PO Box 6064, Chula Vista, CA 91909, (619) 425-5771

6/6/08

RE: Comments on Soil and Water of the PSA:

• The proposed water supply for the project, potable drinking water from Sweetwater Authority, would not cause a significant adverse environmental impact on current or future users of the drinking water.

We strongly disagree with this statement. The director of the Sweetwater Authority gave this presentation to our city council highlighting how critical the water situation was. It seems there may be enough for this year, but in 2009 the possibility of mandatory restrictions is looking more and more likely. http://www.youtube.com/watch?v=EUrk5YSEAAk The governor’s recent declaration of drought also highlights the need to use potable water only for drinking. http://www.nytimes.com/2008/06/05/us/05drought.html?hp How in the world can the CEC staff even think of allowing the waste of so much potable water by a peaker plant proposed for an inappropriate location in an area that does not need peaker power according to its electricity provider, which will not give the company a contract?

• The use of a municipal water supply does not comply with state water policy found in the California Constitution, State Water Resources Control Board Resolution 75-58, and the Energy Commission’s 2003 Integrated Energy Policy Report water policy.

This use is clearly a violation of LORS even the Energy Commissions own LORS!!

• The applicant has not adequately demonstrated that the use of an alternate water supply or cooling technology is environmentally undesirable or economically unsound.

All MMC cares about is its own bottom line. It does not care that it will be putting the citizens of Chula Vista in the position of having to conserve more or that they are wasting a very precious and scarce resource. CEC staff has to care and require that they hook into one of the recycled water lines a few miles to the east. If they hooked into this line it could, perhaps, be used by others for landscaping as well. An alternative would be to truck in recycled water from a place to the east that is connected or directly from the southbay water treatment plant that has a surplus. There are plenty of options and the fact that it will cost MMC some money is not an acceptable reason for not requiring that they use one of these options.

The amount of water-48 million gallons- per year or 116 gallons per minute is totally unacceptable. Staff must use the total number of hours the plant is permitted for in order to meet CEQUA guidelines.

Considering that this peaker is more than twice the size of the old peaker and will use considerably more water will the current ground water detention basin be of adequate size?

The CVEUP will use a maximum of 86 acre-feet a year of potable water. Staff believes that the use of this water will contribute to the cumulative impacts of scarce water supply for the south state. However, the amount of water is modest. Staff does not consider the use of the water to be a cumulatively significant impact.

We strongly disagree with this statement, which is inherently contradictory. This use will contribute to the scarcity in western Chula Vista specifically. In a wet year SWA can supply almost all its water needs from local sources. In this drought it is importing 70% of its supply. There is increasing uncertainty about this imported supply. If staff looks at the CV General Plan they will see the forecast for 7,000 more homes in the southwest and 14,000 in the northwest. This will put an incredible strain on local water resources. SWA is trying to keep up, but with drought conditions this seems uncertain. Wasting drinking water in this way is totally unacceptable. If a way cannot be found to use recycled water this project needs to be rejected in order to help insure the supply for current users.

Using local potable water is a significant cumulative impact when looked at in terms of the projected increase in population for the area.

“The Energy Commission will require zero liquid discharge technologies unless such technologies are shown to be ‘environmentally undesirable’ or ‘economically unsound.’” How can staff support the use of the municipal wastewater discharge system, considering this policy? Normally businesses and homes are required to not increase the amount of discharge from their site. It would be a simple matter to require permeable pavement everywhere on site and to use the retention basins to hold the water until it could percolate into the ground. Definitely we have clay soil and water does not percolate well, but some of it could be recycled on site for reuse.

California Constitution, Article X, Section 2, Warren-Alquist Act, SWRCB Resolution 75-58 and Energy Commission’s 2003 Integrated

Energy Policy Report LORS and water policies applicable

Normally development in Chula Vista is required to have a water conservation plan. This is another example of not following the LORS. CVEUP must conserve water. They MUST use recycled water only for non-potable purposes.

Options that should be analyzed more fully include low quality (brackish) groundwater and recycled water. The use of low quality groundwater would require drilling a well and the installation of additional equipment to clean the water. The use of recycled water would require construction of a pipeline to transport recycled water to the CVEUP site.

SWA use brackish groundwater for drinking purposes. It is planning eventually to put a well near the Otay River, but this water is intended to meet drinking water needs for the local populace. The highest and best use of the San Diego Formation Ground Water is for drinking purposes. It would be wasteful to use it for an unneeded power plant in an inappropriate location. Constructing a pipeline is not necessary. The recycled water could be trucked to the site. It is also possible since CVEUP is close to the bay and there is a heavy dew in the mornings to collect a certain amount of water. The water leaving the peaker as steam could also be collected. There are creative solutions to this problem, but under no circumstances should they be allowed to use potable water.

Conclusions

Considering the LORS, the current drought, and the importance of providing for the future growth in Chula Vista from local resources this statement makes absolutely no sense. This use would cause a huge negative effect.

Sincerely,

Theresa Acerro

President of Southwest Chula Vista Civic Association.