os € 15 € Based on GPA’s most recent low sulfur bid solicitation, it would cost GPA $15 to $16 million annually above present fuel costs to burn low sulfur fuel continuously. This represents a fuel cost increase of 50 percent over present fuel costs, approximately $30 mullion to $10 million, This cost increase would have to be pussed on to the people of Guam in the form of a fuel rate increase. " The cost of serubbers would be between $12 and $20 million in capital expenditures at Cabras alone and another $5 to $15 million at Tanguisson. Additionally, annual operating costs would be $2 to 5214 milhon at Cabras and $114 to $2 million at Tanguisson, Although Tanguisson has an alternative to a scrubber—a tall stack—even this would cost $5 to $10 million for the necessary installation. The wide variation In potential scrubber costs derives from the ~ fact that GPA’s least expensive option is an innovative seawaterbased technology that is not yet commercially proven. [f the seawater system fails to meet expectations a more conventional lime-limestone system will be required, with cupital costs between $18 and $20 mil- hon for Cabras and $10 to $15 milion for Tanulsson. Neither GPA nor the people of Guam can aiford these eosts. GPA was recently granted a 10.7-percent rate Increase for fiscal 1980 and an additional 2.1 percent for 1981. In addition to this rate increase the people of Guam will soon be subject to expensive fuel cost pass- throughs as world oil prices continue to skyrocket. Adding scrubber or low-sulfur fuel costs to this would strain the people of Guam beyond their financial capacity. GPA would quicklyfind itself with thousands of uncollectable accounts, as it has experienced during adverse conditions in the past. Additionally, GPA is presently unable to obtain the fundsto finance a scrubber. Over 50 percent of GPA’s present debt consists of a $36nullon loan from the Federal Government. This loan was extended for two years in December 1978 and H.R. 3756 contains provisions for further extensions, all based on GPA’s inability to obtain private financing. Of critical significance is the fact that compliance with the NSPS and continuous control requirements of the act would have absolutely no clean air benefits for the people of Guamorfor any people else- where. The entire required expenditure would accomplish nothing; it would be a complete waste of the limited financial resources of the people of Guam. specifically, there are no inhabited land masses for approximately 1,500 miles to the west of Guam. When the prevailing winds blow, GPA’s emissions affect neither the people of Guam, nor any other people. These emissions wash out of the atmosphere over hundredsof miles of empty ocean. Burning lowsulfur fuel or operating a scrubber during prevailing winds would therefore benefit no one. The effort and the expenditure would have the sole eilect of improving the air quality over hundreds of miles of uninhabited ocean. When the prevalling winds do not blow, GPA already burns low sulfur fuel, so there is absolutely no difference between continuous emission controls and the present strategy during these periods. Accordingly, requiring GPA to meet the act’s present requirements would have no effect on the quality of the air on Guam. Meeting the act’s present requirements also makes no sense from an overall environmental perspective. The cost of low sulfur fucl on a