Poseidon and AES Legal Vulnerabilities
Draft: At the July 10th Coastal Commission meeting a Joint Policy for the Water Board and Coastal Commission was presented. Essentially, the policy requires Sub-Surface intakes to Desal Processing facilities. The basis for this Policy is clear cut.
What remains to be presented is a broad technical and economic justification that can survive the expected Poseidon lobbying pressure.
Staff has provided an extensive slide presentation illustrating alternative types of ocean water intakes. What remains to be done is to frame then illustrate the engineering issues and provide a clear segue into cost benefit analysis appropriate for policy makers.
Proposed State Board Desal Policy
- Intakes: Require subsurface, unless infeasible; then allow screened open water intakes.
- Discharges: Allow only minor salinity increases, unless site-specific tests show no marine life effects.
- Mitigation: Any of three options –
- •Project- and site-specific mitigation.
- •Funding for existing or proposed mitigation sites.
- •In-lieu fee.
Poseidon Huntington Beach Desalination Plant: The intakes for the Poseidon desal plant is co-located with the AES Power Plant. It is proposed for standalone operation 24 hours a day for up to 60 years after the AES Power Plant ends OTC in 2020. Poseidon is trying to gain CCC approval before the SWRCB releases its draft Ocean Plan Amendment and before the Ocean Plan Amendment is finalized. Approval of the HB desalination plant as proposed (use of existing AES intake, refusal to evaluate sub-sea floor intakes or screens, or incorporate brine diffusers) will set a negative statewide precedent for future ocean desalination plants.
– MPA/Entrainment and Impingement Expert: Preliminary calculations by CCC staff indicate that the source water for the desal plant will mirror the AES plant and could extend from 8 to 50 miles, encompassing at least two MPAs. CCPN and NRDC have requested that the CCC require Poseidon to do an analysis of the potential impacts of the project on MPAs. This would set a new standard for the CCC when reviewing industrial uses of the ocean that impact marine resources.
– Sea Level Rise Planner/Engineer Expert: According to the CCC staff, maps indicate that the desal plant will be an island by 2050. Approval as sited is in direct contradiction to the soon to be released CCC sea level rise guidance and sets a negative statewide precedent for the siting of new industrial infrastructure on the coast.
– Water Supply Planner expertise: The Urban Water Plan for this area does not require ocean desalination and indicates that there will be sufficient water through 2035. An expert (in addition to the CCC) who can testify to the contents of the Urban Water Plan and debunk the myth of ‘reliability’ given the hazards at the site (seismic, sea level rise, tsunami run-up) would be helpful.
– Water Planner/Engineer knowledge: MET and MODOC are currently working on a system integration analysis that includes a lengthy, multi-step process for how to review new water supplies and how to integrate them in to the existing structure. This has not been done for ocean desalination supplies. Ocean desalination may not pass this review given the problems with the hydraulics of getting water from the coast to the inland regions.
– Brine Disposal Expertise: The SWRCB appears to be trending toward requiring brine diffusers to minimize the impacts of brine on marine resources and setting a new, more restrictive standard for the salinity of the discharge water. Poseidon is refusing to use brine diffusers and will be discharging water that will exceed the likely new standard for salinity. An expert to testify to the damaging effects of brine on marine resources and the best methods for reducing those impacts would be helpful.
Intake Pipe Design Issues and SubSurface Criteria
We should provide more easy to visualize slides to demystify what Poseidon is actually proposing. Perhaps a Video would be even better than a few slides.