Comment Log Display

I live adjacent to the Blue Lake Power biomass power plant in Blue
Lake CA, and have done so since it was originally built in 1982.
This 11 Mw biomass power plant, like most others in the state,
employs aging and out of date pollution control technologies and
has not been maintained well over the years. Even when it was brand
new, the Electrostatic Precipitator could not control the black
micro-ash fallout from the plant, and here 30 years later, it still
can't, subjecting all of us downwind from the plant to constant
black ash fallout.  The Blue Lake Power plant is currently the
defendant in an DOJ action for failure to construct and receive
approval for BACT when it restarted about six years ago. It is
significant that the local AQMD failed in their responsibilities in
this matter by allowing the plant to reopen on the basis of their
original, 1980's permit. A Consent Decree has been proposed that
would allow the plant to continue to pollute for another two years,
and if unable to achieve pollution controls established by the CD,
propose higher levels that they can achieve. Measurement of
particulate pollution is required to be measured only ONCE A YEAR.
It is hard to see how this situation and the Consent Decree
negotiated largely by the local AQMD conforms to the intent of SLCP
Strategy.  In other words, the strategy is meaningless unless it
extends to the local AQMD level.

The proposed SLCP strategy calls for significant support of biomass
energy plants, including supporting "moderniz(ation)of existing
biomass facilities".  It is critically important that any biomass
facility receiving support in any form be required to construct
BACT PRIOR to operating, not at some point in the future, and be
held to strict pollution control limits.

Further, the strategy does not address the enormous amounts of
diesel fuel that is consumed in transporting woody biomass out of
the forest and into the burner at the power plant. Blue Lake Power
requires approximately 22 full chip trucks daily for fuel. Looking
at the entire biomass production cycle, there will be a loader for
logs and fuel in the forest, a truck to bring the fuel out of the
forest, a chipper/grinder machine, chip truck transport from
grinder location to power plant, and a loader operating constantly
at the plant to mix fuels and bring them to the burner feed screw. 
If the source is only 30 miles away (and most fuel sources are
further), the diesel use alone adds 3.5 TONS of CO2 to the
atmosphere PER DAY, plus the associated black carbon from diesel.
This part of the cycle has not been adequately addressed in the EIR
or Strategy. 
Calculations 
Distance: 30 miles, round trip 60
Chip/Logging truck mpg: 5
Gallons per trip: 12
Gallons for forest loader, chipper/grinder, yard loader per full
load chip truck (conservative est.): 2
Gallons per day: 22 full load chip trucks/day x 14 = 308
Pds CO2 per gallon diesel: 22.5
Pds CO2 per day: 6930