FINAL REPORT Evaluation of Seawater Desalination Projects ...

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EVALUATION OF SEAWATER DESALINATION PROJECTS PROPOSED FOR THE MONTEREY PENINSULA assessment, it would also be useful to have more information on the pumps and any auxiliary engines associated with them, as well as on-board generators for crew facilities 63 . As noted above, the Minor New Source Review permit application for the proposed Cabrillo Port is a recent example of agency review and applicable air requirements for off-shore vessels. For the Cabrillo Port application, the U.S. EPA Region IX proposed to address permitting of the emission sources in the coastal waters off Ventura through an Authority to Construct issued under District Rules, which would also incorporate applicable federal and state requirements. The port was required to analyze emission controls to determine Best Available Control Technology (BACT) under District rules (which included Selective Catalytic Reduction (SCR) and oxidation catalysts). (The deepwater port would have individual diesel-fired equipment on-board, but information on the SDV suggests that all power would come from the main engine, which burns marine gas-oil or biodiesel.) EPA did not expect to require the purchase of emissions offsets and the area would be designated as “unclassified/attainment” for the purposes of federal New Source Review/Prevention of Significant Deterioration requirements. Several commitments regarding fuel use and the offset of onshore diesel emissions were included in the policy statement. It is noted, however, that this proposed air permit and the EPA Region IX policy for the deepwater port was challenged by the Environmental Defense Center in Santa Barbara (April 6, 2007) as “violating the Clean Air Act.” It was also alleged to be inconsistent with District and ARB requirements for the use of BACT and demonstrating the use of emission offsets. The review of this application suggests that air permitting issues for the SDV are potentially complex and may be contentious. The SDV information appears to be sensitive to issues related to fuel use and greenhouse gas emissions. Both U.S. EPA and the ARB are pressing for more regulation of fuels used by marine vessels, and greenhouse gas emissions concerns are highly visible in light of AB 32. The SDV information states in some places that only biodiesel will be used for both the “mother ship” and the shuttle vessels. In the Proponent’s Statement, on the other hand, biodiesel capabilities are noted but not identified as the only fuel. It will be important to clarify the fuel mixture commitments in the SDV proposal 64 . SDV proponents have made a number of public statements to the effect that local regulatory agencies favor or support the ship-based desalination concept, the intake and discharge schemes, and the seabed pipeline. Telephone discussions with representatives of the Monterey Bay National Marine Sanctuary, the California Coastal Commission, and the Monterey Bay Aquarium Research Institute reveal a more measured assessment. In 63 Proponent’s comments on the draft GEI/B-E report emphasize the ship’s main engine would not be used to produce power as all power would be generated from the gas turbines. 64 Proponent’s comments on the draft GEI/B-E report state their intent to burn biodiesel; however if biodiesel is not available the turbines could use marine gasoil. Monterey Peninsula Water Management District 7-17
EVALUATION OF SEAWATER DESALINATION PROJECTS PROPOSED FOR THE MONTEREY PENINSULA summary, each of these agencies or organizations believes the SDV approach may have merit and should be studied further, but none are offering endorsement, and all believe the permitting challenges have been significantly underestimated by SDV proponents. Monterey Peninsula Water Management District 7-18
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