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Desalination in Huntington Beachh
Huntington Beach, CA--
Surfrider Foundation activists are actively engaged in
tracking, reviewing and commenting upon many projects that
have the potential to impact our beaches and the ocean.
Seawater desalination facilities are currently being
proposed in many locations in California, Florida, Hawaii
and Texas. Below are comment letters from Southern
California chapter coordinator Joe Geever and Huntington
Beach/Seal Beach chapter activist Don Schulz regarding a
proposed desalination facility in Huntington Beach,
California. After consideration of several such letters and
public testimony by Surfrider activists and many other
concerned citizens, the Huntington Beach City Council voted
to reject the Environmental Impact Report prepared for the
project as inadequate.
TO: Huntington Beach City Council
FROM: Joe Geever, Surfrider Foundation National Headquarters
DATE: December 11, 2003
RE: Huntington-Poseidon Desalination EIR
Dear City Council Members:
We are writing to express our deep gratitude for your review
of the Huntington-Poseidon Desalination Environmental Impact
Report (EIR). As we are certain you are now aware, the
notion of desalination as a source of fresh water for the
state is creating great public discourse -- and several
state agencies are currently reviewing the technical and
policy questions surrounding its use.
The Surfrider Foundation is not at this time opposed to
desalination per se. We, like so many others, are still in
the process of deliberating if, and maybe more importantly
how, desalination should fit into the portfolio of options
to provide the state with water. We have been supportive of
efforts by the City of Long Beach to implement a research
facility to experiment with different technologies to
improve the efficiency of "reverse osmosis" filtration. We
are also encouraged by Long Beach's public statements that
they will also be researching methods for reducing the
adverse environmental impacts associated with some methods
of supplying saltwater for these facilities and discharging
the brine concentrate.
With this in mind, we join the Coastal Commission staff, the
California Energy Commission staff, and the California Parks
and Recreation Department in urging you to deny
certification of the EIR as having failed to adequately
analyze important potential environmental impacts. We are
concerned that decision makers and the public cannot make
fully informed decisions about permits for this project
without additional information that is currently missing
from the EIR. Equally important, we are concerned that the
current EIR will set a very low standard of review for the
numerous other desalination facilities that are currently in
some stage of planning up and down the coast.
Again, thank you for your careful review of this very
important issue. Please feel free to contact me by e-mail or
phone if you have any questions.
Sincerely,
Joe Geever
Southern California Regional Manager
Surfrider Foundation
PO Box 6010, San Clemente, CA, 92674-6010
(310) 410-2890 or jgeever@surfrider.org
Introduction
A lead agency needs only to find a single deficiency in an
Environmental Impact Report (EIR) to reject its
certification. The Huntington Beach Planning Commission
raised several concerns that constitute significant
deficiencies in the current Huntington Poseidon EIR that
have yet to be resolved. In fact, as time has passed, more
of the state's responsible agencies have echoed and
substantiated concerns raised by the public in the early
stages of the Commission's deliberations.
Keeping in mind that an EIR needs to be flawed in only one
aspect to be denied certification, we are submitting several
inadequacies below.
1) Project Description Precludes Reasonable Alternatives
Analysis
The description of this project in the EIR is so narrow that
it precludes reviewing alternatives for the supply of
freshwater to the region. The EIR, in the "project purpose,"
characterizes the product water as a "local" source. This
effectively precludes analyzing whether or not reclamation
and/or conservation efforts would fulfill the broader
purpose of meeting freshwater demand in the region. The
public has requested an analysis of reclamation and
conservation as alternatives, but the response has been that
these sources still rely on imports, and are therefore not
"local" supplies. This narrow project description, and the
absence of reasonable alternatives, makes the EIR
inadequate.
Poseidon has also commented that reclamation does not supply
potable water. However, had the EIR reviewed reclamation, it
would likely conclude that delivery of reclaimed water for
irrigation would reduce the demand for imported water and
groundwater (and that this "saved" water could be used for
increased drinking water demand). Furthermore, Orange County
has one of the more progressive reclamation programs in the
state. This should be applauded and pursued to its fullest
before the county considers projects like massive
desalination facilities with so many unresolved questions
about adverse environmental impacts.
Finally, had the EIR reviewed conservation and reclamation
as reasonable alternatives to desalination, the public would
be made aware of the environmental benefits from these
alternatives. In a city plagued with nearshore water quality
problems, it is important to inform the public that
reclamation has the added benefit of diminishing, if not
altogether removing, treated sewage discharges to the ocean
-- and that conservation has the added benefit of reducing,
if not eliminating, difficult problems of urban runoff.
Furthermore, future reclamation of stormwater runoff would
also remove a major source of nearshore contaminants, as
well as help meet the City's Clean Water Act
responsibilities. In stark contrast, the introduction of new
water into the region will likely exacerbate these on-going
problems.
2) Entrainment/Impingement
This issue is of the utmost concern. Numerous species of
marine life in the Southern California Bight are under
extreme pressure and several are estimated to have been
depleted to less than ten percent of their historical
populations. Others have already been listed as being in
danger of extinction. Also, we are disrupting important
marine ecosystems and predator/prey relationships by the
indiscriminate destruction of marine life through current
"once-through" cooling of coastal generators like the AES
plant. This dramatic loss of marine life and bio-diversity
cannot be mitigated without reducing the total intact of
water at these plants. We simply cannot replace all the
species that are lost to this process with man-made
hatcheries. The marine ecology is far too complex for man to
replicate.
The EIR concludes, without careful consideration, that the
addition of a desalination facility to the existing
Huntington Beach Generating Station (HBGS) will not create
additional marine life mortality (based on the fact that
316(b) studies assume 100% mortality in the cooling water
process and that the desalination facility will not alter
existing cooling water intakes). The basis for this
conclusion is flawed and it avoids documenting the potential
cumulative impacts from these two distinct facilities. It
also avoids an analysis of alternative "feed water" intakes
for the desalination plant (e.g., beach wells and/or
galleries). Furthermore, while the HBGS
entrainment/impingement rates are not directly in question
in this EIR, it is reasonable to consider how the contract
with HBGS to deliver "source water" to the desalination
facility will complicate their future compliance with CWA
§316(b) regulations that will require reducing entrainment
rates by 60 to 90 percent and reduce impingement rates by
80-95 percent.
The 316(b) studies assume 100% mortality for entrained
species as a "precautionary" assumption for the operation of
the generator not the desalination facility. Also, the EIR
does not use "actual" cooling water intakes as the baseline
for analysis, instead it relies on fully permitted capacity
(i.e., 517mgd, 365 days/yr, 24 hrs/day). See: Comment
letters from California Energy Commission staff (Nov 17,
2003) and Coastal Commission staff (Dec 8, 2003).Given these
assumptions and operating permits, the EIR concludes that
the desalination facility will not add to mortality of
marine life and therefore the EIR does not analyze the
addition of the desalination facility for cumulative
impacts.
These assumptions do not accurately reflect "actual"
mortality. Therefore, relying on these assumptions
effectively allows the project proponent to evade analyzing
potential additional marine life mortality. Relying on these
assumptions also turns the "precautionary principle" on its
head.
The Planning Department, in responding to the California
Energy Commission staff letter of November 7, 2003, relied
on the judicial decision in Fairview Neighbors v. County of
Ventura for the argument that "full permitted capacity" is
the proper baseline for determining potential cumulative
impacts. However, Fairview is distinguishable from the
present case because assuming full operation of the facility
in that case (a mining operation and the impact from
associated "daily truck trips") was, in effect, assuming the
"worst case scenario" (in other words, applying the
precautionary principle). In the present case, the baseline
of "full permitted capacity" for HBGS has just the opposite
effect. This baseline allows the project proponent to avoid
looking at the effect of adding a desalination facility to
the existing generator and what cumulative effects might
result from this co-location.
The Planning Department responded that the EIR also analyzed
a "worst case scenario" of 126 million gallons a day (mgd).
However, that scenario was in connection with the brine
discharge concentration. This same scenario should be
applied to the current operating conditions and analyzed for
what additional marine life mortality results from operating
the generators at a higher capacity during these times to
supply power to the desalination plant.
Furthermore, the Planning Department has confused a permit
for a change in the operation of the generator itself with
the addition of a distinct facility that can have an impact
on the operation of the generator. HBGS is currently
operating far below their permitted rates even though the
NPDES permit for the plant assumed full capacity operations.
The EIR should consider a baseline of "actual" operating
rates at HBGS, and then analyze the addition of the
desalination facility at the desalination facility's "full
permitted capacity." This is the logical approach to
estimating cumulative impacts and is entirely consistent
with the court's ruling in Fairview. In other words, if the
addition of the desalination facility causes the generator
to run at times it otherwise wouldn't, or at least run their
cooling water pumps at times they otherwise wouldn't, then
the desalination facility is adding to the cumulative
destruction of marine life. Regardless of the extent of that
additional destruction, it must be analyzed before the EIR
can be certified as "adequate." Given the energy intensive
nature of desalination and the co-location of this plant
with a generator, it is safe to assume HBGS will run beyond
its current output to supply electricity to the desalination
facility. The EIR has stated that the desalination facility
will utilize electricity from HBGS in combination with
electricity from the grid, and that it will rely on HBGS for
emergency back-up power. The desalination plant would use
the idle time when the HBGS peaking plant would not normally
operate to generate additional power, thus creating "new"
entrainment. Finally, the EIR has been amended to state that
the HBGS will run cooling water pumps to supply 126 mgd
regardless of whether the plant is generating electricity.
This is inconsistent with the draft 316(b) regulations that
will require reducing marine life mortality whether or not
this is the current HBGS practice. It is also inconsistent
with earlier statements by the project proponent that the
desalination facility would not operate during times when
the generators were not operating.
Furthermore, the precautionary principle, as applied to the
"once through" cooling and the 316(b) studies, assumes 100%
mortality so that it does not underestimate mortality rates.
This precautionary approach would be just the opposite when
the study results are applied to the desalination facility.
That is, to deal with the uncertainty of whether or not
marine life survives entrainment, the EIR should assume that
some species or individuals WOULD survive the cooling water
process -- and then assume 100% mortality of those species
and individuals at the desalination process. In short,
current 316(b) studies are not the proper protocol for
determining survival rates after the entrainment process (as
noted in the EIR Response to Comments). Therefore, reliance
on these assumptions in the EIR makes the conclusions
inadequate.
3) Growth Inducement Long-term "Natural" Growth or
Overnight Development?
Many argue that population growth is neither good nor bad
it is simply an accepted fact of life in Orange County.
However, there are the inherent impacts that are associated
with population growth, such as the need for improved sewage
treatment capacity and improved responses to polluted
stormwater runoff. These persistent water quality problems
are especially apparent in several places in Orange County.
Some areas, like Huntington Beach and Doheny Beach suffer
from persistent beach closures. Other watersheds, like San
Mateo Creek and Trestles Beach, enjoy some of the last
remnants of relatively undisturbed water quality. Therefore,
the location of growth will have a dramatic influence on the
type of responses that will be necessary to accommodate new
sources of sewage and urban runoff. This fact alone argues
for, at a minimum, identifying the areas that will receive
the product water from this desalination project. The EIR is
inadequate if it does not provide the public with the
information necessary to analyze potential impacts from the
distribution of the product water that is, who is the
intended "end user."
Furthermore, the EIR states that the product water will
supply water for growth projections to the year 2020.
Project proponents have also publicly stated that this is
not "growth inducement," for the most part, but rather
responding to natural population growth from a larger future
generation of current residents. This argument is inherently
flawed.
The economics of this project would suggest that the only
interested purchasers of this water would be areas where
dramatic developments are prohibited only by the lack of an
identifiable source of water (i.e., the Kuehl Act prohibited
developments of more than 500 homes without identifying the
needed water). This water will be approximately twice the
price of current sources, and we can only assume that the
increased costs will be absorbed in the profit from planned
development projects or passed on to the purchasers of the
property, or to OCMWD users as a group. Both cases must be
evaluated in the EIR to allow a reasonable basis for
decision that protects the interests of the Public. Also,
this price difference and most likely customers will
certainly induce immediate growth in the region, and it is
safe to assume that current residents will be left just as
reliant on current water sources as we are today. These
assumptions and predictions are fortified by the project
proponent's recent admissions that the only conditional
contract for delivery of this water is with Santa Margarita
Water District an area with huge development proposals
that are stalled from the lack of water supplies.
Nonetheless, the EIR has not been amended to include these
latest public disclosures, nor has the EIR suggested any
foreseeable potential impacts.
4) What's the Deal with Tampa Bay and How Does that Guide
Us?
The Tampa Bay desalination facility under construction has
raised a couple questions that caution against racing into
reliance on desalination: the fiscal quagmire, and the
technical failures.
On the fiscal side, the construction contracts and projected
operations are proving to have dramatically underestimated
development and production costs. It is possible the
Huntington proposal may actually experience greater costs
than the plant in Tampa Bay. Electricity rates here are much
higher and the higher salinity of the "source water"
nearshore in Huntington Beach will demand more energy use.
The Huntington-Poseidon EIR states that electricity for the
desalination facility will be supplied, in part, from the
grid. This makes it effectively impossible to receive any
rate reductions because: 1) it eliminates the technical
efficiencies of lowering transmission losses (from line
resistance), and 2) it eliminates the potential regulatory
price reductions for "within the fence" supplies. Add to
this the fact that salinity in these waters is higher than
those in Tampa Bay, and the costs for production are
compounded.
As noted above, only water agencies from areas with major
development proposals, held up only by the lack of a
dedicated water source, will have any economic incentive to
purchase this water. This would mean that this new water
source will go to the demand created by immediate growth
not the natural growth predictions for the year 2020.
On the technical side, Poseidon has yet to explain how the
project in Huntington differs from the failed attempt in
Tampa Bay. The Tampa facility has experienced unforeseen
difficulties with their filtration systems and the resulting
reliance on chemicals to keep the filters clean. This
unexpected but dramatically greater reliance on chemicals to
keep the filters clean has added the difficulty of disposing
of the chemicals a consequence that is not fully explored
in the Huntington-Poseidon EIR, but has required the Tampa
plant to shut down.
Poseidon has brought a member of the Tampa Planning
Commission to California to explain that the contract
disputes did not arise until after Poseidon was "bought out"
and no longer in control of the construction. But,
regardless of who is at fault for the Tampa Bay failure, the
decision-makers there have scrapped several future
desalination projects and have returned to emphasizing
conservation and reclamation. Conservation and reclamation
do not create the same environmental impacts as disposing of
the chemicals used to flush the filters at an apparently
unforeseeable rate.
As noted above, conservation and reclamation have not been
considered alternatives for desalination in this EIR.
However, these are the alternatives that are being currently
pursued by the Tampa Bay area the only place we can turn
to for experience with desalination on this scale. The
experience of Tampa Bay only underscores the importance of
including conservation and reclamation as alternative means
of meeting the goals of this EIR. These alternatives are not
only more fiscally responsible and rely on more thoroughly
proven technology they are environmentally preferable
because they reduce sewage discharges and polluted runoff
into our nearshore marine waters.
CONCLUSION
In conclusion, as noted above, an EIR should not be
certified as "adequate" if there are ANY deficiencies. We
have offered several of the more glaring deficiencies in the
current draft. This is not an exhaustive list.
Therefore, we request that the City Council deny
certification of this EIR and include our concerns in your
direction to staff.
Surfrider Foundation
Huntington Beach/Seal Beach Chapter
December 9, 2003
The Honorable Councilmember Dave Sullivan
The Honorable Councilmember Jill Hardy
City Council/Redevelopment Agency
2000 Main Street Huntington Beach, California
Dear Council Members,
Thanks for the opportunity to meet with both of you this
afternoon to discuss our concerns regarding the Huntington
Beach/AES Poseidon Desalination Environmental Impact Report
(EIR).
Our Surfrider Foundation, Huntington Beach/Seal Beach
Chapter commends both the City Planning Commission Staff,
and Board Council Members for expending the extra effort,
and performing their duties with due diligence with regard
to studying these very complex issues before rendering a
final decision. During extended drought periods,
desalination plants, together with water conservation and
water reclamation, are certainly worthy of serious
consideration in order to continue to maintain a safe and
reliable source of drinking water for our residents.
However, as we have stated in previous testimony and written
communications, we believe that the present EIR is both
deficient and inadequate in several important areas of
concern, and should be denied.
Huntington Beach is "surf city" to many of our worldwide
organization membership because of its reputation for
consistently good waves and clean and healthy beaches.
Frequent beach postings and closures, particularly in the
surf zone directly in front of the AES power generating
plant (3N-6N) are not only a threat to public health, but
also impose a negative impact on the City, County, and State
economy. Despite the millions of dollars that have been
spent by the Agencies, OCSD, and the Regional Water Quality
Control Board, to address this problem, no source has yet
been identified as the definitive cause for these chronic
postings. Despite this fact, this is the precise location
and power generating facility that Poseidon has proposed to
use for the construction of a "safe" drinking water
desalination plant. The cautionary principle suggests that
prior to considering a desalination plant at this location,
the source of this seawater contamination be identified, and
eliminated. We hope that you agree.
Thank you for the opportunity to make these comments, and
please feel free to contact the undersigned for any further
information on these issues.
Don Schulz
Executive Committee
Surfrider Foundation
Huntington Beach/Seal Beach Chapter
For additional information regarding environmental issues
associated with desalination plants, see http://www.surfrider.org/desal.htm
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