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Comments (19)
17. 1) Natural gas should be replaced by non-burn technologies, not by any solid fuel “biomass” combustion or biofuels.
Numerous references are made to replacing natural gas in the central utility plant with a “decarbonized fuel” or “zero carbon renewable fuel source.” There is no such thing. Any fuel that can be economically combusted on this scale will have carbon emissions. Rare exceptions, like hydrogen, are still produced in processes that use fossil fuels (namely natural gas, in the case of hydrogen). The same is true of the future possibility of “electrofuels” mentioned on page 40, which require electricity and hydrogen inputs to produce the fuel (which itself contains carbon).
Any form of biomass or biofuels used will increase carbon emissions, working in conflict with the project’s aim to reduce global warming emissions. Biomass is not carbon neutral, as several studies in recent years have exposed – most notably the 2010 study commissioned by the Commonwealth of Massachusetts. Massachusetts hired the Manomet Center for Conservation Sciences to study whether biomass is actually “carbon neutral” and found that it is not, and that biomass is worse than coal for global warming over 40 years and worse than natural gas over 90 years. The state then adopted the nation’s strongest regulations limiting biomass eligibility in their renewable energy law, effectively forbidding biomass electric power plants. Links to the Manomet study and others on biomass and global warming, can be found in the right sidebar on http://www.energyjustice.net/biomass
Per unit of energy produced, biomass is more polluting than coal by many other measures in addition to greenhouse gas pollution. Burning biomass emits particulate matter (PM), nitrogen oxides (NOx), sulfur oxides (SOx), carbon monoxide (CO), toxic heavy metals (such as arsenic, mercury, lead, cadmium and chromium), acid gases, dioxins and furans, volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), and other hazardous air pollutants (HAPs). With the exceptions of SOx and mercury, all of these other pollutants are generally released at emission rates worse than coal. Much documentation on this is available through http://www.pfpi.net and more available upon request.
Page 41 lists Seattle Steam’s burning of biomass as a best practice and page 84 mentions the Saint Paul, Minnesota District Energy plant as one that reduces greenhouse gas emissions. The greenhouse gas reduction claim is demonstrably false and these examples ought to be removed altogether, and replaced with appropriate examples of technologies that do not spew toxic pollution and greenhouse gases at rates dirtier than coal power plants. Seattle Steam is burning wood waste, which includes construction and demolition wood waste – a particularly contaminated waste stream known to emit significant levels of arsenic, lead, chromium and dioxins, in addition to the full spectrum of pollutants that normally come with wood burning. Located in a residential area, this has been a serious new health risk for those who live near the Pike Place Market in Seattle, causing local residents to organize against this supposed “best practice.” See: http://www.marketair.org/?p=266
The best practice examples should be replaced with non-burn heating solutions, such as solar thermal technologies, ground source heat pumps (geothermal) or air-source heat pumps, provided that the heat pumps operate on wind or solar power electricity. A good local example of solar hot water is the Tiber Island complex at 430 M St SW in DC. The north tower of the complex has one of the city’s largest solar hot water installations, replacing much of the natural gas heating needs of the 4-tower complex. This project was done by Skyline Innovations, which has many other examples profiled on their website that are worthy of mention as best practices: http://www.skylineinnovations.com/our-projects/
2) The goal of reducing waste to landfill by 80% must include diversion from incineration as well.
On page 42, the plan states the assumption that “60 to 70 percent of the area’s overall waste is sent to the landfill.” This assumption should be checked, since in recent years, most of DC’s waste has been sent to be burned in the incinerator in Lorton, VA (and then to a landfill as the toxic ash must be disposed of).
Incineration involves turning trash into toxic ash and toxic air emissions. About 30% of the weight of the trash becomes concentrated toxic ash that is then landfilled, causing more damage to groundwater over time, as the ash is more toxic and more leachable than the larger volume of unburned trash. The other 70% of the weight of the trash becomes toxic air emissions that are essentially “sky filled,” polluting our air.
Since incineration necessitates generation of ash that goes to landfills, incineration cannot and should not be considered a diversion from landfills.
Materials management plans that aim to maximize source reduction, reuse, recycling and composting are called zero waste plans. San Francisco’s success at diverting 77% of their waste from landfills and incinerators is due to an ambitious zero waste plan the city has adopted.
The official definition of zero waste is one that avoids both landfilling AND incineration of waste. The term was adopted and defined by the Zero Waste International Alliance, and is defined as follows (emphasis added):
"Zero Waste is a goal that is ethical, economical, efficient and visionary, to guide people in changing their lifestyles and practices to emulate sustainable natural cycles, where all discarded materials are designed to become resources for others to use.
Zero Waste means designing and managing products and processes to systematically avoid and eliminate the volume and toxicity of waste and materials, conserve and recover all resources, and NOT BURN OR BURY THEM.
Implementing Zero Waste will eliminate all discharges to land, water or air that are a threat to planetary, human, animal or plant health."
Page 38 of the plan states that “burning coal is a significant contributor to global warming and releases toxic pollution into the air and water.” The same reasons apply to trash incineration. According to the latest EPA eGRID data, trash incineration produces 2.6 times more CO2 per unit of energy produced than burning bituminous coal. Even if you pretend that the “biogenic” fraction does not count (that it’s instantly sucked back up by trees specifically planted to replace the organic products destroyed in the burner), trash incineration is 60% worse than bituminous coal, according to the same EPA data.
Even with more air pollution control equipment in place, trash incinerators emit more pollution than (largely uncontrolled) coal power plants per unit of energy produced. Trash incinerators emit 3-6 times more mercury as coal plants do to produce the same amount of energy, nearly six times more lead, 4.4 times more nitrogen oxides (NOx), twice the carbon monoxide (CO), 4.5 times more sulfur dioxide (SO2) and about 25 times more dioxins (one of the most groups of chemicals known to science).
The plan’s stated concerns about coal’s contribution to global warming and toxic air and water pollution urges that the plan also reject incineration as a waste disposal or energy generation method.
In rejecting trash incineration, the plan must also recognize that incineration is rarely called that anymore, as the technology has earned a very dirty reputation over the last few decades. Various “waste-to-energy” (incineration) schemes now operate with nicer-sounding names, and some variants on the traditional boiler technologies insist that they are not incineration, yet are regulated as incinerators. Gasification, pyrolysis and plasma arc are technologies that are defined in federal regulation as types of incinerators (see 56 FR 5488 and 40 CFR 60.51a or find the definitions spelled out at the bottom of the http://www.energyjustice.net/incineration webpage.
There are numerous zero waste plans that have been developed by forward-thinking cities in the U.S. Here are links to some of their plans, which should serve as a model for this project:
In December 2011, Austin, Texas adopted an excellent Zero Waste master plan to put them on the same path that cities like San Francisco have been pursuing. San Francisco is already at 77% diversion of waste from landfills and incinerators. In 2010, Austin was at 38% diversion.
The Austin Zero Waste plan aims for:
50% in 2015
75% in 2020
85% in 2025
90% in 2030
95%+ in 2040
Austin, TX Zero Waste master plan (competing with $20/ton landfill tip fees!):
http://austintexas.gov/news/austin-city-council-approves-30-year-plan-reach-zero-waste (press release)
http://austintexas.gov/sites/default/files/files/Trash_and_Recycling/MasterPlan_Final_12.30.pdf (the 321 page plan itself - 37 MB PDF)
http://energyjustice.net/files/waste/austinzerowasteplansummary.pdf (25 page summary - 28 MB PDF)
San Francisco Zero Waste plan
http://sfenvironment.org/zero-waste
Alameda County, CA:
http://stopwaste.org
http://stopwaste.org/home/index.asp?page=518 (Policy Tools & Model Ordinances for Local Governments)
Oakland, CA zero waste plan:
http://www.zerowasteoakland.com
Other major resources on zero waste:
http://www.zwia.org - Zero Waste International Alliance
http://www.grrn.org/zerowaste/ - Grassroots Recycling Network
http://www.ilsr.org/initiatives/waste-to-wealth/ - Institute for Local Self-Reliance (this group is great at helping put together alternative economic plans based on recycling and composting)
3) Green Building
The following five points should be integrated into the plan, relating to green building, waste and water use.
Polyvinyl chloride (PVC) plastic (a.k.a. vinyl) should be prohibited in any new construction or building retrofits. Primarily due to its high chlorine content, PVC is highly toxic in its manufacture and disposal, and if buildings ever catch on fire. This toxic plastic is often used in building materials, particularly piping, coating of electrical wiring and in siding. There are alternatives to most PVC uses and they should be required where available. See http://www.ejnet.org/plastics/pvc/ for links to resources on PVC and the alternatives.
Deconstruction methods should be used in place of demolition and in remodeling. In order to minimize waste and maximize recycling and local job creation, deconstruction methods should be used to carefully dismantle and reuse materials in buildings being torn down or remodeled. Also, due to the toxicity of concrete dust, special care must be required of any concrete cutting and demolition, so that all concrete dust is fully contained and not released to the air. See http://www.ilsr.org/initiatives/deconstruction-waste-to-wealth/ for resources on deconstruction.
Waterless urinals should be used to help reduce water use. Water-free urinals are available and should be mandatory where urinals are replaced or installed. Some vendors include www.zeroflush.com, www.falconwaterfree.com and www.waterless.com.
No LEED points should be sought for using cement mixed with coal power plant fly ash. The LEED green building standard assigns recycling points for using cement mixed with the highly toxic fly ash from coal power plants. Cement mixed with this toxic waste byproduct of coal power plants should not be used, both to avoid subsidizing coal power plants, but most importantly to protect the health of the construction workers, all who will ever come in contact with the cement structure, and the community once the concrete is eventually destroyed. See http://www.peer.org/news/news_id.php?row_id=1447 for materials on the hazards of fly ash in cement.
Use of cement manufactured by burning tires, hazardous waste, sewage sludge, plastics, municipal solid waste, refuse-derived fuel or other wastes should be prohibited. Cement manufacturing is pollution enough as is, but the trend toward burning these dangerous waste streams is particularly dangerous to the communities that host cement kilns. Some information on this is available through: http://energyjustice.net/cementkilns and http://earthjustice.org/features/campaigns/cement-plant-background-resources
A concerned resident of SW DC,
Mike Ewall, Esq.
Founder & Director
Energy Justice Network
mike@energyjustice.net
http://www.energyjustice.net
Submitted by Mike Ewall, Esq. on September 10, 2012 at 11:27 pm | Reply to this comment
18. Apologies for these comments not being thoroughly footnoted, as I only learned of this plan very recently. Further info, including references for any claims I made, are available upon request.
Submitted by Mike Ewall, Esq. on September 10, 2012 at 11:30 pm | Reply to this comment
15. rnThe National Capital Planning Commission's draft plan for the Southwest Ecodistrict represents an impressive step forward and lays a solid foundation for concrete action in this vital section of our city. We are particularly excited by the well-integrated energy vision presented in the plan, with a district-wide approach centered on a new microgrid. We would like to reinforce this approach with comments in the following three areas.rnrn1) Central Utility PlantrnrnTo that end, we strongly support the Plan's goals to invest in the existing central utility plant for heating and cooling, to modernize the plant’s equipment, and to increase efficiency by adding new residential and commercial uses throughout the study area. We also support the intention to expand and upgrade existing equipment in order to support new users. In particular, adding residential and hotel users to the central utility plant would help balance thermal and electric loads, and level the output between daytime and evening or weekend usage.rnrnPreserving the Cotton Annex site may be essential to expanding GSA's current HOTD facilities in order to serve the larger SW Ecodistrict. Expanded capacity would be needed to serve both Federal and private facilities, to reach the new construction contemplated in the plan, and to move beyond heating and cooling services to providing electricity service as well. Any plans for that parcel should incorporate the option of incorporating substantial energy infrastructure, including thermal and electric generation, grid integration, storage, and distribution.rnrnWe also support the long-term goal to transition the central utility plant toward a less carbonized energy source when the technologies become available. Not only does natural gas offer significant reductions compared to coal, but the higher efficiency and more intensive utilization of CHP provides an even larger reduction in carbon and other emissions. Even if pipeline natural gas is the only source of fuel, the efficiencies and carbon reductions of the district energy approach make it entirely worthwhile on environmental grounds alone.rnrnMoving beyond fossil fuels requires fuels that are not simply an energy carrier, such as anhydrous ammonia (as opposed to an energy source). We believe that biomass and energy-from-waste will provide an increasing percentage of the methane utilized for electricity production. One cost-effective approach may be to utilize existing pipeline distribution and electricity generators that are already optimized for methane (a.k.a. natural gas). This approach would be similar to relying on Renewable Energy Credits (RECs) and Renewable Portfolio Standards (RPS) to procure low-carbon electricity, even when it is produced at a site that is remote from the point of use. In addition, on-site waste-collection can support medium-term low-carbon energy production through gasification and other zero-emission technologies.rnrnCurrent limitations on GSA's ability to act within a public-private partnership should be overcome. While privatization is at one end of the spectrum, statutory and/or regulatory changes would enable a balanced approach to serving core government interests while still achieving the flexibility and market-based incentives of a business. An energy-specific version of a Business Improvement District – an Energy Improvement District or EID – may provide one appropriate model. Membership would be shared among Federal, non-profit, commercial, and residential properties within the Ecodistrict. Bylaws could be instituted to protect key Federal priorities, including an appropriate role for GSA given its effective management of the HOTD over the years. An EID would also play a key role in sourcing 3rd-party capital for energy infrastructure, in conjunction with other approaches such as Tax Increment Financing. It may be essential from a commercial perspective that users participating in the energy district would only have to pay for the energy they consume, rather than paying all capital costs upfront.rnrn2) Energy StoragernrnThermal storage presents an important opportunity to level both thermal and electric loads and to increase the role of zero- or low-carbon energy sources. With various areas that are planned to be decked over, large-scale storage tanks should be a priority for using those newly-available volumes. Storing hot water overnight would limit the need for dedicated gas or electric hot water boilers in the residential sector during morning peak usage. During cooler weather, storing solar thermal hot water into the evening and overnight would limit peak heating requirements. Chilled-water or ice storage would be even more important, enabling cogeneration to operate overnight with full thermal utilization (i.e. maximum efficiency) during warmer weather, and limiting the peak electricity that would need to be imported from the transmission grid (which is likely to be much “dirtier” power). rnrnThese thermal strategies will make the Ecodistrict function as a more unified microgrid, and increase the reward of shared energy infrastructure and district-wide distribution systems. Even if bus parking and other uses limit the use of sub-decking space, architecturally attractive approaches can integrate thermal storage into other public space – such equipment need not be limited to “back of the house” locations.rnrnElectricity storage is a far less mature technology, but some 'future-proofing' may be warranted. For example, any parking facilities should incorporate the infrastructure (mainly conduits) for installing electric vehicle charging station, and extra space that can be converted when needed to switches, transformers, and other equipment designed to access the EVs as battery-storage for the microgrid.rnrn3) Microgrid-ready and District Energy-ready buildingsrnrnAs part of the Ecodistrict plan – indeed, as an essential element of its very identity – all new buildings and major renovations should be required to be 'district energy-ready'. This means that they design their energy systems from the start to take full advantage of hot-water, chilled-water, and microgrid-based electric service that the Ecodistrict may be supplying. Some of these requirements are relatively minor design decisions that have little or no cost impact on initial construction, but would eliminate costly retrofits when hooking up to the energy district in the future – for example, making sure that heating, cooling, and domestic hot water are all distributed inside the building starting from a ground or basement level, not from the roof, or using 100% hydronic systems for all thermal loads (e.g. instead of electric hot water heaters in each apartment).rnrnOther aspects of requiring participation in an energy district can bring significant savings for new construction. On the thermal side, substantially less space may be required for boilers, chillers, and other mechanical equipment. Rooftops in particular can be converted to premium tenant amenities instead of HVAC systems, and the freed-up space can also support more photovoltaic and solar-thermal collection.rnrnIf a building chooses to install its own thermal equipment, or if the Ecodistrict's distribution system does not yet reach a particular building, that equipment can be valuable (and even revenue-generating) by adding surplus supply and redundancy to the Ecodistrict's distribution system. Similarly, it is essential to keep current GSA users on the system; even if they already have or choose to install their own boilers and chillers, such facilities can be used for peaking purposes for the energy district as a whole, as long as they remain connected to the distribution systems.rnrnNot only should the buildings themselves be energy district-ready, but the street grid should be as well. Any new building sites, new excavation, road realignment, and so forth, should be required to include tunnels for both pipes and wires. This underground distribution infrastructure and right-of-way is one of the most important assets of the current GSA-owned system, and should be expanded into every site within the Ecodistrict.rnrnOn the electric side, a 'microgrid-ready' building can forgo any back-up or standby generation beyond life-safety minimums, since redundancy and reliability for electric supply comes from the microgrid. But any on-site resources, such as photovoltaics or energy-from-waste, can be integrated more easily into a microgrid than directly into the utility grid, especially when using a “non-synchronous” approach to set up the microgrid. Utility hook-ups (such as transformer vaults) should be made easily accessible to the Ecodistrict's own electric distribution, for example from the HOTD central plant. We would note that the larger-scale PV installations contemplated in the plan, such as along the Southwest Freeway, will also be far easier to integrate into a microgrid, avoiding interconnection issues with Pepco.rnrnMore important, a microgrid (or multiple connected microgrids) within the Ecodistrict would mean far lower costs for utility upgrades, substation expansion, new distribution systems, and so forth. The NCPC should solicit early support from Pepco, as the utility has to be part of the stakeholder group from the very beginning. The Ecodistrict would also benefit from a push for new regulations that would permit utility ownership of microgrid assets with appropriate tariffs. Whether by utility ownership or otherwise, an appropriate mechanism must be implemented to make sure that the significant savings from not having to build out the utility grid can be re-directed toward the microgrid alternatives that would avoid those costs.rnrnOur compliments on a great start to an exciting future.rnrnSincerely,rnrnShalom Flank, Ph.D.rnCTO & Microgrid ArchitectrnPareto Energy LTD
16.
The National Capital Planning Commission's draft plan for the Southwest Ecodistrict represents an impressive step forward and lays a solid foundation for concrete action in this vital section of our city. We are particularly excited by the well-integrated energy vision presented in the plan, with a district-wide approach centered on a new microgrid. We would like to reinforce this approach with comments in the following three areas.
1) Central Utility Plant
To that end, we strongly support the Plan's goals to invest in the existing central utility plant for heating and cooling, to modernize the plant’s equipment, and to increase efficiency by adding new residential and commercial uses throughout the study area. We also support the intention to expand and upgrade existing equipment in order to support new users. In particular, adding residential and hotel users to the central utility plant would help balance thermal and electric loads, and level the output between daytime and evening or weekend usage.
Preserving the Cotton Annex site may be essential to expanding GSA's current HOTD facilities in order to serve the larger SW Ecodistrict. Expanded capacity would be needed to serve both Federal and private facilities, to reach the new construction contemplated in the plan, and to move beyond heating and cooling services to providing electricity service as well. Any plans for that parcel should incorporate the option of incorporating substantial energy infrastructure, including thermal and electric generation, grid integration, storage, and distribution.
We also support the long-term goal to transition the central utility plant toward a less carbonized energy source when the technologies become available. Not only does natural gas offer significant reductions compared to coal, but the higher efficiency and more intensive utilization of CHP provides an even larger reduction in carbon and other emissions. Even if pipeline natural gas is the only source of fuel, the efficiencies and carbon reductions of the district energy approach make it entirely worthwhile on environmental grounds alone.
Moving beyond fossil fuels requires fuels that are not simply an energy carrier, such as anhydrous ammonia (as opposed to an energy source). We believe that biomass and energy-from-waste will provide an increasing percentage of the methane utilized for electricity production. One cost-effective approach may be to utilize existing pipeline distribution and electricity generators that are already optimized for methane (a.k.a. natural gas). This approach would be similar to relying on Renewable Energy Credits (RECs) and Renewable Portfolio Standards (RPS) to procure low-carbon electricity, even when it is produced at a site that is remote from the point of use. In addition, on-site waste-collection can support medium-term low-carbon energy production through gasification and other zero-emission technologies.
Current limitations on GSA's ability to act within a public-private partnership should be overcome. While privatization is at one end of the spectrum, statutory and/or regulatory changes would enable a balanced approach to serving core government interests while still achieving the flexibility and market-based incentives of a business. An energy-specific version of a Business Improvement District – an Energy Improvement District or EID – may provide one appropriate model. Membership would be shared among Federal, non-profit, commercial, and residential properties within the Ecodistrict. Bylaws could be instituted to protect key Federal priorities, including an appropriate role for GSA given its effective management of the HOTD over the years. An EID would also play a key role in sourcing 3rd-party capital for energy infrastructure, in conjunction with other approaches such as Tax Increment Financing. It may be essential from a commercial perspective that users participating in the energy district would only have to pay for the energy they consume, rather than paying all capital costs upfront.
2) Energy Storage
Thermal storage presents an important opportunity to level both thermal and electric loads and to increase the role of zero- or low-carbon energy sources. With various areas that are planned to be decked over, large-scale storage tanks should be a priority for using those newly-available volumes. Storing hot water overnight would limit the need for dedicated gas or electric hot water boilers in the residential sector during morning peak usage. During cooler weather, storing solar thermal hot water into the evening and overnight would limit peak heating requirements. Chilled-water or ice storage would be even more important, enabling cogeneration to operate overnight with full thermal utilization (i.e. maximum efficiency) during warmer weather, and limiting the peak electricity that would need to be imported from the transmission grid (which is likely to be much “dirtier” power).
These thermal strategies will make the Ecodistrict function as a more unified microgrid, and increase the reward of shared energy infrastructure and district-wide distribution systems. Even if bus parking and other uses limit the use of sub-decking space, architecturally attractive approaches can integrate thermal storage into other public space – such equipment need not be limited to “back of the house” locations.
Electricity storage is a far less mature technology, but some 'future-proofing' may be warranted. For example, any parking facilities should incorporate the infrastructure (mainly conduits) for installing electric vehicle charging station, and extra space that can be converted when needed to switches, transformers, and other equipment designed to access the EVs as battery-storage for the microgrid.
3) Microgrid-ready and District Energy-ready buildings
As part of the Ecodistrict plan – indeed, as an essential element of its very identity – all new buildings and major renovations should be required to be 'district energy-ready'. This means that they design their energy systems from the start to take full advantage of hot-water, chilled-water, and microgrid-based electric service that the Ecodistrict may be supplying. Some of these requirements are relatively minor design decisions that have little or no cost impact on initial construction, but would eliminate costly retrofits when hooking up to the energy district in the future – for example, making sure that heating, cooling, and domestic hot water are all distributed inside the building starting from a ground or basement level, not from the roof, or using 100% hydronic systems for all thermal loads (e.g. instead of electric hot water heaters in each apartment).
Other aspects of requiring participation in an energy district can bring significant savings for new construction. On the thermal side, substantially less space may be required for boilers, chillers, and other mechanical equipment. Rooftops in particular can be converted to premium tenant amenities instead of HVAC systems, and the freed-up space can also support more photovoltaic and solar-thermal collection.
If a building chooses to install its own thermal equipment, or if the Ecodistrict's distribution system does not yet reach a particular building, that equipment can be valuable (and even revenue-generating) by adding surplus supply and redundancy to the Ecodistrict's distribution system. Similarly, it is essential to keep current GSA users on the system; even if they already have or choose to install their own boilers and chillers, such facilities can be used for peaking purposes for the energy district as a whole, as long as they remain connected to the distribution systems.
Not only should the buildings themselves be energy district-ready, but the street grid should be as well. Any new building sites, new excavation, road realignment, and so forth, should be required to include tunnels for both pipes and wires. This underground distribution infrastructure and right-of-way is one of the most important assets of the current GSA-owned system, and should be expanded into every site within the Ecodistrict.
On the electric side, a 'microgrid-ready' building can forgo any back-up or standby generation beyond life-safety minimums, since redundancy and reliability for electric supply comes from the microgrid. But any on-site resources, such as photovoltaics or energy-from-waste, can be integrated more easily into a microgrid than directly into the utility grid, especially when using a “non-synchronous” approach to set up the microgrid. Utility hook-ups (such as transformer vaults) should be made easily accessible to the Ecodistrict's own electric distribution, for example from the HOTD central plant. We would note that the larger-scale PV installations contemplated in the plan, such as along the Southwest Freeway, will also be far easier to integrate into a microgrid, avoiding interconnection issues with Pepco.
More important, a microgrid (or multiple connected microgrids) within the Ecodistrict would mean far lower costs for utility upgrades, substation expansion, new distribution systems, and so forth. The NCPC should solicit early support from Pepco, as the utility has to be part of the stakeholder group from the very beginning. The Ecodistrict would also benefit from a push for new regulations that would permit utility ownership of microgrid assets with appropriate tariffs. Whether by utility ownership or otherwise, an appropriate mechanism must be implemented to make sure that the significant savings from not having to build out the utility grid can be re-directed toward the microgrid alternatives that would avoid those costs.
Our compliments on a great start to an exciting future.
Sincerely,
Shalom Flank, Ph.D.
CTO & Microgrid Architect
Pareto Energy LTD
19. I support this commenter's recommendation to evaluate and plan for energy storage options. However, he seems confused about combustion technologies.
He uses the phrase "gasification and other zero-emission technologies." Gasification is a type of incineration (that operates in two stages, first turning the fuel/waste into a gas, then burning it) and is recognized by the U.S. EPA (and the E.U., for what that's worth) as incineration. It most definitely is NOT zero emission. Its emissions are quite comparable to conventional style incinerators, and its use for "biomass" and municipal waste is still fairly experimental, with many problems plaguing facilities that try to operate on a commercial scale -- causing the few that have tried to operate commercially to close down due to financial or technical problems or both.
He recommends "biomass and energy-from-waste." "Energy from waste" is merely a PR term for waste incineration, primarily used by Covanta -- the nation's largest trash incineration corporation -- one with quite a history of environmental violations. None of these technologies are appropriate if the project aims to reduce greenhouse gases and toxic emissions. Energy Information Administration data also shows biomass and trash incineration to be the most expensive forms of energy there are -- even more than nuclear and solar. See MSW (municipal solid waste incineration) and biomass costs in: "Updated Capital Cost Estimates for Electricity Generating Plants," Energy Information Administration, November 2010, p.7, Table 1. http://www.eia.gov/oiaf/beck_plantcosts/ (direct link: http://www.eia.gov/oiaf/beck_plantcosts/pdf/updatedplantcosts.pdf).
Submitted by Mike Ewall, Esq. on September 11, 2012 at 2:22 am | Reply to this comment
14. It is heartening to see the plan includes recycling construction and demolition debris at a 75% rate. That should be possible as there are some legitimate recyclers of that material in the area, but beware as there are also some sham recyclers. But it is easy to require recycling. True support of recycling comes from helping develop end markets for recycled products. We suggest the project should require the use of recycled materials in the pavements, such as asphalt shingles in asphalt and recycled concrete as a roadbase, to other recycled and reused products in the buildings.
Submitted by William Turley, Executive Director, Constructin Materials Recycling Association on September 9, 2012 at 1:04 pm | Reply to this comment
13. As an important caveat to the comments by the Washington Interdependence Council, it is important to note that all design elements of the Banneker Memorial: Statue, ClockTower, Benjamin Banneker Institute of Math & Science Technology; and Founding Fathers Visitor's Center would be paid for by private funding raised by the Washington Interdependence Council, as is the case with all national memorials. However, I also failed to mention that the 1158 car/75 tour bus underground parking lot is also a critical component of the U.S. Dept. of Transportation TEA21 funds which our agency procured design component as well. This is the result of our many years of work with the previously listed four governmental agencies we enlisted to pursue this renovation after three years of aggressive outreach. This timely partnership has resulted in the process having matriculated successfully this far along which is essential for the success of the southwest waterfront,
including the three level underground parking lot that will be beneath Banneker Overlook Park.
All the more reason is it highly insulting, not ot mention, execruciatingly painful to bear the insult of systematic exclusion and being erased from histoic record the closer the project comes to fruition and completion. This is one of the most offensive aspects of gentrification.
Mr. Banneker, who also drew 16th Street as the Meridian and "spirtual center" of the nation's capital, over two centuries since he helped create Washington, DC as we know it, and the Washington Interdependence Council which has made major contributions of this SW EcoDistrict Plan, as outlined herein, boith deserve much better than it has gotten and we ask for America to do the right thing by African-Americans who have made major contriubtions to the privileges and benefits that everyone but them seem to enjoy in this country. If the nation's capital has no moral compass or fortitude, how will the country overall exhibit any when the message is: Let's symbolically, and pragmatically continue modern day slavery. It's a no-win formula, no matter how pretty it looks on paper.
Submitted by Peggy Seats, Fdr/CEO, Washington Interdependence Council on September 8, 2012 at 3:51 pm | Reply to this comment
12. This is a lovely vision for the revitalization of the southwest waterfront. As described herein, the L'Enfant Plaza/Benjamin Banneker Overlook Park corridor is a top priority and critical linkage area, or future gateway, tying the Mall and major tri-state waterfront destinations together.
However, as the private organization which has worked for 15 of our 16 years as the facilitators of the planning and funding focus for this "top priority" revitalization, the L'Enfant Plaza/Benjamin Banneker Overlook Park connective corridor, it is amazing and highly insulting that there is no mention of the Washington Interdependence Council's civic work as the faciltators and creative contributors to the embraced vision for transforming this critical corridor into an inviting, lush parklike setting to lure pedestrians from the Mall to the new and improved Banneker Memorial and further on to the new multi-billion dollar waterfronts.
It was the Washington Interdependence Council too which recommended the removal of the U.S. Dept. of Energy's Forrestal building obstructive overpass to open up the vista to the frontal view of Smithsonian Castle.
The Washington Interdpendence Council spent three years lobbying the National Park Service; DDOT [then called the District Dept. of Public Works]; the Federal Highway Administration [the underwriters of the renovation via its TEA21 program] to commence with the massive transformation of this "top priority" area in the the SW EcoDistrict plan; to provide funding for the rehabilitation of this area "to make way for the Banneker Memorial." Yet, there is not one word of mention of our 15 years of work as facilitators of this en progress work as it continues to move forward a hard earned decade and a half later.
There is no mention of the Benjamin Banneker commemorative initiative there, even though the Washington Interdependence Council's name, as facilitators, is on the cover, and are signatories on the Memorandum of Agreement signed on January 12. 2000 by all five partnering agencies to move forward with the proposed vision of improvements.
The Washington Interdependence Council's name is on the first phase of the detailed plan, the L'Enfant Promenade Urban Planniing Study; the second phase document, the L'Enfant Promenade and Benjamin Banneker Park Environmental Assessment for Improvements to the L'Enfant Promenade and Benjamin Banneker Park; and the FONZI [Finding of No Significant Impact] stamp of approval for the proposed overhaul. The agency's name is on those documents, as the only none governmental agency, because its work as a non-profit facilitator, forged those renovative actions as a result of its persuasive proposal to have the funding federal agency, the Federal Highway Administration, to pay to renovate the project area. Our agency was also a full work committees participant over the years, to advance the vision, and helping to co-author those documents, etc.
As the only agency whose executives received no compenseation for these many years of work in not only working to help create these documents laying the foundation for the now en progress reconstruction of this site; AND as the procuring agency of its primary funding which paid agencies such as Parsons Brinckerhoff Quade & Douglas, Inc. and HNTB Architects Engineers Planners et al to help carry this vision forth to its present phase of matriculation, it is very insulting, as the progenitators of this "top priority" area overhaul to receive no credit, acknowledgement nor support for the initiative they have been pursuing for 16 years, the Benjamin Banneker Memorial, which facilitated the possibility of this reconstructive renovation of the key half mile corridor in the way it has successfully advanced forward towards completion circa 2016.
Our agency, from the outset of our commeorative endeavor, indicated that we wanted to upgrade L'Enfant Plaza/Banneker Overook Park to a world class memorial honoring Benjamin Banneker; and thereby sought out the federal funds from the U.S. Dept. of Transp. to do so, in order to defray the cost of the commemorative effort extensively. We later added, as a part of its commemorative design, the Benjamin Banneker Institute of Math & Science Technology, training America's youth from age seven on through to high school [a sort of feeder school to colleges and universities] as leaders in the STEM [Science, Technology, Engineering and Math] disciplines. This is espoused as an American priority,along with a 30-40 foot ClockTower, Founding Father's Visitor's Center and Open Air Overhead Canopy to protect pedestrians from the elements.
We further recommended that the entire corridor of the L'Enfant Plaza corridor serve as "Founding Fathers" walk to tell the story of the eight men [George Washington, Thomas Jefferson, Thomas Johnson, Daniel Carroll, David Stewart, Major Andrew Ellicott, Benjamin Banneker and Charles Pierre L'Enfant] who created the new Federal City as the seat of government in 1791.
We also urged the DDOT and the DC Dept. of Planning and the National Park Service to add a pedestrian overpass to Banneker Overlook Park to carry pedestrians, especially physically challenged and bikers all the way across Maine Ave. on over to the marina. It was, and still is our position that the reason the corridor failed in the first place in terms of faciliting the safe navigation of pedestrians from the Mall to the waterfront was due to the fact that its a terminus. It's a terminus that stops just short of its mission to provide safe passage of persons traversing from the Mall to the waterfront. This was a major selling point in our original proposal which providing the funding and planning for this key area's upgrade. It has yet to be publicly declared a part of the renovation of the project area, and we feel, as some others commenting has expressed, essential to the success of the corridor as a future "gateway" link between the Mall and marina.
The Washington Interdependence Council serves as advocates of the importance of symbolic diversity within the public landscape of America. That is our mission, and is stated as such in our mission statement. This is why we elected to upgrade Banneker Park, as an official memorial to this great colonial American hero, as authorized and designated by the U.S. Dept. of the Interior in 1971, prior to the establishment of the current commemorative oversight agencies such as the National Capital Memorial Commission.
Benjamin Banneker is one of the Founding Fathers of the nation's capitol, and as the surveyor, astronomer and technical and engineering co-planner of the "Federal City" determined the location of the White House, the Capital, the Washington Monument, the Treasury Building and the area contained within the 40 marked Boundary Stones outlining the new Federal City. As such, he deserves the upgrade of the site already named in his honor. If America and the agencies overseeing his current memorial site do not honor his legacy by supporting the upgrade of his commemorative site to a world class memorial versus the desecration of his memorial with other "more important" endeavors, it will be a HUGE MISTAKE.
And that's not the mention giving proper respect and acknowledgment to the Washington Interdependence Council's work in moving the above mentioned embraced and adopted contributions towards the SW EcoDistict Waterfront project forward as well. Must the madness of systemic exclusion based on skin color continue to stain the merit of intended sound and beneficial efforts?
As advocates of the symbolic importance of diversity in the public landscape, it was also the Washington Interdependence Council's idea to have the replica of the Pearl Schooner, the ship with provided transportation for the largest attempted escape by sea of the 77 enslaved persons who sought freedom by leaving out, under the cloak of darkness, from their imprisonment camps to meet up at 7th & Maine Ave., SW to flee to what they had hoped would be freedom. Unfortunately, a storm ensued, and traitors reported them and they were captured at sea and brought back to suffer the consequences of their actions. This was a very historic moment in history and the replica of the Pearl Schooner as a tourist attraction, similar to the Amidon Schooner, would be another excellent cultural offering on the southwest waterfront. I enlisted the late Lloyd Smith, former CEO of the National Capital Revitalization Corporation, which I served as his Southwest Waterfront Consultant for, to take on this project after his retirement from this agency which jump started the SW EcoDistrict renovation.
Also, black and other dieadvantaged businesses should have ownership in initiatives such as the Banneker Memorial and Pearl Schooner, not just work as employees. With no ownership, and no power to voice the stories about blacks being told renders the efforts null and void anyway regardless of if they are "usurped" by others as has the Pearl Schooner project and the on-going onslaught of sabotage and disenfranchment that has been the hall mark of the Benjamin Banneker Memorial experience as we are disrespected, written out of the picture and documentation process, discredited and overall treated persona non grata by the powers that be and the powerful developers who can never get enough. This document, as is, I feel is a testiment to that disservice.
This 50+ year cycle of imperialistically designed gentrification should be mindful of making the same elitist, exclusionary and unjust mistakes which are common to this process time and again. It will behoove the country and its citizenry to take the higher ground and do the right thing, especially by those interests like the Washington Interdependence Council which has more than paid its way for a respectful seat at the table in this en progress SWEcoDistrict Plan. Thank you for your consideration.
Submitted by Peggy Seats, Fdr/CEO, Washington Interdependence Council on September 8, 2012 at 3:18 pm | Reply to this comment
11. This is an exciting plan! However, one thing I don't see is safe bike access through the 14th St/15th St. corridor. The 14th St bridge has a separated bike/ped lane, which leads to the Mt. Vernon Trail (form which the Four Mile Run, W&OD, Custis Trail, etc. can be accessed). The Rock Creek Park trail runs along the Potomac, leading to the C&O and the Capital Crescent. And the ever popular East Potomac Park is just beyond the Jefferson Memorial.
But the 1/2 mile or so between the end of the 15th St. Cycle Track at Penn and the connection to the 14th St. Bridge/Rock Creek Park Trail/East Potomac Park is horrifically cycle-unfriendly--the roadway is narrow with no parking lane and no shoulder to speak of and is filled with speeding cars heading onto the freeway, and the sidewalks are off limits to bikes. There is no way to return northbound into the city without violating the law by riding on sidewalks because Basin Drive is one way southbound. All of this is not to mention the deplorable condition of the roadway at Maine Ave and Ohio Drive.
There is also no safe way to reach the Anacostia Riverwalk Trail from the Mall.
We have such great facilities; it is frustrating to see them underutilized (particularly the Anacostia Riverwalk Trail) because they are unsafe to approach.
10. There need to be protected cycle tracks instead of painted lanes on Maryland Ave and 7th Street, and a pedestrian crossing over Maine Ave so pedestrians and cyclists don't need to risk their lives crossing Maine from Banneker Overlook and vice-versa.
9. This is all well and good, but the wound that started the whole Southwest demolition was the southeast-Southwest Freeway, which since it was built has acted as a tourniquet and jsut basically killed everything south of it...it's foreboding, a barrier. No Southwest project can be even half complete without burying that freeway in a tunneland replacing it with a grade-level boulevard that helps re-connect the grid pattern of the city and connect the southern portion of DC to the rest of it: Nationals Park and all around it are an easywalk from the Capitol but who in their right mind woudl walk tat after dark? The beauty of this is that there's so much land involved that after construction, if the four blocks wide area that is nearly five miles long wer properly husbanded and marketed, the sale of pieces coudl pay for a good portion of th construction over time, and the increase in taxable value of the land south of the freeway woudl lift the tax base enough to make up a good portion of the rest. Plus, it's jsut the right thing to do
The plan has specific numerical targets for waster, energy, and potable water. Why not set one for stormwater, as well? Zero net runoff, for example, or that the district will capture and reuse and/or infiltrate 75% of all annual rainfall. This would help to set targets for each of the individual developments (buildings, roads, memorial sites, etc) and better convey the cumulative impact.
7. As a resident of the Capitol Square community, I support the plan to cover the freeway between 7th and 9th Streets. It will not only improve the connectivity, but also cut down on noise and pollution from the highway traffic. While it would be nice if this area could become open space or a park, I would be OK with a solar farm also.
6. P. 3 of the draft depicts greenery on the metrorail tracks.. .how will that be accomplished with the frequent passage of the train over the grass? I would imagine that the constant disturbance and pollution would kill the grass/plant, etc that are pictured in between the tracks..
4. We have been reading about your project with great interest and admiration of your goals and the example that you are setting for new developments throughout the country. We are in the midst of establishing a national; very interactive, results orientated, guaranteed carbon offset program for households and schools. Put simply, the patented, all natural, root production method of our nursery in Missouri produces the best carbon sequestration trees in America. Our trees will sequester 3 times the carbon in half the time. Over 80% of the trees that we grow are native trees specific to the various regions in which we sell. We would very much like to have the opportunity to present to you our scientific findings and develop for you some growth and carbon analysis specific to your project. We will continue to follow the progress of your endeavors and look forward to an opportunity to demonstrate how RPM trees from the Forrest Keeling Nursery can make a significant contribution to your goals. www.rpmglobalsolutions.com
3. I work in Southwest Waterfront at the Lenfant Plaza complex. I cannot wait for this redevelopment to happen! I fully support it. I especially hope that this plan fully succeeds in addressing the Forrestal building - it cuts off the natural walkway between the waterfront and the mall. Due in part to the SW Ecodistrict plan, I am now looking for opportunities to purchase a new condo or home in the SW neighborhood.
2. I applaud NCPC for attempting to create the SW Ecodistrict. Surely there are many possible plans to come up with for this area -- almost any alternative is better than the current humans-not-welcome 1960's layout.
One measure that I wholeheartedly support as vital is an area of underground parking for tour buses. The current situation on the National Mall is that there are hundreds or even thousands of tour buses every day that line Madison and Jefferson Drives fouling out air with their idling engines, illegally parking in bus pick-up and drop-off zones, blocking the sweeping views and designed sight-lines across the Mall from the sidewalks, making so much noise that it erases any possible sound of nature within this national park, and also creating a dangerous hazard for pedestrians and bicyclists. Whereas any visitor to the National Mall that arrives via Metro or other public transportation option is expected to walk from museum to museum, visitors who arrive by tour bus expect to be chauffered from the door of one museum to the door of the next.
The appropriate solution is to have a large, central underground parking garage within walking distance from the National Mall and to expect tour bus visitors to walk to and from that location to the museums and other attractions. Tour buses should then be banned from picking up, dropping off and parking on the National Mall. A fee of $25 - $50 (or whatever is economically appropriate for the unsubsidized operation of this parking garage) could be charged for tour bus parking at this location.
For those passengers that are handicapped, there could be complimentary shuttles from this location to the various museums.
Every visitor's experience of the National Mall is diminished by these loud, polluting, ugly, traffic-clogging, dangerous tour buses. I hope the SW Ecodistrict plan will include enough parking for a centralized, nearby location where these buses can park en masse and leave the National Mall in peace.
1. The plan area skirts the existing residential neighborhood of Town Square (between 4th Street SW and 7th Street SW, extending from the SE/SW Freeway to H and I Streets). Consider extending the existing 6th Street across the SE/SW freeway by introducing a pedestrian and cyclist bridge from the landscaped circle at 6th and G Streets, crossing over the freeway and accessing 6th Street at St. Dominic's Church.
Comments (19)
Numerous references are made to replacing natural gas in the central utility plant with a “decarbonized fuel” or “zero carbon renewable fuel source.” There is no such thing. Any fuel that can be economically combusted on this scale will have carbon emissions. Rare exceptions, like hydrogen, are still produced in processes that use fossil fuels (namely natural gas, in the case of hydrogen). The same is true of the future possibility of “electrofuels” mentioned on page 40, which require electricity and hydrogen inputs to produce the fuel (which itself contains carbon).
Any form of biomass or biofuels used will increase carbon emissions, working in conflict with the project’s aim to reduce global warming emissions. Biomass is not carbon neutral, as several studies in recent years have exposed – most notably the 2010 study commissioned by the Commonwealth of Massachusetts. Massachusetts hired the Manomet Center for Conservation Sciences to study whether biomass is actually “carbon neutral” and found that it is not, and that biomass is worse than coal for global warming over 40 years and worse than natural gas over 90 years. The state then adopted the nation’s strongest regulations limiting biomass eligibility in their renewable energy law, effectively forbidding biomass electric power plants. Links to the Manomet study and others on biomass and global warming, can be found in the right sidebar on http://www.energyjustice.net/biomass
Per unit of energy produced, biomass is more polluting than coal by many other measures in addition to greenhouse gas pollution. Burning biomass emits particulate matter (PM), nitrogen oxides (NOx), sulfur oxides (SOx), carbon monoxide (CO), toxic heavy metals (such as arsenic, mercury, lead, cadmium and chromium), acid gases, dioxins and furans, volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), and other hazardous air pollutants (HAPs). With the exceptions of SOx and mercury, all of these other pollutants are generally released at emission rates worse than coal. Much documentation on this is available through http://www.pfpi.net and more available upon request.
Page 41 lists Seattle Steam’s burning of biomass as a best practice and page 84 mentions the Saint Paul, Minnesota District Energy plant as one that reduces greenhouse gas emissions. The greenhouse gas reduction claim is demonstrably false and these examples ought to be removed altogether, and replaced with appropriate examples of technologies that do not spew toxic pollution and greenhouse gases at rates dirtier than coal power plants. Seattle Steam is burning wood waste, which includes construction and demolition wood waste – a particularly contaminated waste stream known to emit significant levels of arsenic, lead, chromium and dioxins, in addition to the full spectrum of pollutants that normally come with wood burning. Located in a residential area, this has been a serious new health risk for those who live near the Pike Place Market in Seattle, causing local residents to organize against this supposed “best practice.” See: http://www.marketair.org/?p=266
The best practice examples should be replaced with non-burn heating solutions, such as solar thermal technologies, ground source heat pumps (geothermal) or air-source heat pumps, provided that the heat pumps operate on wind or solar power electricity. A good local example of solar hot water is the Tiber Island complex at 430 M St SW in DC. The north tower of the complex has one of the city’s largest solar hot water installations, replacing much of the natural gas heating needs of the 4-tower complex. This project was done by Skyline Innovations, which has many other examples profiled on their website that are worthy of mention as best practices: http://www.skylineinnovations.com/our-projects/
2) The goal of reducing waste to landfill by 80% must include diversion from incineration as well.
On page 42, the plan states the assumption that “60 to 70 percent of the area’s overall waste is sent to the landfill.” This assumption should be checked, since in recent years, most of DC’s waste has been sent to be burned in the incinerator in Lorton, VA (and then to a landfill as the toxic ash must be disposed of).
Incineration involves turning trash into toxic ash and toxic air emissions. About 30% of the weight of the trash becomes concentrated toxic ash that is then landfilled, causing more damage to groundwater over time, as the ash is more toxic and more leachable than the larger volume of unburned trash. The other 70% of the weight of the trash becomes toxic air emissions that are essentially “sky filled,” polluting our air.
Since incineration necessitates generation of ash that goes to landfills, incineration cannot and should not be considered a diversion from landfills.
Materials management plans that aim to maximize source reduction, reuse, recycling and composting are called zero waste plans. San Francisco’s success at diverting 77% of their waste from landfills and incinerators is due to an ambitious zero waste plan the city has adopted.
The official definition of zero waste is one that avoids both landfilling AND incineration of waste. The term was adopted and defined by the Zero Waste International Alliance, and is defined as follows (emphasis added):
"Zero Waste is a goal that is ethical, economical, efficient and visionary, to guide people in changing their lifestyles and practices to emulate sustainable natural cycles, where all discarded materials are designed to become resources for others to use.
Zero Waste means designing and managing products and processes to systematically avoid and eliminate the volume and toxicity of waste and materials, conserve and recover all resources, and NOT BURN OR BURY THEM.
Implementing Zero Waste will eliminate all discharges to land, water or air that are a threat to planetary, human, animal or plant health."
Source: http://zwia.org/joomla/index.php?option=com_content&view=article&id=9&Itemid=6
Page 38 of the plan states that “burning coal is a significant contributor to global warming and releases toxic pollution into the air and water.” The same reasons apply to trash incineration. According to the latest EPA eGRID data, trash incineration produces 2.6 times more CO2 per unit of energy produced than burning bituminous coal. Even if you pretend that the “biogenic” fraction does not count (that it’s instantly sucked back up by trees specifically planted to replace the organic products destroyed in the burner), trash incineration is 60% worse than bituminous coal, according to the same EPA data.
Even with more air pollution control equipment in place, trash incinerators emit more pollution than (largely uncontrolled) coal power plants per unit of energy produced. Trash incinerators emit 3-6 times more mercury as coal plants do to produce the same amount of energy, nearly six times more lead, 4.4 times more nitrogen oxides (NOx), twice the carbon monoxide (CO), 4.5 times more sulfur dioxide (SO2) and about 25 times more dioxins (one of the most groups of chemicals known to science).
The plan’s stated concerns about coal’s contribution to global warming and toxic air and water pollution urges that the plan also reject incineration as a waste disposal or energy generation method.
In rejecting trash incineration, the plan must also recognize that incineration is rarely called that anymore, as the technology has earned a very dirty reputation over the last few decades. Various “waste-to-energy” (incineration) schemes now operate with nicer-sounding names, and some variants on the traditional boiler technologies insist that they are not incineration, yet are regulated as incinerators. Gasification, pyrolysis and plasma arc are technologies that are defined in federal regulation as types of incinerators (see 56 FR 5488 and 40 CFR 60.51a or find the definitions spelled out at the bottom of the http://www.energyjustice.net/incineration webpage.
There are numerous zero waste plans that have been developed by forward-thinking cities in the U.S. Here are links to some of their plans, which should serve as a model for this project:
In December 2011, Austin, Texas adopted an excellent Zero Waste master plan to put them on the same path that cities like San Francisco have been pursuing. San Francisco is already at 77% diversion of waste from landfills and incinerators. In 2010, Austin was at 38% diversion.
The Austin Zero Waste plan aims for:
50% in 2015
75% in 2020
85% in 2025
90% in 2030
95%+ in 2040
Austin, TX Zero Waste master plan (competing with $20/ton landfill tip fees!):
http://austintexas.gov/news/austin-city-council-approves-30-year-plan-reach-zero-waste (press release)
http://austintexas.gov/sites/default/files/files/Trash_and_Recycling/MasterPlan_Final_12.30.pdf (the 321 page plan itself - 37 MB PDF)
http://energyjustice.net/files/waste/austinzerowasteplansummary.pdf (25 page summary - 28 MB PDF)
San Francisco Zero Waste plan
http://sfenvironment.org/zero-waste
Alameda County, CA:
http://stopwaste.org
http://stopwaste.org/home/index.asp?page=518 (Policy Tools & Model Ordinances for Local Governments)
Oakland, CA zero waste plan:
http://www.zerowasteoakland.com
Other major resources on zero waste:
http://www.zwia.org - Zero Waste International Alliance
http://www.grrn.org/zerowaste/ - Grassroots Recycling Network
http://www.ilsr.org/initiatives/waste-to-wealth/ - Institute for Local Self-Reliance (this group is great at helping put together alternative economic plans based on recycling and composting)
3) Green Building
The following five points should be integrated into the plan, relating to green building, waste and water use.
Polyvinyl chloride (PVC) plastic (a.k.a. vinyl) should be prohibited in any new construction or building retrofits. Primarily due to its high chlorine content, PVC is highly toxic in its manufacture and disposal, and if buildings ever catch on fire. This toxic plastic is often used in building materials, particularly piping, coating of electrical wiring and in siding. There are alternatives to most PVC uses and they should be required where available. See http://www.ejnet.org/plastics/pvc/ for links to resources on PVC and the alternatives.
Deconstruction methods should be used in place of demolition and in remodeling. In order to minimize waste and maximize recycling and local job creation, deconstruction methods should be used to carefully dismantle and reuse materials in buildings being torn down or remodeled. Also, due to the toxicity of concrete dust, special care must be required of any concrete cutting and demolition, so that all concrete dust is fully contained and not released to the air. See http://www.ilsr.org/initiatives/deconstruction-waste-to-wealth/ for resources on deconstruction.
Waterless urinals should be used to help reduce water use. Water-free urinals are available and should be mandatory where urinals are replaced or installed. Some vendors include www.zeroflush.com, www.falconwaterfree.com and www.waterless.com.
No LEED points should be sought for using cement mixed with coal power plant fly ash. The LEED green building standard assigns recycling points for using cement mixed with the highly toxic fly ash from coal power plants. Cement mixed with this toxic waste byproduct of coal power plants should not be used, both to avoid subsidizing coal power plants, but most importantly to protect the health of the construction workers, all who will ever come in contact with the cement structure, and the community once the concrete is eventually destroyed. See http://www.peer.org/news/news_id.php?row_id=1447 for materials on the hazards of fly ash in cement.
Use of cement manufactured by burning tires, hazardous waste, sewage sludge, plastics, municipal solid waste, refuse-derived fuel or other wastes should be prohibited. Cement manufacturing is pollution enough as is, but the trend toward burning these dangerous waste streams is particularly dangerous to the communities that host cement kilns. Some information on this is available through: http://energyjustice.net/cementkilns and http://earthjustice.org/features/campaigns/cement-plant-background-resources
A concerned resident of SW DC,
Mike Ewall, Esq.
Founder & Director
Energy Justice Network
mike@energyjustice.net
http://www.energyjustice.net
The National Capital Planning Commission's draft plan for the Southwest Ecodistrict represents an impressive step forward and lays a solid foundation for concrete action in this vital section of our city. We are particularly excited by the well-integrated energy vision presented in the plan, with a district-wide approach centered on a new microgrid. We would like to reinforce this approach with comments in the following three areas.
1) Central Utility Plant
To that end, we strongly support the Plan's goals to invest in the existing central utility plant for heating and cooling, to modernize the plant’s equipment, and to increase efficiency by adding new residential and commercial uses throughout the study area. We also support the intention to expand and upgrade existing equipment in order to support new users. In particular, adding residential and hotel users to the central utility plant would help balance thermal and electric loads, and level the output between daytime and evening or weekend usage.
Preserving the Cotton Annex site may be essential to expanding GSA's current HOTD facilities in order to serve the larger SW Ecodistrict. Expanded capacity would be needed to serve both Federal and private facilities, to reach the new construction contemplated in the plan, and to move beyond heating and cooling services to providing electricity service as well. Any plans for that parcel should incorporate the option of incorporating substantial energy infrastructure, including thermal and electric generation, grid integration, storage, and distribution.
We also support the long-term goal to transition the central utility plant toward a less carbonized energy source when the technologies become available. Not only does natural gas offer significant reductions compared to coal, but the higher efficiency and more intensive utilization of CHP provides an even larger reduction in carbon and other emissions. Even if pipeline natural gas is the only source of fuel, the efficiencies and carbon reductions of the district energy approach make it entirely worthwhile on environmental grounds alone.
Moving beyond fossil fuels requires fuels that are not simply an energy carrier, such as anhydrous ammonia (as opposed to an energy source). We believe that biomass and energy-from-waste will provide an increasing percentage of the methane utilized for electricity production. One cost-effective approach may be to utilize existing pipeline distribution and electricity generators that are already optimized for methane (a.k.a. natural gas). This approach would be similar to relying on Renewable Energy Credits (RECs) and Renewable Portfolio Standards (RPS) to procure low-carbon electricity, even when it is produced at a site that is remote from the point of use. In addition, on-site waste-collection can support medium-term low-carbon energy production through gasification and other zero-emission technologies.
Current limitations on GSA's ability to act within a public-private partnership should be overcome. While privatization is at one end of the spectrum, statutory and/or regulatory changes would enable a balanced approach to serving core government interests while still achieving the flexibility and market-based incentives of a business. An energy-specific version of a Business Improvement District – an Energy Improvement District or EID – may provide one appropriate model. Membership would be shared among Federal, non-profit, commercial, and residential properties within the Ecodistrict. Bylaws could be instituted to protect key Federal priorities, including an appropriate role for GSA given its effective management of the HOTD over the years. An EID would also play a key role in sourcing 3rd-party capital for energy infrastructure, in conjunction with other approaches such as Tax Increment Financing. It may be essential from a commercial perspective that users participating in the energy district would only have to pay for the energy they consume, rather than paying all capital costs upfront.
2) Energy Storage
Thermal storage presents an important opportunity to level both thermal and electric loads and to increase the role of zero- or low-carbon energy sources. With various areas that are planned to be decked over, large-scale storage tanks should be a priority for using those newly-available volumes. Storing hot water overnight would limit the need for dedicated gas or electric hot water boilers in the residential sector during morning peak usage. During cooler weather, storing solar thermal hot water into the evening and overnight would limit peak heating requirements. Chilled-water or ice storage would be even more important, enabling cogeneration to operate overnight with full thermal utilization (i.e. maximum efficiency) during warmer weather, and limiting the peak electricity that would need to be imported from the transmission grid (which is likely to be much “dirtier” power).
These thermal strategies will make the Ecodistrict function as a more unified microgrid, and increase the reward of shared energy infrastructure and district-wide distribution systems. Even if bus parking and other uses limit the use of sub-decking space, architecturally attractive approaches can integrate thermal storage into other public space – such equipment need not be limited to “back of the house” locations.
Electricity storage is a far less mature technology, but some 'future-proofing' may be warranted. For example, any parking facilities should incorporate the infrastructure (mainly conduits) for installing electric vehicle charging station, and extra space that can be converted when needed to switches, transformers, and other equipment designed to access the EVs as battery-storage for the microgrid.
3) Microgrid-ready and District Energy-ready buildings
As part of the Ecodistrict plan – indeed, as an essential element of its very identity – all new buildings and major renovations should be required to be 'district energy-ready'. This means that they design their energy systems from the start to take full advantage of hot-water, chilled-water, and microgrid-based electric service that the Ecodistrict may be supplying. Some of these requirements are relatively minor design decisions that have little or no cost impact on initial construction, but would eliminate costly retrofits when hooking up to the energy district in the future – for example, making sure that heating, cooling, and domestic hot water are all distributed inside the building starting from a ground or basement level, not from the roof, or using 100% hydronic systems for all thermal loads (e.g. instead of electric hot water heaters in each apartment).
Other aspects of requiring participation in an energy district can bring significant savings for new construction. On the thermal side, substantially less space may be required for boilers, chillers, and other mechanical equipment. Rooftops in particular can be converted to premium tenant amenities instead of HVAC systems, and the freed-up space can also support more photovoltaic and solar-thermal collection.
If a building chooses to install its own thermal equipment, or if the Ecodistrict's distribution system does not yet reach a particular building, that equipment can be valuable (and even revenue-generating) by adding surplus supply and redundancy to the Ecodistrict's distribution system. Similarly, it is essential to keep current GSA users on the system; even if they already have or choose to install their own boilers and chillers, such facilities can be used for peaking purposes for the energy district as a whole, as long as they remain connected to the distribution systems.
Not only should the buildings themselves be energy district-ready, but the street grid should be as well. Any new building sites, new excavation, road realignment, and so forth, should be required to include tunnels for both pipes and wires. This underground distribution infrastructure and right-of-way is one of the most important assets of the current GSA-owned system, and should be expanded into every site within the Ecodistrict.
On the electric side, a 'microgrid-ready' building can forgo any back-up or standby generation beyond life-safety minimums, since redundancy and reliability for electric supply comes from the microgrid. But any on-site resources, such as photovoltaics or energy-from-waste, can be integrated more easily into a microgrid than directly into the utility grid, especially when using a “non-synchronous” approach to set up the microgrid. Utility hook-ups (such as transformer vaults) should be made easily accessible to the Ecodistrict's own electric distribution, for example from the HOTD central plant. We would note that the larger-scale PV installations contemplated in the plan, such as along the Southwest Freeway, will also be far easier to integrate into a microgrid, avoiding interconnection issues with Pepco.
More important, a microgrid (or multiple connected microgrids) within the Ecodistrict would mean far lower costs for utility upgrades, substation expansion, new distribution systems, and so forth. The NCPC should solicit early support from Pepco, as the utility has to be part of the stakeholder group from the very beginning. The Ecodistrict would also benefit from a push for new regulations that would permit utility ownership of microgrid assets with appropriate tariffs. Whether by utility ownership or otherwise, an appropriate mechanism must be implemented to make sure that the significant savings from not having to build out the utility grid can be re-directed toward the microgrid alternatives that would avoid those costs.
Our compliments on a great start to an exciting future.
Sincerely,
Shalom Flank, Ph.D.
CTO & Microgrid Architect
Pareto Energy LTD
He uses the phrase "gasification and other zero-emission technologies." Gasification is a type of incineration (that operates in two stages, first turning the fuel/waste into a gas, then burning it) and is recognized by the U.S. EPA (and the E.U., for what that's worth) as incineration. It most definitely is NOT zero emission. Its emissions are quite comparable to conventional style incinerators, and its use for "biomass" and municipal waste is still fairly experimental, with many problems plaguing facilities that try to operate on a commercial scale -- causing the few that have tried to operate commercially to close down due to financial or technical problems or both.
He recommends "biomass and energy-from-waste." "Energy from waste" is merely a PR term for waste incineration, primarily used by Covanta -- the nation's largest trash incineration corporation -- one with quite a history of environmental violations. None of these technologies are appropriate if the project aims to reduce greenhouse gases and toxic emissions. Energy Information Administration data also shows biomass and trash incineration to be the most expensive forms of energy there are -- even more than nuclear and solar. See MSW (municipal solid waste incineration) and biomass costs in: "Updated Capital Cost Estimates for Electricity Generating Plants," Energy Information Administration, November 2010, p.7, Table 1. http://www.eia.gov/oiaf/beck_plantcosts/ (direct link: http://www.eia.gov/oiaf/beck_plantcosts/pdf/updatedplantcosts.pdf).
including the three level underground parking lot that will be beneath Banneker Overlook Park.
All the more reason is it highly insulting, not ot mention, execruciatingly painful to bear the insult of systematic exclusion and being erased from histoic record the closer the project comes to fruition and completion. This is one of the most offensive aspects of gentrification.
Mr. Banneker, who also drew 16th Street as the Meridian and "spirtual center" of the nation's capital, over two centuries since he helped create Washington, DC as we know it, and the Washington Interdependence Council which has made major contributions of this SW EcoDistrict Plan, as outlined herein, boith deserve much better than it has gotten and we ask for America to do the right thing by African-Americans who have made major contriubtions to the privileges and benefits that everyone but them seem to enjoy in this country. If the nation's capital has no moral compass or fortitude, how will the country overall exhibit any when the message is: Let's symbolically, and pragmatically continue modern day slavery. It's a no-win formula, no matter how pretty it looks on paper.
However, as the private organization which has worked for 15 of our 16 years as the facilitators of the planning and funding focus for this "top priority" revitalization, the L'Enfant Plaza/Benjamin Banneker Overlook Park connective corridor, it is amazing and highly insulting that there is no mention of the Washington Interdependence Council's civic work as the faciltators and creative contributors to the embraced vision for transforming this critical corridor into an inviting, lush parklike setting to lure pedestrians from the Mall to the new and improved Banneker Memorial and further on to the new multi-billion dollar waterfronts.
It was the Washington Interdependence Council too which recommended the removal of the U.S. Dept. of Energy's Forrestal building obstructive overpass to open up the vista to the frontal view of Smithsonian Castle.
The Washington Interdpendence Council spent three years lobbying the National Park Service; DDOT [then called the District Dept. of Public Works]; the Federal Highway Administration [the underwriters of the renovation via its TEA21 program] to commence with the massive transformation of this "top priority" area in the the SW EcoDistrict plan; to provide funding for the rehabilitation of this area "to make way for the Banneker Memorial." Yet, there is not one word of mention of our 15 years of work as facilitators of this en progress work as it continues to move forward a hard earned decade and a half later.
There is no mention of the Benjamin Banneker commemorative initiative there, even though the Washington Interdependence Council's name, as facilitators, is on the cover, and are signatories on the Memorandum of Agreement signed on January 12. 2000 by all five partnering agencies to move forward with the proposed vision of improvements.
The Washington Interdependence Council's name is on the first phase of the detailed plan, the L'Enfant Promenade Urban Planniing Study; the second phase document, the L'Enfant Promenade and Benjamin Banneker Park Environmental Assessment for Improvements to the L'Enfant Promenade and Benjamin Banneker Park; and the FONZI [Finding of No Significant Impact] stamp of approval for the proposed overhaul. The agency's name is on those documents, as the only none governmental agency, because its work as a non-profit facilitator, forged those renovative actions as a result of its persuasive proposal to have the funding federal agency, the Federal Highway Administration, to pay to renovate the project area. Our agency was also a full work committees participant over the years, to advance the vision, and helping to co-author those documents, etc.
As the only agency whose executives received no compenseation for these many years of work in not only working to help create these documents laying the foundation for the now en progress reconstruction of this site; AND as the procuring agency of its primary funding which paid agencies such as Parsons Brinckerhoff Quade & Douglas, Inc. and HNTB Architects Engineers Planners et al to help carry this vision forth to its present phase of matriculation, it is very insulting, as the progenitators of this "top priority" area overhaul to receive no credit, acknowledgement nor support for the initiative they have been pursuing for 16 years, the Benjamin Banneker Memorial, which facilitated the possibility of this reconstructive renovation of the key half mile corridor in the way it has successfully advanced forward towards completion circa 2016.
Our agency, from the outset of our commeorative endeavor, indicated that we wanted to upgrade L'Enfant Plaza/Banneker Overook Park to a world class memorial honoring Benjamin Banneker; and thereby sought out the federal funds from the U.S. Dept. of Transp. to do so, in order to defray the cost of the commemorative effort extensively. We later added, as a part of its commemorative design, the Benjamin Banneker Institute of Math & Science Technology, training America's youth from age seven on through to high school [a sort of feeder school to colleges and universities] as leaders in the STEM [Science, Technology, Engineering and Math] disciplines. This is espoused as an American priority,along with a 30-40 foot ClockTower, Founding Father's Visitor's Center and Open Air Overhead Canopy to protect pedestrians from the elements.
We further recommended that the entire corridor of the L'Enfant Plaza corridor serve as "Founding Fathers" walk to tell the story of the eight men [George Washington, Thomas Jefferson, Thomas Johnson, Daniel Carroll, David Stewart, Major Andrew Ellicott, Benjamin Banneker and Charles Pierre L'Enfant] who created the new Federal City as the seat of government in 1791.
We also urged the DDOT and the DC Dept. of Planning and the National Park Service to add a pedestrian overpass to Banneker Overlook Park to carry pedestrians, especially physically challenged and bikers all the way across Maine Ave. on over to the marina. It was, and still is our position that the reason the corridor failed in the first place in terms of faciliting the safe navigation of pedestrians from the Mall to the waterfront was due to the fact that its a terminus. It's a terminus that stops just short of its mission to provide safe passage of persons traversing from the Mall to the waterfront. This was a major selling point in our original proposal which providing the funding and planning for this key area's upgrade. It has yet to be publicly declared a part of the renovation of the project area, and we feel, as some others commenting has expressed, essential to the success of the corridor as a future "gateway" link between the Mall and marina.
The Washington Interdependence Council serves as advocates of the importance of symbolic diversity within the public landscape of America. That is our mission, and is stated as such in our mission statement. This is why we elected to upgrade Banneker Park, as an official memorial to this great colonial American hero, as authorized and designated by the U.S. Dept. of the Interior in 1971, prior to the establishment of the current commemorative oversight agencies such as the National Capital Memorial Commission.
Benjamin Banneker is one of the Founding Fathers of the nation's capitol, and as the surveyor, astronomer and technical and engineering co-planner of the "Federal City" determined the location of the White House, the Capital, the Washington Monument, the Treasury Building and the area contained within the 40 marked Boundary Stones outlining the new Federal City. As such, he deserves the upgrade of the site already named in his honor. If America and the agencies overseeing his current memorial site do not honor his legacy by supporting the upgrade of his commemorative site to a world class memorial versus the desecration of his memorial with other "more important" endeavors, it will be a HUGE MISTAKE.
And that's not the mention giving proper respect and acknowledgment to the Washington Interdependence Council's work in moving the above mentioned embraced and adopted contributions towards the SW EcoDistict Waterfront project forward as well. Must the madness of systemic exclusion based on skin color continue to stain the merit of intended sound and beneficial efforts?
As advocates of the symbolic importance of diversity in the public landscape, it was also the Washington Interdependence Council's idea to have the replica of the Pearl Schooner, the ship with provided transportation for the largest attempted escape by sea of the 77 enslaved persons who sought freedom by leaving out, under the cloak of darkness, from their imprisonment camps to meet up at 7th & Maine Ave., SW to flee to what they had hoped would be freedom. Unfortunately, a storm ensued, and traitors reported them and they were captured at sea and brought back to suffer the consequences of their actions. This was a very historic moment in history and the replica of the Pearl Schooner as a tourist attraction, similar to the Amidon Schooner, would be another excellent cultural offering on the southwest waterfront. I enlisted the late Lloyd Smith, former CEO of the National Capital Revitalization Corporation, which I served as his Southwest Waterfront Consultant for, to take on this project after his retirement from this agency which jump started the SW EcoDistrict renovation.
Also, black and other dieadvantaged businesses should have ownership in initiatives such as the Banneker Memorial and Pearl Schooner, not just work as employees. With no ownership, and no power to voice the stories about blacks being told renders the efforts null and void anyway regardless of if they are "usurped" by others as has the Pearl Schooner project and the on-going onslaught of sabotage and disenfranchment that has been the hall mark of the Benjamin Banneker Memorial experience as we are disrespected, written out of the picture and documentation process, discredited and overall treated persona non grata by the powers that be and the powerful developers who can never get enough. This document, as is, I feel is a testiment to that disservice.
This 50+ year cycle of imperialistically designed gentrification should be mindful of making the same elitist, exclusionary and unjust mistakes which are common to this process time and again. It will behoove the country and its citizenry to take the higher ground and do the right thing, especially by those interests like the Washington Interdependence Council which has more than paid its way for a respectful seat at the table in this en progress SWEcoDistrict Plan. Thank you for your consideration.
But the 1/2 mile or so between the end of the 15th St. Cycle Track at Penn and the connection to the 14th St. Bridge/Rock Creek Park Trail/East Potomac Park is horrifically cycle-unfriendly--the roadway is narrow with no parking lane and no shoulder to speak of and is filled with speeding cars heading onto the freeway, and the sidewalks are off limits to bikes. There is no way to return northbound into the city without violating the law by riding on sidewalks because Basin Drive is one way southbound. All of this is not to mention the deplorable condition of the roadway at Maine Ave and Ohio Drive.
There is also no safe way to reach the Anacostia Riverwalk Trail from the Mall.
We have such great facilities; it is frustrating to see them underutilized (particularly the Anacostia Riverwalk Trail) because they are unsafe to approach.
The plan has specific numerical targets for waster, energy, and potable water. Why not set one for stormwater, as well? Zero net runoff, for example, or that the district will capture and reuse and/or infiltrate 75% of all annual rainfall. This would help to set targets for each of the individual developments (buildings, roads, memorial sites, etc) and better convey the cumulative impact.
One measure that I wholeheartedly support as vital is an area of underground parking for tour buses. The current situation on the National Mall is that there are hundreds or even thousands of tour buses every day that line Madison and Jefferson Drives fouling out air with their idling engines, illegally parking in bus pick-up and drop-off zones, blocking the sweeping views and designed sight-lines across the Mall from the sidewalks, making so much noise that it erases any possible sound of nature within this national park, and also creating a dangerous hazard for pedestrians and bicyclists. Whereas any visitor to the National Mall that arrives via Metro or other public transportation option is expected to walk from museum to museum, visitors who arrive by tour bus expect to be chauffered from the door of one museum to the door of the next.
The appropriate solution is to have a large, central underground parking garage within walking distance from the National Mall and to expect tour bus visitors to walk to and from that location to the museums and other attractions. Tour buses should then be banned from picking up, dropping off and parking on the National Mall. A fee of $25 - $50 (or whatever is economically appropriate for the unsubsidized operation of this parking garage) could be charged for tour bus parking at this location.
For those passengers that are handicapped, there could be complimentary shuttles from this location to the various museums.
Every visitor's experience of the National Mall is diminished by these loud, polluting, ugly, traffic-clogging, dangerous tour buses. I hope the SW Ecodistrict plan will include enough parking for a centralized, nearby location where these buses can park en masse and leave the National Mall in peace.