Claims of "clean" energy uncovered for Vermont's next high emissions biomass plant

Written comments on the draft air permit for the North Springfield, Vermont biomass plant (aka the “Winstanley” plant) were due to the Vermont Agency of Natural Resources on September 10th.  PFPI submitted a letter not only on the air permit, but also a critique of the “fuel availability” study conducted by Innovative Natural Resource Solutions for both the North Springfield plant and the Beaver Fair Haven biomass/pellet manufacturing facility.
 
 
An outline of our comments on the air permit:
  • The facility rating in MWe does not match what has been filed at the PSB 
  • Potential to emit has been calculated incorrectly       
  • The two boiler capacity values are unconventional and confusing    
  • Stack height is inadequate     
  • SIL and SIA modeling results are obfuscated and appear to have been misrepresented      
  • MSER for CO is not really the most stringent emission rate 
  • The VOC emission rate is unlikely to be achieved    
  • The facility should be considered a major source for HAPs 
  • Organic HAPS emissions alone will likely exceed 25 tons   
  • The absence of acid gas controls makes staying below 10 tons of HCl highly unlikely       
  • The applicant has consistently underestimated HAPs emissions       
  • The discussion of BACT for greenhouse gases is inadequate           
  • The INRS fuel availability study misrepresents supply; wood supply is inadequate
 
  • The INRS studies downplay or ignore greenhouse gas emissions from biomass energy      
  • INRS reports overestimate biomass fuel availability 
  • Large areas of land are not legally harvestable or do not contain trees         
  • The INRS studies do not fully account for existing use of low grade wood
  • Assumption that 50% of forestry residues are available as fuel is unrealistic           
  • Biomass harvesting relies on other harvesting for commercial viability        
  • INRS projections rely on destructive harvesting practices, low-cost fuel, and lack of competition 
  • Other biomass studies estimate lower fuel availability          
 

   

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