20170815Wyoming_OCA Set 1 (1-85).docx

BEFORE THE PUBLIC SERVICE COMMISSION OF WYOMING
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR CERTIFICATES OF PUBLIC CONVENIENCE AND NECESSITY AND NONTRADITIONAL RATEMAKING FOR WIND AND TRANSMISSION FACILITIES
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DOCKET NO. 20000-520-EA-17
RECORD NO. 14781
OFFICE OF CONSUMER ADVOCATE’S FIRST SET OF DATA REQUESTS
Submitted:August 8, 2017
COMES NOW the Office of Consumer Advocate and hereby serves its first set of data requests regarding the above docketed general rate applicationof Rocky Mountain Power, to be answered pursuant to Rules 33, 34, and 36 of the Wyoming Rules of Civil Procedure. The responses are to be served upon and produced in care of Christopher Leger, Counsel;Wyoming Office of Consumer Advocate; 2515 Warren Avenue, Suite 304; Cheyenne, WY 82002.DATA REQUESTS
Application
Please explain in detail why the Company’s 2017R RFP solicits up to 1,270 MWs of new wind generation in Wyoming yet the Company is seeking CPCNs for only 860 MWs of new wind. (Application page 7).
Are the economics of the combined projects, as described in the testimony of Mr. Link based on 860 MWs of new wind or on 1,270 MWs of new wind?
How many MWs of additional QF generation are available from known projects with executed contracts? (Application page 8).
Is the economic analysis performed in support of the combined projects in this proceeding separate from that contained in the 2017 IRP in support of the preferred portfolio, or are they the same? Please explain in detail. (Application page 11).
Please provide an analysis showing the impact to jobs in Wyoming’s coal mining industry, as well as the impact on severance and property taxes if the combined projects are constructed. Please bifurcate the analysis between the periods 2021 through 2028, and 2028 and beyond. (Application page 11).
Please provide a sensitivity analysis showing the relative sensitivity of the combined projects to changes in PTC revenue. At what level of PTC revenue do the combined projects become uneconomic?
Please compare and contrast Black Hills Power’s IRP process with that of the Company. How are they similar and how are they different? (Application page 14)
Crane
What is the current market value of a REC? (Crane page 3).
How is the long term risk associated with future carbon regulation policy quantified by the Company in this proceeding? (Crane page 3).
Please describe in detail which long-term regional transmission plan the transmission projects proposed in this proceeding are an integral part of. Please provide references and specific cites to the plan. (Crane page 3).
Among the benefits of the transmission projects asserted by the Company is a reduction in congestion on the eastern Wyoming system. Will the project alleviate or even moderate congestion on Path 19 – west of Bridger? (Crane page 3).
Under the Company’s proposal, would the difference between base PTC credits and actual PTC credits be tracked until such time as the Federal PTCs are finally phased out? (Crane page 4).
How does the Company propose to recover the cost of rights-of-way, permits and other development costs for the transmission projects in the event that the transmission projects do not move forward? (Crane page 6).
In addition to the voltage support purported to be provided by the transmission projects, will the wind generation intended to the proposed transmission projects be equipped with advanced power controls that enable it to provide frequency support and synthetic inertia to the bulk electric system? (Crane page 8).
Please provide path utilization statistics for the 230 kV system in eastern Wyoming in the form of the U50, U75 and U99 metrics typically used by the Western Electricity Coordinating Council in describing congestion. (Crane page 8).
Please provide a five year outage and deration history for the 230 kV system in eastern Wyoming. (Crane page 8).
Are the transmission paths leading out of Wyoming more or less congested than the 230 kV system in eastern Wyoming? Please provide path utilization metrics for these paths quantifying your answer.
Who ultimately bears the risk of the costs incurred to complete the transmission projects if they are not completed in time for the Company to obtain the full value of PTCs associated with the proposed wind projects? Please explain your answer in detail. (Crane page 11).
Please provide a projected stream of REC revenue associated with the wind projects over the next 30 years. (Crane page 12).
Does the Company expect that the transmission projects will enable additional interconnection of QF wind resources in eastern Wyoming once completed? Please explain in detail. (Crane page 13).
Please explain in detail how the Company intends to diversify Wyoming’s economy without threatening existing industries and jobs. (Crane page 13).
Please provide any Rating Agency opinions, advisories or any other material related to the Company’s proposal in this proceeding. (Crane page 14).
Have the proposed transmission projects been included in the NTTG planning cycle and if so have they also been included in the WECC TEPPC 2026 Common Case? (Crane page 15).
Teply
The 2017 IRP preferred portfolio identified approximately 1,100 MW of new wind in Wyoming. The Company’s 2017R RFP proposes to acquire 860 MW of new wind in Wyoming. The proposed transmission projects are purported sized to allow the integration of up to 1,270 MW of new resources in eastern Wyoming. Please explain in detail why customers should pay for excess transmission capacity provided by the transmission projects. (Teply page 2).
The Application in this matter (page 8) states that the Company has considered known QF capacity with executed contracts that is reasonably expected to be in service by year-end 2021. Mr. Teply states that QF wind resources that began construction prior to January 1, 2017 must have an in-service date of year-end 2020. Please explain in detail how these two provisions relate to each other. (Teply page 7).
How many MW of new wind generation does the Company intend to select through the 2017R RFP process? (Teply page 7).
Will the CPCN applications referred to by Mr. Teply at page 8, line 7, of his testimony be separate applications than those in the instant application and, if so, when will they be filed?
Will the Company’s benchmark wind projects be Company owned or owned by a third party developer? How does the Company’s safe-harbor purchase of equipment in late 2016 fit into the benchmark proposals? (Teply page 9).
When does the Company expect a decision from the ISC with regard to its benchmark proposals? (Teply page 11).
Please provide any studies conducted by the Company to quantify wind capacity factors in the areas of the benchmark projects. (Teply page 11).
When will we know who is responsible for engineering, designing and constructing the benchmark wind facilities? Could this be a QF owner? (Teply page 11).
For wind capacity selected beyond the benchmark projects (presumably up to 1,270 MW) will this capacity be constructed by the Company or a developer? Does it have to be in service by year-end 2020? (Teply page 11).
What happens to the safe-harbor equipment if it is not used in the construction of the benchmark projects? (Teply page 12).
Is the cost of equipment obtained from the 2016 competitive procurement process still relevant to the Commission’s review of the Company’s proposal in this proceeding? (Teply page 13).
Outside of the Greater Sage Grouse, has the Company obtained all of the requisite permits for the siting of the wind and transmission projects proposed in this case, for example: birds of prey; big game migration routes; Eagle take permits; other protected species? (Teply page 14).
Could the expected life of the wind projects also be reviewed and reduced based on new technologies and other factors? (Teply page 15).
Has the Company developed contingency plans if it encounters abnormal construction circumstances, weather conditions, labor availability or materials delivery in constructing the wind projects? (Teply page 17).
Vail
Please provide the relevant WECC path rating studies for the combined transmission projects that are the subject of this proceeding. (Vail page 4).
Please describe in detail how the transmission projects will allow the Company to “more efficiently utilize existing generation resources in Wyoming to serve loads in Wyoming, Idaho, Utah and the Pacific Northwest. (Vail page 4).
Please explain in detail how the transmission projects will “enhance the Company’s ability to comply with mandated NERC and WECC reliability and performance standards. Please identify and discuss the relevant standards. (Vail page 4).
Please provide a map similar to that depicted in RMP_RAV-1, but with political subdivisions, roads, rivers and other geographic features shown, and without land ownership shown. (Vail page 6).
Will any of the structures in the Anticline-to-Bridger line be wood structures? (Vail page 6).
Will the structures in the Anticline-to-Bridger line be convertible to 500 kV in the future if the need arises? (Vail page 6).
Will the new RAS involve load shedding either within Wyoming or across the PAC system, or both? Please explain in detail. (Vail page 8).
Please explain and justify the need to design the Anticline substation to accommodate the future installation of phase shifting transformers. (Vail page 9).
Please describe in detail the site emergency power planned at the Anticline substation. (Vail page 9).
Will the proposed combined transmission projects increase the capacity on Path 19 west of Bridger? If so, by how much? (Vail page 10).
Do the proposed combined transmission projects simply move the congestion that currently exists in eastern Wyoming to Bridger? Please explain in detail. (Vail page 10).
Will Bridger end up as the swing resource to “follow” the wind if the wind and transmission projects proposed in the Application are built? Please explain in detail. (Vail page 10).
Has the Company conducted any power flow, dynamic stability or other studies to determine the impact of Bridger redispatch on, for example, spinning reserves, VAR support, frequency response, etc. Please explain in detail. (Vail page 10).
With regard to the new 230 kV line that will parallel the existing 230 kV line near the Freezeout Mountains, please explain in detail why the Company did not opt to reconstruct the existing line as a single line with a higher voltage rating, i.e. 345 kV. (Vail page 11).
Please justify the need to reconstruct the Aeolus to Freezeout to Standpipe 230 kV line. (Vail page 11).
Please identify in detail the amount of cost that the Company expects to incur to develop the combined transmission projects prior to the commencement of construction. (Vail page 12).
Please describe in detail how the Company expects to recover pre-construction development costs if the wind and transmission projects are not ultimately fully developed. (Vail page 12).
In its Application the Company avers that the combined transmission projects are a critical path component of the overall combined projects. The Company also states that it has yet to acquire all of the rights-of-way necessary to construct the combined transmission projects. Has the Company planned for the contingency that a portion of the necessary rights-of-way will have to be acquired through condemnation proceedings? Please explain in detail. (Vail page 13).
Please explain in detail how the additional transmission capacity provided by the combined transmission projects will allow the Company to move incremental energy out of Wyoming and offset higher cost energy elsewhere on its system or that of other participants in the EIM, particularly in view of the existing west of Bridger constraint. (Vail page 15).
Please provide copies of the relevant “WECC Region plans” and “the most recent Northern Tier Transmission Group sub-regional plan”. (Vail page 22).
Are the proposed combined transmission projects necessary for reliability purposes? (Vail page 22).
Please provide copies of any line-loss studies conducted by the Company regarding the proposed combined transmission projects. Please quantify the value of cost savings attributable reduced line-loss. (Vail page 23).
Please identify and describe any and all federal, state or local permits that must still be obtained before construction of the combined transmission projects can commence. (Vail Exhibit RAV-10, page 1 of 1).
Link
Please describe and quantify “the long term risk associated with potential future state and federal policies targeting carbon dioxide (“CO2”) emissions reductions from the electric sector”. Please cite any federal or Wyoming state law, rule or regulation relied on in quantifying this risk. (Link page 3).
From the Company’s perspective, has the risk of CO2 emissions limits in Wyoming or at the federal level increased or decreased in the last year. Please explain in detail. (Link page 3).
Please quantify the amount of PVRR(d) savings that is attributable to the transmission projects as opposed to the new wind projects under the 9 scenarios studied by the Company. (Link page 4).
The Company avers that the Aeolus to Bridger/Anticline Line was included in the 2017 IRP preferred portfolio. Were the 230 kV upgrades proposed in the Application in this proceeding also included in the 2017 IRP preferred portfolio? Please explain in detail. (Link page 5).
What is the relevance of earlier resource portfolio screening to the Application in this proceeding, including forward market prices and federal CO2 policy based on the CPP, in view of the fact that the CPP has not been, and likely will not be implemented? Please explain in detail. (Link page 9).
Please explain and justify how the Company’s proposed depreciation life for the new wind facilities (up to 1,170 MW) of either 30 or 40 years is consistent with the Company’s long standing position that 20 year contract terms for PPAs are far too long and not in the public interest. (Link page 21).
Please explain in detail the terms of the PPAs that cause the price of power purchased under PPAs to increase by nearly 200% over their terms. (Link page 23).
Please describe in detail the process used to determine that transmission wheeling revenues would offset approximately 12% of the increased revenue requirement associated with the transmission projects. Are all of the new transmission segments categorized as “interstate” in nature? Will all of the 230 kV segments generate wheeling revenue? (Link page 23).
Have the transmission projects been selected for cost allocation under the planning process of a regional planning group such as NTTG? (Link page 23).
Will the proposed transmission projects provide economic, public policy or reliability benefits to the owners of other transmission facilities that they should pay for? Please explain in detail. (Link page 23).
Please describe in detail how the increased transfer capability of 300 MW from the east side of PAC’s system to the west side is related to the increased transfer capability of 750 MW from eastern Wyoming to western Wyoming that is provided by the new transmission investments. (Link page 26).
Will the Company be left with excess transmission capacity in Wyoming when DJ retires at the end of 2027? Please explain in detail. (Link page 29).
Does the Company consider the projected $137 million PVRR(d) savings (medium gas, medium CO2) over the period to 2050 to be substantial savings? (Link page 39).
Please describe in detail how the Company calculates the benefits assigned to REC sales. (Link page 41).
Please describe in detail any plans that have been or will be developed by the Company to mitigate the precipitous revenue requirement increase that will occur in 2030 when the wind PTCs expire. (Link page 42).
Please describe in detail why a 40 year depreciable life, or even a 30 year depreciable life on the wind projects is reasonable in view of the fact that the Company, in a companion proceeding, is proposing to repower the vast majority of its existing wind after only 10 years of service. (Link page 43).
Larsen
Please identify the discount rate used in the PVRR(d) analysis supporting the Company’s Application in this docket and describe in detail the process used by the Company to develop that rate. (Larsen page 4).
Will the RTM proposed by the Company in this proceeding reduce the risk that the Company will not timely recover the costs associated with the combined transmission and wind projects? Will the RTM increase the certainty that the Company will earn its required return on investments tracked in the RTM? (Larsen page 8).
Are credits for the sale of emissions allowances currently captured in the Company’s existing ECAM and so, are not proposed to be included in the proposed RTM? (Larsen page 10).
Please explain in detail why the current depreciation rates will be applied to the gross plant in service of the combined projects, rather than the net plant in service of the combined projects. (Larsen page 11).
Does the RTM provide for the true-up over time of costs and benefits attributable to the combined projects such that customers pay the actual cost, plus the allowed return on those investments? (Larsen page 12).
Will the existing ECAM continue to operate as currently structured, notwithstanding the establishment of the RTM. Does the Company anticipate any modifications to the ECAM as a result of the adoption of the RTM. Please explain in detail. (Larsen page 12).
With regard to the RTM, how will the Company account for prospective changes in the federal income tax rate? (Larsen page 13).
Could the impact of the combined projects on Wyoming’s allocated revenue requirement be drastically different if MSP changes in 2019? (Larsen page 16).
General
On a continuing basis, please provide all direct and supplemental responses to any past, present, and future discovery propounded by any party in this proceeding, as well as the Staff of the Wyoming Public Service Commission.
DATED:Tuesday, August 08, 2017OFFICE OF CONSUMER ADVOCATE
_______________________________
Christopher Leger, Counsel
Wyoming Bar # 6-3963
Wyoming Office of Consumer Advocate
2515 Warren Avenue, Suite 304
Cheyenne, WY 82002
[phone]
[e-mail]
CERTIFICATE OF SERVICEI hereby certify that on August 8, 2017, I served the foregoing First Set of Data Requests by delivering copies thereof to the individuals/entities below, by the method(s) indicated:
Yvonne Hogel
Senior Counsel
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT84111
[e-mail]
e-mail
Stacy Splittstoesser
Wyoming Regulatory Affairs Manager
Rocky Mountain Power
1807 Capitol Ave. Suite 200A
Cheyenne, Wyoming 82001
[e-mail]
e-mail and U.S. Mail
Paul Hickey
Hickey & Evans, LLP
PO Box 467
Cheyenne, WY 82003-0467
[e-mail]
email
Katherine McDowell
McDowell Rackner & Gibson PC
419 SW 11th Ave, Suite 400
Portland, OR 97205
[e-mail]
email
Data Request Response CenterPacifiCorp
825 NE Multnomah, Suite 800
Portland, Oregon97232
[e-mail]
e-mail
Crystal J. McDonough
McDonough Law, LLC
1635 Foxtrail Dr. #327
Loveland, CO 80538
[e-mail]
email
Robert M. Pomeroy, Jr.
Thorvald A. Nelson
Abigail C. Briggerman
Nikolas S. Stoffel
Holland & Hart LLP
6380 South Fiddler's Green Circle, Suite 500
Greenwood Village, CO 80111
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
e-mail
OFFICE OF CONSUMER ADVOCATE
_______________________________
Christopher Leger, Counsel
Wyoming Bar # 6-3963
Wyoming Office of Consumer Advocate
2515 Warren Avenue, Suite 304
Cheyenne, WY 82002
[phone]
[e-mail]