20240904PAC to Bayer 75-78.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 4, 2024
Thomas J. Budge
[e-mail] (C)
Brian C. Collins [e-mail]
Greg Meyer [e-mail]
Kevin Higgins [e-mail] (C)
Neal Townsend [e-mail] (C)
RE: ID PAC -E-24-04
Bayer Set 5 (75-78)
Please find enclosed Rocky Mountain Power’s Responses to Bayer 5th Set Data Requests 75-78.
Also provided are Attachments Bayer 75-1, 75-2 and 76.
If you have any questions, please feel free to call me at [phone].
Sincerely,
____/s/____
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA [e-mail] (C)
Lance Kaufman/IIPA [e-mail] (C)
Matthew Nykiel/ICL [e-mail]
Brad Heusinkveld/ICL [e-mail]
Ronald L. Williams/PIIC [e-mail]
Brandon Helgeson/PIIC [e-mail]
Bradley Mullins/PIIC [e-mail]
Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]
Monica Barrios-Sanchez/IPUC [e-mail]
[e-mail]
RECEIVED
Wednesday, September 4, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-24-04 / Rocky Mountain Power
September 4 , 2024
Bayer Data Request 75

Bayer Data Request 75

Resources Interconnecting to Gateway South and Gateway West. Please refer
to the Direct Testimony of Richard A. Vail, p. 23 (lines 13-14), in which Mr. Vail
states as follows: “[T]hese Transmission Projects allow the Company to
interconnect up to approximately 2,030 megawatts (“MW”) of new resources.”

(a) What portion of the 2,030 MW is expected to interconnect to Gateway South
and what portion is expected to interconnect to Gateway West?

(b) For the portion of the 2,030 MW expected to interconnect to Gateway South,
please identify each resource, its location, nameplate capacity, whether or not
it is owned by PacifiCorp or under contract to sell its generation output to
PacifiCorp, and whether it is included in the 1,640 MW of resources selected
to the final shortlist of RMP’s 2020AS RFP as referenced in the direct
testimony of RMP witness Rick T. Link, p. 37 (lines 5-7).

(c) For each project identified in subpart (b), please provide a copy of each Large
Generator Interconnection Agreement (LGIA), Small Generator
Interconnection Agreement (SGIA), or transmission service agreement, as
applicable.

(d) What is the expected in-service date of each project identified is subpart
75(b)? If the Company is aware of any delays in expected in-service dates
please identify them.

Response to Bayer Data Request 75

(a) None of the 12 generation interconnection projects that make up the 2,030
megawatts (MW) are proposed to directly interconnect to either the Energy
Gateway West or Energy Gateway South 500 kilovolt (kV) transmission lines.
They are all proposed to interconnect to PacifiCorp’s existing, underlying 115
kV and 230 kV transmission system that will be reinforced by Energy
Gateway West segment D.1 and Energy Gateway South. The Rock Creek II
wind project will be interconnected to the 230 kV portion of Aeolus substation
which is in eastern Wyoming where the Energy Gateway South line originates
and where the 525/230 kV transformation is located. The Energy Gateway
transmission lines are required to support the interconnection of all of these
resources to mitigate system reliability issues on the existing transmission
system in the region and to have additional interconnection capacity in eastern
Wyoming.

(b) Please refer to the Company’s response to subpart (a) above for background
on the actual points of interconnection (POI) for the 12 resources. Please refer
to Attachment Bayer 75-1 which provides the requested details for each
PAC-E-24-04 / Rocky Mountain Power
September 4 , 2024
Bayer Data Request 75

resource that requires Energy Gateway South to be in-service prior to
interconnection.

(c) Please refer to Attachment Bayer 75-1.

(d) Please refer to Attachment Bayer 75-2.

Recordholder: Kris Bremer

Sponsor: Rick Vail

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
Bayer Data Request 76

Bayer Data Request 76

Resources Interconnecting to Gateway South and Gateway West. Please refer
to the Direct Testimony of Rick Vail, p. 24 (lines 21-23), in which Mr. Vail states
as follows: “…PacifiCorp has executed 13 contracts with third-party customers
that require constructing one or both of the Transmission Projects.”

(a) Which of the resources listed in response to Bayer Data Request 75(b) above
correspond to any of the 13 contracts referenced by Mr. Vail?

(b) Please indicate which, if any, of the 13 contracts referenced by Mr. Vail are
associated with resources that are included in the 1,640 MW of resources
selected to the final shortlist of RMP’s 2020AS RFP as referenced in Mr.
Link’s direct testimony, p. 37.

(c) If any of the 13 contracts referenced by Mr. Vail are not listed in response to
Bayer Data Request 75(b) above, please:

i. identify each resource, its location, and nameplate capacity;
ii. provide a copy of each Large Generator Interconnection Agreement
(LGIA), Small Generator Interconnection Agreement (SGIA), or
transmission service agreement, as applicable; and
iii. indicate its expected in-service date if known.

Response to Bayer Data Request 76
(a) The 12 resources listed in the Company’s response to Bayer Data Request
Bayer 75, specifically Attachment Bayer 75-1, correspond to the contracts
referenced in the direct testimony of Company witness, Rick A. Vail. The
13th contract is associated with a 500 megawatt (MW) point-to-point (PTP)
transmission service request (TSR).

(b) The generation interconnection agreements for Boswell Springs, Cedar
Springs IV, Anticline, Two Rivers, Rock Creek I and Rock Creek II are
associated with resources selected in the final shortlist (FSL) of PacifiCorp’s
2020 All Source Request for Proposals (2020AS RFP).

(c) The only contract not listed in the Company’s response to subpart (b) above is
the 500 MW PTP TSR contract, which is provided as Attachment Bayer 76.

Recordholder: Kris Bremer

Sponsor: Rick Vail
PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
Bayer Data Request 77

Bayer Data Request 77

Gateway South Net Benefits. Please refer to Exhibit No. 31 attached to the direct
testimony of Rick T. Link. Regarding the entry labeled “Avoided Transmission –
Base 230 kV” under each scenario of this exhibit:

(a) Please confirm that this entry refers to the costs avoided from not constructing
transmission upgrades to accommodate PacifiCorp’s obligation to provide 500
MW of firm point-to-point transmission service to a third-party customer as
discussed on pages 29-30 of Mr. Link’s direct testimony.

(b) What is the estimated construction cost of the transmission facilities
associated with the $(843 million) PVRR in each price policy scenario in
Exhibit No. 31? Is it the $1.4 billion referenced by Mr. Link on page 30 of his
direct testimony or some other amount?

(c) In calculating the $(843 million) PVRR in Exhibit No. 31, did the Company
assume that 80% of the revenue requirement of the avoided 230 kV
transmission line would have been borne by PacifiCorp retail customers if that
line had been built to meet PacifiCorp’s obligation to provide 500 MW of firm
point-to-point transmission service to a third-party customer? If not, please
indicate the percentage the Company used and explain the basis for it.

(d) Is Mr. Link familiar with FERC’s “Higher of” Pricing Policy as discussed in
FERC Order 890, paragraphs 870-885?

(e) In preparing the analysis presented in Exhibit No. 31, why didn’t the
Company assume that retail customers would not have been expected to pay
for the cost of a 230 kV line required to serve a third-party customer seeking
500 kW of firm transmission service, since that customer could have been
required to pay the monthly incremental cost transmission rate using the
revenue requirement associated with the required upgrades as discussed in
FERC Order 890?

(f) In preparing its PVRR analysis, if the Company had assumed that the third-
party customer seeking 500 kW of firm transmission service would have been
required to pay the monthly incremental cost transmission rate using the
revenue requirement associated with the required upgrades, would the $(843
million) PVRR entry in Exhibit No. 31 have changed to zero? If the
Company’s response is “no,” please explain in detail why.

Response to Bayer Data Request 77

(a) The "Avoided Transmission – Base 230 kV" entry in the direct testimony of
Company witness, Rick T. Link refers to the conservative cost assumption to
PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
Bayer Data Request 77

avoid transmission customers for a single third-party transmission customer.
As further described in Rick Link’s direct testimony, this assumption is
conservative because it does not consider the numerous other interconnection
agreements that would require even more infrastructure and more cost than
what is assumed in the referenced exhibit.

(b) The estimated construction cost of the transmission facilities associated with
the $(843) million present value of revenue requirements (PVRR) in each
price policy scenario in Exhibit No. 31 is the $1.4 billion referenced in Rick
Link’s direct testimony, page 30.

(c) The Company assumed that 80 percent of the revenue requirement of the
avoided 230 kilovolt (kV) transmission line would have been borne by
PacifiCorp retail customers if that line had been built to meet PacifiCorp’s
obligation to provide 500 megawatts (MW) of firm point-to -point (PTP)
transmission service to a third-party customer.

(d) The Company objects to this subpart because it asks for either a legal
conclusion, or application of specific facts to a legal authority.
Notwithstanding the foregoing objection, the Company responds as follows:

Company witness, Rick Link does not administer PacifiCorp’s Open Access
Transmission Tariff (OATT).

(e) The Company objects to this subpart because it asks for either a legal
conclusion, or application of specific facts to a legal authority.

(f) The Company assumes that reference to “500 kW of transmission service…”
is intended to be 500 MW of transmission service. Based on the foregoing
assumption, the Company responds as follows:

Yes. The Company agrees that $843 million divided by 80 percent (arriving at
the full present value cost of the avoided transmission cost) equals zero when
subsequently multiplied by zero percent.

Recordholder: Samuel Zacharia

Sponsor: Rick Link

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
Bayer Data Request 78

Bayer Data Request 78

Gateway South. Please refer to Mr. Link’s direct testimony, pages 29- 30, in
which he refers to PacifiCorp’s obligation to provide 500 MW of firm point-to-
point transmission service to a third-party customer.

(a) Does the referenced transmission service customer currently have a
transmission service agreement with the Company? If yes, are the rates
charged under the agreement the embedded cost rate in the Company’s OATT
or the monthly incremental cost transmission rate using the revenue
requirement associated with the Gateway South project?

(b) When did the referenced customer begin to take transmission service from
PacifiCorp? If the customer has not yet started to take service, when does the
Company expect the customer to begin taking service?

(c) If the customer has not yet started to take service, is the customer still subject
to charges from the Company? If yes, please indicate the rate and annual
amount of the charges.

(d) If the rate charged under the agreement is the embedded cost rate in the
Company’s OATT, please explain why the Company did not seek to charge
the monthly incremental cost transmission rate using the revenue requirement
associated with the Gateway South project?

Response to Bayer Data Request 78
(a) Yes. The rates contemplated in PacifiCorp’s point-to-point (PTP) transmission
service agreements are pursuant to the PacifiCorp Open Access Transmission
Tariff (OATT) rates in effect at time of service.

(b) Service under the agreement shall commence on the later of (1) the requested
service commencement date, (2) the date on which construction of any Direct
Assignment Facilities and/or Network Upgrades are completed, or (3) such
other date as it is permitted to become effective by the Federal Energy
Regulatory Commission (FERC).

(c) Charges for transmission service commence upon start of service pursuant to
the agreement.

(d) PacifiCorp’s Transmission Formula Rate was established as a result of a
settlement that was accepted by the FERC in Docket No. ER11-3643-000.
The settlement agreement included a formula rate template (template)
provided in Attachment H-1 of PacifiCorp’s OATT; the protocols are set forth
in Attachment H-2 of the OATT. In accordance with this settlement
PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
Bayer Data Request 78

agreement, by May 15 of the current year, PacifiCorp calculates two separate
rates: (1) a projected rate that includes limited projections for transmission
capital and load, as well as (2) a True-Up rate based on historical actuals
during the preceding calendar year. The transmission formula rate determines
an annual transmission revenue requirement (ATRR) and divides it by billing
determinants to calculate a charge. The rates contemplated in PacifiCorp’s
PTP transmission service agreements are pursuant to the PacifiCorp OATT
rates in effect at time of service.

Recordholder: Veronica Whitesmith

Sponsor: Rick Vail