In 1969, PP&L's planners established that two new fossilfired units would be required in the mid-1970's, one in 1974, and one in 1975. Continuing high electric load growth coupled with extended delays in obtaining approval for nuclear capacity, mandated that the Company build the fossil-fired units to provide the needed capacity ahead of the planned nuclear units, which could not be placed in service before the late 1970's. Further evaluation established that these fossil-fired units should be located in the eastern portion of the PP&L service area, because of load growth. PP&L's coal plants were primarily base load stations, and the last three new units (coal-fired) were built in the western part of the service area. Locating the new units at the Martins Creek Site had many advantages. was close to the major load centers and would, therefore, reduce the amount of new transmission lines. It would also eliminate It the environmental impact of new transmission lines from a "western" plant to the "eastern" load. Use of the already developed site would conserve land; otherwise, a new site would have been required. Therefore, Martins Creek was chosen as the best location from several alternatives. In 1969, public concern over the environment was increasing rapidly. New Jersey had mandated a very strict regulation which restricted the sulfur content of fuels to as low as 0.3 percent in urban areas and as high as 1 percent in its rural area adjacent to the Martins Creek site. This resulted in conversion of that State's power plants from coal to oil. Pennsylvania's air Federal pollution authorities strongly urged that any new units built after that date be equipped with sulfur removal equipment. standards of 0.7 percent sulfur fuel did not cover these units but did concern PP&L that they might in the future. With this high concern for air quality standards, PP&L opted for oil as the fuel for a plant that would probably have to meet increasingly rigid sulfur standards over its thirty year expected life. The use of coal would have required installation of stack gas scrubbers. They were just not technically available for large units (800 MW) in the time frame needed. For this same reason dual-fuel capability, with coal as one of the fuels, was not acceptable in the face of New Jersey's air pollution standards. The units constructed, therefore, do not have the convertability option. One other major reason for choosing oil was its substantial advantage over a coal-fired plant in operating flexibility and reliability. Oil-fired plants can change load faster, can be removed from service easier, and are, therefore, ideally suited for load following. This particular plant is specifically designed and equipped so that it can operate as an efficient peaking plant. This flexability of operation is a considerable advantage when all of PP&L's other plants (coal-fired), which are more economical to operate, are dispatched as base load plants. Finally, oilfired plants have less auxiliary equipment to maintain than coal plants, operate with higher reliability, and thereby experience inherently higher availability. This is not only an important cost consideration but also minimizes the frequency of system voltage reductions and "brownouts". Because of these considerations, and those explained regarding this site's physical limitations, in 1969 we decided that this needed new capacity should be oil fired. All reevaluations of this decision since then to the present, particularly since 1973, establish that it is not practicable to convert it to coal. In conclusion, for the reasons stated, we earnestly urge that the Committees give consideration to an adjustment in S 1777, to accommodate this Martins Creek plant situation. The decision to build these units was made under a very different regulatory atmosphere than today. Certainly, PP&L would not have made it in late 1973, and would not make it today. However, aside from the obvious changes in the price of oil and coal, we assure you that all of the other relevant reasons, such as economic and environmental impact, flexibility of operation, and reliability, strongly favor the operation of this new capacity. PP&L therefore respectfully requests that the proposed act allow for the continued operation of these new Martins Creek units after January 1, 1980. Thank you for your attention. The Energy Committee of the Portland Chamber of Commerce has reviewed S. 1777, the National Petroleum and Natural Gas Conservation and Coal Substitution Act. We appreciate this opportunity to comment consistent with Chamber policy. While we can appreciate the intent of the bill, we find it is full of shortcomings and must recommend against its passage. We recognize that expanded production and usage of coal in the United States is a very key element in a national energy policy. The country's several hundred billion tons of coal constitutes a very high percentage of our total known fossil fuels. A shift from an overdependence on natural gas and oil to other forms of energy, of which coal is indeed important, is a desirable and necessary long-term element of an energy policy. Unfortunately, this bill is not an economically viable means of accomplishing these purposes. We would like to specifically comment on the following points: 1. Oil and natural gas are used as boiler fuel by industry 2. Much of the oil currently used by electric utilities is residual. Conversion of electrical utilities to coal will displace this use of residual fuel. Because of its high sulfur |