|Carolyn Dumaresq||no email address available|
Email sent to trustees this morning (11.15.13 Watt Email to PSU Trustees)
Penn State’s current approach to sustainability ignores the difference between complex problems and difficult problems. A complex problem makes it hard to know what to do. A difficult problem makes it hard to do what must be done. Energy conservation – sealing building envelopes and rationing electricity use – is not complex. It’s difficult. It requires more money for supplies and for physical,rather than intellectual, labor.
The university has no public Energy Strategic Master Plan, and no conservation and renewables coordinator on OPP staff. There’s now an alumni fund soliciting donations to support conservation and renewables (as of November 14, 2013) but it includes no public accountability mechanisms. OPP representatives have never conveyed the urgent need for conservation to the Board of Trustees or requested adequate funding for conservation measures and renewable installations that would – over time – allow the coal-fired boilers and steam heat system to be decommissioned rather than replaced with another fossil fuel-dependent system.
Instead, in the last six months, OPP staffers have repeatedly announced plans to install a Combined Heat & Power (combustion turbine/heat recovery steam generation) unit, to expand the West Campus Steam Plant after the initial $56.3 million boiler replacement and gas pipeline installation. Steam Services Superintendent Paul Moser presented the CHP plan as part of an EPA webinar on April 30. It was presented to the PSU Board of Trustees on July 12. OPP Director of Energy & Engineering Rob Cooper and Moser presented it again at the September 12 “Our Energy Future” public forum, and at the September 19 State College Planning Commission meeting.
Each time, OPP compared the CHP project to a Prius, characterizing CHP as an efficient and reliable mid-point between inefficient coal-fired utilities, and renewable energy such as solar, wind and geothermal. But another community activist with expertise in air quality regulation said a better characterization of CHP at Penn State would be a Prius shaped like a box, running on square wheels: if an efficient steam and electric plant supplies heat and power to inefficient end users (14 million square feet of energy-porous University Park building stock), gains in efficiency are lost.
Despite all the public promotion, the CHP phase is not included in Penn State’s application for permits to begin converting the WCSP from a coal-gas mix to primarily gas, in violation of state law prohibiting incremental phasing of projects to circumvent emissions regulation, including New Source Review. Community activists raised this legal issue at the October 30 DEP hearing, along with other vulnerabilities including publication of two significantly different current emissions data sets; use of space constraint in “best available technology” analysis (emissions and cost are relevant factors); retroactive revisions to 2010 and 2011 emissions data for particulates; failure to include Compliance Assurance Monitoring (CAM) provisions (a potentially improper use of the “permit shield”; failure to include radionuclide emissions assessments; and violation of the State College Community Bill of Rights air quality provisions.
After that meeting, Matt Dahlhausen (MS Architectural Engineering student and community activist) spoke with Assistant Vice President for Physical Plant Steve Maruszewski, reporting: “Steve was upfront that they’d like to do the CHP project as soon as possible, but are delaying it to avoid triggering NSR.”
A week later, Rob Cooper and project consultant Jim California appeared before the State College Planning Commission again. Eighteen minutes into the November 6 presentation, California said: “I’m going to show here, in a minute, the other locations where successful combined heat and power plants have been put in populated areas at other universities, as examples, to show you that we’re not really doing something here that’s unique.” Less than an hour later, Cooper informed the commission that the CHP is “not a real project,” because “we do not have funding” and the CHP is not in the OPP’s five-year capital plan.
To which Planning Commission Chairman (and Councilman-elect) Evan Myers remarked: “You can’t have it both ways.”
Similarly, Penn State officials have repeatedly claimed that the purpose of the WCSP gas conversion commitment is to “comply” with new Maximum Achievable Control Technology (MACT) standards, which apply to emissions units such as coal-fired boilers. Their written filings show, however, that the WCSP conversion is designed to avoid major source MACT standards, area source NESHAP rules, and facility-wide New Source Review. Their NSR dodge in particular is predicated on a netting analysis that includes misrepresented baseline and projected emissions, along with incremental phasing; both were flagged by an EPA reviewer (Gerallyn Duke) in an August 28 letter to DEP officials Muhammad Zaman and Thomas Calhoun.
Community activists have been musing lately about the accountability, motivations and good faith of OPP leaders. Some OPP representatives have complained that they feel unfairly demonized and besieged, because they don’t control energy strategy, the Board of Trustees does.
Yet when I asked PSU trustees, via July 11 email, to decisively lead the university away from fossil fuels and toward conservation and renewables, trustee Paul Silvis replied, by email July 21, “Thank you for your comments. We rely on Penn State professionals to make these decisions,” indicating that trustees – or at least Silvis – don’t consider the board at all responsible for strategic energy policy, only for ratifying and funding OPP decisions.
Cooper answered similar questions at the September 12 public forum, inviting members of the public to review the Energy Strategic Master Plan under OPP supervision, and explaining that: “OPP establishes energy goals, analyzes technologies and projects to meet those goals, and recommends the best ones to top leadership and then the Board of Trustees for approval and funding. Once approved, it is OPP’s responsibility to implement the projects and ensure that energy goals are met.” Then OPP’s Engineering Services Manager Ian Salada, under the direction of Cooper and Maruszewski, personally refused to allow public review of the ESMP on October 4.
Again, they can’t have it both ways. OPP can’t simultaneously be constrained by another entity such as the Board of Trustees, and in full control of energy decisions and planning documents.
Hundreds of millions of dollars are now slated for new construction under the current five-year capital plan presented to trustees September 19, including a $140 million Chemical & Biological Engineering building, and a $69 million data center. That money must be diverted to bringing the aging existing building stock up to high energy efficiency and safety standards; Dahlhausen estimates “the campus energy waste is so great and the project scope so large that it will take more than $100 million and at least a decade to do enough energy efficiency work for renewables to be effective.”
Making that investment will support local construction workers and their families and cut emissions, while making Penn State far more resilient to natural gas and other fossil-fuel price volatility and supply disruptions.
The key goal is to reduce winter peak load and thus needed peak production capacity. To date, OPP staffers have dismissed community-generated alternative energy plans (such as the Rybacki Proposalsubmitted to PSU leaders in mid-September) by failing to distinguish between the energy implications of converting the entire campus to geothermal at current consumption levels, and making deep conservation retrofits the highest budgetary priority, to reduce the campus-wide load, followed by geothermal deployment at the decreased consumption levels.
Until Penn State’s leaders figure out how difficult our societal energy predicament really is – and fully engage in energy master planning and alternatives analyses that account for the whole life-cycle of energy production, distribution, consumption and emissions – the physical campus is nothing more than a large salvage yard in the making, and the educational programming is a temporary anachronism: a throwback to more prosperous times.
In the meantime, community members must continue to educate ourselves about Penn State’s leadership predicament, measure PSU’s transparency aspirations against actual performance, and hold decision-makers accountable through constructive criticism of institutional representatives and their public statements about energy planning.