20170918PAC to Staff 13 16 24 34-47.pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
September 18,2017
Diane Hanian
Idaho Public Utilities Commission
472 W.Washington
Boise,ID 83702-5918
RE:ID PAC-E-17-07
IPUC 16 Set Data Request (1-47)
Please find enclosed Rocky Mountain Power's Responses to IPUC 1st Set Data Requests 1.1-
1.47 Data Requests IPUC 13,16,24,29 and 34-47.Provided on the enclosed CD are
Confidential Attachments IPUC 14,37,39,40-1 and 41-1.Confidential information is provided
subject to the terms and conditions of the protective agreement in this proceeding.
If you have any questions,please feel free to call me at [phone].
Sincerely,
J.Ted Weston
Manager,Regulation
Enclosures
C.c.:Diane Hanian/IPUC [e-mail] (C)
Ronald L.Williams/PIIC [e-mail]
Jim Duke/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail](W)
Val Steiner/PIIC [e-mail] (W)
Brian C.Collins/Brubaker &Associates bmm (C)(W)
James R.Smith/Monsanto s (C)(W)
Maurice Brubaker/Monsanto mbrubaker consultbai.com (C)(W)
Katie Iverson/Monsanto (C)
Eric Olsen/IIPA [e-mail] (C)
AnthonyYankel/IIPA [e-mail] (C)
Randall C.Budge/Monsanto [e-mail](C)
Thomas J.Budge/Monsantogb@racinelaw.n_et (C)(W)
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 1st Set Data Request 13
IPUC Data Request 13
In order for customers to realize the full net benefits of the project as proposed by
the Company,the Company will need to execute its plan on schedule and under
proposed cost estimates.Below are three potential conditions that would put
ratepayer net benefits at risk.For each circumstance below,please describe how
the Company would ensure customers are compensated for lost benefits or
increased costs that are the Company's responsibility.
(a)Reduction in PTC Benefits related to non-attainment of IRS Safe Harbor
requirements (not meeting requirements necessary for 100%of PTC);
(b)Reduction in PTC,NPC,and wholesale wheeling revenue benefits related to
late schedule completion;
(c)Cost overruns due to construction,capital infrastructure cost,cost to establish
right-of-way,permitting,etc.
Response to IPUC Data Request 13
The Company's approach to the Combined Projects is to mitigate risk and ensure
that appropriate off-ramps exist in the project review,approval,and
implementation processes before significant capital outlays or commitments are
made in case the necessary approvals are not received,project economic benefits
erode,or the associated benefits are placed at risk.With timely regulatory
reviews and approvals,and successful transmission rights-of-wayacquisition,the
Company fully expects it will successfully meet the requirements necessary to
ensure eligibilityfor 100%of the production tax credits (PTCs)and receive net
power costs (NPC)and wholesale wheeling revenue benefits available throughthe
Combined Projects.While some risks may materialize during implementation of
the Combined Projects,the Company also anticipates other benefits may become
available (for example,savings on project costs),resulting in the forecasted net
benefits being achieved.It is the net benefit projections in aggregate that support
the prudence of the Combined Projects.The Company's projections of costs and
benefits for the Combined Projects are reasonable and achievable and,as stated
on page four in the Direct Testimony of Company witness,Rick T.Link,"will
produce customer benefits that significantlyoutweigh costs."The three
categories identified in the request are components of the overall net benefit
calculation.To the extent that a material risk is realized during the
implementation of the projects that reduces the net benefits of the Combined
Projects,the Company has proposed a regulatory adjustment mechanism that
would capture that difference.The Company's approach to management of the
material risks would be subject to prudence review because the Idaho Public
Utilities Commission (IPUC)will ultimatelyhave the opportunity to review the
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 13
construction costs and implementation of the Combined Projects and make a
determination on the prudence of the actual costs incurred.
Recordholder:Chad Teply
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16*Set Data Request 16
IPUC Data Request 16
Please list and quantifythe potential for schedule delay related to:
(a)Jurisdictional approval
(b)Permitting
(c)Procurement
(d)Construction
Response to IPUC Data Request 16
The Company structures and manages its major construction projects on a firm,
date-certain,fixed-price,turnkeycontract basis.The Company has managed
multiple major projects that required the work be completed by a date certain or
where the work was tied into an existing system within a short planned-outage
window or closely coordinatedwith delivery of transmission system network
upgrades.Examples of these projects include:
a.Dunlap wind farm
b.High Plains wind farm
c.McFadden Ridge I wind farm
d.Populus-to-Terminal 345kV transmission line
e.Sigurd-to-Red-Butte transmission line
f.Mona-to-Oquirrhtransmission line
g.Lake Side 2 Combined Cycle natural gas facility
h.Jim Bridger Units 3 &4 Selective Catalytic Reduction systems
i.Naughton 1 &2 Flue Gas Desulfurization Systems
j.Hunter 1 &2 and Huntington1 &2 Pulse Jet Fabric Filters
k.Wyodak Pulse Jet Fabric Filter
1.Dave Johnston Units 3 &4 Pulse Jet Fabric Filters &Flue Gas
Desulfurization Systems
(a)Near-term critical path milestones associated with jurisdictional approvals
include securing the Certificate of Public Convenience and Necessity (CPCN)
from the Wyoming Public Service Commission (WPSC)and the permit for
the transmission Projects from the Wyoming Industrial Siting Council (ISC).
The Company's critical-path schedule for the Transmission Projects included
in the initial filing assumes a March 30,2018,receipt date for the CPCN and a
December 31,2018,receipt date for the ISC permit.As a result of subsequent
scheduling conferences in the various states and hearingtimelines,the
company anticipates that it will have commission decisions on or about April
6,2018.Timely receipt of the CPCN is intended to allow rights-of-way
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 16
acquisition for the 500-kV transmission infrastructure to be completed by
March 31,2019.Compression of any of these critical-path activities could
place the planned 500-kV transmission infrastructure construction start of
April 1,2019,at risk of delay;however,the Company has not quantified this
risk and is mitigating risk and ensuring that appropriateoff-ramps exist in the
project review,approval,and implementation processes before significant
capital outlays or commitments are made.
(b)See response to subpart (a)above.In addition,the Transmission Projects'
current critical-path schedule assumes completion of the federal Record of
Decision (ROD)requirements for cultural studies and mitigation plans by
December 31,2018,again with potential day-for-day delay consequences,
although not currentlyexpected to be critical-path activities.The Company is
engaged with all agencies in finalizing all of the Notice to Proceed
requirements in the Energy Gateway West ROD and has an agreed schedule
for completing all of the items with the agencies.Field work is on schedule in
2017 and for all permits to be acquired to meet the schedule submitted with
the CPCN application.The most critical item is Section 106 National Historic
Properties Act compliance,sufficient field work for the Cultural Report is on
schedule to be completed in 2017.For the 230 kilovolt (kV)network
upgrades a strategy and schedule has been agreed to with the agency and field
work already began.
(c)Due to timing of the Company's efforts to support its approval filings,
stakeholder reviews,and request for proposals process,procurement of major
equipment and negotiation of major engineer-procure-constructcontracts are
not expected to become critical-path activities.These procurement efforts are
already underway.
(d)Balance-of-Plant construction contractors and equipment suppliers will be
held to key construction and delivery milestones and development of
compressed schedule mitigation plans,if required.Construction contract
completion dates will be established and backstopped with guarantees.As
with any critical-path workstream,unrecoverable delays would be expected to
place the respective project in-service date schedule at risk for a day-for-day
delay.
Recordholder:Chad Teply,Todd Jensen,Stuart Smith
Sponsor:Chad Teply and Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16 Set Data Request 24
IPUC Data Request 24
Has the Company considered and quantified other locations for siting wind that would
not require building additional transmission lines?If so,please provide the analysis and
the results.If not,why not?
Response to IPUC Data Request 24
To clarify,the Aeolus-to-Bridger/Anticlinetransmission line is not being built because of the
new wind projects.Rather,the transmission line is necessary today to relieve existing
transmission congestion.Currently,no new projects can interconnect in Eastern Wyoming.In
this case,the economic analysis identifies a time-limited opportunity to construct the much-
needed Aeolus-to-Bridger/Anticlinetransmission project in a manner that delivers all-in
customer benefits when combined with the new wind projects.The new line enables
interconnection of up to approximately 1,270 megawatts (MW)of new wind resources in the
area.The transmission and wind projects are mutuallydependent upon one another-the wind
projects rely on the transmission project for interconnection,and the transmission project is
supported by the economic benefits associated with the new wind resources.While there may be
opportunities to acquire new renewable resources that can be delivered into other parts of
PacifiCorp's transmission system,the 2017 Integrated Resource Plan (IRP)did not identify these
opportunities as part of PacifiCorp's least-cost,least-risk plan.All of the resource portfolios
produced during the initial stages of the portfolio developmentphase of the 2017 IRP contained
new Wyoming wind resources in 2021,which for modeling purposes,was used as a proxy on-
line date for production tax credit (PTC)eligible wind resources in commercial operation by the
end of 2020.
Please refer to the Company's responses to IPUC Data Request 25 and IPUC Data
Request 45.
Recordholder:Chad Teply
Sponsor:Chad Teply and Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 29
IPUC Data Request 29
Please explain how the Company determined the amount of wheeling revenue
benefit.Please provide work papers showing the calculated amount with all
formulae intact.
Response to IPUC Data Request 29
PacifiCorp assumes that 12 percent of the new transmission cost will be recovered
from network transmission customers that use PacifiCorp's network transmission
system to serve non-PacifiCorp retail load.The process around determining the
12-percent estimate was based on historical analysis of the relative amount of
revenue received from third parties compared to the total transmission revenue
requirement for a given year.Transmission revenues are allocated to states based
on overall allocation formula rather than assignment of transmission assets and
respective revenues to specific states due to the nature of transmission service and
the calculation of network service revenues,well as other drivers.Additional
transmission assets placed in service,includingthe 230 kilovolt (kV)segments
will increase the transmission revenue requirement,which will result in increases
in third-partyrevenues collected.These revenues will be credited back to
PacifiCorp's retail customers.
Please refer to the confidential work papers that accompanied the Direct
Testimony of Company witness,Rick T.Link,specifically the confidential file
located in the "Exhibits Figures Tables"folder "Gateway Results Direct
Testimony".In the worksheet "Price-Policy Annual PaR"revenue credits are
shown in rows 89,189,etc.The transmission revenue credit for the 230 kV
transmission segments are applied in these rows by multiplyingthe gross revenue
requirement by 12 percent.The gross revenue requirement calculations can be
traced throughthe source files referenced in the formula.The calculation of the
gross revenue requirement and associated 12-percent transmission revenue credit
for the Aeolus-to-Bridger/Anticlinesegment can be traced through the source files
referenced in the formula.
Recordholder:Rick Link
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16*Set Data Request 34
IPUC Data Request 34
Please provide the estimated NPVRR(d)for the project if there is a 1 year,2 year,
or 3 year slip to the project's completion.
Response to IPUC Data Request 34
The Company objects to this request as requiring developmentof a special study
or information not maintained in the ordinary course of business.Without waiving
this objection,the Company responds as follows:
PacifiCorp has not performed the requested analysis.
Recordholder:Randy Baker
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 35
IPUC Data Request 35
What is the breakeven point for continuing with the combined projects in relation
to the Production Tax Credits?At what level of Production Tax Credits do the
costs of the projects become untenable?
Response to IPUC Data Request 35
The Company objects to this request as vague,ambiguous,and requiring
developmentof a special study or information not maintained in the ordinary
course of business.Without waiving these objections,the Company responds as
follows:
PacifiCorp has not developedthe requested breakevenanalysis;however,the
Idaho Public Utilities Commission (IPUC)can estimate the level of production
tax credits (PTCs)that would cause the Combined Projects to achieve break-even
economics using data contained in the Direct Testimony of Company witness,
Rick T.Link,specifically Link Exhibit No.25.This exhibit includes a line item
"New Wind PTCs"for each price-policy scenario.The present value of revenue
requirements differential (PVRR(d))for this line item can be multiplied by a
percentage that offsets the PVRR(d)for the "Net (Benefit)/Cost"line item for any
given price-policy scenario.
For instance,in the medium natural gas and medium carbon dioxide (CO2)priCC-
policy scenario,the PVRR(d)for "New Wind PTCs"is $795 million,which
reflects the full value of PTCs.The PVRR(d)for the "Net (Benefit)/Cost"line
item is $137 million.If the PVRR(d)for the "New Wind PTCs"line item is
multipliedby approximately 83 percent,the "New Wind PTCs"line item would
drop by approximately $137 million,thereby causing the PVRR(d)for the "Net
(Benefit)/Cost"line item to be zero (i.e.,break-eveneconomics).
Recordholder:Dan Swan
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 13'Set Data Request 36
IPUC Data Request 36
When did the Company first begin analyzing the Production Tax Credit after it
was extended in the PATH Act of 2015?Specifically when did the Company
begin pursuing eligibilityfor PTC for these projects?
Response to IPUC Data Request 36
The Company began to review its options in May 2016,followingthe May 5,
2016 release of the Internal Revenue Service (IRS)guidance clarifying the
requirements related specifically to production-tax-credit (PTC)eligibilityand
repowering.The guidance also provided for a four-year safe-harbor to satisfy the
continuityrequirement of continuous physical construction.The Company began
to consider various options for new wind resources in July2016,applying a five-
percent safe-harbor test to qualify for PTCs.A procurement process to secure
safe-harbor wind-turbine equipment for potential new wind projects was initiated
in September 2016.The Company's ultimatelyselected safe-harbor wind turbine
equipment was procured and title transferred to the Company for new wind
projects by year-end 2016.The IRS guidance (Notice 2016-31)can be accessed
using the followingwebsite link:https://www.irs.gov/irb/2016-23 IRB/ar07.html
Recordholder:Chad Teply
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 1st Set Data Request 37
IPUC Data Request 37
Did the Company investigate claiming the Investment Tax Credit (ITC)in lieu of
the PTC?Please provide any analysis the Company did as it pertains to the ITC.
Response to IPUC Data Request 37
Generally,at the expected capacity factors of the new wind farms,the present
value of the 10-year PTC stream is greater than the 30%ITC.In addition,
normalization requirements associated with the ITC increases the present-value
revenue requirement relative to a PTC alternative.No specific analysis by wind
project was conducted.Please refer to Confidential Attachment IPUC 37.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Jonathan Hale
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 38
IPUC Data Request 38
IRS Notice 2017-4 states in Section 3,"If a facility does not satisfy the Continuity
Safe Harbor,whether the facility satisfies the Continuous Construction or
Continuous Efforts Tests is determined by the relevant facts and Circumstances."
If it is determined that the Five Percent Safe Harbor is not met,what information
will the Company rely upon which will satisfy the Continuous Construction or
Continuous Efforts Tests?Is the Company compiling and retaining this
information at this time?
Response to IPUC Data Request 38
The five percent safe harbor relates to the start of physical construction.The
continuityof physical construction still has to be met regardless of whether the
taxpayer utilizes the five percent safe harbor or some other evidence of the start of
physical construction.If the five percent safe harbor is not met for any wind
project ultimatelyevaluated for the final shortlist in the 2017 renewable request
for proposals (2017R RFP)process,then the Company will need to complete its
due diligence to determine whether the claim that physical construction began
prior to January 1,2017,to secure the 100 percent production tax credits (PTC),
and the Continuous Construction or Continuous Efforts Tests can be supported.
That due diligence will not be able to be completed until bids are received in the
2017R RFP process.The Company's planned benchmark proposals have all been
pursued based upon their ability to satisfy the safe harbor.Please refer to the
Company's response to IPUC Data Request 10 regardingthe continuitysafe
harbor requirements of Internal Revenue Service (IRS)Notice 2016-31 and IRS
Notice 2017-4 Section 3.
Recordholder:Chad Teply and Jonathan Hale
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 136 Set Data Request 39
IPUC Data Request 39
Please provide System Optimizer and PaR files containing assumptions,inputs,
outputs,and summary information for all scenarios and sensitivities used in
PacifiCorp's economic analysis.For each scenario and sensitivity,provide a
summary of the parameters changed for each run.
Response to IPUC Data Request 39
Please refer to the confidential work papers supporting the Direct Testimony of
Company witness,Rick T.Link,specifically:
System Optimizer model (SO model)inputs and outputs:
(1)Folder "SO Model Inputs-Outputs".
(2)Folder "Other Summary Reports"-provides information on the Aeolus-
to-Bridger/Anticlinetransmission segment,Transmission Cost,Wind
Project Operating Costs,and Wind Summary Data.
(3)Folder "Transmission Projects"-provides information on the Aeolus-to-
Bridger/Anticlinetransmission segment and network transmission costs
for new wind.
(4)Folder "Wind Projects"-provides information on new wind under the
30-year life and 40-year life sensitivities.
SO model summary information:
(1)Folder "Exhibits Figures Tables",the file "Gateway Results Direct
Testimony"-provides the study results summary,tab "Testimony
Tables".
(2)Folder "SO Model Summary Reports"-provides the SO model portfolio
summaries.
Planning and Risk (PaR)model inputs and outputs:
(1)Folder "PaR Inputs-Outputs".
(2)Folder "Other Summary Reports"-provides information on the Aeolus-
to-Bridger/Anticlinetransmission segment,Transmission Cost,Wind
Project Operating Costs,and Wind Summary Data.
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16*Set Data Request 39
(3)Folder "Transmission Projects"-provides information on the Aeolus-to-
Bridger/Anticlinetransmission segment and network transmission costs
for new wind.
(4)Folder "Wind Projects"-provides information on new wind under
30-year life and 40-year life sensitivities.
PaR model summary information:
(1)Folder "Exhibits Figures Tables",the file "Gateway Results Direct
Testimony"-provides the PaR model study results summary,the tab
"Testimony Tables".
(2)Folder "PaR Summary Reports"-provides the PaR model stochastic
summary reports.
Please refer to Confidential Attachment IPUC 39,which provides the parameters
changed for each run.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Dan Swan
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 40
IPUC Data Request 40
Please provide a copy of the executed PPAs/interconnection agreements for the
320 MW of QF Projects mentioned in Mr.Link's direct testimony on page 21.
Response to IPUC Data Request 40
Please refer to Confidential Attachment IPUC 40-1,which provides copies of the
executed qualifying-facility (QF)power-purchase agreements (PPAs)that equate
to the 320 megawatts (MW)referenced as "QF Projects"in the Direct Testimony
of Company witness,Rick T.Link.The "QF Projects"are Boswell Springs I,
LLC (80 MW),Boswell Springs II,LLC (80 MW),Boswell Springs III,LLC (80
MW),and Boswell Springs IV,LLC (80 MW)-collectively referenced herein as
"Boswell Springs I-IV".
These QF PPAs are subject to acceptance by the Wyoming Public Service
Commission (WPSC),Docket 20000-515-EK-17.Althoughexecuted,the
Company considers these QF PPAs preliminaryuntil the WPSC accepts them for
filing.
Please refer to Attachment IPUC 40-2,which provides the Large Generator
Interconnection Agreements (LGIA)associated with Boswell Springs I-IV.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Bruce Griswold and Kristopher Bremer
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 41
IPUC Data Request 41
Please provide and explain the analysis including work papers that was performed
to conclude the 36.5 MW reduction value is a reasonable assumption to show
reliability benefits (Link,Di.25).
Response to IPUC Data Request 41
Please refer to Confidential Attachment IPUC 41-1 and Attachment IPUC 41-2,
which provide the historical outages that determined that the 146-megawatt
(MW),24-hour outage every four days was equivalent to the outages that
historicallyoccurred.The 36.5 MW outage per day is calculated by 146 MW
divided by four days.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Robyn Kara /Dan Swan
Sponsor:Rick Link and Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 42
IPUC Data Request 42
Please provide and explain the analysis including work papers that was performed
to conclude the 11.6 aMW value is a reasonable assumption to show line-loss
benefits (Link,Di.25).
Response to IPUC Data Request 42
PacifiCorp modeled line losses by decreasing loads by 11.6 average megawatts
(aMW)each hour of the year to ensure that amount of line losses would be
captured.Please refer to Attachment IPUC 42,which provides a spreadsheet with
the loss-savings calculations.The followingprovides a description of the
methodology and considerations used.
Overview of Line-Loss Calculation
The addition of a transmission line in parallel with an existing line(s)or path will
reduce the impedance of the path,resulting in overall reduced energy line losses
(megawatt-hours).The impedance of parallel transmission lines is determinedby
calculating an equivalent resistance (R_equivalent)for the lines.Losses for any
transmission line are determined according to the formula I2R (where "I"is the
current flow and "R"is line resistance).Line losses before and after the addition
of a new line are then compared,with the difference being the line savings
attributed to the new line.
EquivalentResistance of Parallel Lines
Using the Siemens PSS/E power flow program and a range of power flows for the
Wyoming area of study,line losses on various line segments were observed and
recorded (Attachment 1,Tab 1).Using this information,an equivalent resistance
(R equivalent)was calculated (see equations below)for the study area
(Attachment 1,Tab 2).The calculation was repeated with the new Aeolus-to-
Bridger/Anticline(D.2 Project)transmission segment.Additional information
related to calculating equivalent resistance is provided for reference below.This
analysis used hourly historical (2015 and 2016)power flows for the three
Wyoming 230-kilovolt (kV)lines that will be in parallel with the new D.2 Project.
The 230 kV lines and measurement points (*)used are as follows (Attachment 1,
Tab 3,column A through D):
(1)Standpipe*-Platte 230 kV.
(2)Spence*-Mustang 230 kV.
(3)Casper*-Riverton 230 kV.
Line-Loss Calculation
Utilizingthe formula indicated in equation"D"below (Line Losses =MW 2 X
R_equivalent),line losses for the existing 230 kV transmission system between
eastern Wyoming and Bridger were calculated (Attachment 1,Tab 3,column E,G
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 13*Set Data Request 42
and I).Line losses were then recalculated using the same power flow with the
new D.2 Project in-service (Attachment 1,Tab 3,column F,H,and J).The
difference between the two calculations for each segment are the line-loss savings
directlyattributable to the new D.2 Project transmission line,which total
approximately 102 gigawatt-hours (GWh)each year,or 11.6 aMW each hour of
the year based on historical power-flowlevels (Attachment 1,Tab 4).
Additional R equivalentInformation
To calculate current (I),megavolt amperes (MVA)x 1,000 divided by (square
root (3)x kV/1000)is used.
(A)
I =MVA x 1000 ÷ (Ñ3 x kV)
Since the predominant flow on PacifiCorp-s transmission lines is real power,
megawatts (MW),rather than reactive power,megavars (MVAr),the difference
when calculating current is very small between megawatts and MVA.Thus MW
flow can be substituted for MVA in the line-loss formula:Losses =I2R:
With substitution the equationbecomes:
(B)
Losses=(MW x1000)2
(§3 x kV)
The equation can then be refined to:
(C)
2 ¯
2MWx1x1000 xR
3 kV
Since the latter portion of the equation is a fixed constant,it can be simplified into
a single term of "R_equivalent"or Req.Thus,line losses can be accurately
calculated as:
(D)
Lines Losses =MW 2 x Req
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 1st Set Data Request 42
Recordholder:Dan Swan and Robyn Kara
Sponsor:Rick Link and Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC lst Set Data Request 43
IPUC Data Request 43
Please provide additional detail on the 300 MW value chosen to model the EIM
benefits (Link,Di 26).For example,but not limited to in your explanation:
(a)Is this capacity currentlyalways available to transfer between the east and
west sides of PacifiCorp's system?
(b)Does this 300 MW value require the new transmission lines planned in the
Energy Gateway Transmission ExpansionPlan?
(c)Will the capacity be available during the most likely time when 300 MW of
power is needed?
Response to IPUC Data Request 43
(a)The expected additional east-to-west transmission capacity in the energy
imbalance market (EIM),cited in the Direct Testimony of Company witness,
Rick T.Link,is primarily related to the entrance of Idaho Power Company in
April 2018.
(b)No.As stated in Mr.Link's Direct Testimony,the ability to more efficiently
use intra-hour transmission is not driven by the combined projects.
(c)PacifiCorp is unable to speculate on the availabilityof transmission in the
EIM,however,the EIM is a least-cost economic dispatch model that will
dispatch thermal resources across the western footprintto take advantage of
low-cost renewable resources.
Recordholder:Kelcey Brown
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 1st Set Data Request 44
IPUC Data Request 44
Please explain and quantifythe transmission limitations created by the Dave
Johnston coal plan mentioned in Mr.Link's direct testimony on pages 29-30.
Response to IPUC Data Request 44
The Direct Testimony of Company witness,Rick T.Link did not state the
transmission limitations were created by the Dave Johnston plant,but that the
transmission congestion is from the energy output of all resources in eastern
Wyoming,includingthermal generation,wind projects,and qualifyingfacilities.
Recordholder:Dan Swan
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 45
IPUC Data Request 45
Staff is interested in the evaluation of alternativesthat take advantage of PTCs
without additional transmission investment.Please provide and explain all
alternatives that take advantage of PTCs without additional transmission that were
evaluated.For example,but not limited to in your explanation:
(a)How many different alternatives were evaluated?
(b)Did any of the evaluatedalternatives provide a benefit in PVRR(d)?
(c)What are the net benefits and negative implications for implementing the
alternative?For example,taking advantage of PTCs 1-2 years sooner could
show benefits without installinga new transmission line or retiring a coal
plant early would negatively impact system voltage control.
(d)Has the company considered and quantified shutting down the units of Dave
Johnston and/or Wyodak by 2020 to free up transmission capacity to install
some or all incremental wind to take advantage of PTCs?If so,please
provide the results of the analysis.If not,why not?Please explain.
(e)What is the PVRR(d)if units of Dave Johnston and/or Wyodak are shut down
and incremental wind is installed/interconnectedup to the freed up capacity
amount?If this type of analysis has been performed,please explain the
assumptions used and provide the summary files.
Response to IPUC Data Request 45
(a)Please refer to the Company's responses to IPUC Data Requests 24 and 25.
Production-tax-credit (PTC)eligible resources in the simulations performed
without the new wind and transmission projects for each price-policy scenario
are summarized below:
Gas /CO2 2021 Wind 2022 Wind 2023 Wind 2024 Wind Benefit
Assumption MW MW MW MW Relative to
(100%(80%(60%(40%Company
PTC)PTC)PTC)PTC)Proposal?
High/High 760 150 800 0 No
High/Med 760 150 800 0 No
High/Zero 910 0 800 0 No
Med/High 300 150 0 0 No
Med/Med 300 3 0 0 No
Med/Zero 300 0 0 0 No
Low/High 300 0 0 0 No
Low/Med 300 0 0 0 Yes
Low/Zero 300 0 0 0 Yes
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 1st Set Data Request 45
(b)Please refer to the Company's response to subpart (a)above.
(c)The magnitude of the incremental cost or benefit from the alternatives shown
in response to subpart (a)above are located in Table 2 and Table 3 in the
Direct Testimony of Company witness,Rick T.Link.In all but the low natural
gas price scenarios paired with either medium or zero carbon dioxide (CO2)
price assumptions,portfolios with the wind resources shown in response to
subpart (a)above are higher cost than portfolios with the Company's proposed
new wind and transmission project.
(d)Today,due primarily to voltage issues,no new resources can interconnect to
this part of the transmission system without constructing elements of the
Energy Gateway transmission project (beyond those facilities that have
already executed interconnection agreements stating otherwise).If Dave
Johnston and/or Wyodak were to retire early,voltage issues would worsen,
and no new resources would be able to interconnect to this part of the
transmission system.
(e)The Company has not performed the requested analysis.The Company has
completed steady-state transmission studies that identify major system-
reinforcement improvements to the 230 kilovolt (kV)transmission system that
would be necessary to meet thermal and voltage criteria sufficient to operate
the transmission system reliablyassuming Dave Johnston retires early and
new Wyoming wind resources are added to the system.High-levelestimates
indicate the cost of these reinforcement projects would exceed the cost of the
proposed 500 kV Aeolus-to-Bridger/Anticlineproject,would result in a lower
transfer capability (approximately 562 megawatts (MW)versus the 750 MW
expected from the 500 kV Aeolus-to-Bridger/Anticlineproject),and
accelerate the need to replace capacity from the 762 MW Dave Johnston Plant
by seven years (from 2028 to 2021).All of these variables related to an early
Dave Johnston retirement alternative would increase costs and reduce benefits
relative to the Company's proposed new wind and transmission projects.
Recordholder:Dan Swan
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 13'Set Data Request 46
IPUC Data Request 46
Based on the alternatives posed in Request No.46,indicate the year and the
amount of generationwhen incremental system capacity would be required.
Response to IPUC Data Request 46
The Company assumes that the reference in the request to "Request No.46"is
intended to reference IPUC Data Request 45.Based on this assumption,the
Company responds as follows:
Please refer to the Company's response to IPUC Data Request 45.The timing
and location of new resources on the system does not affect the current forecast
for new resource needs.PacifiCorp identifies its need for new capacity in the
2017 Integrated Resource Plan (IRP),which shows that,if firm market purchases
are maximized,new generationwould not be required until 2028.Without these
firm market purchases,PacifiCorp shows an immediate capacity need (i.e.,in
2017).Any new resource added before 2028 would primarily displace firm
market purchases and contribute to the deferral of longer-term resources required
to maintain a target 13-percent capacity planning reserve margin (PRM).
Recordholder:Dan Swan
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 18,2017
IPUC 16'Set Data Request 47
IPUC Data Request 47
Based on the alternatives posed in Request No.46,indicate the difference to net
power cost each year over the life of the projects.
Response to IPUC Data Request 47
The Company assumes that the reference in the request to "Request No.46"is
intended to reference IPUC Data Request 45.Based on the foregoing assumption,
the Company responds as follows:
Please refer to the Company's response to IPUC Data Request 45.
Recordholder:Dan Swan
Sponsor:Rick Link