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.

Project Description

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’ representative

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:

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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.

[1]

[2]

[3]

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.

[4]

Furthermore, this 24.5 MW biomass facility represents new technology for whichthe MPCA recommends further study,

[5]

making an EAW vital to providing the general

public with the clearest possible understanding of the project’s environmental and social

impacts.

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The net cumulative impact of the project on air emissions

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The MPCA air permitdocuments provide estimates of potential emissions from the Midtown Eco Energyfacility.

[6]

However, the MPCA’s air permit documents do not provide any benchmarks to

understand what the incremental effect of the project will be on local and regional air quality.The proposed project is in close proximity to other large point source emitters. SmithFoundry, Abbott Northwestern Hospital, Pechiney Plastics, the University of Minnesota,Hiawatha Metalcraft & Hennepin County Energy Center all hold Title V air emission permitsand are located within 1.5 km (1 mile) of the facility. In addition, Bituminous Roadways andthe City of Minneapolis operate asphalt plants near the proposed facility.

[7]

The neighborhoodalso experiences a higher level of air pollution due to the high volume of car and truck trafficthrough the area on Lake Street, Highway 55 and Interstate Highway 94.

[8]

Midtown EcoEnergy will also be relying on up to 40 additional trucks a day, six days a week to haul woodto the facility. All of this automobile traffic and its associated emissions should be includedas part of a cumulative impact analysis as air pollution from mobile sources can contribute tobreathing and heart problems, aggravate asthma and are suspected of causing cancer andreproductive problems.

[9]

The need for and benefits of adding an additional major pointsource of pollution to a high-density urban area with many vulnerable population groups andhigher-than-average (for the metro area) air pollution levels, warrant clear documentation in

an EAW. Furthermore, the MPCA’s air permit documents fail to

estimate any potentialemissions reductions for the proposed district heating system (connecting the facility toAbbott-

Northwestern Hospital and the Midtown Exchange). Midtown Eco Energy’s main

selling point

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that it will be carbon neutral

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has no project-specific data available tosubstantiate or refute it. In evaluating whether the project is justified, it is helpful to quantifywhat reductions will occur due to the district heating system so the general public can moreaccurately weigh the potential impacts with the potential benefits.

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PM2.5 impacts from wood burning, natural gas combustion and increased automobiletraffic

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Particulate matter is the term used for a mixture of solid particles and liquid dropletsin the air. PM2.5 refers to particulate matter that is 2.5 micrometers or smaller in size.According to the U.S. Environmental Protection Agency (EPA), the sources of PM2.5include fuel combustion from automobiles, power plants, wood burning, industrial processes,and diesel-powered vehicles such as buses and trucks. Fine particles are of concern becausethey are a risk to the environment and to human health

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particularly to children and theelderly. Because these particles are so small they are able to penetrate to the deepest parts of the lungs. Scientific studies have suggested links between fine particulate matter andnumerous health problems including asthma, bronchitis, acute and chronic respiratorysymptoms such as shortness of breath and painful breathing and premature death.

[10]

TheM

PCA’s Air Quality Index (AQI) shows that even without Midtown Eco Energy and the

increased truck traffic it will bring, PM2.5 levels are on the rise at the South Minneapolismonitoring station (site 0963) located at 2727 10

Ave. S. AQI data shows that the PM2.5index reached 101 or more (unhealthy for sensitive groups) five times in 2007 compared toonly one time in 2006 and two times each in 2004 and 2005.

[11]

PM2.5 has not yet beenaddressed specifically in permitting actions.

[12]

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Environmental justice for vulnerable population groups in a densely populatedneighborhood

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According to the 2000 U.S. Census, the population of the four Phillipsneighborhoods (East Phillips, Midtown Phillips, West Phillips and Ventura Village) is19,805. Of this population, 68 percent are from minority groups, including: 29 percent black or African American, 22 percent Hispanics or Latinos, 12 percent American Indians, 6percent Asians and 9 percent multi-

racial. The remaining 32 percent of the neighborhood’s

population is white. Phillips is home to the very young and very old alike. According to the2000 U.S. Census, there were 1,955 children under the age of 5 living in the four Phillipsneighborhoods.

[13]

This age group represents 10 percent of the total population of Phillips,which is higher than the national average for the same age group.

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Phillips also has a fairlyhigh population of seniors. According to the 2000 U.S. Census, 10 percent of the Phillipspopulation was 55 years and older.

[15]

This data shows that Phillips has a higher number of both elderly and children under the age of 5 within its boundaries. Each of these demographicgroups has lower tolerance and lower immunity when dealing with sickness, air pollution andparticulate emissions. According to a Minnesota Center for Environmental Advocacy report,the costs associated with childhood illness like asthma and cancer are significant. The bestestimate of total costs of environmentally attributable childhood diseases in the state of Minnesota is $1.569 billion per year, with a range of $1.393 to $1.890 billion.

[16]

In addition, the percentage of people living in poverty is persistently higher in the Phillipsarea than in the City of Minneapolis overall. In 1999, 32 percent of all families in Phillipslived in poverty.

[17]

An impoverished community has less access to health information,doctors and treatments for sickness. Specifically, asthma, which is exacerbated by airpollution,

[18]

disproportionately affects communities of color and poverty. According to theCenter for Disease Control (2000-2005), 84 percent of asthma sufferers were non-white and73 percent were at or below the poverty level.

[19]

Locally, the Minneapolis Foundation in aJuly 2006 report found that the asthma rate for African American and American Indian adultsin Hennepin County is more than 25 percent higher than that of whites.

[20]

The composition

of Phillips’ population and its increased vulnerabilities, suggest a need for an EAW and a

more thorough Air Emissions Risk Analysis (AERA) normed on a more comparablepopulation so that environmental justice issues about the siting of Midtown Eco Energy canbe addressed.

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Benefit of doubt should err on the side of public safety

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The EAW provides 31 questionsthat must be answered, covering a broad range of environmental impacts. Some of theseimpacts may not be significant for the project, and the EAW process can help rule out theseissues as insignificant, while focusing on the issues that are significant specifically withregard to PM2.5, mercury, sulfur dioxide and lead emissions.

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Supporting evidence for statements made in this petition

[1]

U.S. Census Bureau, “Phillips General Demographic Characteristics” as produced by the City of

Minneapolis Planning Department, October 2001. (Online seehttp://www.ci.minneapolis.mn.us/citywork/planning/census2000/maps/phillips.pdf

)

[2]

MPCA AERA Internal Form-02 Impact Analysis Summary for Midtown Eco Energy, Answer toquestion number 20 on P. 6, February 2007.