20170912Wyoming_OCA Set 2 (1-6).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
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DOCKET NO. 20000-520-EA-17
RECORD NO. 14781
OFFICE OF CONSUMER ADVOCATE’S SECOND SET OF DATA REQUESTS
Submitted:September 1, 2017
COMES NOW the Office of Consumer Advocate and hereby serves its second set of data requests regarding the above docketed applicationof Rocky Mountain Power, to be answered pursuant to Rules 33, 34, and 36 of the Wyoming Rules of Civil Procedure. The responses are to be served upon and produced in care of Christopher Leger, Counsel;Wyoming Office of Consumer Advocate; 2515 Warren Avenue, Suite 304; Cheyenne, WY 82002.DATA REQUESTS
General
The State of Wyoming currently levies a production tax on wind generation produced in Wyoming. With regard to that production tax, please answer the following:
What is the amount of tax paid to the State of Wyoming by PacifiCorp, Rocky Mountain Power, or any of its other subsidiaries?
What is the increased amount of wind generation production tax, at the current tax rate, estimated to accrue as a result of the new and repowered wind currently being proposed by the Company, if it is approved? Please explain in detail how this estimate was derived?
How likely is an increase in the wind production tax rate?
If the wind production tax is increased by the Wyoming Legislature in the future, at what level of wind production tax are the benefits of the federal Production Tax Credit (PTC) for the new and repowered wind entirely offset by the increased wind production tax?
Are there any other states in the U.S. where a wind production tax has been proposed or implemented?
Please confirm that the most recent NTTG 2016-2017 Draft Regional Transmission Plan referred to in the response to OCA Data Request 1.010 has not been finalized. Please also confirm that a number of the comments submitted by interested stakeholders regarding the NTTG 2016-2017 Draft Regional Transmission Plan question the need for the additional Wyoming wind proposed by the Company and the need for the associated transmission system upgrades.
What will be average firm peak capacity rating of the new wind resources in terms of reserve carrying capability?
Please explain in detail how the additional wind generation proposed in this proceeding will be integrated into PacifiCorp’s system. For example, does the addition of the new wind in Wyoming create a need for additional fast ramping or peaking resources and if so, what resources will the Company rely on for those services?
Recently the Company has touted its ability to flexibly manage (ramp) the generation from its Wyoming coal generation facilities to take advantage of attractively priced excess renewable generation available in the Energy Imbalance Market (EIM). Please explain in detail how the injection of at least 1,100 MWs of new wind in eastern Wyoming will impact the Company’s participation in the EIM, including, but not limited to its ability to take advantage of low cost excess renewable generation available in the market.
DATED:Friday, September 01, 2017OFFICE OF CONSUMER ADVOCATE
_______________________________
Christopher Leger, Counsel
Wyoming Bar # 6-3963
Wyoming Office of Consumer Advocate
2515 Warren Avenue, Suite 304
Cheyenne, WY 82002
[phone]
[e-mail]
CERTIFICATE OF SERVICEI hereby certify that on September 1, 2017, I served the foregoing Second Set of Data Requests by delivering copies thereof to the individuals/entities below, by the method(s) indicated:
Yvonne Hogel
Senior Counsel
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT84111
[e-mail]
e-mail
Stacy Splittstoesser
Wyoming Regulatory Affairs Manager
Rocky Mountain Power
315 W. 27th St.
Cheyenne, Wyoming 82001
[e-mail]
e-mail and U.S. Mail
Paul Hickey
Hickey & Evans, LLP
PO Box 467
Cheyenne, WY 82003-0467
[e-mail]
email
Katherine McDowell
McDowell Rackner & Gibson PC
419 SW 11th Ave, Suite 400
Portland, OR 97205
[e-mail]
email
Data Request Response CenterPacifiCorp
825 NE Multnomah, Suite 800
Portland, Oregon97232
[e-mail]
e-mail
Crystal J. McDonough
McDonough Law, LLC
1635 Foxtrail Dr. #327
Loveland, CO 80538
[e-mail]
email
Robert M. Pomeroy, Jr.
Thorvald A. Nelson
Abigail C. Briggerman
Nikolas S. Stoffel
Holland & Hart LLP
6380 South Fiddler's Green Circle, Suite 500
Greenwood Village, CO 80111
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
e-mail
OFFICE OF CONSUMER ADVOCATE
_______________________________
Christopher Leger, Counsel
Wyoming Bar # 6-3963
Wyoming Office of Consumer Advocate
2515 Warren Avenue, Suite 304
Cheyenne, WY 82002
[phone]
[e-mail]