Project River: Air Quality & Public Health

A source-based review of combustion emissions, biomass handling, diesel traffic, permitting, monitoring, and the evidence needed to characterize local exposure.

Permit-grade emissions and dispersion data matter more than generalized claims of either safety or harm.

Open · Detailed issue review

Current status

Project River’s published concept includes natural-gas generation, woody-biomass generation, fuel handling, construction activity, and substantial freight movement. Those components can have different air-emission profiles. The reviewed record does not yet contain a complete Project River emissions inventory, permit application, dispersion model, or receptor-specific exposure analysis.

Sources:RIV-007RIV-009RIV-013RIV-020RIV-027RIV-028

What is documented

Records and statements that can be tied to an identified source.

Developer Statement

The project includes both gas and biomass generation

Project materials describe up to 1,000 MW of natural-gas generation and 500 MW of woody-biomass generation. That establishes the proposed source categories, not their final permitted emissions.

Sources:RIV-013

Government Statement

Air permitting is separate from city land-use approval

TDEC maintains a separate air public-participation process. A zoning or annexation action does not establish that air permits have been issued or that permit-grade emissions have been reviewed.

Sources:RIV-007RIV-009

Third-Party Analysis

Outside analysis has raised emissions questions

Local reporting and SELC materials have raised questions about combustion emissions, biomass scale, truck traffic, and the information needed to evaluate potential air impacts. Those are outside analyses, not final agency findings.

Sources:RIV-020RIV-028

What the project says

These statements are attributed to the project or its participants and are not automatically independent findings.

Developer Statement

Project materials describe a modern, controlled energy campus

Project communications describe the campus as engineered to meet applicable requirements and emphasize planned operating controls. Those statements need to be matched to the actual permit application, equipment, control technologies, and monitoring conditions.

Sources:RIV-013RIV-016

Regulatory and exposure context

A useful air review separates source emissions, permit limits, modeled concentrations, background conditions, and actual measured exposure.

Government Statement

Actual permit filings should control the air review

The TDEC air-notice system and Chattanooga Environmental Field Office are the relevant government sources in the current register for confirming filing status, public-comment opportunities, and issued conditions.

Sources:RIV-007RIV-009

Placeward Analysis

Different source categories should not be collapsed into one number

Gas turbines, biomass conversion, wood storage and handling, backup equipment, construction dust, and diesel freight can involve different pollutants, averaging times, controls, and monitoring methods. A complete source inventory should identify them separately.

Sources:RIV-013RIV-020RIV-029

What remains unresolved

  • ?What are the hourly and annual emissions by source and pollutant for each project phase?
  • ?Which emission-control technologies and operating limits apply to gas generation, biomass conversion, wood handling, and backup equipment?
  • ?What background concentrations and meteorological data will be used in dispersion modeling?
  • ?What are modeled concentrations at the nearest homes, schools, public spaces, and other sensitive receptors?
  • ?How are startup, shutdown, maintenance, upset, and emergency operating conditions represented?
  • ?How will fugitive wood dust, construction dust, and diesel freight emissions be controlled and monitored?
  • ?Which emissions data will be publicly available after startup, and at what frequency?

Evidence needed

Permit-grade emissions inventory
Each stationary and fugitive source, pollutant, control device, hourly rate, annual rate, and operating assumption by phase.
Air permit applications and draft permits
Actual TDEC filings, modeling protocols, permit limits, monitoring terms, reporting requirements, and public-comment documents.
Dispersion modeling
Model inputs, meteorology, terrain, receptor grid, background concentrations, cumulative sources, and modeled results.
Baseline air data
Existing local conditions collected with methods adequate to support before-and-after comparison where appropriate.
Dust and freight controls
Wood-handling design, enclosure, housekeeping, truck-idling controls, road-dust measures, and complaint-response procedures.
Supporting detail

Go deeper without losing your place

Expand chronology, community concerns, research priorities, verification methods, and related guidance as needed.

Community concerns in the record3 items

These entries document concerns raised by residents or outside advocates. They are not presented as proven factual conclusions.

Community Concern

Combustion emissions near homes and schools

Community commentary has raised concern about whether combustion-related pollutants could affect nearby residents, schools, or other receptors. The current record does not yet contain receptor-specific modeling sufficient to characterize that risk.

Sources:RIV-022RIV-027RIV-028

Community Concern

Wood dust and material handling

Residents have also raised questions about dust and particulate emissions associated with biomass unloading, storage, drying, and handling.

Sources:RIV-027RIV-028

Community Concern

Diesel and construction emissions

Truck traffic and construction activity are recurring community concerns and should be accounted for separately from stationary-source permit limits.

Sources:RIV-020RIV-027RIV-028

Additional considerations3 items

Potential advantage if controls are demonstrated

Modern combustion and material-handling systems can incorporate substantial emissions controls. The relevant question is what equipment, limits, monitoring, and enforcement will actually apply here.

Potential risk if assumptions are incomplete

Understating operating hours, fuel characteristics, fugitive sources, startup conditions, or traffic could materially change the emissions picture.

The verification question

Verification requires comparing public-facing claims with the permit-grade source inventory, dispersion model, final permit limits, and post-startup monitoring data.

Verification approachMethod
  1. Inventory every source.Build a phase-by-phase list of stationary, fugitive, construction, and freight-related sources rather than focusing on one headline pollutant.
  2. Use permit documents as the technical baseline.Compare project statements with actual TDEC applications, modeling assumptions, draft permits, and final conditions.
  3. Check receptor-level results.Review modeled concentrations and assumptions at nearby homes, schools, and other sensitive locations rather than relying only on stack-level emissions.
  4. Track enforceability.Identify what is continuously monitored, periodically tested, self-reported, inspectable, and subject to corrective action.
Research addendum · October 1, 2026

PFPI audit: emissions estimates need a River-specific process model

PFPI’s emissions concerns are appropriate leads for permitting review, but generic wood-combustion factors do not resolve Project River’s final emissions profile.

Full PFPI technical audit →
Placeward Analysis

EPA provides established screening factors for wood-residue combustion

EPA AP-42 Section 1.6 contains emissions factors for wood-residue combustion in boilers and is a legitimate screening reference when the process matches. Project River public descriptions, however, have used differing terms including pyrolysis, biochar, boilers, and other conversion descriptions. Generic factors should therefore not be presented as final Project River emissions without matching them to the actual equipment and process.

Sources:RIV-013RIV-017RIV-038RIV-043

Placeward Analysis

The air permit should become the controlling technical record

A defensible Project River emissions assessment needs the actual fuel specification, heat input, process flow, control equipment, stack parameters, startup/shutdown assumptions, expected annual operating hours, pollutant calculations, and dispersion modeling submitted to TDEC. PFPI calculations can identify questions to test against that filing but cannot substitute for it.

Sources:RIV-007RIV-038RIV-043

Placeward Analysis

The “carbon-negative” claim is not yet quantitatively reproducible from the public project record

Project River currently states that pyrolysis and biochar would make the biomass side carbon-negative, while also saying its methodology and verified tonnage figures will be published later. Until the lifecycle boundary, feedstock assumptions, biochar yield and stability, process emissions, and transport inputs are published, The carbon-negative statement remains an attributed project claim rather than an independently established result.

Sources:RIV-013RIV-038

This addendum compares PFPI’s analysis with stronger or more direct sources and identifies which claims are supported, assumption-dependent, unresolved, or unverified. PFPI’s conclusions remain third-party analysis rather than project facts.