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In response to appeals filed by SJCA and others on issuance of the final air quality permit in 2008 for the proposed Desert Rock power plant, the Environmental Protection Agency remanded the entire permit in 2009. This is a major victory for project opponents, and a severe setback for project developers.
EPA now acknowledges deficiencies in the air quality permit for Desert Rock and is requesting reconsideration of particulate matter impacts and Best Available Control Technology applications, citing improper issuance of the permit without consulting under the Endangered Species Act, failure to complete a Maximum Achievable Control Technology analysis for hazardous air pollutants, and inadequate collateral impacts analysis for the project. This follows an earlier decision from EPA to withdraw the carbon dioxide issue from the appeals board on the Desert Rock project.
Desert Rock currently has no final permits in place.
We need to be diligent in getting after the EPA, Bureau of Indian Affairs and other agencies that oversee the permits for Desert Rock and hold them to the highest extent of our environmental laws and regulations. Ill-advised projects like Desert Rock have raised the profile on our existing coal fired power plants and coal mines in the region, combined with more awareness of the adverse air quality conditions associated with large scale energy development.
SJCA OPPOSES DESERT ROCK
SJCA has actively opposed the proposed Desert Rock coal-fired power plant (Desert Rock) for the past five years. SJCA is concerned about the implications of another coal plant being built in an area already adversely impacted by the legacy of two large coal plants (Four Corners Power Plant and San Juan Generating Station) within a huge coal complex. Desert Rock, as proposed, would be a 1,500-megawatt (MW) mine-mouth, coal-fired power plant built by Sithe Global LLC (Sithe) on the Navajo Nation, San Juan County, New Mexico on a 580-acre site in Burnham. Sithe has advertised the proposed Desert Rock facility as a clean coal-fired power plant.
Sithe is a privately held, independent power company based in Houston, Texas. The financial backers of Desert Rock are the Blackstone Group, a Wall Street equity firm that went public in 2007. Desert Rock is proposed by Sithe in partnership with Diné Power Authority (DPA), a Navajo Nation Enterprise. Desert Rock is a merchant power plant, meaning that Sithe plans to sell power on the open market and has no current contracts. Sithe has suggested that Desert Rock “off-takers” (buyers of power) include Arizona Public Service (APS), Nevada Power, and the Salt River Project (SRP) for energy primarily slated for Tucson/Phoenix and the Las Vegas markets. 0-5% of the proposed power from Desert Rock would stay on the Navajo Nation, where many citizens continue to be without electricity.
The Draft Environmental Impact Statement (Draft EIS) for the proposed Desert Rock facility was released by the Bureau of Indian Affairs (BIA) in June of 2007. The Draft EIS is available electronically at www.desertrockenergyeis.com. The Draft EIS was written by a third-party contractor, URS Corporation, out of Phoenix, Arizona, supposedly on behalf of the BIA. The Draft EIS Public Hearings were completed in the summer of 2007 with vast local, regional and national opposition to the proposed third coal plant in the Four Corners region. Over 55,000 public comments were received by BIA on the Draft EIS. Governor Richardson's statement on Desert Rock on July 27, 2007 states, " As planned this new facility will adversely impact air quality, exacerbate existing environment problems, and negatively impact scarce surface and ground water resources."[read as pdf] You can download the Draft EIS at www.desertrockenergyeis.com. You can get a good overview of the project by reading the Executive Summary and Chapter 5, Cumulative Impacts.
Sithe and DPA claimed through 2007 that they would receive a Final Air Quality Permit for Desert Rock from the EPA. SJCA, along with many other organizations and individuals, submitted comprehensive comments on the Draft Prevention of Significant Deterioration (PSD) permit (Air Quality) in November of 2006. In July of 2008, the EPA approved the PSD air quality permit for Desert Rock following political pressure from Bracewell-Giuliani (legal firm representing Sithe). The PSD permit has been completely remanded: Sithe has no air quality permit for Desert Rock.
The escalating costs of the Desert Rock plant are now projected at $4 billion with the connected Navajo Transmission Project (NTP) estimated at over $1 billion. The decline of the financial investment potential in Desert Rock has been precipitous. Project proponents (Sithe and DPA) and investors in Desert Rock (Blackstone Group) can no longer be assured that Desert Rock would be profitable given the contentious legal proceedings over permits to date, a less receptive regulatory environment in 2009, and the chaos on Wall Street. Blackstone Group may now be reluctant to be invested in a controversial project with liabilities such as Desert Rock. Any legitimate critique of the proposed Desert Rock project would point to the great financial uncertainties of attempting to build a new coal plant in an area already home to two of the highest polluting coal plants in the western United States (Four Corners Power Plant and San Juan Generating Station). The Navajo Nation’s investment in an energy project to realize financial gains and job creation would be better served through renewable energy projects, such as concentrated solar plants (CSP), as identified in the Energy and Economic Alternatives to the Desert Rock Energy Project report.
Desert Rock, as designed, would emit 12.7 million tons per year of carbon dioxide. After denying that carbon dioxide is a pollutant, Desert Rock proponents have recently addressed carbon dioxide emissions by claiming the intent to incorporate carbon sequestration/capture (CCS) capability into the design of the plant for retrofit at a later date. Funding for this pilot project CCS component of Desert Rock would be theoretically acquired through the federal government. This is disingenuous, at best, with no proven commercial application of technology currently available for CCS for a super critical pulverized coal plant (technology to be used for Desert Rock). At every turn, throughout the history of Desert Rock, project proponents have gone to great lengths to resist a thorough analysis of reducing carbon dioxide emissions from Desert Rock. Any attempt to now introduce CCS technologies into Desert Rock design must be met with deep skepticism due to the unproven CCS technologies and the huge financial factors of adding this unproven technology. SJCA will oppose any last ditch attempt to incorporate CCS into Desert Rock and will look forward to the reinitiation of all permit applications and processes for the project if Sithe/DPA actually intend to incorporate CCS into their project. In December of 2009, Sithe was denied $450 million in an application to DOE under the Clean Coal Power Initiative to pipeline a small percentage of carbon dioxide produced at Desert Rock to Texas for enhanced oil recovery.
In December, the coal ash pond breach at the TVA Kingston Fossil Plant in Tennessee raised the profile of the fallacy of “clean coal.” The life cycle of burning coal for electricity leads to many forms of pollution and materials including ashes, sludges and waste, characterized as coal combustion wastes (CCW), that should be classified by EPA as hazardous. Desert Rock would create immense amounts of CCW that would be dumped in the excavated coal mines at Navajo Mine, exposing local residents to higher levels of toxic materials (including arsenic, barium, and mercury). This practice of dumping CCW is the norm at the existing Navajo and San Juan mines which are associated with Four Corners Power Plant and San Juan Generating Station, respectively. The proposed CCW dumping from Desert Rock again points to perilous existing health risks to local residents who live in proximity to Navajo and San Juan mines, and the San Juan River between Waterflow and Shiprock, New Mexico.
No construction on Desert Rock can occur until permits are required. Of particular note is that the Navajo Transmission Project Environmental Impact Statement analysis of the 470-mile powerline needed to transmit power from Desert Rock to Phoenix/Tucson and Las Vegas, has been remanded by the Department of Interior in 2009 and is highly deficient.
SJCA is comprehensively involved in evaluating all permits required for Desert Rock and has consistently exposed incomplete studies, improper procedural steps, unenforceable pollution offset agreements, and deficiencies of the project impact analyses. Four Corners citizens should focus on communicating with elected officials on the severe potential problems with Desert Rock including the untenable existing environmental conditions (air quality and life cycle costs of coal) here, and the opportunity to invest in renewable energy projects in our region. It is time to consider the true costs of generating electricity from coal and put public health concerns first.
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With the increased recognition of the impacts of carbon dioxide (CO2) as a major contributor to climate change; State of New Mexico work to create a market-based, greenhouse gas reduction program with other Western states and California; and the formation of the New Mexico Climate Change Advisory Group; it is imperative that CO2 emissions be reduced in the Four Corners region. Existing CO2 emissions in the Four Corners region include 15.6 millions tons per year (tpy) from the Four Corners Power Plant and 13.4 million tpy from the San Juan Power Plant for a total of 29 million tpy of CO2 (source: 2002-2003 CO2 emissions as reported to EPA’s Clean Air Markets Database). Four Corners ranks as number 4 in the top ten Western Coal-Fired Electric Utility Steam Generating Power Plants for CO2 Emissions. San Juan ranks as number 8 in the top ten Western Coal-Fired Electric Utility Steam Generating Power Plants for CO2 Emissions.
Although portrayed by Sithe as a “clean, state of the art coal-fired power plant,” Desert Rock is projected (Sithe’s own numbers) to emit over 12.7 million tpy of CO2 to the atmosphere. The proposed Desert Rock facility would effectively wipe out all positive actions that New Mexico is taking to reduce greenhouse gas emissions. Sithe does not introduce any analyzed alternatives in the Draft EIS that would reduce the CO2 imprint from the proposed Desert Rock facility. The Draft EIS mentions Global Warming in the context of the connection between fossil fuel emissions of CO2 and climate change. The Draft EIS then discusses the concept of Global Dimming and the idea that there may be cooling principles at place with continued CO2 emissions for coal-fired power plants that are actually beneficial. This document is clearly indicative of the strategy of the coal industry to put a spin on Global Warming and instill doubts in the public as to the severity of the problem that has been created. There is minimal analysis in the Draft EIS of the environmental impact from greenhouse emissions and consideration of best available control technology (BACT), including carbon sequestration, to minimize CO2 emissions as a result of the proposed Desert Rock facility.
SJCA is concerned about the public health and economic costs to the Four Corners region and beyond as a result of 12.7 million tpy of CO2 added to the already compromised airshed in the Four Corners region.
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from the Four Corners Power Plant, the San Juan Generating Station and tens of thousands of existing (18,000 in Farmington area alone) and projected natural gas wells in the Four Corners region. Absent significant offsets and/or zero emissions from the proposed plant, the proposed Desert Rock facility is certain to exacerbate health and environmental problems throughout the region, nation and world.
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Projections are that Desert Rock would contribute more mercury (117-161 pounds per year, at a minimum - coal core sample analyses gave not been completed!) to the atmosphere with mercury controls only “if necessary.” Data from the EPA’s Persistent Bioaccumulative and Toxic (PBT) Chemical Program website provides year 2000 total mercury emissions from the Four Corners Power Plant (1,174 pounds) and San Juan Generating Station (1,194 pounds).
This emitted mercury is showing up as mercury deposition in virtually all of the major water bodies in the Four Corners region. These regional waters include the San Juan, Animas, La Plata rivers; Navajo and Vallecito lakes; Narraguinnep and McPhee reservoirs, and numerous water bodies found on the Navajo Nation where fish consumption advisories due to mercury contamination have been issued.
The Draft EIS for Desert Rock claims that the existing power plants are not the source for mercury showing up in our region’s waterways as methylmercury.
Given the news that New Mexico Attorney General Gary King has joined more than a dozen states challenging the EPA's rules governing mercury emissions from power plants and the quote attributed to him, “Simply put, this brief alleges that the EPA's rules weaken the Clean Air Act. Especially in New Mexico, which has the highest atmospheric concentration of airborne mercury in the nation, we feel the EPA's rules are unacceptable,” SJCA believes that stringent mercury reduction measures are more important than ever. Cap and trade of mercury emissions, as proposed in the Clean Air Mercury Rule (CAMR) would be a disaster for the Four Corners region. On February 8, 2008, a Federal Court of Appeals vacated the Clean Air Mercury Rule.
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The proposed siting of the Desert Rock facility, as currently designed, would be detrimental to the public health of citizens of the Four Corners region through increased release of air pollutants that result in the formation of ozone (Nitrogen oxides). Ozone damages lungs, triggers asthma attacks and can even cause premature death. There are literally thousands of sources (coal plants, refineries, natural gas compressors, natural gas compressors) that are contributing to the formation of ozone in the Four Corners. In April of 2009, San Juan County sits right at the 75 parts per billion standard for ozone. The proposed Desert Rock facility would exacerbate our ozone problem.
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The Four Corners region already has significant cumulative air quality problems in the form of regional haze, smog, decreased visibility and public health issues. We cannot continue to allow the high levels of mercury, carbon dioxide, nitrogen oxides and other pollutants that our adversely affecting our air quality and public health. Desert Rock would add to the existing cumulative air quality problem that is documented here in the Four Corners.
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. The Draft EIS clearly states that Desert Rock power would be marketed for Phoenix/Tucson and Las Vegas. The Draft EIS also states that the Four Corners area has disproportionate public health impacts associated with the existing environmental conditions in the region. Of particular note is the idea put forward in the Draft EIS that high cancer rates in the Four Corners are the result of natural arsenic in the soils, rather than any connection to the legacy of energy development in the region. The conclusion of the Draft EIS is that the opportunity to provide cheap power to areas far from here is more important than the public health of citizens of the Four Corners. This is an alarming conclusion by the authors of the Draft EIS and agencies responsible for oversight of public health.
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The Draft EIS for Desert Rock fails to fully analyze renewable energy options or carbon sequestration in comparison to the proposed Desert Rock project. Given the April 2007 implications of the Supreme Court (Massachusetts et al. vs. EPA, et al.) ruling that EPA should regulate CO2, the Draft EIS may be considered deficient. SJCA has provided comment analysis on the Draft EIS that includes renewable energy alternatives to Desert Rock.
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The Draft EIS fails to include complete information or analysis on coal mining, water quality and quality, groundwater testing, transmission of power (all the way – hundreds of miles - to Phoenix/Tucson and Las Vegas) and cumulative impacts. In addition, there is minimal information on the dumping of coal combustion wastes (coal ash) in excavated coal-mines as a result of burning coal for Desert Rock and the contribution to adverse water quality impacts. The coal combustion waste issues of Desert Rock should be considered with way more detail given the December 2008 coal ash pond breach in Tennessee.
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There are large amounts of selenium reaching the San Juan River in the Four Corners Region. Desert Rock would add to this surface water quality issue by releasing high levels of selenium that would end up in the San Juan River, imperiling public health of Four Corners citizens and endangered species (including Colorado pikeminnow and Razorback sucker).
- Desert Rock would need almost 5,000 acre feet/year of water to cool the facility. The source of the water has been reported as groundwater, however test drills have not been completed. Could it be that Desert Rock thinks that they will use San Juan Basin water? SJCA has requested documents through the Freedom of Information Act (FOIA) concerning preparation of the Draft EIS and the water, coal and land leases for the project. Despite these requests and appeals, the BIA has failed to provide the documents. In April of 2008, SJCA and Dine CARE were forced to take legal action on the FOIA request to BIA [see complaint here - pdf]
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