20170815Utah_DPU Set 3 (1-24).docx

PATRICIA E. SCHMID (#4908)
JUSTIN JETTER (#13257)
Assistant Attorney Generals
Counsel for the DIVISION OF PUBLIC UTILITIESSEAN REYES (#7969)
Attorney General of Utah
160 E 300 S, 5th Floor
P.O. Box 140857
Salt Lake City, UT 84114-0857
Telephone [phone]
BEFORE THE PUBLIC SERVICE COMMISSION OF UTAH
In the Matter of Rocky Mountain Power’s Application for Approval of a Significant Energy Resource Decision and Voluntary Request for Approval of Resource Decision
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DOCKET NO. 17-035-39
Division of Public Utilities
3rd Set of Data Requests to
ROCKY MOUNTAIN POWER
August 7, 2017
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Please send an electronic copy and a paper copy of your Data Response to:
Erika Tedder - Paralegal
Division of Public Utilities
160 E 300 S, 4th Floor
Salt Lake City, UT 84114
PLEASE E-MAIL YOUR DATA
RESPONSE TO DPU Data Request
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Response should include where applicable native WORD and EXCEL documents with intact formulae.
Your Data Response is not consideredreceived until an electronic copy is furnished and received.
3.1Hemstreet 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.
3.2Hemstreet 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.
3.3Hemstreet 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.
3.4Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 108-113:
Please provide a copy of referenced IRS guidance on safe harbor investments.
Provide any additional internal memoranda, internal presentations, or analysis on the interpretation of the IRS guidance and eligibility of the proposed repower projects for the safe harbor rules.
Does the referenced five percent rule apply to the total proposed project (i.e. all projects proposed for repowering) or for each turbine individually?
Provide an accounting of total project costs and 2016 expenditures made by the Company to comply with the five percent rule.
Has the Company conducted any formal assessment of the risk that cost overruns could result in 2016 expenditures being 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.
3.5Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 114-121:
Provide a copy of the IRS “additional guidance” regarding continuous efforts.
Provide any additional internal memoranda, internal presentations, or analysis on the interpretation of the continuous-efforts standard.
Please provide all documentation and analysis supporting the statement that the IRS continuous-efforts standard “is a difficult standard to meet.”
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.
3.6Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 139-150:
Please provide a copy of IRS Notice 2016-31.
Provide any additional internal memoranda, internal presentations, or analysis on the interpretation of the IRS guidance and eligibility of the proposed repower projects for the PTC under this guidance.
Provide the “turbine-by-turbine” analysis for each turbine to be repowered under the proposal, demonstrating eligibility under the 80/20 rule.
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.
3.7Hemstreet Testimony.In reference to Mr. Hemstreet’s Testimony, lines 213-227:
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.”
Provide all studies performed by or for the Company regarding the avian impact of the repowering project.
Provide a copy of the Company’s informed-curtailment protocols.
Provide copies of all referenced reports submitted to the Wyoming Game and Fish Department and the U.S. Fish and Wildlife Service.
Does the repowering project require any new environmental permits, related to avian impacts or otherwise? If so, please identify the required permits.
This portion of testimony specifically addresses avian impacts on Wyoming wind facilities. Please provide the same detail (included in testimony and in response to the questions above) for wind facilities in other states.
3.8Hemstreet 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.
3.9Hemstreet 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?
3.10Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 303-317:
Please provide a quantification of the expected costs and benefits to customers of lower ongoing operational costs resulting from the repowering. Provide all workpapers supporting this analysis. Workpapers should be provided in electronic spreadsheet format with formulas intact.
Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 326-336:
Please identify the timing and number of failures of the referenced gearboxes for each wind project.
Please quantify the “increased capital costs” experienced by the Company in recent years.
3.12Hemstreet 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 workpapers where this is represented.
3.13Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 359-367:Please explain why the blade maintenance costs at Goodnoe Hills is higher than other facilities.Please quantify the expected reduced capital costs associated with the blade replacement at Goodnoe Hills, and provide any analysis supporting this quantification.
3.14Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 396-399: Provide a summary of timing and cause of all under-frequency events experienced on the Company’s system over the last five years.
3.15Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 402-416:
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.
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.
Please provide any system studies identifying a need for additional reactive power on the Company’s system.
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.
Please provide a quantification of the benefits associated with the more economic commitment of other generating resources that would be possible after the addition of the WindFREE equipment.
Please provide all documentation and analysis related to any enhancement of grid security provided by the addition of the WindFREE equipment.
3.16Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 417-424:
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.
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.
Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 430-440:
Provide any completed system studies demonstrating the need for additional voltage support on the Company’s system.
Please provide an estimate of when the ongoing transmission studies will be completed.
Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 442-445:
Are all wind projects scheduled to retire at the end of their 30-year depreciation period?
Provide any retirement studies indicating that the wind facilities will need to be retired after 30 years.
Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 450-466:
Do the design standards indicated in this section include the useful life of the foundations and towers?
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.
When will the third-party design assessments referenced in this section be completed? Provide any completed third-party design assessments that have already been completed.
Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 473-486:
Provide a detailed timeline on the completion of any studies not yet complete.
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.
Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 487-493:
Provide all reports and assessments completed by the Company’s consultant regarding foundation condition.
The testimony indicates that not all foundations have been assessed. Provide a detailed schedule and timeline for the completion of this assessment.
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.
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?
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 delivery and 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.
Hemstreet Testimony. In reference to Mr. Hemstreet’s Testimony, lines 552-581:
Has the Company conducted any formal assessment of the risk that permitting could be delayed or 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.