Ask The AZ Corporation Commission To Support Energy Efficiency

Sandy speaking up at the first PDEQ hering. We saved a seat for you!  

I want to thank all of you who took action to stop new natural gas investments in Tucson!

With your help, we made a compelling case to the Pima County Department of Environmental Quality to deny Tucson Electric Power (TEP) the air quality permit they need to move forward with their proposed investment in new gas-fired engines at the Sundt Generating Station. We are awaiting a response and decision, but will be sure to keep you updated.

(Jana's note: Our public letter to the president of TEP will be delivered soon.)

While the fight continues to stop natural gas expansion, there is still lots of other work to be done!

You can take action now by signing a petition telling Arizona Corporation Commission to require energy efficiency for TEP!

Energy efficiency is Arizona's cheapest, cleanest energy resource but a plan filed earlier this year by TEP fails to take full advantage of it. The energy we save means less water use, less pollution, and more dollars in our pockets.

Sign our petition to the Arizona Corporation Commission to require TEP to do more to promote energy efficiency.

Each year, Tucson Electric Power (TEP) and Arizona Public Service (APS) file efficiency plans to show how they will meet Arizona's Energy Efficiency Standards. This year, both utilities have filed plans that are inadequate and that fail to take full advantage of our cheapest cleanest energy resource -- energy efficiency.

The energy we save means less water use, less pollution, and more dollars in our pockets.

Please sign our petition to the Arizona Corporation Commission (ACC) to require TEP and APS to do more to promote energy efficiency in their plans.

Ask the ACC to require that the plans focus on real energy savings. We need to continue to invest in consumer programs that help reduce energy use in homes and businesses, saving money and reducing pollution and water use.

Please sign the Sierra Club's petition. We will deliver it to the ACC and have it entered into the docket.

- Sandy Bahr, Grand Canyon Chapter Director of the Sierra Club 

Speaking Up Against TEP's Proposed Gas-fired Generators

As I mentioned in a previous blog, TEP is proposing modernizing the Sundt Generating Station by replacing two 1950's era steam units with ten natural gas fired combustion engines. The RICE units are fossil-fuel based generating units that would create significant greenhouse gas emissions. According to the Pima Department of Environmental Quality, the project expects to cause an increase in emissions of carbon monoxide, particulate matter and volatile organic compounds.

Last night 30 people from the Irvington neighborhood and our Tucson community attended the march to protest the gas-fired engines being installed in their neck of the woods. 50 people showed up to show support at PDEQ's public hearing. 30 of those, myself included, spoke up.

Some people explained how carbon dioxide from the engines would accelerate climate change and how that would devastate our city. But I'm afraid those comments about green house emissions won't have any impact. We were limited to commenting on how TEP's permit meets the criteria for issuance prescribed in the Arizona Revised Statutes, Section § 49-481 of the Pima County Code.  All of those important comments about climate change were disregarded because CO₂ isn't included in Pima's code. (I know! I couldn't believe it either!)

A few of us from Sustainable Tucson's advocacy group and the Sierra Club have been combing through Pima's code - trying to find some inconsistencies or ANYTHING we can use stop the PDEQ from issuing a permit for the RICE engines.  The deadline for comments to the PDEQ was Thursday, March 29th.  Here are some angles that our team member uncovered. 

But what I found to be really powerful was how the people from the neighborhood spoke their truth to power. They bravely told stories about how TEP's environmental racism had impacted the health of their loved ones. I think that might just be the angle we need for our comments to the PDEQ. On their letter announcing this hearing,  they wrote:

Pima County has completed an extensive review of the permit application, examined the air quality impact analysis of the project and considered environmental justice to protect the health and environment of minority, low-income, tribal and indigenous populations.

After hearing the heartfelt comments from people in the neighborhood, something occurred to me.  I believe that PDEQ did not take into account the special circumstances of how the pollutants from the new gas-fired engines would impact the vulnerable population that is already suffering from cancer, lupus, asthma, heart valve defects, birth defects, arthritis, and central nervous system disorders from decades of dioxane in  their water and the pollution from Sundt's coal-fired plants. 

A 2010 study by the Clean Air Task Force showed the burning of coal at Sundt causes approximately 68 asthma attacks, 6 heart attacks and 4 deaths every year. Built in 1967, the Sundt plant ranked 13th worst in the NAACP’s environmental justice performance ranking.

https://www.sierraclub.org/planet/2015/09/h-wilson-sundt-generating-station-stops-burning-coal

If you're a member of one of the families who suffered from any of these diseases, you might want to use this angle and share your story for the record.  I encourage you to back it up with data (included on this blog and the links provided). (The deadline  has expired. It was Thursday, March 29th.)  Here are the directions. 

TEP’s environmental justice argument leaves things to argue with:

TEP’s Environmental Justice Analysis duly notes the goal of Executive Order 12898, that “each Federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations.”

TEP notes the stark socioeconomic divide between the population in its 38 square-mile Impact Area – a full 18% of our City’s population – and the 82% of Tucsonans who live outside the plant’s shadow. “Minority” (i.e. global majority) 85% (Tucson 56%); Low income 63% (Tucson 51%); Linguistically isolated: 15% (Tucson 6%); % w/o HS diploma 32% (Tucson 17%). Although asthma rates are not broken down to a small scale, TEP noted that between 2012 and 2014, CDC recorded a nationwide increase from 7.0% to 8.4% while Arizona’s statewide number climbed from 8.9% to 9.6%.

For inconsistencies in TEP's Environmental Justice Analysis, scroll down to:

TEP’s environmental justice argument leaves things to argue with with on this page:

I will leave you with Oscar Medina's speech for inspiration:

"My name is Oscar Medina. I am a father, an educator, member of Sierra Club, and a community organizer with Tierra y Libertad Organization. I am here today to express my concern and opposition to TEP’s proposal for 10 new Reciprocating Internal Combustion Engine (RICE) natural gas units at the Sundt Plant location.

I live less than 2 miles away from the TEP’s Sundt Plant location. I have three children: One who attends the Tucson Gymnastics center located near the intersection of Irvington and Alvernon Way. We drive by the plant at least three times a week and the facility does not appear to look the healthiest. My daughter’s school is located just one mile from the intersections of Drexel and Alvernon Way. This is only a few hundred feet from location of the proposed RICE units.

I attended the neighborhood meetings that were hosted by TEP and gave my testimony in opposition to their application at the Arizona Corporation Commission hearing. TEP is framing this project as a campus modernization project. This is deceiving to our community. This expansion project is not about people or the environment, this is about cutting cost and putting profit into the pockets of the TEP investors. At the open house meeting Feb. 15th, I learned from the Pima County Department of Environmental Quality that in the past, TEP has not always complied with the air quality regulations, and that air monitoring reports demonstrated excessive carbon monoxide emission. This demonstrates that TEP is not afraid the break the rules again and pollute our neighborhoods.

The open houses that were held before this hearing were not only missing people from the surrounding neighborhoods but they were missing the pictures of children suffering from respiratory illness in parts of south Tucson. The open house was missing pictures of the effects that emissions of carbon monoxide have on people's health. Let's put the bar graphs and data to the side and paint a clear picture. Our children can see right through TEP’s dirty data. This is another clear example of the ongoing environmental racism still occurring in 2018. This fight against pollution that goes years back to the San Juan and Navajo generating stations. Where are the reparations for harming our Dine* brothers and sisters? That is a dark history that TEP does not wish remember. TEP’s plans and their time frame to expand renewable energy resources to 30 percent by 2030 has expired for our neighborhoods. The stakes are too high. TEP’s polluting practices are not welcome in our backyards. Remember that we are the people that breath this dirty air. Let's keep it clean and simple, divest from coal and gas, keep it renewable and let the future be wind and solar energy."

*The word Dine' is from their own language and means "the people." 

The time for action is NOW - while we still have this little window of opportunity. This is something concrete we can do to leave a better life for our children in Tucson. Let's make those brave speeches count!

Power Generation for Generations to come - YES to Solar + Storage! NO to fossil fuels

TEP is proposing modernizing the Sundt Generating Station by replacing two 1950's era steam units with ten natural gas fired combustion engines. The purpose of the new engines is to ramp up more quickly and to balance the variability associated with solar and wind energy generation. But all that ramping spouts more pollution into the air than the current steam units.

TEP claims that these units are part of a larger goal for 30% renewable energy by 2030, but gas fired engines should not be equated with clean, renewable power from wind and solar. The RICE units are fossil-fuel based generating units that would create significant greenhouse gas emissions. According to the Pima County Department of Environmental Quality, the project expects to cause an increase in emissions of carbon monoxide, particulate matter (fine particles PM2.5 and coarse particles PM10) and volatile organic compounds.

Over a third of carbon dioxide emissions in the US are from power plants.

TEP needs to stop promoting the idea of "clean gas." Just stop. It reeks of Big Oil rhetoric!  Burning fossil fuel still emits about 60 percent as much heat-trapping carbon dioxide as coal. Fracking for gas releases vast amounts of methane, a greenhouse gas that traps 80 times more heat in the atmosphere than carbon dioxide pollution. Gas extraction harms wildlife, disrupts ecosystems, and has been proven to contaminate water and even cause earthquakes throughout the U.S.

Neighborhoods in southeast Tucson have suffered from decades of coal and gas pollution from the Sundt plant. Pollution from the Irvington Campus has had negative health effects for generations. Now TEP is proposing a plant that will emit hazardous air pollutants that are harmful to our health, including benzene, fluorene, naphthalene, and toluene. This proposal will cause a net increase in pollution from particulate matter, carbon monoxide, volatile organic compounds, and greenhouse gases such as carbon dioxide, methane, nitrous oxide, and sulfur hexafluoride.

And none of this is necessary! Utility-scale battery storage can provide the fast acting support that TEP needs to incorporate intermittent renewables like wind and solar even faster than gas units.

TEP claims that the RICE units are the most cost-effective option to incorporate intermittent renewables, but did they even consider clean alternatives to the RICE units? By pairing batteries with solar resources, utilities can use tax credits to reduce their costs. The prices for solar-plus-storage and windplus-storage systems have been plummeting, leading to record-breaking low prices in energy projects in other states. Colorado recently beat a record that Arizona held for the lowest-cost solar-plus-storage project. The median project in Colorado’s energy solicitation was 20% lower than TEP’s NextEra solarplus-storage project.

Sundt Generating Station represents a prime opportunity to choose renewable resources instead of building brand new fossil-fuel reliant projects. We have a great opportunity here! TEP’s service territory sits in one of the richest renewable resource zones in the country. Renewable energy creates far more jobs than fossil fuels. According to the Department of Energy, Arizona’s clean energy and energy efficiency industries already employ nearly 5 times as many people as the fossil fuel industry, and there is much room to grow. So why isn't TEP doing what's best for Tucson's economy and health?

TEP’s target to serve only 30% of its load with renewable energy by 2030 isn't nearly ambitious enough to protect Arizona’s air and water and to limit the impacts of climate change. It's time for our governing officials to demonstrate some strong leadership and do what's right for the people of Tucson and the future of our city.

The time for action is NOW - while we still have this window of opportunity. We can make a difference. Our city council can make a difference with some bold leadership! This is something concrete we can all do to leave a better life for our children in Tucson. 

Actions to take in March 2018

1.   Contact your Pima County Supervisor.  Ask them to deny TEP’s request for increased air pollution limits for the proposed installation of ten gas-fired Reciprocating Internal Combustion Engines (RICE) at the SundtGenerating Plant in Tucson. Most County officials claim that the County’s hands are tied, and that the decision is up to the EPA. But the County’s Department of Environmental Quality is holding public hearings, and even added one on March 28.  

2.   Contact your City of Tucson Council member and Mayor Rothschild (see Ward maps) and ask them to deny TEP’s request for a special zoning designation (Planned Area Development – “PAD”) because TEP’s request for rezoning contradicts the Tucson General Plan’s call for:

(a)  Increased renewable energy sources;

(b)  Recruiting, retaining and expanding Tucson’s key economic sectors in renewable energy;

(c)  Increasing or promoting environmentally sensitive industry; and

(d)  “. . .[N]o compromise on principles of equity, fairness, justice, prosperity, livability, and environmental integrity.”

TEP should not be rewarded for having previously failed to comply with development standards.

(brief talking points) (extensive talking points) 

Additional Resource: Sierra Club talking point for recent City of Tucson zoning hearing

3.   Join local neighbors, sustainable organizations, and the Sierra Club for a Rally and March on Wednesday, March 28.
4:15 p.m. Rally at TEP headquarters, 88 E Broadway.
March to the Pima County Public Works office, 201 N. Stone Ave, for…

4.   Pima County Department of Environmental Quality community meeting March 28, 2018, 5:30-6:30 p.m., at the Pima County Public Works Building, 201 N Stone basement Conference Room C, on TEP’s permit application. 

https://www.facebook.com/events/988829857935438/

Those unable to attend may submit written comments. Those who leave comments are qualified to appeal, but the comments must pertain to on how the permit meets the criteria for issuance prescribed in the Arizona Revised Statutes, Section § 49-481 of the Pima County Code.    

More information here:

http://renewnow.us/sundt/action.htm

The deadline to make public comments is THURSDAY. A well thought out public comment could stop the 10 gas-fired engines from being installed. But to be counted the comments MUST focus on how the permit doesn't meet the criteria for issuance prescribed in the Arizona Revised Statutes Section § 49-481 and Title 17 of the Pima County Code.

We need someone with the time and ability to comb through those government regulations to find inconsistencies in the revised statues or someone who has some knowledge in atmospheric science who can discuss how TEP's permit doesn't meet the Pima County Code air quality standards (like Ozone emissions). This will require an analytical mind and some time to do some research. Please, pass this onto any scientists or legal experts you know. This is our chance to save generations of Tucsonans from more toxic pollution.

Note: the codes do not include anything about greenhouse emissions, so the impact of climate change is not that is not a helpful argument for the public comments - but air quality is.

5. Share this blog:

  https://desktopactivisttucson.blogspot.com/2018/03/this-is-our-fight-its-time-to-take.html

March 28: Stand up for clean air at the Pima County DEQ Meeting about TEP’s Gas Plants

"Put those dirty, pollution spewing gas-fired engines at Irvington!"

The struggle for clean air, renewable energy, and environmental justice in Tucson, AZ continues. The Pima County Department of Environmental Quality (DEQ) is holding a second public meeting to get feedback from the community. They need to hear from you. Tell them that we want clean, renewable energy and less pollution in our neighborhoods. 

Who: Neighbors who want clean air and environmental justice.

What: Pima County DEQ Meeting about TEP’s 10 Gas-fired engines

When: March 28, 2018 from 5:30-6:30 p.m. 

Where: The march will begin at TEP's headquarters (88 E Broadway Blvd, Tucson, AZ 85701) then we will continue to Pima County Public Works Building, 201 N Stone, basement Conference Room C

Tucson 85701.

4:15pm: Join us at TEP's headquarters to show our numbers that our communities want clean renewable energy and not more fossil fuels! Come with signs! 

5:00pm: We will march from TEP headquarters to the Pima County Public Works Building, where we will speak up for rooftop solar and fair electricity rates for everyone. 

5:30-6:30pm: The Pima County Department of Environmental Quality (DEQ) is holding a second public meeting to get feedback from the public. This is our opportunity to tell them we do not want more dirty fossil fuels poisoning our communities and our climate and that we instead want clean renewable energy.

Summary: Tucson Electric Power (TEP) is failing to invest in Arizona’s abundance of low cost renewable energy potential. Instead, TEP is now planning to ten 20 megawatt gas-fired power plants, also known as reciprocating internal combustion engines (RICE), at the H. Wilson Sundt Generating Station on East Irvington Road. 

Environmental injustice and racism: this plants impact areas have an 85% minority population and a 63% of the residents are low-income.

It’s time to stop investing in the unstable fossil fuel industry that’s polluting our air and water, damaging our climate, and holding back the growing clean energy economy that will create opportunities that will last for generations

Read Oscar Medina's critical opinion piece to learn more:

http://tucson.com/opinion/local/oscar-medina-speak-out-against-tep-natural-gas-engine-plan/article_f3ea4076-14dc-5682-abf8-8598592a2902.html

Summary of TEP Rice Proposals: https://docs.google.com/document/d/16dctI1OGrBqJJxYkmKpIP2h8wHj3HQNA78XQSsszQ9s/edit?usp=sharing

More information and ways to protest here.