Letter: Representative Sally P. Kerans to Kathleen Theoharides, Secretary of Energy and Environmental Affairs

Submitted by Jerry Halberstadt on Thu, 07/29/2021 - 15:31

Representative Sally P. Kerans, 13th Essex District, Danvers, Peabody, Middleton 617-722-2800 ext. 7305 Sally.Kerans@mahouse.gov 

Committees:  Transportation,  Election Laws, Financial Services, Mental Health, Substance Use, &  Recovery,  Advanced IT, Internet, &  Cybersecurity

July 23, 2021

Executive Office of Energy and Environmental Affairs
Kathleen Theoharides, Secretary
100 Cambridge Street, Suite 900
Boston, MA 02114

Dear Secretary Theoharides,

I write out of deep concern and a sense of urgency about the impacts of MMWEC’s
proposed 55MW peak capacity generator in Peabody (Project 2015A) on the people and communities I represent. I am requesting that you employ your authority to ensure that
both a comprehensive health impact assessment and an environmental impact report precede the granting of any permit by the DPU, and to insist that the provisions of the Climate Law, Acts of 2021, Ch. 8 S. 15 are adhered to by the DPU as they evaluate the proposal.

Project 2015A will sit on land in Peabody near the Danvers border within an environmental justice area, hundreds of homes, a school, a dairy farm and a neighborhood that lived through a paint factory explosion in 2012. The two existing generators on the site are close to the Waters River. The proposed peaker plant calls for $85 million in bonding. Peabody ratepayers, through their MLP, have invested at 29%.

The project has been characterized by an utter lack of transparency. MMWEC was badgered
into hosting a meeting for residents and convened one on June 22. MMWEC officials talked for two and half hours before allowing any audience questions. And, despite the location of the proposed project on the Danvers line, not one word was spoken to Danvers residents or officials in the five years it’s been in the works.

At a meeting convened by the Danvers Select Board on July 9, I asked MMWEC, “Can you meet your capacity needs without building this plant?” Somewhat hesitantly, one of the MMWEC representatives said “Probably....”. The fact is, MMWEC can purchase capacity. 

While we appreciate that Municipal Light Plants must be concerned with providing electricity, it is our jobs to ask, “At what cost to health and our environment?”

Members of the Danvers Select Board stated that there should be an independent, comprehensive study of the public health and environmental impact of the proposed plant, and made available in language and presentation to enable Danvers residents to understand and evaluate the proposal.

Questions persist about the plant’s impact on the health of hundreds of Peabody and Danvers residents in those very neighborhoods. Indeed, physicians, including a doctor who has treated several area patients for asthma and COPD, have said 2015A would be harmful for our health.

Peabody Director of Health Sharon Cameron wrote to Governor Baker on July 8: “We have reviewed the MassDEP plan approval, which concludes from its analysis of modeling that pollution emitted by the proposed plant will not exceed National or Massachusetts Ambient Air Quality Standards or the applicable Threshold Exposure Levels. However, we also understand that the plant has the potential to produce an additional 12 tons per year of small particulates; 8.3 tons per year of carbon monoxide; 0.6 tons per year of sulfur dioxide; 1.8 tons per year of ozone; 6.3 tons per year of nitrogen oxides; 0.00025 tons per year of lead; and 50,779 tons per year of carbon dioxide equivalents. The magnitude and risks of these hazards cannot be fully understood without comprehensive health impact assessments and environmental impact reports.” The letter is attached.

A Comprehensive Health Impact Assessment is needed to answer some of these questions.

What we know for certain is that investment in fossil fuel technology is incompatible with the climate law signed in March by Governor Baker (and, no doubt, helped to passage with your efforts).

Among many provisions of the law is a broader examination and definition of cost than what existed in April, when the DPU held its first public testimony. The law states: “...provided, however, that when determining cost-effectiveness, the calculation of program benefits shall include calculations of the social value of greenhouse gas emissions reductions, except in the cases of conversions from fossil fuel heating and cooling to fossil fuel heating and cooling (italics added).”

While in April the DPU hearing opened with a friendly but firm reminder to all who testified that this hearing was only about financing, the new climate law took effect on June 25. The DPU should follow the law and define “cost” as more than cents per kilowatt hour when considering Project 2015A. 

Specifically, I urge you to:

• Require that both an Environmental Impact Report (the site is close to the Waters River) and a Comprehensive Health Impact Assessment, as requested by the City of Peabody Board of Health Director, are done before any permit is granted.
• Re-visit the air permit this project received several years ago.
• Use your authority to ask the DPU to halt its deliberation on this application until it can review the project’s environmental, justice and health impacts, consistent with the new Climate law.

I urge you to intervene in your capacity as Secretary of Energy and Environmental Affairs to ensure that at minimum, both an Environmental Impact Report and a Comprehensive Health Impact Assessment are done. Only then will we be confident that all the costs of Project 2015A are considered.

I thank you for your prompt and serious consideration of this matter.


Sally P. Kerans

State Representative, 13th Essex District
Danvers, Peabody, Middleton

Matthew H. Nelson, Chair, Massachusetts Department of Public Utilities
Martin Suuberg, Commissioner, Massachusetts Department of Environmental Protection Margret Cooke, Acting Commissioner, Massachusetts Department of Public Health Governor Charles D. Baker