Huntington Beach - Surfrider on Huntington Beach Desalination



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.

Joe Geever
Southern California Regional Manager
Surfrider Foundation
PO Box 6010, San Clemente, CA, 92674-6010
(310) 410-2890 or [email protected]

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.

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






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