Comments due Sept 15th: Support shut-down of polluting, resource-destroying incinerator in Benson, MN.

I rarely support actions by Xcel Energy, but this time Xcel is doing the right thing in five matters (for its own reasons, of course).  I’ll address these five in separate posts, as Xcel filed five separate matters before the Minnesota Public Utilities Commission.  First, this one about the incinerator in Benson, PUC Docket r-002/M-17-530 (when searching PUC’s eDockets or eFiling comments, it’s the 17-530 that’s important).

In one of the dumbest actions ever taken in Minnesota on an energy-related matter, a large “poultry litter” incinerator was built in Benson, Swift County.  This was supported by many “environmental” interests in MN, as part of a 1994 deal to keep the Prairie Island nuclear plant operating.  It was opposed mainly (only?) by David Morris — Institute for Local Self Reliance.   As one would expect, this facility has a horrendous record of pollution and environmental violations.   Its air emissions permit expired in 2008.  Xcel is proposing to buy the facility and shut it down.  This is good news.  Xcel generally gets what it wants, (regardless of whether it should).  The stated reason is to save Xcel’s customers money, and this the shutdown would likely do, as dirty biomass burner “Power Purchase Agreements” are inflated in cost.

Since the burner has not been able to get enough “litter,” about one-half of what is burned is wood chips, and many comments opposing the shut down have come from logging interests and, disgracefully, from the Minnesota Department of Natural Resources.

So far as I can tell, none of the enviro types, energy wonk types, regulators, or elected officials who supported this damaging incinerator scam have chosen to publicly admit their mistake and support the shutdown.

You can read all the filings in the docket and file your own comments in a couple of ways:

(1)  (less effective but easier) The PUC website has a “discussions” section but this has limitations including that dockets only appear here if they are officially open for public comment, and sometimes not even then.   For example, the Benson burner docket is not there, although it should be. Search for docket “17” (year) and “530 (docket number).

(2)  (more impactful) You can use the “edockets” system to read, download, or print the documents in any docket you are interested in.  You can use the “efiling” system to file your own comments in the Benson 17-530 docket — the next round of comments is due September 15.  To use efiling you need to sign up and get a password, but it’s not hard.  If you file comments after the official closing of public comment, they may or may not be considered.  For example, the Commissioner of the Department of Natural Resources recently filed out-of-time comments opposing the Benson shutdown–arguing on behalf of the DNR’s friends in the logging industry.

Here’s the notice with information on how to file comments in this Benson 17-530 docket:

Notice – 20178-134541-01

The “Public” Utilities Commission is not supposed to be just an industry playpen, though too often it seems that way!

Here are the previous comments I submitted in favor of the shutdown:

Alan Muller
Energy & Environmental Consulting
1110 West Avenue
Red Wing, MN, 55066

September 1, 2017

Daniel P. Wolf

Executive Secretary
Minnesota Public Utilities Commission
121 7th Place East, Suite 350
St. Paul, Minnesota 55101

Reply Comments: Petition of Xcel Energy to terminate a Power Purchase Agreement , etc. with Benson Power, LLC (Ex Fibrominn) E002/M-17-530

Dear Mr. Wolf:

I have been involved in controversies over poultry litter incineration projects instigated by Fibrominn and its successors for many year and in several states.

Such projects were rejected in various US states including Delaware, Maryland, Virginia, North Carolina, and Georgia. Thus, observers were puzzled that such a facility would be accepted in Minnesota. They especially were puzzled that “environmental” interests supported, or failed to oppose, the Benson proposal.

Opposition to poultry litter incineration projects has centered on high emissions, high costs, damage to public health and quality of life in host communities, and undesirable diversion of fiber and nutrients from field application to incineration. I note, for example, that so high are the Benson air emissions that a smokestack over 300 feet high was built to disperse these into the community. Only a fifty (or fifty-five) megawatt generator, “The permit granted for their Fibrominn project allows them to be Minnesota’s largest single source of arsenic pollution, their largest source of sulfuric acid air emissions, their 2nd largest source of hydrochloric acid air emissions, and a significant new source of dioxin pollution.” ¹

The history of the Benson project has been characterized, as would be expected, and as was predicted by opponents, by high emissions, serious and ongoing violations of air permit limits, deceptive practices, and complaints from Benson residents of damage to their health and quality of life. See, for example, this stipulation agreement with the Pollution Control Agency: http://www.bredl.org/pdf2/FibrominnExecutedSTIP12-16-09.pdf

The Benson project has been unable to secure adequate amounts of poultry litter and has become largely a wood burner. Poultry litter, in general, is about fifty percent wood chips and fifty percent bird emissions. Thus, the Benson facility, burning, as has been stated, about one-half poultry litter and one-half wood chips is in fact burning about 75 percent wood.

Wood is a very dirty and chemically complex fuel, and nominal wood burners typically cause the same sorts of environmental problems as the Benson “litter” burner, while producing excessively expensive energy.

Xcel, in its Petition, notes a “plant heat rate of 14,250 Btu/kWh per Benson Power’s 2016 budget.” This corresponds to a thermal efficiency of twenty-four percent. The most efficient coal units have heat rates of around 9,000 Btu/kWh, corresponding to a thermal efficiency of around 38 percent, and combined cycle gas units are over 60 percent efficient.

Thus, I support the proposals of Xcel Energy to terminate power purchase agreements with various “biomass” burning facilities and to purchase and shut down the Benson burner.

(However, one must note the hypocrisy of Xcel in continuing to operate company-owned garbage incinerators in Red Wing, Mankato and French Island (La Crosse) that are similarly dirty and expensive. If Xcel was truly concerned about the well-being of its customers and the public at large it would shut these down and get out of the dirty-burner business entirely.)

(Also parenthetically, large Confined Animal Feeding Operations, including turkey barns, produce large concentrations of nutrients which pose problems. Thus, it is understandable that promoters of “magic bullet” solutions such as incineration have an audience. However, it seems well established that best practices for management of turkey litter should be based on properly managed—not to excess!) land application.)

A review of the filings in this docket indicates—unless I have missed them—no mention at all of the environmental merits, or lack thereof, of the Benson facility. Similarly there is very little mention of the merits of the facility as a power plant. It seems that all the important issues are missed or disregarded.

Unfortunately the actual cost of the Power Purchase Agreement is concealed as proprietary, although it is difficult to imagine any justification for this.

The proposal to pay off the City of Benson out of the proceeds of the “Renewable Development Fund” are yet another abuse of this every-scandalous fund, essentially none of which has ever been used as intended to compensate Red Wing and Monticello for Xcel’s nuclear plant/waste presence.

I conclude that the most important matters in this docket are yet unaddressed, and the comment period should be extended. Especially, it is scandalous that “environmental” interests, which initially promoted the agreement leading to the Benson facility, have not chosen to comment.

I also contemplate petitioning to intervene in this docket.

Yours very truly,

[signed]

Alan Muller