Crawford Generating Station

Crawford Generating Station is a coal-fired power station owned and operated by Edison International subsidiary Midwest Generation near Chicago, Illinois.

The 2011 NAACP report, "Coal Blooded: Putting Profits Before People in Illinois," ranked the Crawford station the highest environmental justice offender in the nation, due to its pollution output and close proximity to communities of color. The nearby Fisk Generating Station was ranked third.

In a deal announced on February 29, 2012 after a multi-year campaign by community groups, Midwest Generation said it will close its Fisk Generating Station in the Pilsen neighborhood by December 2012 and the Crawford Generating Station in Little Village by the end of 2014. On May 1, 2012, Midwest said it will shutter both plants in September 2012.

Plant Data

 * Owner: Midwest Generation EME LLC
 * Parent Company: Edison International
 * Plant Nameplate Capacity: 597 MW (Megawatts)
 * Units and In-Service Dates: 239 MW (1958), 358 MW (1961)
 * Location: 3501 South Pulaski Rd., Chicago, IL 60623
 * GPS Coordinates: 41.8283, -87.722801
 * Coal Consumption:
 * Coal Source: Strip mines in Wyoming
 * Number of Employees:

Emissions Data

 * 2006 CO2 Emissions: 3,299,472 tons
 * 2006 SO2 Emissions: 9,046 tons
 * 2006 SO2 Emissions per MWh:
 * 2006 NOx Emissions: 2,495 tons
 * 2005 Mercury Emissions: 145 lb.
 * People living within 3 miles: 373,690
 * Average income within 3 miles: $11,097 (48.0% of Illinois average)
 * People of color within 3 miles: 83.9% (64.3% Latino, 18.0% African-American)

Death and disease attributable to fine particle pollution from Crawford
In 2010, Abt Associates issued a study commissioned by the Clean Air Task Force, a nonprofit research and advocacy organization, quantifying the deaths and other health effects attributable to fine particle pollution from coal-fired power plants. Fine particle pollution consists of a complex mixture of soot, heavy metals, sulfur dioxide, and nitrogen oxides. Among these particles, the most dangerous are those less than 2.5 microns in diameter, which are so tiny that they can evade the lung's natural defenses, enter the bloodstream, and be transported to vital organs. Impacts are especially severe among the elderly, children, and those with respiratory disease. The study found that over 13,000 deaths and tens of thousands of cases of chronic bronchitis, acute bronchitis, asthma, congestive heart failure, acute myocardial infarction, dysrhythmia, ischemic heart disease, chronic lung disease, and pneumonia each year are attributable to fine particle pollution from U.S. coal plant emissions. These deaths and illnesses are major examples of coal's external costs, i.e. uncompensated harms inflicted upon the public at large. Low-income and minority populations are disproportionately impacted as well, due to the tendency of companies to avoid locating power plants upwind of affluent communities. To monetize the health impact of fine particle pollution from each coal plant, Abt assigned a value of $7,300,000 to each 2010 mortality, based on a range of government and private studies. Valuations of illnesses ranged from $52 for an asthma episode to $440,000 for a case of chronic bronchitis.

Table 1: Death and disease attributable to fine particle pollution from Crawford Generating Station
Source: "Find Your Risk from Power Plant Pollution," Clean Air Task Force interactive table, accessed March 2011

Pollution and pollution controls
According to a 2010 article in Chicago Reader, Midwest Generation has invested about $60 million in pollution control upgrades at Fisk and Crawford since purchasing the plants from ComEd in 1999. The Fisk and Crawford plants have mercury controls to meet state requirements, and plan to have nitrogen oxide controls by 2012. Scrubbers to reduce sulfur dioxide must be installed at Fisk by 2015 and Crawford's two units in 2017 and 2018. Midwest Generation has no plans to take measures to reduce direct particulate matter.

2006 agreement
As part of a 2006 agreement with the state of Illinois, Midwest said it plans to shut down the three smallest generating units in its fleet -- two units at the Will County Generating Station in Romeoville and one at its Waukegan Generating Station -- between the end of 2007 and the end of 2010. The company also said it is committed that its smallest plant -- the single-unit Fisk Generating Station in Chicago -- will either have additional controls for sulfur dioxide emissions or be shut down by the end of 2015. The same agreement to shut down or install additional controls applies to the Waukegan Generating Station by the end of 2014 and to the Crawford Generating Station in Chicago by the end of 2018.

July 2009 lawsuit
In July 2009, five groups of environmental and public health advocates announced their intent to file a Clean Air Act lawsuit against Edison International subsidiary Midwest Generation. The groups say Midwest's six Illinois power plants are decades old and do not have the appropriate pollution controls according to EPA standards. Specifically, the lawsuit will focus on opacity violations, a measurement of the light blocked by particulate matter from smokestacks at Midwest's Crawford, Fisk, Joliet, Powerton, Waukegan, and Will County stations.

The concerned groups include Citizens Against Ruining the Environment, the Environmental Law and Policy Center, Natural Resources Defense Council, the Respiratory Health Association of Metropolitan Chicago, and Sierra Club. The six power plants in question are located in working class and minority neighborhoods, raising concerns about environmental justice. The groups expect to file suit in 60 days, unless Midwest Generation comes into compliance or stops operating, or unless the EPA takes other measures. Shannon Fisk, an attorney for NRDC, described Midwest's Fisk and Crawford plants as, "two dinosaurs in the middle of a large city. They should have cleaned up decades ago. Running those plants is inexpensive for the company, but it's very expensive for public health." A 2001 study by a professor at the Harvard University School of Public Health found that particulate matter from the Fisk and Crawford plants contributes to 41 deaths, 550 emergency room visits, and 2800 asthma attacks each year.

Midwest spokesman Doug MacFarlan said the company is being targeted unfairly, and that Midwest's plants release less particulate matter than most. He also said the company had responded to local complaints by reducing both the amount of coal piled up at Crawford and the dust that blows off barges transporting its coal. "We really believe we have demonstrated environmental responsibility at those plants," McFarlan said. In 2006, Midwest made an agreement with the state of Illinois to reduce emissions at its coal plants. The company has installed mercury controls, but has not decided whether to install scrubbers or shut the plants down. The company has until 2015 to install scrubbers at its Fisk plant and until 2018 to install them at Crawford.

August 2009 lawsuit
On August 28, 2009, less than a month after the public health lawsuit was filed, the EPA, Department of Justice, and state of Illinois announced that they would also be filing suit against Midwest Generation for illegal emissions of particulate matter, nitrogen oxides, and sulfur dioxide. Their claim charged that the company had upgraded its plants, including Fisk and Crawford, without adding the modern pollution controls required under the Clean Air Act.

Lawsuit dismissed and refiled
In March 2010, a federal judge sided with Midwest, dismissing the allegations of Clean Air Act violations at five Illinois coal-fired power plants and partially dismissing claims of violations at a sixth plant. The judge said the New Source Review violations occurred at the time of construction, and that Midwest Generation cannot be liable for the modifications that occurred prior to Midwest Generation's ownership of the plants. The one exception was the Will County Generating Station, as the utility made modifications after buying it from ComEd. The judge barred claims of monetary relief on that claim, however, because the five-year statute of limitations has expired since the major modifications were made in 2000. The judge's order did not address additional allegations that Midwest Generation had violated Title V operating permits as well as opacity and soot limitations under Illinois's federally approved pollution control plan.

In June 2010, the US EPA, the State of Illinois, and several environmental action groups filed amended complaints similar to the prior 2009 complaints, but also seeking to add Commonwealth Edison and Edison Mission Energy (EME) - an indirect wholly owned subsidiary of Edison International - as defendants.

Permits
In late 2010, Midwest secured state permits to install pollution-control equipment that would reduce soot- and smog-forming emissions from its six coal-fired power plants.

In documents discovered in February 2011, however, Midwest Generation signaled it might delay installing pollution controls at its plants "for the maximum time available." The documents, filed with the Securities and Exchange Commission, said whether the company actually makes the $1.2 billion investment depends in part on "regulatory and legislative developments," according to its latest financial documents. The documents conveyed a starkly different message from public statements by Midwest Generation executives, who have pledged to make "meaningful improvements in the environmental performance of our plants."

Poll finds most Chicago residents support pollution controls
A 2011 poll showed that voters in every part of Chicago support efforts by the City to reduce pollution from the Fisk Generating Station and the Crawford Generating Station. Of the 600 registered Chicago voters polled, 72% said they would support a plan that reduces soot pollution from the coal plants by 90% and carbon dioxide pollution by 50%. After hearing arguments both opposing and favoring stricter pollution standards, 64% of respondents said they would support City efforts to reduce pollution from Fisk and Crawford. In a separate question, 56% of those surveyed said protecting the environment is good for the economy. Fako & Associates conducted the poll, which has a margin of error of 4% and was commissioned by the Chicago Clean Power Coalition, a grassroots coalition of more than 60 Chicago organizations.

Chicago's largest carbon dioxide emitter
According to the U.S. Environmental Protection Agency greenhouse gas database, Crawford and Fisk are Chicago's largest industrial sources of heat-trapping carbon dioxide, releasing 4.2 million metric tons in 2010. Altogether, Midwest Generation plants emitted more than 31 million metric tons of carbon dioxide in 2010.

Emanuel sets ultimatum on Fisk and Crawford Plants
On February 21, 2012, after months of negotiations, Mayor Rahm Emanuel announced that Midwest Generation had one week to figure out how to clean up its Fisk Generating Station and Crawford Generating Station plants, either by installing pollution controls or by converting to a less polluting fuel. If Midwest doesn't broker a deal by then, Emanuel's City Council allies will push an ordinance (the Chicago Clean Power Ordinance) that could force the Crawford and Fisk plants to shut down within the next two years.

In Fall 2011, Emanuel's office considered a deal floated by Midwest Generation that would have shut down the coal plants in return for a long-term contract to buy electricity from a wind farm the company owns in northwest Illinois. But House Speaker Michael Madigan reportedly scuttled the idea, forcing the city, company, and others back to the negotiating table.

Ald. George Cardenas, 12th, chairman of the Health and Environmental Protection Committee, said he is ready to call a hearing in March 2012 on the proposed ordinance if the city and company fail to resolve the dispute.

Midwest announces closure
In a deal announced on February 29, 2012, and after a lot of pressure from community groups, Midwest Generation said it will close its Fisk Generating Station in the Pilsen neighborhood by December 2012 and the Crawford Generating Station in Little Village by the end of 2014. On May 1, 2012, Midwest said it will shutter both plants in September 2012.

Crawford Plant and Environmental Justice
The Crawford and Fisk Generating Station are located on the lower west side of Chicago, in the predominantly Latino areas of Pilsen and Little Village, as well as nearby neighborhoods with a significant population of African Americans, raising issues around environmental justice and coal. Within a 3-mile radius of the Crawford Plant live 373,690 residents, 83.9% of which are non-white with a per-capita income of $11,097. The plant does not have an emissions scrubber. Within miles of each plant are homes, parks, schools, etc. Crawford and Fisk are among over 100 coal plants near residential areas.

2010 report: Chicago's Fisk and Crawford Plants cost public up to $1 billion since 2002
On October 20, 2010, the Environmental Law and Policy Center released a study, ELPC Report Finds Chicago Coal Plants Caused Up To $1 Billion in Health Damages Since 2002 finding Midwest Generation's Crawford and Fisk coal plants in Pilsen and Little Village may have caused between $750 million and $1 billion in public health related damages since 2002. The plants operate on equipment built between 1958 and 1961 and skirt Federal Clean Air Act regulations since they were built before 1976. The report uses data culled from various sources such as a 2010 National Research Council study and the Harvard School of Public Health’s Illinois Power Plant Study.

According to the study, the plants cause more than $127 million in 2010 dollars in health damages yearly, based on 2005 emissions. Particulate matter released into the air causes cardiovascular and respiratory diseases, heart attacks, premature death and more. A spokeswoman for Midwest Generation told WBEZ that there is no tie between the plants and public health, putting the blame on traffic instead. The ELPC supports the Chicago Clean Power ordinance, which would require Midwest Generation to reduce PM pollution within 4 years. Howard Learner, executive director for the ELPC, said via press release “Soot and smog from Chicago coal plants is making us sick and costing us millions. Cleaning them up is the right thing to do for our health, our environment and our economy.”

2011 Report: Crawford top environmental justice offender
The 2011 report, "Coal Blooded: Putting Profits Before People in Illinois" by Adrian Wilson, NAACP, Little Village Environmental Justice Organization (LVEJO), and the Indigenous Environmental Network used an algorithm combining levels of sulfur dioxide and nitrogen oxide emissions together with demographic factors in order to calculate an environmental justice score for the 431 coal-fired power plants in the U.S. Twelve plants were ranked the top environmental justice offenders, producing a total of 48,582 Gigawatt-hours (GWh) of electricity in 2005 — only 1.2% of total U.S. electricity production, yet affecting a total of 1.78 million Americans who live within 3 miles of one of the 12 plants, with an average per capita income of $14,626 (compared with the U.S. average of $21,587), and 76.3% people of color.

The plants were:
 * 1) Crawford Generating Station, Chicago, IL (Edison International)
 * 2) Hudson Generating Station, Jersey City, NJ (PSEG)
 * 3) Fisk Generating Station, Chicago, IL (Edison International)
 * 4) Valley Power Plant, Milwaukee, WI (Wisconsin Energy)
 * 5) State Line Plant, Hammond, IN (Dominion)
 * 6) Lake Shore Plant, Cleveland, OH (FirstEnergy)
 * 7) Gallagher Generating Station, New Albany, IN (Duke Energy)
 * 8) Bridgeport Harbor Station, Bridgeport, CT (PSEG)
 * 9) River Rouge Power Plant, River Rouge, MI (DTE Energy)
 * 10) Cherokee Station, Commerce City, CO (Xcel Energy)
 * 11) Four Corners Steam Plant, Niinahnízaad, NM (Arizona Public Service Company)
 * 12) Waukegan Generating Station, Waukegan, IL (Edison International)

August 2011: Environmental Justice Act for new projects, not existing
In August 2011, Illinois Governor Pat Quinn signed into law the Environmental Justice Act, creating a 10-person commission to determine whether people in poor communities are disproportionately affected by pollution. The environmental justice commission is charged with reviewing policies and laws, advising state entitities on environmental issues, creating a criteria for assessing environmental justice issues in communities and recommending how to address these issues to the Governor. The act, however, applies to new projects, rather than existing ones. The IEPA has had an environmental justice policy for five years, but the commission will involve a wider variety of voices – from local government to affected communities concerned with environmental justice – examining social and economic justice as it is affected by environmental decisions.

October 13, 2010: Protesters rally to shut down Chicago Power Plants
On October 13, 2010 protesters in Chicago rallied to shut down Chicago's two coal-fired power plants, Fisk Generating Station in Pilsen and Crawford Generating Station in Little Village. Midwest Generation, a subsidiary of Edison International, owns the plants.

“This is the year we’re going to end coal in Chicago,” said Chicago author Jeff Biggers.

Greenpeace and the Pilsen Environmental Rights and Reform Organization (PERRO) organized the Chicago Clean Power Coalition rally at Alivio Medical Center.

A group of people in T-shirts lettered with “Quit Coal” and wearing green cardboard oxygen masks stood outside in the hot sun to listen to speakers explain why clean air is so important.

“This is the year the next governor and the next mayor will announce that these [plants] are shutting down,” Biggers said.

The coalition sought to raise awareness about pollution that is emitted from both power plants, which are located in dense urban areas.

November 1, 2010: Day of Dead procession held in Chicago
On November 1, 2010 Chicago activists held a "Day of the Dead" rally in "remembrance of the lives lost" to the pollution caused by the Fisk Generating Station and Crawford Generating Stations. Author Jeff Biggers wrote:


 * More than 66 premature deaths, 104 heart attacks, and thousands of asthma attacks and cases of chronic bronchitis--that is the tragic symbol at the altar of Chicago's decrepit coal-fired plants in the Pilsen and Little Village neighborhoods.

"The public can't afford the huge health costs from the Fisk and Crawford coal plants in Chicago neighborhoods," said Howard Learner, Executive Director of the Environmental Law & Policy Center, on the release of the organization's report last month. "It's time for Midwest Generation to be socially responsible and clean them up or shut them down."

April 2011: Activists scale plant, call for it to close
On April 20, 2011, six local activists from Chicago climbed over a fence at the Crawford coal plant, scaled a mountain of coal, and unfurled a huge 7′ x 30′ banner reading “Close Chicago’s Toxic Coal Plants.” The activists - representing Little Village Environmental Justice Organization (LVEJO), Rising Tide North America, Rainforest Action Network, and the Backbone Campaign - called on the City of Chicago to close both the Crawford and nearby Fisk plant. The six activists were later arrested.

The groups were demanding the closure of the plant just one day before the much-anticipated Clean Power Ordinance hearing, which could force the plant to undergo major modifications to upgrade their pollution controls. Mayor Daley may call for a City Council vote on the Ordinance before he leaves office on May 4, 2011. Led by 49th Ward Alderman Joe Moore, Clean Power Chicago organizers recently announced that 26 co-sponsors have signed on to the ordinance, among other aldermen pledges to vote in favor.

Impact of closing the plant on electricity generation
According to Pilsen Environmental Rights and Reform Organization, none of the electricity generated at the Crawford Station and nearby Fisk Generating Station is actually sold to Illinois utilities, but rather is used to maintain reliabity of the electrical grid during peak times. According to Midwest's website, "the electricity produced by Fisk and Crawford goes directly onto the local electric grid for use in Pilsen, Little Village and the downtown district." According to a 2010 article in Chicago Reader, Fisk, Crawford, and State Line contribute to the energy load that Midwest Generation and Dominion sell to ComEd to power the Chicago area, but the plants closing down would pose no risk of an electricity shortage in the region, according to ComEd spokesman Bennie Currie, as Illinois is a net exporter of power.

Midwest Generation has also said that the plants feed into the inter-state PJM Interconnection and help maintain a stable flow of electricity and prevent disruptions through city power lines. Yet, PJM maintains an installed reserve margin of at least 15 percent over record peak demand, according to the Sierra Club's Midwest Director James Gignac: "The grid operators maintain plenty of additional capacity and are in fact planning for multiple coal units to come off-line in the coming years." ComEd has said the plants closing down would pose no risk of an electricity shortage or disruptions if the grid were updated, at a cost of $178 million, which would be funded by rate increases of about 20 cents per month for residential customers, according to ComEd.

Environmentalists envision the sites transformed into solar farms, like the one in West Pullman, or factories making wind turbine components or other "green" industry. In neighborhoods with among the city's least green space, residents would also like to see parks.

Impact of proposed cap and trade on existing U.S. coal plants
It remains unclear how the proposed Waxman-Markey Climate Bill, which passed the U.S. House of Representatives in June 2009 and heads to discussion by the Senate in the fall of 2010, will impact existing coal plants like Crawford. Although the version of the American Clean Energy and Security Act (ACES) that passed the House requires a 50 percent reduction in carbon emissions from new coal plants by 2025, it mandates no specific reduction requirements for existing plants.

Environmental groups and public health advocates are concerned that, by driving up the cost of new plants and offering free emissions allowances or carbon offsets for older facilities, the bill may result in even heavier reliance on an aging fleet of coal plants. Some groups have expressed concern that the climate change legislation may end up having similar issues to the 1977 Clean Air Act, which grandfathered in older plants and largely exempted them from requirements that facilities use the best available pollution-control technologies. Environmental advocates hope that the Senate will add regulations to ACES that will lead to the closure of older, highly polluting plants. Midwest parent Edison International supported the current version of the Waxman-Markey bill.

Related SourceWatch Articles

 * Existing U.S. Coal Plants
 * Illinois and coal
 * Edison International
 * United States and coal
 * Global warming

External Articles

 * Mick Dumke, "The latest salvo in the fight to clean up Chicago's air," Chicago Reader, July 28, 2009.