Public Comment
January 25, 2024
RCEA Board
of Directors
Regular Meeting
From: Benjamin Scurfield
To: Public Comment
Subject: solar in Humboldt
Date: Wednesday, January 24, 2024 2:14:04 PM
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Dear Redwood Energy Board,
I am writing to express my concerns over the NEM 3 solar policies.
What has been 60+ percent of my business has essentially vanished. In the 20 years we have been in business this is unprecedented.
As we struggle to shift our offerings I contemplate if I will need to start laying off staff.
My question to the board is are you able to offer some local rebates to help offset the cost of the battery installation?
Best regards,
Ben Scurfield
From: Matty
To: Public Comment
Subject: Urgent help needed for local solar industry as a result of recent CPUC rule changes Date: Thursday, January 25, 2024 2:34:03 PM
To: Board of Directors.
From Matty Tittmann, Greenwired Renewable Energy
Re: NEM changes have resulted in unprecedented and catastrophic downturn in inquiry/ sales for Grid connected solar
Dear Members of the RCEA board,
Greetings! My name is Matty Tittmann and I co owner of Greenwired Renewable Energy, a local solar/ storage and now hvac company.
For almost 20 years, Greenwired has grown from a few friends to one of the larger solar/ storage/ home energy services companies in the region. Our company began an off grid installation and retail sales company servicing the do it yourself homesteaders and cannabis industry based in the southern part of the county, selling fans, pumps, solar and batteries.
We have now diversified into a full service, licensed electrical and solar contractor serving all the north coast with a 2nd office in Eureka.
Greenwired has installed hundreds of solar/storage systems; residential, commercial, and institutional, and have worked with homeowners, businesses, farms, ranches schools and local tribes to reduce their carbon footprint and become more energy independent, while providing stable employment for our local growing workforce. We recently added licensed HVAC to our suite of offerings.
The CPUC decision last December to transition new solar customers from Nem 2.0 to 3.0 has significantly negatively impacted our business.
We estimate a 75% reduction in sales inquiries after the rules changes went into effect last April, with number of contracts signed also significantly drastically reduced post April 15th. In additional to this huge drop off in sales, Nem 3.0 projects has forced our sales team to include battery in almost all sales and a sophisticated BMS (inverter) capable of peak load shifting to deliver stored solar power to the grid during high use times.
Additionally the VNEM and NEMA program sunsets on February 15, 2024 will also drastically reduce the viability for solar for many multi family/ commercial projects.
While the CPUC NEM 3.0 rule change decision provided a temporary boost in sales for Greenwired due to customer awareness of the transition and ability to lock into previous rate structure, if application was submitted before the deadline, our competent and efficient install crews are now working through our backlog of projects. We are hoping to avoid layoffs and keep our workers schedules full, continuing to deploy solar/ storage and HVAC on the north coast. Our conversations with other local installers convey a similar drastic downturn industry wide.
As an early community choice advocate on the North Coast and former member of RCEAs Community Advisory Committee for many years, I understand that RCEA has a complex array of priorities to navigate and fundamentally is trying to keep rates as low as possible for customers. I believe part of RCEA mandate is to support, whenever possible, local solar integration. We need more local solar integration to help meet CAs zero emission targets, yet these rule changes tragically incentivize the opposite.
I encourage the RCEA board to pass a resolution to direct staff to urgently define and deploy cost saving incentives for local solar deployment that would help alleviate this terrible crisis and allow for some continued deployment of residential and solar and storage moving forward on the north coast
Some examples of this could be
1)generation adders or further incentives to encourage residential and commercial solar/ storage beyond what is currently offered through SGIP.
2) ensure staff are continued to be fully engaged in community/ installer outreach to ensure accessibility to federal/ state rebates for energy efficiency upgrades, including solar storage HVAC, and home efficiency
We wanted to make the board aware of this urgent matter. We would be happy to work with staff to help define some of these ideas further. Alternatively, we would be available to make a presentation or participate at a roundtable a future meeting or RCEA event.
As board members for RCEA, we thank you all for your dedication to our local energy future! respectfully,
Matty Tittmann
Greenwired
4 Oral Communications
According to the North Coast Unified Air Quality Management District, the biomass plant in Scotia has been operating without a permit for two years. This indifference to the law fits a pattern of neglect that has resulted in numerous Clean Air Act violations after a failed smokestack test. Its neglect of periodic opacity monitor testing for six years casts doubt on its compliance with emissions standards during that time. Humboldt Sawmill Company was also served with a recent notice of Clean-Up and Abatement from the Regional Water Quality Board for polluting the Eel River.
Because burning wood to make electricity is an inherently dirty process, the state has set a low bar for the industry on the grounds that wood is renewable. The electricity it produces comes at the cost of higher CO2 emissions and more particulate and toxic air pollution than for any other electricity source.
Its record of not testing its equipment or bothering to file the documentation for its permit distinguishes it from other electricity producers, including other biomass plants.
In 2019 RCEA signed a pledge, sponsored by 350 Humboldt, to supply Humboldt county with clean, renewable energy by 2025. Biomass electricity in general does not qualify. Biomass electricity from Scotia fails even more miserably to inspire community trust. RCEA extending its contract with HSC to 2031 confounds all of us who support RCEA’s stated mission.
As the emergency of climate change intensifies, we must throw our support to real solutions. That includes solutions for how to dispose of woody waste. HSC apparently has no incentive to move towards alternatives other than incineration as long as RCEA buys its product. Please keep your pledge. and honor your commitment to help Humboldt county clean up its energy supply. You have ample grounds for ending your contract with Humboldt Sawmill Company.
Martha Walden
member of 350 Humboldt
You don't often get email from Learn why this is important From: Louis Rodriguez
To: Lori Taketa
Subject: FW: Comment for 1/24 board meeting
Date: Wednesday, January 24, 2024 9:56:24 AM
Wanted to make sure you have this one also. I didn’t say from Public Comment.
Louis Rodriguez
Customer Service Associate | Redwood Coast Energy Authority Office (707) 269-1700 x 306 | | www.RedwoodEnergy.org
Email: [email protected]
Pronouns: he/him
CONFIDENTIALITY NOTICE: We respect your privacy. Please review our privacy policy for more information. http://redwoodenergy.org/privacy/ The information in this e-mail may be confidential, subject to legal privilege, or otherwise protected from disclosure. No confidentiality or privilege is waived or lost by mis-transmission. If you are not the intended recipient or an authorized representative of the intended recipient, you are hereby notified that any review, dissemination, or copying of this e-mail and its attachments, if any, or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify the sender by return e-mail and delete this e-mail from your computer system.
From: Lynda McDevitt
Sent: Wednesday, January 24, 2024 9:25 AM
To: Redwood Coast Energy Authority <[email protected]> Subject: Comment for 1/24 board meeting
To RCEA Board,
I was shocked to hear that the Scotia Biomass Plant has been operating for 2 years without a permit from the NC Air Quality Management Board. This has allowed the Biomass plant to commit numerous violations which should null and void the contract it has with RCEA.
Cancel the contract immediately.
Sincerely,
Lynda McDevitt
January 24, 2024
Dear RCEA Board Members,
As a RCEA ratepayer for the cleanest greenest option offered, I urge you to keep your promise to provide all ratepayers electricity from 100% clean, renewable sources by 2025. Humboldt Sawmill Company’s (HSC) biomass plant does not provide clean electricity.
Biomass burning is dirty and pollutes our air. HSC’s biomass plant emits toxic pollutants and 2.5 micron particulates which are a major health hazard. HSC’s biomass plant emissions are a significant proportion of our county’s annual GHG emissions, almost 300,000 metric tons of carbon dioxide per year. HSC’s rebuttal to this statement is a quote from CARB Technical Support Document from California’s 2000-2015 GHG Emission Inventory (2016 edition): “The GHG inventory includes only the CH4 and N2O emissions resulting from the combustion of biomass fuels since the CO2 emissions would have occurred eventually as the biomass decayed.
These CO2 emissions labeled ‘from biogenic materials’ are estimated and tracked, but are not included in California’s GHG inventory total.” Compare the key phrase, “eventually as the biomass decayed” to the rate of CO2 emissions from burning biomass 24/7.When the rate of CO2 emission exceeds the rate of CO2 sequestration, atmospheric CO2 increases and global warming increases. From NOAA data printed on the front page of the Times-Standard, January 20, 2024, the Daily Average CO2 for the week beginning on January 7, 2024 is 3.95 ppm higher than it was for the same week a year ago, and 25.23 ppm higher than it was for the same time 10 years ago. This shows us that CO2 emissions are increasing at an increasing rate.
Thanks to Dr. Wendy Ring’s research, we have evidence of HSC’s many violations of the Clean Air and Clean Water acts, including water violations for polluting the Eel River. HSC’s continuous air quality violations while under contract with RCEA, documented by NCUAQ Management District (Notice of violation No. 14038 on dates 1/14/23, 1/19/23, 1/22/23) show us the company is violating conditions of the contract, and puts profit over the health and safety of our community. I strongly urge RCEA to implement the option of canceling the existing contract with HSC that applies into 2031. I prefer to have my ratepayer dollars go toward solar, wind, energy storage, geothermal, small hydro and wave energy conversion instead of welfare for the wealthy owners of HSC.
The HSC Scotia plant has ample area for utility scale solar, iron flow energy storage and microgrid installation to provide energy to assist running the mill and drying the wood and reduce the need for diesel used in black starts. I urge you to investigate options to help subsidize HSC to get them to move in this direction because ending the biomass contract alone will not reduce the current GHG emissions and toxic pollutants.
Thank you for having the courage to stand up to private for-profit corporations in order to serve the ratepayers in our County.
Diane Ryerson
Arcata, CA 95521
From: Patty Harvey
To: Public Comment
Subject: Comment for Thurs."s Mtg
Date: Wednesday, January 24, 2024 1:06:21 PM
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I moved to Hum. Co. for it's beauty and clear water and air. Now we hear that daily our air is being compromised; to wit:
Biomass power plants emit more greenhouse gas and air pollution than power plants fueled by fossil gas or coal. Forty percent of the Redwood Coast Energy Authority's (RCEA) renewable energy comes from a biomass plant emitting over 300,000 tons of carbon dioxide equivalent a year.
Please stop this outrage, especially given that the Scotia plant has been operating for two years illegally. Thank you,
Patty Harvey
Willow Creek
From: Wendy Ring
To: Public Comment
Subject: Public comment for 1-25-23 Board Meeting
Date: Wednesday, January 24, 2024 1:49:04 PM
Attachments: HRC, Title V permit 1-31-17.pdf
email from NCUAQMD with date of HSC"s permit renewal application.eml.msg Hi Lori. I could not figure out how to turn the attached email from the air district into a pdf. Maybe you can advise if the current format is not acceptable.
This comment is submitted on behalf of the Humboldt Coalition for Clean Energy, a group of 16 local green, faith, health, political, and community organizations and 2 statewide groups of doctors and nurses calling on RCEA to drop biomass from its renewable portfolio. You have received reports over the past 2 years about air and water violations at Humboldt Sawmill's biomass plant and lackadaisical enforcement by our local air district. Today we have even more disturbing news. For the past 2 years, the biomass plant has been operating without a Title V permit.
Title V permits are required by the federal Clean Air Act for every facility classified as a Major Source based on the tons of criteria pollutants it emits. These permits must be renewed every five years. The last permit, issued on 1/31/2017 expired on 1/31/2022. The air district's Air Pollution Control Officer Brian Wilson told me that the plant could keep operating legally under an application shield because it submitted a complete renewal application, but documents obtained under the CA Public Records Act and subsequent communications from Brian Wilson show that plant does not qualify for a shield because it submitted its renewal application in May of 2023, 2 years after the application deadline and a year and a half after the permit's expiration date. This is a blatant violation of the federal regulations and the air district's own Rule 502, with maximum civil and criminal penalties of over $7 million and 5 years in jail, although the air district's long history of leniency toward the plant and the lack of violations or shut down orders for lacking a permit over the past two years make it unlikely such stiff penalties will be imposed.
A clause in the biomass PPA, which is celebrated on your website and in reports to the CPUC as an example of RCEA's sensitivity to environmental justice and community concerns, allows RCEA to terminate the contract early in the event of environmental violations. You have a physician and public health expert bringing you data on emissions, public health impacts, and regulatory failures; a county health officer testifying that the biomass plant sends 7-8 people a month to the emergency room, and a county medical society asking you to stop contracting for biomass energy, but so far you've chosen to do nothing because Matthew Marshall says biomass is a good deal and reports that the air district tells him the biomass plant's environmental compliance is OK.
Things are clearly not OK. Biomass is dirty energy. Its full cost is not reflected on RCEA's balance sheets because most of it is externalized to the public, where it falls disproportionately on the most vulnerable members of society. Like any seller of a product, RCEA is morally responsible for the maintaining integrity of its supply chain, especially if the regulatory system intended to oversee it is broken. If RCEA lacks the staff, resources, or willingness to provide oversight of biomass energy's considerable environmental impacts, you should take this opportunity to remove it from your renewable portfolio. This might create a shortfall in meeting the RPS, but we doubt the CPUC would fine you for refusing to do business with a criminal, and it would only be temporary since RCEA has over 100 MW of new clean energy coming online next year and there is a glut of solar plus storage projects in CAISO's interconnection queue that will come online long before the biomass contract expires in 2031.
We have been unable to get on your board agenda to provide you with information that would better equip you to make decisions about biomass, but will soon be providing online “Biomass 101” trainings for the community covering the effectiveness of the Humboldt Sawmill Company biomass plant's pollution control and monitoring systems, relevant state and federal regulations and the air district's performance enforcing them, and the plant's reported emissions and their health and climate consequences. If you are interested in attending one of these training sessions, please email me and I will send you information on how to register. Alternatively, you could instruct RCEA staff to put a 45 minute presentation from our coalition (not a substitute or panel stacked with timber interests) on your own agenda. Below you will find links to documentation of the Title V permit regulations. The expired permit is attached, along with an email from Brian Wilson stating the date when HSC's renewal application was submitted.
350 Humboldt
Humboldt Unitarian Climate Action Campaign
EPIC
Northcoast Environmental Center
Women's Intl League for Peace and Freedom-Humboldt
Humboldt Health Care for All
Buddhist Peace Fellowship
HOPE Coalition
Redwood Alliance
Lost Coast League
Sierra Club Redwoods North Group
Friends of the Eel River
Humboldt Green Party
Humboldt Democratic Central Committee
Humboldt Progressive Democrats
Climate Health Now
CA Alliance for Retired Americans-North State
CA Nurses for Environmental Health and Justice
Code of Federal Regulations Permit issuance, renewals, openings, and revisions
NCUAQMD Rule 502 Application and permit requirements
Criminal Provisions of the Clean Air Act
From: Jon Reisdorf
To: Public Comment
Subject: Biomass code violations - Do what is right
Date: Thursday, January 25, 2024 10:16:39 AM
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We Very recently learned that the Scotia Biomass Plant has operated for 2 years without a permit NC Air Quality Management Board. This is unacceptable. Wehave lived in Humboldt County since 2004, moving because of its reputation for responsible stewardship of the environment. Allowing a Biomass plant Carte Blanche to commit violations should null and void the contract it has with RCEA.
Jon and Kathy Reisdorf
From: Sue Y. Lee
To: Public Comment
Subject: request RCEA to remove biomass energy from renewable portfolio Date: Thursday, January 25, 2024 1:16:40 PM
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Dear Members of the Board of Directors for RCEA,
The Humboldt Sawmill Co (HSC) biomass plant has been operating for 2 years without a permit as required by the federal Clean Air Act and in violation of provisions of the North Coast Unified Air Quality Management District. That HSC has filed a renewal permit application in May, 2023 over a year after the permit to operate expired, instead of 6 months prior to expiration, does not mean that HSC can keep operating according to State, Federal and local air district regulations. Given this violation by HSC, and under this circumstance, a provision in RCEA’s contract with HSC would allow RCEA to withdraw its contract with HSC for biomass energy.
HSC has also been found to have committed numerous air quality infractions, and are emitting nearly three hundred thousand metric tons of global warming carbon dioxide annually, a quantity equivalent to 80% of emissions from all Humboldt's passenger vehicles. As a consequence, the HSC biomass plant is endangering our planet’s life support systems and the health of our collective children and future generations, and that is a moral issue.
Given the health and climate impacts of biomass energy production by HSC, please do what’s morally right and protect the health of our planet and our children. Please pass a resolution to recommend that RCEA also do the morally right thing, and end its contract with HSC immediately and remove biomass electricity from its RePower renewable portfolio.
Thank you.
Sincerely,
sue y. lee mossman
RCEA Community Choice Energy customer
From: Wendy Ring
To: Lori Taketa
Subject: Please share with staff and board members. The air district is misquoting its own rules Date: Thursday, January 25, 2024 5:42:19 PM
Federal regulations and NCUAQMD Rule 502 (which restates the federal law) spell out clearly what is required for a facility to keep operating without a license after its permit expires. The permit renewal application must be submitted "timely" which federal regulations define as no less than 6 months prior to permit expiration. If the renewal application is submitted less than 6 months prior to expiration, there is no "application shield" and the plant has to shut down when the permit expires. Humboldt Sawmill submitted their permit renewal application late, 2 months before expiration.Since their submission was not "timely", the plant is not eligible to keep operating without a permit. I have excerpted the relevant parts of the CFR and NCUAQMD rule below. I was wrong about how long the permit has been expired because I asked NCUAQMD for the current permit, they sent me one dated 2017, but there is no question that the permit expired 6 months ago and the plant has been operating illegally ever since. This is just one example of the air district not enforcing EPA regulations. There are more which are even more serious in terms of potential harm to the public.
The exact language is provided below:
CFRTitle 40 Chapter I Subchapter C Part 70 § 70.5
§ 70.5 Permit applications.
(a) (1) Timely application.(iii) For purposes of permit renewal, a timely application is one that is submitted at least 6 months prior to the date of permit expiration, or such other longer time as may be approved by the Administrator that ensures that the term of the permit will not expire before the permit is renewed. In no event shall this time be greater than 18 months Title 40 Chapter I Subchapter C Part 70 § 70.7
(c) Permit renewal and expiration."Permit expiration terminates the source's right to operate unless a timely and complete renewal application has been submitted consistent with paragraph (b) of this section and § 70.5(a) (1)(iii) of this part."
NCUAQMD Rule 502
A 2. Application Shield: If a responsible official submits, pursuant to Regulation V, a timely and complete application for a permit, a source shall not be deemed in violation of the requirement to have a permit to operate until the APCO takes final action on the application. [Reference: 40 CFR 70.7(b) and (e)(2)(v)] B 2. Permit Renewal: For renewal of a permit, a responsible official shall submit a complete standard application no earlier than 18 months and no later than 6 months before the expiration date of the current permit to operate.
A responsible official shall submit applications for renewal of permits to operate for all emissions units at a stationary source for simultaneous review. [Reference: 40 CFR 70.5(a)(1)(iii)] Here are links to the sources cited above.
Code of Federal Regulations Permit issuance, renewals, openings, and revisions https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-70/section-70.5 NCUAQMD Rule 502 Application and permit requirements
Criminal Provisions of the Clean Air Act
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