Health impact analysis concerns/issues from Dr. Shea

Dear Members of the TCLP board,

I have the following issues and concerns regarding the health impact assessment that was presented last evening:

1) The health scope of the proposed biomass facility was limited to short term exposure (1 and 24 hour) of estimated concentrations of PM 2.5. It did not take into account longer term ambient concentrations (one year) which is more typical of this type of analysis. The American Heart Association has a scientific position statement outlining the health risks associated with both long and short term exposures to this pollutant. (An analogy would be what would be the short term health risks of a person smoking 5 packs of cigarettes on one day vs. smoking one pack of cigarettes for a year or more). Due to the physiologic effects of PM2.5 and it's effects on inflammation in the body, long term exposures are concerning and important to evaluate for the development of heart disease and stroke over time. 

2) There was only 2 studies quoted in the health assessment when determining an "acceptable level" of PM2.5 for short term exposure. There actually have been over 2,000 studies performed. There has been a recent scientific position statement released by the American Heart Association summarizing all of the studies and including long term exposure risks to PM2.5. 

Scientific reference:
Lay person reference:

The scientific position statement of the American Heart Association is that there is no safe acceptable lower limit for PM2.5 as there is an increased overall death rate associated with even lower limits of this pollutant in the studies. For this reason, as a health care provider I do not believe it is safe or appropriate to base our city's energy needs on a modality that produces high levels of PM2.5 when there are other viable options such as natural gas/ wind hybrid system which have markedly lower PM2.5 and NOx emissions. 

3) This issue of the effect of ambient ground level ozone due to the NOx emissions was not addressed at all! Biomass emissions are notoriously high in NOx emissions and very much higher than burning natural gas fuel. This is a very important health issue as high ozone levels (which result from NOx emissions) is the most broad reaching health concern with respect to numbers of people exposed to unhealthy levels of air pollution based upon extensive scientific research. In our state over 70% of monitored counties are over the legal limit for ozone and that limit is about to be lowered with the new lower level to be announced by the EPA next month. Our neighboring Benzie county is one of the monitored areas already over the current legal limit. For these reasons, it is important for the health of our citizens to be looking at ways for our community to lower our NOx emissions.

4)The baseline ambient air level increase of any pollutant as a result the biomass facility was not addressed in their analysis, even for PM 2.5 which was the only focus of their analysis. In other words, They looked at the baseline ambient levels from 2002 our community and the levels of PM2.5 that would be produced from the emissions from ONE biomass facility, then compared them to each other. But they did not calculate what the overall increase in the ambient air concentration would be with these additional plant(s). This is far more pertinent to the health of the community as this reflects the level of a pollutant in the actual air that we are breathing. 

5) There was no analysis of the secondary photochemical reactions that would occur with these emissions. Air pollution is a complex mixtures of particles and gases. The emissions are converted to other substances (for example ozone) when the emissions (such as NOx and VOCs) interact with other chemicals in the air. These chemical reactions are facilitated by heat and sunlight, for example. This is very important and is one of the main conceptual principles of air pollution. So looking at only one of the emissions (PM2.5) from one biomass plant and excluding all other external factors (other than the meteorologic data that will disperse the one pollutant) is not a comprehensive analysis of the health impact of a biomass facility. Please take a moment to reference the maps in this 2009 Michigan Air Quality Report provided from the DNRE and note that the VOC and NOx emissions for Grand Traverse County are relatively high at baseline. The emissions from other sources will chemically and cumulatively interact with the biomass facility emissions and I fear result in significant denigration of our air quality over time.

6) The emissions for only ONE plant was reported on, not multiple plants. If you are looking toward using biomass facilities for baseload generation, the assumption is that you will need more than one 10 MW plant and I understand your plan had been to install multiple plants. The cumulative effect of the air pollution and health effects would be obviously greater with multiple plants. Moreover, If 2 plants were installed, the emissions would be in the range of a major emissions source. (Based on the NOx emissions estimated in the health assessment presented last night.) Yet from a regulatory standpoint unless they are built on adjacent properties, even though the total emissions would total that of a major emissions source, the emissions would not be required to be reported as one plant is categorized as a minor emissions source. Therefore, there would be substantial emissions that would not be accounted for or reported when evaluating the health and air quality effects of these plants in our region. 

Other concerns/issues:

-I have heard several board members and city commissioners state when other cleaner options are presented (wind/natural gas) that there will be opposition from environmental groups regardless of the process chosen. I would rebut by stating that most of the citizens of Traverse City, including myself, seem reasonable, most are against biomass and most are not opposed cleaner methods such as natural gas, wind or solar. We should not cater to environmental extremists when designing an energy strategy. The majority of the citizens of Traverse City oppose this plant and are not extremists. 

-Individual wood stove reference: Biomass facilities have pollution control devices and the older woodstoves do not. So per BTU of energy, older woodstoves produce more emissions. But it needs to be taken into account how much total wood/BTU energy is burned in individual wood stoves in this region vs. how much will be burned in order to produce 10-40 MW of energy for our entire city!

-"Other sources exist" reference: Adding a biomass facility will only add to other sources of PM and NOx that already exists. Choosing the cleanest option for energy production is important in considering the other sources and the baseline ambient air quality. So the rationale that there are other sources of PM and NOx emissions other than biomass in our region so biomass facilities are acceptable is not logical to me. 

Thank you in advance for considering these points when addressing the energy needs for our region for the future at your board meeting tonight. 

Please call if you have other issues or questions you would like to discuss with me. I would be more than happy to attend a board meeting and present health care information regarding air pollution if you would like further information. 

Laura Shea, MD