Thursday, April 7th, 2022
To: Donne Brownsey, Chair
California Coastal Commission
455 Market Street, Suite 300
San Francisco, CA 94105
cc: John Ainsworth, Executive Director
Kate Huckelbridge, Senior Deputy Director
Tom Luster, Senior Environmental Scientist
Regarding: Poseidon Resources, LLC; Seawater Desalination Project at Huntington Beach; Application for Coastal Development Permit; Appeal of Coastal Development Permit; 21730 Newland Street, Huntington Beach
Dear Chair Brownsey and Commissioners,
If approved, the Huntington Beach desalination plant, proposed by Brookfield-Poseidon, would be an energy-intensive hazard causing more harm to the communities of North Orange County (“North OC”) than benefits.1 Despite Brookfield-Poseidon’s promises of economic prosperity, industrial polluters such as the entities behind the proposed desalination plant, are known to cause economic harm to commercial properties and residential areas.2 And the permitting of such industrial activity on our coast has the potential to significantly diminish economic activity in the area that is unrelated to the desalination plant. It would also hinder the community’s current and future residential population and the value of their properties.
Brookfield-Poseidon has made assertions that its project will create around 3,000 jobs for Huntington Beach residents, however, they admit that only 1% of that number will be permanent
1 See Oscar Rodriguez, Rodriguez: The Environmental Racism Behind the Poseidon Desalination Proposal, Voice of Orange County (2020) https://voiceofoc.org/2020/11/rodriguez-the-environmental-racism-behind-the-poseidon-desalination-proposal/ (“If the ¿Brookfield-Poseidon desalination project is built, it would unnecessarily expose the community to another half-century of emissions from the Alamitos Energy Center, a gas power plant that has no place in a clean energy future, where everyone’s health matters.”); See also Gregory Pierce, Analyzing Southern California Supply Investments from a Human Right to Water Perspective: The Proposed Poseidon Ocean Water Desalination Plant in Orange County,
UCLA Luskin Center for Innovation at 1-2 (2019)
https://innovation.luskin.ucla.edu/wp-content/uploads/2019/04/Analyzing_Southern_CA_Supply_Investments_from_a _Human_Right_to_Water_Perspective.pdf (finding that the Water Purchase Agreement with Poseidon will make water severely less affordable for disadvantaged households in Orange County, and that the Human Right to Water cannot be plausibly realized from this project.); See also Brian Bienkowski, Desalination plants are on the rise—so is their salty, chemical waste, Environmental Health News (Jan. 15, 2019)
https://www.ehn.org/desalination-plant-waste-oceans–2625733077.html (“When brine is sent back to the ocean it can harm aquatic life by sharply raising the salinity level of the water and can carry harmful chemicals that the brine picks up in the desalination process … high salinity and reduced dissolved oxygen levels can have profound impacts on benthic organisms, which can translate into ecological effects observable throughout the food chain.”).
2 Undesirable land uses like hazardous waste facilities have negative impacts on residential home values no matter the market. Laura O. Taylor, Daniel J. Phaneuf, Xiangping Liu, Disentangling the Property Value Impacts of Environmental Contamination from Locally Undesirable Land Uses: Implications for Measuring Post-Cleanup Stigma, J. of Urb. Econ. 85, 90 (2016).
occupations and even fewer would be locally sourced.3 In fact, the site plans for the Huntington Beach facility contain 187 spaces for parking, a number far from Brookfield-Poseidon’s original employment claims.4 On their website, Brookfield-Poseidon claims the number of jobs is “over 2,000 though only 18 would be full time jobs.5 We believe these inflated job estimates are an attempt to make their proposal seem more appealing and are used to justify the building of a toxic industrial desalination plant on the beautiful coast of Orange County, which is already tainted by the AES plant. The vast discrepancy in the numbers Brookfield-Poseidon communicated to the public and those actually planned by Brookfield-Poseidon show bad faith and should devalue any claims characterizing this project as a significant job creator. Instead, in reality, multi-use zoning and facilities that are close to the beach would likely yield more jobs, economic activity, and property value for local residents, all while protecting the environment.
Granting a permit to yet another polluting facility in North OC would limit tourism as well as residential and environmental activity. Desalination plants are known to have adverse environmental effects and possess the potential to diminish the environmental quality for humans and animals alike.6 As a result, jobs, businesses, and residents could leave in search of a cleaner and healthier environment. Brookfield-Poseidon’s erroneous job claims do not consider the jobs lost due to another toxic industrial facility being permitted to operate in North OC. However, this flight of jobs and capital need not happen if Brookfield-Poseidon’s coastal development permit applications are denied, and other water conservation efforts and strategies are pursued instead.7
A denial of Brookfield-Poseidon’s application for coastal development permits would give way to more sustainable and equitable strategies that offer better jobs, healthy economic activity, and
 Proponents of the project often state this project would create over 3000 jobs for the community, however, Brookfield-Poseidon admits this estimate is solely based on construction work and contracting. According to the company’s website, only 18 full-time jobs will be created along with an ambiguous “322 indirect jobs.” And Brookfield-Poseidon’s Carlsbad desalination plant only employs 35 workers. Whether the number is 18, 35, or 322, all are far short of the estimates proclaimed by the project’s supporters. Furthermore, Brookfield-Poseidon has failed to provide any indication that the jobs will be locally sourced or that there is a local job hiring policy. Huntington Beach Desalination Plant, Poseidon Water https://www.poseidonwater.com/huntington-beach-desalination-plant.html; The Many Benefits of Desalination, Seawater Desalination Huntington Beach facility https://www.hbfreshwater.com/benefits.html; See Senator Barbara Boxer and Antonio Gonzalez, Desalination plant in Southern California is important to water security, Mercury News (Oct. 17, 2021) https://www.mercurynews.com/2017/10/13/opinion-desalination-plant-in-southern-california-is-important-to-water-security/ (“[T]he plant will support more than 3,000 jobs in desalination, engineering, and construction. Once operational, it will directly support 419 ongoing local jobs.”); Carlsbad Chamber of Commerce https://carlsbad.org/Spotlight-OnPeter-MacLaggan-Poseidon-Resources-Corporation/.
 Poseidon Resources Application for Coastal Development Permit, Attachment 22, page 4.
 See Exhibit One (Screenshot of Brookfield-Poseidon’s website).
 See Rodriguez, supra note 1.
 Water conservation efforts like reusing wastewater offers a safer and better option than desalination plants. See Erica Gies, Slaking the World’s Thirst with Seawater Dumps Toxic Brine in Oceans, Scientific American (Feb. 7, 2019) https://www.scientificamerican.com/article/slaking-the-worlds-thirst-with-seawater-dumps-toxic-brine-in-oceans/ (“California, Arizona and … Singapore have been pioneers in … using treated wastewater for crop and landscape irrigation as well as drinking water. Conservation is another oft-overlooked approach to the problem of dwindling water supplies… some water supply systems lose more than half their water to leaks. Urban areas can also expand green spaces to capture more storm water, rather than trying to shunt it away as quickly as possible.”); see also Rodriguez, supra note 1 (“When we get rain, much of it runs to the ocean. We can do a better job of capturing this water with rainwater harvesting and by encouraging more permeable surfaces so the water gets into the ground.”).
healthy communities. Well-funded water recycling and conservation efforts will produce tens of thousands of jobs while also providing better benefits for the residents of North OC. The proposed site for the desalination plant is a brownfield surrounded by brownfields and development on the site and around it will further expose the community to more industrial waste and toxins. Instead, money should be directed to the brownfield project site for remediation and sustainable end uses rather than industrial end uses run on fossil fuels. To be clear, we believe the area should be returned to the original ecology, namely, wetlands and preserved for future generations. However, other end uses that promote sustainable and healthy activity would likely create more full time employment on the site than Brookfield-Poseidon’s plant.
This project is not a significant job creator, but a polluting facility that is likely a job and property tax killer, with a real potential to decrease the quality of life in North OC. Thus, the wildly divergent job claims asserted by Brookfield-Poseidon and the adverse human and environmental effects posed by the toxic plant should accrue towards a denial of Brookfield-Poseidon’s permit application. We ask the Coastal Commission to require Brookfield-Poseidon to prove and clarify its job claims about the project and for the Commission to factor in Brookfield-Poseidon’s bad faith use of inflated claims when deciding on the merits of this application.
 Public resources intended for the Brookfield-Poseidon project can be diverted to more efficient sustainable and equitable water conservation strategies. For example, the Carson Regional Recycled Water Project is expected to create over 47,000 jobs with the number being evenly split between direct and indirect jobs.
 See Rodriguez, supra note 1 (“For every million-dollar investment, water conservation creates 16.6 jobs, water recycling creates 12.6 jobs while desalination would only create 8.7 jobs, and only 60 percent of those jobs would be local.”).
 A brownfield is a property or area whose (re)development is complicated by the presence of pollutants, contaminants, and hazardous substances. However, if carefully planned and equitably executed its redevelopment can have substantial benefits on the surrounding community. Overview of EPA’s Brownfields Program, EPA https://www.epa.gov/brownfields/overview-epas-brownfields-program (“Cleaning up and reinvesting in these properties increases local tax bases, facilitates job growth, utilizes existing infrastructure, takes development pressures off of undeveloped, open land, and both improves and protects the environment.”).
 Martin Wisckol, Huntington Beach wetlands continue to expand, following decades of degradation, The Orange County Register (October 16, 2020) https://www.ocregister.com/2020/10/16/huntington-beach-wetlands-continue-to-expand-following-decades-of-degradation/ (“The coastal wetlands of Orange and Los Angeles counties, once scorned for the obstacles they posed to the construction of roads and buildings, have been squeezed by development to less than 10% of their 19th-century size.”).
 Wetland restoration produces numerous commercial, recreational, and aesthetic benefits for communities. Protecting and restoring wetlands can increase public safety and the quality of life in communities. See, e.g., Basic Information about Wetland Restoration and Protection, EPA https://www.epa.gov/wetlands/basic-information-about-wetland-restoration-and-protection#:~:text=These%20services%20generate%20state%20and,coastal%20areas%20from%20storm%20surges
(“Wetlands also control erosion, limit flooding, moderate groundwater levels and base flow, assimilate nutrients, protect drinking water sources, and buffer coastal areas from storm surges.”); See
Michelle Banks, Wetland restorations offer environmental, economic benefits, https://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/home/?cid=stelprdb1117054 (“[P]lants and biological processes in the wetlands break down pollutants like fertilizers … filtered water then flows into nearby streams or sinks into underground aquifers, which become sources of municipal drinking water … towns are able to reduce water treatment system costs … as an added benefit, wetlands slow down and soak up water that runs off the land, reducing flood impacts and eliminating the need to build expensive flood control structures”).
Andrea León-Grossmann | Climate Action Director of Azul
Frankie Orona | Executive Director, Society of Native Nations
Lydia Poncé | Director, Idle No More So Cal
Charming Evelyn | Chair – Water Committee, Vice Chair Environmental Justice Committee – Sierra Club Angeles Chapter, Co-Chair Conservation Committee – Water, Sierra Club CA
Oscar Rodriguez | Co-founder of OakView ComUnidad
Alejandro Sobrera | Hub Coordinator of Sunrise OC
Patricia J. Flores Yrarrázaval | Project Director, Orange County Environmental Justice (OCEJ)
Espe Vielma | Executive Director of the Environmental Justice Coalition for Water
Conner Everts | Desal Response Group, Southern California Watershed Alliance
Dave Hamilton | President, Residents for Responsible Desalination
Mandy Sackett | California Policy Coordinator, Surfrider Foundation