PETITION FOR ENVIRONMENTAL ASSESSMENT WORKSHEET
We, the undersigned individuals, petition the Environmental Quality Board (EQB) forpreparation of an Environmental Assessment Worksheet (EAW) for the proposed Midtown EcoEnergy LLC facility at 2850 20
Avenue South, Minneapolis. We, the undersigned, believe there arestill significant issues that the project must address before the Minnesota Pollution Control Agency(MPCA) considers issuing a permit for the facility.
Midtown Eco Energy is a proposed 24.5 MW biomass energy facility to be located at 285020
Avenue South in the East Phillips neighborhood of south Minneapolis. The surrounding areaconsists of residential, commercial and industrial uses in a densely populated neighborhood that iswell known for its diverse population and abundance of community gardens. The facility will consistof a 358.6 MMBtu/hr wood-fired Main Boiler, an emergency generator, a cooling tower and woodhandling equipment.
According to the MPCA’s draft Air E
mission Permit No. 05301187-001, theprimary fuel source for the facility would be tree trimmings and wood waste though the permit alsoallows for the combustion of natural gas and other experimental fuels.
Petitioners are represented in this matter by Jullonne Glad, 3245 21
Avenue South,Minneapolis, MN 55407, tel. 612-722-9514.
Environmental and Social Impacts that warrant an EAW
Given the dense urban location of the project, there are important environmental impacts of theproject for nearby residents and regulators to fully understand before making any final decision topermit this facility in this location. We submit that the project has the potential for significantenvironmental effects and are petitioning the EQB for the project developer to complete an EAW forthe project for the following reasons:
Mandatory EAW threshold is 25 megawatts (MW), Midtown Eco Energy facility is 24.5MW and would be situated in a dense urban setting using new technology that warrantsfurther testing -
Minnesota Rules 4410.4300 establishes a threshold that determines whetheror not an EAW must be prepared for a particular project. The EAW threshold is at 25 MWfor Midtown Eco Energy, an electric generating facility as defined in 4410.4300 Subpart 3.
The project’s developers are seeking a permit for a 24.5 MW electric generating facility –
barely below the mandatory EAW threshold. It is highly likely that this electric generatingfacility will run at 105-percent capacity on occasion and thus breach its 24.5 MW capacity.However, even if the facility never exceeds its 24.5 MW capacity, the difference between a24.5 MW and a 25 MW facility is so miniscule that closer scrutiny is necessary in this casebecause the 24.5 MW facility would be situated in a densely populated neighborhood that isalready burdened by excessive emissions.
Placing a 24.5 MW facility in a dense urbansetting where cumulative impacts are already a significant factor is not the same as placing a24.5 MW facility in a setting with fewer people and less existing pollution. In addition, the
project’s developers have already demonstrated their willingness to expand the size of their project; according to the MPCA’s Impact Analysis Summary dated February 2007, Midtown
Eco Energy was originally slated to be a 22.5 MW facility and was increased to a 24.5 MWfacility.
Furthermore, this 24.5 MW biomass facility represents new technology for whichthe MPCA recommends further study,
making an EAW vital to providing the general