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MotiontoExtendConstructionStartDeadline_July31_2013(CaseNo.9164)

MotiontoExtendConstructionStartDeadline_July31_2013(CaseNo.9164)

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Published by ztower
Motion of Dan’s Mountain Wind Force, LLC to Extend Construction Start Deadline for Industrial Wind Facility
Motion of Dan’s Mountain Wind Force, LLC to Extend Construction Start Deadline for Industrial Wind Facility

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Categories:Types, Business/Law
Published by: ztower on Aug 21, 2013
Copyright:Attribution Non-commercial

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06/26/2014

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BEFORE THEPUBLIC SERVICE COMMISSIONOF MARYLANDMOTION OF DAN’S MOUNTAIN WIND FORCE, LLCTO EXTENDCONSTRUCTION START DEADLINE
Dan’s Mountain Wind Force, LLC (“Dan’s Mountain” or the “Applicant”) herebyrespectfully moves to extend the September 12, 2013 deadline for the start of construction setforth in the Commission’s September 4, 2012 Letter Order (the “Letter Order”) in this proceeding to December 31, 2014—an additional extension of approximately sixteen months.
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Dan’s Mountain is
not 
seeking an extension of the deadline to have at least one functioning windturbine in place by September 12, 2015.On March 12, 2009, in granting Dan’s Mountain’s application for an exemption from thecertificate of public convenience and necessity (“CPCN”) requirement for a 69.6 MW windgeneration facility to be constructed in Allegany County, Maryland (the “Project”), theCommission imposed certain conditions, including a start of construction deadline of March 12,
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The requested additional extension actually is fifteen and one-half months, but for conveniencethis motion will refer to the extension as sixteen months.
IN THE MATTER OF THE APPLICATIONOF DAN’S MOUNTAIN WIND FORCE, LLCFOR A CERTIFICATE OF PUBLICCONVENIENCE AND NECESSITY TOCONSTRUCT A 69.6 MW WINDGENERATION FACILITY IN WESTERNALLEGANY COUNTY, MARYLAND ________________________________  ______________ CASE NO. 9164 ______________ 
 
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2012. The Letter Order granted Dan’s Mountain’s motion to extend that original constructionstart deadline.As detailed in the Affidavit of David K. Friend, the Manager of Dan’s Mountain (“
 Friend  Affidavit 
”), during that extension period Dan’s Mountain encountered long and unexpecteddelays beyond its control, associated with the declining financial condition and eventual descentinto bankruptcy of its joint developer/investor Edison Mission Energy (“Edison”). Given therestrictions in Dan’s Mountain’s agreements with Edison, it was necessary for Dan’s Mountainto extricate itself from those agreements before moving forward.
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Edison, however, did notcooperate in unwinding the relationship.Dan’s Mountain has now entered into agreements with Exelon Wind, LLC, a subsidiaryof Exelon Corporation (Exelon Wind and Exelon Corporation referred to hereinafter a “Exelon”)that provide critical development support and funding. With Exelon’s assistance, Dan’sMountain is diligently pursuing the development of the Project. We respectfully request that theCommission grant the instant motion because, absent such relief, the State of Maryland will notrealize the recognized benefits of a substantial, new, renewable wind generation resource.
I
.
BACKGROUND ANDINTRODUCTION
On November 5, 2008, Dan’s Mountain filed an application, pursuant to § 7-207.1 of thePublic Utility Companies Article, Annotated Code of Maryland, for an exemption from theCPCN requirement for the Project. On March 12, 2009, the Commission issued the Letter Order granting the application, subject to a number of conditions. Among the conditions was the
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It was also necessary to obtain new sources of funding to support additional necessary pre-construction development activities.

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