20170829Wyoming_WIEC Set 4 (1-3).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’
FOURTH 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 itsFourth 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, i.e., by September1, 2017, 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.
FOURTH SET OF DATA REQUESTS
In Wyoming Public Service Commission Docket No. 20000-481-EA-16 (Record No. 14220), Rocky Mountain Power witness Mr. Paul Clements stated in his August 26, 2015 Direct Testimony (at page 3, lines 21-22):
“The Company has no need for additional resources for at least the next decade.”
Please admit that this statement remains true as of the date of Rocky Mountain Power’s filing of its Application in this proceeding. If the answer is anything other than an unqualified admission, please explain your answer.
Please admit that this statement was made in reference to both energy and capacity needs. If the answer is anything other than an unqualified admission, please explain your answer in detail.
Please explain any changes to the Company’s forecasted load over the next decade since this statement was made. Please explain your answer.
Please identify any changes in the Company’s resource mix over the next decade since this statement was made. Please explain your answer.
Please provide a list of all Qualifying Facilities in the queue, identifying the facility’s name, the facility’s location by state, the type of generation (i.e, wind, solar, etc.), the capacity of the facility, the expected commercial online date, whether power purchase agreement has been executed, and the power purchase agreement term length. Please provide your answer in live, Excel format.
In Rocky Mountain Power’s 2017 Integrated Resource Plan Energy Vision 2020 Update, filed with the Commission in Docket No. 20000-512-EA-17 (Record No. 14667) on August 2, 2017, Rocky Mountain Power stated (at page 5):
Net customer benefits are calculated as the present-value revenue requirement differential (PVRR(d)) between two simulations of PacifiCorp’s system. One simulation includes the relevant components of the Energy Vision 2020 projects (i.e., either wind repowering or new wind and new transmission) and the other simulation excludes these investments. Customers are expected to realize benefits when the PVRR with the Energy Vision 2020 projects is lower than the system PVRR without these investments. Conversely, customers would experience increased costs if the system PVRR with Energy Vision 2020 projects were higher than the system PVRR without them
Please reconcile this statement with the following Rebuttal Testimony of Rocky Mountain Power witness Mr. Robert M. Meredith (Utah Public Service Commission Docket No. 14-035-114, July 25, 2017 Rebuttal Testimony at page 18, line 339 through 359 (footnotes omitted)):
Rebuttal of Vivint Solar witness Richard Collins
Q. Mr. Collins references the present value of revenue requirement difference between a high private generation sensitivity case and a base sensitivity case from the 2015 Integrated Resource Plan (“IRP”) and concludes, as does HEAL Utah witness Mr. Fisher, that this results in a net benefit associated with residential solar. Do you agree?
A. No. The IRP sensitivities are not a net benefit analysis. Private generation is modeled as a reduction to load without any assignment of the incremental cost of private generation that non-participating customers pay in the form of bill credits. Also, the IRP is used to prepare a long-term resource plan that is based on a 20-year planning horizon. To this end, the IRP sensitivity studies also capture potential changes to long-term system costs that are increasingly uncertain over the 20-year forecast used for any given IRP. Those potential benefits, such as lower fuel costs, are subject to change with the underlying market conditions relative to what was assumed in a 20-year forecast used for any given IRP. For example, in the 2015 IRP, the change in nominal levelized system costs calculated over a 20-year period between the low private generation sensitivity and the base case was $74 per megawatt hour. A comparison of this same value in the 2017 IRP yields a nominal levelized value of $58 per megawatt hour, which is a 22 percent reduction relative to the 2015 IRP. A determination of the costs and benefits of NEM should not rely upon the difference between a pair of IRP sensitivity runs, because they include benefits that are anticipated many years into the future.
Respectfully submitted this 22nd day of August, 2017.
HOLLAND & HART LLP
By: Abigail C. Briggerman, #7-5476
Holland & Hart LLP
6380 South Fiddlers Green Circle, Suite 500Greenwood Village, CO 80111
Telephone: (303) [e-mail] FOR WIEC
CERTIFICATE OF SERVICE
I hereby certify that, on this 22nd day of August, 2017the WYOMING INDUSTRIAL ENERGY CONSUMERS’ FOURTH 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
315 West 27th Street
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/ Adele C. Lee
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