Facts Matter

Greenidge Bitcoin Mining Expansion

Greenidge Generation, the corporation proposing Bitcoin mining expansion by burning fossil fuels in an old, inefficient plant on the shores of Seneca Lake, has been hard at work trying to discredit environmental advocates, residents, and business owners who are concerned about Bitcoin expansion and working to inform the public, by accusing them of spreading false information. They’re “greenwashing” their environmental record by publishing full page ads, letters from contractors, employees and supporters. And they’ve sent 6-page letters to our members and municipal governments around the Finger Lakes. Please forgive us for the length and complexity of this letter, but we take these attacks on the credibility we’ve spent decades earning seriously, and we must respond to these claims, point by point, because facts matter.

Greenidge Claim: The environmental demand and damage Greenidge’s power plant operations are responsible for doesn’t count, because it is within their Department of Environmental Conservation (DEC) permit limits.

Fact: This is a common corporate crutch. DEC’s role is to assist corporations with proposals and attempt to mitigate the worst of the environmental impacts. Sometimes they fail at this task, which is why grassroots community environmental groups are essential. For example, DEC was working with the fracking industry to help them get regulations favorable to industry in New York. It was grassroots environmental groups and hundreds of thousands of ordinary citizens who worked to keep fracking out of NY.

With Greenidge, it is only logical that increasing the electricity needed to expand from 7,000 to 30,000 bitcoin “miners” will require the burning of more natural gas, the withdrawal of more cooling water, the discharge of more hot water, and the creation of more air emissions and noise pollution.

Greenidge Claim: “Greenidge is NOT discharging 108-degree water into Seneca Lake.”

Fact: No one ever said they were. What we are worried about is that their permit from DEC allows Greenidge to do so, into the Keuka Outlet, which is a trout stream, without a penalty. It only stands to reason that if they increase their operations, the temperature of their discharges will also increase. Greenidge is permitted to withdraw 139 million gallons of Seneca Lake water per day (MGD), and discharge 134 million gallons daily at temperatures of up to 108 degrees Fahrenheit.

Source: Exact language within the Greenidge discharge permit limits established by DEC in 2017:
• Daily maximum discharge flow of 134 MGD;
• Daily maximum excess water temperature (i.e., temperature difference between the discharge and intake) of the Greenidge Station: summer 26°F and winter 31°F; and
• Daily maximum discharge temperature: summer 108°F and winter 86°F.
• For the purposes of the permit, summer is defined as May 1st through October 31st; and winter is defined as all other dates.

A DEC and Clean Water Act Failure:
The Environmental Protection Agency’s (EPA) Clean Water Act and DEC regulations set the discharge temperature to trout streams like the Keuka Outlet at 70 degrees, year-round, to protect native fish like trout. Regardless, DEC has permitted Greenidge to discharge into this stream, which goes directly into Seneca Lake, at temperatures of up to 108 degrees. We are merely trying to point out this inconsistency in an effort to protect the trout population in Seneca Lake.

Source: NYDEC Excerpt under: 704.2 Criteria governing thermal discharges https://govt.westlaw.com/nycrr/Document/I4ed9042acd1711dda432a117e6e0f345?viewType=FullText&transitionType=StatuteNavigator&contextData=(sc.Default)

(b) Special criteria.

(2) Trout waters (T or TS).

(i) No discharge at a temperature over 70 degrees Fahrenheit shall be permitted at any time to streams classified for trout.

(ii) From June through September no discharge shall be permitted that will raise the temperature of the stream more than two Fahrenheit degrees over that which existed before the addition of heat of artificial origin.

(iii) From October through May no discharge shall be permitted that will raise the temperature of the stream more than five Fahrenheit degrees over that which existed before the addition of heat of artificial origin, or to a maximum of 50 degrees Fahrenheit, whichever is less.

(iv) From June through September no discharge shall be permitted that will lower the temperature of the stream more than two Fahrenheit degrees from that which existed immediately prior to such lowering.

DEC even has a poster warning fishermen of the danger of warm water to trout:

Catch and Release Anglers Recently the State DEC confirmed that the cooling water discharge temperatures are within the DEC permit that they granted, but outside the Clean Water Act and DEC regulations. They have done nothing to correct this error:

“The SPDES permit limits the discharge of cooling water to 134 million gallons per day at a temperature no more than 108 °F during the summer and 86 °F during the winter. Since 2017, the daily maximum discharge temperatures have been approximately 98 °F in the summer and 70 °F in the winter and the maximum discharge rate was 98 MGD.”

Greenidge Claim: “The water was only, on average, 8.4 degrees warmer when it left Greenidge than it was at intake.”

Fact: Again, this is classic greenwashing. “On average” means that at times the temperatures are much greater than 8.4 degrees warmer. The EPA and DEC regulations set the winter temperature increase at 5 degrees, so Greenidge may be within its permit limits but in violation of both the DEC and EPA regulations.

Greenidge Claim: “The concerns about the Clean Water Act compliance were “already soundly rejected by the courts that have upheld the facility’s State Pollution Discharge Elimination System (SPDES) permit and the associated environmental review.”

Fact: The court never ruled on the propriety of the SPDES permit, the case was dismissed because Greenidge had already started operations while the case was pending. We are urging stronger DEC and EPA oversight.

Greenidge Claim: “At the time these approvals were issued, NYSDEC conducted a full environmental impact analysis of the operation of the Greenidge generating facility prior to its issuance of the permits”, “based on 24/7 operation of the 107 MW generating facility to provide electricity.”

Fact: In 2017, DEC simply reissued a modified SPDES permit and issued a “negative declaration”, indicating that there would be no negative environmental impact. There was no Environmental Impact Statement. DEC simply stated: “This is to inform you that the DEC, as the SEQR lead agency, has issued an amended negative declaration for the project and will not require the preparation of an environmental impact statement.” We are urging DEC to complete a full environmental review.

Greenidge Claim: ‘There is simply no actual evidence that heat from Greenidge’s operations harms the biological community. NYSDEC has thoroughly analyzed this issue and found no adverse impacts.”

Fact: According to a recent DEC study of fish in Seneca Lake, 80% of the lake trout caught were “stocked,” meaning that something is interfering with natural trout reproduction. No full Environmental Impact Statements has been completed to assess this. Greenidge’s hot water discharges and other operating systems may or may not be contributing to the problem, but until studies are done, there is no way to tell the cause. We’re asking for the completion of studies before Greenidge expands.

Greenidge Claim: “Greenidge is already investing millions to protect the fish of Seneca Lake.”

Fact: Under the Clean Water Act, the “Best Technology Available” (BTA) to prevent fish from being sucked into the intake and killed is “closed cycle cooling.” Closed cycle cooling reduces water intake and discharge by 95-99%. Greenidge was not required to have closed cycle cooling because it was originally permitted to only be a “peaker plant”, operating to supply power to the public on demand from the grid, so DEC determined it was too expensive to require closed cycle cooling and permitted the less expensive alternative, variable speed pumps and wedgewire screens. But those screens have still not been installed.

The DEC agrees that until and unless the water intake screens are installed, Greenidge is not in compliance with the DEC regulations or the Clean Water Act.

Source: Greenidge’s 2017 DEC SPDES Permit states: “The cooling water intake structure lacks any fish protection technology, therefore the facility does not meet either the requirements of 6 NYCRR § 704.5 nor the requirements of the CWA § 316(b)Phase II Rule (40 CFR Parts 122 and 125).” So, the DEC agrees, until and unless the water intake screens are installed, Greenidge is not in compliance with the DEC regulations or the Clean Water Act.

The current timetable provided by Greenidge to DEC on 11/2020 for installation of the wedgewire screens is not until October of 2022:

Greenidge Project Installation Schedule

That’s too long, and can continue to cause harm to the fish and other biological life in the lake. Now that Greenidge is not merely an on demand peaker plant, but is operating 24/7 and has turned into a private Bitcoin mining operation, we are urging expedited remediation and consideration that since operations have been modified, the required level of fish protection be upgraded to the Clean Water Act’s Best Technology Available in order to protect Seneca Lake’s aquatic life.

Greenidge Claim: “There were no Harmful Algal Blooms (HABs) within 4 miles of the plant in 2020.”

Fact: The incidence of HABS everywhere on Seneca Lake was shockingly low last year. While not fully studied as to exactly why, the general consensus is that we had a drought (and thus less nutrient loading) as well as higher levels of strong winds. This anomaly was not specific to just Seneca Lake. Nancy Mueller, of the NYS Federation of Lakes Association, advised that there was a general lessening of HABS throughout the state in 2020, which could be attributed to drought covering a very wide area and high winds that may have also affected other water bodies as well.

According to Seneca Lake Pure Waters Association, the organization primarily dedicated to monitoring HABs on Seneca Lake, “2020 was an unusual year, with far fewer blooms than years past. Blooms began to appear in mid-August, with only a few identified on the southeast side of the lake. Sporatic(sic) blooms were reported in the following two months, but only 15 of 21 blooms were confirmed through the entire HAB season (August-October). In the Finger Lakes, as well as around the world, cyanobacteria blooms are receiving more and more attention, and the lite(sic) 2020 season for Seneca Lake was likely due to drought and windy conditions.” https://www.senecalake.org/Blooms

SLPWA volunteers who have run the HABS program for several years on Seneca Lake confirmed that we have historically seen a higher than average incidence of harmful algal blooms both North and South of the Keuka Outlet and in Dresden Bay (where Greenidge is located) since monitoring HABS in our lake.

In brief, Greenidge citing one single year of no HABS reported to support what is going on is unwise, unfair and far from scientific. It is clear that we already have a problem with HABs. Anything that might contribute to that problem should be carefully considered. That is why we have consistently requested a formal Environmental Impact Statement with full thermal studies be prepared as part of their planned expansion.

Greenidge Claim: “The data center project is not now, and has never been, a request to expand the capacity of the Greenidge power generation facility.”

Fact: An increase in operations is allowed within existing DEC permits. However, the original intent of the plant was to intermittently supply power to the public, and now it is primarily a private Bitcoin facility operating 24/7. An increase in size from 7,000 machines to 30,000 machines will require additional electricity to be generated, with more water withdrawal and discharge, burning of natural gas, and harmful air emissions. We think that this change should receive more environmental scrutiny by DEC.

Greenidge Claim: “The facility has been substantially upgraded on more than one occasion over the last two decades, the latest of which occurred in 2017, at a total cost of well over $20 million. These upgrades included the addition of a suite of modern pollution control equipment.”

Fact: When Greenidge transitioned from burning coal to natural gas, they included improvements to the emissions systems, and the addition of variable speed pumps to the water intake. However, they are still using a 68-year-old turbine that was installed in 1953.

Greenidge Claim: “The company has invested approximately $70 million in private capital into our region, already creating dozens of new jobs.”

Fact: Atlas’s partnership with Greenidge represents a $65 million investment into the facility. This includes the installation of 7,000 machines, funds spent on the power plant’s conversion costs and infrastructure changes. When Greenidge was burning coal, Atlas used considerable efforts to convert the site into a natural gas and biomass facility and now the operation solely uses natural gas. Source: https://news.bitcoin.com/natural-gas-bitcoin-mining-operation/

Greenidge has provided temporary jobs to Victor, NY based O’Connell Electric paying them $10 million for the electrical installation of the original Bitcoin miners. We are happy that Lockwood chose City Hill Construction to make all the repairs required by the DEC to bring the toxic ash landfill into environmental compliance with a consent agreement to correct groundwater contamination. But that has nothing to do with Greenidge. The installation of 7,000 mining rigs for Bitcoin use, and future expansion plans will again provide temporary local jobs.

However, what residents, grassroots environmental organizations, businesses, and Faith Leaders in the Finger Lakes have collaboratively called for is responsible corporate management, from a company making millions of dollars per year before expansion, to merely act as good neighbors of the Finger Lakes and put in place adequate systems to protect our agriculturally based economy by protecting our water, air, and quality of life. We ask this to preserve the 58,000 jobs and $3 billion economy supported by the agri-tourism industry, because we must think about those jobs, too.

To date, we have less than optimal cooling and aquatic life-protecting systems in place, along with inefficient energy production by burning fossil fuels. We have incomplete thermal pollution, noise, and water pollution studies, and a proposal to increase private Bitcoin mining operations, with a corresponding increase in greenhouse gas emissions in the midst of climate crisis.

Greenidge could support even more local jobs by hiring people to put the most technologically advanced, environmentally friendly systems in place, and with the amount of money Greenidge is making on its private Bitcoin operations, it would seem that they could afford to adopt those changes, rather than create conflict within the region and leave us all stuck with the damage.

The public should know that, while Greenidge is operating within the permits issued by DEC in 2017, these limits do not comply with the requirements of either the DEC law or regulations or the Federal Clean Water Act. In fact, their permit indicates a number of requirements where Greenidge will not be in compliance until corrective actions are taken or where studies are required to determine compliant limits.

DEC failed to review these limits when Greenidge became a bitcoin mine. DEC has given Greenidge generous time to complete the thermal and pollution studies and it will take years to implement corrective action.

Just because actions are within DEC permit limits, it does not mean there are no environmental impacts. Despite Greenidge’s attempts to discredit hundreds of vocal concerned businesses, organizations and community members, who do you trust? A multi-million-dollar corporation making $1.5 million a week and wanting more, or your neighbors who have done independent research, and earned credibility year after year as we work to protect Seneca Lake and the Finger Lakes?

We have nothing to gain, and everything to protect.