20170925PAC to IIPA 1-11.pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
September 25,2017
Eric L.Olsen
ECHO HAAWK &OLSEN,PLLC
505 Pershing Ave.,Ste.100
Pocatello,Idaho 83205
[e-mail](C)
RE:ID PAC-E-17-07
IIPA 16*Set Data Request (1-11)
Please find enclosed Rocky Mountain Power's Responses to IIPA Ist Set Data Requests IIPA 1-
I1.Also provided is Attachment IIPA 10.Provided on the enclosed Confidential CD is
Confidential Attachment IIPA 3 and Confidential Response IIPA 4.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.:Ronald L.Williams/PIIC ron@_williamsb_radbu_ry om (C)
Jim Duke/PIIC [e-mail] (C)(W)
Kyle Williams/PIIC [e-mail](C)(W)
Val Steiner/PIIC [e-mail] (C)(W)
James R.Smith/Monsanto [e-mail](C)(W)
Maurice Brubaker/Monsanto mbrubgb_ai..co_m (C)(W)
Katie Iverson/Monsanto o_m (C)
AnthonyYankel/IIPA t [e-mail] (C)
Randall C.Budge/Monsanto [e-mail](C)
Thomas J.Budge/Monsanto th@racinelawaet (C)(W)
Diane Hanian/IPUC [e-mail](C)
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 16*Set Data Request 1
IIPA Data Request 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 additional capacity of 750 MW from the east be able to be
absorbed by the rest of the system?
Response to IIPA Data Request 1
(a)Re-dispatch will be used to manage transmission capacity west of Bridger.
(b)Generating resources will be dispatched and re-dispatched in the most cost-
effective and efficient manner to meet load obligations and remain within
transmission capacity constraints.
Recordholder:Craig Quist /Robyn Kara
Sponsor:Rick Link and Rick
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 16*Set Data Request 2
IIPA Data Request 2
Ms.Crane's Direct Testimony at page 8 states that when completed that the
transmission projects "will allow interconnection of up to 1,270 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 addressed in this filing.
What portion of this additional 410 MW is viable,absent this transmission
project?
Response to IIPA Data Request 2
The Company's Application contemplates a total of 1,180 megawatts (MW)of
wind resources composed of the 860 MW of proposed Company benchmark wind
capacity (Wind Projects)and an additional 320 MW of qualifyingfacility (QF)
wind capacity (QF Projects)that currentlyhas executed contracts and favorable
transmission interconnection queue positions,as further described in the direct
testimony of Company witnesses,Rick T.Link and Chad A.Teply.The
reference in the direct testimony of Company witness,Cindy A.Crane to
1,270 MW of incremental wind resources that could be interconnected to the
Transmission Projects describes the total amount of wind resources that will be
pursued in the Company's 2017 renewable request for proposals (2017R RFP)
process to fully subscribe the Transmission Projects.Until bids are received and
assessed in the 2017R RFP,it is yet to be determined whether any wind resources
in addition to or in replacement of the Wind Projects and/or QF Projects will be
incorporated into the Company's supplemental filing in this docket in January
2018.
Recordholder:Chad Teply
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 16*Set Data Request 3
IIPA Data Request 3
For each hour from January 1,2012 through the present,please answer the
followingwith respect to when Bridger 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 generationeast of
Bridger?
(c)What was the Four Corners price of market power?
(d)How many MWh's of Company owned wind generationwas being sent from
east of Bridger to west of Bridger?
(e)How many MWh's of non-Company owned wind generationwas being sent
from east of Bridger to west of Bridger
Response to IIPA Data Request 3
The Company objects to this request on the basis that it does not have custody,
possession or control of the information being requested.The request seeks
developmentof a special study or information not maintained in the ordinary
course of business.The Company further objects on the basis that the request is
vague and ambiguous.Without waiving these objections,the Company responds
as follows:
(a)PacifiCorp does not distinguish between excess generationand economic
displacement for Jim Bridger output.
(b)The Jim Bridger coal plant is located within the PacifiCorp West (PACW)
balancing authorityarea (BAA)and the wind generationeast of Jim Bridger is
located in the PacifiCorp East (PACE)BAA.Transfers of energy between the
PACE and PACW BAAs is not scheduled on a resource-specific basis.
(c)Please refer to Confidential Attachment IIPA 3,which provides POWERDEX
hourlyFour Corners (4C)market prices for calendar years 2012 through 2016,
and calendar year 2017 (through August 2017).The POWERDEX
information provided is confidential and proprietary third-partydata that is the
property of POWERDEX.The POWERDEX hourlymarket prices are
provided subject to the PacifiCorp POWERDEX Subscription Agreement,
which requires that POWERDEX proprietary data be provided only to persons
qualified to receive confidential information under the protective order for this
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 16'Set Data Request 3
regulatory proceeding.Furthermore,parties must return or destroy all
POWERDEX data that the Company provides in responses to data requests in
this regulatory proceeding,and any extracts thereof,followingconclusion of
this regulatory proceeding.
(d)PacifiCorp does not designate specific resources for transfers between the
PACE BAA to PACW BAA.When a transfer occurs from the PACE BAA to
PACW BAA,via the overlay or scheduled generationon a different path,the
transfer of energy is from the PACE system,which includes all resources
within PACE.
(e)Please refer to the Company's response to subpart (d)above.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Tom Burns and Michael Jiang
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA lst Set Data Request 4
IIPA Data Request 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?
Confidential Response to IIPA Data Request 4
The Company objects to this request on the basis that the Company does not have
custody,possession or control of the information being requested.The request
seeks developmentof a special study or information not maintained in the
ordinary course of business.The Company further objects on the basis the
request is vague and ambiguous.Without waiving these objections,the Company
responds as follows:
(a)PacifiCorp is unclear on what the intended definition of "excess capacity"or
"excess generation"as used in this data request.For the Dave Johnston
facility,below are the megawatt-hours (MWh)that the resource was
decremented below its rated capacity.PacifiCorp is unable to determine if the
resource generated below its rated capacity due to renewable generation in the
PacifiCorp system,imports in the energy imbalance market (EIM)that were
more economic than generatingat the facility,or operating restrictions at the
facility.
(b)Please refer to the Company's response to subpart (a)above.
(c)Please refer to the Company's response to IIPA Data Request 3 subpart (c).
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 1st Set Data Request 4
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Tom Burns
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 16*Set Data Request 5
IIPA Data Request 5
Is the retirement of Dave Johnston in 2027 in any way contingent upon the
completion of the transmission project addressed in this case?
Response to IIPA Data Request 5
No.
Recordholder:Chad Teply
Sponsor:Chad Teplyand Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 16'Set Data Request 6
IIPA Data Request 6
On page 6 of Mr.Teply's Direct Testimony it states that when QFs are considered
in conjunctionwith 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.Crane's testimony the new transmission project will increase East to West
capacity by 750 MW.Please explain the disposition of the difference between
1,180 MW of new wind and the increase transmission of 750 MW.
Response to IIPA Data Request 6
The 750-megawatt (MW)figure referred to in the direct testimony of Company
witness Cindy A.Crane is firm incremental east-to-west transmission capacity.
The 1,180 MW of capacity referred to in the direct testimony of Company witness
Chad A.Teply includes 860 MW of proposed Company benchmark wind capacity
(Wind Projects)and an additional 320 MW qualifyingfacility (QF)wind capacity
that currentlyhas a favorable transmission interconnection queue position.The
difference in total incremental wind generationcapacity that will ultimatelybe
interconnected and firm incremental transmission capacity that is attributable to
the Transmission Projects will be balanced by managing the system in response to
the variability in the interconnectedwind generationresources and the ability to
back-down dispatchable Wyoming thermal generating resources,when necessary.
Recordholder:Chad Teply
Sponsor:Chad Teplyand Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA lst Set Data Request 7
HPA Data Request 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 additional wind 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"?
(d)With the wind facilities operating "near full output",what would be the
amount (MW's)of "re-dispatched"resources?
Response to IIPA Data Request 7
(a)Re-dispatched in the context of high wind indicates that other generation
resources would be curtailed or operated at something less than their
maximum output levels.
(b)The most likelyresources to re-dispatch in Wyoming are the units at Jim
Bridger,Dave Johnston and Wyodak.
(c)Near full output would indicate that a generating resource is operating close to
its installed nameplate capacity.
(d)Preliminary studies indicated a re-dispatch of approximately 900 megawatts
(MW).This number is expected to vary with system conditions.
Recordholder:Craig Quist /Robyn Kara
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 16'Set Data Request 8
HPA Data Request 8
Regardingpage 17 of Mr.Vail's Direct Testimony,what is meant by "Under
certain operation conditions"?
Response to HPA Data Request 8
Operating conditions can pertain to the amount of generationon-line or off-line at
a given time,the number of transmission lines or other transmission elements in
service or out of service,the amount of load in a particular area,the amount of
power flows from outside of the PacifiCorp system,or any combinations thereof.
Recordholder:Craig Quist /Robyn Kara
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 1st Set Data Request 9
IIPA Data Request 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 Bridger?
Response to IIPA Data Request 9
As the Energy Gateway West -Subsegment D.2 (Bridger/Anticline-Aeolus)
project does not include new transmission facilities west of Jim Bridger,the
impedance of the lines will remain unchanged as will the resultant energy and
capacity losses.
Recordholder:Craig Quist /Robyn Kara
Sponsor:Rick vail
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 161 Set Data Request 10
IIPA Data Request 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?
Response to IIPA Data Request 10
Please refer to Attachment IIPA 10.
Recordholder:Daniel MacNeil
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 25,2017
IIPA 16'Set Data Request 11
IIPA Data Request 11
Please explain the differences between Exhibit 24 and Exhibit 25 for following
data 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.
Response to IIPA Data Request 11
(a)Please refer to the direct testimony of Company witness,Rick T.Link,
specifically page 26,line 13,through page 27,line 22.This testimony
explains that capital revenue requirement is levelized in the System Optimizer
model (SO model)and Planning and Risk (PaR)model.Levelized capital
revenue requirement for the Combined Projects is reflected in the results
reported in Link Exhibit No.24.
Please also refer to Mr.Link's direct testimony,specifically page 28,
lines 1-16.This testimony explains that levelized capital revenue requirement
is replaced with nominal capital revenue requirement when assessing annual
revenue-requirementimpacts from the Combined Projects.Nominal capital
revenue requirement is reflected in the results reported in Link Exhibit No.25.
(b)The referenced data highlight changes in net power cost (NPC)benefits
between the SO model (Link Exhibit No.24 for the referenced data)and PaR
(Link Exhibit No.25 for the referenced data).Please refer to Mr.Link's
Direct Testimony,specifically page 17,line 10,through page 18,line 16,and
page 37,line 16,through page 38,line 2.The two models have different
purposes.Differences in the functionalitybetween the two models drive
differences in forecasted NPC benefits.
(c)Please refer to the Company's response to subparts (a)and (b)above.
Recordholder:Rick Link
Sponsor:Rick Link