North Marin's Gallagher well permit appealed

04/21/2021

Customers serviced by North Marin Water District may be facing another dry season with salty water. The coastal permit the district obtained last month to build a new well that would reduce its reliance on wells suffering from chronic saltwater intrusion has been appealed over a host of environmental concerns, causing delays.

Inverness resident Gordon Bennett filed the appeal on behalf of his organization, Save Our Seashore. Mr. Bennett is concerned that the district has not adequately shown the effect of the proposed well on Lagunitas Creek streamflows and salmonid species. He also questioned the need for a new well as opposed to better district water conservation. 

“We request that the permits and authorizations for this second Gallagher well not be issued until a more comprehensive [California Environmental Quality Act] analysis is completed,” Mr. Bennett wrote in a March letter to a group of local and state regulatory agencies. 

North Marin Water District has defended its environmental review of the project in response to several letters submitted by Save Our Seashore. As a result of the appeal of the coastal permit approved by the deputy zoning administrator in March, the plans will now be reconsidered by the Marin County Planning Commission next month. The district had hoped to bring the new well online this summer.

A handful of customers wrote to the county expressing their support for the well, saying the salinity intrusion issue has become intolerable. For years, North Marin’s primary water source for its West Marin customers has been two wells adjacent to Lagunitas Creek located at the former Coast Guard property in Point Reyes Station; over the past decade, drought has contributed to increased saltwater intrusion from Tomales Bay. Last year, the water was saltier than ever before, leading some customers to turn to bottled water. 

The proposed well would be located far from the bay, on the Gallagher ranch, where an existing well has serviced the district since 2015. Last July, the existing Gallagher well was meeting 38 percent of West Marin’s demand. With a second well, the district intends for the ranch to cover dry season demand, relieving the need for the Coast Guard wells when the water is saltiest. 

The proposed well and distribution pipelines would be built 100 feet from Lagunitas Creek. While the existing Gallagher well was expected to pull 300 gallons of water per minute, it routinely underperforms, at around half that capacity; the district hopes the second well will make up the difference. 

North Marin conducted an initial environmental review for both wells back in 2009, completing an initial study and mitigated negative declaration under CEQA. Earlier this year, the district produced an addendum to that study to meet new evaluation requirements and to bring the report up to date. During that comment period, Mr. Bennett submitted a letter, as did the San Francisco Bay Regional Water Quality Control Board. 

The well is being considered while coastal Marin suffers from two consecutive, record-breaking low rainfall years. Marin Municipal Water District, which releases water from Kent Lake into Lagunitas Creek under water board standards, commissioned a $305,992 study this month to explore how to reduce releases to conserve water without impacting aquatic species. Both districts are asking customers to reduce usage.

The water board and Mr. Bennett shared several concerns about North Marin’s well proposal. In a Feb. 8 letter, the water board asked North Marin to measure the effect on the streamflow of withdrawing water from both wells at once and not during times when water is being released into Lagunitas Creek from Kent Lake by Marin Municipal. 

In response, the district argued that it had tested both wells when flows were low. “Impacts associated with the implementation of Gallagher Well [number one and two], or their cumulative pumping would be de minimis,” the district wrote to the board. 

It added, “Because the pump test was conducted during a dry year and under seasonal low flows, the small observed reductions in gauge height and streamflow can be viewed as a worst-case condition. It is likely that in times of higher creek flows and elevated groundwater levels (i.e., most periods of most years), continued pumping at the site would not register a discernible response in the creek.”

But even small changes to streamflow can negatively impact salmonid species, Mr. Bennett argued. “Salmonids move up and down the stream in response to environmental conditions, yet neither the [previous environmental review] nor the addendum have any data on salmonid use of Lagunitas below the Gallagher well site. This points out the need for a stream channel survey and salmonid survey below the wells,” he wrote. 

In response, the district said while testing the well, the observed reduction in streamflow was very minor—between 0.2 and 0.3 cubic feet per second and causing the surface to drop one-quarter inch, only under drought conditions. The district referred Mr. Bennett to a new mitigation measure. 

To further mitigate any impacts from a new well, North Marin revised the addendum to commit to ongoing monitoring in collaboration with the water board in order to confirm that effects on the streamflow are “less than significant.” 

Drew McIntyre, the general manager, said the district, as the lead agency in the CEQA review, does not need any additional approval from the water board to move ahead with the project. The North Marin board approved the addendum on March 2. On March 5, Mr. Bennett penned a new letter, proposing that the district simply reduce customer water use and continue relying on the existing wells. 

Under two new state laws, water use in California must drop to 55 gallons per person per day by 2023, Mr. Bennett underscored. By contrast, North Marin customers are averaging 74 gallons per day per person, a drop from 117 gallons a day in the early 2000s.

The district’s need for the well was described in the county staff report on the coastal permit. “Recent salinity intrusion has impacted water quality from the existing Coast Guard wells, threatening public health for municipal water users. This change in conditions has necessitated the construction of this project, Gallagher Well No. 2, as an urgent matter to protect the quality of water served,” it stated. 

The date for the planning commission’s consideration of the project is May 24. This month, North Marin made a contingency plan, committing to setting up temporary fill stations at the Coast Guard site supplied with drinking water from the existing Gallagher well for customers with salt-restricted diets.  

Ken Levin, president of the Point Reyes Station Village Association, was among those who urged the county to approve the permit. “West Marin needs a reliable source of salinity and chloride-free water. Thanks to NMWD for planning the necessary infrastructure changes in order to bring this about,” he wrote in a March letter. “Low stream flow water release agreements are already in place and promise protection to fish and wildlife in the event of low water levels in the creek.”