7-2500-15532-2

 

STATE OF MINNESOTA

OFFICE OF ADMINISTRATIVE HEARINGS

FOR THE PUBLIC UTILITIES COMMISSION

 

In the Matter of a Petition by Xcel                               SUMMARY OF TESTIMONY

Energy for Approval of a Three-Plant                              AT PUBLIC HEARINGS

Emissions Reduction Proposal and

Rate Rider to Recover Costs.

 

          The above matter came before Administrative Law Judge (ALJ) Richard C. Luis for public hearings in Montevideo on September 2, 2003, in Northeast Minneapolis on September 3, 2003, in Winona on September 8, 2003, in North Mankato on September 9, 2003 and in Stillwater on September 11, 2003.  ALJ Allan W. Klein presided over public hearings in St. Cloud on September 15, 2003, in St. Paul on September 16, 2003 and in North Minneapolis on September 17, 2003.

 

          This Summary of Testimony reports to the Public Utilities Commission (PUC) on the oral testimony offered by speakers at the public hearings listed above.  The Commission will issue an Order on the Emissions Reduction Proposal by Xcel Energy Company (Xcel or the Company) after examination of the Summary, the hearing transcripts, all filings in writing submitted by the public (deadline was September 29, 2003), and all filings and arguments submitted by Xcel, the Minnesota Pollution Control Agency (MPCA) and other interested persons and entities.

 

I.  SUMMARY OF XCEL TESTIMONY

 

Xcel presented its testimony in a consistent manner at all eight public hearings, through prepared testimony read or paraphrased by Ron Elsner, the Company’s Metro Emission Reduction Project (MERP) Manager.  His presentation was supplemented by overhead-projected slides (Xcel Ex’s 1-9).  Mr. Elsner’s presentation highlighted the impacts on ratepayers of the proposed projects, commented on the effect (minimal) the proposal would have on the natural gas supply, and laid out the timetable for implementing the proposal.

The Company’s Allen S. King Plant at Oak Park Heights (near Stillwater) is scheduled first for rehabilitation.  The proposed scope of work includes new pollution control equipment, rebuilding of the existing boiler, replacement of the existing steam turbine, installation of a new digital plant control system and the upgrade of the balance of the plant equipment as necessary to support the new installations.  Xcel projected that the rehabilitated plant will be in service by May, 2007, at an estimated cost of 392 million.  The rehabilitation at King is estimated to result in reductions of 17 thousand tons of nitrous oxide per year, 24 thousand tons per year of sulfur dioxide, 90 tons per year of particulate matter and 15 pounds per year of mercury.  These numbers represent reductions over current emissions of 89 percent, 91 percent, 20 percent, and 20 percent, respectively.

The Company’s High Bridge Plant in St. Paul is proposed for conversion from a coal-fired facility to one powered by natural gas, including the installation of two natural gas combustions turbines and a new steam turbine, all by May, 2008.  The estimated capital cost is 412 million dollars.  Emissions reductions are designed to be 4,400 tons per year (98 percent) from current nitrous oxide emissions, 3,100 tons per year (100 percent reduction) from current sulfur dioxide levels, 100 tons per year (100 percent reduction) from current levels of particulate matter and removal of 66 pounds per year of mercury (a 100 percent reduction from current levels).

A partial conversion of the Riverside Plant in Minneapolis is proposed to be completed in May, 2009 at a cost of 240 million dollars.  This repowering, from coal to natural gas, will not result in a replacement of a steam turbine, so the total cost is less than at the other sites.  The resultant reductions in emissions include an estimated 13 thousand tons per year of nitrous oxide (99 percent off current levels), 12 thousand tons per year of sulfur dioxide (a 100 percent reduction), 540 tons per year of particulate matter (a 100 percent drop) and 98 pounds per year of mercury (a 100 percent reduction).

The total price for the proposal is just over 1 billion dollars, which Xcel proposes to recover over 30 years beginning in the year 2006.  The proposed rate increase will vary over time, increasing from 2006 to 2010 and declining thereafter.  The project is expected to increase retail electric rates by approximately 11 or 12 percent (gross).

The Company is advancing the proposal because of the significant environmental benefits offered by the conversions to natural gas.  The proposal also allows Xcel to maintain a diversity of fuel supply, and increases the Company’s total capacity by approximately 400 MW.

II.  SUMMARY OF MPCA PRESENTATIONS

Deputy Commissioner Ann Seha, Staff Engineer Ann Jackson and Section Manager David Thornton made consistent presentations on behalf of the Agency, which filed comments and studies earlier pursuant to its charge from the legislature to review the proposed pollution controls to ensure that they meet pollution reduction requirements, to verify the emission reductions to be expected from the project, to review the costs of the proposal, to estimate the health and environmental benefits of the proposal and to advise the MPUC as to whether the project is appropriate.

Based on its study, the MPCA recommends that the PUC approve the proposal outlined at the public hearings, to convert two of the plants from coal burning to natural gas burning facilities and to upgrade the pollution controls at the King Plant.  The MPCA found that this proposal would achieve large reductions of many key pollutants, install the best control technology at all three plants, and would be cost-effective.

The MPCA presentation stressed some of the legislative history, chiefly the concern on the part of the legislature that 60 percent of the state’s power is still generated in plants that are exempt from the regulations under the Federal Clean Air Act.  As a result, the legislature crafted incentives to energy companies to control their emissions from plants that would otherwise be exempt from the Clean Air Act standards.  This proposal by Xcel is the first to proceed since passage of the new law.  The MPCA has concluded that the project proposed by Xcel appropriately achieves environmental benefits without any unreasonable costs to customers, which is in line with the intent of the legislature.  The Agency notes that the controls that Xcel is proposing to install are the best available control technology for the pollutants that they are dealing with.

The MPCA found that the proposed costs for the projects were reasonable, and that the benefits are large, if the projects are approved.  The largest benefit is the removal of such a large amount of fine particles from the air, which particles have been found to be causing an increasing number of health problems.  The MPCA stresses also that a substantial reduction of sulfur dioxide emissions should result in decreased acid rain.  Significant reductions in mercury emissions are also a benefit, as mercury has been shown to be extremely hazardous to fish life and can cause health problems in humans who consume contaminated fish.  The projects are also expected to result in a significant reduction in haze in the metropolitan area, which will improve visibility.  Also, the proposed refurbishing of a 1000 MW of the power grid for longer life and longer use and the addition of almost 400 MW of available power will have a benefit because the Company will not have to build new electric transmission lines or energy facilities to add an equal amount of power to its grid.

At each hearing, the MPCA distributed a document entitled “MPCA Review of MERP Projects”, which summarizes the studies done by the Agency pursuant to the authorizing legislation.

III.  PUBLIC TESTIMONY IN MONTEVIDEO

The public hearing at the Chippewa County Courthouse in Montevideo on September 2 was attended by approximately eight members of the general public, three of whom offered comments.  MPUC Chair LeRoy Koppendrayer attended the hearing on behalf of the Commission.  Also present were representatives of the MPUC Staff, the Department of Commerce (DOC) and the Office of the Attorney General (OAG).  The commentators, Leo Kuehl, Ralph Anderson and Darrold Boettcher, all spoke against the Metropolitan Emissions Reduction Project.

The basic concerns for the commentators were the cost of the project and the rate increases that would result (for both electricity and natural gas), the potential for jeopardizing the Nation’s natural gas supply and whether sufficient research had been done to clean up the coal burning processes.  Mr. Anderson proposed that the entities that are providing energy through wind power generation technologies be responsible for providing turbines to generate power during the times when the wind is down.  He and Mr. Boettcher emphasized the need to apply best available technologies to the current processes at the Company’s existing plants before engaging in such costly conversions as those proposed in the MERP Plan.  Mr. Kuehl suggested that new energy needs in Minnesota should possibly be met by nuclear power plants.  Marya White, representing the Department of Commerce (DOC), rebutted some of the arguments made by the public commentators.

IV.  PUBLIC TESTIMONY IN NORTHEAST MINNEAPOLIS

Approximately 80 people attended the public hearing at the Northeast Minneapolis Armory on September 3.  Twenty-six people offered oral (and some written) commentary for the record at this hearing, which was attended by PUC Commissioner Gregory Scott.  The comments, most of them brief, were overwhelmingly in favor of adoption of Xcel’s plan.  The top reason given for support was that under the plan, significant amounts of pollution would be removed from the air.  Among the speakers voicing support for Xcel’s endeavor were State Representative Phyllis Kahn and Minneapolis City Councilmen Paul Ostrow (the Council Chair) and Don Samuels.

            Representative Kahn noted that the Legislature is concerned about emissions from coal plants, particularly carbon dioxide that causes global warming, nitrogen oxides and sulfur dioxide that cause ground-level ozone, sulfur oxide that causes acid rain, mercury that contaminates fish and damages the brains of children who eat the fish, and fine particles of coal that cause asthma, lung disease and heart attacks.  These effects also drive up health costs.  Chairman Ostrow noted the City Council passed a unanimous resolution in support of the MERP Proposal and Councilman Samuels likened the Riverside Plant to “one shared giant unfiltered cigarette that the City of Minneapolis puffs on every day.”

Xcel’s Riverside Plant, located in Northeast Minneapolis a short distance away from the site of the hearing, deposits one-third of its emissions in Hennepin County.  This is among the facts offered by witness Carl Nelson, who wrote his Master’s Thesis on the topic of the “Public Health Effect of Converting the Riverside Coal Plant to Natural Gas”, and offered it for the record (Northeast Minneapolis Public Exhibit 3).

A significant number of speakers represented distinct neighborhood associations from various areas in the City of Minneapolis, and all spoke in favor of Xcel’s effort.  Neighborhood associations/groups represented included:  Bottineau, Como, Windom Park, Camden and Corcoran.  Other organizations included an umbrella group (the Mississippi Corridor Neighborhood Coalition), the Sierra Club and an organization called Clean Energy Now.  Many asserted that they were willing to pay even more than the rate increase proposed in the plan if it means cleaning up the air and water.  Some of the speakers touched on specific or single benefits that would result if the MERP Plan is adopted, chiefly reductions in carbon monoxide, sulfur dioxide, nitrogen oxide and mercury, and other health-related improvements.  A number of the speakers who live in close proximity to the Riverside Plant testified to the asthma and heart conditions suffered by themselves, loved ones and others because of the polluted air, and to the dietary restrictions imposed on eating locally-caught fish because of the dangerous concentrations of mercury.

Randy Kouri of the Mississippi Corridor Neighborhood Coalition endorsed the conversion to natural gas at the Riverside Plant and added that conversion to gas is helping clear the air in other segments of our infrastructure, such as the gas furnaces being installed in new housing.  He cited the increase in asthma cases and school absenteeism in Minneapolis.  He believes it is a “no brainer” to convert the Riverside Plant to gas and then to start looking at the future of wind power to supply more clean energy.  Sean Gosiewski stressed the benefit of cutting down the amount of carbon dioxide being placed in the atmosphere that would result from converting power plants from coal-burning to natural gas usage.  He is worried about global warming, which has resulted in a two-to-four degree temperature increase around the world so far, and all the negative consequences if this effect continues (natural disasters such as fires and tropical storms).  Wally Kammeier said that doubters who are concerned about the increased rates resulting from implementation of the MERP Proposal are misplaced in their concern, because energy in this part of the country is significantly less costly than elsewhere in the United States anyway.

Suzanne Maeder pointed out that the plants slated for conversion under the MERP Proposal were exempt initially from the requirements of the Clean Air Act because it was assumed that they soon would be replaced, which has not happened in the 30 years since enactment of the federal legislation.  She applauds Xcel’s effort to do something about it.  Several witnesses who are athletically inclined and engage in distance running, bicycling and basketball within the City of Minneapolis complained that they are suffering now from asthma and shortness of breath, which they attribute to fumes from the Riverside Plant.

          Jeff Conrod pointed out that a conversion of the Riverside Plant to natural gas would eliminate the transportation of coal to fuel the boilers there, and that a pleasant side effect would be that diesel emissions from the diesel trains that bring the coal in and the diesel trucks that haul the ash away would also be eliminated.  Amy Luesebrink testified that her group, Clean Energy Now, advocated in a series of meetings that began years ago some of the very points that ended up in Xcel’s plan.  These goals include a conversion to natural gas at the Riverside and High Bridge Plants, the installation of additional pollution control equipment at the King Plant, and to accomplish the cleanup at the lowest possible cost without an undue burden to small residential customers.  One of Clean Energy Now’s central points has not been achieved under the MERP Proposal, according to Ms. Luesebrink – to set a priority order to convert the plants to natural gas reflecting the highest benefit to the largest population in the shortest time.  She is disappointed that the plan calls for completion of the work at the Allen S. King Plant first.

          Frances Guminga testified in an effort to put a “human face” on the statistics and data in the record.  She related that her older brother died of heart disease, from which he suffered for 20 years, after living for 30 years in the shadow of the Riverside Plant.  She believes that the effects of the plant’s pollution on his heart and lungs contributed to a premature death.  She also expressed concern for her 89-year old mother, who is unable to go outside on many days due to the excessive pollution in Northeast Minneapolis.  Louise Olsen of Northeast Minneapolis, a member of the Mississippi Corridor Neighborhood Coalition, wants action taken to clean up the Riverside Plant as soon as possible because she has a difficult time breathing now and has to spend thousands of dollars per year to buy inhalers to help her asthma.

Many speakers wondered aloud about why the conversion of Riverside was not first on the agenda/timetable proposed by the Company, and why it has taken so long to propose the cleanup of the air and water involved in the MERP proposal.  Several proposed a speeding up of the entire timetable involved in the plan, including one person who advocated finishing the work at all three plants by 2006.

Witness Justin Eibenholzl of the Clean Energy Now Coalition pointed out that the City of Minneapolis has found in a study that there were eight premature deaths, 15 new cases of adult chronic bronchitis, 102 cases of child acute bronchitis, 4 hospital admissions from respiratory causes, 84 emergency room visits, 1,180 asthma attack days, 17,100 restricted days of activity, and 44,300 respiratory symptom days attributable directly to the Riverside Power Plant.  His testimony did not reveal the time period over which the numbers were aggregated.

Jonathan Bishop, of the Sierra Club and “Newer Technology for Mercury Removal”, suggested that Xcel consider installing an experimental powder designed to remove mercury by means of an ion exchange at the Allen S. King Plant.  One company involved in developing this technology is called Enviroscrub.  Mr. Elsner of Xcel replied that Enviroscrub’s process is still a developing technology, whereas the Company has decided, for purposes of its MERP Plan, to rely on technologies that have proven to be reliable over time.

V.  PUBLIC TESTIMONY IN WINONA

The public hearing at the Winona County Courthouse on September 8, 2003, attracted approximately 30 members of the public, of whom 10 offered oral testimony.  PUC Commissioner Phyllis A. Reha attended the proceeding.  Also present were representatives of the PUC staff, the Department of Commerce and the Office of the Attorney General (OAG).

Commentary on the Company’s MERP Proposal was mixed--most speakers favored it, for various and qualified reasons, but some dissented. 

Vic Ormsby, a Winona County Soil and Water Conservation Supervisor, spoke in favor of MERP on behalf of Bluffland Environment Watch, the Prairie Island Coalition and the Downriver Alliance.  Speaking in his individual capacity, Mr. Ormsby urged caution because of our dwindling supplies of natural gas and society’s tendency to be excessive in the consumption of energy.  He noted that 17% of the natural gas consumption in the United States is for the production of electricity.  He urges more promotion of conservation by utility companies and more localized production of energy, with less reliance on large, centralized plants.

Cheryl Gonia, representing the Sierra Club and the National Audubon Society, while supporting Xcel’s initiative, questioned whether development of additional wind generation might be a better long-term solution of the clean air issue.  Joe Morse of the Downriver Alliance (representing conservation organizations in both Minnesota and Wisconsin between Red Wing and LaCrosse) supports the MERP plan but urged also an emphasis on more efficient generation of energy, and increased reliance on wind, biomass and solar power.  He also noted that the refurbished plants, under the MERP Plan, would go out of service in 2034, at the same time the second license period expired at the Prairie Island nuclear site, which accents further the need to increase our reliance on renewable energy sources.

Les Boelter, CEO of Boelter Industries, Inc., which manufactures paper board in Winona and Wabasha, cautioned that a 6-8% rise in (net) electric rates may be too much for some industries to absorb, which could have an adverse economic effect if such companies had to shut down.

Another Winona witness questioned why the Riverside Plant conversion to natural gas should not be completed first, as it would result in the greatest percentage of relative emissions reductions.  Brad Peterson, owner of a welding supply distribution company in Winona and an Xcel shareholder, is concerned about the rate increases that will result from the proposal, and whether the projections factor in the volatility of natural gas supply prices, whether the new capital investments will be cost-effective, and whether the MPUC has considered the nuclear option as a source of clean energy.  A representative of Bay State Milling Company in Winona also was apprehensive about the rate increases that would result if the MERP Plan is enacted by the Commission.  The increase would jeopardize his company’s present ability to make a bread product in Winona and ship it to the east coast for less total cost than the cost of manufacturing the same product in the East.

VI.  PUBLIC TESTIMONY IN NORTH MANKATO

Approximately 50 people attended the proceedings on September 9 at the Community Room in the North Mankato Police Annex Building.  Fifteen of those present offered oral comments.  PUC Commissioner Marshall Johnson and representatives of the MPUC staff, the DOC and the OAG all attended and provided occasional commentary and clarification.  Commissioner Johnson reminded all in attendance of an all-day technical conference set for the following day (September 10) at the MPUC offices in St. Paul on the future of natural gas supplies and prices in Minnesota.

Kathleen Schuler of the Institute for Agricultural and Trade Policy spoke in favor of the MERP Plan, especially with respect to its efforts to reduce mercury levels.  She pointed out that 40% of Minnesota’s mercury emissions come from coal-fired power plants.  She also stressed other socio-economic benefits of reducing pollutants, such as fewer sick days for school children and less jeopardy for childrens’ intellectual capacities.

Tom Marks, a legislative candidate for the Green Party, cautions the MPUC that approval of the MERP Plan would perpetuate our reliance on fossil fuels.  He urges consideration of requiring more utilization of wind and solar power.  Blue Earth County Commissioner Katy Wortel spoke in support of the MERP proposal because it will make it safer to consume fish caught in Minnesota (less mercury) and because she believes the benefits derived from a clean environment outweigh the capital costs ratepayers would incur.  She also advocated a surcharge on polluters for the medical costs they cause.

Elizabeth Sedgwick, a student at Minnesota State University-Mankato, spoke against the proposal because of the cost of conversion and the continuing high price of natural gas, which is a non-regulated commodity.  She cautions that the United States may face a shortage of natural gas in the future, and that gas turbines are less reliable than those fired by coal.  Sister Gladys Schmitz, from Good Counsel in Mankato, supports Xcel’s proposal because it should result in fewer heart and lung problems in Minnesota, less acid rain and a retardation of global warming.

Dr. Barbara Carson, a Sociology Professor at Minnesota State University-Mankato, supports the proposal primarily because of the reduction in acid rain that would result.  She was educated in New England, and observed there the effects of acid rain caused by Midwest Power Plants, which she hopes reforms like those proposed by Xcel will curtail.  Robert Mehltretter cautioned the Commission not to be a “rubber stamp for rate increases,” and added that natural gas prices will be going nowhere but up.  He suggests also considering tying utility rate increases to the Consumer Price Index. 

Another witness supported the notion that the conversion at Riverside come first, with retrofitting at the King Plant last.  Vincent Chavez of the DOC implied that his agency will be submitting an Information Request to Xcel to determine what, if any, money would be saved by juggling the order of retrofitting for the plants involved in the MERP proposal.

VII.  PUBLIC TESTIMONY IN STILLWATER

Approximately 75 members of the general public attended the proceeding on September 11 at the Washington County Government Center in Stillwater.  Twenty-four of them offered comments.  PUC Commissioner Phyllis Reha and representatives of the MPUC staff, the Department of Commerce and the Office of the Attorney General also attended and offered clarification and comments.

          Much of the testimony at Stillwater was specific to the nearby Allen S. King Plant, but some speakers addressed the MERP Plan in general, offering support and making requests.  A few speakers dissented.

          State Representative Rebecca Otto favors adoption of Xcel’s proposal.  Her particular concern is the level of mercury in fish caught in Washington County.  She urges the MPUC to authorize increased filtration of mercury at the King Plant, as well as filtering of oxides as proposed by the Company.

          Former State Senator Jane Krentz, a past chair of the Senate Environmental and Natural Resources Committee, further emphasized the need to filer out more mercury.  She cited a plant in Iowa where mercury reduction was mandated to drop 83%, and questioned why this could not be ordered for the King Plant.  Senator Krentz argued that such a reduction is possible if Xcel added an activated carbon absorption system to the technologies already proposed for the retrofit.  The Company replied that carbon injection technology was not yet a proven technology, and it was not something they were prepared to try for another four to five years.  Mr. Elsner emphasized that current controls at the plant already took out a great deal of mercury and particulates, and the Company’s proposal, which will cut another 20 percent from current levels, represented application of best available proven technology.

          Don Dame, a retired Mechanical Engineer, urged the MPUC to continue to allow the burning of coal before converting the plants in question to natural gas.  He feels natural gas prices are and will be prohibitively high, approximately 400% over that of coal.  Mr. Dame cites for authority the recently-expressed concerns by Federal Reserve Chair Allan Greenspan on the rising prices of natural gas.

          Scott Bol lives near the King Plant in Oak Park Heights.  He favors the MERP Proposal.  Mr. Bol is concerned by the effect of pollutants from the plant on his children, particularly the potential for asthma and the restrictions on eating local fish.  Barbara Prindle, on behalf of the Minnesota Conservation Federation and the National Wildlife Federation, spoke in favor of the MERP proposal, despite its cost, because of the benefit to be derived from reductions in the mercury levels.  She offered a variety of data to support her position.

          Leah Foushee, representing the North American Water Office and the Indigenous Womens’ Mercury Investigation, took the position that the destruction of wildlife caused by power plant emissions, especially from mercury, amounted to genocide of the people whose ancestors were the original caretakers of the land.  She fears also that many of Minnesota’s Southeast Asian population will become ill from overeating freshwater fish that they catch because they cannot relate to written warnings about mercury levels.  For such people, who eat large quantities of fish contaminated by mercury, the only prevention is to stop the introduction of mercury.

          Many of the persons testifying in favor of MERP in Stillwater allege they are happy to pay increased rates for electricity if they can get cleaner emissions.  A number of them complained that the dust blowing off the piles of coal at the King Plant settles on their property and fouls the air in the vicinity.  Others were concerned that the plan calls for only a 20% reduction in the emission of particulate matter (see Xcel’s reply to Jane Krentz, above).  Some questioned Xcel’s officials on the type of fuel to be used in the plant after the conversion – that is, can they find/use coal that is even cleaner?

          Festus Tierney, a retired Xcel employee, opposes the conversions to natural gas because he believes the plants run efficiently on coal, as they were designed to.  Mayor David Beaudet of Oak Park Heights supports the Company’s plan to retrofit the King Plant to cut mercury levels, but expressed concern over the proliferation of coal dust in his city from wind blowing on the piles outside the plant.  Another concern for the community is that the approximately $141,000,000 proposed for renovating the boiler not be exempt from local property taxes.  Larry Sullivan spoke against the MERP Plan because Xcel cannot do it economically without exploring for its own natural gas supply to keep costs down.  If Xcel does not do this, increased gas prices will threaten the financial integrity of the Company.

          Paula Maccabee of the Sierra Club offered the comment that closed-coal storage at the King Plant site would alleviate the problems local residents have with coal dust.  Her suggestion was supported by Bill Metcalf, who also questions why Xcel has no signage to warn fishers that their catch is contaminated by mercury.  Sandy Metcalf wondered if the renovated plant would be more noisy than the current operation (the Company replied that it would not).  Russ Adams of the Alliance for Metropolitan Stability stressed the need to act soon, given that the Twin Cities is experiencing an increased number of Air Quality Warnings that are mostly due to particulates in the air caused by increased ozone levels.  Regional population growth has resulted in more automobile usage, which also pollutes the air.  Adams pointed out that another million residents are expected in the seven counties by 2030.  Rachel Harold of “Clean the Air” also supported adoption of Xcel’s plan, urging the MPUC to demand even greater reduction in the emissions of mercury.

VIII.  PUBLIC TESTIMONY IN ST. CLOUD

          Approximately 18 members of the public appeared in St. Cloud, 14 of whom spoke.  Of those 14, seven were clearly in favor of the proposal, four were clearly against it, and three were uncertain. PUC Chairman Leroy Koppendrayer and representatives of the PUC staff, the DOC and the OAG all attended.

          The seven persons who spoke in favor of the proposal echoed many of the statements discussed in Northeast Minneapolis.  The Minnesota Children’s Health Environmental Coalition outlined the impact of coal burning on children’s health, and the intangible (and tangible) savings that will occur if the project goes forward.  Decreased school absences due to asthma, the costs of medical and emergency room visits, and better academic performance if mercury is reduced, were all mentioned.  Special education costs and lost work time by parents were also cited.

          A Professor of Resource and Environmental Economics at St. John’s University and the College of St. Benedict pointed out that MERP will internalize some of the external costs imposed by the three plants and would bring the price of electricity closer to its true societal cost.  He stated that MERP would be better than what he called “son of MERP,” the alternative that would have all three plants continue to burn coal.  He believed that the higher levels of mercury and carbon dioxide that would be produced by the alternative would be unaccounted for and consumers would continue to receive a false price signal about the true costs of their consumption.

          Another speaker stressed that external costs from pollution are undeniably real costs that are imposed upon society, although very difficult to measure.  He pointed out that the cities of Minneapolis and St. Paul have spent many taxpayer dollars to “reclaim” their riverfronts, and develop them into business and residential centers.  MERP will result in the elimination of coal and ash hauling trains, thereby reducing noise levels and traffic delays.  Coal storage areas will be eliminated.  Tall stacks can be reduced.  Coal and ash dust can be reduced dramatically.  Finally, he stated that we cannot forget our global responsibilities, and our responsibilities to future generations.  We must consider global warming, and find alternatives to fossil fuels.  Natural gas is the best kind of backup power generation for wind power.  It can be turned on quickly, and turned off quickly.

          John Hilton, from Gold’n Plump Poultry spoke in opposition to the MERP Proposal.  Gold’n Plump currently purchases roughly 1.7 million dollars worth of electricity annually from Xcel, and the proposed rate increase could add as much as $136,000.  Gold’n Plump must compete with producers in Arkansas, North and South Carolina, Georgia, and Alabama.  All of these competitors have warmer climates and do not need to spend much on energy.  They also have significantly lower labor rates.  The increase proposed by Xcel would severely hamper Gold’n Plump’s ability to compete, and it is likely that jobs would be lost, business expansion would be curtailed, community contributions would be cut, and local purchases would be reduced.  Gold’n Plump believes that the costs of any changes should be borne by Xcel, and not its customers.  He wondered whether, from a cost-benefit standpoint, it would be better to upgrade emission technology, rather than convert to natural gas.

          Another commentator noted that approximately a week earlier, there had been an air pollution advisory warning, which affected not only the metro area, but also St. Cloud and Duluth.  Minnesota’s air is no longer pure, and the Commission should adopt MERP in order to improve not only air quality but also to lower mercury emissions.

          A spokesman for the Minnesota Interfaith Global Climate Change Campaign, part of a national group including the US Catholic Conference, the National Council of Churches of Christ, the Coalition on Environment and Jewish Life, and the Evangelical Network spoke in support of the primary proposal.  The purpose of his group is to bring a religious and moral perspective to the debates on global warming and energy policy, and to increase the visibility of the broad support within major American faith communities for governmental actions to reduce carbon dioxide and other greenhouse gases.  He pointed out that the primary MERP proposal would reduce carbon dioxide emissions by over a million tons, but that the alternative proposal would actually increase carbon dioxide emissions by 444,000 tons.  If the primary proposal were adopted, it would be the equivalent of removing 250,000 cars from the roads, or the equivalent of building 460 new wind turbines.  Adopting the MERP proposal is the most important thing that Minnesota can do at the present moment to join other states that are trying to deal with global warming.  Global warming will have a definite impact on Minnesota’s climate, and will result in a variety of changes to Minnesota’s environment.  Our agricultural industry will be affected by a loss of crop moisture, leading to a very substantial loss in agricultural production.  Insects and diseases that we can control now will be replaced by those that we may not be able to control.  Boreal forests may be replaced by scrub savannahs.  Hans Blix, who was the Chief United Nations Weapons Inspector in Iraq, said that he was more worried about global warming than about any major military conflict in the world.

          Another speaker noted that the primary MERP proposal would reduce mercury emissions by 191 pounds a year, but the alternative MERP proposal would only reduce these emissions by 14 pounds a year.

          Concerns were voiced over the adequacy and reliability of supplies of natural gas, particularly into the future.  Will there be enough of it, and at what price?  An alternative to natural gas would be coal coking, which would have the side benefit of producing a variety of additional chemicals that could be used for other purposes.  Xcel responded that a coal gasification plant requires roughly 500 acres, whereas the spaces around the High Bridge and Riverside plants are much smaller – about 40 to 50 acres apiece.

          A number of commentators commended Xcel Energy for the proposal.  But some of them went on to say that the Commission must be vigilant to assure that the costs of this project are not unfairly imposed on residential customers.

          At least two customers in St. Cloud stated that natural gas is really not a good long-term solution.  Rather, it must be viewed as just a temporary band-aid solution as we transition toward other fuels.

          A representative of Clean Water Action Alliance focused on mercury, pointing out that the Center for Disease Control has recently stated that roughly 10% of women of childbearing age already have so much mercury in their blood that if they became pregnant, it would pose a threat to a developing fetus.  She went on to say that the Minnesota Department of Natural Resources and the Department of Health are now advising women of childbearing years who are considering having a child to follow the pregnancy consumption guidelines for fish for two years prior to having a child.  She thought that the substantial reduction in mercury that would come with Xcel’s primary proposal is well worth any cost.  This prompted another commentator to ask what portion of the cost of this project was going to be borne by investors, rather than ratepayers.  She wanted to be sure that the consumers would not be paying so that investors could make a big profit.

          Another commentator was opposed to the use of natural gas.  He admitted it had many environmental benefits, but thought that we would be better off building a modern, well-scrubbed coal plant rather than converting coal plants to natural gas.

IX.  PUBLIC TESTIMONY IN ST. PAUL

          Approximately 50 members of the public appeared in St. Paul, and 31 testified.  Of those, 22 favored the MERP primary proposal, three opposed it, and six expressed concerns without indicating a clear position either for or against. PUC Commissioner Marshall Johnson and representatives of the PUC staff, the DOC and the OAG all attended

          One of the first speakers had a copy of the July 21, 2003 issue of Time magazine, and paraphrased from the article that said we were wasting natural gas when we used it to burn electricity, and that we are running out of it, at least running out of it at reasonable prices.  He advocated the use of waste wood, which is being done on a large scale at the District Energy Heating Plant in St. Paul, which generates 25 megawatts of electrical energy and 70 megawatts of thermal energy for district heating and cooling by burning 280 thousand tons of waste wood.  The speaker noted that more than 600 thousand tons of waste wood are generated in the metro area annually, causing storage and disposal problems.  He thought the Commission ought to direct Xcel to consider using waste wood for approximately 30 megawatts of power.

          Dave Thune lives just a few blocks from the High Bridge Plant and he owns and manages commercial property within one mile of the plant.  He urged the Commission to direct that the conversion to natural gas take place as fast as possible, indicating that both as a homeowner and as a businessman, he would gladly pay the price because of the dramatic improvement in the quality of life both in St. Paul and around the plant.

          Another commentator indicated that she had recently signed up for Xcel’s Windsource program, and urged others to do so.  She attempted to place $1500 in cash into the hearing record to indicate her commitment to clean air.  The cash was returned to her, but her commitment is noted here.

          St. Paul Mayor Randy Kelly wrote in favor of the program, so long as  there was “diligent fiscal review” to assure that rates remained affordable.

          The St. Paul Riverfront Corporation urged that the plan be adopted, because it would cut train traffic in the area, cut coal dust emissions, and significantly cut emissions from the stacks.  All of these would be benefits for the city’s riverfront.

          Another commentator urged the Commission to remember the problems of global warming, and the large amount of greenhouse gasses produced by coal burning power plants.  She was opposed to the alternative all-coal proposal because it would increase carbon dioxide emissions and perpetuate Minnesota’s reliance on coal.

          An Xcel shareholder commended the Company for proposing this plan, but urged that the Commission look carefully at Xcel’s past budgets because he believed that Xcel had already established reserve accounts for these types of renovations.  He thought it was only natural for the Company to try to get the ratepayers to pay additional monies for this, rather than for the Company to spend the money it had budgeted for it, but he opposed that.  Finally, he also thought that a 30 year time table was unrealistic.  It appears that he was thinking that the construction itself was going to take 30 years.

          A resident on the south side of the river (in St. Paul, this area is referred to as the West Side) testified about a day, a couple of years ago, when there was a large amount of black soot in the snow.  One of her neighbors indicated that she recalled that day as well.  Both urged that the plan proceed as quickly as possible to avoid any more days like that.

          A representative of EnviroScrub, (a process that was discussed earlier), appeared at St. Paul as well to suggest that the Company’s technology ought to be considered for the King Plant, as well as for the other two plants.  Xcel responded that it has reviewed that technology, along with numerous others, but determined that the technology had not proven itself enough to justify its use at this time.  A representative of Clean Water Action noted that the EnviroScrub process did not claim to reduce carbon dioxide emissions, nor did it reduce the impacts of strip-mining coal.

          Representative Carlos Mariani, whose district includes not only the High Bridge Plant itself, but also neighborhoods on all sides of it, stated that the primary MERP proposal was exactly the kind of outcome that many legislators had hoped for when they adopted the enabling legislation.  He supported the primary proposal, and opposed alternative ideas that relied on continual use of coal.  He also commended Xcel for its efforts to be a good neighbor and improve the area around the plant.

          A small business owner, who employs 30 people, complained about the definition of “industrial.”  His calculations showed that he was going to have to pay 60 times the increase that a residential ratepayer would have to pay, and stated that his company just could not afford it.  He argued that not all businesses are big business, and not all industries big industry; small businesses should get better treatment.

          Another opponent of the plan, who has been an Xcel stockholder for many years, thought that the proposed plan gave Xcel too much freedom to spend any amount of money, and that the Commission must pin down the amount that Xcel is going to spend in order to protect ratepayers.  He favored putting additional scrubbers on the plants, rather than converting to natural gas, but regardless of what plan is adopted, he thought the Commission had to control how much money was spent.

          A number of speakers talked about the qualitative benefits of the primary proposal being hard to measure.  One speaker cited a study done by the Minnesota Project, which indicated that 1.2 billion dollars worth of health costs would be saved if the primary MERP proposal were adopted.  She also pointed out that Minnesota gets 75% of its electricity from coal, which is 50% more than the United States as a whole.  She  thought that it was unfortunate in light of the health, smog, acid rain, greenhouse gas, mercury, and strip-mining impacts of coal burning.

          The executive director of the Environment and Energy Resource Center urged that natural gas be reserved for space heating of homes, and not wasted on electricity generation.  He characterized the use of natural gas for electricity generation as inefficient and shortsighted compared to the use of coal.  He also asked whether the 1.2 billion dollar figure was just benefits that accrued to Minnesota, or whether it included benefits that accrued to Chicago and points downwind of Minnesota.

          A retired professor from Hamline University spoke about intergenerational justice – the idea that political decision makers of today must “bite the bullet” and prevent degradation of the environment that will adversely affect later generations.

          Another commentator focused on mercury, pointing out that it is a global problem and that anything that Minnesota plants can do to reduce their emissions is “almost irrelevant” because the emissions from Minnesota are tiny compared with the global burden of mercury.  Furthermore, if we really want to improve the health of Minnesotans, we should put our money into cleaner power generation in the states to the west of us, such as North Dakota and Montana, because it is their pollution that most affects us.  Converting from coal to natural gas presents a great risk for Minnesota because of natural gas availability and price.  He felt that the assumption that gas is gong to be there at a reasonable price is a “pipe dream…wishful thinking.”  His point was rebutted, however, by a person who had attended the natural gas conference, and reported that the consensus there was that the amount of natural gas required for these conversions is so small, both from a national perspective and a regional perspective, that it will not affect heating costs.

          An author who focuses on issues relating to spirituality and the environment stated that we have benefited from low-cost energy in part because we have not gotten away from coal to the same degree that other states have.  But those costs do not reflect all the externalities, particularly the health impacts.  He thought that we had a moral duty to improve the environment over time, even if only gradually, but that we did not have to do it perfectly.  He favored the primary MERP proposal.

          This position was echoed by a long-time Minnesota resident and historical writer, who agreed that natural gas was not a perfect solution, but that it was a step, and one we should make even though we realize that natural gas is not the final solution.

PUBLIC TESTIMONY IN NORTH MINNEAPOLIS

          Approximately 85 members of the public attended the hearing in North Minneapolis, and 36 of them spoke.  The speakers were overwhelmingly in favor of the primary proposal, with 33 speaking for it, two against it and one who was unclear.  PUC Chairman Leroy Koppendrayer and representatives of the PUC staff, the DOC and the OAG all attended

          Minneapolis Mayor R. T. Rybak favored the primary proposal, indicating that the Riverside Plant was the “number one source of air pollution” in the City.  Although the proposal would increase the City’s own energy costs by six percent, that increase is more than offset by a ten percent reduction in energy achieved by the City’s energy use reduction program.  He urged other businesses, concerned about their increased costs, to institute a similar program that might actually save them more than the MERP proposal would cost.  The Minneapolis Health Department analyzed the health implications of the Riverside Plant to city residents, and determined that the plant was the cause of 15 new cases of adult chronic bronchitis, one or two new cases of child acute bronchitis, four hospital admissions from respiratory problems, 84 emergency room visits, 1,180 asthma attack days, 17,000 restricted activity days, and 44,000 respiratory symptom days.  Recognizing the impossibility of putting a dollar figure on these impacts, the Minneapolis Health Department nonetheless estimated a total 57.4 million dollars in annual impacts.  Mayor Rybak also noted that businesses should be very concerned about the possibility of falling out of compliance with federal air pollution standards, and he noted that the Minnesota Chamber of Commerce has estimated a cost of 260 million dollars a year if that were to happen.  He noted that the plant occupied an important piece of land that is part of the long-term development opportunities in the City, and its coal fields could be converted to housing and other development.  Right across the river is the Upper River Terminal that the City would also like to redevelop.  He noted the presence of lawn signs, particularly in the neighborhoods of North and Northeast Minneapolis, which indicate that this issue is an important one.  Finally, he pointed out that cleaning up the emissions from Riverside was a matter of economic justice.  He noted that the Black Dog plant in Burnsville had been cleaned up, and it was only a matter of justice that the children of North Minneapolis should breath as well as the children of Burnsville.

          Representative Keith Ellison also supported the primary proposal, stating that his only complaint with it was that it should be happening at a faster pace.  As an attorney, he noted that Executive Order 12898, signed by President Clinton, directed federal agencies to make environmental justice part of their missions, by identifying and addressing disproportionately high adverse human health and environmental effects of programs on minority populations and low-income populations.  He pointed out that an Atlanta, Georgia-based coalition, People’s Agenda, and the Washington-based Black Leadership Forum released a study showing that 68 percent of blacks live within 30 miles of a coal-fired plant, which is the area within which people experience the maximum effects of smoke stack emissions.  But much of Rep. Ellison’s district is within three miles of the plant.  On a county-to-county basis, he noted that 71 percent of blacks live within counties that don’t meet federal air pollution standards, compared with 58 percent of whites.  He noted that asthma hospitalization rates for blacks are three times the rate for whites, and the death rate from asthma on blacks is 30.87 deaths per one million, which is twice that for whites.  He thought the conversion should happen sooner, rather than later. 

          Hennepin County Commissioners Gail Dorfman and Peter McLaughlin noted that all seven Hennepin County Commissioners agreed that the primary proposal ought to go forward.  Commissioner Dorfman repeated that the state Chamber of Commerce study estimated that if the area became an ozone nonattainment area, it would cost Minnesota citizens and businesses in the range of 189 to 266 million dollars annually.  Commissioner McLaughlin noted that the Hennepin County Board had passed a resolution on March 11, 2003, supporting Xcel’s proposal to repower the two riverside units with natural gas.  He cited a study by the Minneapolis Healthy Learners Asthma Initiative, in 2001, which reported that 57 percent of students in Minneapolis woke up at night one or more times with wheezing or breathing problems.  47 percent of students missed one or more days of school each month due to asthma.  43 percent of parents missed work because of their child’s asthma.  24 percent reported having a serious asthma attack that requires emergency medical care.  He pointed out that a 2002 County report found that asthma rates were highest in the neighborhoods in closest proximity to the Riverside Plant.  Commissioner Dorfman stated that adopting Xcel’s primary proposal should not be a difficult decision for the Commission and urged that they do so promptly.

          Senator Linda Higgins, who was the chief author of the original MERP bill in the Senate, urged the Commission to quickly approve Xcel’s primary proposal.  She stated that the Riverside Plant emits more toxic air pollution than any other facility in all of Hennepin County, and that its particulate emissions have nearly tripled in the last six years.  In response to those who were concerned about the financial cost of the proposals, she stated that these have to be balanced against the health care cost of individuals and families who must visit the emergency room, must buy inhalers, and must miss work.  She mentioned the same health impact statistics that Mayor Rybak did, but emphasized that they could be reduced by more than 90 percent if the MERP proposal were adopted.

          Representative Joe Mullery, also an attorney, began by strongly endorsing the primary proposal, and labeled the alternative plan as “simply unacceptable.”  He pointed out that the primary plan would result in at least a 200 percent reduction in particulates and a 35 percent reduction in nitrogen oxides as compared to the alternative.  He also discussed the issue of environmental justice, pointing out that the EPA had issued regulations not only preventing intentional environmental racial discrimination, but also preventing any state agencies from in any way being involved in allowing polluting industries to have a disparate impact on communities of color.  He drew the comparison with the Black Dog plant in Burnsville, which was allowed to convert to natural gas, and stated that if the Commission were to turn down the application to convert Riverside to natural gas, that decision could create a lawsuit for intentional racial discrimination.  He noted that the EPA sends a lot of money to the state of Minnesota and one of the sanctions in federal law for intentional racial discrimination is the termination of assistance to any recipient or state.  He also noted that there is a private right of action for intentional discrimination on the basis of race.  He stated that the only thing that was not certain is whether racial minorities who suffer from a negative disparate impact from a PUC decision would have the right to sue the state under 42 USC § 1983.  But he thought that all of that was really unlikely.  His research had not shown him any case where a state agency had prevented a polluter from working with the community to clean up its pollution in the way that Xcel has proposed.  He urged the Commission to adopt the primary MERP proposal without any further delay. 

          Minneapolis Councilman Dean Zimmerman also wanted the conversion to happen twice as fast as it was being planned, and stated that the 57 million dollars worth of hidden health care costs were greater than the increased cost resulting from adoption of the plan.  In other words, it would actually be a net savings for Minneapolis citizens if the conversion took place.  But he also noted that natural gas had to be seen as only a interim step in the long-term solution to the global warming problem.  He pointed out (as did many others) that renewable alternatives such as wind were part of the long term solution, but that wind is intermittent, so it is necessary to have back up power available.  Natural gas is better than coal for that back up power because natural gas generation can be turned on and off quickly, while coal cannot.

          Representative Jean Wagenius, from South Minneapolis, supported the primary proposal, stating that it was one of those rare situations which represented a “win-win” outcome for all parties.  She offered a memorandum from Legislative Analyst Mike Bull regarding the health impacts of the Riverside Plant, the savings that would accrue as a result of the conversion, and the cost of waiting until 2009 to convert.  Bull relied on the Carl Nelson paper which was a source of some of the statistics given by Mayor Rybak, Senator Higgins, and others.  Bull pointed out that Nelson’s paper was limited to the health impacts of particulate emissions only, and thus the 57.4 billion dollar figure widely cited was really not the whole health cost of the plant.  Nelson estimated the total health cost of the plant in the range of 66 to 106 million dollars annually, and thus continuing to burn coal for the seven years from 2002 (when Bull prepared his memorandum) to 2009 could result in $460 to $740 million dollars in health costs.  Representative Wagenius submitted a packet of information (labeled Minneapolis Ex.1) that contained not only the Bull memorandum, but also the underlying Nelson paper and other documents relevant to the proposal.  To those employers who would question the value of converting, she pointed out the sick leave and decreased worker productivity that are caused by the plant.  She also noted that the State had devoted a great deal of time, effort and money attempting to decrease mercury levels, and that the largest source of mercury pollution remaining in the State is the burning of coal for electricity.  She noted that ten percent of women of childbearing age are estimated to carry a body burden of mercury contamination above EPA’s safe levels, which translates into 390 thousand newborns at risk of neurological effects.

          Commissioner Annie Young, of the Minneapolis Park and Recreation Board, also serves as the environmental coordinator at the Women’s Cancer Resource Center.  She urged the Commission to support the primary proposal, arguing that the health benefits to citizens will outweigh the costs of the plan. 

          Senator Scott Dibble presented a petition signed by himself and 19 other senators and representatives from around the Metro area that urged the Commission to adopt the primary proposal because it fulfills both the spirit and the intent of the emissions rider adopted by the Legislature in 2001 and the 2002 Legislation that gave rise to the MERP plan.  The Legislators also urged the Commission to allocate costs equitably to all customers so that the costs are not unfairly imposed on small, residential customers.  Finally, the Legislators urged that Xcel shorten the timeline for converting the High Bridge and Riverside Plants and to plan for additional mercury reduction at the King Plant.  (This was labeled as Minneapolis Ex. 3). 

          Representative Sheldon Johnson, from the East side of St. Paul, pointed out that his district has been a nonattainment area for particulate matter for more than a couple of years, and he wants clean air and clean energy now.  He was one of the signatories to the petition presented by Senator Dibble. 

          The statistical information presented by the elected officials provided the audience with ammunition to state their own views.  One man, for example, talked about the increase in pollution from the Riverside Plant over the past few years and asked the Commission “how much will it grow in the next seven years and what part of this no-brainer [the primary proposal] is misunderstood?”  The American Lung Association of Minnesota and the Minnesota Asthma Coalition both support the primary proposal, arguing that its adoption would be a significant factor in staving off the region’s falling into non-attainment status for ozone and fine particulates.  They noted that currently there are approximately 88,000 Minnesota children with asthma, many of them living within 30 miles of the three plants at issue in the proposal.  Investments will be needed to be made at each of the plants, but the benefits that will result are too great to be ignored.

          A volunteer from the Science Museum of Minnesota’s River Eye Project stated that he encounters many people fishing on the banks of the river.  They are fishing for food, not just for recreation.  He estimated that 90 percent of them were people of color. He feels bad when he tells them the danger of eating fish from the river because of mercury.  He noted that almost the entire length of the Mississippi in the Metro area is covered by a mercury advisory, and that we need to stop the deposition of mercury from all sources, including power plants.

          An opponent of the conversion proposal indicated that he wants a reliable source of electric power.  He views natural gas as expensive and scarce, compared to coal, which he characterized as cheap and plentiful.  He believed that it is technically and economically feasible to reduce coal emissions to the point where they are comparable to natural gas emissions.

          A science teacher in the Minneapolis Public Schools for 27 years stated that when she first started teaching at North High School in 1979, she could count on one hand the number of students that had asthma.  But this year she went to a track meet in March and saw many students laying down getting ready for the event by using an inhaler.  It seemed to her that now she could count on her hand the students that did not have asthma.  She described a scene, about four years ago, after one of the students of North High died from an asthma attack.  She saw one of the student’s best friends sitting in a hallway, crying, and between sobs she was using an inhaler. 

          Another speaker supported the conversion from coal to natural gas but he strongly resented the idea that citizens should have to pay for clean air and clean water when profits from Xcel had gone to its shareholders.  He chided the legislators for allowing Xcel to “pick our pockets” for the conversion, arguing that Xcel had known the benefits of the conversion for years, but chose to profit from the dirty emissions until the Legislature allowed them to charge the public for cleaning it up. 

          A pediatrician who grew up in North Minneapolis and now practices in South Minneapolis stated that everyday he treats at least one child, sometimes two or more, who have asthma, and that “it is the chronic illness of childhood,” accounting for more hospital admissions of children than any other disease.  He prescribes five or six different kinds of inhalers, but their average cost is about $60 to $100 per month.  He has children who are on more than one medication, some who are taking two and three medications a day to control their asthma, and many of whom have to take steroids to control it.  He urged the Commission to approve the conversion. 

          Another commentator spoke of a recent article in a magazine (entitled Organic Style, Minneapolis Ex. 4) that ranked 125 cities in the country by how healthy it was to live there.  Minneapolis ranked poorly -- 105 out of 125.  Boston, Denver, Las Vegas, Atlantic City, and many others ranked ahead of Minneapolis.  He thought the Chamber of Commerce was being shortsighted by opposing the plan, because employers are impacted when their workers are impacted.  He noted that energy conservation can also cut down emissions, but that many energy conservation measures require a high initial investment.  The desire to install more efficient lighting, for example, can present a consumer with a choice between a 50-cent light bulb or a $25 light bulb.  Dramatic energy savings are available for some new refrigerators, for example, but they cost money.  He thought the Commission should approve the primary MERP proposal but not stop there.  He thought there should be some way to make it possible for people to buy efficient light bulbs and appliances, even if they cost more than inefficient ones. 

          Another commentator, who works in a North Minneapolis school, pointed out that when children are absent from school or has not gotten an adequate night’s sleep, they are not able to receive the benefits of the education that is offered.  Many of the schools in North Minneapolis are experiencing an achievement gap.  The commentator stated that most of those children that are not able to graduate are affected by respiratory conditions.  There are 685 students enrolled in her K-8 school, and on the day of the hearing, 45 of those children were absent because of respiratory problems.  She thought that part of the poverty, missed education, and poor health in the North Minneapolis community could be traced to emissions from the Riverside Plant.  She favored the conversion.

          Another public school administrator testified that over the 29 years that she has served in the schools, there has been a dramatic increase in the number of children with asthma.  She characterized the problem as “urgent” and her operative word was “now.” 

          A representative of the Superior National Forest testified that there are four air quality management issues facing the Boundary Waters Canoe Area Wilderness:  Acid deposition, visibility impairment, mercury deposition, and the health of visitors and residents.  He stated that the common pollutant related to all those issues is sulfur, and coal has sulfur, but natural gas does not.  He talked about the threat of nonattainment for ozone in the Metro area, and an imminent change in the federal acid rain rule which will require more emission reductions.  He urged the Commission to act now to approve the primary MERP proposal. 

          Former Commerce Commissioner Jim Bernstein strongly supported the primary MERP Plan, and complemented Xcel for proposing it.  He responded to those who were concerned about rate increases by noting that if these three plants are not upgraded and ultimately have to be replaced, ratepayers will face much bigger increases.  He characterized the rate increases from MERP as “house cats” compared to the “wild tiger” increases that will occur if the plants have to be replaced.  But he did caution the Commission to be certain that the cost is minimized by requiring Xcel to competitively bid the project.  He stated that rate payers have a legitimate stake in keeping the cost as low as possible, and that competitive bidding (which could include Xcel, if it choses to participate) usually results in lower costs.  Finally, he stated that there was no such thing as “clean coal.”  Instead, there is only dirty coal and perhaps less-dirty coal.

          Another commentator, who is a scientist by education but a lawyer by profession, commended Xcel “for doing the science right.”  He did his own calculations of personal costs and benefits, and determined that for him, he would save money if the plan were adopted because he would not have to lose productivity from headaches or breathing problems, and that savings in his productivity would outweigh his cost for the plan. 

          A representative from EnviroScrub stated that it would cost about 20 to 25 million dollars for Xcel to build one of EnviroScrub’s pollution control systems large enough to prove its viability, and that such a commercial-scale project could be operational in 2004.  If it did not meet Xcel standards, this additional cost would only increase Xcel’s budget for the project by about 2.5 percent.  On the other hand, if it did meet Xcel’s standards, several hundred million dollars could be saved.  He noted that in a number of areas, the EnviroScrub process would improve air quality over Xcel’s current plan, particularly in the area of particulate matter, where Xcel plans to meet the EPA’s PM10 particulate standard, while EnviroScrub can meet not only that but also the PM2.5 standard.  But another commentator responded that there is not yet any large-scale use of the EnviroScrub technology and now is the time for the Commission to go ahead and approve the primary MERP proposal. 

          A public health professional who is with the Institute for Agriculture and Trade Policy focused on mercury, indicating that the primary proposal would eliminate 100 percent of mercury emissions at two of the plants, but only 20 percent at the King Plant.  She urged that 20 percent was not good enough, and the Commission should modify Xcel’s plan to require the addition of mercury control technology at the King Plant to reach at least 90 percent removal.  She stated that a plant in Council Bluffs, Iowa, which is similar to the King Plant, is going to install mercury control equipment at an estimated cost of only 3.3 million dollars, which she felt was well worth it to achieve substantial mercury reductions.

          Gregory Gray, a former legislator and now consultant with the Minneapolis Urban League, concluded the evening by pointing out that North Minneapolis was subject to a variety of different sources of air pollution, including the Hennepin County incinerator, the Kondirator, automobile traffic, and chemical spraying.  But the Urban League supported the primary proposal as an opportunity to do something about one of the sources, to make a significant move in the right direction. 

Dated this 15th  day of October, 2003

                                                                      /s/ Richard C. Luis

                                                                      ________________________________

                                                                      RICHARD C. LUIS

                                                                      Administrative Law Judge

 

/s/ Allan W. Klein

ALLAN W. KLEIN

Administrative Law Judge

Reported:  Shaddix and Associates

                 Transcripts Prepared.