Panda Perkiomen Power Project

In July, 1999, Panda Energy International of Dallas, Texas, established in 1982 as a privately owned developer of cogeneration projects, announced their intentions to construct a 1,000 megawatt combined cycle natural gas-fueled electric generating facility in the Upper Perkiomen Valley. Panda Energy International has obtained a 3-year option to buy the John Wentz farm located at 1305 Stauffer Road, Palm, PA - the proposed site for the merchant power plant. This tract consists of 14.13± acres located in the Highway-Commercial district of Hereford Township (Berks County), 21.98± acres located in the R1 (agricultural-low density residential) district of Upper Hanover Township (Montgomery County), and 65.89± acres located in the Limited Industrial-Commercial district of Upper Hanover Township. Partners for Community Preservation opposes this project since it is fundamentally a development which is neither permitted by right nor appropriate for these zoning districts of Hereford and Upper Hanover Townships.

The Panda Perkiomen project is anticipated to utilize 35± acres of the 65.89± acres located in the LIC district of Upper Hanover Township, abutting the Palm Schwenkfelder Church property and a portion of the village of Palm’s residential community. This tract of land, part of a sub-basin for the Perkiomen Creek watershed, is an environmentally sensitive area containing wetlands, floodplains, and alluvial soils - an important part of the hydrologic cycle, riparian corridor, and wildlife habitats.

The generation facility will consist of 4 combustion turbines, 4 heat recovery steam generators, 2 single-casing condensing steam turbines, circulating water cooling towers, a raw water storage tank, and 4 combustion stacks approximately 190-feet in height. The power plant will also require 6.5 to 8 million gallons of water a day to generate electricity. The Upper Perkiomen Valley already suffers from strained groundwater supplies. To meet these limits, Panda is proposing to construct an 18-mile pipeline to carry treated effluent from Kline’s Island, a wastewater treatment plant located on the Lehigh River, Allentown, PA. Water piped to the Panda Perkiomen plant will be converted to steam during the electrical generation process. This will result in a by-product of 1.6 million gallons of polluted water requiring treatment and ultimate discharge into the Lehigh River via a second pipeline.

Delaware River Basin Commission (DRBC)
The Delaware river is fed by 216 tributaries, the largest being the Schuylkill and Lehigh Rivers in Pennsylvania. The DRBC has interstate authority to review, grant approval, and levy charges for any water use plans which withdraw more than 100,000 gallons of water a day. The DRBC has also designated the majority of southeastern Pennsylvania as a Groundwater Protected Area. Within this Protected Area there are lower water withdrawal permit triggers, and withdrawals are viewed on a cumulative basis by subwatershed. The Groundwater Protected Area covers all of Montgomery County, Hereford Township, and Lower Milford Township.

Upper Hanover Township Comprehensive Plan
Among the key objectives for the Upper Hanover Township Comprehensive Plan are:

1. Directing growth to appropriate areas that will have a minimal effect on the the Township’s natural resource system.

2. Identifying and protecting significant historical and cultural resources of the Township.

3. Striving for compatibility with the character of adjacent communities.

Upper Hanover Township Zoning Ordinance
The Limited Industrial-Commercial district of Upper Hanover Township does not include electrical generation facilities as a permitted use by right. Section 1701.8 empowers the Board of Supervisors of Upper Hanover Township to grant conditional use for a public utility (including buildings to house equipment and operations for electric service) only if, upon thorough examination, the land development is deemed to be consistent with the public interest and general welfare. A conditional use land development must demonstrate that it does not substantially injure or detract from the use of surrounding properties or character of the neighborhood, and the use of adjacent properties must be adequately safeguarded.

Montgomery County Initiatives
Under the Agricultural Preservation Program, the development rights for the adjacent tract of land, owned by Henry Fretz and located within the LIC district, have been transferred to Montgomery County - permanently protecting a large portion of this LIC district. Through a joint municipal effort Montgomery County has also preserved the nearby Mill Hill property under their Open Space Program and is actively pursuing the preservation of the land known as Lesher’s Mill which is adjacent to the portion of the John Wentz tract located in the R1 district.

Stormwater, Erosion, and Sedimentation Initiatives
Slope, soils, geology, and climate contribute to the rate of watershed runoff. The rapid expansion of impervious cover in urban and suburban areas has increased the difficulty for rainwater to recharge the groundwater. If impervious cover exceeds 10% to 15% of the total surface area of any watershed, the rate and volume of this runoff dramatically increases. Development sites are often evaluated as if standing alone and not in the context of adjacent land uses - land and water usage must be managed as interdependent resources. The Perkiomen Creek (the largest tributary to the Schylkill River) and the Schylkill River are suspected to be major contributors of nonpoint sediment pollution to the Delaware River Estuary. This is due in part to poorly maintained construction sites resulting in sediment choked streams, severely eroded streambanks, and sediment smothered stream bottoms.

Comprehensive watershed management strategies should incorporate water quality, quantity, surface water, groundwater, aquatic ecosystems, and natural diversity considerations. If we respect the natural value of our groundwater, streams, and riparian corridors our communities will be more desirable.

Wetlands and Riparian Buffers
Riparian corridors are defined as areas of native vegetation surrounding water bodies. Along with wetlands they intercept surface water runoff, wastewater, subsurface flow, and deep groundwater flows from upland sources. This serves to remove or buffer the effects of associated nutrients, sediment, organic matter, pesticides or other pollutants prior to entry into surface waters. When wetlands and riparian buffers are filled in or paved over by developers, the loss of the natural filter capacity of these areas compromises our clean water supply. The habitats of plant and animal species could also be jeopardized.

Biodiversity
Pennsylvania Natural Diversity Inventory (PNDI) is a database containing records of occurrences of rare/endangered species of flora and fauna and important natural communities. This database is regularly used by the state’s permitting agencies to determine if actions affect PNDI sites. There is no guarantee that PNDI sites will be protected. If a community desires to preserve or protect these significant natural areas, it is recommended that municipalities exercise existing powers granted under the Pennsylvania Munic-ipalities Planning Code to provide such protection through their Comprehensive Plan, Zoning Ordinance, SALDO, and Open Space Plan. A species categorized as "threatened" on the U.S. Endangered Species list and "endangered" on the Pennsylvania Endangered Species list exhibits historical occurrences and has been verified as present within proximity of the Panda Perkiomen site since 1980.

Emissions
Montgomery County is presently designated as a federal nonattainment area for the pollutant ozone which is formed by the combination of heat and nitrogen oxide emissions. The exhaust emissions from the Panda Perkiomen combustion stacks would contribute a combined total of over 3,000,000 pounds per year of criteria air pollutants consisting of carbon monoxide, nitrogen oxides, sulfur dioxide, particulate matter, and volatile organic compounds. With emissions of nitrogen oxides in excess of 461 tons per year and VOCs in excess of 65 tons per year, the Panda Perkiomen facility is subject to the New Source Review requirements which are triggered at 25 tons per year for NOx and VOC emmissions in a severe nonattainment area. Based on the NOx and VOC levels, the Panda Perkiomen facility must also secure Emission Reduction Credits of 596 tons per year of NOx and 85 tons per year of VOCs.

The combustion emissions will also contain quantities of hazardous air pollutants including (but not limited to) lead, mercury, and arsenic. Under certain weather conditions, the cooling tower exhaust will appear as a large, white, vapor plume before it dissipates. Due to the use of effluent in the cooling process, there is also potential chemical and biological contamination resulting from the vapor plume fallout as the discharge is carried beyond the plant site.

On-Site Storage of Hazardous Materials
The Panda Perkiomen facility proposes on-site storage of liquid ammonia, sulfuric acid, and caustics. Tanker trucks are anticipated to arrive at the power plant approximately every 2 weeks to deliver the hazardous materials. Solvents and liquids associated with non-residential development can leak or spill onto the ground, and eventually reach the groundwater.

Deregulation of the electric utility industry has created a financial bonanza for independent power producers competing to build power plants on greenfield sites. There is no guarantee that the electricity produced at the Palm location will be utilized by residents of the Upper Perkiomen Valley - the PJM (Pennsylvania/New Jersey/ Maryland) power grid serves a wide area and it is very likely that the electricity produced by Panda Perkiomen would benefit customers in other distant locations while adversely affecting the environment and character of the Upper Perkiomen Valley.

Upper Hanover Township should embrace wise land management practices by focusing on the preservation of the natural resources that have defined and enhanced the community since the first settlements appeared. The electrical generation project proposed by Panda Energy International represents unsuitable land development in an inappropriate location.