Action: Contact the U.S. Environmental Protection Agency (EPA) via Sierra Club’s alert page – ask EPA to fulfill its responsibility to the public, oppose a corrupt and politically-influenced permit process, and hold the Kansas Department of Health and Environment (KDHE) accountable for a botched permit.

Another action you may take is to contact Kansas Attorney General Derek Schmidt and request that his office investigate the Holcomb coal plant permitting process to determine whether there was any illegal misconduct, beyond the unethical collusion between Sunflower Electric (Sunflower) and KDHE.  CREDO Action has set up a page where you can sign on to a petition to Attorney General Schmidt.

Why: Recent reporting by the Kansas City Star shows Sunflower gamed the public comment process for the “Holcomb” coal plant permit, unethically influencing – even controlling – KDHE responses to public comments expressing opposition to the project.

Bottom line: Sunflower colluded with the Kansas agency responsible for public health and environment in order to ignore public input on an unnecessary and dirty coal plant for Colorado, and rush a permit for the project ahead of federal greenhouse gas regulations.

You knew it was bad.  But perhaps you didn’t know just how bad it was .

The Kansas City Star obtained some of the hundreds of emails between KDHE and Sunflower that indicate Sunflower staff, attorneys, and consultants drafted KDHE responses to public comments submitted during the permitting process last summer and fall.  Thousands of Kansans – an unprecedented number, in fact – worked very hard to participate in the permitting process and deserve better than a rushed, unethical process that Sunflower itself was improperly allowed to control.

You read that right. According to the Star, “the department allowed Sunflower to respond to questions from the public and then passed some of the answers off as their own.”

In the wake of the Parkinson settlement agreement and while under intense political pressure from Governor Parkinson’s office, Sunflower – the applicant for a pollution-control permit – was allowed to draft responses to public comments on behalf of the state agency that granted that permit.  KDHE then officially published responses to public comments – created by Sunflower - as the official responses from KDHE and the Acting Secretary.

GPACE’s own review of the emails indicates a number of troubling, unethical patterns.  Clearly Sunflower was acting as an extension of KDHE in terms of the permit review process – there was no effective barrier between the goals of the private-sector applicant and the public-sector agency – and therefore no credible, objective review of the permit or the public comments related to it.  In fact, after Parkinson fired former KDHE Sec. Rod Bremby, the emails indicate that Wayne Penrod of Sunflower was effectively calling the shots for KDHE on how to respond to specific public comments and the schedule for the permit review and ultimate approval.

In addition, Sunflower was given unfair and exceptional access to the public comments, and even converted some of them to editable file formats in order to develop responses for KDHE.  As such, there may be no way to be certain that KDHE published responses to the actual public comments submitted.

Since polluters, special interests, and politicians at the highest levels have thoroughly corrupted the permit process in Kansas, EPA and the state’s ranking law enforcement officer have a legal and ethical obligation to intervene on behalf of the rest of us.

This recent revelation marks a sad day for the rule of law in Kansas – not to mention the health and well-being of generations of Kansans.

But it gives you another opportunity to set things right.  Contact EPA and Attorney General Schmidt now and let them know you expect nothing less.

Forward this GPACE Take Action page.  Don’t let your extraordinary efforts and your right to to be heard and considered by your public agency be taken from you.

You can take additional action that will be very helpful.  We need reporters, editors, and publishers to understand that the public is interested in this issue.  Can you take a few minutes to help promote the KC Star story? Here are some quick and easy things you can do to help.

• Forward the story link and ask others to do the same.
• Post comments below the story on the KC Star website.
• Re-post the link to Facebook, Twitter, and other online outlets you have access to.
• “Like” the story on Facebook.
• Submit a letter to the editor of the KC Star on the story.  If you want a few pointers, instructions, or talking points, we’re happy to help out!  Feel free to get in touch with us at info@gpace.org.  Also check out the additional information links below, and other resources on our website.  Suggested talking points:
  • The permit for the Sunflower coal plant was the most controversial permit KDHE has ever considered.  Despite this, KDHE allowed Sunflower unfair control over the permitting process, reviewed a record number of comments in less time than ever before, and issued  a permit under intense political pressure.
  • Thousands of people, including me (if applicable), participated in the permitting process with expectations that our input would be considered by KDHE in a fair manner.
  • Thank you to the (LJ World or KC Star, whichever is appropriate) for your editorial on the Sunflower coal plant permitting process.  As a citizen who worked hard to participate in the process and submit comments (if applicable), I was deeply discouraged by reports that KDHE allowed Sunflower the ability to respond to public comments.  I expected KDHE to review my comments, not Sunflower.
  • KDHE has failed to adequately protect the health and environment of Kansas, and the EPA has an obligation to act in this case and object to the permit KDHE issued to Sunflower.
  • EPA promised Kansans a fair permitting process.  As the KC Star’s research indicates, a fair process is not what led to the permit approval.  It is time for EPA to make good on its word.

• Email Karen Dillon (kdillon@kcstar.com - the KC Star reporter) and thank her for her investigation into this matter.

For additional background on how Sunflower, Tri-State, Kansas elected officials, and an army of special interest lobbyists have corrupted the Holcomb coal plant process, see:

http://www.gpace.org/news/kdhe-was-a-lapdog/

http://www.gpace.org/news/failed-duty/

http://www.gpace.org/news/a-polluted-process-by-mark-parkinsons-administration-on-sunflower-permit/

http://www.gpace.org/blog/gaming-the-system-to-get-a-coal-plant/

http://www.gpace.org/blog/brembys-firing-could-derail-the-coal-plant/

http://www.gpace.org/blog/a-coal-plant-over-the-rainbow-the-parkinson-kdhe-sunflower-electric-mess/

http://www.gpace.org/blog/the-cleanest-coal-plant-in-the-country-not/

http://www.gpace.org/blog/the-coal-plant-boondoggle-goes-to-washington/

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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.

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.

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.

Scott Allegrucci, director of the Great Plains Alliance for Clean Energy, said he and his organization do not disagree with the governor’s intentions. But he raises the key question.

“(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?” Allegrucci told The Sun.

Quite correctly, Allegrucci expresses dismay about the effects a new coal plant in western Kansas will have on wind power.

That coal facility near Garden City “will clog our (transmission) grid, which could retard wind development for the western part of the state,” Allegrucci said.

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.

Allegrucci also points out that incentives for placing new transmission lines through sparsely populated areas are few.

“And the reality is that in Kansas the real high wind density is in the southwest 25 percent of the state … where there aren’t lines” or many people, Allegrucci said.

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?

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.

Or, as Mr. Allegrucci asks, “Where is the yes to wind energy?”

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For more of Richard Crowson’s work, visit his website.

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We’ve been told by supporters of the proposed Sunflower Electric Power Corporation / Tri-State Generation & Transmission Holcomb Station coal-fired power plant that it will be “the cleanest coal plant in the country.”  For example:

“The BACT analysis has been refreshed.  It’s the cleanest coal power plant in the country.  That’s clean.  If it’s not, it’s something that we should all be ashamed of.”  Wayne Penrod, Executive Manager of Environmental Policy for Sunflower Electric Power Corporation (10/25/2010 – Topeka, KS, KDHE public permit hearing)

“Best Available Control Technology is required, so that means that when a new power plant is built, whatever kind of power plant, it will be the cleanest power plant in the world at that time.”  Forrest Knox, Kansas House of Representatives, District 13 (8/2/2010 – Overland Park, KS, KDHE public permit hearing)

“Bottom line, this will provide badly needed jobs for Kansas and will be the cleanest coal plant in the nation.”  Richard Taylor, President, Kansas State Building & Construction Trades Council (8/2/2010 – Overland Park, KS, KDHE public permit hearing)

Umm…No.  Not Even Close.

In reality, this simply isn’t true. Using Environmental Protection Agency (EPA) and U.S. Energy Information Administration (EIA) data, the KDHE permit for Holcomb 2, and working with MSB Energy Associates and the Natural Resources Defense Council, the Great Plains Alliance for Clean Energy (GPACE) compared four of the most common and troubling emissions from Holcomb 2 and other coal-fired generating units in the country.  In fact, there are currently hundreds of coal-fired units in the country that are already emitting fewer harmful pollutants than the recent KDHE permit allows the proposed Holcomb 2 coal-fired unit to emit.

Here’s what we found:

There are already at least 669 coal-fired units in the country that emit lower rates of particulate matter than the current KDHE Holcomb 2 permit allows (including the Hawthorn and Sibley coal-fired units in Missouri, and Jeffrey Energy Center in Kansas).

There are already at least 321 coal-fired units in the country that emit lower rates of mercury than the current KDHE Holcomb 2 permit allows (including the Comanche and Cherokee coal-fired units in Colorado).

There are already at least 53 coal-fired units in the country that emit lower rates of sulfur dioxide than the current KDHE Holcomb 2 permit allows (including Iatan 1 in Missouri and Jeffrey Energy Center in Kansas).

There are already at least 18 coal-fired units in the country that emit lower rates of nitrogen oxides than the current KDHE Holcomb 2 permit allows (including the W.A. Parish and J.K. Spruce coal-fired units in Texas).

Additionally, there are a number of coal-fired units recently permitted or operational that are not included in the comparative data but that have lower emissions rates than allowed for Holcomb 2.  These projects certainly beat Holcomb 2 in terms of lower toxic pollutant and GHG emissions rates:

• KCP&L Iatan 2 unit in Missouri
• SWEPCO Turk unit in Arkansas
• Duke Energy Cliffside Steam Station in North Carolina
• Plant Washington in Georgia

Given the conflict over air quality permitting currently raging between EPA and the State of Texas, it’s notable that a number of the coal plants that are already “cleaner” than Holcomb 2 are in Texas.  EPA has already done some deal-making to grandfather specific coal plants under older air quality regulations.  However, recent communications from EPA suggest that the agency is drawing a bead on the deficient KDHE permit for Holcomb 2, as well as the political gaming of the process to benefit Sunflower and force the permit.

In a letter date-stamped February 3, EPA notes that KDHE did not respond adequately to concerns about the permit expressed previously by EPA.  The concerns about the permit outlined in the letter focus primarily on emission allowances for Nitrogen Oxides (NOx) and Sulfur Dioxide (SO2).  Furthermore, the letter clearly states that EPA “disagrees with KDHE’s interpretation of federal law” on the issue of ensuring new National Ambient Air Quality Standards (NAAQS).

As GPACE and others have noted before, it will be interesting to see if EPA considers Kansas air quality, public health, and regulatory processes in the public interest on par with Texas’, when reviewing the problematic KDHE permit process that allowed comparably inferior emission control technology for Holcomb 2.

Spin All You Want, But…

There is no such thing as “clean coal.”  All coal-fired power plants emit dozens of dangerous substances, including volatile organic compounds, radioactive elements, heavy metals, and substances known to cause heart disease, lung disease, mental retardation, cancer, and premature death.  Here’s a little more information about the four coal plant emissions we chose to compare:

Particulate matter (PM) has serious effects upon human cardiovascular, respiratory, and neurological systems, including heart palpitations, congestive heart failure, lung cancer, and premature death.

Mercury (Hg) is an extremely potent and dangerous neurotoxin that lingers in the environment and human tissue and increases in concentration as it moves up the food chain.  Increased levels of mercury in humans cause reduced IQ, mental retardation, and impaired neurological development.

Sulfur dioxide (SO2) contributes to respiratory ailments and ischemic stroke, and creates acid rain, which has destructive and costly impacts upon infrastructure, agriculture, and habitats.

Nitrogen oxides (NO2) contribute to acid rain and are ozone precursors that affect the respiratory system, exacerbating asthma and causing chronic obstructive pulmonary disease and stunted lung development in children.

While a few coal plants under construction or recently permitted are attempting to reduce greenhouse gas (GHG) emissions, the KDHE permit for Holcomb 2 requires absolutely no emissions controls in place for carbon dioxide (CO2) or other GHG emissions, nor does the permit include any GHG or other pollution mitigation requirements as suggested by the former KDHE Acting Secretary and former Gov. Parkinson.  A worldwide body of scientific research shows that CO2 is a major contributor to global climate change, which will in turn have significant and irreversible impacts upon human health, agriculture, industry, the economy, water access, transportation, population densities, travel and migration, and the availability of natural resources.

Sunflower has asserted that the Holcomb Station will be a “clean coal” plant, but company representatives also told state legislative committees and KDHE that there is currently no technology to affordably and effectively reduce GHG emissions from coal combustion units.  The recently granted permit for the Holcomb 2 unit does not employ the best available technology to reduce harmful source-point emissions, nor does it obligate Sunflower to make any effort to control or reduce GHG emissions.

Sunflower has touted a “bio-energy” center as part of the Holcomb Station expansion.  The centerpiece of the project was to be a so-called “algae reactor” that Sunflower claims would capture CO2 emissions from the coal plant(s) to be used as feedstock for a massive algae process producing biofuel.  Because the technology is experimental and since the biofuel would then be burned, re-releasing the CO2, it is not certain that this process would result in an overall net reduction in carbon emissions.

In 2008, the Salina Journal investigated Sunflower’s algae reactor claims, revealing the proposed algae project to be essentially smoke and mirrors.  The proposed algae reactor would require a surface area of between 16,000 and 35,000 acres – more than five to ten times the area of Kanopolis Lake – and could cost more than $16 billion – over five times the cost of the coal plant itself.   Where the funding or the water would come from to make this unproven and highly experimental technology work in southwestern Kansas has never been specified.

Sunflower’s KDHE permit does not include the algae process nor does it obligate Sunflower to achieve any GHG emissions reductions.  Sunflower’s own plans called for the experimental algae system to be attached to the existing Holcomb 1 coal plant, never as part of the proposed Holcomb 2 unit, involving less than 50 MW of energy capacity (and emissions) from Holcomb 1.  Furthermore, GreenFuel Technologies, Sunflower’s partner in developing the algae process, has since gone out of business and filed for bankruptcy.  The experimental algae reactor technology is not and is not anticipated to be in use at utility scale anywhere in the country.

Settlement Agreement Bait and Switch

The settlement agreement between Governor Parkinson and Sunflower initially called for the proposed coal plant to be an ultra-supercritical pulverized coal unit, which would have made it among the most advanced and efficient plants in the nation.  However, Sunflower applied for, and KDHE granted a permit for, only a supercritical unit, which is not advanced or leading technology for coal-fired power plants – it’s the current standard technology.

The air quality permit granted to Sunflower by KDHE does not sufficiently protect public health and the environment or fulfill promises made as part of the settlement agreement.  Under the KDHE permit, the proposed Holcomb unit will not be using state of the art processes that are already in place at other 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.

Former Gov. Parkinson already left the state for a well-paid job as a Washington D.C. lobbyist – so neither he nor his family will have to live with the impacts of pollution from this coal plant.  Sunflower CEO Earl Watkins is retiring in 2012 – we’ll see if he decides to live downwind of this plant.  Sen. Lee, who strongly supported the Holcomb coal plant project and who confirmed to reporters meetings with Parkinson’s office to pressure KDHE on the permit, gave up her elected Senate seat for a permanent state job courtesy of Parkinson.

“…It’s Something That We Should All Be Ashamed Of.”

Inaccurate claims by supporters of this coal plant that it will be the “cleanest coal plant in the country” have either been made in ignorance of the actual comparative facts, or to intentionally mislead the public about the impact of the project.  Either way, we agree with Mr. Penrod of Sunflower that they should be ashamed of such claims.

The KDHE air quality permit granted on 12/16/2010 for the proposed Holcomb Station coal-fired project will not result in the “cleanest coal plant in the country”, nor even reasonable inclusion as “one of the cleanest coal plants in the country.”  Based upon direct comparison of emission rates for four critical pollutants, the approved KDHE permit allows construction of a new coal-fired power plant in southwestern Kansas that will be dirtier than hundreds of existing coal-fired units currently in operation around the country, including existing units within Kansas.

Emissions from this plant will directly contribute to deaths and disease in Kansas for generations to come.  The full costs of this project will be paid by individuals and taxpayers in the form of urgent health care and human suffering.  In exchange for hosting this plant and its pollution, no Kansas energy resources (aside from our precious aquifer water) will be used to provide electricity, employment, or revenue for Kansans, while money and energy flow to Colorado and Wyoming.  It seems this is exactly what big special interests in those states wanted.

Given the political tactics and misinformation used to advance this project, one wonders how many other claims in support of this coal plant are simply not true.

Read the GPACE White Paper here.

Find supporting documents here.

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Recently The Associated Press uncovered an e-mail from Sunflower Electric to a group including legislators and the State Treasurer.

The e-mail accuses Kansas Department of Health and Environment Secretary Bremby of “gaming the process” for Sunflower Electric’s coal plant permit, and requests contacting the governor’s office to pressure KDHE to shorten the process. The e-mail mentions scheduled meetings between some of these individuals and the governor’s office.

Regarding whether the process is being unnecessarily delayed, compare the timelines of the current and the most recent permit process.

The previous permitting process began on 6/1/2006 and concluded on 10/18/2007. It involved a public comment period over 80 days long and the full process took over 16 months. There are no recorded complaints from Sunflower or their supporters about the length of that process.

The current permitting process began on 6/30/10 and concluded on 8/15/10 when the first public comment period ended. That’s 46 days of public comment, and the full process would take less than 6 months if the permit is decided during this calendar year.

During the 2006/2007permitting process, KDHE received about 785 total public comments (verbal and written, pro and con). Prior to the most recent public hearings, KDHE had already received over 2,200 public comments on the current draft permit – excluding comments from the public hearings and more than 800 comments submitted between the public hearings and August 15th.

Incorrect data submitted by Sunflower means that an entire section of the permit remains unavailable for review. One wonders whether this was an intentional part of Sunflower’s strategy. Without that data there can be no conclusive analysis done on the permit, since adjustments to one part of complex emissions modeling can impact the entire permit. As such, the public has been unable complete a technical review of or offer all relevant comments on the current permit.

Presumptions that a final permit can be granted before the end of the year are just that – presumptions. Sunflower and their allies are forcing KDHE to take one-third the amount of time to review and respond to at least four times the number of public comments received compared to the previous permit review process.

According to the AP article, the governor’s office claims no involvement in the permitting process and no pressure from that office on KDHE. Yet one of the legislators on the Sunflower email confirmed that pro-coal allies met with the governor’s office, which then communicated with KDHE. And KDHE has now proposed a 30-day second comment period rather than the 45-day period they had announced at a 9/9/10 Joint Committee on Energy and Environmental Policy meeting.

It seems that those making the accusations of “gaming the system” are the very ones doing the “gaming.” Efforts by elected officials and others to pressure KDHE are potentially illegal, certainly unethical, and at the very least undermine the responsibility of the agency to objectively and fairly conduct the regulatory process in the interests of the public.

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TOPEKA, Kan. — A new coal-fired power plant in southwest Kansas is on track to obtain a state environmental permit by year’s end so that it wouldn’t have to comply with new federal rules on greenhouse gas emissions, officials confirmed Thursday.

Sunflower Electric Power Corp. had worried it might not get its permit until next year. Federal rules taking effect Jan. 2 require new power plants to use the best available technology for controlling greenhouse gas emissions blamed for global warming.

A legislative supporter of the project acknowledged Thursday “some angst” over the permitting process at the Kansas Department of Health and Environment. The department already has taken public comments about the plan for a plant outside Holcomb, in Finney County. However, it plans a second comment period because of problems with environmental modeling software used by the utility.

A key issue for Sunflower and environmentalists has been whether the new public comment period would last 30 days, the minimum required, or 45 days. Spokeswoman Kristi Pankratz told The Associated Press on Thursday the department decided on the shorter period and plans to announce it by the end of this month.

As for the permitting decision, Pankratz said, “We’re hoping to have that by the end of the year.”

State Sen. Janis Lee, a Kensington Democrat who strongly supports Sunflower’s plans, also said a decision should be reached by the end of the year in a normal permitting process.

“I believe that there was communication between the governor’s office and the secretary, and the decision was made on 30 days” for the comment period, Lee told the AP. Lee said the decision was made Wednesday.

Before the decision, Lee said, “There was some angst.”

Environmentalists see the shorter comment period as a sign the department is rushing a decision on whether Sunflower gets the air-quality permit it needs to build its plant.

In an e-mail dated Monday and obtained by the AP, Sunflower’s vice president of member service and external affairs, Clare Gustin, had accused department Secretary Rod Bremby of “gaming the process” to delay a permit. Cindy Hertel, a spokeswoman for the Hays-based utility, said the e-mail was an attempt to keep supporters of the project updated.

“My thought is to have multiple contacts with both the Governor and Bremby, hoping that someone can positively change this situation,” Gustin wrote.

Bremby rejected an earlier plan by Sunflower to build two coal-fired plants, deciding in October 2007, more than a year after his staff drafted a proposed air-quality permit. The proposed permit for the latest project was finished June 30.

The Monday e-mail said Democratic Gov. Mark Parkinson, who supports the project, was meeting Thursday with key supporters of the utility’s plans. AP confirmed meetings involving those mentioned in the e-mail, though Parkinson spokeswoman Amy Jordan Wooden said the governor isn’t involved in the permitting process.

Lee confirmed she had a Thursday meeting with Parkinson. An aide to State Treasurer Dennis McKinney, another Democrat who supports the Sunflower project, confirmed that he also was to meet with the governor, though she didn’t know the topic.

Jordan Wooden declined to discuss Parkinson’s non-public schedule. But she also said she’s not aware of any conversations between Parkinson and Bremby about the permitting process.

“This is a KDHE process,” she said. “We are not doing anything to slow down this process. We are not doing anything to accelerate this process.”

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The Kansas Department of Health and Environment is once again on the hot seat as Sunflower Electric Power Corporation seeks a permit for construction of a coal-fired power plant near the southwest Kansas town of Holcomb. The proposal, in one form or another, has been stirring up debate since 2006. Despite a radical scale-back of plans, the issue still seems to pit environmental concerns against economic growth. Health Reporter Bryan Thompson has more as part of our series, “Kansas Health: A Prescription for Change”.

Click here to listen to the full report.

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To the respected staff of the Kansas Department of Health and Environment:

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.

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.

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.

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?

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 – or, we do nothing.

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 – 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.

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.

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.[i]

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.[ii]

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. [iii][iv][v] 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.[vi] [vii] [viii]

By contrast, nearly five years after the first version of this coal plant project was announced, Tri-State Generation &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. [ix]

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.

Of note, Tri-State’s own resource planning shows no need for baseload coal in their system until at least 2026.[x] So, it could be an even longer wait for those construction jobs.

Indeed, in 2004 Sunflower Electric had a permit in hand for the Sand Sage coal plant, and they chose to abandon that project.[xi] If jobs and energy production are the priorities, that project could already be providing both.

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.

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.

In fact, Colorado-based Tri-State G&T has already funneled at least 52 million dollars to its Kansas partners to push this project,[xii] and we can find no indication that that substantial amount of money has yet to produce any jobs for Kansas workers.

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.

Thank you for your diligence regarding this manner, and for the difficult work you do protecting the most precious assets Kansas possesses.

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.

Scott Allegrucci

Great Plains Alliance for Clean Energy

220 SW 33^rd Street, Suite 200

Topeka, KS  66611

[ii] http://epa.gov/cleanenergy/energy-and-you/affect/natural-gas.html

[iii] http://www.cleanenergyfortexas.org/downloads/Nolan_County_case_study_070908.pdf

[iv] http://www.reporternews.com/news/2008/jul/11/nolan-county-economy-soars-wind-industry/

[v] http://www.sweetwaterreporter.com/content/view/100663/60/

[vi] http://www.awea.org/pubs/factsheets/EmissionKB.PDF

[vii] http://www.windpoweringamerica.gov/pdfs/policy/wind_air_emissions.pdf

[viii] http://www.epa.gov/cleanenergy/energy-and-you/affect/non-hydro.html#wind

[ix] http://www.forbes.com/feeds/businesswire/2010/05/27/businesswire140299764.html

[x] http://www.tristategt.org/ResourcePlanning/ResourcePlanDoc.cfm

[xi] http://www.kdheks.gov/download/Application_Timeline.pdf

[xii] http://www.tristategt.org/Financials/annual-report.cfm

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As a Prairie Village native and K-State alumnus, I have spent my life proud of my home state. Today, however, I have serious concerns for the citizens of Kansas and the future health of my family members who still live there.

In my public service as a utility regulator, I have learned a great deal about the intricacies of energy and electricity and the choices that exist for the future of both. Nothing is more risky today than coal. It is dirty and cannot affordably be cleaned up. Period.

Oklahoma rejected a risky coal plant and instead chose to rely on its own native blessings of wind and natural gas to power its future. Time has proven that to be the right decision, especially as gigantic and disastrous cost overruns are coming to light on the coal plant under construction in Illinois. Kansas ratepayers are facing the prospect of increased electric bills from cost overruns on Kansas City Power & Light Co.’s new coal plant in Iatan, Mo.

Meanwhile, native fuel sources of wind and natural gas native to Kansas can spur economic growth and forever provide cleaner electricity.

Wind power emits zero air pollution. It is rural Kansas’ greatest hope for an economic shot in the arm, and it is truly sustainable.

Natural gas is America’s cleanest reliable power source. It is abundant in Kansas and affordably keeps the lights on 24 hours a day across our country. Remember, Kansas exports natural gas to other states.

Yet, Kansas is now debating building a new coal plant in Holcomb, using Wyoming coal for the sake of Colorado utility customers. They can’t build the plant in Colorado, so they want to build it in Kansas.

Colorado will get the power, but the problems will remain with Kansas: Risky capital debt for the 60-year life of the plant, depletion of Kansas’ finite ground water, and massive amounts of dirty air and pollution across Kansas’ skies for the next three or more generations.

A new, massive coal plant in Holcomb makes no sense for a state that prides itself on common sense. Why would Kansas pollute our future, stall our own local, native energy economy and ship Kansas citizens’ money out-of-state for this dirty coal plant?

Because of the pollution expected from this proposed plant, Holcomb’s parent company, Sunflower Electric Power Corp., must obtain an air permit from regulators. That process is underway now and allows parents and grandparents a chance to stand and have their voices heard.

The public hearings begin at 2 p.m. Aug. 2 at Blue Valley Northwest High School in Overland Park. They continue Aug. 4 at the Highway Patrol Training Center in Salina, and Aug. 5 at Garden City Community College.

It’s time that clean air advocates speak out. It’s time for parents who want local Kansas’ energy jobs to exist for their children to speak out.

It’s time that Kansans stand up for Kansas, and I hope you will.

Jim Roth, an attorney and former member of the Oklahoma Corporation Commission, resides in Oklahoma City.

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