20180307PAC to Staff UT OCS Set 11 (1-3) 2.pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PACIFICORP
February 19,2018
Béla Vastag
Office of Consumer Services
160 East 300 South
Salt Lake City,Utah 84111
bvastag@u_tah.gov (C)
RE:UT Docket No.17-035-40
OCS 1Ith Set Data Request (1-3)
Please find enclosed Rocky Mountain Power's Responses to OCS l lth Set Data Requests 11.2.
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 [e-mail] (W)
[e-mail] (W)
Philip Hayet/OCS [e-mail] (C)
Gary A.Dodge/UAE [e-mail] (C)
PhillipRussell/UAE [e-mail] (C)
Kevin Higgins/UAE [e-mail] (C)
Neal Townsend/UAE [e-mail](C)(W)
Kate Bowman/UCE [e-mail](C)
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 19,2018
OCS Data Request 11.2
OCS Data Request 11.2
At lines 18 and 19 of Mr.Link's January 16,2018 SupplementalDirect and Rebuttal
Testimony,he stated "The final shortlist includes four new wind projects located in
Wyoming from three different bidders."At lines 297 to 280 Mr.Link stated "The 2017R
RFP final shortlist includes four new wind projects located in Wyoming from three
different bidders".
(a)When did the Company discover that the final shortlist projects described in Mr.
Link's January 16 testimony may not be the actual final shortlist projects (i.e.that the
interconnection studies may result in "changes to the final shortlist"-as stated in the
Company's January 24 Response)?
(b)Referring to part a.above,what were the circumstances that lead the Company to
discover that the final shortlist projects as described in Mr.Link's January 16
testimony might not be the actual final shortlist projects?
Response to OCS Data Request 11.2
(a)The Company assumes that reference to the "January 24 Response"is in reference to
the Company's response to the motion to vacate the procedural schedule in this
docket.Based on the foregoing assumption,the Company responds as follows:
The Company has been aware that it would need to factor interconnection
requirements into its evaluation of the 2017 Renewable Request for Proposal (2017R
RFP)bids since the beginning of the RFP process.Indeed,the Company originally
included a completed interconnection system impact study (SIS)report as one of the
minimum bid-eligibilityrequirements.In response,however,to recommendations
from the Utah independentevaluators (IE),as supported by other parties in the 2017R
RFP approval process in Docket 17-035-23,the Company agreed to remove the
requirement that a bidder have a completed SIS to be eligible to submit a proposal.
While the removal of this requirementmeant that the Company could not fully
evaluate the relative interconnection requirements of the bids early on in the process,
it allowed a robust set of bidders to participate in the 2017R RFP without regard to
their position in the interconnection queue-a queue that can significantlychange
over time as,for example,generator interconnection customers change project details,
request commercial operation date (COD)extensions or suspension,or even
withdraw from the queue altogether.
In addition,after PacifiCorp announced its plan to construct the Energy Gateway
Aeolus-to-Bridger/AnticlineD.2 segment to come online by 2020,PacifiCorp's
transmission function initiated an interconnection restudy process to ensure its
interconnection studies reflected the most current long-term transmission plan
assumptions.In accordance with PacifiCorp's open access transmission tariff
(OATT),PacifiCorp's transmission function performed these restudies in serial queue
17-035-40 /Rocky Mountain Power
February 19,2018
OCS Data Request 11.2
order to determine whether the acceleration of Energy Gateway segment D.2 would
impact the cost or timing of interconnection of projects that had not yet executed
interconnection agreements and that had previous studies dependingon Energy
Gateway West in its entirety.
On January 15,2018,the Company notified the Oregon and Utah IEs that PacifiCorp
transmission's interconnection restudy process and resulting interconnection restudy
reports could impact the Company's evaluation of the original final shortlist to the
extent it affected a project's ability to secure an interconnection through PacifiCorp
transmission's OATT interconnection process.On January 19,2018,the Company
discussed this issue with the Oregon and Utah IEs,noting that the Company intended
to continue its due-diligence assessment of specific bids by monitoring this issue,but
that the implications of this restudy process would not be definitively known until
PacifiCorp transmission completed the restudy process and posted the resulting study
reports to the Open Access Same-Time Information System (OASIS).PacifiCorp
transmission posted the restudy reports to OASIS on January 29,2018,as well as
certain updated restudy reports on February 9,2018.
The restudy reports impacted the Company's evaluation of the original final shortlist
because they identified which projects in PacifiCorp transmission's generator
interconnection queue could secure an interconnection with only Energy Gateway
segment D.2 constructed,and which projects would need additional transmission
projects (e.g.,all of Energy Gateway West,Energy Gateway South,etc)constructed
justto interconnect.
(b)Please refer to the Company's response to subpart (a)above.