December 2, 2009
Ms. Debra Dalcher
ADEC Air Quality
619 E. Ship Creek Avenue, Suite 249
Anchorage, AK 99501
Dear Ms. Dalcher:
The Resource Development Council (RDC) would like to express its strong support for the Draft Renewal Title V Operating Permit AQ0173TVPO2 for Golden Valley Electric Association’s Healy Clean Coal Plant (HCCP).
RDC is a statewide membership-funded organization founded in 1975. Our membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.
RDC supports the Alaska Department of Environmental Conservation’s determination that a Prevention of Significant Deterioration (PSD) review does not apply to the restart of the HCCP. RDC agrees that the long-delayed commencement of the normal operation of the PSD-permitted plant does not require a major modification triggering another PSD review.
The permit for this plant as well as a smaller adjacent coal plant has been renewed once already since it was first issued. The plant has extremely low emissions and permit terms allow for even lower permit limits based on actual operations. Moreover, Golden Valley itself has a strong compliance history with permit terms.
Timely renewal of the permit is in the public’s interest as access to more power generation is important to Alaskans because of the increasing shortages of natural gas in Southcentral Alaska, which has caused Chugach Electric Association to reduce much of the surplus gas-fired power that it previously sold to Golden Valley at attractive rates. Energy from the HCCP would benefit Golden Valley ratepayers and Southcentral Alaska utilities as power from Healy could be sent south in power shortages or emergencies. In addition, the infrastructure is already in place to generate and transport electricity from this plant.
In conclusion, RDC strongly supports the Draft Renewal Title V Operating Permit for Golden Valley’s clean coal power plant at Healy. RDC appreciates the opportunity to comment on this important permit and looks forward to its timely renewal and the subsequent full operation of the Healy facility.
Sincerely,
Resource Development Council for Alaska, Inc.
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