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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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Clean Drinking WaterThe draft environmental impact report on Cal Am’s proposed desalination plant concludes that the controversial operation would have “less than significant” impact on groundwater, salt water intrusion and Monterey Bay water quality, the subjects of serious concern among opponents of the slow-moving project.

The report was made public Thursday on the state Public Utilities Commission website, setting off a 60-day comment period.

Environmental Science Associates, which prepared the dense, 1,700-page document, also concludes that construction of a smaller plant obviously would have less of an environmental impact even if combined with a new groundwater replenishment project.

Environmental groups and the Ag Land Trust, which owns property next to the project site on the Cemex property north of Marina, have contended that the plant’s pumps would illegally suck up fresh water belonging to others, including water long claimed by Salinas Valley growers. The EIR agrees that fresh water would be drawn in, possibly more than Cal Am’s engineers expected, but it estimates that the plant would draw down the water table in the area by no more than a foot. It labels that a less than significant impact, one that would not require any mitigation.

The report mentions that the Ag Land Trust says it operates a well about a mile from the plant site but an EIR subcontractor couldn’t find it and the State Water Resources Control Board has no record of it. The trust has been sharply critical of the project.

It is possible, according to the report, that the desalination operation actually could ease seawater intrusion by drawing fresh water toward the ocean.

The report says brine discharged by the plant would violate water quality standards in the bay but indicates that the damage could be mitigated. Some scientists have opined that the brine is likely to settle on the floor of the bay and create a dead zone.

Clean Drinking WaterCal Am is under pressure to create a new water supply because of a state order that it dramatically cut back on its use of Carmel River water by the end of next year. With the desalination process slowly slogging through the engineering and regulatory processes, local officials have given up on the 2016 deadline and are pleading with state officials to push the deadline back by several years.

Copies of the report are available at the Monterey Peninsula Water Management District and Monterey Regional Water Pollution Control Agency offices in Ryan Ranch, at the Marina and Seaside community development departments and at some area libraries.

A series of public meetings is scheduled to start May 26 at the Marina library.

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