20180226PIIC 21-42 to PAC.pdf

WILLIAMS ·BRADBURY
ATTORNEYS AT LAW
February 26,2018
Ms.Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W.Washington 5 i
Boise,ID 83702
Re:PAC-E-17-07
Dear Ms.Hanian:
Please find enclosed for filing the original and three copies of PacifiCorp Idaho
Industrial Customers'Fifth Production Request to Rocky Mountain Power in the above
referenced case.
Thank you for your assistance in this matter.Please feel free to give me a call should
you have any questions.
Sincerely,
Ronald L.Williams
RLW
Enclosures
P.O.Box 388 -Boise,ID 83701
Phone:[phone] -www.williamsbradbury.com
Ronald L.Williams,ISB No.3034
P.O.Box 388,802 W.Bannock Street,Suite 900
Boise,ID 83702
Telephone:[phone]
Email:ron @ williamsbradbury.com
Attorneys for PacifiCorp Idaho Industrial Customers
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION OF )Case No.PAC-E-17-07
ROCKY MOUNTAIN POWER FOR )
CERTIFICATES OF PUBLIC CONVENIENCE )FIFTH PRODUCTION REQUESTOF
AND NECESSITY AND BINDING )PACIFICORP IDAHO INDUSTRIAL
RATEMAKING TREATMENT FOR WIND )CUSTOMERS TO ROCKY MOUNTAIN
AND TRANSMISSION FACILITIES )POWER
PacifiCorp Idaho Industrial Customers ("PIIC"),by and through its attorney of record
Ronald L.Williams and pursuant to the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission"),hereby requests that Rocky Mountain Power ("RMP")provide the
followingdocuments and information as soon as possible,and no later than March 19,2018.
This Production Request is continuing,and RMP is requested to provide,by way of
supplementaryresponses,additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question,and supporting work papers that provide detail
or are the source of information used in calculations.RMP is reminded that responses pursuant to
Commission Rules of Procedure must include the name and phone number of the person
preparing the document,and the name,location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be.IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
PIIC FIFTH PRODUCTIONREQUEST TO ROCKY MOUNTAIN POWER Page 1
REQUEST NO.21.Reference the Second SupplementalDirect Testimony of Rick T.
Link at 1:6-10:Please confirm that PacifiCorp did not prepare an updated resource needs
assessment when developing the referenced economic analysis?Please provide an explanation
for PacifiCorp's response.
REQUEST NO.22.Reference the Second SupplementalDirect Testimony of Rick T.
Link at 1:6-10:When performing the referenced analyses,did PacifiCorp update the cost of
supply side resources other than the Wind Projects to reflect the passage of the Tax Cuts and
Jobs Act,and/or any other changes that have occurred since its IRP was filed in 2017?
REQUEST NO.23.Reference the Second SupplementalDirect Testimony of Rick T.
Link at 3:When preparing the nominal and levelized revenue requirement calculations,what
assumptions did PacifiCorp make with respect to the termination of the Power Purchase
Agreement ("PPA")portion of Cedar Springs facility (i.e.did PacifiCorp assume that the PPA
portion would be renewed,and if so,at what price)?
REQUEST NO.24.Reference the Second SupplementalDirect Testimony of Rick T.
Link at 1:6-10:Do PacifiCorp's nominal or levelized revenue requirement analyses consider the
impacts of ongoing capital additions to,and replacements of,the proposed Aeolus-to-Bridger/
Anticline D.2 transmission facilities?If no,please explain why the cost of those ongoing capital
additions and replacements have been excluded?
REQUEST NO.25.Please provide a copy of PacifiCorp's most recently completed
depreciation study,along with the final rates by FERC account and sub-account that have been
approvedby the Idaho Public Utilities Commission.
REQUEST NO.26.Please provide PacifiCorp's most recently completed long-term
load forecast,with hourlyloads,and includingall time periods considered in the forecast.
PIIC FIFTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER Page 2
REQUEST NO.27.Reference the Rebuttal Testimony of Rick T.Link at 25:4-15:Mr.
Link states "In general,it is likelythat spot prices are somewhat systematically risky,because
demand for most commodities tends to move with the economy as a whole.Thus,it is unlikely
that the appropriate discount rate for taking the present value of expected spot prices will be the
risk-free rate that applies to discounting the forward price."
a.Does Mr.Link agree that,if one were to apply a higher discount rate for expected
spot prices than the risk-free discount rate applied to the forward price,as he
recommends,it would indicate that the expected spot price is lower than the
forward price?Please explain?
b.In Mr.Link's opinion,what interest rate would be most appropriately used to
determine the present value of the expected spot price?
c.Did PacifiCorp make any adjustment to the forward prices included in its
economic analysis to account for the higher interest rate applicable to expected
spot market prices,as Mr.Link identifies in the referenced testimony?If no,
please explain why the PacifiCorp has not made this adjustment.
REQUEST NO.28.Reference the Rebuttal Testimony of Rick T.Link at 25:22-26:4:
Mr.Link states "Mr.Mullins'position here is contradicted by his testimony before the Oregon
Commission earlier this year."
a.Please provide a citation for Mr.Link's characterization of Mr.Mullins testimony
in the above quotation?
b.Did Mr.Link testifyin Oregon Public Utility Commission ("OPUC")Docket No.
UE 323?
c.Is Mr.Link aware that in OPUC Docket No.UE 323,Mr.Mullins testified as
follows?
"The difference in actual versus modeled benefit of known short-term
firm amounts might be (as the Company implies)a hedging benefit,or
a premium,embedded in forward price curves.The Company,however,
did not present any empirical analysis to support its theory,nor have I
undertaken extensive study of the matter,other than measuring the
historical benefits of the >7 Day Transactions.In the past,however,I
have observed significant forward premiums in gas prices,so it would
not surprise me if the historical benefits are a sort of hedging benefit,
driven by risk premiums embedded in forward prices."
PIIC FIFTH PRODUCTIONREQUEST TO ROCKY MOUNTAIN POWER Page 3
d.Does Mr.Link agree or disagree that the above testimony of Mr.Mullins
referenced above is consistent with Mr.Link's analysis in this matter?
e.Has Mr.Link reviewed the Day-Ahead /Real-Time system balancing adjustment
that was discussed in OPUC Docket No.UE 323?
f.Do the economic analyses Mr.Link performed in this matter include the Day-
Ahead /Real-Time modeling adjustments that were at issue in Docket No.UE
323?If no,please explain why those purported costs were excluded?
g.Does PacifiCorp expect the new Wind Projects to impact the cost of Day-Ahead /
Real Time system balancing?Please explain and provide PacifiCorp's best
estimate of the impact of the Wind Projects on the cost of Day-Ahead /Real Time
system balancing.
REQUEST NO.29.Reference the Rebuttal Testimony of Rick T.Link at 27:17-28:l:
Mr.Link states that "[t]he GRID studies and assumptions referred to by Mr.Mullins were used
in the 2017 IRP,but not in the economic analysis included in this case."
a.Does PacifiCorp agree that,in preparing the economic analyses identified in the
Second SupplementalDirect Testimony of Rick T.Link,it has incorporated the
adjustments underlying the referenced supplemental GRID studies into the
System Optimizer and Planning and Risk models?
b.On what basis,if any,does PacifiCorp conclude that the impacts of the
adjustments underlying the supplemental GRID studies have changed materially
after being incorporated into System Optimizer and Planning and Risk models?
Please provide all studies showing what PacifiCorp believes the impact of those
adjustments to be when incorporated into the System Optimizer and Planning and
Risk models.
c.Does PacifiCorp's economic analysis identified in the Second Supplemental
Direct Testimony of Rick T.Link still include an assumption where the transfer
capability between Jim Bridger and Walla Walla is increased by 300 MW
corresponding to growing participation in the Energy Imbalance Market ("EIM")?
If yes,please provide PacifiCorp's best estimate of the impact of this assumption
on the medium gas and medium CO2 scenario.If no,please explain.
d.Does PacifiCorp's economic analysis identified in the Second Supplemental
Direct Testimony of Rick T.Link still include an assumption where the Wyoming
loads are reduced to account for purported line loss benefits of the Transmission
projects?If yes,please provide PacifiCorp's best estimate of the impact of this
assumption on the medium gas and medium CO2 scenario.If no,please explain?
PIIC FIFTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER Page 4
e.Does PacifiCorp's economic analysis identified in the Second Supplemental
Direct Testimony of Rick T.Link still include an assumption to account for
reduced de-rates associated with constructing Gateway segment D2?If yes,
please provide PacifiCorp's best estimate of the impact of this assumption on the
medium gas and medium CO2 scenario.If no,please explain.
REQUEST NO.30.Is PacifiCorp required to submit independently balanced EIM Base
Schedules for PACE and PACW balancing area pursuant to the CAISO's EIM tariff or
PacifiCorp Transmission's EIM tariff?If yes,please provide a citation to the tariff
corresponding to the requirement.If no,please explain how the EIM base schedules are
determined for the respective balancing areas.
REQUEST NO.31.Does the EIM provide PacifiCorp with the ability to schedule firm
energy between balancing areas in an amount exceeding the firm transmission rights that
PacifiCorp possesses between the two balancing areas?If yes,please explain,with references to
specific tariff provision,how transfers of such firm energy transfers may be accomplished.
REQUEST NO.32.Please identify the all scheduling information that PacifiCorp
submits to the CAISO on an hour-ahead basis.
REQUEST NO.33.Please provide a sample of the EIM Base Schedules that
PacifiCorp submitted to the CAISO,includingthe most granular level of load and resource data
available,corresponding to the followinghours:
a.June 26,2017,HE 1700.
b.January 16,2017,HE 800.
c.November 30,2016,HE 800.
d.July 28,2016,HE 1700.
REQUEST NO.34.Please provide uninstructed imbalance charges for the following
wind facilities on a monthlybasis (or the greatest level of granularityavailable)over the period
January 1,2015 through June 30,2017:
a.Glenrock
PIIC FIFTH PRODUCTIONREQUEST TO ROCKY MOUNTAIN POWER Page 5
b.Glenrock III
c.Foote Creek
d.McFadden Ridge
e.Seven Mile Wind
f.Seven Mile II Wind
g.Top of the World Wind
h.Dunlap Wind
i.High Plains Wind
j.Mountain Wind I
k.Mountain Wind II
1.Rock River I
m.RollingHills Wind
REQUEST NO.35.Please provide the 5 and 15 minute uninstructed imbalance
associated with the followingwind facilities over the period July 1,2016 through June 30,2017:
h.Dunlap Wind
i.McFadden Ridge
j.Top of the World Wind
REQUEST NO.36.For each PNode in PacifiCorp's PACE and PACW balancing area,
please provide 5-and 15-minutedEIM prices over the period July 1,2016 through June 30,
2017.
REQUEST NO.37.Please identify the date that PacifiCorp issued the forward price
curve used in the revenue requirement analyses in the Second Supplemental Direct Testimony of
Rick T.Link.
REQUEST NO.38.Please identify and provide all long-term natural gas price
forecasts that PacifiCorp has received through a third-partysubscription service over the period
January 1,2018 through the present.
REQUEST NO.39.Reference the Rebuttal Testimony of Rick V.Vail at 27:15-16:
Mr.Vail states that "[t]he 12 percent figure represents the current level of ATRR funded by
OATT customers."
PIIC FIFTH PRODUCTIONREQUEST TO ROCKY MOUNTAIN POWER Page 6
a.Please confirm that PacifiCorp assumed that the proportion of ATRR funded by retail
customers will not increase as a result of acquiring the Wind Projects and
Transmission Projects?If no,please explain.
b.Please explain how PacifiCorp Transmission ATRR costs are allocated between
Network Integration Transmission Service and Point-to-Point transmission
customers?
c.Please identify billingdeterminants used for Network Integration Transmission
Service and Point-to-Point transmission customers,and explain why the billing
determinants are appropriately used for the respective services?
d.Please identify the transmission service PacifiCorp plans to use with respect to the
Wind Projects (i.e.Network Integration Transmission Service or Point-to-Point
Transmission Services).
e.Pursuant to its OATT,is PacifiCorp allowed to designate front office transactions as a
network resource?If no,please explain why not,and identify the transmission service
used to deliver front office transactions to load?
f.Does PacifiCorp intend to terminate any Point-to-Point transmission rights,in the
event that the Transmission Projects and Wind Projects are constructed?If yes,
please identify each reservation,which PacifiCorp intends to terminate.
g.Please explain how PacifiCorp loads served by Point-to-Point transmission are
considered in the determination of PacifiCorp's MonthlyNetwork Load for purposes
of PacifiCorp's Network Integration Transmission Services.
h.Does PacifiCorp agree that its Monthly Network Load will increase if the
Transmission Projects and Wind Projects are constructed due to the fact that a greater
portion of its load will be served by Network Resources (i.e.the Wind Projects),
rather than through Point-to-Point transmission (i.e.Front Office Transactions).If
no,please explain.
i.Does PacifiCorp agree that,if its MonthlyNetwork Load were to increase as a result
of constructing the Transmission Projects and Wind Projects,and assuming no
changes to reserved Point-to-Point transmission rights,that the proportion of ATRR
funded by retail customers would also increase?If no,please explain.
REQUEST NO.40.Please provide an explanation for any assumptions PacifiCorp has
made with respect to the terminal value of the Wind Projects in the economic analyses identified
in Second SupplementalDirect Testimony of Rick T.Link.
PIIC FIFTH PRODUCTIONREQUEST TO ROCKY MOUNTAIN POWER Page 7
REQUEST NO.41.To the extent that terminal values were included in the economic
analysis identified in Second SupplementalDirect Testimony of Rick T.Link,please provide a
narrative explanation of the methodology used to develop the terminal value and provide
workpapers supporting the calculation of the terminal value amount for each Wind Project
included in the short list.
REQUEST NO.42.Has PacifiCorp identified any terminal costs,such as
decommissioning costs,associated with the Wind Projects or Transmission Projects?If yes,
please explain how those additional terminal costs are considered in PacifiCorp's analysis.
DATED at Boise,Idaho,this 26 day of February,2018.
Respectfully submitted,
Ronald L.Williams
Williams Bradbury,P.C.
Attorneys for PacifiCorp Idaho Industrial Customers
PIIC FIFTH PRODUCTIONREQUEST TO ROCKY MOUNTAIN POWER Page 8
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 26th day of February ,2018,I caused to be served
a true and correct copy of the foregoing document upon the followingindividuals in the manner
indicated below:
Diane M.Hanian,Secretary Hand Delivery
Idaho Public Utilities Commission US Mail (postage prepaid)
P.O.Box 83702 Facsimile Transmission
472 W.Washington Street Federal Express
Boise,ID 83702-0074 Electronic Transmission
E-Mail:[e-mail]
Ted Weston .Hand DeliveryIdahoRegulatoryAffairsManager .US Mail (postage prepaid)Rocky Mountain Power ...Facsimile Transmission1407WestNorthTemple,Suite 330 Federal ExpressSaltLakeCity,UT 84116 ...
.Electronic TransmissionE-Mail:[e-mail]
Yvonne R.Hogle Hand DeliveryAssistantGeneralCounsel .US Mail (postage prepaid)Rocky Mountain Power ....Facsimile Transmission1407WestNorthTemple,Suite 320 Federal ExpressSaltLakeCity,UT 84116 ...
.Electromc TransmissionE-Mail:[e-mail]
Data Request Response Center .Hand DeliveryPacificCorpUSMail(postage prepaid)825 NE Multnomah,Suite 2000 -....L_Facsimile TransmissionPortland,OR 97232
.Federal ExpressE-Mail:[e-mail]
Electronic Transmission
Brandon Karpen .Hand DeliveryDeputyAttorneyGeneral .
..US Mail (postage prepaid)Idaho Public Utilities Commission Facsimile Transmission472W.Washington (83702)Federal ExpressPOBox83720
Boise,ID 83720 Electronic Transmission
Email:[e-mail]
Randall C.Budge Hand Delivery
Racine,Olson,Nye &Budge,Chtd.US Mail (postage prepaid)
201 E.Center Facsimile Transmission
PO Box 1391 Federal Express
Pocatello,ID 83204-1391 Electronic Transmission
E-Mail:[e-mail]
Attorney for Monsanto Company
PIIC FIFTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER Page 9
Brubaker &Associates O Hand Delivery16690SwingleyRidgeRoad,#140 US Mail (postage prepaid)Chesterfield,MO 63017
.Facsimile TransmissionE-Mail:[e-mail] Federal [e-mail] -..M Electronic TransmissionMonsantoCompany
Jim Duke O Hand DeliveryIdahoanFoodsOUSMail(postage prepaid)357 Constitution Way -U Facsimile TransmissionIdahoFalls,ID 83742 O Federal ExpressE-Mail:[e-mail] -G Electronic TransmissionPIIC
Kyle Williams Hand DeliveryBYUIdaho.
.US Mail (postage prepaid)Email:[e-mail] Facsimile TransmissionPIICFederalExpress
Electronic Transmission
Val Steiner Hand DeliveryNu-West Industries,Inc.O US Mail (postage prepaid)Email:[e-mail] -..O Facsimile TransmissionPIICFederalExpress
Electronic Transmission
Bradley Mullins .Hand Delivery333S.W.Taylor,St 400 US Mail (postage prepaid)Portland,OR 97204 Facsimile TransmissionEmail:[e-mail] Federal ExpressPIICElectronicTransmission
Eric L.Olsen O Hand DeliveryEchoHawk&Olsen PLLC US Mail (postage prepaid)505 Pershing Ave.,Suite 100 Facsimile TransmissionPOBox6119FederalExpressPocatello,ID 83205
Email:[e-mail] Electronic Transmission
Idaho Irrigation Pumpers Association
Anthony Yankel .Hand Dehvery12700LakeAvenue,Unit 2505 US Mail (postage prepaid)Lakewook,OH 44107 Facsimile TransmissionEmail:tony@ yankel.net Federal ExpressIdahoIrrigationPumpersAssociationElectronicTransmission
Ronald L.Williams
PIIC FIFTH PRODUCTIONREQUEST TO ROCKYMOUNTAIN POWER Page 10