AT Note:  The following letter was submitted to the Mineral County (West Virginia) Commission for consideration at the January 11, 2011 review of the decommission study prepared by GL Garrad Hassan (1), consultant for the Pinnacle Wind Farm project.

Unable to attend, I asked a friend to read it into the record.  It is my understanding that President Commissioner Cindy Pyle did not permit the reading.  It is my hope that the Commissioners will review the concerns I raise regarding seriously understated transportation costs before they accept the Hassan decommission study.

The results of the study, in its present form, heavily favor the position of the developer, US WindForce and, unless corrective action is taken by the Commissioners, the citizens they represent will potentially be on the hook for hundreds of thousands of dollars.

Date:  January 10, 2011

To:  Mineral County Commissioners (via Mineral County Clerk)

Subject:  Pinnacle Decommission Study – transportation of major components.

I am unable to attend the Commission meeting scheduled for January 11, 2010.  Please enter this submission into the public record for the purpose of challenging the decommission study prepared by G.L. Garrad Hassan.

• Since it appears US WindForce does not have responsibility to determine the model or brand of turbine and, lacking a shipping list with weights and dimensions, I cannot determine accurate shipping cost for major items.
  • My 25 years in the transportation/project/manufacturing business does, however, lead me to believe that the estimate provided by GL Garrad Hassan is considerably off the mark, if, as stated by GLGH, the “more complex and valuable material is assumed to be transported within a radius of 500 miles.” (e.g.: blades, hubs, nacelles and tower sections)
  • It is my belief that the per-mile estimate of $3.00 or $4.50 per mile for these major components is flat wrong, and terribly misleading.
  • Estimating heavy lift/overweight/over dimensional cargo on a per-mile basis could, in my opinion, easily cause the estimate of $361,500 for transportation of these components to be off by a factor of 5 or, likely, more.
• Nacelles:
  • Based on industry averages, I would imagine each nacelle to weigh in the neighborhood of 180,000 lbs.
  • I suspect the dimensions are outside of standard shipping dimensions, as well.
  • This excessive weight will require use of a specialized trailer to transport each nacelle to its destination, which again, GLGH allows as anywhere within a 500 mile radius.
  • To presume this can be achieved for a mere $1,500 dollars each is, in my estimation, ludicrous.
• Hubs:
  • It is suggested by GLGH that the hub sections can be shipped in sets of 2.
  • Most, if not all states have laws restricting shippers to land only one overweight piece to a deck and further, the shipper cannot combine pieces that will increase the weight beyond a legal weight limit.
    • Again, not knowing the weight of each hub, but suspecting each may near 25,000 lbs., I believe the hubs must will be required to ship in single units.
• Blades:
  • The same is perhaps true of shipping the blades in sets of 2.
  • Again, I don’t know if the pair will exceed legal weight limits.
  • But, even if the weight of the blade set were light enough to meet weight requirements to ship in pairs, most, if not all states will not permit shippers to combine components which will extend the length or width creating an unnecessary out of legal dimension load.
  • Also, the length of the blades will presumably call for special stretch deck equipment.
  • I believe it likely the blades will ship one per truck.
• Tower sections:
  • The tower sections utilized for most brands are also of considerable weight and length.
  • It is my belief that, at minimum, specialized multi-axle equipment will be required to transport these sections.
  • I believe the cost to transport the individual tower sections to any point within a 500 mile radius will far exceed the $2,250 estimated in the study.
• Conclusion:
  • It is my belief that the GLGH estimate of $361,500 could easily be understated by a factor of 5, and likely, considerably more.
• Resolution:
  • The Mineral County Commissioners, for the sake of reasonable escrow funding, should require US WindForce to take one of the two, easily accomplished, actions to determine a more accurate transportation cost for these few major components.
    • Break out the transportation estimate section pertaining to these components from the original cost roll up of the project.

or,

• • • Request a quotation from an experienced heavy hauler (Specialized Carrier and Rigger Association – scranet.org will provide a list of carriers, by region)
  • Either could be completed within days of the request, not delaying the project by weeks or months.
• Asides:
  • I’m familiar with the major specialized carriers equipped to haul this cargo.
  • I am not convinced any of these carriers would move this equipment from Green Mountain to a point within 500 miles for the costs estimated.
  • If, in fact, GLGH can provide a qualified carrier who will do so, I have a number of clients who would secure the carrier’s services.
• Supplemental Note:  If it is suggested that rail might be used to reach the estimated costs in the study, be sure to consider these issues:

• Clearance limitations become very restrictive as cargo moves east.
• Severe limitations in height and width preclude rail shipment through/in the Shared Asset area affecting a large portion of PA, NJ and NY ports/destinations.
• Unless there is rail service under hook at origin and destination, it will be necessary to:

1.      Truck transport to near siding at origin, load and secure to specialized rail car

2.      Rail transport to near siding at destination within 500 miles

3.      Unload and clear rail car at near siding, truck transport to under hook at final destination.

• In my opinion, even a base rail transport cost (2) (when labor and materials for securing/removal to/from rail car are included), will far exceed quoted transport cost, notwithstanding the other activities listed in (1) and (3), if necessary.

It is my belief that, once real transportation costs are considered, the $35,000 “profit” (scrap recovery v decommission cost) touted by US WindForce in the press will not only evaporate, but turn dramatically negative.  Further, if my suspicion regarding transportation cost is, in fact, confirmed, it would demand that the Commissioners require further evaluation of the entire decommission study by a credible second source.

Thank you,

Michael C. Morgan

Keyser, WV

(1)  Decommission Study: