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THE APPLICATION OF KENTUCKY POWER

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interconnection costs, as summarized in Table 31. We did not observe any systematically different costs by location. The wide range of costs, particularly network upgrade costs, over a relatively small number of observations for large plants, means that the upgrade costs for any individual project may vaiy substantially. To estimate costs for our reference plants, we examined the costs for similarly-sized plants. For the CT, we reviewed interconnection costs for 300-500 MW plants. The average direct interconnect cost was $3.1 million arid the average network upgrade cost was $7.7 million, for a total of $10.8 million. For the CC, we considered 500-750 MW plants The average direct interconnect cost is $7.7 million and the average network upgrade cost is $7.9 million. Based on these numbers, we estimate the total interconnection costs at approximately $11.O million for the CT and $15.5 million for the CC. Plant Size 100-300MW 300-500 MW 500-750 M W Observations AK. ( C O I l l l t ) ($111) 5 $1.1 4 $3.1 9 $7.7 Median ($In) $0.2 $3.2 $4.0 A%* ($117) $4.4 $7.7 $7.9 Median ($I??) $0.1 $6.7 $2.5 AK. ($111) $5.5 $10.8 $15.6 Median ( $ i n ) $0.3 $9.8 $6.5 Table 30 Historical Electric Interconnection Costs in PJM Direct Interconnection Costs Network IJpgrade Costs Total Costs Sources arid Notes Source is PJM (201la). Excludes plants that are interconnected at 138kV or lower 5. Net Start-up Fuel Costs during Testing Before commencing full commercial operations, new generation plants must undergo testing to ensure the plant is functioning and producing power correctly. This occurs in the months before the online date and involves testing the turbine generators on natural gas, as well as fuel oil if it has dual-fuel capability. We received fuel consumption and energy production data from CH2M HILL for each plant type based on data from recently built projects.28 During testing, a plant will pay for the natural gas and fuel oil consumption, and will receive revenues for its energy production. We estimated the cost of natural gas using Henry Hub futures through 2015 and adding a basis differentialtoeachdeliverypoint. WeusedtheChicagoCitygatebasisdifferentialfortheRest of RTO CONE Area, and our estimate of the Transco Zone 6 Non-New York (26 NNY) basis for all other CONE areas.29 We averaged the delivered price over the months of testing to obtain 28 29 Reported in Appendices A. 1 and B. 1 for the simple cycle and combined cycle plants respectively. Because 26 NNY basis future is an illiquid product there are no futures data available there. Instead we used the Zone 6 New York (26 NY) basis after adjusting for the historical relationship between the two. Historically, the 26 NNY and 26 NY prices are nearly identical except for three winter months when the 26 NY prices spikes much higher than (but with a strong correlation to) the 26 NNY price. Because neither the 2 6 NY and Chicago Citygate basis futures are available as far forward as 2015, we increased the monthly-varying basis futures at the rate of inflation for subsequent years. Henry hub futures and basis differentials were downloaded from Bloomberg (201 1). 26

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