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Box 182 Richfield, Utah 84701 435-527-4448
August 13, 2012 Sevier County Commission 250 N Main St. Richfield, Utah 84701 Dear Commissioners, Two years ago, you, the Sevier County Commission embarked on a major project to create a PUD for Sevier Power Company. At that time you invited Sevier Citizens for Clean Air & Water to offer suggestions that might be incorporated into that PUD. We did offer suggestions and recommendations and many of these were ultimately made a part of that PUD. The process of collaboration worked. SCCAW is grateful for that opportunity and we thank you for it. Here we are two years later and Sevier Power is still struggling with their application for an Air Quality Permit from UDAQ. Twelve years have now elapsed since the project was initially proposed. Is this any way to run a business? To our knowledge Sevier Power still does not have a source of natural gas with which to fuel the power plant, does not have a permit to connect to the Rocky Mountain Power substation in Sigurd, has not applied for transmission capability, does not have a customer to purchase the power generated and, without all of the above, does not have financing with which to construct the plant. Homer Simpson could have done a much better job. On Thursday, May 31, we all sat through a Public Hearing, scheduled by UDAQ, to voice our concerns about the draft Air Quality Permit for Sevier Power. A number of significant issues were raised at this hearing. First and foremost is the issuance of pollution allotments to Sevier Power based upon the “assumption” that the air within Sevier County is “in attainment”. This is a general term used by the department to classify any air shed of which they know little or nothing. Think about this for a minute. Sevier Power is asking for the right to pollute with regulated noxious airborne chemicals to the extent of 977 tons per year
(tpy) plus 2,019,226 tpy of greenhouse gases for a period of 40 years. UDAQ is ready to approve this huge increase in our pollution level without even taking the time to investigate the existing condition of our air. They are not even making a SWAG (scientific wild ass guess). Does this make any sense to you? It certainly does not make sense to SCCAW. Assuming that UDAQ might be correct in their guess about the existing air quality of Sevier County, the amount of pollution issued to Sevier Power will come close to the threshold that would soon place Sevier County in a nonattainment status, just as counties along the Wasatch front are now. Should the air be found to not be as clean as assumed, then we could already be in non-attainment status. Is this what we want for Sevier County? When the air quality is approaching the limit of an “attainment” area, what is left for other businesses that we might wish to attract to our county? Some people have said that having a power plant here in the valley will attract other businesses requiring large amounts of power. What ones do you know that don’t also contribute large amounts of pollution. Could they even get an air quality permit with the increments already spoken for? Think about it. Should Sevier County reach non-attainment status, we could lose our ability to attract new businesses. Our current mining and trucking industries may be negatively impacted if there is insufficient pollution increments left after permitting SPC. Current guidelines state that any proposed consumption of increments of pollution should be effectively utilized by the applicant and should not needlessly tie up increments from use by others. Sevier Power Company has been in the application process for a power plant in one form or another since 2001. There is no indication that this application is any more viable than their previous application. There well may be other applicants, in any number of other industries, that might want to take advantage of these increments should they be tied up. It is certainly in the best interests of the UDAQ, the State of Utah and Sevier County to protect incremental consumption for use in viable projects. The following is a quotation from the Utah Supreme Court decision in which the air quality permit for Sevier Power Company was sent back to the division for additional work: “Instead, Utah rule 307-401-11 governs the enforcement of Utah’s PSD program, which was approved by the EPA. This enforcement rule, as approved by the EPA, must be interpreted to achieve the same goals as the federal PSD program. These goals include ensuring that a new emitting source is
constructed with the most current control technology and that a PSD permit for a new source does not tie up PSD increment limits unnecessarily. The Board failed to interpret the rule to achieve this goal when it - - -“
Our primary concern now is that no one really knows what the year round status of the air in Sevier County is. In addition to periodic wildfires, agricultural burns, truck and heavy equipment exhaust, agricultural dust and other permitted mining dust we also have frequent, and sometimes lengthy, inversions – all year round. Don’t you think we should know what our air quality really is? Don’t you think we have the right to know? SCCAW believes both of these questions are pertinent, and that is why they were raised at the Public hearing – and are being raised now. SCCAW is asking you, the Sevier County Commissioners, to take an active role in demanding that UDAQ , either themselves or through the permit applicant, undertake an EPA recommended study to determine the actual levels of pollution for a period of at least one year before finalizing any permit for Sevier Power. Actual data must be collected to protect the health of the population as mandated by the federal Clean Air Act (CAA). You have a duty to the citizens of this county to avoid any undue risks to the health and welfare of all of our citizens. Over 700 residents of Sevier County are now on supplemental oxygen and any reasonable physician will acknowledge there are likely two to three times that number with other respiratory and cardiac problems that will be amplified by the increase in air pollution. SCCAW also requests that Sevier County’s representative to the Central Utah Board of Health request that CUPHD also make the same request of UDAQ. Remember, this permit is good for 40 years, the expected life of the plant. This plant could easily outlive every one of us here in this room today. This plant will not only have an impact on you and I, it will be a legacy for our children and grand children. The quotation below is taken directly from the home page of the Central Utah Public Health Department’s website. Central Utah Public Health Department (CUPHD) was established in 1973 with a mission to improve and protect the health of all citizens in the six-county area by offering services that enhance the environment, prevent illness and injury, and promote healthy lifestyles. Central Utah Public Health provides services to a growing population of over
70,000 residences of Juab, Millard, Sanpete, Wayne, Sevier and Piute. Particular areas of concern for the department are access to health and dental care, cancer prevention, unintended pregnancies and healthy lifestyle education. A Board of Health comprised of elected County Commissioners and citizen representative(s) from each county governs CUPHD. Mission Statement To improve and protect the health of all citizens in the six-county area by offering services that enhance the environment, prevent illness and injury, and promote healthy lifestyles.
With statements like these, how can the department refuse this request? Should the department reply, as they have in the past, that they do not have the research staff to accomplish this I refer you to appendix “A” authored by Dr. Brian Moench of Utah Physicians for a Healthy Environment. You will never see a more thorough analysis of the issue. In short, SCCAW has two issues here: First; SCCAW is asking for the support of you, the Sevier County Commission to request the Utah Division of Air Quality to complete an actual analysis of the air quality in Sevier County prior to issuance of pollution allotments for Sevier Power Company. Second; SCCAW requests that you, the commissioners request immediate involvement by CUPHD to fulfill their mandate to the citizens of Sevier County and the surrounding area. Only with scientifically collected data can we assure ourselves, and our posterity, that we have given this project thorough evaluation. Thank you, Dick Cumiskey President, SCCAW