Attached is a draft of comments I offer regarding the proposed air permit modification for Longview Power.
As you may recall, Longview originally agreed to acquire SO2 emissions offsets from an area within ~100 miles of Dolly Sods in order to offset the impact their plant would have on acid rain in Class I Areas. Longview has had difficulty acquiring the needed offsets and now is seeking to expand the area to include plants to the west of the original area.
Our policy optons are: 1) Do Nothing. We signed a settlement agreement to not oppose the opriginal air permit, although we did include public notification requirements just in case something like this came up. If Longview proposed a change, do we violate our Settlement by asking for something different? Does this jeopardize the mitigation funding for the non-profit we are setting up?
2) Ask for further offsets, but do not oppose the permit modification altogether. This is a relatively minor permit modification for WV-DEP, so it seems unlikely to get denied, and a request for additional offsets is about as much as I think we can get from this.
3) Oppose a permit modification altogether. If Longview can't find the offsets they need, they don't have to operate the plant. I am still not convinced that Longview has made a serious effort to secure those offsets from Alleghny or Dominion, which is why I suggested that WV-DEP needs firm evidence of Longview's eforts and their complete inability to acquire the offsets. I think that Longview is a bunch of cheapskates and will do anything to save a buck.
Let me know what you think. I would like to get a response out to DEP before Jan. 1
Jim Kotcon 304-293-8822 (office) 304-594-3322 (home)