No Altamont Power Plant

I wrote a letter to PG&E to accompany the petition that was collected by our many volunteers in October.  Today I received a response from PG&E’s Vice President of Energy Supply, Roy M. Kuga.

The most important thing in the letter I received was the following declaration by Mr. Kuga:

“PG&E is not presently considering this project as a potential electricity resource…”

This is great news for Mountain House!

This is a very big thing to have this information coming straight from the pen of a top official at PG&E.  I think we can all breathe a lot easier now about the immediacy of the threat of the plant being constructed.  Unless there is someone to sell the power to, the plant will not be built.

While we are celebrating this very significant victory, we should recognize that this is not a guarantee that the plant could not still be built at some point in the future.  It does still have valid permits until 2011 (subject to some amendments).  Note the use of the hedge “not presently” in the statement above.  I think we have to interpret this as meaning it has not been ruled out in the future.

With those caveats in mind, this is a big victory for our community and I want to thank everybody for their support and help.  I will post the full text of the letter shortly.

I communicated with PG&E today about the “shortlist” of competitors for power purchase agreements.  They said due to the confidentiality of the process, they would not share the results.  I asked when information would be made public about who has or has not been awarded power purchase agreements, and they have not responded to that request.

This is disappointing.  When I get any more information about when we might know something about potential contracts, I will share it.

On Oct. 20th, PG&E will announce its shortlist of competitors for power purchase agreements.  This is important.  No power purchase agreement, no plant.

If Calpine is on that list, then we redouble our efforts to discourage their selection for a contract.  If Calpine is not on that list, that would be a major victory for Mountain House.  It would not be a final death blow for EAEC as they could still get a contract at some point in the future before their permits expire, but it would be a big step in that direction.

As soon as I know the results, I will post them here.  Wish us all luck.

Something to keep in mind to have a clear understanding of the visual impact of the plant on our community is the visible plume that the plant will emit.  According to the 2002 report, one of the models they used estimated that 10% of the time, the plume will be 3490 m, or 2.16 miles long. Here’s a few 2.16 mile long lines from the center of the plant site, in the direction of our community:

View Larger Map

Depending on the wind direction, this may or may not pass directly over our homes, but the sheer scope of the plume should be evident, at least. The maximum plume size was estimated as over 5,000 m by one model, and over 10,000 m by the other model. That’s over 3 and 6 miles, respectively.

My wife and I spent several hours this weekend towing our two small children around the neighborhood to get the word out to our neighbors about the plant.  We offered a small flyer with some key facts, and also presented the petition to PG&E for signatures.   We got Questa done first, as there aren’t that many folks out there yet and they would be the most affected, and then we did Wyndham, Stratford, and a start on Hawthorne.   Here’s a map of what we’ve covered so far:

View Larger Map

This is a big undertaking, and we are going to need a lot of help if we are going to be able to complete coverage of Mountain House in the next couple of weeks, before the announcement of PG&E’s shortlist of competitors for the contract on October 20th.

If you can help out by covering a neighborhood, or even your street, please send email to stopmhpowerplant@yahoo.com, and we will send you the flyer we are using, as well as petition sheets that you can print.  Or you can arrange to come by our house and pick up our preprinted ones.  We will even deliver them to you if possible, and we will also come by to pick up signed petition sheets.

Our experiences so far are that, first, about 90% of our neighbors had no idea about the plant at all.  The other 10% or so have heard something about it, but didn’t realize it was so close, or so large, or that it was permitted without any analysis of our health risk.  We’ve met a few people who have been following it online and had signed the online petition.

The second thing I’ve noticed is that we live in a great neighborhood.  I haven’t had a single unpleasant experience yet in talking to my neighbors.  The vast majority are very supportive and thankful for what we were spending our Saturday and Sunday doing.  It’s a great way to get out and meet your neighbors. Can you help us fill in a little more of the map?

Update Oct. 8th:  Avondale and Hawthorne have now been covered and the coverage map updated.  We have volunteers for Colebrook, Glenmore, Marbella, Palisades, Roxbury, Toscana, and Cambridge Place.  We are still seeking volunteers for all remaining neighborhoods not listed.

The 2002 Environmental Impact Report seems to indicate that MHCSD recycled water is necessary for the operation of the plant.  In that report, the CEC  first considered a scenario where the EAEC would only use the Byron Bethany Irrigation District’s (BBID) water.  They concluded that BBID’s water supply alone is insufficient to meet the needs of both the plant and BBID’s other customers:

Water and Soil Resources

Page 5.14-20:

“When EAEC’s proposed raw water demand is added to BBID’s other demand projections, staff finds that there is insufficient fresh (raw) water supplies to serve all of BBID’s demands as early as 2010 and thereafter for essentially the balance of the life of the project (the next 25 years) for both average and peak annual.”

The bold emphasis is mine.  The report goes on to state in the final paragraph of this section:

“This effect is in conflict with CEQA guidelines as specified under Appendix G – Environmental Checklist Form, Section XVI – Utilities and Service Systems, posing the question, “(w)ould the project: d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed”? Because BBID may be overcommitted in the near future, it is likely that without maximum use of local recycled water there would not be enough water to serve EAEC and BBID’s other customers. This would then result in significant adverse impacts to water supplies and to other users of this supply.”

Bold emphasis mine.  The next section goes into how they can use MHCSD water (the local recycled water referenced above) to get around this deficiency.  Now, apparently, MHCSD did agree to supply this water.  Without prejudging the nature of his involvement, I have queried Paul Sensibaugh, the General Manager of MHCSD, for his thoughts on the matter.  The letter I have sent him via email is show below.  I will be sharing any response I get from him.

–

Mr. Sensibaugh,

This is an open letter that I am sharing with the residents of the community.

I am a resident of Mountain House and am gathering information on the issue of the proposed EAEC plant.  As I understand, MHCSD sent a letter of intent in 2002 to the CEC to supply recycled water to EAEC should it be built.  I have seen your name as involved in some manner in those negotiations in the CEC documents.

According to my reading of the 2002 EIR, the use of MHCSD supplied recycled water is a precondition of the permitting of the plant, as the Byron Bethany District - after some initial claims to the contrary by EAEC, but rejected by CEC - does not by itself have sufficient capacity to supply the plant going forward, c.f. Section “Raw Water Supply” beginning on page 5.14-16 in the Water and Soil Resources section of the  2002 EIR.

Speaking for myself, I am concerned that by agreeing to supply such water, MHCSD has potentially enabled the construction of what will be a serious detriment to the desirability of our community.

I would like to hear your thoughts on this matter about which many residents are now deeply concerned, as we become more aware of the nature and scope of this proposed power plant project.  As this is an open letter, be aware that I do intend to share your response with our residents on the internet so we can all come to a clearer understanding of the situation.

Thanks,
Robert W. Anderson

–

The more I read and understand this 2002 environmental impact report, the more disappointed I become in the processes which pass for protection of our citizens and environment in this state.

Consider the inclusion of issues relating to Mountain House in the report.  It doesn’t take long to find a pattern:  Whenever it was advantageous for Calpine’s interests to include Mountain House in their analysis, they included it.  Whenever it was inconvenient to Calpine’s interests to include Mountain House in their analysis, they pretended it didn’t exist.

Let’s take a look at two of the different sections of the report.  The first being the issues surrounding the use of water, the second being the issues surrounding public health risk.  Let’s compare the “Setting” sections present in both reports.

Water and Soil Usage: “The proposed site is located approximately 8 miles northwest of the City of Tracy, 12 miles east of Livermore, 5 miles south of Byron, and less than 1 mile from the Mountain House community, a new town starting Phase I construction.”

Public Health Risk: “This site is approximately 8 miles northwest of the City of Tracy, 12 miles east of Livermore, 5 miles south of Byron, and less than 1 mile from the San Joaquin County border (EAEC 2001a, pages 8.6-1 and 12-1).”

Notice anything different? We exist as long as they want to use our water, and don’t exist when they have to evaluate our health risk.

Taken out of context?  Not in the slightest.  The phrase “Mountain House community” or MHCSD appears in the Water and Soil Resources 102 times, all in reference to our community supplying them with water.  In the context of public health risk, our community is referred to, well, actually never.  Not a single time.  The phrase “Mountain House” appears once, but it is in reference to the Lammersville Elementary school, not our community.

That the rank hypocrisy in trying to “have it both ways” is outrageous and offensive goes without saying.  This will not stand.

In addition to the environmental impact report claiming that there are “few residences” in the vicinity of the site, there is the crucial issue of “sensitive receptors” which apparently have special consideration under the law.  A “sensitive receptor” is described in the report testimony as:

“A sensitive receptor, for purposes of a public health analysis, is an establishment that houses sensitive individuals (e.g., children, the elderly, and individuals with respiratory diseases), such as a school, hospital, a daycare facility, or a nursing home.”

The report claims:

“The applicant indicated, and staff verified, that there is one “sensitive receptor” within a 3-mile radius of the project site (EAEC 2001a, pages 8.4-8, 8.12-1)”

This may have been true in 2002.  However, today, there are at a minimum 12 “sensitive receptors” within a 3-mile radius.  They are:

1. Wicklund Elementary School
2. Bethany Elementary School
3. Brooke’s Busy Bees Day Care
4. Future Stars Daycare
5. Happy Home Day Care
6. Junior Art Studio and Day Care Center
7. Little Star Daycare
8. Love’s Family Preschool and Childcare
9. Mary’s Little Lambs
10. Mountain House Monkeys - Preschool & Daycare
11. Mountain House Preschool
12. Precious Babies Child Care

This is important primarily for the reason that all of these “sensitive receptors” are downwind from the site, whereas the only sensitive receptor used in the original analysis is not downwind.

This comes into play in the health risk assessment in, at a minimum, the following specific way. The report says:

“The applicant’s estimates of the EAEC’s potential contribution to the area’s carcinogenic and non-carcinogenic pollutants were obtained from a screening-level health risk assessment conducted according to procedures specified in the 1993 California Air Pollution Control Officer’s Association (CAPCOA) guidelines. The results from this assessment were provided to staff along with documentation of the assumptions used (EAEC 2001a, pages 8.1-42 through 8.1-44, and pages 8.6-4 through 8.6-8). This documentation included:
Pollutants considered;
Emission levels assumed for the pollutants involved;
Dispersion modeling used to estimate potential exposure levels;
…”

Bold emphasis mine. Dispersion modeling means more or less “where the wind blows the toxins.” Given the wind patterns with which we are all too familiar, we know from a common sense perspective that the upwind/downwind distinction is of critical importance in determining where the toxins will be most concentrated. By chance, I have done similar kinds of modeling professionally, and know that no matter how they modeled this before, that model is now irrelevant using the assumptions that they claimed to have used.

This entire analysis must be reconsidered from scratch. The language of the extension grant does not require this. I intend to work with the CEC to correct this serious mistake.  Preferably by simply voiding the permit and asking Calpine to start over if they want to pursue this in 2008 rather than in 2002.

Here’s the document which approved the extension a few days before the permits were set to expire:

Order Approving Extension of the Deadline for Commencement of Construction

Note that while the extension is granted, it does come with some limitations.  Amendments to the certification are required in the areas of air quality, Hazardous Materials, Soil and Water, and Transmission System Engineering.

While this is better than nothing, the amendments requested seem very minor and do not address the fundamental problems of the proximity of this massive plant and the schools, parks, and residents of Mountain House.

For example, in the area of air quality, compliance with new air quality standard are required, and renegotiation of “mitigation fees” are required.  No new health risk assessment is being required.  This is absolutely unacceptable.

In the original Environmental Impact Report document, linked to below, the following text accompanies the Public Health section of the report regarding the “Setting” of the site of the plant:

“This area of rural Alameda County is sparsely populated, as it is zoned for agriculture, electric utility corridors (such as substations, transmission lines, and wind farms), highways, recreation uses, and water management projects, with the actual project site currently used for agriculture.  Few residences are located in the vicinity of the site.”

Bold emphasis is mine. This is clearly false now (or, at best a snow job, if analysis was limited to strictly Alameda County), and the subsequent analysis is then plainly invalid.  However, the extension granted by CEC is not requiring a re-evaluation of the public health impact of the plant.

We must take action on this with the California Energy Commission.  The signature on the extension is from Jackalyne Pfannenstiel.

Her contact information is listed on the CEC’s website as:

Jackalyne Pfannenstiel
916-654-5036
Assistant’s email: cgraber@energy.state.ca.us

I will be calling her today to make the following statement: “The 2002 Final Environmental Assessment regarding the East Altamont Energy Center (DOE/EA-1411) assumes conditions in the analysis which are categorically untrue today, in particular, but not limited to, the public health risk assessment. And yet in the order you signed to extend the deadline to build, there was no requirement to re-assess the public healths risks of this plant. This is unacceptable.  The original report claims, with respect to public health considerations, and I quote: “Few residences are located in the vicinity of the site.”  In fact thousands of residents, and multiple children’s schools and parks now exist less than a mile from the site. Local residents are organizing a response, which may include but not be limited to petitions and/or legal action to reverse the decision to extend the deadline. We would prefer if the matter be re-opened in good faith to reconsider this and additional oversights regarding deficiencies of the 2002 assessment as it relates to dramatically changed conditions today.  I will be sending supporting materials to your assistant via email. Thank you for your attention to this matter.”

I would encourage others to call or write to either reinforce my statement, or make a statement of their own. Please, be professional and courteous in addition to firm if you decide to call or write.

It is natural to wonder if we are really powerless in all of this, and that maybe any effort we put into this is wasted.  I sometimes wonder that myself, but I don’t believe it is the case.

It’s important to realize that these efforts can and do succeed.

Let’s take a look at a success story, from which we can hopefully learn a thing or two about how to mount a successful campaign against a 1,100 MW power plant.  Here’s the web site.  Note that the last entries are about parties they threw after successfully stopping the project in March 2008:

Stop The Power Plant

These folks went all out to succeed:  “Congratulations and thank you to our elected officials, the lawyers who helped prepare the case, Columbia Law School Environmental Law Clinic, Pace Energy Project, and to the hundreds of community volunteers who have worked so hard over the years to stop the power plant from destroying our neighborhood.”

Their site is very well done.  I will be scouring it over the next few days and contacting some of the people involved to find out what they viewed as their most effective tactics in their successful effort.

There is another group in Hayward that seems to be turning the tide also:

Community Intervention in Eastshore Energy Power Plant

I will be contacting this group in Hayward as well to learn all we can about how they have been able to make their advances so far.