March 22nd, 2017
The Great Plains Institute has long been a problem, and it remains a problem, evidenced in today’s missive trying to bootstrap onto tRump’s “infrastructure” agenda, by releasing a “White Paper” “calling on President Trump and Congress to make CO2 pipelines a priority component of a broader national infrastructure agenda and recommending that the federal government support the development of CO2 pipeline networks.” Oh, great… brilliant idea, just brilliant.
Great Plains Institute a problem? Yes. They were paid handsomely to promote coal gasification, projects including but not limited to Excelsior Energy’s Mesaba Project, the boondoggle of boondoggles. For example:
January 18th, 2007
Carbon capture and storage/sequestration was seen by many circa 2005 as a “way forward for coal.” So the Walton’s Bill Grant said. No. It wasn’t.
It wasn’t a “way forward for coal” then, and it isn’t now.
The market has spoken on coal, and it’s clear that coal is on the way out as coal companies go bankrupt, as coal generated electricity languishes on the energy market, and as the inefficient and costly older coal plants have closed, with newer larger plants waiting in queue to be shuttered.
And CO2 capture and storage/sequestration is a farce. Why? Well, we learned a lot about CO2 capture in our fight against Excelsior Energy’s Mesaba Project. That’s where the Public Utilities Commission determined that it was just to expensive and risky to approve a Power Purchase Agreement — go HERE and search for PUC Docket 05-1933. Here’s a rough visual of CO2 capture and storage/use:
So what’s the problem?
- First, capture is costly and difficult, particularly capturing any significant portion of CO2 generated.
- The higher percentage captured, the higher the cost of that capture, and high percentage capture has not been achieved.
- The cost of capture is not only the cost to physically do it, the hardware, technology, and engineering, but there is a high cost in efficiency of the CO2 producer, a parasitic cost, meaning that if you’re capturing that CO2, you’re paying a high price in efficiency of an already inefficient process (burning is always inefficient).
- And another parasitic cost, these pipelines require pumping stations to pressurize andpump it into the pipeline, a pumping station every 75 miles or so to keep that pressure up, and a pumping station at the destination, and those pumping stations require 4-10 MW of power, depending.
- Environmentally, the impacts of digging up land for hundreds of miles is immense.
- These are private projects and for a private project, a private purpose, eminent domain isn’t available for the taking of people’s land.
Yet this CO2 capture and storage/sequestration farce continues, evidenced in the most recent Great Plains Institute missive I found in the inbox, here the missive’s link to CO2 capture and storage for oil extraction, “Enhanced Oil Recovery”.
Here’s their “White Paper” with what they’ll be lobbying for:
Short version: The federal government should make this CO2 pipeline and infrastructure build out happen across the country, a la the Interstate highway system.
In light of tRump’s Executive Order 13766, Expediting Environmental Reviews and Approvals for High Priority Infrastructure Projects, that’s a scary notion.
Check out this site from Global CCS Institute, and note, they talk of benefits, but look for talk of costs. Hmm…
A “way forward for coal?” CO2 capture? Over my dead polar bear.
March 13th, 2017
Lake Pepin on a very warm blustery day last week
There’s a bill out there that will eliminate Minnesota’s Environmental Quality Board and shove that work over to the MPCA, at the same time, gutting DNR and MPCA review by linking to funding or lack thereof. Shifting preparation of environmental documents to the project applicant. This is not crying wolf, this is happening, it is going through committees in both House and Senate, and I’m at a loss to describe how awful this is. Here’s the point, in short:
Mindful that defunding is a primary means to neuter an agency, check this, for the DNR, but repeated as amendment to 116.07 for Pollution Control Agency in lines 10.3-10.15:
Look at line 3.32 “nor shall it expire without the consent of the permittee.” Gutting DNR and MPCA authority. Failure to fund agencies is such a problem that the MPCA has a backlog of expired permits. This means that permits would go on and on and on, because permit violations are not usually an “imminent threat” but instead a long term cumulative impact.
How about this — earth to Mars, environmental review is not decisional, nothing should be deemed approved because an EIS is approved:
The project applicant prepares the Draft Environmental Impact Statement? WHAT?!?!
Still picking out more specifics…
Bottom line, Minnesotans, here’s the “TO DO” of the day. Contact the House and Senate authors, and send a quick round of emails or call the House Ways & Means and Senate Environment and Natural Resources Finance. Focus on the authors and Republican members. Tell them to vote this bill DOWN! Contact info below.
Here are the House authors:
email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com
Here are the Senate authors:
Senate Status: TEXT – was Amended and amendment not posted. TWO Committee meetings scheduled, one TODAY, BUT status is conflicting:
|Committee on State Government Finance and Policy and Elections|
|03/13/2017||Meeting scheduled for 05:30 PM in Room 1200 Minnesota Senate Bldg.|
|03/13/2017||No Committee Action Recorded|
|Committee on Environment and Natural Resources Finance|
|03/15/2017||Meeting scheduled for 10:30 AM in Room 1150 Minnesota Senate Bldg.|
Here’s the conflict, says it’s already been through State Gov’t Finance despite above 5:30 schedule!
So I think the best bet is to contact Environment & Natural Resources Finance:
February 25th, 2017
The Minnesota legislature is trying to repeal the legislative mandate to the MPCA for rulemaking on silica sand particulate emissions! Why is this a priority? How is it in the public interest? This effort to quash rulemaking is rather odd because the silica sand boom has gone bust, Bakken BOOM! has gone bust, the market has decided and there are few (no?) plans for new silica sand mines in Minnesota. Now is the best time to enact protective legislation, while there’s no pressure for new mining permits.
The legislature passed the following rulemaking mandate in CHAPTER 14–S.F.No. 1086 way back in 2013 (keep in mind this is 2017, FOUR YEARS LATER and it is STILL not done!) with the exemption from Minnesota Statutes section 14.125 “no time constraint” added by moi:
Sec. 105. RULES; SILICA SAND.
(a) The commissioner of the Pollution Control Agency shall adopt rules pertaining
to the control of particulate emissions from silica sand projects. The rulemaking is exempt from Minnesota Statutes, section 14.125 [no time deadline].
(b) The commissioner of natural resources shall adopt rules pertaining to the
reclamation of silica sand mines. The rulemaking is exempt from Minnesota Statutes, section 14.125 [no time constraint].
(c) By January 1, 2014, the Department of Health shall adopt an air quality
health-based value for silica sand.
(d) The Environmental Quality Board shall amend its rules for environmental
review, adopted under Minnesota Statutes, chapter 116D, for silica sand mining and processing to take into account the increased activity in the state and concerns over the size of specific operations. The Environmental Quality Board shall consider whether the requirements of Minnesota Statutes, section 116C.991, should remain part of the environmental review requirements for silica sand and whether the requirements should be different for different geographic areas of the state. The rulemaking is exempt from Minnesota Statutes, section 14.125 [no time constraint].
EFFECTIVE DATE.This section is effective the day following final enactment.
WHAT? Who’s behind this? Mining industry? Given Sen. Tomassoni is one sponsor, perhaps, and given former Sen. Saxhaug’s nastiness about the enabling legislation, even more likely. MPCA? Given their foot dragging and resistance to citizen involvement, perhaps. Back when this rulemaking was just getting going, the MPCA was against having a Citizens Advisory group is authorized by Minn. Stat. 14.10:
Each agency may also appoint committees to comment, before publication of a notice of intent to adopt or a notice of hearing, on the subject matter of a possible rulemaking under active consideration within the agency.
And the MPCA’s objection:
MPCA staff’s report to the EQB stated inexplicably and incredibly that they were “confused,” claiming ignorance of how rulemaking works and the impact of comments at this stage – from their memo to the EQB:
Members of the public expressed interest in a citizen committee to participate in the rulemaking. It is not clear how a citizen committee would affect the rulemaking process laid out in Minn. Statutes Ch. 14. A multi-step public review and comment process is already required in that statute and we just completed the preliminary step. Rulemaking is essentially creating law: Minnesota Rules have the force and effect of law. Rulemaking is a lengthy process, averaging about two years.
So now we have this bill, headed to the House and Senate Environment Committees, contact info below.
Contact the House authors and ask that they withdraw HF 1666 (be sure to put bill number in subject line):
February 8th, 2017
You may have read tRump’s Memorandum pushing the Army Corps of Engineers to ram through the Dakota Access pipeline:
From the Stanley Gazette:
And from the DC District Federal Court, here are the filings:
The Army rolled, and here are the documents stating intent to issue the DAPL easement across Lake Oahe, and the Notice of Termination of the Environmental Impact Statement:
How is this anything but “arbitrary and capricious” action on the part of the Army Corps of Engineers?
January 26th, 2017
As we know, tRump signed a “Memorandum” (note, it is NOT an “Executive Order”) to ram through DAPL. Here’s the cut and paste of the Memorandum, also here at the White House Memoranda page:
One part I’m particularly concerned with is the second paragraph, where the Army Corps is ordered to consider rescinding or modifying the denial of the permit, and whether to withdraw the Notice of Intent and request for Scoping Comments for the Environmental Impact Statement:
(ii) consider, to the extent permitted by law and as warranted, whether to rescind or modify the memorandum by the Assistant Secretary of the Army for Civil Works dated December 4, 2016 (Proposed Dakota Access Pipeline Crossing at Lake Oahe, North Dakota), and whether to withdraw the Notice of Intent to Prepare an Environmental Impact Statement in Connection with Dakota Access, LLC’s Request for an Easement to Cross Lake Oahe, North Dakota, dated January 18, 2017, and published at 82 Fed. Reg. 5543;
Really. That’s tRumpspeak for “Issue the Permit, Who Needs an EIS!” So methinks it’s VERY important to get a lot of detailed scoping comments in ASAP!
What are Scoping Comments? It’s kind of a term of art, they are comments laying out what you think should be covered in the Environmental Impact Statement. It’s a “broadening” exercise, one where you bring up all the things that could be, should be, relevant and investigated, disclosed, analyzed, in the Environmental Impact Statement. Form letters and postcards won’t cut it, this requires a little time and thought, and because you can email them, it’s pretty easy. Just be specific about what issues should be considered. Because they’re looking for “alternative routes” I wouldn’t give them any, because if they put it anywhere, it’s a problem, so I’d recommend instead saying that moving the pipeline doesn’t lessen the odds of rupture, failure, corrosion, and that the pipeline is too much of a rupture waiting to happen to route anywhere!
Here’s the Notice:
Scoping comments are due by February 20, 2017. By mail, and they ask that you include your name, return address, and “NOI Comments, Dakota Access Pipeline Crossing” on the first page of your written comments:
Office of the Assistant Secretary of the Army for Civil Works
108 Army Pentagon
Washington, DC 20310-0108
By email to firstname.lastname@example.org – use Subject: NOI Comments, Dakota Access Pipeline Crossing
They say they want comments about these issues:
(1) Alternative locations for the pipeline crossing the Missouri River;
(2) Potential risks and impacts of an oil spill, and potential impacts to Lake Oahe, the Standing Rock Sioux Tribe’s water intakes, and the Tribe’s water, treaty fishing, and hunting rights; and
(3) Information on the extent and location of the Tribe’s treaty rights in Lake Oahe.
… BUT… don’t limit your input — get creative, be specific, really think about impacts, about connected actions, about the entire length of this pipeline, about each of the bodies of water, the archeological features, protected wildlife areas, homes right next to the line, aquifers with so many wells drawing their water supply, nearby transmission lines which are known to corrode pipelines if too close. In the Notice, they specifically state, “The range of issues, alternatives, and potential impacts may be expanded based on comments received in response to this notice and at public scoping meetings.” So now it’s our job to be very, very specific about the broad range of issues to be included in the Environmental Impact Statement.