the Division of Drinking Water is way behind schedule already. The antidegradation and geochemical assessments identified in the proposal are way behind the schedule included in the application.

The timeframe for permit adoption by the Regional Board is overly optimistic. 13 Based on the proposed schedule and deliverables, can the project be completed within the appropriation timeframe?*
Answer: 3
Answer: The application anticipates that the project will be completed by March 2025, or in approximately

2.25 years. Based on the timeline included in the application and the progress observed at similar projects (Pure Water Soquel and Monterey, City of Morro Bay), March 2025 seems very optimistic.

Budget - 25 Points Possible
Do the summary budget table, narrative, and supporting cost documentation justify the project costs? Are the costs reasonable?*
Answer: 3
Answer: The costs seem on the low end compared to similar projects. The cost for the Central Coast Blue AWPF treatment facility is estimated at approximately $40,000,000. However, the cost of the Pure Water Soquel (PWS) treatment facility is more than double that at $90,000,000. Similarly, the CCB estimated cost for approximately 2 miles of conveyance pipeline and 5 injection wells is approximately $26,000,000 but PWS estimated the cost for 4 miles of conveyance and 4 wells at $39,000,000 and actual costs ended up being much higher. 15 Are the tasks shown in the budget consistent with the tasks shown in the work plan and schedule? Answer: 5
Answer: Yes
16 Was a cost-benefit analysis provided justifying the proposed project relative to other feasible alternatives?*
Answer: 2
Answer: The project is proposed to be a seawater intrusion prevention project but seawater intrusion is only anticipated to occur if there are increases in pumping. The proposal compares the project to other water supply augmentation projects which will bring more water the project entities by either recycling or acquiring more surface water. As a project to increase the size of the water supply portfolio of the project entities it seems to be equivalent or superior to the alternatives. 17 Are the benefits significant given the cost of the project? Answer: 3
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetld=224317 5/6 3/8/23, 2:09 PM Review Sheet Details
Answer: As a strategy to prevent seawater intrusion under current conditions, there are alternatives that were not evaluated, such as conservation, and these alternatives are likely less expensive than the proposed project.
18 Does the proposal include leveraging of other funding sources (i.e., private, federal or local) and are the sources of matching funds clearly committed and well-documented? (Yes = 5 points, No = 0 points) Answer: 5
Answer: Yes
Performance Evaluation and Monitoring - 15 Points Possible 19 Does the proposal include sufficient justification and provide a discussion of the proposed data collection and monitoring and how that data will be managed and reported? Answer: 5
Answer: Yes
20 Will the measurement tools and methods effectively monitor project performance and target progress? Answer: 5
Answer: Yes
21 Is the proposed monitoring appropriate for the benefits claimed, and the process for which it will be tracked discussed?
Answer: 5
Answer: Yes
DAC/EDA - 20 Points Possible Bonus
Technical Reviewer need not answer the question below:

22. Does the implementation project, supported by the planning project proposal indicate project benefits to severely disadvantaged communities (SACs)/ disadvantaged communities (DACs)/ economically distressed areas (EDAs) and are the anticipated benefits sufficiently justified?

23. Does the applicant provide sufficient documentation that the project is supported by SDACs/DACs/EDAs that are anticipated to benefit from the implementation project? Answer: 0
Answer: No per DFA
Overall Review Comments: Central Coast Blue is a worthwhile water recycling and water supply enhancement project. However, the modeling and empirical data indicate that seawater intrusion is not currently occurring and as such, the project may not be a great fit for this grant. The Phase 1B model states that the threat of seawater intrusion is minimal under current pumping volumes. The 2021 NCMA annual report indicates that water levels are stable at the metric for the deep well index and groundwater flow direction is towards the coast and that seawater intrusion is not occurring. The proposal did not look at the potential for further conservation to reduce the need for groundwater extraction and to provide a drought buffer. Based on the urban per capita water rates reported in the 2021 NCMA annual report, there is quite a bit of conservation available, particularly when compared the statewide goal of 55 GPD per capita. Conservation is likely a much less expensive seawater intrusion prevention strategy. © 2023 State of California. Conditions of Use / Contact Us | Privacy Policy. https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224317 6/6 3/8/23, 2:15 PM Review Sheet Details
Welcome Kira Smith of State Water Resources Control Board. If this is not your Account, please log Help | Logout ut.

Pin No: 48162 - Central Coast Blue - ASSIGNED
Application Attachments Eligibility Review Assignments Review Sheets Notes Status Performance Measurement Admin Proposals
Reviewer: Select a Reviewer Return Review Sheet to Selected Reviewer Review Sheet Details
Important: Please read the following before
oroceeding.
i general scoring range of 0 to 5 points is provided for most technical review questions, except wher noted, and should be added to the first answer box after each question. These exceptions will consist of "Yes/No" questions, which are evaluated so that five points will be given for each "Yes" determination while "No" determinations will receive zero points (i.e., no other possible scores aside from zero or five points). Technical reviewer may provide comments for each question in the comment box provided.

Please note, character limit of some of the comments boxes was increased to anticipate detailed responses/justifications.

Project/Applicant Background - 55 Points Possible
1 Does the proposal provide the following to support and justify the project:
a An accurate and complete summary of other work completed to address the groundwater contamination and the relation of this project to other efforts?
Answer: 4
Answer: Briefly describes other efforts like limited groundwater pumping.

Accurate and complete regional and project maps depicting the site location, lateral and vertical extent of contaminated groundwater, location of production wells, location of any injection wells and area to be remediated?
Answer: 5
Answer: Had good maps and ran LIDAR to determine seawater intrusion. c A description of the groundwater basin, beneficial uses, and groundwater quality issues especially related to chemicals of concern (COCs) and their impact on drinking water sources? (Yes = 5 points, No = 0 points)
Answer: 5
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224126 1/6 3/8/23,2:15 PM Review Sheet Details
Answer:
d Accurate and complete identification of contaminant source area(s) associated with the project area? Answer: 5
Answer: Good delineation of seawater intrusion issues
e Accurate and complete summary of the data available on the COCs and any changes in the extent of the plume and COC levels over time?
Answer: 4
Answer: Yes they showed some seawater intrusion impacts from previous studies and what they'd found. f Description of consistency with any applicable groundwater management plan, court decree (for an adjudicated basin), salt and nutrient management plan, and other regulatory orders or requirements? Answer:

Answer: No responsible parties were identified for seawater intrusion 2 Does the proposal:
a Provide a complete description of the extent to which a search for responsible party(ies)/potentially responsible party(ies) has been conducted?
Answer:

Answer:
b Provide a complete and accurate description of the known responsible party/potentially responsible party(ies) in relation to the proposed project?
Answer: 0
Answer: Same as above
Project/Applicant Background - 55 Points Possible (Continued) 3 Has the applicant and its technical team (if identified) conducted similar projects and demonstrated an ability to complete projects on time and within scope and budget? Answer: 3
Answer: applicant does not have experience with GRRP. Technical team has experience in design. 4 How well is the project coordinated with cooperating entities such as; a water master (for adjudicated basins); federal, state, and local regulatory agencies; and any community organizations and is there documented support for the project from cooperating entities?* Answer: 2
Answer: AG and Grover are mentioned but it is not clear how they would benefit from the project. The extraction well belongs to Pismo Beach.
5 Does the applicant demonstrate the required technical, managerial, and financial (TMF) capacity necessary for successful long-term operation and maintenance (O&M) of the project?* Answer: 2
Answer: Not clear what the operation of advanced treatment, monitoring and injection well operation and water quality sampling will be or how it will be paid for.

Address one or more Proposition 1 prioritization criteria (Water Code section 79771 (b)(1-5) (see Guidelines Section 2.1)?*
Answer: 2
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224126 2/6 3/8/23, 2:15 PM Review Sheet Details
Answer: The nearest production well to this project is Pismo Beaches. Not clear how other NCMA or Santa Maria Groundwater Basin would benefit from the project. b Address the State Water Board requirements (see Guidelines Section 2.2)?* Answer: 2
Answer: Model shows very localized seawater protection and appears to benefit only a small piece of the coastline. I'm not clear how it benefits 200,000 people. 5 year budget includes 5000 customers which indicates Pismo Beaches customers are paying for the O&M. c Address one or more State Water Board preferences (see Guidelines Section 2.3)?* Answer: 2
Answer: Not clear how the entire NCMA will benefit or what their partnership currently is. Using advanced treated waste water, compliant with a groundwater recharge project, for a seawater barrier may not be the most econmical approach. The cost/benefit would be better if there was more of a direct water supply benefit, instead of the indirect benefit of a localized barrier. d Address a significant groundwater contamination problem based on best estimates of the anticipated project benefits (by prevention or cleanup of contamination)?* Answer: 3
Answer: Provides localized seawater intrusion relief but not clear on how many supply wells this is benefitting.
e Provide the lowest cost alternative for achieving the project purpose and adequately considered other alternatives?*
Answer: 2
Answer: High capital and O&M costs, small customer base. 7 Does the project include the use of new and innovative technology (or approaches)? (Yes = 5 points, No = 0 points)
Answer: 5
Answer:
8 Has the applicant estimated one or more of the metrics of success (see Guidelines Section 8) and are the estimates reasonable for the project? Are the goals and targets reasonable and feasible within the life of the project?*
Answer: 2
Answer: The model run demonstrating no project did not indicate the entire SMGB nor much of the NCMA would in a much better situation if the project were to be built. Models showed very localized improvements near the injection wells
Scope of Work - 40 Points Possible
9 Does the proposal include sufficient justification and provide:
a A detailed description of the technology and practices the project is proposing to use and adequate justification for the technical basis of the approach?* Answer: 4
Answer: Modeling and LiDAR imaging were used to show seawater intrusion impacts. Groundwater modeling for travel time of injected water. Complete inventory of domestic wells not demonstrated. b The supporting engineering calculations to demonstrate that the project will achieve its purpose?* Answer: 2
Answer: Model shows very localized seawater protection and appears to benefit only a small piece of the coastline. Unclear how it benefits 200,000 people.
c The detailed tasks and deliverables necessary to complete the project? https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetld=224126 3/6 3/8/23, 2:15 PM Review Sheet Details
Answer: 4
Answer: Complete a domestic well inventory and well drilling moratorium d Adequate technical justification that completion of the tasks are appropriate and necessary to achieve the project purpose?*
Answer: 4
Answer: Experienced technical team on the advanced treatment/injection. e Adequate and appropriate stakeholder involvement and include sufficient public outreach? Answer: 2
Answer: Very good public outreach. Involvement of stakeholders, other than Pismo Beach, is not clear. Not a lot of detail on the cost share agreement and JPA.
f An adequate description of how the proposed project is consistent with or is the appropriate next phase to address the contamination?
Answer: 3
Answer: Its designed like a groundwater recharge project that also provides some seawater intrusion relief. g A discussion on the required permits, environmental documentation California Environmental Quality Act (CEQA)/ National Environmental Policy Act [NEPAl), and landowner/access agreements required to implement the project?
(Yes = 5 points, No = 0 points)
Answer: 5
Answer:
h A description of the status of any design plans and specifications? (Yes = 5 points, No = 0 points) Answer: 5
Answer:

Schedule - 20 Points Possible
10 Does the proposal include a description of any key decision points, milestones, or deliverables that could impact project scope, cost, and schedule?
Answer: 4
Answer: Land acquisition.
11 Will the project be completed in a timeframe required for the next phase of the overall project, if applicable?
Answer: 4
Answer: After construction there will likely be some commisioning of the facility before injection 12 Does the proposal include a schedule that is consistent with and reasonable given the tasks described in the Scope of Work and the available budget?
Answer: 3
Answer: It's a very complex project with lots of permitting 13 Based on the proposed schedule and deliverables, can the project be completed within the appropriation timeframe?*
Answer: 3
Answer: It's a very complex project with lots of permitting Budget - 25 Points Possible
14 Do the summary budget table, narrative, and supporting cost documentation justify the project costs? Are the costs reasonable?*
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224126 4/6 3/8/23, 2:15 PM Review Sheet Details
Answer: 2
Answer: Very high capital and O&M costs over small customer base. 15 Are the tasks shown in the budget consistent with the tasks shown in the work plan and schedule? Answer: 3
Answer: Costs aren't fully known
16 Was a cost-benefit analysis provided justifying the proposed project relative to other feasible alternatives?*
Answer: 3
Answer: Some of the alternatives don't seem to address seawater intrusion. 17 Are the benefits significant given the cost of the project? Answer: 2
Answer: They don't appear to be significant given the cost and complexity of the project. 18 Does the proposal include leveraging of other funding sources (i.e., private, federal or local) and are the sources of matching funds clearly committed and well-documented? (Yes = 5 points, No = 0 points) Answer: 0
Answer: Brief mention of a cost sharing agreement that covers planning design and construction based on benefit to the member. Not clear on benefit amount or cost sharing for O&M.

Performance Evaluation and Monitoring - 15 Points Possible 19 Does the proposal include sufficient justification and provide a discussion of the proposed data collection and monitoring and how that data will be managed and reported? Answer: 4
Answer:
20 Will the measurement tools and methods effectively monitor project performance and target progress? Answer: 3
Answer: Water treatment measurement tools and monitoring description. Not clear how seawater intrusion impacts will monitored.
21 Is the proposed monitoring appropriate for the benefits claimed, and the process for which it will be tracked discussed?
Answer: 3
Answer: Much of the monitoring is for a groundwater recharge project to ensure downstream wells are not within project boundaries.

DAC/EDA - 20 Points Possible Bonus
Technical Reviewer need not answer the question below:

22. Does the implementation project, supported by the planning project proposal indicate project benefits to severely disadvantaged communities (SDACs)/ disadvantaged communities (DACs)/ economically distressed areas (EDAs) and are the anticipated benefits sufficiently justified?

23. Does the applicant provide sufficient documentation that the project is supported by SDACs/DACs/EDAs that are anticipated to benefit from the implementation project? Answer:

Answer:

Overall Review Comments: The project has a high capital cost and appears to benefit Pismo Beach's Well 22.

Limited improvement of seawater intrusion based on the no project model. Not clear on the regional benefits. © 2023 State of California. Conditions of Use | Contact Us | Privacy Policy. https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224126 5/6 3/8/23, 2:15 PM Review Sheet Details
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224126 6/6 3/8/23, 2:10 PM Review Sheet Details
Welcome Kira Smith of State Water Resources Control Board. If this is not your Account, please log Help | Logout Main Menu > Proposal Search > Review Sheet Details
Review Sheet Details
This page displays the selected review sheet details including each review questions and the review panels comments. To see the other review sheets of this proposal go back to the list and click on the required review sheet.

Pin No: 48162 - Central Coast Blue - ASSIGNED
Application Attachments | Eligibility Review Assignments Review Sheets Notes Status Performance Measurement Admin Proposals
Reviewer: Select a Reviewer Return Review Sheet to Selected Reviewer Review Sheel letail
Important: Please read the following before
•roceeaina.
\ general scoring range of 0 to 5 points is provided for most technical review questions, except wher noted, and should be added to the first answer box after each question. These exceptions will consist of "Yes/No" questions, which are evaluated so that five points will be given for each "Yes" determination while "No" determinations will receive zero points (i.e., no other possible scores aside from zero or five points). Technical reviewer may provide comments for each question in the comment box provided.

Please note, character limit of some of the comments boxes was increased to anticipate detailed responses/justifications.

Project/Applicant Background - 55 Points Possible
1 Does the proposal provide the following to support and justify the project:
a An accurate and complete summary of other work completed to address the groundwater contamination and the relation of this project to other efforts?
Answer: 5
Answer: See attachment 1. No other prevention or cleanup projects have been implemented in this area.

Applicant does outline other water supply projects/efforts, and includes documentation from seawater intrusion barrier feasibility studies.
b Accurate and complete regional and project maps depicting the site location, lateral and vertical extent of contaminated groundwater, location of production wells, location of any injection wells and area to be remediated?
Answer: 5
Answer: See attachment 1.
c A description of the groundwater basin, beneficial uses, and groundwater quality issues especially related to chemicals of concern (COCs) and their impact on drinking water sources? (Yes = 5 points, No = 0 points)
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224085 1/6 3/8/23, 2:10 PM Review Sheet Details
Answer: 5
Answer: See attachment 1.
d Accurate and complete identification of contaminant source area(s) associated with the project area? Answer: 5
Answer: The concern in the area is seawater intrusion. The applicant studied the salt/fresh water interface during planning activities, which can be seen in an attachment (the Aerial Geophysics TM). While the contaminant source area is well identified, the contamination issue itself is projected based on potential future changes in groundwater use.
e Accurate and complete summary of the data available on the COCs and any changes in the extent of the plume and COC levels over time?
Answer: 3
Answer: The summary refers to "previous studies" to support the applicant's conclusions, without sufficient discussion of the previous studies. Additionally, the maps depicting the change in groundwater conditions over time do not appear to be of the same area. f Description of consistency with any applicable groundwater management plan, court decree (for an adjudicated basin), salt and nutrient management plan, and other regulatory orders or requirements? Answer: 5
Answer: Yes, included description of consistency with the Central Coastal Basin Plan, the San Luis Obispo County 2019 Integrated Regional Water Management Plan, and the SWRCB Recycled Water Policy.
2 Does the proposal:
a Provide a complete description of the extent to which a search for responsible party(ies)/potentially responsible party(ies) has been conducted?
Answer: 5
Answer: The groundwater issue is seawater intrusion, and has no responsible party.

Provide a complete and accurate description of the known responsible party/potentially responsible party(ies) in relation to the proposed project?
Answer: 5
Answer: N/A
Project/Applicant Background - 55 Points Possible (Continued) Has the applicant and its technical team (if identified) conducted similar projects and demonstrated an ability to complete projects on time and within scope and budget? Answer: 5
Answer: See attachment 1. Public agencies have demonstrated abilities to complete grant projects on time and within scope and budget. Technical consultants have participated in the planning, engineering, and implementation of similar projects.

How well is the project coordinated with cooperating entities such as; a water master (for adjudicated basins); federal, state, and local regulatory agencies; and any community organizations and is there documented support for the project from cooperating entities?* Answer: 4
Answer: Applicant demonstrates good coordination with cooperating entities, including regional public agencies and the groundwater basin management area. Letters of support provided from local public agencies, cooperating entities, and elected federal officials. Some of the support letters are regarding other funding sources, focusing on the water recycling elements of the project. These do demonstrate good support for the project as a whole, but may not justify the use of this program funding.
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetld=224085 216 3/8/23, 2:10 PM Review Sheet Details
Does the applicant demonstrate the required technical, managerial, and financial (TMF) capacity necessary for successful long-term operation and maintenance (O&M) of the project?* Answer: 5
Answer: Applicant provided necessary TMF form, and supporting documents for TMF capacity.

Program Priorities, Requirements, and Preferences - 35 Points Possible Does the proposal, including the identified project goals and purpose, provide sufficient justification that the project, as described:

Address one or more Proposition 1 prioritization criteria (Water Code section 79771(b)(1-5) (see Guidelines Section 2.1)?*
Answer: 5
Answer: Yes, see attachment 3.
b Address the State Water Board requirements (see Guidelines Section 2.2)?* Answer: 3
Answer: The project may enhance groundwater quality and basin protection through recycled water injection. It may not prevent the contamination of groundwater in a significant way. The 40-year modeling projects a benefit to one production well. There is a claim that because the Round 1 planning project was deemed high priority by DFA, this implementation project would also be high priority; while this project is informed by the planning project, the importance of each was evaluated independently.
c Address one or more State Water Board preferences (see Guidelines Section 2.3)?* Answer: 4
Answer: Several preferences addressed. The project can be completed in time frame and will benefit the groundwater supply of the area, which will support the human right to water. Preference b- community benefit - is not well demonstrated. The alternatives studied do have community or basin benefits, but do not address the contamination or do not consider the project area. d Address a significant groundwater contamination problem based on best estimates of the anticipated project benefits (by prevention or cleanup of contamination)?* Answer: 2
Answer: By the modeling, the seawater intrusion in the next 40 years does not have a significant impact on more than one production well. The proposed project does protect that one well, but only if pumping is increased significantly. There is no cleanup in this project. e Provide the lowest cost alternative for achieving the project purpose and adequately considered other alternatives?*
Answer: 2
Answer: See attachment 8. The alternatives explored do not attempt to address the prevention/cleanup of contamination or do not consider the project area.
7 Does the project include the use of new and innovative technology (or approaches)? (Yes = 5 points, No = 0 points)
Answer: 5
Answer: IDE RO technology
8 Has the applicant estimated one or more of the metrics of success (see Guidelines Section 8) and are the estimates reasonable for the project? Are the goals and targets reasonable and feasible within the life of the project?*
Answer: 3
Answer: Metrics of success are well detailed, but the claimed benefits are not well supported by the documentation. It is unproven that the proposed project will benefit the entire basin. Other benefits https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetld=224085 3/6 3/8/23, 2:10 PM Review Sheet Details
apply only if conditions change (pumping increases, etc.) Scope of Work - 40 Points Possible
9 Does the proposal include sufficient justification and provide:
a A detailed description of the technology and practices the project is proposing to use and adequate justification for the technical basis of the approach?* Answer: 5
Answer: See attachment 4 and supporting attachments; the technology and practices are both outlined and detailed.
b The supporting engineering calculations to demonstrate that the project will achieve its purpose?* Answer: 3
Answer: Calculations support the efficacy of the AWPF, including quantity/quality of treatment and discharge. Calculations for the test injection well also included, supporting the efficiency claims of proposed injections wells. The completed modeling does not adequately demonstrate that the project will meet its purpose of preventing the spread of contamination. In the 40-year modeling scenario, one existing production well benefits from the proposed injection well barrier. c The detailed tasks and deliverables necessary to complete the project? Answer: 5
Answer: Tasks are well outlined. See attachment 4.

Adequate technical justification that completion of the tasks are appropriate and necessary to achieve the project purpose?*
Answer: 5
Answer:
• Adequate and appropriate stakeholder involvement and include sufficient public outreach? Answer: 5
Answer:
f An adequate description of how the proposed project is consistent with or is the appropriate next phase to address the contamination?
Answer:

Answer: Phase 2 of the project is discussed in several attachments. Phase 1, the proposed implementation project, is consistent with Phase 2. However, it is unclear if phase 2 addresses the contamination. g A discussion on the required permits, environmental documentation California Environmental Quality Act (CEQA)/ National Environmental Policy Act [NEPAl), and landowner/access agreements required to implement the project?
(Yes = 5 points, No = 0 points)
Answer: 5
Answer:
h A description of the status of any design plans and specifications? (Yes = 5 points, No = 0 points) Answer: 5
Answer:

Schedule - 20 Points Possible
10 Does the proposal include a description of any key decision points, milestones, or deliverables that could impact project scope, cost, and schedule?
Answer: 3
https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224085 4/6 3/8/23, 2:10 PM Review Sheet Details
Answer: This is not addressed directly. There are discussions of permitting times, construction costs, and land acquisition.
11 Will the project be completed in a timeframe required for the next phase of the overall project, if applicable?
Answer: 3
Answer: Next phase is estimated to begin in 2025. While the schedule suggests completion of field activities in that time, due to permitting it seems that this will be delayed. 12 Does the proposal include a schedule that is consistent with and reasonable given the tasks described in the Scope of Work and the available budget?
Answer: 5
Answer:
13 Based on the proposed schedule and deliverables, can the project be completed within the appropriation timeframe?*
Answer: 4
Answer: Most likely, although permitting times are uncertain. The applicant appears to include a buffer for permitting times, but this may not be sufficient.

Budget - 25 Points Possible
14 Do the summary budget table, narrative, and supporting cost documentation justify the project costs? Are the costs reasonable?*
Answer: 5
Answer: See attachment 7 and supporting documents. Applicant provides estimate memos. 15 Are the tasks shown in the budget consistent with the tasks shown in the work plan and schedule? Answer: 5
Answer: Budget, schedule, and scope of work are consistent. 16 Was a cost-benefit analysis provided justifying the proposed project relative to other feasible alternatives?*
Answer: 4
Answer: Cost-benefit analysis was provided, and the alternatives were discussed in sufficient detail.

However, by admission, not all alternatives address the contamination issue, which is integral to this program funding
17 Are the benefits significant given the cost of the project? Answer: 1
Answer: Water recycling and supply benefits of this project are significant. However, significant benefits related to cleanup or prevention of contamination of groundwater are not well demonstrated.

Based on the modeling, at least one production well may be protected from seawater intrusion in the next 40 years if the project is implemented, but this assumes that local pumping will increase substantially. Under current conditions, it is not clear that significant seawater intrusion would occur.
18 Does the proposal include leveraging of other funding sources (i.e., private, federal or local) and are the sources of matching funds clearly committed and well-documented? (Yes = 5 points, No = 0 points) Answer: 5
Answer: Applicant will provide more than 50% to the water recycling elements of the project, so they are leveraging other funding sources. Sources of funding are summarized: for non-construction costs, Pismo Beach, Arroyo Grande, and Grover Beach have budgeted for the costs of CCB through 2025 (water rate income). Construction costs will be funded by CWSRF loan that will be repaid https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetId=224085 5/6 3/8/23, 2:10 PM Review Sheet Details
over 30 years, split based on the benefit to each agency: Arroyo Grande - 25%; Grover Beach - 36%; and Pismo Beach - 39%.

Performance Evaluation and Monitoring - 15 Points Possible 19 Does the proposal include sufficient justification and provide a discussion of the proposed data collection and monitoring and how that data will be managed and reported? Answer: 5
Answer: CCB will use monitoring data from the NCMA monitoring network. This includes the monitoring of groundwater levels in 50 wells on a semiannual basis, as well as monitoring groundwater elevations and groundwater quality on a quarterly basis in coastal and inland wells. Over 20 constituents are analyzed quarterly, including TDS, chloride, and nitrates. NCMA publishes an annual monitoring report, and the proposed project would provide additional reporting. 20 Will the measurement tools and methods effectively monitor project performance and target progress? Answer: 5
Answer:
21 Is the proposed monitoring appropriate for the benefits claimed, and the process for which it will be tracked discussed?
Answer: 5
Answer:

DAC/EDA - 20 Points Possible Bonus
Technical Reviewer need not answer the question below:

23. Does the applicant provide sufficient documentation that the project is supported by SDACs/DACs/EDAs that are anticipated to benefit from the implementation project? Answer: 0
Answer: The applicant indicates that work will benefit a DAC. However, based on the DFA analysis of the City's MHI, as well as the potential benefit to nearby communities, the City does not sufficiently benefit a DAC.

Additionally, the applicant did not request a reduction in the match requirement.

Overall Review Comments: Per the Groundwater Grant Program guidelines, this funding is for projects that prevent or cleanup the contamination of groundwater that serves or has served as a source of drinking water. While the proposed project has significant local benefits as a water recycling and groundwater basin enhancement project, th revention of seawater intrusion contamination is not well demonstrated in the provided documents. Based on th modeling scenarios, one local production well will be protected by the proposed injection well barrier, in over 30 years, if pumping increases.
© 2023 State of California. Conditions of Use | Contact Us | Privacy Policy. https://faast.waterboards.ca.gov/Proposal_Mgmt/StaffPropReviewSheetDetails.aspx?AnsSheetld=224085 6/6

Grover Beach City CouncilJune 5, 2023

Grover Beach City Council
June 5, 2023