Tampa Electric Comments to EPA Existing Source Performance 

Standards Hearing in Atlanta, GA (7/30/14) 

My name is Byron Burrows, Manager of Air Programs with Tampa Electric 

Company (TEC). TEC is an investor-owned utility located in West Central 

Florida with over 687,000 residential, commercial and industrial customers 

that depend on us for reliable power and value-added energy services. 

TEC has served our community for over 115 years and currently utilizes a 

balanced fuel mix of coal and natural gas. In 2005, TEC completed the first 

part of a $1.2 billion initiative that reduced carbon dioxide (C02 ) emissions 

by 20% from 1998 levels. By repowering the coal-fired units to a Natural 

Gas Combined Cycle system, 5 million tons of C02 reductions have been 

realized every year since 2005. These reductions were memorialized by 

our participation in a voluntary but legally binding GHG trading program 

from 2003 to 2010 and they are valid reductions. 

The substantial C02 reductions resulted from an agreement with EPA. This 

was the very first agreement in EPA's ongoing NSR enforcement program. 

As a result of this agreement with EPA, TEC and our customers have made 

a substantial investment to make early reductions and EPA's proposal for 

existing sources neglects to account for this bold and early action. If the 

Florida limits outlined in this proposal are finalized in their current form, our 

customers will be paying twice for the same reductions many other 

companies deferred until now. Projects that are part of the billion dollar 

reductions we recently completed are amortized over the remaining life of 

the coal plant (beyond 2030) to minimize the impact to customer's bills and 

this proposal would create stranded assets. The benefits of these 

reductions, 5 million tons of C02 per year, have been realized for each of 

the last ten years. EPA should work with states to adjust the goals relating 

to Block 2 to a level that recognizes this early action, acknowledges the 

importance of fuel diversity, preserves the thousands of jobs at risk, and 

allows existing units to exist and operate within the confines of the Clean 

Air Act 

Instead, EPA's proposal penalizes early action we have already taken with 

respect to Block 1 boiler efficiency improvements. TEC and many other 

utilities have already completed the relevant efficiency improvement 

projects outlined by EPA to get these emission reductions. EPA's goal-
setting exercise for Florida simply assumes a reduction from efficiency 

improvements is plausible without due consideration of whether or not the 

potential measures have already been completed. This would arbitrarily 

reward those who delayed maintenance on power plants until after 2012 

and penalize others. States should be afforded the flexibility to work with 

EPA to adjust the goal if the appropriate efficiency projects that EPA 

assumes are feasible have already been completed or would not achieve 

the reduction that EPA projects. 

Unfortunately EPA's proposal also directly penalizes our customers. In 

addition to paying for the substantial emission reductions described earlier, 

they have been participating in energy efficiency programs TEC has 

incentivized since 1979. Indeed, participation in the programs has been 

diminishing as the energy efficiency opportunities have been depleted in 

the 35 years of this already successful program. Again, the EPA proposal 

penalizes these proactive and forward-thinking customers who are now 

benefitting from a lower power bill because these customers would 

undoubtedly see a substantially higher bill due to the additional costs this 

proposal would bring. EPA should recognize that the decades of early 

action as well as new appliance and building codes are already reducing 

load demand and EPA should work with states to adjust the goal if the 

remaining reductions are found to be too expensive or simply not 

practicable. 

We share the concern of our legal counsel that the rule as proposed does 

not comport with the intent or spirit of the Clean Air Act, which is ill-suited 

for EPA's approach to this rule. We also share the concerns of various 

organizations that we support in evaluating this rule including, Florida 

Electric Power Coordinating Group, Class of 85, and Edison Electric 

Institute. We will join these groups in preparing and submitting written 

comments elaborating on the concerns voiced here today. We desire to 

provide substantive evidence of our observations described above and we 

are actively collaborating with other utilities and organizations in this 

regard. We have participated in previous hearings on this matter, met 

individually with EPA and Florida representatives, and we have participated 

in numerous meetings with our stakeholder groups. It is evident that a 

robust evaluation is warranted, therefore we request an additional 90 days 

to prepare a more complete analysis. 
To summarize, the EPA proposed rule, if implemented as currently drafted, 

would penalize our company and our customers for substantial early action 

taken to reduce C02 emissions. Our low income customers will be 

disproportionately negatively impacted. Our analysis to this point indicates 

that that EPA's proposal pushes each building block beyond practical 

application in our state and region and therefore is devoid of the purported 

flexibility. This can be rectified by accounting for the billion dollar 

repowering and other early action like it in the goal setting formula, allowing 

an appropriate capacity factor for the remaining coal units to properly 

function as existing units, and recognizing our customers' early action in 

implementing substantial energy efficiency measures since 1979. To avoid 

a disproportionate impact to Florida and its citizens, it will require significant 

adjustment to the EPA goals to properly reflect the best system of emission 

reductions as defined in the Clean Air Act We look forward to working with 

EPA and the state of Florida to properly consider these factors during 

development of these standards. Thank you for the opportunity to 

participate in this hearing and submit comments.