The Proposed Poseidon Seawater Desalination Facility A Practical Assessment of Need, Feasibility, Environmental Impacts, and Policy Implications PRESENTED BY: This needs points from Debbie

Poseidon’s Desalination Plant is Not Needed

Source: www.poseidonwater.com Poseidon: What They Do “We secure premier desalination plant locations co- located with power plants….with the capability to intake or discharge seawater….” “Technology neutral approach enables tailored cost- optimized projects.” “Possess intellectual property for desalination co-location with power plants.” I could not get rid of the second text box so please remove it. Is there a way to put a footnote to their website page? Source: www.poseidonwater.com

CA Statewide Policy Advances-- Poseidon’s Desal Design Doesn’t Policy Advancements Since Approval of Carlsbad Plant in 2007 2010 SWRCB orders phase out of open ocean intake at 19 coastal power plants including Carlsbad and AES. MPAs for Southern CA are approved by Fish & Game Commission. 2014 SWRCB intends to adopt the Ocean Plan Amendment that establishes statewide standards for desalination facilities. 2005 SWRCB policy discussion begins to phase out open ocean intakes begins. 2007 Poseidon Carlsbad CDP approved with open ocean intake. 2012 AES applies to decommission open ocean intake by 2020 or earlier. 2011 SWRCB convened Expert Panels in preparation for Statewide Desalination Policy. 2013 SWRCB Expert Panels on Desalination publish recommendations. SWRCB to release Draft Policy before 2014.

Co-Location vs. Best Available Technology Poseidon Co-locates with power plants to reduce construction costs Open ocean intake maximizes marine life mortality with potential adverse impacts to MPAs Open discharge results in large brine plume Designed for profit Best Available Technology Located where needed and site conditions are optimal Subsurface intake minimizes marine life mortality and limits potential adverse impacts to MPAs Spray brine diffuser reduced brine plume up to 90% Designed to meet need

Subsurface is Feasible Operational Subsurface Seabed Infiltration Gallery in Fukuoka, Japan Singular intake from multiple galleries No surface facilities No adverse impacts to public access and vista Poseidon's Distorted Depiction of Subsurface Intakes Multiple intake pipelines to shore Surface pump stations Adverse impacts to public access and vista Is this picture on the left from their presentation. I want to use THEIR slide and the worst one possible. The pic on the right was not very descriptive so I changed it.

Poseidon Must Prove that Subsurface is Infeasible Poseidon cites several Water Globe reports and memos to claim that subsurface intakes are infeasible. Report was prepared by Nikolay Voutchkov, a former Senior Vice President for Technical Services for Poseidon Resources. Voutchkov is the inventor of the patent for co-location that was assigned to Poseidon Resources in 2005. The CCC cannot rely on the Voutchkov ‘report’ to determine infeasibility.

Poseidon Never Proved Subsurface is Infeasible Others performed onsite feasibility studies first, then designed their project. Poseidon designed its project first and never performed site specific studies offshore. A report submitted 6 weeks ago by a former Poseidon employee only indicates wells cannot be built. Staff has never suggested wells.

Poseidon and SDCWA Accounted for Subsurface Intakes in their “Financial Planning” for Carlsbad The Water Purchase Agreement acknowledges that a new intake system could be required in 2017 at Carlsbad given a ‘change in law’ as a result of the “closure and decommissioning” of the open ocean intake as required by the OTC policy. Poseidon and the SDCWA told the New York Times in 2013 that they had accounted for the “eventuality” of subsurface intakes in their “financial planning.” Carlsbad was successfully financed with $734M in Tax Exempt Private Activity Bonds and $189M in private equity based on the WPA as collateral.

Proposed Open Ocean Intake Obsolete technology built in 1958 for a Power Plant Documented marine impacts 100 mile Source Water Population (SWP) Tons of chemical additives a day 4 million+ gallons of wastewater discharge per day

Brine Discharge Hypersaline brine contains residual chemicals, degrades water quality and displaces marine life Proposed vertical open discharge designed for hot water not brine Spray Brine diffuser would reduce Zone of Initial Dilution (ZID) by 90%

Biological Extent of Impacts Total larvae for which impacts are assessed and source water areas are calculated. Total larvae sampled Total larvae entrained Total organisms entrained From Raimondi, Variation in Entrainment Impact Estimations Based on Different Measures of Acceptable Uncertainty, 2011. 12

There are Nine Coastal MPAs within 25 miles of the Huntington Beach Generating Station Bolsa Chica Basin and Bolsa Bay SMCAs HBGS Point Vicente SMCA Abalone Cove No Take SMCA Upper Newport Bay SMCA Crystal Cove SMCA Laguna SMR and No Take SMCA Dana Point SMCA Image credit: NRDC

California’s Marine Protected Areas Have Been Designed to Function as a Network MPA Marine Protected Areas

The Coastal Act Contains Implicit Protections for MPAs Photo by Dana Murray Photo by Marc Shargel

Poseidon’s Temporary Permits are not Entitlements Temporary Co-Location Permits NPDES Permit State Lands Commission Lease California State Parks Easement Department of Public Health Pipelines Routes within Costa Mesa Permit for Standalone Operation 2020 Not Final EIR May Be Required

Temporary NPDES Permit Under temporary stand-alone operations, the Discharger has little control over the intake structure. Under these conditions, the existing intake meets the best available design criteria. Pursuant to Water Code Section 13142.5(b), the direct connection of the desalination plant to the HBGS's cooling water system pipelines represents the best available design feasible to minimize intake and mortality to marine life from the Facility's temporary stand-alone operations. Because different and/or better designs may be feasible in the future under long-term stand-alone operations, the Regional Water Board will reevaluate the Facility's compliance with Water Code section 13142.5(b), best design available requirement, under those conditions.

Poseidon Intentionally Provided False Information in Carlsbad GHG Plan 2008 GHG Hearing: Poseidon assured the Commission that “water from the desalination plant will provide direct, one-for-one replacement of imported water”—Nov. 9, 2007 Poseidon letter 2010 Revocation Hearing: “Water eligible for MWD’s subsidy exclud[es] any Desalinated Seawater that…will not augment water supply.”—2005 MWD agreement Need to add bullet points in. And this cite from the 2005 is not the clearest language. Is there anything that is more direct and not convoluted? AC “We expect MWD to take its full SWP and Colorado River rights and entitlements for the foreseeable future”—Jan. 20, 2010 MWD/SDCWA letter

Poseidon Has Provided The Same False Information Again HB GHG Plan: “Poseidon will be credited with emission reductions associated with the replacement of imported water from the SWP.” Staff Report: “Poseidon’s project will not ensure a decrease in imported water supplies to Southern California…this [automatic] ‘crediting’ approach to achieving carbon neutrality is not warranted.”

Which Project Design Offers More Jobs? Poseidon Plant as Proposed Continued Use of Open Ocean Intake Pipe Constructed in 1958 CCC Staff Recommendation Additional Construction of: Water Infiltration gallery Subsurface Pump Station Connecting pipes Service road This goes as the next to last slide. The extra construction is what Poseidon told Bocho they would have to construct.

Which Desalination “Train” Will Leave the Huntington Beach Station? 1950’s Technology 21st Century Technology