THE STATE OF NEW HAMPSHIRE
SITE EVALUATION COMMITTEE
Berlin Station, LLC
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RE: No. 2011-01
DATA REQUESTS OF COUNSEL FOR THE PUBLIC
Counsel For The Public, K. Allen Brooks, ("Counsel") hereby requests the following
1. Please state the number of tons of ashes that the facility with higher efficiency
information from the applicant:
will produce on a monthly basis. Describe in detail the procedures that the facility will
employ to manage and dispose of those ashes with the facility operating at greater output.
Include in your description maps and diagrams showing the location and design of any ash
holding structures or locations. Provide copies of any documents relating to your plans to
sell any such ashes for reuse.
2. Please provide copies of all power purchase agreements ("PPA") with respect
to any energy to be produced by the Project, including any drafts under discussion
subsequent to the PUC's recent determination of conditional approval.
3. Please provide financial statements for each of the entities identified on pages
4-5 of the Joint Motion dated March 9, 2011.
4. Please provide forecasts for earnings/losses of the Project through 2011.
5. Identify the source of funds now on hand and previously expended for costs of
the Project.
6. State the amount of cash on hand for the Project. State the amount of cash
needed in the next 36 months, by quarter, for the development of the Project. State the
amount of income, including loan proceeds or equity, projected for the Project in the next 36
months, by quarter, and the sources of such. State the complete basis for such projections.
7. Identify any loan applications, requests, or proposals for financing made by
the Applicant for this project and provide copies. Identify and provide copies of any term
sheets or commitment letters for such loans. Provide copies of any loan documents
associated with such loans.
8. Please specify the amounts of debt and equity that the Project will need.
Describe all material terms with respect to the debt and the equity, respectively. Identify the
sources of such debt and equity.
9. How much capital for the Project does the Applicant have committed through
financing or equity as of the hearing date?
10. Please provide legal organization charts for each entity that will own any
interest in or operate the facility, the Applicant or the land on which the project will be
constructed.
II. Please provide an updated copy of the Project's financial model showing the
Applicant's financial assumptions and projections on a going forward basis through to
complete amortization of all debt.
12. Please state from where the labor used for construction of the Project will be
obtained.
13. Does the Applicant plan on maximizing the use of New Hampshire labor to
construct the Project? If so, please describe what steps the Applicant will take to ensure that
use of New Hampshire labor will be maximized.
14. Does the Applicant plan on maximizing the use of New Hampshire citizens to
operate, manage, and maintain the Project? If so, please describe what steps the Applicant
will take to ensure that employment of New Hampshire citizens to operate, manage and
maintain the Project will be maximized.
15. Does Richard Carrier Trucking ("RCT") own land suitable for timber
harvesting or any other property or businesses from which bio-fuel suitable for burning at the
Berlin biopower facility could be obtained?'
16. If the answer to question # 15 is yes, please identify the land, property, or
business as well as its location and estimated available biomass volume for the period of the
fuel supply contract.
17. How many individuals does RCT currently employ?
18. How many of the individuals currently employed by RCT are New Hampshire
residents?
I Questions illS and # 16 pertain to any land whether located within or outside of the United States.
19. Does RCT have existing contractual obligations related to the receipt of timber
or other material suitable for use as fuel at the facility?
20. If the answer to question # 19 is yes, please identify the entities or individuals
with whom RCT has a contractual obligation.
21. If the answer to question # 19 was yes, please identify how many of the entities
22. Please provide a copy of the fuel supply agreement with RCT.
or individuals identified in the answer to question #20 are New Hampshire companies or
New Hampshire residents.i
23. Provide copies of the Facility Lease and Right of Use Agreement, referenced
on page 5 of the Joint Motion.
24. Provide copies of any agreements, term sheets or letters of intent with
Waldron Engineering, Delta Power Services, Black & Veatch, and Shaw Group.
25. Please identify all members of the Laidlaw Advisory Board, including their
contact information and biographical information. Do you expect the membership of the
Board to change prior to the commencement of commercial operations? If so, why?
26. Please specify each condition of the Certificate that you ask the Committee to
amend and provide specific terms that you ask to see instead.
27. Please explain all the reasons why Homeland Renewable Energy and
Fibrowatt Operations, LLC are being replaced. Provide copies of any correspondence
relating to these reasons.
28. Provide copies of all documents that relate in any way to any of the questions
stated above and your responses thereto.
1 At the previous hearings, the representative frorn the applicant's previous fuel supplier, Cousineau Forest Products
("Cousineau"') testified at great length. The questions above are not intended to be exhaustive and the State expects
that the applicant will ensure that RTC answers all questions previously posed to Cousineau either through
testimony at the hearing or through pre-filed testimony subject to cross-examination.
29. Please identify the person responding to each of the foregoing data requests,
include their name, address, title, and experience and qualification for answering the data
request.
COUNSEL FOR THE PUBLIC
By his attorneys
MICHAEL A. DELANEY
ATTORNEY GENERAL
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K. Allen Brooks
Senior Assistant Attorney General
Environmental Protection Bureau
33 Capitol Street
Concord, New Hampshire 03301-6397
Tel. (603) 271-3679
Peter c.r. Roth
Senior Assistant Attorney General
Environmental Protection Bureau
33 Capitol Street
Concord, New Hampshire 03301-6397
Tel. (603) 271-3679
