BEFORE THE PUBLIC SERVICE COMMISSION
OF MARYLAND
THE APPLICATION OF CONSTELLATION
SOLAR MC,LLC FOR A CERTIFICATE OF
PUBLIC CONVENIENCE AND NECESSITY
TO CONSTRUCT A 20 MW SOLAR
PHOTOVOLTAIC GENERATING FACILITY
IN HARFORD COUNTY,MARYLAND
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Case No.
X
X
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THE APPLICATION OF CONSTELLATION SOLAR MC,LLC
FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY TO
CONSTRUCT A 20 MW SOLAR PHOTOVOLTAIC GENERATING FACILITY IN
HARFORD COUNTY,MARYLAND AND REQUEST FOR EXPEDITED REVIEW
AND WAIVER OF THE TWO YEAR NOTICE REQUIREMENT
Pursuant to § 7-207 of the Public Utilities Article ("PUA") of the Annotated Code of
Maryland and Title 20, Subtitle 79 of the Code of Maryland Regulations ("COMAR"),
Constellation Solar MC, LLC ("CSMC" or the "Applicant") respectfully requests that the
Maryland Public Service Commission grant CSMC a Certificate of Public Convenience and
Necessity to construct a nominally rated 20 megawatt ("MW") solar generating facility in
Hanford County, Maryland (the "Perryman Solar Project" or "Application"). The Perryman
Solar Project is being developed pursuant to Condition 10 of Order No. 84698, which requires
Exelon to develop or assist in the development of new generation in Maryland,including 30 MW
of solar generation. CSMC's Application is comprised of this petition together with the attached
Environmental Review Document(`BRD"). Additionally, CSMC requests both a waiver of the
two-year notice requirement and consideration of its Application pursuant to a timeline that
would pernut construction to commence in the beginning ofthe second quarter of2415.
Section I of this petition describes the Applicant; Section II provides an overview of the
Project; Section III provides the information required by section 7-207 of the Public Utilities
Article; and Section IV requests waiver of the two-year requirement and explains the need for
expedited review.
I.
The Applicant
CSMC is a wholly-owned subsidiary of Constellation, an Exelon Company. CSMC is
headquartered at 100 Constellation Way,Baltimore, MD 21202.
II.
Project Background
The Perryman Solar Project will involve the design, construction, and operation of a 20
MW solar generating facility on a portion of Constellation's Perryman Generating Station
("Perryman") property. The Project will be laid out into four arrays of solar modules and
integrated with the existing infrastructure and support facilities of Perryman, including access
roads, existing substation, and transmission lines. Arrays 1 and 2 are each approximately 15
acres in size and are located in the northern part ofthe site in the vicinity ofthe Perryman 51 and
6 Units. Array 3 is also approxunately 15 acres and located southwest of the. Perryman 51 Unit
near the western site boundary. Array 4 is approximately 78 acres and is located south of the
existing Perryman substation. Each solar array of the Project will be connected to the Project's
protective switchgear, which will feed power into a new three-way switch and subsequently into
an existing 34.SkV overhead BGE distribution line that runs down Chelsea Road. Project layout
will emphasize placement of arrays and associated equipment in previously disturbed areas.
The Perryman Solar Project will consist of the following main components: (1)
approximately 88,500 305-watt Hanwha crystalline photovoltaic ("PV") modules;(2)DC to AC
power inverters; (3) electrical interconnection to Baltimare Gas &Electric's ("BGE") 34.SkV
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distribution line on Chelsea Road; and (4) an optional electrical connection to Sod Run
wastewater treatment plant. When the Perryman Solar Project is completed, the project is
expected to have a nominal generating capacity of approximately 20 MW.
A.
Perryman Generating Station
The Perryman Solar Project will be located on a portion of a 717-acre site owned by
Constellation and currently occupied by Constellation's Perryman Unit 51, Units 1 through 4,the
Perryman 6 Project, which is currently under construction, and a BGE substation. The existing
Perryman Generating Station consists offive simple-cycle combustion turbine ("CT") units used
to generate power during periods of peak demand. Perryman Units 1 through 4 consist of four
nominal 50 MW CTs and associated facilities located on a 34-acre tract just east of Chelsea
Road. These units commenced operations in 1972. Perryman Unit 51 is a nominal 135 MW
General Electric 7FA CT located west of Perryman Units 1 through 4. It was licensed in 1993
and placed into commercial operation in 1995. The combined current generating capacity of the
plant is about 355 MW.
The Perryman 6 Project was licensed by the Commission in June 2014 in Case No. 9136
and is currently under construction. It consists of one nominal 120 MW gas turbine generator
package, which includes two simple-cycle aero-derivative CTs coupled to a common electric
generator. It is located on an approximately 5.2-acre area adjacent to the existing Perryman Unit
51 site. Perryman Unit 6 will add 120 MW of generating capacity upon completion.
B.
Project Activities
A complete description of planned Project activities is provided in Chapter 3 of the
attached Environmental Review Document.
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All construction work for the Perryman Solar Project will be accomplished without
impacting the existing units at the site and work will be coordinated to allow tie-ins of new stepup transformers in the existing substation.
III.
Application Requirements
In conformance with the provisions of COMAR 20.79.01.04 (Application Filing
Requirements) and 20.79.03.01 (Description of Generating Station), CSMC hereby states as
follows:
A.
The name ofthe Applicant is Constellation Solar MC,LLC.
B.
The address ofthe principal business office ofthe Applicant is Constellation Solar
MC,LLC, 100 Constellation Way, Baltimore, MD 21202.
C.
The following persons are authorized to receive notices and communications with
respect to the Application:
Divesh Gupta
Assistant General Counsel
Constellation Energy
100 Constellation Way, Suite SOOC
Baltimore, MD 21202
410-470-3158
divesh.gupta@constellation.com
D.
F. William DuBois
Venable LLP
950 East Pratt St., Suite 900
Baltimore, Maryland 21202
410-244-5467
wdubois@venable.com
Copies of the Application are being made available for public inspection and
copying at the Aberdeen Branch of the Hanford County Public Library, 21 Franklin Street
Aberdeen, MD 21001.
E.
A list of each loco?; state, and federal government agency having authority to
approve or disapprove the construction or operation of the Perryman Solar Project is set forth in
Table 1.2 ofthe Environmental Review Document portion ofthis Application.
F.
The Perryman Solar Project will be interconnected to the BGE electric
distribution network by the existing 34.SkV distribution line running along Chelsea Road.
G.
A general description of the generating station, consistent • with COMAR
20.79.03.01, is provided in Chapter 3 ofthe Environmental Review Document.
H.
CSMC seeks to begin construction ofthe Project in Apri12015 and for portions of
the Project to be complete and in service as early as December 15, 2015. Additional information
is contained in the attached Environmental Review Document.
I.
The environmental information required by COMAR 20.79.03.02 is provided in
the attached Environmental Review Document.
IV.
Request for Waiver and Expedited Review
Maryland law requires the filing of CPCN applications at least two years before the
commencement of construction. The Commission has authority to waive that notice requirement
upon a showing of good cause. PUA § 7-208(c)(2), See also COMAR 20.79.01.07. The
Commission routinely grants such requests. See, e.g., Case No. 9351, Order No. 86607
(September 3, 2014)(stating that the requested waiver was granted in a May 22, 2014 prehearing
conference); Case No. 9314, Order No. 85683(May 31, 2013)(indicating that Church Hill Solar
Farm LLC's request was granted in a February 11, 2013 prehearing conference); Case No. 9272,
Order No. 84059(May 26,2011)(granting Maryland Solar LLC's request).
A two year notice requirement is unnecessary when, as here, the project's impacts will
not extend beyond the borders of the site. There are no emissions that will impact adjacent
properties and the installation of solar modules will not materially impact property values for
nearby residents. Accordingly, good cause exists to support the waiver of the two-year notice
requirement.
CSMC also requests expedited review and approval of its Application consistent with
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prior solar CPCN projects in Maryland. Project approval in the first quarter of2015 would allow
for the completion of construction before the end of 2015, thereby providing CSMC with a full
year of renewable energy credits and generation in 2016 to further its ability to meet state
renewable portfolio requirements.
V.
Conclusion
CSMC has provided in support of its Application the information above, the
Environmental Review Document, which is provided as Attachment A,the Direct Testimony of
Joshua Kelley, which is provided as Attachment B, and the Direct Testimony of Lisa Ricker,
which is provided as Attachment C:
20.79.02.01 is provided.
A signed verification as required under COMAR
The Project will have minimal environmental impact, provide
economic benefits to the State, and will have an important, positive impact on the stability and
reliability ofthe electrical system.
Respectfully submitted,
~~
F. William DuBois
Venable LLP
950 E. Pratt St., Suite 900
Baltimore, Maryland 21202
(410)244-5467
~~~
Divesh Gupta
Assistant General Counsel
Constellation Energy
100 Constellation Wap, Suite SOOC
Baltimore, MD 21202
410-470-3158
divesh.gupta@constellation.com
Counselfor Constellation Solar MC,LLC.
VERIFICATION
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~~~n employee of Constellation Solar MC,LLC, having authority
with respect to the foregoing Application for a Certificate of Public Convenience and Necessity
for the Perryman Solar Project and being duly sworn, affirm that the matters and facts set forth in
the Application are true and correct to the best of my information, knowledge, and belief.
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Taken, sworn to and subscribed before me this~day of October, 2014.
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