It’s dirty and dangerous

Biodiesel exhaust lacks a few noxious elements of ordinary fossil-fuel diesel exhaust, but don't let anyone tell you it's "safe". Unless treated (which Tenaska does not intend to do), it includes higher proportions of very fine particulates^2.1—so small, they can move directly from lungs into the bloodstream. And, it includes unregulated chemicals for which no safety limits have yet been established.

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It’s inefficient

Instead of a cleaner, more efficient gas turbine design that saves ratepayer dollars over the long haul, Tenaska chose a dirtier, thirstier, cheaper-up-front unit.

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It’s impractical

When we asked, Tenaska could cite only only one biodiesel-fueled power plant existing anywhere else in the world today: a biodiesel turbine generator in Kemi, Finland^4.1. But it's designed to run continuously, not intermittently like a peaker plant; and it's a cleaner, more efficient design, using biodiesel produced at the wood pulp factory it's literally in the middle of.

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It’s unfair and unwise

The WA Legislature carefully crafted its 2019 Clean Energy Transition Act^5.1 to require utilities to share out the burdens and benefits of its changes fairly and equitably, instead of just dumping the dirtiest facilities onto the most hard-up communities. This project reverts right back to those old, engrained bad habits.

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It’s backwards-looking

Experts reviewing PSE’s draft Clean Energy Implementation Plan called out its significant disregard for non-emitting alternatives, like {{EE/DR/DER}}{(EE=Energy Efficiency (rewarding customers by subsidizing investments in improved insulation, more-efficient appliances or heating & cooling, upgraded windows & doors, etc.);

DR=Demand Response (rewarding customers for reducing demand in peak periods on [automated] advance request by the utility);

DER=Distributed Energy Resources (Rooftop & ground-mount solar PV, battery systems, small wind turbines, etc., owned by individual customers; community solar arrays, owned by customer cooperatives; etc.)} programs. They cite documented positive results from other utilities in our region which made earlier, bigger commitments to building these programs. PSE could directly fill the capacity “hole” it wants to plug by boosting its investment in those programs, instead of noxious diesel-spewing peakers.

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Raw biodiesel exhaust lacks some of the noxious elements^2.6 of ordinary diesel exhaust, but not all.

One major component both do have in common is thousands of tons of nitrogen oxides^2.5—which have long-proven adverse health effects^2.1,2.3, as well as accelerating climate change.

Biodiesel exhaust actually includes higher proportions of very fine particulates^2.2—so small, they can enter your bloodstream via your lungs.

And, it adds unregulated and under-researched chemicals that come from the novel feedstock^2.9 oils—emissions for which no safety limits have been established yet. But there's published early evidence of inflammatory^2.3 and cytotoxic effects^2.8 in laboratory studies.

Overall long-term public health impacts? No-one can quantify them.

But this plant will cause more premature death—its raw, untreated pollutant emissions will kill people^2.4 downwind, particularly the vulnerable: infants, children^2.7, the elderly, and people with cardiac^2.6 or respiratory issues.

Just like no car or light truck is sold in 2023 without sophisticated control systems that have radically cleaned up vehicle emissions from the early days of open pipes, today there are plenty of proven methods available to clean up raw exhaust emissions from a turbine-powered generator.

But Tenaska's proposal rejects all available smokestack abatements—instead, asking the Puget Sound Clean Air Agency to let them pump raw, untreated biodiesel exhaust directly into the air above our homes.

The only commitment in the initial application was that the plant would scrape barely under EPA's limits for federally-regulated pollutants, by limiting total operation time to under 470 hours a year.

After Clean Air Agency engineers responded with some pointed questions, they withdrew the application "for refinement". And in later discussions we've had with them, they acknowledged they “couldn’t make it pencil” without more than doubling that limit.

Soon we should see what the "refined" application "commits" to limiting its maximum annual hours of emissions to. You might want to make PSCAA's New Construction Applications listing your new browser home page—after their next application is posted there, we'll have just 15 days to demand public hearings.

And if the regulators approve the proposal anyway—despite popular pushback—it'll be just as vital to see how the Agency proposes to disincent the developers from blowing past the licensed limits, shrugging off possible penalties as a minor "cost of doing business".

Plenty of us aren't too keen on us, our kids, or our elders being Tenaska's involuntary guinea pigs.

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The cheap, dirty & crude gas turbine design Tenaska proposes nearly doubles the fuel burned, and doubles the exhaust emitted every MW/hour of electricity produced, versus cleaner, more-efficient (and more expensive up-front) two-stage gas turbine generators.

That's because the more-sophisticated two-stage ("Combined Cycle") design adds a Heat Recovery subsystem that captures almost as much waste heat energy again from the exhaust stream as the cheaper, dirtier ("Single Cycle") turbine approach manages to deliver in its single mechanical stage—heat energy the cheap & dirty unit sends straight up its exhaust stack.

Although single-stage units cost less up front, long-term, the extra fuel they guzzle gives the cost advantage to two-stage systems—even more quickly, if reduced emissions impacts to the environment and public health are properly priced in.

Compare unit price ("LCOE") for "Gas peaker" with "Gas (combined cycle)" in this chart:

• SCGT vs. CCGT $Generation

Single-stage units do spin up from a cold start about 15 minutes faster, too. But two-stage systems can easily meet and beat that small head-start by adding a relatively small on-site battery—ready in mere milliseconds to instantly meet demand until the two-stage unit reaches service speed.

Single-stage turbo generator

Two-stage turbo generator

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The reason the world has no other biodiesel peaker plants? Maybe because biodiesel is “contraindicated” for backup/standby generators—according to engineers at John Deere, Inc.

(Oh, and engineering studies by Portland General Electric reached the same adverse conclusion, too.)


Biodiesel can’t be stored for more than 45 days before it degrades too badly for reliable service. It also degrades even faster in conditions of extended heat or cold.


After every use, John Deere recommends emptying the tank, discarding all left-over biodiesel, and cleaning out the tank. A tall order, when your tank capacity is 1.8 million gallons…

There are applications where biodiesel may make sense. But they're mostly in transportation, which is where our limited volumes of biodiesel production ought to be going instead.

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The plant location is also the cheapest choice: right next to the incoming feed lines.

But it’s also right on top of some of Bremerton’s newest and most concentrated residential developments.

Besides recently-completed Soundview Estates, under-construction Soundview West, and the in-planning Buckingham Properties development, there are lots of other zoned-residential parcels nearby, owned by home developers, which the City of Bremerton expects to fill with new residents as its population grows by a third in the next 10 years.

And that's just the new homes: hundreds of other households already sit vulnerable to the toxic plume of exhaust gases and particulates fallout that will stream raw and untreated from the plant's smokestack, if built.

Being next to these current and proposed homes for around 3,000 Bremertonians mean they'll be forced to breathe its untreated emissions, while at the same time their homes suffer massive losses of real-estate value.

Realtors estimate that homeowners near the plant are likely to see a more than $100 million loss on the overall net worth of their homes.

The raw exhaust, with its damaging fine particulate fallout, will fill the air of a census tract that already suffers very high vulnerability indexes, per the WA Department of Health—compounding the unhealthy effects of heavy truck traffic and other industrial airborne pollutant sources, along with proximity to 3 national-scale SuperFund sites.

Those suffering most from the plant’s additional air pollution will be children, the elderly, and anyone already coping with respiratory or cardiac illnesses. WA Dept of Health maps show that this census tract is already among the most disadvantaged areas of Kitsap County.

For very little extra cost, the plant could be set back a mile or so further back onto the Ueland Tree Farm property.

Prevailing winds would then bypass the main residential developments—and extra distance would help dilute contaminant concentrations on the way.

Doing so—and most importantly: adding pollution abatement controls to treat the exhaust stream—would substantially reduce human health risks.

We asked Tenaska to consider adapting their proposal in these small ways.They acknowledged the benefits for public health, but said "it's too late to change our proposal now".

So, persuading PSE, the UTC, the Clean Air Agency, and the City Council to either rethink this approach, or kill the project outright, is our only hope.

We need your help to make a big impression on these groups.

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Right now, today, combustion-fueled peaker plants—which tend overwhelmingly to get dumped on the doorsteps of vulnerable and marginalized communities^6.1,6.2—across the country, and internationally, are being decommissioned and replaced^6.3 left and right by renewable solar and wind sourced-power, backed up by a new class of battery storage systems.

The cost trends of solar photovoltaic and wind power have plummeted exponentially year over year, boosting their cost effectiveness far past nuclear and fossil-fuel sources.

• Renewable Cost Trends

No less an authority than the US Government's Energy Industry Administration acknowledged this May that—with all subsidies removed—solar and wind now costs 25% less than any combustion-based power—even when the cost of storage systems is included to offset the intermittency of renewables.

Grid-stabilizing "hybrid" renewable-plus-storage deployments have been growing exponentially over the last 5 years.

And according to NERC (North American Electric Reliability Corporation) forecasts, essentially zero other utilities on this continent are betting on liquid biofuels (like biodiesel) as a strategically-significant fraction of their future resource plans for the decades ahead. It's under 1% of projected supply; the only possible reason to touch it is to slurp up some sweet Congressional largesse aimed at placating Iowa soy producers.

• Biofuels by source

The future of electrical power is here—enabled by instant, ubiquitous digital communications and control—and it revolves around decentralized networks, micro-grids, and non-emitting sources: energy efficiency programs, demand response programs, and especially distributed energy resources.

It exploits the staggering scalability of solar photovoltaic systems and new battery technologies, plus the unbeatable clean, free fuel advantages of both solar and wind^6.4.

Which, when reasonably accessible global reserves are plotted to scale, lead to one inescapable conclusion: fossil fuel and nuclear generation are so inefficient, damaging, and limited, they simply have no place in the future.

• Global Energy Sources, Sized

What's still new news in utility thinking is the mold-shattering paradigm of Firm Renewable Power^6.6: reliable committed supply, available 7/24/365, sourced 100% from renewables, through a combination of whole-system design, in place of the usual facility-scale piecemeal approach, and coordination of multiple key elements:

• perfect load forecasting^6.7
• overbuilt-for-curtailment-by-design solar^6.8
• a sprinkling of wind
• limited storage
• geographically-dispersed installations

The ability to deliver rock-steady supply to match real-world load curves has been robustly modeled against extensive high-resolution national and regional datasets, drawn from regions as disparate as Italy; Switzerland; Minnesota; California; & New York State^6.7.

• Overbuilt PV=>Firm Power

It's a far more resilient and adaptable architecture—and the best part: it can be implemented and delivering bulk power for unit prices ("LCOEs") that are the same or less^6.8 as today's systems—but it's a difficult paradigm shift for old-school command-and-control-fixated cultures like the utility industry, rooted in the late-19th-Century analog worldview of its origin.

Here's a dead giveaway to tell if you're talking to an engineering type who's still mired in the obsolete paradigms of your great-grandfather's power grid: if they talk about the necessity of fossil or nuclear "baseline" sources to offset/backup "the intermittency of renewables", or if they stare blankly at the term "implicit storage"^6.7, they haven't got the memo yet.