WV PSC Case No 10 1824 E CS PC AES Laurel Mountain Waiver

8/8/2019 WV PSC Case No 10 1824 E CS PC AES Laurel Mountain Waiver

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JACKSON~QLLYTTORNEYS AT LAW PLLC5 0 EE STREET EAST SUITE 1600 PO. BOX 553 CHARLESTON. WEST VIRGINIA 2 5 3 2 2 TELEPHONE: 304-340-1 000 TELECOPIER: 304-340- I I30w.acksonkelly corn

E-Mail: snchambers(Li),iacksonkt.lly.comDIRECT TELEPHON E: (304) 340-1214 DIRECT TELECOPIER: (304) 340-1080

State Bar No. 694

VIA H A N D DELIVERYMs. San dra SquireExecutive SecretaryPublic Service Com mission of WVP. 0.Box 812Charleston, W V 25323

Re: CaseNo. 10- /8&/ -E-CS-PCAES L aurel M ountain, LLC, App lication forW aiver of Siting Certificate Mo dificationRequirem ents or, in the Alternative, for aModification to Siting Certificate and RelatedRequests for ReliefDear Ms. Sq uire:

Enclosed for filing are an unbound original and twelve bound copies of theApplication for Waiver of Siting Certificate Modification Requirements or, in the Alternative,for a Modification to Siting Certificate and Related Requests for Relief (Application), whichare hereby submitted for filing by AES Laurel Mountain, LLC (AES). Also enclosed is a CDcontaining copies of the docu men ts that com prise the Application, each in PD F format. A noticeof intent to make this filing was previously subm itted to the Com mission on October 13, 2010,and a cop y of that notice is included as Exhibit 7 to the Application.In the Application, AES outlines its proposal to install an energy storage device(ESD ) at the site of its certificated 125 M W Laurel Moun tain W ind Pow er Project (Project)that is currently under construction in Barbour and Randolph Cou nties, W est Virginia. As

explained in the Application, the ESD will not constitute a material modification to the Project.For that reason, AES requests that the Commission waive the requirement that it obtain amo dification or amend men t to the siting certificate issued for the Project. In the alternative, ifthe Com m ission should determine that a modification or amendm ent to the AE S siting certificateis nevertheless required, AES requests that the Commission grant such a modification oramendment and waive certain filing requirements under the Commissions Rules GoverningSiting Cer tijkate s o r Exempt Wholesale Generators (Siting Ru les).

(Cl912548 .IClluksburg, WV Mminsburg, WV Morgantown, WV Wheeling, WVDenver, CO Lexington. KY Piasburgh. PA Washington, DC
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Ms. Sandra SquireNovember 29,2010Page 2

Siting Rule 6.5 specifies that any application for modification or amendment of asiting certificate be accompanied by an application fee in an amount equal to the greater of$1,000 or one tenth of one percent (.001) of the projected capital cost of the proposedmodifications, w hich wou ld be $28 ,800 based o n the $28.8 million estimated cost of the ESD. Inlight of the fact that a filing fee in any amount will be required only if the Commissiondetermines that a waiver of the requirement to obtain a modification or amendment to the AESsiting certificate is unwarranted, a check payable to the Commission in the amount of theminimum filing fee of $1,000 is enclosed in a sealed envelope attached to the originalApplication. It is requested that the Com mission hold the check in escrow and deposit the checkonly if it does not grant AE Ss request for a w aiver of the requirement to obtain a modification oramen dm ent of its s iting certificate. In that event, AES will promptly submit the balance of anyadditional filing fee that may be required at that time.The substation of the Project is to be energized in April 2011 with commercialoperation in Jun e 201 1. Installation o f the Storage Device is expected to take approximately fourmo nths and therefore mus t begin no later than February 1, 201 1. Accordingly, A ES respectfullyrequests that the Com mission retain this case and grant it expedited consideration in accordancewith the Com missions applicable procedures. IPlease file the original enclosed Application and the sealed envelope containingthe application fee and distribute the enclosed twelve copies of the Application to the appropriate

parties at the Commission. We also ask that you date stamp the additional copies provided andreturn them with our messenger. As always, we appreciate your cooperation and assistance.Sincerely,

SNCIdmbEnclosurescc: Barry Sw eitzerPiers Lewis

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PUBLIC SERVICE COMM ISSIONOF W EST VIRGINIACHARLESTON

CASE NO. 10- -E-CS - pcApplication of AES Laurel Mountain, LLC forW aiver of siting certificate mod ification requirementsor, in the alternative, for a siting certificate modificationfor the installation of an energy storage dev ice at the siteof the L aurel Mountain Wind P ower Project and relatedreques ts for relief.

APPLICATION FOR WAIVER O F SITING CERTIFICATE MOD IFICATIONREQU IREMENT S OR, IN THE ALT ERNATIVE, FOR A MODIFICATIONTO SITING CERTIFICATE AND RELATED REQUESTS FOR RELIEF

AES Laurel Mountain, LLC (AES), by counsel, respectfully requests that theCom mission waive any requirement that AES ob tiin a mod ification or amendmen t to its existingsiting certificate (Certificate) in connection with the planned installation of an energy storagedevice (ESD) at its 125 Megawatt (MW) Laurel Mountain Wind Power Project (Project)that is currently under construction in Barbour and Randolph Counties, West Virginia. AESrepresents that the ESD will not constitute a material modification to the Projec t in that it will notalter the design, change the footprint, or increase the transmission or generation of the Project,nor w ill it materially affect the viewshed impacts, sound levels, emissions o r other environmentalimpacts of the Project. In the alternative, if the Com mission determines that a modification oramendment to AESs Certificate is required, AES requests that the Commission grant thenecessary modification or amendment at its first opportunity and waive certain filingrequirements under the Commissions Siting Rules as requested in Exhibit 6hereto. AES alsorequests that the Commission retain this Application for decision, and accord it expedited

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consideration in accordance w ith the Com missions applicable procedures. In support of theserequests for relief, AES states as follows:1. Introduction

1. The name and address of the applicant, and the name, address, telephone number,fax num ber and e-mail address of a responsible official of the applicant are as follows:

AES, Laurel Mountain, L LC4300 W ilson BoulevardArlington, Virginia 22203Responsible official:Barry Sweitzer86 Baltimore, StreetSuite 300Cumberland, M aryland 2 1502Telephone: (301) 777-97 54Fax: (301) 777-9756E-mail: [email protected]

2. The names, mailing address, e-mail addresses and telephone and fax numbers ofthe attorneys for AES are:

3.

Christopher L. Callas, Esq. (W VS B No. 5991)Stephen N. Chambers, Esq. (WVSB No. 694)Jackson Kelly PLL C1600 Laidley Tow erP.O. Box 553Charleston, WV 2532 2(304) 340-1000 (office)(304) 340-1080 (facsimile)[email protected]@jacksonkelly.comBy Com mission Order entered on November 26, 2008, in Case No. 08-0109-E-CS

(Certificate Case), the Commission granted AES the Certificate for the construction andoperation of the Project, T he Project involves the construction of a $250 million, 125 MW windturbine wholesale electric generating facility consisting of up to 65 wind turbines situated on an

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mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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eight-mile stretch of the Laurel Moun tain ridgeline lying about three m iles east of Belington inBarbour County and three miles northwest of Elkins in Randolph County. Th e Project iscurrently under construction, with Project roads and civil work nearing completion and windturbines scheduled for installation beginning late this year and continuing through the secondquarter of 20 1 1.comm ercial operation to comm ence in June 201 1.

The Project substation is scheduled to be energized in A pril 201 1, with

4. The Project is bisected by an existing Allegheny Power 138 kilovolt overheadtransmission line that crosses Laurel Mountain at about the midpoint in the string of wind

turbines. An approved interconnection substation is being constructed at the point where theAllegheny transmission line crosses the Project to permit the energy generated by the Project toenter the transmission grid. Subject to the Com missions determinations in this proceeding, AESintends to construct the ESD on a fenced-in parcel of land either directly adjacent to theinterconnection substation or in close proximity thereto and will connect the ESD to theAllegheny transmission line through the Project switchyard. An aerial photograph of the site of

I

Ithe interco nnection substation sho win g the locc!tion of the substation and th e approxim atelocation of the ESD is attached as Exhibit 1 . 11. Description of the ESD

5 . The ESD will have a combined nominal output of 32 M W , comprised of eight 4M W modules consisting of lithium-ion batteries, inverters, transformers and cooling systems.The lithium-ion batteries used in the ESD are about the size of a standard D cell flashlightbattery and are the sam e kind of batteries used w orldw ide in a variety of applications, includingcordless power tools and battery powered or hybrid vehicles. Th e batteries are grouped intobattery packs or m odules that are loaded into trays and the trays are m ounted in floor-to-ceiling

I

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racks inside a standard shipping container (53 ong, 8 wide and 9-1/2 tall). Photographs ofbatteries, a battery pack and tray, racks and a ship ping container similar to what w ill be installedat the Project site are attached hereto a s Exhibit 2. Each 4 MW modu le includes:

two standard sh ipping containers housing the battery packs;a single 20 long sh ipping container that houses bidirectional inverters to convertpower betw een direct cu rrent and alternating current;a chiller to cool the battery con tainers; and

a transformer to chang e the alternating current for the inverter.A diagram sho wing a typical side-by-side layout of two 4 MW modu les is attached as Exhibit 3. In addition, there will be a small control house, main transformer, and row of switchgear.Photographs of an existing AES ESD installation in C hile are attached as Exhibits 4-1 and 4-2.Exhibit 4-1 is an aerial photograph sh ow ing the containerized storage modules in a sing le row tothe left and an adjacent substation on the right. Exhibit 4-2 consists of two ground-levelphotographs. One photograph sh ow s a row of shipping containers in which batteries are housed,with a chiller unit in the foreground. This photograph, as well as Exhibit 4-1 also show s whatresembles a sidewalk extend ing alon g the row of battery containers. Th is is actually the surfa ceof an underground raceway that carries power cables to the main pow er transformer. Th e otherphotograph in Exhibit 4-2 shows, in the foreground, an isolation transformer, and in thebackground, a chiller unit (evaporator and fan).

6 . Installation of th e ESD is expected to take app roximately four mon ths and AES isseeking expedited review in this proceeding to enable construction to start by February 1, 20 1 1 ,thereby permitting the ESD to com e online at the sam e time that the Project is put into service.The construction process will involve minimal initial site work due to the location of the ESD

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adjacent to the site of the Project substation which is already under construction. Onc e the site isprepared, foundations for the shipping containers and concrete pads for other components of theESD will be installed and the shipping containers and other components will then be trucked inand offloaded onto the foundations. Conduits and wiring (mostly at grade or underground) willbe installed to connect the various components of the ESD and the ESD will be connected to th esubstation via underground cables. Th e site will be enclosed by security fencing, with lockedgates. Security lighting and cameras will be installed. Fire suppression systems will be includedin each of the battery storage containers and secondary containment will be installed for the oil-tilled m ain power transforme r to protect against an unexpected release of oil.

7 . The purpose of the ESD is twofold: to regulate the ramp rate of the Project andto provide autom atic generation control (AGC ). T he Project will gain the capability to regulateits own ramp rate, controlling the rate at which power output from the Project to the gridchanges. Additionally, the AGC capability will enable the Project to provide the ancillaryservice of Regulation by increasing or decreasing its power output. Regulation is suppliedprimarily by dispatchable generators with A GC capability, but m ay also b e offered by flexibleloads or energy storage devices. Regu lation helps PJM Interconnec tion, L.L.C. (PJM), the gridoperator, to match generation levels with short-term changes in electricity use in order tomaintain stable grid frequency at 60.0 Hz. Th e resources selected to provide Regu lation in eachhour earn a payment based o n the amount of flexible capacity being provided. Th e market-basedpayment to each resource, known as the regulation market clearing price, is determined hourlyby PJM based on the set of resources offering and clearing in the market. Th e Project will earnrevenue through its participation in the PJM Regu lation market. Th e Projects participation in

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this market is authorized under the Projects authorization by FERC to make sales at market-based rates.

8. PJM has concluded an Interconnection Feasibility Study for the ESD, a copy ofwhich is attached as Exhibit 6-1,and is in the process of performing a System Impact Study,which is expected to be completed in the first calendar quarter of 201 1 . Given that no facilitiesissues were noted in the feasibility study, it is reasonable to expect that PJM will determine thatno facilities study will be required after the System Impact Study is completed. Followingcompletion of the System Impact Study, AES and PJM will revise the Project InterconnectionServices Ag reemen t as necessary. Th e Interconnection Services Agreemen t is expected to beexecuted early in the second q uarter of 201 1 .

9. The estimated cost of the ESD is $28.8 million, w hich will be h n d e d entirely byAES.111. Immaterial Impa ct of ESD

10. Th e impact o f the ESD o n the Project is not material. Specifically:(a ) The ESD does not change the engineering design plans or generating

capacity of th e Project.No additional property is required for the ESD, which will fall within theexisting footprint of the Project. Th e ESD will occupy approximately 1.25acres of land owned by AES directly adjacent or in close proximity to theProject substation and within the limits of disturbance established for thesubstation. On ly mino r changes or additions to roads constructed for theProject will be necessary for access to the ESD site. Du e to the short

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IV.

Nothing in the size, composition, location, operation or nature of the ESDsuggests that it will have any adverse impact on the environment, anyprotected or endangered species, or any architectural or archaeologicalresources in the area of the Project. No additional environmental permitsare required either for the ESD or for the Project as a result of the ESD .AES intends to use local electrical and mechanical contractors for theinstallation of the ESD, ma y of whom are expected to be drawn tiom the7local area.

Waiver Warranted Under Circumstances1 1 . Considering the totality of circum s ances, the installation and operation of the

ESD should not be considered a material mo dification to the Project. Installation of the ESDwill not alter the design, chan ge the footprint, or increase the transmission or generation of theProjcct, nor will i t materially affect the existing viewshed, sound levels, emissions or otherenvironm ental impacts of the Project. In that regard, the relative imp act of the ESD on theProject is quite similar to the impact that a so-called black start generator installed by BigSandy Peaker Plant, LLC at its Wayne County, West Virginia gas-fired generating plant wasfound to have on that facility. In Case No. 06-1912 -E-CS -PW , Bin Sandy Peaker Plant, LLC,the Commission concluded that the construction of the generator was not material because itwould neither modify the footprint of Big Sandys generation facility, nor increase thetransmission or generation of the facility, nor require any modification to the facility with apotential environmental im pact. Th e Comm ission further found that the generator would notmaterially affect the viewshed impacts, noise levels, emissions or other environmental impacts of

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the Big Sand y power plant. Similarly, in Case No. 05-1467-E-C N, Longview Power, LLC, theCom miss ion found that a proposed increase in the g enerating capacity of a coal-fired plant from600 M W to 695 MW was not a material modification to Longview Powers siting certificate,subject to a num ber of con ditions, including that there be n o ch ange in the footprint or layout ofthe facility, the switchyard or transmission line, and stack height, as well as no need foradditional environmental permits or modifications to existing permits and subject to continuedcompliance with operational noise levels set forth in Lon gviews siting certificate.2 Again, thefactors considered by the Com mission in Lo ngview, when applied to the facts of this application,

clearly support the issuance of a waiver of the requirement that AES obtain a modification oramend ment to its siting certificate.V. Request for A lternative Relief

12. If the C om miss ion should determine that the installation of an ESD requires AESto obtain a modification or amendment to the Certificate, AES requests that the Commissiongrant the modification or amendm ent for the reasAns set forth abo ve and in the attached Exhibit

I

6 . I13. Attached as Exhibit 5hereto is an qpplication for Modification to or Amendment

of a Siting Certificate in the form of Form No. 3 attached to the Com missions Rules GoverningSiting; Certificates For Exem pt W holesale Generators (1 50CSR30) (Siting Rules). Alsoattached as Exhibit 6 is a table setting forth (i) the filing requirements of Siting Rules 3.1.a.through 3.l.p. and (ii) either the corresponding required information, a notation that theparticular information is not ap plicable under the circumstances, or a request for a waiver of therequirement for the reasons indicated.

Case No. 06-1912-E-CS-PW, Big Sandy Peaker Plant, LLC (Commission Order entered on January 30,2007) Case No. 05- 1467-E-CN, Longview Power. LLC (Commission Order entered on February 16,2007).

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VI. Pre-Filing and N otice Requirements14. Siting Rules 2.1 and 2.2 require that the Com mission be given at east 30 days

advance notice of an intended application for a siting certificate and that, upon filing of th eapplication, a notice of the filing on Form No. 2 be published. How ever, Siting Rules 6.1through 6.5 con cernin g modification or amen dmen ts to previously-issued siting certificates donot contain any pre- or post-filing notice or publication requirements. Nevertheless, on October13, 2010, C ounsel for AE S filed a letter with the Com mission advising it of the intent of AES tofile this application. A cop y of this letter is attached hereto as Exhibit 7. In addition, AES

representatives and counsel previously met with the Commission Staff to describe the ESD andthe filing o f this application.VII. App lication Fee

15. Siting Rule 6.5 specifies that any application for modification or amendment of asiting certificate be accompanied by an application fee in an amount equal to the greater of$1,000 or one tenth of one percent (.001) of the projected capital cost of the proposedmodifications ($28,800 in this case). In light of the alternative relief requested h erein, a checkpayable to the Com mission in the amount of $ 1,000 in payment of the minimum application feeis being submitted with the filing of this application. It is requested that the Com mission holdthe check in escrow and depo sit the check only if it does not grant AE Ss request for a waiver ofthe requirement to obtain a modification or amen dme nt of its siting certificate.

WHEREFORE, AES prays that the Commission (i) waive any requirement to obtain amodification or amendment to its Certificate to install and operate the ESD; and (ii) hold inescrow the application fee for the reasons identified in paragraph 15 above. In the alternative,AES prays that the Commission (i) grant the waivers of certain filing requirements as specified

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in Exhibit 6hereto; and (ii) grant a modification or amendment to the Certificate to permit theinstallation and operation of the ESD at the Project. In either case, AES requests that theCommission grant such other an d further relief as it may deem appropriate and that it retain thisapplication and accord it expedited consideration in accordance with the Commissionsapplicable procedures.

Respectfully submitted this 2 gthday of Novem ber, 2010.

AES LAUREL MOUNTAIN, LLC

By CounselI

JACKSON KELLY PLLCP. 0. Box 553Charleston, W V 25322Counsel for AES Laurel Mountain, LLC(304) 340-1000

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VERIFICATION

STATE OF MARYLAND,COUNTY OF ALLEGANY, To-Wit:

Ba ny Sweitzer, Vice President of AE S Laurel Mountain, L LC, being duly sworn,says that the facts and allegations contained in the foregoing Application are true, except so faras they are therein stated to be on information, and that, so far as they are therein stated to be oninformation, he believes them to be true.

KRISTEN MABEENotary PublicAllegany CountyMaryland

Taken, sw orn to, and subscribed before m e this is day of November, 2010.My commission expires Q - L . 2 7 , or.

[C1909592.1)

' Notary Public


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Index of Exhibits

Exhibit IExhibit 2Exhibit 3Exhibits 4-1 and 4- 2Exhibit 5

Exhibit 6

Exhibit 6- 1Exhibit 6-2Exhibit 6-3Exhibit7

Aerial Photograph of Site of Interconnection Substation and ES DPhotograph s of B atteries and Battery Con tainersDiagram o f Layout of Two 4 MW ModulesPhotograph s of AES ESD Installation in ChileForm No. 3 -- Application for Modification to or Am endment of a SitingCertificateTab le of Material Modification Siting Requirements and Respo nsiveInformation or Requests for WaiverPJM Feasibility Study ReportGantt Chart of ESD Project Schedu leResults of ESD Noise AnalysisCopy of Pre-Filing Letter Dated Novem ber 22, 20 06

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Exhibit 1

The Energy Storage Device would be located onjust over one acre of land next to the substation

4

@AESthepowerof beingglobal

Approximate Location ofEnergy Storage Device

e Project Substation

I0 010The AES Corporation, All rights reserved.


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Exhibit 2I--atteries on the Grid

Cells

Racks

Modules

w@AES

Trays

Q 2010 The AES Corporation, All rights reserved.


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Exhibit 3

4 MW Modile LayoutTwo Modules Shown Side by Side8 total for 32 MW Device

3'-0 BATTERYl p f ONTAINERD I S T R I B U T I O N \POWER PANF'

I 5 U L A T I ONTRANSFDR MER 1rl'BATTERYCONTAINER

FENCE -


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I l l l l

Exhibit4-1

12 M W Los Andes, Chile(in operation)

T


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Exhibit 4-2


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Exhibit 5[FormNo. 3)

STATE O F WEST VIRGINIAPUBLIC SERVICE COMMISSIONCHARLESTON

CASE NO. 10- -E-CSApplication o f AE S Laurel Mountain, LLC formodification to or amendm ent of an existingelectric generating facility siting certificate inthe counties of Barbour and R andolph

APPLICATION FOR MODIFICATION TOOR AMENDMENT OF A SITING CERTIFICATE

Comes now the above-named AES Laurel Mountain, LLC, the applicant herein,by counsel, and respectfully shows the Com mission as follows:I1. That the name and address of the applicant is AE S L aurel Mountain, L LC,43 00 W ilson Boulevard, Arlington, Virginia 22203.2. Th at the applicant proposes to install an energy storage device (ESD ) atits 125 MW Laurel Mountain Wind Power Project (Project) that is currently under

construction in Barbour and Randolph Counties, West Virginia. See generally the Applicationfor Waiver of Siting Certificate Modification Requirements or, In the Alternative, for aM odification to Siting Certificate and Related Requ ests for Re lie f to which this Form No. 3 isattached as Exhibit 5 (Application). I3. Upo n information and belief, a copy of the Certificate of Authority issuedby the West Virginia Secretary of State on January 15, 2008, authorizing the applicant to dobusiness in West Virginia was previously filed with the Commission as part of Case No. 08-0109-E-CS. The applicant remains in good standing and authorized to do business in WestVirginia and requests that the Commission waive any requirement to submit any additionalcopies of its Certificate of Authority in this proceeding.4. Com mission approval of the requested modification or amend men t shouldbe granted for the reasons set forth in the Application.Dated this 29thday of November, 201 0.

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AES LAUREL MOUNTAIN, LLCBy Counsel

Stephen N. hambers (State Bar ID 694)JACKSON KELLY PLLCP. 0.Box 553Charleston, WV 25322Counsel for AES Laurel Mountain, LLC(304) 340-1000

[Verification Included With Application]


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Exhibit6

Applicability of, Compliance With orRequest for Waiver of Filing Requirements

of Siting Rules 3.1.a Through 3.1.p.(Capitalized terms have meanings ascribed to them in the Application)

$150-30-3.Application3.1 a File a Project summary/facility overview to include:

1, A general purpose statement;

2. Reasons for selection of the proposed site including the principalenvironmental and socio-economic considerations of the proposed si te;

3. A description of the proposed facility;

The purpose of the ESD is to regulate the ramp rateof the Project and to supply ancillary services to thewholesale energy market.Not applicable. The ESD will be located on the siteof the Project constructed and operated pursuant tothe prior authorization of the Commission grantedin the Certificate Case.The ESD will have a combined nominal output of32 M W , comprised of eight 4 MW modulesconsisting of lithium-ion batteries, inverters,transformers and cooling systems. Each 4 MWmodule consists of two standard shipping containershousing battery packs, a single 20 long shippingcontainer housing inverters, a chiller to cool thebattery containers, and a transformer to change thealternating current for the inverter. In addition therewill be a small control house, main transformer, androw of switchgear. The ESD will be located onapproximately 1.25 acres of property adjacent to the

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Exhibit 6

~~4. A list of all required government (state, local,- federal) approvalsand/or permits for the facility, and the filing status of each;

5. A description of any court litigation formally noticed involvingthe project and copies of all relevant pleadings and court orders in suchproceedings; and

Project interconnection substation that is locatedwhere the Project is intersected by a 138 kVAllegheny Power transmission line.Based, in part, on consultation with personnel of theWest Virginia Department of EnvironmentalProtection, the applicant does not believe that anyfurther permits or permit modifications are required.By Order of the West Virginia Supreme Court ofAppeals (Court) entered on June 3, 2009, theCourt refused the Petition of Appeal by LaurelMountain Preservation Association, Inc. (LMPA)of the final order of the Commission in theCertificate Case granting AES a siting certificate forthe Project.On July 6, 2010, LMPA filed an Application toreopen the Certificate Case. On the same date, aNotice of Violations (NOV) of the EndangeredSpecies Act (Act) was filed with the Commissionin the Certificate Case by a group of individuals andentities (NOV Filers). At the conclusion of theNOV, counsel for the NOV Filers asserted that ifcertain requested actions were not taken, the NOVFilers would consider all available avenues,including litigation to protect certain species ofbats pursuant to the Act.To the best of the knowledge of AES as of the dateof the filing of this Application, (i) the Applicationto reopen the Certificate Case has yet to be decidedby the Commission and (ii) AES has not beenserved with, or provided with any formal orinformal notification of, the filing of any court

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Exhibit6

3.1 b

3.l.c

6. An explanation of the project schedule.

A statement explaining the need for the facility with references to anyavailable long term electric supply and demand projections, and anyother rationale for building the facility.

Facility Description.1. Where applicable, for each generationunit,describe thetype o f

unit, estimated net demonstrated capability, heat rate, expected annualcapacity factor and expected hours of annual generation for each yearof the first five years of operation.

2. Provide total facility land area requirement.

litigation pertaining to the Project or the ESD.

Installation of the ESD is expected to begin on 01about February 1, 2011, and be concluded in timefor the ESD to be operational in June, 2011Waiver requested. The need for the Project wasestablished in the Certificate Case. The need for theESD is explained in paragraph 7 of the Applicationand is also set forth above in response to Rule3.1.a. 1.

Gencrally No t Applicable. See response to 3.1 .a.3above.

The ESD will occupy approximately 1.25 acres 01land owned by AES and entirely within thefootprintof the Project.

3. Where applicable, provide fuelquantity. Indicate the maximumamount of fuel expected to be consumed in one hour and the expectedamount of fuel consumed per year.

4. Provide fuel quality. Indicate expected fuel characteristics such asash, sulfur and btu value.

5. Fuel Transportation. Indicate the expected mode of fueltransportation. List the location(s) of the expected fuel source(s).Indicate the expected route(s) fi-om the fuel source(s) to the plant .

Not Applicable.

Not Applicable.

Not Applicable.

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Exhibit6

6. Fuel Storage. Indicate how much, if any, fuel will be stored onand off site. Discuss the details of such storage arrangements includingthe expected number of days of fuel to be stored.

7. Provide a list of expected air andwater emissions and,for each-emission, the name of the federal and/or state regulatory authority fromwhich a permit must be obtained, or, a statement that no permits fromother federal and/or state regulatory authorities are required for thatemission. If permits from other authorities are not required, state theexpected impact of such emissions.

8. Explain water requirement, source of water, treatment, quantityof any discharge and names of receiving streams.

9. Provide a summary description of other major equipment,including any significant safety equipment, e.g., fire fightingequipment.

Not Applicable.

Not Applicable.

Not Applicable.

All of the significant equipment is described in3.1.a.3 above and in paragraph 5 of the Application.Each shipping container will be equipped with a firesuppression unit.

3.1.d Submit all interconnection studies necessary for facility. The PJM Feasibility Study Report for the ESD isattached as Exhibit 6-1. A System Impact Study iscurrently being conducted and is expected to becompleted in the first calendar quarter of 2011.When it i s available, the System Impact Study willbe submitted to the Commission. Given that nofacilities issues were noted in the feasibility study, itisanticipated that no facilities study will be requiredby PJM following completion of the System ImpactStudy. However, if a facilities study is required, itwill be promptly submitted to the Commissionwhen available.

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Exhibit6

Provide proposed project schedule in a Gantt Chart, including thecritical path and covering all applicable major activities and milestones,including:

1. Acquisition of land and/or land rights;2. Submittal of the application and receipt of a Public Service

Commission Siting certificate;

3. Submittal and receipt of all required approvals andor permitsfrom other governmental (state, local, federal) agencies (See Rule5.l.a.). Include a statement of the current status of such submissionsand receipts including copies of any correspondence from agenciesaddressing the status of such applications or permits;

4. Preparation of the final design;5 . Constructionof the facility; and

6. Placementof he facility in service.Describe the impact of delays on the eventual in-service date.

Technical data:

3.1.e See attached Exhibit5-2.

Not applicable. ESD to be located on site of theProject.Application filed on November 29, 2010. Waiver,or modification to or amendment of sitingcertificate, requested in time to permit installation tobegin on or about FebruaIy 1,2011.See response to 3.1.a.4.

Final design of ESD expected to be Completed priorto the end of2010.Installation of ESD expected to begin on or aboutFebruary I , 2011, and be completed on or aboutJune 1,201 1.ESD expected to be put in service on or about June,2011.Delays in putting the ESD in service will deprivethe grid operated by PJM and the generatingfacilities connected thereto of the benefits of thefrequency regulation capabilities of the ESD.

3.1.f

1. Site. Information on the location, major features, and thetopographic, geologic, and hydrological suitability of he selected site.

3.1 gNot applicablelwaiver requested. The ESD is tobe located on the site of the Project. Installation ofthe ESD will have no geologic or hydrologicalimpact on the site.

{C1905369.2} 5


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Exhibit6

2. An aerial photograph for a one-mile radius from the facility.3. Design and construction. Provide plan and elevation view

engineering drawings based on information on the proposed layout onthe most current engineering design plans for the facility, depicting themajor structures and installations.~~4. Site activities. Describe the proposed site preparation and

reclamation operations, including: test boring; removal of vegetation;grading and drainage provisions; access roads; removal and disposal ofdebris; and post-construction reclamation.

5. Plans for construction. Describe the proposed constructionsequence based on engineering design plans filed pursuant to thissection.

6. Structures. Describe all major proposed structures, includingestimated overall dimensions; construction materials; color and textureof facing surfaces; any unusual features; transmission towers; andsecurity facilities.

Not applicable/waiver requested. The ESD is tobe located on the site of the Project.Interim waiver requested. The final siting anddesign of the ESD are in progress and engineeringdrawings are expected to be available by the end of2010 and will be filed with the Commission whenavailable.Only minimal site preparation will be required asthe ESD is being located in close proximity to theProjects interconnection substation on land that isbeing cleared and graded for or in connection withthe substation.See Exhibit 6-2.

7. Future glans. Statement whether applicant intends to be the entity

The ESD will be comprised of eight 4 MW modulesconsisting of lithium-ion batteries, inverters,transformers and cooling systems. Each 4 M Wmodule includes: (i) two standard 53 long shippingcontainers housing the battery packs; (ii) a single20 long shipping container that houses inverters tochange the battery power from direct current toalternating current; (iii) a chiller to cool the batterycontainers; and (iv) a transformer to change thealternating current for the inverter. In addition therewill be a small control house, main transformer, androw of switchgear. The shipping containers andcontrol houses are prefabricated metal structures.These structures will contain fire suppressionsystems and will be enclosed by a locked securityfence and protected by security cameras.[t is currentlv the intent of AE S to be the entitv that

(C1905369.2) 6


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Exhibit6 ,

5.l.h

i.1.i

3.1.j

that will own and operate the facility into the future and a descriptionofany plans for future additions of generating units for the site , includingthe type and timing; and the maximum generating capacity anticipatedfor the site. The applicant shall describe post useful life demolition,removal, disposal, and restoration plans for facilities.

8. Equipment.A. Description of proposed major generating equipment.B. Emission control and safety equipment. Description of allproposed major flue gas emission control equipment, includingtabulations of expected efficiency, power consumption, and operatingcosts for supplies and maintenance; the reliability of the equipment andthe reduction in efficiency for partial failure; the equipment proposedfor control of effluents discharged into water bodies and receivingstreams; and all proposed major public safety equipment.C. Description of any other major equipment not discussedabove.Maps.

1. 5-mile radius Map.2.24-2 -l(c) generating facility Pre-construction map.3. 1-Mile Radius Proposed 24-2-1 c) generating facility Map.

[mpact. Identify and describe the impact of the facility on any publicutilities, including but not limited to water utilities, sewer utilities,5lectric utilities, commercial solid waste facilities, natural gas utilities,md telephone utilities. The applicant shall further identifl and describethe impact of the facility on other generating facilities whether or notutility-owned.Rendering of project.

will own and operate the ESD into the future. Noadditional storage capacity is currently anticipatedfor this site. Post useful life demolition, removal,disposal and restoration plans for the ESD have notbeen developed. However, removal and disposal ofthe self-contained ESD components would not bedifficult and would not require any significantdisturbance o the remainder of the site.See response to 3.1.g.6 above and paragraphs 5 and7 of the Application.

Not appIicable/waiver requested. The ESD willbe located on the site of the Project and will notresult in any additional material impact onproperties or persons in the area.The ESD will have no impact on existing publicotilities or solid waste facilities. The ESD will have2 positive impact on the electric grid operated byP J M Interconnection and the generating facilitiesconnected thereto that will benefit from thefrequency regulation capabilities of the ESD.Waiver requested. The ESD will be located

{C 1905369.2)


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Exhibit6

3.1.k

1. The applicant shall provide still renderings from all scenicoverlooks and project views that will be most evident to the public, andwhich are accessible to the applicant, from which the 24-2-1(c)generating facility will be visible after construction.

Still renderings which show structures at ground level shallinclude a scaled 6 foot tall figure in near proximity to such structures toallow the viewer to clearly see the scale of the project structures.Hydrology and wind.

Provide the natural and the man-affected water budgets,including the ten-year mean and critical (lowest seven-day flow in tenyears) surface flows and the mean and extreme water tables during thepast ten years, to the extent records exist, for each surface water bodyand sub-surface water sources, likely to be directly affected by theproposed facility;

2.

1.

2. Provide an analysis of the prospects of floods and high windsfor the area, including the probability of occurrences and likelyconsequences of various flood stages and wind velocities, and describeplans to mitigate any likely adverse consequences;

adjacent to the site of the interconnection substationfor the Project. Due to the relatively small size ofthe ESD and its low profile (12-15 in overallheight) in comparison to the wind turbines and thesubstation, it will not have any material impact onProject views.

Waiver requested. The ESD will be located on thesite of the Project and will have no additionalimpact on hydrological resources.

Waiver requested. The ESD will be located on thesite of the Project and will have no additionalimpact on hydrological resources.

3.1.1

3. Provide existing maps of aquifers which may be directlyaffected by the proposed facility; and

4. A study of how the project and the water use identified in Rule3.1 c.8. will affect the identified water sources.

Financial and Economic data.1. Debt and Equity Capital.

A. Estimates of the amounts of debt and equity capital for theproject. These estimates shall include all capital that will support theconstruction of the project and all permanent sources of capital, if

Waiver requ este d.The ESD will belocated on thesite of the Project and will have no additionalimpact on hydrological resources.Waiver requested. The ESD will be located on thesite of the Project and will have no additionalimpact on hydrological resources.

AES will pay the entire estimated $28.8 million costof the acquisition and installation of the ESD and noseparate financing (public or private) will berequired. No construction or bridge financing is

{Cl905369.2} 8


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Exhibit6

different than construction financing. Any temporary, interim or bridgefinancing, whether related to the construction phase of the project orotherwise, must be fully disclosed.B. Describe any agreements with public entities and whethersuch agreements would transfer to a future purchaser(s) of the facility.C . If the project will have any funding from public sources,either initially or in the future, the amount and terms for such fundingmust be fully disclosed. Such disclosure shall include a listing of eachsource of public funding, a description of the public funding and a copyof the written agreement(s) setting forth the terms and conditions forthe public funding. The disclosure shall include reasonable estimates ofthe amount of taxes the applicant would pay if, hypothetically, theapplicant constructed and operated the facility without the benefit ofany agreements abating taxes.

2. Pro forma financial statements. Provide pro forma financialstatements pal an ce Sheet, Funds Statement and Income Statement) foreach year of the start-up phase (project development and construction)and for the first five years of operation of the proposed project. Thefinancial statements must disclose all assumptions.

anticipated.

Waiver requested. The ESD will not have anyadverse affect on the financial or operationalcapabilities of either AE S or its operation of theProject. ~~

3. Local and State Economic Impact. Provide estimates of theeffect of the project on the local and state economy as well as the modelused to derive the estimates. Such estimates shall cover the constructionphase of the project and he ongoing impacts after construction. Suchestimates shall include but not be limited to: (i) the impact on localemployment (including the number of added man-hours, jobs andexpected payroll value of added jobs), both directly and indirectlyrelated to the project; (ii) the impact on all local and state taxes(including gross tax amounts and net amounts if any abatementagreements apply), both directly and indirectly related to the project;(iii) the impact on local commercial business activity including

Waiver requestedfor the detailed economic impactinformation set forth in this rule. Although notformally evaluated and quantified, AESsinvestment in construction and operation of the ESDis expected to have a positive economic impact onthe state and local economy similar in nature, androughly proportional in amount, to the positiveeconomic impacts associated with AES sinvestment in the Project itself.

{C 1905369.2) 9


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Exhibit6

3.1.m

tourism; (iv) the impact on area property values; (v) the impact onexisting infiastructure; (vi) the impact on per capita income in the localarea and the region; and (vii) the impact of lost opportunity(ies) as toalternative use(s) of the land upon which the facility is proposed to bebuilt.

4. Regional development impact. The applicant shall describe theimpact of the proposed facility on regional development.

Environmental data.1. Species.

2. Species - Wind powered electric generation facilities only.

3. View.

4. Noise.A. Preconstruction. Provide a noise exposure map of the noise

present prior to construction. Said map will contain contour lines ofequal noise at and up to one mile fiom the facilitys property line.[Details for base line study found in PSC Rules.] The map shall showall exist ing structures within one mile of the facilitys property line andshall indicate whether such structure is residential, commercial orindustrial. Current land uses shall also be designated.

Construction. Provide (with Application filing) a predictivenoise study as to construction noise which shall address: (i) Dynamitingactivities; (ii) Operation of earth moving equipment; (iii) Driving ofpiles; (iv) Erection of structures; (v) Truck or other traffic;Installation of equipment. [Details for predictive noise study found in

B.

(vi)

The ESD will not have any measurable impact onregional development that is separate and apart fiomthe impact of the Project.

Waiver requested. The ESD will not add to orchange the impact, if any, of the Project on anyspecies.Waiver requested. The ESD will not add to orchange the impact, if any, of the Project on anyspecies.Waiver requested. The ESD will not cause anymaterial change in the existing view of the site. SeeApplication at paragraph lO(c).Waiver requested.A. The site of the ESD is within the footprint of theProject; therefore, there is no change to the noiseexposure map submitted in the Certificate Case.B. Construction noise will be no greater than thenoise associated with construction of theinterconnection substation.C. An analysis of sounds associated with thecomponents of the ESD has determined that theESD will have negligible effects on total Projectsound levels. with increases in total modeled Ldn

(C1905369.2) 10


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Exhibit6

3.1 n

PSC Rules.]C . Operation. Provide (with Application filing) a noise exposuremap of the noise expected to be present during operation. Said map willcontain contour lines of equal noise at and up to one mile from thefacilitys property line. [Details for noise exposure map found in PSCRules.]

5. TrafficA. Preconstruction. Describe existing pre-construction traffic nearthe site to provide baseline traffic calculations.B. Construction. Describe the traffic levels expected on roadsnearest the property boundary, any increased traffic expected within a1-mile radius of the proposed facility, any increased traffic levelsexpected within a 5-mile radius of the proposed facility, and any plansto mitigate the impact of increased traffic with respect to trafficsensitive areas within a 5-mile radius of the proposed facility duringconstruction.

C. Operation.

Land Uses. In the application, estimate the impact of the proposedfacility on the land uses depicted on the map required in Rule 3.1.h.l.,identify stmctures that will be removed or relocated, describe formallyadopted plans for future use of the site and surrounding lands foranything other than the proposed facility, and describe plans forconcurrent or secondary uses of the site.

sound levels at the closest residences being less than0.5 decibel. The projected sound impact of the ESDwas modeled under a worst case scenario with boththe wind turbines and the ESD operating at full loadconditions, with all chillers and isolationtransformers running and the main transformer plusthe substation transformer running under secondstage auxiliary cooling. The results of the analysisare summarized on the attached Exhibit 6-3.

Waiver requested. The impact on local traffic willbe minimal during the short installation period.Following installation, there will be no impact onlocal traffic.

Waiver requested. The ESD will have no impacton the existing or foreseeable future uses of the siteor surrounding property.

(C1905369.2)1 1


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Exhibit6

3.1.0

3.l.p

Cultural impact.1. Landmarks.2. Recreation areas.

Public responsibility. Describe any program for public interactionplanned for the siting, construction, and operation of the proposedfacility, i.e., public information programs; and describe any insuranceor other corporate programs for providing liability compensation fordamages to the public resulting from construction or operation of theproposed facility.

Waiver requested. Installation of the ESDwill notchange the cultural impact, if any, of the Project.

Waiver requested. In light of the exceedinglyminor impact of the ESD in relation to the Project,no program for public interaction is proposed. AESmaintains adequate policies of insurance and losscontrol programs to sufficiently protect the publicagainst the risk of any damage to property or personarising from the installation or operation of theESD.

{C 1905369.2) 12


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Exhibit 6- 1

Generation InterconnectionFeasibiiity Study Report

ForPJM Generution InterconnectionRequest

QueuePosition W2-057

LaurelMountuin Project

D PI M Interconnection2010. ll rightsreserved.

PJM DOCS No. 6 1 7 8 8 0 ~ 1October, 2010


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Overview

Exhibit6-1

Interconnection Customer (IC), AES Lauren Mountain, LLC, has submitted an Attachment N topropose the interconnection of 32 MW ofba ttery storage on a tract of land at the site of the PJMQueue number P-59Belington 138kV Leadsville) Project for the purpose of participation in thePJM Regulation and energy markets via the Allegheny Power netw ork This project was studiedas an injection into the same POI used by the P59 project. Since it was stated at the FeasibilityKick-off meeting that the maximum amount ofw ind at this site will be 91.5 MW, the addition of32 MW of battery storage at th is site therefore fell under the 125 MW energy and 25 M W ofCapacity stipulated under the existing P59 ISA. The Commercial Operation da te for this projectwas requested to be October 30,2010. The analysiswas performed using a 2014 base year

PJM Reoort on the Transmission SystemThis portion of the repo rt addresses the impacts on and he required reinforcem entsto that part ofthe transmission system under PJM urisdiction.Network ImpactsQueue project W2-057 was studied as a 32.0MW (0 M W of which w as C apacity) injection intoth e 34.5kV collector bus to be constructed by AES for the P59 Belington 138kV (Leadsville)wind project. Project W2-057 was evaluated for compliance with reliability criteria fbr summerpeak conditions in 2014. Potential network impacts were as follows:Generator Deliverability(Single or N -1 contingencies for the Capa city portion only of the interconnection)No problems iden tified.

Mu ltide Facilitv Co ntiw em y(Double Circuit Tower Line Contingencies only with full energy output. Stuck Breaker and BusFault contingencies will be applied during the Impact Study)N o problems iden tified.

Con tribution to Previoushr Identified Overloads(Overloads initially caused by prior Queue positions with a dditional contribution to overloadingby this project. This project may have % allocation o f cost responsibility which will becalculated and reported for the Impact Study.)No problems iden tified.0 JM Interconnection 2010. ll rights reserved.


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Exhibit 6-1

New Svstem Reinforcements(Upgrades required to mitigate reliability criteria violations, i.e. "Network Impacts", initiallycaused by the addition of this project generation)None.

Contribution to Previouslv Identified Svstem Reinforcements(Overloads initially caused by prior Queue positions with additional contribution to overloadingby this project. This project may have a % allocation cost responsibility which will be calculatedand reported for the Impact Study) INone.

Short Circuit(Report Overdutied breakers here)None.

Stabilitv Analvsis

Will be performed at the System Impact Study Stage.' IEnerev Portion of Interconnection R eauestPJ M also studied the delivery of the energy portion or rhe surrounding generation. Any potentialproblems identified below are likely to result in operational restrictions to the project understudy. The developer can proceed with network upgrades to eliminate the operational restrictionat their discretion by subm itting a Transmission Interconnection equest.Note: Only the most seve rely overloaded conditio ns are listed. There is no guarantee of fulldelivery o f energy for this project by fixing only the conditions listed in this section. With aTransmission Interconnection Request, a subsequent analysis will be performed which analyzesall ovaload conditions associated with the overloaded element(s) identified. As a result of theaggre gate energy resources in the area, the following violations were identified.

N o problems identified.

APS Feasibilitv Analysis Report0 JM Interconnection 2010.All rights reserved.


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Exhibit6-1

This portion of this Feasibility Study Report has been prepared for PJM queue project W1-057by Allegheny Power. It addresses the required reinforcements, if any, found in the PJM analysisof the Transm ission System and provides the results of a similar analysis at the distribution leveLincluding the attachment and direct connec tion facilities.This project was studied as an injection into the 34.5kV ollector bus to be constructed by IC forthe P59 Leadsville)wind project. Therefore, no attachment facilities are to be constructed by APto support this installation.Based on discussions with the developer of this project, it was assumed that the P59 windgeneration hcility will have a maximum output of 91.5 MW. Therefore, at the Leadsville bus,there will be no net increase of generation capacity with the installation of W2-057. Thus,nothermal violations were identified.

Q PIM Interconnection2010. ll rights reserved.


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Exhibit6- 1

Single Line Diagram

AES Laurel Mountain, LLC32 MWmll be C o ~ c r e du thsF5934.5kV But (as shown).

UnionRoadBelington

ES 58 (Option to Build)ESLAUREL MOUNTAIN WNO (pssl --

I

ES AUREL MOUMANX m N G E Q U I P M'01HT OF INTERCONNECTIONI W E OINT >): II* w 8- o a w m t o Eilegheny power AHoma5.MuchavrLar um LEAOSVllLE SHllTCHllG STATfOH

NSn u r AESLAUREL MOUtrrAlM LLC rnrmrrcrrnr

E2457pd OCAU ;DROVlDE IHTERCONWECnOH FAgLmES FORELKINS SERVICE CENTER

0 M nterconnection2010.All rights reserved.


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Exhibit6-2

'roject: Laurel Mountain Summary Sclate: Mon 11/29/10

ID

TaskSplit

5

6

7

I__-89

10.- __11

12

13

14

e TaskName

Laurel Mountain Energy Storage Device

PJM Interconnection Process -ermit ReviewPSC Intent o File Letter

PSC Siting Certificate Filing

Design by Owners Engineer for RFPs and Contracting

RFPs and Bidding for Equipment and Contractors

Detailed Design by Installation Contractor

Procurement and Equipment Delivery

Site Preparation

Foundation and Installation Works

Commissioning

Commercial Operations

I Qtr 3,2010 IQtr 4,2010 I Qtr 1,2011 i Qtr 2.201 1 iQtr 3Jun Jul 1 Aug 1 Sep 1 Oct 1 No\ Dec I Jan ! Feb 1 Mar ! Apr 1 May I Jun 1 Ju

E z l10/13

i

I211

-t

6/1

[ ProgressMilestone + External TasksSummary - External Milestone- roject Summary - Deadline 9

Page 1


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Exhibit 6-3

LaurelMountain ESD Noise Analysis


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JACKSONQLLYTTORNEYS AT LAW PLLCExhibit 7

5M3 LEE STREET EAST SUITE 1600 PO. OX 553 CHARLESTON, WEST VIRGINIA 25322 TELEPHONE: 304-340- 1000 TELECOPIER:304-340-1 I30www.jacksonkolly. orn

E-Mail: snchamb~ ~ iacksonkelIv . comDIRECT TELEPHONE: (304) 340-121 4 DIRECT TELECOPIER: (304) 340-1080

State Bar No.694October 13,2010

Ms. S andra Squire p# 8Cf 13%UJD Psi: EXKC S ~ CIVExecutive SecretaryPublic Service Comm ission of WVP. 0.Box 812Charleston, WV 25323Re: Prefiling notice - AES Laurel M ountain, LLCApplication for Waiver of Siting CertificateMod ification Requirements or, in the Alternative,for a Siting Certificate Modification for theInstallation of an E nergy S torage Device at theSite of the Laurel M ountain W ind Power Project

AES Laurel Mountain, LLC (AES), pursuant to Section 2.1 of theCommissions EWG Siting Rules, hereby gives notice of its intent to file an Application forWaiver of Siting Certificate Modification Requirements or, in the Alternative, for a SitingCertificate Mo dification.

AES intends to install an energy storage device (Storage Device) at the s ite ofits certificated 125 MW Laurel Mountain Wind Power Project (Project) that is currently und erconstruction in Barbour and Randolph Co unties, West Virginia. The S torage Device will have anominal output of 32 MW and will be comprised of eight, 4 MW modules consisting of lithium-ion batteries, inverters, transformers, and cooling systems. T he mo dules will be contained w ithina fenced-in area less than 1% acres in size on open land directly adjacent to the Projectssubstation and transmission line and will be connected through the Project switchyard. Thepurpose of the Storage Device is to regulate the ramp rate of the Project and to enab le the Projectto supply ancillary services in the wholesale markets managed by PJM Interconnection. TheStorage Device will not increase the transmission or generation of the 125 MW Project, but willimprove the delivery of energy from the Project.AES believes that, con sidering the totality of the circumstances surrounding theProject, which extends over an area of approximately 14 miles in length, the construction of th e

WV PSC Case No 10 1824 E CS PC AES Laurel Mountain Waiver

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Transcript of WV PSC Case No 10 1824 E CS PC AES Laurel Mountain Waiver