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HomeMy WebLinkAbout2015 - Neck Lake Hydro REFRoundIXApplication - FINAL September 11, 2015 Alaska Energy Authority Renewable Energy Fund Grant Application 813 West Northern Lights Blvd Anchorage, AK 99503 RE: REF Round 9 Grant Application Neck Lake Hydroelectric Project Phase II-III Grant Application Dear AEA: Enclosed, on behalf of Alaska Power Company (APC), in response to Requests for Grant Applications (RFA) AEA 16012, Renewable Energy Fund Grant Program (ROUND IX) is an application requesting funding for the Neck Lake Hydroelectric Project for Phase II-III – Feasibility – Permitting and Final Design. If you have any questions, please call either Glen Martin (Resource Assessment & Permits) 360-385-1733 x122, Christine Overly (Grant Funds Administrator) 360-385- 1733 x137, or Bob Grimm (President) 360-385-1733 x120. Sincerely, Glen D. Martin Resource Assessment & Permits Enc. (as stated) Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 1 of 44 7/8/14 Application Forms and Instructions This instruction page and the following grant application constitutes the Grant Application Form for Round VIII [IX] of the Renewable Energy Fund. A separate application form is available for projects with a primary purpose of producing heat (see RFA section 1.5). This is the standard form for all other projects, including projects that will produce heat and electricity. An electronic version of the Request for Applications (RFA) and both application forms is available online at: http://www.akenergyauthority.org/Programs/Renewable-Energy-Fund/Rounds#round9. • If you need technical assistance filling out this application, please contact Shawn Calfa, the Alaska Energy Authority Grants Administrator at (907) 771-3031 or at scalfa@aidea.org. • If you are applying for grants for more than one project, provide separate application forms for each project. • Multiple phases (e.g. final design, construction) for the same project may be submitted as one application. • If you are applying for grant funding for more than one phase of a project, provide milestones and grant budget for each phase of the project. • In order to ensure that grants provide sufficient benefit to the public, AEA may limit recommendations for grants to preliminary development phases in accordance with 3 ACC 107.605(1). • If some work has already been completed on your project and you are requesting funding for an advanced phase, submit information sufficient to demonstrate that the preceding phases are completed and funding for an advanced phase is warranted. Supporting documentation may include, but is not limited to, reports, conceptual or final designs, models, photos, maps, proof of site control, utility agreements, power sale agreements, relevant data sets, and other materials. Please provide a list of supporting documents in Section 11 of this application and attach the documents to your application. • If you have additional information or reports you would like the Authority to consider in reviewing your application, either provide an electronic version of the document with your submission or reference a web link where it can be downloaded or reviewed. Please provide a list of additional information; including any web links, in section 12 of this application and attach the documents to your application. For guidance on application best practices please refer to the resource specific Best Practices Checklists; links to the checklists can be found in the appendices list at the end of the accompanying REF Round IX RFA. • In the sections below, please enter responses in the spaces provided. You may add additional rows or space to the form to provide sufficient space for the information, or attach additional sheets if needed. REMINDER: • Alaska Energy Authority is subject to the Public Records Act AS 40.25, and materials submitted to the Authority may be subject to disclosure requirements under the act if no statutory exemptions apply. • All applications received will be posted on the Authority web site after final recommendations are made to the legislature. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 2 of 44 7/8/14 • In accordance with 3 AAC 107.630 (b) Applicants may request trade secrets or proprietary company data be kept confidential subject to review and approval by the Authority. If you want information to be kept confidential the applicant must: o Request the information be kept confidential. o Clearly identify the information that is the trade secret or proprietary in their application. o Receive concurrence from the Authority that the information will be kept confidential. If the Authority determines it is not confidential it will be treated as a public record in accordance with AS 40.25 or returned to the applicant upon request. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 3 of 44 7/8/14 SECTION 1 – APPLICANT INFORMATION Please specify the legal grantee that will own, operate, and maintain the project upon completion. Name (Name of utility, IPP, local government, or other government entity) Alaska Power Company (APC) – A subsidiary of Alaska Power & Telephone Company (AP&T) Type of Entity: Fiscal Year End: Utility December 31 Tax ID # Tax Status: ☒ For-profit ☐ Non-profit ☐ Government (check one) Date of last financial statement audit: Mailing Address: Physical Address: Glen Martin [Same] Alaska Power Company P.O. Box 3222 Port Townsend, WA 98368 Telephone: Fax: Email: 360-385-1733 x122 360-385-7538 glen.m@aptalaska.com 1.1 Applicant Point of Contact / Grants Manager Name: Title: Glen Martin Mgr. Permitting/Licensing/Compliance Mailing Address: Alaska Power Company Attn: Glen Martin P.O. Box 3222 Port Townsend, WA 98368 Telephone: Fax: Email: 360-385-1733 x122 360-385-7538 glen.m@aptalaska.com 1.1.1 APPLICANT SIGNATORY AUTHORITY CONTACT INFORMATION Name: Title: Robert S. Grimm CEO – AP&T Mailing Address: Alaska Power & Telephone Company P.O. Box 3222 Port Townsend, WA 98368 Telephone: Fax: Email: 360-385-1733 x120 360-385-7538 bob.g@aptalaska.com 1.1.2 Applicant Alternate Points of Contact Name Telephone: Fax: Email: Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 4 of 44 7/8/14 Christine Overly – Senior Accountant – Grant Funds Administrator 360-385-1733 x128 360-385-7538 christine.o@aptalaska.com Jason Custer – Bus. Dev. 907-225-1950 x29 jason.c@aptalaska.com 1.2 Applicant Minimum Requirements Please check as appropriate. If applicants do not meet the minimum requirements, the application will be rejected. 1.2.1 Applicant Type ☒ An electric utility holding a certificate of public convenience and necessity under AS 42.05, or ☐ An independent power producer in accordance with 3 AAC 107.695 (a) (1), or ☐ A local government, or ☐ A governmental entity (which includes tribal councils and housing authorities) 1.2 APPLICANT MINIMUM REQUIREMENTS (continued) Please check as appropriate. ☒ 1.2.2 Attached to this application is formal approval and endorsement for the project by the applicant’s board of directors, executive management, or other governing authority. If the applicant is a collaborative grouping, a formal approval from each participant’s governing authority is necessary. (Indicate by checking the box) ☒ 1.2.3 As an applicant, we have administrative and financial management systems and follow procurement standards that comply with the standards set forth in the grant agreement (Section 3 of the RFA). (Indicate by checking the box) ☒ 1.2.4 If awarded the grant, we can comply with all terms and conditions of the award as identified in the Standard Grant Agreement template at http://www.akenergyauthority.org/Programs/Renewable-Energy-Fund/Rounds#round9. (Any exceptions should be clearly noted and submitted with the application.) (Indicate by checking the box) ☒ 1.2.5 We intend to own and operate any project that may be constructed with grant funds for the benefit of the general public. If no please describe the nature of the project and who will be the primary beneficiaries. (Indicate yes by checking the box) Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 5 of 44 7/8/14 SECTION 2 – PROJECT SUMMARY 2.1 Project Title Provide a 4 to 7 word title for your project. Type in the space below. Neck Lake Hydropower Project: Phases II-III 2.2 Project Location 2.2.1 Location of Project – Latitude and longitude (preferred), street address, or community name. Latitude and longitude coordinates may be obtained from Google Maps by finding you project’s location on the map and then right clicking with the mouse and selecting “What is here? The coordinates will be displayed in the Google search window above the map in a format as follows: 61.195676.-149.898663. If you would like assistance obtaining this information please contact AEA at 907-771-3031. Google Maps coordinates: 56.097806.-133.138525 Project is near Whale Pass, Prince of Wales Island 2.2.2 Community benefiting – Name(s) of the community or communities that will be the beneficiaries of the project. The project will benefit the community Whale Pass, Alaska. The most recently available AEA PCE report identifies $0.62 kWh pricing for this service region, with an average PCE payment of $0.39 per eligible kilowatt hour.1 Approximately 54.8% of kilowatt hours sold are subject to PCE subsidization. 2.3 Project Type Please check as appropriate. 2.3.1 Renewable Resource Type ☐ Wind ☐ Biomass or Biofuels (excluding heat-only) ☒ Hydro, Including Run of River ☐ Hydrokinetic ☐ Geothermal, Excluding Heat Pumps ☐ Transmission of Renewable Energy ☐ Solar Photovoltaic ☐ Storage of Renewable ☐ Other (Describe) ☐ Small Natural Gas 2.3.2 Proposed Grant Funded Phase(s) for this Request (Check all that apply) Pre-Construction Construction ☐ Reconnaissance ☒ Final Design and Permitting 1 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/Content/Programs/PCE/Documents/FY14PCEStatisticalRptByComtAmended.pdf Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 6 of 44 7/8/14 ☒ Feasibility and Conceptual Design ☐ Construction 2.4 Project Description Provide a brief one paragraph description of the proposed project. Alaska Power Company (APC), a subsidiary of Alaska Power & Telephone (AP&T), requests $395,200 in AEA REF Round IX funding for Phase II and Phase III activities for the Neck Lake hydropower project. Both Phase II and III must be conducted concurrently because of the FERC licensing process, so both phases need funding at the same time.2 APC will provide $98,800 cash match to AEA funding. The 124 kW Neck Lake Hydroelectric Project will be located below the outlet of Neck Lake, approximately 1.5 miles southwest of the community of Whale Pass on Prince of Wales Island, Alaska. The Project will supply as much as 450,000 kilowatt hours of energy per year to the community of Whale Pass, offsetting diesel generation, which is currently the sole source of electricity for residents. The relatively high and modulated flows from the lake combined with the steep drop at the lower end of the outlet stream provide an attractive opportunity for a small run-of- river hydroelectric project. Project features would include an access road, intake structure, 400 feet of penstock, a containerized power plant, a tailrace channel, and 4 miles of distribution line upgrades. The hydroelectric facilities will be designed to avoid interference with the existing salmon rearing and collection facilities operated at Neck Lake by the Southern Southeast Regional Aquaculture Association (SSRAA). A letter of support from the SSRAA is enclosed. APC conducted a reconnaissance study of the site in 2009 and determined that there is sufficient potential to almost always provide enough generation meeting 100% of current and future Whale Pass loads. This Project will provide clean, renewable electricity, as well as rate stabilization and lower rates for APC’s Whale Pass customers. In 2014 and 2015, AP&T conducted financial and economic analysis which confirmed the economic and financial viability of this project. The AEA’s econometric workbook calculates a B/C Ratio of 1.75, total NPV benefits of $5.12m, and NPV net benefit of $2.67m AEA workbook outputs are displayed below. 2 Considering the current uncertainty regarding funding by AEA under the REF Grant Program, authorizing the budget for both phases in Round IX will ensure the project gets to the construction phase in a timely manner. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 7 of 44 7/8/14 2.5 Scope of Work Project Description Community Nearest Fuel Community Region RE Technology Project ID Applicant Name Project Title Results NPV Benefits $5,120,820.30 NPV Capital Costs $2,931,626 B/C Ratio 1.75 NPV Net Benefit $2,665,630 Performance Unit Value Displaced Electricity kWh per year 450,000 Displaced Electricity total lifetime kWh 22,500,000 Displaced Petroleum Fuel gallons per year 36,000 Displaced Petroleum Fuel total lifetime gallons 1,800,000 Displaced Natural Gas mmBtu per year - Displaced Natural Gas total lifetime mmBtu - Avoided CO2 tonnes per year 365 Avoided CO2 total lifetime tonnes 18,270 Proposed System Unit Value Capital Costs $3,019,575$ Project Start year 2021 Project Life years 50 Displaced Electric kWh per year 450,000 Displaced Heat gallons displaced per year - Renewable Generation O&M $ per year 30,196 Electric Capacity kW 124 Electric Capacity Factor %40 Heating Capacity Btu/hr 0 Heating Capacity Factor %0 Total Public Benefit 2015$ (Total over the life of the project) Base System Size of impacted engines (select from list)$/kWh Diesel Generator O&M 151-360kW 0.203$ Applicant's Diesel Generator Efficiency kWh per gallon Total current annual generation kWh/gallon Diesel Generation Efficiency 12.50 Whale Pass Whale Pass Rural Hydro (Run of River) Neck Lake Hydro Alaska Power Company Neck Lake Hydropower Project: Phases II-III Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 8 of 44 7/8/14 Provide a scope of work detailing the tasks to be performed under this funding request. This should include work paid for by grant funds and matching funds or performed as in-kind match. Both Phase II and III must be conducted concurrently because of the FERC licensing process, so both phases need funding at the same time.3 Phase II of this project requires a total of $171,000 to: complete environmental studies; complete consultations with SSRAA, FERC, and resource agencies; conduct a feasibility analysis; and finalize the conceptual design. APC requests $136,800 AEA REF funding for Phase II, and will provide $34,200 cash match. Phase II: Resource Assessment/Feasibility Analysis/Conceptual Design: July 2016 – December 2017 In late 2009 APC had a surveyor develop topographic mapping of the Project. During the summer of 2016, the conceptual design from the Phase I reconnaissance work by APC will be reviewed and augmented to develop firm information for presenting to permitting agencies. As part of this work, APC will coordinate extensively with SSRAA regarding the proposed development. As discussed above, APC and SSRAA have agreed to work cooperatively to develop a hydropower project that will be junior to all needs of the Neck Lake hatchery, and will assure no adverse impacts to the hatchery or salmon runs. SSRAA has provided a letter of support, which is enclosed. In addition, a cost estimate will be prepared for the selected arrangement, and an updated economic and financial analysis will be conducted. The results will be presented in a feasibility report. At the same time, APC will initiate the FERC licensing process by submitting the Notice of Intent (NOI) and the Preliminary Application Document (PAD) to FERC, the resource agencies, and will be available to the public after a public notice is placed in the areas newspapers. Within 60 days of the notice and NOI and PAD submittal, APC will hold a public/agency consultation meeting to receive comments, questions, and concerns to develop the study plan for environmental surveys. This can be accomplished in the first two months, i.e. July through August 2016. These surveys may include fish surveys, wildlife assessments, botanical surveys, wetlands surveys, archaeological survey (initial SHPO review), and water quality testing. The total area of impact, including within the SSRAA facility, is expected to be approximately 0.25 acres. Phase III: Permitting and Final Design; January 2018 – December 2019 Phase III of this project requires a total of $323,000 to: develop project final design; write the environmental assessment; continue agency consultation; complete a FERC license application filing; respond to FERC’s additional information requests (AIR); finalize agency permitting; and address any additional field studies needed to satisfy agency requirements. APC requests $258,400 AEA REF funding for Phase III, and will provide $64,600 cash match. In this phase, the environmental assessment and the FERC license application will be finalized and submitted to FERC by March 2018. We anticipate having the license by May 1, 2019. Other permits and land easements will be acquired, and final design documents prepared. Permits will include: COE Section 404 permit, ADFG fish habitat permit, ADNR land lease or easement, ADNR water rights (applied for but they won’t issue until after operations have gone on for 5 years), and SHPO review. Final design will begin in approximately May 2019 and will be completed, including agency approval, by December 2019. The development of license article plans with agency consultation after the license is issued will also occur along with final design review by FERC and agencies. If 3 Considering the current uncertainty regarding funding by AEA under the REF Grant Program, authorizing the budget for both phases in Round IX will ensure the project gets to the construction phase in a timely manner. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 9 of 44 7/8/14 additional field studies are requested by the agencies or FERC takes longer than expected to issue a license, this timeline may be pushed back. EXHIBIT 1: SSRAA HATCHERY AND NECK LAKE HYDROPOWER PROJECT LAYOUT SECTION 3 – Project Management, Development, and Operation 3.1 Schedule and Milestones Criteria: Stage 2-1.A: The proposed schedule is clear, realistic, and described in adequate detail. Please fill out the schedule below (or attach a similar sheet) for the work covered by this funding request. Be sure to identify key tasks and decision points in in your project along with estimated start and end dates for each of the milestones and tasks. Please clearly identify the beginning and ending of all phases of your proposed project. Add additional rows as needed. PHASE II - Milestones Tasks Start Date End Date Deliverables NOI & PAD Issued to FERC Completion & Filing of NOI & PAD; issue Public/Agency Meeting Notice 07/01/16 08/01/16 FERC Accepts NOI & PAD Agency Consultation Meeting Consultation with FERC and Agencies; consultation meeting; start to develop study plan 08/01/16 09/01/16 Filing of NOI with FERC; Public Notice of NOI; Draft Study Plan Issued Draft Study Plan issued for comment 12/01/16 12/31/16 Draft Study Plan Final Study Plan Issued Final Study Plan issued so field studies can begin 01/05/17 02/05/17 Final Study Plan Fish Survey Final Report Conduct fish survey – contractor 04/01/17 12/01/17 Final Fish Survey Report Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 10 of 44 7/8/14 Wildlife Survey Final Report Conduct wildlife survey – contractor 05/01/17 12/01/17 Final Wildlife Survey Report TES Botanical Survey Final Report Conduct TES botanical survey – contractor 05/01/17 12/01/17 Final TES Survey Report Wetland Delineation Final Report Conduct wetland delineation – contractor 05/01/17 12/01/17 Final Wetland Delineation Report Cultural Resource Survey Final Report Conduct cultural resource survey – contractor 06/01/17 12/01/17 Final Summary of Cultural Resources Water Quality Sampling Final Report Conduct water quality sampling – contractor/APC 07/01/16 12/01/17 Final Water Quality Report Feasibility & Conceptual Design Analysis of data collected; issuance of draft and final feasibility and conceptual design reports 10/01/17 12/31/17 Issuance of Final Feasibility Report and Conceptual Design Report PHASE III - Milestones Tasks Start Date End Date Deliverables Land Easements / Authorizations / Early Entry Permit Applications Apply to DNR and SSRAA for land use authorizations, including an Early Entry Permit 01/06/18 01/30/18 Applications for land use filed with agencies Environmental Assessment Issued Develop and finalize the EA 01/06/18 02/28/18 Final EA completed File License Application with FERC Develop and finalize the license application 02/01/18 03/15/18 Final License Application filed File for Agency Permits Apply for COE, ADFG, ADNR, ADEC, etc. permits 12/31/17 01/01/19 Applications for permits filed with agencies FERC License Issuance After submitting license application, respond to additional info requests, etc. up to FERC license issuance 03/15/18 04/30/19 FERC issues license Final Design Approval Finalize project design and get FERC / Agency approvals 04/30/19 12/31/19 Final design is approved License Article Plan Approvals Submit draft license articles to FERC and agencies for approvals/permits in preparation to begin construction 04/30/19 12/31/19 License article plans are approved Phase IV: Construction: January 2020 – September 2021 [not a part of this application; for reference only] Construction would begin after a FERC license is received and the license article plans and final design are approved by FERC and other agencies. Once funding for this phase is secured, APC will order generating equipment and begin off-site fabrication of the intake and powerhouse modules. Onsite construction is anticipated to begin in early 2020 and continue through the third quarter of 2021. The construction work should not be significantly compromised by weather at this temperate location. • Award contract for supply of the generating equipment by August 2019 • Completion of access road to intake site by April 2020 • Completion of Diversion Structure by April 2021 • Completion of Powerhouse by July 2021 Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 11 of 44 7/8/14 • Completion of Generation Equipment Installation by July 2021 • Completion of Penstock Installation by April 2021 • Completion of Distribution Line into Whale Pass by April 2021 • Test and Startup by July-August 2021 • End of Phase IV Construction September 2021 EXHIBIT 2: PROJECT TIMELINE 3.2 Budget Criteria: Stage 2-1.B: The cost estimates for project development, operation, maintenance, fuel, and other project items meet industry standards or are otherwise justified. 3.2.1 Budget Overview Describe your financial commitment to the project. List the amount of funds needed for project completion and the anticipated nature and sources of funds. Consider all project phases, including future phases not covered in this funding request. Grand Total, Phase II and Phase III Activities $395,200.00 $98,800.00 APC $494,000.00 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 PHASE I: Reconnassaince Reconnaissance (completed) PHASE II: Resource Assement/Feasibility Analysis/Conceptual Design Agency Consultation/Permitting Resource Assessment (studies) Feasibility & Conceptual Design PHASE III: Final Design and Permitting Permitting & FERC License App FERC Application Processing Final Design Agency Permits Issued PHASE IV: Construction Grant processing Access Road Diversion & Intake Penstock Generating Equipment Procurement Powerhouse Install Distribution Line Test and Start-Up LEGEND:<-- Procurement and off-site fabrication <-- On-site construction 2021 NECK LAKE HYDROELECTRIC PROJECT DEVELOPMENT SCHEDULE 2016 2017 2018 2019 2020 Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 12 of 44 7/8/14 AEA RE- Fund Grant Funds Grantee Matching Funds Source of Matching Funds: Cash/In- Kind/Federal Grants/Other State Grants/Other TOTALS Total Cost - Phase I $3,500.00 APC $3,500.00 Total Cost - Phase II $136,800.00 $34,200.00 APC $171,000.00 Total Cost - Phase III $258,400.00 $64,600.00 APC $323,000.00 Grand Totals - Phase II & Phase III Activities $395,200.00 $98,800.00 APC $494,000.00 Phase II of this project requires a total of $171,000 to: complete environmental studies; complete consultations with SSRAA, FERC, and resource agencies; conduct a feasibility analysis; and finalize the conceptual design. APC requests $136,800 AEA REF funding for Phase II, and will provide $34,200 cash match. Phase III of this project requires a total of $323,000 to: develop project final design; write the environmental assessment; continue agency consultation; complete a FERC license application filing; respond to FERC’s additional information requests (AIR); finalize agency permitting; and address any additional field studies needed to satisfy agency requirements. APC requests $258,400 AEA REF funding for Phase III, and will provide $64,600 cash match. APC’s cumulative Phase II-III request is for a total of $395,200 AEA REF funding, which will be matched by $98,800 in cash provided by APC out of its normal operating funds. This represents an 80% grant / 20% cash match ratio. The construction costs indicated in Section 3.2.5 of this application were developed in August of 2015, based on site reconnaissance conducted in 2009. Construction costs may change by the time final design is completed, and will be updated upon completion of Phase II and Phase III activities proposed for AEA REF funding. In Round II of the REF program, APC was awarded $108,000 for completion of a conceptual design, environmental surveys, and a feasibility report. Part of these funds were used to develop and submit a filing for a FERC jurisdictional determination. FERC determined that a license would be required for this project. Of the total amount of the grant funding, only $22,474.73 was expended. These funds were used to support activities including surveying and mapping, preparation of the FERC jurisdictional determination filling, and conceptual design. FERC’s finding that a license would be required resulted in APC terminating project activities due to concerns about increased project development costs. However, FERC has recently developed a small hydropower licensing track that should significantly expedite the licensing process and reduce the licensing costs associated with a small project such as Neck Lake. The availability of this licensing track – in conjunction with diesel cost escalation estimates and key findings of the SEIRP – have lead APC to conclude that it is in the best interest of the ratepayers of Whale Pass to resume efforts to pursue the Neck Lake hydropower project. This finding is supported by updated reconnaissance level financial and economic analysis completed by APC in August of 2015. Phase II and III project activities and budgets have been updated to reflect current conditions. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 13 of 44 7/8/14 3.2.2 Budget Forms Applications MUST include a separate worksheet for each project phase that was identified in section 2.3.2 of this application, (I. Reconnaissance, II. Feasibility and Conceptual Design, III. Final Design and Permitting, and IV. Construction. Please use the tables provided below to detail your proposed project’s total budget. Be sure to use one table for each phase of your project. The milestones and tasks should match those listed in 3.1 above. If you have any question regarding how to prepare these tables or if you need assistance preparing the application please feel free to contact AEA at 907-771-3031 or by emailing the Grants Administrator, Shawn Calfa, at scalfa@aidea.org. Phase II Milestones RE- Fund Grant Funds Grantee Matching Funds Source of Matching Funds: Cash/In- Kind/Federal Grants/Other State Grants/Other TOTALS Initial FERC Permitting Process/Agency Consultation $17,600.00 $4,400.00 APC $22,000.00 Wildlife Survey $8,000.00 $2,000.00 APC $10,000.00 TES Botanical Survey $8,000.00 $2,000.00 APC $10,000.00 Wetland Delineation $16,000.00 $4,000.00 APC $20,000.00 Cultural Resource Survey $8,000.00 $2,000.00 APC $10,000.00 Consultation / Coordination with SSRAA $8,000.00 $2,000.00 APC $10,000.00 Water Quality Sampling $7,200.00 $1,800.00 APC $9,000.00 Fish Survey $40,000.00 $10,000.00 APC $50,000.00 Feasibility Analysis $16,000.00 $4,000.00 APC $20,000.00 Conceptual Design $8,000.00 $2,000.00 APC $10,000.00 TOTALS $136,800.00 $34,200.00 APC $171,000.00 Budget Categories: Direct Labor & Benefits $44,800.00 $11,200.00 APC $56,000.00 Travel & Per Diem $4,800.00 $1,200.00 APC $6,000.00 Equipment $ $ $ Materials & Supplies $ $ $ Contractual Services $87,200.00 $21,800.00 APC $109,000.00 Construction Services $ $ $ Other $ $ $ TOTALS $136,800.00 $34,200.00 APC $171,000.00 Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 14 of 44 7/8/14 3.2.3 Cost Justification Indicate the source(s) of the cost estimates used for the project budget. The budget is based upon APC’s decades of experience and success in hydropower project development. APC believes that its experience designing, constructing, and operating similar small hydropower projects in Alaska; its longstanding vendor, technical service, supply chain relationships and industry knowledge; and its incumbent project development resources will help minimize risks and control costs. APC has a strong understanding of risks through development/construction experience, as well as an understanding of the processes involved in creating a durable hydropower asset capable of 50+ years of reliable, safe operation. 3.2.4 Funding Sources Indicate the funding sources for the phase(s) of the project applied for in this funding request. Phase III Milestones AEA RE- Fund Grant Funds Grantee Matching Funds Source of Matching Funds: Cash/In- Kind/Federal Grants/Other State Grants/Other TOTALS Additional Field Studies $50,400.00 $12,600.00 APC $63,000.00 FERC Licensing / Agency Permitting / EA $48,000.00 $12,000.00 APC $60,000.00 Final Design $160,000.00 $40,000.00 APC $200,000.00 TOTALS $258,400.00 $64,600.00 APC $323,000.00 Budget Categories: Direct Labor & Benefits $203,200.00 $50,800.00 APC $254,000.00 Travel & Per Diem $4,800.00 $1,200.00 APC $6,000.00 Equipment $$$ Materials & Supplies $$$ Contractual Services $50,400.00 $12,600.00 APC $63,000.00 Construction Services $$$ Other $$$ TOTALS $258,400.00 $64,600.00 APC $323,000.00 Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 15 of 44 7/8/14 Grant funds requested in this application $395,200.00 Cash match to be provided $98,800.00 In-kind match to be provided $0 Total costs for project phase(s) covered in application (sum of above) $494,000.00 3.2.5 Total Project Costs Indicate the anticipated total cost by phase of the project (including all funding sources). Use actual costs for completed phases. Reconnaissance $3,500.00 Feasibility and Conceptual Design $193,475.00 4 Final Design and Permitting $323,000.00 Construction $2,500,000.00 Total Project Costs (sum of above) $3,019,975.00 3.2.6 Operating and Maintenance Costs O&M costs can be estimated in two ways for the standard application. Most proposed RE projects will fall under Option 1 because the new resource will not allow for diesel generation to be turned off. Some projects may allow for diesel generation to be turned off for periods of time; these projects should choose Option 2 for estimating O&M. Options O&M Impact of proposed RE project Option 1: Diesel generation ON For projects that do not result in shutting down diesel generation there is assumed to be no impact on the base case O&M. Please indicate the estimated annual O&M cost associated with the proposed renewable project. NA Option 2: Diesel generation OFF For projects that will result in shutting down diesel generation please estimate: 1. Annual non-fuel savings of shutting off diesel generation 2. Estimated hours that diesel generation will be off per year. 3. Annual O&M costs associated with the proposed renewable project. 1. AEA workbook estimates $91,314.26 2. Hours diesel OFF/year: 8,716 [99.5%] 3. $25,000 3.3 Project Communications Criteria: Stage 2-1.C: The applicant’s communications plan, including monitoring and reporting, is described in adequate detail. Describe how you plan to monitor the project and keep the Authority informed of the status. During Phases II and III, APC proposes to provide quarterly reports to AEA regarding the status of the work. APC has provided similar reports to AEA and other grant funding agencies in the past several years on other projects, and has established the necessary procedures, timely preparation and delivery of reports, and responding in a timely manner to questions and requests for information by the AEA. In addition to providing quarterly reports, at the completion of Phase II, APC will provide AEA with a summary report including conceptual design drawings and an updated cost estimate. At 4 Includes $22,474.73 from earlier grant funding from AEA Round 2 for Phase II. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 16 of 44 7/8/14 the completion of Phase III, APC will provide AEA with a summary reporting including final design drawings, specifications, updated cost estimates, and copies of the FERC license and permits. APC is open to consider any additional/alternative reporting measures which may be desired by the AEA. 3.4 Operational Logistics Criteria: Stage 2-1.D: Logistical, business, and financial arrangements for operating and maintaining the project throughout its lifetime and selling energy from the completed project are reasonable and described in adequate detail. Describe the anticipated logistical, business, and financial arrangements for operating and maintaining the project throughout its lifetime and selling energy from the completed project. Logistical Arrangements: The Neck Lake hydropower project will be operated primarily through automation. The project’s powerhouse will be located adjacent to the SSRAA Hatchery on the existing road system. This will allow for easy access for scheduled maintenance, and any emergencies. The access road will allow personnel to access the project’s other facilities as may be needed. Business Arrangements: The Neck Lake hydropower project is a self-build project undertaken by the incumbent utility, APC, which currently provides certificated utilities services in Whale Pass. This eliminates the need for a power purchase agreement. Financial Arrangements: APC will continue its current practice of performing all utility financial and accounting tasks associated with generation of power in Whale Pass. Additional details can be provided upon request to the AEA. SECTION 4 – QUALIFICATIONS AND EXPERIENCE 4.1 Project Team Criteria: Stage 2-2.A: The Applicant, partners, and/or contractors have sufficient knowledge and experience to successfully complete and operate the project. If the applicant has not yet chosen a contractor to complete the work, qualifications and experience points will be based on the applicant’s capacity to successfully select contractors and manage complex contracts. Criteria: Stage 2-2.B: The project team has staffing, time, and other resources to successfully complete and operate the project. Criteria: Stage 2-2.C: The project team is able to understand and address technical, economic, and environmental barriers to successful project completion and operation. Criteria: Stage 2-2.D: The project team has positive past grant experience. 4.1.1 Project Manager Indicate who will be managing the project for the Grantee and include contact information, and a resume. In the electronic submittal, please submit resumes as separate PDFs if the applicant would like those excluded from the web posting of this application. If the applicant does not have a project manager indicate how you intend to solicit project management support. If the applicant expects project management assistance from AEA or another government entity, state that in this section. Project Management Team: Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 17 of 44 7/8/14 Resumes and references are enclosed. Greg Mickelson – Alaska Power & Telephone Company Project Manager greg.m@aptalaska.com 907-755-4822 Vern Neitzer – Alaska Power & Telephone Company Senior Engineer Vern.n@aptalaska.com 907-983-2202 Larry Coupe – Alaska Power & Telephone Company Senior Civil Engineer Larry.c@aptalaska.com 360-385-1733 x155 Ben Beste – Alaska Power & Telephone Company Senior Mechanical Engineer Ben.b@aptalaska.com 360-302-1379 Bob Berreth – Alaska Power & Telephone Company Senior Electrical Engineer Bob.b@aptalaska.com 360-385-1733 x 123 Glen Martin – Alaska Power & Telephone Company Grant Writer, Project Manager Glen.M@aptalaska.com 360-385-1733 x 122 Jason Custer – Alaska Power & Telephone Company Business Development Director Jason.c@aptalaska.com 907-225-1950 x33 Christine Overly – Alaska Power & Telephone Company Senior Accountant – Grant Funds Administrator Christine.o@aptalaska.com 360-385-1733 x137 Additional AP&T senior engineers and project managers can be utilized as needed to assist with management and execution of the project. Greg Mickelson, APC’s V.P. of Power Operations will be the Project Manager for all phases of work. Mr. Mickelson is an engineer with extensive experience in project management and electrical generation, transmission and distribution. Mr. Mickelson has been a part of APCs team for over 30 years and has been an essential part of the company’s success. He has overseen numerous grant-funded projects and is familiar with following associated guidelines and requirements. Mr. Mickelson’s resume is enclosed. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 18 of 44 7/8/14 APC’s personnel will conduct all Phase II engineering work and will utilize contractors for the environmental studies in Phase II. Resumes of key personnel are enclosed. 4.1.2 Expertise and Resources Describe the project team including the applicant, partners, and contractors. Provide sufficient detail for reviewers to evaluate: • the extent to which the team has sufficient knowledge and experience to successfully complete and operate the project; • whether the project team has staffing, time, and other resources to successfully complete and operate the project; • how well the project team is able to understand and address technical, economic, and environmental barriers to successful project completion and operation. If contractors have not been selected to complete the work, provide reviewers with sufficient detail to understand the applicant’s capacity to successfully select contractors and manage complex contracts. Include brief resumes for known key personnel and contractors as an attachment to your application. In the electronic submittal, please submit resumes as separate PDFs if the applicant would like those excluded from the web posting of this application APC will manage the grant. APC has been providing power to Alaskan communities since 1957. Since then, from only a handful of employees, APC has grown to 134 employee-owners (all of AP&T) who provide power services to 25 communities. APC has experience with renewable resources after constructing 4 hydroelectric projects in S.E. Alaska, currently owns and operates 7 hydroelectric projects in S.E. Alaska, conducted field testing of a pre-commercial hydrokinetic turbine installed in the Yukon River, and is currently constructing their 8th and 9th hydroelectric projects (Hiilangaay and Yerrick Creek). APC also has extensive experience with diesel/hydropower system integration and operations. APC has personnel certified as electrical, civil, and mechanical engineers who maintain existing facilities to the highest professional standards. APC has a consistent history of excellent performance in reliability, customer service, and a long-standing reputation for being a low cost provider of electric service. Additionally, APC is committed to transitioning from fossil fuel power generation to renewable energy. APC’s budgets have included several 50% grant funded projects for installation of transmission lines on Prince of Wales Island, and three RUS (Rural Utilities Service) 100% grants for the installation of transmission lines from Tok to Tetlin and Haines to Lutak, and communities along the Haines Highway. APC’s engineering staff has been involved in the design, construction and operation of hydroelectric projects since the 1980’s. APC currently maintains over 250 miles of transmission line and has seasoned staff to maintain diesel generators and hydro power plants. APC has administrators responsible for multi-million dollar budgets, including the management of 60+ employees, equipment, and all generation and distribution resources. Resumes of key AP&T staff are attached. Key APC/AP&T personnel and their roles in this project are as follows: • Greg Mickelson, Project Manager & Construction Superintendent, Engineer • Vern Neitzer, Senior Engineer Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 19 of 44 7/8/14 • Bob Berreth, Electrical Design • Ben Beste, Mechanical Design • Larry Coupe, Civil Design • Glen Martin, Resource Assessment, Permits, FERC License, Compliance • Jason Custer, Financial and Business Case Analysis, Project Management Tasks, Technical Writing • Christine Overly, Senior Accountant – Grant Administrator Phase I: Reconnaissance Already completed by APC. Phase II: Resource Assessment/Feasibility Analysis/Conceptual Design APC will acquire site control and complete environmental and engineering/conceptual design studies. APC may use the following contractors for the various surveys: • Wetlands delineation – HDR Alaska Inc. • Threatened and endangered plant species survey – HDR Alaska Inc. • Fish surveys – Fisheye Consulting (or possibly staff from SSRAA Hatchery) • Water quality sampling – Analytica Group Environmental Laboratories • Cultural resource surveys – Northern Land Use Research Alaska, LLC APC permitting specialists will compile environment information into resource assessment documents as required by the various permitting agencies and FERC. APC engineers will conduct engineering/conceptual design studies in-house. Phase III: Final Design & Permitting APC will complete agency consultation for permitting and filing a FERC license application. An environmental assessment will be prepared for the license application as well. Final design will be completed after the FERC license is issued. It is estimated that FERC’s small hydro licensing process may take only one year before issuance of a license. Along with a FERC license, the following permits will be acquired: • 404 Certification / permit (Corps of Engineers) • 401 Certification (ADEC); ADEC could waive this because of FERC and COE involvement • Fish habitat permit (ADF&G) • Land lease or easement (SSRAA) • Land lease or easement (ADNR) • Water right (ADNR); will be applied for, but will take minimum of 5 years to obtain because the water right is only certified after the water is being used for a while (certified based on how much water is actually used, or maximum daily use). • SHPO review APC will prepare the final design documents in-house using its staff civil, mechanical, and electrical engineers, who all have extensive experience in hydroelectric development. These engineers designed numerous successfully hydropower projects including Goat Lake, Black Bear Lake, Kasidaya Creek, Falls Creek, and South Fork. Phase IV: Construction [Not included with this grant request: for information purposes only.] Construction activities will be completed by local contractors and APC staff: • Access road – local contractor(s) or force account • Intake fabrications – Reynold Grey Machining and Services • Intake on-site construction – local contractor(s) or force account Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 20 of 44 7/8/14 • Penstock materials procurement – APC • Penstock installation – local contractor(s) or force account • Generating equipment procurement – APC • Powerhouse fabrications – Reynold Grey Machining and Services • Powerhouse construction – local contractor(s) and force account • Distribution line construction – local contractor(s) and force account • Testing and start-up – APC Reynold Grey Machining and Services is a welding and fabrication company in Port Townsend, Washington that APC has used frequently for similar work, including fabrication of container modules for diesel powerplants recently installed in Slana and Allakaket. Reynold Grey is located near APCs engineering staff, who can conveniently oversee the proposed fabrication work. APC will negotiate purchase orders for materials and equipment from vendors who have performed work on other, similar APC hydropower projects. 4.1.3 Project Accountant(s) Indicate who will be performing the accounting of this project for the grantee and include a resume. In the electronic submittal, please submit resumes as separate PDFs if the applicant would like those excluded from the web posting of this application. If the applicant does not have a project accountant indicate how you intend to solicit financial accounting support. AP&T’s utility finance department will perform project accounting tasks under the leadership of CFO Chad Haggar. Chad Haggar, CPA, CFO – Lead Accountant Christine Overly – Senior Accountant – Grant Funds Administrator RESUMES OF KEY PERSONNEL ATTACHED. 4.1.4 Financial Accounting System Describe the controls that will be utilized to ensure that only costs that are reasonable, ordinary and necessary will be allocated to this project. Also discuss the controls in place that will ensure that no expenses for overhead, or any other unallowable costs will be requested for reimbursement from the Renewable Energy Fund Grant Program. APC is a regulated utility, and is required to track and substantiate expenses in a manner which is acceptable to the Regulatory Commission of Alaska. APC is also accustomed to maintaining project records in a manner which is acceptable to the AEA, and the State of Alaska, for grant-funded projects. Thus, APC is accustomed to maintaining data on utility costs and expenditures which meets with a very high standard in terms of assuring that expenses are reasonable, ordinary, and necessary. APC is a private sector business which is accustomed to managing and controlling costs in order to maximize value and return on investment while ensuring sustainable benefits. 4.2 Local Workforce Criteria: Stage 2-2.E: The project uses local labor and trains a local labor workforce. Describe how the project will use local labor or train a local labor workforce. APC routinely employs local labor as full and part time employees. APC will contract aspects of Phase II and III activities to the local labor pool if their skills match project needs. Studies to be conducted may require other Alaskans to come to POW to conduct the work if local skill isn’t Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 21 of 44 7/8/14 available. APC has already trained the local POW workforce to be telephone technicians, power linemen, powerhouse operators, diesel mechanics, and customer service representatives, etc.; and will continue to do so. During the construction phase the local labor force will be more extensively utilized. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 22 of 44 7/8/14 SECTION 5 – TECHNICAL FEASIBILITY 5.1 Resource Availability Criteria: Stage 2-3.A: The renewable energy resource is available on a sustainable basis, and project permits and other authorizations can reasonably be obtained. 5.1.1 Proposed Energy Resource Describe the potential extent/amount of the energy resource that is available, including average resource availability on an annual basis. Describe the pros and cons of your proposed energy resource vs. other alternatives that may be available for the market to be served by your project. For pre-construction applications, describe the resource to the extent known. For design and permitting or construction projects, please provide feasibility documents, design documents, and permitting documents (if applicable) as attachments to this application. Amount of Energy Available, and Pros and Cons of Project: Proposed Energy Resource. The Neck Lake site has the potential to generate 3.2 GWh per year with an installed capacity of 750 kW, however, that would be much greater than existing community needs. APC will evaluate the optimum installed capacity during Phase II; at this time an installed capacity of 124 kW is estimated as being appropriate. Lowers Energy Costs. It is currently estimated that the project will be able to produce clean energy for approximately $0.30 less (50% less) than the cost of diesel-fired generation of electricity. Over time, annual savings will increase as the cost of diesel fuel continues to escalate over stabile hydropower pricing. Stabilizes Energy Costs Long Term. The project will stabilize local energy costs by reducing dependency on diesel fuel – a volatile commodity with costs which escalate faster than the rate of inflation. Hydropower maintenance and operating costs are extremely low compared to that those associated with diesel-fired generation. Long Project Lifespan with Additional Cost-Savings Available Beyond Capital Cost Repayment. The project has an estimated useful life of over 50 years. Properly constructed hydropower sites can provide over 100+ years of reliable service. (For example, AP&T’s Dewey Lakes hydropower project has been operating for 113 years.) After the financing period is complete and capital costs are paid off, the cost of maintaining and operating a hydropower project drops to very low levels. Diesel Fuel Displacement Benefit. The project will displace approximately 99.5% of Whale Pass’s diesel-fired generation of electricity with clean, renewable hydropower from a local, low-impact source. Supports State Renewable Energy Policy Goals. By supplanting diesel-fired generation with clean, renewable hydropower, the project will help to support the State of Alaska’s goal of 50% renewable energy by 2025. No Difficulties with Power Sales Agreements. The project is being proposed by APC, the incumbent utility, as a self-build project. Benefits Community which is Still 100% Diesel Dependent. Unlike other communities of Prince of Wales Island, Whale Pass has not yet had the opportunity to transition from 100% diesel-fired generation to an energy mix including renewables. The most recently available AEA PCE report identifies $0.62 kWh pricing for this service region, with an average PCE payment of $0.39 per eligible kilowatt hour. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 23 of 44 7/8/14 Generates Significant Power Cost Equalization Savings for the State of Alaska. Due to current 100% dependency on diesel-fired generation, the State of Alaska would experience significant Power Cost Equalization subsidization savings. State PCE statistics indicate the 54.9% of total kWh sold in Whale Pass in FY14 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 45% of cost -savings being realized by current ratepayers.5 A Reasonable Increment of Hydropower. Economic viability of many hydropower projects in Alaska is challenged by the difficulty of matching the utility’s incremental load growth to the size of locally available hydropower resources; this produces the frequently occurring situation in which a portion of a project’s power and energy from a new hydropower project cannot be sold during initial years of operation. Neck Lake is a small increment of power and energy, which APC anticipates can be integrated within the regional utility system without these types of challenges to economic and financial feasibility. Experienced Hydropower Developer. APC has significant experience developing, owning, and operating low impact hydropower projects. APC currently owns and operates 7 hydropower projects, with its 8th and 9th projects under construction (Hiilangaay and Yerrick Creek). APC’s parent company, AP&T, has over 50 years of experience as a private sector Alaskan business engaged in ownership, development, and reliable operation of hydropower projects. Existing Investment to Date. Reconnaissance phase activities have been completed due to private investment by both the AEA and APC in which discussions with SSRAA occurred, topographic survey was completed, and a jurisdictional determination with FERC was completed. Disadvantage – Large Capital Expenditure Requirement. The major drawback of hydropower projects is that they are extremely capital intensive. While hydropower projects have very long useful lifespans (50+ or even 100+ years), commercial financing is typically available for a 30 year period at most. Whale Pass is a relatively small increment of new hydropower (0.124 MW), which helps reduce the total capital expenditure required. Ease of Integration. Hydropower can be readily incorporated alongside diesel-fired generation within a small utility system, with minimal integration concerns. Discussion of Energy Technology Alternatives in Whale Pass Region • No other viable alternative energy sources have been identified in the Whale Pass region. • Transmission Interconnection to POW Grid. A 25 mile transmission connection would connect Whale Pass to the existing the Prince of Wales grid, providing access to APC hydropower assets, however, the transmission connection project would be more costly than the Neck Lake micro hydropower project, would be less reliable, and would have a shorter useful lifespan. • Diesel: A Costly and Unsustainable Energy Source – Whale Pass is currently 100% dependent on diesel-fired generation. This energy source is very costly, with pricing escalating faster than inflation due to the rising price of petroleum – a volatile commodity sensitive to a wide variety of supply risks and geopolitical factors. The high cost of diesel- fired generation places financial pressure on families and businesses in Whale Pass. 5 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/Content/Programs/PCE/Documents/FY14PCEStatisticalRptByComtAmended.pdf Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 24 of 44 7/8/14 Continued 100% dependency on diesel-fired generation is not a sustainable way of life for residents of Whale Pass. 5.1.2 Permits Provide the following information as it may relate to permitting and how you intend to address outstanding permit issues. • List of applicable permits • Anticipated permitting timeline • Identify and describe potential barriers Applicable Permits: • 404 permit (Corps of Engineers) • FERC License • Water right (ADNR), • State land easement (ADNR) • Fish habitat permit (ADF&G) • SHPO review Permitting Timeline: APC expects to complete environmental and design studies in 2017 for Phase II. Phase III permitting, licensing, and final design are anticipated to be completed by the end of 2019 due to the FERC licensing process. Potential Permitting Barriers: There are no known permitting barriers at this time. 5.2 Project Site Criteria: Stage 2-3.B: A site is available and suitable for the proposed energy system. Describe the availability of the site and its suitability for the proposed energy system. Identify potential land ownership issues, including whether site owners have agreed to the project or how you intend to approach land ownership and access issues. This project is located on lands owned by the State of Alaska, and SSRAA. As Phase II and Phase III activities progress, APC will be applying for a lease or easement from the State of Alaska, and will negotiate an arrangement with SSRAA. SSRAA has provided the applicant with a letter of support for this project (enclosed). The hydroelectric facilities will be designed to avoid interference with the existing salmon rearing and collection facilities operated at Neck Lake by the SSRAA. APC and SSRAA have agreed to work cooperatively to develop a hydropower project that will be junior to all needs of the Neck Lake hatchery, and will assure no adverse impacts to the hatchery or salmon runs. The project will help support long-term sustainability of hatchery operations by providing affordable hydropower at approximately half the cost of current diesel-fired generation, with pricing remaining stabile long term. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 25 of 44 7/8/14 EXHIBIT 3: PROJECT DESIGN 5.3 Project Risk Criteria: Stage 2-3.C: Project technical and environmental risks are reasonable. 5.3.1 Technical Risk Describe potential technical risks and how you would address them. APC believes that its experience designing, constructing, and operating similar small hydropower projects in Alaska; its longstanding vendor, technical service, supply chain relationships and industry knowledge; and its incumbent project development resources will help minimize risks and control costs. APC has a strong understanding of risks through development/construction experience, as well as an understanding of the processes involved in creating a durable hydropower asset capable of 50+ years of reliable, safe operation. APC’s engineering staff has been involved in the design, construction and operation of hydroelectric projects since the 1980’s. APC currently owns and operates 7 hydropower projects in Alaska, with its 8th and 9th projects (Hiilangaay and Yerrick Creek) currently under construction. APC currently maintains over 250 miles of transmission line and has seasoned staff to maintain diesel generators and hydro power plants. APC has administrators responsible for multi-million dollar budgets, including the management of 60+ employees, equipment, and all generation and distribution resources. Activities currently proposed for AEA REF Round IX funding support will include predevelopment activities which assist in identifying and mitigating risks. Site Control – APC will apply to ADNR for development rights on state lands. APC is confident that the Neck Lake hydropower facility will not conflict with the SSRAA operation already on the site. APC and SSRAA have agreed to work cooperatively to develop a hydropower project that will be junior to all needs of the Neck Lake hatchery, and will assure no adverse impacts to the hatchery or salmon Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 26 of 44 7/8/14 runs. SSRAA has also provided a letter of support, which is enclosed. The project will help support long-term sustainability of hatchery operations by providing affordable hydropower at approximately half the cost of current diesel-fired generation, with pricing remaining stabile long term. Seismic – Project components will be designed appropriately for seismic activity, since the Project will be located in a moderate-risk seismic zone. Structures will be buried as much as possible to minimize seismic impacts. Underground Construction – The project does not include underground construction, which can be fraught with cost overrun potential. Geotechnical investigations will be made at the diversion and powerhouse areas to provide an adequate level of knowledge about ground conditions at those sites. Inclement Weather – Working conditions in the project area during the winter could cause brief interruptions of the construction schedule. If prolonged interruptions occur that could jeopardize the completion schedule, APC will add contractors or more personnel as necessary to get back on schedule. Cost-Overrun – APC believes that its experience constructing similar small hydropower projects in Alaska and its mature supply chain relationships shall minimize cost-overrun risks, and inform determination of a reasonable contingency margin. Environmental Opposition – No environmental opposition to the project is known. However, there is environmental opposition to continued diesel-fired generation in the Whale Pass region, which will be addressed through development of the project. Risks of Non-Development – Failing to develop the renewable energy assets due to lack of interest or support by the State of Alaska and others will leave the residents of Whale Pass dependent on the diesel-fired generation of electricity. If diesel-dependency persists, this community can expect exacerbated socioeconomic distress, continued lack of economic opportunity, and the inability to respond to emerging commercial opportunities and support new economic development. Private Sector Investment Helps Mitigate Risks – Alaska Power & Telephone subsidiary APC will be undertaking development of the project. In addition to providing cash match to predevelopment activities, AP&T anticipates investing substantially in construction of the project. Because private sector businesses are motivated by the ability to earn a profit, as well as the adverse financial impacts of cost-overruns or project failure, AP&T – as an active investor – will be strongly motivated to mitigate risks, and assure the project is a success. 5.3.2 Environmental Risk Explain whether the following environmental and land use issues apply, and if so how they will be addressed: • Threatened or endangered species • Habitat issues • Wetlands and other protected areas • Archaeological and historical resources • Land development constraints • Telecommunications interference • Aviation considerations • Visual, aesthetics impacts Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 27 of 44 7/8/14 • Identify and describe other potential barriers Threatened and Endangered Species: No impacts are anticipated to threatened and endangered species, due to the project’s location and small size (<0.5 acres). An environmental assessment will be made in Phase III as part of the FERC licensing process, which includes agency consultation. Habitat Issues: The Southern Southeast Regional Aquaculture Association (SSRAA) has established a rearing and trapping facility at the lake and outlet stream. Coho salmon smolts are reared in pens in the lake, then released into the lake for migration out to tidewater during the spring. When the adults return, they ascend a ladder into a single raceway, where they are quickly processed for shipment to markets in the Lower 48. Water for the raceway and ladder is diverted from the head of the second (middle falls). SSRAA’s existing knowledge of fish usage of the stream may allow the project to go without additional fish surveys. However, until consultation begins, we are assuming fish surveys will be required. The hydroelectric facility will be designed to avoid interference with the existing salmon rearing and collection facilities. APC and SSRAA have agreed to work cooperatively to develop a hydropower project that will be junior to all needs of the Neck Lake hatchery, and will assure no adverse impacts to the hatchery or salmon runs. The project will help support long-term sustainability of hatchery operations by providing affordable hydropower at approximately half the cost of current diesel-fired generation, with pricing remaining stabile long term. Wetlands: There is potential for a small amount of wetlands to be impacted. It is expected that a wetlands delineation may be necessary to determine what if any impacts may occur. Archaeological & Historical Resources: A site review by the SHPO is required to determine necessity of an archaeological survey. Land Development Constraints: APC will coordinate with SSRAA to make sure their needs and goals are not affected by construction and operation of the Project. Telecommunications Interference: The 12 kV distribution line will not create interference with telecommunications. Aviation Considerations: There is no significant aviation in the Project area and the project infrastructure will be within the range of existing tree heights. Visual, Aesthetic Impacts: The Project will not be in a visually or aesthetically special view shed that needs protection. Potential Barriers: None. 5.4 Existing and Proposed Energy System Criteria: Stage 2-3.D: The proposed energy system can reliably produce and deliver energy as planned. 5.4.1 Basic Configuration of Existing Energy System Describe the basic configuration of the existing energy system. Include information about the number, size, age, efficiency, and type of generation. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 28 of 44 7/8/14 Existing Energy Generation and Usage a) Basic configuration (if system is part of the Railbelt 6 grid, leave this section blank) i. Number of generators/boilers/other 3 ii. Rated capacity of generators/boilers/other Unit #1 = JD4045, 70 kW, Installed 1995, 11.24 kWh/gal. (average from 2013) Unit #2 = JD4045, 70 kW, Installed 1995, 11.95 kWh/gal. (average from 2013) Unit #3 = JD6065, 110 kW, Installed 2008, 13.33 kWh/gal. (avg. 2013) iii. Generator/boilers/other type As noted above iv. Age of generators/boilers/other As noted above v. Efficiency of generators/boilers/other 12.16 kWh/gal. of diesel (aggregate for all generators)* vi. Is there operational heat recovery? (Y/N) If yes estimated annual displaced heating fuel (gallons) No b) Annual O&M cost (if system is part of the Railbelt grid, leave this section blank) i. Annual O&M cost for labor $0.22 / kwh non-fuel cost (labor and non-labor) ii. Annual O&M cost for non- labor $0.22 / kwh non-fuel cost (labor and non-labor) c) Annual electricity production and fuel usage (fill in as applicable) (if system is part of the Railbelt grid, leave this section blank) i. Electricity [kWh] 300,000 kWh (2014) – This figure does not include "off-grid" residents running numerous dispersed diesel gensets, who would reconnect in the event more affordable hydropower becomes available. APC anticipates these connections could increase the total demand to approximately 450,000 kWh. ii. Fuel usage Diesel [gal] 36,000 Other iii. Peak Load 34.40 kW – This figure does not include "off-grid" residents running numerous dispersed diesel gensets, who would reconnect in the event more affordable hydropower becomes available. iv. Average Load 34.15 kW – This figure does not include "off-grid" residents running numerous dispersed diesel gensets, who would reconnect in the event more affordable hydropower becomes available. 6 The Railbelt grid connects all customers of Chugach Electric Association, Homer Electric Association, Golden Valley Electric Association, the City of Seward Electric Department, Matanuska Electric Association and Anchorage Municipal Light and Power. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 29 of 44 7/8/14 v. Minimum Load 26 kW – This figure does not include "off-grid" residents running numerous dispersed diesel gensets, who would reconnect in the event more affordable hydropower becomes available. vi. Efficiency 12.16 kWh/gal. vii. Future trends Use of electricity likely to increase with more affordable rates and with reconnection of current "off-grid" residents. d) Annual heating fuel usage (fill in as applicable) i. Diesel [gal or MMBtu] NA ii. Electricity [kWh] NA iii. Propane [gal or MMBtu] NA iv. Coal [tons or MMBtu] NA v. Wood [cords, green tons, dry tons] NA vi. Other NA *AEA Report. Power Cost Equalization Program - Statistical Data by Community. 2014 Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 30 of 44 7/8/14 5.4.2 Future Trends Describe the anticipated energy demand in the community over the life of the project. Load is expected to grow as residence switch to hydropower over self-generation methods. The project will help support long-term sustainability of Neck Lake SSRAA hatchery operations by providing affordable hydropower at approximately half the cost of current diesel-fired generation, with pricing remaining stabile long term. This will support and sustain the vitality of commercial and recreational fishing resources in the region. The project ability to lower electric rates may also encourage more home building and commercial enterprises in and around Whale Pass. 5.4.3 Impact on Rates Briefly explain what if any effect your project will have on electrical rates in the proposed benefit area over the life of the project. For PCE eligible communities, please describe the expected impact would be for both pre and post PCE. It is currently estimated that the project will be able to produce clean energy for approximately $0.30- $0.31 less (50% less) than the cost of diesel-fired generation of electricity. Over time, annual savings will increase as the cost of diesel fuel continues to escalate over stabile hydropower pricing. Provides more affordable renewable energy, reducing energy costs from $0.62 to $0.32 / kWh in year one, increasing over time as the cost of diesel fuel rises. (Estimates based on recon-level financial and economic modelling.) 5.4.4 Proposed System Design Provide the following information for the proposed renewable energy system: • A description of renewable energy technology specific to project location • Optimum installed capacity • Anticipated capacity factor • Anticipated annual generation • Anticipated barriers • Integration plan • Delivery methods Renewable energy technology specific to location – The Project will be a conventional run-of- river hydroelectric project. Project features shall include: • 400 feet of single lane access road • Intake with fish screen, 34 cfs diversion capacity • 350 feet of 30-inch-diameter pipeline • Powerhouse with four 31-kW generating units, each consisting of a pump-as-turbine and synchronous generator • Upgrade of about 4 miles of distribution line from single-phase to three-phase to reach the diesel plant in Whale Pass. Hydroelectric technology is well established, with over 100+ years of successful commercial application in southeast Alaska, British Columbia, and the Pacific Northwest. The Project will utilize the abundant rainfall and steep topography afforded by the falls on the Neck Lake outlet stream to generate renewable energy. Optimum installed capacity – 124 kW (to be confirmed by Phase II studies). Anticipated capacity factor – TBD. Estimated at 40%. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 31 of 44 7/8/14 Anticipated annual generation – Potentially 450 MWh/yr, providing “off-grid” residents connect to receive more affordable electricity. As Whale Pass loads grow, consistent with estimates within the southeast Alaska integrated resource plan, the project would be able to generate as much as 1,000 MWh/yr with the proposed installed capacity of 124 kW. Anticipated barriers – No technological barriers. Proposed System Design Capacity and Fuel Usage (Include any projections for continued use of non-renewable fuels) a) Proposed renewable capacity (Wind, Hydro, Biomass, other) [kW or MMBtu/hr] 124 kWh run-of-river hydropower b) Proposed annual electricity or heat production (fill in as applicable) i. Electricity [kWh] 1,000,000 kWh max. (300,000 kWh at current load levels) ii. Heat [MMBtu] NA c) Proposed annual fuel usage (fill in as applicable) i. Propane [gal or MMBtu] NA ii. Coal [tons or MMBtu] NA iii. Wood or pellets [cords, green tons, dry tons] NA iv. Other NA d) i. Estimate number of hours renewable will allow powerhouse to turn diesel engines off (fill in as applicable) Approximately 8,716 hours annually 5.4.5 Metering Equipment Please provide a short narrative, and cost estimate, identifying the metering equipment that will be used to comply with the operations reporting requirement identified in Section 3.15 of the Request for Applications. The project will be operated by a SCADA system which will allow for remote viewing and control of the project. This system will record the amount of kWh generated as well as other data. Customers in Whale Pass are currently metered to record their usage. Cost of the SCADA system is included within the project’s construction budget. A plant log is kept at each powerhouse to document conditions related to daily operations, including problems, repairs, and maintenance. Calculations are routinely made to determine water use and electricity generated. Comparisons to how much diesel fuel has been offset by diesel generation can then be made. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 32 of 44 7/8/14 SECTION 6 – ECONOMIC FEASIBILITY AND BENEFITS 6.1 Economic Feasibility Criteria: Stage 2-4.A: The project is shown to be economically feasible (net positive savings in fuel, operation and maintenance, and capital costs over the life of the proposed project). 6.1.1 Economic Benefit Explain the economic benefits of your project. Include direct cost savings, and how the people of Alaska will benefit from the project. The benefits information should include the following: • Anticipated annual and lifetime fuel displacement (gallons and dollars) • Anticipated annual and lifetime revenue (based on i.e. a Proposed Power Purchase Agreement price, RCA tariff, or cost based rate) • Additional incentives (i.e. tax credits) • Additional revenue streams (i.e. green tag sales or other renewable energy subsidies or programs that might be available) The economic model used by AEA is available at http://www.akenergyauthority.org/Programs/Renewable-Energy-Fund/Rounds#round9. This economic model may be used by applicants but is not required. The final benefit/cost ratio used will be derived from the AEA model to ensure a level playing field for all applicants. If used, please submit the model with the application. The AEA’s econometric model calculates a B/C Ratio of 1.75, total NPV benefits of $5.12m, and NPV net benefit of $2.6m Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 33 of 44 7/8/14 Project Description Community Nearest Fuel Community Region RE Technology Project ID Applicant Name Project Title Results NPV Benefits $5,120,820.30 NPV Capital Costs $2,931,626 B/C Ratio 1.75 NPV Net Benefit $2,665,630 Performance Unit Value Displaced Electricity kWh per year 450,000 Displaced Electricity total lifetime kWh 22,500,000 Displaced Petroleum Fuel gallons per year 36,000 Displaced Petroleum Fuel total lifetime gallons 1,800,000 Displaced Natural Gas mmBtu per year - Displaced Natural Gas total lifetime mmBtu - Avoided CO2 tonnes per year 365 Avoided CO2 total lifetime tonnes 18,270 Proposed System Unit Value Capital Costs $3,019,575$ Project Start year 2021 Project Life years 50 Displaced Electric kWh per year 450,000 Displaced Heat gallons displaced per year - Renewable Generation O&M $ per year 30,196 Electric Capacity kW 124 Electric Capacity Factor %40 Heating Capacity Btu/hr 0 Heating Capacity Factor %0 Total Public Benefit 2015$ (Total over the life of the project) Base System Size of impacted engines (select from list)$/kWh Diesel Generator O&M 151-360kW 0.203$ Applicant's Diesel Generator Efficiency kWh per gallon Total current annual generation kWh/gallon Diesel Generation Efficiency 12.50 Whale Pass Whale Pass Rural Hydro (Run of River) Neck Lake Hydro Alaska Power Company Neck Lake Hydropower Project: Phases II-III Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 34 of 44 7/8/14 Annual fuel displacement = 36,000/gal. Annual fuel savings = Will depend fuel prices that year. Estimated at $124,200 in 2021, per AEA fuel pricing dataset. Lifetime fuel displacement = 1,800,000/gal. over 50 years; hydro is capable of 100+ years of service Lifetime cost savings = $8,946,000 per AEA fuel pricing dataset Hours diesel expected to be OFF/year: 8,716 [99.5%] Public Benefit – The project will help support long-term sustainability of Neck Lake hatchery operations by providing affordable hydropower at approximately half the cost of current diesel-fired generation, with pricing remaining stabile long term. This will support and sustain the vitality of commercial and recreational fishing resources in the region. The project will also significantly reduce electric rates for the community of Whale Pass and potentially encourage more commercial or business development. Produces significant PCE benefits for the State of Alaska. PCE is a complex calculation with outputs which are a function of a variety of variables, including: 1) level of legislatively authorized appropriation; 2) the performance of the PCE endowment, and level of investment income produced during a given period; 3) current power and energy prices in “benchmark” communities used as a point of comparison, which in turn are determined by their own unique set of variables; 4) the cost of diesel fuel.7 The extent to which PCE subsidization is deployed in recipient communities is a function of the level of energy consumed by eligible recipients, and in the case of “community facilities,” a function of local population. This makes it difficult to forecast PCE savings. However, State PCE statistics indicate the 54.8% of total kWh sold in Whale Pass in FY14 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 45% of cost-savings being realized by current ratepayers.8 Due to the fact that PCE subsidizes the first 500 kWh per month of residential energy purchases, and the first 70 kWh per month x the community population of community facility expenses, the State of Alaska is “at the front of the line” to experience cost savings for PCE-eligible ratepayer classes. These PCE savings can be used to assist other, less fortunate communities in other parts of Alaska. Lowers Energy Costs. It is currently estimated that the project will be able to produce clean energy for approximately $0.30 less than the current cost of diesel-fired generation of electricity. Over time, annual savings will increase as the cost of diesel fuel continues to escalate over stabile hydropower pricing. Stabilizes Energy Costs Long Term. The project will stabilize local energy costs by reducing dependency on diesel fuel – a volatile commodity with costs which escalate faster than the rate of inflation. Hydropower maintenance and operating costs are extremely low compared to that those associated with diesel-fired generation. Long Project Lifespan with Additional Cost-Savings Available Beyond Capital Cost Repayment. The project has an estimated useful life of over 50 years. Properly constructed hydropower sites can provide over 100+ years of reliable service. (For example, APC’s Dewey Lakes hydropower project has been operating for 113 years.) After the financing period is complete and 7 Source: http://www.akenergyauthority.org/Programs/PCE 8 Source: http://www.akenergyauthority.org/Programs/PCE Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 35 of 44 7/8/14 capital costs are paid off, energy costs drop dramatically, reflecting the relatively low level of costs associated with operating and maintaining a hydropower project. Generates Significant Power Cost Equalization Savings for the State of Alaska. Due to current 100% dependency on diesel-fired generation, the State of Alaska would experience significant Power Cost Equalization subsidization savings. State PCE statistics indicate that 54.8% of total kWh sold in Whale Pass in FY14 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 45% of cost-savings being realized by current ratepayers.9 At present, APC estimates PCE savings to be $3,160,850 over the 50-year life of the Project. The AEA’s econometric model provides a B/C Ratio of 1.75. The project will help support long-term sustainability of Neck Lake hatchery operations by providing affordable hydropower at approximately half the cost of current diesel-fired generation, with pricing remaining stabile long term. This will support and sustain the vitality of commercial and recreational fishing resources in the region. • Replaces approximately 99.5% of diesel-fired generation of electricity in the Whale Pass region. • Provides more affordable renewable energy, reducing energy costs from $0.62 to $0.32 / kWh in year one, increasing over time as the cost of diesel fuel rises. (Estimates based on recon-level financial and economic modelling.) • State PCE statistics indicate that 54.8% of total kWh sold in FY14 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 45% of cost-savings being realized by current ratepayers.2 • Helps to support the State of Alaska’s goal of 50% renewable energy by 2025. • Will stabilize energy prices long term by reducing dependency upon diesel fuel – a volatile commodity with pricing which escalates significantly faster than inflation. • By replacing diesel-fired generation, the project will reduce emissions, avoid “social cost of carbon” costs, and will reduce ambient noise associated with operation of diesel-fired generators in Whale Pass. This includes liability, risk, and noise associated with many “off- grid” residents’ dispersed small generators. • Leverages private investment in renewables, allowing the private sector to share project development costs and risks. • Reduces operating costs for resident businesses, supporting business retention, growth and expansion. • Supports new economic development in the northern Prince of Wales region. • Helps assure long-term sustainability of the Neck Lake hatchery’s operations by providing affordable hydropower at approximately half the cost of current diesel-fired generation, with pricing remaining stabile long term. The Neck Lake hatchery is central to many commercial and recreational opportunities; the long term sustainability of this facility is vital to the region’s economic well-being. The hydroelectric facilities will be designed to avoid interference with the existing salmon rearing and collection facilities operated at Neck Lake by the Southern Southeast Regional Aquaculture Association (SSRAA). APC and SSRAA have agreed to work cooperatively to develop a hydropower project that will be junior to all needs of the Neck Lake hatchery, and will assure no adverse impacts to the hatchery or salmon runs. The SSRAA has provided a letter of support, which is enclosed. 9 Source: http://www.akenergyauthority.org/Programs/PCE Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 36 of 44 7/8/14 • Reduces operating expenses for essential community facilities, helping to support long-term sustainability. • Allows Whale Pass to “home source” its energy supply from local, renewable sources, reducing fuel purchases made outside of the community. • Reduces dependence on foreign oil. • Project avoids 13,195 tons (29,094,975 lbs) of carbon dioxide placed in the air over a 50 year operating period. Because hydropower projects last for 100+ years, these figures could reasonably be doubled. • Reduces the need to transport fuel to Whale Pass, lowering the potential for leaks and spills. Transferring fuel to APC’s storage tank would be less frequent, reducing the potential for spills during fueling, and keeping groundwater safer for the area. 6.1.2 Power Purchase/Sale The power purchase/sale information should include the following: • Identification of potential power buyer(s)/customer(s) • Potential power purchase/sales price - at a minimum indicate a price range • Proposed rate of return from grant-funded project Identify the potential power buyer(s)/customer(s) and anticipated power purchase/sales price range. Indicate the proposed rate of return from the grant-funded project. Price for power purchase/sale: Currently estimated at $0.30 less than the cost of diesel-fire generation, however, this is an early estimate which will be substantiated and revisited following application of AEA Round VIII funds for Phase II and III tasks. Buyer of power: APC will sell the power to itself; because APC is the utility for Whale Pass. Proposed Rate of Return from Grant-Funded Project: The rate of return for the Neck Lake hydropower project would be regulated by the Regulatory Commission of Alaska, and would generate a regulated return on private investment consistent with the rate of return for similar projects. As a regulated utility, APC / AP&T is not permitted to earn a rate of return on grant funds, or otherwise include grant funds in the rate base. APC would sell power at a cost-based rate, consistent with AEA requirements. 6.1.3 Public Benefit for Projects with Private Sector Sales For projects that include sales of power to private sector businesses (sawmills, cruise ships, mines, etc.), please provide a brief description of the direct and indirect public benefits derived from the project as well as the private sector benefits and complete the table below. See section 1.6 in the Request for Applications for more information. Does not apply. Renewable energy resource availability (kWh per month) NA Estimated sales (kWh) NA Revenue for displacing diesel generation for use at private sector businesses ($) NA Estimated sales (kWh) NA Revenue for displacing diesel generation for use by the Alaskan public ($) NA 6.2 Financing Plan Criteria: Stage 2-4.B: The project has an adequate financing plan for completion of the grant-funded phase and has considered options for financing subsequent phases of the project. 6.2.1 Additional Funds Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 37 of 44 7/8/14 Identify the source and amount of all additional funds needed to complete the work in the phase(s) for which REF funding is being applied in this application. Indicate whether these funds are secured or pending future approvals. Describe the impact, if any, that the timing of additional funds would have on the ability to proceed with the grant. Additional Funds – In the event of an award, APC shall provide $98,800 in funds to match AEA REF investment. 6.2.2 Financing opportunities/limitations If the proposed project includes final design or construction phases, what are your opportunities and/or limitations to fund this project with a loan, bonds, or other financing options? This application does include Phase III, which has final design within it. APC is capable of funding the project with a combination of private debt and equity; however, a combination of grant funds and a low interest rate are also required to make the project financially feasible. 6.2.3 Cost Overruns Describe the plan to cover potential cost increases or shortfalls in funding. APC is accustomed to carefully managing project costs to avoid cost overruns, and funding shortfalls. Because APC’s private capital is at risk, the company is strongly motivated to avoid these situations. APC has a very strong history of responsible budgeting, and cost-control on utility sector projects. APC believes its construction cost estimate includes responsible and realistic contingency and cost- escalation margins. APC will pay out of its general operating fund for cost increases or shortfalls in funding. 6.2.4 Subsequent Phases If subsequent phases are required beyond the phases being applied for in this application, describe the anticipated sources of funding and the likelihood of receipt of those funds. APC anticipates seeking state and federal funds and low interest loans to finance construction of the project. APC will also utilize private equity. APC believes that because the project has a positive benefit-cost ratio and healthy NPV benefit stream, it will appeal to funders, and be likely to compete successfully for funding. Also, due to its small size, the project has a relatively low capital cost for a hydropower project, which may perhaps make it easier to fund. 6.3 Other Public Benefit Criteria: Stage 3-4.C: Other benefits to the Alaska public are demonstrated. Avoided costs alone will not be presumed to be in the best interest of the public. Describe the non-economic public benefits to Alaskans over the lifetime of the project. For the purpose of evaluating this criterion, public benefits are those benefits that would be considered unique to a given project and not generic to any renewable resource. For example, decreased greenhouse gas emission, stable pricing of fuel source, won’t be considered under this category. Some examples of other public benefits include: • The project will result in developing infrastructure (roads, trails, pipes, power lines, etc.) that can be used for other purposes • The project will result in a direct long-term increase in jobs (operating, supplying fuel, etc.) • The project will solve other problems for the community (waste disposal, food security, etc.) Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 38 of 44 7/8/14 • The project will generate useful information that could be used by the public in other parts of the state • The project will promote or sustain long-term commercial economic development for the community Providing less expensive electricity to the salmon hatchery will help to sustain recreational and commercial fishing opportunities in Southeast Alaska. With less expensive electric rates more, businesses could operate and provide full time employment within in the community. The project will reduce air pollution from the diesel generation plant located in Whale Pass and green-house- gas (GHG) emissions. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 39 of 44 7/8/14 SECTION 7 – SUSTAINABILITY Describe your plan for operating the completed project so that it will be sustainable throughout its economic life. Include at a minimum: • Capability of the Applicant to demonstrate the capacity, both administratively and financially, to provide for the long-term operation and maintenance of the proposed project • Is the Applicant current on all loans and required reporting to state and federal agencies? • Likelihood of the resource being available over the life of the project • Likelihood of a sufficient market for energy produced over the life of the project Capability – Alaska Power & Telephone Company (AP&T), parent company of Alaska Power Company (APC) has been in operation since 1957 and has continued to grow its customer base to 40 communities in Alaska, from above the Arctic Circle to southeast Alaska. AP&T has the administrative, financial, operations, and engineering staff needed to operate and maintain hydropower projects. AP&T currently owns and operates 7 hydropower projects in Alaska and is currently constructing its 8th and 9th hydropower assets (Hiilangaay and Yerrick Creek). Loans and Reporting – APC is current with all loans and required reporting to state and federal agencies. Resource – Hydropower is a sustainable, renewable resource. Available hydropower potential at Neck Lake is significantly in excess of community needs. (Total of 750 kW versus 124 kW community need.) Sufficient Market – Installing this hydropower project will lower electric rates for the community of Whale Pass, which will support community sustainability, and rural business and employment growth. Community members who are currently generating their own power from small, less efficient diesel generators are likely to reconnect to receive more affordable service from the Neck Lake project, increasing the market for the project’s clean energy output. Proposed business structure(s) and concepts that may be considered – Project would be developed as an asset owned and operated by the incumbent utility, Alaska Power Company (APC). Proposed Operations & Maintenance – Project would be owned and operated by APC, an AP&T subsidiary. APC currently operates 7 hydropower projects in Alaska, and is in the process of constructing its 8th and 9th hydropower assets (Hiilangaay and Yerrick Creek). Back-up requirements – There will be no back-up systems installed. APC’s existing diesel power plant will provide 100% back-up power supply capacity. Identification of operational issues that could arise Mechanical – Well designed and constructed hydroelectric projects generally have few major mechanical operational issues once the inevitable initial bugs have been worked out during the commissioning period. Mechanical operational issues are typically replacement of worn parts. Commitment to reporting savings and benefits – In the event of State investment, APC would be glad to commit to reporting of savings and benefits in a manner consistent with AEA requirements. As a regulated utility serving PCE-eligible communities, APC is required to keep highly detailed records of costs. These records can also be used to help identify savings to the AEA. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 40 of 44 7/8/14 SECTION 8 – PROJECT READINESS Describe what you have done to prepare for this award and how quickly you intend to proceed with work once your grant is approved. Specifically address your progress towards or readiness to begin, at a minimum, the following: • The phase(s) that must be completed prior to beginning the phase(s) proposed in this application • The phase(s) proposed in this application • Obtaining all necessary permits • Securing land access and use for the project • Procuring all necessary equipment and materials Neck Lake Hydro was awarded $82,000 for recon and feasibility and $26,000 for final design for a total of $108,000 in AEA REF Round II funds (#2195455). Part of these funds were used to develop and submit a filing for a FERC jurisdictional determination. FERC determined that a license would be required for this project. Only $22,474.73 of total grant funds were expended, supporting activities including surveying and mapping, preparation of the FERC jurisdictional determination filling, and conceptual design. The remaining balance of funds was returned to the AEA. FERC’s finding that a license would be required resulted in APC terminating project activities due to concerns about project development costs. However, FERC has recently developed a small hydropower licensing track that should significantly expedite the licensing process and reduce the licensing costs associated with a small project such as Neck Lake. The availability of this project licensing track – in conjunction with diesel cost escalation estimates and key findings of the SEIRP – have lead APC to conclude that it is in the best interest of the ratepayers of Whale Pass to resume efforts to pursue the Neck Lake hydropower project. This finding is supported by updated reconnaissance-level financial and economic analysis completed by APC in 2014 and 2015. APC would complete remaining Phase II activities starting in July 2016, upon awarding of AEA funds. Contractors for field studies will be contacted prior to the summer of 2016 to ensure their availability. The phase(s) that must be completed prior to beginning the phase(s) proposed in this application – No phase must be completed prior to beginning the phases proposed in this application. The phase(s) proposed in this application – Phase II and Phase III are proposed in this application. Obtaining all necessary permits – Permits will be acquired in Phase III as well as a FERC license. Securing land access and use for the project – APC has an agreement with SSRAA and their hatchery for accessing the land to conduct Phase II and Phase III activities. Procuring all necessary equipment and materials – Procurement of equipment or materials will not be necessary for Phase II and III. SECTION 9 – LOCAL SUPPORT AND OPPOSITION Describe local support and opposition, known or anticipated, for the project. Include letters, resolutions, or other documentation of local support from the community that would benefit from this project. The Documentation of support must be dated within one year of the RFA date of July 8, 2015. Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 41 of 44 7/8/14 No local opposition is anticipated, as the proposed project would decrease electric rates, substitute clean energy for diesel fuel, and use a waterway which is already developed (for aquaculture). The hydroelectric facilities will be designed to avoid interference with the existing salmon rearing and collection facilities operated at Neck Lake by the Southern Southeast Regional Aquaculture Association (SSRAA). APC and SSRAA have agreed to work cooperatively to develop a hydropower project that will be junior to all needs of the Neck Lake hatchery, and will assure no adverse impacts to the hatchery or salmon runs. The SSRAA has provided a letter of support for this project (07/24/15), which is enclosed. The project will provide significant benefits to the hatchery, helping to assure long-term sustainability of the Neck Lake hatchery’s operations by providing affordable hydropower at approximately half the cost of current diesel-fired generation, with pricing remaining stabile long term. The Neck Lake hatchery is central to many commercial and recreational opportunities; the long term sustainability of this facility is vital to the region’s economic well-being. There is significant community opposition to continued reliance upon diesel-fired generation, due to high and escalating energy costs, and the hardships this produces for businesses and residents. SECTION 10 – COMPLIANCE WITH OTHER AWARDS Identify other grants that may have been previously awarded to the Applicant by the Authority for this or any other project. Describe the degree you have been able to meet the requirements of previous grants including project deadlines, reporting, and information requests. Neck Lake Hydro was awarded $82,000 for recon and feasibility and $26,000 for final design for a total of $108,000 in AEA REF Round II funds (#2195455). Part of these funds were used to develop and submit a filing for a FERC jurisdictional determination. FERC determined that a license would be required for this project. Only $22,474.73 of total grant funds were expended, supporting activities including surveying and mapping, preparation of the FERC jurisdictional determination filling, and conceptual design. The remaining balance of funds was returned to the AEA. Recent grant-funded projects have included: • Kasidaya Creek • Chistochina-Mentasta-Slana Line Extension • Tok Wind Recon • South Fork Hydro • Haines 5-10 Mile Line Extension • Lutak Line Extension • Kasaan Broadband • South Thorn Bay Electrification • Tetlin Intertie • Yerrick Creek Hydropower Project • North Prince of Wales Intertie (Coffman Cove / Naukati) • Reynolds Creek Hydropower Project • Mahoney Lake Hydropower Project • Schubee Lake Hydro Recon • Connelly Lake Hydro Recon • Carlson Hydro Recon • Neck Lake Hydro Recon • Eagle River Hydrokinetic • Tok Organic Rankine Cycle Unit Renewable Energy Fund Round IX Grant Application - Standard Form AEA 15003 Page 42 of 44 7/8/14 • Tok Biomass Feasibility Analysis • Eagle Solar Installation SECTION 11 – LIST OF SUPPORTING DOCUMENTATION FOR PRIOR PHASES In the space below please provide a list additional documents attached to support completion of prior phases. Project activities completed • Acquired topographic mapping (by Sentec) • Developed preliminary arrangement of project features • Prepared request for FERC jurisdictional determination • Prepared responses to FERC requests for additional information • Coordinated with SSRAA regarding preliminary project arrangement and potential impact mitigation measures • Received FERC Jurisdictional Determination SECTION 12 – LIST OF ADDITIONAL DOCUMENTATION SUBMITTED FOR CONSIDERATION In the space below please provide a list of additional information submitted for consideration. • Governing Body Resolution • Certification • Letters of Support • Figures • Project Timeline Chart • Resumes • Permitting • Photos • Governing Body Resolution [see Appendices] • Certification [see Appendices] • Letters of Support [see Appendices] • Figures [see Appendices] • Project Activities Completed • Project Timeline Chart [see Appendices] • Resumes [see Appendices] • Permitting [see Appendices] • Photos [see Appendices] APPENDICES  Governing Body Resolution  Certification  Letters of Support  Figures  Project Activities Completed  Project Timeline Chart  Resumes  Permitting  Photos GOVERNING BODY RESOLUTION CERTIFICATION LETTERS OF SUPPORT FIGURES FIGURE 4 FIGURE 5 PROJECT ACTIVITIES COMPLETED IN EARLIER PHASES • Acquired topographic mapping (by Sentec) • Developed preliminary arrangement of project features • Prepared request for FERC jurisdictional determination • Prepared responses to FERC requests for additional information • Coordinated with SSRAA regarding preliminary project arrangement and potential impact mitigation measures • Received FERC Jurisdictional Determination Topographic Mapping (by Sentec) 1ƒ :)(235.52')1ƒ :234.18'EFORPDERETSIGERROYEVR U S D NALLANOISS MICHAEL J. HORNENo. LS-5318SENTECSurveying Engineering2525 Gambell Street, Suite 200, Anchorage, Alaska 99503Tele: (907) 563-3835 Fax: (907) 563-3817 Preliminary Arrangement of Project Features FIGURE 4 Application to FERC for Jurisdictional Determination December 23, 2009 Kimberly D. Bose Office of Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Re: Neck Lake Hydro Project Petition for Declaratory Order Dear Ms. Bose: We respectfully submit this original via the Commissions e-filing system of the following Declaration of Intent and Petition for Declaratory order that the Neck Lake Hydro Project is not under the Federal Energy Regulatory Commission’s jurisdiction. The Applicant believes, after reviewing Section 23(b) of the Federal Power Act, that none of the criteria in Section 23(b) is met by this project. Therefore, this project should not be under the Commission’s jurisdiction. Reasons for Jurisdictional Determination:  Project located on State of Alaska land managed by DNR, not federal land.  The lake outlet stream is non-navigable with an anadromous barrier.  The project is not below any government dam nor will it use water from a government project.  The project will not impact interstate commerce because it will not connect to an interstate grid, nor will it impact operations by a hatchery on the outlet stream (extensive consultation will take place to ensure their operations are not impacted and the Appliant will see how they can benefit from the project as well). We respectfully request that the Commission evaluate this project for a jurisdictional determination. We believe this project does not meet any of the guidelines for being under Commission jurisdiction. Respectfully Submitted, Kimberly D. Bose, Secretary-FERC Neck Lake Hydroelectric Project December 23, 2009 p. 2 Jurisdictional Determination Glen D. Martin Project Manager (360) 385-1733 x122 (360) 385-7538 fax Enc. (as stated) Kimberly D. Bose, Secretary-FERC Neck Lake Hydroelectric Project December 23, 2009 p. 3 Jurisdictional Determination ALASKA POWER & TELEPHONE COMPANY DECLARATION OF INTENT FOR THE NECK LAKE HYDROELECTRIC PROJECT Submitted to: FEDERAL ENERGY REGULATORY COMMISSION Washington, D.C. DECEMBER 2009 Kimberly D. Bose, Secretary-FERC Neck Lake Hydroelectric Project December 23, 2009 p. 4 Jurisdictional Determination DECLARATION OF INTENT The location of the project: State: Alaska Town: near Whale Pass Street: N/A County: (Alaska does not have counties) Stream: Neck Lake outlet stream River Basin Name: N/A Township, Range, and Meridian: T66S, R79E, CRM Applicant Info: Alaska Power & Telephone Company (AP&T), an Alaska Corporation 193 Otto Street, P.O. Box 3222 Port Townsend, WA 98368 (360) 385-1733 x122 (360) 385-7538 FAX glen.m@aptalaska.com Local Electric Utility Company: Alaska Power & Telephone Company (AP&T), an Alaska Corporation P.O. Box 149 Klawock, AK 99925 (907) 755-4822 (907) 755-4823 FAX Greg Mickelson (greg.m@aptalaska.com) Kimberly D. Bose, Secretary-FERC Neck Lake Hydroelectric Project December 23, 2009 p. 5 Jurisdictional Determination INTRODUCTION This document is a declaration of intent to develop a 124 kW – 400 kW hydropower project at Neck Creek, which is approximately 1.5 miles southwest of the community of Whale Pass, Alaska, as shown in Figure 1. The Project is located in Section 35 within T66S, R79E, CRM (Copper River Meridian). The Project will utilize the natural flow out of Neck Lake. The proposed project is located on lands managed by the State of Alaska and is on a non- navigable stream. The project will provide hydroelectric power to an area that is 100% reliant upon diesel generation. The isolated area this project would serve is currently provided power by AP&T via its diesel generation plant. There would be no interconnection to an interstate power grid, as none exists. AP&T, an Alaska Corporation, further petitions the Federal Energy Regulatory Commission (FERC) for a Declaratory order that the proposed Neck Lake Hydropower Project is not within the Commission’s jurisdiction. The Applicant has reviewed Section 23(b) of the Federal Power Act (FPA) to determine whether the project falls within the stated jurisdictional criteria and believe that none of the four stated jurisdictional criteria are met by the Neck Lake Project. 1. PROJECT DESCRIPTlON AP&T proposes to construct a small run-of-river hydroelectric project at Neck Lake in the outfall stream below the lake, which is located 1.5 miles southwest of the community of Whale Pass on Prince of Wales Island, Alaska. The Project would supply power to the community of Whale Pass and would offset diesel generation, which is currently the sole source of electricity. The relatively high and modulated flows from the lake combined with the steep drop at the lower end of the outlet stream provide a good opportunity for a small run-of-river hydroelectric development. Facilities would include an access road, intake structure, 400 feet of penstock, a containerized power plant with generator rated at 124 kW – 400 kW, a tailrace channel, and upgrade of 4 miles of transmission line. The hydroelectric facilities will be designed to avoid interference with the existing salmon rearing and collection facilities operated at Neck Lake by the Southern Southeast Regional Aquaculture Association (SSRAA). AP&T conducted a reconnaissance study of the site in 2008, and determined that there is sufficient potential to almost always provide enough generation for Whale Pass loads. The Project will provide clean, renewable electricity, as well as rate stabilization and lower rates for AP&T’s Whale Pass customers. Kimberly D. Bose, Secretary-FERC Neck Lake Hydroelectric Project December 23, 2009 p. 6 Jurisdictional Determination 2. JURISDICTIONAL ANALYSIS Section 23(b) of the Federal Power Act would require project licensing of the project only if: a. It is located on a “Navigable Water” of the United States: b. It occupies lands of the United States: c. It utilizes surplus water or water power from a government dam; d. There was a “post-1935 construction” at the project and the project affected the interest of interstate commerce. The petitioner’s project does not meet any of these criteria. a. Navigability Neck Lake is not reachable via its outlet stream as the stream has an anadromous barrier and many cascades before reaching marine waters. Above Photo: Neck Lake outlet stream below lake b. Land Status The proposed project is located on State of Alaska land. No portion of the project is on Federal land. See the enclosed land status map and Status Plat map. Kimberly D. Bose, Secretary-FERC Neck Lake Hydroelectric Project December 23, 2009 p. 7 Jurisdictional Determination c. Surplus Water from Government Dam There are no government (Federal or State) dams near or above the project, nor will the project use water from a government dam. d. Affect on Interstate Commerce Regarding Interstate Commerce, this project is in an isolated, rural Alaskan location and will not connect with any interstate power grid because none exists in Alaska. This project is meant to get this one community off of diesel generation. Because this project is not on a navigable stream, it will not affect shipping or interstate commerce. Though the Southern Southeast Regional Aquaculture Association (SSRAA) has established a rearing and trapping facility at the lake and outlet stream for Coho, AP&T believes a project can be built that will benefit both. The Neck Lake Hatchery is for the purpose of improving Coho stock in the area. The Applicant will be working with the SSRAA to design the project so that their operations will not be impacted. Because this project will be design to have no impact on the SSRAA Coho salmon smolts rearing pens (which are in the lake) or their out migration from the lake to tidewater during the spring (by allowing them to flow over the diversion structure in the outlet stream), and ensuring flow in the summer when they return (summer Coho), this project will not impact Interstate commerce even if this hatchery is viewed as critical to interstate commerce. Operations can be set to work around the SSRAA’s schedule of activity and ensure flow when needed. Additionally, the project would not impact the SSRAA lake operations as the project would be below the lake outlet, operating in a run-of-river mode. The diversion structure will be above the anadromous barrier used by the hatchery to prevent fish from getting back up to the lake. 3. CONCLUSION In AP&T’s review of the applicable jurisdictional criteria found in Section 23(b) of the Federal Power Act, there was no evidence found that the Neck Lake Project meets any one of these criteria. AP&T therefore requests that the Federal Energy Regulatory Commission issue a Declaratory order finding that the project falls outside of the Commission’s jurisdiction and does not require a license or permit under the Federal Power Act. The facts presented herein are true to the best knowledge of the Applicant. Sincerely, Project Manager Responses to FERCs Additional Information Requests (AIR) for the Jurisdictional Determination • January 12, 2010 – AIR Response • February 4, 2010 – AIR Response • February 24, 2010 – AIR Response • March 16, 2010 – AIR Response • March 23, 2010 – AIR Response • March 30, 2010 – FERC Public Notice • November 4, 2010 – FERC Order From: Glen Martin [mailto:glen.m@aptalaska.com] Sent: Tuesday, January 12, 2010 10:46 AM To: Diane Murray Subject: Neck Lake Hydroelectric Project Addendum Diane, Attached is a revised Figure 2 for the jurisdictional determination.In addition,once or twice we stated the “SSRAA Hatchery”but it is not a hatchery.As stated in the Project Description on page 5,it is a rearing and collection facility.The SSRAA facility currently diverts water above the middle falls and returns it just below the lower falls.We intend to divert above the upper falls and return water just below the lower falls.W e will probably discharge into the bottom of the SSRAA’s fish ladder to avoid confusing the fish with another discharge point.W e will avoid interference with SSRAA by only utilizing flow that is in excess of their needs.They only operate their collection facility for a couple months a year.W e will be working with SSRAA to determine how much flow they need and how best to interface with their operation,but at minimum we figure we will discharge into their fish ladder. The diversion point for the hydroelectric project is shown in the application on page 6.The diversion structure will be a concrete wall varying in height from 1 to 3 feet,with an estimated length of 75 feet.The intake will be a prefabricated steel structure with a concrete foundation and will include a fish screen to prevent SSRAA’s smolts from being entrained or ingested.The diversion will be about 1300 feet below the lake outlet and as should be evident by the diversion height,will not hold enough water to back up onto USFS lands. I’ve included a photo of the powerhouse site.The powerhouse would be placed on the grass at right (the creek is on the left)and the SSRAA facility is behind the grass area.This site offers good,existing access and will make coordinating with the SSRAA facility that much easier. I hope this adequately addresses your questions.Please call me if you need anything further. Thank you, Glen Glen D.Martin Project Manager AP&T (360)385-1733 x122 20091223-4039 FERC PDF (Unofficial) 01/12/2010 20091223-4039 FERC PDF (Unofficial) 01/12/2010 BLANK PAGE [intentionally left blank] February 4, 2010 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room 1-A Washington, D.C. 20426 Subject: Neck Lake Hydroelectric Project Jurisdictional Determination – Additional Information Dear Ms. Bose: On December 23, 2009, Alaska Power & Telephone Company filed for a Jurisdictional Determination on the Neck Lake Hydroelectric Project. We would like to provide additional information to help clarify aspects of the project. Enclosed is a figure with photographs on a diagram showing various locations of project features and the environment they will be in. The diversion will raise the creek level in a small area behind it by 3 feet. The lake is 8 feet above the pool elevation of the diversion so that this project will not back up into the lake or cross over onto USFS lands. The distance from the diversion to the lake is approximately 1,300 feet, making the 8-foot- drop a gradual elevation change. However, at the diversion site, as can be seen in the enclosed figure, the short falls there indicate the grade of the creek is changing, getting steeper. The diversion will be at the beginning of these falls, which is the Upper Falls, so that the pool behind the diversion will be very small. The tidal area mentioned in the application is approximately 50 feet below the road bridge shown on the right hand side of the enclosed figure. The SSRAA collection facility collects returning fish at the base of the first anadromous barrier, or Lower Falls, which is indicated on the enclosed figure as the SSRAA Outfall. This project will discharge into the SSRAA collections facility outfall at the base of the anadromous barrier so that there are not two sources of flow to potentially confuse the returning fish. The transmission line upgrade will be to place new conductor on the existing wood poles currently distributing electricity in the area, which is also shown on the enclosed figure (photo of SSRAA collection facility with pole and transformer in foreground). No new poles are proposed to be installed. The new conductor will go into our existing diesel generation plant where switchgear and other controls exist. If there is any further information we can provide you, please contact us at the information below. Kimberly D. Bose, Secretary-FERC 2 Neck Lake Hydroelectric Project February 4, 2010 Jurisdictional Determination Respectfully Submitted, Glen D. Martin Project Manager (360) 385-1733 x122 glen.m@aptalaska.com Enc. (as stated) BLANK PAGE [intentionally left blank] February 24, 2010 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room 1-A Washington, D.C. 20426 Subject: Neck Lake Hydroelectric Project Jurisdictional Determination – Additional Information Dear Ms. Bose: On December 23, 2009, Alaska Power & Telephone Company filed for a Jurisdictional Determination on the Neck Lake Hydroelectric Project. We would like to provide a one- line diagram for this project as additional information for the determination. If there is any further information we can provide you, please contact us at the information below. Respectfully Submitted, Glen D. Martin Project Manager (360) 385-1733 x122 glen.m@aptalaska.com Enc. (as stated) BLANK PAGE [intentionally left blank] March 16, 2010 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room 1-A Washington, D.C. 20426 Subject: Neck Lake Hydroelectric Project Jurisdictional Determination – Additional Information Dear Ms. Bose: On December 23, 2009, Alaska Power & Telephone Company filed for a Jurisdictional Determination on the Neck Lake Hydroelectric Project. We would like to provide additional information to help clarify aspects of the project. Please accept the following enclosures:  Revised figure with photos over plan view of project  Revised one-line diagram  New Conceptual Design diagram  New Project Boundary diagram  New project description The Neck Lake Hydroelectric Project (Project) will not place infrastructure on federal land. Although the FS has jurisdiction over the road system with a 100-foot-wide right- of-way, the Project is outside this boundary. The Project will also not impact the lake that is within the FS managed lands, because the FS and State land boundary is between the lake and above the Projects diversion pool. More detail is provided in the enclosed Project description. To provide more clarity on the existing distribution systems on Prince of Wales Island (POW), though many are still isolated systems, such as that found at Whale Pass, they are owned, operated, and maintained by Alaska Power Company (APC). APC is a wholly owned subsidiary of Alaska Power & Telephone Company (AP&T; also the Applicant). APC also owns and operates all the diesel generation plants on the island, including Whale Pass. APC already has plans to upgrade their single-phase distribution system from Whale Pass to its end at the SSRAA Facility to three-phase because of an existing load imbalance on the line. APC has related to the Applicant that the load imbalance has been an ongoing problem and that they have a work-order and plan to upgrade the line this summer, 2010. The Applicant has notified them of plans to develop a small (124- Kimberly D. Bose, Secretary-FERC 2 Neck Lake Hydroelectric Project March 16, 2010 Jurisdictional Determination 400 kW) hydroelectric project at the end of their distribution system. Their upgrade will help accommodate getting hydropower into this area to offset or eliminate the use of diesel generation. The enclosed diagrams show where the existing distribution system will meet the proposed hydroelectric project. APC’s existing distribution system goes along the U.S. Forest Service Road from Whale Pass, but between the second to last pole and the pole serving the SSRAA Facility the existing distribution system passes onto State of Alaska lands. It is on State of Alaska lands that the project is located and will interconnect with the existing distribution grid. Please see the enclosed Project Boundary diagram for more detail. A previously supplied figure submitted (e-filed) on February 4, 2010, has been revised and is enclosed with this letter (figure with photos over plan view of project site). The one-line diagram submitted (e-filed) on February 24, 2010, has also been revised and is enclosed with this letter. An additional two figures are enclosed showing the project features on a recent topographic survey (F-1) the Applicant had conducted as well as a figure (G-1) with the Project boundary. A revised project description is enclosed due to the questions posed by the Commission staff which has provided more clarity about the project. In order to improve the application before it is public noticed by the Commission, we offer this revised description. In addition, photos are enclosed to provide a better understanding of the Project area and the layout of the SSRAA Facility and where the Project features will go in relation to the FS road ROW. If there is any further information we can provide you, please contact us at the information below. Respectfully Submitted, Glen D. Martin Project Manager (360) 385-1733 x122 glen.m@aptalaska.com Enc. (as stated) NECK LAKE HYDROELECTRIC PROJECT PROJECT DESCRIPTION Alaska Power & Telephone Company (AP&T) proposes to construct a small run-of-river hydroelectric project near Neck Lake in the outfall stream below the lake, which is located 1.5 miles southwest of the community of Whale Pass on Prince of Wales Island, Alaska. The Project would sell power to Alaska Power Company (APC), the power provider to the community of Whale Pass, which would offset diesel generation, their sole source of electricity. The relatively high and modulated flows from the lake combined with the steep drop at the lower end of the outlet stream provide a good opportunity for a small run-of-river hydroelectric development. Facilities would include an access road, an intake structure that would be approximately 1,300 feet below the lake outlet and would be 1-3 feet tall by 75 feet long across the creek, 400 feet of penstock, a containerized power plant with generator rated at 124 kW – 400 kW, a tailrace channel that would discharge into the Southern Southeast Regional Aquaculture Association (SSRAA) Facility discharge channel from its fishway. The project would be intertied to the existing distribution system operated by APC at the present service pole to the SSRAA Facility, located within the existing SSRAA property. All other lands around the project boundary are State of Alaska land, as shown on figure G-1: Project Boundary. The road is a U.S. Forest Service road that is outside the project boundary, also shown on figure G-1. The hydroelectric facilities will be designed to avoid interference with the existing salmon rearing and collection facilities operated at Neck Lake and the Neck Lake outlet stream by SSRAA. AP&T conducted a reconnaissance study of the site in 2008, and determined that there is sufficient potential to almost always provide enough generation for APC to offset Whale Pass loads. The Project will provide clean, renewable electricity, as well as rate stabilization and lower rates for APC’s Whale Pass customers. The Project is located outside any Federal land, is not located on a navigable stream, there is no government dam above the Project nor will the Project use water from a government project, and the Project will not impact interstate commerce because it will not connect to an interstate grid (non exists in Alaska) nor will it impact the nearby fish rearing and catchment facility operated by SSRAA because the Project would be operated to avoid any impacts. BLANK PAGE [intentionally left blank] March 23, 2010 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room 1-A Washington, D.C. 20426 Subject: Neck Lake Hydroelectric Project Jurisdictional Determination – Additional Information Dear Ms. Bose: On December 23, 2009, Alaska Power & Telephone Company filed for a Jurisdictional Determination on the Neck Lake Hydroelectric Project. We would like to provide additional information to help clarify aspects of the project. Please accept the following enclosures:  Plan view of lake outlet to the diversion structure  Elevation profile of the lake outlet to the diversion structure On March 17 Commission staff requested that we provide a plan and profile drawing of the Neck Lake outlet stream to cover the area from the lake outlet to our proposed project. Unfortunately, there is no mapping currently available that will provide suitable detail; USGS mapping in the area has a 100’ contour interval and our project mapping only covered the area from the USFS road to our proposed diversion, which is several hundred feet below the lake outlet. There are no roads or trails between the USFS road and the lake outlet and the terrain is very difficult, so conducting additional topographic mapping for this purpose is impractical. As an alternative, please see the attached annotated satellite image and profile. The satellite image was obtained through the Alaska State Geo-Spacial Data Clearinghouse website (www.asgdc.state.ak.us), and shows the lake outlet and stream to tidewater, as well as land ownership boundaries. AP&T has added annotation showing the location of the three waterfalls on the outlet stream and the proposed location of the project diversion. Note that the location of the lake outlet is indistinct and subject to interpretation. There is a distinct shallow area at the head of the outlet stream 1300 feet upstream from the proposed diversion (as evidenced by the reddish brown color), however it is likely that water currents would be very low in this area except during floods. It is not until about 700-800 feet above the diversion that whitewater can be detected in the satellite image. Kimberly D. Bose, Secretary-FERC 2 Neck Lake Hydroelectric Project March 23, 2010 Jurisdictional Determination In February of this year, AP&T had a surveyor take measurements to determine the elevation difference between the lake water surface and the proposed diversion. That difference was determined to be 11.3 feet. After adjusting all elevation information to a common datum (lake water surface elevation at 89 feet msl per USGS mapping), and assuming 750 feet as the distance between the lake and our diversion site, we have developed the attached stream profile. Although this profile is approximate, it does clearly show that AP&T’s proposed diversion will not cause any change in the lake level; the length of backwater is estimated to be 200-250 feet for a 3 foot increase in the water level at the diversion. If there is any further information we can provide you, please contact us at the information below. Respectfully Submitted, Glen D. Martin Project Manager (360) 385-1733 x122 glen.m@aptalaska.com Enc. (as stated) BLANK PAGE [intentionally left blank] UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Alaska Power &Telephone Company Docket No.DI10-5-000 NOTICE OF DECLARATION OF INTENTION AND SOLICITING COMMENTS, PROTESTS,AND/OR MOTIONS TO INTERVENE (March 30,2010) Take notice that the following application has been filed with the Commission and is available for public inspection: a.Application Type:Declaration of Intention b.Docket No:DI10-5-000 c.Date Filed:December 23,2009,and supplemented on January 12,February 4, February 24,March 16,and March 23,2010. d.Applicant:Alaska Power &Telephone Company e.Name of Project:Neck Lake Hydroelectric Project f.Location:The proposed Neck Lake Hydroelectric Project will be located on Neck Lake outlet stream,near the community of Whale Pass,Alaska,(T.66 S.,R.79 E., sec.35.,Copper River Meridian,Alaska). g.Filed Pursuant to:Section 23(b)(1)of the Federal Power Act,16 USC 817(b). h. Applicant Contact:Glen D.Martin,193 Otto Street,P.O.Box 3222,Port Townsend, WA 98368;telephone:(360)385-1733 x122;Fax:(360)385-7538;email: glen.m@aptalaska.com. i.FERC Contact:Any questions on this notice should be addressed to Diane M.Murray, (202)502-8838,or E-mail address:diane.murray@ferc.gov. j. Deadline for filing comments,protests,and/or motions:April 30,2010. Comments,Motions to Intervene,and Protests may be filed electronically via the Internet. See 18 CFR 385.2001(a)(l)(iii)and the instructions on the Commission’s website under 20100330-3014 FERC PDF (Unofficial) 03/30/2010 Docket No.DI10-5-000 2 the “eFiling”link.If unable to be filed electronically,documents may be paper-filed.To paper-file,an original and eight copies should be mailed to:Secretary,Federal Energy Regulatory Commission,888 First Street,NE.,Washington,D.C.20426.For more information on how to submit these types of filings,please go to the Commission’s website located at http://www.ferc.gov/filing-comments.asp. Please include the docket number (DI10-5-000)on any comments,protests,and/or motions filed. k. Description of Project:The proposed Neck Lake Hydroelectric Project would consist of:(1)a small reservoir;(2)a three-foot-high,75-foot-long dam,located approximately 1,300 feet below the Neck Lake outlet;(3)a 400-foot-long penstock;(4)a proposed powerhouse containing a generator with a capacity of 124 kW –400 kW;(5)a transmission line;(6)an access road;and (7)appurtenant facilities. When a Declaration of Intention is filed with the Federal Energy Regulatory Commission,the Federal Power Act requires the Commission to investigate and determine if the interests of interstate or foreign commerce would be affected by the project.The Commission also determines whether or not the project:(1)would be located on a navigable waterway;(2)would occupy or affect public lands or reservations of the United States;(3)would utilize surplus water or water power from a government dam;or (4)if applicable,has involved or would involve any construction subsequent to 1935 that may have increased or would increase the project's head or generating capacity, or have otherwise significantly modified the project's pre-1935 design or operation. l. Locations of the Application:Copies of this filing are on file with the Commission and are available for public inspection.This filing may be viewed on the web at http://www.ferc.gov using the "eLibrary"link.Enter the Docket number excluding the last three digits in the docket number field to access the document.You may also register online at http://www.ferc.gov/docs-filing/esubscription.asp to be notified via email of new filings and issuances related to this or other pending projects.For assistance,call 1- 866-208-3676 or e-mail FERCOnlineSupport@ferc.gov for TTY,call (202)502-8659.A copy is also available for inspection and reproduction at the address in item (h)above. m.Individuals desiring to be included on the Commission's mailing list should so indicate by writing to the Secretary of the Commission. n.Comments,Protests,or Motions to Intervene --Anyone may submit comments,a protest,or a motion to intervene in accordance with the requirements of Rules of Practice and Procedure,18 CFR 385.210,.211,.214.In determining the appropriate action to 20100330-3014 FERC PDF (Unofficial) 03/30/2010 Docket No.DI10-5-000 3 take,the Commission will consider all protests or other comments filed,but only those who file a motion to intervene in accordance with the Commission's Rules may become a party to the proceeding.Any comments,protests,or motions to intervene must be received on or before the specified comment date for the particular application. o.Filing and Service of Responsive Documents --All filings must bear in all capital letters the title "COMMENTS","PROTESTS",AND/OR "MOTIONS TO INTERVENE",as applicable,and the Docket Number of the particular application to which the filing refers.A copy of any Motion to Intervene must also be served upon each representative of the Applicant specified in the particular application. p.Agency Comments --Federal,state,and local agencies are invited to file comments on the described application.A copy of the application may be obtained by agencies directly from the Applicant.If an agency does not file comments within the time specified for filing comments,it will be presumed to have no comments.One copy of an agency's comments must also be sent to the Applicant's representatives. Nathaniel J.Davis,Sr., Deputy Secretary. 20100330-3014 FERC PDF (Unofficial) 03/30/2010 BLANK PAGE [intentionally left blank] 133 FERC ¶62,121 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Alaska Power &Telephone Compan y Docket No.DI10-5-000 ORDER RULING ON DECLARATION OF INTENTION AND FINDING LICENSING IS REQUIRED (Issued November 04,2010) 1.On December 23,2009,and supplemented on January 12,February 4, February 24,March 16,and March 23,2010,Alaska Power &Telephone Company filed a Declaration of Intention (DI)concerning the proposal to develop the Neck Lake Hydroelectric Project,to be located on Neck Lake outlet stream near the community of Whale Pass on Prince of Wales Island,Alaska (T.66 S.,R.79 E.,sec.35,Copper River Meridian,Alaska). PROJECT DESCRIPTION 2.The proposed Neck Lake Hydroelectric Project would consist of:(1)a small reservoir;(2)a three-foot-high,75-foot-long dam,located approximately 1,300 feet below the Neck Lake outlet;(3)a 400-foot-long penstock;(4)a proposed powerhouse containing a generator with a capacity of 124 kW –400 kW;(5)a transmission line; (6)an access road;and (7)appurtenant facilities.The proposed project would not be connected to an interstate grid,and would not occupy any tribal or federal lands. PUBLIC NOTICE 3.Notice of the DI was published in the Federal Register on April 7,2010.Protests, comments,and motions to intervene were to be filed by April 30,2010.On April 13, 2010,the U.S.D.A.Forest Service –Region 10 filed a motion to intervene.The Forest Service stated that the project appears to be adjacent to a Forest Service road reservation, and therefore,has the potential to affect National Forest System lands.On April 30, 2010,the Southern Southeast Regional Aquaculture Association (SSRAA)filed comments.In its comments,SSRAA stated that it has concerns regarding the adverse impact of project operations on its existing fish program.No other protests,comments, or motions to intervene were received. 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 2 JURISDICTION 4.Pursuant to section 23(b)(1)of the Federal Power Act (FPA),16 U.S.C.§817(1), a non-federal hydroelectric project must (unless it has a still-valid pre-1920 federal permit)be licensed if it: •is located on a navigable water of the United States; •occupies lands or reservations of the United States; •utilizes surplus water or waterpower from a government dam;or •is located on a stream over which Congress has Commerce Clause jurisdiction,is constructed or modified on or after August 26,1935,and affects the interests of interstate or foreign commerce. DISCUSSION 5.Because the licensing requirement is established on other grounds,I do not address the issue of whether Neck Lake outlet stream is navigable at the project site.The project would not occupy federal lands.The project would not use surplus water or waterpower from a federal government dam.The project would be constructed after August 26,1935,would be located on a Commerce Clause stream,1 and would affect the interests of interstate or foreign commerce within the meaning of section 23(b(1)of the Federal Power Act because of its significant effect on anadromous fish in Alaska’s District 6 fishery. A.Fish Resource 6.SSRAA operates a raceway and adult collection facilities for summer run coho salmon (Oncorhynchus kisutch)at the mouth of the outlet stream from Neck Lake.The adult summer run coho salmon harvested at this facility during June,July,and August are marketed for sale in the Pacific Northwest as Snow Pass Coho.2 Adult summer run coho also return to the nearby Burnett Inlet Hatchery,where about 2 million eggs are collected and fertilized each year.After the fry hatch,1.6-to 1.7-million are transported by plane to net pens in Neck Lake,where they rear for a year and are then released as yearling smolts.Upon release from the net pens,these smolts move out of Neck Lake and down the Neck Lake outlet stream,pass over a barrier falls,and enter salt water in Whale Pass.After 12 to 14 months at sea,the returning adult fish enter the commercial gillnet 1 Neck Lake outlet stream is a tributary to Whale Pass,a navigable water of the United States. 2 http://www.ssraa.org/snow_pass_coho.htm This web site provides information on SSRAA’s collection,rearing and marketing of snow pass summer run coho salmon. 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 3 fishery in Alaska Department of Fish and Game’s salmon District 6 (also referred to as District 106)in southeast Alaska. 7.Based on ten years of harvest records (2000 –2009)for the District 6 gillnet fishery,Neck Lake-produced coho salmon contributed an average of 23 percent (with a range of 6 percent to 40 percent)of the total commercial summer run coho salmon catch (Alaska Department of Fish and Game,2010).3 The ex-vessel value4 of this catch for the period 2000-2009 ranged from $12,437 to $186,960 and averaged 20 percent of the total value of the District 6 ex-vessel harvest.Thus,the contribution and value of Neck Lake- produced coho salmon represents a significant part of the District 6 summer coho salmon harvest.For this period,the return from the coho yearling smolts released from Neck Lake averaged 65,000 adult coho salmon,consisting of commercial and sport fishery harvest,and those fish that escaped harvest and returned to the collection facilities on the outlet stream from Neck Lake,for an average survival rate of 4 percent (SSRAA,2010).5 B. Proposed Project Effects 8.The proposed hydro project would use flows from Neck Lake and would consist of a small diversion dam with an intake structure downstream of Neck Lake,a penstock that bypasses about 400 feet of stream,and a powerhouse that discharges near the base of the fish ladder/raceway operated by the SSRAA for capturing returning adult coho salmon.The proposed project description did not provide any details of project design or mode of operation that would prevent or minimize impacts to coho smolts passing from Neck Lake downstream to salt water and return of adults to the collection facilities. 9.Coho smolts moving downstream from Neck Lake could be harmed by:turbine injur y and mortality resulting from entrainment at the project intake structure with no or ineffective screens;injury and mortality from passage over the diversion structure with an inadequate plunge pool;and,inadequate flows in the bypassed reach for passage downstream.Of these three effects,turbine caused mortality would likely be the most significant.Mortality of the downstream migrating coho smolts passing through the project turbine could range from 5 to 20 percent but could reach 100 percent,depending 3 E-mail dated August 6,2010,from Troy Thynes,Alaska Department of Fish and Game to John Novak of Commission staff.(Filed August 20,2010) 4 Price received b y fishermen for fish,shellfish,and other aquatic animals landed at the dock. 5 E-mail dated July 29,2010,from Rod Neterer,Southern Southeast Regional Aquaculture Association to John Novak of Commission staff.(Filed August 4,2010) 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 4 upon the type of turbine installed at this project.6 10.Adult coho salmon returning to SSRAA’s collection facilities could be falsely attracted to the project discharge that would be adjacent to the discharge from the collection facilities.Without a tailrace barrier or modified operation,these fish falsely attracted to the project discharge could enter the draft tube and come in contact with the turbine runners,causing some level of injur y and mortality to these fish.This would affect the survival return rate and ultimately the number of coho harvested for sale by the SSRAA.Further,the SSRAA has expressed the concern that if the penstock were routed over the top of the fish ladder,adult coho salmon,which are active jumpers,would be injured while jumping and coming in contact with the penstock. C. Conclusion 11. Based on available information about the project and its location in a salmon rearing system that contributes a large number of coho salmon to an important commercial fisher y,the proposed project has the potential to cause substantial injur y and mortality to coho smolts passing downstream,thereby significantly affecting the commercial coho fishery in District 6.As noted above,over the past 10 years Neck Lake coho salmon have contributed an average of 23 percent of the commercial gillnet harvest in District 6.This is a significant contribution.Without adequate design and screening of the project intake and worse case,20 percent or more7 of the downstream migrating coho smolts would experience turbine mortality and thereby reduce the commercial fishery in District 6 b y five percent or more.In the Gartina Creek project order,8 the Commission determined that a potential eight-percent reduction in the commercial salmon harvest in District 114 was large enough to be considered real and substantial, therefore requiring licensing of that project.Without adequate fish protection measures, this proposed project also has the potential to cause either a similar or greater level of reduction in the coho salmon commercial harvest.Applying the same rationale here,the impacts of the proposed project on the District 6 commercial gillnet fishery would be real and substantial.Therefore,the project requires licensing because it would significantly affect interstate commerce within the meaning of section 23 (b)(1)of the Federal Power Act. 6 Therrien,J.and Bourgeois,G.2000.Fish passage at small hydro sites.The International Energ y Agency Technical Report.113 pages +Appendices. 7 Some turbines are reported to cause mortalities reaching 100 percent. Installation of such a turbine at this project would result in a 23-percent reduction in the District 6 commercial gillnet fishery for coho salmon. 8 101 FERC ¶61,191 (November 21,2002). 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 5 12. For all the foregoing reasons,I find that the proposed Neck Lake Project would substantially affect the District 6 commercial fishery,and therefore,would affect the interests of interstate or foreign commerce.Accordingly,the project must be licensed pursuant to section 23(b)(1)of the FPA. The Director orders: (A)Alaska Power &Telephone Compan y’s proposed Neck Lake H ydroelectric Project,to be located on Neck Lake outlet stream near the community of Whale Pass on Prince of Wales Island,Alaska,is required to be licensed pursuant to section 23(b)(1)of the Federal Power Act.No construction of the project may commence until a license has been obtained. (B)This order constitutes final agency action.An y party may file a request for rehearing of this order within 30 da ys from the date of its issuance,as provided in section 313(a)of the FPA,16 U.S.C.§825l (2006),and the Commission’s regulations at 18 C.F.R.§385.713 (2010).The filing of a request for rehearing does not operate as a stay of the effective date of this order,or of any other date specified in this order.The licensee’s failure to file a request for rehearing shall constitute acceptance of this order. Edward A.Abrams Director Division of Hydropower Administration and Compliance 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Coordinated with SSRAA regarding Preliminary Project Arrangement • September 17, 2014 – SSRAA Letter of Support FERC JURISDICTIONAL DETERMINATION 133 FERC ¶62,121 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Alaska Power &Telephone Compan y Docket No.DI10-5-000 ORDER RULING ON DECLARATION OF INTENTION AND FINDING LICENSING IS REQUIRED (Issued November 04,2010) 1.On December 23,2009,and supplemented on January 12,February 4, February 24,March 16,and March 23,2010,Alaska Power &Telephone Company filed a Declaration of Intention (DI)concerning the proposal to develop the Neck Lake Hydroelectric Project,to be located on Neck Lake outlet stream near the community of Whale Pass on Prince of Wales Island,Alaska (T.66 S.,R.79 E.,sec.35,Copper River Meridian,Alaska). PROJECT DESCRIPTION 2.The proposed Neck Lake Hydroelectric Project would consist of:(1)a small reservoir;(2)a three-foot-high,75-foot-long dam,located approximately 1,300 feet below the Neck Lake outlet;(3)a 400-foot-long penstock;(4)a proposed powerhouse containing a generator with a capacity of 124 kW –400 kW;(5)a transmission line; (6)an access road;and (7)appurtenant facilities.The proposed project would not be connected to an interstate grid,and would not occupy any tribal or federal lands. PUBLIC NOTICE 3.Notice of the DI was published in the Federal Register on April 7,2010.Protests, comments,and motions to intervene were to be filed by April 30,2010.On April 13, 2010,the U.S.D.A.Forest Service –Region 10 filed a motion to intervene.The Forest Service stated that the project appears to be adjacent to a Forest Service road reservation, and therefore,has the potential to affect National Forest System lands.On April 30, 2010,the Southern Southeast Regional Aquaculture Association (SSRAA)filed comments.In its comments,SSRAA stated that it has concerns regarding the adverse impact of project operations on its existing fish program.No other protests,comments, or motions to intervene were received. 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 2 JURISDICTION 4.Pursuant to section 23(b)(1)of the Federal Power Act (FPA),16 U.S.C.§817(1), a non-federal hydroelectric project must (unless it has a still-valid pre-1920 federal permit)be licensed if it: •is located on a navigable water of the United States; •occupies lands or reservations of the United States; •utilizes surplus water or waterpower from a government dam;or •is located on a stream over which Congress has Commerce Clause jurisdiction,is constructed or modified on or after August 26,1935,and affects the interests of interstate or foreign commerce. DISCUSSION 5.Because the licensing requirement is established on other grounds,I do not address the issue of whether Neck Lake outlet stream is navigable at the project site.The project would not occupy federal lands.The project would not use surplus water or waterpower from a federal government dam.The project would be constructed after August 26,1935,would be located on a Commerce Clause stream,1 and would affect the interests of interstate or foreign commerce within the meaning of section 23(b(1)of the Federal Power Act because of its significant effect on anadromous fish in Alaska’s District 6 fishery. A.Fish Resource 6.SSRAA operates a raceway and adult collection facilities for summer run coho salmon (Oncorhynchus kisutch)at the mouth of the outlet stream from Neck Lake.The adult summer run coho salmon harvested at this facility during June,July,and August are marketed for sale in the Pacific Northwest as Snow Pass Coho.2 Adult summer run coho also return to the nearby Burnett Inlet Hatchery,where about 2 million eggs are collected and fertilized each year.After the fry hatch,1.6-to 1.7-million are transported by plane to net pens in Neck Lake,where they rear for a year and are then released as yearling smolts.Upon release from the net pens,these smolts move out of Neck Lake and down the Neck Lake outlet stream,pass over a barrier falls,and enter salt water in Whale Pass.After 12 to 14 months at sea,the returning adult fish enter the commercial gillnet 1 Neck Lake outlet stream is a tributary to Whale Pass,a navigable water of the United States. 2 http://www.ssraa.org/snow_pass_coho.htm This web site provides information on SSRAA’s collection,rearing and marketing of snow pass summer run coho salmon. 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 3 fishery in Alaska Department of Fish and Game’s salmon District 6 (also referred to as District 106)in southeast Alaska. 7.Based on ten years of harvest records (2000 –2009)for the District 6 gillnet fishery,Neck Lake-produced coho salmon contributed an average of 23 percent (with a range of 6 percent to 40 percent)of the total commercial summer run coho salmon catch (Alaska Department of Fish and Game,2010).3 The ex-vessel value4 of this catch for the period 2000-2009 ranged from $12,437 to $186,960 and averaged 20 percent of the total value of the District 6 ex-vessel harvest.Thus,the contribution and value of Neck Lake- produced coho salmon represents a significant part of the District 6 summer coho salmon harvest.For this period,the return from the coho yearling smolts released from Neck Lake averaged 65,000 adult coho salmon,consisting of commercial and sport fishery harvest,and those fish that escaped harvest and returned to the collection facilities on the outlet stream from Neck Lake,for an average survival rate of 4 percent (SSRAA,2010).5 B. Proposed Project Effects 8.The proposed hydro project would use flows from Neck Lake and would consist of a small diversion dam with an intake structure downstream of Neck Lake,a penstock that bypasses about 400 feet of stream,and a powerhouse that discharges near the base of the fish ladder/raceway operated by the SSRAA for capturing returning adult coho salmon.The proposed project description did not provide any details of project design or mode of operation that would prevent or minimize impacts to coho smolts passing from Neck Lake downstream to salt water and return of adults to the collection facilities. 9.Coho smolts moving downstream from Neck Lake could be harmed by:turbine injur y and mortality resulting from entrainment at the project intake structure with no or ineffective screens;injury and mortality from passage over the diversion structure with an inadequate plunge pool;and,inadequate flows in the bypassed reach for passage downstream.Of these three effects,turbine caused mortality would likely be the most significant.Mortality of the downstream migrating coho smolts passing through the project turbine could range from 5 to 20 percent but could reach 100 percent,depending 3 E-mail dated August 6,2010,from Troy Thynes,Alaska Department of Fish and Game to John Novak of Commission staff.(Filed August 20,2010) 4 Price received b y fishermen for fish,shellfish,and other aquatic animals landed at the dock. 5 E-mail dated July 29,2010,from Rod Neterer,Southern Southeast Regional Aquaculture Association to John Novak of Commission staff.(Filed August 4,2010) 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 4 upon the type of turbine installed at this project.6 10.Adult coho salmon returning to SSRAA’s collection facilities could be falsely attracted to the project discharge that would be adjacent to the discharge from the collection facilities.Without a tailrace barrier or modified operation,these fish falsely attracted to the project discharge could enter the draft tube and come in contact with the turbine runners,causing some level of injur y and mortality to these fish.This would affect the survival return rate and ultimately the number of coho harvested for sale by the SSRAA.Further,the SSRAA has expressed the concern that if the penstock were routed over the top of the fish ladder,adult coho salmon,which are active jumpers,would be injured while jumping and coming in contact with the penstock. C. Conclusion 11. Based on available information about the project and its location in a salmon rearing system that contributes a large number of coho salmon to an important commercial fisher y,the proposed project has the potential to cause substantial injur y and mortality to coho smolts passing downstream,thereby significantly affecting the commercial coho fishery in District 6.As noted above,over the past 10 years Neck Lake coho salmon have contributed an average of 23 percent of the commercial gillnet harvest in District 6.This is a significant contribution.Without adequate design and screening of the project intake and worse case,20 percent or more7 of the downstream migrating coho smolts would experience turbine mortality and thereby reduce the commercial fishery in District 6 b y five percent or more.In the Gartina Creek project order,8 the Commission determined that a potential eight-percent reduction in the commercial salmon harvest in District 114 was large enough to be considered real and substantial, therefore requiring licensing of that project.Without adequate fish protection measures, this proposed project also has the potential to cause either a similar or greater level of reduction in the coho salmon commercial harvest.Applying the same rationale here,the impacts of the proposed project on the District 6 commercial gillnet fishery would be real and substantial.Therefore,the project requires licensing because it would significantly affect interstate commerce within the meaning of section 23 (b)(1)of the Federal Power Act. 6 Therrien,J.and Bourgeois,G.2000.Fish passage at small hydro sites.The International Energ y Agency Technical Report.113 pages +Appendices. 7 Some turbines are reported to cause mortalities reaching 100 percent. Installation of such a turbine at this project would result in a 23-percent reduction in the District 6 commercial gillnet fishery for coho salmon. 8 101 FERC ¶61,191 (November 21,2002). 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 5 12. For all the foregoing reasons,I find that the proposed Neck Lake Project would substantially affect the District 6 commercial fishery,and therefore,would affect the interests of interstate or foreign commerce.Accordingly,the project must be licensed pursuant to section 23(b)(1)of the FPA. The Director orders: (A)Alaska Power &Telephone Compan y’s proposed Neck Lake H ydroelectric Project,to be located on Neck Lake outlet stream near the community of Whale Pass on Prince of Wales Island,Alaska,is required to be licensed pursuant to section 23(b)(1)of the Federal Power Act.No construction of the project may commence until a license has been obtained. (B)This order constitutes final agency action.An y party may file a request for rehearing of this order within 30 da ys from the date of its issuance,as provided in section 313(a)of the FPA,16 U.S.C.§825l (2006),and the Commission’s regulations at 18 C.F.R.§385.713 (2010).The filing of a request for rehearing does not operate as a stay of the effective date of this order,or of any other date specified in this order.The licensee’s failure to file a request for rehearing shall constitute acceptance of this order. Edward A.Abrams Director Division of Hydropower Administration and Compliance 20101104-3033 FERC PDF (Unofficial) 11/04/2010 PROJECT TIMELINE CHART Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 PHASE I: Reconnassaince Reconnaissance (completed) PHASE II: Resource Assement/Feasibility Analysis/Conceptual Design Agency Consultation/Permitting Resource Assessment (studies) Feasibility & Conceptual Design PHASE III: Final Design and Permitting Permitting & FERC License App FERC Application Processing Final Design Agency Permits Issued PHASE IV: Construction Grant processing Access Road Diversion & Intake Penstock Generating Equipment Procurement Powerhouse Install Distribution Line Test and Start-Up LEGEND:<-- Procurement and off-site fabrication <-- On-site construction 2021 NECK LAKE HYDROELECTRIC PROJECT DEVELOPMENT SCHEDULE 2016 2017 2018 2019 2020 PERMITTING 133 FERC ¶62,121 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Alaska Power &Telephone Compan y Docket No.DI10-5-000 ORDER RULING ON DECLARATION OF INTENTION AND FINDING LICENSING IS REQUIRED (Issued November 04,2010) 1.On December 23,2009,and supplemented on January 12,February 4, February 24,March 16,and March 23,2010,Alaska Power &Telephone Company filed a Declaration of Intention (DI)concerning the proposal to develop the Neck Lake Hydroelectric Project,to be located on Neck Lake outlet stream near the community of Whale Pass on Prince of Wales Island,Alaska (T.66 S.,R.79 E.,sec.35,Copper River Meridian,Alaska). PROJECT DESCRIPTION 2.The proposed Neck Lake Hydroelectric Project would consist of:(1)a small reservoir;(2)a three-foot-high,75-foot-long dam,located approximately 1,300 feet below the Neck Lake outlet;(3)a 400-foot-long penstock;(4)a proposed powerhouse containing a generator with a capacity of 124 kW –400 kW;(5)a transmission line; (6)an access road;and (7)appurtenant facilities.The proposed project would not be connected to an interstate grid,and would not occupy any tribal or federal lands. PUBLIC NOTICE 3.Notice of the DI was published in the Federal Register on April 7,2010.Protests, comments,and motions to intervene were to be filed by April 30,2010.On April 13, 2010,the U.S.D.A.Forest Service –Region 10 filed a motion to intervene.The Forest Service stated that the project appears to be adjacent to a Forest Service road reservation, and therefore,has the potential to affect National Forest System lands.On April 30, 2010,the Southern Southeast Regional Aquaculture Association (SSRAA)filed comments.In its comments,SSRAA stated that it has concerns regarding the adverse impact of project operations on its existing fish program.No other protests,comments, or motions to intervene were received. 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 2 JURISDICTION 4.Pursuant to section 23(b)(1)of the Federal Power Act (FPA),16 U.S.C.§817(1), a non-federal hydroelectric project must (unless it has a still-valid pre-1920 federal permit)be licensed if it: •is located on a navigable water of the United States; •occupies lands or reservations of the United States; •utilizes surplus water or waterpower from a government dam;or •is located on a stream over which Congress has Commerce Clause jurisdiction,is constructed or modified on or after August 26,1935,and affects the interests of interstate or foreign commerce. DISCUSSION 5.Because the licensing requirement is established on other grounds,I do not address the issue of whether Neck Lake outlet stream is navigable at the project site.The project would not occupy federal lands.The project would not use surplus water or waterpower from a federal government dam.The project would be constructed after August 26,1935,would be located on a Commerce Clause stream,1 and would affect the interests of interstate or foreign commerce within the meaning of section 23(b(1)of the Federal Power Act because of its significant effect on anadromous fish in Alaska’s District 6 fishery. A.Fish Resource 6.SSRAA operates a raceway and adult collection facilities for summer run coho salmon (Oncorhynchus kisutch)at the mouth of the outlet stream from Neck Lake.The adult summer run coho salmon harvested at this facility during June,July,and August are marketed for sale in the Pacific Northwest as Snow Pass Coho.2 Adult summer run coho also return to the nearby Burnett Inlet Hatchery,where about 2 million eggs are collected and fertilized each year.After the fry hatch,1.6-to 1.7-million are transported by plane to net pens in Neck Lake,where they rear for a year and are then released as yearling smolts.Upon release from the net pens,these smolts move out of Neck Lake and down the Neck Lake outlet stream,pass over a barrier falls,and enter salt water in Whale Pass.After 12 to 14 months at sea,the returning adult fish enter the commercial gillnet 1 Neck Lake outlet stream is a tributary to Whale Pass,a navigable water of the United States. 2 http://www.ssraa.org/snow_pass_coho.htm This web site provides information on SSRAA’s collection,rearing and marketing of snow pass summer run coho salmon. 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 3 fishery in Alaska Department of Fish and Game’s salmon District 6 (also referred to as District 106)in southeast Alaska. 7.Based on ten years of harvest records (2000 –2009)for the District 6 gillnet fishery,Neck Lake-produced coho salmon contributed an average of 23 percent (with a range of 6 percent to 40 percent)of the total commercial summer run coho salmon catch (Alaska Department of Fish and Game,2010).3 The ex-vessel value4 of this catch for the period 2000-2009 ranged from $12,437 to $186,960 and averaged 20 percent of the total value of the District 6 ex-vessel harvest.Thus,the contribution and value of Neck Lake- produced coho salmon represents a significant part of the District 6 summer coho salmon harvest.For this period,the return from the coho yearling smolts released from Neck Lake averaged 65,000 adult coho salmon,consisting of commercial and sport fishery harvest,and those fish that escaped harvest and returned to the collection facilities on the outlet stream from Neck Lake,for an average survival rate of 4 percent (SSRAA,2010).5 B. Proposed Project Effects 8.The proposed hydro project would use flows from Neck Lake and would consist of a small diversion dam with an intake structure downstream of Neck Lake,a penstock that bypasses about 400 feet of stream,and a powerhouse that discharges near the base of the fish ladder/raceway operated by the SSRAA for capturing returning adult coho salmon.The proposed project description did not provide any details of project design or mode of operation that would prevent or minimize impacts to coho smolts passing from Neck Lake downstream to salt water and return of adults to the collection facilities. 9.Coho smolts moving downstream from Neck Lake could be harmed by:turbine injur y and mortality resulting from entrainment at the project intake structure with no or ineffective screens;injury and mortality from passage over the diversion structure with an inadequate plunge pool;and,inadequate flows in the bypassed reach for passage downstream.Of these three effects,turbine caused mortality would likely be the most significant.Mortality of the downstream migrating coho smolts passing through the project turbine could range from 5 to 20 percent but could reach 100 percent,depending 3 E-mail dated August 6,2010,from Troy Thynes,Alaska Department of Fish and Game to John Novak of Commission staff.(Filed August 20,2010) 4 Price received b y fishermen for fish,shellfish,and other aquatic animals landed at the dock. 5 E-mail dated July 29,2010,from Rod Neterer,Southern Southeast Regional Aquaculture Association to John Novak of Commission staff.(Filed August 4,2010) 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 4 upon the type of turbine installed at this project.6 10.Adult coho salmon returning to SSRAA’s collection facilities could be falsely attracted to the project discharge that would be adjacent to the discharge from the collection facilities.Without a tailrace barrier or modified operation,these fish falsely attracted to the project discharge could enter the draft tube and come in contact with the turbine runners,causing some level of injur y and mortality to these fish.This would affect the survival return rate and ultimately the number of coho harvested for sale by the SSRAA.Further,the SSRAA has expressed the concern that if the penstock were routed over the top of the fish ladder,adult coho salmon,which are active jumpers,would be injured while jumping and coming in contact with the penstock. C. Conclusion 11. Based on available information about the project and its location in a salmon rearing system that contributes a large number of coho salmon to an important commercial fisher y,the proposed project has the potential to cause substantial injur y and mortality to coho smolts passing downstream,thereby significantly affecting the commercial coho fishery in District 6.As noted above,over the past 10 years Neck Lake coho salmon have contributed an average of 23 percent of the commercial gillnet harvest in District 6.This is a significant contribution.Without adequate design and screening of the project intake and worse case,20 percent or more7 of the downstream migrating coho smolts would experience turbine mortality and thereby reduce the commercial fishery in District 6 b y five percent or more.In the Gartina Creek project order,8 the Commission determined that a potential eight-percent reduction in the commercial salmon harvest in District 114 was large enough to be considered real and substantial, therefore requiring licensing of that project.Without adequate fish protection measures, this proposed project also has the potential to cause either a similar or greater level of reduction in the coho salmon commercial harvest.Applying the same rationale here,the impacts of the proposed project on the District 6 commercial gillnet fishery would be real and substantial.Therefore,the project requires licensing because it would significantly affect interstate commerce within the meaning of section 23 (b)(1)of the Federal Power Act. 6 Therrien,J.and Bourgeois,G.2000.Fish passage at small hydro sites.The International Energ y Agency Technical Report.113 pages +Appendices. 7 Some turbines are reported to cause mortalities reaching 100 percent. Installation of such a turbine at this project would result in a 23-percent reduction in the District 6 commercial gillnet fishery for coho salmon. 8 101 FERC ¶61,191 (November 21,2002). 20101104-3033 FERC PDF (Unofficial) 11/04/2010 Docket No.DI10-5-000 5 12. For all the foregoing reasons,I find that the proposed Neck Lake Project would substantially affect the District 6 commercial fishery,and therefore,would affect the interests of interstate or foreign commerce.Accordingly,the project must be licensed pursuant to section 23(b)(1)of the FPA. The Director orders: (A)Alaska Power &Telephone Compan y’s proposed Neck Lake H ydroelectric Project,to be located on Neck Lake outlet stream near the community of Whale Pass on Prince of Wales Island,Alaska,is required to be licensed pursuant to section 23(b)(1)of the Federal Power Act.No construction of the project may commence until a license has been obtained. (B)This order constitutes final agency action.An y party may file a request for rehearing of this order within 30 da ys from the date of its issuance,as provided in section 313(a)of the FPA,16 U.S.C.§825l (2006),and the Commission’s regulations at 18 C.F.R.§385.713 (2010).The filing of a request for rehearing does not operate as a stay of the effective date of this order,or of any other date specified in this order.The licensee’s failure to file a request for rehearing shall constitute acceptance of this order. Edward A.Abrams Director Division of Hydropower Administration and Compliance 20101104-3033 FERC PDF (Unofficial) 11/04/2010 PHOTOS