The Honorable Bob Smith
U.S. Senate
307 Dirksen Senate Office Building
Washington, D.C. 20510

Dear Senator Smith:

Representatives of Public Service of New Hampshire recently attended the US Senate Environment and Public Works Committee’s field hearing which you hosted in Durham, New Hampshire on innovative environmental and energy technologies.  PSNH appreciates the opportunity to attend such an informative and interesting hearing in New Hampshire.  On behalf of PSNH, I would like to submit the following comments for your consideration.

As you know, PSNH owns and operates three fossil-fuel electric generation facilities in New Hampshire.  During the last decade, PSNH has spent more than $100 million on environmental initiatives and has substantially reduced emissions from its fossil-fuel generating stations.  In a continuing effort to further economically reduce emissions, PSNH is paying close attention to the development of several innovative environmental technologies, among them Power Span’s Electro-Catalytic Oxidation (ECO).

Power Span’s ECO technology is in a research/development/test mode and, if proven to be feasible, has some promise to achieve substantial emissions reductions from coal-fired electric generation facilities.  Power Span’s projection is for ECO to be a very cost effective solution to the multi-pollutant question.  If proven true, ECO would be a welcomed new technology in the utility industry.  However, neither the first pilot project conducted at FirstEnergy’s R. E. Burger plant nor the second demonstration scheduled to be completed at FirstEnergy’s Eastlake plant are full scale demonstration projects.  Both of these trials involve a limited quantity “slip stream” and control emissions from only a small portion of the total boiler flue gas.  PSNH understands that testing of new, unproven, innovative technology typically is done in stages, however, we believe that the satisfactory full scale operation of control technology is important prior to that technology being considered “commercially available” and a feasible technology for the industry at large.  PSNH remains interested in seeing a full scale testing of the ECO to demonstrate its feasibility before it is considered an industry standard.

PSNH is encouraged that new emission control technologies are being explored and is hopeful that full scale test results will match the initial results of the ECO trial as reported by Power Span.  PSNH is also encouraged by the findings of EPA’s 1999 Information Collection Request which indicate that reductions in mercury emissions are being achieved by existing control technologies currently in operation at coal-fired electric generating facilities.  PSNH believes that additional data gathering and analysis of mercury emissions would be beneficial prior to the implementation of emissions reduction regulations.  Lastly, we feel future regulatory programs should be flexible enough to allow utilities to utilize a combination of existing technologies, and/or innovative technologies, as well as robust market-based economic incentive programs to achieve the greatest emissions reductions.  PSNH is strongly in favor of market-based trading programs in that they economically achieve real reductions.

PSNH also believes that the continued federal funding of innovative emission control technologies and demonstration projects is crucial.  This funding is especially important considering that, in many instances, forward looking environmental regulations are adopted and implementation schedules are established based on the promise of developing, unproven technologies.  A critical success factor lies in commercial viability and availability of these technologies to the utility industry.  PSNH urges that the compliance deadlines established under new emissions reductions requirements be at reasonable future dates such that developing technologies can be perfected and proven in full-scale commercial applications, for the benefit of all.

Thank you for conducting a field hearing in New Hampshire and providing PSNH with the opportunity to comment on this important issue.  I appreciate your continued interest and efforts relative to energy and environmental issues.