20170825Idaho Irrigation Pumpers1-17 to PAC.pdf

Eric L.Olsen (ISB#4811)
ECHO HAWK &OLSEN,PLLC
505 Pershing Ave.,Ste.100
P.O.Box 6119
Pocatello,Idaho 83205
Telephone:[phone]
Facsimile:[phone]
Email:clo a echohn Lcom
Attorneyfor IntervenorIdaho Irrigation Pumpers Association,Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION CASE NO.PAC-E-17-06
OF PACIFICORP DBA ROCKY
MOUNTAIN POWER FOR BINDING IDAHO IRRIGATION PUMPERS
RATEMAKING TREATMENT FOR WIND ASSOCIATION,INC.'S FIRST SET
REPOWERING OF DATA REQUESTS
Idaho Irrigation Pumpers,Inc.,by and through counsel,hereby submits its first Data
Requests to Rocky Mountain Power,pursuant to Commission Rule 225,as follows:
1.Please supply a copy of all responsesto other party's data requests in this case.
2.Please supply a copy of all numerical exhibits,tables,and answers to interrogatories in
electronic format with all formulas intact.
3.On page 5 of Mr.Crane's Direct Testimony it is stated that the repoweringcosts will be
approximately$1.13 billion.
a.What was the total original cost of the facilities that are to be repowered7
b.What was the original cost of the portion of the facilities that are to be repowered (not
tower,foundation,infrastructure,etc.)?
c.At the end of 2017 what is the estimated cost of the undepreciated value of the
equipment that will be replaced because of repowering?
4.On page 10 of Mr.Crane's Direct Testimony it is stated:"In addition,it is important that
parties understand the rate treatment of the project before the Company makes this
significant investment to ensure that the costs and benefits will be properly matched and
customers and shareholders will be fairly treated."
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS -Page 1
a.How much money has already been spent or committed to the repowering project?
b.How much money is anticipated to be spent or committed on the repowering project
before a decision is made by the Idaho Commission?
c.By this statement,does the Company recognize that all moneys spent or committed
before Commission approval,are subject to disallowance for ratemaking purposes?
5.Mr.Hemstreet's Direct Testimony starting on page 5 line 3 states:"It will reduce ongoing
operation costs as a result of replacing older WTG equipment subject to more failure and
maintenance issues than newer equipment."Please supply the numerical responses to this
request in electronic format.
a.For all of the WTG's that are proposed to be repowered,what has been the history of
annual operating expenses for 2010-2016?
b.For all of the WTG's (by site location)that are proposed to be repowered,what is the
forecast annual operating expenses if repowering does not take place?
c.For all of the WTG's (by site location)that are proposed to be repowered,what is the
forecast annual operating expenses if repowering does take place7
d.For all of the WTG's (by site location)that are proposed to be repowered,what has
been the history of annual maintenance expenses7
e.For all of the WTG's (by site location)that are proposed to be repowered,what is the
forecast annual maintenance expenses if repowering does not take place?
f.For all of the WTG's (by site location)that are proposed to be repowered,what is the
forecast annual maintenance expenses if repowering does take place?
g.Where in the filing is the difference between the operation and maintenance expenses
under the repowering and non-repowering scenarios shown?
6.Regarding footnote 1 on Mr.Henstreet's Direct Testimony,what is the estimated cost of
increasing the existing transmission interconnection agreements such that it will allow an
increase in capacity to the 13 to 35 percent levels listed?
7.On page 10 Mr.Hemstreet discusses the Company's "informed-curtailment protocol".For
each of the Company's wind project over the last five years:
a.When were such curtailments implemented?
b.How long did the curtailments last?
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS-Page 2
c.How much capacity was curtailed?
d.What was the estimated amount of energy curtailed?
8.On page 11 of Mr.Hemstreet's Direct Testimony it states that B&V did an evaluationof the
increased energy production fiom the repowering.Please provide a copy of that study.
9.On page 12 of Mr.Hemstreet's Direct Testimony it is stated that:"the proposed repowered
wind facilities are estimated to increase generation by 550,601 MWh per year".This
infonnation appears to come from Exhibit 3.
a.Is the estimated future generation based upon the B&V study/assessmentmentioned
on page 11 of Mr.Hemstreet's Direct Testimony?
b.Were the "Current Long-Term Generation"figures based upon actual figures or
estimated in the same manner as the B&V study to calculate the generation after
repowering?If actual figures,over what timeframe?
c.Using the Glenrock I wind project as an example,explain what is meant by "Current
Project Capacity (MW)".Assuming that this is a maximum capacity at some higher
wind speed,what is the range of that wind speed?
d.Using the Glenrock I wind project as an example,whyis the percentage increase in
generation (MWh)so much greater than the percentage increase in capacity?Please
quantify how the increasedpercentage of energy is derived.
10.Using the Glenrock I wind project as an example,please provide a numerical comparison of
Existing and Repowered Turbine Power Curve Comparison (Exhibit 4)showing for,each 0.5
meters per second wind speed interval,the wind turbine output for the existing and the
repowered scenarios.Show also the frequency of each of the wind speed intervals listed.
l 1.Regarding the reduced ongoing operational costs following repowering that is mentioned on
Mr.Hemstreet's Direct Testimony at page 14,please answer the following:
a.The two-year warranty is expected to "reduce capital costs associated with replacing
and refurbishingthe equipment currently in service."For each year in the future
where this is expected,what is the expected amount of capital costs under the current
conditions and what is the capital reduction after repowering?
b.It is stated that:"After the two-year warranty period for the new equipment expires,
these costs are expected to be lower than the costs of the current equipment..."For
each year in the future where this is expected,what is the expected amount of capital
costs under the current conditions and what is the capital reduction after repowering?
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQisUSTS-Page 3
12.On page 15 of Mr.Hemstreet's Direct Testimony,it states that:"repowering will avoid costs
from replacing certain major turbine components..."
a.What was the original installed cost of all of the Company's wind fleet?
b.What has been the capital additions (by year)to the wind generation fleet?
c.What has been the capital additions (by year)to the wind fleet associated with the
gearbox failures7
13.Figure 5 of Mr.Link's Direct Testimony demonstrates the total annual revenue requirement
based upon the data in Exhibit 10.On page 36 (lines 2-11)of Mr.Link's Direct Testimony
there is a general discussion of what is causing the changes in revenue requirement.Please
give a general overview of data that results in the annual revenue requirements that are
predominant during the followingtimeframes:
a.2027 thru 2028
b.2038 thru 2039
c.What is the PTC benefits each year for the existing WTGs?
d.What is the PTC benefits each year for the repowered WTGs?
14.On page 36 of Mr.Link's Direct Testimony it states:"Annual revenue requirement is
reduced over the 2037-through-2050 time frame when,as discussed earlier in my testimony,
the incremental wind energy output associated with wind repowering increases
substantially."
a.What is the increase in energy output from the repowered WTGs for each year from
2037 thru 2050?
b.What is the PTC value of the repowered WTGs for each year from 2037 thru 2050?
15.On page 9 of Mr.Larken's Direct Testimony it is stated that:"As existing equipment is
replaced by repowering,the Company will transfer the replaced assets from gross EPIS to the
ADR,thereby reducing depreciation expenseon the existing investment until the next
depreciation study,at which time the net plant balance for wind resources will be reviewed
and new depreciation rates set to recover both the new and the remaining replaced
investment."Given that the depreciation for "existing equipment"is contained in present
rates,whywould these plant assets be removed from gross EPIS upon repowering and then
put back in later?
IDAllO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS -Page 4
16.On page 6 of Mr.Hemstreet's Direct Testimony he states that the Company's repowering
project will qualify for the full value of the productiontax credits.
a.Please provide all studies,memoranda or documents wherein the Company
addresses ability for the repowering project to qualify for the full value of the
production tax credits.
b.Please describe how the production tax oredit analysis would change if the
Company incurred cost overruns and the 2016 safe harbor investment ends up
being less than 5%of the overall cost of the repower project.
17.On page 15 of Mr.Larsen's Direct Testimony he states that remaining investment in the wind
equipment being replaced should remain in rates and that the Company's decision to pursue
the wind repowering is dependent on is ability to recover this stranded cost.Please provide
all basis in regulatory precedent,law and fact that supports the Company's requested
regulatory treatment of this planned,stranded wind equipment.
DATED this 25*day of August,2017.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS-Page 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 25*day of August,2017,I served a true,correct and
complete copy of the Petition of Idaho Irrigation Pumpers Association,Inc.for Leave to
Interveneto each of the following,via U.S.Mail or private courier,email or hand delivery,as
indicated below:
Diane M.Hanian,Secretary U.S.Man
Idaho Public Utilities Commission Hand Delivered
P.O.Box 83720 OvernightMail
472 W.Washington Street Telecopy (Fax)
Boise,ID 83720-0074 Electronic Mail (Email)
Data Request Response Center -PacifiCorp U.S.Man
Email:MEduuntaggarnaan Hand Delivered
O Ovemight MaßOTelecopy(Fax)
Electronic Mail (Email)
Ted Weston U.S.Mail
Idaho RegulatoryAffairs Manager Hand Delivered
Rocky Mountain Power O Ovemight Mail
1407 West North Temple,Suite 330 Telecopy (Fax)
Salt Lake City,Utah 84116 Electronic Mail (Email)
Email:testgegon g;w¾tayypin
Yvonne R.Hogle U.S.Man
Assistant General Counsel O Hand Delivered
Rocky Mountain Power Ovemight Mail
1407 West North Temple,Suite 320 Telecopy (Fax)
Salt Lake City,Utah 84116 Electronic Mail (Email)
Adam Lowney O U.S.Maß
McDowell Rackner Gibson PC Hand Delivered
419 SW l 1"'Avenue,Suite 400 Ovemight Man
Portland,OR 97205 O Telecopy (Fax)
Email:plam a mrgdin om Electronic Mail (Email)
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS -Page 6
Katherine McDowell U.S.Man
McDowell Rackner Gibson PC Hand Delivered
419 SW 11"'Avenue,Suite 400 Overnight Mail
Portland,OR 97205 O Telecopy (Fax)
Email:katherine «mrg-lawsom Electronic Mail (Email)
Ronald L.Williams O U.S.Man
Williams Bradbury,P.C.Hand Delivered
P.O.Box 388 Overnight Mail
Boise,ID 83701 O Telecopy (vax)
Email:gang w illiamsbratiburv.com Electronic Mail (Email)
Jim Duke U.S.Man
Idahoan Foods Hand Delivered
Email:[e-mail] O Overnight Mail
O Telecopy (Fax)
Electronic Mail (Email)
Kyle Williams U.S.Mail
BYU Idaho Hand Delivered
Email:y liiamsk by u lu Overnight Mail
O Telecopy (Fax)
Electronic Mail (Email)
Val Steiner U.S.Mail
Nu-West Industries,Inc.Ifand Delivered
Email:in riun O Overnight Mail
O Telecopy (Fax)
Electronic Mail (Email)
Randall C.Budge U.S.Mail
Racine,Olson,Nye &Budge,Chartered O Hand Delivered
P.O.Box 1391;201 E.Center Overnight Mail
Pocatello,ID 83204-1391 Telecopy (Fax)
Email:;a lawnct Electronic Mail (Email)
Brubaker &Associates U.S.Mail
16690 Swingley Ridge Rd.,#140 Hand Delivered
Chesterfield,MO 63017 Ovemight Maß
Email:o op co Telecopy (Fax)
IDAIIO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS-Page7