Today we submitted comments to the state’s Executive Office of Energy and Environmental Affairs (EEA) regarding NRG’s Draft Environmental Impact Report (DEIR) for its proposed Canal Unit 3 Project on the Cape Cod Canal in Sandwich. NRG is planning to build an additional gas powered unit (using oil as backup fuel).

Read our full comments >>

Read a few sections from our comments below.

Units 1 & 2

NRG describes that its new Unit 3 will be highly efficient with state-of-the-art emissions control technologies and near-zero liquid discharge design to reduce water demand. However, Unit 3 will still be an additional source of greenhouse gas emissions. We generally do not support projects that will cause additional reliance on fossil fuels in Massachusetts, but we are supportive of the newer, more efficient technologies, the use of lower-emission fuels, and the lower water demand that will be part of Unit 3 operations. However, we strongly believe that the construction of Unit 3 should be an opportunity to take NRG’s already existing Units 1 and 2 permanently offline. NRG describes Units 1 & 2 as “physically unable to complete in [the Locational Forward Reserve] market” and “are vintage technology.”  These outdated and environmentally harmful units should be decommissioned before Unit 3 is brought on-line. EEA should require further offset for the additional fossil fuel facility by requiring that the two obsolete units be taken offline to eliminate water use and impacts to marine life. When operating, Units 1 and 2 have the capacity to use up to 518 million gallons per day through two cooling water intake structures causing significant entrainment/impingement of marine organisms and pollutant discharges. 

Climate Change

To account for flooding, NRG describes the project site as being raised to an elevation above the 100-year floodplain. Furthermore, NRG states that the design of the project must also address flood adaptation strategies to mitigate future risk associated with sea level rise. Project features and critical components will be elevated to at least 16 feet above mean sea level (AMSL), above the FEMA 100-year flood elevation of 14 feet AMSL plus an allowance for future sea level rise. NRG determined that a 2-foot rise in sea level would be expected over the 40-year life of the project.

NRG uses a 2-foot sea level rise because it represents a “conservative projection.” While we support the use of sea level rise values based on NOAA and USACE since they are nationally accepted and established estimates, NRG should use the most conservative value which is the NOAA high value of 2.93 by 2060. NRG clearly admits that its site will potentially be impacted by sea level rise of nearly 3 feet above MSL (based on NOAA data) until the permit expires in 2060. NRG should also discuss potential for rising groundwater tables, subsidence, and increase in erosion to impact the site, as well as combined effects of surge and mounting waves with extreme storm events. It is not clear that the combined effect scenario was considered. In other words if storm surge and flooding is combined with excessive precipitation (e.g., ice, snow or rain), then how will the site be protected?

The DEIR explains that floor elevations of critical components will be at an elevation of 16 feet AMSL or 6 feet above the existing grade and 2 feet above the existing 100-year flood zone elevation. Consideration should be given to ensuring access to all major components in foul flooded conditions, so that the facility can be maintained during extraordinary weather related events, and rising sea levels, and no adverse environmental consequences are caused from failing infrastructure. The integrity of the entire site should be preserved, not just critical components and the most conservative estimate identified in the petition (2.93 feet) should be used.

NRG reports that the average annual precipitation at the proposed site is about 48 inches (1981-2010) and the average annual temp is 50.6⁰F (1981-2010). It’s important to recognize predicted changes in local precipitation and temperature over the lifetime of the facility. Not only should historical data be assessed, but also future climatic conditions that are projected to increase precipitation amounts and temperatures, particularly in the Northeast U.S. Several studies suggest that precipitation amounts are expected to increase in the future due to climate change and have been projected to increase by 20-30 percent by 2070 to 2100. Specifically in the Northeast, it has been shown that heavy rainfall events are increasing (about 70% from 1958-2012) and are projected to increase further in the coming years due to climate change.