This order may be an opportunity to get additional back-up generation quickly 
installed at customer's facilities in WA State.  It is only applicable for 
onsight energy use - not selling to the grid.

On January 29, 2001 Governor Gary Locke signed Energy Supply Order No. 01-02, 
suspending regulations pertaining to construction and portable source 
requirements of the Washington Administrative Code (WAC 173-400-110) and 
local air pollution control authority regulations adopted under RCW 70.94.152 
for 30 days.  The 30 days suspension was granted to allow temporary electric 
generators that may be a major source of air pollution to be installed or 
constructed by utilities and other users of electricity without receiving a 
construction approval from the state. The order allows non-utilities to 
generate the electricity to offset their existing demand.  However, 
non-utilities cannot sell the generated electricity.  The purpose of the 
Order was to get sources generating electricity on line immediately.  The 
order has now been extended to March 27, 2001 and is known as &Energy Supply 
Order No. 01-04.8  It is likely the extension will continue. 

The basic differences between this Energy Order and a regular plan approval 
process is

1. Facility is allowed to operate a generator immediately without prior 
construction approval.  However, the facility has to meet the same 
requirements as they would if they were applying for a regular construction 
approval and operating permit.
2. No control device is required on the source.  Under the Order, Washington 
Department of Ecology will allow a source to operate without control on a 
temporary basis.  They are thinking of defining &temporary8 as less than six 
months.  After that the source must install a control device.  It is unclear 
if a construction plan approval will be required to install the control 
device at that time.  
3. The facility must obtain offsets or have a plan indicating how they are 
going to get offsets in the Energy Alert notification to the Department.  
There must be enough emission offsets to cover the operating time it would 
normally take to receive a plan approval from the Department.  The normal 
time frame to receive a plan approval from the Department is approximately 
one month.  

The only advantage with the Order is that a source can operate immediately 
and without control device on a temporary basis as long as they follow all 
the requirements listed.   


Mary Schoen
Environmental Strategies
Enron Corp
713-345-7422