HomeMy WebLinkAbout2006-06-13; Housing & Redevelopment Commission; Resolution 4191 RESOLUTION NO. 419
2 A RESOLUTION OF THE HOUSING AND
REDEVELOPMENT COMMISSION OF THE CITY OF
3 CARLSBAD, CALIFORNIA, CERTIFYING
4 ENVIRONMENTAL IMPACT REPORT EIR 03-05,
ADOPTING THE CANDIDATE FINDINGS OF FACT,
5 STATEMENT OF OVERRIDING CONSIDERATIONS, AND
THE MITIGATION MONITORING AND REPORTING
6 PROGRAM FOR THE PRECISE DEVELOPMENT PLAN
AND DESALINATION PLANT PROJECT, A PORTION OF
7 WHICH IS LOCATED IN THE SOUTH CARLSBAD
COASTAL REDEVELOPMENT AREA AND GENERALLY IN
8 THE VICINITY OF AGUA HEDIONDA LAGOON, CANNON
Q ROAD, AND THE ENCINA POWER STATION.
CASE NAME: PRECISE DEVELOPMENT PLAN AND
10 DESALINATION PLANT
CASE NO: EIR 03-05
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WHEREAS, on May 3, 2006, the Carlsbad Planning Commission, the
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review body for recommending and processing land use permits proposed in the South
Carlsbad Coastal Redevelopment Area, held a duly noticed public hearing to consider a
15 proposed Environmental Impact Report (EIR 03-05) and adopted Planning Commission
16 Resolution No. 6087, recommending to the Housing and Redevelopment Commission
17 certification of EIR 03-05 and adoption of the Candidate Findings of Fact, Statement of
18 Overriding Considerations, and the Mitigation Monitoring and Reporting Program; and
in
WHEREAS, the Housing and Redevelopment Commission of the City of
20 Carlsbad did on the 13th . day of June . 2006, hold a public hearing to consider the
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recommendations and heard all persons interested in or opposed to EIR 03-05; and
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WHEREAS, a Draft Environmental Impact Report was prepared and
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submitted to the State Clearinghouse and a Notice of Completion filed, published, and
25 mailed to responsible agencies and interested parties providing a 45-day review period;
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1 WHEREAS, all comments received during the review period are contained
2 in the Final EIR; and
3 WHEREAS, following publication of the Final EIR and distribution of
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responses to commenting parties, certain parties continued to submit comments up to
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and including testimony given at the project's public hearing held by the City of Carlsbad
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Planning Commission on the project on May 3, 2006; and
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WHEREAS, in order to address all issues raised by the public on the
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9 proposed project and provide comprehensive disclosure and documentation of
JO environmental issues associated with the project, additional responses to comments
11 were prepared and revisions to the Final EIR were made as shown on attached Exhibit
12 1 and as hereby incorporated into the Final EIR for consideration by the Housing and
13 Redevelopment Commission of the City of Carlsbad; and
14 WHEREAS, the additional responses to comments and revisions to the
Final EIR necessitated new Findings be added to the Candidate Findings of Fact as
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shown on attached Exhibit 2 and as hereby incorporated into the Candidate Findings of
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Fact for consideration by the Housing and Redevelopment Commission of the City of
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Carlsbad; and
20 WHEREAS, the information contained in the additional responses,
21 revisions to the Final EIR, and new Candidate Findings of Fact does not rise to the level
22 of "significant information" as described in California Environmental Quality Act (CEQA)
23 Guideline 15088.5(a). Instead, the information provided merely clarifies and amplifies
discussion already contained in the Final EIR, and provides background information on
25 past policy decisions and direction taken by the City of Carlsbad, primarily with regards
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to water conservation. As such, recirculation of the Final EIR is not required because
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1 the new information added to the EIR only clarifies, amplifies and makes insignificant
2 modifications to an adequate EIR (CEQA Guideline 15088.5(b)).
3 NOW THEREFORE, BE IT RESOLVED by the Housing and
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Redevelopment Commission of the City of Carlsbad, California, as follows:
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1. That the above recitations are true and correct.
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2. The Housing and Redevelopment Commission does hereby find that the
Final EIR 03-05, as modified by Exhibit 1 attached hereto, the Candidate Findings of
Fact, as modified by Exhibit 2 attached hereto, the Statement of Overriding
Considerations, and the Mitigation and Monitoring Program have been prepared in
9 accordance with requirements of the California Environmental Quality Act, the State EIR
Guidelines, and the Environmental Review Procedures of the City of Carlsbad.
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3. The Housing and Redevelopment Commission has reviewed, analyzed,
11 and considered Final EIR 03-05, as modified by Exhibit 1 attached hereto, the
environmental impacts therein identified for this project, the Candidate Findings of Fact,
as modified by Exhibit 2 attached hereto, the Statement of Overriding Considerations,
13 and the Mitigation and Monitoring Program prior to approving the project, and they
reflect the independent judgment of the City of Carlsbad Housing and Redevelopment
14 Commission.
15 4. The Housing and Redevelopment Commission does accept as its own,
incorporate as if set forth in full herein, and make each and every one of the findings
contained in the Candidate Findings of Fact, as modified by Exhibit 2 attached hereto,
17 including feasibility of mitigation measures pursuant to Public Resources Code 21081
and CEQA Guidelines 15091, and infeasibility of project alternatives.
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5. The Housing and Redevelopment Commission hereby finds that the
19 Mitigation and Monitoring Program is designed to ensure that during project
implementation and operation the Developer and any other responsible parties
implement the project components and comply with the feasible mitigation measures
identified in the Candidate Findings of Fact, as modified by Exhibit 2 attached hereto,
and the Mitigation and Monitoring Program.
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6. Although certain significant or potentially significant environmental effects
23 caused by the project will remain, even after the adoption of all feasible mitigation
measures and any feasible alternatives, there are specific economic, social, and other
considerations that render the unavoidable significant adverse environmental effects
acceptable, as set forth in the Statement of Overriding Considerations.
26 7. The Record of Proceedings for this project consists of the Environmental
Impact Report, as modified by Exhibit 1 attached hereto, Candidate Findings of Fact, as
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1 modified by Exhibit 2 attached hereto, Statement of Overriding Considerations, and
Mitigation and Monitoring Program; the "Record" upon which the Housing and
2 Redevelopment Commission bases these Candidate Findings of Fact and its actions
and determinations regarding the project includes, but is not limited to, the Draft EIR,
together with all appendices and technical reports referred to therein, whether
4 separately bound or not; all reports, letters, applications, memoranda, maps, or other
planning and engineering documents prepared by the City and the Housing &
5 Redevelopment Agency (Agency), planning consultant, environmental consultant,
project applicant, or others presented to or before the decision-makers as determined
6 by the City Clerk; all letters, reports, or other documents submitted to the City and the
Agency by members of the public or public agencies in connection with the City's
7 environmental analysis on the project; all minutes of any public workshops, meetings, or
hearings, including the scoping sessions, and any recorded or verbatim
® transcripts/videotapes thereof; any letters, reports, or other documents or other
9 evidence submitted into the record at any public workshops, meeting, or hearings;
matters of common general knowledge to the City and the Agency that the City and the
10 Agency may consider, including applicable State or local laws, ordinances, and policies,
the General Plan, Zoning Ordinance, Local Facilities Management Plans, and all
11 applicable planning programs and policies of the City and the Agency; and, all findings
and resolutions adopted by the City and the Agency in connection with the project,
12 including all documents cited or referred to therein.
13 The custodian of the full administrative record shall be the City Clerk's Office, 1200
Carlsbad Village Drive, and the Planning Director, 1635 Faraday Avenue, both in
14 Carlsbad, CA 92008.
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8. That the Environmental Impact Report (EIR 03-05) on the above
16 referenced project, as modified by Exhibit 1 attached hereto, is certified; and that the
Candidate Findings of Fact, as modified by Exhibit 2 attached hereto, Statement of
17 Overriding Considerations, and the Mitigation Monitoring and Reporting Program are
adopted and that the condition of the Planning Commission contained in Planning
18 Commission Resolution No. 6087, on file with the City Clerk and incorporated herein by
,g reference, is the condition of the Housing and Redevelopment Commission.
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"NOTICE TO APPLICANT"
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"The time within which judicial review of this decision must
22 be sought is governed by Code of Civil Procedure, Section
1094.6, which has been made applicable in the City of
23 Carlsbad by Carlsbad Municipal Code Chapter 1.16. Any
24 petition or other paper seeking judicial review must be filed
in the appropriate court not later than the ninetieth day
25 following the date on which this decision becomes final;
however, if within ten days after the decision becomes final a
26 request for the record of the proceedings accompanied by
the required deposit in an amount sufficient to cover the
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which such petition may be filed in court is extended to not
later than the thirtieth day following the date on which the
record is either personally delivered or mailed to the party, or
his attorney of record, if he has one. A written request for
the preparation of the record of proceedings shall be filed
with the City Clerk, City of Carlsbad, 1200 Carlsbad Village
Drive, Carlsbad, California 92008."
PASSED, APPROVED AND ADOPTED at a Special Meeting of the Housing and
Redevelopment Commission of the City of Carlsbad on the 13th day of June . 2006, by
the following vote, to wit:
AYES: Commissioners Lewis, Kulchin, Packard, Sigafoose
NOES: None
ABSENT: Commissioner Packard
^T^Yy
RAYMOND R. PATCHETT, SECRETARY
(SEAL)
^"''""//,4?—%
£o/ESTABLISHED \tiv . ; ?s »
Exhibit 1
ADDITIONAL RESPONSES TO COMMENTS ON THE
FINAL EIR-03-05 FOR
THE PRECISE DEVELOPMENT PLAN AND DESALINATION
PLANT PROJECT
SCH #2004041081
June 13, 2006
1.0 INTRODUCTION
The Final EIR for the Precise Development Plan and Desalination Plant project contains
a comprehensive disclosure and analysis of potential environmental effects associated
with the implementation of the Precise Development Plan and Desalination Plant project.
In addition, the Final EIR contains responses to public comments received during the
public review period held on the Draft EIR. Following publication of the Final EIR and
distribution of responses to commenting parties, certain parties continued to submit
comments up to and including testimony given at the project's public hearing held by the
City of Carlsbad Planning Commission on the project on May 3, 2006. In order to
address all issues raised by the public on the proposed project and provide comprehensive
disclosure and documentation of environmental issues associated with the project, the
following additional responses to comments are provided and are hereby incorporated
into the Final EIR for consideration by the Carlsbad City Council.
A review of the materials submitted to the City and of the draft minutes of the May 3,
2006, Planning Commission Hearing, identified two primary issues that would benefit
from additional clarification:
1) Operation of the desalination plant independent of the Encina Power Station
(EPS); and,
2) Water conservation as an "alternative" to the proposed project.
2.0 BACKGROUND
Issue 1: Operation of the Desalination Plant as a stand alone facility - separate
from the EPS
The description of baseline conditions and the basis for the analysis in the Final EIR
assumes the continued operation of the Encina Power Station (EPS) within the
parameters of its historical operating conditions. This approach is based on a
determination by the City that such a baseline condition reflects reasonably foreseeable
circumstances, and therefore appropriately characterizes existing baseline conditions, in
accordance with guidance provided by CEQA. Moreover, all relevant city permits
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ADDITIONAL RESPONSES TO COMMENTS ON THE FINAL EIR 03-05 -
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specify that if the desalination plant were to operate independently, Poseidon or its
successors would have to obtain new permits and undergo new CEQA compliance.
Certain public comments received on the EIR reflect different opinions on what is
considered to be "reasonable" relative to assumptions for the continued operation of the
EPS. Certain commentors asserted that shut-down of the EPS is relatively certain within
the foreseeable future. These commentors further assert that the EIR analysis should take
into account operation of the desalination plant under a scenario in which the EPS is no
longer operating. While as noted above, the City believes it is reasonably foreseeable that
EPS will continue to operate, the EIR does contain information that analyzes operation of
the desalination plant in the absence of EPS operation. The following summary and
clarification is provided to demonstrate more clearly that even if the EPS were to shut
down permanently or for extended periods of time, the analysis and conclusions of the
Final EIR are still accurate and valid.
Issue 2: Water Conservation as an "Alternative" to the Proposed Project
Comments received as a result of review of the Draft EIR suggest that additional or more
aggressive water conservation efforts than are now being employed within the City of
Carlsbad and the region could eliminate the need for the proposed project and should be
addressed as an alternative to the proposed project. The EIR contains a discussion of
water conservation efforts and how they relate to the proposed project, and in addition
makes reference to the County Water Authority's Regional Water Facilities Master Plan,
which also includes consideration of water conservation efforts relative to regional water
supply. However, the information presented in these additional responses provides
additional clarification and amplification on this issue.
3.0 CEQA REQUIREMENTS
CEQA Guideline Section 15088.5 states that, where the Final EIR has not yet been
certified, recirculation for public review is not required unless "significant new
information" is added to the document (CEQA Guideline, § 15088.5, subds. [a], [b]).
"Significant new information" requiring recirculation includes, for example, a disclosure
showing that:
(1) A new significant environmental impact would result from the project or
from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would
result unless mitigation measures are adopted that reduce the impact to a
level of insignificance.
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(3) A feasible project alternative or mitigation measure considerably different
from others previously analyzed would clearly lessen the significant
environmental impacts of the project, but the project's proponents decline
to adopt it.
(4) The draft EIR was so fundamentally and basically inadequate and
conclusory in nature that meaningful public review and comment were
precluded.
None of these conditions exist with respect to the information contained in these
additional responses and revisions to the Final EIR. Instead, the information provided
merely clarifies and amplifies discussion already contained in the EIR, and provides
background information on past policy decisions direction taken by the Carlsbad City
Council. This information does not identify any new significant environmental effects,
nor does it identify any increase in a previously identified significant effect. Further,
information provided on project alternatives does not reveal a new alternative that could
feasibly reduce any of the identified significant effects of the project. Therefore,
recirculation is not required because the new information added to the EIR only clarifies,
amplifies and makes insignificant modifications to an adequate EIR (CEQA Guideline,
15088.5, subd. (b)).
4.0 DISCUSSION
Issue 1: Operation of the Desalination Plant as a stand alone facility - separate
from the EPS
The Lead Agency and the Applicant have analyzed the impacts of the project with and
without the operations of the Encina Power Station (EPS). This information is included
in the Final EIR and Appendix E thereto. The resource areas potentially impacted under
the "No Power Plant Operation" scenario are (1) Aesthetics; (2) Air Quality (3) Marine
Biology - brine discharge; (4) Marine Biology - entrainment/impingement; and (5) Land
Use. The baseline used by the lead agency for measuring potential environmental
impacts of the project under CEQA is the current physical environment ("With Power
Plant Operation" scenario), including current operating conditions. However, the worst
case scenario in the Final EIR analyzed the No Power Plant Operation scenario to
determine the level of significance in the "historical extreme." The Final EIR contains
substantial evidence that shows that the impacts from a No Power Plant Operation
scenario to have the same level of significance as the With Power Plant Operation
scenario for all of the impact areas.
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To provide further clarification on the analysis provided for the No Power Plant
Operation scenario, Section 3 of the Final EIR has been revised, and the excerpted text
edits are included in Section 5.0 of these Additional Responses.
Aesthetics - The significance criteria (section 4.1.3) for Aesthetics in the Final EIR do
not take into consideration the surrounding land uses when assessing visual impacts and
thus the significance analysis will not change with or without the power plant in
operation. Section 4.1.4 - Impacts - states that, "the project is not considered to have a
substantial adverse effect on a scenic vista, or a substantially damaging effect on scenic
resources because the proposed structure would represent a visual enhancement over
what is currently located on the site (Page 4.1-3)." This enhancement of the area would
occur with or without the operation of the EPS. Mitigation measures are proposed so that
the project features are acceptable to the City of Carlsbad and conform to the City's long-
term vision for the surrounding property, which includes relocation of the power plant to
the back of the property and the transition of the front of the property to more public uses.
In June of 2002 the Carlsbad City Council, and in October of 2002 the Carlsbad Housing
and Redevelopment Agency, adopted six principals to pursue negotiations for the
purchase of water from Poseidon:
1. Improved water reliability and quality in both normal and drought periods at
CWA [County Water Authority] water rates.
2. Maximize beach and lagoon access for the public.
3. Maximize open space and recreational opportunities for the public.
4. Redevelop Encina Power Plant to maximize its best public and private uses.
5. Desalination facility protected from power market fluctuations.
6. Accrue a positive economic benefit from the increased industrial development
of the coastal corridor.
These principals were used to evaluate the project in addition to the Strategic Goals and
5-Year Vision Statements approved by the City Council. The project was found to be
consistent with goal number 4 shown above (see pages 4.8-16 - 4.8.18 of the Final EIR),
and would therefore not interfere with any future change in operation at the EPS.
Based on the clarification provided in this response, no revisions to the Final EIR text are
considered to be necessary to further clarify aesthetic effects.
Air Quality. The potential indirect air quality impacts due to emissions from power
generation for the desalination facility are analyzed in the Final EIR with and without the
EPS as the source of power. (See page 4.2-18 of the Final EIR). The Final EIR (page
4.2-18) notes that "the desalination plant will not contain any electrical power generation
facilities, and will purchase this electrical power from the local electric utility, or a power
generator, broker or seller. At this time no contract has been signed for power purchases
from any supplier." Because no supplier of electricity has been designated, the Final EIR
ADDITIONAL RESPONSES TO COMMENTS ON THE FINAL EIR 03-05 -
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analyzed the indirect emission impacts from power generation for three different
scenarios: (1) if power were purchased from EPS; (2) the local utility; (3) or another
power provider. The second and third scenario analyzed the No Power Plant Operation
scenario impacts studied in the Final EIR, and therefore there would be no change in the
Final EIR significance findings if EPS were not operational.
Based on the clarification provided in this response, no revisions to the Final EIR text are
considered to be necessary to further clarify air quality effects.
Marine Biology Brine. The Final EIR for the desalination plant used the "historical
extreme" operation and level of salinity to evaluate the impacts to the marine
environment. In Section 4.3, Biological Resources, the Final EIR notes on page 4.3-44
that, "the EPS can run with an "unheated discharge" (i.e., no power plant operation)."
The Final EIR modeled impacts of unheated "historical extreme" for flow scenarios using
a discharge of 254 million gallons per day, which would represent conditions under the
No Power Plant Operation scenario. Therefore the "historical extreme" conditions
modeled account for impacts related to operation of the desalination facility without
power plant operation and flow rates that would be generated by the desalination plant
being operated independently.
On page 4.3-45, the Final EIR notes that in the "historical extreme" the "highest bottom
salinities were noted with the 'unheated' [i.e., No Power Plant Operation scenario]
condition due to its reduced buoyancy." Again on that page, the Final EIR states that,
"...to determine worst-case conditions, the unheated conditions are examined." Therefore
the No Power Plant Operation scenario is the worst case condition studied by the Final
EIR.
The Analysis of Significance - Elevated Salinity Exposure Effects section of the Final
EIR (page 4.3-50) indicates that significant impacts are found at an extended salinity
exposure level of 40 parts per thousand (ppt). The Final EIR (page 4.3-50) indicates that
under the "historical extreme" the end of pipe salinity of 40.1 ppt "...is diluted across the
ZID [zone of initial dilution] to about 38.2 ppt..." Also on page 4.3-50, the Final EIR
concludes that "extended exposure to salinity levels above 40 ppt would be avoided
under all proposed operating conditions (emphasis added)." The Final EIR (page 4.3-51)
goes on to conclude that "since the 'historical extreme' scenarios under all operating
conditions would not result in salinity levels exceeding this threshold for an extended
period of time, impacts related to elevated salinities would not be significant (emphasis
added)."
Therefore the No Power Plant Operation scenario, or "unheated discharge" condition has
been analyzed in the Final EIR and the impacts from brine discharge in this worst-case
scenario were found to be less than significant.
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Based on the clarification provided in this response, no revisions to the Final EIR text are
considered to be necessary to further clarify effects of brine discharge on marine
organisms.
Marine Biology Entrainment. Data presented in Appendix E of the Final EIR (see
Carlsbad Desalination Facility Intake Effects Assessment (draft), dated March 3, 2005,
and prepared by Tenera Enviromental) supports a finding of no significant impact for
entrainment. The referenced study demonstrates that entrainment of marine organisms at
the EPS is a function of the volume of water flowing through the intake. If the
desalination facility were to operate at 106 million gallons per day (MGD) under the No
Power Plant Operation scenario, there would be 100% mortality resulting from
impingement of the larval fish caught on the desalination plant screens and filters (106
MGD represents a total maximum withdrawal volume, which represents a worst case
volume, as compared to the average withdrawal volume of 104 MGD). As shown in
Table 1, the entrainment loss would represent between 0.6% and 11.8% of the EPS
source water supply of larvae, depending on the fish group modeled. Assuming an
additional 200 MGD was allowed to flow through the intake to the discharge channel for
dilution of the concentrated seawater discharge from the desalination facility, there could
be additional entrainment losses. The level of impact to the organisms and associated
mortality due to the diversion of the dilution water under the No Power Plant Operation
scenario will be less than the impact had the water been pumped through the condensers
as is modeled under the With Power Plant Operation scenario. However, lacking data to
document actual mortality under the No Power Plant Operation scenario mode of
operation, the possible range is 0% to 100% mortality of the larval fish in the dilution
water. Under these conditions the minimum larval fish entrainment loss for the
desalination facility (106 MGD) and associated dilution water (200 MGD) would be
0.6% to 11.8% and the maximum would be 1.7% to 34.1%, depending on the design of
the facility and species modeled. (Table 1).
Table 1
Desalination Facility's Estimated Entrainment Loss
Under No Power Plant Operation
Fish Group
CIQ gobies
Desalination
Facility
Entrainment
Loss
11.8%
Dilution Water
Entrainment
Loss
0%-22.3%
Minimum
Combined
Entrainment
Loss
11.8%
Maximum
Combined
Entrainment
Loss
34.1%
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Combtoothblennies 5.7% 0%-10.8% 5.7% 16.5%
Northern anchovy 0.6% 0%-1.1% 0.6% 1.7%
Significance of Entrainment Losses. The loss of larval fish entrained by the EPS
cooling water flows, whether the EPS is operating or not, are a small fraction of marine
organisms from the abundant and ubiquitous near-shore source water populations. Using
standard fisheries models for adult fishes, the loss of larvae (99 percent of which are lost
to natural mortality) due to the desalination facility entrainment at 306 MGD would have
no effect on the species' ability to sustain their populations, including the gobies at
34.1%. As noted in Table 1 above, gobies are not substantially impacted because of their
widespread distribution and high reproductive potential due to spawning several times a
year and are able to sustain conditional larval stage mortality rates of 34% and higher
without a decline in adult population level. This absence of population level effects for
adult gobies is especially true for the species' early larval stages. The sheer numbers of
larvae that are produced by the adult gobies are resistant to the effects of both natural
mortality and reasonably high levels of conditional mortality.
The most frequently entrained species are very abundant in the area of EPS intake, Agua
Hedionda Lagoon, and the Southern California Bight so that the actual ecological effects
due to any additional entrainment from the project at either level of plant operations are
insignificant. Species of direct recreational and commercial value constitute a very small
fraction (less than 1 percent) of the entrained organisms. Therefore, the operation of the
desalination facility does not cause a significant ecological impact. California
Department of Fish and Game (2002) in their Nearshore Fishery Management Plan
provides for sustainable populations with harvests of up to 60 percent of unfished adult
stocks. The incremental entrainment ("harvest") effect of larval fishes from the
desalination facilities operations at 106 or 306 MGD is approximately 1 to 34 percent
(depending on the species); losses that would have no significant effect on the source
water populations to sustain themselves. Additionally, entrainment mortality losses are
not harvests in the common sense, because the larval fish are not removed from the
ocean, but are returned to supply the ocean's food webs - the natural fate of at least 99
percent of larvae whether entrained or not. Generally less than one percent of all fish
larvae become reproductive adults.
Revisions to the Final EIR text have been made to provide additional clarification on
entrainment effects under the No Power Plant Operation scenario. Excerpts of the
revised text are included in Section 5.0 of these Additional Responses.
Marine Biology Impingement. The Applicant has calculated the approach velocity of
the water flowing through the EPS intake under the No Power Plant Operation scenario
and determined that the velocity would not exceed 0.5 feet per second. Under these
ADDITIONAL RESPONSES TO COMMENTS ON THE FINAL EIR 03-05 -
PRECISE DEVELOPMENT PLAN AND DESALINATION PLANT PROJECT
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operating conditions, the intake would meet impingement mortality performance
standards established in the revised 316(b) permitting requirements.
Revisions to the Final EIR text have been made to provide additional clarification on
impingement effects under the No Power Plant Operation scenario. Excerpts of the
revised text are included in Section 5.0 of these Additional Responses.
Land Use - The proposed project causes no significant impacts to land use and is
consistent with existing land use plans with or without the existence and operation of the
EPS. The project is consistent with the Public Utilities (U) land use designation in the
General Plan and Zoning Ordinance and is consistent regardless of power plant
operations.
In addition the project is consistent with the South Carlsbad Coastal Redevelopment Plan
for the area and would continue to be consistent regardless of the operation of the power
plant. The Final EIR (page 4.8-16) notes that, "The site of the desalination plant was
specifically selected so as not to conflict with two redevelopment plan goals. The first
goal relates to facilitating the conversion and possible relocation of the existing power
plant to a smaller more efficient facility. The second goal relates to the enhancement of
commercial and recreational opportunities in the plan area." Although any changes in
the power plant configuration will require additional environmental review and approval,
a siting study was conducted for the desalination plant in which five sites within the EPS
property were reviewed to find a location for the desalination facility that was sensitive to
the redevelopment plan goal and would "create the least amount of constraints on any
future conversion of the Encina Power Station." (See pages 4.8-16 - 4.8.18 of the Final
EIR for details.) Therefore any future changes to the EPS will not be affected by the
siting of the desalination plant.
Based on the clarification provided in this response, no revisions to the Final EIR text are
considered to be necessary to further clarify land use effects
Issue 2: Water Conservation/Recycled Water Only and Increased
Conservation/Recycled Water as "Alternatives" to the Proposed
Project
As discussed in Section 9 of the Final EIR (pages 9-1 to 9-7), a baseline assumption
incorporated in the Final EIR analysis is that the water conservation and water recycling
elements included in Carlsb ad Municipal Water District's 2000 Urban Water
Management Plan (UWMP) and San Diego County Water Authority's 2004 Regional
Water Facilities Master Plan (RWFMP) will be fully implemented. However, even with
the targeted conservation and recycling in place, both the San Diego County Water
Authority (CWA) and Carlsbad Municipal Water District (CMWD) identified a need for
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additional local water in an amount equal to or greater than the project capacity. The
update to the 2000 UWMP, approved in December 2005, continues to identify that need.
The RWFMP projected that in 2002, approximately 13,700 acre-feet of recycled water
was used within CWA's service area annually. This number is projected to increase to
over 53,000 acre feet per year by 2020. As noted in the Final EIR, while conservation is
not technically a water supply "source", it is also an important strategy employed within
the region to reduce demand for water supply. Water conservation programs are
maintained by MWD, CWA and local water agencies.
Even though the Final EIR references the role of conservation and recycling in local and
regional water supply management and the policy direction that has been pursued relative
to water conservation and recycling, certain commenting parties indicated that additional
conservation/recycling should be considered as a project alternative. A discussion of
water conservation and recycling efforts is provided in the Final EIR to further clarify
how conservation was a consideration that helped shape policy that relates to the
proposed project. Specifically, consideration of water conservation and recycling as
alternatives to the proposed project has been given in past policy making. However, the
level of water conservation and recycling necessary to replace the need for the proposed
project has been rejected as alternatives to the project primarily for public policy reasons
that are further explained in the Final EIR.
Section 15126.6(c) of the CEQA Guidelines provides for discussion of any alternatives
that were considered by the lead agency but were rejected as infeasible. Additionally,
Section 15132(e) states that a Final Environmental Impact Report may consist of "any
other information added by the Lead Agency." Staff has included revisions to the Final
EIR text to provide additional clarification on the rationale for rejection of alternatives to
the proposed project that involve additional conservation and/or recycling. The revised
text is included in Section 5.0 of these Additional Responses.
5.0 FINAL EIR TEXT EDITS
The following are excerpts of portions of text from the EIR that have been revised as a
result of these Additional Responses. Revisions that have been made as a result of these
Additional Responses are noted in strike-through (deletions) and underline (additions)
text.
The following text replaces text that appears in Section 3.3 of the EIR (Starting on Page 3-14, under
the Subheading "Power Plant Baseline Operating Conditions"):
Power Plant Baseline Operating Conditions
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The PDF will not modify the Encina power plant's permitted operating capacity.
However, the following information is provided to accomplish the City's objective of
establishing baseline conditions for identifying existing facilities and operations on site
for the purpose of increasing knowledge and understanding about station operation and
onsite facilities. It should be noted this project does not include any modifications that
would affect the power plant's operating capacity.
Power generation capacity, as described in the NPDES Permit, is provided by a total of
six power generator units1:
• Unit 1-107 megawatts (MW)
• Unit 2-104 MW
• Unit 3-110 MW
• Unit 4 - 287 MW
• Unit 5-315 MW
• Gas Turbine-16 MW
All of these generating units have been designated as "Reliability Must Run" (RMR) by
fythe ISO. The RMR Generation designation represents the minimum generation (number
of units or MW output) required by the ISO to be available to maintain system reliability.
At full production output, the Encina power plant has the capability to directly or
indirectly serve roughly half of the power demand for San Diego County.
Units 1 through 5 are steam turbine generators, each with its own boiler that generates
heat up to 1005 degrees Fahrenheit. Purified water runs through the boilers turning to
high-pressure steam that is used to spin the turbines to generate electricity. The plant
relies on seawater to cool and condense the steam after its energy is expended spinning
the turbine. Seawater flows into the Agua Hedionda Lagoon through the jetty west of
Carlsbad Boulevard into the outer lagoon and into an intake channel located at the
southwestern end of the lagoon. The seawater is then pumped into condensers to
condense the steam on a non-contact heat transfer basis, and then is returned to the ocean
via a discharge channel located to the south of the lagoon's confluence with the ocean.
The power plant cooling water discharge is regulated under a National Pollutant
Discharge Elimination System (NPDES) permit, issued with the Regional Water Quality
Control Board. The plant is currently permitted to discharge a maximum of
1 NPDES Permit, Order No. 2003-03, Regional Water Quality Control Board, February 16, 2000.2 California Independent System Operator website: www.caiso.com, accessed July 29,2004.
6°\
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approximately 860 million gallons per day (mgd) of cooling water. For purposes of this
analysis, data for power plant operation includes records dating from 1980 to 2000. The
generators identified above were phased in from the plant's initial construction in 1952
through 1978. Therefore, the dataset used in the EIR analysis represents operation of all
production units, and is considered to provide data representing the current operational
characteristics from which to analyze existing baseline conditions. With that being said
however, the analysis of effects associated with seawater intake and discharge are
evaluated based on conditions that represent two separate scenarios, with and without
operation of the EPS. The average cooling water discharge rate over the 20-year period
was 576 mgd. Daily average flow rates have not fallen below 304 mgd in the 20-year
dataset. As noted in the analysis presented in Section 5 of this EIR, the 304 mgd flow rate
is used as the worst case operating condition, under the assumption that the discharge is
"unheated". which therefore represents conditions without operation of the EPS. For
purposes of this discussion, this scenario is referenced as the "No Power Plant Operation"
scenario.
The following text replaces text that appears in Section 4.3.4 of the EIR (Starting on Page 4.3-35,
under the Subheading "Impingement Effect"):
Impingement Effect
• The desalination plant operation does not require the power plant to increase the
quantity of water withdrawn nor does it increase the velocity of the water
withdrawn.
• The Carlsbad Desalination Plant will not have a separate direct lagoon or ocean
intake and screening facilities, and will only use cooling water that is already
screened by the EPS intake.
• Under the No Power Plant Operation scenario, approach velocity of the water
flowing through the EPS intake would not exceed 0.5 feet per second. Under
these operating conditions, the intake would meet impingement mortality
performance standards established in the revised 316(b) permitting requirements.
• Therefore, the Carlsbad Desalination Plant will not cause any additional
impingement losses to the marine organisms impinged by the EPS, under the
assumed baseline EPS operating conditions, and would not result in significant
impingement effects under the No Power Plant Operation scenario.
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The following text replaces text that appears in Section 4.3.4 of the EIR (Starting on Page 4.3-36,
under the Subheading "Entrainment Losses"):
Entrainment Losses
• Based on in-plant testing, the average observed entrainment mortality of the
power plant was 97.6 percent (2.4 percent survival). Living fish larvae entrained
by the Carlsbad desalination plant would represent an incremental loss of
approximately 0.01 to 0.28 percent of the larvae present in the power plant source
water, assuming continued operation of the EPS. Under the No Power Plant
Operation scenario, living fish larvae entrained by the Carlsbad desalination plant
would represent a loss of approximately 0.6% to 34.1% of the source populations,
depending on the final design of the desalination facility and on the species.
The cooling water intake structure is part of the EPS existing operations and is presently
regulated under Section 316(b). The desalination plant feedwater withdrawal does not
include a cooling water intake structure. Therefore, it is not subject to intake regulation
under the Federal Clean Water Act (CWA) Section 316(b). However, since the
desalination plant will withdraw intake seawater from the EPS discharge flow, the study
was conducted consistent with the intent of Section 316(b), which requires that baseline
conditions be established. The desalination plant feedwater intake will not increase the
volume, nor the velocity of tho EPS cooling water intake nor will it increase the number
of organisms entrained or impinged by the EPS cooling water intake structure.
Therefore, the project would not result in any additional impingement effects of the EPS
and therefore, impingement effects are not considered as significant impacts attributable
to desalination plant operations.For purposes of this analysis, baseline conditions reflect
quantities of larvae present in the sewater intake, regardless of whether the EPS is in
operation or not.
Study Methodology: The study required an assessment of both the source water for the
EPS (lagoon and ocean) and the discharge from the EPS (the desalination plant's
feedwater supply). The source water was analyzed to establish population characteristics
(relative abundance) for species potentially impacted by the desalination plant. The
desalination plant feedwater was characterized to determine the baseline conditions for
potential impacts associated with the desalination facility. Specifically, the feedwater
characterization examined the type and quantity of organisms that survive entrainment
through the EPS cooling water intake structure that could subsequently be impacted by
the desalination plant operations.
(01
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The EPS source water was partitioned into lagoon and nearshore ocean areas for
modeling purposes; ten sampling stations were chosen so that all source water
community types would be represented, including five lagoon stations and five nearshore
stations. Samples were also collected from EPS's discharge (desalination plant feedwater
supply) just before the water flows into the power station's discharge pond.
Laboratory processing for both the feedwater and source water consisted of sorting
(removing), identifying, and enumerating all larval fishes, pre-adult larval stages of
Cancer spp. crabs, and California spiny lobster larvae from the samples. Identification of
larval fishes was done to the lowest taxonomic level practicable.
Source Water Larval Abundance Estimates: Data collected from three source water
surveys conducted on June 10, June 24, and July 6, 2004, included a total of 27,029 larval
fishes, with 4,750 specimens collected from the five nearshore stations and the remaining
22,279 specimens from the lagoon stations. Two taxa comprised 84 percent of the total
number of larval fishes collected from all surveys and source water stations combined:
three species from the goby family (Clevelandia ios, Ilypnus gilberti, Quietula y-caudd)
hereinafter referred to as CIQ gobies comprised 65 percent and combtooth blennies
(Hypsoblennius spp.) comprised 19 percent. In addition, four species of target
invertebrates were collected in the samples from both the lagoon and nearshore sampling
stations: California spiny lobster (Panulirus interruptus, 93 specimens), yellow rock crab
(Cancer anthonyi, 31 specirriens), brown rock crab (Cancer antennarius, 4 specimens),
and slender crab (Cancer gracilis, 2 specimens).
The mean concentration of CIQ goby larvae from all source water stations and surveys
combined was approximately 4,900/1,000 m3 and the mean concentration of combtooth
blennies was approximately 1,200/1,000 m3.
Feedwater (EPS Discharge) Larval Abundance Estimates: A total of 1,648 fish larvae
was collected during two surveys of the EPS discharge water conducted on June 16 and
July 6, 2004 (Table 4.3-3). Four taxa comprised 95 percent of all of fish larvae in the
EPS discharge flows from which the proposed desalination plant would withdraw its
feedwater supply. They were combtooth blennies, CIQ gobies, labrisomid kelpfishes
(Labrisomidae unid.), and garibaldi (Hypsypops rubicundus). Gobies and blennies
combined accounted for nearly 72 percent of the larvae identified in the feedwater. No
target invertebrate larvae were found in any of the samples from the EPS discharge.
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TABLE 4.3-3
Total Counts and Mean Concentrations of Larval Fishes from EPS Discharge
Mean
Concentration
Taxon Common Name Total Count Percent Cum. Percent (#/1 ,000m3)
Hypsoblennius spp.
CIQ gobies
Labrisomidae unid.
Hypsypops rubicundus
Rimicola spp.
Gibbonsia spp.
Engraulidae
Gobiesocidae unid.
Sciaenidae
Blennioidei
Atherinopsidae
larval/post-larval fish unid.
Heterostichus rostratus
Syngnathus spp.
Paralichthys califomicus
Chaenopsidae unid.
Labridae
larvae, unidentified yolksac
Typhlogobius californiensis
Agonidae unid.
combtooth blennies
CIQ goby complex
labrisomid kelpfishes
garibaldi
kelp clingfishes
clinid kelpfishes
anchovies
clingfishes
croakers
Blennies
Silversides
giant kelpfish
Pipefishes
California halibut
Clinids
Wrasses
blind goby
Poachers
766
426
205
174
13
12
12
8
8
7
6
3
1
1
1
1
1
1
1
1
46.48%
25.85%
12.44%
10.56%
0.79%
0.73%
0.73%
0.49%
0.49%
0.42%
0.36%
0.18%
0.06%
0.06%
0.06%
0.06%
0.06%
0.06%
0.06%
0.06%
46.48%
72.33%
84.77%
95.33%
96.12%
96.84%
97.57%
98.06%
98.54%
98.97%
99.33%
99.51%
99.58%
99.64%
99.70%
99.76%
99.82%
99.88%
99.94%
100.00%
1,119.89
630.94
291.66
230.14
17.54
16.38
15.83
10.15
11.38
9.21
7.36
3.50
1.14
0.92
1.28
0.92
1.28
2.45
1.96
2.19
Total 1,648
Feedwater Larval Survival Results: Eleven surveys to estimate the survival of larval
fishes in the EPS discharge flow were conducted from June through November 2004. A
total of 1,989 fishes was collected from the eleven surveys (Table 4.3-4). Larvae that
were alive immediately after collection were placed in separate containers and observed
for up to three hours after collection. Approximately half of the larvae continued
swimming for up to two hours after collection while the others died between 0.5-1.5
hours after collection. The species of larvae that survived entrainment and sampling were
CIQ gobies, combtooth blennies, and unidentified clingfishes. The highest concentration
of larval fishes (2,444/1,000 m3) was collected July 6, 2004, and the lowest concentration
(93/1,000 m3) was collected on October 21, 2004.
4)3
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The average survey percent survival ranged from 0 percent (November 2 survey) to
9.2 percent (November 30 survey) (Table 4.3-4). The overall average percent survival
based on an average of survival data from each sample containing fish (n=223 out of a
291 total surveys) is 2.40 percent with a standard deviation of 11.22. The average
percent survival based on each survey's (n=ll) average survival data is 2.71 with a
standard deviation of 11.24 among survival averages for the 11 surveys. The surviving
larvae that enter the desalination plant will be retained on the pretreatment filters, which
could be either granular media facilities or membrane filters. The retained organisms will
be removed from the pretreatment filters with the filter media backwash.
TABLE 4.3-4
Summary Of Larval Fish Data Collected During In-Plant Survival Studies
From EPS Discharge Flows During June Through November 2004.
Average Larval Fish Average %
Number of Total Volume
Date Collected Samples1 Filtered (m3)
Concentration (#/1,000 m3) Total # Total # Alive Survival per
per Survey2
(s.d. in parenthesis)
Larvae upon
Collected Collection
Survey3
(s.d. in
parenthesis)
6/16/2004
7/06/2004
7/20/2004
8/13/2004
8/26/2004
8
9
30
30
32
117
112
301
339
284
1,289.4
(754.2)
2,443.8
(875.0)
1,053.3
(674.6)
564.4
(632.9)
415.4
(350.9)
140
276
315
192
112
2
13
7
2
1
1.8
(4.7)
4.3
(4.1)
1.6
(4.0)
0.005
(0.02)
0.6
(3.2)
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9/09/2004
9/23/2004
10/21/2004
11/02/2004
11/18/2004
11/30/2004
31
30
31
30
30
30
342
344
347
257
271
216
2,027.5
(2,246.4)
668.8
(1,134.6)
93.0
(123.9)
182.3
(161.9)
132.9
(166.7)
264.5
(291.6)
590
200
31
47
34
52
4
2
1
0
2
4
0.5
(1.8)
1.2
(5.5)
5.9
(24.3)
0
4.6
(13.8)
9.2
(24.2)
1. The number of samples per survey increased beginning July 20, 2004 when the duration of sampling increased to cover 24-
hour periods.
2. The average larval fish concentration per survey was calculated by summing the individual sample concentrations and dividing
by the number of samples in each survey.
3. The average percent survival per survey was calculated by summing the individual sample survival percentages and dividing
by the number of samples containing fish larvae in each survey.
In order to assess any potential effects of the desalination facility feedwater withdrawal
on local fishery resources, three taxa were selected: CIQ goby complex, combtooth
blennies, and northern anchovy. These taxa were some of the most commonly entrained
species in the EPS cooling water intake structure or were species (northern anchovy) that
may be of interest to fishery managers. Larvae of species with high value to sport and
commercial fisheries such as California halibut were entrained in such low numbers
(approximately 0.06 percent of the total number of EPS-entrained larvae) that any effects
on source water populations of these species could not be modeled.
Entrainment Effects Model: The Empirical Transport Model (ETM) used in the analysis
is based on principles used in fishery management. To determine the effects of fishing on
a population, a fishery manager needs an estimate of the number of fishes in the
population and the number of fishes being removed by the fishery. ETM is
recommended and approved by the California Energy Commission (CEC), California
Coastal Commission (CCC), Regional Water Quality Control Boards and other
regulatory and resources agencies for analyzing impacts to fisheries. This assessment
assumes 100 percent mortality of all organisms surviving the EPS upon withdrawal into
the desalination facility.
The ETM first takes the estimate of daily mortality (also known as Proportional
Entrainment (PE)), and expands the estimate over the number of days the larvae from a
single cohort, or batch of larvae, would be exposed to entrainment. The ETM thereby
predicts regional effects on appropriate adult populations. Finally, the effects of
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entrainment are examined in the context of survival data collected from the EPS
discharge.
The estimate of daily incremental mortality, or proportional entrainment (PE), was
computed as the ratio of the number of larvae in the water withdrawn by the proposed
facility to the number of larvae in the surrounding source water. The average
concentration of larvae in the feedwater, as noted in Table 4.3-4, was multiplied by
desalination facility's maximum feedwater withdrawal volume of 401,254 m3/day (106
mgd). A total maximum withdrawal volume of 106 mgd (as compared to average
withdrawal of 104 mgd) was used as a worst case volume, under a scenario where
maximum backwash water volumes would be used during a period of maximum RO
production.
Average concentrations of larval fishes from the source water survey data were
multiplied by the volume estimates for each of the water body segments (total of three
lagoon and nine nearshore areas) and then combined to estimate the average source water
population.
The estimated effects of withdrawal for desalination operations on a single cohort of
larvae were calculated using the ETM as: PM = 1 — (1 — PE) ratt°", where Pm is the
proportional level of mortality resulting from the water withdrawals by the proposed
desalination facility. A larval duration of 23 days from hatching to entrainment was
calculated from growth rates using the length representing the upper 99th percentile of the
length measurements from larval CIQ gobies collected from entrainment samples during
316(b) studies (Tenera 2004).
The results of the analysis are contained in Table 4.3-5. Estimates of PE ranged from
0.01 percent for northern anchovy to 0.55 percent for CIQ gobies.
TABLE 4.3-5
Estimates of Average Daily Mortality (PE)
(Standard Error in parentheses)
Feedwater Volume - Maximum Flow
Fish Group 401,254 m3/day (106 MGD)
CIQ gobies
Combtooth blennies
0.55% (2.08)
0.36% (0.87)
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Northern anchovy 0.01% (0.05)
Fish larvae entrained by desalination plant represent an incremental loss of the EPS
source water supply of larvae. The average observed entrainment mortality of the EPS
was 97.6 percent (2.4 percent survival). Since 97.6 percent of the larvae are dead at the
point of the desalination plant intake, the incremental entrainment loss on source water
populations is the 2.4 percent survival rate times the desalination plant proportional
entrainment for each specific species in the EPS discharge. These incremental effects
range from 0.01 percent for northern anchovy to 0.28 percent for CIQ gobies
(Table 4.3-6). The incremental mortality assumes 100 percent mortality of all organisms
surviving the EPS upon withdrawal into the desalination facility. However, under the No
Power Plant Operation scenario, no mortality is attributed to EPS operations and all
entrainment effects are assigned to the desalination plant.
TABLE 4.3-6
Estimates of Proportional Mortality (Pm)
Fish Group
Pm based on Maximum Length
at Entrainment
Desalination Plant Entrainment
from EPS Discharge Flow
Maximum flow -106 MGD
(401,254m3/day)
Estimate When Applying The Pm Based on No Power
Overall Average Survival Plant Operation
Estimate Of 2.4 Percent1 Scenario
Incremental Entrainment Loss Desalination Plant
Due to Desalination Plant Entrainment with
Operations Maximum flow - 306
Maximum flow-106 MGD MGD
(401,254m3/day)
CIQ gobies
Combtooth blennies
Northern anchovy
11.8%
5.7%
0.6%
0.28%
0.14%
0.01%
34.1%
16.5 %
1.7%
The overall average percent survival (2.4 percent with a standard deviation of 11.22) was based on an
average of each sample that contained fish (n=223).
bl
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The role of turbulence and temperature and how larvae are affected were not evaluated at
the EPS. It is noted that mortality from entrainment through the cooling water intake
structure may be primarily due to pressure and turbulence in the water flow, rather than
temperature increases resulting from the cooling operation. Since the desalination plant
feedwater will be subject to the same turbulence whether or not the EPS is operating, it is
reasonable to estimate incremental mortality for the heated and unheated desalination
scenarios using the survival data presented in Table 4.3-4 Using those data, and based on
typical operation of the EPS, the entrainment loss rate ranges from 0.01 percent to 0.28
percent.
If the desalination facility were to operate at 106 million gallons per day (MOD) under
the No Power Plant Operation scenario, there would be 100% mortality resulting from
impingement of the larval fish caught on the screens and filters. The No Power Plant
Operation scenario would increase the flow volume attributable to the desalination plant
by an additional 200 MOD for dilution of the concentrated seawater discharge from the
desalination facility. The level of impact to the organisms and associated mortality due
to the diversion of the dilution water under the No Power Plant Operation scenario will
be less than the impact had the water been pumped through the condensers as is modeled
under the With Power Plant Operation scenario. However, lacking data to document
actual mortality under the No Power Plant Operation scenario, the possible range is 0% to
100% mortality of the larval fish in the dilution water. Under these conditions the
minimum larval fish entrainment loss for the desalination facility (106 MOD) and
associated dilution water (200 MOD) would be 0.6% to 11.8% and the maximum would
be 1.7% to 34.1%. depending on the design of the facility and species modeled. (Table
4.3-6).
Although combtooth blennies had higher PE estimates, CIQ gobies had higher estimates
of Pm because their larvae were exposed to entrainment for a longer period of time (either
from multiple spawnings of one species or from different species spawning at different
times). Adult CIQ gobies and combtooth blennies are very common in Agua Hedionda
Lagoon habitats and these levels of mortality would not be expected to result in any
population-level effects because these fishes are adapted to estuarine environments where
large percentages of their larvae are exported into nearshore areas during tidal flushing.
Gobies are abundant in the shallow mudflat and eelgrass habitats that are common in
Agua Hedionda middle and inner lagoons. A significant proportion of the CIQ goby
larvae in the outer lagoon at the point of entrainment likely originated in the inner and
middle lagoon segments and would be exported from the lagoon system on the following
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tidal cycle. Adult combtooth blennies are common in outer lagoon habitats including
rock jetties, docks, pilings, and aquaculture floats, as well as some sandy areas in the
lagoon, which explains the large numbers of the larvae found in the EPS discharge flows.
The estimates for northern anchovy are much lower than the other two taxa because they
are more common in the nearshore areas than the lagoon. In fact, the estimates for
northern anchovy are very conservative because these fish are distributed over a large
area and therefore the estimate of their source water population would be much larger
than the estimate used in the calculation of PE.
Significance of Entrainment Losses: The small proportion of marine organisms lost to
entrainment as a result of the desalination plant would not have a substantial effect on the
species' ability to sustain their populations because of their widespread distribution and
high reproductive potential. The most frequently entrained species are very abundant in
the area of EPS intake, Agua Hedionda Lagoon, and the Southern California Bight, and
therefore, the actual ecological effects due to any additional entrainment from the
desalination plant are less than significant. California Department of Fish and Game
(2002) in their Nearshore Fishery Management Plan provides for sustainable populations
with harvests of up to 60 percent of unfished adult stocks. The incremental entrainment
(or "harvest") effect of larval fishes from the desalination plant operations between 0.01
and 0.28 percent up to 34.1% under the No Power Plant Operation scenario depending on
the design of the facility and species modeled.
The loss of larval fish entrained by the EPS cooling water flows, whether the EPS is
operating or not, are a small fraction of marine organisms from the abundant and
ubiquitous near-shore source water populations. Using standard fisheries models for
adult fishes, the loss of larvae (99 percent of which are lost to natural mortality) due to
the desalination facility entrainment at 306 MGD would have no effect on the species'
ability to sustain their populations, including the gobies at 34.1%. Gobies are not
substantially impacted because of their widespread distribution and high reproductive
potential due to spawning several times a year, are able to sustain conditional larval stage
mortality rates of 34% and higher without a decline in adult population level. This
absence of population level effects for adult Robies is especially true for the species' early
larval stages. The sheer numbers of larvae that are produced by the adult gobies are
resistant to effects of both natural mortality and reasonably high levels of conditional
mortality.
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The most frequently entrained species are very abundant in the area of EPS intake, Agua
Hedionda Lagoon, and the Southern California Bight so that the actual ecological effects
due to any additional entrainment from the project at either level of plant operations are
insignificant. Species of direct recreational and commercial value constitute less than 1
percent of the entrained organisms, and considering the fact that in general, less than one
percent of all fish larvae become reproductive adults, the operation of the desalination
plant would not result in significant impacts on those species. California Department of
Fish and Game (2002) in their Nearshore Fishery Management Plan provides for
sustainable populations with harvests of up to 60 percent of unfished adult stocks. The
incremental entrainment ("harvest") effect of larval fishes from the desalination facilities
operations at 106 or 306 MOD is approximately 1 to 3 4 percent (depending on the
species): losses that would have no significant effect on the source water populations to
sustain themselves. Additionally, entrainment mortality losses are not harvests in the
common sense, because the larval fish are not removed from the ocean, but are returned
to supply the ocean's food webs - the natural fate of at least 99 percent of larvae whether
entrained or not. Generally less than one percent of all fish larvae become reproductive
adults.
The following text replaces text that appears in Section 6.0 of the EIR (Starting on Page 6-1):
SECTION 6.0
ALTERNATIVES TO THE PROPOSED ACTION
In order to fully evaluate proposed projects, CEQA requires that alternatives be
discussed. Section 15126.6 of the State CEQA Guidelines requires the discussion of "a
range of reasonable alternatives to the project, or to the location of the project, which
would feasibly attain most of the basic objectives of the project but would avoid or
substantially lessen any of the significant effects of the project, and evaluate the
comparative merits of the alternatives." The alternatives discussion is intended to "focus
on alternatives to the project or its location which are capable of avoiding or substantially
lessening any significant effects of the project, even if these alternatives would impede to
some degree the attainment of the project objectives as listed in Section 3.0 of this EIR.
The alternatives discussion focuses on the desalination plant aspect of the PDF.
The Alternatives discussion in this EIR focuses on four project alternatives: a No
Project/No Development Alternative, an Alternative Site Location Alternative, a
Modified Intake Design Alternative, and a Reduced Project Capacity Alternative.
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Along with the Alternatives identified in this Section, previous consideration has been
given to policy options that are discussed as alternatives that have been considered and
rejected for the purposes of this EIR. These alternatives include the Recycled Water
Only Alternative and Increased Water Conservation/Recycled Water Alternative. These
alternatives are not currently considered to be feasible project alternatives, and for that
reason, are not put forward as alternatives that the City Council may select as alternatives
actions to project approval. However, based on comments received on the EIR, the City
of Carlsbad believes it important to emphasize and clarify past policy decisions relative
to water recycling and conservation, and how those water management strategies relate to
the proposed project.
Alternatives Considered but Rejected as Infeasible
Section 15126.6(c) of the CEOA Guidelines provides for discussion of any alternatives
that were considered by the lead agency but were rejected as infeasible. The alternatives,
identified as the Recycled Water Only Alternative and Increased Water
Conservation/Recycled Water Alternative, have been considered in past decision making
by the City and both have been determined to be infeasible, because they require
recycling and conservation practices that go beyond what is considered to be acceptable
from a public policy perspective. The following discussion provides information that
explains how water recycling and conservation have and will continue to play an
important role in local and regional water management. This discussion is also intended
to provide a framework for understanding past policy decisions that limit the extent to
which recycling and conservation can be taken without causing unacceptable social and
economic effects.
Water conservation and recycling has long been a part of local and regional water supply
strategies. Conservation and recycling involve social and economic impacts that are
given consideration by policy makers in terms of how much these strategies are feasibly
able to contribute to reducing and/or satisfying demand.
The Department of Water Resources' draft California Water Plan Update 2005
acknowledges that local efforts to conserve and reuse water must continue to be
implemented and new water supplies must be developed (including up to 500,000 acre-
feet of desalination) to ensure an adequate water supply for California's future.
(California Water Plan Highlights, page 15.) Update 2005 states that if recent growth
trends continue, water conservation and reuse alone will not be adequate to meet
Southern California's future needs. More than 600,000 acre-feet of new supply will be
needed to meet the South Coast region's needs by the year 2030.
"7
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The San Diego County Water Authority's Regional Water Facilities Master Plan has
projected that an additional one million people will be added to the county over the next
three decades. To keep up with this growth, it is expected that by 2020 water demands
will grow by 107,000 acre feet (AF) over 2005 total projected demands to 813,000 acre
feet per year (AFY). The contribution from water conservation efforts account for
54,900 AFY of estimated reduced demand today and is expected to grow by nearly 75%
to a potential 93,200 AFY in reduced demand over the next 15 years. The increased
demand projection of 107,000 AFY is net of the 93.200 AFY of projected savings due to
ongoing and planned water conservation efforts, but still requires additional supply to
meet the demands of growth in the region.
The City of Carlsbad currently imports 100% of its potable water supply. The City of
Carlsbad's pursuit of seawater desalination is in direct response to growing concern over
water supply reliability. This concern is driven by several factors, including climate,
limited surface and groundwater supplies, expected population growth, and decreasing
reliability of imported water resources stemming from the Colorado River 4.4 Plan and
QSA, Sacramento-San Joaquin Bay-Delta Accord, and other regional, state and federal
water issues. Conservation programs defer or limit the rate of demand for water:
however, these programs cannot reliably address the City's long-term water supply
needs.
The Carlsbad Municipal Water District ("CMWD") considered a variety of actions to
improve its water supply reliability, diversify supplies, and reduce dependence on
imported water. These actions include a commitment to implement all cost-effective
water conservation and recycling opportunities. Today, CMWD has one of the most
aggressive conservation and recycling programs in the San Diego region.
CMWD is also a signatory to the California Urban Water Conservation Council
Memorandum of Understanding ("MOU"). Signatories to the MOU implement 14 Best
Management Practices that have received a consensus among water agencies and
conservation advocates as the best and most realistic methods to produce significant
water savings from conservation.
Conservation on a local level is implemented through strategies identified in the Urban
Water Management Plan (UWMP). The goals of the City's water conservation program
are to: reduce demand for more expensive, imported water: demonstrate continued
commitment to the Urban Best Management Practices (BMPs); and to ensure a reliable
T2,
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future water supply. The UWMP includes water demand management measures,
consisting of:
• Best Management Practices / Audits
• Low consumption toilets / showerheads / faucets
• Leak detection / Metering
• Landscape programs / Drought tolerant plantings
• Public information / School education
• Commercial & Industrial conservation measures
• Water waste prohibitions
In 1991, Carlsbad adopted a five-phase Recycled Water Master Plan designed to save
potable water. The result is that CMWD has the most aggressive water recycling
program in the region when measured in terms of percent of supply derived from
recycled water. The Recycled Water Master Plan is referenced herein.
The implementation of the water conservation and water recycling elements included in
CMWD's UWMP are on schedule and are achieving the desired reduction in potable
water use. These programs are designed to work in tandem with the proposed seawater
desalination project to accomplish the City Council's water supply reliability goal of 90
percent water availability during a severe drought. This goal could not be met through
conservation and recycling alone.
The CMWD's current UWMP, approved in 2005 and referenced herein, projects that in
the year 2020 the City of Carlsbad will have 102.536 residents in the CMWD Service
Area, an increase of almost 22.000 people from the 2005 Service Area population
estimate. The projected water demand for the Service Area in 2020 is 28.907 acre feet
(AF) per year. The UWMP has projected that 1.945 AF. or approximately 7% of the
demand, will be met by conservation, a 500 AF increase over 2005 projected
conservation savings. Further, recycled water is estimated to constitute 6,300 AF, or
21%, of CMWD water demand in 2020. This represents a 6% increase over recycled
water supplies in 2020 estimated by the 2000 UWMP.
As an alternative to use of desalinated water for the 72% of the City's water needs that
would not be supplied by conservation (7%) and recycled water (21%) in 2020. certain
commentors have claimed that it is possible for the City to increase conservation or use
of recycled water in a manner which eliminates the need for desalinated water from the
desalination facility.
-73
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The Recycled Water Only Alternative would involve a situation where the City of
Carlsbad would not utilize any external source of potable water. Under this scenario, the
residents and businesses in the City would reduce their consumption of water, and only
utilize water which is recycled from the City's wastewater system. The current water
supply projection for 2020 - 21% recycled water and 7% conservation - would increase
by some combination to 100% under this alternative. A variety of different combination
of conservation and use of recycled water could be imagined under this alternative.
With this alternative, there would be no need for the desalination facility. The significant
effects of the desalination facility related to air quality and growth inducement would be
avoided.
Under the Recycled Water Only and Increased Conservation/Recycled Water
alternatives, the City would implement more aggressive conservation measures that go
beyond current BMPs as a means to meet future water demands. The City would more
aggressively apply BMPs going beyond what is locally cost-effective and implement new
restrictions on water use, such as limitations on residential landscape irrigating, washing
vehicles, irrigating golf courses and parks and other uses, and have appropriate penalties
for failure to comply with restrictions.
To more aggressively implement conservation measures beyond the current industry
standard, the City would have to implement non-cost-effective BMPs, non-proven
potential BMPs, and would have to enforce restrictions that could harm the City's
economy and result in a drastic change in life styles. Even with the aggressive
conservation measures the City has taken, coupled with planned future conservation
projects, the savings would not be sufficient to offset the estimated demand forecast for
2020.
The Recycled Water Only Alternative appears to be infeasible as it does not take into
account water loss and replacement. Inevitably, some water will be lost through
evaporation, transportation, leaks, application to soil, and water treatment processes in
industrial and public utility uses, such as waste treatment systems. Eventually, this lost
water will require replacement from another water source "outside" the recycled water
system. Accordingly, an argument could be made that this replacement could come from
sources other than imported and desalinated water, such as stormwater. However, the
City has no way of capturing stormwater for use as a potable supply as the City does not
have any stormwater impoundment reservoirs.
No community in the world has achieved the level of recycling and conservation
presented in the Recycled Water Only Alternative. Furthermore, the California
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Department of Health Services has health based restrictions on the use of recycled water
which prevent its use as a complete replacement for potable water. In addition, the
general public is unwilling to use recycled water as a complete replacement for water
used in cooking, bathing, washing and drinking.
The City has also previously analyzed the Increased Conservation/Recycled Water
Alternative, whereby the combined level of conservation and recycled water supply
would total somewhere between UWMP projections as used as the baseline assumption
in this FEIR and a level of 100%, which is the level analyzed in the Recycled Water Only
Alternative discussed above. (The 2000 UWMP estimates 15% of the City's water
demand in 2020 would be meet by recycled water: an estimate is not provided for
conservation, although the 2000 UMWP discusses conservation, the components to
achieve it, and recognizes conservation as a critical part of CMWD's long term water
supply needs.) A variety of different combinations of increased use of recycled water and
increased conservation are covered within this alternative. Commentors did not describe
a specific level of conservation or use of recycled water that they felt the City could
achieve.
The Increased Conservation/Recycled Water Alternative was not presented as an actual
alternative to the proposed project. No matter what level of conservation or recycled
water is proposed below 100%, the City and other jurisdictions in San Diego County still
face a need for potable water from some source. As a result, this is not a feasible
alternative to the proposed project. For example, reaching a theoretical goal of supplying
water needs through conservation and use of recycled water to meet 50% of the City's
water needs still requires a source of water for the remaining 50% of the water needs.
The desalination facility is still needed to supply that remaining 50%, even under this
type of Conservation/Recycled Water Alternative. Thus, this Alternative would not
eliminate the need for the desalination facility, nor would it eliminate the potential
adverse effects of the desalination facility related to a contribution to cumulative air
quality or a contribution to regional growth inducement.
An Increased Conservation/Recycled Water Alternative would permit the City to
purchase less desalinated water from the desalination facility. If Carlsbad were the only
customer for the desalination facility, this could result in a reduced capacity desalination
facility. The impacts of a Reduced Project Capacity Alternative are analyzed in Section
6.4 of the EIR. As noted in Section 6.4 of the EIR, a Reduced Project Capacity
Alternative would reduce but not eliminate the project's contribution to a cumulative air
quality and cumulative regional growth inducing impacts.
"16
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In summary, the City concludes that the Increased Conservation/Recycled Water
Alternative also appears to be infeasible for public policy reasons because it would
require a level of conservation and use of recycled water that is unacceptable as a matter
of public policy. The City previously determined the maximum acceptable levels of
conservation and recycled water use that should be mandated by the City in the approval
of the UWMP and the Recycled Water Master Plan, and does not believe these levels can
or should be increased for many reasons, as set forth in the record before the City Council
when those plans were approved. For example, due to current legal restrictions, recycled
water cannot be used for bathing, cooking and other household domestic needs. Current
mandated low flow toilets, showerheads and other plumbing fixtures represent the
maximum feasible level of conservation from these fixtures, and at this time it is
infeasible to mandate fixtures which provide higher levels of conservation.
Single family residential households use a large portion of the CMWD water supply. The
2005 UWMP estimates that in 2020. 38% of the total water supply, or 11.013 AF. can be
attributed to use by these households. Single family residential water demand includes
both indoor and outdoor water usage with 60% of the water usage attributed to outdoor
use, primarily for landscaping. Increasing the percentage of water supply available
through conservation, above the 7% conservation projection in 2020, would require an
equal reduction in demand.
While reduction of water demand could occur through use of recycled water for
landscape irrigation for single-family residences, this would present concerns. Installing
the public infrastructure and retrofitting all single-family residences to enable use of
reclaimed water for irrigation purposes would be economically infeasible. Moreover, use
of reclaimed water for irrigation by private residences is also discouraged by some
county health officials.
Further restrictions on outdoor water use, such as a ban on all outdoor water usage, are
not acceptable as a matter of public policy. If all outdoor water usage from single family
residences were prohibited, for example, a conservation of approximately 6,607 AF of
water (60% of 11.013 AF) or 22% of total 2020 demand would be achieved, enhancing
the total conservation supply for the City of Carlsbad in 2020 to 29% (7% + 22%).
However, among other things, this alternative would require the City of Carlsbad to enact
ordinances that allow only non-irrigated landscaping within the City of Carlsbad, and
ordinances that ban the use of outdoor irrigation for single family residences.
The City of Carlsbad has determined that prohibition of single family residential outdoor
irrigation and most outdoor landscaping is not a desired public policy goal of the City of
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Carlsbad, and the City Council does not believe that this action would be in the best
interest of the quality of life, or health and well being of the residents of Carlsbad.
Exhibit 2
AMENDMENT TO ADD THE FOLLOWING SECTION 5.5 TO
EXHIBIT "EIR-A"
CITY OF CARLSBAD RESOLUTION
NO.
CALIFORNIA ENVIRONMENTAL QUALITY ACT
FINDINGS OF FACT
(PUBLIC RESOURCES CODE 521081 CEQA GUIDELINES 315091)
and
STATEMENT OF OVERRIDING CONSIDERATIONS
(CEQA GUIDELINES 515093)
for the
FINAL ENVIRONMENTAL IMPACT REPORT (EIR 03-05)
PRECISE DEVELOPMENT PLAN AND DESALINATION PLANT
(SCH No. 2004041081)
5.5 Alternatives Considered and Rejected for the Purposes of this EIR
5.5.1 Description
Along with the Alternatives identified in this Section 5.0, previous consideration has been
given to policy options that are discussed as alternatives that have been considered and
rejected as infeasible for the purposes of this EIR. These alternatives include the
Recycled Water Only Alternative and Increased Water Conservation/Recycled Water
Alternative. These alternatives are not considered to be feasible project alternatives
because they require recycling and conservation practices that go beyond what is
considered to be acceptable from a public policy perspective. However, based on
comments received on the EIR, the City of Carlsbad believes it important to emphasize
and clarify past policy decisions relative to water recycling and conservation, and how
those water management strategies relate to the proposed project. Section 15126.6(c) of
the CEQA Guidelines provides for discussion of any alternatives that were considered by
the lead agency but were rejected as infeasible.
Under the Recycled Water Only Alternative, the City would not utilize an external source
of portable water. Residents and business would reduce their water consumption and
would only utilize water recycled from the City's wastewater system.
Under the Increased Water Conservation/Recycled Water Alternative, which the City has
previously analyzed, the City would increase its level of water conservation and use of
recycled water whereby the combined level of conservation and use of recycled water
would total somewhere between the figures stated in the City's 2000 Urban Water
Management Plan as used as the baseline assumption in the FEIR, and a level of 100%,
which is the level analyzed in the Recycled Water Only Alternative described above. In
the year 2020, for example, the 2000 UWMP estimates 15% of the City's water demand
would be meet by recycled water; an estimate is not provided for conservation, although
the 2000 UMWP discusses conservation, the components to achieve it, and recognizes
conservation as a critical part of CMWD's long term water supply needs. The update to
the 2000 UWMP, approved in 2005 following the release of the FEIR, revises the water
supply numbers and notes that in 2020, 21% of the CMWD water supply will be met by
recycled water and 7% of the water supply will be met through conservation.
5.5.2 Supporting Explanation
The City finds both the Recycled Water Only Alterative and the Increased Water
Conservation/Recycled Water Alternative are infeasible for public policy reasons because
they would require a level of conservation and use of recycled water that is unacceptable
as a matter of public policy (see FEIR Section 6.0). The City previously determined the
maximum acceptable levels of conservation and recycled water use that should be
mandated by the City in the adoption of the Urban Water Master Plan and the Recycled
Water Master Plan, and does not believe these levels can or should be increased for many
reasons, as set forth in the record before the City Council when those plans were adopted.
CEQA Findings of Fact and Statement of Overriding Considerations
EIR 03-05 - PDF and Desalination Plant
Amendment to add Section 5.5
2
For example, due to current legal restrictions, recycled water cannot be used for bathing,
cooking and other household domestic needs. Current mandated low flow toilets,
showerheads and other plumbing fixtures represent the maximum feasible level of
conservation from these fixtures, and at this time it is infeasible to mandate fixtures
which provide higher levels of conservation. Further, use of recycled water by single
family homeowners for irrigation would necessitate installing the public infrastructure
and retrofitting all single-family residences to enable use of reclaimed water for irrigation
purposes. This likely would prove to be economically infeasible and use of reclaimed
water for irrigation by private residences is also discouraged by some county health
officials.
It would also be infeasible and undesirable to achieve increased conservation through a
ban on all outdoor water usage by single family residences. Under this scenario, a
conservation of approximately 6,607 AF of water or 22% of total 2020 demand would be
achieved, enhancing the total conservation supply for the City of Carlsbad in 2020 to
29% (7% achieved through already projected conservation + 22%). However, the
additional 22% of supply conservation would require that no water be used outdoors in
single family residential dwellings. Among other things, this alternative would require
the City of Carlsbad to enact ordinances that allow only non-irrigated landscaping within
the City of Carlsbad, and ordinances that ban the use of outdoor irrigation for single
family residences.
The City of Carlsbad finds and has determined that prohibition of single family
residential outdoor irrigation and most outdoor landscaping is not a desired public policy
goal of the City of Carlsbad, and the City Council does not believe that this action would
be in the best interest of the quality of life, or health and well being of the residents of
Carlsbad.
The City also finds that, under the Increased Conservation/Recycled Water Alternative,
no matter what level of conservation or recycled water is proposed below 100%, the City
and other jurisdictions in San Diego County would still face a need for potable water
from some source. As a result, this is not a feasible alternative to the proposed project.
For example, reaching a theoretical goal of supplying water needs through conservation
and use of recycled water to meet 50% of the City's water needs would still require a
source of water for the remaining 50% of the water needs. Thus, this Alternative would
not eliminate the need for the desalination facility nor would it eliminate the potential
adverse effects of the desalination facility related to a contribution to cumulative air
quality or a contribution to regional growth inducement.
The City also finds, with regards to the Recycled Water Only Alternative, that it is
infeasible as it does not take into water loss and replacement. Inevitably, some water will
be lost through evaporation, transportation, leaks, application to soil, and water treatment
processes in industrial and public utility uses, such as waste treatment systems.
Eventually, this lost water will require replacement from another water source "outside"
CEQA Findings of Fact and Statement of Overriding Considerations
EIR 03-05 - PDF and Desalination Plant
Amendment to add Section 5.5
3
the recycled water system. Accordingly, an argument could be made that this
replacement could come from sources other than imported and desalinated water, such as
stormwater. However, the City has no way of capturing stormwater for use as a potable
supply as the City does not have any stormwater impoundment reservoirs.
CEQA Findings of Fact and Statement of Overriding Considerations
EIR 03-05 - PDF and Desalination Plant
Amendment to add Section 5.5
4