Blue Ridge Environmental
Defense League's comments on
Carolina Power &
Light IRP
To: NC Utilities Commission
From: Louis Zeller, BREDL
Place: Asheville, Buncombe County Courthouse,
District Courtroom 2
Re: Carolina Power & Light Company 1999
Annual Integrated Resource Plan,
Docket No. E-100, Sub 84
Date: January 19, 2000
The Integrated Resource Plan submitted by
Carolina Power & Light to the NC Utilities
Commission contains long-term energy and peak
load forecasts for a 30,000 square mile service
area including the Asheville region, much of
eastern and central North Carolina, and part of
South Carolina. Almost four million people
served by CP&L rely on the company for
electric power. But citizens also require
economical electricity and a clean
environment. In the areas of the
environment and economics the IRP is a failure.
We join with citizens across North Carolina to
demand clean air and reduced reliance on
fossil-fueled and nuclear-powered electricity. At
NC Utility Commission public hearings in
1995, citizens spoke against rising air pollution
levels, the negative impacts of pollution on
children's health, and called for real
reductions in acid rain, ground-level ozone, and
air toxins. In 2000 we repeat these demands and
call for better management of the earth's
resources. We call for an end to delay
tactics which allow utilities to continue to emit
excess pollution into the atmosphere. We
call for energy efficiency and renewable power
sources which will not foul the air and
water. We call for fair and equitable
pricing of electricity with no favors to large
consumers of power.
Environment
The 1999 IRP forecasts a 2.6% annual growth rate
in electricity demand, an increase in 1,760
gigawatt-hours (GWh) per year. By 2013
power generation would increase from 57,624 GWh
to
82,295 GWh, a 43% rise in annual power
generated. The energy growth would come
primarily from fossil-fueled units: 11,348 GWh
from existing coal-fired units and 21,397
GWh from new combustion turbines, fired by
diesel or natural gas. During the same
period hydroelectric output drops both as a
percentage of total power and actual generation
levels from 1151 GWh to 823 GWh per year.
Also, nuclear power output falls 22% from present
levels.
The power generated by fossil-fueled units will
add huge amounts of air pollution to the existing
problems of ozone, acid rain, and the greenhouse
effect. CP&L's seven coal-fired plants
opened in 1949, 1951, 1954, 1956, 1964, 1966, and
1983. The Congressmen who passed the
original Clean Air Act assumed--erroneously--that
most of these plants would not last into the 21st
Century. New combustion turbines are permitted to
burn natural gas and/or diesel fuel. The
decision on which fuel to use is left to the
utility and is based on fuel pricing, not air
quality.
The huge amounts of pollution from
CP&L's seven plants, 300 million pounds/year
of SO2, 175 million pounds of NOx, and 5 million
pounds of PM-10 are already an unbearable burden
on the air quality of North Carolina.
Additional particulates are created by sulfur
dioxide emissions after release into the
atmosphere and create haze which blots out the
mountains in summer. A 43% increase in
annual power production from these ancient
coal-fired units (IRP page 10) should not be
permitted to be the backbone of CP&L's
Integrated Resource Plan for 2013.
The utility presents no explanation for the drop
in hydroelectric power. Existing hydro
would require no additional stream impoundments
to continue operating. This pollution-free
resource should be maintained and expanded where
possible. Hydroelectric power which does
not need huge dams should comprise an expanding
part of the energy supply in a state with
countless waterways.
One of the greatest shortcoming is the failure of
the utility to account for energy efficiency
programs in its forecast. Energy efficiency
measures implemented in the 1970's caused
substantial reductions in need for additional
generating capacity for decades after: a 16%
decrease from 1980 to 1990 (from 1371 GWh to 1150
GWh per year). North Carolina's economy
expanded during those decades. There
is inadequate justification presented by CP&L
for forecasts of 1760 GWh/year of additional
power through 2013.
Special Order by Consent Delays Utility
Compliance
In 1999 CP&L petitioned North Carolina for an
exemption from smokestack opacity regulations and
was granted a consent order which allows a
system-wide suspension of the 20-year old rule
until 2002. Opacity is related to
particulate pollution. The public notice
for the order said, "This order allows the
Company time to evaluate the condition of their
electrostatic precipitators...." But
electrostatic precipitators were first developed
in 1906. They are very effective at
removing fine particles from the air and are in
extensive use throughout the coal-fired electric
utility industry. But non-compliance with
existing regulations and pending Title V
permitting problems prompted CP&L to request
the delay.
Toxic Air Pollution
Toxic pollutants also result from the burning of
thousands of tons of coal. Air toxins are inhaled
by people and deposited on plants, soil, and
water. The EPA Toxics Release Inventory for
CP&L's coal-fired electric generating
stations lists over 32 million pounds of toxic
compounds in 1998, mostly air emissions.
The releases include hydrochloric acid, sulfuric
acid, hydrofluoric acid, barium, manganese,
copper, chromium, zinc, arsenic, nickel, ammonia,
beryllium, chlorine, cobalt, lead, selenium and
mercury. The true health impact of toxic
pollutants will not be calculated because the
industrial boilers are exempt from NC toxic air
pollutant rules.
Fair Pricing v. "Uneconomic
Bypass"
CP&L states in its 1999 IRP that it is better
to retain customers even if a specific customer
demands rates which are below the utility's fixed
costs. It is CP&L's policy to avoid
so-called uneconomic bypass. The
effect of this policy is to shift some of the
financial burden from larger customers to those
with less power to negotiate cheaper rates.
Who are the customers with the clout to force
lower rates? Industry. If this
practice is allowed to continue, large industrial
ratepayers will continue to transfer the true
costs of electric power generation to smaller
residential customers.
The CP&L 1999 Integrated Resource Plan
states: "CP&L currently has retail
customers on self-generation deferral rates and
wholesale customers on long-term contracts.
These rates and contracts have been structured to
avoid uneconomic bypass. Retaining
customers at rates which recover a portion of the
utility's fixed costs keeps rates lower for all
customers than would be the case if the utility
lost the customer entirely. It is the
Company's policy to avoid uneconomic bypass now
and in the future."
The NC Utilities Commission should prohibit this
practice and make fair pricing the rule for all
customers. Fair pricing requires all
customers to share the same cost of electric
power. If this rule was applied to all
utilities, large industrial and commercial
electric customers would find ways to reduce
their power bills. Homeowners have done
this for decades by a variety of methods, for
example, shifting to fluorescent light
bulbs. The higher costs of such
energy-saving appliances is borne entirely by the
homeowner. Fair pricing would require
similar initiatives from industry. The loss
of customers posited by CP&L as the
alternative to below-cost rates would not occur
if the NC Utilities Commission applied the fair
pricing rule to all electric utilities and their
ratepayers.
_______________________________________________
BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
PO Box 88 ~ Glendale Springs, North
Carolina 28629 ~
Phone (336) 982-2691 ~ Fax (336) 982-2954 ~
Email: BREDL@skybest.com
www.bredl.org
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