20171004PAC to IIPA 20-29.pdf

daho Puolc Utéties Commission
Ofuce of the SecretaryRECEIVED
ROCKY MOUNTAIN 001 0 4 209
POWERorvismomomeo.Boise,idanC 1407 W North Temple.Suite 330
Salt Lake City,Utah 84116
October 4,2017
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 4"'Set Data Request (20-29)
Please find enclosed Rocky Mountain Power's Responsesto IIPA 4th Set Data Requests 20-29.
Also provided is Attachment IIPA 24.Provided on the enclosed Confidential CD is Confidential
Attachment IIPA 21.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/PllC ron i williamsbradburv.com (C)
Brad Mullins/PIIC brmullins mwanalvtics.com (C)
Jim Duke/PIIC iduke idahoan.com (C)(W)
Kyle Williams/PIIC williamsk2bvui.edu (C)(W)
Val Steiner/PIICval.steiner aurium.com (C)(W)
James R.Smith/Monsanto iim.r.smithamonsanto.com (C)(W)
Brian C.Collins/Brubaker&Associates beollinsdi consultbai.com (C)(W)
Maurice Brubaker/Monsanto [e-mail] (C)(W)
Katie Iverson/[e-mail] (C)
Anthony Yankel/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 4,2017
IIPA 4th Set Data Request 20
IIPA Data Request 20
What is the total expected installed cost of the facilities to repower the proposed
wind facilities?
Response to IIPA Data Request 20
The total expected installed cost of the wind repowering facilities is $1.128
billion.For a breakdown of the installed costs per facility,please refer to page 1
of Confidential Exhibit No.3,which accompanied the Direct Testimony of
Company witness,TimothyJ.Hemstreet.
Recordholder:Tim Hemstreet
Sponsor:Tim Hemstreet
PAC-E-17-06 /Rocky MountainPower
October 4,2017
IIPA 4th Set Data Request 21
IIPA Data Request 21
What is the unrecovered cost of the existing wind facilities that will be replaced
by the repowering?
Response to IIPA Data Request 21
Please refer to Confidential Attachment IIPA 21.The net book balance of the
equipment being replaced will be transferred into the accumulated depreciation
reserve and will be recovered over the 30-year life of the replacement equipment.
The Accumulated Deferred Income Taxes (ADIT)balances have been derived
through ratios based on the replaced components as a percentage of the total wind
property by wind plant.
Confidential informationis provided subject to the nondisclosure agreement
between the Company and IPUC.
Recordholder:Kent Ipson
Sponsor:Jeff Larsen
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 22
IIPA Data Request 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?
Response to IIPA Data Request 22
The estimated futurecost of the unrecovered existing/replaced wind facilities has
not been calculated by year.However,please refer to the Company's response to
IIPA Data Request 21,which provides the net book and Accumulated Deferred
Income Taxes (ADIT)balances at the repower date by wind facility as well as the
projected annual depreciation expense.Also,please refer to Larsen Exhibit No.14
accompanyingDirect Testimony of Company witness,Jeffrey K.Larsen,for the
Idaho system generation (SG)allocation factor and financial assumptions such as
the capital structure and cost,pre-tax return and consolidatedincome tax rate used
in developing the wind facilities revenue requirement in Larsen Exhibit No.12
and Larsen Exhibit No.13.
Recordholder:Terrell Spackman
Sponsor:Jeff Larsen
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 23
IIPA Data Request 23
What is the annual change in wind energy generated and the Production Tax
Credits resulting from the repowering?
Response to IIPA Data Request 23
Please refer to the confidential work papers that accompanied the Direct
Testimony of Company witness,Rick T.Link,specifically the folder "Other
Summary Reports",the file "RePower Data 20170516 LGIA Limit vl3".
The annual change in wind energy generated in gigawatt-hours (GWh)is shown
on line 49 on the tab "Summary".This is the difference between annual
generationwith repowering (line 20)and without repowering (line 37).
The annual change in Production Tax Credits (PTC)is shown on line 75 on the
tab "Summary".This is the difference between PTCs with repowering (line 13)
and without repowering (line 30).
Recordholder:Mark Paul
Sponsor:Rick Link and Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 24
HPA Data Request 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 inputto 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?
(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?
Response to HPA Data Request 24
(a)Yes.Retirement assumptions are the same for all cases,and match the 2017
Integrated Resource Plan (IRP)Preferred Portfolio.
(b)Yes.Retirement assumptions are the same for all cases,and match the 2017
IRP Preferred Portfolio.
(c)The Company objects to this request as misstating the evidence in the record
given the implication that repoweredwind resources are a replacement
resource for existing coal units that will be retiring.Coal retirements and wind
repowering are separate decisions,eachjustified on its own merits.Without
waiving this objection,the Company offers the followingresponse:
The Company anticipates future depreciation study filings will facilitate
retiring coal facilities to be fully recovered throughdepreciation expense by
the retirement date.For the unrecoveredcost of the coal facilities referenced
in the 2017 IRP,specifically Figure 1.7,please refer to Attachment IIPA 24,
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 24
which shows the total plant net investment as of December 31,2016,for each
coal facility referenced in the 2017 IRP,specifically Figure 1.7.
(d)The Company objects to this request as not reasonably calculated to lead to
the discovery of admissible evidence and requiring development of a special
study or information not maintained in the ordinary course of business.
Without waiving these objections,the Company responds as follows:
The information being requested has not been calculated.
(e)Full recovery of both replaced wind and retiring coal resources will be
addressed in the next depreciation study.
(f)Yes.The same cost recovery assumptions are used for retiring units in both
the with-and without-repowering scenarios.
Recordholder:Jin Jin Fan and Terrell Spackman
Sponsor:Rick Link,JeffLarsen and Tim Hemstreet
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 25
IIPA Data Request 25
If the Company's analysis of Benefit/Cost of Wind Repowering in Table 2 of Mr.
Link's testimony contained the 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 Updated2015 IRP.
Response to IIPA Data Request 25
The Company objects to this request as not reasonably calculated to lead to the
discovery of admissible evidence and requiring developmentof a special study or
informationnot maintained in the ordinary course of business.Without waiving
these objections,the Company responds as follows:
PacifiCorp has not performed the requested analysis.
Recordholder:Jin Jin Fan
Sponsor:Rick Link
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 26
HPA Data Request 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?
Response to HPA Data Request 26
(a)At the time of the 2015 IntegratedResource Plan (IRP)Update,Arizona's
State Implementation Plan (SIP),the Federal Implementation Plan (FIP),the
United States (U.S.)Environmental Protection Agency (EPA)determinations
and ongoing litigation made the retirement of Cholla Unit 4 at the end of 2024
a conservative and reasonable assumption.As stated in the 2015 IRP Update,
page 26:"With reduced load,lower market prices and uncertainties around
state plans for implementing the clean power plan (CPP),the Business Plan
assumes Cholla Unit 4 is retired at the end of 2024.PacifiCorp will continue
to evaluate the most cost effective compliance alternatives for Cholla Unit 4 in
future IRPs".
Please refer to the following:
rated Resource Plan/2015IRP/PacifiCorp 2015IRP-Vol3-CoalAnalysis-
REDAC_TED pdf(page 28-45)
6_0426_.p_d_f (page 2-3)
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 26
(b)Nine regional haze cases were developedand analyzed in the 2017 IRP to
reflect a range of potential regional haze compliance outcomes for affected
generatingunits in PacifiCorp's fleet.Regional haze case RH-5a was selected
as the least-cost least-risk compliance portfolio,which included the early
retirement of Cholla Unit 4.
For further discussion of Regional Haze case development,please refer to the
2017 IRP,Chapter 7 (Modeling and Portfolio Evaluation Approach),page 170
and 171,which is publicly available and can be accessed by utilizingthe
followingwebsite link:
http://www.pacificoro.com/es/iro.html
(c)Yes,the Cholla Unit 4 facility would be assumed to retire at the end of 2020.
The assumed retirement date of the Cholla Unit 4 facility is not impacted by
the repowering projects.
(d)Yes,the Cholla Unit 4 facility would be assumed to retire at the end of 2020.
The assumed retirement date of the Cholla Unit 4 facility is not impacted by
the new wind and transmission projects.
(e)Yes,the Cholla Unit 4 facility would be assumed to retire at the end of 2020.
The assumed retirement date of the Cholla Unit 4 facility is not impacted by
the combination of the repower,new wind and transmission projects.
Recordholder:Jin Jin Fan
Sponsor:Rick Link
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 27
HPA Data Request 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 through 2034 according to
the Company's Updated 2015 IRP?
(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?
(e)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?
Response to HPA Data Request 27
Based on the facility name and timing described above,the Company assumes the
reference to "Craig"applies to the Craig Unit 1 facility.Based on this assumption,
the Company responds as follows:
(a)The 2015 Integrated Resource Plan (IRP)Update evaluatedupdated
information relevant to the 2015 IRP Preferred Portfolio,and did not evaluate
new alternative Regional Haze compliance scenarios.The Craig Unit 1
facility was analyzed under the default assumption of an end-of-life
retirement.
(b)Nine regional haze cases were developed and analyzed in the 2017 IRP to
reflect a range of potential regional haze compliance outcomes for affected
generatingunits in PacifiCorp's fleet.Regional haze case RH-5a was selected
as the least-cost least-risk compliance portfolio,which included the early
retirement of Craig Unit 1.As noted in Volume I,Chapter 3,page 36 of
PacifiCorp's 2017 IRP,owners of Craig Unit 1 have agreed to retire the unit
by December 31,2025,or convert the unit to natural gas by August 31,2023.
The terms of this agreement are currentlybeing considered by the Colorado
Air Quality Board;United States (U.S.)Environmental Protection Agency
(EPA)review and approval will then be required.
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 27
For further discussion of Regional Haze case development,please refer to the
2017 IRP,Chapter 7 (Modeling and Portfolio Evaluation Approach),page 170
and 171,which is publicly available and can be accessed by utilizingthe
followingwebsite link:
(c)Yes,the Craig Unit I facility would be assumed to retire at the end of 2025.
The assumed retirement date of the Craig Unit 1 facility is not impacted by the
repowering projects.
(d)Yes,the Craig Unit 1 facility would be assumed to retire at the end of 2025.
The assumed retirement date of the Craig Unit l facility is not impacted by the
new wind and transmission projects.
(e)Yes,the Craig Unit 1 facility would be assumed to retire at the end of 2025.
The assumed retirement date of the Craig Unit 1 facility is not impacted by the
combination of the repower,new wind and transmission projects.
Recordholder:Jin Jin Fan
Sponsor:Rick Link
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 28
IIPA Data Request 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 203 7.
(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?
Response to IIPA Data Request 28
Based on the facility name and timing described above,the Company assumes the
reference to "Jim Bridger"applies to the Jim Bridger Unit 1 facility.Based on this
assumption,the Company responds as follows:
(a)The 2015 Integrated Resource Plan (IRP)Update evaluatedupdated
information relevant to the 2015 IRP Preferred Portfolio,and did not evaluate
new alternative Regional Haze compliance scenarios.The Jim Bridger Unit 1
facility was analyzed under the default assumption of an end-of-life
retirement.
(b)Nine regional haze cases were developedand analyzed in the 2017 IRP to
reflect a range of potential regional haze compliance outcomes for affected
generating units in PacifiCorp's fleet.Regional haze case RH-5a was selected
as the least-cost least-risk compliance portfolio,which included the early
retirement of Jim Bridger Unit 1.If a different regional haze case had been
least-cost least-risk,Jim Bridger Unit 1 could again have been selected to
retire at the end of 2037.
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 28
For further discussion of Regional Haze case development,please refer to the
2017 IRP,Chapter 7 (Modeling and Portfolio Evaluation Approach),page 170
and 171,which is publicly available and can be accessed by utilizing the
followingwebsite link:
(c)Yes,the Jim Bridger Unit 1 facility would be assumed to retire at the end of
2028.The assumed retirement date of the Jim Bridger Unit 1 facility is not
impacted by the repowering projects.
(d)Yes,the Jim Bridger Unit 1 facility would be assumed to retire at the end of
2028.The assumed retirement date of the Jim Bridger Unit 1 is not impacted
by the new wind and transmission projects.
(e)Yes,the Jim Bridger Unit I facility would be assumed to retire at the end of
2028.The assumed retirement date of the Jim Bridger Unit 1 is not impacted
by the combination of the repower,new wind and transmission projects.
Recordholder:Jin Jin Fan
Sponsor:Rick Link
PAC-E-17-06 /Rocky Mountain Power
October 4,2017
IIPA 4th Set Data Request 29
HPA Data Request 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 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 this second Jim Bridger unit assumed to be retired in 2033
according to the Company's 2017 IRP?
(c)Would the second unit at Jim Bridger be assumed to be retired in 203 3 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?
Response to HPA Data Request 29
Based on the facility name and timing described above,the Company assumes the
reference to "Jim Bridger"applies to the Jim Bridger Unit 2 facility.Based on this
assumption,the Company responds as follows:
(a)The 2015 Integrated Resource Plan (IRP)Update evaluatedupdated
informationrelevant to the 2015 IRP Preferred Portfolio,and did not evaluate
new alternative Regional Haze compliance scenarios.The Jim Bridger Unit 2
facility was analyzed under the default assumption of an end-of-life
retirement.
(b)Nine regional haze cases were developed and analyzed in the 2017 IRP to
reflect a range of potential regional haze compliance outcomes for affected
generatingunits in PacifiCorp's fleet.Regional haze case RH-5a was selected
as the least-cost least-risk compliance portfolio,which included the early
retirement of Jim Bridger Unit 2.If a different regional haze case had been
least-cost least-risk,Jim Bridger Unit 2 could again have been selected to
retire at the end of 2037.
PAC-E-17-06 /Rocky MountainPower
October 4,2017
IIPA 4th Set Data Request 29
For further discussion of Regional Haze case development,please refer to the
2017 IRP,Chapter 7 (Modeling and Portfolio Evaluation Approach),page 170
and 171,which is publicly available and can be accessed by utilizingthe
followingwebsite link:
(c)Yes,the Jim Bridger Unit 2 facility would be assumed to retire at the end of
2032.The assumed retirement date of the Jim Bridger Unit 2 facility is not
impacted by the repowering projects.
(d)Yes,the Jim Bridger Unit 2 facility would be assumed to retire at the end of
2032.The assumed retirement date of the Jim Bridger Unit 2 is not impacted
by the new wind and transmission projects.
(e)Yes,the Jim Bridger Unit 2 facility would be assumed to retire at the end of
2032.The assumed retirement date of the Jim Bridger Unit 2 is not impacted
by the combination of the repower,new wind and transmission projects.
Recordholder:Jin Jin Fan
Sponsor:Rick Link