Legalectric

Oops, running late on getting the Letters to the Editor posted. Here’s the ones from this weekend’s Grand Rapids Herald Review — there weren’t any in yesterday’s paper. Who is this Robert Crowe and what’s his “dog” in this Mesaba coal gasification project?

Project will endanger health

Herald-Review
Friday, November 10th, 2006 04:33:22 PM

Editor:

In a letter to the editor in the October Herald-Review Robert Crowe of Hill City stated that Excelsior Energyâ??s proposed coal gasification plant would be good for this area and that arguments from the detractors of the project are mostly proven untrue. I challenge Mr. Crowe to prove the following arguments to be untrue.

Excelsior plans to use water from the Canisteo Mine Pit, known as Pit Lake, and run it through three to eight times in their cooling towers before discharging it back into the pit. Each cycle will reduce the water by 80 percent thereby increasing the mercury, phosphorus, sulfate and other solids as much as eight times with each discharge. This is documented in appendix 6 of Excelsiorâ??s Joint Permit application. The pit is tied in with the aquifers serving Bovey and Coleraine, (per Baxter Jones testimony to the Minnesota Public Utilities Commission.)

The proposed plant would be expected to discharge 54 pounds of mercury and 6,558 tons of other pollutants per year, as is documented in section 1.8 of the Mesaba Energy Project Environmental Supplement. According to section IV page 124 of Excelsiorâ??s report to the Public Utilities Commission, under the heading of â??Health Benefits,â? pollutants from Mesaba One will kill 1.5 fewer people in Minnesota that if it were a traditional coal fired plant, 6.4 fewer in the United States as a whole. We can double those figures if both Mesaba One and Mesaba Two were running. Encouraging isnâ??t it? I believe Hill City is in the line of fire for these â??health benefitsâ? too.

Darrell White
Bovey

And here’s another:

Air quality will be compromised

Herald-Review
Friday, November 10th, 2006 04:33:46 PM

Editor:

Regarding a couple of letters by Robert Crowe of Hill City, I have the following comments. I don’t know whether he has a dog in this fight or if he merely chooses to express his opinion.

Judging by the address, he must live outside the predicted fall-out zone, won’t have to surrender his home to eminent domain, or leave if the air quality becomes unbearable.

In an earlier letter, Mr. Crowe referred to the diesel smoke that was emitted by the trucks when the natural ore mines were in operation. I worked in, on, and around these trucks for almost 40 years. Granted, I inhaled a lot of diesel fumes and ore dust, but they are relatively benign compared to what would be produced by Mesaba Energy. The smoke and dust were generally confined to the mine area and were not a hazard to the general public. However, the coal-fired steam locomotives that traveled through Coleraine and Bovey on their way to Trout Lake concentrator and the dumps that are now Eagle Ridge Golf Course would have been a different matter.

The IGCC process is referred to as a “clean coal technology,” but it can only be “cleaner coal technology” if and when the proper procedures are followed. So far developers have not demonstrated that they are prepared to do so.

Alvar E. Hupila
Bovey

Huh??? What’s going on here? It’s unprecedented — at yesterday’s Prehearing Conference, we reached a (reluctant on my part) “global agreement” that the evidentiary hearing on the Excelsior Mesaba coal gasification project isn’t happening. We’re going forward on the basis of the prefiled testimony and exhibits, and given that those of us who don’t have resources, budgets, staff, etc., get our evidence in on cross-examination, we’ll be introducing all the Exhibits we can find, that is those “in the public domain.” For our exhibits thus far, go here www.mncoalgasplant.com/ppa.html and scroll way down to MCGP Exhibits. The most popular ones for download right now are the Excelsior Scherner Presentations to NM-SPG!

There will be public hearings in December:

December 18, 2006
1 p.m. & 6 p.m.
PUC Lg. Hearing Room
121 – 7th Place East, 3rd Floor
St. Paul, MN

December 19, 2006
1 p.m. & 5 p.m.
Hoyt Lakes Areana
Hoyt Lakes, MN

December 20, 2006
1 p.m. & 5 p.m.
Taconite Community Center
Taconite, MN

Noteworthy too is that the crucial cost information on CO2 capture and sequestration will remain “Trade Secret.” What a load of crap — it’s just a way of delaying the societal recognition that carbon capture and sequestration ain’t a happenin’ thang… and so I’m digging and digging on the internet to find that same info. Why? Well, for example, look at all that Joyce Foundation pro-coal gasification money going into the new enviro mantra, “IGCC is good with CO2 capture and sequestration” and coal gasification junkets to Europe. And of course the Joyce Foundation’s CCX — they didn’t corner the market on CO2 trading, they MADE it! Carbon capture and sequestration in Minnesota is an utterly delusional pipedream, everyone working on this case knows it’s an utterly delusional pipedream, including MCEA, Fresh Energy, Waltons — we all have this info and know it. So fair warning — I’d better not hear any of these groups singing that IGCC mantra!

And for everyone who’s dying to know what generation is proposed, here’s a spreadsheet of the MISO Queue in sortable Xcel. Why? Because then you can ask “How much wind is proposed for Illinois?” and find out that it’s 8,682.4, so when anyone tells you they’ll be building wind in South Dakota and shipping it to Illinois, you can confidently say, “I don’t think so!” Here’s the Excel MISO Generation Spreadsheet!

miso-queue-with-coal-separated-out-sheet-2.xls

Have fun and pay attention!!!

.

Ken relaxing at Lock & Dam #3 with the Priarie Island nuclear plant in the background.

Let me see if I understand this… Prairie Island has diesel generators that they fought like hell about 10 years ago to get classified as “pollution control equipment” so that they’d be exempt from utility personal property tax. These engines, after all, kick in to keep the cooling system going when there’s a power outage and prevent nuclear meltdown so they must be pollution control equipment, eh? (Imagine the mind that thought up that argument, and the yahoos that bought it!) Anyway, these pollution control engines spew crap into the air like any diesel, including Nitorgen Oxide (no, not Nitrous Oxide, it’s not a laughing matter). So now they’re at the Pollution Control agency because they’re in violation of their Air Quality Permit and want to avoid New Source Review. Uh-huh… right… and so what do they propose? Heaven forbid they would have to abide by their permit — nope, no sir, what’s proposed is to raise the emissions limits and decrease the fuel they burn (therefore decreasing emissions, duh). Compliance isn’t contemplated.
Primary documents:

publicnotice.pdf

draftairemissionpermit.pdf

technicaldoc.pdf

It seems to me that this is unreasonable, given that it’s pollution control equipment, after all. Now supposedly biodiesel isn’t as NOx-ious as regular diesel, so why aren’t they required to burn biodiesel? They could keep it warm in the winter by nestling it in with the casks? And as a former truckdriver, cutting the fuel usage limit from 83,955 to 70,238 gallons/month is bizarre. What exactly are they doing out there? In a truck, it’s about 780 gallons from here to California, multiple drops in LA and produce pickups, and back home with multiple drops. So every month, they’re burning the equivalent of 100 trips to CA and back? How often are they using these generators and what for? If the plant has such a laudable capacity factor, why are they running the diesels at all? Methinks I’d better ask Michael Wadley about this, now that he’s off the Mesaba Project and back to boring old nuclear, he could use a little excitement!

And here I thought it was an emissions increase for the garbage burner across the highway… silly me… but look at this blurb in the paper, it’s called the “steam plant.” HUH?!?!?!

Xcel proposing changes to limits

The Republican Eagle

Published Tuesday, November 14, 2006

The Minnesota Pollution Control Agency will open a public comment period on Wednesday for an Xcel Energy air emission permit proposal at the companyâ??s Red Wing steam plant.

The major amendment in reissuance of the permit is to increase the emission limit for nitrogen oxides. The public comment period runs from Nov. 15 to Dec. 14. Contact MPCAâ??s Trevor Shearen at (651-) 296-8638 for more information.

Here’s the rough list of Exhibits for the Excelsior Mesaba coal gasification project that need to get on the record — it’s not complete, and there are some to be deleted because I can’t find some exhibits that should be in these boxes somewhere, i.e., the Harvard report — which one is in and which ones need to be added? Are all the G519 Miso studies in there?? And I still have to scan in some of the documents, the ones below without links, zzzzzzzzzzzz, this is SO tedious…

OK, the list:

Xcel IRP E-002/RP-04-1752 Order Clarifying…for Baseload Proposals

MISO Queue as of 11/10/06

MISO STUDIES & MAPP NM-SPG PRESENTATIONS

G477 Interconnection Feasibility Study March 10 2005 (p. 9 â?? Deliverability = 90MW)

G477 System Impact Study Rev July 6 2006

G519 System Impact Study 2nd Revision June 6 2006
G519 Short Circuit Study July 27 2006

G519 System Impact Study 1st Revision May 8 2006

G519 Initial2post â?? Branch Violations
mcgp-ex-g519-initial2post-branch-violations.pdf
Excelsior Sherner Presentation to NM-SPG 03-30-04
mcgp-ex-excelsior-sherner-presentation-nm-spg-03-30-04.pdf
Excelsior Sherner Presentation to NM-SPG 10-26-04
mcgp-ex-excelsior-sherner-presentation-nm-spg-10-26-04.pdf
Excelsior Sherner Presentation to NM-SPG 05-05-05
mcgp-ex-excelsior-sherner-presentation-nm-spg-05-05-05.ppt
Excelsior Sherner Presentation to NM-SPG 08-16-06
mcgp-ex-excelsior-sherner-presentation-nm-spg-08-16-06.ppt

MISC. ARTICLES

Iron Range Board gives subsidy for new power plant â?? Business Journal, December 12, 2001

Mesaba Energy Project: Powerful Stuff
Energy Park developer pitches Hoyt Lakes power plant
Excelsior Energy back to start up Mesaba project

Wabash River Coal Gasification Repowering Project – Final Technical Report
Treatment of Coal Gasification Wastewater â?? ORNL
Labovitz Reports from UMD:

The Economic Impact of Constructing and Operating an Integrated Gasification Combined-Cycle Power Generation Facility on Itasca County (for IEDC) April 2006
The Economic Impact of Constructing and Operating an Integrated Gasification Combined-Cycle Power Generation Facility on the Iron Range, Update 2006
The Economic Impact of Constructing and Operating an Integrated Gasification Combined-Cycle Power Generation Facility on the Iron Range, September 2005
DOE Notice of Financial Award and Agreement â?? dated May 23, 2006

Harvard 3 Party Covenant reports (not already entered):

Financing IGCC â?? 3 Party Covenant

Deploying IGCC in This Decade with 3 Party Covenant Financing â?? Volume 1, July 2004
Deploying IGCC in This Decade with 3 Party Covenant Financing â?? Volume 2, May 2005 Revision

IRR Exhibits â?? stipulated by Guunar B. Johnson, Asst. A.G. for IRR:

IRR Letter to Chris Clark, Xcel Energy â?? January 26, 2006
mcgp-ex-irr-letter-to-clark-january-26-2006.pdf
IRR Letter to Chris Clark, Xcel Energy — March 22, 2006
mcgp-ex-irr-letter-to-clark-march-22-2006.pdf
Public Infrastructure Improvement Study â?? January 2006
mcgp-ex-irr-seh-public-infrastructure-improvement-study-january-2006-selected.pdf
Agenda from June 8-10, 2005 DOE site visit with scope of work, maps, list of attendees , and pictures
mcgp-ex-irr-doe-site-visit-june-8-10-agendaparticipantpotosselected.pdf
Excelsior Energy $8,000,000 Convertible Debenture Agreement

Minnesota Power Exhibits â?? stipulated by David Moeller, Minnesota Power
American Transmission Company, Minnesota Power and Wisconsin Public Service Corp.
Arrowhead to Weston 345kV Transmission Line, Cost Estimate Audit Report, Revision 1
May 23, 2003
R.W. Beck Final Report, Independent Cost Review of the Arrowhead-Weston Project, #RPA-PSD-160, July 2003

The record from the Public Hearing in St. Paul, Taconite and Hoyt Lakes must be fully incorporated into the record and citable in briefs. And then there’s the matter of that Fluor Attachment 1 – that’s got to be made public!

The Webstermeistress of mncoalgasplant.com and I were on the horn last night organizing the PUC files for the Excelsior Mesaba coal gasification project, and just now, she sent this missive:

Did you know that the combination of words Excesior Energy, Mesaba Project and Boondoggle, Pork are searched for on the internet 10 times a day – every day…

Now that’s a day brightener as I dig through piles and piles of papers looking for documents for our “Exhibit List” to submit tomorrow.

Lots of Mesaba documents are here on Legalectric, and there’s a lot more on the mncoalgasplant.com site. Check it out! Everything you ever wanted to know about coal gasification and lots they don’t want you to know!