And Davidge’s answers
Questions Directed to Mr. Davidge (continued)
- Off-Shore Environmental Impact
- How will you mitigate the effects of your bag and tug operations on the marine mammals (migrating grey whales, resident harbor seals, etc) that frequent the Gualala Point Regional Park shoreline?
Answer: Our bag operation, as originally presented in the drawing provided to the SWRCB was not correct. We have subsequently amended the buoy placement much further off shore and thus it should not have any adverse impacts to marine mammals. The NMFS has already looked at similar operations in other parts of the United States and approved our operations. A bag is in most cases to marine mammals not any different then a vessel such as a boat or ship. The Gualala historically had large ships enter its mouth. But, placement further offshore will greatly mitigate any special impacts.
- How would the proposed northward extension of the National Marine Sanctuaries to Cape Mendocino affect your project?
Answer: I will look into this.
- What are the dimensions of the water collection features needed for your project?
Answer: The pipeline will be 24 inches in diameter. The scale of the cistern is yet to be finally determined and will in part depend on placement and distance.
- Will any portion of the pipeline be laid through the water trace of the stream?
Answer: The pipeline will be laid within the alluvium in the river’s bed.
- How will you anchor your pipes?
Answer: With concrete anchors and bull rock.
- What material will you use for the pipeline thrust blocks and how will they be installed?
Answer: (delegated to engineer)
- What method will you use to get the pipeline under the sandspit?
Answer: We will either go around the spit or through it. Since the spit is seasonal, it is an unstable land form that will migrate based on flows and tides we do not think this will be a significant issue.
- How will you maintain the filters at your intakes?
Answer: (delegated to engineer)
- Will you have any on-shore storage?
- How will the pumps be powered and how will you access that power?
Answer: By electricity from the closest power source. Now under study.
- What will you do to ensure that the pumps do not cause pollution?
Answer: Electric underwater pumps (in themselves) do not cause pollution.
- Why do you require treatment plants?
Answer: We do not.
- Where will you locate treatment plants?
Answer: We will not have any treatment plants.
- What will happen to the on-shore and off-shore infrastructure if your venture fails?
Answer: In most cases the state permits require the infrastructure to be removed or closed off. That will be determined by the state requirements.
- Will the water intakes be precisely located as shown on the maps included in your applications?
Answer: No. We continue to study the dynamics of these rivers and will file amendments with the state as necessary. It is our hope to have this sufficiently pinned down that we can discuss alternatives during the public comment process. We do not believe in assuming that we have all the answers. We depend greatly on local experts and knowledge and wish to be as flexible as possible so that we are responsive to new information or concerns.
- How much maintenance activity will be required because of changes in the stream channels blocking your intakes?
Answer: With proper installation and placement we do not anticipate much if any.
- How will your infrastructure affect recreational boaters and swimmers?
Answer: It should not have any affect on either.
- What happens when there is an intake of flow, but no bag in which to pump it?
Answer: The pumps will not pump the water.
- In decibels, what will be the noise levels caused by your on-shore operations?
Answer: Electric pumps are very quiet and as our harvest is only during high flow seasons the sound of the river will erase any sound of the pumps. The pumps will also be within a concrete structure under the river’s bed so the sound will be greatly muted.
- How would you handle any environmental problems that developed after you built your infrastructure?
Answer: In most cases states require ongoing monitoring of a wide range of issues. We will continue to monitor our harvest system as it is installed and in operation.
- How will you monitor whether your project is having detrimental effects on aquatic life?
Answer: same as previous answer. Additionally, we anticipate the state maintaining an ongoing overview of this operation due to its unique placement and operation so that they can be more informed in commenting on other such applications in California in the future.
- How will you cooperate with on-going State- and community-supported river restoration projects?
Answer: By being a good neighbor and working with the community. We have already offered to work with the fishery restoration group and our work should be complementary.
- To what extent will you commit escrowable resources to restore and maintain the river system during worst case periods?
Answer: In most cases states require commitment to protect the public interest.
- Please clarify the capacity and dimensions of the bags.
Answer: Initially we anticipate operating using 50,000 cubic meter/ton bags. The other specifics about our bags is considered proprietary/trade secrets.
- How long will it take to fill one bag?
Answer: We anticipate no more than 24 hours each.
- What is the expected cost of a 45 acre-feet bag?
Answer: That is proprietary
- In what sea state will the bags fail?
Answer: With the development of our new bags by Albany International we anticipate that the bags will withstand significant seas. The problem will be more with the tow between the tug and the bag and the tug operator will make an informed decision on when to not operate based on weather conditions. The bags now in operation in the Mediterranean will not be the same as are used in the Pacific or the Atlantic.
- What is the size and configuration of the mooring facility?
Answer: A single mooring buoy will consist of a surface buoy for site identification and an undersea pumping facility. The outside scale of this is yet to be determined by the engineers. This type of system has been used for over 3 decades by other industries.
- Will you have any off-shore storage?
Answer: No, none other than a filling bag.
- Will you require nighttime illumination and marine hazard warnings, such as fog horns?
Answer: Whatever the U.S. Coast Guard requires.
- Where will the bags and tugs be manufactured?
Answer: Within the United States consistent with the Jones Act. Albany has a plant in California.
Off-Shore Operational Considerations
- Will bag deployment and tug operations be conducted at night? If so, what brightness will the lights be?
Answer: I cannot answer that absolutely at this time. It is far safer to operate in the daylight given the safety checks we require during the bags filling and pre-towing inspections. We do not anticipate night operations other than bag filling.
- Under what sea conditions would you expect to have to suspend operations?
Answer: That is not yet determined. With the testing of the new generation of bags developed by Albany we will determine our safety zone of operation. We hope to have sea trials of the new bags later this year in the Pacific.
- What provisions will you have for tugs running aground?
Answer: Whatever the U.S. Coast Guard requires.
- How will you protect the bags from severe winter storms?
Answer: Bags do not operate in the water in the same manner, as do hard surface vessels. In most cases the wave energy passes through the bag with little to no effect. Wind energy generally blows over the bag as we anticipate the bag floating just below the surface. The bags are constructed with buoyancy and will not sink. They are also monitored with GPS and other instruments so that we know the status of each bag in real time.
- Where will you have your bag repair facilities?
Answer: Not yet determined. This will be coordinated with the tug operator and bag manufacturer.
- Will you have crews on-site 24/7 during the months when you operate?
Answer: Given the nature of the operation we anticipate someone being on site at all times during harvest activities. During off-season we will have someone in the area check the systems regularly.
- What indemnities will you provide for environmental damage due to failure of your tugs, bags and mooring facilities?
Answer: We will carry the required project insurance as is most common in marine projects. What indemnities does the local water utility that takes water from the Gualala River provide?
- What is the mean time between failures for your waterbag mooring and towing systems?
Answer: Please further clarify this question.
- In decibels, what will the noise levels be caused by your off-shore operations?
Answer: Unknown at this time, but we are certain it will be less then the surf. This is an area we will define.
- How would your project impact on tourism and the local economy?
Answer: We have already filed an amendment to our Gualala River application to move the buoy and pipeline to a location that is not visible to the community of Gualala in response to concerns raised by community leaders. This is the type of responsiveness we hope to continue as long as the changes are within our economic and environmental parameters. We have also offered to be of assistance to the group attempting to restore species in this river.
- How will you mitigate the visual impact from bluff top trails and from the town of Gualala?
Answer: See answer to previous question. In most cases the bag is not visible from the beach or cliffs as it floats just below the surface of the water. The buoy will be visible but the footprint is very small.
- What is the maximum impact your project will have from the Gualala tourist industry’s “signature” view from the bluffs?
Answer: The buoy will be visible at times, but by placing the operation behind the rock outcropping along the south side of the river, we believe the community will not be able to see it very often. Remember, that our harvest is seasonal and tourism is significantly less during the winter months then it is in the summer.
- Why do you assert that the bags will not be visible from shore?
Answer: Because they float below the surface of the water. The pictures you see in our videos shows bags from a higher point of view and in the Mediterranean, where the salt content is significantly higher then in the Pacific, the bags to be more boyant and thus more visible.
- What do you expect the economic impact will be on kayak rentals?
- What security problems do you anticipate?
Answer: No more than usual. Once the cistern and pipeline are in place it will not be visible and the buoy and tug operations will handle their own security. We do not specifically discuss project security in the public as it compromises our strategies.
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