SEA Exec Paul Chakroff Responds To CIF Article On Donors, Support Of Alpine Proposal
Crucians In Focus has received the following response from Paul Chakroff, Executive Director of the St. Croix Environmental Association, to an article entitled “Conflicts, Contradictions Abound In Alpine Support System; Why Is The SEA Testifying In Favor Of AEG?” We have printed his response in its entirety.
The sections in italic represent excerpts from the CIF article to which Chakroff is responding.
Michael Springer, President
Crucians in Focus
Dear Michael,
Thank you for publishing the Crucians in Focus article Conflicts, Contradictions Abound In Alpine Support System; Why Is The SEA Testifying In Favor Of AEG? I am happy to address the issues you have raised. Below I have addressed your statements or questions (in ital.) point by point.
Why would Paul Chakroff, Executive Director of St. Croix Environmental Association (SEA) testify in favor of the Alpine Energy Group (AEG)?
St. Croix Environmental Association (SEA) has endorsed waste-to-energy (WtE) and the technology proposed, not Alpine Energy Group.
The Legislature is holding hearings on the latest AEG proposal Tuesday on St. Thomas and Wednesday on St. Croix. Hearings on both islands begin at 6 p.m…. A review of the testifiers reveals all the usual participants, and one that caused us to question why an organization that was forcefully against the original Alpine proposal would now stand in favor of their newest plan…. A visit to the SEA website may have provided part of the answer to this question. If you were an organization committed to the preservation of the environment of the Virgin Islands, would you accept donations from some of the donors on this list?
Yes! SEA seeks and welcomes grants, contracts AND charitable donations from all sectors. There are many motivations for people, foundations or corporations to make charitable donations: EDC requirements, tax benefits, environmental impact mitigation, guilt, philosophical agreement, financial advantage, etc. The challenge to me is to ensure that a) donations are used according to any stated wishes of the donors, and b) charitable donations do not influence my advocacy position vis-à-vis the donor. There are both legal and ethical rules that apply here.
Let’s take HOVENSA as an example. For many years SEA has received $10,000 – $20,000 per year from this corporate citizen. We restrict their donation to our environmental education program and do not allow the donation to influence our advocacy position regarding our review of their air or groundwater pollution emissions. Our testimony on HOVENSA permit applications has not been particularly favorable to HOVENSA and I am happy to share that with you or your readers if you are interested in reviewing it. Similarly with DIAGEO, I am currently discussing a project designed to mitigate air pollution impacts on the people residing in Bethlehem Village and Profit Hills. If receipt of funding by SEA for education or environmental impact mitigation is a problem for you for your readers, we have to agree to disagree about a fundamental difference in opinion.
Any guesses as to who the “Anonymous” donor might be?
SEA’s anonymous donors are private individuals who shall remain anonymous until they instruct me otherwise.
Time certainly does bring about a change. Back when Alpine brought its first proposal to the VI in 2008, Chakroff had a completely different view of the company, its proposal, and even whether it was qualified to bid on the contract in the first place. Those contracts are still in place for the current Alpine proposal. What changed his mind?
What changed SEA’s position are the significant changes in the proposed project design (made in response to public pressure brought by SEA, VICS and other Virgin Islanders), not least of which is the guaranteed removal of petroleum coke as a preferred or even opportunity fuel.
At that time Chakroff, then director of the VI Conservation Society, waged a public campaign against Alpine through a series of letters to local media. The main objection to that project was the use of pet coke in the generation of energy – a possibility that officials have admitted still exists with the “new” plan.
I question your assertion that petroleum coke may be used in the WtE facility as currently designed. SEA understands that petroleum coke is out, even under emergency conditions. It is our understanding that (if approved) EPA and/or DPNR permits issued pursuant to the federal Clean Air Act will not permit petroleum coke combustion in the Alpine WtE facility.
However, note that he wrote with equal vehemence questioning Alpine’s suitability to bid on the project, and the effectiveness of the solid waste solution they were then and are now proposing. “How did Alpine get prequalified for a contract by WAPA in the first place? Alpine appears not to have prequalified under at least four of nine mandatory criteria, all of which the “respondent must pass to prequalify according to WAPA’s request for proposals (RFP)…” We at CIF have asked the same question.
After raising these questions, SEA made it clear that (per our mission) we would continue to carefully review environmental and public health issues related to the proposed project. We called upon ratepayer associations, financial experts or other concerned citizens to take up issues related to transparency in government, RFP procedures, contact law, and ratepayer/taxpayer costs. The fact that no legal challenge has come to these non-environmental issues is not SEA’s fault.
Chakroff went on to write: “It is our understanding that Alpine has never designed, constructed or operated a power plant, much less one similar to the one being proposed; and that neither the burning of petroleum coke in combination with municipal solid waste (MSW), nor the processing of fluff® or pelletized refuse-derived waste (PRDF) by the WasteAway® process are commercially proven.”
As a result of our thorough review of the proposed project, SEA has come to understand that the proposed energy generation technology is commercially proven and proposed to be designed and operated by companies with extensive experience in the industry. We remain uncertain about the Waste Away process and will continue to assess it through the CZM permit review process if the project reaches that stage.
“How much of VIWMA’s current budget will be displaced by payments to Alpine for processing PRDF? VIWMA will continue to incur costs for collection, transport, sorting and disposal both before and after the PRDF process.”
This issue has been addressed by VIWMA Executive Director, May Adams-Cornwall. As I have stated in testimony before the Senate, it is SEA’s position that this is among a number of issues that must be addressed in CZM Environmental Assessment Report, Sec. 7.00, Impact of the Proposed Project on the Human Environment. SEA and others will address this and other impacts in that appropriate forum.
“Does the Alpine deal solve our solid waste problem? While 40% (73,000 tons) of our MSW may be processed into PRDF, the Alpine facilities do not provide a solution for the other 107,000 tons of MSW generated in the USVI per year. Up to an additional 100 tons per day (36,500 tons per year) of metals, glass, grit and other noncombustible solid waste will be returned to VIWMA after PRDF processing…”
The answer to this question remains no. WtE does not solve our entire solid waste problem, but neither would any other single process. After nearly 3½ years of study, SEA has come to the conclusion that the territory cannot deal with 100% of our solid waste without landfilling, shipping off-island, and/or WtE. Without a landfill option (due to EPA and FAA court orders), or a shipping option for the bulk of our solid waste (due to the prohibitive expense to the people of the Virgin Islands plus its carbon footprint), we conclude that we must include environmentally acceptable WtE as part of a comprehensive solution to our solid waste problem for the near term, giving us time (2 decades, not 2-3 years) to maximize the role of reduction, reuse and recycling in addressing our solid waste problem.
“We need to separate the MSW discussion from the energy generation issue and allow VIWMA to move forward quickly on solving our MSW problem. Solid waste management and energy generation do not have to be handled together, and there appear to be strong regulatory compliance, economic, environmental and public health advantages to dealing with them separately.”
This remains SEA’s position. As now designed (unlike as designed prior to March 8, 2010), the Alpine project is principally a waste management project. The WtE project is a significant and critical part of an integrated waste management plan for the territory for the next 20 years. At the same time, a secondary benefit of the project is the supply of 91,646 megawatt hours of electricity at reduced cost to the WAPA ratepayer to the St. Croix grid.
The objections he raised at that time were valid then, and they are valid now. What is challenging to reconcile is how the representative of an organization whose mission is to protect the environment has apparently joined forces with an organization whose operation will only contribute to its destruction. Some of the objections that were valid then and valid now will be dealt with individually in public hearings required in consideration of various project permits.
To say that ALL previous objections are still valid is false. SEA has vigorously addressed (and been successful in pursuing) mitigation of environmental and public health impacts of the proposed WtE plant. Other financial and contractual investigations that have not been pursued by others may still be pursued within the framework of the permitting and legal system.
As you put it, SEA has joined forces with the people of St. Croix and the Virgin Islands for the last 26 years, and any suggestion that we take the part of an individual developer or project is totally erroneous. We comment on projects and issues, not individual companies. We have not joined forces with anyone but the concerned citizens of the Virgin Islands, and we believe that the project as currently designed, scaled and sited, offers a NET ENVIRONMENTAL AND PUBLIC HEALTH BENEFIT to the people of the Virgin Islands.
In addition, the WtE project enables recycling at levels we have never seen in the Virgin Islands. SEA’s proposal (ref. attached letter to Mark Lichtenstein) allows and encourages recycling of:
100% of the territory’s glass; 100% of the territory’s aluminum, steel and other metals,\; 100% of the territory’s recyclable (#1 and #2) plastics; 100% of the territory’s after-market white goods; 100% of the territory’s e-waste; 100% of the territory’s construction & demolition waste, and; 29% (18.5 million pounds per year) of the territory’s green waste.
This level of recycling would bring the USVI to par with recycling efforts that have been underway for over 20 years on the mainland.
Please let me know if I can address any additional questions in print or on air.
Yours,
Paul Chakroff
Executive Director
St. Croix Environmental Association
Steam chief – that kind of question needs to go to Alpine. Based on what I piicked up from the testimony and the
GBB report and the contracts, it would seem that WMA guarantees 400 tpd of waste, which is 125 tons per day less than what is currently being placed in the dumps. Using the guarantied amount only, and a 75% conversion ratio, you have at least 110,000 tons per year. Alpine claims the heating value is 8,100 per pound due to removal of inerts and drying. 1.8million mmbtu’s per year. Alpine also claims that the average heat rate for the boiler is 14,000, meaning it needs 1.3 million mmbtu’s to generate the required 94,000 megawatt hours. Just on the guaranteed waste alone, it looks like they have 35% more waste than they need. I guess, when you add all the additional waste out there, it starts to makes sense why they are building a bigger facility than necessary…the fuel is there to generate more inexpensive power to the community. Alpine should be coming the real folk hero in the usvi.
steamchief, I’m certain you know B&W, they are our selected vendor for the steam generator, you tell me, will a company with a 140 year history play the purported game anon is suggesting we are playing to make a quick buck? I didn’t hear any “real” answers about the mistrust, where does it come from? It obviously existed before Alpine came to town. I get a kick out of the accusation of being a washed up business man and yet being the head of a corupt organization that can assemble such a complex web. Please; tell me how that works?
Ms. Parten in response to your comment “Tell me this though, while you’re “on the line” (and since Andy Hixon doesn’t seem willing to respond to this question): If you’re so certain of your facts / figures and assertions, why is it that you don’t INSIST that EPA conduct their reviews of your proposed St. Croix burn operation, before insisting that the legislature of the VI must approve a land lease at Bovoni, for a RDF processing facility which does not require EPA review or approval”.
We are certain of our facts and figures. We cannot “INSIST” that the EPA do anything, you should know that. The EPA review and the approval of a land lease are independent, again if you had experience in development you should know this. You are trying to make these independent activities look related and they are not.
EPA has been reviewing the information we submitted for months. The lease approval is necessary to continue the local permitting process. EPA does not have jurisdiction over the facility on St. Thomas, this is the jurisdiction of the DPNR. If you don’t like this reality then perhaps you should try to change this process. Please don’t try to imply that we have control over the EPA or the GVI, you know better.
Say Don Hurd what about Susan Parten being a Virgin Islands hero didn’t you get? I need to put you on notice that things can turn real ugly if you continue to disrespect her by making those kind of childish remarks. If you say those sorts of things about a woman what are you calling the proximate black community here in the Virgin Islands? Is that why you have no problem burning what ever will make you a quick buck?
Don Hurd this is your final notice. You want to get ugly and insult our hero? Think you’re going to get away with it? Keep it up and see where it will get you.
We in the Virgin Islands thank God for sending us Susan Parten to cast away the Lucifer like you Don Hurd. Keep it up Lucifer and see how many more holy bible are open to cast you out into eternal misery.
Hurd, the mistrust as you aptly put, is because of the corrupt vetting process to begin with on the RFP, and the way you maneuvered your E3 incorporation to AEG for beginners.
Next would be you are a company of 3 failed, yes failed men from past ventures. You are just some guys scamming the VI, paying off those for votes to include WMA, WAPA, PSC, Administration and of course our ever corrupt senators.
It is an election year, so either you have to grease more or we the people will vote out any senator who votes for more pollution on STX and a deal that reeks of corruption.
Thank you Susan for all of your input.
ok, I am currrently running calcs- found a host of engineering literature. Calcs are lengthy- by end of the day I’ll have results (I do have a job that I work at)
For Mr. Hurd;
Before I start work (normal job) I have been struck by some questions regarding the contracts- since they “jumped off the page” I’ll ask them first, then start the calcs in about 4 hours;
1) Is it MSW or RDF which will be transported betweent STT and STX?
2) Now that Hovensa is closing- where are you going to get the secondary fuel source? How much will this impact the price?
3) What is your expected fuel rate for the secondary fuel (assuming 2 oil)
4) In the case that WMA experiences a waste shortfall, and electrical production is say reduced by 35%- Will Alpine still be charging the 85% minimum production charge even though only 65% is being delivered?
5) US Average cost for a WTE-RDF Plant is $30MM to $40MM, (or 75k to 102k per tons/day- based on 400 tons)- Whys is the cost of your plant so high?
6) The average ash remainder ACTUALLY runs about 15% of t/day input- what is being done with this generation of this 60 t/day of ash?
7) Chlorine emissions for RDF is about 0.6%- what is being done to scrub or process the chlorine gas production to prevent it from becoming airborne?
Thanks
and Mr. Hurd, did you send a copy of your bid pre qualification form to CIF? If you are confident Alpine commited no fraud why haven’t this form been posted to this website? Are you hiding something?
Mr. Hurd did Alpine Energy Group, LLC commited fraud? If not answer these questions and submit AEG prequalification submission to the WAPA RFP to this website administrator for the world to see. That is a direct challenge to you and AEG Mr. Hurd. Provide that evidence to substantiate that you and AEG is not a fraud.
Your failure to commit to this simply request for transparency will raise red flags through out numerous concern bodies. There is absolutely nothing in that form considered to be protected information other than potential fraudulent activity. Your cooperation is appreciated.
PR-11-08 Request for Proposal To Provide Electric Energy to the Virgin Islands Water and Power Authority DATE ISSUED: December 28, 2007 OFFERS DUE: May 1, 2008
ATTACHMENT G – Criteria for pre-qualification and for non price evaluation.
“Criteria for Pre-qualification (Respondent must PASS all to pre-qualify).
1. Company Information: Pass/Fail Comment
2. Company or affiliated parents established for more than three years?
3. Respondent has demonstrable experience operating generating facilities similar to the one being proposed?
Ms. Parten:
I previously answered your question about EPA a few comment pages back, but will copy/paste in case you missed it the first time . . .
I’m not sure what you’re suggesting with respect to EPA and their review time. EPA is currently reviewing emissions and energy balance information, but their review is independent of the Legislature approval of the Bovoni lease. We believe these steps should continue in parallel. So, we’re not trying to rush EPA into any sort of decision. However, we do believe it is necessary for the Legislature to vote on the lease ASAP so that the local permitting process (i.e., CZM) can continue. That process is on hold until the lease is approved. There’s no reason the Legislature’s decision on the lease should be impacted by EPA’s review of the project. If the Legislature approves the lease, but Alpine is not able to obtain all the necessary permits (EPA, DPNR, etc.), then Alpine’s option on the lease is void.
. . . follow-up, as Don suggested, we cannot insist that EPA does anything. They move at their own pace, issue decisions when they are good and ready. My guess is we will continue to have back and forth correspondence with EPA throughout the permitting process.
Good questions, SteamChief:
1. Shipping RDF from STT to STX
2. None of the secondary fuel was coming from HOVENSA. If I’m interpreting your question correctly, secondary fuel means things like rum bottoms, tire derived fuel, biomass, green waste, etc. We do plan on using ultra low sulfur diesel (ULSD) for start-up, but not as a secondary fuel to generate power. Just like WAPA, Alpine will have to find another source for ULSD with HOVENSA closing.
3. No planned fuel rate for secondary fuels on a routine basis. Minimum power delivery will be met through guaranteed MSW. Additional power is expected to be generated by secondary fuels as well as additional MSW that may be delivered above the contract guarantees.
4. With respect to your waste shortfall question, can you clarify where you’re coming up with the 85% number? Bottom line is that WMA knows the waste is there, else they would not have signed a contract.
5. Where did you get your cost numbers for US WTE Plant? I’m not aware of any WTE plants currently under development for less than $200MM.
6. Based on removing glass and other inerts, the ash content is expected to be roughly 10%. Annual ash generation will be roughly 10,000-15,000 tons per year, roughly 40-45 tons per day. The collection and storage process will be covered and protected from the elements. No ash will be stored outdoors. Alpine is currently working with local aggregate and construction companies to re-use the ash as road base material, erosion control blocks, etc. Prior to using ash for these types of applications, Alpine would have to obtain the appropriate environmental approvals/permits. In the event that the by-product cannot be used in the USVI, Alpine will ship the ash to the mainland US for re-use or disposal. The cost of managing and disposing of the ash belongs to Alpine.
7. You don’t get chlorine gas emissions from RDF combustion, you get acid gases like HCl. I’m not implying HCl is friendly, just saying there is a difference between chlorine gas and HCl. EPA’s NSPS Subpart Eb specifically regulates HCl emissions from WTE projects, requiring 95% reduction. Alpine will exceed this requirement through the use of a scrubber with a hydrated lime sorbent. B&W is familiar with controlling HCl both from WTE applications and coal fired power plants.
Don,
Not sure if it’s by design, or because you read my question wrong. But my question was not around your insisting ANYTHING of EPA. But rather that, if you’re so certain of your figures, facts, and costs, and there are such profound questions surrounding those assertions, that you insist upon WAITING until EPA has conducted their necessary reviews of your project (the St. Croix burn operation).
Regarding EPA has been reviewing your submittal “for months”, you only submitted information on December 13, and that is only just over a month, which as you know, is not that long for federal review.
What we do not want, and which is quite understandable for any reasonable person, is for ANYTHING around your project to move forward on St. Thomas, before EPA approves the St. Croix burn operation, which would be the only reason for any of your activities on St. Thomas.
“SteamChief”: You’re 125 tons per day high on your solid waste production figures, for whatever numbers you’re crunching. If you’d like to post your email address, I’ll be happy to send you the GB&B study that shows a total (all of the VI) of 403 tons per day. The figures I gave you broke that out between STT and STX.
Andy H said, “Annual ash generation will be roughly 10,000-15,000 tons per year, roughly 40-45 tons per day. The collection and storage process will be covered and protected from the elements. No ash will be stored outdoors.”
Any ash stored would become airborne once the first Cat 2 Hurricane hits the island in the tin roof building they plan to use. But of course that would do Alpine a favor since it would be spread across much of St. Croix and they would call it a “force majeur” so they don’t have to pay for any clean up.
Alpine claims: “The cost of managing and disposing of the ash belongs to Alpine.” Where is the clause where is makes certain that any effects whatsoever of fly ash distribution outside of the confines of their storage *is* their responsibility to mitigate and clean up to all those persons, people, home owners and businesses so effected.?
You see how WMA, wrote their own deal without regard to protect the residence of St. Croix, that was not vetted publicly but crafted by May Adam Cornwall with Alpine in the back room. When is all this nonsense going to end? Maybe after Alpine takes away some more money we don’t have and the people stop letting themselves be played as fools.
Andy Hixon:
Your comment that EPA reviews are completely independent of VI local reviews, is exactly my / our point. That is the VERY reason we need EPA reviews first, which as you know quite well (and your attempt to assert otherwise yell out disingenuousness) are pivotal, relative to sorting fact from fiction relative to your assertions regarding power production capabilities from local wastes, pollutant emissions from such wastes, etc. As you know quite well, LOCAL VI reviews and approvals will touch upon none of these things that go to the HEART of the resaonableness (UN-reasonableness) of your project.
You know these things well. As does Mr. Hurd. And you are banking on the “asleeep at the switch”, or “complicit at the switch” nature of the local process to try to get your nose “under the tent”.
Notice how Hurd and Don totally avoid the questions on the bidding process?
How 3E magically turned into AEG with the same incorporation numbers in the state of Colorado to falsefy the time in business?
mr hurd and hickson,
are you paying people to keep this discussion on the environmental part or operational part ? Its the one issue on witch you will win because you have the facts.
i will summerise my earlier post.
why are we fighting you tooth and nail: two other times a proect came to st croix and the results for our environment have beed a disaster for us, many people here have relaives who have cancer or asma as a result of renasance red dirt that still sits on our land, many have cancer or asma from hovenzas acidental releases of toxic materials, now befor they built here the experts and owners of theose projects swore up and down how safe it would be and all the midagating facts, sound familer isnt that what you are doing.
when you came here you made no attempt to getto know the people. no sitting down to dinner with the grass roots people and learning how to aproach them.
your manerisims and your methods scream in the face of our culture.
you say hi im MR Hurd let me tell you about alpine, when in fact you need to know anyone of us would say, good day wait for the responce then say im mr hurd how are you. it seems like a small thing but it is the glue that binds so many different people together while they have had to fight an on going struggle agaisnt the simple act of paying there bills and surviving. this is an afro centric comunity our sence of unity and pride comes befor all else. do you know whos clothes you showed up wearing? You show up wearing the clothes and manorisims of the ancestrial enemy of most of our people erocentric colinial/slave owners. you flaunt your wealth and keep the conversation only on what you want.
then you cant see why you are resisted. you know the alpine project might be a great thing for us, you may be willing to keep your word and keep this project clean and eficent, but you wont be selling power to us your selling it to a close to bankrupt WAPA that charges us $90 for power useage and $325 for leac adjustment, how can the adverage vi citizen expectalpine to save them anything?
my question for you is are you willing to do this our way?
im not asking because im not expecting alpine to come begging us, my experiance as a small bussiness owner that moved here and learned early on to do it the VI way where there was resitance at first there came aceptance and support. In the end i realised that what works here was just different and that did not make it bad bussiness or agaisnt my bussiness values.
It all starts with the manorisims and cultural actions that show you are open to the crucian way.
the island has a saying about crabs in a bucket always puling those who would escape the realitys here back down, want sucess with your project
demonstraight how your project lifts all the crabs and not just those crabs on top.
I guess Don and Andy have travel days today, so that they can be sure and keep their date with Hugo, May and the legislature tomorrow for the “Please give us that Bovoni lease agreement even though we haven’t gotten the necessary permits yet for our burn operation” date. (Wednesday, I assume St. Legislative Hall).
Steam Chief:
Are you a VI-licnsed engineer? Live in VI? Why don’t you come out and identify yourself?
Also — like Ms. Parten said — if you’re crunching numbers, and you’re using higher than the numbers she gave you for waste production, then you’re not crunching the right numbers. Could you get back to us all on that?
No, it’s not St. Thomas legislative hall tomorrow — looks like it’ll be Chuckie’s committee over on St. Croix at the Legislative chambers. Should be entertaining, for sure.
To “SteamChief” (yes.. we’re all curious who you really are):
Here are the figures you should be using, that Ms. Parten posted before for your number crunching, and which have been confirmed via correspondence with VIWMA’s solid waste consultant (GBB).
Susan Parten, P.E. on January 29, 2012 at 11:51 pm
Dear SteamChief:
Here are my answers to your questions, based on public information (not “spun” information):
1) Present Estimate for Total Volume of MSW from both STT and STX separately.
STX = 81,558 tons per year (short tons, per GBB Dec. 2009 Waste Characterization Study accepted by VIWMA)
STT = 65,515 tons per year (short tons, per GBB Dec. 2009 Waste Characterization Study accepted by VIWMA)
2) Estimated RDF Pelletized quotient for these MSW Streams, separately.
According to the categories of waste in the GBB study, approximately 84% is combustible. Therefore, of the total 147,073 tons per year for both STT and STX, there would be about 123,541 combustible tons per year of MSW. From that (and assuming an RDF production rate of 75% from MSW would be achieved), VI MSW might produce some 92,656 tons per year of RDF (assuming ZERO recycling of combustible materials). That comes to 254 tons daily, on average.