Purpose of This Report

The purpose of this Report is to provide Lane Regional Air Protection Agency, Seneca Sustainable Energy, LLC and Oregon Toxics Alliance with a list of formal human rights norms of concern associated with the permitting of Seneca’s proposed power generation plant, to outline LRAPA’s and Seneca’s potential liabilities and to describe pathways that can be taken to reduce those liabilities.

Facts

Lane Regional Air Protection Agency is the agency charged with regulating impacts on air quality within the Lane County regional airshed. LRAPA has prepared a draft permit for Seneca Sustainable Energy, LLC to operate a proposed 18.8 MW cogeneration power plant to be located just south of Enid Road, east of Highway 99 and co-located with the existing Seneca sawmill.

The cogeneration plant would employ a wood-fired boiler to produce steam for an 18.8 MW steam turbine. Fuel for the boiler would principally be sawdust from the Seneca sawmill and trucked in woody biomass (trees and slash from forestry operations).

According to LRAPA’s draft Air Contaminant Discharge Permit Review Report (dated 6-29-09), air emissions from the proposed plant would include 187 tons per year of NOx, 39 tons per year of SO2, 202 tons per year of CO, 39 tons per year of VOCs, 6 tons per year of Acetaldehyde, 17 tons per year of various Hazardous Air Pollutants, including 1.7 tons of formaldehyde, and 14 tons per year of PM/PM10/PM2.5.

According to data in the Eugene-Springfield Consolidated Plan 2005, West Eugene neighborhoods within a five mile radius of the proposed power plant have a disproportionately high percentage of minority populations, a disproportionately high poverty rate, and a disproportionately high percentage of disabled residents, compared to minority, poverty and disability rates in Eugene’s overall population.

Oregon Toxics Alliance is a 501(c)(3) non-governmental organization, chartered in the state of Oregon, whose mission is to understand and expose root causes of pollution and to assist communities in efforts to protect human and environmental health. OTA is concerned about potential degradation of regional air quality and about maldistribution of adverse health impacts on residents of adjacent neighborhoods.