FPL doubled down on a need because it claims fracked methane is “clean”, in its FERC filing of 21 April 2014. FPL says it is “a strong supporter of solar power” even though it didn’t increase its solar capacity from 2010 to 2013 because of the lame baseload capacity excuse. FPL says it knows nothing about Export of Gas, even though Floridian LNG, located next to FPL’s Martin County “Clean Energy” Center right at the end of the Transco-Sabal-FSC pipeline, was approved for LNG export by the U.S. DoE Office Fossil Energy (FE) 14 November 2013, and Crowley Maritime’s Carib Energy was approved for export from Florida by FE 27 July 2011. And FPL says its ratepayers are not paying the costs of the pipeline, even though FPL VP of development and external affairs Pam Rauch argued in pring 29 July 2012 for a “Clean Energy” (fracked methane) Center at Cape Canaveral that was one of several mentioned by the Tampa Times 24 October 2014 as a reason for a new pipeline, and that same Pam Rauch filed PF14-2 with FERC for the Florida Southeast Connection (FSC) pipeline that connects from Sabal Trail to FPL’s “Clean Energy” Center in Martin County, next to Floridian LNG. FPL doesn’t seem to know what’s going on next to it, and maybe not what its own employees are doing. I hope EPA doesn’t consider the questions it filed with FERC the same day answered by this weak tea from FPL.
April 21, 2014
Ms. Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Subject: Southeast Market Pipelines Project
Docket Nos. PF14-1-000, PF14-2-000, and PF14-6-000
Dear Ms. Bose:
Florida Power & Light Company (“FPL”) hereby submits these comments in response to the Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) Notice of Intent to Prepare an Environmental Impact Statement for the Planned Southeast Market Pipelines Project, Request for Comments on Environmental Issues, and Notice of Public Scoping Meetings (“NOI”), issued February 18, 2014 in the captioned dockets. FPL is an anchor shipper on the Sabal Trail Transmission, LLC (“STT”) and Florida Southeast Connection, LLC (“FSC”) projects, subscribing to 400,000 MMcf/d of firm capacity beginning May 1, 2017, increasing to 600,000 MMcf/d of firm capacity on May 1, 2020 (collectively, the STT and FSC projects are referred to as the Southeast Market Pipelines, or the “SMP Project”). FPL strongly supports the SMP Project.
In addition to expressing strong support for the SMP Project, FPL will address herein four issues raised during the Commission’s public scoping meetings held in March 2014 that are specific to FPL. These issues are (1) the need for an additional natural gas pipeline; (2) why solar power alone cannot meet this need; (3) whether FPL will export gas transported on the pipeline; and (4) the cost of the project to FPL customers.
1. Need for New Natural Gas Pipeline
In the past decade or so, FPL has reduced its use of oil to produce electricity by 98 percent – from more than 40 million barrels a year in 2001 to less than 1 million in 2012 – through investments in natural gas-fired power. Currently, FPL uses roughly 1.5 to 2 Bcf of natural gas a day to generate power. Looking across the state, Florida utilities consumed an average of almost 3 billion cubic feet of natural gas per day in 2012 – for a total annual consumption of more than 1 trillion cubic feet of natural gas. Natural gas now comprises 68 percent of the electricity generated in Florida. Yet, unlike other parts of the country like Texas and California that also rely on natural-gas fired generation, Florida has no natural gas storage and almost no in-state gas production. In addition, unlike Texas, California and most other parts of the country, peninsula Florida has only two interstate pipelines, Florida Gas Transmission Company, LLC (“FGT”) and Gulfstream Natural Gas System, LLC (“Gulfstream”) both which are fully or nearly fully subscribed. FPL alone has almost 1.3 Bcf of firm transportation on FGT and almost 700,000 MMcf/d of firm capacity on Gulfstream, or nearly 50 percent of the combined capacity on the two pipelines.
FPL’s investments in fuel-efficient, natural gas-fired power plants are providing clean, reliable power and help keep bills low by saving money for customers on fuel costs. Without increasing Florida’s natural gas pipeline capacity in the near future, there will be insufficient natural gas capacity to meet the growing electricity needs of Floridians, which means more oil would have to be burned. A new pipeline system is the best option to meet the future needs for FPL and its customers, and this critical investment in natural gas infrastructure will provide enormous benefits for all Floridians. For this reason, FPL sought a Florida Public Service Commission (“FPSC”) determination that its decision to subscribe to the SMP Project’s capacity was prudent and in the public interest. On October 28, 2013, the FPSC found that FPL has demonstrated a need for 400 million cubic feet per day of additional firm natural gas transmission capacity by 2017 and that it is eligible to seek cost recovery for through the FPSC’s Fuel Clause for its contracts with STT and FSC. The FPSC’s order is included herein as Attachment 1.
The SMP Project will provide FPL and Florida other benefits in addition to adding new pipeline capacity. The new pipeline system will expand the state’s access to additional sources of natural gas throughout the U.S. This will help reduce the state’s reliance on offshore sources and lessen its vulnerability to fuel supply interruptions that can occur in the Gulf of Mexico region during severe tropical weather. STT’s use of the Transcontinental Gas Pipe Line Company LLC’s (“Transco”) lease also provides a substantial public benefit, as FPL and other STT shippers will have direct access to diverse supplies of natural gas in Transco Zone 4 at Station 85 at the Zone 4 Pool (FPL presently can only directly access Transco’s Zone 4-A Pool via its existing Transco 4-A capacity and must pay a fee to access the Zone 4 Pool). The SMP project will also enhance electric reliability. The Commission in recent years has demonstrated a major interest in electric/gas coordination and ensuring electric reliability given the increased reliance on natural gas. FPL submits that construction of a new pipeline system where electric generators like FPL sign up for long-term firm transportation is the most effective method to ensure reliability. Another key public benefit of the SMP Project is the new Central Florida Hub. Presently, there is extremely limited ability to flow gas between Gulfstream and FGT. The new Central Florida Hub will provide for the full capacity of STT to be delivered into both FGT and Gulfstream and for the same volumes to be delivered between FGT and Gulfstream in central Florida, greatly increasing the reliability of the pipeline system in peninsula Florida in the event of an outage on one of the existing pipelines. Finally, the SMP Project will facilitate gas delivery to some of FPL’s preferred sites for future generation expansion. In FPL’s 2014 Ten Year Site Plan filed with the FPSC on April 1, 2014, See: http://www.psc.state.fl.us/utilities/electricgas/10yrsiteplans.aspx one of the preferred expansion sites is located in Okeechobee County. The intended route for the FSC project comes within three (3) miles of the Okeechobee site, and could be served by construction of a new short lateral off of the FSC project.
2. Solar Power
Various commenters during the scoping meetings stated that solar power can replace the need for new pipeline capacity. FPL is a strong supporter of solar power. FPL operates three utility-scale solar energy centers, Martin Next Generation Clean Energy Center, DeSoto Next Generation Solar Energy Center, and Space Coast Next Generation Solar Energy Center that collectively total more than 100 MW of solar power. In an effort to offer more customers the choice to support solar power, on April 2, 2014 FPL filed with the FPSC a proposal for a voluntary, community-based, solar partnership pilot program. If approved, FPL will install new solar-powered generating facilities in Florida communities, funded by voluntary contributions from FPL customers who choose to participate in the pilot program. FPL’s petition for approval of the pilot program may viewed on the FPSC website at the following address: http://www.psc.state.fl.us/library/FILINGS/14/01477-14/01477-14.pdf
While solar power does constitute an important part of the equation for serving future generation load, however, it cannot provide the same sort of base load generation that natural gas provides in Florida due to climactic conditions, developmental costs, reliability issues, the need for large expanses of land, and the uncertainty of solar power availability at times of system peak demand. As a result of these limitations, solar power cannot be a substitute for the electric generation that will be fueled by the SMP Project.
Numerous comments in the scoping meetings stated that the natural gas transported on the SMP Project will be exported. FPL has no intention to export the natural gas that it transports on the SMP Project. As noted above, the FPSC has already found that FPL has shown a need for the additional pipeline capacity in order to serve its electric load. Even if Florida were to have facilities to export natural gas (it currently does not), FPL has entered into its contracts with the SMP Project in order to deliver the natural gas it needs to generate electricity. Quite simply, FPL is not in the natural gas export business; in fact, FPL does not even have the legal authorization necessary to export natural gas.
Several commenters raised concerns and questions about whether these pipeline projects are currently being funded by FPL customers. The SMP Project is not currently being funded by FPL customers. FPL customers pay for fuel and transportation on their electric bills at actual cost via FPL’s FPSC approved fuel clause. FPL – and its customers — will only begin to pay for the SMP Project when it actually goes into service (projected for 2017); the pipeline projects are responsible for their own financing until then.
In closing, FPL fully supports the SMP Project for the reasons expressed above and urges the Commission to approve it as expeditiously as possible.
/s/ Sam Forrest
Energy Marketing and Trading
Florida Power & Light Company
Florida Power & Light Company
700 Universe Boulevard, Juno Beach, FL 33408
FPL attached a copy of PAA Order PSC-13-0505-PAA-EI on FPL’s proposed Sabal Trail Transmission, LLC and Florida Southeast Connection pipelines; docket to be closed if order becomes final; protest due 11/18/13. See information about possible appeal. Yet when attorney and directly affected landowner Beth Gordon filed a petition to appeal, the Florida PSC dismissed it because she was not an FPL customer, even though Sabal Trail proposed to gouge through her land for FPL’s benefit.
As far as ratepayer costs after the pipeline is constructed (if it ever is), Susan Salisbury wrote for the Palm Beach Post 25 October 2013, State regulators clear way for FPL natural gas pipeline,
The Public Service Commission also approved FPL’s request to charge customers for the fuel and transportation costs beginning in 2017.
Florida Public Counsel J.R. Kelly said FPL customers could pay as much as $15 billion for gas transportation costs alone over the 25 to 40 years after the pipeline goes into service. The commission’s vote amounted to a approval of future costs, he said.
Florida AARP already filed a legal protest all the way to the Florida Supreme Court about the FL PSC’s approval of the previous rate hike for the type of “modernizations” (conversion from coal or oil) that FPL cites in its 21 April 2014 FERC filing as justification for the Sabal Trail pipeline.
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