July 20, 2020 Melanie Bachman, Esq. Executive Director
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July 20, 2020 Melanie Bachman, Esq. Executive Director Connecticut Siting Council 10 Franklin Square New Britain, CT 06051 RE: Petition of Bloom Energy Corporation for a Declaratory Ruling for the Location and Construction of a 150-Kilowatt Fuel Cell Customer-Side Distributed Resource at The Home Depot, 90 Monroe Turnpike, Trumbull, Connecticut Dear Attorney Bachman: We are submitting an original and fifteen (15) copies of the above-captioned Petition, together with the filing fee of $625. In the Petition, Bloom Energy Corporation (“Bloom”) requests the Connecticut Siting Council approve the construction and operation of a 150-kilowatt fuel cell and associated equipment (the “Facility”). The Facility will be installed at The Home Depot located at 90 Monroe Turnpike, Trumbull, CT (the “Site”). Electricity generated by the Facility will benefit The Home Depot, and any excess electricity will be exported to the electric grid. The Facility will be fueled by natural gas. Should you have any questions, concerns, or require additional information, please contact me at (860) 839-8373. Sincerely, Bloom Energy Justin Adams [email protected] (860) 839-8373 4353 North First Street San Jose CA 95134 T 408 543 1500 F 408 543 1501 www.bloomenergy.com STATE OF CONNECTICUT CONNECTICUT SITING COUNCIL PETITION OF BLOOM ENERGY : PETITION NO. ____ CORPORATION FOR A DECLARATORY : RULING FOR THE LOCATION AND : CONSTRUCTION OF A 150-KILOWATT FUEL : CELL CUSTOMER-SIDE DISTRIBUTED : RESOURCE AT 90 MONROE TURNPIKE, : TRUMBULL, CT : JULY 20, 2020 PETITION OF BLOOM ENERGY CORPORATION FOR A DECLARATORY RULING I. INTRODUCTION Pursuant to Conn. Gen. Stat. §§ 4-176 and 16-50k(a) and Conn. Agencies Regs. § 16-50j- 38 et seq., Bloom Energy Corporation (“Bloom”) requests that the Connecticut Siting Council (“Council”) approve by declaratory ruling the location and construction of a customer-side distributed resources project at The Home Depot located at 90 Monroe Turnpike, Trumbull, Connecticut (the “Site”). Bloom will install one (1) ES-5 Bloom Energy Server solid oxide fuel cell and associated equipment (the “Facility”), providing 150 kilowatts (“kW”) (net) of power to the Site. See Exhibits 1 and 2. The Facility will be installed, maintained and operated by Bloom under a 15-year power purchase agreement owned by a third-party financing source. Conn. Gen. Stat. § 16-50k(a) provides that: Notwithstanding the provisions of this chapter or title 16a, the council shall, in the exercise of its jurisdiction over the siting of generating facilities, approve by declaratory ruling ... (B) the construction or location of any fuel cell, unless the council finds a substantial adverse environmental effect, or of any customer-side distributed resources project or facility ... with a capacity of not more than sixty- 1 4353 North First Street San Jose CA 95134 T 408 543 1500 F 408 543 1501 www.bloomenergy.com five megawatts, as long as such project meets air and water quality standards of the Department of Energy and Environmental Projection…. The proposed fuel cell will be a customer-side distributed resources facility under 65 MW that complies with the air and water quality standards of the State of Connecticut Department of Energy and Environmental Projection (“DEEP”). Bloom submits that no Certificate is required for the proposed Facility, as the installation would not have a substantial adverse environmental effect in the immediate vicinity of the Site or in the State of Connecticut. II. COMMUNICATIONS Correspondence and other communication regarding this petition should be directed to the following parties: Justin Adams Alicia Surowiec Bloom Energy Corporation Bloom Energy Corporation 4353 North First Street 4353 North First Street San Jose, CA 95134 San Jose, CA 95134 Telephone: (408) 543-1500 Telephone: (408) 543-1500 Fax: (408) 543-1501 Fax: (408) 543-1501 Email: [email protected] Email: [email protected] III. DISCUSSION A. The Facility The Facility will be a 150-kW customer-side distributed resource consisting of one (1) Bloom solid oxide fuel cell Energy Server, model ES5-VA4AAN, and associated equipment. As shown in Exhibit 2, the fuel cell and associated equipment (utility cabinets, water deionizers, telemetry cabinets, and disconnect switches) will be installed in the northeastern corner of the property, behind the retail building. The installation will be in a cleared area adjacent to the paved area at the rear of the building. The Facility will be interconnected to the building’s 2 4353 North First Street San Jose CA 95134 T 408 543 1500 F 408 543 1501 www.bloomenergy.com existing electrical switchgear and fueled by natural gas supplied by Eversource. See Exhibit 3 for details, photographs and equipment specifications. The Facility will interconnect to the Site’s distribution system and operate in parallel with the grid to provide the Site’s electrical requirements. Any electricity generated in excess of the Site’s requirement will be exported to the grid in accordance with the UIL interconnection technical requirements. The Facility will not be capable of outputting power in a grid- independent capacity. At the request of The Home Depot’s energy management team, Bloom sized the system at 150 kW. The request was based on an annual load profile of the typical Home Depot building, with the intent of limiting the net export to 1-2% throughout the year during low energy usage periods, generally at night and/or when the store is closed. Any energy exported to the grid would be sold under the Net Metering tariff and is reflected in the Interconnection Application for the Site. The operational life of the Facility is for the life of the 15-year contract. At the conclusion of the 15-year contract, The Home Depot may renew the contract, return the Facility at no cost, or buy the Facility at a fair market value. The interconnection application for the Facility will be submitted to UIL in August 2020. Bloom anticipates initial feedback, including an impact analysis and cost determination, within approximately 30 days of submission. Final approvals are anticipated in October 2020. B. Public Health and Safety The Facility will be installed in compliance with applicable building, plumbing, electrical, and fire codes. The Facility is enclosed, factory-assembled and tested prior to installation on the Site. Solid oxide media in the fuel cells are exchanged at roughly five-year 3 4353 North First Street San Jose CA 95134 T 408 543 1500 F 408 543 1501 www.bloomenergy.com intervals. Extensive hardware, software and operator safety control systems are utilized, and will be controlled from a Bloom Energy Remote Monitoring Control Center (“RMCC”). Internal sensors continuously monitor system operation and provide for system components to shut down if safety circuits detect a condition outside normal operating parameters; the RMCC operator can initiate an emergency shutdown if warranted. Town of Trumbull Fire Department personnel are provided with an Emergency Response Plan. Exhibit 5. The Facility will be installed in accordance with NFPA 8531. The Facility does not burn natural gas; it is used in a chemical reaction to generate electricity, and is digested almost immediately upon entering the unit and is no longer combustible. Before commissioning, the fuel lines (pipes) are cleaned in accordance with Conn. Gen. Stat. Section 16-50ii2. C. Existing Environment i. The Site The Facility would be installed in the northeastern corner of a 17.76-acre parcel on the east side of Monroe Turnpike (State Route 111) in the northeastern area of the Town of Trumbull (“Town”). The property is in the Town’s Commercial Zone B-C (Business). The Facility is designed to take advantage of utility infrastructure while minimizing impact on operational requirements and traffic and pedestrian flow within the Site. Commercial and light industrial development exists along Route 11 west and south of the Site. Two residential properties are immediately to the north, between the Site and industrial properties; Old Mine Park, a municipal property, is to the east. Old Mine Park is largely wooded, and contains trails and a National Register of Historic Places Archaeological Site deriving from a 1 Standard for the Installation of Stationary Fuel Cell Power Systems, 2015 Edition 2 Public Act 11-101, An Act Adopting Certain Safety Recommendations of the Thomas Commission 4 4353 North First Street San Jose CA 95134 T 408 543 1500 F 408 543 1501 www.bloomenergy.com historical use. The nearest property line to the proposed Facility equipment is the boundary with one of the two residential properties, at approximately 93’ to the east. ii. Wildlife and Habitat Based on a review of the publicly available Connecticut Department of Energy and Environmental Protection (DEEP) Natural Diversity Database (NDDB) June 2020 data, the proposed Facility is within .25 mile of an identified location of endangered, threatened and special concern species or significant natural community. The nearest NDDB area is approximately .20 mile from the Site. Exhibit 4. Therefore, a DEEP NDDB request for review was submitted. By letter dated July 13, 2020, DEEP responded that no negative impacts to State- listed species are anticipated from Bloom’s proposed activity at the Site. See Exhibit 4. iii. Wetlands and Watercourses There are no identified natural wetlands or watercourses within the proposed location of the Facility. The nearest identified wetland is approximately 791 feet north of the Facility. Exhibit 4. The Facility is located within a previously developed area and will have no effect on the Site beyond the project area. iv. Flood Zones and Aquifer Protection Area A review of the flood hazard mapping data from Federal Emergency Management Agency’s (“FEMA”) National Flood Insurance Program (“NFIP”) shows the Facility would not be located in either a 100-year or 500-year flood zone. See Exhibit 4. The Site was also reviewed for proximity to Aquifer Protection Areas.