New Energy Future News

The following is in response to the Bureau of Indian Affairs’ August 20, 2007 request for comments on the Draft Environment Impact Statement (EIS) for the proposed Desert Rock coal-fired power plant.

These comments are respectfully submitted on behalf of Environment New Mexico, a state-wide environmental advocacy organization representing over 5,000 members state-wide.

Overall, we strongly believe that the Desert Rock Energy Project, proposed by Sithe Global Power, LLC, for the Navajo Nation in Burnham, New Mexico should not be permitted to move forward. The plant poses significant risks for the health of the local community, undermines global warming reductions being made elsewhere in the state, has failed to garner broad-based state and local support and does little to create economic opportunity or increased electrification of the Navajo Nation. In a world faced by the threat of global warming, building another coal-fired power plant is an environmentally and economically disastrous investment. Environment New Mexico strongly opposes the construction of Desert Rock.

The following lays out some specific assessments regarding the content of the Draft EIS:

Global Warming Emissions from the Proposed Desert Rock Facility Threaten New Mexico’s Climate:

Scientists agree that global warming is real, that it’s already affecting the planet we live on and that we need to reduce our global warming emissions by at least 80% by 2050 if we’re to avoid the worst consequences of a warming planet. The scientific community agrees that the evidence is “unequivocal” and we need to quickly and dramatically reduce our emissions.

Carbon dioxide, which is produced by coal-fired power plants, is a major contributor to global warming. The state of New Mexico has taken significant steps to reduce the state’s emissions including the formation of the New Mexico Climate Change Advisory Group (CCAG), work to create a Western regional greenhouse gas reduction program and expansion of the renewable energy portfolio standard. Given this, it is absolutely imperative that we halt and reduce emissions in the Four Corners region.

Existing carbon dioxide emissions in the Four Corners region include 15.6 millions tons per year (tpy) from the Four Corners and 13.4 million tpy from the San Juan plants for a total of 29 million tpy of carbon dioxide. Although portrayed as a “clean, state of the art coal-fired power plant,” Desert Rock is projected to emit over 12.7 million tpy of carbon dioxide into the atmosphere. The proposed Desert Rock facility would effectively wipe out all positive actions that New Mexico is taking to reduce greenhouse gas emissions.

The Draft EIS does not introduce any analyzed alternatives that would reduce carbon dioxide emissions from the proposed Desert Rock facility. Instead, despite scientific consensus to the contrary, the draft EIS discusses the concept of “global dimming,” an idea which purports that continued emissions may actually have a beneficial cooling effect on the planet. There is minimal and inadequate analysis in the Draft EIS of the environmental impact from greenhouse gas emissions and consideration of best available control technology to minimize carbon dioxide emissions as a result of the proposed Desert Rock facility.

Air Pollution Emissions from the Proposed Desert Rock Facility Threaten Public Health:

Environment New Mexico’s concerns go beyond global warming, however; we are also extremely concerned about the direct public health costs to the Four Corners region. The Navajo Nation is currently disproportionately burdened with a legacy of pollution from the Four Corners Power Plant, the San Juan Generating Station and tens of thousands of existing and projected natural gas wells and uranium mines in the Four Corners region.

The proposed Desert Rock facility is certain to exacerbate health and environmental problems. Projections indicate that Desert Rock would contribute more mercury into the atmosphere, compounding problems already associated with the Four Corners Power Plant (1,174 pounds of mercury emissions in 2000) and San Juan Generating Station (1,194 pounds of mercury emissions in 2000). Mercury is already accumulating in the area’s waterways. Recent information from the EPA suggests that the Navajo Nation would potentially have a mercury allowance of 1,200 pounds per year, potentially making the Four Corners a mercury hot spot. Proposed mercury emissions from the Desert Rock facility would only add to significant, cumulative public health impacts that are unacceptable to the region.

Moreover, the Draft EIS clearly states that Desert Rock power would be marketed for sale in Phoenix, Tucson and Las Vegas. The Draft EIS also states that the Four Corners area has disproportionate public health impacts associated with the existing environmental conditions in the region. The public health of citizens in the Four Corners region should not be compromised in order to provide cheap power to out-of-state consumers.

The Draft EIS Fails to Analyze a Reasonable Range of Alternatives:

The Draft EIS for Desert Rock fails to fully analyze potential alternatives including renewable energy options, demand-side management and energy efficiency in comparison to the proposed Desert Rock project, options that preclude the need to build additional coal-fired power plants in New Mexico. Given the recent implications of the Supreme Court ruling that EPA should regulate carbon dioxide, the Draft EIS is deficient.

The Scope of the Analysis in the Draft EIS is Inadequate:

The Draft EIS fails to include complete information or analysis on coal mining, water quality, impacts to surface water, groundwater testing, transmission of power and cumulative impacts. These are significant matters virtually absent from the discussion of the proposed plant, but which could significantly impact the environment, public health and the economics of the project.

Thank you for your consideration of these comments.

Respectfully submitted,