Many of you have asked about the key problems with LBWL's air permit application to install a RICE power plant. We have reviewed the application that LBWL submitted to EGLE, talked to several outside experts, and read EGLE's response. Below are the major points that you should feel free to use when you submit your comments to EGLE. Comments must be sent to EGLE by Tuesday May 14. You can use this page to submit your comment. Additional resources from EGLE can be found here, here, and here.

 

A virtual public hearing has been scheduled for May 1 at 6:00pm via Zoom. You are not required to speak at the hearing, but you must register.

 

If you choose to comment, we would appreciate it if you could let us know and if possible, email it to us. It would be great to see what people are saying.

 

1)  The RICE plant will emit significant pollution, and it is unclear whether these pollutants will stay within legal limits without active and continuous public monitoring.

• LBWL has, itself, described the expected emissions for PM2.5 and NO2 as up to 99% of permissible limits, so that exceeding those emission levels is likely. PM2.5 are tiny particles that can worsen asthma symptoms and have been linked to premature death in people with heart or lung disease. NO2, or nitrogen dioxide, can react with sunlight to form ground-level ozone or smog that can damage lungs.

• Eaton County doesn’t currently have any air pollution monitoring equipment and Ingham County’s equipment is substantially to the northeast. Air pollution monitoring equipment should be required for the proposed Eaton County site to detect emissions in excess of permit limits, if the permit is approved.

• How LBWL runs the facility will substantially influence its air pollution impacts such that periodic site testing will not assure continuous permit compliance.              

• EGLE has stated in a fact sheet that based on modeling the RICE plant will include emission controls and that the plant “will comply with all applicable state and federal air quality requirements.” But only monitoring equipment will ensure this compliance and provide real data on actual emissions.

• EPA found in 2023 that the LBWL had violated multiple federal environmental rules in 29 cases at its Erickson site regarding protection of water and air from toxic coal ash. Though LBWL disputes most of the alleged violations, EPA’s findings raise concerns about whether the LBWL will comply with an air permit for its RICE plant. Among other violations, EPA found that LBWL was supposed to install a groundwater monitoring system in 2017 but did not do so until 2020.

 

2) The RICE plant poses an environmental justice threat.

• On page 61 of the LBWL application, they indicate that they evaluated environmental justice concerns within a 1-mile radius of the proposed RICE plant. However, EPA recommends that companies screen within a 3-mile radius. (https://www.epa.gov/power-sector/frequent-questions-about-power-plants-and-neighboring-communities#question7). LBWL should be required to screen out to the recommended 3-mile radius.

• As suggested by EPA guidelines, air monitoring should be required given that the RICE plant will be less than 3 miles from a disadvantaged community, as reported by LBWL to the MPSC. Only real data will indicate any adverse impact on that community.

 

3)  The RICE plant will prevent LBWL from meeting renewable energy goals.

• Adding a RICE plant is contrary to LBWL meeting its 50% renewable energy goal by 2030 and to meeting state renewable energy standards. https://www.michigan.gov/whitmer/news/press-releases/2023/11/28/governor-whitmer-signs-historic-clean-energy-climate-action-package

• According to LBWL’s website https://www.lbwl.com/about-bwl/facilities, only 13% of LBWL’s energy output currently comes from renewable sources.

• Plans to install nearly 500 MW from new solar and wind facilities won’t bring LBWL’s energy mix to even 40% renewable. LBWL needs to install more renewable energy sources to meet the 50% renewable energy standard by 2030. A new RICE plant would put the LBWL further behind.

• Granting LBWL a permit enables it to build something that will contribute 541,000 tons of CO2eq every year.  A typical passenger vehicle in the US emits 4.6 tons of CO2 every year, which means that BWL’s CO2eq emissions would be the equivalent of putting 117,000 new cars on the road around Lansing every year for the life of the plant.

• LBWL has excluded carbon capture and storage as an option for eliminating a RICE plant’s greenhouse gas emissions, because it would cost more to install and run than the RICE plant itself.

 

4)  LBWL should not sell dirty electricity out of state.

• The LBWL’s General Manager announced in 2023 that the LBWL was signing a 20 year contract with an Ohio company for 50 MW of electricity. To illustrate how much 50 MW is, a standard assembly plant draws about 25 MW.  It is unclear if any of the electricity produced by the RICE plant would be sold to this company. If it is, it would not be counted in determining what percentage of the LBWL’s electricity qualifies as clean, allowing the BWL to artificially boost its percentage of clean energy. If LBWL is planning on meeting the 50% renewable energy standard by selling its electricity from its fossil fuel plants to customers outside of Michigan  to avoid counting it for purposes of the renewable energy standard, LBWL is burdening its customers with the cost of the plant, higher rates from operating the plant,  as well as additional air pollution.

 

5) Alternatives are available and more affordable.

• The RICE plant does not represent the best available current technology for electricity generation with respect to CO2e emissions, air pollutants, and affordability, even though the emissions control technologies proposed for the RICE might be considered best available.

•  A solar and/or wind plus batteries electricity generation system is more affordable, and there are no CO2eq and other air pollutant emissions from these sources, obviating the need for air permits. 

• Other load management techniques, such as virtual power plant systems, should also be considered by LBWL to manage electricity loads.

• Lazard (a key analyst of energy information) estimates that utility scale solar plus battery storage costs half of what a natural gas peaker plant would, even unsubsidized. Solar plus batteries beats a RICE plant on financial terms across every analysis (considering different costs of capital, variable fuel prices, different carbon taxes, different subsidy rates).  https://www.lazard.com/research-insights/2023-levelized-cost-of-energyplus/