The new permit is “to establish start up and shutdown limits based on continuous compliance tests conducted at the facility.” This change in emission limits would increase nitrogen oxide and particulate start up emissions and decrease volatile organic compounds and carbon monoxide start up emissions. Overall, the changes will decrease the total air emissions of the facility. For that reason, the assessment of existing community conditions and analysis of the cumulative impacts of new or modified sources of air pollution that may affect Environmental Justice (EJ) populations will NOT be required.”

The Peabody Board of Health and Breathe Clean North Shore have previously requested that MMWEC be required by MassDEP to develop an Environmental Impact Report and a comprehensive health impact assessment given the facility’s proximity to EJ populations within four communities residing within one mile of the plant.

“Although the net result will be an overall decrease in emissions, there is still the potential for elevated health impacts, particularly respiratory events.

During the siting process to add MMWEC’s new generator to the two existing PMLP generators at Waters River Station. BCNS and the Peabody Board of Health requested that MMWEC be required by MassDEP to develop an Environmental Impact Report and conduct a Comprehensive Health Assessment (CHIA). Neither of these two assessments were conducted.

Although MMWEC’s application shows that the permitted changes will result in an overall reduction in potential emissions over the course of a single start-up/shut down event as well as over the course of the operating years when operating on its primary fuel source (natural gas), it also shows that there would be a net increase in total potential emissions both on a per cycle and on annual basis when the plant is operating on its backup fuel: diesel oil.

When SP2015A operates on natural gas, start-up emissions of nitric oxide and levels of particulates could increase. When burning diesel oil, start-up emissions of NOx, methane, particulates, S02m and Hs 204 could increase. These pollutants cause health risks, including cancer, birth defects, harm to the nervous system and brain, heart disease, COPD and asthma.

We agree with the Peabody Board of Health that the potential for elevated health impacts, particularly respiratory events, exist during facility start-up events. There is currently no mechanism to be aware of increased risks that may be associated with these start up events.

BCNS and the Peabody Board of Health have repeatedly requested information about whether and when the plant runs and what it is burning – to no avail.

BCNS also recommends the Peabody Board of Health’s safeguards be implemented prior to approving any application that allows, even for a limited period, an increase in emission of pollutants.

1. MMWEC should be required to conduct the Cumulative Impact Analysis described at 310 CMZR 7.02 (14).

2. MMWEC should be required to submit information about its compliance with air quality and other environmental parameters associated with its permit to the Board of Health.

3. MMWEC should be required to regularly share information with the Board of Health about any complaints received regarding emissions, odor, noise, or other environmental concerns, as well as corrective action taken.

4. MMWEC should be required to regularly share information with the Board of Health about any malfunction affecting emissions at the facility,as well as corrective action taken.

5. MMWEC should be required to install and maintain one or more air monitors in the adjacent EJ area that measures particulate levels and whose data is publicly accessible in real time, such as through the Purple Air Monitoring network or some similar public platform, so that the public can monitor local air quality and take individual precautions when relevant.

BCNS requests that MMWEC also provide details on the monitor to be installed at the plant that DEP requested after reviewing comments from the last public hearing (12/14/2?). BCNS has followed up with MMWEC as to the status of the monitor and how the monitor’s results will be published and available but we have not received a final update with details.

A health analysis of the neighborhoods within 2km of the Waters River Power Station was conducted by the BU School of Public Health in 2022 in cooperation with Mass Climate Action Network (MCAN). @ Pollution, People, and Power

plants: Health Burdens in Peabody, MA November 1, 2022

https://assets.nationbuilder.com/…/Pollution_People…

What surprised you about the 2023 plan?

S. Smoller, BCNS – I was surprised to find a voice emphasizing climate resiliency. I jumped up and cheered when I read about plans for a Sustainability Committee and hiring a Sustainability Coordinator! And, how do we get PMLP involved with the Sustainability effort?

What is missing from the 2023 plan?

S. Smoller, BCNS – I live in West Peabody but over the past two years I have fallen in love with the East End. There’s nothing in the plan about the Waters River. It’s too bad there are two gas-and-oil burning peaker plants there now. But, they won’t be there on City-owned land forever. One of the plants is slated to close in 2026. The second plant will be closed eventually as burning fossil fuels becomes more regulated. What is the plan for that space? – especially in a neighorhood with two proposed housing developments, a proposed charter middle school and development of a former Superfund site. There’s no public access to the Waters River now. The Danvers Open Space plan also highlighted increasing the access and use of the Waters River.

Let’s focus on the Waters River the way we have given attention to the North River. Lastly, the river is surrounded on both sides by Environmental Justice areas. As we move forward, how are we going to insure that these neighborhoods are not burdened further? We need a climate resiliency voice that reaches out to all the different city departments and helps us work together. Mayor, please hire a Sustainability Director.Draft Open Space Plan:

Activists want the Governor to revisit projects (like the Peabody Peaker) that developed under her predecessor

https://www.wgbh.org/…/as-healey-ramps-up-environmental…

The Office of Energy and Environmental Affair’s Environmental Justice Policy and Executive Order 552 require that EEA agencies develop their own strategies to “proactively promote environmental justice in all neighborhoods in ways that are tailored to their agencies’ mission.”

EEA’s EJ Office convened and led the EJ Task Force to develop this draft EJ Strategy. EEA is taking public comments on the draft EJ Strategy until January 27, 2023.

View documents and instructions for comments at:
https://www.mass.gov/info-details/eeas-draft-environmental-justice-ej-strategy

Support the Commonwealth in Advancing Environmental Justice
Your voice is important as we collectively work to advance environmental justice throughout the Commonwealth and will serve as the guiding force to the implementation of EEA’s Environmental Justice Strategy.

How Can You Engage 
Register for the online sessions or join us at one of the two in-person sessions. Click on Public Notice, which is available in multiple languages, for more detailed information. 

Public comments are accepted at this portal or can be emailed to ej.inquiries@mass.gov. Comments can also be mailed to the address below (postmarked by January 27, 2023):
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Attn: Carline Lemoine, Deputy Director of EJ for External Stakeholder Coordination

Free public event. Hosted by The Massachusetts Executive Office of Energy and Environmental Affairs (EEA).

6:00 pm – 8:00 pm EST
Online