An incident took place during the 1948 Presidential election campaign in which a supporter yelled out to Harry Truman during a speech “Give ‘em Hell, Harry!”. Truman replied, “I don’t give them Hell. I just tell the truth … and they think it’s Hell.” We have studied the Environmental Protection Agency’s (EPA) proposed rule to regulate carbon dioxide (CO2) emissions from existing power plants at length to be sure we can give our Members the truth. Here is the truth as we see it: The proposed rule does not make sense for our Members. At Talquin, we love clean air and a clean environment. Not only do we live within this environment, but our friends and family also live within this environment. Environmental responsibility is one of our key values. This value is what drove Talquin and nine other cooperatives to direct Seminole Electric to install emissions equipment on its coal plant in Palatka that makes it one of the cleanest power plants in the world. However, we believe there is a right way and a wrong way to do things. We believe the proposed EPA rule is wrong for our Members for the following reasons: 1. The EPA used assumptions to generate goals for each state without considering specific information for each state or each plant. In Florida, utilities have been working on coal plant efficiencies and energy efficiency improvements at generation locations since the 1980’s. Talquin Electric alone has performed over 2,300 energy audits for its Members over the last seven years to help Members increase energy efficiency at their homes and businesses. Seminole Electric has continually made efficiency improvements to its coal plant when the improvements proved to be economically viable. The EPA assumed in their rule making that all states could achieve the same plant and energy efficiency goals. Setting the same requirement for Florida as the other states that have not been doing these things puts an unfair burden on our Members. The EPA is expecting Floridians to have more efficient power plants, homes, and businesses than other states because they simply did not consider that we may have already been doing these things without their intervention. 2. The EPA wants us to shut down our coal plants before the end of their useful economic life. Forcing plants to close down while we still owe money on the plants and associated transmission lines will create an economic burden for our Members. Under this rule, our Members will be required to continue paying for a coal plant while purchasing energy from a second plant. Much of the debt our Members will have to pay comes from installing the environmental equipment that makes our plant one of the cleanest in the world. Closing these coal plants by the year 2020 and replacing their production with existing natural gas plants will result in lost jobs. No one can tell you truthfully that these jobs will be replaced any time soon. The EPA suggests Florida should close down 18 coal plants. Shutting down these plants will result in thousands of lost jobs in our state at a time when our economy is still struggling to recover. 3. The time frame to transition over 90% of our existing coal generation to natural gas is just too short. The EPA will not issue a final rule until June 2015. State plans are not due until June 2016. Utilities will not be able to start working before that time to make any transitions because we cannot make decisions based on anticipated results. If our state follows the EPA’s proposal to make the transition from coal to gas, we will only have until January 2020 to do so. Until the EPA approves the state plan, we will not know what types or sizes of transitions to make. For utilities, the short time frame from June 2016 to January 2020 is not long enough to make these transitions without creating significant risk to our electricity supply. To make matters worse, our state has the option under this proposed rule to work with other states in the region on a joint plan. Should Florida decide to work with other states, the plan will not be final until June 2018. As you can see, a plan that is not put in place until then could leave us with only 18 months to make the largest fuel source transition ever attempted in our industry. 4. This rule would force our Members to be over-dependent on natural gas. If Florida were to follow the rule as released by the EPA, we would be dependent on natural gas for about 85% of our electricity production. Being tied that tightly to one fuel source would introduce potentially dramatic reliability issues. Florida now depends on only two gas lines to provide this fuel to our state, one of which is on the bottom of the Gulf of Mexico. Every tropical event in the Gulf would threaten our ability to produce electricity for our Members. Being 85% dependent on natural gas would also mean that our electricity rates would be as volatile as natural gas prices have traditionally been. Another interesting aspect to this requirement from the EPA is that the rate of CO2 emissions from burning natural gas is 48% higher than our state’s goal. We are concerned that future requirements to reduce emissions would make Florida extremely vulnerable due to a lack of potential fuel sources. We absolutely should not make ourselves over-dependent on one fuel source. 5. The EPA’s proposed rule has an unrealistic time horizon for increasing Florida’s zero emissions energy production. Solar and nuclear energy are Florida’s only true options for zero emission electricity. To reach our state goal based on the rule’s assumptions, we would need to install the equivalent of at least eight large nuclear plants by the year 2030. Nuclear plants, as Floridians are well aware, take decades to build. To provide the equivalent amount of production using today’s solar panels would require the use of millions of acres of land. We would need the equivalent of almost 80,000 football fields covered in solar panels. Of course solar energy is also not produced consistently, so significant energy storage devices would be required that do not exist in today’s markets. In order for Florida to provide the large scale amount of renewable energy considered by the EPA’s rule, we would need significantly more time than the rule currently allows for more efficient solar panel development to reduce land mass use and for utility-scale energy storage to be developed and become economical. We should not rush to a solution that does not make long term sense. 6. Finally, this rule puts an unfair burden on Floridians as compared to other states. Florida reduced emissions significantly from 2005 to 2012. The EPA’s choice of 2012 for benchmarking means Florida did not receive any credit for the reductions we have already performed. Now, the EPA would have us sacrifice even more, and at levels not proportionate with most of the other states. While the rule would help lower CO2 emissions slightly (1% globally), the juice in this rule is just not worth the squeeze. The EPA can and should do better. Help us tell the EPA that this rule is not the right approach for Florida. Please visit action.coop or tellepa to voice your concerns.
Posted on: Mon, 20 Oct 2014 16:14:14 +0000
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