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HomeMy WebLinkAbout20050831Comments.pdf~.; .If'. ItJJ. /fo ~ q fL D jJ JJJ r; ff~ ~ EA JvJ~~ ~ , U- J;r~S/jr~ k~ lP/A.,C!-, ' ~,, ~1~ fw-, Pc -f- "Q"- .2:t ~ . YU- fi! 19 fiJ- 0 I . -I- JJ..../-J! /J -0. ~:' ~l :L.JFi ,",. i: ~ . Mtfl.. I. r C. -Mt ~. J;iiIV)1 -tt.. -l-l IV /1-; A~" f~ ~ ;;' J i " " (l), /IUL '-'V~r~t~::"' ~ ~., t "-1- ~c-' . "~- '.l, 0 a..-u ' ,' '::",:", ;2;;,, , '~).' .' ', , 6.l'J-zJ~0 ~ 0 ' " ,, ' 0;-. ~~ ;;:;::::::~U 0 " , ,~"') ", '.. -, ' --' '---- , ' Z:,h/~ ()... 001 3 0 13 J J-rk... ?:3 3 /(". .."", ' Rug 30 05 04: 05p ~~O 12085299210Ho 1 den - McCart~ Insurance v ~ f\,iJ../1u August 30, 2005 Schvvendill1an \Vind LLC 9633 East Highway 33 Newdale, Idaho 83436. A9&~Idaho Public Utilities Commission 472 W. W ~shington Boise, Idaho 83702 FAX: 208-334-3762 Dear Coffilnissioners This letter is to voice our opinion that Windland Inc.s request for a Stay and subsequent Reconsideration Petition on your order number 29839 are both inappropriate and presumpJuous. We strongly support your decision to preserve at least a few projects as you grant Idaho Power s request for a Illoratorium on new projects and evellillore so when this is extended across Idaho. We also strongly feel that such a decision \vas \-yell \vithin your authority and 'A'as very appropriate. That decision is of course crucial to our project and we appreciate the opportunity to follo\v through with all of the CO111111itn1ents ve lnade ard the investment we have in this project to date. We have worked long and hard to get our project to the point \ve are now ready to dig holes and pour concrete. Our turbines are scheduled for delivery and our contract is poised for approval. Pacificorp is ready to start construction on their part of the project also. We may not be done in 2005 like vve hoped, but ",,-e'll be under construction next month and willbe done in the first quarter of next year. We feel that our project is exactly \vhat PURPA was designed for and feel that we are perfectly in line vvith the IPUC rulings and orders to date, Our project has drrunatically evolved into an excellent generation resource and will be significant in this area. -.,., f-'" i~::ti?. (j) ('"') -., S~(: :~i,F::;: ","01;" .,,;,-p. . -- """, c:;:' ::;,, ,. c:.:.:::, (;',.)'","" ; ,".'.'" f;_ ~~~; :T~.':;:, c=~ G"' ",,~:.: W,) ~!1'1 ""'",".....:!;:,. f~:J C~:J: AJ'- " ~ t1() A.II. .//0 ~13I 0 Schroeder Wind Farm Development Project August 30, 2005 cfj'b-2-3'; ~ ~&/ Z:~ ~~:::; )A '-" n - ~~ ~ i~"' ;-'~.:'~:;:~;::: (, " 1;:-\ :::.". Mark Schroeder Schroeder Wind Farm 3 74 East 5400 North Hagerman, Idaho 83332 ~_. ",,!e::: Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702 ,."..," (j)C)(I) (;!). .;""""""\ C~J -"" RE: Response to Windland, Inc. Petition for Reconsideration and Motion to Stay on IPUC Dear Commissioners: This letter is to thank you for your consideration for grandfathering status of projects already committed to development in Order 29839 which limits PURP A project sizes. My project is the result of long, tedious, and expensive efforts to build a wind project against what I felt were great odds. I am simply an Idaho farmer who became enamored with wind many years ago. I put up the first anemometer in the Bell Rapids area and would already have a project built if I had been willing to simply sell the rights instead of holding out to be a true development partner in the creation of something meaningful. The following was taken from the IPUC website, Order 29838: Accordingly, this Commission finds it reasonable to establish the following criteria to determine the eligibility of PURP A qualifying wind generating facilities for contracts at the ORDER NO. 29839 published avoided cost rates. For purposes of determining eligibility we find it reasonable to use the date of the Commission Notice in this case, i.e., July 2005. For those QF projects in the negotiation queue on that date the criteria that we will look at to determine project eligibility are: (1) submittal of a signed power purchase agreement to the utility, or (2) submittal to the utility of a completed Application for Interconnection Study and payment of fee. In addition to a finding of existence of one or both of the preceding threshold criteria, the QF must also be able to demonstrate other indicia of substantial progress and project maturity, g. , (1) a wind study demonstrating a viable site for the project, (2) signed contract for wind turbines, (3) arranged financing for the project, and/or (4) related progress on the facility permitting and licensing path. Letter Regarding Grandfathering Rights to Wind Projects Schroeder Wind Farm Development Project I clearly qualify for the grandfathering status as granted in Order 29839 and thus have a lot to lose if that is not preserved. (1) submittal of a signed power purchase agreement to the utility, or (2) submittal to the utility of a completed Application for Interconnection Study and payment of fee. I submitted my request for interconnection early in June this year. In addition to a finding of existence of one or both of the preceding threshold criteria, the QF must also be able to demonstrate other indicia of substantial progress and project maturity, e. g. , (1) a wind study demonstrating a viable site for the project... I have done extensive wind studies myself and as part of the Bell Rapids Irrigation District over several years. In addition to meeting the criteria set forth in your order, I have made the following progress on my project. I hired Brian Jackson with Renaissance Engineering in May of 2005 to get my project back on track. By June he had connected me with turbines and we had filed our interconnection request. Since then I have signed agreements with developers who have turbines available both in 2005 and 2006. All I need now is a power-purchase agreement from Idaho Power and I will be ready to build my project. After over 4 years of work all of the pieces of my project's puzzle finally came together in June. Then Idaho Power muddied up the waters with their moratorium request. This year has been a roller coaster ride, what with selling my Bell Rapids water rights and all of the questions about my wind project possibilities. I hope that we can finally put these questions to rest and I can get my project built. I am including a copy of a letter that I sent to Mr. Allphin at Idaho Power requesting that they prepare a draft Power Purchase Agreement which I can sign. I am also including a letter from Mr. Jackson at Renaissance Engineering which describes the wind analysis done on my property. Given all of the time, effort and money that I have put into this wind project, I am very happy that your commission has established grandfathering rules which will keep my project alive. Letter Regarding Grandfathering Rights to Wind Projects Schroeder Wind Farm Development Project Again, I respectfully ask 1pfIt you maintain the grandfathering position you included in the Order No. 29839. I feel it is the minimum which at least lets the existing projects like mine which have so much work inv~ proceed with deveLopment Sincerely, Mark Schroeder Letter Regarding Grandfatbcring Rights to Wind Projecb Mark Schroeder Schroeder Wind F ann 374 East 5400 North Hagcnnan, Idaho 83332 August l~ ,. 2005 Idaho Power C:ompany PO BOX 10 Boise, Idaho 83707 Attn: Randy Allphin RE: Wind Farm Power Purchase A&reement. Dear Mr. Allphin; Ibis leUet is to documen1 .my position and situation rcgardi11~ the grandfathering statUS under theIPUC Order 29839 which lists th~ reasonable requirements to grunt my project a Power PurchaseAgreement. I have been tryiftg to get a wind farm 'on my property since 200111Dd was finally ma.1c.in& progress this spring to the point where I have inveStment arade data on my specific property and nearby lona term reference: data. I have: been negotiating with lOIDeone who ha.$ tllfbines andmoney to put the project together. I have been trying 'to get the interconnection study done: aft~applying this spring. I have invested thousands of doners personally and IS part of Bell Rapids Mutuallrri.gauonCompany just ih wind data collection and malysis alone over the past 4-5 years. I have had twoan~Ometer data collection systems. one on a grain stnJcture and the other a comp1ete sOm da1atower. Also, I am part owner of tho Dell Rapids ~metetS and thus have another 50m toweras well as four mnaller 20m type aystemJ across the plateau property which I can correlate myown data to. I was JWt otthe case befQfe the commission in September of2003 when Idaho Power prevailed in Bettini a foleQosUng requirement and performanc.e band attached to their wind project contracts. I could not finance my project under such terms with Investors I was working with at that tUne. Neverthel~ss. 1 kept collectinl data, hopmg to find some way to develop my project.Aftcrmy oId8r anemo~ter blew down In January of2OO4. I had a new SOm anemometerinstalled at my site at considerable expense and in Spring ot2005 had . full year of data on thatunit. J paid Renai"'~t: Engineering .t Design on 5/11flOOS to anal)lZe my data BIJd help Q1~submit an interconnection request. That intorcorm~tion document 91ates by the way tbat "Upon rcc,eipt" of those iten1S. Idaho Power Company would notifY me alin writing of the applicable contract application date and beam the process of drafting the appropriate energy $a1~$ agreement" for my rtWiew. Of coune, I never did receive a draft energy sales ~etnent. Brian acnoD m1.1mCd from the May wind conference in Denver with sad news about the availability of turbines in genen1, but good news in connecting me to someone 'with turbine possibilities and severaJ options. Al~or despit~ obvious di::itastc for the tt:rms of the Idaho Power contract, som~ investors WQTC dearly williOj to take; the chance and sign up for projects uuder tho5e terms. Fin~.uy I felt I had a chance to mBke this teal, right on the hoal$ of sellinll the water rights and tWTIing my irrigated land into dr1.1and farming. A wind project couldn't come at a better tirnefor me. ~ , jI."'hen 1 heard that Idaho Pow~ had requested a moratorium on signing PURPA contract!S for wind projects., I thought that w~ a. vicious nunor even ~oJ1d truth. Wh~n I found that it wasindeed true, I didn't ~en file to be an intervener in the case after the last one I was in at th~ Commission. However, 1 do distinctly qualif)# for th~ grandfatheril1S st.Atus grant~ in the writtendocumentation from the Commissio.nen. In particular, the two key elements of my project are that: (1) I .submitted my request forinterconl,lectiun earl)' in May. tm. yea.. aad (2) I have done 8I.teD.$ive wiad studies over several yeara. 1 have been m con1act with developers with turbines even having the possibilityof installinj 2005 instaUations with OE turbines or perhapg even Clipper Turbines in the spring of2006, The faotis, I was in tbe midst of sueh d.iscussions~ CU1d the emphatic; neod for a signed power purchase agreemen1 the very week of June 13da while waiti11g for results of'myinterconnection stud)' and then the following week was told that the wholc process was in turmoil and I ~'ould have to wait until the conunission came out wiili their Ofder jn July. As forthe other points made b)' the commission.l certainly WM in contact with people who lwf bothmoney and turbines, but just as cenainly cowd not sign contracts withoUt a Power Purchase Agreement in hand.. At the point of creating a dreft PP A, I was infonned I could file a QF "'SelfCertification~ fonn with FEke which I can do this week ifit is recommend Furthermore" I own 1,920 deeded acres on the Bell Rapids Plat~all and am part of the 20 000Beres of farm land that has sold the water rights aM shall quit the irrigated farming forever. Thisproject has more than cnoUih room and is adjacent to private and county access roads. Site~SS aod control is simply no1 an issue. Obviously with the other wind ptojeots happening in the Bell Rapids area, the potential for my projed SWtds out as far &5 wind resource like the other projects currently in place or proposed. nwby, As far as pennitting is concerned! I will followthrough with the detail and. tasks required, however, to date the oounty has consistc:ntly approvedeach proposed wind project application in this area. Please consider this request .in the most serious maanet and prepare the draft PP .A. for my r=viewand approval according to tbc: Commission di~ves. This will be an excellent project as itcom~a together. I was looking at GE turbines when I Itattted this year and found access to more1ban enough units actually with 100m towers which would ~ Verf good since my site hasexcellent wind shcar. Inste~ I have become aware of turbines and financing l\'ailab1c to usetM Clipper Liberty- 2.SMW turbmes for eatl)' ta mid 2006 construction. That i. Ii SllmpleinstaUation of four turbines on my property at the 10MW level. 11 may be possible to pursue upto 20MW nameplate in total, I am prepared to proceed with haste and sign agre~mtnu withdevelopers if 1 can just wrap up the Power Purchase Aareement. Sin(:creJy, f Mark SchrQcder j3J d I 1/ ,Jb i;;;1. RENAISSANCE ENGINEERING DESIGN PLLC ""t.J;.t.....t_.... ~~. ......-. ~,,-~,.._ t... (,f1.1e..t-. ~_.....J. J-k...~. ..) August 15 2005 Mark Schroeder Schroeder Wind Farm 374 East 5400 North Hagerman, Idaho 83332 Wind Analysis Summary Memo Dear Mark This memo is intended to summarize a portion of the data analysis work which has been done to date on your project in support of your letter to Idaho Power indicating "substantial progress and "project maturity" per the Commission s language. First I would like to congratulate you on such diligence and persistently working toward a working project. I have been analyzing data at Bell Rapids since the fIrst anemometer I installed several years ago and the subsequent group of three more including the 50m reference anemometer on the plateau directly west of the Fossil Gulch Wind Park. Note that for this report I have included a portion of the analysis work done for you that compares the 50m anemometers from your site to that reference unit. From detailed analysis we know that the 50m location is perhaps a better site than the original 20m location installed several years ago and that most of that data set is actually public information. Note that Chart shows the continuous daily wind patterns through part of the winter of 2003-2004 over more than 25,000 data points. The dates were taken off the data to prevent public disclosure of perhaps strategically sensitive information. The key element to notice is a very high visual correlation to the winds speeds on a diurnal basis. Chart 2 shows the same data set sorted down to 15 mph which results in about 8000 points from the entire data set. Note that in the highest energy segment, your anemometer actually shows a higher output (this is also reflected by the blue tips on the high points in Chart 1). However, the data shows for this seta slightly lower wind speed than the Bell Rapids 50m anemometers from about 32 mph on down. In a statistical comparison we fmd your data may indicate a slightly lower capacity factor than the Bell Rapids 50m anemometer, by perhaps as much as 5%. However, I actually suspect that your site is slightly better or at least equal. The main reason for this is the anemometer placement at your site is almost in a valley instead of on the ridge on your property. The 50m anemometer has the top instruments only 164 ft above ground level and I noted during the site visit, that your ridge is almost 50 ft higher in elevation than the anemometer tower base near the county road. Thus, that anemo~eter is significantly affected and worse is simply not in the right place. The good news however is that your data does correlate very well and should be extremely conservative. Based on your data alone, I would predict your net capacity factor to be approximately 30% after accounting for all losses and in comparison to other calculated capacity factors in that area. 7800 Alfalfa Lane Melba Idaho' 83641 ph 208-495-1111 fax 208-A95-1555 brian~clever-ideas.com RENAISSANCE ENGINEERING DESIGN PLLC -'lJ;._.... CCf..,.. .......... ~,,-..,....... t.., ~!I1e..t-- . ~...._ J. J-k.....,.. However, if I were to predict a capacity factor when taking into consideration the anemometer location and other"tactors including comparisons to multiple anemometers I would predict the calculation to be more like 32%. This can be enhanced of course by the special large blades expected to be available for the Clipper Wind Turbines late next spring. My recommendation is that we install an additional 50m anemometer on the ridgeline itself validate this as soon as you know you can get a contract for the purchase of energy. There are several used anemometers available now from people who don t think they will be able to pursue wind anymore. As far as the site location is concerned, the project fits your area very well and furthermore your ridge lines up nicely with the wind rose in that region. The last two sheets are summaries from your entire data set that show the maximum speed over the past year at 68 mph on April 7 of this year. The wind rose shows the now famous predictability of the wind from the west in your region with the smaller amount from the east. This is particularly convenient on your ridge which runs north-south in the area and it also allows you to place turbines closer to each other since you have virtually no North-South winds. The complete financial wind analysis and report you require is almost done and will be ready to send to the investors on their schedule, assuming things go will with your Power Purchase Agreement. I believe this project can be coordinated for a sequential construction with another project in particular which should go in near you next year also. This report should be sufficient to indicate the depth of the study we ve done, without divulging any information of strategic importance. Should you require more information I am available at your convenience. Sincerely, Brian D. Jackson, PE MBA CEM Project Engineer 7800 Alfalfa Lane, Melba Idaho 83641 ph 208-495-1111 fax 208-495-1555 brian~clever-ideas.com .. . . . It ) ~ ; 'I - 0 0 I - :I : a. . :: E a. . rJ ) CH A R T 2 : D a t a S p e e d C o r r e l a t i o n Sc h r o e d e r SO m a n d Be l l R a p i d s SO m l,; ' ;., ;'" " H " '* ' II, ,~ , ., ~ '! ! ! ' e'" ,~ , "'i 1 ' - - - - - - - - - - , _ . . . . A! .'. " !! 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