Citizens of the State of Florida, Appellants v. Julie Imanuel Brown

Summary

The court affirmed the Florida Public Service Commission's approval of environmental-cost recovery for expenses incurred under consent agreements addressing hypersaline groundwater contamination from a power plant's cooling canal system. It held that environmental-protection costs may include remediation of existing harm when the harm is ongoing and remediation is necessary to prevent further damage, and it found competent substantial evidence supporting the Commission's conclusion that the remediation measures were an anticipated evolution of an earlier monitoring plan.