ML17266A431
| ML17266A431 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/13/1981 |
| From: | Boyhan G RESOURCES RECOVERY (DADE COUNTY), INC. |
| To: | |
| Shared Package | |
| ML17266A429 | List: |
| References | |
| NUDOCS 8104090700 | |
| Download: ML17266A431 (25) | |
Text
BEFORE THE UNITED,Siw'ZES OF AMERICA FEDERAL ENERGY REGULATORY CO&D1YSSXON r" I!-'l: 0i! H" "'r.CtlV 'I"if<Y Resources Recovery Docket No. QF- =,=-.up!!';! 0> v C~~p,!q~gg~o~;.
(Dade County), Inc.
NOTICE OF QUALIFICATION, PURSUANT TO 18 C.F.R. 5 292.207 (a),
OF A RESOURCE RECOVERY FACILITY IN DADE COUNTY I FLORIDAF AS A QUALIFYING SMQL POWER PRODUCTION FACILITY Resources Recovery (Dade County), Inc., owner and operator of a resources recovery fa'cility in Dade County, Florida (the "Facility") hereby gives notice pursuant to 18 C.F.R. 1292.207(a) that the Facility is. a "qualifying, small power production 'facility" C
within the meaning of Section 201 of the Public Utility Regulatory 1 Policies Act of 1978 (."PURPA"), 16 U.S.C. 5 796, and 18 C.F.R.
Part 292, 45 Fed. ~Re .17959 (March 20, 1980), and is thereby en-titled to the benefits conferred by Section 210 of PURPA, 16 U.S.C.
5824a-3, and. the regulations promulgated thereunder. In accordance wi,th 18 C.F;R. 5292.207 (a), the following information is provided:
- 1) The name and address of the qualifying small power producer is:
Resources Recovery (Dade County), Inc.
P.O. Box 524056 Miami, Florida 33152 The facility is located in'northeastern Dade County, Florida.
4090 Q'0
- 2) The Facility is a small power production facility which will process solid waste, recover recyclable material, handle up to 18,000 tons per week of s'olid waste, convert combustible materials into refuse-derived fuel ("RDF"), and burn the fuel to raise steam which in turn generates electricity. The Facility is the largest of its kind in the United States. The qualifying facility includes four boilers, four sets 'of, mechanical cyclone dust collectors and four electric turbogenerators, two turbogenerators and condensers and all required auxiliary and control equipment.
. All equipment for combustion of the RDF and generation of electric energy and its delivery to the transmission network is included.
- 2) The primary energy source is biomass.
- 3) The Facility has an installed nameplate electric genera-tion capacity of approximately 76 megawatts at 13.8 KV, 3 phs 60 cycles.
DATE: March 13,1981 RESOURCES RECOVERY (DADE COUNTY), INC.
By G rge E. Boyhan Executive Vice President
+r CERTIFICATE OF S~RVIC>
I hereby certify 'that'I have this day served a copy of the oregoing doqument upon:
Hr. Robert Talion Executive Vice President Florida Power &. Light Company P.O. Box 529100 Miami, Florida 33152 in accordance with the requirements of. Section 1.17 o'f the Rules of Practice and Procedures.
l ~
Dated at Washington, D.C.'this 13th day of March 1981.
Lewis =. Leibowitz Counsel for Resources Recovery (Dade County), Inc.
APPENDXX B Arent, Fox, Kintner, Plotkin 8c Kahn Federal Bar Building, 1815 H Street, N.W.
Washington, D.C. 20006 Telephone: (202) 8574000 CaMe:hRFOX 'Plex:NtU892672 1IT440266 David J. Bardin
'ounsel (202) 857-6089 April 3, 1981 CERTIFIED MAIL RETURN RECEIPT REQUESTED L. Christian Hauck, Esq.
Vice President, Legal Affairs Florida Power 6 Light Company 9250 West Flagler Street Miami, Florida 33152
Dear'Mr. Hauck:
Our client, Resources Recovery (Dade County), Inc.
(RRD) now owns and operates in Dade County, Florida, a qualifying small power production facility (QF), as noticed to the Federal Energy Regulatory Commission (FERC) and Florida Power and Light Company (FPL) on March 13, 1981.
As an alternative to the exclusive sale of electric energy to FPL, RRD wishes to explore .competitive opportunities for sales to other electric would have utility entities. To that end, RRD to turn to FPL for transmission services;'ince FPL is the monopoly owner of the transmission network in the area, we believe that the anti. trust laws require FPL to provide such services.
More directly, we understand that upon approval of the proposed settlement agreement pending in NRC Docket No. 50-389A (St. Lucie Plant', Unit No. 2), the terms of that agreement, in the context of general law, will oblige FPL to transmit electricity on behalf of RRD to potential customers other than FPL. Please confirm our understanding, or advise us of any impediments that you see to full implementation of such, obligation on behalf of RRD; In order to exercise its rights, RRD also needs the following information (including copies of tariff, guideline or other documents as relevant):
- l. Is FPL prep'ared to transmit the electric output of the QF for wholesale sales to one or more other entities?
- 2. What would be FPL's terms and conditions for
-such transmission service?
~
J Arent, Fox, Kintner, Plotkin-8c Kahn
- 3. Under what tariff or other established provi-sions would FPL transmit the electric energy?
at
- 4. If RRD sells all of the wholesale to FPL or others electric output of the QF P a'. under what existing rate schedule would FPL render retail service to the QF?
- b. under what proposed rate schedule would FPL render retail service to the'QF if the Public Service Commission approves FPL's pending proposals?
internal 5- If the QF chose to purchase energy needed for use from FPL at retail, under applicable rate schedules, would FPL also require the. QF to buy "back-up" or "maintenance" power? If yes, why?
- 6. Would FPL attempt to place any restrictions on its transmission services?
We would appreciate the favor of a reply within two weeks.
Very truly yours, David J. Bar z.n cc: Robert A. 'Ginsburg, Esq.
County Attorney Dade County Court House Room 1626 Miami, Florida 33130
APPENDIX C clarify, that existing rules and law would be available for rec ours e.
3 '
HS. REBER: Yes, Florida law.
COMMISSIONER GUNTER: There is sufficient law in the statutes for the State of Florida to take care of the situation you'e addressing.
NS. REBER: Commissioners, if 'there are no other further questions of staff, perhaps we would Like to move into some statements for the next half hour or so.
10 COWi ISSIONER GUNTER: I think we should.
MS. REBER: Okay. I would just, since we only have 12 a half hour, I have 20 speakers listed. If there's another list circulating of people who want to speak, I would need to 14 get that List and have it typed up. Mould you prefer that I 15 read off the first five so they could be prepar'ed to address the Conzaiss ion?
17 COMMISSIONER GUNTER: Since we do~'t have but a 15 limited time period, why don' you just start with the first 1g one and we'l go from there?
20 HS. REBER: Okay. Tf you would please identify 21 yourself for the court 'reporter before you speak,,it would be 22 appreciated. The first speaker wishing to address the Commis-23 is Governor Reubin Askew.
'ion 24 GOVERNOR ASKE';J: Mi . Chairman, members of the Com-mission, I'm Reubin Askew, a member of the law firm of
1.25 Greenberg, Traurig, Askew, et al. I appear on behalf of Dade County to voice our strong support for the Commission's pro-3 ~
posed rules respecting utilities'bligations to cogenera-tors and small power producers. I'm submitting for the record, five copies of my oral statement short of what I may put in between, Dade County's written comments, and the sug-gested revisions of the text of the rule.. I do not appear here as an'.~crt in this area, but I am accompanied by the gentleman that just rose, Mr. Nordhaus, Robert Hordhaus who 10 was the general counsel for the Federal Energy Regulatory Commission both at the time the legislation passed, PURPA
,l 12 passed, as well as the general counsel for FERC at the time 13 that the regulation was adopted. So I think that he is a 14 resource that the Commission may 'wish to make use of during 15 the course of the hearing. I'm also accompanied by Mr.
16 Mer ett Stierheim, who is the County Manager of Metropolitan Dade County; Dennis Carter, the Assistant County Manager of 18 Metropolitan Dade County; and Robert Ginsberg, the County Attorney of Metropolitan Dade County.
20 I have listened with great interest to all that' 21 been said. A couple of things have occu red to me. First of 22 all, I think it' rather obvious that the private investor utilities in this country don' come with great enthusiasm 24 toward this law. They opposed it almost every step of the wa:i-25 in its consideration and its enactment as. well as the
126 regulations. So Z think that the hearing should be put in the context that Hs. Reber so eloquently said in one of her state-3 ~
ments when she mentioned bargaining leverage for quali ying facilities. Now that is essentially what this is all about.
Also she said, more likely to encourage cogeneration. And the gentleman who presented your economic impact statement, which, in his opinion, he pointed out what he thought was a myth of the monopoly per se of utilities, but only toward the trans-mission and distribution as opposed to the generation and pro-10 duction. And that there should be opportunity to 'competition on the production side.
12 Now E've just had the distinct opportunity of repre-13 senting the United States of America for L5 months negotiating all over the world, and 1 want to tell you that there's no 15 greater problem facing us economically in the industrialized 16 Hest, than our dependence on foreign oil and the fact that we 17 are dealing with a cartel. And this country last year importe by volume, 19% less foreign oil than it did 'I the year before, 19 but we paid 63% more per average cost per barrel which shows 20 the critical importance of the energy package and this part that it plays in it of trying to understand thate are going 22 to have to develop some sources for energy other than j us t the trad.'tionaL deoendence upon oil. That's what prompted the 24 President, that' what prompted the Congress to.enact th' to.
25 ,begin with, was simply to encourage competition a'nd the
127 production of energy.
Now one of the things you learn quite quickly in negotiation is that if you can' negotiate from a position of leverage, you'e in trouble. And I don't know anyone right now, municipality or otherwise, that can approach a'large utility company and negotiate from a position of leverage.
7 You can'. That's ezact1.y why Ns. Rebe was so correct when 8 she talked about bargaining leverage fo.-. the qualifying facili Now if we'e serious, we'e going to have to view 10 this law and its implementation, that if it is not maximized in terms of how you interpret it in favor of a qualifying 12 fac. lity or small generation unit, then want to tell you, T.
13 you get.caught up in a lot of legalistics. And you have some 14 of the most competent people. in this state at this table 18 representing the utility companies, some representing not-utility compan'es. And you begin to 'see all the lega istics you can get tied up in. And I want to ask you that you step 18 back from all this when it comes time to deciding and realize, as you constantly do, that you represent the public interest.
And the public interest is served for us trying to get weaned 21 away from a dependence upon foreign oil. And when you comb'ne that with one of. the most critical problems facing this count" 23 indus tr ia 1 ly, it' kept a capital'ormation.
24 Now isn' it somewhat familiar when utility companies, say, "Give us some spec'al rules as we go along to try to help
128 us build the capacity in capital formation," and this is one of the areas that's designed to try to help zelieve them of 3 ~
further capacity in terms of capital formation.
Now it's quite right from the standpoint of the public utility, from the standpoint of the private-investor public utility. In the end, whatever they pay, their customer are going to have to pay. So they certainly have an interest themseLves other than just a profit from the capital investmen that personalLy people put in as an investor in the'r utilty.
10 So I hope that in .all of this that we don't get lost in what your staff has done. There may be some disagreement in the staff, but I want to tell you, how many attorneys can 13 you get together representing different clients that agree on 14 the same thing anyway? So that's not strange.
15 Dade County is commenting on these proposed rules 16, b cause it is actively examining the feasibility of a possible 17 cogeneration unit. as well as a small power production pzoject.
P Zn the planning s tage, there are 25 megawatt cogeneration 19 facilities to supply heat, air conditioning, and electric 20 power for the proposed government center downtown. Second, a 21 wastewater treatment plant which will include a small power 22 production facility 'enerating 3. 5 megawatts of 23 power from methane derived from sewage sludge. And, or" course it'-s no secret that in addition there is a 78 megawatt resouzc recovery gene aton facility, the status of wh'ch is the
i 129 subject of dispute between some of the contracting parties and which faciLity may or may not become affected by these pro-posed rules. And, of course, there could be many other ~nits in the future which might come under the ruLes.
The Commission's rules,,in my view, substantially carry out the national objectives that the generation and small power production program is designed to achieve their objective. And I wou d commend the staff in their efforts.
As I tell you, I have participated in too many governmentaL 10 hearings. 'In fact, this is a tremendous adjustment for me.
This is the first meeting I'e attended in approximately 10 12 years in Tallahassee I didn't preside on. Tt ce'rtainly gives 13 you a much greater freedom when you can preside. So when you get really some of the highest paid lawyers, of which I hope 15 someday to become part of the ranks, taking on your staff, you 16 realize that a tremendous amount of effort has gone into this.
17 And, sure, you know, we get paid by the hour. That makes a 18 difference in terms of how brief we may appear to be. And 19 some vaLid points are being made. And we have some we'd like 20 to make as well. But, more importantly, these rules will also 0
V 0 21 provide valuable benefits. First, utilities in Florida,
'4 4
22 despite their best efforts to convert to other Less expensive 23 fuels are still substant'ally dependent on all the fue's of 24 their generating facilities. This nation and Florida's 25 dependence on foreign oil must be reduced as rapidly as is
130 econom'cally feasible. Cogeneration and small power pxoductioq.
offer significant opportunities to reduce dependence 'oy sub-3 stituting renewable sources for oil.
And I want to tell you, we'eep producing an awful lot of garbage, an awful lot, of waste, so I think that can be considered renewable. As the energy input for electric genera-tion and by promoting the more efficient use of fuel. that can be obtained through cogeneration. Thes'e benefits can be ob-I tained without any increase in electric rates to the citizens of the state. The PSC's rules guarantee that no utility will be required to pay more for power from cogeneration and small power production facilities than the utilities'voided cost.
13 That is a cost of the power it would otherwise have generated or purchased.
15 The second benefit to the citizens of this state is that this program will make it -economically feasible for Dade 17 County and other local governments in the state to use munici-pal soLid waste and "sewage sludge as fuel. Rather than using 19 increasingly scare or urban suburban land for waste disposal.
20 These local governments can use these by-products of our 21 urban society as an energy input.
22 The economic benefits to the citizens of Dade County, 23 for instance, in the form of lower waste disposal fees, Lower ta:<es, can amount to millions of dollars each year. Some of 25 these util't'es have approached this whole idea differently,
131 and I'm not here to paint any one industry with a broad brush.
I will, however, say that Florida Power Company in working wit Pinellas County and working out their rates, I think you'l find that the people representing Florida Power will tell you that they come close, almost 957. to meeting PURPA.. And this is an example of what a utility can do when it really gets together with a community and really wants to encourage it.
But aside from the question o'f the utility industry, none of us, legal or otherwise, are particularly in the busi-10 ness to encourage competition. But when we give a semblance of a monopoly, the overriding public interest must remain 12 clear. An essential element of the'proposed rules and one
.13 which is critical to providing the necessary incentives for 14 cogeneration and small power production is a requirement that 15 utilities purchase power from qualifying facilities at 1007.'f 16 avoided cost. This requirement is derived from the FERC rules 17 implementing PURPA, and it' clearly necessary to encourage 18 rapid utilization of this technology.
19 Our written comments, which I will submit for the 20 record at this point, contain a number of suggestions which, in our view, will clarify the proposed rules. In my oral 22 statement, I wil1 ment'on orily those which are of major sub-23 stantive import. First, the PSC should adoot the same pro-24 cedural mechanism. for determining avoided capacity costs as it has adoptee for determining avoiced energy costs. Namely, the
132 utility should be required to fil.e a tariff stating the avoide capacity costs payment it will make to a quali ying facility which is really to enter into a legally enforceaole commitment 4 to sell power to the'utility. Under such a tariff, the burden would be on the utility to show why the offered capacity is'ot reliable or usezul rather than on the qualified facility .
to show why the capacity is reliable and usezul to the utility Now just think back about what you'e seen and the display of horrendous legal talent th's morning. If you think 10 that you put the monkey on the back to the qual fying utility, 11 to what extent are you really going to get to the merits? In 12 terms of having the technology and the ability to understand 13 it, we say it should just be the opposite. A qual.ifying 14 facility is not likely to have the access to the sophisticated 15 data necessary to prove the usefulness to the utility of its 16 offered capacity.
17 Second, the concept of decremental fuel cost, should 18 be clarified so it is consistent with E'ERC rules. Avoided 19 energy costs under PERC's rules is not limited to avoided fuel 20 costs. It .also includes avoided purchased power and non-fuel 21 ooeration and maintenance costs. These costs may, in some circumstances, be substantial components of avoided energy 23 cos ts.
24 As I noted above, our prepared statement has- a num-25 ', be" oz other suooestions oz a more eechnical nature wh'ch we
133 will also urge the Commission to consider. And, as I say, since I'e already admitted I'm no expert~to give greater credibility to that I
which is suggested, I would say that. Ãr.
Hordhaus, who played a very important role in doing them, Ls the one who assisted us in the preparation of the comments as well, as my testimony. Dade County views the proposed rules as a significant step forward for our state and urges their adoption by the Commission in final forra with,the changes we sugges'ted.
10 In conclusion, adoption of PURPA is intended to benefit the public by encouraging development of small power and cogeneration facilities and thereby promote competition in the energy production field. That was no easy thing for me as Governor to say that this business of requiring utilities 15 every time there's an increase in oil it will have to come back for approval. All that was doing was adding expense to 17 the process and eventually costing-'their own subscribers or 18 purchasers. And, so I strongly supported trying to have some 19 type of fuel adjustment. Because utilities, unfortunately, 20 are dealing with the most expensive, the most volatile ever 21 increas'ng item that they have, and tne publ'c isnalways 22 fully appreciative of how expensive the product is and why it 23 must essentially be borne by those it serves.
24 I would hope that the standard for any change 'n the prooosed PSC rules will be to assure maximum development
134 of small power and generation facilities, to promote competi-tion, and thereby to best serve the public in whose interest
- 3. PURPA itself was adopted.
Now tha,t' my statement. I'e been waiting three hours to give it. I'm all loaded up, and that's MARKS: Governor, let me ask it.'OMMISSIONER this question right quick if I may, just as a general question concerning'his whole idea. Do you believe that the rule as presented by staff presently is in the best interest of the 10 ratepayers of this 'state?
GOVERNOR ASKER: Absolutely.
12 COMMISSIONER MARKS: You talked about the split-the-13 savings concept indirectly somewhat. You didn't directly 14 address that. Do you believe that concept is a disincentive 15 to cogeneration?
16 GOVERNOR AS'cKH: I'm not expert enough on that to 17 respond to it.. If you want to ask me .why our trade deficit 18 continues to have problems because of imported oil, I'1l be 19 happy to respond to that.
20 COt&ISSIONER YMRKS: I'm not an expert on. that, so I 21 don' even know how to ask that question.
22 GOVERNOR ASKER: Although I wil.l say that Mi 23 Hordhaus is here, and he might wish to respond to it. That' why we'e asked him to come along.
25 COtQ!ISSTONER ~~KS: Let me ask you anothe question
APPENDIX D
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMI SION In the Matter of FLORIDA POWER & LIGHT COMPANY Docket No. 50-389 (St. Lucie Plant, Unit No. 2)
CERTIFICATE OF SERVICE I hereby certify that copies of PETITION FOP. LEAVE TO INTERVENE AND REQUEST FOR HEARING. submitted by Resources Recovery (Dade County), Inc. and Parsons & Whittemore, Inc. and the accompanying BRIEF IN SUPPORT THEREOF were served on the following persons via first class mail, postage prepaid, this 7th day of April, 1981.
Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Harold- Denton Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington,- D. C. 20555 Harold Reis, Esquire Lowenstein,.Newman, Reis, Axelrad & Toll 1025 Connecticut Avenue, N.W.
Washington, D. C. 20036 Janet R. Urban, Esquire Antitrust Division U. S. Department of Justice P. O. Box 14141 Washington, D. C. 20044
Robert A. Jablon, Esquire Alan J. Roth, Esquire 2600 Virginia Avenue, N.W.
Washington, D. C. 20037 One of Counse
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