Today’s EPA deadline

The Friday Photo
May 9, 2014

pine trees
mature pine trees in our front yard

I had other plans for The Friday Photo today but spent more time than I expected crafting my comments to the EPA about proposed carbon pollution rules for existing power plants and why Plant Washington isn’t an existing source of greenhouse gases. The deadline was today at 5:00 p.m.

My comments included this:

“On a sunshine soaked afternoon in September 2013 while Power4Georgians was announcing its intent to request permit extensions from the Georgia Environmental Protection Division, crews hired by the current land owners were preparing the proposed plant site for planting timber. Growing timber is an investment in time and money, as my family knows from timber management on our family farm. Growing trees requires patience as it takes several years before even a thinning of the growth is necessary, with significant harvesting sometimes requiring 20 years of patient waiting and watching.”

Just like growing timber, fighting Plant Washington has required time and patience, and some watching and waiting. The investment for those of us who steeled ourselves and stood up in our community has been worth the effort. We won’t have to wait decades for the return on our investment.

You can’t take “way over” to the bank

Last Wednesday’s Macon Telegraph included coverage of the long-lingering proposed Plant Washington and developer Dean Alford’s race to meet an April 12 “commence construction” carbon pollution rule deadline set by the EPA almost a year ago.

Should someone call or email Alford? Maybe he missed exactly what the EPA said when it announced the carbon rule (see section 2.2.4). Maybe he hasn’t seen the EPA filings specifically about Plant Washington, or the news coverage and numerous web site postings in the past year pointing out that beating the clock on the April 12 deadline won’t help his no-bid project.

When the EPA announced the deadline, the agency said very clearly that to be exempt from the carbon rule, new coal plants had to have a final permit in hand.

Plant Washington didn’t have a final permit when the rule was announced.

So it isn’t exempt from the carbon emission rules when you get right down to what the EPA said. We all know from past playground experience, whoever makes the rules also gets to enforce them.

The EPA knows exactly when Alford got a final permit because last spring in another set of court filings pertaining to mercury emissions, the agency refers to Plant Washington’s lack of a final permit at the time the carbon rule was announced. The EPA’s filing included this, “The Power 4 Georgians’ (“P4G”) Project (Case No. 12-1184): Movants submit a declaration stating that “as of April 9, 2012, P4G has a final PSD permit and all other required permit approvals necessary to commence construction of Plant Washington.” Mot. Ex. H ¶ 5. This assertion is incorrect, inasmuch as state administrative challenges to the P4G permit remain pending.”


Other coal developers did get the news. They ran the numbers again for their projects as natural gas, and even wind and solar, gained more ground in the power generation market.

Like dominoes, developers began cancelling proposed plants, even in coal friendly states like Texas. The math just didn’t add up any longer. They couldn’t finance, build, and then sell coal-generated power for a profit. They said new coal can’t compete, and existing coal isn’t so cheap either. Beating an April 12 deadline wouldn’t help them. They couldn’t afford to go forward.

Despite the fact that the carbon rule does apply to Plant Washington (and Alford said that having to meet carbon rules would kill the project), Alford has continued talking up his project and making a lot out of meeting the April 12 deadline.

Earlier this week Alford continued the charade when he told the Telegraph “If I add up everybody I’m talking to, I’ve got way over the amount of money I need for this project.”

“Way over” must be A LOT of money, because conservative 2011 estimates, without carbon controls, put Plant Washington at a whopping $3.9B, almost doubling the original $2.1B estimate in 2008. I can’t imagine how many zeros would be added to a price estimate to engineer and control for carbon.

Alford is “talking to” utilities, private investors, pension funds and independent power producers. (Never mind that one doesn’t “talk to” pension funds, it is the fund manager who must be convinced to invest.) Power4Georgians (P4G) and Washington EMC also think there is no reason to be burdened by a pro forma study or independent market analysis to make the case to investors, so at least they aren’t having to trot out tried and true methods of return on investment to funders.

Oh yeah, “talking to” is also not the same as having power purchase agreements, contractors, an EPA approved boiler design, county issued bonds, or all the financing confirmed.

And in all this “talking to,” who is Alford saying will own this plant which will not only supply power to the power purchase customers, but also repay the debt owed in a timely manner?

When Alford announced Plant Washington in January 2008, he said it would be owned and operated by the EMCs in P4G. I heard it with my own ears because I was in the room. Alford even said that under oath in September 2010.

That all changed when his former employer, Cobb EMC, abandoned the project in January 2012. Alford made a final pitch at that meeting to keep his largest funding source engaged. The Marietta Daily Journal’s coverage last year included this from the Cobb EMC minutes, “Power4Georgians owns the permits but he (Dean Alford) stated that P4G never intended to build Plant Washington. He stated P4G’s goal has always been to obtain the permits needed and then sell them to any interested party that could build the plant.”

In January 2012 Alford told the AJC there were “hundred of entities” interested in this project. If the contracts were real, investors were lining up to get a piece of this project, and an owner had been secured, wouldn’t they have been paraded out by now?

The time for Alford and the four remaining EMCs to call it a day on Plant Washington is “way over.”

There’s no need to wait until April 12.

Rural and Progressive

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