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Home My WebLink About20171004Wyoming_OCA Set 4 1-2.pdfROCKY MOUNTAINPOWER A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330 Salt Lake City,Utah 84116 October 2,2017 Christopher Leger,Counsel Wyoming Bar #6-3963 Wyoming Office of Consumer Advocate 2515 Warren Avenue,Suite 304 Cheyenne,WY 82002 christopher.leger@wyo.gov (C) RE:Wyoming Docket 20000-520-EA-17 OCA 4th Set Data Request (1-2) Please find enclosed Rocky Mountain Power's Responses to OCA 4th Set Data Requests 4.1-4.2. If you have any questions,please call me at (307)632-2677. Sincerely, Stacy Splittstoesser, Manager,Regulation Enclosures C.C.:Meridith Bell/WPSC meridith.bell@wyo.gov(C) Lori L.Brand/WPSC lori.brand@wyo.gov (W) John Burbridge/WPSC john.brubride@wyo.gov (W) Michelle Bohanan/WPSC Michelle.bohanan@wyo.gov (W) Kara Seveland/WPSC kara.seveland@wyo.gov(W) Morgan Fish/WPSC morgan.fish@wvo.gov (W) Dave Walker/WPSC dave.walker@wyo.gv (W) Perry McCollom/WPSC perry.mccollom@wyo.gov(W) Abigail C.Briggerman/WIEC acbriggerman@hollandhart.com(C) Patti Penn/WIEC PPenn@hollanhart.com(W) Bob Pomeroy/WIEC rpomerov@hollandhart.com (W) Thor Nelson/WIEC tnelson@hollandhart.com (W) Emanuel Cocian/WIEC etcocian@hollanhart.com (W) Nik Stoffel/WIEC NSStoffel@hollandhart.com (C)(W) Crystal J.McDonough/NLRAcrystal@medonoughlawlle.com (C) Adele Lee/WIEC ACLee@hollandhart.com (W) Lisa Tormoen Hickey/Interwestlisahickey@newlawaroup.com (C) 20000-520-EA-17 /Rocky Mountain Power October 2,2017 OCA Data Request 4.01 OCA Data Request 4.01 Please describe in detail the difference in net benefit to customers that results from the new wind proposed by the Company in this proceeding as opposed to the cost of the proposed transmission.In other words,how big would the benefit of the new wind be if the Company didn't have to build the transmission projects to interconnect the new wind? Please provide any supporting analysis related to the answer to this question. Response to OCA Data Request 4.01 There can be no net benefit to customers from the new wind projects proposed in eastern Wyoming without the new transmission project because the new wind projects cannot interconnectto the transmission system without the Aeolus-to-Bridger/Anticlineline. PacifiCorp needs and has needed the new transmission line for quite some time.To avoid a $700 million expense,most of which would be borne by our retail customers under Federal Energy Regulatory Commission (FERC)precedent,the company has been "living within its means"and re-dispatching generation that exists today to avoid reliability issues and to cost-effectivelydispatch its resources.PacifiCorp's plan capitalizes on the production tax credits (PTC)that the new wind will generate to not only meet its long-term resource needs,but to also build new and much-needed transmission with all-in net benefits for customers. Respondent:Sarah Link Witness:Rick Link and Rick Vail 20000-520-EA-17 /Rocky Mountain Power October 2,2017 OCA Data Request 4.02 OCA Data Request 4.02 Please provide a detailed,itemized list of all known errors in the Company's analysis in this proceeding along with a detailed explanation of the source of the error and its impact on the net benefit of the proposal.Will these known errors cause the Company to revise its analysis in this proceeding? Response to OCA Data Request 4.02 PacifiCorp is aware of two modeling errors in the Energy Vision 2020 analysis as described below.While the impact of these errors have not been explicitlyquantified at this time,PacifiCorp does not anticipate that corrections will eliminate the projected net benefits projected from the project.The Company intends to correct for these errors and update its analysis as part of its rebuttal testimony.Impacts on the net benefit of the Company's Application is not known at this time,but will be described in Rebuttal Testimony of Company witness,Rick T.Link. The "Cholla to 4-Corners"transmission tie in the System Optimizer model (SO model)and Planning and Risk (PaR)model,included transfer capability of 37 megawatts (MW)over the 2021 period in the simulations containing new wind and transmission.This transfer capability should have been 0 MW during the 2021 through 2025 period,which is the same assumption used in the simulations without the new wind and transmission. The "WyomingNEto Aeolus Wyoming"transmission tie derate was inadvertentlynot applied during the 2017 through 2019 period in simulations without the new wind and transmission. Respondent:Dan Swan Witness:Rick Link