Reopen DOE Separate Source Determination

SAME SOURCE DETERMINATION REQUESTED

Submitted to Shelton Blog by Katherine Price Mason County Progressive

DEPARTMENT OF ECOLOGY
Attention: Mr. Jeff Johnston, PhD
Science and Engineering Section Manager
Air Quality Program
Post Office Box 47600
Olympia, WA 98504-7600

Re: Separate Source Determination for Proposed Simpson Renewable Energy Company Facility

Dear Dr. Johnston:

I am writing you to request that you reopen your consideration of the above determination and make a “same source” determination instead. In support of this request I enclose the following:

• Your letter of August 4, 2010, to Kirk Lilley, in connection with the “Separate Source Determination Request for Proposed Solomon Renewable Energy Company Facility.”

• A copy of the cover page of the City of Shelton Mitigated Determination of Nonsignificance (MDNS), for the project “Simpson Lumber Shelton Biomass Cogeneration Plant.”

• A copy of the cover page of the Air Operating Permit issued by the Olympic Region Clean Air Agency to Simpson Timber Company.
  

• A copy of the cover page of the Air Operating Permit issued by the Olympic Region Clean Air Agency to Olympic Panel Products LLC.

• A copy of the November 16, 2010, letter from Simpson Lumber Company, LLC, to Jason Dose at the City of Shelton.

Background: I am a resident of Shelton and I work in downtown Shelton several blocks from the existing Simpson/Olympic Panel operations at Front and Railroad Streets in Shelton. I am a member of Grandmothers Aligned Against Pollution (GAAP) and I am adamantly opposed to the addition of an additional biomass incinerator in the Shelton Harbor.

Separate Source Determination. In your letter of August 4, 2010, you state:

Based on the information submitted, it is Ecology’s opinion that the power plant proposed by SREC is not under common control or ownership of Simpson or Olympic, that the power plant is not a support facility to either of those companies, and that Simpson and Olympic are not support facilities to SREC...

This determination does not constitute Ecology’s endorsement of the accuracy of the information submitted to Ecology by SREC.

Simpson Lumber Shelton Biomass Cogeneration Plant. Page 1 of this document provides the proponent information as follows:

Solomon Renewable Energy Company
Attention: Dave McEntee
P O Box 21866
Seattle, WA 98111

Cover Page, Air Operating Permit, Simpson Timber Company. The air operating permit was issued on February 3, 2005, and it expired on February 3, 2010. Whether Simpson is operating without an air permit is not the point of providing this page, although inquiring minds do want to know… This page is provided to show the dates of issuance and expiration only, because they are identical to the dates of issuance and expiration for the following.

Cover Page, Air Operating Permit, Olympic Panel Products LLC. As noted above, the air operating permit was issued on February 3, 2005, and it expired on February 3, 2010. As noted, the date of issuance and expiration are exactly the same as those of Simpson Timber Company.

November 16, 2010, letter from Dave McEntee, of Simpson Lumber Company LLC, on behalf of Solomon Renewable Energy Company LLC. This letter speaks to additional questions presented to Solomon Renewable Resources Company LLC (SREC) by Jason Dose of the City of Shelton. The questions submitted to SREC by the City of Shelton are answered in this document by Simpson Lumber Company LLC.

This determination does not constitute Ecology’s endorsement of the accuracy of the information submitted to Ecology by SREC.

If you were to visit the City of Shelton on any given day, you might have some of the experiences my family and I do as a result of living and working in an ALREADY highly polluted environment.

My eyes burn on days when Simpson/Olympic are burning (ammonia?).

My chest hurts, and I cough and wheeze, on days when I am foolish enough to walk the two blocks from my office to the Post Office (particulate matter?) when Simpson/Olympic are burning.

Last month, we had roofers re-roof our office building; by the end of the day, they were up on the roof literally coughing and choking because of the air that day.

I regularly call Robert Moody of ORCAA to report the terrible conditions of our air. As a result, the City of Shelton and ORCAA have recently entered into an agreement to place an air monitor in the City, on top of our new Public Safety Building, within blocks of the Simpson/Olympic operations, so that the citizens might get a better idea of how bad our air is.

If you were to visit with the people on the street of Shelton, and you were to ask them who is burning in the harbor, they would tell you it is Simpson. If you were to inquire about Olympic Panel, most citizens would tell you “same guys".If you were to ask about Solomon Energy, they would laugh and tell you who “Solomon” is to this city, as in “Solomon Simpson", the founder of Simpson Timber.

I provide you this information so that you can see that making your determination on the “information submitted", has resulted in you making an incorrect determination as to separate source.

There is no separate source here in Shelton. These businesses are inter-related in ownership and financial benefit. The citizens of Shelton are not fooled for one minute by changing their names and spinning off companies: Green Diamond Resources, Simpson Timber Company, Olympic Panel, and now their latest incarnation, Solomon Renewable Energy Company LLC.

Solomon G. Simpson is laughing in his grave at the wisdom and skill utilized by those who now run his various entities in fooling anyone outside of the City of Shelton into believing these entities do not have a “common control and ownership or support facility relationship". They do.

I respectfully request that the Department of Ecology re-open the “Separate Source Determination” and allow the citizens of Shelton to help you understand the “common control and ownership or support facility relationship” that most certainly does exist among the entities that have sprung forth from Solomon G. Simpson’s initial timber company.

Citizens in my community gathered 3,200 signatures to put on the ballot a measure in connection with biomass incinerators last summer. We did this because our county and state leaders refused to listen when we said we did not want the Adage facility built above our town. Our leaders rejected our request and denied us a ballot vote on biomass incinerators.

The object of the vote was not to stop Adage from coming to Shelton, it was to stop all biomass incinerators from coming to Shelton. Our County Commissioners denied us a vote on the matter, even though we had provided sufficient signatures to earn the right to vote on whether additional polluting sources would be added to our community.

In the very same week that we learned Adage was pulling out, we were delivered the City of Shelton’s Mitigated Determination of Nonsignificance. We were not even given a week to celebrate dodging the ADAGE bullet, before the City of Shelton made its unholy MDNS and fired their SREC bullet at the heart of our town.

The citizens of the City of Shelton are already the recipients of Sol Simpson’s pollution, which has been raining down on our community and our water for more than 100 years. To add another source or pollution in our harbor, for any reason, is the height of insanity. It will be the death of our community, literally.

Please re-open the “Separate Source Determination” and give us the opportunity to show you that the man behind the curtain in our community is not the Wizard of Oz, he is Solomon G. Simpson, and he, and his, have been polluting in Shelton more than long enough.

Very truly yours,

Katherine Austin Price
Shelton, WA