Re: Greenidge Generating Station
Air Title V Facility Permit ID 8-5736-00004/00017
Facility DEC ID: 8573600004
October 13, 2021
Dear Mr. Hogan,
I submit these comments as a resident of Poestenkill NY and as chair of the Green Education and Legal Fund to request that the Department of Environmental Conservation (DEC) and the Hochul administration do not issue the Air Title V Facility Permit for Greenidge Generating Station as currently drafted.
Greenridge is no longer operating solely to provide power to the public and has become largely a private operation to mine Bitcoin. The financial rewards remain with the company and its investors, while the environmental impacts of its intensive energy use are externalized, impacting our community, our state, and our ever-warming world. Under Governor Cuomo, the DEC failed to consider this a new source and did not complete a thorough environmental review as required by SEQRA at its onset.
The power plant, with its new use as a bitcoin mining operation and its enormous increases in GHG emissions, will adversely impact our water and air quality, degrading the pastoral nature of the region and damaging vital environmental resources and our health. Its operation will also negatively impact the health of the vibrant agriculture within one of the state’s largest agricultural counties. Other negative impacts are thermal pollution and exploitation of our natural resources including our water, and noise levels impacting human health
This facility will not promote the aesthetic, cultural, or commercial values that have made the Finger Lakes a premier destination for residents and visitors alike.
This facility, and others like it, will prevent the state from meeting its critical climate goals established under the Climate Leadership and Community Protection Act (CLCPA). Facilities for these type of bitcoin operations are already having a major negative impact on climate changes, resulting in significant increases in greenhouse emissions both at this facility and worldwide.
Greenidge is a precedent-setting test case for other potential NY facilities, like the Fortistar plant in North Tonawanda. 6 other recently retired fossil fuel fired power plants in upstate alone have generating capacity of 2,130 MegaWatts, more than 20 times that of Greenidge. This and other facilities like it will prevent our state from achieving its bold Greenhouse Gas (GHG) reductions under the CLCPA
The GHG emissions at the Greenidge Generating Station are skyrocketing. When this former coal powered plant shut down, it was producing ZERO emissions from 2001 through 2016. When it transitioned to burn gas, no one knew that it would operate as a private Bitcoin facility that operated 24 hours a day 7 days a week. No one knew that it would go on to produce the amount of greenhouse gases that it is today and into the future. This should have been treated by DEC as a new source when it transitioned from a shuttered coal plant to a gas plant, and for this reason alone, Governor Hochul should now direct DEC to view this facility through the lens of New York’s Climate law and deny the Title V air permit.
Under CLCPA law, Greenidge is required to factor in both the greenhouse gases it produces on site, and the emissions generated “upstream”; meaning from the drilling site, through the pipelines and on to the power plant. These combined emissions, according to Greendge’s own calculations, would exceed the limit on its Title V air permit by nearly 67%. They project that their onsite and upstream emissions total over a million tons.
Under CLCPA, Greenidge is NOT carbon neutral as they claim. Sources in the electric generating sector are NOT allowed to participate in a carbon offset scheme.
A CLCPA Advisory Panel found that NYS can cut CO2 emissions up to 40% by 2030 if we eliminate 50% of our greenhouse gas emitting facilities and only produce 15 million tons of CO2 equivalents per year. If Greenidge expands to their capacity, THEY ALONE are projected to produce 1 Million Tons of that 15 Million Tons. This is not the model Governor Hochul can allow for this or other plants in NY to follow.
Dr. Robert Howarth of Cornell University and a member of the Climate Action Council established under the CLCPA, said “We can make the cuts by quickly ramping up renewable energy sources But we CAN’T do it if we have Greenidge and other Greenidge-like plants.”
In 2020, Greenidge emissions equaled 51,027 additional passenger vehicles on the road for one year.
Greenidge has not provided a justification for the Facility nor proposed sufficient alternatives of GHG mitigation measures. Now that its operation is primarily for private use, it does not serve the public in any meaningful capacity.
- NY’s Climate law states that if a facility would be inconsistent with or would interfere with the Statewide GHG emission limits, DEC must also: (1) provide a detailed statement of justification of the Facility notwithstanding inconsistency with the Climate Act; and (2) identify alternatives or GHG mitigation measures to be required.
- This gas-fired power plant is simply not necessary to serve either short-term or long-term power generation reliability needs. The power supply within Zone J, where this power plant resides, is already sufficient to address short-term local and longer term bulk power needs.
Greenidge claims that it is utilizing carbon offsets to counteract its emissions. However, NY’s Climate Law states that stationary power plants cannot avail themselves of carbon offsets, and that any offsets be located in the same county, and within twenty-five linear miles, of the source of emissions.
Air emissions and particulate matter from power plants like Greenidge are harmful to human health and crops, particularly grapes. Electricity production, the raw material of Greenidge’s proof of work cryptocurrency, has a profound human cost. Globally, four million premature deaths occur each year as a result of air pollution, a sizeable fraction of which are due to coal and natural gas combustion in power plants. Yates County is one of the largest agricultural producing counties in NY State, in the heart of the Finger Lakes, where the economy is dependent upon its clean air and water to support its driving economic engine- wine and tourism. This agricultural and tourist driven economy generates $3 Billion dollars for NY State annually, and supports 58,000 jobs. This predatory corporation is exploiting our natural resources at the risk to human health, people’s livelihoods, and our economy and Governor Hochul must deny the air permit renewal.
Most of the energy generated at this power plant is not going to the grid. Instead, it is being used by a private technology company where the financial rewards remain with the company and its investors, while the environmental impacts of its intensive energy use are externalized, impacting our community, our state, and our ever-warming world.
Because Greenidge threatens the environmental and economic sustainability of this region, is a precedent-setting test case for other aging power plants in NY, and is not consistent with the CLCPA, GELF requests that Governor Hochul and DEC deny the Title V Air Permit for Greenidge.
Mark A Dunlea
Green Education and Legal Fund, Co-Chair