20170925Utah_DPU Set 7 (1-1-35).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PACIFICORP
September 1,2017
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 7th Set Data Request (1-35)
Please find enclosed Rocky Mountain Power's Responses to DPU 7th Set Data Requests 7.3-7.4,
7.10,7.18,7.22-7.23,7.28-7.29,7.32,and 7.34-7.35.The remaining responses will be provided
separately.Also provided are Attachments DPU 7.3 -l,7.32,and 7.35 -2.Provided on the
enclosed Confidential CD are Confidential Attachments DPU 7.3 -2,7.4,7.34 -(1-3),and 7.35-1
and Confidential Responses to DPU 7.18,7.22-7.23,7.28-7.29,7.32,and 7.34-7.35.
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].
Si y
Bob Lively
Manager,Regulation
Enclosures
C.c.:Dan Kohler/DPU (C)
Dan Peac/DPU (C)(W)
Aliea Afnan/DPU (W)
Béla Vastag/OCS bvastag@utahgov_(C)
Philip Hayet/OCS [e-mail]_m (C)
Gary A.Dodge/UAE ggodge@hidl_w.co_m (C)
Kevin Higgins/UAE (C)
Neal Townsend/UAE [e-mail](C)(W)
17-035-39 /Rocky Mountain Power
September 1,2017
DPU Data Request 7.3
DPU Data Request 7.3
Link Testimony.In reference to Mr.Link's Testimony,lines 344-359:
(a)Please provide all analysis and documentation supporting the 36.5 MW assumed
reduction in transfer capability.
(b)Is the 36.5 MW reduction in transfer capability applied in every hour of the study?
(c)Please provide a summary of transfer limit de-rates over the past 5 years.
(d)Provide any analysis performed by or for the Company to quantifythe economic
impact of the 36.5 MW de-rate.
Response to DPU Data Request 7.3
(a)Please refer to Attachment DPU 7.3-1,which provides the calculations supporting the
referenced values.Also refer to Confidential Attachment DPU 7.3-2,which provides
additional supporting details
(b)Yes.
(c)Please refer to the Company's response to subpart (a)above.
(d)The 36.5 megawatts (MW)de-rate is included as a base assumption and eliminated in
cases when the new transmission project is assumed to be placed in service at the end
of October 2020 (i.e.,the sensitivity case in this proceeding).The economic impact is
therefore embedded in the system-level optimized outcome unique to every model
run.
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
September 1,2017
DPU Data Request 7.4
DPU Data Request 7.4
Link Testimony.In reference to Mr.Link's Testimony,lines 360-373:
(a)Provide all analysis and documentation supporting the l1.6 aMW of line loss
reduction.
(b)Please explain why the line-loss benefits were applied as a reduction in northeast
Wyoming load.
(c)Provide details on how the 11.6 aMW reduction in northeast Wyoming load was
shaped over the year (i.e.flat,shaped proportional to load,etc.).Please provide an
hourly 8760 strip of load reduction.
Response to DPU Data Request 7.4
(a)Please refer to Confidential Attachment DPU 7.4,which provides the calculations
supporting the referenced values.
(b)With line losses,a portion of the electrical energy at the source of production is lost
as it moves across the transmission system.When line losses are reduced,more
electrical energy can flow across the transmission system.Similarly,if load is
reduced in a given location,more electrical energy can flow across the transmission
system.By reducing load at a level that is tied to the incremental reduction in line
losses,additional electrical energy can flow across the transmission system,thereby
mimickingthe effect of an incremental reduction to assumed line losses.
(c)The l1.6 average megawatts (aMW)was modeled as a flat load reduction.
Confidential Attachment DPU 7.4 provides additional supporting details.
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
September 1,2017
DPU Data Request 7.10
DPU Data Request 7.10
Larsen Testimony.In reference to Mr.Larsen's Testimony,lines 231-232,stating that
"Under the current EBA,100 percent of the incremental NPC benefits of the wind
repowering project will be credited to customers...":
(a)Please explain how NPC is calculated under the current EBA?Please also explain
any differences in this calculation vs.the calculation proposed for treatment of NPC
under the RTM to the extent RTM is used to pass NPC benefit to customers.
(b)Are there any other costs and/or benefits associated with the wind repowering project
that go through or are anticipated to go through the Company's EBA?If so,please
explain.
Response to DPU Data Request 7.10
(a)Actual net power costs (NPC)are defined in the Company's general rate case
proceedings and modeled by the Generation and Regulation Initiative Decision Tool
(GRID).Specifically,NPC includes amounts booked to the followingFERC
Accounts:
FERC Account 447 -Sales for resale,excluding on-system wholesale sales and
other revenues that are not modeled in GRID
FERC Account 501 -Fuel,steam generation;excluding fuel handling,start-up
fuel (gas and diesel fuel,residual disposal)and other costs
that are not modeled in GRID
FERC Account 503 -Steam from other sources
FERC Account 547 -Fuel,other generation
FERC Account 555 -Purchased power,excluding the Bonneville Power
Administration ("BPA")residential exchange credit pass-
through if applicable
FERC Account 565 -Transmission of electricity by others
Please refer to the Direct Testimony of Company witness,Jeffrey K Larsen,
specifically Exhibit RMP (JLK-4),for the calculation of the NPC incremental
savings that would be included in the Resource Tracking Mechanism (RTM)to the
extent RTM is used to pass NPC benefit to customers.
(b)No,all non-NPC expenses and benefits will be recovered outside of the EBA as
discussed in Mr Larsen's Direct Testimony.
17-035-39 /Rocky Mountain Power
September 1,2017
DPU Data Request 7.18
DPU Data Request 7.18
Larsen Testimony.In reference to Mr.Larsen's Testimony,lines 43-47 and lines 269-
273:
(a)Please provide any analysis that the Company has done to evaluate the impact of
weather variability on the amount of the PTCs received from the wind repowering
projects.Please include any supporting work papers,inputs and models that support
the Company's analysis with formulas intact.
(b)What factors other than weather will affect the generationoutput of the wind repower
projects?Please provide any analysis conducted by the Company to evaluate output
risk.
(c)Does the Company anticipate being able to recover damages (includingbut not
limited to insurance claims)for "lost"PTC value resulting from any factors that
adversely affect the amount of generationfrom the wind repower projects?If so,
please provide the terms includingany limitations of such recovery.Please also
explain how the Company proposes to pass such recovery on to customers.
(d)Is the ongoing true-up of PTCs through a RTM followingthe next general rate case
consistent with the rate treatment of PTC's associated with the Company's existing
PTC eligible wind resources?If not,what is the current rate treatment for PTC
associated with the Company's existing PTC eligible wind resources?Please also
explain why the Company is proposing a different approach for the wind repowering
projects.
Response to DPU Data Request 7.18
(a)The Company's analysis uses historical wind generation data that is adjusted to
account for incremental energy output after repowering.Consequently,the underlying
generationlevels assumed in the Company's analysis reflect variations in wind
generationtied to all available historical output,which accounts for observed
historical weather variability.The Company has not performed additional analysis to
quantifyimpacts of "lost"production tax credit (PTC)value for variability in wind
output that differs from what has been observed in the historical data.
(b)Wind energy production and associated PTCs are also dependent on the operational
availability of the wind turbines to produce energy.The Company contracts for the
service and maintenance of its wind projects and these contracts require the vendors
to achieve specific wind turbine availabilitymetrics to ensure that the wind projects
are available to produce energy as anticipated.
17-035-39 /Rocky Mountain Power
September 1,2017
DPU Data Request 7.18
(c)The Company anticipates being able to recover damages,in part or in full,through
liquidated damages associated with lost production due to performance unavailability
in the operations and maintenance (O&M)agreement with the OEM.The amount of
liquidated damages is influenced by PTC values.The liquidated damage values,
availability guarantees and duration of the underlyingO&M agreements are currently
under negotiation.
Any recovery of damages would be given back to customers,either as a reduction to
plant or expense,consistent with generally accepted accounting principles (GAAP)
and Federal Energy Regulatory Commission (FERC)accounting procedures.
(d)PTCs are currentlyincluded in base rates and are not modified through a true-up
mechanism between general rate cases.The existing PTCs that are included in base
rates are not changed because of the implementation of the Resource Tracking
Mechanism (RTM).
As Mr.Jeffrey K.Larsen states in his direct testimony at lines 36-40,the Company
proposes to capture customer benefits from the wind repowering projects and match
those benefits with the projects'costs.This includes the continued tracking and
updating of PTC benefits that are to be passed through to customers.Mr.Larsen
continues,at lines 44-47:"Because PTCs are entirelydependent on the variable
output of the repowered wind facilities and difficult to precisely forecast,tracking
PTCs through the RTM ensures that customers receive their full value."
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
September 1,2017
Confidential DPU Data Request 7.22
DPU Data Request 7.22
CONFIDENTIAL REQUEST-Link Testimony Workpapers:Repower Results Direct
Testimony.xlsx.
Response to DPU Data Request 7.22
The 2016 safe-harbor capital expendituresare included in the referenced confidential
work paper "Repower Results Direct Testimony"but are not separately broken out.
Please refer to the Company's response to OCS Data Request 1.50,specifically
Confidential Attachment OCS 1.50,which provides the five percent safe-harbor
calculations by project.Please refer to the Company's response to OCS Data Request
1.27 subpart (a)for the 2016 expendituresmade by the Company to comply with the five-
percent rule.Please also refer to the Company's response to OCS Data Request 1.26
regarding the 2016 safe-harbor capital expenditures incorporated into the capital costs for
each repowered project.
The 2016 safe-harbor capital expendituresare included in the present value of revenue
requirements benefits in the confidential work paper "Repower Results Direct
Testimony",tab "Testimony Tables".The capital costs for the 2016 safe-harbor
expenditures are included in the "Repower Capital Investment"amounts in Exhibit
RMP (RTL-1)to the Direct Testimony of Company witness,Rick T.Link.
17-035-39 /Rocky Mountain Power
September 1,2017
Confidential DPU Data Request 7.23
DPU Data Request 7.23
CONFIDENTIAL REQUEST-Link Testimony Workpapers:SO and PaR analysis.
Response to DPU Data Request 7.23
The Company objects to this request to the extent it requires developmentof a special
study or informationnot maintained in the ordinary course of business.Without waiving
this objection,the Company responds as follows:
(a)The system wide marginal costs are not reported in System Optimizer model (SO
model)and Planning and Risk (PaR)model outputs on an hourlybasis.The Aurora
model is used to develop the price curves used in the filing.The price curves are
inputs to the SO model and PaR model.
(b)The Company has not performed the requested analysis.
17-035-39 /Rocky Mountain Power
September 1,2017
Confidential DPU Data Request 7.28
DPU Data Request 7.28
CONFIDENTIAL REQUEST-Link Testimony Workpapers:RePower2017051
LGIALimit vl 3.xlsx.
Response to DPU Data Request 7.28
Referencingthe confidential work paper supporting the Direct Testimony of Company
witness,Rick T.Link entitled "RePower Data 20170516 LGIA Limit vl3",the Company
responds as follows:
(a)The table of informationstarting on row 60,is to format the revenue requirement
informationdelta between the wind repower and status quo,reported on a real
levelized basis,into the integrated resource plan (IRP)model format input as fixed
operations and maintenance (FOM)dollars per kilowatt-hourper year ($/kW-year)as
reported in column H.
(b)The analysis covers 33 years from 2017 through the end of the repowered project's
useful life in 2049.
(c)This represents the remaining expected life of each wind plant without repowering,
which is unique for each wind facility.
17-035-39 /Rocky Mountain Power
September 1,2017
Confidential DPU Data Request 7.29
DPU Data Request 7.29
CONFIDENTIAL REQUEST-Link Testimony Workpapers:RePower2017051
LGIALimit vl 3.xlsx.
Response to DPU Data Request 7.29
Please refer to the Direct Testimony of Company witness,Rick T.Link,lines 390
through 400,for a description of the sunk investment and the proposed treatment of those
costs.
17-035-39 /Rocky Mountain Power
September 1,2017
Confidential DPU Data Request 7.32
DPU Data Request 7.32
CONFIDENTIAL REQUEST-Link Testimony Workpapers:PaR Summary Reports.
Response to DPU Data Request 7.32
(a)Please refer to Attachment DPU 7.32.This index was included with the non-
confidential work papers supporting the Direct Testimony of Company witness,Rick
T.Link.
(b)The "Input 12mth"worksheet takes the monthlydata by iteration from the "PaR data"
and calculates the 10 percent confidence,90 percent confidence,average,and medium.
These data are outputs from the Planning and Risk (PaR)model and there are no work
papers available that calculate the referenced values.
(c)The "PaR Data"worksheet informationare the stochastic cost monthlyfrom the PaR
model results output for the 50 iterations.The stochastic costs are then formatted into
the table format -month by iteration.These data are outputs from the PaR model and
there are no work papers available that calculate the referenced values.
17-035-39 /Rocky Mountain Power
September 1,2017
Confidential DPU Data Request 7.34
DPU Data Request 7.34
CONFIDENTIAL REQUEST-Link Testimony Workpapers:SO Model Summary
Reports.
Response to DPU Data Request 7.34
Referencing the confidential work papers supporting the Direct Testimony of Company
witness Rick T.Link,specifically the work papers provided in the folder titled "SO
Model Summary Reports"the Company responds as follows:
The Company does not have historical data in the format presented in the System
Optimizer model (SO Model)files referenced above because the referenced files are
specific to SO Model inputs/outputs.With this clarification of data availability,For the
Company's available owned generationdata,please refer to Confidential Attachment
DPU 7.34-1 for thermal data,Confidential Attachment DPU 7.34-2 for wind data,and
Confidential Attachment DPU 7.34-3 for hydroelectric data.
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
September 1,2017
Confidential DPU Data Request 7.35
DPU Data Request 7.35
CONFIDENTIAL REQUEST-Link Testimony Workpapers:SO Model Summary
Reports.
Response to DPU Data Request 7.35
The Company objects to this request to the extent it requires developmentof a special
study or information not maintained in the ordinary course of business.Without waiving
this objection,the Company responds as follows:
Please reference the confidential work papers supporting the Direct Testimony of
Company witness Rick T.Link,specifically the work papers provided in the folder
entitled "SO Model Summary Reports".The Company does not have historical data in
the format presented in the System Optimizer model (SO Model)files referenced above,
as the referenced files are specific to SO Model inputs/outputs.With this clarification,the
Company responds as follows:
Front Office Transactions (FOTs)
FOTs are a modeling resource utilized in the integratedresource plan (IRP)and SO
modeling processes.In actual operations,FOTs generally encompass all short-term firm
(STF)market purchases to balance the Company's system.Please refer to Confidential
Attachment DPU 7.35-1,which provides the Company's actual STF market purchases for
calendar years 2012 through 2016.The Company's STF market purchases typically
include a combination of monthly,daily,and hourly products,and prices vary based on
market conditions at the time the transaction is entered.
Company Owned Actual Generation (megawatt-hours(MWh))
Please refer to Attachment DPU 7.35-2,which provides the Company's actual annual
generation from Company-owned thermal,hydroelectric,and wind resources for calendar
years 2012 through 2016.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.