20170918IIPA 20-29 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:[e-mail]
Attorneyfor Intervenor Idaho 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 FOURTH
REPOWERING SET OF DATA REQUESTS
Idaho Irrigation Pumpers,Inc.,by and through counsel,hereby submits its fourth Data
Requests to Rocky Mountain Power,pursuant to Commission Rule 225,as follows:
20.What is the total expected installed cost of the facilities to repower the proposed wind
facilities?
21.What is the unrecoveredcost of the existing wind facilities that will be replaced by the
repowering?
22.Assuming full recovery,what is the estimated future cost of the unrecovered
existing/replaced wind facilities by year,broken down by return,depreciation,taxes,etc.?
What general assumptions go into the estimated costs?
23 What is the annual change in wind energy generated and the Production Tax Credits resulting
from the repowering?
24.In Figure 1.7 of the Company's 2017 IRP there is listed the Preferred Portfolio Coal Unit
Retirements.
a.Are these retirements the same as those used as input to the cost analysis for the impact
of the repowering?If not,what were the retirements used?
b.Are these retirements the same as those used as input to the cost analysis for the base
case without repowering?If not,what were the retirements used?
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FOURTH SET OF DATA REQUESTS-Page 1
c.What is the unrecovered cost of these retired facilities that will be replaced by the
repowering?
d.Assuming full recovery,what is the estimated future cost of the retired facilities by year,
broken down by return,depreciation,taxes,etc.?What general assumptions go into the
estimated costs?
e.Does the Company propose to recover the cost of these retired facilities in the same
manner as that of the wind facilities that were repowered (continued recovery of
undepreciated costs)?
f.In the Company's financial analysis of the repowering,is the same cost recovery used
for the retired units in both the with and without repowering scenarios?
25.If the Company's analysis of Benefit/Cost of Wind Repowering in Table 2 of Mr.Link's
testimony containedthe same coal plant retirement dates for the with and without repowering
scenarios,please rerun the analysis for the "repowering"scenario with the same retirements
used and the "without repowering"scenario using the retirements found in Table 5.3 of the
Company's Updated 2015 IRP.
26.The 2021 retirement of 387 MW of the Cholla 4 facility in Figure 1.7 of the Company's 2017
IRP is five years before the retirement listed on Table 5.3 of the Company's Updated 2015
IRP (March 31,2016).According to Table 5.3 of the Company's 2017 IRP,the "Assumed
End-of-Life"for Cholla 4 is 2042.
a.Why was Cholla 4 assumed to be retired in 2025 according to the Company's Updated
2015 IRP?
b.Why was Cholla 4 assumed to be retired in 2020 according to the Company's 2017 IRP?
c.Would Cholla 4 be assumed to be retired in 2020 if the repowered wind project did not
take place?What would the retirement date be in that case?
d.Would Cholla 4 be assumed to be retired in 2020 if the new wind project did not take
place?What would the retirement date be in that case?
e.Would Cholla 4 be assumed to be retired in 2020 if both the new wind project and
repowering did not take place?What would the retirement date be in that case?
27.The retirement of 82 MW of the Craig facility in Figure 1.7 of the Company's 2017 IRP
takes place in 2026,but does not take place during the 20-year planning horizon ending 2034
on Table 5.3 of the Company's Updated 2015 IRP (March 31,2016).According to Table 5.3
of the Company's 2017 IRP,the "Assumed End-of-Life"for Craig is 2034.
a.Why was Craig assumed to not be retired through2034 according to the Company's
Updated 2015 IRP?
IDAHO IRRIGATION PUMPERSASSOCIATION,INC.FOURTH SET OF DATA REQUESTS -Page2
b.Why was Craig assumed to be retired in 2025 according to the Company's 2017 IRP?
c.Would Craig be assumed to be retired in 2025 if the repowered wind project did not take
place?What would the retirement date be in that case?
d.Would Craig be assumed to be retired in 2025 if the new wind project did not take place?
What would the retirement date be in that case?
f.Would Craig be assumed to be retired in 2025 if both the new wind project and
repowering did not take place?What would the retirement date be in that case?
28.The retirement of approximately 350 MW of the Jim Bridger facility in Figure 1.7 of the
Company's 2017 IRP takes place in 2029,but does not take place during the 20-year
planning horizon ending 2034 on Table 5.3 of the Company's Updated 2015 IRP (March 31,
2016).According to Table 5.3 of the Company's 2017 IRP,the "Assumed End-of-Life"for
Jim Bridger is 2037.
a.Why was this unit at Jim Bridger assumed to not be retired through 2034 according to the
Company's Updated 2015 IRP?
b.Why was one Jim Bridger unit assumed to be retired in 2029 according to the Company's
2017 IRP?
c.Would the first unit at Jim Bridger be assumed to be retired in 2029 if the repowered
wind project did not take place?What would the retirement date be in that case?
d.Would the first unit at Jim Bridger be assumed to be retired in 2029 if the new wind
project did not take place?What would the retirement date be in that case?
e.Would the first unit at Jim Bridger be assumed to be retired in 2029 if both the new wind
project and repowering did not take place?What would the retirement date be in that
case?
29.The retirement of approximately 350 MW of the second Jim Bridger facility in Figure 1.7 of
the Company's 2017 IRP takes place in 2033,but does not take place during the 20-year
planning horizon ending 2034 on Table 5.3 of the Company's Updated2015 IRP (March 31,
2016).According to Table 5.3 of the Company's 2017 IRP,the "Assumed End-of-Life"for
Jim Bridger is 2037.
a.Why was this unit at Jim Bridger assumed to not be retired through 2034 according to the
Company's Updated 2015 IRP?
b.Why was this second Jim Bridger unit assumed to be retired in 2033 according to the
Company's 2017 IRP?
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FOURTH SET OF DATA REQUESTS-Page3
c.Would the second unit at Jim Bridger be assumed to be retired in 2033 if the repowered
wind project did not take place?What would the retirement date be in that case?
d.Would the second unit at Jim Bridger be assumed to be retired in 2033 if the new wind
project did not take place?What would the retirement date be in that case?
e.Would the second unit at Jim Bridger be assumed to be retired in 2033 if both the new
wind project and repowering did not take place?What would the retirement date be in
that case?
DATED this |fË day of September,2017.
pff &OLSEN
ERÌCi OTSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FOURTH SET OF DATA REQUESTS-Page 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this /day of September,2017,I served a true,correct
and complete copy of Idaho Irrigation Pum ers Association,Inc.Fourth Set of Data Requests to
each of the following,via U.S.Mail or private courier,email or hand delivery,as indicated below:
Diane M.Hanian,Secretary U.S.Mail
Idaho Public Utilities Commission Hand Delivered
P.O.Box 83720 Overnight Mail
472 W.Washington Street Telecopy (Fax)
Boise,ID 83720-0074 Electronic Mail (Email)
[e-mail]
Data Request Response Center -PacifiCorp U.S.Mail
Email:[e-mail] Hand Delivered
O Overnight Mail
O Telecopy (Fax)
Electronic Mail (Email)
Brandon Karpen U.S.Mail
Deputy AttorneyGeneral Hand Delivered
Idaho Public Utilities Commission Overnight Mail
P.O.Box 83720 Telecopy (Fax)
472 W.Washington Street (83702)Electronic Mail (Email)
Boise,ID 83720-0074
[e-mail]
Ted Weston U.S.Mail
Idaho Regulatory Affairs Manager Hand Delivered
Rocky Mountain Power Overnight Mail
1407 West North Temple,Suite 330 Telecopy (Fax)
Salt Lake City,Utah 84116 Electronic Mail (Email)
Email:[e-mail]
Yvonne R.Hogle U.S.Man
Assistant General Counsel Hand Delivered
Rocky Mountain Power OvernightMail
1407 West North Temple,Suite 320 Telecopy (Fax)
Salt Lake City,Utah 84116 Electronic Mail (Email)
Email:Yvonne.hogleRpacificorp.com
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FOURTH SET OF DATA REQUESTS -Page 5
Ronald L.Williams U.S.Maß
Williams Bradbury,P.C.Hand Delivered
P.O.Box 388 Overnight Mail
Boise,ID 83701 Telecopy (Fax)
Email:[e-mail] Electronic Mail (Email)
Jim Duke U.S.Mail
Idahoan Foods Hand Delivered
Email:[e-mail] OvernightMail
Telecopy (Fax)
Electronic Mail (Email)
Kyle Williams U.S.Man
BYU Idaho Hand Delivered
Email:[e-mail] Ovemight Man
Telecopy (Fax)
Electronic Mail (Email)
Val Steiner U.S.Mail
Nu-West Industries,Inc.Hand Delivered
Email:[e-mail] OvernightMail
Telecopy (Fax)
Electronic Mail (Email)
Randall C.Budge U.S.Maü
Racine,Olson,Nye &Budge,Chartered Hand Delivered
P.O.Box 1391;201 E.Center Overnight Mail
Pocatello,ID 83204-1391 Telecopy (Fax)
Email:[e-mail] Electronic Mail (Email)
Brubaker &Associates U.S.Man
16690 Swingley Ridge Rd.,#140 Hand Delivered
Chesterfield,MO 63017 Overnight Mail
Email:[e-mail] Telecopy (Fax)
[e-mail] Electronic Mail (Email)
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FOURTH SET OF DATA REQUESTS-Page 6