Dominion Virginia Power and the Shenandoah National Park have reached a deal over the proposed Warren County Power Station proposed for Front Royal, Virginia. Although the agreement between the park and the power company was approved last week by the Obama administration, the deal does not address a range of concerns expressed by the Shenandoah National Park superintendent and others at a November 9th public hearing held by the Virginia Department of Environmental Quality.
Under the proposed agreement Dominion Virginia Power is volunteering to close its 74-megawatt North Branch Power Station in Bayard, West Virginia when the proposed Warren County Power Station near Front Royal begins commercial operations in late 2014 or early 2015.
The Warren County plant is designed to generate approximately 1,300 megawatts of electricity with, according to Dominion Power, “the net result would be more electricity to serve Virginia’s growing needs and cleaner air in the region that includes the Shenandoah National Park.”
However, closer review of Dominion’s press release on the agreement with the Shenandoah National Parks appears to contradict its claim that the net result will be “cleaner air in the Shenandoah National Park region.”
In Dominion Power’s written statement released Thursday, the North Branch plant “was put in cold reserve status in August of this year”. “Cold reserve status” means that the plant is not currently producing the air pollution from burning its fuel mix of coal and waste coal used to generate electricity.
Because the North Branch plant is not generating pollution and was already off-line long before the agreement was reached with the Shenandoah National Park, the addition of the proposed Front Royal plant will result in a net increase in park pollution over today’s levels, not a decrease as asserted by Dominion.
Dominion Power also says that without the park agreement its North Branch station could be returned to service in a “short time if needed”, sounding somewhat like a veiled threat toward regulators and the public should the Front Royal plant be denied. However, the likelihood of a return to service for the North Branch plant any time soon seems unlikely for several reasons.
First, the North Branch facility began commercial operation in 1992 and was later purchased by Dominion in 1994. It is considered ancient when compared to today’s more modern air pollution mitigation technology. Secondly, Dominion has already transferred nearly all of its North Branch employees to other jobs. The logistics of re-manning the old facility makes the plant’s future return to service even more unlikely. Dominion already has plans that North Branch’s last three remaining employees will be transferred to the company’s nearby Mt. Storm Power Station upon completion of activities related to North Branch’s retirement.
Dominion Power’s claim of a “net environmental benefit” for the park region is further suspect given the distance of the new Front Royal plant in relation to the already-closed North Branch facility in Bayard, WV. The proposed Front Royal facility is located less than five miles from the Shenandoah National Park, however, the North Branch facility is located approximately 100 miles west and 50 miles north of Front Royal. Due to its proximity, pollution emitted from the power plant in Front Royal will have a concentrated and immediate impact on local air quality both in the park and in Clarke County.
Given that the Warren County facility’s annual emissions of air pollutants are expected to be 216 tons per year (tpy) of total filterable & condensable particulate matter, 12 tpy of sulfur dioxide (SO2), 330 tpy of nitrogen oxides (NOx), 374 tpy of carbon monoxide (CO), 240 tpy of volatile organic compounds, 9 tpy of sulfuric acid mist, and 21 tpy of total hazardous air pollutants, the current air quality in the region of the Shenandoah National Park and Clarke County, Virginia will significantly decrease once the proposed facility goes on-line rather than see the net-benefit declared by Dominion.
At a Virginia Department of Environmental Quality public hearing on November 9th in Front Royal, Shenandoah National Park Superintendent Martha Bogle, Clarke County citizen and environmental quality expert Alison Teetor and Piedmont Environmental Council president Christopher Miller all expressed the importance of finding local pollution offsets as critical to protecting the northern Shenandoah Valleys economic and cultural amenities.
Both Superintendent Bogle and PEC’s Miller expressed concerns the facility’s smokestack not only will concentrate particulate and ozone emissions into the air near the park, but will be visible both from the Shenandoah National Park and to large areas of Warren County currently under conservation easement.
“The impact from this facility on the eco-system goes well beyond the Shenandoah National Park, Front Royal and Warren County” Miller said. “Ozone produced from the power generation facilities has a huge impact on grapes and vineyards.”
According to Shenandoah National Park public affairs officer Karen Beck-Herzog, the Shenandoah National Park considered the overall impact to air quality in finally agreeing to the pact. When asked about the concerns over the smoke plume and smokestack associated with the facility Beck-Herzog said that that park officials had decided that there was “nothing that we could do to diminish the impact of the plume”.
Superintendent Bogle did not return a call requesting comment on the Dominion Power agreement.
Beck-Herzog said that the decision to not oppose Dominion’s proposed facility had been made in Washington, DC. In a November 29th letter from US Department of the Interior Assistant Secretary for Fish, Wildlife and Parks Thomas Strickland to Virginia Department of Environmental Quality’s Anita Riggleman, Strickland said in regard to Dominion’s proposal to close the North Branch plant; “Assuming that Virginia DEQ is able to include such an enforceable permit condition and Dominion Power meets its obligation to implement the agreed upon emission reduction plan, I do not oppose the Warren County power station permit.”
Under the agreement, emissions reductions credits from closing the North Branch station will be combined with other offsets to mitigate the emissions from the new power station. The agreement is conditioned upon the Virginia Air Pollution Control Board’s approval of the air permit for the proposed station, other regulatory approvals and the construction and operation of the proposed station.
The Dominion Power-Shenandoah National Park agreement, which is now part of the Virginia air permit application for the Warren County station, states that the mitigation plan for the station “consists of a combination of emission reduction credits and emission allowances resulting in a net environmental benefit to park resources.”
Many people concerned about the environmental impacts of the proposed plant will likely not be satisfied with Dominion’s attempt to address local pollution with a national offset response. Clarke County citizen Alison Teetor said that she was disappointed that the Park Service had settled for Dominion’s proposal.
“A lot of bad air comes from the Ohio Valley so if there are emissions offsets then perhaps we’re no worse off but I just don’t know” Teetor said. “I’m planning to look at the proposal in detail and reserve my final opinion until I’ve had a chance to consider what is being proposed in more detail”.
At its last meeting the Clarke County Board of Supervisors took the opportunity to blast Dominion Power officials who were present at the meeting over the emissions from the plant that will impact Clarke County air quality. County Supervisor Pete Dunning (White Post) said that Dominion’s strategy was unfair because rural areas were forced to carry the burden of polluted air so that urban areas can enjoy electricity without having to deal with power plants in their backyards.
“The electricity from this plant isn’t even going to serve our area, is it?” Dunning said to Dominion representatives. ”It’s really for cities in northeast.”
Dominion’s park proposal is contingent upon receiving approvals from Virginia Department of Environmental Quality and the Virginia Air Pollution Control Board. The air board is expected to vote on Dominion’s application for the Warren County air permit at its Dec. 17 meeting in Richmond.
“The planned Warren County Power Station is designed to be among the cleanest fossil-fuel fired facilities in the nation. We expect that it will be at or near the top of the EPA’s national clearinghouse list of facilities with the best air pollution control technologies,” said David A. Christian, chief executive officer of Dominion Generation.
Dominion apparently feels very confident that with the Shenandoah National Park’s concern out of the way that approval is now only a formality. Dominion says that it “anticipates seeking permission from the Virginia State Corporation Commission next year to build the new power station.”