Text

Limited Appearance Statement of Zachariah Cosner on Behalf of Tropical Audubon Society Regarding Turkey Point, Units 3 and 4, License Amendment Request
	ML16019A378
Person / Time
Site:	Turkey Point
Issue date:	01/16/2016
From:	; Tropical Audubon Society
To:	; Atomic Safety and Licensing Board Panel, NRC/SECY
	SECY/RAS
References
	50-250-LA, 50-251-LA, ASLBP 15-935-02-LA-BD01, VVV-31
	Download: ML16019A378 (12)
	v • d • e

Tropical Audubon Society South Floridas Voice of Conservation President It is the position of the Tropical Audubon Society that the use of the Cooling Canal System (CCS)

Dr. Jose Barros as an Industrial Waste Water Facility (IWWF) to the current operations of the Turkey Point Nuclear Facility are highly damaging to, Biscayne Bay - an Outstanding Florida Water, Biscayne Honorary Director National Park, the Biscayne Aquifer and are in conflict with the goals of Comprehensive Roger Hammer Everglades Restoration Plan (CERP), and in potential violation of the Federal as well as local law Board of Directors based on the localized seepage of CCS into the Biscayne Aquifer and surrounding surface waters Alan Steinberg of Biscayne Bay and waters that flow into Biscayne Bay.

Brian Rapoza The Environmental Assessments (EA) for FPLs Turkey Point proposed nuclear units 6 & 7 Lewis Milledge, Finding of No Significant Impact disregarded the existing problems at and around the Turkey Esq.

Point facility caused by the 40 + years of seepage to groundwater and surface water from the Gary Hunt unlined CCS used by units 1-5. In fact, the EA for the recently uprated units 3 & 4 mentioned the Rafael Galvez increased temperature of the discharge water from the uprated Units 3 & 4 but also found no significant impact relying upon the assumption that the increased temperature, resulting Elizabeth Smith evapotranspiration and increased salt concentrations would be naturally remedied by rainfall Pilar Rodriguez and storm water runoff into the CCS. This assumption of natural attenuation has been dispelled Gary Milano by, among other things, the need for addition of 100s of millions of gallons a day from every other source FPL can find to lower the temperature and salinity unexpectedly increased by the Martin Jensen, increased heat from the uprated units. To the extent the the proposed units 6 & 7 rely at all on Esq.

the CCS as an IWWF, the CCS has to receive proper review. Until now, the CCS has received a Sonia Succar Ferré rubber stamp of approval from the agencies charged with environmental oversight.

Dr. Tiffany Troxler In order to properly analyze impacts to the surrounding environment, the regulatory agencies Richard Pettigrew must consider the observable decades of hypersaline water and toxic contaminants migrating Claire Lardner from the CCS through the permeable substrate into Biscayne Bay and the Biscayne Aquifer. The toxic contaminants include the accumulation of ammonia producing biotic material within the Subrata Basu canals and algal blooms, uncontrollable without addition of more chemicals into the CCS water Zachary Ruvin temporarily contained within, but flowing through the porous limestone.

Carlos Sanchez 1-Compatibility with CERP Gary Pappas, Esq.

The operations and proposed expansion of the Turkey Point Nuclear Facility are inherently Advisory Board Dennis Olle, Esq.

incompatible with the goals of Everglades restoration as promulgated under CERP and its Biscayne Bay Coastal Westlands Project (BBCW). The reasons for the incompatibility are based David Pearson on the fact that Turkey Point operations tax freshwater resources at higher rates and volumes George Gann than experienced any where else in the state of Florida. The freshwater that should be used to Dr. Thomas E. Lodge achieve the the lower salinity goals within the near shore of Biscayne Bay, as sought by CERP, is instead used to cool the nuclear units at Turkey Point. Furthermore, prior to the discharge of the Katy Sorenson cooling water, industrial solvents and radiological constituents mix with the water as it cools the Joy Klein interior structures of the units and is discharged into a shallow unlined porous limestone Executive Director system. The extreme heated (and chemically treated) discharge water in the CCS increases the Laura Reynolds evaporation of the freshwater leaving the chemicals, radiologicals, and high salt concentrations Editor Ana Lima Tropical Audubon Society l 5530 Sunset Drive Miami, FL 33143 l (305) 667-7337 l www.tropicalaudubon.org

Tropical Audubon Society South Floridas Voice of Conservation in the porous unlined limestone CCS that sits on top of the Biscayne Aquifer and next to an estuary that is a national park. This fresh water would otherwise flow to the Bay and help lower and stabilize the increased salty near shore waters of the Bay.

In context, the BBCW project is a key component of CERP authorized by congress in WRRDA 2014. The stated goal of this project is to increase the ecological health of Biscayne Bay (including freshwater wetlands, tidal creeks and near- shore habitat) by adjusting the quantity, quality, timing, and distribution of freshwater entering Biscayne Bay and Biscayne National Park. The US Department of the Interior estimates that 960,000 acre-feet per year of freshwater flows will be necessary to achieve the desired salinity conditions in Biscayne Bay. Current operations at the Turkey Point Nuclear Facility run contrary to these goals. Recent data shows that hypersaline migration from the Turkey Point Cooling Canal System is responsible for a massive uptick in hyper salinity in the waters to the west of the plant. Hyper-salinity and the negative impact it produces upon the environment is exactly the problem the BBCW project is meant to address. Furthermore, ammonia and contaminant pollution from the canal system is likely to degrade the Biscayne Bay ecosystem in yet unanticipated ways. In order to achieve this end, water guzzling practices such as those utilized by FPL in the operation of this plant must be reevaluated.

Proposed expansion of the Turkey Point Nuclear Facility to include units 6 & 7 would undermine the goals of the BBCW project even further. The proposed construction would impact 800 acres of wetland, expand roads which block the flow of water to CERP wetlands as well as compartmentalize rehydration lands, use an additional 90 Million Gallons of Water per day, and increase chloride pollution via rock-mining projects, radial well construction, and the removal of water from wetland basins.

2-Current operations of the CCS The original Environmental Impact Statement (EIS) and regulatory regime concerning the Turkey Point Nuclear Facility Cooling Canal System operate under the assumption that the aforementioned canals constitute a closed system." Recently collected data indicates that this is assumption is false. Data generated by FPL under the South Florida Water Management District s Fifth Supplemental Agreement indicates that contaminated hypersaline water from the CCS had migrated down into the aquifer and has spread in all directions, with the leading edge found nearly 4 miles to the west. Furthermore, data indicates that contamination from the CCS has reached the surface waters of the L-31 canal. If true, this constitutes discharge to surface waters of the United States and is likely addressed by federal laws under the National Pollutant Discharge Elimination System currently delegated to the state of Florida to enforce.

Tropical Audubon Society l 5530 Sunset Drive Miami, FL 33143 l (305) 667-7337 l www.tropicalaudubon.org

Tropical Audubon Society South Floridas Voice of Conservation FIGURE 1.

3. Amount of water needed to operate The Turkey Point Nuclear Facility currently acts as the greatest singular water user in South Florida, if not the entire state. Should the planned expansion of the turkey point facility to include units 6 & 7 go through, the plant will need to utilize an additional 90 million gallons of water per day. This incredible burden placed on the local water supply by the Turkey Point facility stands in opposition to the goals of Everglades restoration by bogarting water resources that could have potentially been redirected towards established CERP project goals. In September 2014 FPL obtained emergency approval from the SFWMD to draw up to 100 million gallons of fresh water per day from the L-31E canal for use in the CCS to combat hyper-salinity. Should FPLs bid be approved, the company would then proceed to divert huge amounts of highly caluable fresh water into the CCS for the next 20 years. It is worth noting that in the original 1972 EIS for units 3 and 4 Tropical Audubon member and at that time a University of Miami PhD candidate, Ross McCluney, submitted comments for the EIS noted the concern for a declaration of a state of emergency would result in a [f]requent and unnecessary invoking of the waiver provisions with possible adverse environmental impact. McCluney went on to note that in s situation wherein FPL were given free rein to discharge ulimited amounts of highly saline water to the Sound the effects would be catastrophically and permanently damaging to the ecology of Card Sound and lower Biscayne Bay and that such a situation should be prevented at all costs. While FPL may have slowed the direct discharge into the Bay by purportedly closing open pipes, long term seepage through the permeable limestone has been ongoing for 4 decades. Thus, it is incumbent upon any and all regulatory agencies to compare the true baseline ecological data incorporated in the 1972 EIS to ecological data collected recently to determine actual impacts, if any, from the seepage of hypersaline and chemically loaded CCS water to the surrounding ground and surface water, including in the near shore national park.

Tropical Audubon Society l 5530 Sunset Drive Miami, FL 33143 l (305) 667-7337 l www.tropicalaudubon.org

Tropical Audubon Society South Floridas Voice of Conservation 4-Legacy pollution plume has been recently flushed into Biscayne National Park and surrounding potable water supply source of Miami-Dade County---Newton Well fields closed The recent nuclear Uprate resulting in heightened temperature and salinity discharges into the CCS has also resulted in the shortsighted need to increase in water from any outside source into the CCS has resulted in too much volume and pressure within the unlined porous CCS. The result of the addition of 100s of millions of gallons a day of new water into the CCS has been a constant flushing of the hypersaline and chemically contaminated water within the CCS and underneath the CCS outside and away from the CCS into the Biscayne National Park, to the west and in every direction surrounding the CCS. This flushing effect is observed by way of higher saline and tritium concentrations in the unconfined Biscayne aquifer, which as mentioned above, is the potable water source for Miami-Dade County. This flushing has coincidentally corresponded with the closing of the Newton Well fields, which lie only a short distance from the distance to which contaminants were successfully traced.

figure 2.

5-location and sensitive nature of the surrounding environment and elevation and sealevel rise Tropical Audubon Society l 5530 Sunset Drive Miami, FL 33143 l (305) 667-7337 l www.tropicalaudubon.org

Tropical Audubon Society South Floridas Voice of Conservation There are few true certainties when it comes to predicting the effects of global climate change upon individual systems. Of all the potential changes which may be projected upon the earth system however the rise of average sea levels is almost sure to take place, and in relatively short order. As global temperatures increase, land ice in arctic regions will continue to melt, thus increasing the amount of water circulating in the oceans. At the same time, increased oceanic temperatures will naturally lead to thermal expansion of oceanic water with the ultimate consequence being significant sea level rise. As sea levels begin to rise, unconfined coastal aquifers such as the Biscayne aquifer (which is essential to the provision of drinking water to upwards of 4 million people in South Florida) will become more and more subject to degradation via saltwater intrusion. The effects of saltwater intrusion will only be exacerbated by the increased use of water which would otherwise serve to keep a fresh water head strong to push back on salt water intrusion.

The nuclear Uprate resulting in the increased temperature of the CCS and increased salinity has only exacerbated the many problems produced via the regular operations of the Turkey Point Nuclear Facility and its CCS. The remedy prescribed by DEP has simply caused the pollution to be flushed out with absolute disregard for the ecological consequences. This current state of affairs endangers the local community and national parks, flouts the core tenets of sustainability, and potentially violates federal permitting criteria that DEP is obligated to enforce. Not only is a potential violation of the clean water act an ongoing occurrence, FPL is currently operating without a valid NPDES permit as its IIWF -

no discharge permit expired over 5 years ago. The NRC and EPA cannot allow this activity to continue without stepping in to stop the degradation of a National Park and make sure the Clean Water act is not being violated.

Out of consideration of these facts, the EPA should revisit the final judgment and the EIS from 1972 which highlighted numerous potential problems as well as potential solutions for true abatement of contamination. As was so succinctly stated by Ross McCluney in the 1972 Environmental Impact Statement for the Turkey Point power plant units 3 and 4, If power company executives will be more willing to accept the higher costs of better cooling systems we may be able to avoid many of these unwanted and unnecessary conflicts between electrical power generation and the environment. There are better solutions to abate, mitigate and remediate the ongoing daily salt loading and seepage thereof than the inconsequential goals mandated by the state of Florida. This EA should revisit and appropriately analyze the facts, all of the remedies to ultimately make better use of current technologies that is not in direct conflict with CERP restoration, local resiliency, water supply needs, and sustainability of a national park.

Appendix:

See Comments on The Environmental Impact Statement Concerning Turkey Point Electrical Geerating Units NO.3 and 4 of the Florida Power and Light Company, Ross McCluney, (March 28, 1972)

See State of Florida, South Florida Water Management District, Petition for Formal Administrative Hearing, Tropical Audubon Society, INC. v. South Florida Water Management District And Florida Power and Light Company, Permit Number 13-05856-W, (Jun 23, 2015)

Tropical Audubon Society l 5530 Sunset Drive Miami, FL 33143 l (305) 667-7337 l www.tropicalaudubon.org

Tropical Audubon Society South Floridas Voice of Conservation See State of Florida, Department of Environmental Protection, Petition for Formal Administrative Hearing, Tropical Audubon Society, INC., Blair Butterfield, Charles Munroe and Jeffrey Mullins v. State of Florida Department of Environmental Protection and Florida Power and Light Compay, OGC NO. 14-0741, (Feb 9, 2015)

See Before the South Florida Water Management District, Tropical Audubon Society INC.s Exxeptions to Recommended Order, Tropical Audubon Society, INC. v. Florida Power and Light Company and South Florida Water Management District, DOAH Case No.15-3845, (January 14, 2016)

Please contact me with any questions you may have regarding the foregoing. I can be reached at (786) 543-1926 or tropicalaudubon@gmail.com. Thank you.

Tropical Audubon Society l 5530 Sunset Drive Miami, FL 33143 l (305) 667-7337 l www.tropicalaudubon.org

From: Zac cosner To: Docket, Hearing; Pepperl, Nicole; Scro, Jennifer

Subject:

[External_Sender] Limited Appearance Statement Date: Saturday, January 16, 2016 12:09:32 AM Attachments: TAS Limited Appearance Statement.pdf FPL pollution graph.png Below is the body of the text for the Limited Appearance Statement from the Tropical Audubon Society. I received several bouncebacks and failed to send messages in my original message which included numerous attached documents which pertained to this letter. In order to ensure that each of you receives the necessary text, I send this copy without attachments.

It is the position of the Tropical Audubon Society that the use of the Cooling Canal System (CCS) as an Industrial Waste Water Facility (IWWF) to the current operations of the Turkey Point Nuclear Facility are highly damaging to, Biscayne Bay - an Outstanding Florida Water, Biscayne National Park, the Biscayne Aquifer and are in conflict with the goals of Comprehensive Everglades Restoration Plan (CERP), and in potential violation of the Federal as well as local law based on the localized seepage of CCS into the Biscayne Aquifer and surrounding surface waters of Biscayne Bay and waters that flow into Biscayne Bay.

The Environmental Assessments (EA) for FPLs Turkey Point proposed nuclear units 6 & 7 Finding of No Significant Impact disregarded the existing problems at and around the Turkey Point facility caused by the 40 + years of seepage to groundwater and surface water from the unlined CCS used by units 1-5. In fact, the EA for the recently uprated units 3 & 4 mentioned the increased temperature of the discharge water from the uprated Units 3 & 4 but also found no significant impact relying upon the assumption that the increased temperature, resulting evapotranspiration and increased salt concentrations would be naturally remedied by rainfall and storm water runoff into the CCS. This assumption of natural attenuation has been dispelled by, among other things, the need for addition of 100s of millions of gallons a day from every other source FPL can find to lower the temperature and salinity unexpectedly increased by the increased heat from the uprated units. To the extent the the proposed units 6 & 7 rely at all on the CCS as an IWWF, the CCS has to receive proper review. Until now, the CCS has received a rubber stamp of approval from the agencies charged with environmental oversight.

In order to properly analyze impacts to the surrounding environment, the regulatory agencies must consider the observable decades of hypersaline water and toxic contaminants migrating from the CCS through the permeable substrate into Biscayne Bay and the Biscayne Aquifer.

The toxic contaminants include the accumulation of ammonia producing biotic material within the canals and algal blooms, uncontrollable without addition of more chemicals into the CCS water temporarily contained within, but flowing through the porous limestone.

1-Compatibility with CERP The operations and proposed expansion of the Turkey Point Nuclear Facility are inherently incompatible with the goals of Everglades restoration as promulgated under CERP and its Biscayne Bay Coastal Westlands Project (BBCW). The reasons for the incompatibility are based on the fact that Turkey Point operations tax freshwater resources at higher rates and volumes than experienced any where else in the state of Florida. The freshwater that should be used to achieve the the lower salinity goals within the near shore of Biscayne Bay, as

sought by CERP, is instead used to cool the nuclear units at Turkey Point. Furthermore, prior to the discharge of the cooling water, industrial solvents and radiological constituents mix with the water as it cools the interior structures of the units and is discharged into a shallow unlined porous limestone system. The extreme heated (and chemically treated) discharge water in the CCS increases the evaporation of the freshwater leaving the chemicals, radiologicals, and high salt concentrations in the porous unlined limestone CCS that sits on top of the Biscayne Aquifer and next to an estuary that is a national park. This fresh water would otherwise flow to the Bay and help lower and stabilize the increased salty near shore waters of the Bay.

In context, the BBCW project is a key component of CERP authorized by congress in WRRDA 2014. The stated goal of this project is to increase the ecological health of Biscayne Bay (including freshwater wetlands, tidal creeks and near- shore habitat) by adjusting the quantity, quality, timing, and distribution of freshwater entering Biscayne Bay and Biscayne National Park. The US Department of the Interior estimates that 960,000 acre-feet per year of freshwater flows will be necessary to achieve the desired salinity conditions in Biscayne Bay. Current operations at the Turkey Point Nuclear Facility run contrary to these goals. Recent data shows that hypersaline migration from the Turkey Point Cooling Canal System is responsible for a massive uptick in hyper salinity in the waters to the west of the plant. Hyper-salinity and the negative impact it produces upon the environment is exactly the problem the BBCW project is meant to address. Furthermore, ammonia and contaminant pollution from the canal system is likely to degrade the Biscayne Bay ecosystem in yet unanticipated ways. In order to achieve this end, water guzzling practices such as those utilized by FPL in the operation of this plant must be reevaluated.

Proposed expansion of the Turkey Point Nuclear Facility to include units 6 & 7 would undermine the goals of the BBCW project even further. The proposed construction would impact 800 acres of wetland, expand roads which block the flow of water to CERP wetlands as well as compartmentalize rehydration lands, use an additional 90 Million Gallons of Water per day, and increase chloride pollution via rock-mining projects, radial well construction, and the removal of water from wetland basins.

2-Current operations of the CCS The original Environmental Impact Statement (EIS) and regulatory regime concerning the Turkey Point Nuclear Facility Cooling Canal System operate under the assumption that the aforementioned canals constitute a closed system." Recently collected data indicates that this is assumption is false. Data generated by FPL under the South Florida Water Management District s Fifth Supplemental Agreement indicates that contaminated hypersaline water from the CCS had migrated down into the aquifer and has spread in all directions, with the leading edge found nearly 4 miles to the west. Furthermore, data indicates that contamination from the CCS has reached the surface waters of the L-31 canal. If true, this constitutes discharge to surface waters of the United States and is likely addressed by federal laws under the National Pollutant Discharge Elimination System currently delegated to the state of Florida to enforce.

FIGURE 1.

3. Amount of water needed to operate

The Turkey Point Nuclear Facility currently acts as the greatest singular water user in South Florida, if not the entire state. Should the planned expansion of the turkey point facility to include units 6 & 7 go through, the plant will need to utilize an additional 90 million gallons of water per day. This incredible burden placed on the local water supply by the Turkey Point facility stands in opposition to the goals of Everglades restoration by bogarting water resources that could have potentially been redirected towards established CERP project goals.

In September 2014 FPL obtained emergency approval from the SFWMD to draw up to 100 million gallons of fresh water per day from the L-31E canal for use in the CCS to combat hyper-salinity. Should FPLs bid be approved, the company would then proceed to divert huge amounts of highly caluable fresh water into the CCS for the next 20 years. It is worth noting that in the original 1972 EIS for units 3 and 4 Tropical Audubon member and at that time a University of Miami PhD candidate, Ross McCluney, submitted comments for the EIS noted the concern for a declaration of a state of emergency would result in a [f]requent and unnecessary invoking of the waiver provisions with possible adverse environmental impact.

McCluney went on to note that in s situation wherein FPL were given free rein to discharge ulimited amounts of highly saline water to the Sound the effects would be catastrophically and permanently damaging to the ecology of Card Sound and lower Biscayne Bay and that such a situation should be prevented at all costs. While FPL may have slowed the direct discharge into the Bay by purportedly closing open pipes, long term seepage through the permeable limestone has been ongoing for 4 decades. Thus, it is incumbent upon any and all regulatory agencies to compare the true baseline ecological data incorporated in the 1972 EIS to ecological data collected recently to determine actual impacts, if any, from the seepage of hypersaline and chemically loaded CCS water to the surrounding ground and surface water, including in the near shore national park.

4-Legacy pollution plume has been recently flushed into Biscayne National Park and surrounding potable water supply source of Miami-Dade County---Newton Well fields closed The recent nuclear Uprate resulting in heightened temperature and salinity discharges into the CCS has also resulted in the shortsighted need to increase in water from any outside source into the CCS has resulted in too much volume and pressure within the unlined porous CCS.

The result of the addition of 100s of millions of gallons a day of new water into the CCS has been a constant flushing of the hypersaline and chemically contaminated water within the CCS and underneath the CCS outside and away from the CCS into the Biscayne National Park, to the west and in every direction surrounding the CCS. This flushing effect is observed by way of higher saline and tritium concentrations in the unconfined Biscayne aquifer, which as mentioned above, is the potable water source for Miami-Dade County. This flushing has coincidentally corresponded with the closing of the Newton Well fields, which lie only a short distance from the distance to which contaminants were successfully traced.

5-location and sensitive nature of the surrounding environment and elevation and sealevel rise There are few true certainties when it comes to predicting the effects of global climate change upon individual systems. Of all the potential changes which may be projected upon the earth system however the rise of average sea levels is almost sure to take place, and in

relatively short order. As global temperatures increase, land ice in arctic regions will continue to melt, thus increasing the amount of water circulating in the oceans. At the same time, increased oceanic temperatures will naturally lead to thermal expansion of oceanic water with the ultimate consequence being significant sea level rise. As sea levels begin to rise, unconfined coastal aquifers such as the Biscayne aquifer (which is essential to the provision of drinking water to upwards of 4 million people in South Florida) will become more and more subject to degradation via saltwater intrusion. The effects of saltwater intrusion will only be exacerbated by the increased use of water which would otherwise serve to keep a fresh water head strong to push back on salt water intrusion.

The nuclear Uprate resulting in the increased temperature of the CCS and increased salinity has only exacerbated the many problems produced via the regular operations of the Turkey Point Nuclear Facility and its CCS. The remedy prescribed by DEP has simply caused the pollution to be flushed out with absolute disregard for the ecological consequences. This current state of affairs endangers the local community and national parks, flouts the core tenets of sustainability, and potentially violates federal permitting criteria that DEP is obligated to enforce. Not only is a potential violation of the clean water act an ongoing occurrence, FPL is currently operating without a valid NPDES permit as its IIWF - no discharge permit expired over 5 years ago. The NRC and EPA cannot allow this activity to continue without stepping in to stop the degradation of a National Park and make sure the Clean Water act is not being violated.

Out of consideration of these facts, the EPA should revisit the final judgment and the EIS from 1972 which highlighted numerous potential problems as well as potential solutions for true abatement of contamination. As was so succinctly stated by Ross McCluney in the 1972 Environmental Impact Statement for the Turkey Point power plant units 3 and 4, If power company executives will be more willing to accept the higher costs of better cooling systems we may be able to avoid many of these unwanted and unnecessary conflicts between electrical power generation and the environment. There are better solutions to abate, mitigate and remediate the ongoing daily salt loading and seepage thereof than the inconsequential goals mandated by the state of Florida. This EA should revisit and appropriately analyze the facts, all of the remedies to ultimately make better use of current technologies that is not in direct conflict with CERP restoration, local resiliency, water supply needs, and sustainability of a national park.

Appendix:

See Comments on The Environmental Impact Statement Concerning Turkey Point Electrical Geerating Units NO.3 and 4 of the Florida Power and Light Company, Ross McCluney, (March 28, 1972)

See State of Florida, South Florida Water Management District, Petition for Formal Administrative Hearing, Tropical Audubon Society, INC. v. South Florida Water Management District And Florida Power and Light Company, Permit Number 13-05856-W, (Jun 23, 2015)

See State of Florida, Department of Environmental Protection, Petition for Formal Administrative Hearing, Tropical Audubon Society, INC., Blair Butterfield, Charles Munroe and Jeffrey Mullins v. State of Florida Department of Environmental Protection and Florida Power and Light Compay, OGC NO. 14-0741, (Feb 9, 2015)

See Before the South Florida Water Management District, Tropical Audubon Society INC.s Exxeptions to Recommended Order, Tropical Audubon Society, INC. v. Florida Power and Light Company and South Florida Water Management District, DOAH Case No.15-3845, (January 14, 2016)

Please contact me with any questions you may have regarding the foregoing. I can be reached at (786) 543-1926 or tropicalaudubon@gmail.com. Thank you.

Zachariah A. Cosner University of Miami, Tropical Audubon Society, MDPRC 305-608-8303

-WoodyGuthrie