Technical Deficiencies, New Source Review and the Role of the PSU Trustees
Last Friday, I emailed a copy of the June 19 post about the “Long Power Emergency” to the PSU Board of Trustees, via “email@example.com.” I followed up over the weekend with a note and a link to a recent article in The Guardian:
“Following up on my email from last week (copied below), please see the attached Guardian.uk article by Nafeez Ahmed compiling data and analysis about inflated shale gas production projections, and the likelihood that the shale gas bubble will burst within the next few years.
If Penn State commits to a natural gas based energy system – via your decision in a few weeks at the July trustees meeting (when the Office of Physical Plant staff will present information about alternative routes for the Columbia Gas pipeline to serve the West Campus Steam Plant), costs will increase significantly within a short time, and supply access and reliability will decrease significantly over the same timeframe, jeopardizing the long-term financial stability of the university.
In light of the evidence, it’s my belief that the university’s long-term interests are best served by strong board leadership toward conservation and renewables now, rather than later. The millions of dollars currently slated for investment in natural gas infrastructure (along with the millions planned for the HUB renovation and other cosmetic projects) would be far better spent on comprehensive conservation measures and targeted renewable installations.”
Yesterday, I got a reply email from Tom Poole, Vice President for Administration:
“As Vice President for Administration I help President Erickson and the Board of Trustees respond to emails and important issues. Thank you for your email and for taking the time to share the article from The Guardian. We respect your comments and views on this matter. I’ll be sure the Board leadership sees your note. Thanks again for writing.” (6.24.13 Poole Email)
This is very intriguing. Does it mean that Penn State administrators screen all public emails and only forward a selection to the governing trustees, effectively insulating the Board of Trustees from direct public contact?
Or does it mean that Penn State administrators are simply included in the list of trustee recipients accessible through “firstname.lastname@example.org,” giving them the opportunity to highlight certain emails in case trustees overlook them?
I emailed this morning to ask that question – “Curious – does your office screen all email messages sent to email@example.com before sending selected messages on to some or all of the trustees, or are all messages sent to firstname.lastname@example.org automatically forwarded to the individual addresses of all the trustees?” Awaiting Poole’s response…
It matters because the Board of Trustees is ultimately the decision-making body that sets energy policy for the entire university: they direct the administrators and the Office of Physical Plant staff on what the goals are, and the adminstrators and staff work to carry out those directions. Without accurate information – or worse, with deliberately misleading information – the Board of Trustees cannot make sound decisions.
Faced with MACT compliance deadlines, if the Board direction given to OPP was “find the quickest, cheapest way to expand campus energy production capacity while avoiding New Source Review triggers,” then the OPP staff has made a tremendously good try under difficult conditions.
But if the direction given to OPP was “find the quickest, cheapest way to reduce campus energy use and bring it in line with decreasing energy production capacity caused by the aging of campus fossil fuel infrastructure and the rising cost of fossil fuels, while implementing a plan to replace the declining capacity year to year with new renewable sytems,” then the OPP staff actions over the last few years don’t even come close to compliance.
The conservation/renewables directive is the one that matters, because it’s the one aligned with economic and geological realities.
So far, Muhammad Zaman at the DEP seems to be keeping up with them, sending several letters outlining “technical deficiencies” and calling them out on their misrepresentations.
One factor is the large number of diesel-powered emergency generators added around campus over the last few years, and how those emissions figure in overall calculations before, during and after the retubing at the East Campus Steam Plant and the conversion/demolition/installation process at the WCSP. Another recurrent theme in the paper trail is BAT – best available technology – and DEP assertions that the university is not incorporating BAT into their plans.
And timing appears to be crucial – PSU needed the DEP to approve the WCSP conversion plan in April 2013 so that they could place orders for the two new WCSP boilers with a 52-week lead time; the whole construction schedule seems to be designed around timing things to go online and offline at synchronized moments to stay under whatever thresholds bring NSR into applicability, right up until MACT compliance in December 2015.
The documents are technically complex, and community-based engineers are planning to take a look and see if they can unravel some of the technical issues in more detail.
But I think the technical details will only reinforce empirical support for the key community goals of keeping people safe, keeping the University on sound financial footing and dramatically cutting regional greenhouse gas emissions:
The safest, most reliable, cheapest and cleanest energy supply is energy that isn’t used at all: conservation, followed by carefully targeted renewables.