Thursday, October 29, 2015

Guest article: Questions on air pollution from L'Anse Warden biomass plant and postponed public hearing

These railroad ties and wood chips, to be burned in the L'Anse Warden Electric Company's biomass plant, appear to be stacked near a wetland. (Photo courtesy Diane Miller)

By Diane Miller*

As a lover of clean air and wild places, and a communication professor who emphasizes the need to become informed and participate in the democratic process, I have some bad news, some good news, and a few questions that hope you can help me with.

Bad news: The L’Anse Warden Electric Company, LLC, markets itself as "green." This is bad news because this biomass incinerator burns up our forests and our tax dollars, and it’s allowed to spit out more kinds of serious air pollution every single day than most coal-fired power plants in Michigan.

Good News: The Renewable Operating Permit for the Warden Plant expires at the end of this year. This is good news, because our democratic process provides for public input on the renewal of the plant’s permit. That is, we are allowed to communicate with the regulatory bodies charged with monitoring the plant’s environmental effects, with the idea that our public officials could stop allowing private companies to release toxins into our air.

Bad news: An important element of this public comment process -- a public hearing that had been scheduled for this evening -- October 29 -- has been postponed because, according to an October 21 Department of Environmental Quality (DEQ) press release, "the company’s latest emissions testing indicates it may not be able to comply with air quality regulations."

Huh?

The press release gives this explanation: "The DEQ cannot move forward with the current draft renewable operating permit if a non-compliance issue exists."

Is this good news?  That is, does this mean that since the plant is not complying with emissions limits, the hearing is not needed because the plant will shut down -- either immediately or on January 1? Nope. According to DEQ spokesperson Ed Lancaster, the plant has successfully applied for an "Application Shield." This seems to mean that the plant’s admission of non-compliance is one way to avoid having to comply: even after the current operating permit expires, Warden gets to keep burning.

Diane Miller, left, the author of this article, joins Catherine Andrews, right, in a presentation on biomass at the Portage Lake District Library last April. Since then both of them have been researching the emissions from the L'Anse Warden biomass plant. (Photo by Keweenaw Now)

According to the air quality terminology link at epa.gov, "A permit shield can protect a source from enforcement of an applicable requirement under two circumstances: 1) where that applicable requirement has been included in the permit and is therefore enforced through the permit, or 2) where it has been determined that the requirement does not apply to the source. Under no circumstances should a permit shield be used to exempt a source from a requirement to which it is subject."

Huh?

If the requirement is included in and enforced through the permit, why would the application shield be needed? If the second scenario is the case, why does the requirement suddenly not apply? Let’s make sure we don’t forget this part of the definition: "Under no circumstances should a permit shield be used to exempt a source from a requirement to which it is subject."

Meanwhile, although we have been told that the current permit is not moving forward, the process itself does seem to be moving forward after all: According to Lancaster, the DEQ expects to hold a hearing sometime in January -- a much more difficult month than October in which to gather concerned citizens in L’Anse Michigan. The DEQ is required to announce the date 30 days before the hearing.

Given this confusing situation, it is good news that the DEQ will extend the period during which it will accept public comment through telephone and mail -- we’ve got that contact info for you at the end of this article. But first, I have a couple of more questions. How do you feel about renewing the operating permit of a facility that is referred to as "green," but according to the August 10, 2015, draft, will be licensed to:
  • Burn natural gas for up to 49 percent of its annual heat input?
  • Burn old tires -- 32,800 TONS per year?
  • Burn railroad ties -- 72,078 TONS per year of the creosote-soaked variety, and 6 TONS per day of extremely toxic pentachlorophenol-soaked wood? (Who will be monitoring which railroad ties are which as they go into the hopper?)
  • Burn 44,280 TONS of wood "fines" (small particles) and bark every year? (Aren’t "fines" former trees?)**
Old tires at the L'Anse Warden plant are used for Tire Derived Fuel (TDF). (Photo courtesy Diane Miller)

These are just some of the practices that contribute to the Warden Plant’s reputation as one of the world’s worst biomass plants. Meanwhile, ALL biomass plants share these core problems that make all large-scale biomass burning for power generation the opposite of "green":

1. Although biomass burning is touted as "carbon neutral," it is not. Burning wood is simply not carbon neutral -- even if invested parties say it is. Biomass produces about 40 percent more emissions than coal for every unit of energy generated. While it is true that "waste" wood otherwise left on the forest floor would also emit carbon, this decomposition takes years, sometimes decades, and happens to be essential to the health of the forest. It also takes decades, even centuries, for "harvested" forests to grow back -- if they can. Large, living trees, meanwhile, absorb large amounts of carbon -- currently as much as 15 percent of our total emissions. The small trees planted to replace them cannot do this job. So, to think of biomass burning as carbon neutral seems a lot like using your credit card to pay for an expensive dinner, then somehow hoping that long after it’s over, you -- and your children and their children’s children -- will pay the bill and its interest, which has grown faster than the children’s ability to pay.

2. Biomass plants do not burn only sawdust or other "waste wood" -- instead of whole trees. Google "aerial view of biomass plant," the celebrated McNeil plant, for example, in Vermont, and see how it is surrounded by stacks of what used to be forest, ready to help charge our cell phones and our hair dryers. But what is "waste wood" anyway? We know how dead limbs are needed by the forest, to build soil and provide homes for animals. As Mother Nature would tell us if we asked, there is no such thing as "waste wood."

3. Biomass burning does not lead us away from fossil fuels. In fact, the practice depends on fossil fuels in a variety of ways. First of all, it takes a lot of diesel fuel and natural gas not only to ignite the wood, which is often green and difficult to burn, but also as a backup when the plants break down; and they frequently do. Fossil fuels power the large equipment required to cut, gather, and haul wood for burning. And now that our forests’ soils have been depleted by third and fourth cuttings, petroleum-based fertilizers are being applied in some areas by airplanes. So how does anyone make a profit doing this? Because of government subsidies for "green" energy, plant owners can still make a profit even though their practices are not cost- or energy-efficient.

4. Biomass burning is not environmentally friendly. The list of heavy metals and volatile organic compounds released from biomass plant smokestacks is too long to include here, but you can see which ones the Warden Plant is allowed to release by reading its operating permit.** Worse, the increased demand for forest products exacerbates the reduction in wildlife habitat that has become a crisis for many species -- again a long list, easier to spell, but more painful to think about.

This sample of black melted snow taken from the playground of the BHK pre-school located near the L'Anse Warden plant was exhibited at the April 2015 presentation on biomass at Portage Lake District Library. Since then it has been analyzed at Michigan Tech and determined to contain particles of tires. Black snow on children's clothing raised concerns by parents and teachers about pollution from the plant. (Photo by Keweenaw Now)***

5. There is not enough wood to provide a meaningful amount of energy for our needs. According to ecologist Marvin Roberson’s article in the April 27, 2014, Detroit Free Press, "If we used all the forest growth from all of Michigan’s forests for biomass, including state parks, all private, protected and public lands, and closed down all current consumers of timber (lumber, paper, etc.), we would generate less than 7 percent of Michigan’s electrical needs." Indeed, if biomass burning were the sustainable practice it is touted to be, shouldn’t a country who engages in it be able to rely on its own resources? European countries, including Germany and Finland, don’t. Their imported wood chips are our exported former forests riding on a boat. Worst of all, while the burning of forests, tires, and trash has provided a measurable amount of electricity, it does not seem to have reduced the amount of electricity produced from other sources. Rather, we just keep using more.

I am not attacking people who burn wood to heat their homes. I do this too. I’m talking here about large-scale burning for electricity -- and ALL biomass plants fall into this category.

I could go on. But don’t take my word for it. You can look these things up for yourselves, starting with the Warden Plant’s (Draft) Renewable Operating Permit.**

Then, please, please, please make a comment to the Department of Environmental Quality. (The DEQ is still accepting comment until the public hearing date, which has not yet been announced but will probably be held in January.) Here’s how to submit comments:
Contact Ed Lancaster by calling 906-228-4853 or writing to him at the Upper Peninsula District Office, Michigan Department of Environmental Quality Air Quality, Air Quality Division, 1504 West Washington St., Marquette, MI 49855.

Editor's Note:
Just after Diane Miller submitted this article, the DEQ announced early this week that it is also seeking public comment about proposed changes to its Air Pollution Control Rules. The extended comment period on these changes runs through Dec. 18. Two public hearings will be held on Dec. 7, 2015, in Lansing. (It is not clear whether this affects the ROP for the L'Anse Warden plant.) Click here for details.

Notes:

* Guest writer Diane Miller is a former Keweenaw resident and former Finlandia University communication professor. She now teaches at a community college downstate.

** See the Aug. 10, 2015, Draft Renewable Operating Permit for the Warden Plant.

*** See our Sept. 16, 2015, article, "Groups cite deficiencies in draft air permit for L’Anse Warden plant, potential health hazards from emissions."

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