Cartoon of the Day

Submitted to Shelton Blog by Claude

SAVE OUR SKIES!

We can still look up and see this!

Submitted to Shelton Blog by John Cox

In the coming years, it will become harder and harder to find areas in this country that will be able to attract visitors and residents looking for "natural" surroundings. By that I mean clean air, water, forests and mountains, and very few strip malls.

We are fortunate enough to still have this in Mason County. It is like having gold in the bank and must be protected. It must be protected from $hortsighted developers and politicians who would destroy it in the name of "economic development," or "jobs".

When you hear a corporation, or a developer, or a politician using "jobs" as justification for their plans...watch out! It usually means they don't really have any other justification for their plans that they are willing to admit publically. "Jobs" sounds much better than "we are going to rape the environment, pollute and makes tons of money," doesn't it? And what does economic development really mean?

We should redefine what development means to making use of resources in a way that leads to healthier and happier citizens. Toward that end, Mason County could become a refuge for folks wanting to escape the torments of big city life, or a location for authentically "green" businesses. We are perfectly positioned to become a haven for visitors and new residents seeking a respite from what is usually called "economic development" (see definition of "jobs" above).

There are obstacles to this vision of the future. They are the $hortsighted, harmful, promoters of "any growth is good growth," which is like a cancer in any community that is concerned about the quality of life.

Two current local projects come to mind as examples of the wrong kind of economic growth...the Adage and the new Simpson Incinerators. Both of these pollution generating cancers serve only one real purpose, to make money for a corporation. They are not intended to improve the quality of our lives.

We are at a cross roads here in Mason County at this moment. If these incinerators are built, I fear for the possibility of genuine development being created here. Genuine economic development promotes a community's sustainable, life affirming goals.

Whose goals are being promoted now?

Photo by Christine

Cartoon for the Day

Submitted to Shelton Blog by Claude

ADAGE? Hirschi says "No"; Lingle says "Maybe"

Submitted to Shelton Blog by Katherine Price

Jerry Lingle has gone even further toward the dark side this week.

Last night, at a candidate forum held by the League of Women Voters, Jerry proved that every man has his price. We don't know what his price was, but it seems the man has been bought. It probably won't show up in his PDC reports, but I will take a look anyway.

In support of the statement (that Jerry has been bought): At two previous public events he has stated unequivocally that he was opposed to Adage coming to Mason County; that he had spoken to many, many citizens and they are opposed to Adage, I recall he even said he has asthma or something, so he was DOUBLY troubled by Adage coming to Mason County.

At last night's meeting, Kim McNamara asked the following question of Brenda and Jerry, (the two candidates for County Commissioner, District 3), prefacing it with "The answer to this question is "yes" or it is "no."

Do you support Adage coming to Mason County?

Candidate Brenda Hirschi answered, "NO, I do not support Adage."

Candidate Jerry Lingle answered, "MAYBE."

I swear it was only three weeks ago that I heard him last speak to the issue and he was opposed to it!

I will say no more...for now.

Peek-a-Boo!

Submitted to Shelton Blog by John Cox

The New Port Parking Lot?

The last couple of times I've visited the Port of Shelton, I've noticed the Port dump truck parked in a strange place. It's parked along the fence across the street from the Port office building, and is in the view of the Commissioners' meeting room. When I took a closer look...SURPRISE! Is this just another attempt by Jay Hupp to silence his critics? Is this an appropriate use of Port resources?

Hmmmmmm.....

Vote "Yes" on all 3 Port Ballot Issues!

Where Have All the Wood Chips Gone?

Submitted to Shelton Blog by Katherine Price

Fourth Energy, a Scottish Company, to Import Biomass

“The firm has admitted that much of the wood chip needed for the plant will have to be brought by boat from North America and Europe.”

The above quote was taken from an article about a biomass incinerator proposed for Scotland. Because they do not have enough of their own "bio-waste," they plan to purchase and ship it to Scotland from North America and Europe.

I have no idea what incentives they are being given by their government to come up with "green" alternative energy, but it must be staggering if it will subsidize the purchase and transport of “wood chip” from North America and Europe.

I hate to burst the bubble of those folks in Scotland, but if America goes bio-massacre crazy, as it seems intent on doing, we will surely not be selling and shipping any of our wood chips to Scotland. Our garbage, perhaps…but we are going to want our biomass to stay right here, to be burned by the likes of ADAGE and Simpson/Solomon.

The Department of Natural Resources provided figures on permitted slash burns for the past three years. Those figures are actually proof that ADAGE is going to be burning something besides “slash.” The slash permitted and burned annually would operate the ADAGE facility for nine and one-half days. After which they will begin burning…? We don’t know. That’s the $50 million question, isn’t it?

While ADAGE has contracted with Green Diamond Resources (who is not Simpson), to provide them with fuel for their plant, it still begs the question: What type of fuel is Green Diamond going to be providing ADAGE? 600,000 tons a year of what?

I don’t think any of these bio-massacre plants are going to become operational. I think they MAY get to break ground, and maybe they will get their big fat federal dollars, but I really don’t even think that is going to happen. Mostly because of citizen ire; citizen ire is slowing these things down enough for a reality check.

What I think is going to happen, because of groups around the planet who are resisting this, is that we will delay one project after another until the EPA and Kyoto re-evaluate what they think they know about this. I think science and medicine will trump the crazy idea of caveman technology being the answer to the planet's energy crisis.

I think if we keep holding the line, if we keep pushing back, if we continue to pressure elected officials, whether they like it or not...in the end, our right to breathe will trump their right to make money at all costs.

Link to quoted Edinburgh News article

Cartoon for the Day

Submitted to Shelton Blog by Claude

What's Up Hupp?

Submitted to Shelton Blog by Tom Davis

When Port Commissioner, Jay Hupp, claimed he was “neutral” on the subject of biomass fueled incinerators, even after it was revealed he was a longtime advocate, the door swung shut on his credibility.

Now, the public knows he can’t be trusted. So, when it was reported that a “business owner” wants to build a 35,000 square foot manufacturing building in Johns Prairie Road Industrial Park, a big red flag went up for me.

The announcement was made on the heels of two other, ‘benign’ events:

1) The port voted to adopt the recommendations of the newly updated comprehensive plan, and now has the authority to sell port property to the aforementioned “business owner.”

2) Port commissioners moved to alter the conditions of the Foreign Trade Zone agreement.

So what’s up Hupp? Getting ready to drop another environmental bomb on the residents of Mason County?

Given Hupp’s track record, it is reasonable to wonder if the new manufacturing building that needs to be located near a rail system will not turn out to be yet another big polluter and/or a supporting business for the Adage incinerator. Who knows, but I’ll bet it also has something to do with the changes to the Foreign Trade Zone.

You see what happens when a commissioner loses credibility? The public keeps waiting for the next deception. But maybe, just maybe, I’m wrong, and Hupp is trying to lure in a company that makes solar panels, or wind turbines, or…flying pigs. I can hardly wait for the news.

At the risk of stating the obvious, Hupp’s lack of credibility is the reason Initiatives 1 & 2 are on the November ballot. It’s curious that a guy who plans his moves so far in advance would fail to consider the possible downside of lying to the public. But then the political landscape is littered with the careers of politicians who sought to outsmart those they had sworn to serve.

But by the time Hupp finds out what he should already know, it may be too late. Having spent many years trying to throw Mason County under the biomass bus, he is committed to the industry. Where we see trees, he sees fuel; where we see clean water, he sees industrial cooling fluid; and where we see home, he sees an epicenter of heavy industry.

That’s the problem with allowing old men to shape the future; they don’t have to live in it for very long.

Public Invited to Comment on Permit Rule Changes

Olympic Peninsula Environmental News

Ecology invites comments on changes to rule that requires permits for air pollution sources

Posted on October 10, 2010 by alberg

An Air Operating Permit is different from an EIS. Ecology doesn’t say what the new industries that will need these permits are.

OLYMPIA – The public can comment on the Washington Department of Ecology’s (Ecology) proposed changes to the state’s rule for permits for sources of air pollution, including greenhouse gases.

Chapter 173-401 of the Washington Administrative Code (WAC) requires air operating permits for large facilities that emit pollutants regulated under the federal Clean Air Act. Examples of these regulated pollutants include particulate matter, sulfur dioxide and nitrogen dioxide. An air operating permit contains all the emitter’s requirements for limiting air pollution emissions.

Ecology’s proposed changes will align the state rule with new requirements issued by the U.S. Environmental Protection Agency (EPA). You can review the proposed changes online.

Right now, EPA requires permits for air pollution sources that emit more than 100 or 250 tons of air pollution per year. (The amount of pollution requiring a permit depends on what type of pollution is emitted.)

Beginning in January 2011, EPA will regulate greenhouse gas emissions for the first time.

Emissions of greenhouse gases from all activities, including industrial facilities, are much higher than emissions of other air pollutants. If the permit thresholds for other air pollutants (100 or 250 tons) were used for greenhouse gases, the number of facilities needing permits would be overwhelming.

Instead, EPA set levels that exempt smaller sources of greenhouse gases. Examples include farms, restaurants and schools. This is called the “tailoring rule,” since it “tailors” permitting programs to limit the number of facilities that must get permits.

Sources must get new permits if they emit, or have the potential to emit, 100,000 tons or more of greenhouse gases each year.

A few emitters that haven’t previously needed permits will have to get an air operating permit because of their greenhouse gas emissions. However, Ecology expects that changing state rules to match the EPA “tailoring rule” will keep most small businesses from needing permits.

Power plants, refineries, wood product industries and other large industrial plants still need permits for emissions of greenhouse gases.

The comment period is open and continues through Nov. 17, 2010. Ecology will hold a public hearing at 6:30 p.m. Wednesday, Nov. 10, at the agency’s headquarters, 300 Desmond Drive SE, Lacey.

Here’s how to submit written comments:

• E-mail to elena.guilfoil@ecy.wa.gov.
• Fax to (360) 407-7534.
• Mail to Elena Guilfoil, Department of Ecology, P.O. Box 47600, Olympia, WA 98504-7600.

Ecology will review and respond to all comments. The agency must adopt the revised rule by January 2011.

Link to Olympic Peninsula Environmental News

Greg Helms' SEPA Comments

Submitted to Shelton Blog by Greg Helms

Letter to City of Shelton urging a determination
of significance for Solomon/Simpson

October 7, 2010

Mr. Jason Dose
Senior Planner
City of Shelton
525 W. Cota Street
Shelton, WA 98584

Dear Mr. Dose,

I am writing to you today to express my concerns regarding the “Solomon Renewable Energy Company LLC” SEPA application before your office. Simpson Lumber Company originally submitted the application in May of this year for a 31 MW cogeneration plant that was to replace an aging process steam plant.

Simpson Lumber Company gave a public presentation about how the new system would be so much better for the downtown region and that overall air quality would be improved. In the subsequent two months a new entity “SREC” has suddenly appeared, a new SEPA application filed in August and news that the existing Simpson process steam boiler would not be removed has taken the citizens by surprise. Taken together with the impending Adage project and it begins to look like the city of Shelton will be home to well over 1 million tons of wood incineration per year.

Despite state assurances that the air in Shelton meets air quality standards most of the year it is common knowledge that Shelton is home to some of the worst air inversions during both the winter and summer months and that the air downtown is hazardous during these times. Taking the 2007 emission inventory numbers for both Simpson and Olympic Panel we see that the “current” state of air pollutants (for a selected few pollutants) in the downtown bowl includes:

Simpson Lumber current emissions
Total Particulatel	136 tons per year (tpy)
PM10	61 tpy
PM2.5	48 tpy
Nitrogen Oxides (NOx)	60 tpy
Volatile Organic Cmpds (VOC)	14 tpy
Acetaldehyde	16.5 tpy
Carbon Dioxide (CO2)	106,000 tpy
Hydrogen Chloride (HCl)	12.6 tpy
Carbon Monoxide (CO)	258 tpy
Total Hazardous Air Pollutants (HAP)	28.7 tpy

Olympic Panel Products
Total Particulate	103 tpy
PM10	T45 tpy
PM2.5	23 tpy
Volatile Organic Cmpds (VOC)	23 tpy
Propane	91 tpy

Overall this does not include all of the current diesel truck traffic as well. I realize that the Simpson site has been a heavy industrial site since the inception of the city of Shelton however the idea that adding to the current load of pollutants is somehow safe or advisable is ludicrous.

The idea that a new entity “SREC” can come in and install a 31 MW biomass incinerator without removal of the current Simpson burner is not acceptable. The current pledge to use the original Simpson burner only in times of need does not preclude them from operating it 24/7 if they so choose.

Air pollution is a cumulative phenomena and the very real possibility exists that in addition to the already high levels of pollutants being dumped into the Shelton airshed that the “SREC” facility AND the Adage facility could be adding the following to the mix:

SREC proposed emissions for a 31 MW biomass plant (from the NOC application to ORCAA)

Total Particulate	67 tons per year (tpy)
PM10	38.2 tpy
PM2.5	28.6 tpy
Nitrogen Oxides (NOx)	248 tpy
Sulfur Dioxide (SO2)	147 tpy
Carbon Dioxide (CO2)	265,000 tpy*
Hydrogen Chloride (HCl)	9 tpy
Carbon Monoxide (CO)	248 tpy
Total Hazardous Air Pollutants (HAP)	23.1 tpy

* (my conservative estimate due to the fact that they are not required to report the CO2 emissions based on the false assumption of carbon "neutrality")

Whereas the Adage proposed emissions for a 60 MW biomass plant (from the NOC application to ORCAA):

Total Particulate	195 tons per year (tpy)
PM10	98 tpy
PM2.5	97 tpy
Nitrogen Oxides (NOx)	248 tpy
Sulfur Dioxide (SO2)	149 tpy
Carbon Dioxide (CO2)	550,000 tpy*
Hydrogen Chloride (HCl)	9.7 tpy
Carbon Monoxide (CO)	248 tpy
Total Hazardous Air Pollutants (HAP)	18.5 tpy

It is very interesting to note the discrepancies in the amounts of pollutants between the SREC and the Adage applications. The SREC facility is roughly half the size of the Adage proposed facility yet the numbers achieved via the “modeling” of the plants are extremely different in terms of the ratios when you account for the factor of 2. Both will utilize identical fuel sources and both will employ very similar pollution control technology.

It is obvious that we, the citizens, should be VERY skeptical of any of the data presented in either application. How can it be that a plant twice the size emits the same levels of certain pollutants (i.e. CO and NOx levels). The particulate numbers for the SREC facility are also quite suspect as they are too low compared to the Adage numbers, especially as they will be employing an electrostatic precipitator vs the filter baghouse for Adage. When accounting for the difference in size the SREC facility will emit 43% less PM2.5 than the Adage facility yet it will use a stoker type boiler and an electrostatic precipitator, equipment that is generally considered by most experts to be less efficient than a fluidized bed burner and a baghouse for particulate capture. Either the modeling numbers are not correct or both applications are fraudulent. It is also necessary to factor in the potential for upwards of 300 additional diesel tractor-trailer trips through the heart of Shelton if the Adage facility is to be permitted.

It is interesting to note that both Adage and SREC will be employing what is known as BACT (Best Available Control Technology) rather than MACT (Maximum Achievable Control Technology) for control of the listed pollutants due to the fortuitous sizing of the plants to escape having to pay for more expensive equipment. The SREC application even lists the “economic justification” in the Appendix B (BACT Analysis) for the use of BACT stating “If the cost per ton of pollutant reduced for a particular technically feasible control system is disproportionately high compared to the cost per ton in recent BACT determinations for other sources in the same source category, the control technology is deemed not cost effective and can be rejected as economically unjustifiable”.

In other words if you size your plant to be just under the wire for required MACT controls, then you can emit at close to the maximum levels for the cost of the lower control technology. This in the face of the recent EPA findings that for every dollar that industry spends towards particulate matter control at the MACT level a savings of 5 dollars is realized in public health. Once again, industry profits over the health of the citizens!

The ORCAA application for SREC also states (page 12) that the proposed facility will NOT need a Prevention of Significant Deterioration (PSD) permit due no one pollutant being greater than 250 tons per year. I believe this is due to their request for a separate source determination which would make them a separate entity from either Simpson or Olympic Panel.

It is interesting to note that this “separate” nature is also being used to circumvent any need to comply with acid rain regulations under the Clean Air Act as they claim the facility will be a cogeneration facility that is NOT a primary energy production company and will not be selling more than 1/3 of its power production to a public utility. In addition they claim under their “Separate Source Determination Request” NOT to be a “support” facility to either Simpson or OPP. I am not sure how supplying steam and electric power is not a support facility but this is obviously a legal loophole that will allow Simpson to sell itself power and steam while claiming to be a “separate” entity that is supposed to market clean, green energy (but not too much!). They (Simpson) should not be allowed to evade all manners of regulatory control by using a “shell”.

I would implore you in your capacity as planner to render a decision that this facility represents a SIGNIFICANT risk to the public (especially when combined with all of the other sources of air pollution). Secondly I would hope that you recommend a full and complete EIS to be conducted so that a proper accounting of the levels of pollution can be made. Looking at the discrepancies between the SREC and Adage facilities I would hope that you would render the same decision for the Adage application when it comes up for determination.

Thank you for your attention in this matter.

Sincerely,

Gregory L. Helms, Ph.D.
Scientist and Mason County Resident

Link to pdf version of the letter