20180307PAC to Staff UT OCS Set 12 (1-21).pdf

1407 W.NorthTemple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A D1VISION OF PACIFICORP
February 21,2018
Béla Vastag
Office of Consumer Services
160 East 300 South
Salt Lake City,Utah 84111
b_vastag@utah_.go_v (C)
RE:UT Docket No.17-035-40
OCS 12th Set Data Request (1-21)
Please find enclosed Rocky Mountain Power's Responses to OCS 12th Set Data Requests 12.1-
12.21,excluding OCS 12.16 and 12.21.The responses to OCS 12.16 and 12.21 will be provided
separately.Also provided are Attachments OCS 12.1 and 12.7.Provided on the enclosed
Confidential CD are Confidential Responses OCS 12.1-12.6,12.13,and 12.15 and Confidential
Attachments OCS 12.8,12.10,and 12.15.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].
S
Jana Saba
Manager,Regulation
Enclosures
C.c.Erika Tedder/DPU [e-mail]@utah.gov(C)
Dan Kohler/DPU [e-mail](C)
Dan Peaco/DPU dpeaco daymarkea.com (C)(W)
Aliea Afnan/DPU [e-mail] (W)
[e-mail] (W)
Philip Hayet/OCS [e-mail] (C)
Gary A.Dodge/UAE [e-mail](C)
Phillip Russell/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 21,2018
OCS Data Request 12.1
OCS Data Request 12.1
CONFIDENTIAL REQUEST-Refer to Mr.Link's testimony at line 172,in which he
states that there is a transmission customer in the interconnection queue with an executed
interconnection agreement for a 240 MW QF in the area,and the Conapany had to reserve
capacity for that transmission customer.The Company stated that it "restricted new wind
resource bids in eastern Wyoming to 1,030 MW (1,270 MW less 240 MW)."
(a)Please identify the name and Queue Request number of the 240 MW QF and provide
a copy of the executed interconnection agreement.
(b)Please provide copies of the latest Interconnection Feasibility Study,System Impact
Study,Interconnection Facilities Study,and Engineering and Procurement
Agreements that may exist for the 240 MW QF.
(c)Please explain in more detail what was unique that the Company had to reserve
capacity for that transmission customer.
(d)Refer to Mr.Teply's Exhibit CAT-2SD-14,containing TB Flats 1 and II Large
Generator Interconnection Facilities Study Reports
Please explain in detail all of the ramifications of
being included in the lists found on these pages,and explain the status of these
projects.
(e)
discussed at line 173 of Mr.Link's testimony?
(f)Explain the differences between the 240 MW QF and the
and explain
was not treated like the 240 MW resource that
Mr.Link discussed at line 173 of his testimony.In other words,why didn't the
Company restrict new wind resource bids in eastern Wyoming to
(1,030 MW less
Response to OCS Data Request 12.1
(a)The project referred to in Mr.Link's testimony is Q0542.The 240 megawatt (MW)
qualifyingfacility (QF)project has been split into three 80 MW phases known as
Pryor Caves Wind (Q0542A),Mud Springs Wind (Q0542B)and Horse Thief Wind
(Q0542C).Please refer to the Company's response to OCS Data Request 10.12,
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.1
specifically Confidential Attachment OCS 10.12.
(b)Please refer to Attachment OCS 12.1.
(c)This interconnection customer has an executed interconnection agreement that does
not require Energy Gatewayinvestments.To honor this agreement,PacifiCorp must
reserve sufficient interconnection capacity for this interconnection customer.
(d)Projects listed in the "Higher Priority Requests"section of the TB Flats I and II
reports are either transmission service requests or generation interconnection requests
that are higher in the queue than the studied project.This means that,in accordance
with the open access transmission tariff,PacifiCorp transmission assumed that the
higher-priorityrequests (and any associated interconnection requirements)were in-
service when it studied the TB Flats I and II interconnection requests.Please refer to
the Open Access Same-Time Information System (OASIS)for the current status of
any of the higher-priorityrequests listed in the TB Flats I and II study reports:
http://www.oasis.oati.com/PPW/PPWdocs/pacificorpleiaq.htm
(e)Yes.
(f)Please refer to the Company's response to DPU Data Request 13.11.The 320 MW
project used as a proxy resource in the Company's original economic analysis.The
320 MW project has an executed interconnection agreement that requires Energy
Gateway investments beyond the Aeolus-to-Bridger/AnticlineD.2 segment.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.2
OCS Data Request 12.2
1SD-10):
(a)
(b)
Re-Study Report results during the period of
(c)Explain the usefulness/validity of the System Impact Re-Study Report results if in
fact the
(d)Explain why the System Impact Re-Study Report cautions that the results are
.Please be sure to fully explain the quote.
Response to OCS Data Request 12.2
(a)In accordance with PacifiCorp's open access transmission tariff,PacifiCorp
transmission must study interconnection requests in serial-queue order,with each
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.2
study assuming earlier-queuedprojects (and any associated interconnection
requirements)are in-service for purposes of the studied project's report.In light of
the earlier queued requests assumed in-service before the Cedar Springs project,the
initial September 30,2016 Cedar Springs study determined that a new customer-
constructed and customer-funded transmission line would be required to interconnect
the project.Review of the initial study results with the customer resulted,however,
in a determination that a more viable solution would be for PacifiCorp transmission to
assume completion of the company's long-term transmission expansion plan (i.e.,
Energy Gateway projects)to support interconnection.Additionally,during the re-
study process,a number of higher-queuedprojects were removed from the queue,
which also drove the need for a re-study.
(b)Please refer to the Company's response to subpart (a)above.
(c)The most current interconnection study report for Cedar Springs does not require
Energy Gateway West and Gateway South for the Cedar Springs project to be able to
secure interconnection service,so a delay in construction of Gateway West and
Gateway South would not affect the project's current interconnection requirements.
(d)On page 2 of the system impact re-study report,January 1,2021,is listed as the
requested commercial operation date (COD)from the project developer.The quoted
statement clarifies that the transmission expansion projects identified as necessary for
the project to secure interconnection (i.e.,the Energy Gatewayprojects listed in the
referenced study report)were not planned to be in-service until after the project
developer's requested commercial operation date.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.3
OCS Data Request 12.3
CONFIDENTIAL REQUEST-Further regarding the
Cedar Springs System Impact Re-
Study Report.
(a)Explain this statement,found in Section 5.0-Study Assumptions,in detail and explain
(b)Please reconcile this statement found in Section 8.0-Schedule,
Response to OCS Data Request 12.3
(a)Power flow analysis requires Western Electricity Coordinating Council (WECC)
base cases to reliablybalance under peak load conditions the aggregate of
generationin the local area,with the Large Generating Facility at full output,to
the aggregate of the load in the Transmission Provider's Transmission System.As
the PacifiCorp East (PACE)balancing authority area (BAA)has more existing
and proposed generationthan load,it is necessary to assume some portion of other
resources are displaced by this Project's output in order to assess the impact of
interconnecting this Project's generationto transmission system operations.For
the purposes of the Cedar Springs study,generationin the Transmission
Provider's southern Utah area was assumed to be displaced,not redispatched.
PacifiCorp transmission has since updated its standard interconnection study
language to be more accurate in this regard.
The Cedar Springs study did not address the impact of network resources in
southern Utah in regard to the Energy Gatewayprojects.
The Company's economic analysis is based on System Optimizer model (SO
model)and Planning and Risk (PaR)model system simulations with and without
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.3
the Combined Projects,which includes the referenced project.These simulations
account for how economic dispatch of all system resources is affected by the
Combined Projects.Specifically,system dispatch impacts are captured in the
change in net power costs (NPC)between the two simulations.
(b)System impact studies (SIS)provide a preliminaryschedule necessary to
implement interconnection work identified in the study.In the facilities study,a
construction project manager will be assigned and responsible for reviewing and
updating the schedule as necessary.A final schedule will be set forth in the
executed interconnection agreement.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.4
OCS Data Request 12.4
CONFIDENTIAL REQUEST-See the
that can be downloaded from PacifiCorp's OASIS.On page 15,the report indicates that
the Total
(a)Please compare these numbers to the transmission costs that were included in the
economic analysis based the Company's preferred wind portfolio.
(b)
.When will that analysis take place,and did PacifiCorp conduct any sensitivity
economic analysis considering substantially different transmission costs?If analyses
have been performed,please provide all work papers associated with those analyses.
(c)
When will the facilities study be completed,and when does the Company expect the
Interconnection Agreement to be completed.
(d)
to complete the development of the interconnection
facilities after signing the Interconnection Agreement,this project would not make
the December 2020 PTC deadline,and would not be eligible for PTC benefits?If
PacifiCorp does not believe this to be true,please explain how this project could still
be eligible for PTC benefits when the project could not even be interconnected to the
Grid?
(e)
.How has PacifiCorp taken this limitation into account
in its economic evaluation of this project?
Confidential Response to OCS Data Request 12.4
(a)In the economic analysis supporting the Company's January 16,2018 supplemental
direct and rebuttal filing,interconnection costs for the Cedar Springs project were
based on then-current information supplied by the bidder.That analysis assumed
direct-assigned interconnection costs of
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.4
.The costs
identified in the system-impact study (SIS)dated January 29,2018 were not available
when the Companymade its supplemental direct filing.
In the economic analysis supporting the Company's February 16,2018 second
supplemental filing,network-upgrade interconnection costs for the Cedar Springs
project were based on the costs identified in the SIS dated February 9,2018.That
analysis assumed direct-assigned interconnection costs of
(b)The field review of the distribution system occurs after the interconnection agreement
is signed.There are no economic studies performed in relationship to the
interconnection studies or interconnection agreement.
(c)The Company anticipates that the facilities study for this project will be complete in
the spring of2018 and the interconnection agreement to be executed in approximately
two months after the completion of the facilities study.
(d)Please refer to response to the Company's response to OCS Data Request 12.3
subpart (b).
(e)PacifiCorp plans to use its network transmission service rights to deliver this project's
power to network load,so it was unnecessary to adjust its economic evaluation of this
project based on the quoted language in the interconnection study.
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 21,2018
OCS Data Request 12.5
OCS Data Request 12.5
CONFIDENTIAL REQUEST--
Please provide the comparable cost that PacifiCorp assumed in its economic
evaluations in rebuttal testimony for these two units.
Confidential Response to OCS Data Request 12.5
In the Company's supplemental direct and rebuttal testimony,the Company assumed the
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 21,2018
OCS Data Request 12.6
OCS Data Request 12.6
CONFIDENTIAL REQUEST-
Does
PacifiCorp intend to update this study,and when does it expect the study results to be
available?
Confidential Response to OCS Data Request 12.6
The studies will not be updated.The studies were completed prior to the Company's plan
to construct the Aeolus-Bridger/AnticlineEnergy Gateway West segment D.2 by 2020.
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 21,2018
OCS Data Request 12.7
OCS Data Request 12.7
Please provide all transmission study reports for the Uinta project.If no reports are
currentlyavailable,please state when all of the reports will be developed.
Response to OCS Data Request 12.7
Please refer to Attachment OCS 12.7.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.8
OCS Data Request 12.8
Section IV of PacifiCorp's OATT covers Large Generator Interconnection Service and
discusses Queue Position associated with performing interconnection studies.
(a)For each Interconnection Study type discussed,provide a copy of all signed study
agreements that the McFadden Ridge II,TB Flats I and II,Cedar Springs,Uinta and
Ekola Flats projects have signed with PacifiCorp transmission.
(b)It has been reported that some solar project developers that have requested
interconnection studies have been required to wait longer than the expected amount of
time to have interconnection studies performed.Please provide a general explanation
of the reasons for these delays.
(c)Explain why it was permissible for PacifiCorp to expediteperforming the
interconnection studies for the wind projects that have been selected in the 2017R
RFP.
(d)What is the current status of signing and executing Interconnection Agreements with
each of the wind projects includingMcFadden Ridge II,TB Flats I and II,Cedar
Springs,Uinta and Ekola Flats?
(e)Will PacifiCorp be required to request FERC approval for these Interconnection
Agreements,and if so,when does PacifiCorp expect to submit and receive that
approval?
Response to OCS Data Request 12.8
(a)Please refer to Confidential Attachment OCS 12.8.
(b)PacifiCorp has recently received an unprecedented number of large generation
interconnection applications which has resulted in longer than normal timelines for
the provision of studies.Delays have affected all request types.
(c)PacifiCorp has not expeditedthe processing of interconnection studies for wind
projects participating in the 2017R Request for Proposals (2017R RFP).Rather,
PacifiCorp's transmission function issued system impact restudy reports as part of a
broader Open Access Transmission Tariff (OATT)restudy process.More
specifically,after the Company announced its plan to construct the Energy Gateway
Aeolus-to-Bridger/AnticlineD.2 segment to come online by 2020,the Company's
transmission function initiated an interconnection restudyprocess to ensure its
interconnection studies reflected the most current long-term transmission plan
assumptions.In accordance with its OATT,the Company's transmission function
performed restudies in serial queue order to determine whether the acceleration of
Energy Gateway segment D.2 would impact the cost or timing of interconnection of
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.8
projects that had not yet executed interconnection agreements and that had previous
studies dependingon Energy Gateway West in its entirety.PacifiCorp transmission
posted all of these system impact restudy reports,includingany performed for the
wind projects participating in the 2017R RFP,to the Open Access Same-Time
Information System (OASIS).
(d)All of the projects except Ekola Flats are still in the study phase.An interconnection
agreement was executed for the Ekola Flats projects November 27,2017.
(e)PacifiCorp anticipates that all of the projects will execute pro-forma standard Large
Generator Interconnection Agreements (LGIA)from PacifiCorp's OATT and will be
included as a line item in PacifiCorp's electronic filingto the Federal Energy
Regulatory Commission (FERC),but do not require a separate filing.
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 21,2018
OCS Data Request 12.9
OCS Data Request 12.9
Regarding the Solar Sensitivity that included the Combined Projects.
(a)In this sensitivity,were the wind bids (McFadden Ridge II,TB Flats I and II,Cedar
Springs,and Uinta)modeled as one combined option,or as separate options,such that
a subset of wind bids could have been selected in the least cost expansion plan for the
run?If not,please explain why not.
(b)Were the solar bids modeled as one combined option or as separate options,such that
a subset of solar options could have been selected in the least cost expansion plan for
the run?If not,please explain whynot.
(c)Does the Company believe that the SO model was setup to detennine the optimal
combination of any amount of eastern Wyoming wind,western Wyoming wind,solar,
and transmission upgrade and expansion costs,subject to constraints?If so,please
explain how the Company believes this was modeled,and if not,please explain why
the Company did not model this.
Response to OCS Data Request 12.9
(a)In the referenced sensitivity,the System Optimizer model (SO model)was allowed to
separately choose wind bids.The wind bids were not modeled as a combined option.
(b)In this sensitivity,the SO model was allowed to separately choose among solar bids.
The solar bids were not modeled as a combined option.
(c)Yes.No bids were forced.The model selected the least-cost portfolio of resources,
includingall available discrete bid options for Wyomingwind,western Wyoming
wind,and solar resources.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.10
OCS Data Request 12.10
Please provide a summary table that clearlyidentifies and describes the transmission
assumption,wind bid options,and solar bid options included for resource selection in the
model runs underlyingthe Solar Sensitivity results included in Link tables 4-SD and 5-SD.
Response to OCS Data Request 12.10
Please refer to Confidential Attachment 12.10,which provides a table summarizing
included transmission and bid options modeled in the Solar Sensitivity cases.
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 21,2018
OCS Data Request 12.11
OCS Data Request 12.11
Did the Company conduct an SO modeling study that excluded the Aeolis-to-
Bridger/Anticlinetransmission project and cost,but included wind AND solar bids,
which were allowed to be selected economically subject to transmission constraints.If
so,please identify this run and the bids allowed to be selected.If not,please explain why
not.
Response to OCS Data Request 12.11
No.The Company did not perform this study because none of the wind binds located in
the constrained area of the Company's transmission system in eastern Wyoming can
interconnect without the Aeolus-to-Bridger/Anticlinetransmission line.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.12
OCS Data Request 12.12
In the Sensitivity case with solar bids only that excluded the proposed 500 kV line and
the proposed new wind resources,did the Company allow any proxy wind options to be
modeled?If so,please explain how those options were setup in the SO model and
provide the $/kW cost of the proxy wind options.For example,did the Company allow
for wind resources in Western Wyoming,or Idaho,etc.?If not,please explain why not.
Response to OCS Data Request 12.12
Yes,except for the Wyoming wind proxy,which is assumed to be located behind the
TOT4A transmission constraint,the solar sensitivities allowed proxy wind resources to
be selected in Oregon,Washington,Idaho and Utah.The generic proxy resource options
available in the system optimizer model (SO model)are detailed in the Company's 2017
IntegratedResource Plan (IRP),specifically Chapter 6 (Resource Options),Table 6.1
(2017 Supply Side Resource Table)and Table 6.2 (Total Resource Cost for Supply-Side
Resource Options).The Company's 2017 IRP is publicly available and can be accessed
by utilizingthe followingwebsite link:
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.13
OCS Data Request 12.13
CONFIDENTIAL REQUEST-See Attach OCS 9.4.1 concerning the Transmission
Integration Cost Stated in 2016 $(column F).
(a)Provide the mput assumptions and calculations that were performed to derive the
values
and explain what these values represent.
(b)Provide the input assumptions and calculations that were performed to derive the
values
and explain what these values represent.
(c)The Company's response to OCS 9.4.a,states that the values referenced in OCS 9.4.1
were supplied from the IRP.Hasn't the Company updated transmission capital costs
for the Wyoming wind projects since the IRP?
(d)Has the Company updated any of the Solar transmission cost assumptions since the
IRP?If not why not,and if so,what updates have been performed?
Response to OCS Data Request 12.13
(a)No studies or calculations are performed in determining these values.The values are
based on high level review of existing knowledge of the transmission system and
possible infrastructure additions required to accommodate the megawatt (MW)
interconnections in an area of PacifiCorp's transmission system.Values are based on
the assumptions determined in the high level review and reflect current cost
information for infrastructure expected to be required.These values are expected to
be used for indications of costs associated with interconnection of a resource and are
not refined.Refinement of costs would occur in the generation interconnection study
phase.
(b)Please refer to the Company's response to subpart (a)above.
(c)The Company's response to OCS Data Request 9.4 subpart (a)explains the purpose
and function of the "Renewable Transmission Cost",as requested.The data provided
does not apply to bids received as part of the 2017 Renewable Request for Proposals
(2017R RFP),which incur transmission costs specific to each bid/project.
(d)The Companyhas updated solar cost assumptions since the 2017 IntegratedResource
Plan (IRP)based on bids received,with interconnection-network upgrade costs
estimated for each specific bid.Please refer to the Company's response to subpart (c)
above.
17-035-40/Rocky Mountain Power
February 21,2018
OCS Data Request 12.14
OCS Data Request 12.14
In OCS 9.5,the Company was asked to justify why it no longer desires to levelize PTC
costs in its to-2036 analysis.The Company's response references DPU 13.la,and states,
"PTC benefits will flow through to customers over the first 10 years of operation,and
unlike revenue requirement associated with capital,PTC benefits are not spread over the
30-year life of the wind assets."
(a)Admit or deny that in the Repowering Docket (17-035-39),in response to OCS 5.8a,
the Company stated the opposite.In other words,the Company stated,"Considering
that PTCs are a component of income taxes that are included in revenue requirement,
they are levelized over the life of the project in the same way that other components
of revenue requirement are levelized (i.e.,return on and return of investment)."
Please explain.
(b)Admit or deny that a declining revenue requirement stream used for ratemaking will
always provide a higher present value revenue requirement than the corresponding
revenue requirement stream computed using an economic carrying charge approach,
when considering a study period that is shorter than the life of the capital resource.If
the answer is anything other than admit,please explain.
(c)Please reconcile and fully explain the Company's current treatment of PTCs in this
docket with the Commission's January 23,2018 Order in Docket No.17-035-37
where the Commission stated:"...Because the PTC benefits associated with the 2021
Wyoming wind resources will be received in the first ten years of operation,
PacifiCorp now proposes to reflect these benefits over a ten-yearperiod.PacifiCorp
maintains this method reflects the actual timing of tax credit benefits.....We therefore
reject PacifiCorp's proposed removal of PTCs from the calculation of real levelized
avoided cost prices....deny PacifiCorp's proposal pertaining to the treatment of PTC
values in the calculation of avoided costs"
Response to OCS Data Request 12.14
(a)In prior responses,the Company included production tax credits (PTC)under the
broader umbrella of income taxes as a component of revenue requirement.The
Company has subsequently recognized the actual timing of PTCs as an annual tax
credit benefit.This change was in part needed to more accuratelyreflect the
difference in how build-transfer agreement (BTA)bids and benchmark bids are
expected to impact customer rates relative to power-purchase agreement (PPA)bids.
The near-term annual accrual of PTCs is a material competitive distinction between
BTA versus PPA bids.
(b)The Company confirms that the present value of nominal revenue requirement is
greater than the present value of levelized revenue requirement for initial capital
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.14
expenditures when calculated over a term (i.e.,a study period)that is shorter than the
life of the capital resource.
(c)The referenced order from Docket 17-035-37 pertains to the methodology for
calculating avoided cost prices for qualifying facilities (QF)in Utah.The order does
not address bid evaluation and selection from the 2017 Renewable Request for
Proposals (2017R RFP)and it does not address how to assess customer benefits in the
current proceeding.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.15
OCS Data Request 12.15
CONFIDENTIAL REQUEST-Refer to the Company's response to OCS 10.3 and
Link supplemental/rebuttaltestimony,beginning at line 264.It appears that the
levelization of the PTC values impacts the SO resource selections,and the amount of
PTC costs captured in the SO and PaR to-2036 study results.
(a)Please supplement the infonnation provided to include inputwork papers,revenue
requirement models,the alternative SO modeling run summary files,and study results
through 2036 and 2050.
(b)Did the Company also perfonn alternative sensitivity cases to those cases reported in
Link Tables 4-SD and 5-SD that included wind bids modeled with levelized PTCs?If
such studies were not perfonned,please explain how the Company is confident that
the PTC modeling has not biased any resource selections in the Solar Sensitivity
study cases.
(c)If no study in part b above was performed,how can the Company be certain that just
because a PTC sensitivity was performed for the wind bid only cases,there would be
no bias against solar PPAs in favor of wind BTAs by using nominal PTCs?
(d)Please admit that contrary to the Company's representation that the attachment to
DPU 13.lc provides "a calculation of the impact of the change in treatment
methodology",the analysis provided only accounts for the impact of value of the
PTCs,and not the impact of the change in portfolio selection performed in the SO
model.
Response to OCS Data Request 12.15
(a)The study results for 2037 through 2050 are forecasted and not from the system
optimizer (SO)model run.Please refer to the Company's response to OCS Data
Request 10.3,specifically Confidential Attachment OCS 10.3,file "2017R RFP IE
Sensitivit 2018-01-14 CONF".
Please also refer to the confidential work papers supporting the supplemental direct
and rebuttal testimony of Company witness,Rick T.Link,specifically folder "SO
Summary reports",files "SO Portfolio R17-Base-MM 1712300840.xlsm",and "SO
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.15
Portfolio R17-WFSL-MM 1801121945.xlsm".In addition,please refer to
Confidential Attachment OCS 12.15,which provides the "I.E.SO Portfolio
Summary"file "SO Portfolio R17-WFLP-MM_1801131530".
Due to the ongoing nature of the 2017 Renewable Request for Proposals (2017R
RFP),the financial models associated with the 20 17R RFP that contain the derivation
of inputs used in the SO model and the planning and risk (PaR)model are considered
commercially sensitive and highly confidential.The Company does not typically
permit access to commercially sensitive 2017R RFP documentationuntil the RFP has
been concluded.Please contact Jana Saba at [phone] or Yvonne Hogle at
[phone] to make arrangements for review.
(b)The solar sensitivity studies clearly demonstrate that the change in production tax
credit (PTC)treatment has no impact on solar bid selection.The solar bids selected in
each price-policy scenario includingwind bids is identical to the solar bid selections
in the corresponding cases where no wind bids were modeled.Please refer to the
confidential work papers supporting Mr.Link's supplemental direct and rebuttal
testimony,specifically the "Portfolio"worksheet of the followingfiles in the "SO
Summary Reports"folder:
File:SO Portfolio Rl7-SenSR-LN 1801041258.xlsm
File:SO Portfolio Rl7-SenWS-LN 1801122014.xlsm
File:SO Portfolio R17-SenSR-MM 1801041306.xlsm
File:SO Portfolio Rl7-SenWS-MM 1801122015.xlsm
(c)Please refer to the Company's response to subpart (b)above.
(d)DPU Data Request 13.1 subpart (c)did not request additional modeling,but rather
requested the impact on the calculation of benefits,which the Company's response to
DPU Data Request 13.1 and specifically Attachment DPU 13.1 directlyprovides.For
information regarding impacts on both bid selection and present value of revenue
requirements (PVRR),please refer to the Company's response to OCS Data Request
10.3,specifically Confidential Attachment OCS 10.3,page 18 of the "PDF"file.
Portfolio selection impacts are detailed in the third bullet point,and (benefit)/cost
impacts are presented in the two charts at the top of the page.
(e)Due to the ongoing nature of the 2017R RFP,the financial models associated with the
2017R RFP that contain the derivation of inputs used in the SO model and the PaR
model are 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 Jana Saba at [phone] or
Yvonne Hogle at [phone] to make arrangements for review.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.15
In addition,please refer to the Company's response to DPU Data Request 13.1,
specifically Confidential Attachment DPU 13.1,which isolates the impact of the
change in methodology on PTC benefits only without partial year adjustments as
noted by using a formula calculation instead of a goal-seek.Note:the worksheet label
in Confidential Attachment DPU 13.1,and the worksheet referenced in footnote 2 of
that worksheet are incorrect.The worksheet and the footnote should have identified
"PaR -RFP WFSL Studies"as the correct data source.
Confidential infornation 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 21,2018
OCS Data Request 12.17
OCS Data Request 12.17
Regarding the two transmission alternatives that the Company has proposed,the first
being the new 500 kV line,and the proposed 230 kV upgrades,and the second being the
Gateway Segment D2 230 kV Alternate.
(a)Please confirm that in the case of the first alternative,PacifiCorp will still need to rely
on remedial action schemes.If this is not the case,please explain.
(b)Please confirm that in the case of the second alternative,PacifiCorp will not need to
rely on remedial action schemes,as stated in DPU 12.6a.If this is not the case,
please explain.
(c)Why was the first alternative designed such that it still needed to rely on RAS,but the
second was designed such that it would not?Please explain.Couldn't the second
alternative have been designed more inexpensively to also rely on RAS?
(d)What is the benefit that could be attributed to the second alternative for avoiding the
reliance on RAS schemes?
Response to OCS Data Request 12.17
(a)For the Energy Gateway West -Subsegment D.2 Project (Bridger/Anticline-
Aeolus)500 kilovolt (kV)project,a remedial action scheme (RAS)will be required
to trip up to 640 megawatts (MW)of southeast Wyoming generation for loss of
transmission facilities between Bridger and Aeolus.
(b)For the proposed 230 kV alternative,which evaluated the retirement of the Dave
Johnston power plant and did not include D.2 Project 500 kV facilities,no RAS will
be required.
(c)As part of the analysis for the 500 kV and the 230 kV transmission alternatives,the
utilization of RAS were assumed during the studies.However,for the 230 kV
alternative as generation resources were added to the model and corresponding
transmission facilities were included in the model -the last transmission facility
added resulted in a topology solution that mitigated the need for a RAS.Therefore,
the 230 kV alternative did not include a RAS in the plan-of-service.
(d)Please refer to the Company's response to subpart (c)above.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.18
OCS Data Request 12.18
Refer to lines 261 to 284 of Mr.Vail's testimony.
(a)Mr.Vail states there is an independent need for the Aeolus-to-Bridger line to be built
by 2024 even if the new Wind Projects are not constructed.If this were true,why
didn't the Company include that assumption in its base case?In other words,why
didn't the Company assume in its base case that the new transmission projects would
be in service in 2024?
(b)See line 227,in which Mr.Vail states that the eastern Wyomingsystem is severely
restrained and experiences voltage-support issues.If the new Wind Projects are not
constructed,is it the Company's position that it would have to construct the Aeolus-
to-Bridger line by 2024 because of the existing severely restrained conditions and the
voltage-support issues?If so,wouldn't that mean that NERC reliability criteria are
being or are expected to be violated even without adding the new wind units?
(c)Please be clear to explain if PacifiCorp's need to add the new transmission is driven
by adding the new wind,or if PacifiCorp's position is now that the Company would
add the new transmission even if it did not add new wind,as Mr.Vail stated at lines
261 -271.
Response to OCS Data Request 12.18
(a)Western Electricity Coordinating Council (WECC)base cases representing the 2024
or later time period include Energy Gateway South and Energy Gateway West.The
Energy Gateway West -segment D.2 (Aeolus to Anticline/Bridger)project is a
subset of the Energy Gateway West -Segment D included in the WECC base case.
As a result of advancing the D.2 Project facilities from the 2024 time period to 2020,
the segment is not included as a standalone project in the WECC base case.The
segment will be submitted to WECC for inclusion in the next base case update.
(b)The southeastern area of Wyomingis prone to voltage fluctuations,which is a
function of the large amount of existing generationin the area and lack of
transmission,which can be exacerbated by the addition of new generation.There
have been no voltage or frequency deviations that fall outside of WECC or North
American Electric ReliabilityCorporation (NERC)criteria since the items approved
in Docket 20000-428-EA-13 were placed into service.The needs for the project are
summarized in the Company's response to subpart (c)below.
(c)Independentof the Project providing support for the integration of new wind
generationresources,addition of the Project will provide multiplebenefits to the
existing Wyomingtransmission system,including:
The Projects will strengthen the overall reliability of the existing transmission
system by providing critical voltage support to the Wyomingtransmission
network.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.18
The addition of new transmission lines will mitigate the impact of outages on the
existing system,and will increase the system reliability under the various multiple
contingencies of the TPL-001-4 standard.
In the event of a line outage,the redundancyprovided by the Project will allow
the Company to continue to meet native load service obligations and continue to
meet other contractual obligations to third parties.
The Projects will improve the Company's ability to perform required maintenance
without significant operational impacts to the system,and will reduce impacts to
customers during planned and forced system outages.
In addition to reliabilitybenefits,the Projects will also:
-Increase the transfer capability across Wyoming by at least 900 megawatts
(MW)and enable additional interconnections,includingof the proposed Wind
Projects;
-Provide greater flexibilityin managing existing resources and reduce energy
and capacity losses;and
-Support the long-term transmission expansion planning established in the
most recent Northern Tier Transmission Group sub-regionalplan.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.19
OCS Data Request 12.19
Refer to UAE 3.1 in the Utah Docket 17-035-39 (Repowering).Please provide a similar
step change analysis comparing the impact of assumption changes fiom the analysis
provided in direct testimony to the analysis provided in rebuttal testimony.Please
provide information reconciling the medium natural gas,medium CO2 price-policycases
provided in Link Table 2 to Table 2-SD as well as Link Table 3 to Table 3-SD in this 17-
035-40 docket.
Response to OCS Data Request 12.19
The Company has not performed a series of incremental step-change evaluations for the
Company's supplemental direct and rebuttal testimony.
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.20
OCS Data Request 12.20
Refer to OCS 10.11.Please supplement the table provided in part d with additional
explanation.
(a)Explainthe purpose of the "Wyoming IRP Wind Options (2021)"and the reason a
change in modeling was made to go from a 300 MW resource in direct testimony to a
239 MW PPA in rebuttal testimony?
(b)Please explain the "Transmission Reliability Derate"that is modeled in rebuttal,but
not direct.Please explain if this is to correct the error(s)identified and described in
OCS 5.2.
(c)Please explain the purpose of the Contract Update Post 2017 IRP item,and explain
what changed between the IRP and direct testimony.
(d)For any items in this table that were characterized as being the same in direct and
rebuttal,please confirm that they were not only modeled in both cases,but that they
were modeled the identical way in both cases.
Response to OCS Data Request 12.20
(a)The table row labeled as "Wyoming IRP Wind Options (2021)"reports the assumed
interconnection limit behind the TOT4A constraint in the absence of the Aeolus-to-
Bridger/Anticlinetransmission project.In the 2017 Integrated Resource Plan (IRP),
as well as in the Company's direct testimony,Wyoming wind resources behind the
TOT 4A constraint were limited to 300 megawatts (MW)in cases without the Energy
Gateway transmission project.This limit was based on a review of interconnection
studies for wind projects in the interconnection queue,which indicated that
approximately 240 MW of new wind could be interconnected.These studies indicate
that once approximately 240 MW of generation is interconnectedbehind the TOT 4A
constraint,no further interconnections are possible.Any additional projects would be
lower in the interconnection queue and require incremental transmission investment.
For planning purposes,the Company used 300 MW as a simplifying assumption
recognizing that the interconnection queue is dynamic.Generator-interconnection
customers can change project details,request commercial operation date (COD)
extensions or suspensions,or even withdraw from the queue altogether.This
distinction is also made in the 2017 IRP.Please refer to Volume I of PacifiCorp's
2017 IRP,Chapter 4 (Transmission Planning),page 62.The Company's 2017 IRP is
publicly available and can be accessed by utilizingthe followingwebsite link:
http://www.pacificorp.com/es/irp.html
In the Company's supplemental direct and rebuttal testimony,the Company restricted
new wind resource bids in eastern Wyomingto 1,030 MW (1,270 MW less 240 MW)
17-035-40 /Rocky Mountain Power
February 21,2018
OCS Data Request 12.20
in consideration of an customer in the current interconnection queue with an executed
interconnection agreement governing a 240 MW qualifyingfacility (QF)
interconnection in the constrained area and not requiring the construction of Energy
Gateway for interconnection purposes.As the Company has transitioned from
planning and proxy assumptions used in the 2017 IRP and in direct testimony,these
planning and proxy assumptions have been updated to reflect the most current
conditions,includingthe current interconnection queue.Note:while the 239 MW
figure cited in the table provided with the Company's response to OCS Data Request
10.11 subpart (d)is accurate for the QF's capacity,the number has been rounded to
240 MW in discussion as it coincides with the estimated 240 MW interconnection
limit.
(b)The transmission derate is described in the 2017 IRP Volume I,Chapter 8 (Modeling
and Portfolio Selection Results),page 221.
The transmission reliability derate was intended to be included in both the Company's
direct testimony modeling,and the Company's supplemental direct and rebuttal
testimony modeling for those cases includingthe Aeolus-to-Bridger/Anticline
transmission project.The inclusion of this derate in the Company's supplemental
direct and rebuttal testimony modeling corrects the oversight explained in the
Company's response to OCS Data Request 5.2.
(c)A new Wyoming320 MW QF power purchase agreement (PPA)used as a proxy for
a new wind resource in the constrained area of PacifiCorp's transmission system in
eastern Wyoming,and a 3 MW QF in Utah were added into the Company's direct
testimony.In addition,new information was received on planned solar PPA start
dates,which were also added into the Company's direct testimony.
(d)There are four rows in the table provided with the Company's response to OCS Data
Request 10.11 subpart (d)that are listed with the same response between the direct
testimony,and the supplemental direct and rebuttal testimony columns of the table.
(1)"IRP Solar Options"are identical between the direct testimony,and the
supplemental direct and rebuttal testimony base cases,and is provided in the
Company's 2017 IRP,specifically Chapter 6 (Resource Options),Table 6.1 and
6.2.
(2)"EIM (Modeled)"refers to the modeling of energy imbalance market (EIM)
transmission benefits described in the direct testimony of Company witness,Rick
T.Link,specifically lines 576 through 591.This modeling did not change
between the Company's direct testimony,and the Company's supplemental direct
and rebuttal testimony filings.
(3)"Carbon Dioxide (CO2)Emissions"prices were included in both the direct
testimony,and the supplementaldirect and rebuttal testimony models,but updated
17-035-40/Rocky Mountain Power
February 21,2018
OCS Data Request 12.20
between filings.The CO2 pTICO RSsumptions used in the updated economic
analysis were inadvertentlymodeled in 2012 real dollars instead of nominal
dollars.Consequently,the present value of revenue requirements differential
(PVRR(d))net benefits in the six price-policy scenarios that use medium and high
price assumptions are conservative.
(4)"Contract Update Post 2017 IRP".Please refer to the Company's response to
subpart (c)above.