Today, for my fourth post number on the thread about comments provided to DEQ on the scope of work from the poultry litter working group, I have reviewed and will summarize the letter sent by the Southern Environmental Law Center and the Shenandoah Valley Network. This letter was dated April 25 and signed by Cale Jaffe and Kate Wofford; the version I have is a PDF, so I cannot cut and paste the entire document, thus the summary below.
The letter begins by acknowledging that the DEQ’s and DCR's efforts are meant to restore the Chesapeake Bay and this study is part of that, contributing by analyzing options to reduce net nutrient load from the Shenandoah Valley. The letter also “acknowledges and incorporates by reference” comments that were provided by other significant stakeholders, specifically, the Chesapeake Bay Foundation and the National Park Service.
The letter outlines three general concerns about the scope:
1. The focus on a single solution – a proposed 55MW litter to energy “incineration and power generation facility” – the draft scope of work says “The purpose of this work plan is to guide research to determine the net environmental benefit of a major litter to energy project. The letter goes on to compare that to a neutral focus considering “the net environmental impacts of a major litter to energy project.”
2. The “short shrift” given to a review of alternatives – the only alternative mentioned in the scope they reviewed was a subsidy for bulk transport of litter out of the Chesapeake Bay watershed. The alternatives that should be considered include on-farm technologies, smaller centralized incinerators, improved land application and management methods at the farm level, anaerobic digestion, gasification or thermal oxidation.
3. The draft scope ignores air quality and public health concerns. Here there is a reference to public and stakeholder comments at the 2/11/11 and 3/28/11 meetings which were focused on these potential impacts, yet the DEQ scope ignores them.
Additionally, the letter offers six further comments:
a. The scope of the study should consider air deposition of nutrient loads, since nitrogen compounds can be distributed this way and would likely make their way into the watershed;
b. The scope should include the use of an approved EPA modeling technique for the air deposition analysis by looking at three alternative potential sites and the impacts that result from local climate conditions at them;
c. The scope should provide an expanded description of how land application alternatives will be evaluated; there is a reference to the use of alternative commercial fertilizers “in correct agronomical rates” but appears to assume that there would be no net impact from them;
d. The scope needs to include an evaluation of the storage and transport stages is considered, those handling activities that occur prior to incineration, since there is the potential for watershed impacts here;
e. Since a litter-to-energy plant is not proposed as a replacement for any retired generator facilities, it is an additional source of pollution – there is no real benefit of reducing emissions from the impact of new technologies, only the impact of adding to them, given this situation; and
f. The scope should analyze the ability to meet other standards for poultry litter feedstock generating units.
The letter concludes with and encouragement to strive for the best possible study – as opposed to outright opposition to the plant.
For my fifth and final post on this short series, I hope to have a summary of the scope of work – this will be the draft version these recent posts were responding to – and I will try to have that up on the blog by Monday.
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