-2 extending through 1980. 2. Section 301 of S. 253 pertains to stack heights; Supporting Detail: Hawaiian Electric is the principal source of electric energy in one of the highest-cost states in the Nation. A major responsibility of HECO is, accordingly, the task of doing all it can to keep the cost of its essential product as low as possible. While the location of Hawaii is mainly responsible for the high costs which prevail here, the location offers certain unique characteristics upon which we base our argument in support of the Clean Air Act Amendments proposed in the preceding paragraph. Our isolated location makes valid measures to protect air quality which differ markedly from those which are appropriate elsewhere. Our location also creates a totally different set of conditions concerning the disposal of air pollution and, at the same time, reduces the viable alternative solutions to this problem. These facts bear directly on our proposed amendments to the Clean Air Act. Hawaii possesses no viable energy resource -- it is virtually 100% dependent upon imported fuel oil. Because of this, it has long been the practice of Hawaiian Electric to secure unusually long-term (10 years or more) fuel oil con -3 tracts -- our current contracts on Oahu terminate in four years at the end of 1980. Much of the oil under contract (that with a sulfur content greater than 0.58) would be unusable long before the contracts under which it is available terminate unless the proposed Clean Air Act Amendments are further amended as we have proposed earlier. The need to negotiate new contracts and void the existing contracts would add about $24 million per year (for the cost of fuel alone) to the cost of electricity on Oahu for each year that was "lost" from the existing contract. The basic reason for this would be the need to comply with the State Implementation Plan through the use of scarce low sulfur content fuel available only at a price premium instead of the use of fuel oil available under the extremely favorable terms of a contract negotiated long before the energy crisis was generally recognized. Our proposal for delayed compliance is valid for application in Hawaii because of our isolated location, the isolated location on Oahu of the only Generating Station for which a Compliance Date extension is required and the direction of strong trade winds which prevail in force and direction about 85% of the time. This unique circumstance is depicted graphically in the attached diagram, and results in air quality that has not been found to have any adverse effects on health or general welfare. Since a critical air quality condition doesn't exist at Kahe, early compliance gains nothing yet will result in a serious economic burden. Hawaiian Electric maintains continuous surveillance of alternative measures which can be taken to reduce current or future costs while providing compliance with applicable air quality standards. Because we use fuel oil, we have not found 502 scrubber technology for oil burning boilers to be economically viable. Also, we are aware that 502 scrubber technology is rapidly evolving so that new, more efficient methods and combined SO/NO, third generation scrubbers may well be available in the future. To unnecessarily foreclose a potentially attractive future alternative at this time by investiment in an evolving system of scrubbers is not prudent. Our recommendation concerning the tall-stack provision offers the only viable means in our judgment for mitigating the magnitude of the cost increase which will confront rate · payers in Hawaii when our long term contracts either expire or are terminated. For the reasons of isolation and prevailing winds, the height of generating station stacks in Hawaii is unusually short; perhaps only half of what good engineering practice would have dictated elsewhere. The stack height provision included in S. 253, and proposed above for S. 252, would allow HECO to increase its stack heights and thus avoid the necessity of purchasing ultra-low sulfur content fuel when current fuel is no longer available. We have estimated the cost advantage of this to the residents of Oahu to be a minimum of about $4 million per year. Compliance date extension through 1980 and stack heightening to avoid plume down-wash are two provisions which can be included in the amended Clean Air Act at no cost to the Hawaiian environment two provisions that will, at the same time, relieve any person on Oahu of an unnecessary cost burden. WE URGE YOUR SERIOUS CONSIDERATION manians casaidaration of our proposals. The Highway Users Federation is made up of more than 600 businesses and industry groups working together for safe and efficient highway transportation. We have affiliated highway user organizations in every state and 40 major metropolitan areas. Their combined membership totals over 5,500 groups, which in turn represent millions of Americans. We support reasonable and practical efforts to improve air quality and are pleased to note from Council of Environmental Quality reports that substantial improvements already have been achieved. We feel that, in view of present conditions, more emphasis should be given to the energy and economic consequences of clean air requirements. Future regulations should not conflict with national energy and economic goals. We believe it is in the interest of motor vehicle transportation consumers to: * Approve the automobile tailpipe emissions * Clarify and relax the questionable "significant deterioration" provisions in ambient air quality regulations. 1776 Massachusetts Avenue NW Washington DC 20036 (202) 833-5800 |