Wednesday, August 26, 2009

To the Florida PSC, regarding proposed FPL pipeline and rate increase

[This letter is a modified version of a 'Motion to Intervene' PBCEC filed on several fossil fuel power plants proposed for south Florida. They were rubber stamped by the Public Service Commission (PSC) in 2008 without a local public hearing. We want to express our sincere gratitude to the Florida Alliance for a Clean Environment for their support in filing grassroots interventions, as we borrowed several of their points for our letters.]

FPL Pipeline Docket 090172 and FPL rate increase Docket No. 080677-EI

The Palm Beach County Environmental Coalition opposes FPL ‘s proposed a $1.6 billion 280-mile fossil fuel (gas) pipeline across Florida, as well as the proposed $1.3 billion proposed rate increase.

We contend that when compared to other options and strategies the 280-mile FPL pipeline proposals poses an extended period of economic risk that is unreasonable and diminishes the economic well being of FPL's Florida customers now and in the future. Therefore, we request that the project be denied, pending more complete assessment of available energy options, updated growth projections and accurate complete environmental costs of burning fossil fuels.

The proposed projects do not meet the needs criteria established by the State of Florida in FS403.519(4) which require the project contribute to FPL's power system's reliability and integrity, it's fuel diversity, base load generation capacity, and its effort to deliver adequate electricity at a reasonable cost. That it continues to be a viable option after any renewable energy sources and technologies or conservation measures that may be taken or are reasonably available to FPL that might mitigate the need for the proposed fossil fuel transmission projects has been considered, while also providing the most cost effective source of power.

Florida’s electrical power grid is already over 70% dependent on gas-powered generation.

It is our contention that every dollar of FPL rate payer money proposed to be spent on the proposed fossil fuel power project could be better spent on efficiency, conservation and renewables; financing programs that may include new or expanded DSM programs, leveraging through cost sharing the expansion of net metering / distributive energy programs. The integration of solar thermal and geothermal applications can mitigate peak load. The more efficient use of the existing base load can eliminate the need for new base load capacity.

We also see a slowing of growth in Florida that calls into question the proponent's projection for need. New building design criteria is also intended to reduce the need for new fossil fuel and transmission.

We, the PBCEC, are in agreement with the report from the Treasure Coast Regional Planning Council (TCRPC, or 'Council') regarding expansion of fossil fuel infrastructure. A was approved and authorized to be transmitted to the Florida Public Service Commission (PSC) on May 16, 2008, at the public Council meeting. This report found FPL to be "inconsistent with Strategic Regional Policy Plan Goal 9.1, Decreased vulnerability of the region to fuel price increases and supply interruptions; and Strategy 9.1.1, Reduce the Region's reliance on fossil fuels." The TCRPC urged FPL and the State of Florida to continue developing new programs "to 1) reduce the reliance on fossil fuels as future energy sources; 2) increase conservation activities to offset the need to construct new power plants; and 3) increase the reliance on renewable energy sources to produce electricity."

It is our belief, based on our research and the reports of the State of Florida’s TCRPC, that the projected cost of this proposal as alleged by FPL does not represent an accurate assessment of the actual costs of the project. Future costs attributed to CO2 are not taken into consideration in a tangible and concrete manner and environmental and health cost impacts associated with drilling and extraction are not mentioned. The availability and cost of water need also to be considered.

We believe that the reality of greenwashing must be taken into serious consideration when reviewing this pipeline proposal. "Greenwash" (a portmanteau of green and whitewash) is a term that is used to describe the act of misleading consumers regarding the environmental practices of a company or the environmental benefits of a product or service. The term Green sheen has similarly been used to describe organizations which attempt to appear that they are adopting practices beneficial to the environment.

While FPL's self-promotion reads, unsurprisingly, like an advertisement for their highly-profitable product. Independent, public
interest assessments of their proposals, such as that of the Treasure Coast Regional Planning Council (TCRPC), reads quite differently.

The Council recommended that "FPL should develop a program to install, own and operate photovoltaic units on the rooftops of private and public buildings... modeled after the Southern California Edison plans" where a utility will plans to install solar energy on more than 100 buildings in the greater Los Angeles area. TCRPC suggests that:

"shift[ing] to rooftop photovoltaic systems distributed throughout the area of demand could reduce the reliance on large transmission lines and reduce costs associated with owning property; purchasing fuel [and water]; and permitting, constructing, and maintaining a power plant."

This above-mentioned technology is available now, and is underway in other parts of the United States.

The TCRPC report also suggests the partnering of offshore wind and ocean current generation. PBCEC believes these options, which are under development now, could be available in a hastened time frame if non-renewable conventional fuels sources were not pursued in this crucial decade, which has been acknowledged by global climate scientists to within the tipping point of irreversible climate change.

In media releases, FPL has claimed that this so-called ‘EnergySecure line’ before the PSC will reduce CO2 emissions by millions of tons over the life of its operations. But the critical eye of public interest, and public agencies that are tasked to work in its service, must also note that the project will facilitate emissions surpassing that amount on an annual basis for the duration of their operations. 'Reduction' standards must not be in the eye-of-the-profiteer. They must be concrete and tangible, measured in observance of the evolving climate science of the Intergovernmental Panel on Climate Change and other reputable scientific bodies.

The PBCEC is concerned that FPL's current agenda is not as economically sound or environmentally friendly as their public
relations would have us believe. In a letter-to-the-editor published in the Palm Beach Post following an annual FPL shareholders meeting, entitled, ironically "Conservation a top priority for industry leader FPL", Company president Armando Olivera explains FPL's perspective:

"Over-reliance on conservation to meet our needs will leave customers vulnerable to higher rates and decreased reliability."

In the face of clean, renewable energy options and efficiency and conservation opportunities, this attitude can only be seen as a threat to its customers and a leash to centralized non-renewable, unsustainable power for our FPL ratepayers in the PBCEC.

FPL’s proposed rate increases (Docket No. 080677-EI) which accompany the expansion of out-dated fossil fuel expansion and fortification of a centralized energy grid show that their priority is in maximizing company profits in violation of Florida State Statutes intend to protect the people.

We expect the Public Service Commission to follow your lawful mandate to protect our interests. Surprise us.

Most sincerely,
Panagioti Tsolkas
Co-Chair, Palm Beach County Environmental Coalition
s/panagioti tsolkas 8/26/09

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