March 6, Dear Ms. Ferrell:

Transcription

1 VIA FACSIMILEAND OVERNIGHT MAIL Ms. Ingrid Ferrell Executive Secretary Public Service Commission of West Virginia 201 Brooks Street Charleston, WV March 6,20 19 Re: CASE NO E-P APPALACHIAN POWER COMPANY and WHEELING POWER COMPANY Petition for review of EE/DR Program Rate Increments, Petition for Approval of New EE/DR Programs, and Application for Approval of Modifications to EE/DR Tariff Sheets Dear Ms. Ferrell: Enclosed for filing on behalf of Constellium Rolled Products Ravenswood, LLC are an original and twelve copies of "Constellium Rolled Products Ravenswood, LLC Recertljkation of Eligibility and Intent to Opt-Out,from the Appalachian Power Company Energy Efficiency and Demand Side Management Program. ' I Please do not hesitate to contact me if you have any questions or require further information. Thank you as always for your attention to this filing. Sincerely, Derrick Price Williamson Barry A. Naum (WV State Bar #12791) dwilliamson@spilmanlaw.com bnaum@,spilmanlaw.com BAN.sds Enclosures c: Certificate of Service

2 CERTIFICATE OF SERVICE I, Barry A. Naum, counsel to Constellium Rolled Products Ravenswood, LLC, do hereby certify that on this 6'h day of March, 2019, a copy of the foregoing "Constellium Rolled Products Ravenswood, LLC RecertiJcation of Eligibility and Intent to Opt-Out from the Appalachian Power Company Energy Efficiency and Demand Side Management Program'' was served upon the parties and/or counsel of record in this proceeding as follows: VIA U.S. MAIL William C. Porth, Esquire Heather G. Harlan, Esquire Robinson & McElwee PLLC P.O. Box 1791 Charleston, WV and James R. Bacha, Esquire American Electric Power Service Corp. 1 Riverside Plaza P.O. Box Columbus, OH and Noelle J. Coates, Esquire American Electric Power Service Corp. 3 James Center 1051 E. Cary Street, Suite 1100 Richmond, VA Counsel for Appalachian Power Company and Wheeling Power Company Thomas E. Scarr, Esquire Charles K. Gould, Esquire Jenkins Fenstermaker, PLLC 325 Eighth Street, 2"d Floor Huntington, WV Counsel for SWVA, Inc. Wendy Braswell, Esquire Staff Attorney Public Service Commission of West Virginia 201 Brooks Street Charleston, WV Counsel for Commission Staff Heather Osborn, Esquire Consumer Advocate Division 700 Union Building 723 Kanawha Boulevard, East Charleston, WV Counsel for Consumer Advocate Division Emmett Pepper, Esquire 1500 Dixie Street Charleston, WV Counsel for West Virginia Citizen Action Group Evan Johns, Esquire Appalachian Mountain Advocates 415 Seventh Street Northeast Charlottesville, VA and Mike Becher, Esquire Appalachian Mountain Advocates P.O. Box Charleston, WV Counsel for Sierra Club Barry A. Naum (WV State Bar #12791)

3 PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON CASE NO E-P APPALACHIAN POWER COMPANY and WHEELING POWER COMPANY Petition for Review of EE/DR Program Rate Increments, Petition for Approval of New EE/DR Programs, and Application for Approval of Modifications to EE/DR Tariff Sheets CONSTELLIUM ROLLED PRODUCTS RAVENSWOOD, LLC RECERTIFICATION OF ELIGIBILITY AND INTENT TO OPT-OUT FROM THE APPALACHIAN POWER COMPANY ENERGY EFFICIENCY AND DEMAND SIDE MANAGEMENT PROGRAM Pursuant to the Public Service Commission of West Virginia ("PSC'I or Tommission") Order issued on March 31, 201 1, in Case No E-P ("March 31 Order") and the PSC Order issued February 23, 20 18, in Case No E-P ("February 23 Order"), Constellium Rolled Products Ravenswood, LLC ("Constellium") hereby submits this filing and accompanying Affidavit, included as "Exhibit A," recertifying Constellium's eligibility and intent to opt-out from the Energy Efficiency and Demand Side Management Program ("EE/DR Program") administered by Appalachian Power Company (" APCo") for a five-year period ending on November 28,2023. As certified by the Affidavit, Constellium submits the following: 1. Constellium is entitled to opt-out from the APCo EEDR Program by reason of a stated load in excess of 1 MW for at least one billing cycle during the previous year. Attached to this filing as "Exhibit B" is a letter fiom American Electric Power ("AEP"), on behalf of APCo, confirming that Constellium's stated load exceeds the 1 MW threshold for eligibility to opt-out from the EE/DR Program.

4 2. Constellium further certifies that it has met the standards reflected in the PSCapproved Settlement in Case Nos E-GI and E-P regarding investments in EE/DR measures installed within the last 36 months (or to be installed in the next 6 months) designed to achieve energy or demand savings comparable to those available through the EE/DR Program. A description of these investments, including the projected energy savings and estimated life, is provided in the Table below. Investment Measure Upgrade Controls on Air Compressors - Improved Turn-down resulting in decreased amount of compressor blow off. Will also automatically shut down compressors when not needed. Estimated kwh/year or WAear Savings 2,478,554 kwh/yr Expected Life (Years) 15 Install new air dryers throughout the plant (total of 5 new desiccant air dryers for CPG and main compressors). Currently have 3 compressed air purge desiccant dryers in constant regen..5 MW/yr 25 Convert plant lighting to LED - phases 2 & ,3 84 kwhlyr 10 Convert coil annealing furnace pilots and sumps from compressed air to >lower/electric I.05 MW

5 WHEREFORE, Constellium Rolled Products Ravenswood, LLC, respectfully requests that the Commission enter this filing and accompanying exhibits in the above-referenced docket and take notice of Constellium's recertification of its eligibility and intent to opt-out from the Appalachian Power Company Energy Efficiency and Demand Side Management Program, effective November 28,2018. Respectfully submitted this 6'h day of March, Barry A. Naum (WV State Bar No ) SPILMAN THOMAS & BATTLE, PLLC 1100 Bent Creek Blvd., Suite 101 Mechanicsburg, PA Phone: Fax: dwilliamson@,spilmanlaw.com bnaum@,spilmanlaw.com Counsel for Constellium Rolled Products Ravenswood, LLC 3

6 EXHIBIT A

7 AFFIDAVIT STATE OF WEST VIRGINIA, COUNTY OF JACKSON, to-wit: The undersigned, Adam CasweIl ("Affiant"), being first duly sworn, deposes and says: 1. I am a Senior Engineer for ConstelIium Rolled Products operations in Ravenswood, West Virginia. 2. Based upon my thorough review of the records and documents related to this matter, I certify that the information contained in the foregoing filing is true and correct to the best of my knowledge, information, and belief Subscribed and sworn to before me this My commission expires HANNAH J BOLYARD Notary Pubk Off~ial Seal ycomm.expwesfebii.x)21 R.bfiaa3 I I, 702 I J day of February, [Notarial Seal]

8 EXHIBIT B

9 February 7, Bent Creek 5oulevard, Suite 101 ~echanjcsbu~g, PA Dear umber 022-8g4"0~2-0 Co~ste~iium Rolled ts' f ~ r request, ~ a ~ dated 2018, Out. The Co~panies haw under a &~o~nt n~~ber u~o~s t~e~we months+ lic ~e~~~~ ~ ~ ~ ~ ~ $ s ~ ~ ions to Schedule E.E./D.R., pa~~cularly as it relates t part of this revised process, it is necessary for the Co~panie$ to be able to veri@ the savings identified by the customer in its recertification application. This will allow the ~ompanies to include such savings as part of its overall EE/OR savings attainment report. Eased on the additional inf5rmat~on provided in Attach~ent A y C~n~tetl~urn Rolled F ~ ~ ~ on ~ c t s ~ January 9, 2019, the Companies were able to review and perform calculations to verify, to the best of their knowledge and belief, that the kw/kwh savings attained, as shown on Attachment B, would provide energy or demand savings that would be comparable to the savings that would be available through EE/DR programs by the Companies. As agreed to by Cons~elli~~ Rolled Products and the Compan~es, Project 2 and Project 4 were excluded from the calcufation of these savings.. These results ~ndicate that Constellium Rolled Products is eligib Com~an~es' EE/DR t-out program. Fending any add~t~~nal o r~ce~~f~&a~i~n wou be required prlor to November 2,2023 to co~ti~ue pa~~cipatio~ in the C o m ~ ~ EE/DR ~ ~ e opt-out ~ ' program. Please submit this letter along with aif the s ~ppo~~ng do&um~~tati~~ and i ~ f ~ ~ to ~ the a t ~ o ~ C o ~ ~ ~ as ~ a closed s i ~ entry n at Case No E-P with an a~companyin~ Aff~da~it attesting to the

10 Sincerely, c: aiach~~~ Power (via onlyf