Written by: Janet Brennan, LandWatch Board Member.
Those of us following the effort to address water supply alternatives for the Monterey Peninsula have been frustrated by the lack of a unified process that evaluates all proposed desalination projects. These projects include the People’s Desal Project, Deep Water Desal Project, alternative well locations within the boundary of the Monterey Peninsula Water Management District (MPWMD) as well as the CalAm desalination project.
A unified approach addressing environmental impacts is now assured with the National Marine Sanctuary’s announcement that the California Public Utilities Commission (CPUC) must prepare an Environmental Impact Statement (EIS) on the CalAm project. This is good news for the process since an EIS must discuss a range of alternatives, including the proposed action, comparatively analyzed, i.e., each alternative must be analyzed on an equal footing.
This requirement under the National Environmental Policy Act (NEPA) differs substantially from the alternatives analysis required under the California Environmental Quality Act (CEQA). Under CEQA, only feasible alternatives which would avoid or lessen the project’s impacts must be addressed. If a project has no impacts or if it has impacts that other alternatives would not address, then there is no assurance that all feasible alternatives would be evaluated. Even if they are, the analysis is not as comprehensive as one required under NEPA.
Under CEQA, however, all feasible mitigation measures for adverse environmental impacts must be adopted. Under NEPA, a federal agency need not adopted mitigation measures unless required by its own NEPA procedures.
Now, what is needed is an agency to prepare a comparable financial analysis. While the Mayor’s group has commissioned such an effort, it may fall short of the comprehensive analyses needed to help choose an alternative. The MPWMD has a financial model similar to the one that will be used by the CPUC to evaluate the CalAm project. A comparable analysis for the other alternatives prepared by the MPWMD would address this matter.
Janet Brennan is an environmental planner with 30 years of experience working for local and regional governments. Her experience includes air quality, land use, water quality, infrastructure, and hazardous waste planning and environmental review.
to Water Issues and Actions]