How to Research a Proposed Coal Plant
For citizen journalists and activists researching a proposed coal plant, Valley Watch, an Indiana citizen group working on energy issues, prepared a step-by-step guide entitled "So You Have a New Power Plant Proposed." The guide consists of a series of questions, each addressing a different aspect of power plant development.
- What is the proposed capacity of the plant? Is it needed to supply their “regulated” customers?
- Where do they intend to sell the output form the plant? What is the market for the plant?
- Have they investigated alternatives like renewables?
- What is the proposed level of efficiency?
- What kind of public process is involved in each phase or permit?
- Will co-generation be utilized?
- What is the source of fuel? Is it coal, natural gas or some other fuel source?
- What type of technology will the plant use? If it is gas, is it combined cycle or simple cycle? If it is coal, is it pulverized coal (conventional), Integrated Gasification Combined Cycle (IGCC), Circulating Fluidized Bed (CFB) or, another type?
- What kind of pollution controls do they plan to incorporate? Will it have a “Baghouse”? Does it use “Scrubbers”? Perhaps, an Electro Static Precipitator (ESP)? Low NOX Burners? Selected Catalytic Reduction (SCR)?
- What are they proposing for Best Available Control Technology (BACT)?
- What is their plan for disposing of the pollution control residue and ash? Will they build a landfill? Will they ship it off-site? Will any of it actually be recycled? If so, what exactly is their plan? How large a landfill will be required? How long do they propose to use the landfill? What kind of liner will be used? Will it be clay or synthetic?
- Where will they get their fuel? An adjacent mine? Will it have to be shipped? If so, where from and what method(s) of transport will be used?
- What kind of fuel chemical analysis have they done? What is the sulfur content? What is the Mercury content? Moisture? Ash? Chlorine? BTU?
- Will the coal be washed? On-site or before it arrives at the plant?
- Will this fuel be used alone or will it be mixed with something else? Garbage? Gob? Waste tires?
- If they are using ‘Scrubbers,” where will they get their limestone? What is the method of shipment?
- What is the “attainment” status for the Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS)?
- Has “pre-construction monitoring” been done for criteria pollutants?
- Will an Environmental Impact Statement be filed? If so, by which agency?
- Will it be permitted under the Prevention of Significant Deterioration (PSD) program for attainment areas? Or, will it be permitted under New Source Review (NSR) for non-attainment areas?
- Is your state a “delegated” state for NSR/PSD programs?
- What other major polluters exist in the area? Do you sense that other business wants the facility or are they skeptical about its impact on their pollution control plans?
- What is their cooling water source? What other industries use the that source? Will it be necessary to pipe water to the plant? If so, how far will it be piped? Will they need to use any groundwater or will it all be surface water? Will eminent domain be used for the pipeline?
- What kind of cooling towers will be used?
- What is their water demand?
- What are the plans for transporting the electricity from the power plant to its end point?
- Do transmission lines already exist for this plant? Has a study to determine that been made? If so, is it publicly available? When will it be available?
- Will new transmission lines need to be built? If so, who will build them and who will pay for their construction? Will eminent domain be used, if necessary, to secure the transmission route? If, so, what entity has the power of eminent domain?
- What capacity will the lines leaving the plant be? How much electricity will be carried on the lines? How much line loss is anticipated? What kind of technology will new lines use to assure greater efficiency?
The Company Proposing the Plant
- What is the exact name of the company proposing the plant? Is it a subsidiary of another company?
- Is it an “investor owned utility” (IOU)? Or, is it something else?
- Is the plant a “merchant” plant or will it serve a specified, regulated set of customers?
- If it is a merchant plant, do they have a contract for the sale of their output? If not, where do they intend to sell the electricity?
- Does the Company have other plants? If so, where are they and what kind are they?
- How long has the company been in business?
- Are there any legal actions or investigations of the company currently underway? By the SEC? By EPA? By FERC? By any state agencies anywhere?
- Is the parent company incorporated in your state? If not where?
- What is the financial status of the Company and its parent Company?
- Will the Company operate the plant once it is built? Or, will it have an operating partner? If they seek a partner, has one been chosen? If so, who is it?
- What is the financial condition of all principals? Have any of them ever filed for bankruptcy?
Financing and Construction
- What is the projected cost of the plant? How long will it take to build?
- Has a contractor been hired? If so, who is it? If not, who is anticipated and where are they headquartered?
- What are the projected number of jobs during and after construction? Will it be built with local labor? Local organized labor?
- How will the plant be financed? Will the Company seek financial support from any unit of government or will it be built with strictly private capital?
- If it is an Investor Owned Utility, will construction cost be allowed in the rate base prior to its operation (CWIP, or Construction Work In Progress)?
- Has the Company compared the construction cost of the plant with alternative energy sources or technologies? If so, is that available to the public? If not, why not?
These are just starting point questions. If you can find the answers to these questions, you will be well on your way to planning a strategy to deal with the proposal. Most proposals remain merely proposals. Few power plants ever actually get built, even if they break ground.
- "So You Have a New Power Plant Proposed," Valley Watch, Accessed February 2008.