On November 21, 2021 the Jefferson County Department of Health (JCDH) posted for public comment a Draft Renewal of the Major Source Operating Permit, also known as a Title V permit, for Alabama Power Company’s (APC) Miller Steam Plant (Miller).
The public has 30 days from the date of the public notice to submit written comments on the Draft Permit. This means that the comments will be due December 21, 2021.
Miller is located in West Jefferson County. It has four coal-fired electricity generating units. The Miller is the largest emitter of greenhouse gases in the country, emitting 18,846,905 tons of CO2 emissions each year.
Fossil fuel consumption is the leading contributor to climate change. Coal has the highest carbon content of any fossil fuel per unit of energy. Accordingly, burning coal for electricity produces more carbon per kilowatt-hour generated than does burning oil or natural gas. “Coal emits 27 percent more CO2, the main pollutant that fuels global warming, per unit of energy than oil and 75 percent more than natural gas.”
GASP will be reviewing the Draft Permit for a number of ways in which air emissions can be reduced; the ability of citizens to enforce the Clean Air Act is preserved; and to ensure that there is adequate monitoring to ensure compliance with the Clean Air Act, among other issues.
However, it is also imperative to keep in mind the climate impacts of Miller. After all, President Biden’s recent executive order on the climate crisis emphasizes that executive action is to be taken by this Administration to tackle the climate crisis at home by “immediate review of harmful rollbacks of standards that protect our air, water, and communities” as well as increasing environmental justice monitoring and enforcement through new or strengthened offices at the EPA, Department of Justice, and Department of Health and Human Services. Where EPA will be the ultimate reviewer of the permit issued to Alabama Power for its Miller plant, it is imperative that the final permit contain monitoring and enforcement provisos that ensure that the EPA is able to tackle the crisis at home by properly regulating the #1 greenhouse gas emitter in the country.
 Environmental Integrity Project, “Greenhouse Gases from Power Plants 2005-2020: Rapid Decline Exceeds Goals of EPA’s Clean Power Plan” (February 25, 2021) at 10 available at https://environmentalintegrity.org/wp-content/uploads/2021/02/Greenhouse-Gases-from-Power-Plants-2005-2020-report.pdf.
 Environment America, “America’s biggest polluters: Carbon dioxide emissions from power plants in 2007,” 8 (Nov. 2009) available at http://www.environmentamerica.org/sites/environment/files/reports/EA_web_biggestpolluters.pdf.