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WD-6 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

In the Matter of the Application of CaliforniaAmerican Water Company (U210W) for a Certificate of Public Convenience and Necessity to Construct and Operate its Monterey Water Supply Project to Resolve the Long-Term Water Supply Deficit in its Monterey District and to Recover All Present And Future Costs in connection Therewith in Rates

Application No. 12-04-019 (Filed April 23, 2013)

DIRECT TESTIMONY OF LARRY M. HAMPSON

De LAY & LAREDO David C. Laredo, CSBN 66532 Heidi A. Quinn, CSBN 180880 Alex J. Lorca, CSBN 266444 606 Forest Avenue Pacific Grove, CA 93950-4221 Telephone: (831) 646-1502 Facsimile: (831) 646-0377 Email: dave@laredolaw.net heidi@laredolaw.net alex@laredolaw.net Attorneys for MONTEREY PENINSULA WATER MANAGEMENT DISTRICT February 22, 2013
DIRECT TESTIMONY OF LARRY M. HAMPSON A.12-04-019 PAGE 1

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Q3. A3. Q2. A2. I. Q1. A1.

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

In the Matter of the Application of CaliforniaAmerican Water Company (U210W) for a Certificate of Public Convenience and Necessity to Construct and Operate its Monterey Water Supply Project to Resolve the Long-Term Water Supply Deficit in its Monterey District and to Recover All Present And Future Costs in connection Therewith in Rates

Application No. 12-04-019 (Filed April 23, 2013)

DIRECT TESTIMONY OF LARRY HAMPSON

INTRODUCTION Please state your name, business address, and telephone number. My name is Larry M. Hampson. My business address is 5 Harris Court, Building G, Monterey, California 93940. My telephone number is (831) 658-5620.

By whom are you employed and in what capacity? I am employed by the Monterey Peninsula Water Management District (MPWMD or Water Management District) as District Engineer. I have worked continuously for MPWMD since March 1991 and was employed as a hydrologist and a water resources engineer prior to my current position with MPWMD as District Engineer and Manager of Planning and Engineering.

Please give a summary of your professional qualifications. My education includes a Bachelor of Science degree in Engineering Science from Colorado State University and a Masters of Business Administration in Finance from the
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University of Colorado. I am a Registered Civil Engineer in the State of California (No. C 45763) and a licensed Professional Engineer in the State of Colorado (No. 25726). Most of my 30 years of professional experience has been in Civil Engineering related to water resource management. I am familiar with laws and regulations concerning environmental review and permitting of water supply projects, principles of integrated water resources planning, and am knowledgeable regarding Monterey Peninsula water resource management issues in general and issues related to hydrology, erosion protection, and riparian habitat mitigation and river restoration in the Carmel River in particular. I have been a guest lecturer on several occasions at graduate level classes involving water resources studies for the University of California at Berkeley and California State University at Monterey Bay and have also given several presentations on local water supply issues and solutions to professional organizations and interested stakeholder groups.

Please briefly outline your responsibilities at the Water Management District. As the District Engineer, I participate in planning, engineering, and environmental impact investigations for water supply projects to augment available supplies. Water supply projects include: evaluation of surface storage in the Carmel River watershed, such as the New Los Padres Dam, the Carmel River Dam and Reservoir, and modifications to Los Padres Dam and Reservoir; evaluation and initial planning for seawater desalination projects; and evaluation of wastewater recycling projects. My responsibilities include: planning, design, implementation, and monitoring of District-sponsored projects for Carmel River erosion protection and river restoration; review and inspection of non-District sponsored projects that affect the channel of the Carmel River, such as the San Clemente Dam Removal and Carmel River Reroute Project; review of applications to alter the channel of the Carmel River; and issuance of permits to implement proposed alterations. I am also involved in: review of water rights
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applications for the Carmel River Basin and in maintaining the Districts water rights; and planning level efforts to expand the Seaside Groundwater Basin Aquifer Storage and Recovery (ASR) Project. Since 2004, I have directed and coordinated efforts of MPWMD staff and other local agencies and non-governmental organizations to complete and update an Integrated Regional Water Management (IRWM) Plan for a planning region that comprises the Carmel River watershed, the six Monterey Peninsula cities, and unincorporated portions of Monterey County within the MPWMD boundary1. The IRWM Plan for the region includes planning and implementation of projects that are directly related to augmenting the water supply for the region and protecting and enhancing local water resources. Since 2005, I have been involved in monitoring, evaluating, and developing solutions to protect infrastructure at the Carmel River State Beach and Lagoon against damage resulting from flooding and beach erosion, and from environmental damage resulting from mechanical breaching of the barrier beach. As facilitator of the Carmel River Lagoon Technical Advisory Committee, I coordinated completion of a scoping document for long-term management at the Carmel River State Beach and Lagoon 2 and recently participated in the selection of a team of consultants who are evaluating solutions to beach management and erosion of the bluff along Scenic Road in Carmel, California.

The Department of Water Resources IRWM web site (http://www.water.ca.gov/irwm/grants/index.cfm) states that Integrated Regional Water Management (IRWM) is a collaborative effort to manage all aspects of water resources in a region. IRWM crosses jurisdictional, watershed, and political boundaries; involves multiple agencies, stakeholders, individuals, and groups; and attempts to address the issues and differing perspectives of all the entities involved through mutually beneficial solutions. IRWM includes fostering comprehensive management of surface and groundwater, storm water, recycled water, recreational uses, and the habitats and species dependent on water. 2 See Study Plan for Long Term Adaptive Management of the Carmel River State Beach and Lagoon, MPWMD, April 2007. http://www.mpwmd.dst.ca.us/Mbay_IRWM/IRWM_library/CarmelBay/LongTermStudyPlanFinal200704-17.pdf DIRECT TESTIMONY OF LARRY M. HAMPSON A.12-04-019 PAGE 4

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Q5. A5.

Have you previously testified before the California Public Utilities Commission? Yes. I provided testimony on Cal-Ams 2010 Amended Application filed on August 26, 2011 to Application No. A.10-01-012 Filed January 5, 2010 for an order authorizing the collection and remittance of the Monterey Peninsula Water Management District User Fee.

II. Q6. A6.

PURPOSE OF TESTIMONY What is the purpose of this direct testimony? The purpose of my testimony is to comment on the desalination component of the Monterey Peninsula Water Supply Project (MPWSP) described in testimony submitted by California American Water. I have comments and concerns about the following:

1) The November 2012 contingency plan to supply water for municipal use from Carmel River diversions during an extended outage of the proposed desalination component;

2) The proposal to locate, operate and maintain slant wells in the swash zone; and

3) The proposal to construct slant wells during the five-month period from October through February.

Q7.

What concerns do you have about Cal-Ams contingency plan for supplying water to the Monterey system during an extended outage of the proposed desalination component?

A7.

Cal-Am is erroneously presuming Carmel River diversions can be relied on in the future to meet Monterey system demand during an extended outage of the desalination

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component.

In California-American Water Company Contingency Plan Compliance

Filing on 11-01-12 (Contingency Plan), page 6, Cal-Am asserts the following: While the Monterey County District is facing future water supply issues, California American Waters existing assets in the Seaside Basin and Carmel River are sufficient to meet all customer demands, including maximum day demands and maximum monthly demands in the near-term. Neither of these two sources are constrained for daily or monthly flows, meaning that if the proposed desalination plant at the Charles Benson Road site were down for a couple of days or a month, these existing assets will be able to meet customer demands just as they are currently doing. Page 7 of the Contingency Plan goes on to state: If in the long-term the ASR water supply increases due to successive wet years in the first five years of operating the proposed desalination plant, then curtailment [of water service to customers during a prolonged outage of the desalination plant] as described above may not be needed due to the presence of 1,920 AFA of ASR water and 500 to 600 AFA of Table 13 water. This amounts to almost two months of summer demands. A description of how Cal-Am believes wells and its treatment plant in Carmel Valley will be operated in the Carmel River Basin during the dry season once the MPWSP is delivering water to the system is contained on Page 8 in Direct Testimony of Eric J. Sabolsice: Operation of the Carmel River wells will be minimized during the summer months (low flow period) with only a maintenance flow passing through BIRP [Begonia Iron Treatment Plant located at mid-Carmel Valley]. This maintenance flow is important and will allow operations the ability to quickly increase the flow rate out of BIRP in the event of a problem at the desalination plant. As I show in the following analysis, Cal-Am can supply only a small fraction of municipal demand from the Carmel River in the dry season during an outage of a desalination plant without resorting to unauthorized diversions. For purposes of this testimony, I divide the water year into two periods the winter or wet period from December 1 through May 31 of the following year and the dry season between June 1 and
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November 30. These periods coincide with the proposed operations plan shown in Tables 2 and 3, beginning on p. 7 in Attachment 1 to Supplemental Testimony of Richard C. Svindland, January 11, 2013 (Mr. Svindland, Supplemental Testimony). With a desalination plant in operation, Cal-Am proposes to meet municipal demand by using most of its Carmel River diversion rights in the winter 3 and supplying most of its summer demand from non-Carmel River Basin sources. As shown, Cal-Am would divert 1.0 million gallons per day during the dry season through BIRP or about 560 AF over a 183-day period. The remainder of existing Carmel River rights 2,816 AF would be diverted in the winter. By June 1 of each water year, Cal-Am will not have the ability to legally ramp up production in Carmel Valley in response to a desalination plant outage even for a short period without later shutting down or scaling back operations at BIRP in order to stay within its authorized diversion rights. It is important to note that Cal-Am officials have stated that a complete shut-down of BIRP in the dry season could result in a loss of treatment capacity at this facility. Cal-Am will not be able to supply water directly to the system in the dry season under a new permit from a Table 13 reservation. The proposed SWRCB permit limits the season of diversion to December 1 through May 31 of the following year. Thus, Cal-Am will be limited to supplying less than 95 AF per month in the dry season from the Carmel River Basin. In the dry period, demand shown on Table 2 and 3,

What is not shown in Tables 2 and 3 for the winter supply calculations, but is alluded to in the November 2012 contingency plan filing, is the potential to supply an additional 620 AFA from ASR diversions (for a total of 1,920 AFA) and 500 to 600 AFA directly to the system in the winter under a Table 13 reservation (SWRCB Decision 1632). MPWMD estimates that the long term yield of ASR diversions under SWRCB Permits 20808 A and B, which have a face value of 5,326 AFA, will be about 2,000 AFA. Cal-Ams Table 13 reservation is for direct diversion and use (as opposed to diversion to storage and later recovery) of up to 1,488 AFY, which may yield 500 to 600 AFA in the long term. The draft permit issued by SWRCB in early 2013 includes a season of diversion from December 1 through May 31 of the following year. The maximum diversion rate allowed under this permit is 4.1 cfs (2.65 mgd) and is subject to meeting minimum instream flow requirements. DIRECT TESTIMONY OF LARRY M. HAMPSON A.12-04-019 PAGE 7

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 A8. Q8.

Attachment 1 to Mr. Svindlands Supplemental Testimony varies between about 1,090 AF/mo and 1,780 AF/mo. If Seaside Groundwater Basin supplies are not capable of meeting the remainder of demand during a prolonged outage of the desalination component, it is unlikely that Cal-Am could either obtain an emergency authorization from the SWRCB to divert from the Carmel River Basin in the dry period or successfully mitigate for impacts from unauthorized diversions, except perhaps in an extremely wet water year. 4 Rather than continuing to rely on dewatering of the Carmel Valley Aquifer during the dry season, production facilities providing water from the Seaside Groundwater Basin and total system storage should be designed to meet municipal demand during an extended outage of the desalination component.

What concerns do you have about the proposal to locate, operate, and maintain intake slant wells in the swash zone? Cal-Ams most recent proposal for locating slant wells is contained in Attachment 11 to Mr. Svindlands Supplemental Testimony, which states: In order to protect the wellheads from wave damage, to eliminate any visual profile after construction, and to eliminate impacts on Snowy Plover nesting habitat, the wellheads will be completely buried below the beach surface in the area known as the swash zone, which is the portion of the beach that lies within the run-up of waves at normal high tide. In order to eliminate any possibility that the wellheads or any associated

Recent permits issued by SWRCB have included a condition to protect steelhead that requires a minimum of 5 cubic feet per second, or about 10 AF/day, at the Highway 1 gage in the dry period in order to divert flow. Using August as a worst case month, evapotranspiration along the streamside corridor is estimated at about 9 AF/day for the month of August (Table 2, p. 9, MPWMD Technical Memorandum 2010-01 USING GIS TO QUANTIFY RIPARIAN AREA OVERLYING THE CARMEL VALLEY ALLUVIAL AQUIFER, prepared by Thomas Christensen and Elizabeth Geisler, December 2010). Non-Cal-Am pumpers may divert an average of 8 AF/day during the dry period (presuming that 60% of non-Cal-Am diversions of about 2,400 AFA are carried out in the dry season at a constant rate). In total, an estimated 27 AF/day would be needed at San Clemente Dam in order to meet summer instream flow requirements at Highway 1. Analysis of simulated unimpaired flows at San Clemente Dam between 1958 and 2002 shows that this requirement could be met in only 4 of 44 years in the month of August, or in about 9% of years. DIRECT TESTIMONY OF LARRY M. HAMPSON A.12-04-019 PAGE 8

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structures will be exposed by the combined effects of coastal erosion and sea level rise, they will be capped at or below mean sea level. In Richard C. Svindlands Direct Testimony of April 23, 2012, at p. 10, Cal-Am proposed that The preliminary design [of the intake system] envisions locating the well head approximately 500 feet from the average high tide mark. Mr. Svindlands Supplemental Testimony, Attachment 11, which was given nine months after his Direct Testimony, describes an intake system located in the swash zone, which is a substantial change in the proposed location of the intake system. The District is concerned that this change was not subject to the environmental scoping process. Cal-Ams testimony does not contain an analysis of the potential effects of coastal erosion or sea level rise on the long-term viability of placing well heads and gravity caissons in the swash zone at this location. Stamski (2005) estimated landward erosion rates at the CEMEX site are 51 to 86 cm/year (1.7 to 2.8 feet/year) 5. Griggs et al (cited in Figure 2.1 by Smith et al in 2005) showed an erosion rate of 86 cm/year (2.8ft./year). PWA 2008, Table 4 shows an estimate of up to 4.7 feet per year in the general vicinity of the site. 6 Smith et al (2005) estimated the long term retreat of the coastline along

Southern Monterey Bay and concluded the following: The southern Monterey Bay coastline is retreating at approximately 1 m/yr [3.28 ft.], and has been retreating for a long time. The retreating coastline will continue to impact existing structures and convert both public and private lands to marine continental shelf at a rate of about 1 m/yr. 7 The estimated annual rate of landward beach translation shows a range of results, likely due to the episodic nature of coastal erosion; however, the research clearly shows

Fig. 2.6, p.40, Rebecca Stamski, California Sea Grant Fellow, Monterey Bay National Marine Sanctuary, COASTAL EROSION AND ARMORING IN SOUTHERN MONTEREY BAY, A Technical Report in support of the Monterey Bay National Marine Sanctuary Coastal Armoring Action Plan, Version 1.1, June 2005. 6 Table 4, p. 36, Philip Williams & Associates, Ltd. With Ed Thornton, Jenifer Dugan, Halcrow Group COASTAL REGIONAL SEDIMENT MANAGEMENT PLAN FOR SOUTHERN MONTEREY BAY, Prepared for Association of Monterey Bay Area Governments, November 3, 2008. 7 P. 12, Smith, D.P, Gref, K., and Hofmann, A., 2005, Are Stable Shorelines and Broad Beaches Mutually Exclusive Management Goals Along Southern Monterey Bay? The Watershed Institute, California State University Monterey Bay, Publication No. WI-2005-09, 46 pp.

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landward movement, with the lowest estimate being 1.7 feet per year. It appears from Figure 7 Profile A-A of Southern Intake Well Cluster in Attachment 11 to Mr. Svindlands Supplemental Testimony that locating the well heads and gravity caissons in the existing swash zone would expose these facilities to wave activity within a relatively short period as the beach translates landward, potentially rendering the facilities inoperable due to wave impacts and scour. Page 6 of Attachment 1 to Mr. Svindlands Supplemental Testimony describes that maintenance of the well heads would require access to the well heads for cleaning every five to ten years. It is not clear from the project description if such operations would require temporary protection from ocean waves that is similar to what would be required for initial construction. It is also unclear from the testimony provided how potential landward translation of the beach would complicate necessary future well rehabilitation efforts. If scour and/or beach erosion occur and expose the well head vaults, their location at mean sea level would result in visual exposure at low tide.

Q9.

What concerns would you have about construction in the swash zone during the proposed October through February construction season?

A9.

PWA 2008, page 87 states the following: An aerial photograph of the dredge pond at [the CEMEX sand mining site in] Marina taken after the storm of January 2008 (Figure 20, right panel) shows how effective the mined area on the beach is at trapping sediment from the littoral zone. Prior to the storm the pond was filled with water (Figure 20, left panel). During the storm, waves and surge overtopped the berm and broke loose the 80-ton dredge that was chained inside the pond. [emphasis added] Large swell events can occur during the proposed construction period and can result in significant wave heights 8 in the 30 to 35-foot range in Monterey Bay. Figure 1

Significant wave height is the average height of the highest one-third of the waves during a 20 minute sampling period. DIRECT TESTIMONY OF LARRY M. HAMPSON A.12-04-019 PAGE 10

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is a plot of significant wave heights measured at the Monterey Bay buoy during the January 2008 swell event referenced in the PWA report above. The buoy, Station 46042, is located about 17 miles west of the CEMEX sand mine site and is maintained by the National Data Buoy Center. Swell heights during el Nio events along the Southern Monterey Bay are reported to be highest between the Salinas River and Fort Ord 9. Concerning the potential for a coastal flood at the site, PWA 2008, p. 18 reports that: The Federal Emergency Management Agency (FEMA) coastal flood studies in southern Monterey Bay (FEMA, 2007) projected the maximum elevations of wave runup and overtopping during a 100-year flood event, denoted by the Base Flood Elevation (BFE) (Table 2). Structures at elevations below the BFE may be subject damages from direct wave impacts or undermining by wave scour. [emphasis added] PWA 2008, Table 2 shows the BFE in Sand City and at the Seaside Pump Station to be 27 feet (NAVD 1988) and to be 23-24 feet north of the Salinas River mouth. A reasonable interpretation of the BFE near the CEMEX site appears to be approximately 25 feet (NAVD), which corresponds to 22 feet MSL, or about six feet higher than the top of the sheet piling proposed in Figure 7, Attachment 11 to Mr. Svindlands Supplemental Testimony. As proposed, the temporary sheet pile wall and well head construction area would likely be subject to wave overtopping during a large swell event or a coastal flood. If the well heads could be installed successfully at this site, large waves could scour or undermine the facilities, even though they are placed below sea level initially. An analysis of potential maximum wave runup and depth of scour should be carried out for the site in order to design temporary facilities. As previously described, the effect of long-term landward translation of the beach needs to be considered in selecting both the depth and horizontal placement of the well heads.

Fig. 9, Quan, S.; Kvitek, R.; Smith, D., and Griggs, G. 0000, Using vessel-based LIDAR to quantify coastal erosion during El Nio and inter-El Nio periods in Monterey Bay, CA. Journal of Coastal Research, 00(0), 000000. Coconut Creek, (Florida), ISSN 0749-0208. Published Pre-print online 18 December 2012. DIRECT TESTIMONY OF LARRY M. HAMPSON A.12-04-019 PAGE 11

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DIRECT TESTIMONY OF LARRY M. HAMPSON A.12-04-019 PAGE 12
U:\GENERAL (NEW)\MPWMD - Main\PUC - A.12-04-019 (MRY Water Supply Project)\Testimony\Larry Hampson\Direct Testimony of Larry Hampson.docx

Figure 1 Monterey Bay Buoy Recording, January 2008

Q10. A10.

Does this conclude your testimony? Yes.