ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION ) OF THE CIYT OF FORREST CITY FOR THE ) DOCKET NO. 15-076-U APPROVAL OF AN INCREASE OF THE ) GENERATING CAPACITY LIMIT OF A ) NET METERING FACILITY ) AMENDED PETITION FOR NET METERING ADJUSTMENT OF GENERATING CAPACITY The City of Forrest City Arkansas petitions this body for an adjustment to the net metering generating capacity in accordance with Arkansas Code Annotated 23-18-604 and the Arkansas Public Service Commission net metering rules. 1. The City of Forrest City Arkansas previously filed a Petition for Adjustment of Net Metering, an answer was filed in response to the same, and the Commission held said Petition in abeyance for 90 days. 2. The City of Forrest City Arkansas hereby amends said Petition and incorporates the former Petition and all of exhibits herein as if they were written line for line word for word. 3. The City of Forrest City Arkansas seeks approval of the Arkansas Public Service Commission for it to have a net metering facility with two (2) separate locations within the City of Forrest City. 4. A Net metering facility is defined by this Commission as a facility for the production of electrical energy that: (a) Uses solar, wind, hydroelectric, geothermal, or biomass resources to generate electricity including, but not limited to, fuel cells and micro turbines that generate electricity if the fuel source is entirely derived from renewable resources; and,
(b) Has a generating capacity of not more than twenty-five (25) kilowatts for residential use or three hundred (300) kilowatts for any other use; and, (c) Is located in Arkansas; and, (d) Can operate in parallel with an electric utility s existing transmission and distribution facilities; and, (e) Is intended primarily to offset part or all of the net-metering customer requirements for electricity; or, (f) Is designated by the Commission as eligible for net metering service pursuant to Ark. Code Ann. 23-18-604(b)(4). 5. House Bill 1004, Act 827 of the Regular Session which is titled AN ACT TO REQUIRE ELECTRIC UTILITIES TO COMPENSATE NET-METERING CUSTOMERS FOR NET EXCESS GENERATION CREDITS IN CERTAIN CIRCUMSTANCES; AND FOR OTHER PURPOSES. has been enacted by the Arkansas legislature and goes into effect 90 days after the closure of the regular session. The regular session was closed on April 22, 2015. 6. Act 827, which amends Arkansas Code Annotated 23-18-604, changes section (b)(5) of that statute to provide that the Arkansas Public Service Commission may increase the generating capacity limits if doing so results in distribution system, environmental, or public policy benefits. 7. The City of Forrest City Arkansas is attempting to develop a facility which would fit the definition of a net metering facility. 8. The City of Forrest City Arkansas facility will be located in Forrest City, Arkansas.
9. The Facility will be designed to operate in parallel with and electric utility s existing transmission and distribution facilities. 10. The Facility is intended primarily to offset part or all of the City of Forrest City s requirements for electricity. 11. The City of Forrest City Arkansas desires to erect said facility; however, the City of Forrest City currently utilizes far in excess of Three Hundred (300) Kilowatts per month and desires to erect a facility which would benefit the city for its full capacity of electrical power that is utilized each month. 12. The City of Forrest City Arkansas currently utilizes in excess of Seven (7) Megawatts of energy per annum and seeks to design a facility which would generate Seven (7) Megawatts per annum. 13. The City of Forrest City Arkansas petitions this body to adjust the Net metering generating capacity for the project. 14. The City of Forrest City Arkansas has accounts and is provided service by both Woodruff Electric and Entergy. 15. The Forrest City Water Utility s General Manager, Calvin Murdock, has contacted both local providers and has kept each of them posted regarding the City s project and desire for net metering. 16. Neither Woodruff Electric, nor Entergy has currently expressed any objection to the potential project. 17. The City of Forrest City, Arkansas proposes to acquire, construct and equip improvements at and/or near the City's Water Treatment Plant & Waste Water Treatment Facility.
18. The City of Forrest City, Arkansas Alternative Energy Power Point is attached hereto and incorporated herein by reference as if it were written, line for line, word for word. 19. The City admits that the financial mechanism has not been approved at this time; however, the City desires to move this process forward to assure that there will be no delay once the project has been approved. 20. The City of Forrest City Arkansas requests a total of Seven (7) Megawatts to be authorized for Net metering for this project. The petition represents that the City is requesting Two and one-half (2.5) Megawatts Net metering to be applied toward Woodruff Electric and the other Two and and one-half (2.5) Megawatts Net metering to be applied toward Entergy. 21. The City has requested more than its current load for several reasons include, but not limited to, the fact that the city may have to finance this project for 15 to 30 years and the costs associated energy will rise significantly over the next 30 years. The city has also considered demand charges and other related expenses which will occur during that time period. In addition, as the City grows, the city will be required to invest in its infrastructure which will include additional lighting and related capital improvements. 22. Once the project enters the construction phase, the City of Forrest City Arkansas will complete all necessary documents including the Standard Interconnection Agreement for Net Metering Facilities with both providers. 23. The City of Forrest City, Arkansas attaches hereto and incorporates herein several documents, including but not limited to a chart from the Solar Energy Industries Association hereinafter referred to as SEIA.
24. Said chart provides that at the end of 2011, there were only 184 solar net metering customers in the State of Arkansas and that number represented 0.99 percent of the then existing installed solar net metering capacity. 25. The City of Forrest City Arkansas attaches hereto and incorporates herein as it they were written line for line word for word the Forrest City Water Utility Alternative Energy Project power point, Alternative Energy Project Engineering report prepared by Roy A. McCann, Ph.D., The 50 States of Solar quarterly look at America s fast evolving distributed solar policy conversation, and the Solar Energy Industries Association reports. 26. The City also includes the testimonies of Calvin Murdock, Roy McCann, and Andrew Durham. 27. The City of Forrest City petitions that body for approval of the increase above and beyond 300 kw for a variety of reasons, including, but not limited to the energy charges that would be saved by the utility if the plan were implemented. 28. As previously stated, the City of Forrest City has accounts with both Woodruff Electric as well as Entergy. 29. The City has two separate proposed site locations. One proposed site is to be located at 3120 Sanyo Road, Forrest City Arkansas. The second proposed site is to be located at 320 St. Francis County Road 290 in Forrest City, Arkansas. 30. In forming its design, the City of Forrest City utilized data from pvwatts.nrel.gov. The PVWatts Model is provided by the National Renewable Energy Laboratory (NREL) which is operated by the Alliance of Sustainable Energy, LLC for the U.S. Department of Energy.
31. The 3120 Sanyo Road location and station identification bears a latitude of 35.05 N and a longitude of 89.98 W. The Weather Data Source is (TMY2) Memphis, TN which is 46 miles away. 32. The PV system specifications for that location are the DC system size is 2.449.44 kw, has a standard module type, and a fixed array. The array tilt is 20, array azimuth is 180, system losses is 17%, inverter efficiency is 96%, and DC to AC size ratio is 1.1. 33. The average cost of electricity purchased from the Utility is estimated to be 0.08$/kWh. The initial cost is estimated to be $1.85$/Wdc with the cost of electricity generated by the system being 0.09 $/kwh. 34. The model reflects that there would be 3,431,262 kwh per year. Month Solar Radiation (kwh/m2/day) AC Energy (kwh) Energy Value January 3.46 212,609 16,435 Febuary 4.18 231,258 17,876 March 5.17 305,442 23,611 April 5.91 326,140 25,211 May 6.18 341,551 26,410 June 6.50 342,942 26,509 July 6.55 355,117 27,451 August 6.50 352,438 27,243 September 5.15 276,807 21,397 October 5.11 291,377 22,523 November 3.65 208,686 16,131
December 3.04 186,796 16,131 Annual 5.12 3,431,263 $ 265,236 35. The 3120 Sanyo Road will be designed for Entergy. The City currently has a total of 26 meters that it utilizes with Entergy from the Forrest City Water Utility alone. The City has additional 17 meters that it anticipates it will use regarding the net metering from the remainder of the city. 36. The second site which is currently designed to be located at 320 St. Francis County Road 290 will be dedicated to Woodruff Electric. 37. The 320 St. Francis County Road 290 location and station identification bears a latitude of 35.05 N and a longitude of 89.98 W. The Weather Data Source is (TMY2) Memphis, TN which is 46 miles away. 38. The PV system specifications for that location DC system size is 2.285 kw, has a standard module type, and a fixed array. The array tilt is 20, array azimuth is 180, system losses is 17%, inverter efficiency is 96%, and DC to AC size ratio is 1.1. 39. The average cost of electricity purchased from the Utility is estimated to be 0.08$/kWh. The initial cost is estimated to be $2.60$/Wdc with the cost of electricity generated by the system being 0.12 $/kwh. 40. The model reflects that there would be 3,200,923 kwh per year. Month Solar Radiation (kwh/m2/day) AC Energy (kwh) Energy Value January 3.46 198,337 15,331 Febuary 4.18 215,733 16,676
March 5.17 284,937 22,026 April 5.91 304,246 23,518 May 6.18 318,920 24,637 June 6.50 319,920 24,730 July 6.55 331,278 25,608 August 6.50 328,779 25,415 September 5.15 258,225 19,961 October 5.11 258,225 21,011 November 3.65 194,677 15,049 December 3.04 174,257 13,470 Annual 5.12 3,200,922 $ 247,432 41. The 320 St. Francis County Road 290 located will be designed for Woodruff Electric. The City of Forrest City Water Utility currently has 20 meters with Woodruff Electric and 3 other meters with the entire city of Forrest City that it plans to use for net metering purposes. 42. The City of Forrest City anticipates that the benefits to the City will be less than 76% net metering with Entergy and 37% over its usage with Woodruff Electric energy offsets per solar energy production. 43. Both of the above preliminary designs are primarily designed to meet the needs of the Forrest City Water Utility and the City of Forrest City Arkansas. 44. The City believes that both utilities will benefit from net metering as well.
45. The Forrest City Water Utility billing analysis for the calendar year of 2014 kwh is as follows: APSC FILED Time: 11/12/2015 1:32:47 PM: Recvd 11/12/2015 1:32:05 PM: Docket 15-076-U-Doc. 4 Woodruff Entergy Months kwh kwh January 232408 247187 February 192574 228809 March 196605 232075 April 174504 186349 May 174504 225834 June 173571 291463 July 213116 282051 August 204197 217490 September 188599 352845 October 199949 212382 November 199953 242240 December 189486 244641 Total 2339466 2963366 5302832 46. The City is requesting a total of 7MW capacity. 47. The aforementioned billing data is for what was formerly the Forrest City Water Utility. This City of Forrest City has additional billing data with both Entergy Arkansas and Woodruff Electric. 48. The billing data for the calendar year 2014 for the remaining portions of the City of Forrest City Arkansas is: 2014 Entergy Kwh 2014 Woodruff Kwh Kwh
Month Month January 155,066 January 6459 65 Feb 12,314 February 9099 50 Mar 144,101 March 5092 62 Apr 152,067 April 7476 64 May 34,864 May 7476 64 Jun 185,474 June 5542 63 Jul 216,755 July 6459 65 Aug 160,764 August 6459 65 Sept 205,092 Sept. 3095 64 Oct 197,136 Oct. 2112 67 Nov 132,410 Nov. 7756 63 Dec 165,277 Dec. 7265 66 Total 1,761,320 74290 758 49. Including the remaining areas of the City of Forrest City, the City has approximately 3,600,000 annual Kwh with Entergy and 2,500,000 annual Kwh with Woodruff Electric. 50. The City anticipates that there may be various benefits achieve by having this solar array. 51. Many of the potential benefits are: 1 Mitigation of Market Power 2 Airborne or Outdoor Emissions The value to the system from reducing output from high marginal production cost plants, mitigating capacity shortages and countering the seller s market power The economic incentives to owners of clean DG technologies and the reduced health risks to society. The pattern of emissions from outdoor or airborne pollutants such as NOx, SO2, and others from clean DG units that are less hazardous than emissions of the conventional plants that DG replaces
3 Reduced Security Risk to Grid 4 Reliability and Power Quality (Distribution System) 5 Voltage Support to Electric Grid 6 Enhanced Electricity Price Elasticity 7 NIMBY Opposition to Central Power Plants and Transmission Lines The value of reducing the reliance on the central grid, making the grid a less appealing terrorist target and reducing the impact of other grid disruptions The value to the utility of avoiding outage costs and improving the quality of the power at or near customer sites. The value to the utility of providing voltage/var control. Small-scale generation in the distribution system can support voltage by injecting reactive power thereby improving power quality and lowering losses The value of increasing the elasticity of electric demand, which will tend to lower prices to the benefit of all consumers The value of reducing the Not in my back yard sentiment towards the siting of new power plants. Opposition to small scale on site facilities is likely to be less of an impediment to development of DG than of central stations. 8 Land Use Effects The value of reducing foot-print or space needed by generation, transmission and distribution infrastructure 9 Avoided T&D Capacity The financial value of avoiding or deferring a capital investment in transmission and distribution system capacity 10 System Losses The value of the energy saved through reduced resistive system losses. Energy is lost when it is transmitted through wires. The larger the distance, the more the losses are. Sitting small-scale generation close to load lowers losses 11 Combined Heat and The monetary savings from utilizing waste heat from the DG in Power/ Efficiency customer applications to meet heating or cooling needs, Improvement increasing overall efficiency of energy use 12 Consumer Control The value of allowing customers to control their energy source and avoid dependence on a large centrally controlled system 13 Lower Cost of Electricity The difference for a customer between the cost of purchasing electricity and the cost of generating electricity onsite 14 Consumer Electricity Price Protection 15 Reliability and Power Quality (DG Owner) The value for customer of having the ability to lock-in prices for their energy requirements for the long term The value to the customers with sensitive loads of avoiding outages and improving the quality of their power 16 Ancillary Services The value of providing spinning reserve, regulation, or other ancillary services. 52. The aforementioned benefits are derived from a distributed generation costs and benefits issue paper by Mark Rawson, public interest energy research California Energy Commission dated July 2004.
53. The City has attached a copy of its articles of incorporation which has been filed in both the Circuit Court of St. Francis County, Arkansas and with the Secretary of State of the State of Arkansas. APSC FILED Time: 11/12/2015 1:32:47 PM: Recvd 11/12/2015 1:32:05 PM: Docket 15-076-U-Doc. 4 54. The City has also attached the testimony of Calvin Murdock, General Manager of the Utility, Andrew Durham, professional engineer, and Roy McCann, electrical engineer and tenured professor at the University of Arkansas. 55. The City of Forrest City requests that this matter be approved by the board and requests any and all other relief for which it may be entitled. Respectfully Submitted City of Forrest City, Arkansas Andre K Valley Attorney for Forrest City Water Utility 423 Rightor Street, Suite #2 Helena-West Helena, AR 72342 (870) 338-6487 x 2 telephone (870) 338-8030 facsimile andrekvalley@gmail.com e-mail By: Andre K. Valley CERTIFICATE OF SERVICE I, Andre K Valley, do hereby certify that I have served a copy of the above and foregoing pleading upon all parties of record electronically, by first class mail or both on this the 10 th day of November, 2015. By: Andre K. Valley