User manual | IA-09-04

I. Meeting Packet
Attachment 1
II. Outside Persons Who
Wish to Address the
Commission at
Internal Affairs
Note: The records reflect that no outside persons
addressed the Commission at this Internal Affairs
meeting.
III. Supplemental
Materials for Internal
Affairs
Note: The following material pertains to Item 1
of this agenda.
State of Florida
lFuhtitFeffiEeW.ffi
C.TPMNI CNCI,E, OFFICE CENTEN
O
2540 SHUMARD OAK BOULEVARD
TnLulHlssEE, FLoRIDA 32399-0850
-M-E.M.O-R-A-N-D.U-M.
DATE:
September 3,2014
TO:
Art Graham, Chairman
FROM:
Eduardo E. Balbis, Commissioner
RE:
Comments regarding the EPA's Proposed Rule for Carbon Pollution Emission
ins Units
Sources:
Guidelines for Existi
u
1g,Z1l4,the EPA published the proposed rule for Carbon Pollution Emission
Guidelines for Existing Stationary Sources: Electric Utility Generating Units. The comment
period for the proposJd Rule ends October 16,2014. After reviewing the Proposed Rule, I have
.or,."*, with the Final Goal of 740lbs/lr4Wh of COz and the methods dnd data the EPA used to
On June
reach the Final Goal.
the minimum issues I
Attached is a document drafted in comment format containing
Rule fails to take into
believe the FpSC needs to address. As a brief summary, the Proposed
with other
interconnection
limited
account the unique geographic features of Florida and our
rate
improvements
for heat
states in the region.-f'uit irmore, the Proposed Rule's assumptions
data from our review
ftt
historic
supported
not
4)
are
(Block l) and bSM reductions (dlock
9',
pioposed
of the 2012 capacity
assumption
baseline
Rulels
of our GpIF and DSM progru-r. rn.
reduction.
available
inflated
factor for NGCC plants is i-ncorrect, which creates a drastically
energy soulces severely
Finally, the Proposed Rule's cost assumption for increasing renewable
to the EPA's own
according
sources
the installed cost of renewable energy
underestimates
numbers.
following are the estimated costs
Based on the EpA,s estimated costs and available data, the
for the Building Blocks:
.
.
r
o
r
Cc:
Block I
-
$1.15 billion
Block2-unknown
PV
Block 3 - $16.S billion using the EIA's estimated installed costs for
capacity
Block 4 - $g.6 billion using the historical DSM data for avoided
Total - at least $26.55 billion
Lisa Polack Edgar, Commissioner
Ronald A, Bris6, Commissioner
Julie I. Brown, Commissioner
Mark Futrell, Director, IDM
versus cost
[email protected]
Handout
Int€mal AffairYASdr
on_1 J9_JJ!_
Item No.
IV. Transcript
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BEFORE THE
FLORIDA PUBLIC SERVICE COMMISSION
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PROCEEDINGS:
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COMMISSIONERS
PARTICIPATING:
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CHAIRMAN ART
COMMISSIONER
COMMISSIONER
COMMISSIONER
COMMISSIONER
GRAHAM
LISA POLAK EDGAR
RONALD A. BRISÉ
EDUARDO E. BALBIS
JULIE I. BROWN
DATE:
Thursday, September 4, 2014
TIME:
Commenced at 10:36 a.m.
Concluded at 11:10 a.m.
PLACE:
Betty Easley Conference Center
REPORTED BY:
LINDA BOLES, CRR, RPR
Official FPSC Reporter
(850) 413-6734
Room 148
4075 Esplanade Way
Tallahassee, Florida
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INTERNAL AFFAIRS
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FLORIDA PUBLIC SERVICE COMMISSION
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P R O C E E D I N G S
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CHAIRMAN GRAHAM:
Okay.
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start the meeting.
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Thursday, September the 4th.
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is the Internal Affairs meeting.
I think it's time to
Let the record show it is still
It's about 10:35, and this
I want to welcome everyone for being here
6
7
today.
8
privilege for Commissioner Balbis.
9
I'm going to take a little time of personal
COMMISSIONER BALBIS:
Thank you, Mr. Chairman.
10
And I want to thank my fellow Commissioners for this
11
moment.
12
My advisor, John Truitt, has been with me
13
for over a year now, and today is his last day
14
unfortunately.
15
Public Service Commission.
16
for all the hard work that he has done and the sound
17
legal advice and other advice that he's given me over
18
the past year.
19
just wanted to recognize him and thank him.
20
of you that are out there, you have one day left to
21
blame him for things that I do, and then after that I'm
22
on my own.
But he is going to move on from the
And I did enjoy working with him, and I
And for all
But I just wanted to say that, so thank you.
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(Applause.)
24
CHAIRMAN GRAHAM:
25
I just want to recognize him
John, it was good having you
around, and good luck on your future endeavors.
FLORIDA PUBLIC SERVICE COMMISSION
Thank you, Mr. Chairman.
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MR. TRUITT:
2
CHAIRMAN GRAHAM:
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000003
Okay.
Staff, item number 1.
Take it away.
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MS. ORTEGA:
Good morning, Commissioners.
5
Anna Ortega with staff, with Jim Breman and Kathryn
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Cowdery.
7
Item number 1 contains information on two
8
recent EPA proposals which would regulate CO2 emissions
9
from existing sources:
First, the proposed rule for
10
modified and reconstructed sources; and, second, the
11
Clean Power Plan, which establishes state-specific CO2
12
emission limits.
13
Staff is here today to provide you with a
14
briefing on the two rules and answer any questions that
15
you may have; also to provide you with a little
16
background information on where we are with the process.
17
To help inform staff and the Commission on the various
18
aspects of the EPA proposals, staff solicited comments
19
on both of the actions from interested persons.
20
responses can be found on the Commission's web page.
21
Those
Additionally, staff sent out information
22
requests to Florida electric generating units to get
23
some specific technical aspects of both proposals.
24
Attachment C of the item has a high level summary of
25
those responses.
FLORIDA PUBLIC SERVICE COMMISSION
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Staff continues to analyze the very complex
000004
2
rules summarized in this packet and also go through the
3
voluminous technical support documents.
4
have met several times with DEP, also with the Florida
5
Electric Power Coordinating Group, and will continue to
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participate in relevant meetings, webinars, and
7
otherwise track the EPA developments.
8
comment and will take comment on both proposals, which
9
are due October 16th of this year.
10
In addition, we
EPA is soliciting
If you'll allow, I'll go in just a high level
11
summary of the two proposals that we have in the packet.
12
Attachment A is a summary of the modified and
13
reconstructed rule, and it also provides background on
14
the specific areas of the Clean Air Act that the EPA
15
looked to in developing the two proposals.
16
As you are aware, these proposals were both
17
issued on June 18th of this year.
18
reconstructed rule sets specific unit base standards on
19
the units.
20
for the modified and reconstructed natural gas plants as
21
it has in the new source performance standards, but
22
they set a less stringent standard on modified and
23
reconstructed coal plants.
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25
The modified and
EPA has proposed setting the same standards
Secondly, the Clean Power Plan, which was also
published on June 18th, has emission standards that are
FLORIDA PUBLIC SERVICE COMMISSION
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proposed in the rate base form, which is the form of a
2
pound of CO2 per megawatt hour for each state.
The clean air -- Clean Power Plan has two
3
4
parts:
5
standards and, second, our guidelines for states to
6
develop plans to submit to the EPA.
7
First is the state-specific CO2 emission
EPA determined the best system of emission
8
reductions and then imposed those national and/or
9
regional assumptions for the building blocks which are
10
the best system of emissions performance on the states.
11
Attachment B goes into the details of the Clean Power
12
Plan, and it also includes a description of how EPA set
13
the targets for Florida.
14
Finally, in the packet you'll find Attachment
15
D, which contains general topics that staff has
16
identified as important considerations for Florida in
17
meeting those EPA standards.
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Commission, these are the areas that staff would use to
19
prepare comments for the Commission to consider at the
20
next Internal Affairs meeting.
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22
If directed by the
Staff is here to answer any specific questions
you have on the proposed rules.
Commissioner Balbis.
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CHAIRMAN GRAHAM:
24
COMMISSIONER BALBIS:
25
Thank you, Mr. Chairman.
And I want to thank staff for the overview of the
FLORIDA PUBLIC SERVICE COMMISSION
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proposed EPA rules.
And I wanted to focus primarily on
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EPA's 111(d), or the Clean Power Plan.
As we all know, Florida has a very unique
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4
geography and we do not have the interconnections with
5
other states that other states may have.
6
the 740 pounds per megawatt goal, the EPA used four
7
building blocks that I have significant concerns that
8
they had incorrect assumptions and mistakes, technical
9
mistakes in developing those blocks.
In developing
In block one, the EPA assumes that we can
10
11
easily and cost-effectively achieve a 6 percent
12
improvement in heat rate.
13
GPIF in place for decades, and I cannot find a single
14
investor-owned utility that has achieved a 6 percent
15
improvement consistently.
As we all know, we've had
In block two, the EPA assumes that we can
16
17
easily and cost-effectively achieve 70 percent
18
utilization rate for our gas power plants.
19
Unfortunately they use nameplate capacity, which grossly
20
overestimates how much generation we can actually
21
achieve.
22
In block three, the EPA assumes that we can
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cost-effectively have 10 percent of our electricity
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generated with renewable energy.
25
required to look at the cost-effectiveness of
By statute we're
FLORIDA PUBLIC SERVICE COMMISSION
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generation, and just having an arbitrary 10 percent goal
2
may result in significant impacts to ratepayers.
And finally in block 4, the EPA estimates and
3
4
assumes that we can cost-effectively achieve a
5
10 percent conservation goal.
6
required by statute to look at the technical potential
7
and cost-effectiveness of conservation measures before
8
we implement those goals.
9
measures and with the technical issues and incorrect
Once again, we're
And with all these four
10
assumptions that have been made, and staff have
11
mentioned several of these, the sum total of these using
12
the EPA's own numbers is over a $26.5 billion impact.
13
So given those impacts and the mistakes that
14
are made, I've put together just some general comments
15
that I'd like to have staff to consider when they go
16
back and prepare the formal comments for our full
17
consideration.
Given the statewide impacts, I feel that this
18
19
is the single most important issue facing Florida
20
ratepayers today, and I want to make sure that the
21
Public Service Commission has an active role in this
22
process.
23
know, the Commission and staff.
24
shorthanded, I'm not sure who's going to hand those out,
25
but -- I see Ms. Stauffer is going to do that.
So I've put together some comments for, you
Since I'm kind of
FLORIDA PUBLIC SERVICE COMMISSION
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(Document handed out.)
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Mr. Chairman, that's all I had.
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CHAIRMAN GRAHAM:
4
Commissioner Edgar.
5
COMMISSIONER EDGAR:
6
Just very generally first as we kind of kick
Okay.
Other Commissioners.
Thank you, Mr. Chairman.
7
off our discussion today, first I want -- or second I
8
want to commend our staff who have put a lot of time
9
into this issue.
I know I've had many discussions and
10
many meetings with them over the time since this
11
proposal has come out and also the months leading up to
12
it as the EPA was gathering data and was going on, as
13
they called it, their listening tour.
14
background information that has been provided is very
15
good.
16
appreciate, and very well covered a number of very
17
complicated and very technical issues.
18
the work that you've done to get us to this point, and
19
thank you in advance for the work that you will be
20
continuing to do for quite a while, I hope, as we
21
continue to look at this issue.
And I think the
I found it very, very concise, which I
So thank you for
Commissioner Balbis, also thank you for your
22
23
attention to this issue.
24
heavy.
25
approximately 12 pages.
Obviously -- this is kind of
Commissioner Balbis has given us a handout of
Clearly I'm going to need a
FLORIDA PUBLIC SERVICE COMMISSION
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little bit of time to absorb it, so I'm not sure where
2
you want us to go with this from here, but I'll come
3
back to that.
So from then, just again to kick off, I know
4
5
that our staff has also been coordinating with staff at
6
our sister agency, Department of Environmental
7
Protection, and I want to thank you for taking that
8
initiative and also thank them for the work that they've
9
done.
We, you know, all represent the same people and
10
the same interests but, of course, have different
11
statutory jurisdictions and different areas of technical
12
expertise.
13
that type of cooperation and sharing, and I know that
14
will continue as well.
15
And it's wonderful to have a good example of
Commissioner Balbis touched on what I think
16
are the two most central issues from our authority and
17
our jurisdiction, which is potential impacts on
18
reliability and the potential cost impacts and how those
19
will or may flow through to the ratepayers, and what our
20
ability is to discern the value and the appropriateness
21
of those steps and of those costs.
22
proposal I believe there are a number of legal issues
23
that are raised and are questions that I have and I
24
think that many, many people have.
25
on the Clean Air Act have a number of questions.
I know that with the
Many who are experts
FLORIDA PUBLIC SERVICE COMMISSION
And so
1
I think as we go forward at drafting potential more
2
specific comments, that some of those legal issues
3
should be raised.
4
or we can all continue to coordinate with staff.
5
000010
And we can talk about that more now
But the reliability issue and the potential
6
cost impact are the two key areas that I would ask that
7
we highlight.
8
fellow Commissioners, say that I do support our staff
9
working to put together draft specific comments for our
10
consideration based on our comments and input and that
11
that then come back to us and that we seriously consider
12
the option as an agency of filing officially comments
13
with the EPA and take advantage of this comment
14
opportunity.
15
And I would, Mr. Chairman, and to my
I recognize, as does Commissioner Balbis or as
16
he pointed out, that because of our geography and some
17
other factors that we are uniquely situated, and
18
therefore there will be many comments, I think, from
19
other states and stakeholders in other states that we
20
will probably share and have in common.
21
there are some factors that are specific to Florida, and
22
it is our responsibility to raise those and to make them
23
clear so that the EPA can at least have that information
24
from us and hopefully factor it in as they go on to
25
their next steps.
But I think
FLORIDA PUBLIC SERVICE COMMISSION
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I also have some, a few more specific comments
1
2
on a few of the specific building blocks and how they
3
are supposed to or may or may not interact as we, as we
4
get to that -- give me just a second to look at my
5
notes -- one of which is the potential impact on fuel
6
diversity or lack of fuel diversity.
7
on that a little bit more.
8
what I believe is inherent in the structure of the rule,
9
which is to push states and operators from what we have
I'd like to touch
And then also the reality of
10
always termed as economic dispatch for efficiency and
11
cost-effectiveness to what has been termed environmental
12
dispatch and a number of issues practically and from a
13
cost standpoint that could be raised from that.
So that's just kind of generally to help us go
14
15
from this point, Mr. Chairman, and I'm very interested
16
in hearing from my colleagues.
17
CHAIRMAN GRAHAM:
Thank you, Commissioner
18
Edgar.
I think you touched on, well, the two things
19
that I think are most important in this, and it's going
20
back to what our mission is on the Public Service
21
Commission is, number one, there's a financial impact.
22
I think, you know, the, how that, how this is all going
23
to financially impact the individual ratepayers and the
24
utility industry as a whole here for the State of
25
Florida, and the other thing is going to be grid
FLORIDA PUBLIC SERVICE COMMISSION
1
reliability.
2
the other details that probably other agencies probably
3
should get into, and just remind everybody that we are
4
not, we are not writing the comments for the entire
5
State of Florida individually how this is going to
6
affect you.
7
mission is here at the Public Service Commission.
It needs to be comments on what our job
That being said, let's move on to Commissioner
8
9
You know, we can get down into a lot of
000012
Brisé.
10
COMMISSIONER BRISÉ:
Thank you, Mr. Chairman.
11
I think many of the comments -- I join in many of the
12
comments that have been made by my colleagues in
13
addressing the fact that within our role and mission we
14
have to look at reliability and the cost.
15
end of the day, I think the -- those are the two factors
16
that are most important.
And at the
But I'm very interested -- and I'll leave it
17
18
at interested at this point -- in the implementation
19
aspects of it and getting clarity on how this could be
20
enforced.
21
we need clarity on some of those, on some of those key
22
factors.
23
And I think our comments need to reflect that
The other thing that I think, and recognizing
24
that there are other agencies that may be addressing
25
some of these issues, but I think we as a Commission
FLORIDA PUBLIC SERVICE COMMISSION
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1
need to also look at what legal authority that we have
2
as a Commission to regulate what we regulate per our
3
statutes and where the delineation is between the
4
federal powers and the state powers as it relates to
5
federalism or cooperative federalism and so forth.
6
those are things that I think our comments should also
7
address.
8
9
So
And recognizing that there is a traditional
way of doing this through the traditional state
10
regulatory powers that currently exist and that is the
11
current regime, and so any movement from that regime, we
12
have to get full clarity as to how that is going to be
13
addressed and delineated.
14
numbers will bear out, I think it's important to
15
establish the baseline as to how this will work, and
16
then I think our comments need to reflect our concern
17
about that.
So outside of what the
Commissioner Brown.
18
CHAIRMAN GRAHAM:
19
COMMISSIONER BROWN:
Thank you.
And I would
20
agree four times over and am very supportive as well
21
with regard to preparing concise comments.
22
I do want to thank our staff for their
23
continued work on it, for your role at the NARUC level
24
and monitoring this, and your future continued work on
25
it as well.
So thank you for that.
FLORIDA PUBLIC SERVICE COMMISSION
And I know that we talked about possibly
1
2
asking questions.
3
of that that has been discussed by my fellow
4
Commissioners.
5
impacts.
6
discussed it but just -- and, of course, on the
7
reliability as a result of this federal mandate.
000014
And as I stated, I would support all
But my focus really is on the cost
And we've already had briefings on this and
Various analyses I've read -- the Wall Street
8
9
Journal, the U.S. Chamber -- they have different cost
10
impacts ranging from $50 billion a year for businesses
11
to about $28 billion per year.
12
southeastern states, including Florida, is going to face
13
the biggest rate impact.
And the southern,
Do you have an estimate, perhaps a rough
14
15
estimate on what that actual impact could potentially be
16
in Florida?
17
MS. ORTEGA:
Thank you, Commissioner.
I think
18
what's been raised a couple of times here is the amount
19
of uncertainty and actual implementation.
20
have certainty of how the final rule will look and also
21
what DEP submits to EPA as their implementation plan,
22
that's really when we can do a better or best cost
23
estimate.
24
staff hasn't been able to really develop a cost estimate
25
for you.
And until we
But because of the uncertainty, at this point
FLORIDA PUBLIC SERVICE COMMISSION
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1
COMMISSIONER BROWN:
2
was expecting.
3
opportunity.
And that was the answer I
I just wanted to give you an
Also, you sent out a solicitation of comments
4
5
that went out not just to the Florida Electric Power
6
Coordinating Group but also to just the general group of
7
stakeholders.
8
you've compiled them but they're not attached in our
9
packet here.
10
I think there were five questions.
MS. ORTEGA:
They are not.
Excuse me.
And
They
11
are not attached in the packet, but they are available,
12
all the responses are available on the Commission
13
website.
14
after this hearing.
And staff can certainly give a printout to you
But we did solicit information or provide an
15
16
opportunity for a wide group of commenters to give us
17
their take, if you will, on the proposals, both
18
proposals.
19
some comments, but they have all been posted on the
20
website.
And as of yesterday, we were still receiving
Okay.
Thank you.
21
COMMISSIONER BROWN:
22
And this is a question for Ms. Cowdery with
23
regard to taking comments.
The EPA extending the
24
potential date, that's currently at October 16th.
25
you have any insight into whether the EPA is inclined to
FLORIDA PUBLIC SERVICE COMMISSION
Do
1
2
000016
extend that date?
MS. COWDERY:
I have no specific information
3
about any action that they have taken or not taken or
4
that they may take or may not take regarding the
5
requests for extension of time.
6
requests for extension of time on providing comments to
7
both rules, one or the other or one or both rules that
8
go between 90 days, 120 days, 60 days.
9
there's been no word that I am aware of from EPA on
10
11
12
13
There are about a dozen
But thus far
those requests.
COMMISSIONER BROWN:
Has FCG, have they
submitted a request to extend?
MS. COWDERY:
Yeah.
FCG has requested a
14
90-day extension.
City of Tallahassee also, Seminole
15
Electric Cooperative also.
16
last couple of days to see if any other Florida
17
interests have submitted a request for extension.
I have not checked in the
18
COMMISSIONER BROWN:
19
MR. BAEZ:
20
CHAIRMAN GRAHAM:
21
MR. BAEZ:
Okay.
Thank you.
Mr. Chairman?
Yes, sir.
I was going to mention at the tail
22
end of the discussion but Commissioner Brown raised it
23
now, discussing an extension or a request, a letter
24
requesting an extension is completely appropriate.
25
We've discussed it among the staff, and there's no
FLORIDA PUBLIC SERVICE COMMISSION
000017
1
heartburn over putting out such a letter, if it's your
2
pleasure to do so.
3
consider and discuss, and it's not -- you know, we're
4
still on time to do it.
5
It's something that you all can
I will mention, however, I think it's been
6
alluded to in our discussions, I don't think that
7
there's anyone that has serious hopes that an extension
8
might be granted.
9
think it's inappropriate for us to at least consider it.
Having said that, I don't, I don't
10
So we're prepared to do whatever the Commission's
11
pleasure is on that subject.
12
MR. KISER:
Mr. Chairman, I think that the
13
information that we've got in that staff report and
14
accompanied by Commissioner Balbis's observations
15
probably ought to be forwarded to our congressional
16
delegation.
17
Commissioner Balbis is leaving, but perhaps if his name
18
were placed in the right spot, he could be called on to
19
testify before Congress.
20
lot of these issues, particularly the reasonableness of
21
how these are going to impact the states.
22
someone from Florida testifying, because we do set a
23
pretty good -- we have a pretty good case to take to
24
them compared to maybe some other states.
25
issues need to get to the congressional delegation so
And I know it's with great regret that
They keep having hearings on a
And perhaps
But these
FLORIDA PUBLIC SERVICE COMMISSION
000018
1
they too in their capacities on the various committees
2
they serve on can weigh in on the unique characteristics
3
of Florida and how this really treats us unfairly.
Commissioner Edgar.
4
CHAIRMAN GRAHAM:
5
COMMISSIONER EDGAR:
Thank you, Mr. Chairman.
6
And I agree completely that when we have -- are at the
7
point that we have comments finalized and approved that
8
I would absolutely consider and encourage that we send
9
those to our congressional delegation and others as we
10
can discuss.
I don't think we're quite at that point in
11
our review and in our process.
12
As Commissioner Balbis knows, and I don't know
13
if our General Counsel does or not, but coincidentally I
14
was asked to testify before a congressional committee on
15
these issues about three weeks ago.
16
because I did not think that we were at a point yet
17
where we had taken a position and, therefore, it felt
18
premature to me for us to speak specifically on those
19
issues for Florida.
20
will come again.
21
if we can use those avenues as well.
22
And I declined
But I'm sure that that opportunity
So when we're at that point, we'll see
If this is the appropriate time, Mr. Chairman,
23
there are a few other points that I would like to point
24
out just generally that may have come up.
25
case they haven't, one is that I would ask our staff to
But just in
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consider including in our comments that EPA better give
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credit for early reductions.
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are a number of states, Florida in particular, who have
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taken a number of steps over the years, and our
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ratepayers have both benefited from it but also have
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contributed through their rates and their dollars to
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taking those steps.
8
that are built in, I do not believe that we are given
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credit for that.
I do believe that there
And with some of the assumptions
And I would like that we consider
10
highlighting that point and asking for a change in the
11
rule specifically for Florida and other states that are
12
so situated.
13
Commissioner Brisé raised the point of under
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this rule there being, if not the active purpose, but
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certainly the inference that through this process that a
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number of areas that are within the jurisdiction of the
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states both by state law and by the Federal Power Act
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and a number of other federal requirements would be
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somewhat shifted potentially to the federal
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environmental agency.
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would ask that we consider how to best raise that issue
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that not just that areas such as energy efficiency,
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conservation, and fuel diversity, and others are not
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just traditionally reserved to the states but are
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appropriately reserved to the states, and that the
That is of concern to me, and I
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unique nature of many states and many regions that that
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should continue to be the case and should not be
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co-opted through this kind of side door through the
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Clean Air Act and however is the best way to term that
5
to raise that issue.
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I would also ask that we consider raising the
7
issue that the interim target is of concern; that if
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there are going to be interim targets, my suggestion
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would be that it be more of a goal or a direction rather
10
than an enforceable requirement, primarily because I
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don't think the timeline is realistic.
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I mentioned the issue of fuel diversity.
I
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think that's very, very important.
For as many years as
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I've been involved in environmental policy in the State
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of Florida, which I assure you is a very long time, we
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have had as a policy component as a state a desire for
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fuel diversity and the recognition that fuel -- that a
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diverse fuel portfolio is in the best interest of our
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consumers, our economy, and our environment.
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at the same time our fuel diversity or the diversity
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within our fuel portfolio has been diminishing for a
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variety of reasons.
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coming up to, not too far away, 70 percent natural gas.
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And under this proposal I think it really again
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encourages, if not forces, a continuing move in that
However,
And at this point we are, you know,
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direction, and I think that that is a concern and
2
something that we should raise.
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I also would ask that our staff look at the
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point that -- my understanding is within the draft rule
5
that the baseline is one year and that that baseline
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should more appropriately be the average or
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consideration of a several-year period, not just a
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one-year snapshot.
9
I also, and this has come up a little bit, but
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I recognize that under the rule that it does encourage
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regional cooperation and regional agreement.
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certainly encourage that and support it.
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just put out there for discussion and consideration --
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recognize that Florida and many states in the southeast
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and the northwest for a variety of reasons are not in an
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RTO or a MISO type arrangement, making that regional
17
approach problematic for a variety of reasons --
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legally, cost wise, and implementation -- and would ask
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that we look very closely that because that may not be
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an option for us in at least the first few years, that
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we not be penalized somehow because of that.
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I
But I also --
The issue was raised about enforceability, and
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I think there are a number of points there that again I
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would ask our staff to look at for our consideration,
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including the issue of the Clean Air Act being
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potentially applied here or implemented for that outside
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the fence rather than within the fence line is kind of
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the way it's been described, but a site specific
4
requirement.
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believe ours included, did ask the EPA give flexibility
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in, as they were drafting the rule, and I recognize that
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that is in there.
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many questions as to how that would actually be enforced
9
and applied.
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11
And I recognize that many states, I
But I also recognize that there are
And so, again, I would ask that we
continue to look at that.
Thank you, Mr. Chairman.
Again, I look
12
forward to more discussion and will chime in if I think
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of anything else.
Commissioner Balbis.
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CHAIRMAN GRAHAM:
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COMMISSIONER BALBIS:
Thank you, Mr. Chairman.
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And I couldn't agree more with Commissioner Edgar.
In
17
fact, on the regional opportunities, I was in a
18
conference, I believe, in Washington where there were
19
different states discussing these opportunities, and
20
maybe because of lack of communication I was surprised
21
to see that Commissioner Edgar was moderating the panel.
22
So she is certainly aware of the issues associated with
23
the, with our lack of interconnection with other states
24
as it pertains to Florida.
25
represented.
So I think we are very well
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One additional request or direction to staff,
2
since there are so many uncertainties on some of the
3
costs, but I do think it's important for us to at least
4
use the EPA's own numbers for it.
5
building block one in their technical support documents
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they have a cost per kilowatt for heat rate
7
improvements, and it's a very easy calculation to do.
8
And in building block two there's a lot of uncertainty
9
there, and I certainly don't expect staff to put a
10
11
And especially in
number to that.
But in building block three the EPA does have
12
a cost per kilowatt of renewable generation, so that's a
13
relatively simple calculation.
14
four, we do know that, you know, Florida customers have
15
paid almost $300 million per year to achieve the
16
conservation that we do in a cost-effective manner.
17
that, you know, one way to estimate would be to
18
extrapolate that to the 10 percent at least to have an
19
idea, you know, knowing that with what is known and what
20
EPA so helpfully provided us in their support
21
documentation we can at least start grasping the
22
magnitude of the potential impacts.
23
CHAIRMAN GRAHAM:
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Staff, do you understand your orders?
25
MS. ORTEGA:
And in building block
Any other Commissioners?
Loud and clear.
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So
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CHAIRMAN GRAHAM:
I do thank you so very much
2
for what you've put together so far and for putting all
3
the comments that we received in on the website.
4
think that's helpful for all of us Commissioners and for
5
the general public to see what sort of comments are
6
coming in and what direction we see ourselves going.
7
Seeing nothing else from the other Commissioners, I
8
thank you very much, and do good work and come back
9
soon.
Next on the agenda is the Executive Director's
10
11
report.
Commissioners, no report today,
12
MR. BAEZ:
13
except to put a bow on this.
14
I
What we're anticipating is having a set of
15
draft comments before you for the October 2nd, I believe
16
is the date of the next IA.
17
know, things will go as normal.
18
And at that point, you
I know that we used a little bit more of a
19
hybrid approach to take public comment and to kind of
20
develop these comments before you.
21
trust it's working to everyone's expectations so far.
22
But we'll be back on to a more traditional comment and
23
draft comments and public comment structure for the next
24
time, so you'll have some drafts before you to vote on
25
and change as you will.
I'm hoping -- I
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CHAIRMAN GRAHAM:
2
MR. BAEZ:
3
CHAIRMAN GRAHAM:
Thank you.
000025
Thank you.
Okay.
Other matters?
4
Seeing none -- I like this -- it is 10 after 11:00, and
5
we are adjourned.
6
Everybody please travel safely.
(Internal Affairs concluded at 11:10 a.m.)
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STATE OF FLORIDA
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COUNTY OF LEON
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:
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CERTIFICATE OF REPORTER
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I, LINDA BOLES, CRR, RPR, Official Commission
Reporter, do hereby certify that the foregoing
proceeding was heard at the time and place herein
stated.
IT IS FURTHER CERTIFIED that I stenographically
reported the said proceedings; that the same has been
transcribed under my direct supervision; and that this
transcript constitutes a true transcription of my notes
of said proceedings.
I FURTHER CERTIFY that I am not a relative, employee,
attorney or counsel of any of the parties, nor am I a
relative or employee of any of the parties' attorney or
counsel connected with the action, nor am I financially
interested in the action.
DATED THIS 11th day of September, 2014.
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__________________________________
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LINDA BOLES, CRR, RPR
FPSC Official Hearings Reporter
(850) 413-6734
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FLORIDA PUBLIC SERVICE COMMISSION

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