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On April 13, Cal Am wrote a letter to the Peninsula Mayors Water Authority, responding to a letter from Public Water Now and other parties citing “alarming deficiencies” on the Monterey Peninsula Water Supply Project (MPWSP). The letter from Public Water now cited lack of water rights and poor science surrounding the slant well ocean intakes proposed for the Cal Am desalination plant.

The Cal Am letter was signed by desal project manager Ian Crooks. An excerpt follows:

The most definitive and best science to determine the feasibility of slant wells is to drill and operate an actual slant well in the proposed project location and observe its performance. Cal Am’s test slant well at the CEMEX property in Marina has accomplished just that and proven unequivocally over its 480 days of pumping that slant wells are a feasible technology for our project. The important indices are yield, reliability and water quality, and results in all three areas are outstanding. (Italics and bold added)

I wish to rebut this statement as vigorously as I can.

Traditional “scientific method” would support Mr. Crooks’ first sentence. Scientific method requires a hypothesis, and the hypothesis of this “experiment” is that a slant well can sustain a continuous extraction rate of 2,000 gallons per minute (gpm) from the proposed location without harming the groundwater. Extensive modeling by notorious hydrogeologist Dennis Williams, president of GeoSciences, was presented in the first environmental impact report iteration in 2015, and was modified by HydroFocus and Lawrence Livermore Labs in the recirculated version now pending. This extensive modeling “finds” that the hypothesis is correct and therefore that the damage to the existing surrounding coastal aquifers of the Salinas Valley River Basin is “insignificant.”

This is where a test slant well comes into play: To test the modeling work with a field test. This is also sound experimental design based on the scientific method. However, it is at this point I must diverge from Mr. Crooks and his statement highlighted in bold above. Let’s examine the “outstanding” results of the thre indices, one at a time: Reliability, yield and water quality.

Reliability

The long-term pumping test began on April 22, Earth Day, 2015, which was 722 days before Mr. Crooks’ letter to the mayors. Assuming he accurately represents that the pumping had continued for 480 days as of April 13, that means the pump had been idle for 242 days, or just over 33 percent of the total time. Who in their right mind would rate a 67 percent reliability performance as outstanding? When I was going to public high school that rate of performance was known as “a D.”

Yield

CalAm has consistently made claims, widely reported in the local papers and public meetings, that the slant well yield has “exceeded expectations,” steadily drawing between 2,000 and 2,200 gallons per minute (gpm) when it is operating. But here is the problem. There is no evidence or data to support the claim within the public sphere. The current EIR presents no such information. The Hydrological Working Group (HWG), a team of hydrogeologists including Dr. Williams, monitor and measure the well’s performance as required by its permit issued by the California Coastal Commission. The HWG is required to post weekly reports on the public website www.watersupplyproject.org and submit monthly reports to the acting director of the Coastal Commission, which are also posted on the website. The monthly reports are nearly 1,000 pages, reporting minutiae gathered electronically every five-15 minutes about the groundwater and salinity levels at the monitoring wells. Yet the yield results about how many gallons of brackish water are being sucked through the slant well and tossed out to sea through the existing outfall pipe appear nowhere in any of the documentation of these lengthy reports.

As far as “yield exceeding expectations,” you will just have to take Cal Am’s word for it, and surprisingly, everyone seems to (and are damned jolly that it is going so well!) However, in my experience, I have learned to never take Cal Am’s word for anything. Except when they tell us our rates are going up. I always believe them then.

Water Quality

Cal Am reports about water quality are focused solely on the level of salinity of the water drawn through the slant well. The company hopes for a salinity percentage as high as possible. The higher the seawater percentage (i.e. the percent salinity of the brackish water), the lower the percentage of fresh water coming from the landward aquifers and the less water that has to be delivered to Castroville to satisfy the agency act in the “return water agreement.” The agreement is a ridiculous plan cobbled together by politicians, bureaucrats and lawyers that could cost ratepayers millions of additional dollars annually and would require an entire essay to describe its stupidity in detail.) These folks are relatively pleased that the salinity was recently measured at 92 percent seawater. However, the percolating winter deluge will likely dilute that percentage, pumping even more freshwater out to sea this spring. They predict and hope that salinity at the slant well will rise to the target level 96 percent seawater or higher once they install sevem more production slant wells, and start sucking out groundwater at over 10 million gallons per day.

You might be wondering how such a volume of pumping could be expected to have “insignificant impact” on the surrounding aquifers and so do I. It seems like magic, and I suspect magical thinking here regardless of what the extensive modeling in the EIR predicts. Fortunately, the test slant well experiment has provisions to collect data on this aspect. Monitoring wells in the area help determine what is going on in the groundwater near the slant well pump.

So, what has happened at the threshold monitoring well in the 480 days out of 722 of the long-term pumping test as of April 13, 2017? The answer is that the salinity has steadily and “very slightly” risen by over 25 percent in that time. That is an alarming number! This result is further accentuated by the fact that in the 26 days prior to the beginning of any slant well pumping (the only baseline there is at the site) the salinity at the threshold well actually dropped by 2.2 percent.

Rising salinity at this spot indicates significant rising seawater intrusion into the basin. Mr. Williams and the HWG claim that these results are unrelated to the impact of a single test slant well operating only 67 percent of the time. They say it is for other reasons, but they do not quantify nor verify those claims with data.

The science is poor because the scientists have a predetermined outcome that goes beyond normal bias. But what can you expect when you are examining science reports from Cal Am and its Crooks?

Michael Baer is a retired public school science teacher,  a 30-plus year resident of the Monterey Peninsula, and a local water activist.

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The following is my Aug. 7 letter to the California Coastal Commission’s executive director, Charles F. Lester, regarding the Cal Am test well:

Dear Mr. Lester,

Public Water Now (PWN) is the group that discovered the patents owned by Dennis Williams and Geoscience. PWN alerted the public about potential conflicts of interest. PWN is also the group that has harped on the phrase issued by the State Water Resources Control Board about pursuing subsurface intakes, “if feasible,” prior to pursuing other options.

I am writing to alert you to related issues that I hope you consider in the review of an amended permit for Cal Am, and the follow up monitoring and evaluation of data and circumstances re this test slant well.

PWN is well aware of the desire by you, the State Water Resources Control Board, California Public Utilities Commission, and others in the state that want a successful subsurface intake for desal facilities. PWN is also aware of the environmental reasons, and we do not disagree.

But PWN strongly objects to several factors that are in play, and you have a role in considering them.

How does the CCC remain objective and focused on the facts when it has a obvious public policy to support subsurface intake? PWN questions the depth of objectivity CCC will bring if the overlying policy goal is a successful subsurface intake for desal. Will CCC go the extra mile to guarantee its objectivity and interest in validated data and analysis? Is the CCC open to looking beyond the face value of the data it receives?

The patent royalty relationship between Dennis Williams/Geoscience and the driller –Boart Longyear – has not been queried. Is it possible that substantive financial relationships exist between these two that could cause the data to be skewed to serve ulterior motives? Will CCC look into the contract relationship between Williams and Boart Longyear? Will CCC determine there are no royalty and shared self interests in the contracts or in the actual test well operations that could skew their reports?

Will CCC question the financial relationship of these key sources of data and opinion?

PWN has felt for some time that the specific test period got cavalier treatment by the CCC. I made this very point at your hearing in November 2014 on the initial permit. Since slant wells are not in use anywhere in the world, how can CCC not absolutely insist on a valid test period? Not knowing what is a valid period, surely sophisticated professional attention is required. What is a valid test period? Will CCC opine on this? Will CCC prescribe a valid duration for the test period?

The only known subsurface intakes for desal have occurred in California – Dana Point and Sand City.

1) Dana Point results after 18 months of test slant well pumping are these: no conclusions on viability; some sand infiltration problems; and pumping efficiency declined from over 90% to about 55% over 18 months.

2) The data from the Sand City vertical subsurface wells for a small 300 acre foot/year plant shows actual pumping efficiency over 4 year of operation to be in serious decline:

From Sand City Public Works, calendar year:

  • 2011 96.8%
  • 2012 69.6%
  • 2013 64.8%
  • 2014 60.8%

From Monterey Peninsula Water Management District, water year

  • 2011 91.9%
  • 2012 80.7%
  • 2013 62.3%
  • 2014 59.5%

This data on Sand City tells a very negative tale about reliability, and therefore viability. Why does pumping efficiency with subsurface intake decline so significantly over a few years? Dana Point and Sand City data clearly make this point! Has the CCC considered this? This is why a valid test period is critical. Experience so far does not dictate a “full speed ahead” mentality. In fact it screams out for caution. And to be skeptical about any optimism about short term data. The telling will be in the testing, and in the duration, not the first data available.

Will CCC require a legitimate test period of two years or more? Remember, Cal Am originally proposed a two year test period. But with unexplained lower performance at Sand City, is two years adequate?

Every diagram example in all sources describe slant wells as penetrating far enough under the sea floor to extract water from beneath the sea floor. The intent is clear – to avoid aquifer interference, and perhaps to avoid related water rights claims. But the Cal Am test well does not penetrate the vertical line at the mean high tide line. It stops landward of that line. Would this “test well” meet your normal standard for a test of under sea floor intake? The fact that it did not extend under the sea floor area should raise questions about design or engineering?

Was the drilling length too risky or difficult? Was the drilling capacity limited in some way? Is this an issue for feasibility? Was the design under the patents too limiting? Should horizontal directional drilling still be an option? Are there more experiments that should take place? Did the insistence on the removable casings create engineering demands that were excessive? Could the guidelines from the State Water Board have established too high a level of outcome that was too expensive for success? The fact of a shorter test well length than intended (by the proponent, the patent holder and the public promotion) must get questioned regarding its use as a “test”?

Furthermore the plan of Cal Am to proceed directly from a short test period into a development permit for nine production wells makes a farce of all the publicity about the “test well” being a legitimate test well! The plan of Cal Am is based on assumptions, not tests. There are enough questions about long term performance reliability and cost acceptability that should ring alarm bells at the CCC, and elsewhere.

Working out the details and the costs of this experiment should not fall on the ratepayers. This is a state-sponsored requirement, and should have significant state funding. I doubt you have access to funding assistance. At least you might acknowledge the unfairness of the state, and the corporate utility, foisting this unproven and little scrutinized experiment on ratepayers.

The CCC, having jurisdiction over the efficacy of slant well impacts, and having a deep interest in the long term success of subsurface intakes, should have a particular interest in seeing that it is done right. This is too new for the CCC to feel comfort in self-interested promoters and contractors.

Whatever happened to the precautionary principle?

If there is to be a successful test, there must be conscientious and professional attention to the fact that slant wells have never been successfully constructed and become operational anywhere in the world.

Costs can become astronomical, and should not fall exclusively on local ratepayers. State resources must be made available, since it is a policy goal of several state agencies for subsurface intakes. And the facts of declining pumping efficiency should also raise alarms.

We sincerely hope you will take these issues into account during deliberations and analysis of Cal Am’s amended permit.

Respectfully,

 

George T. Riley
Managing Director
Public Water Now

Emailed to: tom.luster

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Cal Am’s latest desal delay is its own damned fault

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For the past couple of years now, California American Water and its various partners have told us that time is of the essence, that its plans for a $400 million-plus desalination plant must proceed at all costs. The threat of a state-ordered cutback on water use looms large, especially over the hospitality industry, the Peninsula’s largest economic driver.

So when environmentalists have raised concerns about the impact of drilling giant wells under the beach, when those of a technical bent worried aloud about the integrity of the pre-construction testing process and the potential impact on groundwater near the plant site, when people concerned about the high cost of mistakes pointed out a glaring conflict of interest among the project team, they were all dismissed as obstructionists.

“They” are trying to stop the project, we were told, though “they” were never really identified. (The working definition of the so-called obsctructionists might be anyone who isn’t being paid to advance the project or doesn’t stand to receive a direct financial benefit.)

Those arguing that state environmental laws should be not be ignored for the convenience of the engineers were called tree huggers or worse, shills for potentially competing projects. Though they have found themselves in an emergency of their own making, Cal Am and its bedfellows argue that there have been too many delays already and rules are meant to be broken if it is in the interest of speed and commerce.

And now comes another significant setback for the project. Ruling Extending EIR Deadline for MPWSP Whose fault? Those damned obstructionists? Not hardly.An administrative law judge for the Public Utilities Commission ruled Thursday that the bureaucratic timetable must be set back three months because one of the key figures in the well-testing process is wearing too many hats. There are things to be sorted out, said an exasperated judge, Gary Weatherford.

Here is today’s Herald story on the ruling.

It seems that Dennis Williams of Geoscience is working for just about everyone involved in the well testing, including both Cal Am and the PUC, and he also holds a patent on the technology being tested. In other words, he was being paid by the PUC and the company preparing the environmental impact report on the project to help test Cal Am’s test wells of his design while also being paid by Cal Am. What could possibly go wrong?

So now expect to be told that this is an unnecessary delay caused by “those who would destroy the project.” But the truth is that this is the fault of those making the decisions on behalf of Cal Am and the Public Utilities Commission. This is not the handiwork of obstructionists. This is another breakdown in the procedure, a result of arrogance.

True, some of those who aren’t big fans of the project did notice the conflict and pointed it out but the powers that be on this project already knew all about it. If they say they didn’t, they will either be lying or admitting to grotesque incompetence. Google Dennis Williams and Geoscience and see how long it takes for you to spot the problem and say, “Oh, my.”

Williams is highly qualified for the work involved and it is entirely possible that he can segregate his functions properly and provide accurate assessments, at least according to his own standards. But that should have been discussed openly by the various parties – including the public – right from the start. Not now, after the media demonstrated that the PUC’s experts couldn’t even find a private well near the test site. Not now, after unexpected decline in groundwater in the area suggests the test well isn’t working as it is supposed to. Now now, after Cal Am’s customers have been put on the hook for some $10 million in testing costs, costs that will come straight out of customers’ pockets no matter how any of this turns out.

It could be that Williams was the best choice for the job and should have been hired. But doing that right would have required putting his various entanglements on the record, and you know what can happen when the public knows too much.

Weatherford’s ruling comes just a week at the Coastal Commission ruled that Cal Am needs to do some more work on its well testing program, which begs the question of whether Cal Am could have accomplished more early on by refining its testing plan rather than scratching and clawing to fast track it through the regulatory processes in the first place.

It could be that under current standards of public works construction, it isn’t possible for a project to be built without compromises of quality, design and process. Maybe there is corruption and self-dealing in every venture beyond some certain financial threshold. Maybe it’s $100 million. Maybe it’s whatever Cal Am’s budget calls for.

From Cal Am’s perspective, Tom Moore fits right into the obstructionist category. He’s on the board of the Marina Coast Water District, which once was a partner in Cal Am’s desal efforts, a partnership that fell apart spectacularly when it came out that a former county water official, Steve Collins, was being paid under the table for consulting work on the project. Now there is litigation and Monterey County and Cal Am and Moore’s district are trying to make each look bad and, for the most part, succeeding.

But Moore is also well positioned to comment on the swirl that the desal venture has become. Here’s his take.

“Given the history of the Regional Desalination Project and what happened to Steve Collins, logic would dictate that Cal Am and the CPUC would carefully vet ALL of their consultants and contractors to ensure there wouldn’t be even the slightest whiff of the appearance of a conflict of interest.  And logic would also dictate that any consultant or contractor thinking about working for either the CPUC or Cal Am on the Monterey Peninsula Water Supply Project, or both in this case, would consult with competent attorneys and disclose, disclose, disclose in order to stay the hell away from even a remote possibility of a conflict of interest.  Unfortunately, it seems logic was not at work here.

“What does appear to be in abundance in this entire debacle is an appalling belief:  that when it comes to making more money for your shareholders and yourself, the ends always justify the means.  The withholding of critical information from customers and the public, the concealment of conflicts of interest, twisting the truth and even outright lying seem to be coin of the realm for the folks who hold this appalling belief.  It’s a very unfortunate commentary about private commerce today that $20 million $30 million will buy a lot of this sort of dishonesty.”

As it stands, the process leading to a possible desalination plant has become littered with thorns. Supporters of this project feel they must barrel through it all and demonstrate certitude  even though they has never built such a plant or maneuvered through such a process. They apparently feel that to stop and listen to anyone who isn’t on their desal team might be seen as a sign of weakness, so they choose to ignore all the noise from the bleachers. “They’re just trying to stop the project.”

And while that might be true for a few, many, many who have been watching and weighing in on the desal project for a decade now want only for the project to be completed as efficiently and cleanly as possible. And, just in case, they want officials to continue considering alternative projects that likely would not be as expensive or environmentally intrusive. There are many who don’t trust Cal Am and fear that special deals with the hospitality industry will leave everyone else paying exorbitant amounts for water. But they also understand that the river needs to be protected and an additional water supply is required. What they want is for Cal Am and the PUC to do a better job.

Cal Am averted a public takeover effort partly by convincing the public that it can do a better job than a public agency. Since then, the company has have presented no evidence of that. If there was generalized trust that Cal Am and its boosters were capable of getting it done on their own, and keeping costs at least somewhat under control,  the noise surely would die down. But what has gone down instead is the trust level, and there may be no end in sight unless Cal Am et al change their ways.

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