Roger Caiazza
The Applied Economics Clinic (AEC) report titled ”A Community Assessment of Health Impacts from the Pittsfield Generating Facility on Local Communities”, prepared on behalf of the Massachusetts Clean Peak Coalition has to be in the running for the most egregious example of inflammatory peaker power plant fear-mongering of all time. This post compares the claims against reality.
Environmental non-governmental organizations have latched onto peaking power plants as an example of power company greed and disregard for neighboring communities. For example, the PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.” The influence of this position on current environmental policy has led to this issue finding its way into multiple environmental initiatives. However, I have found that the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. The AEC report takes the claims to ridiculous levels.
The AEC report example is extreme even compared to the Peak coalition accusations. Researcher Jordan Burt, Assistant Researcher Elisabeth Seliga, Researcher Tanya Stasio, PhD, Research Assistant Lila McNamee, and Principal Economist Liz Stanton, PhD, prepared a report that summarizes the negative health impacts of fossil fuel-fired emissions on communities living near the Pittsfield Generating Facility (Figure 1). They claim that the facility exacerbates negative health outcomes of overburdened residents and asserts there are three key takeaways:
- First, as long as the Pittsfield Generating Facility is in operation, it has the potential to produce much higher greenhouse gas emissions and co-pollutants in any given year.
- Second, Pittsfield’s vulnerable populations live in close proximity to the Facility, putting them at a disproportionate risk for the negative health impacts associated with fossil fuel-fired generation.
- Lastly, replacing the Facility with clean energy resources can not only improve the health outcomes for residents, but also aid the Commonwealth in achieving its decarbonization goals.
This article addresses these takeaways.
Figure 1: Pittsfield Generating Station in Relative to Pittsfield, MA
Pittsfield Generating Company
According to the Massachusetts Department of Environmental Protection (DEP) Final Operating Permit Renewal for the facility:
The Pittsfield Generating Company LP is an electric power generation facility located at 235 Merrill Road in Pittsfield, Massachusetts. The facility largely consists of three (3) General Electric (GE) Frame 6 6001B combustion turbines, known as Emission Units (EU) – 1, 2, and 3, which are each equipped with steam injection and a selective catalytic reduction system for control of nitrogen oxides (NOX) emissions. Each combustion turbine has a maximum heat input rate of 430.25 million British thermal units per hour (“MMBtu/hr”) and is exhausted to an associated Deltak heat recovery steam generator (“HRSG”). The steam generated in the three (3) heat recovery steam generators is combined to supply a single (1) GE steam turbine. Emission Units 1, 2, and 3 burn natural gas or #2 fuel oil and operate in combined-cycle mode with a net total output of nominally 165-megawatts.
A common claim about peaking power plants is that they are old, dirty, and inefficient units, but these units are modern, well-controlled, and efficient generating units. Despite their efficiency, in the last seven years the units have only run less than 10% of the time which qualifies them to be peaking units. By definition, for EPA reporting purposes 40 CFR Part 75 §72.2, a combustion unit is a peaking unit if it has an average annual capacity factor of 10.0 percent or less over the past three years and an annual capacity factor of 20.0 percent or less in each of those three years. Note that because peaking plants run so little the units can be designed for that mode of operation. The specifications for those units are primarily focus on costs. The Pittsfield units include all the pollution control equipment associated with units designed to run as much as possible. They became peaking units because of market conditions that priced them out of the market, so they simply run less. Nonetheless, they serve an important reliability role providing dispatchable power when needed on high energy demand days.
Takeaway 1
AEC claims that the facility has the potential to produce much higher greenhouse gas emissions and co-pollutants in the future. Table 1 lists the annual emissions and operating information for the last 25 years from the EPA Clean Air Markets Division website. That potential may exist but the historical data show that there has been vast operating and emission reductions since 2000. As a result, any alleged impacts from the facility should have improved significantly over time.
Table 1: Pittsfield Generating Company Facility Emissions and Operating Parameters
Takeaway 2
In the second takeaway AEC states that Pittsfield’s vulnerable populations live near the Facility, putting them at a disproportionate risk for the negative health impacts associated with fossil fuel-fired generation. They offer no estimates of the potential health impacts.
Last year I published a detailed critique of a General Accounting Office (GAO) report “Information from Peak Demand Power Plants” that discussed air quality impact evaluation. The fundamental air quality presumption has always been that the National Ambient Air Quality Standards (NAAQS) is the primary metric used to determine health impacts. As an air pollution meteorologist one of my jobs was to run air quality models to determine the air quality impacts of existing and proposed facilities. The essential consideration was whether the modeling proved that the projected impacts from a facility were less than the NAAQS limits. Industry and regulatory agencies believed that when an applicant showed compliance with those standards, they proved that they were protecting the health of “sensitive” populations such as asthmatics, children, and the elderly. Regulatory agencies are required to ensure that any facility that cannot show compliance with the NAAQS must modify its permitted operations, or it cannot be allowed to operate. The Massachusetts DEP only issues air permits if they are confident that the facility attains the NAAQS, so I am sure that Pittsfield Generating meets those standards.
The air quality pollutant of concern is nitrogen oxides or NOx. The DEP set an emission limit of 22.8 lb NOx/hr. I calculated the average hourly emission using the total NOx mass and the operating hours as 10.4 lb NOx/hr. This is well below the emission rate that we know attains the NAAQS. It is beyond the scope of this analysis and my presently available computer capabilities to quantify specific NOx impacts. However, I only recall doing impacts assessment of power plants that used tons per hour not pounds per hour for an emission rate. My point is that a pounds per hour rate is extraordinarily small and my experience suggests that local impacts at those levels would be so low that they would be difficult to measure and if they cannot be measured there is little chance of any health impact.
Takeaway 3
AEC asserts that “replacing the Facility with clean energy resources can not only improve the health outcomes for residents but also aid the Commonwealth in achieving its decarbonization goals.” Environmental justice organizations will read this without understanding the background. In context, the impacts of this facility are well within the NAAQS, probably could not be measured, and the carbon emissions are a negligible fraction of the state total (Table 2). In the last five years the CO2 emissions have been less than or equal to 0.5% of the state total.
This table brings up other questions. In New York the coal and oil generation was displaced to natural gas, but the overall Massachusetts generation has dropped significantly while there was a shift away from coal and oil. The Massachusetts CO2 reduction from 2009 to 2023 was 84% while New York only dropped 38%. I do not know why they managed such a substantial decrease.
Table 2: Pittsfield Emissions Relative to Total Massachusetts Emissions and Operating Characteristics
Pragmatic Concerns
Pragmatic environmentalism is all about tradeoffs. There is no question that disadvantaged communities have suffered and continue to suffer disproportionate environmental impacts, but it is important to understand what causes the harm, balance expectations, and determine potential solutions.
In this instance, it is likely that transportation sources have a bigger impact on air quality for Pittsfield’s vulnerable population. There are just under 44,000 residents in the city, there are 19,566 households, and the average number of cars per household is 2. I assume the estimated 39,132 cars drive two thirds of the Massachusetts average 12,117 miles per year within the city and that means that city mile traveled equals 316,108,296 miles per year. The estimated U.S. average vehicle NOx emission rate per automobile in 2023 was 0.00129 lb. per mile. The result is that in 2023 automobiles emitted 204 tons of NOx. That is more than double the annual emissions from the power plant since 2003 and 57 times higher than the 2024 emissions from the power plant. In addition, auto emissions are close to the ground while the power plant emissions are from elevated stacks so the auto emissions have a greater impact. Clearly, the vilification of the emissions from the power plant is unwarranted.
AEC proposes that the plant be replaced with an “alternative, cleaner energy source like a solar plus storage facility can help reduce community exposure to pollution”. The Title V permit says that emission units 1, 2, and 3 have a “net total output of nominally 165-megawatts.” I estimate that 165MW of solar would cover 973 acres. However, to ensure reliable reinforcement of a gas plant requires more than a one for one replacement. Based on this reference, the solar required would be 660 MW covering 3,894 acres. The storage system may need to be oversized as well, potentially requiring 410 MW of 4-hour storage to replace 100 MW of gas peaker capacity. Replacing perfectly good power plant with solar plus storage prematurely does not seem to be a good investment.
AEC claims that the solar plus storage option would reduce exposure to pollution. However, there are substantive safety concerns with currently available battery energy storage systems. On January 16, 2025 a fire was reported at the Vistra Moss Landing Energy Storage Facility located in Moss Landing, California. The fire burned at a temperature of between 2500 – 5000 degrees Fahrenheit. Since the fire heavy metals have been measured at levels 100 to 1,000 times higher than normal in soil within a mile of the facility. During the fire there was an evacuation zone within 1.5 miles of the facility. In my opinion, the risks of environmental impacts from a battery fire far outweigh the “benefits” of eliminating the minimal emissions of this facility.
Moreover, there is no currently available technology that has been proven at the scale necessary that can replace fossil-fired generation safely, reliably, and affordably. If those characterized are not prioritized, then it could easily result in an electric system that does not maintain current standards. More importantly, problems associated with reliability impact disadvantaged communities most so those concerns must be considered when decisions are made about peaking power plants benefits and potential impacts.
Conclusion
This analysis epitomizes my frustration with pragmatic tradeoffs for peaking power plants. AEC claims that the facility has the potential to produce much higher greenhouse gas emissions and co-pollutants in the future ignoring the fact that emissions have gone down significantly since the plant started operating. AEC also claims that Pittsfield’s vulnerable populations live near the Facility, putting them at a disproportionate risk for the negative health impacts associated with fossil fuel-fired generation. AEC overlooks the fact that facility emissions are so small that adverse health impacts are unlikely from the plant and that transportation emissions are much higher which means adverse air quality impacts are more likely from other sources. AEC’s final takeaway claim is that “replacing the Facility with clean energy resources can not only improve the health outcomes for residents but also aid the Commonwealth in achieving its decarbonization goals.” That is true in theory, but it ignores the fact that there are other emission reduction strategies that are likely to be more effective and pose less risk to the electric system than shutting down a dispatchable generating resource. Fear mongering based on emotion and not facts is not in the best interests of a reliable electric system and this report is the best example of this folly I have seen to date.
Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.
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I just read about the answer – it comes from Saul Griffith – “ELECTRIFY” America, that’s all. He and his followers are on a mission to stamp out that evil CO2 and save the environment. Remember, “ELECTRIFY”, and everything is solved.
People who are against fossil peaking plants are really against 24/7 electricity since there are no practical substitutes. Unless one includes the health and social problems created by blackouts the arguments have zero merit.
The biggest problem of eliminating “Peaking” Generators is the loss of electricity needed to run your Refrigerator and/or Freezer. Since the local utility shut down their NPP I have had, on average, two outages a year where the Refrigerator and/or Freezer did not keep the frozen food FROZEN. Additionally I had to replace two freezers because the power was “Switched” rather than “synchronized.” This caused a “lockup” of the motor which required the motor or the Starting Capacitor to be replaced.
Total cost to people in the area the size of the above map would be near or over $One Million. Thus, Applied Economics Clinic (AEC) is not providing the customers an ECONOMIC solution.
First, with an SCR for each gas turbine, the facility is well equipped to control NOx. Many of the older peaking units mentioned as “dirty” are grandfathered in and do not have SCRs.
Second, an excellent point about NAAQS. That standard is based on the cumulative health effects in the area. They have to comply with those standards or they could not operate.
Third, the General Dynamics facility abutting the CT site has over 400 cars in its parking lot with room for many more. With that, plus the 4 lane roads going through the area, there can be significant amounts of pollution from these sources. But those are being ignored by the AEC.
AEC does not truly care about the “vulnerable populations,” they are just using them as a cudgel to batter a source of reliable energy they are opposed to,
From the article: “They became peaking units because of market conditions that priced them out of the market, so they simply run less.”
The “market conditions” are foisted on the peaking units by politicians, and the “market conditions” have no relationship to the real market conditions. Politicians have created a monopoly of windmills and solar in our electrical grids. The windmills and solar get the preference, and they make perfectly suitable conventional power plants sit idle until the time comes when the wind doesn’t blow and the sun doesn’t shine. And all of this raises the cost of electricity.
If you want to know why your electric bills keep climbing higher it’s because these fools keep adding more windmills and solar to the grids and to do so they create a pricing structure that favors windmills and solar and penalizes conventional generation, which raises costs. If they didn’t favor windmills and solar with special pricing, the windmills and solar would go out of business. They are not economically viable on their own, and if we insist on using them, then our society will not be economically viable in the future.
No more subsidies or special pricing for windmills and solar!
I used to live in that area of Pittsfield. The real health threats in that area are not due to the power plant but due to massive amounts of PCBs in the ground due to the General Electric factory that used to be there producing transformers. There has been an epidemic of bladder cancer in the area attributed to those PCBs. Another health threat is the increasing crime due to poverty. The city used to be rather wealthy- it’s population has dropped about a third in the past half century. General Electric used to have something like 12,000 employees in its Pittsfield facilities. That company is now long gone. The city is decrepit.
A 10% capacity factor. All that money invested for 10% utility, but the ratepayers have to provide the return on investment that keeps 100% of the madness afloat. Wind plants run at an annual average of 30% capacity factors, but really, when it counts, they have an effective load carrying capacity of 10%. Something else, also with a 10% capacity factor, will pick up their slack. Solar has a 20-25% capacity factor, but has to be curtailed when it produces too much. As more gets built capacity factor declines more. Transmission lines overbuilt for the off-chance that wind and solar don’t produce much at all, and we need to haul power from distant places, won’t have anywhere near 100% utility either.
Eventually we will have an electrical energy network the only parts of which run near 100% utilization will be local distribution. Forget about no fuel costs. Capital costs sunk into parts of the system that almost never supply value will make electricity very costly.
It would be cheaper not to build any more wind and solar plants and let a modern CCGT plant run more than 10% of the time.
Agreed. And compliment them with modern quick-start Peakers that can go from cold steel to full load in about 15 minutes.
Why does no on, yet, point out that this cheap and now clean generation with chimney scrubbers can run much cheaper than renewables at 24/7 without any renewables. THey comome expensive because if the renewables are allowed to force them off the grid to harvest their subdies for the less than half the time they work on average. The cheap coal fired power that used to work 24/7 to meet demand on demand becomes expensive because it is base load power forced to operate on a low duty cycle by stupid laws that make everything more expensive. The problem is entirely caused by the moronic and/or corrupt politicians who force expensive unreliables on to the grid for a fast renewable huckster buck by law that can only make everything worse and more expensive. Who knew? They did.
Carbon capture by scrubbing is not cheap and not yet proven, IMHO, at utility scale. Some utilities now have priced CC into their Integrated Resource Plans, and the Cost will be an order of magnitude bigger than the sulfur dioxide scrubbing technology that was implemented very successfully starting in the 1990s.
How dare you!
How dare you keep my lights on and keep my fridge operating and my laptop in power when the wind stops blowing
How dare you!
You could put a few large lithium battery farms in instead..
That’d solve the CO2 air pollution problem.
/sarc !
Point #1: A few minutes of “touring” around the city using Google Street View confirms Joseph Zorzin’s view {@8:13 am} that Pittsfield is decrepit.
Point #2: The owner is Hull Street Energy, a private equity firm that has the purpose to deploy capital into the North American power sector as it transitions to a more sustainable footprint.
Translation: we will make all the money we can out of this while the politicians, agencies, and NGOs dither (a state of indecisive agitation). The Trump Administration’s challenge to climate nonsense may impact this company, and this particular plant, eventually. Meanwhile, the plant is simply being used in a manner similar to using an old pickup truck until it falls apart.
In my opinion Point #2 is spot on. Th private equity firms that own this type of facility wlll them to maximize profits and if there is a problem will just shut down.
Maybe Massachusetts can just replace these gas fired peaker plants with some of those New York Emissions Free Dispatchable Resources. I understand that New York has ordered these to be invented so they should be in mass production any day now.
NY expects that the magical resource will also be cheaper
Excellent and timely article a perfect example of why natural gas peaking plants need to not only be maintained but increasing used because solar ix not cost effective and battery storage, based on Moss Landing, is not safe. The new DOE Administration should use the Pittsfield generating “complaint” to good advantage.
Very nice Roger. I have a problem with this sentence.
“They became peaking units because of market conditions that priced them out of the market, so they simply run less.”
What market conditions priced them out of the market? What generating process is cheaper than natural gas? If they weren’t replaced with cheaper generators then I don’t see how it could be market conditions. This has the stink of government mandates, subsidies, tax preferences and environmental forgiveness. It really smells. I am fed up with the lying and cheating.
Bob,
You answered your own question: government mandates [Renewable Portfolio Standards] decree that all output from wind & solar must be used first and fossil fuel produced electricity is last in line. Thus, peaker plants are needed to do “load following” to make-up on a minute-to-minute basis the intermittancy of wind & solar. A very inefficient [ie, costly] way to run a NG plant.
The “market conditions” Roger mentioned are really a “crony capitalism” market .
Other “crony” schemes include Net Metering & Feed-in Tariffs.
I asked about this with a couple of people who follow the New England electric system.
Meredith Angwin offered two possible explanations.
1) devastating drop in demand (people leaving taxachusetts)? Or lots of rooftop solar?
2) surge in imports ?
Warren Van Wyck responded to her suggestions.
From 2009 to 2023 MA went from 72% in-state Utility generation to 39% Yes, much more imports. The load decreased about 8%.
Yes, roof top solar in 2023 was 19% of Generation.
MA eliminated Coal generation (was 23% in 2009) and greatly reduced Oil (2% to 0.5%) That might also explain CO2 reduction variance.
When natural gas pipelines become constrained during cold winter weather, the market demands oil-fired =power because it is cheaper than the NG. The grid operators call for all of the oil-fired power plants that hardly every run to maximum output. Also, some combined cycle plants can run on oil also and join the party.
Health outcomes predictions from air quality assessment are complete nonsense. I grew up in the shadow of Cleveland’s steel mills and me and all my friends were 100 times more healthy than the children today that are locked inside homes with their neurotic single-parent moms glued to a screen.
That is a very good point and i agree. I am stlll waiting to see an analysis that verfies all the alleged health benefits claimed relative to observed benefits from the air quallity improvements over the last 20 years.
Twenty one years in Akron, OH [with five rubber plants that turned a white care black overnight as I grew up] and I am now 83 years old and live in NE. My doctor tells me every time I get my annual physical “I wish I was as healthy as you.” I have heard similar from all five of my siblings.
Not to mention lead. I was age 10 in 1960 and managed to make it this far in good health notwithstanding the average 10 year old in 1960 had 60 micrograms of lead per deciliter. Today’s kids? 3.5 micrograms.
Did you get to play with elemental (metallic) Mercury in a school science class?
I suggest the peaking plants all stay turned off for a week or two. Lets see how New York manages with that.
The same arguments are used in the bogus push to get rid of gas stoves. Most of the concerns with indoor air pollution are alarmist, but if people are so concerned about it let them mitigate it themselves, at their own expense.
There is a significant issue with Battery Energy Storage Systems that has been largely overlooked. They are prone to fires which are very difficult to fight, and spew toxic chemicals for days at a time. Do a search for Moss Landing battery fire. Moss landing is a gas fired power plant in California retired and converted to a BESS. A recent fire most likely has created a super fund site. With natural gas peaking units, expensive and hazardous BESS facilities are not needed.
It is incredible that the same people that want to kill low emitting clean natural gas will turn the blind eye to a real environmental problem.
And of course, the new inflation reduction act promulgated under the Biden administration now is providing subsidies for BESS facilities.
The blog pointed out how small the NOX emissions are from the gas fired units compared to the transportation sector. The carbon emissions from the peaking plants are very small, on par with the CO2 that the human population of Pittsfield produces, for example. Nationally, natural gas has enabled coal facilities to be retired and is the main driver of the reduction of CO2 emissions in the US electric sector over the last 20 years.