RE:Ciro One in trouble??? 7-2019. In its Motion in Compliance with Order, in the case file NEPR-AP-2020- 0008, PREPA admits regarding the CIRO One Salinas and Xzerta projects that, “neither the prices presented by the producers, nor the interconnection costs will translate into savings for consumers ”.7 The energy purchase prices in the contract would increase the cost of energy to PREPA's subscribers and do not comply with the projections of the Certified Fiscal Plan for the entity in 2020, as highlighted by the Financial Supervision and Administration Board itself for Puerto Rico (hereinafter, the “Board”). 8 The Certified Fiscal Plan presumes prices of 8 c / kWh in fiscal year 2023, until increasing to 9.7 c / kWh in 2049. However, the agreement approved by PREPA includes purchase prices of 9.85 c / kWh, increasing at a rate of 2% per year, until reaching 14.1 c / kWh. Worse, in addition to exceeding the Board's expectation, the prices are above the cost of renewable energy on the market. It highlights the fact that PREPA has not even carried out a competitive auction process from which the real cost in the market can be inferred and that its own estimates reflect values below those agreed for this project. When negotiating the contract for the non-operational CIRO One Salinas project, PREPA did not adequately assess what would be the impacts of an increase in the rate to the subscribers of this project in conjunction with the other 15 projects in controversy. The renegotiation and the wrong analysis of the contract does not protect the subscribers against future increases in the electricity rate. According to PREPA's Petition, the Ciro One project requires the construction of 3.51 miles of a 115kv transmission line and, in addition, will require a new right of way (right ofway) of 100 'x 100' and other new infrastructure at a cost of $ 8.1 million, which PREPA would have to reimburse to the designer.9
The appearing parties do not have other legal means to protect their interests, for which they request the intervention or participation in this procedure, including the ability to provide expert testimony, carry out discovery of evidence and cross-examine the witnesses of PREPA, CIRO One, among other entities, to ensure that the interests of its memberships are adequately protected. As if that were not enough, much of the discussion around this project has taken place without any transparency. If the contract is approved, it not only perpetuates a centralized generation system continuously impacting the communities, but it would be carried out by damaging the rights of access to information and timely and effective participation in government decision-making processes. Participating in this procedure is the only way for the auditors to protect their interests. ii. Your interests are not adequately represented by the parties to this proceeding None of the parties to the proceeding represents or can represent the interests of the appearing parties, particularly in terms of their environmental, energy and agricultural interests. They have unique and specific interests related to the proximity and impacts to water sources of the non-operational project that is the object of this procedure. iii. Your participation will reasonably help prepare a more complete record in this proceeding. Because the appearing parties are or represent community groups, environmentalists, agriculturalists and citizens, their full participation as interveners or participants will lead to a significantly better representation of public input in the final file of this 9 Sargent and Lundy, Solar PPOA Interconnection Summary Report, June 11, 2020, p. 36, Exhibit D at PREPA's request.