Thursday, April 13, 2006

State Rep. Rob Hogg's Feb. 15, 2006 letter

Iowa General Assembly Representative Rob Hogg expresses concern about LS Power Elk Run Energy Station proposed for construction near Waterloo

February 15, 2006

John Norris, Chair
Iowa Utilities Board
350 Maple Street
Des Moines, IA 50319

Jeff Vonk, Director
Iowa Department of Natural Resources
502 E. 9th Street
Des Moines, IA 50319

Mary Lawyer, Director
Iowa Department of Economic Development
200 E. Grand Ave.
Des Moines, IA 50309


Dear Chairman Norris, Director Vonk, and Director Lawyer:

I am writing to you to express my serious concerns about the proposed 750 megawatt pulverized coal Elk Run power plant which LS Power would like to construct near Waterloo, Iowa. At a recent meeting between your staff and LS Power representatives, your staff asked to hear concerns early in the process. As requested, I am sharing my concerns with you and I hope that you will share them with your staff working on this project.

At this point, I have three main concerns about the proposed plant: (1) the proposed plant would likely squeeze out Iowa,s developing renewable energy industry, (2) the proposed plant would likely have a serious negative adverse effect on the health of many Iowans, and (3) the proposed plant, if built, would almost irretrievably commit Iowa to higher levels of future greenhouse gas emissions despite the need to reduce such emissions.


Iowa has been blessed with abundant renewable energy resources such as wind and biomass. As you know, "[i]t is the policy of this state to encourage development of alternate energy production facilities . . . in order to conserve our finite and expensive energy resources." Iowa Code § 476.41. Further, a new power plant facility is not to be built unless it is "consistent with reasonable land use and environmental policies." Iowa Code § 476A.6.

Our state has been working very hard to develop a strong, dynamic renewable energy industry. In the field of electric generation, we have long had a renewable energy standard for our investor-owned utilities. Iowa Code § 476.44. In 2003, Governor Vilsack set a goal of 1,000 MW of production capacity from renewable energy sources in Iowa. Later that year, we passed a bill (HF659) to help MidAmerican build a 310-megawatt wind farm. Governor Vilsack's goal was not the end; it was only the beginning toward greater reliance on renewable energy after 2010. Iowa is a leader in research through its Biomass Energy Conversion Facility (BECON) at Iowa State University. Iowa is a leader for co-firing switchgrass in existing coal plants and developing high-efficiency bio-refineries that will produce heat, electricity, high-value chemicals, and renewable fuels in the future. In 2005, we passed tax credits to encourage construction of wind power and other renewable energy sources like methane digesters and biomass conversion facilities. Iowa Code §476C.1 et seq. We also provided business incentives which helped convince Clipper Windpower to locate its production facilities in Iowa. Iowa Code § 15.335. Further initiatives are under consideration this year. In short, clean renewable energy produced in Iowa is a winner for our economy and our environment and supporting those clean energy sources is critical for our state's future.

By contrast, a 750 megawatt conventional pulverized baseload coal burning power plant - as is being proposed by LS Power - would squeeze out the development of Iowa's renewable energy industry and direct millions of dollars out of state for the purchase of coal. Iowa already obtains 84% of our electrical production from coal plants. Iowans now spend $2.9 billion on electricity every year, much of which leaves the state to pay for coal and other fossil fuels. Worse yet, once built, the high fixed costs of a coal burning power plant almost ensures that the plant would be operated squeezing out clean Iowa renewable energy for decades.


Air pollution from coal-burning power plants can cause or contribute to serious health problems such as asthma, emphysema, mercury poisoning, and even premature death.

Asthma. According to the Iowa Department of Public Health, asthma affected 200,000 Iowans in 1999, of whom 40,000 were children under age 18. More than 1,500 children were hospitalized in Iowa with asthma in 1999. The economic cost of asthma in Iowa in 1994 the last year the cost was calculated was $116 million. Nationwide, the Natural Resources Defense Council has reported an estimate that smog triggered more than six million asthma attacks in 1997. (

Particulates. As the Iowa Department of Natural Resources has reported, "[p]articulates can harm lung tissue, cause eye and throat irritation, premature death and reduced visibility from haze." ( According to the American Lung Association's Particle Pollution Fact Sheet, "Fine particles can cause serious health effects at relatively low concentrations. Tens of thousands of premature deaths each year are attributed to fine particle air pollution." (

Mercury. Coal-fired plants account for approximately 40% of all mercury emitted by industries in the United States. In 41 states, officials warn against eating fish from lakes and rivers ( Although Iowa has issued at this point only a general advisory for pregnant women and children, the proposed plant in northeast Iowa would add mercury to the environment and to fish in northeast Iowa.

These are serious concerns that need to be fully assessed and weigh heavily against the construction of a new 750 megawatt coal burning power plant, which would be a multiple decade commitment to higher levels of pollution. As we struggle with rising health care costs, we need to make sure our energy investments support the protection of public health. Increasing mercury pollution in our state will not make fish safer to eat. Increasing emissions of sulfur dioxide, nitrogen oxides, particulates, and other air pollution will not help us reduce asthma and other respiratory ailments in our state.


As you may know, the United States Environmental Protection Agency has funded an Iowa Greenhouse Gas Emissions Inventory for 1990 and 2000. The original 1990 inventory is important because 1990 emissions are the base level for international negotiations for emission reductions under the United Nations Framework Convention on Climate Change. Ultimately, to stop the buildup of carbon dioxide in the atmosphere, it is expected that emissions will need to be reduced by more than 60%. Although the United States has not ratified any mandatory reductions under the United Nations Framework Convention, the participation of the United States in a future international greenhouse gas regulatory structure is virtually certain.

Assuming that the proposed 750-megawatt coal burning power plant is built, and achieves a capacity factor of 90%, it would emit more than 6.5 million tons of carbon dioxide every year. In 2000, total greenhouse gas emissions in Iowa were 32.8 million metric ton carbon equivalents, or equivalent to 120 million tons of carbon dioxide - an increase from 84 tons of carbon dioxide in 1990. The proposed LS Power plant, by itself, would represent a more than 5% increase in the state's greenhouse gas emissions -
equivalent to adding more than 700,000 vehicles to the highways in Iowa every day for the life of the plant.

Given the almost certainty of greenhouse gas regulations during the lifetime of the plant, it would be environmentally and fiscally irresponsible to allow the plant to be built without careful scrutiny of alternatives and without considering options to mitigate or eliminate the greenhouse gas impact of the plant, such as carbon offsets or carbon capture. Iowa has obligations to the environment and future generations to reduce our greenhouse gas emissions. I ask that you consider those obligations in your actions on the LS Power plant.

I hope this letter is helpful to you. Please let me know if you would like to discuss this further, or if there is anything else I can do to be of assistance.


Rob Hogg
State Representative
House District 38


At 2:25 PM, Blogger Carol A. Overland said...

This plant probably could not be built but for the transmission addition to the SE corner of Cedar Falls, where CFU is putting in a 161kV completion of a loop around the cities, and which alleviates the transmission constraints in the area. We're contesting this and are at the Polk Co. District Court, briefs due end of month, argument in June. Take a close look at the transmission plans -- that's a lot of power to stick into the system. How much does it cost and what does this cost do to the "reasonableness" of this "alternative." Probably puts it right through the roof and if you show it's too expensive, voila, no plant! GOOD LUCK!!!

Carol A. Overland

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