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