Tampa Electric Comments to EPA Existing Source Performance Standards Hearing in Atlanta, GA (7/30/14)

My name is Byron Burrows, ManagerofAir Programswith Tampa Electric Company (TEC). TEC is an investor-owned utility located in WestCentral 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 115years and currently utilizes a balanced fuel mix of coal and natural gas. In 2005, TEC completed thefirst part of a $1.2 billion initiativethat reduced carbon dioxide (C02) emissions by 20% from 1998 levels. By repowering the coal-fired unitsto a Natural Gas Combined Cycle system, 5 milliontons ofC02 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 ofthis agreementwith EPA, TEC and our customers have made

a substantial investment to make early reductions and EPA's proposal for existing sources neglectsto accountfor this bold and early action. Ifthe Florida limits outlined in this proposal arefinalized in their currentform, our customers will be paying twice forthe same reductions many other companies deferred until now. Projects that are part ofthe billion dollar reductions we recently completed are amortized overthe remaining life of the coal plant (beyond 2030)to minimizethe impactto customer's bills and this proposal would create stranded assets. The benefits ofthese reductions, 5 million tons ofC02 peryear, have been realized foreach of the lasttenyears. EPA should work with states to adjustthe goals relating to Block 2 to a level that recognizes this early action, acknowledges the importance offuel diversity, preservesthethousands ofjobs at risk, and allows existing unitsto exist and operatewithin the confines ofthe Clean AirAct

Instead, EPA's proposal penalizes early action we have alreadytaken with respectto Block 1 boiler efficiency improvements. TEC and many other utilities have already completed the relevant efficiency improvement projects outlined by EPAto getthese emission reductions. EPA's goal-setting exercisefor Florida simply assumes a reduction from efficiency improvements is plausible without due consideration ofwhether or notthe potential measures have already been completed. This would arbitrarily reward those who delayed maintenance on power plants until after2012 and penalize others. States should be afforded the flexibility to work with EPA to adjust the goal ifthe appropriate efficiency projectsthat EPA
assumes are feasible have already been completed orwould not achieve the reduction that EPA projects.
Unfortunately EPA's proposal also directly penalizes our customers. In addition to paying forthe 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 ofthis 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 dueto the additional costs this proposal would bring. EPA should recognize that the decades ofearly action as well as new appliance and building codes are already reducing load demand and EPA should work with states to adjustthe goal ifthe 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 comportwith the intent orspirit ofthe Clean AirAct, which is ill-suited for EPA's approach to this rule. We also share the concerns ofvarious organizationsthat we support in evaluating this rule including, Florida Electric Power Coordinating Group, Class of85, and Edison Electric Institute. We will join these groups in preparing and submitting written comments elaborating on the concerns voiced heretoday. We desireto provide substantive evidence ofour 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 evidentthat 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 analysisto this point indicates thatthat EPA's proposal pushes each building block beyond practical application in our state and region and therefore is devoid ofthe purported flexibility. This can be rectified by accounting forthe billion dollar repowering and other early action like it in the goal setting formula, allowing

an appropriate capacity factor forthe remaining coal unitsto properly function as existing units, and recognizing our customers' early action in implementing substantial energy efficiency measures since 1979. To avoid

a disproportionate impactto Florida and its citizens, it will require significant adjustmentto the EPA goals to properly reflect the best system ofemission reductions as defined in the Clean AirAct We lookforward to working with EPA and the state of Florida to properly considerthese factors during development ofthese standards. Thank you forthe opportunityto participate in this hearing and submit comments.