When opponents simplify the issues…

Toxics and pollutants are regulated on an individual basis, but overall air quality is monitored. And not only that, the models used (CMAQ and CAMx) to assess overall quality do look at some interactions between pollutants. For a look at what is going on according to the latest models and assessments in our region, you can start reading the Columbia River Gorge Air Quality Study Science Summary Report.

One can leap onto what the models do, what kinds of algorithms they employ, etc., but it is amazing that we have this kind of data all. It is amazing to see what is happening in our region, and it is the regional level air quality that constitutes most of the information one mights find. Because the wind blows. That said, there are regulatory pieces that look at pollution in terms of its local footprint. Again on an individual pollutant basis, and without the fine tuned monitoring data that one might want because monitoring is incredibly expensive. And good monitoring even more so.

Mobile sources of pollution account for the vast majority of our air quality issues, but only some facets of this pollution can be dealt with at a state or regional level. In fact, the regulations for vehicle standards etc. are not within our regional jurisdiction at all. Not that they don’t exist, they just can’t be part of addressing regional air quality in terms of changes we can make at a local regulatory level.

What does fall in our regulatory hands is roughly 10% of the pollution sources that come from industry, homes, products etc. Which may falsely lead some to think it futile to stop so “minimal a pollution source” as this biomass plant, but really should lead to looking at the big picture of how increasing pollution levels and more complicated issues have come about. And how we are at the mercy of increased industrialization in a context that tries hard to regulate but cannot help but have many failure points in terms of health and quality of life.

Our air agency (http://www.swcleanair.org/) really does work to monitor and safeguard according to standards the health of the public. But if you go in a building, your health and air quality is monitored and safeguarded by Labor & Industries. Come out of the building and SWCA has you in its folds once again. Standards are set at the federal level (EPA) as well as methodologies for testing, although thy can be made more stringent than required at the state level. Monitoring data that is collected finds its way into score cards and easier access portals all the time. The data that is part of scorecards is most often from the toxic release inventory (TRI) and pollutant reporting done by industry to regulatory agency etc. And all of that data must be compiled, and not all of it is uniform, and not all of it is current. And everyone is cautioned about resting on that data alone. Data always comes with caveats. And we have just been talking about air quality and not even overall environmental context.

This proposed biomass plant is regulated to use BACT -Best Available Control Technology- for each pollutant. And there are standards and background you can view here on woody biomass. [PDF] And it is up to Schneider to fire the first round of data to the air agency on what they consider BACT for their plant and not the recipients of its emissions. So BACT is determined – at first – by the company itself based on the specs for the plant. The regulating agency then models and assesses this information in terms of the property on which the plant sits, ambient air quality data, the controls chosen, and the existing regulatory framework that is has jurisdiction over.  So we have learned that biomass plants DO have to employ BACT, but that BACT is determined by a lot of things going on all at once. Not the least of which is whether or not the science is there to determine whether or not health issues are adequately being addressed.

In fact, Maximum ACT, Generally ACT, and Best ACT are up for all sorts of determinations depending on their setting and industry and individual pollutants. And this leads me to a point. In some instances, our air quality may be improving. In some cases it may be getting worse. In some cases the region may be fine but the locale may be terrible. And the determination of “fine” and “terrible” may be from a standard that is really current in terms of knowledge or based on information that has not been updated in some time. Realize that people are still wrangling over this issue and others.

Regardless of the control technology that is put in place, everyone must realize that there will be emissions of pollutants. And that control technologies can make it better for local environs but worse for regional or the other way round too! Or, they can not even address certain pollutants to the degree to which real health is assured because there are already too many other pollutants to deal with or because the standards to which technologies are held are not as adequate as they could be because it is onerous for businesses or too difficult to establish.

So, after this brief, complicated, and jumpy tour of some of the information you might want to start get a handle on to put this biomass plant in context, go ahead and look at this map of the most current National Scale Assessment for Non-cancer respiratory risk.

And review our community scorecard too. (page 13 is a must as it talks a bit about lack of data)

And please think about the addition of not just one of these biomass plants but many of them.  Because we care about our environs more than others does not mean that other environs like ours won’t face the same issue. Because the wind blows. And it may blow here.

Maybe the controls can be put in place on this plant that help immediate neighborhoods. Maybe not. Maybe it is fine for a few plants, but not a whole lot more. Maybe the diesel trucks that must be coming on through are adding a burden that should be looked at even more than they are. Remember that both Washington and Oregon get “not good” report score cards for particulate matter 2.5 emissions (the kind that really impacts health) among other pollutants.  And remember that biomass is not even a non-contentious energy source for other reasons.

In our broadly based coalition’s opinion, this project is simply not worth the disruption and cost given what we already know about combined heat and electricity plants: biomass is a growing field because of monetary incentives but not because it really is better than coal and oil and natural gas, the regulatory environment has intentions to protect human health but is operating within criteria that simply cannot protect everyone or punish all offenses adequately, we already have issues in our area that are not adequately addressed in terms of new industries because of a myriad of reasons, and not everyone within a region is equally impacted. And, we don’t have all the data we might because it is too expensive to gather it together.

Indeed, biomass is not as simple as some would have us believe. Nor is it an issue that suddenly becomes neutral or beneficial in its complexity. And all we started to cover here is air quality! Imagine what biomass issues look like when you look at taxes, subsidies, forest and ecosystem health, energy policy, transportation issues, etc. And then look at who stands to gain the most. I imagine that you will see that it isn’t our county, and it certainly isn’t neighborhoods in downtown Vancouver.