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HomeMy WebLinkAbout092214_AEA - Clearwater Creek Hydro - REF Round VIII September 22, 2014 Alaska Energy Authority AEA 15003 Renewable Energy Grant Application 813 West Northern Lights Blvd. Anchorage, AK 99503 RE: Clearwater Creek Hydroelectric Project Phase II Grant Application AEA 15003 Renewable Energy Grant Application Dear AEA: Enclosed in response to RFA AEA 15003 Renewable Energy Grant Application program, is an application requesting funding for the Neck Lake Hydroelectric Project for Phase II & III activities. If you have any questions, please call either Glen Martin (Resource Assessment & Permits) 360-385-1733 x122, Karl Wood (Grant Funds Administrator) 360-385-1733 x128, or Bob Grimm (President) 360-385-1733 x120. Sincerely, Glen D. Martin Resource Assessment & Permits Enc. (as stated) Renewable Energy Fund Round VIII Grant Application - Standard Form Application Forms and Instructions This instruction page and the following grant application constitutes the Grant Application Form for Round VIII 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/REFund8.html. • 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 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. • 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. • In the sections below, please enter responses in the spaces provided, often under the section heading. 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. • In accordance with 333 (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 is 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. AEA 15003 Page 1 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form SECTION 1 – APPLICANT INFORMATION Name (Name of utility, IPP, or government entity submitting proposal) Alaska Power Company (APC) – A Subsidiary of Alaska Power & Telephone Co. (AP&T) Type of Entity: Fiscal Year End: Utility December, 2014 Tax ID #92-0153693 Tax Status: ☒ For-profit ☐ Non-profit ☐ Government (check one) Date of last financial statement audit: April, 2014 (Available in AP&T Annual Report) Mailing Address: Physical Address: Jason Custer [Same] 136 Misty Marie Lane Ketchikan, AK 99901 Telephone: Fax: Email: 907-225-1950 x 29 907-225-6450 Jason.c@aptalaska.com 1.1 APPLICANT POINT OF CONTACT / GRANTS MANAGER Name: Title: Jason Custer -- Business Development Director, Alaska Power & Telephone Mailing Address: Jason Custer 136 Misty Marie Lane Ketchikan, AK 99901 Telephone: Fax: Email: 907-225-1950 x 29 907-225-6450 Jason.c@aptalaska.com 1.1.1 APPLICANT ALTERNATE POINTS OF CONTACT Name Telephone: Fax: Email: Glen Martin 360-385-1733 x 122 Glen.m@aptalaska.com Karl Wood 360-385-1733 x 128 Karl.w@aptalaska.com AEA 15003 Page 2 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form 1.2 APPLICANT MINIMUM REQUIREMENTS Please check as appropriate. If you do not to meet the minimum applicant requirements, your application will be rejected. 1.2.1 As an Applicant, we are: (put an X in the appropriate box) ☒ 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/REFund8.html. (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) AEA 15003 Page 3 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form SECTION 2 – PROJECT SUMMARY This section is intended to be no more than a 2-3 page overview of your project. 2.1 Project Title – (Provide a 4 to 7 word title for your project). Type in space below. Clearwater Creek Hydropower Project: Phase II 2.2 Project Location – Include the physical location of your project and name(s) of the community or communities that will benefit from your project in the subsections below. 2.2.1 Location of Project – Latitude and longitude, 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 Map Coordinates: 63.1513.-143.198217 Approximately 15 miles south of Tok, Alaska 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 interconnected communities of the Upper Tanana region, including Tok, Tanacross, Tetlin, and Dot Lake. The most recently available AEA PCE report identifies $0.50 kwh pricing for this service region, with an average PCE payment of $0.28 per eligible kilowatt hour.1 If the Slana-Chistochina-Mentasta grid becomes connected to Tok in the future, these communities will also benefit from the presence of the Clearwater Creek hydropower project. Similarly, if Northway, Northway Junction, and Northway Village also become connected to Tok, they will benefit from this project. All of these communities are served by APC, and are currently 100% dependent on diesel-fired generation. The most recently available AEA PCE report identifies $0.69 / kwh pricing for these service regions, with an average PCE Payment of $0.47 per eligible kilowatt hour 2. 2.3 PROJECT TYPE Put X in boxes 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 1 Source: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf 2 Source: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf AEA 15003 Page 4 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form ☐ 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 ☒ Feasibility and Conceptual Design ☐ Construction AEA 15003 Page 5 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form 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 $413,600 in AEA Renewable Energy Fund Round VIII grant funding support for Phase II Feasibility / Conceptual Design activities for the Clearwater Creek hydropower project, and proposes a match of $100,400 in private funds supplied by AP&T / APC; an additional $8,000 in-kind 3 is being provided, making APC’s contribution 21%. The proposed project is a 1 MW run-of-river hydroelectric project on Clearwater Creek, which is located approximately 15 miles southwest of the community of Tok on the Tok-Cutoff Highway (Glenn Highway). The project would supply approximately 3.4 GWh annually to Tok and surrounding interconnected communities. Clearwater Creek’s project features would consist of a small diversion structure, a 1 MW generating system (Turgo turbine), approximately 20,000 feet of penstock, an open tailrace channel, substation, approximately 5 miles of access road, and a distribution line. The project would interconnect with the Tok region grid via a 14-mile transmission connection made utilizing existing highway right-of- way (ROW). 2.5 PROJECT BENEFIT Briefly discuss the financial and public benefits that will result from this project, (such as reduced fuel costs, lower energy costs, local jobs created, etc.) The 1 MW Clearwater Creek hydropower project will significantly reduce the cost of electricity in the Tok service area, which also includes the communities of Tanacross, Tetlin, and Dot Lake. These communities are currently 100% dependent upon diesel-fired generation, and pay energy costs of $0.50 kWh (before PCE).4 It is anticipated that with State AEA support, the Clearwater Creek project can provide clean, affordable energy at 50% the cost of diesel-fired generation in year one of operations, with cost savings increasing long term as the cost of diesel fuel continues to rise. It is anticipated that this project would be developed subsequent to the more advanced Yerrick Creek hydropower project as a follow-up increment of hydropower for the Tok service region. The Yerrick Creek hydropower project will supplant 40% of diesel-fired generation. Clearwater Creek would supplant 31% of the region’s current diesel-fired generation, or approximately 50% of the diesel-fired generation remaining after Yerrick Creek’s completion. The two projects would be complimentary (not redundant) components of a future renewable-dominated Tok regional utility grid. AEA Econometric Workbook Outputs: 3 $5,000 for Phase I and $3,000 for Phase II in equipment (stream gauge). 4 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf AEA 15003 Page 6 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Note: Period of analysis for the above calculations is 50 years. However, hydropower projects have a useful life of over 100 years, which would effectively double these numbers. Additional Project Benefits:  Will reduce energy costs by providing more affordable clean energy. Current estimates indicate the project may be able to supply energy for half of the cost of diesel-fired generation. Estimates will be refined subsequent to the completion of the proposed scope of work.  Replaces approximately 31% of diesel-fired generation of electricity in the Tok and Upper Tanana Region with clean, renewable hydropower. (50% of diesel-fired generation remaining after completion of Yerrick Creek.)  If the Slana-Chistochina-Mentasta grid becomes connected to Tok in the future, these communities will also benefit. Similarly, if Northway, Northway Junction, and Northway Village also become connected to Tok, they will benefit from this project. All these communities are served by APC and are currently 100% dependent upon diesel generation.  State PCE statistics indicate the 58.2% of total kWh sold in FY13 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 41.8% of cost-savings being realized by current ratepayers.5  Helps to support the State of Alaska’s goal of 50% renewable energy by 2025. 5 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf Results NPV Benefits $15,957,327.33 NPV Capital Costs $9,588,161 B/C Ratio 1.66 NPV Net Benefit $6,369,166 Performance Unit Value Displaced Electricity kWh per year 3,400,000 Displaced Electricity total lifetime kWh 170,000,000 Displaced Petroleum Fuel gallons per year 242,857 Displaced Petroleum Fuel total lifetime gallons 12,142,857 Displaced Natural Gas mmBtu per year - Displaced Natural Gas total lifetime mmBtu - Avoided CO2 tonnes per year 2,465 Avoided CO2 total lifetime tonnes 123,250 AEA 15003 Page 7 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form  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 Tok.  Leverages private investment in the regional energy market, allowing the private sector to share project development costs and risks.  Reduces operating costs for resident businesses, supporting retention, growth and expansion.  Supports new economic development and resource development activities in the upper Tanana region. (Ex: growth of value-added manufacturing of forest products from locally harvested timber, and ancillary loads associated with an expanding local workforce.)  Reduces operating expenses for local schools, medical facilities, and other non-profit organizations, helping to support long-term sustainability.  Provides enhanced stability to the regional utility system.  Allows Tok and the surrounding Upper Tanana region to “home source” its energy supply from local, renewable sources, reducing fuel purchases from outside of the community, and allowing more wealth to remain and recirculate within the community.  Reduces dependence on foreign oil.  Displaces 242,857 gallons of diesel fuel per year, or 12.1 million gallons during the project’s initial 50-year period of operations.  Displaces 2,465 tons of carbon dioxide per year, avoiding 123,250 tons of carbon dioxide over the project’s initial 50-year period of operation. This is equivalent to approximately $10.4m in Social Cost of Carbon savings. (Calculated using the average of all four federal calculation methodologies specified by the US Interagency Working Group for Social Cost of Carbon, as required for US EO 12866 review.) Hydropower projects have 100-year-plus lifespans, which means that total savings will be twice that displayed above (or higher, depending on future SCC valuations).  Reduces the need to transport fuel from Fairbanks to Tok, lowering the potential for leaks and spills along the Alaska Highway. Transferring fuel from a supply truck to APC’s storage tank would be less frequent, reducing the potential for spills during fueling, and keeping groundwater safer for the area. APC is also working to complete the Yerrick Creek hydropower project, and has prioritized Yerrick Creek project for completion and commissioning in 2016. Clearwater Creek would serve as the subsequent increment of hydro for the Tok region, which would help further reduce the cost of energy, and provide energy needed for continued economic growth within the Tok community. APC owns and operates the existing Tok region grid, including all transmission, distribution, and generation equipment. AEA 15003 Page 8 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form 2.6 PROJECT BUDGET OVERVIEW Briefly discuss the amount of funds needed, the anticipated sources of funds, and the nature and source of other contributions to the project. APC anticipates needing $517,000 for Phase II activities. APC is seeking $413,600 in AEA REF Round VIII grant funding for Phase II activities, which would be matched by $100,400 in private funds supplied by AP&T / APC. APC is also supplying $3,000 in in-kind funding in the form of a stream gauge to bring the total contribution to $103,400. Previously utilized funds of $5,000 for reconnaissance brings APC’s total commitment to $108,400, or 21% matching funding. APC investment to date (estimated $5,000) has funded initial reconnaissance activities, including: stream flow investigation and analysis; preliminary economic benefit and financial modelling; a review of existing studies, reports, and literature; and filing for and receiving a FERC Non- Jurisdictional Determination. FERC issued the Non-Jurisdictional Decision in July 2012. AEA APC APC In-Kind Funds Phase Grant Funds Matching Funds Total I – Reconnaissance (1) $0 $0 $5,000 $5,000 II – Feasibility/Conceptual Design (2) $413,600 $100,400 $3,000 $517,000 III - Design and Permitting $320,000 $80,000 $400,000 IV – Construction $8,000,000 $7,000,000 $15,000,000 Total $8,733,600 $7,180,400 $8,000 $15,922,000 (1) APC conducted a site reconnaissance in 2012. (2) APC stream gauge equipment. Depending upon outcomes of Phase II activities, APC anticipates funding future project activities through a combination of private debt/equity, and would seek to utilize grant programs including the AEA REF program to provide affordably-priced clean energy for ratepayers in the Tok region. 2.7 COST AND BENEFIT SUMMARY Include a summary of grant request and your project’s total costs and benefits below. Costs for the Current Phase Covered by this Grant (Summary of funds requested) 2.7.1 Grant Funds Requested in this application $413,600 2.7.2 Cash match to be provided $100,400 1. New Match to New State Investment: N/A 2. Match to Date: [$5,000 (Phase I)] 3. Funds currently available: Matching funds will come from APC’s O&M budget 2.7.3 In-kind match to be provided $3,000 AEA 15003 Page 9 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form 2.7.4 Other grant funds to be provided $None Identified 2.7.5 Total Costs for Requested Phase of Project (sum of 2.7.1 through 2.7.4) $517,000 Other items for consideration 2.7.6 Other grant applications not yet approved NA Project Costs & Benefits (Summary of total project costs including work to date and future cost estimates to get to a fully operational project) 2.7.7 Total Project Cost Summary from Cost Worksheet, Section 4.4.4, including estimates through construction. $15,922,000 2.7.8 Additional Performance Monitoring Equipment not covered by the project but required for the Grant Only applicable to construction phase projects Does not Apply 2.7.9 Estimated Direct Financial Benefit (Savings) The economic model used by AEA is available at www.akenergyauthority.org/REFund8.html. This economic model may be used by applicants but is not required. Other economic models developed by the applicant may be used, however the final benefit/cost ratio used will be derived from the AEA model to ensure a level playing field for all applicants. AEA model displays: $16m NPV Benefits $9.5m NPV Capital Costs BCR of 1.66 NPV Net Benefit of $6.3m (See below.) (See 2.7.10 Other Public Benefit If you can calculate the benefit in terms of dollars please provide that number here and explain how you calculated that number in Section 5 below. State PCE statistics indicate the 58.2% of total kWh sold in FY13 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 41.8% of cost- savings being realized by current ratepayers.6 See below for social cost of carbon and fuel displacement statistics. 6 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf AEA 15003 Page 10 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form AEA Econometric Workbook Outputs: Note: Period of analysis for the above calculations is 50 years. However, hydropower projects have a useful life of over 100 years, which would effectively double these numbers. Displaces 2,465 metric tons of carbon dioxide per year, avoiding 123,250 metric tons of carbon dioxide over the project’s initial 50-year period of operation. This is equivalent to approximately $10.4m in Social Cost of Carbon savings. (Calculated using the average of all four federal calculation methodologies specified by the US Interagency Working Group for Social Cost of Carbon, as required for US EO 12866 review.) Hydropower projects have 100-year-plus lifespans, which means that total savings will be twice that displayed above (or higher, depending on future SCC valuations). SECTION 3 – PROJECT MANAGEMENT PLAN Describe who will be responsible for managing the project and provide a plan for successfully completing the project within the scope, schedule and budget proposed in the application. 3.1 Project Manager Tell us who will be managing the project for the Grantee and include contact information, a resume and references for the manager(s). 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. Results NPV Benefits $15,957,327.33 NPV Capital Costs $9,588,161 B/C Ratio 1.66 NPV Net Benefit $6,369,166 Performance Unit Value Displaced Electricity kWh per year 3,400,000 Displaced Electricity total lifetime kWh 170,000,000 Displaced Petroleum Fuel gallons per year 242,857 Displaced Petroleum Fuel total lifetime gallons 12,142,857 Displaced Natural Gas mmBtu per year - Displaced Natural Gas total lifetime mmBtu - Avoided CO2 tonnes per year 2,465 Avoided CO2 total lifetime tonnes 123,250 AEA 15003 Page 11 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Project Management Team: Resume and references attached. Greg Mickelson – Alaska Power & Telephone Company Project Manager 907-755-4822 greg.m@aptalaska.com 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 Bob Berreth – Alaska Power & Telephone Company Senior Electrical Engineer Bob.b@aptalaska.com 360-385-1733 x 123 Glen Martin – Alaska Power & Telephone Company Co-Grant Writer 360-385-1733 x 122 Glen.M@aptalaska.com Jason Custer – Alaska Power & Telephone Company Business Development Director 907-225-1950 x 33 Jason.c@aptalaska.com Karl Wood – Alaska Power & Telephone Company Grant Administrator 360-385-1733 x128 Additional APC senior engineers and project managers can be used 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 APC’s team for over 30 years and has been an essential part of their success. He has overseen numerous projects that have also had grant funding and is familiar with procedures put in place for their use. Mr. Mickelson’s resume is enclosed. 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. AEA 15003 Page 12 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form 3.2 Project Schedule and Milestones Please fill out the schedule below. 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. Phase I: Reconnaissance: Completed 2012 Initial reconnaissance and non-jurisdictional determination request filed with FERC. FERC determined a federal license was not required. Phase II: Resource Assessment/Feasibility Analysis/Conceptual Design: 2015-2016 In 2015, after AEA Round VIII funding is released to the project, the following would occur: PHASE II MILESTONES PHASE II - Milestones Tasks Start Date End Date Agency Consultation Consult with Agencies & file for permits to conduct studies 07/01/15 12/01/16 Site Visit by Engineering APC engineering team inspects project site for conceptual design and studies 08/01/15 09/30/15 Stream gage installation & maintenance APC installs their stream gauge and downloads data and maintains as needed for two years 08/01/15 08/01/17 Wetland delineation Contractor hired to conduct study 06/01/16 08/31/16 TES botanical survey Contractor hired to conduct study 06/01/16 08/31/16 Fish survey Contractor hired to conduct study 08/01/15 10/31/16 Wildlife Survey (Avian) Contractor hired to conduct study 05/01/16 08/31/16 Water quality sampling Quarterly sampling regime 08/01/15 10/01/16 Cultural Resource Survey Contractor hired to conduct study 06/01/16 08/31/16 Topographic mapping Contractor hired to conduct study 08/01/15 10/31/16 Feasibility Analysis & Conceptual Design APC will conduct an analysis of the collected data for project feasibility and develop a conceptual design and then provide a draft and final reports for AEA 10/01/16 12/31/16 A bar schedule of the expected feasibility analysis and conceptual design sequence is provided below along with the entire development sequence; activities funded by this grant will be Phase II activities only. AEA 15003 Page 13 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form FIGURE 1: TIMELINE FOR PROJECT DEVELOPMENT 3.3 Project Resources Describe the personnel, contractors, personnel or firms, equipment, and services you will use to accomplish the project. Include any partnerships or commitments with other entities you have or anticipate will be needed to complete your project. Describe any existing contracts and the selection process you may use for major equipment purchases or contracts. Include brief resumes and references for known, key personnel, contractors, and suppliers as an attachment to your application. APC: 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 electrical service to 24 communities. APC has experience with renewable resources after constructing 4 hydroelectric projects in S.E. Alaska and experimenting with a hydrokinetic turbine in the Yukon River. APC owns and operates 7 hydroelectric projects in Southeast Alaska and has extensive experience with the integration between diesel generation and renewable energy generation. One of APC’s service centers is in Tok where diesel generation supplies power to Tok, Tetlin, Tanacross, and Dot Lake. Other small nearby grids such as the (1) Slana-Chistochina-Mentasta, and (2) Northway-Northway Village-Northway Junction are also served by APC, but are currently not connected to Tok. APC has power linemen, engineers, accounting and bookkeeping personnel in Tok as well as at the APC corporate headquarters in Port Townsend, Washington for managing the grant, managing field studies, feasibility analysis, conceptual design, permitting, and final design as well as operating and maintaining a hydropower project. 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) Stream Gauging Topographic Mapping Feasibility & Conceptual Design PHASE III: Final Design and Permitting Permitting Final Design PHASE IV: Construction Order Materials Mobilization 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 2020 CLEARWATER CREEK HYDROELECTRIC PROJECT FEASIBILITY ANALYSIS AND CONCEPTUAL DESIGN SCHEDULE 20192015201620172018 AEA 15003 Page 14 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form 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 APC Staff are enclosed. 3.4 Project Communications Discuss how you plan to monitor the project and keep the Authority informed of the status. Please provide an alternative contact person and their contact information. APC proposes to provide quarterly reports to AEA regarding the status of the work and use of the grant funds. APC will be glad to respond promptly to any AEA questions, and is pleased to consider any reasonable reporting method preferred by the AEA. APC has a strong and enduring track record of accurate and timely reporting for grants provided by the AEA and other agencies over the past decade, and is capable of producing necessary reports and responding to AEA questions in a timely and reliable manner. As previously mentioned, Karl Wood will be the grant administrator responsible for filing quarterly reports and funding reimbursements. Additional AP&T administrative staff can be utilized as necessary. 3.5 Project Risk Discuss potential problems and how you would address them. APC currently owns and operates 7 hydropower projects in Alaska, with an 8th (Reynolds Creek) scheduled for near-term construction. APC believes that for the following reasons, risks and costs can be minimized:  Experience designing, constructing, and operating similar small hydropower projects in Alaska  Longstanding vendor, technical service, supply chain relationships and industry knowledge and their incumbent project development resources AEA 15003 Page 15 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form  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  Experience with assisting other utilities with hydropower development activities on a contractual basis. Activities currently proposed for AEA REF Round VIII funding support will include pre- development activities which assist in identifying and mitigating risks through a feasibility analysis and conceptual design. Typical risks of developing a hydropower project in the Tok region which may apply to Clearwater are described below. Inclement Weather – Working conditions in Alaska’s interior can be very harsh during the winter. The proposed construction schedule assumes little/no work at the project site during winter months. If it appears likely that a harsh winter would occur and extend for an unusually long time period, APC and its contractor(s) can consider options such as double-shift work during long summer days, or completing limited work during winter months. 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 significant environmental opposition to continued diesel-fired generation in the Tok 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 Tok, Tanacross, Tetlin, and Dot Lake dependent on a significant amount of diesel-fired generation of electricity. If diesel- dependency persists, these communities can expect exacerbated socioeconomic distress, continued lack of economic opportunity, long term job loss, continued population outmigration, and the inability to respond to emerging commercial opportunities and support new economic development. 3.6 Project Accountant(s) Tell us who will be performing the accounting of this Project for the Grantee and include contact information, a resume and references for the project accountant(s). 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 project management support. Enclosed is a resume for Karl Wood, Financial Analyst and Grant Administrator for APC. If needed, supplemental accounting assistance can be supplied by APC. 3.7 Financial Accounting System AEA 15003 Page 16 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Discuss the accounting system that will be used to account for project costs and whom will be the primary user of the accounting system. 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. 3.8 Financial Management Controls Discuss 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. 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. ECTION 4 – PROJECT DESCRIPTION AND TASKS The level of information will vary according to phase(s) of the project you propose to undertake with grant funds. 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 satisfied and funding for an advanced phase is warranted. 4.1 Proposed Energy Resource Describe the potential extent/amount of the energy resource that is available. Discuss 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. Work on Previous Phases: The following documents are enclosed for AEA to demonstrate that sufficient reconnaissance work has been completed to support issuance of a FERC non-jurisdictional determination. • Federal Energy Regulatory Commission. July 2012. Order Finding License Not Required. • Alaska Power Company. March 2012. Request for a Jurisdictional Determination by FERC. Feasibility analysis and conceptual design still needs to occur to determine if this project should continue to the final design and construction phases. With the release of State REF Round VIII funds, Phase II activities can begin. Amount of Energy Available, and Pros and Cons of Project: AEA 15003 Page 17 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form The 1 MW Clearwater Creek hydropower project has the estimated potential to provide 3,400,000 average annual kilowatt hours (aKWH) of affordable, renewable energy to Tok and surrounding communities (Tanacross, Tetlin, and Dot Lake), which are currently 100% dependent upon diesel- fired generation, which produces energy costs of $0.50 / kWh (before PCE).7 These communities are currently served by Alaska Power Company (APC), a subsidiary of Alaska Power & Telephone (AP&T). This project is located entirely on lands owned by the State of Alaska, and received a FERC non-jurisdictional determination in 2012, eliminating the need for a more expensive and time- consuming FERC licensing process. The project will eliminate use of 242,857 gallons of diesel fuel per year for a 50+ year operating life, avoiding a total of 12.1m gallons of diesel fuel over its initial 50 year period of operations. The project would help replace approximately 31% of the region’s diesel-fired generation of electricity with clean, renewable hydropower from a local, low-impact source, helping to support the State of Alaska’s goal of 50% renewable energy by 2025. AEA Econometric Workbook Outputs: Note: Period of analysis for the above calculations is 50 years. However, hydropower projects have a useful life of over 100 years, which would effectively double these numbers. APC is also working to complete the Yerrick Creek hydropower project, and has prioritized Yerrick Creek project for completion and commissioning in 2016. Clearwater Creek would serve as the subsequent increment of hydro for the Tok region, which would help further reduce the cost of energy, and provide energy needed for continued economic growth within the Tok community. 7 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf Results NPV Benefits $15,957,327.33 NPV Capital Costs $9,588,161 B/C Ratio 1.66 NPV Net Benefit $6,369,166 Performance Unit Value Displaced Electricity kWh per year 3,400,000 Displaced Electricity total lifetime kWh 170,000,000 Displaced Petroleum Fuel gallons per year 242,857 Displaced Petroleum Fuel total lifetime gallons 12,142,857 Displaced Natural Gas mmBtu per year - Displaced Natural Gas total lifetime mmBtu - Avoided CO2 tonnes per year 2,465 Avoided CO2 total lifetime tonnes 123,250 AEA 15003 Page 18 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form If the Slana-Chistochina-Mentasta grid becomes connected to Tok in the future, these communities will also benefit. Similarly, if Northway, Northway Junction, and Northway Village also become connected to Tok, they will benefit from this project. 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 58.2% of total kWh sold in FY13 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 41.8% of cost-savings being realized by current ratepayers.8 Lowers Energy Costs. It is currently estimated that the project will be able to produce clean energy for half of 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, APC’s Dewey Lakes hydropower project has been operating for 109 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 31% of the region’s diesel-fired generation of electricity with clean, renewable hydropower from a local, low-impact source. The project will eliminate use of 242,857 gallons of diesel fuel per year for a 50+ year operating life, avoiding a total of 12.1m gallons of diesel fuel during the project’s first 50 years of operations. The project displaces 2,465 metric tons of carbon dioxide per year (plus 62 tons of NOx), avoiding 123,250 metric tons of carbon dioxide (plus 3,100 tons of NOx) over the project’s initial 50- year period of operation. This is equivalent to approximately $10.4m in Social Cost of Carbon savings. (Calculated using the average of all four federal calculation methodologies specified by the US Interagency Working Group for Social Cost of Carbon, as required for US EO 12866 review.) Hydropower projects have 100-year-plus lifespans, which means that total savings will be twice that displayed above (or higher, depending on future SCC valuations). 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. 8 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf AEA 15003 Page 19 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form No Difficulties with Power Sales Agreements – The project is being proposed by APC, the incumbent utility, as a self-build project. This eliminates uncertainty regarding the possibility of achieving a power purchase agreement with the incumbent utility. Avoids Costly, Time-Consuming Federal Permitting Requirements. The project is located on State lands and has received a non-jurisdictional determination from the Federal Energy Regulatory Commission (FERC), making it possible to develop this low-impact hydropower project in a timely fashion without undergoing lengthy federal permitting processes through FERC. Benefits Communities which are Still 100% Diesel Dependent. The project will benefit the interconnected communities of the Upper Tanana region, including Tok, Tanacross, Tetlin, and Dot Lake. Unlike other communities in Alaska, Tok and surrounding communities of the upper Tanana region have 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 $0.50 kWh pricing for this service region, with an average PCE payment of $0.28 per eligible kilowatt hour. Potential to Extend Benefit to Additional Communities -- If the Slana-Chistochina-Mentasta grid becomes connected to Tok in the future, these communities will also benefit from the presence of the Clearwater Creek hydropower project. Similarly, if Northway, Northway Junction, and Northway Village also become connected to Tok, they will benefit from this project. All of these communities are served by APC, and are currently 100% dependent on diesel-fired generation. The most recently available AEA PCE report identifies $0.69 / kWh pricing for these service regions, with an average PCE Payment of $0.47 per eligible kilowatt hour. 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 58.2% of total kWh sold in the Tok service region in FY13 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 41.8% of cost-savings being realized by current ratepayers.9 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. Clearwater Creek 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, currently owning 7 hydropower projects: Dewey Lakes, Lutak, Black Bear Lake, Goat Lake, South Fork, Kasidaya Creek, and Falls Creek. APC has developed 4 new hydropower projects in Alaska in the last 20 years, with a 5th hydropower project 9 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf AEA 15003 Page 20 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form (Reynolds Creek) currently entering final construction. APC has over 50 years of experience as a private sector Alaskan business engaged in ownership, development, and reliable operation of hydropower projects. AP&T / APC have assisted a number of other Alaskan utilities with hydropower and energy development projects on a contractual basis. Support for State of Alaska Resource Development and Economic Development Policy. The upper Tanana region is challenged by high energy costs, which limit economic development and employment opportunities. While businesses are actively pursuing new value-adding opportunities within the forest products sector and are conducting mining exploration activities, commercial feasibility of these resource-driven opportunities is limited by high local energy costs. The current situation creates constraints to realizing State of Alaska’s Natural Resource Policy, as defined in Article 8 Section 1 of the State of Alaska Constitution, which is as follows: “It is the policy of the State to encourage the settlement of its land and the development of its resources by making them available for maximum use consistent with the public interest.” Existing Investment and Activity to Date. During the initial reconnaissance phase, APC spent $5,000 for site inspection, one-time stream gaging for a benchmark, and filing of a FERC Non- Jurisdictional Determination in 2012. APC also performed a review of existing studies, reports, and literature, and conducted preliminary reconnaissance-level financial and economic analysis. Willing Private Sector Investor. APC is very interested in participating as an equity investor in the project, and is committing to develop and implement an economically and financially feasible financing package. After economically and financially feasible loan terms can be negotiated, APC would be in the position to make a final financial commitment to the project. 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 (100+ years)10, commercial financing is typically available for a 30 year period at most. Clearwater Creek is a relatively small increment of new hydropower (1 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 minimum integration concerns. APC believes that Clearwater Creek would complement the Yerrick Creek hydropower project – another small hydropower project which is currently scheduled for construction and completion in advance of Clearwater Creek. Discussion of Energy Technology Alternatives in the Tok Region. APC’s “Technology-Neutral” Approach for Lowering Energy Costs for Ratepayers: APC utilizes a “technology neutral” approach, and considers all possible technologies which may produce clean, reliable energy at a lower rate for the benefit of the ratepayers. While APC considers solar, wind, river hydrokinetic, hydropower, biomass, and alternative fuels, the company ultimately focuses on the opportunities which meet the criteria of providing ratepayers with the most affordable, 10 Current knowledge is based on how long hydropower has been utilized; these projects could just as well go 200+ years, or more. AEA 15003 Page 21 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form reliable, and low-risk clean energy possible. After studying a wide variety of options, APC has identified low impact hydropower options such as Clearwater Creek and Yerrick Creek as the renewable energy options offering the best value to ratepayers within the Tok and upper Tanana region.  Solar: Challenged by Intermittency – Solar power is an intermittent resource which is only available when the sun is shining in sufficient quantity to produce useable energy and power. Solar is not yet competitive with diesel-fired generation in the Tok and Upper Tanana region; part of the reason for this is that even in the presence of solar, dispatchable generation sources such as diesel power plants are still needed to supply power to fully serve the local load at times when the sun is not shining – for example, at night, during times of cloud-cover, and during the interior’s long winters when hours of sunshine are scarce. Diesel power plants must still be staffed, maintained, and operated – and so while installation of solar panels may eliminate purchase of some diesel-fired generation, it does not reduce these “fixed costs” incurred by the utility and its ratepayers. While storage and load-shaping technology is available to help to mitigate intermittency, these technologies are not yet commercially competitive versus the cost of diesel-fired generation. There are also limits to the amount of intermittent resources which can be integrated into a small, insular system before significant transmission line and other upgrades are necessary to preserve system stability. The article below, published by the Economist, looks at the costs of “intermittency,” which are oftentimes not reflected in levelized energy costs or comparisons of solar power versus other generation alternatives. http://www.economist.com/news/finance-and-economics/21608646-wind-and- solar-power-are-even-more-expensive-commonly-thought-sun-wind-and Despite these challenges, APC is investigating new opportunities and business models for deployment of solar in APC service regions. While solar deployment may be economically feasible in future years as technology advances and diesel costs continue to rise, the economics of the Clearwater Creek hydropower project are currently estimated to be more attractive. Activities proposed for funding through the REF Round VIII program should help provide more information regarding the cost of hydropower from Clearwater vs. solar.  Wind: Challenged by Intermittency – Like solar, wind is an intermittent resource which requires availability of dispatchable back-up from thermal or hydropower plant sources, and can present significant integration challenges / expenses to small, insular grid systems. APC is studying opportunities for wind deployment and integration in its service regions – however, the economics of the Clearwater Creek hydropower project are currently estimated to be more attractive. Activities proposed for funding through the REF Round VIII program should help provide more information regarding the cost of hydropower from Clearwater vs. wind. AEA 15003 Page 22 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form  Biomass CHP: Challenged by Lack of Viable Market for Heat, and Fuel Supply Risks – With the support of State funding, APC has studied the opportunity for a commercial-scale biomass CHP power plant in the Tok and Upper Tanana region. While studies found that biomass-fired generation of electricity is feasible, hydropower projects such as Yerrick Creek and Clearwater Creek appear more economically attractive than a biomass CHP plant, and offer a better value to the Tok and upper Tanana region’s ratepayers, with significantly less risk. The business case for biomass could be improved upon if a market can be found for the heat produced by a CHP biomass power plant; however, no viable markets currently exist. Other risks and challenges to biomass implementation in the Tok region include securing a long-term timber supply which assures financially feasible operations for a period coinciding with project financing, and obtaining assurances of sufficient fuel quality. It would be necessary to find a supplier with the willingness and financial means to commit to a long-term supply agreement which addresses liquidated damages in the event that fuel of agreed-upon quality is not delivered in a timely manner. Another consideration is fuel cost escalation that could occur over time as nearby biomass is exhausted, creating a need to obtain fuel supply from locations further away, at a higher cost of transportation.  LNG: Currently Challenged by Supply Availability, Economies of Scale, and Technology Issues – While APC has investigated LNG options, an economically viable business model for small-scale LNG has not yet been identified. Challenges include lack of currently available supply, significant transportation/logistics challenges, and lack of commercially viable and cost-competitive technology for LNG storage and powerplants in a service area as small as Tok. Emissions from natural-gas fired generation are lower than those from diesel-fired generation, however, they are still considerably higher than emissions from hydropower generation.  Diesel: A Costly and Unsustainable Energy Source – Tok and the upper Tanana region are 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 political factors. The high cost of diesel-fired generation places financial pressure on rural communities, businesses, and schools, forcing migration to other regions with a more affordable cost of living and doing business. Diesel fuel expenditures are made outside of the community Tok, resulting in ongoing financial leakage and attrition. Diesel-fired generation also has high environmental costs, producing a significant level of emissions and carbon, and carrying risks of fuel spills. Continued 100% dependency on diesel-fired generation is not a sustainable way of life for residents of the Tok and upper Tanana region. Residents in this service area have been increasingly outspoken about the unsustainability of continued 100% reliance on diesel-fired generation. However, diesel-fired generation does present advantages in terms of dependability, dispatchability, and the ability to quickly respond to and match load requirements. It is likely that diesel-fired generation will maintain some presence within the Tok region’s energy mix until a commercially viable and financially feasible thermal generation alternative becomes available. AEA 15003 Page 23 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form  Other Hydropower Options – Yerrick Creek APC and its partners Tanacross Inc. and the Native Village of Tanacross are also working to complete the Yerrick Creek hydropower project. APC has prioritized Yerrick Creek project for completion and commissioning in 2016, which means that Yerrick Creek would be operational in advance of Clearwater Creek. Clearwater Creek would serve as a subsequent increment of hydro for the Tok region, which would help further reduce the cost of energy, and provide energy needed for continued economic growth within the Tok community. The two projects would be complimentary (not redundant) components of a future renewable-dominated Tok regional utility grid. APC believes it is timely to advance our understanding of the Clearwater Creek hydropower project as the Yerrick Creek project proceeds through construction, so that Clearwater can be developed subsequently, in a timely manner, to further increase ratepayer and PCE savings. 4.2 Existing Energy System 4.2.1 Basic configuration of Existing Energy System Briefly discuss the basic configuration of the existing energy system. Include information about the number, size, age, efficiency, and type of generation. The existing electrical energy market in the Upper Tanana area consists of an isolated power grid serving the communities of Tok, Tetlin, Dot Lake and Tanacross, as well as other, scattered rural ratepayers. A diesel powerplant located in Tok supplies this small grid system. The Tok powerplant is comprised of five diesel gensets: Unit #3 = CAT Model D3516, 1320 kW, Purchased / Installed 1999 Unit #4 = CAT/KATO Model 3516, 1135 kW, Purchased / Installed 1989 Unit #5 = CAT/KATO Model 3516, 1135 kW, Purchased / Installed 1995 Unit #8 = CAT/KATO Model D3508, 440 kW, Purchased / Installed 1985 Unit #9 = CAT/KATO Model 3512C, 1050 kW, Purchased / Installed 2008 If the Slana-Chistochina-Mentasta grid becomes connected to Tok in the future, these communities will also benefit from the presence of the Clearwater Creek project. Similarly, if Northway, Northway Junction, and Northway Village also become connected to Tok, they will benefit from this project. All of these communities are served by APC, and are currently 100% dependent on diesel-fired generation. The most recently available AEA PCE report identifies $0.69 / kwh pricing for these service regions, with an average PCE Payment of $0.47 per eligible kilowatt 11. 4.2.2 Existing Energy Resources Used 11 Source: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf AEA 15003 Page 24 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Briefly discuss your understanding of the existing energy resources. Include a brief discussion of any impact the project may have on existing energy infrastructure and resources. Existing power plant resources are described in section 4.2.1. above. Existing potential renewable / alternative energy resources are discussed in section 4.1 above. Clearwater Creek will not produce the types of system stability problems which could be produced by attempting to integrate a high degree of intermittent resources such as wind and solar. 4.2.3 Existing Energy Market Discuss existing energy use and its market. Discuss impacts your project may have on energy customers. Existing Energy Use and Market The project will benefit the interconnected communities of the Upper Tanana region, including Tok, Tanacross, Tetlin, and Dot Lake, as well as additional rural customers. The most recently available AEA PCE report identifies $0.50 kWh pricing for this service region, with an average PCE payment of $0.28 per eligible kilowatt hour. The figures below provide a characterization of this energy market: i. Electricity [kWh] 10.9 GWh ii. Fuel usage Diesel [gal] 778,571 Other NA iii. Peak Load 2.2 MW iv. Average Load 1.1 MW v. Minimum Load 0.5 MW vi. Efficiency 30% vii. Future trends Transition to non-diesel sources, increased distributed generation If the Slana-Chistochina-Mentasta grid becomes connected to Tok in the future, these communities will also benefit from the presence of the Clearwater Creek hydropower project. Similarly, if Northway, Northway Junction, and Northway Village also become connected to Tok, they will benefit from this project. All of these communities are served by APC, and are currently 100% dependent on diesel-fired generation. The most recently available AEA PCE report identifies $0.69 / kWh pricing for these service regions, with an average PCE Payment of $0.47 per eligible kilowatt hour. Impacts upon Energy Customers As discussed at length above, the high and rising cost of energy in these communities severely limits economic opportunities; contributes to unemployment and population outmigration; places pressures upon household budgets, as well as budgets of schools, community facilities, and government entities; and inhibits realization of the State of Alaska’s natural resource policy goals. Development of the Clearwater Creek hydropower project will help mitigate these conditions, and AEA 15003 Page 25 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form create energy cost and economic parity between the Tok and upper Tanana region, and other areas of Alaska. Lowers Energy Costs. It is currently estimated that the project will be able to produce clean energy for half of 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, APC’s Dewey Lakes hydropower project has been operating for 109 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. Potential to Extend Benefit to Additional Communities – If the Slana-Chistochina- Mentasta grid becomes connected to Tok in the future, these communities will also benefit from the presence of the Clearwater Creek hydropower project. Similarly, if Northway, Northway Junction, and Northway Village also become connected to Tok, they will benefit from this project. All of these communities are served by APC, and are currently 100% dependent on diesel-fired generation. The most recently available AEA PCE report identifies $0.69 / kWh pricing for these service regions, with an average PCE Payment of $0.47 per eligible kilowatt hour. 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 58.2% of total kWh sold in the Tok service region in FY13 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 41.8% of cost-savings being realized by current ratepayers.12 4.3 Proposed System Describe the system you are intending to develop and address potential system design, land ownership, permits, and environmental issues. 4.3.1 System Design Provide the following information for the proposed renewable energy system: Renewable Energy Technology: Run-of-river hydropower. Optimum Installed Capacity: 1.0 MW 12 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf AEA 15003 Page 26 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Anticipated Annual Generation: 3,400,000 average annual kilowatt hours. Capacity Factor: 38.9% Integration Concept: The Clearwater Creek hydropower project will be integrated within the incumbent Alaska Power Company utility system as an alternative to current diesel-fired generation. The project will supplant 3,400,000 average annual kilowatt hours of diesel-fired generation, or approximately 31% of the Tok region’s load. Description of Project Features: The proposed Clearwater Creek Hydro Project will consist of a 1.0 MW generating system that will provide hydroelectric power to the isolated APC grid around Tok; currently 100% reliant upon diesel generation. The project will have a small diversion structure, approximately 20,000 feet of penstock and a powerhouse that will house one Turgo generating unit. Diversion Structure – A small diversion structure approximately 300 feet long by 10 feet high that will be rock fill with a concrete spillway and intake. The diversion will have a water surface at approximately 2550 feet above MSL. The intake will convey water from the diversion structure pond through a penstock to the powerhouse. Penstock – The 24-inch-diameter ductile iron penstock will be buried a distance of approximately 20,000 feet to the powerhouse, at elevation 2050 feet. Powerhouse – The 30-foot by 50-foot powerhouse will contain one 1,000 kW Turgo generating unit with 500 feet gross head and a hydraulic capacity of 35 cfs. Tailrace – An open tailrace channel will transport the turbine discharge back into Clearwater Creek for a distance of approximately 400 feet. Substation – A small substation to change the voltage to 34.5 kV will be placed adjacent to the powerhouse. Access Road – An existing 0.5 mile road into the Clearwater Campground will be used in addition to an additional 0.5 mile to the powerhouse and 4 miles to the diversion structure. Current design includes two bridges crossing the creek. Transmission Line – The transmission line will follow the access road out to the highway, a distance of 1.0 miles and will be buried in this stretch. At the highway, the distribution line will be place on single wood pole structures of 45-55 feet in height. The distribution line will travel north to the Tok grid, a distance of approximately 14 miles. The Tok grid is owned and operated by the Applicant and is within the Applicant’s certificated service area. This project will be a step toward energy independence for this remote area that is geographically isolated and is reliant upon fossil fuel for its energy needs. This project will help to avoid the related costs and air quality emissions associated with diesel generation. AEA 15003 Page 27 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form FIGURE 2: PRELIMINARY CONCEPTUAL PROJECT LAYOUT Delivery methods: Project will deliver energy to Alaska Power Company via conventional distribution lines and substations. 4.3.2 Land Ownership 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’s features will be located entirely on lands owned by the State of Alaska. The project is located in both the Tanana State Forest and the Department of Parks and Outdoor Recreation, both of which are within the Alaska Department of Natural Resources. Nearby native allotments can be avoided. 4.3.3 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 discuss potential barriers AEA 15003 Page 28 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form APC received a FERC non-jurisdictional determination in 2012, eliminating the need for FERC license. The following permits will be necessary to construct this project: • State of Alaska Department of Natural Resources (ADNR) – Land permit • ADNR – Water Use Permit – won’t be issued until after operations begin • State of Alaska Department of Fish & Game – Habitat Permit (is likely but not sure yet) • ADNR – State Historical Preservation Office – Review of data and will provide a determination of impacts or not. • State of Alaska Department of Environmental Conservation – 401 Water Quality Certification (they may waive with COE involvement) • U.S. Army Corp of Engineers – 404 Certification (Nation Wide or Individual Permit) Anticipated permitting timeline: Permitting activities would not be completed until Phase III, subsequent to the Phase II activities proposed within the scope of this grant application. Potential barriers: Weather is the single greatest potential barrier to accomplishing any tasks in this part of Alaska. 4.3.4 Environmental Address 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 • Identify and discuss other potential barriers TES: APC will consult with USF&WS as to what concerns they may have in regards to avian species in particular and terrestrial mammals as well. The project is small and should be able to avoid any concerns. Habitat: Fish habitat assessment will occur during this grant funded phase (Phase II). Other species habitat will also be evaluated by the project biologist during field studies. Wetlands: The project site will have a wetland delineation made by field study. Archaeological / Historical: An archaeologist will be hired to conduct initially a literature review and further evaluation as needed or required by SHPO. The historic “Eagle Trail” passes through the project’s access road in the area of the state campground. Further review will occur during this grant funded phase. Land Development Constraints: The state campground could potentially produce constraints; this will be determined as part of proposed Phase II activities. AEA 15003 Page 29 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Telecommunications: This project will not affect telecommunications, but could enhance landline telephone service south of Tok at a later date; would be separate from this project. Aviation: Nothing in this grant funded phase will affect aviation. In the construction and operation phase, the distribution line along the highway will generally be 45-55 feet tall, similar in height to trees along the highway. For this reason, if the project is constructed there should be no obstruction from the project to aviation. In addition, the project stops well short of an abandoned airport just south of downtown Tok. Visual: During this phase of grant funded effort, no visual impacts should occur. The powerhouse and access road from the construction phase could have some visual impact to the campground, but it is too early to know at this time when project design is only conceptual, at best. The distribution line may be buried along the access road out to the highway to minimize this visual impact. 4.4 Proposed New System Costs and Projected Revenues (Total Estimated Costs and Projected Revenues) The level of cost information provided will vary according to the phase of funding requested and any previous work the applicant may have done on the project. Applicants must reference the source of their cost data. For example: Applicants records or analysis, industry standards, consultant or manufacturer’s estimates. 4.4.1 Project Development Cost Provide detailed project cost information based on your current knowledge and understanding of the project. Cost information should include the following: • Total anticipated project cost, and cost for this phase • Requested grant funding • Applicant matching funds – loans, capital contributions, in-kind • Identification of other funding sources • Projected capital cost of proposed renewable energy system • Projected development cost of proposed renewable energy system Anticipated Project costs (based on APC’s knowledge and experience at building hydroelectric projects): AEA APC APC In-Kind Funds Phase Grant Funds Matching Funds Total I – Reconnaissance (1) $0 $0 $5,000 $5,000 II – Feasibility/Conceptual Design (2) $413,600 $100,400 $3,000 $517,000 III - Design and Permitting $320,000 $80,000 $400,000 IV – Construction $8,000,000 $7,000,000 $15,000,000 Total $8,733,600 $7,180,400 $8,000 $15,922,000 (1) APC conducted a site reconnaissance in 2012. (2) APC stream gauge equipment. AEA 15003 Page 30 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Proposed Costs for Phase II: Feasibility Analysis/Conceptual Design Phase II Milestones Anticipated Completion Date RE - Funds Grant Funds Grantee Matching Funds Source of Matching Funds: Cash/In- kind/Federal Grants/Other State Grants/Other TOTALS Consult with Agencies & file for Permits to conduct studies July 2015 - Dec 2016 $20,000 $5,000 APC $25,000 Site Visit by Engineering Aug-Sept 2015 $12,800 $3,200 APC $16,000 Conduct studies Aug 2015-Oct 2016 Stream gage installation & maintenance Aug 2015 -Aug 2017 $40,000 $10,000 $3,000 $53,000 Wetland delineation June-Aug 2016 $32,800 $8,200 APC $41,000 TES botanical survey June-Aug 2016 $8,000 $2,000 APC $10,000 Fish survey Aug 2015-Oct 2016 $168,800 $42,200 APC $211,000 Wildlife Survey (Avian) May-Aug 2016 $16,000 $4,000 APC $20,000 Water quality sampling Aug 2015-Oct 2016 $12,000 $3,000 APC $15,000 Cultural Resource Survey June-Aug 2016 $24,800 $6,200 APC $31,000 Topographic mapping Aug 2015-Oct 2016 $40,000 $10,000 APC $50,000 Feasibility Analysis Oct-Dec 2016 $16,000 $4,000 APC $20,000 Conceptual Design Oct-Dec 2016 $20,000 $5,000 APC $25,000 Totals July 2015 - Dec 2016 $411,200 $102,800 $3,000 $517,000 Budget Categories: Direct Labor & Benefits $102,400 $25,600 APC $128,000 Travel & Per Diem $6,400 $1,600 APC $8,000 Equipment $3,000 $3,000 Materials & Supplies $0 Contractual Services $302,400 $75,600 APC $378,000 Construction Services $0 Other $0 TOTALS $411,200 $102,800 $3,000 $517,000 AEA 15003 Page 31 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Requested Grant Funding: $413,600 (80% of total cost for Phase II) Applicant Matching Funds: $100,400 (19.4% of total cost for Phase II) $8,000 ($5,000 Phase I; $3,000 in-kind stream gauge Phase II) $108,400 (total APC investment; 21%) Other Funding Sources: Other funding sources have not been identified at this time. AP&T will provide the $100,400 in matching funds for Phase II from its normal operating funds. Projected Capital Cost of Renewable Energy System: $15,000,000 (assumed to be the cost of Phase IV Construction) Projected Development Cost of Proposed Renewable Energy System: $922,000 (assumed to be the sum of Phase I, II, and III costs). 4.4.2 Project Operating and Maintenance Costs Include anticipated O&M costs for new facilities constructed and how these would be funded by the applicant. (Note: Operational costs are not eligible for grant funds however grantees are required to meet ongoing reporting requirements for the purpose of reporting impacts of projects on the communities they serve.) The O&M cost for the Project is estimated to be approximately $100,000 per year. APC will operate and maintain the Project with proceeds from sale of power to its customers. No grant funding shall be requested for operation and maintenance. 4.4.3 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 The customer for power is Alaska Power Company – the applicant requesting grant funds. Potential sales price is currently estimated to be half the cost of diesel-fired generation in year 1 of operations. This estimate will be refined and examined in further detail following the outcome of Phase II activities. Proposed Rate of Return from Grant-Funded Project: The rate of return for Clearwater Creek would be regulated by the Regulatory Commission of Alaska. The project would generate a regulated return on private investment only, consistent with the rate of return for similar APC 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. 4.4.4 Project Cost Worksheet AEA 15003 Page 32 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Complete the cost worksheet form which provides summary information that will be considered in evaluating the project. Please fill out the form provided below. Renewable Energy Source The Applicant should demonstrate that the renewable energy resource is available on a sustainable basis. Annual average resource availability. 3,400,000 aKWH Existing Energy Generation and Usage a) Basic configuration (if system is part of the Railbelt 13 grid, leave this section blank) i. Number of generators/boilers/other 5 ii. Rated capacity of generators/boilers/other Unit #3 = CAT Model D3516, 1320 kW, Purchased / Installed 1999 Unit #4 = CAT/KATO Model 3516, 1135 kW, Purchased / Installed 1989 Unit #5 = CAT/KATO Model 3516, 1135 kW, Purchased / Installed 1995 Unit #8 = CAT/KATO Model D3508, 440 kW, Purchased / Installed 1985 Unit #9 = CAT/KATO Model 3512C, 1050 kW, Purchased / Installed 2008 iii. Generator/boilers/other type As noted above iv. Age of generators/boilers/other As noted above v. Efficiency of generators/boilers/other 14 kwh per gallon of diesel (aggregate for all generators) b) Annual O&M cost (if system is part of the Railbelt grid, leave this section blank) i. Annual O&M cost for labor $80,000 (approximate) ii. Annual O&M cost for non-labor $20,000 (approximate) 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] 10.9 GWh ii. Fuel usage Diesel [gal] 778,571 Other NA iii. Peak Load 2.2 MW iv. Average Load 1.1 MW v. Minimum Load 0.5 MW 13 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. AEA 15003 Page 33 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form vi. Efficiency 30% vii. Future trends Transition to non-diesel sources, increased distributed generation 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 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] 1 MW Run-of-River hydropower b) Proposed annual electricity or heat production (fill in as applicable) i. Electricity [kWh] 3,400,000 aKWH 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 Project Cost a) Total capital cost of new system $15,000,000 b) Development cost $922,000 c) Annual O&M cost of new system $100,000 (approximately) d) Annual fuel cost None Project Benefits a) Amount of fuel displaced for i. Electricity Estimated 242,857 gallons of diesel per year ii. Heat NA iii. Transportation NA b) Current price of displaced fuel $4 / gallon – equivalent to $0.2857 / kwh AEA 15003 Page 34 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form c) Other economic benefits $75,000 in deferred maintenance/replacement of diesel generator at Tok power plant d) Alaska public benefits Significant PCE savings for the State of Alaska. State PCE statistics indicate the 58.2% of total kWh sold in FY13 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 41.8% of cost-savings being realized by current ratepayers.14 Social Cost of Carbon avoidance is calculated below. AEA Econometric Workbook Outputs: Note: Period of analysis for the above calculations is 50 years. However, hydropower projects have a useful life of over 100 years, which would effectively double these numbers. Power Purchase/Sales Price a) Price for power purchase/sale Currently estimated at half the cost of diesel-fire generation, however, this is a reconnaissance-level 14 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf Results NPV Benefits $15,957,327.33 NPV Capital Costs $9,588,161 B/C Ratio 1.66 NPV Net Benefit $6,369,166 Performance Unit Value Displaced Electricity kWh per year 3,400,000 Displaced Electricity total lifetime kWh 170,000,000 Displaced Petroleum Fuel gallons per year 242,857 Displaced Petroleum Fuel total lifetime gallons 12,142,857 Displaced Natural Gas mmBtu per year - Displaced Natural Gas total lifetime mmBtu - Avoided CO2 tonnes per year 2,465 Avoided CO2 total lifetime tonnes 123,250 AEA 15003 Page 35 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form estimate which will be revised subsequent to the outcome of proposed Phase II activities. Project Analysis a) Basic Economic Analysis Project benefit/cost ratio AEA-generated BCR of 1.66 Payback (years) Currently estimated at 30 years based upon a 50 year project period, divided by 1.66 BCR. AEA Econometric Workbook Outputs: Note: Period of analysis for the above calculations is 50 years. However, hydropower projects have a useful life of over 100 years, which would effectively double these numbers. Displaces 2,465 metric tons of carbon dioxide per year, avoiding 123,250 metric tons of carbon dioxide over the project’s initial 50-year period of operation. This is equivalent to approximately $10.4m in Social Cost of Carbon savings. (Calculated using the average of all four federal calculatation methodologies specified by the US Interagency Working Group for Social Cost of Carbon, as required for US EO 12866 review.) Hydropower projects have 100-year-plus lifespans, which means that total savings will be twice that displayed above (or higher, depending on future SCC valuations). 4.4.5 Impact on Rates Briefly explain what if any effect your project will have on electrical rates in the proposed benefit area. If the is for a PCE eligible utility please discuss what the expected impact would be for both pre and post PCE. State PCE Savings: Results NPV Benefits $15,957,327.33 NPV Capital Costs $9,588,161 B/C Ratio 1.66 NPV Net Benefit $6,369,166 Performance Unit Value Displaced Electricity kWh per year 3,400,000 Displaced Electricity total lifetime kWh 170,000,000 Displaced Petroleum Fuel gallons per year 242,857 Displaced Petroleum Fuel total lifetime gallons 12,142,857 Displaced Natural Gas mmBtu per year - Displaced Natural Gas total lifetime mmBtu - Avoided CO2 tonnes per year 2,465 Avoided CO2 total lifetime tonnes 123,250 AEA 15003 Page 36 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form 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.15 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 58.2% of total kWh sold in the Tok region in FY13 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 41.8% of cost-savings being realized by current ratepayers.16 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. The project will benefit the interconnected communities of the Upper Tanana region, including Tok, Tanacross, Tetlin, and Dot Lake. The most recently available AEA PCE report identifies $0.50 kWh pricing for this service region, with an average PCE payment of $0.28 per eligible kilowatt hour. If the Slana-Chistochina-Mentasta grid becomes connected to Tok in the future, these communities will also benefit from the presence of the Yerrick Creek hydropower project. Similarly, if Northway, Northway Junction, and Northway Village also become connected to Tok, they will benefit from this project. All of these communities are served by APC, and are currently 100% dependent on diesel- fired generation. The most recently available AEA PCE report identifies $0.69 / kWh pricing for these service regions, with an average PCE Payment of $0.47 per eligible kilowatt hour. Impacts upon Energy Customers As discussed at length above, the high and rising cost of energy in beneficiary communities severely limits economic opportunities; contributes to unemployment and population outmigration; places pressures upon household budgets, as well as budgets of schools, community facilities, and government entities; and inhibits realization of the State of Alaska’s natural resource policy goals. Development of the Clearwater Creek hydropower project will help mitigate these conditions, and create energy cost and economic parity between the Tok and upper Tanana region, and other areas of Alaska. Lowers Energy Costs. It is currently estimated that the project will be able to produce clean energy for half of the cost of diesel-fired generation of electricity. Over time, annual savings will increase as the cost of diesel fuel continues to escalate over stable 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 15 Source: http://www.akenergyauthority.org/PDF%20files/PCEProgramGuideJuly292014EDITS.pdf 16 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf AEA 15003 Page 37 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form 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 109 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. Potential to Extend Benefit to Additional Communities -- If the Slana-Chistochina- Mentasta grid becomes connected to Tok in the future, these communities will also benefit from the presence of the Clearwater Creek hydropower project. Similarly, if Northway, Northway Junction, and Northway Village also become connected to Tok, they will benefit from this project. All of these communities are served by APC, and are currently 100% dependent on diesel-fired generation. The most recently available AEA PCE report identifies $0.69 / kWh pricing for these service regions, with an average PCE Payment of $0.47 per eligible kilowatt hour. 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 58.2% of total kWh sold in the Tok service region in FY13 are PCE-eligible kWh; if this ratio holds true, the State of Alaska would realize significant PCE subsidization savings, with approximately 41.8% of cost-savings being realized by current ratepayers.17 17 Source: Most recently available AEA PCE report: http://www.akenergyauthority.org/PDF%20files/pcereports/FY13StatisticalRptComt.pdf AEA 15003 Page 38 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form SECTION 5– PROJECT BENEFIT Explain the economic and public 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: • Potential annual fuel displacement (gallons and dollars) over the lifetime of the evaluated renewable energy project • Anticipated annual revenue (based on i.e. a Proposed Power Purchase Agreement price, RCA tariff, or cost based rate) • Potential additional annual incentives (i.e. tax credits) • Potential additional annual revenue streams (i.e. green tag sales or other renewable energy subsidies or programs that might be available) • Discuss the non-economic public benefits to Alaskans over the lifetime of the project Potential Fuel Displacement 1 Year – 242,857 gallons -- $971,428 ($2014, assuming $4 / gallon) 50 Years – 12,142,850 gallons -- $48,571,400 ($2014, assuming $4 / gallon) 100 Years – 24,285,700 gallons -- $97,142,800 ($2014, assuming $4 / gallon) Anticipated Annual Revenue To be determined based upon outcome of activities proposed for AEA REF Round VIII funding. Potential Additional Annual Incentives Produces significant PCE savings for the State of Alaska, as discussed above. Potential Additional Annual Revenue Streams While Alaska does currently not have Renewable Portfolio Standards, these conditions could change, and there may potentially be a market for Renewable Energy Certificates or other environmental attributes from the project at a future date. 5.1 Public Benefit for Projects with Private Sector Sales 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. SECTION 6– SUSTAINABILITY Discuss your plan for operating the completed project so that it will be sustainable. Include at a minimum: • Proposed business structure(s) and concepts that may be considered. • How you propose to finance the maintenance and operations for the life of the project • Identification of operational issues that could arise. • A description of operational costs including on-going support for any back-up or existing systems that may be require to continue operation • Commitment to reporting the savings and benefits AEA 15003 Page 39 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form 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. Proposed Operations & Maintenance Project would be owned and operated by APC, an AP&T subsidiary. APC currently operates 7 hydropower projects in Alaska, with an 8th (Reynolds Creek) scheduled for near term construction, and an 9th (Yerrick Creek) scheduled for construction in advance of Clearwater Creek. Back-up requirements There will be no back-up systems installed. APC’s existing Tok-based 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. Mechanical operational issues are typically replacement of worn parts. Other: A potential operational issue is the impact of climate change on inflows to the project. It is not certain what changes will occur, but there is some support for the belief that hydropower operation in Alaska may be beneficially affected by climate change in that there will be more precipitation in the winter in the form of rain rather than snow, which may result in additional energy during winter months when hydropower flows tend to be lowest. Commitment to reporting the savings and benefits In the event of State investment, project partners 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. SECTION 7 – READINESS & COMPLIANCE WITH OTHER GRANTS Discuss what you have done to prepare for this award and how quickly you intend to proceed with work once your grant is approved. Tell us what you may have already accomplished on the project to date and identify other grants that may have been previously awarded for this project and the degree you have been able to meet the requirements of previous grants. APC invested its own private sector resources in funding initial project site reconnaissance activities. Activities included initial stream gauging, which supported a Federal Energy Regulatory Commission (FERC) Non-Jurisdictional Determination filing. FERC informed APC on July 31, 2012, that a federal license will not be required for this project (document enclosed). Because of this, APC has elected to not involve FERC in any stage of environmental review, project design, or construction. AEA 15003 Page 40 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form To date, no grants have been utilized for work on this project. AP&T / APC has also conducted reconnaissance-level economic and financial modelling, which demonstrates that the Clearwater Creek project would be beneficial to the Tok service region, and supports additional investment in advancing the project. APC has received cost estimates from consultants to conduct field studies and topographic mapping starting in July 2015, as soon as Round VIII grant funds are released. A timeline for the different phases of this project can be found in Section 3.2 – Project Schedule and Milestones. APC anticipates that it would complete the Yerrick Creek hydropower prior to the Clearwater Creek project. APC hopes to continue advancing the Clearwater Creek project so that it can be available for timely development, subsequent to the Yerrick project. SECTION 8 – LOCAL SUPPORT AND OPPOSITION Discuss local support and opposition, known or anticipated, for the project. Include letters of support 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 2, 2014 There is significant local support for development and integration of renewable resources. The two letters of support enclosed are directed toward the Yerrick Creek Hydroelectric Project, but are equally representative of support for any renewable energy for the Tok area, and therefore have a place with this grant application for Clearwater Creek. There is significant community opposition to continued reliance upon diesel-fired generation. SECTION 9 – GRANT BUDGET Tell us how much you are seeking in grant funds. Include any investments to date and funding sources, how much is being requested in grant funds, and additional investments you will make as an applicant. 9.1 Funding sources and Financial Commitment Provide a narrative summary regarding funding source and your financial commitment to the project APC is seeking $413,600 in AEA REF Round VIII grant funding for Phase II activities, which would be matched by $100,400 in private funds PLUS $3,000 in in-kind equipment supplied by AP&T / APC for a total 20% match. APC investment to date (estimated $5,000) has funded initial reconnaissance activities, including: stream flow investigation and analysis; preliminary economic benefit and financial modelling; a review of existing studies, reports, and literature; and filing for and receiving a FERC Non- Jurisdictional Determination. FERC issued the Non-Jurisdictional Decision in July 2012. AEA 15003 Page 41 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form PHASE II GRANT BUDGET See below for a cost breakdown. Depending upon outcomes of Phase II activities, APC anticipates funding future project activities through a combination of private debt/equity, and would seek to utilize grant programs including the AEA REF program to provide affordably-priced clean energy for ratepayers in the Tok region. APC is very interested in participating as an equity investor in the project, providing a technically feasible design can be developed, and an economically and financially feasible financing package can be developed. Activities proposed for AEA REF Round VIII funding will support development of the level of knowledge required to develop a viable design and business case for the project, which will be used to gain investment commitments. 9.2 Cost Estimate for Metering Equipment Please provide a short narrative, and cost estimate, identifying the metering equipment, and its related use to comply with the operations reporting requirement identified in Section 3.15 of the Request for Applications. Does not apply. AEA APC Phase Grant Funds Matching Funds Total I – Reconnaissance (1) $0 $0 $5,000 $5,000 II – Feasibility/Conceptual Design (2)$413,600 $100,400 $3,000 $517,000 III - Design and Permitting $320,000 $80,000 $400,000 IV – Construction $8,000,000 $7,000,000 $15,000,000 Total $8,733,600 $7,180,400 $8,000 $15,922,000 (1) APC conducted a site reconnaissance in 2012. (2) APC stream gauge equipment. APC In-Kind Funds AEA 15003 Page 42 of 45 7/2/14 Renewable Energy Fund Round VIII Grant Application - Standard Form Phase II Budget: Clearwater Creek Hydro APC – Indicates cash match provided by APC / AP&T. Phase II Milestones Anticipated Completion Date RE - Funds Grant Funds Grantee Matching Funds Source of Matching Funds: Cash/In- kind/Federal Grants/Other State Grants/Other TOTALS Consult with Agencies & file for Permits to conduct studies July 2015 - Dec 2016 $20,000 $5,000 APC $25,000 Site Visit by Engineering Aug-Sept 2015 $12,800 $3,200 APC $16,000 Conduct studies Aug 2015-Oct 2016 Stream gage installation & maintenance Aug 2015 -Aug 2017 $40,000 $10,000 $3,000 $53,000 Wetland delineation June-Aug 2016 $32,800 $8,200 APC $41,000 TES botanical survey June-Aug 2016 $8,000 $2,000 APC $10,000 Fish survey Aug 2015-Oct 2016 $168,800 $42,200 APC $211,000 Wildlife Survey (Avian)May-Aug 2016 $16,000 $4,000 APC $20,000 Water quality sampling Aug 2015-Oct 2016 $12,000 $3,000 APC $15,000 Cultural Resource Survey June-Aug 2016 $24,800 $6,200 APC $31,000 Topographic mapping Aug 2015-Oct 2016 $40,000 $10,000 APC $50,000 Feasibility Analysis Oct-Dec 2016 $16,000 $4,000 APC $20,000 Conceptual Design Oct-Dec 2016 $20,000 $5,000 APC $25,000 Totals July 2015 - Dec 2016 $411,200 $102,800 $3,000 $517,000 Budget Categories: Direct Labor & Benefits $102,400 $25,600 APC $128,000 Travel & Per Diem $6,400 $1,600 APC $8,000 Equipment $3,000 $3,000 Materials & Supplies $0 Contractual Services $302,400 $75,600 APC $378,000 Construction Services $0 Other $0 TOTALS $411,200 $102,800 $3,000 $517,000 AEA 15003 Page 43 of 45 7/2/14 APPENDICES  Governing Body Resolution  Certification  Figures  FERC Non-Jurisdictional Determination  Letters of Support  Resumes  Permitting  Photos GOVERNING BODY RESOLUTION CERTIFICATION FIGURES FERC NON-JURISDICTION DETERMINATION 140 FERC ¶ 62,091 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Alaska Power & Telephone Company Docket No. DI12-4-000 ORDER FINDING LICENSING NOT REQUIRED (July 31, 2012) 1. On March 29, 2012, Alaska Power & Telephone Company (APT) filed a Declaration of Intention (DI) concerning the proposed Clearwater Creek Hydro Project (project), which will be located on Clearwater Creek, near the town of Tok, Alaska, at T. 16 N., R. 11 E., secs. 1, 2, 3, and 12; T. 16 N., R. 12 E., secs. 1, 2, 3, 7, 9, 10, 17, and 18; T. 17 R. 12 E., secs. 14, 23, 26, and 35, Copper River Meridian. PROJECT DESCRIPTION 2. The proposed run-of-river Clearwater Creek Hydro Project will consist of: (1) an approximately 300–foot-long, 10-foot-high rock-filled and concrete diversion structure on Clearwater Creek diverting water into a 20,000-foot-long, 24-inch-diameter ductile iron buried penstock; (2) a proposed 30-foot wide, 50-foot-long powerhouse, containing a 1,000-kW Turgo generating unit and electrical generating equipment; (3) an open, 400- foot-long tailrace from the powerhouse to Clearwater Creek; (4) a 14-mile-long transmission line; and (5) appurtenant facilities. The power will be used by local communities. PUBLIC NOTICE 3. Notice of the DI was published on April 3, 2012. Protests, comments, and/or motions to intervene were to be filed by May 3, 2012. On May 4, 2012, the Department of Fish and Game (DFG), State of Alaska, filed a motion to intervene, but had no comments relating to the jurisdictional status of the proposed project. The DFG commented that it has identified a number of fish and wildlife resource concerns, but these concerns were not related to the jurisdictional determination, and would be sent to APT separately. No other protests, comments, or motions to intervene have been received. Docket No. DI12-4-000 - 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 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. Based on available information it does not appear that the proposed project would be located on a navigable water of the United States. It will not occupy any public lands or reservations of the United States, and will not use surplus water or waterpower from a Federal government dam. The proposed project would be constructed after August 26, 1935, and would use water from a Commerce Clause stream,1 but would not affect interstate commerce because it would not be connected to the interstate grid. Therefore, the project does not require licensing under Section 23(b)(1) of the FPA. CONCLUSION 6. Consequently, Section 23(b)(1) of the FPA does not require licensing of the proposed Clearwater Creek H ydro Project. If evidence sufficient to require licensing is found in the future, section 23(b)(1) would require licensing. Under section 4(g) of the FPA, the project owner could then be required to apply for a license. The Director orders: (A) Section 23(b)(1) of the Federal Power Act does not require licensing of the proposed Clearwater Creek Hydro Project. This order is issued without prejudice to any future determination upon new or additional evidence that licensing is required. 1 For purposes of FPA section 23(b)(1), Commerce Clause streams are the headwaters and tributaries of navigable waters of the United States. See FPC v. Union Electric Co., 381 U.S. 90, 94-96 (1965). Clearwater Creek is tributary to the Tok River, which is tributary to the Tanana and Yukon Rivers. Docket No. DI12-4-000 - 3 - (B) This order constitutes final agency action. Any party may file a request for rehearing of this order within 30 days 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 (2012). 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. Charles K. Cover, P.E. Chief, Project Review Branch Division of Hydropower Administration and Compliance (blank on purpose) March 29, 2012 Kimberly D. Bose Office of Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Re: Clearwater Creek Hydro Project Petition for Declaratory Order Dear Ms. Bose: We respectfully submit this e-filing of the following Declaration of Intent and Petition for Declaratory order that the Clearwater Creek 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. Respectfully Submitted, Glen D. Martin Project Manager (360) 385-1733 x122 (360) 385-7538 fax Enc. (as stated) ALASKA POWER & TELEPHONE COMPANY DECLARATION OF INTENT FOR THE CLEARWATER CREEK HYDROELECTRIC PROJECT Submitted to: FEDERAL ENERGY REGULATORY COMMISSION Washington, D.C. MARCH 2012 Petition for Declaratory Order-FERC Clearwater Creek Hydro Project March 2012 Page 2 DECLARATION OF INTENT The location of the project: State: Alaska Town: N/A Street: N/A County: (Alaska does not have counties) Census Tract: Census Tract 1, Southeast Fairbanks Census Area, Alaska Stream: Clearwater Creek River Basin Name: Tok River Township, Range, and Meridian: T16N, R11E, CRM & T16N, R12E, 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 207 Tok, AK 99780-0207 (907) 883-5101 (360) 883-5815 FAX john.h@aptalaska.com Petition for Declaratory Order-FERC Clearwater Creek Hydro Project March 2012 Page 3 PROJECT DESCRIPTION This document is a declaration of intent to develop a 1.0 MW hydropower project at Clearwater Creek approximately 16 miles south of Tok in South Central Alaska, as in Figure 1. The Project is located within the Copper River Meridian (CRM), the Township of T16N, the Range of R11E, and the Sections 1, 2, and 12, and CRM, T16N, R12E, Sections 7, 17, and 18 as shown in Figure 1. The Project will utilize the natural flows in Clearwater Creek. The creek has an estimated drainage area of approximately 26.7 SQMI at the point of the proposed diversion structure. The proposed project is located on lands not owned by the United States and is on a non-navigable stream. The project will provide hydroelectric power to an area solely reliant upon diesel generation. The area grid this project would intertie with is operated by the Applicant. The communities to be served would be Tok, Dot Lake, Healy Lake, Dry Creek, Tanacross, Tetlin, and Northway. These communities are on an ‘isolated’ grid, owned and operated by the Applicant; currently fed by 100% diesel generation. The distance to intertie with the Tok grid would be approximately 14 miles north. Transmission poles (single wood structures) would be place within the right-of-way (ROW) of the Glenn Highway. Land ownership is primarily state land including the highway ROW. 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 Clearwater Creek 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 Clearwater Creek Project. 1. PROJECT DESCRIPTlON The proposed Clearwater Creek Hydro Project will consist of a 1.0 MW generating system that will provide hydroelectric power to the isolated AP&T grid around Tok; currently 100% reliant upon diesel generation. The project will have a small diversion structure, approximately 20,000 feet of penstock and a powerhouse that will house one Turgo generating unit. Diversion Structure – A small diversion structure approximately 300 feet long by 10 feet high that will be rock fill with a concrete spillway and intake. The diversion will have a water surface at approximately 2550 feet above MSL. The intake will convey water from the diversion structure pond through a penstock to the powerhouse. Petition for Declaratory Order-FERC Clearwater Creek Hydro Project March 2012 Page 4 Penstock – The 24-inch-diameter ductile iron penstock will be buried a distance of approximately 20,000 feet to the powerhouse, at elevation 2050 feet. Powerhouse – The 30-foot by 50-foot powerhouse will contain one 1,000 kW Turgo generating unit with 500 feet gross head and a hydraulic capacity of 35 cfs. Tailrace – An open tailrace channel will transport the turbine discharge back into Clearwater Creek for a distance of approximately 400 feet. Substation – A small substation to change the voltage to 34.5 kV will be placed adjacent to the powerhouse. Access Road – An existing 0.5 mile road into the Clearwater Campground will be used in addition to an additional 0.5 mile to the powerhouse and 4 miles to the diversion structure. Current design includes two bridges crossing the creek. Transmission Line – The transmission line will follow the access road out to the highway, a distance of 1.0 miles and will be buried in this stretch. At the highway, the transmission line will be place on single wood pole structures of 45- 55 feet in height. The transmission line will travel north to the Tok grid, a distance of approximately 14 miles. The Tok grid is owned and operated by the Applicant and is within the Applicant’s certificated service area. This project will be a step toward energy independence for this remote area that is geographically isolated and is reliant upon fossil fuel for its energy needs. This project will help to avoid the related costs and air quality emissions associated with diesel generation. The Project would typically be automatically operated and run-of-river. 2. JURISDICTIONAL ANALYSIS Section 23(b) of the Federal Power Act would require 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: Petition for Declaratory Order-FERC Clearwater Creek Hydro Project March 2012 Page 5 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, as discussed below: a. Navigability Clearwater Creek is a small mountain stream emanating from the Alaska Range dropping from approximately 5,100 feet above MSL to the Tok River at 1,850 feet MSL over a distance of about 12 miles (averaging about 270 feet elevation change per mile). The photo below of this creek, although snow covered, shows a narrow channel that is boulder strewn. The width of the creek after spring flood has a range between 6-12 feet, depending on the location. Down by the campground it is about 12 feet wide. The creek channel consists of a gravel, cobble, and boulder substrate. Water depths are generally less than one foot except during flood periods in the late spring and early summer. Figure 1: Photo of Clearwater Creek looking downstream Petition for Declaratory Order-FERC Clearwater Creek Hydro Project March 2012 Page 6 Clearwater Creek is not considered navigable for any portion of its length. b. Land Status The proposed project is located on State of Alaska land; a combination of State Forest and Dept of Transportation (DOT) ROW. No portion of the project is on Federal land. Figure 2: Glenn Highway (Tok Cutoff) north of Clearwater Creek. Photo courtesy of Google Earth. The photo above shows the shoulder of the highway in which the wood pole structures for the transmission line would be placed. Land along the highway is primarily state land with some private lands outside the DOT ROW, including a few Native allotments; please see Figure 3 and Figure 3a.   Petition for Declaratory Order-FERC Clearwater Creek Hydro Project March 2012 Page 7 As shown in Figure 3: Land Management, the project diversion and penstock are on state land. The powerhouse is placed on the west side of the creek to stay on state land, avoiding the Native allotments on the opposite side of the creek. The project will construct a short access road from the powerhouse to meet up with the state campground access road and place a buried transmission line along this route out to the Glenn Highway (a.k.a. Tok Cutoff). The transmission line is then above ground to the community of Tok to the north. The overhead transmission line will consist of single wood pole structures that will be within the DOT ROW. Three Native allotments are found up in Sections 35 and 26 that will be avoided by staying within the highway ROW. It should be noted that we are avoiding the Native allotments because working with BIA is time consuming and thus expensive; we do not believe that Native allotments are federal lands and thus not lands of the United States because of the BIA Trust relationship with individuals. However, we would appreciate the Commissions input on whether this is true. In Figure 3a, the project transmission line is shown meeting the existing Tok power grid, a 7.2 kV distribution line, in Section 14. The Tok distribution line is scheduled to be upgraded to 34.5 kV in the next few years. Only state lands (ADOT) are utilized along this portion of the projects transmission line. As shown, no federal lands are encountered within the project boundary. 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 The Clearwater Creek Hydroelectric Project will generate and sell power to APC (Alaska Power Company; a subsidiary of the Applicant) which supplies power to communities around Tok on the Alaska Highway. The project will not be connected to any interstate power grid, because none exists. The project, having no storage and not being on a navigable stream will have no effect on shipping or interstate commerce in any form. The project is within the applicant’s present certificated service area. Clearwater Creek is not cataloged as an anadromous stream and would have its discharge reenter the creek Petition for Declaratory Order-FERC Clearwater Creek Hydro Project March 2012 Page 8 above the state campground, well above the Tok River which is listed as an anadromous stream (334-40-11000-2490-3660; CO present). 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 Clearwater Creek 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, Director Permitting & Licensing Enc. (as stated) (blank on purpose) LETTERS OF SUPPORT PERMITTING DEPARTMENT OF FISH AND GAME DIVISION OF SPORT FISH SEAN PARNELL, GOVERNOR Research and Technical Services 333 Raspberry Road Anchorage, Alaska 99518-1565 PHONE: (907) 267-2312 FAX: (907) 267-2422 May 4, 2011 Ms. Kimberly Bose, Secretary Federal Energy Regulatory Commission 888 First Street Washington D.C. 20426 Subject: DI12-4-000 Clearwater Creek Hydroelectric Dear Ms. Bose: We appreciate the opportunity to comment on the request for a Non-Jurisdictional Determination filed with the Commission by Alaska Power and Telephone (APT). After discussions with ADF&G staff with management authority over fish and wildlife resources, habitat issues and departmental permitting, ADF&G will make no comment on the request for Non-Jurisdictional Determination. A number of fish and wildlife resource concerns have been identified but are not nexus to the request made by APT and will be sent to APT separately. Thank You for the opportunity to review this project request. Sincerely, Monte Miller Statewide Hydropower Coordinator Alaska Department of Fish and Game Division of Sport Fish/RTS 333 Raspberry Road Anchorage, Alaska 99518-1565 907 267-2312 monte.miller@alaska.gov E Copy: Glen Martin, AP&T Henry Ecton, FERC, Washington D.C. Jim Durst, ADF&G Habitat Division, Fairbanks William Morris, ADF&G Habitat Division, Fairbanks Joseph Klein, ADF&G Sport Fish Division/RTS, Anchorage Bonnie Borba, ADF&G Commercial Fisheries Division, Fairbanks Audra Brase, ADF&G Sport Fish Division, Fairbanks Brandy Baker, ADF&G Sport Fish Division, Delta Junction Torsten Bentzen, ADF&G Division of Wildlife Conservation, Fairbanks Marla Carter, ADF&G Sport Fish Division, Anchorage PHOTOS