Tuesday, November 30, 2010
The Bio-En Citizens Response Group, represented by Dr. Dan Holt, and Michael Purves-Smith, do not object to the technology involved in the anaerobic digestion of bio wastes. The group recognizes that the technology represents an important contribution to the reduction of biological waste.
However, the B-e CRG is adamantly opposed to the location of an anaerobic digestion plant at the proposed location.
Therefore the B-e CRG is anxious to help broker a deal which will see the plant more suitably located with minimum additional costs to the Bio-en group.
Objections to the present location fall under ten distinct categories:
While Bio-en has hired a Guelph Company, with a record of success in reducing odour emissions, this company does not have prior experience with its bio-filtration technology as applied to anaerobic digestion plants.
Two engineers with specialties in odour reduction have both expressed concern that the biofilters proposed to accomplish the odour reduction will not be adequate for the task.
Jerry Heidbuurt is chief engineer of Cold Spring Farm where he is responsible for the control of biological odour. Mr. Heidbuurt is an executive member of the
He may be reached at 519-285-3940 ext. 372 or at firstname.lastname@example.org
Adam Quipp, Director of O2e inc., environmental consultants, London, Ontario. Mr. Quipp has recently been working with Elmira Pet Food to locate the odours emanating from its plant that are causing citizen complaints. The Elmira Pet Food plant is located adjacent to the proposed Bio-en plant site.
He may be reached at 519-633-2400 or at email@example.com
B-e CRG further notes that both the Ontario Ministry of the Environment on its own web site and the Guidelines for Selecting Suitable Sites for Biogas Plants (Appendix A) indicate that some level of smell offensive to residents unused to agricultural odours cannot be avoided. This report was prepared under the aegis of the European Commission. This is noteworthy because the Bio-en team has repeatedly used the European experience as an example in its attempts to persuade local residents to accept the location of the plant. On page 14 of the Guideline we find the following statement: “Emissions, particularly smell and noise emissions can not be avoided.” B-e CRG notes the crucial distinction that agricultural odours are common place in a rural town such as Elmira. However, the difference is that while the odours from the proposed plant will likely not be as pungent as some agricultural smells, they will persist 24/7 for nearby residents and may, since Elmira is mostly downwind of the proposed site, impinge much further afield. The European Commission report states on page 14 that: . . . (If there) are residential areas in proximity, this should be analysed in view of the prominent wind direction.
Elmira has a long, and somewhat unhappy history, with the chemical and agricultural industries. The B-e CRG contends that for this reason alone Elmira is an especially unsuitable location for yet another chemical industry plant.
In a recent flyer delivered to the doors of Elmira residents the company made the claim that “there is no significant impact on existing traffic.” While the grammar of the statement is difficult to decipher, B-e CRG assumes that this refers to the company’s consistent claim that truck traffic will not increase significantly if the plant is located to the North of Elmira. The B-en CRG objects vigorously to this contention on many grounds:
a)Any truck traffic added to an already very severe problem with heavy trucks in downtown Elmira is significant. See Appendix B
b)The numbers of new truck passes will be considerable if the plant is to be operated at anything near to capacity.
c)Virtually all truck traffic to the proposed plant would pass through downtown Elmira converging on Arthur St. N. The report from the European Commission (page 14) has this to say under the heading Adequate Road Access: “The biogas plant requires a steady supply and has an outflow of large quantities of biomass. Thus, a good road access is compulsory….” See also page page 4 step 3. It is very difficult to estimate truck traffic flow for this plant, but suffice it to say that there are strong reasons to question the company’s persistent low-balling of truck traffic when questioned. Recently it has said that incoming trucks would normally average not more than seven to fifteen trucks. We are not convinced. First of all, significant discrepancies in the D and O suggest that the company itself does not have a very clear picture of traffic flow. Second, why is there such a wide range in the estimates that we find of page 13 of the D and O report? There the estimates range between an expected maximum of no more than 80 trucks per day and an expected average of 30 trucks per day. The company has explained this by saying that there may be times when an extra amount of digestate would need to be removed to meet seasonal farm demands. Since the plant would have to reach an equilibrium close to maximum and to maintain a constant flow of digestate off site year round, this answer is preposterous. We expect that the number of trucks will be closer to the larger number. Elsewhere in the Noise Study Report (page 4) we find: “It was estimated . . . that there would be a maximum of twenty truck movements per hour (on site). . . Two movements is equivalent to one truck on site . . . Since we are told that the plant will handle trucks 16 hours a day, this adds up to the 80 trucks referred to in the earlier example. We have attempted to estimate truck traffic flow in appendix C.
d)The diesel fumes from all the heavy truck traffic clearly pose a significant health threat in the downtown and to residents near to the main corridors of traffic. Please refer to the attached reports, appendix D.
e)The heavy truck traffic is extremely unappealing in the down town and the B-e CRG contend that it is contributing to the difficulties that the commercial district is experiencing in Elmira as shown by the amount of vacant space in the commercial area and by the exceptionally low ratio of commercial business to population. Please refer to appendix E
The B-e CRG argues that the proposed plant makes absolutely no sense in the proposed Elmira location.
We note that the Bio-en D and O draft proposal (page 7) contains the following statement: “It is anticipated that the Proposed Facility will service an area this is Ontario-wide but will primarily focus on southwestern Ontario, however, the Facility may service other jurisdictions (sic).” Based upon this statement and assuming transportation in south-western Ontario only, it is possible to demonstrate that the transportation of the feeder stock and digestate could use up the equivalent energy in transportation fuel to the energy the plant is capable of generating in electricity. Transportation from further distances could lead to a negative energy position.
We note that the company has recently emphasized its intention to rely on “high energy inputs” (“Entire project is designed to focus on high energy inputs to reduce facility size and reduce the volume of inputs needed” [quoted from the most recent Bio-en flyer].) We have reliable information from Phil McKee whose company, McKee Farm Technologies Limited, (519-669-5720) builds a significant proportion of the tanker trucks used to transport waste products in the province that the disposal of high energy bio waste is already fully accounted for in our region. That suggests that first, if the company is serious about the “high energy inputs” it will involve long distance transportation and second, the long term viability of the company may be in doubt. McKee Farm Technologies Ltd. is located immediately adjacent to the proposed Bio-en installation. It should be noted that the flotation residue from the Elmira Waste Water Treatment Plant are currently trucked to a site near Buffalo New York. It would certainly make sense to dispose of this waste in Elmira, were that possible, but this could supply only a small amount of the feeder stock requirements of the Bio-en plant and it would still involve trucks moving through down+town Elmira.
Commentary derived from the Guidelines for Selecting Suitable Sites for Biogas Plants
Page 3 Step 1:
The first step is to select suitable regions for biogas production. Suitable regions are defined by the availability of biomass. Due to the low energy content per volume and large quantities it is economically and energetically usually not useful to transport liquid agricultural feedstock further than 5 km, and stackable energy crops not more than 15 km. Thus, a biogas plant should be located in a radius of less than 15 km from the available biomass sources.
The nearest source that we know about is Piller’s Sausages and Delicatessens. The company is a partner in the Bio-en project. It is located 13 kilometres from the proposed Elmira plant. However, since the feeder stock from this plant would almost certainly be slurry diluted with water it more properly belongs in the 5 kilometre limit. This is to take into account the added weight of non energy producing water in the feeder stock. The company has said that it will accept feeder stock from anywhere in the province and even from across the border. Some evidence printed in the press suggests that it plans to take advantage of the huge supply of waste available in the Toronto area.
Page 4 Step 1:
Also the digestate which is usually used as fertiliser for feedstock production should not be transported further than 15 km due to increasing transport costs.
This refers to the fact that in Europe feeder stock is often grown on nearby crop lands which can then be “fertilized” by the digestate. We have no clear idea about the disposal of the digestate other than the fact that it could be used as a fertilizer in its slurry form or as a soil enhancer in its solid state. Not mentioned in the report we are analyzing is the fact that it could be used as an asphalt substitute of as shoe soles. In any case, it is highly unlikely that the company will be able to meet the suggested 15 kilometre limit. However, it will likely do its best because on this end it will be paying the transportation costs.
Page 4 Step 2:
The second step is to define suitable neighbourhoods within the selected region. Suitable neighbourhoods are defined by opportunities to sell heat and to feed electricity into the grid. Transporting heat is cost intensive and energy losses are inevitable. Therefore, the biogas plant should be located in a radius closer than 1000 metres on an average to the heat user, depending on the produced heat.
The proposed for Bio-en is well located from the point of view of electricity transmission as there is an Ontario Hydro transformer station less than a kilometre away. Transmission of electricity at low voltage is the source of serious energy loss. Therefore, elsewhere in the white paper we are examining, it is suggested that a transformer be included on site. Presumably this is a possibility for Bio-en if another site can be located which might otherwise be too far from an Ontario Hydro transformer. The sale of the heat will be difficult to arrange as none of the nearby companies can make use of the heat. So far as we know, no private residences have been contacted. In Elmira’s climate it will be difficult to maintain a steady heat flow throughout the year and when heat is most saleable, that is during the winter, much of the heat generated by the plant (about one third) will be needed to maintain the temperature of the anaerobic digestion. Nonetheless, the sale of heat is not likely to be crucial to the success of the company. However, we are concerned that the industrial site will be quickly expanded in order to make use of the heat energy generated by the plant. This will exacerbate the traffic issues already associated with the site.
There are complicated issues related to water use and disposal for the proposed plant. Once the proposal has been re-posted, the B-en CRG will present an outline of its concerns to the MOE. While we fervently hope that the project will not be approved in its present location, if it is the B-en CRG will undertake a peer review of the water issues.
6.Questionable practices in the procedure thus far.
a.The area for which the plant is proposed is zoned Industrial Dry. The company appears to have dealt with this particular problem by means of circumlocution. Where the water comes from (storm runoff, municipal water, or trucked in water), and whether or not some of the water is recycled is beside the point. Far from being dry, the project is water intensive. One sixth of the material in the digester tanks is added water; the bio-filters need to be washed continually, and the clean up process on the floor of the plant is very water intensive.
b.Truck traffic is mentioned in the draft proposals only in connection with on site activity. No traffic impact survey was done. Brian Soehner and David Young, both senior officials in traffic at the Region (519-575-4558),will be happy to verify that a) no traffic impact survey was done for this project, b) that this is very unusual, c) that they can’t remember a case where this procedure was not followed, and d) that the survey would normally be initiated by the township and passed on to the region for its comment.
7.Misleading information in the company’s public information thus far. We will make an analysis of the company’s most recent flyer (Appendix F) an example, but a careful reading of this presentation suggests that there have been other occasions on which the company has been disingenuous in its anxiety to realize this project in its present location. For example, at the all candidates meeting that the B-en CRG arranged as a part of its response to the Bio-en proposal, the company publically stated that it has done much to reduce truck traffic on Arthur St. N. from the pet food mill. This statement was vigorously supported by Councillor, Ruby Weber. At the next public meeting organized by B-en CRG, the company stated once again that the truck traffic was decreasing, pointing to the likely anomalous spike in the traffic count for 2003. This is a case of brinkmanship because none of the partners in the Bio-en company any longer had any interest in Elmira Pet Foods during the period of the traffic counts in question (2000 – 2010).
While the B-en CRG does not question that the plant will be designed to minimize the threat of a methane explosion, we maintain that such a plant should not be located near to residences. One has only to think of the recent methane explosion in Cuidad del Carmen, Mexico that took the lives of five Canadian tourists to understand that methane can be lethal. Methane gas explosions killed at least seventy miners in Russia in 2010 and the Gulf of Mexico oil spill was the result of a methane explosion. Methane is a very dangerous substance. An explosion at Bio-en in the proposed location would be devastating. We are therefore also concerned that only one employee will be on site at any given time.
9.Heat generation and plans for further development
The plant would generate in excess of 3 MW of heat according to the company’s own estimates. It has stated that it plans to sell the heat to nearby companies. There are two significant companies immediately adjacent. McKee Farm Technologies will not purchase heat from the plant because it has already installed a geo-thermal heating system which fully meets its needs. Elmira Pet Foods would certainly be interested, but since purchasing heat from Bio-en would involve very expensive modification of EPF’s extant drying process, it has not found the way to make heat from Bio-en economically feasible. In addition there are at least two poultry breeding operations within the optimal kilometre range that might use some, but by no means all, of the co-generated heat. This opens the possibility of the company developing the in-excess-of 20 adjacent acres of industrially zoned land that it has access to through Mabro Holdings. While B-en CRG recognizes that it would be unfair to restrict any expansion plans on the part of the existing companies in the North Elmira Industrial Zone, it argues very strongly that no new development should be permitted until such time as adequate and non-disruptive access can be made available to the Zone by means of an Elmira truck bypass. We would argue that this applies to Bio-en as well as to any other business that would follow. Furthermore, given the uneven nature of the heat available from cogeneration at Bio-en, the product is suitable only for some applications. Please consult appendix A pages 11 and 12. High on the list of suitable business are agriculture enterprises which, in view of an unsatisfactory experience with previous Mabro owned businesses in the immediate region, would be viewed as highly undesirable by its neighbours.
10.Real Estate Values
Bio-en CRG has information from a professional real estate agent with long experience in the Elmira region that confirms its opinion that real estate values have been negatively impacted by the reputation of the town for chemical manufacturing, by serious traffic difficulties, and by the perceived threat of the Bio-en installation. Anecdotally, it is not hard to envision the difficulty of selling a property for a fair price once any or all of the problems that will be generated by the plant are disclosed. Who would buy a property on Arthur St. at anything other than fire sale prices once it was revealed that the property were subject to a constant stream of garbage carrying, three axle trucks?
Since the requested meeting with MPP Pendergast came upon us somewhat by surprise, B-en CRG apologizes for any incomplete information this preliminary presentation may contain. It will endeavour to supply any needed documentation for a submission to the MOE as soon as the application from Bio-en is posted. Should the MOE approve the Bio-en proposal B-en CRG will, of course, undertake a vigorous information campaign to inform the people of the region of the dangers of the proposal and it will make common cause with the many other groups which are springing up around us in response to sometimes ill-conceived green projects. Finally, it will attempt to raise the not inconsiderable funds that will be needed for peer reviews of all of the aspects of the proposal.
The B-en CRG wishes to express its sincere appreciation for all of the help that MPP Leanna Pendergast and her staff have extended to the group as it has worked its way through the process.
Dr. Dan Holt