Dear Mayor Barr and council:
The Rimbey and District Clean Air People (RADCAP) is a community-based advocacy group, principally focused on protecting air and water quality. Since its inception in 1996, RADCAP has engaged in issues research and respectful dialogue with local industry working toward environmental protection. Most recently, we have been asked to examine a licensing application by Aspen-Bio Industries Ltd. to build and operate an ethanol/methanol plant in Rimbey. We offer the following observations for consideration by your offices and the community at large.
We appreciate the message from the Rimbey Town Office that the proposed plant would provide positive economic effects for our community. The construction phase of this highly technical project would draw several specialized contractors, many of whom would patronize the local service sector and likely employ a component of local labour. An operating plant would generate employment opportunities and a significant contribution to the tax base. Beyond the promise of economic stimulus, this plant has also been branded as an environmentally positive solution for dealing with agricultural and municipal solid waste. Unfortunately, RADCAP’s review of Aspen-Bio’s licensing application does not allow us to support this notion.
A principle concern surrounds the feedstock supply for plant operation. Of the 100,000 tonnes per year required, 80 per cent is to be clean straw and 20 per cent pre-sorted municipal solid waste. Regarding the larger straw component, several points are worrying.
• The agricultural community does not consider straw a waste product. It becomes a commodity only when growers decide not to return it to cultivated land for soil enrichment. Straw is otherwise made available for bedding or as a component of feed programs, in which case it is eventually returned to the soil through manure spreading. To quote from an article titled Estimating the Value of Crop Residues by Alberta Agriculture, ”A wise strategy may be to allow straw removal once in a three or four-year rotation on black soils with a low risk of erosion…On other soils, the value of straw for organic matter maintenance or building would be significant (probably at least the value of nutrients), and thus straw removal would not be as economic or recommended.”
• Rimbey is primarily a livestock raising area. The competition for straw from this plant may place livestock producers at an economic disadvantage.
• Rimbey is not central to areas of straw production, thus requiring medium to long trucking distances for the vast majority of the 80,000 tonnes per year required.
• Actual straw availability is addressed by sourcing 70 per cent from a straw cooperative not locally based, the remaining 30 per cent to be purchased on the open market. Dependability of the open market to supply affordable straw is not predictable, particularly in conditions of short supply. The Aspen plant process cannot practically tolerate interruptions of feedstock.
Regarding the required 20,000 tonnes per year of presorted municipal solid waste, the following must be noted:
• Rimbey can and has committed 2,000 tonnes per year (10 per cent). The remaining 18,000 tonnes (90 per cent) will have to be contracted from a variety of other municipal waste sites, the largest contributions coming from Ponoka, Lacombe and Red Deer. To date, Red Deer’s waste (10,000 tonnes per year) is previously committed and unavailable. Aspen-Bio is convinced this commitment can be redirected to the Rimbey project. Although discussions with potential sources are reported as positive, Aspen-Bio states that no commitments beyond Rimbey are yet confirmed.
• Assuming adequate participation, this other 90 per cent of municipal solid waste will have to be trucked to Rimbey for final sorting and processing.
A plant sited in Rimbey is central to neither the source of straw, nor municipal waste required. Ethanol/methanol produced would, as stated, replace non-renewable fossil fuels. Unfortunately, this benefit is seriously compromised when weighing the true agricultural value of straw, and the trucking inefficiencies inherent in this choice of location.
RADCAP has carefully reviewed this application with regard to plant emissions and waste. Community perception is that this plant would release only steam or water vapour to the atmosphere. There are, in fact, many components to be released as emissions, all predicted at levels well within regulations. The process engineering does appear to make a very strong effort at minimizing emissions. Nonetheless, this is a chemical plant generating pollutants that must be accepted as normal to the process. Acknowledging this, Aspen-Bio includes a monitoring regime within its application. RADCAP would respectfully suggest that, without causing undue difficulty to the operator, modest improvements to the proposed monitoring schedule, for both air emissions and wastewater, could and should be made to properly serve the community.
RADCAP also draws attention to potential release into the atmosphere of 7,453 kg/hr (approximately 15 tonnes per day) of C02. Aspen-Bio declares that a third party intends to capture, liquefy and sell virtually all of the produced CO2. This project would require a separate application which, to date, has not been filed. Aspen-Bio is not prepared to guarantee that a CO2-capture facility would be in place at start-up. As it stands, Aspen-Bio’s licensing application would permit direct release to the atmosphere of this entire volume of CO2. RADCAP submits that within this application Aspen-Bio declare formal commitment to CO2-capture being in place at plant start-up.
Another aspect of air quality is odour control. The Aspen-Bio proposal declares strong commitment to preventing any odour issue. There is, however, an anomaly in the odour control program. When asked about dealing with moisture in municipal solid waste, Aspen-Bio stated that it would be directed to the drying processor designated for clean straw. This system vents directly to atmosphere at low temperature via a dedicated stack. No odour control is referenced in the design but would certainly be required.
RADCAP believes that there is a need for more dialogue before committing to this project. It is regrettable that, as is customary, a public consultation was not scheduled to discuss details released in the plant licensing application. In lieu of such an opportunity, RADCAP now offers the above for your consideration. We welcome any comments in response.
Editor’s Note: A copy of this letter to town council was presented to the Rimbey Review for publication, GSB, editor.