20171003Pac to IIPA 19.pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIRCORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
October 3,2017
Eric L.Olsen
ECHO HAAWK &OLSEN,PLLC
505 Pershing Ave.,Ste.100
Pocatello,Idaho 83205
[e-mail] (C)
RE:ID PAC-E-17-06
IIPA 3rd Set Data Request (19)
Please fmd enclosed Rocky Mountain Power's Response to IIPA 3rd Set Data Request 19.
Provided on the enclosed Confidential CD is Confidential Attachment IIPA 19.Confidential
information is 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 ron@williamsbradburv,com (C)
Brad Mullins/PIIC [e-mail] (C)
Jim Duke/PIIC [e-mail] (C)(W)
Kyle Williams/PIIC [e-mail] (C)(W)
Val Steiner/[e-mail] (C)(W)
James R.Smith/Monsanto iim.r.smith(¿Amonsanto.com (C)(W)
Brian C.Collins/Brubaker&Associates [e-mail] (C)(W)
Maurice Brubaker/Monsanto [e-mail] (C)(W)
Katie Iverson/[e-mail] (C)
AnthonyYankel/IIPA [e-mail](C)
Randall C.Budge/Monsanto [e-mail] (C)
Thomas J.Budge/Monsanto [e-mail] (C)(W)
Diane Hanian/[e-mail](C)
PAC-E-17-06 /Rocky Mountain Power
October 3,2017
IIPA 3rd Set Data Request 19
HPA Data Request 19
Please answer the followingwith respect to the Company's response to IPUC
Staff request 4:
(a)According to the response,Attachment IPUC 4-1 lists historic "actual annual
megawatt-hours (MWH)".According to the response,Attachment IPUC 4-5
lists historic "annual MWh eligible for the credit."The annual MWH in 4-1 is
less than the annual MWH in 4-5.Why would there be more annual MWH
eligible for the production tax credit than the actual MWH generated?
(b)Regarding Link's Exhibit 6,the average MWH of generation "Existing Wind
Before Repowering"is different than those listed in Attachments IPUC 4-1
and 4-5.Please explain the basis for this difference in MWH generated prior
to repowering.
(c)With respect to Mr.Links Tables 2 and 3,please recalculate these values
using the "Existing Wind Before Repowering"on Attachment IPUC 4-1 and
the Repowered Wind values changed by the same percentage as that between
the "Existing Wind Before Repoweling"and Attachment IPUC 4-1.
(d)With respect to Mr.Links Tables 2 and 3,please recalculate these values
using the "Existing Wind Before Repowering"on Attachment IPUC 4-5 and
the Repowered Wind values changed by the same percentage as that between
the "Existing Wind Before Repowering"and Attachment IPUC 4-5.
Response to IIPA Data Request 19
(a)The Production Tax Credit (PTC)is booked on the accrual method.The year-
end calculation is based on 11 months of actual megawatt-hours (MWh)
generated and a forecasted December amount.The actual December MWh are
not available at the time the accrual must be booked.
(b)Attachment IPUC 4-1 and Attachment IPUC 4-5 provide availablehistorical
data,varying annually,and including partial years during resource
development.
Referencing the Direct Testimony of Company witness,Rick T.Link,
specifically,Link Confidential Exhibit No.6,the "Energy"and "LGIA
Limited Energy"represents expected generation,calculated by formula,and
incorporatinghistorical operations in the capacity factor for each resource.
Please refer to Confidential Attachment IIPA 19,which provides the
confidential work papers used to develop the energy values stated in Link
PAC-E-17-06/Rocky Mountain Power
October 3,2017
IIPA 3rd Set Data Request 19
Confidential Exhibit No.6.Specifically,please refer to the "Repower Info
(No Limit)"tab,cells C5:C23 (formulas intact).
(c)The Company objects to this request on the basis that it seeks information that
is not in the Company's custody,possession or control.The request requires
development of a special study or information not maintained in the ordinary
course of business.Without waiving this objection,the Company responds as
follows:
The requested analysis would be circular in nature,as the capacity factors
applicable to Link Confidential Exhibit No.6 already incorporate historical
operations.
(d)Please refer to the Company's responses to subparts (b)and (c)above.
Confidential information is provided subject to the nondisclosure agreement
between the Company and IPUC.
Recordholder:Brian Keyser /Randy Baker
Sponsor:Rick Link