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	<title>GPACE &#187; Great Plains Alliance for Clean Energy</title>
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	<description>Together we can demand a clean energy future!</description>
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		<title>GPACE Executive Moving to Sierra Club Position</title>
		<link>http://www.gpace.org/news/gpace-executive-moving-to-sierra-club-position/</link>
		<comments>http://www.gpace.org/news/gpace-executive-moving-to-sierra-club-position/#comments</comments>
		<pubDate>Fri, 18 Nov 2011 13:33:30 +0000</pubDate>
		<dc:creator>GPACE</dc:creator>
				<category><![CDATA[News]]></category>
		<category><![CDATA[Beyond Coal Campaign]]></category>
		<category><![CDATA[clean air]]></category>
		<category><![CDATA[coal-fired power plant]]></category>
		<category><![CDATA[GPACE]]></category>
		<category><![CDATA[Great Plains Alliance for Clean Energy]]></category>
		<category><![CDATA[green economy]]></category>
		<category><![CDATA[Holcomb]]></category>
		<category><![CDATA[jobs]]></category>
		<category><![CDATA[Kansas]]></category>
		<category><![CDATA[Kansas Department of Health and Environment]]></category>
		<category><![CDATA[Missouri]]></category>
		<category><![CDATA[Nebraska]]></category>
		<category><![CDATA[pollution]]></category>
		<category><![CDATA[renewable energy]]></category>
		<category><![CDATA[Scott Allegrucci]]></category>
		<category><![CDATA[sierra club]]></category>

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		<description><![CDATA[Allegrucci begins his work with the Beyond Coal Campaign November 28th.  His work as a Senior Campaign Representative will cover the states of Kansas, Nebraska, and Missouri. <a href="http://www.gpace.org/news/gpace-executive-moving-to-sierra-club-position/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p>In December, the executive director of the Great Plains Alliance for Clean Energy will join the Sierra Club’s Beyond Coal Campaign in a regional position that will enhance efforts toward clean energy generation, environmental protection, and related job creation in Kansas and two neighboring states.</p>
<p>Scott Allegrucci, a founding board member and executive director of the Great Plains Alliance for Clean Energy (GPACE), will become the Beyond Coal Senior Campaign Representative covering Missouri, Nebraska as well as Kansas, bringing regional coordination and focus to the push for clean energy choices.</p>
<p>“While Scott’s role in Kansas will necessarily change, we’re very excited that his new assignment with Sierra Club can bring regional leverage to our state efforts,” said Kim Hanson, GPACE Board Chair. “Regional advocacy makes sense since coal plant pollution and electrical power distribution don’t stop at state lines. Kansas will benefit from Scott’s move because our state is very rich in cleaner and renewable energy sources.”</p>
<p>The Beyond Coal Campaign is the Sierra Club’s national effort to clean the air, end the coal era, and accelerate the transition to cleaner, cost-effective energy sources. Started as a three-person campaign in 2002, the Beyond Coal campaign has quickly grown into a powerhouse effort that is changing the way America produces energy.</p>
<p>“The GPACE mission to support a clean, secure, prosperous energy economy benefiting Kansas and all future Kansans can be advanced by a collaborative regional effort,” Allegrucci said. “With regional strategy and organization, we’ll be better able to advocate for Kansas actions that can enable clean energy, create new jobs and jump-start the American economy.”</p>
<p>Allegrucci said the achievements of GPACE prove that Kansans are ready to capitalize on the state’s native energy resources to create more higher-paying jobs; a resilient economy; and a healthy environment for our children and grandchildren.</p>
<p>“The stage is set because Kansas has a surplus of cleaner and renewable electricity fuel sources,” Allegrucci said. “The region will benefit if the kind of progress and cooperation GPACE and Sierra Club have realized in Kansas can be coordinated with similar efforts in Missouri and Nebraska.”</p>
<p>Allegrucci led GPACE in the successful 2008 and 2009 Kansas legislative fights that stopped Tri-State Generation &amp; Transmission Association’s proposal to add two, huge coal-burning plants at Sunflower Electric’s Holcomb Station.</p>
<p>He also led GPACE’s efforts against the Tri-State and Sunflower 2010 proposal to add one plant at Holcomb. A permit was granted, but the matter was tainted by reports of political pressure and collusion between Kansas regulators and Sunflower Electric representatives. Sierra Club and Earthjustice have mounted legal challenges to the proposed expansion and to the permit granted by the Kansas Department of Health and Environment.</p>
<p>“Coal-burning power plants are the single largest source of global warming, mercury pollution and asthma attacks in children and adults,” Allegrucci said. “It’s a public health and economic issue that must be addressed on a regional and national basis as well as within individual states.”</p>
<p>Hanson said Allegrucci’s move is logical because GPACE and the Sierra Club have fought side by side on a number of activities in Kansas during this period.</p>
<p>“Sierra Club’s growing national capacity and Scott’s experience building effective partnerships on the ground mean GPACE’s mission and objectives will continue to be well served,” Hanson said.</p>
<p>Among the major supporters of the Beyond Coal campaign is Michael R. Bloomberg, Mayor of New York City, and Bloomberg Philanthropies, which has committed $50 million to the campaign.</p>
<p>“I can’t imagine a more effective way for Sierra Club to use some of the Bloomberg money in Kansas than to engage Scott Allegrucci on a regional basis,” said GPACE Board Member Dan Nagengast.</p>
<p>Under the guidance of its Board of Directors, GPACE remains engaged with national, regional, and state partners regarding efforts to fund and coordinate clean energy and clean air advocacy not only in Kansas, but also in the Great Plains region, particularly the Southwest Power Pool and EPA Region 7.  Strategic planning is under way, Allegrucci said.</p>
<p>Hanson added: “We expect to know in early 2012 the full impact that regional efforts, led by Scott, will have in Kansas. At that point we’ll determine what level of resources and staffing GPACE requires in order to continue to be effective in our state.”</p>
<p>Allegrucci begins his work with the Beyond Coal Campaign November 28<sup>th</sup>.  His work as a Senior Campaign Representative will cover the states of Kansas, Nebraska, and Missouri.</p>
<p>&nbsp;</p>
<p>&nbsp;</p>
<p>&nbsp;
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		<title>Congress Pulls Plug on Bill That Would Have Repealed Light Bulb Standards</title>
		<link>http://www.gpace.org/news/congress-pulls-plug-on-bill-that-would-have-repealed-light-bulb-standards/</link>
		<comments>http://www.gpace.org/news/congress-pulls-plug-on-bill-that-would-have-repealed-light-bulb-standards/#comments</comments>
		<pubDate>Wed, 13 Jul 2011 20:18:09 +0000</pubDate>
		<dc:creator>Kelly</dc:creator>
				<category><![CDATA[News]]></category>
		<category><![CDATA[bulb efficiency]]></category>
		<category><![CDATA[Great Plains Alliance for Clean Energy]]></category>
		<category><![CDATA[Kevin Yoder]]></category>
		<category><![CDATA[light bulb act]]></category>
		<category><![CDATA[light bulb efficiency]]></category>
		<category><![CDATA[Scott Allegrucci]]></category>
		<category><![CDATA[Take Charge Challenge]]></category>

		<guid isPermaLink="false">http://www.gpace.org/?p=3220</guid>
		<description><![CDATA[On Tuesday, House Republicans failed to get a bill passed that would have stopped the implementation of new energy-saving standards for light bulbs. The vote, 233-193, fell short of the two-thirds majority needed for passage. <a href="http://www.gpace.org/news/congress-pulls-plug-on-bill-that-would-have-repealed-light-bulb-standards/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p><em>By Christine Metz for <a href="http://sunflowerhorizons.com/groups/for-the-future/2011/jul/12/congress-unplugs-bill-that-would-have-re/">SunflowerHorizons.com</a></em></p>
<p>How many members of Congress does it take to change a light bulb bill? Not enough, apparently.</p>
<p>On Tuesday, House Republicans failed to get a bill passed that would  have stopped the implementation of new energy-saving standards for light  bulbs. The vote, 233-193, fell short of the two-thirds majority needed  for passage.</p>
<p>Earlier this week, House Republicans argued the bill pointed to an  overreaching government. Among the more than 60 cosponsors of the bill  was U.S. Rep. Kevin Yoder, R-Kan., whose district includes part of  Lawrence.</p>
<p>&#8220;The original light bulb mandate is a perfect example of government  regulation run amuck,&#8221; Yoder noted in a written statement. &#8220;It is not  the role of the federal government to tell consumers what products they  can and cannot buy.&#8221;</p>
<p>Signed into law in 2007 by President George W. Bush, the existing  legislation requires the classic incandescent light bulbs to be phased  out over the next few years and replaced with more energy efficient  ones.</p>
<p>The law doesn&#8217;t exactly ban incandescent bulbs, which haven&#8217;t changed  much since Thomas Edison invented them. But it would require them to be  25 to 30 percent more efficient than the traditional models. While the  newer technology saves more energy, the bulbs also cost more upfront.</p>
<p>Some folks in Lawrence were monitoring the bill closely. Scott Allegrucci, executive director for <a rel="nofollow" href="../">Great Plains Alliance for Clean Energy</a>, said the bill was worrisome for organizations like his.</p>
<p>&#8220;When you look at the nature of it, there is a strong suggestion that  they are trying to turn back anything that is deemed a response to a  carbon constraint,&#8221; Allegrucci said.</p>
<p>Even without the threat of climate change, Allegrucci said &#8220;there are  a ton of good reasons why energy efficiency measures, including light  bulbs, are good ideas.&#8221;</p>
<p>According to the U.S. Department of Energy, using a more energy  efficient compact fluorescent light bulb can save $40 over its lifetime.</p>
<p>The switch from incandescent to CFLs is one many in Lawrence have made as part of the statewide energy saving competition, <a rel="nofollow" href="http://www.takechargekansas.org/Site_Data/Sub_Pages/City.php?City=7">Take Charge Challenge</a>. In Lawrence, nearly 21,000 light bulbs have been switched to CFLs since the competition started in January.</p>
<p>Linda Cottin, owner of <a rel="nofollow" href="http://sunflowerhorizons.com/groups/general/2011/apr/19/businesses-support-take-charge-challenge/">Cottin&#8217;s Hardware</a>,  said that hardware stores and lighting companies are aware of the light  bulb changes that will kick in soon. But no one is quite clear on what  exactly will change.</p>
<p>The industry has successfully navigated through the government&#8217;s  banning of other products, such as certain chemicals and Freon.  Typically, they are phased out slowly after manufacturers stop producing  them.</p>
<p>&#8220;I definitely would like to see the country move forward with wiser  manufacturing practices, but personally I&#8217;m not positive banning  incandescent bulbs and replacing them with CFLs, which has mercury in  them, is the best,&#8221; Cottin said.</p>
<p>Over the past few years, Cottin has seen sales from incandescent  bulbs dwindle. The store&#8217;s onetime 12-foot long display of incandescent  light bulbs has shrunk to three feet.</p>
<p>&#8220;It is shifting, but still there are so many light fixtures out there where there is not an option to switch,&#8221; she said.</p>
<p>On the other hand, the law could be just what the industry needs, Cottin said.</p>
<p>&#8220;I think there are alternatives out there that we could come up with  that could work, that could make sense. Maybe this (law) is what is  needed to make that happen,&#8221; she said.</p>
<ul>
<li>The Associated Press contributed to this story</li>
</ul>
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		<title>Sunflower Avoiding 5% Solution on Coal</title>
		<link>http://www.gpace.org/news/sunflower-avoiding-5-solution-on-coal/</link>
		<comments>http://www.gpace.org/news/sunflower-avoiding-5-solution-on-coal/#comments</comments>
		<pubDate>Mon, 04 Jul 2011 00:12:16 +0000</pubDate>
		<dc:creator>Kelly</dc:creator>
				<category><![CDATA[News]]></category>
		<category><![CDATA[air quality]]></category>
		<category><![CDATA[coal]]></category>
		<category><![CDATA[coal-fired power plants]]></category>
		<category><![CDATA[Great Plains Alliance for Clean Energy]]></category>
		<category><![CDATA[Holcomb coal plant]]></category>
		<category><![CDATA[Kansas Department of Health and Environment]]></category>
		<category><![CDATA[Kansas Energy]]></category>
		<category><![CDATA[pollution]]></category>
		<category><![CDATA[sierra club]]></category>
		<category><![CDATA[Sunflower Electric]]></category>

		<guid isPermaLink="false">http://www.gpace.org/?p=3182</guid>
		<description><![CDATA[Correspondence produced as a result of a Kansas Open Records Act indicate Sunflower officials helped KDHE write an explanation why the 5 percent coal provision could be sidestepped. <a href="http://www.gpace.org/news/sunflower-avoiding-5-solution-on-coal/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p><em>By Tim Carpenter for the <a href="http://cjonline.com/news/2011-07-03/sunflower-avoiding-5-solution-coal">Topeka Capital-Journal</a></em></p>
<p>Sen. Bob Marshall felt confident an amendment to a controversial  coal-plant authorization bill offered southeast Kansas a reasonable shot  at a slice of economic development.</p>
<p>The Fort Scott Republican inserted into legislation endorsed by  plant-applicant Sunflower Electric Power Corp. and signed into law by  Gov. Mark Parkinson a provision requiring 5 percent of coal burned in  any new power unit to have been mined in Kansas. The coal clause was  among several designed to convince reluctant legislators to open the  door to Sunflower&#8217;s quest for a $2.2 billion expansion.</p>
<p>As ink was drying on that landmark document in 2009, Marshall rubbed  his hands together in pleasure. He knew the biggest coal deposits in  Kansas were underneath the ground in southeast Kansas, a corner of the  state long suffering from economic malaise.</p>
<p>Turns out Sunflower&#8217;s application for an air-quality permit for the  new Holcomb plant didn&#8217;t take into account use of a single chunk of  Kansas coal to generate electricity.</p>
<p>Email traffic between Sunflower and the Kansas Department of Health  and Environment indicated Kansas coal, which has a higher sulfur  content, wasn&#8217;t factored into computer modeling on emissions critical to  KDHE&#8217;s authorization in December to proceed with the project.</p>
<p>Correspondence produced as a result of a Kansas Open Records Act  indicate Sunflower officials helped KDHE write an explanation why the 5  percent coal provision could be sidestepped.</p>
<p>&#8220;I never thought Sunflower would be the problem,&#8221; Marshall said. &#8220;I thought it would be KDHE.&#8221;</p>
<p>Cindy Hertel, spokeswoman for the Hays-based Sunflower, said she  viewed as premature suggestions the Kansas company and a major business  partner, Tri-State Electric Generation and Transmission Association in  Denver, would never rely upon Kansas coal. Sunflower and Tri-State have  business interests in Powder River Basin coal in Wyoming.</p>
<p>The law regarding coal consumption directed new plants to burn 5  percent Kansas fuel if it could be acquired at a competitive price and  was of sufficient quality to avoid air violations.</p>
<p>The permit issued by KDHE declared the project proposal, void of a  link to Kansas coal, in compliance with air quality laws. Sunflower  might make coal from Kansas a piece of the fuel mixture at some point,  Hertel said.</p>
<p>&#8220;We are still considering it,&#8221; she said. &#8220;It&#8217;s part of the legislation.&#8221;</p>
<p>Such assurances aren&#8217;t convincing for representatives of the Sierra  Club and the Great Plains Alliance for Clean Energy, which have raised  objections to the project for years. Lawyers for the Sierra Club filed a  lawsuit in an attempt to force reconsideration of the permit.</p>
<p>Stephanie Cole, spokeswoman for the the Sierra Club&#8217;s chapter in  Kansas, said layering the bill with a Kansas coal teaser demonstrated  how the process was twisted by Sunflower and its political allies to  gain House and Senate support for a project blocked by Democrat Gov.  Kathleen Sebelius in 2007. Her successor, Parkinson, negotiated the deal  approved by legislators in 2009.</p>
<p>&#8220;It appears there may have never been plans to use Kansas coal, but  rather this was a political tactic used to gain legislative support for a  coal plant that cannot be justified by a need for the electricity it  will produce,&#8221; Cole said.</p>
<p>GPACE executive director Scott Allegrucci said the provision tied to 5  percent coal served as incentive for reluctant lawmakers to vote for a  project.</p>
<p>&#8220;They then subverted the law, with help from KDHE, in order to  preserve the Holcomb project with direct fuel sourcing relationships to  Powder River Basin coal mines owned by Western Fuels Association, in  which both Tri-State and Sunflower have a significant revenue stake,&#8221; he  said.</p>
<p>Allegrucci said there were public health, environmental, financial  and legal problems with construction of the coal plant, but if  Sunflower&#8217;s facility were to be built it should include Kansas coal as a  fuel source.</p>
<p>Reps. Bob Grant and Doug Gatewood, both Democrats who represent  southeast Kansas, said the Sunflower legislation should have  emphatically called for consumption of a small percentage of coal mined  within the state.</p>
<p>&#8220;I don&#8217;t know why we want to supply Wyoming with more jobs,&#8221; said  Grant, of Cherokee. &#8220;Kansas coal was one of the reasons I voted for it.&#8221;</p>
<p>Gatewood, of Columbus, said the majority of electricity to be  produced at the new Sunflower unit would be transferred to consumers in  other states.</p>
<p>&#8220;Why would they consider using Kansas products,&#8221; he said. &#8220;The product they&#8217;re producing won&#8217;t be going to Kansas.&#8221;
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		<title>What&#8217;s your plan, Governor?</title>
		<link>http://www.gpace.org/news/whats-your-plan-governor/</link>
		<comments>http://www.gpace.org/news/whats-your-plan-governor/#comments</comments>
		<pubDate>Wed, 01 Jun 2011 16:03:11 +0000</pubDate>
		<dc:creator>Kelly</dc:creator>
				<category><![CDATA[News]]></category>
		<category><![CDATA[clean energy]]></category>
		<category><![CDATA[coal plant]]></category>
		<category><![CDATA[energy policy]]></category>
		<category><![CDATA[Flint Hills]]></category>
		<category><![CDATA[Great Plains Alliance for Clean Energy]]></category>
		<category><![CDATA[Holcomb Station]]></category>
		<category><![CDATA[sam brownback]]></category>
		<category><![CDATA[Scott Allegrucci]]></category>
		<category><![CDATA[Sunflower Electric]]></category>
		<category><![CDATA[wind energy]]></category>

		<guid isPermaLink="false">http://www.gpace.org/?p=3063</guid>
		<description><![CDATA[Gov. Sam Brownback has received praise for declaring Kansas' Flint Hills totally off limits to wind energy development. There is no question that this pristine prairie environment must not be spoiled or endangered, but we have some concerns about what happens next. We do not doubt Brownback's sincerity in guarding those hills, but he now must demonstrate that he is equally committed to capitalizing on his state's vast wind energy development potential. It is much easier to declare where wind turbines cannot go than it is to open opportunities for their development.  <a href="http://www.gpace.org/news/whats-your-plan-governor/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p><em>An editorial from <a href="http://www.kccommunitynews.com/johnson-county-sun-news/28082509/detail.html">The Johnson County Sun</a></em></p>
<p>Gov. Sam Brownback has received praise for declaring Kansas&#8217; Flint  Hills totally off limits to wind energy development. There is no  question that this pristine prairie environment must not be spoiled or  endangered, but we have some concerns about what happens next.</p>
<p>We  do not doubt Brownback&#8217;s sincerity in guarding those hills, but he now  must demonstrate that he is equally committed to capitalizing on his  state&#8217;s vast wind energy development potential. It is much easier to  declare where wind turbines cannot go than it is to open opportunities  for their development.</p>
<p>Kansas ranks second among all states in  wind energy potential, but when you cut one huge swath of the state from  possible production, that potential is greatly diminished. There still  are plenty of breezy flatlands out there, but there are complications in  tapping it.</p>
<p>The Flint Hills always were a temptation to wind  energy developers because transmission lines already were in place. Now,  we must wonder when, where and if enough costly new transmission lines  can or will be available for future wind power farms.</p>
<p>Scott  Allegrucci, director of the Great Plains Alliance for Clean Energy, said  he and his organization do not disagree with the governor&#8217;s intentions.  But he raises the key question.</p>
<p>&#8220;(Kansas is) saying no to wind  energy in the Flint Hills, which we think is a good idea, but where is  the yes to wind energy?&#8221; Allegrucci told The Sun.</p>
<p>Quite correctly, Allegrucci expresses dismay about the effects a new coal plant in western Kansas will have on wind power.</p>
<p>That  coal facility near Garden City &#8220;will clog our (transmission) grid,  which could retard wind development for the western part of the state,&#8221;  Allegrucci said.</p>
<p>Ironically, much of the power generated by that  controversial plant will flow into Colorado. Emissions from it, however,  will float eastward on the untapped Kansas winds. So instead of getting  a flow of clean energy from western Kansas, it appears there is a much  greater chance that Johnson County will get the fallout of burning coal  pollution.</p>
<p>Allegrucci also points out that incentives for placing new transmission lines through sparsely populated areas are few.</p>
<p>&#8220;And  the reality is that in Kansas the real high wind density is in the  southwest 25 percent of the state &#8230; where there aren&#8217;t lines&#8221; or many  people, Allegrucci said.</p>
<p>So we wonder: Was it really necessary to  bar wind energy development completely from the Flint Hills? Could we  not have allowed it at least to some limited extent?</p>
<p>And please  tell us, Gov. Brownback, that you have an aggressive strategy for wind  development elsewhere. Please tell us that there is a plan that will  provide clean energy to Johnson County.</p>
<p>Or, as Mr. Allegrucci asks, &#8220;Where is the yes to wind energy?&#8221;
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		<title>GPACE Comments to Colorado Public Utilities Commission Regarding 2010 Tri-State G&amp;T IRP</title>
		<link>http://www.gpace.org/news/gpace-comments-to-colorado-public-utilities-commission-regarding-2010-tri-state-gt-irp/</link>
		<comments>http://www.gpace.org/news/gpace-comments-to-colorado-public-utilities-commission-regarding-2010-tri-state-gt-irp/#comments</comments>
		<pubDate>Wed, 23 Feb 2011 19:59:54 +0000</pubDate>
		<dc:creator>GPACE</dc:creator>
				<category><![CDATA[News]]></category>
		<category><![CDATA[Colorado Public Utilities Commission]]></category>
		<category><![CDATA[GPACE]]></category>
		<category><![CDATA[Great Plains Alliance for Clean Energy]]></category>
		<category><![CDATA[Kansas department of he]]></category>
		<category><![CDATA[Sunflower Electric Power Corp.]]></category>
		<category><![CDATA[Tri-State Generation and Transmission Association]]></category>

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		<description><![CDATA[Given the impact and influence of Tri-State’s direct involvement in the Holcomb coal-fired project on political and public policy outcomes in Kansas, and the significant impacts of the Holcomb Station expansion upon the health, environment, and economy of Kansans for generations to come, we believe Tri-State can and should, in the public interest, provide more detailed information about its intentions and investments regarding the Holcomb project. <a href="http://www.gpace.org/news/gpace-comments-to-colorado-public-utilities-commission-regarding-2010-tri-state-gt-irp/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p><span style="font-style: normal;">February 22, 2011</span></p>
<address></address>
<address><span style="font-style: normal;">Colorado Public Utilities Commission</span></address>
<address><span style="font-style: normal;">1560 Broadway, Suite 250</span></address>
<address><span style="font-style: normal;">Denver, CO 80202</span></address>
<address><span style="font-style: normal;"><br />
</span></address>
<address><span style="font-style: normal;">Re:  Tri-State Generation &amp; Transmission 2010 Integrated Resource Plan</span></address>
<address><span style="font-style: normal;">Docket No. 10M-879E</span></address>
<address><span style="font-style: normal;">Decision No. C11-0109</span></address>
<address><span style="font-style: normal;"><br />
</span></address>
<p>To Chairman Binz, Commissioner Tarpey, and Commissioner Baker:</p>
<p>As the Executive Director of the Great Plains Alliance for Clean Energy (GPACE), I write to you regarding the Tri-State Generation and Transmission Association (Tri-State) 2010 integrated resource plan (IRP) submitted for review to the Colorado Public Utilities Commission (PUC).  Specifically, this letter references PUC docket number 10M-879E, and PUC decision number C11-0109.</p>
<p>Briefly, GPACE is a Kansas non-profit organization formed to support a clean, secure, prosperous energy economy benefiting Kansas businesses, farms, communities, and all future Kansans.  We have coordinated grassroots education and outreach and legislative lobbying with a diverse alliance of partner organizations and communities, including private companies, other non-profit groups, student organizations, and religious congregations around Kansas.  GPACE has approximately 2,000 active members and a direct, opt-in communications network of over 10,000 Kansas citizens.</p>
<p>For over five years, Tri-State has been involved with Sunflower Electric Power Corporation (Sunflower) of Kansas in a contentious effort to construct the first of several large coal-burning power plants at the existing Holcomb Station in Kansas.  The current project is an 895MW super-critical pulverized coal plant that for decades to come will import coal from Wyoming, deliver electricity back to Colorado, rely upon Kansas air and water, and impact the health and environment of Kansans.  The project was recently granted an air quality permit by the Kansas Department of Health and Environment (KDHE).</p>
<p>According to all available public information, Tri-State is currently a 77% owner of the proposed Holcomb 2 unit and the power it will generate.  As such, 77% of the electrical energy output from the unit is scheduled for transmission to Colorado users within the Tri-State system, so we believe it is appropriate that the Colorado PUC review Holcomb 2 and any related transmission capacity into Colorado, and that the PUC continue to monitor this situation closely.  That is especially true for this project, given the potential risks to Colorado ratepayers derived from Sunflower&#8217;s troubled financial and debt history.</p>
<p>On one hand, given the extraordinary expenditure of time and resources (including both Kansas taxpayer dollars and Tri-State ratepayer dollars) as well as the overt political pressure used to advance this project in Kansas, our members are surprised and disappointed that the Tri-State IRP submitted for your review reveals so little information about the Holcomb coal plant project.</p>
<p>On the other hand, given available generation options, the considerable foreseeable risks related to the project, and Tri-State’s resource models that show no need for significant new coal-fired capacity, the near absence of information about the proposed Holcomb coal plant in the IRP might suggest Tri-State’s sensible exclusion of it as a generation option.</p>
<p>Yet, our understanding is that Tri-State has <em>not</em> excluded Holcomb 2 or any coal baseload generation from the Holcomb Station as a generation option, and that it simply did not include Holcomb 2 or any other proposed coal baseload generation at the Holcomb Station in the 2010 IRP modeling output even though that modeling shows no need for its current equity share of or the electricity from Holcomb 2 within the 20-year planning period.</p>
<p>We are puzzled by the relationship between Tri-State’s two hands.  One is dropping tens of millions of dollars and commensurate influence into the Kansas political and public policy process, while affirming every intention to provide the primary capital, credit, expertise, ratepayer commitment, and customer demand that are being used to justify and build the Holcomb 2 coal-fired unit in our state.  Yet, Tri-State’s other hand appears to be holding tightly to the submitted IRP and a public resource planning process in Colorado that clearly demonstrates no near or mid-term need for its share of the Holcomb project and that affirms its commitment to model renewable energy, public health, carbon valuation, and climate change policies and regulations as enacted by the State of Colorado and the United States government, in particular by the Environmental Protection Agency.</p>
<p>Our members have come to see this apparently contradictory approach as inconsistent with the values of our state, and – we believe &#8211; of yours.   Accordingly, <a href="http://www.gpace.org/blog/public-resource-planning-process-for-colorado-utility-impacts-kansas/">GPACE participated in the public resource planning process</a> ably hosted by Tri-State throughout much of 2010.   In particular, GPACE was represented at the May 19, 2010 public meeting at Tri-State headquarters in Westminster, CO, and in the planning and follow-up conference calls related to that meeting and the public process in general.</p>
<p>As part of our presentation at the May 19, 2010 meeting, I asked <a href="http://www.gpace.org/blog/gpace-comments-and-questions-to-tri-state-generation-transmission/">a number of questions of Tri-State</a> on behalf of our members and thousands of concerned Kansans.  Those questions, and the responses (to-date) from Tri-State are indicated below:</p>
<ol>
<li>Does the recent Xcel “switch” toward natural gas and increased renewables signal a potential move by Tri-State to push its dirtier, riskier baseload capacity out-of-state to places like Kansas?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Does Tri-State intend to externalize costs and liabilities related to its energy and fuel portfolio by sending them over the state line and out of the service area and Colorado regulatory oversight?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>What are the likely impacts from over-production of coal-fired capacity upon the integration of wind energy and natural gas deployment in the region?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Will an over-reliance on coal cause Kansas air quality (and related costs) to suffer more than expected under current modeling?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>We were also interested to hear a Tri-State representative at a previous meeting in this series indicate that Tri-State had done no significant transmission planning related to the proposed Holcomb expansion, counter to public comments in Kansas from Sunflower Electric.  Why has Tri-State not undertaken this transmission planning?
<ul>
<li><em>At meetings as part of the public resource planning process, Tri-State representatives have indicated that none of its current transmission planning is designated specifically for or of adequate capacity for Holcomb 2.  Otherwise, no response from Tri-State.</em></li>
</ul>
</li>
<li>Does it intend to?  Is that dependent upon permit status of the proposed project?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>What is the real likelihood of a major export pathway for wind-generated electrons moving west from Kansas to and through Tri-State’s service area, across the phase shift barrier between our respective power pools, away from key renewable energy markets in the Southeast (and Kansas’s own power pool), and swimming upstream against a robust wind resource right here in Colorado?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>What can Tri-State tell us about the water impacts of the project?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Have any hydrological studies or analyses been undertaken and could those be shared with the public?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Has Tri-State undertaken or acquired any data or analysis on the water and agricultural-related economic impacts from the project?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>With regard to new coal-burning baseload, what contingencies has Tri-State adopted to address the certainty of pending carbon valuation and other regulations related to nitrous oxides, sulfur dioxide, particulate matter, and mercury?
<ul>
<li><em>No response from Tri-State.  Please see recent analysis comparing Holcomb 2 emissions allowances in the recent KDHE permit for the unit and emissions data for all U.S. coal units, <a href="http://www.gpace.org/wp-content/CleanestCoalPlantintheCountry_WhitePaper.pdf">as released by GPACE and attached to this document</a></em><em>.</em></li>
</ul>
</li>
<li>With regard to the economic liabilities created by pending carbon valuation, mercury, and criteria pollutants, where does Tri-State anticipate the fiscal, regulatory, and legal liability will accrue?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>What liability related to pollutants (including carbon) does Tri-State anticipate from the proposed project?
<ul>
<li><em>No response from Tri-State.  Please see recent analysis comparing Holcomb 2 emissions allowances in the recent KDHE permit for the unit and emissions data for all U.S. coal units, <a href="http://www.gpace.org/wp-content/CleanestCoalPlantintheCountry_WhitePaper.pdf">as released by GPACE and attached to this document</a></em><em>.</em></li>
</ul>
</li>
<li>Will those obligations be assigned according to equity ownership (i.e. the current 80-20 split indicated by Sunflower and the permit application, or will they remain solely with the permit holder (Sunflower Electric)?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Will they follow power purchase agreements?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>What is the strategy and/or contractual agreement in place regarding the proposed project to deal with the consequences of carbon valuation, taxation, or regulation, and the fiscal impacts of other criteria pollutants?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Will carbon or other emissions liabilities be passed on to ratepayers?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Does Tri-State anticipate rate increases related to Holcomb 2 if it comes on line?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>How does the business arrangement between Tri-State and Sunflower address rate increases?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Will increased costs related to the construction of the plant, the fuel requirements of the plant, or other factors be passed on to Colorado ratepayers, Kansas ratepayers, or both?  How is that determined?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Does Tri-State have any concerns regarding Sunflower’s financial situation and history?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Has Tri-State undertaken to provide any financial assurances to creditors regarding the proposed 895mw project or its partnership with Sunflower Electric in general?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>With 30 years of unpaid and restructured taxpayer debt, does the current plan for one, two, or three additional large coal-fired units seem archaic and exceedingly risky?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Is this a situation that Tri-State or any rural electric cooperative would or should undertake on its own, absent a partner like Sunflower?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Has Tri-State established a maximum investment it is willing to make in Holcomb 2 with no return on the equity?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>If for any reason, Holcomb 2 is not permitted or built, what debt obligation (if any) does Sunflower have to Tri-State?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>If the project is permitted and completed, what debt obligations (if any) do Tri-State and Sunflower share?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Can Tri-State share more detailed information regarding its financial, legal, regulatory, and operational relationship with Sunflower Electric, especially with respect to the proposed 895mw unit and related transmission infrastructure?
<ul>
<li><em>No response from Tri-State.</em></li>
</ul>
</li>
<li>Does Tri-State have or anticipate a business relationship with Sunflower Electric and the Holcomb Station expansion beyond the proposed 895mw unit?
<ul>
<li><em>No response from Tri-State, but recent public comments from Tri-State as part of the public record related to the 2010 IRP clearly indicate Tri-State maintains an interest in multiple coal-fired generation units as part of the Holcomb Station expansion.</em></li>
</ul>
</li>
</ol>
<p>From the most recent (2009) Tri-State Generation and Transmission Association Annual Report, page 41, we read,  “<em>Excluding the cost of land and water rights</em> [emphasis added], the cost of developing the [Holcomb] units incurred by the Association as of December 31, 2009 is $51.3 million.”  We have anecdotal reports that the current investment by Tri-State in the Holcomb 2 project is around $70 million.  No physical construction has been initiated on the project site, and Tri-State stated, as part of articles regarding its recent Fitch credit rating, that it does not anticipate construction on Holcomb 2 to begin until 2016 at the earliest.   This timing is inconsistent with public claims by Sunflower Electric, though it may match the stated intent by Tri-State to “reserve the option” represented by Holcomb 2 for some time in the future.</p>
<p>In the meantime, the Holcomb project has emerged as one of the most contentious and costly public policy confrontations in recent Kansas history, bringing two sessions of the Kansas legislature to a near halt, absorbing significant expenditure of public resources and time, affecting the careers of Kansas public officials, and skewering political and policy initiatives seemingly unrelated to energy or Holcomb.  A record number of public comments were filed as part of KDHE review process for the Holcomb permit, which ended with what appears to be unethical and potentially illegal political influence upon the outcome, drawing close and ongoing scrutiny from the Environmental Protection Agency and various public advocacy groups.</p>
<p>Despite the unprecedented number of public comments submitted about the Holcomb project, and the tremendous expenditure of Kansas taxpayer time and money, private money and political deal-making have effectively shut the concerns of the Kansas public out of the ongoing process in Kansas related to the Holcomb project.  This highly politicized and suspicious process &#8211; largely funded by Tri-State and driven by Tri-State’s commitment to the project &#8211; gives some indication why GPACE is interested in Tri-State’s resource planning and why (ironically) the Colorado PUC is the only remaining public forum in which Kansas citizens will have a fair opportunity to express credible concerns about Tri-State’s role in the Holcomb Station expansion.</p>
<p>As you discuss Tri-State’s resource planning relevant to Colorado citizens and ratepayers, on behalf of current and future Kansans, and with respect for the state and jurisdictional boundary that separates us, we ask you to consider the impacts of your decisions upon our health and well-being, our economic and civic vitality, efforts to protect our natural resources and our economy, and the need for fiscal responsibility concerning long-term energy investments.</p>
<p>Given the impact and influence of Tri-State’s direct involvement in the Holcomb coal-fired project on political and public policy outcomes in Kansas, and the significant impacts of the Holcomb Station expansion upon the health, environment, and economy of Kansans for generations to come, we believe Tri-State can and should, in the public interest, provide more detailed information about its intentions and investments regarding the Holcomb project.  At the very least, our members believe that Tri-State’s IRP should transparently and accurately depict its role and intentions regarding the proposed Holcomb Station expansion, and that it should be consistent with Tri-State’s actual demand projections with regard to coal baseload generation in general, and the Holcomb 2 unit in particular.</p>
<p>Based upon Tri-State’s own demand projections and demonstrated lack of need for the coal-fired capacity it is developing at the Holcomb Station, we hope that you will require additional information from Tri-State about the project, and/or require Tri-State to amend its 2010 IRP to reflect either its ratepayers’ long-term responsibility for, or its abandonment of, the Holcomb 2 unit.</p>
<p>Respectfully,</p>
<address><span style="font-style: normal;">Scott Allegrucci, Executive Director</span></address>
<address><span style="font-style: normal;">Great Plains Alliance for Clean Energy</span></address>
<address><span style="font-style: normal;"><br />
</span></address>
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		<title>A Coal Plant Over the Rainbow: The Parkinson-KDHE-Sunflower Electric Mess</title>
		<link>http://www.gpace.org/blog/a-coal-plant-over-the-rainbow-the-parkinson-kdhe-sunflower-electric-mess/</link>
		<comments>http://www.gpace.org/blog/a-coal-plant-over-the-rainbow-the-parkinson-kdhe-sunflower-electric-mess/#comments</comments>
		<pubDate>Thu, 30 Dec 2010 21:55:38 +0000</pubDate>
		<dc:creator>GPACE</dc:creator>
				<category><![CDATA[Blog]]></category>
		<category><![CDATA[Bremby]]></category>
		<category><![CDATA[coal]]></category>
		<category><![CDATA[coal-fired power plant]]></category>
		<category><![CDATA[emissions]]></category>
		<category><![CDATA[energy]]></category>
		<category><![CDATA[EPA]]></category>
		<category><![CDATA[GPACE]]></category>
		<category><![CDATA[Great Plains Alliance for Clean Energy]]></category>
		<category><![CDATA[greenhouse gases]]></category>
		<category><![CDATA[Holcomb]]></category>
		<category><![CDATA[Kansas]]></category>
		<category><![CDATA[Kansas Corporation Commission]]></category>
		<category><![CDATA[Kansas Department of Health and Environment]]></category>
		<category><![CDATA[natural gas]]></category>
		<category><![CDATA[Parkinson]]></category>
		<category><![CDATA[Rural Utility Service]]></category>
		<category><![CDATA[Sebelius]]></category>
		<category><![CDATA[settlement agreement]]></category>
		<category><![CDATA[Sunflower Electric Power Corp.]]></category>
		<category><![CDATA[Tri-State Generation and Transmission Association]]></category>
		<category><![CDATA[Western Fuels Association]]></category>
		<category><![CDATA[wind energy]]></category>

		<guid isPermaLink="false">http://www.gpace.org/?p=2213</guid>
		<description><![CDATA[Unfortunately, too many of our own elected representatives are ambivalent toward, even supportive of, the negative health, environmental, economic, energy policy and ethical impacts of the proposed coal plant and the process that has resulted (for now) in a state permit.  As a result, it will be up to federal regulators and the legal system to ensure that the rule of law is still meaningful in Kansas, and to safeguard our environmental and public health legacy for future Kansans.  Whether the coal plant does or does not ever become operational, this process could and should have been much different. <a href="http://www.gpace.org/blog/a-coal-plant-over-the-rainbow-the-parkinson-kdhe-sunflower-electric-mess/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p><strong>Public Process, Private Influence</strong></p>
<p>This morning <a href="http://www.gpace.org/news/ousted-agency-head-is-still-paid/">the Kansas City Star reported</a> that former Kansas Department of Health and Environment Secretary Rod Bremby is still being paid by the State, even after being fired by Governor Parkinson in November.</p>
<p>News that Bremby is still being paid and that the governor&#8217;s office still won&#8217;t comment sounds to us like there is some kind of severance or non-disclosure agreement in place to keep the public (and the Environmental Protection Agency) from discovering the facts surrounding the Governor&#8217;s firing of the Secretary.</p>
<p>In light of this recent development, along with all the <a href="http://www.gpace.org/blog/gaming-the-system-to-get-a-coal-plant/">other evidence of political pressure and tampering with the KDHE permit process</a> for the proposed Sunflower Electric Power Corporation/Tri-State Generation and Transmission coal plant, we have to question the governor&#8217;s previous public statements <a href="http://cjonline.com/news/state/2010-09-23/parkinson_not_pressuring_kdhe">“that we won&#8217;t do anything to artificially accelerate the permit process and we also won&#8217;t do anything to artificially delay the process.&#8221; </a> If Secretary Bremby was fired in order to compress or hasten the permit review, and then bound by a non-disclosure agreement tied to his family&#8217;s financial security, that &#8211; on top of all the other indications of political engagement in the process &#8211; seems to be an <a href="http://www.gpace.org/news/analysis-kansas-governor-owns-decision-on-coal-plant/">artificial acceleration of the permit process directed by Governor Parkinson</a>.  If it isn’t, we are hard-pressed to say what would constitute accelerating the permit process.</p>
<p>One of the many ironies an all this is that the <a href="http://www.gpace.org/news/epa-issues-next-step-for-state-greenhouse-gas-permitting-programs/">EPA greenhouse gas regulations</a> impacting new coal plants and due to go into effect in early January of 2011 – the regulations that created the urgency for Sunflower Electric and coal plant supporters to push for a permit by the end of this year – actually <a href="http://www.gpace.org/news/epa-to-set-modest-pace-for-greenhouse-gas-standards/">set very modest and achievable goals for GHG reductions</a>.  Environmental groups almost universally acknowledged at least some disappointment with the regulations.  This round of federal regulation would not doom the coal plant.  It simply would require Sunflower to undertake initial, achievable efforts at greenhouse gas (GHG) reduction.  But apparently even that was asking too much of the Kansas pro-coal and climate-denier crowd and their political and special-interest allies.</p>
<p>Let’s review some of the other indications of extraordinary political activity designed to accelerate the granting of a needed KDHE air quality permit to Sunflower Electric for the coal plant project.</p>
<p>The <a href="http://www.gpace.org/blog/gpace-analysis-of-the-provisions-of-the-governors-coal-plant-agreement/">settlement agreement</a> between the governor and Sunflower Electric was conducted in secret, with no independent environmental, air quality, economic, energy or other expertise involved – though lobbyists for Sunflower Electric were involved.   According to information obtained by GPACE as part of an open records request, Parkinson began negotiations with representatives of Sunflower Electric prior to and apparently without the knowledge of former Governor Sebelius.  He announced <a href="http://www.gpace.org/blog/message-from-gpace-director-scott-allegrucci/">the deal</a> just days after he was sworn in as governor.  KDHE was not party to the agreement, was not given any time to review the agreement for technical, environmental, and public health impacts, and Secretary Bremby did not sign the agreement.  In addition to numerous other questionable provisions, the <a href="http://kansas.sierraclub.org/Wind/FactSheet-Parkinson-Sunflower-ByVolland-2009-0521.pdf">settlement agreement</a> ensured that Sunflower Electric will likely never come under ratepayer or resource oversight by the Kansas Corporation Commission (KCC), and it codified into Kansas statute a directive specifically stating that Sunflower Electric be granted an air quality permit for its coal plant.  This, well before any KDHE review or public comments on the project and possibly in violation of the state implementation plan with EPA regarding the federal Clean Air Act.</p>
<p>The existence of <a href="http://www.gpace.org/news/coal-plant-permit-expected-this-year/">a leaked email from Sunflower Electric</a> referencing meetings between the governor&#8217;s office and coal plant supporters and calling for elected officials to put pressure on KDHE, was uncovered just prior to the official KDHE announcement of a second public comment period on the permit.  The email accuses Bremby of “gaming the process” but obscures the fact that the second comment period was necessitated by the submission of erroneous modeling data by Sunflower Electric as a part of its initial permit request.  It also indicates unethical communication and collusion between elected legislators, the governor’s office, and special interest lobbyists in order to specifically pressure KDHE to get the permit granted by the end of 2010.  The governor’s office denied any such involvement, but a pro-coal legislator who received the email publicly confirmed meetings with the governor’s office to pressure KDHE on timing of the permit.  Soon after the email was discovered, <a href="http://www.kdheks.gov/news/web_archives/2010/09222010a.htm">KDHE announced a 30-day second public comment period</a>, as opposed to the 45-day comment period agency representatives had already publicly committed to.  Of note, KDHE granted the permit on December 16<sup>th</sup>, 15 days before the end of the year and effective start of the EPA GHG regulations feared by Sunflower Electric.</p>
<p>Governor <a href="http://www.gpace.org/news/firing-improves-chances-for-sunflower-coal-plant/">Parkinson fired KDHE Secretary Bremby</a> on election day, in an obvious attempt to bury the story amidst election coverage.  The Governor claims no connection between Bremby’s firing and the coal plant permit, but the timing and method of the action leave no other explanation – and the Governor has not offered any.  Additionally, sources indicated the existence of a pre-typed memo from the governor&#8217;s office leaked after press got hold of the story, incorrectly stating that Bremby had voluntarily resigned as Secretary of KDHE and accepted a transition position.  That is not, in fact, what happened.  Specifically what did happen remains shrouded in secrecy, as indicated by the Kansas City Star’s ongoing coverage.  However, it seems clear that Bremby was removed as KDHE Secretary when he refused to be “reassigned” to a Brownback transition position, and refused to resign as Secretary.</p>
<p>In <a href="http://www.gpace.org/news/kansas-governors-comments-dont-quiet-coal-plant-fuss/">the wake of Bremby’s firing</a>, Environment Division Director Mitchell was elevated to Acting Secretary thereby compressing the inter-agency review process for the permit.  Since the air quality functions of the agency are under the Environment Division, the Division Director is one of three inter-agency review steps in the permit process (technical staff, Division Director, Secretary).  Making the Division Director the Acting Secretary effectively trims that internal review down to two steps.  What’s more, <a href="http://www.gpace.org/news/permit-process-for-coal-fired-power-plant-in-kansas-draws-criticism/">the Kansas City Star reported</a> that nine KDHE staff were working overtime, nights, weekends, and holidays (with no additional pay) to complete the coal plant permit.  Our understanding is that there are only nine professionals in the entire agency qualified to work on air permitting, so the entire qualified staff of KDHE worked overtime on a single permit.  This would mean that all other permit applications were sidelined for the coal plant.  We assert that this extraordinary effort was not undertaken because the work was critical to the health and environmental well being of Kansans, but because the permit (issued prior to Jan 2011) was deemed to be critical to the applicant (Sunflower Electric) and its financial and political backers.  Again, if this does not constitute “accelerating the process” or political pressure, what does?</p>
<p>KDHE completed review and approved the permit in less time than it&#8217;s <a href="http://www.kdheks.gov/air-permit/forms/Timeline.pdf">own published schedule for a decision on such complex permits</a> indicates it should take.  According to KDHE policy, the start-to-finish permitting process for a &#8220;complex&#8221; permit takes a minimum of <em>186 [working] </em>days, <em>not including</em> <em>the variable period for</em> <em>public comment response</em> OR the <em>variable backlog period, </em>(usually 2-6 weeks).  And this does not count the extraordinary issues that have been part of this process, nor any agency backlog on other permit applications.</p>
<p>But KDHE granted the permit on 12/16/2010, so it took them about 168 calendar days, or about 140 working days &#8211; at least a month less than the <em>minimum</em> time the agency itself says it should have taken.  However, there was an additional public comment process introduced into this process, which does not seem to be accounted for in the agency document, an unprecedented number of public comments, various machinations forced by the governor&#8217;s office to further compress the review time (colluding with pro-coal lobbyists and elected officials to pressure KDHE, forcing KDHE to reduce second public comment period from 45 to 30 days, elevating Division Director to Acting Secretary over existing Deputy Sec., etc.), and the actual draft permit was (in the current regulatory context) certainly a complex project.  Clearly KDHE rushed its own process in order to finalize the draft permit, as needed by Sunflower/Tri-State and as directed by Parkinson.</p>
<p>Finally, it bears repeating that the previous round of comments on a prior permit proposal for Sunflower Electric took 18 months and involved fewer than 800 public comments, while the public process that just ended took 6 months and involved over 5,000 public comments, many of them very complex and technical criticisms of the new draft permit.  So KDHE granted a permit involving at least <strong>six times the number of public comments in about one-third the time</strong>.  <a href="http://www.kdheks.gov/air-permit/forms/Timeline.pdf">The schedule that transpired is significantly shorter than the publicly posted KDHE schedule for review of such permits</a>.</p>
<p>All of this points to collusion and political maneuvering by the governor explicitly to benefit Sunflower Electric, at the expense of the public.  In fact, there is now no question that Secretary Bremby was forced out because he was attempting to do his job and ensure an airtight and credible permit process.  In the wake of Parkinson’s secret settlement agreement with Sunflower, that was all the authority that was left to him.  Again, even that <a href="http://www.gpace.org/blog/brembys-firing-could-derail-the-coal-plant/">constricted public responsibility on the part of the agency head responsible for protecting the public health and environment</a> of all Kansans was apparently too much for the Kansas coal cabal to bear.</p>
<p>Whatever his personal opinions on the issue, clearly Secretary Bremby was deeply committed to a transparent, fair, credible process, especially with regard to public comments on the permit.  Had the governor not fired him, the permit would have proceeded at the pace and process established by the rule of law.  Now, the entire process is clouded by unethical and possibly illegal behavior that will drag it out for years, all so Sunflower, the governor, and coal plant supporters could score a meaningless political victory.</p>
<p><strong>More to the Story</strong></p>
<p>In the larger context of Bremby’s firing and the KDHE permit process there are some important facts to keep in mind regarding the proposed coal plant project.</p>
<p>It is not accurate to state that much of the power from the proposed coal plant will be “<strong>sold” </strong>to out-of-state utilities.  The plant and its power will be <strong>owned</strong> primarily by out-of-state utilities.  Under the current arrangement, the Holcomb coal plant will be 80% owned by <a href="http://www.tristategt.org/">Tri-State Generation and Transmission</a>, based in Colorado.  So, 80% of the electricity produced by the plant will be owned by Tri-State.  The electricity will not be sold by Sunflower in a free-market context, and as such, it will not be an export product ‘like wheat or beef’, as has been claimed by pro-coal advocates.  There is no sale and no “export” involved.  The plant itself will be phased for the western grid, not for the eastern grid (which serves Kansas).  So the power will have to be converted before it can be used in Kansas, but not so for Colorado. <a href="http://www.gpace.org/blog/who-really-owns-the-coal-plant/">The plant is a coal plant for Colorado</a>.</p>
<p>Sunflower Electric will not be the primary owner of the plant or the power because <a href="http://www.gpace.org/blog/pay-no-attention-to-the-taxpayer-behind-that-curtain/">Sunflower is in such bad financial shape</a>.  Sunflower essentially defaulted on hundreds of millions of dollars of taxpayer funded loans for its first coal plant, and then created a shell-company to contain the unpaid debt (now probably about a billion dollars) and walked away from it &#8211; and from its responsibility to repay taxpayers.  Sunflower even got the USDA Rural Utility Service (RUS) to restructure its debt on three separate occasions, and then got RUS to approve the proposed coal plant projects for the Holcomb Station expansion without requiring environmental impact statements tied to the taxpayer debt (a case is now pending in federal court that could do more damage to Sunflower’s coal plant plans than the EPA GHG regulations).</p>
<p>Neither Sunflower nor Tri-State &#8211; the primary Colorado owner of the plant &#8211; can demonstrate any real need for the electricity the plant will produce.  <a href="http://kec.kansas.gov/reports/Capacity_and_Load_Forecasts.pdf">Sunflower reports on its own to the KCC</a> and shows no gap between demand and capacity for at least eight years, and then only a tiny fraction of the plant&#8217;s capacity.  Tri-State <a href="http://www.tristategt.org/ResourcePlanning/documents/Tri-State_IRP-ERP_Final.pdf">just concluded a resource planning process</a> in which they modeled around two dozen scenarios, and only one showed any possible need for coal baseload &#8211; only 300MW, by 2027, with no demand side EE management, and after the construction of two natural gas plants.</p>
<p>The suggestion that a coal plant of this size producing 895MW of unneeded electricity will complement wind energy in Kansas is completely misguided.  All those extra electrons on the grid will crowd out wind developers in Kansas &#8211; for the life of the coal plant (maybe 50 years).  Coal plants do not work well with wind energy since they do not ramp up and down efficiently and so are left running whether they are needed or not.  This coal plant is almost certain to retard wind development in western Kansas.  And any transmission infrastructure will be only to move electrons from the plant to Colorado (since the plant itself will be phased for the western grid and the transmission interconnect between the grids will likely be only to move coal-generated electrons from the plant), and so will not be of any benefit to wind developers in Kansas (I have heard this from half a dozen different wind energy companies).</p>
<p>Almost lost in the spin and secrecy surrounding the project is the simple fact that Sunflower had a permit in hand for a 660 MW coal plant from 2002 until 2005.  KDHE granted the <a href="http://www.sunflower.net/documents/NRReceivesAirPermitForNewPlant.pdf">original air quality permit for the Sand Sage project</a> in October of 2002, and then granted Sunflower an <a href="http://www.sunflower.net/documents/NRKDHEExtendsAirPermit.pdf">18-month extension</a> on the permit through October of 2005.  But Sunflower let that permit expire, for reasons that remain somewhat unclear.  If creating jobs and economic development for Kansans were honestly of utmost importance for the coal plant supporters, that project &#8211; had it been constructed &#8211; would still be providing both.  Tri-State &#8211; the driver and owner of the project &#8211; has <a href="http://www.businesswire.com/news/home/20100309007110/en/Fitch-Affirms-Tri-State-Generation-Transmission-COs-Revs">publicly stated</a> that it does not see construction starting on the recently-permitted project until 2016 at the earliest.  It is also curious to note that Governor Sebelius offered a compromise to Sunflower and its legislative supporters in 2008 whereby the State would allow a 660 MW coal-fired unit to move forward at the Holcomb Station, but the compromise offer was universally rejected by the pro-coal crowd (again, for reasons that remain somewhat unclear&#8230;at least publicly).</p>
<p>And of course, there are the <a href="http://www.psr.org/resources/coals-assault-on-human-health.html">deaths and disease</a> in Kansas that will be caused directly by the emissions from this plant, but that will be paid by individuals and taxpayers in the form of urgent health care costs and human suffering.  Claims by supporters that this will be the &#8220;cleanest coal plant in the nation&#8221; are simply not true.  According to 2010 <a href="http://www.epa.gov/ttn/emc/cem.html">EPA CEMS data</a>, there are at least 53 coal plants in the country that have lower rates of sulfur dioxide emissions, and at least 18 with lower nitrogen oxide emissions, than the proposed Holcomb plant.  Similarly, particulate matter and mercury emissions will exceed that from many other plants.  Under the KDHE permit, the Holcomb unit will not be using state of the art processes that are already in place at dozens of existing coal plants, and proposed for many more.  If preventing death and disease from poisoned air is the standard for utilities and citizens in other states, it should be the standard for Kansas.</p>
<p>Another example of the kind of unethical and highly politicized actions supporters of the coal plant have engaged in thus far can be found in an overlooked part of the recently issued KDHE permit as it relates to Kansas law.</p>
<p>One provision of the <a href="http://24.123.107.252/blackbelt_kf/Text_111/20092369D.pdf">sweeping law signed by Governor Parkinson</a> in the wake of the secret settlement deal requires all new coal plants in Kansas to burn at least 5% Kansas coal, but the permit just approved allows Sunflower Electric to violate that law.  The provision was part of an amendment added to House bills in 2009 in order to secure southeast Kansas legislative support for the coal plant near Holcomb in far southwestern Kansas.  It seems that southeast Kansas was promised an economic boost related to renewed coal mining if the plant went operational.  However, the provision included exemptions (apparently overlooked or misunderstood by local legislators) clearly designed to excuse utilities from ever using Kansas coal.</p>
<p><a href="http://www.ucsusa.org/clean_energy/technology_and_impacts/impacts/burning-coal-burning-cash.html">Over 99% of the coal currently used by Kansas utilities to generate electricity is imported</a>.  According to the permit, the coal used for the Holcomb plant will be imported from Wyoming &#8211; enhancing that state&#8217;s tax base and revenues, at the expense of Kansas fuel producers.</p>
<p>A veteran Republican lobbyist in Topeka with experience in energy policy confirmed to us that Sunflower Electric&#8217;s Chief Counsel actually wrote the amendment offered by Rep. Bob Grant and then signed into law by Governor Parkinson.  So, it seems that Sunflower wrote the law for political expediency, and then, <a href="http://www.kdheks.gov/bar/sunflower/sunflower.html">according to its permit,</a> intends to violate the law it wrote and does not intend to use any Kansas coal in the Holcomb power plant&#8217;s fuel mix.</p>
<p>The Great Plains Alliance for Clean Energy commented on the law as part of our <a href="http://www.gpace.org/blog/gpace-comments-from-scott-allegrucci-at-final-kdhe-hearing/">public comments on the KDHE draft permit</a>, and provided evidence that (a) none of the exemptions were actually sound &#8211; that is, none of the exemptions could legally exclude Kansas coal from the Sunflower project, and (b) that the permit allowed the project and Sunflower Electric to violate Kansas law.  Sunflower applied for the permit after the law was in effect, so both Sunflower and KDHE had prior knowledge that there was a potential conflict between the statute and the permit as submitted.  KDHE should have at least required Sunflower to model inclusion of 5% minimum Kansas coal in it&#8217;s fuel mix, identify the Kansas coal source, and potentially adjust mitigation technology for compliance with the CAA (or show cause why they could not).  KDHE (in response to our comment) essentially claimed that the exemptions in the statute held both the agency and Sunflower harmless and exempt from any such requirements.  We believe that <a href="http://www.kdheks.gov/bar/sunflower/Responsiveness_Summary_Final.pdf">KDHE incorrectly and hastily dismissed GPACE comments</a>, and granted the permit without revisions, setting the stage for future legal action related to the violation.</p>
<p>Of additional interest, Sunflower Electric is a <a href="http://www.westernfuels.org/members/Class-A.cfm">Class A member of the Western Fuels Association (WFA),</a> which owns significant coal mine and coal rail transport interests in the Powder River Basin (PRB) of Wyoming.  The Holcomb plant permit identifies PRB coal as the fuel source for the plant.  So, coal mined in Wyoming (but partly owned by Sunflower Electric) will power the Holcomb plant &#8211; returning tax revenue, salaries, jobs, and investment to Wyoming, and revenue to Sunflower Electric &#8211; but no revenue, investment, or jobs to Kansas, especially the historic coal region of Southeastern Kansas.</p>
<p>Furthermore, Tri-State Generation and Transmission &#8211; the Colorado utility that will actually own 80% of the Holcomb coal plant &#8211; is also a Class A member of the Western Fuels Association.  In fact, Tri-State is heavily represented in the WFA, and the headquarters of WFA is actually at the exact same address as Tri-State&#8217;s headquarters (in Westminster, Colorado).  So, again, <a href="http://www.gpace.org/blog/gpace-comments-and-questions-to-tri-state-generation-transmission/">Tri-State owns most of the equity of the Holcomb coal plant</a>, most of the electricity produced, a stake in the coal mines and railroads that will supply the plant, water rights in Western Kansas, land in Western Kansas, and has contributed at least $53 million (<a href="http://www.tristategt.org/Financials/annual-report.cfm">as of 12/2009</a>) directly to Sunflower Electric to cover the costs of the fight to get the permit for the plant.</p>
<p>As if all of this weren’t insult enough, the plant would be built on top of the 5th largest natural gas reserve in the continental US (<a href="http://www.eia.doe.gov/state/state_energy_profiles.cfm?sid=KS">the Hugoton field</a>), and in the midst of the second best wind resource in the nation (<a href="http://www.nrel.gov/wind/resource_assessment.html">according to data from the National Renewable Energy Laboratory</a>).  Both are fuel resources Kansas has in abundance and significantly under-utilizes (and both are much cleaner than coal and would create more long-term jobs, a more robust industry base for the state, and much more widely distributed income and revenue than coal).</p>
<p>We don’t believe this project has ever been primarily about a need for energy or about the best way to provide long-term economic development to Kansas.  It has always been more about money, mismanagement, and partisan political games.</p>
<p><a href="http://www.gpace.org/blog/what-are-we-fighting-for/">We believe that Kansas deserves – and can do – much better</a>.  Unfortunately, too many of our own elected representatives are ambivalent toward, even supportive of, the negative health, environmental, economic, energy policy and ethical impacts of the proposed coal plant and the process that has resulted (for now) in a state permit.  As a result, it will be up to <a href="http://www.gpace.org/news/epa-leader-pledges-fair-decision-on-power-plant/">federal regulators</a> and the legal system to ensure that the rule of law is still meaningful in Kansas, and to safeguard our environmental and public health legacy for future Kansans.  Whether the coal plant does or does not ever become operational, this process could and should have been much different.</p>
<p><em>Scott Allegrucci is the Executive Director of the <a href="http://www.gpace.org/">Great Plains Alliance for Clean Energy</a></em>
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		<title>State Approves Permit for Holcomb Coal Plant</title>
		<link>http://www.gpace.org/news/state-approves-permit-for-holcomb-coal-plant/</link>
		<comments>http://www.gpace.org/news/state-approves-permit-for-holcomb-coal-plant/#comments</comments>
		<pubDate>Thu, 16 Dec 2010 22:28:09 +0000</pubDate>
		<dc:creator>Kelly</dc:creator>
				<category><![CDATA[News]]></category>
		<category><![CDATA[air quality]]></category>
		<category><![CDATA[coal plant]]></category>
		<category><![CDATA[GPACE]]></category>
		<category><![CDATA[Great Plains Alliance for Clean Energy]]></category>
		<category><![CDATA[Kansas]]></category>
		<category><![CDATA[Kansas Department of Health and Environment]]></category>
		<category><![CDATA[pollution]]></category>
		<category><![CDATA[Scott Allegrucci]]></category>
		<category><![CDATA[Sunflower Electric]]></category>
		<category><![CDATA[Tri-State Generation and Transmission Association]]></category>

		<guid isPermaLink="false">http://www.gpace.org/?p=2131</guid>
		<description><![CDATA[Acting Health and Environment Secretary John Mitchell announced his decision Thursday. It allows Hays-based Sunflower Electric Power Corp. to move forward with its $2.8 billion project outside Holcomb. <a href="http://www.gpace.org/news/state-approves-permit-for-holcomb-coal-plant/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p><em>By John Hanna for the<a href="http://www.kansas.com/2010/12/16/1635993/kan-regulator-to-make-announcement.html"> Associated Press</a></em></p>
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<p>TOPEKA, Kan. &#8211; Kansas&#8217; top environmental regulator has approved an air quality permit for a new coal-fired power plant in the southwest part of the state.</p>
<p>Acting Health and Environment Secretary John Mitchell announced his decision Thursday. It allows Hays-based Sunflower Electric Power Corp. to move forward with its $2.8 billion project outside Holcomb.</p>
<p>The utility and its supporters had hoped a permit would be issued before the end of the year, so the new plant wouldn&#8217;t fall under federal regulations on greenhouse gases linked to global warming, which take effect Jan. 2.</p>
<p>Gov. Mark Parkinson brokered a deal with Hays-based Sunflower in April 2009 to allow the plant&#8217;s construction and clear opposition in the Legislature to proposals he favored to promote wind and other forms of renewable energy. The governor has said he hasn&#8217;t been involved in the permitting process and doesn&#8217;t care how it turns out, but environmentalists put little stock in such statements.</p>
<p>Scott Allegrucci, executive director of the Great Plains Alliance for Clean Energy, said before the news conference that the department should take more time to review questions about the project and the proposed permit for Sunflower. But he said he anticipated the permit&#8217;s approval.</p>
<p>&#8220;We&#8217;ve known this was coming,&#8221; Allegrucci said. &#8220;We&#8217;ve been assuming that it&#8217;s a fait accompli.&#8221;</p>
<p>Sunflower&#8217;s plant would have a capacity of 895 megawatts, enough to meet the peak needs of 448,000 homes, according to one state estimate. Three-quarters of the new capacity, or 695 megawatts, would be reserved for a Sunflower partner, Tri-State Generation and Transmission Association Inc., of Westminster, Colo.</p>
<p>Sunflower spokeswoman Cindy Hertel said the department didn&#8217;t rush its a decision.</p>
<p>Sunflower has worked on proposals for additional coal-fired generating capacity since 2001, and in 2006 filed an application for a permit for two plants on the same Holcomb site.</p>
<p>&#8220;We think it&#8217;s been thoroughly vetted,&#8221; she said.</p>
<p>In October 2007, Mitchell&#8217;s predecessor, Secretary Rod Bremby, denied a permit for two coal-fired power plants. He cited the potential hazards posed by new greenhouse gas emissions, and environmentalists around the nation praised his decision.</p>
<p>Democrat Kathleen Sebelius was governor at the time, and she backed his decision.</p>
<p>But Sunflower&#8217;s efforts to build two plants had bipartisan support among legislators, and they passed bills in 2008 and 2009 to overturn Bremby&#8217;s decision and strip the secretary of some of his power. Sebelius vetoed the measures, while legislators blocked &#8220;green&#8221; energy policies she sought.</p>
<p>In April 2009, Sebelius resigned to become U.S. secretary of health and human services, elevating Parkinson from lieutenant governor to governor. Almost immediately, he brokered the deal with Sunflower.</p>
<p>Bremby stepped down as KDHE secretary in November, and environmentalists worry he was forced out to smooth the way for a permit for Sunflower. Parkinson&#8217;s office has said Bremby was asked to take a job helping to manage the transition to Gov.-elect Sam Brownback&#8217;s administration and declined.</p>
<p>Later, Pankratz confirmed that salaried KDHE employees involved in Sunflower&#8217;s permit worked extra hours around Thanksgiving, though at no additional cost to the state. She said such extra work is not unusual within the agency, but environmentalists saw it as another sign that the permit was being rushed.</p>
<p>Parkinson, a Democrat, did not run for a full four-year term and leaves office Jan. 10. Brownback, a Republican, supports Sunflower&#8217;s project.</p>
<p><a href="http://www.kansas.com/2010/12/16/1635993/kan-regulator-to-make-announcement.html#ixzz18JfrzvSz"></a></div>
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		<title>Coal&#8217;s Grip on Power Debated</title>
		<link>http://www.gpace.org/news/coals-grip-on-power-debated/</link>
		<comments>http://www.gpace.org/news/coals-grip-on-power-debated/#comments</comments>
		<pubDate>Mon, 23 Aug 2010 15:42:34 +0000</pubDate>
		<dc:creator>Kelly</dc:creator>
				<category><![CDATA[News]]></category>
		<category><![CDATA[air quality]]></category>
		<category><![CDATA[coal-fired power plants]]></category>
		<category><![CDATA[Earl Watkins]]></category>
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		<category><![CDATA[Kansas]]></category>
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		<category><![CDATA[renewable energy]]></category>
		<category><![CDATA[Scott Allegrucci]]></category>
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		<category><![CDATA[stephanie cole]]></category>
		<category><![CDATA[Sunflower Electric]]></category>

		<guid isPermaLink="false">http://www.gpace.org/?p=1751</guid>
		<description><![CDATA[The number of plants recently built and being built now represent just a fraction of the 151 total plants that the federal government had forecast several years ago. Allegrucci says that shows “coal as an electricity fuel is on the wane.” And while most of the coal plants have been canceled or put on hold, renewable energy sources have been developed at a record pace. <a href="http://www.gpace.org/news/coals-grip-on-power-debated/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p><em>By Scott Rothschild of <a href="http://www2.ljworld.com/news/2010/aug/23/coals-grip-power-debated/">The Lawrence Journal World</a></em></p>
<p>Is coal-fired production of electricity on the rise or is it flaming out?</p>
<p>A recent report by The Associated Press described a nationwide wave of coal-burning power plant construction.</p>
<p>And that fits in with the plan by Hays-based Sunflower Electric Power Corp. to build an 895-megawatt unit in southwestern Kansas.</p>
<p>“Coal isn’t on the wane,” Earl Watkins, president and chief executive officer of Sunflower Electric, said this month after a public hearing in Garden City on the proposed plant.</p>
<p>Environmentalists, however, say the premise of the AP report is inaccurate.</p>
<p>“The coal plants that are being built today were permitted years ago when the outlook for coal was much more favorable than current conditions,” said Stephanie Cole, a spokeswoman for the Kansas chapter of the Sierra Club.</p>
<p>“Building a new coal plant today could be equated to making an investment in rotary dial landline telephones. Coal is yesterday’s fuel source,” Cole said.</p>
<p>Sunflower Electric is seeking a permit from the Kansas Department of Health and Environment for the project. Most of the electricity will be owned by Colorado-based Tri-State Generation and Transmission Association for sale to out-of-state customers.</p>
<p>“There are some 16 coal plants in various stages of construction right now,” Watkins said. “There are another eight to 10 that have just recently been permitted by other utilities across the country.</p>
<p>“Coal projects that are built for speculation are dropping off the table because no one wants to make that type of an investment without knowing they have a need,” Watkins said. “But all of the participants of this project are going to be displacing lost resources, like us, or displacing higher cost market prices, so they have got a revenue stream there.”</p>
<p>Coal-burning has been under fire for producing climate-changing carbon dioxide emissions. President Barack Obama’s administration has proposed regulating CO2. But the AP recently reported that the nation is seeing the largest increase in coal-fired plants in two decades.</p>
<p>More than 30 coal plants have been built since 2008 or are under construction at a cost of $35 billion, AP reported. Once on line, the plants will produce enough electricity to power 15.6 million homes, the equivalent to all the homes in California and Arizona, the report said.</p>
<p>In addition, the plants will generate 125 million tons of greenhouse gases each year, the equivalent of putting 22 million more automobiles on the road.</p>
<p>But Scott Allegrucci, director of the Great Plains Alliance for Clean Energy in Kansas, has a different view of the coal landscape, both nationally and in Kansas.</p>
<p>The number of plants recently built and being built now represent just a fraction of the 151 total plants that the federal government had forecast several years ago. Allegrucci says that shows “coal as an electricity fuel is on the wane.”</p>
<p>And while most of the coal plants have been canceled or put on hold, renewable energy sources have been developed at a record pace.</p>
<p>“So, since November 2008, not a single new coal plant has broken ground for construction, but record amounts of wind, solar, and other renewables are coming online,” Allegrucci said.</p>
<p>And he notes that in the Kansas proposal, Tri-State Generation and Transmission, which will buy most of the power from the proposed Kansas plant, hasn’t made a concrete commitment to the project, describing the plant as an option in Tri-State’s long range plans.</p>
<p>Another factor not mentioned in reports of coal’s rise is that some coal plants are being mothballed, said the Sierra Club’s Cole.</p>
<p>“Today we’re seeing more utilities announce retirement plans for existing coal plants than we are seeing utilities announcing plans to build new coal plants,” Cole said.
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		<title>Scott Allegrucci: Overland Park Public Hearing Testimony</title>
		<link>http://www.gpace.org/blog/scott-allegrucci-overland-park-public-hearing-testimony/</link>
		<comments>http://www.gpace.org/blog/scott-allegrucci-overland-park-public-hearing-testimony/#comments</comments>
		<pubDate>Tue, 03 Aug 2010 15:12:23 +0000</pubDate>
		<dc:creator>Kelly</dc:creator>
				<category><![CDATA[Blog]]></category>
		<category><![CDATA[coal-fired power plants]]></category>
		<category><![CDATA[Emporia Energy Center]]></category>
		<category><![CDATA[energy]]></category>
		<category><![CDATA[Great Plains Alliance for Clean Energy]]></category>
		<category><![CDATA[Holcomb Station]]></category>
		<category><![CDATA[Kansas Department of Health and Environment]]></category>
		<category><![CDATA[natural gas]]></category>
		<category><![CDATA[nolan county]]></category>
		<category><![CDATA[Scott Allegrucci]]></category>
		<category><![CDATA[Sunflower Electric]]></category>
		<category><![CDATA[Texas]]></category>
		<category><![CDATA[Tri-State Generation and Transmission]]></category>
		<category><![CDATA[wind energy]]></category>

		<guid isPermaLink="false">http://www.gpace.org/?p=1717</guid>
		<description><![CDATA[The following comments were delivered by GPACE Executive Director Scott Allegrucci at the Overland Park Public Hearing for Sunflower Electric's Holcomb Station Expansion Project on Monday, August 2. <a href="http://www.gpace.org/blog/scott-allegrucci-overland-park-public-hearing-testimony/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p><em>The following comments were delivered by GPACE Executive Director Scott Allegrucci at the Overland Park Public Hearing for Sunflower Electric&#8217;s Holcomb Station Expansion Project on Monday, August 2.</em></p>
<p><em> </em>To the respected staff of the Kansas Department of Health and Environment:</p>
<p>Thank you for the opportunity to provide comments today.  My name is Scott Allegrucci and I am a third-generation Kansan. I am also the executive director of the Great Plains Alliance for Clean Energy, based in Topeka.</p>
<p>Our members appreciate, first, that the Kansas Department of Health and Environment plans to open a second public comment period for the draft permit in question. Obviously, since incorrect modeling data was filed, and since our engineers and consultants cannot review the full and accurate permit, we cannot speak directly to the technical aspects of the draft permit and what we expect will be bad news for Kansas air quality.  We will append our current comments with a more comprehensive and technical analysis once the draft permit is actually complete and accessible at KDHE. Today, then, we’d like to address another aspect of this project.</p>
<p>I come from a southeast Kansas working-class family. Early last century, many of my family members (and friends and neighbors) worked the coal mines in and around Crawford County. They were working with the technology and supplying the fuel of that era, and the Allegruccis have a long history of support for those industries as well as for the interests of working families across the state of Kansas.</p>
<p>Today, the organization for which I speak recognizes that Kansas needs jobs now and will likely need additional electrical power in the future. The real question is: What is the best way to create jobs and supply electricity for our economy?</p>
<p>Unfortunately, that question has been obscured by a false choice that has been foisted on Kansas by a powerful alliance of out-of-state, business, and political interests. That false choice is that we generate power and create jobs with another coal-burning power plant, just like we did last century &#8211; or, we do nothing.</p>
<p>The truth is that there is a better way to create jobs and supply power – especially in Kansas. A better way for Sunflower Electric Power Corporation to create more jobs over time, and create them sooner.  A way that develops Kansas’ native resources &#8211; especially natural gas and wind immediately.  A way that embraces the future, instead of clinging to the past, so that there will be good jobs for our children and grandchildren as well as for us, without jeopardizing the health and environment of all Kansans for generations.</p>
<p>I am submitting written testimony that substantiates this approach. There’s much more detail than time allows, but I will briefly share here today two examples of how Sunflower Electric could do this better for Kansans.</p>
<p>In August 2006, Westar Energy announced plans for two natural gas electricity production units at their Emporia Energy Center. The permits were granted in April 2007.  The first unit was complete and operational 13 months later.  The second came online a year after that.  The project was under budget, ahead of schedule, and operates at a higher efficiency than predicted.  At the peak of construction, almost 600 workers were employed.<a href="#_edn1">[i]</a></p>
<p>And the utilization of natural gas (a fuel Kansas currently exports) reduces carbon dioxide emissions by nearly 50% per BTU (as compared to coal), reduces the emissions of ozone precursors by even more, and nearly eliminates the dangerous particulate and mercury emissions that require the expensive and highly regulated technical controls that seem to have been problematic for Sunflower Electric’s initial modeling data.<a href="#_edn2">[ii]</a></p>
<p>About the same time, leaders in Nolan County, Texas, committed to developing their wind energy resources. In that one county, the wind energy industry has created more than a thousand jobs with a combined payroll of more than 45 million dollars a year. <a href="#_edn3">[iii]</a><a href="#_edn4">[iv]</a><a href="#_edn5">[v]</a> Additionally, as you know, wind energy production emits no dangerous criteria pollutants, no greenhouse gas pollutants, no mercury, and requires none of our limited water resources to create electricity.<a href="#_edn6">[vi]</a> <a href="#_edn7">[vii]</a> <a href="#_edn8">[viii]</a></p>
<p><a href="#_edn8"></a>By contrast, nearly five years after the first version of this coal plant project was announced, Tri-State Generation &amp;Transmission of Colorado (the entity that will own at least 80 percent of the proposed Holcomb coal plant), has publicly stated that the soonest construction would even begin for this plant would be 2016. <a href="#_edn9">[ix]</a></p>
<p>That’s a long time to wait for people who need jobs today.  Especially when we could have spent the last six years working together to create good, lasting jobs and industries built upon our own natural resources.</p>
<p>Of note, Tri-State’s own resource planning shows no need for baseload coal in their system until at least 2026.<a href="#_edn10">[x]</a> So, it could be an even longer wait for those construction jobs.</p>
<p>Indeed, in 2004 Sunflower Electric had a permit in hand for the Sand Sage coal plant, and they chose to abandon that project.<a href="#_edn11">[xi]</a> If jobs and energy production are the priorities, that project could already be providing both.</p>
<p>In Kansas we need to make the right choices, the smart choices, for both jobs and energy. That means developing our own native resources, both natural and human.</p>
<p>Kansas should not let itself be manipulated by Wyoming coal companies, a Nebraska-based railroad and a Colorado utility that all stand to make millions while Kansas is left with depleted water resources and air pollution that will poison our children and grandchildren.</p>
<p>In fact, Colorado-based Tri-State G&amp;T has already funneled at least 52 million dollars to its Kansas partners to push this project,<a href="#_edn12">[xii]</a> and we can find no indication that that substantial amount of money has yet to produce any jobs for Kansas workers.</p>
<p>Our members believe it is time to look to the future, and not to the past, and to look to Kansas and not other states, for energy generation and related economic development in Kansas.</p>
<p>Thank you for your diligence regarding this manner, and for the difficult work you do protecting the most precious assets Kansas possesses.</p>
<p>Thanks also to the Blue Valley School District and the staff of Blue Valley Northwest High School for allowing this venue to be used for such an important public event.</p>
<p>Scott Allegrucci</p>
<p>Great Plains Alliance for Clean Energy</p>
<p>220 SW 33<sup>rd</sup> Street, Suite 200</p>
<p>Topeka, KS  66611</p>
<p><hr size="1" /><a href="#_ednref">[i]</a>http://www.westarenergy.com/corp_com/contentmgt.nsf/publishedpages/emporia%20energy%20center</p>
<p><a href="#_ednref">[ii]</a> http://epa.gov/cleanenergy/energy-and-you/affect/natural-gas.html</p>
<p><a href="#_ednref">[iii]</a> http://www.cleanenergyfortexas.org/downloads/Nolan_County_case_study_070908.pdf</p>
<p><a href="#_ednref">[iv]</a> http://www.reporternews.com/news/2008/jul/11/nolan-county-economy-soars-wind-industry/</p>
<p><a href="#_ednref">[v]</a> http://www.sweetwaterreporter.com/content/view/100663/60/</p>
<p><a href="#_ednref">[vi]</a> http://www.awea.org/pubs/factsheets/EmissionKB.PDF</p>
<p><a href="#_ednref">[vii]</a> http://www.windpoweringamerica.gov/pdfs/policy/wind_air_emissions.pdf</p>
<p><a href="#_ednref">[viii]</a> http://www.epa.gov/cleanenergy/energy-and-you/affect/non-hydro.html#wind</p>
<p><a href="#_ednref">[ix]</a> http://www.forbes.com/feeds/businesswire/2010/05/27/businesswire140299764.html</p>
<p><a href="#_ednref">[x]</a> http://www.tristategt.org/ResourcePlanning/ResourcePlanDoc.cfm</p>
<p><a href="#_ednref">[xi]</a> http://www.kdheks.gov/download/Application_Timeline.pdf</p>
<p><a href="#_ednref">[xii]</a> http://www.tristategt.org/Financials/annual-report.cfm
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		<title>Public Hearing in Salina Scheduled for Sunflower Coal Plant</title>
		<link>http://www.gpace.org/news/public-hearing-in-salina-scheduled-for-coal-plant-hearing/</link>
		<comments>http://www.gpace.org/news/public-hearing-in-salina-scheduled-for-coal-plant-hearing/#comments</comments>
		<pubDate>Sat, 31 Jul 2010 19:43:39 +0000</pubDate>
		<dc:creator>Kelly</dc:creator>
				<category><![CDATA[News]]></category>
		<category><![CDATA[air quality]]></category>
		<category><![CDATA[coal-fired power plant]]></category>
		<category><![CDATA[GPACE]]></category>
		<category><![CDATA[Great Plains Alliance for Clean Energy]]></category>
		<category><![CDATA[Kansas Department of Health and Environment]]></category>
		<category><![CDATA[Kathleen Sebelius]]></category>
		<category><![CDATA[pollution]]></category>
		<category><![CDATA[Scott Allegrucci]]></category>
		<category><![CDATA[Sunflower Electric]]></category>
		<category><![CDATA[Tri-State Generation and Transmission Association]]></category>

		<guid isPermaLink="false">http://www.gpace.org/?p=1710</guid>
		<description><![CDATA[A public hearing on the proposal is scheduled for Wednesday at the Kansas Highway Patrol training center. The hearing will begin at 2 p.m., with a break from 5 to 6:30, then resume until everyone has an opportunity to speak. <a href="http://www.gpace.org/news/public-hearing-in-salina-scheduled-for-coal-plant-hearing/">Continue reading <span class="meta-nav">&#8594;</span></a>]]></description>
			<content:encoded><![CDATA[<p><em>By Michael Stand of <a href="http://www.salina.com/News/Story/sunflower2010-07-30T03-07-23">The Salina Journal</a></em></p>
<p>In 2007, Kansas was temporarily in the world spotlight when Rod Bremby, secretary of the Kansas Department of Health and Environment, denied a permit to Sunflower Electric to build a new coal-fired generating plant in southwest Kansas.</p>
<p>The decision was so widely watched because it was the first time a permit had been denied because of the carbon dioxide a plant would emit; it declared carbon dioxide a health hazard.</p>
<p>Sunflower is once again looking to expand its generating capacity at Holcomb, this time seeking to build a far smaller, 895 megawatt plant, instead of the twin 700-MW plants it wanted to build a few years ago.</p>
<p>A public hearing on the proposal is scheduled for Wednesday at the Kansas Highway Patrol training center. The hearing will begin at 2 p.m., with a break from 5 to 6:30, then resume until everyone has an opportunity to speak.</p>
<p>During the 2008 legislative session, Gov. Kathleen Sebelius vetoed three different bills seeking to overturn Bremby&#8217;s ruling, but after she resigned to become U.S. Secretary of Health and Human Services, Gov. Mark Parkinson met with Sunflower officials and reached a compromise.</p>
<p>Included in that compromise, said Clare Gustin, Sunflower&#8217;s executive manager for external affairs, was a much smaller expansion, as well as a commitment from Sunflower to develop more renewable energy sources.</p>
<p>The plant is a joint project between Sunflower and Colorado-based Tri-State Generation and Transmission Cooperative.</p>
<p>Among those opposing the plant expansion is Scott Allegrucci, executive director of the Great Plains Alliance for Clean Energy.</p>
<p>Allegrucci says that while the new proposal is significantly smaller &#8212; and will create less carbon dioxide &#8212; most of the objections to the earlier proposal still hold.</p>
<p>This isn&#8217;t exporting wheat</p>
<p>Allegrucci says the bulk of the power generated by the new plant will be used in Colorado, with Sunflower customers getting just 10 percent.</p>
<p>He acknowledges that Kansas exports lots of stuff, such as wheat, but says this case is different.</p>
<p>&#8220;We&#8217;re not exporting power,&#8221; he said. &#8220;Sunflower isn&#8217;t making power and then selling it on the market &#8212; essentially we&#8217;re hosting a coal plant for an out-of-state utility &#8230; Tri-State doesn&#8217;t want to fight this fight in Colorado.&#8221;</p>
<p>And in spite of Gustin&#8217;s assurances that Sunflower is committed to developing renewable energy sources, Allegrucci says the expansion would make it more difficult for wind and solar projects to gain a foothold.</p>
<p>&#8220;An overbuild of this size would flood our grid with coal-generated electrons, making (renewables) that much less economically feasible,&#8221; he said.</p>
<p>Why not natural gas?</p>
<p>He also questions why Sunflower wants to use coal to power the generators, saying he thinks natural gas would be better for a number of reasons.</p>
<p>&#8220;We have natural gas in Kansas, and they could be using that and keeping the money in Kansas instead of buying coal from Montana,&#8221; Allegrucci said. &#8220;Even if gas prices go higher, at least the money would be staying in Kansas.&#8221;</p>
<p>Gustin says choosing coal over natural gas is a sound business decision. Utilities typically use coal for so-called &#8220;base load,&#8221; because coal-fired plants must run constantly, and use gas-fired plants &#8212; which can be turned off and on almost at will &#8212; to handle peak loads only, because gas is more expensive.</p>
<p>&#8220;We&#8217;re not just biased toward coal,&#8221; she said, adding that the expansion is a 30- to 40-year investment, and that the company thinks coal prices will be more stable over that time.</p>
<p>Who will buy the power?</p>
<p>Allegrucci also says the plant isn&#8217;t needed now, even by Tri-State, and that Tri-State&#8217;s own projections say it won&#8217;t need the power until 2026.</p>
<p>But Gustin says a contract Westar has to buy 174 MW of power from Aquila expires in 2018, and Westar will need to get that power from somewhere else.</p>
<p>Allegrucci also said it&#8217;s possible the federal government might step in to stop the plant expansion, even if state officials approve it.</p>
<p>In 2007, the U.S. Supreme Court ruled that the EPA could regulate carbon dioxide, and Allegrucci said the agency intends to start doing just that beginning in January.</p>
<p>Exactly how that regulation will unfold remains to be seen, Allegrucci said, adding that the EPA has already required one plant in Kentucky to use natural gas instead of coal, because it creates less carbon dioxide.</p>
<p>&#8220;Basically, Sunflower is racing to get their permit before January 2011,&#8221; he said.
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