Here is Green Delaware’s request that the letter be withdrawn and the “Combined Heat and Power Partnership” be investigated:
February 12, 2014
Ms. Regina McCarthy, Administrator
United States Environmental Protection Agency
Dear Administrator McCarthy:
I am writing about the objectionable letter attached to this email, authored by Gary McNeil of the U.S. EPA “Combined Heat and Power Partnership,” and dated February 7, 2014.
I have been observing the “Combined Heat and Power Partnership” for some years. This program has a long history of ill-advised and unsubstantiated endorsements of questionable projects. In my view it is, like many EPA “partnerships” with industrial special interests, essentially an industrial lobbying program and has no legitimate place in an environmental regulatory agency.
This promotional letter is particularly objectionable because the proposed project is essentially a scam, a 278 MW (electrical output) fossil fueled power plant being promoted as an “auxiliary” use to a “data center” which could hardly have an electrical load greater than 20 MW or so. Local and Delaware state agencies have connived with the promoters to conceal the characteristics of this project from the public and to obstruct public participation in approvals of it.
I think it is particularly sad to see the EPA joining this effort at the same time the agency is trumpeting its commitments to “Environmental Justice,” etc.
Mr. McNeil says “TDC [the promoters] provided the Partnership with information …” However, McNeil provides no details on this “information” or how it was vetted, or if any sort of peer review occurred.
Similarly, Mr, McNeil provides no details on the analysis supposedly performed.
Mr. McNeil writes “… we write to express our support for the use of CHP by The Data Centers, LLC (TDC) as part of the construction of a data center …” yet the proposed project is out of all proportion to the proposed “data center.”
Mr. McNeil says “… the Partnership has determined that TDC’s proposed CHP system is expected to avoid NOx emissions by [sic] http://premier-pharmacy.com/product-category/antibiotics/ approximately 1,400 tons per year, SO2 emissions by approximately 9,200 tons per year, and CO2e emissions by approximately 1,030,000 tons per year compared to conventional energy sources.” But there is no indication of what he means by “conventional energy sources” and no indication of what LOCAL health/air quality impacts are expected to be, or if these were considered in any way.
This endorsement letter is certain to be used for promotional purposes without adequate balance or documentation, tending to bring discredit on the USEPA and calling into question the independence, objectivity and professionalism of any permitting review role the EPA might have with respect to the proposed project. This link provides and example of how the letter is being used: http://delawarebusinessdaily.com/2014/02/epa-official-says-data-centers-heat-and-power-system-will-cut-carbon-emissions/
CHP systems can make sense, but it is nearly certain that the investment proposed for this power plant, if redirected into energy efficiency investments, would prove far more beneficial, whether from the point of view of local and/or regional air quality (the proposed project is in a non-attainment area for ozone and PM2.5) or climate-forcing emissions.
Therefore, I request
(1) That the letter be withdrawn by the EPA pending adequate documentation of the stated conclusions;
(2) That the EPA, pursuant to the Freedom of Information Act–should you consider that necessary–provide to me all correspondence and technical documentation, including model runs, etc., underlying Mr. McNeil’s letter; and
(3) That the EPA commence a review of the “Combined Heat and Power Partnership” program to determine how this program is operating, how it is funded, and how it aligns with the mission and statutory responsibilities of the EPA. By copy to Inspector General Elkins I am requesting the involvement of OIG.
If this letter raises any questions please contact me.
Yours very truly,
Copy: Inspector General Arthur A. Elkins, Jr.
Rep. John Kowalko
Energy & Environmental Consulting
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