Rebuttal to Bennett op-ed

06/17/2021

Last week’s letter from Gordon Bennett titled “North Marin Water misses mark with drought plan, rate hike” mixes up two related but separate issues: the proposed revenue increases and rate structure changes that will be considered at a public hearing on June 22, and our efforts to address salinity in the West Marin water supply by building another well at the Gallagher ranch, for which Bennett is the sole protestant. Here is our response to his assertions.

“The rate increase... encourages excessive landscape use.” Reductions to existing tier rate usage thresholds will ensure that water rates reflect the cost of providing service, as required by law. This change does not encourage excessive outside use.

“By failing to create conservation tiers that reflect a sustainable yield, the district is able to use salt intrusion as a false justification for rushing to build another well.” The rate changes are proposed to ensure full compliance with Proposition 218. Salinity intrusion is real and not going away without a physical solution.

“The drought plan discriminates against those already conserving.” Our West Marin Emergency Water Conservation Ordinance remains in effect for a second year in a row. Many customers have already reduced water use to less than mandatory levels; customers using less than 200 gallons a day are already in compliance.

“North Marin’s well at the Gallagher ranch, which is not subject to salt intrusion, pumps at 140 gallons per minute, more than enough to meet demand.” West Marin customers have done a great job conserving water over the years; current water use is 30 percent less than demands in the early 2000s. Even with this level of conservation, the Gallagher well cannot meet demand.

“The Coast Guard wells can be pumped for any extra demand during lower tides... There are also engineered solutions—injection wells and subsurface barriers—that keep saltwater at bay and boost sustainable yields.” During this drought, salinity concentrations in the Coast Guard wells has risen to levels that are independent of tidal fluctuations. With the removal of the Giacomini summer dam across Lagunitas Creek and restoration of the Giacomini Wetlands, salinity intrusion has progressively worsened water quality. After the dam was removed in 1997, N.M.W.D. envisioned a future need to construct a new salinity intrusion barrier (a dam) on Lagunitas Creek, but that was an environmentally sensitive, complex and expensive solution. We believe another well at the Gallagher ranch will avoid the need for a dam. As for other engineered solutions, we could consider desalination, but this technology has other challenges, including high operating costs and significant energy consumption.

“The rate increase’s proposed tier 1 allows 250 gallons per 2.06-person household—an astonishing 121 gallons per person per day. That compares to the state goal of 55 gallons per person per day.” The new tier 1 use threshold is proposed at 250 g.p.d., 37.5 percent less than current use. The state’s goal of 55 gallons per person per day is for indoor use only, and has no bearing on what we need to consider when setting our rates. That said, current residential indoor water use in West Marin is already below that goal.

“Whether or not we need a new well, any construction should be proceeded by environmental studies on possible salmon impacts.” We conducted a CEQA review for construction of the second well in 2009. Together with a March 2021 addendum, that review establishes that the second well would not have an effect on sensitive species habitat.

“The regional water board requested studies in February, but North Marin has been slow to respond.” We moved as quickly as possible to contract with an experienced environmental consultant, develop a detailed scope of work, and solicit input from interested resource agencies and stakeholders, including Bennett, on the proposed study plan. Field study work started last week.

“North Marin appears to have been taking salmon water before doing the studies to determine if it is harming salmon.” We have not yet installed the second Gallagher well. We are working with the California Department of Fish and Wildlife on a mitigation monitoring plan to ensure the project does not harm fish. This is exactly what was done in 2015 before initiating operation of the first Gallagher well.

West Marin customers are invited to attend the public hearing on the proposed revenue increases and rate structure changes on Tuesday, June 22. And N.M.W.D. will remain in full compliance with provisions in its water right license for the diversion of water from Lagunitas Creek.

Drew McIntyre is the general manager for North Marin Water District.