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HomeMy WebLinkAboutCOMMUNITY ENERGY SOLUTIONS ANALYSIS OF ELK RUN ENERGY ASSOCIATES LLC Community Energy Solutions' Analysis of Elk Run Energy Associates, LLC Annexation and Rezoning Application April 28, 2008 Package Contents Page Number Introduction 1 Annexation Issues 1 Rezoning Issues 2 Development Agreement Issues 3 Estimated Replacement Tax Analysis 6 Economic Impact Study 6 Impact on African Americans—Board of Health 8 Real Estate Property Value Study 9 Transportation Study— Trains 9 Traffic Increased 150% or more 10 Road Improvements 11 Traffic Impact on County Roads 12 Public Rights-of-Way 13 Plant Site Issues 13 Site Drainage, Flood Plain and Wetlands Issues 14 Wastewater Supply/Discharge Systems 14 Waste Methane Gas 15 Quarry 15 North-South Rail Spur Needed 16 Transmission Lines and Towers 16 Summary 16 Attachments: A. Time for Coal Train to Pass an Intersection 18 B. Transportation Impacts during Operational Phase 19 Articles: "Air of Injustice: African Americans & Power Plant Pollution Elk Run Energy Associates Biomass Analysis Iowa Coal Combustion Waste Disposal Community Energy Solutions' Analysis of Elk Run Energy Associates, LLC Annexation and Rezoning Application April 28, 2008 Introduction The annexation and rezoning petition from Elk Run Energy Associates LLC (EREA) to allow the building of a coal-burning merchant power plant does not align with the City's vision or the goals of the taxpayer-funded Greater Cedar Valley Alliance This City Council is simply not following Waterloo's Comprehensive Plan to promote and protect the health, welfare and safety of its residents. As citizens, we expect more discernment regarding new businesses being considered for our area. Some of you would dismiss this comment saying that this is the same argument used when land was annexed to create the Northeast Industrial Park a few years back. We see that this time there is a huge difference. This petition is for the sole purpose of building a mega-size merchant coal-burning power plant at a time when greater emphasis on energy efficiency and renewable sources of generation is called for. This coal plant will forever change the quality of life in the Cedar Valley which makes this public impact issue especially pertinent. "Today's city is not an accident. Its form is usually unintentional but it is not accidental. It is a product of decisions made for single separate purposes whose interrelationships and side effects have not been fully considered." (Page 5, Urban Design as Public Policy by Jonathan Barnett) This is the case here. Even though the City Council has repeatedly stated that the issue before them is only one of annexation and rezoning. The interrelationships of the many facets the City must consider before approving the applicant's petition for the construction of a pulverized coal-fired power plant are so vast, so huge, and so expensive that the limited analysis the City performed falls astonishingly short of safeguarding citizen's personal health and economic well being. After at least two years, many of the interrelationships and key dependencies involved in this project remain critical unknowns. Only when local government makes well-informed decisions exercising due diligence with documented, verified facts is responsible fiduciary behavior demonstrated to protect the best interests of its citizens. The following is a synopsis of what is believed to be the major crucial issues regarding the annexation and rezoning petition before the City Council of Waterloo. Annexation Issues 1. On April 1, 2008, the City's Planning, Programming and Zoning (PP&Z) Commission recommended the annexation petition as submitted which included suspension of three city ordinances. City Staff Report stated that the selective Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 1 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of waterloo,Iowa suspension of ordinances for one situation is illegal. Therefore all citizens of Waterloo may be able to burn leaves, discharge firearms and ignore the International Property Maintenance Code which was just adopted in 2007 and was a primary 2007 city objective. Because the current PP&Z Commission appeared to fail in its fiduciary responsibility by ignoring this issue, one would wonder why those persons who voted in favor of this annexation should not be replaced. 2. It appears that no County/Township consultation meeting was held 30 days before hearing as stated in Iowa Code 368.7. Isn't this a violation of code? 3. Could the LESA land score be considered suspicious because of the City/County joint planning function? 4. Railroad is being annexed to the City as a flagpole annexation. Just as Newell Street was a flagpole in the last petition, the City Attorney concurs that there is still an outstanding issue regarding the legality of flagpole annexations in Iowa. What happens to this whole petition is in court it is proven once and for all that flagpole annexations are illegal? Where is this risk analysis? 5. Will this be a "conditional' annexation, meaning if EREA does not get the required permits, the land will be deannexed? 6. If this is not the case, then those people living on the newly annexed city property can demand city services. What plans does the city have to satisfy this legitimate request? Rezoning Issues General 1. Has City Staff completed an independent cost-benefit analysis with risk assessment of potential future liabilities of the financial costs (capital, operating, maintenance and fuel costs), health costs (increased health aid to low-income people, costs of premature deaths) and environmental impacts of data/information supplied by applicant? Determining the health, environmental and economic damages associated with air pollution changes requires rigorous analysis using health and environmental impact modeling reflects sound municipal planning in my opinion—a point that the state's City Development Board noted that was not evident in the documents submitted to them. To open up this large area for industrial development without any community planning is certainly not fulfilling your fiduciary responsibility to the citizens of Waterloo. 2. Revised Zoning Ordinance tabled after two years work by the Planning, Programming and Zoning Commission. Does it seem very odd that the new ordinance would have required review of more governmental entities and more inspections to protect citizens and yet the entire revision was tabled because Council could not decide on 200 square feet for metal-sided buildings? Wonder if the timing of this zoning ordinance delay and the applicant's recent refiling is somehow related? 3. So since the new zoning ordinance was tabled, it appears that fire inspection report is not required for this power plant. 4. The land use must be a consideration of the rezoning action this time. "This is a multiple decade commitment to higher levels of pollution representing a 5% Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 2 of 20 Prepared by Community Energy Solutions Submitted on Apr l 28,2004 to City Council of Waterloo,1mm increase in the state's greenhouse gas emissions. This is equivalent to adding more than 700,000 vehicles to the highways in Iowa every day for the life of the plant." (State Rep. Rob Hogg, 2/15/2006) And the expected life of this plant is between 40-50 years!!! 5. On page 1 of 24 in the PROJECT DESCRIPTION first paragraph, the applicant states that the "(p)ower produced by the Project will be sold under long term contracts to local...electric utilities." Isn't it interesting that MidAmerican Energy, the local franchise provider of electricity for the City of Waterloo, has stated many times that they have no intention of buying power from ERES and yet the applicant is allowed to make this statement in their application to the City? 6. In the Applicant Overview, it states that "Two coal-fired facilities located in Arkansas and Texas are currently under construction. All of the projects developed by the firm have enjoyed the support of the local community." Visit www.txpower.org to understand how local communities in Texas are fighting and winning against the construction of these coal plants. We believe the Texas facility's construction is currently held up in the courts. Do you wonder what the real reason is for LS Power engaging with the University of Austin on page 3 of 8 of the Applicant Overview? Is it the same tactic used here in Iowa— o influence the public with the perception of good corporate citizenry while petitioning to forever destroy our quality of life? 7. Resolutions of support seem marginally relevant. a. Resolution of Support for New Industry from the: • Greater Cedar Valley Chamber of Commerce Cedar Falls and Waterloo • Greater Cedar Valley Chamber of Commerce Waterloo • Waterloo Industrial Development Association • Waterloo Development Corporation • Greater Cedar Valley Alliance All "support the concept and location of the Elk Run Energy Station in Black Hawk County." Wonder why there is no stated support from these groups to locate the plant in the City of Waterloo? b. Support from Resale Power Group of Iowa Currently these entities purchase their power through Midwest Independent Transmission System Operator(MISO) and they will do so in the future. It would seem to me that a demonstration of real commitment to support Elk Run Energy Associates, LLC would have included the stated intention to enter into purchase power agreements. Development Agreement Issues General In the Application for Rezoning, the Applicant states on page 7 of 8: "As codified in the Development Agreement between the Applicant and City of Waterloo dated May 7, 2007, pursuant to City of Waterloo Resolution No. 2007-333 adopted May 7, 2007, Applicant has agreed to certain conditions related to direct funding support for certain Review of Annexation and Rezoning Application by Elk Rim Energy Associates,LLC March 2008 Page 3 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa social programs and initiatives, upgrades to required infrastructure such as Newell Street and pipelines, and mitigations to local transportation impacts. This legal agreement between the Applicant and the City is a corporate dream and a citizen's nightmare. It contains many ambiguities and lacks concrete terms and conditions. Much of what follows is directly related to the provisioning of City services and the relationship of those services to the best interests of the citizens. Critiques: A. Article 3— "Obligations of the City" 1) Section 3.3; "Voluntary Severance" — City officials have on numerous occasions, verbally and in writing stated that filing (recording) would not occur until such time as the State has issued its appropriate permits and licenses. However, the City approved both annexing and rezoning the territory on May 7, 2007 and, prior to State approval, recorded same with Black Hawk County Recorder on July 31, 2007. 2) Section 3.6; "Rights-of-Access", Section 3.7; "Waste Methane Agreement" and Section 3.8; "Sewer and Water Services"—Each one of these sections contain no concrete terms or conditions guaranteeing that the public will be protected from absorbing unknown costs as time goes on. B. Article 4— "Obligations of the Developer" The fulfillment of many of those obligations that reside with the Developer are fraught with such statements as "Developer agrees to explore in good faith the potential incorporation of waste methane..."; "Incorporation of biomass fuels as part of the Project shall be determined based on Developer's sole discretion"; "Developer shall endeavor to "act in good faith to incorporate agriculture, green space, conservation best management practices..." Above all, Article 2, Section 2.2 makes the obligations of the Developer in Article 4 binding only if three major contingencies have been met. How is a contractual agreement containing such open-ended non-specific statements which leave the Developer with no firm obligation to perform in the best interests of the citizens? Since the Developer has been touting the environmental benefits in print ads and in speeches, the City should consider imposing a $1 million tax penalty for every percent below the 10% that the Developer fails to deliver on stated promises. This is proactively protecting the City of Waterloo. 1) Section 4.4: "Road Development" — The plan is to "upgrade" the whole of the Newell Street easement running between Elk Run Road and North Raymond Road, after which the City will assume responsibility for maintenance of the road through an unspecified and as yet unnegotiated agreement with the County. This upgrade is necessary to support the massive increase in traffic on Newell Street during construction and operation of the proposed coal plant. The cost of this proposal is not in the best interest of the taxpayers of Waterloo, when the sole beneficiary will be one company, Elk Run Energy, and the uncertainty of the maintenance arrangement with the Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 4 of 20 Prepared by Community Energy Solutions Submitted on Aprl 28,2008 to City Council of Waterloo,Iowa County is not in the best interests of the neighborhood residents and will undoubtedly lead to future conflicts between the City and the County. 2) The City is required to secure rights-of-way on one side of Newell Street for the road upgrade. If these rights-of-way are taken involuntarily, this is not an action in the best interests of the citizens. 3) What is noticeably missing from this Development Agreement is a plan for the rebuilding and/or reinforcing of the Newell Street bridge, even though it is stated as a need in the Staff Analysis under Tab F of the City's June 26, 2007 submission to this Board. 4) The newly-retired County Engineer, in his Technical Review of LS Power Development, listed over $15 million dollars of drainage, transportation and truck route expenses. Where is the analysis of these funds to make sure that the citizens are not going to shoulder the burden for the industrial development? C. Section 4.8 Transportation Study In this section it says: "Developer agrees to use commercially reasonable efforts to employ all of the recommended mitigation measures identified in the Transportation Study with the intent of minimizing adverse impacts to the local community." To the City Attorney who negotiated this agreement, "commercially reasonable" means that, "LS Power does not have to comply with the Transportation Study 100%but only have to do their best as any other business would do. There may be factors beyond LS Power's control." The recourse the City negotiated is if Elk Run Energy deems that the mitigation criteria becomes too expensive the Development Agreement can be reopen to negotiations. How can the public be assured that the City will hold the best interests of its citizens foremost in any negotiation and hold LS Power to its promise in the April 3, 2007 PP&Z meeting where Mark Milburn, Project Manager, stated and I quote"...(T)here would be road upgrades required, particularly to Newell Street, and LS Power would commit a significant portion of the cost in doing that and there will not be any burden of the costs on the residents." (Minutes of April 3, 2007 Meeting of Planning, Programming& Zoning Commission,page 9). D. Other-Assurance/Performance Bond Why hasn't the City prudently demanded an assurance/performance bond from EREA to cover any loss the City may experience if this project is abandoned after construction begins?LS Power abandoned three projects in 2007 and one already in 2008. Apparently even this company throws spaghetti at the wall to find out what sticks. E. Other Decommissioning At no time has the City held a public discussion or submitted a public document to indicate an obligation on the part of the Developer to be responsible for those costs associated with the decommissioning of the plant should it cease to be Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 5 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa completely built or to become operational. Good business practices and a desire to serve the best interests of the citizens would dictate that a bond, an escrow account, or some form of financial protection to cover those decommissioning costs would be required of the Developer. Do we need another Chamberlain, Rath or maybe another superfund site? The City's consistent lack of responsible planning and responsiveness to the issues raised by concerned citizens throughout this annexation process indicate that the City has not fully weighed the impact of its decision or the impact of that decision— both present and future—on the current and future interests of the citizens of Waterloo. Estimated Replacement Tax Analysis 1. The revised Project Design (page 1 of 24 of the Application for Rezoning, March 2008), says, "... (T)he project is being developed to accommodate a single power generation unit of up to approximately 750 MW in net capacity...." This statement differs from the first application;there was no qualification of capacity. This is a critical nuance as it may potentially impact the replacement tax calculations drastically as net capacity has no relationship to the number of potential customers. 2. In the table on page 15 of 24 of the application, the estimated breakout of the annual replacement generation tax revenues which would be assessed on the Project in lieu of property tax pursuant to Iowa Code 437A is shown. The annual estimated amount for the City of Waterloo is $851,363 based on the plant operating at 80% capacity. Richard Latham, an energy expert brought in by Progress Cedar Valley, states that the average capacity factor (total output divided by potential output in a year, typically) for Iowa coal plants is 60% so the tax pot has potentially decreased to $638,522. What if the plant only operates at 25%, a potential possibility as stated in the applicant's DNR application then the number is $266,051 per year. There is no mandatory minimum amount the applicant must pay to the City in the Development Agreement. This omission from the Development Agreement may represent a major exposure to the City for services they would be obligated to supply. Furthermore the applicant states that the "final capacity of the ERES will be determined as development of the project progresses." Where is the City's risk assessment analysis of this critical component of this project? A component that has been used to sell this project to citizens of Waterloo as a potential "gold mine." Economic Impact Study 1. Where is the economic analysis that looks at the businesses that will be put out of business because of the pollution caused by this power plant? The strawberry farmer comes to mind. How will local farmers deal with acid rain and the impact on crop yields? Wonder if Warren Transport has a heck of a time staging John Deere tractors on the railroad spur. Where is this impact analyzed? Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 6 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo 1mm 2. What happens to Waterloo when the Federal Clean Air Standards are exceeded as happened twice last year?No new businesses will be able to relocate here. When a location is out of compliance with these ambient air standards, this impacts funds received from the Federal government—Transportation Funds and Block Grant Monies are impacted. What happens when our current businesses cannot expand? Where is the validation of the economic impacts to justify the building of this plant at the expense of potentially other future viable business opportunities? 3. Author's disclaimers stated in the Economic Impact Study indicate that a broader view with other dependencies and considerations is needed to make an informed decision. What study has the city conducted to look into all the key interdependencies? 4. A standard ratio that economists use to determine economic benefits is that when money is made by a local company, it stays in the community and turns over a minimum of seven (7) times; whereas profits earned by a non-local company are transferred out of the local economic system and sent to the company headquarters. Obviously portions of salaries earned are spent locally if person lives in the community. Will the citizens really realize the touted economic benefits from this project? 5. According to the applicant's data provided for the Transportation Study the number of employees in Year 1 is 350, Year 2 = 1000 Year 3= 1100 Year 4= 500. How come in the Project Overview(page 1 of 8) that "more than 1,200 jobs (will be) required at the peak of construction" and yet the analysis of economic impact is based on the array of jobs over the years as stated above? Would this difference in how jobs are counted significantly distort the local economic stimulus?Where is the City's risk assessment study of this difference? 6. In the Economic Impact Study, it states (page 7) that "75 percent of the labor needed for the project will come from the existing three county region (Bremer, Grundy and Black Hawk) and the remaining 25 percent accumulates ultimately to other places outside of the region." How much benefit will the City of Waterloo actually realize given these facts? Where is the analysis from the City's Chief Financial Officer validating this study? 7. Mark Milburn responding to Harold Getty's questions last year indicated that they will hire their own General Contractor and he will hire his employees. The applicant's document substantiate this fact that 3 of workers will come from a three county area and that 1/4 of the workers will be hired outside of the region. 8. How do we position the union support? Actual jobs or only dues paying workers from out of state or out of area?How many workers from Waterloo will be hired? Do we have the skilled labor pool here? Have you researched what job skills are needed to run a coal plant? What independent analysis has the City done on this issue? 9. Why hasn't the City prudently demanded an assurance/performance bond from EREA to cover any loss the City may experience if this project is abandoned after construction begins? Elk Run Energy Associates is an LLC and only an affiliate of LS Power. One would think the City would protect the citizen's from future tax hikes if this company defaults. Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 7 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa 10. What is the financial health of this LLC? LS Power abandoned plans for three coal plants in 2007 and one in 2008 so far. Where is the risk assessment considering this possibility? 11. Could the promise of funding for certain social programs be viewed as soft bribes for support? Impact on African Americans-Black Hawk County Board of Health 1. On January 16, 2008, the BHC Board of Health took a stand for the health of the people of the County by adopting the following Focus Issue: "Human Health Effects of Emissions of Particulate Matter and Recommended Functional Role of Public Health in Black Hawk County": a. The Black Hawk County Board of Health recommend the state lower its annual average PM 2.5 standard to 12 p.g/m3. b. The Black Hawk County Board of Health recommends a moratorium on the permitting of state-regulated coal-fired power plants in the State of Iowa until safe and clean energy production methods are available. c. The Black Hawk County Board of Health should investigate developing its own air quality monitoring program in conjunction with Iowa Department of Natural Resources and Iowa Department of Public Health. d. Iowa Department of Natural Resources and Iowa Department of Public Health should be urged to join efforts to incorporate public health standards in the permitting, compliance and regulatory process governing Iowa air standards. 2. According to the BHC Board of Health, asthma hospitalization rates among African American citizens of Black Hawk County are 2.5 times higher than the overall county average and 40% higher than the state average hospitalization rates for all African Americans in the state. What analysis has been done to a determine any possible future liability when residents become ill due to the effects of the pollution caused by this power plant and cannot afford health care? Have both the City and County now been put on notice from its own Board of Health regarding the harmful health impacts resulting from the pollution created by a coal-fired power plant? 3. This proposed 750 MW merchant coal-fired power plant is a large emitter of particulate matter. For a plant located only five miles northeast of the City of Waterloo, emissions will add to already high ambient PM concentrations and add to the already existing risk of pulmonary and cardiovascular disease prevalent in the county. Individual risk will be highest for those county residents living or working in close proximity to the plant (approximately 1,100 residents and 6,500 workers within a 6-mile square area around the site). What responsibility does the City have to Deere and Tyson and the other major businesses in this area? 4. In the attached article, Air of Injustice, "a landmark environmental justice study conducted by the United Church of Christ titled "Toxic Waste and Race" established that race was the most reliable predictor of proximity to hazardous waste sites in the United States — more reliable than poverty, land values and home ownership." Are our African American citizens in Waterloo expendable? Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 8 of 20 Prepared by Community Energy Solutions Submitted on April 28 2008 to city council of Waterloo Iowa Real Estate Property Value Study 1. The Real Estate Property Value Study appears to be very narrow in scope of study. Where is the inclusion of city, county residential properties, commercial business/land and agricultural land? 2. On page 17 of 24 under Property Value, the applicant makes this statement: "...(T)he Project site area has not experienced a new residential development for over ten years." Absolute truth. This area is either farm land or residential acreages without purposeful development. What a sales argument! 3. Not stating the differences of scale between size of UNI and CFU coal plants appears to be a major omission in the study. The UNI plant is 100 times smaller and CFU is 30 times smaller. A key fact is that they operate only when energy is needed not 24/7 365 days per year as this wholesale plant is planned to do. Why was this critical point omitted from the report? 4. The real estate market is certainly different than it was last year and yet the study has not been updated. Where is the City's analysis of current trends and impacts of the market so as to protect its citizens from a false sense of security? Transportation Study Trains 1. Where is the actual location of the railroad connector? The proposed new connector is drawn on the map submitted in the application. Why will not the City name the streets now that are considered as possible options? Don't citizens have a right to know before a decision is made to annex and rezone? 2. What citizens will be impacted by condemnation to build this connector? 3. Where is the engineering and environmental study as recommended one year ago? 4. What if intersections will be blocked by 135-150 open-air coal cars pulled by 4 diesel engines? Where is the statement from the railroad companies disputing this fact? 5. The amount of coal to be hauled has potentially increased from 3 million tons to 4 million tons per year. Will the coal trains be longer now and block our intersections even longer? Or will there be more frequent trains? In either case, what are the city's contingency plans to handle blocked intersections and potentially increased emergency response times? (See Attachment A — Time for Train to Pass Intersection) 6. What will the expected response time be for fire, police and EMS? Where is the statement from the Fire Chief, Police Chief, and EMS to attest to the alternative routes that will be needed to meet response time objectives? 7. How can we protect teenagers from jumping the tracks to get to East High? 8. What is the City's plan to increase the street sweeping schedule to remove the fugitive dust escaping from coal trains that will probably accumulate on streets and sidewalks? Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 9 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Io..a Trucks Traffic Increased 150% or more 1. In the rezoning application under Project Design on page 1 of 24, the applicant states that the plant will burn "up to 10% biomass sources." In the Courier on Sunday, April 13, 2008, Elk Run Energy Associates, LLC advertised that "The plant will also reduce emissions by using renewable energy from biomass products as a supplemental fuel source." 2. In this rezoning application to the City, where does it state the number of trucks that will haul this biomass? The number of trucks/day is stated as 53 in Elk Run Energy Associates Application for an Air Quality Permit petitioned before the Department of Natural Resources, February 2008. When asked about this omission at the April 1, 2008 P&Z meeting, Mr. Mark Milburn, project manager, stated that they must report the maximum number to the DNR. (See Attachment B Transportation Impacts during Operations Phase) 3. How is it that the applicant states in the application to both the City and to the State that the intention is to burn 10%biomass and yet no trucks are accounted for in the City's application? Would it not follow that 53 trucks are needed each day to haul in biomass to the plant site as stated in the DNR application? Or does the applicant really not intend to reduce emissions by burning biomass and this is the reason it was omitted from the application to the City? See attached analysis of Biomass Facts. 4. In the application to the City(page 8 of Transportation Study), the applicant states that 33 trucks will be needed to haul the carbon combustible materials to the quarry. Again in the DNR Application the number of trucks has increased and is divided between trucks hauling Bottom Ash (4.4/day) and trucks hauling Fly Ash (38.4/day) for total trucks hauling to and from the quarry as 42.8 trucks/day. This increase logically seems to follow since the amount of coal has increased to 4 million tons per year from the original 3 million tons of coal. 5. The following additional numbers of trucks are stated in both applications: Active carbon = 0.5 truck/day; Lime = 3.7 trucks/day; Ammonia = 0.5 truck/day and Miscellaneous deliveries=4.0 trucks/day. 6. What is the impact on roads now for a total number of trucks at 104.1—an increase of 150%? Isn't this increase significant enough for the City to evaluate the City infrastructure? Since there appeared to be no Technical Consultation Meeting convened for this new application, how is the County to know of this tremendous increase in truck traffic on County roads? 7. Here are other deliveries by truck (turnovers) that appear to be missing from the application to the City but were stated in the DNR application: • 8 turnovers per year of distillate fuel • 14 turnovers per year of diesel fuel for storage tank • 40 turnovers per year of diesel fuel for 1000 gallon horizontal storage tank • 7 turnovers per year of diesel fuel for Emergency Firewater Pump • 12 turnovers per year of unleaded gasoline for horizontal storage tank These additional deliveries potentially amount to another 81 trucks entering and leaving the plant site. Where is the impact analysis?Has the County been informed of this increase, perhaps, during a Consultation Meeting? Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 10 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa 8. What types of trucks will be hauling on our roads? What is the weigh limit for each type of delivery either into the plant or hauling out of the plant? 9. Will trucks hauling to the quarry be securely covered to prevent air pollution? Tie down tarps are not secure enough to contain these fine soot particles. 10. According to Table 5 page 8 of the Transportation Study, the calculation assumption appears to be that the trucks will haul between the hours of 7:00 a.m. and 5:00 p.m. What zoning ordinances in the city and county restrict hauling into the night? This is a 24/7 operation 365 days/year, after all. The Development Agreement is also silent on this issue. 11. On page 12 of 24, the applicant states: "The CCBs truck traffic going to the south Waterloo quarry would be routed as directly as possible onto US 20, Iowa 21 and US 218; it would avoid Dysart Road and downtown Waterloo." Is this the stipulated route? Or is it one of the many others listed in the Transportation Study?How will the city enforce this stipulation? Or will this enforcement burden be placed on the county? Road Improvements 1. Originally Newell Street was to be annexed to the City as a flagpole annexation. It now appears that those property owners along Newell Street that have an option to sell to EREA will have their easements annexed into the City. Those owners along Newell Street that are directly opposite will not have their easements annexed. So it looks like parts of Newell Street will be divided in half—some easements in the city and some in the county. And some other owners with easements on Newell Street will remain unchanged. Even though some streets exist today in this bifurcated "ownership" between city and county, why does the City of Waterloo purposely enter into such a complicated situation? Does this example of planning follow principles of sound municipal planning? 2. How will taxes be allocated between these two entities? Who will be responsible for maintaining this bifurcated road? 3. What new considerations must be considered now that only half of Newell Street will be annexed to city (the other half will still be a county-occupied road)? Doesn't upgrading and possibly widening require increased rights of way? When will owners of the easement be told that they must give up more of their land for the road easement? What is the cost for buying these easements? Who pays? Will the county abdicate its responsibility for its half of Newell Street?What if there is resistance from the people?What then? Condemnation of land? 4. In the application on page 13 of 24, it states "Newell Street should be paved and upgraded between Elk Run Road and the Project in order to adequately accommodate construction and operations traffic." The Development Agreement 4.4 Road Improvements states that "Developer shall provide funding for upgrading Newell Street between Elk Run Road and Raymond Road." One would surmise that the Development Agreement is binding on the Developer to upgrade Newell Street from Elk Run to Raymond Road. Explicit statements are required. Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 11 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa 5. Is Eagle Road, a gravel road, currently capable of withstanding the increased heavy-weight truck traffic to and from the quarry without incurring substantial damage? Who pays for the repairs? 6. What contribution costs for ongoing maintenance have been negotiated with applicant? What funds have been identified for the additional street sweeping that will be required to remove coal dust to keep roads safe for traffic both in the city and the county? 7. Will Elk Run Road be widened and upgraded?Who will pay? Who will maintain? 8. Newell Street is a county-occupied road with easements granted by owners of property along this street. To upgrade the road the City must enter into an agreement with the County. The Development Agreement codified between the Applicant and the City of Waterloo dated May 7, 2007, pursuant to City of Waterloo Resolution No. 2007-333 adopted May 7, 2007 describes upgrades to required infrastructure such as Newell Street and pipelines. 9. What about the needed upgrades to the Newell Street Bridge? No specific statement is made in the Development Agreement committing the developer to contribute funds for this bridge upgrade. Because this upgrade appears to be needed for one business, how much will this upgrade cost the taxpayers of Black Hawk County without any reimbursement from the developer? Shouldn't the cost causer be the cost payer? Traffic Impact on County Roads 1. On page 12 of 24, the applicant states: "The CCBs truck traffic going to the south Waterloo quarry would be routed as directly as possible onto US 20, Iowa 21 and US 218; it would avoid Dysart Road and downtown Waterloo." Is this the stipulated route? Or is it one of the many others listed in the Transportation Study?How will the city enforce this stipulation? Or will this enforcement burden be placed on the county? 2. Section 2 PROPERTY INFORMATION of the Application for Rezoning in Section g Conditions (if any) agreed to (page 7 of 8), states that"....(M)itigations to local transportation impacts." In the Transportation Study on page 2, there are "Mitigation Measures" and on page 16, Section 5 PROPOSED MITIGATION list nine (9) recommendations "to further mitigate the impacts of additional roadway and rail traffic." Which of these or all of these are implied in the Development Agreement? Clarity is critical in these negotiations. What is the agreed upon route these trucks will take to the quarry? 3. On page 9 of the Development Agreement, paragraph 4.8, Transportation Study, states "Developer agrees to use commercially reasonable efforts to employ all of the recommended mitigations measures identified in the Transportation Study." To the City Attorney who negotiated this agreement, "commercially reasonable" means that, "LS Power does not have to comply with the Transportation Study 100% but only has to do its best as any other business would do. There may be factors beyond LS Power's control." The recourse the City negotiated is if Elk Run Energy deems that the mitigation criteria becomes too expensive the Development Agreement can be reopened to negotiations. How can the public be Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 12 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa assured that the City will hold the best interests of its citizens foremost in any negotiation and hold Elk Run Energy Associates, LLC to its promise in the April 3, 2007 PP&Z meeting where Mark Milburn, Project Manager, stated and I quote "... (T)here would be road upgrades required, particularly to Newell Street, and LS Power would commit a significant portion of the cost in doing that and there will not be any burden of the costs on the residents." (Minutes of April 3, 2007 Meeting of Planning, Programming&Zoning Commission,page 9). 4. Is the gravel Eagle Road currently capable of withstanding the increased heavy truck traffic to and from the quarry for the next 40-50 years? 5. Will Elk Run Road be widened and upgraded? Who will pay? Who will repair? Who will maintain? Public Rijihts-of-Wav 1. How is it that one company is allowed to use public rights-of-way when this company is not a public utility? Plant Site Issues 1. Where is the environmental study to protect the city from future liability from the county and/or other municipalities? 2. What type of city building permit is required to build an electrical sub-station on site? Who is qualified to inspect this facility to ensure the safety of all citizens including the power plant workers? 3. What city permit is required to build a private railroad track on the property? Who in the city is qualified to inspect this construction? 4. Will the noise levels of the plant operating around the clock violate any city ordinances? 5. Will the plant lighting shining all night violate any city ordinance? 6. The DNR regulates fugitive dust within the plant boundaries. How will the city protect citizens from fugitive coal dust from the trucks leaving the plant and from dust blowing off coal piles? 7. In this new annexation application, Elk Run Energy changed the wording from its original application where they stated there would be "a coal yard and handling system" to a "fuel handling and storage systems." Without researching the difference in these words, does the city know that the following information was provided to the DNR in EREA's Air Construction Permit submission? EREA describes three coal piles in Section 3 of that document as follows. • "The Active Piles will approximate the shape of two cones with approximate base diameters of 160 feet and heights of 51 feet." • "The Emergency Pile will approximate the shape of a cone with an approximate base diameter of 165 feet and height of 60 feet." • "The Inactive Pile will be generally rectangular in shape. The approximate dimensions of the pile will be 860 feet by 700 feet at the base with a height of 30 feet and a side slope of 2:1. Approximately 6.6 percent of the pile may be disturbed once a week. The remaining 93.4 percent, the Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 13 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa Inactive Portion, is assumed to be affected by wind erosion and is calculated as industrial wind erosion." Since the applicant did not provide engineering ties regarding the coal piles that are shown near Newell Street on the conceptual drawings, what city ordinances cover set backs of coal piles? One would think this information is needed so that the city and county could evaluate the impact upon citizens? 8. Will additional fire protection be required considering the volatile chemicals that will be stored on site (ammonia, lime, cleaning fluids, gasoline and diesel)? What about spontaneous combustion of coal piles?How do you know what dangers lurk inside the property lines? Does the city/county have fire engines large enough (hook and ladder companies) to respond to emergencies on site if the plant emergency systems fail? How do you know? 9. What if water usage is greater than estimated and we enter into the predicted drought, who gets water first? Citizens, farmers or power plant? Why does the Development Agreement favor the power plant over citizens and farmers? 10. How will utility services be routed? Is this another potential ROW issue? 11. On page 10 of 24, PROJECT IMPACTS, Land Use, the applicant was originally going to donate the multi-use recreational trail to the City of Waterloo? This language is missing from the new application. What changed and why? Site Draina,'e, Flood Plain and Wetlands Issues 1. When will the environmental impact study be completed for site drainage, flood plain and wetlands protection? 2. What impacts will site drainage have on Newell Street and the bridge plus the properties located across and down the road from the site? What about Phyllis Morgan's land some of which is located in a flood plain? 3. What protection does the city offer citizens from contaminated holding ponds? 4. How will the city mitigate the fugitive coal dust contaminating the wetlands? Wastewater Supply/Discharze Systems 1. If the wastewater treatment plant (WWTP) is unable to provide the required total amount wastewater-12-15 million gallons per day (the total volume of the wastewater stream), the applicant says of page 3 of 24, "During times of low flow at the WWTP, the effluent will be supplemented by mixing in fresh groundwater from the local Water Works." What agreements/plans have been made to protect citizens if this area experiences the predicted drought? What citizens will be denied water so that plant can operate? 2. An underground pipeline must be constructed to discharge 2-3 million gallons of into the Cedar River from the plant. What is the proposed route from the Easton Plant to the plant site and from the plant site to the river? Will more private land be taken by eminent domain? 3. Additional treatment of the water will be required before it is discharged into the now upgrade Cedar River (A-1 vs. B River). According to the applicant, Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 14 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,bun chemicals, various acids, caustics and other additives will be stored on the plant site?Who protects the citizens from an industrial accident should one occur? 4. The US Army Corps of Engineering as well as the DNR will probably be involved in the design for this outfall of water into the Cedar River. What impact will this have on city plans? Waste Methane Gas 1. "In the Development Agreement dated May 7, 2007, the City agreed to offer EREA the rights to the waste gas upon termination of the third-party agreement. In return, EREA committed to exploring the use of the waste gas in the Project as a renewable energy component." (Page 6 of 24) (Emphasis added)What contingency plans exist if EREA does not use the waste gas and the other agreement has been terminated?Does this create another revenue shortfall? 2. What is the proposed route from wastewater treatment plant (WWTP) to the plant site and from the plant site to the river? Will more private land be taken by eminent domain? 3. Will another pipe be installed to route the methane gas to the plant site? 4. Will there be a split distribution system(a Y)to pump some to Tyson's? 5. What other potential ROW issues are involved? Quarry 1. Coal combustion waste (CCW), including fly ash and bottom ash, is not non- hazardous as stated in the application. CCWs contain concentrated levels of heavy metals such as arsenic and mercury, to name only two. These elements are dangerous. 2. Arsenic, according the US EPA, is a highly poisonous semi-metallic element which can cause bladder, lung and skin cancer and may cause kidney and liver cancer. It also harms the central and peripheral nervous systems, as well as heart and blood vessels, and causes serious skin problems. It may also cause birth defects and reproductive problems. These health impacts are caused when arsenic contaminates drinking water supplies. 3. Mercury is a toxic heavy metal that is a byproduct of thermo combustion of fossil fuels, especially coal. Mercury and compounds containing mercury can accumulate in the environment and are highly toxic to humans and animals if inhaled or swallowed, Exposure can permanently damage the brain, kidneys and fetuses according to the US EPA. 4. The better the technology employed by the plant to remove these contaminants from air emissions, the heavier the concentration levels that end up in the combustion waste. 5. Elk Run Energy Associates, LLC proposes dumping the combustion waste from its plant into unlined local quarries, where dangerous contaminants can seep into ground water. 6. Given the amount of standing water in the quarry and the extensive seasonal runoff, it seems that a real potential for future liability exists for the County if the Review of Annexation and Rezoning Application by Elk Rim Energy Associates,LLC March 2008 Page 15 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa ground water becomes contaminated. Residents of Anne Arundel County, Maryland are forced currently to rely on bottled water because of serious ground water contamination that seeped into wells from coal combustion waste hauled from coals plants. See attached report, "Iowa Coal Combustion Waste Disposal." North South Rail Spur Needed 1. A new north-south spur line needs to be built somewhere between Elk Run Road and Raymond Road as presented in the application. 2. Since the proposed new spur line is drawn on the map submitted in the application, isn't it important to identify the county land parcels now that are considered as possible options so as to inform citizens? 3. When the citizen's farm land is identified, will the County exercise eminent domain to condemn the land if the citizen is unwilling to sell to the railroad? 4. Where is the engineering and environmental study as recommended one year ago regarding this rail spur? Transmission Lines and Towers 1. Transmission lines and towers need to be built to connect the sub-station on the plant site to the existing transmission line. Even though the Applicant states that "real estate negotiations for private easements between the plant site and substation site are underway", seventeen (17) farmers have already said that they will not sell an easement across their farm land to the applicant. Is the County prepared to exercise eminent domain and condemn more farm land? Summary The author of the economic study included in the petition wrote in his conclusion that "...(t)he desirability of a project like this to a community is a function of the capacity of the community to accommodate this type of growth and whether the growth in question aligns with community planning goals. Those choices are policy-driven, and this research only provides one small piece (emphasis added) of the information needed to evaluate a project such as this from a community perspective. After extensive review of the documents submitted by the applicant, there seems to be a myriad of critical questions that remain unanswered. The City Council and the County Board of Supervisors must protect citizens from the long-term impacts of this proposed power plant not only from hidden economic costs but health and environmental concerns as well. This project does not align with the Waterloo Comprehensive Plan or the County Comprehensive Plan. Nor does this project fit with any of the businesses that the Greater Cedar Valley Alliance is targeting to bring to Cedar Valley. Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 16 of 20 Prepared by Community Energy Solutions Submitted on A Al 28,2m8 to eity romtei:of Waterloo,iolvS To this day after nearly three years, many of the interrelationships and key dependencies involved in this project remain as critical unknowns. Only when local government makes well-informed decisions with documented and verified facts is responsible fiduciary behavior demonstrated to protect the best interests of its citizens. There is no need to rush a decision that has such long-term dire consequences not only for all Waterloo citizens but for all of the Cedar Valley as well. Passing off the responsibility of long-range municipal planning and orderly city development under the guise that other governmental agencies have jurisdiction for environmental and health consequences appears irresponsible. This City has a responsibility to determine how best to deal with increased truck, with train traffic, with the disposal of coal ash, with mitigation the serious health impacts of particulate matter. We ask you to deny this annexation and rezoning application until you engage in responsible community planning that begins with a cost-benefit analysis and risk management assessment for future liabilities the City may incur. The time is always right to do the right thing. Martin Luther King, Jr. Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 17 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa Attachment A: Time for Coal Train to Pass an Intersection at Various Speeds Average Train: 135 cars Car Length: 54.7 feet Total Train length (in miles) 1.40 I----- Time--- Speed - - ------� of Train entire train each car each car (in (in miles/hr miles/min. minutes) (in minutes) seconds) 3 0.050 27.97 0.207 12.43 3.5 0.058 23.98 0.178 10.66 4 0.067 20.98 0.155 9.32 4.5 0.075 18.65 0.138 8.29 5 0.083 16.78 0.124 7.46 5.5 0.092 15.26 0.113 6.78 6 0.100 13.99 0.104 6.22 6.5 0.108 12.91 0.096 5.74 7 0.117 11.99 0.089 5.33 7.5 0.125 11.19 0.083 4.97 8 0.133 10.49 0.078 4.66 8.5 0.142 9.87 0.073 4.39 9 0.150 9.32 0.069 4.14 9.5 0.158 8.83 0.065 3.93 10 0.167 8.39 0.062 3.73 10.5 0.175 7.99 0.059 3.55 11 0.183 7.63 0.057 3.39 11.5 0.192 7.30 0.054 3.24 12 0.200 6.99 0.052 3.11 12.5 0.208 6.71 0.050 2.98 (1) (2) (3) (4) (5) (1) Speed of train in miles/hour (2) Speed of train in miles/minute (mph divided by 60) (3) Time for entire train to pass a point (in minutes) (total train length divided by miles per minute) (4) Time for one car to pass a point (in minutes) (time in minutes divided by number of cars) (5) Time for one car to pass a point (in seconds) (time in minutes times 60, divided by number of cars) Review of Annexation and Rezoning Application by Elk Rim Energy Associates,LLC March 2008 Page 18 of 20 Prepared by Community Energy Solutions Submitted on Apr l 28,2008 to City Council of Waterloo,Iowa Attachment B: Transportation Impacts during Operational Phase Part 1 Source: For CCBs from Elk Run Energy Application for Rezoning— Transportation Study, Section 4, Table 5, February 2007. Other truck data taken from Elk Run Energy Application for an Air Construction Permit before the Department of Natural Resources, February 2008. PART 1 Deliveries Trucks/Day Truck Capacity Material Onty Material Only (In Tons) (Tons/Year) (Tons/Day) CCBs 33.0 24 203,500 557.5 (Assumes combination of Fly and Bottom Ash) Active Carbon 0.5 10 1,200 3.3 Lime 3.7 25 24,000 65.8 Ammonia 0.5 20 2,450 6.7 Miscellaneous 4.0 TOTAL 41.7 (Number supplied in original estimate was 33 trucks only for CCBs) PART 2 Part 2 Source: Data taken from Elk Run Energy Application for an Air Construction Permit before the Department of Natural Resources, February 2008 Deliveries Trucks/Day Truck Capacity Material Onty Material Onty (In Tons) (Tons/Year) (Tons/Day) CCBs Bottom Ash 4.4 24 38,790 106.3 Fly Ash 38.4 24 336,315 921.0 Biomass 53.0 24* 454,634 1273.0 Active Carbon 0.5 10 1,200 3.3 Lime 3.7 25 24,000 65.8 Ammonia 0.5 20 2,450 6.7 Miscellaneous 4.0 TOTAL 104.1 * Assumes the largest truck size listed in the Transportation Study. These numbers in Part 2 represent an increase of 150% in truck traffic per day over and above the already stressed city, county and state road system. Review of Annexation and Rezoning Application by Elk Rim Energy Associates,LLC March 2008 Page 19 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa Here are other deliveries by truck (turnovers) that appear to be missing from the application to the City but were stated in the DNR application: • 8 turnovers per year of distillate fuel • 14 turnovers per year of diesel fuel for storage tank • 40 turnovers per year of diesel fuel for 1000 gallon horizontal storage tank • 7 turnovers per year of diesel fuel for Emergency Firewater Pump • 12 turnovers per year of unleaded gasoline for horizontal storage tank for a total of 81 trucks additional. Review of Annexation and Rezoning Application by Elk Run Energy Associates,LLC March 2008 Page 20 of 20 Prepared by Community Energy Solutions Submitted on April 28,2008 to City Council of Waterloo,Iowa Biomass Analysis LS Power Statements: LS Power to burn biomass at coal plant(Feb 17,2007)-Project manager Mark Milburn said the company will incorporate the plan into its state permit applications as it seeks approval for the $1.3 billion, 750-megawatt generating facility in northeast Waterloo. "We've been looking at ways we can incorporate greenhouse gas reduction into our plant," Milburn said. "With the addition of biomass fuels we can burn less coal and burn the biomass to supplement a certain percentage of it, and with it, we can get lower emissions and reductions in greenhouse gases." The exact kind and source of the fuels have yet to be determined. "We've identified several sources that work," he said. "What we want to do is further economic analysis," possibly using local suppliers to reduce LS Power's cost and also benefit farmers or other potential local suppliers. Potential fuel sources, Milburn said, include switch grass, cornstalks and waste products from ethanol plants. LS Project Application -The Facility will be designed to burn up to 10%biomass sources such as switch grass, corn stover, and and/or Dried Distillers Grain(DDG). A maximum of 454,634 tons per year of biomass will be transferred at a maximum rate of 200 tons per hour. Biomass Facts: I. Enemy Density Analysis: LS Power indicates usage of 3,965,950 tons of coal and 454,634 tons of biomass per year to provide 10% of the energy from biomass. • Energy density of coal—24 GJ/ton • Energy density of corn stover and most agricultural residues- 9-15 GJ/ton (Depends greatly on moisture content) Using the 24 GJ/ton and 12 GJ/ton energy densities, biomass would provide only 5.4% of the total energy, not the 10%maximum per project plan. Summary: Application is incorrect—Maximum of only 5.4%. H. Economic Analysis: Coal • Powder River Basin coal costs(April 14, 2008) = $14.20 per ton. • Energy cost ($/GJ)= $14.20/24= $0.59/GJ Biomass • December 2007 Iowa State University Ag Extension report—Corn stover feeding value of$59.60 per ton. Dried Distillers Grain valued at$125/ton. • Another 2007 Kansas State University Ag Extension survey of Iowa farmers would not sell corn stover even at $30/ton price because of the soil nutrient value of the stover. • Corn Stover Energy Cost(assuming $60/ton and 12GJ/ton)=$60/12=$5.00/GJ • DDG energy cost=$125/12= $10.42/GJ Summary: Iowa Corn Stover$vs. Powder River Coal$_$5.00/0.59= 8.5:1 DDG$vs. Powder River Coal $=$10.42/0.59= 17.7:1 III. Supply and Demand Analysis: LS Power indicates 454,634 tons of biomass per year from switch grass, corn stover or Dried Distilled Grain. Switch grass is not economically viable for farmers as a crop alternative for corn and soybeans. Most likely produced only limited CRP land. From the economic analysis, DDG is much more costly than coal. Iowa DNR indicates that 21 million tons of corn stover is available per year. In 2007, 14.3M acres of corn was planted in Iowa so the average corn stover yield is approximately 1.5 tons/acre. Using this average yield of 1.5 tons/acre, here's the facts.... 2007 Corn Stover County Corn Acreage (Tons/Year) Black Hawk 140,500 210,750 Buchanan 168,000 252,000 Total 308,500 462,750 LS Project Usage 454,634 Summary: All corn stover in Black Hawk and Buchanan County is needed to meet the project tonnage need. This biomass produces only 5% of total fuel energy. IV. Transportation Analysis Crop residue is very low density. Corn stover is typically baled in large round bales that weigh approximately 1,200 pounds per bale. If they were transported 8 bales per load, it would require nearly 100,000 loads or an average of more than 250 loads per day or 25 trucks per hour for a ten hour per day workday. Since biomass is a seasonal crop, the maximum traffic load is expected to be much higher. Summary: 5% biomass usage presents a major logistics and transportation { challenge. V. Additional LS Proposal Flaws for Biomass • No power plant on-site biomass storage, only a biomass silo with no dimensions. • Evidently LS Power expects on-farm storage of all biomass. Additional costs for the producers for a commodity that already as a significant cost disadvantage to coal. • Biomass is a seasonal crop and facilities need to be designed for much high seasonal volume, not just 200 tons/hour. Summary: Inadequate facility design for biomass storage and handling. fl L--::- A mint I�• � ass is not unrealistic due nt; on t ico ig*: ti i us