In Hot Water
Environmental groups and the state Coastal Commission aren't buying the line that Duke Energy's money can save marine life from the power plant expansion.
Thursday, July 20, 2000
In an assembly room overshadowed by Moss Landing Power Plant''s two towering 500-foot smoke stacks, a crowd of 100 or more environmentalists, scientists and public officials gathered on Monday to talk about the impending expansion of the Moss Landing facility by Duke Energy. Among them were representatives from the Monterey Bay National Marine Sanctuary, the California Coastal Commission, the county of Monterey and a myriad of conservation groups. For most of them, the project was a mystery until a month ago.
Inside the assembly room, Duke Power propaganda adorned the walls, touting the economic benefits, improved air quality and improved water use expected from the expansion. But despite the expansion project''s celebrated efficiency, not everyone was impressed. The expanded power plant, conservationists fear, will take its toll on the surrounding ecology in ways they can''t even guess at yet.
Although eight defunct smoke stacks will be torn down and five old power generating units will be dismantled, the project is definitely a net expansion. It entails constructing two new power-generating units behind the existing plant, part of which will remain in operation (the part to remain includes the two landmark smoke stacks). Courtesy of new technology, the new natural-gas burning units are projected to spew 25-40 percent fewer emissions into the air and use less water than the older units for their once-through cooling systems, which draw water in from the adjacent Elkhorn Slough and the Moss Landing Harbor to cool their turbines.
The new units may use less water than the older, still operational units, but when combined the upgrade will increase the water drawn from the slough and the harbor by 6 percent. Altogether, the new plant could draw as much as 28 percent of the area''s waters through its cooling system and back out into Monterey Bay. Environmentalists are worried about effects of inadvertent trapping and killing of sea life and larvae in the water intake system and the increased discharge of warmer water into the Monterey Bay.
Perhaps most pressing, they''re worried about getting stuck with a vaguely defined and poorly researched mitigation plan to make up for the environmental damage. The California Coastal Commission, the Sierra Club, Friends of the Sea Otter, the Center for Marine Conservation, and Save Our Shores, among others, are concerned that the proposed mitigation measures don''t directly address potential harm to wildlife in the biologically sensitive Elkhorn Slough.
Staff with the California Energy Commission, the lead agency on the project, is recommending that Duke pay $7 million for enhancement or expansion of 390 acres of wetlands to mitigate environmental impacts. But the report doesn''t outline specific measures, and conservationists say throwing money at the problem won''t necessarily fix it. Furthermore, the staff report fails to clearly spell out how exactly the $7 million is to be spent.
"There is no [mitigation] plan," says Michael Bowen, an analyst with the Coastal Commission, which on Tuesday sent a letter containing its formal comments on the project to the Energy Commission. "The gist of what the [Coastal] Commission is saying is that a pot of money is not a satisfactory substitute for mitigating the project impacts."
Under state rules, Duke won''t have to have a permit from the Coastal Commission even though the project falls within the coastal zone. However, Bowen says, state law does require the Energy Commission to incorporate the Coastal Commission''s comments into permit conditions--or else give a good reason why they can''t.
The interplay between the two commissions on this project has consequences reaching far beyond Moss Landing. Since the Moss Landing expansion is the first power plant upgrade on the California coast since the Coastal Commission was created in 1976, how seriously the Energy Commission takes the Coastal Commission''s comments will set a precedent for future power plant expansions up and down the coast. With the deregulation of energy, similar projects could prove prolific. As a matter of fact, Duke is planning a similar expansion in Morro Bay.
"How [the Energy commissioners] react will have a very significant impact for how power plant projects are designed and built in the coastal zone," Bowen says.
Slough of Strife
In May of last year, Duke Energy filed an application with the California Energy Commission to expand the Moss Landing Power Plant, which feeds a grid supplying power to the western United States and two states each in Canada and Mexico. The $475 million project will increase the plant''s maximum output from 1,500 to 2,700 megawatts. That''s enough to power 2.7 million homes and make Moss Landing one of the largest power plants in the state of California.
Were the power plant being built today, chances are it wouldn''t have broken ground next to this fragile marsh. But the plant was built in 1950, long before the California Environmental Quality Act or the California Coastal Act or the Endangered Species Act. The expansion project is, however, subject to those laws, which require a public review process and environmental analysis, including the cumulative effects of the existing operation. "We are now in essence revisiting environmental decisions of a different era," Bowen says.
Duke Energy needs permits from the state Energy Commission, the California Regional Water Quality Control Board, and the county of Monterey before it can expand. Yet, one of the problems local groups have with the project is a perceived unwillingness by Duke and the permitting agencies to let them in on the planning. "Nobody gave us any notice," says Jim Curland, science director for the Friends of the Sea Otter. "They tried to send this project through without involving the environmental community."
And, while the Energy Commission has been working on the project for more than a year, the first assessment of the biological impacts of the project wasn''t released until June 9, followed by amendments released on June 19. That was just one day prior to a public workshop, a window that left concerned parties precious little time to prepare their questions or comments.
Their sensitivity is partly due to the fact that the power plant expansion will directly affect the Elkhorn Slough National Estuarine Research Reserve, part of the Monterey Bay National Marine Sanctuary. The slough is far from pristine--historically, agricultural runoff including DDT has contaminated it, and erosion and dredging have altered it physically. But it is one of the few large coastal wetlands remaining in California and a rich wildlife habitat that is home to some 260 bird species, some of whom are endangered or threatened. The threatened southern sea otter also lives here, as well as some 480 invertebrate and fish species.
According to a June 19 Energy Commission staff report, currently the plant''s cooling system sucks in cold seawater from the Moss Landing Harbor and the slough and spits out warmer water into the Monterey Bay after it''s been used to cool the power plant''s turbines. The expanded facility will require about 6 percent more water per year--the new pumps will pull in an additional 250,000 gallons per minute--raising the maximum amount of needed water to more than one-quarter of the slough and harbor''s total volume. In addition to the draining impact on the slough, the intake process itself is giving project critics a headache.
When the water is sucked into the cooling system, fish and invertebrates can be caught against the system''s screens, causing what''s called impingement, in which the critters are unable to break free. The water is discharged 600 feet offshore at a higher temperature, potentially causing harm to marine life. However, Energy Commission biologists believe that those two impacts will not cause significant harm to marine life.
What they do consider a significant impact is the entrainment of fish larvae. Entrainment refers to the drawing in of small larvae that float in sea water. The larvae pass through the system''s screens and are destroyed. In the report, commission staff calculates an average of 13 percent of the area''s fish larvae will be killed. The loss of larvae could affect the fish that supply food for the various bird species and the sea otters.
To counteract that loss of fish larvae, the Energy Commission staff report recommends requiring Duke to improve 13 percent, or 390 acres, of the slough. The report calls for charging Duke a $7 million impact fee to be used to purchase land around the slough or to improve existing wetlands.
"We did feel strongly that by improving the habitat...that we in some respects would be mitigating the impacts," says Energy Commission biologist Richard Anderson.
But the problem, say conservationists, is that buying or enhancing wetland areas doesn''t directly address the loss of larvae caused by the project.
"Enhancement in the slough or erosion control in the upper watershed doesn''t directly mitigate impacts caused by the project," says Kaitlin Gaffney, program director for the Center for Marine Conservation. "You start by trying to avoid the impacts. If that''s not possible, you try to mitigate as close as possible the impacts. That''s a basic premise of mitigation."
For example, the current mitigation package does not specifically take into account possible impacts to creatures higher up the food chain.
"Sea otters rely on prey in the slough," Curland explains. "If you are going to modify the habitat, you better address how you are going to account for those losses."
Moreover, putting a $7 million cap on the mitigation could be giving Duke a deal. The staff report estimates the costs of wetland restoration in the slough at an average of $18,000 per acre. But the state Coastal Commission''s Michael Bowen says that might not be enough. He puts the costs closer to $100,000 per acre.
A final draft of the Energy''s Commission''s staff assessment is due out in August, after which public comment will be accepted for 30 days. But environmentalists fear that an approving nod by the commission might be a foregone conclusion.
"Certain decisions have already been made," Gaffney says. "You create a certain amount of momentum once you have staff recommendations."
For more information about the Moss Landing Power Plant expansion, call (800) 822-6228 or visit www.energy.ca.gov/sitingcases/mosslanding.