20180307PAC to Staff UT OCS Set 14 (1-6).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISiON OF PACIFICORP
March 1,2018
Béla Vastag
Office of Consumer Services
160 East 300 South
Salt Lake City,Utah 84111
bvastag@utahgov (C)
RE:UT Docket No.17-035-40
OCS 14th Set Data Request (1-6)
Please find enclosed Rocky Mountain Power's Responses to OCS 14th Set Data Requests 14.1-
14.6.Also provided is Confidential Response OCS 14.5.Confidential information is provided
subject to Public Service Commission of Utah 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 [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
March 1,2018
OCS Data Request 14.1
OCS Data Request 14.1
Refer to Exhibit RMP (JRS-2SS).
(a)Does the Company agree that if the Company files a base rate case using a test year
of 2021,under its proposal,the higher "Net Rate Base"amount on page 2,line 4
would be incorporated in the revenue requirements,all else being equal,and
customers would not receive the benefits of the reduced rate base amount for each
year thereafteruntil a future rate case that uses a test year of 2022 or later due to the
projects no longer being included in the proposed RTM once incorporated in base
rates (with the exception of the PTC impacts)?
(b)Considering page 1,Table 1,shows the highest revenue requirement impact for 2021,
which then declines each subsequent year,would the Company consider leaving the
projects in the proposed RTM mechanism after the next base rate case?If no,
explain,in detail,why not.
Response to OCS Data Request 14.1
(a)Yes
(b)No.The resource tracking mechanism (RTM)is intendedto be a short-term
mechanism to properly match the Combined Projects costs and benefits in the interim
period between project in-service and inclusion in rates through a general rate case.
The inclusion of the Combined Projects in base rates is consistent with other rate base
items that are not trued up on an annual basis after rate cases.
17-035-40/Rocky Mountain Power
March 1,2018
OCS Data Request 14.2
OCS Data Request 14.2
Refer to the SupplementalDirect Testimony of Joelle R.Steward in Docket No.17-035-
39,at page 4,figure 1.Also please refer to Exhibit RMP_(JRS-2SS)at page 1,Table 1
in this proceeding.Since the Company is proposing an RTM in both dockets,please
provide a revised version of the "Estimated Revenue Requirement Cost (Benefit)"for
each year,2019 through 2023,that includes both the "Combined Projects"at issue in this
docket and the Repowering projects at issue in Docket No.17-035-39.
Response to OCS Data Request 14.2
Please refer to the submitted work paper files "17-035-39 RMP WP-Steward-Exhibits
2SD-4SD 2-1-18"tab "Savings Summary",and "17-035-40 RMP WPs-Steward 2-16-18"
tab "JRS-2SS Page 1",for an electronic spreadsheet version of the referred to "Estimated
Revenue Requirement Cost (Benefit)".These spreadsheets provide the information
needed to produce the requested revised version of the "Estimated Revenue Requirement
Cost (Benefit)"table.
17-035-40 /Rocky Mountain Power
March 1,2018
OCS Data Request 14.3
OCS Data Request 14.3
Refer to Exhibit RMP_(JRS-2SS),page 2,in this docket and Exhibit RMP_(JRS-2SD)
in Docket No.17-035-39,both of which present "Example Annual RTM Deferral
Calculation -Revenue Requirement."Please provide a revised version of Exhibit
RMP (JRS-2SS)that incorporates the impacts of both the Combined Projects at issue in
this case AND the Repowering Projects at issue in Docket No.17-035-39.
Response to OCS Data Request 14.3
Please refer to the submitted work paper files "17-035-39 RMP WP-Steward-Exhibits
2SD-4SD 2-1-18"tab "JRS-2SD",and "17-035-40 RMP WPs-Steward 2-16-18"tab
"JRS-2SS Page 2",for an electronic spreadsheet version of the referred to "Example
Annual RTM Deferral".These spreadsheets provide the information needed to produce
the requested revised version of "Exhibit RMP_(JRS-2SS)".
17-035-40 /Rocky Mountain Power
March 1,2018
OCS Data Request 14.4
OCS Data Request 14.4
Refer to Exhibit RMP (JRS-3SS)in this docket and Exhibit RMP (JRS-3SD)in
Docket No.17-035-39,both of which present "Example Monthly RTM Deferral
Calculation -Revenue Requirement."Please provide a revised version of Exhibit
RMP_(JRS-3SS)that incorporates the impacts of both the Repowering projects at issue
in Docket No.17-035-39 AND the Combined Projects at issue in this docket.
Response to OCS Data Request 14.4
Please refer to the submitted work paper files "17-035-39 RMP WP-Steward-Exhibits
2SD-4SD 2-1-18"tab "JRS-3SD",and "17-035-40 RMP WPs-Steward 2-16-18"tab
"JRS-3SS",for an electronic spreadsheet version of the referred to "Example Monthly
RTM Deferral".These spreadsheets provide the information needed to produce the
requested revised version of "Exhibit RMP (JRS-3SS)".
17-035-40 /Rocky Mountain Power
March 1,2018
OCS Data Request 14.5
OCS Data Request 14.5
Refer to Exhibit RMP_(JRS-2SS),page 2.The exhibit shows the SG and GPS
allocation factors to Utah as remaining unchanged from 2020 to 2023.
(a)Please provide the current actual SG and GPS allocation factors as of the present date.
(b)Please provide the Company's current best estimate of the allocation factors that will
be used for each of the line items on this exhibit for each year,2020 through 2023.
While the Multi-State Process is still underway,please provide any internal Company
budgets or estimates regarding the Utah jurisdiction allocation factors that will be
used during the period 2020 through 2023.
Response to OCS Data Request 14.5
(a)The below factors are from Docket 17-035-15 page 10.2,Results of Operations-June
2017:
SG:43.3823 percent
GPS:43.0165 percent
(b)The factors used for the resource tracking mechanism (RTM)wouldbe the approved
factors from the most recently approved rate case,Docket 13-035-184,and would
continue to be used until the Company's next general rate case.At which time the
RTM would only use the then approved SG factor since the RTM will only involve
the continuing treatment of Production Tax Credits (PTC).The Company proposal
before the Multi-State Process broad review work group is to fix the SG factor based
on three years historical (2015-2017)and three years forecast (2018-2020).Below are
the forecasted SG factors for each year 2020 through 2023 that were presented to the
Multi-State Process (MSP)Broad Review Work Group (BRWG)on March 22,2017:
[BEGIN CONFIDENTIAL
[END CONFIDENTIAL
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
March 1,2018
OCS Data Request 14.6
OCS Data Request 14.6
Refer to page 2 of Exhibits RMP_(JRS-2SD)and RMP (JRS-2SS).
(a)Please explain,in detail,why the annual amount of Operation &Maintenance
Expense on line 8 increases by over $2.5 million annual for 2021 and 2022 and over
$3 million annual for 2023 in the 2nd supplemental filing as compared to the
supplemental filing.
(b)Please explain,in detail,why the annual Operation &Maintenance Expense on line 8
is now increasing every year between 2020 through 2023 in the 211d supplemental
filing when the costs were projected to decline between 2022 and 2023 in the
supplemental filing.
Response to OCS Data Request 14.6
(a)The final shortlist at the time of the Company's supplemental and rebuttal testimony
filing included McFadden Ridge II.The final shortlist in the Company's second
supplemental testimony filing included Ekola Flats,instead.Because Ekola Flats is
larger than McFadden Ridge II,the operation and maintenance (O&M)expense
dollars for Ekola Flats is larger,resulting in a larger aggregate total in the Company's
second supplemental testimony filing.
(b)Since the 2017 Renewable Request for Proposals (2017R RFP)bids included O&M
expense for the first three years,assets were modeled with a common dollars per
kilowatt ($/kW)assumption for O&M after the third year.The dollars per megawatt-
hour ($/MWh)O&M cost in the McFadden Ridge II bid was higher than the $/MWh
O&M cost in the Ekola Flats bid.The resulting transition from the bid to the common
assumption for McFadden Ridge II O&M was a large decrease,while the transition
for Ekola Flats O&M was a small decrease that was masked in the aggregate total by
increases for the other three projects.