20240531Direct T. Hemstreet - Redacted.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. PAC-E-24-04
OF ROCKY MOUNTAIN POWER FOR )
AUTHORITY TO INCREASE ITS RATES ) DIRECT TESTIMONY OF
AND CHARGES IN IDAHO AND ) TIMOTHY J. HEMSTREET
APPROVAL OF PROPOSED ) REDACTED
ELECTRIC SERVICE SCHEDULES AND )
REGULATIONS )
ROCKY MOUNTAIN POWER
CASE NO. PAC-E-24-04
May 2024

1 I . INTRODUCTION AND QUALIFICATIONS
2 Q. Please state your name, business address, and present
3 position with PacifiCorp d/b/a Rocky Mountain Power (the
4 "Company") .
5 A. My name is Timothy J. Hemstreet. My business address is
6 825 NE Multnomah Street, Suite 1800, Portland, Oregon
7 97232 . My present position is Vice President of
8 Renewable Energy Development for PacifiCorp.
9 Q. Briefly describe your education and business experience.
10 A. I hold a Bachelor of Science degree in Civil Engineering
11 from the University of Notre Dame in Indiana and a Master
12 of Science degree in Civil Engineering from the
13 University of Texas at Austin. I am also a Registered
14 Professional Engineer in the State of Oregon. Prior to
15 joining the Company in 2004, I held positions in
16 engineering consulting and environmental compliance.
17 Since joining the Company, I have held positions in
18 environmental policy, engineering, project management,
19 and hydroelectric project licensing and program
20 management . In 2016, I assumed a role in renewable energy
21 development, and in June 2019 I assumed a role focusing
22 on PacifiCorp' s wind repowering effort, and assumed my
23 current role in September 2022, in which I oversee the
24 development of renewable energy resources that enhance
25 and complement PacifiCorp' s existing renewable energy
Hemstreet, Di 1
Rocky Mountain Power

1 resource portfolio .
2 Q. Have you testified in previous regulatory proceedings?
3 A. Yes . I have previously sponsored testimony in Idaho,
4 California, Oregon, Utah, Washington, and Wyoming.
5 II . PURPOSE OF TESTIMONY
6 Q. What is the purpose of your direct testimony?
7 A. The purpose of my testimony is to demonstrate the
8 prudency of the Company' s efforts to acquire and repower
9 the Foote Creek II, III and IV ("Foote Creek II-IV") and
10 Rock River I wind energy facilities (collectively, the
11 "Projects") , similar to the effort undertaken previously
12 at the Company' s Foote Creek I wind facility, for which
13 cost recovery was approved in the Company' s last general
14 rate case. ' My testimony provides detail on the Company' s
15 commercial and other arrangements related to the
16 Projects, and explains their customer benefits .
17 Specifically, my testimony addresses :
18 0 the background of the Projects;
19 0 the scope of the repowering effort and the
20 Project' s relationship to the Company' s earlier
21 repowering efforts;
22 0 the contracting arrangements, implementation
23 status, permitting status, and schedule for the
24 Projects;
25 0 the energy benefits of the Projects;
26 0 the financial benefits for customers of repowering
27 resulting from production tax credit ("PTC")
' In the Matter of Rocky Mountain Power's Application for Authority to
Increase its Rates and Charges in Idaho and Approval of Proposed Electric
Service Schedules and Regulations, Case No. PAC-E-21-07, Order No. 35277
(Dec. 30, 2021) .
Hemstreet, Di 2
Rocky Mountain Power

1 qualification of the Projects; and
2 the evaluation of the Projects in the 2021
3 Integrated Resource Plan ("IRP") .
4 III . SUMMARY OF TESTIMONY
5 Q. Please summarize your testimony.
6 A. In March 2021, PacifiCorp completed a significant effort
7 to repower the entirety of its owned wind fleet that was
8 originally constructed before 2011, including the Foote
9 Creek I facility. These repowered facilities are now
10 delivering enhanced value and long-term customer
11 benefits . The Company is pursuing additional benefits
12 for customers by acquiring and repowering additional
13 wind facilities adjacent to the Company' s Foote Creek I
14 facility in Carbon County, Wyoming, at the Foote Creek
15 II-IV and Rock River I wind projects . These Projects
16 will allow the Company to leverage existing long-term
17 wind energy lease rights, facilities, and infrastructure
18 in the local area (including staff and contractor
19 resources) that will provide customers with benefits
20 from these cost-effective, high-capacity-factor wind
21 energy resources .
22 Acquiring and repowering the Projects is consistent
23 with the Company' s 2021 and 2023 IRPs, that identified
24 both Projects as beneficial to customers and included
25 their repowering in the Company' s least-cost, least risk
Hemstreet, Di 3
Rocky Mountain Power

1 preferred portfolio .2 The Company obtained the required
2 certificates of public convenience and necessity
3 ("CPCNs") for both Projects from the Wyoming Public
4 Service Commission ("Wyoming Commission") . 3 Construction
5 at Foote Creek II-IV began in the summer of 2022, and
6 the project reached commercial operation in November
7 2023 . Construction of Rock River I began in the spring
8 of 2023 with commercial operation on track for late 2024 .
9 IV. WIND REPOWERING PROJECT BACKGROUND, SCOPE, AND
10 RELATION TO PRIOR REPOWERING PROJECTS
11 Q. Please explain the background of the Foote Creek II-IV
12 and Rock River I wind energy projects .
13 A. The Foote Creek Rim wind energy projects, consisting of
14 Foote Creek I, II, III and IV, were the first utility-
15 scale, commercial wind energy projects in the state of
16 Wyoming. The projects are located at Foote Creek Rim due
17 to the extraordinary combination of geography and wind
18 energy resource at the site that causes already robust
19 winds to accelerate as they move over the elevated
2 In re PacifiCorp 2021 Integrated Resource Plan, at 295, 323
(https://www.pacificorp.com/energy/integrated-resource-plan.html) ; In re
PacifiCorp 2023 Integrated Resource Plan, at 307
(https://www.pacificorp.com/energy/integrated-resource-plan.html) .
3 In re Application of RMP for a Certificate of Public Convenience and
Necessity to Construct New Wind Turbines and Update Collector Lines at
the Existing Foote Creek II-IV Wind Energy Facility, Docket No. 20000-
606-EN-21 (Record No. 16955) ; In re Application of RMP for a Certificate
of Public Convenience and Necessity to Construct New Wind Turbines and
Update Collector Lines at the Existing Rock River I Wind Energy Facility,
Docket No. 20000-613-EN-22 (Record No. 17017) .
Hemstreet, Di 4
Rocky Mountain Power

1 plateau of the Foote Creek Rim. Development of wind
2 energy facilities to take advantage of these favorable
3 wind energy characteristics began in the early 1990s,
4 and construction of the Foote Creek Rim projects was
5 completed between 1999 and 2000 . The Rock River I wind
6 project is located approximately five miles northeast of
7 the Foote Creek Rim projects and four miles northwest of
8 the High Plains and McFadden Ridge projects . Rock River
9 I was developed shortly after the Foote Creek Rim
10 projects and reached commercial operation in October
11 2001 . Rock River I was similarly developed adjacent to
12 the Foote Creek Rim due to these similar favorable wind
13 energy resource characteristics .
14 PacifiCorp participated in wind energy development
15 at the Foote Creek Rim site in partnership with the
16 Eugene Water & Electric Board ("EWEB") and the
17 Bonneville Power Administration ("BPA") . PacifiCorp and
18 EWEB were co-owners of the Foote Creek I wind energy
19 facility that reached commercial operation in 1999, and
20 BPA purchased a portion of the project' s output.
21 PacifiCorp acquired full ownership of the Foote Creek I
22 project in 2019 and completed repowering of the project
23 in March 2021 . The Foote Creek II-IV wind energy
24 facilities, which were previously owned by Terra-Gen,
25 LLC ("Terra-Gen") , were independently developed and
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Rocky Mountain Power

1 their generation output was sold to other utilities
2 under power purchase agreements . The Foote Creek II-IV
3 projects were constructed with 64 wind turbines (of
4 which 33 turbines had a nameplate capacity of 0 . 6
5 megawatt ("MW") each and 31 turbines had a nameplate
6 capacity of 0 . 75 MW) with a total nameplate capacity of
7 43 . 35 MW.
8 Rock River I was constructed with 50 wind turbines
9 (each turbine with a nameplate capacity of one megawatt)
10 with a total nameplate capacity of 50 MW. Rock River I
11 was previously co-owned by Terra-Gen and Shell Wind
12 Energy Inc. ("Shell") and its output was sold to the
13 Company under a 20-year power purchase agreement that
14 expired in December 2021 . The Rock River I project
15 interconnects to the Company' s transmission system at
16 the Foote Creek Substation.
17 Q. What does it mean to repower a wind energy facility?
18 A. Repowering a wind energy facility means upgrading the
19 wind turbine generator ("WTG") equipment at an existing
20 wind energy project with more efficient equipment to
21 increase the power generation from the facility and
22 extend the life of the facility. Specifically,
23 repowering Foote Creek II-IV and Rock River I involves
24 installing new turbines while reusing other pre-existing
25 facility infrastructure .
Hemstreet, Di 6
Rocky Mountain Power

1 Q. Please briefly describe PacifiCorp' s effort to repower
2 the Foote Creek II-IV and Rock River I facilities .
3 A. Similar to the Company' s effort to repower its
4 neighboring Foote Creek I facility, repowering of the
5 Projects involves installing modern WTGs .
6 At Foote Creek II-IV, the repowering effort
7 involved installing 11 new WTGs of the same type recently
8 installed at Foote Creek I to replace the older wind
9 turbines of much smaller capacity that were previously
10 at the site . Similarly, the Rock River I repowering
11 effort will install 19 new WTGs to replace the smaller
12 capacity turbines originally at the project.
13 The new WTGs at the Projects will be supported on
14 new foundations and connected to the Foote Creek
15 Substation with new energy collector circuits . The
16 turbines will have updated switchgear and controls, and
17 the new WTG locations will be linked by new turbine
18 access roads . The proposed site layout for the Foote
19 Creek II-IV repowering effort is shown in Exhibit No. 36
20 and the Rock River I site layout is shown in Exhibit No .
21 37 .
22 Q. Will the Projects benefit from PacifiCorp' s prior
23 efforts to repower the adjacent facilities?
24 A. Yes . As part of the Foote Creek I repowering effort, the
25 Company obtained the master wind energy lease rights for
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Rocky Mountain Power

1 the entire Foote Creek Rim site, encompassing the
2 original Foote Creek I, Foote Creek II, Foote Creek III,
3 and Foote Creek IV wind energy project boundaries . These
4 rights were acquired in August 2019 and their
5 acquisition enhanced the customer benefits of the Foote
6 Creek I repowering project by reducing the ongoing land
7 rights cost of the project . Similarly, repowering the
8 Foote Creek II-IV facilities will allow customers to
9 fully benefit from these wind energy lease rights, which
10 provide the ability to cost-effectively generate power
11 at one of the most favorable wind energy locations in
12 Wyoming. Acquiring the Foote Creek II-IV facilities
13 allowed the Company to nearly double the number of modern
14 turbines it operates at the Foote Creek Rim, increasing
15 operations and maintenance efficiencies associated with
16 current operations at the repowered Foote Creek I
17 facility.
18 The Rock River I facility will benefit from the
19 Company' s recent repowering effort at the nearby High
20 Plans and McFadden Ridge projects, utilizing operations
21 and maintenance staff contracted for that project to
22 also operate the Rock River I facility. Thus, no
23 additional operations facilities are needed to support
24 project operations . Some project controls will also be
25 housed at the Company' s Foote Creek operations and
Hemstreet, Di 8
Rocky Mountain Power

1 maintenance building, which is nearby the Foote Creek
2 Substation, where Rock River I will interconnect to the
3 transmission system. This local infrastructure results
4 in efficiencies and cost savings for the project since
5 it can draw on existing infrastructure as well as Company
6 staff and contractor resources .
7 Q. Are there other ways in which Foote Creek II-IV will
8 benefit from PacifiCorp' s prior repowering effort at
9 Foote Creek I?
10 A. Yes . The Foote Creek I repowering project required
11 access road upgrades to the Foote Creek Rim plateau to
12 allow larger, modern wind turbine equipment to be
13 delivered to the site. These improvements were also used
14 for the Foote Creek II-IV facilities, and the enclosed
15 switchgear building constructed adjacent to the Foote
16 Creek Substation as part of the Foote Creek I repowering
17 project is being used for equipment that will support
18 the repowered project, reducing costs . Finally, the
19 Foote Creek II-IV facilities will be operated from the
20 Company' s existing operations and maintenance building
21 for the Foote Creek I project, so no additional
22 facilities are needed for project operations .
Hemstreet, Di 9
Rocky Mountain Power

1 Q. Will the larger blades from the new turbines increase
2 the potential for avian impacts at the repowered
3 facilities?
4 A. Monthly monitoring conducted at the Projects over the
5 last several years shows no significant avian impacts .
6 Although the larger blades and greater rotor-swept area
7 will increase the overall risk zone of the repowered
8 wind turbines, this does not necessarily correlate with
9 an increased risk of avian impacts . The significant
10 reduction in the number of turbines that will be deployed
11 at the site also means that less of the overall project
12 site area will be covered by wind turbines . To further
13 mitigate any potential impacts, at both the Foote Creek
14 II-IV and Rock River I projects, new turbine locations
15 have been sited to avoid areas of higher avian use such
16 as the edges of the plateaus .
17 The Company also performs monthly monitoring at all
18 Company-owned Wyoming wind facilities and reports to
19 both the Wyoming Game and Fish Department and the U. S .
20 Fish and Wildlife Service. Once repowering concludes,
21 the Company will begin this monthly monitoring at the
22 Projects to determine if the new turbines cause
23 additional impacts to avian species and will engage with
24 the appropriate agency to discuss and, if prudent and
25 practicable, implement additional avoidance,
Hemstreet, Di 10
Rocky Mountain Power

1 minimization, or mitigation measures . In addition, the
2 Company continues to coordinate with both the Wyoming
3 Game and Fish Department and the U. S . Fish and Wildlife
4 Service on the Project, including the development of an
5 Eagle Conservation Plan and Bird and Bat Conservation
6 Strategy for the new turbines .
7 V. WIND REPOWERING PROJECT CONTRACTING, PERMITTING
8 STATUS, SCHEDULE, AND COST
9 Q. What commercial arrangements has PacifiCorp made to
10 acquire and repower the Projects?
11 A. For Foote Creek II-IV, in addition to the earlier
12 acquisition of the master wind energy lease rights for
13 the project site, PacifiCorp executed a Purchase and
14 Sale Option Agreement ("PSOA") with Terra-Gen to acquire
15 100 percent of its interests in the Foote Creek II, III
16 and IV facilities . Pursuant to the PSOA, Terra-Gen
17 removed the original 64 turbines from the site and
18 completed site restoration activities in preparation for
19 repowering of the facility by the Company. The Company
20 closed on the acquisition of the facilities pursuant to
21 the PSOA in June 2022, following the approval of the
22 Company' s CPCN application by the Wyoming Commission.
23 For Rock River I, the Company negotiated a PSOA
24 with Terra-Gen and Shell to acquire 100 percent of their
25 interests in the Rock River I facility including the
Hemstreet, Di 11
Rocky Mountain Power

1 project' s wind energy lease rights, transmission and
2 access easements, and interconnection agreement.
3 Pursuant to the PSOA, Terra-Gen and Shell removed the
4 original 50 turbines from the site and completed site
5 restoration activities in preparation for repowering of
6 the site by the Company. The Company closed on the
7 acquisition of the facilities pursuant to the PSOA in
8 February 2023, and shortly thereafter issued a Full
9 Notice to Proceed to the construction contractor. The
10 Company began repowering construction activities in the
11 spring of 2023, in support of a late 2024 in-service
12 date for the project .
13 Q. What other commercial arrangements has PacifiCorp made
14 with respect to the Projects?
15 A. For Foote Creek II-IV, the Company executed a master
16 supply agreement and a turbine supply agreement for the
17 repowering turbines with Vestas-American Wind Energy,
18 Inc. ("Vestas") in which Vestas will supply and
19 commission WTGs suitable for the site of the same type
20 used at the Foote Creek I facility. The Company has also
21 executed a contract for balance of plant ("BOP") wind
22 energy construction services following a competitive
23 procurement process in which proposals from qualified
24 wind energy construction companies were solicited. The
25 Company has also executed a turbine service and
Hemstreet, Di 12
Rocky Mountain Power

1 maintenance agreement with Vestas, which will provide
2 service for the repowered turbines consistent with
3 negotiated pricing and terms .
4 For Rock River I, the Company executed a safe harbor
5 purchase agreement and a turbine supply agreement with
6 General Electric International, Inc. ("'GE") in which GE
7 will supply and commission WTGs suitable for the site.
8 The Company has also executed a BOP wind energy
9 construction services contract. The Company has also
10 executed a full-service agreement with GE under which GE
11 will maintain the repowered turbines consistent with
12 negotiated pricing and terms .
13 Q. What is the status of necessary permitting to begin
14 construction of the repowering projects?
15 A. For both Projects, the Company has received the
16 necessary Federal Aviation Administration no-hazard
17 determinations to install the larger new turbines at the
18 site . The Company has also received Conditional Use
19 Permits for the repowering efforts from Carbon County,
20 Wyoming. The Company has received building permits from
21 Carbon County for both the Foote Creek II-IV and Rock
22 River I .
23 Q. What is the anticipated construction schedule for the
24 Projects?
25 A. For Foote Creek II-IV, the Company began construction in
Hemstreet, Di 13
Rocky Mountain Power

1 the summer of 2022, and turbine delivery and
2 commissioning activities occurred in summer and fall of
3 2023 . Foote Creek II-IV achieved commercial operation in
4 November 2023 . Major Project milestones for Foote Creek
5 II-IV are shown below:
6 Milestone Completion Date
7 Wyoming CPCN Approval April 2022
8 Project Acquisition June 2022
9 Construction Mobilization June 2022
10 Turbine Foundation Completion September 2022
11 Access Road Completion April 2023
12 Complete Turbine Deliveries June 2023
13 Mechanical and Electrical Completion October 2023
14 Commercial Operation November 2023
15 Final Completion/Site Restoration July 2024
16 (Anticipated)
17 For Rock River I, the Company began construction in
18 the spring of 2023, with foundations and access roads
19 the focus of efforts in 2023 and turbine delivery,
20 installation and commissioning activities occurring in
21 2024 . The Rock River I project is anticipated to be fully
22 online and serving customers in December 2024 . Major
23 Project milestones are indicated below:
24 Milestone Completion
25 Date
26 Wyoming CPCN Approval September 2022
27 Project Acquisition February 2023
28 Construction Mobilization May 2023
29 Turbine Foundation Completion September 2023
30 Access Road Completion April 2024
31 Complete Turbine Deliveries June 2024
32 (anticipated)
33 Mechanical and Electrical Completion September 2024
34 (anticipated)
35 Commercial Operation November 2024
Hemstreet, Di 14
Rocky Mountain Power

REDACTED
1 (anticipated)
2 Final Completion/Site Restoration July 2025
3 (anticipated)
4 Q. What is the construction status of Foote Creek II-IV?
5 A. At Foote Creek II-IV, major construction activities are
6 complete, and the project reached commercial operation
7 on November 21, 2023, and the new turbines are operating
8 and providing energy for customers. Remaining
9 construction activities consist of interconnection
10 improvements within the Foote Creek Substation and site
11 restoration activities that will be completed in summer
12 2024 .
13 Q. What is the construction status of Rock River I?
14 A. Construction at Rock River I began in the spring of 2023
15 and turbine foundations were completed in the fall of
16 2023. Access roads are fully complete and prepared to
17 receive turbine deliveries that will begin in May 2024 .
18 Turbine assembly by the balance of plant contractor will
19 begin thereafter and the project is anticipated to be in
20 commercial operation in November 2024 . Similar to Foote
21 Creek II-IV, site restoration activities will be
22 completed in the following summer, when conditions are
23 amenable for revegetation of construction laydown areas .
24 Q. What is the cost of the Projects?
25 A. The cost of acquiring and repowering the Foote Creek II-
26 IV facilities was on a total-Company
Hemstreet, Di 15
Rocky Mountain Power

REDACTED
1 basis, which is on a Idaho-allocated basis .
2 The cost of acquiring and repowering the Rock River I
3 facility is estimated at on a total-
4 Company basis, which is on an Idaho-
5 allocated basis.
6 Q. Does the acquisition and repowering of the Projects
7 benefit customers?
8 A. Yes . Acquisition and repowering of the Foote Creek II-
9 IV and Rock River I projects will result in significant
10 benefits for customers as a result of the energy and PTC
11 benefits of the project, as more fully detailed in the
12 direct testimony of Company witness Mr. Thomas R. Burns .
13 VI . WIND REPOWERING BENEFITS INCLUDING REQUALIFICATION FOR
14 PRODUCTION TAX CREDITS
15 Q. What benefits will customers realize from the Projects
16 once repowered?
17 A. Given the extraordinary wind resource in the area, the
18 Projects will provide significant energy benefits to
19 customers: the Foote Creek II-IV facilities are
20 estimated to have a high net capacity factor of ■
21 percent, and the Rock River I facility is estimated to
22 provide a similarly high net capacity factor of ■
23 percent. These high net capacity factors allow the
24 facilities to contribute to system capacity needs .
Hemstreet, Di 16
Rocky Mountain Power

1 Q. Will the repowered Projects qualify for PTCs?
2 A. Yes . Repowering will requalify both Projects for PTCs,
3 which will be passed on to the Company' s customers .
4 Q. What is the value of the PTC for the Projects?
5 A. For 2024, the value of the federal PTC is 2 . 9 cents per
6 kilowatt-hour, or $29 per megawatt-hour. This PTC value
7 is adjusted annually based upon an inflation index, and
8 the PTC is available for energy produced during the 10-
9 year period after the wind facility begins commercial
10 operation. Pursuant to the Inflation Reduction Act of
11 2022, the Projects are expected to qualify for 110
12 percent of the value of the federal PTC given the
13 location of the projects in Carbon County, which is
14 expected to meet the definition of an "energy community"
15 under the law. Location in an "energy community"
16 increases the PTC value from 100 percent to 110 percent
17 under the Inflation Reduction Act .
18 Q. Are there other requirements that the repowered Projects
19 must satisfy to qualify for the PTC?
20 A. Yes, the repowered Foote Creek II-IV and Rock River I
21 projects must be in service before the end of 2025 and
22 2026, respectively, to meet the IRS continuous efforts
23 safe harbor and qualify for the PTC by completing
24 construction within four calendar years . Because
25 repowering at the Projects will not incorporate retained
Hemstreet, Di 17
Rocky Mountain Power

1 components from the existing wind turbines at the site
2 there are no requirements related to the Internal
3 Revenue Service "80/20" test - a test that was applicable
4 to the repowering of the majority of PacifiCorp' s wind
5 fleet in which the foundations and towers were retained. 4
6 Q. Will repowering increase the overall generating capacity
7 of the Projects?
8 A. No . The existing Foote Creek II - IV, and Rock River I
9 interconnections will be fully used but the generating
10 capacity of the Projects is not expected to be expanded
11 as a result of repowering. The wind turbine equipment
12 that will be used at the Projects has been optimized to
13 make full use of the existing interconnection capacities
14 and the Company has not factored into its analysis of
15 the project an increase in interconnection capacity.
16 Q. What is the anticipated generation that the Projects
17 will produce?
18 A. The Company retained the engineering consulting firm
19 Black & Veatch, Inc. ("Black & Veatch") to evaluate the
20 energy production expected from the Projects . To
21 complete this assessment, Black & Veatch used site wind
22 data, wind turbine location data, operational
23 performance data, and other available site-specific
4 Internal Revenue Service Notice 2016-31, § 6 (May 5, 2016) (available
here: https://www.irs.gov/pub/irs-drop/n-16-31.pdf ) .
Hemstreet, Di 18
Rocky Mountain Power

REDACTED
1 information to model the expected generation from the
2 Projects . The wind model also evaluated generation
3 losses resulting from the wake losses at each turbine
4 location. Wake losses are the reduction in generation at
5 turbines downwind of other turbines due to reduced wind
6 speed and increased turbulence in the airflow—or wake-
7 behind a turbine. At Foote Creek II-IV, completion of
8 the project is estimated to result in annual energy
9 production of _ gigawatt-hours ("GWh") , resulting in
10 a high net capacity factor of ■ percent. At Rock River
11 I, the estimated annual energy production of the
12 facility is expected to be GWh after repowering,
13 resulting in a high net capacity factor of ■ percent.
14 In total, the repowered Projects will produce an amount
15 of energy used by the equivalent of nearly 42, 000 homes .
16 The technical analysis documenting the expected
17 generation from the Projects is provided in Confidential
18 Exhibit No . 38 and Confidential Exhibit No . 39 .
19 VII . REVIEW OF WIND REPOWERING PROJECTS IN THE IRP
20 Q. Were the Projects reviewed as part of the Company' s 2021
21 IRP?
22 A. Yes . The Projects were made available as a potential
23 resource that could meet customer energy needs in the
Hemstreet, Di 19
Rocky Mountain Power

1 model used to develop the Company' s 2021 IRP.5 Because
2 the resources were beneficial to customers, they were
3 included in the Company' s least-cost, least-risk
4 preferred portfolio.
5 Q. Was the acquisition and repowering of the Projects
6 included in the 2021 IRP Action Plan?
7 A. Yes . Action Item 2b of the 2021 IRP noted that the
8 Company would pursue necessary regulatory approvals to
9 authorize the acquisition and repowering of the Foote
10 Creek II-IV and Rock River I facilities in order to
11 support late 2023 and late 2024 in-service dates,
12 respectively. 6 The Company' s 2021 IRP Update continued
13 to include acquisition and repowering of the Projects in
14 the preferred portfolio, as did the Company' s 2023 IRP. '
15 Q. What is your recommendation?
16 A. I recommend the Commission: (1) find that acquiring and
17 repowering the Foote Creek II-IV and Rock River I wind
18 projects are prudent, reasonable and in the public
19 interest and will benefit customers; and (2) allow the
5 In re PacifiCorp's 2021 Integrated Resource Plan, at 295 (Sept. 1,
2021) (available here: https://www.pacificorp.com/energy/integrated-
resource-plan.html) .
6 Id. at 323.
' In re PacifiCorp's 2021 IRP Update, at 5 (Mar. 31, 2022) (available
here:
https://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorp/en
ergy/integrated-resource-plan/2021 IRP Update.pdf) ; In re PacifiCorp's
2023 IRP, at 10 (Mar. 31, 2023) (available here:
https://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorp/en
ergy/integrated-resource-plan/2023-irp/2023 IRP Volume I.pdf) .
Hemstreet, Di 20
Rocky Mountain Power

1 Company to recover the cost of these investments in
2 retail rates .
3 Q. Does this conclude your direct testimony?
4 A. Yes .
Hemstreet, Di 21
Rocky Mountain Power

Case No. PAC-E-24-04
Exhibit No. 36
Witness : Timothy J. Hemstreet
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony
of Timothy J. Hemstreet
Foote Creek Site Layout
May 2024

Rocky Mountain Power
Exhibit No.36 Page 1 of 1
Case No. PAC-E-24-04
Witness:Timothy J.Hemstreet
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Source: NAIP Imagery,2019
Lease Boundary
WWI
Foote Creek II-IV Turbine Foote Creek II-IV
Electrical Collection Line
—Access Road Repowering
Laydown Area
Substation Project Location
N
Carbon
Miles
0 0.5 1
I I I I I MARTIN&NICHOLSON
ENVIRONMENTAL CONSULTANTS2

Case No. PAC-E-24-04
Exhibit No . 37
Witness : Timothy J. Hemstreet
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony
of Timothy J. Hemstreet
Rock River I Site Layout
May 2024

Rocky Mountain Power
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Case No. PAC-E-24-04
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Existing P TT CARBON COUNTY,WYOMING
Overhead Q Substation = w Project No. 193579D.000
Transmission Rocky River WY Z
Line 0 Ranches o
RBON `` I
�PACIFICORP Feeder 1 � State of Wyoming ALBANY
Feeder 2 Laramie
RAMIE
: Cheyenne
Sources: 0 0.5 1 1.5 2 e
uscs(2019) CO
ESRI(2021) Miles
2

REDACTED
Case No. PAC-E-24-04
Exhibit No. 38
Witness : Timothy J. Hemstreet
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
REDACTED
Exhibit Accompanying Direct Testimony
of Timothy J. Hemstreet
Foote Creek II-IV Energy Production Analysis
May 2024

THIS EXHIBIT IS CONFIDENTIAL IN ITS
ENTIRETY AND IS PROVIDED UNDER
SEPARATE COVER

REDACTED
Case No. PAC-E-24-04
Exhibit No. 39
Witness : Timothy J. Hemstreet
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
REDACTED
Exhibit Accompanying Direct Testimony
of Timothy J. Hemstreet
Rock River I Energy Production Analysis
May 2024

THIS EXHIBIT IS CONFIDENTIAL IN ITS
ENTIRETY AND IS PROVIDED UNDER
SEPARATE COVER