Bad news from Huffington Post: The Canadian Arctic has reached the highest temperatures in at least 44,000 years. Gifford Miller, a researcher at the University of Colorado, Boulder, says, “This study really says the warming we are seeing is outside any kind of known natural variability, and it has to be due to increased greenhouse gases in the atmosphere.” This study reaffirms that global temperatures are rising at an unprecedented rate: we’ve seen a warming trend for the past century, but the process has been accelerating significantly since the 1970s and has skyrocketed in the last twenty years. Miller didn’t end on a happy note. “We expect all of the ice caps to eventually disappear, even if there is no additional warming.
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More than 300 people attend Calvert County town hall meeting concerning controversial proposal to export fracked gas from Maryland to Asia
The first town hall meeting concerning the risks of the proposed Cove Point LNG export terminal in Maryland was held Tuesday night, October 23. It was a big and rousing success. At least 300 people attended, most of them local residents. It was held at the Southern Community Center in Lusby, Md. in Calvert County, just a few miles from where Dominion Resources wants to build an industrial terminal to export fracked natural gas — piped in from Appalachia — and ship it to India and Japan. The $3.8 billion facility would chill the gas to 270 degrees below zero, turning it into liquid for 1000-foot-long shipping tankers coming into the Bay. It would generate 3.3 million tons of CO2 pollution per year. (You can learn more about the health and environmental risks of exporting fracked gas from Maryland by clicking here.)
Weekly Climate Insider: Green Business, VA Hybrid Tax and Power Shift!
Welcome back to the Weekly Climate Insider!
In Maryland, fracking and the results of the Environment America study posted in last week’s Climate Insider are still making headlines. As a recap, the report found that our water supply is put at risk by the billions of gallons of dirty wastewater produced by fracking. See the coverage from Capital News Service.
This week, we’re profiling two Maryland businesses that are environmentally newsworthy.
A Maryland construction company called Hobbitat builds small houses made out of reclaimed materials. The 250 square foot houses, called “hobs,” are made almost exclusively from from salvaged or repurposed materials, nearly eliminating the adverse effects of new construction. In energy terms, “The hobs’ square footage is about 11 percent of the median U.S. house size, so much less energy is required to heat and cool them.” Check out some photos of these gorgeous little hobs!
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Presenting: The Weekly Climate Insider
In the fight against climate change and dirty energy polluters, there’s a lot going on. Some of it is good — take the global boom in solar power and its increasing affordability. Some of it just encourages us to push harder and faster. But whether the news is encouraging or frustrating, local or global, knowledge is power. That’s why we’re bringing you a new recurring blog post from CCAN: The Weekly Climate Insider.
Every week, we’ll keep you in the loop with important climate stories impacting Virginia, Maryland, Washington D.C. and beyond. We’ll touch on big issues in our campaigns, like the threat of fracking and sea level rise, and we’ll also bring you broader climate news.
Let’s get started.
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Plan for chicken litter energy plant in Maryland lacks certainty, includes errors and contradictions, and could make greenhouse gas pollution worse
Plan for chicken litter energy plant in Maryland lacks certainty, includes errors and contradictions, and could make greenhouse gas pollution worse
A memo from the Chesapeake Climate Action Network on the “Delmarva Bio Energy Plant” proposed by the company Green Planet Power Solutions
Oct. 1, 2013
Overview
A California-based company’s written plan to convert chicken litter to electricity on Maryland’s Eastern Shore includes numerous contradictions and errors, would involve the combustion of large amounts of wood waste, and could emit significant amounts of global warming pollution. These concerns emerge from a close examination of the 81-page proposal selected by a Maryland state agency to potentially construct the first poultry waste power plant in the state.
In June 2013, a group of concerned Maryland health and environmental groups submitted clarifying questions directly to GPPS, the company proposing to build the poultry litter energy plant. (See Appendix 2 for a copy of those questions.) To date, GPPS has not responded. Absent such a response, and considering CCAN’s specific concerns about climate change, we decided to perform this analysis in order to focus on the potential greenhouse gas emissions from the project. As we reviewed the proposal, we noted other areas of concern as well.
The proposal from GPPS is dramatically short on specific technical details related to the type and characteristics of the fuels the plant would burn. It also lacks specific information on key pollution-reduction technology the plant would employ. As part of a 2011 Request for Proposals (RFP), the Green Planet Power Solutions (GPPS) company submitted its proposal to the Maryland General Services Administration to build a “biomass” plant of up to 20 megawatts in size. In January 2013, the GPPS proposal was selected for a Power Purchase Agreement (PPA) commitment from the state covering 13.4 megawatts of the power generation, thus guaranteeing a state-funded market for most of the plant production.
Various elected officials and agency leaders have expressed support for a chicken waste power plant. Supporters assert that the combustion of chicken litter will lead to generation of “green” renewable energy while simultaneously preventing millions of tons of manure pollution from washing into the Chesapeake Bay from the over application of litter as fertilizer in the Bay watershed. However, several concerns associated with the GPPS power plant proposal lead us to question whether the GPPS project would accomplish these goals.
Three major concerns: Company expertise, wood waste factor, and carbon pollution
First, GPPS has no direct experience themselves in constructing and operating biomass plants of any kind, much less one containing state-of-the-art pollution-reduction features as promised in its proposal.
Second, the proposed plant would burn nearly as much wood waste as poultry litter. The company has proposed combusting approximately 56 percent litter and 44 percent wood waste. In terms of the litter quantity, GPPS’s proposal gives different amounts: “greater than 50%,” 56 percent, and 60 percent. At best, the facility is a hybrid plant with barely half the consumed fuel able to address the targeted waste problem from chickens. In addition, the GPPS proposal actually states that the plant will consume 150,000 bone dry tons of wood fuel per year, enough to actually power all 20 megawatts of generation. Either this is an error or the plant developers anticipate the possibility that the plant will at times run entirely on wood fuel, if built.
Third, the proposed power plant raises major carbon pollution concerns. Any facility that combusts bio-fuels like chicken litter or wood waste runs the risk of emitting high amounts of greenhouse gases. The key to climate-friendly, low-carbon energy generation from bio-fuels rests heavily on the type of fuel used, the careful accounting of the “life-cycle” carbon budget of that fuel, and the use of appropriate technology at the point of conversion to energy. Unfortunately, GPPS, in its proposal, erroneously declares wood waste and chicken litter to be “carbon neutral” with no scientific grounding.
In reality, due to challenges from concerned communities and scientists, the EPA is currently revising its evaluation of bio-fuel carbon emissions. EPA’s own Science Advisory Board (SAB) asserted there are numerous factors such as the inherent differences in the carbon cycle regeneration rates for different biomass energy sources that must be addressed before determining any possible “carbon neutrality.” Also, the potential long-term tradeoffs of storing biogenic feedstock versus immediate or near-term combustion must be considered. If a power plant uses low-efficiency technology to burn whole trees from forests that will not be quickly replenished, then the carbon emissions may be worse per unit of energy produced than burning fossil fuels. Even so-called wood waste, as GPPS proposes to burn, can generate carbon emissions at a higher and unsustainable pace than if the wood were allowed to naturally decompose. Again, GPPS claims that its wood waste combustion will be carbon neutral or better, but this cannot be confirmed until the company carefully details the source of its wood fuel and until credited, up-to-date, life-cycle calculations from the EPA are complete.
Similar carbon concerns apply to the greenhouse gas emissions from chicken litter combustion. It also requires emerging EPA guidance to confirm the life-cycle carbon benefit of litter combustion. As with wood, it is not acceptable to simply declare that combusting chicken litter is automatically carbon neutral.
In order to reduce emissions of nitrogen oxides (including the powerful greenhouse gas nitrous oxide), GPPS has included in its proposal the use of a Selective Non-Catalytic Reduction (SNCR) system. This is a promising technology and must be a mandatory part of any proposal moving forward.
A final air quality concern involves particulate matter. The GPPS proposal gives highly divergent numbers concerning the fine particulate matter (ash) that would escape from the plant. The contradictory reporting of this data in the proposal deepens our concern about the firm’s ability to build such a plant.
Conclusion: CCAN’s research into this project reveals that significant additional study and revision is needed before large-scale manure-to-energy systems, like the one proposed by GPPS, can be responsibly developed in Maryland.
APPENDIX 1 – Detailed Areas of Concern
Management: While GPPS claims to have other proposed biomass energy projects, none of them have been brought to fruition. GPPS alone has no experience in the renewable energy business, leaving it entirely dependent on its project partners to complete and maintain the power plant.
Technical: Both Governor O’Malley and Attorney General Doug Gansler have lauded poultry waste-to-energy as a solution to agricultural runoff in the Chesapeake Bay. Yet, the proposed plant will be fueled by 44% wood waste instead of by poultry litter alone. Wood waste and poultry litter have drastically different properties. Their impacts on the environment and health of the community must be addressed individually.
The proposal never clarifies the contents of the chicken litter and wood waste the plant intends to burn. Chicken litter is a mixture of poultry manure, spilled feed, feathers, and materials used as bedding. The nutrient content of the litter may vary tremendously depending on the facility c
leaning technique, storage methods of litter and other factors.1 Wood waste ranges from whole tree branches, pallets, untreated used lumber, to urban wood waste that has been treated with toxic chemicals. The environmental and health impacts of burning different types of wood waste vary significantly.
GPPS claims the litter and wood waste it will acquire has an average moisture content of 10 percent. That is unattainable. According to study from the University of Florida, in a well-managed broiler house, litter moisture averages between 25 to 35 percent.2 GPPS makes no distinction if the wood waste is dried or undried. Undried wood is typically known as “green” wood. Since drying wood requires additional process, wood used for biomass burning is typically undried.3 The industry standard for “green” wood has a moisture content of 45 percent – much higher than the suggested 10 percent.4
The proposal claims a total of 150,000 BDT of wood waste. That amount alone is enough to power a 20MW biomass power plant, with no chicken litter at all.5
Technology: The proposal asserts the plant will include an electrostatic precipitator to collect dust, ash, and other impurities from the industrial process. Then, two paragraphs down, it states the boiler exhaust will be directed through a traditional fabric filter, also known as baghouse, to remove ash. These are two vastly different types of dust collectors, varying widely in design, operation, effectiveness, and costs.6 The selection of dust collector is critical in determining particulate matter emissions. This inconsistency of a critical component of the plant system cannot be ignored.
Location: The site of the project written in the proposal, Frank M. Adams Industrial Park, is located 1.5 miles from Federalsburg Elementary School. It is our understanding that since submitting their proposal, staff members of GPPS have verbally stated they may move the facility to a location in Salisbury. Either way, air pollutants such as particular matter and saw dust can pose serious public health concerns for the local community.
Permitting: In its proposal, GPPS asserts that “biomass power production facilities fewer than 50 MW are not considered a power producing utility and are not subject to U.S. EPA or Maryland State statutory responsibility for licensing power plants.” This is false.
According to the Maryland Public Service Commission, the definition of a “generating station” in the Code of Maryland Regulations (COMAR 20.79.01.02(B)(11)(b)) excludes units with a capacity less than 0.373 MW. The Delmarva Bio Energy Plant is 20 MW and thus subject to the Certificate of Public Convenience and Necessity (CPCN) process. GPPS may apply for an exemption if at least 10 percent of the electricity generated at the generating station each year is consumed on-site.7
U.S. EPA’s regulations and standards of renewable fuels are separate from those applied to traditional fossil fuels. The permitting programs under the Clean Air Act (CAA) applies to all biomass power plants with no MW minimum. In addition, the proposal references EPA’s three year deferral of its GHG permitting program for its lack of carbon dioxide emission controls. In fact, as of July 2013, the U.S. Court of Appeals for the District of Columbia Circuit found that EPA failed to justify its 2011 decision.8 The Delmarva Bio Energy Plant will have to obtain Prevention of Significant Deterioration (PSD) and Title V Operating Permits to ensure all air quality standards are met through the installation of Best Available Control Technology (BACT) and comprehensive air quality analysis.9
GHG emissions: Although the proposal argues that “if left unabated, the biomass materials would emit substantially higher levels of GHG (carbon dioxide, methane, and nitrous oxide) as a result of their biodegradation in landfills or in the forests, or from their open-burning in agricultural fields or in the forests,” the carbon neutrality of biogenic carbon sources cannot be assumed.
CO2 emission lb/MWh at point of combustion10
Proposed Plant: 3,328
Coal Plants: 2,249
Natural Gas Plants: 1,135
Solid-Waste Plants: 2,988
EPA’s own Science Advisory Board (SAB) asserted there are numerous factors such as the different time scales inherent in the carbon cycle and the potential long-term tradeoffs of storing and burning biogenic feedstock that must be addressed to determine the full carbon cycle of different biomass energy.11
Considering only the point of combustion emissions, this plant would emit more carbon dioxide than average fossil fuel and solid-waste power plants according to GPPS’ own estimates. According to the proposal, Delmarva Bio Energy Plant plans to emit 3,328 lbs of CO2 per MWh with a total of 80,592 MWh guaranteed firm annual energy, thus producing 268,210,176 lbs (134,105 tons) of CO2 per year. That is equivalent to an additional 26,295 typical passenger cars on the road every year.12
It’s possible that net carbon emissions would be much lower over a specified lifecycle. But those lifecycle emissions need to be established by the applicant and can’t simply be assumed.
Other toxic pollutants emissions: The proposal includes two particulate matter 2.5 (PM2.5) emissions estimates. Under the “Project Fuel Plan” section, PM2.5 is recorded at 7.89 lbs/ton. Later, the summary attachment puts emission at 0.00000789 lbs/ton. This is an enormous difference and must be addressed by GPPS. PM2.5 should also be expressed with standard units of lb/MMBtu boiler capacity.
Other emissions include volatile organic compounds, and ammonia. Such pollutants cause serious health problems such as aggravated asthma, decreased lung function, heart attacks, nausea, and damage to the liver.13
Details of the Delmarva Bio Energy Plant
According to GPPS’s proposal, the plant will:
- produce 20 megawatt (MW) gross electrical output fueled by roughly 56% chicken litter and 44% wood waste,
- utilize a fluidized bed advanced stage gasifier system, considered the Best Available Control Technology (BACT), as well as a selective non-catalytic reaction (SNCR) NOx control,
- be built on a 21-acre land located in Caroline County,
- seek to qualify as a Tier-1 renewable energy facility under the RPS,
- cost $2.4 million and 17 to 19 months to construct, and be expected to produce commercial electricity by December 31, 2015.
Green Planet Power Solutions Team
- Green Planet Power Solutions (GPPS) is a privately-held renewable energy company founded in 2008 in Northern California. In addition to Maryland, the company currently has proposed projects in California, Delaware, Oregon, Texas, Louisiana, Nevada, and Hawaii. Alone, GPPS has no experience in the renewable energy business and is described as the “Project Sponsor.”
- Industrial Power Technology (IPT) – Owner’s representative (design engineering advisor). IPT has worked on projects in the US, UK and China, utilizing a wide variety of fuels and energy systems including natural gas, coal, digester gas, urban waste, scrap tires, biomass, and agricultural waste.
- Energy Products of Idaho (EPI) – Technology provider (EPI was acquired by Finnish resource technology company, Outotec in December 2011, after the proposal was submitted). EPI installed the first c
ommercial fluidized bed system in the US and has manufactured nearly 100 systems providing over 5 million hours of operating experience:- First fluidized bed utilizing biomass (wood) – 1973
- First biomass fluidized bed retrofit of stoker coal boiler and use of inbed heat transfer surface – 1981
- First commercial fluidized bed biomass gasifier (district heating) – 1983
- First commercial fluidized bed biomass gasifier power plant – 1985
- First biomass advanced staged gasifier – 2002
- First biomass staged gasifier retrofit of stoker boiler – 2006
- ProEnergy Services – Engineering, Procurement, Construction (EPC) contractor
- Gray Construction – General contractor
- National Real Estate Advisors – Financing partner
- Green Sensitive Design (DSD) – Permits handler
Staffing Overview
- Robert Walther – IPT CEO, Chairman of the board/engineer, responsible for all site design, interconnection development, balance of plant and fuel handling. A professional engineer & certified plant engineer.
- Steve Carpenter – GPPS CEO, the leading negotiator and contact of the project. An experienced real estate broker and investor. Contact information: 530-368-0984 / steve@stevecarpenter.com / steve@greenplanetpowersolutions.com.
- Mike Colomb – GPPS President of New Business Development, responsible for sourcing new locations and fuel sources.
- Joe Burns – GPPS President of Operations.
- Doug Gray – President of Gray Construction.
- Coleman Cassel – GPPS President of Strategic Development, new business and contract negotiation.
- Dave Clark – corporate attorney.
The Project
- Fuel: GPPS will obtain approximately 177,000 bone dry tons (BDT) of agricultural waste products (poultry litter as well as wood waste) annually that have heating values of 8,400 Btu/lb (bone dry) with an average moisture content of 10% based on a bone dry ton measurement.
1. Chicken litter supplier – Ellis Farms: An East Coast shores premier supplier of poultry litter, servicing nearly 500 farms in Maryland. GPPS has signed letter of intent (LIO) from Ellis Farms for the delivery of over 100,000 tons of litter.
2. Wood waste supplier – Vision Forestry: Manages over 55,000 acres of forestry for a variety of clients in Delaware, Maryland, and Virginia. GPPS is under negotiation for approximately 75,000 bone dry tons annually for a 20 year term.
3. Wood waste supplier – Eastern Shore Forest Products: GPPS is negotiating for an additional 75,000 bone dry tons annually. - Timeline: GPPS originally anticipated commencing commercial operations in Q2 2014, filing permits in Q2 2012, receiving permits in Q3 2012, and begin construction by Q4 2012. Currently, they are still looking for boiler technology and has not filed for any permits. The power produced will be directly connected to the PJM grid via a 69KV transmission line located one mile off the property line.
- Location: According to the submitted proposal, the proposed site is Frank M. Adams Industrial Park, 1011 Frank Adams Industrial Way, Federalsburg, MD, 21632, Lots 2, 3, 5, and 6. As of the proposal submission, land for the proposed power plant have not been purchased, but a sale price has been agreed upon.
- Technology: GPPS intended to install EPI’s fluidized bed advanced stage gasifier system, one of the applications of the fluidized bed combustion technology. This language from the proposal describes the system:
The GPPS team will be installing an Energy Products of Idaho (EPI) Fluidized Bed advanced stage gasifier allowing precise combustion and emission control in the combustion stage. …The boiler will generate PSIG superheated steam at 900ºF for delivery to the steam turbine generator to achieve the maximum possible efficiency for a wood burning facility. The boiler island will include a steam generator, superheater, air heater, and economizer zone to maximize steam production efficiency.
- Apart from this language and a set of accompanying graphs which are not carefully explained, the proposal does not provide a comprehensive, detailed and thorough description of the system. Lacking such specifics, CCAN compiled the following details from available industry sources, including EPI’s parent company, Outotec.
- Fluidized bed combustion: the systems convert solid matter into a fluid-like state by passing liquid or gas up a heated bed of sand within a rising column of air.14
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- Thermal oxidation (combustion): conventional complete incineration of fuel, a total oxidation of carbon, hydrogen and other elements. The burning of fuel with excess air creates thermal energy in the form of steam, the heat then turns the turbines to generate power.15
- Gasification: gasification converts biomass into a synthetic fuel gas, called syngas, through pyrolysis with a controlled amount of steam and oxygen. The resulting gas is a mixture of carbon monoxide, hydrogen and carbon dioxide. As syngas cools, the steam condenses to medium energy gas, which turns the turbines to generate energy. Gasification is a much cleaner process than combustion because it doesn’t produce any access pollutants such as SOx and NOx.16
- Advanced staged gasification: The staged gasification process combines gasification and combustion. The fuel is first turned into a low energy syngas. The resulting gas is then burned to create a higher energy gas that will turn the turbines to generate electricity. This technology is more efficient as it burns more components of the fuel, reducing ash output. It also reduces power demand up to 30%.
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Air Emissions:
CO2: 3,328 lb/MWh
NOx: .5384lb/MWh
SO2: .3479 lb/MWh
PM2.5: 7.89 lb/tons
VOCs: .1250 lb/MWh
Ammonia: .0810 lb/MWh
HAPS: 0.0786 lbs/MWh
Free Your Voice inspires community action in Curtis Bay
At Benjamin Franklin High School, a human rights-focused student group called Free Your Voice is mobilizing their community to fight back against a potential environmental and public health catastrophe. CCAN is excited to partner with them as they fight to give their community a voice.
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For Cove Point, political parties don’t dictate sides
Two weeks ago, a group of environmental organizations, waterman, nurses, and concerned citizens stood outside of the Public Service Commission in Baltimore to launch our No to Cove Point LNG Exports Campaign. It was a great press conference – lots of media and onlookers. I stood there and watched a host of people speak, everyone from a representative of a national non-profit to a member of a local Cove Point Homeowners Association. I got to meet activists from all over Maryland. I was on day 3 of my new job, and I was impressed.
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O'Malley urged to fight gas export terminal on Bay
By Tim Wheeler
A broad coalition of environmental and other groups urged Gov. Martin O’Malley Tuesday to oppose development of a natural gas export terminal on the Chesapeake Bay, calling it an unacceptable environmental and safety threat.
Members of the coalition, which includes more than 120 local, statewide and national groups, gathered outside the Maryland Public Service Commission offices just before noon to outline their concerns over the proposed liquefied natural gas (LNG) export facility at Cove Point in Calvert County. They contended it would pollute the air and bay, undermine state efforts to combat climate change and expose nearby residents to the risks of a catastrophic explosion, either by accident or from a terrorist attack.
Broad Coalition Unites to Challenge Construction of Dominion’s Cove Point LNG Export Facility
120+ groups from across Maryland and the region urge Governor O’Malley to intervene; as first step, he must demand a federal “Environmental Impact Statement”
$3.8 billion industrial project would trigger the state’s biggest single source of global warming pollution, endanger local communities and the Chesapeake Bay, and ignite a new wave of fracking and pipelines
BALTIMORE—An unprecedented coalition of concerned citizens—from business leaders to watermen to environmentalists—announced its opposition Tuesday to a proposed $3.8 billion liquefied natural gas (LNG) export facility on the Chesapeake Bay in Calvert County, Maryland. Standing outside the Public Service Commission office in downtown Baltimore, the group declared its intention to challenge an upcoming series of federal, state and local permits needed by Virginia-based Dominion Resources before it can begin construction. Against a backdrop of posters saying “No LNG Exports on Chesapeake Bay,” they unveiled a letter signed by more than 120 groups urging Governor Martin O’Malley to stand with them against the project, given the great harm it could inflict on Maryland communities, the climate and the Chesapeake Bay.
Coalition members said Governor O’Malley should, as a minimum first step, demand that the federal government prepare a full Environmental Impact Statement (EIS) that carefully considers the implications of building an LNG export terminal on the Chesapeake Bay. Much to the dismay of local citizens, the Federal Energy Regulatory Commission (FERC) has indicated that it will only prepare an Environmental Assessment, which is a far less detailed impact review.
DOE 'conditional' approval for Cove Point LNG exports is not in Maryland's interests
With LNG Export Approval, DOE Shortchanges American Public, Ignores Economic and Safety Concerns
Cove Point project would hike energy costs, threaten public safety, harm Chesapeake Bay
WASHINGTON, DC – The Department of Energy announced today it had granted conditional approval to the Dominion Cove Point LNG facility to export liquefied natural gas to non-free trade agreement countries, pending an environmental review by the Federal Energy Regulatory Commission (FERC).
The $3.8 billion project would transform a sleepy natural gas import facility on the Chesapeake Bay into a massive export hub and hasten the already hectic pace of fracking for natural gas in the nearby Marcellus and Utica shale regions.
But as recently as last week, FERC regulators were raising concerns with Dominion about the safety of the project pointing to the potential for a “fireball” connected to on-site chemical storage. And while economic benefits of the project are heavily in dispute, all experts agree that it would raise domestic energy prices.
Dominion still faces major hurdles before the project can proceed. The company needs approval from the Federal Energy Regulatory Commission, which has yet to complete its environmental review. Dominion also needs approval from Maryland utility regulators as well as more than 60 permits and approvals. There is still pending litigation over whether Dominion has the right to build this facility or if it breaks an earlier legal agreement with Sierra Club.
The following are statements from groups that have aligned in opposition to this project: