### Additional Public Comments Rose Flame to: R9AirPermits 01/11/2014 12:01 AM

Cc: Shaheerah Kelly, Deborah Jordan, "hswriter@frontiernet.net", Marily
Woodhouse

From: Rose Flame <mysecretfires@gmail.com>

To: R9AirPermits@EPA,

Cc: Shaheerah Kelly/R9/USEPA/US@MSO365, Deborah Jordan/R9/USEPA/US@MSO365, "hswriter@frontiernet.net" <hswriter@frontiernet.net>, Marily Woodhouse <marily-lobo@hotmail.com>



### Deborah Jordan, Region 9, EPA Air Director Shaheerah Kelly, Project Administrator/Engineer EPA Region 9 75 Hawthorne St. San Francisco, CA 94105-3901 R9airpermits@epa.gov

RE: Permit No. SAC 12-01/ Modification of Permit #94-VP-18b I would like to include the following article from a local newzine, the Fantom Penguin: http://www.fantompenguin.com/2013/10/dam- p roject-not-done-de al-by- j oe.html According to the article, Shasta Dam currently provides 710 megawatts of generating capacity. With this source of electricity set to go offline, is biomass energy currently planned as a replacement? Will this 31 megawatt facility be used, in conjunction with other new biomass facilities, to replace the 710 megawatt loss when construction on Shasta Dam begins? Is biomass still exempt from BACT consideration during the environmental review process, or has that changed in light of recent policy decisions? Thank you,

Celeste Draisner citizen activist Citizens For Clean Air 530-223-0197 Thursday, October 31, 2013, Fantom Penguin 

# Dam Project not a Done Deal by Joe McGarity

Shasta Dam has been on people’s minds lately. There has been much talk of and no small amount of opposition to a proposed construction project that would enlarge the dam. The person in charge of Shasta Dam is Brian Person of the United States Department of the Interior’sBureau of Reclamation. The Fantom Penguin asked him about Shasta Dam’s role in the Central Valley Project. “Shasta Dam is generally considered as the keystone of the Central Valley Project. It serves as the head-works. It’s the upstream-most storage facility and it’s also by far the largest water storage facility on the Central Valley Project. Central Valley Project runs from near the north end of the state and it navigates its way through the center of the state to near the southern end and it addresses the water disparity, if you want to call it tha t , in California. The vast majority of the precipitation occurs in the north end of the state and the greater demand is in the central and southern part of the state. So it’s a complex assemblage of storage, dams, conveyance features and power generation facilities that make a linkage between where the water naturally occurs, where it naturally falls in the north end of the state and the demand, as I indicated, at the southern end of the state. Shasta stores 4.55 million acre feet. It was constructed from 1938 – 1945, primarily for the purpose of flood control and water storage. We also generate power through the five hydroelectric generating units at the dam that have a total nameplate capacity of 710 megawatts. It’s been uprated three times over the years. The last uprate occurred from about 1999 – 2006 or so. So, it’s a significant facility. It makes possible, really, the Central Valley Project by virtue of its location and the volume of water that it stores.” So, as we record this, the dam is celebrating its 75th anniversary. Now, that’s the anniversary of the beginning of construction. You said earlier the construction lasted until 1945. It makes me wonder if World War II was a factor in the construction. It must have been. “It very much was. In terms of providing manpower and materials, World War II was a factor. There was an emphasis of course for resources to fight the war effort and so the materials that were made available for Shasta Dam, the World War II demand was a consideration and also in terms of manpower – and then hydroelectric generation. Two of the units that are installed at Shasta first spent time at Grand Coulee, because Grand Coulee was constructed earlier, so that electrical power generation could be used to fulfill the demand for manufacturing associated with the war effort.” And can you tell me about how many communities or about how many people are served by the electricity generated by the dam?

Photo by Joe McGarity “Generally speaking -- and it depends on demand and it depends on if all air conditioners are running, but a megawatt provides power, generally speaking, for about a thousand homes if you look at average demand. So our 710 megawatts of generating capacity, under normal demand circumstances, could provide electrical power to about 710,000 homes at any given time. It really doesn’t work that way. We are so interconnected now on the western part of the United States on the grid so that it isn’t a geographic limitation as much as it once was. So it isn’t accurate to say necessarily that the electrical energy produced at Shasta Dam provides power to the nearest 710,000 homes. We are interconnected and thepower g oes onto the g rid for broad distribution.”
And it’s routed wherever it needs to be routed? “Where the demand is, yes.” “So this week is really about, obviously celebrating the anniversary of the beginning of construction and focusing on the significance that Shasta Dam and Reservoir and Power Plant have played in our water-supply portfolio and meeting our power-generation needs. But more than that, it’s about celebrating the accomplishment of the men and women who worked so hard in some pretty challenging conditions and at a challenging time to construct the dam. There are just a few of the original construction workers still among us and this is an opportunity to celebrate their accomplishment and to honor them and that’s really the significance of this week for us at Reclamation.” It was a dangerous time to be a dam builder. Some . . . well, you may even know the number. Some people lost their lives in the effort. Did they not?

“Yes. There were a number who lost their lives. I think the number is nineteen. I’m not certain. As compared to other large dam-building efforts of the time, on a relative scale it was safe. Each one of those lives lost was a tragedy, but it’s an order of magnitude (almost) less than the number of lives lost at Hoover. Safety concerns and safety equipment, while still primitive, were making advances at the time. Some have said that some of the lives lost were buried in the concrete. That’s simply false. That’s folklore. There’s no one buried in the concrete. The concrete was placed in eight cubic yard buckets and each lift was no more than five feet. So if a worker were in the concrete they were able to be removed. If they were injured in the concrete, they were able to be removed. So there’s no one buried in the dam. That’s folklore.” Well, that’s very disappointing to a newspaper man, but probably good for anyone that’s superstitious about taking the tour. And speaking of tours . . .

Photo by Joe McGarity “Yes, we offer guided tours seven days a week and in significance of the anniversary celebration this week there were night tours conducted two nights this week. They were very, very well attended. We did those Tuesday and Wednesday and I think nearly a hundred people went through the dam. They’ll be tours conducted through the weekend and they’ll be some more celebration activities occurring here. But I guess as you indicated, by the time people see this, that will have been passed.” Over the decades, more than once, the prospect of adding to the dam or building it higher has come up. Can we start on this subject by maybe discussing when this has been brought up in the past and what happened? “At least as far back as the Eighties, the prospect of enlarging the dam and reservoir has been raised. The ‘raise’ has been raised. I’m not certain . . . I’m less certain at least of initiatives earlier than that. But there were raise increments discussed initially of 100 feet and 200 feet and there have been other discussions and even studies started, all driven by the notion that despite our efforts for programs such as water conservation and dual water systems, that is water recycling, that the demand for water is continually growing in California and there’s a finite supply. So the question was asked, ‘Does it make sense to enlarge the dam and reservoir?’ So you start looking at some numbers. The average annual inflow to the basin over the eighty-five or so years of hydrologic record that we have is 5.7 million acre feet a year flows into the basin. And as we indicated, the reservoir at full capacity is 4.55 million acre feet. So more water flows into the basin, simply put, in a given year than what we can store. So, with those numbers in mind, it makes sense to take a look at increasing storage. So this most recent effort was authorized by the CALFED Authorization and it directs Reclamation to take a look at increasing storage capacity at several locations and Shasta is one of those. So the work began in earnest a few years ago.There was a preliminar y draft feasibilit y stud y and environmental impact statement released last y ear and earlier this year a draft feasibility study and draft environmental impact statement were released. We’ve had several public workshops. We’ve had a public hearing, gathering comment and we’ve met with a variety of affected publics. What the study results tell us thus far is that is feasible from a hydrologic, economic and physical perspective and an engineering perspective to raise the dam by eighteen and a half feet. Raising the dam by 18 1⁄2 feet, because freeboard would be operated differently, would allow us to increase the operating elevation by 20 1⁄2 feet. In terms of numbers, that additional space, when full, would store an additional 634,000 acre feet and that represents about a 14% increase in storage above the 4.55 million acre foot current capacity. Obviously that water wouldn’t have space in it every year. If you look at the 85 years of hydrologic record and you do hydrologic routing, you’d see water in that space every 4

– 6 years. Recent hydrologic history has really bourn that out. So it makes sense to examine the enlargement potential. On a preliminary basis, it has been found to be feasible. Reclamation will complete the process, head toward a final EIS and presumably a record of decision that will end up ultimately being submitted to the Congress and that’s where the decision would be made. Important to note that the authorization from the Congress directs us to perform a feasibility study and that it would literally require another act of Congress directing us to take action to raise the dam, literally another act of Congress.” So, it isn’t a done deal at this point? “It is not. No, it is not a done deal. Reclamation will fulfill its directives to prepare and submit the feasibility study in combination with a final environmental impact statement and then it goes to the decision makers. So no, not a done deal.”