1. Wheelabrator Technologies Inc. A Waste Management Company Proposed RPS Methodology for Florida Workshop on Renewable Portfolio Standards Florida Public Service Commission December 6, 2007 Patrick Jeffery Wheelabrator Technologies, Inc. (603) 918-8515 Pjeff@wm.com

2. Wheelabrator Technologies Inc. A Waste Management Company Support for Solar/Wind Development Wheelabrator and Integrated Waste Management Assn (IWSA) support attractive incentives for solar and wind development 2 Tier system proposed below, for incenting solar/wind development, is likely to be more attractive for solar/wind than a multiplier system

3. Wheelabrator Technologies Inc. A Waste Management Company Statutory Background 366.92 F.S. states It is the intent of the legislature to promote renewable energy; protect the economic viability of Floridas existing renewable energy facilities; diversify the types of fuel used to generate electricity in Florida... 377.803 F.S. defines renewable to include hydrogen, biomass, solar energy, geothermal energy, wind energy, ocean energy, waste heat, and hydroelectric power.

4. Wheelabrator Technologies Inc. A Waste Management Company Disadvantages of a Multiplier system Multiplier financial incentives for solar/wind are inextricably tied to the value of other renewable resources; when there is an increase in the supply of other renewables, this will create a decrease in REC value, thus the multiplied value for solar/wind will be similarly decreased. The linkage between solar/wind and other renewables, in a multiplier system, makes it difficult for PSC from implementing incentive policy specifically for solar/wind

5. Wheelabrator Technologies Inc. A Waste Management Company A methodology which addresses all concerns A 2 tier system can address concerns of various parties This system is also consistent with 366.92 and 377.803 F. S. Tier I: New Solar and Wind sources Tier II: Renewable sources other than solar/wind

6. Wheelabrator Technologies Inc. A Waste Management Company Tier ISolar/WindIncentives for Development FL PSC can tailor incentives specifically for solar/wind, with this separate Tier I, by adjusting required percentages for Tier I purchases Eliminates competition between differing renewables technologies, making Florida more attractive for renewables developers Promotes fuel diversity Elimination of competition between technologies enables broad based support for an RPS program throughout the renewables community

7. Wheelabrator Technologies Inc. A Waste Management Company Tier II Promotes Renewable Energy and Protects Economic Viability of Existing Resources Tier II in this proposal for new and existing renewable facilities is consistent with current law and reduces the risk of backsliding regarding the renewables base in Florida power generation while promoting the development of new renewable resources This system promotes fuel diversity, in keeping with 366.92 F.S.

8. Wheelabrator Technologies Inc. A Waste Management Company The Two Tier System in Sum Two Tier System is consistent with 366.92 and 377.803 F. S. More attractive than multiplier systems for solar/wind development Promotes fuel type diversity Eliminates linkage between solar/wind incentives and value of other renewables RECs Eliminates competition between technologies thus enabling broad support of all renewable industries in developing an RPS policy. Provides more attractive environment for renewables development in Florida Enables FL PSC to tailor incentives specifically to solar/wind