HomeMy WebLinkAboutCOM 0710.142 2010-2012 COUNTY CI._ERK
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2012 J11:' 21 Al 10: 50
Field Code Changed
estimony For June 19,2012 Hearing
i1l 256,Draft 2,and Bills 257 and 267)
On behalf of Puna Geothermal Venture and its parent company Ormat Technologies,
Inc.,we wish to provide these comments relating to Bill 256,Draft 2 and the recently introduced
Bill 267. We also speak to Bill 257.While the intentions of Bills 256 and 267 may be worthy of
consideration,it is PGV's position that the information which has been provided thus far,and the
language of those bills require serious reconsideration,given the unintended impacts of the
current language of the bills.
At the outset,we wish to make clear that PGV's and Ormat's number one concern is
public health and safety,wherever it operates,and we support the concept of conducting
comprehensive health studies for persons residing near the PGV plant and in the East Rift Zone.
However,this common goal can be accomplished without concluding that a"buffer"is
necessary,before the studies are completed.
As a general background, Ormat's experience in the field includes the fact that Ormat
has provided some 90%of the mainland's geothermal plant technology in the past ten years. It
has over 380 MW of installed generating capacity in New Zealand,over 500 MW in the
mainland in operation or under construction,and has built or supplied over 1370 MW
worldwide.Its experience in the field of exploration,plant technology,construction and
operation is unparalleled.
As for the Kapoho plant,PGV operates under some of the most stringent air emission,
water quality and noise standards established by the Environmental Protection Agency and the
Department of Health in Hawaii. It has 35 point source air monitors on site,and 3 air and noise
monitor stations on the perimeter of the plant facility,all of which can be viewed on the
company website,and records of this data are maintained by the Department of Health.
Air and noise monitors establish that PGV's operations are in compliance with health and
safety standards. The hydrologic monitoring program is conducted by the State Safe Drinking
Water Branch,and no deposits or leaks have occurred. Double and triple well casings together
with advanced blowout protectors exist at the wellsites to prevent what occurred in 1991. Since
then,PGV has drilled 7 wells,with no blowout.
Geothermal brine is reinjected back to its origin,well below the fresh water table,which
already has chemical composition affected by magmatic chemicals having nothing to do with
PGV's operations. PGV has consistently been in compliance with DOH and EPA standards and
regulations which have been established in order to assure that the health and safety of the public
is protected. As the Council is aware,more detailed information about PGV's operations and
safety protocols will be provided on these matters on July 2.
Before we proceed to more specific comment on the bills,some general perspective on
the issue of geothermal's role in this island's energy future is also in order.First of all,while
there has been talk about shipping geothermal energy to other islands,Ormat's goals have been
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to assist in Hawaii Island's energy needs. It has not entered into any contracts or agreements to
produce power to ship off island,nor advocated this. Geothermal is a critical element of our
renewable energy in Hawaii.While solar and wind are important components in a renewable
energy grid, firm load-following capable energy must be available when the sun goes down and
wind speeds vary,and geothermal is the only proven source which can provide such energy.
While individual photovoltaic systems have an important place,most consumers do not have the
money to buy such systems.
People also forget that geothermal is a much cleaner source of energy than diesel or
biomass plants,and the 38 MW which PGV is contracted to provide to HELCO displaces an
estimated 300,000 barrels of oil per year,and provides in excess of 20%of the island's energy
needs,substantially lowering greenhouse gas emissions.With the additional 8 MW that have
been recently added,additional royalties will be paid,and much of the 38 MW is now being
supplied to HELCO at rates lower than the former avoided cost structure. These reduced rates
are being passed on to consumers.
Customers can now plug electric vehicles in at night at a further reduced rate. Looking
forward,we have the potential to support the growing energy need for cloud systems for
information technology and knowledge based industry at all hours of the day,use off peak or
evening power generation capability to produce hydrogen fuel,and put this resource to other
potential uses which our imaginations can expand on.
Now to the bills and the information which has driven them along up to this point. If
passed,they have the potential effect of not only creating impediments to accomplishing the goal
of providing a renewable energy grid,but can have more immediate effects of creating a specter
of public health risk that is unjustified. The bills and the manner in which incorrect information
has been presented in support of the bills also have the real potential of reducing the county's
real property tax base in a wide area,and devalue property for residents who have no desire to
relocate and invested their lives in the area.
Unfortunately,claims have been made that health issues are attributable to PGV's
operations without the benefit of accepted scientific or medical evidence,in the limited context
of a forum which has not been conducive to obtaining detailed factual information relevant to the
issues from all concerned. PGV/Ormat have not been given the opportunity that others have had
to make a presentation that was provided to others. Basing your decision on the current level of
information,without first hearing from the Department of Health.DLNR and other agencies with
expertise in the field needs to be reconsidered.
We have already presented a health risk assessment by the Senior Toxicologist for the
Agency for Toxic Substances and Disease Registry of the US Department of Health and Human
Services,which unequivocallyy concluded that the PGV plant operations do not pose a public
health hazard. At the request of some members of the Council,we have provided daily air
monitoring data which establishes that during normal operations in 2011,hydrogen sulfide levels
at the plant perimeter were essentially at 0 ppb for the past year,which shows there is a serious
disconnect between plant operations and health concerns.While a lightning strike in November
2011 required the wells to be shut in and a temporary spike of 23 ppb occurred during an
approximately one hour period,this is a level substantially lower than numerous health
guidelines for acute,or even chronic,exposure. For example,the OSHA standard for limiting
exposure to employees,when eye irritation might be expected to occur,is set at 10.000 ppb.
Other misinformed statements have been repeated. Examples of such statements are:
That there is an industry wide standard 10 mile buffer between geothermal plants and
residential areas.FALSE: No such standard has been provided to you because it does not
exist. As one example,Ormat operates an 86 MW plant in the city limits of Reno, NV
located in close proximity to residential locations. California has some 1000 MW on line
and no such buffer standard,even though it also has stringent air quality standards.
The November 2011 lightning strike damaged well casings.FALSE: In fact,the strike
damaged power lines,and when this occurred,as a safety procedure,PGV shut its wells
in.Well casings sustained absolutely no damage.
The catalytic sulfite process contains lead and arsenic.FALSE: In fact,no such chemicals
containing lead or arsenic are present.
There was no EIS prepared for the plant.FALSE: In fact,one was prepared in 1987,
before the plant opened,even though agencies had not required such a study when the
GRP was obtained.
That any increases in generating capacity will be transmitted to neighbor islands.FALSE:
This is not PGV's or Omat's plan,which is to provide for this island's energy needs,
when required.
That PGV has no evacuation plan.FALSE: In fact,it has always had one for the plant,
but does not have jurisdiction to dictate the circumstances under which the public should
be evacuated. It maintains communication with civil defense,fire and police,and has
always been ready to cooperate in developing a coordinated plan with these agencies.
We will continue to assist Civil Defense and the other agencies in developing an
evacuation plan outside the plant.
Most troubling are the assertions that PGV's operations have caused health issues for
residents in the vicinity. While easy to make such an assertion,to date,no such health claims
have been made against the geothermal asset fund,to which PGV has contributed$50,000
annually,and now totals over$2 million,due to the lack of claims against the fund.The
County's rules correctly require that any such claim be substantiated by medical or scientific
evidence,such as physician and expert opinions.
PGV supports the idea that comprehensive health and epidemiological studies conducted
by competent experts in the field should be made for people residing within close proximity to
the PGV plant,as well as other areas within the rift zone. Such studies should include the
analysis of the numerous factors which may contribute to health issues of residents,such as vog,
living in proximity to natural vents,the type of drinking water available,family history,lifestyle
habits,diet,etc. PGV also supports the concept of having air monitors outside the plant site,and
is of the belief that such monitors will continue to verify the integrity of its operations.
On the other hand,the current language of Bill 256 contains unwarranted inferences or
implications that indicate public health and safety concerns must already now be mitigated,that a
"buffer"is necessary,or that once acquired by the County under the relocation program,
dwellings in the vicinity are not to be considered habitable, before any such study has been
performed. In fact,there are a substantial number of people who have chosen to reside and stay
in close proximity to the plant for years. Purchasing and then destroying houses would be an
irrational waste of resources.Current reference to the 1991 blowout incident is not warranted,
given safeguards which have been implemented since then,except to remind us that we do need
to remain vigilant.
If the Council is still inclined to move forward with the adoption of a form of Bill 256,
we have previously circulated another draft of a bill,which contains language which
accomplishes the goal of conducting a public health study that properly accounts for analysis of
the numerous factors that may affect the health of residents living in the rift zone,but which does
not unjustifiably target PGV or condemn nearby communities in the process.
Shifting community benefits in the relocation fund to relocation and health studies,and
shifting use of the geothermal asset fund to community benefits is unnecessary. Taken together.
Bills 256 and 267 switch the purposes of the funds which already provide these options, but with
questionable outcomes.Cost estimates should first be obtained to determine if the$2 million in
the geothermal asset fund is sufficient to fund the recommended health studies and air
monitoring stations,without dipping into royalties. The geothermal asset fund is already
intended for impact mitigation under the GRP and County ordinance. Changing the fund's
purpose raises issues which extend to the GRP's specific designation for use of the funds.
Moreover,while the purpose of Bill 267 to include scholarships is laudable,this is not an
impact mitigation expenditure. The Council and the public should be aware that in addition to
the royalties and geothermal asset fund payments made by PGV,it has already been funding
scholarships to Pahoa high school graduates,in addition to numerous community,cultural and
youth programs. We have provided you with a summary of just some of PGV's contributions to
the community. PGV will continue giving back to the community in this manner.Taking away
from the community benefit fund which geothermal royalties provide,on the other hand,is
unnecessary. Community benefit funds using such royalty money paid by PGV have recently
been used to purchase Hele On buses,to improve the Pahoa Transfer Station,the paving of
Mainstreet Pahoa Town Road,and other benefits.
In closing,we reiterate that PGV will continue to strive to be a good neighbor and remain
conscientious in assuring that clean,safe and reliable renewable energy can be provided to the
Big Island. Should any members of the Council want specific information about operations.we
have already provided contact numbers,as well as contact information of regulatory authorities
who oversee PGV's operations.
We appreciate the support which PGV has been given by agencies.officials, and
members of the public who understand the issues and appreciate PGV's safety track record with
Ormat's involvement.Thank you for this opportunity to provide this information. If you have
questions,please let us know.
Thomas Yeh,
Counsel for Puna Geothermal Venture