20170905Idaho Irrigation Pumpers 1-11 to PAC.pdf

Eric L.Olsen (ISB#4811)
ECHO HAWK &OLSEN,PLLC
505 Pershing Ave.,Ste.100
P.O.Box 6119
Pocatello,Idaho 83205
Telephone:[phone]
Facsimile:[phone]
Email:eloda)echohawk.com
Attorneyfor Intervenor Idaho Irrigation Pumpers Association,Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION CASE NO.PAC-E-17-07
OF PACIFICORP DBA ROCKY
MOUNTAIN POWER FOR A IDAHO IRRIGATION PUMPERS
CERTIFICATE OF PUBLIC ASSOCIATION,INC.'S FIRST SET
CONVENIENCE AND NECESSITY AND OF DATA REQUESTS
BINDING RATEMAKING TREATMENT
FOR NEW WIND AND TRANSMISSION
FACILITIES
Idaho Irrigation Pumpers,Inc.,by and through counsel,hereby submits its first Data
Requests to Rocky Mountain Power,pursuant to Commission Rule 225,as follows:
1.Ms.Crane's Direct Testimony at page 8 states that the "Transmission Projects will increase
the transfer capability from east to west by 750 MW."It is understood that by "west"is
meant at or near Bridger.
a.How much excess transmission capacity is there west of Bridger that accommodate this
additional 750 MW of capacity coming from the east?
b.How will the additionalcapacity of 750 MW from the east be able to be absorbed by the
rest of the system?
2.Ms.Crane's Direct Testimony at page 8 states that when completed that the transmission
projects "will allow interconnection of up to l,270 MW of incremental wind resources".
Given that this Application deals with 860 MW of new wind resources,it appears that there
are an additional 410 MW that are not being addressedin this filing.What portion of this
additional 4l0 MW is viable,absent this transmission project?
3.For each hour from January 1,20l2 through the present,please answer the followingwith
respect to when Bridger had its output reduced because of excess capacity on the system:
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS-Page 1
a.How many MWh's were reduced because of excess generation anywhere on the system?
b.How many MWh's were reduced becauseof excess wind generation east of Bridger?
c.What was the Four Corners price of market power?
d.How many MWh's of Company owned wind generation was being sent from east of
Bridger to west of Bridger?
e.How many MWh's of non-Company owned wind generation was being sent from east of
Bridger to west of Bridger
4.For each hour from January 1,2012 through the present,please answer the followingwith
respect to when Dave Johnston had its output reduced because of excess capacity on the
system:
a.How many MWh's were reduced because of excess generation anywhere on the system?
b.How many MWh's were reduced because of excess wind generation east of Bridger?
c.What was the Four Corners price of market power?
5.Is the retirement of Dave Johnston in 2027 in any way contingent upon the completion of the
transmission project addressed in this case?
6.On page 6 of Mr.Teply's Direct Testimony it states that when QF's are considered in
conjunction with the 860 MW of wind considered in this case,there will be 1,180 MW of
new wind that will be supported by this Application.According to Ms.Cranes testimony the
new transmission project will increase East to West capacity by 750 MW.Please explain the
disposition of the difference between l,l80 MW ofnew wind and the increase transmission
of 750 MW.
7.On pages 14 and 15 of Mr.Vail's testimony it indicates that because to the Transmission
Project that there could be a resulting interconnection of 1,270 MW of additionalwind
facilities.It goes on to state that when southeastern Wyoming wind is operating near full
output,other resources in the area can be "re-dispatched".Please answer the following:
a.What is meant by "re-dispatched"?
b.What "resources"would be "re-dispatched"?
c.With respect to the 1,270 MW of wind,what would be considered "near full output"?
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS -Page 2
d.With the wind facilities operating "near full output",what would be the amount (MW's)
of "re-dispatched"resources?
8.Regarding page 17 of Mr.Vail's Direct Testimony,what is meant by "Under certain
operation conditions"?
9.On page 23 of Mr.Vail's Direct Testimony it states:"Generally,the addition of a new
transmission path in parallel with existing lines,like the Transmission Projects,will reduce
the energy and capacity losses by reducing the impedance of the transmission system."What
is expected to happen to the impedance (and resulting energy and capacity losses)west of
Jim Bridger if 750 additional MW's are added from east of Jim Bridger7
10.On page 8 of Mr.Link's Direct Testimony it is stated that assumed wind capacity factor for
the new wind projects was 41.2 percent.For each of the last five years,what has been the
wind capacity factor from each of the Company's existing wind farms in Wyoming that are
going to be re-powered?
11.Please explain the differences between Exhibit 24 and Exhibit 25 for followingdata for the
year 2021 under the Low Natural Gas,Zero CO2 Price Policy Scenario:
a.The SO Model Cost of the Projects of $103 million on Exhibit 24 and the Net Project
Cost of $146 million on Exhibit 25.
b.The SO Model NPC of negative $48 million on Exhibit 24 and the NCP of negative $54
million on Exhibit 25.
c.The SO Model Net (Benefit)/Cost of $20 million on Exhibit 24 and the Net
(Benefit)/Cost of $55 million on Exhibit 25.
DATED this ay of September,2017.
E WK
æd &LSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS Page 3
CERTIFICATE OF SERVICE
I HEREBY CERTlFIY that on this day of September,2017,I served a true,correct
and complete copy of Idaho Irrigation Pumpers Association,Inc.First Set of Data Requests to
each of the following,via U.S.Mail or private courier,email or hand delivery,as indicated
below:
Diane M.Hanian,Secretary U.S.Mail
Idaho Public Utilities Commission Hand Delivered
P.O.Box 83720 Overnight Mail
472 W.Washington Street Telecopy (Fax)
Boise,ID 83720-0074 Electronic Mail (Email)
[e-mail]
Data Request Response Center -PacifiCorp U.S.Mail
Email:[e-mail] Hand Delivered
O Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Ted Weston U.S.Mail
Idaho Regulatory Affairs Manager Hand Delivered
Rocky Mountain Power OvernightMail
1407 West North Temple,Suite 330 Telecopy (Fax)
Salt Lake City,Utah 84116 Electronic Mail (Email)
Email:[e-mail]
Yvonne R.Hogle U.S.Mail
Assistant General Counsel Hand Delivered
Rocky Mountain Power Overnight Mail
1407 West North Temple,Suite 320 Telecopy (Fax)
Salt Lake City,Utah 84116 Electronic Mail (Email)
Email:[e-mail]
Brandon Karpen U.S.Mail
Deputy Attorney General Hand Delivered
Idaho Public Utilities Commission Overnight Mail
P.O.Box 83720 Telecopy (Fax)
472 W.Washington Street (83702)Electronic Mail (Email)
Boise,ID 83720-0074
[e-mail]
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS -Page 4
Ronald L.Williams U.S.Mail
Williams Bradbury,P.C.Hand Delivered
P.O.Box 388 Ovemight Mail
Boise,ID 83701 Telecopy (Fax)
Email:ron williamsbradbury.com Electronic Mail (Email)
Jim Duke U.S.Mail
Idahoan Foods Hand Delivered
Email:[e-mail] Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Kyle Williams U.S.Mail
BYU Idaho Hand Delivered
Email:williamskWbyui.edu Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Val Steiner U.S.Mail
Nu-West Industries,Inc.Hand Delivered
Email:[e-mail] Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Randall C.Budge U.S.Mail
Racine,Olson,Nye &Budge,Chartered Hand Delivered
P.O.Box 1391;201 E.Center Overnight Mail
Pocatello,ID 83204-1391 Telecopy (Fax)
Email:[e-mail] Electronic Mail (Email)
Brubaker &Associates U.S.Mail
16690 Swingley Ridge Rd.,#140 Hand Delivered
Chesterfield,MO 63017 Overnight Mail
Email:[e-mail] Telecopy (Fax)
[e-mail] Electronic Mail (Email)
RIC OWEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQEUSTS-Page 5