Enron Mail

From:alan.comnes@enron.com
To:tom.alonso@enron.com, ray.alvarez@enron.com, robert.badeer@enron.com,tim.belden@enron.com, christopher.calger@enron.com, jeff.dasovich@enron.com, michael.driscoll@enron.com, mark.fischer@enron.com, chris.foster@enron.com, mark.guzman@enron.com, stev
Subject:FW: FW: Davis Eases Power Plant Pollution Rules
Cc:
Bcc:
Date:Mon, 18 Jun 2001 10:33:00 -0700 (PDT)

Here is information on the ability of CA generators to run in excess of the=
ir=20
orginal offset NOx quantities.

Alan Comnes

-----Original Message-----
From: Schoen, Mary =20
Sent: Monday, June 18, 2001 3:23 PM
To: Comnes, Alan
Cc: Guerrero, Janel
Subject: Re: FW: Davis Eases Power Plant Pollution Rules

The following is more explanation about the recent Executive Order (EO)=20
signed by the Governor of California on June 11, 2001. In order to avoid=
=20
future blackouts, Governor Gray Davis is waiving limits on hours of operati=
on=20
and the associated emissions for natural gas-fired peaker units if they=20
adhere to certain conditions. He is requesting local air districts to allo=
w=20
natural gas-fired peaker power plants to operate in excess of their hourly,=
=20
daily, quarterly and/or annual emission limitations if they do the followin=
g:

1. Agree to sell power to the California Department of Water Resources or t=
o=20
a utility located in California=20
2. To serve an operating utility=01,s own load
3. Agree to sell to another California-based utility

The gas-fired peaker units must also pay a mitigation fee to the local air=
=20
districts of $7.50 per pound of oxides of nitrogen (NOx) and $1.10 per poun=
d=20
of carbon monoxide (CO) emitted. (The Governor set this number - it is,=20
however, the same amount the South Coast AQMD is charging for NOx offsets i=
n=20
the modifications it made to the RECLAIM program.) These mitigation fees wi=
ll=20
be used to clean up or retire other sources of pollution in the same air=20
basin. The Governor is ordering the California Air Resources Board to work=
=20
with the Environmental Protection Agency to ensure that power plants willin=
g=20
to operate under this order obtain the necessary approvals.

As you know, there are many peaking plants that are close to exhausting the=
ir=20
allowable operating hours. Once these facilities exhaust the amount of=20
allowable hours they would have to either shut down the units or negotiate =
an=20
agreement with the local air agency to continue to operate. With the=20
exception of Mirant Potrero in San Francisco and Reliant Energy Mandalay in=
=20
Ventura County, no facilities have negotiated such agreements. The EO issu=
ed=20
by the Governor gives the peaker facilities a blanket approval to operate=
=20
beyond the restrictions. The Governor believes that waiving of the=20
requirements will also minimize reliance on backup diesel-fired generators,=
=20
which have even higher emissions than the natural gas peakers. In my=20
previous discussions with the US EPA Region 9, they did say they were willi=
ng=20
to work with the state to provide variances to power plants' operating=20
limits. However, in the two instances mentioned above, the EPA required t=
he=20
plants to agree to install pollution control equipment at a specific future=
=20
date. This aspect of the agreement was critical to EPA, because the=20
increased emissions from the peakers with increased hours are now significa=
nt=20
enough (major source status) to trigger New Source Review which requires=20
installation of Best Available Control Technology (BACT). The EO by the=20
Governor makes no mention of future controls.

According to municipal utilities and other generators, the Governor's actio=
n=20
could provide up to 1,200 Megawatts of additional power this summer by=20
expanding the number of hours of operation at natural gas-fired plants. T=
he=20
EO will expire on October 31, 2001, unless revoked, modified or extended by=
=20
further executive order. The air director of the Ventura air board has=20
already sent comments opposing this order due to its negative air impacts. =
=20
Environmentalists will also no doubt object. The EPA has not yet responded=
. =20
Despite the potential negative environmental effects, the political pressur=
e=20
will be strong to let these plants operate. I will keep my ears open for=
=20
additional developments on this matter, please let me know if you have any=
=20
questions.



From: Alan Comnes/ENRON@enronXgate on 06/12/2001 11:57 AM
To: Mary Schoen/NA/Enron@Enron
cc: =20

Subject: FW: Davis Eases Power Plant Pollution Rules=20


Mary,

Any insight into this latest change would be appreciated by the traders. I=
s=20
this order any different than the SCAQMD $7.50/ton program already=20
implemented? Will EPA allow that state to do this?

Thanks,

Alan Comnes
-----Original Message-----
From: Comnes, Alan =20
Sent: Tuesday, June 12, 2001 9:55 AM
To: Alonso, Tom; Alvarez, Ray; Badeer, Robert; Belden, Tim; Calger,=20
Christopher F.; Dasovich, Jeff; Driscoll, Michael M.; Fischer, Mark; Foster=
,=20
Chris H.; Guzman, Mark; Hall, Steve C.; Heizenrader, Timothy; Kaufman, Paul=
;=20
Mainzer, Elliot; Mallory, Chris; Mara, Susan; Motley, Matt; Perrino, Dave;=
=20
Platter, Phillip; Richter, Jeff; Scholtes, Diana; Swain, Steve; Swerzbin,=
=20
Mike; Williams III, Bill; Wolfe, Greg
Subject: Davis Eases Power Plant Pollution Rules=20


=20
Tuesday, June 12, 2001=20
Davis Eases Power Plant Pollution Rules=20
Electricity: Order will allow more production from heavily polluting=20
'peaker' facilities.=20


By DAN MORAIN, Times Staff Writer





SACRAMENTO--Gov. Gray Davis agreed Monday to lift air emission limits =
on=20
heavily polluting power plants and allow them to run at capacity this summe=
r=20
as long as the electricity they produce is sold in the state.=20
State officials said the plants must be pressed into use to avoid=20
blackouts.=20
Davis' executive order lets the generators build the cost of air=20
pollution fines into the price the state pays for electricity produced by=
=20
natural gas-fired power plants, said Catherine Witherspoon of the Californi=
a=20
Air Resources Board.=20
Municipal utility districts--including the Los Angeles Department of=
=20
Water and Power--and independent power companies could supply as much as=20
1,200 megawatts from so-called peaker plants, facilities that generally are=
=20
permitted to operate for only a few hundred hours a year because they pollu=
te=20
so heavily. That is enough power for more than 1 million homes.=20
Other gas-fired power plants that have been shut down because of air=
=20
pollution restrictions also could be started up as a result of the order.=
=20
In a news conference Monday, state officials said the order will have=
=20
the effect of lowering air pollution by limiting the use of far dirtier=20
diesel generators, which industry could use if power supplies are threatene=
d.=20
"If we don't get every last megawatt we can [from natural gas-fired=20
plants]," said Witherspoon of the air board, "we will see people turning to=
=20
diesel more frequently."=20
Added Kellan Fluckiger, a top energy advisor to Davis: "If you don't r=
un=20
these, you're either going to have outages or you're going to run something=
=20
dirtier."=20
Fluckiger said the order expands "the number of hours these things can=
=20
run and the amount of energy they can produce."=20
New natural gas-fired power plants emit about half a pound per=20
megawatt-hour of operation of ozone-producing pollutants. The plants affect=
ed=20
by the order emit between two and five pounds of oxides of nitrogen per=20
megawatt-hour.=20
If the plants are pressed into operation for 200,000 megawatt-hours th=
is=20
summer, there will be between 400,000 and 1 million additional pounds of=20
oxides of nitrogen emitted into the air.=20
The state probably will end up paying the fees associated with the ext=
ra=20
pollution through higher electricity prices. The fees amount to $7.50 per=
=20
pound of oxides of nitrogen--or $7.5 million if the plants operate for=20
200,000 hours--and $1.10 per pound of carbon monoxide emissions. The money=
=20
would be used to reduce air pollution from other sources.=20
"Under this order, dirty power plants can run as long as they want and=
=20
pollute as much as they want so long as they pay into a fund," said Gail=20
Ruderman Feuer, senior attorney with the Natural Resources Defense Council.=
=20
"Our concern is that there's no guarantee that the fund will result in=20
emission reductions any time soon."=20
A Ventura County air pollution control official said that running one=
=20
peaking power plant operated by Reliant Energy for one hour is the equivale=
nt=20
of adding 20,000 new cars to Ventura County highways for an hour. Reliant=
=20
Energy could not be reached for comment Monday night.=20
"To the extent that they run when not needed for an emergency, it's=20
going to put more air pollution into Ventura County skies and it's going to=
=20
make our air dirtier," said Dick Baldwin, air pollution control officer for=
=20
Ventura County.=20
Los Angeles DWP Director David Wiggs hailed the order, saying it was=
=20
needed so the city can sell the state as much as 1,000 megawatts of power=
=20
this summer.=20
"This was the issue we had to have solved or we could not offer any of=
=20
our excess capacity to the state," Wiggs said.=20
He added, however, that the city and state have not yet agreed on a=20
price for the power. Wiggs said the city is "negotiating to get our cost as=
=20
low as we can legally charge" so that customers of the city utility distric=
t=20
are not subsidizing consumers in the rest of the state. Municipal utility=
=20
districts elsewhere in the state also are expected to benefit from the orde=
r.=20
Though the order was aimed at spurring municipal utilities to sell pow=
er=20
to the state, it also applies to independent power producers such as Relian=
t=20
Energy of Houston and Duke of North Carolina--both of which have called on=
=20
Davis to ease air pollution restrictions on their old natural gas-fired=20
facilities.=20
"This puts more money in the Texans' pockets and more air pollution in=
=20
Ventura County residents' lungs," said Baldwin of Ventura County.=20
Doug Allard, a Santa Barbara County air pollution control officer, als=
o=20
said it seems as if the governor is giving private power generators much of=
=20
what they had sought.=20
"We have serious concerns about the order," said Feuer of the Natural=
=20
Resources Defense Council. "It's taking the discretion away from local air=
=20
districts to regulate power plants in their region."=20


* * *
Times staff writer Nancy Vogel contributed to this story.=20
RELATED STORY=20
Utility: Edison plans to raise $1 billion in debt restructuring. C1=20
Copyright 2001 Los Angeles Times =20


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