20170828Staff 1-48 to PAC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.7956
Street Address for Express Mail:
472 W.WASHINGTON
BOISE,IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )PACIFICORP DBA ROCKY MOUNTAIN )CASE NO.PAC-E-17-07
POWER FOR A CERTIFICATE OF PUBLIC )
CONVENIENCE AND NECESSITY AND )BINDING RATEMAKING TREATMENT FOR )FIRST PRODUCTION
NEW WIND AND TRANSMISSION FACILITIES)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and throughits attorney of record,
Brandon Karpen,Deputy Attorney General,requests that Rocky Mountain Power provide the
followingdocuments and information as soon as possible,but no later than MONDAY,
SEPTEMBER 18,2017.
This Production Request is to be considered continuing,and Rocky Mountain Power is
requested to provide,by way of supplementaryresponses,additional documents that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title and telephone number of
the person preparing the documents.Please identifythe name,job title,location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 28,2017
In addition to the written copies provided as response to the requests,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.1:Please provide workpapers,exhibits,tables,and any analysis
supporting the Company's filing in electronic format with formulae intact with references to
sources for all pasted values.
REQUESTNO.2:Please provide copies of all past and future data requests and
responses received by or sent from Rocky Mountain Power to any party in related applications
submitted in other state jurisdictions.Please include both formal and informal responses.In
addition to requests made in Idaho,please provide copies of PacifiCorp's responses to new wind
and transmission data requests submitted by all parties in the states of Utah,Washington,
Oregon,Wyoming,and California.This response should include public and confidential data
responses.Please provide all future responses at,or shortlyafter,the time when the Company
files its responses to other parties'requests.As responses are provided,please include a
summary of the state name,organization and DR#s for the DRs containedwithin each response.
REQUESTNO.3:Please provide a list of all regulatory authorizations required for the
project.Please identify the authorizations,if not obtained,that would cause the Company to
cancel or modify the project,and explain why it would affect the project and specifically what
action the Company would take.
REQUESTNO.4:Please provide all information since the last depreciation study
supporting the Company's basis for a 30-year depreciation life of the wind turbine generators
(i.e.,manufacturer data or studies).
REQUESTNO.5:Please explain all IRS requirements needed by the Company to
receive 100%of the PTC's related to PAC-E-17-07 projects.
REQUESTNO.6:Please detail all IRS requirements the Company has completed to
date by project site in order to qualify for 100%of the PTC's referenced by PAC-E-17-07.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 28,2017
REQUESTNO.7:Please detail all remaining IRS requirements by project site which
the Company has yet to complete in order to qualify for 100%of the PTC's referenced by
PAC-E-17-07.
REQUESTNO.8:In reference to Company witness Teply's testimony on page 7,
please provide the documentation,by Wind Project,showing that the Company has met the "start
of construction"requirement,and the "safe harbor"requirement for the PTCs.Include all source
documents includingreceipts,journal entries,emails,contracts,and any other documents for the
purchases and acquisitions for the Wind Projects before December 31,2016.
REQUESTNO.9:Please explain the Company's approach to meet IRS Safe Harbor
eligibilityincluding start of construction,continuityand any other provisions.
REQUESTNO.10:If the Company does not meet the December 2020 completion
project date,please describe in detail the Company's contingency plans to obtain 100%
eligibilityof PTCs.
REQUESTNO.11:The Company has provided economic analysis of the project
assuming 100%eligibilityand receipt of the PTCs.Please provide similar analysis of the project
if full receipt of the PTC is not met (i.e.80%,60%,and 40%).
REQUESTNO.12:With respect to the previous question,please quantify the
likelihood of not receiving 100%of the PTC.
REQUESTNO.13:In order for customers to realize the full net benefits of the project
as proposed by the Company,the Company will need to execute its plan on schedule and under
proposed cost estimates.Below are three potential conditions that would put ratepayer net
benefits at risk.For each circumstance below,please describe how the Company would ensure
customers are compensated for lost benefits or increased costs that are the Company's
responsibility.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 28,2017
a.Reduction in PTC Benefits related to non-attainment of IRS Safe Harbor
requirements (not meeting requirements necessary for 100%of PTC);
b.Reduction in PTC,NPC,and wholesale wheeling revenue benefits related to late
schedule completion;
c.Cost overruns due to construction,capital infrastructure cost,cost to establish
right-of-way,permitting,etc.
REQUESTNO.14:Please provide the average yearly market price of wind RECs over
the past five years,in addition to the projected value of these RECs over the next 10 years.
REQUESTNO.15:Please provide the Company's Project Plan includingbut not
limited to:
a.A detailed schedule/Ganttchart reflecting all major activities on the critical path.
b.Any contingency plans the Company will implement to recover from delays.
c.Project risks,the likelihood of these risks,and costs associated with those risks.
REQUESTNO.16:Please list and quantifythe potential for schedule delay related to:
a.Jurisdictional approval
b.Permitting
c.Procurement
d.Construction
REQUESTNO.17:Please provide the transmission capacity and the monthlypercent
utilization for the existing line segment between Aeolus and Jim Bridger.
REQUESTNO.18:Please provide a detailed map of the existing transmission system
for Wyoming identifyingthe individual segments and the segment transmission capacity.
Separately provide a table showing each transmission segment and the monthlyutilization for
each of the segments.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 28,2017
REQUESTNO.19:Please provide additional detail and examples related to Mr.Link's
testimony on page 7,lines 18-20 -"At times when wind resources in southeastern Wyoming are
operating near full output,other resources in the area can be re-dispatched to accommodate PTC-
producing wind generation."
REQUESTNO.20:Presupposing a new transmission line between Aeolus and
Anticline,would the 60 MVAr synchronous condenser at Standpipe still be required for voltage
stabilization?(Vail,Di.24)
REQUESTNO.21:Please provide all related costs associated with the installation of
the synchronous condenser located at Standpipe.(Vail,Di.24).
REQUESTNO.22:Please indicate if the Company plans to evaluate the bids through
its proposed Request for Proposal process from the perspective of the utility or from the
perspective of the ratepayer.In other words,will the Company include the Company's
authorized rate of return when evaluating the cost of the Company's submitted bids for its
benchmark projects versus the cost of a Purchase Power Agreement for a developer owned and
operated facility?Please provide an example of the analysis over the life of the project to
compare the benchmark project to a PPA.
REQUESTNO.23:The Request for Proposal solicitation includes a provision allowing
the Company to purchase the wind development project under a build-transfer agreement (Link,
Di.13).How will the Company ensure that Customers not be economically disadvantaged if the
Company chooses to purchase the facility?
REQUESTNO.24:Has the Company considered and quantified other locations for
siting wind that would not require building additional transmission lines?If so,please provide
the analysis and the results.If not,why not?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 28,2017
REQUESTNO.25:Has the Company quantified the economic tradeoff between
reduced wind capacity factors and transmission investment expense?If so,please provide the
results of the analysis.If not,why not?
REQUESTNO.27:Please provide the NPVRR(d)of the project with capacity factors
of 20%,30%,40%,and 50%for the Company's benchmark wind projects using medium gas
price and medium CO2 price assumptions.
REQUESTNO.28:Please provide all supporting documentation for the transmission
project cost estimates by project section (i.e.the 3 projects included in the Aeolus-to-
Bridger/Anticline Line;and the 3 projects included in the 230 kV Network Upgrades).(Vail,Di
2)
REQUESTNO.29:Please provide all supporting documentation for the benchmark
wind project cost estimates.
REQUESTNO.30:Please explain how the Company determined the amount of
wheeling revenue benefit.Please provide workpapers showing the calculated amount with all
formulae intact.
REQUESTNO.31:Please provide a copy of PacifiCorp's Energy Vision 2020 strategy.
REQUESTNO.32:Please explain what the Company will do with the items procured
to meet the 5%safe harbor benchmark if the projects do not proceed.Will the Company request
customers pay these costs?
REQUESTNO.33:Please provide a list of all contracts required to complete the wind
and transmission projects.Please include the names of the contractor,the purpose of the
contract,and estimated cost amounts.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 AUGUST 28,2017
REQUESTNO.34:In reference to Company witness Larsen,please provide all
workpapers that were used to develop Exhibit 27 and Exhibit 28.
REQUESTNO.35:Please provide the estimated NPVRR(d)for the project if there is a
1 year,2 year,or 3 year slip to the project's completion.
REQUESTNO.36:What is the breakeven point for continuing with the combined
projects in relation to the Production Tax Credits?At what level of Production Tax Credits do
the costs of the projects become untenable?
REQUESTNO.37:When did the Company first begin analyzing the Production Tax
Credit after it was extended in the PATH Act of 2015?Specifically when did the Company
begin pursuing eligibilityfor PTC for these projects?
REQUESTNO.38:Did the Company investigate claiming the Investment Tax Credit
(ITC)in lieu of the PTC?Please provide any analysis the Company did as it pertains to the ITC.
REQUESTNO.39:IRS Notice 2017-4 states in Section 3,"If a facility does not satisfy
the Continuity Safe Harbor,whether the facility satisfies the Continuous Construction or
Continuous Efforts Tests is determinedby the relevant facts and Circumstances."If it is
determined that the Five Percent Safe Harbor is not met,what information will the Company rely
upon which will satisfy the Continuous Construction or Continuous Efforts Tests?Is the
Company compiling and retaining this information at this time?
REQUESTNO.40:Please provide System Optimizer and PaR files containing
assumptions,inputs,outputs,and summary information for all scenarios and sensitivities used in
PacifiCorp's economic analysis.For each scenario and sensitivity,provide a summary of the
parameters changed for each run.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 AUGUST 28,2017
REQUESTNO.41:Please provide a copy of the executed PPAs/interconnection
agreements for the 320 MW of QF Projects mentioned in Mr.Link's direct testimony on page
21.
REQUESTNO.42:Please provide and explain the analysis includingwork papers that
was performed to conclude the 36.5 MW reduction value is a reasonable assumption to show
reliability benefits (Link,Di.25).
REQUESTNO.43:Please provide and explain the analysis includingwork papers that
was performed to conclude the l 1.6 aMW value is a reasonable assumption to show line-loss
benefits (Link,Di.25).
REQUESTNO.44:Please provide additional detail on the 300 MW value chosen to
model the EIM benefits (Link,Di 26).For example,but not limited to in your explanation:
a.Is this capacity currentlyalways available to transfer between the east and west
sides of PacifiCorp's system?
b.Does this 300 MW value require the new transmission lines planned in the Energy
Gateway Transmission Expansion Plan?
c.Will the capacity be available during the most likely time when 300 MW of
power is needed?
REQUESTNO.45:Please explain and quantifythe transmission limitations created by
the Dave Johnston coal plan mentioned in Mr.Link's direct testimony on pages 29-30.
REQUESTNO.46:Staff is interested in the evaluation of alternatives that take
advantage of PTCs without additional transmission investment.Please provide and explain all
alternatives that take advantage of PTCs without additional transmission that were evaluated.
For example,but not limited to in your explanation:
a.How many different alternatives were evaluated?
b.Did any of the evaluated alternatives provide a benefit in PVRR(d)?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 AUGUST 28,2017
c.What are the net benefits and negative implications for implementing the
alternative?For example,taking advantage of PTCs 1-2 years sooner could show
benefits without installinga new transmission line or retiring a coal plant early
would negatively impact system voltage control.
d.Has the company considered and quantified shutting down the units of Dave
Johnston and/or Wyodak by 2020 to free up transmission capacity to install some
or all incremental wind to take advantage of PTCs?If so,please provide the
results of the analysis.If not,why not?Please explain.
e.What is the PVRR(d)if units of Dave Johnston and/or Wyodak are shut down and
incremental wind is installed/interconnected up to the freed up capacity amount?
If this type of analysis has been performed,please explain the assumptions used
and provide the summary files.
REQUESTNO.47:Based on the alternativesposed in Request No.46,indicate the
year and the amount of generationwhen incremental system capacity would be required.
REQUESTNO.48:Based on the alternativesposed in Request No.46,indicate the
difference to net power cost each year over the life of the projects.
DATED at Boise,Idaho,this day of August 2017.
B ndon en
Dep Attorney eneral
Technical Staff:Rick Keller/l-27
Kathy Stockton/28-41
Michael Eldred/40-48
i:umisc:prodreq/pace17.7bkrkkisme prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 AUGUST 28,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF AUGUST 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.
PAC-E-17-07,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
TED WESTON YVONNE R HOGLE
ROCKY MOUNTAIN POWER ASSITANT GENERAL COUNSEL
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 1407 WN TEMPLE STE 320
E-MAIL:[e-mail] SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER RANDALL C BUDGE
E-MAIL ONLY:RACINE OLSON NYE &BUDGE
[e-mail] PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL:[e-mail]
BRUBAKER &ASSOCIATES RONALD L WILLIAMS
16690 SWINGLEY RIDGE RD #140 WILLIAMS BRADBURY PC
CHESTERFIELD MO 63017 PO BOX 388
E-MAIL:bcollins consultbai.com BOISE ID 83701
E-MAIL:ron williamsbradbury.com
ELECTRONIC ONLY ELECTRONIC ONLY
JOHN DUKE KYLE WILLIAMS
IDAHOAN FOODS BYU IDAHO
E-MAIL:[e-mail] E-MAIL:[e-mail]
ELECTRONIC ONLY ERIC L OLSEN
VAL STEINER ECHO HAWK &OLSEN
NU-WEST INDUSTRIES INC PO BOX 6119
E-MAIL:[e-mail] POCATELLO ID 83205
E-MAIL:elco echohawk.com
ANTHONY YANKEL
UNIT 2505
12700 LANE AVENUE
LAKEWOOD OH 44107
E-MAIL:tony vankel.net
SECRETARY
CERTIFICATE OF SERVICE