Enron Mail

From:rockford.meyer@enron.com
To:stanley.horton@enron.com
Subject:Letters from Tampa Paper Regarding TECO conversion - Good and Bad
Cc:
Bcc:
Date:Fri, 14 Jan 2000 08:00:00 -0800 (PST)

A little backround surrounding the TECO pollution problems at Gannon.

Rock


---------------------- Forwarded by Rockford Meyer/FGT/Enron on 01/14/2000
04:00 PM ---------------------------
From: David Rosenberg on 01/14/2000 03:47 PM
To: Rockford Meyer/FGT/Enron@ENRON
cc: James Saunders/FGT/Enron@ENRON

Subject: Letters from Tampa Paper Regarding TECO conversion - Good and Bad

Couldn't remember if I had passed along copies of these letters to the editor
from the Tampa Tribune.

Dec 20, 1999 - 07:33 PM

TECO is trying to do the right thing
JOHN RAMIL

At Tampa Electric, we're trying to do the right thing. Our goal
is a challenging one - to
meet the needs of our customers and operate a financially sound
business in an
environmentally responsible way.

Even those with extreme viewpoints should agree that achieving a
balance like this is
never easy. But in our $1 billion agreement with the Florida
Department of
Environmental Protection, we believe we've found a way.

As with any major shift in thinking, the road to our
environmental plan has been far
from simple. Since early 1999, we have spent many, many hours in
negotiation with
two federal agencies, each, perhaps, with different objectives.

In our dialogue with EPA and the Department of Justice, we
invested a great deal of
time and energy trying to find common ground on which to develop
a long-range
environmental strategy for our company.

When this did not happen, the state of Florida stepped in, as
was its right and duty as
the agency with primary responsibility for implementation and
enforcement of the
environmental emission standards in question.

As an agency ready to act, DEP helped us craft an agreement that
actually takes us
further than any of our negotiations with the federal entities.

As a result, Tampa Electric has accomplished what we originally
set out to do with
the EPA - our nitrogen oxide emissions will drop by 85 percent
by the year 2010 from
1997 levels. Using 1994 as the starting point, the ultimate
reductions in nitrogen oxide
will exceed 90 percent.

These reductions are significant on their own, but even more so
when you consider
that Tampa Electric must simultaneously generate almost 40
percent more electricity
for our customers over the same time period.

But the federal government has said it is still not satisfied.
They want penalties. In
fact, that may be what this case is all about.

This is a dramatic departure from EPA's position stated on Nov.
3, when they
announced their suit against utilities around the country. Then,
they said the purpose
of the lawsuit was not to penalize, but to improve the air.

That's exactly what Tampa Electric is doing, with the direction
of the DEP, in a way
that balances the environment, our customers and our employees.

We're also a little confused as to why Hillsborough EPC chief
Roger Stewart has
criticized this landmark plan. Two years ago, when we announced
a voluntary plan in
concert with EPC to reduce nitrogen oxide emissions by 10
percent, Stewart was
enthusiastic in his support. Now, a much higher 85 percent
reduction draws his
criticism.

Like any business, we have many stakeholders for whose interests
we are concerned.
The environment is a critical one, but it is still one of many.

We must also consider the effect of any major capital
expenditures on our customers'
rates, and we must make those expenditures in a way that is
fiscally sound, so that
we can continue to deliver reliable and economical electricity
to meet our community's
growing energy needs.

The $1 billion commitment we have pledged to environmental
improvements
represents a huge expenditure, particularly for a company with
$3 billion in overall
assets.

Yet we recognize the positive impact environmental improvements
will have for our
other stakeholders, including our customers in the Tampa Bay
area. Toward this end,
we are excited to have found a way to undertake the largest
environmental cleanup
effort Florida has seen in the last quarter-century.

We're proud of what we will accomplish on behalf of Florida's
environment, while
keeping our prices low and our service high. That, we believe,
is the right thing to do. an 3, 2000 - 05:03 PM

Now for the Negative Side from January 3


On Nov. 3 the U.S. Environmental Protection Agency brought a
lawsuit against Tampa
Electric Co. for violations of the Clean Air Act. EPA claims
TECO made illegal major
changes to its Big Bend and Gannon power plants. The changes
allowed TECO to
extend the operating life of two of the nation's dirtiest power
plants and to produce
more electricity and more air pollution without necessary
permits. On Dec. 8 the
Florida Department of Environmental Protection filed and settled
a state lawsuit
against TECO involving those same actions.

Florida DEP Secretary David Struhs, in his Dec. 14 guest column
(Commentary),
makes fine-sounding arguments about why the TECO deal is good
for Florida.
However, the agreement DEP made doesn't match Struhs'
description - only three of
six Gannon units (built between 32 and 42 years ago) will close
- units that were never
built to run more than 25-30 years. The DEP agreement has many
loopholes for
TECO to slip through. Most important of the many conditions is
that the Florida Public
Service Commission must allow TECO to recover all its expenses
for compliance from
its customers.

Struhs defends allowing TECO to keep sulfur dioxide and nitrogen
oxide emission
credits; the former have a current value of about $200 per ton
and can be sold to other
utilities. The agreement allows both credits to be used by TECO
in the future instead
of requiring the utility to further reduce its pollution. And
Struhs doesn't address the
fact that the agreement protects TECO from having to comply with
new air pollution
standards for the next 10 years.

What is lost in Struhs' version of the deal is that a basic
principle of government
enforcement is to remove the reward the violator has reaped from
its illegal action.
TECO has overhauled obsolete plants, overpolluted and profited
financially by its
actions. The DEP deal doesn't come close to evening the score.
Struhs makes much
of ``punitive payments totaling $10 million'' going to Florida
rather than Washington.
But $2 million to study Tampa Bay pollution and $8 million to
research technologies
TECO might use are not punitive and are grossly inadequate
compared with the
benefit TECO received through its actions. And it's TECO
customers, not those
responsible for the violations, who will pay.

Legislation now before Congress would require electric utilities
such as TECO to
actually reduce sulfur dioxide and nitrogen oxide 75 percent by
2005, limit mercury by
90 percent and reduce carbon dioxide emissions for the first
time. Florida's
congressional delegation, including representatives from the
Tampa Bay region, needs
to get serious about air pollution. Smog and fine particles are
health threats that can
no longer be ignored. Valuable natural resources such as Tampa
Bay are at risk from
air pollution that is nearby and is washed into the bay.

Air pollution is both a local and national problem. Secretary
Struhs has demonstrated
that we can't trust our state officials to protect our health
from power plant pollution.
We need real reductions sooner, rules or agreements with real
teeth. Maybe it's time
for a national solution. - GAIL KAMARAS Tallahassee

The writer is director of the Energy Advocacy Program of the
Legal Environmental
Assistance Foundation.

-- -- --

TECO is the dirtiest plant in the nation. It has had 30 years to
achieve compliance but
attempts to strike another good ol' boy deal to get another 10
years to pollute, but the
feds object and try to protect locals.

The water management district (the term is not really
descriptive of what it does) voted
to put the largest desalination plant near Big Bend plant. Both
members of the
Hillsborough County Commission in the group voted against it,
but the majority -
representing water needs from Pasco and Pinellas County - don't
want it in their areas
because it may not leave room for more development. They voted
to put it in our area
with promises of no impact on the bay or canals.

A new wallboard plant is planned for a location near the Big
Bend TECO plant and the
desalination plant. Company officials also promise no pollution
will leave the site. And
oh, by the way, they will need lots of water!

Cargill announces that it needs to double the size of its gypsum
stack in order to
operate for the next 30 years. The company says there is no
danger to the
environment!

A consortium of phosphate companies has now announced that they
want to put a
liquid-sulfur plant near Big Bend. Again, promises of no odor or
pollutants leaving the
site. And again, they will need more water!

My questions are:

Who, if anyone, is studying the cumulative effects of all these
actions? What plans
are being made to ensure that there is no odor and that
emissions do not leave the
site? What protection is being included in the permits to ensure
an immediate clean
up response and shutdown of the facility in case of an accident?

I do not believe there is anyone doing these things from a
whole-community
perspective. The addition of the few jobs that will be created
by this potentially
disastrous collection of industries does not justify the
potential damage to the bay,
our community and our children's future.

Enough is enough! - RICHARD CLOY Apollo Beach

-- -- --

Since 1998, Southwest Florida Water Management District has held
monthly
preapplication meetings on the Cone Ranch Dispersed Wells
Project for Tampa Bay
Water staff and consultants.

During these meetings, new information related to this hotly
debated wellfield are
discussed, and Tampa Bay Water gains a better understanding of
what will be
required to obtain a pumping permit for the Cone Ranch
wellfield.

Citizens who organized in opposition to the Cone Ranch project
were successful in
obtaining the consultant-prepared preapplication meeting notes
(approved by all
attendees of the preapplication meetings). Unfortunately, the
notes contain repetitive
text, missing and incorrect meeting dates, apparent text
deletions and poor definition
of action items and responsibilities. In response to complaints
about the lack of detail
and accuracy, Tampa Bay Water responded that the reports were
intended only ``to
provide summaries of important discussion points'' and that the
summaries were
accurate. In effect, these ``accurate'' summaries prevented
concerned citizens from
sequentially reconstructing permitting developments at Cone
Ranch and thereby
limited public participation in the process.

On Oct. 12, Tampa Bay Water General Manager Jerry Maxwell agreed
to allow two
citizens of this donor community to attend Cone Ranch
preapplication meetings as
observers. However, despite the fact that ongoing studies
continue to provide new
project feasibility information, no preapplication meeting
notices have been provided to
these two citizens. In addition, Tampa Bay Water has denied our
requests to
videotape the preapplication meetings so that the proceedings
can be shared with a
growing multicounty-opposition base.

This unwillingness to share with the public information obtained
at public expense is,
unfortunately, consistent with many observations made by
citizens and elected
officials at the June meeting of the State Water Resources
Committee. How long will
Tampa Bay Water's board of directors require us to endure this
level of disrespect and
manipulation? - CINDY RYAN-BROWN Plant City