CONCERNS ABOUT LOCAL IMPACT

by Shirley J. Pulawski, October 2007

Last week, I met with officials from NRG's ethanol division. They did confirm to me that they are continuing research into building a 100 million gallon per year ethanol plant in the Town of Dunkirk, on Willow Road near Temple.

I was assured by them that every safety measure available would be in place. If the project goes forward, part of the current plans would be to close Temple from Willow to Route 5 and the County Home would build it's own access road to Route 5. A traffic light would go into that intersection. The bridge underpass at Willow Road by the fire house would be widened and the road would be lowered enough to accommodate trucks. I was told that light pollution would be minimized by pointing the lights inward (I don't want to give up black star-filled skies at night) and assured that odor would be controlled by the best regenerative thermal oxidizers available.

I was told that every single problem would be minimized or eliminated by a lot of great technology.

I was told that basically we wouldn't even notice it.

After all of the months of research I have done about the impact of ethanol plants on communities, I felt like I was talking to the builder of the Titanic, who said his ship was unsinkable. I mentioned this to the representatives with whom I spoke and the comment drew laughter.

I didn't think it was funny.

I told them that I believed that /he believed/ that his ship was unsinkable, too, and that while he was flawed in his logic, he probably was a genius engineer for his time. More laughter, then some quiet... while I felt like the gentlemen with whom I was speaking were sincere in their beliefs, I also felt like I was being sold a large bridge in an urban and populated area... Brooklyn, anyone?

Part of my concern is what I have thoroughly researched for months now and continue to research. Thermal oxidizers (which /reduce/ but do not eliminate emissions) have only been used since 2001. This is pretty new technology. The NRG officials claim they will be using Regenerative Thermal Oxidizers (RTOs) which are even newer, supposedly better, yet I have found information on plants designed and built by the same companies that NRG is using for construction that is having problems with odors and emissions despite the promises, and these are all plants built within the last three years. From my reading, thermal oxidizers require more maintenance than the officials from NRG told me is required. Maybe NRG is willing to keep up with proper maintenance, but what if they aren't? What if they sell the company to someone else who isn't willing to keep up with the stringent requirements I am being told will be upheld? What if NRG itself doesn't meet those promises? Then what are we stuck with?

Please keep in mind that NRG has never built or operated an ethanol plant anywhere.

These points are only the tip of the *iceberg* (another Titanic reference? Maybe...) in my discussion and my research. My main point is that once this plant goes in, there is no turning back. If people aren't asking questions now, BEFORE they can file SEQR with the DEC (expected in the next 3-6 months, after which things will happen quickly) then any consequences all of the communities surrounding this plant suffer *will be our own fault*. Keep in mind that foul odors do not linger just around the plant, they spread through several miles on any given day. The wind patterns change, and no resident will ever know when they will be affected, and the smell from these plants, even with thermal oxidizers can be sickening to the stomach as well as harmful to health. Most resident around problematic plants will say that there are good days and bad days with a plant, so visiting an operational facility for an hour or so isn't going to give the big picture, although I have found testimonies online from people who have visited plants and were disgusted by the odors in the communities surrounding the plants. In my book, anything that smells bad enough to make a person sick to their stomach is not healthy. Our bodies are designed to run away from things that are unhealthy for us.

The approval of this plant will lie only in the hands of the Town of Dunkirk Board, a few people, and no other surrounding governing bodies. Meanwhile, it will affect the entire surrounding community, and not any of the elected people in the Jamestown area who want to see this happen. This means it's up to us as citizens, to pressure leaders of the surrounding communities to pressure the Town of Dunkirk for answers and action. Who will hold the ball in the case of an accident? A fire? Intense odor problems, ones that are so bad they can be sickening? Another train derailment with cars full of ethanol? We've already had two derailments near the County Home in the last ten years, and we were simply lucky they weren't full of highly flammable liquids.

There are plants now in operation, designed by the same companies that NRG is planning on using that are now under scrutiny for higher emissions of odors and volatile organic compounds and nitrogen oxides than the levels they said they would be emitting once in production. Sadly, in many cases of emissions violations, plants just get fined small amounts and are not forced to comply with regulations, which were relaxed as of April 12th of this year by the federal government.

The plants that are now functioning across the US that get few or no complaints are located in extremely rural locations with very small populations. While NRG is proposing this on a rural property, the surrounding area is not, and let's not forget how much pollution with which we already have to deal. We have schools, a hospital, a university, a waterfront and two downtown areas trying very hard to thrive again. If these areas are full of the stench of an old stale tavern, who will want to come out and enjoy them? Who will want to even leave their houses or open their windows on the "bad days" of the plant's operations?

I am not against progress or jobs, although this plant will not create many. However, I am against going into any large project ignorantly and without research or knowledge or forethought. I am against calling something "progress" if it actually causes harm in the long run. I am also against running forward with an unknown project without protections in place to make sure those responsible will make reparations for any harm they do in the name of their profit.

I am not convinced so far that this will be progress, and I am disappointed that I am more informed on this topic than so many of the local leaders I have contacted thus far. What binding agreements will hold NRG to their promises after they go into operation? Who will ensure any problems are solved, or will it be the runaround and red tape and passing the buck? Who will pay for the added burdens on the surrounding communities, not just the Town of Dunkirk? This plant is proposed right on the border of City of Dunkirk and the Village of Fredonia. Don't think for a minute that it isn't your problem if you don't live in proximity to those places.

I encourage all of the area leaders, as well as ALL citizens to spend some time informing themselves. There is an infinite resource of information on the internet, as well as a local website. To voice your opinion, contact your representative and visit the local site,  http://discussion.understandethanol.info and for more links and information, visit http://www.understandethanol.info All opinions are welcomed so long as respectful and peaceful conversation is observed. My goal right now is to make sure local leadership is ready when the ball starts rolling down the aisle (when NRG files its paperwork) because things will happen very fast at that point and there will be limited public hearings. Then it's in the hands of a small few, but that doesn't mean we can't all make a difference.

I have a lot of people right now looking to me to be the one who will make a difference for them, but the reality is that everyone can make a difference. Shame on you if you expect someone else to "do something about it" while you sit idly by.

CONCERNS REGARDING DUNKIRK ETHANOL PLANT CONSTRUCTION

by Shirley J. Pulawski, July, 2007

While a new and large industry such as NRG’s proposed ethanol plant can provide some economic advantages to a community, as a citizen, I need reassurance that our leaders are paying attention to the details surrounding this. Many communities have welcomed ethanol plants and discovered later that the additional burdens placed on the area were very high, while quality of life hit new lows. I do not want to see that happen here. While the current plans are going into my backyard, it is quite clear the entire surrounding community will be affected by this, not just myself and the other immediate neighbors.

SAFETY:
Ethanol plants, like any industry, can pose many safety risks. Plants of this size and nature typically store 8,000 pounds of anhydrous (undiluted) ammonia) 7,000 gallons of sulfuric acid, 7,500 gallons of gasoline, and 500,000 to over a million gallons of ethanol on any given day of operation.

A minimum 2.5 mile evacuation plan is needed in the event of anhydrous ammonia spill or other major disaster (fire, explosion, leak, etc). This would mean Brooks Memorial Hospital would be unusable for emergencies and all government agencies and homes would have to be evacuated. Those within 5 miles from an incident are encouraged to stay indoors. Has a feasible evacuation plan been studied in regards to this site? If so, who else has been included in this planning? We have a large University, hospital, a nursing home, several police and fire districts, many businesses and residences within a 2.5-5 mile area.

What sort of burdens will this plan place on our local emergency workers and law enforcement? What sort of additional training and equipment will they require? Who will be paying for this? Our fire departments are heavily reliant on volunteers. Will local municipalities have to increase fire department budgets to manage the risks or will NRG cover these burdens?

Many communities with ethanol plants in their vicinity, even those with the most modern thermal oxidizers, complain of increased smog, particularly in the winter where the cloud of smog will settle over the area. These plants emit nitrogen oxide, which combines with other elements in the air to create smog and ozone, which contributes to respiratory and other health problems. Is this community impact being taken into consideration?

WATER/SEWER:
Cooling a plant of this size generally requires an estimate 500-2,000 gallons or more PER MINUTE of fresh water pumped in and out of the facility. Can the current infrastructure support this? If this is taken and returned to the lake, how much will the discharge warm the lake, and how will that impact snow in the winter (more cost to community) and fishing? Will the waste water be tested and regulated, and by whom? Will it be treated before being returned to the environment? Has an environmental impact study on the integrity of the lake or ground water supply been included in this plan?

Will NRG do it’s own pumping and filtration, or will that burden fall on the City water supply and/or local taxpayers?

If the water comes from the Dunkirk water supply, how will this massive increase in use affect citizens? Will our water prices go up? Will the increased burdens lead to expansion in the water system that will cost taxpayers money, especially considering that the proposed site will be JUST outside of the City of Dunkirk, thereby avoiding City tax, and let's face it: NRG has a history of trying to avoid paying its taxes as it is.

ODOR:
Even with the newest, most technologically advanced thermal oxidizers, only 70-80% of the noxious odor (mostly from the yeast mash) are removed, the rest goes into the air. Residents within three miles of plants around the country are complaining about horrific odor from these plants, even those plants upgraded to reduce emissions. Considering the placement of this plant and typical wind patterns, the odor would likely move right into down town Dunkirk and the area around the college. How will this impact the quality of life in the area? How will it impact enrollment at the college or other local events?

The left over mash is often dried and used for animal feed, which also gives off unpleasant odor. Where will this process occur? Who will be affected by the disposal of other by products from the process?

TRAFFIC:
How will increases in trucking and rail impact the community? Who will bear these costs? What changes will be made? How will noise levels change and in what areas? Will the necessary road improvements and maintenance be funded well enough that my taxes will not be raised?

LONG TERM:
Vital components of these plants are designed to last a mere 10 years. What commitment has NRG made to renewing vital infrastructure? The University of Iowa recently published a study that suggests the profitability of ethanol production will only last about 10 years. Once he government subsidies (corporate welfare) run out it’s possible that ethanol will no longer be profitable for the industries producing it. If this happens, will this new plant then become the next large brownfield that the state will have to come in and clean up?

What further tax burdens will the community bear because of this over the long term? Safety, pollution, cleanup, infrastructure, etc. NRG already wants to dramatically reduce the taxes on it’s CFB plant in Dunkirk, one that as of 2005 emits 97,000 pounds of sulfuric acid into our air as well as 97 pounds of mercury. So far, it is not a company that is proving to be a good neighbor. As of April 12th, 2007, Federal regulations specific to ethanol plants have relaxed pollution controls. This legislation allows ethanol companies to emit 250,000 tons of pollutants into the atmosphere, which would be in addition to what already impacts our area by the same company.

As my property becomes completely devalued by my proximity to this plant, will my assessment be reduced? Have property values in the entire area been taken into consideration in this plan? Will the increase in industry be offset by even more people leaving the community because this plant may negatively affect their lifestyles and possibly health? Has a buffer zone been discussed to offer fair compensation to those citizens who don’t want to live next door to this plant? Have health and safety concerns for those in the immediate area even been considered? What options are available for residents who do not want this in their backyard?

Who will be accountable for problems that arise down the road? How will the complaint process be handled and by whom? From my research, ethanol plants have been notorious for passing all of the preliminary permit requirements and then entering into violations after they’ve begun operation, when the damage has already been done. With whom will citizens or other entities file a grievance for these violations? How will these grievances be handled? Will it be on a local level, or will it be through dealing with far away agencies with contacts that are difficult to reach? Will grievance filing require legal representation?

How will the pollution and odor affect the lake front revitalization plans? Will there still be walleye in the lake? Will anyone even want to come here any more, or will this become a place like Lackawanna where everyone holds their nose while driving through as quickly as they can make it out? Will our healthcare system be able to handle increased respiratory problems?

Are our leaders doing the proper footwork to ensure that our community is served by this plan rather than further burdened? Or, are the plans for this short sighted and intended to grab a few quick dollars without studying the big picture and long term effects?

Once this plant goes in, our community will be forever changed. It’s landscape, it’s appearance, it’s odor, it’s level of desirability as a place to live and visit will be permanently altered. Whether these changes come at a benefit or at a high cost to the community depends entirely on the research, proper planning and action of all involved NOW, not later, after the deal is already done. There is no way to undo a decision of this magnitude, and every person in this area will be affected by it, for better or for worse.