20170815Utah_DPU Set 5 (1-9).docx

PATRICIA E. SCHMID (#4908)
JUSTIN JETTER (#13257)
Assistant Attorney GeneralsCounsel 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 Resource Decision to Repower Wind Facilities
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DOCKET NO. 17-035-39
Division of Public Utilities
5thSet of Data Requests to
ROCKY MOUNTAIN POWER
August 10, 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.
Crane Testimony. In reference to Ms. Crane’s Testimony, lines 75-84:
What is the status of regulatory filings in other state jurisdictions?
Will the repowering project continue if it the Company’s applications are rejected in other jurisdictions?
The California proceeding is scheduled for 2019, after the deadlines noted in this proceeding. How would a rejection by California impact the project and Utah ratepayers?
Crane Testimony. In reference to Ms. Crane’s Testimony, lines 117-136: Please differentiate between the purchases made in 12/2016 and the purchases planned for early 2018. Please provide an itemization of completed and planned equipment purchases.
Crane Testimony. In reference to Ms. Crane’s Testimony, lines 229-241:
Provide any analysis performed by or for the Company related to the impact on the Company’s credit rating of a denial of this application.
Provide any analysis quantifying the impact to customers of a denial of this application, including credit rating impacts, collateral impacts, financing terms impacts, etc.
Link Testimony. In reference to Mr. Link’s Testimony, lines 58-63:
Please explain why the Company did not include a REC value in the economic analysis.
Please provide workpapers supporting the $11 million benefit value. Workpapers should be provided in electronic spreadsheet format with formulas intact.
Link Testimony. In reference to Mr. Link’s Testimony, lines 64-67: Please explain why the Company structured the economic benefits analysis as a 20-year study.
Link Testimony. In reference to Mr. Link’s Testimony, lines 276-283:
The previous data request alluded to the Company’s 20-year economic analysis. How were the re-powered wind resources analyzed given their renewed 30-year or, potentially, 40-year lives? Were their economic analyses for 30 and 40 years? Or, were they analyzed over 20 years, but with, say, different depreciation rates?
Link Testimony. In reference to Mr. Link’s Testimony, lines 303-334:
How was Goodnoe Hills analyzed, i.e. was it added to the list into the SO and Par analyses in a similar manner to Leaning Juniper? Was the analyses for Goodnoe Hills given the same 20, 30, and 40 year economic evaluation as were the other projects (per the Company’s answers to data requests 5.5 and 5.6)? Was Leaning Juniper removed from the analysis with Goodnoe Hills included to determine whether or not it, Leaning Juniper, remained an economically viable repowering option?
Link Testimony. In reference to Mr. Link’s Testimony, lines 246-263: Please provide detailed calculations of the risk-adjusted PVRR, including all calculations related to “adding five percent of system variable costs, from the 95th percentile of the distribution of system variable costs, to the stochastic-mean PVRR.”
Link Testimony. In reference to Mr. Link’s Testimony, lines 314-317: Please provide a reference to specific workpapers where the $7 million value is calculated. If this value is not calculated in workpapers already provided, please provide all analysis supporting this value.
DPU Requestor:Division(801) 530-6653
Erika Tedder - [phone]
cc:Service List