A Sierra Club reply to Brad Lofton, copied to the Valdosta Board of Education and others.

-jsq

From: Joy Towles Ezell
Date: Wed, 29 Sep 2010 20:27:54 -0700 (PDT)

As the former Conservation Chair and the former Energy Chair of the Florida Chapter of the Sierra Club, and as the former Energy Chair of the Big Bend Group of the Florida Chapter, I must “set the record straight”. Today’s National Sierra Club policy is not as strong as the Florida Chapter’s policy was against burning biomass. I can speak only to Florida’s SC policy, so I submit to you the policies of the Florida Chapter and the Big Bend Group concerning the burning of biomass during my tenure, with our press release concerning the now defeated biomass plant in Tallahassee:

The Florida Chapter Policies were also published, in part, in The Pelican, Spring 2004, the official Florida Chapter newsletter.

Here is the Chapter policy on ‘biomass.’

Florida Chapter Sierra Club policy opposes biomass production:

“We continue to oppose the development of biomass production as an
alternative to solar and wind power. Biomass production depletes the
environment by decreasing topsoil, using more water, fertilizer and
diesel fuel than it is worth and creates more pollution.”
Page 8. http://florida.sierraclub.org/Pelican/spring04.pdf

For Immediate Release: 01/05/09

Contact: Joy Towles Ezell, Big Bend Sierra Energy Chair,

850 584 7087 office & fax 850 843 1574 cell

Susie Caplowe, Big Bend Sierra Environmental Justice Chair, 850-567-2448

The Big Bend Sierra Club

The Truth about BG&E and Biomass in Tallahassee

The Big Bend Group of the Sierra Club has opposed biomass in general since adopting the Florida Chapter’s biomass policy in 2004. That policy states in part: “We continue to oppose the development of biomass production as an alternative to solar and wind power. Biomass production depletes the environment by decreasing topsoil, using more water, fertilizer and diesel fuel than it is worth and creates more pollution.” http://florida.sierraclub.org/Pelican/spring04.pdf

1. The proposed biomass plant is really nothing more than an “incinerator in disguise.” As with all incinerators, local air quality will be impacted and Leon County already has the 2nd worst air quality of any county in Florida.

2. The specific air filtering equipment (including bag houses and precipitators) that has been promoted by BG&E and their public relations firm as “state of the art” is actually Edsel-era equipment originally developed in the 1940’s, 50’s, and 60’s.

3. BG&E, the company proposing the plant has a poor track record as a responsible corporate citizen, both in terms of environmental stewardship and caring for communities. BG&E was formerly known as FERCO and while the name has changed, the players are the same (Glenn & Milton Farris). FERCO established a biomass gasification unit in Burlington Vermont but the company declared bankruptcy after settling a lawsuit with the surrounding Riverside neighbors due to air, noise, water, dust, soil contamination and pollution that caused the properties to decrease in value. FERCO left the city with $2 million in debt and with serious groundwater contamination. According to the Burlington Electric Dept, the gasification unit “seemed just like bad business” and tests at the McNeil plant ended in 2001. The gasification facility sits, unused. “We shut off the lights in 2001,” Irving (project manager) said. “The whole thing has left a real bitter taste in our mouth.”

4. The BG&E biomass gasification incinerator will be exempt from major provisions of the Clean Air Act. Air pollution in excess of Clean Air Act standards will be produced included many toxic substances that will be carried by prevailing winds to communities all over the area.

a. The “char combustor” is allowed to emit 10 pounds per hour (each) of particulate matter, NOx (Nitrous oxides) and CO (carbon monoxide). (Page 10 of the air permit);

b. the combustion turbines are allowed to emit 17.2 pounds per hour of carbon monoxide, 17.2 pounds per hour of NOx, and 10 pounds per hour of particulate matter. (Pages 15-16)

c. We can see that this facility is not entirely a gas burner. Almost one-third of the heat input, and more than one third of the air emissions, come from burning solid materials.

d. From the DEP “public notice of intent,” cover letter dated October 24, 2008)
http://www.dep.state.fl.us/Air/permitting/construction/tallahassee/BGENOTICE.pdf )

Pollutants Estimated Emm. (TPY) Potential Emm (TPY)
Carbon Monoxide (CO) 204 231
Nitrogen Oxides (NOX) 197 214
Particulate Matter (PM/PM10) 114/114 156/156
Sulfur Dioxide (SO2) 83 83
Volatile Organic Compounds (VOC) 18 18
Hazardous Air Pollutants (HAP) <5 <5
————————————- —- ——
total tons per year 621 707
total pounds per year 1,242,000 1,414,000

e. The “potential to emit”, the most important number to consider, is what the facility could put out without violating its air permit. Sometimes facilities claim that their “expected” emissions are far less, but that is not the case here: the “potential is 1.4 million pounds per year and the “estimated,” or “expected” is 1.2 million pounds per year. To put this in plain terms, the applicants admit that they expect to emit over 1.2 million pounds of health-damaging air pollutants every year (3400 pounds per day), and would be allowed to emit over 1.4 million pounds per year (3900 pounds per day). This means a potential of two tons per day of air pollutant emissions.
f. There are many points to consider in the permit. The proposal is to maintain on the site an inventory of 10,000 to 14,000 tons (28 million pounds) of “wet biomass.” (page 6) This would apparently be kept in covered piles. There is considerable potential for emissions of hazardous and odorous air pollutants, as well as mold spores and allergens, from such an inventory, especially in the warm and humid climate of Florida. There is also a possibility of spontaneous combustion which could be difficult to extinguish and would be very hazardous and unpleasant to be around. We know of no evacuation plan for the neighborhoods and schools in the area in case of leaks, hazardous emissions, or explosions.
g. It’s also worth noting that diesel locomotives tend to be very high emitters of toxics. Judging from the amount of trackage in the area, the surrounding communities are already “disproportionately impacted” by rail operations, which would increase if this facility was built. Approximately 5200 train car loads per year of fuel shipments are expected and these would be allowed to be spotted for unloading at all hours of days and nights (page 5-6). (The overall fuel consumption seems to be estimated at 365,000 wet tons per year.)

5. This pollution will disproportionally impact a predominately African-American neighborhood and will have a devastating effect on South Side development and revitalization. This violates the long-held position of the Sierra Club against environmental racism.

6. Florida‘s own flawed definition of biomass will allow the plant to burn much more than “woody waste” and like materials. The plant will be allowed to burn much more toxic substances like sludge from paper mills, chemically treated scrap lumber and other sources that increase cancer risks throughout the area. The new Florida definition of biomass allows biomass burners in Florida to burn many “fuels”: Biomass-energy production is the production of energy (electricity; liquid, solid, and gaseous fuels; and heat) from biomass. Biomass may be any organic matter including dedicated energy crops and trees, forest manufacturing products and waste, agricultural food and feed crop residues, aquatic plants, wood and wood residues, animal wastes and other organic waste including the aerobic and anaerobic break-down product of any organic matter and waste streams. By definition, pulp and paper mill wastes, such as toxic sludge containing dioxins and furans would be allowed as fuels. The owners have not been forthcoming in the actual fuels to be used; they have said at various times: wood chips, Arundo Donax (a dangerous invasive exotic plant species), paper mill wastes and yard wastes. According to state statute any and all of these could be incinerated as well as poisonous arsenic/CCA treated wood and municipal solid waste. The permit and state law are at odds, which may lead to fuels not included in the permit to be legally burned.

6. Biomass generates unsustainable land uses that may release soil carbon to the atmosphere. Accelerated and poorly-managed harvesting of forests and crops as fuel, accompanied by the conversion of natural ecosystems to fuel farms, such as the growing of the BG&E biomass fuel source called “Arundo donax”, will increase global warming and degrade the environment.

7. Biomass burners are not “CLEAN, RENEWABLE, and SUSTAINABLE” merely because industry lobbyists and legislatures have passed laws that say they are. Massive new biomass energy resources are NOT available without risking soil and forest health, given the lack of commitment by governments and industry to preservation, restoration, and conservation of natural resources.

8. This biomass plant could easily begin burning garbage for power generation when the intended “CLEAN” fuel sources supply runs short.

9. Burning materials is NOT clean energy. Combustion for energy production is responsible for much of the world’s air pollution and, indirectly through deposition, much of its water and land pollution as well. These pollutants, including smog, acid rain, and persistent bioaccumulative toxics, threaten human health and the global ecosystem. All fossil fuels and most biomass technologies aggravate global warming by producing CO2. Unless very carefully managed, biomass operations may not be sustainable and may add to the CO2 problem because of damage to soil health or failure to assure sustainable regrowth of the fuel stock. Biomass is in principle renewable, but native soils hold substantial carbon, mostly in root mass, and while it is possible to preserve soil carbon balances, conventional agricultural practices rarely do so. Much of the debate surrounding biomass technologies involve assessing their environmental impact against the benchmark of coal-fired energy production. We are increasingly concerned that biomass projects may rely on or may create incentives for fuel derived from unsustainable forestry and agricultural practices.

REAL CLEAN SOLUTIONS

The Big Bend Group believes that energy use should be minimized through conservation and efficiency, and that sustainable, renewable energy resources be utilized for human needs. In the near future, efficiency is the only “energy source” which does not incur some environmental damage and which is available immediately in generous supply. Sophisticated building construction, efficient appliances, recycling, modernized industrial processes, “smart” buildings that turn off lights and lower the temperature in unused rooms, programmable thermostats, public transit supplemented by fuel-efficient cars, and many other innovative technologies can reduce energy use tremendously, usually while saving money.

• The Big Bend Group believes that the City of Tallahassee has not adequately encouraged an effective policy of energy conservation and efficiency. We believe that residents, taxpayers and businesses are willing to cut back the electric use successfully.
• The City’s current power plant fuel, using natural gas, is less expensive than depleting non-sustainable forest resources. Yard waste can and should be composted, creating jobs, and providing for soil health.
• Solar voltaic power is becoming less and less expensive. State rebates at 50% are available for residential and commercial customers, offering income tax deductions.
• The Big Bend Group believes that effective conservation and efficiency strategies would encourage small local business and create jobs; and that there is no need for any new power plant, especially a polluting, resource wasting, biomass example of environmental injustice.

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