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 cont ain 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. T he 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 fo und 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 l ie 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

interconn ect 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 mor e

. T his 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

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

W OULD 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 theability to carry p ollutants 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 hi re of 19 employees at completion according to the EI S , w ith an additional temporary hire of 25

- 50 employees during construction

. Economically we do n ot 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 loa m 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 i n 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 co ncerns.

* 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 EI S and apply it to larger vicinity around the proposed site

. This expanded vicinity nee ds to be studied with all 17 environmental factors potentially e ffected reconsidered so that it includ es the

residential areas and the school surrounding the site including the V erde Vale and River

Ranch areas

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

EI S

. 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 al l 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 HW Y 273

, but they are mix ed among cattle ranches, family orchards, and residential n eighborhoods 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 exac tly 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 t he 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 m any environmental factors are at play? If the company proposing the site is getting into the power business, a legitimate venture, why aren’t theyusing 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? Wh at 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 neigh borhood. 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 maintain ing existing groundwater and water tables for thos e h omes 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 thei r

pr operty 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

res idential 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 prope rty 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 catt le, walnuts and livestock. These may not be significant farms but the dairy

across I

- 5 in the path of the emissions should be consi dered a significant agricultural

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

*OF UTMOST CONCERN IS AIR QUAL ITY

. D ue 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 EI S mentions that it is a significant impact

, t hat 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 2008pertains to our neighborhood completely

- we are the people living in the vicinity where

accordin g 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 with in this sites vicinity. The

environmental con sequences 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

th e 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 r unoff 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 document s 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 need s to be studied further. Are

there other cogeneration plant s 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 residence s . 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 evi dence 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, th reaten 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 sup port a finding that the project would have environmental

effects which would cause substantial adverse effects on human beings, either directly or indirectly.” Th ese 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