Juneau Hydropower, Inc. PO Box 22775 Juneau, AK 99802 www.juneauhydro.com Telephone: (907) 789-2775 Fax: (907) 375-2973 October 11, 2013 To All Agencies and Other Interested Parties Re: Sweetheart Lake Hydroelectric Project P-13563 Successive Draft License Application and Preliminary Draft Environmental Assessment Beginning of 90-Day Review, Comment, and Recommendation Period. Dear Agency Representatives and interested parties, Pursuant to the National Environmental Policy Act (NEPA) of 1969, 42 USC 4321 et seq. (1988), and Section 2403 (b) of the Energy Policy Act of 1992, Pub. L. No. 102-486, enclosed is the successive Preliminary Draft Environmental Assessment (PDEA) and Draft License Application (DLA) for the Sweetheart Lake Hydroelectric Project, Project No. P-13563. We request that you review the aforementioned documents and provide your written comments on the PDEA and DLA to Juneau Hydropower, Inc. and the Federal Energy Regulatory Commission (Commission) by J a n u a r y 9 , 2014. The addresses you should use for the Applicant and the Commission is: Duff W. Mitchell, VP & Business Manager Juneau Hydropower, Inc. PO Box 22775 Juneau, AK 99802 Federal Energy Regulatory Commission Office of Hydropower Licensing – Room 6H-10 888 First Street, N.E. Washington, DC 20426 In addition to comments on the PDEA and DLA, we would appreciate and request your Preliminary Terms, Conditions, and Recommendations for the PDEA and DLA by May 2, 2011. All comments on the PDEA and DLA for the Sweetheart Lake Hydroelectric Project should be sent to the addresses noted above. All comments must: (1) bear the heading "Preliminary Comments", Preliminary Recommendations", "Preliminary Terms and Conditions", or Preliminary Prescriptions"; and (2) set forth in the heading the name, “Juneau Hydropower, Inc.” and the project number “P-13563” of this application. Any party interested in commenting should do so before January 9, 2014. (90 days from mailing). We will then incorporate your comments and recommendations into the Final License Application and Draft Environmental Assessment and submit them to the Commission.
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FERC NO. P-13563 - Juneau Hydropower DLA PDEA... · enclosed is the successive Preliminary Draft Environmental Assessment (PDEA) and Draft License Application (DLA) for the Sweetheart
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Juneau Hydropower, Inc. PO Box 22775
Juneau, AK 99802 www.juneauhydro.com
Telephone: (907) 789-2775 Fax: (907) 375-2973
October 11, 2013
To All Agencies and Other Interested Parties
Re: Sweetheart Lake Hydroelectric Project P-13563 Successive Draft License Application and Preliminary Draft Environmental Assessment Beginning of 90-Day Review, Comment, and Recommendation Period.
Dear Agency Representatives and interested parties,
Pursuant to the National Environmental Policy Act (NEPA) of 1969, 42 USC 4321 et seq. (1988), and Section 2403 (b) of the Energy Policy Act of 1992, Pub. L. No. 102-486, enclosed is the successive Preliminary Draft Environmental Assessment (PDEA) and Draft License Application (DLA) for the Sweetheart Lake Hydroelectric Project, Project No. P-13563. We request that you review the aforementioned documents and provide your written comments on the PDEA and DLA to Juneau Hydropower, Inc. and the Federal Energy Regulatory Commission (Commission) by J a n u a r y 9 , 2014. The addresses you should use for the Applicant and the Commission is:
Duff W. Mitchell, VP & Business Manager Juneau Hydropower, Inc. PO Box 22775 Juneau, AK 99802
Federal Energy Regulatory Commission Office of Hydropower Licensing – Room 6H-10 888 First Street, N.E. Washington, DC 20426
In addition to comments on the PDEA and DLA, we would appreciate and request your Preliminary Terms, Conditions, and Recommendations for the PDEA and DLA by May 2, 2011. All comments on the PDEA and DLA for the Sweetheart Lake Hydroelectric Project should be sent to the addresses noted above.
All comments must: (1) bear the heading "Preliminary Comments", Preliminary Recommendations", "Preliminary Terms and Conditions", or Preliminary Prescriptions"; and (2) set forth in the heading the name, “Juneau Hydropower, Inc.” and the project number “P-13563” of this application. Any party interested in commenting should do so before January 9, 2014. (90 days from mailing). We will then incorporate your comments and recommendations into the Final License Application and Draft Environmental Assessment and submit them to the Commission.
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An Aquatic Working Group Meeting and a Wildlife Working Group Meeting will be held prior to the 90 day response period to discuss and clarify any issues you may have with these areas in the proposed Sweetheart Lake Hydroelectric Project. The date and time will be determined and forwarded soon.
In addition, any agency or concerned member of the public should feel comfortable and is encouraged to contact Juneau Hydropower, Inc. to answer any questions that you might have related to this successive Draft License Application and successive Preliminary Draft Environmental Assessment.
If you have any questions, please call me at (907) 789-2775.
Potable water would be supplied from a well system or piped from the powerhouse that is
designed to meet Alaska DEC and CBJ requirements.
There is a planned shelter facility located near the dam site to provide overnight
accommodations to operations and maintenance (O&M) personnel and for seasonal fish
barge workers. This facility would measure approximately 400 sq. ft.
These facilities would be located on federal land managed by the Forest Service.
(v) Fish Collection and Transportation
A planned fish collection barge would be seasonally placed in Sweetheart Lake to collect out-migrating sockeye smolts. Smolts would be collected and prepared for helicopter transport from Sweetheart Lake and delivered to the smolt reentry pool located in the powerhouse/switchyard area. The fish collection barge would be hauled out and stored on the northern lakeshore near the intake area. A ramp with a winch would be used to remove the fish collection barge system when not in use
(vi) Sweetheart Lake Dam
The Main Dam will be a roller compacted concrete (RCC) dam with an estimated height
of 111 feet (from the downstream toe to the top of dam) and a crest length of 280 feet.
The top of dam will be at EL 651 feet MLLW and the overflow spillway crest will be
at EL. 636 feet MLLW (the high normal pool elevation). The dam section will consist of
a vertical upstream face and a stepped downstream face with an overall slope of
0.85 horizontal to 1.0 vertical (0.85H:1.0V). It is anticipated that the steps on the
downstream face will be four feet high with a horizontal “tread” of 3.4 feet. The overall
section geometry was selected based on preliminary gravity stability analyses in
accordance with FERC criteria.
The RCC dam will extend across the full valley and tie into approved rock foundation on
both abutments. An overflow spillway will be constructed in the center of the RCC dam
and flow will be discharged directly down the stepped downstream face of the RCC to
the base of the dam. Outside of the spillway limits the dam will include a 25 foot wide
vertical chimney section. Concrete parapets will be constructed at the crest of the dam to
EL 651 feet MLLW.
RCC will be placed sequentially in 1-foot- thick lifts and there is a tendency for seepage
to develop along the lift lines, particularly when using dry (high vebe time) RCC mixes.
To control seepage along these lift lines, most RCC dams include a low-permeability
upstream facing system in combination with carefully designed RCC mix, with
attention to lift joint preparation and treatment. The proposed dam will include a grout
enriched RCC (GERCC) upstream face or a conventional concrete facing
system to lower the permeability between adjacent lifts of RCC. Air entrained RCC
may be used to improve the freeze-thaw durability. In addition, a low vebe time (wetter
mix) will be used in conjunction with a retarding admixture to improve the bond
between lifts.
Juneau Hydropower Inc. A-5 DLA Exhibit A October 2013
Exhibit B is presented herein and addresses the FERC regulation 18 CFR 4.41 (c).
(c) Exhibit B is a statement of project operation and resource utilization. If the project includes more than one dam with associated facilities, the information must be provided separately for each discrete development.
Juneau Hydropower, Inc. states that the proposed Sweetheart Lake Hydroelectric Project includes a dam at the mouth of Lower Sweetheart Lake and will re-regulate the natural flows of Sweetheart Creek to provide flow to the 19.8 MW powerhouse and return all water utilized into the anadromous reach of Sweetheart Creek. Aside from natural accretion of 3%, the Project will release 3 cfs for instream flow releases.
4.41(c)(1) A description of each alternative site considered in selecting of the proposed site;
(1) ALTERNATIVE SITES
(i) Alternative Sites in and around the Juneau Area
On December 14, 2009, the Applicant was issued preliminary permit P-13563 for the investigation of a lake tap, Lake Siphon hydroelectric development on the Lower Sweetheart Lake and Sweetheart Creek. On April 11, 2013, the Applicant received a successive preliminary permit.
In our analysis, we reviewed all sites in Juneau listed in previous governmental publications related to the hydropower resources that could serve the growing commercial and residential demand in the City and Borough of Juneau. The Applicant reviewed several sites within and beyond the City and Borough of Juneau. Many of these alternative sites are identified in USGS Water Supply Paper 1529 and the Federal Power Commission, Water Powers of Southeast Alaska (1947). These sites include previously developed project sites such as Sheep Creek and Tease Lake along with other small projects. Further sites were identified such as the Whiting River or the damming of the Taku River as proposed in the early 1950’s. Damming salmon bearing rivers would pose monumental environmental issues and would not be further considered by this developer or the general public. Additionally, AEL&P has developed Lake Dorothy I that with proper license amendments and financing could develop Lake Dorothy II as an alternative site.
None of these undeveloped alternative sites were determined to be superior to the Sweetheart Lake Hydroelectric Project site in generating economically viable energy at a reasonable cost of development that could serve the current and growing Juneau market demand. No other undeveloped sites within the Juneau market are of the economies of scale size necessary to deliver reliable year round power for Juneau’s needs. Other resources were therefore eliminated from additional investigation of time and investigation resources. In addition, not all undeveloped sites are federal power site classifications. The designation as a federal power site provides the federal withdrawal of the land for the reserved purpose of developing hydropower resources for the citizens of the United States. Sweetheart Lake Hydroelectric Project is listed as a federal power site under PLO 382b as Power Site Classification 221 March 6, 1929. Because Power Site Classifications are identified by Public Land Orders, these lands potentially have inherent rights and benefits accrued by the Congressional authorizing language establishing the authority for water reservations and power site withdrawals as discussed in Section 3.3.7.
(ii) Alternative Sites in and around the Sweetheart Lake Hydroelectric Development
The proposed project site is clearly the superior dam site and powerhouse locations in the Sweetheart Lake watershed for development of a storage dam and reservoir due to the narrow gorge just below the Lower Sweetheart Lake as it empties into the steep and narrow Sweetheart Creek. This determination of superior attributes is reinforced by previous governmental studies that invested substantial federal and state resources in configuring the location and determining the water power resource of the Sweetheart Lake watershed.
Previous studies located the powerhouse closer to Gilbert Bay at a lower elevation of Sweetheart Creek. This would provide an additional 30 to 35 feet of head and would improve the economics of the project. However, this alternative of locating the powerhouse at Gilbert Bay would likely destroy the natural and stocked salmon runs and would have secondary and third order negative impacts on the Sweetheart Creek ecosystem and the recreational attributes.
A storage project requiring a small dam as proposed is necessary to efficiently and economically utilize the Sweetheart Lake watershed resource because of the highly variable stream flows.
Nonetheless, the Applicant has identified and considered the Upper Sweetheart Lake, as described below:
The Upper Sweetheart Lake drops from an elevation of 1750 for development of storage, the waterway would consist of about 1000 feet of tunnel connecting with about 2000 feet of penstock to a powerhouse located on Sweetheart Lake. This alternative could generate up to 2.5 MW.
Although this project could be developed at a future date this alternative plan was not selected because: 1) generation would only be possible during about 6 months of the year when the value of power is lowest, and 2) mobilization of equipment and material would be prohibitive and 3) the entire cost of the transmission line for the full development
would need to be borne by the alternative, which makes the alternative cost of power economically prohibitive.
Other locations reviewed for consideration were, Boundary Lake near the Taku River, Whiting River and Taku River. These locations are either: too small to be economically feasible , too seasonal to provide reliable year round power necessary to provide energy security, too far away from current transmission assets or irresponsible from an environmental viewpoint and would be inconsistent with the 2008 Tongass Land Management and Resources Plan (TLMP).
4.41(c)(2) A description of any alternative facility designs, processes, and operations that were considered.
(2) ALTERNATIVE DESIGNS AND OPERATIONS
(i) Alternative Reservoir Characteristics, Power Plant Hydraulic Capacities, and Operations
(Note-all elevations are denoted as MLLW unless specified otherwise) The generation by the Project is determined by the water resource (available flow), the hydraulic head, and the operation of the reservoir and turbines. Other parameters, such as the tunnel diameter and the number of generating units, may be engineered to suit the operation of the facility. After quantifying the water resource, the Applicant conducted an economic analysis on the main dimensions of choice for the proposed Sweetheart Lake hydropower facility: 1) the maximum reservoir elevation, which determines the hydraulic head and 2) the operation of the facility, including operation for peaking or baseload generation, the maximum reservoir draw-down, and the maximum hydraulic capacity of the turbines. The Applicant proposes a hydropower project with a maximum reservoir elevation of 636 MLLW, 60 ft of storage (to a minimum of 576 ft), a maximum hydraulic capacity of 474 cfs, and operation for baseload generation. The economic analysis was based on the assumptions described in Exhibit D.
Alternative maximum reservoir levels at 600 feet, 650 feet, and 700 feet were evaluated, as were alternative hydraulic capacities of 500 cfs, and 600 cfs. The maximum storage (drawdown) of the reservoir was considered at 30, 60 and 90 ft. Higher maximum reservoir elevations create more power at the expense of a greater inundation area and a larger dam and associated civil cost. A larger allowable drawdown of the reservoir provides greater storage but increases the environmental impact of reservoir operation.
In addition, the applicant considered peaking and baseload operation. The analysis is sensitive to the assumptions used for the financing conditions, construction costs, and critically the market price for power by time of day and season. The Project was initiated as a 30 MW peaking project, but the optimization analysis indicates that a lower capacity facility intended for baseload generation makes full use of the hydropower resource while preserving the environmental attributes of the ecosystem in maintaining required and optimum stream flows below the barrier falls necessary for anadromous salmon. The Applicant has elected to propose in this application operations that provide relatively seasonally stable stream flows for the anadromous reach of Sweetheart Creek.
Consideration of the environmental and economic consequences of these alternatives indicates that a maximum reservoir elevation of 636 ft with 60 ft of storage (to a minimum of 576 ft) and a maximum hydraulic capacity of approximately 450 cfs makes effective use of the hydropower resource while mitigating adverse environmental impacts. These values are the same as proposed with the exception of the hydraulic capacity. The hydraulic capacity proposed in this application is somewhat to increase the operating efficiency of the powerplant.
(ii) Alternative Dam Types
The proposed dam type is a roller compacted concrete (RCC) gravity dam with a 125 foot wide overflow spillway that discharges over the RCC. This type of dam is simple, robust, and can be constructed quickly (within a single construction season). The geometry was conservatively selected to meet current FERC stability criteria for various loading conditions including the PMF. Numerous mid-sized to very large RCC dams have been built worldwide in cold and wet climates similar to conditions expected at the Sweetheart Lake Hydroelectric Facility. .
The Lower Sweetheart Lake site is remote and poses significant construction challenges regardless of the dam type. Efficient construction scheduling anticipates that the power tunnel will be constructed first and the aggregate produced from the tunnel will be crushed and stockpiled near the powerhouse area for use as aggregate for the RCC dam. Upon completion of the tunnel, a batch plant will be set up in the powerhouse area and RCC will be vehicular and or belt conveyed through the tunnel to the dam site. This will reduce the disturbed area at Lower Sweetheart Lake and reduce the amount of equipment and materials necessary at the dam site. The grade and quality of the rock in the area lends itself for use as a quality aggregate in the RCC dam. Fully utilizing the local resources reduces costs, but also minimizes environmental impacts as compared to other alternative dam types.
Other dam types considered for the site include a concrete faced rockfill dam and conventional concrete. A conventional concrete dam would be similar in size to an RCC gravity dam. However, it would take more than one season to construct a concrete dam due to the limited construction season and the number of placements required by this type of construction. Extending dam construction into a second year would significantly increase the overall cost. A conventional concrete dame would require more transportation to and from the site, additional conveying to the dam site and a larger layout yard would be needed. In addition, the thermal issues associated with conventional mass concrete would increase the cost of construction.
A concrete faced rockfill dam cannot convey flows over the top of the dam and the existing stream valley is narrow, with very steep side slopes. Considering the site geometry, excavation of a large overflow spillway on an abutment is not a cost effective or practical solution. For this type of dam, a riser structure and outlet pipe would serve as the primary spillway. Due to the limited hydraulic capacity of these types of spillways we assumed that storms larger than the 100-year rainfall event up to the PMF would be conveyed through a small (~50-foot-wide) overflow auxiliary spillway excavated into
rock on the abutment. Due to the limited hydraulic capacity, the height of the dam to safely pass the PMF would be considerably higher than an RCC dam. Considering the slopes of a typical rockfill dam it is estimated that the base of the dam (upstream to downstream) would be approximately 500 feet (vs. about 100 feet for the RCC option). The large footprint, the volume of material required for this option, and the additional cost of a large riser spillway and steep abutment excavation make this option less feasible than an RCC dam.
(iii) Power Tunnel Alternatives
The power tunnel will be constructed with conventional drill-and-blast method (DBM) as is typical in many areas in southeast Alaska. The primary consideration is that the tunnel will need to be able to withstand vehicle traffic to convey goods, material and equipment to the dam site. The Applicant considered a Tunnel Boring Machine (TBM) alternative. A TBM has many advantages such as a faster advance rate, smoother bore for head loss and reduction in ground support requirements compared to DBM, it has one large disadvantage for the Sweetheart Lake power tunnel. The primary disadvantage is that a TBM produces a smooth round hole. Unfortunately rock trucks and wheeled equipment require a relatively flat surface. Therefore in order to provide a means to have vehicles use the tunnel, we would be required to blast a horseshoe flat bottom to the TBM tunnel. This is not cost effective and will add time and expense to the construction schedule thereby negating the advantages of a TBM.
Another primary advantage of driving a tunnel using the DBM allows for better handling of poor quality and adverse ground conditions as ground support elements can be installed quickly at the tunnel heading. In comparison, support of poor quality ground in bored tunnels is installed from the rear of the machine after the cutting head has passed the unstable/difficult ground section. The final decision has been made to use DBM as a result of the alternative cost benefit analysis.
(iv) Alternative Access Road Alignments
The proposed access road alignment has been selected based on cost, functionality, and environmental impact criteria. One primary objective is to mitigate the impact on a designated roadless area. Although hydropower developments may be an approved road building activity under certain conditions in the Tongass National Forest, the Applicant has sought to lessen the road construction activity in the Project plan in order to mitigate road building in an otherwise Inventoried Roadless Area. On May 24, 2011 Judge Sedwick entered a Roadless Rule order that ruled in part regarding hydropower developments in the Tongass National Forest, “…Nothing in this judgment shall be construed to prohibit any person or entity from seeking, or the U.S. Department of Agriculture from approving, otherwise lawful road construction, road reconstruction, or the cutting or removal of timber for hydroelectric development pursuant to the standards
and procedures set forth in the Federal Power Act, 16 U.S.C. §§ 791-823d” (emphasis added) 1
In the initial evaluation of the Project by the Applicant and developed in prior governmental hydropower studies on Sweetheart Lake, there was a several mile length road proposed in the project development. In a 1983 Sweetheart Lake plan of development called for a 2.25 mile road from tidewater to damsite. This road would cut through a Semi Remote Recreation Land Use Designation that encompasses the eastern shore of Gilbert Bay and the project area. This alternative road would have crossed wetlands and would have left a visible scar on the scenic landscape that could be seen from any point in Gilbert Bay. This 1983 alternative was ruled out by the Applicant as unnecessary and environmentally obtrusive. A secondary objective of the Applicant was to minimize visibility of the necessary road corridor that would traverse from the proposed dock area on the eastern shore of Gilbert Bay to the powerhouse. Two alternatives were developed: An upland forest road alternative and a high tide coastal road alternative. Based on several environmental factors, aesthetics and habitat disruption being primary selection criteria, the coastal alternative was selected by the Applicant.
This preferred Coastal road/trail Alternative is a 4400 ft. road that is aligned just below the cliff face along the eastern shore for 2000 feet. The proposed coastal road/trail is surveyed and engineered to be built at or just below the mean high tide and is extremely rocky and would encompass 6.83 State of Alaska acres but only .98 federal acres. The coastal road/trail would be built along this rocky section of the beach and the road/trail specifically designed and constructed to have a reverse slope where the road slopes interior. This strategic construction design would help mask the existence of a road from the Gilbert Bay anchorage area. As the road meanders southward toward the grassy Sweetheart estuary, the road would head east and increase in elevation toward the powerhouse located at elevation 50. Below are four survey sheets of the detailed boundary and land ownership map for the coastal road/trail based on LIDAR (Laser Interferometry Detection and Ranging) and land surveying conducted in 2012.
1 John W. Sedwick Roadless Rule Judgment Case 1:09-cv-00023-JWS Document 85 Filed 05/24/11
The powerhouse access road preferred route is the coastal alternate that runs parallel to the beach at elevation 25 feet climbing to 50 feet near the powerhouse / tailrace. The coastal road/trail will be gravel surface single lane and pullouts and be constructed from clean shot rock to USFS standards. Pullouts will be removed upon cease of construction and the berms composted and revegetated to hasten their return to a more natural looking state.
The Applicant would bury both the high voltage transmission and lower voltage service transmission cable from the powerhouse switchyard area to the dock area using the coastal road/trail alternative. Burying the cable would eliminate avian impact of eagles and waterfowl that frequent Gilbert Bay. It is the applicant’s view that the preferred alternative provides superior environmental attributes as compared to the Forest Road Alternative.
Figure B-2 Alternative Road Analysis
A Forest Road alternative of routing had been considered and was the initial alternative. In fact the forest road alternative was surveyed, engineered and drawings drafted and Therefore a substantial cost was invested in developing this alternative, but this route is not preferred. The Forest Road Alternative would originate in the same dock area and would travel upland from the marine facility and then south toward the powerhouse. The figure above depicts the two alternatives.
The computer graphic rendering below roughly represents the two contrasting road alternatives.
Figure B-3 Computer Simulation Alternative Road Analysis There are many advantages to justify the selection of the coastal/trail alternative over the forest road alternative.
1. Less road distance in length.
2. Less road impact on federal land as the coastal road is almost entirely on State of Alaska land.
3. Less impact on wetlands.
4. Less impact on scenic disturbance (buried powerlines on coastal road/trail alternative.
5. Substantially less logging required.
6. Less impact on intermittent streams along Gilbert Bay and less soil and runoff caused by erosion.
7. Less impact on waterfowl and raptors (buried powerlines on coastal road/trail alternative.
8. Combines use of trail with the roadway whereas the forest road alternative would not be used as a trail.
9. Requires less maintenance and clearing over the life of the project.
Regardless of weighting of criteria, the coastal road/trail is a superior alternative.
Initially, the Applicant reviewed previous plans to determine what was identified for power house and plant locations. All previous federal and state agency plans called for a tidewater powerhouse. Unfortunately, these tidewater power plant locations would either impair or materially destroy the natural runs of salmon and would negatively impact the recreational and personal use sockeye fishery. For these reasons, the previous suggested power plant locations were ruled out by the Applicant as unacceptable.
It is recognized that the terrain is rocky, uneven, steep and difficult alongside the banks of Sweetheart Creek and it is understandable that previous studies desired to avoid the additional engineering design and construction necessary to place the powerhouse upstream. However, it is an upstream location that is needed to produce a hydropower project in this environment that would have little or no impact on anadromous species. The net result is over 30 feet of lost head and the economic impact of this loss is significant representing more than a 5% loss of head by placing the powerhouse upstream, but will little to no impact on the anadromous species utilizing Sweetheart Creek.
Therefore an upstream power house alternative was the only alternative considered. The Applicant selected an area on the north side of Sweetheart Creek where a tailrace could re enter water below the barrier falls of Sweetheart Creek. Several engineering reconnaissance trips were conducted in the area at different times of the year. In 2012, the Applicant had the entire Sweetheart Creek area surveyed to determine the best location for a powerhouse and tailrace to work with nature. Based on the survey and overlaid with LIDAR, a power plant location was selected away from the southern bank of Sweetheart Creek in recognizable difficult terrain.
The selected power plant location was subsequently chosen because; 1) it minimizes potential impacts to Sweetheart Creek by discharging tailrace water back into Sweetheart Creek close and below the barrier falls of the anadromous reach. 2) This location allows partial screening of the power plant by existing forest and hidden by strategic placement of mounds to minimize aesthetic disturbance 3) the location allows the power plant to be
Coastal/Forest Road Comparison Chart1
Total Length (feet) Total Wetland Fill (acres) PF04 Filled (acres) Rocky Intertidal Filled (acres)
Cleared to 200’ (acres) Impacted Streams (feet) Transmission Line Yellow Cedar Density Coastal Road
4400 0.54 0.29 0.25 0 25
Buried Low
Forest Road
5900 1.62
1.62 0
26.16 671
Overhead High
1Reproduced from Jurisdictional Wetland Delineation Report for the Sweetheart Lake Hydroelectric Project FERC No. 13563
partially buried in order to minimize acoustic disturbance. 4) This location provides an opportunity to for the Project to expand the stream distance to provide additional fishing stream bank for recreational fishers and wildlife.
(vi) Alternative Transmission Line Types and Alignments
The Project will employ a combination of transmission line types: buried, overhead and submarine. Submarine and buried cables tend to be exponentially more expensive than overhead transmission due to their manufacture and ability to withstand a harsher environment.
There were two transmission line alternatives from the power plant location to a marine terminal/dock area located at Gilbert Bay. The alternatives for this segment will be discussed first before exploring the transmission line interconnection alternatives from Gilbert Bay to the connection at the Snettisham transmission line. The alternatives of overhead versus buried cable for this segment was embedded with the alternative for the road/trail alternatives discussed earlier.
Topography between the Sweetheart Creek powerhouse and extending to the Gilbert Bay marine terminal/dock area is rocky and forested on the upland and has lower elevation forest and rock beach fringe at the lower elevations along the shoreline. The Applicant first explored and surveyed a forest road alternative because it was thought that this route was intuitively the preferred environmental alternative. This previously considered forest road alternative would have employed an overhead transmission line. There are many gullies and rock embankments thereby making the terrain unacceptable to buried transmission lines. Further, the area gullies have seasonal floods which could damage or wash out sections of buried line.
Therefore the forest road alternative would have an overhead transmission line that due the dense forest would require a right of way timber clearance of 200 feet. The opening of the forest area would impact the current habitats and would need large cut and fills in order to lay a road sufficient to move equipment and turbines. In addition, many culverts would be required and future washouts from gullies would require diligent maintenance. This alternative would require a large scare on the aesthetic appearance on the eastern shore of Gilbert Bay of a similar terrain scarred nature that is current with the Snettisham transmission line. Due to the aesthetic scarring effect of this road/transmission alternative and upon consultation with the Applicants environmental engineers, another alternative was developed that would have less impact on the environment. This alternative road and transmission was dismissed.
The Applicant has developed a coastal road/trail alternative that would require less invasiveness of the environment in that it is shorter in length and would require less cutting into the hillsides. The coastal road would emplace a more expensive buried transmission line that would serve to eliminate avian impacts from eagles, costal birds, and seasonal waterfowl. Over the 50 year life of the project, the buried transmission line would not only eliminate aesthetic disturbance but it will virtually eliminate any chance of an avian strike.. An overhead transmission line would cause avian strike issues and
would defeat the aesthetic features of the coastal road/trail alternative. The Applicant will emplace a 12.47 kV service line alongside the high voltage 138 kV buried transmission line to provide electrical service to the dock, and caretaker/shop facility. For these reasons, the Applicant selected the coastal road/trail alternative to have a buried transmission line.
(vii) Gilbert Bay to Snettisham Interconnection Transmission Line Alternatives.
The Applicant considered two alternatives from the marine facility/dock at Gilbert Bay to a Snettisham transmission line interconnection just north of Mist Island on the northern shore of Port Snettisham.
The first consideration was where the interconnection to the Snettisham transmission line should occur. The entire northern shoreline of Port Snettisham is situated in an Old Growth Habitat Land Use Designation which is designated as a more sensitive environment when considering activities and power line infrastructure. However this entire Old Growth Habitat LUD along the northern shore of Port Snettisham is dominated by the existing high voltage Snettisham Transmission Line. The northern shore of Port Snettisham was analyzed to determine the optimum location for an interconnection point.
One alternative was to make a connection directly across Point Sentinel. The advantage is that it is a shorter and perhaps less costly route. However, it would require substantial hillside logging, deforestation and earthwork to ensure a stable and reliable transmission interconnection. The disadvantage is that it would require a very large intrusion on an Old-Growth Habitat LUD and would create a large scenic disruption to the landscape for any vessel entering or leaving Port Snettisham.
Figure B-4 Earlier Considered Port Snettisham Submarine Transmission Alternative
Figure B-5 TLMP Land Use Designations Port Snettisham Area Therefore, this interconnection point was ruled out by the Applicant. The shoreline investigation determined that there was an excellent landfall location combined with a relatively small intrusion on the Old Growth Habitat LUD. This location was selected as it would best fit the needs of the Project as well as for the TLMP management prescriptions.
The alternative analysis for the Northern Port Snettisham transmission segment then switched to whether to use an overhead or buried transmission line from the shoreline to the Snettisham Transmission Line. It was decided that for the short distance (less than
500 feet) that a buried cable would provide safe and reliable transmission while removing scenic disturbance that would be caused by an otherwise overhead transmission line poles and interconnection.
The analysis then focused on whether to employ entirely a submarine transmission cable from the Gilbert Bay marine facilities to the northern shore of Port Snettisham or to use a combination of submarine and overhead transmission lines.
The western shore of Gilbert Bay is situated in a Timber Production LUD which has environmental management prescriptions since it is designated as a future timber harvest area. Therefore it was determined after reviewing the Timber Production LUD TLMP management prescriptions that this LUD was an acceptable LUD to build transmission corridors. The Applicant’s 2012 survey with personal use fishermen indicated that the large response of survey respondents were equally divided on an all submarine cable versus a combination submarine overland cable.
The Applicant conducted an analysis and gave an in depth consideration to routing a 100% submarine transmission line, but abandoned that idea due to the likely interference with longline and crab fishermen who harvest thousands of pounds of fishery resource with gear that uses anchors. The socio economic impact on commercial fishermen over the life of the project was weighed in the transmission routing considerations as over 40,000 lbs of commercial harvest occurs in Gilbert Bay annually. It was determined that there could be a high likelihood of gear/anchor interaction with a 100% submarine transmission cable would not only economically impact the fishermen with potential lost gear but that lost gear would continue to ghost fish and not be environmentally friendly. Another factor was that longline gear and anchors interactions and potential snagging on the cable could lessen the longevity and useful life of the marine transmission cable.
An earlier alternative was considered that would have the routing cross the eastern shore of Gilbert Bay in a Semi-Remote Recreation LUD, then traverse to cross the Whiting River and then cut across the Port Snettisham to interconnect with the Snettisham Power line. However this alignment would be longer, problematic with depth and bottoms and the terrain is steeper and therefore would be more costly. Therefore the alternative for using was abandoned in favor of a western shore route.
Additionally, a previous plan developed prior to JHI’s involvement with the Project considered an overhead power line from Sweetheart Creek over the Gilbert Bay flats. This alternative is aesthetically unpleasing but would also produce a significant avian hazard for migrating waterfowl. Therefore this alternative was ruled out early in the investigative process as environmentally irresponsible.
Upon completion of the investigative process, the Applicant has selected the combination overland submarine cable for several reasons. 1) The personal use fishermen survey was equally divided on all submarine vs. a combination overland submarine cable so there was no clear preference. 2) The west shore of Gilbert Bay is a Timber Production LUD, the least restrictive LUD for timber harvest, road building and emplacing Transportation and Utility Systems (TUS) LUD. Therefore a Transmission and Utility System corridor is most consistent with this land use designation. 3) This alternative lessens the socio economic impact on commercial fish harvesters who use Gilbert Bay on a large
commercial basis. The impact of these fishermen and on the harvestable fishery resources for the life of the project is an important economic consideration. 4) Lost commercial fishing gear entangled on a submarine cable could ghost fish aquatic resources and further could also present a hazard to marine mammals.
Construction of a conventional overhead/submarine cable transmission line route along the western portion of Gilbert Bay was judged to be preferable over an all submarine cable. The routing of the submarine portions of the overland/submarine transmission alternative was strategically analyzed to avoid crab, halibut, and shrimp producing and productive harvesting areas. An all submarine cable alternative would cross all of these harvesting these productive fishing areas.
Figure B-6 Final Transmission Corridor from Alternative Analysis After the decision was made to choose the an overhead transmission segment over the western shore of Gilbert Bay, a route analysis was conducted considering environmental considerations of wetland impact, botanical impact, scenic impact, recreational impact, and wildlife impact as well as economic impact on the cost of construction. As a result of input from the Applicant’s environmental contractors, a route was selected for the overhead transmission segment alternative for the eastern shore of Gilbert Bay. The proposed project transmission terminates at the primary transmission line at the existing Snettisham Transmission line at the proposed Sweetheart/Snettisham interconnection point just east of Mist Island on the north side of the Snettisham entrance.
4.41(c)(3) A statement as to whether operation of the power plant will be manual or automatic, an estimate of the annual plant factor, and a statement of how the project will be operated during adverse, mean, and high water years;
(3) PROPOSED OPERATION
(i) Operation Mode
The project will normally operate under automatic control, with manual control as a selectable option.
(ii) Annual Plant Factor
The estimated plant factor is 67% (annual generation of 116 GWh and an installed capacity of 19.8 MW).
(iii) Operation During Adverse, Mean, and High Water Years
The project will be operated to provide firm power according to a schedule determined by the power off takers and in accordance with the water release agreements. For the purposes of this application, the Applicant has assumed a delivery schedule to maximize revenue from power sales to serve a steady commercial load with excess generation to be called upon by the utility receiving power. This schedule assumes steady operation of 12-13 MW (300-325 cfs) during all months and allowing the reservoir to fill from spring/summer run off. This schedule also has positive effects for the anadromous reach of Sweetheart Creek by providing a stable “spring runoff” water level that is considered by some accounts beneficial to aquatic life cycles. During typical generation, two of the three turbines will be used and will operate at near peak efficiency. Any one of the three turbines and generators can be serviced without affecting normal plant operations.
During adverse water years, the Project will operate at approximately 12 MW. The reservoir will be drawn down to near minimum levels by late April or early May, and will refill during the summer and fall. Any surplus water will be released for non-firm generation at a rate to maximize efficiency and revenue. Based on historical data, the reservoir model shows the project will deliver firm power even in adverse water years.
During mean water years, there may be somewhat more water available during the winter months than in adverse years. Nevertheless, the Project will be operated to provide only the required firm power delivery of 12-13 MW and the reservoir will not draw down as far as in adverse water years. Once the reservoir refills in the summer, there will be more water available for non-firm generation. There may be some brief periods during the summer when the inflows are so high that additional water must be released through the spillway or the outlet works. Firm power will be provided with two of the three turbines operating. Additional non-firm power will typically be produced with three turbines operating.
During high water years, the operation will be similar to that during mean water years, except there will be longer periods of non-firm generation and potential spill.
Figure B-7 shows reservoir levels during typical adverse, mean, and high water conditions. The numerical modeling of the reservoir included ten continuous years, and the level of reservoir during one year is affected by the water conditions of the previous year. Therefore the lowest reservoir levels are not necessarily during the driest years, nor are the highest levels during high water years. The highest and lowest conditions for the reservoir are shown.
Figure B-7 Reservoir Level During Adverse, Mean and High Water Conditions
4.41(c)(4) An estimate of the dependable capacity and average annual energy production in kilowatt-hours (or mechanical equivalent), supported by the following data:
(i) Estimated Dependable Capacity
Monthly dependable capacities are the values shown in Table B-1. These energy production values have been determined by numerical simulation of ten years of continuous hydrologic record from calendar years 1921-1930 and reservoir and turbine operation. This period of record has the desirable characteristics of having the same mean annual flow as the entire period of record and contains both the driest and second wettest years on record. Firm power and monthly dependable capacities are based on the year (1922) with the lowest annual power production during the ten-year simulation. The Project is designed and expected to deliver dependable capacity between 12.5 and 12.9 MW of firm power throughout the year.
(1) Firm capacity is based on the year (1922) with the lowest annual power production during the ten-year simulation discussed in section
(ii) Estimated average annual energy production in kilowatt hours The net average annual energy contribution of the Project to the Juneau market is expected to average 116,000 MWh or 116,000,000 kWh annually.
4.41(c)(4)(i) The minimum, mean, and maximum recorded flows in cubic feet per second of the stream or other body of water at the powerplant intake or point of diversion, with a specification of any adjustment made for evaporation, leakage minimum flow releases (including duration of releases) or other reductions in available flow; monthly flow duration curves indicating the period of record and the gauging stations used in deriving the curves; and a specification of the critical streamflow used to determine the dependable capacity
The Sweetheart Lake watershed above the dam site is approximately 35 square miles. The drainage area above the Sweetheart Creek gaging station is 36 square miles. A U.S.
Geological Survey (USGS) streamflow gaging station at “Sweetheart Falls Creek Below Sweetheart Falls” (USGS Station 15030000) was established and operated from 1915 through 1927.2 The USGS extended the stream gaging record by estimating the monthly run off in the 1928-32 and 1949 to 1956 water years from records of the Long River near Juneau and determining a relationship between the monthly runoff of Sweetheart Creek and Long River in a period of overlapping records.
In 2011, the Applicant contracted with Civil Science Inc. (CSI) to establish and maintain a stream and lake gage for the Project. The stream gage was installed at Sweetheart Creek at the same location, just below the barrier falls, as the USGS gage operated between 1915 through 1927. The Applicant conducted extensive research to find original USGS records in order to install the stream gage at the exact site of the gage that operated in early of the last century. The newly installed gage began recording at its location below Sweetheart Falls on September 23, 2011. A second gage was added and began recording near the potential dam site (i.e. at the outlet at Lower Sweetheart Lake) on the next day. By using the two gages it was verified that approximately 3% of the flow at the lower gage, as would be expected from drainage areas is due to accretion in Sweetheart Creek below the lake outlet.
CSI developed an extended flow record based on data from the USGS gage at Long River (15034000). The USGS had previously extended the monthly record of Sweetheart Creek. The USGS extension was made by estimating the flow in Sweetheart Creek in the 1917-18, 1928-32 and 1940-56 years from records of recorded flows in nearby Long River.3
The CSI monthly correlation models were based on daily discharge data. A separate relationship was developed for each month of the year. Monthly flow correlation formulae, expressing flow in cfs per square mile of drainage area (csm) at the Sweetheart Falls Creek gage (USGS 15030000) as function of the flow in USGS Station 15034000, Long River near Juneau. The formulae were developed through least-squares regression and took the form of the following power function:
QSHFC = C QLRn
where:
QSHFC = Daily flow at Sweetheart Falls Creek (USGS Station 15030000), csm
C = A coefficient, typically around one, ranging from 0.32 (August) to as much as 1.67 (June)
n = An exponent, ranging from 0.77 (June) to 1.22 (January)
QLR = Daily flow in Long River, csm
2 USGS gaging station records 15030000. 3 USGS Water Supply Paper 1529 page 49
The correlation models were used to create a synthetic data flow record for portions of 1917, 1918 and 1934 plus full years for 1927-1933 and 1952-1968. The synthetic record, combined with the original USGS data and data from the new gaging station, yielded approximately 39 years of flow data, including two 17-year periods of continuous record. The final extended record had an average annual flow of 336 cfs for the lake outlet. Comparatively, the USGS had estimated, using monthly flows, that lower Sweetheart Lake outlet would have produced an average annual flow of 335 cfs when pro-rated to the lake by drainage areas over the combined periods of the Sweetheart Falls Creek record and the period data calculated from Long River through 1956 (USGS Water Supply Paper 1529, 1962). Minimum, mean, and maximum average daily flows for the gaged periods as well as the extended record are shown in Table B-3.
Table B-3 Minimum, Mean and Maximum Daily Avg. Lower Sweetheart Lake Outlet Discharge in cfs.
Gaged Flows Date Synthetic Record
Date
Minimum 16.3 Jan. 17, 2012 11.1 Jan 1, 1930
Mean 336 337
Maximum 3,617 Sept. 14, 2012 2,781 Oct. 3, 1961
The applicant plans to release 3 cfs either through quantifiable seepage or though dedicated release to ensure that the bypass reach maintains a flow from the toe of the dam to downstream. This 3 cfs release would be additional to the natural 3% accretion that naturally exists. An allowance of 3 cfs was made for 1) evaporation, assumed to be minimal because the area around Sweetheart Creek is cool and wet and 2) seepage through the dam.
The estimated monthly stream flows available at the Project intake are summarized in Table B-4
USGS Gage 15030000. Sweetheart Falls Creek below Sweetheart Falls.Synthethic Record for Sweetheart Creek via same-day flow correlation with USGS Gage 15034000 (Long River nr Juneau)New JHI Gage established 9/24/2011. Lower Sweetheart Lake Outlet near Juneau.Year has gaged and synthetic monthly flow values.
The record of flows for Lower Sweetheart is 39 full years, based on gages and synthetic data, and 3 partial years.
The Minimum Monthly discharge was estimated on for January 1930 at 11.1 cfs.
The Maximum Monthly gaged discharge was for September 2012 for 1,085 cfs
The Average or mean of gaged discharge is 333 cfs. The average for the complete record of gaged data and synthetic data is 337 cfs.
The proposed project will operate using reservoir storage to regulate flows. As such, this Project’s firm capacity depends largely on the storage capacity of the reservoir and not a critical streamflow as with a run-of-the-river project.
The critical streamflow period used to determine the dependable capacity is water year 1922. Firm power and monthly dependable capacities are based on the year (1922) with the lowest annual power production during the ten-year simulation.
Annual and monthly flow duration curves are shown in Figures B-8 and B-9 below.
Figure B-8 Annual Flow Duration Curve
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Lower Sweetheart Lake OutletAnnual Flow-Duration Characteristics
Annual Data
Long-term (~36 yrs) data set includes:Pro-rated USGS data from Sweetheart Falls Creek Station (No. 15030000), Pro-rated data from correlation with USGS
4.41(c)(4)(ii) An area-capacity curve showing the gross storage capacity and usable storage capacity of the impoundment, with a rule curve showing the proposed operation of the impoundment and how the usable storage capacity is to be utilized;
Reservoir Characteristics
Capacity and area curves for the reservoir are shown in Figures B-11 and B-12. As described above, the project will not be operated on a rule curve, but rather on a firm energy delivery schedule. Therefore, a rule curve is not provided. The planned reservoir operation will draw down the water level a maximum of 60 ft from the dam spillway. Figure B-10 illustrates the proposed operation of the reservoir. The levels shown are from the reservoir simulation. The reservoir draws down to near minimum level (576 ft) from April to May and fills approximately June through October to near maximum (636 ft).
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Lower Sweetheart Lake OutletMonthly and Annual Flow-Duration Characteristics
Annual DataJanuary
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Long-term (~36 yrs) data set includes:Pro-rated USGS data from Sweetheart Falls Creek Station (No. 15030000), Pro-rated data from correlation with USGS
4.41(c)(4)(iii) The estimated minimum and maximum hydraulic capacity of the powerplant in terms of flow and efficiency (cubic feet per second at one-half, full and best gate), and the corresponding generator output in kilowatts.
The lower tailwater of the Project is the existing Channel of Sweetheart Creek where water from the Project will be returned to Sweetheart Falls Creek. This pool’s water surface elevation is controlled by a bedrock sill that forms control for the gaging station. This rating is well-defined (Figure B-13; Table B-6) and will improve with ongoing maintenance of the gage and station rating.
The tailwater elevation at the power plant will be controlled by the crest of the weir of the velocity barrier structure at the head of the tailrace channel. The weir crest has been set at EL 37.61 to provide suitable flow conditions in the tailrace channel. The crest length of 50 feet has been set to provide a maximum depth of flow of 2.0 feet over the weir crest as specified by the National Marine Fisheries Service guidelines published in the Anadromous Salmonid Passage Facility Design, July 2011. 4.41(c)(4)(v) A curve showing powerplant capability versus head and specifying maximum, normal, and minimum heads
The maximum net head is 590 ft. when the reservoir elevation is 636 ft and one turbine is operations. The normal head is 558 ft. when the reservoir is 606 ft. and two turbines are operating. The minimum net head is 524 ft. when the reservoir elevation is 576 ft. and three turbines are operating. Note that while the stated minimum is possible, the Applicant does not intend to operate three turbines when the reservoir level is near minimum. Figure B-15 illustrates the output of the powerplant at 158 cfs rated flow for each turbine operating at various net heads and corresponding reservoir elevations.
4.41(c)(5) A statement of system and regional power needs and the manner in which the power generated at the project is to be utilized, including the amount of power to be used on-site, if any, supported by the following data:
(i) Power Needs
The project will be interconnected with the State of Alaska, Alaska Industrial Development and Export Authority (AIDEA) owned Snettisham Transmission line (managed and operated by Alaska Electric Light & Power). Theoretically, generation could be utilized by AELP customer in their service area or by any customer outside their certificated service area. Currently, the Kensington Mine that has an approximately 60,000,000 kWh annual is located within the City and Borough of Juneau (CBJ) but is not connected to the Juneau grid system and is outside the AEL&P service area. The current CBJ Comprehensive Plan and the CBJ Climate Action Plan call for connecting industrial loads currently serviced by diesel electrical generation to renewable hydropower generation. The Hecla Greens Creek mine and several other interruptible customers may desire to receive full time firm electrical service if more economical and reliable year round hydropower electricity becomes available. Interruptible customers have witnessed a substantial increase in energy production costs and a very high disparity of cost between diesel self generation and lower cost hydropower generated electricity. It is likely that market substitution would occur if options are made available to interruptible customers.
Market substitution is already occurring in firm electrical energy ratepayers in Juneau as ratepayers are switching to hydropower generated electricity from more expensive diesel heating fuel for space heating needs to electric heat. This phenomena is further compounded that virtually all new construction in Juneau in 2013 is base board electrical heating (AELP personal communication 2013). Aside from market forces and substation occurring in space heating needs, there is small but continued growth in electrical transportation. Both, increases in local hydropower production and increases in electrical transportation are supported in the CBJ Comprehensive Plan and CBJ Climate Action Plan.
Data Sources: AELP Regulatory Commission of Alaska quarterly filings, AELP FERC Form No. 1, 2013, CBJ Comprehensive Plan, CBJ Climate Action Plan, Juneau Empire, AELP Press Releases.
4.41(c)(5)(i) Load curves and tabular data, if appropriate
4.41(c)(5)(ii) Details of conservation and rate design programs and their historic and projected impacts on system loads; and
At this time, the Applicant does not have any conservation or rate design programs that could or will impact historic and or projected impacts on system loads.
4.41(c)(5)(iii) The amount of power to be sold and the identity of proposed purchaser(s)
Power Sales Purchasers
The Applicant expects to operate as a FERC certified Qualifying Facility and thereby sell all of the firm project generation through a combination of sales to, AEL&P, a certificated Juneau utility for demand within their service area and to sell directly by contract to industrial demand customers outside the certificated boundary of the Juneau utility.
4.41(c)(6) A statement of the applicant's plans for future development of the project or of any other existing or proposed water power project on the affected stream or other body of water, indicating the approximate location and estimated installed capacity of the proposed developments.
At this time, the Applicant has no plans for any future water power project developments in the affected stream, lake or other body of water.
C-1 Juneau Hydropower Inc. DLA Exhibit C October 2013
Reserve Fund .....................................one year of debt service
The reserve fund is assumed to be a financing requirement, but the applicant will seek
fewer funds to be set aside in a Reserve Fund. Interest earned on the reserve fund is
estimated at 2% per year.
The sum of the total investment cost, financing costs, and Reserve Fund is termed the
total capital requirement, and amounts to $176,926,493.00
4.41(e)(2) If any portion of the proposed project consists of previously constructed,
unlicensed water power structures or facilities, a statement of the original cost of those
structures or facilities specifying for each, to the extent possible, the actual or
approximate total costs (approximate costs must be identified as such) of:
(2) ORIGINAL COST OF EXISTING STRUCTURES AND FACILITIES
Not applicable, as there are no existing structures or facilities.
4.41(e)(3) If the applicant is a licensee applying for a new license, and is not a municipality or a state, an estimate of the amount which would be payable if the project were to be taken over pursuant to section 14 of the Federal Power Act, 16 U.S.C. 807, upon expiration of the license in effect including: …
(3) AMOUNT PAYABLE PURSUANT TO FPA SECTION 14
The Applicant is applying for an original license, not a new license. Therefore, an estimate of
the amount payable if the Project were taken over pursuant to Section 14 of the Federal Power
Act is not applicable.
(i) Cost of capital (equity and debt);
(ii) Local, state, and Federal taxes;
(iii) Depreciation or amortization,
(iv) Operation and maintenance expenses, including interim replacements, insurance,
administrative and general expenses, and contingencies; and(v) The estimated capital cost and
estimated annual operation and maintenance expense of each proposed environmental
measure;
(4) AVERAGE ANNUAL PROJECT COSTS
(i) Cost of Capital
There are no public instruments in place yet for financing the construction cost, nor can
there be until after the license is issued, delivered cost of power contractually finalized,
and a power sales agreement is in place. Therefore, the calculation of the cost of capital
must be based on assumptions regarding the financing terms. For the purposes of this
application, the financing has been assumed to 80% by debt with an interest rate of 5.0%
and a term of 30 years. The applicant shall perhaps pursue the Alaska Industrial
Development and Export Agency (AIDEA) renewable energy loan with a 50 year loan
term and a loan guarantee program and or under the US Department of Agriculture
Section 9007-Rural Energy for America Loan Program (REAP) with a 30 year loan term