The South Bay Parkland Conservancy suggests these five action steps:

1. Sign our petition
2. Contact our local representatives
3. Write a letter to the water board
4. Share steps 1-3 with your database
5. Testify before the Water Board at its October 17 meeting

In 2010, the California Water Board adopted a “Once-Through Cooling Policy” requiring coastal power plants to phase out the use of “once-through cooling” systems (which is what AES is) as they were highly damaging to the marine environment. This policy mandated the closure of the AES Power Plant by December 2020. Despite significant opposition, in September of 2020, the Water Board voted to extend AES Plant operations for an additional year.

 Now, at their October 17, 2021, Board meeting, they are proposing to extend the AES Plant for another two years with the justification that the plant is needed for “stand-by” capacity as an emergency power facility. The irony is that the AES power plant is so old (67 years old) and inefficient (it takes 12 to 24 hours to power up) that it failed to provide power during all flex alerts called in 2020 due to equipment failures and heat. The threat of brownouts or blackouts if the AES Plant goes offline is an empty cover story the Water Board is telling to justify their decision to extend operations yet again of this highly polluting, ocean-sucking, carbon-emitting plant. The more the SBPC digs, the more apparent it becomes that the power brokers, vulnerable politicians, and the well-funded power company lobbyists, NOT FACTS, are driving this decision. Essentially, the State abdicated implementation of their California climate policy and the health of the Santa Monica Bay to energy interests that of course, caused the problems to begin with.

In good conscience, as environmentalists and truth-seekers, the SBPC cannot let this stand. It is clear to us that only an avalanche of opposition will have any chance of derailing this backroom deal. Everyone who is awake can see the carnage the Earth is experiencing from climate change, and we can no longer kick the climate can down the road. The SBPC needs broader support in this endeavor and is contacting you in hopes that you will help us by joining in this fight. 

In keeping with the Water Board’s “see no evil, hear no evil” approach, the Water Board closed the comment period on this item on July 17, more than THREE MONTHS before the board hearing, which is scheduled for October 17 of this year. The City of Redondo Beach requested an extension of the comment period as they were not expecting comments to be due at such an early date. The Water Board initially indicated that they would likely accommodate the City’s request, but then they denied the request the DAY THE COMMENTS WERE DUE!

In the same vein, the Water Board is also playing fast and loose with the California Environmental Quality Act (CEQA) to jam these extensions through. The Water Board prepared an addendum to an 11-year-old “CEQA Equivalent Document” (essentially an Environmental Impact Report [a weak one at that]), as their compliance with CEQA for this action. Under CEQA, an “addendum” is only to be used when there are minor technical changes to a project that do not pose new impacts and/or will not increase previously disclosed impacts. The Water Board is somehow concluding that extending the lifespan of the most highly polluting plant along the entire California coast for three years beyond the original deadline set 11 years ago (a 30% increase in the duration of impacts from the facility), does not pose additional impacts on the environment. In 2020, the Cities of Redondo Beach and Hermosa Beach and a local non-profit sued the Water Board over their failure to properly evaluate the impacts associated with these extensions under CEQA, but these lawsuits will not be heard by the Court until late Fall. 

Additionally, for over a decade now the Water Board has continued to extend “interim” discharge permits with “interim” mitigation requirements (which the Board admitted in its September 1, 2020 hearing were insufficient) to meet their own regulatory obligations under the Clean Water Act. The SBPC reviewed materials received per a Public Records Act request issued to the Water Board and found that the AES Plant failed to meet its discharge requirements almost every month of the last year resulting in over $230,000 in fines. The AES Plant also received numerous violations and fines from the South Coast Air Quality Management District (AQMD) for not meeting permitted air quality requirements (although the AQMD, is also putting its head in the sand about this plant, taking the position that if an enforcement officer does not personally witness an “upset condition” as far as they are concerned, it did not happen). The SBPC includes several Board members with extensive experience in environmental planning and these professionals are confident that the Water Board will ultimately lose the CEQA lawsuits and strongly believe that they are failing in their mandate to administer the provisions of the Clean Water Act. 

So, we have a power plant that does not work, that we do not need, that consistently violates its permitting requirements, that was scheduled by the Water Board to be decommissioned in 2020, but we are going to keep it operating anyway?  One needs to ask, what is really happening here? Is it AES Redondo who spent well over $200,000 to lobbyists this year to grease the skids for another extension in plant operations (they are being paid over $40 million per year to keep the plant on standby)? Is it the big power interests that only need to whisper “brown-out” or “black-out” to put fear in the heads of politicians everywhere? Is it a Governor facing a recall, hedging his bets against a Texas-like power shortage coming at just the wrong time (although if that happens, it will not be because of the AES Plant)? Is it a bureaucracy that adopted a policy but failed to take the steps to implement it? Any way you put it, while California burns, the agencies responsible for our energy grid and the resource agencies charged with regulating them, are claiming that the only thing keeping us from brownouts and blackouts during peak power use is a highly polluting, ocean-sucking, a 67-year-old antiquated power plant located adjacent to the most densely populated communities along the California Coast. Given that we know this is a myth, can California really call itself a leader in climate policy when “on the ground” it is business as usual? 

Sadly, several recent studies have concluded that the California Independent Systems Operator (CAISO) and the Public Utilities Commission (PUC) failed to execute the steps needed to reach the State’s target of 100% clean electricity by 2045. CAISO continues to mismanage the grid (during last summer’s brownouts we were exporting electricity to Arizona) and by their own confirmation, CAISO, the PUC, and the Water Board have no viable plan currently in place for decommissioning the AES Plant even though they were given 11 years to meet their “mandated” deadline. What is so tragic about this outcome is that there are so many good reasons to decommission this plant. It is located on a 55-acre parcel immediately adjacent to the Pacific Ocean (where can you find that these days) and the City of Redondo Beach plans on preserving 25 acres of this site as parkland and open space. Additionally, the AES Plant is located on active wetlands (this area was once called the Old Salt Lake, California Historic Landmark #373), and per the California Coastal Commission, the wetlands must be restored when the plant is finally decommissioned. Multiple State agencies committed millions of dollars toward this restoration and the County of Los Angeles Board of Supervisors voted unanimously to identify this site as an Enhanced Infrastructure Financing District, thereby directing tens of millions more dollars toward restoration and maintenance. This parcel holds such promise to be a major stop along the Pacific Flyway and a major passive recreation facility along the densely populated southern California coastline. The City of Redondo Beach already lost almost $5 million in grant money when the AES Plant was extended last year, we cannot let this happen again.

The SBPC hopes that you share our concerns and are willing to help. Although the official comment period on this item is closed, we need to continue working every angle we can to shut this planet-warming, ocean-killing, polluting eyesore down.

•  Here is a link to a petition we hope you will share with your members.
• We also respectfully request that you activate whatever political and/or lobbying power you have in your arsenal to move the needle on this and to call, write, and email all regulatory and political contacts you have, including the Water Board, so we can make sure our voices are heard.

Governor Newsom: https://govapps.gov.ca.gov/gov40mail/

Assemblyman Al Muratsuchi: https://a66.asmdc.org/contact
Senator Allen: https://sd26.senate.ca.gov/contact/message

• We also request that your staff and supporters request that the AES plant be shut down under non-agenda items at all the Water Board’s upcoming meetings between now and October 17^th to let them know we are paying attention.

Information on California Water Board meetings:  https://www.waterboards.ca.gov/board_info/

 California Water Board email addresses:

Joaquin.Esquivel@waterboards.ca.gov

Dorene.Dadamo@waterboards.ca.gov

Tam.Doduc@waterboards.ca.gov

Sean.Maguire@waterboards.ca.gov

laurel.firestone@waterboards.ca.gov

•  Finally, testify before the Water Board at its October 17^th hearing, which will determine the outcome for this site.

 Please do not hesitate to contact us with any questions you may have as the SBPC will be happy to provide your organization with any additional information you may need to support our position on this issue. 

Sometimes it takes a village, and this is one of these times. We truly hope you will join us in this fight.

With appreciation,

The South Bay Parkland Conservancy Board Members

—

Aga ChenFu

Marketing/Communications

South Bay Parkland Conservancy