NJDEP Told To Reject B.L. England Air Permit at Public Hearing

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Environment New Jersey Research and Policy Center

Trenton – Tonight, at 7 p.m. at the Upper Township Municipal Building in Cape May County, the NJDEP will hold the only public hearing regarding the permitting for the repowering of the B.L. England power plant as full-time gas facility, as opposed to retiring the facility, which is well over 50 years old.

Doug O’Malley, Director of Environment New Jersey, released the following statement ahead of tonight’s public hearing:

“Tonight’s NJDEP hearing is an attempt to rubberstamp climate malpractice, rip off ratepayers, and worsen air pollution in South Jersey. This is a trifecta of dirty energy: B.L. England is an artifact of the Eisenhower era, and it should have been retired a decade ago. Instead, the Christie Administration’s DEP wants to double down on its love affair with the gas industry and create the largest global warming polluter in South Jersey – in a flood plain no less.

The worse part of the $400 million B.L. England repowering proposal is the attempt to ram a gas powerline through the heart of the New Jersey Pinelands. New Jersey has already gone ga-ga over gas, and doubled down on gas plants with 4 gas power plants in the works across the state (West Deptford, Newark, Woodbridge, Sewaren). These plants will likely bring more than 30,000 new MW onto the grid, which is significantly more than the 600 MW which will be lost with the retirement of Oyster Creek.

A repowered B.L. England power plant is the pot of gas at the end of the Pinelands pipeline rainbow. B.L. England should have been retired a decade ago, and now the Christie Administration is trying to extend the life of an Eisenhower era fossil fuel dinosaur.”

Included also are a transcript of his comments that will be delivered at tonight’s public hearing:

The attempt by NJDEP to repower B.L. England entirely ignores the precedent of the Global Warming Response Act, which requires an 80% reduction in carbon pollution by 2050. It also ignores the NJDEP’s own ruling in 2004 to regulate carbon pollution as an air pollutant, and the NJDEP permit won’t require any pollution controls for carbon pollution and completely ignores the lifecycle carbon emissions of natural gas, which are significant, and can entirely erase gas’ supposed cleaner moniker. New Jersey law requires the best available technology for pollution control. Even a repowered B.L. England is hardly state of the art.

Repowering B.L. England will make it even harder for New Jersey to meet EPA’s Clean Power Plan, which requires a decrease in carbon emissions by a quarter between now and 2030 from the state’s fossil fuel power plants.

More than a decade ago, EPA and NJDEP found that B.L. England’s air pollution violated the Clean Air Act, as a peaker power plant. Because of unending deadline extensions, a coal-fired power plant has now become a host creature for the gas industry to repower B.L. England as a baseload power plant, violate the intent of the Pinelands Commission by routing South Jersey’s gas line through the heart of the Pinelands and allow the future potential for LNG gas export to foreign shores.

The Repowering Canard: Increased Emissions:

The current permit doesn’t acknowledge the distinction between emissions from a part-time (or peaker) plant and a facility that is constantly in use. The current facility only operates during peak seasons, but when it is repowered it will operate year round, adding to the total emissions.

According to the draft permit, allowable carbon equivalent emissions –greenhouse gases — would total 1.6 million tons a year. These emissions alone could make B.L. England the 4th most polluting power plant in the state for global warming pollution. B.L. England would also release 129,000 pounds of lead per year.

B.L. England is exploiting a regulatory loophole by repowering the facility, instead of building a new power plant, with the most up-to-date emission technology. The air permit would increase the plant’s operation to 365 days a year and increase methane pollution, which is 70 times a more potent greenhouse gas than carbon.

The air quality in South Jersey for ozone (i.e. smog) recently received a F grade from the American Lung Association’s 2016 State of the Air report for Atlantic and Cumberland Counties (data wasn’t available for Cape May County). However, 6,400 adults and 1,600 children suffer from asthma in the county, and in Atlantic, 17,600 adults and 5,700 children suffer from asthma. A full-time repowered power plant will negatively impact air pollution across the region, but especially for these vulnerable populations, especially in Atlantic City.

Another Gas Plant?: New Jersey has already gone ga-ga over gas, and doubled on gas plants with 4 gas power plants in the works across the state (West Deptford, Newark, Woodbridge, Sewaren). These plants will likely bring more than 30,000 new MW onto the grid, which is significantly more than the 600 MW which will be lost with the retirement of Oyster Creek.

The disparity is incredibly stark at the Shore between peak demand in the summer months vs. winter months, partially because of energy needs but primarily because of the massive increase in population during the summer months. This kind of discrepancy of peak demand would be better addressed through energy efficiency demand response technology as opposed to repowering an dinosaur fossil fuel plant. There is no need to build a power plant that will serve an electric grid that spans to Illinois.

Lack of Public Input: There is a clear need for an extension of the public comment period and for additional public hearings.  The need argument for this facility is exposed by the very fact that the new and improved Cape May Energy Center is 22% smaller than initially proposed. And the very process of the revision for the repowering of the facility exposes a shocking lack of public input or explanation. The initial revisions were only exposed during the BPU kangaroo court/hearing in December 2015 giving approval to the South Jersey Gas pipeline:

The BPU Order from October 2015 shows there were big impacts for the Pinelands. There was no opportunity to comment on this revision or provide feedback, and during the December 2015 BPU hearing there was no cross examination from BPU staff, Ratepayer Advocate or independent organizations.

On October 9, 2015, an updated study entitled “Benefits to Pinelands Area of B.L. England Repowering: Updated Analysis” was completed to incorporate additional changes that have occurred since the October 2013 report prepared for R.C. Cape May by PowerGEM. First, the size of the repowered facility is projected to be 447 MW instead of the 570 MW that was assumed in the prior reports.

Oversupply/Lack of Need: Even more egregious is that the incentives established by FERC to avoid energy price spikes sparked these revisions – and those same incentives exposed an overreliance on natural gas as a fuel source. This concern is echoed by the recent report from the Union of Concerned Scientists which documented the overreliance on natural gas power plants, and analyzed 16 states, including New Jersey, as being oversupplied with natural gas.

UCS Gas Report link: http://www.ucsusa.org/clean-energy/rating-the-states-on-their-risk-of-natural-gas-overreliance#.Vztn7b7krWM  

PJM evaluated the grid reliability issue under the assumption that BL England would shut down, that reliability upgrades would be to existing infrastructure, not new power plant projects, and they specifically noted that the grid was over 40 years old and in need of upgrades independent of BL England open or closed. The PJM reliability upgrades are not all related to closure of BL England – the transmission infrastructure is over 40 years old and some of these upgrades would be required with or without BL England.

Economic Impact: It should be noted that while the permit does not focus on economic impact, the best economic potential from power generation for South Jersey would be from off-shore wind. The Fishermen’s Energy project alone, which is only five turbines off the coast of Atlantic City, is estimated to create more than 500 jobs. The economic impacts of the Wind Energy Areas 10-15 miles off Atlantic City will have a much larger positive economic impact, both for short-term and long-term jobs.

Ratepayer Ripoff: The repowering of BL England and the construction of the South Jersey Gas pipeline aren’t just a bad deal for the environment – they are also a rip-off for ratepayers. Currently, ratepayers are on the hook for picking up 60% of the $100 million construction costs of the pipeline, with exemptions for B.L. England from the Societal Benefits Charge by the BPU and an assumption that the state will never reenter RGGI. And this doesn’t even account for the $400 million price tag for the B.L. England plant repowering AND the social cost of the plant’s lifecycle carbon pollution.

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