1. ELECTRICITY RESTRUCTURING ROUNDTABLE
Resolving Dual-Fuel Capability
&
Environmental Permitting Issues
Edward Kunce
Deputy Commissioner
Mass DEP
9 December 2005

2. FROM MASS DEP's PERSPECTIVE
UNCONTROLABLE FACTORS IN CONTINGENCY PLANNING
NATURE
Gulf Coast hurricane damage
Winter 2005/2006
ECONOMICS
Relative costs of gas vs. oil
ISO’s dispatching and bidding processes
Fuel purchasing strategies
INFRASTRUCTURE AND OPERATIONS
Ability to deliver fuel driving “cold snaps”
Facility limitations for fuel oil, e.g. storage capacity
O&M factors with fuel switching
Satisfying demand of other fuel oil users
LAS VEGAS
Differing/Contradictory projections on Fuel Shortfalls “which one you betting on??

3. MANY "SPECIES" OF GAS FIRED
POWER PLANTS
Gas only
Permitted for dual fuel but only use gas
Permitted for dual fuel and use both fuels (primary gas, 30(+)days oil)

4. FRAMEWORK FOR MASS DEP's CONTINGENCY STRATEGY
DUAL FUEL POWER PLANTS
FRAMEWORK FOR MASS DEP's CONTINGENCY STRATEGY
Balance economic and environmental risks
Work within existing regulatory framework as much as possible
Build off historic fuel oil use patterns

5. DUAL FUEL POWER PLANTS UNDER REVIEW
Pittsfield Power MW
Dartmouth Power MW
Mass Power, Springfield 270 MW
NEA Bellingham MW
W Springfield GT MW
Mirant Kendell (*) MW
Total MW
(*) began compliance testing to burn oil Nov. 05

6. FUEL OIL USE AT DUAL FUEL POWER PLANTS
Facility
DAYS ALLOWED
IN PERMIT
MAX USED
LAST 4 YEARS
Pittsfield
55.2
4.6 (8%)
Dartmouth
62.5
19.0 (30%)
Springfield
35.0
4.2 (12%)
Bellingham
30.0
3.0 (10%)
W. Springfield
39.0
N/A

7. MASS DEP's PROPOSED STRATEGY
Meet with dual fuel power plant representatives
Clarify flexibility in existing permits & regs.
Review past fuel oil use
Review infrastructure limitations/issues
Review expected fuel oil use this year
Attempt to get agreements on voluntary “set-aside”
Plan for a number of “cold snap shortfalls”
Facilities “set-aside” some of permitted days for “cold snap shortfalls”
Be prepared for emergency regulations if Items 1&2 aren’t adequate

8. DATA TO SUPPORT "SET-ASIDE" STRATEGY
FACILITY
DAYS
ALLOWED
MAX USED
LAST 4 YEARS
SET-ASIDE
(1)
BALANCE
(2)
Pittsfield
55.2
4.6 (8%)
4.5 (8%)
46.1 (84%)
Dartmouth
62.5
19.0 (30%)
4.5 (7%)
26.3 (7%%)
Springfield
35.0
4.2 (12%)
4.5 (13%)
26.3 (75%)
Bellingham
30.0
3.0 (10%)
4.5 (15%)
22.5 (75%)
W. Springfield
39.0
N/A
4.5 (12%)
Assumes three “cold snaps” during the winter that last an average of three days each and that these cold snaps coincide with NG shortfalls that
would require dual fuel facilities to burn oil or shut down. These facilities would serve as peaking facilities for about 12 hours each “cold snap” day.
(This results in 4.5 days set aside for cold snaps)
“Balance” represents operating flexibility within existing permits for oil use assuming a baseline use established by max use of last four years
plus “cold snap” set-aside.