Below are the detailed and thoroughly researched comments submitted by Dr. Karim Ahmed to the Connecticut Siting Council regarding the proposed fracked gas plant in Killingly. On June 6, 2019, just a few days after the comments closed, the CT Siting Council and DEEP greenlighted this project, raising the question – did they even read the comments submitted? It is hard to imagine that they did. We don’t need another fracked gas plant in Connecticut – we need clean, renewable energy from wind and solar. Ironically, the Governor took the right step in that direction when he signed the Offshore Wind Bill into law on June 7, but it shows the cognitive dissonance that our government is approving clean wind and dirty fossil fuel power in the same 24 hour period.
May 30, 2019
Melanie Bachman, Executive Director
Connecticut Siting Council
10 Franklin Square
New Britain, CT 06051
RE: Killingly Energy Center, NTE Connecticut, LLC
Killingly, Connecticut
Docket No. 470B
Via electronic mail: siting.council@ct.gov
Dear Ms Bachman:
I write these comments with regard to the above listed proceedings, which is related to NTE Connecticut’s application for a reopening of the original Docket No. 470, requesting approval for a proposed natural gas electric power plant to be built at the Killingly Energy Center in Killingly, CT. While speaking as an individual, though reflecting the views of many residents in the State of Connecticut, it is my sincere hope that the Connecticut Siting Council will not grant approval of this request. I will summarize my opposition as follows:
- Contrary to testimony entered in these proceedings, the siting of natural gas power plant in our state is neither the most cost-effective alternative nor an interim bridge to the future production of renewable energy in Connecticut and the New England region as a whole.
- There are serious impacts on human health and global climate change when natural gas production activities, chemical waste disposals and pipeline transmission leakages are taken into account, especially those planned natural gas deliveries made to Connecticut from fracking operations in the Marcellus Shale deposits in nearby Pennsylvania.
- There is no compelling reason why another fossil fuel power plant (proposed capacity of 650 MW) need be built in this region at this time, when a bipartisan bill in the Connecticut State Legislature was overwhelmingly approved (134-10) by the House on May 14, 2019, authorizing the construction of offshore wind turbines generating electricity of up to 2000 MW.
Let me introduce myself. Currently, I am an Adjunct Professor of Occupational and Environmental Medicine at the University of Connecticut Health Center (UConn Health) in Farmington, CT, where I teach graduate courses in children’s environmental health, risk assessment/risk management, sustainable development and environmental ethics. I also hold an Honorary Professorship at the School of Public Health and Family Medicine at the University of Cape Town in South Africa.
For the past thirty years, I have served as a Board Member and Secretary-Treasurer at the National Council for Science and the Environment (NCSE) in Washington, DC. Previously, I was Senior Staff Scientist and Research Director at the Natural Resources Defense Council (NRDC) in New York City, and Deputy Director of Health, Environment and Development at the World Resources Institute (WRI) in Washington, DC.
Since 2006, I have been a resident in Connecticut. In presenting these comments, I shall forward the views of several colleagues and fellow congregants of mine at two faith-based institutions in the state – (a) Immanuel Congregational Church, Hartford, CT, where I am a member of its Environmental Action Committee, and (b) Interreligious Eco-Justice Network (IREJN), as a senior adviser and former board member.
Here are my views and concerns on the applicant’s request for approval in greater detail;
- Natural Gas is not an appropriate fossil fuel bridge to a renewable energy future: In testimony presented to the Siting Council, NTE Connecticut spokesmen have stated that the use of natural gas for electric power generation at this time would serve as an appropriate means to bring renewable energy to the New England region. Because of the intermittent nature of solar and wind power, a natural gas power plant, supplemented by ultra-low sulfur distillate (ULSD, i.e., dual-use diesel fuel), would provide a steadier and more reliable source of electricity. While this may appear to be reasonable at first glance, it is based on an assumption that the cost of purchasing natural gas will remain at current low market prices for the foreseeable future. In other words, the choice of natural gas in power production would be cost competitive to other alternatives. On the other hand, the opposite, in fact, may be true – the cost of renewable energy will continue to fall, making natural gas a less attractive option.
According to the US Energy Information Administration (EIA), natural gas prices are expected to remain stable around $4.00 per 1000 cubic feet in the next few years, while its domestic consumption rate rises slightly, from an estimated 82.7 billion cubic feet per day (bcf/day) in 2019 to a projected 83.5 bcf/day in 2020.[1] Although natural gas power production may appear a cost-effective option today, it has done so at the expense of existing coal burning plants being shuttered in many regions of the country. Hence, it is likely that as demands for natural gas increases, with acute shortages appearing in the market place, it will be unable to maintain its current low price ranges in the commercial and industrial sector. For these reasons, the Siting Council should take these potential short to medium term supply and demand developments in the natural gas market into account.
Now, let us take a look at the renewable energy sector. Here the picture looks dramatically different than it did a decade ago. Using the Levelized Cost of Electricity (LCOE) as a measuring stick, we are able to compute the net present value of the unit-cost of electricity of various power production options over the lifetime of a generating entity. According to the authoritative Lazard report, for wind energy power production, the drop in lifetime cost fell by 69% from 2009 to 2018 – i.e., from LCOE of $135/MWh to $42/MWh. During the same period, the decrease for solar energy was even more drastic – a 88% drop in LCOE, from $359/MWh to $43/MWh.[2] Moreover, when seen in comparison to other power generation options – natural gas, coal and nuclear – the solar and wind energy sector at present has essentially overtaken them in life-time cost-effectiveness, as seen in the table below:
| Production Option | Wind (On-shore) | Solar PV (Utility Scale) | Gas Combined Cycle | Coal | Nuclear |
| LCOE ($/MWh) | $29 – 56 | $36 – 44 | $41 – 74 | $60 – 143 | $112 – 189 |
- Natural gas fired power generation, when viewed from a life-cycle perspective, have significant impacts on public health and global climate change: All too often, the proponents of continuing use of natural gas in the residential, commercial or industrial sector, view its human health and environmental impacts from a misleadingly narrow point of view. Even though natural gas produces half as much carbon dioxide as coal during combustion processes (emitting 117 pounds of CO2/million BTU versus 205 to 230 pounds of CO2/million BTU for coal), it consists primarily of methane gas (66% to 77%, depending on its source). Methane is a powerful greenhouse gas. Its global warming potential (GWP) ranges from 21 to 56 times greater (based on a 100 to 20 year time frame) than carbon dioxide.[3] Thus, the presence of methane in the atmosphere is considerably more potent than carbon dioxide in its impact on climate change and global warming.
In a recent comprehensive study conducted by the Environmental Defense Fund and 15 leading universities and research institutions, methane emissions in the United States from oil and natural gas supply chain were estimated. Using both ground-based measurements and aircraft observations, the authors of the report found that such methane emission was equivalent to 2.3% of all natural gas production (or 13 teragrams per year), which arose from extraction and processing activities, and from leaks in natural gas transmission and distribution. All told, such uncontrolled methane emission’s impact on global warming was equivalent to a 20-year contribution of carbon dioxide emissions from natural gas combustion at the user end.[4] Hence, placing these findings within a fossil fuel supply chain framework, provides us with a more accurate portrayal of the overall impact of natural gas production and consumption on global climate change. This point of view was clearly expressed by Joseph Daniels, Senior Energy Analyst at the Union of Concerned Scientists:[5]
. . . if the industry builds out gas infrastructure in a way that at all follows the trajectory EIA [Energy Information Administration] has projected, it will be virtually impossible to decarbonize the power sector and achieve a net-zero emissions economy by 2050. When it comes to gas, the utility industry is repeating the same mistakes it made with coal: ignoring environmental costs, market trends, and lack of public support.
Since over two-thirds of natural gas supply today is derived from hydraulic fracturing (“fracking”) processes, it is necessary to see the public health impacts of this fossil fuel extraction technology at close hand. According to petroleum industry sources, 1.7 million production wells have used the fracking process to extract oil and gas in the past, producing some 600 trillion cubic feet of natural gas in recent years.[6] Today, fracking natural gas is certainly a booming industry; however, a well kept secret in the industry is that it has yet to turn a profit for its many nervous investors.[7] Thus, there is a tendency to keep its extraction, processing and waste disposal costs as low as possible. While the New England states still import liquefied natural gas at present, there is increasing pressure to start transporting fracked natural gas from the extensive Marcellus shale deposits in Pennsylvania to the Northeastern region.
Spanning some 95,000 square miles, the Marcellus shale formation covers substantial portions of Pennsylvania, West Virginia, New York and Ohio. It is the largest natural gas deposit in the country, with an estimated reserve of some 77 trillion cubic feet of natural gas.[8] In Pennsylvania, large scale fracking of natural gas did not commence until 2010, with an explosive growth that took off during much of the past decade. Last December, a regional news report indicated that total estimated natural gas production in the Marcellus basin in Pennsylvania was around 1.567 trillion cubic feet in 2018 – an all-time high – with fracked gas being extracted from 8,431 (95%) out of 8,917 drilling wells.[9] Thus, almost all natural gas to be transported by pipeline from Western Pennsylvania to the Killingly Energy Center in Connecticut will have originated from unconventional fracking process, with its present stable of controversial problems.
Based on health complaints filed by local residents in the Marcellus basin, the National Institute of Environmental Health Sciences (NIEHS) has recently provided long-term research funding to study the impact of natural gas fracking on pregnancy, asthma and cardiovascular diseases of individuals who live in the region.[10] Among the environmental health-related problems identified by NIEHS are the following; (i) water quality contamination occurring from a large variety of chemicals used in the fracking process that might seep through existing cracks in rock formations near underground aquifers. For the most part, their chemical identities are largely unknown, since they are considered a trade secret and deemed proprietary by the industry; (ii) air quality deterioration from combustion and flaring of excess drilled gas and tail-pipe emissions of transportation vehicles in the well’s vicinity. Here, the drilling sands and chemicals used in the fracturing process may also become airborne in the form of particulate matter and aerosols; (iii) occupational hazards of workers that are employed in fracking operations. This includes drilling sand inhalation and chemical spill exposures, along with respiratory distress caused by acutely toxic hydrocarbons in flowback operations, with four deaths reported since 2010.[11]
Like certain newly founded industries of late, the hydraulic drilling of natural gas deposits has successfully undergone an unprecedented growth spurt. Unfortunately, with enormous pressure to become profitable, reduce its overall debt obligations and pay back ample returns to its early investors, the industry has cut corners in terms of safety and health, both to neighboring communities and to workers on site. A number of reports and news articles in the past few years have documented the extent to which the fracking industry, with the willing assistance of local and federal government officials, have suppressed information about the adverse impacts of drilling operations in different regions of the country. As a recent Forbes article pointed out:[12]
It’s also important to note that these risks are likely to be seriously underestimated, because the environmental agencies have been downplaying the risks to the public. A new in-depth expose from investigative journalists at Public Herald looks in-depth at the Pennsylvania Department of Environmental Protection’s (DEP) misconduct and negligence, as the DEP studiously ignored citizens’ complaints, sometimes not even testing water samples. Earlier studies from ProPublica and others showed similar EPA failures in the western U.S. (emphasis in original)
Finally, the use of water resources and the disposal of fracking wastewater and other drilling-related materials must next be examined. To begin with, fracking operations consume an enormous amount of surface and ground water in the US. Depending on the region, this could range between 2 and 15 million gallons of water per wellhead per day, with daily fracking operations in the Marcellus deposit region using an average estimated 8.4 million gallons per well.[13] [14] According to a recent study by Duke University’s Nicholas School of the Environment, the amount of water employed in all fracking operations (oil and gas) nationwide rose by 770 percent between 2011 and 2016. Yet, the amount of brine- and chemically-laden wastewater from these operations increased 1440 percent during the same period.[15] [16] These wastewater slurries contain a witches brew of known and unknown compounds, some radioactive, some acutely toxic, and some neurotoxic and carcinogenic, although their exact composition still remains a mystery.[17] [18] [19] [20] In the final analysis, the increased use of dwindling water resources will seriously impede the growth of fracking operations around the country, while the industry’s ability to safely process and dispose its wastewater will remain a difficult and challenging problem.
In order for the Siting Council and the State of Connecticut to examine its energy production alternatives, it is important to carry out an extensive life-cycle analysis of the proposed natural gas power plant. This is because examining the potential health and environment impacts at the plant site alone misses the big picture. Here are some questions to ask of the applicant: (1) what are its major sources of the natural gas, (2) how is it extracted from the ground, (3) what is the level of groundwater contamination at the production site(s), (4) what is known about the human health impacts in the community, (5) how are the drilling chemicals and waste materials being disposed of, (6) how is the natural gas being delivered to the power plant, (7) how well-maintained are the pipelines that transport the natural gas, (8) what amount of methane gas leaks during the transmission process.
III. Given the State of Connecticut and the New England Region’s commitment to achieve a renewable energy future, there is no need to build another fossil fuel power plant at this time: All six states in New England have adopted Renewable Portfolio Standards, establishing renewable energy goals within the next few decades.[21] These are: Connecticut – 44% by 2030; Massachusetts – Class I: 35% by 2030 plus 1% per year thereafter, Class II: 6.7% by 2020; New Hampshire – 25.2% by 2025; Rhode Island: 14.5% by 2019, 1.5% per year till 38.5% by 2035; Vermont – 55% by 2017, 75% by 2032; Maine – 40% by 2017. Additionally, ISO New England, an independent agency that oversees electric power system in the region, has stated its commitment to renewable energy by issuing the following statement:[22]
Over the past 20 years, New England’s wholesale electricity markets have attracted billions of dollars in private investment in some of the most efficient, lowest-emitting power resources in the country – providing reliable electricity every second of every day, lowering wholesale prices, shifting costly investment risk away from consumers, and reducing carbon emissions.
In light of these energy-related trends and firm commitments made by State Legislatures and government officials in New England, there does not seem to be a pressing need to site another fossil fuel power plant in the region. In fact, such an unwise step at present would greatly hinder the publicly supported and officially mandated renewable energy goals of many New England states.
As mentioned in my opening remarks here, the State of Connecticut is on the cusp of approving a major wind turbine generating system off the New London coastline. The bill, HB 7156 (“An Act Concerning The Procurement of Energy Derived from Offshore Wind”), which provided such a public-private initiative, was overwhelming voted by a 134 – 10 margin by the House in the State Legislature a few weeks back.[23] The bill, once signed by Governor Ned Lamont, would build up to 1000 wind turbines on the Long Island Sound. It would require the Department of Energy and Environment Protection (DEEP) within 14 days of the bill’s enactment to solicit bids for constructing 2000 MW wind-generating electric power capacity for the region.
Based on considerations outlined above, I would urge the Connecticut Siting Council to carefully weigh all the economic, environmental and public health consequences of building a gas-fired power plant in the state at the present time.
Sincerely yours,
- Karim Ahmed, Ph.D.
cc Governor Ned Lamont
Lt. Governor Susan Bysiewicz
Members of Connecticut State Legislature
Department Heads
[1] US Energy Information Administration, Short Term Energy Outlook (May 17, 2019)/Today in Energy (January 17, 2019), https://www.eia.gov/outlooks/steo/report/natgas.php and https://www.eia.gov/todayinenergy/detail.php?id=38052
[2] Lazard, Levelized Cost of Energy Analysis (Version 12.0), November 8, 2018. https://www.lazard.com/perspective/levelized-cost-of-energy-and-levelized-cost-of-storage-2018/
[3] Global Warming Potentials, United Nations Framework Convention on Climate Change (UNFCCC), Geneva, Switzerland. https://unfccc.int/process/transparency-and-reporting/greenhouse-gas-data/greenhouse-gas-data-unfccc/global-warming-potentials
[4] R.A.Alvarez, et al., “Assessment of methane emissions from the U.S. oil and gas supply chain”, Science, 361:186-188 (2018). https://science.sciencemag.org/content/361/6398/186.
[5] J.Daniel, “The rush to overbuild gas-fired power”, Union of Concerned Scientist, Washington, DC, January 30, 2019. https://blog.ucsusa.org/joseph-daniel/rush-to-overbuild-gas-fired-power
[6] Independent Petroleum Association of America (IPAA), Hydraulic Fracturing, IPAA website. https://www.ipaa.org/fracking/
[7] J.Mikulka, “Are investors finally waking up to North America’s fracking gas crisis?”, Resilience (website), February 12, 2019. https://www.resilience.org/stories/2019-02-12/are-investors-finally-waking-up-to-north-americas-fracked-gas-crisis/
[8] Energy Information Administration, Marcellus Shale Play, Geology Review, 2017. https://www.eia.gov/maps/pdf/MarcellusPlayUpdate_Jan2017.pdf
[9] “PA natural gas production hits another all-time high in 3Q18”, Marcellus Drilling News, December 5, 2018.
[10] National Institute of Environmental Health Sciences (NIEHS), Hydraulic Fracking and Health, NIESH, Durham, NC. https://www.niehs.nih.gov/health/topics/agents/fracking/index.cfm
[11] Occupational Safety and Health Administration (OSHA), “OSHA highlights fracking hazards other than silica”, OSHA, Oil and Gas, Washington, DC. https://synergist.aiha.org/osha-highlights-fracking-hazards
[12] J.Stone, “Fracking is dangerous to your health – here’s why”, Forbes, February 23, 2017. https://www.forbes.com/sites/judystone/2017/02/23/fracking-is-dangerous-to-your-health-heres-why/#1fe43fa65945
[13] American Geosciences Institute (AGI), “How much water does the typical hydraulically fractured well require?”, AGI website. https://www.americangeosciences.org/critical-issues/faq/how-much-water-does-typical-hydraulically-fractured-well-require
[14] “Hydraulic fracturing water usage”, FracFocus, Chemical Disclosure Registry. https://fracfocus.org/water-protection/hydraulic-fracturing-usage
[15] “Water use for fracking has risen by up to 770 percent since 2011”, Nicholas School of the Environment, Duke University, Durham, NC, August 15, 2018. https://nicholas.duke.edu/about/news/water-use-fracking-has-risen-770-percent-2011
[16] A.J.Kondash, et al., “The intensification of the water footprint of hydraulic fracturing”, Science Advances, Volume 4, No. 2, August 15, 2018. https://advances.sciencemag.org/content/4/8/eaar5982
[17] Food and Water Watch (FWW),“Waste: The soft and dirty underbelly of fracking”, FWW website, April 2012. https://www.foodandwaterwatch.org/sites/default/files/Underbelly%20of%20Fracking%20FS%20April%202012.pdf
[18] C.H.Arnaud, “Figuring out fracking wastewater”, Chemical and Engineering News, March 16, 2015. https://cen.acs.org/articles/93/i11/Figuring-Fracking-Wastewater.html
[19] C.Davenport, “Reversing course, EPA says fracking can contaminate drinking water”, New York Times, December 13, 2016. https://www.nytimes.com/2016/12/13/us/reversing-course-epa-says-fracking-can-contaminate-drinking-water.html
[20] A.C.Kaufman, “The amount of toxic wastes produced by fracking is unbelievable”, Mother Jones, August 17, 2018. https://www.motherjones.com/environment/2018/08/the-amount-of-toxic-wastewater-produced-by-fracking-is-unbelievable/
[21] National Conference of State Legislatures, State Renewable Portfolio Standards and Goals, February 1, 2019. http://www.ncsl.org/research/energy/renewable-portfolio-standards.aspx
[22] ISO New England, Resource Mix, website, https://www.iso-ne.com/about/key-stats/resource-mix/
[23] C.Keating, “House approves bipartisan plan for wind power off New London”, Hartford Courant, May 14, 2019. https://www.courant.com/politics/hc-pol-wind-power-new-london-20190514-r6ezuilfm5apjbocuffzyxo4uu-story.html
