Environmental Issue Alert
A Crisis Looms in the Slough
At the Oct 27 Regional Water Quality Board Meeting in San Luis Obispo we were denied a fair hearing. The permit was issued. We are filing a petition for reconsideration.
As of Feb. 1, our petition, and two others, were being seriously reviewed by the State Water Resources Board. Thanks to hundreds of you who wrote letters.
Amidst spectacular displays of wildlife, a fast moving proposal will allow the Moss Landing Power Plant -owned by Duke Energy of North Carolina- to double the power generated at their facility in the fragile Elkhorn Slough Ecological Reserve.
The expansion plan seriously threatens the robust, complex life in this rare coastal estuary, but it may not be too late to stop it.
Moss Landing power plant is the second largest steam plant in the world. Expanded, it will take more than a billion gallons of cold water every day to cool off its massive turbine engines.
The plant burns fossil fuels --oil and gas-- the cold water cools the engines. Then the hot water is discharged through pipes into the ocean just 600 feet off shore.
After a long hard fight to restore Elkhorn Slough to a semblance of its natural state as one of America's greatest wildlife treasures, this plant expansion would turn that around over night. Why?
The Regional Water Quality Control Board, Friday, Sept. 15, voted 3-2 to delay approval of the expansion permit. It was continued for better study of the environmental impact, and to conduct a study of the alternative technology for cooling the plant, and for discharging the heated water from the plant into the Marine Sanctuary.
At the Oct. 27 mtg. in San Luis Obispo the staff made an elaborate presentation, paid by a Duke funded endowment that attempted to dismiss concerns for the biological impact of the plant expansion.
It also did not present an analysis of the alternatives to cooling the plant giant turbine engines with Slough water.
We are now seeking a review of the Regional Board's action by the State Water Resources Board. This petition will present our case that we were denied a fair public; there were irregularities in the staff's presentation; and, there were errors in fact.
At hearings before the California Energy Commission and the Regional Water Quality Control Board, we presented testimony in opposition to the permits, and many letters were presented in opposition. In all, the testimony in opposition was 8 to 1 greater than the testimony given for the expansion. And, to the best of our observance, all the testimony in favor of the expansion had financial relationship with Duke Energy.
Thanks to all who submitted their concern we are forming a group called Friends of Elkhorn to oppose the plant expansion.
Power outages in California incite outcries for more power. Astronomical power bills to consumers add to the chorus.Energy deregulation is becoming known as a failure in the State. Virtually everyone acknowledges that. Except, of course, the power companies who love the inflated profits, and the business clamor for more power, which allows more power plant construction.
The Battle has just begun. We need your help:
Send A Letter to the State Water Resources Agency
Submit a comment to Voices of the Wetlands.
For more information about Friends of Elkhorn, contact: VOW@pelicannetwork.net
While deregulation is proving a disaster for consumers all over the state, power companies are rushing to step up production to reap the higher rate windfall.
To do this, the process of environmental review is being short cut. Kaitilin Gaffney, Central Coast Director for Center for Marine Conservation, says, "this is exactly the kind of project where we need rigorous environmental review."
Meanwhile, environmentally sensitive projects, like expanding the plant in the Elkhorn Slough, do not get diligent review for its consequences on the environment. This proposal will make the Moss Landing Power Plant the largest plant in the State. It is in one of the most environmentally sensitive place in the State. And the plant will hideously double its kill of marine life.
This will happen because the general public does not know about the consequences.
Duke Energy, a $31 billion company based in North Carolina, doesn't seem worried about the marine life it will kill when it expands the plant. Nowhere on its website does it claim to make any effort to reduce it's kill.
In its application to the California Energy Commission, Duke Energy says its expansion units will kill 13 per cent more of the marine life in the Slough. So, added to the existing kill by the power plant intake of Slough water, it will kill 30 to 40 per cent of all the marine life in the Slough.
This kill occurs mostly by an "entrainment" of marine life. The intake valves for this entrainment are right in front of the power plant, right at the most critical point of the harbor and Slough current. Hardly any living organism --coming into the slough- or leaving the slough to go into the ocean- can avoid the sucking of these intake valves. This includes all plankton (minute animal and plant life) that feeds all life in the sea. It means all fish eggs, larvae, every seed that becomes a clam, or becomes a crab, which become food for a sea otter, and food for the fish.
But it does not acknowledge how much more marine life will be killed by impingement -- which means marine life and fish that will get sucked up to the screens in front of the intake valves, and will not be able to escape the traps and screens on the intake valves, and die.
It is a great quantity, and it is vital in the food chain for all life in Elkhorn Slough. Each day a boat with crew hired by the power plant goes to the intake valves and cleans out the impinged sea creatures.
The hot water that is dumped back into the ocean from the plant is going right back into the slough. Technically, the Slough begins at the mouth of the great underwater canyon of Monterey Bay - for the Slough is the cradle of life for the huge marine life system of the Bay. The plant says it dumps the water 600 feet off shore - that is actually right back into the slough.
The ambient temperature is the most critical factor in the nursery for all this marine life that makes the Slough so wonderful. And Duke wants to change that, too. They have not made studies of how the heated water will affect vertebrates and invertebrate marine species, and pelagic birds in the Slough.
Thermal discharges have created deserts of marine shelves in other power plant locations such as San Onofre, California. Alternative methods of cooling the waters have not been studied.
Back in 1940s when PG&E applied for permission to build this plant, the workings of the Bay and the Slough were not well understood. But, today it is known that the plant does horrific devastation to the life in the Bay and the Slough, and there is no excuse for allowing it now.
The Best Technology Available was not analyzed for this plant expansion. Duke is currently being sued in the Eastern U.S. because for 10 years it refused to use the best technology. The essence of our petition the State Water Resources Board for a re-hearing on the permit, is to require Duke to study the alternative technologies.
Duke proposes to give $7 million to the Elkhorn Slough Foundation to mitigate the impacts of the plant expansion. The Foundation proposes to acquire some agriculture land in the rear of the Slough Reserve . But, agricultural lands are not an appropriate substitute for the marine life to be taken.
The byways of the harbor are prolific feeding areas for sea and shore birds that frequent Elkhorn. Water for cooling the plants engines comes from the confluence of the three sloughs and the mouth of the harbor. It contains the most dense concentration of larvae and other marine forms of life in Elkhorn Slough. This marine life becomes vital to the Slough's food web. The scene to the right is a constant occurrence at this very rich point.
Elkhorn Slough is one of the most important estuaries in the world. Over a thousand species flourish in the Slough. More than 200 species of birds live here at different times of the year. Hundreds of marine animals call this home. They give birth and nurture their young here. Thousands of microorganisms which make the Slough so rich in nutrients are nourished here. It is a rare place. It is a nursery.
This is not like taking water out of the ocean. It is taking food out of a nursery.
Elkhorn Slough is often called a cradle of life. This phrase has been used by many writers of the fabled waters of this unique setting.
Hardly anyone has done it so well as Lucinda Jaconette, Author of Monterey Bay and Beyond:
"Elkhorn marine babies get super formula from the offshore Monterey Bay, which sends the slough a constant supply of nutrients that mix with slough decay, such as old pickleweed, and humus from top soil to make 'Elkhorn Slough stew.' The stew is the first course in a food chain that passes from protozoa to plankton to young fish. Sharks, raptors, seals otters, and humans share the harvests farther up the chain. Santa Cruz Sentinel reported Thursday, August 31, 2000:
"Elkhorn Slough has gone global as a great place for birds. The American Bird Conservancy has designated the slough a "globally important bird area" because of the significant breeding and wintering populations of threatened Western snowy plover and the migrant and wintering shorebirds.
The designation means that it is one of the most important areas in the country for bird conservation efforts."
Sea Otters breed and nurse their young in the Slough. These beloved creatures are dependent on clams and shellfish for their survival; the shellfish in turn depend on the microscopic life presently available in the Slough waters.
The plant, owned by Duke Power from North Carolina, is a $22 billion company that builds dams and power plants internationally. Duke is severely criticized by environmentalists for trying to build a dam in Belize that will flood a rain forest. Two other power plants in California are drawing environmental criticism.
This expansion is quickly moving along the approval trail because there is not a big enough voice rising against it. If you care about protecting the birds and marine life in this cradle of life, you can help that voice grow so that it may become effective.
But, however 'onerous' the review process may be, it still is not enough to stop a plant that would not be allowed by the U.S. Environmental Protection Agency. The environmental devastation the plant expansion will do to this vital marine life habitat is beyond calculation, and way beyond what new plants would be allowed to do anywhere in this country. But, because this plant was built in the 1950s, when very little was known of our energy generation consequences on our environment, this plant is 'grandfathered' around the rules.
Duke's proposal to speed up the review process is based on their claim that there will be more power outages, and rates are going up.
Duke claims the permit process in California is the "most onerous" in the country. They are not calling it the most environmentally conscientious, or, most accountable, or any of the kinds of terms the law makers who drafted the process regulations in the public interest may have labeled it. To Duke, it just seems to be a hindrance, and they want to get around the process.
Elkhorn Slough is a vital resting, nesting and feeding place for hundreds of different kinds of birds. Less that 10% of all California wetlands remain. With this expansion proposal, Duke Power would cut out up to 40% of the life of Elkhorn Slough's life that sustains the birds.
Many birds, like the Great Egret, conduct their whole life cycle here. They breed, then nest in the tops of the Monterey Pines in the Slough, and hatch and feed their eggs in those nests, then take the fledglings out into the Slough's waters and shores to teach them fishing and other life skills. With up to 40% of the life taken out of the Slough, the bird populations will die off at least at that rate.
Cormorants, parent to hatchling, can be observed in the Slough. In the Slough's Rookery Pond, in a great stand of Monterey Pines, three giant birds nest next to each other: Great Egrets, Great Blue Herons and Cormorants.
The world record for viewing the most species of birds belongs to Elkhorn Slough - more than a hundred different kinds of birds seen in one day.
Forty years ago the California Brown Pelican was believed to headed for extinction. It's greatest enemy was DDT. After Rachel Carson's book, Silent Spring, exposed the dangers of spraying with that insecticide, it was banned in the U.S. The pelican was found nesting on Anacapa Island off the Santa Barbara coast, and saved by wildlife specialists. And, with DDT no longer dooming them to extinction, Pelicans began repopulating our habitats. Now, there are hundreds in and near the Elkhorn Slough. It is a favorite haunt for them because of the great abundance of fish near the mount of the Slough where the power plant expansion will double its current intake and double its hot water output. This will a seriously negative effect on the Pelican.
The cruel irony of this proposal is the fact that this plant would not have been built if today's laws existed then.
The U.S. Environmental Protection Agency would not allow this plant to expand but for a quirk of the law. The obsolete technology of this plant is "grandfathered" in because it originally was allowed to operate at the level now proposed. If the plant is allowed to expand, the permit will be good for another 50 years.
All around the Monterey Bay people pretend not to notice the plant, and the huge plumes of smoke constantly flowing from the 500 foot high smoke stacks. It is like a specter in the corner of the room, nobody looks at it. In Moss Landing, the sound of the plant running is constant. Soot from the smoke stacks carpets the boats. People, for the most part, ignore it. Sort of willing it away. But, when it doubles in production, and a drastic reduction in the marine life in the slough reduces kayaking, bird watching and fishing business, people will notice.
The great obscenity on Elkhorn Slough, one of only 13 true estuary ecological reserves in the country, is not that Duke wants to kill all this marine life so they can make money.
The more horrific crime is that people who love nature and treasure the value of wild life may allow it to happen.
The Slough has been under attack since settlers first spotted it. They have diverted it, drained, plugged up its natural tidal pipes, and done whatever it could to exploit it for their own greed. Now there is a consciousness arisen that recognizees the nature values of the slough. That is is critical as a nursery and a habitat for hundred of birds and fish, and thousands of marine organisms that feed the fish and birds.
Regional Water Quality Control Board (RWQCB) is the state agency responsible for issuing the intake and discharge permits required for this plant to operate. The Duke proposal seeks to utilize the same outdated, inappropriate technology for intake and discharge that was permitted in the 1950s to continue for another 50 years.
The RWQCB has asked for more information on alternative technologies that would reduce the impacts on the Slough and Sanctuary inhabitants. This information is to be presented at their next meeting in San Luis Obispo on October 27.
The California Energy Commission is responsible for granting the operating permits for power plants. Existing state and federal guidelines would not allow a plant to be built in such a biologically significant area today, nor would they allow a plant using such outmoded technology.
Duke's expansion plans are announced to cost $500 million. That includes the token $7 million for mitigation, which spread over the operating life of the permit, comes to only $140,000/year.
What is the price tag to protect the otters, the hundreds of resident and migratory birds, of the sharks, skates, rays, gobys and other species living now in Elkhorn Slough waters?