20170829Utah_DPU Set 6 (1-8).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 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
6thSet of Data Requests to
ROCKY MOUNTAIN POWER
August 15, 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.
PTC Rate Recovery and Risk
Larsen Testimony. In reference to Mr. Larsen’s Testimony, lines 45-47 and lines 248-252:
Please provide any analysis that the Company has done to evaluate the annual variability of wind production of energy and PTC caused by weather pattern fluctuations. Please include any analysis of historical operations of other existing wind energy facilities in the region and any simulations of the performance of the Benchmark Wind Projects. Please include any supporting workpapers, inputs and models that support the Company’s analysis with formulas intact.
Please identify any other factors that could cause the wind energy and PTC production to vary from year-to-year. Please provide any analysis that the Company has done to evaluate the annual variability of wind production of energy and PTC caused by these factors.
Please identify all wind energy and PTC production risks associated with design, manufacturing, construction (quality and schedule), or operations that will be the subject of warrantees in contracts with any third parties or covered by insurance. Please describe the contractual provisions (e.g., liquidated damages provisions, insurance coverages) that will provide the Company and its ratepayers with protection against losses associated with these risks.
Larsen Testimony. In reference to Mr. Larsen’s Testimony, lines 43-45: Is an ongoing true-up of PTC’s through a RTM following the next general rate case consistent with the rate treatment of PTC’s associated with the Company’s existing PTC eligible wind resources? If not, describe the current rate treatment for PTC associated with the Company’s existing PTC eligible wind resources and explain why the proposed treatment for this case is different?
Crane Testimony. In reference to Ms. Crane’s Testimony, lines 68-70:
Does the Company anticipate being able to recover damages (including but not limited to liquidated damages or insurance claims) for “lost” PTC value in the event that the Combined Projects do not achieve commercial operation by December 31, 2020?
Please provide the terms including any limitations of such recovery.
Please explain how the Company proposes to pass such recovery on to customers.
Larsen Testimony. In reference to Mr. Larsen’s Testimony, lines 244-246:
Does the Company plan to adjust the tax gross-up rate used to calculate the revenue requirement value of the PTC tax credits to reflect any adjustments in the tax gross-up rate approved in future base rate cases?
Please provide any analysis that the Company has done to evaluate the change in the tax gross-up rate that would result from any tax reforms that may be considered by Congress in 2017. Please describe any risks to the economic viability of the Projects that may result from these potential tax reforms.
Qualifying Facilities
Teply & Link Testimony. In reference to Mr. Teply’s Testimony, lines 101-107 and Mr. Link’s Testimony, lines 484-487:
Please provide a copy of all purchased power agreements and interconnection agreements with QFs referenced in this passage.
Please any documents or analysis that support the Company’s expectation that these QFs will be in-service by the end of 2021. Provide any assessment of the likelihood that the projects will be successfully completed.
Please identify all other potential QFs in the Aeolus area that are known to the Company. For each QF identified, please:
Describe the status of the project (including interconnection, contract, and timing).
Describe why the project was not included in the group of QFs assumed in the Combined Projects.
Provide any assessment that the Company has made of the potential for these projects to be developed.
Link Testimony. In reference to Mr. Link’s Testimony, lines 487-493:
Please provide all documents or assessments of the QF Projects feasibility that support the Company’s conclusion that they are reasonably expected to connect to the system if the Transmission Projects are in-service.
Please describe the basis for the Company’s conclusion that the QF projects are not expected to interconnect without the Transmission Projects. Provide any studies or assessments of the interconnection of the QF Projects supporting this conclusion.
Link Testimony. In reference to Mr. Link’s Testimony, lines 519-522:
Please confirm that the QF Projects are not assumed to continue operation beyond 2014 in any analysis of the Combined Projects. If not confirmed, provide the assumptions used for the QF Projects’ production and pricing after 2041 in the analysis of the Combined Projects?
Please provide any documents or analysis that support the aggregate capacity factor assumption for the QF Projects.
Please provide any analysis available to the Company pertaining to the uncertainty of energy production from the QF Projects, including variance in annual production values and in long-term average production levels.
Please provide a description of any performance guarantees contractually provided by the QF Projects.
Link Testimony. In reference to Mr. Link’s Testimony, lines 840-843:
Please provide any analysis conducted by the Company of a case including an extension of the QF Projects’ PPAs or the procurement of additional wind resources after the term of those PPAs.
Provide the assumptions used in that analysis regarding the cost and performance of those resources.
Provide all studies, documents, or analysis that indicates that benefits are likely from extension of the PPAs or procurement of additional wind resources.
DPU Requestor:Daymark(801) 530-6653
Erika Tedder - [phone]
cc:Service List