On March 13th, the Colorado Air Pollution Control Division (APCD) released a revised draft permit for the PRPA’s proposed Rawhide gas plant. The permit documents are available here. The Fort Collins Sustainability Group and others have since reviewed the permit, and have concluded that while it represents an improvement over the first draft permit, it could do much more to protect public health and the environment. We are therefore asking people to send comments to the APCD again asking that they make additional improvements. This should be done prior to deadline of April 12th.

The new draft permit does establish annual limits for how long the new fleet of five gas turbines (collectively, the gas plant) may run, and how much “hazardous air pollutants” (HAPs) that fleet may release. It requires that Rawhide Unit #1 (the coal plant) shut down within 180 days of the date when all five gas turbines become operational, and no later than December 31st, 2029. However,

  1. The new permit allows the gas plant to operate at equivalent full output for 45% of the entire year. That’s a lot of hours – 3,942, to be precise.
  2. The new permit allows the gas plant to emit up to 25 tons of HAPs per year. That’s a lot of air toxins that wouldn’t be released by wind turbines, solar panels, or batteries.
  3. Perhaps most surprisingly, the new permit allows the gas plant to emit more HAPs in the summer – ozone season on the front range – than during other seasons. More specifically, it allows:
    1. 30% of total annual pollutants to be released in December – February
    2. 15% of total annual pollutants to be released in March – May
    3. 40% of total annual pollutants to be released in June – August (aka ozone season)
    4. 15% of total annual pollutants to be released in September – November.

Please write to the APCD at cdphe_apcd_airpermitcomments@state.co.us and state in the subject line that you are commenting on Draft Construction Permit 24LR0705. Tell them that the final permit should:

  1. Include more stringent limitations on hazardous air pollutants (HAPs) during June – August. Letting the gas plant release 40% of annual total HAPS during ozone season is unconscionable.
  2. Reduce the total amount of HAPs permitted from 25 tons to the lowest number possible. HAPs – including carbon monoxide, particulate matter, nitrogen oxides, sulfur dioxide, and volatile organic compounds – lead to poor health and kill people and animals.
  3. If 25 tons of HAPs is really the absolute minimum that APCD can accept, reduce the number of turbines permitted from five to three. Three turbines can produce more than enough electricity than the draft permit assumes is needed. Building fewer turbines will help reduce the spiraling cost of PRPA’s new gas plant, which will be paid for by the residents of Fort Collins, Loveland, Longmont, and Estes Park over the coming decades through their electricity bills.

Please use your own words if you can, and explain why at least limiting the size of the gas plant is important to you. But sending something is better than nothing! Be sure to e-mail your letter to the APCD before the deadline, April 12th.