20170815Wyoming_WIEC Set 2 (1-8).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.
DOCKET NO. 20000-520-EA-17
(Record No. 14781)WYOMING INDUSTRIAL ENERGY CONSUMERS’
SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
The Wyoming Industrial Energy Consumers (“WIEC”), an unincorporated association comprised of industrial energy consumers, by and through its undersigned counsel, Holland & Hart LLP,respectfully submits itssecond set ofdata requests to Rocky Mountain Power, a division of PacifiCorp (“PacifiCorp,” the “Company,” or “Rocky Mountain Power”). The following response date, definitions, and instructions apply to this set of data requests:
RESPONSE DATEPlease respond to these data requests within 10 calendar days, unless an earlier date is specified by the Wyoming Public Service Commission or by agreement between WIEC and Rocky Mountain Power.
DEFINITIONS AND INSTRUCTIONSPlease refer to the Definitions and Instructions included in WIEC’s First Set of Data Requests to Rocky Mountain Power in the above-captioned docket.
SECOND SET OF DATA REQUESTS
To the extent available in Microsoft Excel format, please provide a complete copy of all of the exhibits to the direct testimony of Ms. Crane, Mr. Teply, Mr. Vail, Mr. Link, and Mr. Larsen in that electronic format with all formulae, links and underlying worksheets and workbook intact.
Referring to Mr. Link’s direct testimony at page 8:
Please provide a complete copy of all power flow and dynamic-stability analyses and studies that PacifiCorp has performed, or had performed on its behalf, to determine the incremental transfer capability of the proposed new transmission line will be 750 MW and it could enable up to 1,270 MW of new resource interconnections.
Please provide a complete copy of all PSS/E power flow and dynamic-stability results that underlie the analyses and studies provided in response to subpart (a).
Please provide an electronic copy of all Siemens PTI PSS/E and MUST monitoring, contingency, subsystem files, PSAS, IPLAN and Python files utilized to perform the analyses and studies provided in response to subpart (a).
Please provide in “sav” format a complete copy of the Siemens PSS/E power flow files used to perform the analyses and studies provided in response to subpart (a). When providing these files, please identify the version of PSS/E from which they were produced.
Please provide a complete copy in electronic format of all Microsoft Excel workbook and worksheets used to compile, process, or analyze the results from the analyses and studies provided in response to subpart (a) with all formulae, links, and underlying workbooks and worksheets intact.
Referring to the direct testimony of Mr.Link at pages 16-18:
Please provide a complete copy of all Present Value Revenue Requirement (“PVRR”) System Optimizer (“SO”) and Planning and Risk (“PaR”) analyses performed by, or on behalf of, PacifiCorp for the Combined Projects.
Please provide a complete copy of the SO and PaR output files that underly the analyses provided in response to subpart (a).
Please provide a complete electronic copy of all Microsoft Excel workbooks and worksheets utilized by PacifiCorp to perform or process the results from the analyses provided in response to subpart (a) with all formulae, links, and underlying workbooks and worksheets intact.
Referring to the direct testimony of Mr. Link at pages 23-24:
Please admit that FERC could determine that the Transmission Projects should not flow into PacifiCorp’s OATT rates on the basis that the Transmission Projects are specifically being pursued to integrate and provided delivery of power from the Wind Projects to PacifiCorp’s bundled retail load customers.
Please fully identify and describe the impact on the PVR SO and PaR analysis results for the Combined Projects if FERC does determine the Transmission Projects should not flow into PacifiCorp’s OATT rates and instead should be assigned 100% to PacifiCorp’s bundled retail load customers?
Does PacifiCorp agree to hold its Wyoming bundled retail load customers harmless from a FERC decision to not allow the Transmission Projects to flow into PacifiCorp’s OATT rates?
Referring to the direct testimony of Mr. Link at pages 24-25:
Please provide a complete copy of all historical records, analyses and studies supporting:
An average derate of 146 MW over approximately 88 days per year; and
A 36.5 MW reduction in the transfer capability from eastern Wyoming to the Aeolus area.
Please provide a complete electronic copy of all Microsoft Excel utilized to compile the historical records and perform the analyses and studies provided in response to subpart (a)with all formulae, links and underlying workbook and worksheets intact.
Referring to the direct testimony of Mr. Link at page 25:
Please providea copy of all analyses and studies performed by, or on behalf of, Pacificorp that support the estimated line-loss benefit of the Transmission Projects with the Wind Projects in-service.
Please provide a complete copy of all PSS/E power flow results that underly the analysis and studies provided in response to subpart (a).
Please provide a complete electronic copy of all Microsoft Excel workbooks and worksheets that were used to perform, process the results from or compile the results from the analyses and studies provided in subpart (a)with all formulae, links, and underlying workbooks and worksheets intact.
Referring to the direct testimony of Mr. Vail at pages 13-14:
If the Commission grants PacifiCorp’s requested conditional CPCN for the Transmission Projects, will PacifiCorp hold its bundled retail load customers in Wyoming harmless from right-of-way acquisition costs and all other costs PacifiCorp incurs for the Transmission Projects if in the end the Commission does not grant a CPCN for the Wind Projects or PacifiCorp fails to acquire all of the necessary right-of-way?
If the Commission grants PacifiCorp by the requested dates a conditional CPCN for the Transmission Projects and a CPCN for the Wind Projects, will PacifiCorp hold its bundled retail customers in Wyoming harmless from any lost federal Production Task Credits related to a delay in the completion of, or a failure to complete, the Transmission Projects or the Wind Projects?
Referring to the direct testimony of Mr. Vail at page 17.
Please provide a copy of all analyses and studies performed by, or on behalf of, Pacificorp that support the critical voltage support benefit of the Transmission Projects.
Please provide a complete copy of all PSS/E power flow results that underlie the analysis and studies provided in response to subpart (a).
Please provide a complete electronic copy of all Microsoft Excel workbooks and worksheets that were used to perform, process the results from or compile the results from the analyses and studies provided in subpart (a)with all formulae, links, and underlying workbooks and worksheets intact.
Respectfully submitted this 26th day of July, 2017.
HOLLAND & HART LLP
By: s/ Nikolas S. StoffelAbigail C. Briggerman, #7-5476Nikolas S. Stoffel, #7-5484
Holland & Hart LLP
6380 South Fiddlers Green Circle, Suite 500Greenwood Village, CO 80111
Telephone: (303) [e-mail]@hollandhart.comATTORNEYS FOR WIEC
CERTIFICATE OF SERVICE
I hereby certify that, on this 26th day of July, 2017the WYOMING INDUSTRIAL ENERGY CONSUMERS’ SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER was served via electronic mail or U.S. Mail, addressed to the following:
Stacy Splittstoesser
Wyoming Regulatory Affairs Manager
Rocky Mountain Power
1807 Capital Avenue, Suite 200A
Cheyenne, WY 82001
[e-mail]
Paul Hickey
Hall & Evans, LLP
P.O. Box 467
Cheyenne, WY 82003-0467
[e-mail]
Wyoming Public Service Commission
2515 Warren Avenue, Suite 300
Cheyenne, WY 82002
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
[e-mail]
Katherine McDowell
McDowell Rackner & Gibson PC
419 SW 11th Avenue, Suite 400
Portland, OR 97205
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]
Ivan H. Williams
Christopher Leger
Wyoming Office of Consumer Advocate
2515 Warren Avenue, Suite 304
[e-mail]
[e-mail]
s/ Nikolas S. Stoffel
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