Monterey City Council
July 16, 2024

MONTEREY PENINSULA UNIFIED SCHOOL DISTRICT

EXECUTIVE SUMMARY
ENROLLMENT PROJECTIONS - FALL 2023
PowerSchool Predictive Enrollment Analytics is pleased to present this report of findings to the Board of Education and Executive Staff of Monterey Peninsula Unified School District. Both a Conservative and Moderate projection have been generated for the district. Assuming district revenue is generated on a per pupil basis, the Conservative projection is more suitable for budget planning purposes while the Moderate projection is more suitable for facilities planning purposes.

KINDERGARTEN ENROLLMENT
In general, Kindergarten enrollment over the past four years has been decreasing. The data also show that the difference between the graduating cohort and the incoming cohort has been decreasing. Note that both studies project a relatively stable trend at the Kindergarten level.

COHORT PATTERNS
A typical student cohort ages from grade to grade relatively unchanged from the previous year.

Historically, 2 cohorts show more than a 5% annual change.

NEW HOUSING DEVELOPMENT
Approximately 5,800 new residential units are projected to be occupied over the next 10 years. During that period, the annual impact in any given year, based on the Moderate Study, is estimated in peak years to be 621 students.

DISTRICT-WIDE ENROLLMENT PROJECTION
Overall the projections forecast a decline across the 10-year period based upon the historical enrollment trends and any projected new residential development.

MORE INFORMATION
A richer and more comprehensive review of both studies is contained in the Final Report accompanying this Executive Summary. A wealth of more detailed information and analysis regarding both studies is also quickly and easily accessible online.

Respectfully Prepared and Submitted by:

The Predictive Enrollment Analytics Team
February 16, 2023
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1730, Packet Page 2058

MONTEREY PENINSULA UNIFIED SCHOOL DISTRICT

HISTORICAL ANALYSIS

RECENT CHANGES IN ENROLLMENT
Familiarity with recent historical enrollment patterns and trends establishes the foundation for understanding projected enrollment. Percentages in the table below compare the current year enrollment to that of three years ago.

Kindergarten 81%
Gr K-6 90%
Gr 7-8 87%
Gr 9-12 108%
District (K-12) 95%
4 Year History Change
FIGURE 1

KINDERGARTEN IMPACT
Kindergarten enrollment is a significant driver of overall future district-wide enrollment. A trend at Kindergarten from year to year, or a trend in the difference between the district's graduating cohort in a given year and the Kindergarten cohort the subsequent year, will eventually be reflected in the total district enrollment count.

In general, Kindergarten enrollment over the past four years has been decreasing. The data in the table below also show that the difference between the graduating cohort and the incoming cohort has been decreasing.
[More details: Enrollment > Historical > District-Wide > History Years Enrollment] 2020 2021 2022
Kindergarten 92% 98% 90%
Grade 12 to K 93% 84% 80%
Total K-12 96% 99% 100%
Percent Change of Previous Year
FIGURE 2
Transition K enrollment is forecast as a separate grade level. These projections include an expansion of TK from 3 months to 12 months starting in 2022 through 2025. [All data in this report excludes Transition K unless specifically noted.]

LIVE BIRTH TRENDS
Live birth trends have an impact in large geographies, and on long range projections. However, in smaller areas of study, such as a school district, population mobility is often a mitigating if not an overriding factor, thereby reducing the effectiveness of live births as a predictor of enrollment.

Consequently, PowerSchool Predictive Enrollment Analytics has found that recent Kindergarten ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1731, Packet Page 2059

enrollment trends by sub-geographies to be a better, more reliable predictor of future Kindergarten enrollment.

COHORT IMPACT
A typical student cohort ages from grade to grade relatively unchanged from the previous year. By contrast, the cohort matriculating from Kindergarten to Grade 1 is a common example of a cohort increase, typically attributable to students returning from a private school.

In the following table, cohort changes with more than a 2% variance from static are marked accordingly.

Those with more than a 5% changed are marked as ‘Significant’.

Cohort Percent +/- Significant
K > 1 97% ----
1 > 2 96% ----
2 > 3 95% ----
3 > 4 97% ----
4 > 5 96% ----
5 > 6 92% ---- SSSS
6 > 7 95% ----
7 > 8 100%
8 > 9 125% ++++ SSSS
9 > 10 101%
10 > 11 99%
11 > 12 101%
Average Cohort Change Past Three Years
FIGURE 3

INCOMING OUT-OF-DISTRICT TRANSFER IMPACT
The number of students served from outside the district boundaries can impact enrollment. It is a factor over which the district may have some control. For the past two years, the number of out-of-district students served annually has been approximately 348, and has been increasing. [More details: Enrollment > Historical > District-Wide > Out of District]

KEY VARIABLES IN PROJECTING DISTRICT ENROLLMENT
Both a Conservative and Moderate projection have been generated for the district. Assuming district revenue is generated on a per pupil basis, the Conservative projection is more suitable for budget planning purposes while the Moderate projection is more suitable for facilities planning purposes.

As a matter of standard practice, PowerSchool Predictive Enrollment Analytics does not typically include specialized schools or programs such as Home and Hospital Programs, Community Day Schools or Independent Study Programs in the Enrollment Projections. Our work is focused on projecting grade level enrollment for typical schools that are reported to the state.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1732, Packet Page 2060

The major variables that distinguish the Conservative projection from the Moderate are described in the table below.

Key Variables Controlling the Projections Algorithm
Applies the lesser or greater of 3-4 year history trend in each studyblock to the appropriate study.

Applies the lesser or greater of 3-4 year history trend in each studyblock to the appropriate study.

Restricts the effect of anomalous spikes in Kindergarten history Restricts the effect of anomalous spikes in Kindergarten history For each grade level span, applies the lesser or greater of 1-2 year history to the lograde; ages through existing students.

Moderate study assumes developer's phasing calendar. Conservative study shifts the developer's calendar toward the out-years.

Typical of recent history by product type.

K Enrollment Change Floor
K Enrollment Change Cap
Cohort Change
Incoming Out-of-District Transfers
Dwelling Units
Student Generation Rates
Kindergarten Enrollment Change
FIGURE 4

IMPACT OF PROJECTED NEW DWELLING UNITS

PROJECTED OCCUPANCY
Approximately 5,800 new residential units are projected to be occupied over the next 10 years. The tables below show the mix of proposed units across the three dwelling unit types. The Moderate table summarizes the plans described by developers while the Conservative table estimates a more likely scenario based on anticipated market conditions. The most recent residential research was completed in September 2022 by Rebecca Noren-Matz.
[More details: Enrollment > Residential > District-Wide > Proposed Dwelling Units] 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032
Multi-family 97 680 620 376 494
Attached 62 202 203 172 2 4 877
Detached 270 357 357 357 209 100 100 100 101
Totals: 429 1239 1180 905 211 104 100 100 1472 0
New Dwelling Units Projected to be Occupied by Year (Moderate) FIGURE 5
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1733, Packet Page 2061

2023 2024 2025 2026 2027 2028 2029 2030 2031 2032
Multi-family 74 567 550 364 218 395 99
Attached 50 172 163 152 104 4 702 175
Detached 198 315 285 285 257 167 103 80 81 81
Totals: 322 1054 998 801 579 171 103 80 1178 355
New Dwelling Units Projected to be Occupied by Year (Conservative) FIGURE 6
The graph below depicts visually the differences between the phasing projected in the Moderate and Conservative studies.

FIGURE 7

STUDENTS GENERATED
Over the period of years during which these units will become occupied, the impact, based on the Moderate scenario, is shown in the table below. The “Annual” row projects the number of students new to the district from these units each year. The “Aggregate” row projects the accumulated increase in students served by the district through the year indicated and includes matriculation through and eventually out of the district for students introduced in previous years. 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032
Aggregate 672 1161 1566 1724 1825 1947 2085 2706 2823
Annual 192 480 489 405 158 101 122 138 621 117
Students Generated by Residential Development (Moderate) FIGURE 8
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1734, Packet Page 2062

The table below reflects the students generated using the Conservative estimate of projected Dwelling Units.
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032
Aggregate 556 959 1308 1581 1718 1833 1947 2436 2673
Annual 144 412 403 349 273 137 115 114 489 237
Students Generated by Residential Development (Conservative) FIGURE 9

STUDENT GENERATION RATES
Moderate student generation rates are typical of students enrolled from existing developments of similar product type. Conservative student generation rates, if different, are designed to anticipate a diminution in family size.
[More details: Enrollment > Residential > District-Wide > Student Generation Rates] A complete report regarding new residential development is available online in our platform under “Home > Administration and Tools > District Documents”. This report includes a map of proposed dwelling unit projects, the phasing by dwelling unit type in each project, students generated by new development by studyblock, student generation rates. Additional individual reports can be found online under “Enrollment > Residential”.

PROJECTED ENROLLMENT CHANGES BY GRADE LEVEL
The tables below display the five-year district-wide projections by grade level and allow a comparison to enrollment in the current year.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1735, Packet Page 2063

CONSERVATIVE 5 YEAR DISTRICT-WIDE PROJECTION BY GRADE LEVEL Grade 2022 2023 2024 2025 2026 2027
TK 184 183 196 209 210 209
K 581 529 535 541 544 541
1 656 566 546 552 554 551
2 655 632 576 558 560 568
3 608 620 626 579 562 571
4 632 594 628 635 586 574
5 634 604 589 625 628 593
6 611 584 572 561 592 617
7 584 586 566 560 549 569
8 548 578 585 569 559 553
9 820 689 756 772 751 726
10 827 825 720 782 793 767
11 815 820 839 737 794 805
12 760 815 827 848 744 801
Subtotals: 8915 8625 8561 8528 8426 8445
Pct Chg: 0.5% -3.3% -0.7% -0.4% -1.2% 0.2%
SDC: 325 317 312 307 304 303
Totals: 9240 8942 8873 8835 8730 8748
FIGURE 10
MODERATE 5 YEAR DISTRICT-WIDE PROJECTION BY GRADE LEVEL Grade 2022 2023 2024 2025 2026 2027
TK 184 191 208 226 231 226
K 581 552 569 586 598 587
1 656 577 577 595 606 593
2 655 644 600 602 612 609
3 608 632 651 615 613 613
4 632 607 655 675 634 618
5 634 614 612 662 676 634
6 611 590 589 592 634 659
7 584 596 582 587 588 611
8 548 584 601 591 591 588
9 820 701 779 802 786 756
10 827 835 742 816 832 793
11 815 830 861 770 837 835
12 760 825 848 880 786 844
Subtotals: 8915 8778 8874 8999 9024 8966
Pct Chg: 0.5% -1.5% 1.1% 1.4% 0.3% -0.6%
SDC: 325 322 323 324 326 324
Totals: 9240 9100 9197 9323 9350 9290
FIGURE 11
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1736, Packet Page 2064

As the following graph illustrates, overall the projections forecast a decline across the 10-year period based upon the historical enrollment trends and any projected new residential development.

FIGURE 12
The tables below compare the Conservative and Moderate enrollment projections by key grade level groupings. Projected changes in enrollment at Kindergarten or lower grade level groupings will eventually impact total district enrollment.
5 YEAR ENROLLMENT TRENDS: MODERATE AND CONSERVATIVE COMPARED Change by Level Cnsv Mod
Kindergarten 541 587
Change 93% 101%
Gr K-6 4015 4313
Change 92% 99%
Gr 7-8 1122 1199
Change 99% 106%
Gr 9-12 3099 3228
Change 96% 100%
District (K-12) 8236 8740
Change 94% 100%
FIGURE 13
Note that an averaging of both studies project a relatively stable trend at the Kindergarten level.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1737, Packet Page 2065

The table below compares the ten-year projections. In the 10-year future at Kindergarten, both studies, averaged together, project a decline.
10 YEAR ENROLLMENT TRENDS: MODERATE AND CONSERVATIVE COMPARED Change by Level Cnsv Mod
Kindergarten 505 562
Change 87% 97%
Gr K-6 3736 4098
Change 85% 94%
Gr 7-8 1098 1192
Change 97% 105%
Gr 9-12 2989 3244
Change 93% 101%
District (K-12) 7823 8534
Change 90% 98%
FIGURE 14
The graphs below compare the Conservative and Moderate enrollment projections by key grade level groupings.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1738, Packet Page 2066

ELEMENTARY SCHOOL LEVEL
The projected elementary school enrollment shows a significant decline. [More details: Enrollment > Projections > Selected Schools > All Elementary Schools] FIGURE 15

MIDDLE SCHOOL LEVEL
The projected middle school enrollment shows a relatively stable trend. [More details: Enrollment > Projections > Selected Schools > All Middle Schools] FIGURE 16
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1739, Packet Page 2067

HIGH SCHOOL LEVEL
The projected high school enrollment shows a slight decline. [More details: Enrollment > Projections > Selected Schools > All High Schools] FIGURE 17
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1740, Packet Page 2068

SUMMARY OF DISTRICT PROJECTIONS BY YEAR
The complete district-wide projection table for each study is available online. Corresponding sets of individual School Projections are available online as well.

The tables below present a more detailed annual view of projected changes by grade level clusters for both projections. The “Pct Prev Yr” row represents the percent of the previous year’s enrollment in each grade cluster that is projected in the subsequent year. The “5-Yr Change” row represents the percent change projected over the enrollment five years prior.

CONSERVATIVE PROJECTION
Change by Level 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 Kindergarten 581 529 535 541 544 541 525 507 489 510 505 Pct Prev Yr 90% 91% 101% 101% 101% 99% 97% 97% 96% 104% 99% 5-Yr Change 93% 93%
Gr K-6 4377 4129 4072 4051 4026 4015 3892 3779 3666 3781 3736 Pct Prev Yr 100% 94% 99% 99% 99% 100% 97% 97% 97% 103% 99% 5-Yr Change 92% 93%
Gr 7-8 1132 1164 1151 1129 1108 1122 1158 1141 1087 1096 1098 Pct Prev Yr 96% 103% 99% 98% 98% 101% 103% 99% 95% 101% 100% 5-Yr Change 99% 98%
Gr 9-12 3222 3149 3142 3139 3082 3099 3011 2939 2918 2993 2989 Pct Prev Yr 104% 98% 100% 100% 98% 101% 97% 98% 99% 103% 100% 5-Yr Change 96% 96%
District (K-12) 8731 8442 8365 8319 8216 8236 8061 7859 7671 7870 7823 Pct Prev Yr 101% 97% 99% 99% 99% 100% 98% 97% 98% 103% 99% 5-Yr Change 94% 95%
NOTE: The gray column is the most recent history year.

FIGURE 18
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1741, Packet Page 2069

MODERATE PROJECTION
Change by Level 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 Kindergarten 581 552 569 586 598 587 571 556 542 579 562 Pct Prev Yr 90% 95% 103% 103% 102% 98% 97% 97% 97% 107% 97% 5-Yr Change 101% 96%
Gr K-6 4377 4216 4253 4327 4373 4313 4183 4084 3993 4202 4098 Pct Prev Yr 100% 96% 101% 102% 101% 99% 97% 98% 98% 105% 98% 5-Yr Change 99% 95%
Gr 7-8 1132 1180 1183 1178 1179 1199 1247 1233 1179 1199 1192 Pct Prev Yr 96% 104% 100% 100% 100% 102% 104% 99% 96% 102% 99% 5-Yr Change 106% 99%
Gr 9-12 3222 3191 3230 3268 3241 3228 3143 3105 3129 3267 3244 Pct Prev Yr 104% 99% 101% 101% 99% 100% 97% 99% 101% 104% 99% 5-Yr Change 100% 100%
District (K-12) 8731 8587 8666 8773 8793 8740 8573 8422 8301 8668 8534 Pct Prev Yr 101% 98% 101% 101% 100% 99% 98% 98% 99% 104% 98% 5-Yr Change 100% 98%
NOTE: The gray column is the most recent history year.

FIGURE 19
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1742, Packet Page 2070

GRADE LEVEL PROFILE COMPARISON
Another view of grade level enrollment can be seen in the chart below. The current grade level enrollment profile is compared with the projected grade level profile in the five and ten-year future.

FIGURE 20

PROJECTING SCHOOL ENROLLMENT
School projections are primarily a function of the proportion of district students who enroll at a given school, modified by intra-district transfers within a given school level that may occur after initial enrollment, and augmented by inter-district transfer students.

SCHOOL DRAW IMPACT
A draw rate is the percentage of students who enroll in a grade level in a school from a specified geographic area. Open enrollment among district schools is projected using this concept. Except for changes in school boundaries or other changes in policy, historical draw rates from a given geographic area to a specific school (including out-of-district students) are assumed in the projections.

INTRA-DISTRICT TRANSFERS
Transfers within the district are incorporated into the projections to anticipate the movement of students from one district school to another within the same level, e.g., transfer from a neighborhood school to a special school. Recent historical transfer patterns are typically assumed in the projections. [More details: Enrollment > Historical > All Schools > Open Enrollment]

INTER-DISTRICT TRANSFERS
Transfers into the district by out-of-district students, sometimes referred to as ‘permit students’, are an integral part of the district and school projections. Recent historical transfer patterns are typically assumed in the projections.
[More details: Enrollment > Historical > District-Wide > Out of District] ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1743, Packet Page 2071

INDIVIDUAL SCHOOL PROJECTION TABLES
The complete set of individual school projection tables for each study is available online. [More details: Enrollment > Projections > All Schools > Projections]

MYSCHOOLLOCATOR
MySchoolLocator is a web-based service accessible to PowerSchool Predictive Enrollment Analytics clients. This service allows online users to enter a residential address and find out which district schools are assigned to serve them. Public access to MySchoolLocator is via a unique URL on the District's web site. The URL for integration into your district's website can be requested via Support at any time.

Additionally, requests can be submitted to apply custom messages for various geographies which will then be seen by those using MySchoolLocator.

IMPACT OF THE PROJECTIONS ON SCHOOL CAPACITY
Facility challenges, if any, may exist if projected numbers exceed the current school capacity data. These challenges may also manifest differently in a Moderate or Conservative projection. The Moderate projection shows 3 schools with a potential capacity challenge. [More details: Enrollment > Projections > All Schools > Over Capacity] The table below lists up to five schools that are projected to experience the most change in enrollment in the 5-year future based on the Conservative projection. [More details: Enrollment > Projections > All Schools >Ten Percent Change] 5-Yr Pct
Change
10-Yr Pct
Change
-100% -100%
-44% -51%
34% 41%
-29% -31%
-25% -32%
Walter Colton MS
Central Coast HS
Marshall ES
Ord Terrace ES
Dual Language Academy
School
FIGURE 21

IMPACT OF SDC STUDENTS ON CAPACITY
Relative to the impact of SDC students on school capacity, note that SDC students are not included in the grade level counts, but are included in the capacity calculation as taking up one seat each.

ANALYZING/STUDYING/REVIEWING THE ENROLLMENT PROJECTIONS The projections of district and school enrollment are based on a complex mix of historical data, the projection of recent trends, and specific assumptions regarding the future. We strongly encourage our clients to actively engage with the data with the aim of better understanding, further refining, and using the results to inform decisions about to be made. We believe increased effectiveness for both the district and PowerSchool Predictive Enrollment Analytics comes with increased and welcome dialogue.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1744, Packet Page 2072

Graphs or tables may be copied from the PDF version of this document using the Snapshot Tool inside PDF Reader.

Please do not hesitate to contact PowerSchool Predictive Enrollment Analytics regarding any questions or suggestions that may arise regarding these studies.

Respectfully Prepared and Submitted by:

The PowerSchool Predictive Enrollment Analytics Team
February 16, 2023
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1745, Packet Page 2073

APPENDIX

ASSUMPTIONS AND METHODOLOGY
All projections are based on assumptions, and when read or shared are best prefaced with the phrase, “Based on these assumptions…”, or “Based on these historical trends…”. Particularly for projections more than 5 years out, “Enrollment Trend” is a far more accurate descriptor.

Three major factors drive district-wide student enrollment projections. These include:

1. recent kindergarten enrollment trends,

2. changes in the grade level cohorts of students served as they age through, and

3. changes in the number of residential units within the district.

District-wide projections are disaggregated to school projections based on the historical patterns of:

1. the rates at which each school draws enrollment from various sections of the district, and

2. the pattern of transfers within the district at a given level from one school to another.

DISTRICT PROJECTIONS
Studyblocks
For enrollment projections the district is divided into studyblocks. A studyblock is a custom unit of geography created by PowerSchool Predictive Enrollment Analytics for the purpose of generating reliable projections. They are generally based on elementary boundaries or some portion thereof. A studyblock serves as the basis for the analysis of students served by the district and by schools. The objective is to do analysis with a small enough geographic unit to sense small area changes but large enough to allow for reliable projection. Studyblocks typically encompass 500–1000 students.

Kindergarten Enrollment
The projected Kindergarten enrollment is a key variable in projecting K–12 enrollment. The base Kindergarten projection is determined by the trend of Kindergartners served in each studyblock in the previous 3 or 4 years. Depending on the circumstances, a growth trend in Kindergarten enrollment may be capped. Steep straight-line trends are mathematically moderated to avoid unrealistic results.

School Capacities
School capacities provided by the district are compared to projected enrollments. Districts are invited to calculate school capacities in a manner that best serves the enrollment projection environment and provide them to us via Support for entry into the platform.

A Special Day Class (SDC) student at the elementary level is calculated by default as requiring 1 seat.

This value, at district option, may be changed to 3, on the assumption that a class of 10 SDC students will occupy a typical classroom.

Students in the Projections
Enrollment projections are limited to typical K–12 students. SDC students are projected as a stable percentage of the typical population unless all SDC students are mainstreamed. Excluded from the projections are students enrolled in Non-Public School (NPS), Adult High School, Home School, Adult Ed, Independent Study programs and other special schools.

Attendance Boundaries
Attendance boundaries are assumed to remain constant, unless otherwise noted by the district.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1746, Packet Page 2074

Closed Schools
Opportunities for open enrollment (intra-district) are assumed to remain unchanged, unless otherwise noted by the district.

Inter-district Enrollment
Students enrolled from other school districts are treated in aggregate in separate studyblocks. Students in Kindergarten and the initial grade at each level are projected only to the extent they exist in recent years. Students enrolled in other grade level cohorts are aged through to the highest grade at each level.

These defaults may be modified at district request.

Cohort Percent Change
Cohort percentage changes are calculated to assure sensitivity to perennial changes in students served by the district as they age from one grade level to the next. If every cohort were stable as it ages, the cohort percent change, from one grade to the next in each studyblock, would be calculated as 100%. For each studyblock, a cohort weighted average percent change over a defined number of years is calculated based on the change in the enrollment served as it ages from the previous grade level.

Average cohort percentages above 100% might, for example, reflect students returning from private schools. Cohort percentages below 100% might reflect dropouts.

Growth studyblocks are those showing unusually high increases in enrollment and/or cohort percent change in recent years—due, typically, to new housing development. Once growth studyblocks are identified, their default cohort percent change rate is set to 100% so as not to over-project new residential growth. By default, growth is not predicted to continue unless new occupied dwelling units are projected.

Dwelling Unit Impact
The predicted impact of new dwelling units on school enrollment is based on three factors: 1) new dwelling units, 2) the student generation rate for each unit type, and 3) the grade level distribution of newly generated students.

1. Dwelling Units
New dwelling units are categorized into 3 housing types: Single Family Detached, Single Family Attached, and Multifamily. Developers and builders are contacted for information relative to their plans for occupancy of new dwelling units.

2. Student Generation
Student generation rates are determined for each product type for each level: elementary, middle school and high school. Student generation rates are based on similar product types where such exist; otherwise, a default generation rate is used.

3. Grade Level Distribution
For each level, students generated by new dwelling units are distributed across grade levels.

These percentages are based on historical patterns where they exist; otherwise, default percentages are used.

SCHOOL PROJECTIONS
Projecting enrollment at the school level is based on the concept of a school draw rate, i.e., the percent of students from a given studyblock who enroll in a school at its lowest grade. Draw rates reflect the impact of open enrollment within a district. For example, if one-half the sixth graders from a given ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1747, Packet Page 2075

studyblock enroll in a particular 6–8 middle school, that school has a draw rate of 50% from that studyblock.

The draw rate for the most recent year is applied by default to the projected district enrollment for that grade from a given studyblock. The draw rate ages with the cohort. In this way, if the underlying cohort changes, the number of students enrolled at the school will change accordingly.

Draw rates can be adjusted if necessary. Manipulation of draw rates is used, for example, to project the impact of changes in attendance boundaries, or the impact of closing a school to open enrollment.

Intra-district Transfers
Grade-level transfers within or across schools are included in the projections to accommodate fluctuations like retention, transfer to continuation school, or any other special programs a district may offer that result in students changing schools at other than the typical grade configuration shifts.

Transfers are calculated by applying the percent of a grade level population at one school that is transferred in the following year to another school or continued at the same grade level at a given school in the following year.

CAVEATS ON PROJECTIONS AND METHODOLOGY
On Projections
Enrollment projections are based upon two critical factors: the student and school data from the school district and the mathematical formulas that are applied to those data. Projections fundamentally look at recent history as reflected in the student data and assume that past patterns and trends will continue. The calculations assume that the historical data provided is at one-year intervals based on enrollment at the beginning of each school year.

PowerSchool Predictive Enrollment Analytics takes great care in preparing a district’s projections. A range of unpredicted anomalies, however, can cause reality to vary from the historical patterns. These include, but are not limited to, rapid changes in the economy, mortgage interest rates, the housing market, the job market, residential development plans, rental rates, global pandemics, etc. Anomalous changes that occur between the last set of student data and the first projection are not reflected in the projections unless the district works with PowerSchool Predictive Enrollment Analytics to amend the projections.

In the projections, calculations are mathematically precise. Each result is rounded to a whole number for ease of reading. This rounding sometimes results in the displayed whole numbers in a column not adding exactly to the displayed total of the column. This phenomenon, which is a result of rounding and not of any inaccuracy in the calculations, occurs both in the enrollment projections, residential reports, and community demographics.

On Student Data
PowerSchool Predictive Enrollment Analytics obtains historical student data files from the district. To the extent that the student data files are internally inconsistent from year to year, or the count of students in the files does not reflect the count of actual enrollees, errors are introduced to the projection calculations. For optimum results, the student data files must also consistently capture the same categories of students annually.

The calculations assume that the historical data provided is at one-year intervals based on enrollment near the beginning of each school year. It is important that the student files obtained from the district are close to a common date each year, typically near the beginning of the school year. The snapshot of ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1748, Packet Page 2076

historical data near the beginning of the school year is best suited to our goal of projecting enrollment for the beginning of subsequent school years. To the extent the historical student data provided is not at one-year intervals or is not at a common date near the beginning of the school year, projections may reflect monthly fluctuations in enrollment that will diminish the accuracy of the projections.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1749, Packet Page 2077 www.powerschool.com
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1750, Packet Page 2078

APPENDIX
H

TRANSPORTATION

VMT AND EVACUATION

ASSESSMENT
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1751, Packet Page 2079 This page intentionally left blank.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1752, Packet Page 2080

TABLE OF CONTENTS
Vehicle Miles Traveled (VMT) Analysis..................................................................................... H-1 Evacuation Route Capacity Assessment..................................................................................H-8 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1753, Packet Page 2081 City of Monterey General Plan Housing Element Update
DRAFT Vehicle Miles Traveled (VMT) Assessment
Memorandum
To: Andrew Hill, MUP
Principal

DYETT & BHATIA

From: Ayberk Kocatepe, PhD.

Frederik Venter, PE
Michael Schmitt, AICP CTP, PTP, RSP1
Chris Gregerson, PE, TE, PTP, PTOE
Re: City of Monterey General Plan Update
Vehicle Miles Traveled (VMT) Analysis

Date: December 11, 2023
This memorandum documents the Vehicle Miles Traveled (VMT) analysis completed for three scenarios (2023 Baseline, 2031 No Project, 2031 with Project,) for the City of Monterey General Plan Update. This VMT Analysis is provided to support the CEQA analysis for the City’s General Plan Update project, which includes updates to the Housing, Safety, Land Use, and Circulation Elements of the General Plan.

Methodology and Assumptions
Based on the land use information provided, for the purposes of SB 743 analysis and the determination of transportation-related significant impacts, the following major land uses were analyzed:
§ Residential
§ Employment-based (Manufacturing and Mining, Construction, Finance and Real Estate, Service, Public, Agriculture, Wholesale, Education, Health)
The most recent version of the Association of Monterey Bay Area Governments Regional Travel Demand Model (AMBAG RTDM), which was released in 20221
, served as the primary tool for calculating VMT
across all land uses. The AMBAG RTDM has a base year of 2015 and a future year of 2045. Both the base year and future year versions of the AMBAG RTDM were employed to assess the VMT impacts of the land uses across three specific analysis scenarios. The land uses were evaluated based on these scenarios:
§ Baseline – 2023 land use in the incorporated and unincorporated areas of the County § 2031 No Project – 2031 land uses in the incorporated and unincorporated areas based on the housing element (HE) update in the County, excluding the City of Monterey. § 2031 With Project – 2031 land uses in the incorporated and unincorporated areas based on the HE update in the County, including the City of Monterey.

SB 743 Background and City of Monterey Thresholds of Significance SB 743 is an effort by the California legislature to improve California’s sustainability and reduce greenhouse gas emissions through denser infill development, a reduction in single occupancy vehicles, improved mass transit, and other actions. VMT is widely accepted as a reliable proxy for evaluating Greenhouse Gas (GHG) and other transportation related impacts that the State is actively trying to address.
1 The AMBAG RTDM was provided to Kimley-Horn by AMBAG staff on September 23, 2022.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1754, Packet Page 2082 City of Monterey General Plan Housing Element Update December 11, 2023 DRAFT Vehicle Miles Traveled (VMT) Assessment Page 2 of 7 In January 2019, the California Natural Resources Agency finalized updates to the CEQA Guidelines including the incorporation of SB 743 modifications. The Guidelines’ changes were approved by the Office of Administrative Law and are now in effect. Specific to SB 743, Section 15064.3(c) states, “The provisions apply statewide as of July 1, 2020.”
To aid lead agencies with SB 743 implementation, the Governor’s Office of Planning and Research (OPR) produced a VMT Guidelines2 document that included detailed guidance about the variety of implementation questions they face with respect to shifting to a VMT metric.

This SB 743 compliant analysis was performed based on guidelines established by the City of Monterey, for determination of potential VMT related transportation impacts caused by the Project to the surrounding area. The City of Monterey’s VMT thresholds consider the VMT performance of residential and non-residential components of a project separately, using the efficiency metrics of VMT per capita and VMT per employee, respectively. The City of Monterey’s VMT thresholds of significance are summarized below for each of these components:
§ Residential – 15% below baseline (existing) average VMT per Capita § Employment-based land uses (e.g., office) – 15% below baseline (existing) average VMT per Employee
Land Use Inputs
The land use projections for the City of Monterey 2031 Housing Element Update, specific to each analysis scenario, were sourced from the Client, the City, and AMBAG staff. These were analyzed with the following considerations and adjustments:
§ For the Environmental Impact Review (EIR) to mirror the City's actual conditions, the employment assumptions for the 2023 Baseline were adjusted. However, the total employment growth (control total) between 2023 and 2045 was kept consistent. § Employment growth between 2023 and 2045 was redistributed to the relevant City Traffic Analysis Zones (TAZs) to reflect land use and zoning changes that would be made for implementation of the 2031 General Plan Update. A total of 457 jobs were removed from TAZs and added to other TAZs, accordingly. The overall projected increase in new jobs within the City from 2015 to 2045 remains unchanged, totaling 7,415 jobs. § The growth of unoccupied housing units (i.e., households) in the City of Monterey from 2023 to 2031 is 5,682 units. In areas of the County excluding the City of Monterey, the growth amounted to 17,065 units.
§ The 6th Cycle Housing Element Update for the City and the adjacent cities in the County includes adjustments to occupied household estimates in terms of vacancy rates, overcrowding percentages, need for replacement housing, and percent of households that are cost-burdened.

However, direct integration of these factors would result in overestimating the number of trips and total population unless significant changes are made to the model structure and underlying demographic forecasts, particularly as it relates to occupancy rates and persons per household. In addition, direct integration of these factors at the TAZ level, while the Regional Housing Needs Allocation Plan is at a larger scale, could result in misleading forecasting results. Hence, we used adjustment factors in accordance with the 2023-2031 Regional Housing Needs Allocation (RHNA 6) to reasonably estimate occupied housing units in the County. 2 Technical Advisory on Evaluating Transportation Impacts in CEQA. Governor’s Office of Planning and Research, State of California. December 2018.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1755, Packet Page 2083 City of Monterey General Plan Housing Element Update December 11, 2023 DRAFT Vehicle Miles Traveled (VMT) Assessment Page 3 of 7 § Per the California Department of Housing and Community Development (HCD) guidance, 120 new ADUs in established single-family neighborhoods were distributed across the City. § To estimate the VMT more precisely in two expansive TAZs that included new residential developments (TAZ 577 and TAZ 771), these zones were split into multiple TAZs that covered smaller areas. The splits were done because otherwise, traffic would have been directed to inappropriate roadways, leading to flawed VMT projections. § The AMBAG RTDM does not feature interim years such as the 2031 analysis year, instead featuring just the base year of 2015 and the future projection of 2045. Thus, for 2031 land use approximations, values were interpolated based on the growth observed between 2023 and 2031.
§ The 2031 No Project scenario includes projected land use changes for 2023-2031 in the County excluding the City. The 2031 With Project scenario includes projected land use changes for 2023- 2031 in the County including the City.

The land use totals for the proposed scenarios are summarized in Table 1 below.

Table 1 – Land Use Inputs
Scenario Households
(City)
Employment
(City)
Households
(County)
Employment
(County)
2023 Baseline 13,421 22,246 132,414 217,512
2031 No Project 13,603 24,220 151,085 227,882
2031 With Project 18,725 24,220 156,207 227,882
The AMBAG RTDM adopted in 2022 provides land uses based on residential and employment classifications. Employment classifications are broken into eleven categories that group together various industries based on similar trip-making characteristics. Note that the eleven employment categories were an expansion compared to the previously adopted AMBAG model, which only contained six employment categories. Table 2 below shows the cross-reference between the North American Industry Classification System (NAICS) industries and AMBAG sectors.

Roadway Network Assumptions
The baseline transportation network model uses the 2015 roadway network from the AMBAG model. For both the 2031 With Project and 2031 No Project scenarios, the network is derived from the 2045 AMBAG model roadway network, under the assumption that there will be no modifications to the transportation network from 2031 to 2045. After dividing the TAZs, connectors were employed to link the new TAZs to the current roadway system. Nevertheless, there were no additions or alterations to the roadway segments.

Table 2 – AMBAG RTDM Employment Categories
Category Description and NAICS codes
Agriculture (AGR) Agriculture, Forestry, Fishing, and Hunting (11)* Construction (TR_CON) Construction (23), Utilities (22), Transportation and Warehousing (48-49), Administrative and Support and
Waste Management and Remediation Services (56),
Public Administration (92)*
Manufacturing and Mining (MFG) Mining (21), Manufacturing (22, 31-33), Wholesale (WHL) Wholesale Trave (42), Agriculture, Forestry, Fishing, and Hunting (11)*
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1756, Packet Page 2084 City of Monterey General Plan Housing Element Update December 11, 2023 DRAFT Vehicle Miles Traveled (VMT) Assessment Page 4 of 7 Retail (RET) Retail Trade (44-45), Agriculture, Forestry, Fishing, and Hunting (11)*
Finance and Real Estate (FIRE) Information (51), Finance and Insurance (52), Real Estate Rental and Leasing (53), Professional, Scientific, and
Technical Services (54), Management of Companies and
Enterprises (55)
Education (EDU) Educational Services (61), Public Administration (92)* Healthcare (HLT) Health Care and Social Assistance (62) Service (SER) Art, Entertainment, and Recreation (71), Accommodation and Food Service (72), and Other Services (81)
Public (PUB) Public Administration (92)*
Self Self-Employed
*Note: Some NAICS industry sectors have been divided up, based on business operations and transportation demand, across AMBAG sectors.

Analysis
The following sections detail the analysis completed:

Residential and Employment-based Land Uses
The VMT for the residential land uses was computed by combining the production VMT for all HomeBased trip purposes. VMT for non-residential land uses was computed from the attraction Home-Based Work VMT. The external VMT for residential land uses was determined by multiplying the calibrated external trip distance by TAZ determined using big data (Replica) by the total internal-external (I-X) HomeBased trips for that TAZ. The external VMT for non-residential land uses was determined by multiplying the calibrated external trip distance by TAZ determined previously by the total internal-external (I-X) Home-Based Work trips for that TAZ.

To determine the share of the non-residential VMT for the employment-based land uses, the total number of trips attracted to each TAZ was calculated by multiplying the model’s underlying trip generation rate for the Home-Based Work trip purpose by employment type. The land use share of the total VMT was then calculated by dividing the number of trips by employment by the total number of Home-Based Work Trips calculated using the trip generation rates. The VMT for the employment-based land uses was calculated by multiplying the land use share by the total Home-Based Work VMT (including External VMT).

Residential and employment-based VMT per Capita and VMT per Employee, respectively, for each TAZ were computed by dividing the residential and non-residential VMT by TAZ by the total population or total employees.

As this analysis provided an opportunity to update the City’s thresholds, the VMT per capita and VMT per employee were calibrated using measured VMT per capita and VMT per employee with Monterey County supplied by Replica, a big data platform that collects trip data from around the United States. The VMT calibration was completed by first calculating the percent difference in VMT per capita and VMT per employee for each TAZ and each employment type between the base year and 2031 scenarios, both No Project and Plus Project. As the base data only does not separate VMT per employee by employment type, a weighted average VMT per employee percent difference was calculated based on the number of employees in each TAZ for each scenario. The base data is also categorized by Census Block Group rather than by TAZ, so each model TAZ was associated with its own Block Group. A VMT per capita and VMT per employee percent difference for each Block Group was calculated using a weighted average based on the ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1757, Packet Page 2085 City of Monterey General Plan Housing Element Update December 11, 2023 DRAFT Vehicle Miles Traveled (VMT) Assessment Page 5 of 7 total population and employment, respectively, for the TAZs within each Block Group. This percent difference was then applied to the base VMT per capita and VMT per employee for each Block Group to calculate a VMT per capita and VMT per employee for the 2031 No Project and 2031 Plus Project scenario for each Block Group. The Block Groups located in the City of Monterey where then combined to calculate a citywide VMT per capita and VMT per employee, as shown in Table 3.

Table 3 summarizes the VMT evaluation across the analysis scenarios, as well as the City’s calculated residential and employment VMT per capita and VMT per employee thresholds. The thresholds were determined by setting them 15% lower than the baseline county-wide average VMT per capita and per employee, consistent with current City of Monterey guidelines. As shown in Table 3, the thresholds were calculated to be 14.3 VMT per capita for residential uses and 18.9 VMT per employee for employment uses.

The 2031 No Project scenario resulted in a VMT per capita of 12.9 and VMT per employee of 24.4. The 2031 Plus Project scenario resulted in a VMT per capita of 11.6 and VMT per employee of 24.5. Notably, both 2031 scenarios—whether No Project or With Project—do not exceed the VMT thresholds for residential. However, both 2031 scenarios result in employment-based land uses exceeding the threshold. It should be noted that the VMT per capita value is reduced by 1.3 VMT per capita between the 2031 No Project and 2031 Plus Project scenarios for residential uses. However, the VMT per employee value is increased by 0.1 VMT per employee between the 2031 No Project and 2031 Plus Project scenarios for employment uses.

Table 3 – Vehicle Miles Traveled (VMT) by Scenario
Jurisdiction 2031 No Project 2031 Plus Project
VMT/Capita VMT/Employee VMT/Capita VMT/Employee
Threshold 14.3 18.9 14.3 18.9
City of Monterey 12.9 24.4 11.6 24.5
City of Monterey (% Threshold) 90.2% 128.9% 81.1% 129.3% Over Threshold? No Yes No Yes
Findings
Based on the results of this analysis, the following findings are made:
§ The residential land uses do not exceed the threshold of significance for the 2031 Project and 2031 No Project scenarios. Both the 2031 No Project and 2031 With Project scenarios are determined to not have a significant transportation impact for residential land uses. § The employment-based land uses exceed the threshold of significance for the 2031 No Project and 2031 With Project scenarios. As a result, the Project is determined to have a significant transportation impact for employment-based land uses.

Note that specific development projects may perform better or worse than the overall impacts determined by this programmatic level analysis. However, in the aggregate, it is likely that this VMT analysis represents a worst-case scenario given that it does not fully represent the effect of planned VMTreducing design principles or the effect that targeted mitigation measures may ultimately have on development projects.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1758, Packet Page 2086 City of Monterey General Plan Housing Element Update December 11, 2023 DRAFT Vehicle Miles Traveled (VMT) Assessment Page 6 of 7 VMT Reducing Design Principles, Policies, and Improvements It's challenging to comprehensively account for the influence of particular design principles, policies, and enhancements that could reduce VMT in this analysis. Nonetheless, these strategies remain vital when interpreting the outcomes of this VMT assessment, and where relevant, they should be incorporated in future VMT evaluations within the City.

VMT Reducing Design Principles
Project design features that reduce VMT can potentially lower the overall VMT of the project.

Considerations include:
§ Compactness of design/Transit Oriented Development,
§ A range of housing options,
§ Incorporation of mixed uses,
§ Walkable community, and
§ A variety of transportation options, and
§ The preservation of open space.

Since the AMBAG Model doesn't inherently cater to the effects of several design principles detailed and the precise characteristics, location, and timeline of these VMT-reducing strategies are uncertain, the additional impact of these design elements will necessitate assessment at the specific project level.

However, it's crucial to understand that these factors will significantly influence the analysis of development projects, though the extent will depend on the chosen location and design features.

VMT Reducing Policies and Improvements
This section delves into the establishment of a framework for a programmatic approach to policies and improvements that respond to the need for feasible VMT mitigation within the City. The pinpointed opportunities for VMT mitigation include:
§ Transportation Demand Measures
§ 2045 Metropolitan Transportation Plan & the Sustainable Communities Strategy § Participation in a VMT Bank
§ VMT Reducing Design Principles
Transportation Demand Measures
VMT mitigation typically depends significantly on Transportation Demand Measures. Generally, these measures encompass two primary strategies: policy-based and infrastructure-related. The California Air Pollution Control Officers Association (CAPCOA) guide for Quantifying Greenhouse Gas Mitigation Measures is one of the primary bases for estimating mitigation effects in California. The most recent version of CAPCOA’s Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity was published in January 2022. While this resource is of great significance, caution is essential when applying it, especially since some measures come from smaller sample sets and many measures are rooted in observations from densely urbanized regions.

Depending on the chosen measures, they can pose challenges in terms of mitigation monitoring.

Furthermore, they are often not favored by project applicants because of the potential need to be managed and paid for in perpetuity. Such constraints have led authorities to gravitate towards programmatic strategies for VMT mitigation.

The team reviewed measures to find those fitting for the City and to determine their maximum potential in reducing VMT. While some options can be applied to specific projects, many are more effective when ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1759, Packet Page 2087 City of Monterey General Plan Housing Element Update December 11, 2023 DRAFT Vehicle Miles Traveled (VMT) Assessment Page 7 of 7 used systematically. The measures listed below are considered suitable for a systematic approach in Monterey:
• Reduce Parking Supply
• Transit Stops
• Travel Behavior Change Program
• Promotions & Marketing
• Emergency Ride Home (ERH) Program
• Bike Share
• Implement/Improve on-street and on-site Bicycle facilities • Affordable Housing
2045 Metropolitan Transportation Plan & the Sustainable Communities Strategy AMBAG developed a Sustainable Communities Strategy (SCS) which was integrated into the Metropolitan Transportation Plan (RTP). According to the AMBAG MTP/SCS, the region is intended to meet or surpass these objectives, aiming to considerably reduce greenhouse gas emissions by 2045. The AMBAG MTP/SCS outlines various approaches to reach these aims. These approaches emphasize the integration of land use planning with transportation enhancements. A few primary approaches from the MTP/SCS relevant to the City are listed below:
§ Improve job-housing balance in the region
§ Focus new growth around transit
§ Improve transit network
§ Promote and improve active transportation
§ Promote shared mobility
Participation in a VMT Bank
Programmatic approaches, where large infrastructure projects are jointly funded, show potential for VMT reduction. This is because they allow projects to pay a one-time fee proportional to their impact without the need for continuous monitoring or management. Plus, these strategies can benefit the public by funding transportation improvements that might not be built otherwise. This can lead to less traffic congestion, lower GHG emissions, more transport options, and more chances for active transportation.

In a VMT Banking framework, various VMT-reducing projects are bundled, and their VMT reductions are turned into buyable credits. These credits can then be bought to offset VMT over thresholds. The projects in the bank can benefit either the wider region or just the local area. However, having a VMT Bank could offer valuable options for developments that might otherwise struggle to lessen their impact.

VMT Mitigation
It is not possible to fully account for the effect of specific design principles, policies, and improvements that will reduce VMT as part of this analysis. Although many of the VMT-reducing design principles, policies, and improvements that are described in the prior section may ultimately mitigate and/or potentially reduce the VMT impacts outlined in this evaluation, necessary details to assure implementation and appropriately evaluate their effect are not yet available. The VMT-reducing approaches cited in the prior section will require further planning and development as well as committed funding sources including those from participants in the development community (many of which may not be identified yet as large areas of land may be further subdivided into specific projects and development
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1760, Packet Page 2088 City of Monterey, Evacuation Assessment, Page 1
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 October 17, 2023
Andrew Hill, MUP Principal

DYETT & BHATIA
Urban and Reginal Planners 4001
Howe Street
Oakland, CA 94611
Re: City of Monterey,CA
Evacuation Route Capacity Assessment
Monterey, California
Kimley-Horn and Associates, Inc. (“Kimley-Horn” or the “Consultant”) is tasked to conduct an evacuation route capacity analysis for the City of Monterey General Plan Update. This provides an assessment of roadway capacity under the described wildfire and flood scenarios in compliance with SB99 and AB747.

Introduction and Purpose
This document is an assessment of the City of Monterey’s roadway capacity during a variety of evacuation scenarios. It evaluates the ability of the roadway system to accommodate an evacuation event under a worse-case scenario in the City of Monterey. A worse-case scenario for this analysis is defined as two simultaneous natural events (wildfire and flooding). The purpose of this is to test the roadway under a worst-case scenario, that is a short-notice evacuation.

During short notice evacuation worse case scenario, it wouldn't be reasonable to assume to coordinate complex instructions and or Presidio. Coordination with other agencies and establish required traffic controls. Under the circumstances, they are encouraged to navigate to well-established routes they know.

Background
Recent regulations related to emergency evacuation that are addressed in this assessment include the following bills and guidelines passed by the State of California.
• Assembly Bill (AB) 747: Local governments must update their safety elements to identify evacuation routes and their capacity, safety, and viability under a range of emergency scenarios. This requirement applies to all safety elements or updates to hazard mitigation plans completed after January 2022. • Senate Bill (SB) 99: Local governments must update their safety elements to identify residential developments in hazard areas that do not have at least two emergency evacuation routes. • State of California, Office of the Attorney General Best Practices for Analyzing and Mitigating Wildfire Impacts of Development Projects Under the California Environmental Quality Act (CEQA): This guidance document recommends that local governments use evacuation modeling and analysis to assess the impact of new development on evacuation and emergency access.

In other words, California law now requires local governments to consider evacuation routes and emergency access when planning and approving new developments in high wildfire-risk areas. This assessment uses evacuation modeling and analysis to assess the ability of the City’s transportation system to provide adequate emergency evacuation capacity during a wildfire and flood evacuation, considering areas under very high wildfire and/or high flooding risk.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1761, Packet Page 2089 City of Monterey, Evacuation Assessment, Page 2
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Evacuation analysis is done by evacuation modeling. This is a systematic approach used to simulate and plan the movement of people from areas at risk to places of safety. It involves the use of computer-based models and realworld data to predict how individuals and vehicles will respond and move during an evacuation.

Key Components of Evacuation Modeling:
• Geographical Data: Data about the area under threat, including road networks, population density, and hazard zones. This information helps us understand the physical layout of the region. • Behavioral Data: Data about how people typically behave during evacuations. This includes factors like the time it takes for individuals to decide to leave, how they choose their evacuation routes, and their preferred modes of transportation.
• Transportation Infrastructure: Understanding the capacity of the roadways, bridges, and public transportation systems is critical.

One of the crucial indicators in evacuation modeling is the "volume over capacity ratio." This ratio indicates whether there are too many vehicles on the roads compared to what the roads can handle comfortably. • Volume: This refers to the actual number of vehicles and people trying to evacuate. • Capacity: Capacity represents the maximum number of vehicles and people that the transportation infrastructure can handle without causing congestion and delays. • Ratio: When the volume exceeds the capacity, it results in a high volume over capacity ratio, indicating potential congestion and delays in the evacuation process.

SB 99 Accessibility Analysis
Kimley-Horn reviewed the evacuation routes and evacuation shelter area (Monterey Fairgrounds) provided by the city, which are attached to this report as Attachment 1. Under a short-notice evacuation condition, the shelter is not a consideration and is not being activated under the modeling scenarios. Monterey Fairgrounds would be used for longnotice evacuation destinations. The review process focused on identifying wildfire and flooding hazard zones and how these zones/areas would impact evacuation routes and evacuation capacity. From Monterey Bay, the City has steep slopes and constrained road access, and the Presidio of Monterey creates a major east-west barrier within the City for roadway access. These constraints limit the number of available evacuation routes, as described below:
• Topography and the Pacific Ocean limit access to the west such that emergency access is limited to the following roadway facilities such as:
o Veterans Dr
o Skyline Dr
o Via Del Rey
o Via Gayuba
o Pacific St
o Mar Vista Dr
o Soledad Drive
• The Presidio of Monterey limits access to the northwest of the city such that emergency access is limited to:
o Lighthouse Ave
A review of hazard zones shows that the city's south/southeast and west regions exhibit a very high risk of wildfire and ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1762, Packet Page 2090 City of Monterey, Evacuation Assessment, Page 3
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 a high risk of floods (Attachment 1), as described below:
• Parts of Josselyn Canyon and the Flats (Wildfire)
• East of Holman Highway (Wildfire)
• East of Highway 1 and west of La Mesa Village (Wildfire) • Monterey Bay Park, Del Monte Avenue, Camino El Estero, and Camino Aguajito (Floods). Based on FEMA hazard maps, and the adopted city of Monterey GP in 2019, Lighthouse Ave tunnel is not a high-risk flood zone area. However, it is understood that tunnel floods during heavy rain events. Fremont Street would continue to be the primary evacuation route for the designated areas. This analysis is only focusing on the worst-case scenario analysis for the highest-risk zones. Nevertheless, since Del Monte Ave is closed, the traffic is already being diverted to Fremont Ave. It means that Lighthouse Ave is not being used.

In a worst-case scenario, all southern conduits such as Highway 68 could be blocked for neighborhoods such as Skyline, and Monterey Vista, cutting off the northwest of the City such as New Monterey, Presidio, and Pacific Grove.

Furthermore, during a short-notice evacuation, evacuees are encouraged to navigate to well-established routes they know and move away from the hazard areas as far as possible.

To address this risk, two destination points (shown in Attachment 2 and Attachment 3) have been identified on the east and northeast sides of the city in compliance with the available evacuation routes. The destination selected on the north is located at Highway 1 at the Fremont Blvd/Del Monte Blvd Interchange and Seaside The destination selected on the east is located on Highway 68 at York Road in Ryan Ranch. Evacuation access across the city was assessed by looking at how far people would possibly have to travel during an event. This methodology offers insights into evacuation accessibility and aids in pinpointing communities that might confront heightened risks amidst evacuation occurrences. To do this, we used the city parcels to evaluate the accessibility of the neighborhoods. The assessment, illustrated in Attachment 2 and Attachment 3, identifies the shortest distance to those two exit points.

Constrained Parcel Groups
The analysis was conducted to identify residential parcels in the city and within hazard zones that are restricted to a single emergency access route. Note, that the city’s designated zones for wildfire and flood hazards are situated in contrasting locales, resulting in distinct clusters of constrained parcels and roadways pertinent to each type of hazard.

Having parcels with constrained access is highly detrimental during an evacuation, as it significantly impedes the swift and orderly movement of residents to safer locations. Such limitations can lead to congestion, delayed emergency response times, and heightened risk to life and property, especially in high-risk areas where rapid evacuation is imperative due to imminent threats. Attachment 4 delineates the mapped locations of all constrained residential parcel groups located in the city.

Attachment 5 outlines constrained parcels located in the areas of Skyline Forest, Monterey Vista, and smaller portions of Old Town neighborhoods which are at heightened risk of wildfires and are restricted to a single emergency access route. Attachment 6 indicates constrained parcels in The Flats neighborhood situated to the southeast of MontereySalinas Highway (SR 68), that are also under very high wildfire hazard risk and are restricted to a single emergency access route. Attachment 7 indicates the areas and parcel groups with limited access under potential high-flooding risk such as Del Monte Beach and Lake El Estro.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1763, Packet Page 2091 City of Monterey, Evacuation Assessment, Page 4
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Evacuation Route Capacity Assessment
The assessment of route capacity was conducted consistent with AB 747 requirements, particularly focusing on its capability to facilitate an evacuation during wildfires and/or floods. The relevance of AB 747 lies in its mandate to ensure the optimal utilization of transportation systems during evacuations, and it attempts to provide a structured approach to analyzing and enhancing existing setups.

When undertaking this review, reasonable assumptions were made to facilitate the analysis and allow for more streamlined and focused research. The nature of evacuation scenarios is complicated and involves many of unpredictable and dynamic elements. With the abundance of variables, ranging from human behaviors to the suddenness of events, factoring every possible scenario is not possible. Given this complexity, it is pivotal to introduce assumptions to create a manageable framework that allows us to run specific scenarios and derive meaningful insights and conclusions that can guide further detailed investigations and refinements of our models.

Two distinct areas were identified in collaboration with city staff as • Very High-Risk Fire Hazard Zones (VHFHZ) are indicated in the Attachment 8. • High-Risk Flood Zone also indicated in Attachment 8.

For the very high-risk fire hazard zones (VHFHZ), evacuation analysis was only conducted for the area located in the Skyline, Monterey Vista, and parts of Old Monterey areas as discussed with city staff. The very high-risk wildfire area in the Flats has evacuation routes along Aguajito Road and Josselyn Canyon Road. Further evacuation analysis is not required for this area.

Modeling Assumptions
• The analysis focuses on the Skyline, Monterey Vista, Old Monterey area, and the high-risk flood zone area as depicted in Attachment 8. The Flats were assessed qualitatively. • The analysis is based on a single, multi-hazard evacuation scenario, which represents a worst-case situation encompassing both very high fire hazard (Local Responsibility Area) and high -flood risk. The analysis aligns with the city of Monterey's 100-year flood zone and FEMA's 1% annual chance of flood hazard maps that estimate the high chance of flooding on Del Monte Ave, Camino El Estero, and Camino Aguajito. Note that FEMA flood maps show how likely it is for an area to flood. Any place with a 1% chance or higher chance of experiencing a flood each year is considered to have a high risk. Those areas have at least a one-in-four chance of flooding during a 30-year mortgage. FEMA’s 1% annual chance of flooding is used for evacuation analysis.
• The evacuation notice is a short notice, issued abruptly early in an off-peak when all residents are at home and evacuation demand traffic would be at its highest. The off-peak is defined as hours outside of the morning and afternoon peak periods that occurs 6 AM-9 AM and 4 PM-7 PM. • Given the short notice for an evacuation, it is assumed that all evacuee traffic will enter the transportation network at the same time. Typically evacuation occurs in an S-curve in which most trips occur in a short time. In addition, the AMBAG Travel Demand model cannot simulate an S-curve evacuation. This analysis produces slightly conservative results, which is acceptable for the purposes of this analysis. • No evacuation is assumed for Pacific Grove since the fire location poses a direct threat to Monterey only. • For the purpose of this analysis, traffic is directed towards designated evacuation routes. • This analysis does not account for "shadow evacuees" – individuals who depart even if not explicitly instructed to.
• All evacuees who head towards two exit destination points (shown in Attachments 2 and 3) have been ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1764, Packet Page 2092 City of Monterey, Evacuation Assessment, Page 5
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 identified on the east and northeast sides of the city in compliance with the available evacuation routes.

The destination selected on the north is located at Highway 1 at the Fremont Blvd/Del Monte Blvd Interchange and Seaside The easterly destination point selected is located on Highway-68 at York Road in Ryan Ranch. Given the short-notice evacuation, the evacuation shelter would have not been prepared in advance, so it is not related to short-notice evacuation. • The number of evacuees per vehicle is determined using household size and vehicle ownership data based on the Association of Monterey Bay Area Governments (AMBAG) Travel Demand Model (TDM) which includes LEHD, Census, American Community Survey (ACS), and local data. • Roadway capacities adhere to existing conditions.
• Background traffic which would be already on the network when an evacuation occurs compromises 15% of the capacity of the roadways in off-peak. This traffic is referred to as the unaffected background traffic for an evacuation event.
• This analysis does not assume any evacuation from people using boats or airlifts. • Holman Highway is operating with 10% capacity as an evacuation route because of its location of proximity to high-risk wildfire. This 10% is only available for dispatch units as well as other operational vehicles. Local streets, collectors’ streets, and arterials will be utilized to gain access to gain access to Highway 1 to evacuate to destination points. As shown in Attachment 8, the area notably lacks proximal evacuation routes.
• Due to flooding risks, Del Monte Boulevard is inaccessible between Camino El Estero and Camino Aguajito, as per the 100-year flood zone. The tunnel flooding also cuts of access to Del Monte Boulevard between the tunnel and the flood zone.
• The scenario analysis employs the most recent AMBAG model. This model, accommodating the Sixth Cycle RHNA projections for the City of Monterey and all other jurisdictions on the Monterey Peninsula, integrates the updated land use and accompanying projections Additionally, the model has been updated to account for actual 2015 employment levels in the City.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1765, Packet Page 2093 City of Monterey, Evacuation Assessment, Page 6
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Land Use
The assessment was executed focusing on the scenario for emergency evacuation that evacuates all households and employment shown in Attachment 8. To approximate the number of vehicles involved in such evacuations, references were made to the number of inhabitants, expected vehicle ownership per household, and the number of employees within the designated area. The information regarding land use within the evacuation zone for the evacuation route capacity analysis is summarized in Table 1.

Table 1 Evacuation Zone Land Use
Land Use 2031 Conditions
Households 1,506
Population 3,314
Employment 1,048
Source: AMBAG model 2031 Build-out Projections
In creating this scenario, several key land use assumptions have been made. One such assumption is the notion that households without access to a personal vehicle would inherently depend on external support to evacuate. This element is crucial, and while it was not the main focus of this assessment, it raises a significant point of consideration for the City. The development of programs or initiatives, potentially involving public transit or community-based solutions, could be vital in ensuring the seamless evacuation of such households, contributing to the overall efficacy and inclusiveness of our evacuation strategy.

It is presumed that employment centers would undertake the responsibility of facilitating the evacuation of employees lacking personal vehicles to the extent that employees would be at their place of work at the early off-peak time of day assumed for the multi-hazard scenario. This assumption is integral to creating a comprehensive evacuation model that encompasses not only residents but also the working population within the area, ensuring that all individuals, regardless of their access to personal transportation, are accounted for and assisted during emergency evacuations.

Another layer of our assumptions delves into the practical utilization of vehicles within multi-vehicle households during an evacuation. Specifically, it is assumed that households possessing more vehicles than licensed drivers would inevitably face limitations in mobilizing all their vehicles when an evacuation is warranted. For instance, households with three or four vehicles, but inhabited by only two licensed drivers, are anticipated to leave some vehicles behind.

This assumption is not a trivial one; it impacts the accuracy of our vehicle flow models and helps in refining the projections related to traffic volumes and congestion levels during evacuation events. Table 2 provides the total vehicle trips based on the assumptions discussed above.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1766, Packet Page 2094 City of Monterey, Evacuation Assessment, Page 7
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Table 2 Evacuation Demand
Evacuee type
Number of
Vehicles per
HH or Emp
Total Vehicle
Trips
Zero Vehicle Households 1 64 64
One Vehicle Households 1 486 486
Two Vehicle Households 2 564 1,128
Three Vehicle or more Households 2.5 392 980
Employees 1 1,048 1,048
TOTAL 3,706
Model Analysis and Results
Based on the land use and modeling assumptions, Kimley-Horn has developed a model using a software called CUBE to simulate the evacuation scenario. The results of the model analysis are illustrated in evacuation volume over capacity plot shown on Attachment 9. The results reveal that the evacuation proceeded through three local corridors: SkylineVeterans Drive, Via Gayuba-Martin Street-El Dorado Street, and Mar Vista Drive-Soledad Drive. Evacuees navigated these corridors to access the main evacuation routes: Highway 1, Munras Avenue, and Fremont Street.

The volume over capacity plot (Attachment 9) only shows the roadway segments with V/C ration higher than 0.08. The plot indicates that the evacuation-induced traffic volumes largely remained below the capacity within the evacuation zones and their immediate vicinities. However, volumes surpassed capacity as traffic approached Highway 1, specifically at the interchanges of Fremont Street-Highway 1, and Soledad Drive-Highway 1. Upon accessing the primary evacuation routes, the traffic conditions are favorable, with sufficient capacity to facilitate a smooth evacuation, as depicted in Table 3. The V/C indicates that evacuation does not impact traffic down Lighthouse Avenue On a systemwide basis, the roadways have adequate capacity for an evacuation. The analysis indicates that the overall capacity is 9,300, and the evacuation demand is 3,706 vehicles.

This analysis indicates that the existing roadways possess adequate capacity to accommodate evacuation traffic.

However, it’s pertinent to acknowledge the inherent unpredictability and potential irregularities in driver behavior during emergency scenarios.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1767, Packet Page 2095 City of Monterey, Evacuation Assessment, Page 8
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 Table 3 Evacuation Route Capacities
Roadway Outbound
Lanes
Evacuation
Capacity
(veh per
hour)
Highway 1 2 3,600
Munras Avenue 2 3,000
Fremont Street 2 2,700
Total 9,300
The evacuation capacity refers to the roadway capacity being reduced by 15% because of the background traffic
Tsunami and Evacuation
In the event of an earthquake, it quickly generates a tsunami that reaches Monterey's coastline within minutes. This seismic event may also lead to a landslide in the Monterey Canyon. It is anticipated that earthquake sirens and tsunami warnings will be activated promptly.

Areas at risk of flooding (Attachment 10), including neighborhoods like Old Town, should be prepared for residents to move to higher ground which may be a few blocks away without delay. Unlike wildfire evacuations, there may not be enough time for a traditional evacuation process. If a tsunami is generated further out in the Pacific Ocean, the city will have a longer lead time for orderly evacuation utilizing all city streets before the tsunami wave arrives.

In the Canary Row-Lighthouse district, residents at risk of a tsunami's impact would need to move uphill, roughly beyond the Canary Row/Monterey Bay Scenic Trail. Attachment 10 also highlights that the Lighthouse curve would be prone to flooding, including the risk of the Lighthouse Tunnel submerging, along with several downtown blocks. In response, residents in these locations should promptly evacuate uphill upon hearing tsunami warning signals generated when the tsunami originates from the Monterey Canyon.

As for the Lake El Estero area, it is expected to suffer the most severe flooding during a tsunami event, affecting both Del Monte Ave and Fremont Street. Attachment 10 indicates evacuation patterns that are recommended due to a worst-case tsunami.

Engagement with at-risk communities should emphasize community-centric planning, focusing on those threatened by tsunamis. Simultaneously, an all-encompassing response and recovery strategy must be devised, encompassing the coordination of critical services such as law enforcement, rescue services, emergency medical services (EMS), and public utilities. This comprehensive approach ensures that essential functions are maintained, and recovery efforts are efficiently orchestrated in the aftermath of a tsunami.

Qualitative Assessment of Potential Evacuation Route Constraints in Adjacent Cities When considering the potential evacuation route constraints for Monterey, CA, and its adjacent cities like Pacific Grove, Seaside, and Sand City, it is imperative to incorporate a qualitative discussion focusing on the unique geographical and infrastructural elements of each area. Below is a qualitative discussion examining various aspects and considerations regarding the adjacent cities:

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1768, Packet Page 2096 City of Monterey, Evacuation Assessment, Page 9
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 • Pacific Grove:

Pacific Grove’s proximity to the coastline and rugged terrain poses significant constraints to the development and utilization of evacuation routes. The limited road capacity and possible bottlenecks at key intersections could significantly hinder the flow of evacuation traffic, especially during a mass evacuation scenario. Additionally, the presence of residential areas intermingled with natural habitats can exacerbate the risk of wildfires, necessitating wellcoordinated and effective evacuation plans. • Seaside:

Seaside's urban density and potentially congested roadways can act as a bottleneck during evacuation, limiting the mobility of evacuating residents. The interaction between local and through traffic, especially during peak hours, can constrain the effectiveness of evacuation routes. Additionally, specific attention needs to be paid to the synchronization of traffic lights and effective traffic management to prevent gridlocks during evacuation. • Sand City:

Given its smaller size and industrial character, Sand City might experience constraints due to limited egress points and road network capacity. The presence of industrial complexes and commercial centers logistical hubs may necessitate additional planning to manage the evacuation of large vehicles and freight traffic, which could obstruct regular vehicular movement.
• Carmel-by-the-Sea:

The city’s intricate layout, characterized by winding roads and residential zones interspersed with wooded areas, presents substantial constraints during high-pressure evacuation scenarios, particularly during wildfires. Given Carmelby-the-Sea's status as a tourist destination, there could be an influx of unfamiliar drivers during an emergency, complicating traffic management and potentially causing confusion and delays during evacuations. • SR68 towards Salinas:

The SR68 corridor, serving as a critical connector between Monterey and Salinas, embodies various unique challenges that require thoughtful evacuation strategies. The corridor’s significance as a primary artery for both daily commuters and freight transport elevates the importance of maintaining continuous traffic flow during evacuation scenarios. The existence of agricultural zones and the associated movement of agricultural vehicles and equipment require planning to prevent any obstruction to the evacuation traffic, ensuring a smooth transition of various traffic types during crises.

Recommendations
The City of Monterey is characterized by its diverse geographical features and unique neighborhoods. Given the importance of addressing evolving emergency evacuation needs, particularly in areas such as the southwestern neighborhoods, the following comprehensive recommendations can enhance evacuation strategies, focusing on addressing areas with high volume-to-capacity ratio, optimizing roadway designs, and fostering robust connectivity, all with an aim to ensure the safety and well-being of the residents. • Address potential bottlenecks by temporarily widening highway ramps by placing traffic cones to indicate two lanes to accommodate a higher volume of evacuating vehicles, mitigating congestion and delays. • In high-risk areas, consider of evacuation capacity during roadway design and maintenance initiatives. For instance, considering painted medians over raised medians can significantly increase evacuation capacity and flexibility, however, roadway safety is paramount and careful consideration must be taken when determining how to design a median.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1769, Packet Page 2097 City of Monterey, Evacuation Assessment, Page 10
kimley-horn.com 555 Capitol Mall, Suite 300, Sacramento, California 95814 916 858 5800 • Deploy adaptive traffic signal control systems that dynamically respond to real-time traffic conditions, giving priority to evacuation traffic, and ensuring efficient traffic flow during emergencies. • Install clear and comprehensive signage and wayfinding to facilitate smoother traffic flow, directing residents effectively to evacuation routes.
• Employ dynamic message signs, roadway sensors, and other ITS tools to disseminate real-time traffic conditions, alternative routes, and delays to drivers, enhancing situational awareness and decision-making. • For neighborhoods with limited access points, provide additional emergency access roads to facilitate smoother evacuation processes.
• Develop and improve connectivity between different neighborhoods to provide alternative evacuation routes, alleviating pressure on the primary access points. • Ensure road surfaces can withstand all weather conditions and are maintained to accommodate increased traffic during evacuations.
• Coordinate with transit agencies and other bus operators to provide organized public transportation, like buses, to transport residents lacking personal vehicles, subsequently reducing the total number of vehicles on the road during evacuations.
• Work with adjacent cities like Pacific Grove, Seaside, and Sand City to synchronize evacuation efforts and manage regional traffic flows efficiently.
• Educate and train residents about evacuation preparedness.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1770, Packet Page 2098 Attachment 1
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1771, Packet Page 2099 Attachment 2
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1772, Packet Page 2100 Attachment 3
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1773, Packet Page 2101 Attachment 4
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1774, Packet Page 2102 Attachment 5
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1775, Packet Page 2103 Attachment 6
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1776, Packet Page 2104 Attachment 7
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1777, Packet Page 2105 Attachment 8
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1778, Packet Page 2106 Attachment 9
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1779, Packet Page 2107 Attachment 10
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1780, Packet Page 2108

APPENDIX
I

WATER SUPPLY

ASSESSMENT
ATTACHMENT 1 / EXHIBIT A
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1782, Packet Page 2110

TABLE OF CONTENTS
California American Water Monterey Water Supply Assessment ....................................... I-1 Monterey Peninsula Water Management District Letter..................................................... I-48 Rule 142 – Water Efficiency Standards ...................................................................................I-127 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1783, Packet Page 2111 Water Supply Assessment
For City of Monterey
DECEMBER 2023
Prepared by Water Systems Consulting, Inc
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1784, Packet Page 2112

TABLE OF CONTENTS

1.0 Introduction and Purpose ................................................................................................... 1

1.1 Legislation ...................................................................................................................... 2

1.2 Definitions....................................................................................................................... 2

2.0 Public Water System Overview.......................................................................................... 3

2.1 Climate ........................................................................................................................... 5

2.2 Service Area Population ................................................................................................. 7

2.3 Water Demand ............................................................................................................... 7

3.0 Project Description...........................................................................................................11

4.0 Water Supplies.................................................................................................................12

4.1 Water Sources..............................................................................................................12

4.2 Surface Water...............................................................................................................16

4.3 Transfer Opportunities..................................................................................................16

4.4 Recycled Water ............................................................................................................16

4.5 Desalination..................................................................................................................16

4.6 Future Water Projects...................................................................................................17

4.7 Water Supply Summary................................................................................................17

5.0 Water Supply and Demand Analysis................................................................................20

5.1 Water Supply Management ..........................................................................................20

5.2 Year Type Characterization..........................................................................................20

5.3 Water Supply Reliability................................................................................................21

5.4 Comparison of Supply and Demand.............................................................................21

6.0 Determination of Water Supply Sufficiency......................................................................28

7.0 References.......................................................................................................................29 Appendix A WSA Request from City of Monterey................................................................... 1 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1785, Packet Page 2113

LIST OF FIGURES
Figure 2-1. Monterey County District’s Water Service Areas........................................................ 4 Figure 2-2. Historical Rainfall and Temperature ........................................................................... 5 Figure 2-3. Historical, Current and Projected Population.............................................................. 7 Figure 4-1. Historical ASR Injection and Recovery.....................................................................15 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1786, Packet Page 2114

LIST OF TABLES
Table 2-1. Historical Temperature, Rainfall and Reference Evapotranspiration (ETo) Data ........ 6 Table 2-2. Historical and Projected Water Demands..................................................................10 Table 4-1. Carmel Valley Aquifer Historical Groundwater Extractions, AFY...............................13 Table 4-2. Seaside Groundwater Basin Aquifer Historical Groundwater Extractions, AFY ........14 Table 4-3. Historic Supply from ASR, AFY .................................................................................15 Table 4-4. Pure Water Monterey Historic Supply, AFY...............................................................16 Table 4-5. Water Supplies –Projected (AFY)..............................................................................19 Table 5-1. Normal Year Supply and Demand Comparison........................................................22 Table 5-2. Single Dry Year Supply and Demand Comparison...................................................23 Table 5-3. Multiple Dry Years Low Supply Range and Demand Comparison (AFY).................24 Table 5-4. Multiple Dry Years High Supply Range and Demand Comparison (AFY) .................26 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1787, Packet Page 2115

1.0 Introduction and Purpose
This Water Supply Assessment (WSA) was prepared on behalf of California American Water (CAW) by Water Systems Consulting, Inc. (WSC). CAW provides water service to the City of Monterey (City) and surrounding communities. This WSA was prepared to satisfy the requirements of California Water Code (CWC) Section 10910 (Senate Bill 221) for the City’s Monterey 2031 Project (Project). The Monterey 2031 Project involves updates to the Housing, Land Use, Circulation, and Safety Elements of the City of Monterey General Plan to respond to changing demographics, emerging issues, and new State law. A critical piece of the Project is planning for additional housing to meet the City’s assessed share of the projected Regional Housing Needs Allocation (RHNA) for the upcoming planning period from 2023 through 2031. The City provided a written request to CAW to prepare a WSA that accounts for additional RHNA estimates; a copy of the request is provided in Appendix A.

As required by Senate Bill 610 (SB 610), CAW is responsible for assessing whether the total projected water supplies available during average, single dry, and five-consecutive dry water years during a 20-year projection will meet the projected water demand for the Project, in addition to the Monterey service area’s existing and planned future uses. A water supplier’s Urban Water Management Plan (UWMP) serves as a foundational document for a WSA. The water demands in CAW’s 2020 Urban Water Management Plan (2020 UWMP) were submitted to the California Department of Water Resources (DWR) in June 2021. Since the UWMP was submitted, CAW has continued to review and update its projections to support on-going planning efforts and incorporate California Public Utilities Commission (CPUC) proceeding A.21-11-024.

Additional information from other sources was also incorporated into this WSA to document supplies from all sources, including groundwater and purchased water.

Documentation includes identifying and quantifying supply water rights, contracts, and/or entitlements. This WSA includes the following:
 Overview of CAW’s water system (Section 2)
 Information on CAW’s current and projected water demands in the water service area (Section 2)
 Description of the proposed Project and estimated water demand (Section 3)  Information on the service area’s current and projected water supplies (Section 4)  Discussion of the Monterey service area water supply reliability and comparison of supplies and demands for average, single dry, and multiple dry years (Section 5)  Determination of the Monterey water service area water supply sufficiency (Section 6)
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1788, Packet Page 2116

1.1 Legislation
The City has determined that the Project is subject to review under the California Environmental Quality Act (CEQA) (Public Resources Code, Section 21000 et seq.), and the state CEQA Guidelines (California Code of Regulations, Section 15000 et. seq.). The City has determined that the Project is a “project” as defined in CWC 10912 and has determined that an EIR is required for the Project.

SB 610 amended the Public Resources Code, effective January 1, 2002, to incorporate CWC requirements for certain types of development projects to improve the link between information on water supply availability and certain land use decisions made by cities and counties. SB 610 seeks to promote more collaborative planning between local water suppliers, cities, and counties by requiring detailed information regarding water availability to be provided to the city and county decision-makers prior to approval of specified large development projects.

Under SB 610, water suppliers must prepare WSAs for projects meeting certain project size criteria, such as the Project, and deliver them to local governments for inclusion in any environmental documentation.

1.2 Definitions
For the purposes of this WSA, the following defined terms are used:
 Groundwater production: The amount of water produced from the Carmel River Aquifer and the Seaside Groundwater Basin groundwater supply sources and put into the distribution system based on metered flows at each well. CAW provided annual groundwater production data for 2021 and 2022 in addition to 2020 UWMP data.  Purchased water: The amount of water purchased from wholesale supply sources and put into the distribution system based on metered flows at each supply connection. CAW purchases water from the Sand City Desalination Plant.
 Consumption: The amount of billed metered water consumed by customers.  Demand: The amount of water distributed through the entire water system, which is the sum of water from all sources put into the distribution system. Demand includes nonrevenue water, which is equal to the difference between water put into the distribution system and billed consumption.
 Non-revenue water: Unmetered water use and losses from the distribution system due to leaks, unauthorized connections, agency use (e.g., system flushing), or theft.  Water demand factor: The calculated amount of water demand per unit (e.g., acre, dwelling unit, etc.) of a specific type of use (e.g., land use, development type, business type, etc.).

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1789, Packet Page 2117

2.0 Public Water System Overview
CAW operates water systems throughout the state of California. CAW’s operations are organized into three Division Offices: the Northern Division; Central Division; and Southern Division. The Central Division includes the Monterey County District, which includes the Monterey Main System and six satellite systems. The District is located in the northwest region of Monterey County, California, and serves most of the Monterey Peninsula, including the cities of Carmel-by-the-Sea, Del Rey Oaks, Monterey, Pacific Grove, Sand City, Seaside, and the unincorporated areas of Carmel Highlands, Carmel Valley, Presidio of Monterey, and Pebble Beach.

This WSA covers the Monterey Main system within the Monterey County District. Figure 2-1 shows the Monterey County District service areas. Since the publication of the 2020 UWMP, the Ryan Ranch and Bishop systems have been merged into the Monterey Main system.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1790, Packet Page 2118 Figure 2-1. Monterey County District’s Water Service Areas ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1791, Packet Page 2119

2.1 Climate
The climate in the study area is characterized by warm summers and mild winters. The proximity to the Pacific Ocean and geologic features results in several climatic zones within the service area. Table 2-1 presents average climate data for the service area, including temperature, rainfall, and reference evapotranspiration (ETo). As shown in Table 2-1, the warmest month of the year is September with an average temperature of 60 degrees Fahrenheit (°F), while the coldest month of the year is December with an average temperature of 52°F.

The average annual precipitation in Monterey is 12.7 inches per year, while the Carmel Valley experiences 16.5 inches per year on average. As shown Figure 2-2, the majority of the rainfall occurs in the months of November through March. December through March are the wettest months with an average rainfall of approximately 2.7 inches per month.

Figure 2-2. Historical Rainfall and Temperature
44 46
48 50
52 54
56 58
60 62
0 2
4 6
8 10
12 14
16 18
Air Temp (F)
Precipitation (in)
Month
Avg Cumulative Rain
Carmel Rain
Pacific Grove Rain
Average Rain
Carmel Temp
Pacific Grove Temp
Average Temp
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1792, Packet Page 2120 Table 2-1. Historical Temperature, Rainfall and Reference Evapotranspiration (ETo) Data Pacific Grove Carmel Pacific Grove Carmel Pacific Grove Carmel Month
Average
Temperature
(°F)1
Average
Temperature
(°F)2
Average
Precipitation
(in.)1
Average
Precipitation
(in.)2
Average
Standard ETo
(in.)1
Average
Standard ETo
(in.)2
January 52.3 51.4 2.6 3.0 1.75 1.82
February 52.2 51.4 1.7 2.2 2.40 2.32
March 52.7 52.5 2.6 3.2 3.23 3.38
April 53.3 54.1 0.9 1.2 4.09 4.22
May 54.3 55.7 0.3 0.5 4.49 4.59
June 57.5 58.0 0.1 0.2 4.34 4.97
July 57.1 59.4 0.0 0.0 3.82 4.85
August 59.0 60.6 0.0 0.0 3.45 4.41
September 59.3 60.8 0.1 0.2 3.33 3.99
October 57.6 58.9 0.6 1.9 2.85 3.26
November 54.6 54.0 1.3 1.4 1.97 2.07
December 52.0 50.8 3.1 3.4 1.6 1.52
Notes:

1. CIMIS weather station 193 in Pacific Grove (2011-2023) http://www.cimis.water.ca.gov/

2. CIMIS weather station 210 in Carmel (2010-2023) http://www.cimis.water.ca.gov/ ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1793, Packet Page 2121

2.2 Service Area Population
The current and projected populations for the water service area are shown in Figure 2-3.

Estimates of future population were developed using the regional growth forecast prepared by the Association of Monterey Bay Area Governments (AMBAG). The population projections were based on AMBAG data for the years 2020 and 2040 for the geographic areas served by CAW. Linear growth in population was assumed from 2020 through 2040 and extended through 2045.

Figure 2-3. Historical, Current and Projected Population

2.2.1 Other Demographic Factors
The land use within the study area includes residential, commercial, institutional, and open space areas. The regional growth forecast prepared by AMBAG included an estimated total employment in the Monterey service area for 2020 and 2040. Linear growth in employment was assumed from 2020 through 2045 and extended through 2045. The rate of growth in employment was used to estimate the rate of growth in water use for non-residential development.

2.3 Water Demand
The 2020 UWMP includes water demand projections through 2045. Water use for residential development was estimated using the projected population increase from the AMBAG data and an estimate of residential use in gallons per capita per day (GPCD).

For non-residential customers, water use was anticipated to increase at the rate of employment growth forecasted by AMBAG. The actual number of employees was not used in the projection; rather, non-residential water use was assumed to increase at the same rate as the estimated employment in the study area. The water demands for the Project were not explicitly accounted for in the 2020 UWMP. 91,717
93,577
95,437
97,297
99,157
101,017
86,000
88,000
90,000
92,000
94,000
96,000
98,000
100,000
102,000
2020 2025 2030 2035 2040 2045
Population
Year
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1794, Packet Page 2122 CAW continuously monitors and updates its projections of future demands and supplies as necessary to support on-going planning efforts. Since the 2020 UWMP was published CAW has incorporated new data into its projections and updated certain categorization of historical water use in the 2020 UWMP. In order to establish an updated basis for continued planning efforts, CAW identified the following updates to the demand projections:

1. The measured production from the Begonia Iron Removal Plant (BIRP) was used in the 2020 UWMP to quantify the volume of water entering the distribution system. However, using the total production from the wells gives a more accurate estimate of the portion of water that will be lost to leaks or unmetered use and thus the total demand. This update to projected total demand increases the portion of future total production that is expected to be attributed to water loss.

2. The 400 AFY that had been projected for Fire Service Demand was based on historical data for that use category. CAW subsequently determined that the applicable meters had not registered that much consumption, and that much of the water thought to be used in this category was actually non-revenue water; the water was produced and pumped into the system, but it did not flow through any customer meter and was lost to leaks or unmetered use. Essentially, the Fire Service Demand should be combined with the losses and categorized as total non-revenue water. Going forward, the water used for fire service is included as nonrevenue water in the non-residential demand category. Because this volume (400 AFY) was previously included as Fire Service Demand, the shift of the 400 AFY to nonrevenue water has no impact on the total projected demand.

3. The 2020 UWMP population growth is based on AMBAG data for the years 2020 and 2040 for the geographic areas served by CAW. Linear growth was assumed through 2040 and extended through 2045. For future planning, this same linear growth was extended through 2050.

Future demands for this study were projected by evaluating monthly historic trends in customer water usage and incorporating estimated future changes in water use due to behavioral changes, new water use regulations, projected growth, tourism water use, and employment projections by AMBAG. Water use for residential customers was approximately 55.2 GPCD for the period from 2018 through 2022, including indoor and outdoor use. It was anticipated that residential use could increase by 10% to 60.7 GPCD by 2030 when a new supply source is online and is expected to reduce the need for usage restrictions. For non-residential customers, water use was anticipated to increase at the rate of employment growth forecasted by AMBAG. Nonresidential demand includes the commercial, industrial, other public authority, company accounts, miscellaneous sales, sale for resale, fire service, and water loss categories, and is calculated as total water production minus residential metered sales.

Table 2-2 presents baseline and projected water demands through 2050. In addition to residential and non-residential development, additional categories are included to ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1795, Packet Page 2123 represent unique factors to the service area that are expected to affect future demands.

These include:
• Pebble Beach Entitlements. The Pebble Beach Company has entitlements to approximately 325 AFY that can be sold to other Del Monte Forest property owners. These entitlements constitute an existing obligation by CAW to serve the properties when developed. This demand is expected to be phased in over time once a new supply is online.
• Tourism Rebound. The region has historically been a popular destination for business and leisure travelers. In recent years, an economic slowdown contributed to reductions in visitor activity. The potential water demand increase due to a tourism bounce-back has been estimated by the CPUC as 500 AFY.

Once a new source of supply is available, hotels and visitor facilities can be built, remodeled, and expanded.
• Lots of Record. For residential development, a backlog of properties has accumulated that are not able to be developed because of limited water supply.

The demand for these Lots of Record (LOR) has been calculated as 1,180 AF.

The pace at which these properties could be developed if water were available would depend on economic factors and government policies. • Regional Housing Needs Allocation. The City’s request for a WSA identified an additional need for 3,654 housing units within the City. It is estimated that 6,213 housing units will be required for all areas within the Monterey service area by the end of the planning period in 2031. At an average density of approximately two persons per housing unit, the expected demand would be 0.12 AFY per unit, or a total of 745 AFY.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1796, Packet Page 2124 Table 2-2. Historical and Projected Water Demands
Customer Class
Baseline
(2018-
2022)
2025 2030 2035 2040 2045 2050
Residential Demand
(AF) 5,673 5,788 6,493 6,620 6,746 6,873 6,999
Non-Residential
Demand (AF) 3,773 3,932 4,091 4,250 4,409 4,569 4,728
Other Future
Demand (AF)
Pebble Beach
Entitlements 0 65 130 195 260 325
Tourism Rebound 250 500 500 500 500 500
Legal Lots of
Record 0 300 520 740 960 1,180
RHNA Demands 0 370 745 745 745 745
Total Demands
(AFY, nearest ten) 9,450 9,970 11,820 12,760 13,340 13,910 14,480 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1797, Packet Page 2125

3.0 Project Description
The Monterey 2031 Project involves updates to the Housing, Land Use, Circulation, and Safety Elements of the City of Monterey General Plan to respond to changing demographics, emerging issues, and new State law. A critical piece of the Project is planning for additional housing to meet the City’s assessed share of the projected Regional Housing Needs Allocation (RHNA) for the upcoming planning period from 2023 through 2031. The City is required to plan to accommodate 3,654 new housing units over the planning period, including 1,177 very low-income units, 769 low-income units, 462 moderate income units, and 1,246 above-moderate units. The Monterey City Council has approved an inventory of sites for housing that provide a total projected capacity of 5,802 new units, sufficient to provide a buffer to meet the RHNA requirements. This buffer is intended to ensure that lack of available sites does not constrain the City’s ability to meet the goal of 3,654 new housing units.

A project description for the Monterey 2031 Project is included in the City’s request for a WSA, included in Appendix A.

Future demands for the Project were estimated as part of the system-wide demand projections described in Section 2. The RHNA demands in Table 2-1 were based on the addition of 6,213 housing units for all areas within the Monterey service area by 2031.

The average demand per housing unit was assumed to be 0.12 acre-feet per year. As shown in Table 2-2, this RHNA demand is considered separately from the projected demand based on other factors, such as lots of record.

As stated in Section 2, the Project is assumed to be complete by 2031. Therefore, the total demand for the Project is 745 acre-feet (AF) and is assumed to occur between 2023 and 2035 for the purposes of this WSA.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1798, Packet Page 2126

4.0 Water Supplies

4.1 Water Sources
CAW’s current sources of supply for the Monterey Main System are:
• Groundwater from Upper and Lower Carmel Valley Aquifers; • Groundwater from the Seaside Groundwater Basin and its sub-basins; • Aquifer Storage and Recovery (ASR);
• Pure Water Monterey, a water recycling project;
• Sand City Desalination Plant; and
• A Future Ocean Desalination Plant as part of the Monterey Peninsula Water Supply Project (MPWSP).
• Table 13 Water, or diversions of flow from the Carmel River under Permit 21330 issued by the State Water Resources Control Board (SWRCB). This source is vulnerable to drought conditions and climate change, and it is not considered to be a dependable source.

The sources of supply are detailed further in the following sections.

4.1.1 Groundwater

4.1.1.1 Carmel River Aquifer
The Carmel Valley Aquifer is located along the Carmel River, southeast of the Monterey Peninsula. The Monterey Main system’s service area overlies the Carmel Valley Aquifer.

The aquifer is comprised of the alluvial deposits that form the valley floor underlying the Carmel River. The aquifer is identified as a high-priority basin and withdrawals are regulated through the State Water Resource Control Board (SWRCB).

The Monterey Main System pumps from both the Upper and Lower Carmel River Aquifer.

State Board Order 95-10 has placed seasonal limits on the allowable production from the wells in the Upper Carmel Valley Aquifer. The wells are operated in the winter months (November through April) and when the Carmel River flows exceed 40 cubic feet per second (cfs). If the river flow at the Don Juan Bridge is less than 20 cfs for more than 5 consecutive days, a “low flow period” is triggered and the upper valley wells cannot be used. The wells in the Upper Carmel River Aquifer are of good quality and discharge directly into the distribution system with disinfection at the wellhead.

The wells in the Lower Carmel River Aquifer do not have seasonal production limits. The wells pump into a raw water transmission main, which transfers groundwater to the ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1799, Packet Page 2127 Begonia Iron Removal Plant (BIRP) for treatment and removal of iron and manganese before being pumped into the distribution system.

CAW’s extractions from the Carmel Valley Aquifer for the past five years are shown in Table 4-1 for reference. Future supply from this source is limited to 3,376 AFY as authorized by the SWRCB.

Table 4-1. Carmel Valley Aquifer Historical Groundwater Extractions, AFY 2018 2019 2020 2021 2022
Carmel Valley Aquifer1 5,954 6,249 5,317 5,305 3,535
Note:

1. The Carmel River Aquifer volume excludes water that was injected into the Seaside Basin for ASR. This volume is counted as ASR storage and supply.

4.1.1.2 Seaside Groundwater Basin
The Seaside Groundwater Basin (SGWB) overlies and is a subbasin to the Salinas Groundwater Basin. The Salinas Valley Basin is made up of eight subbasins that span Monterey County and northern San Luis Obispo County. The Monterey and Laguna Seca Systems are located within and utilize water from the Seaside Area Subbasin of the Salinas Valley Groundwater Basin.

The Seaside Area Subbasin is bounded by 180/400 Foot Aquifer subbasin to the north, the Corral de Tierra sub-basin to the south and east, and by the Pacific Ocean to the west. The total surface area of the aquifer covers approximately 19 square miles. The southern boundary of the Seaside Groundwater Basin follows the Chupines fault, a relatively impermeable formation uplifted to near sea level. The western boundary of the basin extends to the shoreline. The eastern boundary of the basin is defined by the flow divide in the Paso Robles aquifer, which approximately coincides with surface drainage between the Canyon del Rey and El Toro Creek watersheds. Finally, the northern boundary of the basin also follows a groundwater flow divide from the Salinas Valley groundwater basin.

Historically, seawater intrusion had not been observed in existing monitoring and production wells in the Seaside Basin. In 2020 increased chloride concentrations were reported in two monitoring wells for the first time, which may be a precursor to seawater intrusion. The 2019 Updated Water Quality, Seawater Intrusion Analysis Report, and Basin Management Action Plan found that despite recent pumping at levels less than the decision-established natural safe yield of 3,000 AFY, water levels in some portions of the Basin are continuing to drop. Water levels and chloride concentrations are expected to improve once a new supply source is secured for the Peninsula and CAW can reduce its pumping from the Seaside Groundwater Basin.

Similar to the Carmel River, the Seaside Basin is vulnerable to climate impacts, notably after years of over pumping. The main climate vulnerability is continued seawater ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1800, Packet Page 2128 intrusion in the basin as seawater levels rise, plus increased agricultural water use and more severe and frequent droughts that may result in over pumping and further stress the basin. CAW is expected to significantly reduce reliance on both the Carmel River and Seaside Basin in the future as additional sources come online.

The CAW Monterey Main System has a total entitled right of 1,474 AFY from the Seaside Groundwater Basin. However, CAW has an agreement in place not to pump 700 AFY of this right for 25-years once a new supply source is operational. Because a new supply source is expected to be operational, CAW’s allocation from the Seaside Basin will be reduced to 774 AFY (1,474 AFY minus 700 AFY) from 2030 to 2055.

CAW’s extractions from the SGWB for the past five years are shown in Table 4-2 for reference. Beginning in 2030, future extractions are expected to be limited to 774 AFY, as discussed above.

Table 4-2. Seaside Groundwater Basin Aquifer Historical Groundwater Extractions, AFY 2018 2019 2020 2021 2022
Seaside Groundwater Basin
Aquifer 2,296 2,378 2,802 858 1,597

4.1.2 Aquifer Storage and Recovery
The Aquifer Storage and Recovery (ASR) program allows for the storage of excess Carmel River flows in the Seaside Groundwater Basin Coastal Subbasin during the months of December through May for later extraction during dryer summer months, historically between July and November. The ASR program is a joint program between CAW and the Monterey Peninsula Water Management District (MPWMD). Because diversions for the ASR system are contingent on maintaining minimum daily instream Carmel River flows, and precipitation and streamflow can vary substantially from year to year, the actual supply from the ASR project can vary substantially. In wet years with high streamflow, CAW is able to inject a significant volume of water for ASR.

Table 4-3 and Figure 4-1 shows the historic yield from ASR. Historically, the yield from ASR has varied significantly based on the hydrology and the available storage. The project has not been effective at building long term storage, and the average annual volume stored since 2006 is 84 AFY with multiple years of no stored water.

In most normal years the injection volume from seasonal Carmel River flows beyond CAW’s entitled rights is only slightly greater than the extraction volume, and there is little to no excess supply available to build ASR storage. CAW is projected to build ASR storage only in wet years. In dry years, if storage is available, CAW could draw down the ASR storage when the excess Carmel River flows are unavailable, but it is not anticipated to last through a multi-year drought based on the previous drought. Additional ASR storage would allow the ASR supply to last longer in a multi-year drought, though ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1801, Packet Page 2129 increased demands and climate impacts, including shifting rainfall patterns and hotter summers, will increase the difficulty of building ASR storage.

The average annual ASR extraction volume over the historic period of operations was 559 AFY. The projected ASR supply for future years is estimated to be 470 AFY with 90% reliability.

Table 4-3. Historic Supply from ASR, AFY
2018 2019 2020 2021 2022
ASR Extraction 1,210 744 806 0 0
Figure 4-1. Historical ASR Injection and Recovery
0 500
1,000
1,500
2,000
2,500
2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 Volume of Water (AF)
Water Year
ASR Injection ASR Recovery
Calculated Storage Average Storage
Five Consecutive
Driest Years
2012-2016
Basis of ASR
Supply
2018-2022
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1802, Packet Page 2130

4.2 Surface Water
The Monterey service area does not currently utilize surface water supplies.

4.3 Transfer Opportunities
CAW has completed interconnections between the Monterey Main System and the Ryan Ranch and Bishop System, which are now both supplied from the Monterey Main System.

CAW is also working to complete an interconnection between the Monterey Main System and the Hidden Hills System. The interconnections provide greater supply reliability for all systems.

4.4 Recycled Water
Monterey One Water (M1W), previously Monterey Regional Water Pollution Control Agency, operates a treatment plant that produces recycled water. The plant treats all collected wastewater through secondary treatment. Some secondary treated water is treated to a higher degree including Title 22 tertiary disinfection level for raw food crop irrigation or purified using advanced treatment. The tertiary treated water is used to irrigate edible food crops.

MPWMD and M1W operate the Pure Water Monterey (PWM) Project under which CAW is contracted to receive 3,500 AFY of advanced-treated recycled water for the Seaside Groundwater Basin. Table 4-4 shows the historic volume of water produced under the PWM Project (only 3,500 AFY of this amount was available to CAW in 2022).

Table 4-4. Pure Water Monterey Historic Supply, AFY
2021 2022
Pure Water Monterey Production 3,097 4,042

4.5 Desalination
The Sand City Desalination Plant includes a reverse osmosis desalination plant, water storage tanks, and a connection to CAW’s Monterey Main system. The desalination facility is designed to produce 300 AFY, but it typically produces closer to 190 AFY. CAW has an allocation of 94 AFY from this facility, and the rest is reserved for future development. CAW may only use more than 94 AFY until the future developments use the remaining supply. Because any supply beyond 94 AFY is reserved for the City, it cannot be relied upon as a future water supply for CAW.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1803, Packet Page 2131

4.6 Future Water Projects

4.6.1 Pure Water Monterey Expansion
PWM provides purified recycled water for injection into the Seaside Groundwater Basin and extraction for potable use in Monterey Main. CAW has a water purchase agreement to secure water from the project, which could deliver 3,500 AFY of advanced-treated recycled water for injection to the Seaside Groundwater Basin. The advanced treated recycled water mixes with the existing groundwater and is pumped as a potable supply source. PWM is a key component of CAW’s MPWSP to reduce diversions from the Carmel River and will serve as a key component of the future water supply for the Monterey Peninsula.

Phase 1 of PWM began operating at the end of 2019. Phase 2 of the project is envisioned to deliver an additional 2,250 AFY of water to the Seaside Basin that would be available to CAW. However, the PWM Expansion has not been proven to provide the full 2,250 AFY, particularly during dry years. A 2022 analysis determined that the PWM Expansion can be reasonably expected to provide 2,001 to 2,234 AFY during normal conditions and 0 to 1,100 AFY during drought conditions.

4.6.2 Monterey Peninsula Water Supply Project Ocean Desalination The proposed MPWSP Desalination Plant would produce up to 6,252 AFY of potable water. The first phase of the plant approved by the California Coastal Commission in November 2022 would have a capacity of 4.8 million gallons per day (mgd) and would produce approximately 5,372 AFY. A future second phase would raise the capacity to

6.4 mgd or approximately 6,252 AFY.

The desalination plant would be constructed near the Monterey One Water Regional Treatment Plant (MOWRTP). It would treat seawater that is filtered through the ocean floor, then collected through slant wells and piped to the desalination plant. The slant well approach would draw water from under the sea floor past the average high tide line and would avoid the impacts to marine life posed by open ocean intakes.

At the plant, seawater would be treated using various treatment technologies including reverse osmosis. Brine would be blended with other treated effluent and discharged to the ocean via the existing outfall at MOWRTP. This report assumes that the first phase of the MPWSP Desalination Plant will be operational by 2030, and that the second phase will be operational by 2035 in order to serve additional projected demand.

4.7 Water Supply Summary
CAW’s current sources of supply for the Monterey Main System are mostly from groundwater: the Carmel River Aquifer and the Seaside Groundwater Basin. These sources provided approximately 64% of the system’s water supply in the baseline window of 2018 through 2022. As proposed projects are completed in the future, it is anticipated ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1804, Packet Page 2132 this percentage will decrease to 25% as the MPWSP Ocean Desalination Plant and the PWM Phase 2 projects are completed.

Projected supplies are summarized in Table 4-5.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1805, Packet Page 2133 Table 4-5. Water Supplies –Projected (AFY)
Water Supply 2025 2025 2030 2030 2035 2035 2040 2040 2045 2045 Normal Drought Normal Drought Normal Drought Normal Drought Normal Drought Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 3,376 3,376 3,376 3,376 Seaside
Groundwater Basin 1,474 1,474 774 774 774 774 774 774 774 774 Aquifer Storage and
Recovery2 470 0 470 0 470 0 470 0 470 0
Sand City
Desalination 94 94 94 94 94 94 94 94 94 94
PWM Phase 13 3,500 3,500 3,500 3,500 3,500 3,500 3,500 3,500 3,500 3,500 PWM Expansion3 0 0 2,001 –
2,234
0 -
1,100
2,001 –
2,234
0 -
1,100
2,001 –
2,234
0 -
1,100
2,001 –
2,234
0 -
1,100
PWM Reserves4 0 0 0 0 - 775 0 0 - 775 0 0 - 775 0 0 - 775 MPWSP Ocean
Desalination Project 0 0 5,372 5,372 6,252 6,252 6,252 6,252 6,252 6,252 Low Range Year
Total5 8,914 8,444 15,587 13,116 16,467 13,996 16,467 13,996 16,467 13,996 High Range Year
Total5 8,914 8,444 15,820 14,991 16,700 15,871 16,700 15,871 16,700 15,871 Notes:

1. Drought conditions consider multiple dry consecutive years

2. ASR availability is determined to be 470 AFY with 90% reliability (California American Water Company, 2022)

3. Assumes during normal year PWM Project delivers 3,500 AF and PWM Expansion can deliver 2,001 – 2,234 AF based on assessment of source water availability. During drought years the assumption is PWM Project delivers 3,500 AF but PWM Expansion on low end is zero due to source water availability during a multi-year drought and reserves are not established or used already, and on high end 1,100 AF to meet the minimum Water Guarantee of 4,600 AF from both PWM Project and PWM Expansion

4. During a multi-year drought it is assumed that PWM Reserves are used to offset some of the resulting shortfall if available. The Amended and Restated WPA requires Operational and Drought Reserves of 2,875 AF and 1,000 AF, respectively, for a total of 3,875 AF. This analysis assumes that 775 AF will be available per year from Operational and Drought Reserves over a 5-year drought period.

5. This table does not take into account a 10% contingency buffer for supply.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1806, Packet Page 2134

5.0 Water Supply and Demand
Analysis

5.1 Water Supply Management
In general, groundwater supply is less vulnerable to seasonal and climatic changes than surface water. Natural groundwater supply estimates are based on long-term averages, which account for inconsistency in natural supplies. CAW’s future withdrawals from the Carmel River Aquifer and the Seaside Groundwater Basin are limited by regulatory orders and water rights agreements.

The ASR Program allows for the storage of excess Carmel River flows in the Seaside Groundwater Basin Coastal Subbasin for later extraction during summer months.

Diversions for the ASR system are contingent on maintaining minimum daily instream Carmel River flows, and precipitation and streamflow can vary substantially from year to year. Therefore, the actual supply from the ASR project can vary substantially. CAW is projected to build ASR storage only in wet years. In dry years, if storage is available, CAW could draw down the ASR storage when the excess Carmel River flows are unavailable, but it is not anticipated to last through a multi-year drought based on the previous drought.

Additional ASR storage would allow the ASR supply to last longer in a multi-year drought, though increased demands and climate impacts, including shifting rainfall patterns and hotter summers, will increase the difficulty of building ASR storage. The ASR Program is a relatively small percentage (3-4%) of the system’s total supply and will have a minimal impact on the system’s supply reliability in normal and dry years. Supply is considered to be zero in dry and multiple dry year conditions.

Water from the Sand City Desalination plant is used year-round at the same rate. Water from PWM and the future ocean desalination plant are assumed to be available yearround and in all year types as well.

5.2 Year Type Characterization
The basis for the “year type” is determined from the single‐driest and multiple‐driest years using precipitation data (2011‐2023) from CIMIS using the Pacific Grove and Carmel stations. Even though precipitation is variable, groundwater supply estimates are based on long‐term averages and established pumping limits, which account for these variabilities. Therefore, CAW’s groundwater and desalination sources are assumed to be 100% available in single‐dry and multiple‐dry year conditions.

Per SB 610 requirements, CAW has evaluated reliability for an average year, single-dry year, and five-consecutive-dry-years period. The UWMP Act defines these years as:

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1807, Packet Page 2135  Average Year. This condition represents the water supplies a supplier considers available during normal conditions. This could be a single year or averaged range of years that most closely represents the average water supply available.
 Single-Dry Year. The single dry year is recommended to be the year that represents the lowest water supply available. The single lowest year of precipitation was 2013, with 3.9 inches per year.
 Five-Consecutive-Years Drought. The driest five-year historical sequence for the supplier, which may be the lowest average water supply available for five years in a row.

The lowest five years of precipitation was 2012 to 2016, with an average of 11.6 inches per year.

5.3 Water Supply Reliability
Generally, the groundwater supply estimates are less vulnerable to seasonal and climatic changes than surface water. Natural groundwater supply estimates are based on longterm averages, which account for inconsistency in natural supplies. CAW’s future withdrawals from the Carmel River Aquifer and the Seaside Groundwater Basin are limited by regulatory orders and water rights agreements. Water from the Sand City Desalination plant and the future MPWSP Ocean Desalination Plant are drought resistant, and supply is assumed to be reliable.

ASR supply can vary substantially depending on weather and available supply. Increased demands and climate impacts, including shifting rainfall patterns and hotter summers, will increase the difficulty of building ASR storage. Supply is considered to be zero in dry and multiple dry year conditions.

Supply from the PWM Expansion is variable and provided as a range in CAW’s latest supply and demand estimates. Due to the expansion’s dependence on wastewater supply and user’s consumption behavior, the supply and demand comparison was evaluated for the low and high values of its estimated supply range in normal and dry conditions. This comparison is detailed further in Section 5.4.

5.4 Comparison of Supply and Demand
Groundwater supply from the Carmel River Aquifer and Seaside Groundwater Basin is assumed to remain 100% available because the long‐term average of the groundwater includes dry periods, and CAW’s future pumping is limited by regulatory orders and water rights agreements.

Table 5-1 and Table 5-2 compare the average and single dry-year supply and demand.

Table 5-3 and Table 5-4 compare water supply and demand during multi-year droughts in five-year increments. Each table lists the available supply based on the projected reliability of the source.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1808, Packet Page 2136 Based on these results, the Monterey service area requires the additional supply from the new MPWSP Ocean Desalination Plant and the PWM Expansion to meet the region’s demands during average, single-dry year, and five consecutive dry years from 2025 to 2050. The new supply sources will help provide a secure and reliable water supply for the Monterey Peninsula and reduce the need for stringent demand reduction measures to close the gap between supply and demand. However, even with the second phase of the MPWSP operational in 2035, it is estimated that demand will outpace supply during dry year and multi-year drought scenarios when supply is at the lower range of projections starting in 2040.

Table 5-1. Normal Year Supply and Demand Comparison
- 2025 2030 2035 2040 2045 2050
Demand Totals, AFY 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 470 470 470 470 470 470
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey
Expansion1 0 2,001 -2,234
2,001 -
2,234
2,001 -
2,234
2,001 -
2,234
2,001 -
2,234
Pure Water Monterey Reserves 0 0 0 0 0 0
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Low Range Total Water Supply,
AFY 8,914 15,587 16,467 16,467 16,467 16,467
Operation Buffer (10%) -891 -1,022 -1,022 -1,022 -1,022 -1,022 Surplus/ Shortfall -1,947 2,746 2,676 2,106 1,536 966
High Range Total Water Supply,
AFY 8.914 15,820 16,700 16,700 16,700 16,700
Operation Buffer (10%)2 -891 -1,045 -1,045 -1,045 -1,045 -1,045 Surplus/ Shortfall -1,947 2,955 2,885 2,315 1,745 1,175 Note:

1. The PWM Expansion Project is reliant on the MPWSP Desalination Plant for increased water demands and wastewater for source water.

2. The operational buffer has not been applied to the MPWSP Ocean Desalination supply, which, given its source water, is drought-proof.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1809, Packet Page 2137 Table 5-2. Single Dry Year Supply and Demand Comparison - 2025 2030 2035 2040 2045 2050
Demand Totals, AFY 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey
Expansion1 0 0 -1,100
0 -
1,100
0 -
1,100
0 -
1,100
0 -
1,100
Pure Water Monterey Reserves 0 0 - 775 0 - 775 0 - 775 0 - 775 0 - 775 MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Low Range Total Water Supply,
AFY 8,444 13,116 13,996 13,996 13,996 13,996
Operation Buffer (10%)2 -844 -774 -774 -774 -774 -774
Surplus/ Shortfall -2,370 522 452 -118 -688 -1,258
High Range Total Water Supply,
AFY 8,444 14,991 15,871 15,871 15,871 15,871
Operation Buffer (10%)2 -844 -962 -962 -962 -962 --962
Surplus/ Shortfall -2,370 2,209 2,139 1,569 999 429
Note:

1. When the MPWSP Desalination Plant comes online, it will provide a drought-proof supply that will allow water demands to increase to the projected levels and wastewater flows to increase, which provides more source water for the PWM and PWM Expansion Project and improves both projects supply reliability. This excess supply is only available in dry years if the MPWSP is operational.

2. The operational buffer has not been applied to the MPWSP Ocean Desalination supply, which, given its source water, is drought-proof.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1810, Packet Page 2138 Table 5-3. Multiple Dry Years Low Supply Range and Demand Comparison (AFY) 2025 2030 2035 2040 2045 2050
First
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey Expansion 0 0 0 0 0 0
Pure Water Monterey Reserves 0 0 0 0 0 0
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 13,116 13,996 13,996 13,996 13,996 Operation Buffer (10%)2 -844 -774 -774 -774 -774 -774
Surplus/ Shortfall -2,370 522 452 -118 -688 -1,258
Second
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey Expansion 0 0 0 0 0 0
Pure Water Monterey Reserves 0 0 0 0 0 0
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 13,116 13,996 13,996 13,996 13,996 Operation Buffer (10%)2 -844 -774 -774 -774 -774 -774
Surplus/ Shortfall -2,370 522 452 -118 -688 -1,258
Third
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY 4,944 13,116 13,996 13,996 13,996 13,996 Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1811, Packet Page 2139 2025 2030 2035 2040 2045 2050
Pure Water Monterey Expansion 0 0 0 0 0 0
Pure Water Monterey Reserves 0 0 0 0 0 0
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 13,116 13,996 13,996 13,996 13,996 Operation Buffer (10%)2 -844 -774 -774 -774 -774 -774
Surplus/ Shortfall -2,370 522 452 -118 -688 -1,258
Fourth
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey Expansion 0 0 0 0 0 0
Pure Water Monterey Reserves 0 0 0 0 0 0
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 13,116 13,996 13,996 13,996 13,996 Operation Buffer (10%)2 -844 -774 -774 -774 -774 -774
Surplus/ Shortfall -2,370 522 452 -118 -688 -1,258
Fifth
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey Expansion 0 0 0 0 0 0
Pure Water Monterey Reserves 0 0 0 0 0 0
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 13,116 13,996 13,996 13,996 13,996 Operation Buffer (10%)2 -844 -774 -774 -774 -774 -774
Surplus/ Shortfall -2,370 522 452 -118 -688 -1,258
Note:

1. Demands are assumed to remain static at the beginning of a multi-year drought where demand restrictions will offset population and employment growth.

2. The operational buffer has not been applied to the MPWSP Ocean Desalination supply, which, given its source water, is drought-proof.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1812, Packet Page 2140 Table 5-4. Multiple Dry Years High Supply Range and Demand Comparison (AFY) 2025 2030 2035 2040 2045 2050
First
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey Expansion 0 1,100 1,100 1,100 1,100 1,100 Pure Water Monterey Reserves 0 775 775 775 775 775
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 14,991 15,871 15,871 15,871 15,871 Operation Buffer (10%)2 -844 -962 -962 -962 -962 --962
Surplus/ Shortfall -2,370 2,209 2,139 1,569 999 429
Second
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey Expansion 0 1,100 1,100 1,100 1,100 1,100 Pure Water Monterey Reserves 0 775 775 775 775 775
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 14,991 15,871 15,871 15,871 15,871 Operation Buffer (10%)2 -844 -962 -962 -962 -962 --962
Surplus/ Shortfall -2,370 2,209 2,139 1,569 999 429
Third
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1813, Packet Page 2141 2025 2030 2035 2040 2045 2050
Pure Water Monterey Expansion 0 1,100 1,100 1,100 1,100 1,100 Pure Water Monterey Reserves 0 775 775 775 775 775
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 14,991 15,871 15,871 15,871 15,871 Operation Buffer (10%)2 -844 -962 -962 -962 -962 --962
Surplus/ Shortfall -2,370 2,209 2,139 1,569 999 429
Fourth
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey Expansion 0 1,100 1,100 1,100 1,100 1,100 Pure Water Monterey Reserves 0 775 775 775 775 775
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 14,991 15,871 15,871 15,871 15,871 Operation Buffer (10%)2 -844 -962 -962 -962 -962 --962
Surplus/ Shortfall -2,370 2,209 2,139 1,569 999 429
Fifth
Year Water Demand 9,970 11,820 12,770 13,340 13,910 14,480 Water Supply, AFY
Carmel River Aquifer 3,376 3,376 3,376 3,376 3,376 3,376 Seaside Groundwater Basin 1,474 774 774 774 774 774
Sand City Desalination 94 94 94 94 94 94
ASR 0 0 0 0 0 0
Pure Water Monterey 3,500 3,500 3,500 3,500 3,500 3,500 Pure Water Monterey Expansion 0 1,100 1,100 1,100 1,100 1,100 Pure Water Monterey Reserves 0 775 775 775 775 775
MPWSP Ocean Desalination 0 5,372 6,252 6,252 6,252 6,252 Total Water Supply 8,444 14,991 15,871 15,871 15,871 15,871 Operation Buffer (10%)2 -844 -962 -962 -962 -962 --962
Surplus/ Shortfall -2,370 2,209 2,139 1,569 999 429
Note:

1. Demands are assumed to remain static at the beginning of a multi-year drought where demand restrictions will offset population and employment growth.

2. The operational buffer has not been applied to the MPWSP Ocean Desalination supply, which, given its source water, is drought-proof.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1814, Packet Page 2142

6.0 Determination of Water Supply
Sufficiency
Based on the results described in Section 5, CAW requires additional supply to meet current and future water demands. The PWM Expansion is anticipated to add up to 2,234 AFY of supply by 2030 during normal years. The new MPWSP Ocean Desalination Plant is anticipated to add approximately 5,372 AFY by 2030 with the completion of the first phase approved by the California Coastal Commission in November 2022. The second phase of the MPWSP Ocean Desalination Plant is expected to raise the total production to 6,252 AFY. For the purposes of this report, the second phase is assumed to be completed by 2035.

The tables in Section 5 show that during dry years, the PWM Expansion is anticipated to provide up to 1,100 AFY, or approximately one-half of the normal year capacity. PWM and the PWM Expansion project rely on multiple source waters, each of which are impacted differently by climate warming and increased frequency of drought. During dry years there is limited source water available for PWM and the PWM Expansion project after meeting other contracted demands until demands and wastewater flows on the Peninsula increase. The increased frequency of droughts due to climate change will continue to reduce the reliability of source supply for these projects and as a water supply for the Monterey Main System.

The MPWSP Ocean Desalination Plant is anticipated to provide a drought-proof supply.

With the addition of these supplies, it is expected that supply will exceed demand during normal years through 2050. The new supply sources will help provide a secure and reliable water supply for the Monterey Peninsula and reduce the need for stringent demand reduction measures to close the gap between supply and demand. During single dry year and multiple dry year scenarios, it is estimated that demands will outpace available supply by 2040 when supply is at the lower estimated range of values.

A supply deficit is anticipated until new supplies are available. After new supplies are available, there will be adequate supply to serve projected demand (including projected demands for RHNA housing). Until the new supplies come online, CAW will use its Water Shortage Contingency Plan (WSCP) measures to maintain demand below the available supply.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1815, Packet Page 2143

7.0 References
California American Water Company. (2022). Monterey Peninsula Water Supply Project, CDP Application No. 9-20-0603: Updated Supply and Demand Estimates.

City of Monterey. (September 2023). 2023 Water Supply Assessment Request for California American Water Company.

Water Systems Consulting, Inc. (2021). 2021 Urban Water Management Plan for Monterey County District.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1816, Packet Page 2144 Appendix A WSA Request from City of
Monterey
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1817, Packet Page 2145 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1818, Packet Page 2146 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1819, Packet Page 2147 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1820, Packet Page 2148 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1821, Packet Page 2149 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1822, Packet Page 2150 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1823, Packet Page 2151 142-1
Monterey Peninsula Water Management District
RULE 142 - WATER EFFICIENCY STANDARDS
A. Water Effi ciency Standards.

1. All Sites supplied with water from a Water Distribution System regulated by the District shall comply with these standards.

2. All New Construction of New Structures shall install and maintain plumbing fi xtures and conservation standards as set forth in this Rule.

3. No plumbing fi xture shall be replaced with fi xtures which allow greater water use.

4. All new and replacement water fi xtures shall comply with then-current California plumbing and energy standards/codes when more restrictive than the District’s.

5. Manufactured Homes shall be subject to these standards.

B. Former Rules. Water Permit requirements change periodically to refl ect current effi ciencies. Sites with uncompleted Water Permits that have not received a fi nal inspection shall at a minimum comply with the requirements in place at the time the Water Permit was issued unless required to install more effi cient fi xtures as a result of a subsequent triggering event (e.g. new/amended Water Permit or Change of Ownership/ Use).

C. Residential Water Effi ciency Standards for New Structures.

All Residential New Structures receiving a Water Permit, shall meet or exceed the following standards:

1. High Effi ciency or Ultra High Effi ciency Toilets shall be installed;

2. Urinals, when installed in a Residential use, shall be designed to fl ush with one (1) gallon of water. After January 1, 2016, newly installed Urinals shall fl ush with no more than 0.125 gallon per fl ush;

3. Showerheads, Rain Bars, or Body Spray Nozzles must be designed and manufactured to emit a maximum of 2.0 gallons per minute of water;

4. All shower fi xtures should be equipped with scald protection valves rated for 2.0 gallons per minute Showerheads;

5. High Effi ciency Clothes Washer(s) and High Effi ciency Dishwasher(s) shall be required when installed in a Residential use;

6. Lavatory Sink faucets shall emit a maximum of 1.2 gallons of water per minute at 60 psi;
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1824, Packet Page 2152 142-2
Monterey Peninsula Water Management District

7. Kitchen Sink, Utility Sink, and Bar Sink faucets shall emit a maximum of

1.8 gallons of water per minute at 60 psi. Faucets may have the capability to temporarily increase fl ow to 2.2 gallons per minute for fi lling pots and pans, but must default back to a maximum Flow Rate of 1.8 gallons per minute measured at 60 psi;

8. Instant-Access Hot Water Systems shall be installed;

9. All hot water pipes shall be insulated;

10. Sodium chloride (salt) water softeners shall be discouraged in New Construction.

Alternate technologies such as potassium chloride shall be recommended. When a sodium chloride water softener is to be installed within the MPWMD, the unit shall use demand-initiated regeneration which senses when the resin must be recharged, either electronically or with a meter that measures and calculates usage.

This requirement shall be specifi ed on the Construction Drawings;

11. Landscaping. All New Construction (including new buildings with landscape or other new landscape, such as a park, playground, or Greenbelt without an associated building) shall install and maintain landscapes that comply with Rule 142.1.

12. Rainwater collection/Irrigation Systems are encouraged to supplement irrigation for new landscaping. New Structures shall be encouraged to include one or more rainwater Cisterns and a system to provide at least 75 percent of exterior irrigation during normal rainfall years. Systems must be compliant with local catchment system standards.

13. Graywater collection/Irrigation Systems are encouraged to supplement irrigation for new Landscaping. Systems must be compliant with local catchment system standards, including Monterey County Environmental Health Bureau.

14. All Sites utilizing a Graywater reuse system shall install and maintain a Backfl ow Prevention Device as required by any Water Distribution System Operator that supplies water to the Site.

D. Non-Residential Water Effi ciency Standards for New Structures.

All Non-Residential New Structures receiving a Water Permit shall meet or exceed the following standards:

1. High Effi ciency or Ultra High Effi ciency Toilets shall be installed;

2. Urinals shall be Pint Urinals or Zero Water Consumption Urinals and shall be clearly specifi ed on the fi nal Construction Drawings. Zero Water Consumption Urinals shall be encouraged in settings where there is a regular maintenance staff;

3. Showerheads, Rain Bars, or Body Spray Nozzles must be designed and ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1825, Packet Page 2153 142-3
Monterey Peninsula Water Management District
manufactured to emit a maximum of 2.0 gallons per minute of water;

4. All shower fi xtures should be equipped with scald protection valves rated for 2.0 gallons per minute Showerheads;

5. Public Washbasins shall emit a maximum of 0.5 gallon of water per minute at 60 psi. Private Washbasins (e.g. hotel or motel guest rooms and hospital patient rooms) shall emit a maximum of 1.2 gallons of water per minute at 60 psi. All other sinks shall emit a maximum of 2.2 gallons of water per minute at 60 psi unless higher fl ow is required by Health and Safety Code;

6. Public Washbasins equipped with automatic shut off devices or sensor faucets shall operate with a maximum fl ow of 0.25 gallons per cycle;

7. High Effi ciency Clothes Washers shall be installed when a Clothes Washer is installed in a New Structure permitted under this Regulation;

8. High Effi ciency Dishwashers or High Effi ciency Commercial Dishwashers shall be installed and maintained on the Site when a Dishwasher is installed in a New Structure permitted by a Water Permit;

9. Instant-Access Hot Water System(s) shall be installed for hot water access points to ensure that hot water is available within ten (10) seconds;

10. All hot water pipes shall be insulated;

11. Sodium chloride (salt) water softeners shall be discouraged in New Construction.

Alternate technologies, such as potassium chloride shall be recommended. When a sodium chloride water softener is to be installed within the MPWMD, the unit shall use demand-initiated regeneration which senses when the resin must be recharged, either electronically or with a meter that measures and calculates usage. This requirement shall be specifi ed on the Construction Drawings;

12. Water Effi cient Pre-Rinse Spray Valves shall be utilized when a pre-rinse spray valve is installed;

13. There shall be no single-pass water use systems in ice machines, hydraulic equipment, refrigeration condensers, X-ray processing equipment, air compressors, vacuum pumps, etc. Air-cooled or better technology shall be installed when available;

14. Water cooled refrigeration equipment shall be prohibited when there is alternative cooling technology available at the time the Water Permit is issued;

15. Cooling Towers shall be equipped with conductivity controllers that are used to increase the number of cycles that can be achieved;
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1826, Packet Page 2154 142-4
Monterey Peninsula Water Management District

16. Boilerless steamers or connectionless steamers shall be installed in place of boilerbased steamers when a steamer is installed in New Construction;

17. Landscaping. All New Construction (including new buildings with landscape or other new landscape, such as a park, playground, or Greenbelt without an associated building) shall install and maintain landscapes that comply with Rule 142.1.

18. Rainwater collection/Irrigation Systems are encouraged to supplement irrigation for new landscaping. New Structures shall be encouraged to include one or more rainwater Cisterns and a system to provide at least 75 percent of exterior irrigation during normal rainfall years. Systems must be compliant with local catchment system standards.

19. Graywater collection/Irrigation Systems are encouraged to supplement irrigation for new landscaping. Systems must be compliant with local catchment system standards, including Monterey County Environmental Health Bureau.

20. All Sites utilizing a Graywater reuse system shall install and maintain a Backfl ow Prevention Device as required by any Water Distribution System Operator that supplies water to the Site.

21. The implementation of water conservation Best Management Practices shall be integrated into construction and operation of the project to the extent possible.

22. The use of Alternative Water Sources for indoor toilet fl ushing and other uses allowed by the Jurisdiction shall be encouraged.

23. Visitor-Serving and Public and Quasi-Public Facilities shall display in visible locations in all restrooms, kitchens, and dining areas, placards or decals approved by the District promoting public awareness of the need for water conservation and/or advising the public that waste of water is prohibited.

24. The owner and/or manager of rental property shall provide current and new tenants with information about the water conservation requirements, including the Water Waste and Non-Essential Water Use regulations of the District. This information shall be readily accessible on a tenant portal website with annual notifi cation of its presence, or when notice is not provided electronically, the owner and/or manager shall annually provide written information to existing tenants and to new tenants as they move in.

25. Visitor-Serving Facilities shall promote towel and linen reuse programs by providing written notice in the rooms, whereby towels and linens are changed every three days or as requested by action of the guest.

26. Visitor-Serving Facilities shall provide written notice that drinking water is available only upon request. Notifi cation of this requirement shall be provided on ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1827, Packet Page 2155 142-5
Monterey Peninsula Water Management District
the table(s) or menu(s) of each facility. Visitor-Serving Facilities shall not provide drinking water from the Monterey Peninsula Water Resource System at the table unless specifi cally requested.

27. Facilities utilizing alternative sources of irrigation water (i.e. purifi ed recycled water, Non-Potable Water, rainwater and Graywater, etc.) shall be encouraged to provide notice of the alternative supply, either by erecting a sign in compliance with local codes or by identifying the alternative supply in other venues such as in newsletters, websites, menus, etc.

E. Residential and Non-Residential Change of Ownership, Change of Use, and Expansion of Use Water Effi ciency Standards
Sites that have a Change of Ownership, or receive a Water Permit for a Change of Use or Expansion of Use shall meet or exceed the following standards:

1. High Effi ciency or Ultra High Effi ciency Toilets shall be installed;

2. Urinals shall be at a minimum High Effi ciency Urinals (when installed prior to January 1, 2016). Newly installed Urinals shall be Pint Urinals or Zero Water Consumption Urinals. Zero Water Consumption Urinals shall be encouraged in settings where there is a regular maintenance staff;

3. Showerhead Flow Rates shall meet or exceed water effi ciency standards for New Structures;

4. Bathroom faucet Flow Rates shall meet or exceed water effi ciency standards for New Structures;

5. Kitchen faucet Flow Rates shall meet or exceed water effi ciency standards for New Structures;

6. Remodels or relocations of water fi xtures or appliances that involve hot water shall be encouraged to install an Instant-Access Hot Water System and insulate all new hot water pipes;

7. Pre-rinse spray valves shall meet or exceed the District’s defi nition for Water Effi cient Pre-Rinse Spray Valves;

8. Changes of Use and Expansions of Use that require a Water Permit shall not install any single-pass water use systems in ice machines, hydraulic equipment, refrigeration condensers, X-ray processing equipment, air compressors, vacuum pumps, etc. Air-cooled or better technology shall be installed when available;

9. Changes of Use and Expansions of Use that require a Water Permit shall not install any water cooled refrigeration equipment when there is alternative water effi cient cooling technology available at the time the Water Permit is issued; ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1828, Packet Page 2156 142-6
Monterey Peninsula Water Management District

10. Automatic Irrigation Systems, with the exception of Weather- Based Irrigation Systems, shall be retrofi t to include a Rain Sensor;

11. The implementation of Non-Residential Best Management Practices shall be integrated into construction and operation of Non-Residential uses to the extent possible;

12. Projects that include Rehabilitated Landscapes (modifi ed Landscape Area is equal to or greater than two thousand fi ve hundred (2,500) square feet) shall comply with Rule 20-B and Rule 142.1
F. Water Effi ciency Standards for Multi-Family Residential Sites and Common Interest Developments:

1. Multi-Family Residential Sites and Common Interest Developments with four or more Dwelling Units, shall meet or exceed the following water effi ciency standards before January 1, 20191
:
a. High Effi ciency or Ultra High Effi ciency Toilets shall be installed. Multi- Family Residential Sites and Common Interest Developments with Ultra- Low Flush Toilets installed prior to January 1, 2014, shall be exempt from this toilet retrofi t requirement.;
b. Urinals shall be at a minimum High Effi ciency Urinals (if installed prior to January 1, 2016). Newly installed Urinals shall be Pint Urinals or Zero Water Consumption Urinals;
c. Showerheads, Rain Bars, or Body Spray Nozzles must be designed and manufactured to emit a maximum of 2.0 gallons per minute of water at 60 psi;
d. Washbasin faucets shall emit a maximum of 1.2 gallons of water per minute at 60 psi;
e. Kitchen Sink, Utility Sink, and Bar Sink faucets shall emit a maximum of 1.8 gallons of water per minute at 60 psi. Faucets may have the capability to temporarily increase fl ow to 2.2 gallons per minute for fi lling pots and pans, but must default back to a maximum Flow Rate of

1.8 gallons per minute measured at 60 psi;
f. Common Laundry Rooms. By January 1, 2019 all Clothes Washers installed in Common Laundry Rooms within the District shall meet the defi nition of High Effi ciency Clothes Washer rated with a Water Factor of 5.0. Washer/extractors that do not comply with the 5.0 Water 1 Individually owned condominiums and cooperatives that are subject to Rule 142-E shall be exempt from this requirement.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1829, Packet Page 2157 142-7
Monterey Peninsula Water Management District
Factor shall be programmed by a manufacturer/vendor technician to only function on the low water setting (non-user selected setting). A written statement shall be provided to MPWMD by the manufacturer/vendor’s technician stating that the machines have been programmed to only use the low water setting and that there is no way to manipulate the water usage via a user setting. This statement shall be maintained by MPWMD.
g. Clothes Washers located inside Dwelling Units should be encouraged to replace Clothes Washers with High Effi ciency Clothes Washers; h. Water Pressure Regulating Devices shall be installed and maintained to maintain water pressure between 50 and 65 psi.
i. Automatic Irrigation Controllers properly adjusted to adhere to the District’s Stage 1 Water Conservation Requirements (Rule 162) shall be installed, used, and maintained.

2. The owner (or his authorized agent) of a Multi-Family Residential Site or Common Interest Development manager shall certify compliance with this regulation by one of the following methods:
a. Provide the District with a District-certifi ed inspection report that provides all Site information required by the District and that verifi es installation of Low Water Use Plumbing Fixtures throughout the Site, as required by Regulation XIV and Regulation XV; or
b. Provide documentation to the District from a District-certifi ed city or county building offi cial that provides all Site information required by the District and that certifi es installation of Low Water Use Plumbing Fixtures throughout the Site, as required by Regulation XIV and Regulation XV; or
c. Provide owner/association certifi cation that plumbing fi xtures throughout the Site have been retrofi tted in compliance with Regulation XIV and Regulation XV. The owner, his authorized agent, or CID manager shall forward a copy of this certifi cation, together with a dated copy of the purchase receipt for each Low Water Use Plumbing Fixture and a dated copy of the labor contract or a statement of self- installation which evidences complete installation to the District. The District may verify certifi cation by an onsite inspection.

Rule added by Ordinance No. 30 (7/13/87); amended by Ordinance No. 71 (12/20/1993): Ordinance No. 125 (9/18/2006); Ordinance No. 141 (11/16/2009); Ordinance No. 151 (11/19/2012); Ordinance No. 170 (5/16/2016); Ordinance No. 172 (8/15/2016); Ordinance No. 177 (9/18/2017); Ordinance No. 178 (11/13/2017); Ordinance No. 182 (5/20/2019) ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1830, Packet Page 2158 5 Harris Court, Building G, Monterey, CA  93940        P.O. Box 85, Monterey, CA  93942‐0085 831‐658‐5600        Fax  831‐644‐9560       www.mpwmd.net

VIA EMAIL
January 23, 2024
Mr. Hans Uslar
City Manager
City Hall
Monterey, CA 93940
RE: Water Supply Assessment
Dear Mr. Uslar:

In August 2023 you requested a water supply assessment from the Monterey Peninsula Water Management District (District). Under California Water Code Section 10910, as a city or the county develops growth plans for jobs and housing on the Monterey Peninsula, the water supply assessment required under CEQA for the projects shall include a discussion with regard to whether the public water system's – in this case, California American Water Company’s (CalAm’s) – total projected water supplies available during normal, single dry, and multiple dry water years during a 20-year projection will meet the projected water demand associated with the proposed projects, in addition to Cal-Am’s existing and planned future uses.

If the projected water demand associated with the proposed projects was accounted for in the most recently adopted urban water management plan (UWMP), Cal-Am is the entity who should have provided the water supply assessment and incorporated the requested information from the urban water management plan in preparing and submitting the assessment within 90 days of the request, or requested an extension of time. At the time of your letter, we recognized that you copied Cal-Am and hoped that they would be responsive.

The “Urban Water Management Planning Act” (Act) is comprised of Section 10610 through 10657 of the California Water Code Division 6, Part 2.6. Under Section 10620, every urban water supplier shall prepare and adopt a UWMP. An urban water supplier indirectly providing water, such as MPWMD as a wholesaler, shall not include planning elements in its water management plan as provided in Article 2 (commencing with Section 10630) that would be applicable to urban water suppliers or public agencies directly providing water, such as Cal-Am.

Hence, it is Cal-Am that is obligated to work with a city or the county to provide a water supply assessment to assist with CEQA. However, that section of the Act also provides that each urban water supplier shall coordinate the preparation of its plan with other appropriate agencies in the area, including other water suppliers that share a common source, water management agencies, and relevant public agencies, to the extent practicable. MPWMD was not asked by Cal-Am to coordinate on its UWMP, nor does MPWMD agree with many of the assumptions and ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1831, Packet Page 2159 Mr. Hans Uslar

January 23, 2024
conclusions of Cal-Am’s UWMP and subsequent Cal-Am supply and demand analysis.

As such, MPWMD has undertaken the attached Water Supply Assessment in conjunction with testimony filed with the California Public Utilities Commission (CPUC) on January 22, 2024. It is consistent with the State of California requirements for an UWMP and, specifically, a Water Shortage Contingency Plan in accordance with Sections 10632 and 10640 of the Act. Here, because MPWMD disagrees with Cal-Am on the need for implementation of a desalination facility, MPWMD’s Water Supply Assessment includes Pure Water Monterey Expansion, completion by the end of 2025, but excludes the Monterey Peninsula Water Supply Project desalination plant.

You can reach me at 831-658-5651 or [email protected] for any additional information.

Sincerely,
David J. Stoldt
General Manager
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1832, Packet Page 2160

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA
Application of California-American Water
Company (U210W) to Obtain Approval of
the Amended and Restated Water Purchase
Agreement for the Pure Water Monterey
Groundwater Replenishment Project, Update
Supply and Demand Estimates for the
Monterey Peninsula Water Supply Project,
and Cost Recovery
Application No. 21-11-024
(Filed November 29, 2021)
PHASE 2 SUPPLEMENTAL DIRECT TESTIMONY OF DAVID J. STOLDT De LAY & LAREDO
David C. Laredo, CSBN 66532
Frances M. Farina, CSBN 185035
606 Forest Avenue
Pacific Grove, CA 93950-4221
Telephone: (831) 646-1502
Facsimile: (831) 646-0377
Email: [email protected]
[email protected]

Attorneys for

MONTEREY PENINSULA WATER

MANAGEMENT DISTRICT
January 22, 2024
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1833, Packet Page 2161

TABLE OF CONTENTS
Page
I. INTRODUCTION ............................................................................................. 1 II. PURPOSE OF TESTIMONY ........................................................................... 2 III. WATER DEMAND .......................................................................................... 3 IV. WATER SUPPLY ............................................................................................. 8 V. SUPPLY V. DEMAND .................................................................................. 13 ATTACHMENT A: Water Supply Assessment Dated January 22, 2024 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1834, Packet Page 2162

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA
Application of California-American Water
Company (U210W) to Obtain Approval of
the Amended and Restated Water Purchase
Agreement for the Pure Water Monterey
Groundwater Replenishment Project, Update
Supply and Demand Estimates for the
Monterey Peninsula Water Supply Project,
and Cost Recovery
Application No. 21-11-024
(Filed November 29, 2021)
PHASE 2 SUPPLEMENTAL DIRECT TESTIMONY OF DAVID J. STOLDT I. INTRODUCTION
Q1: What is your name, title, and business address?
A1: My name is David Stoldt, and I am the General Manager of the Monterey Peninsula Water Management District (MPWMD). My address is 5 Harris Court, Building G, Monterey, CA 93940.

Q2: Have you previously provided testimony in this proceeding? A2: Yes, I submitted Phase 2 Direct Testimony on August 19, 2022, which expanded upon my credentials to include prior experience with demand forecasting. I also submitted testimony in Phase 1 of this proceeding on March 11, 2022,1 and April 4, 2022.2 My credentials were included in the March 11, 2022, Phase 1 direct testimony.
1 MPWMD-01, Direct Testimony of David J. Stoldt, dated March 11, 2022. 2 MPWMD-02, Supplemental Testimony of David J. Stoldt, dated April 1, 2022.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1835, Packet Page 2163 II. PURPOSE OF TESTIMONY
Q3: What is the purpose of your testimony?
A3: In response to the Administrative Law Judge’s Ruling Regarding Evidence and Setting Schedule Second Phase Hearings dated November 30, 2023, I am providing updated supply and demand analyses related to the Monterey Peninsula Water Supply Project, as well as providing alternative views to many of the issues raised in the Phase 2 Supplemental Direct Testimony of Christopher Cook of California-American Water Company (Cal-Am) dated December 21, 2023.

Q4: What specific issues does your direct testimony cover? A4: I will address the following:

Water Demand: The Cal-Am Updated Demand Estimate provided in Table 2 of the Phase 2 Supplemental Direct Testimony of Christopher Cook has three major errors and two minor errors, which result in significantly overstated results; Water Supply: Table 4 of the Phase 2 Supplemental Direct Testimony of Christopher Cook improperly and significantly understates the amount of supply available from Pure Water Monterey Expansion, Aquifer Storage and Recovery (ASR), the Seaside Groundwater Basin, and the Sand City Water Supply Project (desalination plant); and Malpaso water rights and wheeled water should be included. “Wheeled Water” refers to water supplied to Cal-Am’s distribution system by others and delivered by Cal-Am to serve demands on Cal-Am’s system.

Supply v. Demand: With Pure Water Monterey Expansion and without a desalination plant, projected supplies can meet forecasted demands for more than 30 years.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1836, Packet Page 2164 III. WATER DEMAND
Q5: What are the three major errors in the Cal-Am water demand forecast? A5: 1) It adds water demand for legal lots of record to water demand for population growth; 2) It adds water demand for the Regional Housing Needs Allocation (RHNA) to water demand for population growth; and 3) It mistakenly increases the amount of water used per person per day in future years.

The Cal-Am demand forecast in Table 2 of Cook’s Phase 2 Supplemental Direct Testimony starts with the population forecast from its 2020 Urban Water Management Plan (UWMP), but continues for an additional period to 2050. The UWMP states “The service area population will increase at the rate forecasted by AMBAG. For non-residential customers, water use will increase at the rate of employment growth forecasted by AMBAG”3 “AMBAG” is the Association of Monterey Bay Area Governments, an independent regional planning agency. Using an independent third party with expertise in demographic forecasting is an acceptable approach.

AMBAG has captured the factors that influence both residential and non-residential water demand growth in its Regional Growth Forecast. AMBAG’s Final 2022 Regional Growth Forecast which Ian Crooks of Cal-Am included as Attachment D to his Phase 2 Direct Testimony was the basis for the UWMP demand forecast and Table 2 to Cook’s Phase 2 Supplemental Direct Testimony. It is important to also note that AMBAG has already begun work on its 2026 Regional Growth Forecast and reflects “population projections are substantially lower than in the 2022 Regional Growth Forecast” and “job projections are also lower than in the 2022 RGF,”4 meaning that the demand projections in Table 2 of Cook’s testimony will be too high. 3 Phase 2 Direct Testimony of Ian C. Crooks, Attachment A, Cal-Am 2020 Urban Water Management Plan, p. 4-7. 4 AMBAG Board of Directors Agenda, January 10, 2024, pages 41-45 of 56; Document may be found at:
https://www.ambag.org/sites/default/files/2024-01/AMBAG%20January%202024%20Agenda.pdf ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1837, Packet Page 2165 “Legal Lots of Record” shown in the table (line 5, page 4) are empty lots upon which housing and businesses could be built. Empty lots themselves do not use water or increase water demand.

The same is true for the “RHNA Demands” shown in the table (line 9, page 4). RHNA stands for Regional Housing Needs Assessment and are housing numbers projected to meet future populations. Empty houses themselves do not use water or increase water demand.

Population moves to the area and lives in either existing housing stock or new housing stock that is built on Legal Lots of Record. The new 6th Cycle Regional Housing Needs Allocation Plan is reflected within the AMBAG Regional Growth Forecast. Houses and lots don’t use water, people do – population estimates drive water demand, not housing stock and buildable lot estimates. Cal-Am already captures Residential Demand for population (see bottom line of Table 2 on page 3 of Cook’s testimony.) Thus, adding water for Legal Lots of Record is double counting. Adding water for RHNA housing stock is triple counting.

Q6: How does the third major error, an increase in the amount of water used per person per day in future years impact the demand forecast?
A6: The third major error is stated on page 4, lines 19-21 of the Phase 2 Supplemental Direct Testimony of Cook: “Table 2 above also anticipates that residential use could increase by 10% to

60.7 GPCD by 2030 when a new permanent water supply source sufficient to meet long-term demand becomes available…” This is reflected in the Residential Demand section of the table (line 27, page 3) where GPCD stands for “gallons per capita per day.” A rising GPCD causes the residential water demand to be overstated in future years.

A rising GPCD is both counterintuitive and inconsistent with historic data, as well as current and future regulations. Residential per-capita water use will not increase over time and is ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1838, Packet Page 2166 expected to decline because of plumbing codes, appliance and fixture turnover, and new technology in existing and new housing. In addition to numerous local efficiency requirements, water waste restrictions, and tiered rates, the adoption of “Making Water Conservation a California Way of Life” (Senate Bill 606 and Assembly Bill 1668 of 2018), and its predecessor “the Water Conservation Act of 2009”5 will result in further reductions in per-capita use.

Recently amended State law (Water Code Section 10609.4) sets efficiency standards for indoor residential water use beginning with 55 gallons per capita per day (“GPCD”) until 2025, 47 GPCD from 2025-2030, then 42 GPCD thereafter. The recommendation to reduce GPCD came from the Department of Water Resources (“DWR”) and the State Water Resources Control Board (“SWRCB”) after the completion of the Indoor Residential Water Use Study6 (“IRWUS”) by the Pacific Institute. Note that the IRWUS found that lower GPCD will occur without the “active” conservation programs such as rebates, conservation-oriented rate structures, and education programs which can provide additional water savings.

Water Code Section 10609 also requires the DWR and the SWRCB to develop standards for both residential and non-residential outdoor water use. The resulting implementation of statemandated Urban Water Use Objectives by Cal-Am will result in more efficient landscapes and reduced outdoor water use, which will contribute to a reduction in overall residential demand and GPCD.

It is also counterintuitive that a person would use more water than at the present when the cost of water becomes 40%-60% higher due to the costs of a new water supply project, when that same person is not restricted from water use today (if a customer opens the tap today, water comes 5 Included as Attachments A and B to the Phase 2 Direct Testimony of Stephanie Locke, dated August 19, 2022 6 Attachment K, Results of Indoor Residential Water Use Study, to the Phase 2 Direct Testimony of Stephanie Locke, dated August 19, 2022
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1839, Packet Page 2167 out.) In fact, Cal-Am’s own witness in its current General Rate Case says “The Law of Demand is a fundamental principle in economics that states that as the price of a good or service increases, the quantity demanded of that good or service will decrease… It is one of the most widely accepted principles in economics and has been supported by extensive empirical research. It is incontrovertible that the Law of Demand applies to residential water service.”7 With the desalination plant expected to cost $300 to $400 million, it could add as much as 50% or more to the revenue requirement, and thus rates.

Q7: What are the two minor errors in Table 2 of Cook’s Phase 2 Supplemental Direct Testimony?
A7: He includes Pebble Beach Entitlements and Tourism Rebound as additional water demand, when in fact they are already captured in the Residential and Non-Residential Demand forecasts of Table 2.

Pebble Beach Entitlements are set aside to build new housing or commercial uses within Pebble Beach. However, they are also already included in the AMBAG Regional Growth Forecast for the unincorporated County – within Residential Demand for population growth and within Non-Residential Demand for new hotel rooms and other commercial uses.

Tourism Rebound has already occurred with no corresponding increase in commercial water use. This is an antiquated and no longer relevant concept that is no longer justified. Such a factor should not be added as additional water demand in future years. The 500 acre-feet per year (AFY) for economic recovery was originally suggested by the local hospitality industry in 2012 – over a decade ago – to account for a recovery of occupancy rates in the tourist industry in a postWorld Trade Center tragedy setting. Representatives of the Coalition of Peninsula Businesses 7 Rebuttal Testimony of David Mitchell, witness for Cal-Am in CPUC Proceeding A.22-07-001, footnote 62, pages 36-37, May 25, 2023
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1840, Packet Page 2168 indicated in 2017 testimony that the hospitality industry was hurt by the recent recession and that occupancy rates need to increase by 12 to 15 percent to re-attain the levels of decades ago.8 It is true that the Salinas-Monterey market was one of five California markets, out of 22, to experience significant declines after the events of 2001, from 71.8% in 2000 to 63.0% in 2001.9 It is also true that the decline persisted and has not been revised at the time the MPWSP desalination plant was sized in April 2012, with occupancy rates of 62.8% in 2011-12 and 64.1% in 2012-13. However, occupancy rates have since recovered with no notable increase in water demand. Local hotel occupancy rates returned to approximately 70%-75% in the post-COVID years. In so far as Tourism Rebound has already occurred, a factor to reflect this former concern is no longer needed.

Finally, Assembly Bill No. 1572, signed into law by the Governor on October 13, 2023, further restricts the use of potable water for irrigation of non-functional turf in commercial and institutional settings, putting additional pressure on reduced demand in the non-residential sector.

Q8: How far off is Cal-Am’s demand forecast?
A8: Cal-Am has overstated demand by at least 1,470 AF in 2030 and by 3,900 AF in 2050, possibly more, depending on assumptions, which is 14% too high in 2030 and 37% too high in 2050.

Q9: Does MPWMD have a demand forecast of its own to share? A9: Yes. MPWMD adopted the following growth rates in water demand based on the AMBAG 2022 Regional Growth Forecast, similar to Cal-Am, and used current production, a measure of the total water required before losses or fire flows, as the base. However, in the Water Supply Assessment scenario analysis and drought risk assessment attached as Attachment A to this testimony, alternative growth rates in demand are evaluated. 8 See Attachment L to the Phase 2 Direct Testimony of David J. Stoldt, August 19, 2022. 9 Id., p. 5, HVS San Francisco, August 19, 2003.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1841, Packet Page 2169 Table 1
Calculation of Future Year Water Demand Growth
AF per Year
Demand Growth
Water for
Population 18.00
Water for NonResidential 13.44
Total 31.44
Table 2
Demand Forecast – Expected Outcome Scenario
Baseline
2025 2030 2035 2040 2045 2050
Residential 6,378 6,468 6,558 6,648 6,738 6,828
Non-Residential 3,435 3,502 3,569 3,636 3,703 3,771
Total 9,813 9,970 10,217 10,285 10,442 10,599
IV. WATER SUPPLY
Q10: On what assumptions about water supply does MPWMD disagree with Cal-Am? A10: MPWMD is in general agreement with Cal-Am about the Carmel River and Pure Water Monterey base project sources of supply, but disagrees with Cal-Am’s view of Pure Water Monterey Expansion, Aquifer Storage and Recovery (ASR), the Seaside Groundwater Basin, and the Sand City Water Supply Project. Further, MPWMD believes that Malpaso LLC and Seaside Basin water wheeled by others should be included as sources.

Water supply available in any year is the aggregate of the many different sources of supply. The sources of supply can be divided into two categories: “Water Supplies not Affected by Drought” and “Water Supplies Affected by Drought”. Each of these are described below.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1842, Packet Page 2170 Table 3
Water Supplies not Affected by Drought
Source of Supply Capacity
(AFY)
Carmel River 3,376
Seaside Basin 1,474
Seaside Basin Wheeled 20
Malpaso 86
Pure Water Monterey Base 3,500
The Carmel River water right is considered not affected by drought because the aquifer refills to 95% or beyond with 6- to 8 weeks of river flow, which typically occurs in a “Normal” water year.

Even in a “Below Normal” or “Dry” year, some replenishment occurs.

In our analysis, we initially value the Seaside Basin at 1,474 AFY instead of 774 AFY reflected in Table 4 of the Cook Phase 2 Supplemental Direct Testimony. The reason for this is that Cal-Am has adjusted for an “In Lieu” recharge program of 700 AFY beginning in the very first year of new supply availability. However, Cal-Am has in other forums indicated it would not begin the in lieu recharge until after it secures a desalination plant, a plant that MPWMD analysis shows unnecessary. Hence, we do account for such a recharge program in several of our scenarios analyzed in Attachment A hereto, but it is not a certainty that such a program is required when the full effects of stored water are considered.

Seaside Basin Wheeled water supply refers to just over 7 AFY that Montage Health and 13 AFY that the Ascent housing project has secured from other “Alternate Producers” with separate and distinct pumping rights under the Seaside Basin adjudication. Cal-Am will wheel this water. This amount could include surplus September Ranch water in the future, but it is not included here.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1843, Packet Page 2171 Malpaso water supply refers to water made available to Cal-Am by the Malpaso Water Company, LLC based on its own separate and distinct water license to meet Cal-Am demand by properties in the unincorporated Carmel Valley or the City of Carmel that have paid for water entitlements, as well as any excess which is allowed to serve other Cal-Am customers. It is subject to the same conclusions as the Carmel River water right held by Cal-Am, meaning not affected by drought.

The Pure Water Monterey (PWM) Base project supply includes a variety of wastewater and PWM source waters that combined are approximately twice the requirements of the project. Monterey One Water (M1W) has a priority right to use the source waters.10 All data presented to date by Monterey One Water (M1W), the owner and operator of the project, show no impact of drought on source water.

Q11: What supply sources are impacted by drought?
A11: MPWMD defines “Drought” as two or more consecutive years when unimpaired streamflow data falls into the “Dry” or “Critically Dry” categories. Water year classifications and corresponding dependent supplies are shown in the tables in the Water Supply Assessment in Attachment A hereto.

Three supply sources are considered affected by drought: Pure Water Monterey Expansion, Aquifer Storage and Recovery (ASR), and Sand City Desalination, as shown in the table below. //
//
//
10PWM Source Waters include water in the Blanco Drain and Reclamation Ditch, urban storm water runoff from the cities of Salinas and Monterey, Salinas Agricultural Wash Water (Ag Wash Water), and treated water in Pond 3 at the Salinas Treatment Facility (also referred to as Pond Recovery Water).

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1844, Packet Page 2172 Table 4
Water Supplies Affected by Drought11
Source of Supply Capacity (AFY)
Pure Water Monterey Expansion 1,905 to 2,250
Aquifer Storage and Recovery 0 to 1,210
Sand City Desalination 160 to 200
Pure Water Monterey Expansion is based on documentation by M1W that in dry/drought years the PWM Expansion production will be approximately 345 AFY short in total from June through September (four months). However, the PWM base project can produce approximately 200 AFY of extra water in the winter months, yielding a net shortfall of 145 AFY. In the drought risk assessment attached as Attachment A hereto, scenarios are analyzed where the assumed shortfall is correlated to drought years and could be in the range of 145 AFY to 345 AFY, as further described in the “Scenario Analysis” section of Attachment A. Table 4 of Cook’s Phase 2 Supplemental Direct Testimony incorrectly suggests PWM Expansion could be 0 to 1,100 AFY in drought – which is directly refuted by the Phase 2 Supplemental Direct Testimony of Paul Sciuto, dated January 22, 2024.

MPWMD has long held that the yield of ASR is 1,300 AFY based on District data. However, for purposes of this analysis, MPWMD has adopted Cal-Am data presented in the Paul Findley, Sarp Sekeroglu “ASR Reliability Analysis” dated July 15, 2022, and included in the Cal-Am Phase 2 Direct Testimony of Paul Findley dated July 20, 2022, which is also included in Attachment A, Exhibit 3, hereto. In the Findley memorandum and testimony, he computes the average annual yield of ASR to be 1,210 AFY. However, the actual yield in a year depends on streamflow and 11M1W defines dry/drought years as years when the Salinas River Diversion Facility is not operated, typically “Dry” and “Critically Dry” years as documented by MPWMD. MPWMD defines drought as two or more “Dry” or “Critically Dry” years in a row.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1845, Packet Page 2173 rainfall, so Cal-Am’s witnesses obtained daily Carmel River flow records for 59 years (1963 to 2021), and then prepared a hypothetical simulation in which they looked at the river flow for each day and determined if ASR diversion would have been permitted under present-day permit rules.

If that day qualified as an injection day, they then determined if ASR injection would have been

13.3 acre-feet per day (AFD) or 17 AFD for that day, depending on the amount of streamflow and the relevant permits. They then compiled and analyzed the results for each year. The range of yields is 0 AFY in a “Critically Dry” year to 2,843 AFY in an “Extremely Wet” year. Each year of the 59-year hydrologic cycle was entered individually and analyzed in the Water Supply Assessment’s drought risk assessment in Attachment A hereto.

In the drought risk assessment in Attachment A hereto, three scenarios are analyzed (i) where the assumed ASR injection rate could have achieved the maximum 17 AFD, (ii) was limited to 13.3 AFD, or worse, (iii) was only achievable at 75% of the 13.3 AFD due to unidentified persistent Cal-Am operating constraints, as further described in the “Scenario Analysis” section of Attachment A.

Sand City Desalination is expected to provide 200 AFY in non-drought years once a new intake well is fully permitted, expected to occur before PWM Expansion comes online. However, during drought periods, it is assumed that Sand City Desalination provides a reduced 80% level beginning the second year of drought and restores to the 100% level a year after the drought ends. Cal-Am is incorrect to discount Sand City desalination to only 94 AFY because the Cal-Am demand forecast includes all Sand City demand, whether served by Cal-Am sources or Sand City’s own entitlement, and the source is being delivered through the Cal-Am distribution system. Any Sand City desalination produced is available supply to demands in Sand City or elsewhere.

Q12: Is it true that Cal-Am has accounted only for available supplies of 470 AFY from ASR in a normal year, less during a drought?
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1846, Packet Page 2174 A12: Yes, Cal-Am has previously testified to that12, and reasserts the claim in Table 4 of the Phase 2 Supplemental Direct Testimony of Cook, but it is the result of faulty technical analysis.

Q13: What makes the Cal-Am technical analysis of ASR faulty? A13: It ignores the importance of storage. In its testimony, Cal-Am states: “The capability of the ASR system to provide potable water to California American Water’s portfolio is highly unpredictable and depends entirely on rainfall conditions during a water year.”13 This is not entirely correct. Instead, the capability of the ASR system to provide potable water to Cal-Am depends on rainfall conditions during a water year and stored ASR water from prior years.

Cal-Am’s analysis focuses on injection in the water year and has mistakenly left storage completely out of the equation. In fact, in the Phase 2 Rebuttal Testimony of Paul Findley, the witness states “carry-over storage to the following year is not addressed…”14 Instead, Findley relies on confidence levels for injection within a water year, but completely misses the importance of storage of excess supply from years available to when needed. Even the American Water Works Association (AWWA) recognizes ASR in its reliability assessment: “ASR wells can improve water basin management by storing water underground from periods of excess supply…, and later allowing a portion of the stored water to be extracted during periods of demand or short supply”15 V. SUPPLY v. DEMAND
Q14: How do MPWMD’s conclusions on future supplies versus demand differ from Cal-Am’s? 12 Phase 2 Direct Testimony of Ian C. Crooks, Corrected, dated July 25, 2022, p. 37 at line12 13 Id., p. 34, beginning at line 12. 14 Phase 2 Rebuttal Testimony of Paul Findley, page 8, line 22, September 19, 2022. 15 See Attachment O to Phase 2 Direct Testimony of David J. Stoldt, August 19,2022, AWWA, “Water Resources Planning: Manual of Water Supply Practices M50”, 3rd Edition, p. 148.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1847, Packet Page 2175 A14: MPWMD believes that available supplies, even when adjusted for drought, will frequently exceed water demands to such a level as to allow a significant accumulation of storage, which CalAm has completely left out of their analysis.

The aggregate total of water supplies available to serve customers in a year is the sum of “Water Supplies not Affected by Drought”, “Water Supplies Affected by Drought”, and stored (or “banked”) water. In many years, the sum not including stored water will exceed the total expected demand, due in part to the slow evolution of new population, housing, and jobs, creating a surplus that goes into storage. Furthermore, in years where rainfall and streamflow are significant, the amount available from ASR will add to the surplus. Alternatively, in years of drought or in later years when demand has grown, annual (in-year) supplies may produce less or no surplus.

Surplus water must be tracked as “Stored Water”, within the limits of the law, to benefit the region’s water security. In any single year the supplies available to meet customer demand are the joint amount of supply available from sources in that year plus prior end-of-year storage.

Q15: Has MPWMD analyzed the impact of stored water?
A15: Yes. MPWMD performed a multi-scenario Water Supply Assessment consistent with the State of California requirements for a UWMP and, specifically, a Water Shortage Contingency Plan in accordance with Sections 10632 and 10640 of the Act. The drought risk assessment compares water supplies available in the future under a normal water year, a single dry water year, and a drought lasting five consecutive water years. In the analysis in Attachment A hereto, MPWMD takes 59 years of actual water year data and reorders it to start in a 5-year drought in the first full year after the PWM Expansion project comes online, expected to be in late 2025.

The 59-year historical hydrology represents 1963 through 2021 and the 5-year drought began in 1987. Once the pattern of climate, weather, and hydrology is established eight different supply v.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1848, Packet Page 2176 demand scenarios are analyzed. Each scenario is progressively more restrictive, meaning increasing demand expectations, reducing supply availability, or both at the same time. The eight scenarios analyzed are identified in Attachment A:

Scenario 1- Expected Outcome:
• ASR injects up to 17 AF per day if weather and streamflow support it. • PWM Expansion “borrows” 145 AFY from storage in drought years. • Sand City Desalination is diminished 20% beginning 2nd drought year. • Demand grows at AMBAG 2022 Regional Growth Forecast average rate. • Start with 2,159 AF in storage – the ASR balance at the end of 2023. Does not include the PWM Operating Reserve storage.

The results of this most Expected Outcome are shown below. Notice how the green line – the total available supply – far exceeds the demand in all years. 0 10,000
20,000
30,000
40,000
50,000
60,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Acre-Feet
Year Following PWM Expansion
Supply and Storage Available v. Demand
30 Years Following PWM Expansion
Scenario 1 - Expected Outcome
Supply Available
in Year
Demand
Available in Year
Plus Prior Year
Storage
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1849, Packet Page 2177 Seven other alternative scenarios, each more restrictive than the next, were evaluated. The results show that the Expected Outcome (Scenario 1) and three other more restrictive scenarios provide sufficient water supply for the entire 59-year hydrologic cycle. Scenarios 1 – 7 demonstrate an adequate supply for over 30 years, with Scenario 8 demonstrating sufficient supply for 26 years. Results are summarized in the table below:

Table 5
Results of Scenario Analysis
Scenario Years of Supply
Exceeding Demand
Storage at
End of Period
Scenario 1 More than 59 65,507 AF
Scenario 2 More than 59 65,507 AF
Scenario 3 More than 59 65,444 AF
Scenario 4 More than 59 10,371 AF
Scenario 5 51 0 AF
Scenario 6 40 0 AF
Scenario 7 37 0 AF
Scenario 8 26 0 AF
In other words, existing Monterey Peninsula supplies, plus PWM Expansion, and adjusted for drought occurrence, provide sufficient water for expected and higher water demand requirements for approximately three decades or more, without the necessitation of a desalination plant.

Q16: What else can stored water be used for?
A16: In addition to eliminating a need for a 10% supply contingency from bigger construction, the stored water can be used for peaking to meet maximum month demands (MMD), maximum day demand (MDD), and peak hourly demand (PHD) without building more supply projects. It is ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1850, Packet Page 2178 always in the ratepayer’s interest to build one or two additional production wells for $3 million each, rather than a $300 to $400 million desalination plant if saved or stored water can be utilized to meet peak demands.

Stored water can also be used as a drought reserve and to provide protective water levels in the Seaside Groundwater Basin. It may be possible that the Cal-Am proposed “In Lieu” recharge program for the Seaside Basin could be reduced or eliminated.

Q17: Does that conclude your Phase 2 Supplemental Direct Testimony? A17: Yes.

Attachment A – 2024 Water Supply Assessment for Monterey Peninsula Water Management District including California American Main System
Exhibit 1: Monterey Peninsula Water Supply Assessment for 59 Years Following Pure Water Monterey Expansion
Exhibit 2: Monterey Peninsula Water Management District Technical Memorandum Exhibit 3: Phase 2 Direct Testimony of Paul Findley
Exhibit 4: Seaside Basin Watermaster Annual Report - 2023 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1851, Packet Page 2179 Attachment A
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1852, Packet Page 2180 2024 Water Supply Assessment
for
Monterey Peninsula Water Management District
including
California American Main System
(Considering Water Supply and Demand
and
Water Shortage Contingency Planning)
January 22, 2024
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1853, Packet Page 2181 Summary
The Monterey Peninsula Water Management District (MPWMD) has undertaken a Water Supply Assessment of the future water supplies available versus projected water use demand, considering resiliency to periodic droughts, including starting out in a 5-year drought following Pure Water Monterey Expansion coming online.

The reader is encouraged to read this Assessment in its entirety. However, the conclusive evidence shows that existing Monterey Peninsula water supplies, plus PWM Expansion, and adjusted for drought occurrence, provides sufficient water for expected and higher water demand requirements for more than three decades in most cases, without necessitation of a desalination plant.

Introduction to Water Supply Assessment
Under California Water Code Section 10910, as a city or the county develops growth plans for jobs and housing on the Monterey Peninsula, the water supply assessment required under CEQA for the projects shall include a discussion with regard to whether the public water system's – in this case, California American Water Company’s (Cal-Am’s) – total projected water supplies available during normal, single dry, and multiple dry water years during a 20-year projection will meet the projected water demand associated with the proposed projects, in addition to Cal-Am’s existing and planned future uses.

If the projected water demand associated with the proposed projects was accounted for in the most recently adopted urban water management plan (UWMP), Cal-Am should provide the water supply assessment and incorporate the requested information from the urban water management plan in preparing and submitting the assessment within 90 days of the request, or request an extension of time.

The “Urban Water Management Planning Act” (Act) is comprised of Section 10610 through 10657 of the California Water Code Division 6, Part 2.6. Under Section 10620, every urban water supplier shall prepare and adopt a UWMP. An urban water supplier indirectly providing water, such as MPWMD as a wholesaler, shall not include planning elements in its water management plan as provided in Article 2 (commencing with Section 10630) that would be applicable to urban water suppliers or public agencies directly providing water, such as Cal-Am.

Hence, it is Cal-Am that is obligated to work with a city or the county to provide a water supply assessment to assist with CEQA. However, that section of the Act also provides that each urban water supplier shall coordinate the preparation of its plan with other appropriate agencies in the area, including other water suppliers that share a common source, water management agencies, and relevant public agencies, to the extent practicable. MPWMD was not asked by Cal-Am to coordinate on its UWMP, nor does MPWMD agree with many of the assumptions and conclusions of Cal-Am’s UWMP and subsequent Cal-Am supply and demand analysis.

As such, MPWMD has undertaken this Water Supply Assessment consistent with the State of ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1854, Packet Page 2182 California requirements for an UWMP and, specifically, a Water Shortage Contingency Plan in accordance with Sections 10632 and 10640 of the Act.

Requirements of a Water Supply Assessment
An UWMP is required to include current and projected population, climate, and other social, economic, and demographic factors affecting the supplier’s water management planning. The projected population estimates shall be based upon data from the state, regional, or local service agency population projections within the service area to at least 20 years. It shall consider the current and projected land uses within the existing or anticipated service area, which the following analysis does.

The UWMP should identify and quantify, to the extent practicable, the existing and planned sources of water available over the same period, including detailed discussion of anticipated supply availability under a normal water year, single dry year, and droughts lasting at least five years, as well as more frequent and severe periods of drought, as described in the drought risk assessment. The analysis discussed below not only starts in a 5-year drought, but includes periodic droughts of 2 to 4 years.

Past and current water use and projected water use among water use sectors, such as singlefamily residential, multifamily, commercial, industrial, institutional, and governmental, and so on, including losses, should be considered.

The UWMP shall include a detailed description of expected future projects and programs that the urban water supplier may implement to increase the amount of the water supply available, as well as an implementation timeline. Here, because MPWMD disagrees with Cal-Am on the need for implementation of a desalination facility, MPWMD’s Water Supply Assessment includes Pure Water Monterey Expansion, completion by the end of 2025, but excludes the Monterey Peninsula Water Supply Project desalination plant.

Section 10632 of the California Water Code also requires every urban water supplier to prepare and adopt a water shortage contingency plan (WSCP) as part of its UWMP that includes analysis of water supply reliability conducted pursuant to Section 10635 of the Code.

Section 10635 requires an assessment of the reliability of its water service to its customers during normal, dry, and multiple dry water years. This water supply and demand assessment shall compare the total water supply sources available to the long-term total projected water use (demand) over at least the next 20 years for a normal water year, a single dry water year, and a drought lasting five consecutive water years.

The drought risk assessment shall include each of the following:
(1) The data, methodology, and basis for one or more supply shortage conditions that are necessary to conduct a drought risk assessment for a drought period that lasts five ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1855, Packet Page 2183 consecutive water years, starting from the year following when the assessment is conducted. Here, MPWMD’s assessment will evaluate starting in a 5-year drought coincident with the Pure Water Monterey Expansion coming online. (2) A determination of the reliability of each source of supply under a variety of water shortage conditions. This may include a determination that a particular source of water supply is fully reliable under most, if not all, conditions. (3) A comparison of the total water supply sources available to the total projected water use for the drought period.
(4) Considerations of the historical drought hydrology, plausible changes on projected supplies and demands under climate change conditions, anticipated regulatory changes, and other locally applicable criteria, as included in this analysis.

Important to understand is that MPWMD defines “Drought” as two or more consecutive years where unimpaired streamflow data falls into the “Dry” or “Critically Dry” categories.

MPWMD’s Water Supply Assessment
Water Demand:

The projected population estimates are based on the Association of Monterey Bay Area Governments (AMBAG) adopted 2022 Regional Growth Forecast, a 25-year forecast.

Past water use and projected water use among water use sectors were “mapped” onto data showing “production for customer service”, based on actual Cal-Am consumption information for residential use (single-family residential and multifamily) and non-residential use (commercial, industrial, institutional, and governmental). Because each city or the county may grow at a different pace, the sectors were also analyzed by political jurisdiction, again using actual Cal-Am data, and then aggregated.

The percentages of historical consumption were then applied to “production for customer service” which is actual Cal-Am data showing how much water must be produced (supplied) into the system to satisfy customer demand. Hence, losses in the distribution system are accounted for because supply is calculated before it enters the distribution system.

Residential demand growth rate is based on the AMBAG population forecast growth rates by jurisdiction and non-residential demand is based on the AMBAG job growth rates as a proxy for economic growth.

This methodology was utilized in the MPWMD Adopted 2022 Supply and Demand Forecast attached hereto as Exhibit 2. That Demand Forecast indicated growth in water demand as follows:

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1856, Packet Page 2184 Residential Water Demand Growth Rate: 18.00 acre-feet per year (AFY) Non-Residential Water Demand Growth Rate: 13.44 AFY
Total Annual Growth Rate in Water Demand: 31.44 AFY
By comparison, the average growth in, or absorption of, water use in the decade preceding the State’s Cease and Desist Order (CDO) was during a period of relative economic stability, available property, no moratorium on new service connections, and lower water rates, yet only resulted in 16.4 AFY of new demand.

In the drought risk assessment below, scenarios are analyzed where the assumed growth rate in demand is doubled or more, as further described in the “Scenario Analysis” section.

The starting demand value, or “Base Year” assumed to be the year prior to the Pure Water Monterey (PWM) Expansion coming online, is 9,813 AF. That value is the 10-year average of actual production for customer service for Cal-Am 2014-23.

Water Supply:

Water supply available in any year is the aggregate of the many different sources of supply. The sources of supply can be divided into two categories: “Water Supplies not Affected by Drought” and “Water Supplies Affected by Drought”. Each of these are described below.

Water Supplies not Affected by Drought
Source of Supply Capacity
(AFY)
Carmel River 3,376
Seaside Basin 1,474
Seaside Basin Wheeled 20
Malpaso 86
Pure Water Monterey Base 3,500
The Carmel River water right is considered not affected by drought because the aquifer refills to 95% or beyond with 6- to 8-weeks of river flow, which typically occurs in a “Normal” water year. Even in a “Below Normal” or “Dry” year, some replenishment occurs.

The volume of “Usable Storage” of the Carmel Valley Alluvial Aquifer is 28,458 AF. In 2022, a “Dry” year, all known wells produced 5,421 AFY. Thus, a full aquifer can meet approximately a 5-year pumping demand.

Furthermore, recent historical data shows that drought periods were preceded or followed by water years that would likely have refilled to aquifer to 95% or greater, as shown in the table below:

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1857, Packet Page 2185 Period # of Years
of Drought
Water Year Type
1976-77 2 Before: “Above Normal”
After: “Extremely Wet”
1987-91 5 Before: “Wet”
After: “Normal”
2012-15 4 Before: “Above Normal”
After: “Normal”
2021-22 2 Before: “Normal”
After: “Extremely Wet”
Regarding the Seaside Basin, there is no evidence from the most recent three droughts that reductions in pumping were required.

Seaside Basin Wheeled water supply refers to just over 7 AFY that Montage Health and 13 AFY that the Ascent housing project have secured from other “Alternate Producers” with separate and distinct pumping rights under the Seaside Basin adjudication. Again, there is no evidence from the most recent three droughts that reductions in pumping were required. This amount could include surplus September Ranch water in the future, but it is not included here.

Malpaso water supply refers to water made available to Cal-Am by the Malpaso Water Company, LLC based on its own separate and distinct water license to meet Cal-Am demand by properties in the unincorporated Carmel Valley or the City of Carmel that have paid for water entitlements, as well as any excess which is allowed to serve other Cal-Am customers. It is subject to the same conclusions as the Carmel River water right held by Cal-Am, meaning not affected by drought.

The Pure Water Monterey (PWM) Base project supply amount is deemed to be not affected by drought because the source waters to meet the supply are approximately twice the requirements of the project, and the PWM Base project has a first right to that source water. All data presented to date by Monterey One Water (M1W), the owner and operator of the project, show no impact of drought on source water.

Water Supplies Affected by Drought
Source of Supply Capacity (AFY)
Pure Water Monterey Expansion 1,905 to 2,250
Aquifer Storage and Recovery 0 to 1,210
Sand City Desalination 160 to 200
Pure Water Monterey Expansion is based on documentation by M1W that in dry/drought years the PWM Expansion production will be approximately 345 AFY short in total from June through September (four months). However, the PWM Base project can produce approximately 200 AFY of extra water in the winter months, yielding a net shortfall of 145 AFY for the combined expanded project. In the drought risk assessment below, scenarios are analyzed where the assumed shortfall is correlated to “Dry” and “Critically Dry” years when the Salinas River ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1858, Packet Page 2186 Diversion Facility (SRDF) is not available and could be in the range of 145 AFY to 345 AFY, as further described in the “Scenario Analysis” section.

MPWMD has long held that the yield of Aquifer Storage and Recovery (ASR) is 1,300 AFY based on District data. However, for purposes of this analysis MPWMD has accepted Cal-Am data presented in the Paul Findley, Sarp Sekeroglu “ASR Reliability Analysis” dated July 15, 2022 and included in the Cal-Am Phase 2 Direct Testimony of Paul Findley dated July 20, 2022 and attached as Exhibit 3 hereto. In the Findley memorandum and testimony, he computes the average annual yield of ASR to be 1,210 AFY. However, the actual yield in a year depends on streamflow and rainfall, so Cal-Am’s witnesses obtained daily Carmel River flow records for 59 years (1963 to 2021), and then prepared a hypothetical simulation in which they looked at the river flow for each day and determined if ASR diversion would have been permitted under present day permit rules. If that day qualified as an injection day, they then determined if ASR injection would have been 13.3 acre-feet per day (AFD) or 17 AFD for that day, depending on the amount of streamflow and the relevant permits. They then compiled and analyzed the results for each year. The range of yields is 0 AFY in a “Critically Dry” year to 2,843 AFY in an “Extremely Wet” year. Each year of a 59-year hydrologic cycle was entered individually.

In the drought risk assessment below, scenarios are analyzed where the assumed ASR injection rate could have achieved the maximum 17 AFD, was limited to the 13.3 AFD, or worse, was only achievable at 75% of the 13.3 AFD due to persistent Cal-Am operating constraints, which might included limited Carmel Valley well capacity or other causes, as further described in the “Scenario Analysis” section.

Sand City Desalination is expected to provide 200 AFY in non-drought years once a new intake well is fully permitted, expected to be before PWM Expansion comes online. However, during drought periods, it is assumed that Sand City Desalination provides a reduced 80% level beginning the second year of drought and restores to the 100% level a year after the drought ends.

Again, MPWMD defines “Drought” as two or more consecutive years when unimpaired streamflow data falls into the “Dry” or “Critically Dry” categories. Water year classifications and corresponding dependent supplies are shown in the tables attached in Exhibit 1.

Storage:

The aggregate total of water supplies available to serve customers in a year is the sum of “Water Supplies not Affected by Drought”, “Water Supplies Affected by Drought”, and stored (or “banked”) water. In many years, the sum not including stored water will exceed total expected demand, due in part to the slow evolution of accumulated demand and market absorption of new population, housing, and jobs, creating a surplus which goes into storage. Furthermore, in years where rainfall and streamflow are significant, the amount available from ASR may add to a surplus. Alternatively, in years of drought or in later years when demand has grown, annual (in year) supplies may become strained.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1859, Packet Page 2187 Surplus water must be tracked as “Stored Water”, within the limits of the law, to benefit the region’s water security. In any single year the supplies available to meet customer demand are the joint amount of supply available from sources in that year plus prior end-of-year storage.

However, “Stored Water” will only be stored in the Seaside Basin and is limited by storage rights in that adjudicated basin. The Cal-Am storage rights in the Seaside Basin are 68,382 AF as shown in Exhibit 4 hereto. Assuming that MPWMD desires to hold a separate Operating Reserve of 2,875 AF for PWM, storage rights should considered be a maximum of 65,507 AF. The drought risk assessment below reflects such a limit.

Scenario Analysis
This Water Supply Assessment is consistent with the State of California requirements for an UWMP and, specifically, a Water Shortage Contingency Plan in accordance with Sections 10632 and 10640 of the Act. The drought risk assessment compares water supplies available in the future under normal water year, a single dry water year, and a drought lasting five consecutive water years. In the analysis that follows, MPWMD takes 59 years of actual water year data and reorders it to start in a 5-year drought in the first year that the PWM Expansion project comes online, expected to be in 2026.

The 59-year historical hydrology represents 1963 through 2021 and the 5-year drought began in 1987. Once the pattern of climate, weather, and hydrology is established eight different supply v. demand scenarios are analyzed. Each scenario is progressively more restrictive, meaning increasing demand expectations, reducing supply availability, or both at the same time. The eight scenarios analyzed are identified below:

Scenario 1- Expected Outcome:
• ASR injects up to 17 AF per day if weather and streamflow support it. • PWM Expansion “borrows” 145 AFY from storage in drought years. • Sand City Desalination is diminished 20% beginning 2nd drought year. • Demand grows at AMBAG 2022 Regional Growth Forecast average rate. • Start with 2,159 AF in storage – the ASR balance at the end of 2023. Does not include the PWM Operating Reserve storage.

Scenario 2:
• Same as Scenario 1, but ASR injection reduced, limited to wells ASR wells 1 & 2, or

13.3 AF per day.

Scenario 3:
• Same as Scenario 2, but PWM Expansion “borrows” 345 AFY in drought years, with no winter “pay back”.

Scenario 4:

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1860, Packet Page 2188 • Same as Scenario 3, but demand grows at double (2x) the AMBAG rates. This addresses concerns of certain people who believe there is “pent-up demand” such that growth will exceed AMBAG’s Regional Growth Forecast.

Scenario 5:
• Same as Scenario 4, but supplies reduced by 700 AFY of Seaside “In Lieu Recharge” beginning in year 6 for 25 years.

Scenario 6:
• Same as Scenario 5, but assumes ASR injection at 75% of the 13.3 AFD due to unidentified persistent Cal-Am operating constraints.

Scenario 7:
• Same as Scenario 6, but zero starting (Year 1) storage balance.

Scenario 8:
• Same as Scenario 7, but residential demand grows at triple (3x) the AMBAG rates and non-residential demand grows at double (2x) the AMBAG rates. This addresses concerns of certain people that housing demands will be met more quickly and population will grow much faster than AMBAG’s Regional Growth Forecast. .

Results of Scenario Analysis
Each Scenario is shown in Exhibit 1, attached. The results show that the Expected Outcome (Scenario 1) and three other more restrictive scenarios provide sufficient water supply for the entire 59-year hydrologic cycle. Scenarios 1 – 7 demonstrate an adequate supply for over 30 years, with Scenario 8 demonstrating sufficient supply for 26 years. Results are summarized in the table below:

Scenario Years of Supply
Exceeding Demand
Storage at
End of Period
Scenario 1 More than 59 65,507 AF
Scenario 2 More than 59 65,507 AF
Scenario 3 More than 59 65,444 AF
Scenario 4 More than 59 10,371 AF
Scenario 5 51 0 AF
Scenario 6 40 0 AF
Scenario 7 37 0 AF
Scenario 8 26 0 AF
In other words, existing Monterey Peninsula supplies, plus PWM Expansion, and adjusted for drought occurrence, provides sufficient water for expected and higher water demand requirements for approximately three decades or more, without necessitation of a desalination plant.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1861, Packet Page 2189 Exhibit 1
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1862, Packet Page 2190 Available
Pure Pure Aquifer Non- in Year
Water Derived Seaside Water Water Storage & Sand Total Residential Residential Total Stored Plus Forecast Year From Carmel Seaside Basin Monterey Monterey Recovery City Water Water Water Water Water Prior Year Year Class Year River Basin Wheeled Malpaso Base Expansion (ASR) Desal Available Demand Demand Demand Surplus Deficit EOY Storage Base/Avg n/a 3,376 1,474 20 86 3,500 2,203 1,210 193 12,062 6,378 3,435 9,813 2,159 1 Dry 1987 3,376 1,474 20 86 3,500 2,105 0 200 10,761 6,396 3,448 9,844 917 0 3,076 12,920 2 Critically Dry 1988 3,376 1,474 20 86 3,500 2,105 0 160 10,721 6,414 3,461 9,876 845 0 3,921 13,7973 Critically Dry 1989 3,376 1,474 20 86 3,500 2,105 0 160 10,721 6,432 3,475 9,907 814 0 4,735 14,6424 Critically Dry 1990 3,376 1,474 20 86 3,500 2,105 0 160 10,721 6,450 3,488 9,939 782 0 5,517 15,4565 Dry 1991 3,376 1,474 20 86 3,500 2,105 307 160 11,028 6,468 3,502 9,970 1,058 0 6,575 16,5466 Normal 1992 3,376 1,474 20 86 3,500 2,250 449 160 11,315 6,486 3,515 10,002 1,314 0 7,889 17,8917 Wet 1993 3,376 1,474 20 86 3,500 2,250 1,643 200 12,549 6,504 3,529 10,033 2,516 0 10,405 20,4388 Critically Dry 1994 3,376 1,474 20 86 3,500 2,105 187 200 10,948 6,522 3,542 10,065 884 0 11,289 21,353 9 Extremely Wet 1995 3,376 1,474 20 86 3,500 2,250 2,262 200 13,168 6,540 3,556 10,096 3,072 0 14,361 24,457 10 Above Normal 1996 3,376 1,474 20 86 3,500 2,250 1,511 200 12,417 6,558 3,569 10,127 2,290 0 16,651 26,778 11 Above Normal 1997 3,376 1,474 20 86 3,500 2,250 1,627 200 12,533 6,576 3,582 10,159 2,374 0 19,025 29,184 12 Extremely Wet 1998 3,376 1,474 20 86 3,500 2,250 2,515 200 13,421 6,594 3,596 10,190 3,231 0 22,256 32,446 13 Normal 1999 3,376 1,474 20 86 3,500 2,250 1,705 200 12,611 6,612 3,609 10,222 2,389 0 24,646 34,867 14 Above Normal 2000 3,376 1,474 20 86 3,500 2,250 1,390 200 12,296 6,630 3,623 10,253 2,043 0 26,689 36,942 15 Normal 2001 3,376 1,474 20 86 3,500 2,250 1,159 200 12,065 6,648 3,636 10,285 1,781 0 28,469 38,754 16 Below Normal 2002 3,376 1,474 20 86 3,500 2,250 803 200 11,709 6,666 3,650 10,316 1,393 0 29,862 40,178 17 Normal 2003 3,376 1,474 20 86 3,500 2,250 1,974 200 12,880 6,684 3,663 10,347 2,533 0 32,395 42,743 18 Below Normal 2004 3,376 1,474 20 86 3,500 2,250 735 200 11,641 6,702 3,676 10,379 1,262 0 33,657 44,036 19 Wet 2005 3,376 1,474 20 86 3,500 2,250 2,310 200 13,216 6,720 3,690 10,410 2,806 0 36,463 46,874 20 Wet 2006 3,376 1,474 20 86 3,500 2,250 2,027 200 12,933 6,738 3,703 10,442 2,491 0 38,955 49,396 21 Critically Dry 2007 3,376 1,474 20 86 3,500 2,105 193 200 10,954 6,756 3,717 10,473 481 0 39,436 49,909 22 Normal 2008 3,376 1,474 20 86 3,500 2,250 936 200 11,842 6,774 3,730 10,505 1,338 0 40,773 51,278 23 Normal 2009 3,376 1,474 20 86 3,500 2,250 802 200 11,708 6,792 3,744 10,536 1,172 0 41,945 52,481 24 Above Normal 2010 3,376 1,474 20 86 3,500 2,250 2,232 200 13,138 6,810 3,757 10,568 2,571 0 44,516 55,083 25 Above Normal 2011 3,376 1,474 20 86 3,500 2,250 2,205 200 13,111 6,828 3,771 10,599 2,512 0 47,028 57,627 26 Dry 2012 3,376 1,474 20 86 3,500 2,105 201 200 10,962 6,846 3,784 10,630 332 0 47,360 57,990 27 Dry 2013 3,376 1,474 20 86 3,500 2,105 684 160 11,405 6,864 3,797 10,662 743 0 48,103 58,765 28 Critically Dry 2014 3,376 1,474 20 86 3,500 2,105 0 160 10,721 6,882 3,811 10,693 28 0 48,131 58,824 29 Dry 2015 3,376 1,474 20 86 3,500 2,105 253 160 10,974 6,900 3,824 10,725 249 0 48,380 59,105 30 Normal 2016 3,376 1,474 20 86 3,500 2,250 1,148 160 12,014 6,918 3,838 10,756 1,258 0 49,638 60,395 Water Supplies not Affected by Drought Water Supplies Affected by Drought Water Demand Monterey Peninsula Water Supply Assessment
For 59 Years Following Pure Water Monterey Expansion
Scenario 1
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1863, Packet Page 2191 31 Extremely Wet 2017 3,376 1,474 20 86 3,500 2,250 2,383 200 13,289 6,936 3,851 10,788 2,502 0 52,140 62,928 32 Below Normal 2018 3,376 1,474 20 86 3,500 2,250 265 200 11,171 6,954 3,865 10,819 352 0 52,492 63,311 33 Extremely Wet 2019 3,376 1,474 20 86 3,500 2,250 2,026 200 12,932 6,972 3,878 10,851 2,082 0 54,574 65,424 34 Normal 2020 3,376 1,474 20 86 3,500 2,250 1,640 200 12,546 6,990 3,892 10,882 1,664 0 56,238 67,120 35 Dry 2021 3,376 1,474 20 86 3,500 2,105 80 200 10,841 7,008 3,905 10,913 0 72 56,166 67,07936 Above Normal 1963 3,376 1,474 20 86 3,500 2,250 1,825 200 12,731 7,026 3,918 10,945 1,786 0 57,952 68,897 37 Dry 1964 3,376 1,474 20 86 3,500 2,105 347 200 11,108 7,044 3,932 10,976 132 0 58,084 69,060 38 Normal 1965 3,376 1,474 20 86 3,500 2,250 1,389 200 12,295 7,062 3,945 11,008 1,287 0 59,372 70,379 39 Dry 1966 3,376 1,474 20 86 3,500 2,105 787 200 11,548 7,080 3,959 11,039 509 0 59,881 70,920 40 Wet 1967 3,376 1,474 20 86 3,500 2,250 2,227 200 13,133 7,098 3,972 11,071 2,063 0 61,943 73,014 41 Critically Dry 1968 3,376 1,474 20 86 3,500 2,105 120 200 10,881 7,116 3,986 11,102 0 221 61,722 72,824 42 Extremely Wet 1969 3,376 1,474 20 86 3,500 2,250 1,974 200 12,880 7,134 3,999 11,133 1,747 0 63,469 74,603 43 Normal 1970 3,376 1,474 20 86 3,500 2,250 1,247 200 12,153 7,152 4,012 11,165 988 0 64,457 75,622 44 Below Normal 1971 3,376 1,474 20 86 3,500 2,250 1,024 200 11,930 7,170 4,026 11,196 734 0 65,191 76,388 45 Critically Dry 1972 3,376 1,474 20 86 3,500 2,105 147 200 10,908 7,188 4,039 11,228 0 320 64,872 76,099 46 Wet 1973 3,376 1,474 20 86 3,500 2,250 2,052 200 12,958 7,206 4,053 11,259 1,699 0 65,507 77,830 47 Above Normal 1974 3,376 1,474 20 86 3,500 2,250 2,282 200 13,188 7,224 4,066 11,291 1,898 0 65,507 78,695 48 Above Normal 1975 3,376 1,474 20 86 3,500 2,250 1,742 200 12,648 7,242 4,080 11,322 1,326 0 65,507 78,155 49 Critically Dry 1976 3,376 1,474 20 86 3,500 2,105 0 200 10,761 7,260 4,093 11,354 0 592 64,915 76,268 50 Critically Dry 1977 3,376 1,474 20 86 3,500 2,105 0 160 10,721 7,278 4,107 11,385 0 664 64,251 75,636 51 Extremely Wet 1978 3,376 1,474 20 86 3,500 2,250 2,366 160 13,232 7,296 4,120 11,416 1,816 0 65,507 77,48352 Normal 1979 3,376 1,474 20 86 3,500 2,250 1,735 200 12,641 7,314 4,133 11,448 1,193 0 65,507 78,148 53 Extremely Wet 1980 3,376 1,474 20 86 3,500 2,250 2,199 200 13,105 7,332 4,147 11,479 1,626 0 65,507 78,61254 Below Normal 1981 3,376 1,474 20 86 3,500 2,250 1,150 200 12,056 7,350 4,160 11,511 545 0 65,507 77,56355 Extremely Wet 1982 3,376 1,474 20 86 3,500 2,250 2,587 200 13,493 7,368 4,174 11,542 1,951 0 65,507 79,00056 Extremely Wet 1983 3,376 1,474 20 86 3,500 2,250 2,843 200 13,749 7,386 4,187 11,574 2,176 0 65,507 79,25657 Normal 1984 3,376 1,474 20 86 3,500 2,250 1,658 200 12,564 7,404 4,201 11,605 959 0 65,507 78,07158 Dry 1985 3,376 1,474 20 86 3,500 2,105 507 200 11,268 7,422 4,214 11,637 0 368 65,139 76,77559 Wet 1986 3,376 1,474 20 86 3,500 2,250 1,528 200 12,434 7,440 4,228 11,668 766 0 65,507 77,573 Notes: Seaside Basin Wheeled is comprised of 7.17 AF to Montage and 13 AF to Seaside Ascent project Malpaso is assumed to be 86 AFY production; less losses yields 80 AFY available to meet customer demandASR Uses actual 59-year record produced by Cal-Am witness in Phase 2 testimony to CPUC, starting in 1987 drought yearSand City Desal assumes 200 AFY with new intake well online; During 2nd year of drought and remaining drought year 20% reductionBase Year Water Demand is 9,813 AF, the 2023 10-year average; Assume to be split 65% Residential, 35% Non-ResidentialResidential Demand yearly increase: 18 AFY based on 2022 AMBAG Regional Growth Forecast (population) Non-Residential yearly increase: 13.44 AFY based on 2022 AMBAG Regional Growth Forecast (jobs) Initial storage includes ASR balance, excludes PWM Operating Reserve ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1864, Packet Page 2192 0 60,00050,00040,00030,00020,00010,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Acre-Feet
Year Following PWM Expansion
Supply and Storage Available v. Demand
30 Years Following PWM Expansion
Scenario 1
Supply Available in YearDemandAvailable in Year Plus PriorYear Storage ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1865, Packet Page 2193 Available
Pure Pure Aquifer Non- in Year
Water Derived Seaside Water Water Storage & Sand Total Residential Residential Total Stored Plus Forecast Year From Carmel Seaside Basin Monterey Monterey Recovery City Water Water Water Water Water Prior Year Year Class Year River Basin Wheeled Malpaso Base Expansion (ASR) Desal Available Demand Demand Demand Surplus Deficit EOY Storage Base/Avg n/a 3,376 1,474 20 86 3,500 2,203 1,055 193 11,907 6,378 3,435 9,813 2,159 1 Dry 1987 3,376 1,474 20 86 3,500 2,105 0 200 10,761 6,396 3,448 9,844 917 0 3,076 12,920 2 Critically Dry 1988 3,376 1,474 20 86 3,500 2,105 0 160 10,721 6,414 3,461 9,876 845 0 3,921 13,7973 Critically Dry 1989 3,376 1,474 20 86 3,500 2,105 0 160 10,721 6,432 3,475 9,907 814 0 4,735 14,6424 Critically Dry 1990 3,376 1,474 20 86 3,500 2,105 0 160 10,721 6,450 3,488 9,939 782 0 5,517 15,4565 Dry 1991 3,376 1,474 20 86 3,500 2,105 307 160 11,028 6,468 3,502 9,970 1,058 0 6,575 16,5466 Normal 1992 3,376 1,474 20 86 3,500 2,250 373 160 11,239 6,486 3,515 10,002 1,238 0 7,813 17,8157 Wet 1993 3,376 1,474 20 86 3,500 2,250 1,413 200 12,319 6,504 3,529 10,033 2,286 0 10,099 20,1328 Critically Dry 1994 3,376 1,474 20 86 3,500 2,105 187 200 10,948 6,522 3,542 10,065 884 0 10,983 21,047 9 Extremely Wet 1995 3,376 1,474 20 86 3,500 2,250 1,933 200 12,839 6,540 3,556 10,096 2,743 0 13,726 23,822 10 Above Normal 1996 3,376 1,474 20 86 3,500 2,250 1,280 200 12,186 6,558 3,569 10,127 2,059 0 15,785 25,912 11 Above Normal 1997 3,376 1,474 20 86 3,500 2,250 1,427 200 12,333 6,576 3,582 10,159 2,174 0 17,959 28,118 12 Extremely Wet 1998 3,376 1,474 20 86 3,500 2,250 2,107 200 13,013 6,594 3,596 10,190 2,823 0 20,782 30,972 13 Normal 1999 3,376 1,474 20 86 3,500 2,250 1,520 200 12,426 6,612 3,609 10,222 2,204 0 22,987 33,208 14 Above Normal 2000 3,376 1,474 20 86 3,500 2,250 1,223 200 12,129 6,630 3,623 10,253 1,876 0 24,863 35,116 15 Normal 2001 3,376 1,474 20 86 3,500 2,250 1,053 200 11,959 6,648 3,636 10,285 1,675 0 26,537 36,822 16 Below Normal 2002 3,376 1,474 20 86 3,500 2,250 761 200 11,667 6,666 3,650 10,316 1,351 0 27,888 38,204 17 Normal 2003 3,376 1,474 20 86 3,500 2,250 1,773 200 12,679 6,684 3,663 10,347 2,332 0 30,220 40,568 18 Below Normal 2004 3,376 1,474 20 86 3,500 2,250 693 200 11,599 6,702 3,676 10,379 1,220 0 31,440 41,819 19 Wet 2005 3,376 1,474 20 86 3,500 2,250 1,929 200 12,835 6,720 3,690 10,410 2,425 0 33,865 44,276 20 Wet 2006 3,376 1,474 20 86 3,500 2,250 1,773 200 12,679 6,738 3,703 10,442 2,237 0 36,103 46,544 21 Critically Dry 2007 3,376 1,474 20 86 3,500 2,105 193 200 10,954 6,756 3,717 10,473 481 0 36,584 47,057 22 Normal 2008 3,376 1,474 20 86 3,500 2,250 845 200 11,751 6,774 3,730 10,505 1,247 0 37,830 48,335 23 Normal 2009 3,376 1,474 20 86 3,500 2,250 677 200 11,583 6,792 3,744 10,536 1,047 0 38,877 49,413 24 Above Normal 2010 3,376 1,474 20 86 3,500 2,250 1,865 200 12,771 6,810 3,757 10,568 2,204 0 41,081 51,648 25 Above Normal 2011 3,376 1,474 20 86 3,500 2,250 1,860 200 12,766 6,828 3,771 10,599 2,167 0 43,248 53,847 26 Dry 2012 3,376 1,474 20 86 3,500 2,105 201 200 10,962 6,846 3,784 10,630 332 0 43,580 54,210 27 Dry 2013 3,376 1,474 20 86 3,500 2,105 635 160 11,356 6,864 3,797 10,662 694 0 44,274 54,936 28 Critically Dry 2014 3,376 1,474 20 86 3,500 2,105 0 160 10,721 6,882 3,811 10,693 28 0 44,302 54,995 29 Dry 2015 3,376 1,474 20 86 3,500 2,105 253 160 10,974 6,900 3,824 10,725 249 0 44,551 55,276 30 Normal 2016 3,376 1,474 20 86 3,500 2,250 1,053 160 11,919 6,918 3,838 10,756 1,163 0 45,714 56,471 Water Supplies not Affected by Drought Water Supplies Affected by Drought Water Demand Monterey Peninsula Water Supply Assessment
For 59 Years Following Pure Water Monterey Expansion
Scenario 2
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1866, Packet Page 2194 31 Extremely Wet 2017 3,376 1,474 20 86 3,500 2,250 1,960 200 12,866 6,936 3,851 10,788 2,079 0 47,793 58,581 32 Below Normal 2018 3,376 1,474 20 86 3,500 2,250 265 200 11,171 6,954 3,865 10,819 352 0 48,145 58,964 33 Extremely Wet 2019 3,376 1,474 20 86 3,500 2,250 1,747 200 12,653 6,972 3,878 10,851 1,803 0 49,948 60,798 34 Normal 2020 3,376 1,474 20 86 3,500 2,250 1,640 200 12,546 6,990 3,892 10,882 1,664 0 51,612 62,494 35 Dry 2021 3,376 1,474 20 86 3,500 2,105 80 200 10,841 7,008 3,905 10,913 0 72 51,540 62,45336 Above Normal 1963 3,376 1,474 20 86 3,500 2,250 1,587 200 12,493 7,026 3,918 10,945 1,548 0 53,088 64,033 37 Dry 1964 3,376 1,474 20 86 3,500 2,105 347 200 11,108 7,044 3,932 10,976 132 0 53,220 64,196 38 Normal 1965 3,376 1,474 20 86 3,500 2,250 1,227 200 12,133 7,062 3,945 11,008 1,125 0 54,346 65,353 39 Dry 1966 3,376 1,474 20 86 3,500 2,105 787 200 11,548 7,080 3,959 11,039 509 0 54,855 65,894 40 Wet 1967 3,376 1,474 20 86 3,500 2,250 1,907 200 12,813 7,098 3,972 11,071 1,743 0 56,597 67,668 41 Critically Dry 1968 3,376 1,474 20 86 3,500 2,105 120 200 10,881 7,116 3,986 11,102 0 221 56,376 67,478 42 Extremely Wet 1969 3,376 1,474 20 86 3,500 2,250 1,600 200 12,506 7,134 3,999 11,133 1,373 0 57,749 68,883 43 Normal 1970 3,376 1,474 20 86 3,500 2,250 1,127 200 12,033 7,152 4,012 11,165 868 0 58,617 69,782 44 Below Normal 1971 3,376 1,474 20 86 3,500 2,250 987 200 11,893 7,170 4,026 11,196 697 0 59,314 70,511 45 Critically Dry 1972 3,376 1,474 20 86 3,500 2,105 147 200 10,908 7,188 4,039 11,228 0 320 58,995 70,222 46 Wet 1973 3,376 1,474 20 86 3,500 2,250 1,667 200 12,573 7,206 4,053 11,259 1,314 0 60,309 71,568 47 Above Normal 1974 3,376 1,474 20 86 3,500 2,250 1,987 200 12,893 7,224 4,066 11,291 1,603 0 61,911 73,202 48 Above Normal 1975 3,376 1,474 20 86 3,500 2,250 1,440 200 12,346 7,242 4,080 11,322 1,024 0 62,935 74,257 49 Critically Dry 1976 3,376 1,474 20 86 3,500 2,105 0 200 10,761 7,260 4,093 11,354 0 592 62,343 73,69650 Critically Dry 1977 3,376 1,474 20 86 3,500 2,105 0 160 10,721 7,278 4,107 11,385 0 664 61,679 73,06451 Extremely Wet 1978 3,376 1,474 20 86 3,500 2,250 1,947 160 12,813 7,296 4,120 11,416 1,397 0 63,076 74,49252 Normal 1979 3,376 1,474 20 86 3,500 2,250 1,467 200 12,373 7,314 4,133 11,448 925 0 64,001 75,44953 Extremely Wet 1980 3,376 1,474 20 86 3,500 2,250 1,840 200 12,746 7,332 4,147 11,479 1,267 0 65,268 76,747 54 Below Normal 1981 3,376 1,474 20 86 3,500 2,250 1,041 200 11,947 7,350 4,160 11,511 436 0 65,507 77,215 55 Extremely Wet 1982 3,376 1,474 20 86 3,500 2,250 2,187 200 13,093 7,368 4,174 11,542 1,551 0 65,507 78,600 56 Extremely Wet 1983 3,376 1,474 20 86 3,500 2,250 2,419 200 13,325 7,386 4,187 11,574 1,752 0 65,507 78,832 57 Normal 1984 3,376 1,474 20 86 3,500 2,250 1,587 200 12,493 7,404 4,201 11,605 888 0 65,507 78,000 58 Dry 1985 3,376 1,474 20 86 3,500 2,105 507 200 11,268 7,422 4,214 11,637 0 368 65,139 76,775 59 Wet 1986 3,376 1,474 20 86 3,500 2,250 1,267 200 12,173 7,440 4,228 11,668 505 0 65,507 77,312 Notes: Seaside Basin Wheeled is comprised of 7.17 AF to Montage and 13 AF to Seaside Ascent project Malpaso is assumed to be 86 AFY production; less losses yields 80 AFY available to meet customer demandASR Uses actual 59-year record produced by Cal-Am witness in Phase 2 testimony to CPUC, starting in 1987 drought yearSand City Desal assumes 200 AFY with new intake well online; During 2nd year of drought and remaining drought year 20% reductionBase Year Water Demand is 9,813 AF, the 2023 10-year average; Assume to be split 65% Residential, 35% Non-ResidentialResidential Demand yearly increase: 18 AFY based on 2022 AMBAG Regional Growth Forecast (population) Non-Residential yearly increase: 13.44 AFY based on 2022 AMBAG Regional Growth Forecast (jobs) Initial storage includes ASR balance, excludes PWM Operating Reserve ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1867, Packet Page 2195 0 60,00050,00040,00030,00020,00010,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Acre-Feet
Year Following PWM Expansion
Supply and Storage Available v. Demand
30 Years Following PWM Expansion
Scenario 2
Supply Available in YearDemandAvailable in Year Plus PriorYear Storage ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1868, Packet Page 2196 Available
Pure Pure Aquifer Non- in Year
Water Derived Seaside Water Water Storage & Sand Total Residential Residential Total Stored Plus Forecast Year From Carmel Seaside Basin Monterey Monterey Recovery City Water Water Water Water Water Prior Year Year Class Year River Basin Wheeled Malpaso Base Expansion (ASR) Desal Available Demand Demand Demand Surplus Deficit EOY Storage Base/Avg n/a 3,376 1,474 20 86 3,500 2,139 1,055 193 11,842 6,378 3,435 9,813 2,159 1 Dry 1987 3,376 1,474 20 86 3,500 1,905 0 200 10,561 6,396 3,448 9,844 717 0 2,876 12,720 2 Critically Dry 1988 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,414 3,461 9,876 645 0 3,521 13,3973 Critically Dry 1989 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,432 3,475 9,907 614 0 4,135 14,0424 Critically Dry 1990 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,450 3,488 9,939 582 0 4,717 14,6565 Dry 1991 3,376 1,474 20 86 3,500 1,905 307 160 10,828 6,468 3,502 9,970 858 0 5,575 15,5466 Normal 1992 3,376 1,474 20 86 3,500 2,250 373 160 11,239 6,486 3,515 10,002 1,238 0 6,813 16,8157 Wet 1993 3,376 1,474 20 86 3,500 2,250 1,413 200 12,319 6,504 3,529 10,033 2,286 0 9,099 19,1328 Critically Dry 1994 3,376 1,474 20 86 3,500 1,905 187 200 10,748 6,522 3,542 10,065 684 0 9,783 19,847 9 Extremely Wet 1995 3,376 1,474 20 86 3,500 2,250 1,933 200 12,839 6,540 3,556 10,096 2,743 0 12,526 22,622 10 Above Normal 1996 3,376 1,474 20 86 3,500 2,250 1,280 200 12,186 6,558 3,569 10,127 2,059 0 14,585 24,712 11 Above Normal 1997 3,376 1,474 20 86 3,500 2,250 1,427 200 12,333 6,576 3,582 10,159 2,174 0 16,759 26,918 12 Extremely Wet 1998 3,376 1,474 20 86 3,500 2,250 2,107 200 13,013 6,594 3,596 10,190 2,823 0 19,582 29,772 13 Normal 1999 3,376 1,474 20 86 3,500 2,250 1,520 200 12,426 6,612 3,609 10,222 2,204 0 21,787 32,008 14 Above Normal 2000 3,376 1,474 20 86 3,500 2,250 1,223 200 12,129 6,630 3,623 10,253 1,876 0 23,663 33,916 15 Normal 2001 3,376 1,474 20 86 3,500 2,250 1,053 200 11,959 6,648 3,636 10,285 1,675 0 25,337 35,622 16 Below Normal 2002 3,376 1,474 20 86 3,500 2,250 761 200 11,667 6,666 3,650 10,316 1,351 0 26,688 37,004 17 Normal 2003 3,376 1,474 20 86 3,500 2,250 1,773 200 12,679 6,684 3,663 10,347 2,332 0 29,020 39,368 18 Below Normal 2004 3,376 1,474 20 86 3,500 2,250 693 200 11,599 6,702 3,676 10,379 1,220 0 30,240 40,619 19 Wet 2005 3,376 1,474 20 86 3,500 2,250 1,929 200 12,835 6,720 3,690 10,410 2,425 0 32,665 43,076 20 Wet 2006 3,376 1,474 20 86 3,500 2,250 1,773 200 12,679 6,738 3,703 10,442 2,237 0 34,903 45,344 21 Critically Dry 2007 3,376 1,474 20 86 3,500 1,905 193 200 10,754 6,756 3,717 10,473 281 0 35,184 45,657 22 Normal 2008 3,376 1,474 20 86 3,500 2,250 845 200 11,751 6,774 3,730 10,505 1,247 0 36,430 46,935 23 Normal 2009 3,376 1,474 20 86 3,500 2,250 677 200 11,583 6,792 3,744 10,536 1,047 0 37,477 48,013 24 Above Normal 2010 3,376 1,474 20 86 3,500 2,250 1,865 200 12,771 6,810 3,757 10,568 2,204 0 39,681 50,248 25 Above Normal 2011 3,376 1,474 20 86 3,500 2,250 1,860 200 12,766 6,828 3,771 10,599 2,167 0 41,848 52,447 26 Dry 2012 3,376 1,474 20 86 3,500 1,905 201 200 10,762 6,846 3,784 10,630 132 0 41,980 52,610 27 Dry 2013 3,376 1,474 20 86 3,500 1,905 635 160 11,156 6,864 3,797 10,662 494 0 42,474 53,136 28 Critically Dry 2014 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,882 3,811 10,693 0 172 42,302 52,995 29 Dry 2015 3,376 1,474 20 86 3,500 1,905 253 160 10,774 6,900 3,824 10,725 49 0 42,351 53,076 30 Normal 2016 3,376 1,474 20 86 3,500 2,250 1,053 160 11,919 6,918 3,838 10,756 1,163 0 43,514 54,271 Water Supplies not Affected by Drought Water Supplies Affected by Drought Water Demand Monterey Peninsula Water Supply Assessment
For 59 Years Following Pure Water Monterey Expansion
Scenario 3
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1869, Packet Page 2197 31 Extremely Wet 2017 3,376 1,474 20 86 3,500 2,250 1,960 200 12,866 6,936 3,851 10,788 2,079 0 45,593 56,381 32 Below Normal 2018 3,376 1,474 20 86 3,500 2,250 265 200 11,171 6,954 3,865 10,819 352 0 45,945 56,764 33 Extremely Wet 2019 3,376 1,474 20 86 3,500 2,250 1,747 200 12,653 6,972 3,878 10,851 1,803 0 47,748 58,598 34 Normal 2020 3,376 1,474 20 86 3,500 2,250 1,640 200 12,546 6,990 3,892 10,882 1,664 0 49,412 60,294 35 Dry 2021 3,376 1,474 20 86 3,500 1,905 80 200 10,641 7,008 3,905 10,913 0 272 49,140 60,05336 Above Normal 1963 3,376 1,474 20 86 3,500 2,250 1,587 200 12,493 7,026 3,918 10,945 1,548 0 50,688 61,633 37 Dry 1964 3,376 1,474 20 86 3,500 1,905 347 200 10,908 7,044 3,932 10,976 0 68 50,620 61,596 38 Normal 1965 3,376 1,474 20 86 3,500 2,250 1,227 200 12,133 7,062 3,945 11,008 1,125 0 51,746 62,753 39 Dry 1966 3,376 1,474 20 86 3,500 1,905 787 200 11,348 7,080 3,959 11,039 309 0 52,055 63,094 40 Wet 1967 3,376 1,474 20 86 3,500 2,250 1,907 200 12,813 7,098 3,972 11,071 1,743 0 53,797 64,868 41 Critically Dry 1968 3,376 1,474 20 86 3,500 1,905 120 200 10,681 7,116 3,986 11,102 0 421 53,376 64,478 42 Extremely Wet 1969 3,376 1,474 20 86 3,500 2,250 1,600 200 12,506 7,134 3,999 11,133 1,373 0 54,749 65,883 43 Normal 1970 3,376 1,474 20 86 3,500 2,250 1,127 200 12,033 7,152 4,012 11,165 868 0 55,617 66,782 44 Below Normal 1971 3,376 1,474 20 86 3,500 2,250 987 200 11,893 7,170 4,026 11,196 697 0 56,314 67,511 45 Critically Dry 1972 3,376 1,474 20 86 3,500 1,905 147 200 10,708 7,188 4,039 11,228 0 520 55,795 67,022 46 Wet 1973 3,376 1,474 20 86 3,500 2,250 1,667 200 12,573 7,206 4,053 11,259 1,314 0 57,109 68,368 47 Above Normal 1974 3,376 1,474 20 86 3,500 2,250 1,987 200 12,893 7,224 4,066 11,291 1,603 0 58,711 70,002 48 Above Normal 1975 3,376 1,474 20 86 3,500 2,250 1,440 200 12,346 7,242 4,080 11,322 1,024 0 59,735 71,057 49 Critically Dry 1976 3,376 1,474 20 86 3,500 1,905 0 200 10,561 7,260 4,093 11,354 0 792 58,943 70,29650 Critically Dry 1977 3,376 1,474 20 86 3,500 1,905 0 160 10,521 7,278 4,107 11,385 0 864 58,079 69,46451 Extremely Wet 1978 3,376 1,474 20 86 3,500 2,250 1,947 160 12,813 7,296 4,120 11,416 1,397 0 59,476 70,89252 Normal 1979 3,376 1,474 20 86 3,500 2,250 1,467 200 12,373 7,314 4,133 11,448 925 0 60,401 71,84953 Extremely Wet 1980 3,376 1,474 20 86 3,500 2,250 1,840 200 12,746 7,332 4,147 11,479 1,267 0 61,668 73,147 54 Below Normal 1981 3,376 1,474 20 86 3,500 2,250 1,041 200 11,947 7,350 4,160 11,511 436 0 62,104 73,615 55 Extremely Wet 1982 3,376 1,474 20 86 3,500 2,250 2,187 200 13,093 7,368 4,174 11,542 1,551 0 63,655 75,198 56 Extremely Wet 1983 3,376 1,474 20 86 3,500 2,250 2,419 200 13,325 7,386 4,187 11,574 1,752 0 65,407 76,981 57 Normal 1984 3,376 1,474 20 86 3,500 2,250 1,587 200 12,493 7,404 4,201 11,605 888 0 65,507 77,900 58 Dry 1985 3,376 1,474 20 86 3,500 1,905 507 200 11,068 7,422 4,214 11,637 0 568 64,939 76,575 59 Wet 1986 3,376 1,474 20 86 3,500 2,250 1,267 200 12,173 7,440 4,228 11,668 505 0 65,444 77,112 Notes: Seaside Basin Wheeled is comprised of 7.17 AF to Montage and 13 AF to Seaside Ascent project Malpaso is assumed to be 86 AFY production; less losses yields 80 AFY available to meet customer demandASR Uses actual 59-year record produced by Cal-Am witness in Phase 2 testimony to CPUC, starting in 1987 drought yearSand City Desal assumes 200 AFY with new intake well online; During 2nd year of drought and remaining drought year 20% reductionBase Year Water Demand is 9,813 AF, the 2023 10-year average; Assume to be split 65% Residential, 35% Non-ResidentialResidential Demand yearly increase: 18 AFY based on 2022 AMBAG Regional Growth Forecast (population) Non-Residential yearly increase: 13.44 AFY based on 2022 AMBAG Regional Growth Forecast (jobs) Initial storage includes ASR balance, excludes PWM Operating Reserve ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1870, Packet Page 2198 0 60,00050,00040,00030,00020,00010,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Acre-Feet
Year Following PWM Expansion
Supply and Storage Available v. Demand
30 Years Following PWM Expansion
Scenario 3
Supply Available in YearDemandAvailable in Year Plus PriorYear Storage ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1871, Packet Page 2199 Available
Pure Pure Aquifer Non- in Year
Water Derived Seaside Water Water Storage & Sand Total Residential Residential Total Stored Plus Forecast Year From Carmel Seaside Basin Monterey Monterey Recovery City Water Water Water Water Water Prior Year Year Class Year River Basin Wheeled Malpaso Base Expansion (ASR) Desal Available Demand Demand Demand Surplus Deficit EOY Storage Base/Avg n/a 3,376 1,474 20 86 3,500 2,139 1,055 193 11,842 6,378 3,435 9,813 2,159 1 Dry 1987 3,376 1,474 20 86 3,500 1,905 0 200 10,561 6,414 3,462 9,876 685 0 2,844 12,720 2 Critically Dry 1988 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,450 3,489 9,939 582 0 3,426 13,3653 Critically Dry 1989 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,486 3,516 10,002 519 0 3,946 13,9484 Critically Dry 1990 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,522 3,543 10,065 456 0 4,402 14,4675 Dry 1991 3,376 1,474 20 86 3,500 1,905 307 160 10,828 6,558 3,570 10,128 700 0 5,102 15,2306 Normal 1992 3,376 1,474 20 86 3,500 2,250 373 160 11,239 6,594 3,597 10,191 1,048 0 6,150 16,3417 Wet 1993 3,376 1,474 20 86 3,500 2,250 1,413 200 12,319 6,630 3,624 10,254 2,065 0 8,215 18,4698 Critically Dry 1994 3,376 1,474 20 86 3,500 1,905 187 200 10,748 6,666 3,651 10,317 431 0 8,647 18,964 9 Extremely Wet 1995 3,376 1,474 20 86 3,500 2,250 1,933 200 12,839 6,702 3,678 10,380 2,459 0 11,106 21,486 10 Above Normal 1996 3,376 1,474 20 86 3,500 2,250 1,280 200 12,186 6,738 3,705 10,443 1,743 0 12,849 23,292 11 Above Normal 1997 3,376 1,474 20 86 3,500 2,250 1,427 200 12,333 6,774 3,732 10,506 1,827 0 14,676 25,182 12 Extremely Wet 1998 3,376 1,474 20 86 3,500 2,250 2,107 200 13,013 6,810 3,759 10,569 2,444 0 17,120 27,689 13 Normal 1999 3,376 1,474 20 86 3,500 2,250 1,520 200 12,426 6,846 3,786 10,632 1,794 0 18,915 29,547 14 Above Normal 2000 3,376 1,474 20 86 3,500 2,250 1,223 200 12,129 6,882 3,813 10,695 1,434 0 20,349 31,044 15 Normal 2001 3,376 1,474 20 86 3,500 2,250 1,053 200 11,959 6,918 3,840 10,758 1,201 0 21,550 32,308 16 Below Normal 2002 3,376 1,474 20 86 3,500 2,250 761 200 11,667 6,954 3,867 10,821 846 0 22,396 33,217 17 Normal 2003 3,376 1,474 20 86 3,500 2,250 1,773 200 12,679 6,990 3,894 10,884 1,795 0 24,191 35,075 18 Below Normal 2004 3,376 1,474 20 86 3,500 2,250 693 200 11,599 7,026 3,921 10,947 652 0 24,844 35,791 19 Wet 2005 3,376 1,474 20 86 3,500 2,250 1,929 200 12,835 7,062 3,948 11,010 1,825 0 26,669 37,679 20 Wet 2006 3,376 1,474 20 86 3,500 2,250 1,773 200 12,679 7,098 3,975 11,073 1,606 0 28,275 39,348 21 Critically Dry 2007 3,376 1,474 20 86 3,500 1,905 193 200 10,754 7,134 4,002 11,136 0 382 27,893 39,02922 Normal 2008 3,376 1,474 20 86 3,500 2,250 845 200 11,751 7,170 4,029 11,199 552 0 28,445 39,644 23 Normal 2009 3,376 1,474 20 86 3,500 2,250 677 200 11,583 7,206 4,056 11,262 321 0 28,767 40,029 24 Above Normal 2010 3,376 1,474 20 86 3,500 2,250 1,865 200 12,771 7,242 4,083 11,325 1,446 0 30,213 41,538 25 Above Normal 2011 3,376 1,474 20 86 3,500 2,250 1,860 200 12,766 7,278 4,110 11,388 1,378 0 31,591 42,979 26 Dry 2012 3,376 1,474 20 86 3,500 1,905 201 200 10,762 7,314 4,137 11,451 0 689 30,902 42,35327 Dry 2013 3,376 1,474 20 86 3,500 1,905 635 160 11,156 7,350 4,164 11,514 0 358 30,544 42,05828 Critically Dry 2014 3,376 1,474 20 86 3,500 1,905 0 160 10,521 7,386 4,191 11,577 0 1,056 29,489 41,066 29 Dry 2015 3,376 1,474 20 86 3,500 1,905 253 160 10,774 7,422 4,218 11,640 0 866 28,623 40,263 30 Normal 2016 3,376 1,474 20 86 3,500 2,250 1,053 160 11,919 7,458 4,245 11,703 216 0 28,839 40,542 Water Supplies not Affected by Drought Water Supplies Affected by Drought Water Demand Monterey Peninsula Water Supply Assessment
For 59 Years Following Pure Water Monterey Expansion
Scenario 4
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1872, Packet Page 2200 31 Extremely Wet 2017 3,376 1,474 20 86 3,500 2,250 1,960 200 12,866 7,494 4,272 11,766 1,100 0 29,939 41,705 32 Below Normal 2018 3,376 1,474 20 86 3,500 2,250 265 200 11,171 7,530 4,299 11,829 0 658 29,281 41,110 33 Extremely Wet 2019 3,376 1,474 20 86 3,500 2,250 1,747 200 12,653 7,566 4,326 11,892 761 0 30,043 41,935 34 Normal 2020 3,376 1,474 20 86 3,500 2,250 1,640 200 12,546 7,602 4,353 11,955 591 0 30,634 42,589 35 Dry 2021 3,376 1,474 20 86 3,500 1,905 80 200 10,641 7,638 4,380 12,018 0 1,377 29,257 41,27536 Above Normal 1963 3,376 1,474 20 86 3,500 2,250 1,587 200 12,493 7,674 4,407 12,081 412 0 29,669 41,750 37 Dry 1964 3,376 1,474 20 86 3,500 1,905 347 200 10,908 7,710 4,434 12,144 0 1,236 28,433 40,577 38 Normal 1965 3,376 1,474 20 86 3,500 2,250 1,227 200 12,133 7,746 4,461 12,207 0 74 28,360 40,567 39 Dry 1966 3,376 1,474 20 86 3,500 1,905 787 200 11,348 7,782 4,488 12,270 0 922 27,438 39,708 40 Wet 1967 3,376 1,474 20 86 3,500 2,250 1,907 200 12,813 7,818 4,515 12,333 480 0 27,918 40,251 41 Critically Dry 1968 3,376 1,474 20 86 3,500 1,905 120 200 10,681 7,854 4,542 12,396 0 1,715 26,203 38,599 42 Extremely Wet 1969 3,376 1,474 20 86 3,500 2,250 1,600 200 12,506 7,890 4,569 12,459 47 0 26,250 38,709 43 Normal 1970 3,376 1,474 20 86 3,500 2,250 1,127 200 12,033 7,926 4,596 12,522 0 489 25,762 38,284 44 Below Normal 1971 3,376 1,474 20 86 3,500 2,250 987 200 11,893 7,962 4,623 12,585 0 692 25,070 37,655 45 Critically Dry 1972 3,376 1,474 20 86 3,500 1,905 147 200 10,708 7,998 4,650 12,648 0 1,940 23,130 35,778 46 Wet 1973 3,376 1,474 20 86 3,500 2,250 1,667 200 12,573 8,034 4,677 12,711 0 138 22,992 35,703 47 Above Normal 1974 3,376 1,474 20 86 3,500 2,250 1,987 200 12,893 8,070 4,704 12,774 119 0 23,111 35,885 48 Above Normal 1975 3,376 1,474 20 86 3,500 2,250 1,440 200 12,346 8,106 4,731 12,837 0 491 22,621 35,458 49 Critically Dry 1976 3,376 1,474 20 86 3,500 1,905 0 200 10,561 8,142 4,758 12,900 0 2,339 20,282 33,18250 Critically Dry 1977 3,376 1,474 20 86 3,500 1,905 0 160 10,521 8,178 4,785 12,963 0 2,442 17,840 30,80351 Extremely Wet 1978 3,376 1,474 20 86 3,500 2,250 1,947 160 12,813 8,214 4,812 13,026 0 213 17,627 30,65352 Normal 1979 3,376 1,474 20 86 3,500 2,250 1,467 200 12,373 8,250 4,839 13,089 0 716 16,911 30,00053 Extremely Wet 1980 3,376 1,474 20 86 3,500 2,250 1,840 200 12,746 8,286 4,866 13,152 0 406 16,506 29,658 54 Below Normal 1981 3,376 1,474 20 86 3,500 2,250 1,041 200 11,947 8,322 4,893 13,215 0 1,268 15,238 28,453 55 Extremely Wet 1982 3,376 1,474 20 86 3,500 2,250 2,187 200 13,093 8,358 4,920 13,278 0 185 15,053 28,331 56 Extremely Wet 1983 3,376 1,474 20 86 3,500 2,250 2,419 200 13,325 8,394 4,947 13,341 0 16 15,037 28,378 57 Normal 1984 3,376 1,474 20 86 3,500 2,250 1,587 200 12,493 8,430 4,974 13,404 0 911 14,126 27,530 58 Dry 1985 3,376 1,474 20 86 3,500 1,905 507 200 11,068 8,466 5,001 13,467 0 2,399 11,728 25,195 59 Wet 1986 3,376 1,474 20 86 3,500 2,250 1,267 200 12,173 8,502 5,028 13,530 0 1,357 10,371 23,901 Notes: Seaside Basin Wheeled is comprised of 7.17 AF to Montage and 13 AF to Seaside Ascent project Malpaso is assumed to be 86 AFY production; less losses yields 80 AFY available to meet customer demandASR Uses actual 59-year record produced by Cal-Am witness in Phase 2 testimony to CPUC, starting in 1987 drought yearSand City Desal assumes 200 AFY with new intake well online; During 2nd year of drought and remaining drought year 20% reductionBase Year Water Demand is 9,813 AF, the 2023 10-year average; Assume to be split 65% Residential, 35% Non-ResidentialResidential Demand yearly increase: 36 AFY based on 2x 2022 AMBAG Regional Growth Forecast (population) Non-Residential yearly increase: 27 AFY based on 2x 2022 AMBAG Regional Growth Forecast (jobs) Initial storage includes ASR balance, excludes PWM Operating Reserve ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1873, Packet Page 2201 0 60,00050,00040,00030,00020,00010,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Acre-Feet
Year Following PWM Expansion
Supply and Storage Available v. Demand
30 Years Following PWM Expansion
Scenario 4
Supply Available in YearDemandAvailable in Year Plus PriorYear Storage ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1874, Packet Page 2202 Available
Pure Pure Aquifer Non- in Year
Water Derived Seaside Water Water Storage & Sand Total Residential Residential Total Stored Plus Forecast Year From Carmel Seaside Basin Monterey Monterey Recovery City Water Water Water Water Water Prior Year Year Class Year River Basin Wheeled Malpaso Base Expansion (ASR) Desal Available Demand Demand Demand Surplus Deficit EOY Storage Base/Avg n/a 3,376 1,177 20 86 3,500 2,139 1,055 193 11,546 6,378 3,435 9,813 2,159 1 Dry 1987 3,376 1,474 20 86 3,500 1,905 0 200 10,561 6,414 3,462 9,876 685 0 2,844 12,720 2 Critically Dry 1988 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,450 3,489 9,939 582 0 3,426 13,3653 Critically Dry 1989 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,486 3,516 10,002 519 0 3,946 13,9484 Critically Dry 1990 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,522 3,543 10,065 456 0 4,402 14,4675 Dry 1991 3,376 1,474 20 86 3,500 1,905 307 160 10,828 6,558 3,570 10,128 700 0 5,102 15,2306 Normal 1992 3,376 774 20 86 3,500 2,250 373 160 10,539 6,594 3,597 10,191 348 0 5,450 15,641 7 Wet 1993 3,376 774 20 86 3,500 2,250 1,413 200 11,619 6,630 3,624 10,254 1,365 0 6,815 17,0698 Critically Dry 1994 3,376 774 20 86 3,500 1,905 187 200 10,048 6,666 3,651 10,317 0 269 6,547 16,8649 Extremely Wet 1995 3,376 774 20 86 3,500 2,250 1,933 200 12,139 6,702 3,678 10,380 1,759 0 8,306 18,686 10 Above Normal 1996 3,376 774 20 86 3,500 2,250 1,280 200 11,486 6,738 3,705 10,443 1,043 0 9,349 19,792 11 Above Normal 1997 3,376 774 20 86 3,500 2,250 1,427 200 11,633 6,774 3,732 10,506 1,127 0 10,476 20,982 12 Extremely Wet 1998 3,376 774 20 86 3,500 2,250 2,107 200 12,313 6,810 3,759 10,569 1,744 0 12,220 22,789 13 Normal 1999 3,376 774 20 86 3,500 2,250 1,520 200 11,726 6,846 3,786 10,632 1,094 0 13,315 23,947 14 Above Normal 2000 3,376 774 20 86 3,500 2,250 1,223 200 11,429 6,882 3,813 10,695 734 0 14,049 24,744 15 Normal 2001 3,376 774 20 86 3,500 2,250 1,053 200 11,259 6,918 3,840 10,758 501 0 14,550 25,308 16 Below Normal 2002 3,376 774 20 86 3,500 2,250 761 200 10,967 6,954 3,867 10,821 146 0 14,696 25,517 17 Normal 2003 3,376 774 20 86 3,500 2,250 1,773 200 11,979 6,990 3,894 10,884 1,095 0 15,791 26,675 18 Below Normal 2004 3,376 774 20 86 3,500 2,250 693 200 10,899 7,026 3,921 10,947 0 48 15,744 26,69119 Wet 2005 3,376 774 20 86 3,500 2,250 1,929 200 12,135 7,062 3,948 11,010 1,125 0 16,869 27,879 20 Wet 2006 3,376 774 20 86 3,500 2,250 1,773 200 11,979 7,098 3,975 11,073 906 0 17,775 28,848 21 Critically Dry 2007 3,376 774 20 86 3,500 1,905 193 200 10,054 7,134 4,002 11,136 0 1,082 16,693 27,82922 Normal 2008 3,376 774 20 86 3,500 2,250 845 200 11,051 7,170 4,029 11,199 0 148 16,545 27,74423 Normal 2009 3,376 774 20 86 3,500 2,250 677 200 10,883 7,206 4,056 11,262 0 379 16,167 27,42924 Above Normal 2010 3,376 774 20 86 3,500 2,250 1,865 200 12,071 7,242 4,083 11,325 746 0 16,913 28,238 25 Above Normal 2011 3,376 774 20 86 3,500 2,250 1,860 200 12,066 7,278 4,110 11,388 678 0 17,591 28,979 26 Dry 2012 3,376 774 20 86 3,500 1,905 201 200 10,062 7,314 4,137 11,451 0 1,389 16,202 27,653 27 Dry 2013 3,376 774 20 86 3,500 1,905 635 160 10,456 7,350 4,164 11,514 0 1,058 15,144 26,658 28 Critically Dry 2014 3,376 774 20 86 3,500 1,905 0 160 9,821 7,386 4,191 11,577 0 1,756 13,389 24,966 29 Dry 2015 3,376 774 20 86 3,500 1,905 253 160 10,074 7,422 4,218 11,640 0 1,566 11,823 23,46330 Normal 2016 3,376 774 20 86 3,500 2,250 1,053 160 11,219 7,458 4,245 11,703 0 484 11,339 23,042 Water Supplies not Affected by Drought Water Supplies Affected by Drought Water Demand Monterey Peninsula Water Supply Assessment
For 59 Years Following Pure Water Monterey Expansion
Scenario 5
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1875, Packet Page 2203 31 Extremely Wet 2017 3,376 1,474 20 86 3,500 2,250 1,960 200 12,866 7,494 4,272 11,766 1,100 0 12,439 24,205 32 Below Normal 2018 3,376 1,474 20 86 3,500 2,250 265 200 11,171 7,530 4,299 11,829 0 658 11,781 23,610 33 Extremely Wet 2019 3,376 1,474 20 86 3,500 2,250 1,747 200 12,653 7,566 4,326 11,892 761 0 12,543 24,435 34 Normal 2020 3,376 1,474 20 86 3,500 2,250 1,640 200 12,546 7,602 4,353 11,955 591 0 13,134 25,089 35 Dry 2021 3,376 1,474 20 86 3,500 1,905 80 200 10,641 7,638 4,380 12,018 0 1,377 11,757 23,77536 Above Normal 1963 3,376 1,474 20 86 3,500 2,250 1,587 200 12,493 7,674 4,407 12,081 412 0 12,169 24,250 37 Dry 1964 3,376 1,474 20 86 3,500 1,905 347 200 10,908 7,710 4,434 12,144 0 1,236 10,933 23,077 38 Normal 1965 3,376 1,474 20 86 3,500 2,250 1,227 200 12,133 7,746 4,461 12,207 0 74 10,860 23,067 39 Dry 1966 3,376 1,474 20 86 3,500 1,905 787 200 11,348 7,782 4,488 12,270 0 922 9,938 22,208 40 Wet 1967 3,376 1,474 20 86 3,500 2,250 1,907 200 12,813 7,818 4,515 12,333 480 0 10,418 22,751 41 Critically Dry 1968 3,376 1,474 20 86 3,500 1,905 120 200 10,681 7,854 4,542 12,396 0 1,715 8,703 21,099 42 Extremely Wet 1969 3,376 1,474 20 86 3,500 2,250 1,600 200 12,506 7,890 4,569 12,459 47 0 8,750 21,209 43 Normal 1970 3,376 1,474 20 86 3,500 2,250 1,127 200 12,033 7,926 4,596 12,522 0 489 8,262 20,784 44 Below Normal 1971 3,376 1,474 20 86 3,500 2,250 987 200 11,893 7,962 4,623 12,585 0 692 7,570 20,155 45 Critically Dry 1972 3,376 1,474 20 86 3,500 1,905 147 200 10,708 7,998 4,650 12,648 0 1,940 5,630 18,278 46 Wet 1973 3,376 1,474 20 86 3,500 2,250 1,667 200 12,573 8,034 4,677 12,711 0 138 5,492 18,203 47 Above Normal 1974 3,376 1,474 20 86 3,500 2,250 1,987 200 12,893 8,070 4,704 12,774 119 0 5,611 18,385 48 Above Normal 1975 3,376 1,474 20 86 3,500 2,250 1,440 200 12,346 8,106 4,731 12,837 0 491 5,121 17,958 49 Critically Dry 1976 3,376 1,474 20 86 3,500 1,905 0 200 10,561 8,142 4,758 12,900 0 2,339 2,782 15,68250 Critically Dry 1977 3,376 1,474 20 86 3,500 1,905 0 160 10,521 8,178 4,785 12,963 0 2,442 340 13,30351 Extremely Wet 1978 3,376 1,474 20 86 3,500 2,250 1,947 160 12,813 8,214 4,812 13,026 0 213 127 13,15352 Normal 1979 3,376 1,474 20 86 3,500 2,250 1,467 200 12,373 8,250 4,839 13,089 0 716 (589) 12,50053 Extremely Wet 1980 3,376 1,474 20 86 3,500 2,250 1,840 200 12,746 8,286 4,866 13,152 0 406 (994) 12,15854 Below Normal 1981 3,376 1,474 20 86 3,500 2,250 1,041 200 11,947 8,322 4,893 13,215 0 1,268 (2,262) 10,953 55 Extremely Wet 1982 3,376 1,474 20 86 3,500 2,250 2,187 200 13,093 8,358 4,920 13,278 0 185 (2,447) 10,831 56 Extremely Wet 1983 3,376 1,474 20 86 3,500 2,250 2,419 200 13,325 8,394 4,947 13,341 0 16 (2,463) 10,878 57 Normal 1984 3,376 1,474 20 86 3,500 2,250 1,587 200 12,493 8,430 4,974 13,404 0 911 (3,374) 10,030 58 Dry 1985 3,376 1,474 20 86 3,500 1,905 507 200 11,068 8,466 5,001 13,467 0 2,399 (5,772) 7,695 59 Wet 1986 3,376 1,474 20 86 3,500 2,250 1,267 200 12,173 8,502 5,028 13,530 0 1,357 (7,129) 6,401 Notes: Seaside Basin Wheeled is comprised of 7.17 AF to Montage and 13 AF to Seaside Ascent project Malpaso is assumed to be 86 AFY production; less losses yields 80 AFY available to meet customer demandASR Uses actual 59-year record produced by Cal-Am witness in Phase 2 testimony to CPUC, starting in 1987 drought yearSand City Desal assumes 200 AFY with new intake well online; During 2nd year of drought and remaining drought year 20% reductionBase Year Water Demand is 9,813 AF, the 2023 10-year average; Assume to be split 65% Residential, 35% Non-ResidentialResidential Demand yearly increase: 36 AFY based on 2x 2022 AMBAG Regional Growth Forecast (population) Non-Residential yearly increase: 27 AFY based on 2x 2022 AMBAG Regional Growth Forecast (jobs) Initial storage includes ASR balance, excludes PWM Operating Reserve ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1876, Packet Page 2204 0 60,00050,00040,00030,00020,00010,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Acre-Feet
Year Following PWM Expansion
Supply and Storage Available v. Demand
30 Years Following PWM Expansion
Scenario 5
Supply Available in YearDemandAvailable in Year Plus PriorYear Storage ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1877, Packet Page 2205 Available
Pure Pure Aquifer Non- in Year
Water Derived Seaside Water Water Storage & Sand Total Residential Residential Total Stored Plus Forecast Year From Carmel Seaside Basin Monterey Monterey Recovery City Water Water Water Water Water Prior Year Year Class Year River Basin Wheeled Malpaso Base Expansion (ASR) Desal Available Demand Demand Demand Surplus Deficit EOY Storage Base/Avg n/a 3,376 1,177 20 86 3,500 2,139 791 190 11,279 6,378 3,435 9,813 2,159 1 Dry 1987 3,376 1,474 20 86 3,500 1,905 0 200 10,561 6,414 3,462 9,876 685 0 2,844 12,720 2 Critically Dry 1988 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,450 3,489 9,939 582 0 3,426 13,3653 Critically Dry 1989 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,486 3,516 10,002 519 0 3,946 13,9484 Critically Dry 1990 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,522 3,543 10,065 456 0 4,402 14,4675 Dry 1991 3,376 1,474 20 86 3,500 1,905 230 160 10,751 6,558 3,570 10,128 623 0 5,025 15,1536 Normal 1992 3,376 774 20 86 3,500 2,250 280 160 10,446 6,594 3,597 10,191 255 0 5,280 15,471 7 Wet 1993 3,376 774 20 86 3,500 2,250 1,060 200 11,266 6,630 3,624 10,254 1,012 0 6,292 16,5468 Critically Dry 1994 3,376 774 20 86 3,500 1,905 140 200 10,001 6,666 3,651 10,317 0 316 5,977 16,2949 Extremely Wet 1995 3,376 774 20 86 3,500 2,250 1,450 200 11,656 6,702 3,678 10,380 1,276 0 7,253 17,633 10 Above Normal 1996 3,376 774 20 86 3,500 2,250 960 200 11,166 6,738 3,705 10,443 723 0 7,976 18,419 11 Above Normal 1997 3,376 774 20 86 3,500 2,250 1,070 200 11,276 6,774 3,732 10,506 770 0 8,746 19,252 12 Extremely Wet 1998 3,376 774 20 86 3,500 2,250 1,580 200 11,786 6,810 3,759 10,569 1,217 0 9,964 20,533 13 Normal 1999 3,376 774 20 86 3,500 2,250 1,140 200 11,346 6,846 3,786 10,632 714 0 10,678 21,310 14 Above Normal 2000 3,376 774 20 86 3,500 2,250 917 200 11,123 6,882 3,813 10,695 428 0 11,106 21,801 15 Normal 2001 3,376 774 20 86 3,500 2,250 790 200 10,996 6,918 3,840 10,758 238 0 11,344 22,102 16 Below Normal 2002 3,376 774 20 86 3,500 2,250 571 200 10,777 6,954 3,867 10,821 0 44 11,300 22,12117 Normal 2003 3,376 774 20 86 3,500 2,250 1,330 200 11,536 6,990 3,894 10,884 652 0 11,952 22,836 18 Below Normal 2004 3,376 774 20 86 3,500 2,250 520 200 10,726 7,026 3,921 10,947 0 221 11,731 22,67819 Wet 2005 3,376 774 20 86 3,500 2,250 1,447 200 11,653 7,062 3,948 11,010 643 0 12,374 23,384 20 Wet 2006 3,376 774 20 86 3,500 2,250 1,330 200 11,536 7,098 3,975 11,073 463 0 12,837 23,910 21 Critically Dry 2007 3,376 774 20 86 3,500 1,905 145 200 10,006 7,134 4,002 11,136 0 1,130 11,707 22,84322 Normal 2008 3,376 774 20 86 3,500 2,250 634 200 10,840 7,170 4,029 11,199 0 359 11,348 22,54723 Normal 2009 3,376 774 20 86 3,500 2,250 508 200 10,714 7,206 4,056 11,262 0 548 10,800 22,06224 Above Normal 2010 3,376 774 20 86 3,500 2,250 1,399 200 11,605 7,242 4,083 11,325 280 0 11,080 22,405 25 Above Normal 2011 3,376 774 20 86 3,500 2,250 1,395 200 11,601 7,278 4,110 11,388 213 0 11,293 22,681 26 Dry 2012 3,376 774 20 86 3,500 1,905 151 200 10,012 7,314 4,137 11,451 0 1,439 9,854 21,305 27 Dry 2013 3,376 774 20 86 3,500 1,905 476 160 10,297 7,350 4,164 11,514 0 1,217 8,637 20,151 28 Critically Dry 2014 3,376 774 20 86 3,500 1,905 0 160 9,821 7,386 4,191 11,577 0 1,756 6,882 18,459 29 Dry 2015 3,376 774 20 86 3,500 1,905 190 160 10,011 7,422 4,218 11,640 0 1,629 5,253 16,89330 Normal 2016 3,376 774 20 86 3,500 2,250 790 160 10,956 7,458 4,245 11,703 0 747 4,506 16,209 Water Supplies not Affected by Drought Water Supplies Affected by Drought Water Demand Monterey Peninsula Water Supply Assessment
For 59 Years Following Pure Water Monterey Expansion
Scenario 6
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1878, Packet Page 2206 31 Extremely Wet 2017 3,376 1,474 20 86 3,500 2,250 1,470 160 12,336 7,494 4,272 11,766 570 0 5,076 16,842 32 Below Normal 2018 3,376 1,474 20 86 3,500 2,250 199 160 11,065 7,530 4,299 11,829 0 764 4,312 16,141 33 Extremely Wet 2019 3,376 1,474 20 86 3,500 2,250 1,310 160 12,176 7,566 4,326 11,892 284 0 4,596 16,488 34 Normal 2020 3,376 1,474 20 86 3,500 2,250 1,230 160 12,096 7,602 4,353 11,955 141 0 4,737 16,692 35 Dry 2021 3,376 1,474 20 86 3,500 1,905 60 200 10,621 7,638 4,380 12,018 0 1,397 3,341 15,35936 Above Normal 1963 3,376 1,474 20 86 3,500 2,250 1,190 200 12,096 7,674 4,407 12,081 15 0 3,356 15,437 37 Dry 1964 3,376 1,474 20 86 3,500 1,905 260 200 10,821 7,710 4,434 12,144 0 1,323 2,033 14,177 38 Normal 1965 3,376 1,474 20 86 3,500 2,250 920 200 11,826 7,746 4,461 12,207 0 381 1,653 13,860 39 Dry 1966 3,376 1,474 20 86 3,500 1,905 590 200 11,151 7,782 4,488 12,270 0 1,119 534 12,804 40 Wet 1967 3,376 1,474 20 86 3,500 2,250 1,430 200 12,336 7,818 4,515 12,333 3 0 538 12,871 41 Critically Dry 1968 3,376 1,474 20 86 3,500 1,905 90 200 10,651 7,854 4,542 12,396 0 1,745 (1,207) 11,189 42 Extremely Wet 1969 3,376 1,474 20 86 3,500 2,250 1,200 200 12,106 7,890 4,569 12,459 0 353 (1,560) 10,899 43 Normal 1970 3,376 1,474 20 86 3,500 2,250 845 200 11,751 7,926 4,596 12,522 0 771 (2,330) 10,192 44 Below Normal 1971 3,376 1,474 20 86 3,500 2,250 740 200 11,646 7,962 4,623 12,585 0 939 (3,269) 9,316 45 Critically Dry 1972 3,376 1,474 20 86 3,500 1,905 110 200 10,671 7,998 4,650 12,648 0 1,977 (5,245) 7,40346 Wet 1973 3,376 1,474 20 86 3,500 2,250 1,250 200 12,156 8,034 4,677 12,711 0 555 (5,800) 6,91147 Above Normal 1974 3,376 1,474 20 86 3,500 2,250 1,490 200 12,396 8,070 4,704 12,774 0 378 (6,178) 6,59648 Above Normal 1975 3,376 1,474 20 86 3,500 2,250 1,080 200 11,986 8,106 4,731 12,837 0 851 (7,028) 5,80949 Critically Dry 1976 3,376 1,474 20 86 3,500 1,905 0 200 10,561 8,142 4,758 12,900 0 2,339 (9,367) 3,53350 Critically Dry 1977 3,376 1,474 20 86 3,500 1,905 0 160 10,521 8,178 4,785 12,963 0 2,442 (11,809) 1,154 51 Extremely Wet 1978 3,376 1,474 20 86 3,500 2,250 1,460 160 12,326 8,214 4,812 13,026 0 700 (12,509) 517 52 Normal 1979 3,376 1,474 20 86 3,500 2,250 1,100 200 12,006 8,250 4,839 13,089 0 1,083 (13,591) (502)53 Extremely Wet 1980 3,376 1,474 20 86 3,500 2,250 1,380 200 12,286 8,286 4,866 13,152 0 866 (14,457) (1,305) 54 Below Normal 1981 3,376 1,474 20 86 3,500 2,250 781 200 11,687 8,322 4,893 13,215 0 1,528 (15,985) (2,770)55 Extremely Wet 1982 3,376 1,474 20 86 3,500 2,250 1,640 200 12,546 8,358 4,920 13,278 0 732 (16,717) (3,438) 56 Extremely Wet 1983 3,376 1,474 20 86 3,500 2,250 1,814 200 12,720 8,394 4,947 13,341 0 621 (17,337) (3,996) 57 Normal 1984 3,376 1,474 20 86 3,500 2,250 1,190 200 12,096 8,430 4,974 13,404 0 1,308 (18,645) (5,241) 58 Dry 1985 3,376 1,474 20 86 3,500 1,905 380 200 10,941 8,466 5,001 13,467 0 2,526 (21,170) (7,703) 59 Wet 1986 3,376 1,474 20 86 3,500 2,250 950 200 11,856 8,502 5,028 13,530 0 1,674 (22,844) (9,314) Notes: Seaside Basin Wheeled is comprised of 7.17 AF to Montage and 13 AF to Seaside Ascent project Malpaso is assumed to be 86 AFY production; less losses yields 80 AFY available to meet customer demandASR Uses actual 59-year record produced by Cal-Am witness in Phase 2 testimony to CPUC, starting in 1987 drought yearSand City Desal assumes 200 AFY with new intake well online; During 2nd year of drought and remaining drought year 20% reductionBase Year Water Demand is 9,813 AF, the 2023 10-year average; Assume to be split 65% Residential, 35% Non-ResidentialResidential Demand yearly increase: 36 AFY based on 2x 2022 AMBAG Regional Growth Forecast (population) Non-Residential yearly increase: 27 AFY based on 2x 2022 AMBAG Regional Growth Forecast (jobs) Initial storage includes ASR balance, excludes PWM Operating Reserve ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1879, Packet Page 2207 0 60,00050,00040,00030,00020,00010,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Acre-Feet
Year Following PWM Expansion
Supply and Storage Available v. Demand
30 Years Following PWM Expansion
Scenario 6
Supply Available in YearDemandAvailable in Year Plus PriorYear Storage ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1880, Packet Page 2208 Available
Pure Pure Aquifer Non- in Year
Water Derived Seaside Water Water Storage & Sand Total Residential Residential Total Stored Plus Forecast Year From Carmel Seaside Basin Monterey Monterey Recovery City Water Water Water Water Water Prior Year Year Class Year River Basin Wheeled Malpaso Base Expansion (ASR) Desal Available Demand Demand Demand Surplus Deficit EOY Storage Base/Avg n/a 3,376 1,177 20 86 3,500 2,139 791 193 11,282 6,378 3,435 9,813 0 1 Dry 1987 3,376 1,474 20 86 3,500 1,905 0 200 10,561 6,414 3,462 9,876 685 0 685 10,561 2 Critically Dry 1988 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,450 3,489 9,939 582 0 1,267 11,206 3 Critically Dry 1989 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,486 3,516 10,002 519 0 1,787 11,7894 Critically Dry 1990 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,522 3,543 10,065 456 0 2,243 12,3085 Dry 1991 3,376 1,474 20 86 3,500 1,905 230 160 10,751 6,558 3,570 10,128 623 0 2,866 12,9946 Normal 1992 3,376 774 20 86 3,500 2,250 280 160 10,446 6,594 3,597 10,191 255 0 3,121 13,312 7 Wet 1993 3,376 774 20 86 3,500 2,250 1,060 200 11,266 6,630 3,624 10,254 1,012 0 4,133 14,3878 Critically Dry 1994 3,376 774 20 86 3,500 1,905 140 200 10,001 6,666 3,651 10,317 0 316 3,818 14,1359 Extremely Wet 1995 3,376 774 20 86 3,500 2,250 1,450 200 11,656 6,702 3,678 10,380 1,276 0 5,094 15,474 10 Above Normal 1996 3,376 774 20 86 3,500 2,250 960 200 11,166 6,738 3,705 10,443 723 0 5,817 16,260 11 Above Normal 1997 3,376 774 20 86 3,500 2,250 1,070 200 11,276 6,774 3,732 10,506 770 0 6,587 17,093 12 Extremely Wet 1998 3,376 774 20 86 3,500 2,250 1,580 200 11,786 6,810 3,759 10,569 1,217 0 7,805 18,374 13 Normal 1999 3,376 774 20 86 3,500 2,250 1,140 200 11,346 6,846 3,786 10,632 714 0 8,519 19,151 14 Above Normal 2000 3,376 774 20 86 3,500 2,250 917 200 11,123 6,882 3,813 10,695 428 0 8,947 19,642 15 Normal 2001 3,376 774 20 86 3,500 2,250 790 200 10,996 6,918 3,840 10,758 238 0 9,185 19,943 16 Below Normal 2002 3,376 774 20 86 3,500 2,250 571 200 10,777 6,954 3,867 10,821 0 44 9,141 19,96217 Normal 2003 3,376 774 20 86 3,500 2,250 1,330 200 11,536 6,990 3,894 10,884 652 0 9,793 20,677 18 Below Normal 2004 3,376 774 20 86 3,500 2,250 520 200 10,726 7,026 3,921 10,947 0 221 9,572 20,51919 Wet 2005 3,376 774 20 86 3,500 2,250 1,447 200 11,653 7,062 3,948 11,010 643 0 10,215 21,225 20 Wet 2006 3,376 774 20 86 3,500 2,250 1,330 200 11,536 7,098 3,975 11,073 463 0 10,678 21,751 21 Critically Dry 2007 3,376 774 20 86 3,500 1,905 145 200 10,006 7,134 4,002 11,136 0 1,130 9,548 20,68422 Normal 2008 3,376 774 20 86 3,500 2,250 634 200 10,840 7,170 4,029 11,199 0 359 9,189 20,38823 Normal 2009 3,376 774 20 86 3,500 2,250 508 200 10,714 7,206 4,056 11,262 0 548 8,641 19,90324 Above Normal 2010 3,376 774 20 86 3,500 2,250 1,399 200 11,605 7,242 4,083 11,325 280 0 8,921 20,246 25 Above Normal 2011 3,376 774 20 86 3,500 2,250 1,395 200 11,601 7,278 4,110 11,388 213 0 9,134 20,522 26 Dry 2012 3,376 774 20 86 3,500 1,905 151 200 10,012 7,314 4,137 11,451 0 1,439 7,695 19,14627 Dry 2013 3,376 774 20 86 3,500 1,905 476 160 10,297 7,350 4,164 11,514 0 1,217 6,478 17,992 28 Critically Dry 2014 3,376 774 20 86 3,500 1,905 0 160 9,821 7,386 4,191 11,577 0 1,756 4,723 16,300 29 Dry 2015 3,376 774 20 86 3,500 1,905 190 160 10,011 7,422 4,218 11,640 0 1,629 3,094 14,73430 Normal 2016 3,376 774 20 86 3,500 2,250 790 160 10,956 7,458 4,245 11,703 0 747 2,347 14,050 Water Supplies not Affected by Drought Water Supplies Affected by Drought Water Demand Monterey Peninsula Water Supply Assessment
For 59 Years Following Pure Water Monterey Expansion
Scenario 7
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1881, Packet Page 2209 31 Extremely Wet 2017 3,376 1,474 20 86 3,500 2,250 1,470 200 12,376 7,494 4,272 11,766 610 0 2,957 14,723 32 Below Normal 2018 3,376 1,474 20 86 3,500 2,250 199 200 11,105 7,530 4,299 11,829 0 724 2,233 14,062 33 Extremely Wet 2019 3,376 1,474 20 86 3,500 2,250 1,310 200 12,216 7,566 4,326 11,892 324 0 2,557 14,449 34 Normal 2020 3,376 1,474 20 86 3,500 2,250 1,230 200 12,136 7,602 4,353 11,955 181 0 2,738 14,693 35 Dry 2021 3,376 1,474 20 86 3,500 1,905 60 200 10,621 7,638 4,380 12,018 0 1,397 1,342 13,36036 Above Normal 1963 3,376 1,474 20 86 3,500 2,250 1,190 200 12,096 7,674 4,407 12,081 15 0 1,357 13,438 37 Dry 1964 3,376 1,474 20 86 3,500 1,905 260 200 10,821 7,710 4,434 12,144 0 1,323 34 12,178 38 Normal 1965 3,376 1,474 20 86 3,500 2,250 920 200 11,826 7,746 4,461 12,207 0 381 (346) 11,86139 Dry 1966 3,376 1,474 20 86 3,500 1,905 590 200 11,151 7,782 4,488 12,270 0 1,119 (1,465) 10,805 40 Wet 1967 3,376 1,474 20 86 3,500 2,250 1,430 200 12,336 7,818 4,515 12,333 3 0 (1,461) 10,872 41 Critically Dry 1968 3,376 1,474 20 86 3,500 1,905 90 200 10,651 7,854 4,542 12,396 0 1,745 (3,206) 9,190 42 Extremely Wet 1969 3,376 1,474 20 86 3,500 2,250 1,200 200 12,106 7,890 4,569 12,459 0 353 (3,559) 8,90043 Normal 1970 3,376 1,474 20 86 3,500 2,250 845 200 11,751 7,926 4,596 12,522 0 771 (4,329) 8,19344 Below Normal 1971 3,376 1,474 20 86 3,500 2,250 740 200 11,646 7,962 4,623 12,585 0 939 (5,268) 7,31745 Critically Dry 1972 3,376 1,474 20 86 3,500 1,905 110 200 10,671 7,998 4,650 12,648 0 1,977 (7,244) 5,40446 Wet 1973 3,376 1,474 20 86 3,500 2,250 1,250 200 12,156 8,034 4,677 12,711 0 555 (7,799) 4,91247 Above Normal 1974 3,376 1,474 20 86 3,500 2,250 1,490 200 12,396 8,070 4,704 12,774 0 378 (8,177) 4,59748 Above Normal 1975 3,376 1,474 20 86 3,500 2,250 1,080 200 11,986 8,106 4,731 12,837 0 851 (9,027) 3,81049 Critically Dry 1976 3,376 1,474 20 86 3,500 1,905 0 200 10,561 8,142 4,758 12,900 0 2,339 (11,366) 1,534 50 Critically Dry 1977 3,376 1,474 20 86 3,500 1,905 0 160 10,521 8,178 4,785 12,963 0 2,442 (13,808) (845)51 Extremely Wet 1978 3,376 1,474 20 86 3,500 2,250 1,460 160 12,326 8,214 4,812 13,026 0 700 (14,508) (1,482) 52 Normal 1979 3,376 1,474 20 86 3,500 2,250 1,100 200 12,006 8,250 4,839 13,089 0 1,083 (15,590) (2,501) 53 Extremely Wet 1980 3,376 1,474 20 86 3,500 2,250 1,380 200 12,286 8,286 4,866 13,152 0 866 (16,456) (3,304)54 Below Normal 1981 3,376 1,474 20 86 3,500 2,250 781 200 11,687 8,322 4,893 13,215 0 1,528 (17,984) (4,769) 55 Extremely Wet 1982 3,376 1,474 20 86 3,500 2,250 1,640 200 12,546 8,358 4,920 13,278 0 732 (18,716) (5,437) 56 Extremely Wet 1983 3,376 1,474 20 86 3,500 2,250 1,814 200 12,720 8,394 4,947 13,341 0 621 (19,336) (5,995) 57 Normal 1984 3,376 1,474 20 86 3,500 2,250 1,190 200 12,096 8,430 4,974 13,404 0 1,308 (20,644) (7,240) 58 Dry 1985 3,376 1,474 20 86 3,500 1,905 380 200 10,941 8,466 5,001 13,467 0 2,526 (23,169) (9,702) 59 Wet 1986 3,376 1,474 20 86 3,500 2,250 950 200 11,856 8,502 5,028 13,530 0 1,674 (24,843) (11,313) Notes: Seaside Basin Wheeled is comprised of 7.17 AF to Montage and 13 AF to Seaside Ascent project Malpaso is assumed to be 86 AFY production; less losses yields 80 AFY available to meet customer demandASR Uses actual 59-year record produced by Cal-Am witness in Phase 2 testimony to CPUC, starting in 1987 drought yearSand City Desal assumes 200 AFY with new intake well online; During 2nd year of drought and remaining drought year 20% reductionBase Year Water Demand is 9,813 AF, the 2023 10-year average; Assume to be split 65% Residential, 35% Non-ResidentialResidential Demand yearly increase: 36 AFY based on 2x 2022 AMBAG Regional Growth Forecast (population) Non-Residential yearly increase: 27 AFY based on 2x 2022 AMBAG Regional Growth Forecast (jobs) Initial storage is zero, excludes PWM Operating Reserve ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1882, Packet Page 2210 0 60,00050,00040,00030,00020,00010,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Acre-Feet
Year Following PWM Expansion
Supply and Storage Available v. Demand
30 Years Following PWM Expansion
Scenario 7
Supply Available in YearDemandAvailable in Year Plus PriorYear Storage ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1883, Packet Page 2211 Available
Pure Pure Aquifer Non- in Year
Water Derived Seaside Water Water Storage & Sand Total Residential Residential Total Stored Plus Forecast Year From Carmel Seaside Basin Monterey Monterey Recovery City Water Water Water Water Water Prior Year Year Class Year River Basin Wheeled Malpaso Base Expansion (ASR) Desal Available Demand Demand Demand Surplus Deficit EOY Storage Base/Avg n/a 3,376 1,177 20 86 3,500 2,139 791 193 11,282 6,378 3,435 9,813 0 1 Dry 1987 3,376 1,474 20 86 3,500 1,905 0 200 10,561 6,432 3,462 9,894 667 0 667 10,561 2 Critically Dry 1988 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,486 3,489 9,975 546 0 1,213 11,188 3 Critically Dry 1989 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,540 3,516 10,056 465 0 1,679 11,7354 Critically Dry 1990 3,376 1,474 20 86 3,500 1,905 0 160 10,521 6,594 3,543 10,137 384 0 2,063 12,2005 Dry 1991 3,376 1,474 20 86 3,500 1,905 230 160 10,751 6,648 3,570 10,218 533 0 2,596 12,8146 Normal 1992 3,376 774 20 86 3,500 2,250 280 160 10,446 6,702 3,597 10,299 147 0 2,743 13,042 7 Wet 1993 3,376 774 20 86 3,500 2,250 1,060 200 11,266 6,756 3,624 10,380 886 0 3,629 14,0098 Critically Dry 1994 3,376 774 20 86 3,500 1,905 140 200 10,001 6,810 3,651 10,461 0 460 3,170 13,6319 Extremely Wet 1995 3,376 774 20 86 3,500 2,250 1,450 200 11,656 6,864 3,678 10,542 1,114 0 4,284 14,826 10 Above Normal 1996 3,376 774 20 86 3,500 2,250 960 200 11,166 6,918 3,705 10,623 543 0 4,827 15,450 11 Above Normal 1997 3,376 774 20 86 3,500 2,250 1,070 200 11,276 6,972 3,732 10,704 572 0 5,399 16,103 12 Extremely Wet 1998 3,376 774 20 86 3,500 2,250 1,580 200 11,786 7,026 3,759 10,785 1,001 0 6,401 17,186 13 Normal 1999 3,376 774 20 86 3,500 2,250 1,140 200 11,346 7,080 3,786 10,866 480 0 6,881 17,747 14 Above Normal 2000 3,376 774 20 86 3,500 2,250 917 200 11,123 7,134 3,813 10,947 176 0 7,057 18,004 15 Normal 2001 3,376 774 20 86 3,500 2,250 790 200 10,996 7,188 3,840 11,028 0 32 7,025 18,05316 Below Normal 2002 3,376 774 20 86 3,500 2,250 571 200 10,777 7,242 3,867 11,109 0 332 6,693 17,80217 Normal 2003 3,376 774 20 86 3,500 2,250 1,330 200 11,536 7,296 3,894 11,190 346 0 7,039 18,229 18 Below Normal 2004 3,376 774 20 86 3,500 2,250 520 200 10,726 7,350 3,921 11,271 0 545 6,494 17,76519 Wet 2005 3,376 774 20 86 3,500 2,250 1,447 200 11,653 7,404 3,948 11,352 301 0 6,795 18,147 20 Wet 2006 3,376 774 20 86 3,500 2,250 1,330 200 11,536 7,458 3,975 11,433 103 0 6,898 18,331 21 Critically Dry 2007 3,376 774 20 86 3,500 1,905 145 200 10,006 7,512 4,002 11,514 0 1,508 5,390 16,90422 Normal 2008 3,376 774 20 86 3,500 2,250 634 200 10,840 7,566 4,029 11,595 0 755 4,635 16,23023 Normal 2009 3,376 774 20 86 3,500 2,250 508 200 10,714 7,620 4,056 11,676 0 962 3,673 15,34924 Above Normal 2010 3,376 774 20 86 3,500 2,250 1,399 200 11,605 7,674 4,083 11,757 0 152 3,521 15,27825 Above Normal 2011 3,376 774 20 86 3,500 2,250 1,395 200 11,601 7,728 4,110 11,838 0 237 3,284 15,12226 Dry 2012 3,376 774 20 86 3,500 1,905 151 200 10,012 7,782 4,137 11,919 0 1,907 1,377 13,29627 Dry 2013 3,376 774 20 86 3,500 1,905 476 160 10,297 7,836 4,164 12,000 0 1,703 (326) 11,674 28 Critically Dry 2014 3,376 774 20 86 3,500 1,905 0 160 9,821 7,890 4,191 12,081 0 2,260 (2,585) 9,496 29 Dry 2015 3,376 774 20 86 3,500 1,905 190 160 10,011 7,944 4,218 12,162 0 2,151 (4,736) 7,42630 Normal 2016 3,376 774 20 86 3,500 2,250 790 160 10,956 7,998 4,245 12,243 0 1,287 (6,023) 6,220 Water Supplies not Affected by Drought Water Supplies Affected by Drought Water Demand Monterey Peninsula Water Supply Assessment
For 59 Years Following Pure Water Monterey Expansion
Scenario 8
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1884, Packet Page 2212 31 Extremely Wet 2017 3,376 1,474 20 86 3,500 2,250 1,470 200 12,376 8,052 4,272 12,324 52 0 (5,971) 6,353 32 Below Normal 2018 3,376 1,474 20 86 3,500 2,250 199 200 11,105 8,106 4,299 12,405 0 1,300 (7,271) 5,13433 Extremely Wet 2019 3,376 1,474 20 86 3,500 2,250 1,310 200 12,216 8,160 4,326 12,486 0 270 (7,541) 4,94534 Normal 2020 3,376 1,474 20 86 3,500 2,250 1,230 200 12,136 8,214 4,353 12,567 0 431 (7,972) 4,59535 Dry 2021 3,376 1,474 20 86 3,500 1,905 60 200 10,621 8,268 4,380 12,648 0 2,027 (9,998) 2,65036 Above Normal 1963 3,376 1,474 20 86 3,500 2,250 1,190 200 12,096 8,322 4,407 12,729 0 633 (10,631) 2,098 37 Dry 1964 3,376 1,474 20 86 3,500 1,905 260 200 10,821 8,376 4,434 12,810 0 1,989 (12,620) 190 38 Normal 1965 3,376 1,474 20 86 3,500 2,250 920 200 11,826 8,430 4,461 12,891 0 1,065 (13,684) (793)39 Dry 1966 3,376 1,474 20 86 3,500 1,905 590 200 11,151 8,484 4,488 12,972 0 1,821 (15,505) (2,533) 40 Wet 1967 3,376 1,474 20 86 3,500 2,250 1,430 200 12,336 8,538 4,515 13,053 0 717 (16,221) (3,168) 41 Critically Dry 1968 3,376 1,474 20 86 3,500 1,905 90 200 10,651 8,592 4,542 13,134 0 2,483 (18,704) (5,570) 42 Extremely Wet 1969 3,376 1,474 20 86 3,500 2,250 1,200 200 12,106 8,646 4,569 13,215 0 1,109 (19,813) (6,598) 43 Normal 1970 3,376 1,474 20 86 3,500 2,250 845 200 11,751 8,700 4,596 13,296 0 1,545 (21,357) (8,061) 44 Below Normal 1971 3,376 1,474 20 86 3,500 2,250 740 200 11,646 8,754 4,623 13,377 0 1,731 (23,088) (9,711) 45 Critically Dry 1972 3,376 1,474 20 86 3,500 1,905 110 200 10,671 8,808 4,650 13,458 0 2,787 (25,875) (12,417) 46 Wet 1973 3,376 1,474 20 86 3,500 2,250 1,250 200 12,156 8,862 4,677 13,539 0 1,383 (27,257) (13,718) 47 Above Normal 1974 3,376 1,474 20 86 3,500 2,250 1,490 200 12,396 8,916 4,704 13,620 0 1,224 (28,481) (14,861) 48 Above Normal 1975 3,376 1,474 20 86 3,500 2,250 1,080 200 11,986 8,970 4,731 13,701 0 1,715 (30,195) (16,494) 49 Critically Dry 1976 3,376 1,474 20 86 3,500 1,905 0 200 10,561 9,024 4,758 13,782 0 3,221 (33,416) (19,634) 50 Critically Dry 1977 3,376 1,474 20 86 3,500 1,905 0 160 10,521 9,078 4,785 13,863 0 3,342 (36,758) (22,895) 51 Extremely Wet 1978 3,376 1,474 20 86 3,500 2,250 1,460 160 12,326 9,132 4,812 13,944 0 1,618 (38,376) (24,432) 52 Normal 1979 3,376 1,474 20 86 3,500 2,250 1,100 200 12,006 9,186 4,839 14,025 0 2,019 (40,394) (26,369) 53 Extremely Wet 1980 3,376 1,474 20 86 3,500 2,250 1,380 200 12,286 9,240 4,866 14,106 0 1,820 (42,214) (28,108) 54 Below Normal 1981 3,376 1,474 20 86 3,500 2,250 781 200 11,687 9,294 4,893 14,187 0 2,500 (44,714) (30,527) 55 Extremely Wet 1982 3,376 1,474 20 86 3,500 2,250 1,640 200 12,546 9,348 4,920 14,268 0 1,722 (46,436) (32,168) 56 Extremely Wet 1983 3,376 1,474 20 86 3,500 2,250 1,814 200 12,720 9,402 4,947 14,349 0 1,629 (48,064) (33,715) 57 Normal 1984 3,376 1,474 20 86 3,500 2,250 1,190 200 12,096 9,456 4,974 14,430 0 2,334 (50,398) (35,968) 58 Dry 1985 3,376 1,474 20 86 3,500 1,905 380 200 10,941 9,510 5,001 14,511 0 3,570 (53,967) (39,456) 59 Wet 1986 3,376 1,474 20 86 3,500 2,250 950 200 11,856 9,564 5,028 14,592 0 2,736 (56,703) (42,111) Notes: Seaside Basin Wheeled is comprised of 7.17 AF to Montage and 13 AF to Seaside Ascent project Malpaso is assumed to be 86 AFY production; less losses yields 80 AFY available to meet customer demandASR Uses actual 59-year record produced by Cal-Am witness in Phase 2 testimony to CPUC, starting in 1987 drought yearSand City Desal assumes 200 AFY with new intake well online; During 2nd year of drought and remaining drought year 20% reductionBase Year Water Demand is 9,813 AF, the 2023 10-year average; Assume to be split 65% Residential, 35% Non-ResidentialResidential Demand yearly increase: 54 AFY based on 3x 2022 AMBAG Regional Growth Forecast (population) Non-Residential yearly increase: 27 AFY based on 2x 2022 AMBAG Regional Growth Forecast (jobs) Initial storage is zero, excludes PWM Operating Reserve ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1885, Packet Page 2213 0 60,00050,00040,00030,00020,00010,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Acre-Feet
Year Following PWM Expansion
Supply and Storage Available v. Demand
30 Years Following PWM Expansion
Scenario 8
Supply Available in YearDemandAvailable in Year Plus PriorYear Storage ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1886, Packet Page 2214 Exhibit 2
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1887, Packet Page 2215 Monterey Peninsula Water Management District
Technical Memorandum
2022 Supply and Demand Forecast
Adopted September 19, 2022
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1888, Packet Page 2216 Water Demand
At its basic level, planning water supply is being able to answer three simple questions: (i) What is our usage today (current demand)? (ii) What will we need in the future (future demand)? and, (iii) when will we get there (growth rate)? The answers translate to how much supply will be needed each year going forward. In addition, the planner also has to examine if there is enough supply available to reliably serve the 10-Year Maximum Daily Demand (MDD) and Peak Hour Demand (PHD) in the higher demand months, per the California Code of Regulations (CCR) section 64554.

The 5-year average demand from 2017-2021 was 9,725 AFY. As can be seen in Figure 1 below, the trend in water demand has been declining, but relatively steady the past seven years.

Figure 1
Trend in Annual Water Demand
Using a fully-vetted third-party growth forecast is a very objective way for projecting water demand increase. AMBAG implemented an employment-driven forecast model for the first time in the 2014 forecast and contracted with the Population Reference Bureau (PRB) to test and apply the model again for the 2018 Regional Growth Forecast (RGF). To ensure the reliability of the population projections, PRB compared the employment driven model results with results from a cohort-component forecast, a growth trend forecast, and the most recent forecast published by the California Department of Finance (DOF). All four models resulted in similar Exhibit 2
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1889, Packet Page 2217 population growth trends. As a result of these reliability tests, AMBAG and PRB chose to implement the employment-driven model again for the 2022 Regional Growth Forecast.

AMBAG has captured the factors that influence both residential and non-residential water demand growth in its Regional Growth Forecast. AMBAG’s Final 2022 Regional Growth Forecast is utilized by AMBAG in its 2045 Metropolitan Transportation Plan and Sustainable Communities Strategy (MTP/SCS) adopted in May 2022. The 2045 MTP/SCS includes a planning period through 2045. The years forecasted include 2025, 2030, 2035, 2040, and 2045.

The forecast the same model that predicts employment growth using a shift-share model based on local data as well as state and national trends. Population growth is then driven by employment growth. Household and housing growth are driven by population growth, demographic factors and external factors. While the methodology for the 2022 Regional Growth Forecast has remained the same through three planning cycles, the models have been updated for the Moving Forward 2045 Monterey Bay Plan to include current data, a revised base year of 2020 and a new horizon year of 2045.

Houses and empty lots do not use water, people do. The portion of the AMBAG Regional Growth Forecast that forecasts population captures that water demand for residential purposes.

Hence, the housing envisioned for Legal Lots of Record, within Pebble Beach, or elsewhere is affiliated with the population growth forecast.

Similarly, economic growth is captured in the AMBAG Regional Growth Forecast by the growth in jobs. Both Cal-Am1 and the District have utilized job growth as a proxy for non-residential water demand growth. Hence, the commercial growth envisioned for Legal Lots of Record, within Pebble Beach, or due to increased tourism is affiliated with the growth in the jobs forecast.

AMBAG conducted 22 one-on-one meetings with local jurisdictions in the Cal-Am Main service area,2 where AMBAG discussed the Regional Growth Forecast estimates, subregional allocations, and recent trends at the Planning Directors Forum in August 2019, January 2020, and August 2020. Those meetings were the opportunity for the jurisdictions to voice concerns that other growth-related activities needed to be reflected and incorporated into the growth forecast.
1 Phase 2 Direct Testimony of Ian C. Crooks, Attachment A, 2022 Urban Water Management Plan, p.4-7: “For nonresidential customers, water use will increase at the rate of employment growth forecasted by AMBAG.” 2 Attachment A hereto, Final 2022 Regional Growth Forecast, Attachment 1.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1890, Packet Page 2218 Regional Housing Needs Allocation (RHNA) housing numbers are also embedded in the Regional Growth Forecast. “The regional growth forecast (RGF) is an important reference point in the RHNA process.”3
“The 2045 MTP/SCS includes an updated RHNA. The 6th Cycle Regional Housing Needs Determination (RHND) from HCD to AMBAG is 33,274 units.”4 The final growth forecast was adopted along with the 2045 Metropolitan Transportation Plan/Sustainable Communities in June 2022. The 6th Cycle RHNA Plan itself recognizes that it is contained within the 2045 MTP/SCS which utilizes the AMBAG 2022 Regional Growth Forecast. “May 2022 – AMBAG releases final 2045 Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) accommodating RHNA.”5 They are all tied together.

Since the City of Seaside is not entirely served by Cal-Am’s service area, only half of the future units for Seaside are assumed to be within the Cal-Am service area.” However, any future housing permitted and built in the old Fort Ord area of the cities of Monterey, Del Rey Oaks, or Seaside would also be served by Marina Coast Water District, not Cal-Am. Similarly, any housing units to be built in unincorporated Carmel Valley may be served by existing supplies that are not Cal-Am’s future supplies, but perhaps “wheeled” by Cal-Am – including 130 units at Carmel Valley Village, as well as September Ranch, that will apply against the RHNA goal, but not require a new supply to be met by Cal-Am. MPWMD believes the water for housing requirements that will be met by others should be as follows: Seaside 50% (same as Cal-Am’s own assumption), Del Rey Oaks 20%, Monterey 10%, unincorporated County 30% and should be applied as a discount to future residential water demand. These discounts will be reflected in MPWMD’s demand forecast shown below.

Many people incorrectly interpret the RHNA process as requiring housing units to be built within the next 8 years. That is not the case. The role of local governments is to participate in the development of the allocation methodology and to update their Housing Elements within the County General Plans and local zoning to show how they will accommodate their share of the housing, following the adoption of the RHNA methodology. It is a planning and zoning process.

It is not a building process.

The September 8-14, 2022 edition of The Monterey County Weekly states: “Cities and counties do not have to guarantee the units will be built by 2031, but they do have to rezone areas and remove barriers to developer who may take on the actual construction.” The City of Lafayette describes the process as “the RHNA allocation is not a prescription to build any units. And, the 3 Attachment C hereto, Draft 6th Cycle Regional Housing Needs Allocation Plan 2023-2031, April 2022, p. 5. 4 Attachment B hereto, Monterey Bay 2045 – Moving Forward, AMBAG, June 2022, Excerpts, pp. 4-38. 5 Attachment B hereto, Draft 6th Cycle Regional Housing Needs Allocation Plan 2023-2031, April 2022, p. 13.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1891, Packet Page 2219 City itself does not build units; private developers do. The City is only required to show that there is enough land zoned at appropriate densities to accommodate this need, should a developer want to build these units. In addition, the City must demonstrate that its codes and requirements do not unduly constrain the building of housing (for example, it needs to show that housing can be built “as-of-right” in some zones, without requiring a land use permit).”6 Or, as the City of Santa Monica adds: “It is important to recognize that the RHNA is a targeted housing number - Cities and counties do not have to build this number of units, but rather they are required by the state to plan for them and demonstrate that under the current land use and development standards, there is capacity to accommodate for this number of housing units.”7 This concept is reinforced by Sand City’s appeal and statement “it is inconceivable how the City could meet the goals of the current RHNA allocation. The City of Sand City requests AMBAG lower Sand City's allotment to a number that is actually achievable in light of its small size and noted constraints” and Pacific Grove Councilmember’s statement “Do I think Pacific Grove will really build all (1,125 units)? No, but we’re putting a policy in place that is supportive of additional housing. Our staff’s job is to show that the city in good faith is implementing policing, zoning or incentives to do so.”8
The ability of the Monterey Peninsula to generate or “absorb” the housing and commercial growth will help determine when such water supply is needed. The average growth in, or absorption of, water use in the decade preceding the Cease and Desist Order (CDO) was during a period of relative economic stability, available property, no moratorium on new service connections, and lower water rates, yet only resulted in 16.4 AF per year of absorption. Things do not develop quickly on the Monterey Peninsula. MPWMD analysis below shows 31.4 AF per year, almost twice as much as the historical rate, based on the AMBAG forecast.

To summarize:
• Legal Lots of Record: Population moves to the area and lives in either existing housing stock or new housing stock built on Legal Lots of Record. Housing is already included in the AMBAG Regional Growth Forecast. Thus, Legal Lots of Record is not additive. • Tourism Rebound: Non-residential economic growth is captured in the AMBAG Regional Growth Forecast and is not additive.
• Pebble Beach Entitlements: The entitlements represent new housing and commercial growth in the unincorporated County area of Pebble Beach. Hence, it is encapsulated within the AMBAG Regional Growth Forecast and is not additive. 6 Attachment E hereto, Frequently Asked Questions About RHNA, pp. 17, 19 et al. 7 Id., p. 16.
8 Id., pp. 21, 23-24.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1892, Packet Page 2220 • RHNA Housing Numbers: The new 6th Cycle Regional Housing Needs Allocation Plan 2023-2031 is reflected within the AMBAG Regional Growth Forecast and is not additive.

MPWMD’s forecast is based on the AMBAG 2022 Regional Growth Forecast and uses current 5-year average water production, a measure of the total water required to “feed” the system for customer use, before losses and fire flows, as the base. Starting with three years of actual consumption data (2017, 2018, and 2019 – pre-COVID), MPWMD allocated consumption for residential and non-residential by political jurisdiction, based on the proportionate percentages of each then mapped the current base production to the same proportions.9 Assuming all prospective population and housing growth is captured in AMBAG’s Regional Growth Forecast and all commercial economic expansion occurs at the same rate as AMBAG’s employment projections, MPWMD offers the following water demand forecast:

Table 1
Water Required for Population Growth10
Monterey
Pacific
Grove
Carmelby-theSea Seaside
Del Rey
Oaks
Sand
City County11 TOTAL
Population
in 2020 28,170 15,265 3,949 33,537 1,662 385 8,916 91,884 Population
in 2045 29,639 15,817 3,984 38,316 2,650 1,198 9,916 101,520 Increase 5.2% 3.6% 0.9% 14.2% 59.4% 211.2% 11.2% 10.5%
Acre-Feet
in 2020 1,675 908 413 1,015 92 21 2,221 6,345
Acre-Feet
by 2045 1,762 941 417 1,160 146 65 2,471 6,961
AF Served
by Others12 9 - - 72 11 - 75 167
Net AF in
2045 1,753 941 417 1,087 135 65 2,396 6,795
9 Attachment D hereto, Data and Methodology to Support MPWMD Forecast of Water Demand 10 Attachment A hereto, Final 2022 Regional Growth Forecast 11 To estimate unincorporated County population, use Cal-Am service area population reported in SWRCB Urban Water Supplier Monthly Reports (Raw Dataset), May 2022 value, minus urban areas. Estimate 1,000 residents added by 2045.
https://www.waterboards.ca.gov/water_issues/programs/conservation_portal/conservation_reporting.html. 12 This represents the portion of new residents in the jurisdiction who will reside in units served by water other than Cal-Am’s Main system. Non-Residential water demand served by others has not been designated.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1893, Packet Page 2221 Table 2
Water Required for Employment Growth13
Monterey
Pacific
Grove
Carmelby-theSea Seaside
Del Rey
Oaks
Sand
City County14 TOTAL
Jobs in
2020 40,989 8,016 3,566 10,476 748 2,092 4,300 70,187
Jobs in
2045 45,509 8,445 3,915 11,543 834 2,259 4,721 77,226
Increase 11.0% 5.4% 9.8% 10.2% 11.5% 8.0% 9.8% 10.0%
NonResidential
AF in 2020
1,547 332 225 336 22 66 853 3,380
NonResidential
AF in 2045
1,718 349 247 370 24 71 936 3,716
Increase 171 18 22 34 3 5 83 336
These AMBAG Regional Growth Forecast values can be converted to a long-term water demand forecast in the following manner:

Table 3
Calculation of Future (Year 2045) Water Demands
Base Year
(2020)
Estimate
For 2045
AMBAG
AF per
Year
Net Water for
Population 6,345 AF 6,795 AF 18.00
Water for NonResidential 3,380 AF 3,716 AF 13.44
Total 9,725 AF 10,511 AF 31.44
This future year growth rate, applied annually, results in the following water demand forecast:
13 Attachment A hereto, Final 2022 Regional Growth Forecast. 14 California Employment Development Department, Monthly Labor Force Data for Cities and Census Designated Places. November 15, 2019. Sum of Carmel Valley Village CDP and Del Monte Forest CDP. Escalated at same rate as Carmel-by-the-Sea.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1894, Packet Page 2222 Table 4
MPWMD Water Demand Forecast
2020 2025 2030 2035 2040 2045 2050 2055
Water Demand - AF 9,725 9,882 10,039 10,196 10,353 10,511 10,668 10,825 This demand forecast does not need to be increased by a “peaking factor” to meet the Maximum Month Demand, Maximum Day, or Peak Hourly Demand. As explained later in the section about “Water Supply”, it is not necessary to provide additional supplies if water resources stored can be utilized to meet peak demands. Instead, stored water can be accessed with increased production well capacity, rather than over-building supplies. It is always in the ratepayer’s interest to build one or two additional production wells for $3 million each, rather than a $321 million15 desalination plant if stored water can be utilized to meet peak demands.

WATER SUPPLY
Available sources of supply are shown in Table 5 below and are described in the discussion that follows.

Table 5
Monterey Peninsula Available Supply
(Acre-Feet Annually)
Supply Source w/ PWM Expansion
Pure Water Monterey 3,500
PWM Expansion 2,250
Carmel River 3,376
Seaside Basin 774
Aquifer Storage & Recovery (ASR) 1,300
Sand City Desalination Plant 210
Table 13 Water Rights 0
Malpaso Water Rights 58
Total Available Supply 11,468
15 From Attachment C-3 of Advice Letter AL 1220-A, September 10, 2019. Proposed costs for Cal-Am desalination plant have not been updated for many years. Given current inflation, supply chain issues, and increased construction cost environment, the desalination plant costs should be updated.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1895, Packet Page 2223 SUPPLY v. DEMAND
By comparing future supplies available inclusive of Pure Water Monterey Expansion and comparing to the expected long-term water demand16, future water supply beyond a Pure Water Monterey Expansion, such as a desalination plant, can be determined if needed for the Monterey Peninsula
The future Supply versus Demand analysis shows that the addition of the Pure Water Monterey Expansion meets the region’s demand needs for over 30 years and a new Cal-Am desalination plant, or some other alternative, is not needed.

Applying the 31.44 AFY from Table 3 linearly across a 30-year horizon results in the demands shown in the figure below showing expected supply versus demand.

Figure 2
Water Supply Available
vs.

Water Demand for AMBAG 2022 Regional Growth Forecast
16 Attachment F hereto, Evaluation of Water Supply Available versus Water Demand. 9,000
9,500
10,000
10,500
11,000
11,500
12,000
12,500
2025202620272028202920302031203220332034203520362037203820392040204120422043204420452046204720482049205020512052205320542055 Supply w/ Pure Water
Demand (Base Case)
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1896, Packet Page 2224 MPWMD also analyzed a demand forecast 25% higher, at 39.3 AF per year of average growth.

That result is shown in Figure 3, below:

Figure 3
Water Supply Available
vs.

Water Demand for AMBAG 2022 Regional Growth Forecast
Plus 25% for Forecasting Error
MPWMD also analyzed a demand forecast 50% higher, at 47.2 AF per year of average growth.

At that level, available supplies (with Pure Water Monterey Expansion, without a desalination plant) exceed water demand for over 30 years. In fact, MPWMD’s model shows that at 63 AF per year of average growth – 200% of or twice the water forecasted to be required for the AMBAG 2022 Regional Growth Forecast – supplies are available for over 30 years.

A contingency can be achieved by having additional stored water available to call upon at any time. This can be achieved by building up available storage in the early years where supply exceeds demand. As seen in Figures 2 and 3 above, and in the last columns of Attachment F, in the initial years following completion and availability of Pure Water Monterey Expansion (2025) the available supplies exceed demands by over 1,500 AF per year. In the very first year, more than 10% of available supplies (1,147 AF) can be stored to satisfy any contingency.

Water for available storage is shown below:
9,000
9,500
10,000
10,500
11,000
11,500
12,000
12,500
2025202620272028202920302031203220332034203520362037203820392040204120422043204420452046204720482049205020512052205320542055 Supply w/ Pure Water
Demand (Base Case + 25%)
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1897, Packet Page 2225 Table 6
Water Available for Storage
(With Pure Water Monterey Expansion, without Desalination) In addition to eliminating a need for a contingency from bigger water supply construction, the stored water can be used for peaking to meet maximum month demands (MMD), maximum day demand (MDD), and peak hourly demand (PHD) without building more supply projects. As stated earlier, it is always in the ratepayer’s interest to build one or two additional production wells for $3 million each, rather than a $321 million desalination plant if stored water can be utilized to meet peak demands.

Stored water can also be used as a drought reserve and to provide protective water levels in the Seaside Groundwater Basin. In fact, the average water to storage in the base case above in Table 6 is 1,268 AFY – far in excess of recommended protective water levels for the basin.

If the Monterey Peninsula were to experience drought during the initial “buildup period” of ASR reserves following the completion of new water supply and the lifting of the CDO, ASR would arguably be delayed in building up a drought reserve, but it should not be overlooked that a Pure Water Monterey Expansion is new capacity without an immediate offsetting demand. That is, 2,250 AFA from Pure Water Monterey Expansion would provide an off-set in the early years if Year
Storage
Available
Base Case
Demand
Storage
Available
Base Case
Demand +
25% Error Year
Storage
Available
Base Case
Demand
Storage
Available
Base Case
Demand +
25% Error
2025 1,586 1,586 2041 1,083 957
2026 1,555 1,547 2042 1,052 918
2027 1,523 1,507 2043 1,020 879
2028 1,492 1,468 2044 989 839
2029 1,460 1,429 2045 957 800
2030 1,429 1,390 2046 926 761
2031 1,397 1,350 2047 894 721
2032 1,366 1,311 2048 863 682
2033 1,334 1,272 2049 831 643
2034 1,303 1,232 2050 800 604
2035 1,272 1,193 2051 1,469 1,264
2036 1,240 1,154 2052 1,437 1,225
2037 1,209 1,114 2053 1,406 1,186
2038 1,177 1,075 2054 1,374 1,146
2039 1,146 1,036 2055 1,343 1,107
2040 1,114 997 Total 38,046 34,392
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1898, Packet Page 2226 ASR’s drought reserve has not yet built-up. Just a few years of Pure Water Monterey Expansion water could also provide drought-resilience to the Monterey Peninsula.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1899, Packet Page 2227 Exhibit 3
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1900, Packet Page 2228 1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA
Application of California-American Water
Company (U210W) to Obtain Approval of
the Amended and Restated Water Purchase
Agreement for the Pure Water Monterey
Groundwater Replenishment Project, Update
Supply and Demand Estimates for the
Monterey Peninsula Water Supply Project,
and Cost Recovery.

Application 21-11-024
(Filed November 29, 2021)
PHASE 2 DIRECT TESTIMONY OF PAUL FINDLEY
Sarah E. Leeper
Nicholas A. Subias
Cathy Hongola-Baptista
California-American Water Company
555 Montgomery Street, Suite 816
San Francisco, CA 94111
(415) 863-2960
[email protected]
Lori Anne Dolqueist
Willis Hon
Nossaman LLP
50 California Street
34th Floor
San Francisco, CA 94111
(415) 398-3600
[email protected]
[email protected]
Attorneys for California-American Water Company
Dated: July 20, 2022
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1901, Packet Page 2229 3 1
2 3
4 5
6 7
8 9
10 11
12 13
14 15
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18 19
20 21
22 23
24 25
26 27
28 Q7. How do permits limit ASR diversions?
A7. The diversion of excess Carmel River water for injection the ASR system is limited by two SWRCB permits, and both permits have minimum stream flow conditions that must be met. When these minimum stream flow conditions are met, then the permits would theoretically allow diversion of up to 14.7 cubic feet per second (CFS), which is 29.2 Acre-feet per day (AFD). However, it is not physically possible to inject this amount of water in the ASR wells due to capacity limitations of the system.

Q8. What is the maximum ASR injection rate?
A8. The only way that Carmel River water can be delivered to the ASR wells is via the Crest Pipeline, and due to capacity limitations of that pipeline, the maximum ASR injection rate is 8.6 CFS (17 AFD). However, when diversion is only permitted under Permit 20808A, but stream flows are below the minimums of Permit 20808C; or, when the Upper Carmel Valley wells are not in operation, then the maximum injection rate is 6.7 CFS (13.3 AFD).

Q9. How did you simulate future ASR operation?
A9. I obtained daily Carmel River flow records for the last 59 years (1963 to 2021). I then prepared a hypothetical simulation in which I looked at the river flow for each day and determined if ASR diversion would have been permitted under present day permit rules.

If that day qualified as an injection day, I then determined if ASR injection would have been 13.3 AFD or 17 AFD for that day. I then compiled and analyzed the results for each year.

Q10. What were the results of this simulation?
A10. Over the last 59 years, the number of days that would have qualified for injection averaged 79 days per year but ranged from zero (seven of the 59 years) to 181 days ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1902, Packet Page 2230 4 1
2 3
4 5
6 7
8 9
10 11
12 13
14 15
16 17
18 19
20 21
22 23
24 25
26 27
28 (once, in 1983). Simulated ASR injection averaged 1,210 AFY but ranged from zero (seven of the 59 years) to 2,840 AF (in 1983).

Q11. Did you discover any trends?
A11. Yes. I noticed a definite downward trend in average river flow in the last 30 years.

Average Carmel River flow during the time period 1992-2001 was 256 CFS, and fell to 198 CFS during 2002-2011, and then fell again to 143 CFS during 2012-2021. As a result, simulated ASR diversion averages fell from 1,445 AFY for 1992-2001 to 868 AFY for 2012-2021.

Q12. What did you conclude regarding ASR injection as a reliable source of supply? A12. Based on the past 59 years of record, I concluded that the chances that ASR injection will be zero in any given year in the future is approximately 12 percent. I also looked at fiveyear averages, and concluded that for any five-year period in the future, CAW can expect that the five-year ASR injection average will exceed 240 AFY with 95 percent reliability, and 470 AFY with 90 percent reliability.

Q13. Can ASR injection fill the anticipated gap between demand and firm supply? A13. In my opinion, not with any reasonable degree of reliability. During the time period 2026-2030, the projected average demand is 11,300 AFY, which is 1,300 AFY more than the firm supply of 10,000 AFY. Based on the five-year averages from the simulation, the probability of attaining a five-year average of 1,300 AFY from ASR injection is 39 percent.

Q14. Does this conclude your testimony?
A14. Yes.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1903, Packet Page 2231

ASR AVAILABILITY AND RELIABILITY ANALYSIS TECHNICAL MEMOR To:

From:

Subject:

Date:

Background
Ian Crooks
Paul Findley, Sarp Sekeroglu
ASR Reliability Analysis
July 15, 2022
The Aquifer Storage and Recovery (ASR) Program, operated jointly by California American Water (CAW) and the Monterey Peninsula Water Management District (MPWMD), allows for the storage of excess Carmel River water in the Seaside Groundwater Basin during wet winter and spring months for later extraction and beneficial use during dry summer and fall months. The diversion of Carmel River water for this purpose is regulated by the State Water Resources Control Board (SWRCB) such that it only can occur during a six-month (183-day) ASR injection season from December 1 to May 31, and only if minimum stream flow requirements are met.

The injection of excess Carmel River water in the ASR system is limited by two SWRCB permits. Permit 20808A provides for injection of up to 6.7 cubic feet per second (CFS) of excess Carmel River flows, which is 13.3 acre-feet per day (AFD). For higher Carmel River flows, Permit 20808C provides for the injection of an additional 8 CFS (15.9 AFD). The maximum injection allowed under these two permits is 14.7 CFS (29.2 AFD). However, it is not physically possible to inject this amount of water in the ASR wells due to capacity limitations of the system.

ASR System Limitations
The ASR system's relevant facilities, shown in Figure 1, are the Carmel Valley Wells, the Begonia Iron Removal Plant (BIRP), the Segunda and Crest Tanks, the Crest/ ASR pipelines, and the ASR wells.

Figure 1- ASR System Facilities
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1904, Packet Page 2232


























































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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1906, Packet Page 2234 Exhibit 4
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1907, Packet Page 2235 1 SEASIDE BASIN

WATERMASTER
ANNUAL REPORT – 2023
January 3, 2024
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1908, Packet Page 2236 27 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1909, Packet Page 2237 142-1
Monterey Peninsula Water Management District
RULE 142 - WATER EFFICIENCY STANDARDS
A. Water Effi ciency Standards.

1. All New Construction of New Structures shall install and maintain plumbing fi xtures and conservation standards as set forth in this Rule.

2. No plumbing fi xture shall be replaced with fi xtures which allow greater water use.

3. All new and replacement water fi xtures shall comply with then-current California plumbing and energy standards/codes when more restrictive than the District’s.

B. Former Rules. Water Permit requirements change periodically to refl ect current effi ciencies. Sites with uncompleted Water Permits that have not received a fi nal inspection shall at a minimum comply with the requirements in place at the time the Water Permit was issued unless required to install more effi cient fi xtures as a result of a subsequent triggering event (e.g. new/amended Water Permit or Change of Ownership/ Use).

C. Residential Water Effi ciency Standards for New Structures.

All Residential New Structures receiving a Water Permit, shall meet or exceed the following standards:

1. High Effi ciency or Ultra High Effi ciency Toilets shall be installed;

2. Urinals, when installed in a Residential use, shall be designed to fl ush with one (1) gallon of water. After January 1, 2016, newly installed Urinals shall fl ush with no more than 0.125 gallon per fl ush;

3. Showerheads, Rain Bars, or Body Spray Nozzles must be designed and manufactured to emit a maximum of 2.0 gallons per minute of water;

4. All shower fi xtures should be equipped with scald protection valves rated for 2.0 gallons per minute Showerheads;

5. High Effi ciency Clothes Washer(s) and High Effi ciency Dishwasher(s) shall be required when installed in a Residential use;

6. Lavatory Sink faucets shall emit a maximum of 1.2 gallons of water per minute at 60 psi;

7. Kitchen Sink, Utility Sink, and Bar Sink faucets shall emit a maximum of

1.8 gallons of water per minute at 60 psi. Faucets may have the capability to temporarily increase fl ow to 2.2 gallons per minute for fi lling pots and pans, but must default back to a maximum fl ow rate of 1.8 gallons per minute measured at 60 psi;
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1910, Packet Page 2238 142-2
Monterey Peninsula Water Management District

8. Instant-Access Hot Water Systems shall be installed;

9. All hot water pipes shall be insulated;

10. Sodium chloride (salt) water softeners shall be discouraged in New Construction.

Alternate technologies such as potassium chloride shall be recommended. When a sodium chloride water softener is to be installed within the MPWMD, the unit shall use demand-initiated regeneration which senses when the resin must be recharged, either electronically or with a meter that measures and calculates usage.

This requirement shall be specifi ed on the Construction Drawings;

11. Landscaping.
a. All New Construction shall install and maintain Landscaping that complies with the California Model Water Effi cient Landscape Ordinance as revised (California Code of Regulations, Title 23, Water, Division 2, Department of Water Resources, Chapter 2.7, Model Water Effi cient Landscape Ordinance) or with local or District Landscape requirements if more restrictive.
b. Plants shall be grouped in hydrozones.

12. Irrigation System Effi ciency.
a. Weather-Based Irrigation System Controllers (e.g. Smart Controllers) shall be installed, used and maintained on Sites where there is an Irrigation System.
b. Weather-Based Irrigation System Controllers shall include functioning Soil Moisture Sensors and a Rain Sensor as components of the system. c. Drip Irrigation shall be utilized for watering all non-turf irrigated plantings.
d. Rotating Sprinkler Nozzles shall be utilized for turf irrigation. e. Overhead spray irrigation shall not be used to water non-turf Landscaping, including trees and shrubs.
f. Irrigation Systems shall operate with at least 75 percent effi ciency for overhead spray devices and at least 81 percent effi ciency for drip systems. g. Rainwater collection/irrigation systems are encouraged to supplement irrigation for new Landscaping. New Structures shall be encouraged to include one or more rainwater Cisterns and a system to provide at least 75 percent of exterior irrigation during normal rainfall years. Systems must be compliant with local catchment system standards.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1911, Packet Page 2239 142-3
Monterey Peninsula Water Management District
h. Graywater collection/irrigation systems are encouraged to supplement irrigation for new Landscaping. Systems must be compliant with local catchment system standards, including Monterey County Department of Environmental Health.
i. All Sites utilizing a Graywater reuse system shall install and maintain a backfl ow prevention device as required by any Water Distribution System Operator that supplies water to the Site.

D. Non-Residential Water Effi ciency Standards for New Structures.

All Non-Residential New Structures receiving a Water Permit shall meet or exceed the following standards:

1. High Effi ciency or Ultra High Effi ciency Toilets shall be installed;

2. Urinals shall be Pint Urinals or Zero Water Consumption Urinals and shall be clearly specifi ed on the fi nal Construction Drawings. Zero Water Consumption Urinals shall be encouraged in settings where there is a regular maintenance staff;

3. Showerheads, Rain Bars, or Body Spray Nozzles must be designed and manufactured to emit a maximum of 2.0 gallons per minute of water;

4. All shower fi xtures should be equipped with scald protection valves rated for 2.0 gallons per minute Showerheads;

5. Public Washbasins shall emit a maximum of 0.5 gallon of water per minute at 60 psi. Private Washbasins (e.g. hotel or motel guest rooms and hospital patient rooms) shall emit a maximum of 1.2 gallons of water per minute at 60 psi. All other sinks shall emit a maximum of 2.2 gallons of water per minute at 60 psi unless higher fl ow is required by Health and Safety Code;

6. Public Washbasins equipped with automatic shut off devices or sensor faucets shall operate with a maximum fl ow of 0.25 gallons per cycle;

7. High Effi ciency Clothes Washers shall be installed when a Clothes Washer is installed in a New Structure permitted under this Regulation;

8. High Effi ciency Dishwashers or High Effi ciency Commercial Dishwashers shall be installed and maintained on the Site when a Dishwasher is installed in a New Structure permitted by a Water Permit;

9. Instant-Access Hot Water System(s) shall be installed for hot water access points to ensure that hot water is available within ten (10) seconds;

10. All hot water pipes shall be insulated;
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1912, Packet Page 2240 142-4
Monterey Peninsula Water Management District

11. Sodium chloride (salt) water softeners shall be discouraged in New Construction.

Alternate technologies, such as potassium chloride shall be recommended. When a sodium chloride water softener is to be installed within the MPWMD, the unit shall use demand-initiated regeneration which senses when the resin must be recharged, either electronically or with a meter that measures and calculates usage. This requirement shall be specifi ed on the Construction Drawings;

12. Water Effi cient Pre-Rinse Spray Valves shall be utilized when a pre-rinse spray valve is installed;

13. There shall be no single-pass water use systems in ice machines, hydraulic equipment, refrigeration condensers, X-ray processing equipment, air compressors, vacuum pumps, etc. Air-cooled or better technology shall be installed when available;

14. Water cooled refrigeration equipment shall be prohibited when there is alternative cooling technology available at the time the Water Permit is issued;

15. Cooling Towers shall be equipped with conductivity controllers that are used to increase the number of cycles that can be achieved;

16. Boilerless steamers or connectionless steamers shall be installed in place of boilerbased steamers when a steamer is installed in New Construction;

17. Landscaping.
a. All New Construction shall install and maintain Landscaping that complies with the California Model Water Effi cient Landscape Ordinance as revised (California Code of Regulations, Title 23, Water, Division 2, Department of Water Resources, Chapter 2.7, Model Water Effi cient Landscape Ordinance) or with local or District Landscape requirements if more restrictive.
b. Plants shall be grouped in hydrozones.

18. Irrigation System Effi ciency.
a. Weather-Based Irrigation System Controllers shall be installed, used and maintained on Sites where there is an Irrigation System. b. Weather-Based Irrigation System Controllers shall include functioning Soil Moisture Sensors and a Rain Sensor as components of the system. c. Drip Irrigation shall be utilized for watering all non-turf irrigated plantings.
d. Rotating Sprinkler Nozzles shall be utilized for turf irrigation.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1913, Packet Page 2241 142-5
Monterey Peninsula Water Management District
e. Overhead spray irrigation shall not be used to water non-turf Landscaping, including trees and shrubs.
f. Irrigation Systems shall operate with at least 75 percent effi ciency for overhead spray devices and at least 81 percent for drip systems.
g. Rainwater collection/irrigation systems are encouraged to supplement irrigation for new Landscaping. New Structures shall be encouraged to include one or more rainwater Cisterns and a system to provide at least 75 percent of exterior irrigation during normal rainfall years. Systems must be compliant with local catchment system standards.
h. Graywater collection/irrigation systems are encouraged to supplement irrigation for new Landscaping. Systems must be compliant with local catchment system standards, including Monterey County Department of Environmental Health.
i. All Sites utilizing a Graywater reuse system shall install and maintain a backfl ow prevention device as required by any Water Distribution System Operator that supplies water to the Site.

19. The implementation of water conservation Best Management Practices shall be integrated into construction and operation of the project to the extent possible.

20. The use of Alternative Water Sources for indoor toilet fl ushing and other uses allowed by the Jurisdiction shall be encouraged.

E. Residential and Non-Residential Change of Ownership, Change of Use, and Expansion of Use Water Effi ciency Standards
Sites that have a Change of Ownership, or receive a Water Permit for a Change of Use or Expansion of Use shall meet or exceed the following standards:

1. High Effi ciency or Ultra High Effi ciency Toilets shall be installed;

2. Urinals shall be at a minimum High Effi ciency Urinals (when installed prior to January 1, 2016). Newly installed Urinals shall be Pint Urinals or Zero Water Consumption Urinals. Zero Water Consumption Urinals shall be encouraged in settings where there is a regular maintenance staff;

3. Showerhead fl ow rates shall meet or exceed water effi ciency standards for New Structures;
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1914, Packet Page 2242 142-6
Monterey Peninsula Water Management District

4. Bathroom faucet fl ow rates shall meet or exceed water effi ciency standards for New Structures;

5. Kitchen faucet fl ow rates shall meet or exceed water effi ciency standards for New Sturctures;

6. Remodels or relocations of water fi xtures or appliances that involve hot water shall be encouraged to install an Instant-Access Hot Water System and insulate all new hot water pipes;

7. Pre-rinse spray valves shall meet or exceed the District’s defi nition for Water Effi cient Pre-Rinse Spray Valves;

8. Changes of Use and Expansions of Use that require a Water Permit shall not install any single-pass water use systems in ice machines, hydraulic equipment, refrigeration condensers, X-ray processing equipment, air compressors, vacuum pumps, etc. Air-cooled or better technology shall be installed when available;

9. Changes of Use and Expansions of Use that require a Water Permit shall not install any water cooled refrigeration equipment when there is alternative water effi cient cooling technology available at the time the Water Permit is issued;

10. Automatic Irrigation Systems, with the exception of Weather- Based Irrigation Systems, shall be retrofi t to include a Rain Sensor;

11. The implementation of Non-Residential Best Management Practices shall be integrated into construction and operation of Non-Residential uses to the extent possible.

Rule added by Ordinance No. 30 (7/13/87); amended by Ordinance No. 71 (12/20/1993): Ordinance No. 125 (9/18/2006); Ordinance No. 141 (11/16/2009); Ordinance No. 151 (11/19/2012); Ordinance No. 170 (5/16/2016) ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1915, Packet Page 2243 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1916, Packet Page 2244 Final Environmental Impact Report
July 5, 2024
SCH #2023080034
Monterey 2031
General Plan Update
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1917, Packet Page 2245 Monterey 2031
General Plan Update
Final Environmental Impact Report
July 5, 2024
Prepared for the City of Monterey
Prepared by
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1918, Packet Page 2246 Table of Contents
1 Introduction............................................................................................................... 1-1 Purpose ..................................................................................................................................................... 1-1 CEQA Process......................................................................................................................................... 1-2 Organization............................................................................................................................................. 1-2 2 Public Comments and Responses ........................................................................... 2-1

2.1 Comments Received....................................................................................................................... 2-1

2.2 Master Responses........................................................................................................................ 2-229

2.3 Responses to Comments........................................................................................................... 2-234 3 Revisions to the Draft EIR........................................................................................ 3-1 Table of Contents................................................................................................................................... 3-1 Executive Summary ................................................................................................................................ 3-1 Chapter 1: Introduction. ....................................................................................................................... 3-5 Chapter 3.2: Agricutural Resources................................................................................................... 3-5 Chapter 3.4: Biological Resources...................................................................................................... 3-7 Chapter 3.8: Hazards and Hazardous Materials............................................................................ 3-10 Chapter 3.9: Hydrology and Water Quality................................................................................... 3-11 Chapter 3.12: Public Services and Recreation................................................................................ 3-14 Chapter 3.13: Transporation.............................................................................................................. 3-14 Chapter 3.14: Utilities and Service Systems................................................................................... 3-15 Chapter 3.15: Wildfire......................................................................................................................... 3-15 Chapter 4: Alternatives....................................................................................................................... 3-16 Chapter 5: CEQA Required Conclusions....................................................................................... 3-17 Appendix 1: MCWD Confirming Water Supply ........................................................3-20 Appendix 2: LandWatch Parcel-Based Projections...................................................3-24 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1919, Packet Page 2247 Final Environmental Impact Report for the Monterey 2031 General Plan Update Table of Contents
This page intentionally left blank.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1920, Packet Page 2248 1-1
1 Introduction
In accordance with the California Environmental Quality Act (CEQA), this document provides responses to comments received on the Draft Environmental Impact Report (Draft EIR) SCH No. 2023080034 for the proposed Monterey 2031 General Plan Update (Proposed Plan) in the City of Monterey, California, and it includes revisions to the text in the Draft EIR made in response to these comments. The Draft EIR identified significant impacts associated with the Proposed Plan and examined alternatives and recommended mitigation measures that could avoid or reduce potential impacts.

This document will constitute the Final EIR if the City Council certifies it as adequate and complete under CEQA.

Purpose
As described in Sections 15089 and 15132 of the State CEQA Guidelines, the lead agency must prepare a Final EIR before approving a project. The purpose of a Final EIR is to provide an opportunity for the lead agency to respond to comments made by the public and agencies. Pursuant to CEQA Guidelines Section 15132, a Final EIR must contain the following:
• The Draft EIR or a revision of the Draft;
• A list of persons, organizations, and public agencies commenting on the Draft EIR; • Comments and recommendations received on the Draft EIR; • The response of the Lead Agency to significant environmental points raised in the review process; and
• Any other information added by the Lead Agency.

The EIR is intended to disclose to the City of Monterey decision makers, responsible agencies, organizations, and the general public the potential impacts of implementing the Proposed Plan using a program level of analysis. This Final EIR amends and incorporates by reference the Draft EIR, which is bound separately. As required under CEQA, this document includes comments and responses to comments on the Draft EIR, and minor corrections and clarifications to the Draft EIR.

The Final EIR and the Draft EIR are available for review at:
https://haveyoursaymonterey.org/monterey2031.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1921, Packet Page 2249 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 1: Introduction
1-2
CEQA Process
The City of Monterey is the lead agency for this EIR. According to CEQA, lead agencies are required to consult with public agencies having jurisdiction over a Proposed Plan, and to provide the general public with an opportunity to comment on the Draft EIR. The Draft EIR was made available for public review on February 9, 2024. The Draft EIR was distributed to local and State responsible and trustee agencies and the general public was advised of the availability of the Draft EIR through public notice published in the local newspaper and on the City's website and the project website as required by law.

Copies of all written comments received on the Draft EIR are contained in this document. These comments and responses to these comments are included in Chapter 2 of this Final EIR.

Organization
This document contains the following components:
• Chapter 1 Introduction. This chapter discusses the use and organization of the Final EIR. • Chapter 2 Public Comments and Responses. Lists all of the agencies, organizations, and individuals that submitted written comments on the Draft EIR and reproduces all comments. Provides responses to comments on the Draft EIR as well as revisions to the Draft EIR where necessary to clarify or amplify in the order that responses appear. Where such revisions are warranted in response to comments on the Draft EIR, deletions are shown in strikethrough and additions are shown underlined in red in the matrix of comments and responses.
• Chapter 3 Revisions to the Draft EIR. Provides errata with revisions to the Draft EIR where necessary to clarify or amplify. Revisions are organized by Draft EIR section and by page number. Where such revisions are warranted in response to comments on the Draft EIR, deletions are shown in strikethrough and additions are shown underlined in red in the matrix of comments and responses.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1922, Packet Page 2250 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-1
2 Public Comments and Responses
This chapter contains copies of the comment letters received on the Draft EIR during the public comment period, which began on February 9, 2024 and ended on March 25, 2024, as well as responses to comments that pertain to environmental issues and the merits of the analysis in the Draft EIR.

2.1 Comments Received
There were 71 comment letters received during the comment period. These contained 522 unique comments. Comment letters are organized into two categories and presented in alphabetical order within each category: Public Agency comments (section A), Organization comments (section B) and Individual comments (section C).

Each letter or summary is identified by a designator (e.g. “Letter A1”). Specific comments within each letter or summary are identified by a designator in the page margin that reflects the sequence of the specific comment within the correspondence (e.g. “A1-1” for the first comment in Letter A1).

Comment letters received are listed in Table 2-1.

Table 2-1: Comments Received on the Draft EIR
Comment
Letter
Date Commenter
Agencies (A)
A1 3/11/2024 Association of Monterey Bay Area Governments (AMBAG) A2 3/20/2024 California Department of Toxic Substances Control (DTSC) A3 3/25/2024 California Department of Transportation (Caltrans) A4 3/19/2024 County of Monterey
A5 3/25/2024 Monterey-Salinas Transit District (MST)
A6 3/22/2024 United States Department of the Navy
Organizations (B)
B1 3/25/2024 California Native Plant Society
B2 3/21/2024 LandWatch
Individuals (C)
C1 3/4/2024 Weinstein, Beth
C2 3/16/2024 Turner, Elizabeth
C3 3/19/2024 Behl, Robert
C4 3/16/2024 Benzing, Jeff
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1923, Packet Page 2251 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-2
Comment
Letter
Date Commenter
C5 3/22/2024 Biby, Jordan
C6 3/20/204 Birkhofer, Wendell and Celeste
C7 3/1/2024 Bonavico, Chris
C8 3/8/2924 Breidenbach, Fred
C9 3/8/2024 Breidenbach, Susan
C10 3/24/2024 Brown, Henry
C11 3/19/2024 Chrietzberg, Charles
C12 3/7/2024 Cochran, Robert and Laurie
C13 3/21/2024 Cook, Arthur
C14 3/23/2024 Cooper, Helen
C15 3/7/2024 Corliss, Robert and Melanie
C16 3/1/2024 Darabont, Frank
C17 3/1/2024 Darabont, Rae
C18 3/13/2024 DePalatis, Dale and Caroline
C19 3/20/204 Hamilton, Jackie
C20 3/15/2024 Hamilton, Randy
C21 3/25/2024 Harrill, Meredith
C22 3/5/2024 Hawryluk, Andrew
C23 3/5/2024 Healy, Linda
C24 3/5/2024 Healy, Michael
C25 3/5/2024 Heinrich, Dana
C26 3/25/2024 Hennington, Daian and Glenn
C27 3/19/2024 Hogan, Michael
C28 3/6/2024 Hunt, Grant
C29 3/18/2024 Hunt, Susan
C30 3/20/204 Jacobs, Stuart
C31 3/20/2024 Jamieson, Peter and Kay
C32 3/15/2024 Jones, Michelle
C33 3/22/2024 Kim, Young
C34 3/25/2024 Lanier, Andrea and Brent
C35 3/19/2024 Lovett, Nigel
C36 3/24/2024 MacHarg, Carlyle
C37 3/24/2024 MacHarg, Kimiko
C38 3/12/2024 McLoghlin, Oona
C39 3/5/2024 Menzies, Lurline
C40 3/21/2024 Nikssarian, David
C41 3/21/2024 Nikssarian, Mary Khasigian
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1924, Packet Page 2252 Final Environmental Impact Report for the Monterey 2031 General Plan Update Chapter 2: Public Comments and Responses
2-3
Comment
Letter
Date Commenter
C42 3/25/2024 O'Neil, Carol
C43 3/25/2024 O'Neil, John
C44 3/24/2024 Pace, Andrea
C45 3/11/2024 Powell, Rebecca
C46 3/2/2024 Robbins, Gail
C47 3/6/2024 Roth, Tom
C48 3/21/2024 Smith, Geoff
C49 3/19/2024 Sorbo, Allen
C50 3/20/204 Stevenson, Stephanie
C51 3/25/2024 Thayer, Steven
C52 3/16/2024 Agrati, Linda
C53 3/17/2024 Villafranca, Lisa
C54 3/14/2024 Walton, Patricia
C55 3/17/2024 Washington, James
C56 3/1/2024 Agrati, Guy
C57 3/19/2024 Weitz, Gary
C58 2/29/2024 Weitz, Susan
C59 3/19/2024 Weitz, Susan
C60 3/25/2024 Wheatley, Sandra
C61 3/5/2024 Woehler, Markus
C62 3/22/2024 Zerbe, Laura
C63 3/25/2024 Zerbe, Lindley
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1925, Packet Page 2253 March 11, 2024
Christy Sabdo, AICP
Senior Associate Planner
City of Monterey, Planning Division
580 Pacific Street
Monterey, CA 93940
RE: Monterey 2031 General Plan Update Draft EIR Comments (SCH# 2023080034) Dear Ms. Sabdo:

Thank you for the opportunity to review Draft Environmental Impact Report (DEIR) and the Revised Draft Housing Element for the City of Monterey’s 2031 General Plan Update. The following comment is offered for your consideration.

In the 2023‐31 Housing Element, AMBAG requests the following revision:
 On page 3‐2 under section Regional Housing Needs Allocation, it states, “Monterey’s Regional Housing Needs Assessment (RHNA) allocation for the 2023‐31 planning period has been determined by ABAG to be…” Please revise “ABAG” to “AMBAG.” Thank you for the opportunity to review the DEIR for the 2031 General Plan Update. Please feel free to contact me at [email protected] or (831) 264‐5086 if you have any questions.

Sincerely,
Heather Adamson
Director of Planning
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1926, Packet Page 2254

SENT VIA ELECTRONIC MAIL
March 20, 2024
Christy Sabdo
Senior Associate Planner, AICP
City of Monterey
570 Pacific Street
Monterey, CA 93940
[email protected]
RE: DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR) FOR THE MONTEREY 2031 GENERAL PLAN UPDATE, DATED FEBRUARY 9, 2024 STATE
CLEARINGHOUSE # 2023080034
Dear Christy Sabdo,
The Department of Toxic Substances Control (DTSC) received a DEIR for the Monterey 2031 General Plan Update. The Proposed Plan is a targeted update to the Housing, Land Use, Safety, and Circulation Elements of the City of Monterey General Plan to respond to emerging issues and new State laws. It contains goals, policies, and programs to guide future development of up to approximately 5,800 units and 1,995 jobs within a Planning Area that encompasses approximately 8.67 square miles and

3.5 square miles of water. The Housing Element identifies suitable sites to accommodate the City's assessed share of the regional housing need through 2031 and incorporates strategies to remove barriers, further fair access to housing, and facilitate buildout of the sites. The Land Use Element introduces new land use designations and policies to foster mixed use neighborhoods and promote compatibility with airport and military operations. The Safety Element includes new data on natural ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1927, Packet Page 2255 hazards and climate change along with actions to strengthen community resilience and emergency evacuation capacity. The Proposed Plan also ensures consistency between the Land Use Element and newly adopted Monterey Regional Airport Land Use Compatibility Plan. The Circulation Element incorporates strategies for multi-modal mobility, roadway safety, and VMT reduction. Based on our project review, we request consideration of the following comments:

1. The proposed Project encompasses multiple active and nonactive mitigation and clean-up sites where DTSC has conducted oversight that may be impacted as a result of this Project. This may restrict what construction activities are permissible in the proposed Project areas in order to avoid any impacts to human health and the environment.

2. Due to the broad scope of the Project, DTSC is unable to determine the locations of the proposed sites, whether they are listed as having documented contamination, land use restrictions, or whether there is the potential for the sites to be included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Therefore, DTSC recommends providing further information on the proposed project and areas that may fall under DTSC's oversight within future environmental documents. Once received, DTSC may provide additional comments on the future environmental documets as further information becomes available. Please review the project area in Envirostor; DTSC’s public-facing database.

DTSC believes the City of Monterey must address these comments to determine if any significant impacts under the California Environmental Quality Act (CEQA) will occur and, if necessary, avoid significant impacts under CEQA. DTSC recommends the department connect with our unit if any hazardous waste projects managed or overseen by DTSC are discovered. Please refer to the City of Monterey EnviroStor Map for additional information about the areas of potential contamination DTSC appreciates the opportunity to comment on the Monterey 2031 General Plan Update. Thank you for your assistance in protecting California’s people and ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1928, Packet Page 2256 environment from the harmful effects of toxic substances. If you have any questions or would like any clarification on DTSC’s comments, please respond to this letter or via email for additional guidance.

Sincerely,
Tamara Purvis
Associate Environmental Planner
HWMP - Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
cc: (via email)
Governor’s Office of Planning and Research
State Clearinghouse
[email protected]
Dave Kereazis
Associate Environmental Planner
HWMP – Permitting Division - CEQA Unit
Department of Toxic Substances Control
[email protected]
Scott Wiley
Associate Governmental Program Analyst
HWMP – Permitting Division - CEQA Unit
Department of Toxic Substances Control
[email protected]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1929, Packet Page 2257 Z
March 25, 2024 MON/VAR
SCH# 2023080034
Christy Sabdo
Senior Associate Planner
City of Monterey
570 Pacific Street
Monterey, CA 93940

COMMENTS FOR THE DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR) – MONTEREY 2031

GENERAL PLAN UPDATE
Dear Ms. Sabdo:

The California Department of Transportation (Caltrans), District 5, Development Review, has reviewed the City of Monterey General Plan DEIR which contains goals, policies, and programs to guide the future development of up to approximately 5,800 units and 1,995 jobs within a planning area that encompasses approximately 8.67 square miles and 3.5 square miles of water. Caltrans offers the following comments in response to the DEIR:

1. Caltrans applauds the City of Monterey General Plan’s efforts to ensure that infrastructure is seamlessly integrated, well-connected, and supports all modes and users through a balanced multimodal transportation network. These measures will help meet statewide goals of reducing vehicle miles traveled and greenhouse gas emissions while supporting an equitable transportation network for all users.

2. We support the City of Monterey in adopting Policy 1.2. Increased densities affect the distance people travel and provide greater options for the mode of travel they choose. Increasing residential density results in shorter and fewer trips by singleoccupancy vehicles. 50 HIGUERA STREET | SAN LUIS OBISPO, CA 93401-5415
(805) 549-3111 | TTY 711
www.dot.ca.gov
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1930, Packet Page 2258

3. Caltrans appreciates the efforts to reduce employment-based VMT based on the strategies of CAPCOA’s Handbook for Analyzing Greenhouse Gas Emissions Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity.

Incorporating multiple of these strategies could result in an additional reduction in VMT under the proposed plan.

4. To continue to combat employment-based VMT, we encourage an increase in transit frequency on one or more transit lines serving the community. Increased transit frequency reduces waiting and overall travel times, improving the user experience and increasing transit service attractiveness. This results in a mode shift from single occupancy vehicles to transit.

5. Figure 3.9-5 shows both the projected sea level rise and coastal hazards.

Overlapping info makes it harder to identify anticipated conditions on the map.

We suggest breaking this single map into two different maps: 1) sea level rise and 2) coastal hazards.

Thank you for the opportunity to review and comment on the proposed project. If you have any questions or need further clarification on the items discussed above, please contact me at (805) 835-6543 or email [email protected].

Sincerely,
Jacob Hernandez
Transportation Planner
District 5 Local Development Review
Coordinator
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1931, Packet Page 2259 19 March 2024 SENT VIA EMAIL
Christy Sabdo
Senior Associate Planner
City of Monterey Planning Office
570 Pacific Street, 1st Floor
Monterey, CA 93940
Subject: REF240008 – City of Monterey 2031 General Plan Update Dear Ms. Sabdo,
Thank you for the opportunity to comment on the Draft EIR for the City of Monterey’s draft Housing, Land Use, Circulation, and Safety Elements. We’ve provided our comments below.

1. Planning Area: The planning area doesn’t appear to contemplate any of the unincorporated areas that are within Monterey’s sphere of influence. California Government Code Section 65300 requires a city to include in its General Plan all territory within the boundaries of the incorporated area as well as “any land outside its boundaries which in the planning agency’s judgment bears relation to its planning.” The Governor’s Office of Planning and Research (OPR) General Plan Guidelines recommend that when establishing a planning area, each city consider using it’s sphere of influence as a starting point, and building on that area based on other factors. As the sphere of influence is the probable physical boundaries and service area of the city (Gov. Code § 56076), it seems that it would have some relation to Monterey’s planning. While a broader planning effort for these areas is likely out of the scope of this update, we would suggest acknowledging the unincorporated sphere of influence in the planning area, and potentially land use element.

2. Agricultural Mitigation: MM-AG-1 suggests participation in the Monterey County Agricultural Conservation Mitigation Program. If this is in reference to the agricultural mitigation program currently being developed by the County, we don’t think that approach would be feasible at this time. The program has not been adopted, and as drafted does not appear to apply to the plan update:
a. It only applies to the inland areas of the unincorporated County. b. The mitigation is for Grazing Land, while our draft program defines Farmland to be Prime Farmland, Farmland of Statewide Importance, Unique Farmland, or Farmland of Local Importance (similar to CEQA Statute definition of Agricultural Land in Public Resources Code section 21060.1.).
c. The draft applies to changes in land use designation from an agricultural designation to a non-agricultural designation, or certain discretionary entitlements on properties with an agricultural land use designation and zoning.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1932, Packet Page 2260

3. Marina Coast Water District: Mitigation Measure MM-UTIL-2 states that the MCWD shall increase sources of water supply. Per CEQA Guidelines section 15126.4(a)(2), mitigation measures must be fully enforceable. We strongly encourage you to coordinate with the district if they are intended to be the party ultimately responsible for implementing this mitigation.

Please contact me with any questions at (831) 784-5731 or [email protected] Sincerely,
Phil Angelo, Associate Planner
Housing and Community Development – Planning
cc: Referral File
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1933, Packet Page 2261 March 25, 2024
Christy Sabdo
City of Monterey
580 Pacific Street
Monterey, CA 93940
RE: Monterey 2031 General Plan Update Draft
EIR Comments
Dear Ms. Sabdo:

Monterey-Salinas Transit District (MST) provides public transportation throughout the City of Monterey and operates a transit hub at the Monterey Transit Plaza, which provides connections to neighboring communities. MST is happy to see the City of Monterey advancing its General Plan and we look forward to being a community asset that will support the City’s goal of establishing a pedestrian and transitoriented city that is safe and equitable. MST has reviewed the Monterey 2031 General Plan Update Draft Environmental Impact Report (DEIR) and Notice of Availability (NOA) and would like to make the following comments for your consideration:

3.10 Land Use, Population, and Housing
To prevent substantial unplanned growth in areas of Monterey, MST recommends the General Plan include policies that would facilitate mixed-use and transit-oriented development within previously developed areas of Monterey. MST led a Transit-Oriented Development (TOD) Planning Study as a part of the planned SURF! Busway and Bus Rapid Transit project. The planning study identifies opportunities to increase TOD viability and ridership potential by enhancing multimodal connections within the SURF! Corridor through improved transit, bike and pedestrian facilities, and Transportation Demand Strategies (TDM). The Study’s goal is to decrease greenhouse gas (GHG) emissions, reduce vehicles miles traveled (VMT) from development, and make TOD more attractive for residents and developers in Monterey County.

MST’s Planning Study identified opportunity sites for TOD five study areas including the Monterey and Seaside area. These opportunity sites include sites in Laguna Del Rey, Del Monte Light Industrial, and North Fremont areas. MST recommends that the City of Monterey use MST’s TOD Planning Study as a resource to access potential for TOD. For more information regarding MST’s TOD Planning Study, please visit MST’s website: mst.org/about-mst/planning-development/ ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1934, Packet Page 2262

3.13 Transportation
Planned Transportation Network Changes
MST is in support of the City’s proposed bicycle, pedestrian, crosswalk and American with Disabilities Act (ADA) enhancements. 86% of MST passengers walk, bike, or scooter to access the bus. Therefore, it is crucial that all traffic calming, and active transportation enhancements be compatible with transit. Bus stop layouts and designs are evaluated using MST’s Designing for Transit Guidelines (2020) and all stops should adhere to these guidelines to ensure adequate access pertinent to the standards of the American with Disabilities Act (ADA). In addition, transit buses have a width of 10 feet 6 inches, and therefore need a minimum travel lane width of 11 feet. Lane width narrower than 11 feet will preclude service by MST.

Transportation Demand Strategies
MST is in support of the Transportation Demand Management (TDM) strategies included in the General Plan. TDM Strategies play a critical role in reducing automobile dependency and improving mobility choices. MST’s Transit-Oriented Development (TOD) Planning Study outlines TDM measures that can be implemented at the project/site, community/city, and transportation system management levels. Some of these strategies include:
• Employer Transit Pass Subsidy
• Shared Mobility Parking
• Street Connectivity Improvements
• Advanced Bicycle and Pedestrian Detection
MST recommends the City of Monterey use the TOD Study’s recommended TDM strategies to further the reduction of VMT.

Impact 3.13-2
MST is in support of Mitigation Measure VMT-1: Implement Commute Trip Reduction Program, which will offer business resources and incentives to reduce the number of single-occupancy vehicles (SOV) commuting to work. MST has programs available for individuals who are interested in using transit or vanpools for work. MST offers a Group Discount Program, which provides 31-Day MST GoPasses in bulk at a substantially reduced price. Businesses can enroll and offer bus passes to their staff to encourage transit use and reduce the number of SOVs.

MST recently partnered with Enterprise to offer vanpooling options for commuters traveling to or from Monterey County. Vanpools are open to the public and must have a minimum of four riders to receive a van or SUV from Enterprise. Participants can receive up to $450 monthly subsidy per vehicle if monthly ridership reports are completed. MST encourages the City of Monterey to participate in MST’s programs to extend VMT mitigation efforts.

Existing Transit System
MST submits the following comments pertaining to Page 3.13-5 of the Draft EIR:

Monterey-Salinas Transit District (MST) is the principal transit service for the city and the surrounding communities. MST is a joint powers agency special district with a board of directors that includes a representative from the City. Thirteen Eleven MST routes currently serve the citizens of the community.

The City-owned and maintained Simoneau Plaza located in downtown Monterey is the transfer center for all routes serving the city. The MST Trolley is an example of a tourist serving transit line which ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1935, Packet Page 2263 promotes the City’s “Park Once” program encouraging visitors to park once and reduce high demand to the transportation network. Senior and disabled citizens can use the MST fixed-route and Direct Area Response Transit (DART). MST also operated the RIDES program for disabled citizens. These routes operate on weekdays and Saturdays from approximately 7:00 AM to 11:00 PM 6:00 AM to 10:00 PM, and from approximately 7:30 AM to 5:30 PM 7:00 AM to 9:00 PM on Sundays and holidays weekends, and certain routes operate from approximately 7:00 AM to 7:00 PM on holidays.

Please note that the Direct Area Response Transit (DART) has been discontinued.

Closing
As the Monterey 2031 General Plan moves forward, we ask that the City of Monterey continue to collaborate with MST to ensure public transportation is available to Monterey’s residents. If you have any questions about the above comments, please do not hesitate to contact me at [email protected] or 831-264-9288.

Sincerely,
Emma Patel
Planning Manager
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1936, Packet Page 2264 City of Monterey
c/o Ms. Christy Sabdo, AICP

DEPARTMENT OF THE NAVY

NAVAL SUPPORT ACTIVITY MONTEREY
271 STONE ROAD
MONTEREY CA 93943-5189
City of Monterey Planning Division
580 Pacific Street
Monterey, CA 93940
Dear Ms. Sabdo:

IN REPLY REFER TO:
11000
Ser N00/074
March 22, 2024
SUBJECT: RESPONSE TO MONTEREY 2031 GENERAL PLAN UPDATE DRAFT EIR

COMMENTS REQUEST
Thank you for the City of Monterey's (City) consideration of the military mission and potential impacts associated with City policy changes. We acknowledge receipt of the notification and, currently, do not anticipate negative mission impact from your efforts.

We do, however, have minor suggested nomenclature adjustments for your consideration and have di�cussed them with City staff. Primarily, references in text and on mapping products to the Naval Postgraduate School (NPS) should be changed to Naval Support Activity Monterey when referencing the Navy's property itself (as we are proudly the home of, and therefore the physical location of, NPS).

Once the General Plan update is approved, we would encourage the City to take advantage of the vast array of federal grant opportunities available to it because of its proximity to multiple military installations. The Office of Local Defense Community Cooperation (www.oldcc.gov) has already supported the Monterey Regional Compatible Use Study and has several other programs, including the Defense Community Infrastructure Program (DCIP), that may prove to be of value in further General Plan policy implementation.

We recognize the immense undertaking of updating your General Plan document and its impact of defining the City's long-term development goals and vision. ·We look forward to continuing to work with you on future projects and partnership opportunities.

If you have further questions, please contact Ms. Marlana Brown, Community Planning Liaison Offic�r, at (831) 656-2475 / [email protected].

Sincerely,
#/4')�
ROBERT S. SMITH
Captain, U.S. Navy
Commanding Officer
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1937, Packet Page 2265

March 25, 2024
Christy Sabdo, AICP
Senior Associate Planner
City of Monterey Planning Division
580 Pacific Street
Monterey, CA 93940
Submitted via email to: [email protected]
Submitted by: Monterey Bay CNPS, P.O. Box 221303, Carmel, CA 93922 Re: Monterey Bay Chapter of the California Native Plant Society Comments on the Monterey 2031 General Plan Update Draft EIR
Dear Ms. Sabdo and the City of Monterey Planning Commission:

Thank you for the opportunity to comment on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report (DEIR). The following comments are submitted on behalf of the California Native Plant Society (CNPS), a non-profit environmental organization with over 12,500 members in 36 Chapters across California and Baja California, Mexico. CNPS’s mission is to protect California’s native plant heritage and preserve it for future generations through the application of science, research, education, and conservation. We work closely with decisionmakers, scientists, and local planners to advocate for well-informed policies, regulations, and land management practices.

The Monterey Bay Chapter of the California Native Plant Society (Chapter) supports the City of Monterey’s goal to adopt plans that provide opportunities for affordable housing development within the city as part of its proposed 2031 General Plan Update. Above all, the Chapter would like to see the City adopt a plan to streamline the development of housing for those with extremely low and very low incomes, as well as for the special housing needs of people who are elderly or disabled, farmworkers, and people experiencing homelessness, to meet its State-mandated Regional Housing Needs Allocation (RHNA) and facilitate the construction of desperately needed affordable housing in the city from now through 2031.

The Chapter is compelled to advocate for affordable housing and, of course, for the protection of threatened and endangered plant (and animal) species and incredibly rare and irreplaceable plant communities, including Maritime Chaparral, Coastal Prairie, Monterey Pine Forest, vernal pools, riparian woodlands, and wetland meadows, that are currently slated for development by the City’s General Plan Update in its current form.

California Department of Fish and Wildlife-designated “Sensitive Natural Communities,” as listed ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1938, Packet Page 2266 Monterey Bay Chapter of the California Native Plant Society Comments on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report
2 above, and an astoundingly large number (39!) of special-status plant and animal species known to occur or with the potential to occur in the City’s Planning Area, would be eliminated or severely impacted by the City’s current plans for commercial development and mostly non-affordable housing in the Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68 Opportunity Areas identified in the 2031 General Plan Update. We need to be emphatically clear here, these are veritable biodiversity hotspots that are being planned for development within this document.

These rare and irreplaceable habitats, and the threatened and endangered species they harbor, are protected by the California Environmental Quality Act (CEQA), the California Natural Community Conservation Planning Act, the federal Endangered Species Act, the California Endangered Species Act, the California Native Plant Protection Act, the Clean Water Act, the Migratory Bird Treaty Act, the Natural Community Conservation Planning Act, and the California Coastal Act. However, despite these facts, a comprehensive analysis of the anticipated impacts of implementing the City of Monterey’s 2031 General Plan Update, an essential requirement of the CEQA process, is nearly completely absent from this Draft Environmental Impact Report. This required comprehensive analysis of the impacts of the General Plan Update is so lacking, that the Monterey CNPS Chapter’s analysis of the proposed General Plan Update DEIR in this comment letter has been significantly impeded and curtailed due to the lack of essential information in the document.

A partial list of the special-status plant and wildlife species found either occurring or with the potential to occur in the City’s Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68 Opportunity Areas includes: the federally endangered Yadon’s rein orchid (Piperia yadonii), conservancy fairy shrimp (Branchinecta conservatio), the State and federally endangered Monterey clover (Trifolium trichocalyx), the State and federally threatened California tiger salamander (Ambystoma californiense), the federally threatened Monterey spineflower (Chorizanthe pungens var. pungens) and California red-legged frog (Rana draytonii), the federally endangered and state threatened Monterey gilia (Gilia tenuiflora ssp. arenaria), the federally endangered Smith’s blue butterfly (Euphilotes enoptes smithi), and many State Species of Special Concern including Monterey shrew (Sorex ornatus salarius), burrowing owl (Athene cunicularia), Monterey dusky-footed woodrat (Neotoma fuscipes luciana), Northern California legless lizard (Anniella pulchra), coast horned lizard (Phrynosoma blainvillii), two species of rare and endemic ceanothus, Monterey ceanothus (Ceanothus rigidus) and dwarf ceanothus (Ceanothus dentatus), and four species of rare and endemic manzanitas – Hooker’s (Arctostaphylos hookeri), Toro (Arctostaphylos montereyensis), Pajaro (Arctostaphylos pajaroensis, and sandmat (Arctostaphylos pumila). Just the names alone tell you how rare, local, and essentially “Monterey” many of these species are.

Many important species with the potential to occur within the Planning Area are completely absent from the DEIR including California tiger salamander, California red-legged frog, conservancy fairy shrimp, coast horned lizard, Monterey dusky-footed woodrat. These species are not mentioned nor evaluated.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1939, Packet Page 2267 Monterey Bay Chapter of the California Native Plant Society Comments on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report
3 The Monterey Bay Chapter of the California Native Plant Society writes in strong opposition to the elements of the 2031 General Plan Update which would lead to the destruction (i.e. being bulldozed) of the State-protected Sensitive Natural Communities found in the Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68 Opportunity Areas, including Monterey Pine Forest, Maritime Chaparral, Coastal Prairie, vernal pools and wetlands. The Chapter, with science-driven understanding and expertise, calls on the Planning Commission to identify and remove these highly sensitive areas from current development plans before approving the 2031 General Plan Update Draft Environmental Impact Report.

The project will have significant and irreversible impacts to the aforementioned biological resources, and the DEIR has failed to adequately establish baseline conditions and analyze the impacts to biological resources in the Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68 Opportunity Areas to justify, based on substantial evidence, that the proposed mitigation measures for biological impacts will be sufficient and effective. Below, we outline in greater detail the numerous issues related to the project in its current form and the deficiencies in the DEIR, and provide our conclusion that the project’s development plans and DEIR must be substantially revised prior to approval.

Ryan Ranch/Fort Ord Opportunity Area
The DEIR mentions that there is “a cluster of underutilized commercial properties north of Upper Ragsdale Road which presents opportunities for redevelopment.” DEIR mapping shows this over 150-acre strip of former Fort Ord lands zoned as “Mixed Use Neighborhood” (Figure 2-4: General Plan Land Use) and “Mixed Income” (Figure 2-6: Sites available for Housing) housing opportunity sites. However, these former Fort Ord lands contain some of the rarest and most imperiled habitat in the State, habitat that is found nowhere else on the planet – Central Coast Maritime Chaparral.

The specific type of Central Coast Maritime Chaparral along Upper Ragsdale Road and in the City’s plan for development is “Sandmat Manzanita Chaparral” and “Monterey Manzanita Chaparral.”1 These two extremely sensitive natural communities have the most imperiled California Department of Fish and Wildlife Sensitive Natural Community State ranking of “S1,” meaning that there are fewer than six viable occurrences of these plant communities in existence in California.

Sandmat manzanita (Arctostaphylos pumila) and Monterey manzanita (Arctostaphylos montereyensis), after which both plant communities above are named, are both native shrubs endemic (limited) to the Central Coast of California and both have a CDFW California Rare Plant Rank of 1B.2 (rare, threatened, or endangered in California and elsewhere).

However, with the exception of one DEIR map identifying Maritime Chaparral north of Upper Ragsdale Road, the mention of Maritime Chaparral in the text of the DEIR is completely and stunningly absent! The City of Monterey is planning on developing (i.e. bulldozing) one of the rarest and most imperiled habitats in California and there is absolutely no discussion of it in the

1 California Department of Fish and Wildlife Vegetation Classification and Mapping Program’s List of Sensitive Natural Communities, California Department of Fish and Wildlife’s California Natural Diversity Database, California Native Plant Society Manual of California Vegetation
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1940, Packet Page 2268 Monterey Bay Chapter of the California Native Plant Society Comments on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report
4 DEIR, let alone a comprehensive review, analysis, and full mitigation program to address the project’s anticipated impacts on this sensitive natural community, and the 39 special-status plant and animal species with the potential to occur here, as required by the California Environmental Quality Act2,3.

Much like Coast Redwood Forest, the Central Coast Maritime Chaparral plant community thrives within the zone of coastal summer fog – a local meteorological phenomenon with which it evolved and depends on, along with wildfire, for its continuance.4Mixed within the Maritime Chaparral are patches of Coast Live Oak woodland, another sensitive natural community. The Maritime Chaparral ecosystem is characterized by endemic species of Arctostaphylos (manzanita) and Ceanothus, which mostly reproduce by seed rather than resprouting and require fire to regenerate.

Animal species that are present in Central Coast Maritime Chaparral include: Monterey duskyfooted woodrat (Neotoma fuscipes luciana) a State Species of Special Concern, California deer mouse (Peromyscus californicus), brush rabbit (Sylvilagus bachmani), California quail (Callipepla califonica), Heerman kangaroo rat (Dipodomys heermanni), California ground squirrel (Spermophilus beecheyi), California mule deer (Odocoileus hemionus californicus), raccoon (Procyon lotor), bobcat (Lynx rufus), red-tailed hawk (Buteo jamaicensis), and northwestern fence lizard (Sceloporus occidentalis occidentalis)
5 .

Insect species, such as beetles, ants, bumble bees, flies, moths, and butterflies are abundant in maritime chaparral and some species function as important pollinators for the flowering shrub species. Ground-inhabiting beetles include species from the Carabidae and Staphylinidae families, which prey on small arthropods and other organisms, and species from the Tenebrionidae family, which are mostly scavengers. Seed-gathering ants are an important part of the chaparral ant population. The flower-visiting insects consist of the bees, flies, moths, butterflies, and some beetles6
.

The Central Coast Maritime Chaparral is highly threatened by coastal residential development, urbanization, and agricultural development, along with fire suppression which prevents

2 An essential requirement of the California Environmental Quality Act requires local agencies to review, analyze, and mitigate a project’s anticipated impacts and determine if the project “would have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Game or US Fish and Wildlife Service (CEQA Appendix G, Public Resources Code sections 21083 and 21083.09).
3 Sensitive Natural Communities are protected by the California Environmental Quality Act and the State’s Natural Community Conservation Planning Act.
4 In 2010 researchers revealed that summertime fog hours had declined by 33% over the last century. Natural resource managers working to protect California’s coastal plant and animal communities in the face of a warming climate are alarmed (USGS, The Pacific Coastal Fog Project 2017). 5 Quinn, Ronald D., Habitat Preferences and Distribution Of Mammals In California Chaparral, Berkeley, CA: Pacific Southwest Research Station, Forest Service, U.S. Department of Agriculture, Research Paper PSW-202, 1990. 6 Force, Don C., Ecology of Insects in California Chaparral, Berkeley, CA: Pacific Southwest Research Station, Forest Service, U.S. Department of Agriculture, Research Paper PSW-201, 1990.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1941, Packet Page 2269 Monterey Bay Chapter of the California Native Plant Society Comments on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report
5 reproduction and eliminates stands. Common stressors and threats include fragmentation of the habitat by housing and roads, and nearby housing and agriculture may make utilization of prescribed fire nearly impossible. Exotic, invasive weeds, including pampas grass, iceplant, French broom, and blue gum eucalyptus also threaten many occurrences of Central Coast Maritime Chaparral. Maritime Chaparral is likely more densely invaded by exotics than other chaparral types because it is more densely fragmented by roads and thus closer to human disturbance and sources of exotic seeds7
. The California Coastal Commission estimates that only 1700 acres of Central Coast Maritime Chaparral remains in California and has adopted a policy that seeks to “ensure that Central Coast Maritime Chaparral is protected and allowed to thrive.” In addition to the extremely rare Central California Maritime Chaparral present in the Ryan Ranch/Fort Ord Opportunity Area, the site supports Monterey Pine Forest, another sensitive Natural Community considered rare by the California Department of Fish and Wildlife. Monterey Pine Forest occurs naturally in the state in only three coastal populations and the local Monterey stands support a number of special status species, including the federally endangered Yadon’s piperia (Piperia yadonii). This orchid and two other native orchid species (Piperia elongata and Piperia michaelii) have been documented by the Chapter in the Monterey Pine Forest habitat south of South Boundary Road in the former Fort Ord.

Although the Central Coast Maritime Chaparral and Monterey Pine Forest lands are not part of proposals currently in the City’s pipeline for housing development, the Draft Housing Element calls for the “[P]reparation of a specific plan to guide future residential and mixed-use development in the Fort Ord/Ryan Ranch area, identify infrastructure needs and financing mechanisms, and establish measures to ensure sustainable development and adequate resource protection.” The City has long hoped to develop the Maritime Chaparral and Monterey Pine Forest lands between South Boundary Road and Upper Ragsdale Road. This land was transferred to the City by the U.S.

Army as part of the Fort Ord Base Reuse Plan as a nominal means to offset economic losses incurred by the base closure. However, this does not preclude the need to conduct a full CEQArequired comprehensive review, analysis, and full mitigation program to address the project’s anticipated impacts on the biological resources of the Central Coast Maritime Chaparral and Monterey Pine Forest. Nor does it preclude the public’s ability to decide if they still want to develop this biodiversity hotspot in the face of an unprecedented and unfolding extinction crisis.

Garden Road/Airport/Highway 68 Opportunity Areas
The Garden Road/Airport/Highway 68 Opportunity Area includes the highly scenic Tarpey Flats, the visually stunning and historically significant gateway to the Monterey Peninsula from Highway

68. Tarpey Flats is the last remaining undeveloped marine terrace in the Monterey Peninsula region and must be appropriately considered in the Scenic Vistas and visual resources section of the DEIR. The scenic Tarpey Flats area provides visually important vistas across undeveloped Coastal Prairie towards the Monterey Pine Forests of Jacks Peak and the Joyce Stevens Monterey Pine Preserve.

7 NatureServe Website 2023
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1942, Packet Page 2270 Monterey Bay Chapter of the California Native Plant Society Comments on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report
6 The Garden Road/Airport/Highway 68 Opportunity Area (north and south of Highway 68) contains rare Coastal Prairie, Vernal Pool, Monterey Pine Forest, wetland, and riparian habitats. Yet the DEIR not only fails to specifically locate and identify these “Sensitive Natural Communities” on DEIR maps but also fails to review, analyze, and mitigate the City’s housing and development plan’s anticipated impacts as required by the California Environmental Quality Act. The DEIR mentions that “both valley needlegrass grassland and coastal prairie occur within the Planning Area” but no analysis or mitigation is given. Analysis and mitigation is also missing for all sensitive natural communities within the 2031 General Plan Update DEIR.

In the truncated biological resources impact analysis, the DEIR states that “a significant impact would occur if the Proposed Plan would have a substantial adverse effect on State or federally protected wetlands, including, but not limited to, marsh, vernal pool, coastal [sic], etc.), through direct removal, filling, hydrological interruption, or other means.” Yet, despite mentioning the presence of wetlands within the Planning Area, and the fact that development of these wetlands would likely lead to their elimination, Impact 3.4-3 of the DEIR, addressing State or federally protected wetlands, states that project impacts would be “less than significant” and no mitigation measures are required. These are irrefutable and egregious violations of the California Environmental Quality Act and State and federal laws protecting wetlands.

One of the many ways in which the DEIR has failed to adequately analyze the General Plan Update’s anticipated impacts to botanical resources is the fact that recent, comprehensive protocol-level floristic surveys for special-status plants and sensitive natural communities have not been performed (along with special-status wildlife surveys) in the Coastal Prairie, Monterey Pine Forest, Oak Woodland and wetland habitats that occur in the Tarpey Flats area south of Highway

68. The DEIR’s only means to address the impacts to special-status species is “Mitigation Measure BIO-1: Conduct Preconstruction Surveys for Special Status Species.” These last minute assessments would presumably be an individual developer’s responsibility. The responsible parties are not specified in the DEIR nor are the subsequent required mitigation measures required by State and federal environmental protections laws should special-status species or sensitive natural communities be identified on a development site.

Relying on preconstruction surveys to determine the presence or absence of special-status species that the DEIR has identified as having the potential to occur on the site is entirely inadequate.

Deferring biological studies until after project approval in this manner prevents public comment and oversight over the protection of these species, and runs afoul of CEQA’s requirement that the lead agency analyze and disclose a project’s impacts to the public before the project is approved.

The lack of botanical and wildlife surveys also precludes the development of species-specific mitigation measures that have been reviewed and vetted by the responsible agencies and the public prior to the approval of the project, a core requirement of CEQA.

Floristic surveys are the only way to confirm the presence or absence of special-status species ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1943, Packet Page 2271 Monterey Bay Chapter of the California Native Plant Society Comments on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report
7 within the project area, and are the only way to ensure that the full scope of impacts to specialstatus plants is being captured in the City’s analysis. By not performing protocol-level surveys in the face of the evidence that numerous special-status plants have potential to occur on the project site, the City has failed to establish the environmental setting. This is a fundamental flaw in the DEIR for the 2031 General Plan Update. EIRs, programmatic or not, are required to describe the baseline physical conditions on the project site through which the lead agency will determine whether an impact is significant (CEQA Guidelines, § 15125(a)(1)). The failure to conduct floristic surveys8
, as well as special-status wildlife surveys, precludes the City from being able to accurately establish the baseline physical conditions, and thereby prevents the EIR from meeting CEQA’s mandate of making an evidence-based determination of the project’s impacts to botanical resources and mitigating those impacts if they are significant.

Protocol-level surveys for evaluating impacts to Sensitive Natural Communities, also required by CEQA, are not even mentioned in the DEIR9. Additionally, the need to obtain mandatory Incidental Take Permits from the U.S. Fish and Wildlife Service and the California Department of Fish and Wildlife for “take” (harm or kill) of listed species is not discussed in the DEIR, nor is the need for a fully developed and approved Habitat Conservation Plan that ensures that the effects of the authorized incidental take are adequately minimized and mitigated for the listed species.

The approval of a U.S. Fish and Wildlife Habitat Conservation Plan requires extensive baseline biological surveys of listed species on the project site to support the conservation strategy, including multi-year floral surveys of listed plant species10. The Habitat Conservation Plan will also mandate expensive compensatory mitigation for impacts to these species and their habitat as permits require the preparation and implementation of a long-term mitigation and monitoring plan including a take assessment, compensatory mitigation lands, success criteria, and funding assurances along with mitigating impacted sensitive natural community habitat offsite at a minimum 3:1 ratio through preservation, restoration,11 and/or a conservation bank.12,13

8 Botanical field surveys provide information used to determine the potential environmental effects of a proposed project on special status plants and sensitive natural communities as required by law (Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities. 2018. State of California Natural Resources Agency, Department of Fish and Wildlife). 9 California Department of Fish and Wildlife’s (CDFW) Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities 10 The USFWS and CDFW must be able to describe and analyze the effects of the proposed covered activities on the covered species to issue incidental take coverage for each species. Estimates of the number of individuals of each covered species that a development project will “take” must be provided. This cannot be done without sufficient baseline biological studies (U.S. Fish and Wildlife Service Form 3-200-56). 11 “CDFW generally does not support the use of translocation, transplantation, or salvaging plants as the primary mitigation strategy for unavoidable impacts to plants composing a sensitive plant community. Studies have shown that these efforts are experimental and the outcome unreliable. Transplantation to mitigate for impacts to sensitive plant communities may be unsuccessful when mitigation does not account for abiotic and biotic components of a plant community. Abiotic variables such as hydrologic regime, soil type, microclimate, slope, aspect, and elevation determine where a plant community occurs. Plant communities are not merely plants but also consist of pollinators and microscopic biota such as detritovores, cyanobacteria, lichens, algae, and microfungi. Abiotic and biotic variables are rarely considered during mitigation site selection or when developing a ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1944, Packet Page 2272 Monterey Bay Chapter of the California Native Plant Society Comments on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report
8 This programmatic DEIR is insufficient with the fact that in terms of the program’s impact on special status plants and sensitive natural communities, this DEIR is not “programmatic,” as it should be, at all. The California Code of Regulations Section 15168 states that a program EIR should “provide a description of planned activities that would implement the program and deals with the effects of the program as specifically and comprehensively as possible. With a good and detailed project description and analysis of the program, many later activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required.”
Instead of describing in this DEIR the potential or likely effects of the City’s development plans on special-status plants and sensitive natural communities as specifically and comprehensively as possible and requiring the City to develop a Habitat Conservation Plan for impacts to special-status species and Sensitive Natural Communities in order to obtain required Incidental Take Permits from the U.S. Fish and Wildlife Service and the California Department of Fish and Wildlife, this “programmatic” DEIR dodges its responsibility of streamlining affordable housing and presumably directs subsequent individual project developers to obtain their own Incidental Take Permits for development projects instead of tiering from this General Plan Update (again, with no mention of extensive biological studies, habitat conservation plans, compensatory mitigation, funding assurances, monitoring, and the need for “No Surprises” assurances).

To be serious about streamlining affordable housing, as required by the State of California Housing Element Law, this 2031 General Plan Update Draft EIR must direct the City to work with the U.S.

Fish and Wildlife Service and California Department of Fish and Wildlife to develop a conservation plan and obtain take permits for potentially occurring special-status species in a holistic and comprehensive manner. It is very unlikely that the wildlife agencies will allow piecemeal biological studies and permitting on these very sensitive Central Coast Maritime Chaparral, Coastal Prairie, Monterey Pine Forest, vernal pool, wetland and riparian habitats.

While the 1997 Habitat Management Plan provides a framework for species and habitat conservation on former Fort Ord, it does not meet U.S. Fish and Wildlife Service or California Department of Fish and Wildlife standards or requirements for an application soliciting the issuance of Incidental Take Permits. The more recent Fort Ord Multi-Species Habitat Conservation Plan, drafted but never adopted, was intended to fulfill those requirements by combining key

conservation plan. This may result in a project never being able to replace the plant community that was impacted.

Lastly, transplanting or establishing plants could be unsuccessful without sufficient investment to the restoration site.” CDFW Site Plan Review 20-009 Project, Mitigated Negative Declaration, SCH #2021010230, City of Palmdale, Los Angeles County.
12 The California Native Plant Society believes that the acquisition and permanent protection of an alternative parcel does not alter the fact that the loss of the initial site brings the rare habitat and species one step closer to ultimate extinction (CNPS Policy on Mitigation Guidelines Regarding Impacts to Rare, Threatened, and Endangered Plants (CNPS Rare Plant Scientific Advisory Committee, revised 1998). 13 California Department of Housing and Community Development (HCD) best practices for choosing RHNA sites requires that sites do not require environmental mitigation (HCD Housing Element Site Inventory Guidebook).

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9 components of the Habitat Management Plan with additional elements to ensure compliance with the Endangered Species Act and the California Endangered Species Act, thereby serving as a basis for issuance of base-wide Incidental Take Permits by the U.S. Fish and Wildlife Service and California Department of Fish and Wildlife.

Additional constraints to using the former Fort Ord properties to meet the City’s housing goals are numerous and generally beyond the scope of CNPS expertise and analysis, however we feel compelled to address the issues of Unexploded Ordnance (UXO), toxic soils, and environmental justice. Unexploded Ordnances, including bombs, artillery, mortar, rocket and small arm ammunitions, mines, demolition charges, pyrotechnics, grenades, high explosives, and propellants, are still potentially on the project site within the Ryan Ranch/Fort Ord Opportunity Area. This site is also seriously constrained by a “State Covenant to Restrict Use of Property with the Army” that the City is currently bound by. It is likely that the Fort Ord lands were never sufficiently cleared of UXO and hazardous materials to allow housing development.

A major constraint to any housing development, the existing covenant prevents the following types of use for the former Fort Ord properties: residential use, day care facilities that do not have measures to prevent contact with soil, schools for persons under 21 years of age, and hospitals (other than veterinary hospitals). To allow housing development, the covenant needs to be lifted by the California Department of Toxic Substances Control (DTSC). The DEIR fails to mention any correspondence with the DTSC in preparing the document and whether they may be willing to lift the covenant, what environmental studies might still be needed to do so, what type of cleanup is needed, and what kind of timeline any or all of this may take.

A comment letter from DTSC to the City concerning the 2031 General Plan Update DEIR, dated March 20, 2024 (Clearinghouse #2023080034), states that “[D]ue to the broad scope of the Project, DTSC is unable to determine the locations of the proposed sites, whether they are listed as having documented contamination, land use restrictions, or whether there is the potential for the sites to be included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Therefore, DTSC recommends providing further information on the proposed project and areas that may fall under DTSC's oversight within future environmental documents.” The letter concludes “DTSC believes the City of Monterey must address these comments to determine if any significant impacts under the California Environmental Quality Act (CEQA) will occur and, if necessary, avoid significant impacts under CEQA.” The very real possibility that DTSC and the binding covenant will ultimately not allow housing development is reason enough to remove the former Fort Ord lands along Upper Ragsdale Road and South Boundary Road from their list of housing opportunity sites in the General Plan Update.

A UXO and hazardous materials cleanup by DTSC to a level sufficient for future families to live in health and safety may actually be an impossibility.

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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1946, Packet Page 2274 Monterey Bay Chapter of the California Native Plant Society Comments on the City of Monterey’s 2031 General Plan Update Draft Environmental Impact Report
10 California State Senate Bill 100014 – Environmental Justice in Local Land Use Planning – requires local governments to identify environmental justice communities (called "disadvantaged communities") in their jurisdictions and address environmental justice in their general plans and housing elements. The State’s Attorney General is working to ensure local governments comply with Senate Bill 100015. The DEIR does not even mention environmental justice or address the very real environmental justice issue of planning housing for very low income households on lands that potentially have UXO and hazardous materials not sufficiently cleaned up on them. The potential environmental injustice that this program represents needs to be fully analyzed and resolved.16 The undetermined and unspecified time needed to resolve these constraints within the Housing Element’s eight year planning period are not discussed in the DEIR and run afoul of State Housing Element Law.

Former military bases are some of the most polluted and toxic sites in the country. The entire former Fort Ord is still on the Superfund list, a “list of sites of national priority among the known releases of hazardous substances, pollutants, or contaminants throughout the United States.”17 It is fairly well known that hazardous and toxic waste materials at the former Fort Ord consist of a wide variety of materials including industrial chemicals, petrochemicals, domestic and industrial wastes (landfills), asbestos and lead paint in buildings, above- and underground storage units, and ordnance and explosives.

Planning to build affordable housing for the poorest families in the community on land where housing is still prohibited due to insufficient clearing of UXO and hazardous wastes would be a newsworthy example of environmental injustice in the State’s Housing Element program. It appears unknown to anyone if or when the DTSC will ever be able to clean up the former Fort Ord lands to a level where children can safely play ball in their yards or neighborhood parks.

The Monterey Bay Chapter of the California Native Plant Society respectfully urges the City to comprehensively revise the 2031 General Plan Update and Draft Environmental Impact Report to adequately identify, review, analyze, and mitigate the project’s anticipated impacts on State and federally protected plant and wildlife species and the rare habitats they depend upon, as an essential requirement of the California Environmental Quality Act.

A close examination of this DEIR points to the conclusion that the City cannot use the Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68 Opportunity Areas as housing opportunity sites to meet its RHNA requirements, principally because of the large number of environmental constraints (many of which may potentially be irresolvable) that prohibit the streamlining of affordable housing development.

14 Senate Bill 1000 – California Government Code of Regulations Section 65302(h). 15 State of California Department of Justice, Bureau of Environmental Justice (https://oag.ca.gov/environment/justice)
16 American Institute of Certified Planners Code of Ethics and Professional Conduct https://www.planning.org/ethics/ethicscode/
17 epa.gov
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11 The California Department of Housing and Community Development states the “For each policy, procedure, or requirement identified as a constraint, the housing element must include programs to address and remove or mitigate the constraint.” However, the Housing Element Update and DEIR do not even clearly identify many of these constraints and offer no sufficient measures or realistic timelines to remove or mitigate the constraints.

With so many environmental constraints to development, many potentially irresolvable, the Ryan Ranch/Fort Ord and Garden Road/Airport/Highway 68 Opportunity Areas should be removed from the 2031 General Plan Update as opportunity sites for future development. We request that the City conduct the appropriate studies to determine if the public would be best served by conserving these sensitive natural communities for current and future generations to appreciate and treasure.

Thank you for the opportunity to comment on the Monterey 2031 General Plan Update and Draft Environmental Impact Report. We would welcome any opportunity to meet with the Planning Commission and further discuss the issues we have raised on the inadequacies of the Draft Environmental Impact Report’s analysis of potential impacts of the plan on biological resources.

Sincerely,

Patrick Furtado, M.S. Brian LeNeve
Conservation Committee Chair Chapter President
Monterey Bay Chapter Monterey Bay Chapter
California Native Plant Society California Native Plant Society [email protected] [email protected]
CC:

California Department of Housing and Community Development, Land Use and Planning Unit California Department of Fish and Wildlife, C/O Evelyn Barajas-Perez, Environmental Scientist California Environmental Protection Agency (CalEPA), Department of Toxic Substances Control (DTSC) California Department of Justice, Office of the Attorney General, Bureau of Environmental Justice California Environmental Protection Agency (CalEPA), Environmental Justice Program California Central Coast Regional Water Quality Control Board U.S. Fish and Wildlife Service, C/O Mark Ogonowski, Ventura Office Monterey County Housing and Community Development, C/O Fiona Jensen, Senior Planner Monterey County Weekly
Center for Biological Diversity
LandWatch Monterey County
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1948, Packet Page 2276 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1949, Packet Page 2277 3/21/24, 2:40 PM Mail - Christy Sabdo - Outlook
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ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1950, Packet Page 2278 P.O. Box 1876, Salinas, CA 93902-1876 | 831-759-2824 | www.landwatch.org | [email protected] March 21, 2024
Christy Sabdo, AICP
Senior Associate Planner
City of Monterey Planning Division
580 Pacific Street
Monterey, CA 93940
[email protected]
Re: Monterey 2031 General Plan Update Draft EIR Comments Dear Ms. Sabdo:

LandWatch Monterey County supports a housing element that provides dense, infill housing in existing urbanized areas affordable to those who live and work in the City of Monterey.

Environmental justice demands affordable housing that minimizes environmental harms.

Accordingly, LandWatch urges the City to adopt the Relocated Housing Alternative, which would provide denser infill housing sufficient to meet the City’s 6th Cycle Regional Housing Needs Allocation (RHNA) while avoiding significant environmental impacts to the City’s natural lands in the former Fort Ord.

While we appreciate inclusion of the Relocated Housing Alternative in the draft EIR (DEIR), the DEIR is inadequate under CEQA. It fails to disclose the scope of the water supply and biological resource impacts that the proposed project would cause in the former Fort Ord.

Moreover, the DEIR presents an inadequate analysis of the Relocated Housing Alternative. It erroneously fails to find this alternative environmentally superior despite the EIR’s own detailed comparisons of its impacts. It also erroneously concludes that it would provide insufficient lower income housing.

The DEIR’s water supply analysis does not meet CEQA’s legal requirement to provide an accounting of supply and demand. The mandatory SB 610 Water Supply Analysis simply omits the demand from the Marina Coast Water District (MCWD) service area in Fort Ord. The DEIR’s reliance on MCWD’s 2020 Urban Water Management Plan (UWMP) instead cannot cure this error because it does not constitute a valid Water Supply Analysis and because the now dated 2020 UWMP admittedly fails to include the proposed new demand for residential water supplies from the City.

The 2020 UWMP also omits new demand from other jurisdictions in the former Fort Ord. Because ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1951, Packet Page 2279 2 the DEIR does not provide an accurate accounting of the Fort Ord demand and supply for this project or other cumulative projects, it does not and cannot disclose the magnitude of the water supply shortfall.

The DEIR’s water supply analysis for Fort Ord also fails to acknowledge and assess two critical constraints on the City’s access to water for Fort Ord. First, the DEIR fails to disclose that, under its settlement agreement with LandWatch and Keep Fort Ord Wild, MCWD cannot provide new residential hookups for Fort Ord housing development because it is bound by a 6,160-unit cap on new residential hookups, a limitation that has already been reached. Second, the DEIR fails to disclose that the City’s entitlement to MCWD groundwater is limited to 65 AFY, an amount that is woefully inadequate to supply the 1,660 houses the proposed project would locate in Fort Ord.

The DEIR proposes illusory water supply mitigation in the form of an unenforceable directive to MCWD, an independent agency, that MCWD provide more water by resuming production from its mothballed desalination facility and by undertaking a new water supply project. The DEIR also inconsistently concludes that there will be no impacts from new water supply facilities, even though the Mitigation Measure UTIL-2 purports to demand that MCWD provide a new facility.

The EIR admits that MCWD has no funding or plan to provide additional water supplies to Fort Ord and that no other feasible water supply source has been identified. In light of this admission, the City cannot legally include the Fort Ord housing units in its Housing Element. The Housing Element Law requires that an adequate water supply for proposed units must “be included in an existing general plan program or other mandatory program or plan, including a program or plan of a public or private entity providing water or sewer service. . ..” (Gov. Code, § 65583.2(b)(5)(B).) This requirement is not met.

The DEIR’s discussion of biological resource impacts is inadequate because it lacks essential environmental setting information as to the locations and extent of sensitive species and fails to acknowledge the presence of sensitive natural communities in the majority of the lands proposed for development. It also fails to disclose the extent of wetlands and the additional constraints on development imposed by federal protection of upland areas used by the California Tiger Salamander. It also relies on outdated and incomplete data sources that fail to disclose that the City’s Fort Ord land is a major wildlife corridor. Without this setting information, the EIR cannot and did not assess the significance of impacts or the feasibility of avoidance and minimization measures that would be required for development, including the likelihood that impacts would remain unavoidably significant because mitigation is simply infeasible.

The DEIR assesses two substantive alternatives to the proposed project. The Increased Workforce Housing Alternative would increase housing units but forgo development of 50 acres of grazing land. The Relocated Housing Alternative would forgo Fort Ord development and increase the density of development in already-urbanized areas to replace this housing. The DEIR’s comparison of these two alternatives is flawed. Its conclusion that the Increased Workforce Housing Alternative is environmentally superior is directly contradicted by its detailed comparisons of the proposed project and the alternatives. The Relocated Housing Alternative reduces more significant impacts ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1952, Packet Page 2280 3 than the Increased Workforce Housing Alternative (seven rather than five), and it causes no increase in the severity of other significant impacts, whereas the Increased Workforce Housing Alternative aggravates four other significant impacts. Clearly, the Relocated Housing Alternative is environmentally superior.

Finally, the EIR’s conclusion that the Relocated Housing Alternative would not provide sufficient lower income units to meet the City’s RHNA obligation is unsupported and incorrect. The Relocated Housing Alternative is supposed to increase densities in five already urbanized areas in order to relocate the Fort Ord units. But the EIR unaccountably assumes that the Fort Ord units would not be relocated despite the increased density. In fact, the increased densities of the areas already identified for lower income units in these five urbanized areas under the proposed project would provide 388 more lower income units, more than making up for the 220 lower income units proposed for Fort Ord.

Indeed, it is the proposed project that would not provide sufficient lower income units, because the EIR admits that only 240 market rate units could be developed during the 6th Cycle, which would provide only 24 lower income units under the proposed inclusionary housing ordinance. Unlike the Relocated Housing Alternative, the proposed project would therefore fall short of the RHNA goal for lower income units.

Our detailed comments follow. LandWatch staff and consultants would be delighted to meet with you to review our comments and analysis.

A. Fort Ord lacks sufficient water supplies for the proposed housing, and the DEIR’s water supply analysis is inadequate.

The project description includes capacity for 5,787 residential units, of which 1,660 would be in the Fort Ord/Ryan Ranch area. (DEIR, pp. 2-10, 2-15.) Buildout of these 5,787 units is assumed by the horizon year 2031. (DEIR, p. ES-4, 2-21, 2-25.) Water supply for the Fort Ord area would be provided by Marina Coast Water District (MCWD) and for the rest of the project by Cal-Am. (DEIR, pp. 3.14-1, 3.14-6.)
Even though Fort Ord and Ryan Ranch would have different water suppliers, the EIR and the Site Inventory treat the Fort Ord/Ryan Ranch area as a unit. (DEIR, p. 2-15, GPU, Appendix A, Sites Inventory [listing 1,660 units for six parcels identified as within “Ryan Ranch/Fort Ord”].) However, it appears that the bulk of the combined Ryan Ranch/Fort Ord housing site – three City owned parcels totaling 93.69 acres - is in fact in Fort Ord. It appears that the other three privately owned parcels totaling 3.3 acres may be in Ryan Ranch. If the Fort Ord housing units on 93.69 acres were at the same density as the Ryan Ranch units on 3.3 acres, then 94% of the units – or 1,555 units – would be on Fort Ord land and be serviced by MCWD.

Preliminarily, we note that the EIR’s failure to disaggregate unit counts by water supplier renders the project description inadequate to support necessary analysis. Furthermore, the site inventory’s identification of at most 96.99 acres of housing site land in the combined Ryan Ranch/Fort Ord ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1953, Packet Page 2281 4 area is inconsistent with the description in the EIR of Fort Ord as containing “approximately 127 acres of vacant land . . . potentially available for development with housing and other uses.” (DEIR, p. 2-14.)
CAL-AM SERVICE AREA: Based on a Water Supply Assessment from Cal-Am, the EIR concludes that the water supply impact in the Cal-Am service area would be significant and unavoidable because, Cal-Am claims that without its proposed desalination project demand would exceed supply in some years. (DEIR, pp. 3.14-24 to 3.14-27.) The EIR does not disclose that Cal-Am’s supply and demand analysis is contested by the Monterey Peninsula Water Management District, MCWD, and Monterey One Water and that the California Public Utilities District is in the midst of proceedings in which these public agencies are challenging Cal-Am’s supply and demand analysis.

MCWD SERVICE AREA: Based on the 2020 MCWD Urban Water Management Plan, the EIR concludes that the water supply impact in the MCWD service area, i.e., Fort Ord, would be significant and unavoidable because MCWD “does not currently have a plan or funding in place” to provide sufficient water supplies. (DEIR, p. 3.14-28.)

1. Inclusion of Fort Ord sites in the Site Inventory violates the Housing Element Law because there is no existing or mandatory plan or program for providing water.

The Housing Element Law requires that an adequate water supply must “be included in an existing general plan program or other mandatory program or plan, including a program or plan of a public or private entity providing water or sewer service. . ..” (Gov. Code, § 65583.2(b)(5)(B).) Whereas CalAm does have a program or plan to supply water, albeit in unnecessary quantities, the EIR admits that MCWD does not. In particular, the EIR states that “MCWD does not currently have a plan or funding in place to reactivate the pilot seawater desalination plant or procure additional supply from Phase 2 of the Pure Water Monterey Expansion Project. No other feasible sources of additional water supply have been identified. Therefore, this impact is considered significant and unavoidable.” (DEIR, pp. 3.14-28 to 3.14-29.)
Furthermore, as discussed below, MCWD has never planned to supply more than 65 AFY to Monterey. Also, as discussed below, MCWD is barred from providing more than 6,160 hookups for new residential units and MCWD has already committed to those hookups.

2. The Water Supply Assessment is inadequate under SB 610 and CEQA. a. Legal requirements under CEQA and SB 610 for supply and demand accounting An agency proposing a development of more than 500 residential units must prepare or have prepared a Water Supply Assessment (WSA). (Water Code, § 10912(a)(1).) The WSA must disclose “whether the total projected water supplies, determined to be available by the city or county for the project during normal, single dry, and multiple dry water years during a 20-year projection, will meet the projected water demand associated with the proposed project, in addition to existing and ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1954, Packet Page 2282 5 planned future uses, including agricultural and manufacturing uses.” (Water Code, § 10910(c)(3), (4).)
CEQA case law also requires that an agency disclose the sufficiency of available supply to meet demand from a project, existing users, and foreseeable future users. The California Supreme Court has held that a “discussion of total supply and demand is necessary to evaluate ‘the long-term cumulative impact of development on water supply.’” (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 441.) Vineyard holds that it is not sufficient to cite demand and supply data in related planning documents without reconciling their inconsistencies with the EIR’s assumptions and presenting a clear picture of the sufficiency or insufficiency of the water supply to meet the demand identified in the EIR for the project. While an EIR may ultimately conclude that the water supply is uncertain, it must provide a consistent and coherent account of project demand and how that demand is reflected in the related planning documents on which it relies. The Vineyard EIR failed to meet the obligation to show at least a rough balance between water supply and demand because it failed to explain and reconcile the differing water demand assumptions in a related planning document on which it relied, the Water Forum FEIR, and the demand assumptions in the project EIR itself. (Vineyard at 439.) Such “factual inconsistencies and lack of clarity” preclude substantial evidence to support conclusions about water supply and demand. (Id.) It is not sufficient for informed decision making to present “seemingly inconsistent figures for future total area demand and surface water supply, with no plainly stated, coherent analysis of how the supply is to meet the demand.” (Id. at 445; see also 447 [failure to show how inconsistent supply and demand figures “match up” “results in a lack of substantial evidence”].)
Where there is an adverse impact due to a shortfall in water supplies, it is not sufficient simply to label this impact significant and unavoidable; the EIR must contain “some information about how adverse the adverse impact will be.” (Santiago County Water District v. County of Orange (1981) 118 Cal.App.3d 818, 831.)
In sum, SB 610, Vineyard, and Santiago hold that an accurate accounting of projected supply, demand, and any resulting shortfall is mandatory.

Finally, SB 610 permits an agency preparing a WSA to rely on the supply and demand data in an Urban Water Management Plan, but only “if the projected water demand associated with the proposed project was accounted for in the most recently adopted urban water management plan.” (Water Code, § 10910(c)(3), (4).)
b. The EIR and its WSA fail to provide the required accounting of water supply and demand.

The WSA provided as Appendix I to the EIR fails to include the water supply and demand for the MCWD service area. This WSA is the only WSA provided for the project, but it omits the MCWD demand for the 1,660 Fort Ord units, or, as we proposed to disaggregate the Fort Ord units from the Ryan Ranch units above based on relative acreage, at least 1,555 units. Thus, the WSA fails on ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1955, Packet Page 2283 6 its face to provide the total projected water supplies and demand for the project, and it fails to address or answer the question whether there will be sufficient supplies for the entire project over average, single dry, and multiple dry years.

If a water supplier does not provide a WSA, then the CEQA lead agency must provide the analysis itself. (Water Code, § 10910(b).) The DEIR does not purport to provide a WSA for the MCWD service area. Instead, its discussion relies on the 2020 MCWD UWMP. (DEIR, pp. 3.14-6 to 3.14-8, 3.14-26 to 3.14-29.) Not only is the UWMP not a WSA, but the EIR admits that “the 2020 UWMP does not fully account for the RHNA allocations of the other communities served by MCWD, including the cities of Marina, Seaside, and Del Rey Oaks and unincorporated portions of Monterey County.” (DEIR, p. 3.14-28.)
In fact, the 2020 MCWD UWMP assumes that the water demand from the City of Monterey through 2040 would be only 130 AFY, for which only 65 AFY is actually allocated. (DEIR, p. 3.14-28, Table

3.14-5; see also MCWD 2020 UWMP, pp. 23, 27.) Since the EIR admits that the 65 AFY allocation is sufficient for only 240 housing units, the 130 AFY demand figure in the 2020 UWMP represents demand from at most 480 units. Thus, the demand projection in the MCWD 2020 UWMP omits at least the demand for 1,180 to 1,075 housing units (depending on whether the Fort Ord area is planned for 1,660 units or 1,555 units). Based on the assumption that 65 AFY are required for 240 units, the omitted demand is at least 320 to 291 AFY for the omitted 1,180 to 1,075 housing units.

As the DEIR admits (DEIR, p. 3.14-28), the 2020 UWMP omits portions of the 6th Cycle RHNA demand for other jurisdictions now planning to increase previously planned Fort Ord development to meet RHNA targets. For example, the City of Seaside is now planning through its Seaside 2040 General Plan Update to include 995 housing units and 2.6 million square feet of employment space supporting 2,051 jobs in “Seaside East,” a development area within the former Fort Ord that would have to be served by MCWD. (Seaside GPU DEIR, App. B, Tables 1, 15, and 16.1 ) This demand is also
not included in the MCWD 2020 UWMP, which is based on assumptions about growth that were included in Seaside’s planning documents as of 2020. (MCWD UWMP, pp. 22-26, App. C [Seaside growth projections are based on existing plans, including 5th Cycle General Plan Housing Element].) The proposed Seaside 2040 General Plan Update projects substantially more growth than Seaside’s general plan as of 2020. (Seaside GPU DEIR, App. C, Hexagon December 7, 2022, p. 1, Table 1, Land Use Comparison [comparing households, jobs, and population for 2015, the current General Plan buildout, and the year 2040 proposed general plan buildout].) The DEIR here fails to account for any of this foreseeable demand that was not included in the 2020 UWMP.

These increased and competing demands for new development water supply from MCWD, above the demand levels assumed in the 2020 UWMP, are well known to the local jurisdictions. (See Monterey County Weekly, “Despite obstacles, Monterey and Del Rey Oaks plan to use Fort Ord land 1 Available at https://seaside2040.com/wp-content/uploads/2023/10/Seaside-2040-DEIRwith-Appendices_ocr.pdf.

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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1956, Packet Page 2284 7 for housing,” Oct. 5, 2023.2) It is unreasonable for the DEIR not to have disclosed these new sources of water demand in the MCWD Fort Ord service area. This non-disclosure vitiates both the noncumulative and cumulative water supply analyses. Both a WSA and a valid cumulative analysis must account for all cumulative demand that would be met by the project’s supplier.

The EIR simply fails to provide what SB 610 and CEQA case law require: an accounting of the relation of supply and demand in the MCWD service area for Fort Ord and a disclosure of just how adverse the impact to water supplies would be. These omissions are material since the EIR assumes that the undisclosed shortfall in MCWD supplies could be addressed with as little as 300 AFY from resumption of the mothballed desalination facility or an undisclosed supply from “Phase 2 of the Pure Water Monterey Project,” both projects for which the EIR admits there is neither a plan nor funding. (DEIR, pp. 3.14-28.) Even if there were a plan or funding, the evidence indicates that the shortfall is much greater than 300 AFY.

3. The EIR fails to disclose that MCWD cannot provide new residential hookups for Fort Ord housing development because it is bound to honor a 6,160-unit cap on new hookups, a limitation that has already been reached.

The Draft EIR makes no mention of a critical constraint on a water supply for areas served by MCWD, including all of the former Fort Ord area.

As part of the Fort Ord Reuse Plan, the Fort Ord Reuse Agency imposed a 6,160-unit cap on new residential development in order to protect groundwater resources.3 Although FORA ceased to exist in 2020, MCWD is committed to honor the 6,160-unit cap under the terms of a settlement agreement between MCWD, LandWatch, and Keep Fort Ord Wild. 4 The 6160-unit cap applies to
units served with groundwater. All of MCWD’s potable water supply is groundwater. (MCWD UWMP, p. 37.)
In order to ensure that land use jurisdictions did not approve entitlements for new residential development in excess of the cross-jurisdictional 6,160 cap on new units, FORA required that each 2 Available at
https://www.montereycountyweekly.com/news/local news/despite-obstacles-monterey-and-delrey-oaks-plan-to-use-fort-ord-land-for-housing/article_710ab000-62ef-11ee-9781- 5795df508bbf.html.
3 FORA, Development and Resource Management Plan, p. 132, Program 3.11.5.5(b)(2), available at https://www.fora.org/Reports/DevResourcePlan.pdf. 4 MCWD, LandWatch Monterey County, and Keep Fort Ord Wild, Settlement Agreement, September 17, 2018, available at https://landwatch.org/pages/issuesactions/fortord/091918- MCWD-Settlement-Agreement.pdf.

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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1957, Packet Page 2285 8 land use jurisdiction report annually the number of new residential units for which it had granted entitlements.5 Based on those entitlements, it is clear that there is no scope to approve additional projects reliant on groundwater in Fort Ord without violating the 6,160-unit cap.

The most recent systematic accounting of the unit cap, prepared by the City of Seaside in 2020 in connection with the Campus Town project in Seaside and based on current FORA records, indicated that all but ten of the 6,160 units had already been entitled.6 Furthermore, that accounting likely undercounts approved new residential units by up to 608 units, which would mean that no additional units can be entitled without further overcommitting the unit cap.7 The omission of this information renders the description of the environmental setting and the analysis of water supply and demand inadequate.

4. The EIR fails to disclose that the City’s entitlement of MCWD groundwater is limited to 65 AFY.

MCWD has jurisdiction as the sole water supplier in the former Fort Ord. The allocation of groundwater supplies in the former Fort Ord to each land use jurisdiction is spelled out in Appendix E to the MCWD 2020 Urban Water Management Plan (“UWMP”).8 The UWMP acknowledges that the “[p]otable water supply for the former Fort Ord (MCWD Ord Community service area) comes from the Monterey Subbasin of the Salinas Valley Groundwater Basin (SVGB).”9 The UWMP explains that MCWD owns and operates the Ord Community groundwater system and 5 Id.
6 City of Seaside, Campus Town FEIR, 2020, pp. 3-169 to 3-170.

7 First, the Campus Town accounting omits the 223-unit Bayview Community development and the 297-unit Sun Bay Apartments, both in Seaside, and both approved, built, and occupied. (FORA, Development Projects, 2014, available at https://www.fora.org/Projects.html.) Second, it omits the approved but not yet built 88-unit Seaside Senior Living project, based on the spurious claim that it is not a residential use but a “Business and Professional Services use,” citing Seaside Municipal Code (“SMC”) §§ 17.12.020 and 17.98.020. Nothing in those SMC sections references the Development Resource and Management Plan that governs the 6,160-unit cap, much less discusses what counts as a new residential use under the 6,160-unit cap. To the contrary, Section 17.12.20 includes "professional offices, convalescent homes, and care facilities" in the high-density residential zoning district and it lists care facilities as a "residential" use. And the definition of "residential care facility" in Section 17.98.020 does not characterize this use as non-residential. 8 MCWD, 2020 Urban Water Management Plan, Appendices, Appendix E, available at https://www.mcwd.org/docs/engr files/edfp/uwmp/MCWD%202020%20UWMP%20Appendices 202 10625.pdf.
9 Id., p. 58.

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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1958, Packet Page 2286 9 underlying groundwater extraction rights.10 The UWMP explains that the rights to use groundwater were allocated among the land use jurisdictions.11 For example, the City of Monterey was allocated only 65 AFY.12 The UWMP explains that MCWD will issue a water supply verification required by SB 221 or a will-serve letter for a final subdivision map only “up to the point where a given land use jurisdiction’s allocation is fully allocated to projects.”13 Thus, once a land use jurisdiction has exhausted its groundwater allocation through approval of previous projects, MCWD will not commit to provide additional groundwater. MCWD’s UWMP reflects this fact by identifying the difference between Monterey’s assumed 130 AFY demand and its 65 AFY allocation as a “shortage.” (UWMP, p. 62, Table 5.3, “Ord Community Groundwater Shortfalls.”) The EIR’s water supply discussion fails to disclose that the 65 AFY allocation represents a firm limit on planned or available potable water supply for Fort Ord development.14 Instead, the EIR’s project description section implies that the 65 AFY allocation is merely a near-term housing opportunity, not a long-term limitation on feasible development in Fort Ord, as follows:

Further, with the closure of Fort Ord, an allotment of 65-acre-feet of water was set aside for the City (an amount sufficient for 240 new homes), potentially making Fort Ord one of the more feasible locations for housing development in the near term. (DEIR, p. 2-15.) The failure to disclose the 65 AFY allocation as a limitation on available supplies renders the description of the environmental setting and the analysis of water supply and demand inadequate.

5. The EIR fails to disclose the magnitude of the water supply shortfall.

The only reference to the magnitude of a water supply shortfall for Fort Ord development is an entirely unexplained figure in Mitigation Measure UTIL-2, which purports to direct MCWD to increase water supply and states that these “measures shall be sufficient to generate an additional 199.2 AFY by 2030, as needed to support new development within the City of Monterey that will be served by MCWD.” (DEIR, p. 3.14-29.) Nowhere does the EIR explain how this 199.2 AFY figure was derived.
10 Id.
11 Id., p. 59 and Table 1
12 Id.
13 MCWD, 2020 Urban Water Management Plan, p. 65, available at https://www.mcwd.org/docs/engr files/edfp/uwmp/MCWD 2020 UWMP 20210630.pdf. 14 As the EIR admits (DEIR, p. 3.14-28), MCWD has no committed plan or funding to provided additional potable water.

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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1959, Packet Page 2287 10 A 199.2 AFY shortfall cannot represent the actual magnitude of MCWD’s total shortage or the shortage in water allocated to Monterey.

First, a 199.2 AFY shortfall cannot represent MCWD’s total shortfall in 2030. As discussed above, MCWD has service responsibility for the whole of the Fort Ord area, including service to other jurisdictions that are now planning to increase their development in Fort Ord beyond the levels assumed in the MCWD UWMP. The EIR provides no assessment of the total increase in cumulative demand across jurisdictions for MCWD water supplies, but it admits that the UWMP does not include Monterey’s current RHNA demand. (DEIR, p. 3.14-28.) And, as discussed above, other jurisdictions are planning substantially more development in Fort Ord than assumed in the MCWD 2020 UWMP, which the EIR admits. Accordingly, if the 199.2 AFY figure was derived in reliance on supply and demand projections in the MCWD UWMP, it is not accurate and certainly understates the cumulative shortfall.

Second, a 199.2 AFY shortfall cannot represent the shortfall of water allocated to Monterey. As discussed, Monterey’s allocation is only 65 AFY. Monterey plans at least 1,555 units, and perhaps 1,660 units, on Fort Ord, and the EIR assumes that each unit requires 0.27 AFY. (65 AFY divided by 240 units – see DEIR, p. 2-15.) This implies a water demand of from 421 AFY to 448 AFY, which is 356 to 383 AFY short of the 65 AFY allocation.

6. Proposed water supply mitigation is inadequate.

Mitigation Measure UTIL-2 to address the lack of a water supply provides:

MCWD shall implement measures to increase sources of water supply, including reactivation of the pilot seawater desalination plant and Indirect Potable Reuse of advanced treated water from the Pure Water Monterey project. The measures shall be sufficient to generate an additional 199.2 AFY by 2030, as needed to support new development within the City of Monterey that will be served by MCWD. (DEIR, p. 3.14-29.) This mitigation measure is inadequate under CEQA because it is not enforceable. (CEQA Guidelines, § 15126.4(a)(2).) The measure is legally infeasible because the City of Monterey does not have authority to require MCWD, an independent special district, to implement measures to provide additional water supply. The measure is also inadequate because, as the EIR admits, MCWD has no plan or funding to implement this mitigation.

As discussed below, the elimination of proposed development on Fort Ord lands is feasible mitigation and a feasible project alternative since needed RHNA development can in fact be relocated elsewhere in the City not dependent on MCWD water supplies. The EIR should propose this feasible mitigation instead.

7. The EIR fails to disclose the impacts of new water supply facilities.

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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1960, Packet Page 2288 11 The EIR concludes that, with respect to water supplies for the MCWD service area, the project would not result in “relocation or construction of new or expanded water . . . facilities, the construction or relocation of which could cause significant environmental effects.” (DEIR, p. 3.14-

29.) The stated rationale for this conclusion is that “MCWD owns a pilot desalination plant which if reactivated could provide 300 AFY of additional water supply to meet additional demand within its service area, including additional demand from new development at Fort Ord as part of the Proposed Plan. Therefore, implementation of the Proposed Plan would not require the construction of new or the expansion of existing regional water facilities over and above existing and planned facilities.” (DEIR, p. 3.14-29.)
This claim is inconsistent with Mitigation measure UTIL-2, which directs MCWD to reactivate its mothballed desalination plant and to implement a new project it calls “Indirect Potable Reuse of advanced treated water from the Pure Water Monterey project.” Because indirect potable reuse is not an existing facility, its implementation may cause significant environmental effects, which the EIR must be revised to disclose.

The existing indirect potable reuse of 3,500 AFY of treated water supplied by Pure Water Monterey discussed in the EIR is not water for the MCWD service area; it is for the Cal-Am service area. (DEIR, p. 3.14-6.)
The EIR identifies a possible MCWD indirect potable reuse project as one of the potential projects and management actions described in the Groundwater Sustainability Plan for the Monterey Subbasin that MCWD may pursue in the future. (DEIR, p. 3.9-23, citing Marina Coast Water District Groundwater Sustainability Agency & Salinas Valley Basin Groundwater Sustainability Agency, Groundwater Sustainability Plan Monterey Subbasin, 2022 (Monterey Subbasin GSP)15; see also DEIR, p. 2.9-27.) The EIR admits that indirect potable reuse for the MCWD service area has so far only undergone a feasibility study and that it is neither funded nor planned. (DEIR, pp. 3.14-8, 3.14- 28 to 3.14-29.) The Monterey Subbasin Groundwater Sustainability Plan confirms that this project has not yet been selected for implementation, funded, or undergone CEQA review. (Monterey Subbasin GSP, pp. 9-36 to 9-44.) Accordingly, it would be a new project, and if this project depends on its implementation, the DEIR must disclose its environmental impacts.

B. Biological resources
In general, the DEIR is inadequate because it fails to conduct any local field studies or analyses to evaluate the feasibility of even a general program of anticipated biological impacts mitigation measures relating to the City's lands on the former Fort Ord. Without this environmental setting information, the EIR does not and cannot assess the significance of impacts.

Furthermore, if mitigation is not demonstrably feasible, mitigation measures may not be deferred.

Here, the evidence is that mitigation is so uncertain that the EIR must specify the mitigation now.

That specification must address more than mitigation ratios and protocols but the uncertainty 15 Available at https://svbgsa.org/monterey-subbasin.

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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1961, Packet Page 2289 12 itself, which requires disclosure of the geographic location and extent of the covered species and natural communities as well as the availability of mitigation lands.

1. Sensitive species
Contrary to what is stated in the DEIR, Impact 3.4-1 would not be mitigable to a less than significant level because mitigation MM-BIO-4 would be infeasible. The City's former Fort Ord lands include occurrences of sensitive species and sensitive plant communities whose extent is great enough that the anticipated project-level avoidance and minimization would be infeasible, rendering the future projects unviable. These limitations should be identified with a program level analysis in the EIR that includes field-based quantification of the distribution of the species.

Examples of special status species on former Fort Ord lands with within-City extents large enough to be unavoidable to development projects include: (1) sandmat manzanita, (2) monterey ceanothus, and (3) Yadon's piperia, an endangered orchid. The EIR’s description of the environmental setting is inadequate, and its conclusions about the feasibility of mitigation, are unfounded without documentation of the range and extent of these species.

2. Sensitive communities
The DEIR is inadequate in stating that Impact 3.4-2 on sensitive natural communities would be less than significant because the DEIR is incorrect - at least on the former Fort Ord - when it states that such areas "are located primarily in the open space designations for the Planning Area and do not overlap with proposed sites for development." (DEIR, p. 3.4-33.) The entire area of the City's former Fort Ord lands are designated for Mixed Use Development under the proposed plan update, and the majority of this area is currently occupied by sensitive plant communities, including: (1) sandmat manzanita maritime chapparal, (2) woollyleaf manzanita maritime chaparral, (3) Toro manzanita maritime chaparral, (4) vernal pools and other wetlands.

3. Wetlands
The DEIR is inadequate in stating that Impact 3.4-3 on wetlands would be less than significant because it fails at a programmatic level to evaluate the distinct possibility that no development projects may be feasible in the City's former Fort Ord lands while complying with all applicable laws, regulations, policies, and agreements relating to wetlands, vernal pools, and runoff. The west edge of the City's former Fort Ord lands includes a vernal pool complex with numerous native wetland species and - via a sequence of USFWS Biological Opinions - a federally regulated role in protecting habitat for endangered California Tiger Salamander. Impacts to this area are unmitigable as no sufficient mitigation habitat exists. The area and required setbacks could not be developed. Federally mandated restrictions also exist relating to runoff reaching the Frog Pond Natural Area Expansion, immediately downstream from City land. Any flow detention infrastructure relating to this requirement would need to be in areas outside the vernal pool complex and associated setbacks. Such areas are occupied by sensitive upland species and communities. This presents the possibility that none of the City's former Fort Ord lands are feasibly developed under ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1962, Packet Page 2290 13 the Mixed Use designation. Such constraints should be evaluated at a programmatic level, and not left to future project proposals, because they have wide-reaching impacts for the remainder of the City's General Plan, particularly relating to attainment of housing targets.

4. Habitat Connectivity
The DEIR is inadequate in stating that Impact 3.4-4 to movement corridors would be less than significant because in making this determination, it primarily relies on information that is completely inappropriate for habitat connectivity analysis in relation to City's former Fort Ord lands. The analysis relied primarily on the California Essential Habitat Connectivity (CEHC) project (Spencer et al. 2010), and a version of it available through the CDFW BIOS Habitat Connectivity Viewer. CEHC was a state-wide analysis, with Monterey-area information so coarse, inaccurate, and out-dated that it failed to recognize the former Fort Ord as a substantially natural and conserved area (CEHC 2010 Figures 2.1, 2.2, 2.5), despite it being one of the most important conserved natural areas in the California Central Coast Region.

CEHC essentially assumed that Fort Ord was still an Army base. This led to a failure in the CEHC analysis to recognize Fort Ord as a habitat node (Fig. 2.7) or even as a conserved area (Fig. 2.9) despite the existence of the Fort Ord National Monument and its predecessor, the Fort Ord Natural Resource Management Area (designated in 1997 under the Fort Ord Habitat Management Plan).

These are fundamental errors that undermine any attempt to use CEHC to analyze the role of the City's lands in maintaining habitat connectivity. For example, because of the deficiencies in CEHC, Figure 3.4-3 of the DEIR incorrectly obscures habitat connectivity near the Ryan Ranch Disc Golf Course between the Santa Lucia Range and the former Fort Ord region via Jacks Peak; failing to even recognize Jacks Peak Regional Park and Fort Ord National Monument as "Natural Areas".

The DEIR also cited the Fort Ord Habitat Management Plan (1997) as designating no habitat corridors in the City's former Fort Ord lands. This also was a misuse of inapplicable information; the HMP corridor parcels were only designated to connect habitats within Fort Ord, not between Fort Ord and outside areas. (HMP, p. 2-13.) In fact, when one views the original 1996 Land Use Concept approved by the Fort Ord Reuse Authority (not the unapproved 2001 republication), a corridor of "open space/recreation" and "habitat management" is designated through City of Monterey land between areas to the south and what is now the Fort Ord National Monument.

The other two documents cited were municipal planning documents from the 1980s, hardly viable sources of habitat information within a contemporary planning framework. A much more granular analysis is required. No previous analysis is fully adequate. One of the most recent analyses was commissioned by TAMC in relation to Highway 68, and it was also flawed. For example, the only sensitive species reported as roadkill by this survey was an American badger killed where there is an existing habitat corridor on City of Monterey land near the Ranch Ranch Disc Golf course. But the TAMC analysis failed to recognize this and instead focused on the numerically greater detection of mule deer using culverts, which in turn was biased by the fact that remote cameras are more easily installed in culverts than along un-culverted sections of highway such as exist where the badger was killed. The reality is that the physically largest habitat corridor between Fort Ord ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1963, Packet Page 2291 14 and areas to the south (Monterra, Jacks Peak, and the broader Santa Lucia Range) occurs through City of Monterey lands on the former Fort Ord, and sensitive mammals such as badger (which are found on Fort Ord) are using this corridor. The existing general plan (2005-2016) rightly designates this entire corridor for parks, recreation, and open space. The proposed update retains the designation for the non-Fort Ord lands (where the Ranch Disc Golf Course is located). It should also retain the designation for the adjacent Fort Ord lands. Only this would likely support the DEIR's conclusion of less than significant impact.

C. Alternatives
Other than the obligatory no-project alternative, the EIR assesses two alternatives.

The Relocated Housing Alternative, designed to avoid significant water supply, biological, and hazardous materials impacts at Fort Ord, would relocate the proposed 1,660 units of Ryan Ranch/Fort Ord housing to the existing urbanized portions of the City by increasing permitted density and heights in the downtown area and key commercial corridors, including North Fremont Street, Lighthouse Avenue, Del Monte Avenue, Garden Road, Pacific Avenue, Munras Avenue, and Abrego Street. (DEIR, p. 4-3.) The DEIR assumes that the Relocated Housing Alternative would result in only 4,183 housing units instead of the 5,787 units under the proposed plan. (DEIR, p., 4-4, Table 4-1.).

The Increased Workforce Housing Alternative, designed to avoid the loss of 50 acres of grazing land and reduce VMT impacts, would replace office and visitor-serving uses with high density housing in the Downtown, Cannery Row, Lighthouse Avenue, North Fremont Street, Pacific Avenue, Munras Avenue, and Abrego Street locations; transform Del Monte Avenue into a high-density residential corridor; and increase multifamily housing at Fort Ord. (DEIR, p. 4-3.) The development of the 50-acre MPUSD site would not proceed. The Increased Workforce Housing Alternative would increase the number of housing units to 9,830 and reduce the number of new jobs to better balance jobs and housing to reduce VMT. (DEIR, pp. 4-3 to 4.4.) The DEIR finds that the Increased Workforce Housing Alternative is environmentally superior “because it avoids the Proposed Plan’s significant and unavoidable impact pertaining to agricultural resources and reduces the severity of significant and unavoidable impacts related to air quality.” (DEIR, p. 4-22.) The DEIR acknowledges that the Relocated Housing Alternative reduces “the number of impacts compared to the Proposed Plan, although it would have a worse impact on an already significant and unavoidable impact on water supply.” The DEIR also claims that the Relocated Housing Alternative would not meet the RHNA objective to provide sites for the City’s share of Very Low and Low income housing units. (DEIR, p. 4-22.) The DEIR lacks substantial evidence for these conclusions, each of which is directly contradicted by the evidence in the EIR itself. The EIR demonstrates that the Relocated Housing Alternative would not have a “worse impact” on water supply but would entirely avoid the water supply impact in the MCWD service area; would reduce seven significant impacts compared to the proposed project; and would not increase the severity of any significant impacts. By contrast, the Increased Workforce Housing Alternative would reduce only five significant impacts compared to the proposed project; ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1964, Packet Page 2292 15 and would increase the severity of four significant impacts. Finally, there is no evidence that the Relocated Housing Alternative would not provide sites for the RHNA share of very low and low income units and substantial evidence it would provide more lower income units than the proposed project. These points are discussed below.

1. The Relocated Housing Alternative is environmentally superior because it reduces seven significant impacts and increases none, whereas the Increased Workforce Housing Alternative reduces only five and increases four.

The EIR’s alternatives comparison table indicates for each potential impact caused by the proposed project whether it is of no impact (NI), less than significant without mitigation (LTS), potentially significant but less than significant with mitigation (LTSM), or unavoidably significant even with mitigation (SU). (DEIR, pp. 4.2-22 to 4.2-25, Table 4-2.) The table then indicates for each alternative whether its impacts are less than, the same as, or greater than the impacts of the proposed project.

Alternatives should be designed to reduce significant impacts that would otherwise require mitigation or that are significant and unavoidable despite mitigation. Thus, the efficacy of the alternatives should be assessed with reference to whether they avoid or reduce the proposed project’s LTSM or SU impacts.

Considering just the LTSM and SU impacts of the proposed project, Table 4-2 indicates that the Relocated Housing Alternative would avoid or reduce the following seven impacts, five of which are SU and two of which are LTSM:
● 3.3-1 Air Quality Plan (SU -)
● 3.3-2 Increase in Criteria Pollutant (SU -)
● 3.3-3 Sensitive Receptors (SU -)
● 3.4-1 Special-Status Species (LTSM -)
● 3.8-4 Hazardous Materials Site (LTSM -)
● 3.14-1 Relocation or Expansion of Utilities (SU -)
● 3.14-2 Water Supply (SU -)
The Relocated Housing Alternative would not increase any LTSM or SU impacts compared to the proposed project.

By contrast, the Increased Workforce Housing Alternative reduces only the following five LTSM and SU impacts of the proposed project, four of which are SU and one of which is LTSM:
● 3.2-3 Farmland Conversion (SU-)_
● 3.6-2 Conflict with an Applicable Plan, Policy, or Regulation [re Energy, GHG, Climate Change] (SU-)
● 3.13-2 VMT (SU-)
● 3.15-1 Emergency Response/Evacuation [wildfire] (SU-) ● 3.15-3 Infrastructure [Wildfire] (LTSM-)
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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1965, Packet Page 2293 16 And the Increased Workforce Housing Alternative aggravates four LTSM or SU impacts of the proposed project, three of which are SU and one of which is LTSM:
● 3.6-1 Generate GHG Emissions (SU+)
● 3.12-1 Fire, Police, Schools, Parks, or Other Public Facilities (LTSM+) ● 3.14-1 Relocation or Expansion of Utilities (SU+)
● 3.14-2 Water Supply (SU+)
Thus, by the EIR’s own accounting, the Relocated Housing Alternative reduces more SU impacts and more LTSM impacts than the Increased Workforce Housing Alternative does. And the Relocated Housing Alternative does not increase any SU or LTSM impacts, whereas the Increased Workforce Housing increases three SU impacts and one LTSM impact.

There is no substantial evidence that the Increased Workforce Housing Alternative is environmentally superior. The evidence in the EIR itself is that the Relocated Housing Alternative is environmentally superior.

2. The EIR errs in its conclusion that the Relocated Housing Alternative would not meet the objective of accommodating very low and low income RHNA units.

The EIR’s discussion of the Relocated Housing Alternative concludes that it would not meet the objective to accommodate the City’s very low and low income RHNA. (DEIR, p. 4-22.) The EIR states that the Relocated Housing Alternative would provide only 4,183 units, which is 1,604 units fewer than the proposed project’s 5,787 units. The 1,604-unit reduction represents nearly all of the projected 1,660 units for the Ryan Ranch/Fort Ord area in the proposed project.

The fact that the total number of units is reduced by essentially all of the proposed Fort Ord units indicates that the EIR preparers have simply ignored the provision in the Relocated Housing Alternative intended to relocate housing from Fort Ord to the urbanized portions of the City by increasing “permitted density and heights in the downtown area and key commercial corridors, including North Fremont Street, Lighthouse Avenue, Del Monte Avenue, Garden Road, Pacific Avenue, Munras Avenue, and Abrego Street.” (DEIR, p. 4-3.) It makes no sense to have included provisions in the Relocated Housing Alternative intended to relocate housing through increased density if those provisions were assumed to be ineffective.

Notably, the Increased Workforce Housing analysis assumes that its density increases would be effective in increasing housing units: it is assumed to increase housing units from 5,787 units to 9,830 units by provisions to “replace office and visitor-serving uses with high density housing the Downtown, Cannery Row, Lighthouse Avenue, North Fremont Street, Pacific Avenue, Munras Avenue, and Abrego Street locations; transform Del Monte Avenue into a high-density residential corridor; and increase multifamily housing at Fort Ord.” (DEIR, pp. 4-3 to 4-4.) If such increased density provisions are effective for the Increased Workforce Housing Alternative, they should be effective for the Relocated Housing Alternative.

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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1966, Packet Page 2294 17 The EIR offers no analysis, and thus no evidence, to support its conclusion that the Relocated housing alternative would not provide sufficient very low and low income units to meet the City’s RHNA. It appears that the EIR simply neglected to assess the effect of the increased densities and height limits.

Information in the Site Inventory section of the Housing Element indicates that increased height limits and permitted densities would in fact provide enough additional very low and low income units in the North Fremont Street, Lighthouse Avenue, Del Monte Avenue, Garden Road, Pacific Avenue, Munras Avenue, and Abrego Street areas to more than make up for the loss of the projected 220 units of very low and low income units in Fort Ord.

The Site Inventory identifies relevant constraints for lower income units and provides that all sites meeting these constraints were counted toward the lower income unit RHNA. First, the Site Inventory points out that sites for lower income units must “be of appropriate size, be free from environmental constraints, be zoned to accommodate housing, have appropriate development standards, and be served by public facilities.” (Housing Element p. 3-2.) The Site Inventory states that “[s]ites meeting the criteria established in State law for lower income RHNA sites were counted toward the City's Low and Very Low Income RHNA allocation; other sites were attributed to the City's Above Moderate RHNA allocation.” (Housing Element, p. 3-10, emphasis added.) Generally, the State law safe harbor criteria for very low and low income sites are met if the Site Inventory (1) provides by-right development for sites used in prior RHNA cycles, (2) zones or proposes to zone at Mullin density, which for Monterey County is 20 units per acre, and (3) counts only parcels that meet the parcel size limitations, which are over ½ acre and under 10 acres. (HCD, Site Inventory Handbook, June 10, 2020, pp, 11-18.16)
The site inventory further clarifies that “Low and Very Low RHNA capacity has been attributed to sites that meet the suitability criteria outlined in State law, including parcel size, location, and zoning. Infill sites that do not meet the established suitability criteria are assumed to develop with market rate housing and that capacity has been assigned to above moderate income households.

However, the City has adopted an Inclusionary Ordinance which requires that 20 percent of new units in projects of six or more units be affordable to moderate and low income households and through Program 2-I in the Housing Action Plan (Chapter 4), the ordinance will be revised to specify that 10 percent of the units provided must be affordable to moderate income households and 10 percent must be affordable to low income households. Accordingly, 10 percent of the total above moderate infill development capacity has been reallocated to moderate income RHNA, and 10 percent to lower income RHNA.” (Housing Element, p. 3-29.) In short, any parcel identified for lower income units in the Site Inventory can be assumed to meet the criteria for lower income units.
16 Available at https://www.hcd.ca.gov/community-development/housingelement/docs/sites inventory memo final06102020.pdf.

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Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1967, Packet Page 2295 18 Following these criteria, and based on the assumed permitted densities at various sites, the Site Inventory determines that 973 lower income units can be provided at North Fremont Street, Lighthouse Avenue, Del Monte Avenue, Garden Road, Pacific Avenue, Munras Avenue, and Abrego Street areas. For example, the Site Inventory assumes that the Garden Road area would be zoned to permit 50 units per acre and then calculates that, at this density, 515 lower income units could be developed. (Housing Element, p. 3-15.) If the allowed density of these units were increased from 50 to 60 units per acre, i.e., a 20% density increase, then the number of lower income units on the same areas already assumed to meet the criteria to accommodate lower income units could be increased 20%, i.e., 103 units.

The table below applies the percentage increases in allowed density to each of the five areas that would be upzoned in the Relocated Housing Alternative. The table demonstrates that, if the various densities assumed for the areas already identified as eligible for lower income units were increased to 60 units per acre, an additional 388 lower income units could be provided.

Site
Proposed
project
units/acre
Proposed
project
lower
income
units
Relocated
Housing
Alternative
units/acre
RH
Alternative
density
increase
RH
Alternative
lower
income
units
North Fremont
Street
(HE, p. 3-11) 45 263 60 33% 351
Lighthouse Ave.
(HE, p. 3-14) 30 31 60 100% 62
Del Monte Ave.
(HE, p. 3-18) 30 126 60 100% 252
Garden Road (HE,
p. 3-15) 50 515 60 20% 618
Pacific, Munras,
Abrego
(HE, pp. 3-15, 3-
18 [max density
29 units/acre]) 29 38 60 107% 79
Totals 973 1,361
Since the Fort Ord site was assumed to provide only 220 lower income units, and the Relocated Housing Alternative can be seen to provide 388 more lower income units than the proposed project, the upzoning would more than compensate for the elimination of Fort Ord housing. An additional benefit of the upzoning is that it would provide more moderate income and above moderate income units as well.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1968, Packet Page 2296 19 3. The Housing Element overcounts potential affordable units at Fort Ord because it mischaracterizes the inclusionary housing ordinance and ignores site development constraints that cannot be resolved in the 6th Cycle.

The Housing Element claims that 220 of the 1,660 units proposed for Ryan Ranch/Fort Ord would be made available to lower income families and 220 made available to moderate income families “consistent with the City’s inclusionary ordinance.” (Housing Element, p. 3-19.) This is inaccurate.

As set out in proposed Program 2-I, the current and planned inclusionary housing ordinance only mandates 20% of total units be made affordable, 10% for lower income and 10% for moderate income units. (Housing Element, p. 4-14.) Thus, of the 1,660 total units planned for Ryan Ranch/Fort Ord, at most 166 would be required to be made affordable to lower income households, and at most 166 made affordable to moderate income households – not the 220 lower income and 220 moderate income units.

Furthermore, counting all of these 166 lower income units and 166 moderate income units in Fort Ord toward the 6th Cycle RHNA is inconsistent with the admission in the Housing Element that at most 240 total units could be developed before 2031 due to water supply constraints and the timeline for remediation of hazardous materials. (Housing Element, pp. 2-14 to 2-15.) Under the inclusionary housing ordinance, only 10% of the units or 24 units must be affordable to lower income households and only 10% or 24 units must be affordable to moderate income households.

Thus, the Housing Element overcounts affordable units by 196 units (220 counted units less the 24 units actually required and feasible in the 6th Cycle). The 196-unit overcount of lower income units exceeds the 161-unit buffer or surplus of units over the RHNA requirement for lower income units. (Housing Element, p. 3-30, Table 3-4.) The 196-unit overcount of moderate income units also exceeds the 44 unit buffer for moderate income units. Thus, the proposed project would fail to provide sufficient affordable units, whereas the Relocated Housing Alternative would provide them.

In conclusion, LandWatch urges the City to adopt the Relocated Housing Alternative to better meet its RHNA obligations and to minimize significant environmental impacts. If the City chooses not to adopt this alternative, it must revise and recirculate the draft EIR to correct the flaws discussed above in the analysis of biological and water supply impacts caused by developing housing on Fort Ord land.

Sincerely,
Michael DeLapa
Executive Director
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1969, Packet Page 2297 3/4/24, 8:42 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/5 Re: Significant concern with 640 unit development off Highway 68 Beth Weinstein
Mon 3/4/2024 8:31 AM
To:Christy Sabdo <[email protected]>
Thanks Christy.  I have concerns with both projects, and the cumulative effects in what was always designated a rural/scenic area.

Appreciate the additional information.

Best,
Beth
Beth Weinstein
Organization Development Consultant and Executive Coach Mobile
Email:

On Mon, Mar 4, 2024 at 8:28 AM Christy Sabdo <[email protected]> wrote:

Hi Beth,
You may want to forward your comments to the County. It is the County that is planning for approximately 1,324 housing units south of Hwy 68. The County contact for their Housing Element is: Jaime Guthrie: [email protected] Link to County website: https://www.co.monterey.ca.us/government/departments-a-h/housing-community-development/planningservices/advance-planning/ordinances-plans-under-development/general-plan-elements-update-housing-element-6th-cycle-update-2023- 2031-ref220020-lrpwp-task-no-21-02
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1970, Packet Page 2298 3/4/24, 8:42 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/5 The City is planning for 640 units on 50-acres south of Highway 68 as part of a Monterey Peninsula Unified School District Educational Workforce Housing overlay. The City's Draft Housing Element is here: https://haveyoursaymonterey.org/monterey2031/news feed/45-daypublic-review-period-begins-for-the-draft-program-level-draft-environmental-impact-report-for-the-monterey-2031-general-plan-update-2 Best regards,
Christy
Christy Sabdo, AICP
Senior Associate Planner | City of Monterey
570 Pacific Street | Monterey, CA 93940
831-646-3885 (main) | 831-646-3758 (direct) |
[email protected] | have your say | city website
From: Beth Weinstein <[email protected]>
Sent: Sunday, March 3, 2024 4:36 PM
To: Christy Sabdo <[email protected]>
Subject: Significant concern with 640 unit development off Highway 68 You don't often get email from [email protected]. Learn why this is important Hi Christy,
We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1971, Packet Page 2299 3/4/24, 8:42 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/5 anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

The two I especially object to are the County's 1324 units being proposed off Olmstead Rd and the city of Monterey's 640 units being proposed for land that was previously designated for education. Both of these projects violate the State of California's desire for infill on already developed land and pose significant risk, including:
*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be estimated that Monterey's proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day. This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The assumption is 2.5 car trips per housing unit per day). The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic?
*Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10-20 units per acre) fit into this environment?  I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads.  That is not in the spirit of what California state criteria is for affordable housing. *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in and out.  Is this also going to be onto Olmstead Road through the County's development?  Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks. *Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single family home in the Monterra neighborhood. If such an incident were to occur in a high density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property? ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1972, Packet Page 2300 3/4/24, 8:42 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 4/5 *Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor? *Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk?
*Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?
*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

Thank you for including my input.  I would encourage you to look at using ADUs and other infill strategies using land that has already been developed and is not being fully utilized, such as empty lots next to MPC and Casa Verde, the old courthouse and hospital, as well as parcels around Cannery Row.

Beth Weinstein
Email: [email protected]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1973, Packet Page 2301 3/4/24, 8:42 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 5/5 [NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
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[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1974, Packet Page 2302 3/18/24, 8:43 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Comments on Draft EIR for Monterey 2031 General Plan Update Elizabeth Turner
Sat 3/16/2024 6:28 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Ms. Sabdo:

I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031 General Plan Update.

The proposed housing plan for the City of Monterey includes developing a 50 acre parcel on Highway 68. Developing this parcel would have a significant negative impact on the Highway 68 Scenic Corridor and on the environment, in general, especially as it would increase traffic congestion on Highway 68 and the surrounding rural roads. The parcel is in an area that is labeled as a “highly sensitive viewshed.” There has already been extensive development in the Highway 68 Scenic Corridor as evidenced by the airport runway extension, the Highway 68 car condos, and the Montage Ohana building that was inexplicably allowed to loom over the highway. At least, the south side of the highway has maintained a scenic rural character. If that is now developed, the designation of Highway 68 as a scenic corridor would be in jeopardy.

PROPOSED PLAN BASED ON UNREALISTIC PROJECTIONS
The Proposed Plan outlined in the City of Monterey document is based on what seem to be unrealistic projections of population growth and corresponding housing needs. The population of Monterey has actually decreased by 2.2% over the past 3 years and is projected to continue to decrease. The source of these projections, AMBAG, states that employment drives growth, but projected employment growth does not support the numbers used as the basis for the proposed housing development plan. The Proposed Plan assumes that, by 2031, employment in Monterey will grow by 8.3%, but population will grow by 37.6%, and somehow that necessitates a 41.9% growth in housing units. For each new job, it is proposed that approximately five people will move to Monterey. Is population growth outpacing employment growth due to the birth rate and/or due to the number of unemployed (potentially retired) people expected to move to Monterey? If it is the birth rate, it should be noted that children live in the same housing unit as their parents so there should not be a need for three times as many housing units as new jobs, as is proposed.

PROPOSED PLAN CONFLICTS WITH PROJECT OBJECTIVES
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1975, Packet Page 2303 3/18/24, 8:43 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 The Proposed Plan, which includes development of the 50 acre parcel on Highway 68, conflicts with six of the specific objectives, or goals, for the project as outlined in the report. Goal 1 states that the plan should address the regional housing needs (RHNA) but, as mentioned above, Monterey appears to be planning for many more new units than are necessary to meet projected needs.

It leads one to wonder if perhaps the Highway 68 parcel is included because an influential developer would like to build on it at the expense of the Highway 68 Scenic Corridor, the environment, and the general enjoyment and welfare of the community.

Goal 6 states that the City of Monterey should “ encourage new housing in locations supported by existing or planned infrastructure, while maintaining existing neighborhood character.” There is no existing infrastructure on the 50 acre Highway 68 parcel and the neighborhood character is low density residential and rural so the proposed plan does not meet goal 6.

Goal 7, entitled “Maintain Existing Housing," states that the city wants to “assure high quality maintenance, safety, and habitability of existing housing resources.” If this is so, why not have programs to rehabilitate and remodel existing housing, especially in core areas of the city? If you build an excess of new housing and significantly increase vacancy rates and decrease rental rates, it is well known that landlords will not be willing or able to maintain existing properties. The result will be some nice new buildings along Highway 68 while the appearance of Monterey's central district continues to degrade.

Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and schools…” This goal is in line with the State of California’s goal to promote infill as a way to promote sustainability and minimize negative impacts on the environment.

The parcel on Highway 68 does not meet this goal. It is not infill and would require residents to use cars to get to work and for all errands. It is not on a major transit route and it has a very low walk score.

Goal 12 states that the Proposed Plan should be consistent with the Airport Land Use Compatibility Plan (ALUCP) yet development of the 50 acre parcel blatantly violates this stated goal. According to ALUCP, the parcel is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas.

Goal 9 states that the Proposed Plan should “support a vibrant local economy.” This goal is what is used to promote the Proposed Plan over the “Increased Workforce Alternative Plan.” The City of Monterey report states that the Increased Workforce Alternative Plan is environmentally superior to the Proposed Plan as it avoids significant and unavoidable impacts to agricultural resources and air quality. However, the City of Monterey rejects the Increased Workforce Alternative Plan because it does not support local economic vitality to the same extent as the Proposed Plan does. This is in direct contradiction to the stated facts! Goal 9, which discusses economic vitality, states that there should be a balance of jobs and housing so that those who work in Monterey can afford to live in Monterey but the report also states that with the Proposed Plan, low wage hospitality and tourism workers would increase their vehicle miles traveled (VMT). So isn’t the Increased Workforce Alternative Plan better for low wage workers, better ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1976, Packet Page 2304 3/18/24, 8:43 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 for the environment, and better for everyone else as it reduces traffic congestion and air pollution and maintains the scenic beauty of the Highway 68 Corridor?
Finally, why not embrace a hybrid plan? Development of the land on South Boundary Rd, as described in the Proposed Plan, makes sense as it’s within walking distance of jobs at Ryan Ranch. Why not implement part of the Increased Workforce Alternative Plan but also develop housing along Boundary Rd? Boundary Rd. is not part of a recognized scenic corridor and would be much less likely to add to traffic congestion on Highway 68. In keeping with the State of California’s guideline for higher density units that are infill, the City of Monterey could modernize and further develop areas that could use revitalization without destroying the natural beauty and rural character that attracts tourists to visit and retirees to relocate to the Monterey Peninsula.

Thank you for your time and consideration of my input.

Liz Turner
--
Elizabeth Turner, PhD
Public Health & Education Research
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1977, Packet Page 2305 3/20/24, 8:37 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/2 Development of 50 Acre Parcel - Highway 68
Robert Behl
Tue 3/19/2024 10:03 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Ms. Sabdo:

My wife and I are active members of the Monterey City Community, despite currently living in Monterra.  For well over 20 years, we owned a home in the city, before we were able to afford something more rural, but close to our many City-centric activities like volunteering at the Aquarium, etc. The proposed high-density housing adjacent to our new home is, of course concerning, but we are trying hard not to be NIMBYs, as we understand the need for additional housing.

We do not oppose lower-density, careful development that maintains Highway 68 as a scenic corridor, with adequate spacing from both the Highway and neighbors and maintaining firebreak and passage for wildlife.

However, we are deeply concerned about the infrastructure needed to support both the County and the City’s proposals. Who is going to pay for water, sewer, and highway improvements required to make the proposed number of homes viable.

We are particularly concerned about water availability.  Currently Canada Woods Water serves several local communities from the local aquifer.  This aquifer already is experiencing salt water intrusion, requiring expensive reverse-osmosis desalination.

In recent meetings the airport has brought up that they will require significant additional water from their two wells in the same aquifer, to support the terminal improvement project.  Additionally, the test wells on the proposed County parcel have also had significant water quality problems from the same aquifer, without continuous drawing of water for more than a possible 1000 new homes.  If the City were to use substantial amounts of well water for their development, in addition to the already highly endangered supply, the results could be disastrous for everybody.

Secondly, the existing wastewater infrastructure, is very likely not going to be sufficient to support the expanded airport, re-development of Garden Road, and the proposed County development.  It certainly will not support many hundreds of additional homes along highway 68.

Finally, commuters bypassing the Highway1/68 exchange, especially in the evening commute, are already pushing Olmsted Rd beyond capacity, and putting pressure on the troubled Olmsted/impacted 68 intersection.  With added pressure from redeveloped homes on Garden Road, increased airport traffic, and Olmsted homes per the County plan, that intersection will be a nightmare, blocking commuters from new City homes, even if it eventually has a traffic circle installed.  To solve this, may require four-lanes on ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1978, Packet Page 2306 3/20/24, 8:37 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/2 68, all the way up to Ryan Ranch, and some sort of cloverleaf/merge-lanes at Olmsted.  Very expensive, and certainly not a “Scenic Highway” entrance to Monterey.

We really think that higher density infill and development closer to existing infrastructure, jobs, shopping, etc makes a whole lot more sense for everybody, especially for those future homeowners.

That also comes closer to the state mandates for housing which does not intend creation of an isolated development, divorced from the existing community.

Thank you for considering our input in these matters,
Sincerely,
Robert & JoAnna Behl
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1979, Packet Page 2307 Dear Ms. Sabdo:

I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031 General Plan Update.

The proposed housing plan for the City of Monterey includes developing a 50 acre parcel on Highway 68. Developing this parcel would have a significant negative impact on the Highway 68 Scenic Corridor and on the environment, in general, especially as it would increase traffic congestion on Highway 68 and the surrounding rural roads. The parcel is in an area that is labeled as a “highly sensitive viewshed.” There has already been extensive development in the Highway 68 Scenic Corridor as evidenced by the airport runway extension, the Highway 68 car condos, and the Montage Ohana building that was inexplicably allowed to loom over the highway. At least, the south side of the highway has maintained a scenic rural character. If that is now developed, the designation of Highway 68 as a scenic corridor would be in jeopardy.

PROPOSED PLAN BASED ON UNREALISTIC PROJECTIONS
The Proposed Plan outlined in the City of Monterey Document is based on what seem to be unrealistic projections of population growth and corresponding housing needs.

The population of Monterey has actually decreased by 2.2% over the past 3 years and is projected to continue to decrease. The source of these projections, AMBAG, states that employment drives growth, but projected employment growth does not support the numbers used as the basis for the proposed housing development plan. The Proposed Plan assumes that, by 2031, employment in Monterey will grow by 8.3%, but population will grow by 37.6%, and somehow that necessitates a 41.9% growth in housing units.

For each new job, it is proposed that approximately 5 people will move to Monterey. Is population growth outpacing employment growth due to the birth rate and/or due to the number of unemployed (potentially retired) people expected to move to Monterey? If it is the birth rate, it should be noted that children live in the same housing unit as their parents so there should not be a need for 3 times as many housing units as new jobs, as is proposed.

PROPOSED PLAN CONFLICTS WITH PROJECT OBJECTIVES

The Proposed Plan, which includes development of the 50 acre parcel on Highway 68, conflicts with six of the specific objectives, or goals, for the project as outlined in the report. Goal 1 states that the plan should address the regional housing needs (RHNA) but, as mentioned above, Monterey appears to be planning for many more new units than are necessary to meet projected needs. It leads one to wonder if perhaps the Highway 68 parcel is included because an influential developer would like to build on it at the expense of the Highway 68 Scenic Corridor, the environment, and the general enjoyment and welfare of the community.

Goal 6 states that the City of Monterey should “ encourage new housing in locations supported by existing or planned infrastructure, while maintaining existing neighborhood ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1980, Packet Page 2308 character.” There is no existing infrastructure on the 50 acre Highway 68 parcel and the neighborhood character is low density residential and rural so the proposed plan does not meet goal 6.

Goal 7, entitled “Maintain Existing Housing” , states that the city wants to “assure high quality maintenance, safety, and habitability of existing housing resources.” If this is so, why not have programs to rehabilitate and remodel existing housing, especially in core areas of the city? If you build an excess of new housing and significantly increase vacancy rates and decrease rental rates, it is well known that landlords will not be willing or able to maintain existing properties. The result will be some nice new buildings along Highway 68 while the appearance of Monterey's central district continues to degrade.

Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and schools…” This goal is in line with the State of California’s goal to promote infill as a way to promote sustainability and minimize negative impacts on the environment. The parcel on Highway 68 does not meet this goal. It is not infill and would require residents to use cars to get to work and for all errands. It is not on a major transit route and it has a very low walk score.

Goal 12 states that the Proposed Plan should be consistent with the Airport Land Use Compatibility Plan (ALUCP) yet development of the 50 acre parcel blatantly violates this stated goal. According to ALUCP, the parcel is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas. The airport is a major revenue generator for the county and provider of jobs. It has been proven time and time again that residential development within an airport environment leads to community pressure to close, or at a minimum, scale back airport operations due to noise and environmental issues. As you are aware, the Airport district is currently undergoing the construction of a new Terminal building and an expansion of its served markets, all things which lead to higher tax revenues for the County and an increased number of high paying skilled employment opportunities for the area’s residents. To put this in jeopardy would be a mistake.

Goal 9 states that the Proposed Plan should “support a vibrant local economy.” This goal is what is used to promote the Proposed Plan over the “Increased Workforce Alternative Plan.” The City of Monterey report states that the Increased Workforce Alternative Plan is environmentally superior to the Proposed Plan as it avoids significant and unavoidable impacts to agricultural resources and air quality. However, the City of Monterey rejects the Increased Workforce Alternative Plan because it does not support local economic vitality to the same extent as the Proposed Plan does. This is in direct contradiction to the stated facts! Goal 9, which discusses economic vitality, states that there should be a balance of jobs and housing so that those who work in Monterey can afford to live in Monterey but the report also states that with the Proposed Plan, low wage hospitality and tourism workers would increase their vehicle miles traveled (VMT).

So isn’t the Increased Workforce Alternative Plan better for low wage workers, better for ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1981, Packet Page 2309 the environment, and better for everyone else as it reduces traffic congestion and air pollution and maintains the scenic beauty of the Highway 68 Corridor? Finally, why put our Airport at risk? Why not embrace a hybrid plan? Development of the land on South Boundary Rd, as described in the Proposed Plan, makes sense as it’s within walking distance of jobs at Ryan Ranch. Why not implement part of the Increased Workforce Alternative Plan but also develop housing along Boundary Rd? Boundary Rd. is not part of a recognized scenic corridor and would be much less likely to add to traffic congestion on Highway 68. In keeping with the State of California’s guideline for higher density units that are infill, the City of Monterey could modernize and further develop areas that could use revitalization without destroying the natural beauty and rural character that attracts tourists to visit and retirees to relocate to the Monterey Peninsula.

Thank you for your time and consideration of my input.

Sincerely,
Jeffrey Benzing
Resident
Monterey
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1982, Packet Page 2310 3/25/24, 9:57 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/1 Oppostion to Olmsted develoment
jordan biby
Fri 3/22/2024 12:44 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Sir/Madam,
I am writing to express my strong opposition to the proposed housing development in our neighborhood. While I understand the need for affordable housing in our city, I believe that this project would have a detrimental impact on our community.

First and foremost, the proposed development is simply too large for our area. The increase in population density would put a strain on our already overburdened infrastructure, leading to increased traffic congestion, noise pollution, and strain on our public services. Additionally, the construction of this project would result in significant environmental damage, destroying natural habitats and putting wildlife at risk.

Furthermore, the type of housing being proposed is simply not in keeping with the character of our neighborhood. It would also drastically alter the aesthetic of our area, replacing the existing greenery and open spaces with a high-density housing complex.

In conclusion, I am deeply concerned about the impact this development would have on property values in the surrounding area. I strongly urge you to reconsider this proposed housing development. While I recognize the need for affordable housing, I believe that this project is simply not the right fit for our neighborhood. Thank you for your attention to this matter. Please add all impacted residents to the discussion about planning and development in areas that would directly affect their homes.

Sincerely,
Jordan Biby: Resident of Manor Rd
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1983, Packet Page 2311 March 20, 2024
Dear City of Monterey Planning Office:

We are writing as very concerned long-term homeowners on the Highway 68 Scenic Corridor. The proposed 50 acre development across from Monterey Airport, off Olmstead Road, raises a number of serious issues related to our community. we certainly know that affordable housing is in short supply in our beautiful region on the coast. However, the broad issues of environmental impact, water supply and run-off, more congested traffic along Highway 68, air quality, fire protection and public safety services, among other issues, make the Olmstead development highly unattractive in our view.

We urge you to reconsider the efforts being undertaken to change scenic/conservation zoning and provide entitlements, and evaluate other more attractive areas for future housing supply. The residents of our greenbelt community are also disappointed that we were not informed earlier about the looming threats to the character of our Monterey rural area along Highway 68.

Sincerely and With Concern,
w~w+
Wendell and Celeste Birkhofer
Monterey, CA 93940
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1984, Packet Page 2312 3/5/24, 9:44 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/1 Regarding Olmsted Road development proposal
Chris Bonavico
Fri 3/1/2024 7:58 PM
To:Christy Sabdo <[email protected]>
[You don't often get email from Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ] Hello,
We live across Olmsted road from the area you are studying.

We have small children and are very concerned about the greatly increased additional traffic and the risk to children that tenants of subsidized housing presents.

The wildlife also will suffer.   And the school / schoolchildren will be negatively impacted by development.

I know there is political pressure to create low income housing, but this is a terrible area to impact.   We are not a high income family, but we ask that you consider the impacts to families here - and choose to develop elsewhere. [NOTICE:  This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1985, Packet Page 2313 March 8, 2024
Attention: Christy Sabdo
Subject: Significant concern with 640 unit development off Highway 68 I had the opportunity to review my neighbors letter and I thought it was spot on with regards to my personal concerns. So, rather than rewrite it or paraphrase it, I am copying it with the exception of this paragraph and the last two paragraphs.

We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

The two I especially object to are the County's 1324 units being proposed off Olmstead Rd and the city of Monterey's 640 units being proposed for land that was previously designated for education. Both of these projects violate the State of California's desire for infill on already developed land and pose significant risk, including:
*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be estimated that Monterey's proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day. This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The assumption is

2.5 car trips per housing unit per day). The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse.

Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1986, Packet Page 2314 currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic?
*Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10-20 units per acre) fit into this environment? I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing. *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in and out. Is this also going to be onto Olmstead Road through the County's development? Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks.
*Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life.

Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property?
*Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1987, Packet Page 2315 CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?
*Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk? *Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations.

The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents? *Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1988, Packet Page 2316 predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

Thank you for including my input. I would encourage you to look at using ADUs and other infill strategies using land that has already been developed and is not being fully utilized, such as empty lots next to MPC and Casa Verde, the old courthouse and hospital, as well as parcels around Cannery Row, the east side of General Jim Moore Parkway, and even Ft. Ord which I understand would require significant clean up but it has to be done sometime.

In summary, I am strongly opposed to high density development in the areas pointed out for the reasons stated in this letter. We should learn from other municipalities that have unsuccessfully gone this route.

Sincerely,
Fred Breidenbach
Monterey, CA 93940
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1989, Packet Page 2317 March 8, 2024
Attention: Christy Sabdo
Subject: Significant concern with 640 unit development off Highway 68 I had the opportunity to review my neighbors letter and I thought it was spot on with regards to my personal concerns. So, rather than rewrite it or paraphrase it, I am copying it with the exception of this paragraph and the last two paragraphs.

We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

The two I especially object to are the County's 1324 units being proposed off Olmstead Rd and the city of Monterey's 640 units being proposed for land that was previously designated for education. Both of these projects violate the State of California's desire for infill on already developed land and pose significant risk, including:
*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be estimated that Monterey's proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day. This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The assumption is

2.5 car trips per housing unit per day). The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse.

Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1990, Packet Page 2318 currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic?
*Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10-20 units per acre) fit into this environment? I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing. *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in and out. Is this also going to be onto Olmstead Road through the County's development? Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks.
*Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life.

Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property?
*Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1991, Packet Page 2319 CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?
*Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk? *Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations.

The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents? *Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1992, Packet Page 2320 predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

Thank you for including my input. I would encourage you to look at using ADUs and other infill strategies using land that has already been developed and is not being fully utilized, such as empty lots next to MPC and Casa Verde, the old courthouse and hospital, as well as parcels around Cannery Row, the east side of General Jim Moore Parkway, and even Ft. Ord which I understand would require significant clean up but it has to be done sometime.

In summary, I am strongly opposed to high density development in the areas pointed out for the reasons stated in this letter. We should learn from other municipalities that have unsuccessfully gone this route.

Sincerely,
Susan Breidenbach
Monterey, CA 93940
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1993, Packet Page 2321 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1994, Packet Page 2322 Dear Ms. Sabdo:

I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031 General Plan Update.

The proposed housing plan for the City of Monterey includes developing a 50 acre parcel on Highway 68. Developing this parcel would have a significant negative impact on the Highway 68 Scenic Corridor and on the environment, in general, especially as it would increase traffic congestion on Highway 68 and the surrounding rural roads. The parcel is in an area that is labeled as a “highly sensitive viewshed.” There has already been extensive development in the Highway 68 Scenic Corridor as evidenced by the airport runway extension, the Highway 68 car condos, and the Montage Ohana building that was inexplicably allowed to loom over the highway. At least, the south side of the highway has maintained a scenic rural character. If that is now developed, the designation of Highway 68 as a scenic corridor would be in jeopardy.

PROPOSED PLAN BASED ON UNREALISTIC PROJECTIONS
The Proposed Plan outlined in the City of Monterey Document is based on what seem to be unrealistic projections of population growth and corresponding housing needs.

The population of Monterey has actually decreased by 2.2% over the past 3 years and is projected to continue to decrease. The source of these projections, AMBAG, states that employment drives growth, but projected employment growth does not support the numbers used as the basis for the proposed housing development plan. The Proposed Plan assumes that, by 2031, employment in Monterey will grow by 8.3%, but population will grow by 37.6%, and somehow that necessitates a 41.9% growth in housing units.

For each new job, it is proposed that approximately 5 people will move to Monterey. Is population growth outpacing employment growth due to the birth rate and/or due to the number of unemployed (potentially retired) people expected to move to Monterey? If it is the birth rate, it should be noted that children live in the same housing unit as their parents so there should not be a need for 3 times as many housing units as new jobs, as is proposed.

PROPOSED PLAN CONFLICTS WITH PROJECT OBJECTIVES
The Proposed Plan, which includes development of the 50 acre parcel on Highway 68, conflicts with six of the specific objectives, or goals, for the project as outlined in the report. Goal 1 states that the plan should address the regional housing needs (RHNA) but, as mentioned above, Monterey appears to be planning for many more new units than are necessary to meet projected needs. It leads one to wonder if perhaps the Highway 68 parcel is included because an influential developer would like to build on it at the expense of the Highway 68 Scenic Corridor, the environment, and the general enjoyment and welfare of the community.

Goal 6 states that the City of Monterey should “ encourage new housing in locations supported by existing or planned infrastructure, while maintaining existing neighborhood ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1995, Packet Page 2323 character.” There is no existing infrastructure on the 50 acre Highway 68 parcel and the neighborhood character is low density residential and rural so the proposed plan does not meet goal 6.

Goal 7, entitled “Maintain Existing Housing” , states that the city wants to “assure high quality maintenance, safety, and habitability of existing housing resources.” If this is so, why not have programs to rehabilitate and remodel existing housing, especially in core areas of the city? If you build an excess of new housing and significantly increase vacancy rates and decrease rental rates, it is well known that landlords will not be willing or able to maintain existing properties. The result will be some nice new buildings along Highway 68 while the appearance of Monterey's central district continues to degrade.

Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and schools…” This goal is in line with the State of California’s goal to promote infill as a way to promote sustainability and minimize negative impacts on the environment. The parcel on Highway 68 does not meet this goal. It is not infill and would require residents to use cars to get to work and for all errands. It is not on a major transit route and it has a very low walk score.

Goal 12 states that the Proposed Plan should be consistent with the Airport Land Use Compatibility Plan (ALUCP) yet development of the 50 acre parcel blatantly violates this stated goal. According to ALUCP, the parcel is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas.

Goal 9 states that the Proposed Plan should “support a vibrant local economy.” This goal is what is used to promote the Proposed Plan over the “Increased Workforce Alternative Plan.” The City of Monterey report states that the Increased Workforce Alternative Plan is environmentally superior to the Proposed Plan as it avoids significant and unavoidable impacts to agricultural resources and air quality. However, the City of Monterey rejects the Increased Workforce Alternative Plan because it does not support local economic vitality to the same extent as the Proposed Plan does. This is in direct contradiction to the stated facts! Goal 9, which discusses economic vitality, states that there should be a balance of jobs and housing so that those who work in Monterey can afford to live in Monterey but the report also states that with the Proposed Plan, low wage hospitality and tourism workers would increase their vehicle miles traveled (VMT).

So isn’t the Increased Workforce Alternative Plan better for low wage workers, better for the environment, and better for everyone else as it reduces traffic congestion and air pollution and maintains the scenic beauty of the Highway 68 Corridor? Finally, why not embrace a hybrid plan? Development of the land on South Boundary Rd, as described in the Proposed Plan, makes sense as it’s within walking distance of jobs at Ryan Ranch. Why not implement part of the Increased Workforce Alternative Plan but also develop housing along Boundary Rd? Boundary Rd. is not part of a recognized scenic corridor and would be much less likely to add to traffic congestion on Highway 68. In keeping with the State of California’s guideline for higher density units ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1996, Packet Page 2324 that are infill, the City of Monterey could modernize and further develop areas that could use revitalization without destroying the natural beauty and rural character that attracts tourists to visit and retirees to relocate to the Monterey Peninsula.

Thank you for your time and consideration of my input.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1997, Packet Page 2325 3/20/24, 8:34 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/1 Support for City plan for 650 housing units off highway 68 at Olmstead Charles Chrietzberg
Tue 3/19/2024 8:19 PM
To:Christy Sabdo <[email protected]>
[You don't often get email from Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
As the owner of 14 properties in Monterra/ Tehama and York Highlands (Walden), we are in 100% in favor of this much needed housing.

This is an excellent location and we commend the City for moving this project forward.

I am certain that most of the millionaires who live in Multi million dollar homes in the exclusive developments will be against this housing project as they can’t understand
lower priced housing for those not as fortunate as them.

I wish you good luck with getting this project thru  this lengthy process.

Charles
[NOTICE:  This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1998, Packet Page 2326 3/7/24, 5:11 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 proposed development off 68
Robert Cochran
Thu 3/7/2024 10:51 AM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Ms. Sabdo,
We are writing about the proposed housing project of 640 units off Highway 68 currently owned by the Monterey Peninsula School District. This is extremely concerning, given all the other development being proposed in the immediate area, including the Garden Court development, the 1300 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. We understand, and support, the moral and political mandate for affordable housing, but the cumulative effects of all this on an area that already is struggling with traffic and was designated a scenic corridor are likely to be disastrous. The major areas of concern include:

1. Traffic. Assuming 2.5 car trips per housing unit per day, the city’s proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day.

This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make for a traffic nightmare - not only for current residents but for the new residents as well. Is there any plan to deal with the impact of all this extra traffic? To emphasize the point, we understand that Carmel, to take a nearby example, covers approximately 1 square mile with about 3000 residents. As you know, Carmel can be quite congested for pedestrians, cars, and bicycles. These projects will have a considerably larger number of residents packed within an area a fraction of Carmel’s size. Does that really make sense?

2. Environmental impact and vanishing Greenbelt. The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel, such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. How does such a high density (10- 20 units per acre) fit into this environment? I don't understand how a designated scenic ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 1999, Packet Page 2327 3/7/24, 5:11 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing.

3. Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e.

Truckee with a private jet, as well as Naples FLA recently). Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property?

4. Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times.

Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Has the city of Monterey analyzed additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west, and is the city prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this firebreak?

5. Police Protection. The proposed rezoning will place an untenable burden on our existing law enforcement resources, which already are in critical shortage. Have the police and/or sheriff’s departments been consulted and are they prepared to handle this high increased risk?

6. Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tires. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants? How will this be mitigated for current and future residents?

7. Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2000, Packet Page 2328 3/7/24, 5:11 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

In summation, it’s hard to believe that there are no sites which are more appropriate for a project of this size. It also seems quite likely that the same number of units could be spread out over a number of sites in the city with far less harm done to the existing communities, residents, and environments, and a better outcome for the occupants of the new housing. We hope you will give serious consideration to the concerns raised in this email.

Thank you,
Bob and Laurie Cochran
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2001, Packet Page 2329 ARTHUR B. COOK
March 21, 2024
Christy Sabdo, AICP
Senior Associate Planner
City of Monterey, Planning Division
By email: [email protected]
Subject: Draft Program-Level Draft Environmental Impact Report (EIR) for the Monterey 2031 General Plan Update. Specifically, the statements which appear in the Revised Draft City of Monterey 2023-2031 Housing Element, as follows:
“HOUSING POTENTIAL BY OPPORTUNITY AREA
“Garden Road
“This area contains a large, vacant parcel owned by the Monterey City School District (MPUSD).

Located east of Tarpey Flats and south of the airport, the 50-acre parcel is on relatively flat terrain and is identified as potential site for moderate and low income housing in the Highway 68 Area Plan if MPUSD were to declare the property surplus… To facilitate development of this site with mixed income housing, Program 1-I has been included in the Housing Action Plan (Chapter4) and the inventory assumes 640 new housing units…” Revised Draft | December 8, 2023 p. 3-15
Dear Associate Planner Sadbo,
In considering its housing element, the City of Monterey needs to be mindful that Monterey Regional Airport brings $250 Million annually into the City and immediate surrounding area.

The additional housing planned by the City and described in the quote above, if approved, would cripple the only vehicular ingress and egress for passengers coming and going to and from the area by air. The traffic impact of this proposed housing development would contribute to a disastrous bottleneck on Rt. 68 from Highway 1 to Ryan Ranch.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2002, Packet Page 2330 Vehicular Ingress and Egress to the Airport Is Already Constricted: The primary route to and from the Airport is by Olmsted Road via Route 68. This section of highway is already very crowded, and its status as the access to MRY Airport terminals requires consideration. The City has already approved 600 units on Garden Road. Imagine if the City also approves 640 homes on the 50 acre parcel now owned by MPUSC. Meanwhile, the County has proposed 1324 units of housing to be built South of Route 68 at Olmsted Road. Any of these projects would be highly detrimental to the Monterey Regional Airport, an engine of this area’s economy.

Collectively, more than 3000 additional commuter vehicles will travel Route 68 through the intersection with Olmsted Road twice daily, weekday mornings and evenings. There are no jobs, shops or services near any of these housing sites. The nearest supermarket, Safeway at Fremont Boulevard and Del Rey Oaks Boulevard, is over 2 miles away. Residents will require vehicular transportation for every errand, adding additional daily vehicular round trips through Route 68 between Highway 1 and Rt 218.

CalTrans and TAMC Scenic Route 68 Corridor Improvements Project: CalTrans and TAMC have a joint project to place roundabouts at major intersections along Route 68 between Salinas and Monterey, including at Rt. 218 and Olmsted Road. CalTrans’ and TAMC’s engineering for these roundabouts took into consideration permits which had been approved at the time of their planning, but not as-yet-unpermitted projects such as the City’s plan for 1240 housing units or the County’s plan for 1324 housing units in the immediate vicinity of the airport.

Airport Expansion: These housing plans must also be considered in the context that Monterey Regional Airport is already in the process of renovating and expanding the airport terminal and is adding gates, flights and destinations. More vehicular traffic from the airport must also be considered, entering and exiting at Olmsted Road and Rt. 68.

Conclusion: Neither the City nor the County should plan additional housing anywhere south of Rt. 68 between Highway 1 and Ragsdale Drive. Choking off vehicular access to the area’s commercial airport would be disastrous for the local economy.

Thank you for your consideration of this issue.

Sincerely,
Arthur Cook
Carmel
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2003, Packet Page 2331 3/25/24, 9:20 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/2 Olmstead Rd Housing Project
Helen Cooper
Sat 3/23/2024 3:38 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear [Christy],
I am writing to express my concerns about the proposed 640-unit housing development off Highway 68, which is currently under the ownership of the Monterey Peninsula School District. As a resident in proximity to the site, I am alarmed by the cumulative impact of this and other developments planned in the vicinity, such as the Garden Court and Boundary Road projects.

The proposed developments threaten to exacerbate existing traffic issues in an area that many, including myself, have chosen for its scenic qualities and relative tranquility. The addition of potentially over 5000 cars from these new units poses a significant risk to the designated scenic corridor and contradicts the State of California's infill policy, which favors development on already urbanized land.

Furthermore, the environmental repercussions of eliminating the greenbelt in this area cannot be overstated. The loss of habitat for key species and the disruption of the biological corridor are at odds with preserving the rural character that defines our community. Introducing high-density housing (10-20 units per acre) in a scenic corridor undermines the very essence of what makes this area unique and raises questions about the adherence to state criteria for affordable housing.

Safety concerns also arise with the increased traffic, as the infrastructure, particularly on Olmstead Road, is ill-equipped to handle the influx. The risks extend beyond traffic to potential flight crash hazards, fire protection challenges, and police resource strains. The development's proximity to critical firebreaks and the potential for increased wildfire risks necessitate a thorough review and consultation with CALFIRE.

Air quality degradation due to additional traffic and idling, along with potential water supply and quality issues, further compound the potential negative outcomes of these developments. The health and safety of current and future residents must be a priority, and I urge a reevaluation of the impact on local air quality and groundwater, particularly considering the known contaminants from Fort Ord.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2004, Packet Page 2332 3/25/24, 9:20 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/2 In conclusion, I implore you to consider alternative infill strategies that utilize existing developed land, such as vacant lots near MPC and Casa Verde, the old courthouse, and hospital, and areas around Cannery Row. These options would mitigate the risks and preserve the integrity of our community.

Sincerely,
Helen Cooper
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2005, Packet Page 2333 3/7/24, 5:07 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/1 Development off Highway 68
mlcorliss
Thu 3/7/2024 10:40 AM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important To Whom It May Concern:

We currently own a home in Monterey County and am dismayed at the the significant number of proposed housing developments near the airport off Highway 68, including the Garden Court development, the 1324 units being proposed by the county and the Boundary Road project with significant units in the Ryan Ranch area. The cumulative effects of this massive undertaking will have significant ramifications to the traffic, lifestyle, environment, air quality, safety, fire and police protection and water availability for those of us who moved here to enjoy these wonderful attributes that Monterey provides. While we understand additional affordable residential development is necessary, I would suggest several of the proposed sites are of particular concern given the high density. I especially am greatly concerned about the proposed 1324 units off Olmstead Road and the city of Monterey's 640 units being proposed for land that was previously designated for education.

Please reconsider the damaging effects these developments will result in and consider alternative sites that would be less damaging to these areas.

Thank you in advance for your consideration.

Sincerely,
Robert & Melanie Corliss
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2006, Packet Page 2334 3/1/24, 1:21 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Resident Concern Letter: Olmsted Development
Frank Darabont
Fri 3/1/2024 9:52 AM
To:Christy Sabdo <[email protected]>
You don't often get email from . Learn why this is important Dear Christy Sabdo,
Hello, my name is Frank Darabont, and I am a current resident of the Monterra neighborhood in Monterey, CA. It's just come to my attention that there is a land overlay bordering Hwy 68/Olmsted Rd/Via Malpaso (to the south of the airport) that is being considered by the county for just under 1,400 units of state-mandated low-income housing development.

While I agree whole-heartedly that affordable housing is needed, and am not opposed to additional residential development in our county, I believe this is a terrible location for a housing project of this density. I'm writing to you with the following concerns:

1. Traffic on Olmsted Rd and Hwy 68:

There is a very important different between inconvenient traffic (a fact of modern life for us all) and catastrophic traffic, which is the type of traffic development of this location would create.

Each unit could be estimated to have 10 trips per day (this includes multiple house members and the frequency of Amazon and other deliveries). An added 13,000 trips per day would add a catastrophic impact to the one-lane highway that services our airport (which is expanding), and provides the only artery for the many commuters who work on the Monterey Peninsula from Salinas and other areas east of here. There is no mass transit in the area to help alleviate this burden.

With the high danger of wildfires in this area, how will Hwy 68 be able to stand in the instance of mass evacuations, or provide clear access for first responders?
When we have severe rain storms, like the one we just endured, and flooding, how will this impact the one-lane highway at this location? How will airport access be affected in these circumstances? How do you plan to mitigate the impact of all this extra traffic? This plan would turn this area from a quiet rural road into a very busy urban road. What is your plan for pedestrian and cyclist safety if you have a considerably high volume of cars in this area?
The city has objected to the development of this area before because of the need for a highway expansion to make it feasible, among other reasons.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2007, Packet Page 2335 3/1/24, 1:21 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 What is your plan for expanding the highway and creating more lanes to this area? Who will pay for infrastructure development of this magnitude?

2. Environmental impact: The area we're discussing is currently home to a significant amount of wildlife, some of them presently endangered (mountain lions, for example). It is also home to a significant number of heritage oak trees.

With a project of this density, how are you proposing to mitigate the impact on this sensitive area?

3. Air quality: The additional traffic, especially considering the projected congestion and car idling, will cause significant deterioration in local air quality, both to onsite residents of the new development to nearby existing populations.

How will this air pollution be mitigated and what is the cost to the county for these measures?

4. Loss of scenic and rural character of the Hwy 68 corridor: The current residential zoning in this area is one home per 10 acres of land in order to preserve the rural character and wildlife preservation of this area.

How does such a high density (10-15 units per acre) fit into this environment without destroying its character? Once it's built, this area will be changed permanently! It cannot be undone!
The removal of this greenbelt is a significant adverse impact aesthetically and visually, as well as being a devastating loss of habitat for many keystone animal species that can be observed on the subject parcel. This area is not just a blessing to the immediate neighbors of the Hwy 68 Corridor, but to the entire Peninsula. Developing this beautiful land that has been a reserve for wildlife for so long will ruin the character of this area, for the entire Peninsula and for the hundreds of thousands of tourists and visitors who came to Monterey for annual events and to enjoy the natural beauty.

How will development of this area impact tourism and the reputation of our area for natural beauty? Instead of arrivals to our airport being greeted with the graceful and timeless open land and trees of this 50-acre parcel, they will be shocked by inappropriate development and catastrophic traffic.

5. Sewage: How will the sewer be managed? Will it be a closed septic system? This is a very expensive system, who will be paying for it on an ongoing basis?

6. Increased requirements for Fire and Police Services: This area is currently rural and development of 1,300+ units would require a dramatic increase in fire and police availability. How would that be managed, and again, who is paying for it on an ongoing basis?

7. Airport proximity: With the planned expansion of the airport, flight noise will be increasing. Given this project's proximity to the airport, flight noise will be a constant problem for the occupants of this new development.

The EPA states that noise levels above 75 dB are harmful and these levels will be exceeded at the site. How will this be mitigated and have you discussed this with the airport authority yet?
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2008, Packet Page 2336 3/1/24, 1:21 PM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 In 2021, we experienced a tragic plane crash in the neighborhood of Monterra, devastating one home and causing several fatalities. There is a potential danger of airplane crashes in this area, and this danger would be increased exponentially given the project's density.

What is your plan for protecting these (endangered) species? Also, with the land being converted into concrete slabs and housing structures, you are removing the natural cushioning that the green belt provides to absorb the noise pollution coming from the airport. With the impending expansion of the airport, this noise pollution will only increase.

What is your plan for mitigating the increased noise pollution from the expanding airport, if the green belt is converted into concrete and housing?
I look forward to receiving your answers to the many questions and concerns I've raised above.

Sincerely,
Frank Darabont
Monterey, CA 93940
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2009, Packet Page 2337 3/1/24, 11:24 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Hwy 68/Olmsted Corridor Development
Rae Darabont
Fri 3/1/2024 8:45 AM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Christy Sabdo,
My name is Rae Darabont, and I am a current resident of the Monterra neighborhood in Monterey, CA. It's just come to our attention that there is a land overlay bordering Hwy 68/Olmsted Rd/Via Malpaso (to the south of the airport) that is being considered by the county for just under 1,400 units of state-mandated low-income housing development.

While I agree whole-heartedly that affordable housing is needed, and am not opposed to additional residential development in our county, I believe this is a terrible location for a housing project of this density. I'm writing to you with the following concerns:

1. Traffic on Olmsted Rd and Hwy 68:

There is a very important different between inconvenient traffic (a fact of modern life for us all) and catastrophic traffic, which is the type of traffic development of this location would create.

Each unit could be estimated to have 10 trips per day (this includes multiple house members and the frequency of Amazon and other deliveries). An added 13,000 trips per day would add a catastrophic impact to the one-lane highway that services our airport (which is expanding), and provides the only artery for the many commuters who work on the Monterey Peninsula from Salinas and other areas east of here. There is no mass transit in the area to help alleviate this burden.

With the high danger of wildfires in this area, how will Hwy 68 be able to stand in the instance of mass evacuations, or provide clear access for first responders?
When we have severe rain storms, like the one we just endured, and flooding, how will this impact the one-lane highway at this location? How will airport access be affected in these circumstances? How do you plan to mitigate the impact of all this extra traffic? This plan would turn this area from a quiet rural road into a very busy urban road. What is your plan for pedestrian and cyclist safety if you have a considerably high volume of cars in this area?
The city has objected to the development of this area before because of the need for a highway expansion to make it feasible, among other reasons.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2010, Packet Page 2338 3/1/24, 11:24 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 What is your plan for expanding the highway and creating more lanes to this area? Who will pay for infrastructure development of this magnitude?

2. Environmental impact: The area we're discussing is currently home to a significant amount of wildlife, some of them presently endangered (mountain lions, for example). It is also home to a significant number of heritage oak trees.

With a project of this density, how are you proposing to mitigate the impact on this sensitive area?

3. Air quality: The additional traffic, especially considering the projected congestion and car idling, will cause significant deterioration in local air quality, both to onsite residents of the new development to nearby existing populations.

How will this air pollution be mitigated and what is the cost to the county for these measures?

4. Loss of scenic and rural character of the Hwy 68 corridor: The current residential zoning in this area is one home per 10 acres of land in order to preserve the rural character and wildlife preservation of this area.

How does such a high density (10-15 units per acre) fit into this environment without destroying its character? Once it's built, this area will be changed permanently! It cannot be undone!
The removal of this greenbelt is a significant adverse impact aesthetically and visually, as well as being a devastating loss of habitat for many keystone animal species that can be observed on the subject parcel. This area is not just a blessing to the immediate neighbors of the Hwy 68 Corridor, but to the entire Peninsula. Developing this beautiful land that has been a reserve for wildlife for so long will ruin the character of this area, for the entire Peninsula and for the hundreds of thousands of tourists and visitors who came to Monterey for annual events and to enjoy the natural beauty.

How will development of this area impact tourism and the reputation of our area for natural beauty? Instead of arrivals to our airport being greeted with the graceful and timeless open land and trees of this 50-acre parcel, they will be shocked by inappropriate development and catastrophic traffic.

5. Sewage: How will the sewer be managed? Will it be a closed septic system? This is a very expensive system, who will be paying for it on an ongoing basis?

6. Increased requirements for Fire and Police Services: This area is currently rural and development of 1,300+ units would require a dramatic increase in fire and police availability. How would that be managed, and again, who is paying for it on an ongoing basis?

7. Airport proximity: With the planned expansion of the airport, flight noise will be increasing. Given this project's proximity to the airport, flight noise will be a constant problem for the occupants of this new development.

The EPA states that noise levels above 75 dB are harmful and these levels will be exceeded at the site. How will this be mitigated and have you discussed this with the airport authority yet?
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2011, Packet Page 2339 3/1/24, 11:24 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/3 In 2021, we experienced a tragic plane crash in the neighborhood of Monterra, devastating one home and causing several fatalities. There is a potential danger of airplane crashes in this area, and this danger would be increased exponentially given the project's density.

What is your plan for protecting these (endangered) species? Also, with the land being converted into concrete slabs and housing structures, you are removing the natural cushioning that the green belt provides to absorb the noise pollution coming from the airport. With the impending expansion of the airport, this noise pollution will only increase.

What is your plan for mitigating the increased noise pollution from the expanding airport, if the green belt is converted into concrete and housing?
I look forward to receiving your answers to the many questions and concerns I've raised above.

Sincerely,
Rae Darabont
Monterey, CA 93940
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2012, Packet Page 2340 3/14/24, 8:33 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 1/3 Significant concern with 640 unit development off Highway 68 Dale & Caroline DePalatis
Wed 3/13/2024 7:46 PM
To:Christy Sabdo <[email protected]>
You don't often get email from why this is important
Dear Ms. Sabdo:

We are nearby residents of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area.  Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California.  While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

The two I especially object to are the County's 1324 units being proposed off Olmstead Rd and the city of Monterey's 640 units being proposed for land that was previously designated for education.  Both of these projects violate the State of California's desire for infill on already developed land and pose significant risk, including:
*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be estimated that Monterey's proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day.  This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows.  The assumption is 2.5 car trips per housing unit per day).  The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area.  What is the plan to mitigate the impact of all this extra traffic?
*Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character.  It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest.

Does the County understand the implications of eliminating this biological corridor?  The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area.  How does such a high density (10-20 units per acre) fit into this environment?   I don't understand how a designated scenic corridor can be turned into a high density set of houses and roads.  That is not in the spirit of what California state criteria is for affordable housing. *Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in and out.  Is this also going to be onto Olmstead Road through the County's development?  Olmstead Rd would go from a quiet rural road to a very busy urban one.  What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2013, Packet Page 2341 3/14/24, 8:33 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/3 *Flight Crash Risk. 2 years ago, there was a crash into an unoccupied single-family home in the Monterra neighborhood. If such an incident were to occur in a high-density community, there could be a substantial loss of life. Similar incidents have occurred in California (i.e. Truckee with a private jet, as well as Naples FLA recently).  Has the city of Monterey and County consulted with Monterey Regional Airport on the flight crash risk specific to the subject property?
*Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE  depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed.  Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor? *Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk? *Air Quality. The additional traffic, especially considering the projected congestion and idling, will cause significant deterioration in local air quality, both to onsite residents of the new development and to nearby existing populations. The specific pollutants of public health concern are sulfur dioxide, oxides of nitrogen, carbon monoxide and carbon fibre from tyres. Is the County aware that approximately 20,000 deaths per annum occur in the United States from these air pollutants?  How will this be mitigated for current and future residents? *Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord.

It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood.

See for example:  Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

Thank you for including our input.  I would encourage you to look at using ADUs and other infill strategies using land that has already been developed and is not being fully utilized, such as empty lots next to MPC and Casa Verde, the old courthouse and hospital, as well as parcels around Cannery Row. Or what about finding some land in Fort Ord?
Sincerely,
Dale and Caroline DePalatis
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2014, Packet Page 2342 3/21/24, 10:11 AM Mail - Christy Sabdo - Outlook
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Jackie Hamilton
Wed 3/20/2024 3:56 PM
To:Christy Sabdo <[email protected]>
You don't often get email from Learn why this is important Dear Ms. Sabdo:

I am writing to provide you with my comments regarding the Draft EIR for the Monterey 2031 General Plan Update. I have resided on Oak Tree Place for the past 27 years. After discovering the proposals for this area, I have become extremely concerned and alarmed at the potential impacts these plans would have on this area in order to meet state mandates. I believe this plan will do way more harm than good and other, more compatible, sites must be identified on the peninsula to meet these requirements. This is an important, sensitive and already heavily encroached area that is becoming more and more strained as the Garden Road area and other sites down the highway continue to be developed. We must leave this open space or the entire area will become a dysfunctional gridlock. We have been very close to fire evacuation twice and as we live on the edge of a pine preserve this is an extremely volatile area for fire. How on earth would we all escape should a fire hit the Jacks Peak area? As a highly dense forest filled with flammable pines, we constantly consider how quickly our homes will be threatened ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2015, Packet Page 2343 3/21/24, 10:11 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 2/7 should fire spark in that forest. With two lane roads and an already congested highway, how on earth would we all escape should this area be developed further? Freeway traffic is so congested in the mornings and afternoons that commuters are utilizing the rural route from hwy 68, through upper Aguajito Road and across Olmsted Road to the Salinas Highway. This two lane road has become a speedway, too dangerous to walk, cross over, bike ride or pull out onto. I cannot even fathom what this massive additional population would do to this already dangerous situation.

Wildlife has very little open space left to hunt, forage and travel. It is not unusual on any given day to see coyotes and deer crossing through. We have had many visits by mountain lions and bobcats in our yard. At one point a black bear even visited. Please don’t take this remaining land from them. They are not less important than humans.

The proposed housing plan for the City of Monterey includes developing a 50 acre parcel on Highway 68. Developing this parcel would have a significant negative impact on the Highway 68 Scenic Corridor and on the environment, in general, especially as it would increase traffic congestion on Highway 68 and the surrounding rural roads. The parcel is in an area that is labeled as a “highly sensitive viewshed.” There has already been extensive development in the Highway 68 Scenic Corridor as evidenced by the airport runway extension, the Highway 68 car condos, and the Montage Ohana building ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2016, Packet Page 2344 3/21/24, 10:11 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 3/7 that was inexplicably allowed to loom over the highway. At least, the south side of the highway has maintained a scenic rural character. If that is now developed, the designation of Highway 68 as a scenic corridor would be in jeopardy.

PROPOSED PLAN BASED ON UNREALISTIC PROJECTIONS
The Proposed Plan outlined in the City of Monterey Document is based on what seem to be unrealistic projections of population growth and corresponding housing needs. The population of Monterey has actually decreased by 2.2% over the past 3 years and is projected to continue to decrease. The source of these projections, AMBAG, states that employment drives growth, but projected employment growth does not support the numbers used as the basis for the proposed housing development plan. The Proposed Plan assumes that, by 2031, employment in Monterey will grow by 8.3%, but population will grow by 37.6%, and somehow that necessitates a 41.9% growth in housing units.

For each new job, it is proposed that approximately 5 people will move to Monterey. Is population growth outpacing employment growth due to the birth rate and/or due to the number of unemployed (potentially retired) people expected to move to Monterey? If it is the birth rate, it should be noted that children live in the same housing unit as their parents so there should not be a need for 3 times as many housing units as new jobs, as is proposed.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2017, Packet Page 2345 3/21/24, 10:11 AM Mail - Christy Sabdo - Outlook
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PROPOSED PLAN CONFLICTS WITH PROJECT OBJECTIVES
The Proposed Plan, which includes development of the 50 acre parcel on Highway 68, conflicts with six of the specific objectives, or goals, for the project as outlined in the report. Goal 1 states that the plan should address the regional housing needs (RHNA) but, as mentioned above, Monterey appears to be planning for many more new units than are necessary to meet projected needs. It leads one to wonder if perhaps the Highway 68 parcel is included because an influential developer would like to build on it at the expense of the Highway 68 Scenic Corridor, the environment, and the general enjoyment and welfare of the community.

Goal 6 states that the City of Monterey should “ encourage new housing in locations supported by existing or planned infrastructure, while maintaining existing neighborhood character.” There is no existing infrastructure on the 50 acre Highway 68 parcel and the neighborhood character is low density residential and rural so the proposed plan does not meet goal 6.

Goal 7, entitled “Maintain Existing Housing” , states that the city wants to “assure high quality maintenance, safety, and habitability of existing housing resources.” If this is so, why not have programs to rehabilitate and remodel existing housing, especially in core areas of the city? If you build an excess of new housing and significantly increase ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2018, Packet Page 2346 3/21/24, 10:11 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 5/7 vacancy rates and decrease rental rates, it is well known that landlords will not be willing or able to maintain existing properties. The result will be some nice new buildings along Highway 68 while the appearance of Monterey's central district continues to degrade.

Goal 8 states that appropriate housing sites “are proximate to transportation, shopping and schools…” This goal is in line with the State of California’s goal to promote infill as a way to promote sustainability and minimize negative impacts on the environment. The parcel on Highway 68 does not meet this goal. It is not infill and would require residents to use cars to get to work and for all errands. It is not on a major transit route and it has a very low walk score.

Goal 12 states that the Proposed Plan should be consistent with the Airport Land Use Compatibility Plan (ALUCP) yet development of the 50 acre parcel blatantly violates this stated goal. According to ALUCP, the parcel is in Zone 3, where all residential development is prohibited, except low density and infill in already developed areas.

Goal 9 states that the Proposed Plan should “support a vibrant local economy.” This goal is what is used to promote the Proposed Plan over the “Increased Workforce Alternative Plan.” The City of Monterey report states that the Increased Workforce Alternative Plan is environmentally superior to the Proposed Plan as it avoids significant and unavoidable ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2019, Packet Page 2347 3/21/24, 10:11 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 6/7 impacts to agricultural resources and air quality. However, the City of Monterey rejects the Increased Workforce Alternative Plan because it does not support local economic vitality to the same extent as the Proposed Plan does. This is in direct contradiction to the stated facts! Goal 9, which discusses economic vitality, states that there should be a balance of jobs and housing so that those who work in Monterey can afford to live in Monterey but the report also states that with the Proposed Plan, low wage hospitality and tourism workers would increase their vehicle miles traveled (VMT). So isn’t the Increased Workforce Alternative Plan better for low wage workers, better for the environment, and better for everyone else as it reduces traffic congestion and air pollution and maintains the scenic beauty of the Highway 68 Corridor? Finally, why not embrace a hybrid plan? Development of the land on South Boundary Rd, as described in the Proposed Plan, makes sense as it’s within walking distance of jobs at Ryan Ranch. Why not implement part of the Increased Workforce Alternative Plan but also develop housing along Boundary Rd? Boundary Rd. is not part of a recognized scenic corridor and would be much less likely to add to traffic congestion on Highway 68. In keeping with the State of California’s guideline for higher density units that are infill, the City of Monterey could modernize and further develop areas that could use revitalization without destroying the natural beauty and rural character that attracts tourists to visit and retirees to relocate to the Monterey Peninsula.

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2020, Packet Page 2348 3/21/24, 10:11 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauCRO%2B0TS3sBwBM%2FAwa938OT7ZqAdJ6D5c… 7/7 Thank you for your time and consideration of my input.

Jackie Hamilton
Monterey, CA
831.917.0769
Sent from my iPad
[NOTICE: This message originated outside of the City of Monterey mail system -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2021, Packet Page 2349 ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2022, Packet Page 2350 Subject: Significant concern with 640 unit development off Highway 68 I am a nearby resident of the proposed housing project for 640 units off Highway 68 currently owned by the Monterey Peninsula School District. I'm shocked with all the development being proposed all around the airport/68, including the Garden Court development, the 1324 units being proposed by the county, and the Boundary Road project with significant units in the Ryan Ranch area. Does anyone care about the cumulative effects of all these developments on an area that already is struggling with traffic and was designated a scenic corridor? Many of us moved to this area to escape the urbanization and densification in other parts of California. While I support the need for additional residential development that is affordable to ensure hard working people can afford to live and work in Monterey County, several of the proposed sites are of particular concern especially given the high density.

The two I especially object to are the County's 1324 units being proposed off Olmstead Rd and the city of Monterey's 640 units being proposed for land that was previously designated for education. Both of these projects violate the State of California's desire for infill on already developed land and pose significant risk, including:

Violation of the City’s own objective #6: “ …. Maintaining existing neighborhood characteristics” (pg ES-3). The proposed plan would significantly effect the current neighborhood in a very bad way.

*Traffic on Olmstead Road and Highway 68, including the proposed roundabout: It can be estimated that Monterey's proposed development could generate up to 1600 extra cars per day and the County's project 3250 extra cars per day. This would be approximately 5000 more cars in an area already dense with traffic and backups, especially during commute windows. The assumption is 2.5 car trips per housing unit per day). The expansion of the airport facilities and new apartments on Garden Rd and proposed housing on South Boundary Rd and the current courthouse off Aguajito Rd. would make traffic even worse. Enormous costs of widening Hwy 68 would be paid for by taxpayers. There is currently no mass transit in the area. What is the plan to mitigate the impact of all this extra traffic? *Environmental impact and vanishing Greenbelt: The removal of this greenbelt is a significant adverse impact aesthetically and a huge contrast from the scenic easement that gives this area such a special character. It is also a loss of habitat for many keystone animal species that can be observed on the subject parcel. Frequent observations occur of Apex/keystone species such as Mountain Lion, Bobcat and Coyote as well as many avian species of special interest. Does the County understand the implications of eliminating this biological corridor? The current residential zoning in this area is one home per 10 acres to allow for new residential development, while still preserving the rural character of this beautiful area. How does such a high density (10- 20 units per acre) fit into this environment? I don't understand how a designated scenic ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2023, Packet Page 2351 corridor can be turned into a high density set of houses and roads. That is not in the spirit of what California state criteria is for affordable housing.

*Pedestrian and Bicycle safety: It is not clear the roads in and out of the 640 unit housing complex since there would need to be at least one additional road for entry in and out. Is this also going to be onto Olmstead Road through the County's development? Olmstead Rd would go from a quiet rural road to a very busy urban one. What is the plan for pedestrian and bike safety with a high volume of cars coming in and out onto Olmstead on both sides of the street? Are you planning to access the development directly from Highway 68? This would also pose significant safety risks.

*Fire Protection. This development would come with extraordinary expense of added fire response personnel and equipment. This is compounded by traffic jams adding to response times. Additionally, one of the important functions of the existing greenbelt zoning gives the entire community an important firebreak. CALFIRE depends on this parcel for fire protection of this whole region. These parcels were an important staging area for firefighters during the last fire just three years ago and we would lose that critical capability if this land were to be developed. Does the city of Monterey and County comprehend the magnitude of additional risk of wildfire this abandonment of firebreak will produce, given the forest densities to the east and west? Is the city of Monterey and County prepared to assume liability for a future wildfire disaster, which could have been prevented by preservation of this critical firebreak? Has the County consulted with CALFIRE on the details of how this firebreak is vital to community safety along the entire Hwy 68 corridor?

*Police Protection. This proposed rezoning will place an untenable burden on our existing police resources, which already are in critical shortage. This is not only a public safety threat, but also an extraordinary economic impact by placing 3000 new residents with the county's Olmstead development and ~1500 with Monterey's development in locations, which are not even conveniently serviced for the expected demand level. Has the Monterey County sheriff been consulted and are they prepared to handle this high density loading and increased risk?

*Quality and Availability of Water: If the moratorium on drilling wells is lifted, is there data to support that the onsite wells can provide sufficient healthy ground water for over 3000 new residents for the County development and ~1500 for the Monterey city development without being a detriment to the current ground water supply? It is well established that there are a number of carcinogenic and toxic chemicals in the groundwater emanating from Fort Ord. It is also known that this subsurface water plume is presently moving in the direction of the proposed rezoning parcel, if not already present beneath the subject parcel. This is a serious threat to residents of the subject parcels, particularly to children who will predictably explore the soils of their neighborhood. See for example: Cancer cluster at Fort Ord: Sick vets wonder, are there more of us? (thecalifornian.com) .

ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2024, Packet Page 2352 Thank you for including my input. I would encourage you to look at using ADUs and other infill strategies using land that has already been developed and is not being fully utilized, such as empty lots next to MPC and Casa Verde, the old courthouse and hospital, as well as parcels around Cannery Row.

Randy Hamilton
ATTACHMENT 1 / EXHIBIT A
Council Regular Meeting, 7/16/2024, Item No. 15., Item Page 2025, Packet Page 2353 3/26/24, 8:14 AM Mail - Christy Sabdo - Outlook
https://outlook.office365.com/mail/inbox/id/AAMkAGVlZjBmYTIwLTZmZTAtNGFkMy05M2YwLWNmY2E4ZmY1NWIzMABGAAAAAADidRUKlyk8RauC… 1/1 Olmsted Road / Tarpy Flats area development
Meredith Harrill
Mon 3/25/2024 5:59 PM
To:Christy Sabdo <[email protected]>
[You don't often get email from Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
Christie Sabdo,
I wish to express my disapproval of development of the Olmsted Road area.  There are other areas where infill development could  be done where infra-structure and nearby amenities are already in place.

There are multiple limitations in the Olmsted area regarding water, sewage, traffic, environmental impacts, safety, HWY 68 impacts, fire and noise.

I think we can do much better.

Thank you for considering these concerns.