Coal Myths and Environmental Realities: Industrial Fuel-Use Decisions in a Time of Change by Alvin L Alm

Author:Alvin L Alm [Alm, Alvin L]
Language: eng
Format: epub
Tags: Political Science, General
ISBN: 9780429705717
Google: YCyNDwAAQBAJ
Goodreads: 44598150
Publisher: Routledge
Published: 2019-03-01T00:00:00+00:00

Effects of Delays

The time required to obtain environmental permits affects firms differently. The lead time for constructing and installing a large utility boiler from initial concept to startup is generally six to eight years, even without any additional time for environmental permitting. The lead time for smaller package boilers and fuel-use projects, on the other hand, may be reasonably short—one to two years. When environmental permitting is integrated into the planning process, firms may experience no actual delays. On the other hand, when a firm lacks experience with the complexity of permitting and does not build in sufficient lead time during the planning process, substantial delays may result. Even experienced and sophisticated firms may encounter unusual problems or bureaucratic delays in obtaining some permits, which lengthen the permitting process beyond normal planning timetables and cause construction delays. Firms desiring to convert small boilers may experience delays in bringing them on-line, simply because the length of time required to obtain environmental permits approaches that of installing a pre-packed boiler.

Many companies reported minimal problems with project delays due to air quality permitting problems. General Motors, for example, had applied for approximately twenty PSD permits over the course of three years and had experienced no great difficulties in obtaining permits. Most of GM's applications had been acted upon within three to four months, with an occasional permit requiring six months. On the other hand, a very small paper firm received timely review of its permit only by daily attention to the permit's progress through the review process. Even where companies have experienced some problems with delays due to air quality permits, as General Shale did in its Chattanooga plant, the overall sense is that coal conversions and expansions using coal need not be subject to significant delays due to permitting problems.

Some firms feared time delays even though they had not experienced any. American Cyanamid had considered applying for a Department of Energy (DOE) prohibition order under the Fuel Use Act to facilitate conversion of plants in New York State, but was dissuaded from doing so because of the unfavorable experience a local utility was having in gaining its permits.

The gap between quantitative data on delays and industry perception is large. The National Commission on Air Quality concluded that 75 percent of PSD permits were issued between three-and-one-half and ten months, and only 25 percent took between ten and sixteen months.8 These data however did not include time estimates for monitoring requirements, which can take up to a year, nor requests for additional information before a permit can be officially received. A number of the firms interviewed felt that permits could and would take two to three years to be issued, when all of these steps were included.

Project delays caused by the permitting process have two major effects. The first and most obvious is to increase the cost of the project if the permit is on the critical path. For many firms, the second effectthe loss of their competitive edge--is a more serious problem.

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