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June 1, 2016
David D. Ferrentino
General Counsel
Seminole Electric Cooperative, Inc.
North Dale Mabry Highway
Tampa, Florida 33618
Dear Mr. Ferrentino:
Several days ago I requested Seminole Electric Cooperative, Inc.'s federal tax returns for the last
3 years, IRS Form 990 for tax-exempt organizations, or equivalent, from Ryan Hart, see
attached. Does your client plan to provide the tax returns, and if so, when?
On page 31 of Ms. Johnsons testimony April 14, 2015 before the House Subcommittee on
Energy and Power, Ms. Johnson said Florida has a lack of native energy production capacity.
Given Florida is the Sunshine State, it appears Florida has an unlimited supply of free native
solar energy production capacity. Did I read Ms. Johnsons testimony correctly?
Kindly provide information about Seminole Electric Cooperative, Inc.s use of Floridas
unlimited supply of free native solar energy production capacity. Thank you.
Sincerely,
Neil J. Gillespie
8092 SW 115th Loop
Ocala, Florida 34481
Tel. 352-854-7807
Email: neilgillespie@mfi.net
Enclosures: Ms. Johnsons testimony, House Subcommittee on Energy and Power;
Email to Mr. Hart requesting Seminole Electric Cooperative, Inc.'s federal tax returns
Cc.: Gina McCarthy, EPA Administrator
Office of the Administrator, Mail Code 1101A
Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Second Day Air UPS No. 1Z64589FNY90276059
Cc: Ryan Hart, email RHart@seminole-electric.com
Page 1 of 1
Neil Gillespie
From:
To:
Sent:
Subject:
Mr. Hart,
This is a request for Seminole Electric Cooperative, Inc.'s federal tax returns for the last 3 years, IRS
Form 990 for tax-exempt organizations, or equivalent. Thank you.
Neil J. Gillespie
5/31/2016
Page 1 of 1
Neil Gillespie
From:
"Ryan Hart" <RHart@seminole-electric.com>
To:
"Neil Gillespie" <neilgillespie@mfi.net>
Sent:
Sunday, May 29, 2016 6:17 PM
ATT00022.txt
Attach:
Subject: Read: Request Seminole's IRS Return 990 for tax-exempt organizations
Your message
To: Ryan Hart
Subject: Request Seminole's IRS Return 990 for tax-exempt organizations
Sent: Sunday, May 29, 2016 5:55:49 PM (UTC-05:00) Eastern Time (US & Canada)
was read on Sunday, May 29, 2016 6:17:22 PM (UTC-05:00) Eastern Time (US & Canada).
5/31/2016
Table of Contents
1. EXECUTIVE SUMMARY OF WRITTEN TESTIMONY ..................... 3
2. SEMINOLES COOPERATIVE SYSTEM .............................. 8
a. Introduction .............................................. 8
b. Seminole Generating Station (SGS) ........................ 11
i.
Seminoles
Members include:
10
ii.
iii.
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dollars Seminole invested into SGS, and has not yet recovered,
would be completely lost; a result that undoubtedly constitutes
a severe economic impact to Seminole and its Members.
In addition to stripping Seminole of all economicallyviable use of its SGS property, the proposal also appears to
completely eliminate Seminoles distinct investment-backed
expectations in SGS. As previously discussed, Seminole built SGS
in 1984, pursuant to the requirements of the federal Powerplant
and Industrial Fuel Use Act of 1978, which restricted new power
plants from using oil or natural gas and encouraged the use of
coal. SGS was built as a coal-fired power plant because the
federal regulatory environment of 1984 left Seminole with no
other viable fuel options to meet its legal obligation to serve
its customers. At a time when the government encouraged the use
of coal, and prohibited the use of oil and natural gas, Seminole
reasonably expected that its coal-fired power generation at SGS
would not be regulated out of the market (by the very government
that required it to build a coal-fired plant) during its useful
life. Based on the regulatory environment of 1984, EPAs 2014
CPP was completely unforeseeable. Seminole relied on the federal
governments directive to construct coal units, and spent
hundreds of millions of dollars since then complying with
subsequent environmental rules.
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ii.
Unlike solid fuel (coal) and liquid fuel (oil), natural gas
is not easily stored due to its physical characteristics that
require significantly more volume per unit of energy stored.
Natural gas storage facilities must also possess specific
characteristics to safely and economically store a material
amount of fuel for use during periods of supply disruption.
The CPP does not provide ample time for EGUs to negotiate
contracts for the requisite gas supply and transportation
capacity and for the permitting and construction of the
necessary pipeline infrastructure. Contracting decisions made
with the urgency to comply with EPAs proposed timelines may not
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4. CONCLUSION
Seminole has serious concerns regarding EPAs CPP for
numerous legal, technical, and policy reasons. Accordingly,
Seminole requests that EPA withdraw this proposal, and
meaningfully address the issues we have raised in this
testimony, as well as expanded comments that were submitted to
the EPA during the rulemaking process.
Sincerely,
Lisa D. Johnson
Chief Executive Officer & General Manager
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