April 2002 Newsletter Articles
Sierra Club Asks DCA to Review Power Plant Comp Plan Amendment
The Sierra Club is requesting that the Florida Department of Community Affairs conduct a thorough review of the comprehensive plan amendment passed by the Polk County Board of County Commissioners. We are requesting the review based on the declarations of compelling state interests identified in state statute:
- Every Florida resident has a right to breathe clean air, drink pure water, and eat nutritious food.
- The state should assure a safe and healthful environment through monitoring and regulating activities which impact the quality of the state’s air, water, and food.
- Government shall ensure that future growth does not cause the environment to adversely affect the health of the population.
- Improve air quality and maintain the improved level to safeguard human health and prevent damage to the natural environment.
- Ensure that developments and transportation systems are consistent with the maintenance of optimum air quality.
- Reduce sulfur dioxide and nitrogen oxide emissions and mitigate their effects on the natural and human environment.
- The plan amendment also affects issues concerning power facilities equal to or in excess of 75 Megawatts of Steam Generation.
The Sierra Club believes that this amendment must be elevated to a thorough and comprehensive multi-agency review.
We actively participated in the original language adoption that is proposed to be changed by this amendment. The basis for adoption of the existing language was to meet the energy goals of the state, in part, within Polk County while protecting the natural resources of Polk County.
The methods used to determine proper siting of power plant facilities took the approach that air quality was a limiting factor to siting in the context of the Comprehensive Plan. To that end, an analysis was conducted to avoid increased deposition of pollutants in areas known to have high ozone counts. These areas continue to have elevated ozone counts and are nearing levels that could trigger Non-Attainment. Power Generation Facilities were allowed to site in all areas of the county based on conforming land uses, conditional use, and the types of facilities requesting siting. Siting of various types of facilities had to conform as to the type of facility allowed in that area.
The rationale for the original language for permitting High Impact Power Generation Facilities and Certified Power Generation Facilities was to avoid transporting pollutants to areas where high ozone readings already exist. Therefore, the language calls for siting these facilities where the prevailing wind patterns would not create a cumulative effect by pollutant deposition from these plants (principally NOX a precursor chemical to ozone). The wind pattern as illustrated here was used as the basis for siting these types of facilities within the southwest/phosphate mine portion of the county, thus avoiding pollutant deposition in metropolitan areas of the County.
This Wind Rose was developed from surface meteorological data available from the National Weather Service in SCRAM format for 1988 through 1991. Current conditions for wind patterns have not changed.
This overlay of the wind rose was prepared for this objection to compare prevailing wind patterns to Polk’s metropolitan areas.
While this criteria limited the siting of High Impact and Certified Electric Generation facilities, it did not limit Low Impact Electric Generation Facilities as defined in Polk County’s Comprehensive Plan. Siting of these facilities in proper land use categories within all areas of the county is allowed based on the characteristics of the facilities.
Low Impact Electric Generation sites are facilities that qualify under PURPA (Public Utilities Regulatory Policies Act of 1978) as cogenerators. Cogeneration reduces pollution to a metropolitan area by using the steam produced at a power plant for cooling as a replacement for other industrial boiler operations that are much more polluting. Siting these types of facilities would provide a net reduction of pollutant loading to an area while still affording the public with increased capacity for electric generation.
Since adoption of the original language, there has been no change in conditions that would provide any refuting data and analysis to the original assumptions and conclusions. Polk County has not provided the Florida Department of Community Affairs with data and analysis to justify the change as part of their transmittal. Further, Polk County’s "Staff Findings" section only contains unsupported opinion--they have not demonstrated a valid reason for the Comp Plan change.
We object to this Amendment because of the decrease in air quality that this Comp Plan change would encourage and the increased risk of Non-Attainment that Polk County would face. In fact, there is a greater risk of Non-Attainment than ever before. The most current data available to the public from FDEP shows that we are at an extremely high risk of Non-Attainment based on the current trends in readings from the two monitoring stations located in Polk County. The original siting criterion identified the southwest area of the county as having the least cumulative impact on air quality for the County. Siting criteria based on prevailing wind patterns avoided additional loading to urban areas already identified as having significant impacts. This limits the risk for Non-Attainment in Polk County and additional costs to citizens if Non-Attainment is reached and limits negative impacts to economic development countywide. The southwest/ phosphate mine area also has the land mass available to accommodate cooling pond style power plant operations and closed loop water recovery systems that limited aquifer withdrawals.
County Staff says by allowing high impact and certified electric-power generation facilities to locate in other appropriate Future Land Use designations, other geographic locations of the County will benefit from electric power generation facilities locating closer to where they are needed.
We say this rationale does not stand the test of reality. There are limited distribution resources elsewhere in the county where these facilities would site if the Comp Plan changes. The necessary line sizes needed to accommodate distribution are 168,000, 230,000 and 500,000-volt transmission lines. Over the past several years transmission systems have been enhanced in the phosphate mine area because of the consolidation of power generation facilities in this region. This infrastructure would need to be improved and built in other areas of the county to meet supply capacity. The fact that electric generation is some distance from the end user is irrelevant. The only form of electric generation that would work at the distribution line level that would allow siting throughout the county that is not accommodated now by the Comp Plan is a relatively new technology called Distributed Generation (DG). DG provides the efficiencies that large plants do not and warrant locating the facilities near the end user to directly connect to the distribution system rather than the transmission system. If the County should make any changes it should to add language that would provide for DG.
County staff says all residents and business need electric power. More plants are needed to handle Florida’s rapid growth. The amendment will create more opportunities for plant sitings.
We know that more than 60 new power plants are being permitted, or are in some phase of permitting, in the state of Florida. Capacity estimates exceed the projected need in Florida with these facilities for at least the next 10 years.
A petition is being circulated that asks DCA to disapprove this proposed Comp Plan amendment. If you would like a copy of it, please call 863-293-6961.
... Marian Ryan
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Living Machines for Waste Treatment
At the March meeting,
Judy Howell presented a videotape which described an ecologically friendly way to deal with a major issue that faces most communities and many industrial plants in Polk County. That is, how can we treat sewage, wastewater, and weather related runoff from our streets with a minimum utilization of energy and minimum production of harmful byproducts?
The system, called the LIVING MACHINE by its developers, Ocean Arks of Burlington, VT, employs aquatic vegetation, snails and fish to convert raw sewage into "pure" water in four days. This combination of biological organisms consumes all "nutrients" in the waste and some of the plants actually extract heavy metals and other toxic components thus rendering the effluent free of all contaminates except for some microorganisms. Presumably a few PPM of added chlorine or simple boiling would be all that is needed to make the outflow safe for human consumption.
Following the video tape, Judy fielded questions from the audience.