The company NRG recently filed two petitions with the Mass Department of Public Utilities’ Energy Facilities Siting Board (EFSB) to 1) construct a new natural gas powered power plant (Unit 3) and to obtain a comprehensive zoning exemption from the Town of Sandwich. JRWA submitted comments to the EFSB today concerning NRG’s petitions. Read our comments letter HERE >>
Here are some of the points outlined in the letter:
- EFSB should require NRG’s Units 1 & 2, which are outdated, environmentally destructive and operating under an expired NPDES permit, to be decommissioned before an additional unit is approved. We believe EFSB should offset the construction of an additional fossil fuel facility by taking the two obsolete units offline to eliminate water use and impacts to marine life in the Cape Cod Canal.
- Buzzards Bay, Cape Cod Bay, the Cape Cod Canal, and the surrounding environment are at continued risk from oil spills by further barge shipments to NRG’s Unit 3, as well as from methane releases from the new pipeline and storage tanks — we ask that the environmental and economic consequences of spills and releases be outlined by NRG, including impacts on endangered, threatened and rare species.
- NRG should be required to maintain environmental mitigation accounts that can be drawn on to effectively respond to a variety of accidents or when emissions exceed permitted levels.
- NRG should outline how and when it will check the stability of underground tanks and pipes, and how leaks will be detected. As sea levels rises, so will groundwater levels on the site, and whether salt water intrusion will be an issue for NRG’s underground infrastructure should be addressed.
- Unit 3 does not meet EFSB’s technology performance standards for CO emissions by 13% — a clear emission exceedance that is of major concern for the surrounding environment. Units 1 & 2 should be decommissioned to mitigate the continued decline of air quality and atmospheric health by Unit 3.
- In terms of coastal impacts, NRG should consider future climatic conditions that are projected to increase precipitation and temperatures, particularly in the Northeast; NRG should use the most conservative value of 2.93 feet above mean sea level by 2060 to develop plans to protect the site and should also address potential for rising groundwater tables, subsidence, and erosion on the site.
- Impacts to protected species (including North Atlantic right whales and their critical habitat) from all activities associated with constructions and operation Unit 3 should be outlined, including releases of oil and other hazardous substances. Right whales are known to travel through the Cape Cod Canal and many have been sighted close to the plant.
- At no point in the petition does NRG discuss methane (CH4) emissions, which have a 25x greater impact on climate change. Drilling, storage, extraction, and pipeline activities associated with natural gas result in methane leaks. Compared to carbon dioxide, methane is a far more potent greenhouse gas that could escalate climate problems. NRG should discuss any requirements concerning methane emissions.
- Funds should be set aside to identify and mitigate methane leaks. Otherwise, construction should not be permitted or tolerated.
Read the entire comment letter HERE >>