Monterey City Council
September 19, 2023

1-1 of that document explains in part:

Fort Ord obtains all of its water for use in its potable water system from the Salinas Valley groundwater basin. Concentrations of chlorides (salts) in groundwater have increased in the Fort Ord and Marina areas resulting in the abandonment or deepening of many wells. These increases in chloride concentrations are attributable to seawater intrusion, resulting from groundwater overdraft. [¶] Seawater intrusion has resulted because of a reversal in natural groundwater flow. The coastal groundwater aquifers of the Salinas Valley groundwater basin are hydraulically continuous with the ocean. In its natural state, freshwater migrates seaward.

When the pumping rate of these aquifers exceeds the rate of natural replenishment (overdraft), the seaward movement of the freshwater reverses and seawater fills in the aquifer behind the receding freshwater. By 1985, seawater intrusion in the 180-foot aquifer was overlain by 16,000 acres of land, and intrusion into the 400-foot aquifer was overlain by 6,700 acres (Figure 1-1 ); seawater has been proceeding inland at a rate of 150 acres per year in the 180- and 400-foot groundwater aquifers in the Marina and Fort Ord area (Jones & Stokes Associates 1990).

This seawater intrusion was most responsible for rendering water from 14 on-post wells unusable. Wells 24, 27, and 28, located near Fritzsche Army Airfield (Fritzsche Airfield), also are contaminated with lead and carbon tetrachloride. Wells 27 and 28 were abandoned, and well 24 is on standby active status; however, water from well 24 is used only to supply peak demands because its water must be blended with water from wells 29-32 to be potable. (EA Engineering, Science, and Technology 1991)
Response 9.17
The commenter states that in the mid-1980s, water problems at Fort Ord included finite groundwater supply, seawater intrusion, overdrafting, and supply reliability.

This comment does not pertain to the Draft EIR or WSA. Please refer to Response 9.2 and Response

9.5 regarding seawater intrusion and to the Water Master Response. As noted therein, although “Seawater intrusion has driven groundwater management in the greater Salinas Valley Basin and the Monterey Subbasin for more than seventy years,” “MCWRA, in coordination with other local agencies, has since developed additional efforts to combat seawater intrusion, including the Castroville Seawater Intrusion Program that delivers recycled and seasonal flows diverted from the Salinas River for irrigation in lieu of pumped groundwater.” Seawater intrusion is not an immediate threat to MCWD’s groundwater supplies because “MCWD pumps groundwater from wells in the 400-foot (from the four inland Ord Community wells) and 900-foot (from one Ord Community well and three Central Marina wells) Aquifers.” Moreover, additional groundwater management for the Monterey Subbasin will be set forth by 2022 pursuant to SGMA. SGMA requires that the 3-129 Attachment A
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groundwater sustainability plans developed for the Monterey Subbasin control “significant and unreasonable” seawater intrusion by 2040 (see Water Code § 10721(x)(3) (2019)).

Please see Response 9.16 for a discussion of MCWD’s efforts to ensure the sustainability of groundwater supplies. Revisions to the Draft EIR are not required in response to this comment.

Response 9.18
The commenter states the opinion that the Draft EIR does not adequately consider water extraction impacts and long-term sustainability of pumping. The commenter states that multiple Army wells went dry or turned salty, and the Draft EIR did not fully analyze impacts of pumping at 6,600 AFY.

Please refer to Response 9.2 and Response 9.15 regarding the 6,600 AFY allocation. The commenter’s claim that the Proposed Project would take 6,600 AFY from the Deep Aquifer is false.

As stated in the Draft EIR Appendix M1: “The 6,600 acre-feet per year amount includes 5,200 acrefeet from the 180-foot and 400-foot aquifers, along with 1,400 acre-feet per year from the 900-foot or Deep Aquifer.” See Response 10.17 for a discussion of groundwater pumping from the Deep Aquifer. Detailed groundwater data, including seawater intrusion figures and groundwater elevation hydrographs, can be found in Chapter 5 of the Salinas Valley Basin Integrated Sustainability Plan. A link to this plan is provided in Response 9.5.

Finally, CEQA “does not require a city or county, each time a new land use development comes up for approval, to reinvent the water planning wheel” (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 434). The Draft EIR and the WSA for the Project properly rely on existing studies of long-term water supplies on a region-wide level. The information included in the Draft EIR is sufficient for the purposes of the analysis.

Response 9.19
The commenter claims that Table 5-2 in the WSA is misleading and inconsistent with public records, including the amount of water allocated to the Main Gate project, Monterey College of Law, Monterey Peninsula College, and City of Seaside.

FORA water allocations/water consumption, including the Main Gate project and MPUSD, can be found in FORA’s 2017-2018 Annual Report.6
Regarding the Main Gate project, please see Response 14.1. As discussed therein, while the Main Gate Specific Plan (i.e., development regulations) was approved approximately 10 years ago, no specific project entitlements were issued. FORA’s 2017-2018 Annual Report notes that while Main Gate’s WSA included a total of 207 AFY, only 149 AFY has been actually allocated (refer to the FORA Annual Report for Fiscal Year 2018-19, available online at https://www.fora.org/Reports/AR/AnnualReport2019-Full.pdf). The EIR for that project analyzed gross square footage ranging from approximately 775,000 square feet to 843,500 square feet, however the City issued a RFP for less than maximum buildout (i.e., only 650,000 square feet)7 (see Save Round Valley Alliance v. County of Inyo (2007) 157 Cal.App.4th 1437 [holding the Draft EIR did not need to assume second dwelling unit [theoretical build-out] would be constructed even though allowed by zoning]).
6 https://www.fora.org/Reports/AR/AnnualReport2019-Full.pdf 7 As explained in the 2016 Main Gate request for proposal “[t]he City has also committed sufficient potable water for development of approximately 650,000 square feet of commercial building space on the site.” 3-130
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The commenter alleges that the Monterey College of Law has actually been allocated 2.8 AFY, but cites to no evidence to support such assertions. The Monterey College of Law has been allocated 2.6 AFY per “Allocation reso. 04-20,” as shown in FORA’s 2017-2018 Annual Report. The Draft EIR properly relies upon the numbers found in FORA’s 2017-2018 Annual Report. This figure is also supported by MCWD Resolution 2009-46, noting an allocation 2.575 AFY of water to the Monterey College of Law.8 Furthermore, as shown in the annual report, water consumption has been significantly less than this allocation, i.e., only 0.49 AFY.

The commenter claims that FORA records show that the Monterey Peninsula Unified School District (“MPUSD”) has been allocated or is using 100 AFY, but provides no evidence to support such assertions. The WSA conservatively assumes an 81 AFY water allocation for Monterey Peninsula Unified School District. FORA's 2017-2018 Annual Report states that MPUSD’s actual consumption was 28 AFY in the 2017/2018 annual report. No official allocation for MPUSD has been issued, but the UWMP, Draft EIR and WSA conservatively estimates 81 AFY, which is significantly higher that MPUSD’s 2017/2018 consumption and its historic water use (Appendix M, Table 3-2).

Monterey Peninsula College’s (MPC) allocation is listed as 9.0 AFY in the WSA. However, FORA's 2017-2018 Annual Report states that this allocation is actually 9.7 AFY. The commenter is correct that the water allocation for MPC is Seaside Resolution No 09-36 is 9.7 AFY rather than 9.0 AFY. As shown in the FORA Annual Report cited above, the MPC water use was 0.26 AFY. (i.e., significantly less than its water allocation). Nevertheless, the Draft EIR text and Mitigation Measure UTIL-1 has been updated to reflect this change and to increase Mitigation Measure UTIL-1’s water offset by 0.7 AFY. See Section 4, Amendments to the Draft EIR. The commenter also states “The DRAFT EIR WSA fails to disclose Seaside’s water allocation has been increased at least twice by FORA.” The existing Seaside allocation from the 6,600 AFY is correctly described on Draft EIR page 4.9-26.

Response 9.20
The commenter states that the existing MCWD desalination plant is not likely to be reopened or to provide water to the Project.

Please refer to Response 9.10 regarding desalinated water supply. Section 4 of the Draft EIR Appendix M characterizes MCWD’s existing water infrastructure, including the currently deactivated desalination facility. This section does not suggest the Proposed Project would utilize water produced at the facility; rather, it addresses the operational status of the plant and discloses the existing 2006 agreement.

Response 9.21
The commenter claims that the Draft EIR omits discussion of recycled water as a diminishing resource as water conservation increases. The commenter expresses the opinion that impacts of water conservation trends have not been adequately investigated, disclosed, identified, and mitigated. In addition, the commenter claims that recycled water allocations in Table 5-1 of the WSA are not accurate. The commenter states the opinion that the Project may not be able to use recycled water, and suggests that this possibility is not analyzed or mitigated. Lastly, the commenter states that the Draft EIR makes unreasonable assumptions about desalinated water, as a new desalination plant has not been approved.
8 Available at: https://www.mcwd.org/docs/resolutions/2009-46.pdf 3-131 Attachment A
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Please refer to the Water Master Response and Response 9.13. As noted therein, through the Pure Water Delivery and Supply Project agreement entered into by MCWD and M1W on April 8, 2016, MCWD secured up to 1,427 AFY of future recycled water supplies needed for the Ord Community.

The commenter expresses the concern that increasing water conservation efforts will diminish recycled water supplies available for the Proposed Project. However, as water conservation efforts increase, the demand for traditional water supplies such as groundwater would decrease.

Furthermore, as shown in Figure 4.18-2 of the Final EIR for the Pure Monterey Water project,9 the Regional Treatment Plan received between 20,000 and 25,000 AFY of wastewater, which is substantially less than the amount of recycled water produced by Pure Water Monterey project. As discussed in the 2016 Pure Monterey project Final EIR, “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 project could provide up to 5,900 acre feet per year for crop irrigation.” In fact, revisions have been proposed to expand recycled water treatment capacity by an additional 2,250 AFY, as a backup plan in the event that desalination facilities are delayed.10 System-wide, water conservation would not adversely impact the availability of MCWD water supplies for the Proposed Project.

As discussed in detail in the Draft EIR Appendix M, the Advanced Water Purification Facility is currently being constructed, with a design capacity of 5.0 million gallons per day. The Phase 1 Recycled Water Project will have an initial yield of 4,100 AFY, of which 600 AFY would be available to MCWD. The commenter asks for the explanation behind the assumption that 453 AF of recycled water will be available to Seaside. As discussed, the City of Seaside has an allocation of 453 AFY from the Phase 1 Recycled Water Project. Future phases of the Project will increase MCWD’s yield to 1,427 AFY. As noted in the Draft EIR Appendix M, the Proposed Project would use up to 45.83 AFY of recycled water. The Proposed Project’s use of recycled water is mandated by the Specific Plan Section 5.2.2.

Please see Response 9.10 and Response 9.14 regarding desalinated water supplies.

Response 9.22
The commenter states the Draft EIR does not disclose that new, deeper wells have been drilled on Armstrong Ranch since 2017, and is extracting thousands of AFY. The commenter states the Draft EIR does not disclose and analyze the Reuse Plan requirement that Seaside and FORA monitor residential development to ensure demand does not outstrip supply of employment-generating uses, and the Draft EIR does not disclose cumulative impacts related to this.

The commenter appears to be referring to litigation between MCWD and the County of Monterey related to environmental review for new well permits for Armstrong Ranch (i.e., whether County well permits are discretionary or ministerial). The Draft EIR page 4.16-3 noted that “there are Deep Aquifer wells serving the Monterey Dunes Colony (120 homes) and the Armstrong Ranch…” The Draft EIR made reasonable assumptions about future cumulative water demand, including demand associated with Armstrong Ranch, which is located outside of Fort Ord. (Appendix M1, Table 3-3.) 9 Pure Monterey Water 2016 Final EIR: https://purewatermonterey.org/wp/wp-content/uploads/Volume-I-Consolidated-Final-EIR-Jan2016.pdf 10 Notice of Availability of the Draft Supplemental EIR for Proposed Modifications to the PWM/GWR Project:
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The comment also asserts “The DRAFT EIR fails to disclose that the Project would cause cumulative impacts and would cause the residential development at Fort Ord to further outstrip the available supply of employment-generating uses. This is true in any event, and the impacts would be worsened by the Project’s proposed phasing of developing residential uses first. The DRAFT EIR fails to mitigate for those foreseeable impacts.”
Please refer to Response 10.4 regarding the housing cap set by FORA for development on former Fort Ord lands. Please also see Response 13.8 for discussion of project phasing. The EIR does not state that it phases “residential uses first;” Campus Town Phase 1 includes non-residential development (Draft EIR Table 2-4). Please see Response 9.19 for discussion of FORA’s annual report, which includes water consumption. Furthermore, it is the purpose of the EIR to analyze the impacts of the Proposed Project, not to implement every measure contemplated by FORA’s BRP. For discussion of planning consistency, please see Draft EIR Section 4.10. Please see Response 9.2 and Draft EIR Sections 4.9 and 4.16, and Draft EIR Appendix M1 for discussion of water supply reliability.

Please also refer to the Water Master Response. As noted therein, the Water Supply Assessment analyzes the availability of water supplies.

Response 9.23
The commenter states the 6,600 AFY agreement is not permanent, and the Draft EIR fails to explain this, or that a new water supply was originally envisioned. The commenter asks how close seawater intrusion is to groundwater wells (including Central Marina wells) proposed to supply Project water.

The commenter requests disclosure of MCWD well risk of salt water intrusion and wells that pump from the Deep Aquifer, as well as related impacts on Project water supply.

Please refer to Response 9.2 and the Water Master Response. The commenter also asserts that “No new [water] project has taken its place.” As also explained in Response 9.13, Response 9.14, and Response 9.21, the EIR and the WSA both expressly discussed new water supply projects. As additionally noted, the Draft EIR identifies a potentially significant impact related to seawater intrusion if the Project’s water demands are not mitigated. Mitigation Measure UTIL-1 identifies a number of offset and in-lieu storage programs to offset the water demands of the Proposed Project.

Please also refer to Response 9.5 and the Water Master Response regarding seawater intrusion.

Response 9.24
The commenter states that recharge only accrues in shallow aquifers and is not available to Deep Aquifer wells. The commenter claims that the Army has acknowledged that average pumping exceeds safe yield, and any increase in water use could impact sustainability of the aquifer.

The Draft EIR incorporates by reference MCWD’s 2015 UWMP, which discusses in detail the status of the Deep Aquifer and its recharge rates. Please see Response 9.2 and Response 9.16, which summarizes the MCWD’s efforts to ensure the long-term sustainability of its groundwater supplies and historic water supply information. Please refer to the Water Master Response regarding water rights to underlying groundwater. This comment does not address the Draft EIR or CEQA process.

Response 9.25
The commenter questions the assumption that Seaside will give all its remaining water allocation to the Project, and asks if Seaside has agreed to this, what the impacts are, and how this would affect 3-133 Attachment A
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jobs and housing. The commenter suggests that the EIR include a mitigation that prohibits development until non-potable water supply is available through existing infrastructure.

The Draft EIR was prepared by the City of Seaside. Approval of the Project requires that the Project secure required water supplies before operation and prior to the issuance of a final map. More specifically Mitigation Measure UTIL-1 expressly states “Prior to issuance of a final map, the City shall demonstrate the offset of 261 AFY of potable water based upon available programs, and the applicant shall obtain written verification from MCWD that sufficient water supplies have been secured.”
See Response 9.2 for discussion of the 6,600 AFY allocation. The decision to approve the Proposed Project, an alternative, or a variation thereof will be made by the Seaside City Council.

Response 9.26
The commenter requests supporting documentation for the claim that MCWD’s groundwater supply is considered reliable. The commenter asks if MCWD has a right to produce recycled water and requests details. The commenter asks if MCWD would need to construction storage facilities for recycled water and requests details.

See Draft EIR Section 4.9, Section 4.16, and Appendix M1, and the UWMP for discussion of reliability and supporting documentation. Please also refer to the Water Master Response and the long-term water management planning documents referenced therein. Please also see Response 9.13, Response 9.14, and Response 9.21 for discussion of recycled water and new water supply projects and associated infrastructure and environmental documentation, and citations in the EIR and WSA where these projects were discussed.

Response 9.27
The commenter first alleges that the Draft EIR does not adequately analyze and mitigate impacts to views from the Fort Ord National Monument, which the commenter states was not designated as such at the time of the BRP EIR analysis. The commenter also alleges that impacts to views (i.e., Impact AES-1) should be considered significant because “the project area can be seen from multiple locations on the National Monument.” And requests “all [view] impacts to Fort Ord National Monument must be analyzed.”
The commenter’s opinion (1) is not supported by the scenic vista methodology in the EIR, (2) does not accurately reflect existing conditions, and (3) ignores the provisions of CEQA which require impact conclusion upon a comparison to existing conditions. Furthermore, it is not feasible nor does CEQA require an analysis of every geographic location, from different viewing angles, and from different viewing heights (CEQA Guidelines Section 15204(a)).

Section 4.1.3 of the Draft EIR provides an analysis of potential impacts related to aesthetics and visual resources. Impacts were determined to be less than significant with no mitigation required.

Formal designation of an area does not have any effect on the Draft EIR’s impact analysis, and the Draft EIR acknowledged that the area had been designated (Draft EIR Section 3.2). This type of argument has also been rejected by the Courts (Fund for Environmental Defense v. County of Orange (1988) 204 Cal.App.3d 1538 [A change in land use designations (i.e., new park designation) does not constitute a change in the environmental setting]).

The commenter’s opinion is also not supported by the scenic vista methodology/definition; as discussed in Draft EIR Section 4.1.1(e):
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Scenic vistas are viewpoints that provide an expansive/panoramic view of a large geographic area for the benefit of the public. Furthermore, panoramic views provide visual access to a large geographic area for which the field of view can extend into the distance… Most of the scenic views and vistas in Seaside are oriented toward Monterey Bay and do not overlook former Fort Ord lands east of General Jim Moore Boulevard. Figure 4.1-1 shows one scenic viewpoint on the CSUMB campus with westerly views towards Monterey Bay, and southwesterly views towards the Plan Area. Topographical variation and existing buildings obstruct visibility of the Plan Area from this scenic viewpoint. No other scenic viewpoints are near the Plan Area. [Emphasis added.]
The closest portion of the Fort Ord National Monument11 is located approximately 1.5 miles east/southeast of the Plan Area. The Plan Area from the Fort Ord National Monument is generally not visible because of the oak woodlands and shrubbery, as can be seen from the closest points from the National Monument facing west (refer to Figure 1 below). Furthermore, even if limited views were available, they would not meet the definition of scenic vista described above. 11 Fort Ord National Monument Map: https://www.blm.gov/sites/blm.gov/files/documents/files/program-nlcs-california-fort%20ordtrail-map.pdf. 3-135 Attachment A
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Figure 1 Views of the Plan Area
Photograph 1. View from the closest point for the Fort Ord National Monument facing the Plan Area.

Photograph 2. Distant view facing the plan area from Watkins Gate Road to the southeast.

Photograph 3. Distant view facing the Plan Area from Hennekens Ranch Road to the southeast.

Source: Google.com photos by Demian Ford
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The comment also ignores that impacts are based upon a comparison to baseline conditions. As discussed in Draft EIR Section 4.1.1, “the Plan Area is developed with extant buildings, including former barracks, administration facilities, and parking lots, originally part of the Fort Ord base...

These buildings are now mostly vacant and dilapidated, and many have been vandalized.” As discussed in greater detail under Impact AES-3, the Project proposes a number of improvements to baseline conditions.

The commenter also states the Draft EIR does not present the total number of trees that would be removed as part of the Project, or quantify the number of oaks in Figure 4.3-1.

The level of detail for baseline conditions is controlled by CEQA Guidelines Section 15125(a), which explains that “The description of the environmental setting shall be no longer than is necessary to provide an understanding of the significant effects of the proposed project.” The information requested by the commenter was not necessary to analyze the impacts of the Proposed Project. The Draft EIR, pages 4.3-1 and 4.3-2, provided a detailed overview of the existing oak trees, including a detailed map of these areas. The Draft EIR (page 4.3-1) further explained:

Within the Plan Area, this vegetation community is largely degraded by fragmentation as a result of prior development and disturbance. Ice plant (Carpobrotus spp.) mats have invaded the understory and homeless encampments have resulted in significant degradation to the woodland including the general poor health of the trees.

The largest and least disturbed patch of coast live oak woodland occurs southwest of the Lightfighter Drive and General Jim Moore Boulevard intersection. This patch is approximately nine acres and is consistent with a live oak… Along the western edge, ice plant is creeping in and overtaking the herbaceous layer. Additionally, a number of trees were observed in this patch with sapwood decay fungus (Hypoxylon thouarsianum); this fungus typically infects diseased and dying trees…In total, approximately 14.14 acres of coast live oak woodland occur within the Plan Area.

The EIR further determined under Impact BIO-2 that “A small remnant stand of oak woodland is present on the western end of the Plan Area (see Figure 4.3-1), but is isolated from open expanses of oak woodland and scrub habitat to the east on the former Fort Ord, and is largely degraded by fragmentation and disturbance. As such, this area is not considered a sensitive natural community.” Nevertheless, an Arborist Report was prepared by HMH, which included an inventory of 891 trees within the Plan Area, with the majority identified as coast live oak (619 trees). This report is included as Appendix O to this document.

The following text was added to Section 4.3.1(a), page 4.3-3 of the Draft EIR to include information from the Arborist Report:

In total, approximately 14.14 acres of coast live oak woodland occur within the Plan Area.

Tree Survey
An Arborist Report was prepared by HMH, dated October 4, 2019; which included an inventory of 891 trees within the Plan Area. The following trees were observed: Coast Live Oak (Quercus agrifolia, 619 total trees), Monterey Cypress (Cupressus marcocarpa, 86 total trees), Blue Gum (Eucalyptus globulus, 62 total trees), Monterey Pine (Pinus radiata, 61 total trees), Torrey Pine (Pinus torreyana, 35 total trees), Blackwood Acacia (Acacia melanoxylon, 9 total trees), Red Gum (Eucalyptus ficifolia, 9 total trees), Fan Palm (Washingtonia filifera, 7 total trees), Myoporum (Myoporum laetum, 2 total trees), and Indian Laurel Fig (Ficus microcarpa, 1 total tree). 3-137 Attachment A
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The changes reflected above would not result in alterations to the degree of impact or significance conclusions presented in the Draft EIR, and therefore do not constitute “significant new information” requiring Draft EIR recirculation under CEQA Guidelines Section 15088.5. Rather, the changes serve to clarify and amplify the content of the EIR.

Response 9.28
The commenter states that the Draft EIR does not identify a mitigation location for Oak Woodland.

The commenter does not accurately discuss the contents of the EIR. The Draft EIR, under Impact BIO-5 explained how the trees would be replaced on site. Since preparation of the Draft EIR, additional off-site tree replacement options have been proposed, as described in the revised text from Draft EIR page 4.3-26:

The Proposed Project retains a portion of one of the areas with coast live oak trees within the Plan Area (approximately 1.5 acres), located directly west of General Jim Moore Boulevard, and designates this location as a “tree save” park. However, the Proposed Project includes the removal of approximately 12.64 acres of oak trees, which as noted above under the environmental setting are degraded and fragmented. While the Proposed Project includes the removal of existing trees in the Plan Area, the Proposed Project also provides for the incorporation of new trees in its thoroughfare regulations (Specific Plan Section 3.3), its parking standards (Specific Plan Section 4.7.14), and its landscape regulations, which include coast live oak, and requires replacement of coast live oak and Monterey Cypress trees, and requires replacement of coast live oak trees and Monterey Cypress trees at a ratios described below of 1:1.5 (Specific Plan Section 3.5). Specific Plan Figures 2.2, 2.10, and 3.25 provide plans for new trees within the Plan Area as well as Arborist Report, Exhibit B.

Existing Coast Live Oak trees recommended for preservation (as identified by the criteria in the Arborist Report) that have a height of 10 feet or more, or a circumference of 20 inches or more measured 24 inches above the ground that are removed as part of construction shall be replaced (i) at a ratio of 1:1 within the Plan Area or (ii) at a ratio of 1:5.0 at an off-site location approved as part of a Conformance Determination for any Development Application, in either case unless a finding is made pursuant to Section 6.3.1A of this Specific Plan that preservation is not feasible due to the health of the tree (including disease or pests). The size of each replacement tree shall be a 15-gallon or larger Coast Live Oak tree meeting American Standards for Nursery Stock (ANSI Z60.1) having 1” – 1 1/4” minimum caliper and average height of six to eight feet measured from the base. Trees replaced off-site shall be planted in open space areas for oak forest naturalization from tree pots that have been propagated from the Fort Ord / Marina area.

Existing Monterey Cypress trees recommended for preservation that have a circumference of 20 inches or more measured 24 inches above the ground that are removed as part of construction shall be replaced at a ratio of 1:1.2 within the Specific Plan Area or at an off-site location approved as part of a Conformance Determination for any Development Application, in either case unless a finding is made pursuant to Section 6.3.1A of this Specific Plan that preservation is not feasible due to the health of the tree (including disease or pests). The size of each replacement tree shall be a 15-gallon or larger Monterey Cypress tree, meeting American Standards for Nursery Stock (ANSI Z60.1) having 1” – 1 1/2” minimum caliper and average height of six to eight feet measured from the base.
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Up to 619 Coast Live Oak trees recommended for preservation would be removed.

Approximately 335 replacement Coast Live Oak Trees could be planted on site, on locations within the Plan Area designated as public open space. Assuming that none of the trees to be removed are found infeasible to preserve due to health,12 the remaining 284 Coast Live Oak trees to be removed which cannot be replaced on-site would be replaced off site at the 1:5 replacement ratio, for a total of 1,420 off-site replacement Coast Live Oak trees. It is anticipated that off-site tree replacement would occur on the 72-acre City-owned property located south of the Plan Area (bounded by Parker Flats Cut Off Road to the south and west, existing development to the northwest and north, and Gigling Road to the north) or another location approved by the City that can accommodate the required number of trees to be planted, has soil characteristics conducive to tree growth, and does not contain excessive amounts of utility lines that would interfere with root development, in order to ensure the replanted trees have a high success rate. Up to 86 Monterey Cypress trees recommended for preservation would be removed, and all replacement Monterey Cypress trees could be planted on site as street trees or at an off-site location at a ratio of 1:1.2. The actual number of Coast Live Oak and Monterey Cypress trees recommended for preservation that need to be removed and replaced, the actual number that can be replaced on-site, and the location of off-site replacement, will be determined at the time of each Development Application.

As described in Response 9.27, an Arborist Report was prepared (HMH 2019), which included an inventory of 891 trees within the Plan Area, with the majority identified as coast live oak (619 trees).

The Specific Plan has been updated to require tree replacement ratios for coast live oaks of 1:1 that are replaced within the Plan Area and for any trees that cannot be replaced on-site, will be replaced offsite at a ratio of 1:5.

The commenter alleges that FORA, Seaside, and Monterey County have not adopted an Oak Woodlands Conservation Area as required in the Reuse Plan. This comment does not pertain to impacts of the Proposed Project, and instead refers to regulatory procedures which are beyond the scope of this Project and EIR. As discussed under CEQA Guidelines Section 15204(a) “In reviewing draft EIRs, persons and public agencies should focus on the sufficiency of the document in identifying and analyzing the… ways in which the significant effects of the project might be avoided or mitigated."
Response 9.29
The commenter states that the seawater intrusion discussions in the Draft EIR and WSA are outdated, with no data past 2015 provided.

CEQA Guidelines require an EIR to “be prepared with a sufficient degree of analysis to provide decisionmakers with information which enables them to make a decision which intelligently takes account of environmental consequences” (CEQA Guidelines § 15151). Evaluations of these environmental effects “need not be exhaustive” (Ibid). The Draft EIR meets this standard with respect to seawater intrusion issues.

As discussed above, the Draft EIR acknowledges that seawater intrusion is an ongoing problem in the Salinas Valley Groundwater Basin, but that MCWD’s wells in the Deep Aquifer have not experienced signs of seawater intrusion and has reliable quality (Draft EIR page 4.9-5). MCWD’s 12 Preservation of trees in poor health is not required; therefore, the removal of any trees in poor health do not require replacement trees be planted elsewhere.
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Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
2015 UWMP concludes that “neither seawater intrusion nor groundwater contamination pose an immediate threat to water supply reliability” (MCWD 2016 UWMP § 5.2, page 73).

Contrary to the commenter’s contention, the Draft EIR cites to studies after 2015. The Draft EIR provides the following seawater intrusion information dated in 2019: “[a]ccording to the 2019 Salinas River Long-Term Management Plan, current ‘seawater intrusion extends approximately 7 miles inland within the 180-foot aquifer and 4 miles inland in the 400-foot Aquifer.’ (Salinas River Long-Term Management Plan 3-41, 3-42, available at
http://www.salinasrivermanagementprogram.org/ltmp_doc.html.)” (Draft EIR page 4.9-5, footnote 1).

Additionally, the comment references a 2017 study from MCWD, but does not provide this study in the comment not a citation to the study. It is unclear what study the commenter is referring to.

The WSA includes Table 3-1, which shows groundwater production by services area for years 2006- 2015. Table 3-2, however, includes water use within the Seaside-Ord Community for both 2016 and 2017. These numbers are used in the WSA to support the conclusion that “the proposed project does not increase the projected total water demand for the City above the amounts analyzed in the 2015 UWMP” (WSA page 18). Because this determination was made by comparing demand to the analysis in the 2015 UWMP, the WSA’s reliance on 2015 production numbers is reasonable and meets CEQA standards for detail.

Please also refer to Response 9.5 regarding seawater intrusion.

Response 9.30
The commenter claims that the WSA Section 4.1 regarding MCWD’s source of water and desalination plant is confusing and misleading because MCWD’s sole water supply is groundwater pumping, with no back-up supply. The commenter reiterates that the desalination plant is inoperative.

Please refer to Response 9.10. As noted therein, the Draft EIR Appendix M discloses that MCWD’s existing desalination plant located near Marina State Beach is not currently in use, and that the Project does not propose to bring the desalination plant back online.

Response 9.31
The commenter states the opinion that the Draft EIR omits crucial information regarding the golf course storage and recovery program, and fails to disclose information about the long-term reliability of the golf course well, which has been shut down in recent years due to poor water quality. The commenter reiterates that the Seaside Basin is in overdraft and has been adjudicated.

As described in Section 4.2.1 of the Draft EIR, the Bayonet and Blackhorse Golf Courses in-lieu storage and recovery program would replace up to 450 AFY of existing potable water use with recycled water. However, water for the Campus Town project would be supplied by MCWD, who receives its water supply from the Monterey sub-basin, not from wells within the golf course (i.e., not from wells within the Seaside sub-basin). See also Response 9.13, Response 9.21, and the Water Master Response regarding the status of recycled water projects which would be utilized for in-lieu storage included under Mitigation Measure UTIL-1. See also Response 1.10 for the status of the inlieu storage program. 3-140 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 826, Packet Page 949 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
The commenter correctly notes that the Seaside Basin has been adjudicated. A weblink to the Seaside Basin Adjudication is included in the UWMP which is incorporated by reference into the Draft EIR. Draft EIR Section 4.16, Utilities and Service Systems, summarizes the history of the adjudication process and the court’s physical solution. The City of Seaside is subject to Replenishment Assessments in the event it pumps more than its allocation of groundwater supplies from the Seaside Basin. Replenishment Assessments may only be used for artificial replenishment of the Seaside Basin. As noted in the Draft EIR, the Seaside Basin Adjudication ensures the long-term sustainability and reliability of groundwater supplies in the Seaside Basin.

Therefore, the Draft EIR sufficiently addresses the Bayonet/Blackhorse Golf Course and the reliability of groundwater supplies from the Seaside Basin.

Response 9.32
The commenter supports the letter submitted by LandWatch Monterey County and requests to be included on the distribution list for all notices related to the Project.

This comment is noted. Refer to Letter 10 and Response 10.1 through Response 10.32 for the LandWatch comment letter and associated responses.

The commenter has been added to the Project distribution list. 3-141 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 827, Packet Page 950 I;IGH






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10.1 10.2

10.3 3-142 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 828, Packet Page 951 )5;9


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3-143 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 829, Packet Page 952 )5;9


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3-147 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 833, Packet Page 956 )5;9


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10.8 3-148 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 834, Packet Page 957 )5;9


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10.8 (cont'd)

10.9 10.10
3-149 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 835, Packet Page 958 )5;9


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10.12 3-151 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 837, Packet Page 960 )5;9

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10.12 (cont'd)

10.13 10.14
3-152 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 838, Packet Page 961 )5;9



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10.15 10.14
(cont'd)
3-153 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 839, Packet Page 962 )5;9



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10.15 (cont'd)

10.16 3-154 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 840, Packet Page 963 )5;9



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10.17 10.18
3-155 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 841, Packet Page 964 )5;9




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10.19 10.20

10.21 3-156 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 842, Packet Page 965 )5;9



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10.22 3-157 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 843, Packet Page 966 )5;9





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10.22 (cont'd)

10.23 10.24
3-158 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 844, Packet Page 967 )5;9



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10.24 (cont'd)

10.25 10.26
3-159 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 845, Packet Page 968 )5;9



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10.26 (cont'd)

10.27 3-160 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 846, Packet Page 969 )5;9



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10.28 3-161 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 847, Packet Page 970 )5;9



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10.29 10.30
3-162 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 848, Packet Page 971 )5;9


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3-163 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 849, Packet Page 972 )5;9


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10.31 10.32
3-164 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 850, Packet Page 973 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 10
COMMENTER: Michael DeLapa, Executive Director, LandWatch DATE: August 21, 2019
Response 10.1
The commenter summarizes the Project’s proposed development within the Plan Area. The comment does not pertain to the adequacy of the EIR or the CEQA process. Therefore, no further response is required.

Response 10.2
The commenter claims that the Draft EIR fails to follow the MBARD guidelines and consistency should be addressed with the City of Seaside instead of on a countywide basis.

As discussed on pages 4.2-19 to 4.2-20 of Section 4.2.3 of the Draft EIR, the MBARD 2008 CEQA Air Quality Guidelines (pages 5-10 to 5-11) state the following (text is bolded for emphasis):

For a proposed residential project, consistency is determined by comparing the project population at the year of project completion with the forecast for the appropriate five year increment…for the jurisdiction in which the project is located…In Monterey County, consistency with population forecasts is based on comparing a project’s population with countywide forecasts to avoid confusion related to declining population forecasts for cities on the Monterey Peninsula.

Therefore, for projects located in cities in Monterey County, such as Seaside, MBARD recommends comparing the Project’s population with countywide forecasts. As such, the Draft EIR correctly evaluates consistency with the 2015 Air Quality Management Plan based on countywide population forecasts because the Project is located in Monterey County.

Response 10.3
The commenter states that GHG emissions under baseline conditions would be cumulatively considerable and claims that proposed GHG reduction measures are not specified with any precision or are enforceable. However, the commenter provides no explanation on why they believe these measures and imprecise or unenforceable. The referenced measures identify installation of electric vehicle chargers for residential and commercial uses. Such measures are explicitly identified by the State Office of Planning and Research as appropriate mitigation for GHG. (OPR Technical Advisory, CEQA and Climate Change: Addressing Climate Change Through California Environmental Quality Act CEQA) Review,13 page 19-19 [“Examples of GHG Reduction Measures… Where feasible, include in new buildings facilities to support the use of low/zero carbon fueled vehicles, such as the charging of electric vehicles from green electricity sources.”]) The Greenhouse Gas Reduction Plan (GGRP; GHG-1(d)) sets a specific performance standard, and provides a menu of options to accomplish that standard, including but not limited to solar PV. A specific GGRP plan has been proposed pursuant to the provisions of GHG-1(d), as is included as Appendix P, to the Final EIR. However, given the lack of 13 http://opr.ca.gov/docs/june08-ceqa.pdf
3-165 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 851, Packet Page 974 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
information on why the commenter believes these measures are inadequate, no further response is possible.

The commenter states that CARB recommends a series of non-project specific mitigation measures.

Since the commenter offers no evidence that mitigation measures included in the provided list are feasible or applicable to the Proposed Project, the City is under no obligation to evaluate each of them individually in the Final EIR, although such evaluations are nevertheless provided at the end of this response. See Santa Clarita Organization for Planning the Environment v. City of Santa Clarita (2011) 197 Cal.App.4th 1042, 1055 ([“Considering the large number of possible mitigation measures set forth in the letter [50 suggestions], as well as the letter's indication that not all measures would be appropriate for every project, it is unreasonable to impose on the city an obligation to explore each and every one.”)
Section 15126.4(a)(1)(B) of the CEQA Guidelines states, “The specific details of a mitigation measure, however, may be developed after project approval when it is impractical or infeasible to include those details during the Project’s environmental review provided that the agency (1) commits itself to the mitigation, (2), adopts specific performance standards the mitigation will achieve, and (3) identifies the types of potential action(s) that can feasibly achieve that performance standard and that will be considered, analyzed, and potentially incorporated in the mitigation measure.” The City of Seaside has proposed implementing Mitigation Measures GHG-1(a) through GHG-1(d), which would be imposed as enforceable conditions of approval if the City approves the Project.

These mitigation measures include specific performance standards that must be achieved by the project applicant in terms of the quantity of GHG emissions that must be reduced and/or offset. For example, Mitigation Measure GHG-1(a) requires the applicant to implement one or more compliance options to reduce construction-related GHG emissions by 49,974.6 metric tons (MT) of CO2e, and Mitigation Measure GHG-1(d) requires the applicant to prepare and implement a Greenhouse Gas Reduction Plan (GGRP) that reduces the Project’s operational GHG emissions by 12,874 MT of CO2e per year. Finally, these mitigation measures identify the types of potential actions that can achieve these performance standards. For example, Mitigation Measure GHG-1(a) identifies Direct Reduction Activities and Carbon Offsets as potential actions, and Mitigation Measure GHG-1(d) includes a wide array of potential actions in Table 4.7-4 such as solar photovoltaic panels, electric vehicle chargers, transportation demand management programs, LED streetlights, and carbon offsets.

Since publication of the Draft EIR, the Project applicant has prepared a draft GGRP, which identifies a suite of actions that would achieve compliance with Mitigation Measures GHG-1(a) and GHG-1(d) included in the Draft EIR. The GGRP is included as Appendix P and includes the requirement for the Project to include electric vehicle chargers, solar on non-residential buildings, and plant trees. With the GGRP, the Project would result in net zero carbon emissions.

Regarding the suggested mitigation measures, none are needed because with the GGRP, the Project meets the City’s net zero threshold, and would not make a cumulatively considerable contribution to significant cumulative climate change impacts. Regarding each specific measure:
 Freon-free air conditioning: Air conditioning will not be a standard feature in single-family homes or multi-family buildings. Commercial air conditioning would meet California’s green building standards. Buildings would be designed to include features, such as sunscreens, window shades, or low-emission glass, that reduce the need for air conditioning, as well as the mild climatic conditions in Monterey County along the coast. 3-166 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 852, Packet Page 975 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
 Recycling facilities for each residential unit and all public/common areas: Each single-family home will have recycling containers. In multi-family buildings, recycling facilities would be available to all residents (City of Seaside 2019). Recycling facilities also would be available in park/common space areas (Draft EIR Appendix B, Section 3.6.2). The entire Project would comply with the City of Seaside’s recycling and waste diversion requirements. As already discussed in the Draft EIR, “The City currently contracts with GreenWaste Recovery, a private hauler to provide trash, recycling and yard waste collection services” (Draft EIR page 4.16-8; see also Draft EIR Section 4.16.8).
 Recycling education to homeowners on purchase and annually thereafter: Although this measure would not reduce GHG emissions, the Project applicant would supply written material about recycling to new homeowners and have a requirement for the HOA to provide such written material annually to all community residents.
 Recycling of 5 percent of demolition and construction waste: The Project is already required to do this by law, and therefore this is not a mitigation measure (See Draft EIR Section 4.16.8).  Exceed Title 24 by 20 percent: The Project will meet the Title 24 requirements in effect at the time the Project applicant applies for building permits. Given that each version of Title 24 has required increasing energy efficiency, it may not be possible to exceed Title 24 by 20 percent at the time the Project applicant applies for permits. The California Building Code (Title 24, California Code of Regulations) is an area of law heavily regulated by the California Building Standards Commission who reviews and updates the Code every three years for feasibility (Health & Safety Code § 18949.6). The California Building Code standards which go into effect in 2020 already contain highly stringent energy efficiency standards (see Draft EIR page 4.7-6). As noted above, with the existing mitigation measures, the Project would achieve net zero emissions.
 Provide programmable thermostats: The Project already is required to provide programmable thermostats under Title 24, Section 110.2(c): Thermostats. All heating or cooling systems not controlled by a central energy management control system (EMCS) shall have a setback thermostat. (1) Setback Capabilities. All thermostats shall have a clock mechanism that allows the building occupant to program the temperature setpoints for at least four periods within 24 hours. Thermostats for heat pumps shall meet the requirements of Section 110.2(b).”  Multimetering “dashboards” in dwelling units: The inclusion of multi-metering dashboards would not alter the Project’s GHG emissions. As noted, with the GGRP, the Project achieves net zero emissions overall. Furthermore, the Project would comply with the new California Building Code requirements, which require installation of solar (see Draft EIR page 4.7-7 and 10). As also discussed on Draft EIR page 4.7-10, “Monterey Bay Community Power (MBCP), which provides carbon-free electricity, is the default energy provider in the Plan Area. However, future residents and tenants of the Proposed Project could opt out of MBCP and connect to Pacific Gas and Electric (PG&E), which does not provide carbon-free electricity. According to MBCP, approximately 97 percent of accounts in their service area maintain their enrollment in MBCP.”  On-site solar panels on each roof that does not face north: The Project already includes a large quantity of rooftop solar. However, not every roof surface can have specifically angled solar due to roof designs and rooftop equipment requirements. As shown in the GGRP, the Project would include a substantial amount of solar generation.
 75 percent of project electrical energy provided through carbon free, on-site electrical generation facilities: The Project would comply with the new California Building Code requirements, which require installation of solar (see Draft EIR page 4.7-7 and 10 and measures 3-167 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 853, Packet Page 976 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
provided in the GGRP [Appendix P]). As also discussed on Draft EIR page 4.7-10, “Monterey Bay Community Power (MBCP), which provides carbon-free electricity, is the default energy provider in the Plan Area. However, future residents and tenants of the Proposed Project could opt out of MBCP and connect to Pacific Gas and Electric (PG&E), which does not provide carbon-free electricity. According to MBCP, approximately 97 percent of accounts in their service area maintain their enrollment in MBCP.” Under the GGRP, the Project would be producing sufficient solar to meet 100 percent of its electrical energy needs. GGRP measures also require nonresidential buildings to opt in to MBCP as their electric provider, which ensures the buildings would use 100 percent carbon-free electricity.
 All residential roofs and other building roofs that have adequate solar orientation (not northfacing) be designed to be compatible with the installation of photovoltaic panels or other current solar power technology: Under Title 24, all low-rise residential units are required to have rooftop solar panels; the Project would comply with Title 24. In addition, for single-family residences and nonresidential buildings, the GGRP requires rooftop solar that is designed to net out the energy use of those buildings.
 Large buildings use a combined heating and cooling system (cogeneration): As noted above, with the GGRP, the Project would not make a cumulatively considerable contribution to significant climate change impacts, and therefore no additional mitigation measures are required under CEQA. Cogeneration is a process in which the boiler system and a turbine system are integrated to generate heat for both hot water and electricity and in which waste energy may be utilized to produce heat and electricity. Cogeneration is typically only feasible for very large projects, e.g., LAX international airport, and associated with on-site electricity generation.

The Project does not propose installing projects of this scale, nor does it propose on-site electricity generation, aside from solar panels. The suggestion is not considered feasible or necessary to reduce a significant impact.
 Pools and spas heated use solar water heaters unless they use naturally heated water; Energyefficient pumps and motors for pools and spas; Covers for pools and spas that are not naturally heated: Energy efficiency standards for any future pools and spas in the Plan Area would be controlled by Title 24 of California’s energy code.  Light colored to minimize cooling requirements: Draft EIR page 4.7-6 already explains that the Project is required to comply with Title 24, which requires installation of cool roofs. Further, cooling is not a large issue in Seaside, which has relatively few very hot days.  Construction equipment powered by clean-burning fuel, bio-diesel fuel, and/or other alternative fuels, or shall use electric or hybrid-electric engines so as to reduce construction emissions: The GGRP requires the Project applicant to use renewable diesel in its heavy construction equipment and use electric-powered hand-held tools.  Operational vehicles supporting the project, including shuttles, shall be electric or other zero emission vehicles: The Project applicant anticipates that shuttles, such as a hotel shuttle, would be electric, but this measure is not included in the GGRP because there is insufficient data to quantify emission reductions associated with such a shuttle. As noted above, with the mitigation already required, the Project result in net zero GHG emissions. Additionally, the GGRP (Appendix P) includes measures requiring the installation of electric vehicle charging stations at single-family residences, in 10 percent of multi-family residence parking spaces, and in commercial parking areas.
 Limit Construction equipment idling to 5 minutes: This is already required by Mitigation Measure N-1, and by existing regulations (13 CCR §2485). 3-168 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 854, Packet Page 977 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
 Limit delivery vehicle idling to 3 minutes: As noted, with the mitigation already required, the Project result in net zero GHG emissions. Furthermore, as noted above, the state already limits commercial idling times, and the City finds if infeasible from a policy perspective to second guess such decisions which are already regulated by the state.

Response 10.4
The commenter questions the unit count for dwelling units within the former Fort Ord area referenced in the Draft EIR. The commenter provides numbers based on their data and requests clarification on how the City will assure consistency with the 6,160-unit cap and whether the Project will take priority over new residential development at the Main Gate Specific Plan (MGSP).

FORA’s Development Resource Management Plan includes a Residential Development Program and New Residential Unit Limit that generally limit total new residential development at the former Fort Ord. The Residential Development Program projects 10,816 residential units, of which 6,160 are projected to be new units. The New Residential Unit Limit generally restricts total new residential units within the former Fort Ord to 6,160 units. The FORA Capital Improvement Program (CIP) for Fiscal Year 2019-20 through 2028-29 indicates that there are 4,665 new residential units entitled, leaving a remaining capacity of 1,495 new residential units (FORA 2019a). The Draft EIR provides the correct buildout numbers per the FORA 2019 CIP. Table 3-1 below lists the entitled and constructed buildout numbers for these projects based on the FORA 2019 CIP.

One of the Projects referenced in the comment is not included in this list, i.e., Marina’s Permanent supportive Housing for Veterans at Hayes Circle. This project is already operational, and is an existing barracks which was converted into replacement housing.

Table 3-1 FORA Residential Development (Including Seaside Notes) Project Title Entitled Residential Units Built Residential Units New Residential
Sea Haven 1,050 201
Dunes of Monterey Bay 1,237 410
Cypress Knolls1 712 0
Veterans Transition Center 84 13
Seaside Resort 125 3
Nurses Barracks2 0 0
East Garrison 1,470 869
Sub-total 4,665 1,282
Existing/Replacement Residential
Preston Park 352 352
Abrams B 192 192
MOCO Housing Authority Project 56 56
Shelter Outreach Plus Project 39 39
Interim Inc. 11 11
Sunbay 297 297
3-169 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 855, Packet Page 978 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
Project Title Entitled Residential Units Built Residential Units Bayview 225 225
Seaside Highlands 380 380
Seaside Senior Living3 0 0
Sub-total 1,565 1,766
Total New + Existing/Replacement 6,230 3,048
Source: FORA 2019, Table 6.
1 While the Cypress Knolls project is still listed in FORA’s table, it is no longer reasonably foreseeable, as the vesting tentative map has expired; the project requires new discretionary approvals, and no application for such approvals has been filed. 2 The Nurses Barracks would replace existing housing units and is not entitled. 3 While Seaside Senior Living would provide approximately 88 units, is not considered a residential use, rather it is a Business and Professional Service use (SMC §§ 17.12.020 and 17.98.020).

FORA’s Development and Resource Management Plan also includes an Industrial and Commercial Job Creation Program, which provides that, when the estimated jobs within the former Fort Ord reach 18,000, the Residential Development Program shall be eliminated. Accordingly, the FORA CIP for Fiscal Year 2019-20 through 2028-29 provides that the new residential unit limit is 6,160 until 18,000 new jobs are created on Fort Ord lands. This 6,160-unit limit does not include existing and replacement residences, which total 1,813 units, for a total of 7,973 units allowed in Fort Ord (not including the POM Annex or CSUMB Housing) (FORA 2019a). Therefore, there is a remaining capacity of 1,495 new residential units as of May 3, 2019 (6,160-unit limit minus 4,665 new units entitled equals 1,495 units remaining; this calculation conservatively includes buildout of the Cypress Knolls project, despite that it is no longer reasonably foreseeable). This is adequate to accommodate the Project, which proposes 1,485 new residential units within the Plan Area. Please also see Government Code Section 66300(b)(1)(D), SB 330 (2019).

The Main Gate Specific Plan (MGSP) was approved in August 2010, and includes a retail center, hotel/spa, and conference center, but no residential (City of Seaside 2010). While the developer had informally discussed potential revisions related to making residential a permissible use, there is no current active application for such an amendment.

Response 10.5
The commenter suggests several additions to the cumulative project list (Table 4-1), including East Garrison, Sea Haven, the Dunes at Monterey Bay, Seaside Resort, Seaside Senior Living Center, Housing for Hayes Circle, and South of Tioga.

Table 4-1 of the Draft EIR already includes the South of Tioga project, and the Housing for Hayes Circle is listed as “Veterans Transition Center Housing.” The remaining suggested cumulative projects have been added to Table 4-1 (revisions are shown below) and are considered in the cumulative analysis subsections throughout Section 4. The Cypress Knolls project is no longer reasonably foreseeable, as the vesting tentative map has expired and the project would require new discretionary approvals in order to proceed; no application for such approvals has been submitted.

The following revisions have been made in Table 4-1 on Pages 4-3 through 4-5. 3-170 Attachment A
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Table 4-1 Pending Projects in the Vicinity of the Plan Area (Revisions Only) Cumulative
Project Description Project Status
Cypress Knolls
Senior Residential
Senior residential community with active-adult housing, care services, senior community center, and supportive amenities and services on 188 acres.

Approved, not
built
East Garrison Construction of 40,000 sf of retail and 1,470 total residential units, including single-family homes, apartments, and townhomes, as well as recreational and community areas, an artist live-and-work “downtown” residential and visitor-serving area. Approximately 2.7 miles east of the Plan Area.

Approved,
partially
constructed
(869 units)
Sea Haven
(formerly Marina
Heights)
Removes 828 Fort Ord housing units and constructs 1,050 residential units, including single-family homes and townhomes. Approximately 1 mile north of the Plan Area. Cypress Marina Heights, LLC., the developer of the project made an application for the “Marina Heights Specific Plan” in October of 2002 and the Marina City Council approved the project in 2003.

Approved,
partially
constructed
(201 units)
The Dunes at
Monterey Bay
(formerly
University
Villages)
Retail, commercial, and residential project, including 1,237 residential units, 500 hotel rooms, 760,000 sf office, and 570,000 sf retail.

Located approximately 0.5 mile north of the Plan Area.

Approved,
partially
constructed
Seaside Resort Development of 125 residential units, 330 hotel units, and 170 timeshare units on two former Army golf courses. Located approximately 1 mile south within the Black Horse Golf Course.

Approved,
partially
constructed (3
units)
Seaside Senior
Living Project
This project would construct an assisted living facility, memory care facility, and co-housing assisted living facility, with a total of 144 multifamily units (70 studio units and 74 total one-bedroom, two-bedroom, and co-housing units). Located approximately 1.8 miles southwest of the Plan Area.

Proposed
sf = square feet
The revisions provided in this table would not affect the cumulative analyses in the individual resource sections. Many parts of the EIR rely upon cumulative growth projections rather than the list of projects, including Air Quality, Energy, Greenhouse Gas Emissions, Transportation, and Utilities. Other resource areas, inclusion of additional projects would not have a substantive effect on the existing cumulative analysis. For example, the Aesthetics analysis geographic scope is based upon projects in the general vicinity of the Plan Area. The closest project added to this list, is the Dunes at Monterey mixed use project, approximately 0.5 mile north of the Plan Area, and would replace existing deteriorated residential army structures. The other projects are beyond the geographic scope of the aesthetics cumulative analysis. The other resource analyses have been similarly reviewed, and no additional revisions are necessary to the underlying analyses.

Response 10.6
The commenter states that no replacement water supply for the 1993 Agreement has been provided, and that FORA, MCWD, and local jurisdictions assume they can pump 6,600 AFY from former Fort Ord indefinitely, even though there is no permanent right to pump groundwater, as this is a temporary water supply. The commenter states the opinion that the Draft EIR is flawed because it assumes there is 181.3 AFY supply of groundwater for the Project based on the 6,600 AFY supply, 3-171 Attachment A
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and fails to evaluate the impacts of using this supply. The commenter suggests inclusion of a mitigation measure that would require a water supply to be secured. Lastly, the commenter expresses concern that the water supply analysis provided in the EIR relies upon “paper water” assumptions, where a certain amount of water is known to be allocated to a particular user but the physical amount of water allocated has not been provided or is not available.

The 6,600 acre-feet per year figure is derived from the 1984 peak and the 1988-1992 average amount of potable water Fort Ord withdrew from the Salinas Basin, not including pumping from a non-potable golf course well” (Draft EIR Section 4.16.1). Reliance upon the 6,600 AFY allocations is supported by (1) the statutory baseline procedures provided under Pub. Res. Code § 21083.8.1 (Draft EIR Sections 3.3 and 4.16.1), and (2) MCWRA’s Long-Term Management Plan and the groundwater sustainability planning process which are designed to ensure the reliability of the 6,600 AFY (Draft EIR page 4.16-20; Draft EIR Appendix M1, Section 5.3 [“Reliability of Water Supply and the Regional 6,600 AFY Allocation”]). Furthermore, the purpose of CEQA is to analyze impacts in comparison to existing conditions, not to fix existing environmental issues (Watsonville Pilots Association v. City of Watsonville (2010) 183 Cal.App.4th 1059 [“The FEIR was not required to resolve the [existing] overdraft problem, a feat that was far beyond its scope”]). Please also see the Water Master Response.

Response 10.7 & 10.8
The prevailing theme amongst Comments 10.7 through 10.8 are requests for evidence of FORA’s procedural compliance with the provisions of CEQA Guidelines Section 15229. However, the procedural requirements contained CEQA Guidelines Section 15229 related to FORA’s actions were not adopted or applicable to the Fort Ord Base Reuse Plan EIR. CEQA Guidelines Section 15229 was not filed with the Office of Administrative Law (OAL) until May 27, 1997 (California Regulatory Notice Register 97, No. 22), and was not applicable to the BRP EIR (CEQA Guidelines, § 15007). A Notice of Preparation for the BRP EIR was issued on January 8, 1996, and the Notice of Availability for the BRP EIR initiated public review of the BRP Draft EIR on May 31, 1996 (FORA Resolution 97-6, §§ (B)(5) and (10)). Furthermore, the time to challenge the BRP EIR’s compliance with Pub. Res.

Code Section 21083.8.1 expired more than two decades ago; the BRP Final EIR expressly stated under “1.2.2 Baseline Determination:”
As with the Army’s FEIS and DSEIS, this Draft EIR determines whether the proposed project may have a significant impact on the environment based on physical conditions that were present at the time the decision became final to close Fort Ord as a military base (September, 1991). This complies with Section 21083.8.1 of the Public Resources Code and utilizes the extensive research already conducted for the Army’s NEPA documents, which use the same baseline year. (Emphasis added.)
FORA certified the BRP EIR and the language quoted above, stating “The board of Directors certifies the Final Environmental Impact Report, including its concomitant components as described in this Resolution, adequately describes the environmental consequences of the Fort Ord Reuse Plan, and has been completed in compliance with state law” (FORA Resolution 97-6).

While the time period for challenging FORA’s compliance with Pub. Res. Code Section 21083.8.1 has long since passed, detailed information on FORA’s BRP CEQA process is provided by its historic documents. As outlined in FORA Resolution 97-6, “On January 8, 1996 staff for Fort Ord Reuse Authority issued a Notice of Preparation [which] was sent to the California Office of Planning and Research State Clearinghouse and each responsible agency, federal agency, and trustee agency as 3-172 Attachment A
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required by law, as well as to interested agencies, individuals, and jurisdictions…On January 22 [1996], the Fort Ord Reuse Authority conducted noticed public scoping sessions…Notice of these scoping session was published in accordance with state law” (FORA Resolution 97-6 and BRP Final EIR Section 1.5). A copy of the Notice of Preparation is included in Final EIR SCH # 9601302214 and states in part:

The Fort Ord Reuse Authority (FORA) will be the Lead Agency and will prepare an Environmental Impact Report (EIR) for the Reuse Plan on the closed Federal military facility at Fort Ord. Fort Ord's location is illustrated in Attachment A. We need to know the views of your agency as to the scope and content of the environmental information which is germane to your agency's statutory responsibilities in connection with the proposed project. Public Resources Code Section 21083.8 allows FORA to rely in part on the Fort Ord Disposal and Reuse Environmental Impact Statement (EIS) and the Draft Fort Ord Disposal and Reuse Draft Supplemental Environmental Impact Statement (SEIS), which are incorporated herein by reference, for environmental review on the Reuse Plan. FORA intends to utilize the EIS and SEIS as the Draft EIR and requests comments on whether, and to what extent, the EIS and SEIS provide adequate information to serve as the Draft EIR for the Reuse Plan, and what specific additional information, if any, is necessary to comply with the California Environmental Quality Act (CEQA)….

As provided by Public Resources Code Section 21083.8, the purpose of this process for closed Federal military facilities is to facilitate the environmental review process on Reuse Plans, to avoid duplication and to utilize or build on the environmental work already completed by a Federal agency in a consistent manner with CEQA.

Further, as provided by Public Resources Code Section 21083.8.1, it is FORA's intent to make the determination of whether the Project may have a significant effect on the environment in the context of the physical conditions which were present at the time that the Federal decision became final for closure of Fort Ord.

Furthermore, the commenter misrepresents CEQA Guidelines Section 15229 which does not require “FORA to prepare” the “proposed baseline physical conditions.” Both 15229 and Pub. Res. Code anticipate utilizing the baseline data prepared in the EIS, i.e., “the lead agency shall specify whether it will adopt any of the baseline physical conditions [from the EIS] for the reuse plan EIR…” See also Gov. Code 67675.9 [“The board shall, to the greatest extent feasible, avoid duplication and utilize information in the environmental impact statement consistent with this division. The draft environmental impact report shall consist of all or part of the environmental impact statement and any additional information that is necessary to prepare a draft environmental impact report in compliance with the California Environmental Quality Act.”] The commenter requests identification of the time that the federal decision for the closure of Fort Ord base became final. As explained in Campus Town Draft EIR Section 2.2.3 “The Plan Area is located within the former Fort Ord Army Base, which was closed in 1994 pursuant to the Base Realignment and Closure (BRAC) action. The final decision to close the base occurred several years earlier, in September 1991.” Similarly, Draft EIR Section 3.3 explains “the time the decision became final to close Fort Ord as a military base [was] (September 1991).” The BRP EIR Section 1.2.2 also states: “As with the Army’s FEIS and DSEIS, this Draft EIR determines whether the proposed project may have a significant impact on the environment based on physical conditions that were present at the time the decision became final to close Fort Ord as a military base (September, 1991). This 14 https://www.fora.org/Reports/BRP/031997_rpt_FEIR_Volume%20I_Comments.pdf 3-173 Attachment A
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complies with Section 21083.8.1 of the Public Resources Code.”15 As explained in BRP Section 2.4.4 "NEPA does not apply to the BRAC 1991 deliberation and decision process, nor to the closing action itself, but does apply to disposal and reuse of property.” The Record of Decision referenced in the comment occurred in 1993 and is associated with FORG’s Initial Reuse Plan. (BRP, Volume 1, Section

2.4.4;16 see also BRP, Volume 2, page 214.17)
Response 10.9
The commenter requests the baseline conditions in the BRP EIR for annual groundwater pumping be identified, and the source of assumptions be identified. The commenter requests the time period, geographic scope, and groundwater basin or subbasin for baseline conditions be identified. The commenter further notes that Figure 4.9-2 in the Draft EIR does not show the Plan Area, and requests a figure depicting each well that would supply water to the Plan Area, with indication of the source aquifer.

The information requested was expressly provided in Draft EIR Appendix M1, page 22:

Under the “Agreement between the United States of America and the Monterey County Water Resources Agency concerning Annexation of Fort Ord into Zones 2 and 2A of the Monterey County Water Resources Agency, Agreement No. A-06404”, dated September 21, 1993, the District (successor to the United States) may withdraw up to 6,600 acre-feet per year from the Salinas Valley Groundwater Basin for use in the District’s Ord Community service area. The 6,600 acre-feet per year figure is derived from the 1984 peak and the 1988-1992 average amount of potable water Fort Ord withdrew from the Salinas Basin, not including pumping from a nonpotable golf course well.9
FN9 ‘After execution of this agreement and until Project Implementation, Ford Ord/POM/RC may withdraw a maximum of 6,600 acre-feet of water per year from the Salinas Basis, provided no more than 5,200 acre feet per year are withdrawn from the 180-foot aquifer and 400-foot aquifer. The 6,600 and 5,200 acre-feet thresholds correspond to the annual peak (1984) and recent average (1988-1992) amounts of potable water Ford Ord has withdrawn from the Salinas Basin (does not include pumpage from the non-potable golf course well in the Seaside Basin)” (Agreement A-06404, § 4, subd. (c); available at https://www.fora.org/Reports/09231993- agreement-Army-MCWRA.pdf.)’
[The weblink to the 1993 Agreement explains] After execution of this agreement and until Project Implementation, Fort Ord/POM Annex/RC may withdraw a maximum of 6,600 acre-feet of water per year from the Salinas basin, provided no more than 5,200 acre-feet per year are withdraw from the 180-foot aquifer and 400-foot aquifer. The 6,600 and 5,200 acre-feet thresholds correspond to the annual peak (1984) and recent average (1988-1992) amount of potable water Fort Ord has withdrawn from the Salinas Basin (does not include pumpage from the non-potable golf course well in the Seaside Basin). (Emphasis added.) The Draft EIR incorporated by reference the “Other Physical Attributes Baseline Study of Ford Ord” as discussed in Draft EIR Section 3.3 (CEQA Guidelines Section 15150). Similar discussion of historic water use from Fort is provided on page 1-8 of that document. 15 http://b77.402.myftpupload.com/wp-content/uploads/BRP_v4_FinalEIR_1997_Sec01_Introduction.pdf 16 https://www.fora.org/Reports/BRP/BRP_v1_ContextAndFramework_1997.pdf 17 https://www.fora.org/Reports/BRP/BRP_v2_ReusePlanElements_1997.pdf 3-174
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The commenter also asserts that “the Plan Area is not in fact shown on [Figure 4.9-2].” Draft EIR Figure 4.9-2 does in fact include the Plan Area, which was expressly identified on the previous page of the EIR (i.e., Figure 4.9-1). Please review these two Figures in conjunction with one another.

MCWD’s well locations are identified in Figure 2.2 of the Urban Water Management Plan, which was incorporated by reference in the EIR (Draft EIR page 4.16-13).

However, as discussed in the EIR, the WSA, and the Water Master Response, MCWD owns and operates three wells in its Central Marina service area and five in its Ord Community service area, all of which are within the Monterey Subbasin, and may be used to support the Proposed Project.

Response 10.10
The commenter requests clarification of the term “upper aquifers,” as used in the Draft EIR.

The term “upper aquifers” as used on pages 4.9-5 and 4.9-25 in Section 4.9 of the Draft EIR, and on pages 4.16-19 and 4.16-20 in Section 4.16, Utilities and Service Systems, refers to the Monterey Subbasin of the SVGB, not to the 180/400 Foot Aquifer Subbasin of the SVGB. As described in the Draft EIR and references provided by in-text citation, the Monterey Subbasin is not substantially affected by seawater intrusion. As also explained in the WSA: “all of the District’s [i.e., MCWD’s] wells are located within the Monterey sub-area [i.e., subbasin] of the Salinas Valley Groundwater Basin” (Draft EIR Appendix M1, page 22). MCWD’s well locations are identified in Figure 2.2 of the Urban Water Management Plan, which was incorporated by reference in the EIR (Draft EIR page

4.16-13).

Response 10.11
The commenter requests the wells (by number) supplying water from the Deep Aquifer and from other aquifers to the Ord Community be identified. The commenter also presents text from the MCWD UWMP, and requests that the EIR for the Proposed Project include specific information in response to text from the UWMP, including explanation of: whether MCWD serves the Ord Community with water from MCWD wells in Central Marina; how much water is supplied on an annual basis for the Deep Aquifer and other aquifers; and whether MCWD serves Marina with water from Ord Community wells as well as how much water is supplied annually for the Deep Aquifer and other aquifers. The commenter also requests data showing the amount of water supplied to the Ord Community from various wells (deep aquifer and upper aquifer) since the year 1991. “An EIR need not include all information available on a subject. An EIR should be ‘analytic rather than encyclopedic’ and should emphasize portions ‘useful to the decision-makers and the public’” (Al Larson Boat Shop, Inc. v. Board of Harbor Commissioners (1993) 18 Cal.App.4th 729, 748). As the Supreme Court has explained “CEQA… does not require a city or county, each time a new land use development comes up for approval to reinvent the water planning wheel… When an individual land use project requires CEQA evaluation, the urban water management plan’s information and analysis may be incorporated in the water supply and demand assessment” (Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova [2007] 40 Cal.4th 412).

Please see Responses 9.9 and 10.9. As referenced therein, quarterly Ord Community Consumption Reports through 2019 can be found in PDF format on MCWD’s website.18 An overview of the history of groundwater management is provided in the Water Master Response; as described, MCWRA’s 18 https://www.mcwd.org/gsa_water_consumption.html
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role in the management of the Monterey Subbasin dates back to the late 1940s, and MCWRA developed a groundwater management plan in 2006.

Response 10.12
The commenter presents language and analysis from the Draft EIR, which describes overdraft and seawater intrusion as reported in MCWD’s UWMP, and states that the Draft EIR discusses overdraft and seawater intrusion into the groundwater basin. The comment presents a summary of information and analysis contained in the EIR and does not pertain to the adequacy of the EIR.

Therefore, no further response is required.

Response 10.13
The commenter claims that the Draft EIR does not disclose whether the Monterey Subbasin is experiencing overdraft or seawater intrusion, nor the hydrological connection and influences between the Monterey Subbasin and the 180/400 Foot Aquifer Subbasin. The commenter requests an explanation of whether the MCWD upper aquifers are in overdraft or experience seawater intrusion, and requests that wells be identified by number.

The commenter is incorrect in claiming that the Draft EIR does not disclose the condition of the Monterey Subbasin. The Draft EIR for the Proposed Project fully characterizes known current and past conditions of groundwater supply in the Monterey Subbasin, including on page 4.9-5 of the Draft EIR, which describes that the Monterey Subbasin Deep aquifer has not experienced signs of seawater intrusion and is considered to have reliable quality. As also explained on page 4.9-5 “there is a monitoring well that serves as an ‘early warning system to identify any seawater intrusion…’ (MCWD 2016 UWMP Section 4.2.5, at p. 48).” The Draft EIR incorporated by reference, the UWMP, including Figure 4.6, which shows the locations of sea-water intrusion in the overall Salinas Valley Groundwater Basin in the 400-foot aquifer. As shown in that figure, seawater intrusion in the Monterey Subbasin 400-foot aquifer (located approximately south of Reservation Road), has not substantially progressed since the 1990s. MCWD’s wells in the 400-foot aquifer (MCWD-29, 30, 31, 34, and 39) are located outside of this area of sea-water intrusion. (UWMP, Figure 2.2 and Section

4.2.5.) Further discussion of groundwater and groundwater management in the Plan Area is provided in the Water Master Response.

The commenter asks for the identity of the MCWD well numbers in the “upper aquifers” using the well ID numbers on page 45 of the 2015 UWMP. This level of detail is not necessary for the EIR to meet its statutory obligation to “be prepared with a sufficient degree of analysis to provide decisionmakers with information which enables them to make a decision which intelligently takes account of environmental consequence.” (CEQA Guidelines § 15151). Evaluations of these environmental effects “need not be exhaustive” (Ibid). “An EIR need not include all information available on a subject. An EIR should be ‘analytic rather than encyclopedic’ and should emphasize portions ‘useful to the decision-makers and the public’” (Al Larson Boat Shop, Inc. v. Board of Harbor Commissioners (1993) 18 Cal.App.4th 729, 748). As the Supreme Court has explained “CEQA… does not require a city or county, each time a new land use development comes up for approval to reinvent the water planning wheel… When an individual land use project requires CEQA evaluation, the urban water management plan’s information and analysis may be incorporated in the water supply and demand assessment” (Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova (2007) 40 Cal.4th 412). Nevertheless, this information was already provided in the UWMP, which was incorporated by reference. (See UWMP, Figure 2.2 and Section 4.2.5.) 3-176 Attachment A
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Response 10.14
The commenter claims the Draft EIR does not provide essential information to assess cumulative impacts to the Monterey Subbasin upper aquifers and requests current and projected cumulative pumping, recharge, and water balance data. The commenter requests the following information be included: total current and projected annual groundwater pumping, total annual recharge, sustainable yield without overdraft or seawater intrusion, and the amount of increase pumping from the Project on the Monterey Subbasin. The commenter requests an explanation of whether the upper aquifers are hydrologically connected.

The EIR and WSA considered past, present and future projects in Table 4.16-1, Marina Coast Water District Projected Cumulative Water Demand – Ord Community, which are based upon historic water consumption and projected water use in the Urban Water Management Plan (Draft EIR page 4.16-3; Draft EIR Appendix M1, Section 3.2). The commenter also requests information on hydrologically interconnections. The Draft EIR and WSA incorporated by reference MCWD’s 2015 Urban Water Management Plan (Draft EIR page 4.16-13; Draft EIR Appendix M1, page 6). MCWD’s UWMP discusses hydrological interconnections on pages 35-37.

The data requested by the commenter amounts to a comprehensive hydrologic evaluation for the Monterey Subbasin. It is beyond the scope of the EIR to provide the regional water balance data and analyses requested by the commenter (Watsonville Pilots Association v. City of Watsonville (2010) 183 Cal.App.4th 1059 [“The FEIR was not required to resolve the [existing] overdraft problem, a feat that was far beyond its scope”]). The Draft EIR provides analysis of potential impacts associated with the Project's water supply requirements, and identifies mitigation required to ensure water supply availability for the Project. Please see the Water Master Response for further discussion regarding CEQA requirements for the scope of an EIR. As stated above, CEQA “does not require a city or county, each time a new land use development comes up for approval, to reinvent the water planning wheel.” (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 434). Please also see Response 10.13.

Response 10.15
The commenter refers to page 4.9-5 of the Draft EIR, where the Salinas Valley Water Project is mentioned in a reference from MCWD’s 2015 UWMP, and requests detailed discussion as to how the Salinas Valley Water Project has reduced pumping in the upper aquifers and what the Salinas Valley Water Project’s effects on groundwater supply have been. The commenter requests evidence that the upper aquifers are a long-term source of water supply.

The commenter’s citations are to a broad overview of existing groundwater issues in “in the 180/400 Foot Aquifer Subbasin,” and not within the Monterey Subbasin (the subbasin that is utilized by MCWD, the water provider for this Project). The commenter’s organization is also readily familiar with this Project, having litigated the efficacy of the Salinas Valley Water Project on several occasions, and having challenged it’s efficacy at length on other projects19 (Highway 68 Coalition [and LandWatch Monterey County] v. County of Monterey (6th App. Dist. July 26, 2019 Case no.

H045253;20 see also LandWatch Monterey County v. County of Monterey (26th App. Dist. 2007 Case 19 LandWatch submitted extensive comments on the Salinas Valley Water Project on the Monterey County General Plan EIR in 2010, and were given an extensive detailed description of this Project in Master Response Sections 4.2.2 and 4.2.3 of that EIR:
https://www.co.monterey.ca.us/home/showdocument?id=45384 and https://www.co.monterey.ca.us/home/showdocument?id=45386 20 Highway 68 Coalition [and LandWatch Monterey County] v. County of Monterey (6th App. Dist. July 26, 2019 Case no. H045253:
https://www.courts.ca.gov/opinions/nonpub/H045253.PDF.
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No. H028659) [holding that there is substantial evidence that the SVWP water supply benefits would accrue to portions of North County]). While it appears the commenter is familiar with this Project, if they would like to obtain additional information, it is available online.21 Please see the Water Master Response for detailed discussion of long-term water supply management activities and responsible parties, including identification and discussion of planning documents relevant to the area. The Water Master Response notes that the Salinas Valley Water Project is one of multiple infrastructure and water supply reliability projects within the Salinas Valley Basin that are designed to address seawater intrusion. As described in previous responses, basinwide hydrologic modeling is beyond the required scope of CEQA analysis for the Proposed Project.

Because this comment does not pertain to the adequacy of the Draft EIR or CEQA process, no further response is required.

The comment additionally states that “[s]tudies also indicate that a temporary slow-down in the rate of seawater intrusion has been reversed and that seawater intrusion has in fact accelerated,” and that the Draft EIR “is inadequate as an informational documents because it fails to discuss this.” The comment cites to no specific study and has attached no studies supporting this contention. And as discussed above, this is referencing a different subbasin which is not utilized by MCWD for this project. Please also see Response 10.13 and Response 9.5 for discussion of seawater intrusion.

Response 10.16
The commenter claims the Draft EIR does not provide an adequate analysis of existing and future pumping from the Deep Aquifer or explain how much increased pumping would occur as a result of the Project. The commenter requests information on hydrologic connectivity between aquifers. The commenter asks for the wells that will serve the Project with Deep Aquifer water be identified, the current and future amount of pumping from the Deep Aquifer, sources of recharge, and amount of sustainable pumping.

Please see Water Master Response for detailed discussion of previous and long-term water management including Fort Ord groundwater wells. As described in previous responses, basin-wide hydrologic modeling is beyond the required scope of CEQA analysis for the Proposed Project.

Because this comment does not pertain to the adequacy of the Campus Town Draft EIR or CEQA process,.

With respect to this comment’s request for ID numbers of wells, see Response 10.13. Please see Response 10.14 for discussion of hydrological connections. Please see Response 10.9 for discussion of Fort Ord’s historic water use and allocations of water between different aquifers within the Monterey subbasin. Please see the 2015 MCWD UWMP Figure 2.2 and Section 4.2.5 for well locations. Please see Response 10.14 and Draft EIR Section 4.9, Section 4.16, and Appendix M1 about cumulative water use and the Project’s water use and MCWD’s water sources. See Response

9.22 for discussion of MCWD litigation. See Response 9.5 for discussion of the Deep Aquifer’s water source.
21 SVWP Phase I: https://www.co.monterey.ca.us/government/government-links/water-resources-agency/projects-facilities/salinasvalley-water-project-svwp#wra SVWP Phase II: https://www.co.monterey.ca.us/government/government-links/water-resources-agency/projects-facilities/salinas-valleywater-project-phase-ii#wra 3-178 Attachment A
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Response 10.17
The commenter requests explanation regarding statements made in the Draft EIR that the Deep Aquifer has not experienced seawater intrusion and groundwater quality impairment. The commenter also requests clarification of the following: a 2003 study that was cited in MCWD’s UWMP (which was in turn incorporated by reference in the Draft EIR); the term “landward flow of groundwater” and its relation to seawater intrusion; and the baseline rate of Deep Aquifer pumping.

The commenter cites pages 4.9-5, 4.9-25, and 4.16-19, in requesting explanation of statements about seawater intrusion and groundwater quality. To clarify, the Draft EIR does not state that these issues have not occurred in the area; rather, the Draft EIR cites the MCWD 2015 UWMP in stating that seawater intrusion and groundwater contamination do not “pose an immediate threat to water supply reliability.” The Draft EIR (and the cited UWMP) goes on to describe that seawater intrusion and groundwater contaminations issues are known to occur in the area, and monitoring wells are utilized as an “early warning system” to anticipate and identify the presence of these conditions.

Other groundwater management activities are described in the Draft EIR and the Water Master Response, including the 1998 Water/Wastewater Facilities Agreement between MCWD and FORA, the 2016 Pure Water Delivery and Supply Project between MCWD and M1W, and the SGMA.

The commenter requests clarification of a statement made on page 4.9-5 of the Draft EIR regarding a 2003 study that modeled seawater intrusion in the area. That statement, “in the absence of other action to control seawater intrusion, the landward flow of groundwater would increase,” communicates that were no groundwater supply management actions in place, and groundwater pumping in the Deep Aquifer were increased up to five times the baseline rate, seawater intrusion (the landward flow of groundwater) to the Deep Aquifer would increase. In other words, increasing groundwater production from the Deep Aquifer without managing the area for seawater intrusion will result in seawater intrusion. This message is consistent with the analysis provided in the Draft EIR, which discusses the multiple groundwater management efforts in the Plan Area with respect to how they address the potential for seawater intrusion to occur.

The commenter requests identification of the 2003 study referenced by the Draft EIR. To clarify, the 2003 study was referenced by MCWD’s 2015 UWMP, which was in turn referenced in the Draft EIR.

Review of the 2015 UWMP (page 50) indicates that the 2003 report is entitled, “Deep Aquifer Investigative Study,” and was prepared by WRIME in May 2003. This document has also been cited extensively by LandWatch, including their February 26, 2019 comments on the Monterey Downs Project.22
The phrase “landward flow of groundwater” refers to groundwater which flows in the direction of land rather than the direction of sea, which is apparent given the context of the phrase in relation to discussion of seawater intrusion. The Water Master Response provides additional discussion of groundwater management in the Plan Area. The Water Master Response also provides discussion of the required scope of analysis for CEQA.

Response 10.18
The commenter requests explanation of how increased withdrawal of potable groundwater supports the contention that any pumping from the Deep Aquifer is part of a baseline. 22 http://www.landwatch.org/pages/issuesactions/fortord/022619-GroundwaterLetter-LWCommentstoArmy.pdf 3-179 Attachment A
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Please see Response 10.6, Response 10.7, and Response 10.9 for discussion of the historic use of 6,600 AFY. Refer to the Water Master Response. As stated therein, the Water/Wastewater Facilities Agreement entered into by MCWD and FORA, dated March 13, 1998, provided that MCWD would take over conveyance of Fort Ord’s water and wastewater facilities and build additional water and sewer facilities as needed by the Fort Ord BRP. The commenter cites a section of MCWD’s 1998 Agreement with FORA, and states “Please explain how the reference to a permitted ‘increased withdrawal of potable groundwater from NCWD’s existing will in the 900-foot aquifer’… is part of a baseline.” As noted in Section 1.4 of that 1998 Agreement “The USA presently owns all existing facilities. The USA has determined to divest itself of the existing facilities… At its meeting on October 11, 1996, the FORA Board authorized staff to commence negotiations with MCWD for the purpose of negotiating an agreement with MCWD whereby MCWD would assume the responsibility of the operation, maintenance, and ownership of the exiting water (and wastewater collection) systems on the former Fort Ord.” Furthermore, by 1998 the existing Army base had closed, and water consumption would have gone below historic use when the base was fully operational.

As explained above, prior to the 1998 Agreement, MCWD did not have the authority to pump the Army/FORA’s water allocations. Therefore, any increased consumption by MCWD would be an increase above what MCWD would have utilized previously. This is not referencing an increase of the Army/FORA’s allocations. Indeed, the section of the 1998 Agreement cited by the commenter explicitly references section 4.C of the 1993 Agreement discussed in Response 10.9 above, which explains that “The 6,600 and 5,200 acre-feet thresholds correspond to the annual peak (1984) and recent average (1988-1992) amounts of potable water Ford Ord has withdrawn from the Salinas Basin…”
The Water Master Response further describes MCWD’s rights to pump groundwater from the Deep Aquifer, explaining in part that by pumping groundwater and providing it for domestic use, MCWD has perfected appropriative groundwater rights. The Monterey Subbasin is not presently subject to a groundwater basin adjudication or other legal action to enjoin groundwater use. Thus, there is no present legal restriction on MCWD’s ability to extract groundwater for reasonable beneficial use. As such, MCWD would likely establish prescriptive rights in an adjudication, securing MCWD’s domestic supply even under overdraft conditions.

Response 10.19
The commenter requests the amount of groundwater pumped from the Deep Aquifer be provided for each year since 1991, citing stipulations from the 1996 Annexation Agreement and Groundwater Mitigation Framework for Marina Area Lands and the 1998 Water/Wastewater Facilities Agreement, which state that MCWD may increase its withdrawals of potable water by up to 1,400 AFY, from 5,200 AFY to 6,600 AFY for use on Fort Ord.

Please see Response 10.6, Response 10.7, Response 10.9, and Response 10.18 for discussion of the historic use of 6,600 AFY. An overview of the history of groundwater management is provided in the Water Master Response; as described, MCWRA’s role in the management of the Monterey Subbasin dates back to the late 1940s, and MCWRA developed a groundwater management plan in 2006.

Please see the Water Master Response for further discussion of groundwater management in the Plan Area and use of area aquifers.
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Response 10.20
The commenter requests that documents cited in the MCWD 2015 UWMP, which is incorporated by reference to the Draft EIR, be identified by page number in the EIR.

The MCWD 2015 UWMP is incorporated by reference into the Draft EIR, this does not mean that the EIR has an obligation to provide every document imaginable that is referenced in that document (Fort Mojave Indian Tribe v. California Department of Health Services (2008) 38 Cal.App.4th 1574).

However, the City notes that Section 7 of the Draft EIR does provide weblinks to the BRP and its EIR:
https://www.fora.org/BRP.html.

Response 10.21
The commenter claims that the Draft EIR does not provide an assessment of the effect of increased pumping on overdraft, aquifer depletion, lowering groundwater levels, and seawater intrusion, and only focuses on the availability and reliability of the assumed 6,600 AFY supply. The commenter also states that the Draft EIR does not consider the effect of incremental increase in pumping resulting in significant impacts and impeding sustainable groundwater management. Lastly, the commenter states the opinion that Section 4.9 of the Draft EIR discusses water quality standards, altered drainage, and obstruction of a water quality control plan but not contamination from seawater intrusion or incremental groundwater pumping.

Reliance upon the 6,600 AFY allocations is supported by (1) the statutory baseline procedures provided under Pub. Res. Code § 21083.8.1 (Draft EIR Sections 3.3 and 4.16.1), and (2) MCWRA’s Long-Term Management Plan and the groundwater sustainability planning process which are designed to ensure the reliability of the 6,600 AFY (Draft EIR page 4.16-20; Draft EIR Appendix M1, Section 5.3 [“Reliability of Water Supply and the Regional 6,600 AFY Allocation”]). Furthermore, the purpose of CEQA is to analyze impacts in comparison to existing conditions, not to fix existing environmental issues (Watsonville Pilots Association v. City of Watsonville (2010) 183 Cal.App.4th 1059 [“The FEIR was not required to resolve the [existing] overdraft problem, a feat that was far beyond its scope”]). Furthermore, the Draft EIR determined that impacts associated with water supply would be significant without mitigation (Draft EIR Impact UTIL-1).

The commenter also incorrectly alleges that “the focus of analysis in section 4.16 is the availability of a water supply, not the impacts on the groundwater resource of using that supply.” The commenter also faults Section 4.9 for not including discussion of “overdraft, seawater intrusion, falling groundwater levels, or aquifer depletion.” As expressly noted on Draft EIR page 4.9-21: “For the existing conditions of the City’s groundwater supply, and the effects of groundwater demand from development, see Section 4.16.” Section 4.16, Impact UTIL-1 expressly states “If groundwater pumping were to be increased to meet this demand without mitigation, this would potentially result in overdraft and lowered groundwater levels which would lead to seawater intrusion, which would decrease water quality, by increasing salt concentrations (such as chloride, nitrogen, sodium...” Please also see Response 9.2 and Response 10.6.

The commenter is incorrect in stating that the Draft EIR fails to address water quality control/contamination or sustainable groundwater management. To clarify, these topics are addressed throughout Section 4.9 of the Draft EIR, including on pages 4.9-25 through 4.9-27, as noted by the commenter. Responses 9.2 and 10.6 discuss how groundwater management in the Project area has historically occurred in response to water quality concerns regarding seawater intrusion, and that groundwater management in the Project area continues to focus on seawater 3-181 Attachment A
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intrusion. The Water Master Response also provides further discussion of groundwater management in the Project area.

Response 10.22
The comment states “The DEIR is inadequate because it does not discuss the impacts on overdraft, groundwater levels, aquifer depletion, or seawater intrusion caused by increasing the existing levels of groundwater pumping. Nor does the DEIR discuss whether there could be significant direct or cumulative impacts from some level of increased pumping to support new Fort Ord development short of 6,600 afy.”
Section 4.16, Impact UTIL-1 expressly states “If groundwater pumping were to be increased to meet this demand without mitigation, this would potentially result in seawater intrusion, which would decrease water quality, by increasing salt concentrations (such as chloride, nitrogen, sodium...” To the extent the commenter is simply faulting the text for not utilizing the terms “overdraft” and “groundwater levels,” the Draft EIR focused upon the consequences of “overdraft” and lowered “groundwater levels” which would lead to “seawater intrusion, which would decrease water quality, by increasing salt concentrations.” To clarify, the text of Impact UTIL-1 has been revised to state:

If groundwater pumping were to be increased to meet this demand without mitigation, this would potentially result in overdraft and lowered groundwater levels which would lead to seawater intrusion, which would decrease water quality, by increasing salt concentrations (such as chloride, nitrogen, sodium...

Reliance upon the 6,600 AFY allocations is supported by (1) the statutory baseline procedures provided under Pub. Res. Code § 21083.8.1 (Draft EIR Sections 3.3 and 4.16.1, and Response 10.7), and (2) MCWRA’s Long-Term Management Plan and the groundwater sustainability planning process which are designed to ensure the reliability of the 6,600 AFY (Draft EIR page 4.16-20; Draft EIR Appendix M1, Section 5.3 [“Reliability of Water Supply and the Regional 6,600 AFY Allocation”]).

Furthermore, the purpose of CEQA is to analyze impacts in comparison to existing conditions, not to fix existing environmental issues (Watsonville Pilots Association v. City of Watsonville (2010) 183 Cal.App.4th 1059 [“The FEIR was not required to resolve the [existing] overdraft problem, a feat that was far beyond its scope”]).

Accordingly, the Draft EIR uses available published information to characterize potential impacts of the Proposed Project, including with respect to overdraft, groundwater levels, aquifer depletion, and seawater intrusion. The Water Master Response provides detailed discussion of the legal scope of the CEQA analysis for the Proposed Project, as well as discussion of groundwater management with respect to the 6,600-AFY Fort Ord allocation. As described therein, the FORA Allocation should not be understood to be a water right; rather, it is a demand management arrangement; by contrast, the water rights supporting Fort Ord, and now the Ord Community, originate from the common law. Originally, the Army’s right to supply groundwater to Fort Ord arose from federal water rights, among other possible claims. MCWD possesses groundwater rights that it relies on to serve the Ord Community under other doctrines discussed in the Water Master Response.

Responses 9.2 and Response 10.6 also expand upon discussion of the 6,600 AFY. 3-182 Attachment A
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Response 10.23
The commenter requests identification of each management option in Table 4-1 of the MCWRA Long-Term Management Plan that applies to the Fort Ord area and has been approved, funded, and environmentally reviewed pursuant to CEQA.

Reliance upon the 6,600 AFY allocations is supported by (1) the statutory baseline procedures provided under Pub. Res. Code § 21083.8.1 (Draft EIR Sections 3.3 and 4.16.1, and Response 10.7), and (2) MCWRA’s Long-Term Management Plan and the groundwater sustainability planning process which are designed to ensure the reliability of the 6,600 AFY (Draft EIR page 4.16-20; Draft EIR Appendix M1, Section 5.3 [“Reliability of Water Supply and the Regional 6,600 AFY Allocation”]).

The Long-Term Management Plan cited by the commenter is discussed on page 4.9-27 of the Draft EIR and is available online (http://salinasrivermanagementprogram.org/ltmp_doc.html). Table 4-1 of the MCWRA Long-Term Management Plan outlines the objectives and actions associated with management of the Salinas River area. As stated in the Draft EIR, those management efforts together with other groundwater management efforts in the area collectively address long-term overdraft and seawater intrusion concerns for the region. The tools for implementation are discussed in Chapter 5 of the LTMP.23 The commenter is also referred to detailed discussion of ongoing water supply projects which are included in Draft EIR Appendix M1, Section 5.3 [“Reliability of Water Supply and the Regional 6,600 AFY Allocation”]. This discussion provides detailed information on the status of these projects, included Appendices A and B to the WSA. Additionally, since the Draft EIR and the WSA were published, revisions have been proposed to expand recycled water treatment capacity of the Pure Monterey Water Project by an additional 2,250 AFY.24 Response 10.24
The commenter requests that SGMA actions and adopted projects that avoid or lessen overdraft, seawater intrusion, and aquifer depletion in the Fort Ord area be identified. The commenter claims that Section 4.19 does not address impacts to groundwater supply, as indicated in Section 4.9.

It is assumed that the commenter’s reference to Section 4.19 is a typo and the commenter intended to refer to Section 4.16, Utilities and Service Systems, of the Draft EIR; there is no Section 4.19. As explained in Responses 10.21 and 10.22, and Draft EIR Section 4.16, Impact UTIL-1 expressly stated “If groundwater pumping were to be increased to meet this demand without mitigation, this would potentially result in seawater intrusion, which would decrease water quality, by increasing salt concentrations (such as chloride, nitrogen, sodium...”
SGMA requirements and actions relevant to the Proposed Project are discussed in Section 4.9 and Section 4.16 of the Draft EIR. As stated on page 4.9-11, MCWD and the Salinas Valley Basin GSA are each GSAs pursuant to SGMA within the Monterey Subbasin. The Plan Area is located within MCWD’s jurisdictional boundaries where MCWD serves as the GSA. Groundwater management activities pursuant to SGMA are required to be completed within specific timeframes that are defined based upon a groundwater basin’s designation by the California DWR. Page 4.9-5 and page

4.16-20 of the Draft EIR state that the Monterey Subbasin is subject to SGMA but is not designated as critically overdrafted [by the DWR]; this means that the Monterey Subbasin’s deadline for 23 The LTMP is available online at:
http://www.salinasrivermanagementprogram.org/documents/ltmp_doc/chapter_5_implementation.pdf 24 Notice of Availability of the Draft Supplemental EIR for Proposed Modifications to the PWM/GWR Project:
https://purewatermonterey.org/wp/wp-content/uploads/Notice-of-Availability-Draft-Supplimental-EIR-Dec-20-2019-Extension-of-PublicReview-Period.pdf 3-183 Attachment A
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implementation of a GSP is in 2020. Also as stated on page 4.9-5 and page 4.16-20 of the Draft EIR, the Salinas Valley GSAs are collectively working to prepare a GSP for the Monterey Subbasin by 2020, in order to achieve sustainability throughout the Salinas Valley Basin by 2040, as required by SGMA. Together, the activities of the MCWRA with those of the SVGSA and the District, implementing GSPs, will curtail future seawater intrusion and ensure sustainable management of the Salinas Valley groundwater supplies.

As demonstrated with the above response, the requested information regarding SGMA requirements and actions is already provided in the Draft EIR and, contrary to the commenter’s assertions, the Draft EIR does thoroughly address groundwater supply. Additionally, the Water Master Response provides further discussion of groundwater management in the area, including the Fort Ord allocation, and the scope of analysis for cumulative effects to groundwater pumping. No revisions to the EIR have been incorporated in response to this comment because the requested information is already contained in the Draft EIR, which is also now supplemented with discussion in the Water Master Response.

Response 10.25
The commenter asks for an explanation if the southern portion of the Monterey Bay Hydrologic Unit (HU) watershed is depicted on the UC Davis Hydrologic Unit Code (HUC) online mapper and, if not, that a map be provided depicting the watershed. The commenter also asks how groundwater pumping outside the Monterey Subbasin and/or the 180/400 Foot Aquifer Subbasin is relevant to cumulative effects, and why the scope of the cumulative analysis did not include the entire Monterey Subbasin and/or the entire 180/400 Foot Aquifer Subbasin. The commenter states that the scope of analysis for cumulative impacts is unjustified, and that the relevant scope of analysis for cumulative impacts to water supply would be “the hydrologically interconnected groundwater basins that provide water supply to the project.”
Many of these comments appear to come from a misunderstanding which started under Comment

10.21 which faults the Section 4.9 for not addressing seawater intrusion. As expressly noted on Draft EIR page 4.9-21 “For the existing conditions of the City’s groundwater supply, and the effects of groundwater demand from development, see Section 4.16.” For discussion of the cumulative scope of the groundwater supply analysis which is referenced in Section 4.9, please see Draft EIR Section

4.16.9(c) and Response 10.28.

The extent of cumulative analysis suggested by the commenter would require regional hydrologic modelling, which is well beyond the scope of analysis for CEQA. Rather, as stated on page 4.9-27 of the Draft EIR, the geographic scope for cumulative hydrology and water quality impacts is the southern portion of the Monterey Bay HU, from the slopes of the Fort Ord National Monument on the east to the Pacific Ocean on the west; this portion of the watershed encompasses the cities of Marina, Sand City, Seaside, and Monterey. The commenter’s diagram of the Monterey Bay HU watershed is consistent with maps used for the Draft EIR analysis. This geographic scope is appropriate for hydrology and water quality because water quality impacts are localized in the watershed where the impact occurs. Cumulative development within this geographic scope include development envisioned under Draft Seaside 2040, as well as buildout of the City of Marina, City of Sand City, and County of Monterey General Plans. The discussion provided on pages 4.9-27 through

4.9-29 of the Draft EIR is sufficient to determine the geographic scope of the cumulative analysis.

AMBAG’s 2018 Regional Growth Forecast predicts the region will build “just over 42,600 housing units by 2040,” 24,000 of which would be in Monterey County. (See AMBAG 2018 Regional Growth 3-184 Attachment A
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Forecast at pages 6 and 26, available at:
https://ambag.org/sites/default/files/documents/2018_Regional_Growth_Forecast_PDFA.pdf.) However, cumulative quantitative growth rates are not necessary to determine significance because existing regulatory requirements under the MS4 permits requires all new development to provide on-site stormwater retention. These permits require drainage systems allowing for infiltration of the 85th percentile 24-hour storm runoff event, and in many instances for previously developed sites, will reduce overall stormwater flows and associated existing water quality issues. (See Draft EIR at page 7-21, NPDES General Permit No. 2013-0001-DWQ. Waste Discharge Requirements for Storm Water Discharges from Small Municipal Separate Storm Sewer Systems (MS4s) (General Permit) at page 53, available at
https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/phsii2012_5th/order_fi nal.pdf.)
Response 10.26
The commenter states the opinion that the Draft EIR cumulative discussion does not provide information about existing or future groundwater pumping, and requests a list of past, present, and probable future projects in a summary of projections that describes regional or areawide groundwater pumping conditions. The commenter requests the existing and projected cumulative groundwater pumping for the relevant subbasins and aquifers be provided.

Many of these comments appear to come from a misunderstanding which started under Comment

10.21 which faults the Section 4.9 for not addressing seawater intrusion. As expressly noted on Draft EIR page 4.9-21, under Impacts HWQ-2 and HWQ-5 “For the existing conditions of the City’s groundwater supply, and the effects of groundwater demand from development, see Section 4.16.” For discussion of the cumulative water demand including past, present and future projects see Draft EIR Table 4.16-1, Marina Coast Water District Projected Cumulative Water Demand – Ord Community, which are based upon historic water consumption and projected water use in the Urban Water Management Plan (Draft EIR page 4.16-3; Draft EIR Appendix M1, Section 3.2.) The commenter is incorrect in stating that the cumulative analysis discussion in the Draft EIR does not include information about present or future groundwater pumping. Rather, the characterization of cumulative impacts for the provided in Section 4.9 of the Draft EIR accounts for the types of activities in the cumulative area that could result in cumulative impacts to hydrology and water quality. In addition, the commenter requests “existing and projected cumulative groundwater pumping for the Monterey Subbasin Deep Aquifer, Monterey Subbasin ‘upper aquifers,’ 180/400 Foot Aquifer Subbasin Deep Aquifer, 180/400 Foot Aquifer Subbasin ‘upper aquifers.’” The analysis provided in the Draft EIR relies upon known published information, consistent with CEQA requirements.

Response 10.27
The commenter states the cumulative effects analysis does not provide a summary of environmental effects including overdraft, lowered groundwater levels, aquifer depletion, and seawater intrusion; a reasonable analysis of cumulative projects impacts; or an indication of whether there is a significant cumulative effect from all cumulative projects including the Proposed Project. The commenter asks for a separate explanation of whether the Project would make a cumulative contribution to a significant cumulative impact, and states that Mitigation Measure UTIL3-185 Attachment A Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 871, Packet Page 994 City of Seaside
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1 is not sufficient to prevent cumulative impacts. Finally, the commenter asks whether the Draft EIR is tiering from a previous EIR’s cumulative impact discussion and requests explanation.

Many of these comments appear to come from a misunderstanding which started under Comment

10.21 which faults the Section 4.9 for not addressing seawater intrusion. As expressly noted on Draft EIR page 4.9-21, under Impacts HWQ-2 and HWQ-5 “For the existing conditions of the City’s groundwater supply, and the effects of groundwater demand from development, see Section 4.16.” As explained in Response 10.21 and Response 10.22, Draft EIR Section 4.16, Impact UTIL-1 expressly stated “If groundwater pumping were to be increased to meet this demand without mitigation, this would potentially result in seawater intrusion, which would decrease water quality, by increasing salt concentrations (such as chloride, nitrogen, sodium...” This information was cross referenced under the cumulative impact analysis for UTIL-1. Nevertheless, the language on Draft EIR page 4.16- 28 has been revised to state:

Cumulative development in the MCWD service area will continue to increase demands on water supplies. Table 3-3 in the WSA (Appendix M1) shows projected water demands for MCWD through 2035. By 2040, MCWD anticipates a total demand of 10,881 AFY, an increase of 6,677 AFY from the 2015 demands (MCWD 2019). As discussed above under Impact UTIL-1, due to water demands from the project in combination with projected growth, there are insufficient existing water supplies to accommodate cumulative development and achieve full buildout of the Proposed Project, which is projected to demand 441.6 AFY of potable water. This results in a cumulatively considerable contribution to a significant cumulative impact. As discussed under Impact UTIL-1, if groundwater pumping were to be increased to meet this demand without mitigation, this would potentially result in overdraft and lowered groundwater levels which would lead to seawater intrusion, which would decrease water quality, by increasing salt concentrations (such as chloride, nitrogen, sodium). To address the discrepancy between the Proposed Project’s 441.6 AFY of potable water demand and the 181.3 180.6 AFY of available potable water supply, Mitigation Measure UTIL-1 would require the City to implement programs to offset potable supply, thereby making potable supplies available for the demands of the Proposed Project. The City would be required to demonstrate that sufficient water supplies have been secured prior to issuance of final map. With mitigation, impacts related to water supply sufficiency would be less than significant. Therefore, after mitigation, the Proposed Project would not have a cumulatively considerable contribution to a significant cumulative impact regarding water supply services.

Contrary to the commenter’s statements regarding adequacy of the Draft EIR, a thorough and CEQA-sufficient analysis of the cumulative scenario and potential cumulative impacts is provided in the Draft EIR. The Water Master Response provides further definition of the appropriate scope of analysis for CEQA, including with respect to cumulative impacts. As described in Response 10.25, the geographic scope of cumulative analysis defined in the Draft EIR sufficiently accounts for areas that could experience cumulative impacts of the Proposed Project.

The Draft EIR adequately discloses that “due to water demands from the project in combination with projected growth, there are insufficient existing water supplies to accommodate cumulative development and achieve full buildout of the Proposed Project, which is projected to demand 441.6 AFY of potable water. This results in a cumulatively considerable contribution to a significant cumulative impact” (Draft EIR page 4.16-28). However, it was determined that with mitigation implemented for the Proposed Project, the Project’s contribution to the cumulative scenario would not be substantial and cumulative unavoidable impacts would not occur. 3-186
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It should be noted that Draft EIR Mitigation Measure UTIL-1 applies specifically to the Proposed Project, in order to reduce the Project’s contribution of potential impacts to the cumulative scenario; implementation of Mitigation Measure UTIL-1 would effectively minimize the Project’s contribution to the cumulative scenario such that significant unavoidable cumulative impacts would not occur. The Draft EIR does not tier from a cumulative impact discussion in a previous EIR, and is a stand-alone project-specific analysis of impacts of the Proposed Project.

Please see Response 10.6 for discussion of the 6,600 AFY allocation.

Response 10.28
The commenter states the geographic scope in Section 4.16 is unjustified because the relevant scope is hydrologically interconnected groundwater basins that provide water to the Plan Area. The commenter states MCWD is not the only entity extracting water from the aquifers that would affect cumulative water supplies. The commenter states the discussion does not provide sustainability information or cumulative effects of groundwater pumping on overdraft, aquifer depletion, lowering groundwater levels, and seawater intrusion. The commenter states the 1993 Agreement is not a permanent entitlement to 6,600 AFY of groundwater, the 6,600 AFY allocation is not effective or enforceable, there is no discussion of the residential unit cap in the BRP, the constraints on pumping from the 1996 Agreement are not discussed, and groundwater pumping is subject to regulation.

The geographic extent of analysis for cumulative impacts to Utilities was determined by considering the area within which cumulative impacts to utility services could occur; the geographic scope of the MCWD district for the utilities cumulative analysis is appropriate because it encompasses all areas to which MCWD is responsible for providing potable water, including residential, commercial, industrial, and fire protection uses. As the Supreme Court has explained “CEQA… does not require a city or county, each time a new land use development comes up for approval to reinvent the water planning wheel… When an individual land use project requires CEQA evaluation, the urban water management plan’s information and analysis may be incorporated in the water supply and demand assessment” (Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova (2007) 40 Cal.4th 412). As explained in Draft EIR Section 4.16.9(c):

The geographic scope for cumulative water supply impacts is the MCWD service area, depicted in Figure 4.16-1. This geographic scope is appropriate because, as the local water purveyor, MCWD is responsible for supplying potable water to all residential, commercial, industrial, and fire protection uses within its service area, including the Plan Area (MCWD 2016). Development that is considered part of the cumulative analysis includes buildout of local General Plans, as well as development projects identified in the MCWD’s 2015 UWMP and the WSA prepared for the Proposed Project.

The Draft EIR relies on MCWD’s 2015 UWMP for water supply projections and constraints. The UWMP takes into account regional water demands, population growth projections, and groundwater pumpers outside of the service area in its water supply calculations. Therefore, although the geographic scope is limited to MCWD’s service area, it does take into account other water users in the region. The Water Master Response provides a detailed discussion of the 1993 Agreement, the 6,600 AFY Fort Ord allocation, and the 1996 Annexation Agreement and Groundwater Mitigation Framework.
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In addition, please see Response 9.2 and Response 10.6, both of which offer further discussion of the 6,600 AFY. Contrary to the commenter’s statement that the Draft EIR fails to acknowledge that groundwater pumping remains subject to regulation and suspension by multiple agencies and pursuant to SGMA, previous and ongoing groundwater management, including for compliance with SGMA, is discussed on page 4.16-11. The Water Master Response also provides further discussion of groundwater management and applicable agencies in the Plan Area. Please also refer to a detailed discussion of ongoing water supply projects which are included in Draft EIR Appendix M1, Section

5.3 [“Reliability of Water Supply and the Regional 6,600 AFY Allocation”].

The comment states that the Draft EIR fails to disclose constraints on pumping from the Deep Aquifer. The Draft EIR discloses that there is a limit of 1,400 AFY of pumping allowed from the Deep Aquifer (Draft EIR page 4.16-3). The WSA cites Section 5.3.1 of the “Water/Wastewater Facilities Agreement” between the FORA and MCWD dated 1998, which provides that “[t]he parties will cooperate on MCWD's increased withdrawal of potable groundwater from MCWD's existing wells in the 900-foot aquifer by up to 1,400 acre-feet per year (afy), in compliance with law, to enable the increased withdrawals from 5,200 afy to 6,600 afy for use in the service area…” Response 10.29
The commenter states that Mitigation Measure UTIL-1 defers the formation of the water offset program without explaining why deferral is needed, does not provide evidence of feasibility, and lacks performance specifications. The commenter asks if the suggested offset projects were approved with the expectation or commitment that its potable water would be replaced with recycled water. The commenter requests identification of environmental review documents for the listed offset program projects, including whether impacts were significant and unavoidable. The commenter recommends modifications to Mitigation Measure UTIL-1 to be a verifiable, permanent, and additive reduction in groundwater pumping.

Contrary to the commenter’s assertion, Mitigation Measure UTIL-1 does not defer mitigation, but rather ensures that the Project would not be implemented without demonstration of sufficient potable water supply. As stated in the content of Mitigation Measure UTIL-1, the City shall demonstrate the required offset of 261 AFY of potable water to MCWD, and the applicant shall obtain written verification from MCWD that sufficient water supplies have been secured. This is sufficient performance specification to ensure effective implementation of Mitigation Measure UTIL-1.

As the commenter notes, the Draft EIR identifies four possible offset projects that may be utilized under Mitigation Measure UTIL-1. It is well settled that an EIR may set forth a “menu” or range of choices of potentially appropriate mitigation measures without committing the lead agency to any one (or more) specific choices prior to further study (Defend the Bay v. City of Irvine (2004) 119 Cal.App.4th 1261, 1275; see also CEQA Guidelines Section 15126.4(a)(1)(B) “measures may specify performance standards which would mitigate the significant effect of the project and which may be accomplished in more than one specified way”). See Response 1.10, for discussion of the status of the in-lieu storage program.

These projects were identified for their potential to be able to accommodate the offset actions described in Mitigation Measure UTIL-1 and, as specified in the mitigation language.

The commenter also asserts “The DEIR claims that there would be no secondary impacts from UTIL1 because ‘the recycled water supply is a pre-existing project that has already been subject to environmental review.’ (DEIR, p. 4.16-22.) Please identify the environmental review document or 3-188 Attachment A
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Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
documents in which each of the four possible offset programs was discussed.” See Draft EIR Appendix M1 for detailed discussion of this issue. As explained in detail Draft EIR Appendix M1, Section 4.2.1:

In 2012, M1W began planning the Pure Water Monterey Groundwater Replenishment Project, which will develop additional sources of water supply and produce advanced treated water for injection into the Seaside Groundwater Basin for indirect potable reuse. The Pure Water Monterey Groundwater Replenishment Project replaces previously planned urban recycled water deliveries to the Monterey Peninsula under RUWAP. M1W approved the Pure Water Monterey Project and an Environmental Impact Report in October 2015. Additional details about the RUWAP and the Pure Water project are provided in Appendix A. In 2016, MCWD and M1W entered into an agreement allowing MCWD to participate in the Pure Water Monterey Project. MCWD is completing construction of the transmission main, which will be used to deliver advanced treated water for both groundwater injection and for urban irrigation, including construction of recycled water mains to the Campus Town Plan Area….

On April 8, 2016, MCWD and M1W entered into an agreement which would provide up to 1,427 AFY of advanced treated water for urban landscape irrigation instead of the tertiary treated recycled water planned under the RUWAP.

Weblinks to the Pure Water Monterey Project were included in Draft EIR Appendix M1, Appendix C:

References. Including a weblink to the EIR for that project: https://purewatermonterey.org/reportsdocs/cfeir/.

In response to the commenter’s assertion that any incremental [groundwater] pumping to support the Project would make a “considerable contribution to significant cumulative impacts,” please see Response 10.22 through Response 10.28, and the Water Master Response for detailed discussion of the context and extent of cumulative impact analyses. As described in the Draft EIR, with implementation of Mitigation Measure UTIL-1 for the Proposed Project, the Proposed Project would not make considerable contribution to significant cumulative impacts to water supply.

Response 10.30
The commenter claims that the Draft EIR does not describe how the Project will be consistent with BRP water supply policies, asks what steps the City has taken to comply with Policies B-1, B-2, and C3, as well as subsequent programs.

As explained on Draft EIR page 4.10-3 “Under FORA's procedures, consistency of legislative land use decision with the BRP is based upon consistency with the provisions of the general plan, certified as consistent with the BRP” (FORA Resolution 04-6, Section 8.01.020(g)). As also explained in the methodology discussion on page 4.10-24 “For an impact to be considered significant, any inconsistency would also have to result in a significant adverse change in the environment not already addressed in the other resource chapters of this EIR.” The commenter cites a number of non-project specific policies. However, it is not the purpose of the Draft EIR to implement the BRP, or to monitor implementation of the BRP as a whole. Rather the purpose of this EIR is the analyze the environmental impacts of the Proposed Project. Please see Response 10.29 and Draft EIR Appendix M1 for discussion of ongoing water supply projects, and the status of those projects. The commenter is also referred to Draft EIR Section 4.9, Section 4.16, and Appendix M1, which discuss ongoing water conservation measures, on-site water 3-189 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 875, Packet Page 998 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
storage/infiltration requirements, recycled/reclaimed water, and long-term water supply planning.

See also Response 10.4 for discussion of the housing cap.

Response 10.31
The commenter states the Draft EIR should discuss the impacts of not building later phases of the Project due to water shortages and requests a discussion of effects of not building the full Project, including a discussion of secondary impacts to public services, utilities, infrastructure, traffic, GHG, emissions, schools, and the jobs/housing balance. The commenter states inconsistency with BRP policies may result in significant impacts.

Please see Draft EIR Section 6.3 for discussion of the No Project Alternative. An EIR need not consider every possible buildout horizon, nor assume that a project is going to fail. CEQA Guidelines Section 15126.6 explains that an EIR is not required to consider every conceivable alternative to a project, but must consider a reasonable range of alternatives. Therefore, it is not necessary to consider a scenario where the Project is not built.

The comment faults the Draft EIR for assuming that the Project will be built as-proposed. Courts have rejected such criticisms. In Village Laguna of Laguna Beach, Inc. v. Board of Supervisors (1982) 134 Cal.App.3d 1022, Petitioners “criticized the EIR for making assumptions about the proposed project but failing to evaluate the environmental consequences if any of the assumptions proved erroneous” (Id. at page 1029). The Court rejected this argument noting that “[a]ppellants are asking more of the EIR than is legally required. The ‘assumptions’ referred to are actually integral portions of the proposed project… The proposed project, which includes the transportation corridor, a preserved Greenbelt and 25 percent affordable housing, was evaluated in the EIR, CEQA requires nothing more” (Id. at page 1030). The court went on to not that the “assumptions” noted by Petitioners “are actually integral portions of the proposed project. If they fail to become reality… we are dealing with a different project” (Id. at page 1030). An EIR need only evaluate the project as proposed (Ibid).

As discussed in Response 10.30, the Draft EIR contains an extensive analysis of the Project’s conformity with the 2004 Seaside General Plan. This analysis concludes that the Project is consistent with the 2004 Seaside General Plan, which is in turn consistent with the BRP. The Project is therefore consistent with the BRP.

Response 10.32
The commenter states that they incorporate by reference comments on the older WSA prepared by MCWD in June 2018. Furthermore, the commenter ignores that a revised WSA was prepared and included in Appendix M1 of the Draft EIR. In fact, many revisions were added to the updated WSA to specifically address comments LandWatch sent to MCWD on the WSA.

The lead agency does not have a duty to respond to non-Project specific materials (Environmental Protection & Information Center v. California Dept. of Forestry and Fire Protection (2008) 44 Cal.4th 459, 484 [“Although CDF has a duty to consider comments by members of the public under the Forest Practice Rules, that duty does not necessarily extend to considering all of the non-Projectspecific secondary materials submitted in support of the comments”]).

The commenter does not explain which issues they still believe are relevant, and it is not the purpose CEQA to provide response to comments on older versions of documents which have been updated (See also Sierra Club v. City of Orange (2008) 163 Cal.App.4th 523, 537 [Comments on the 3-190 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 876, Packet Page 999 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
Notice of Preparation/Initial Study not considered comments on the Draft EIR]). Please also see Response 10.1 through Response 10.31 which address issues similar to those raised in some of the WSA comments submitted to Marina Coast Water District on the old WSA. Please also see Response

11.1 through Response 11.5.
3-191 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 877, Packet Page 1000 June 15, 2018
Board of Directors
Care of Paula Riso, Clerk to the Board
Marina Coast Water District
11 Reservation Road,
Marina, CA 93933
[email protected]
Re: Water Supply Assessment for Campus Town Specific Plan Dear Members of the Board:

I write on behalf of LandWatch Monterey County to object to the proposed adoption of the Water Supply Assessment and Written Verification of Supply for the Campus Town Specific Plan (“WSA”), appearing as item 10c on your June 18, 2018 agenda.

The WSA is flawed because it wrongly assumes 6,600 afy water supply is available for use in the Ord Community. The Board should be familiar with LandWatch’s objections to this blithe assumption, objections that were most recently set out in my February 19, 2018 letter to you, and in hydrologist Timothy Parker’s February 15, 2018 letter, concerning the proposed annexation of Fort Ord parcels. The 6,600 afy supply is not a firm commitment because the Fort Ord Reuse Plan provides that it can only be used if salt water intrusion is not aggravated. Moreover, the 6,600 afy supply is not reflective of baseline use or sustainable yield.

Despite its obligation to disclose the effect on users reliant on the same groundwater source, the WSA fails to acknowledge overwhelming evidence that additional groundwater pumping from either the 400-foot or Deep Aquifer will result in serious adverse effects on other users. As hydrologist Parker has explained, additional pumping would contribute considerably to significant cumulative impacts, including salt water intrusion, falling groundwater levels, and depletion of the Deep Aquifer.

Neither MCWD nor any other agency has yet determined the sustainable yield of the Deep Aquifer, or even determined its actual storage capacity. The WSA cannot claim that the Deep Aquifer is part of a reliable 20-year water supply with no data or analysis.

To our knowledge, MCWD has no concrete plans or commitments to conduct the work that would be necessary to make these determinations. And while the County has recently indicated that it intends to study the question, it has no timeline or resources for this study.
3-192 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 878, Packet Page 1001 June 15, 2018

The WSA fails to acknowledge that recent mapping demonstrates rapid advance of the salt water intrusion front and that the County has ordered a moratorium on additional groundwater pumping from the areas proximate to that front and from the Deep Aquifer. Even if MCWD’s pumping is currently exempted from this moratorium, the WSA fails to consider the likelihood that pumping restrictions may still be imposed by the County’s own authority and/or under SGMA. Accordingly, the conclusion that groundwater will be available for the existing and planned new use over the 20-year horizon cannot be supported without this important qualification.

The WSA fails to disclose that MCWD has no right to use more than 5,400 afy from the 180-foot and 400-foot Aquifers and has committed not to increase its pumping from the Deep Aquifer by more than 1,400 afy over 1996 levels in its 1996 and 1998 agreements with MCWRA and FORA. Thus, for example, the WSA’s claim in Table 4-1 that there is 3,326 afy of pumping capacity available from well 34 in the Deep Aquifer (or from any other interconnected wells) is likely inconsistent with the 1996 and 1998 agreements. The WSA should be revised to explain just how much additional pumping is actually available from the Deep Aquifers in light of the 1996 and 1998 agreements and in light of the limitations on pumping from the 180-foot and 400-foot Aquifers.

Because there is a significant possibility that salt water intrusion may render pumping from MCWD wells in the 400-foot aquifer infeasible within the next 20 years, the WSA’s claimed capacity for wells in the 400-foot Aquifer to serve the Ord community does not reflect a reliable water supply. The WSA’s claims regarding reliability of the supply should be qualified.

LandWatch asks that MCWD modify the WSA to reflect the hydrologic realities and uncertainties of MCWD’s groundwater supply. For too long MCWD, FORA, and its member agencies have simply ignored the fact that the Ord Community has already exhausted the available groundwater supply.

Yours sincerely,
M. R. WOLFE & ASSOCIATES, P.C.

John Farrow
JHF:hs
3-193 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 879, Packet Page 1002 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 11
COMMENTER: John Farrow, M R Wolfe & Associates, P.C.

DATE: June 15, 2018
The commenter incorporates by reference comments on the older WSA prepared by MCWD in June 2018. However, the commenter ignores that a revised WSA was prepared and included in Appendix M1 to the Draft EIR. In fact, many revisions were added to the updated WSA to specifically address comments LandWatch sent to MCWD on the WSA.

The lead agency does not have a duty to respond to non-Project specific materials (Environmental Protection & Information Center v. California Dept. of Forestry and Fire Protection (2008) 44 Cal.4th 459, 484 [“Although CDF has a duty to consider comments by members of the public under the Forest Practice Rules, that duty does not necessarily extend to considering all of the non-Projectspecific secondary materials submitted in support of the comments”]).

The commenter does not explain which issues they still believe are relevant, and it is not the purpose CEQA to provide response to comments on older versions of documents which have been updated (See also Sierra Club v. City of Orange (2008) 163 Cal.App.4th 523, 537 [Comments on the Notice of Preparation/Initial Study not considered comments on the Draft EIR]).

Response 11.1
The commenter states that the WSA wrongly assumes 6,600 AFY of water supply is available, as this is only accurate if salt water intrusion is not aggravated and this supply is not reflective of baseline use or sustainable yield.

Please refer to Response 9.5 regarding seawater intrusion and to Response 9.15 and the Water Master Response for a full discussion of the 1993 Agreement and the 6,600 AFY water supply. As noted therein, the FORA Allocation serves as a limitation to a pre-existing water right. The Draft EIR does not claim the 1993 Agreement constitutes a transfer of water rights. Rather, the 6,600 AFY supply allocation is considered to be a constrained demand for supply augmentation.

Response 11.2
The commenter states that the WSA does not acknowledge evidence that groundwater pumping from the Deep Aquifer would result in adverse effects to other users. The commenter states that the sustainable yield and storage capacity of the Deep Aquifer have not been determined by any agency.

See Response 10.17 for a discussion of groundwater pumping from the Deep Aquifer. As noted therein, were no groundwater supply management actions in place, and groundwater pumping in the Deep Aquifer were increased up to five times the baseline rate, seawater intrusion (the landward flow of groundwater) to the Deep Aquifer would increase. In other words, increasing groundwater production from the Deep Aquifer without managing the area for seawater intrusion will result in seawater intrusion. This message is consistent with the analysis provided in the Draft EIR, which discusses the multiple groundwater management efforts in the Plan Area with respect to how they address the potential for seawater intrusion to occur. 3-194 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 880, Packet Page 1003 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 11.3
The commenter states that recent mapping demonstrates rapid salt water intrusion, that the County has ordered a moratorium on additional groundwater pumping from the Deep Aquifer, that the WSA does not consider the likelihood of pumping restrictions, that MCWD has committed not to increase its pumping from the Deep Aquifer, and that Table 4-1 is likely inconsistent with 1996 and 1998 pumping agreements. Please see Response 10.13, Response10.14, Response 10.15, and Response 10.17 related to seawater intrusion; Response 10.28 regarding ongoing regulatory changes; and Response 10.16, Response10.17, Response10.18, and Response10.28 for discussion of the deep Aquifer.

Response 11.4
The commenter states that because salt water intrusion may render pumping from MCWD wells infeasible, this water supply is not reliable. The WSA’s claims regarding reliability should be qualified.

Please refer to the Water Master Response, Response 10.13, Response10.14, Response 10.15, Response10.17, Response10.19, Response10.22, and Response10.27 for a discussion of seawater intrusion. As noted therein, the Draft EIR adequately discloses the risks of seawater intrusion.

Response 11.5
The commenter requests that the WSA be revised to reflect the hydrologic realities and uncertainties of MCWD’s groundwater supply.

Please refer to Response 10.14, Response 10.16, Response 10.17, Response 10.22, and Response

10.26 for a discussion of water supply availability.
3-195 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 881, Packet Page 1004 Santa Clara ● San Francisco ● Santa Rosa ● Salinas
August 21, 2019
City of Seaside, Economic Development Department
ATTN: Kurt Overmeyer
440 Harcourt Avenue
Seaside, CA 93955
Subject: Comment on the Draft Environmental Impact Report for the Campus Town Specific Plan Dear Mr. Overmeyer:

In 2018, Schaaf & Wheeler prepared the Water Supply Assessment and Written Verification of Supply for the Campus Town Specific Plan, under contract with the Marina Coast Water District.

The District Board of Directors formally approved the report on June 18, 2018, and submitted it to the City for inclusion in the EIR for the specific plan. The published Draft EIR contains two versions of the report in Appendix M, the version approved by MCWD an edited version. Section 4.16.2.b of the Draft EIR explains the two versions as follows:
“Pursuant to SB 610, a WSA was prepared by MCWD (Appendix M2). The original WSA stated the EIR should describe the water offset programs and “the project EIR should clearly describe that intent and the resulting allocation of potable and recycled water supply.” Consistent with this direction, the City of Seaside has prepared an Updated WSA to provide more detailed information on the water offset programs (Mitigation Measure UTIL-1 below) and to correct several minor errors (e.g., incorrect street addresses) and provide additional background information. The Updated WSA is included in the EIR as Appendix M1. See Appendix M1, Summary of Updates to the WSA, for additional information.” The Updated WSA in Appendix M1 was not prepared by Schaaf & Wheeler, and was not reviewed and accepted by the MCWD Board of Directors. The author of the edited document is not identified, and the changes made to the original document are not noted. We ask that the changes to our original report be presented in legal blackline (underline additions and strike-through deletions) so that it is clear to the reader what was revised, and we recommend that the author of the edited version be identified on the title page.

Sincerely,
Schaaf & Wheeler
Andrew A. Sterbenz, PE
Senior Project Manager
Schaaf & Wheeler

CONSULTING CIVIL ENGINEERS
3 Quail Run Circle, Suite 101
Salinas, CA 93907
831-883-4848
FAX 831-758-6328
3-196 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 882, Packet Page 1005 DRAFT

WATER SUPPLY ASSESSMENT AND WRITTEN

VERIFICATION OF SUPPLY

FOR THE

AMENDED MAIN GATE SPECIFIC PLAN
Prepared by

MARINA COAST WATER DISTRICT
and
Schaaf & Wheeler

CONSULTING CIVIL ENGINEERS
August 2018
3-197 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 883, Packet Page 1006

WATER SUPPLY ASSESSMENT AND

WRITTEN VERIFICATION OF SUPPLY

FOR THE

AMENDED MAIN GATE SPECIFIC PLAN
Prepared by

MARINA COAST WATER DISTRICT
Board of Directors
Thomas P. Moore, President
Jan Shriner, Vice-President
William Y. Lee
Howard Gustafson
Herbert Cortez
and
Schaaf & Wheeler

CONSULTING CIVIL ENGINEERS
3 QUAIL RUN CIRCLE, SUITE 101
SALINAS, CA 93907
August 2018
Draft
For Review Only
Andrew A. Sterbenz, P.E.

License No. C 69703
Date: 8/17/2018
3-198 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 884, Packet Page 1007 DRAFT WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan i 8/17/2018
Table of Contents
Summary of Water Supply Assessment .......................................................................................... 5 Section 1 - Introduction ............................................................................................................. 6

1.1 Project Overview .............................................................................................................. 6

1.2 Purpose of Water Supply Assessment .............................................................................. 6

1.3 Project Subject to CEQA.................................................................................................. 7

1.4 Project Requiring a Water Supply Assessment ................................................................ 7

1.5 Requirements of a Written Verification of Supply .......................................................... 7

1.6 Public Water Agency Serving the Project ........................................................................ 8

1.7 Relationship of WSA to MCWD Urban Water Management Plan ................................ 10 Section 2 - Project Description and Water Demands .............................................................. 11

2.1 Project Description ......................................................................................................... 11

2.2 Land Use and Water Demands ....................................................................................... 14

2.2.1 Residential............................................................................................................... 14

2.2.2 Hotel ........................................................................................................................ 14

2.2.3 Retail ....................................................................................................................... 14

2.2.4 Dining ..................................................................................................................... 14

2.2.5 Landscaping ............................................................................................................ 14

2.2.6 Recycled Water Use ................................................................................................ 15

2.2.7 Project Total Water Demands ................................................................................. 15 Section 3 - District Water Demands ........................................................................................ 17

3.1 Historic and Current Water Demands ............................................................................ 17

3.2 Future Demands ............................................................................................................. 18

3.3 Dry-Year Demands ........................................................................................................ 20 Section 4 - Water Supply ........................................................................................................ 22

4.1 Current Water Supply..................................................................................................... 22

4.1.1 Groundwater ........................................................................................................... 22

4.1.2 Desalinated Water ................................................................................................... 24

4.2 Future Water Supply ...................................................................................................... 24

4.2.1 Recycled Water ....................................................................................................... 24

4.2.2 Desalinated Water ................................................................................................... 25

4.2.3 Conservation ........................................................................................................... 25

4.3 Regulatory Permits Necessary for Supply Delivery ...................................................... 25 Section 5 - Supply Sufficiency Analysis ................................................................................. 26

5.1 Comparison of Project Demands to Projected Supply ................................................... 26

5.2 Plans for Acquiring Additional Water Supplies ............................................................. 27

5.3 Reliability of Water Supply............................................................................................ 27

5.4 Effect on Agricultural and Industrial Users Reliant on the Same Source ...................... 28 Section 6 - Conclusions ........................................................................................................... 29

6.1 Sufficiency of Water Supply for the Project .................................................................. 29

6.2 Future Actions ................................................................................................................ 29 3-199 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 885, Packet Page 1008 DRAFT WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan ii 8/17/2018
Appendices
A. Recycled Water Project Details
B. Desalination Project Details
C. References
D. MCWD Board Resolution Approving the Water Supply Assessment for the Monterey Downs Specific Plan
List of Tables
Table i Acronyms Used in this Report ........................................................................................ iii Table ii Units of Measure Used in this Report ............................................................................ iv Table 2-1: Land Use Comparison ................................................................................................ 11 Table 2-2: Summary of Estimated Water Demand ...................................................................... 16 Table 3-1: Water Production by Service Area (AF) ..................................................................... 17 Table 3-2: Water Use within the Seaside-Ord Community (AF) ................................................. 18 Table 3-3: Water Demand Projection by Service Area (AF) ........................................................ 19 Table 3-4: Main Gate Elements compared to Elements in the 2015 UWMP ............................... 20 Table 3-5: Dry Year Demand Projections .................................................................................... 21 Table 4-1: Existing Pumping Capacity ......................................................................................... 23 Table 5-1: FORA Allocations in the Ord Community.................................................................. 26 Table 5-2: City of Seaside Sub-Allocations .................................................................................. 27 List of Figures
Figure 1.1: Marina Coast Water District Service Areas ................................................................. 9 Figure 2.1: 2007 Main Gate Site Plan ........................................................................................... 12 Figure 2.2: 2018 Main Gate Site Plan ........................................................................................... 13 Figure 4.1: Groundwater Basins ................................................................................................... 22 3-200 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 886, Packet Page 1009 DRAFT WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan iii 8/17/2018
Table i. Acronyms Used in this Report
Acronym Description
afy, ac-ft/yr Acre-feet/year
ccf, hcf Hundred cubic feet
gpd Gallons per day
gpcd Gallons per capita day, or gallons per person per day mgd Million gallons per day
sq-ft Square feet
BMP Best management practice
CAW, CalAm California American Water Company
CCR California Code of Regulations
CEQA California Environmental Quality Act
CSUMB California State University – Monterey Bay
CWC California Water Code
DDW SWRCB Division of Drinking Water
DMM Demand management measure
DWR California Department of Water Resources
FORA Fort Ord Reuse Authority
LAFCO Local Agency Formation Commission
M1W Monterey One Water (formerly MRWPCA)
MCWD, District Marina Coast Water District
MCWRA Monterey County Water Resources Agency
MPWMD Monterey Peninsula Water Management District
OMC Ord Military Community
POM Presidio of Monterey
PWM Pure Water Monterey Project
SB California Senate Bill
SRDP Salinas River Diversion Project
SVBGSA Salinas Valley Basin Groundwater Sustainability Agency SVWP Salinas Valley Water Project
SVGB Salinas Valley Groundwater Basin
SWRCB State Water Resources Control Board
UCMBEST University of California Monterey Bay Education, Science and Technology Center
UWMP Urban Water Management Plan
WSA Water Supply Assessment
WVS Written Verification of Supply
3-201 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 887, Packet Page 1010 DRAFT WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan iv 8/17/2018
Table ii. Units of Measure Used in this Report
Unit Equals
1 acre-foot = 43,560 cubic feet
= 325,851 gallons
1 cubic foot = 7.48 gallons
1 CCF = 100 cubic feet
= 748 gallons
1 MGD = 1,000,000 gallons/day
= 1,120 acre-feet / year
3-202 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 888, Packet Page 1011 DRAFT WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan 5 8/17/2018
Summary of Water Supply Assessment
Project: Main Gate Specific Plan, Seaside, California
The Main Gate Specific Plan was adopted by the City of Seaside in 2010. The City is currently amending the adopted specific plan, and has requested that the water supply assessment be updated to reflect the revised project description.

Pursuant to Section 10910 of the California Water Code (CWC), and based on the analysis detailed in this report and the representations by the Project’s proponents, the Marina Coast Water District (the District) has determined that its currently projected water supplies will be sufficient to meet the projected annual water demands of existing and previously approved uses and the implementation of the Main Gate Specific Plan during normal, single-dry, and multipledry years. The Project will add approximately 370.8 acre-feet per year (AFY) of new demand to the District’s Ord Community Service Area, within the City of Seaside. The City has an existing allocation of Salinas Valley Groundwater of 1,012 AFY, and has previously sub-allocated 825.7 AFY to projects, including 149.0 AFY to the original specific plan area, leaving 186.3 AFY available. The City also has the ability to purchase recycled water from the Regional Urban Water Augmentation Project, which is currently under construction. The City may sub-allocate an additional 163 AFY of groundwater supply to meet the projected potable demand, along with

58.8 AFY of recycled water to meet the project’s non-potable demand. The District can supply potable water immediately, and will be able to supply recycled water when the system construction is completed in 2019.

The City has multiple projects under consideration, and does not have sufficient available supply to allocate for all of them. Developments may be phased to use the currently available groundwater supply. The District has two planned water supply projects it intends to implement in the next decade, the Recycled Water Project and the Desalination Project. These two projects are intended to develop 2,400 AFY of new supply for the Ord Community. As these projects come on-line, the Fort Ord Reuse Authority will allocate the supply among the Land Use Jurisdictions in the Ord Community. The initial phase of the Recycled Water Project is under construction, and will supply water starting in 2019.
3-203 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 889, Packet Page 1012 DRAFT WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan 6 8/17/2018
Section 1 - Introduction

1.1 Project Overview
The City of Seaside in Monterey County, California, acting as the lead agency, is preparing an amendment to the Main Gate Specific Plan for a 49-acre project area located within the City of Seaside. The Main Gate Specific Plan was prepared in 2007-2008, and adopted by the City in 2010. The Project is located on the former Fort Ord. Potable water supply for the former Fort Ord is provided by the Marina Coast Water District. Further description of the Project is given in Section 2.0.

The Water Supply Assessment and Written Verification of Supply for the City of Seaside Main Gate Specific Plan was prepared by Byron Buck and Associates in 2007, and it tiered off the analysis in the Marina Coast Water District 2005 Urban Water Management Plan, also prepared by Byron Buck. This updated analysis builds off of the District’s 2015 Urban Water Management Plan (UWMP), which was prepared by Schaaf & Wheeler.

1.2 Purpose of Water Supply Assessment
The California Water Code (§10910 et. seq.), based on Senate Bill 610 of 2001 (SB 610), requires a project proponent to assess the reliability of a project’s water supply as part of the California Environmental Quality Act (CEQA) process. Under the California Government Code (§66473.7), based on Senate Bill 221 of 2001, proposed subdivisions adding 500 dwelling units are also required to receive written verification of the available water supply from the project’s water supplier. This project includes the addition of up to 610 dwelling units, so both a water supply assessment and a written verification of supply are required.

This report is meant to serve as the Water Supply Assessment (WSA) and Written Verification of Supply (WVS) for the Project to meet the California Water and Government Code requirements. This WSA documents the District’s existing and future water supplies for the Project area and compares them to the District’s total projected water demands for the next twenty (20) years.

The SB 610 process requires the following several steps to identify the need and scope of a project’s WSA:

1. Determine whether the project is subject to CEQA.

2. Determine whether the project meets the definition of a “project” per SB 610.

3. Determine the public water agency that will serve the project.

4. Determine whether any current Urban Water Management Plan considers the projected water demand for the project area.
3-204 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 890, Packet Page 1013 DRAFT WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan 7 8/17/2018

5. Determine whether groundwater is used by the public water agency to serve the project area.

1.3 Project Subject to CEQA
CEQA applies to projects for which a public agency is directly responsible, funds, and/or requires the issuance of a permit. The City of Seaside determined that the Project is subject to the requirements of CEQA. An amendment to the adopted Environmental Impact Report (EIR) is currently being prepared.

1.4 Project Requiring a Water Supply Assessment
CWC §10912(a) defines a Project for WSA purposes as including any of the following1:
 a proposed residential development of more than 500 dwelling units;  a proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space;  a mixed-use project that includes one or more of the projects identified in this list;  a project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500 dwelling unit project.

The Main Gate Specific Plan proposes the addition of up to 610 dwelling units and 210,000 square feet of commercial space, so a water supply assessment is required.

1.5 Requirements of a Written Verification of Supply
Government Code §66473.7(b)(1) requires:

The legislative body of a city or county or the advisory agency, to the extent that it is authorized by local ordinance to approve, conditionally approve, or disapprove the tentative map, shall include as a condition in any tentative map that includes a subdivision a requirement that a sufficient water supply shall be available. Proof of the availability of a sufficient water supply shall be requested by the subdivision applicant or local agency, at the discretion of the local agency, and shall be based on written verification from the applicable public water system within 90 days of a request.

The public water system must determine if there is sufficient water supply for the subdivision, as defined in Government Code §66473.7(a)(2): ‘‘Sufficient water supply’’ means the total water supplies available during normal, single-dry, and multiple dry years within a 20- year projection that will meet the projected demand associated with the proposed subdivision, in addition to existing and planned future uses, including, but not limited to, agricultural and industrial uses. 1 There are additional uses that may qualify as a “project” under the CWC, but included here are the applicable categories.
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1.6 Public Water Agency Serving the Project
The Marina Coast Water District, a county water district, serves the City of Marina and the former Fort Ord, which includes portions of the City of Marina, City of Seaside, City of Del Rey Oaks, City of Monterey and unincorporated Monterey County. The District has two service areas, Central Marina and the Ord Community. The Project is located in the Seaside portion of the MCWD Ord Community Service Area (see Figure 1.1).

MCWD provides water and wastewater service to the Ord Community as outlined in the Water/ Wastewater Facilities Agreement between the Fort Ord Reuse Authority (FORA) and MCWD (1998) and as further described in the Assignment of Easements on Former Fort Ord and Ord Military Community, County of Monterey, and Quitclaim Deed for Water and Wastewater Systems, between FORA and MCWD, dated October 24, 2001. MCWD recently submitted an application to the Local Agency Formation Commission of Monterey County (LAFCO) to formally annex the served portions of the Ord Community into the District’s service area and sphere of influence. The portion of the project area west of General Jim Moore Blvd was not included in the LAFCO application, and will require a subsequent application to LAFCO. 3-206 Attachment A
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Figure 1.1: Marina Coast Water District Service Areas
*Proposed Annexation Area is the current Ord Community Service Area 3-207 Attachment A
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1.7 Relationship of WSA to MCWD Urban Water Management Plan The California Urban Water Management Planning Act (§10610 et. seq. of the CWC) requires urban water suppliers providing over 3,000 acre-feet per year (AFY) of water or having a minimum of 3,000 service connections to prepare plans (urban water management plans or UWMPs) on a five-year, ongoing basis. An UWMP must demonstrate the continued ability of the provider to serve customers with water supplies that meet current and future expected demands under normal, single dry, and multiple dry year scenarios. These plans must also include the assessment of urban water conservation measures and wastewater recycling.

Pursuant to Section 10632 of the CWC, the plans must also include a water shortage contingency plan outlining how the water provider will manage water shortages, including shortages of up to fifty percent (50%) of their normal supplies, and catastrophic interruptions of water supply. The Marina Coast Water District is required to prepare Urban Water Management Plans. The District’s most recent Urban Water Management Plan (2015 UWMP) was adopted in June 2016.

The 2015 UWMP projected demands for 20 years through the year 2035.

As provided for in the State law, this WSA incorporates by reference and relies upon many of the planning assumptions and projections of the 2015 UWMP in assessing the water demands of the proposed Project relative to the overall increase in water demands expected within the entire District service area. The 2015 UWMP projected a significant increase in water demand within the Ord Community due to the planned redevelopment of the former Fort Ord, as documented in the Fort Ord Base Reuse Plan, the General Plans of the various land use jurisdictions, and the approved specific plans within the Ord Community. The 2015 UWMP found that the projected Ord Community water demand of 8,293 AFY in year 2035 exceeded the currently available supply of 6,600 AFY. Additionally, because the current water supply within the Ord Community has been allocated among the land use jurisdictions, some jurisdictions maintain a projected surplus, while others have projected shortages. The District is pursuing two water supply projects to address the projected shortfall. First, an urban recycled water system is being constructed, which will provide an initial 600 AFY for landscape irrigation, and ultimately provide up to 1,427 AFY of non-potable supply. Second, a seawater desalination project is proposed to provide up to 1,500 AFY of potable water supply. The District is currently considering alternative groundwater replenishment projects which, if feasible, may replace the desalination portion of the RUWAP.

Projected development within the City of Seaside was accounted for in the 2015 UWMP, spread across entitled areas, approved specific plan areas and remaining areas. The UWMP included the retail and hospitality uses from the 2010 Main Gate Specific Plan, projected to be constructed between the year 2020 and 2025. The projected demand for the site in the 2015 UWMP is 213 AFY.
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Section 2 - Project Description and Water Demands

2.1 Project Description
The Main Gate Specific Plan for the City of Seaside, California, describes the planned development of approximately 49-acres within the former Fort Ord. The land is currently undeveloped, bounded by Highway 1 on the west, 2nd Avenue on the east, 1st Street on the north and Light Fighter Drive on the south.

The original specific plan included a mix of retail, entertainment and visitor-serving uses. Two options for the retail center were included, one centered on an anchor department store and one centered on a multiplex theater. A significant portion of the site is dedicated to parking space. A site plan showing the department store option is at Figure 2.1.

The revised project reduces the retail component, increases the number of hotel rooms and adds a mix of single-family, multi-family and student residential use. The development density is significantly increased. A site plan showing the proposed revision is at Figure 2.2. Table 2-1, below, presents the usage quantities of the two options in the original specific plan and the proposed revision.

Table 2-1: Land Use Comparison
Use Type Unit
Original Plan,
Version 1
Original Plan,
Version 2
Proposed
Revised Plan
Retail SF 368,500 368,500 135,000
Restaurant SF 79,000 79,000 72,000
Department Store SF 120,000
Theater SF 51,500
Hotel Rm 250 250 450
Spa SF 24,000 24,000
Conference Facility SF 27,000 27,000
Landscape AC 10.41 10.41
Single Family Residential DU 160
Multi-Family Residential DU 200
Student Apartment DU 250
Gas Station Pump 16
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Figure 2.1: 2007 Main Gate Site Plan
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Figure 2.2: 2018 Main Gate Site Plan
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2.2 Land Use and Water Demands
The Amended Main Gate Specific Plan consists of several elements including medium- to highdensity residential, retail and visitor serving businesses, as detailed below.

2.2.1 Residential
Single-family residential densities will range from 12 to 20 units per acre for detached lots and attached townhomes. The MCWD 2015 UWMP uses a demand factor of 0.25 acrefeet/year/dwelling unit (AFY/DU) for single-family residential at densities above 8-units/acre.

Multi-family residential units will consist of multi-story apartment buildings and apartments on upper floors of mixed-use commercial buildings. The MCWD 2015 UWMP uses a demand factor of 0.25 AFY/DU for all multi-family residential development. The project also includes student apartments, which are assumed to have the same demand as the multi-family apartments.

The number of units by housing type is initially assumed to be 160 single-family, 200 multifamily and 250 student apartments. The residential water demand is estimated to be 152.5 AFY = (610 DU) x (0.25 AFY/DU).

2.2.2 Hotel
The specific plan includes three hotel sites with at total of 450 rooms. The MCWD demand factor for hotels is 0.17 AFY/room, so the estimated demand for the hotel is 76.5 AFY.

Landscape irrigation is estimated separately, below.

2.2.3 Retail
The specific plan includes 135,000 square-feet of retail space. The plan does not further divide the usage by type, so it is assumed this will be a mix of grocery, markets and dry goods/apparel shops. The MCWD 2015 UWMP uses a demand factor of 0.00021 AFY/SF for general retail.

The estimated water demand for the retail component is 28.4 AFY. Landscape irrigation is estimated separately, below.

The site plan shows one gas station with four pump islands. A typical island has four pumps. For a total of sixteen. MCWD uses a demand factor of 0.1051 AFY/gas pump, so the estimated demand for the gas station is 1.7 AFY. This would include an associated convenience store.

2.2.4 Dining
The specific plan includes 72,000 square-feet of space to be used for restaurants and food incubators. The plan does not further divide the usage by type. The MCWD 2015 UWMP uses a demand factor of 0.00145 AFY/SF for restaurants, for a total of 104.4 AFY. Landscape irrigation is estimated separately, below.

2.2.5 Landscaping
The conceptual site plan includes assumes 3.5 acres of irrigated non-turf landscaping along street frontages and within commercial landscaped areas. A demand factor of 2.1 AFY/AC is used for 3-212 Attachment A
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non-turf landscaping, based on the local evapotranspiration factor of 39 inches/year. The estimated landscaping demand for the specific plan area is 7.4 AFY.

2.2.6 Recycled Water Use
The 2007 WSA did not estimate the potential use of recycled water within the Main Gate Project. MCWD in cooperation with Monterey One Water is currently constructing the Pure Water Monterey Project, a portion of which will provide recycled water for urban use. The City of Seaside intends for the revised project to maximize the use of recycled water. The California Code of Regulations and the California Plumbing Code allow for the use of tertiary-treated and disinfected recycled water for commercial and residential outdoor landscape irrigation, and for water closet and urinal flushing in certain structures. The list of allowable structures excludes single-family residential use, but hotels, apartments and condominiums may all be dual-plumbed to allow toilet flushing with recycled water.

Recycled water demand for residential toilet flushing is estimated as 2,336 gallons/person/year, based on 5 flushes per person per day and 1.28 gallons per flush. Rates by housing type is calculated using the following occupancies:

Multi-family: 3.3 persons/DU x 2,336 gallon/year ÷ 325,851 gal/acre-ft = 0.024 AFY/DU Students: 2.5 persons/DU x 2,336 gallon/year ÷ 325,851 gal/acre-ft = 0.018 AFY/DU Hotel: 1.5 persons/room x 2,336 gallon/year ÷ 325,851 gal/acre-ft = 0.011 AFY/DU Recycled water demand for toilet flushing in commercial establishments is estimated as 5% of the indoor water demand. Note that MCWD requires the use of waterless urinals in all new construction.

Recycled water demand for residential landscaping is estimated at 0.05 AFY/DU, and is applied to single family, multi-family and apartments. Commercial landscaping is included in the 3.5 acres of overall site landscape.

Applying the above factors, the estimated recycled water demand for the specific plan area is

58.8 AFY, leaving a potable water demand of 312 AFY.

2.2.7 Project Total Water Demands
The total water demand projected for the project is 370.8 AFY, as shown in Table 2-2, below.

As stated in Section 2.2.6. Potential Recycled Water Demand reflects residential and nonresidential landscape irrigation and indoor toilet flushing. Use of recycled water requires special certification of irrigation system operators and periodic cross-connection inspections, which should be pointed out in the development conditions of approval. 3-213 Attachment A
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Table 2-2: Summary of Estimated Water Demand
Land Use Quantity Unit
Demand
Factor
(afy/unit)
Potable
(afy)
Recycled
(afy)
Total
Demand
(afy) Notes
A Single Family Homes 160 DU 0.25 32.00 8.00 40.00 1, 2 B Multi-Family Apartments 200 DU 0.25 35.20 14.80 50.00 C Hotel Rooms 0.17 71.55 4.95 76.50 450
D Student apartments 250 DU 0.25 45.50 17.00 62.50 3
E Retail 135,000 SF 0.00021 26.93 1.42 28.35 4, 5
F Restaurant 72,000 SF 0.00145 99.18 5.22 104.40 4, 5
G Gas Station pump 0.1051 1.60 0.08 1.68 6 16
Irrigated Landscape (Non-Turf) 3.5 AC 2.1 7.35 7.35 7
311.96 58.82 370.78
Notes
1 SFR Density ranges from 12 to 30 per acre. Demand factor is the same as multi-family 2 Number of units based on conceptual site plan.
3 Assume apartments with kitchens and not traditional dormitories. 4 Gross suqare footage from conceptual site plan
5 Assume 5% of demand is toilet flushing.
6 Assume 16 pumps based on site plan. Factor from MCWD code of ordinances. 7 Assume all landscaping will be non-turf and irrigated with recycled water 3-214 Attachment A
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Section 3 - District Water Demands

3.1 Historic and Current Water Demands
Table 3-1 shows the District’s water production over the period 2006-2015. The District’s average production over that period was 4,104 AFY, with 1,697 AFY in the Central Marina service area and 2,407 AFY in the Ord Community service area.

Table 3-1: Water Production by Service Area (AF)2
Year Central
Marina
Ord
Community Total
2006 1,786 2,509 4,295
2007 1,622 2,941 4,563
2008 1,833 2,269 4,102
2009 1,962 2,076 4,038
2010 1,744 2,389 4,133
2011 1,698 2,348 4,047
2012 1,814 2,360 4,174
2013 1,467 2,964 4,431
2014 1,619 2,407 4,026
2015 1,420 1,808 3,228
The City of Seaside is served by three water providers: the City’s municipal water system and California American Water serve the portion of the City outside the former Fort Ord, and Marina Coast Water District serves the portion within the former Fort Ord. Within the Ord Community, there are three land use jurisdictions within the City, each separately managing their water supply. Those jurisdictions are the U.S. Army (Presidio of Monterey Annex), California State University, Monterey Bay (CSUMB) and the City of Seaside. Water use within the City of Seaside portion of the Ord Community (excluding CSUMB and U.S. Army) is provided in Table 3-2.
2 Source: 2015 UWMP, Table 4.1
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Table 3-2: Water Use within the Seaside-Ord Community (AF)3

3.2 Future Demands
Table 3-3 shows projected water demands for the District through 2035. The projection is based on Table 3.5 of the 2015 UWMP, with two modifications. The original table included demand projections for the Monterey Downs Specific Plan Area, which was located in Seaside and unincorporated Monterey County. The developer for that project has since withdrawn their planning application, so that project was removed from the demand projection. The 2015 UWMP also assumed that Bayonet/Blackhorse Golf Course would connect to the recycled water project for irrigation supply, so that irrigation demand was included in the demand projection. The City has since decided that the golf course irrigation will remain on well water from the Seaside Groundwater Basin (outside of MCWD), so that irrigation demand was removed from this projection.
3 Source: MCWD Quarterly Water Consumption Reports
Use Category 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 Notes Single family 277.13 244.67 230.47 223.61 236.78 255.68 219.95 172.6 160.69 179.24 1 Multi-family 59.81 59.83 60.25 69.17 66.54 64.4 44.95 48.7 57.89 58.66 2 Commercial 26.2 33.87 65.87 29.58 27.88 16.92 16.64 23.93 22.65 20.75 3 Industrial 0 0 0 0 0 0 0 0 0 0
Institutional/Governmental 71.81 68.13 83.2 62.66 64.81 72.38 25.99 40.55 39.1 22.87 4 Landscape 11.67 10.82 350.44 440.15 271.16 467.58 536.5 147.48 9.3 8.5 5 Agriculture 0 0 0 0 0 0 0 0 0 0
Total 446.62 417.32 790.23 825.17 667.17 876.96 844.03 433.26 289.63 290.02 Notes:

1. Includes Seaside Highlands and Bay View Mobile Home Park

2. Includes Sun Bay Apartments

3. Includes construction meters and all uses not listed elsewhere.

4. All schools (MPUSD, Chartwell, MCL, MCP)

5. Includes only Soper Field and Bayonet/Blackhorse Golf Course. Golf course use was only in years 2010-2015. 3-216 Attachment A
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Table 3-3: Water Demand Projection by Service Area (AF)4 The demand projection for the City of Seaside includes the build-out of two projects, Seaside Resort and The Projects at Main Gate (original), and estimates for the remaining redevelopment parcels within the City. The California Central Coast Veterans Cemetery is located within the City, but the water allocation was provided by the U.S. Army, so it is included in the Army demand projection. Elements of the Main Gate Specific Plan as included in the in the UWMP are compared to the current plan in Table 3-4 (below). As can be seen, the proposed project significantly increases the projected total water demand within the specific plan area. 4 Source: Table 3.5 of the 2015 MCWD Urban Water Management Plan Jurisdiction 2012* 2015** 2020 2025 2030 2035 Notes Allocation U.S. Army 620 633 663 825 825 825 1,577
CSUMB 404 404 442 632 755 779 1,035
Del Rey Oaks 0 0 186 551 551 551 243
City of Monterey 0 0 0 130 130 130 65
County of Monterey 8 52 377 539 539 539 720
UCMBEST 3 3 94 299 515 515 4 230
City of Seaside 657 657 592 783 1,097 1,560 1, 2 1,012
State Parks and Rec. 0 0 12 18 20 25 45
Marina Ord Comm. 264 285 901 1,572 1,702 1,704 3 1,625
Assumed Line Loss 395 348 348 348 348 348 348
Armstrong Ranch 0 0 0 680 680 680 920
Cemex 0 0 0 0 0 500 500
Marina Central 1,823 1,823 2,184 2,491 2,606 2,725 3,020 Subtotal - Ord 2,351 2,382 3,616 5,698 6,482 6,976 5 6,900 Subtotal - Marina 1,823 1,823 2,184 3,171 3,286 3,905 4,440 Total 4,174 4,204 5,800 8,868 9,768 10,881 11,340
*Actual demands from calendar year 2012 used to represent a non-drought year. ** Projected demands. Actual use was lower due to mandatory drought restrictions. 1 Includes Seaside Resort Golf Course use in 2012 and 2015 (temporary use).

2. Revised values shown initalics. Removes Monterey Downs and Golf Course irrigation.

3. Allocation includes 1325 AFY groundwater and 300 AFY existing pilot desalination plant

4. MBEST commented that they may develop up to 230 AFY as soon as the market allows it.

5. Allocation includes 6600 AFY groundwater and 300 AFY existing pilot desalination plant.

Ord Marina
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Table 3-4: Main Gate Elements compared to Elements in the 2015 UWMP5 The demand estimate in Tables 2-2 and 3-4 use a larger demand factor for retail development than in the 2007 WSA. This is because the retail use in the current plan does not specify the type of use (dry goods and apparel vs. grocery or market), so an averaged demand rate is applied.

The non-turf landscape demand factor of 2.1 AFY/acre is used in the current estimate, consistent with the land use plan. The higher demand factor used in 2007 is applicable to turf lawns and playing fields, which are not typical in high-density areas.

3.3 Dry-Year Demands
Section 10631 of the Water Code requires that water demands be estimated for an average water year, a single dry water year and multiple dry water years. As discussed in the District’s 2015 Urban Water Management Plan, the MCWD service area has a cool summer-type Mediterranean climate, with rain occurring in October through May, and advection fog enveloping the coast in the summer in response to inland heating. Due to these cool summer conditions, the area does not experience the significant increases in summer irrigation demands common to areas further inland in the Salinas River Valley. Periods of below normal rainfall do not reduce the coastal fog, resulting in very minor demand fluctuations between average and dry years.

In the 2015 UWMP, the demand increase during a single-dry year or the first of multiple dry years was calculated to be 1%, based on the system demand increase from 2012 to 2013 (start of the recent drought). Due to mandatory water conservation measures, water demands declined in subsequent years, by 12% in the second dry year and 25% in the third dry year. The projected 5 Source: Table C-3, 2015 UWMP
2015 UWMP 2018 Specific Plan
Qty Unit Factor Demand Qty Unit Factor Demand
(afy/unit) (afy) (afy/unit) (afy)
SF Residential (8-15 du/ac) - DU 0.25 0.0 160 DU 0.25 40.0 MF Residential (>15 du/ac) - DU 0.25 0.0 200 DU 0.25 50.0 Student Apartments (>15 du/ac) - DU 0.25 0.0 250 DU 0.25 62.5 Retail 368,500 SF 0.00005 18.4 135,000 SF 0.00021 28.4
Restaurant 79,000 SF Note 1 102.3 72,000 SF 0.00145 104.4 Conference Center 27,000 SF 0.0002 5.4
Spa 24,000 SF 0.0003 7.2
Hotel Rooms 250 RM 0.17 42.5 450 RM 0.17 76.5
Theater 51,500 SF Note 2 11.2
Parks/Landscaping 10.41 AC 2.5 26.0 3.5 AC 2.1 7.4
Gas Station 16.0 Pu 0.1051 1.7
TOTAL 213.0 370.8
Notes:

1. Demand based on 650 in-line food service seats at 0.038 AFY/seat plus 3879 restaurant seats at 0.02 AFY/seat

2. Theater based on 8000 seats at 0.0014 AFY/seat

3. Demand rates for retail and restaurant in the 2018 Plan reflect the standard factors used in the 2015 UWMP. 3-218 Attachment A
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demands during single dry years and multiple dry years are provided in Table 3-5, with the maximum demand being 374.5 AFY. This methodology may over-estimate the savings during mandatory conservation periods if all of the landscape irrigation uses recycled water. Recycled water systems are typically not subject to the same use restrictions as potable supplies.

Table 3-5: Dry Year Demand Projections
MCWD has sufficient supply and well capacity to meet all customer demands during peak (single dry year) conditions.

Average
Year
Single Dry
Year
1st Dry
Year
2nd Dry
Year
3rd Dry
Year
Factor 1.01 1.01 0.88 0.75
Projected Demand (AFY) 370.8 374.5 374.5 326.3 278.1
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Section 4 - Water Supply

4.1 Current Water Supply
The District’s primary source of water supply is the Salinas Valley Groundwater Basin, and it also has a small desalination plant in the Central Marina Service Area. Under the Regional Urban Water Augmentation Project, the District is working to develop recycled water and a larger desalination plant to meet the projected demands of the Ord Community. None of the District’s current supply is purchased under wholesale contract.

4.1.1 Groundwater
The District supplies groundwater from the Salinas Valley Groundwater Basin. In 2016, the California Department of Water Resources (DWR) published an Interim Update to Bulletin 118, California’s Groundwater. Bulletin 118 defines groundwater basin and sub-basin boundaries used for planning and groundwater management. The update reflects changes submitted to and approved by DWR under the Sustainable Groundwater Management Act. Within northern Monterey County, the changes include redefining the boundaries of the Seaside and Corral De Tierra sub-areas to reflect the defined boundary of the adjudicated Seaside Groundwater Basin, and merge the remaining portion of the Seaside sub-area with the Corral de Tierra sub-area (remained the Monterey sub-area). The revised boundaries are shown in Figure 4.1.

Figure 4.1: Groundwater Basins
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All of the District’s wells are located within the Monterey Sub-Basin of the Salinas Valley Groundwater Basin. MCWD has been designated as an exclusive Groundwater Sustainability Agency (GSA) within its LAFCO service area, and it participates in the Salinas Valley Basin GSA as a member of the Advisory Committee. A portion of the District’s Ord Community service area overlays the Seaside Sub-Basin of the Salinas Valley Groundwater Basin, which is an adjudicated basin managed by the Seaside Water Master Board.

Under the “Agreement between the United States of America and the Monterey County Water Resources Agency concerning Annexation of Fort Ord into Zones 2 and 2A of the Monterey County Water Resources Agency, Agreement No. A-06404”, dated September 21, 1993, the District (successor to the United States) may withdraw up to 6,600 acre-feet per year from the Salinas Valley Groundwater Basin for use in the District’s Ord Community service area. Under the “Annexation Agreement and Groundwater Mitigation Framework for Marina Area Lands” dated March 1996, by and between the MCWRA, the Marina Coast Water District, J.G.

Armstrong Family Members, RMC Lonestar, and the City of Marina, the District may withdraw up to 3,020 AFY from the Salinas Valley Groundwater Basin for use in the District’s Central Marina service area. Under that agreement, additional groundwater supply will be made available to the District for use within the Armstrong Ranch and the RMC Lonestar properties north of Marina, if and when the City annexes and develops those areas.

There are three defined aquifers within the Marina Coast Water District service area, the 180- foot, the 400-foot and the 900-foot or Deep Aquifer. The District operates eight wells, with three in Central Marina and five in the Ord Community. The service areas are interconnected for reliability, with meters at the points of connection to facilitate managing the two well-fields to ensure each service area remains within its authorized withdrawal limit. Table 4-1 summarizes the existing pumping capacity of the District wells. As can be seen, the District has sufficient well capacity to meet the maximum day demands with the largest well out-of-service.

Table 4-1: Existing Pumping Capacity
Location Well # Aquifer Estimated Capacity
(AFY) (GPM)
Marina
10 Deep 2,670 1,654
11 Deep 3,561 2,206
12 Deep 3,264 2,022
Ord
29 400 foot 2,885 1,787
30 400 foot 3,624 2,245
31 400 foot 3,625 2,246
34 Deep 3,326 2,000
35 400 foot 3,326 2,000
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4.1.2 Desalinated Water
The District has a desalination plant located near Marina State Beach, which can contribute up to 300 AFY of potable water supply to the Central Marina service area. The plant was constructed in 1997 as a pilot project but is not currently in use. Under a 2006 agreement among the District, Cypress Marina Heights, L.P., Marina Community Partners, L.L.C., and Cypress Knolls, L.L.C., the yield of this plant is dedicated to meeting the needs of the three developments in the Marina portion of the Ord Community service area. The developers may opt to terminate the agreement once new supply available to the Ord Community from the Regional Urban Water Augmentation Project, at which time that supply would revert to Central Marina.

4.2 Future Water Supply
The District is working towards developing new sources of water supply to meet projected demand increases due to redevelopment within the Ord Community, as well as taking actions to address groundwater wells impacted by seawater intrusion. The two major water supply projects described below are (i) reclaimed wastewater, and (ii) desalinated water, which make up the Regional Urban Water Augmentation Project. MCWD is investigating alternative sources of potable supply, which may be less costly than desalination.

4.2.1 Recycled Water
Recycled water refers to sanitary sewage which undergoes treatment and disinfection, typically for non-potable uses such as agricultural and landscape irrigation. The Monterey One Water (M1W, formerly Monterey Regional Water Pollution Control Agency) operates a regional wastewater treatment facility in north Marina and produces reclaimed water for agricultural irrigation in the Castroville area. Through prior agreements with the M1W, the District is entitled to receive recycled water from the regional plant, up to the volume of wastewater generated within the District and sent to the plant. In 2007, MCWD began detailed design of the recycled water distribution system, and has now constructed several portions of the transmission main. In 2012, M1W began planning the Pure Water Monterey Groundwater Replenishment Project, which will develop additional sources of water supply and produce advanced treated water for injection into the Seaside Groundwater Basin for indirect potable reuse. In 2016, MCWD and M1W entered into an agreement allowing MCWD to participate in the Pure Water Monterey Project. MCWD is completing construction of the transmission main, which will be used to deliver advanced treated water for both groundwater injection and for urban irrigation.

Under the initial phase of the project, MCWD will receive up to 600 AFY of advanced treated water for urban irrigation use. In later phases, the project may be expanded and MCWD’s share would increase to 1,427 AFY, which was the amount of non-potable demand in the Ord Community analyzed in the RUWAP EIR.
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4.2.2 Desalinated Water
Given readily available saline and brackish waters near the District’s service area, desalinated water has been considered as another potential water supply. The District’s existing 300 AFY desalination plant is relatively small, but a larger facility to serve the District is planned as a supplemental water supply. The Regional Urban Water Augmentation Project EIR includes a 1,500 AFY desalination facility for the District. The facility was sized to provide 1,200 AFY of new supply to the Ord Community and 300 AFY to Central Marina, allowing the District to retire the existing pilot desalination plant.

4.2.3 Conservation
The Marina Coast Water District has an active water conservation program. Under the District’s water conservation ordinance, all new construction is required to incorporate water saving devices over and above the requirements of the state building code. Additionally, the District has adopted the State’s Model Water Efficient Landscape Ordinance. The District requires developers to install water conserving fixtures during construction, landscapes which require high irrigation are discouraged, and a tiered water rate structure discourages water waste. The District offers rebate incentives to replace less efficient water fixtures, for installing smart irrigation controllers, and for replacing lawns and sprinklers.

The State of California has established a goal of reducing per person water use by 20% by the year 2020, compared to the 2008 baseline demands. Toward that end, the California Building Code was updated in 2010, with the goal of reducing indoor water use to 55 gallons per person per day. In the 2010 UWMP, the District identified a year 2020 conservation target of 117 gallons per person per day (system-wide potable average). It is anticipated that the Main Gate Specific Plan area will meet that goal, based upon the new indoor plumbing fixture codes and the planned use of recycled water to meet non-potable demands. The Specific Plan Area could potentially use 58.8 AFY of recycled water, which is 16% of the projected overall water demand.

4.3 Regulatory Permits Necessary for Supply Delivery
The Marina Coast Water District is a public water system, permitted by the State Water Resources Control Board, Division of Drinking Water, System No. 2710017. The recycled water distribution system is permitted as System No. 2790009. Permits required for the construction and operation of new facilities are obtained on a project-by-project basis. 3-223 Attachment A
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Section 5 - Supply Sufficiency Analysis

5.1 Comparison of Project Demands to Projected Supply
Within the Ord Community, the 6,600 AFY of existing Salinas Valley groundwater supply has been allocated among the land use jurisdictions by the Fort Ord Reuse Authority (FORA), as shown in Table 5-1, below. The municipal jurisdictions (Cities and Monterey County) formally sub-allocate this supply to developments. Until additional water supplies are developed and allocated within the Ord Community, MCWD will only allow new service connections up to the usage totals allocated by the respective jurisdictions. FORA has also formally allocated the recycled water supply from the Phase 1 Recycled Water Project. Those allocations are included in Table 5-1.

Table 5-1: FORA Allocations in the Ord Community
Land Use Jurisdiction
Existing
Groundwater
Allocation
(AFY)
Future
Recycled
Allocation
(AFY)
City of Del Rey Oaks 243 280
City of Marina (Ord) 1,325 345
City of Monterey 65 0
City of Seaside 1,012 453
County of Monterey 710 134
Marina Sphere (existing use) 10 0
CA State Parks and Rec. 45 0
CSU Monterey Bay 1,035 87
Univ. of California MBEST 230 60
U.S. Army 1,577 0
Assumed Line Loss 348 68
Total – Ord Community 6,600 1,427
The City of Seaside has sub-allocated portions of their existing groundwater allocation, as detailed in Table 5-2, including 149.0 AFY to the Main Gate Specific Plan Area. The remaining unallocated supply totals 186.3 AFY, which is sufficient to meet the remaining 163.0 AFY of potable supply required for the specific plan area, assuming that 58.8 AFY of recycled water supply is also provided for non-potable use. The Project may be phased, and the first phase supplied up to the amount currently allocated by the City. The city is currently considering other development projects which require water supply allocations as well. A Water Supply Assessment was recently prepared for the Campus Town Specific Plan, with an estimated total demand of 487.4 AFY. The City has not yet allocated any water supply to that project, and the City does not have sufficient existing water supply to support both specific plans.

The Project is projected to use up to 58.8 AFY of recycled water. The City of Seaside has an allocation of 453 AFY from the Phase 1 Recycled Water Project, which will be available in 3-224 Attachment A
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2019. Once the recycled water distribution system is operational, potable water use that is replaced with recycled water may be reallocated to new projects. Recycled water is planned for use at MPUSD schools for landscapes and play fields (30 to 40 AFY) and within Seaside Highlands for parks and common area landscapes (43.1 AFY).

Table 5-2: City of Seaside Sub-Allocations
Land Use Jurisdiction
Existing
Groundwater
Allocation
(AFY)
City of Seaside
SunBay Apartments 120.0
Brostram Park (Bay View MHP) 84.8
Seaside Highlands 168.5
Seaside Resort 161.4
MPUSD 81.0
Monterey College of Law 2.6
Monterey Peninsula College 9.0
Chartwell School 6.4
Main Gate "Retail Lifestyle Mall" 149.0
American Youth Hostile 5.5
State Parks transfer for AYH -5.5
Seaside Senior Living 40.0
Other Existing Use 3.0
City of Seaside Total 825.7
FORA Allocation 1012.0
City of Seaside Unallocated 186.3

5.2 Plans for Acquiring Additional Water Supplies
Under the provisions of Section 10911 of the California Water Code, if the water supplier concludes that water supplies will be insufficient for the proposed project, the water supplier shall provide its plans for acquiring additional water supplies. The Marina Coast Water District is currently pursuing two water supply projects, the Recycled Water Project and the Desalination Project, which are intended to allow the District to develop 2,400 AFY of new supply to meet the projected Ord Community demand. Detailed descriptions of these projects are provided in Appendices B and C.

5.3 Reliability of Water Supply
The Salinas Valley Groundwater Basin has a large storage volume, and is recharged by the Salinas River, which is augmented by upstream reservoirs managed by MCWRA. Consequently, the aquifer does not experience wide level variations due to climatic conditions. Water levels vary by 20 to 30 feet seasonally, and decline an additional 10 to 20 feet during drought periods.

The District’s demands accounted for less than one percent of the total groundwater pumped from the Salinas groundwater basin in 2015, the latest year reported. Therefore, the District’s 3-225 Attachment A
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supply is considered reliable on a quantity basis. The upper aquifers in the Salinas Valley Groundwater Basin (180-foot aquifer and 400-foot aquifer) along the coast are experiencing high salinity due to seawater intrusion. The District’s wells in Central Marina are in the Deep Aquifer, which has not experienced signs of seawater intrusion and is considered to have reliable quality. In the Ord Community, the District has one well in the deep aquifer and four wells in the upper aquifers, but outside the area currently affected by seawater intrusion. The District is closely monitoring the quality in these wells.

The planned additional sources of supply are recycled wastewater and seawater desalination.

The source of supply for recycled water is wastewater return flows, which originate from indoor water use. Indoor water use is not subject to the same levels of curtailment during drought periods as outdoor water use, so the source of recycled water supply is considered drought-proof.

The SVRP treatment plant operated by the MRWPCA has reliably produced recycled water meeting the requirements of Title 22 for over a decade. Similarly, seawater desalination is considered a reliable source of supply. Reverse osmosis technology is a proven method of desalinating seawater and brackish groundwater.

5.4 Effect on Agricultural and Industrial Users Reliant on the Same Source There are no agricultural water users within the MCWD service area, nor are there industrial users with privately-owned wells. Agricultural users in the Salinas Valley rely on the same basin-wide supply from the Salinas Valley Groundwater Basin, accounting for 92.9% of the groundwater pumping in 2015. In the local area, 12,000 acres of irrigated agriculture are supplied with recycled water from the Castroville Seawater Intrusion Project. These uses are taken into account in the basin planning of the MCWRA and SVBGSA as part of developing a water balance for the Basin. Additional demands in the Central Marina and Ord Community area are not expected to affect the agricultural users, provided that the District groundwater pumping to meet new demands remains consistent with the MCWRA agreements. 3-226 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan 29 8/17/2018
Section 6 - Conclusions

6.1 Sufficiency of Water Supply for the Project
The City of Seaside will have sufficient existing water supply to achieve the complete build-out of the planned Main Gate Specific Plan Area once the recycled water system (currently under construction) is completed in 2019. If the project is phased, the initial phase could proceed using the existing 149 AFY Salinas Valley Groundwater allocation. However, the City has multiple projects under consideration and insufficient supply to approve them all, so they must determine how to prioritize and phase them.

6.2 Future Actions
Section 10911(b) of the Water Code states “The City or County shall include the water assessment provided pursuant to Section 10910, in any environmental document prepared for the Project pursuant to [CEQA].” The City of Seaside will need to adopt this WSA as part of the CEQA environmental review for the proposed Project, including the findings described above.

The City of Seaside may take certain additional actions to guarantee the availability of the water supplies for the Main Gate Specific Plan and other projects under consideration:
 To offset urban irrigation demands within the Seaside portion of the Ord Community with recycled water and then apply the existing potable supply towards the Main Gate and/or Campus Town Specific Plan areas, the project EIR should clearly describe that intent and the resulting allocation of potable and recycled water supply. The Seaside Highlands development was constructed with recycled water mains to supply the landscape irrigation systems. This system is currently fed with potable water, but recycled water will be available within the next few years. Providing recycled water for irrigation of that project would make up to 43.1 AFY6 of potable supply available for reallocation from Seaside Highlands. An additional 10 AFY may be made available by converting the City’s Soper Field sports complex (adjacent to Seaside Highlands) to recycled water.
 The City may require dual-plumbing of buildings to use recycled water for sanitary fixture flushing (toilets and urinals), which will offset potable water demand with recycled water.
 The City may determine that certain sub-allocation areas are fully developed, and reallocate the unused portion of existing allocations to a new project. In doing this, the 6 The City of Seaside water allocation to the Seaside Highlands project states that 43.1 AFY of irrigation demand will be converted to recycled water when it becomes available. 3-227 Attachment A
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City should use the maximum water use from the last 10 years as the basis of comparison.
 The City may enter into an agreement with another land-use jurisdiction in the Ord Community to allocate currently unused water supply to a portion of this Project. 3-228 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan A-1 August 2018
Appendix A: Recycled Water Project Details
In 2004-2005, the District prepared engineering studies for the Regional Urban Water Augmentation Project (RUWAP). This project was intended to develop 2,400 AFY of additional water supply for the Ord Community, to meet projected demands identified in the Fort Ord Base Reuse Plan. The RUWAP has two components, urban use of recycled water and a desalination facility. The final capacity of the two components may be adjusted during final design, but the total amount of new supply will be 2,400 AFY.

In 2012, the Monterey One Water (M1W, formerly the Monterey Regional Water Pollution Control Agency) and the Monterey Peninsula Water Management District began planning the Pure Water Monterey Groundwater Replenishment Project, which includes the advanced treatment of recycled water for indirect potable reuse. On April 8, 2016, MCWD and M1W entered into an agreement which would provide up to 1,427 AFY of advanced treated water for urban landscape irrigation instead of the tertiary treated recycled water planned under the RUWAP. The Pure Water Monterey Project required a pipeline running parallel to MCWD’s planned RUWAP pipeline, so the agencies agreed to share a single pipeline, realizing a cost savings to each project.

1. Source of Supply: Tertiary treated wastewater available at the MRWPCA Regional Wastewater Treatment Plant in North Marina. Under the annexation agreement between MCWD and MRWPCA, the District has the right to purchase recycled water, subject to annual and seasonal limits. The Advanced Water Purification Facility (AWPF) is currently being constructed, with a design capacity of 5.0 mgd. The plant will produce advancedtreated recycled water meeting the Title 22 standards for indirect potable reuse (injection into a groundwater aquifer and recovery at other wells).

2. Expected Supply Capability: The Phase 1 project will have an initial yield of 4,100 AFY, of which 600 AFY would be available to MCWD. The remaining 3,500 AFY would be conveyed to an injection wellfield in the Ord Community and stored in the Seaside Groundwater Basin. Future Phases of the project will increase MCWD’s yield to 1,427 AFY.

3. Project Facilities:
o Advanced water purification facility and pump station, located within the M1W plant in North Marina
o Product water transmission and distribution pipelines within Marina and the Ord Community
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o Recycled water storage tank within the Ord Community

4. Historical Record:
o MCWD operated a recycled water system from 1996 to 1998. Thereafter the Marina Wastewater Treatment Plant was retired and the local sanitary sewer system was connected to the Regional wastewater collection system. o MCWD prepared engineering studies for the Regional Urban Water Augmentation Project (RUWAP), which included a recycled water component. The District approved the CEQA EIR for the RUWAP in 2005, and amended the findings in 2006 and 2007 as detailed planning progressed.
o In 2004, MCWD published standards for recycled water infrastructure and began requiring the construction of recycled water pipelines in new subdivisions. o MCWD constructed 3.5 miles of recycled water pipelines within the Ord Community during on-going road construction projects, in cooperation with the Fort Ord Reuse Authority and California State University Monterey Bay. o MCWD is currently constructing the shared product water transmission main and storage reservoir. The transmission main connects the AWPF in north Marina to the injection wellfield in Seaside.
o M1W is currently constructing the Pure Water Monterey AWPF and the injection wellfield.
o MCWD is currently completing design of the recycled water distribution system, which connects customers to the transmission system.
o MCWD obtained a pipeline easement for the recycled water main across the Armstrong Ranch in 2007. MCWD obtained a pipeline easement from the City of Seaside for the recycled water main from Normandy Ave to the water tank site in 2010. The District obtained ownership of the recycled water tank site in 2010 (previously held as an exclusive easement). MCWD finalized the recycled water main easements with the Presidio of Monterey in 2012. MCWD finalized the recycled water main easements with CSUMB in 2018.

5. Written Contracts and Agreements:
o In the annexation agreement between MCWD and MRWPCA, MCWD retained the right to obtain recycled water in an amount not to exceed the volume of wastewater flows originating from the District.
o MCWD entered into an agreement with the Fort Ord Reuse Authority in 2005 to develop the RUWAP water supplies.
o MCWD executed two memoranda of understanding with MRWPCA and MCWRA (one in 2009 and one in 2010) to work cooperatively towards the RUWAP, and to specify quantities, (seasonal) availability, and roles and responsibilities. o MCWD entered into the Pure Water Delivery and Supply Project Agreement with M1W in 2016 to participate in the Pure Water Monterey Project and receive advanced 3-230 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan A-3 August 2018
treated water instead of tertiary treated and disinfected recycled water for the RUWAP.
o In agreements with developers of new subdivisions for the construction of water infrastructure, the District requires the installation of recycled water pipelines for the irrigation of public and commercial landscapes.

6. Estimated Costs and Financing: The Pure Water Monterey Project overall cost is estimated at approximately $70 million. This includes both the MCWD and M1W Facilities. Both agencies have received State Revolving Fund Loans to cover a majority of the construction costs. The Fort Ord Reuse Authority has budgeted $37 million for the Regional Urban Water Augmentation Project. A portion of that funding will be applied to this project.

7. Timeframes: The District began constructing recycled water pipelines in conjunction with road construction projects by other jurisdictions (Fort Ord Reuse Authority and CSU Monterey Bay) and private developers beginning in 2004. Construction of the transmission main and water tank is on-going, and projected to be complete by November 2018.

Construction of the AWPF and injection wellfield is on-going and projected to be complete by early 2019.

8. Federal, State and Local Permits for Construction:
o The project is subject to the California Environmental Quality Act (CEQA) and also the National Environmental Policy Act (NEPA) because the SVRP facility is partially funded by the U.S. Department of the Interior, Bureau of Reclamation. The CEQA EIR for the RUWAP Phase 1 Project with supporting NEPA studies has been completed. CEQA actions for a future RUWAP Phase 2 expansion have not been initiated.
o The CEQA EIR for the Pure Water Monterey Project with supporting NEPA studies has been completed.
o The project pump stations and pipelines are outside the Coastal Zone and therefore a Coastal Commission Permit is not required.
o Encroachment permits and easements for pipeline construction have been coordinated with the City of Marina, the City of Seaside, CSU Monterey Bay, Monterey Peninsula Unified School District and the Presidio of Monterey (Ord Military Community). o A Monterey County Conditional Use Permit was obtained for the pipeline crossing agricultural land (Armstrong Ranch).
o M1W has obtained a Water System Permit with the California State Water Resources Control Board, Division of Drinking Water for the advanced treated water system. o The District’s Water System Permit with the California State Water Resources Control Board, Division of Drinking Water will need to be updated to include the recycled water distribution system before the system can be placed into operation. 3-231 Attachment A
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The Title 22 Engineering Report for that addition has been submitted and a recycled water system number has been assigned.
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Marina Coast Water District Amended Main Gate Specific Plan B-1 August 2018
Appendix B: Desalination Project Details
In 2004-2005, the District prepared engineering studies for the Regional Urban Water Augmentation Project (RUWAP). This project was intended to develop 2,400 AFY of additional water supply for the Ord Community, to meet projected demands identified in the Fort Ord Base Reuse Plan. The RUWAP has two components, urban use of recycled water and a desalination facility. The final capacity of the two components may be adjusted during final design, but the total amount of new supply will be 2,400 AFY.

The Desalination Project was originally studied as a stand-alone facility, located at the former Fort Ord Wastewater Treatment Plant. In 2008, the District began working cooperatively with California American Water, which was planning a larger desalination facility to serve their Monterey Service Area (adjacent to the Ord Community). The two agencies jointly planned a Regional Desalination Facility to be located in North Marina adjacent to the MRWPCA Regional Wastewater Treatment Plant. This location facilitated the use of the existing wastewater outfall pipeline for brine disposal from the desalination plant. In 2011, the agreement between MCWD, American Water and Monterey County Water Resources Agency was terminated. MCWD is now pursuing a smaller desalination facility, as sized in the RUWAP EIR, located on the North Marina site.

The following details are provided as required per Water Code §10911.

1. Source of Supply: Seawater-intruded groundwater in the 180-foot aquifer of the Salinas Valley Groundwater Basin, Pressure Sub-Area. Source wells will capture seawater within the aquifer which is currently migrating inland.

2. Expected Supply Capability: 1,500 AFY (average annual yield). Of this total, 1,200 AFY would be for the Ord Community, and 300 AFY would replace the capacity of the District’s existing pilot desalination plant, which would then be retired.

3. Project Facilities:
o Source wells in the intruded portion of the 180-ft aquifer o A reverse-osmosis desalination plant located in North Marina, o Product water pipeline from the plant to the MCWD service area, o Brine disposal pipeline from the plant to the Monterey One Water effluent disposal pipeline (deep ocean outfall)
o Water storage tanks within the MCWD service area

4. Historical Record:
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o MCWD constructed a pilot desalination plant in Marina in 1996. o MCWD prepared engineering studies for the Regional Urban Water Augmentation Project (RUWAP), which included a seawater desalination component. o The District approved the CEQA EIR for the RUWAP in 2005, and amended the findings in 2006 and 2007 as detailed planning progressed. o CAWC prepared engineering studies for the Coastal Water Project (CWP) in 2005- 2008, which included a seawater desalination facility, and submitted a CEQA EIR to the California Public Utilities Commission in 2009.
o MCWD and CAWC worked cooperatively to develop a regional desalination facility as an alternative to two separate facilities, as reflected in the CWP EIR. o The CPUC approved the CWP EIR in 2010.
o The Water Purchase Agreement was terminated by CAWC in September 2011. o MCWD issued an RFQ for Design-Build Services for the Desalination Project in September 2012, but did not award a contract. The project was placed on hold to focus on the recycled water project

5. Written Contracts and Agreements:
o MCWD entered into an agreement with the Fort Ord Reuse Authority in 2005 to develop the RUWAP water supplies.
o MCWD entered into an option agreement with the Armstrong Family Trust in 1998 to purchase land for a future water facility. The District executed that option in 2010 for the Regional Desalination Facility site.
o MCWD entered into an agreement with MRWPCA in 2009 for shared use of the effluent disposal pipeline.
o MCWD, CAWC and MCWRA entered in the Water Purchase Agreement in 2010.

This agreement established project responsibilities between the three agencies. This agreement was terminated by CAWC in September 2011.

6. Estimated Costs and Financing: The Regional Desalination Project is estimated to cost approximately $80 million. The District will pursue State and Federal grants for portions of the project cost. The Fort Ord Reuse Authority has budgeted $37 million for the Regional Urban Water Augmentation Project. A portion of that funding will be applied to this project.

7. Timeframe: Preliminary studies are complete. Assuming a traditional design-bid-build delivery model, it would take from 4 to 6 years to complete design, permitting and construction.

8. Federal, State and Local Permits for Construction:
o The project is subject to the California Environmental Quality Act (CEQA) and also the National Environmental Policy Act (NEPA) because the facility may be partially funded by the U.S. Department of the Interior, Bureau of Reclamation. CEQA EIRs 3-234 Attachment A
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with supporting NEPA studies for the RUWAP Desalination Project and for the Regional Desalination Project have been completed. The RUWAP EIR must be amended to reflect the new MCWD facility location and brine disposal method. o A Coastal Development Permit from the California Coastal Commission may be required for some project facilities if brackish water source wells are located in the Coastal Zone.
o Encroachment permits for pipelines will be required from Monterey County, City of Marina, and possibly CALTRANS.
o MCWD must amend their Water System Permit with the California Department of Public Health to add the desalination facility as a new source of supply before the system can be placed into operation.
o A Regional Water Quality Control Board discharge permit (NPDES) for the desalination plant will be required.
o A Monterey County Building Permit will be required for the desalination plant o A permit from the Monterey Bay Unified Air Pollution Control District will be required for the desalination facility
o Monterey County Environmental Health must approve permits for (1) construction of the groundwater wells, and (2) construction of the desalination facility 3-235 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan C-1 August 2018
Appendix C: References
California American Water Company:

Coastal Water Project, Final Environmental Impact Report, prepared for the California Public Utilities Commission, October 2009
CalAm Monterey Peninsula Water Supply Project, Final Environmental Impact Report, prepared for the California Public Utilities Commission, March 2018 California Department of Water Resources:
20x2020 Water Conservation Plan, February 2010.

Bulletin 118: California’s Groundwater, Interim Updated 2016, December 2016 California Irrigation Management Information System (CIMIS) website, www.cimis.water.gov
Guidebook for Implementation of Senate Bill 610 and Senate Bill 221 of 2001, October 8, 2003.
2015 Urban Water Management Plan Guidebook for Urban Water Suppliers, March 2016.

Model Water Efficient Landscape Ordinance, July 15, 2015 California Urban Water Conservation Council, Memorandum of Understanding Regarding Urban Water Conservation in California, As Amended June 9, 2010 California Building Standards Commission, 2016 California Plumbing Code, with 2018 Supplement
Carollo Engineers, Marina Water Systems Master Plan, February 2007.

City of Seaside:
2009-2014 Housing Element, adopted August 2010
Redevelopment Agency of the City of Seaside, Implementation Plan, 2007 – 2012, Seaside-Fort Ord Redevelopment Project Area, January 17, 2008 The Projects at Main Gate Specific Plan, adopted August 2010 City Council Resolution dated May 15, 2008, allocating 149.0 AFY to the Retail Lifestyle Mall component of the Projects at Main Gate
County of Monterey, 2010 Monterey County General Plan, October 26, 2010 3-236 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan C-2 August 2018
Denise Duffy & Associates:

Draft Environmental Impact Report, Pure Water Monterey Groundwater Replenishment Project. April 2015.

Final Environmental Impact Report, Pure Water Monterey Groundwater Replenishment Project. January 2016.

Denise Duffy & Associates in association with RBF Consulting:

Draft Environmental Impact Report Regional Urban Water Augmentation Project. June 2004.

Final Environmental Impact Report Regional Urban Water Augmentation Project.

September, 2004.

Fort Ord Reuse Authority:

Capital Improvement Program, FY 2017/18 through Post FORA, June 2017.

Fort Ord Reuse Plan, 1996.

Reuse Plan EIR, 1997.

Harding ESE, Final Report, Hydrogeologic Investigation of the Salinas Valley Basin in the Vicinity of Fort Ord and Marina, Salinas Valley, California, prepared for the Monterey County Water Resources Agency, April 2001
Keyser Marston Associates, Inc., Implementation Plan for the Fort Ord Redevelopment Project Area, Prepared for the Redevelopment Agency of Monterey County, March 2007 LAFCO of Monterey County, Municipal Services Review for the Monterey Peninsula, 2006 Marina Coast Water District:
2015 Urban Water Management Plan, prepared by Schaaf & Wheeler, Consulting Civil Engineers, June 2016.
2017 Consumer Confidence Report for Central Marina and Ord Community, April 2018 Pure Water Delivery and Supply Project Agreement between Monterey Regional Water Pollution Control Agency and Marina Coast Water District, April 8, 2016.

Water Supply Assessment and Written Verification of Supply for the City of Seaside Main Gate Specific Plan, prepared by Byron Buck & Associates, November 2, 2007.

Quarterly Water Consumption Report, period ending: December 31, 2017.

Monterey County Water Resources Agency:
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2015 Groundwater Extraction Summary Report, April 2017.

Agreement between the United States of America and the Monterey County Water Resources Agency concerning Annexation of Fort Ord into Zones 2 and 2A of the Monterey County Water Resources Agency, Agreement No. A-06404, September 21, 1993.

Annexation Agreement and Groundwater Mitigation Framework for Marina Area Lands (1996). Document recorded in the Office of the Monterey County Recorder on August 7, 1996, at Reel 3404 Page 749.

Regional Water Providers Consortium, www.conserveh2o.org/toilet-water-use RHAA, Development Master Plan, California Central Coast Veterans Cemetery, Fort Ord, prepared for the Redevelopment Agency of Monterey County, September 2008.

RMC Water and Environment, MCWD Recycled Water Project Basis of Design Report, 2006 University of California Cooperative Extension, A Guide to Estimating Irrigation Water Needs for Landscape Plantings in California, August 2000
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Marina Coast Water District Amended Main Gate Specific Plan D-1 August 2018
Appendix D: MCWD Board Resolution Approving the Water Supply Assessment for the Monterey Downs Specific Plan
3-239 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 925, Packet Page 1048

WATER SUPPLY ASSESSMENT AND WRITTEN

VERIFICATION OF SUPPLY

FOR THE

AMENDED MAIN GATE SPECIFIC PLAN
Prepared by

MARINA COAST WATER DISTRICT
and
Schaaf & Wheeler

CONSULTING CIVIL ENGINEERS
November 2018
With Errata dated December 10, 2018
3-240 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 926, Packet Page 1049

WATER SUPPLY ASSESSMENT AND

WRITTEN VERIFICATION OF SUPPLY

FOR THE

AMENDED MAIN GATE SPECIFIC PLAN
Prepared by

MARINA COAST WATER DISTRICT
Board of Directors
Thomas P. Moore, President
Jan Shriner, Vice-President
William Y. Lee
Howard Gustafson
Herbert Cortez
and
Schaaf & Wheeler

CONSULTING CIVIL ENGINEERS
3 QUAIL RUN CIRCLE, SUITE 101
SALINAS, CA 93907
November 2018
With Errata dated 12/10/18
3-241 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 927, Packet Page 1050 WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan With Errata 12/10/2018 i 11/20/2018
Table of Contents
Summary of Water Supply Assessment .......................................................................................... 5 Section 1 - Introduction ............................................................................................................. 6

1.1 Project Overview .............................................................................................................. 6

1.2 Purpose of Water Supply Assessment .............................................................................. 6

1.3 Project Subject to CEQA.................................................................................................. 7

1.4 Project Requiring a Water Supply Assessment ................................................................ 7

1.5 Requirements of a Written Verification of Supply .......................................................... 7

1.6 Public Water Agency Serving the Project ........................................................................ 8

1.7 Relationship of WSA to MCWD Urban Water Management Plan ................................ 10 Section 2 - Project Description and Water Demands .............................................................. 11

2.1 Project Description ......................................................................................................... 11

2.2 Land Use and Water Demands ....................................................................................... 14

2.2.1 Residential............................................................................................................... 14

2.2.2 Hotel ........................................................................................................................ 14

2.2.3 Retail ....................................................................................................................... 14

2.2.4 Dining ..................................................................................................................... 14

2.2.5 Landscaping ............................................................................................................ 14

2.2.6 Recycled Water Use ................................................................................................ 15

2.2.7 Project Total Water Demands ................................................................................. 16 Section 3 - District Water Demands ........................................................................................ 17

3.1 Historic and Current Water Demands ............................................................................ 17

3.2 Future Demands ............................................................................................................. 18

3.3 Dry-Year Demands ........................................................................................................ 20 Section 4 - Water Supply ........................................................................................................ 22

4.1 Current Water Supply..................................................................................................... 22

4.1.1 Groundwater ........................................................................................................... 22

4.1.2 Desalinated Water ................................................................................................... 24

4.2 Future Water Supply ...................................................................................................... 25

4.2.1 Recycled Water ....................................................................................................... 25

4.2.2 Desalinated Water ................................................................................................... 25

4.2.3 Conservation ........................................................................................................... 26

4.3 Regulatory Permits Necessary for Supply Delivery ...................................................... 26 Section 5 - Supply Sufficiency Analysis ................................................................................. 27

5.1 Comparison of Project Demands to Projected Supply ................................................... 27

5.2 Plans for Acquiring Additional Water Supplies ............................................................. 29

5.3 Reliability of Water Supply............................................................................................ 29

5.4 Effect on Agricultural and Industrial Users Reliant on the Same Source ...................... 29 Section 6 - Conclusions ........................................................................................................... 31

6.1 Sufficiency of Water Supply for the Project .................................................................. 31

6.2 Future Actions ................................................................................................................ 31 3-242 Attachment A
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Appendices
A. Recycled Water Project Details
B. Desalination Project Details
C. References
D. MCWD Board Resolution Approving the Water Supply Assessment for the Main Gate Specific Plan
E. Memorandum: Errata for the Main Gate and Campus Town Water Supply Assessments List of Tables
Table i Acronyms Used in this Report ........................................................................................ iii Table ii Units of Measure Used in this Report ............................................................................ iv Table 2-1: Land Use Comparison ................................................................................................ 11 Table 2-2: Summary of Estimated Water Demand ...................................................................... 16 Table 3-1: Water Production by Service Area (AF) ..................................................................... 17 Table 3-2: Water Use within the Seaside-Ord Community (AF) ................................................. 18 Table 3-3: Water Demand Projection by Service Area (AF) ........................................................ 19 Table 3-4: Main Gate Elements compared to Elements in the 2015 UWMP ............................... 20 Table 3-5: Dry Year Demand Projections .................................................................................... 21 Table 4-1: Existing Pumping Capacity ......................................................................................... 24 Table 5-1: FORA Allocations in the Ord Community.................................................................. 27 Table 5-2: City of Seaside Sub-Allocations .................................................................................. 28 List of Figures
Figure 1.1: Marina Coast Water District Service Areas ................................................................. 9 Figure 2.1: 2007 Main Gate Site Plan ........................................................................................... 12 Figure 2.2: 2018 Main Gate Site Plan ........................................................................................... 13 Figure 4.1: Groundwater Basins ................................................................................................... 23 3-243 Attachment A
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Table i. Acronyms Used in this Report
Acronym Description
AFY, ac-ft/yr Acre-feet/year
ccf, hcf Hundred cubic feet
gpd Gallons per day
gpcd Gallons per capita day, or gallons per person per day mgd Million gallons per day
sq-ft Square feet
BMP Best management practice
CAW, CalAm California American Water Company
CCR California Code of Regulations
CEQA California Environmental Quality Act
CSUMB California State University – Monterey Bay
CWC California Water Code
DDW SWRCB Division of Drinking Water
DMM Demand management measure
DWR California Department of Water Resources
FORA Fort Ord Reuse Authority
LAFCO Local Agency Formation Commission
M1W Monterey One Water (formerly MRWPCA)
MCWD, District Marina Coast Water District
MCWRA Monterey County Water Resources Agency
MPWMD Monterey Peninsula Water Management District
OMC Ord Military Community
POM Presidio of Monterey
PWM Pure Water Monterey Project
SB California Senate Bill
SGMA Sustainable Groundwater Management Act
SRDP Salinas River Diversion Project
SVBGSA Salinas Valley Basin Groundwater Sustainability Agency SVWP Salinas Valley Water Project
SVGB Salinas Valley Groundwater Basin
SWRCB State Water Resources Control Board
UCMBEST University of California Monterey Bay Education, Science and Technology Center
UWMP Urban Water Management Plan
WSA Water Supply Assessment
WVS Written Verification of Supply
3-244 Attachment A
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Table ii. Units of Measure Used in this Report
Unit Equals
1 acre-foot = 43,560 cubic feet
= 325,851 gallons
1 cubic foot = 7.48 gallons
1 CCF = 100 cubic feet
= 748 gallons
1 MGD = 1,000,000 gallons/day
= 1,120 acre-feet/year (AFY)
3-245 Attachment A
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Summary of Water Supply Assessment
Project: Main Gate Specific Plan, Seaside, California
The Main Gate Specific Plan was adopted by the City of Seaside in 2010. The estimated water demand for the Project was 213 AFY. The Project has not yet been constructed. The City is currently amending the adopted specific plan, and has requested that the water supply assessment be updated to reflect the revised project description.

Pursuant to Section 10910 of the California Water Code (CWC), and based on the analysis detailed in this report and the representations by the Project’s proponents, the Marina Coast Water District (the District) has determined that its currently projected water supplies will be sufficient to meet the projected annual water demands of existing and previously approved uses and the implementation of the Main Gate Specific Plan during normal, single-dry, and multipledry years. The Project will add approximately 250.4 acre-feet per year (AFY) of new demand within the City of Seaside portion of the District’s Ord Community Service Area, which is an increase of 37.4 AFY over the original Project. The City has an existing allocation of Salinas Valley Groundwater of 1,012.5 AFY, and has previously sub-allocated 831.2 AFY to projects, including 149.0 AFY for an initial phase of Main Gate Project, leaving 181.3 AFY available.

The City also has the ability to purchase recycled water from the Regional Urban Water Augmentation Project, which is currently under construction. The City may sub-allocate an additional 101.4 AFY of groundwater supply to meet the amended project demand, or it may allocate up to 38.4 AFY of recycled water for non-potable landscape irrigation, and the remaining 63.1 AFY as potable groundwater. The City may also require the use of recycled water for toilet flushing, converting up to 14.6 AFY of indoor demand from potable to recycled water. The District can supply potable water immediately, and will be able to supply recycled water when the system construction is completed in 2019.

The City has multiple projects under consideration, and does not have sufficient potable and recycled water supply to fully develop all of them. Developments will need to be prioritized or phased so as not to exceed the allocated potable and recycled water supply. The District has two planned water supply projects it intends to implement under the Regional Urban Water Augmentation Project, which is intended to develop 2,400 AFY of new supply for the Ord Community. The Recycled Water Project will deliver up to 1,427 AFY for non-potable use.

The initial phase of the Recycled Water Project is under construction, and will supply water starting in 2019. The Desalination Project will provide up to 1,200 AFY of potable supply to the Ord Community. As these projects come on-line, the Fort Ord Reuse Authority or its successor agency will allocate the supply among the Land Use Jurisdictions in the Ord Community. 3-246 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan With Errata 12/10/2018 6 11/20/2018
Section 1 - Introduction

1.1 Project Overview
The City of Seaside in Monterey County, California, acting as the lead agency, is preparing an addendum to the Main Gate Specific Plan for a 49-acre project area located within the City of Seaside. The Main Gate Specific Plan was prepared in 2007-2008, and adopted by the City in 2010. The Project is located on the former Fort Ord. Potable water supply for the former Fort Ord is provided by the Marina Coast Water District. Further description of the Project is given in Section 2.0.

The Water Supply Assessment and Written Verification of Supply for the City of Seaside Main Gate Specific Plan was prepared by Byron Buck and Associates in 2007, and it tiered off the analysis in the Marina Coast Water District 2005 Urban Water Management Plan, also prepared by Byron Buck. This updated analysis builds off of the District’s 2015 Urban Water Management Plan (UWMP), which was prepared by Schaaf & Wheeler.

1.2 Purpose of Water Supply Assessment
The California Water Code (§10910 et. seq.), based on Senate Bill 610 of 2001 (SB 610), requires a project proponent to assess the reliability of a project’s water supply as part of the California Environmental Quality Act (CEQA) process. Under the California Government Code (§66473.7), based on Senate Bill 221 of 2001, proposed subdivisions adding 500 dwelling units are also required to receive written verification of the available water supply from the project’s water supplier. This project includes the addition of up to 620 dwelling units, so both a water supply assessment and a written verification of supply are required.

This report is meant to serve as the Water Supply Assessment (WSA) and Written Verification of Supply (WVS) for the Project to meet the California Water and Government Code requirements. This WSA documents the District’s existing and future water supplies for the Project area and compares them to the District’s total projected water demands for the next twenty (20) years.

The SB 610 process requires the following several steps to identify the need and scope of a project’s WSA:

1. Determine whether the project is subject to CEQA.

2. Determine whether the project meets the definition of a “project” per SB 610.

3. Determine the public water agency that will serve the project.

4. Determine whether any current Urban Water Management Plan considers the projected water demand for the project area.
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5. Determine whether groundwater is used by the public water agency to serve the project area.

1.3 Project Subject to CEQA
CEQA applies to projects for which a public agency is directly responsible, funds, and/or requires the issuance of a permit. The City of Seaside determined that the Project is subject to the requirements of CEQA. An addendum to the adopted Environmental Impact Report (EIR) is currently being prepared.

1.4 Project Requiring a Water Supply Assessment
CWC §10912(a) defines a Project for WSA purposes as including any of the following1:
 a proposed residential development of more than 500 dwelling units;  a proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space;  a mixed-use project that includes one or more of the projects identified in this list;  a project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500 dwelling unit project.

The Main Gate Specific Plan proposes the addition of up to 620 dwelling units, 280 hotel rooms and 108,000 square feet of commercial space, so a water supply assessment is required.

1.5 Requirements of a Written Verification of Supply
Government Code §66473.7(b)(1) requires:

The legislative body of a city or county or the advisory agency, to the extent that it is authorized by local ordinance to approve, conditionally approve, or disapprove the tentative map, shall include as a condition in any tentative map that includes a subdivision a requirement that a sufficient water supply shall be available. Proof of the availability of a sufficient water supply shall be requested by the subdivision applicant or local agency, at the discretion of the local agency, and shall be based on written verification from the applicable public water system within 90 days of a request.

The public water system must determine if there is sufficient water supply for the subdivision, as defined in Government Code §66473.7(a)(2): ‘‘Sufficient water supply’’ means the total water supplies available during normal, single-dry, and multiple dry years within a 20- year projection that will meet the projected demand associated with the proposed subdivision, in addition to existing and planned future uses, including, but not limited to, agricultural and industrial uses. 1 There are additional uses that may qualify as a “project” under the CWC, but included here are the applicable categories.
3-248 Attachment A
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1.6 Public Water Agency Serving the Project
The Marina Coast Water District, a county water district, serves the City of Marina and the former Fort Ord, which includes portions of the City of Marina, City of Seaside, City of Del Rey Oaks, City of Monterey and unincorporated Monterey County. The District has two service areas, Central Marina and the Ord Community. The Project is located in the Seaside portion of the MCWD Ord Community Service Area (see Figure 1.1).

MCWD provides water and wastewater service to the Ord Community as outlined in the Water/ Wastewater Facilities Agreement between the Fort Ord Reuse Authority (FORA) and MCWD (1998) and as further described in the Assignment of Easements on Former Fort Ord and Ord Military Community, County of Monterey, and Quitclaim Deed for Water and Wastewater Systems, between FORA and MCWD, dated October 24, 2001. MCWD recently submitted an application to the Local Agency Formation Commission of Monterey County (LAFCO) to formally annex the served and entitled portions of the Ord Community service area into the District’s jurisdictional boundaries. The area proposed to be annexed includes the Main Gate Specific Plan area.
3-249 Attachment A
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Figure 1.1: Marina Coast Water District Service Areas
*Proposed Annexation Area is the current Ord Community Service Area 3-250 Attachment A
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1.7 Relationship of WSA to MCWD Urban Water Management Plan The California Urban Water Management Planning Act (§10610 et. seq. of the CWC) requires urban water suppliers providing over 3,000 acre-feet per year (AFY) of water or having a minimum of 3,000 service connections to prepare plans (urban water management plans or UWMPs) on a five-year, ongoing basis. An UWMP must demonstrate the continued ability of the provider to serve customers with water supplies that meet current and future expected demands under normal, single dry, and multiple dry year scenarios. These plans must also include the assessment of urban water conservation measures and wastewater recycling.

Pursuant to Section 10632 of the CWC, the plans must also include a water shortage contingency plan outlining how the water provider will manage water shortages, including shortages of up to fifty percent (50%) of their normal supplies, and catastrophic interruptions of water supply. The Marina Coast Water District is required to prepare Urban Water Management Plans. The District’s most recent Urban Water Management Plan (2015 UWMP) was adopted in June 2016.

The 2015 UWMP projected demands for 20 years through the year 2035.

As provided for in the State law, this WSA incorporates by reference and relies upon many of the planning assumptions and projections of the 2015 UWMP in assessing the water demands of the proposed Project relative to the overall increase in water demands expected within the entire District service area. The 2015 UWMP projected a significant increase in water demand within the Ord Community due to the planned redevelopment of the former Fort Ord, as documented in the Fort Ord Base Reuse Plan, the General Plans of the various land use jurisdictions, and the approved specific plans within the Ord Community. The 2015 UWMP found that the projected Ord Community water demand of 8,293 AFY in year 2035 exceeded the 6,600 AFY supply available under the 1993 USA-MCWRA Zone 2/2A Annexation Agreement. Additionally, because the current water supply within the Ord Community has been allocated among the land use jurisdictions, some jurisdictions maintain a projected surplus, while others have projected shortages. The District is pursuing two water supply projects to address the projected shortfall.

First, an urban recycled water system is being constructed, which will provide an initial 600 AFY for landscape irrigation, and ultimately provide up to 1,427 AFY of non-potable supply.

Second, a seawater desalination project is proposed to provide up to 1,500 AFY of potable water supply. The District is currently considering alternative groundwater replenishment projects which, if feasible, may replace the desalination portion of the RUWAP.

Projected development within the City of Seaside was accounted for in the 2015 UWMP, spread across entitled areas, approved specific plan areas and remaining areas. The UWMP included the retail and hospitality uses from the 2010 Main Gate Specific Plan, projected to be constructed between the year 2020 and 2025. The projected demand for the site in the 2015 UWMP is 213 AFY.
3-251 Attachment A
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Section 2 - Project Description and Water Demands

2.1 Project Description
The Main Gate Specific Plan for the City of Seaside, California, describes the planned development of approximately 49-acres within the former Fort Ord. The land is currently undeveloped, bounded by Highway 1 on the west, 2nd Avenue on the east, 1st Street on the north and Light Fighter Drive on the south.

The original specific plan included a mix of retail, entertainment and visitor-serving uses. Two options for the retail center were included, one centered on an anchor department store and one centered on a multiplex theater. A significant portion of the site is dedicated to parking space. A site plan showing the department store option is at Figure 2.1.

The revised project reduces the retail component, increases the number of hotel rooms and adds a mix of single-family, multi-family and student residential use. The development density is significantly increased. A site plan showing the proposed revision is at Figure 2.2. Table 2-1, below, presents the usage quantities of the two options in the original specific plan and the proposed revision.

Table 2-1: Land Use Comparison
Use Type Unit
Original Plan,
Version 1
Original Plan,
Version 2
Proposed
Revised Plan
Retail SF 368,500 368,500 95,000
Restaurant SF 79,000 79,000 13,000
Department Store SF 120,000
Theater SF 51,500
Hotel Rm 250 250 280
Spa SF 24,000 24,000
Conference Facility SF 27,000 27,000
Landscape AC 10.41 10.41
Single Family Residential DU 140
Multi-Family Residential DU 150
Student Apartment DU 330
Gas Station Pump 16
3-252 Attachment A
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Figure 2.1: 2007 Main Gate Site Plan
3-253 Attachment A
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Figure 2.2: 2018 Main Gate Site Plan
3-254 Attachment A
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2.2 Land Use and Water Demands
The Amended Main Gate Specific Plan consists of several elements including medium- to highdensity residential, retail and visitor serving businesses, as detailed below.

2.2.1 Residential
Single-family residential densities will range from 10 to 15 units per acre for detached lots. The MCWD 2015 UWMP uses a demand factor of 0.25 acre-feet/year/dwelling unit (AFY/DU) for single-family residential at densities above 8-units/acre. Multi-family residential units will consist of multi-story apartment buildings and apartments on upper floors of mixed-use commercial buildings. The MCWD 2015 UWMP uses a demand factor of 0.25 AFY/DU for all multi-family residential development. The project also includes student apartments, which are assumed to have the same demand as the multi-family apartments. The number of units by housing type is initially assumed to be 140 single-family, 150 multi-family and 330 student apartments. The residential water demand is estimated to be 155.0 AFY = (620 DU) x (0.25 AFY/DU).

2.2.2 Hotel
The specific plan includes several hotel sites with a total of 280 rooms. The MCWD demand factor for hotels is 0.17 AFY/room, so the estimated demand for the hotels is 47.6 AFY.

Landscape irrigation is estimated separately, below.

2.2.3 Retail
The specific plan includes 95,000 square-feet of retail space. The plan does not further divide the usage by type, so it is assumed this will be a mix of grocery, markets and dry goods/apparel shops. The MCWD 2015 UWMP uses a demand factor of 0.00021 AFY/SF for general retail.

The estimated water demand for the retail component is 20.0 AFY. Landscape irrigation is estimated separately, below.

The site plan shows one gas station with four pump islands. A typical island has four pumps. For a total of sixteen. MCWD uses a demand factor of 0.1051 AFY/gas pump, so the estimated demand for the gas station is 1.7 AFY. This would include an associated convenience store.

2.2.4 Dining
The specific plan includes 13,000 square-feet of space to be used for restaurants and food incubators. The plan does not further divide the usage by type. The MCWD 2015 UWMP uses a demand factor of 0.00145 AFY/SF for restaurants, for a total of 18.9 AFY. Landscape irrigation is estimated separately, below.

2.2.5 Landscaping
The conceptual site plan includes assumes 3.5 acres of irrigated non-turf landscaping along street frontages and within commercial landscaped areas. A demand factor of 2.1 AFY/AC is used for 3-255 Attachment A
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non-turf landscaping, based on the local evapotranspiration factor of 39 inches/year. The estimated landscaping demand for the specific plan area is 7.4 AFY.

2.2.6 Recycled Water Use
The 2007 WSA did not estimate the potential use of recycled water within the Main Gate Project. MCWD in cooperation with Monterey One Water is currently constructing the Pure Water Monterey Project, a portion of which will provide recycled water for urban use. The City of Seaside intends for the revised project to maximize the use of recycled water. The California Code of Regulations and the California Plumbing Code allow for the use of tertiary-treated and disinfected recycled water for commercial and residential outdoor landscape irrigation, and for water closet and urinal flushing in certain structures. The list of allowable structures excludes single-family residential use, but hotels, apartments, condominiums, retail and dining establishments may be dual-plumbed to allow toilet flushing with recycled water.

MCWD’s current recycled water distribution permit only addresses out door water use for landscape irrigation. Before recycled water may be provided for indoor use, the permit must be updated to add indoor toilet flushing as an approved use, and to document the controls (crossconnection, signage and inspection) required for sites using recycled water indoors. Enforcement of the plumbing code requirements will be the responsibility of the building official of the land use jurisdiction. For this reason, indoor recycled water demand is estimated and presented separately from landscape irrigation.

Recycled water demand for residential toilet flushing is estimated as 2,336 gallons/person/year, based on 5 flushes per person per day and 1.28 gallons per flush. Rates by housing type is calculated using the following occupancies:

Multi-family: 3.3 persons/DU x 2,336 gallon/year ÷ 325,851 gal/acre-ft = 0.024 AFY/DU Students: 2.5 persons/DU x 2,336 gallon/year ÷ 325,851 gal/acre-ft = 0.018 AFY/DU Hotel: 1.5 persons/room x 2,336 gallon/year ÷ 325,851 gal/acre-ft = 0.011 AFY/DU Recycled water demand for toilet flushing in commercial establishments is estimated as 5% of the indoor water demand. Note that MCWD requires the use of waterless urinals in all new construction.

Recycled water demand for residential landscaping is estimated at 0.05 AFY/DU, and is applied to single family, multi-family and apartments. Commercial landscaping is included in the 3.5 acres of overall site landscape.

Applying the above factors, the estimated outdoor (landscape) recycled water demand for the specific plan area is 38.4 AFY, and the indoor (potable) demand is 212.1 AFY. Of the indoor demand, up to 14.6 AFY could be met using recycled water for toilet flushing, potentially reducing the potable demand to 197.5 AFY.
3-256 Attachment A
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2.2.7 Project Total Water Demands
The total water demand projected for the project is 250.4 AFY, as shown in Table 2-2, below.

As stated in Section 2.2.6. Potential Indoor Recycled Water Demand reflects toilet flushing, where allowed, and Landscape Irrigation includes both residential and non-residential landscapes. Use of recycled water requires special certification of irrigation system operators and annual cross-connection inspections, which must be pointed out in the development conditions of approval. The land use jurisdiction may need to update their code of ordinances to reflect the need for annual compliance inspections of dual-plumbed buildings by the health or building official.

Table 2-2: Summary of Estimated Water Demand
Land Use Quantity Unit
Demand
Factor
(afy/unit)
Potable
Demand
(afy)*
Indoor
Recycled
(afy)**
Landscape
Recycled
(afy)
Total
Demand
(afy) Notes
A Single Family Homes 140 DU 0.25 28.00 7.00 35.00 1, 2 B Multi-Family Apartments 150 DU 0.25 30.00 3.60 7.50 37.50 2 C Hotel Rooms 0.17 47.60 3.08 280 47.60
D Student apartments 330 DU 0.25 66.00 5.94 16.50 82.50 3 E Retail 95,000 SF 0.00021 19.95 1.00 19.95 4, 5
F Restaurant 13,000 SF 0.00145 18.85 0.94 18.85 4, 5
G Gas Station pump 0.1051 1.68 0.08 16 1.68 6
Irrigated Landscape (Non-Turf) 3.5 AC 2.1 7.35 7.35 7
212.08 14.64 38.35 250.43
Notes
* Potable calculated as Total Demand minus Landscape Demand ** Indoor Recycled Demand is toilet flushing. Requires dual-piping per the plumbing code. 1 SFR Density ranges from 10 to 15 per acre. Demand factor is the same as multi-family 2 Number of units based on conceptual site plan.
3 Assume apartments with kitchens and not traditional dormitories. 4 Gross square footage from conceptual site plan
5 Assume 5% of demand is toilet flushing.
6 Assume 16 pumps based on site plan. Factor from MCWD code of ordinances. 7 Assume all landscaping will be non-turf and irrigated with recycled water 3-257 Attachment A
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Section 3 - District Water Demands

3.1 Historic and Current Water Demands
Table 3-1 shows the District’s water production over the period 2006-2015. The District’s average production over that period was 4,104 AFY, with 1,697 AFY in the Central Marina service area and 2,407 AFY in the Ord Community service area.

Table 3-1: Water Production by Service Area (AF)2
Year Central
Marina
Ord
Community Total
2006 1,786 2,509 4,295
2007 1,622 2,941 4,563
2008 1,833 2,269 4,102
2009 1,962 2,076 4,038
2010 1,744 2,389 4,133
2011 1,698 2,348 4,047
2012 1,814 2,360 4,174
2013 1,467 2,964 4,431
2014 1,619 2,407 4,026
2015 1,420 1,808 3,228
2016 1,303 1,722 3,025
2017 1,587 1,651 3,238
The City of Seaside is served by three water providers: the City’s municipal water system and California American Water serve the portion of the City outside the former Fort Ord, and Marina Coast Water District serves the portion within the former Fort Ord. Within the Ord Community, there are three land use jurisdictions within the City of Seaside, each separately managing their allocation of water supply. Those jurisdictions are the U.S. Army (Presidio of Monterey Annex), California State University, Monterey Bay (CSUMB) and the City of Seaside. Water use within the City of Seaside portion of the Ord Community (excluding CSUMB and U.S. Army) is provided in Table 3-2.
2 Source: 2015 UWMP, Table 4.1
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Table 3-2: Water Use within the Seaside-Ord Community (AF)3

3.2 Future Demands
Table 3-3 shows projected water demands for the District through 2035. The projection is based on Table 3.5 of the 2015 UWMP, with two modifications. The original table included demand projections for the Monterey Downs Specific Plan Area, which was located in Seaside and unincorporated Monterey County. The developer for that project has since withdrawn their planning application, so that project was removed from the demand projection. The 2015 UWMP also assumed that Bayonet/Blackhorse Golf Course would convert from existing irrigation wells in the Seaside Groundwater Basin to the RUWAP recycled water project, so that irrigation demand was included in the demand projection. The City has since notified MCWD that the golf course irrigation will remain on the existing irrigation wells, so that demand was removed from this projection.
3 Source: MCWD Quarterly Water Consumption Reports
Use Category 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 Notes Single family 277.13 244.67 230.47 223.61 236.78 255.68 219.95 172.6 160.69 179.24 1 Multi-family 59.81 59.83 60.25 69.17 66.54 64.4 44.95 48.7 57.89 58.66 2 Commercial 26.2 33.87 65.87 29.58 27.88 16.92 16.64 23.93 22.65 20.75 3 Industrial 0 0 0 0 0 0 0 0 0 0
Institutional/Governmental 71.81 68.13 83.2 62.66 64.81 72.38 25.99 40.55 39.1 22.87 4 Landscape 11.67 10.82 350.44 440.15 271.16 467.58 536.5 147.48 9.3 8.5 5 Agriculture 0 0 0 0 0 0 0 0 0 0
Total 446.62 417.32 790.23 825.17 667.17 876.96 844.03 433.26 289.63 290.02 Notes:

1. Includes Seaside Highlands and Bay View Mobile Home Park

2. Includes Sun Bay Apartments

3. Includes construction meters and all uses not listed elsewhere.

4. All schools (MPUSD, Chartwell, MCL, MCP)

5. Includes only Soper Field and Bayonet/Blackhorse Golf Course. Golf course use was only in years 2010-2015. 3-259 Attachment A
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Table 3-3: Water Demand Projection by Service Area (AF)4 The demand projection for the City of Seaside includes the build-out of two projects, Seaside Resort and The Projects at Main Gate (original), and estimates for the remaining redevelopment parcels within the City. The California Central Coast Veterans Cemetery is located within the City, but the water allocation was provided by the U.S. Army, so it is included in the Army demand projection. Elements of the Main Gate Specific Plan as included in the UWMP are compared to the current plan in Table 3-4 (below). As can be seen, the proposed project has been scaled so that the indoor water demand matches the estimated water demand in the original specific plan, and the outdoor demand is met using recycled water. 4 Source: Table 3.5 of the 2015 MCWD Urban Water Management Plan Jurisdiction 2012* 2015** 2020 2025 2030 2035 Notes Allocation U.S. Army 620 633 663 825 825 825 1,577
CSUMB 404 404 442 632 755 779 1,035
Del Rey Oaks 0 0 186 551 551 551 243
City of Monterey 0 0 0 130 130 130 65
County of Monterey 8 52 377 539 539 539 720
UCMBEST 3 3 94 299 515 515 3 230
City of Seaside 657 657 592 783 1,097 1,560 1, 2 1,012
State Parks and Rec. 0 0 12 18 20 25 45
Marina Ord Comm. 264 285 901 1,572 1,702 1,704 1,325
Assumed Line Loss 395 348 348 348 348 348 348
Armstrong Ranch 0 0 0 680 680 680 920
Cemex 0 0 0 0 0 500 500
Marina Central 1,823 1,823 2,184 2,491 2,606 2,725 4 3,320 Subtotal - Ord 2,351 2,382 3,616 5,698 6,482 6,976 6,600 Subtotal - Marina 1,823 1,823 2,184 3,171 3,286 3,905 4,740 Total 4,174 4,204 5,800 8,868 9,768 10,881 11,340
*Actual demands from calendar year 2012 used to represent a non-drought year. ** Projected demands. Actual use was lower due to mandatory drought restrictions. 1 Includes Seaside Resort Golf Course use in 2012 and 2015 (temporary use).

2. Revised values shown initalics. Removes Monterey Downs and Golf Course irrigation.

3. MBEST commented that they may develop up to 230 AFY as soon as the market allows it.

4. Allocation includes 3020 AFY groundwater and 300 AFY existing pilot desalination plant.

Ord Marina
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Table 3-4: Main Gate Elements compared to Elements in the 2015 UWMP5 The demand estimate in Tables 2-2 and 3-4 use a larger demand factor for retail development than in the 2007 WSA. This is because the retail use in the current plan does not specify the type of use (dry goods and apparel vs. grocery or market), so an averaged demand rate is applied.

The non-turf landscape demand factor of 2.1 AFY/acre is used in the current estimate, consistent with the land use plan. The higher demand factor used in 2007 is applicable to turf lawns and playing fields, which are not typical in high-density areas.

3.3 Dry-Year Demands
Section 10631 of the Water Code requires that water demands be estimated for an average water year, a single dry water year and multiple dry water years. As discussed in the District’s 2015 Urban Water Management Plan, the MCWD service area has a cool summer-type Mediterranean climate, with rain occurring in October through May, and advection fog enveloping the coast in the summer in response to inland heating. Due to these cool summer conditions, the area does not experience the significant increases in summer irrigation demands common to areas further inland in the Salinas River Valley. Periods of below normal rainfall do not reduce the coastal fog, resulting in very minor demand fluctuations between average and dry years.

In the 2015 UWMP, the demand increase during a single-dry year or the first of multiple dry years was calculated to be 1%, based on the system demand increase from 2012 to 2013 (start of 5 Source: Table C-3, 2015 UWMP
2015 UWMP 2018 Specific Plan
Qty Unit Factor Demand Qty Unit Factor Demand
(afy/unit) (afy) (afy/unit) (afy)
SF Residential (8-15 du/ac) - DU 0.25 0.0 140 DU 0.25 35.0 MF Residential (>15 du/ac) - DU 0.25 0.0 150 DU 0.25 37.5 Student Apartments (>15 du/ac) - DU 0.25 0.0 330 DU 0.25 82.5 Retail 368,500 SF 0.00005 18.4 95,000 SF 0.00021 20.0
Restaurant 79,000 SF Note 1 102.3 13,000 SF 0.00145 18.9 Conference Center 27,000 SF 0.0002 5.4
Spa 24,000 SF 0.0003 7.2
Hotel Rooms 250 RM 0.17 42.5 280 RM 0.17 47.6
Theater 51,500 SF Note 2 11.2
Parks/Landscaping 10.41 AC 2.5 26.0 3.5 AC 2.1 7.4
Gas Station 16 Pu 0.1051 1.7
TOTAL 213.0 250.4
Notes:

1. Demand per 2007 WSA: 650 in-line food service seats at 0.038 AFY/seat plus 3879 restaurant seats at 0.02 AFY/seat

2. Theater based on 8000 seats at 0.0014 AFY/seat

3. Demand rates for retail and restaurant in the 2018 Plan reflect the standard factors used in the 2015 UWMP. 3-261 Attachment A
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the recent drought). Due to mandatory water conservation measures, water demands declined in subsequent years, by 12% in the second dry year and 25% in the third dry year. The projected demands during single dry years and multiple dry years are provided in Table 3-5, with the maximum demand being 215.1 AFY. This methodology may over-estimate the savings during mandatory conservation periods if all of the landscape irrigation uses recycled water. Recycled water systems are typically not subject to the same use restrictions as potable supplies.

Table 3-5: Dry Year Demand Projections
MCWD has sufficient supply and well capacity to meet all customer demands during peak (single dry year) conditions.

Average
Year
Single Dry
Year
1st Dry
Year
2nd Dry
Year
3rd Dry
Year
Factor 1.01 1.01 0.88 0.75
Projected Demand (AFY) 250.4 252.9 252.9 220.4 187.8
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Section 4 - Water Supply

4.1 Current Water Supply
The District’s primary source of water supply is the Salinas Valley Groundwater Basin, and it also has a small desalination plant in the Central Marina Service Area, which is permitted but currently inactive. Under the Regional Urban Water Augmentation Project, the District has secured entitlement to 1,427 AFY of advanced treated water from the Pure Water Monterey Project, of which the first 600 AFY will become available in 2019. The District is working jointly with FORA and M1W to identify additional water supply options to supply an additional 973 AFY for the Ord Community. None of the District’s current supply is purchased under wholesale contract.

4.1.1 Groundwater
The District supplies groundwater from the Salinas Valley Groundwater Basin. Under the “Agreement between the United States of America and the Monterey County Water Resources Agency concerning Annexation of Fort Ord into Zones 2 and 2A of the Monterey County Water Resources Agency, Agreement No. A-06404”, dated September 21, 1993, the District (successor to the United States) may withdraw up to 6,600 acre-feet per year from the Salinas Valley Groundwater Basin for use in the District’s Ord Community service area. In 2001, the Army through FORA deeded to MCWD all of the 6,600 acre-feet per year except for reserving 1,577 acre-feet per year to meet Federal water demands within the former Fort Ord. Under an exclusive potable water contract, the Army provides its reserved water right to MCWD to meet Army and other Federal Agency potable water demands within the former Fort Ord.

Under the “Annexation Agreement and Groundwater Mitigation Framework for Marina Area Lands” dated March 1996, by and between the MCWRA, the Marina Coast Water District, J.G.

Armstrong Family Members, RMC Lonestar, and the City of Marina, the District may withdraw up to 3,020 AFY from the Salinas Valley Groundwater Basin for use in the District’s Central Marina service area. Under that agreement, additional groundwater supply will be made available to the District for use within the Armstrong Ranch and the RMC Lonestar (now CEMEX) properties north of Marina, if and when the City annexes and develops those areas.

Consequently, MCWD owns or manages on behalf of the Army a combined total of 9,620 AFY of potable groundwater for its Central Marina and Ord Community service areas. MCWD interconnected the potable water systems within the Central Marina and Ord Community service areas to provide a more efficient and reliable system and, in 2007, MCWD was issued a water supply permit for the combined system by the State of California.

In 2016, the California Department of Water Resources (DWR) published an Interim Update to Bulletin 118, California’s Groundwater. Bulletin 118 defines groundwater basin and subbasin boundaries used for planning and groundwater management. The update reflects changes 3-263 Attachment A
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submitted to and approved by DWR under the Sustainable Groundwater Management Act (SGMA). Within northern Monterey County, the changes include redefining the boundaries of the Seaside and Corral De Tierra subbasins to reflect the defined boundary of the adjudicated Seaside Groundwater Basin and named that area the Seaside Subbasin. DWR then merged the remaining portion of the Seaside subbasin with the Corral de Tierra subbasin, and named that area the Monterey Subbasin). The revised boundaries are shown in Figure 4.1.

The MCWRA designation of groundwater subbasins within the Salinas Valley Groundwater Basin differs from DWR. MCWRA combines DWR’s 180/400 Foot Aquifer Subbasin, the new Monterey Subbasin and the revised Seaside Subbasin into the Pressure Subarea.

Figure 4.1: Groundwater Basins6
All of the District’s wells are located within the Monterey Subbasin of the Salinas Valley Groundwater Basin. MCWD has been designated as an exclusive Groundwater Sustainability Agency (GSA) within its LAFCO service area, and it participates in the Salinas Valley Basin 6 Boundaries from the DWR Groundwater Basin Boundary Assessment Tool, https://gis.water.ca.gov/app/bbat/
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GSA as a member of the Advisory Committee. A portion of the District’s Ord Community service area overlays the Seaside Subbasin of the Salinas Valley Groundwater Basin, which is an adjudicated basin managed by the Seaside Water Master Board.

MCWD in coordination with the Salinas Valley Basin Groundwater Sustainability Agency (SVBGSA) is preparing a Groundwater Sustainability Plan (GS Plan) for the Monterey Subbasin, which includes the Main Gate Specific Plan Area. The GS Plan will identify the sustainable yield of the subbasin, in accordance with Section 10721 of the California Water Code. The GS Plan is required to be implemented not later than January 31, 2022, but the District intends to complete it not later than January 31, 2020, concurrent with the SVBGSA completion of the GS Plan for the 180/400 Foot Aquifer Subbasin. Until those plans are completed and adopted, the groundwater pumping limits in the previous Zone 2/2A Annexation Agreements are assumed to be fully reliable.

There are three defined aquifers within the Marina Coast Water District service area, the 180- foot, the 400-foot and the 900-foot or Deep Aquifer. The District operates eight wells, with three in Central Marina and five in the Ord Community. The service areas are interconnected for reliability, with meters at the points of connection to facilitate managing the two well-fields to ensure each service area remains within its authorized withdrawal limit. Table 4-1 summarizes the existing pumping capacity of the District wells. As can be seen, the District has sufficient well capacity to meet the maximum day demands with the largest well out-of-service.

Table 4-1: Existing Pumping Capacity
Location Well # Aquifer Estimated Capacity
(AFY) (GPM)
Marina
10 Deep 2,670 1,654
11 Deep 3,561 2,206
12 Deep 3,264 2,022
Ord
29 400 foot 2,885 1,787
30 400 foot 3,624 2,245
31 400 foot 3,625 2,246
34 Deep 3,326 2,000
35 400 foot 3,326 2,000

4.1.2 Desalinated Water
The District has a desalination plant located near Marina State Beach, which can contribute up to 300 AFY of potable water supply to the Central Marina service area. The plant was constructed in 1997 as a pilot project but is not currently in use. 3-265 Attachment A
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4.2 Future Water Supply
The District is working towards developing new sources of water supply to meet projected demand increases due to redevelopment within the Ord Community, as well as taking actions to address groundwater wells impacted by seawater intrusion. The two major water supply projects described below are (1) reclaimed wastewater, and (2) desalinated water, which make up the Regional Urban Water Augmentation Project. MCWD is currently investigating alternative sources of potable supply, which may be less costly than desalination.

4.2.1 Recycled Water
Recycled water refers to sanitary sewage which undergoes treatment and disinfection, typically for non-potable uses such as agricultural and landscape irrigation. The Monterey One Water (M1W, formerly Monterey Regional Water Pollution Control Agency) operates a regional wastewater treatment facility in north Marina and produces reclaimed water for agricultural irrigation in the Castroville area. Through prior agreements with the M1W, the District is entitled to receive recycled water from the regional plant, up to the volume of wastewater generated within the District and sent to the plant. In 2007, MCWD began detailed design of the recycled water distribution system, and has now constructed several portions of the transmission main. In 2012, M1W began planning the Pure Water Monterey Groundwater Replenishment Project, which will develop additional sources of water supply and produce advanced treated water for injection into the Seaside Groundwater Basin for indirect potable reuse. In 2016, MCWD and M1W entered into an agreement entitling MCWD to 1,427 AFY of advanced treated water from the Pure Water Monterey Project. MCWD is completing construction of the transmission main, which will be used to deliver advanced treated water for urban irrigation within MCWD and for groundwater injection into the Seaside Subbasin and recovery for indirect potable reuse within the Monterey Peninsula.

Under the initial phase of the project, MCWD will receive 600 AFY of advanced treated water.

In later phases, the project will be expanded, subject to financing and demand, by an additional 827 AFY, or a total of 1,427 AFY, which was the amount of non-potable demand within the Ord Community analyzed in the RUWAP EIR.

4.2.2 Desalinated Water
Given readily available saline and brackish waters near the District’s service area, desalinated water has been considered as another potential water supply. The District’s existing 300 AFY desalination plant is relatively small, but a larger facility to serve the District is planned as a supplemental water supply. The Regional Urban Water Augmentation Project EIR includes a 1,500 AFY desalination facility for the District. The facility was sized to provide up to 1,200 AFY of new supply to the Ord Community and 300 AFY to Central Marina, allowing the District to retire the existing pilot desalination plant. As part of the current joint water supply planning effort by MCWD, M1W and FORA, additional sources of potable water supply are 3-266 Attachment A
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being considered. If an alternative source of potable supply is identified, the RUWAP EIR may be amended to reflect the replacement project.

4.2.3 Conservation
The Marina Coast Water District has an active water conservation program. Under the District’s water conservation ordinance, all new construction is required to incorporate water saving devices over and above the requirements of the state building code. Additionally, the District has adopted the State’s Model Water Efficient Landscape Ordinance. The District requires developers to install water conserving fixtures during construction, landscapes which require high irrigation are discouraged, and a tiered water rate structure discourages water waste. The District offers rebate incentives to replace less efficient water fixtures, for installing smart irrigation controllers, and for replacing lawns and sprinklers.

The State of California has established a goal of reducing per person water use by 20% by the year 2020, compared to the 2008 baseline demands. Toward that end, the California Building Code was updated in 2010, with the goal of reducing indoor water use to 55 gallons per person per day. In the 2010 UWMP, the District identified a year 2020 conservation target of 117 gallons per person per day (system-wide potable average). It is anticipated that the Main Gate Specific Plan area will meet that goal, based upon the new indoor plumbing fixture codes and the planned use of recycled water to meet non-potable demands. The Specific Plan Area could potentially use up to 53.0 AFY of recycled water, which is 21% of the projected overall water demand.

4.3 Regulatory Permits Necessary for Supply Delivery
The Marina Coast Water District is a public water system, permitted by the State Water Resources Control Board, Division of Drinking Water, System No. 2710017. The recycled water distribution system is permitted as System No. 2790009. Permits required for the construction and operation of new facilities are obtained on a project-by-project basis. 3-267 Attachment A
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Section 5 - Supply Sufficiency Analysis

5.1 Comparison of Project Demands to Projected Supply
Within the Ord Community, the 6,600 AFY of existing groundwater supply has been allocated among the land use jurisdictions by the Fort Ord Reuse Authority (FORA), as shown in Table 5-1, below. The municipal jurisdictions (Cities and Monterey County) formally sub-allocate this supply to developments. Until additional water supplies are developed and allocated within the Ord Community, MCWD will only allow new service connections up to the usage totals allocated by the respective jurisdictions. For the City of Seaside, this is in accordance with Subsection 3a of the May 31, 2001 Implementation Agreement between FORA and the and the City of Seaside, which provides that in using, developing, or approving development on property received from FORA, the City “shall not commit (or cause the commitment of) water resources that are unavailable to the [City] (whether through FORA allocations or otherwise).” FORA has also formally allocated the recycled water supply from the Phase 1 Recycled Water Project. Those allocations are also included in Table 5-1.

Table 5-1: FORA Allocations in the Ord Community
Land Use Jurisdiction
Existing
Groundwater
Allocation
(AFY)
Future
Recycled
Allocation
(AFY)
City of Del Rey Oaks 243 280
City of Marina (Ord) 1,325 345
City of Monterey 65 0
City of Seaside 1,012 453
County of Monterey 710 134
Marina Sphere (existing use) 10 0
CA State Parks and Rec. 45 0
CSU Monterey Bay 1,035 87
Univ. of California MBEST 230 60
U.S. Army 1,577 0
Assumed Line Loss 348 68
Total – Ord Community 6,600 1,427
The City of Seaside has sub-allocated portions of their existing groundwater allocation, as detailed in Table 5-2, including 149.0 AFY to the original Main Gate Specific Plan Area7. The remaining unallocated supply totals 181.3 AFY, which is sufficient to meet the remaining 101.4 AFY of supply required for the Amended Main Gate Specific Plan. To make up the total 101.4 7 Note that the City only allocated water supply for the Retail Lifestyle Mall portion of the Main Gate Project, and not the full 213 AFY required for the full specific plan build-out. 3-268 Attachment A
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AFY, the City may choose to allocate 38.4 AFY of recycled water for non-potable landscape irrigation, and allocate the remaining 63.1 AFY as groundwater. The City may also require the use recycled water for toilet flushing, converting up to 14.6 AFY of indoor demand from potable to recycled water. The Project may be phased, and the first phase supplied up to the amount currently allocated by the City. The City is currently considering other development projects which require water supply allocations as well. A Water Supply Assessment was recently prepared for the Campus Town Specific Plan, with an estimated total demand of 487.4 AFY. The City has not yet allocated any water supply to that project, and the City does not currently have sufficient existing water supply to support both specific plans.

The Project has the potential to use up to 53.0 AFY of recycled water. The City of Seaside has a FORA recycled water allocation of 453 AFY, or 31.74% of the 1,427 AFY total. Once the recycled water distribution system is operational, potable water use that is replaced with recycled water may be reallocated to new projects. Recycled water is planned for use at MPUSD schools for landscapes and play fields (30 to 40 AFY) and within Seaside Highlands for parks and common area landscapes (43.1 AFY).

Table 5-2: City of Seaside Sub-Allocations
Project or Existing Water User
Existing
Groundwater
Allocation
(AFY)
SunBay Apartments 120.0
Brostram Park (Bay View MHP) 84.8
Seaside Highlands 168.5
Seaside Resort 161.4
MPUSD 81.0
Monterey College of Law 2.6
Monterey Peninsula College 9.0
Chartwell School 6.4
Main Gate "Retail Lifestyle Mall" 149.0
American Youth Hostel 5.5
Seaside Senior Living 40.0
Other Existing Use 3.0
City of Seaside Total 831.2
FORA Allocation 1012.5
City of Seaside Unallocated 181.3
The initial phase of the recycled water project will provide up to 600 AFY starting in 2019. This supply is being made available to customers on a first come, first served basis. If the City fails to opt into the initial phase of the project, other jurisdictions may use up the Phase 1 project, forcing the City to wait until the Phase 2 expansion is funded and constructed. 3-269 Attachment A
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5.2 Plans for Acquiring Additional Water Supplies
Under the provisions of Section 10911 of the California Water Code, if the water supplier concludes that water supplies will be insufficient for the proposed project, the water supplier shall provide its plans for acquiring additional water supplies. The Marina Coast Water District is currently pursuing two water supply projects, the Recycled Water Project and the Desalination Project, which are intended to allow the District to develop 2,400 AFY of new supply to meet the projected Ord Community demand. Detailed descriptions of these projects are provided in Appendices B and C.

5.3 Reliability of Water Supply
The Salinas Valley Groundwater Basin has a large storage volume, and is recharged by the Salinas River, which is augmented by upstream reservoirs managed by MCWRA. Consequently, the aquifer does not experience wide level variations due to climatic conditions. Water levels vary by 20 to 30 feet seasonally, and decline an additional 10 to 20 feet during drought periods.

The District’s demands accounted for less than one percent of the total groundwater pumped from the Salinas groundwater basin in 2015, the latest year reported. Therefore, the District’s supply is considered reliable on a quantity basis. The upper aquifers in the Salinas Valley Groundwater Basin (180-foot aquifer and 400-foot aquifer) along the coast are experiencing high salinity due to seawater intrusion. The District’s wells in Central Marina are in the Deep Aquifer, which has not experienced signs of seawater intrusion and is considered to have reliable quality. In the Ord Community, the District has one well in the deep aquifer and four wells in the upper aquifers, but outside the area currently affected by seawater intrusion. The District is closely monitoring the quality in these wells.

The planned additional sources of supply are recycled wastewater and seawater desalination.

The source of supply for recycled water is wastewater return flows, which originate from indoor water use. Indoor water use is not subject to the same levels of curtailment during drought periods as outdoor water use, so the source of recycled water supply is considered drought-proof.

The SVRP treatment plant operated by Monterey One Water has reliably produced recycled water meeting the requirements of Title 22 for over a decade. The Pure Water Monterey Advanced Water Purification Plan is currently under construction, and is scheduled to begin delivering advance treated water in 2019. Similarly, seawater desalination is considered a reliable source of supply. Reverse osmosis technology is a proven method of desalinating seawater and brackish groundwater.

5.4 Effect on Agricultural and Industrial Users Reliant on the Same Source There are no agricultural water users within the MCWD service area, nor are there industrial users with privately-owned wells. Agricultural users in the Salinas Valley rely on the same basin-wide supply from the Salinas Valley Groundwater Basin, accounting for 92.9% of the groundwater pumping in 2015. In the local area, 12,000 acres of irrigated agriculture are 3-270 Attachment A
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supplied with recycled water from the Castroville Seawater Intrusion Project. As described in Section 4.1.1., the SVBGSA is preparing a Groundwater Sustainability Plan for the 180/400 Foot Aquifer Subbasin, which will determine the sustainable yield of the subbasin. The sustainable yield determination may require cutbacks in pumping in that subbasin. MCWD hopes to work with those pumpers to develop joint groundwater recharge projects that will benefit areas on both sides of the Salinas River.
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Section 6 - Conclusions

6.1 Sufficiency of Water Supply for the Project
The City of Seaside has sufficient existing water supply to achieve the complete build-out of the planned Main Gate Specific Plan Area, and will have access to non-potable water supply when the recycled water system (currently under construction) is completed in 2019. If the project is phased, the initial phase could proceed using the 149 AFY previously sub-allocated by the City to the original Project. However, the City has multiple projects under consideration and insufficient supply to approve them all, so the City must determine how to prioritize and phase them so as not to exceed the City’s FORA allocations of potable and recycled water supply.

Once a determination is made, the City must notify MCWD so that they may provide the water supply to the Project.

6.2 Future Actions
Section 10911(b) of the Water Code states “The City or County shall include the water assessment provided pursuant to Section 10910, in any environmental document prepared for the Project pursuant to [CEQA].” The City of Seaside will need to adopt this WSA as part of the CEQA environmental review for the proposed Project, including the findings described above.

The City of Seaside may take certain additional actions to guarantee the availability of the water supplies for the Main Gate Specific Plan and other projects under consideration:
 To offset urban irrigation demands within the Seaside portion of the Ord Community with recycled water and then apply the existing potable supply towards the Main Gate and/or Campus Town Specific Plan areas, the project EIR should clearly describe that intent and the resulting allocation of potable and recycled water supply. The Seaside Highlands development was constructed with recycled water mains to supply the landscape irrigation systems. This system is currently fed with potable water, but recycled water will be available within the next few years. Providing recycled water for irrigation of that project would make up to 43.1 AFY8 of potable supply available for reallocation from Seaside Highlands. An additional 10 AFY may be made available by converting the City’s Soper Field sports complex (adjacent to Seaside Highlands) to recycled water.
 The City may require dual-plumbing of buildings to use recycled water for sanitary fixture flushing (toilets and urinals), which will offset potable water demand with recycled water.
8 The City of Seaside water allocation to the Seaside Highlands project states that 43.1 AFY of irrigation demand will be converted to recycled water when it becomes available. 3-272 Attachment A
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 The City may determine that certain sub-allocation areas are fully developed, and reallocate the unused portion of existing allocations to a new project. In doing this, the City should use the maximum water use from the last 10 years as the basis of comparison.
 The City may enter into an agreement with another land-use jurisdiction in the Ord Community to allocate currently unused water supply to a portion of this Project. 3-273 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan A-1 November 2018
Appendix A: Recycled Water Project Details
In 2004-2005, the District prepared engineering studies for the Regional Urban Water Augmentation Project (RUWAP). This project was intended to develop 2,400 AFY of additional water supply for the Ord Community, to meet projected demands identified in the Fort Ord Base Reuse Plan. The RUWAP has two components, urban use of recycled water and a desalination facility. The final capacity of the two components may be adjusted during final design, but the total amount of new supply will be 2,400 AFY.

In 2012, the Monterey One Water (M1W, formerly the Monterey Regional Water Pollution Control Agency) and the Monterey Peninsula Water Management District began planning the Pure Water Monterey Groundwater Replenishment Project, which includes the advanced treatment of recycled water for indirect potable reuse. On April 8, 2016, MCWD and M1W entered into an agreement which would provide up to 1,427 AFY of advanced treated water for urban landscape irrigation instead of the tertiary treated recycled water planned under the RUWAP. The Pure Water Monterey Project required a pipeline running parallel to MCWD’s planned RUWAP pipeline, so the agencies agreed to share a single pipeline, realizing a cost savings to each project. The project is currently under construction, and scheduled to begin operation in 2019.

1. Source of Supply: Tertiary treated wastewater available at the M1W Regional Wastewater Treatment Plant in North Marina. Under the annexation agreement between MCWD and M1W, the District has the right to purchase recycled water, subject to annual and seasonal limits. The Advanced Water Purification Facility (AWPF) is currently being constructed, with a design capacity of 5.0 mgd. The plant will produce advanced-treated recycled water meeting the Title 22 standards for indirect potable reuse (injection into a groundwater aquifer and recovery at other wells).

2. Expected Supply Capability: The Phase 1 project will have an initial yield of 4,100 AFY, of which 600 AFY would be available to MCWD. The remaining 3,500 AFY would be conveyed to an injection wellfield in the Ord Community and stored in the Seaside Groundwater Basin. Future Phases of the project will increase MCWD’s yield to 1,427 AFY.

3. Project Facilities:
o Advanced water purification facility and pump station, located within the M1W plant in North Marina
o Product water transmission and distribution pipelines within Marina and the Ord Community
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Marina Coast Water District Amended Main Gate Specific Plan A-2 November 2018
o Recycled water storage tank within the Ord Community

4. Historical Record:
o MCWD operated a recycled water system from 1996 to 1998. Thereafter the Marina Wastewater Treatment Plant was retired and the local sanitary sewer system was connected to the Regional wastewater collection system. o MCWD prepared engineering studies for the Regional Urban Water Augmentation Project (RUWAP), which included a recycled water component. The District approved the CEQA EIR for the RUWAP in 2005, and amended the findings in 2006 and 2007 as detailed planning progressed.
o In 2004, MCWD published standards for recycled water infrastructure and began requiring the construction of recycled water pipelines in new subdivisions. o MCWD constructed 3.5 miles of recycled water pipelines within the Ord Community during on-going road construction projects, in cooperation with the Fort Ord Reuse Authority and California State University Monterey Bay. o MCWD is currently constructing the shared product water transmission main and storage reservoir. The transmission main connects the AWPF in north Marina to the injection wellfield in Seaside.
o M1W is currently constructing the Pure Water Monterey AWPF and the injection wellfield.
o MCWD is currently completing design of the recycled water distribution system, which connects customers to the transmission system.
o MCWD obtained a pipeline easement for the recycled water main across the Armstrong Ranch in 2007. MCWD obtained a pipeline easement from the City of Seaside for the recycled water main from Normandy Ave to the water tank site in 2010. The District obtained ownership of the recycled water tank site in 2010 (previously held as an exclusive easement). MCWD finalized the recycled water main easements with the Presidio of Monterey in 2012. MCWD finalized the recycled water main easements with CSUMB in 2018.

5. Written Contracts and Agreements:
o In the annexation agreement between MCWD and M1W, MCWD retained the right to obtain recycled water in an amount not to exceed the volume of wastewater flows originating from the District.
o MCWD entered into an agreement with the Fort Ord Reuse Authority in 2005 to develop the RUWAP water supplies.
o MCWD executed two memoranda of understanding with M1W and MCWRA (one in 2009 and one in 2010) to work cooperatively towards the RUWAP, and to specify quantities, (seasonal) availability, and roles and responsibilities. o MCWD entered into the Pure Water Delivery and Supply Project Agreement with M1W in 2016 to participate in the Pure Water Monterey Project and receive advanced 3-275 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 961, Packet Page 1084 WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan A-3 November 2018
treated water instead of tertiary treated and disinfected recycled water for the RUWAP.
o In agreements with developers of new subdivisions for the construction of water infrastructure, the District requires the installation of recycled water pipelines for the irrigation of public and commercial landscapes.

6. Estimated Costs and Financing: The Pure Water Monterey Project overall cost is estimated at approximately $70 million. This includes both the MCWD and M1W Facilities. Both agencies have received State Revolving Fund Loans to cover a majority of the construction costs. The Fort Ord Reuse Authority has budgeted $37 million for the Regional Urban Water Augmentation Project. A portion of that funding will be applied to this project.

7. Timeframes: The District began constructing recycled water pipelines in conjunction with road construction projects by other jurisdictions (Fort Ord Reuse Authority and CSU Monterey Bay) and private developers beginning in 2004. Construction of the transmission main and water tank began in December 2017, and are projected to be complete by November 2018. Construction of the AWPF and injection wellfield began in 2017, and are projected to be complete by early 2019.

8. Federal, State and Local Permits for Construction:
o The project is subject to the California Environmental Quality Act (CEQA) and also the National Environmental Policy Act (NEPA) because the SVRP facility is partially funded by the U.S. Department of the Interior, Bureau of Reclamation. The CEQA EIR for the RUWAP Phase 1 Project with supporting NEPA studies has been completed. CEQA actions for a future RUWAP Phase 2 expansion have not been initiated.
o The CEQA EIR for the Pure Water Monterey Project with supporting NEPA studies has been completed.
o The project pump stations and pipelines are outside the Coastal Zone and therefore a Coastal Commission Permit is not required.
o Encroachment permits and easements for pipeline construction have been coordinated with the City of Marina, the City of Seaside, CSU Monterey Bay, Monterey Peninsula Unified School District and the Presidio of Monterey (Ord Military Community). o A Monterey County Conditional Use Permit was obtained for the pipeline crossing agricultural land (Armstrong Ranch).
o M1W has obtained a Water System Permit with the California State Water Resources Control Board, Division of Drinking Water for the advanced treated water system. o The District’s Water System Permit with the California State Water Resources Control Board, Division of Drinking Water will need to be updated to include the recycled water distribution system before the system can be placed into operation. 3-276 Attachment A
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The Title 22 Engineering Report for that addition has been submitted and a recycled water system number has been assigned.
3-277 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 963, Packet Page 1086 WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan B-1 November 2018
Appendix B: Desalination Project Details
In 2004-2005, the District prepared engineering studies for the Regional Urban Water Augmentation Project (RUWAP). This project was intended to develop 2,400 AFY of additional water supply for the Ord Community, to meet projected demands identified in the Fort Ord Base Reuse Plan. The RUWAP has two components, urban use of recycled water and a desalination facility. The final capacity of the two components may be adjusted during final design, but the total amount of new supply will be 2,400 AFY.

The Desalination Project was originally studied as a stand-alone facility, located at the former Fort Ord Wastewater Treatment Plant. In 2008, the District began working cooperatively with California American Water, which was planning a larger desalination facility to serve their Monterey Service Area (adjacent to the Ord Community). The two agencies jointly planned a Regional Desalination Facility to be located in North Marina adjacent to the M1W Regional Wastewater Treatment Plant. This location facilitated the use of the existing wastewater outfall pipeline for brine disposal from the desalination plant. In 2011, the agreement between MCWD, American Water and Monterey County Water Resources Agency was terminated. MCWD is now pursuing a smaller desalination facility, as sized in the RUWAP EIR, located on the North Marina site.

As mentioned in the report, MCWD is jointly studying with FORA and M1W alternative sources of potable water supply. If a preferred source of potable supply is identified, the RUWAP may be amended at that time.

The following details are provided as required per Water Code §10911.

1. Source of Supply: Seawater-intruded groundwater in the 180-foot aquifer of the Salinas Valley Groundwater Basin, Pressure Subbasin. Source wells will capture seawater within the aquifer which is currently migrating inland.

2. Expected Supply Capability: 1,500 AFY (average annual yield). Of this total, 1,200 AFY would be for the Ord Community, and 300 AFY would replace the capacity of the District’s existing pilot desalination plant, which would then be retired.

3. Project Facilities:
o Source wells in the intruded portion of the 180-ft aquifer o A reverse-osmosis desalination plant located in North Marina, o Product water pipeline from the plant to the MCWD service area, 3-278 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan B-2 November 2018
o Brine disposal pipeline from the plant to the Monterey One Water effluent disposal pipeline (deep ocean outfall)
o Water storage tanks within the MCWD service area

4. Historical Record:
o MCWD constructed a pilot desalination plant in Marina in 1996. o MCWD prepared engineering studies for the Regional Urban Water Augmentation Project (RUWAP), which included a seawater desalination component. o The District approved the CEQA EIR for the RUWAP in 2005, and amended the findings in 2006 and 2007 as detailed planning progressed. o CAWC prepared engineering studies for the Coastal Water Project (CWP) in 2005- 2008, which included a seawater desalination facility, and submitted a CEQA EIR to the California Public Utilities Commission in 2009.
o MCWD and CAWC worked cooperatively to develop a regional desalination facility as an alternative to two separate facilities, as reflected in the CWP EIR. o The CPUC approved the CWP EIR in 2010.
o The Water Purchase Agreement was terminated by CAWC in September 2011. o MCWD issued an RFQ for Design-Build Services for the Desalination Project in September 2012, but did not award a contract. The project was placed on hold to focus on the recycled water project

5. Written Contracts and Agreements:
o MCWD entered into an agreement with the Fort Ord Reuse Authority in 2005 to develop the RUWAP water supplies.
o MCWD entered into an option agreement with the Armstrong Family Trust in 1998 to purchase land for a future water facility. The District executed that option in 2010 for the Regional Desalination Facility site.
o MCWD entered into an agreement with M1W in 2009 for shared use of the effluent disposal pipeline.
o MCWD, CAWC and MCWRA entered in the Water Purchase Agreement in 2010.

This agreement established project responsibilities between the three agencies. This agreement was terminated by CAWC in September 2011.

6. Estimated Costs and Financing: The Regional Desalination Project is estimated to cost approximately $80 million. The District will pursue State and Federal grants for portions of the project cost. The Fort Ord Reuse Authority has budgeted $37 million for the Regional Urban Water Augmentation Project. A portion of that funding will be applied to this project.

7. Timeframe: Preliminary studies are complete. Assuming a traditional design-bid-build delivery model, it would take from 4 to 6 years to complete design, permitting and construction.
3-279 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 965, Packet Page 1088 WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan B-3 November 2018

8. Federal, State and Local Permits for Construction:
o The project is subject to the California Environmental Quality Act (CEQA) and also the National Environmental Policy Act (NEPA) because the facility may be partially funded by the U.S. Department of the Interior, Bureau of Reclamation. CEQA EIRs with supporting NEPA studies for the RUWAP Desalination Project and for the Regional Desalination Project have been completed. The RUWAP EIR must be amended to reflect the new MCWD facility location and brine disposal method. o A Coastal Development Permit from the California Coastal Commission may be required for some project facilities if brackish water source wells are located in the Coastal Zone.
o Encroachment permits for pipelines will be required from Monterey County, City of Marina, and possibly CALTRANS.
o MCWD must amend their Water System Permit with the California Department of Public Health to add the desalination facility as a new source of supply before the system can be placed into operation.
o A Regional Water Quality Control Board discharge permit (NPDES) for the desalination plant will be required.
o A Monterey County Building Permit will be required for the desalination plant o A permit from the Monterey Bay Unified Air Pollution Control District will be required for the desalination facility
o Monterey County Environmental Health must approve permits for (1) construction of the groundwater wells, and (2) construction of the desalination facility 3-280 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan C-1 November 2018
Appendix C: References
California American Water Company:

Coastal Water Project, Final Environmental Impact Report, prepared for the California Public Utilities Commission, October 2009
CalAm Monterey Peninsula Water Supply Project, Final Environmental Impact Report, prepared for the California Public Utilities Commission, March 2018 California Department of Water Resources:
20x2020 Water Conservation Plan, February 2010.

Bulletin 118: California’s Groundwater, Interim Updated 2016, December 2016 California Irrigation Management Information System (CIMIS) website, www.cimis.water.gov
Guidebook for Implementation of Senate Bill 610 and Senate Bill 221 of 2001, October 8, 2003.
2015 Urban Water Management Plan Guidebook for Urban Water Suppliers, March 2016.

Model Water Efficient Landscape Ordinance, July 15, 2015 California Urban Water Conservation Council, Memorandum of Understanding Regarding Urban Water Conservation in California, As Amended June 9, 2010 California Building Standards Commission, 2016 California Plumbing Code, with 2018 Supplement
Carollo Engineers, Marina Water Systems Master Plan, February 2007.

City of Seaside:
2009-2014 Housing Element, adopted August 2010
Redevelopment Agency of the City of Seaside, Implementation Plan, 2007 – 2012, Seaside-Fort Ord Redevelopment Project Area, January 17, 2008 The Projects at Main Gate Specific Plan, adopted August 2010 City Council Resolution dated May 15, 2008, allocating 149.0 AFY to the Retail Lifestyle Mall component of the Projects at Main Gate
County of Monterey, 2010 Monterey County General Plan, October 26, 2010 3-281 Attachment A
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Marina Coast Water District Amended Main Gate Specific Plan C-2 November 2018
Denise Duffy & Associates:

Draft Environmental Impact Report, Pure Water Monterey Groundwater Replenishment Project. April 2015.

Final Environmental Impact Report, Pure Water Monterey Groundwater Replenishment Project. January 2016.

Denise Duffy & Associates in association with RBF Consulting:

Draft Environmental Impact Report Regional Urban Water Augmentation Project. June 2004.

Final Environmental Impact Report Regional Urban Water Augmentation Project.

September, 2004.

Fort Ord Reuse Authority:

Capital Improvement Program, FY 2017/18 through Post FORA, June 2017.

Fort Ord Reuse Plan, 1996.

Reuse Plan EIR, 1997.

Harding ESE, Final Report, Hydrogeologic Investigation of the Salinas Valley Basin in the Vicinity of Fort Ord and Marina, Salinas Valley, California, prepared for the Monterey County Water Resources Agency, April 2001
Keyser Marston Associates, Inc., Implementation Plan for the Fort Ord Redevelopment Project Area, Prepared for the Redevelopment Agency of Monterey County, March 2007 LAFCO of Monterey County, Municipal Services Review for the Monterey Peninsula, 2006 Marina Coast Water District:
2015 Urban Water Management Plan, prepared by Schaaf & Wheeler, Consulting Civil Engineers, June 2016.
2017 Consumer Confidence Report for Central Marina and Ord Community, April 2018 Pure Water Delivery and Supply Project Agreement between Monterey Regional Water Pollution Control Agency and Marina Coast Water District, April 8, 2016.

Water Supply Assessment and Written Verification of Supply for the City of Seaside Main Gate Specific Plan, prepared by Byron Buck & Associates, November 2, 2007.

Quarterly Water Consumption Report, period ending: December 31, 2017.

Monterey County Water Resources Agency:
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Marina Coast Water District Amended Main Gate Specific Plan C-3 November 2018
2015 Groundwater Extraction Summary Report, April 2017.

Agreement between the United States of America and the Monterey County Water Resources Agency concerning Annexation of Fort Ord into Zones 2 and 2A of the Monterey County Water Resources Agency, Agreement No. A-06404, September 21, 1993.

Annexation Agreement and Groundwater Mitigation Framework for Marina Area Lands (1996). Document recorded in the Office of the Monterey County Recorder on August 7, 1996, at Reel 3404 Page 749.

Regional Water Providers Consortium, www.conserveh2o.org/toilet-water-use RHAA, Development Master Plan, California Central Coast Veterans Cemetery, Fort Ord, prepared for the Redevelopment Agency of Monterey County, September 2008.

RMC Water and Environment, MCWD Recycled Water Project Basis of Design Report, 2006 University of California Cooperative Extension, A Guide to Estimating Irrigation Water Needs for Landscape Plantings in California, August 2000
3-283 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 969, Packet Page 1092 WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan D-1 November 2018
Appendix D: MCWD Board Resolution Approving the Water Supply Assessment for the Amended Main Gate Specific Plan
3-284 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 970, Packet Page 1093 3-285 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 971, Packet Page 1094 3-286 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 972, Packet Page 1095 WSA / WVS for the
Marina Coast Water District Amended Main Gate Specific Plan E-1 December 2018
Appendix E: Memorandum, Errata to the Main Gate and Campus Town Water Supply Assessments
3-287 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 973, Packet Page 1096

MEMORANDUM
TO: Brian True, PE, MCWD DATE: December 10, 2018
FROM: Andrew Sterbenz, PE JOB#: MCWD.46.17:007
SUBJECT: Errata for the Main Gate and Campus Town Water Supply Assessments The purpose of this memorandum is to explain the errata to the Water Supply Assessment and Written Verification of Supply for the Amended Main Gate Specific Plan dated November 20, 2018, and the Water Supply Assessment and Written Verification of Supply for the Campus Town Specific Plan, dated June 12, 2018. Following the issue of the WSA for the Amended Main Gate Specific Plan, it came to our attention that the tabulation of previous water allocations contained an error, which affected the amount of unallocated supply available to future projects. This error did not affect the analysis of projected water demand for the subject projects.

In both reports, Table 5-2, City of Seaside Sub-Allocations, the City is shown having a water allocation of 1012 AFY from the Fort Ord Reuse Authority. The table also includes an entry for the transfer of 5.5 AFY of supply for the American Youth Hostel (entered as a negative demand: -5.5). The supply value of 1012 AFY comes from the staff report accompanying the Fort Ord Reuse Authority (FORA) Resolution 07-1, which made loans from the FORA water reserve permanent. That staff report also accounted for water transfer agreements between jurisdictions. We had believed that the transfer of 5.5 AFY from State Parks to the City of Seaside occurred after FORA Resolution 07-1, but in fact it was included in that summary.

Therefore, the 5.5 AFY transfer was double-counted in the analysis. Also, the value of the transfer for the youth hostel used in the 2007 staff report was 5.0 AFY, but the final agreement value was 5.5 AFY, so the City of Seaside total allocation should be 1012.5 AFY, not 1012.0 AFY.

Making those two corrections to Table 5-2, the City of Seaside has a total of 831.2 AFY allocated to other projects, and has 181.3 AFY of remaining unallocated supply. In the attached corrected reports, Table 5- 2 is corrected, and the text in the Summary and in Section 5.1 is updated to reflect the corrected balances. This change does not affect the conclusions in either report, because neither project’s projected water demand was within 5.5 AFY of the City’s remaining unallocated supply.

This memorandum is added as an Appendix to the corrected reports.

Schaaf & Wheeler

CONSULTING CIVIL ENGINEERS
3 Quail Run Circle, Suite 101
Salinas, CA 93907
t. 831-883-4848
f. 831-758-6328
[email protected]
3-288 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 974, Packet Page 1097 Brian True, PE, MCWD December 10, 2018
Schaaf & Wheeler Page 2
Attachments

1. Water Supply Assessment and Written Verification of Supply for the Amended Main Gate Specific Plan, with Errata

2. Water Supply Assessment and Written Verification of Supply for the Campus Town Specific Plan, with Errata
References:

1. Fort Ord Reuse Authority, Resolution 07-1, “Resolution of the Authority Board changing the 150 AFY loans granted to Del Rey Oaks, Seaside, Marina and Monterey County in October 1998 to permanent additions to their water allocations” and the staff report dated 1/12/2007 3-289 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 975, Packet Page 1098 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 12
COMMENTER: Andrew Sterbenz, PE, Senior Project Manager, Schaaf & Wheeler Consulting Civil Engineers
DATE: August 21, 2019
Response 12.1
The commenter states that Appendix M of the Draft EIR includes two versions of the WSA, of which the updated version was not prepared by Schaaf & Wheeler and was not reviewed and accepted by the MCWD Board of Directors. The commenter requests that the changes to the report be presented in underline-strikeout and requests that the author of the edited version be identified on the title page.

The Draft EIR and its materials were prepared by City Staff and its consultants, as outlined in Draft EIR Section 7.2. The commenter is correct that Appendix M contained two versions of the WSA, the first was included in Draft EIR Appendix M1, which noted that it contained “Errata from the City of Seaside Dated June 2019”. Section 4.16.2(b) (page 4.16-10) of the Draft EIR describes the changes to the Updated WSA “to provide more detailed information on the water offset programs (Mitigation Measure UTIL-1 below) and to correct several minor errors (e.g., incorrect street addresses) and provide additional background information.” In addition, a detailed summary of the updated WSA is provided on pages 1 to 2 of Appendix M1, describing what changes were made. The revised WSA was sent to MCWD before release of the Draft EIR. The revisions were generally acceptable to MCWD, however they did not provide any additional input. As described in detail in Draft EIR Appendix M1:

The City has prepared this Updated WSA to clarify the text of the prior WSA and to correct several minor errors. The District adopted its Water Supply Assessment on June 18, 2018. The WSA approved by MCWD is included in the EIR as Appendix M2 and is available online at:
https://www.mcwd.org/docs/agenda_minutes/2018-06-18_board/Item%2010-C%20- %20Draft_Campus_Town_WSA_JUN2018.pdf
The WSA prepared by MCWD concluded “The Project will add approximately 487.4 acre-feet per year (AFY) of new demand to the District’s Ord Community Service Area, within the City of Seaside. The City has an existing allocation of Salinas Valley Groundwater of 1,012 AFY, and has previously suballocated 825.7 AFY to other projects, leaving 186.3 AFY available.” (Appendix M2, p. 1.) “To offset urban irrigation demands within the Seaside portion of the Ord Community with recycled water and then apply the existing potable supply towards the Campus Town Specific Plan area, the project EIR should clearly describe that intent and the resulting allocation of potable and recycled water supply.” (Appendix M2, Section 6.2.) The MCWD WSA further discussed such water offset programs to include Seaside Highlands and Soper Field and suggested utilizing recycled water for sanitary fixture flushing (toilets and urinals). (Id.) The updated WSA contained herein, provides more detailed information regarding the proposed water offset programs, consistent with the WSA’s direction that the EIR describe the water offset programs and “clearly describe that intent and the resulting allocation of potable and recycled water supply.” (Appendix M2, Section 6.2.) This information has been incorporated throughout the WSA, including Section 6.2. The updated WSA also includes quantification of the recycled water use within the Plan Area, and a more precise calculation of landscaping water 3-290 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 976, Packet Page 1099 City of Seaside
Campus Town Specific Plan Responses to Comments on the Draft EIR Final Environmental Impact Report
demand, as shown in Table 2-1. Additional background information has also been added discussing the history of the 6,600 AFY allocation, long term water supply planning, and water supply reliability.

Minor errors were also corrected. For example, street addresses have been corrected in Section

2.1, which lists the current buildings within the Plan Area, and the acreage of the Plan Area has been clarified. Figures 2.1 and 2.2 have also been updated to be consistent with the current Specific Plan. Additional citations have also been provided, such as references in Section 2.2, which disclose the sources of the water demand assumptions. The left column of Table 3-4 was also revised to correctly identify 942 units at a density of 5-8 du/acre rather than 8-15 du/acre as identified in the original WSA.
3-291 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 977, Packet Page 1100 ________________________________________________________________________________________________________________________________ 5757 PACIFIC AVENUE \ SUITE 222 \ STOCKTON, CA 95207 \ PH 209.472.7700 \ MODESTO PH 209.525.8444 \ FX 209.472.7986 \ APC Steven A. Herum
[email protected]
August 20, 2019

VIA ELECTRONIC MAIL
City of Seaside
440 Harcourt Avenue
Seaside, California 93955
Attention: Kurt Overmeyer
[email protected]
Re: Campus Town Specific Plan
Draft Environmental Impact Report
SCH#2018021079
Dear Mr. Overmeyer:

This office represents the Committee for Sound Water and Land Development of Fort Ord (Committee) and in that capacity has been instructed to review and provide comments about the Campus Town Specific Plan Draft Environmental Impact Report (SCH#2018021079) (DEIR) on behalf of Committee. Committee is an unincorporated association consisting of property owners in the City of Seaside and the Committee is vitally interested in protecting the environment of Seaside and maintaining the quality of life within and around the community.

To start with, CEQA is to be expansively interpreted in order to provide maximum evaluation and consideration of potential direct and indirect environmental effects.

Title 14 California Code of Regulation § 15003(f) [hereinafter CEQA Guideline]; Friends of Mammoth v. Board of Supervisors (1972) 8 Cal.3d 247, 259. In keeping with this expansive statutory mandate the “EIR requirement is the heart of CEQA.” CEQA Guideline § 15003(a); County of Inyo v. Yorty (1973) 32 Cal.App.3d 795.

More specifically, an Environmental Impact Report must consider both direct and indirect environmental effects (CEQA Guideline § 15064(e)) including secondary environmental effects resulting from direct economic effects. The expansive interpretation of this rule was presented in Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1205-1206 (Bakersfield) and illustrates the meaningful relationship between socio-economic direct effects to secondary or indirect environmental effects:
3-292 Attachment A
Council Regular Meeting, 9/19/2023, Item No. 19., Item Page 978, Packet Page 1101 City of Seaside
August 20, 2019