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Help Make the Miami-Dade County Partnership with FPL a Real Win-Win


Laura Reynolds, Consultant for Southern Alliance for Clean Energy


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Image: FPLs Turkey Point cooling canal system (CCS) covered in algae, March 2017, satellite imagery


At the end of January, Miami-Dade County Mayor Giménez announced a significantJoint Partnership Agreement(JPA) proposal between Miami-Dade County and FPLthat includes a plan to provide reclaimed waste water for Turkey Point’s cooling canal system (CCS). The proposal was first discussed publicly at the Chairman's Policy Committee meeting last month, which I attended and provided comments. The Miami-Dade County Commission, led by Rebecca Sosa and Dennis Moss, agreed with public commenters that though this could represent a positive step for the County and FPL, significantly more detail must be added into the agreement upfront before signing on the dotted line, including clarification that this does not change the Commissionsearlier positionto require closure of the CCS and a technology upgrade to cooling towers by 2033.


While everyone agrees it is beneficial to recycle Miami-Dade’s waste water, it is only practical that the largest water user in South Florida, FPL’s Turkey Point facility, be the entity partly responsible to make that happen. But caution is needed. The County must maintain its regulatory authority to protect the region’s water quality and water supply while ensuring the use of more sustainable water resources. This necessitates development of a back-up plan in case FPL’s actions change and aspects of the proposal fail to materialize.


This new proposal is encouraging because it could free up tens of millions of gallons of water every day that FPL had been using for electricity generation at Turkey Point, so that water can instead naturally enter Biscayne Bay and keep the salinity closer to levels needed to support fish and wildlife, the main goal of Everglades Restoration.


Currently the County is battling with FPL to enter into a “Corrective Action Plan”—a directive embedded within the County’s Consent Agreement with the utility to clean up the nutrient pollution that is leaking out all around their Turkey Point plant. FPL continues to claim that the pollution from this industrial waste facility is not theirs and they should not have to enter into a corrective action plan to clean it up. If reuse water is instead used by FPL, the County must ensure the water is cleaned up to the highest possible standards so as to not add to the current nutrient pollution problem. The proposed agreement does not provide that information and instead it kicks the can down the road to study the situation and then enter into a “Reclaimed Water Service Agreement” in 2019.


The County has already done a study of reuse water quality levels required to the standards necessary to protect human health and our Outstanding Florida Water (OFW), Biscayne National Park. These water quality standards must be explicitly written into this agreement now. The County should not wait for the details to follow or to trust that other agencies’ standards will be enforced.


The Turkey Point cooling canals were built on porous limestone and if their operation continues the cooling canals will continue to exchange the polluted industrial waste water into the surrounding environment. The seepage into our aquifer and into the Bay has only increased since the plant’s uprate in 2012 and the eventual addition of other sources of water. The higher the level of water in the cooling canal system the more pollution is forced into the aquifer and into the Bay; FPL calls this remediation plan “Feed and Bleed”. Unfortunately for the health of the Bay and for the health of our water supply this is not a solution to Turkey Point’s pollution, this only causes the pollution to be forced from the cooling canals into more sensitive areas. That includes polluting the region’s sole source aquifer, Biscayne National Park and adjacent Everglades Restoration Projects. The County took the position in a unanimously passed July 2016 resolution that the failing Turkey Point cooling canal system must be decommissioned by 2033 and replaced by cooling towers. However, this proposed agreement suggests that there will never be a technology upgrade to cooling towers, despite FPL’s new proposal to run the plant an additional twenty years, which was referenced in the utility’s January press releaseabout the proposal. 


With a second twenty-year license extension, if approved by the U.S. Nuclear Regulatory Commission, FPL’s Turkey Point is the first applicant to request potential operation of a nuclear plant for eighty years, to the 2050 timeframe, which could make it the oldest, longest-running nuclear plant in the country, posing serious safety concerns for our region. Additionally, the cooling canals will continue leaking into the surrounding environment for decades longer than currently approved if something is not done now.


The Miami-Dade County should demand that a comprehensive solution is needed and maintain the position that FPL using reuse water at Turkey Point is only one stepin the needed abatement, remediation and mitigation process and should remain skeptical that the current remediation plan will even work.


If the details are provided, the proposed agreement could provide a comprehensive solution that could solve three serious problems:


1)      Miami Dade County is required to stop ocean outfalls and is mandated to reuse and recycle nearly 120 million gallons of water per day by 2025;


2)      FPL needs this reclaimed water, which can easily be used in cooling towers, in order to fix the many problems associated with Turkey Point’s polluting cooling canal system; and


3)      the Biscayne Bay Coastal Wetland Restoration Project has an identified need for increased freshwater and could be provided the remainder of clean, reuse water for restoration.


Miami-Dade County has been the only arm of government consistently challenging FPL and working to protect the health of our region’s water supply. This proposed agreement must not cloud their regulatory judgment. Therefore, the County must include language in this agreement now that tightens the requirements for FPL now if the utility truly wants the County as a partner.


The County has a responsibility first to protect its citizens and our environmental resources. Any agreement with FPL should have the required details included up front so there is a level of assurance for everyone in order to truly be a Win-Win partnership for County residents.


In a very successful development I, along with Kirk Martin, were asked to provide a presentation at February 28, 2018 FKAA board meeting on recent data trends and the proposed Joint Partnership Agreement between FPL and Miami Dade County. If you are interested in a copy of the presentation slides, please email me at lreynolds@conservationconceptsllc.org. FKAA followed that meeting with a press releaseand their decision to act in support of moving toward new cooling technology at Turkey Point. 


The day after that meeting, several environmental groups sent a joint letteron March 1, 2018 to Mayor Giménez and the Miami-Dade County Commission requesting improvements to the proposed JPA. The plaintiffs in the ongoing Clean Water Act (CWA) case also provided a redline revised JPAthat would significantly improve the initial proposed agreement.


The next upcoming public meeting discussing Turkey Point will be at the Monroe Board of County Commissioners meeting on March 21, 2018 in Key Largo. We will ask Monroe County to follow suit and join FKAA in the outreach, funding and legal filings to support our CWA case. Interested members of the public should encourage the County to act.


The plaintiffs in the CWA case are listed below. Please consider making a donation earmarked “FPL/Turkey Point” to hold FPL accountable by updating the cooling technology at Turkey Point and doing more to protect our valuable natural resources:

·         Founded in 1985, the Southern Alliance for Clean Energy promotes responsible energy choices that work to address the impacts of Global Climate Change and ensure clean, safe, and healthy communities throughout the Southeast.

Learn more at www.cleanenergy.org.

·         Founded in 1947, Tropical Audubon Society works to conserve and restore natural South Florida ecosystems, focusing on birds, other wildlife and their habitats through advocacy and education for the benefit of biological diversity and humanity itself. 

Learn more at www.tropicalaudubon.org.

·         Founded in 1969, Friends of the Everglades compels government agencies to comply with existing environmental laws, encourages politicians to recognize the long consequences of their actions and spreads awareness of the importance of the Everglades to the South Florida ecosystem.

Learn more at www.everglades.org.


If you have any questions or would like more information, please contact me, Laura Reynolds, at lreynolds@conservationconceptsllc.orgor 786-543-1926.

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