California Coastal Commission Executive Director’s Determination RE: Condition Compliance – Special Condition #11 of Coastal Development Permits (“CDPs”) A-3-MRA-14-0050 and 9-14-1735 for California American Water’s (“Cal-Am’s) slant test well project in Marina, Monterey County

ABSTRACT: In a letter from Charles F. Lester, Executive Director, California Coastal Commission, to Ian Crooks, P.E., Engineering Manager, California American Water Company, dated July 3, 2015, Dr. Lester states in the Executive Director’s Determination, as follows: Special Condition 11 requires, in part, that Cal-Am stop its pump test if monitoring shows more than a 1.5-foot decrease in water levels at Monitoring Well 4. It also requires the HWG to examine the monitoring data to determine the causes of the water level decrease and to submit its determination to the Executive Director. We reviewed the above-referenced letter, along with the HWG’s follow-up June 22, 2015 letter, weekly monitoring reports, and a June 25, 2015 submittal by Remy Moose Manley, all of which address various aspects of the pump test, monitoring results, aquifer characteristics, and regional and seasonal pumping regimes. The June 22nd HWG letter notes that there are likely several influences other than Cal-Am’s pump test, but that the test could be responsible for about 0.2 to 0.5 feet of the decrease.2 Based on our review, we have determined that the water level decrease appears to be caused in part by the pump test. Pursuant to Special Condition #11, Cal-Am must therefore submit an application for a permit amendment to allow restart of the test and is not to conduct further pump testing until receiving an amended permit. However, we understand that minimal maintenance pumping, of no more than 6 hours once per week, is required to maintain the well and its related equipment. This maintenance pumping is allowed prior to the Commission’s action on an amendment to Cal-Am’s permit. We understand you will notify us of the start and stop times for each of these maintenance cycles.With the benefit of several months of monitoring data obtained before, during, and after the pump test, including data Cal-Am is continuing to collect, we believe the current permit and its conditions can be modified to better reflect aquifer conditions identified through these data, to better characterize other factors affecting the aquifers, and to better identify the potential effects of the pump test as they relate to those factors. We therefore recommend Cal-Am work with the HWG to develop a proposed amendment that incorporates the analyses and information referenced above and that addresses the following:

• Characterization of local/regional effects: The available data suggest the monitoring results are affected by several elements other than the pump test – e.g., regional pumping regimes, daily changes in agricultural pumping, etc. We recommend the application for the proposed amendment identify and incorporate the likely effects of those elements on the data. For example, the HWG surmises that a regular pattern observed in the data is due to seasonal increases in agricultural pumping, of pumping being reduced on Sundays, etc. We recommend the application include available data to support those assumptions.

• Effects on different aquifers: The available monitoring data show that the three aquifers underlying the area have different characteristics – e.g., confined, semi-confined, and unconfined – and are affected differently by the pump test and the other factors. We recommend that Cal-Am consider whether the application should include separate, specific thresholds that can be used to measure the potential effects of the test well on each of the aquifers.

• Water and TDS levels: The available monitoring data suggests the changes in water and TDS levels may be better described not as single values but as a range or trend in the data. We recommend that Cal-Am consider whether the application should include proposed thresholds that better reflect the identified trends in the monitoring data.
In addition, and as noted in the above-referenced June 25th letter, we request that you clarify Cal-Am’s compliance with the requirement of Special Condition #11 that monitoring devices be installed at a minimum of four wells on the CEMEX site within 2000 feet of the test well.
A document copy of the letter is embedded. 

Condition Compliance CalAm Letter July 3 2015 Lester to Crooks

STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY
CALIFORNIA COASTAL COMMISSION
LETTER FROM CHARLES F. LESTER, EXECUTIVE DIRECTOR, TO IAN CROOKS, P.E., ENGINEERING MANAGER, CALIFORNI A AMERICAN WATER COMPANY
July 3, 2015

REFERENCES: Cal Am must seek amended desal test well permit
By Jim Johnson, Monterey Herald
Posted: 07/06/15, 6:18 PM PDT |

CALIFORNIA AMERICAN WATER

TEST SLANT WELL DOCUMENTS