More than 50 years of destroying marine life by coastal power plants are coming to a close in Morro Bay and rest of California2 Comments Published by CAPE July 19th, 2007 in Press Releases
By Jack McCurdy, co-president, Coastal Alliance on Plant Expansion
For more than 50 years, power plants have been drawing sea water from bays, estuaries and the ocean to cool their electrical generators, killing “billions of aquatic organisms, including fishes, fish larvae and eggs, crustaceans, shellfish and many other forms of aquatic life from California waters each year.”
That quote is from a landmark report issued by the staff of the California Energy Commission in June, 2005. It was the first time that any state agency had faced up to the long-term damage inflicted on the marine environment by California’s 21 coastal power plants along the entire length of the coast from Humboldt Bay to San Diego, including the LS Power plant in Morro Bay.
It got zero coverage in the media, but it took on a life of its own, spawning a grassroots movement against use of ocean water for cooling by these plants, or any new or replacement plants. That statewide movement is at its zenith right now.
(This cooling process is commonly called once-through cooling, or OTC, because the water is diverted into plants through intake channels, used to cool generators and then discharged heated back into the ocean. An estimated 17 billion gallons is used daily by the 21 plants.)
Studies required by the U.S. Clean Water Act have often documented the significant loss of aquatic life from OTC used by individual plants on the California coast. But, amazingly, the collective damage in a macro sense had never been assessed or recognized.
Here is how the Integrated Energy Policy Report described it:
“California marine and estuarine environments are in decline and the once-through cooling systems of coastal power plants are contributing to the degradation of our coastal waters…California’s Ocean Action Plan recognized…that the marine environment has been overexploited to the point that its biological integrity and the viability of economies that depend on it are threatened…
“California Energy Commission and other State agencies have shown that coastal power plants that use seawater for once-through cooling are contributing to declining fisheries and the degradation of estuaries, bay and coastal waters. These power plants indiscriminately ‘fish’ the water in these habitats by killing the eggs, larvae, and adults when water drawn from the natural environment flows through the plant (entrainment impacts) and by killing large adult fish and invertebrates that are trapped on intake screens (impingement impacts). These facilities also affect the coastal environment by discharging heated water back into natural environments.”
The report emphasized that “alternative cooling technologies,” such as “dry cooling,” which uses a finite amount of fresh water recirculated in plants as in a car radiator, could drastically reduce or eliminate OTC and the destruction it causes.
The staff recommended a new policy on power plant cooling that would, in effect, eliminate licenses for plants using OTC. But the Commission failed to go along in the final report that went to Gov. Arnold Schwarzenegger for approval.
Undoubtedly, the power companies lobbied against the staff recommendation to end the free “fishing” of those plant owners, refusing the pay the modest costs of alternative cooling technologies but more than willing to allow the public, the state, the environment and coastal-dependent businesses to shoulder the effects–and costs–of broadscale marine degradation.
The Commission and regional water boards, which also must issue permits for coastal plants, have always bent over backwards with a wink and a nod to approve OTC, even accepting evidence from companies that failed to square with the facts.
For instance, at Morro Bay where water is withdrawn from the Morro Bay National Estuary, Duke Energy insisted that dry cooling for its proposed replacement plant would be unreasonably expensive because the cooling units would have to be large enough to cool at an ambient temperature of 84 degrees. The Commission staff called this “irrational” because the official atmospheric record shows that the average is 64 degrees, which would require much smaller and affordable units (costing less than .004 cents per kilowatt).
But the Commission bought Duke’s argument. At Moss Landing, the Central Coast Regional Water Quality Control Board approved two large new generating units that use OTC, based just on Duke’s undocumented claim that dry cooling would be too costly. That decision is being challenged before a state appellate court.
In the face of such virtual automatic support for OTC by state agencies, the Commission staff report on marine impacts threw a wrench into the steamroller. Dana Palmer of the Santa Monica Baykeeper and I discovered the report, alerted other environmental groups and got the California Coastkeeper Alliance to spearhead a stateside effort to convince other state agencies to take action to protect the marine environment from these plants.
The Ocean Protection Council, mandated by the California Ocean Protection Act to preserve the state’s coastal resources, called on the state–quoting liberally from the report–“to implement the most protective controls to achieve a 90-95 percent reduction in impacts” from OTC. It also launched its own study of how best to convert the plants to alternative cooling technologies. The State Lands Commission, which also has jurisdiction over the coast, joined in the call for action.
But they both deferred to the State Water Resources Control Board, which has prime statutory authority over industrial use of water, both ocean and fresh. The Board has held several workshops and meetings on a new state policy on OTC by plants, and recommendations from it staff are pending.
But the bombshell that is expected to outlaw OTC came last Jan. 25 when the Second Circuit federal appellate court in New York ruled that existing plants must use “best technology available” (BTA) when being upgraded or replaced. (The decision applies nationally.)
No longer can plants be allowed to continue using OTC and compensate for its damage by paying to restore or protect natural habitat, which has been the common practice, but now declared illegal. (Whether such restoration actually makes up for the loss of aquatic life has never been proven, even though the Commission and regional boards have routinely approved it.)
And no longer can cost of technologies, such as dry cooling, be used to determine whether they must be required. “…total cost is no longer to be considered in comparison to effluent reduction benefits,” the decision said. Cost can be considered, the court said, in selecting which cooling technology to use–but whatever the cost, the one chosen must equal “the performance of the bestperforming technology.”
However, this powerful decision does not minimize the importance of a new state water board policy on OTC–far from it. Power industry appeals of the decision may take a year, and in the meantime, the state board could and should lead the way in implementing the letter and spirit of the decision.
The California Air Resources Board is revered for going beyond federal rules in requiring more stringent air quality standards in California. The same kind of protection of water quality from the destruction visited on our coastal waters and sea life by the wasteful, inefficient and outmoded OTC should be provided to our state and its people, impelled by the court decision.
The immediate question is whether the decision’s requirement of BTA should apply to the current, reduced operations of California’s aging 21 plants. One thing is clear: the court said its decision “applies to existing facilities” and made no exceptions.
As the Commission report noted, “California’s coast in particular (is) in serious decline,” which means that even reduced killing of aquatic life can inflict an even more serious disproportional wound.
Despite that reality, the power industry as a whole continues to demand a right to use OTC, but their unity is beginning to fracture. Owners of old plants in Chula Vista near San Diego, El Segundo and Humboldt County have voluntarily agreed to forego OTC (what happened to the argument that alternative cooling technologies are too expensive?) and incorporate some kind of closed-cycle cooling in the new plants that they hope to replace the old plants with.
As one plant manager told me, his company sees the handwriting on the wall–and the letters spell BTA, not OTC.