We
have a vision for a new Salem Green Harbor built
entirely around
progressive energy sources. It would be a mixed use
facility built through a public-private partnership to
use solar, wind, wave and geothermal energies
exclusively. It will include a manufacturing facility,
an environmental conference center and hotel, parking,
condos, marina and office and restaurants on the harbor
front. Wind turbines will adorn the jetty, and the deep
harbor port will accommodate cruise ships. The natural
and historic beauty of Salem Harbor will once again be
restored.
Fifty six years of a toxic power plant are enough. Let's
embrace the future for Salem! It will have more jobs and
more taxes than the current Dominion power plant, which
is harming our health.
Fossil Fuel Dinosaur? Or Bright Future for Salem?
Background
Salem Harbor is one of America's most beautiful natural
harbors and one of its most historic. Only 25 miles from
downtown Boston, Salem is also a large tourist draw with
approximately 1 million tourists a year.
Salem Harbor Power Plant was built in 1952 and is one of
the oldest plants in the Commonwealth. It was built to
last 30 years. Fifty-six years later it is time for its
retirement.
Salem's plant has three coal-fired units and one oil
unit. Over the years, the plant has struggled to
maintain compliance, and minimal investment has been
made to upgrade the facility to modern standards. Salem
Harbor is one of the "Filthy Five" targeted by
Massachusetts to clean up their plants. The plant failed
to meet the 2001 clean air standards, and finally in
2004 you will recall that Governor Romney threatened to
shut it down for its violations. He did not follow
through with this threat.
The plant continues to be the largest single polluter of
criteria air pollutants in Essex County, and is the
second most polluting power plant in the
Commonwealth.[1] There are elevated cancer rates in
Essex County versus the state average.[2] The 2000
Harvard School of Public Health study estimated that
there are 53 premature deaths, 16 heart attacks, 14,400
asthma attacks and 570 emergency room visits that can be
directly attributed to the toxins emitted by the power
plant annually.[3] The plant has been a public health
risk for decades and the people living nearby have paid
a price. This is not, however, only an issue of public
health, it also raises clear issues of environmental
justice.
Air emissions and compliance record:
Dominion has a spotty compliance record. “Not
surprisingly, Dominion has not always operated lawfully.
The energy giant has been subject to a slew of lawsuits
and government violations. In its quest to perpetually
increase profits, the effect of the corporate behemoth’s
operations on the health and welfare of the public is
not always taken into consideration. For example,
Dominion skimped on costly pollution control equipment
at one of its fossil-fuel power plants – a violation of
federal clean air laws – and ultimately agreed on a
billion dollar settlement with the federal government
over the infraction.”[4]
Essex County's air quality is among the worst in the
country.[5] In addition to the power plant, there is a
waste burning plant next door in Lynn, and a sewage
treatment plant in Salem. PG&E filed with ISO-NE to
close the plant in April 2003 citing its lack of
economic viability and the large expense required to get
it up to any kind of modern standard.[6] Dominion Energy
purchased the plant reluctantly as part of a bankruptcy
package and filed with ISO-NE to retire the plant in
February 2005.[7] ISO-NE objected to closure at that
time due to concerns about the impacts on reliability of
the power grid.[8] The May 2008 ISO-NE report documented
that its reliability must run agreement with Dominion
would terminate on September 30, 2008. The report did
not indicate any intention to renew such an agreement.
This is likely due to transmission upgrades and new
capacity created since 2005.[9]
Dominion Energy is the country's largest energy company
with operating revenue of almost $16 billion in 2007,
and profit before tax of $4.5 billion.[10] PG&E
estimated upgrading the plant would cost $350 million
back in 2005. The owners of this plant have successfully
negotiated their way out of making these upgrades over
decades. They have not stepped up to the plate to
modernize the plant. Both owners have sought to shut
down the plant, and now is the time to urge Dominion to
do it. Our government can no longer tolerate further
delays, negotiating tactics, or excuses for failing to
clean up this plant.
The plant is only in technical compliance at this time
due to credits from other locations.[11] Only minimal
upgrade or improvement has been made to the Salem Plant.
This means that Salem itself is not complying with
emissions requirements and a major upgrade will be
required once the credits run out. The people of Essex
County continue to be plagued with the health and
environmental harms from this aging plant. The failure
to force them to upgrade has cost hundreds of lives and
compromised the health of all inhabitants living within
30 miles of this plant.
The plant emitted over 340,000 pounds of toxins in 2006,
including mercury, lead and arsenic.[12] In 2006, the
plant emitted 1,771.9 tons of nitrogen oxide, 8,615.9
tons of sulfur dioxide, and over 2 million tons of
carbon dioxide.[13] It is a major contributor to acid
rain, smog and global warming.
One of the biggest environmental and health problems
arises from the coal dust generated by a coal pile that
sits right on the harbor. In spite of an agreement in
2005 to cover the pile for public health, Dominion has
failed to do this. The soot covers Salem and blows
across the harbor into Marblehead and Beverly. This
visible indication of the plant’s emissions spurs
chronic complaints of coal dust on window sills,
porches, boats, cars—everywhere, and it hints at the
reach of the invisible toxins emitted from this plant.
Soot alone has been shown to cause black lung and lung
cancer, and Salem’s elevated lung cancer rate as
compared to the state average signals the very real
impacts of the plant.
The Salem Harbor plant, due to its advanced age, emits
roughly twice as much pollutant as a modern coal plant,
and up to ten times as much as a natural gas plant per
kilowatt/hour.[14]
OSHA issued a citation to Dominion in May 2008 fining
Salem Harbor Power Plant for a failure to protect its
employees. In November 2007, boiler tubes exploded,
killing three workers. The site of the explosion had not
been entered and inspected in over nine years.[15] The
families have initiated a wrongful death suit against
Dominion. During the plant’s subsequent six month
closure no interruptions to electricity for the North
Shore occurred. This closure reduced the amount of toxic
emissions for 2007, but indicates how poorly the plant
has been managed. Dominion spent $15 billion in
company-wide investments and upgrades last year, but it
has completely neglected Salem.
Electricity generation alternatives:
Major upgrades in transmission have been made for the
North Shore since 2005.[16] The reliability agreement
between ISO-NE and Salem Harbor will terminate in
September 2008.[17] We have received confirmation from
ISO-NE that the Salem Harbor plant is no longer
necessary to reliability.[18] We have evidence of smooth
operations without the plant from November 7, 2007 after
the fatal explosion until April 25, 2008. Keeping Salem
operating has distorted the natural market for energy
production and distribution on the North Shore. A
shut-down would open the market to cleaner, more modern
facilities to fill any potential future gap for Salem
and the surrounding areas. Maintaining Salem for an
additional twenty-six years has effectively prevented
others from providing electricity there. The cost of
coal has been cheap financially, but the public has paid
a high price in increased mortality, health problems and
a degraded environment.
Job Impact:
Closing the plant has been on the minds of many in Salem
for the past two decades. Originally built to last only
until 1982, it has outlasted its usefulness. It is an
embarrassment to Massachusetts that such a plant was
forced to stay open and that better alternatives have
not yet been deployed. All knew that its time would come
eventually. The recent fatal explosion reinforces the
conclusion that the time is now.
The Salem Plant provides only 147 jobs—less than 1% of
the Salem labor force of 23,352 in a population of
41,756. Salem's unemployment rate is below the state
average and 2,505 jobs are posted on Monster.com within
10 miles of Salem. To put the 147 jobs in perspective,
my bank in Boston, Brown Brothers Harriman & Co. has 241
job openings, and Fidelity Boston has 366 openings. This
does not mean that some of the workers would not need to
look for jobs elsewhere within the power industry,
consider relocation or look for retraining. But in the
overall scheme of things, Dominion is only the 14th
largest employer in Salem and the job loss impact would
be minimal.
The plant’s impact on Salem's tax base has been
declining. The plant represents less than 3% of Salem's
tax base. The city is in a difficult budget position due
to the recent school budget scandal, but the plant
provides less than half of the tax revenue than it did
ten years ago and has become much less significant to
the overall budget than in former years. The plan to
redevelop one of our most beautiful harbors would
greatly improve Salem's tax situation. Any short term
gap could be filled with the money from new construction
jobs, development grants and increased tourism due to
the Green Harbor. Salem has approximately 1 million
tourists a year today, and we predict that tourism would
more than double within 5 years with a world famous
Green Harbor development.
Salem Green Harbor – An Energy Vision for the Future:
Given that Salem Harbor is no longer necessary for
reliability, it is time to de-commission it and
redevelop the site for a beneficial use. We recommend
building a Green Harbor development that would run
exclusively on renewable energy. We propose a total
conversion away from the dirty, out-dated energy
production technology of the past to a leading edge city
powered by solar, wind, geothermal and wave energy. The
oceanside location also lends the site great potential
for commercial uses. Solar and wind power companies have
expressed interest in establishing manufacturing
facilities there. Working with MIT and the Massachusetts
Technology Collaborative, we propose forming a
public-private partnership to establish a world renowned
center for progressive energy sources. Converting the
aging dinosaur and eyesore into a world class center for
progressive energy sources would attract worldwide
attention and put Massachusetts on the map as a leader
in a carbon-free energy future. Given our technology and
university base in Massachusetts, there is no reason
that we should not be the nation's braintrust on
alternative energy discovery and R&D. The Salem Green
Harbor would also include a visitor's center and a Deval
Patrick Environmental Campus for research and education
about global warming and alternative energies. Salem
Green Harbor would make Massachusetts a global beacon in
the battle to find new technologies to preserve the
planet.
Conclusion:
Maintaining Salem Harbor for fifty-six years has been a
public health and environmental disaster. This
Administration has shown leadership in promoting
initiatives for green jobs and renewable energy, and it
has demonstrated its effectiveness in working with
private parties to prod them towards cleaner, greener
development. We urge you to convene a meeting with
Dominion to discuss the potential for the redevelopment
of this site.
Dominion Energy will announce its plans in July 2008 for
what it will do to meet emissions standards required by
the "Filthy Five" legislation in Massachusetts. Such
upgrades will need to start immediately for them to
comply with the law by 2010/2011. We want to ensure that
the plant’s legacy of delay ends. No more negotiations.
No more dilatory tactics. The government must make it
clear that the best course of action for the community
and the company is redevelopment. This plant poses too
big a threat to human health to continue operating this
way for three more years. We need your continued
leadership on global warming. We need leadership on
establishing new centers of excellence in Massachusetts
for progressive energy. This plant has been allowed to
poison the community for too long. This is the time to
shut it down.
[1] United States Environmental Protection Agency, Clean
Air Markets – Data and Maps for 2006 Emissions, Facility
Level Emissions Quick Report available at http://camddataandmaps.epa.gov/gdm/index.cfm?fuseaction=emissions.output&startMarker=1
[2] See the Massachusetts Cancer Registry available at
http://www.mass.gov/Eeohhs2/docs/dph/cancer/registry_statewide_01_05_report.pdf
[3] Jonathan Levy and John D. Spengler, Harvard School
of Public Health Estimated Public Health Impacts of
Criteria Pollutant Air Emissions from the Salem Harbor
and Brayton Point Power Plants (2000).
[4]See Public Citizen 2004, Corporate Profile of
Dominion
[6] See In re USGen New England, Inc., 111 FERC ¶ 63066
(June 14, 2005).
[7] See Letter from Stephen G. Whitley, Senior Vice
President & Chief Operating Officer, ISO-New England to
Marisa A. Sifontes, Senior Counsel, Dominion Resources
Services, Inc. (February 25, 2005).
[8] See id.
[9] ISO-NE, Reliability Agreement Status Summary (May 1,
2008).
[10] See Dominion’s website available at http://www.dom.com.
[11] See Amended Administrative Consent Order allowing
for the use of emissions credits to meet the
requirements of 310 CMR 7.29
[12] See United States Environmental Protection Agency,
Toxic Release Inventory for 2006 (February 2008)
available at http://www.epa.gov/cgi-bin/broker?view=COFA&trilib=TRIQ0&sort=_VIEW_&sort_fmt=1&state=25&county=25009&chemical=_ALL_&industry=
ALL&year=2006&tab_rpt=1&fld=RELLBY&ONDISPD=Y&OTHDISPD=Y&_service=
oiaa&_program=xp_tri.sasmacr.tristart.macro
[13] See United States Environmental Protection Agency,
Clean Air Markets – Data and Maps for 2006 Emissions,
Facility Level Emissions Quick Report for Salem Harbor
available at http://camddataandmaps.epa.gov/gdm/index.cfm
[14] Emissions of particulate matter, mercury and sulfur
dioxide is classified as “negligible” for natural gas
plants. Thus pulverized coal plants may emit up to ten
times as much sulfur dioxide as a natural gas plant. See
United States Environmental Protection Agency, Final
Report, Environmental Footprints and Costs of Coal-Based
Integrated Gasification Combined Cycle and Pulverized
Coal Technologies, ES-8 (July 2006); United States
Department of Energy/National Energy Technology Lab,
Cost and Performance Baseline for Fossil Energy Plants,
Exhibit ES-2 (Revision 1, August 2007); Cost and
Performance Baseline for Fossil Energy Plants,
Presentation, 29 (May 15, 2007).
[15] See Occupational Health and Safety Administration,
Citation and Notification of Penalty, Inspection No.
311425474 at 6 (May 5, 2008).
[16] See ISO-New England, Quarterly Status Update on
Projects and Factors that Impact the Need for Continued
Operation of the Salem Harbor Units, 2-3 (November 19,
2007).
[17] See In re USGen New England, 111 FERC ¶ 61,454 at
63004 (June 22, 2005).
