November 21, 2006

Rick Bolfing

Bureau of Air and Radiation

Kansas Department of Health and Environment

Curtis State Office Building

1000 SW Jackson Street

Topeka, Kansas 66612

Dear Mr. Bolfing:

The Lawrence City Commission would like to submit the following comments on Sunflower Electric Power Cooperation’s proposed air quality construction permit for three new 700 megawatt coal-fired steam-generating units and associated ancillary equipment at their generating station located in Holcomb, Kansas.  We ask that the Kansas Department of Health and Environment recommend that the Governor of Kansas place a moratorium on the construction of additional coal-fired plants in the State of Kansas until a feasibility study is completed regarding the potential for the use of renewable energy.  The study should address the true costs of coal to the Kansas consumers, and compare it to the costs of using renewable Kansas resources including wind and solar. 

The Lawrence City Commission based its decisions on a wide array of factors, but submits the following four as the most critical:

• The citizens of Lawrence and of Kansas are not served by the construction of these coal fired power plants. Kansas will only use 8% of the energy generated and the rest will be sold to Colorado, New Mexico, and other western states.
• Once completed this plant will emit 16,700,000 lbs. of CO2 a year.  The whole Northeast agreed to cut their carbon emissions by 24 million tons annually by 2020 (RGGI).  If they are able to reach that benchmark, this single plant will effectively nullify 70% of their efforts.

• While the energy this plant creates will go west – all the polluting aspects of the plant will go northeast – to Lawrence and beyond.  We already have smog and mercury advisories in the eastern portion of our state and in Missouri.  We do not need more particulate pollution or more mercury contamination.  Nor does anyone on the globe want the CO2.
• Kansas has other options that will provide greater economic benefits and will not damage our health and environment.

The proposed Holcomb plant will be located in the heart of Class V wind territory.  As a Commission we would like to reference the attached study produced by Dr. Ray Dean, Professor Emeritus of the University of Kansas.  The study shows that a combination of wind and gas-fired energy would actually create more jobs than the proposed Holcomb plant, and would create far-greater economic stimulus for the state of Kansas.  Economic impacts would be spread out among many small western Kansas communities and to the farmers and ranchers who can place wind on their property.  The study also shows the wind in that region is consistent enough to avoid problems with intermittency in the grid.  The utilities argue that we have problems with transmission – but they are willing to put in the lines to transmit the coal-fired energy.  We suggest that the utilities build the same transmission lines but use a combination of gas-fired energy, wind, and solar.

Coal-fired Energy is not the cheapest form of energy for Kansans in the long term.  It is understood that the cost of coal will rise.  It is understood that the cost of transporting it will rise.  The imposition of a future federal carbon tax is anticipated with implementation between 2012 and 2015. Those costs would significantly increase the base costs of coal-fired energy and all of those costs would be passed on to ratepayers if approval is given to the proposed plants. .This does not account for the external costs of coal-fired energy such as asthma, heart attacks, strokes, mercury impacts, and global warming.

Lawrence is doing its part to improve energy efficiency and increase the use of sustainable renewable power.  Examples include:

• Our adoption earlier this year of the US Mayors Climate Protection Agreement, which pledges Lawrence to review our emissions and take steps to reduce global warming. 
• We are also participating in the Cool Cities Program of the Sierra Club
• Lawrence is now officially a member of the U.S. Green Building Council and is reviewing LEED  (Leadership in Energy and Environmental Design) opportunities in the design and operation of City facilities.
• As part of EPA’s Green Power Community, Lawrence has purchased “Green Tags” which support wind and solar renewable energy resources to replace our fossil fuel based energy sources.

The success of our local efforts directly depends on the development of additional resources of renewable energy. We believe the development of additional coal-fired power plants will be a disincentive to investment in renewable energy projects.

Lawrence supports the economic development of all parts of our state, including western Kansas.  Kansas has the opportunity to become an innovative leader in renewable energy.  We have one of the greatest wind resources in the nation – we should use it to benefit the entire state of Kansas. We believe Western Kansas can see the same or greater level of economic benefit from the development of renewable power as they expect to see from additional coal-fired plants in Holcomb.

Respectfully submitted,

Mike Amyx

Mayor