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The Desert Rock Draft Environmental Impact Statement (Draft EIS) Public Hearings were completed in the summer of 2007 with vast opposition to the proposed third coal plant in the Four Corners region. Although Sithe Global Power, LLC and Dine Power Authority (DPA), the project proponents, would like people to believe that this is a “done deal,” there are significant hurdles for Desert Rock. As of April, 2008 the proposed project has acquired none of the primary permits that would allow the project to proceed. 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.desertrockenergy.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. San Juan Citizens Alliance (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. As of April 2008 this PSD permit has not been issued by EPA due to the extensive comments concerning the proposal to site a third coal-fired power plant in the already degraded San Juan basin airshed as well as legal interpretations over EPA responsibilities concerning greenhouse gases. On January 17, 2008 the Bracewell-Giuliani law firm (YES, as in Rudy Giuliani, Former Presidential Candidate and Mayor of New York City) submitted a Notice of Intent to Sue letter concerning EPA's legal responsibility to issue the Final PSD permit for Desert Rock in a timely manner. As for the claims that the Navajo Nation and Sithe have been waiting for their PSD permit for four years, perhaps it is because they have never complied with providing accurate information or evaluations pertaining to air quality in the region. See the Bracewell-Guiliani letter from Jeff Holmstead (former assistant administrator for air and radiation at the EPA): [read as pdf] On March 18, 2008 Bracewell-Giuliani law firm, on behalf of Sithe, sued the EPA, for not issuing the PSD permit. See the complaint [pdf] here. The following day, the New Mexico Environment Department issued a Press Release concerning the suit [read as pdf].
SJCA has been actively opposing the proposed Desert Rock coal-fired power plant (Desert Rock) for the past three years. SJCA is working with a broad coalition of groups concerned about the implications of another coal plant being built in an area already adversely impacted by the legacy of two large coal plants 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 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 (Diné Power), 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 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.desertrockenergy.com. The Draft EIS was written by a third-party contractor, URS Corporation, out of Phoenix, Arizona, on behalf of the BIA.
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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 Mercury Rule.
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The proposed siting of the Desert Rock facility, as currently designed, would be detrimental to citizens of the Four Corners region through increased emission levels of CO2, mercury and pollutant contributions that result in the formation of ozone. 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.
San Juan County, the Cities of Aztec, Bloomfield, and Farmington, the NMED, and the EPA signed the San Juan County Early Action Compact (EAC) on December 20, 2002. The EAC entails milestones through 2007 that are designed to keep San Juan County in attainment of the federal standard for ground-level ozone. If San Juan County cannot remain in attainment for ozone, there would certainly be significant economic and environmental repercussions. The proposed Desert Rock facility represents serious implications that apply to climate change, mercury policies and ozone attainment for the State of New Mexico. Note that the EPA is tightening the rules for ground-level ozone to 75 ppb. EPA proposes to set the primary (health) standard to a level within the range of 0.070-0.075 ppm (70 -75 ppb)
It is essential that state of New Mexico, state of Colorado, and Federal legislators be involved in siting and design decisions for the Desert Rock facility, to understand potential alternatives (including renewables, demand-side management, energy efficiency) that preclude the need to build more coal-fired power plants in our state.
The Draft EIS uses the same deficient monitoring and modeling of air quality that was used in the Draft PSD permit.
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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 recent implications of the Supreme Court ruling that EPA should regulate CO2, the Draft EIS is 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 in excavated coal-mines as a result of burning coal for Desert Rock and the contribution to adverse water quality impacts.
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There are massive 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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