MMC Talking Points Fact Sheet
· The new power plant, like the one it is replacing, remains in a very poor location. Roughly 1300 ft. from an elementary school and only 350 ft. from the nearest residential neighborhood.
· Chula Vista General plan policy E 6.4 expressly directs the city to “avoid siting new or re-powered energy facilities and other major toxic emitters within 1,000 ft. of a sensitive receptor
· The creation of a new facility on a previously empty portion of a lot with a 122% increase in capacity is basically a new power plant that is using a “limited amount” of recycled equipment.
· Another general plan policy violated by the siting of this proposed plant is E 6.15 “site industries in a way that minimizes the potential impacts of poor air quality on homes, schools, hospitals, and other land uses where people congregate.”
Inappropriate Land Use
· The site and adjacent parcels are both considered “limited industrial.” Power plants are not included on the list of permitted or conditional uses for this designation.
· According to the AFC, the potential of PM emissions is higher and the source is closer to sensitive uses. Again, it is the location of the project that is a significant obstacle.
· There is insufficient information about the cumulative impacts to the surrounding community. The proposed new power plant, with the increase in the hours that it will run, will likely add more pollutants to the area.
· MMC has not given the public a good idea of how many hours we are likely to see from the new power plant. The proposed plant will have a technical capacity of 4500 hours.
· The AFC compared the emissions of the old plant with emissions of the proposed plant but for only 500 hours of operation. This is not an accurate comparison, since the old plant never ran 500 hours in a year and the new plant will run more than 500 hours a year.
· In a comparison of emissions at both 500 and 4500, the proposed plant releases more emissions for each contaminant listed except for CO under the 500 hour analysis and for all contaminants under the 4500 hour analysis.
· The MMC peaker expansion does nothing to create a more sustainable energy future and curb greenhouse gas emissions in that is does not include any commitments to implement renewable energy or finance energy efficiency to offset future need of this gas-fired plant.
· EHC’s position is that all new gas-fired projects must, as part of their proposal, incorporate other energy sources in compliance with the Preferred Loading order.
· It is incumbent on new power projects to reflect what the region needs with respect to energy generation in the region- clean, sustainable, and renewable. The proposed MMC plant contains none of these.
· In a region suffering from drought conditions and the need to tightly conserve our water resources, it not reasonable for MMC to propose a power plant that could use up to 28 million gallons per year of water.
Use of Ammonia
· Any air quality information must also include the likely emissions from the ammonia trucks that will be coming down a highly congested Main St. to fill up the 12,000 gallon ammonia tank once every two or three weeks, according to the AFC.
· Based on the worst-case scenario done for the Larkspur peaker plant in Otay Mesa (the release of the entire contents of a 10,000 gallon above-ground storage tank of aqueous ammonia), the radius of an area that would be exposed to ammonia beyond what is considered extremely toxic under federal law is over 1,000 feet.
· Based on the more probable accident of a hose leaking while re-filling the tank, according to models run for Larkspur, the hazard zone would still be over 1,000 ft.
Possibility of Expansion
· The old portion of the plant will be removed, leaving the southern portion of the lot with what MMC described as, “a shed for storage. Easily this structure could be removed (or not built in the first place), leaving room for another possible expansion.
· The Alternatives section of the AFC is incomplete and must include a more detailed analysis of why some of the alternatives were ruled out.
o First, in regard to the alternative locations, none of the assessments of the alternative locations discussed proximity to communities and schools.
o Closed sections of the landfill and site in the eastern areas should have been, but were not, analyzed.
o There should be an analysis of alternative methods of cooling, which was not presented in the AFC.