To the Energy Committee: Attached are the comments submitted on behalf of the Club for the TransGas Coal-To-Liquids air permit last Friday. While I put some time into this, we also got a substantial amount of help from National Sierra Club and a couple experts they retained, and these comments would not have been anywhere near as extensive without them.
Our first major issue is that TransGas and WV-DEP have significantly underestimated the pollution emissions as part of an effort to have this plant be permitted as a "minor" source. As such, the applicant is attempting to avoid a lot of pollution modeling requirements, BACT analyses, and many other permitting requirements under the Clean Air Act. Thus, the bulk of the comments identify the numerous emissions sources that were ignored or underestimated by WV-DEP.
The second big issue is that the applicant has not proposed any controls or limits on greenhouse gas emissions. While West Virginia does not currently have an emissions standard for greenhouse gases, we argued that they have an obligation to impose limits based on their broad responsibility to protect the public welfare.
There are also numerous other issues with monitoring, enforceability, and "confidential business information".
This is a great read for policy wonks or simply for educational purposes. I am grateful to Elena and all the support from National on this issue.
Jim Kotcon
Elena Saxonhouse Elena.Saxonhouse@sierraclub.org 12/18/2009 7:33 PM >>>
This is a corrected version of what we sent yesterday; I sent an errata sheet to DEP earlier today. I am not attaching the Exhibits, but would be happy to provide them to anyone who wants them.
Elena Saxonhouse Sierra Club Environmental Law Program 85 Second St., 2nd Floor San Francisco, CA 94105 (415) 977-5765 (415) 977-5793 (fax)