Comments from Seneca Lake Guardian Business Coalition and Finger Lakes Wine Business Coalition Opposing Greenidge Generating Station Air Title V Facility Permit
VIA EMAIL
Christopher M. Hogan
NYSDEC Headquarters
625 Broadway
Albany, NY 12233
(518)402-9167
Comment.GreenidgeGenerating2021@dec.ny.gov
Re: Comments from Seneca Lake Guardian Business Coalition and Finger Lakes Wine Business Coalition Opposing Greenidge Generating Station Air Title V Facility Permit ID 8-5736-00004/00017
Facility DEC ID: 8573600004
Dear Mr. Hogan,
The undersigned members of the Fingers Lakes Wine Business Coalition urge the Department of Environmental Conservation to deny the Greenidge facility’s Title V Air Permit, which is up for renewal. We are concerned that the power plant, with its new use as a bitcoin mining operation and its enormous increases in GHG emissions, will adversely impact the vibrant wine and tourism industry in the region, degrade the pastoral nature of the Finger Lakes and damage the vital natural resources on which we rely. As the facility aims to increase its Bitcoin mining operations, its benefit to the public decreases as less energy produced will go to the grid and more of it is consumed for private gain, making its justification as a necessary public power plant extremely weak. Additionally, we believe that this facility, and others like it, will prevent the state from meeting its critical climate goals established under the Climate Leadership and Community Protection Act (CLCPA).
A number of the elements in the Finger Lakes dynamically interact to form the region’s community character, including the role of natural beauty and an agricultural landscape, specifically a viticultural landscape, which is central to the Finger Lakes region’s sense of place over time and to the branding of the emerging tourism economy. The community is consciously pursuing economic development strategies—especially recreation and agri-tourism—that will enable it to preserve these aesthetic and environmental values that are core to the high quality of life enjoyed here, the tourism value and long term economic development of the region.
Tourism to the Finger Lakes region and to Seneca Lake in particular grew progressively in the latter half of the 20th century. The Seneca Lake Wine Trail was founded in 1986 in response to the increase in visitation to the Seneca Lake region and as a coordinated approach to support the economic importance of the wine industry. The region is now drawing nationally and internationally recognized winemakers, supports over 58,000 jobs and generates $3 Billion for New York State annually. Although Greenidge promises a handful of jobs, we urge you to consider the livelihoods that some of us have spent generations building which could be at risk in the long term should this facility be permitted to continue operating.
Of note is that American Viticulture Areas (AVAs) are federally designated economic zones that have a substantive economic and social context that define them as a region. They are cultural landscapes that have, as their community character, an historical and contemporary economic and social coherence. The scenic landscape of vineyards and wineries of the Finger Lakes AVA and Seneca Lake AVA is a visual and perceptual image of the region’s community character.
The Finger Lakes is also currently being considered by Congress for a National Heritage Designation.
While we once were a much more industrial region, we have evolved into a world-class agricultural and tourist destination that relies heavily on clean air and water for our survival and success. Yates County, where Greenidge is housed, is one of New York's largest agricultural producers. Furthermore, the facility is already increasing noise in the area, and an increase in mining would add more noise, disrupting the peaceful nature of the area and potentially effecting visitors across the lake.
Analyzing the long term impacts of the Greenidge facility, not only from a localized air emissions standpoint, but also from a standpoint of how it will further disrupt our climate in an area that is already struggling with more severe flooding, seeking new agricultural practices and pest management control resulting from a changing climate, is important to the region.
Seneca Lake recently experienced extreme flooding from two severe rain events, with significant runoff and dangerously high lake levels. We also experienced record-breaking Harmful Algal Blooms in the North-western quadrant of the lake on October 6th, where Greenidge is permitted to discharge 134 million gallons of water at up to 108 degrees Fahrenheit daily. https://waterfrontonline.blog/2021/10/13/seasons-worst-toxic-bloom-outbreak-hit-on-dead-calm-afternoon-of-oct-6-senecas-northwest-quadrant-hit-hardest/
The wine industry depends on Seneca’s clean water to draw tourists and wine enthusiasts to our region.
Any single facility in our region that stands to threaten the wine and tourist industry with combined upstream and on site emissions of over one million tons of CO2 equivalents annually must be carefully scrutinized under a risk-versus-reward lens. Weighing the potential costs of the facility to the burgeoning agriculture and wine industry is critical.
Additionally, if New York State is to achieve its necessary and bold climate goals, permitting Greenidge and Greenidge-like facilities to operate will undermine the initiative we established in law in 2019 under the CLCPA. We must adhere to this law, aimed at reducing the state’s GHG emissions, in an effort to leave a livable climate for future generations.
We further urge you to consider the impact that this facility’s increased air pollution may have on our vineyards and on the many other crops in a largely agricultural region:
i. Nitrogen oxide, one of the main pollutants released from natural gas plants, mixes with other substances in the air causing yellowing, reduced growth, and lower yields due to acid rain and smog. (Agricultural Outlook, n.d.)
ii. Sulfur dioxide reacts with other substances in the air to form acid rain. When acid rain reaches the soil in vineyards, the pH of the soil is lowered, which makes it more difficult for grapes to grow (Pambianchi, 2009)
iii. Particulate matter has two effects on plants, it reduces solar radiation reaching the surface and increases diffuse radiation, which have opposing impacts on plant productivity (Our Research, n.d.)
iv. Sources:
1. Agricultural Outlook: How limiting air pollution will protect farms. EIT Food. (n.d.). Retrieved October 26, 2021, from Agricultural Outlook: How Limiting Air Pollution Will Protect Farms | EIT Food https://www.eitfood.eu/blog/post/agricultural-outlook-how-limiting-air-pollution-will-protect-farms#:~:text=According%20to%20the%20World%20Resources,growth%2C%20ammonia%20drives%20biodiversity%20loss
2. Pambianchi, D. (2009, November). How Do Air Pollution and Acid Rain Affect Vines, Grapes and Wine Quality, and Ultimately Our Health? GENCO Winemakers. Retrieved from https://www.gencowinemakers.com/docs/How%20Do%20Air%20Pollution%20and%20Acid%20Rain%20Affect%20Vines,%20Grapes%20and%20Wine%20Quality,%20and%20Ultimately%20Our%20Health_.pdf
3. Air pollution impacts on global crop yields. Air pollution impacts on global crop yields | Abdul Latif Jameel Water and Food Systems Lab (J-WAFS). (n.d.). Retrieved October 27, 2021, from https://jwafs.mit.edu/projects/2016/air-pollution-impacts-global-crop-yields#:~:text=By%20scattering%20and%20absorbing%20solar,canopy%2C%20thereby%20increasing%20plant%20productivity
i. Ozone damages plants causing yellowing, cell injury, irregular spots, and reduces yields. It is estimated that ozone causes between a 5% and 12% loss in yields of staple groups globally. (info@sustainablefoodtrust.org 2019)
ii. With a decline in ozone, projections show an increase in crop yields for wine grapes, table grapes, and nectarines for study in California (Bryce, 2020)
iii. Ozone can cause a yellowing of leaves due to low chlorophyll levels and chlorophyll is necessary for photosynthesis to occur. Pollution can cause physical damage to leaves where photosynthesis takes place and cause food production to cease to cope with environmental stress (Rogers, 2019)
iv. Sources:
1. info@sustainablefoodtrust.org, S. F. T.-. (2019, May 7). The impact of air pollution on crops. Sustainable Food Trust. Retrieved October 26, 2021, from https://sustainablefoodtrust.org/articles/the-impact-of-air-pollution-on-crops/
2. Bryce, E. (2020, March 27). Decreasing air pollution increases agricultural yields. Anthropocene. Retrieved October 26, 2021, from https://www.anthropocenemagazine.org/2020/03/tighter-air-pollution-regulations-in-california-could-mean-more-wine/
3. Rogers, C. D. (2019, November 18). How does pollution affect photosynthesis? Sciencing. Retrieved from https://sciencing.com/how-does-pollution-affect-photosynthesis-12305798.html
i. Pollutants can damage the stomata, disturb the water balance in a plant, and hinder its ability to respond to stress. Depending on the level of exposure to pollutants, respiration can be inhibited or stimulated in plants (Gupta, 2016)
ii. Air pollutants interfere with net carbon fixation and soil resource capture, which reduces plant growth and hinders plants’ ability to respond to stress. (Environmental Protection Agency, 2021)
iii. A study found that high ozone levels affect grapevine weight and disturb photosynthesis, which reduces growth rates. The quality of wine, including nutritional benefits and taste, is impacted by reductions of polyphenols due to exposure to ozone (Fumagalli, 2019)
iv. Sources:
1. Gupta, A. (2016). Effect of air pollutants on plant gaseous exchange process ... Retrieved from https://www.researchgate.net/publication/305796689_Effect_of_Air_Pollutants_on_Plant_Gaseous_Exchange_Process_Effect_on_Stomata_and_Respiration
2. Environmental Protection Agency. (2021, March 9). Plant Response to Air Pollution. EPA. Retrieved from https://cfpub.epa.gov/si/si_public_record_Report.cfm?Lab=NHEERL&dirEntryId=50437
3. Fumagalli, I., Cieslik, S., De Marco, A., Proietti, C., & Paoletti, E. (2019, December 12). Grapevine and ozone: Uptake and effects. MDPI. Retrieved from https://www.mdpi.com/2225-1154/7/12/140/htm.
In summary, The Greenidge facility on the western side of Seneca Lake is inconsistent with the character of the local and regional Finger Lakes community. Local land use plans focus on retaining open space and the natural setting, protecting air and water quality, preserving the rural/small town atmosphere -- and this proposed facility would not be conducive to those goals. It is clear that renewing air permits for a facility of this type would also not comport with local and regional economic drivers, which focus on tourism, the wine industry, and agriculture. Finally, the emissions from this facility would make it extremely difficult for New York to attain its climate goals as laid out in the CLCPA.
For these reasons we urge you to deny the Greenidge Title V air permit renewal.
Cc: The Honorable Governor Kathy Hochul
Cc: DEC Commissioner Basil Seggos
Signed,
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