No Altamont Power Plant

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.

There are only three power plants in California that are 1,000 MW or larger (the proposed Altamont plant is 1,100 MW).  They can be found in this list on CA energy commission’s web site.   They are:

• Moss Landing @ 1,060 MW
• La Paloma @ 1,124 MW
• Mountainview @ 1,026 MW

Let’s take a look at the surroundings of each of these plants. It appears to me that the siting of the East Altamont Energy Center is unprecedented in its close proximity to schools and desirable residential housing.

Each of these images is zoomed to approx. the 1000 ft level.

The Moss Landing Plant

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There is no residential or schools visible at the 1,000 ft level here around the Moss Landing plant. Let’s look at La Paloma:

La Paloma Plant

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La Paloma is truly in the boonies (where these projects belong). Taking a look at the Mountainview Plant in San Bernardino:

Mountainview Plant

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This plant does in fact have some residential in close proximity to it, in addition to the primarily industrial setting. But if you take a look at the street view, it is not a neighborhood that is comparable to Mountain House in desirability. And I don’t think this is how we want our neighborhood to end up.

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Actually this plant (Mountainview in San Bernardino) gives us a chance to get a clear visual of a plant this size using google’s street view again:

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Now let’s take a look at the siting of the plant adjacent to Mountain House.

East Altamont

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Here I’ve highlighted in green the proximity of two our Elementary School sites that are visible on the 1,000 ft scale. The plant site is outlined in red.

Conclusion: Nowhere else in all of California is a plant of this scale so close to elementary schools and desirable residential neighborhoods.  We should see to it that we are not the first.

Next I’d like to get to specifics of what can be done to oppose the building of this plant. The sooner we can start pushing back on this the better.

Here is a link to the full environmental impact report submitted in 2002.

Right off the bat, we should be disabused of the notion that this plant will be insignificant to us.  Direct quotes from the report:

• The EAEC as proposed has the potential to create significant impacts to local and regional air quality.
• Staff found that the project’s emissions of oxides of nitrogen (NOx) and volatile organic compounds (VOC) have the potential to cause significant impacts relative to the state and federal 1-hour ozone air quality standards.
• Further, the project’s emissions have the potential to cause significant impacts relative to the state 24-hour PM10 (particulate matter less than 10 microns in diameter) air quality standard.
• The project would also contribute to existing violations of the recently promulgated federal 8-hour ozone and 24-hour PM2.5 standards.

The tone of the report is often skeptical and dismayingly deferential to parties with interests which are opposed with those of us who would actually have to live with the consequences of the plant.  For example, regarding the land usage:

“Although staff does not completely agree with the conclusions of the County (Alameda), such conclusions are plausible and staff therefore defers to the County’s interpretation of their own guidelines”

I’m sure Alameda County loved the siting of this plant. They get all of the benefits and get to dump all of the consequences on us. The fact that the law requires approval from Alameda County only and not from the county which is mainly impacted is manifestly unjust. If necessary, I intend to contest this aspect of the siting and approval process.

Note that the approval process was conducted in 2002 at a time when California had just been through a severe energy crisis. The state of CA came under harsh criticism for not having sufficient generating capacity to meet energy demand needs, and a frantic push to approve new power plants ensued. This application was approved at the height of this manic period, which no doubt influenced the decision making process. It is my opinion that if this decision is revisited, cooler heads will prevail and the plant will not be permitted to be built.

Calpine has recently been granted a 3 year extension to build one of the largest power plants in CA directly adjacent to Mountain House.  The site’s proximity to MH is shown below.  We all know which way the winds blow in our community:  from the site directly into the heart of Mountain House.

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The plant will be a 1,100 MW natural gas fired, fossil fuel burning power plant. It will be one of the largest plants in the entire state of California. To get an idea of what this entails, this is a picture of the 600 MW Calpine Riverside Energy Center in Benoit, Wi:

Note that the plant pictured above is roughly half the size of the plant we are facing being built.  My concerns relate to polluting and potentially hazardous emissions, foul odors, noise pollution, visual blight, and the potential for accidents especially considering the known use of large quantities of anhydrous ammonia at the plant, which has been at the center of several serious accidents.

Environmental impact studies conducted in 2002 indicate that this plant will have chemical emissions that are significant enough to trigger the need for special exceptions under the law. To take one example, the plant will emit 293.9 lb/year of benzene into the air, which exceeds both the “trigger limit” of 6.9 lb/year (which requires an impact study) as well as the “special exception needed” limit of 199 lb/year. Benzene is a known carcinogen, and is specifically known to cause leukemia with chronic exposure. Wikipedia gives a lot of information on the known and documented risks of benzene exposure. This is just one example. There are literally dozens of known harmful chemicals that we will be directly downwind from if this plant is built and operated.

Currently, we believe based on solid information that Calpine must acquire a power purchase agreement from PG&E before they will be able to obtain the funding to build the power plant. PG&E is choosing a short list of competitors for such a power purchase agreement in October, 2008. That is very soon. We would like for PG&E not to choose Calpine for the power purchase agreement. No power purchase agreement, no plant.

We believe the environmental assessments done in 2002 are no longer valid due to the growth of MH all the way into Questa, which puts residents right now directly adjacent to the proposed site. As a first step towards prevention of the plant, we would like to enlist concerned residents’ help in making it known to PG&E that:

• The citizens of Mountain House are ready to take all legal steps to prevent and/or delay the construction of the East Altamont Energy Center.
• We have a valid concern that the environmental impact studies done thus far are invalid under the law due to significant changes in the surrounding area, and must be completely revisited.
• Furthermore, we believe the proposed site will be deemed not viable due to what is now an extremely close proximity to our growing residential community and schools, and the prevailing wind patterns.
• Therefore, it is not in their interests to proceed into any power purchase agreement with proposed East Altamont Energy Center due to these serious impediments to the viability of such a contract.

If you would like to help, please bookmark this site and visit often for ways to get involved in the fight to stop this power plant. I am working on setting up an online letter writing campaign as a first step to making our opposition to this project known. I believe that our health, our children’s health, our property values, and our very community are at stake.

Sincerely,
Robert W. Anderson and Family
Altamont Resident