Some concerns evident with the Laidlaw application of note:
1.Appendix P deals with fuel availability. In it, Landvest (Laidlaw's wood study
company) states conclusively that there is already 6,000,000 annual tons of
biomass being used by existing paper mills and energy plants, and that there is
710,000 additional supply within the 100 mile radius. The Laidlaw project will
require approximately 750,000 tons of fuel annually therefore the study would
imply not quite enough fuel. More telling is the aspect that this is all the
fuel available with the existing mix of users. Therefore if Laidlaw goes forward
there will be no fuel for any expanded paper mill consumption, for any of the
other proposed new biomass energy facilities, for any use by municipalities for
schools or district heating, or any potential left for wood pellet production
with the 100 mile radius. Bravakis suggests that harvesting ratio related to
annual re-growth be increased from 50% to 70% to make more biomass available.
This is exactly the opposite of what the growing concern related to forest
sustainability will require. The Landvest study confirms and Laidlaw depends
upon a New Hampshire state approval that Laidlaw alone will be anointed to
utilize 100% of the biomass potential within the 100 mile radius and that all
other uses of merit need not apply. Bravakis' testimony assumes 70% of
utilization which is more than the industry standard and the entire application
assumes that this higher number is the magical way for Laidlaw to exist and
utilize all available biomass grade wood at the expense of all other potential
uses. Good luck with this approach.
2.Appendix M deals with environmental concerns. There seems to be almost a
complete disregard that this is a brownfield site. In the application it seems
studies of contamination are completely ignored, that the company simply plans
to dig and store materials dug up on site, with no plans for a study to
determine what impact disturbing the ground may have on mercury contamination or
the like that may be currently pooled but upon disturbing the ground could leach
into newly formed cracks creating huge issues downstream on the Androscoggin
river.
3.Pertinent to carbon neutrality with significantly more harvesting and long
distance deliveries planned by Laidlaw, missing from the application are any
analysis of carbon footprint or analysis of just how sensitive this approach
will be should there be a sharp increase in diesel fuel cost.
4.Ownership: Northstar Ownership is 25%. The application does not state who
the individuals or entities are who make up Northstar. I wonder about conflicts
of interest that may come out later.
5.If Laidlaw is assuming it will utilize all the remaining supply of wood, they
must figure they will be able to pay more for biomass fuel than any of their
competition. Laidlaw apparently assumes an open ended pass thru on fuel cost to
PSNH. Will the NH PUC consider such fuel pass through advantage for Laidlaw to
be in the best interest of the rate payer? Most recently a PSNH lawyer stated
that Laidlaw has no deal with PSNH. But even if a deal develops it is unlikely
that the NH PUC would approve such an arrangement that would be bad for the
consumer and a monopoly utility backed competitive edge for one merchant energy
producer over all others.
Monday, December 21, 2009
Bullet Holes in Laidlaw's application?
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- Jonathan Edwards
- Business owner, father of four children. Concerned for a northern nh city, Berlin, that has a chance to redefine itself as an important green energy producer for New England. This area has a choice between two biomass companies but only enough resource to fuel one proposal. I am in favor of biomass as a means to move NH towards its 2025 initiative of 25% alternative energy production, but not at the expense of sustainability or quality of life. I believe massive biomass plants need to have a nation wide analysis as they can effectively eliminate higher efficiency use of our forest.
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