20170912Utah_OCS 6 (1-9).docx

BEFORE THE PUBLIC SERVICE COMMISSION OF UTAHIn the Matter of the Application of Rocky:Docket No. 17-035-40Mountain Power for Approval of a :Office of Consumer ServicesSignificant Energy Resource Decision:Sixth Data Request toAnd Voluntary Request for Approval of:Rocky Mountain PowerResource Decision:August 25, 2017Please provide responses to:Béla VastagDonna RamasOffice of Consumer ServicesRamas Regulatory Consulting, LLC160 East 300 South 4654 Driftwood DriveSalt Lake City, Utah 84111Commerce Twp., MI 48382(801) 530-6374(248) [e-mail]@aol.comRefer to the Direct Testmony of Rick T. Link, page 5, lines 85 - 90, which states: “For every dollar assigned to the incremental RECs that will be generated by the Wind Projects, present-value benefitswould improve for all scenarios by an additional $34 million when calculated from the change in system revenue requirement through 2050. When calculated from the change in system revenue requirement over a 20-year period, each dollar assigned to the incremental RECs from the Wind Projects would increase PVRR(d) benefits by $26 million.” Please explain and show, in detail, how the $34 million was determined. Include all assumptions used in deriving the amount.Please identify the quantity of RECs considered in deriving the $34 million and identify the percentage of total incremental RECs generated that the quantity used in determining the $34 million entails (i.e., 50%, 75%, 100%, etc.).Please explain and show, in detail, how the $26 million was determined. Include all assumptions in deriving the amount.Please identify the quantity of RECs considered in deriving the $26 million and identify the percentage of total incremental RECs generated that the quantity used in determining the $26 million entails (i.e., 50%, 75%, 100%, etc.).Please identify through what year the Company’s calculations assume that there will be a market for the sale of RECs.Does the Company currently anticipate that there will continue to be a market for REC through 2036? Through 2050? If yes, to each of these, please explain why the Company feels there will continue to be a market for REC sales through those dates.Please provide the a copy of any internal forecasts or projections the Company has regarding the marketability of RECs going forward and the sales prices of RECs going forward. Additionally, if the Company has projected any future sales prices on a per REC basis, please provide such information for all future years the Company has projected and explain how the projected sales price per REC was determined.Please provide a detailed description of the Company’s current policy regarding the retention of RECs. Additionally, please explain if $34 million and $26 million referenced on page 5 of Mr. Link’s testimony factor in the impacts of the Company’s current REC retention policy. If no, explain why not. If yes, explain how the retention policy was factored into the calculations.Please provide in table format the following information for each year, 2012 through 2017 year to date:Total RECs PacifiCorp generated;Total RECs from contracts where PacifiCorp obtains ownership of the RECs;Total RECs generated and acquired (combination of (a) and (b));Amount of RECs retained for renewable portfolio standards compliance requirements;Amount of RECs sold;Amount of RECs remaining at year-end; andPercentage of RECs generated and acquired that were sold during the year.Please provide in table format the following information for each year, 2012 through 2017 year to date:Total RECs sold by vintage year;Total revenues from RECs sold during the year; andAverage revenue received per REC sold (i.e., subpart (b) divided by subpart (a)).Please provide for each year, 2012 through 2016, the number of RECs remaining available for sale at year end (i.e., excluding RECs retained for renewable portfolio standards compliance requirements) by vintage year of the RECs.Please provide the number of RECs currently available for sale as of the most recent date available (i.e., excluding RECs retained for renewable portfolio standards compliance requirements) by vintage year of the RECs.If the Company historically has not sold all of the RECs it has had available for sale, please explain, in detail, how the incremental RECs generated as a result of the Wind Projects will result in increased REC sales revenues.Does the Company project or anticipate that the additional wind resources that will come on-line in the United States between now and when the opportunity for projects to qualify for the production tax credits under the current phase-out of the credits expiring will put downward pressure on the amount paid for RECs and on the percentage of REC available for sale that are actually sold? If no, please explain why not. If yes, please describe the projected impacts based on the Company’s current estimates.