From Jon Edwards:
Jonathan Edwards
323 School St.
Berlin, NH 03570
1/5/2010
Via email and US mail
Thomas S. Burack, Chairman
NH Site Evaluation Committee
NH Department of Environmental Services
29 Hazen Drive
Concord, NH 03302
Laidlaw Berlin Biopower
Sec. Docket No. 2009-02
Dear Chairman Burack,
As a PSNH Customer, citizen of Berlin, and business owner within the city of
Berlin, I am concerned related to issues raised recently by Clean Power
Development pertinent to an incomplete application submitted by Laidlaw Berlin
Biopower. It certainly does seem to be appropriate that Laidlaw's application
should be revised or resubmitted so as to address the glaring issues identified
prior to any public hearings. The general public has great need of accurate
information prior to any hearings being held upon which we shall address our
issues and concerns. Of particular concern to me and others who have followed
the Laidlaw development is the history of conflicting press releases now
followed by a filing before your committee with testimony and incomplete
information that seems to be an effort to mislead or otherwise shade the truth.
The following subjects seem to be less than straight forward and therefore
misleading based on the current Laidlaw application.
1.The Landvest study (wood study done for the benefit of Laidlaw to prove ample
supply within a 100 mile radius) neglects to include numerous companies already
using the wood basket nor does it give any consideration of the other potential
users of the biomass. Not only are there other more efficient users proposed for
this same limited resource within New Hampshire but there are a considerable
number of out of state developments that target the same limited fuel supply.
2.Based upon recent testimony to the contrary by a PSNH attorney in an ongoing
docket before the NH Public Utilities Commission 09-067, Laidlaw's contention
that they have a Letter of Intent from PSNH needs to be ascertained as it is
presently not clear that such would be possible. Laidlaw states that a favorable
Purchase Power Agreement is necessary to realize project financing and therefore
without a PPA, or a letter of intent that is substantially the same, is Laidlaw showing
it has the financial capability to construct the project?
3.The Burgess Mill site has a long history of environmental contamination. In
1999 contaminants seeping into the Androscoggin River were of sufficient
quantity that an effort was undertaken to plug the bedrock cracks by injecting
grout. Mercury continued to seep into the river such that 140 pounds was
collected between 1999 and 2006. The site was placed on the National Priorities
List(Superfund) in September 2005. The EPA has been monitoring the river on and
off since then. It is my understanding that EPA is presently investigating the
site. The Laidlaw filing seems to be significantly incomplete as it relates to
the issues and concerns that surround a Brownfield site proposed for
redevelopment. Disturbance of soil and blasting of rock to place new equipment
foundations may be very dangerous as it relates to the fracturing of rock and
the release of more contaminants into the already burdened river. I have concern
for the downstream plant and animal life as well as the environmental risk for
people that may consume fish or drink affected water.
4. Clearly, Laidlaw is not the owner of the Burgess mill site, they are but an
operator/tenant and at best an agent of PJPD holdings, an LLC with unknown
members other than a few officers, with links back to numerous other LLC's of
unknown ownership. It is to the owners of the site and facility that we the
people will seek grievance if there are losses related to environmental damage
to our water and air. Any covenant not to sue between the State of New Hampshire
and the past or future owners of the property should only be related to issues
from the past. If a quantity of contaminants are locked up in this site they
must stay locked up or be properly removed and disposed of. Disturbing the site
so as to cause a release of such contaminants to the environment should lead to
a law suit for damages, and therefore the assets built on the site and the
balance sheet of the owner is of the utmost importance.
5. Laidlaw's potential of producing 40 direct jobs sounds good on the surface. But their
monopoly usage of remaining supply and then an apparent need for further supply can
effectively raise chip price. That could be extremely counterproductive to the north country
economy. Other wood commodity businesses already in operation could easily be forced
out of business due to chip price hikes. Proposals offering higher efficiencies and
synergies can be prevented from going forward due to lack of supply. Though Laidlaw's
claim is that their project will produce 300 indirect jobs within the wood commodities
industry, it is understandable that such a project could easily terminate these indirect jobs
currently being generated by proven entities already in place. The Landvest study clearly
needs to account for all currently operating wood usage in order to fairly balance our
economy moving forward. If biomass plants in Tamworth, Bethlehem, Whitefield, are
forced to close and mucipalities looking to synergize with biomass to heat their
towns and cities can no longer do so, what kind of 2025 initiative is that? What if chip
prices escalate to a point so high that it impacts Fraser papers and becomes the reason
for its closure? What impact would such closures have on area tax base, jobs, and home
grown effieciency? "What ifs"can never be used as a basis for decision making but certainly
need to be carefully looked at in relation to wood supply.
Berlin, in general, seems quite divided on two biomass proposals within the
city, and is basing a great deal of their decision making on potentially
incomplete or inaccurate information. The subject of these biomass facilities
has become the main subject of local newspapers and internet blogs.
Many people within the city feel that politics is too much at play and that
PSNH has too much power within the State for a fair outcome to prevail. I
disagree, and wholeheartedly believe this great State will prevail with what is
in the best interest of our economy, synergy, efficiency, forest sustainability,
and letter of the law. Berlin has been abandoned so many times before by unknown
entities that have liquidated the value of our forest stands, hydros and sold
off the remaining mills for pennies on a dollar, based largely on companies that
left the city in peril, with no one the city could hold accountable. Though it
is possible we have more accountable owners this time around, we the people do
not know who they are. We fear what we do not know and having an untrackable and
untraceable PJPD hiding in the shadows implies that they will also be
unaccountable. Perhaps if we follow the money back to its source we will not
like what we find. I look forward to protection from our state agencies to chart
Berlin into a better future.
Respectfully,
Jonathan Edwards
