Technical Analysis

Reverse-Engineering the Ridgeline Emissions Profile

Using EPA AP-42 emission factors, Clean Air Act thresholds, and publicly available data. All calculations shown. February 2026.

Executive Summary

Based on standard engineering calculations, a 785 MW natural gas power plant operating continuously cannot be classified as a minor source of air pollution. Even with the best commercially available emission controls, the facility exceeds the 100 TPY major source threshold for four of six criteria pollutants.

The permit's claimed 99 TPY NOx — precisely 1 ton below the threshold — would require operating at only 27.5% of capacity. The claimed 56 TPY CO would require only 11.5% of capacity. Neither is consistent with powering a 24/7 data center.

1. What Makes a "Major Source"?

Under the Clean Air Act's Prevention of Significant Deterioration (PSD) program, a major source is any facility that emits — or has the potential to emit — 100 tons per year (TPY) or more of any regulated pollutant.

The Ridgeline facility's heat input (~7,458 MMBtu/hr) is 29.8 times the threshold for listed source categories. Whether classified as listed or unlisted, it exceeds all applicable thresholds.

Pollutant	Major Source Threshold	PSD Significant Level
NOx	100 TPY	40 TPY
CO	100 TPY	100 TPY
SO₂	100 TPY	40 TPY
PM₁₀	100 TPY	15 TPY
PM₂.₅	100 TPY	10 TPY
VOC	100 TPY	40 TPY

Class I Wilderness Areas

Dolly Sods Wilderness is approximately 10–15 miles from the proposed site. Otter Creek Wilderness is approximately 20–30 miles away. Both are mandatory Class I federal areas under the Clean Air Act — they receive the most stringent air quality protection available.

Any new major source within ~31 miles of a Class I area must demonstrate it won't degrade air quality there. Under the minor source permit, none of this analysis was required.

2. Power & Fuel Calculations

Known Facts (Public Record)

Parameter	Value	Source
Permitted capacity	785 MW	WV DEP permit
Diesel backup storage	30 million gallons	WVPB, June 2025
Site size	~500 acres (up to 10,000)	Multiple sources
Fuel	Natural gas pipeline	Permit application

Heat Input & Fuel Consumption

Using a conservative heat rate of 9,500 Btu/kWh (favorable to the applicant — many industrial turbines run 10,000–11,500):

Heat Input = 785,000 kW × 9,500 Btu/kWh = 7,457.5 MMBtu/hr

Annual (24/7): 7,457.5 × 8,760 hr/yr = 65,327,700 MMBtu/yr

Natural gas: ~64 billion scf/yr (~175 million scf/day)

3. Emissions Calculations

Using EPA AP-42, Section 3.1 (Stationary Gas Turbines) — the standard reference for air quality permitting:

785 MW — Best Available Controls (DLN + SCR + Oxidation Catalyst)

This is the most favorable scenario possible for the applicant:

Pollutant	Factor (lb/MMBtu)	Annual Emissions	Threshold	Result
NOx	0.011	359 TPY	100 TPY	3.6× OVER
CO	0.015	490 TPY	100 TPY	4.9× OVER
PM₁₀/PM₂.₅	0.0066	216 TPY	100 TPY	2.2× OVER
SO₂	0.0034	111 TPY	100 TPY	1.1× OVER
VOC	0.0021	69 TPY	100 TPY	Below

Four of five criteria pollutants exceed the major source threshold even with the best available controls. Without controls, NOx alone hits 10,452 TPY — over 100× the threshold.

Even at 200 MW — Still Over

Even a facility only 25% the size of what's permitted would exceed thresholds:

Pollutant	200 MW (Best Controls)	Threshold	Result
NOx	91.5 TPY	100 TPY	⚠️ Marginal
CO	125 TPY	100 TPY	1.25× OVER
PM₁₀/PM₂.₅	55 TPY	100 TPY	Below
SO₂	28 TPY	100 TPY	Below

4. The Permit's Numbers Don't Add Up

The permit reportedly claims 99 TPY NOx and 56 TPY CO. Let's reverse-engineer what operating conditions that requires:

To achieve 99 TPY NOx (with best controls):

99 tons = 198,000 lb/yr
198,000 ÷ 0.011 lb/MMBtu = 18,000,000 MMBtu/yr allowed
At 7,457.5 MMBtu/hr full load:
  18,000,000 ÷ 7,457.5 = 2,414 hours/yr at full load

Running 24/7 (8,760 hr/yr):
  Average load = 18,000,000 ÷ 8,760 = 2,055 MMBtu/hr
  = 216 MW average
  = 27.5% of 785 MW capacity

To achieve 56 TPY CO (with best controls):

56 tons = 112,000 lb/yr
112,000 ÷ 0.015 lb/MMBtu = 7,466,667 MMBtu/yr
Running 24/7:
  Average load = 852 MMBtu/hr = ~90 MW
  = 11.5% of 785 MW capacity

The fundamental question:

Why build a 785 MW power plant if you can only run it at 11–27% capacity?

If the actual power demand is only 90–216 MW, there is no engineering reason to permit 785 MW of capacity. The disparity suggests the facility intends to operate at higher loads than the emission limits would allow.

5. What "Synthetic Minor" Avoids

By classifying as a minor source, the Ridgeline facility bypasses every major protection the Clean Air Act provides for communities near large pollution sources:

Requirement	Major Source	Minor Source (Ridgeline)
Air quality dispersion modeling	✅ Required	❌ Not required
Class I area impact analysis	✅ Required	❌ Not required
Federal Land Manager review	✅ Required	❌ Not required
Visibility impact assessment	✅ Required	❌ Not required
BACT determination	✅ Required	❌ Not required
Continuous emissions monitoring	✅ Required	❌ Not required
Pre-construction air monitoring	✅ Required	❌ Not required

You are pretending here that you can actually demonstrate that you will be below the major source threshold, even on the best of times, even if you have continuous monitoring. And here you don't even have that. You're truly flying blind.

— Dr. Ron Sahu, expert witness testimony, December 2025

6. Class I Area Impacts

Every criteria pollutant exceeds the PSD significance level that would trigger mandatory Class I area analysis:

Pollutant	PSD Significant Level	785 MW (Best Controls)	Multiple
NOx	40 TPY	359 TPY	9×
PM₂.₅	10 TPY	216 TPY	22×
PM₁₀	15 TPY	216 TPY	14×
SO₂	40 TPY	111 TPY	2.8×
CO	100 TPY	490 TPY	4.9×
VOC	40 TPY	69 TPY	1.7×

Dolly Sods and Otter Creek are among the most pristine wilderness areas in the eastern United States. The minor source classification means no one has modeled what 359 tons/year of NOx and 216 tons/year of particulate matter would do to their air quality.

7. What We Didn't Include

This analysis is conservative — it consistently uses assumptions favorable to the applicant:

Diesel backup: 30 million gallons of diesel on site. Diesel combustion produces significantly higher NOx, PM, and SO₂ than natural gas. Not included.
Part-load penalties: Gas turbines produce more pollution per MWh at reduced loads. Our calculations assume full-load efficiency. Reality would be worse.
Startup/shutdown: Elevated emissions during startup and shutdown cycles. Not included.
Heat rate: We used 9,500 Btu/kWh — better than many industrial turbines actually achieve. A more realistic 10,500 Btu/kWh would increase all emissions by ~10%.
TransGas applications: Two additional permit applications for 2,457 MW each were filed in September 2025. If related to the same development, total capacity could reach 5,699 MW.

Methodology

This analysis uses:

EPA AP-42, 5th Edition, Section 3.1 — Stationary Gas Turbines (Supplement F, April 2000)
40 CFR §52.21 — PSD regulatory thresholds
40 CFR §81.348 — Class I area designations for West Virginia
Standard engineering heat rate assumptions for simple-cycle gas turbines
Publicly available permit data and news reporting

The methodology is consistent with standard air quality engineering practice. All calculations are shown. Corrections and additional data are welcome.

A 785-megawatt natural gas power plant cannot be a minor source of air pollution.

This is not a close call.

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