"Great things begin in the tiny seed of the small change in the troubled individual heart. One single, lonely, inexperienced heart has to change first-- and all the rest will follow." *
Oct 27 in San Luis Obispo, the Regional Water Quality Control Board meets to deliberate on a permit for the Moss Landing Power Plant. They have the responsibility for issuing a permit for taking the Slough water, and for discharging the heated water into the Sanctuary. You can have a voice in the decision. Please complete and submit the following form mail:
In the 1970s Margaret Owings saw a person shoot a sea lion from the highway. She was not an activist, not even a conservationist, but she wrote a letter to the Monterey Herald that closed with: the man "had taken a life greater than his own."
Later she learned of plans to kill sea otters because they ate abalone. She founded Friends of the Sea Otters.
When Rachel Carson received the National Audubon Society Award she spoke these words for her work that taught the world the dangers of DDT.
Twenty years later, just before dying, Carson wrote to Margaret Owings to ask that she repeat these words when she would receive the same award.
Letters from other members of Friends of Elkhorn
Dear RWQCB Directors,
In September of this year, scientists working with Conservation International designed "California's floristic province", of which Salinas and Pajaro Rivers systems, including their allied sloughs are central, as THE area in the United States in which conservation dollars would achieve maximum habitat protection effectiveness.
Later that month, the American Bird Conservancy designated Elkhorn Slough as "globally significant bird habitat" for resident and migratory species, some of which are rare and some even endangered.
In early October, the Western Hemisphere Shorebird Research Network gave final approval to the designation of 4 new sites, one of which is Elkhorn Slough, into their network.
These designations join the existing ones for this section of the Pacific as a "National Marine Sanctuary" and for Elkhorn as a "National Estuarine Research Facility".
The remarks of Robert Stephens of the Packard Foundation, Fred Keeley, Speaker Pro Tempore of the Assembly of the State of California and Bruce Babbitt, U. S. Secretary of the Interior on Wednesday of this week at Lighthouse Field all extolled the biological diversity to be found in this region and acknowledged that biotic resources and habitats are endangered by population growth and development. They were pledging cooperation between private, state and federal sources to achieve the goals set forth by Conservation International. The growing number of public and private marine and wetland research institutions ringing Monterey Bay, including the new National Marine Fisheries Service office in Santa Cruz is a manifestation of our growing national concern with marine issues, from tanker transport regulations to declining fish stocks and declining marine mammal and bird populations.
Speaker Hertzberg's editorial in the San Jose Mercury early this week calling for development to be evaluated on a regional basis is also in line with a growing awareness that the quality of life can be destroyed unless a new approach to planning and resource protection and utilization is applied.
You are charged with issuing the discharge and intake permits for the proposed expansion of the Duke Energy plant in Moss Landing and next year, in Morro Bay, which is why I testified before you in Seaside last month and write to you again today.
Both these plants were designed and built in the last 1940's, a time when virtually nothing was known of marine nor wetland science or the complex interactions between them nor the vital ecosystem functions they perform nor the wildlife populations they support. Some of these lessons Americans have learned the hard way as we pursued a national course of diking, dredging and filling these areas for recreational, residential and industrial uses - only to see declines in dependent species.
Yet Duke proposes to utilize the basic 1940's intake and discharge elements in this 21st century expansion and not only to continue but to accelerate the "hijacking" of vital elements of the food web that sustains all life in the Elkhorn Slough system by withdrawing even greater quantities of slough water for cooling.
I most sincerely request that you insist on adequate protection for the essential public resources of the Elkhorn Slough system by requiring that Duke construct a recirculating system, including a cooling tower which would enable them to both reuse the water to cool the turbines, which would protect organisms in the Slough waters, but would also halt the practice of dumping superheated water into the National Marine Sanctuary. The continuous dumping of 1.3 Billion gallons of water 28 - 34 degrees warmer than ambient waters, a temperature differential far greater than would be found naturally between the waters of Baja California and the waters of British Columbia, can, in no way, be beneficial to the Sanctuary ecosystem.
The first rule that all good doctors must follow - "First, do no harm"applied here and I ask you please to insist that Duke be held to these requirements for their permit.
Thank you for your attention.
Patricia Matejcek"There is only one body of water on our planet Earth, constantly traveling from one river to one lake to one ocean... The sea is a bonus to us all, soothing climates, washing beaches, pregnant with resources of all kinds, but still sensitive and vulnerable." - Jacques-Yves Cousteau
Dear Board Members:
On Friday, October 27, 2000, you will be meeting to decide on the Reissuance of NPDES Permit No. CA0006254 for Duke Energy Power Plant, Moss Landing, Monterey County.
I urge you to deny this permit on several grounds:
First is that the heated wastewater discharge is over the allowable limit by about 4 degrees Fahrenheit and will cause death to a greater number marine life as stated in the CEC's Errata to the Presiding Member's Proposed Decision -and- Response to Comments of October 12, 2000,
"page 164, footnote 65, add a second sentence: Comment of the California Department of Fish and Game point out that heated water is deleterious to larval organisms at the temperature proposed for discharge."
Secondly, the monitoring of the effects of the thermal discharge is not to begin until after the project has started. Thus there is no baseline to compare to. The permit should not be issued until studies have been made to comparable power plant discharges in different parts of California and to other parts of the United States.
Lastly, the mitigation package does not include reparations for marine organisms harmed by the thermal discharge.
Again, I urge you to deny the permit on the above scientific grounds, but also on the grounds that the area is biologically significant for migrating birds and mammals and thus is irreplaceable. There is no real, only an artificially created, need to increase the desecration of what vital coastal habitat remains in California today.
Dear RWQCB Directors,
The decisions you make concerning the application to expand the Moss Landing Power Plant will have great effect on the fate of Elkhorn Slough. At your last hearing you showed genuine concern for the well being of the Slough, and asked your staff and the applicant to vet an alternative technology for the plant's cooling system.
This letter represents the hopes and concerns of hundreds of people who visited our website, and expressed hope you will do two things.
1. Act favorably on the proposal to install an alternative cooling system.
2. Consider a study of the harbor's relationship to the Slough.
We ask you to require the applicant to install the closed cycle cooling water system that would eliminate the controversial once-through system that requires such massive water intake, and thermal discharge into the Sanctuary. The California Energy Commission, which is concerned with getting power plants on line, dismissed this technology as too costly.
The alternative, however, as proposed by California Fish and Game would not be too costly. It would utilize existing structures, including the 225 ft. smoke stacks that could be retrofitted for the closed cycle system. The costs, which are referred to by CEC as too expensive at $30 million, would be much reduced by this retrofit use. Other reports show the costs to be quite less, in the area of $13-14 million. Further, the cost for demolition would be saved.
Then, consider the savings by not having to compensate for the loss of biological productivity that would have been caused by the plant's intake; and, the effect the harbor now has on precious habitats in the ecological reserve.
After the biological loss posed by the plant's intake, the greatest threat to the Slough is the tidal scour caused by the harbor.
The Slough is losing more than 10 acres of wetlands each year now due to tidal scour. (This is not a hard number, and it would be difficult to assess exactly how much erosion there actually is.) Twice a day giant surges in and out of the Reserves, are caused by a tidal bore through the opening of the harbor to the ocean, and to the channels of Elkhorn and Moro Cojo Sloughs. This scour causes massive erosion in the Slough, resulting in the loss of precious habitat in the mudflats, and takes away islands.
To compensate for the biological loss in the front of the slough, with payment for wetland restoration in the back of the slough is a paradox. It provides redress for something not caused by plant intake. It will pay for restoring lands caused by another effect.
But, all reports agree the plant intake will cause a loss of biological productivity. The CEC technical working group considered that to be worth 390 acres.
What was not realized, however, was that restoring upslough wetlands is not productive while continuing to allow the tidal scour to take away wetlands. Indeed, the compensation accounts for 390 acres for a 50 year plan, while the loss of habitat due to tidal scour from the dredged harbor opening straight into the Elkhorn Slough main channel will be 500 acres (again, an estimate).
The compensation package is based on a multiplier of $17,000 an acre, which is woefully inadequate. If based on comparable wetland acquisitions for restoration by the Coastal Conservancy, it should be more in the neighborhood of $50,000. Thus, the compensation package should be about$20 million. And, if you gave comparable value for the land cost, the compensation would be more like $25 million.
That would be sufficient for a closed cycle water cool system, which would obviate the need for a compensation because there would be no biological loss. So, the closed cycle system is probably a savings to Duke Energy.
However, Duke should be asked to financially participate in a modification of the harbor opening to the sloughs. Moss Landing Marine Laboratories, concerned citizens, the harbor district, watershed community groups and the Slough Foundation should be convened to propose solutions to the tidal scour problem.
Your Board praised the efforts of some to contribute to the future well being of the Slough. This acknowledged the goals and objectives of the Elkhorn Slough Foundation as laudatory. This indicated that there should be an effort to contribute to the mission of restoring wetlands and protecting watershed.
However, the tidal scour is causing an alarming rate of salt water incursion to the slough, and to not reckon with the cause is similar to trying to put toothpaste back in a tube. To not make an insightful decision now about the future of the Slough, could cause very expensive decisions to be made later.
For the complete well being of the Slough, channels of rivers should never have been made, the harbor should not have been dug, and the power plant should not have been installed. In such an ecologically important area, we now knew these are inappropriate. To revert the setting to a pristine state, is fanciful. But, they can be realistically modified, and within practical economic restraints, so as to achieve an integrated co-existence that will achieve a well being for the slough.
If you require the applicant to (1.) work with a consortia of local groups and the Army Corps of Engineers to plan modifications to the harbor opening, and, (2.) install the closed cycle cooling water technology using the retrofitted towers as suggested by Fish and Game, you will have made a great accomplishment for the well being of the slough.Jack Ellwanger
Dear RWQCB Directors.
Several technological options need deeper study and consideration before Duke Energy is issued a permit to expand their Moss Landing Power Plant. One alternative is cooling towers, which would complete eliminate the need for intake of water from the Slough. The other is the use of a closed cycle cooling water system. Although it has some negative impacts, they are minuscule compared to the potential damage to the web of life by the proposed technology. At even less cost to Duke than cooling towers, this technology could avert the impact on the slough.
The best alternative would be one requiring Duke energy to use a non-polluting, highly sustainable and efficient energy source. Duke could be denied a permit until really sustainable energy is available. It might encourage them to develop such an alternative quickly. The particulate matter created by fossil fuel burning is damaging to water, air, people and equipment. After investigation, I have come to believe that California1s so called power shortages are in fact created by the energy company and their unregulated marketing. We should not be pressured by false shortages into granting Duke Energy a permit. We should insist that the highest standards be upheld for environmental protection.
Another cause for concern is the dredging in the harbor, for which no one seems responsible. This leads to scouring and serious erosion of the slough as well as the depositing of toxic laden materials in the water and wetlands. My understanding is that a screen or sheet could be erected by the Army Corp of Engineers at the opening to the ocean to correct the problem.
Before the permit is granted, this situation must also be rectified.
I am troubled, that while Duke Energy 3cannot afford2 cooling towers, they have given a great deal of 3good neighbor2 money to many organizations. They have been so successful with this practice that there are few organizations or individuals who oppose the permit.Although the Public Utilities Commission keeps track of the contributions of utility companies, power plants do not have to report their contributions to them! The absence of this ethical safeguard has allowed Duke Energy the opportunity to 3make friends2 with all those who might speak against the permit. How can we make the best choices for the water, environment and community when this is the climate for our decisions?
As Duke Energy has not made a friend of me, I rigorously oppose giving them a permit unless and until better solutions are found to significant problems.Lois Robin,
CALIFORNIA COASTAL ACT OF 1976
The basic goals of the California Coastal Act, Pub. Res. Code §3000 et seq., are to protect, maintain, and where feasible, enhance and restore the coastal environment including coastal estuaries, watersheds, wildlife habitats and recreational areas; ensure orderly and balanced utilization and conservation of coastal zone resources; maximize public recreational opportunities consistent with sound resources conservation principals; and ensure priority for coastal-dependent development over other development on the coast.
The California Coastal Act established the California Coastal Commission which is vested with both planning and regulatory authority. Determining whether Federal project activity is consistent with the California Coastal Management Program is one of the responsibilities of the Commission. The Act also established a permitting program which requires the Commission to review and issue coastal development permits for tidelands, submerged lands, and public trust lands.
The Act requires local governments within the coastal zone to develop and implement local coastal plans approved by the Commission. The Commission has the authority to issue all coastal zone permits, until a local coastal program has been at least partially approved.
Once a local coastal program has been approved by the Commission, the Commission retains only appellate authority over locally issued coastal development permits, except for those types of lands listed above. Specific provisions of the Act protect wetlands and other sensitive habitats. These are outlined below. Regulatory/Responsible Agency: California Coastal Commission (CCC).
Section 30240 (a) - "Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values, and only use dependent on such resources will be allowed within such areas."
Section 30230 - "Marine resources shall be maintained, enhanced, and, where feasible, restored. Special protection will be given to areas and species of special biological...significance."
Section 30231 - "The biological productivity and quality of coastal waters, streams, wetlands, estuaries, and lakes appropriate to maintain optimum populations of marine organisms...shall be maintained and, where feasible, restored."
Sections 30007.5 and 30250 - "...protection of resources - including sensitive habitats... has priority over all other land uses.
Crisis Looms in Elkhorn Slough