Riverstart Solar Park LLC IURC Cause No. 45336 Petitioner’s Exhibit 1 Page 1 of 30 20604283.9 VERIFIED DIRECT TESTIMONY OF RYAN J. BROWN INTRODUCTION Q1. Please state your name and business address. 1 A. My name is Ryan J. Brown, and my business address is 129 E. Market Street, 2 Suite 600, Indianapolis, Indiana 46204. 3 Q2. By whom are you employed and in what capacity? 4 A. I am employed by EDP Renewables North America LLC (“EDPR”) as Executive 5 Vice President, Eastern Region and Canada. I have been delegated responsibility 6 for the development of the Riverstart Solar Park (“Riverstart Solar Park” or 7 “Project”) by Riverstart Solar Park LLC (“Petitioner”). I am responsible for 8 EDPR’s business in the eastern U.S., including the State of Indiana, and Canada. 9 EDPR is a global leader in the renewable energy sector and the world’s fourth- 10 largest wind energy producer, with a presence in 14 countries. EDPR’s business 11 comprises the development, construction, and operation of wind farms and solar 12 plants to generate and deliver clean electricity. 13 Q3. Please summarize your educational and professional background. 14 A. I received my Bachelor’s Degree in Economics from the University of Chicago in 15 2001. I have 15 years of experience in the energy sector, including work at the 16 Indiana Office of Energy Development from 2004-2008 and at EDPR since 2008 17 in several roles, including Development Project Manager, Senior Development 18 Project Manager, Director of Development-Canada, and my current position as 19
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 1 of 30
20604283.9
VERIFIED DIRECT TESTIMONY OF RYAN J. BROWN
INTRODUCTION Q1. Please state your name and business address. 1
A. My name is Ryan J. Brown, and my business address is 129 E. Market Street, 2
Suite 600, Indianapolis, Indiana 46204. 3
Q2. By whom are you employed and in what capacity? 4
A. I am employed by EDP Renewables North America LLC (“EDPR”) as Executive 5
Vice President, Eastern Region and Canada. I have been delegated responsibility 6
for the development of the Riverstart Solar Park (“Riverstart Solar Park” or 7
“Project”) by Riverstart Solar Park LLC (“Petitioner”). I am responsible for 8
EDPR’s business in the eastern U.S., including the State of Indiana, and Canada. 9
EDPR is a global leader in the renewable energy sector and the world’s fourth-10
largest wind energy producer, with a presence in 14 countries. EDPR’s business 11
comprises the development, construction, and operation of wind farms and solar 12
plants to generate and deliver clean electricity. 13
Q3. Please summarize your educational and professional background. 14
A. I received my Bachelor’s Degree in Economics from the University of Chicago in 15
2001. I have 15 years of experience in the energy sector, including work at the 16
Indiana Office of Energy Development from 2004-2008 and at EDPR since 2008 17
in several roles, including Development Project Manager, Senior Development 18
Project Manager, Director of Development-Canada, and my current position as 19
thorn
New Stamp
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 2 of 30
20604283.9
Executive Vice-President since January 2015. I also have previous work 1
experience in corporate finance and education and volunteer work in Mexico and 2
Ecuador. 3
Q4. Have you previously testified before government bodies or agencies? 4
A. Yes. I have testified before the Indiana Utility Regulatory Commission in several 5
proceedings, most recently in Cause No. 45320 (Indiana Crossroads Wind Farm 6
LLC). I have also previously testified before the Maine Public Utility 7
Commission in a 2015 docket pertaining to our wind and transmission 8
developments in that state. 9
Q5. What is the purpose of your direct testimony in this proceeding? 10
A. The purpose of my direct testimony is to discuss the relief sought by Petitioner in 11
this proceeding and to provide the Commission with information regarding the 12
Petitioner and the Project. 13
Q6. Please describe EDPR. 14
A. EDPR is a Delaware limited liability company, and its ultimate parent company is 15
Energias de Portugal, S.A. (“EDP”), a major Portuguese utility headquartered in 16
Lisbon, Portugal. EDPR is a wholly-owned subsidiary of EDP Renováveis, S.A. 17
(“EDP Renováveis”), a Spanish company and subsidiary of EDP. EDPR has over 18
600 employees and is headquartered in Houston, Texas, with regional offices 19
throughout the United States. 20
Q7. What relief does Petitioner request of the Commission in this Cause? 21
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 3 of 30
20604283.9
A. Petitioner is requesting that the Commission decline to exercise jurisdiction 1
pursuant to Ind. Code § 8-1-2.5-5 over Petitioner’s construction, ownership and 2
operation of, and any other activity in connection with the Project, and determine 3
that the public interest will be served by the Commission’s declining to exercise 4
jurisdiction over Petitioner. 5
6
PROJECT BACKGROUND 7
Q8. Please describe the Riverstart Solar Park. 8
A. The Riverstart Solar Park is a utility-scale photovoltaic (“PV”) project located in 9
Randolph County, Indiana. The Project is situated within the footprint of EDPR’s 10
Headwaters Wind Farm, Phase I, and will leverage synergies with Headwaters 11
Wind Farm, such as jointly using the generation lead line to interconnect with the 12
bulk transmission system. The Project is anticipated to have the capability of 13
generating up to approximately 200 MW of PV alternating current solar-derived 14
energy. The total area for the Project covers an approximately 1,200-acre fenced, 15
solar panel field with approximately 660,000 solar panels. Petitioner leased 16
additional acreage to provide a buffer area around the fenced solar panel field. 17
Electricity generated by the Project will be transmitted to the Project substation, 18
which will interconnect to American Electric Power’s (“AEP”) Losantville 19
substation via the existing Headwaters generator lead line running between the 20
Headwaters Wind Farm and the Losantville switchyard just northwest of Modoc 21
in Randolph County. Major construction is set to commence in 2020, and 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 4 of 30
20604283.9
commercial generation is expected in 2021. 1
Q9. Is the Project similar to other electric generating plants for which the 2
Commission has previously declined to exercise jurisdiction? 3
A. Yes. The Commission has already declined to exercise much of its jurisdiction 4
over EDPR’s wind farms, including the Headwaters Wind Farm located in 5
Randolph County. In the Matter of the Petition of Headwaters Wind Farm II LLC, 6
Cause No. 45202 (May 29, 2019) and In the Matter of the Petition of Headwaters 7
Wind Farm LLC, Cause No. 44358 (Sept. 19, 2013). The Commission similarly 8
declined to exercise much of its jurisdiction over EDPR’s Rosewater Wind Farm. 9
In the Matter of the Petition of Rosewater Wind Farm LLC, Cause No. 45197 10
(June 5, 2019). 11
The Commission also declined to exercise jurisdiction over the construction, 12
ownership, and operation of the 6 phases of Meadow Lake Wind Farm 13
constructed by EDPR in White and Benton Counties, with the exception of 14
specifically stated conditions set out in the Commission’s declination of 15
jurisdiction orders. See In the Matter of the Petition by Meadow Lake Wind Farm 16
LLC, Cause No. 43602 (Feb. 18, 2009); In the Matter of the Petition by Meadow 17
Lake Wind Farm II LLC, Cause No. 43678 (Aug. 19, 2009); In the Matter of the 18
Petition of Meadow Lake Wind Farm III LLC, Cause No. 43759 (Nov. 24, 2009); 19
In the Matter of the Petition of Meadow Lake Wind Farm IV LLC, Cause No. 20
43758 (Nov. 24, 2009); Joint Petition of Meadow Lake Wind Farm IV LLC, 21
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 5 of 30
20604283.9
Meadow Lake Wind Farm V LLC, Cause No. 43876 (Sept. 15, 2010) and Meadow 1
Lake Wind Farm VI LLC, Cause No. 45010 (February 28, 2018) . 2
The Commission also issued orders declining much of its jurisdiction over electric 3
generating facilities proposed by other solar developers. See In the Matter of the 4
Petition by Lone Oak Solar Energy LLC, Cause No. 45255 (Oct. 29, 2019); In the 5
Matter of the Petition by Fairbanks Solar Energy Center LLC, Cause No. 45254 6
(Oct. 29, 2019); In the Matter of the Petition by Speedway Solar, LLC Cause No. 7
45230 (Sept. 18, 2019) 8
The Project is similar to these other electric generating facilities in the sense that 9
it will be a generator of electricity for sale in the wholesale power market, and it 10
represents an increase in the amount of electricity generated in Indiana. 11
Q10. Has the Commission previously declined to exercise jurisdiction over other 12
solar generation projects pursuant to Ind. Code § 8-1-2.5-5? 13
A. Yes. I identified Lone Oak Solar (Cause No. 45255), Fairbanks Solar (Cause No. 14
45254), and Speedway Solar (Cause No. 45230) previously. Like the Lone Oak 15
Solar, Fairbanks Solar, and Speedway Solar projects, the Project will generate 16
more than the 80 MW limitation set forth at Ind. Code § 8-1-2.4-5(a)(1) and will 17
not meet the definition of a “qualifying facility” under 170 IAC 4-4.1 22. As 18
previously mentioned, the nameplate capacity for the Project is 200 MW. 19
Q11. Where will the Project be located? 20
A. The Riverstart Solar Park is located approximately 25 miles southeast of Muncie, 21
Indiana, and is spread out over approximately 1,200 acres in Randolph County (an 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 6 of 30
20604283.9
additional 1,600 acres are under a lease option). A vicinity map depicting the 1
location of the Project within east-central Indiana is attached as Petitioner’s 2
Attachment RJB-1. A preliminary site map depicting the approximate facility 3
locations for the Project is attached as Petitioner’s Attachment RJB-2. 4
Q12. How will the Project generate electricity? 5
A. The Project will generate electricity via solar modules (i.e., panels) located within 6
an approximately 1,200-acre, fenced, solar panel field. The solar field will include 7
mounted PV modules and inverters that will be configured in array blocks, as well 8
as a main power transformer to transform voltage from 34.5 kV to 345 kV. The 9
PV modules will be constructed primarily of non-metallic materials such as 10
silicon, monocrystalline glass, composite film, plastic, and epoxies, with an 11
anodized aluminum frame. Each panel will measure approximately 84 inches by 12
45 inches. The PV modules will be mounted on single-axis horizontal tracker 13
mounting systems generally 6 feet off the ground. The panels, at their highest 14
point, may be up to approximately 15 feet off the ground. The module arrays will 15
be arranged in north-south oriented rows, and drive motors will rotate the 16
horizontally mounted solar panels from east to west to follow the sun (on a single 17
axis) throughout the day. The highest point for a horizontal tracker will be 18
achieved during the morning and evening hours when the trackers are tilted at 19
their maximum angle. 20
Each array block will have Power Conversion Stations (“PCS”) containing 21
inverters and medium voltage transformers as well as other electrical equipment. 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 7 of 30
20604283.9
Each PCS will also contain electrical and communication equipment to power and 1
communicate with the tracker units. All electrical equipment will be housed in 2
their respective protective enclosures on concrete pads or precast vaults, or on 3
posts. The collection system will transport the electricity from each array block to 4
an onsite substation via underground 34.5 kV cabling. From the Project’s 5
substation, the Project will be interconnected to AEP’s Losantville substation via 6
existing generator lead line running between EDPR’s Headwaters Wind Farm and 7
AEP’s Losantville Substation. The proposed Project substation, the point of 8
interconnection, and AEP’s Losantville substation are depicted in Attachment 9
RJB-2. 10
Q13. Have the component pieces to construct the Project been secured? 11
A. Petitioner has secured the tracking system and the panels. Petitioner is in the 12
process of securing the inverters. Orders for all component pieces will be made to 13
facilitate completion of construction in late 2021. 14
PROJECT SITE 15
Q14. What information or exhibits have been collected to demonstrate the 16
appropriateness of the site? 17
A. Based upon our due diligence and permitting work to date, no environmental 18
issues are foreseen that would delay or prevent the permitting and construction of 19
the Project within the timeline listed herein. Landcover and habitat mapping were 20
completed in summer 2019. Wetland and cultural investigations began in fall 21
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 8 of 30
20604283.9
2019 and will continue as the engineering for the Project is finalized. Also, 1
EDPR’s more than 10 years of experience successfully developing renewable 2
energy projects in the area informs Petitioner’s analysis. 3
Petitioner will retain KTA Associates (“KTA”) to complete a Phase I 4
Environmental Site Assessment in accordance with ASTM Standard E-1527-13. 5
Petitioner anticipates that KTA will complete its work in 2020, and Petitioner will 6
late-file the executive summary of KTA’s report in this Cause or will file it as an 7
attachment to a post-Order report. Petitioner does not believe KTA’s report will 8
identify any known, existing on-site recognized environmental conditions that 9
would require a formal cleanup under Federal or State regulatory programs or that 10
would potentially have a negative impact on the feasibility of the development of 11
the Project. Regardless, KTA’s report will be completed prior to EDPR’s 12
conversion of its lease options to leases; if a cleanup is required, the land will not 13
be leased for the Project. 14
EDPR introduced this Project to U.S. Fish and Wildlife Service (“USFWS”) and 15
Indiana Department of Natural Resources (“IDNR”) in 2019. Based on EDPR’s 16
experience in developing renewable energy projects in Indiana and the wildlife 17
studies required by USFWS and IDNR, Petitioner contracted with Ecology and 18
Environment, Inc. (“E&E”) to conduct wildlife surveys. Wildlife surveys began in 19
October 2018 with a Site Characterization Study. The Site Characterization Study 20
reviewed land use and biological resources within the Project area and a 2-mile 21
area immediately surrounding the Project. The executive summary of the Site 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 9 of 30
20604283.9
Characterization Study is attached as Petitioner’s Attachment RJB-3. As noted in 1
the Site Characterization Study, “No issues that would restrict project 2
development, construction or operation were identified during the development of 3
the site characterization study.” There are, however, federal and state protected 4
species that have the potential to occur within the Project area. In particular, the 5
Indiana bat and the northern long-eared bat have the potential to occur in the area. 6
Petitioner will coordinate with USFWS and IDNR to determine with greater 7
certainty whether appropriate habitat exists within the Project area. Should listed 8
bat species be found to occur in the Project area and that a “take” as a result of 9
tree removal associated with the Project construction is likely, Petitioner will 10
implement conservation measures such as out-of-season tree clearing. EDPR’s 11
more than 10-year track record of wind development in the Project area without 12
incident further demonstrates that EDPR develops projects in an environmentally 13
responsible manner. 14
Petitioner contracted with Westwood Professional Services, Inc., to perform a 15
geotechnical engineering report (“Geotechnical Report”) for the Project site. The 16
purposes of the Geotechnical Report were to describe subsurface conditions 17
encountered in 70 test borings and 55 test pits, analyze and evaluate the field and 18
laboratory test results, and provide design and construction recommendations with 19
respect to subsurface soil conditions, groundwater observations, seismic 20
classifications, earthwork, foundation design and construction, and contributory 21
risk components. The Geotechnical Report revealed no subsurface conditions that 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 10 of 30
20604283.9
would preclude the development of the Project. The Executive Summary of the 1
Geotechnical Report is attached as Petitioner’s Attachment RJB-4. 2
Q15. Will the Project use water and will there be any impact on local water 3
supplies? 4
A. The Project will not use water in any significant quantities, and it will have 5
negligible or no impact on local water supplies. Water will be used during 6
construction, reconstruction and removal of Project facilities, primarily for dust 7
control and concrete mixing. After construction is completed, water may be used 8
for panel washing, if necessary. 9
Q16. Will the Project have any substantial negative impact on any groundwater 10
rights and obligations, or any streams or wetlands? 11
A. No, the Project will not have any substantial negative impact on any groundwater 12
rights, streams, or wetlands. 13
14
PUBLIC UTILITY STATUS AND PERMITTING ISSUES 15
Q17. Will Petitioner qualify as a public utility under Indiana law? 16
A. The Indiana legislature has defined “public utility” to include any entity that 17
owns, operates, manages or controls any plant or equipment within the state for 18
the production of electricity. As described above, Petitioner intends to develop, 19
own, and operate an electric generating facility, so even though it does not intend 20
to sell electricity directly to retail customers, it may fall within this very broad 21
definition of “public utility” under Indiana law. As a public utility, Petitioner 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 11 of 30
20604283.9
would then also meet the definition of an “energy utility” for purposes of Ind. 1
Code § 8-1-2.5-5. This Code section permits an energy utility electing to be 2
subject to this section to request the Commission to decline to exercise its 3
jurisdiction with respect to the energy utility, which prompted the Petition in this 4
case. 5
Q18. Has Petitioner applied for and obtained, or will Petitioner apply for and 6
obtain, all necessary federal, state, and local permits needed for construction 7
and operation of the Project? 8
A. Yes. 9
Q19. What local permits are required for the Project? 10
A. County and municipal building, construction, grading, and wastewater permits are 11
required, as they apply in Randolph County. 12
Q20. Please describe the requirements of the various zoning ordinances with 13
respect to the Project facilities to be installed in Randolph County. 14
A. Randolph County is close to finalizing a solar energy ordinance that sets forth 15
specific project design and setback standards for solar energy installations. 16
Petitioner has assisted Randolph County in the development of the forthcoming 17
solar energy ordinance, and Petitioner will comply the requirements ultimately 18
included in the solar energy ordinance adopted by Randolph County. Petitioner 19
may also sign a Road Use Agreement with Randolph County, or in the alternative, 20
repair roads as part of the construction process, depending on the final terms of 21
the solar energy ordinance ultimately adopted by Randolph County. Under the 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 12 of 30
20604283.9
Road Use Agreement, Petitioner anticipates that it and Randolph County will 1
agree to a set of roads that will be utilized by the Petitioner, and Petitioner will be 2
responsible to fund any road upgrades required to deliver the solar panels and 3
associated equipment. Petitioner also anticipates that under the Road Use 4
Agreement the Petitioner will be responsible to either repair or pay for repairs 5
necessary due to Petitioner’s use of the roads. Petitioner will also enter into an 6
Economic Development Agreement with Randolph County. Petitioner 7
anticipates this agreement will be similar to the economic development 8
agreements that EDPR’s project entities Headwaters Wind Farm LLC and 9
Headwaters Wind Farm II LLC entered into with Randolph County for the 10
development of the phases of the Headwaters Wind Farm. 11
Q21. Will the Project require an Improvement Location Permit? 12
A. Yes, the Improvement Location Permit will be issued by Randolph County prior 13
to installation of solar panels and construction of Project facilities. 14
Q22. Will the Project have a decommissioning plan? 15
A. Yes. Petitioner will have its decommissioning plan approved in accordance with 16
the Randolph County zoning ordinance. 17
Q23. What is the purpose of the decommissioning plan? 18
A. The decommissioning plan provides assurance that the Project facilities are 19
properly decommissioned at the end of the Project’s useful life or upon facility 20
abandonment. Each applicant must provide a cost estimate for demolition and 21
removal of the Project facilities. To guard against the worst-case possibility that 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 13 of 30
20604283.9
the Project will be unable to meet its obligation to dismantle the solar project, a 1
decommissioning security will be established. The decommissioning security is 2
intended primarily to cover the cost of removing project infrastructure and for 3
restoring the leased premises to their original condition. Detail regarding the type 4
and amount of the security and method of calculating it will be specified in the 5
decommissioning plan. 6
Q24. What State permits are required for the Project? 7
A. State requirements for this Project include the following: 8
An NPDES general permit is required under Title 327 of the Indiana 9
Administrative Code for the discharge of construction-related storm water 10
(“Rule 5 permit”). Petitioner will submit a written construction plan to the 11
local county Soil and Water Conservation District office in Randolph County. 12
Once the plan is approved, the review has been waived, or the 28-day review 13
period has passed, Petitioner will submit a Notice of Intent to the Indiana 14
Department of Environmental Management (“IDEM”) at least 48 hours prior 15
to starting land-disturbing activities. After IDEM determines that Petitioner's 16
activity is covered by Rule 5, it will issue a notice of sufficiency to Petitioner, 17
the Notice of Intent applicant. 18
Permits, as needed, from INDOT to allow Project electric lines and other 19
facilities to cross state highways and for driveways, road exits, etc. Petitioner 20
will apply for these permits as they become necessary. 21
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 14 of 30
20604283.9
Isolated wetlands are regulated by the IDEM under the State Isolated 1
Wetlands Law and development activities conducted within the floodway of 2
any waterway of the State are regulated by the IDNR under the Flood Control 3
Act and the Floodplain Management Rule. Wetland delineations are in 4
process, but Petitioner does not currently anticipate the need for an IDEM 5
isolated wetland permit. The Petitioner intends to avoid construction activity 6
within state regulated floodways. However, if construction within floodways 7
cannot be avoided, Petitioner will obtain appropriate IDNR floodway permits, 8
if necessary for the Project. 9
Q25. What federal requirements apply to the Project? 10
A. The Project will comply with the following federal requirements: 11
Petitioner intends to self-certify as an exempt wholesale generator and apply 12
for market-based rate authority under Federal Energy Regulatory Commission 13
(“FERC”) rules and regulations. 14
Petitioner will prepare a federal spill prevention, control and countermeasure 15
(“SPCC”) plan for oil spill contingencies. 16
Development activities that affect wetlands and other waters of the U.S. in the 17
State of Indiana are regulated by the U.S. Army Corps of Engineers 18
(“USACE”). A Water Quality Certification from IDEM is also required when 19
applying for a federal permit. Based on the nature and extent of the anticipated 20
impacts to wetlands or waters of the U.S., the Project is eligible for 21
authorization under a USACE Nationwide Permit (“NWP”). Pending final 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 15 of 30
20604283.9
design, it is anticipated that the Project will be permitted under USACE 1
NWPs 12, 33, and 51. IDEM has conditionally certified all NWPs. If NWP 2
33 is used, a Pre-Construction Notification will be submitted to USACE. 3
INTERCONNECTION 4
Q26. How will the Project interconnect with the wholesale electric transmission 5
grid? 6
A. The Project is expected to interconnect with AEP’s Losantville Substation in 7
Randolph County, Indiana. Solar panels will be arranged on the Project site in the 8
form of single-axis tracking solar arrays. Structures supporting the PV modules 9
will consist of steel piles (e.g., cylindrical pipes, H-beams, or similar). The 10
proposed design is laid out primarily in approximately 2.39 MW increments 11
(blocks), each approximately 2.39 MW block will include an inverter-transformer 12
station constructed on a pad that is to be generally located on the interior 13
perimeters of each block. Cables will be installed to convey the direct current 14
(“DC”) electricity from the panels to the inverters to convert the DC to alternating 15
current (“AC”), which will then be carried to a substation located onsite, which 16
will transform the 34.5 kV collection voltage to 345 kV. From the Project’s 17
substation, the Project will be interconnected to AEP’s Losantville substation via 18
the existing Headwaters generator lead line running between the Headwaters 19
Wind Farm and the Losantville switchyard just northwest of Modoc in Randolph 20
County. 21
Q27. What studies have been done regarding the interconnection with AEP? 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 16 of 30
20604283.9
A. AEP’s transmission system is part of the wholesale power grid controlled by PJM 1
Interconnection, LLC (“PJM”). PJM studied the Project via two 100 MW queue 2
positions, AC1-174 and AC1-175. The two feasibility studies for the Project were 3
completed in April 2017 and are attached as Petitioner’s Attachment RJB-5 4
(together, the “Feasibility Study”). A System Impact Study was completed by 5
PJM for the Project in June 2018. A copy of PJM’s System Impact Study is 6
attached as Petitioner’s Attachment RJB-6. Petitioner, AEP, and PJM have not yet 7
entered into an Interconnection Services Agreement (“ISA”), as the Project is 8
currently within PJM’s Facilities Study phase. Petitioner will late-file a copy of 9
the ISA in this Cause or will file a copy as an attachment to a post-Order report. 10
Q28. Can the Project be interconnected without negatively impacting system 11
performance? 12
A. Yes. The Feasibility Study and the System Impact Study indicate that the 13
Project’s interconnection with the AEP transmission system will not negatively 14
impact system performance. 15
16
THE PROJECT WILL SERVE THE PUBLIC INTEREST 17
Q29. Is there a need for electricity generated by the Project? 18
A. Yes. Petitioner already has an off-taker for the electricity produced by the 19
Project. Hoosier Energy and Petitioner have entered into a 20-year power 20
purchase agreement for the entirety of the Project’s electrical output. 21
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 17 of 30
20604283.9
Q30. Will the development of additional generating capacity serve the public 1
interest? 2
A. Yes, the public interest will be served in a number of important respects by the 3
addition of the electric generating capacity represented by the Project. First, the 4
public needs electricity. Second, Petitioner’s proposed solar park represents one 5
of the most environmentally friendly means of generating electricity. Solar energy 6
helps reduce the negative effects of electricity generation on the environment by 7
being a source of clean power. Solar parks do not release any pollutants, such as 8
Q52. Does Petitioner also agree to the additional requirements concerning 11
material change in Project output or project modification or suspension 12
under the terms of the ISA? 13
A. Yes. Petitioner agrees to the following additional requirements: In the event that 14
Petitioner intends to materially increase or decrease or otherwise materially 15
change the Project’s capacity or operation, the owner must obtain the 16
Commission’s prior approval. Petitioner considers a material change to include an 17
increase of greater than three (3) MW in the Facility’s capacity; a change in 18
operating entities; a transfer of assets; and changes identified in subsequent case 19
law as constituting a material change. Petitioner will notify the Commission in the 20
event that it modifies or suspends the Project under the terms of the ISA and does 21
not reinstitute work within three (3) years following commencement of such 22
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 28 of 30
20604283.9
suspension. In the event of a proposed increase greater than 3MW, the Petitioner 1
will provide the Commission with at least thirty (30) days’ notice prior to the 2
increase. If the Commission determines that the Petitioner has (a) failed to enter 3
into an agreement pursuant to PJM’s generator interconnection procedures; (b) 4
suspended the project under the terms of the ISA and has not reinstated work 5
within three (3) years following commencement of such suspension; or (c) has 6
otherwise suspended its efforts to complete the Project within three (3) years of its 7
Order, the Commission may, following notice to the Petitioner, proceed to issue 8
an Order terminating the declination of jurisdiction set forth herein. 9
Q53. Does this conclude your direct testimony? 10
A. Yes, it does. 11
45336
VERIFICATION
Riverstart Solar Park LLC IURC Cause No .. __ _
Petitioner's Exhibit I Page 29 of30
I hereby verify under the penalties of perjury that the foregoing representations are true to
the best of my knowledge, information, and belief.
20604283.9
Riverstart Solar Park LLC IURC Cause No. 45336
Petitioner’s Exhibit 1 Page 30 of 30
20604283.9
LIST OF ATTACHMENTS FOR VERIFIED DIRECT TESTIMONY OF RYAN J. BROWN
Attachment RJB-1 Vicinity Map Attachment RJB-2 Preliminary Site Map Attachment RJB-3 Site Characterization Study Executive Summary Attachment RJB-4 Geotechnical Report Executive Summary Attachment RJB-5 Feasibility Study Attachment RJB-6 System Impact Study Attachment RJB-7 Resolution of Randolph County Commissioners Supporting
Renewable Energy Projects Attachment RJB-8 Resolution of Randolph County Council Supporting
Renewable Energy Projects Attachment RJB-9 EDP Renováveis’ 2018 Annual Report
Losantville
Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c) OpenStreetMap contributors, and the GIS User Community, Source: Esri, DigitalGlobe, GeoEye, EarthstarGeographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community
Ecology and Environment, Inc. was contracted by EDP Renewables North America to conduct a site characterization study for the Riverstart Solar Park.Ecology and Environment, Inc., reviewed land use, biological, and culturalresources within the Riverstart Solar Park project area, and a 2-mile buffer of the project boundary (collectively, the Evaluation Area). The proposed Riverstart Solar Park Evaluation Area is located in Randolph County, Indiana, and encompasses 24,907 acres (39 square miles).
Desktop review methodology included assessing publicly available geographic information system datasets and summarizing the findings for each subject within the geographic limits of the Evaluation Area. Information obtained from publicly available government websites was also used to supplement the geographic infor-mation system data.
No issues that would restrict project development, construction, or operation were identified during the development of the site characterization study. There are federal and state threatened and endangered species that have the potential to occur within or in proximity to the Riverstart Solar Park, and coordination with the U.S. Fish and Wildlife Service and the Indiana Department of Natural Resources may be warranted to better understand concerns regarding the potential impacts to these species or their habitats. Species of potential concern include the Indiana bat (Myotis sodalis) and the northern long-eared bat (Myotis septentrionalis). Two architectural resources noted in a Randolph County survey as having the potential to be eligible for listing in the National Register of Historic Places (i.e., rated “outstanding”) are located within the Evaluation Area, and may warrant discussion with the U.S. Army Corps of Engineers and the Indiana Department of Natural Resources, Division of Historic Preservation and Archaeology.
The information presented in this report may be used for planning purposes dur-ing project development. Prior to project development, it is advisable that the information in this report be verified through more comprehensive on-site investi-gations to ensure compliance with all applicable local, state, or federal permit authorities.
Riverstart Solar Park LLC Cause No. 45336
Attachment RJB-3 Page 002
Riverstart Solar Project (Phase I) Geotechnical Investigation Report
Randolph County, Indiana
September 17, 2019
Prepared By:
Prepared For:
Riverstart Solar Park LLC Cause No. 45336
Attachment RJB-4 Page 001
Westwood '$ renewobles
Geotechnical Investigation Report – Riverstart Solar Project (Phase I)
1.0 EXECUTIVE SUMMARY
Westwood Professional Services (Westwood) is pleased to present this geotechnical investigation report to EDP Renewables (EDPR) for the proposed Phase 1 of the Riverstart Solar Project located in Randolph County, Indiana. The scope of work for this investigation included subsurface exploration, field and laboratory testing, pile load testing, engineering analysis, and preparation of this report. The geotechnical investigation has generally revealed no subsurface conditions that would preclude development of the proposed solar energy facility. Based on the information obtained from 70 soil borings performed on site to a target depth of 20 feet and 55 test pits excavated to depths of 6 to 8 feet, the subsurface conditions typically consist of approximately 6 to 14 inches of topsoil overlying very soft to hard clay with varying amounts of silt, sand, and gravel. Occasionally interbedded within the clayey units were layers of poorly to well graded sand with varying amounts of clay, silt, and gravel. These sand layers were generally 2 to 8 feet thick, although some extended beyond the target depth. During test pit excavations, trace to few cobbles and boulders were occasionally encountered within the clay and sand, indicative of glacial erratics often found in till. Shallow auger or bucket refusal was not encountered at any of the boring or test pit locations. Groundwater was encountered during drilling at 36 of the 70 boring locations between 3 to 17 feet below ground surface (bgs), and in 26 of the 55 test pits between 4 and 8 feet bgs. The site is mapped within geologic units that have potential for karst formation; however, limestone bedrock is expected to be deep (> 100 ft bgs) and the overall potential for karst features to develop on site is considered low. A detailed karst investigation is beyond the scope of this investigation. Driven pile foundations typically used to support the photovoltaic (PV) racking systems are feasible for this site; however, shallow refusal may occur at isolated locations on site due to glacial erratic boulders and cobbles. Special considerations should also be given to the high potential for frost heave, as the fine‐grained soils have high frost susceptibility and foundation may be at risk of heaving during winter months if not properly designed. Shallow foundations are also generally feasible to support electrical infrastructure and other associated project structures, although the shallow clay on site may be soft and frost susceptible, and the subgrade below shallow foundations should be over‐excavated and prepared in accordance with the recommendations provided in this report.
This executive summary should be read in context of the entire report for full understanding of the subsurface conditions encountered, as well as design and construction recommendations.
Riverstart Solar Park LLC Cause No. 45336
Attachment RJB-4 Page 002
Westwood
Generation Interconnection Feasibility Study Report
Preface The intent of the feasibility study is to determine a plan, with ballpark cost and construction time estimates, to connect the subject generation to the PJM network at a location specified by the Interconnection Customer. The Interconnection Customer may request the interconnection of generation as a capacity resource or as an energy-only resource. As a requirement for interconnection, the Interconnection Customer may be responsible for the cost of constructing: (1) Direct Connections, which are new facilities and/or facilities upgrades needed to connect the generator to the PJM network, and (2) Network Upgrades, which are facility additions, or upgrades to existing facilities, that are needed to maintain the reliability of the PJM system.
In some instances a generator interconnection may not be responsible for 100% of the identified network upgrade cost because other transmission network uses, e.g. another generation interconnection, may also contribute to the need for the same network reinforcement. The possibility of sharing the reinforcement costs with other projects may be identified in the feasibility study, but the actual allocation will be deferred until the impact study is performed.
The Feasibility Study estimates do not include the feasibility, cost, or time required to obtain property rights and permits for construction of the required facilities. The project developer is responsible for the right of way, real estate, and construction permit issues. For properties currently owned by Transmission Owners, the costs may be included in the study.
General Riverstart Solar Park, LLC (Riverstart Solar) proposes to install PJM Project #AC1-174, a 100.0 MW (38.0 MW Capacity) solar generating facility in Losantville, IN (see Figure 2). The point of interconnection will be a direct connection to AEP’s Losantville 345 kV substation (see Figure 1).
The requested in service date is November 30, 2019.
Attachment Facilities Point of Interconnection (Losantville 345 kV Substation) To accommodate the interconnection at the Losantville 345 kV substation, the substation will have to be expanded requiring the installation of two (2) 345 kV circuit breakers, and starting a new string (see Figure 1). Installation of associated protection and control equipment, 345 kV line risers, SCADA, and 345 kV revenue metering will also be required. Losantville Station Work: Expand the Losantville 345 kV substation, start a new string, and install two (2) 345 kV
circuit breakers (see Figure 1). Installation of associated protection and control equipment, 345 kV line risers, SCADA, and 345 kV revenue metering will also be required. Estimated Station Cost: $3,000,000
Non-Direct Connection Cost Estimate The total preliminary cost estimate for Non-Direct Connection work is given in the following tables below:
For AEP building Direct Connection cost estimates:
Description Estimated Cost
345 kV Revenue Metering $400,000 Upgrade line protection and controls at the expanded Losantville 345 kV substation.
$400,000
Upgrade line protection and control settings at the Desoto 345 kV substation to coordinate with the expanded Losantville 345 kV substation.
$50,000
Upgrade line protection and control settings at the Tanners Creek 345 kV substation to coordinate with the expanded Losantville 345 kV substation.
Table 1 It is understood that Riverstart Solar is responsible for all costs associated with this interconnection. The cost of Riverstart Solar’s generating plant and the costs for the line connecting the generating plant to Riverstart Solar’s switching station are not included in this report; these are assumed to be Riverstart Solar’s responsibility.
The Generation Interconnection Agreement does not in or by itself establish a requirement for American Electric Power to provide power for consumption at the developer's facilities. A separate agreement may be reached with the local utility that provides service in the area to ensure that infrastructure is in place to meet this demand and proper metering equipment is installed. It is the responsibility of the developer to contact the local service provider to determine if a local service agreement is required.
Interconnection Customer Requirements Requirement from the PJM Open Access Transmission Tariff:
1. An Interconnection Customer entering the New Services Queue on or after October 1, 2012 with a proposed new Customer Facility that has a Maximum Facility Output equal to or greater than 100 MW shall install and maintain, at its expense, phasor measurement units (PMUs). See Section 8.5.3 of Appendix 2 to the Interconnection Service Agreement as well as section 4.3 of PJM Manual 14D for additional information.
2. The Interconnection Customer may be required to install and/or pay for metering as necessary to properly track real time output of the facility as well as installing metering which shall be used for billing purposes. See Section 8 of Appendix 2 to the Interconnection Service Agreement as well as Section 4 of PJM Manual 14D for additional information.
Revenue Metering and SCADA Requirements
PJM Requirements The Interconnection Customer will be required to install equipment necessary to provide Revenue Metering (KWH, KVARH) and real time data (KW, KVAR) for IC’s generating Resource. See PJM Manuals M-01 and M-14D, and PJM Tariff Sections 24.1 and 24.2.
AEP Requirements The Interconnection Customer will be required to comply with all AEP Revenue Metering Requirements for Generation Interconnection Customers. The Revenue Metering Requirements may be found within the “Requirements for Connection of New Facilities or Changes to Existing Facilities Connected to the AEP Transmission System” document located at the following link:
The Queue Project AC1-174 was evaluated as a 100.0 MW (Capacity 38.0 MW) injection at the Losantville 345kV substation in the AEP area. Project AC1-174 was evaluated for compliance with applicable reliability planning criteria (PJM, NERC, NERC Regional Reliability Councils, and Transmission Owners). Project AC1-174 was studied with a commercial probability of 53%. Potential network impacts were as follows:
Base Case Used Summer Peak Analysis – 2020 Case
Contingency Descriptions The following contingencies resulted in overloads:
Option 1
Contingency Name Description
8823
CONTINGENCY '8823' OPEN BRANCH FROM BUS 243218 TO BUS 243232 CKT 2 / 243218 05DESOTO 345 243232 05SORENS 345 2 OPEN BRANCH FROM BUS 243225 TO BUS 243232 CKT 1 / 243225 05KEYSTN 345 243232 05SORENS 345 1 END
3027_C2
CONTINGENCY '3027_C2' OPEN BRANCH FROM BUS 243233 TO BUS 249567 CKT 1 / 243233 05TANNER 345 249567 08M.FTHS 345 1 OPEN BRANCH FROM BUS 243233 TO BUS 254524 CKT 1 / 243233 05TANNER 345 254524 16HANNA 345 1 OPEN BRANCH FROM BUS 243233 TO BUS 243382 CKT 5 / 243233 05TANNER 345 243382 05TANNER 138 5 END
678_B3_05TANNER 345-5
CONTINGENCY '678_B3_05TANNER 345-5' OPEN BRANCH FROM BUS 243233 TO BUS 249567 CKT 1 / 243233 05TANNER 345 249567 08M.FTHS 345 1 OPEN BRANCH FROM BUS 243233 TO BUS 243382 CKT 5 / 243233 05TANNER 345 243382 05TANNER 138 5 END
8702_B2_TOR2543
CONTINGENCY '8702_B2_TOR2543' OPEN BRANCH FROM BUS 243218 TO BUS 243232 CKT 2 / 243218 05DESOTO 345 243232 05SORENS 345 2 END
P1-#..B2 TERMINAL-EAST BEND 4516
CONTINGENCY 'P1-#..B2 TERMINAL-EAST BEND 4516' OPEN BRANCH FROM BUS 249575 TO BUS 249565 CKT 1 END
kV line 243792 243218 2 DC 89.55 96.08 ER 1166 76.13 2
Table 3
Contribution to Previously Identified Overloads (This project contributes to the following contingency overloads, i.e. "Network Impacts", identified for earlier generation or transmission interconnection projects in the PJM Queue)
Note: Please see Appendices for projects providing impacts to flowgate violations. The values in the Reference column correspond to the proper table in the Appendix.
None
Steady-State Voltage Requirements
None
Short Circuit (Summary of impacted circuit breakers)
LGEE Impacts to be determined during later study phases (as applicable). MISO Impacts: MISO Impacts to be determined during later study phases (as applicable). Duke, Progress & TVA Impacts: Duke Carolina, Progress, & TVA Impacts to be determined during later study phases (as applicable). OVEC Impacts: OVEC Impacts to be determined during later study phases (as applicable).
Delivery of Energy Portion of Interconnection Request PJM also studied the delivery of the energy portion of this interconnection request. Any problems identified below are likely to result in operational restrictions to the project under study. The developer can proceed with network upgrades to eliminate the operational restriction at their discretion by submitting a Merchant Transmission Interconnection request.
Note: Only the most severely overloaded conditions are listed below. There is no guarantee of full delivery of energy for this project by fixing only the conditions listed in this section. With a Transmission Interconnection Request, a subsequent analysis will be performed which shall study all overload conditions associated with the overloaded element(s) identified.
AC1-174 Delivery of Energy Portion of Interconnection Request
Contingency Affected
Area Facility
Description
Bus
Cir. PF
Loading Rating MW Con.
FG App. # Type Name From To Initial Final Type MVA
1 N-1 8702_B2_TOR2543 AEP - AEP
05KEYSTN-05SORENS 345
kV line 243225 243232 1 DC 107.08 109.49 NR 897 21.59
2 N-1
P1-#..B2 TERMINAL-EAST
BEND 4516 AEP -
DEO&K
05TANNER-08M.FORT 345
kV line 243233 249567 1 DC 140.3 140.91 NR 1409 19.96
New System Reinforcements # Overloaded Facility Upgrade Description Schedule Estimated Cost
#1
05DESOTO-05JAY 138 kV line
Replace the Jay breaker G (1200A) Replace the Jay Switch (1200A)
Replace Jay Riser (1590 AAC 61 Str.) Replace the Jay Bus (1590 AAC 61 Str.)
Replace the Desoto Switch (1200A)
The Jay Area Improvements project will replace the limiting elements identified above.
Work to be completed May 2017 N/A
#2 05LOSANTVILL-05DESOTO 345 kV line
A sag check will be required for the ACAR ~ 2303.5 ~ 54/7 ~ Conductor Section 1 to determine if the line section can be operated
above its emergency rating of 1166 MVA. The result could prove that no additional upgrades are necessary, that some upgrades on the circuit are necessary, or that the entire 14 mile section of line would need to be
rebuilt.
Sag Study: 6 to 12 months. Rebuild/Reconductor: The standard time required for construction differs from state to state. An approximate construction time would be 36 to 48 months after signing an interconnection agreement.
$56,000
Total New Network Upgrades $56,000
Table 5 Schedule
It is anticipated that the time between receipt of executed agreements and Commercial Operation may range from 12 to 18 months if no line work is required. If line work is required, construction time would be between 24 to 36 months after signing an interconnection agreement.
Note: The time provided between anticipated normal completion of System Impact, Facilities Studies, subsequent execution of ISA and ICSA documents, and the proposed Backfeed Date is shorter than usual and may be difficult to achieve.
Conclusion
Based upon the results of this Feasibility Study, the construction of the 100.0 MW (38.0 MW Capacity) solar generating facility of Riverstart Solar (PJM Project #AC1-174) will require the following additional interconnection charges. This plan of service will interconnect the proposed solar generating facility in a manner that will provide operational reliability and flexibility to both the AEP system and the Riverstart Solar generating facility.
Cost Breakdown for Point of Interconnection (Losantville 345 kV Substation) Attachment Cost Expand Losantville 345 kV Substation $3,000,000
Non-Direct Connection Cost Estimate
345 kV Revenue Metering $400,000
Upgrade line protection and controls at the expanded Losantville 345 kV substation.
$400,000
Upgrade line protection and control settings at the Desoto 345 kV substation to coordinate with the expanded Losantville 345 kV substation.
$50,000
Upgrade line protection and control settings at the Tanners Creek 345 kV substation to coordinate with the expanded Losantville 345 kV substation.
A sag check will be required for the ACAR ~ 2303.5 ~ 54/7 ~ Conductor Section 1 to determine if the line section can
be operated above its emergency rating of 1166 MVA. The result could prove that no additional upgrades are necessary, that some upgrades on the circuit are necessary, or that the
entire 14 mile section of line would need to be rebuilt.
$56,000
Total Estimated Cost for Project AC1-174 $3,956,000
Table 6 The estimates are preliminary in nature, as they were determined without the benefit of detailed engineering studies. The cost of remediation for sag limited conductors is not included in this estimate. Final estimates will require an on-site review and coordination to determine final construction requirements.
Preface The intent of the feasibility study is to determine a plan, with ballpark cost and construction time estimates, to connect the subject generation to the PJM network at a location specified by the Interconnection Customer. The Interconnection Customer may request the interconnection of generation as a capacity resource or as an energy-only resource. As a requirement for interconnection, the Interconnection Customer may be responsible for the cost of constructing: (1) Direct Connections, which are new facilities and/or facilities upgrades needed to connect the generator to the PJM network, and (2) Network Upgrades, which are facility additions, or upgrades to existing facilities, that are needed to maintain the reliability of the PJM system.
In some instances a generator interconnection may not be responsible for 100% of the identified network upgrade cost because other transmission network uses, e.g. another generation interconnection, may also contribute to the need for the same network reinforcement. The possibility of sharing the reinforcement costs with other projects may be identified in the feasibility study, but the actual allocation will be deferred until the impact study is performed.
The Feasibility Study estimates do not include the feasibility, cost, or time required to obtain property rights and permits for construction of the required facilities. The project developer is responsible for the right of way, real estate, and construction permit issues. For properties currently owned by Transmission Owners, the costs may be included in the study.
General Riverstart Solar Park II, LLC (Riverstart Solar) proposes to install PJM Project #AC1-175, a 100.0 MW (38.0 MW Capacity) solar generating facility in Losantville, IN (see Figure 2). The point of interconnection will be a direct connection to AEP’s Losantville 345 kV substation utilizing the Generator Lead that will be constructed for PJM Project #AC1-174 (see Figure 1).
The requested in service date is November 30, 2019.
Attachment Facilities Point of Interconnection (Losantville 345 kV Substation) It is assumed that PJM Project AC1-174 will pay for the necessary direct connection work required to connect to the Losantville 345 kV substation (see Figure 1). In the event that AC1-175 proceeds without AC1-174, the Attachment Facilities estimates provided in the AC1-174 report would apply for AC1-175. It is understood that Riverstart Solar is responsible for all costs associated with this interconnection. The cost of Riverstart Solar’s generating plant and the costs for the line connecting the generating plant to Riverstart Solar’s switching station are not included in this report; these are assumed to be Riverstart Solar’s responsibility.
The Generation Interconnection Agreement does not in or by itself establish a requirement for American Electric Power to provide power for consumption at the developer's facilities. A separate agreement may be reached with the local utility that provides service in the area to ensure that infrastructure is in place to meet this demand and proper metering equipment is installed. It is the responsibility of the developer to contact the local service provider to determine if a local service agreement is required.
Interconnection Customer Requirements Requirement from the PJM Open Access Transmission Tariff:
1. An Interconnection Customer entering the New Services Queue on or after October 1, 2012 with a proposed new Customer Facility that has a Maximum Facility Output equal to or greater than 100 MW shall install and maintain, at its expense, phasor measurement units (PMUs). See Section 8.5.3 of Appendix 2 to the Interconnection Service Agreement as well as section 4.3 of PJM Manual 14D for additional information.
2. The Interconnection Customer may be required to install and/or pay for metering as necessary to properly track real time output of the facility as well as installing metering which shall be used for billing purposes. See Section 8 of Appendix 2 to the Interconnection Service Agreement as well as Section 4 of PJM Manual 14D for additional information.
PJM Requirements The Interconnection Customer will be required to install equipment necessary to provide Revenue Metering (KWH, KVARH) and real time data (KW, KVAR) for IC’s generating Resource. See PJM Manuals M-01 and M-14D, and PJM Tariff Sections 24.1 and 24.2.
AEP Requirements The Interconnection Customer will be required to comply with all AEP Revenue Metering Requirements for Generation Interconnection Customers. The Revenue Metering Requirements may be found within the “Requirements for Connection of New Facilities or Changes to Existing Facilities Connected to the AEP Transmission System” document located at the following link:
The Queue Project AC1-175 was evaluated as a 100.0 MW (Capacity 38.0 MW) injection at the Losantville 345kV substation in the AEP area. Project AC1-175 was evaluated for compliance with applicable reliability planning criteria (PJM, NERC, NERC Regional Reliability Councils, and Transmission Owners). Project AC1-175 was studied with a commercial probability of 53%. Potential network impacts were as follows:
Base Case Used Summer Peak Analysis – 2020 Case
Contingency Descriptions The following contingencies resulted in overloads:
Option 1
Contingency Name Description
8823
CONTINGENCY '8823' OPEN BRANCH FROM BUS 243218 TO BUS 243232 CKT 2 / 243218 05DESOTO 345 243232 05SORENS 345 2 OPEN BRANCH FROM BUS 243225 TO BUS 243232 CKT 1 / 243225 05KEYSTN 345 243232 05SORENS 345 1 END
3027_C2
CONTINGENCY '3027_C2' OPEN BRANCH FROM BUS 243233 TO BUS 249567 CKT 1 / 243233 05TANNER 345 249567 08M.FTHS 345 1 OPEN BRANCH FROM BUS 243233 TO BUS 254524 CKT 1 / 243233 05TANNER 345 254524 16HANNA 345 1 OPEN BRANCH FROM BUS 243233 TO BUS 243382 CKT 5 / 243233 05TANNER 345 243382 05TANNER 138 5
CONTINGENCY '678_B3_05TANNER 345-5' OPEN BRANCH FROM BUS 243233 TO BUS 249567 CKT 1 / 243233 05TANNER 345 249567 08M.FTHS 345 1 OPEN BRANCH FROM BUS 243233 TO BUS 243382 CKT 5 / 243233 05TANNER 345 243382 05TANNER 138 5 END
8702_B2_TOR2543
CONTINGENCY '8702_B2_TOR2543' OPEN BRANCH FROM BUS 243218 TO BUS 243232 CKT 2 / 243218 05DESOTO 345 243232 05SORENS 345 2 END
P1-#..B2 TERMINAL-EAST BEND 4516
CONTINGENCY 'P1-#..B2 TERMINAL-EAST BEND 4516' OPEN BRANCH FROM BUS 249575 TO BUS 249565 CKT 1 END
Table 1
Generator Deliverability (Single or N-1 contingencies for the Capacity portion only of the interconnection)
None
Multiple Facility Contingency (Double Circuit Tower Line, Fault with a Stuck Breaker, and Bus Fault contingencies for the full energy output)
AC1-175 Multiple Facility Contingency
Contingency
Affected Area Facility Description
Bus
Cir. PF
Loading Rating MW Con.
FG App. # Type Name From To Initial Final Type MVA
Contribution to Previously Identified Overloads (This project contributes to the following contingency overloads, i.e. "Network Impacts", identified for earlier generation or transmission interconnection projects in the PJM Queue)
Note: Please see Appendices for projects providing impacts to flowgate violations. The values in the Reference column correspond to the proper table in the Appendix.
AC1-175 Contributions to Previously Identified Overloads
Contingency
Affected Area Facility Description
Bus
Cir. PF
Loading Rating MW Con.
FG App. # Type Name From To Initial Final Type MVA
1 DCTL 8823 AEP - AEP 05DESOTO-05JAY 138 kV line 243278 243319 1 DC 100.6 101.45 ER 393 7.43 1
Table 3
Steady-State Voltage Requirements None
Short Circuit (Summary of impacted circuit breakers)
New circuit breakers found to be over-duty:
None
Delivery of Energy Portion of Interconnection Request PJM also studied the delivery of the energy portion of this interconnection request. Any problems identified below are likely to result in operational restrictions to the project under study. The developer can proceed with network upgrades to eliminate the operational restriction at their discretion by submitting a Merchant Transmission Interconnection request.
Note: Only the most severely overloaded conditions are listed below. There is no guarantee of full delivery of energy for this project by fixing only the conditions listed in this section. With a Transmission Interconnection Request, a subsequent analysis will be performed which shall study all overload conditions associated with the overloaded element(s) identified.
AC1-175 Delivery of Energy Portion of Interconnection Request
Contingency Affected
Area Facility
Description
Bus
Cir. PF
Loading Rating MW Con.
FG App. # Type Name From To Initial Final Type MVA
1 N-1 8702_B2_TOR2543 AEP - AEP
05KEYSTN-05SORENS 345
kV line 243225 243232 1 DC 109.49 111.9 NR 897 21.59
2 N-1
P1-#..B2 TERMINAL-EAST
BEND 4516 AEP -
DEO&K
05TANNER-08M.FORT 345
kV line 243233 249567 1 DC 140.91 141.51 NR 1409 19.96
3 N-1 678_B3_05TANNER
345-5 AEP - AEP
05LOSANTVILL-05DESOTO 345
kV line 243792 243218 2 DC 97.13 104.61 NR 1016 76
LGEE Impacts: LGEE Impacts to be determined during later study phases (as applicable). MISO Impacts: MISO Impacts to be determined during later study phases (as applicable). Duke, Progress & TVA Impacts: Duke Carolina, Progress, & TVA Impacts to be determined during later study phases (as applicable). OVEC Impacts: OVEC Impacts to be determined during later study phases (as applicable).
Replace the Jay breaker G (1200A) Replace the Jay Switch (1200A)
Replace Jay Riser (1590 AAC 61 Str.) Replace the Jay Bus (1590 AAC 61 Str.)
Replace the Desoto Switch (1200A)
The Jay Area Improvements project will replace the limiting elements identified above.
Work to be completed May 2017 N/A
#2 05LOSANTVILL-05DESOTO 345 kV line
A sag check will be required for the ACAR ~ 2303.5 ~ 54/7 ~ Conductor Section 1 to determine if the line section can be operated
above its emergency rating of 1166 MVA. The result could prove that no additional upgrades are necessary, that some upgrades on the circuit are necessary, or that the entire 14 mile section of line would need to be
rebuilt.
Sag Study: 6 to 12 months. Rebuild/Reconductor: The standard time required for construction differs from state to state. An approximate construction time would be 36 to 48 months after signing an interconnection agreement.
It is anticipated that the time between receipt of executed agreements and Commercial Operation may range from 12 to 18 months if no line work is required. If line work is required, construction time would be between 24 to 36 months after signing an interconnection agreement.
Note: The time provided between anticipated normal completion of System Impact, Facilities Studies, subsequent execution of ISA and ICSA documents, and the proposed Backfeed Date is shorter than usual and may be difficult to achieve.
Conclusion
Based upon the results of this Feasibility Study, the construction of the 100.0 MW (38.0 MW Capacity) solar generating facility of Riverstart Solar (PJM Project #AC1-175) will require the following additional interconnection charges. This plan of service will interconnect the proposed solar generating facility in a manner that will provide operational reliability and flexibility to both the AEP system and the Riverstart Solar generating facility.
Cost Breakdown for Point of Interconnection (Losantville 345 kV Substation)
Attachment Cost PJM Project AC1-174 is expected to pay for the necessary direct connection work required to connect to the Losantville 345 kV substation (see Figure 1).
N/A
Non-Direct Connection Cost Estimate
345 kV Revenue Metering to be installed by PJM Project AC1-174. N/A
A sag check will be required for the ACAR ~ 2303.5 ~ 54/7 ~ Conductor Section 1 to determine if the line section can
be operated above its emergency rating of 1166 MVA. The result could prove that no additional upgrades are necessary, that some upgrades on the circuit are necessary, or that the
entire 14 mile section of line would need to be rebuilt.
$56,000
Total Estimated Cost for Project AC1-175 $56,000
Table 6 The estimates are preliminary in nature, as they were determined without the benefit of detailed engineering studies. The cost of remediation for sag limited conductors is not included in this estimate. Final estimates will require an on-site review and coordination to determine final construction requirements.