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Section 3: Affected Environment, Environmental Consequences, and Mitigation

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Section 3: Affected Environment, Environmental Consequences, and Mitigation Section 3: Affected Environment, Environmental Consequences, and Mitigation 3.1 Introduction: Regional Setting The proposed project area is located in south central Washington in the mid-Columbia River Basin as shown on Figure 1-1. The affected areas are Townships 3, 4, and 5 North, Ranges 10 through 23 East; Township 6 North, Ranges 18 through 23 East; and Township 7 North, Ranges 19 through 23 East, W.M. within Klickitat County, Washington. Farming, ranching, forestry, hay and wheat production, orchards, and vineyards have long been the base of Klickitat County's economy. The county contains 85 miles of frontage on Columbia River, connecting with Oregon on its southern border. The county is home to more than 19,000 residents. The total area of the county is 1,904 square miles. The following analysis of the affected environment and environmental consequences of the proposed Energy Overlay addresses potential impacts to the entire County and, where appropriate, the region to encompass the Technology, Geographic, Procedural, and No Acton Alternatives and to account for cumulative impacts of the proposed Overlay. 3.2 Air This section evaluates potential impacts of the proposed energy Overlay alternatives to air quality. The principal impacts to air quality are expected to be ongoing sources of emissions from fuel-burning thermal power plants. However, these impacts could be partially offset by encouraging wind power development in the region as an alternative to thermal power. For instance Overlay encourages alternative sustainable and low-impact energy development while excluding higher impact technologies like coal-fired power plants. This may encourage regional development of cleaner or no-impact technologies instead of coal or diesel fired plants. 3.2.1 Study Methodology Air quality resources are affected by atmospheric emissions, especially by technologies that combust fossil fuel or biomass. Most impacts can be determined by the amount of emissions attributed to a project and the ground-level concentrations resulting from those emissions. Emission estimates and an impact evaluation are normally performed during the permitting process for a proposed facility, when the project site and design have been finalized. In the case of CCCT facilities, information required for an impact evaluation includes turbine design data, turbine-specific emission factors, stack and building dimensions, the location of the facility, property boundaries, and terrain elevations of the area surrounding the facility. Typical energy development projects in the region were used to assess typical potential impacts to air quality from the proposed Overlay alternatives. A number of power plant projects have been recently proposed or permitted and constructed in the Pacific Northwest. From these projects, it is possible to estimate emissions and impacts from a typically sized project. The evaluation presented below examines emissions and impacts from projects that may be built in Klickitat County. The emissions and concentrations were obtained from approved permitting documents or developed from publicly available emission factors. Projects reviewed include: Klickitat County Energy Overlay FEIS Page 3-1 • The 248 MW River Road Generating Station near Vancouver, Washington, permitted in 1999 (Mint Farms Generating LLC 1999) • The Cliffs Energy Project near the Goldendale Aluminum Plant near Goldendale, Washington (Cliff’s Energy Project Environmental Checklist 2001) • Sumas Energy 2 Generation Facility, Sumas Washington (Jones and Stokes 2001) • Klickitat Cogeneration Project, near Bingen, Washington (BPA 1994) • BP Cherry Point Cogeneration Project near Ferndale, Washington ( EFSEC 2001) • The Goldendale Energy Project, Goldendale, Washington (URS 2000). 3.2.2 Affected Environment The affected environment includes the regional air shed and the regulatory processes for controlling air emissions. 3.2.2.1 Regional Air Shed The proposed Overlay has the potential to affect air quality in the regional air shed, including visibility in the Columbia River Gorge National Scenic Area (CRGNSA). Klickitat County is currently in attainment of all air quality standards. The CRGNSA is the subject of an analysis assessing visibility issues. The boundaries of a regional air shed are difficult to define. Atmospheric impacts can have localized or long-distance sources. For the purposes of the analysis below, we assume a regional air shed that includes south-central and southeastern Washington, north central Oregon, and the CRGNSA. 3.2.2.2 Regulatory Framework Both the federal and state governments regulate and permit sources of air emissions. The U.S. Environmental Protection Agency (EPA) has established national ambient air quality standards (NAAQS) to protect public health from criteria pollutants. In addition to these primary standards, secondary ambient air quality standards exist to protect human welfare and the environment. The PM10 and ozone federal standards were revised recently, and a new PM2.5 particulate matter standard was promulgated. Measures to limit emissions to comply with these standards have yet to be incorporated into the Washington regulations. The Washington State Department of Ecology (Ecology) has established additional AAQSs for criteria air pollutants and regulates new sources of toxic air pollutants (TAP). Graphic 3-1 presents the federal and Washington AAQSs. New sources of air emissions in areas that do not meet the standards (nonattainment areas) must undergo more rigorous permitting than equivalently sized sources in areas that meet the standards. Klickitat County is an attainment area for all regulated air pollutants. Klickitat County Energy Overlay FEIS Page 3-2 Graphic 3-1. Ambient Air Quality Standards Averaging Washington Ambient Air National Ambient Air Pollutant Period Quality Standard 1 Quality Standard 2 CO (parts 1-hour 3 35 35 per million 3 [ppm]) 8-hour 9 9 4 NO2 (ppm) Annual 0.05 0.05 1-hour 5 0.12 - O3 (ppm) 8-hour 6 - 0.08 3 PM10 24-hour 150 150 (micrograms per cubic 4 meter Annual 50 50 [µg/m3]) 7 3 24-hour - 65 PM2.5 (µg/m ) Annual 8 - 15 1-hour 9 0.25 - 1-hour 3 0.40 - 3,10 SO2 (ppm) 3-hour - 0.50 24-hour 3 0.10 0.14 Annual 4 0.02 0.03 Notes: 1 WAC 173-470, 173-474, and 173-475. 2 40 CFR Part 50. 3 Not to be exceeded more than once per year. 4 Not to be exceeded. 5 Not more than 1 day per calendar year. 6 3-year average of the 4th highest daily maximum 8-hour concentration. 7 99th percentile 24-hour concentration averaged over 3 years. 8 3-year average of annual arithmetic mean. 9 Not more than twice in a consecutive 7-day period. 10 Secondary standard. Certification by EFSEC is required for certain energy facilities which meet or exceed “capacities or dimensions set forth in” state statute (RCW 80.50.060(1)). Included within this definition are power generation facilities with a generating capacity of 350 MW or more (RCW 80.50.020(14)(c)(a)). Also, certain alternative energy projects may opt out of the local regulatory approval process and seek approval through the state process (RCW 80.50.060(2); RCW 80.50.020(17)). Historically, applicants proposing energy projects in Klickitat County have not utilized the EFSEC process. All or almost all projects contemplated by the EIS will likely be reviewed at the local level due to the limited jurisdiction of EFSEC and its lengthier review process. However, even if an energy project were to be certified by EFSEC, local regulations would be relevant to the state’s review. Klickitat County Energy Overlay FEIS Page 3-3 Local development regulations are used to guide development unless preempted. If EFSEC determines that local land use controls are inconsistent with the application, the applicant must apply for a change to these controls and make all reasonable efforts to resolve the noncompliance with the local jurisdiction (WAC 463-28-030). If these efforts fail, the applicant files a written request for state preemption (RCW 80.50.090; WAC 463-28-040). EFSEC makes a preemption recommendation based on: (1) applicant good faith effort to resolve the noncompliance issues; (2) failure to reach an agreement with local authorities; (3) alternative locations within the same county and city were reviewed and found unacceptable; and the interests of the state as outlined in RCW 80.50.010 (WAC 463-28-040; WAC 463-28-060). If EFSEC approves the preemption request, its recommendation on the project will be forwarded to the governor with conditions giving due consideration to local interests (WAC 463-28-070). Local law is not superseded until the governor approves the project (See WAC 463-28-060; RCW 80.50.100). Thus, even if the EFSEC process is utilized, local planning would still play a key role in permitting energy projects within the County. For Klickitat County projects, the nearest Class I Areas would be Mt. Adams, Goat Rocks Wilderness, Mt. Rainier, and Alpine Lakes Wilderness in Washington, and Mt. Hood and Mt. Jefferson in Oregon. The CRGNSA is not a Class 1 Area. It is protected through the Columbia River Gorge National Scenic Area Act, however. The Act does not regulate air emissions but regulates development with the CRGNSA with two goals: (1) to “protect” and “enhance” the “scenic, cultural recreational, and natural features of the Columbia River Gorge;” and (2) to “protect and support the economy of the Columbia River Gorge Area” by “encouraging growth: and “allowing future economic development in a manner consistent with paragraph (1).” Act, Sec. 3(1), (2); 16 USC§ 544a(1), (2). Power plants with less than 350 MW of capacity and less than 100 tpy of emissions require only a Notice of Construction (NOC) from Ecology, but a BACT analysis, AAQS compliance demonstration, and TAP evaluation are still required. Additional air quality permitting is required if operational emissions are greater than the major source threshold. A major electrical generating source for PSD has a potential to emit greater than 100 tpy.
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