THE COB PLANT PROPOSED FIRE PROTECTION proposal violates OAR 345-022-0110 at page 78 D.13. of the 12/30/2003 ODE Draft Proposed Order. Additionally, the Draft Proposed Order violates ORS 469.401(4) on page 148 at (3) "ODE recommends that the siting council does not have jurisdiction for determining compliance of…." Various programs addressing fire protection and fire safety.

This appears to be a blatant attempt by ODE staff to simply avoid dealing with the various fire protection and fire safety issues.

1. The COB facility application for a site certificate and subsequent draft siting permit issued by ODE relies heavily on the Bonanza Volunteer Rural Fire Protection District (BRFPD) for fire suppression ( page 86 line 24-25 of Draft Proposed Order)at their proposed site during construction and during the proposed thirty year life span of the facility.
2. The expected initial time required for BRFPD to respond is not discussed. Because BRFPD is both rural and volunteer this expected response time must be evaluated.

    

3. Simultaneous fires at the COB facility and at another non-Cob facility site might prevent BRFPD from responding to the COB facility for an extended period of time.
4. The nearest back up responders for BRPFD is located is suburban Klamath Falls. Their only access to the COB facility is over more than twenty miles of two lane winding farm to market roads. Their response time is significantly weather related.

    

5. The suitability of BRFPD equipment to suppress any fire in a complex facility with more than twenty five acres under roof is not discussed.
6. The suitability of back up responders’ equipment to suppress any fire in a complex facility with more than twenty five acres under roof is not discussed.

    

7. The suitability of BRFPD equipment to suppress chemical, electrical, or natural gas fueled fires is not discussed.
8. The level of training of the fire chief and her rural volunteer crew to suppress chemical fires is not discussed.

    

9. The level of training of the fire chief and her rural volunteer crew to suppress major electrical fires is not discussed.

Respectfully submitted,

Dr. Doug Whitsett

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The Council Facility Siting Standards are violated in the Draft Proposed Order at D.1 (1) (a) "the overall public benefits of the facility outweigh the damage to the resources protected…."

The ODE draft Proposed Order to site the COB facility does not address the possible impact that stray voltage produced by the facility’s operation may have on local dairy production. Three large producing dairy farms are located within four miles of the proposed facility. The production of these dairy operations, and therefore their economic viability, are extremely sensitive to stray voltage.

For instance, within 24 hours of the start of the generators at the McNary Dam an adjacent dairy experienced an approximate 50% reduction in production. Eventually, this sustained loss of production was attributed to both stray voltage in the milking facility as well as stray voltage on the pasture foliage. Investigators felt a tingling shock when they touched their tongues to blades of grass. It was assumed that the loss of production resulted from the cows teats receiving mild shocks while being milked and by reduced forage consumption due to an electrically charged pasture. The problem was mitigated by the purchase and decommissioning of the dairy.

A similar situation is said to have occurred adjacent to a large gas fired generation facility in the Midwest.

The Cob facilities possible negative impact on local dairy production should be investigated and mitigated, if possible, prior to the final siting authorization for the COB facility.

Respectfully submitted,

Dr. Doug Whitsett