HomeMy WebLinkAboutMINUTES - 03091993 - WC.1 wCA
TO: BOARD OF SUPERVISORS Contra
FROM: WATER COMMITTEE Costa
SUPERVISOR SUNNE WRIGHT McPEAK
SUPERVISOR TOM TORLAKSON, CHAIR County
DATE: MARCH 9, 1993
SUBJECT: REPORT ON EAST BAY MUNICIPAL UTILITY DISTRICT WATER SUPPLY MANAGEMENT
PROGRAM ENVIRONMENTAL IMPACT STATEMENT/REPORT
SPECIFIC REQUEST(S) OR RECOMMENDATIONS) & BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS
Authorize Chair to sign a letter expressing comments on the East
Bay Municipal Utility District Water Supply Management Program
(WSMP) draft Environmental Impact Statement/Report.
BACKGROUND/REASONS FOR RECOMMENDATIONS
Prior to release of the WSMP environmental documentation, the Board
sent a letter to the East Bay Municipal Utility District (EBMUD) ,
indicating concern with assumptions used in formation of the WSMP.
Concerns focused on conservative assumptions used to determine the
need for additional water supply by the year 2020. Assumptions
for planned growth, inclusion of areas outside EBMUD's service
boundary (which may ultimately be served by EBMUD) , and Mokelumne
River additional future flow requirements mandated by the State
Water Resources Control Board could combine to significantly alter
the future water supply scenario, subsequently threatening
viability of the EBMUD water supply planning process. The County
proposes that worst case supply/demand assumptions be used, to help
accommodate those factors over which EBMUD has little or no
control.
CONTINUED ON ATTACHMENT: x YES
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S) :
Supervisor Sunne W. McPeak, Chair Supervisor Tom Torlakson
ACTION OF BOARD ON ! APPROVED AS RECOMMENDED T OTHER
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A
K UNANIMOUS (ABSENT TRUE AND CORRECT COPY OF AN
AYES: NOES: ACTION TAKEN AND ENTERED ON THE
ABSENT: ABSTAIN: MINUTES OF THE BOARD OF
SUPERVISORS ON THE DATE SHOWN.
Contact: Roberta Goulart (510/646-2071) ATTESTED lhf� / 153
cc: Community Development Dept. (CDD) PHIL BATCHELOR, CLERK OF
County Counsel THE BOARD OF SUPERVISORS
AND COUNTY ADMINISTRATOR
RG:gms BY 4 , DEPUTY
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Report on EBMUD WSMP EIS/EIR
Continued - Page Two
The Water Supply Management Program
EBMUD recently released the WSMP Environmental Impact
Statement/Report, allowing a 60-day review period ending March 15,
1993 . This document explores the need for water through the year
2020, and methods by which EBMUD expects to accommodate reliable
supply for existing customers and anticipated growth, while not
surpassing 25% rationing during the worst-case drought. A number
of different options were screened, resulting in a finite number of
components which were then combined into composite programs, (or
alternatives) , examined in the document.
Six composite programs are evaluated in the draft EIS/EIR. The
programs include:
• Demand side reduction; (aggressive conservation and reclamation
only) ;
• Groundwater (with lower-level conservation, reclamation) ;
• Delta Supply (with lower-level conservation, reclamation) ;
• Groundwater and Folsom South connection (with conservation,
reclamation) ;
• Raise Pardee (with lower-level conservation, reclamation) ; and
• Groundwater only.
Of the six programs, the EBMUD Board has indicated a preference for
two programs which include the conjunctive use, or groundwater
alternative. At this time, the 'groundwater only' alternative has
been determined by the EBMUD Board to be impractical. The EBMUD
Board has selected the 'groundwater-American River' or'
groundwater-Mokelumne River' programs.
Groundwater Programs allow for conjunctive use of water by under-
ground storage of surface water supplies when water is available,
for use in dry years. EBMUD has selected groundwater basins
existing within San Joaquin County near the Lodi area as the best
opportunity for storage. This opportunity, while providing less
significant environmental impacts, will be difficult to implement
from an institutional/permit perspective, and raises many questions
as to water quality.
County staff has outlined comments which will be expanded prior to
signature by the Chair.
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OUTLINE OF COMMENTS TO BE PROVIDED TO EBMUD
PROCEDURAL CONCERNS
The draft EIS/EIR appears to be inconsistent with CEQA; there is no summary
of impacts and mitigation, consistent with Section 15123 of the California
CEQA guidelines.
The draft appears to be inconsistent with CEQA; few impacts identified and
mitigation proposed, and what impacts are mitigated to insignificance?
The draft EIS/EIR is not understandable as written, given above factors, the
County suggests redraft/recirculation on that basis.
CONCERNS WITH ASSUMPTIONS
The aqueduct security program is good, but is no guarantee of a continued
water source in the event of earthquake or other catastrophe, particularly
when only it (or so) miles will be strengthened (see #3, alternatives) .
The need for water evaluated by EBMUD does not consider growth planned
outside EBMUD's ultimate service boundaries, which may be approved by the
cities, the counties, or as required by LAFCO. As a result, the need for
water number may be higher than anticipated within this document. Given the
fact that Contra Costa County has a General Plan which manages growth through
the Growth Management Element and an Urban Limit Line is in place, it would
be desirable for EBMUD to provide water service to planned growth outlined in
the County's General Plan. The County strongly recommends consistency with
County General Plans as part of this WSMP planning process.
Proposed annexation policy ignores growth redirected toward urban areas, and
may have the negative effect of an increased jobs-housing imbalance in the
tri-valley area. In addition, this program may affect affordable housing
opportunities, and have additional impacts upon areas which 'could otherwise
be developed through the County General Plan process. The EIS/EIR needs to
examine these issues in detail, and evaluate the significance of impacts to
property owners in areas which otherwise have development potential. How
EBMUD's existing program affects the respective Counties' planning
responsibilities needs to be examined.
The State Water Resources Control Board may appropriate significantly more
water for fisheries from the Mokelumne River than the figure planned by EBMUD
in the Lower Mokelumne. River Management Plan. What are the effects to EBMUD
should the SWRCB appropriate significantly more water for fisheries than
anticipated?
The conservative assumptions described above are of concern to the County
because they do not fully consider supply needs in the future, under
circumstances which may not be under full control of EBMUD. Despite EBMUD
policy considerations, a true worst-case scenario must be included, or EBMUD
may not be able to provide existing customers with adequate supply,
threatening the viability of this planning process.
CONCERNS WITH ALTERNATIVES/COMPOSITE PROGRAMS
Proposed alternatives do not present a fair range of programs which actually
could be implemented (no guarantee on groundwater storage, or delta supply,
for example) .
Major terminal (local) reservoir alternatives (within Alameda or Contra Costa
Counties) should be proposed as. part of composite programs to insure
emergency supply in case of damage to aqueducts. Although alternatives are
supposed to reflect a combination of factors, none of the alternatives
proposes the large terminal storage option.
The County supports conjunctive use, particularly with American River supply
supplement; question as to whether groundwater storage (even with
conservation and reclamation) , will probably not be sufficient, given the
complexities associated with implementation of groundwater storage.
The County recommends that delta supply continue to be considered as an
option.
Outline of Comments to be Provided to EBMUD
Continued -- Page Two
How is groundwater storage, with resultant degradation in water quality of
stored water reconciled with EBMUD policy regarding the highest quality water
source? Wouldn't American River, or raise Pardee options, and/or local
reservoir options be more consistent with this policy?
What degree of additional treatment would be required for stored groundwater?
Do costs contained in the draft EIS/EIR consider additional treatment,
capital improvements and operation and maintenance costs for water qualtiy
equipment? How would existing treatment plants be modified?
What about contamination potential associated with groundwater storage? What
measures would be taken to protect groundwater? County problem with
nitrates, as an example. Analysis of contaminants and hydrogeologic analysis
should be included in the final environmental documentation.
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The Board of Supervisors Contra C�"ko° `��d
and
County Administration Building Costa County Administrator
$51 Pine SL,Room 106 (510)W6.2371
Martinez, California 94553-1290 County
UN Polum tet 0111111160
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November 3, 1992
No. Nancy J. Nadel
President
Board of Directors
East Bay Municipal Utility District
P.O. Box 24055
Oakland, Ca. 94623
Dear Ms Nadel:
The Contra Costa County Board of Supervisors authorized this letter
In order to commend East Bay Municipal Utility District (EBMUD)
water reclamation and conservation programs, and to express concern
with aspects of the Water Supply Management Program (WSMP)
currently underway.
Contra Costa County's comments are as follows;
1) Areas not currently within EBMUD's Ultimate Service Boundary,
but which may eventually be served by EBMUD, should be included in
the underlying assumptions, and subsequently factored into the
total need for water determined by EBMUD.
2) The growth rate factor used as part of the WSMP may be low for
areas of Contra Costa County served by EBMUD. Some very
preliminary calculations using ABAG's Projection 192 figures over
a 20-year period (for cities served by EBMUD) seem to reflect a
3/4% per year growth factor, rather than the 1/2% per year growth
rate used by EBMUD. If the higher 'projection proves to be
accurate, this would create a greater need for water over the 30-
year planning period, and therefore should be addressed as part of
the WSMP.
3) Potential increased future flow requirements for the Mokelumne
River to be determined by the State Water Resources Control Board
and the Federal Energy Regulatory Commission processes, coupled
with the above-mentioned conservative assumptions used throughout
the WSMP planning process may result in a significantly different
estimated need for water by the year 2020. EBMUD's reluctance to
address- the potential for a numeric range to indicate need for
water may ultimately threaten the viability of the WSMP planning
effort. A true worst-case scenario should be included. Otherwise,
EBMUD should consider some delay in release of WSMP environmental
documentation until the State Water Resources Control Board and the
Federal Energy Regulatory Commission can release their respective
flow requirements for the Mokelumne River.
4) The concept of EBMUD "wheeling" of water should be addressed.
Some potential may exist for water from other sources to be
provided for distribution through EBMUD's system to areas just
outside of the ultimate 'service boundary.
5) Other measures to insure adequate water supply over the long-
term should by considered by EBMUD and included in the WSMP
process, such as purchase of water from the State Water Bank and
allocation from the Central Valley Project.
6) Contra Costa County supports conjunctive use of water supplies.
However, if for some reason, conjunctive use does not remain as the
preferred alternative, (and given the absence of the Los Vaqueros
alternative) , the Board of Supervisors strongly encourages EBMUD to
consider taking water from the Delta (i.e. the common pool
approach) .
7) Among other things, annexation policy recommended as part of the
WSMP process ignores growth redirected toward urban areas and may
have the negative effect of an increased jobs-housing imbalance in
the tri-valley area. The Board of Supervisors requests that
proposed annexation policy be discussed in detail between the
respective Boards, to allow concerns to be communicated, and to
allow EBMUD policy to reflect the range of issues which need to be
recognized as part of the County's land use planning process.
8) Contra Costa County supports EBMUD's commitment to water
conservation and reclamation activities. The Board of Supervisors
strongly encourages additional levels of reclamation and
conservation programs to take place as part of any alternative
selected through the WSMP process.
The Board appreciates your serious consideration of our concerns.
We thank you for the opportunity to comment on this very important
process prior to release of the environmental documentation on the
WSMP. If you have any questions, please do not hesitate to contact
our staff, Roberta Goulart at (510) 646-2071, or myself at 646-
5763.
Since 44
Sunne Wright McPea
Chair
Board of Supervisors
I-C5A>
C/t 7 uTU !-► c►,s;pIcT
December 4, 1992
Sunne Wright Weak
Chair
board of Supervisors
Contra Costa County
651 Pine Street, Room 106
Martinez, CA 94553-1290
Subjects EBMUD•s Water Supply Management Program
Dear Supervisor McPeak: ,
The East Bay Municipal Utility District (District) wishes to
express its gratitude to the Contra Costa County Board of
Supervisors for support of .the District's conservation and
reclamation efforts and for the letter to the State Water
Resources Control Board expressing the Board of Supervisors'
concerns with the re-evaluation of the District's Hokelumne
River water rights. In Addition, -the District would like to
respond to the concerns expressed in the Board of Supervisors'
November 3, 1992 letter regarding the ongoing Water Supply
Management Program (WSMP) . The letter identified eight specific
issues.
1) EBmuv is planning to provide Mater service only within its
existing ultimate Service Boundary (OSB) .
EBMUD has imposed rationing on its existing customers
for the past six years in response to the ongoing
drought. As the District looks toward its future,
continued deficiencies in supply are anticipated.
This situation will be exacerbated by any additional
releases required to benefit the fishery resources.
The District is preparing the WSMP to identify the
programs and projects which will best most the needs
of its customers. However, the institutional
constraints accompanying any program which would
increase the District's water supply could seriously
delay or hinder EBMUD.realisation of yield from any
proposed program. Given these institutional
uncertainties and the naturally variable hydrology of
the Mokalumne River, prudent planning dictates that
the District not .overcommit itself to serve outside
its UsB at the expense of customers within its USB.
The District recognises the need to evaluate water
service to areas outside its USB and is willing
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DEC-15-192 12:47 MEMO PUBLIC AFFAIRS TEL 3O:510-287-0149 13009 P02
Sunne Wright McPsak
December 4, 1992
Page 2
to work in a cooperative effort with other entities to
try to identify possible sources of crater for new
developments outside the USB. However, District
customers within the-USB should not be expected to
expend their financial resources or to sacrifice the
quality or quantity of their water in this effort.
2) „The VBMP growth rate factors used as part of the MBMP miy
be low for areas of Contra Costa County served bx 9BXUD.11
Specific reference is made to the %/a% per year population
growth rate identified in the •sxP and recently released
ABAG Projections f§2*
The WSMP demand projections were derived from ABAG 1990
projections of the number of households rather than
population figures. Analyses were performed by census
tract since ESMUD only serves a portion of some cities.
The District projections were forwarded to all cities
and the two counties it serves for review. Any
comments made by the cities and counties were
incorporated into the projections.
Since the District projections are based on households
rather than populationthe ABAG 192 population increases do
not appear to have a significant impact on the WSMP demand
analysis, especially since the ABAG 092 projections also
show increases in the number of people per household.
Additionally, while ABAG 092 projections did increase
household projections for Contra Costa County, these same
projections decrease the number of households projected for
Alameda County. ' Consequently, there is little change in the
household projections for the two counties combined and the
impact to the WSMP demand projections is not significant.
3) since there is serious potential for increased future flow
requirements on the Kokelumne sliver, sBXUD,s need for
additional Mater should be a range, or the WARP
environmental documentation should not be released until the
regulatory agencies have identified their flow requirements
for the Kokelumne Rivers
in order to recognize the uncertainties inherent in demand
projections, flexibility was emphasized as a key element in
the evaluation of potential solutions to BBMUD's need for
additional water. Solutions which were "flexible", meaning
they could be phased or significantly expanded in the
future, received higher scores in the alternatives
evaluation than those that lack flexibility.
DEC-15-192 12:48 ID:EBMJD PUBLIC AFFAIRS TEL h0:510-287-0149 #009 P03
8unne Wright McPeak
December 4, 1992 i
Page 3
The District is confident that the environmental
documentation presented to the regulatory agencies provides
a strong argument for adhering to the District's proposed
fishery releases on the Mokelumne River. The District also
believes it is important for the regulatory agencies to know
that EBMUD has conducted a comprehensive and thorough
evaluation of its water supply alternatives and has
developed a well-conceived solution to balance the needs of
its customers and the public trust resources of the
Mokelumne River, and intends to vigorously pursue it's
program. Release of the WSMP EIR/EIS is essential to the
District's ability to convey this message to the regulatory
community and to District customers.
4) IlThe Concept of aBMUD "wheeling" of Mater should be
addressed. Some potential may exist for Mater from other
sources to be provided for distribution through ZBMUDPs
system to areas outside the 988.91 '
As part of its WSMP, the District evaluated obtaining
"wheeled" water as a potential supplemental supply option to
increase dupplies to the District. However, when evaluated
against other water supply options available to the
District, it did not rate well. Therefore it- was not
pursued. The District has not received any specific
proposals to "wheel" water outside its USB, but would be
willing to review any such a proposal(s) with the County.
The District would also be willing to cooperate .with other
organizations assessing the potential of "wheeling" water.
5) $#other measures to insure adequate Mater supply over the
long-term should be considered by ZBXUD and included in the
WSMP process,' such as purchase of Crater from the dtate Water
eanx ane allocation trot the Central valley Project.l,
This '6s evaluated as part of the WSMP supplemental supplyy
analysis. One of the six primary solutions the Districts
considering includes pumping water from the Delta. It is
assumed that the water withdrawn from the Delta would be
purchased from either the state Water Hank, another agency
or some private party.
6) The Board of Supervisors strongly encourages seMVD to
consider taking Mater from the Delta if the proposed
conjunctive use program does not remain the pretesred
alternative.
DEC-15-'92 12:49 ID:EMO PUBLIC AFFAIRS TEL NO:510-2V-0149 #W9 PO4 `
Sunne Wright McPeak
December 4, 1592
Page 4
The District Board will carefully consider the comments
on the WSMP DEIS and the other primary solutions which
were developed to provide the need for additional
water. As stated above, one of these alternatives -
involves a Delta take.
7) „The board of Supervisors requests that the Distriat's
proposed annexation policy be discussed is detail between
the respective Boards.$#
The District Board of Directors is very interested in
pursuing this discussion with the Contra Costa board of
Supervisors.' I an responding to this request under
separate cover.
8) @'The Board of supervisors strongly encourages additional
levels of conservation and reclamation programs to be
included as part of any alternative selected through the
WOMP.If
Conservation and reclamation are integral components of
the District's long range plans to effectively use all
existing supplies. The District is committed to
continuing to reduce. demand within its USB through
expanded conservation and reclamation programs.
Furthermore, the District has included increased levels of
conservation and reclamation as elements of the preferred
'programs of the WSMP. The Board of Supervisors' support of
these endeavors is greatly appreciated.
The District appreciates the Board of Supervisors' participation
in the WSMP process. The concerns you identified demonstrate
your understanding and commitment to solving the water supply
problems facing Contra Costa County. If you have any additional
questioner or concarns, please contact John Lampe, Manager of
Water Planning at (510) 287-1127.
Very truly yours,
Nancy J. Nadel
President
Board of Directors
NJN:JAM:ra
ccs EBMUD Board of Directors
AP
DEC-15-192 12:49 ID:EBMUD PUBLIC AFFAIRS TEL tO:510-267-0149 #OM P05 '
t ,
bee:
Jorge Carrasco
Robert Maddow
Dennis Allen.
John Lamps
Bill Kirkp&trick
Mark Mihaly
Michael Goldberg
Jacqueline Millet
NSMP Chrono
The Board of Supervisors Contra CerrkoahehBoard
and
County Administration Building Costa y
Count Administrator
651 Pine St., Room 106 (510)646-2371
Martinez, California 94553 County
Tom Powers, 1st District
Jeff Smith,2nd District se r
. .
Gayle
Gayle Bishop•3rd District
Sunne Wright McPeak,4th District ,Y.
Tom Torlakson.5th District ?rte — •;r
q..a.
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q C, L:Sr
March 15, 1993
John B. Lampe
Manager, Water Planning
East Bay Municipal Utility District
375 11 th Street
Oakland, CA 94607
Dear Mr�ampe:
The Contra Costa County Board of Supervisors has authorized this letter in order to
comment on the Water Supply Management Program (WSMP) draft Environmental
Impact Statement/Report (EIS/EIR). The Board encourages responsible water supply
planning efforts through EBMUD's WSMP process, in order to determine how best to
provide adequate, reliable water supply over the long-term. The Board has a number
of comments on the draft EIS/EIR, as follows.
CONCERNS RELATIVE TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
(CEQA)
Although the attempt has been made to address both NEPA and CEQA within a
voluminous set of documents, it appears that some requirements under CEQA have
not been met. First, the draft EIS/EIR seems to be inconsistent with CEQA under
Section 15123, due to the lack of a summary which is required (even at the program
level of detail), describing impacts of the proposed program, and mitigation for those
impacts, including impacts reduced to a level of insignificance. Meaningful discussion
of environmental impacts, (significant and otherwise), as well as mitigation of those
impacts, seem to be largely absent from this document, and is required under Section
15126 of the CEQA guidelines. In addition, cumulative impacts of this program have
not been evaluated, consistent with Section 15130.
CEQA requires that inconsistency between the WSMP and local general plans be
addressed in accordance with Section 15125 of the CEQA Guidelines. Finally, CEQA
John B. Lampe Date: March 15, 1993
WSMP Draft EIR/EIS - 2-
Guidelines, Section 15131 requires that effects of the WSMP (i.e. water conservation
requirements, rationing,water service policy and other program aspects)on economic,
social and particularly housing factors must be addressed.
CEQA requires a clear analysis of environmental impacts and subsequent mitigation
of those impacts. Although an extreme amount of information is presented in the
draft and appendices, the large amount of interwoven technical data coupled with the
lack of environmental documentation renders this document unworkable and
confusing, particularly to the lay-person attempting to understand the process. The
Board hereby requests that the WSMP draft EIS/EIR be redrafted and recirculated, in
order to provide the community with a readable document which lays out
environmental impacts as well as mitigation of those impacts as part of this program.
ASSUMPTIONS USED TO ESTIMATE DEMAND AND SUBSEQUENT SUPPLY NEEDS
Baseline assumptions used by EBMUD to determine the need for water through the
year 2020 are too conservative, do not take into account additional water needs
outside EBMUD's control, and may result in additional hardship on current EBMUD
customers. In addition, conservative assumptions used could threaten the viability of
the entire planning process. A worst-case scenario should be portrayed, even if this
scenario is not consistent with EBMUD Board intent or policy, in order to
accommodate factors which may be out of the Board's purview, or other factors not
anticipated at this time.
The draft EIS/EIR doe3 not address potential effects of the State Water Resources
Control Board Decision 1630, effects of the recent listing of the Delta Smelt by the
US Fish and Wildlife Service as a threatened species, and effects of the Central Valley
Project Improvement Act 102-575 Title 34.
Although the County acknowledges the effort put forth by EBMUD on the Lower
Mokelumne River Management Plan, the LMRMP may have significantly
underestimated the amount of water which will be reallocated from EBMUD to
fisheries by the State Water Resources Control Board, and perhaps by the Federal
Energy Regulatory Commission (FERC).
Growth assumptions used in the WSMP are lower than preliminary growth estimates
calculated for the County over the next 20 years. This could create a greater need
for water than is predicted by EBMUD. Projections '92 data shows higher population
and household numbers than those calculated by EBMUD using 1990 data.
The rationing level of 32 percent is too high and is overly optimistic (particularly when
considering current levels of use rather than non-drought levels) for residential areas.
John B. Lampe Date: March 15, 1993
WSMP Draft EIR/EIS - 3-
The EIS/EIR should consider additional levels of conservation and/or reclamation
activity in place of the severe rationing requirement.
PROVISION OF WATER SUPPLY OUTSIDE EBMUD'S ULTIMATE SERVICE BOUNDARY
EBMUD's decision not to consider development outside of the ultimate service
boundary (USB) is not entirely compatible with growth planned by other agencies
which logically could be served by EBMUD. This policy may not be realistic in all
cases, in that EBMUD may be required to serve these areas by the Local Agency
Formation Commission (LAFCO). As a result, the need for water number may be
higher than anticipated within the WSMP EIS/EIR.
The WSMP, which allows water service within the USB only, has the effect of
ignoring growth redirected toward urban areas and may have the additional negative
impact of an increased jobs-housing imbalance in the tri-valley area. EBMUD's
reluctance to supply housing needs outside the USB by disallowing annexation affects
a number of land use planning agencies, necessitating examination and inclusion of
impacts as part of the WSMP environmental review process. Impacts on
transportation and air quality need to be evaluated as well, among other factors.
As a land use planning agency which must take into account a great many factors as
part of an orderly process of community development, and in accordance with State
law, Contra Costa County has a General Plan (January 1991 ). Among other things,
the General Plan contains strong, responsible policy in regard to growth management.
This also includes a voter-approved 65/35 Land Preservation Standard and Urban Limit
Line, which sets aside lands for preservation and specifies lands which may be
considered for a change in land use (i.e. may be developed). It is important to note
that all of the area within the Urban Limit Line may not be developed, in accordance
with the 65/35 Land Preservation Standard.
EBMUD's WSMP, as written, does not fully consider Contra Costa County's land use
planning process and potential for growth within the urban limit line as provided in the
General Plan. Better correlation between these two very important programs is
certainly desirable, but absent this, the WSMP would have impacts upon the County
land use planning process which are not discussed in the WSMP EIS/EIR. Impacts to
housing are particularly important. How would the WSMP (and annexation policy)
affect the County's ability to provide for our appropriate share of regional housing
needs pursuant to Government Code Sections 65583 and 65584? Impacts on
housing prices, availability, and growth patterns, as opposed to provision of water to
those areas which can be considered for growth as specified in the general plan
should be addressed.
John B. Lampe Date: March 15, 1993
WSMP Draft EIR/EIS - 4-
EBMUD's failure to consider planned growth in Contra Costa County outside the USB
is particularly distressing given EBMUD's long-standing historical reliance on County
support of EBMUD projects.
WSMP ALTERNATIVES/COMPOSITE PROGRAMS
The composite programs listed within the WSMP EIS/EIR do not appear to provide a
reasonable range of alternatives which could be implemented. The delta supply, raise
Pardee, and particularly the groundwater alternatives provide little evidence to support
feasibility of implementation.
In addition, not one of the composite programs listed in the WSMP EIS/EIR includes
a local reservoir option, despite the fact that composite programs were supposed to
reflect a combination of components. It is not clear within the WSMP EIS/EIR as to
why local storage options were eliminated, particularly considering that options which
were included in composite programs do not appear to be any more implementable,
or have significantly different levels of impact. Relative merit of local reservoir
alternatives (within Alameda or Contra Costa Counties) should be proposed as part of
composite programs and strongly considered. This could provide the added benefit
of insuring emergency supply in case of damage to aqueducts despite aqueduct
security measures.
The County supports conjunctive use, particularly with the American River supply
supplement. Questions remain, however, as to EBMUD's ability to provide future
water supply should problems arise (which appears likely) with implementation of the
groundwater component, (even with conservation/reclamation), without inclusion of
the American River supply.
There are a number of questions associated with the concept of groundwater storage
which should be discussed to some degree as part of the program level EIS/EIR. How
is groundwater storage, with resultant degradation in water quality of stored water
reconciled with EBMUD policy regarding the highest quality water source? Wouldn't
American River, or raise Pardee options, and/or local reservoir options be more
consistent with this policy?
What degree of additional treatment would be required for stored groundwater? Do
costs contained in the draft EIS/EIR consider additional treatment, capital
improvements and operation and maintenance costs for water quality equipment?
What are costs of pumping water out of underground aqueducts? How would existing
treatment plants be modified? Costs and other impacts associated with initial
recharge of a currently overdrafted aquifer should also be examined.
John B. Lampe Date: March 15, 1993
WSMP Draft EIR/EIS - 5-
What about contamination potential associated with groundwater storage? What
measures would be taken to protect groundwater? The County has concerns
regarding potential for contaminant infiltration, due in part to problems with nitrate
contamination of local wells. Some level of analysis of potential contaminants and
hydrogeologic factors should be included in the final environmental documentation to
provide some level of comfort should one of the preferred alternatives be selected.
The County recommends that delta supply continue to be seriously considered as an
option. In addition, wheeling of water through EBMUD facilities should also be
considered, particularly for areas where EBMUD is proposing no water service.
IMPACTS ON CUSTOMERS
It is likely that, given the margin of error associated with the base assumptions in
determination of the need for water, coupled with the relative uncertainty associated
with outside influences also requiring this water, the conservative approach used by
EBMUD may result in severe impacts to existing and future customers through
continued water deficiencies in the future.
EBMUD has avenues of supply through the American River and other sources, as well
as potential methods of additional storage which could be implemented to
accommodate anticipated growth as contained in the County General Plan through the
year 2005. The downsizing of anticipated demand, and lack of consideration of the
full range of available options at this time may result in some of these options being
unavailable for future consideration.
Given the great number of concerns with the underlying assumptions determining the
need for water, CEQA considerations and the number of issues which remain to be
resolved, the Contra Costa County Board of Supervisors hereby requests that the
WSMP be redrafted and recirculated.
Thank you for the opportunity to comment and for your attention to our concerns.
If you have questions, do not hesitate to contact Roberta Goulart at (510) 646-2071
or James Cutler at 646-2035.
Sincerely,
2 1 dl2.�as�
Tom Torlakson, Chair
Contra Costa County Board of Supervisors
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