Beach Cleanups & Rain Posted Thursday, January 24, 2008
Unless it is raining real hard, there WILL be a cleanup! We are always there on the scheduled day unless, of course, it is raining cats and dogs :)
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If you are unsure the day of the scheduled cleanup, please call Kitty 714.614.7255
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Thank you for your continued support!~
HB/SB MYSPACE PAGE Posted Tuesday, October 30, 2007
Please come be our friend as we now have a myspace page Check it out: www.myspace.com/surfcitychapter
Seawater Desalination-With a Grain of Salt. Posted Wednesday, July 5, 2006
Pacific Institute issues a comprehensive scientific perspective on seawater desalination. www.pacinst.org/reports/desalination/index.htm
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"Desalination, With a Grain of Salt – A California Perspective, the Pacific Institute provides a comprehensive overview of the history, benefits, and risks of ocean desalination, and the barriers that hinder more widespread use of this technology, especially in the context of recent proposals for a massive increase in desalination development in California."
"The potential benefits of ocean desalination are great, but the economic, cultural, and environmental costs of wide commercialization remain high. In many parts of the world, alternatives can provide the same freshwater benefits of ocean desalination at far lower economic and environmental costs. These alternatives include treating low-quality local water sources, encouraging regional water transfers, improving conservation and efficiency, accelerating wastewater recycling and reuse, and implementing smart land-use planning."
Sunset Aquatic Park Expansion Permit Comments. Posted Wednesday, June 28, 2006
Our environmental coalition partners from the Sierra Club and Friends of the Seal Beach National Wildlife Refuge have joined us in opposing the planned expansion of the Sunset Aquatic Park boat launch and storage facility.
See our chapter post dated April 26,2006 for backround information.
The following letter regarding this issue was sent by the Friends of the Seal Beach National Wildlife Refuge to the O.C. Register.
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May 7, 2006
Orange County Register
Letter to the Editor
Subject: Sunset Aquatic Park Pollution: Trashing our Coast and Ocean
A new parking lot, boat storage yard, and a maintenance facility on our California coast? The County of Orange supports its lessee, Goldrich and Kess, in its ill-conceived proposal to construct such facilities at the coastal Sunset Aquatic Park in Seal Beach.
A coastal area that provides invaluable enjoyment for California
Residents and where multi-million dollar homes exist is an
inappropriate place for this planned expansion. The State of
California is leading the nation in ocean and coastal protection
with creation of its Ocean Protection Council and yet our local
government, the County of Orange, supports its lessee in a proposed
development that is counter to actions stated in California’s
Protecting Our Ocean: California’s Strategy Plan and also violates
The provisions of the federal Clean Water Act, Marine Mammal
Protection Act, and Endangered Species Act.
Sunset Aquatic Park drains polluted runoff into Anaheim Bay and
Onto public beaches in Seal Beach and Long Beach. In addition, it
also drains into the Seal Beach National Wildlife Refuge, the
Habitat of several endangered species. This unnecessary and ill-
conceived development will trash these coastal areas with more
point and nonpoint pollution affecting the health of humans and
Wildlife.
It is time that the County of Orange elected officials who would
wake up to their obligation to protect our California coast and ocean
by rethinking their endorsement of this anti-the California coast and
ocean proposed development.
Bruce and Corinne Monroe
Friends of the Seal Beach National Wildlife Refuge
640 Seabreeze Drive
Seal Beach, CA 90740-5747
Desalanation Plant Opponents Appeal for Tax-Deductable Donations. Posted Monday, June 12, 2006
At the recent Surfrider Foundation Celebrity Surf-Jam, held last Sat. June 10 at the Huntington Beach pier, our desalination plant opposition coalition partners, Residents for Responsible Desalination (R4RD), circulated a petition and an appeal for tax-deductable donations to help support our pending legal battle with the City of Huntington Beach.
To view the text of the petition as well as signing on-line, contact;
www.petitiononline.com/hbdesal/petition.html
Text of the letter follows;
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Dear Neighbor,
R4RD is contesting the Huntington Beach City Council’s approval for Poseidon Resources to build the nation’s largest desalination plant in our city.
If the Poseidon project is built and operated as proposed, it will cause irreparable harm to the community and the coastal environment.
The Council’s approval did not comply with local and state policies.
By a vote of 4-3, the Council granted Poseidon Resources a conditional use permit (CUP) and coastal development permit (CDP) to build a 50-million gallon-per-day (mgd) desalination plant along with approximately 4 miles of 48-inch diameter, high pressure pipeline through the City.
R4RD Takes Action.
R4RD has submitted an appeal to the California Coastal Commission (CCC), which contends that the City violated its own Local Coastal Program (LCP) and the state Coastal Act by granting the CDP to Poseidon. The CCC has agreed unanimously that the appeal has substance and merits formal hearings.
R4RD also filed a legal action in the California courts asserting that the City’s approval of the Poseidon project Environment Impact Report (EIR) violated the California Environmental Quality Act (CEQA). These legal actions are now proceeding.
R4RD needs your help—These actions are important and costly.
R4RD is composed of a diverse group of residents from Huntington Beach and surrounding communities who have joined together to educate the public about desalination. Surfrider Foundation, the Sierra Club, and SEHBNA have joined the cause. This coalition has contributed significantly to mount this challenge, yet has raised only 80% of what may be required to pursue these legal actions. We still need to raise at least $7,000 from the community.
Your donation can make a difference!
For the sake of a better community and to protect our precious ocean resource, join R4RD and/or make a tax-deductible donation. To participate in this very worthy cause, please mail your donation or membership dues in the enclosed envelope. Find answers to questions, additional information, future events, and updates on our website at www.hbdesalfacts.org.
The challenge is before all of us. We want and need your involvement.
Thank you very much for your continued support.
Sincerely,
Topper Horack, President
Donations may be mailed to;
R4RD
P.O. Box 5422
Huntington Beach CA. 92615-5422
Chapter Submits Grant Application Support Letters for Diversion Projects. Posted Monday, June 5, 2006
Our Chapter recently submitted the following letters of support
to the City of Huntington Beach for grant funding for urban runoff diversion and water quality control projects in the Wintersberg Channel/East Garden Grove and Irby Park sections of our watershed.
Both diversions and water quality control technologies such as constructed wetlands, have proven benefits in reducing the amount of polluted runoff that eventually reaches the surf zone.
Text of these letters follows;
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Geraldine Lucas June 1, 2006
Principal Civil Engineer
City of Huntington Beach
2000 Main Street
Huntington Beach, CA 92648
Subject: Letter of Support for Application # 9005 – East Garden Grove Wintersburg Channel Urban Runoff Diversion-Phase II
Dear Mrs. Lucas,
We are writing to express the Surfrider Foundation, Huntington Beach/Seal Beach Chapter support for the City of Huntington Beach’s grant request to complete Phase II of the East Garden Grove Wintersburg Channel Urban Runoff Diversion Project located in the Central Park area. When completed, the project will provide multi-benefits to the city and region.
The project will complete Phase I & II of the East Garden Grove Wintersburg Channel Urban Runoff Diversion Project. Phase I includes the diversion of approximately 3 million gallons per day of urban runoff from the channel through pre-treatment devices and into a 15-acre area on the east side of Central Park for treatment. Phase II includes routing the urban runoff to the west side of Central Park to be used as a water source for Huntington Lake and Shipley Nature Center. The primary project's treatment technology includes an engineered wetland system with infiltration enhancements.
We believe this project is very worthwhile and strongly support state funding for it.
Sincerely,
Don Schulz P.E.
Blue Water Task Force
Surfrider Foundation
Huntington Beach/Seal Beach Chapter
P.O. Box 3087, Long Beach, CA 90803
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Geraldine Lucas June 1, 2006
Principal Civil Engineer
City of Huntington Beach
2000 Main Street
Huntington Beach, CA 92648
Subject: Letter of Support for Application # 9006 – Irby Park Urban Runoff Treatment Project
Dear Mrs. Lucas,
We are writing to express the Surfrider Foundation, Huntington Beach/Seal Beach Chapter support for the City of Huntington Beach’s grant request for the Irby Park Urban Runoff Treatment Project located in the city of Huntington Beach. When completed, the project will provide multi-benefits to the city and region.
This project will divert approximately 250,000 gallons per day of polluted urban runoff from the Wintersburg Channel and local drainage areas through pre-treatment devices, into a city owned 7-acre area in Irby Park for natural treatment provided by an engineered wetland system. This project will provide multi-benefits to the region; including the protection of the beneficial uses of our receiving waters; enhancement of local flood control, habitat value & park features; groundwater recharge; and education & outreach opportunities.
We believe this project is very worthwhile and strongly support state funding for it.
Sincerely,
Don Schulz P.E.
Blue Water Task Force
Huntington Beach/Seal Beach Chapter
P.O. Box 3087, Long Beach, CA 90803
AMRF Recruits Volunteers for Research Project. Posted Friday, June 2, 2006
Beginning July 1st Algalita Marine Research Foundation will begin a new relationship with Cabrillo Marine Aquarium. We will be having a lab space in their marine science building. This space will allow us to analyze both beach sand samples and ocean plankton samples for plastic content. Students that come through the aquarium on a regular basis will be exposed to our analytical techniques and our issues of concern with plastics in the ocean. We need volunteers at the Cabrillo Lab to analyze and explain samples to students coming through the aquarium and in some cases, to teach students to do the sampling because some classes will return on a regular basis to the aquarium.. We will need volunteers who can be there whenever a class comes through and give a brief talk about what we do and there will also be a need for volunteers to actually teach students that are there for repeat visits how to analyze samples themselves. Each person that comes in contact with these children needs to fill out a volunteer form to work at Cabrillo Marine Aquarium and needs to go to a designated location to get finger printed. You will then be given a parking pass for the aquarium’s parking lot. We will be coordinating the schedule with the education director, Linda Chilton, so that we will always have somebody there when needed to support her work with the students. Please let us know if you are interested in this new and exciting opportunity. You can also visit Algalita Marine Research Foundations website at http://algalita.org for more information and a sample volunteer from and information about fingerprinting locations.
Thank you,
Captain Charles Moore
Orange County Beach Water Quality is Getting Better. Posted Wednesday, May 31, 2006
Two recently released reports on Orange County beach water quality both indicate that the over the past year water quality conditions at our local beaches are improving.
According to the environmental group Heal the Bay water quality at almost all Orange County beaches this summer was rated excellent. The only failing grade was given to Huntington State Beach at Magnolia Boulevard. Beaches receiving C's were Huntington State Beach at Newland Avenue, Newport Bay Harbor Patrol Beach, Monarch Beach North, San Juan Creek at the ocean interface and Dana Point Harbor west-end Baby Beach. Doheny Beach at Poche Creek received a D.
Also, the 2005 Annual Ocean and Bay Water Quality Report from the Orange County Health Care Agency (OCHCA) states, “In 2005 the total number of postings during the AB411 period (April to October) remained virtually unchanged from 2004, and was the 2nd lowest since 2000.” And; “From 2000 through 2005 Doheny State Beach had the highest number of beach mile days posted due to AB411 standard violations.”
Details of each of these reports can be downloaded from;
www.healthebay.org/brc/ for Heal the Bay
and.
www.ocbeachinfo.com/downloads/reports/2005oceanreport.pdf for OCHCA.
Surfdad
Surfrider Comments to. H.B. City Council RE: Poseidon Desal. CDP Posted Saturday, February 25, 2006
Our Surfrider Chapter has been joined by Surfrider Foundation National in submitting the following comments to the Huntington Beach City Council regarding the inconsistencies that exist between the proposed Poseidon Coastal Development Permit (CDP) and the
current Huntington Beach Local Coastal Program (LCP).
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February 24, 2006
TO: Huntington Beach City Council
FROM: Surfrider Foundation
VIA E-Mail
RE: Poseidon Desalination CDP No. 02-05 (Seawater Desalination Project)
Dear City Council Members:
We are writing on behalf of the Surfrider Foundation and our more than 45,000 members – all of whom are dedicated to the protection and enjoyment of our coast and ocean. We first want to thank you for your careful consideration of this letter.
Please accept the comments below in regards to the Coastal Development Permit (CDP) for the Poseidon Huntington Beach Desalination Facility. As detailed below and in the attached letters, the issuance of a permit for this desalination facility would violate the policies of the California Coastal Act and the City of Huntington Beach Local Coastal Program (LCP).
Furthermore, we ask that you consider the issuance of the CDP within the context of the numerous concerns about the inadequacy of the Recirculated Environmental Impact Report (REIR) that were raised by Surfrider Foundation and several environmental organizations, numerous state and federal government agencies, and members of the general public. Among many inadequacies, the REIR failed to fully inform the public of:
- the interrelationship of the proposed desal facility with the Huntington Beach Generating Station (HBGS), the foreseeable future of the cooling water intake structure at HBGS, and the associated impacts to marine life attributable to the proposed desal project as a “stand alone” facility;
- a clearly identified need for the project and a reasonable range of alternatives for meeting that need – including greater reliance on future wastewater recycling, water conservation, and stormwater retention;
- the increased energy demand, both for this project proposal individually and for the multiple statewide ocean desalination proposals cumulatively, of reliance on ocean desalination as a new source of fresh water supply.
NATIONAL OFFICE – PO BOX 6010 – SAN CLEMENTE, CA 92674-6010
(949) 492-8170 – FAX (949) 492-8142 – www.surfrider.org - E-MAIL info@surfrider.org
We have described in the two attached letters how the issuance of a CDP for this facility will violate the City’s LCP. Briefly, the attached letters document:
- the City’s goals, objectives and implementation policies on alternatives for fresh water supplies that call for implementation of water conservation, wastewater reclamation and stormwater retention – as opposed to the clear City policy to encourage the study of desalination production;
- the misinterpretation of the standards for compliance with CEQA versus compliance with the City’s policies in the LCP. In particular, the standard for minimizing impacts to marine resources does not demand a finding of “significance” and does not allow for “after the fact” restoration.
Per this writing, we are including for your consideration the LCP language regarding the maintenance and restoration of marine water quality to mitigate adverse impacts on marine organisms. We are also including language on energy production and the City’s clear policy for encouraging alternative sources – as opposed to permitting projects that exacerbate the limits of existing energy production.
Again, thank you for your consideration of these comments.
Sincerely,
Joe Geever Don Schulz
Regional Manager HuntingtonBeach/Seal Beach Chapter
Surfrider Foundation Surfrider Foundation
8117 W Manchester Ave, #297 PO Box 3087
Playa del Rey, CA 90293 Long Beach, CA 90803
ADDITIONAL COMMENTS
(Please consider these comments in addition to those submitted in the attached letters of October 17, 2005 and January 9, 2006)
LCP § C6 – Water and Marine Resources
The Staff Recommendations for “Findings and Conditions of Approval” (Findings) refers to LCP policy C 6.1.1: “Require that new development include mitigation measures to prevent the degradation of water quality of groundwater basins, wetlands and surface waters.” See: Findings, Attachment p. 1.3.
This quote is inaccurate. The actual language in the LCP is: “Require that new development include mitigation measures to enhance water quality, if feasible; and at a minimum, prevent the degradation of water quality of groundwater basins, wetlands, and surface water. LCP § C 6.1.1 [emphasis added].
Furthermore, the LCP also includes several relevant policies to “…mitigate the impacts of human activities on marine organisms and the marine environment….” See: LCP § C 6.1 (Objective). These more relevant policies that were not included in the Findings include:
- C 6.1.2: Marine resources shall be maintained, enhanced, and where feasible restored. Special protection shall be given to areas and species of special biological or economic significance.
- C 6.1.4: The biological productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes appropriate to maintain organisms and for the protection of human health shall be maintained and, where feasible, restored.
The misquotation and/or omission of relevant policy in the Findings precludes thorough consideration of the CDP. The Findings go on to suggest that, “Based on the analysis contained in the Recirculated EIR, no mitigation measures are required to protect ocean water quality.” See: Findings, p. 1.3 However, there is no similar finding that mitigation measures to enhance water quality have been considered – as required in the misquoted LCP policy. Furthermore, there is no similar finding that marine resources will be maintained, enhanced or restored – as mandated in the LCP.
Once again, the Findings have confused the standards for compliance with CEQA with those of the California Coastal Act. Reliance on the Recirculated EIR conclusions about “significance” is insufficient for analyzing compliance with the City’s own LCP §§ C 6.1.2 and C 6.1.4.
In conclusion, even the Recirculated EIR found that the discharge of cleaning solutions and concentrated brine would impact the biological productivity of the zone of dilution surrounding the discharge conduit by displacing certain species. This adverse impact could be exacerbated if, according to the Statement of Facts and Findings, “an alternative to discharging the ‘first rinse’ of the RO membrane cleaning solution into the OCSD system is to discharge the solution (‘first rinse’ and all subsequent rinses) into the Pacific Ocean via the HBGS outfall.” These cleaning chemicals include industrial soaps and weak solutions of acids and sodium hydroxide. Approval of the CDP would violate the LCP without thorough consideration and documentation of whether the discharge of concentrated brine and cleaning solutions met all the policies contained in LCP policies C 6 1.1, C 61.2, C 61.4, et seq.
LCP § C 8 – Energy Facilities
Local Coastal Program policy C 8 sets the goal to: “Accommodate energy facilities with the intent to promote beneficial effects while mitigating any potential adverse impacts.” An example of the policies to carry out the goal includes: “Promote the use of solar energy and encourage energy conservation.” See: LCP § C 8.3.1.
It is well documented in the record that ocean desalination, despite claims of improvements in efficiency, is still the most energy demanding alternative for fresh water supplies. The EIR documents that the proposed project will require 35 megawatts and that this demand will create an estimated increase in the Huntington Beach load of approximately nine percent (9%) over existing demand. See: Draft REIR § 6.0, p 6.24.
The REIR fails to compare the energy demands of wastewater reclamation. More importantly, the REIR fails to document the potential energy conservation that could be realized from aggressive pursuit of water conservation and stormwater retention programs. As noted in our previous letters, these programs have been documented in the Urban Water Management Plan published by the Municipal Water District of Orange County as sufficient means to meet the fresh water demands of the region until the year 2030 planning horizon.
Therefore, approval by the City Council of the Poseidon Huntington Beach Desalination Project proposal would violate the City’s clear policy to “…encourage energy conservation.”
Attachments:
Letter from Surfrider Foundation to City of Huntington Beach (dated October 17, 2005)
Letter from Surfrider Foundation to City of Huntington Beach (dated January 9, 2006)
Chapter Submits Sewage Treatment Backsliding Comments to OCSD Posted Saturday, February 18, 2006
On Feb. 22, at 7pm, at the Orange County Sewage District (OCSD) Administration offices in Fountain Valley, the OCSD Board Members will recieve an update of treatment costs and level of sewage treatment at the OCSD treatment facilities.
We are concerned that the Board may be considering backsliding with regard to the committment to meet their NPDES permit compliance schedule, and have submitted the following comments;
February 17, 2006
Dear Interim General Manage Ruth and OCSD Board Members;
We understand that a proposal is being considered to reduce sewage treatment levels before discharging effluent into the ocean.
We respectfully oppose this proposal, and ask that you continue maximum treatment protocols prior to discharge. Two cents per week, or a dollar or two per resident per year, is a modest price to pay to protect Orange County’s greatest resource.
Our chapter commends the OCSD staff for their commitment to the full secondary treatment of our wastewater with existing facilities, and the GWR initiative.
The economy and environment of Orange County is heavily leveraged against a clean ocean and beach wellness. Backsliding treatment levels are not in the best interest of our residents and guests. Hence, please remain committed to the highest levels of wastewater treatment going forward.
Respectfully,
Greg Jewell
Executive Committee Member
Seal Beach/Huntington Beach Chapter
714-891-1545
Chapter Endorses State Lands Commission Resolution Posted Thursday, February 9, 2006
Our Chapter has submitted the following comments to the State Lands Commission in support of a resolution opposing once-through cooling in California power generating facilities.
Chapter staff representative Joe Geever is making the trip to Sacramento to present our views to the Commission.
Text follows;
Dear Chair Westly and Commissioners:
We are writing to strongly support your proposed resolution on the elimination of once-through cooling in California power generating facilities, and urge the Commission to pass it during your meeting on February 9, 2006. We greatly appreciate the California State Lands Commission's effort to take a leadership role on this very important and timely issue.
Once-through cooling systems are highly destructive to marine life, and it is time to eliminate this antiquated destructive methodology from our precious coastal waters.
Thank you.
Surfrider Foundation
Huntington Beach/Seal Beach Chapter
P.O. Box 3087 Long Beach CA 90803
RESOLUTION BY THE CALIFORNIA STATE LANDS COMMISSION REGARDING ONCE THROUGH COOLING IN CALIFORNIA POWER PLANTS
WHEREAS, The California State Lands Commission and legislative grantees of public trust lands are responsible for the administering and protecting the public trust lands underlying the navigable waters of the state, which are held in trust for the people of California; and
WHEREAS, the public trust lands are vital to the recreational, economic and environmental values of California's coast and ocean; and
WHEREAS, the commission has aggressively sought correction of adverse impacts on the biological productivity of its lands including, litigation over contamination off the Palos Verdes Peninsula and at Iron Mountain, the adoption of best management practices for marinas and litigation to restore flows to the Owens River; and
WHEREAS, California has twenty-one coastal power plants which use once-through cooling, the majority of which are located on bays and estuaries where sensitive fish nurseries for many important species are located; and
WHEREAS, these power plants are authorized to withdraw and discharge approximately 16.7 billion gallons of ocean water daily; and
WHEREAS, once-through cooling harms the environment by killing large numbers of fish and other wildlife, larvae and eggs as they are drawn through fish screens and other parts of the power plant cooling system; and
WHEREAS, once through cooling also adversely affects the coastal environment by raising the temperature of adjacent water, killing and displacing wildlife and plant life; and
WHEREAS, various studies have documented the harm caused by once-through cooling including one study that estimated that 2.2 million fish were annually ingested into eight southern California power plants during the late 1970s and another that estimated that 57 tons of fish were killed annually when all of the units of the San Onofre Nuclear Generating Station were operating; and
WHEREAS, regulations adopted under Section 316 (b) of the federal Clean Water Act recognize the adverse impacts of once-through cooling by effectively prohibiting new power plants from using such systems; and
WHEREAS, the Governor's Ocean Action Plan calls for an increase in the abundance and diversity of aquatic life in California's oceans, bays, estuaries and coastal wetlands, a goal which can be better met by eliminating the impacts of once-through cooling; and
WHEREAS, members of the California Ocean Protection Council have called for consideration of a policy at its next meeting to discourage once-through cooling; and
WHEREAS, the California Energy Commission and the State Water Resources Control Board have the authority and jurisdiction over the design of power plants and are conducting studies into alternatives to once-through cooling, such as air cooling, cooling with treated wastewater or recycled water and cooling towers; and
WHEREAS, in its 2005 Integrated Energy and Policy Report, the California Energy Commission adopted a recommendation to work with other agencies to improve assessment of the ecological impacts of once-through cooling and to develop a better approach to the use of best-available retrofit technologies; and
WHEREAS, the Commission recognizes that the coastal power plants currently utilizing once-through cooling make an important contribution to California's energy supply, but believes that the elimination of these cooling systems, through conservation, conversion, construction of new facilities, or utilization of other sources can be feasible and will be facilitated by establishing a deadline for this to occur; therefore, be it
Resolved by the California State Lands Commission that it urges the California Energy Commission and the State Water Resources Control Board to expeditiously complete all necessary studies and develop policies that eliminate once-through cooling from all new and existing power plants in California; and be it further
Resolved, that the Commission shall not approve new leases or extensions of existing leases for facilities associated with once-through cooling after 2020 and calls on public grantees of public trust lands to implement the same policy for facilities within their jurisdiction; and be it further
Resolved, that the Commission's Executive Officer transmit copies of this resolution to the Chairs of the State Water Resources Control Board, the California Energy Commission, and the California Ocean Protection Council, all grantees, and all current lessees of public trust lands that utilize once-through cooling.
Huntington Beach City Council Meeting, Feb.27 Posted Saturday, January 21, 2006
January 21 2006
ATTENTION CHAPTER MEMBERS:
On February 27, 2006 the Huntington Beach City Council will consider a vote on whether to permit the nation’s second massive ocean desalination facility. A similar facility, about half the size, was approved and constructed in Tampa Bay, Florida several years ago. It has yet to function properly.
But the Huntington Beach vote goes beyond consideration of the reliability of a single co-located and out-dated power generating station and desalination plant.
WILL WE CHOOSE A HEALTHY ENVIRONMENT, OR CONTINUE TO DEGRADE THE COAST AND OCEAN WE LOVE?
Once-through cooling power generating stations, such as the AES power generating station in Huntington Beach, are harmful to Marine Life:
This desalination facility will rely on out-dated cooling water technology at the AES coastal generator in southeast Huntington Beach. “Once-though” cooling of hundreds of millions of gallons of ocean water daily –killing precious marine life in the process. Surfrider Foundation is currently challenging the regulations on cooling water intakes in federal court. It is time for coastal generators to quit killing marine life by updating and retrofitting with modern cooling technology. This desalination facility will only serve to prolong the life of this destructive practice.
There Are Better Choices:
We don’t need the water. The Municipal Water District of Orange County (MWOCD) has recently concluded that we can meet the future demand for water in the region with alternatives that can actually improve our ocean water
quality. To their credit, MWDOC is promoting:
•Water conservation. We can dramatically reduce the demand for water
by simple installation of water saving devices both in our homes
and gardens. We currently use around 50%of our water on residential
irrigation – and much of it ends up going down the gutter. With
improved irrigation devices and practices we can save water and
dramatically reduce polluted water reaching our beaches.
•Water Recycling. Orange County is currently developing an award-
winning Groundwater Replenishment System to take the wastewater we
were discharging to the ocean and put it to good use. Wastewater is
first purified with the same technology used for desalination and
then injected into our groundwater to protect against saltwater
intrusion and to store it for future uses. With a fully operational
Water Recycling program, we can eliminate otherwise harmful
wastewater discharges to our local beaches and improve our future
water supplies.
•Stormwater Capture. Orange County is on the leading edge of
developing Natural Treatment Systems by constructing a series of
wetlands to Capture stormwater. These wetlands will naturally
purify run-off,allow the water time to percolate to our aquifers,
and re-create critical habitat for numerous threatened species.
AND HERE’S THE KICKER – THESE ALTERNATIVES ARE ALL CHEAPER THAN OCEAN
DESALINATION!
The choice is clear – we can choose alternatives that both ensure a
reliable source of freshwater and improve our coastal environment, or we can rely on an out-dated and destructive coastal generator.
For more detailed information regarding water conservation, recycling, and other desalination issues, visit the following websites;
www.MWDOC.com
www.hbdesalfacts.org
www.surfrider.org/a-z/desal.asp and www.surfrider.org/huntington/ newsletter
www.coastal.ca.gov/energy/ 14a-3-2004-desalination.pdf
A list of other environmental organizations that share our views and have submitted comments to the Huntington Beach City Council on this issue include;
California Coastal Protection Network * California Earthcorps * Elkhorn Slough Coalition * Friends of the Sea Otter * Friends Artists and Neighbors of Elkhorn Slough * Public Citizens * San Diego Baykeeper * Save Our Shores * Save Our Waterfront Committee * Sierra Club * Southern California Watershed Alliance * Surfrider Foundation * The Ocean Conservancy
Please join us at the Huntington Beach City Council hearing on February 27, and show your support for healthy coasts and oceans. Both your attendance and attention to this important environmental issue is greatly appreciated.
THANKS
Executive Committee Members
Surfrider Foundation
Huntington Beach/Seal Beach Chapter
P.O. Box 3087, Long Beach, CA 90803
Surfrider Foundation Comments to Huntington Beach City Council Posted Tuesday, January 10, 2006
TO: Huntington Beach City Council (Via e-mail)
RE: Poseidon Desalination CDP No. 02-05 (Seawater Desalination Project)
Dear Huntington Beach City Council:
We are writing on behalf of the Surfrider Foundation and our more than 50,000 members. Surfrider Foundation is an environmental organization dedicated to the restoration and protection of our coasts and oceans. We want to thank the City Council for your consideration of the following comments.
We continue to believe the FREIR for this project is woefully inadequate and that recent revelations about the design and potential operation of this facility raise significant environmental concerns that have yet to be fully analyzed. Nonetheless, even assuming the FREIR is adequate, for the sake of analyzing the Coastal Development Permit (CDP), the project’s identified impacts violate the City’s Local Coastal Program (LCP).
A non-exhaustive list of concerns include:
1) the policies adopted in the LCP clearly identify preferred alternatives for meeting the freshwater demands of the area, and this project is inconsistent with those delineated policies. Furthermore, as noted in numerous comments on the FREIR, this project is inconsistent with the regional Urban Water Management Plan produced by the Municipal Water District of Orange County – which identifies a freshwater supply portfolio that is consistent with the Huntington Beach LCP policies.
2) New information suggests that the FREIR did not fully disclose the design of the project proposal and consequently omitted components that will exacerbate existing impacts on marine life and associated marine ecosystems. Furthermore, even using the impacts documented in the FREIR, the CDP fails to recognize the different standards for analysis between CEQA requirements and the policies of the LCP. Finally, full disclosure would include an analysis of the desalination project as a “stand alone” facility.
These broad points are outlined in greater detail below. Once again, thank you for your consideration of these comments. We look forward to a thorough response.
Sincerely,
Joe Geever
Southern California Regional Manager
Surfrider Foundation
ANALYSIS of POSEIDON CDP & LCP CONSISTENCY
1) “Alternatives” Analysis and LCP Consistency
As we have noted numerous times in previous comments on the environmental analysis of this proposed project, there are several alternatives for meeting the future demand for freshwater in the region. Briefly re-stated, the need for this project can be met through greater efforts at water conservation, wastewater reclamation, and stormwater management.
In fact, the regional water purveyor, the Municipal Water District of Orange County (MWDOC), has also identified these alternative sources of freshwater in their recently published Urban Water Management Plan. MWDOC has concluded that future demand for freshwater can be met through these alternative sources.
Importantly, these alternatives also have associated environmental benefits, including reduced urban runoff from irrigation conservation and stormwater retention, and reduced ocean discharges from expanded wastewater reclamation.
The “Request for City Council Action” (dated January 9, 2006) recommending approval of the Coastal Development Permit (CDP) cites the consistency of the proposed facility with Section C 6.1.13 [“Encourage research and feasibility studies regarding ocean water desalination as an alternative source of potable water. Participate in regional studies and efforts where appropriate.”] There is no other reference to LCP policies on alternative sources of potable water cited in the Request for City Council Action.
LCP Section C 6.1.13
The Request for City Council Action (hereinafter “Request”) seems to imply that the proposed desalination production facility is consistent with the LCP policy encouraging research and feasibility studies:
“By building the facility and locating it in Huntington Beach, the facility will demonstrate the opportunities offered by desalination, and will offer cities, counties, and the State of California a tangible example of how desalination can become more widely accepted throughout the State and the nation, and will encourage additional research and feasibility studies regarding ocean desalination as an alternative source of potable water.” See: Request Attachment 1.6.
In effect, the “Request” has characterized a production facility as somehow participating in and/or encouraging research and feasibility studies. This bold assertion is not substantiated in any way and is, on its face, counter-intuitive.
Research and feasibility studies are already being conducted in other locations around the State of California. It is unclear how the construction of a production facility, prior to the conclusion of on-going research and feasibility studies, is “participating” in these regional studies. Furthermore, it is unclear how the construction of a full-blown production facility encourages “research and feasibility studies.” Common sense and a reasonable interpretation of the City’s LCP would conclude that research and feasibility studies be conducted prior to the development of production facilities. Therefore, the implicit conclusion that this project proposal is consistent with the policy contained in the City’s LCP § C 6.1.13 is flawed.
LCP Sections C 6.1.12, C 6.1.14, C 6.1.18(c)
Maybe more importantly, the analysis of sub-Section C 6.1.13 in the Request for City Council Action is taken out of the context of other relevant policies contained in that Section. A more comprehensive review of the City’s LCP indicates a broader policy of encouraging implementation of alternative sources of freshwater supplies – as opposed to the policy to study ocean water desalination.
For example: LCP § C 6.1.12 encourages water conservation implementation ; LCP § C 6.1.14 encourages implementing wastewater reclamation projects ; and LCP § C 6.1.18(c) encourages flood control projects that provide percolation to existing groundwater supplies .
As noted in our comments on previous iterations of the EIR and REIR, the environmental benefits of these alternative sources of freshwater supplies were not thoroughly considered. This absence of any analysis in the environmental documents, combined with the limited citation of LCP policies in the Request for City Council Action, has precluded a thorough review of critical issues surrounding the approval of a Coastal Development Permit. Therefore, the Request for City Council Action is arguably incomplete and misleading, and approval of the CDP would violate the comprehensive policies referenced above and codified in the City’s LCP.
2) Entrainment/Impingement and LCP Mitigation Policy
There are several issues raised in the administrative record on this project that are relevant to the issuance of a Coastal Development Permit.
- First, the Request for City Council Action confuses legal standards in the California Environmental Quality Act (CEQA) with the clear policy of the City’s own Local Coastal Program.
- Second, the Request for City Council Action concludes that the withdrawal of ocean water for the desalination facility is not regulated by the Clean Water Act § 316(b). That is exactly the reason why the proposed project needs to be analyzed as a “stand alone” project before any permits are issued.
- Finally, it has come to our attention that the Project Proponent has a patent for an intake method to mix the hot water from the generator’s discharge with cooler water that by-passes the generator (see additional discussion below). Because this method apparently improves the overall energy efficiency of the desalination process, the Project Proponent will likely implement this newly patented process at the Huntington Beach facility. Therefore, the additional marine life mortality from the by-passed portion of the desalination “feed water” should be analyzed both in a newly recirculated EIR, as well as reviewed for consistency with the LCP. Additionally, because CEQA § 15126.4 requires an analysis of feasible energy efficiency measures, a revised EIR must also review how this patented process would affect energy use of the proposed facility.
LCP § C 6.1.19 versus CEQA Review
The Request for City Council Action has confused the CEQA requirement to mitigate “significant” impacts to the environment with the stricter policy in the City’s LCP to provide “maximum feasible mitigation measures to minimize damage to marine organisms….”
The City’s LCP states:
“Prior to the approval of any new or expanded seawater pumping facilities, require the provision of maximum feasible mitigation measures to minimize damage to marine organisms due to entrainment in accordance with State and Federal law.” See: LCP § C 6.1.19.
The proposed project is a new facility in that it is taking seawater and pumping it through pre-filtration and reverse osmosis filter trains over and above the existing uses of seawater for cooling the Huntington Beach Generating Station.
Importantly, the City’s LCP policy does not require a finding of “significant” impacts to trigger the mitigation measures. In contrast to CEQA, the City’s policy requires maximum feasible mitigation measures to minimize damage to marine organisms due to entrainment – regardless of whether that entrainment mortality is considered “significant.”
In the “Statement of Facts and Findings” the City documents that: “The desalination project is estimated to increase mortality by 1.2 percent (from 94.1% to 95.3%) at flows of 507 MGD and by 4.6 percent (from 94.1% to 98.7%) at flows of 127 MGD.” See: Finding for Impingement and Entrainment, page 17 of 48. The “Statement of Facts and Findings” goes on to conclude that this mortality attributable to the desalination facility is “insignificant.” Id.
The reasoning employed in the “Statement of Facts and Findings” has applied the wrong standard. There is nothing in the City’s LCP that requires a finding of “significant” impacts before triggering the requirement to provide maximum feasible mitigation measures. Therefore, the CDP should be denied until the project proponent identifies and provides maximum feasible mitigation measures for, at the very least, the damage to marine organisms admittedly attributable to the project. Further, the additional water that would be used due to the patented process described below may, in fact, increase entrainment impacts to levels that would be considered “significant” under CEQA; however this has not yet been addressed in the EIR.
Clean Water Act § 316(b) and the California Coastal Act
The City has mischaracterized recently adopted regulations on cooling water intakes under the authority of the federal Clean Water Act § 316(b) and has not thoroughly analyzed the implication of these regulations to the co-location of the proposed desalination facility.
The “Statement of Facts and Findings” argues that, “[T]he proposed desalination facility would not result in significant entrainment impacts even upon implementation of the new U.S Environmental Protection Agency (EPA) 316(b) final rule (which mandates a reduction in entrainment by 60 to 90 percent….).” See: Statement of Facts and Findings, page 17 of 48. The City then goes on to imply that “[i]mplementation of an improved intake screening system, velocity reduction, or other EPA approved method” would bring the HBGS into compliance with those regulations without having any implications on the co-location of the desalination facility. Id.
First, the City’s analysis has not fully documented the recommendations for reducing entrainment contained in the final rule on 316(b). The limited choice of “improved intake screening” and/or “velocity reduction” are, in fact, methods to reduce impingement, not entrainment, and have little to do with meeting the rule’s “performance standard” of reducing entrainment by 90%. Furthermore, HBGS has not been granted a permit under the new rule. It is foreseeable that, within the realm of alternatives for meeting the new performance standards in the 316(b) regulations, HBGS will have to dramatically reduce the volume of its current cooling water intake. Obviously, this reduction of volume will have a direct implication on the operation of the desalination facility, as well as the marine life mortality that is attributable to the desalination operations.
In the “Request for City Council Action” the City goes on to argue that “withdrawal of feedwater for desalination is from the HBGS cooling water discharge and not subject to intake regulation under the Federal Clean Water Act (316b).” See: Request for City Council Action, Attachment 1.5.
This reasoning is precisely why it is critical for the City to consider the operation of the desalination facility as a “stand alone” plant. Should HBGS reduce the volume of cooling water intake by 90% to meet the requirements of the new 316(b) regulations, the result would be the elimination of the required 100 MGD for the co-located desalination facility. Furthermore, if the City’s interpretation of the Clean Water Act is correct, any additional withdrawal of seawater to feed the desalination facility would not be regulated by Section 316(b).
Nonetheless, the additional withdrawal of seawater for the desalination facility would be regulated by the City’s policy on new or expanded seawater pumping facilities. See: LCP § C 6.1.19.
Given that the future of the existing cooling water intake system at HBGS is speculative, and it is reasonably foreseeable that there will be dramatic reductions in the volume of cooling water from HBGS available as feedwater for the proposed project, the CDP must “require the provision of maximum feasible mitigation measures to minimize damage to marine organisms due to entrainment” prior to approving a Coastal Development Permit. See: LCP § C 6.1.19.
Substantial New Information on Feedwater Intake
There is new available information on “feedwater” methods of operation that is relevant to the review of this proposed project and is not contained in the administrative record. This new information is relevant both to the previous certification of the REIR and to the applicable policies in the City’s LCP.
We have recently become aware that Poseidon has a patented process to improve efficiencies by mixing the hot water from the generator’s cooling system discharge with colder water that is diverted around the coastal generator.
See: http://patft.uspto.gov/netacgi/nph-Parser?Sect1=PTO2&Sect2=HITOFF&p=1&u=/netahtml/search-bool.html&r=1&f=G&l=50&co1=AND&d=ptxt&s1=Poseidon.ASNM.&OS=AN/Poseidon&RS=AN/Poseidon
If this is the method Poseidon plans to employ, it raises new and significant issues regarding marine life impacts that were not discussed in the FREIR. For example, the marine life mortality attributable to the water being diverted around the generator’s cooling system and mixed with the desalination facility’s “feed water” is above and beyond the mortality identified in the FREIR. To be clear, if Poseidon plans to employ their patented method for increasing plant efficiencies, the FREIR is fatally flawed and once again needs to be revised and re-circulated. We request the City fully explore this question and determine whether or not Poseidon intends to utilize the methods identified in their patented process either now or in the future.
Furthermore, should Poseidon plan to employ its patented method for feedwater intakes, the policies contained in the City’s LCP § C 6.1.19 are applicable to the increased seawater intake that would not be used for cooling water at HBGS.
3) Conclusion
In conclusion, we want to emphasize that the inadequacies identified in the REIR by numerous organizations and agencies, including California Coastal Commission staff, have precluded a thorough consideration of the policies contained in the City of Huntington Beach Local Coastal Program. Given the now apparent need for further evaluation of this project before approving a Coastal Development Permit (CDP), we strongly urge the City of Huntington Beach to revise and recirculate the Environmental Impact Report. Alternatively, should the City choose to review the application for a CDP given the available information, we strongly urge the denial of that permit based on policies identified in the comments above.
PUBLIC HEARING-Poseidon Desalination Plant CUP Posted Tuesday, January 3, 2006
On Monday, Jan. 9, 2006 at 6:00 p.m. in the City Council Chambers, 2000 Main Street, Huntington Beach,the City Council will hold a public hearing on the Conditional Use Permit (CUP) for the proposed Poseidon Resources Corporation Seawater Desalination Project.
ALL INTERESTED PERSONS are invited to attend this hearing and express opinions or submit evidence for or against this applicant.
Our H.B. Chapter has submitted both oral and written comments to the H.B. Planning Dept. and the City Council regarding the errors,
inaccuracies, omissions and deficiencies contained in both the EIR and the REIR technical documents submitted by the applicant in support of this project.Similar comments have also been submitted
to the City by the California Coastal Commission and several other concerned environmental organizations.
If you are a H.B. resident your attendance at this important hearing is sincerely appreciated.
MERRY XMAS & HAPPY NEW YEAR Posted Friday, December 23, 2005
"There are those of us
For whom
The waves
Are silent cliffs of water
Ment to cradle us.
To carry us away.
We Surf"
From:
PAPER SHREDDERS- An Anthology of Surf Writing.
Merry Xmas and Happy New Year to all.
Surfdad.
Poseidon Resources Lacks Credibility Posted Friday, December 23, 2005
TO:Huntington Beach City Council Members.
Poseidon Resources asserts that the source water for their proposed desalination plant is of "high quality" since it comes from the "open ocean" via the AES power plant intake.
Nothing could be further from the truth!
The cooling water for the AES power plant comes from Huntington State Beach, a 303d listed impared water body because of high levels of fecal indicator bacteria,(FIB's), and Polychlorinated biphenyls (PCB's). The beach ajacent to the power plant is ranked an "F" during wet weather by Heal the Bay, and the surfzone exhibits episodic occurrances of FIB's that are off-the-scale (>400 cfu/100ml.) with respect to enterococcus concentrations. Enterococcus is the indicator organism that is favored by the EPA for monitoring marine waters.
During the summer months the near shore frequently exhibits algeal blooms of microscopic organisms we call "red tide." These dynaflagelates excrete a toxic substance, deplete the ocean water of dissolved oxygen, and can cause fish kills. When conditions permit, they are believed to bloom in such great concentrations at the Santa Ana River mouth because of the high nutrient content (nitrates and phosphates) in the water from the Santa Ana River. The near-shore current flow from the Santa Ana River mouth is predominately up-coast, and the "red tide" is then transported throughout the water column to a zone directly in front of the AES power plant where it can be captured by the intake to the power plant and cause the RO filters in the proposed Poseidon desalination plant to clog and fail.
It was marine organisms that caused the filters to fail at the Poseidon designed Tampa Bay, Florida desalination plant.
The Huntington Beach City Council should be encouraged to get the facts straight before making a decision permitting the Poseidon desalination plant.
Don Schulz
Beach Water Quality Workgroup Priority List Posted Wednesday, December 7, 2005
Recommended Prop 13 Priority Projects from the November 29, 2000 BWQW Meeting
The Beach Water Quality Workgroup’s List of Priority Projects/Research Areas
1. Develop rapid and cheap indicators of bacterial contamination. Currently analytical tests for bacterial indicators take 24 to 36 hours, or longer, to complete. Because of the time it takes to run the analysis, the public is notified of the results of the test for beach contamination at a minimum of one day after the sample was collected. The public will be better protected if bacterial contamination can be detected in a rapid and cost efficient manner and it will greatly enhance our capability to track down sources of pathogens and to measure the effectiveness of management practices..
2a. Develop better source characterization methods. Once contamination is detected at the beach it is important to be able to characterize whether the source of the contamination is human or non-human. This improves our capability to narrow an investigation's focus on potential upstream sources. AB 538 requires the State to develop source-identification protocols. The protocols will be used once contamination is detected at the beach. We need to implement pilot projects to test the methodologies - to test their feasibility and to identify data gaps.
2b. Better characterize runoff sources. Studies are needed to determine the quality of water running off a variety of land uses. The information about the contribution of pathogens and their indicators from various land uses can be used to determine load allocations in TMDL development.
3. Conduct public health impacts/epidemiological studies. The Santa Monica Bay Restoration Project study looked at the health affects of one time exposure to swimming in ocean waters near a stormdrain. Additional study is needed to determine the affects of ocean water contact (swimming, surfing, etc.) during wet weather when contamination is more widespread. Also, we need to determine the health-effects of long-term exposure to contaminated water. This information is needed to validate present standards and identify priorities based on health effects.
4. Develop improved nearshore transport models. More detailed studies are needed to identify the mechanisms for transporting water-borne contamination along the shore. This model will help identify the areas where release of contaminated water would have potential to result in beach contamination given specific tidal, wind and wave conditions. These studies should include a component to elucidate the mechanism for transport of bacteria in addition to the water. This information is needed to identify requirements, both temporal and spatial, for monitoring and posting and assist in source identification.
5a. Develop and implement a template for shoreline microbiological monitoring. Currently, shoreline microbiological monitoring programs are neither consistent nor comprehensive. Monitoring decisions are made on a case-by-case basis without regard to equitability or public health protection. Regional Boards need guidelines on how to implement a comprehensive shoreline microbiological monitoring program. These guidelines will include how to gather better information about the degree of impairment of water quality identified by exceedance of bacterial indicators. This will help to develop a monitoring program that best protect the beneficial uses.
5b. Improve our understanding of the relationship between indicators and pathogens. Better information is needed about the relationship between the actual presence of pathogens and the indicators that are used to identify their presence. It is essential to know if current methods fail to indicate any major disease-causing pathogens.
5c. Develop list of urban runoff treatment options and their effectiveness. Urban runoff is one of the primary causes of beach postings. Treatment options of dry weather flows may be a cost effective alternative to diversions. Local agencies need good cost-benefit data to facilitate implementation of best control measures.
6. Reduce dry weather runoff. Dry weather flows transport pathogens to the beach. Overwatering of lawns and other non-stormwater discharges are major sources of dry weather flows. We need projects that identify and characterize sources of dry weather flows so that measures to reduce them are effective.
7a. Develop watershed management plans. In watersheds that experience chronic beach contamination, we need management plans to organize information on sources of pathogens and develop timelines for implementation of best management practices.
7b. Develop GIS characterization of watersheds and coastal areas. For each high priority watershed GIS layers of each of the attributes which influence water quality need to be identified and mapped. This will identify sources and loads essential in the development and implementation of TMDLs.
8a. Develop asset management plans for sewage collection systems. Sewage spills are a major cause of beach closures. Sewage collection systems are frequently ill-maintained and lack adequate contingency plans. An asset management plan provides for routine maintenance of pipe infrastructure and should include a risk based evaluation and inspection and maintenance schedule. The plan would also provide emergency measures when a spill occurs.
8b. Determine the relationship of marshes/wetlands to beach water quality. It is not known whether marshes and wetlands, when located upstream of beaches, improve or degrade the downstream beach water quality. Control measures based on natural systems (e.g., wetlands, marshes and lagoons) can provide comprehensive solutions to watershed problems, but may have unpredictable or undesirable effects on beach water quality. A better understanding of these natural systems' functions will improve our ability design effective management solutions.
8c. Develop performance standards for reducing grease blockage in collection systems. Sewage spills are the number one cause of beach closures; grease blockages are the number one cause of sewage spills. Grease blockages are preventable with proper planning, outreach and enforcement. All collection systems which have the potential for spills to reach the beach need to have grease blockage prevention plans developed and implemented.
9a. Divert dry weather flows from storm drains. Diverting dry weather flows in areas where such flows result in chronic postings will reduce contamination of the coastal waters and improve public health protection.
9b. Improve public access to beach water quality data. The public needs good information on the quality of water at beaches. The effort to make this information publicly available needs to be expanded.
10a. Develop trash removal techniques. Tons of trash litters our shorelines annually. Increased loading of pathogens are likely associated with trash in the water. Mechanisms to reduce the amount of trash getting to the beach need to be implemented.
10b. Determine the mechanisms of bacterial transport. There is an assumption that bacteria move through the water column as if they were in solution. This may not be the case. Bacteria could potentially be transported on particles or surface film in which case they would have different transport dynamics. Studies are needed to determine the extent to which bacteria attach to particles and, if so, to what size and type of particles. This information is needed to understand the routes of ingestion, identify appropriate sampling points and evaluate treatment technologies.
Don Schulz
member BWQW
GWRS Wins Award Posted Wednesday, December 7, 2005
Groundwater replenishment system WINS 2005 Governor’s Environmental and Economic leadership award
News Release, Orange County Water District – 11/23/05
Contact, Rebecca Long – (714) 378-3362
FOUNTAIN VALLEY, Calif. — The Groundwater Replenishment (GWR) System, the largest water purification project of its kind and joint project of Orange County Water District (OCWD) and Orange County Sanitation District (OCSD), received the 2005 Governor’s Environmental and Economic Leadership Award in the category of Ecosystem and Watershed Management.
The award was presented to Denis Bilodeau, OCWD board member, Jose Solorio, OCWD board member, Virginia Grebbien, OCWD general manager, Michael Duvall, OCSD board member, James Ferryman, OCSD board member, Carolyn Cavecche, OCSD board member and Robert Ghirelli, acting OCSD general manager, at a formal recognition ceremony held at the California Environmental Protection Agency Headquarters in Sacramento on November 22.
The award is the state of California’s highest environmental honor and the Ecosystem and Watershed Stewardship category recognizes innovative and sustainable approaches to land and water management that restore or protect natural conditions, functions and processes and provide economic, social and environmental benefits.
A committee selected the GWR System as the most deserving from a competitive pool of applications received from residents, businesses, non-profit organizations, professional and trade associations, communities, state and local governmental agencies and federal agencies operating in California.
“To be singled out as a leader in watershed management in California, a state known for its innovative watershed conservation initiatives, validates the efforts of everyone involved in planning and building the GWR System,” said Phil Anthony, board president for OCWD. “While the GWR System will be a much needed new source of water for Orange County, we’re extremely proud of the GWR System’s additional environmental and economic benefits.”
The GWR System takes highly treated sewer water that is currently released into the ocean and purifies it using the same technologies that purify baby food, fruit juices, medicines and bottled water. The GWR System will create a new supply of very clean water, totaling 70 million gallons per day.
The new water will be used to expand the already existing seawater intrusion barrier along the coast and to augment groundwater supplies for north and central Orange County. The GWR System will also help reduce the demand on the San Francisco-San Joaquin Delta Watershed, and reduce the amount of treated wastewater released to the ocean locally.
“Receiving the Governor’s award is further proof that projects like the GWR System are the future of water purification technology,” said Steve Anderson, board chair for OCSD. “Almost since its inception 12 years ago, the project has served as a beacon for thoughtful and responsible public agency cooperation and resource management. The project has attracted visitors from arid regions all over the world.”
More information on the Groundwater Replenishment System is available at www.gwrsystem.com.
Orange County Water District (OCWD) manages the large groundwater basin that underlies North-Central Orange County that provides most of the water for 2.3 million citizens. OCWD is committed to constantly improving Orange County’s groundwater quality and reliability in an environmentally friendly manner. With years of prudent planning and careful investment, OCWD has doubled the yield of the groundwater basin. Recently, the basin, larger than the largest reservoir in Southern California, sustained the County through a five-year drought. OCWD has also spent millions of dollar on studies by outside experts to ensure the quality of our groundwater. We want to be your trusted source for water quality. We will continue to plan and invest in ways to get more water into and out of the basin. OCWD is a special district, separate from the County of Orange, that supplies to residents in the cities of Anaheim, Buena Park, Cypress, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, Irvine, La Palma, Los Alamitos, Newport Beach, Orange, Placentia, Santa Ana, Seal Beach, Stanton, Tustin, Villa Park, Westminster and Yorba Linda.
The Orange County Sanitation District is responsible for safely collecting, treating, and disposing wastewater. It is a special district, separate from the County of Orange or any city government, established under the State Health and Safety Code, to provide sewerage service to a specific geographic area. The Orange County Sanitation District is governed by a 25-member board of directors comprised of representatives of each local sewering agency or cities within our 470-square-mile service area. For more information, visit the Web site at www.ocsd.com. #
SWRCB 316(b) Workshop. Posted Friday, November 25, 2005
Surfrider Foundation National Staff Members Submit 316(b) Comments to SWRCB Workshop.
As you may know, Section 316(b) of the Clean Water Act requires that the location, design, construction and capacity of cooling water intake structures must reflect the best available technology for reducing and minimizing any adverse environmental impact. In California, the withdrawal of up to17 billion gallons per day of ocean cooling seawater is used to cool the “once-through” power generating stations located on our coast. This outdated technology results in a significant loss of marine life and aquatic organisms due to impingement (marine life that is killed on the intake screens) and entrainment (smaller organisms that are killed in the cooling condensers). There are alternative technologies used by inland generators that recycle the cooling water-avoiding the unnecessary destruction of marine life. Surfrider Foundation is a co-plaintiff in federal litigation to strengthen current regulations on cooling water intakes to reflect that superior technology.
Recent re-powering proposals at five coastal power plants, including the AES owned Huntington Beach Generating Station (HBGS), included modern combustion turbines that meet current air emission standards, but did not propose changes to once-through cooling water systems that would substantially reduce impacts to aquatic organisms.
Recent recommended US EPA regulations may require that these systems to be substantially modified or replaced in order to reduce their effects on marine ecosystems. Additionally, in several recent reviews of proposed upgrades to power plants, the California Coastal Commission has determined that continued use of once-through
cooling systems does not conform to Coastal Act policies.
At the State Water Resources Control Board (SWRCB) workshop in Laguna Beach on Sept. 26, comments to the SWRCB staff were made by Surfrider Foundation staff members Rick Wilson and Joe Geever supporting the Coastal Commission, and argued that in California the SWRCB should reflect our heightened interest in protecting our coast and ocean by implementing regulations that are at least as stringent as those recommended by the EPA, and enforcing them. They were joined in similar comments made by Santa Monica Baykeeper, Heal the Bay, California Coastal Commission, Stanford Environmental Law Clinic, and others.
It is uncertain how HBGS intends to comply with the recently promulgated Clean Water Act 316(b) regulations for cooling water intakes on existing power plants drawing more than 50mgd (“Phase II regulations”). These new regulations on cooling water intake structures require dramatic reductions in marine life impingement (80-95%) and entrainment (60-90%). For this reason and others, the Huntington Beach/Seal Beach Chapter of Surfrider Foundation is currently opposed to the use of existing “once-through cooling” for a co-located desalination facility at HBGS until these uncertainties are resolved.
Don Schulz
GRS Plant Tour Posted Thursday, November 24, 2005
The public will have an opportunity to see the efforts being made by OCWD and OCSD to recycle precious water. Recycling this water is much cheaper and better for our environment than the proposed desalination plant that some HB council persons seem intent upon approving. The water will be sent inland so that it can replenish ground water supplies.
FOR IMMEDIATE RELEASE NOVEMBER 21, 2005
MEDIA QUESTIONS, CONTACT:
Rebecca Long, OCWD, (714) 378-3362
ORANGE COUNTY RESIDENTS INVITED TO TOUR
CONSTRUCTION SITE FOR NEW WATER PURIFICATION PLANT
Tour Scheduled for Saturday, December 3 from 9 to 10:30 a.m.
What: The Groundwater Replenishment System (GWR System) is a new water project for Orange County that will help meet future water demands. As part of an ongoing effort to provide Orange County residents with information about the GWR System and the construction of the water new purification facility on Ellis Avenue, officials from Orange County Water District will host a tour of the construction site and the existing water purification plant.
The tours are conducted by Mike Markus, OCWD assistant general manager and project manager for the GWR System. The tours are free and open to all interested residents.
When: Saturday, December 3 from 9-10:30 a.m.
Where: 10500 Ellis Avenue Fountain Valley. Meet in the administration parking lot – off of Ellis Avenue – near the corner of Ellis and Ward. Refreshments will be served and walking shoes with closed toes are recommended. The tour is appropriate for people 13 years or older, but everyone is welcome.
Why: The tour provides residents with an opportunity to learn about the project and its technology while touring the construction site and the Phase I facility that is currently utilizing the same purification processes as the GWR System, but on a smaller scale.
Contact: Kira Erquiaga, community liaison, at (949) 216-9038
www.gwrsystem.com
A joint effort of the Orange County Water District and the Orange County Sanitation District (714) 378-3200 • Fax (714) 378-3381 • 10500 Ellis Avenue • Fountain Valley • California 92708
WATER QUALITY 101 Posted Friday, October 28, 2005
WATER QUALITY 101
An introductory adult education class on the basics of recreational
water science, including laboratory test methods and water quality regulations, used to determine water quality of ocean and bay waters. OPEN TO THE PUBLIC.
TOPICS INCLUDE:
* What diseases can I get from swimming in water?
* What are indicator bacteria?
* How often are my beaches tested?
* How clean are the beaches in Orange County?
Tuesday, November 1, 2005 7:00pm to 8:30pm
Muth Interpretive Center
2301 University Drive
Newport Beach, CA 92660
For directions, please visit: www.newportbay.org/maptoic.htm
To reserve a spot, RSVP by e-mail to Ray Mahallati at:
rmahallati_labhca@sbcglobal.net
Urban Runoff Diversions Work. Posted Tuesday, September 13, 2005
Blake Anderson, General Manager of Orange County Sanitation District reports:
Urban Runoff Diversions are Working!"Bacteria levels at Huntington State Beach have significantly declined since the inception of the District’s urban runoff diversion program in 2000. That is the conclusion of a review of beach water quality data collected since 1997 conducted by a team of Sanitation District scientists including George Robertson, Hai Nguyenand Charles McGee. By evaluating data collected before and after the diversions were put in place in 2000, they were able to demonstrate an improvement since the district began accepting urban runoff from the Talbert Marsh and Santa Ana River drainage areas. The results support the findings of the Orange County Health Care Agency’s annual water quality report which indicates a reduction in the number of beach closures and postings each year since 2000."
A Sanitation District Fact Sheetdescribing the urban runoff program and these recent results can be found on the OCSD website at:www.ocsd.com
Paddle-Out for Clean Water. Sept.11. H.B. Pier 8am Posted Monday, August 29, 2005
WHAT: A “Paddle Out” is a public rally where citizens concerned about the state of our coasts and ocean gather on a specific beach to make public presentations and take action. Some of those attending will paddle surfboards, kayaks, etc, into the nearby water to form a “circle of solidarity” in a showing of commitment to turn around the trend of degradation. But, the event is not only for those willing and able to paddle – it is open to everyone who shares our concerns for the coast and ocean.
WHY
The 2005 national Paddle for Clean Water is a media event that will bring national public attention to 2 major reports on the state of our coasts and ocean (Pew Ocean Commission (2003) and US Commission on Ocean Policy (2004)), and the recommendations they make on how to restore and protect our coasts and ocean.
Both reports agree that pollution, over-fishing, increased coastal development, altered sediment flow and dramatic declines in water quality have significantly impacted the health and safety of our oceans, waves and beaches. Yet, well over a year later, and nothing has been done.
Help Surfrider Foundation spread the word about the important findings of these 2 "blue ribbon panel" reports and educate the public on what those findings mean to you and your community.
for more info:
www.surfrider.org./paddle
Celebraty Surf-Jam. H.B. Pier Sept.11 Posted Monday, August 29, 2005
Celebrities and Champion Surfers Will Share the Spotlight at the Surfrider Foundation Celebrity Surf Jam, Sept. 11
09/11/2005
The Surfrider Foundation and Propaganda Headquarters are proud to announce the roster of well-known musicians and professional athletes set to participate in the first ever Surfrider Foundation Celebrity Surf Jam. The event will take place at Orange County's famed Huntington Beach Pier on Sunday, September 11th, 2005 from 8 AM to 2:00 PM. High profile musicians taking part in the event include Brandon Boyd, Mike Einziger and Ben Kenney of Incubus, Peter DiStefano (Porno for Pyros) and Jim Lindberg (Pennywise). Four-time Olympic medal winning swimmer Aaron Peirsol will also be competing in the event. The event is being chaired by X-Games and ABC Sports commentator Sal Masekela. Professional surfers include event Co-chair and co-star of the Endless Summer II, Pat O‚Connell, Rob Machado, Jeff Deffenbaugh (Former WCT competitor and local surfer who is also helping to co-produce the event), and rising professional surfers Alex Grey and Dane Reynolds. "We have been surfing our whole lives, so protecting the oceans and beaches is especially important to us," says Incubus' Brandon Boyd. "It is our honor and privilege to participate in such a worthy cause." Read Surfrider Foundation's entire press release. See Surfrider's special Celebrity Surf Jam web section.
www.surfrider.org/surfjam
STATE OF THE BEACH REPORT RELEASED. Posted Friday, July 29, 2005
Surfrider's STATE OF THE BEACH Report Released July 28th!
07/28/2005
What state is your beach in? Find out the answer to that and many other questions in Surfrider Foundation's 2005 State of the Beach report that was released on July 28th. The State of the Beach Report web site is fueled by a database of over 600 pages of great coastal information. The State of the Beach report is a deep coastal resource that's great for anyone with more than a passing interest in our coastal environment. Especially useful for Coastal Zone Managers, too. Read Surfrider's press release and also see the 2005 State of the Beach Report web site at:
http://www.surfrider.org/stateofthebeach.
Also recently released are beach water quality reports from Natural
Resources Defense Council(NRDC) "TESTING THE WATERS" available at:
http://www.nrdc.org/media/PressReleases/testing the waters.
And the Heal the Bay 2005 Beach Report Card can be viewed at:
http://www.healthebay.org/Beach Report Card.
The Orange County Health Care Agency 2004 Annual Ocean and Bay Water
Quality Report is available at:
http://www.ocbeachinfo.com/2004 annual ocean and bay water quality report.
Surfdad.
Orange County Resource Conservation Conference Posted Tuesday, July 26, 2005
Subject: Register Now for the Resource Conservation Conference in Orange County
Registration is Now Open!
Date: Friday, September 16, 2005
Time: 9:30 am 4:30 pm
Registration Fee: $55
The Local Government Commission, the Institute for Local Self Government, the local non-profit Friends of Harbors Beaches and Parks and its Orange County Green Vision Project are pleased to announce that registration is now open for the conference, “Resource Conservation: Successful Strategies and Funding Opportunities for Creating Healthy Communities” on Friday, September 16, 2005, at the Hyatt Regency Huntington Beach. The event will focus on strategies to conserve land in Orange County for people to enjoy as parks, recreation areas, natural places and sources of clean water ensuring livable sustainable communities for generations.
This day-long event will include dynamic keynote presentations, interactive breakout discussion sessions on some of the most critical open space issues Orange County is facing, and the opportunity to network with your peers as well as practitioners from many different disciplines who all have the same goal creating healthier communities throughout Orange County. See the attached agenda or visit http://www2.lgc.org/events/ for more detailed information.
For more information about the program and to register, visit http://www2.lgc.org/events, fill-out the attached flyer, or contact:
Tony Leonard Flossie Horgan
916-448-1198, ext. 315 714-536-7262
aleonard@lgc.org horganf@aol.com
This conference is being jointly presented by the Local Government Commission, the Institute for Local Self Government, the local non-profit Friends of Harbors Beaches and Parks and its Orange County Green Vision Project.
Topics covered during the event include:
· Health and the Environment
· Open Space and Water Quality
· Successful Funding Strategies
· Orange County’s Fair Share
· What Makes a Healthy Community?
· The Benefits of Open Space
· State Bond Opportunities
POSEIDON DESALINATION DRAFT EIR COMMENTS. Posted Sunday, June 26, 2005
Attached are comments to the EIR from a group including the Surfrider Foundation, California Earthcorps, Sierra Club, Southern California Watershed Coalition, The Ocean Conservancy, California Coastal Protection Network, Save Our Shores, etc.
"It is important to point out that the undersigned groups are not opposed to desalination as a source of potable water."....
"Nonetheless, in the absence of any detailed statewide or regional policy on the implementation of desalination facilities, we believe proposals like the Poseidon- Huntington facility are premature and currently unnecessary"...
"- Similarly, since the initial review of this project, the United States Environmental Protection Agency has promulgated regulations for the use of "cooling water intake structures" at large facilities like the Huntington Beach Generating Station (HBGS). These regulations mandate a dramatic reduction in the current mortality of marine life from "impingement" and/or "entrainment." It is unclear at the current time how the HBGS intends to comply with these new regulations. But, reliance on the current cooling water intake for desalination source water is, again, premature and unsound public policy."...
"It is in the best interest of ratepayers and the environment to make sure that the answers to these outstanding issues are resolved before approval of such a permanent and massive facility as the Poseidon-Huntington proposal."...
"Finally, and possibly most importantly, as detailed below, the draft REIR still fails to allow a fully informed consideration of the proposal by the public and their elected representatives. The REIR, in several areas, is inadequate. In the most extreme cases, the REIR may also be misleading the public and our representatives."
Comments relative to the AES Plant (HBGS = Huntington Beach Generating Station):
"2) Definition of Entrainment/Impingement "Significance" is Misleading and Scope of Impacts Too Narrow
Once again, given that this is the first CEQA review of a desalination facility of this configuration and size, the REIR is effectively setting a new CEQA "standard of review." With this in mind, the assumptions employed, as well as the scope and standards used, deserve heightened scrutiny.
The REIR relies on misleading standards for determining "significance" of impacts to marine life. Furthermore, the REIR narrowly defines the scope of potential impacts from the co-location of a massive desalination facility with the existing Huntington Beach Generating Station (HBGS).
Defining "Significant"
The REIR, in Section 5.10, page 41, concludes that, "Impacts due to operation of the proposed desalination facility in regards to impingement and entrainment are not anticipated to be significant." This conclusion is based in part on reliance on the harvest control rule adopted in the Nearshore Fishery Management Plan - the so-called "40-10 rule." Id. This harvest control rule is applied to fisheries where the necessary data is available. For many species, this data is not available and harvest controls must resort to "proxies."
Additionally, the REIR does not document historical impingement/entrainment of species of major concern, nor does it compare these rates with dwindling populations. For example, populations of Sheephead, Vermillion Rockfish, Boccacio Rockfish, Cowcod Rockfish have declined from habitat losses, overfishing and other pressures over the past several decades that may lead to dramatic reductions in the number of individuals recorded in impingment/entrainment studies. Nonetheless, these population declines only underscore the importance of reducing marine life mortality from cooling water intake structures. Furthermore, numerous species likely entrained at the facility, such as Tidewater Goby and Garibaldi, are not regulated for sustainable harvests - several having total prohibitions on any "take." Therefore, the use of fishery management plans and harvest control rules as an indicator of "significant impacts" on marine life in the REIR oversimplifies the complicated process of determining "total allowable catch" and misleads the reader.
Nonetheless, assuming the best case scenario (i.e., that the species' populations, survival strategies, and life cycles are fully understood), the rule would not necessarily allow the "taking" of up to 60% of the existing populations - as implied in the REIR. In fact, the harvest control rule relies on estimates of "unfished biomass" - not current populations. If the current populations are below 40% of the estimated unfished biomass, "rebuilding plans" are implemented on a curve between 40% and 10% of those populations. Consider a species where the necessary data is available to employ the "40-10" rule, and current populations are below 10% of the estimated unfished biomass - the "40-10" rule may prohibit the take of these species altogether. There are species within the Southern California Bight where this is the case (e.g., "Cow Cod" rockfish) and others that have dramatically reduced harvest allowances because the current populations are estimated below the 40% target (e.g., "Sheephead"). Therefore, any "take" of these species and others under similar controls would be "significant" under the definition relied on in the REIR.
In short, the REIR's use of the "40-10 rule" for defining "significant" -- and the inexplicable application of the rule to the species killed by the HBGS -- and the additional mortality attributable to the proposed co-located desalination facility -- is misleading. Without fully identifying the populations of consideration, and the applicability of the harvest control rule, the REIR falsely concludes that:
The maximum "harvest" effect of HBGS operations at 127 MGD is 0.33 percent, significantly below the accepted (DFG) thresholds of 60%. The maximum harvest effect of the proposed project is 0.02 percent, an order of magnitude less than 0.33 percent, based on HBGS entrainment mortality of 94.1 percent.
This not only directs the public into falsely relying on a misleading definition of "significant impact", it raises serious questions about the adequacy of the impingement/entrainment study itself. For example, the baseline of 127 MGD is a minimum withdrawal rate and does not accurately reflect current average cooling water intakes, nor projected increases in cooling water intake volume after the addition of the desalination facility.
Furthermore, the REIR should identify species killed in the process that do not have harvest controls and "take" is prohibited. For instance, there is no allowable fishery for Garibaldi or Black Sea Bass. "Take" of these species is prohibited altogether and any impact on these species would be "significant."
Therefore, the REIR should not be certified until it includes a thorough and defensible definition of "significant impact" on all species collected in historical and current impingement/entrainment studies. The REIR should also thoroughly explain the current population assessments for the species recorded in these studies and reconcile why some with already diminished populations may be recorded in relatively low numbers. Finally, the REIR should identify species killed in the intake that are protected under the Endangered Species Act, fishery management plan "take" reductions and prohibitions, and other regulatory and legislative protections.
Scope of Impacts
As noted in previous comments, the addition of a desalination facility of this size will create a dramatic new demand on the HBGS. In a misleading conclusion, the REIR states that: "The operation of the desalination facility would not result in any changes to the permitted operations or in the maximum HBGS intake flow rate…." This reliance on "permitted flow rates" versus actual historical cooling water intakes sets a misleading baseline from which to compare projected impingement/entrainment impacts.
The REIR is confusing in that in one instance, at Section 3, page 28, the REIR states that: "The desalination facility would not include a back-up generator. Emergency power would come from the electric power grid and/or HBGS auxiliary reserve bank." This statement implies that the energy necessary to run the desalination facility under normal operating circumstances (i.e., not during "emergencies") would come directly from the HBGS. Consequently, the baseline and average operations of the generators will surely increase to supply the necessary energy to run the desalination plant. It is important to repeat here that the baseline for calculating marine life mortality is not the "permitted" withdrawal of 514 MGD, but the actual historical withdrawal of cooling water.
According to the REIR, the desalination facility will "require approximately 30 to 35 megawatts…. As such, the daily energy consumption of the facility is estimated to be 720 to 840 megawatt hours per day." See: REIR § 5.4, page 13. The current average daily out put of the HBGS is not presented in the REIR. However, if the average daily cooling water intake flow rates are any indication, HBGS, between 2002 and July 2003, was only operating generators 1 and 2 on average. See: REIR § 4, page 7 (average flow rate equaled 265 MGD, with low flow rates at 127 MGD). If so, on average, the HBGS is generating approximately 430 MW. See: REIR § 4, page 3. Given these extrapolations, the addition of the energy demand from the desalination facility will increase average operating output of the Huntington AES from 430 MW to 465 MW - an increase of approximately 8%. Nowhere in the REIR is there an analysis of how much additional water will be withdrawn from the ocean to meet this increase in daily electrical output at HBGS.
Assuming the energy demand for the desalination facility will be supplied by HBGS under normal circumstances; the REIR fails to identify the resulting increases in on-site cooling water intakes and associated marine life mortality to supply the energy.
Alternatively, the REIR may conclude that the energy demand for the desalination facility will be met under normal operating conditions by power from the electrical grid. In this case, some estimate of what percentage of power on the grid comes from facilities using "once through cooling" would help decision makers better understand regional impacts. In short, without some clarity of how the facility will meet the energy demands of the massive desalination facility, it is impossible to adequately assess the associated marine life mortality.
Therefore, the REIR fails to adequately inform the public of the impacts of the project on marine life mortality until it is clear how the energy demand will be met. One potential solution would be an unequivocal and irreversible commitment to the source of energy - either the HBGS or the grid. This is not an unreasonable condition given the importance of this factual background for fully documenting foreseeable impacts to marine life.
3) New Regulations for Cooling Water Intakes Not Analyzed
The REIR fails to include all the relevant information currently available on marine life impacts, including the recently promulgated rules on cooling water intake structures [i.e., Clean Water Act 316(b)] and a recently completed impingement and entrainment study for HBGS.
It is uncertain how HBGS intends to comply with the recently promulgated Clean Water Act 316(b) regulations for cooling water intakes on existing power plants drawing more than 50mgd ("Phase II regulations"). These new regulations on cooling water intake structures require dramatic reductions in marine life impingement (80-95%) and entrainment (60-90%).
Relevant issues raised by the promulgation of these new rules include:
- the land used for the footprint of the desalination facility would preclude the option of adopting closed-cycle cooling for HBGS by disallowing use of the same land for cooling towers;
- reducing cooling water flows for HBGS, or installation of alternative technologies, may offer alternatives to meet the performance standards in the new regulations. However, such mandated changes may render the desalination facility economically or practically inoperable without continued use of the ocean water intake structure.
Licensing of the Desalination Plant At This Time Would Foreclose HBGS From Using EPA's Preferred Technology
The Phase II regulations specify closed-cycle cooling as the best technology available for minimizing adverse environmental impact. While the rule allows compliance in other ways that meet closed-cycle performance standards, the EPA expresses the preference for closed-cycle cooling. In fact, for new power plants, closed-cycle cooling is essentially required. However, closed-cycle cooling demands available land for construction of cooling towers. Therefore, licensing of the desalination plant would likely foreclose the use of closed-cycle cooling due to the available space taken up by the desalination plant. Furthermore, the desalination facility's reliance on HBGS's once-through cooling water will effectively preclude the transition to closed cycle cooling, or force the continued use of the intake structure for desalination "source water" -- undermining the intent of the new regulations.
By precluding HBGS from employing closed-cycle cooling, or prolonging the use of the ocean water intake structure for other purposes, the desalination facility is effectively undermining the intent of the new 316(b) regulations. This foreseeable impact should be thoroughly documented in the REIR.
If the Desalination Plant Attempts to Comply with the 316b regulations by means other than EPA's preferred technology, the viability of the desalination plant is suspect.
The Phase II regulations provide compliance alternatives other than the use of closed-cycle cooling. For instance, the plant can reduce cooling flows through reduced operations, install new technology, or perform a combination of these to comply with the performance standards. However, each of these alternatives has consequences on either the total water available to the desalination plant or the electricity available to consumers, the desalination plant, or both.
One potential HBGS compliance response would be to reduce the volume of intake water from the historical baseline. Assuming this response, the REIR is incomplete until it provides an analysis of how the desalination facility would make up for the reduction in cooling water at HBGS. More importantly, the REIR should document the marine life mortality associated with this response.
Future 316b Regulations May Eliminate the Viability of The Desalination Plant Altogether.
The REIR indicates that, should the HBGS discontinue the use of the "once through cooling" system, Poseidon would take over operations of the cooling water intake structure to supply water to the desalination facility. In this scenario, all of the marine life mortality from the 100 MGD-plus withdrawal would be directly attributable to the desalination facility. The draft phase III regulations, which would likely apply to the desalination plant, would likely require the same reductions in impingement and entrainment from uncontrolled levels as the HBGS plant must meet. The REIR does not indicate how the desalination plant might meet these requirements should it need to draw water directly from the ocean.
Missing Relevant Information
It is our understanding that the California Energy Commission has recently released a comprehensive study of the marine life mortality rates at the HBGS. This "316(b) study" is currently available for public review, but has not been included in this REIR. It is also our understanding that there are significant differences in the scope of the analysis and the relevant information contained in that study as compared to the study provided in the REIR. This is pertinent and significant information for the public and our elected representatives to make fully informed decisions. Absence of this information renders the REIR inadequate.
Furthermore, the REIR does not summarize nor append copies of the recently adopted Clean Water Act 316(b) regulations controlling the use of "cooling water intake structures" for existing facilities, including the HBGS. Again, this is essential information for fully informing the public of the scope of impacts related to this project proposal.
Conclusion
In summary, the Phase II regulations were the focus of a great deal of discussion during public comment on the original DEIR, and should be treated as "significant new information" in this REIR. Before the HBGS demonstrates how it will comply with the Phase II regulations, it is premature for the City of Huntington Beach to license the desalination plant. Furthermore, relevant documentation of current impingement/entrainment is now available from the California Energy Commission, and that information is critical to a thorough understanding of the operations of HBGS as is, as well as predicted impacts from the co-location of a massive desalination facility. Again, the absence of this pertinent and significant information precludes a fully informed decision and renders the REIR inadequate."
CHAPTER COMMENTS TO THE HUNTINGTON BEACH DESALINATION PLANT Posted Monday, June 6, 2005
Our Chapter has submitted comments to both the Huntington Beach Planning Committee and the City Council regarding the errors, omissions and deficiencies in the above referenced document and has recommended that the dREIR not be certified. Click here to see the comments.
Surfrider Foundation
Huntington Beach/Seal Beach Chapter
To: City of Huntington Beach Planning Department May 27, 2005
2000 Main Street, Huntington Beach California 92684
Attn: Ricky Ramos
From: Surfrider Foundation, Huntington Beach/Seal Beach Chapter.
P.O. Box 3087, Long Beach, CA 90803
Don Schulz PE Blue Water Task Force
Re: Draft Recirculated Environmental Impact Report (EIR) No. 00-02 for the Seawater
Desalination Project at Huntington Beach-Comments.
Dear Mr. Ramos;
Our Huntington Beach/Seal Beach Chapter of Surfrider Foundation appreciates the opportunity to provide the following comments to the above referenced Draft Recirculated Environmental Impact Report (dREIR). As you are aware, comments from our chapter were submitted to the originally circulated Draft EIR which continues to remain unresolved.
After review of the contents to the new dREIR, there appears to be several additional issues of concern to our membership. The comments to those specific dREIR contents which are either (or both) misleading and incorrect, or not supported by the facts, are summarized in the accompanying attachments to this letter.
It is recommended that unless, (or until) these dREIR issues are resolved, certification to the above referenced document be denied.
Your attention to these dREIR comments is sincerely appreciated.
Don Schulz
Executive Committee Member
Surfrider Foundation, Huntington Beach/Seal Beach Chapter
P.O. Box 3087, Long Beach, CA 90803
Sanitary Sewage Overflows (SSO's) Posted Friday, June 3, 2005
SANITARY SEWAGE OVERFLOW-IS AN OXYMORON!
There is nothing "sanitary" about a sewage overflow.
EPA will scuttle proposal to mix sewage in rains
After receiving nearly 100,000 comments from the public, the Environmental Protection Agency announced on Thursday that officials had abandoned a proposal that would have allowed sewer operators to dump rainwater mixed with sewage during heavy storms.
The EPA's proposal was opposed by local water-quality advocates in the Surfrider Foundation and Defend the Bay. Bob Caustin, founder of the latter organization, greeted the EPA's decision as good news.
"No one wants to have that in the water supply," he said.
Santa Ana Regional Water Quality Board spokesman Kurt Berchtold said the board was not worried about the EPA's proposal. Since mixed sewage would have been diluted with rainwater, the board did not expect impurities to exceed permitted levels.
"We didn't really see much impact one way or another," Berchtold said.
In 2003, the EPA proposed rules that would have allowed sewer operators to mix rainwater with untreated sewage during storms.
The idea behind the proposal was to address sewer operators' concerns that heavy flows would be harmful to facilities that use microorganisms to treat wastewater.
In order to safeguard those facilities, the EPA would have allowed sewage that had not been treated with microbes to be mixed with storm flows before being discharged.
In a statement, the EPA indicated that it would consider other methods to solve the microorganism problem.
The agency's assistant administrator for its Office of Water, Benjamin Grumbles, said blending water was not a long-term fix that would meet the EPA's desires to cut down on overflows and enhance treatment.
The use of microorganisms to treat sewage after wastewater is filtered is called secondary treatment.
In 2002, the Orange County Sanitation District voted to add secondary treatment facilities.
In March, sanitary district technical director Robert Ghirelli said the cost to add the new facilities was $450 million.
At the time, he said it would cost more to expand facilities to handle massive storm flows without blending.
Caustin said he would prefer that environmental agencies fund expansions rather than limit protective measures.
"It's the cost of doing business," he said. "It's the cost of protecting public health and the environment."*
EPA RETAINS SSO POLICY Posted Monday, May 23, 2005
EPA Keeps Policy on Sewage Plants
In a reversal, agency says it won't allow facilities to skip a crucial but costly step in treating wastewater after heavy rains and snow melts.
From Associated Press
May 20, 2005
WASHINGTON The Environmental Protection Agency said Thursday that it would not allow sewage treatment plants to skip a process for killing some disease-causing micro-organisms after heavy rains or snow melts. The decision reverses a plan proposed in November 2003.
Hours after EPA's announcement, the House approved a measure to block the agency's 2003 proposal from taking effect. The measure had been offered by lawmakers before EPA's about-face.
If the EPA had adopted the policy, U.S. sewage plants might have avoided an estimated $90 billion or more in facility upgrades to allow for oxidation of pollutants in wastes after heavy rains. That lets microbes feed on organic materials, removing viruses and parasites.
The agency normally requires sewage to be treated using a three-step process. But during peak flows from storms, it routinely lets plants discharge a blend of fully and partly treated sewage. The agency had proposed letting that become the official policy for handling the huge volume of wastewater that storms bring, but changed its mind after reviewing 98,000 public comments and the testimony at some congressional hearings.
"Blending is not a long-term solution," said Benjamin H. Grumbles, assistant administrator of the agency's Office of Water. "Our goal is to reduce overflows and increase treatment of wastewater to protect human health and the environment."
Agency officials haven't decided what their National Pollutant Discharge Elimination System requirements should be for municipal wastewater treatment during wet weather. They said they were looking at "the most feasible approaches to treat wastewater and protect communities, upstream and downstream."
Tiernan Sittenfeld, legislative director for the League of Conservation Voters, which supported the House measure, said EPA's reversal was "a victory for health" and would help ensure cleaner lakes, rivers and streams.
Aging sewer systems are designed to overflow from rain, each year discharging more than a trillion gallons of untreated sewage into waterways, raising the chance of waterborne disease outbreaks.
Researchers at Johns Hopkins University say that more than half of the waterborne disease outbreaks in the United States in the last 50 years followed a period of extreme rainfall.
BLUE PLANET Final Report Posted Wednesday, May 18, 2005
BLUE PLANET Final Report is available here:
http://www.surfrider.org/huntington/pages/BLUE_PLANET_Final_Report.zip
Download the report and un-zip. These are word and excel files.
NGO's Rank Coastal Commissioners Voting Record. Posted Monday, May 16, 2005
CALIFORNIA COASTAL COMMISSION VOTING ANALYSIS SHEDS LIGHT ON COASTAL DEVELOPMENT DECISIONS
The 2003 & 2004 California Coastal Commission Conservation Voting Charts Rank Commissioner’s Performance on Protection of Coastal Resources and Public Beach Access
San Francisco, CA (April 12, 2005)– The Conservation Voting Chart that provides key insight into the performance of the California Coastal Commission (the Commission) was released by a coalition of environmental organizations this week. Sierra Club Coastal Program, the Surfrider Founda
