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Salem's Bright Future

COAL?

Or STROLL?

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.

www.stoptheplantnow.org

 

[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

[5] http://creativemethods.com/airquality/maps/massachusetts.htm

[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).

 

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