Subject: Proposed additional Longview Power Plant at Ft. Martin, Monongalia Co.

 
                                             MON VALLEY CLEAN AIR COALITION, Monongalia County, WV   
                   NOTE: The following 13 items were submitted to the Monongalia County Commission
                       at the regular weekly meeting on Wednesday, February 5, 2020 by Duane Nichols

             1. The WV Public Service Commission held a Public Hearing on the proposed Longview II power plant this past Thursday in Charleston. Public comment was limited to only 2 minutes.  The local newspaper indicated that Duane Nichols of Maidsville spoke about the traffic flows on WV Route 53 thru the Ft. Martin community.
 
         2. Duane Nichols is from Stewartstown, but was speaking for many residents of Maidsville.  Actually, Stewartstown, Bakers Ridge, Pt. Marion and other areas are downwind of the two coal fired plants and gets more than their share of the pollution.  Now a third plant is proposed but is not needed.
 
        3.  The lawyer for Longview stated to the Public Service Commission that the “non-binding term sheet, which is the financial arrangement of a PILOT agreement from the Monongalia County Commission, is actually a binding document; that it is official and formal and commits the County to the project.  Since I was not aware of when or where the Mon. Commission had approved this project, I was in a state of shock.
 
        4.Since last Thursday, I have learned more about the traffic in Maidsville and on the Ft. Martin hill. Listen to this: there are approx. 300 diesel coal trucks per day hauling Pennsylvania coal up the hill to Longview I; --- there are special diesel trucks hauling Longview I flyash down the hill and off to a remote facility, often after dark and perhaps during the night; --- next, there are diesel trucks hauling First Energy flyash from the Ft. Martin power plant down to the old Humphrey mine site off WV Route 100; --- next there is employee traffic for the power plants, --- delivery trucks for the power plants, ---and then resident traffic and school buses. (Now much more is being proposed.)
 
       5. This Commission is planning to permit hundreds of vehicles MORE for Longview II construction employees AND the large scale movement of heavy power plant equipment. The Longview CFO told the Public Service Commission that some traffic could be from the north if the Shannopin dock at the mouth of Dunkard Creek is utilized.  In my opinion, this is unlikely. So the traffic issues are much much greater than we ever were aware.  I believe the residents of the Ft. Martin community deserve more consideration than they have been given.
 
  6. Residents of the Ft. Martin community have complained to the WV DOH, to the WV PSC, to the State Police, and indeed to this Commission. Yet, these challenges keep getting worse.  The residents of Ft. Martin can actually “feel” and hear the truck vibrations inside their homes.  And, driving on Routes 53 and 100 is quite dangerous.(All this traffic is adding to the air pollution.)
 
         7. Longview submitted the following two items to the Public Service Commission on January 17, 2020 regarding the public roads: PROPOSED CONDITION 8. “Applicant and their contractors and subcontractors, shall not block roads by changing shifts or heavy haul while school buses are scheduled to be on the roads within 1 mile of the site.” PROPOSED CONDITION 13.  “Applicants will consult with the DOH on the advisability and feasibility of constructing a right turn lane on the CR 53 approach to the Project site.” This is a puzzle because the project site is to the left.  Further, right turns are almost always of no concern since they do not cross on-coming traffic. [These are the only traffic control items proposed.]
 
         8. NEW TOPIC.  Longview submitted application materials to the WV-PSC on September 12, 2019. Included in Exhibit 2 on page 17, the last paragraph reads as follows: “To the east, along the new entrance road to the CCGT Facility, the foundation of a homestead farm house will be preserved when the access road is constructed through this area.  In addition, one of the storm water management ponds located near the farm house foundation will be converted to a recreational pond.  This area will be developed with the addition of a pavilion with picnic tables, a walking trail, and baseball/softball field.  Signage will be added for the walking trail.  The new Project Park will be considered as part of the CCGT Facility operational footprint.  The Project Park will be open for both Company and community functions and events at times approved by the Company.  The homestead ruins will be preserved and identified by signage.  Trees and shrubs will be planted around the pavilion and along the walking trail.”  However, these proposals are absent from the Proposed Conditions of Exhibit JLK-3 submitted on January 17, 2020.
 
         9. Consider the existing Ft. Martin Grade School, an old structure on Route 53.  It is locked tight, probably has not been opened for 20 years.  What are the plans for this school building? Can we consider moving it to a location where it could safely be appreciated, perhaps the Mason-Dixon Park.  There it could be looked after by responsible people.
 
       10. The existing Longview I coal conveyor could be relocated to the Ft. Martin hill, and with cooperation from First Energy, could be used to transfer coal from the River up to the Longview I power plant.  Cooperation among the power companies over there would be necessary. This County Commission would serve the county well by facilitating cooperation among the parties.

      11. Regarding the coal-fired 1400 MW Ft. Martin power plant. Coal arrives by railroad cars but the ash is conveyed up the hill to Route 53.  It is then trucked down the hill and onto Route 100 where it is dumped onto the old Humphrey mine property, if I am correct. Now this is very near the Monongahela River, so the surface runoff and groundwater leachate can ultimately flow to the River.  We should insist that this ash be disposed up top as originally planned, somewhere on top of the hill or in Pennsylvania.  This would remove some of the trucks and dust on the Ft. Martin hill.
 
      12.   Dust from the trucks gets on the roadway and dries, then the traffic suspends it into the air as an aerosol where some of it settles out in yards and on the homes of the residents. Some residents keep boots available for walking in the muck at their mail-boxes.
 
13. Many letters have been received at the PSC raising issues with a PILOT agreement. The PSC is not forwarding these to Monongalia County.  And, I doubt seriously that the County Commission is giving them any consideration. PILOT agreements are quasi-legal, not having a firm foundation in law. So, any PILOT agreement should be prepared, negotiated and approved only with the full and open participation of the pubic citizens. (Further, an alternative site should be chosen or better yet, limit the project to an alternative energy project of solar cells.)
 
 
Duane G. Nichols, MVCAC Coordinator, 330 Dream Catcher Circle, Stewartstown, WV 26508
Date: February  5, 2020.   Nichols330@gmail.com; 304-216-5535.
 
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 RE: W.V. PUBLIC SERVICE COMMISSION:  Case 19-0890-E-CS-CN, Longview Power II.
Note: This Case will be open for comment until February 24th. Early comments are needed particularly with regard to whether the Ft. Martin site is right for another power plant. This new plant will generate some 4 million tons per year of greenhouse gases, adding to over 10 million already.
 
A proposed agreement for property taxes in place of routine taxes, called a Payment In Lieu Of Taxes (PILOT), has been prepared by the Monongalia County Commission and submitted to Longview Power, LLC, for their consideration. This was done without the participation of the citizens of the county.  A study and report of PILOT agreements in general and this one in particular has been completed by the WV Center on Budget and Policy, as shown here:
  
"PILOT Agreements Cost State Millions in Tax Revenue: An In-Depth Look at Longview Power Plant" - West Virginia Center on Budget & Policy, Ted Boettner, October 15, 2019
 
 
A.      Letters of Information, Support or Protest can be mailed to: Ms. Connie Graley, Executive Secretary, WV Public Service Commission, 201 Brooks Street, Charleston, WV 25301. Specify the Case Number and Title: Case 19-0890-E-CS-CN, Longview Power II.
 
B.     Comments Can Be Filed Electronically directly to the WV-PSC: Go to: WV Public Service Commission, choose “Submit a Comment,” choose “Formal Case,” enter the case number; click on the case number, enter the requested information and your comment. Or, try the following link that may take you to this same screen:
 
 
 
 
C.     Comments May be Submitted Electronically to the Monongalia County Commission: