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September 2008 – BEAT and several other organization jointly filed a Motion to Participate in the appeal of the issuance of a Water Management Act Permit

The state appears to be pushing through a badly concieved project with negative environmental impacts all in a misguided attempt to improve the state’s energy policy.

February 29, 2008 – BEAT’s comments on the Draft Water Management Act Permit (pdf)

March 21, 2008 BEAT’s comments on the Final Environemntal Impact Report (pdf)

DEP issues Draft Water Management Act Permit – in apparent violation of MEPA regulations– 2/4/2008On February 4, 2008, the Massachusetts Department of Environmental Protection (DEP) issued a Draft Water Management Act Permit (pdf) for the Russell BioMass Project. BEAT is unclear on how this draft permit can be issued prior to the final Secretary’s Certificate from the completed MEPA process. From the about MEPA webpage:
“M
EPA review occurs before permitting agencies act, to ensure that they know the environmental consequences of their actions.” Agencies are defined as state agencies and includes the DEP.Here are some of BEAT’s comments on this Draft permit:Alternatives analysis:The Massachusetts Department of Environmental Protection (DEP) acknowledges that using air-cooled technology is technically feasible. In an age where weather is becoming less and less predictable, droughts are occurring across the country, and in some locations severe droughts are causing a widespread wish that there had been better control of water withdrawals before those areas reached that point; it seems foolish not to require air-cooled technology. There is no good reason to allow a new power plant to contribute unnecessarily to both increased water withdrawal from the ecosystem, and sending large amounts of water vapor into the atmosphere.Water withdrawal:BEAT would need to look at the Wastewater Discharge Permit to better understand the effect of the currently proposed withdrawal. What will the temperature of the discharge be? How much water will be discharged? And again, why should any water be allowed to be discharged back into the river, when technology exists to run this plant using air cooling instead.BEAT is appalled that the draft permit appears to use the lowest flow that was ever recorded for this river as the target for minimum flow. This is not an environmentally sound methodology! If this methodology was used for the Ipswich River, the minimum flow would be zero. BEAT would suggest that a more appropriate minimum would be the aquatic base flow figure.Aquatic Base Flow based on an 0.5 cfsm factor is a quick and dirty way to estimate a minimal flow for a stream; however, it in no way guarantees that on any given river the flow is adequate for the flora and fauna of that stream.If this permit were to be issued, all downstream NPDES permits should be reinvestigated because their dilution factors, based on the 7Q10, would need to be recalculated and adjusted accordingly.
Russell Biomass Informational Hearing An informational hearing was held January 18, 2006 at 7 pm at the Russell Elementary School to discus a proposed bylaw change that would ban all biomass electricity-generating plants from the town. This proposal is in response to Russell Biomass LLC’s bid to build a biomass plant on the banks of the Westfield River at the former Westfield River Paper Company. Neither of the two organized groups, Concerned Citizens of Russell or Citizens for Renewable Energy is responsible for the petition drive to put the bylaw on the warrant for the Annual Town Meeting in May.

Background and regulatory history on the Russell Biomass Project

Although this project is outside of Berkshire County, BEAT is keeping an eye on what happens.

The proponent, Russell Biomass, LLC, proposes to build a 50 megawatt power plant, fueled by over 500,000 tons of wood product, to produce heat to drive a turbine to generate 380,000,000 kWh of electricity annually. The plant would withdraw 100,000 or more gallons per day of water from the Wild and Scenic Westfield River. The Westfield is a tributary of the Connecticut River has had returning Atlantic Salmon build nests (redds) in its tributaries.

This proponent submitted an Environmental Notification Form for Massachusetts Environmental Policy Act (MEPA) review in September 2005. EOEA#13635 The proponent submitted an Expanded ENF with a request that a single Environmental Impact Report be required rather than the usual Draft and Final EIR.

The Secretary issued a Certificate, the response to a MEPA review, on October 31, 2005 requiring both a Draft and Final Environmental Impact Report.

On November 3, 2005 the Secretary issued a follow up Certificate in response to an email inquiry from the proponent, specifying that if Russell Biomass planned to deviate from the fuel source, or in any other way deviate from the plan they had presented in the ENF, they would have to file a Notice of Project Change and possibly undergo further environmental review.

The Massachusetts Division of Fisheries and Wildlife is calling for more study of the Russell Biomass project because of concerns about possible impacts that the $150-million wood-burning power plant would have on fisheries and protected species.

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