Doctorate of Engineering Science, New York University


I wish to state that the air pollution emanating from the proposed plant as specified in the Environmental Impact Report (EIR) prepared by an independent engineering company evaluating this proposal demands that this project NOT be built in Banning.

The Environmental Impact Report states that the operators of this plant intend that one and 1/3 billion Ib. of waste sewage sludge will be brought through the streets of Banning per year from all over California. Sewage sludge is essentiality semidried and treated sewage. Additionally 1/2 billion Ib of biomass, per year will need be transported through Banning, again, from all over California. Is there any question that Banning might become known as the “Sewage Dump Capital Of California”? The City Council is discussing the means of enticing freeway traffic in the future to stop at outdoor cafe’s in downtown Banning. Does anyone think that visitors will stop in the “SEWAGE DUMP OF CALIFORNIA”?

The Environmental Impact Report states that the sewage will be stored in 16 sludge containing silos 60 feet high and 30 feet in diameter. If a visitor is considering purchasing a home here, or opening a new business and asks the obvious question “what are those towers at the east end of town”? and receives the answer “Oh, that’s where the sewage from California is stored”, do you think the sale will be completed ?

Mr. Hawkins of Liberty Energy himself in the Press Enterprise of August 27 was quoted as saying that “industrial properties cause a fall the first year of property values in the surrroundings of 5 to 6%, and they level off after 5 years”. That is their statement for the fall in value for property around a normal industrial plant. No one can predict what the property values near a sewage burning plant of this magnitude would be. With all the properties available in California, would you buy in the city with this plant and likely resultant reputation?

The Environmental Impact Report states that the air in Banning currently does NOT meet the AQMD standards. The monitoring station at the Banning airport has reported approximately 90 days per year in which the ozone levels currently exceed the AQMD standards and the particulate matter currently exceeds the AQMD standards between 6 and 18 days per year for the last three years for which data is available. The additional air pollution produced by the proposed plant will be added to our already unsatisfactory air. I have heard repeatedly the incorrect statement that this plant is sealed and does not emit any pollution or odors. We know that is completely incorrect. Quoting the statement from the Environmental Impact Report:
“Flue gases leaving the bubbling fluidized combustion units would be cooled and directed through dry or wet scrubbers and baghouses prior to release to the atmosphere. Emissions would be released through the cooling tower”. These flue gases contain all the pollutants listed in the EIR which are emitted to our air.

Criteria pollutants are those that the AQMD has set upper acceptable limits. The Environmental Impact Report lists the output of this proposed plant for the criteria pollutants: carbon monoxide, nitrous oxides, sulfur oxides, volatile organic vapors and solid particles. The sum total of these pollutants emitted from this plant is 462,000 Ib per year. Again, these air pollutants would be added to the already unsatisfactory air in our region.

To emphasize the impropriety of such additional pollution, this amount of pollution addition is so great that this plant could not be built without the AQMD requiring Liberty to purchase Emission Reduction Credits from some other company in a different area. What this means is that other cities that have reduced their pollution will be paid so that Banning can increase its air pollution.

This is an absurd action for our city to consider. Cities throughout California are attempting all means to reduce their air pollution. The meager pollution produced by cigarette smoke from outdoor restaurant areas, and the pollution from lawn mowers are being considered to be banned by other cities. For Banning to accept this giant increase in its air pollution goes against every known concept of improving the quality and image of our city. Our city should be planning to be one which can sell emission reduction credits to other cities, rather than be the polluter requiring special dispensation to increase our pollution.

Besides these pollutants whose maximum permissible concentrations have been set by the AQMD, other pollutants will be generated by this plant, and other dangerous chemicals will need to be transported into Banning to permit this plant to operate. One of the most serious dangerous chemicals is concentrated pure ammonia, which requires special and careful handling. This plant requires 3,942,000 Ib of liquid ammonia be brought through Banning into the plant every year. If each truck carries 30,000 Ib of ammonia, that is three to four trucks per week of this dangerous chemical through our streets. Even if none is lost in transfer, and no accident occurs, the Environmental Impact report states that 29,400 Ib per year will be part of the pollution emitted by the plant to our atmosphere. Many other pollutants are generated by this plant. I will only list those that I believe everyone is familiar with: 118,000 Ib per year of hydrochloric acid will be emitted, 321 Ib of chlorine will be emitted, 36 Ib mercury will be emitted. The report lists a total of 53 such non-criteria pollutants that will be released into our atmosphere when this plant is in operation.

The Southern California Air Quality Management District (SCQAMD) has given a courtesy preliminary evaluation of that EIR on July 24. Their review idicates that the pollution problems recognized in the EIR must be increased, and also that odors will be a significant and ongoing problem for Banning if this plant is built. The SCAQMD review of the Environmental Impact Report states the following
” Dust during construction was greatly understated. The number of employee trips, sewage sludge and biomass trips and biomass processing, and the resulting pollution from these trips was understated.”

The following statements indicate that odors will be a problem.
” There is insufficient information to determine whether…odor venting and combustion system…is adequate to control odors..or whether or not that receiving systems would adequately control biosolid odors.”

Another quote: ” SCAQMD recommends… a proposal for handling odor complaints. This could include.. Odor surveys, keep a log of characteristics of any odors…identify source of odor”
clearly, this indicates that SCAQMD recognizes that odors will be generated by this plant and that complaints will be received. The suggestion that these complaints be logged clearly indicates that such complaints are expected to occur at regular intervals. Providing a protocol or procedure for handling such complaints does not stop them from happening repeatedly. Can anyone conceive of what the property values and life in Banning would be like when sewage odors are evidenced in our city?

The review by SCAQMD states that the area around the proposed plant be rezoned to preclude residential development in a buffer zone 1000 feet wide at all points due to air quality considerations. This Liberty plant would occupy 20.3 acres. The buffer zone required due to its pollution generation is an area of 165 acres. This plant makes that area uninhabitable! What type of industry is likely to be willing to occupy this buffer zone? If any could be found, they would likely be polluters themselves, requiring additional buffer zones.

This plant is inappropriate for Banning, and all the information required to reach that decision is in the Environmental Impact Report.

Edward Miller holds a doctorate in Engineering Science from New York University. He has more than 30 years experience in researching, consulting and teaching various aspects of the field of thermodynamics including power plant design, emission analysis and alternate energy sources. He has published more than 50 technical articles.

Dr. Edward Miller can be contacted at :

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