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Attn: Robert Stein, ChairmanConnecticut Siting Council10 Franklin SquareNew Britain, CT 06051RE:Petition of Bloom Energy Corporation, as agent for Frontier CommunicationsCorporation, for a Declaratory Ruling for the Location and Construction of a 200kW Fuel Cell Customer Side Distributed Resource at 39 West Street, Danbury, CT06810Dear Chairman Stein:We are submitting an original and fifteen (15) copies of the above-captioned Petition, togetherwith the filing fee of 625.In the Petition, Bloom Energy Corporation (“Bloom”), as agent for Frontier CommunicationsCorporation (“Frontier”), request the Connecticut Siting Council approve the location andconstruction of a 200 kilowatt fuel cell and associated equipment (the “Facility”). The Facilitywill be located on the site of the Frontier building at 39 West Street, Danbury, CT (the “Site”).Electricity generated by the Facility will be consumed primarily at the Site, and any excesselectricity will be exported to the electric grid. The Facility will be fueled by natural gas.Should you have any questions, concerns, or require additional information, please contact me at(860) 839-8373.Sincerely,Bloom EnergyJustin Adamsjustin.adams@bloomenergy.com(860) 839-83731299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
STATE OF CONNECTICUTCONNECTICUT SITING COUNCILPETITION OF BLOOM ENERGYCORPORATION AS AGENT FOR FRONTIERCOMMUNICATIONS CORP FOR ADECLARATORY RULING FOR THELOCATION AND CONSTRUCTION OF A 1.4MEGAWATT FUEL CELL CUSTOMER-SIDEDISTRIBUTED RESOURCE AT 39 WESTSTREET, DANBURY, CONNECTICUT: PETITION NO.::::: November 11, 2016PETITION OF BLOOM ENERGY CORPORTATION AS AGENT FOR IKEA FOR ADECLARATORY RULINGPursuant to Conn. Gen. Stat. §§ 4-176 and 16-50k(a) and Conn. Agencies Regs. § 16-50j38 et seq., Bloom Energy Corporation (“Bloom”), as agent for Frontier Communications Corp.(“Frontier”), requests that the Connecticut Siting Council (“Council”) approve by declaratoryruling the location and construction of a customer-side distributed resources project comprised ofone (1) new ES-5 Bloom Energy Servers solid oxide fuel cells and associated equipment (the“Facility”), providing 200-kiloawatts (“kW”) (net) of power to the Frontier building located at 39West Street, Danbury, Connecticut (the “Site”). See Exhibit 1. The Facility will be installed,maintained and operated by Bloom and owned by Key Equipment Finance, a third partyfinancing source of Bloom under an agreement with Frontier.Conn. Gen. Stat. § 16-50k(a) provides that:Notwithstanding the provisions of this chapter or title 16a, the council shall, in theexercise of its jurisdiction over the siting of generating facilities, approve bydeclaratory ruling . . . (B) the construction or location of any fuel cell, unless thecouncil finds a substantial adverse environmental effect or of any customer-sidedistributed resources project or facility . . . with a capacity of not more than sixtyfive megawatts, as long as such project meets air and water quality standards ofthe Department of Energy and Environmental Projection.”1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
The proposed Facility will be a customer-side distributed resource facility under 65MWthat complies with the air and water quality standards of the Connecticut Department of Energyand Environmental Protection (“DEEP”). Bloom submits that no Certificate is required becausethe proposed modifications would not have a substantial adverse environmental effect in theimmediate vicinity of the Facility as well as in the State of Connecticut.I.COMMUNICATIONSCorrespondence and other communication regarding this petition should be directed tothe following parties:Justin AdamsBloom Energy Corporation1299 Orleans DriveSunnyvale, CA 94089Telephone: (860) 839-8373Fax: (408) 543-1501Email: justin.adams@bloomenergy.comII.Alicia SurowiecBloom Energy Corporation1299 Orleans DriveSunnyvale, CA 94089Telephone: (484) 888-3621Fax: (408) 543-1501Email: alicia.surowiec@bloomenergy.comDISCUSSIONA.Project Description and PurposeThe proposed Facility would be a 200kW customer-side distributed resource consistingof a state-of-the-art Bloom Energy Server and associated equipment. It will be interconnected toswitchgear located inside the electrical room of the Frontier Communication Corp. building(“Building”). See Exhibit 2.The Facility will be a “customer-side distributed resource(s)” project because it will be “aunit with a rating of not more than sixty-five megawatts [and is located] on the premises of anindustrial end user within the transmission and distribution system including, but not limited to,1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
fuel cells . . . .” Conn. Gen. Stat. § 16-1(a)(40)(A). Further, in its Final Decision in Docket No.12-02-09, dated September 12, 2012, the Connecticut Public Utilities Regulatory Authority(“PURA”) determined that Bloom’s Energy Server qualifies as a Class I renewable energysource fuel cell as defined in Conn. Gen. Stat. §16-1(a)(26)(A). See Exhibit 3.The purpose of the proposed Facility is to replace the average baseload of the Buildingwith a Class I renewable energy source, achieve sustainability goals, and improve reliability ofelectrical systems and equipment. The meter interval data analysis conducted in 2016 (Exhibit4) determined the average baseload for the Building to be 186kW, approximately equivalent tothe proposed 200kW Facility. Therefore, electricity generated by the Facility will be consumedprimarily at the Site, and any excess electricity will be exported to the grid.B.The Facilityi.The FacilityThe Facility will consist of a Bloom solid oxide fuel cell Energy Server and associatedequipment. The Energy Server is approximately 26 feet long, 4 feet wide and 7 feet tall. Thelocation and arrangement for the fuel cells and equipment at the rear of the Building is shown inExhibit 2. The Energy Server module is enclosed, factory-assembled and tested prior toinstallation. See Exhibit 5.The Facility will be capable of producing 200kW of clean, reliable and continuouselectric power. The Facility will interconnect to the Site’s distribution system and operate inparallel with the grid to provide the Site’s electrical requirements. Any electricity generated inexcess of the Site’s requirement will be exported to the grid under an Eversouce net meteringtariff. This site will not have an uninterruptible power module (“UPM”) and thus will not have1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
any means to output power in a grid independent capacity at any time. The interconnection toEversource will be provided from switchgear located inside the electrical room. The Eversourceinterconnection application for the Facility was submitted and is currently under review. TheFacility will be fueled by natural gas supplied by Eversource.The Facility, and more specifically the inverters within, are UL1741/IEEE1547 compliantand thus will not operate without a stable utility voltage. In the event of an outage, the Facilitywill not shut down, they will automatically enter a state of stand-by awaiting the return of astable utility voltage. When in a state of complete shut down the Energy Server requires acombination of remote and on-site coordination to start up the systems. This work is performedby Bloom employed, trained and certified personnel only, Frontier does not control the operationof the system directly. In accordance with Public Act 11-101 1, an Emergency Response Plan(Exhibit 6) and associated training is provided to Frontier and select employees.The Facility includes extensive hardware, software and operator safety control systems,designed in accordance with the American National Standards Institute (ANSI) / CanadianStandards Association (CSA) America FC 1-2004 standard for “Stationary Fuel Cell PowerSystem(s)”. The Facility will be remotely monitored by Bloom Energy 24 hours a day, sevendays a week. If software or hardware safety circuits detect an unsafe condition, variation intemperature or gas pressure outside of operational parameters, fuel supply is automaticallystopped and the system is shut down. A Bloom Energy trained service technician will visit thesite to determine the cause of the shutdown before starting the system back up. Two manual fuel1An Act Adopting Certain Safety Recommendations of the Thomas Commission1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
shut-off valves are provided at each installation site, and two normally closed, safety shut-offrated isolation valves are installed within the system.The Facility will be installed in accordance with NFPA 853 2. This standard provides fireprevention and fire protection requirements for safeguarding life and physical propertyassociated with buildings or facilities that employ stationary fuel cell systems of all sizes. Therisk of fire related to the operation of this Facility is therefore very low. Furthermore, in theEnergy Server, natural gas is not burned; it is used in a chemical reaction to generate electricity.The natural gas is digested almost immediately upon entering the unit and is no longercombustible. In accordance with Public Act 11-101 3, the fuel line (pipe) cleaning procedure is topurge for 60 seconds with 10 blasts of on off prior to connecting to the Facility. In addition tothese safety features, the Facility will also be installed in compliance with all applicable building,plumbing, electrical, and fire codes to ensure local standards and procedures are addressed.C.Existing Environmenti.The SiteThe Facility would be installed within the Frontier property located at 39 West Street,Danbury. The Building and the surrounding parking, driveways and grounds occupy four parcelsthat are owned by Frontier and combine to equal 1.19-acres (“the Site”). The Facility will beconstructed at the rear of the Building in proximity to existing mechanical equipment. The Siteis within the “Downtown Revitalization Overlay Zone” and is zoned as “Light Commercial”(“CL-10”) under the zoning regulations of the City of Danbury (the “City”). The surrounding23Standard for the Installation of Stationary Fuel Cell Power Systems, 2015 EditionPublic Act 11-101, An Act Adopting Certain Safety Recommendations of the Thomas Commission,1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
areas are zoned as CL-10 and High Rise Residential (RH-3). The abutting properties of theproposed location include churches, business services, law offices, an apartment building, andDanbury City Hall.The Facility would be located on a concrete pad within an existing paved driveway andparking area at the rear of the Building. Existing parking for the building is not established andthe parking spaces are not delineated for the site. A parking plan and proposed rear drive aisle(Exhibit 2) were submitted to Danbury’s City Planning and Fire Marshal representatives for theirreview. As shown in Exhibit 2, parking would be limited to the western side of the Buildingwhich provides an adequate number of spaces so the Building would be over parked at theconclusion of the project. In addition, the rear of the Building would be a dedicated drive aislewith sufficient width to allow the safe passage of emergency vehicles. Bloom will continue towork closely with the City to ensure necessary requirements are met.The location of Facility was strategically placed in proximity to the existing mechanicalequipment, at the rear of the Building to reduce visual impacts to the City and abutters. Photos ofthe proposed location and adjacent areas are provided in Exhibit 7.ii.Wildlife, Habitat and Cultural ResourcesA review of the publically available Natural Diversity Database (NDDB) has shown noknown occurrences of state-listed species within the proposed Facility location. Furthermore, theproposed Facility will be located on a driveway and parking area that were previously developedand disturbed during construction of the Building. Therefore, the construction and operation ofthe Facility will not have a substantial adverse effect on wetlands, state-listed species, andcultural (archaeological and historical) resources.1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
iii.Flood ZonesA review of the flood hazard mapping data from Federal Emergency ManagementAgency’s (“FEMA”) National Flood Insurance Program (“NFIP”) has shown the Facility wouldbe located within an unshaded FEMA Zone X, an area determined to be outside the 500‐yearflood zone. However, to the northwest and bordering the Site a 100-year flood zone area exists.See Exhibit 8. Site work, such as grading and soil removal, would be limited to areas outside ofthe 100-year flood zone.D.Environmental Effects and Mitigationi.Natural Gas Desulfurization ProcessThe first step in the production of electricity in the Bloom Energy server isdesulfurization – the removal of the sulfur compounds, which have been added to the natural gasas an odorant by the natural gas suppliers. This step occurs in the desulfurization unit – a canisterwhich contains a filter made for this purpose. Sulfur is not “produced” in this process, but isseparated from the natural gas in which it was contained. In this process, trace levels of othercompounds which are naturally present in the natural gas may also absorb to the filter. Again,these are not “produced” from the process, but are separated from the natural gas in which theywere contained. The filter is made up of inert materials.The desulfurization process takes place entirely within desulfurization canisters. Theseare made of extruded aluminum or zinc-plated steel that are built to last for the life of the EnergyServer and beyond. Because they are built to hold natural gas, their structural integrity isessential. That integrity is assured by around the clock monitoring of the Energy Servers todetect any leak. Were there a leak, the Server (including the desulfurization operation) would1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
shut down automatically. There has never been a leak from one of the desulfurization canisters.The structural integrity and leak prevention continues after the desulfurization canisters areremoved from service. At that point, the entry and exit points for the natural gas automaticallyseal shut. The desulfurization canister remains sealed and is not opened at the Site, or anywherein the State of Connecticut.Within days that a desulfurization canister is taken out of service, it is picked up by aBloom contractor and taken to a licensed facility outside the State, where the desulfurization unitis opened and the contents are removed. As described above, the desulfurization unit hascomplete structural integrity. Its safety as a container for transporting has been certified by theDepartment of Transportation (DOT). This certification assures that the canisters are secure andhave the structural integrity to transport the desulfurization materials safely and without risk of arelease.Bloom has been engaged and expects to have further follow up discussion with regulatorson the proper management of materials found in all public pipeline natural gas supplied to homesand businesses, which we filter before that fuel is consumed by our product to produce clean,environmentally friendly electric power. Because our technology is relatively new, the 35 yearold regulations do not address our situation, but we have been working with the regulators toobtain clarification.ii.EmissionsThe construction and operation of the Facility will comply with DEEP’s air and waterquality standards and will not have a substantial adverse environmental effect.1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
With respect to water discharges, the Energy Servers are designed to operate withoutwater discharge under normal operating conditions. Additionally, the Facility would use nowater during normal operation beyond a 75-gallon injection at start up.Conn. Agencies Regs. § 22a-174-42, which governs air emissions from new distributedgenerators, exempts fuel cells from air permitting requirements. Accordingly, no permits,registrations, or applications are required based on the actual emissions from the Facility. SeeConn. Agencies Regs. §§ 22a-174-42(b) and (e). Notwithstanding this exemption, as shownbelow in Table 1, the Facility meets the Connecticut emissions standards for a new distributedgenerator.Table 1: Connecticut Emissions Standards for a New Distributed GeneratorCompoundOxides of Nitrogen (NOx)Carbon Monoxide (CO)Carbon Dioxide (CO2)Connecticut EmissionStandard (lbs/MW-hr) 40.1511,650Bloom Energy Server(lbs/MW-hr) 0.01 0.10735-832The facility will also meet state criteria thresholds and projected emissions for allgreenhouse gases defined in Regulations of Connecticut State Agencies Section 22a-174-1(49)as shown in Table 2. By virtue of the non-combustion process the Energy Servers virtuallyeliminate NOx, SOx, CO, VOCs and particulate matter emissions from the energy productionprocess. Similarly there are no CH4, SF6, HFC or PFC emissions. CH4 is broken down in thereforming process. Reforming is the type of process where if you have sufficient catalyst, thereaction can go all the way to completion. That is the case for the Bloom Energy Server. Thefuel is reformed in the hot box – with a very significant excess catalyst for reaction.4Conn. Agencies Regs. § 22a-174-42, Table 42-2.1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
Table 2: Connecticut Thresholds for Greenhouse GasesEmission TypeNitrous Oxides (NOx)Carbon Monoxide (CO)Sulfur Oxides (SOx)Volatile Organic Compounds (VOCs)Carbon Dioxide (CO2) 5iii.Bloom Output 0.01 lbs/MWh 0.10 lbs/MWhNegligible 0.02 lbs/MWh735-832 lbs/MWhLERC allowance0.07 lbs/MWh0.10 lbs/MWhNot Listed0.02 lbs/MWhNot ListedSound LevelsBloom contracted Mei Wu Acoustics (MWA) to predict the sound levels produced by theproposed Facility. In addition, MWA conducted 24-hour sound level measurements at the Site to establishthe existing ambient environmental sound levels in order to compare predicted noise levels with existingconditions and demonstrate compliance with the requirements. The report is provided in Exhibit 9.The report indicates that the proposed location would be considered a “high background noisearea 6” according to the DEEP regulations. However, this regulation need not be applied to meet the DEEPrequirements. In the proposed configuration the predicted noise levels emitted from the Facility to theClass A (residential) receivers would be less than 45 dBA, and in compliance with noise criteria set forthin Connecticut regulations for the Control of Noise.iv.Visual EffectsThe overall visual effect would be mitigated by the proposed location at the rear of theBuilding in proximity to existing mechanical equipment.E.Project Construction and MaintenanceDuring construction, appropriate erosion and sedimentation (E&S) controls will beinstalled to protect roof drains and prevent the transport of construction related sediment off-site.56Carbon Dioxide is measured at Bloom’s stated lifetime efficiency level of 53-60%DEEP Sec. 22a-69-3.6.1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
Temporary E&S control measures will be maintained and inspected throughout construction toensure their integrity and effectiveness. The temporary E&S control measures will remain inplace until the work is complete. Due to the limited disturbance required for the Facility’sinstallation, no construction-related storm water permits will be required. Further, no additionalimpervious area will be added to the Site and it will not affect drainage patterns or stormwaterdischarge. Construction-related impacts will be minimal and contained to the roof or within thebuilding.III.COMMUNITY OUTREACHBloom has provided notice of this petition to all persons and appropriate municipalofficials and governmental agencies to whom notice is required to be given pursuant to Conn.Agencies Regs. § 16-50j-40(a). 7 A copy of the notice letter and a service list are provided inExhibit 10 and the corresponding abutters map is provided in Exhibit 11. Additionally, prior tofiling this petition, representatives from Bloom briefly discussed the proposed Facility with theCity of Danbury Planning Department. An opportunity to comment on the proposed Site Planhas been provided to the Mayor and City Planner to incorporate any design comments they mayhave. See Exhibit 12.IV.BASIS FOR GRANTING OF THE PETITIONUnder Conn. Gen. Stat. § 16-50k(a), the Council is required to approve by declaratoryruling the construction or location of a customer-side distributed resources project or facility7Conn. Agencies Regs. § 16-50j-40(a) requires that “[p]rior to submitting a petition for a declaratory ruling to theCouncil, the petitioner shall, where applicable, provide notice to each person other than the petitioner appearing ofrecord as an owner of property which abuts the proposed primary or alternative sites of the proposed facility, eachperson appearing of record as an owner of the property or properties on which the primary or alternative proposedfacility is to be located, and the appropriate municipal officials and government agencies [listed in Section 16-50l ofthe Connecticut General Statutes].”1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
with a capacity of not more than 65 MW, as long as the facility meets DEEP air and waterquality standards. The proposed Facility meets each of these criteria. The Facility is a“customer-side distributed resources” project, as defined in Conn. Gen. Stat. § 16-1(a)(40)(A),because the Facility is “a unit with a rating of not more than sixty-five megawatts [and islocated] on the premises of a retail end user within the transmission and distribution systemincluding, but not limited to, fuel cells” and, as demonstrated herein, will meet DEEP noise, airand water quality standards. In addition, as demonstrated above, the construction and operationof the Facility will not have a substantial adverse environmental effect in the State ofConnecticut.V.CONCLUSIONFor the reasons stated above, Bloom, as agent for Frontier, respectfully requests that theCouncil approve the location and construction of the Facility by declaratory ruling.Respectfully submitted,Bloom Energy CorporationBy:Justin AdamsBloom Energy Corporation1299 Orleans DriveSunnyvale, CA 94089Telephone: (408) 338-7452Email: justin.adams@bloomenergy.com1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
EXHIBITSExhibit 1:Site Location MapExhibit 2:Site PlanExhibit 3:Final Decision, PURA Docket No. 12-02-09, Petition of Bloom EnergyCorporation for a Declaratory Ruling that Its Solid Oxide Fuel Cell EnergyServer Will Qualify as a Class I Renewable Energy Source (Sept. 12, 2012)Exhibit 4:Meter interval data analysis conducted in 2016Exhibit 5:Bloom Energy Server Product Datasheet and General Installation OverviewExhibit 6:Emergency Response PlanExhibit 7:Site Location PhotosExhibit 8:FEMA Flood ZoneExhibit 9:Mei Wu Acoustics Noise Analysis and ReportExhibit 10:Notice Pursuant to Conn. Agencies Regs. § 16-50j-40(a)Exhibit 11:Abutters MapExhibit 12:Letter to Mayor and City Planner1299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
Exhibit 11299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
Job#:BEC-21222TMScale:Date:Drawn By:39 West StreetDanbury, CT 0681010/11/2016MDS1299 Orleans Drive, Sunnyvale CA, 94089Tel: 408 543 1500Fax: 408 543 150158 Mount Bethel Boulevard, Suite 301,Warren, NJ 07059Tel: (908) 462-9700 Fax: (908) 462-9909amueller@core-eng.comEXHIBIT 1 - SITE LOCATION MAPUSGS MAP (HARTFORD SOUTH)
Exhibit 21299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
User: MSOUSADrawing: I:\Bloom Energy\BEC-21230 - Fontier Danbury, CT\Drawings\BEC-21230 - Frontier (Danbury, CT) - 2.0 Site Plan.dwg ;Site PlanLast Modified: Nov. 10, 16 - 15:54Plot Date/Time: Nov. 10, 16 - 16:08:22DOCUMENTS PREPARED BY CORESTATES GROUP, INCLUDING THISDOCUMENT, ARE TO BE USED ONLYFOR THE SPECIFIC PROJECT ANDSPECIFIC USE FOR WHICH THEY WEREINTENDED. ANY EXTENSION OF USETO ANY OTHER PROJECTS, BY OWNEROR BY ANY OTHER PARTY, WITHOUTTHE EXPRESSED WRITTEN CONSENT OFCORE STATES GROUP IS DONEUNLAWFULLY AND AT THE USERS OWNRISK. IF USED IN A WAY OTHER THANTHAT SPECIFICALLY INTENDED, USERWILL HOLD CORE STATES GROUPHARMLESS FROM ALL CLAIMS ANDLOSSES.58 MOUNT BETHEL ROADSUITE 301WARREN, NJ 07059amueller@core-eng.com80SCALE01" 80'80FEET16010SCALE01" 10'10FEET20NEW CONSTRUCTION OFCLEAN ENERGY SERVERYANKEE GAS SERVICE COMPANYEVERSOURCESEALREV10-28-16 PRELIM. SUBMISSIONDATESHEET NUMBERDESCRIPTION111-07-16 PRELIM. SUBMISSION (REV 1)211-10-16 PARKING RESTRIPINGPROJECT INFORMATIONJOB #DATE:DRAWN BY:CHECKED BY:BEC-2123010-20-16MODELSHEET TITLESITE PLANMMDMDSPROPRIETARY & CONFIDENTIAL1252 Orleans Drive, Sunnyvale CA, 94089Tel: 408 543 1500Fax: 408 543 1501www.bloomenergy.comTM
Exhibit 31299 Orleans Drive, Sunnyvale CA 94089 T 408 543 1500 F 408 543 1501 www.bloomenergy.com
STATE OF CONNECTICUTDEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTIONPUBLIC UTILITIES REGULATORY AUTHORITYTEN FRANKLIN SQUARENEW BRITAIN, CT 06051DOCKET NO. 12-02-09PETITION OF BLOOM ENERGY CORPORATION FOR ADECLARATORY RULING THAT ITS SOLID OXIDE FUELCELL ENERGY SERVER WILL QUALIFY AS A CLASS IRENEWABLE ENERGY SOURCESeptember 12, 2012By the following Directors:Arthur H. HouseJohn W. Betkoski, IIIDECISIONI.INTRODUCTIONBy Petition dated February 14, 2012, pursuant to Section 4-176 in the GeneralStatutes of Connecticut (Conn. Gen. Stat.) and Section 16-1-113 in the Regulations ofConnecticut State Agencies, Bloom Energy Corporation requests that the Public UtilitiesRegulatory Authority (Authority) issue a declaratory ruling that its solid oxide fuel cellenergy server qualifies as a Class I renewable energy source.
Docket No. 12-02-09II.Page 2PETITIONER’S EVIDENCEBloom Energy Corporation (Bloom) has commercialized a scalable, modular fuelcell using Bloom’s patented solid oxide fuel cell (SOFC) technology. A fuel cell is adevice that uses a fuel and oxygen to create electricity by an electrochemical process. Asingle fuel cell consists of an electrolyte and two catalyst-coated electrodes (an anodecathode). Fuel cells are generally categorized by the type of electrolyte used. Petition,pp. 2 and 3.Each Bloom Energy Server consists of thousands of Bloom’s patented SOFCs.Each fuel cell is a flat, solid ceramic square capable of producing at least 25 watts. Inan energy server, Bloom “sandwiches” the SOFCs between metal interconnect platesinto a fuel cell “stack.” Bloom aggregates multiple fuel cell stacks together into a “powermodule,” and then multiple power modules, along with a common fuel input andelectrical output, are assembled as a complete energy server fuel cell. Id., p. 3.The Bloom Energy Server converts the chemical energy contained in fuel, suchas natural gas, into electricity at an efficiency of approximately 50% - 60% (lowerheating value net AC) without any combustion or multi-stage conversion loss. Fuelentering the energy server is processed using a proprietary catalytic method to yield areformate gas stream, and the gaseous product and preheated air are introduced intothe fuel cell stacks. Within the stacks, ambient oxygen reacts with the fuel to producedirect current (DC) electricity. The DC power produced by the energy server system isconverted into 480-volt AC power using an inverter, and delivered to the host facility’selectrical distribution system. Id.SOFCs operate at very high temperatures, obviating the need for expensivemetal catalysts. With low cost ceramic materials, and extremely high electricalefficiencies, SOFCs can deliver attractive economies without relying on combined heatand power. Id.Bloom Energy Servers are a fraction of the size of a traditional base load powersource, with each server occupying a space similar to that of a parking space. Thissmall, low-impact, modular form of base load power does not pose the environmentalchallenges associated with a traditional base load power plant, significantly reducingenvironmental impacts. Moreover, Bloom’s innovative design requires only an initialinput of 120 gallons of water per 100 kW, after which no additional water is consumedduring normal operation. Id., pp. 3 and 4.Bloom Energy Servers deliver significant environmental benefits overconventional base load technologies. In addition to significant CO2 reductions due to itshigh efficiency, the energy server emits virtually no NOx, SOx, or other smog formingparticulates since the conversion of gas to electricity in a Bloom Energy Server is donethrough an electrochemical reaction rather than combustion. Id., p. 4.
Docket No. 12-02-09III.Page 3AUTHORITY ANALYSISConn. Gen. Stat. §16-1(a)(26) defines a Class I renewable energy source as:(A) energy derived from solar power; wind power; a fuel cell;methane gas from landfills; ocean thermal power; wave ortidal power; low emission advanced renewable energyconversion technologies; a run-of-the-river hydropowerfacility provided such facility has a generating capacity of notmore than five megawatts, does not cause an appreciablechange in the river flow, and began operation after theeffective date of this section; or a biomass facility, including,but not limited to, a biomass gasification plant that utilizesland clearing debris, tree stumps or othe
kW Fuel Cell Customer Side Distributed Resource at 39 West Street, Danbury, CT 06810 . Dear Chairman Stein: We are submitting an original and fifteen (15) copies of the above-captioned Petition, together with the filing fee of 625. In the Petition, Bloom Energy Corporation ("Bloom"), as agent for Frontier Communications
