October 17, 2012

TO:

The U.S. Environmental Protection Agency Region 9

FROM: 

Ashley and Scott Wayman

RE: Concerns regarding Sierra Pacific Biomass Plant permit modification for Anderson, 

California

Attn: Omar Shalev (AIR-3)

U.S. EPA Region 9

We are a group of citizens who live in close approximation to the proposed cogeneration 

plant’s site. The next couple of pages contain a list of our concerns in regards to this 

project. The references to an EIS are based on the Environmental Initial Study – UP07-

021-Sierra Pacific Industries, released March 26, 2008. This study was prepared by the 

Shasta County Planning Division. The references to the animal and plant statistics come 

from a report prepared by ENPLAN, 278-08, dated November 6, 2007. I realize updated 

reports are available but our same concerns remain even with slightly altered data. Links 

to these studies can be found through the following URL: 

co.shasta.ca.us/departments/resourcemgmt/drm/index.htm. Our concerns are presented in 

bullet form. Thank you for your considerations.

*Verde Vale Elementary and an established older neighborhood lie directly west of the

site at approximately .38 miles away. Our neighborhood known as the River Ranch 

neighborhood located off of Eastside Road by the Jolly Green Giant, is approximately 

1.89 miles due north of the site and has an established older neighborhood of 100+ homes 

with houses located on the river. Adjacent and accessed through our neighborhood are 

“the gravel pits”, as marked on your map, which were actually given to the City of 

Redding by a man named Kapusta. The gravel pits have become large ponds that 

interconnect through trails. A large hidden jewel with few visitors, it is a hidden

ecological habitat that supports the animals and flora discussed in your reports, as well as 

more animals within the food chain. Home to beavers, deer, egrets, otters, lynx and more.

This park now owned by the City of Redding would face severe ecological consequences

along with the River Ranch and Verde Vale neighborhoods, the Verde Vale Elementary 

school, and surrounding riverfront that does not pass the mill but could be greatly 

affected in adverse ways with the proposed plant and the issues raised in the EIR. WE 

WOULD LIKE A LARGER AREA STUDIED WITHIN THE FORTHCOMING EIR. 

We are all connected. This site does not exist in a vacuum and weather patterns have the 
ability to carry pollutants around the world. Shasta County already has the second 

highest carbon monoxide level in the state.

*Shasta County has high unemployment, underemployment and really no local business 

sector leading the way as once was the way with logging in our community. Given this 

we were surprised by the fact the new plant in its enormity will result in the hire of 19

employees at completion according to the EIS, with an additional temporary hire of 25-50 

employees during construction. Economically we do not believe the number of new 

hires is not enough jobs to offset the ecological impacts this project would create. 

*Quality of life issues now face our neighborhood. Will my garden, chickens and eggs 

still produce organic food in rich, healthy river loam fed by a well supplying the most 

wonderful water? Will we have to relocate knowing the particulates are overhead being 

breathed in by our family on a continual basis? Consider the impact on the value of our 

life and homes in the River Ranch subdivision due to the issues found to be serious 

impacts identified in the EIR. These problems will no doubt be a problem for us as well 

as all citizens in Shasta County with time. Our main concerns are air quality, water table 

issues for our wells and aesthetic concerns.

*We want all studies updated to show what is happening in the current construction plan.

* The new EIR needs to include the impacts addressed in the current EIS and apply it to 

larger vicinity around the proposed site. This expanded vicinity needs to be studied with 

all 17 environmental factors potentially effected reconsidered so that it includes the 

residential areas and the school surrounding the site including the Verde Vale and River 

Ranch areas. We believe that population and housing is not adequately addressed in the 

EIS. In fact it is not even listed as a checked factor. Please study the residents who call 

this vicinity home. It’s not only a few mobile home parks that will be effected as the 

report states if you look out 2 miles in all directions. There is residential housing as well 

as populations of inhabitants completely circling this site if you look. We understand 

there are industrial zones along HWY 273, but they are mixed among cattle ranches, 

family orchards, and residential neighborhoods on acre lots who homestead with pride on 

our fertile soil. The surrounding area needs to be studied to a greater extent. How far out 

will the population be at increased risk for the different health risks stated in your 

reports?

*What exactly will be used to fuel this plant? What does urban wood waste consist of? 

What are other cogeneration plants currently burning under the guise of Urban Wood 

Waste and what were the effects? How many trucks will be hauling fuel, urban wood 

waste, into the site and can they change what they use as fuel down the road? How far 

will trucks travel to get to your site from the point of collection? 

*Why are you producing 21 megawatts when it is stated you will only be using 4 

megawatts for the mill when so many environmental factors are at play? If the company 

proposing the site is getting into the power business, a legitimate venture, why aren’t they 
using one of their other wood mills located in the hinterlands of Northern California, 

instead of smack dab in the middle of Redding and Anderson?

* What is the ash used for that is trucked to your alfalfa fields north of the mill, how 

hazardous is it, and how many trips a day will be required? What is in this ash as far as 

hazardous material is concerned? What happens if you make more ash than the fields can 

absorb?

*The River Ranch neighborhood and existing homes within the area of the site rely on

wells for all our water needs and have so for generations. Our water is amazing and a 

huge value to our neighborhood. The amount of water proposed to be used by the site is 

enormous and it is stated it could have a significant affect depleting groundwater supplies 

and the capability of lowering the water table in our area. We are concerned about this 

new amount of water being used and how it will affect our wells and ground water less

than 2 miles away. Currently in our third year of drought, how sustainable and reliable is 

the availability of the water Sierra Pacific requires to serve the plants water needs now

and in the future while maintaining existing groundwater and water tables for those

homes and businesses surrounding you that use wells at the same time? How will those 

affected by the water loss and the drying of wells be compensated as the value in their 

property continues to decrease due to this site's proposed operations? 

*The boiler standing at 105 feet is alarming. The tower at this height does not include the 

plumes of smoke. The light and glare ramifications also need to be addressed. The 

residential areas surrounding the site will be forever be changed by the tower which will 

be visible from a far distance upsetting the horizon and skyline. A beautiful natural area 

with a giant tower seen from our neighborhood once again decreasing our property value

but more importantly how far will this exhaust travel?

*There are some family cattle ranches, orchards, family farms and a plant nursery located 

around the proposed plant. ACID canal goes through our neighborhood at River Ranch 

supporting cattle, walnuts and livestock. These may not be significant farms but the dairy 

across I-5 in the path of the emissions should be considered a significant agricultural 

resource. We don’t need these chemicals in our food chain.

*OF UTMOST CONCERN IS AIR QUALITY. Due to the fact that we live less than 2 

miles away the chemicals being released and the amounts are cause for great concern. 

We would like exact studies on what is going to be put into our air, where it will flow, 

how many particulates will fall to the soil and into our watershed and what effect it will 

have on the environment and human beings. How do we know the company proposing 

the cogeneration plant will not continually violate air standards? The EIS mentions that it 

is a significant impact, that emissions from this site exceed thresholds and that odor will 

be a problem. How are you going to ensure the air we breathe 2 miles north from the site 

won’t leave us with one or some of the listed 87 chemicals? Are all these chemicals 

listed going to be produced and released continually? What do you do about odor? Is the 

odor due to dangerous chemicals within the air? Item III of the EIS released in 2008 
pertains to our neighborhood completely-we are the people living in the vicinity where

according to the Authority to Permit Application prepared by Geomatrix (2007),

determined the horrible health consequences tied to the air quality will be. 

*We are fortunate to still have uninhabited riverfront within this sites vicinity. The 

environmental consequences of this proposed project will affect more of the river and the 

surrounding riparian forests than are addressed in previous studies. We ask you to visit 

surrounding riverfront areas and include the surrounding areas in your report to determine 

the affect it will have to the fish, wildlife and plants living all around this delicate 

ecosystem. We want a more thorough review into the biological resources at risk. All 

salmon are struggling to exist. Is there a focus in the upcoming EIR relating to runoff 

and air pollutants into our water? 

*Are there considerations to the cultural resources on site and the surrounding areas 

before work begins? We are home to many fossilized dinosaurs and Native American 

sites. We are asking consideration is given to the cultural and historical sites within the 

proposed project site. 

*Part VII of the EIS released in March of 2008 and its supporting documents allow us to 

come to the conclusion it would not be safe to live where we currently do because of 

hazardous materials created, emitted and transported from the proposed site. The fact 

that there is a potentially significant impact in this area needs to be studied further. Are

there other cogeneration plants that exist like this we can learn from? We do not want to 

worry about the possible release of hazardous materials. 

*Noise. We do not want to hear any increased noise from our residences. Noise is 

pollution and it needs to be determined exactly how far away from the site the noise 

levels will carry to and what the noise level will be. 

*Shasta County’s main industry is recreation. This project will be a loud eyesore 

omitting hazardous material on the Sacramento River. How will the offset in lost 

revenue for recreation be made up? 

*Why doesn’t the whole county know of this project?

* “XVII. MANDATORY FINDINGS OF SIGNIFICANCE: 

This bullet is in reference to the EIS, released in 2008, specifically the Discussion, “based 

on the discussion and findings in Section IV Biological Resources there is evidence to 

support a finding that the project would have the potential to degrade the quality of the 

environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or 

wildlife population to drop below the self-sustaining levels, threaten to eliminate a plant 

or animal community or reduce the number or restrict the range of a rare or endangered 

plant. 

 There is evidence to suggest the project would have impacts that are cumulatively 

considerable. 
 There is evidence to support a finding that the project would have environmental 

effects which would cause substantial adverse effects on human beings, either directly or 

indirectly.” These are the quoted final statements of that EIS. We hope that mitigation 

and monitoring for this proposed cogeneration plant will be developed and analyzed with 

great scrutiny and vigilance in a new updated Environmental Impact Report. 

Thank you in advance for your hard work on this matter. 

Ashley and Scott Wayman