I believe I can effectively argue that, as far as the air quality impacts of this permit are concerned, my comments are more pertinent than 95% of the residents of Wise County. High stacks are now employed at most new permitted coal generating plants in order to disperse pollutants farther away from the source. A quick glance at a Virginia map shows that, aside from the town of St. Paul, the plant is east of virtually 99% of Wise County, making almost the entire county typically upwind.
My wife and I live in Emory, Virginia. According to Marcus, Bailey, Stewart, & Sampson (Journal of Applied Meteorology, Vol. 30, August, 1991) the prevailing wind direction on Whitetop Mountain is from the west-northwest. Assuming the main current of air skips over the ridgetops, the directional flow at Whitetop, at the southern edge of Washington County would be a good indicator for Emory's air source. A west-northwest wind would make Emory typically downwind from Dominion Power Company's proposed new coal generating plant at Virginia City in far eastern Wise County.
I attended one of the evening public hearings on the Dominion permit request to the Department of Environmental Quality (DEQ) earlier this month in St. Paul. Dozens of citizens and leaders from Wise County got up to denounce opposition to the plant and support the jobs and economic development that they anticipate might flow from it. This permit, however, is not before the State Corporation Commission where such economic development issues may hold sway. This is an air quality permit, and the comments about the economic impacts on a part of Southwest Virginia (Wise Co.) where air quality will be little affected by the plant are irrelevant. Those of us DOWNWIND, who will suffer the air quality impacts of a second coal-burning power plant in the immediate region are the citizens with the clearest standing in this permit. The permit affects our health. It affects our health because granting the permit will affect the air we breathe, much more than it would affect the air that the vast majority of Wise Countians breathe.
I am deeply concerned about the air quality my family and neighbors breathe. For years we have been downwind of coal-burning power plants not just at American Electric Power's Carbo plant, but throughout the Ohio and Tennessee Valleys. These generating plant emissions have clearly taken a toll on visibility, but far more sinister, these emissions have damaged lungs and circulatory systems throughout our region, leaving behind higher than normal rates of emphysema, asthma, and heart disease. I was an elementary school counselor in the Washington County Public Schools and school nurses have told me that there is already an epidemic of childhood asthma among our students.
DEQ, itself, documents that, if built, the Dominion plant would, upon commencing regular operation, be among Virginia's top 10 point-sources of air pollution. This new pollution stream would join with AEP's old Carbo plant, less than 10 miles away and already a top 10 state polluter. The two plants would belch out a dangerous breathing zone downwind for residents of Russell and Washington Counties and beyond. That zone already contains more than its share of particulate, nitrous and sulfur oxides, mercury, and other heavy metal contaminant in the air, land and water because of the Carbo plant and the distant plumes of other AEP generating plants along the Ohio River. We cannot risk more human damage. Dominion should not be allowed to rub our noses in their dirt.
The high altitude fraser firs and red spruce forests on Whitetop and Mt. Rogers are like our canaries in the mine. Many scientists believe these fragile mountain top trees are experiencing damage and are in decline because of the acid deposition. In her 2001 masters thesis at East Tennessee State University, Dendrochemical Analysis of Lead, Aluminum, and Calcium in Southern Appalachian American Beech, Suzanne Southerland examined "concentrations of metals, including lead, aluminum, and calcium in growth rings of an important northern hardwood species, American beech (Fagus grandifolia Ehrh.) at Mount Rogers and Whitetop Mountain, Virginia." Her conclusions state "Concentrations of both lead and calcium varied according to aspect facing. Northwest and southwest facing aspects tended to have the highest concentrations of cations." This analysis shows the sides of the mountains most polluted by heavy metals were those exposed to prevailing winds from the west.
The ridge and valley topography is uniquely beautiful. It also creates some unique air quality problems. Climb up to a high point on Clinch Mountain, like White Rock, commanding a long view of the central valley in Washington County. Do this on a day when a thermal inversion is occurring. You will witness how pollution plumes stay low and travel up the valleys. Our beautiful ridge and valley topography only exacerbates the problem of pollution dispersal.
The pie charts and "back trajectory" maps from The State of North Carolina's Recommendations on Boundaries of PM2.5 Non-Attainment Areas, 2/26/04 (www.epa.gov/pmdesignations/documents/04Recommendations/4/s/North_Carolina_A1.pdf -) show that Southwest Virginia is the major source outside North Carolina for ambient particulate pollution in Davidson Co., North Carolina. It appears that most likely this pollution is originating with AEP's Carbo Plant. That particulate pollution, further downwind, gives credence to the concerns of the National Forest Service for critical environmental areas that they manage, like Linville Gorge
If you want some economic impacts that are clearly related to air quality, you need look no further than Sullivan County (Kingsport and Bristol, Tennessee) which is a non-attainment area for ground-level ozone already exists and is causing economic prospects to look elsewhere (TDOT lowers I-26, I-81 speed limits in Sullivan Co. Kingsport Times-News 1/31/07).
Among the most interesting on-point documents regarding regional air quality are the recommendations presented to the DEQ State Advisory Board, (at its meeting 11/6/02) regarding the Southern Appalachian Mountain Initiative (SAMI). These recommendations are still valid. Recognizing that the entire Southern Appalachians are an environmentally sensitive area, the stated mission of SAMI is "Through a cooperative effort, [to] identify and recommend reasonable measures to remedy existing and to prevent future adverse effects from human induced air pollution on the air-quality related values of the Southern Appalachian Mountains, primarily those of Class I areas, weighing the environmental and socioeconomic implications of any recommendations." Among the consortium's "Key Findings" were:
G求 Electric utilities are the largest sources of SO2 emissions
G求 Electric utilities & highway vehicles are the largest sources of NOx
G求 On annual average, SO4 (Sulfate) is largest contributor to fine particles that
G求 impair visibility
G求 Most of changes in visibility in SAMI strategies due to changes in SO2 (Sulfur Dioxide) emissions
The SAMI recommendations presented a roadmap for how Virginia should handle the Dominion permit:
G求 Each SAMI state would receive the most benefit from reductions of emissions from within their own state boundaries.
G求 The SAMI states support & will promote strong national multipollutant legislation for electric utility plants to assure significant sulfur dioxide and nitrogen oxides reductions both in and outside the
G求 Each SAMI state should encourage energy efficiency, conservation, and use of renewable energy to reduce the emissions from stationary and mobile sources.
Sadly, unlike other states, the Governor's new State Energy Plan (SEP)declares that Virginia ranks low on energy efficiency and conservation savings, originating from utility programs. Of course, in many cases energy efficiency and conservation is the cheapest and cleanest energy "source". However, the SEP urges "...increase the use of conservation and efficiency measures in Virginia." That challenge could be met by encouraging utility investments in demand-side conservation. As the SEP advises, "Efficiency and conservation can defer the need for new power generation facilities...Virginia can obtain significant saving and environmental benefits through increased investments in energy efficiency and conservation... Developing and implementing aggressive energy efficiency and conservation programs make good business sense for Virginia." The utility could be rewarded with a higher rate of return, transforming utility profit incentive from building more generation facilities to investing in their customers' conservation.
The global concern about climate change, resulting from increased green house gas emissions, is a topic that transcends local interests. Dominion is headed in the wrong direction for at least 50 years (the life of the plant). On October 18, 2007, the Sunflower coal-fired power plant permit was rejected by Roderick L. Bremby, Secretary of the Kansas Department of Health and Environment (KDHE), on the basis of potential public health and environmental harms from plant pollution. Bremby said the Department based its ruling on the Supreme Court decision in April, 2007, that CO2 is a pollutant and that the Environmental Protection Agency is required to regulate it.
"I believe it would be irresponsible to ignore emerging information about the contribution of carbon dioxide and other greenhouse gases to climate change and the potential harm to our environment and health if we do nothing," said Bremby (The Denver Post, Politics West, 10/19/07).
Doesn't DEQ have the same responsibility? Again, the SEP directs that state action "...facilitate development of energy sources that are less polluting" and do not "contribute to global warming".
The SEP concludes, "Utilities and their consumers face less technical and financial risk if there is less need to construct new facilities." It is plain foolhardy for Dominion to build a plant with a promise to adopt an as yet untested and unproven CO2 capture and storage technology. Such an action places the utility, its customers and Virginia at needless financial risk. Representative Rick Boucher has stated publicly that the upcoming Congress will adopt a cap and trade program for green house gas emissions. Building new coal-fired generating capacity will put the utility and its customers and Virginia's economic development at risk because of the liability of a new carbon-emitting generator.
While no coal-burning technology is clean, Dominion's plan to use a 30-year-old technology, instead of state-of-the-art technology like IGCC (Integrated Gasification Combined Cycle) demonstrates a lack of concern for efficiency and the pollution they will generate.