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Earthjustice attorney says WindCup EJIS understates ongoing emissions; urges top-down analysis and boiler electrification
Summary
An Earthjustice attorney told the hearing WindCup's EJIS fails to treat ongoing emissions as part of a disproportionate impact, cited the company's recent VOC release figures, and urged a top-down technical feasibility analysis including electrifying boilers to reduce emissions.
Colin Parts, an attorney with Earthjustice, told the hearing that WindCup's Environmental Justice Impact Statement misapplies the rule when it treats the renewal as avoiding disproportionate impacts while acknowledging ongoing emissions.
"WindCup's ongoing emissions do actually contribute to a disproportionate impact on the community under the plain language of the EJ rule, contrary to WindCup's assertions," Parts said, arguing that the EJ analysis should start with the most protective control measure and then explain why it would not be adopted. He noted the EJIS shows WindCup released nearly 58 tons of VOCs in 2024 and said that fact, coupled with local air-pollution stressors, requires a more rigorous top-down technical-feasibility analysis.
Parts urged that the EJ rule allows facility-wide changes, including replacement of polluting emissions units, and specifically recommended electrifying the facility's boilers as an example of a control measure that WindCup should evaluate. Consultants and company representatives answered some technical questions but said they would provide formal written responses to several points raised by participants.
