We are writing to urge the South Carolina Department of Health and Environmental Control (SC DHEC) to deny any expansion of the wood pellet industry in South Carolina and to immediately address the environmental justice implications of this facility. We urge DHEC to address the impacts this facility would have on the climate, on South Carolina forests, on biodiversity, and on the health and well-being of impacted residents. Specifically, we call on leaders and DHEC to:

• Postpone all permitting procedures, including public comment until the coronavirus emergency declaration has been lifted. 
•  Complete a full Environmental Justice Report, which includes an impact analysis of Enviva’s proposed operation that takes into consideration its predicted increased production volume and coinciding pollution and cumulative impacts.
•  Deny Enviva’s air quality permit to expand production in Greenwood, South Carolina

Environmental Justice Impacts

Similar to other wood pellet production facilities in South Carolina, the Greenwood Enviva plant is located in an environmental justice-designated community. Greenwood County has an estimated population of 31.4% African American, 0.8% Asian, 0.3% Native American, and is already ranked in the 90th percentile for small particulate matter (PM 2.5) pollution.

Within a 2-mile radius around the current Enviva plant, the approximate 2,200 residents are already ranked above the 75th percentile for exposure to PM2.5, ozone, diesel, air toxins cancer risk, respiratory hazards, Superfunds, and hazardous waste. Increasing production at the plant would further heighten the risk of exposure to many of these common pollutants, but most especially the PM2.5 and respiratory hazards risks.

The COVID-19 crisis is affecting predominantly BIPOC (Black, Indigenous, and People of Color) communities across the South. Greenwood County is currently experiencing a “high” rate of infection according to the county government. With citizens concerned about their health and well-being, they may not be able to engage in a public comment period for such a critical permit. The public hearing must be delayed until after the coronavirus emergency is over, so that community members may be meaningfully involved in DHEC’s decision-making process regarding this permit.

Climate Impacts

Dogwood Alliance urges this SC DHEC to consider the impacts this facility will have on South Carolina’s forests, the state’s ability to be resilient in the face of increasing storms and hurricanes, and our commitment to reduce carbon emissions. While climate action is a top priority for communities that are facing climate impacts, dirty industries continue to expand, and protections for forests and communities fall short. Wood pellet production is carbon-intensive, leads to higher pollution in production areas, and removes forests that store and sequester carbon.

Enviva is applying for an expansion permit on the Greenwood pellet plant in Greenwood, SC. Currently the plant is limited to 550,000 tons per year, but Enviva now proposes to expand the plant to 660,000 tons per year. If Enviva is permitted and their intended expansion goes through, this facility will increase logging to 15,840 acres per year or 43 acres per day and emit 1,422,057 tons per year of CO2e, the equivalent of over 273,900 extra cars on the road.

Many forms of biomass—especially from forests—produce higher carbon emissions compared to fossil fuels. In particular, a growing body of peer-reviewed, scientific studies shows that burning wood from whole trees in power plants to produce electricity can increase carbon emissions relative to fossil fuels for many decades—anywhere from 35 to 100 years. This time period is significant: the Intergovernmental Panel on Climate Change made it clear that the coming decade is crucial and requires dramatic short-term reductions in greenhouse gases. The emissions from biomass will persist in the atmosphere well past the time when significant reductions are needed.

Forest & Wildlife Impacts

Global demand for wood pellets is devastating forest ecosystems in the Southeast United States. Biomass facilities acknowledge that they harvest from wetlands, highly diverse habitats with many threatened mammal, reptile, amphibian, and bird species. Despite the claims of the wood pellet industry, independent reporting shows a disturbing pattern: wood pellets often are sourced from wood that is harvested from native hardwood forests in an area designated as a global biodiversity hotspot.

Demand for softwood and pine plantations is also having a negative impact on forests, the climate, and biodiversity. Since 1953, the government has used various programs to pay landowners to plant pine instead of allowing natural forests to grow. As a result, we’ve lost over 35 million acres of natural forest and gained over 40 million acres of pine plantation instead. In addition, industrial tree plantations pose a serious threat to South Carolina’s climate change resiliency because they make the effects of floods, droughts, heat waves, storms, and disease more severe.

Conclusion

If Enviva is granted the extension, it will have impacts on the health of local residents, the ability of natural ecosystems to support greater resiliency to storms and hurricanes, and contribute to global carbon emissions at a time when community health and safety rely on cutting those emissions. Affected residents deserve an opportunity to be informed about the consequences of expansion.

We reiterate our ask for SC DHEC to postpone all permitting procedures, including public comment, until the COVID-19 emergency declaration has been lifted, and until a full Environmental Justice Report has been completed. Ultimately, we urge SC DHEC to deny Enviva’s air quality permit to expand production in Greenwood, South Carolina.

Thank you for the opportunity to comment on this permit.

If you’d like to submit your own public comment, please take action now.