20180208PAC to Staff UT OCS Set 10 (1-16).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
AD1VISION OF PAClFICORP
February 2,2018
Béla Vastag
Office of Consumer Services
160 East 300 South
Salt Lake City,Utah 84111
b_vastag@utahgov (C)
RE:UT Docket No.17-035-40
OCS 10*Set Data Request (1-16)
Please find enclosed Rocky Mountain Power's Responses to OCS 10*Set Data Requests 10.1,
10.5,10.7,10.9,10.10,10.11,and 10.13.The remaining responses will be provided separately.
Also provided are Attachments OCS 10.1 and OCS 10.10.Provided on the enclosed
Confidential CD are Confidential Attachments OCS 10.5 and OCS 10.9.Confidential
information is provided subject to Public Service Commission of Utah (UPSC)Rule 746-1-602
and 746-1-603.
If you have any questions,please call me at [phone].
Sincerely,
Jana Saba
Manager,Regulation
Enclosures
C.c.Erika Tedder/DPU [e-mail]@utah.gov(C)
Dan Kohler/DPU [e-mail](C)
Dan Peaco/DPU [e-mail] (C)(W)
Aliea Afnan/DPU aafnan daymarkea.com (W)
jbower@dayn;iarkea.com(W)
Philip Hayet/OCS [e-mail] (C)
Gary A.Dodge/UAE [e-mail] (C)
PhillipRussell/UAE [e-mail] (C)
Kevin Higgins/[e-mail] (C)
Neal Townsend/UAE [e-mail](C)(W)
Sophie Hays/UCE [e-mail](C)
Kate Bowman/UCE [e-mail](C)(W)
Emma Rieves/UCE [e-mail](C)(W)
Lisa Tormoen Hickey/[e-mail] (C)
Mitch Longson/Interwest [e-mail](C)
Nancy Kelly/[e-mail](C)
Jennifer Gardner/WRA [e-mail](C)
Penny Anderson/WRA [e-mail] (W)
Peter J.Mattheis/Nucor [e-mail] (C)
Eric J.Lacey/Nucor [e-mail] (C)(W)
William J.Evans/UIEC [e-mail]
Vicki M.Baldwin/UIEC [e-mail](W)
Chad C.Baker/UIEC [e-mail] (W)
17-035-40/Rocky Mountain Power
February 2,2018
OCS Data Request 10.1
OCS Data Request 10.1
EIM modeling.
(a)Did the Company continue to model a 300 MW increase in transfer limits in its
Rebuttal Analyses to account for participation in the EIM?
(b)Please describe the analysis that was performed to determine that 300 MW was the
correct value to use for this purpose as opposed so something less or more than 300
MW.Please provide any analyses performed to derive the 300 MW value.
(c)Did the Company explore any other potential modeling options for this purpose?For
example,why is an increase in transfer capacity more appropriate than lowering
market prices,increasing market depth,etc?Please explain.
Response to OCS Data Request 10.1
(a)Yes.
(b)PacifiCorp's estimate of a 300 megawatt (MW)increase in transfer capability was
based on historical experience with adjacent entities that have joined the energy
imbalance market (EIM)since 2014.Please refer to Attachment OCS 10.1,which
provides the transmission intertie connectivityvolumes as of December 2017.In each
case that an entityhas joined the EIM,total transmission connectivityto PacifiCorp
has been greater than or equal to 300 MW.Idaho Power Company (IPC)has not yet
finalized its transmission availabilityto the market,however,it is in each entity's best
interest to make its transmission available to the market to maximize EIM benefits.
(c)No,the Company did not explore any non-transmission modeling options for the EIM
benefit as the 300 MW increase stems from transmission-relatedimpacts.The
transmission increase is primarily attributed to IPC participation in the EIM in 2018,
creating 300 MW of incremental intra-hour transmission available from the Jim
Bridger plant to south-central Oregon.
17-035-40/Rocky Mountain Power
February 2,2018
OCS Data Request 10.5
OCS Data Request 10.5
Proxy PPA/OF modeling.Beginning at line 301 of his rebuttal testimony,Mr.Link
discusses that proxy PPA costs were modeled in the Company's initial filing,and that
those costs were based on certain QF projects.
(a)Provide the name of those QF projects,and any reports/analyses concerning those
projects that the Company used to develop cost and unit characteristic assumptions
that was used in modeling wind resources in the SO/PaR models in the initial filing.
Provide any work papers,electronicallythat the Company developedin modeling
those units in the initial filing.
(b)Explain how the company derived the values at lines 303 and 304 of Mr.Link's
rebuttal testimony,and provide work papers,if any were created.
(c)At line 307 of his rebuttal testimony,Mr.Link states that certain interconnection
costs were removed from the modeling.Please provide a comparison of the
interconnection costs that were removed,and describe the specific interconnection
facilities no longer needed,and compare that to the costs and the type of
interconnection facilities being added for each individual winningwind resource.
Response to OCS Data Request 10.5
Note:The "QF Projects"are Boswell Springs I,LLC (80 megawatts (MW)),Boswell
Springs II,LLC (80 MW),Boswell Springs III,LLC (80 MW),and Boswell Springs IV,
LLC (80 MW),collectivelyreferenced herein as "Boswell Springs I-IV."
(a)The proxy power purchase agreement (PPA)costs modeled in the Company's direct
testimony filing reflected the avoided cost prices contained within the PPAs executed
with Boswell Springs for the Boswell Springs I-IV projects.While these prices
represent the Company's avoided costs,the execution of the PPA indicates that the
project owner anticipated the PPAs would support project development,making it a
suitableproxy for PPAs proposals expected to be received in the 2017R Request for
Proposals (2017R RFP).Please refer to the Company's response to OCS Data
Request 1.34,specifically Confidential Attachment OCS 1.34-1,which provides
copies of the executed Boswell Springs I-IV PPAs.Please refer to Confidential
Attachment OCS 10.5,which provides supporting work papers on pricing and hourly
wind shape.
(b)Lines 303 and 304 in the rebuttal testimony of Company witness,Rick T.Link are
supported by Confidential Exhibit 1 to Mr.Link's direct testimony,specifically rows
42,45 and 48.
(c)The Boswell Springs I-IV projects require additional transmission facilities beyond
the currentlyproposed Aeolus to Bridger expansionto be completed in 2020.
17-035-40/Rocky Mountain Power
February 2,2018
OCS Data Request 10.5
Completion of Energy Gateway South and the Aeolus to Populus portion of the
Energy Gateway West expansionproject will be required prior to interconnecting the
Boswell Springs I-IV projects.Interconnection of the Boswell Springs I-IV projects
prior to completion of the listed incremental transmission facilities would create
system emergency conditions.These transmission projects,which represent several
billion dollars of new capital,are not planned to be in service until 2024.These costs
were not included in the analysis;however,the listed facilities are required to be in-
service prior to Boswell Springs I-IV project interconnection to maintain system
reliability.Note:interconnection queue numbers for the Boswell Springs I-IV
projects are:409-A (Boswell Springs I),409-B (Boswell Springs II),409-C (Boswell
Springs III),and 409-D (Boswell Springs IV)
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.
17-035-40/Rocky Mountain Power
February 2,2018
OCS Data Request 10.7
OCS Data Request 10.7
Solar RFP and Sensitivity.Refer to Mr.Link's rebuttal testimony starting at line 685.
Mr.Link describes,"two model runs--one with solar PPA bids and the Combined
Projects and one with solar PPA bids but without the Combined Projects".
(a)In each of the cases studied,i.e.the case with the wind bids modeled,the case with
the solar bids,and the case with the solar bids and the wind bids modeled,how did
the Company model the new transmission costs (500 kV and 230 kV costs)in each
case?For example,were there any cases modeled in which the new transmission
costs were not forced-in?Were the new transmission costs forced-in in the case in
which just solar bids were modeled?
(b)Please explain what Mr.Link meant when he stated,"Combined Projects".Did he
mean the new wind/new transmission projects?
(c)Please explain how the Uinta bid and other wind resources located in areas outside of
the constrained transmission area were modeled in any of the portfolio selection
analyses.In other words,was it possible for non-eastern Wyomingwind projects to
be selected along with Utah solar without having to pay the costs of doing the
transmission upgrades in eastern Wyoming?
Response to OCS Data Request 10.7
(a)All cases simulations in which wind bids were made available for selection by the
system optimizer model (SO model)include the cost of the Aeolus-to-
Bridger/Anticlinetransmission line and the cost of interconnection network upgrades
for the specific wind projects selected.All cases where wind bids were not available
for selection by the SO model (i.e.,the case with solar bids only),there are no costs
for the Aeolus-to-Bridger/Anticlinetransmission line and no costs for interconnection
network upgrades for wind bids.The cases that allow solar bids to be selected include
interconnection network upgrade costs associated with the specific solar bids selected
by the SO model.
(b)Please refer to lines 7-10 of the supplemental direct and rebuttal testimony of
Company witness,Rick T.Link.Yes,the Combined Projects is in reference to the
new wind resources,the Aeolus-to-Bridger/Anticlinetransmission line,and network
upgrades.
(c)The SO model was used to evaluate all wind bids endogenouslyas options in the
model,selecting the least-cost combination of all bids.For bids behind the TOT4A
transmission constraint,total bid selections were limited to 1,030 megawatts (MW).
This applied to all but three of the initial shortlist projects.No restrictions were
placed on those bids that are not behind the TOT4A constraint.Transmission
interconnection network upgrade costs were assigned to each bid,as applicable.The
17-035-40 /Rocky Mountain Power
February 2,2018
OCS Data Request 10.7
cost of the Aeolus-to-Bridger/Anticlinetransmission line was not assigned to a
specific bid,but was included as a system cost.Consequently,the SO model was free
to select wind bids,regardless of location,along with solar bids in the sensitivitythat
allowed for solar bid selections,without being assigned the cost of the Aeolus-to-
Bridger/Anticlinetransmission line.In this way,the cost of the Aeolus-to-
Bridger/Anticlinetransmission line does not affect bid selections,but it does affect
the present value of revenue requirements differential (PVRR(d))results.
17-035-40/Rocky Mountain Power
February 2,2018
OCS Data Request 10.9
OCS Data Request 10.9
Wind Specifications.Please provide a side-by-side comparison of the wind benchmark
resources modeled in direct testimony to the selected wind resources modeled in the
rebuttal testimony.Please provide comparisons of energy pattern,resource costs,
capacity factors,capacity contribution percentage,and any other relevant characteristics
that were modeled.
Response to OCS Data Request 10.9
Please refer to Confidential Attachment OCS 10.9,which provides the energy patterns for
the wind shapes.
The Company has compiled a worksheet with the original base case wind assets (all
PacifiCorp benchmarks)and the current final short list (FSL)case wind assets.Due to the
ongoing nature of the 2017R Request for Proposals (2017R RFP),the document
associated with the foregoing 2017R RFP information is considered commercially
sensitive and highly confidential.The Company does not typically permit access to
commercially sensitive 2017R RFP documentation until the RFP has been concluded.
Please contact Stacy Splittstoesser at [phone] or Yvonne Hogle at [phone]
to make arrangements for review.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.
17-035-40 /Rocky Mountain Power
February 2,2018
OCS Data Request 10.10
OCS Data Request 10.10
Fuel Assumptions.Did the Company utilize more recent fuel,CO2,and market price
forecasts (low,medium,high)compared to what it used in its updated modeling in its
Rebuttal Testimony in the Repowering docket (17-035-39)?If so,please provide a side-
by-side comparison of the differences in the fuel,CO2,and market price forecasts (low,
medium,high).
Response to OCS Data Request 10.10
Yes.Please refer to Attachment OCS 10.10,which provides the Company's natural gas
and carbon dioxide (CO2)price assumptions used in the supplemental direct and rebuttal
testimony of Company witness,Rick T.Link versus those used in Mr.Link's rebuttal
testimony in Docket 17-035-39.
Note:the December 2017 CO2 prices,referenced in Figure 4-SD of Mr.Link's
supplemental direct and rebuttal testimony,were inadvertentlyapplied in real dollars
instead of nominal.Consequently,economic results for the six price-policy scenarios that
assume medium or high CO2 prices are conservative and understate potential cost savings
associated with reduced CO2 emissions.Nominal figures are also included in Attachment
OCS 10.10.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.
17-035-40 /Rocky Mountain Power
February 2,2018
OCS Data Request 10.11
OCS Data Request 10.11
Base Cases.Refer to Mr.Link's rebuttal testimony beginning at line 384 and the "Risk
Adjustment"tab in "Table 2-SD,Table 3-SD,Figure 5 FSL Results Summary File.xlsx"
and the "Risk Adjustment"tab in "Gateway Results Direct Testimony.xlsm".
(a)Please confirm that the "Rl7-Base-MN"(rebuttal)is the analog case to "PSENS-
RPN-EEN-MN"(direct).
(b)Please confirm that these new "base"cases reflect load-forecast,OFPC,and tax rate
changes.
(c)Please confirm that these new "base"cases exclude the solar and wind alternative
options and transmission projects.
(d)Please identify all differences between the IRP base case,the direct testimony base
case,and this rebuttal filing base case.
(e)Please explain why the rebuttal results can be directlyderived from this risk-
adjustment tab summary to match Table 2-SD,but that is not the case for the direct
testimony results.In other words,in the "Table 2-SD...xlsx"file,"Risk Adjustment"
tab,cell D15 -D6 =104 matches to Link Table 2-SD.But in the "Gateway Results
Direct Testimony.xlsm""Risk Adjustment"Tab,cell D15 -D6 =56 does not match
to Table 2 in Mr.Link's direct testimony.
Response to OCS Data Request 10.11
(a)Confirmed,"R17-Base-MN"(rebuttal)is the analog case to "PSENS-RPN-EEN-
MN"(direct).
(b)Confirmed,all cases reflect updates to load forecast,official forward price curve
(OFPC)and tax rate that have occurred since the Company submitted its direct
testimony in this proceeding.
(c)Confirmed,the new base cases exclude the 2017S Request for Proposals (2017S
RFP)bids,but includes 2017 Integrated Resource Plan (IRP)solar options.The new
base cases exclude the 2017R RFP bids,but includes a Wyomingwind power
purchase agreement (PPA)for a qualifying facility (QF)project that has an executed
interconnection agreement.The new base cases also exclude the new transmission
project.
(d)Please refer to the followingtable listing the base cases:
17-035-40 /Rocky Mountain Power
February 2,2018
OCS Data Request 10.11
2017 IRP Base Case Direct Testimony Rebuttal Filing
(OP-NT3)Base Case Base Case
Filing Date March 31,2017 June 30,2017 January 16,2018
Loads December 2016 December 2016 August 2017
Prices October 2016 April 2017 December 2017
Wyoming IRP Wind 300 megawatts (MW)300 MW 239 MW PPA
Options (2021)
IRP Solar Options Available Available Available
EIM (Modeled)Post Model Yes Yes
Adjustment
Transmission Post Model No Yes
Reliability Derate Adjustment
Federal Tax Rate 35 percent 35 percent 21 percent
Carbon Dioxide(CO2)Mass Cap B CO2 Price CO2 Price
Emissions
Contract Update Post No Yes Yes
2017 IRP
(e)The values in Table 2 report the "Net (Benefit)/Cost"as calculated in the "Price-
Policy Annual -SO"and "Price-Policy Annual -PaR"worksheets.These worksheets
include an adjustment to "Cost of Projects"for each Price-Policy scenario capturing
additional fixed costs not reflected in the initial present value of revenue requirements
(PVRR)results for the cases includingthe new wind and transmission projects.Using
the given example,the "PaR Stochastic Mean"present value of revenue requirements
differential (PVRR(d))for the Low Gas,Zero CO2 case is a net cost of $77 million.
This is linked by formula to the "Price-Policy Annual -PaR"worksheet,cell C868,
and correctly reflects the adjusted "Cost of Projects".Without this adjustment,the
"PaR Stochastic Mean"PVRR(d)for the Low Gas,Zero CO2 case would have
incorrectlyreported a $56 million benefit,as calculated based on the raw PVRR
values reported in the "Risk Adjustment"worksheet.The Table 2 values are therefore
correct.
Note:as this was a fixed cost adjustment,model results (includingportfolio
optimization)were not affected in any way,and the correction is accurately
represented as a top-side adjustment to the final PVRR(d).
This adjustment was not necessary in the Company's supplemental direct and rebuttal
testimony results as the full "Cost of Projects"was captured in the initial model
inputs.This allows the final PVRR(d)to be calculated accuratelybased on either the
Price-Policy Annual results or the PVRR outcomes reported in the "Risk Adjustment"
worksheet.
17-035-40 /Rocky Mountain Power
February 2,2018
OCS Data Request 10.13
OCS Data Request 10.13
Transmission Capacity.With regard to transmission interfaces modeled in SO or PaR:
(a)Please provide a table showing transmission interfaces and corresponding transfer
limits.For any transfer limits that changed as a result of transmission upgrades,
provide the transfer limits before and after the transmission upgrades.Provide this
table to compare what the limits were as modeled in the IRP,as modeled in direct
testimony analyses,and as modeled in rebuttal testimony analyses.If there are any
differences in the limits that were modeled in PaR vs SO,please provide a
comparison of those differences.
(b)Please provide a topology map showing all transmission connections,as modeled in
the IRP,the direct testimony and rebuttal testimony.If the only difference was in the
limits supplied in response to the previous question,justprovide one topology map,
or provide a reference to where this may be found,if this has already been supplied.
Response to OCS Data Request 10.13
(a)In lieu of a table,please refer to Confidential Attachment 10.13,which combines
transmission path ratings with the IntegratedResource Plan (IRP)transmission model
topology.In the attachment,page 2 presents the topology and path ratings with 2017
IRP assumptions.Page 2 presents the topology with the Company's direct testimony
assumptions for the base cases.Page 3 presents the Company's direct testimony
topology for cases includingthe new Wyomingtransmission project.The topology
and path ratings are the same for the system optimizer model (SO model)and the
planning and risk (PaR)model,and remain the same in the Company's supplemental
and rebuttal filing.
(b)Please refer to the response to subpart (a)above.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.