[NukeNet] Individual Action in progress, Florida Alliance update, Part 2.
Minimushomines at aol.com
Minimushomines at aol.com
Mon Jan 7 20:03:57 EST 2008
Dear,
Nuke net, grass roots independent, environomic activist, advocates, (Twigs,
swarmers and opposers of toadies, chameleons and people that do unmentionable
things to swine.
Part 2) Pre Hearing statement.
Comments and other input appreciated from the above mentioned social
subgroups.
..........................................................................................................................................................
BEFORE THE PUBLIC SERVICE COMMISSION
Re: Florida Power and Light Company’s DOCKET
NO. 070650-EL
Petition to Determine Need for FPL Turkey Point
Nuclear Units 6 and 7 Electrical Power Plant
Dated: January 4, 2008
INTERVENORS BOB AND JAN KRASOWSKI’S PREHEARING STATEMENT
Pursuant to Order No. PSC-07-0869-PCO-EL, issued October 30, 2007,
Intervenors, Bob and Jan Krasowski hereby file their Prehearing Statement.
1. All known Witnesses.
None.
2. All known exhibits.
None at this time. Pursuant to Order No. PSC-07-0869-PCO-EL, issued
October 30, 2007, #IV and # VII, E, we reserve the right to present exhibits
at the Prehearing conference scheduled for January 14, 2008.
3. Basic Position Statement
A large variety of efficient resource management as well as power management
and generating options are available to the utilities that service the
residential, institutional and business energy demands of Florida. In assessing
the options for meeting these energy demands we have come to the conclusion
that the nuclear project proposed by FP&L for Turkey Point does not represent
the best choice available to service FP&L customers. We contend that when
compared to other options and strategies the Turkey Point 6&7 proposal poses an
extended period of economic risk that is unreasonable and diminishes the
economic wellbeing of FPL’s Florida customers now and in the future. Therefore, we
request that the petition for determination of need for Turkey Point 6&7 be
denied.
FP&L’s representatives allege that the Turkey Point 6&7 proposed project
meets the needs criteria established by the State of Florida in FS403.519(4) in
that the project contributes to FPL’s power system’s reliability and
integrity, it’s fuel diversity, base load generation capacity, and its effort to
deliver adequate electricity at a reasonable cost. That it continues to be a
viable option after any renewable energy sources and technologies or
conservation measures that may be taken or are reasonably available to FPL that might
mitigate the need for the proposed generating units has been considered,
while also providing the most cost effective source of power.
It is our belief, based on our research, that the projected cost of this
proposal as alleged by FP&L does not represent an accurate assessment of the
actual costs of the project. That the cost of managing the waste associated with
this nuclear project has not been accurately identified. Future costs
attributed to CO2 and other green house gas (GHG) emissions attributed to the
mining, milling, and refining of nuclear fuel have not been adequately accounted
for. Potential cost charged for radioactive emissions from mining and
operations are not mentioned. The availability and cost of water need to be
considered.
It is our contention that every dollar of FP&L rate payer money (14 to 24
Billion Dollars) proposed to be spent on the proposed Turkey Point 6&7 nuclear
power project could be better spent on efficiency, conservation and
renewables; financing programs that may include embellishing existing or creating new
DSM programs, leveraging through cost sharing the expansion of net metering /
distributive energy programs. The integration of solar thermal and geo
thermal applications can mitigate peak load. The more efficient use of the
existing base load can eliminate the need for new base load capacity. We also see a
slowing of growth in Florida that calls into question the proponent’s
projection for need. New building design criteria will also reduce the need for new
generation.
4. Statement of Positions and issues
ISSUE 1: Is there a need for the proposed generating units, taking
into account the need for electric system reliability and integrity, as this
criterion is used in Section 403.519(4), Florida Statutes?
Position: No, the current and future needs of Floridian’s power can be met
with greater reliability and integrity with the implementation of
efficiency/conservation measures, the graduated increased use of renewable technologies,
a generous net metering / distributive energy program.
ISSUE 2: Is there a need for the proposed generating units, taking
into account the need for fuel diversity, as this criterion is used in Section
403.519(4), Florida Statutes?
Position: No, distributive generation of thermal and pv solar and gas
capture for agriculture are preferred methods of establishing fuel diversity over
nuclear in the existing energy needs environment.
ISSUE 3: Is there a need for the proposed generating units, taking
into account the need for base-load generating capacity, as this criterion is
used in Section 403.519(4), Florida Statutes?
Position: No, there already exists sufficient base-load. Future base-load
and current base-load can incrementally be provided and replaced by efficiency
and cleaner new renewable applications. Population decline and greater
efficiencies allow current existing base-load capacity to satisfy the need.
ISSUE 4: Is there a need for the proposed generating units, taking
into account the need for adequate electricity at a reasonable cost, as this
criterion is used in Section 403.519(4), Florida Statutes?
Position: No, reasonable cost has not been established here. The cost of
the waste storage, CO2 and other greenhouse gases related to fuel assessment
are not complete. Water costs remain a question. We already have adequate
electricity. The economic costs of insuring the risks associated with an
unforeseen event may be limited to FPL but extend to the overall population in the
amount of billions and billions of dollars and need to be considered in the
cost/risk assessment and in relationship to the other options.
ISSUE 5: Are there any renewable energy sources and technologies or
conservation measures taken by or reasonably available to Florida Power &
Light Company which might mitigate the need for the proposed generating units?
Position: Yes, (An assessment of the meaning of the word reasonable is
seriously necessary in regard to this issue). Enormous opportunities for
efficiency and conservation, distributive energy and clean technologies exist.
ISSUE 6: Will the proposed generating units provide the most
cost-effective source of power, as this criterion is used in Section 403.519(4),
Florida Statutes?
Position: No, this project’s costs must be compared with an equal amount of
analysis to a renewable/ efficiency option. The proposed nuclear project time
line extends over a period that would allow the monies dedicated to the
project to incrementally provide for FPL customer energy needs by the use of
efficiency programs, elevated standards of power usage and investments in clean
energy technologies, without the costly, problematic issues of long term toxic
waste management, among other things.
ISSUE 7: Based on the resolution of the foregoing issues, should the
Commission grant Florida Power & Light Company’s petition to determine the
need for the proposed generating units?
Position: No
ISSUE 8: Should this docket be closed?
Position: Yes, this docket should be closed and FPL’s petition denied
due to the lack of adequate analysis of all reasonable options and the
extreme risk and inability to project accurate costs which in turn stifles the
development and investment in efficiency and new clean technologies
Additional Issues
FPL
ISSUE 9: If the Commission grants Florida Power & Light Company’s
petition to determine the need for the proposed generating units, should the
Commission’s order expressly state support for the development of new nuclear
generation, affirm the need to take steps now to preserve new nuclear
generation as a resource option to meet future customer needs, acknowledge the risks
and costs associated with a project of such magnitude and the corresponding
stepwise role of the annual review process and emphasize the importance of
continued regulatory support throughout the process? (FPL 8)
Position: It is our position, as stated during the effort to identify
issues, that issues 9-12 are not appropriately placed in this docket. In
particular reference to issue 9 if we are incorrect in our assessment of the
inappropriateness of the placement of these issues in this docket we have listed an
additional issue for ourselves that is identified in the pending motions
portion of this document that requests specific actions by the PSC in the event
they deny this petition.
ISSUE 10: If the Commission grants Florida Power & Light Company’s
petition to determine the need for the proposed generating units, is it prudent
for FPL to make advance payments for such long-lead procurement items as are
reasonably necessary to preserve the potential for 2018-2020 in-service dates
for the proposed generating units? (FPL 9)
Position: No, we believe issue 10 is not appropriate for this docket.
ISSUE 11: If the Commission grants Florida Power & Light Company’s
petition to determine the need for the proposed generating units, are prudent
advancepayments made prior to the completion of the proposed generating units’
site clearing work properly characterized as “pre-construction costs,” to be
recovered pursuant to the mechanism provided in Rule 25-6.0423, F.A.C.? (FPL
10)
Position: No, we believe issue 11 is not appropriate for this docket
ISSUE 12: If FPL were to file for recovery by May 1, 2008, would
pre-construction costs associated with the proposed generating units that the
Commission determines are reasonable and prudent be included for cost recovery
purposes as a component of the 2009 Capacity Cost Recovery Factor in the
annual Fuel and Purchased Power Cost Recovery proceeding, pursuant to Rule
25-6.0423(5) (c), F.A.C.? (FPL 11)
Position: No, we believe issue 12 is not appropriate for this docket
FMPA/FMEA
ISSUE 13: Does FPL's nuclear power plant petition contain a summary of
any discussions with other electric utilities regarding ownership of a
portion of the plant by such electric utilities, consistent with the requirements
of Rule 25-22.081, F.A.C.? (FMPA/FMEA 7)
Position: No, and the fact that FPL’s petition does not contain a summary of
any discussions they had with other electric utilities regarding ownership
of the portion of the plant should be rectified by FPL amending their original
petition to include the required information or, if there have been no
preliminary discussions as claimed, and no summary is possible, FPL should be
required to withdraw their present petition and submit an accurate correct one
starting from square one.
OUC
ISSUE 14: Does not 403.519(4)(b), Fla. Stat., stating that the
Commission shall “take into account matters within its jurisdiction, which it deems
relevant” allow the Commission to conclude that co-ownership is relevant
especially in light of (4)(b)(2) which requires the Commission to consider
whether the approval will enhance the reliability of power production within the
state (not just in FPL’s territory) and (4)(b)(3) requiring the Commission to
take into account the plant’s contribution to the long-term stability and
reliability of the electric grid? (OUC 1)
Position: No.
ISSUE 15: Did Florida Power and Light’s Petition, as required by Rule
25-22.081 (2) (d) F.A.C., contain a summary of any discussions Florida Power
and Light had with other electric utilities concerning the other electric
utilities’ ownership of a portion of the Florida Power and Light nuclear plant?
(OUC 2)
Position: No, and the fact that FPL’s petition does not contain a summary of
any discussions they had with other electric utilities regarding ownership
of the portion of the plant should be rectified by FPL amending their original
petition to include the required information or, if there have been no
preliminary discussions as claimed, and no summary is possible, FPL should be
required to withdraw their present petition and submit an accurate correct one
starting from square one.
ISSUE 16: Does 403.519(4)(a)(5), Fla. Stat., and Rule 25-22.081(2)(d)
F.A.C., create any duty on Florida Power & Light (“FPL”) to initiate
discussion with other utilities that might have an interest in ownership of a
portion of the nuclear plants or is this legislation and rule meaningless and may
be ignored all together (FPL says they can satisfy law and rule by not having
any discussions and reporting that fact at FPL Response, Paragraph 2, page
2)? (OUC 4)
Position: No, to the following sentence, “Does 403.519(4)(a)(5), Fla.
Stat., and Rule 25-22.081(2)(d) F.A.C., create any duty on Florida Power & Light
(“FPL”) to initiate discussion with other utilities that might have an
interest in ownership of a portion of the nuclear plants.”
No to the following portion of issue 16 “or is this legislation and rule
meaningless and may be ignored all together.”
Yes to the following portion of issue 16 “FPL says they can satisfy law and
rule by not having any discussions and reporting that fact” (See our
position on issue 14)
ISSUE 17: Does OUC, a utility that presently has ownership in two
nuclear power plants, have a substantial interest in having meaningful
discussions with Florida Power & Light regarding ownership of a portion of the nuclear
power plants at issue here as required by 403.519(4)(a)(5), Fla. Stat.?? (OUC
5)
Position: No, no such requirement exists
ISSUE 18: Should the Commission infer any intent by Legislature from
actions that were not taken by the Legislature (an amendment was proposed but
withdrawn)? (OUC 6)
Position: No.
Seminole
ISSUE 19: Has FPL engaged in meaningful discussions with other
electric utilities regarding ownership of a portion of the proposed nuclear plants
by such utilities? (SEMINOLE 7)
Position: Yes, FPL has stated in their petition on page 37 IX that “FPL has
held preliminary discussions regarding the potential for ownership
participation with several Florida utilities who have expressed interest. As FPL
proceeds through the licensing phase and begins dedicated commercial negotiations
with the selected vendor, opportunities for partnership with Florida utilities
will continue to be explored.” The fact that FPL’s petition does not
contain a summary of any discussions they had with other electric utilities
regarding ownership of the portion of the plant should be rectified by FPL amending
their original petition to include the required information or, if there have
been no preliminary discussions as claimed, and no summary is possible, FPL
should be required to withdraw their present petition and submit an accurate
correct one starting from square one.
ISSUE 20: If not, should the Commission require such discussions?
(SEMINOLE 8)
Position: No, only a summary is provided by law.
5. Stipulated issues
None at this time.
1. Pending motions and other matters upon which action is sought
If the commission denies FPL’s petition for the determination of need for
the proposed units, should the commission order expressly state support for a
comprehensive analysis of all energy efficiency and conservation
opportunities, all clean renewable generating options and the value of an expanded net
metering/ distributive energy program and research into the application of
innovative methods of reordering the competitive marketplace in Florida to more
effectively and prudently address the energy needs of the State’s residents
financed with the billions of that would have been used to pay for the nuclear
power plants?
7. Pending claim for confidentiality
None at this time
8. Objections to witness qualifications as an expert, none.
None at this time
9. Compliance with Order No, PSC-07-0869-PCO-El,
At this time persons who are intervenors are unaware of any requirements of
the Order Establishing procedure with which they can not comply.
Respectfully submitted this 4th day of January, 2008.
s/ Bob Krasowski
s/ Jan Krasowski
Bob and Jan Krasowski
1086 Michigan Ave.
Naples, FL.34103-3857
239-434-0786
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