20170815Utah_DPU Set 5 (1-8).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. 17-035-40
Division of Public Utilities
5th Set of Data Requests to
ROCKY MOUNTAIN POWER
August 9, 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 ERIKA TEDDER
[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.
PTCs. Referring to Mr. Teply’s Testimony (Teply) (lines 123-134):
Please provide a description of the “risk of interpretation” of the IRS continuity requirements. Provide any documentation, analysis, findings, and opinions that the Company relies upon in assessing this risk.
Please provide any documentation, analysis, findings, and opinions that describes the process to demonstrate “continuous progress” to the IRS for any of the Wind Projects that fails to reach commercial operation after December 31, 2020.
With respect to the other wind facilities that may be selected in the RFP, is the Company proposing to assume the risk that those facilities fail to meet the continuity requirements? Please describe how the interpretation risk will differ for the Wind Project as compared to other wind projects that may be selected in the RFP.
Please provide any documentation, analysis, findings, and opinions that describes how the Wind Projects ability to meet the IRS safe-harbor and continuous progress requirements are impaired in the event that the Wind Project are completed in 2020 but the Transmission Projects are not complete by December 31, 2020.
PTCs Referring to Teply (lines 135-140)::
Please describe all equipment purchased in 2016 for the Wind Projects.
Please provide all analysis, findings, and opinions that demonstrate or support the Company’s view that the Wind Projects meet the IRS’s “start-of-construction” criteria and the “safe-harbor” requirements for 2016.
Please provide any analysis, findings, and opinions regarding any uncertainty orrisk that any of the Wind Projects will not meet the IRS’s “start-of-construction” criteria before Jan 1, 2017.
Wind Projects Characteristics
Teply Testimony. Referring to Teply (lines 58-68):
Please provide the basis for the Company’s decision to develop benchmark projects for inclusion in the RFP process.
Please provide the basis for the Company’s decision to develop four benchmark projects for inclusion in the RFP process. Provide any documents or analysis used as the basis for electing to include each of the four projects.
Provide any documentation or analysis used as the basis for concluding that the proposed benchmark projects will “ensure competitive market engagement”.
Teply Testimony. Referring to Teply (lines 88-93):
Please provide the Company’s current estimate of the costs incurred to date and the total costs to be incurred for each of the Benchmark Wind Projects. Include all costs from project inception though the date of selection of the winning bids in the RFP.
Please explain the Company’s intended plans for development or disposition of any of the Benchmark Wind Projects that are not winning bids in the RFP.
Please provide any reports or assessments the Company has prepared regarding of the feasibility or cost to develop these projects in the event the project is not a winning project in the RFP.
Please describe the Company’s requested ratemaking treatment for the costs incurred on any Benchmark Wind Project that does not win an award in the RFP.
Teply Testimony. Referring to Teply (lines 26-30, 97-98 and 241-243):
Is the Company seeking approval of the four Benchmark Wind Projects regardless of whether or not any of those projects are winning projects in the RFP?
Does the Company have development and implementation rights to any other projects that may be bid into the RFP? If so, please identify those projects.
Teply Testimony. Referring to Teply (lines 97-98, 105-107, and 143-146):
Please explain how the 860 MW, 1,100 MW and 1,270 MW relate to one another.
Please explain how each of these values relate to the approvals being sought in this application.
Is the Company’s request for approval of Wind Projects limited to be no more than 860MW? If no, please describe the limit on the total amount of wind energy to be considered in this application.
Teply Testimony. Referring to Teply (lines 176-177), please provide any economic analysis conducted by the Company on the Wind Projects assuming the Transmission Projects do not proceed and any economic analysis of the Transmission Projects conducted by the Company assuming the Wind Projects do not proceed.
Teply Testimony. Referring to Teply (lines 187-189):
Based on Mr. Teply’s characterization of the Wind Projects as “proxies” and the indication that further work is to be done on the projects, is it the Company’s position that the cost and performance characteristics presented in Mr. Teply’s testimony are only illustrative at this time?
Is the Company seeking any approval of the representations of the cost and performance characteristics presented in Mr. Teply’s testimony? If yes, please explain what approvals on these values are being sought.
DPU Requestor:Division [phone]
Erika Tedder - [phone]
cc:Service List