20170915Pac to IIPA 1-17.pdf

ROCKY MOUNTAIN
POWER
A DIVISION OF PActBCORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
September 14,2017
Eic L.Olsen
ECHO HAAWK &OLSEN,PLLC
505 Pershing Ave.,Ste.100
Pocatello,Idaho 83205
elo@e_chollawk.co_m(C)
RE:ID PAC-E-17-06
IIPA 1"Set Data Request (1-17)
Please find enclosed Rocky Mountain Power's Responses to IIPA 16'Set Data Requests 1-16.
The response to IIPA 17 will be provided under separate cover Also provided are Atteahments
IIPA 1 -1,3,5 -1,and 12.Provided on the enclosed CD are Confidential Attachments IIPA 1 -2,
5 -2,8,10,11,and 16 -(1-2)and Confidential Response IIPA 9.Confidential informationis
provided subject to the terms and conditions of the protective agreement in this proceeding.
If you have any questions,please feel free to call me at [phone].
Sincerely,
J.Ted Weston
Manager,Regulation
Enclosures
C.c.:Ronald L.Williams/PIIC (C)
Jim Duke/PIIC (C)(W)
Kyle Williams/PIICw_illiamsk byui._e_du (C)(W)
Val Steiner/PIIC (C)(W)
James R.Smith/Monsanto (C)(W)
Maurice Brubaker/Monsanto mbrubaker consultbai.com (C)(W)
Katie Iverson/Monsanto (C)
AnthonyYankel/IIPA [e-mail] (C)
Randall C.Budge/Monsanto [e-mail] (C)
Thomas J.Budge/Monsanto [e-mail] (C)(W)
Diane Hanian/IPUC (C)
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16'Set Data Request 1
HPA Data Request 1
Please supply a copy of all responses to other party's data requests in this case.
Response to IIPA Data Request 1
Please refer to Attachment IIPA 1-1 and Confidential Attachment IIPA 1-2.
Going forward,IIPA will be provided responses to data requests in this case.
Confidential information is provided subject to the protective order in this
proceeding.
Recordholder:Kaley McNay
Sponsor:Not applicable
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16'Set Data Request 2
HPA Data Request 2
Please supply a copy of all numerical exhibits,tables,and answers to
interrogatories in electronic format with all formulas intact.
Response to HPA Data Request 2
Native files,includingMicrosoft Excel files were provided in electronic format.
Recordholder:Kaley McNay
Sponsor:Not applicable
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16 Set Data Request 3
IIPA Data Request 3
On page 5 of Mr.Crane's Direct Testimony it is stated that the repowering costs
will be approximately $1.13 billion.
(a)What was the total original cost of the facilities that are to be repowered?
(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?
Response to IIPA Data Request 3
Please refer to Attachment IIPA 3,which provides:(a)the total original cost as of
December 31,2016,of the wind facilities;(b)the original cost as of December
31,2016,of the facilities that are to be repowered;and (c)the undepreciated value
at the end of 2017 of the facilities that are to be repowered.
Recordholder:Kent Ipson
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA lst Set Data Request 4
HPA Data Request 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".
(a)How much money has alreadybeen 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?
Response to HPA Data Request 4
(a)As of August 31,2017,$85.8 million has been incurred on the repowering
project.
(b)The Company anticipates that $89 million will be incurred on the repowering
project by December 31,2017,by which time the Company believes the
Idaho Public Utilities Commission (IPUC)may issue a decision.
(c)The Company recognizes that the IPUC has the authorityto disallow the
recovery in rates of costs determinedto be imprudentlyincurred by the
Company.
Recordholder:Tim Hemstreet
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 1"*Set Data Request 5
HPA Data Request 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
place?
(d)For all of the WTG's (by site location)that are proposed to be repowered,
what has been the history of annual maintenance expenses?
(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?
Response to IIPA Data Request 5
(a)The Company does not account for the costs of operations separately from
maintenance.Please refer to Attachment IIPA 5-1,which provides operations
and maintenance (O&M)costs for the wind projects from 2010 through 2016.
(b)Please refer to the Company's response to subpart (a)above.Please also refer
to Confidential Attachment IIPA 5-2,which includes O&M costs as well as
run-rate capital expendituresfor each wind project for assuming repowering
and assuming no repowering (status quo operations).
(c)Please refer to the Company's response to subparts (a)and (b)above.
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 1st Set Data Request 5
(d)Please refer to the Company's response to subpart (a)above.
(e)Please refer to the Company's response to subpart (b)above.
(f)Please refer to the Company's response to subpart (b)above.
(g)Please refer to the Direct Testimony of Company witness,Rick T.Link,
specifically Confidential Link Exhibit No.6,which shows the differences in
O&M expenses and run-rate capital expenditures between the repowering and
non-repowering (status quo)scenarios.
Confidential information is provided subject to the protective order in this
proceeding.
Recordholder:Tim Hemstreet
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16*Set Data Request 6
IIPA Data Request 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?
Response to IIPA Data Request 6
The Company does not yet have an estimate of the costs to modify the existing
transmission interconnection agreements since the costs of potential transmission
upgrades,if any,will be determinedthrough transmission studies that are not yet
completed.
Recordholder:Tim Hemstreet
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16'Set Data Request 7
IIPA Data Request 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?
(c)How much capacity was curtailed?
(d)What was the estimated amount of energy curtailed?
Response to IIPA Data Request 7
(a)The Company has implemented informed curtailments at the Glenrock I,
Glenrock III,and RollingHills wind projects during the followingmonths
over the past five years:
2012 -September to December
2013 -January to December
2014 -January to December
2015 -January,February,March,October,November,and December
2016 -January,February,March,October,November,and December
2017 -January,February,and March
The Company has implemented informed curtailments at the Seven Mile
Hill I and Seven Mile Hill II wind projects during the followingmonths over
the past five years:
2012 -September to December
2013 -January to December
2014 -January to December
2015 -January,February,and March
2016 -January,February,March,and December
2017 -January,February,and March
(b)Curtailments vary in duration based on time of day and season of the year.
Curtailment durations may range from no turbine shut down time up to
multiplehours based on eagle usage levels and behavior (e.g.,perching,
soaring,and hunting).
(c)The Company does not track curtailments by capacity so this information is
not available.Curtailments are implemented at specific zones within the wind
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 161 Set Data Request 7
projects that may contain two or more turbines.Thus,any active curtailment
would affect a nameplate capacity of three megawatts (MW)or more.
(d)Reduced generation in megawatt-hours (MWh)as a result of curtailments at
the Glenrock I,Glenrock III,and RollingHills wind projects by year are
shown below:
2012 -10,71l MWh
2013 -33,569 MWh
2014 -33,915 MWh
2015 -13,168 MWh
2016 -3,876 MWh
2017 (year to date)-1,596 MWh
Reduced generation in MWh as a result of curtailments at the Seven Mile
Hill I and Seven Mile Hill II wind projects are shown below:
2012 -6,837 MWh
2013 -17,606 MWh
2014 -16,237 MWh
2015 -1,943 MWh
2016 -388 MWh
2017 (year to date)-286 MWh
Recordholder:Tim Hemstreet
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16'Set Data Request 8
HPA Data Request 8
On page II of Mr.Hemstreet's Direct Testimony it states that B&V did an
evaluation of the increased energy production from the repowering.Please
provide a copy of that study.
Response to HPA Data Request 8
Please refer to Confidential Attachment IIPA 8.
Confidential information is provided subject to the protective order in this
proceeding.
Recordholder:Tim Hemstreet
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16'Set Data Request 9
HPA Data Request 9
On page 12 of Mr.Hemstreet's Direct Testimony it is stated that:"the proposed
repowered wind facilities are estimated to increase generationby 550,601 MWh
per year".This information appears to come from Exhibit 3.
(a)Is the estimated future generationbased upon the B&V study/assessment
mentioned 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,why is the percentage
increase in generation (MWh)so much greater than the percentage increase in
capacity?Please quantifyhow the increased percentage of energy is derived.
Confidential Response to HPA Data Request 9
(a)Yes,the estimated energy production increases with repowering are based
upon the estimates contained in the Black &Veatch (B&V)study.Please refer
to the Company's response to IIPA Data Request 8,which provides a copy of
that study.
(b)The current long-term generation figures are based upon the actual generation
output from each wind project since the first full year of commercial
operations.The timeframe therefore varies by project but represents the entire
period of complete annual records since the project began commercial
operations.
(c)The current project capacity in megawatts (MW)represents the total
nameplate capacity of the project.Using Glenrock I as an example,there are
66 wind turbine generators (WTG)each with a current nameplate capacity
of 1.5 MW,resulting in a Current Project Capacity of 99 MW.For the
Glenrock I project,the wind turbine generators generally reach their
maximum generating casacity at wind speeds of approximately
meters
per second.
(d)Increases in energy production (megawatt-hours (MWh))are not directly
proportional to increases in the nameplate generatingcapacity of the WTGs.
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16'Set Data Request 9
The new WTGs will produce additional energy (MWh)in all wind speeds,as
shown in Exhibit No.4 of the Direct Testimony of Company witness,
Timothy J.Hemstreet.The percentage increase in energy production depends
primarily upon the differences in the power output between the existing and
new WTGs at specific wind speeds and the frequency of operations at those
different speeds.Percentage increases in energy production were quantified
using a wind model calibrated using site-specific information on wind speeds,
wind turbine layout,site topography,production availability,and project
generationhistory,among other factors,to determine the change in energy
output associated with replacing the existing equipment with the proposed
equipment,as described in the B&V report (provided with the Company's
response to IIPA Data Request 8).
Confidential information is provided subject to the protective order in this
proceeding.
Recordholder:Tim Hemstreet
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA lst Set Data Request 10
IIPA Data Request 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.
Response to IIPA Data Request 10
Please refer to Confidential Attachment IIPA 10.
Confidential information is provided subject to the protective order in this
proceeding.
Recordholder:Tim Hemstreet
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 161 Set Data Request 11
IIPA Data Request 11
Regarding the reduced ongoing operational costs followingrepowering 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 refurbishing the equipment currentlyin 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?
Response to IIPA Data Request 11
(a)Please refer to the Company's response to IIPA Data Request 5,specifically
Confidential Attachment IIPA 5-2.In the spreadsheet provided,the capital
expendituresfor each project under the repowering and status quo cases is
indicated in the tab "CAPEX".The two-year warranty is expected to reduce
capital expendituresin the years 2019,2020,2021 and 2022,reflecting the
different commercial operations dates (COD)for the projects.Please also
refer to Confidential Attachment IIPA 11,which includes work papers used to
derive the capital costs for the repowering and status quo cases.
(b)Please refer to the Company's response to subpart (a)above.and the
Company's response to IIPA Data Request 5,specifically Confidential
Attachment IIPA 5-2.In the spreadsheet provided,the capital expenditures for
each project under the repowering and status quo cases is indicated in the tab
"CAPEX".Capital costs are expected to be reduced in the years 2021 through
2025 as a result of reduced equipment failure rates followingrepowering,
without consideration of the capital cost savings relatedto replacing impacted
gearboxes and GoodnoeHills blades.
Confidential information is provided subject to the protective order in this
proceeding.
Recordholder:Tim Hemstreet
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 1"Set Data Request 12
HPA Data Request 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 failures?
Response to IIPA Data Request 12
Please refer to Attachment IIPA 12.
Recordholder:Kent Ipson
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16'Set Data Request 13
IIPA Data Request 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?
Response to IIPA Data Request 13
(a)Between 2027 through 2028,there is a $37 million decrease in revenue
requirement and an increase in benefits.The net increase in benefits is from:
Benefits of $3 million attributed to lower capital recovery from the
depreciation of the rate base;
Benefits of $10 million from higher production tax credit (PTC)value,
which escalates over time;
Benefits of $5 million from lower net power costs (NPC)from wind
repowering,which consists of the Planning and Risk (PaR)mean for fuel,
front office transactions (FOT),long-term contracts,and system
balancing;
Benefits of $19 million due to lower fixed costs that include up-front
capital costs of new resources,fixed run-rate operating costs for new and
existing resources,and any applicable decommissioning costs,due to the
removal of a thermal single-cycle combustion turbine (SCCT)addition in
2028.
(b)Between 2038 and 2039,there is a $48 million decrease in revenue
requirement and an increase in benefits.Over this period,the incremental
change in wind volume increases by approximately 1,350 gigawatt-hours
(GWh),capturing the full output of wind facilities that would otherwise have
hit the end of their useful lives if not repowered.The net increase in benefits is
from:
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 1st Set Data Request 13
Benefits of $161 million driven by lower NPC partiallyoffset by higher
system fixed costs of $69 million.
Benefits of $13 million due to a reduction in cost of emissions;
Costs of $32 million from higher repowered project costs due to existing
wind retirements;and,
Costs of $25 million from higher variable costs.
(c)Please refer to the confidential work papers that accompanied the Direct
Testimony of Company witness,Rick T.Link,specifically the folder "Other
Summary Reports",file "RePower Data 20170516 LGIA Limit vl3".The
PTCs for existing wind are reported on the "Summary"tab line 30.For the
repowered wind,the PTCs are reported on line 13.
(d)Please refer to the Company's response to subpart (c)above.
Recordholder:Dan Swan
Sponsor:Rick Link
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16*Set Data Request 14
IIPA Data Request 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?
Response to IIPA Data Request 14
(a)Please refer to the confidential work papers that accompanied the Direct
Testimony of Company witness,Rick T.Link,specifically the folder
"Exhibits Figures Tables",file "Repower Results Direct Testimony".The
incremental repower wind generation is reported on tab "Price-Policy Annual
-PaR"and line 51 "Net Change in Repower GWh".
(b)The production-tax-credit (PTC)value for repowered wind in the annual
revenue requirement is zero during the years 2037 through 2050 because
PTCs expire toward the end of 2030.
Recordholder:Dan Swan
Sponsor:Rick Link
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 161 Set Data Request 15
IIPA Data Request 15
On page 9 of Mr.Lar[sjen's Direct Testimony it is stated that:"As existing
equipment is replaced by repowering,the Company will transfer the replaced
assets from gross EPlS to the ADR,thereby reducing depreciation expense on 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,why would
these plant assets be removed from gross EPIS upon repowering and then put
back in later?
Response to IIPA Data Request 15
As existing equipment is replaced,Federal Energy Regulatory Commission
(FERC)accounting guidelines require that the replaced equipment be transferred
from gross electric plant in service (EPIS)to accumulated depreciation reserve
(ADR).The replaced equipment investment will not be transferred back to gross
EPIS,as suggested in the data request above,but will remain in ADR until the
wind project is retired from service.
Depreciation expense is calculated by multiplyingthe most recently approved
depreciation rate by the gross EPIS balance.Transferring the replaced investment
from gross EPIS to ADR will have the effect of reducing the annual depreciation
expense by the amount that would have been calculated for the replaced
repowered investment.At a future depreciation rate study,the depreciation rates
will be set at a rate sufficient to recover the remaining net wind investment,
includingthe replaced equipment transferred to ADR that was not fully
depreciated when transferred.
Recordholder:Steve McDougal
Sponsor:Jeff Larsen
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16'Set Data Request 16
IIPA Data Request 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 production tax 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 credit 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.
Response to IIPA Data Request 16
(a)The Company objects to the request to the extent it seeks information
protected by the attorney-client privilege or the attorney work product
doctrine.Without waiving this objection,the Company responds as follows:
The Company has assessed each of the relevant criteria for qualifyingthe
repowering projects for the full value of available production tax credits
(PTCs)consistent with applicable Internal Revenue Service (IRS)guidance.
This assessment has included:(1)whether the 2016 safe-harbor purchases
from the turbine vendors are sufficient to satisfy the five-percent safe harbor
for retrofitted facilities (Section 6 of IRS Notice 2016-31);(2)whether the
projects will be able to be placed into service by the end of the fourth calendar
year followingthe year construction began (i.e.,December 31,2020,for
construction that began in 2016)consistent with the four-year continuitysafe
harbor (Section 3 of IRS Notice 2016-31);and (3)whether each turbine to be
repowered will meet the requirements of the IRS 80/20 Rule (IRS Revenue
Ruling 94-3 l).
For the Company's analysis of each project's conformance with the five-
percent safe-harbor requirement,please refer to Confidential Attachment IIPA
16-1.For the Company's construction schedule indicating completion of all
repowering projects by the December 31,2020 deadline to satisfy the four-
year continuitysafe hyarbor,please refer to the detailed project schedule for
the repowering projects provided in the Direct Testimony of Company
witness,Timothy J.Hemstreet,specifically Exhibit No.5.For the Company's
80/20 Rule calculations demonstrating the ability of each repowering project
to meet 80/20 rule requirements,please refer to Confidential Attachment IIPA
16-2.
(b)To address potential cost overrun risk,the Company procured safe-harbor
equipment in 2016 sufficient to satisfy at least six percent of applicable
PAC-E-17-06 /Rocky Mountain Power
September 14,2017
IIPA 16*Set Data Request 16
project costs for each repowering project (please refer to Confidential
Attachment IIPA 16-1).Because turbine-supply costs for the projects are
known and fixed-and since those costs make up the overwhelming majority
of project costs-it is very unlikely that cost overruns could render the 2016
safe-harbor investments insufficient to meet the five-percent requirement.
Nonetheless,if cost overruns had the potential to impact the ability of the
projects to qualify for PTC,the Company would have the ability to make
adjustments to the project to address this scenario.For instance,the Company
could reduce the number of turbines repowered so that the safe-harbor
equipment acquired in 2016 would be sufficient to qualify a particular
repowering project for the full value of the PTC.Alternatively,the Company
could acquire additional safe-harbor equipment to separately qualify a number
of turbines that could not be qualified with the 2016 safe-harbor equipment,
albeit at a potentiallyreduced PTC value for that portion of the project.
Confidential information is provided subject to the protective order in this
proceeding.
Recordholder:Tim Hemstreet and Jonathan Hale
Sponsor:Tim Hemstreet