Georgia WAND Comments to the Public Service Commission Georgia Power’s 9th and 10th Construction Monitoring Reports for Vogtle Units 3 and 4
June 3, 2014
My name is Courtney Hanson I’m director of Organizing at Georgia Women’s Action for New Directions, we represent women and communities from across the state including those in the central Savannah River area living near plant Vogtle. We support community efforts toward environmental cleanup and clean energy. We want to thank the PSC for their leadership this year in moving Georgia forward with solar and for the opportunity to comment on Georgia Power’s 9th and 10th Vogtle construction monitoring report.
Both the information provided in the report as well as that information yet to be determined demonstrates the company’s failure to plan ahead and raises serious concerns about the financial benefits and the safety of the project. The Company’s failure to account for future costs of legal disputes, obtain all permits needed for operation of Vogtle Units 3 and 4 and provide proof that the project will be fiscally beneficial in all delay scenarios point to the conclusion that continuing down this same path would in fact be an imprudent use of ratepayer dollars.
In reference to an ongoing lawsuit with its contractor over who should take on 900 million dollars worth of cost increases due to project delays, Georgia Power states that it expects negotiations with the Contractor to continue and a settlement is possible. However, the Company’s current cost projection assumes they will prevail in the litigation and the current cost projections do not include any amounts or "reserve" for a possible settlement. This lack of planning and failure to take responsibility demonstrates a great risk to ratepayers, who could end up footing the bill of Georgia Power and their partners are held liable. This kind of risk is not prudent.
In the 9th and 10th VCM the company also states that they have acquired or on track to acquire permits necessary for the Voglte project. Georgia Power, however, has not obtained a water withdrawal permit from the Georgia Environmental Projection Division or the National Pollutant Discharge Elimination System (NPDES) permit. It should be noted that serious concerns about the company’s request to withdrawal an additional 74 million gallons per day from the Savannah River were raised by stakeholders from across Georgia in a May 8 public hearing in Waynesboro, Georgia.
Among concerns raised by local residents, preachers, environmental groups including Georgia WAND, homeowners associations, and business interests was the impact of such high withdrawals on water flow given the ongoing effects of climate change on the Savannah River including drought and saltwater intrusion.
The National Climate Assessment, produced by hundreds of expert scientists under federal guidance, was released earlier this month. It reports that “The Southeast is ‘exceptionally vulnerable’ to sea level rise, extreme heat events, hurricanes, and a decreasing freshwater supply. The permit does not include a contingency plan for drought, low flow, or continuing effects of climate change.
Drought conditions impact the health of the river and the potential of Georgia Power’s ability to obtain this vital permit. They also affect a thirsty nuclear plant’s ability to operate. Shutdowns at Vogtle due to drought conditions down the road could diminish the future benefit of the Vogtle project to consumers and should be considered in this docket.
Finally, the fact that Georgia Power’s own projections that in one 48 month delay scenario, Vogtle units 3 and 4 would no longer be financially beneficial to customers should be weighed heavily when considering the prudency of approving their expenses and moving forward with the project. The company has already pushed back operation dates of Vogtle Units 3 and 4 by 22 months. They also demonstrated failure to meet deadlines during negotiations for federal loan guarantees, which underwent several deadline extensions. Given this track record, it would not be unprecedented for future project delays to happen. In fact, it would almost be expected.
I highly encourage the Commission to consider Georgia Power’s track record, their failure to plan ahead and the questions they’ve left unanswered when considering whether or not the costs they’ve incurred are prudent. From our point of view, the best benefit to customer across the state would be to not approve the company’s expenditures for the 9th and 10th construction monitoring periods.