On April 30, 2024, EPUD Board President Charles Kimball and Board Treasurer Curt Offenbacher contacted the Lane County Commissioners about their risky IMERF project. In the letter, the directors cited the $150 million price tag, the financial impact to the community and to EPUD customers in particular, and the project's contradiction to the County's own Climate Action Plan as reasons why the IMERF should be reconsidered.
View/download the letter.
The letter reads as follows:
April 30, 2024
Lane County
Board of Commissioners
125 East 8th Avenue
Eugene, OR 97401
Dear Commissioners,
As you know, we strongly disagree with your decision to build a new Integrated Materials and Energy Recovery Facility (IMERF) in the Goshen area. This $150 million facility will raise costs for all local residents at a time when they can least afford it. EPUD customers will be hit particularly hard, picking up the tab for $20 million in lost power generation on top of the garbage fee increases. With the urban-rural divide as wide as ever, this is one more indication of local politicians turning their back on those who live outside of town.
We simply have to ask: is this continued obsession with a legacy project really worth it? EPUD and Lane County already have a proven approach to emissions control that represents the very best of local government cooperation. Now, after no effort at genuine engagement, the County is on track to drive a wedge through this arrangement in an attempt at marginal additional emissions reduction. It’s a tremendous price to pay in more ways than one.
We’d like to call your attention to the County’s own Climate Action Plan, Phase 2: Community Greenhouse Gas Mitigation Action Plan. Page 40 includes the following (highlighting added):
The highlighted section above clearly states that any anaerobic digestion facility was to be constructed at the Short Mountain landfill itself. However, the IMERF is now planned to be sited far outside the landfill in Goshen even though plenty of space exists at Short Mountain. This is not only contrary to what you told the community in your Climate Action Plan, it’s economically damaging to EPUD as we no longer have access to the gas. But perhaps that’s the point, as County staff suggests in a recent news article (Cottage Grove Sentinel, 04/17/24):
Note: Per the draft contract, Lane County is entitled to 25% of gas sale revenues AFTER Bulk Handling Systems (BHS) receives the first $5 million.
Placing the IMERF outside of the landfill clearly has a financial benefit to the County. And clearly that’s important to your staff. We must ask, however: where do you think this benefit is coming from? It’s at the direct expense of EPUD customers, who will pay more for power because our gas supply is significantly diminished. This is the unavoidable truth despite lip service to the contrary (“there’s plenty of gas for everyone!”). We’d also point out that EPUD collects the gas at no cost to the County and, in fact, our royalty payments have nearly doubled. This same statement from your Climate Action Plan also references a public benefit clause:
We challenge you to explain how a contract that allows Bulk Handling Systems to monetize $5 million per year in renewable natural gas sales to a fossil fuel company (Northwest Natural) is “most beneficial to the community.” EPUD’s use of the gas leads directly to lower rates and greater reliability for our 50,000 Lane County citizens. This would seem to be an actual community benefit, as opposed to lining the pockets of corporate executives.
We also encourage you to revisit other aspects of your Climate Action Plan to determine whether this IMERF project is really the place to spend your political capital. Phase 2: Community Greenhouse Gas Mitigation Action Plan, Page 5 includes a complete list of strategies for the County to focus on to achieve emissions reductions (red highlight added):
How is it that the strategy second from the bottom of this list is nonetheless the urgent priority of the County? Marshalling the resources for a $150 million investment is not something you will have the capacity to do every year, or even every decade. Surely the “bang-for-the-buck” would be far and away higher by dedicating this same level of investment to those strategies with the highest emissions reduction potential.
It's not too late to do the right thing, come back to the table, and double down on our longstanding partnership. We stand ready to make further investments at the landfill to achieve significant emissions reductions at a fraction of the cost of the IMERF. We know these investments work. As indicated by the chart below, our recent higher spending has dramatically increased our gas capture rate over the past three years:
Notably these latest figures are not a “single data point” but rather the sustained progress made possible by steel-in the-ground investments at the landfill. We have a long list of projects that will allow us to further push this capture rate up to world class levels but need to ensure a reliable gas supply for these to pencil out. Should the County move forward with the IMERF, however, we have every intention of capturing only what we need to meet the terms of our contract. This opportunity cost of lost emissions reduction should be factored into your decision making just as much as any IMERF-related reductions being touted by your staff.
Finally, we will again note our frustration at being an afterthought in these discussions. Despite the very real ($20 million real) impact to our customers, we were only consulted after reaching out to the Board of Commissioners directly. County staff’s claims that there were “multiple planning meetings” with EPUD is revisionist history. In reality, there were a couple of thrown together Zoom meetings among lower-level staff in which—bizarrely—EPUD was advised as to how we might stop the IMERF project by offering specific points of public comment. Apparently, this ambivalence toward the project among County staff never did make it to the Commissioner level, but we encourage you to investigate just how much internal support this project really has.
We welcome the chance for a reset and look forward to engaging further on this topic.
Sincerely,
Charles Kimball
EPUD Board President
Board Director, Subdistrict 5
Curt Offenbacher
EPUD Board Treasurer
Board Director, Subdistrict 3
We encourage customers and other members of the public to reach out to the Lane County Board of Commissioners and ask them to support EPUD’s Short Mountain power plant rather than building the expensive new IMERF facility.
The Board of Commissioners can be reached by email at lcbcccom@lanecountyor.gov or you can contact them through our website.