Big unanswered questions Mr. Canfield!

I have asked some very simple questions that you have not answered and the public wants some answers. And don't put your political spin on them, answer them precisely.

Here they are:

First point: The EPA on 1/24/08 published a advance warning about the emissions. You said that the GM informed the board 12-18 months later and after LL&P spent 250K. Why didn't he advise the board before the upgrades took place. He is the hired professional that is supposed to know this. The warning told power plants about the upcoming emission rules IN 2008 not after LL&P made the upgrades and don't try to put a spin on this Question! You said that you read the EPA's website but you didn't answer the question!

Here is my previous response for the second time jan 27th

you must have missed my response in the Dear Voice post, even though you responded to it. here it is copied from that post Jan 20th

Our current Diesel Generators, in place on Water St at the main office, have rarely run in the last 7 years. Due to the age, 50+ years old, they are inefficient, with high operating costs and would only be called upon in brownout, peak demand load situations. In 2008, with the new President and Admin, stricter rules were proposed and implemented and the Board & GM discussed the repair costs and decided to invest $250K so that the generators could be operated.

12-18 months later the Board was informed by the GM that additional requirements were coming that would require additional upgrades at which time the Board discussed and unanimously voted to pull the plug on them. Some of the recent upgrades, such as switching gear would hopefully be used on the new generator install. I went to the EPA website and looked at one of the nine notifications that came out in the four year period 08 to 12. About 20 pages, enough to make your eyes glaze over reading it. I didn't bother trying to read the other 8.
LL&P belongs to state and national groups that assist us in operations and advising us on where the industry and regulation is going. We consider their input also. While I don't recall every detail years later, the Board made that decision, not the GM.

For the Third and Final Time, since my usually accurate memory is not good enough, I went to the trouble of locating the physical documentation you insist on as an answer. I have in my possession, a 5 page document from the American Public Power Association which opens with

" In March 2010, the Environmental Protection Agency(EPA) issued its final rules revising the National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. The new rules, which are incorporated into the existing RICE regulations, for the first time subject many previously unregulated engines, including those designated for emergency use, to Federal Regulation."


I will attach the first page as soon as I find a 10 year old to help me.

Second point: Is it true that you cannot run the new Combustion turbines from the month of Sept. to May due to a lack of natural gas?
Here's your response:
"The gas supply problem has several solutions and as board minutes show we were aware of it early on."

What are the solutions??? That was not an answer. I know you knew early on about the problem. I want to know what you are going to do for fuel in the winter!

again answered previously on JAN 28 Consumers Energy's line to Lowell does not have the capacity at this time to provide adequate pressure during periods of high demand (in the extreme cold). This can be solved by using a compressor to increase the pressure or there are other vendors interested in providing gas that we are working with. There is also an currently unused 6" line from Chicago to the Dependable Gas property that if viable could provide gas to Lowell and LL&P might be able to provide gas to Lowell residents at extremely competitive rates like it does electric.


And according to your last thread they might not run due to cheaper available power but be there in case of disaster.

Did we need to spend over 2 million on two combustion generators for a possible disaster that will take out the entire grid? And these gens don't make enough power to supply the entire town. We need between 9 and 13 megawatts. Combined they only make 7.5 meg. AND once again what happens when this disaster is in the winter and you have no fuel?


LL&P can operate the Combustion Turbines to provide electricity for residential and commercial customers during nonpeak periods to keep the lights on. some adjustments may need to be made by large industrial customers to allow LL&P to maintain the load consumed at 8 megawatts. I don't have the exact number but I believe it to be far less than $2 million, probably closer to $1 million and it is planned for in our capital
improvements budget without borrowing money to complete the project. As an illustration, currently power is purchased wholesale for 5 cents per KWH from existing coal fired generation that we have purchased an operating share of. As demand increases, say on a very hot day, additional peaking generation is called into production at higher costs of possibly 9 cents per KWH. If the cost of local generation is 7 cents per KWH, most of the time , LL&P and its ratepayers are better off using the power that is available for 5 cents per KWH. That's why the CT probably won't run on a daily basis, until the day in the future when they are the cheapest generation after Coal Fired plants are legislated into extinction.


You didn't reply to this question either!

True or False: It takes a 300 hp and a 100 hp or a 150 hp electric motor to start them, that is 295 kilowatts to 335 kilowatts of electricity. How will you start them if they are not running and the power goes out? That is an VERY large portable electric generator that I don't believe LL&P owns.

Only one CT would be started at a time. At present, LL&P intends on using the CHP engine/generator from the BioDigester to provide emergency power to cold start one of the CT's in the event of a power outage.


Or this one!
]
Third point: The biodigester; I have been told it will only produce around 850 kilowatts. That will not meet our required 10% green energy so we will still have to purchase green energy from the open market. True or false?

False, The BioDigester will provide the required 10% to meet the renewable energy criteria. We also have renewable energy credits built up from our contract with the Grainger Landfill Gas Generation that would insure we meet or exceed our requirements.

Or this one!

Why did LL&P chose a biodigester where only one existed in the world? Why not a more pr oven design or at least a more common one. The City of Grandville just added an anaerobic digester that didn't come from Germany and it was placed at there waste water plant, were the fuel is, not in the middle of town. Our plant is on the outskirts of town. It would provide some of the fuel and the trucks that will be bringing the rest of the fuel won't have to travel into the city.

There are many anaerobic digesters in the world. Anaerobic digesters have been upgraded to incorporate upflow/downflow/reflow systems which produce an extra 20% of biogas from the same feedstock as a non UDR system. 15 systems utilizing the UDR system have been developed, implemented and in operations for at least two years in Europe

True or false: Did the DEQ stop the installation of the combustion generators during an inspection mid summer due to lack of permits?

Oh you responded to this by saying:

"There were delays in getting all the DEQ permits in place, but they are in place now, including the clean air permit. I am not aware of the project being shut down at any point."

LL&P filed for its air permit to operate the combustion turbines on July 24th. On August 23, the DEQ conducted an inspection of all LL&P facilities as part of the permit review process. LL&P did not believe, based on previous knowledge and information, that setting the newly delivered CT's on their eventual location was considered "installation construction". Our understanding was that all of the Electrical, Mechanical, Ducting and Plumbing was the installation construction. The DEQ disagreed, but understood our position. As a formality we received a violation notice on Sept 5. We responded to the notice on Sept 11 and no further action was required or taken by the DEQ. The permitting process continued with no further complications and was approved as submitted on Dec 3rd.

That is a LIE.

Really, I say I am not aware of the project being shut down and you call me a liar. You complain that no one will respond to you but look how you treat someone who is just trying to get the truth out.

I talked to the DEQ and they did shut you down for starting construction without having your clean air permit. He said he stoped the construction when he made an inspection of the site for the clean air permit. If I have to I will get his name and phone # so everybody can call. Is that what you want???

I called the DEQ today at 356 0500, and spoke with Heidi. She confirmed the a information I posted a couple paragraphs up.


You didn't answer this question:

True or false: Doesn't the planning commission require ALL permits before the start of any construction?

See above explanation. yes we set the CTs in place before the permits were final. lock us up and throw away the key.


We already know this one:

True of false: Was the board aware of the problems that Mr. Pierce encountered in Travers City before he was hired?
But you still hired him anyways.

You've beat this horse to death, let it go.



This question you really focused on probably to try to divert attention to the other bigger questions. And then you tried to spin it like a politician. "they abused the coffee pot", please...

True of false: Did LL&P take the coffee pot away from one of their union employees just to latter return it when the public found out.
If so, would that be why worker moral is so low among the workers that joined the union?

This is an internal matter. as previously stated the Board manages the GM and does not micromanage the employees.


You didn't answer this one either:

True or False: Has LL&P added multiple surcharges to rate payers bills in the last couple years.

The surcharges on your bill are set by the Public Service Commission, and while I did not get a chance to look at them, these are regulated charges that allow power companies to recover costs without raising rates. Electric Rates have risen due to increased generation costs. LL&P rates are 12-15% below Consumers Energy who serves most of the outlying community with less reliable power than we have here. The same surcharges are added to Consumer's customers also. Its how electricity is sold now.

I know that LL&P hasn't raised the rate of Kilowatt per hour but due to these added charges their bills have gone up considerably.



One other thing, if in your own words:
"Employees wanting job security and those supporting them would like the union to take over management rights that currently belong to the LL&P Board. The right to Hire, Fire and manage employees needs to remain locally controlled, with final decisions being made by the Board of appointed community residents, not an arbitrator and attorneys from outside the area, whose main motivation is billable hours."

If this is so why do we have a great police force, that has been in a union for years, and has not crippled our city? The city and the Lowell police dept has been negotiating contracts for years without the city hiring a specialized labor attorney and due to Act. 312 the police has guaranteed 3rd party binding arbitration. Arbitration is neutral and fair so why would LL&P and the city not want it's other employees to have the same right?

Actually while we do have an excellent Police Department, the cost of that Department is a problem. About 1/3 of the city budget, $800,000 of 2.4 million goes to the police department. Previous City Councils have discussed using the Sheriff as a cost saving measure. This union contract is not a renewal. its a brand new deal that has to be made. The members joining a union is not a problem for the board or management. Expecting us to give up local control is.

This isn't mudslinging. These are simple, straight forward questions that I and some other ratepayers would like to have answered.



Read more: voiceoflowell.freeforums.net/index.cgi?board=general&action=post&thread=19&page=1#ixzz2JQ8j3wf2

Mr. Canfield, I will rebuttal claims with this:

1. The old generators: The "advance notice to rule making" from the EPA is all that is important. 1/24/08 is when it was released! Why do they call it a "advance notice"? The EPA does this to warn you of upcoming rulings so you don't make a investment of $250,000 in generators and then decommission them due to the cost of "diesel retrofit controls". I don't care about the final ruling. The EPA warned you on 1/24/08. A year before LL&P started the upgrade. LL&P wasted $250,000 END OF STORY! And because I know you won't admit that Greg Pierce made a mistake that cost the rate payers of LL&P a quarter million dollars I have copied a segment directly from this "Advance notice of proposed rule making"
1/24/2008.

I want you to take notice to "diesel retrofit controls" or the things that made you decommission the generators!

"EPA is considering
focusing on non-emergency diesel
engines that were built before 1996 and
that are rated greater than 300 BHP,
although EPA is open to alternatives
that commenters may propose that are
well supported with appropriate data.
We are focusing on non-emergency
engines, because, while they represent
only 20% of the total number of
stationary engines, they are responsible
for a significant amount of HAP
emissions from stationary engines. EPA
is considering focusing on pre-1996
engines because, generally speaking,
emissions controls were not
implemented in a significant way on
nonroad diesel engines until the 1996
engine model year. Thus, the pre-1996
engines represent stationary engines
that EPA believes are largely
uncontrolled. In addition, diesel retrofit
controls are typically more cost effective
and technically feasible the larger the
engine. 30 When these three criteria
are combined, it comprises a set of
larger, older non-emergency engines
that represent the majority of PM and
toxics emissions from non-emergency
engines as a whole"

This my first reply that demonstrates that you are trying to conceal the truth from the public. Please once again save your fingers and don't reply because this document from the EPA is proof. EPA, RICE rules, January 2008!

Mr. Canfield my next point. You said:

" As an illustration, currently power is purchased wholesale for 5 cents per KWH from existing coal fired generation that we have purchased an operating share of. As demand increases, say on a very hot day, additional peaking generation is called into production at higher costs of possibly 9 cents per KWH. If the cost of local generation is 7 cents per KWH, most of the time , LL&P and its ratepayers are better off using the power that is available for 5 cents per KWH. That's why the CT probably won't run on a daily basis, until the day in the future when they are the cheapest generation after Coal Fired plants are legislated into extinction"

You mean to tell us that you bought two expensive generators, one of which was built in 1984, to sit around and wait until coal fired plants are legislated into extension? When the heck is that going to be, 25, 50, 75 years from now??? This much money spent "not to run on a daily basis" you have got to be kidding me.

HOW MUCH MONEY HAVE LL&P SPENT ON THESE COMBUSTION GENERATORS??? As a rate payer I want to know the exact dollar amount, now. Not ten years from now. I want to know how much money was spent on something that is barley going to be used. And if they are going to be used often, then how many hours a day or week, month or year they will run. Oh and I would like to know if they will run at full power in the winter months?