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another DEIS DREF comment

Posted by Steve Cone on 8:00 AM October 9, 2007.

Harrilene Yazzie, NEPA Coordinator
Bureau of Indian Affairs, Navajo Regional Office

Comments on Desert Rock DEIS

The final Desert Rock EIS should fully address the following prospective concerns:

Final EIS should stipulate that a requirement of consistent applications of BAT
(Best Available Technologies) to all aspects of emissions controls will best serve the environmental protections envisioned under NEPA. These should include the technically feasible reduction of mercury emissions by 95%, per comments by Colorado's Air Pollution Control Division.*

Some form of CO2 capture/entrainment should be required, especially given its defined status as a climate change agent, and the likely future impacts to both utility consumers and shareholders of a virtually inevitable carbon tax/trading regime.

Contingencies in Final EIS
Despite assumptions of a [very] limited area of impact, there should be clearly defined and fixed contingencies should any of the following occur concurrent with and presumably related to operation of the proposed facility:

1) Ozone exceedances in Farmington area. This area is already impacted by
unusual and remarkable levels approaching regulatory thresholds. A fixed Desert Rock ozone contingency should be incorporated in the final EIS, espectially given the continued expansion of CBM gas operations regionally and the many unknowns regarding ozone formation and transport mechanisms.

2) An increase in measurable haze in nearby protected or Class 1 areas. The well-defined historical impacts from existing plants argues for a clearly defined contingency requirement of Desert Rock should its particulate emissions contribute to any significant overall deterioration.

3) Airshed loading in southeast La Plata County (and presumably northern San Juan County) is likely approaching regulatory threshold levels - per the Colorado Air Pollution Control Division's PSD program. At a minimum, a detailed and comprehensive survey of extant airshed loading (esp. relative to protecting nearby Class 1 airshed) should be completed prior to any ROD regarding permitting of Desert Rock. The last survey conducted in SW Colorado was about 10 years ago.

Cumulative air quality impacts
All related air impacts should be incorporated in final EIS, including re-entrained
road dust, from all aspects of construction, all mining & coal hauling operations, and employee vehicle trips, in addition to the actual power generation processes (including cold unit start-ups, with their substantially higher levels of pollution).

Cumulative impacts to groundwater quality & quantity
All relevant concerns expressed regarding impacts to both water quality and depletions should be addressed in the final EIS, including a well-defined supply and firm contracts adequate for long-term operations.** The net energy losses associated with groundwater pumping should be reflected in final EIS.

Water quality analyses should include all relevant impacts to ground water, including burial of combustion products and potential contamination resulting from all aspects of coal mining operation.***

The final EIS should also attempt to justify why a broader range of alternatives
were not considered, per NEPA. In light of impending climate change impacts from CO2 and ongoing depositions of heavy metals from the existing four corners power plants, more progressive, "green" alternatives should have been
incorporated into the DEIS. This approach would better fulfill NEPA's intent in identifying the broadest range of alternatives and prospctive environmental impacts associated with the proposed project's stated goals.

Certainly both the Navajo's economic welfare as well as the natural environment would benefit from consideration of a wind turbine alternative, based on an NAU study cited in public testimony by Chris Colwell. With both the potential for substantially more long-term employment and multiples of the proposed power output - produced from a totally renewable resource - this draft EIS failed in its over-arching NEPA responsibility to offer a sufficiently broad range of alternatives and thereby minimize associated environmental impacts. With regard to maximizing the long-term economic benefits to Navajo tribal members, a wind turbine alternative appears to be a no-brainer.

The final EIS should offer a clarification of why Alternatives B and C proffered
a blatant apples-to-oranges comparison. Instead of Alternative C simply involving a single supercritical 750MW unit, a less-efficient 550MW unit was substituted, presumably to favor Alternative B by comparison. Per the summary narrative:
" ... power generation under this alternative [C] would be less efficient and there would be greater emissions and water usage per unit of power produced, but overall emissions and water consumption would be lower because of the reduced size of the unit. Coal usage under Alternative C would be 10 to 15 percent higher per megawatt-hour because of the higher heat rate of the subcritical plant ..." (emphasis added)

The final EIS should also satisfactorily address issues of environmental justice raised by both numerous individuals, regional organizations, and elected officials, as well as the US Environmental Protection Agency. The "benefits" of this project will likely bypass many Navajo families now living without electricity or phones, as well as having to haul their domestic water. This is also an especially critical consideration given the region's status as a "national sacrifice area" as a result of the impacts of (so-called) coal bed methane production.

Also detailed in the final EIS should be a exposition of pressure apparently applied by Sithe Global to eliminate concerns regarding the effects of climate change in a contractor-prepared biological assessment. These include effects on
local hydrology affecting future water supplies, and related biological impacts on T&E species, including the Colorado pikeminnow, razorback sucker, bale eagle and Southwest willow flycatcher.

--------------------------------
* In its comments the Colorado Air Pollution Control Division identified ongoing documented mercury contamination at Mesa Verde National Park, as well as Navajo, Vallecito, McPhee, Totten and Narraguinnep reservoirs.

** Dine Power Authority is attempting to amend federal legislation to divert basin water from the long-term Navajo NIIP to M&I uses, including power production. Since this involves a controversial change in the application of a massive quantity of legally apportioned water, its broader implications - including the defacto uncertainty of sufficient water supplies for this project - should be clearly identified in final EIS. All San Juan (and Colorado River) basin water users have an interest and some stake in this modification of application.

*** Impacts to groundwater quality from mining operation should include, but are not limited to industrial solvents, heavy lubricants, drilling fluids, blasting compounds, and various fluids frequently lost from trucks and heavy mechanical equipment.

Very Sincerely -

Jerry Swingle
317 E. 5th Avenue, Durango CO 81301
Ph: 970-247-5797

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