20170905Staff 5-35 to PAC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.7956
Street Address for Express Mail:
472 W.WASHINGTON
BOISE,IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )PACIFICORP DBA ROCKY MOUNTAIN )CASE NO.PAC-E-17-06
POWER FOR BINDING RATEMAKING )
TREATMENT FOR WIND REPOWERING )
)SECOND PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission requests that Rocky Mountain Power
provide the followingdocuments and information as soon as possible,but no later than
TUESDAY,SEPTEMBER 26,2017.
This Production Request is to be considered continuing,and Rocky Mountain Power is
requested to provide,by way of supplementaryresponses,additional documents that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title and telephonenumber of
the person preparing the documents.Please identify the name,job title,location and telephone
number of the record holder.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 5,2017
In addition to the written copies provided as response to the requests,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.5:Please provide workpapers,exhibits,tables,and any analysis
supporting the Company's filing in electronic format with formulae intact with references to
sources for all pasted values.Please consider this an ongoing request.
REQUESTNO.6:Please provide copies of all past and future data requests and
responses received by or sent from Rocky Mountain Power to any party in related applications
submitted in other state jurisdictions.Please include both formal and informal responses.In
addition to requests made in Idaho,please provide copies of PacifiCorp's responses to wind
repowering data requests submitted by all parties in the states of Utah,Washington,Oregon,
Wyoming,and California.This response should include public and confidential data responses.
Please provide all future responses at,or shortlyafter,the time when the Company files its
responses to other parties'requests.As responses are provided,please include a summary of the
state name,organization and DR#s for the DRs contained within each response.
REQUESTNO.7:Please provide a list of all regulatory authorizations required for the
project.Please identify the authorizations,if not obtained,that would cause the Company to
cancel or modify the project,and explain why it would affect the project and specifically what
action the Company would take.
REQUESTNO.8:Please provide all information since the last depreciation study
supporting the Company's basis for a 30-year depreciation life of the wind turbine generators
(i.e.,manufacturer data or studies).
REQUESTNO.9:Please detail all IRS requirements the Company has completed to
date by project site in order to qualify for 100%of the PTC's referenced by PAC-E-17-06.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 5,2017
REQUESTNO.10:Please detail all remaining IRS requirements by project site which
the Company has yet to complete in order to qualify for 100%of the PTC's referenced by
PAC-E-17-06.
REQUESTNO.11:Please provide the documentation,by Wind Project,that shows the
Company has met the "start of construction"requirement,and the "safe harbor"requirement for
the PTCs.Include all source documents including receipts,journal entries,emails,contracts,and
any other documents for the purchases and acquisitions for the Wind Repowering projects before
December 31,2016.
REQUESTNO.12:Please explain the Company's approach to meet IRS Safe Harbor
eligibilityincluding start of construction,continuityand any other provisions.
REQUESTNO.13:If the Company does not meet the December 2020 completion
project date,please describe in detail the Company's contingency plans to obtain 100%
eligibilityof PTCs.
REQUESTNO.14:The Company has provided economic analysis of the project
assuming 100%eligibilityand receipt of the PTCs.Please provide similar analysis of the project
if full receipt of the PTC is not met (i.e.80%,60%,and 40%).
REQUESTNO.15:With respect to the previous question,please quantifythe
likelihood of not receiving 100%of the PTC.
REQUESTNO.16:In order for customers to realize the full net benefits of the project
as proposed by the Company,the Company will need to execute its plan on schedule and under
proposed cost estimates.Below are three potential conditions that would put ratepayer net
benefits at risk.For each circumstance below,please describe how the Company would ensure
customers are compensated for lost benefits or increased costs that are the Company's
responsibility:
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 5,2017
a.Reduction in PTC Benefits related to non-attainment of IRS Safe Harbor
requirements (not meeting requirements necessary for 100%of PTC).
b.Reduction in PTC,NPC,and wholesale wheeling revenue benefits related to late
schedule completion.
c.Cost overruns due to construction,capital infrastructure cost,permitting,etc.
REQUESTNO.17:Please provide the average yearly market price of wind RECs over
the past five years,and the projected value of these RECs over the next 10 years.
REQUESTNO.18:Please provide the Company's Project Plan including,but not
limited to:
a.A detailed schedule/Ganttchart reflecting all major activities on the critical path.
b.Any contingency plans the Company will implement to recover from delays.
c.Project risks,the likelihood of these risks,and costs associated with those risks.
REQUESTNO.19:Please list and quantifythe potential for schedule delay related to:
a.Jurisdictional approval
b.Permitting
c.Procurement
d.Construction
REQUESTNO.20:Has the Company considered and quantified other locations for
siting wind that would qualify for the PTC and not require retirement of existing capital?If so,
please provide the analysis and the results.If not,why not?
REQUESTNO.21:Please explain what the Company will do with the items procured
to meet the 5%safe harbor benchmark if the projects do not proceed.Will the Company request
customers pay these costs?
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 SEPTEMBER 5,2017
REQUESTNO.22:Please provide a list of all contracts required to complete the wind
repower project.Please include the names of the contractor,the purpose of the contract,and
estimated cost amounts.
REQUESTNO.23:In reference to Company witness Larsen,please provide all
workpapers that were used to develop Exhibit 12 and Exhibit 13.
REQUESTNO.24:Please provide the source documents that support the information
in Larsen Exhibits 12 and 13.
REQUESTNO.25:Please provide the estimated PVRR(d)for the project if there is a
1-year,2-year,or 3-year slip to the project's completion.
REQUESTNO.26:What is the breakeven point for continuing with the wind
repowering in relation to the PTCs?At what level of PTCs do the costs of the projects become
untenable?
REQUESTNO.27:When did the Company first begin analyzing the PTCs after it was
extended in the PATH Act of 2015?Specifically,when did the Company begin pursuing
eligibilityfor PTC for these projects?
REQUESTNO.28:Did the Company investigate claiming the Investment Tax Credit
(ITC)in lieu of the PTC?Please provide any analysis the Company did as it pertains to the ITC.
REQUESTNO.29:IRS Notice 2017-4 states in Section 3,"If a facility does not satisfy
the ContinuitySafe Harbor,whether the facility satisfies the Continuous Construction or
Continuous Efforts Tests is determined by the relevant facts and Circumstances."If it is
determined that the Five Percent Safe Harbor is not met,what information will the Company rely
upon which will satisfy the Continuous Construction or Continuous Efforts Tests?Is the
Company compiling and retaining this information at this time?
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 SEPTEMBER 5,2017
REQUESTNO.30:The expected cost of wind repowering is approximately $1.13
billion.
a.Please provide a cost breakdown by item (blades,nacelle,etc.)and location for
the cost estimate totaling approximately $1.13 billion.
b.Please provide the workpapers,invoices,emails,and all other source documents
used to calculate the estimate.
c.Please provide the workpapers,invoices,contracts,etc.for the items that have
been purchased or contracted for through June 30,2017.Please provide the
information by wind facility,i.e.Glenrock I,Glenrock III.Please update this
monthlythroughout the remainder of the project.
REQUESTNO.31:Please provide the contracts with General Electric,Inc.and Vestas-
American Wind Technology,Inc.for the purchase of new WTG equipment.
REQUESTNO.32:Please provide the ongoing depreciation expense calculation,and
all other costs currentlyin rates,by project,by year,for the recovery of the plant equipment that
is replaced due to the wind powering project.Does the Company anticipate that these costs will
continue to be recovered in the next general rate case?Does the Company anticipate there is any
salvage value in the replaced plant equipment?If so,please quantify.
REQUESTNO.33:Please quantifythe reduced operating expenses by providing an
estimate of the O&M costs for the wind facilities as they are today,for the years 2020 through
2029,and the estimate of the O&M costs for the repowered wind facilities,for the years 2020
through 2029.Please include any anticipated updated capital investments to the existing wind
facilities,includingthe corresponding depreciation expense changes associated with any capital
upgrades.
REQUESTNO.34:Please provide and explain the costs associated with modifyingthe
current interconnection agreements.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 SEPTEMBER 5,2017
REQUESTNO.35:Please provide any economic analysis that has been completed by
the Company relating to the salvage value of the removed equipment from the wind repowering
project.For example,but not limited to:
a.Selling or auctioning equipment salvage value.
b.Reusing or repurposing equipment salvage value.
c.Scrap metal salvage value.
DATED at Boise,Idaho,this day of September 2017.
Br on arpen
eputy A orney General
Technical Staff:Rick Keller/5-20
Kathy Stockton/21-33
Michael Eldred/34-35
i:umise:prodreqlpacel7.6bkrkklsme prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 SEPTEMBER 5,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5th DAY OF SEPTEMBER 2017,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.
PAC-E-17-06,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
TED WESTON YVONNE R HOGLE
ROCKY MOUNTAIN POWER ASSITANT GENERAL COUNSEL
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 1407 WN TEMPLE STE 320
E-MAIL:[e-mail] SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER RANDALL C BUDGE
E-MAIL ONLY:RACINE OLSON NYE &BUDGE
[e-mail] PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL:[e-mail]
BRUBAKER &ASSOCIATES RONALD L WILLIAMS
16690 SWINGLEY RIDGE RD #140 WILLIAMS BRADBURY PC
CHESTERFIELD MO 63017 PO BOX 388
E-MAIL:[e-mail] BOISE ID 83701
E-MAIL:[e-mail]
ELECTRONIC ONLY ELECTRONIC ONLY
JOHN DUKE KYLE WILLIAMS
IDAHOAN FOODS BYU IDAHO
E-MAIL:[e-mail] E-MAIL:[e-mail]
ELECTRONIC ONLY ERIC L OLSEN
VAL STEINER ECHO HAWK &OLSEN
NU-WEST INDUSTRIES INC PO BOX 6119
E-MAIL:val.steiner agrium.com POCATELLO ID 83205
E-MAIL:elo echohawk.com
ANTHONY YANKEL
UNIT 2505
12700 LANE AVENUE
LAKEWOOD OH 44107
E-MAIL:tonv vankel.net
SECRETARY
/CERTIFICATE OF SERVICE