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									                     To:      Environmental Management Commission
                              Renewable Energy Scoping Process
                     From:    Molly Diggins, State Director
                              North Carolina Sierra Club
                     Re:      Scoping comments, renewable energy: methane capture from swine operations
                     Date:    March 31, 2008


                     The Sierra Club greatly appreciates the Environmental Management Commission’s foresight in establishing
   North             an Alternative Energy Committee. Rapid developments in the energy sector, recent state legislation and
  Carolina           anticipated federal legislation all suggest that North Carolina can expect a substantial and expedited growth
                     in renewable energy. Sierra Club is committed to a clean energy future for our state and nature. We also
  Chapter            recognize that new and growing energy industries may create a need for additional environmental review
  Regional           and, as appropriate, new regulation to avoid unintended consequences.
   Groups
                     These scoping comments are intended to address one aspect of these regulatory needs: methane capture
Blue Ridge           from swine operations.
      Boone
                     Background:
 Cape Fear
  Wilmington         Methane is a powerful greenhouse gas, estimated to be several times more potent than carbon dioxide.
                     Greenhouse gas emissions credits are already being bought and sold for flaring methane, even when no
    Capital          energy is produced, in nations which have adopted a cap and trade program.
     Raleigh
                     Here at home, legislation passed by the North Carolina General Assembly in 2007
   Central           (S. 1465, Swine Farm Environmental Performance Standards) established a methane capture pilot project
 Piedmont            for up to 50 swine operations. The North Carolina Utility Commission has recently opened a docket to
   Charlotte         establish appropriate costs for electricity generated from methane capture, not to exceed $.018 kWh over a
                     seven year period, per the enabling legislation.
   Cypress
  Greenville
                     In addition, S. 3, Promote Renewable Energy/Baseload Generation, established a set-aside for electricity
                     generated from swine waste.
  Foothills
    Winston-
      Salem
                     Finally, the US Congress is giving serious consideration to climate change legislation and the establishment
                     of a cap-and-trade program. Federal legislation is also expected spur interest in methane capture and swine-
Headwaters           waste-to-energy.
    Durham
                     For these reasons, the future of methane capture requires the Commission to evaluate the current regulatory
    Medoc            programs as applied to methane capture technologies.
Rocky Mount

   Orange-           Scoping comments:
  Chatham
  Chapel Hill        Flaring of methane may release in significant amounts of ammonia and other emissions to the atmosphere.
                     Ammonia is a precursor of NOx and particulate matter. Nitrogen deposition from ammonia emissions is
 Piedmont            believed to be a significant contributor to water quality problems in nitrogen-sensitive coastal waters.
   Plateau
 Greensboro          Ammonia emissions from swine operations are not currently subjected by DENR to permit requirements,
                     but are the topic of substantial scientific study and research. Methane capture from swine waste lagoons,
    Pisgah           while reducing greenhouse gas emissions, could have the unintended consequence of increasing ammonia
     Brevard         emissions or other pollutants of concern.

    South            Sierra Club urges the EMC Alternative Energy Committee to investigate these matters and if appropriate to
 Mountains           consider if air quality permit should be required for swine operations capturing methane.
  Morganton
                     Lagoon covers are the industry’s preferred method of methane capture. There is reason to be concerned that
   Wenoca
                     lagoon covers result in increased concentrations of ammonia in the wastewater which may in turn get into
   Asheville
                     groundwater. We urge the Committee to explore if additional limits on ammonia are needed for operations
                     which capture methane and also whether there are other controls on methane capture which are appropriate.


       Chapter Office: 112 S. Blount Street • Raleigh NC 27601 • Tel: 919-833-8467 • Fax: 919-833-8460 • info@sierraclub-nc.org

								
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