20170925Utah_DPU Set 3(1-24).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVIS10N OF PACIFICORP
August 17,2017
Erika Tedder
Division of Public Utilities
160 E 300 S,4th Floor
Salt Lake City,UT 84114
[e-mail]
[e-mail](C)
RE:UT Docket No.17-035-39
DPU 3rd Set Data Request (1-24)
Please find enclosed Rocky Mountain Power's Responses to DPU 3rd Set Data Requests 3.1-
3.24.Also provided are Attachments DPU 3.7 -(1-2)and 3.15.Provided on the enclosed
Confidential CD are Confidential Attachments DPU 3.7 -3,3.13,and 3.20 and Confidential
Response to DPU 3.20.Confidential information is provided subject to Public Service
Commission of Utah (UPSC)Rules 746-1-602 and 746-1-603.
If you have any questions,please call Tarie Hansen at [phone].
Sincerely,
Bob Lively
Manager,Regulation
Enclosures
C.c.:Dan Kohler/DPU (C)
Dan Peac/DPU [e-mail] (C)(W)
Aliea Afnan/DPU [e-mail] (W)
[e-mail]_rn (W)
Béla Vastag/OCS [e-mail](C)
Philip Hayet/OCS p_hayet@j)Renn.com(C)
Gary A.Dodge/UAE gdo_dge@hj_dla_w.com(C)
Kevin Higgins/UAE M (C)
Neal Townsend/UAE (C)(W)
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.1
DPU Data Request 3.1
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 54-62,noting
that repowering older facilities with new,higher capacity equipment can result in fewer
turbines needed to produce the same energy and capacity.Did the Company evaluate the
comparative costs and benefits of this repowering approach for its older wind facilities?
Please provide all analysis and documentation produced by or for the Company related to
this issue.
Response to DPU Data Request 3.1
The only wind facility that falls into the "older"category described in the Direct
Testimony of Company witness,TimothyJ.Hemstreet is the Foote Creek project.As
noted in Mr.Hemstreet's testimony,lines 73-80,the feasibility and economics of
repowering this project is still under evaluation.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.2
DPU Data Request 3.2
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 94-96:Do the
referenced increases in capacity factor pertain to each individual turbine generator,or the
total wind project average?Please provide the change in capacity factor by turbine
generator,and all reports and analysis supporting the increases in capacity factor.
Response to DPU Data Request 3.2
The referenced testimony describes the range of increased energy production from the
wind projects on an average basis for each project.This range reflects the increases per
Project as shown in column 5 of Table 2 in Confidential Exhibit RMP (TJH-3).The
average energy increase for each repoweredturbine at the projects is siwn in column 4
of this table.The Company does not have an estimate of the increased capacity factor for
individual wind turbines within the wind projects.Please refer to the Company's
response to DPU Data Request 1.5;specifically Confidential Attachment DPU 1.5,for
documentation of the estimated energy increases as a result of repowering.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.3
DPU Data Request 3.3
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 89-194:Has the
Company conducted any formal assessment of the risk that the IRS deems the repowered
projects ineligible for the PTC?If so,please provide any analysis or documentation of
this risk assessment and impacts on the economic analysis.
Response to DPU Data Request 3.3
The Company objects to the request to the extent it seeks information protected by the
attorney-client privilege and work product doctrines.Without waiving the objection,the
Company provides the followingresponse:
The Company has assessed each of the relevant criteria for qualifyingthe repowering
projects for the full value of available production tax credits ("PTC")consistent with
applicable Internal Revenue Service ("IRS")guidance.This assessment has included:(1)
whether the 2016 safe harbor purchases from the turbine supply 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 94-31).
For the Company's analysis of each project's conformance with the five percent Safe
Harbor requirement,please refer to the Company's response to OCS Data Request 1.50;
specifically Confidential Attachment OCS 1.50.For the Company's construction
schedule indicating completion of all repowering projects by the December 31,2020
deadline of the four-year ContinuitySafe Harbor,please refer to the detailed project
schedule for the repowering projects provided in the Direct Testimony of Company
witness,Timothy J.Hemstreet;specifically Exhibit RMP_(TJH-5).For the Company's
analysis methods for determining the fair market value (FMV)of the retained project
assets,please refer to the Company's response to DPU Data Request 1.13.For the
Company's 80/20 Rule calculations demonstrating the ability of each repowering project
to meet 80/20 Rule requirements,please refer to the Company's response to OCS Data
Request 1.55;specifically Confidential Attachment OCS 1.55.
Because the Company has determined that the repowering projects will meet all
applicable IRS requirements necessary to qualify the projects for the full value of PTCs,
the Company has not developed an analysis to evaluatethe impacts of the IRS
determining that the projects were ineligible for the PTC.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.4
DPU Data Request 3.4
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 108-113:
(a)Please provide a copy of referenced IRS guidance on safe harbor investments.
(b)Provide any additional internal memoranda,internal presentations,or analysis on the
interpretation of the IRS guidance and eligibilityof the proposed repower projects for
the safe harbor rules.
(c)Does the referenced five percent rule apply to the total proposed project (i.e.all
projects proposed for repowering)or for each turbine individually?
(d)Provide an accounting of total project costs and 2016 expendituresmade by the
Company to complywith the five percent rule.
(e)Has the Company conducted any formal assessment of the risk that cost overruns
could result in 2016 expendituresbeing insufficient to satisfy the five percent rule?If
so,please provide any analysis or documentation of this risk assessment and impacts
on the economic analysis.
Response to DPU Data Request 3.4
(a)Please refer to the Company's response to OCS Data Request 1.58.In reference to
this portion of the testimony,the relevant Internal Revenue Service (IRS)guidance on
safe harbor investments as applied to retrofitted facilities is Notice 2016-31,which is
publicly available and can be accessed by utilizingthe followingwebsite link:
https://www.irs.gov/irb/2016-23_IRB/ar07.html
(b)See Response to DPU Data Request 3.3.
(c)The referenced five percent rule is applicable to each separate wind project.
(d)Please refer to the Company's response to OCS Data Request 1.50;specifically
Confidential Attachment OCS 1.50,which provides the 5 percent safe harbor
calculations by project.Please refer to the Company's response to OCS Data Request
1.27 subpart (a),which provides the 2016 expendituresmade by the Company to
comply with the 5 percent rule.
(e)The Company has not conducted any formal assessment of the risk of cost overruns
rendering the 2016 expendituresinsufficient to meet the 5 percent rule.To address the
potential for cost overruns,the Company procured safe harbor equipment in 2016 of
sufficient value to attain a safe harbor percentage of at least 6 percent for each
project.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.5
DPU Data Request 3.5
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 114-121:
(a)Provide a copy of the IRS "additional guidance"regarding continuous efforts.
(b)Provide any additional internal memoranda,internal presentations,or analysis on the
interpretation of the continuous-efforts standard.
(c)Please provide all documentation and analysis supporting the statement that the IRS
continuous-efforts standard "is a difficult standard to meet."
(d)Has the Company conducted any formal assessment of the risk that the IRS deems the
repowered projects ineligible for the PTC under the continuous-efforts standard?If
so,please provide any analysis or documentation of this risk assessment and impacts
on the economic analysis.
Response to DPU Data Request 3.5
The Company objects to the request to the extent it seeks information protected by the
attorney-client privilege and work product doctrines.Without waiving the objection,the
Company provides the followingresponse:
(a)The "additional guidance"referred to is Internal Revenue Service (IRS)Notice 2016-
31.Please refer to the Company's response to DPU Data Request 3.4 subpart (a).
(b)None.
(c)IRS Notice 2016-31 provides for a safe harbor to meet the continuityrequirement of
physical construction for any wind facility placed in service by the end of the fourth
calendar year after the year that physical construction began.If the safe harbor is not
met,then the taxpayer will be required to show that under the particular facts and
circumstances,that the continuityrequirement of physical construction was met.
Section 4.02(2)of the Notice provides for a non-exclusive list of excusable
disruptions for a delay in physical construction.However,if physical construction
began in 2016 and the facility was placed in service after December 31,2020 the
taxpayer would be required to prove the existence of excusable disruptions for
starting construction in 2016 and placing it in service after 2020.Detailed
documentation would be required to prove an excusable disruption for a more than
four year period.Any failure to prove an excusable disruption would result in the
denial of any production tax credits (PTC)for the facility.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.5
(d)The Company has not conducted any formal assessment of the risk that the IRS
deems the repoweredprojects ineligible for the PTCs under the continuous-efforts
standard.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.6
DPU Data Request 3.6
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 139-150:
(a)Please provide a copy of IRS Notice 2016-31.
(b)Provide any additional internal memoranda,internal presentations,or analysis on the
interpretation of the IRS guidance and eligibilityof the proposed repower projects for
the PTC under this guidance.
(c)Provide the "turbine-by-turbine"analysis for each turbine to be repowered under the
proposal,demonstrating eligibilityunder the 80/20 rule.
(d)Has the Company conducted any formal assessment of the risk that the IRS deems the
repowered projects ineligible for the PTC under the 80/20 rule?If so,please provide
any analysis or documentation of this risk assessment and impacts on the economic
analysis.
Response to DPU Data Request 3.6
(a)Please refer to the Company's response to DPU Data Request 3.4 subpart (a).
(b)Please refer to the Company's response to DPU Data Requests 3.3 and 3.5.
(c)Please refer to the Company's response to OCS Data Request 1.55;specifically
Confidential Attachment OCS 1.55.
(d)None.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.7
DPU Data Request 3.7
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 213-227:
(a)Provide all documentation and analysis supporting the conclusion that a larger risk
zone "does not necessarily correlate with an increased risk of avian impacts at
existing turbine sites."
(b)Provide all studies performed by or for the Company regarding the avian impact of
the repowering project.
(c)Provide a copy of the Company's informed-curtailment protocols.
(d)Provide copies of all referenced reports submitted to the WyomingGame and Fish
Department and the U.S.Fish and Wildlife Service.
(e)Does the repowering project require any new environmental permits,related to avian
impacts or otherwise?If so,please identify the required permits.
(f)This portion of testimony specifically addresses avian impacts on Wyomingwind
facilities.Please provide the same detail (included in testimony and in response to
the questions above)for wind facilities in other states.
Response to DPU Data Request 3.7
(a)Project mortality estimates are based on pre-construction usage and do not account
for habituation /avoidance of existing operating turbines (which is relevant to
repowering since no new turbines will be constructed and most of the turbines have
been operating greater than eight years),turbine down times,and /or avoidance and
minimization actions taken by the Company.These avoidance and minimization
actions can include informed curtailment,carrion removal,habitat modification,
raptor prey reduction,detection and deterrence testing,and adjustments to wind
turbine operations.Post-construction monitoring of the turbines can identify if actual
increases in avian mortality have occurred followingrepowering and will be used to
inform the Company's Bird and Bat Conservation Strategies and Eagle Conservation
Plans developedpursuant to the Company's applications to the United States (U.S.)
Fish and Wildlife Service (FWS)for eagle take permits.
(b)The Company has not performed new studies regarding the avian impacts of
repowering.For the Marengo wind project,the Company has updated the pre-
construction avian exposure index at the request of county.Please refer to Attachment
DPU 3.7 -1.
(c)Please refer to Attachment DPU 3.7 -2.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.7
(d)Please refer to Confidential Attachment DPU 3.7 -3,which provides annual reports
for the 2016 operating year submitted to the WyomingGame and Fish Department
(GFD),the Oregon Department of Fish and Wildlife (DFW),the Washington DFW,
and the U.S.FWS.
(e)The Company does not anticipate any new environmental permits will be required.
(f)Please refer to the Company's responses to subparts (a)through (e)above,and to
Confidential Attachment DPU 3.7 -3.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.8
DPU Data Request 3.8
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony lines 258-261:Provide
all documentation,studies,and analysis supporting the conclusion that these larger rotors
do not require upgraded foundations and towers at the proposed repowering sites.
Response to DPU Data Request 3.8
Please refer to the Company's response to DPU Data Request 1.4 subpart (d).
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.9
DPU Data Request 3.9
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 273-278:What is
the status of the generator interconnection applications?When does the Company expect
final decisions on the applications?
Response to DPU Data Request 3.9
Queue numbers for all large generator interconnection agreement ("LGIA")applications
have been received and system impact studies ("SIS")are currentlybeing performed.
These studies evaluate the impact of proposed increased output of the repowered facilities
on the reliabilityof the transmission system.After the studies are completed,facility
studies are required prior to executing the LGIAs.
Based on these requirements and the significant number of LGIA applications received
by PacifiCorp's transmission merchant for the same geographical area,the Company
anticipates having executed LGIAs for Marengo I and Marengo II in Ql 2018,and for the
rest of the projects in the Q2 2018 and Q3 2018.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.10
DPU Data Request 3.10
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 303-317:
(a)Please provide a quantification of the expected costs and benefits to customers of
lower ongoing operational costs resulting from the repowering.Provide all work
papers supporting this analysis.Work papers should be provided in electronic
spreadsheet format with formulas intact.
Response to DPU Data Request 3.10
(a)While,the Company has not prepared an analysis to isolate the expected costs and
benefits to customers of lower operational costs resulting from repowering,the
economic impact is reflected in the financial analysis in the avoided capital
expendituresprior to repowering due to failed wind turbines that are unable to be
returned to service economically prior to repowering,and in reduced ongoing capital
costs associated with major component refurbishments and replacements following
repowering.Please refer to the Company's response to DPU Data Request 1.9;
specifically Confidential Attachment DPU 1.9,the file entitled "Wind Repower
CAPEX (May 10 2017)CONF"which contains the work papers in which capital
costs for the repowering case and status quo case are shown.In these work papers,the
reduced operating capital costs are quantified by project.Please refer to the tab
entitled "CAPEX MODEL INPUTS"and the changes in run-rate capital costs by
project in rows 43 through 54.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.11
DPU Data Request 3.11
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 326-336:
(a)Please identify the timing and number of failures of the referenced gearboxes for each
wind project.
(b)Please quantifythe "increased capital costs"experiencedby the Company in recent
years.
Response to DPU Data Request 3.11
(a)Please refer to the Company's response to DPU Data Request 2.1.
(b)Please refer to the Company's response to DPU Data Request 2.6;specifically
Confidential Attachment DPU 2.6 -1,for a quantification of these costs.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.12
DPU Data Request 3.12
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 348-358:Please
explain how the replacement of the ten reference gearboxes is factored into the economic
analysis,and provide specific references to any work papers where this is represented.
Response to DPU Data Request 3.12
The number cited on line 350 of the Direct Testimony of Company witness,TimothyJ.
Hemstreet is in error.The correct number is 12 gearboxes.The Company's financial
analysis assumes that 12 impacted gearboxes at the Glenrock /RollingHills site that are
within the 32 turbines that are not repowered will be replaced over the next 10 year
period (2017 through 2026)at the average costs for a complete gearbox replacement of
$400,000,adjusted for inflation.
Please refer to the Company's response to DPU Data Request 1.9;specifically
Confidential Attachment DPU 1.9,the spreadsheet entitled "Wind Repower CAPEX
(May 10 2017)CONF"which contains work papers in which these capital costs are
represented.Please refer to the tab entitled "Repower CAPEX",and rows 53,54 and 60,
which shows the allocated capital costs for the replacement of these 12 gearboxes.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.13
DPU Data Request 3.13
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 359-367:Please
explain why the blade maintenance costs at GoodnoeHills is higher than other facilities.
Please quantifythe expected reduced capital costs associated with the blade replacement
at GoodnoeHills,and provide any analysis supporting this quantification.
Response to DPU Data Request 3.13
Regarding the cause of higher blade capital costs at the Goodnoe Hills project,please
refer to the Company's response to DPU Data Request 1.8.The Company's financial
analysis assumes that after repowering,capital costs for blade refurbishments and
replacements at the GoodnoeHills project will reflect average component replacement
costs experiencedat the Company's other wind facilities.Please refer to Confidential
Attachment DPU 3.13,which provides a quantification of these reduced capital costs.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.14
DPU Data Request 3.14
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 396-399:
Provide a summary of timing and cause of all under-frequency events experiencedon the
Company's system over the last five years.
Response to DPU Data Request 3.14
The data referencing any "under-frequency event"has not been compiled.
Frequency events are common across the Westem ElectricityCoordinating Council
(WECC)Westem Interconnection,and therefore frequency deviations on the PacifiCorp
share of the system can be caused by events anywhere in the Westem
Interconnection.Likewise,as part of the Westem Interconnection PacifiCorp shares part
of the responsibility for providing frequency response to the interconnection based on the
percentage of load and generationthat is within the PacifiCorp balancing authorityareas
(BAA).This frequency response primarily comes from the govemor action of generating
resources.Per the North American Electric ReliabilityCorporation (NERC)guideline on
primary frequency response,generator govemors should be tuned to provide frequency
response (an increase or decrease in generation from their base point)any time the
frequency falls below 59.965 hertz (Hz)or goes above 60.035 Hz.Hourly sampled data
from the past two years shows that the frequency in the Westem Interconnection drops
below 59.965 or above 60.035 Hz at some point during 84 percent of all hours,requiring
govemor response of the generatingfleet during 84 percent of all hours.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.15
DPU Data Request 3.15
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 402-416:
(a)Please provide an analysis of the total incremental costs and benefits of the
WindFREE equipment,compared to a repowering case without adding the
WindFREE equipment.
(b)Please provide details on the capital cost associated with the addition of the
WindFREE equipment,as well as the ongoing cost of operating the WindCONTROL
system.
(c)Please provide any system studies identifying a need for additional reactive power on
the Company's system.
(d)Has the Company identified any "grid reinforcements specifically designed for no-
wind conditions"that the addition of the WindFREE equipment can avoid?If so,
provide details on the expected avoided costs.
(e)Please provide a quantification of the benefits associated with the more economic
commitment of other generatingresources that would be possible after the addition of
the WindFREE equipment.
(f)Please provide all documentation and analysis related to any enhancement of grid
security provided by the addition of the WindFREE equipment.
Response to DPU Data Request 3.15
(a)The Company has not prepared such an analysis and cannot until the benefits of the
WindFREE equipment can be factored into the Company's financial analysis
followingthe completion of transmission studies.The Company's financial analysis
of the repowering project has included the cost of the WindFREE and WindINERTIA
features,but has yet to account for the benefits of this equipment,which will be
determinedwith the completion of transmission studies.Please refer to the
Company's response to OCS Data Request 1.20 regarding the cost of the WindFREE
and WindINERTIA features.These features represent options that can be added to the
turbines the Company orders from General Electric (GE).If the benefits of the
features as determined from transmission studies do not justify the increased costs,
the Company will not order these features.However,the Company believes the
benefits will outweigh the costs.
(b)Please refer to the Company's response to OCS Data Request 1.20 and OCS Data
Request 1.26 regarding WindFREE capital costs.The Company does not have an
estimate of the ongoing costs of operating the WindCONTROL system as those
feature costs are not separately tracked from other costs associated with project
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.15
control and supervisory control and data acquisition (SCADA)systems.There are no
known incremental ongoing operating costs associated with the WindFREE
equipment.
(c)Please refer to Attachment DPU 3.15,which provides a copy of the Western
Electricity Coordinating Council (WECC)path rating studies for Energy Gateway
West,which included the Aeolus West transmission path.The Aeolus West path was
granted Phase 3 status by WECC Planning Coordination Committee (PCC)on
January 5,2011.These studies identify a need for additional reactive power on the
Company's system.
Preliminary North American Electric ReliabilityCorporation (NERC)FAC-013-2
Transmission Assessment studies are currentlyunderway;the completed studies will
be finalized in 2020.System Operating Limit (SOL)studies required by Peak
Reliabilitywill be completed six months prior to the new Aeolus -Bridger /Anticline
line going in-service in December 2020.
(d)The Company has not yet completed analysis of these potential avoided costs.
(e)The Company is not able to quantifythese benefits at this time until transmission
studies are completed.
(f)The Company has no such analysis at this time.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.16
DPU Data Request 3.16
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 417-424:
(a)Please provide an analysis of the total incremental costs and benefits of the
WindINERTIA equipment,compared to a repowering case without adding the
WindINERTIA equipment.
(b)Please provide details on the capital cost associated with the addition of the
WindINERTIA equipment,as well as the ongoing cost of operating the
WindINERTIA system.
Response to DPU Data Request 3.16
Please refer to the Company's response to DPU Data Request DPU 3.14.
(a)The Company has not prepared such an analysis and cannot until the benefits of the
WindINERTIA equipment can be factored into the Company's financial analysis
followingthe completion of transmission studies.Please see also the Company's
response to Data Request DPU 3.15.
(b)Please refer to the Company's response to OCS Data Request 1.20 and OCS Data
Request 1.26.There are no known incremental costs associated with ongoing
operation of the WindINERTIA system.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.17
DPU Data Request 3.17
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 430-440:
(a)Provide any completed system studies demonstrating the need for additional voltage
support on the Company's system.
(b)Please provide an estimate of when the ongoing transmission studies will be
completed.
Response to DPU Data Request 3.17
The Western ElectricityCoordinating Council (WECC)path rating studies for Energy
Gateway West,which included the Aeolus West transmission path,are provided with the
Company's response to DPU Data Request 3.15;specifically Attachment DPU 3.15.On
January 5,2011,the Aeolus West path was granted Phase 3 status by WECC planning
coordination committee (PCC).These system studies demonstrated the need for
additional voltage support on the Company's system.
While preliminaryNorth American Electric ReliabilityCorporation (NERC)FAC-013-2
transmission assessment studies are currentlyunderway,the completed studies will be
finalized in 2020.System operating limit (SOL)studies required by Peak Reliabilitywill
be completed six months prior to the new Aeolus -Bridger /Anticline line going in-
service in December 2020.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.18
DPU Data Request 3.18
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 442-445:
(a)Are all wind projects scheduled to retire at the end of their 30-year depreciation
period?
(b)Provide any retirement studies indicating that the wind facilities will need to be
retired after 30 years.
Response to DPU Data Request 3.18
(a)But for repowering,the wind projects are all currentlyassumed to have a 30-year
asset life.For planning purposes,the Company assumes generationfrom these
projects ceases at the end of their depreciablelife.
(b)The Company has no such studies.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.19
DPU Data Request 3.19
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 450-466:
(a)Do the design standards indicated in this section include the useful life of the
foundations and towers?
(b)What evidence is the Company relying on to support its assumption that the useful
life of the existing towers can be extended 10 years?Provide any studies or analysis
supporting this assumption.
(c)When will the third-partydesign assessments referenced in this section be completed?
Provide any completed third-partydesign assessments that have already been
completed.
Response to DPU Data Request 3.19
(a)The design standards evaluate the useful life of the towers.Evaluation of the useful
life of the foundations is the responsibility of the project owner.
(b)The Company is relying upon the fact that new wind developments designed to these
same standards are assumed to have a 30-year life.
(c)The Company anticipates that the third-partydesign assessments will be completed
by mid-December 2017.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.20
DPU Data Request 3.20
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 473-486:
(a)Provide a detailed timeline on the completion of any studies not yet complete.
(b)Provide all documentation,studies,and support for the conclusion that "future
foundation loads at some of the facilities...are less than the original design loads"
due to the newer load-mitigation controls.
Confidential Response to DPU Data Request 3.20
(a)The Company expects that foundation studies for the Leaning Juniper and Goodnoe
Hills projects will be completed by the end of October 2017.
(b)Please refer to Confidential Attachment DPU 3.20 and the Company's response to
Data Request DPU 1.4,specifically Confidential Attachment DPU 1.4.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.21
DPU Data Request 3.21
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 487-493:
(a)Provide all reports and assessments completedby the Company's consultant
regarding foundation condition.
(b)The testimony indicates that not all foundations have been assessed.Provide a
detailed schedule and timeline for the completion of this assessment.
(c)Has the Company conducted any formal assessment of the risk that the foundations
and/or towers are not suitable for the new turbines,such that the economic benefits of
the repowering may be impacted?If so,please provide any analysis or
documentation of this risk assessment.
Response to DPU Data Request 3.21
(a)Please refer to the Company's response to DPU Data Request 1.9.
(b)Please refer to the Company's response to DPU Data Request 3.20 subpart (a).
(c)The Company has conducted no such assessment or analysis.The Company will not
repower a turbine unless the foundation supporting the turbine is documented through
engineering analysis to be suitable for the new turbine foundation loads.Similarly,
the turbine suppliers will not supply equipment to repower a wind turbine unless
engineering analysis demonstrates the tower is suitable for the new equipment.The
equipment suppliers will be unable to obtain the contractuallyrequired third party
design certification without verifying the suitabilityof the new turbines with the
existing towers.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.22
DPU Data Request 3.22
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 507-510,what is
the significance of the March 31,2020 date for completing the retrofits?
Response to DPU Data Request 3.22
The date represents the start of the 2020 construction season,and due to the anticipated
high demand for equipment in 2020,a longer lead time is required by the manufacturer
for equipment to be delivered in 2020.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.23
DPU Data Request 3.23
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 523-532:Do the
agreements with GE and Vestas include any provisions to hold the suppliers liable if
deliveryand installation of the turbines is delayed such that the projects are not ultimately
eligible for the PTC?If so,please provide the applicable contract language.
Response to DPU Data Request 3.23
The Company cannot respond at this time because the contracts remain under negotiation
and are not yet executed.The Company will supplement this response when the contracts
have been finalized.
17-035-39 /Rocky Mountain Power
August 17,2017
DPU Data Request 3.24
DPU Data Request 3.24
Hemstreet Testimony.In reference to Mr.Hemstreet's Testimony,lines 552-581:
(a)Has the Company conducted any formal assessment of the risk that permitting could
be delayedor denied such that the repower would not be completed,or would be
delayed beyond the PTC deadline?If so,please provide any analysis or
documentation of this risk assessment.
Response to DPU Data Request 3.24
(a)The Company has not conducted any formal assessment of the risk that permitting
could delay the repowering projects.The Company is not aware of any additional
environmental permits being required to implement the repowering projects,and
repowering can be conducted consistent with the requirements of the existing state
and countypermits for the facilities.Because only limited,standard buildingupgrade
permits need to be acquired,the Company does not believe permitting poses a
significant schedule risk to the project.