The IMP describes the Greenhouse

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					INVENTORY MANAGEMENT PLAN
Mary Archer ed6ba15a-1604-45dc-8c1a-978ef07b8deb.doc revised 2/3/2007

The IMP describes the Greenhouse gas management process for the company and addresses the Climate Leaders reporting requirements.

I

Partner Information
FPL GROUP 700 UNIVERSE BLVD, JUNO BEACH, FL 33408 MARY J. ARCHER, Principal Environmental Specialist

1. Company Name 2. Corporate Address 3. Inventory Contact

4. Inventory Contact Information mary_archer@fpl.com ; phone: 561-691-7057; fax: 561-691-7070

BOUNDARY CONDITIONS

II

Organizational

5. Inclusion of Partially Owned or Controlled Assets FPL Group reports its GHG emissions by equity share based on financial ownership. Leased properties’ emissions are reported in the same manner as properties where the company has an equity share. Any emissions from leased generation sources will be reported in the same manner as facilities that are owned by FPL Group. Equity share approach Using the equity share approach, FPL Group accounts for GHG emissions from operations according to its share of equity in the operation. The equity share reflects economic interest, which is the extent of rights the company has to the risks and benefits derived from the operation. The share of economic benefits in an operation is aligned with the company’s percentage ownership of the operation, and equity share will normally be the same as the ownership percentage. The company’s accounting or legal staff provide information to ensure that the appropriate equity share percentage is applied for each joint operation. The equity share approach requires collection of GHG emissions data from joint operations not under the control of the company. Business managers have access to the equity only facilities data. The business manager assigned to financial reporting for these facilities provides the generation & fuel use data. 6. Facilities List FPL Group, Inc. is one of the nation’s largest providers of electricity-related services and is nationally known as a high-quality, efficient and customer-driven organization. Its principal subsidiary, Florida Power & Light Company, serves more than 8 million people along the eastern seaboard and southern portion of Florida. FPL Energy, LLC (FPL Group’s wholesale generation subsidiary) is a leader in producing electricity from clean and renewable fuels. Together, FPL and FPL Energy’s generating assets represent more than 30,000 megawatts of capacity. A. FPL Utility Facilities Facility / Site name: 2006 list of FPL Group generating plants; all FPL facilities except Scherer are located in Florida.

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Plant
PCC PCC

Unit & Location
1 2

Percent ownership
100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100

Cape Canaveral - PCC
PCU PCU

[Fl.]
5 6

Cutler – PCU
PFL PFL

[Fl.]
4 5

Ft. Lauderdale – PFL
PFM PFM PFM

[Fl.]
1 2 3

Ft. Myers - PFM
PMR PMR

[Fl.]
1 2

Martin – PMR
PMR 8 PMG PMG

[Fl.]
8 3 4

Martin Gas - PMG
PMT PMT

[Fl.]
1 2

Manatee – PMT
PPE PPE PPE PPE

[Fl.]
1 2 3 4

Port Everglades - PPE
PPN PPN

[Fl.]
1 2

Putnam - PPN
PRV PRV

[Fl.]
3 4

Riviera - PRV
PSN PSN PSN

[Fl.]
3 4 5

Sanford – PSN
PTP PTP

[Fl.]
1 2

Turkey Point Fossil – PTP
PTN PTN

[Fl.]
3 4

Turkey Point Nuclear – PTN
PSL PSL**

[Fl.]
1 2

St. Lucie Nuclear – PSL [1]
GFL GFL

[Fl.]
1 2

Ft. Lauderdale GTs – GFL Ft. Myers GTs – GFM Port Everglades GTs - GPE
PJK PJK

[Fl.] [Fl.] 1 [Fl.] 2
1 2

85 100 100 100 100 100

St. Johns Power Park – PJK

[Fl.]

20

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or SJRPP [3] 76.36 Scherer - PSG [2] [Ga.] 4 100 Turkey Point diesels - PTP-D [Fl.] 1-5 [1] PSL-2 Generation reported is FPL's 85% ownership share only. [Fl.] [2] Scherer-4 totals reported are FPL's 76.36% ownership share only. The facility is located in Georgia. FPL does not operate this facility. [3]SJRPP totals reported are FPL's 20% ownership share. [Fl.] FPL does not operate this facility. B. FPL Energy Facilities by Fuel Type: Wind

FPL Energy Wind Net Generation (MWh)
Year to Date December, 2006
Existing Projects: State Plant MW 21 Green Ridge WPP 90 WPP 91 WPP 91-2 WPP 92 High Winds Mojave Sky River TPC Victory Garden WPP 93 CA Cabazon Green Power Cameron Ridge CA 144 CA 14 CA 19 CA 23 CA 28 CA 162 CA 85 CA 77 CA 29 CA 22 CA 41 CA 40 CA 17 CA 30 50% 17 100% 40 100% 21 50% 22 100% 14 50% 77 100% 42 50% 162 100% 14 50% 12 50% 10 50% 7 50% 72 50% Owner Owner ship ship % MW 50% 21 100%

Altamont Diablo

CA CA

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60 Pacific Crest Ridgetop Cerro Gordo Hancock
Gray County

CA 47 CA 31 IA 41 IA 98 KS 112 MN 26 MN 104 MN 99 ND 62 ND 51 ND 50 NM 204 OK 51 OK 51 OK 107 OR 25 PA 65 PA 10 PA 15 PA 30 PA 9 SD 41 TX 210 TX 299

24 16 41 98 112 13 104 99 62 51 50 204 51 51 107 25 65 10 15 30 9 41 210 299

50% 50% 100% 100% 100% 50% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100%

WPP 93 MN Lake Benton Mower N. Dakota Oliver Wind Wilton Wind New Mexico Oklahoma I Oklahoma II (Sooner) Weatherford Vansycle Waymart Green Mountain Mill Run Meyersdale Somerset South Dakota
HORSE HOLLOW I HORSE HOLLOW II

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HORSE HOLLOW III RED CANYON

TX 224 TX 84 TX 29 TX 114 TX 75 TX 278 TX 160 TX 83 TX 40 WA 300 WV 66 WI 30 WY 144 4,243

224 84 29 114 75 278 160 83 27 300 66 30 144

100% 100% 100% 100% 100% 100% 100% 100% 67% 100% 100% 100% 100% 96%

Delaware Mt. Callahan Divide Southwest Mesa King Mt. Woodward Mt. Indian Mesa WPP 94 Stateline Mountaineer Montfort Wyoming Projects Total

3,956
• Montfort • Woodward Mountain • Mountaineer • Wyoming • New Mexico Gas Site Location Percent Ownership %

GAS PROJECTS Bayswater Bellingham Blythe Calhoun Cherokee Doswell Forney Lamar Power Partners Marcus Hook 50 Marcus Hook 750 RISEC Sayreville OIL PROJECTS Long Isl., NY Bellingham,MA Blythe , Ca Alabama Gaffney,SC Richmond,VA Texas Paris,TX Marcus Hook,PA Marcus Hook,PA MD Sayreville,NJ 100% 50% 100% 100% 50% 100% 95% 99% 100% 100% 100% 50%

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Cape Station Wyman 1 Wyman 2 Wyman 3 Wyman 4 Yarmouth/WF Wyman Jamaica Bay COAL
Port of Stockton

Maine Maine Maine Maine Maine Yarmouth,ME Long Isl, NY

100% 100% 100% 100% 62% 72% 100%

Stockton,CA

50%

Nuclear • Seabrook Station Hydro • Maine-Hydro Oil • Jamaica Bay (Oil/Gas) • Wyman, Cape • Wyman 4 Solar • SEGS III • SEGS VII [2005 addition] • SEGS VIII • SEGS IX Coal • Gilberton/ Birch • Ebensburg • Port of Stockton - POSDEF facility Other • Montgomery County

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III

Operational

7. GHG List Of the six major GHGs (CO2, CH4, N2O, HFCs, PFCs, and SF6) CO2 and SF6 are included in FPL’s GHG inventory and plan.

FUEL COMBUSTION—GHGs Although all three gases [CO2, CH4, & N2O] are emitted during the combustion of fossil fuels, CO2 accounts for the majority of FPL’s greenhouse gas emissions. The approach required to estimate CO2 emissions varies significantly from that required to estimate CH4 and N2O emissions. While CO2 can be reasonably estimated by applying appropriate emission factors to the fuel quantity consumed, estimating CH4 and N2O depend not only upon fuel characteristics, but also on technology type and combustion characteristics, usage of pollution control equipment, and ambient environmental conditions. Emissions of these gases also vary with the size, efficiency, and vintage of the combustion technology, as well as maintenance and operational practices. Due to this complexity, a much greater effort is required to estimate CH4 and N2O emissions from stationary sources, and a much higher level of uncertainty exists. Consequently, due to the relative insignificance of CH4 and N2O emissions from most stationary sources, this plan only includes a method for estimating CO2 emissions from stationary sources. DOE EIA emission factors are used when Continuous Emissions Monitoring is not available. Reference: WRI’s GHG Protocol Reporting Standard and Guidance See #12 & #13 for additional CEMs information.

8. Emission Source Identification Procedure  Stationary Combustion: An existing inventorying process was established for the DOE’s Climate Challenge in 1995. The Air permitting process (Title V and General air permits) are used to identify the combustion units. The air permits are also employed to identify insignificant sources that are excluded from the inventory. The Title V air operating permits [40 CFR 70] contain an appendix of insignificant/unregulated sources that are excluded from annual emissions inventories due to the small quantity or emissions or/and lack of data to accurately calculate.  Mobile Emissions: Fuel types and quantities are tracked for the fleet mobile sources. All fuel used in fleet vehicles are accounted for in the reported totals. Using the total fuel for each type and emissions factors emissions of CO2 are calculated. Please see Item 14.  Fugitive Emissions: Sulfur Hexafluoride – SF6 Direct fugitive emissions of SF6 for FPL Utility and Seabrook Nuclear Station are tracked per the Memorandums of Understanding applicable to the addressed entities. www.epa.gov/electricpower-sf6 Quantifying Fugitive SF6 Emissions from the company deals primarily with the electricity transmission and distribution operations. FPL Group uses the mass balance method for the FPL Utility and each facility within FPL Energy determines releases on a mass balance at the facility level.

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9. Direct Sources CO2 emissions for stationary Sources listed in Item 6 are calculated and reported. These include steam generating units, combustion turbines, gas turbines, solar gas heaters, and a municipal waste burner. Direct emissions of CO2 are also calculated from the FPL Fleet. Direct emissions of CO2 equivalents of SF6 gas releases are also reported. FPL Group does not have process emissions. 10. Indirect Sources – Energy Import / Export Purchased power is reported as indirect in EIA’s 1605b program. The companies that generate this power will be reporting the emissions as direct emissions. Emissions from indirect emissions (purchased power) are not included in FPL GHG inventory for Climate Leaders. Emissions from T&D losses are calculated but add a layer of double counted emissions, since FPL Group emissions are reported for all power generated not delivered. Emissions from T&D losses are reported on FERC Form 1.

11. Optional Sources Optional sources as related to solar power that also utilizes natural gas fired heaters to generate electricity reports both renewable solar MWh and gas generated MWh. The solar generation is separated from the gas generation and the CO2 emissions from the heaters are reported. The solar facility is relevant to the inventory.

III

Emissions Quantification

12. Quantification Method A. Power Plants B. Transportation C. Sulfur Hexafluoride

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A. Power Plants Estimation method used in the inventory: This section of the plan addresses fuel use for combustion purposes only. Therefore, all fuel consumption for other purposes is excluded from this analysis. In general there are two estimation methodologies used to calculate the company’s GHG emissions from combustion sources:  Emission factor based methodology;  Direct monitoring [continuous emissions monitors – CEMs]. Both are acceptable ways to estimate GHG emissions and are employed based on the availability of the monitoring equipment on the emissions unit. Both methods were used for comparison in the baseline year inventory, where available the CEMs data was used. Exceptions occurred for new units where the CEMs data was not available for the entire operating period. Routinely the emission factor based methodology was used for peaking type units that do not have CEMs. The direct monitoring approach is common in electric utilities in the U.S. Direct monitoring system has already been established in a facility, the associated data provides a good estimate of CO2 emissions. Emission factor based methodology: For the emission factor approach, a fuel source- or facility-specific method (calculating fuel consumed per unit or facility) is used. Fuel burned data is tracked at the facility level and incorporated into a corporate-wide inventory of stationary sources at power plants. CEM data: fuel usage meters are the basis of CEM data for natural gas and oil-burning facilities. Coal plants (2 partially owned)–CEM data is from stack measurement. See file attachment: calculation_methodology.pdf

FUEL COMBUSTION—GHGs See Item 7.

B. Transportation Fleet CO2 Calculation Methods: Transportation data includes distribution fuel purchases only for fleet vehicles. Mobile source fuel purchase data is collected and rolled up by the Fleet Services Department. Fuel purchase records are maintained in the Fleet Services Department and totals are provided for GHG calculation on an annual basis. The calculation uses the number of gallons and applies EIA fuel coefficients for gasoline and diesel, 19.564 per gallon and 22.384 per gallon, per Appendix B in Instructions for Form EIA-1605 Voluntary Reporting of Greenhouse Gases [March 2003].

FPL Transportation (Distribution only)
Gallons Gasoline Tons CO2 (gal x 19.564) Gallons Diesel Tons CO2 Gasoline + Diesel ((gal x 22.384)/ 2000) Tons CO2

C. Sulfur Hexafluoride Direct fugitive emissions of SF6 for FPL Utility and Seabrook Nuclear Station are tracked per the Memorandum of Understanding. www.epa.gov/electricpower-sf6

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Quantifying Fugitive SF6 Emissions from the company deals primarily with the electricity transmission and distribution operations. FPL Group uses the mass balance method for the FPL Utility and each facility within FPL Energy determines releases on a mass balance at the facility level. Mass Balance Method: The mass balance approach looks at the difference between the quantity of SF6 in storage at the beginning of the year and the quantity in storage at the end of the year, SF6 purchases, sales and disbursements, and the change in nameplate capacity. Fugitive SF6 emissions are determined by obtaining the following: 1. Change in SF6 Inventory 2. Purchases/Acquisitions of SF6 3. Sales/Disbursements [recycled/disposal off-site] of SF6. 4. Calculate total annual emissions. 5. Convert SF6 Emissions to CO2 equivalent 6. Calculate percent leakage rate Each step is described in greater detail below. Step 1: Determine Change in SF6 Inventory & Determine Purchases/returns of SF6. Determined by the difference between the quantity of SF6 in storage at the beginning of the year and the quantity in storage at the end of the year. The ―quantity in storage‖ includes SF6 gas contained in cylinders or other storage containers. It does not refer to SF6 gas held in operating equipment. The change in inventory will be negative if the quantity of SF6 in storage increases over the course of the year. Using the following equation: Purchases of SF6 + SF6 returned to site after off-site recycling = Total Additions Step 2: Determine Sales/Disbursements of SF6. This is the sum of all the SF6 sold or otherwise disbursed to other entities during the year either in storage containers or in equipment. Using the following equation: Sales of SF6 [to other entities] + Returns of SF6 to supplier + SF6 taken from storage and disposed of + SF6 taken from storage and sent off site for recycling = Total Subtractions Step 3: Determine the Change in Total Nameplate Capacity of Equipment. This is the net increase in the total volume of SF6-using equipment during the year. The total nameplate capacity refers to the proper charge of the equipment rather than to the actual charge, that could reflect leakage. If new equipment is purchased, the SF6 used to charge the new equipment is not be counted as an emission. Using the following equation: Total nameplate capacity of new equipment + Total nameplate capacity of retiring equipment = Change to Nameplate Capacity. Step 5: Determine Total Annual Emissions. This is the total amount of SF6 emitted over the course of the year, based on the information provided in Steps 1-4. The following equation is used to calculate the SF6 total annual emissions from operations: Total SF6 Emissions = Beginning or year – End of year + Purchases/acquisitions of SF6 – Sales/returns/off-site recycle disposal of SF6 – Change in Nameplate Capacity. Step 6: Convert SF6 Emissions to CO2 equivalents. The amount is presented both in pounds of SF6 and in short tons of CO2-equivalent. Tons CO2e = [pounds SF6 x 23,900] / 2000. Step 7: Emission Rate. The total nameplate capacity of all the electrical equipment in the utility / facility is determined at the end of the year. The percent leakage rate is calculated from a mass balance determination. The emission rate is equal to the total annual emissions divided by the total nameplate capacity. The following equation is used to calculate the SF6 emission rate: SF6 % Emission Rate = Total annual emissions/Total Nameplate Capacity X 100. References:

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California Climate Action Registry: Chapter 9: Fugitive Emissions addressing SF6 Catalog of Guidelines and Standards for the Handling and Management of Sulfur Hexafluoride (SF6) Prepared for U.S. Environmental Protection Agency, Office of Air and Radiation, http://www.epa.gov/highgwp1/sf6/pdf/sf6utility7.pdf A companion document, ―Technical Papers, Conference Proceedings, and Books Related to Use and Emissions of Sulfur Hexafluoride (SF6) Gas‖ (August 2000), provides a much broader compilation of information addressing topics such as physical/chemical properties, byproducts, greenhouse gas potential, and uses. This document is available at: http://www.epa.gov/highgwp1/sf6/pdf/bibliofinal800.pdf.

13. Emission Factors and Other Constants
SF6 : Pet Coke CO2 Propane lb/ Propane equiv. (lbs/milli million (lbs/MMb Per SF6 on Btu) Btu tu) lb. 23900

Carbon Dioxide
FPL emission factors*

Oil (lbs/ million BTUs) 173.906

sub-bit. bit. Coal coal Gas (lbs/ (lbs/ (lb/MMBtu) million million Btus) BTUs) 205.3 bit. Coal (lbs/ Gas (lbs/ short 1000 ft3) ton) 120.593 119.5 4931.3 203.1 117.08

Diesel (lbs/ million BTUs)

Oil (lbs/ bbl) FPL emission factors* EPA 1093.384 172.0

212.7 161.386 139.178 225.13 139.178 sub-bit. Diesel Propane Propane coal (lbs/ (lbs/ Pet Coke (lbs/ (lb/short gallon) gallon) lb/ton gallon) ton) 3715.9 210.0 22.384 159.7 12.669 6768.667 137.7 12.669

EPA default heating values Units Heavy oil 6.287 MMBtu/bbl diesel 5.825 MMBtu/bbl propane 3.836 MMBtu/bbl bit. Coal 23.890 MMBtu/short ton sub-bit. Coal 17.140 MMBtu/short ton nat gas 1.027 MMBtu/mcf

Emissions factors are used in several regulatory programs and are reviewed annually prior to start of calculations for report submittals. DOE emission factors are used where CEMs are not available. The best available emission factor may be used including test data, published emission factors, and manufacturer emissions data.

IV

Data Management

14. Activity Data Power plants meter the fuel quantity and the heating value of the fuel. Facilities may provide mmBtus or a mass/volume of fuel quantity. Facilities with CEMs will report CO2 from their CEMs data also. Transportation [Fleet] monitors fuel use: Transportation data includes Distribution fuel purchases only for fleet vehicles. Applied EIA fuel coefficients for gasoline and diesel are 19.641 per gallon and 22.384 per gallon, respectively. SF6 loss is determined by mass balance per the instructions with the SF6 Partners MOU. All equipment with less than 15 pounds of gas is excluded from inventory. SF6 emissions are calculated by the Inventory contact that receives data from personnel in the Power Systems Business Unit including substations, stores, and environmental staff.

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15. Data Management Please see Item 24. 16. Normalization Factor(s) Selection The normalization factor selected is emissions pounds per Kilowatt hour of owned and leased electric generating facilities based on equity share. This metric is a standard in the electric generating industry. Based on discussions with the EPA, it was determined that pounds per Kilowatt hour would be the most appropriate metric to illustrate efficiency improvements in terms of emission reductions based on comparisons with similar facilities. 17. Data Collection Process – Normalization Factor CO2 information is reported quarterly for units with CEMs. Units without CEMs report information annually. The two databases combined are used as the basis for calculating the normalization factor. For each fiscal year, the operations technician [FPL] and the business managers [FPL Energy] will provide an annual update of total CO2 emissions reported per facility, to the Inventory Contact. Megawatt hours Determination: FPL Utility reports MW hours and fuel data with other operating information on an internal form no. 1192. This form is completed by each operated facility on-line and is accessed by the corporate office to roll-up the total MWhs for all facilities operated by the FPL Utility. Two coal facilities that are not operated by the FPL Utility, but in which the utility has an equity share, supply the equity share of emissions and MWhs to the FPL Utility. FPL Energy reports MW hours to the environmental technical specialist and business managers by email. This information will be supplied by each operated facility and is rolled-up by region by the business managers located in the corporate office. Facilities that are not operated by FPL Energy, but in which the company has an equity share, supply the equity share of emissions and MWhs to FPL Energy business managers. This information from both subsidiaries will be used as the basis for the normalization factor calculation for the given fiscal year. 18. Data Collection Process – Quality Assurance Facility Level fuel and CEM data for FPL Utility & FPL Energy: Emissions from combustion sources are determined through fuel use measurement/CEMs calibrations & testing. Metering/measuring equipment is calibrated in accordance with the applicable regulatory standard either 40 CFR 60 or 40 CFR 75. These systems have Quality Assurance Plan Manuals that contain calibration/operation and record keeping procedures in accordance with 40 CFR 75 Appendix D. These procedures include a daily calibration of CEMs. Megawatt hours Determination: FPL Utility reports MW hours and fuel data with other operating information on an internal form no. 1192. This form is completed by each operated facility on-line and is accessed by the corporate office to roll-up the total MWhs for all facilities operated by the FPL Utility. Two coal facilities that are not operated by the FPL Utility, but in which the utility has an equity share supply the equity share of emissions and MWhs to the FPL Utility. FPL Energy reports MW hours to the environmental technical specialist and business managers by email. This information is supplied by each operated facility and is rolled-up by region by the business managers located in the corporate office. Facilities that are not operated by FPL Energy, but in which the company has an equity share supply the equity share of emissions and MWhs to FPL Energy. Uncertainty: The most significant source of uncertainty is related to the metering and reporting of fuel use by units that do not have CEMs and the subsequent calculation of CO2 emissions. Since the accuracy of fuel receipts & fuel use meters are of financial and regulatory compliance for both the power plant and

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corporate operations there is a strong motivation for the facility and the operations technician to ensure the accuracy of these meters/receipts and the values generated. There is also a potential for human error in the transcribing of data from these reports to the inventory by the Inventory Contact. The data is reviewed by the operations specialist and either or both the technical specialist and Inventory contact, it is anticipated that any discrepancies will be identified. 19. Data Collection System Security A. Continuous Emissions Monitor data security B. Corporate Document Security A. Continuous Emissions Monitor data security The CEMS security is broken down by groups—Environmental, Performance, Engineer, Plant Operators, Plant Administration and Manager. Each group’s access authorization by "DAHS access screens" is identified on the following summary. CEMS Appendix D fuel data and the Central Lab "LIMS" fuel data are located in two different sources. The Environment Group only has access to the CEMS Appendix D fuel data. The LIMS where we access our Appendix D fuel analysis is a ―view only‖ for those outside of the Central Laboratory. See security matrix in file CEMs_security.doc B. Corporate Document Security Records Management Program—General. This document provides records management objectives, responsibilities, and guidance related to managing FPL utility records. The Management Program is applicable to all records created and received, on any medium, in the course of business, except where specific nuclear / Quality Assurance (QA) requirements apply. are the following topics: Requests for Records What is a Record? Records Management Program Objectives Responsibilities The Records Life Cycle Record Creation Record Retention Record Maintenance Destruction of Records Terms and Definitions Related References Electronic Records Management. Records retained electronically and the systems on which they reside inherently require definitive security controls to alleviate and minimize risk. Refer to GO Information Security Procedure #13010 for more information concerning the security and protection of electronic records. GO Information Security Procedure #13010: To emphasize minimum requirements, responsibilities and metrics for the protection of FPL's information resources and services, which may be considered but not limited to:  the information residing on any FPL network, system, device, or assets contained therein  any system(s) attached to FPL's network infrastructure (computer servers/workstations, and telephone systems) mainframe/host computers, and local and wide area networks (LANs/WANs). This policy is applicable to all users of FPL's information resources. The objective of protecting FPL's Information technology resources will be accomplished through the following mechanisms, institutions or methodologies.   Ownership of Information Achieving Level of Protection

program Records ordinary Included

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       

Policy, Procedure, and Standards Utilization Individual Stake Holder Responsibilities FPL's Data Classification Use of FPL's Computer Systems FPL's Telecommunication Networks / Telephone Systems FPL's Business/Vendor Relationships and Inter-Enterprise Service Connections Implementation, Enforcement, and Corrective Action Related References

GHG calculation files final versions are stored in Documentum—the electronic record storage program. Documents in the Document Management System – Documentum can only be changed by the originator or someone granted permission by the originator. The originator must go into the system and grant editing rights for the document to be changed by anyone other than the originator. Electronic Corporate Document Security – this program has been in a limited use phase for over a year & is now being implemented throughout the Business Unit. 20. Integrated Tools Facilities with CEMs are rolled into the Environmental Services Technical Specialist’s emissions spreadsheets for corporate emissions determinations. 21. Frequency FPL Utility facilities with CEMs report emissions data to corporate personnel on a quarterly basis. Other facilities’ data is reported annually.

V

Base Year

22. Adjustment – Structural Changes Since the baseline year, a nuclear facility, Seabrook Generating Station, was purchased by FPL Energy and must be incorporated into the baseline year. Greenfield sources and acquired sources that did not exist during the baseline year will not adjust the baseline year, however, existing sources that are acquired & existed during the baseline year will require a baseline year adjustment. Prior to structural changes at power plants permitting drivers include evaluations for permit revisions and evaluation of any potential emissions changes. 23. Adjustment – Methodology Changes An annual comparison will be done for operating facilities to address acquisitions, divestitures, and greenfields in the baseline year.

VI

Management Tools

24. Roles and Responsibilities – FPL Group Head Quarters FPL Environmental Services Department coordinates the roll-up of the GHG emissions inventory, and the Vice President of FPL Corporate Environmental Services reviews and signs GHG emission reports. The Principal Environmental Air Specialist [Inventory contact] enters data into spreadsheets, researches emission factors, completes reporting activities; requests data that is not supplied by the Power Generation Department Specialist [Operations Specialist] or the Environmental Services Technical Specialist [Technical Specialist ] from the specific facility business manager. The Inventory contact requests information from Fleet Services and the SF6 inventory from Power Systems, plus, requests equity share only plants data from the company business managers for those facilities.

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The Environmental Services Technical Specialist [Technical Specialist] collects facility specific data from units with CEMs monitors for both FPL Utility and FPL Energy. Power Generation Department Specialist [Operations Specialist] collects facility specific data from units with CEMs monitors, plus generation units that do not have CEMs for the FPL Utility 25. Training Currently the three corporate employees that are involved in the roll-up of data collection/calculation activities have many years of experience with emissions determination. 26. Document Retention and Control Policy The Records Management Program provides guidance necessary to:    effectively and efficiently manage authentic, reliable, and usable records on all media throughout their life cycle comply with regulatory and legal recordkeeping requirements and mandatory standards of practice, and protect and preserve records that must be retained for their scheduled retention period.

General Operations Date Approved: 09/09/2003

Corporate Records Center. Store records in accordance with the Records Management Program requirements. Retention Period. Each business unit sending original records to the CRC is responsible for ensuring that their records are identified with a retention period obtained from a record retention schedule. The retention period is used to calculate when the record will be eligible for destruction. Although records may be eligible for destruction at the end of the retention period, they will not be destroyed until the CRC has received proper authorization from the Office of Record department management, as described in GO Records Management Procedure #840.2. Environmental Services documents will have creation dates and modify dates on inventory files.

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VII

Auditing & Verification

27. Internal Auditing The IMP and its components will be reviewed for technical compliance and input by the FPL Environmental Auditing manager. Additional external validation of the IMP or its components are not planned at this time. 28. External Validation and/or Verification The IMP and its components will be reviewed for technical comment and input by E Source on behalf of the Climate Leaders Program. Additional external validation of the IMP or its components is not planned at this time. 29. Management Review Vice President -level will be involved in the review process of the setting of the reduction goal and the annual inventory reporting. 30. Corrective Action If errors are identified an assessment will be made by Environmental Services to determine steps that will be necessary to correct the error or problem and act to ensure it will not be repeated. A tab labeled actions will list corrective actions initiated in the annual inventory reports.

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