November 4, 1995

Mr. Gary Zarker
Seattle City Light
1111 Third Ave.
Seattle WA 98101

Mr. Zarker;
I am writing to you with regard to the recent SWAPCA RACT finding for the Centralia coal fired power plant, located 63 miles southeast of Seattle. I understand that the plant has been authorized by SWAPCA to require no pollution controls until as late as 2002. In the intervening 6 years, plant SO2 emissions, (and thus sulfate particulate levels generated in the atmosphere) are expected to increase continuously. SWAPCA has estimated that by 1999, plant SO2 emissions will be between 83,000 and 94,500 tons/year. At the time pollution control takes effect, the plant would be required to limit its SO2 emissions to 55,000 ton per year. Sulfate particulate has been implicated in several health issues in the Puget Sound area, and has been shown to reduce visibility and acidify lakes in and around Mt. Rainier National Park.

In addition to the particulate problem, other issues, in my opinion, have not been satisfactorily addressed: 1) According to several studies, Centralia plant emissions produce levels of ozone sufficient to result in health effects, as well as reduction in crop yield and damage to certain types of trees. 2) Coal fired power plants have long been the largest industrial source of mercury emissions. Although these plants are exempt from federal mercury controls, It would be nice to know how much mercury the Centralia plant is emitting. 3) Plant operators acknowledge emissions of "hazardous air pollutants".

SWAPCA and plant operators place responsibility for resolution of all health related air quality issues on the federal EPA, which is already bogged down with lawsuits regarding particulate and ozone standards. The EPA is also responsible for testing and setting of standards for 180+ designated "hazardous air pollutants". The EPA's work will almost certainly have to be done in the face of funding and staff reductions. The Clean Air Act itself, which already allows a liberal time frame for implementation of EPA rules, may be weakened. These factors argue for a long time period before all health issues are satisfactorily resolved at the local level by the EPA, if they are resolved at all.

The agreement SWAPCA reached with PacifiCorp, particularly in authorizing as long as 6 more years of continuously increasing uncontrolled emissions, causes me to doubt that they have struck a reasonable balance between public and private interests. The economic needs of Lewis County are best served by continued operation of the Centralia plant. On the other hand, I believe that the interests of the population and environment of Western Washington as a whole would best be served by a plan that reduced allowable emissions to a greater extent and took effect much more rapidly.

I learned that Seattle City light, concerned about possible adverse health and environmental effects, wanted to allow more time for public involvement before the license was granted. I very much appreciate your utility's intended courtesy in this matter.