20171109PAC to Staff 3rd Suppl WY-17 WIEC Set 7 1-14.pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACFFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
October 23,2017
Abigail C.Briggerman,#7-5476
Holland &Hart LLP
6380 South Fiddlers Green Circle,Suite 500
Greenwood Village,CO 80111
[e-mail](C)
RE:Wyoming Docket 20000-520-EA-17
WIEC 7th Set Data Request (1-14)
Please find enclosed Rocky Mountain Power's Responses to WIEC 7th Set Data Requests 7.6 and
redacted responses to 7.8,and 7.9.Provided on the enclosed Confidential CD are Confidential
Responses WIEC 7.8 and 7.9 and Confidential Attachment WIEC 7.9.Confidential information
is provided subject to the terms and conditions of the protective agreement in this proceeding.If
you have any questions,please call me at [phone].
Sincerely,
Stacy Splittstoesser,
Manager,Regulation
Enclosures
C.C.:Meridith Bell/WPSC (C)
Lori L.Brand/WPSC (W)
John Burbridge/WPSC [e-mail] (W)
Michelle Bohanan/WPSC [e-mail] (W)
Kara Seveland/WPSC [e-mail](W)
Morgan Fish/WPSC nmorgandishgLwy_ogov (W)
Dave Walker/WPSC slave._walker@wy_ogv (W)
Perry McCollom/WPSC [e-mail] (W)
Patti Penn/WIEC PPenn hollanhart.com (W)
Bob Pomeroy/WIEC (W)
Thor Nelson/WIEC (W)
Emanuel Cocian/WIEC (W)
Adele Lee/WIEC [e-mail] (W)
Nik Stoffel/WIEC [e-mail] (C)(W)
Christopher Leger/OCA (C)
Crystal J.McDonough/NLRAc_rysta medo_no_ughlawlle.co_m(C)
Lisa Tormoen Hickey/[e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
October 23,2017
WIEC Data Request 7.6
WIEC Data Request 7.6
Please confirm that RMP and/or PacifiCorp Subject Matter Experts represented the
followingstatements to be true during the New Wind Technical Conference on
September 9,2017.For each of the statements below,if any response is anything other
than an unqualified confirmation,please explain the response in detail.
(a)The new wind facilities cannot qualify as commercially operational (and therefore
would not be eligible for PTCs)unless both the proposed transmission and wind
facilities are completed and placed in service prior to December 31,2020.
(b)The capital cost estimates are still uncertain as the exact sites,equipment,vendors,
etc.are still unknown because the RFP is still being conducted.
(c)The wind distribution profiles,and consequently,the distribution of net capacity
factors for the proposed project are still uncertain as the exact sites,equipment,
vendors,etc.are still unknown because the RFP is still being conducted.
(d)The Company has not performed any breakeven analysis or sensitivity analysis with
respect to the net capacity factor assumption as the exact sites,equipment,vendors,
etc.are still unknown because the RFP is still being conducted.
(e)The Company is planning to supplement its filing with data for the specific sites once
the RFP process is completed and specific sites,vendors,equipment,etc.is chosen.
(f)Once the RFP process is further along and a "short list"is identified,a third-partywill
be developing site specific wind profiles that will be used to assess the wind potential
and wind risk at the site(s)chosen.
(g)Parties should not focus on one parameter or another included in the analysis
currently,such as individual sensitivities to the capital cost or net capacity factor in
isolation,but rather in order to adequately assess the economics,you have to wait and
see the combined proposal resulting from the bidding process currentlyunder way.
Response to WIEC Data Request 7.6
The Company assumes the date stated above (September 9,2017)is a typographical error
and should actually be September 25,2017 since that is the date the technical conference
was held in Wyoming.Based on the foregoing assumption,the Company responds as
follows:
(a)Not confirmed.The Company recalls discussing the nuances of production tax credit
(PTC)eligibilityunder a number of hypothetical scenarios during the technical
conference with Wyoming stakeholders held on September 25,2017.During the
dialogue,the Company explained that its interpretation of Internal Revenue Service
(IRS)code regarding individual wind turbine generators (WTGs)is that individual
WTGs may meet the IRS's "in-service"qualification to maintain 100 percent safe-
harbor PTC eligibilityunder certain circumstances before December 31,2020,
20000-520-EA-17 /Rocky Mountain Power
October 23,2017
WIEC Data Request 7.6
without having been placed into "commercial operation."The Company recalls
explaining that the 500 kilovolt (kV)transmission line associated with the Company's
proposed Wyoming wind projects will need to be "in-service"to facilitate
"commercial operation"of the wind resources.
(b)The Company presumes the capital cost estimates referenced in this question are for
the Wyoming wind projects contemplated in the Company's Certificate of Public
Convenience and Necessity (CPCN)application.As described throughout the
Company's CPCN application and subsequent correspondence with Parties,the
capital costs for the Wyoming wind projects that are ultimatelyselected (if
demonstrated to be economic through the 2017 Renewable Request for Proposals
(2017R RFP)results and assessment)will be submitted in the Company's January
2018 supplemental filing in the Wyoming CPCN docket,followingfinal shortlist
determination in the 2017R RFP.
(c)Please refer to the Company's response to subpart (b)above.The wind projects
selected in the 2017R RFP will dictate the wind characteristics and performance of
individual wind resources.
(d)Confirmed.
(e)Confirmed,as communicated in the Company's CPCN application and subsequent
correspondence with Parties.
(f)The 2017R RFP requires that bidders provide appropriate wind profile assessments
for their specific sites,equipment selections,equipment layouts,and interconnection
details at the time of bid submittal (subject to due diligence beginning at that time).
This information will be provided before the short list is determined.
(g)In response to a question regarding whether a change in net capacity factor would
undermine the economic benefit of the proposed wind and transmission projects,the
Company explained that evaluation factors such as capital cost and net capacity factor
must inherentlybe assessed in conjunction to determine the benefits of individual
wind projects.
Respondent:Chad Teply
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
October 23,2017
WIEC Data Request 7.8
WIEC Data Request 7.8
Confidential Request -With respect to the new wind roject oposed,please discuss in
detail how the assumed
was determined.
Response to WIEC Data Request 7.8
The Company assumes that the Wyoming Industrial Energy Consumers'(WIEC)
reference to the assumed wind capacity factor is based on data from the Planning and
Risk (PaR)model in a table included in a confidential work paper supporting the Direct
Testimony of Company witness,Rick T.Link,specifically "Wind Summary Data".
These data reflect output from the PaR model,which performs a stochastic analysis of the
Company's system over the forecast horizon by sampling a representative week for each
month.These data show the resulting annual generation data for the proposed pro.jects
reported as an output from the PaR model,reflecting its extension of the sampled weeks
for any given year.The sampling of weeks is not completely arbitrary or random.The
sample week for summer peak is aligned to the summer peak load.To the extent that
sampling the peak week coincides with a week in the hourly generationprofiles where
the wind generationfor that week is higher than the monthlyaverage,the effective
capacity factor calculated off of the PaR output can be higher than the average hourly
generationused as an input in PaR.However,the underlying data fed into PaR reflects an
hourly generationprofile that is consistent with the capacity factor assumptions
summarized in Confidential Exhibit RMP_(RTL-1)to Mr.Link's direct testimony.
The Company is developing a process improvement whereby the hourly generation data
inputs for PaR are adjusted so that the hourly generation for sample weeks is equal to
hourly generationexpected for the associated month.The Company intends to update its
PaR results in its rebuttal filing to reflect this process improvement.
The input data used to estimate net capacity factor (NCF)inputs for the proxy resources
was developedusing the followinginformation:
The utility scale wind generation study prepared by Black and Veatch (B&V)in 2016
that was used to inform the wind cost and performance data in the 2017 Integrated
Resource Plan (IRP)that indicated a NCF of 43 percent in Wyoming.A copy of the
B&V study is provided with the Company's response to WIEC Data Request 7.9,
specifically Confidential Attachment WIEC 7.9.
The historic NCFs of the Company's Seven Mile Hill and Dunlap wind facilities
which are in the range of 40 percent.
Actual performance of existing wind facilities was combined with anticipated
performance of new wind turbine technology to create a balanced estimate of future
wind facility performance.
20000-520-EA-17 /Rocky Mountain Power
October 23,2017
WIEC Data Request 7.8
The specific wind turbines selected for deployment on these projects,as well as detailed
site layouts,and site specific wind conditions will ultimatelydictate and inform NCF
assumptions and associated project economics.In its rebuttal filing,the Company will
update NCF assumptions,and other cost data for the proxy benchmark resources,based
on data included in the benchmark resource bids submitted into the 2017 Renewable
Request for Proposals (2017R RFP).The Company will update its economic analysis to
reflect final shortlist bid selections from the 2017R RFP in its January 16,2018
supplemental filing.
Confidential information is provided subject to the protective order in place in this
docket.
Respondent:Ken Clark /Randy Baker
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
October 23,2017
WIEC Data Request 7.9
WIEC Data Request 7.9
Confidential Request -Referring to RMP's Response to WIEC Data Request 5.9 and
Attachment WIEC 5.9,lease discuss in detail why a
assumption was used when the
average capacity factor realized from 2012-2016 for each of the Wyoming wind farms
listed in response to WIEC 5.9 was between 33.5%and 41.9%.
On October 13,2017,the Wyoming Industrial Energy Consumers (WIEC)submitted a
restated request for WIEC Data Request 7.9 as follows:
RESTATED CONFIDENTIAL REQUEST-Referring to RMP's Response to WIEC
Data Request 5.9 and Attachment WIEC 5.9.Also refer to Mr.Link's Direct Testimony
at Page 23,Line 5 as well is his confidential work paper "Wind Summary Data.xlsx"and
please answer the followingquestions:
(a)Please explain why,if annual capacity factors are calculated for the data tables found
on the "New Wind Data for Cales"tab,excluding the QF projects,and assuming 860
MW of Installed Wind Capacity and 8760 hours in a year (8784 for leap years),the
annual average capacity factor for the "PaR"data table is roximately
hereas the "SO"data
table is approximatelyM?Please also reconcile this to Mr.Link's Testimony and exhibits.
(b)
was used when the average capacity factor realized from 2012-2016 for each of the
Wyoming wind farms listed in response to WIEC 5.9 was between 33.5%and
41.9%.
(c)Please discuss in detail why a
net capacity factor assumption as stated in Mr.Link's
Testimony was used when the average capacity factor realized from 2012-2016 for
each of the Wyoming wind farms listed in response to WIEC 5.9 was between 33.5%
and 41.9%.
(d)Please provide all supporting studies performed by RMP or on its behalf used to
develop and justify its capacity factor assumption?
(e)Confirm that that the information reported in Table 3 and Figure 5 in Mr.Link's
Direct Testimony relies upon the "PaR"outputs which have incorporated an average
annual ca acity factor of approximately
(as calculated in question 1).If the response is anything
other than an unqualified confirmation,please explain the response in detail.
Confidential Response to WIEC Data Request 7.9
20000-520-EA-17 /Rocky Mountain Power
October 23,2017
WIEC Data Request 7.9
(a)Please refer to the Company's response to WIEC Data Request 7.8.The System
Optimizer model (SO model)does not perform its simulation using sample weeks.
The referenced SO model data are closely aligned with the capacity factor
assumptions identified in the Direct Testimony of Company witness,Rick T.Link,
specifically Confidential Exhibit RMP_(RTL-1).The slight differences between the
capacity factor assumptions from the SO model out relative to Confidential Exhibit
RMP_(RTL-1)can be attributed to rounding effects and the SO model's use of a
365.25-day (8766 hour)year to accommodate leap-year rather than varyingevery
fourth year in the 20-year analysis.
(b)Please refer to the Company's response to subpart (a)above.Input assumptions for
new wind resources are based on operations from existing wind facilities and
improvements in wind turbine technology,notably blade length which have led to
substantial changes in wind turbine performance and layout design compared to wind
projects that were constructed in 2007 through 2010.
(c)Mr.Link's direct testimony does not reference a
net capacity factor (NCF)assumption.Please refer to
the Company's response to subpart (b)above.
(d)Please refer to Confidential Attachment WIEC 7.9,which provides a copy of the
utility scale wind generation study prepared by Black and Veatch (B&V)in 2016 that
was used to inform the wind cost and performance data in the 2017 Integrated
Resource Plan (IRP),the information of which was used to support the estimated
capacity factor assumptions.Please also refer to the Company's response to WIEC
Data Request 5.9,specifically Attachment WIEC 5.9,which also provides
information used to support the estimated capacity factor assumptions.
(e)Yes.Results reported for the Planning and Risk (PaR)model in Table 3 and Figure 5
in Mr.Link's direct testimony rely on the referenced PaR outputs.
Confidential information is provided subject to the protective order in place in this
docket.
Respondent:Ken Clark /Randy Baker
Witness:Chad Teply