12-May-2010

Dear City Commissioners and City Manager,

I have had email correspondence with Jim Carruthers sharing my concerns over the health impact of reduced air quality with biomass burning/incineration. His response was to request from me more information regarding the health impact of the specific proposed gasification plant. In order to interpret current scientific research of adverse health effects for you, it would help if I knew specific emissions data. I am told that specific emissions data will not be available until after the plant is built. Therefore, I have done research find these answers. Below is a summation of the emissions of a staged incineration process (gasification plant) for Wood biomass burning:

  • NOX
  • PM
  • CO2
  • SOX,
  • NH3,
  • CH4,
  • NMVOC, primary energy, residues, and others

Of concern is that wood burning biomass incineration plants emit higher amounts of fine particle matter (PM2.5) and ozone producing pollutants than coal burning plants which emit heavier particles. These fine particles have very concerning adverse human health impact. I will be happy to supply you with the specific scientific research findings if you do not have this information. Here are a few salient points:

  • Recent research demonstrates that of all the pollutants, PM2.5 and sulfates have the highest likelihood of causing disease (cardiopulmonary disease such as COPD, lung cancer, asthma, heart attack, arrythmia, heart failure and sudden cardiac death)
  • PM 2.5 pollutants are implicated in 30,000 deaths per year.
  • For every 1 mcg/cubic meter reduction in PM2.5, the overall mortality rate would decline 3%!
  • There does not appear to be a safe lower limit of this by product according to medical research and position statements by medical societies based upon research. PM2.5 is correlated with increases in the following mortality rates: all cause, lung cancer and cardiovascular systems.
  • Ultrafine particles (smaller than PM2.5 and emitted in smoke) are currently being studied and emerging concerns about the significant adverse health effects as these particles go deeper into the lungs and get absorbed into the body. Because of this they have a higher surface are to mass ration resulting in higher biological activity and toxicity. This particle is not yet being regulated as the science is just emerging.

That known, I have these questions for you:

  1. Are the city commissioners and city manager aware of the current medical research regarding the adverse health effects of NOx/VOCs and their subsequent conversion to ozone as well as SOx and PM emissions?
  2. I am assuming you have reviewed the industry supplied materials for this emissions of this incinerator prior to voting to move forward on the plant. If so, do you feel confident that it will accurately represent the actual emissions that will be produced? (There are reports of historic disparity between industry-stated and actual emissions for such plants. ) Has the estimated emission data for the proposed plant been released to the public? If not, why not?
  3. Are you aware that air quality monitoring for the pollutants such as particulate matter, etc. will not even be performed in this region as we are a non-urban area with a population of 100,000? This is of obvious concern to me as a physician with bringing an energy solution such as a biomass incinerator to our area which has emissions which will adversely affect our air quality and have documented, significant adverse health effects.
  4. Has the likelihood of mechanical failure of the plant and the safety implications to our community been considered. (Gasification plants in Europe have been fraught with mechanical failure and in Germany, for example, a core leak in a gasification plant resulted in toxic gas emission/ cooling and permanent plant closure).
  5. Are you aware that biomass ash is not "non-toxic" as was reported by Ed Rice in his biomass statement and published in the Northern Express the week of April 5th? I am concerned over this misrepresentation of the facts and public perception that this plant will not adversely affect their health.
  6. Why have clean options (hydro/solar/wind) not been maximized prior to moving forward with a biomass incineration plan? (While biomass is renewable, it is certainly not clean.) For example, if the Stony Corners site near McBain states their wind climate is sufficient to support 20-30% of our energy needs with wind, why are we only installing turbines generating only 7% of our needs. (FYI: Are you aware that in 2009 the State of Wisconsin has 440 MW of wind power generating capacity while Michigan only has 120? ) Why is the existing hydroelectric infrastructure not being considered in our region's energy plan? Has a pump storage facility similar to the one in Ludington been considered? Have the newer lower cost mass produced solar options been entertained? Have conservation programs been rolled out and maximized?
  7. Are you aware of the EPA recommendation and warnings about air pollution based on recent, extensive medical research? Because of this the EPA is recommending that communities become PROACTIVE in regards to preventing air pollution. Installing a biomass incineration plant in proximity to downtown Traverse City while not maximizing truly clean options is not what I would call being proactive.
  8. Energy re-design for a community such as ours in this era booming clean energy technologic advancement is complex. I am concerned the best solution(s) may fall outside the expertise of Ed Rice and our current TCLP board. I propose the city consider establishing a volunteer multidisciplinary community "board" to assist in addressing the issues surrounding energy generation/ efficiency/ conservation. Perhaps something similar to the Ann Arbor Energy Commission which has saved the city a large sum of money. (http://www.a2gov.org/government/publicservices/systems_planning/energy/energycommission/Pages/AboutTheEnergyCommission.aspx) A special city appointed "energy manager" position could oversee this board. Functions could include: community education and enhancement of the rates of energy conservation and recycling, fundraising to help fund truly clean energy options, assessing the health impact of energy generation and educating the public of such, and comprehensively evaluating the most recent clean energy technology and assessing for the feasibility of bringing more of this to our region.

Our community is filled with concerned, intelligent, health conscious citizens. We hope as our community leaders you will listen to our concerns, be proactive, and implement intelligent ideas with regard to energy re-design and clean energy solutions.

Thank you in advance for your thorough consideration of the potential adverse health impacts of a biomass incinerator in our city.

I would like to schedule a meeting with any or all of you to discuss these issues.

Laura Shea, MD