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© POSEIDON WATER 2013 1THESE MATERIALS HAVE BEEN PROVIDED TO THE COASTAL COMMISSION STAFF
Huntington Beach Project Coastal Commission Hearing
November 13, 2013
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Use proven technology to affordably provide a long-term, local and reliable source of water not subject to the variations of drought or regulatory constraints
Reduce local dependence on imported water and strengthen regional self-reliance
Contribute desalinated water to satisfy regional water supply planning goals
Key Objectives of the Huntington Beach Project
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California and Orange County Counting on Seawater Desalination
California Department of Water Resources’ Water Plan Update sets a goal of up to 400,000 acre feet / AF of desalination by 2030
Project would provide 56,000 acre feet per year
Governor Brown’s recently released State Water Strategy identifies desalination as one of the pillars to increase regional water self-reliance
Metropolitan Water District of Southern California is counting on 150,000 acre feet of desalination by 2030
Project identified in Municipal Water District of Orange County’s RUWMP as necessary to reduce demand on imported water
50% of Orange County’s water supply is imported
Without seawater desalination, Orange County’s demand for imported water will increase
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Project Permitting History
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Proposed Project
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Flow Schematic – Reusing Existing Industrial Facilities
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RESPONSE TO STAFF REPORT
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Applicant’s Request for Commission Approval
The Applicant requests that the Commission: Approve the Project as submitted Adopt the Applicant’s alternative conditions and
findings
Primary differences with Staff recommendation: Elimination of seafloor infiltration gallery
requirement Elimination of conditions that require a new design
and a new entitlement process
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STAFF REPORT – KEY ISSUES
Subsurface Intakes
Marine Life Effects
State Water Board’s Proposed Desalination Policy
Wetlands
Sea Level Rise
Special Conditions
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ALTERNATIVE SUBSURFACE INTAKE SYSTEM
SEAFLOOR INFILTRATION GALLERY
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Subsurface Seafloor Infiltration Gallery
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Subsurface Intakes: Site-Specific Project Analyses
The study and analysis of alternative subsurface intakes has been a primary focus throughout the Project’s entitlement process
Hundreds of pages of technical analyses of alternative intakes have been provided to permitting agencies that confirm the infeasibility of a seafloor infiltration gallery
The Regional Board relied on technical reports and site-specific data to reject a seafloor infiltration gallery and approve the Project’s use of the existing intake
Since 2006, the Applicant has provided Commission Staff with nine detailed submittals analyzing alternative subsurface intakes and site-specific conditions
The submittals include site-specific geotechnical reports analyzing offshore subsurface conditions at Huntington Beach
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History of Subsurface Intake Analysis
• PSOMAS, 2007, Feasibility of Alternative Seawater Intakes for the Huntington Beach Desal Project
• PSOMAS, 2007, Supplemental Subsurface Intake Feasibility Assessment
• Water Globe Consulting, 2010, Evaluation of Alternative Desalination Plant Subsurface Intake Technologies
• Water Globe Consulting, 2011, Evaluation of Alternative Desalination Plant Subsurface Intake Technologies
• Tetra Tech, 2012, Technical Document Review for Site-Specific Hydraulic Conductivity Values
• Water Globe Consulting, 2012, Well Intake Capacity Updated Based on 2012 Soil Transmissivity Study
• Geosyntec, 2013, Review of Aquifer Properties and Potential Pumping Huntington Beach Desalination Plant
• Geosyntec, 2013, Feasibility Assessment of Shoreline Subsurface Collectors
• Geosyntec, 2013, Response to Requests from California Coastal Commission Staff Regarding Feasibility Assessment of Shoreline Subsurface Collectors
• Water Globe Consulting, 2013, Critical Review of 2013 Desalination Journal Publication on Subsurface Intakes
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Subsurface Geotechnical Analysis Conducted
Staff requested that the Applicant conduct an offshore subsurface geotechnical analysis that included:
Seismic testing to determine subsurface characteristics of ocean floor
Assessment of seafloor sediment samples
Geosyntec conducted site-specific analyses, which included: Seismic testing as requested by Staff; and
Analysis of existing site-specific sediment data in Huntington Beach
• Geosyntec Report corroborated earlier analyses and demonstrated:
Huntington Beach seafloor is not suitable for infiltration gallery
Seafloor sediments consist of “muddy sand” of low permeability
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Locations of Offshore Sediment Samples
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Location of Offshore Geotechnical Analysis
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Results: Offshore Consists of “Muddy Sand”
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Staff’s Recommendation Conflicts with the Regional Board’s Determination
In approving the Applicant’s NPDES Permit, the Regional Board analyzed a number of subsurface intake alternatives as well as the Project’s use of the existing intake
Subsurface intake alternatives analyzed included a seafloor infiltration gallery
The Regional Board found: The Project’s use of the existing intake constitutes the best available
technology feasible to minimize the intake and mortality of all forms of marine life in compliance with Water Code section 13142.5(b). (Permit, p. F-30)
“A seafloor infiltration gallery sized for the Facility would impact approximately 64 acres of benthic habitat and beachfront.” (Permit, p. F-27)
“The alternative subsurface intakes were determined not to be the environmentally preferred alternatives.” (Permit, p. F-28)
“Taking into account economic, environmental and technological factors, the Regional Water Board finds that the alternative subsurface intakes are not feasible.” (Permit, p. F-28)
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A Seafloor Infiltration Gallery is Environmentally Inferior
Excavation of 63.6 acres of seafloor habitat and beachfront
Displacement of plant and animal organisms on the seafloor
Periodic maintenance dredging every 1 to 3 years to remove unsuitable material and sedimentation, resulting in ongoing impacts to benthic communities
Construction of substantial pumping facility(ies), including associated acoustical and visual shielding, security fencing on the shoreline, and access road(s), restricting public access to the beach
Doubles intake-related energy consumption and GHG emissions
Substantial noise and vibration impacts from dredging and sheet pile driving
Removal and disposal of 290,000 to 560,000 cubic yards of seafloor material
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Seafloor Infiltration Gallery Conflicts with Coastal Act and LCP Policies
• Marine Environment (Coastal Act Sections 30230, 30231) Excavation of the seafloor would repeatedly and permanently impact the offshore
benthic environment
• Public Access and Recreation (Coastal Act Sections 30211, 30220, 30221)
Public access and recreation impacts from the construction of 33 intake water collection wells and trenches for connector piping along one-mile strip of shoreline, including service roads
• Energy Consumption (Coastal Act Section 30253(d)) Energy to convey source seawater from infiltration gallery to desalination plant
will be approximately 2 times higher than from collecting seawater from existing intake system
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Subsurface Intakes Are Infeasible
“Feasible means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.” (Coastal Act § 30108)
Environmental: Staff’s recommendations are more environmentally impactful
Technological: Unproven technology; excessive risk
Economic: Not financeable; capital costs increase at least 50%
Social: Impairs coastal access and public recreation
Time: Would require a new entitlement process; current entitlements have taken 10 years
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MARINE LIFE EFFECTS
IMPINGEMENT & ENTRAINMENT
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Marine Life Effects
As proposed, Huntington Beach Project’s marine life effects are minimal - smaller than the Commissioned-approved Carlsbad project - and can be mitigated in compliance with Coastal Act.
Intake structure is not within an Area of Special Biological Significance (ASBS) or Marine Life Protected Area (MPA)
No threatened or endangered species; recreational species very uncommon
Estimated daily impingement of 0.78 lbs of fish/shellfish per day
92% reduction in fish impingement compared to HBGS’ impingement losses
Larval entrainment losses projected to affect only a small fraction of larvae
(0.02-0.28%) of the source water populations of 115 billion
Project would not affect the ability of species to sustain their populations
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STATE WATER BOARD
SEAWATER DESALINATION POLICY
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SWB Proposed Desalination Policy
Acknowledges that seawater desalination is important to meeting State’s potable water demands
Designed to provide permitting guidance to Regional Boards
Draft plan has not been released
Requires public review and comment, CEQA clearance, & State Board and US EPA approval
Policy will be implemented through Regional Board’s NPDES permitting process
Project will have to comply with policy in order to maintain its NPDES permit
Poseidon proposed CDP special condition: Poseidon shall comply with all current and future Ocean Plan requirements applicable to the Project
of the Talbert Aquifer.
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WETLANDS
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No Wetland Impacts
Staff incorrectly claims that areas within fuel storage tank containment berms were recently wetlands
SEIR Jurisdictional Determination concluded that vegetation, soils and hydrology onsite are not wetlands
No nexus to require wetland restoration
Staff incorrectly claims that adjacent wetlands will be impacted by project construction
Site design complies with LCP wetland setback policy
Only a portion of an access road and parking spaces are within 100 feet of a degraded pickleweed area
14-foot high, 60-foot wide containment berm provides buffer between Project site and pickleweed area
Mitigation measures minimize noise, light and vibration impacts
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Pickleweed Area Buffer
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SEA LEVEL RISE
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No Sea Level Rise Impacts
Project site will not be affected by sea level rise Project site is 9-14 ft above MSL
Worst-case sea level rise is 2 ft MSL by 2050 at Project Site
Project complies with Commission’s draft sea level rise guidance
Therefore, Project not affected by sea level rise
Poseidon proposed special condition: Permit expires 35 years after commercial operation; allows Commission to re-evaluate sea level rise impacts
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APPLICANT’S PROPOSED PERMIT CONDITIONS
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Applicant’s Proposed Permit Conditions
Poseidon proposing a separate set of Special Conditions to authorize approval of the Project as submitted
Incorporate elements of conditions recommended by Staff related to site-specific conditions in Huntington Beach
Eliminates requirement for a subsurface infiltration gallery
Eliminates requirements to start new entitlement and environmental review process, and to re-analyze issues that already have been thoroughly analyzed
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Applicant’s Proposed Permit Conditions – Key Changes
Noise and Avian Protection (Special Condition 10) Requires site-specific nesting surveys during construction
periods
Establishes noise protection at active nest locations rather than site boundary
Utilizes 65 dBA standard consistent with Commission precedent
Seismic and Tsunami Protection (Special Conditions 15 and 16)
Applicant’s Special Condition 16 imposes all necessary structural stability requirements requested by Staff
Applicant’s Special Conditions eliminate duplicative requirement to study tsunami impacts that have already been evaluated and elaborate review and sign-off requirements from entities that do not have review authority
Applicant’s Special Condition 15 requires City approval of tsunami response plan and coordination with adjacent power plant on emergency response
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Applicant’s Proposed Permit Conditions – Key Changes
Wetland Protection and Restoration Sufficient buffers exist to avoid wetland impacts, consistent with LCP
policy
Eliminates requirement to redesign Project to increase buffer width
Noise protection condition ensures no impacts to potential sensitive species
Eliminates obligation to create 14 acres of coastal wetland habitat since Jurisdictional Determination confirmed no wetlands on Project site
Marine Life Mitigation Plan & GHG Plan (Special Conditions 13 & 18)
Provides Commission ability to consider MLMP and GHG Plan at future hearing
Neither are deferred mitigation Both must be approved prior to permit issuance & before development
commences
GHG Plan with specific performance standards imposed as City condition
Applicant has already submitted proposed MLMP and GHG Plan, and the Commission has the discretion to approve those today
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Conclusion
The Project is needed to meet to local, regional, and state water supply and reliability goals
Reduces Orange County’s need for imported water
The Project uses the best available technology feasible to minimize effects on marine life
The Staff’s recommendation is more environmentally impactful, conflicts with Coastal Act and LCP policies, and is infeasible
The Project as submitted is fully consistent with applicable Coastal Act and LCP policies
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Applicant’s Requested Motions
November 11, 2013 Letter provides the following:
Applicant’s Proposed Conditions (Exhibit A – pink)
Applicant’s Suggested Basis for Findings (Exhibit B – yellow)
Motions and Resolutions to approve Applicant’s Proposed Project (Exhibit D – blue; Exhibit E – green)
Recommended