20180307PAC to Staff WY WIEC Set 14 (1-38).pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
February 9,2018
Abigail C.Briggerman,#7-5476
Holland &Hart LLP
6380 South Fiddlers Green Circle,Suite 500
GreenwoodVillage,CO 80111
[e-mail] (C)
RE:Wyoming Docket 20000-520-EA-17
WIEC 14th Set Data Request (1-38)
Please find enclosed Rocky Mountain Power's Responses to WIEC 14th Set Data Requests 14.1-
14.13,14.16,14.20,14.26-14.27,14.30-14.34,and 14.36-14.38.Also provided are Attachments
WIEC 14.37 and 14.38.Provided on the enclosed Confidential CD are Confidential Responses
WIEC 14.27 and 14.30 and Confidential Attachments WIEC 14.26,14.27,14.30 -(1-2),14.34,
and 14.36.Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
If you have any questions,please call me at [phone].
Sincerely,
Stacy Splittstoesser,
Manager,Regulation
Enclosures
C.C.:Meridith Bell/WPSC [e-mail](C)
Lori L.Brand/WPSC [e-mail] (W)
John Burbridge/WPSC [e-mail] (W)
Michelle Bohanan/WPSC [e-mail] (W)
Kara Seveland/WPSC [e-mail](W)
Morgan Fish/WPSC [e-mail] (W)
Dave Walker/WPSC [e-mail] (W)
Perry McCollom/WPSC [e-mail](W)
Patti Penn/WIEC [e-mail](W)
Thor Nelson/WIEC [e-mail] (C)(W)
Emanuel Cocian/WIEC [e-mail] (W)
Adele Lee/WIEC [e-mail] (W)
Nik Stoffel/WIEC [e-mail] (C)(W)
Christopher Leger/OCA [e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.1
WIEC Data Request 14.1
Referring to Joelle Steward's rebuttal testimony at page 8,line 21 through page 9,line 3.
(a)Is it PacifiCorp's position that it would not be reasonable for customers to benefit
from any new zero-fuel-cost generation on the Company's system before that new
zero-fuel-cost generationis included in rates?Please explain your answer in detail.
(b)Please provide any analyses or studies prepared by or on behalf of PacifiCorp to
quantifythe financial impact to the Company if the RTM is rejected and there is no
rate recovery for the Combined Project until after the Company's next general rate
case.
Response to WIEC Data Request 14.1
(a)No.The Company's position is that a matching of costs with benefits is reasonable
and appropriate.The Company's proposal for the RTM in this case is to provide the
ability to match costs with benefits in a comparable time period and avoid the need to
multiplerate cases over a short period of time.The referenced testimony on page 8
recognizes that there are potentiallyother ways to track and recover costs and
benefits.However,the Company does not agree benefits from these investments
should flow through the ECAM without recognition and recovery and/or deferral of
the costs incurred that creates those benefits.
(b)Please refer to Exhibit RMP_(JRS-2SD)Page 2 of 2,line 23 labeled "Rev Reqt after
ECAM Pass-through".These amounts reflect the Company's projection of the net
financial impact to the Company if the RTM is rejected and there is no rate recovery
for the Combined Projects.
Respondent:Joelle Steward
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.2
WIEC Data Request 14.2
Referring to Joelle Steward's rebuttal testimony at page 9,lines 13-16.Please identify
where "a meaningful opportunityto review the proposed ratemaking treatment for large
capital investments before they are made"is addressed in the stipulation in the
Company's 2010 rate case and the decision approving that stipulation.
Response to WIEC Data Request 14.2
Please refer to Docket 20000-384-ER-10,Stipulation and Agreement,sub-section "Major
Plant Investments,"beginning at paragraph 13.Additionally,see the Stipulation
Testimony of Kevin C.Higgins in that proceeding,page 8 -10,in which he describes the
process in the Stipulation,specifically as "essentially the same analysis the Commission
would traditionally consider on an after-the-fact basis in a rate case,but with a fuller
picture of the costs and benefits of the entire project"(page 10,lines 1-3).
Respondent:Joelle Steward
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.3
WIEC Data Request 14.3
Referring to Joelle Steward's rebuttal testimony at page 10,lines 7-10.Why are
mechanisms like the RTM typically implemented for costs that are variable and out of the
Company's control?Please explain your answer in detail.
Response to WIEC Data Request 14.3
The referenced testimony is explaining why it is reasonable for PTCs to be recovered on
an on-going basis through the RTM,similar to net power costs.An on-going mechanism
allows the recovery of specific costs and benefits at the level they are incurred on a
timely basis.If costs and benefits for elements that are variable and outside of the
Company's control,such as weather conditions that influence wind production and the
corresponding amount of PTCs,are fixed in rates at a specific level,variations of under-
collection or over-collection may result.A mechanism such as the ECAM or RTM for
PTCs on an on-going basis,provides an appropriate and timely ratemaking treatment
without the need for more frequent and time-consuming general rate proceedings,
especially when specific cost and benefit items can be discretely identified and measured
between rate cases.
Respondent:Joelle Steward
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.4
WIEC Data Request 14.4
Referring to Joelle Steward's rebuttal testimony at page l 1,lines 2-10.
(a)Does Ms.Steward agree that capping or reducing the recoverable costs for the
Combined Projects would increase the likelihood of customers actuallyexperiencing
benefits from the Combined Projects?Please explain your answer in detail.
(b)Does Ms.Steward agree that capping or reducing the recoverable costs for the
Combined Projects would increase the amount of benefits from the Combined
Projects actuallyexperiencedby customers?Please explain your answer in detail.
Response to WIEC Data Request 14.4
(a)No.Capping or reducing recoverable costs could result in an arbitrary transfer of
excessive project benefits to customers to the detriment of the Company for what
would be considered just and reasonable expenditures.
(b)Please refer to the Company's response to subpart (a)above.
Respondent:Joelle Steward
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.5
WIEC Data Request 14.5
Referring to Joelle Steward's rebuttal testimony at page l1,lines l1-19.Please explain
the impact to shareholders if the Company meets its resource needs through new
Company-owned resources rather than through front office transactions.
Response to WIEC Data Request 14.5
Shareholders that invest in Company-owned resources do so with the anticipation that
they will earn a fair return on their investment based on the authorized rate of return as
ordered by the Public Service Commission.The economic analysis in the 2017 IRP and
in this proceeding shows that the Combined Projects are the least-cost,least-risk resource
decisions to serve customers.
Respondent:Joelle Steward
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.6
WIEC Data Request 14.6
Referring to Joelle Steward's rebuttal testimony at page 12,lines 1-5.
(a)Please define "discretionary"as used by Ms.Steward.
(b)Please provide an example of a resource acquisition that meets Ms.Steward's
definition of discretionary.
(c)Please admit that PacifiCorp can meet its near-term resource needs with front office
transactions.If your answer is anything other than an unqualifiedadmission,please
explain in detail.
Response to WIEC Data Request 14.6
(a)"Discretionary,"as used in Ms.Steward's testimony,describes Mr.Phillip'sclaims
that the Combined Projects are discretionary or unneeded investments.
(b)A "discretionary"resource,in line with the Company's response in subpart (a)above,
would be a purchase of energythat is not warranted or needed to provide a balanced,
long-term,least-cost,least risk portfolio of resources.
(c)The Company could meet its "near-term"resource needs with higher-cost,higher-risk
front office transactions (FOT),however,the Company must also plan and strive for a
portfolio of resources that is a balance of least-cost and least-risk such as that
provided through acquisition of the Combined Projects.The economic analysis in this
proceeding shows that the Combined Projects are least-cost,least-risk path available
to serve customers by meeting both near-term and long-term needs,even after taking
into account the availability of FOT.
Respondent:Joelle Steward
Witness:Joelle Steward and Rick Link
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.7
WIEC Data Request 14.7
Referring to Joelle Steward's rebuttal testimony at page 12,lines 8-9.
(a)Please define "typical utility investments"as used by Ms.Steward.
(b)Please explain how the investment in the Combined Projects is different than a typical
utility investment.
Response to WIEC Data Request 14.7
(a)Typical utility investments encompass all acquisitions of assets,goods and services,
procured for the purpose of providing safe and reliable electrical service for
customers.
(b)As noted in testimony,the Combined Projects are the same as typical utility
investments because they do not impose a greater risk on customers and are not
discretionary.Theyare different because of the magnitude,and because benefits will
flow to customers through the ECAM without customers paying the costs if the RTM
is not implemented.
Respondent:Joelle Steward
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.8
WIEC Data Request 14.8
Referring to Joelle Steward's rebuttal testimony at page 12,lines 10-11.What is the
current "standard for what benefits must be achieved"in order for the Commission to
find a proposed investment predicated on customer benefits is reasonable and in the
public interest?Please explain your answer in detail.
Response to WIEC Data Request 14.8
A reasonable "standard for what benefits must be achieved"would find that if the
Company has used due diligence in fulfilling its obligation to provide safe and reliable
electrical service at a reasonable cost while taking into account available information
known at the time that decisions are made.Also,that the Company has planned for
current and future service in a way that pursues a balance of least-cost,least-risk
resources for the benefit of its customers,and that the company can reasonably expect
that the Commission would allow recovery of reasonable and prudent costs and not
arbitrarilypenalize or handicap the Company's ability to earn its authorized rate of
return.As indicated in Ms.Steward's rebuttal testimony,Mr.Phillips'proposal of taking
all the benefits of the Combined Projects,while capping and disallowing the costs the
Company would be allowed to recover would certainly be without regard to a "standard
for what benefits must be achieved."
Respondent:Joelle Steward
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.9
WIEC Data Request 14.9
Referring to Joelle Steward's rebuttal testimony at page 14,lines 13-16.Please explain
how the Commission can find that customers "will benefit"as a result of the Combined
Projects if the benefits are variable and outside of the Company's control?
Response to WIEC Data Request 14.9
Customer benefit is typically measured as the present value revenue requirement
differential (PVRR(d))between the proposed project and other reasonable,viable
alternatives.Such analysis of major resource alternatives is considered in the Company's
Integrated Resource Plan (IRP)and has also been addressed by Mr.Link in his testimony
regarding the benefit analysis of the Combined Projects.
Respondent:Joelle Steward
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.10
WIEC Data Request 14.10
Referring to Joelle Steward's rebuttal testimony at page 15,lines 4-9.
(a)Please identify the Commission decision where the Commission first determined that
acquiring Cholla would provide net savings to customers.
(b)Please explain how the benefits and costs associated with the Company's investment
in Cholla were first recovered from customers.
Response to WIEC Data Request 14.10
a.Please refer to the WyomingPublic Service Commission (WPSC)order from Docket
20000-ER-95-99 dated August 23,1996,approving a stipulation.The Commission
order approving the stipulation refers to Cholla in section 9a paragraph 4 on page 11.
The order states Cholla Unit 4 is activelysupplying the needs of PacifiCorp,was
acquired at a price lower than the price of comparable generatingoptions,and
generates savings in various amounts when measured against PacifiCorp's avoided
costs stated in present value terms.
b.The benefits and costs were first reflected in base rate through the general rate case
stipulation identified in part (a).
Respondent:Craig Larsen
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.11
WIEC Data Request 14.11
Referring to Joelle Steward's rebuttal testimony at page 15,lines 4-9.
(a)Please identify the Commission decision where the Commission first determined that
acquiring Craig and Hayden would provide net savings to customers.
(b)Please explain how the benefits and costs associated with the Company's investment
in Craig and Hayden were first recovered from customers.
Response to WIEC Data Request 14.11
a.Please refer to the WyomingPublic Service Commission (WPSC)order from Docket
20000-ER-95-99 dated August 23,1996,approving a stipulation.The Commission
order approving the stipulation refers to Craig and Hayden in section 9a paragraph 4
on page 11.The order states Craig and Hayden are activelysupplying the needs of
PacifiCorp,were acquired at a price lower than the price of comparable generating
options,and generates savings in various amounts when measured against
PacifiCorp's avoided costs stated in present value terms.
b.The benefits and costs were first reflected in base rates through the general rate case
stipulation identified in part (a).
Respondent:Craig Larsen
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.12
WIEC Data Request 14.12
Referring to Joelle Steward's rebuttal testimony at page 15,lines 4-9.
(a)Please identify the Commission decision where the Commission first determined that
acquiring Chalis would provide net savings to customers.
(b)Please explain how the benefits and costs associated with the Company's investment
in Chalis were first recovered from customers.
Response to WIEC Data Request 14.12
The Company assumes that the reference to "Chalis"is intended to reference the
Company's Chehalis combine-cycle combustion turbine (CCCT)generationplant.Based
on the foregoing assumption,the Company responds as follows:
a)Please refer to the WyomingPublic Service Commission (WPSC)order Docket
20000-333-ER-08,Record 11824.The Chehalis plant was included in the Company's
rate case filing.The rate case was resolved througha stipulation.Neither the
stipulation nor the Commission order approving the stipulation specifically mention
the Chehalis plant.The Chehalis plant has also been included in all subsequent rate
cases.
b)See response to part (a)
Respondent:Craig Larsen
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.13
WIEC Data Request 14.13
Referring to Joelle Steward's supplemental direct testimony at page 1,lines 22-23 and
Exhibit RMP (JRS-2SD).
(a)Please explain how the Combined Projects are the least cost alternative to meet
customers'needs in 2021.
(b)Please explain how the Combined Projects are the least cost alternative to meet
customers'needs in 2022.
(c)Please explain how the Combined Projects are the least cost alternative to meet
customers'needs in 2023.
Response to WIEC Data Request 14.13
(a)The Combined Projects has been found to be the best least cost,least risk economic
resource balance compared to other resource alternatives.Individual year's results are
not necessarily an indication of the total net benefits that are achieved across a long-
term planning cycle or the life of the resource.
(b)Please refer to the Company's response to subpart (a)above.
(c)Please refer to the Company's response to subpart (a)above.
Respondent:Joelle Steward
Witness:Joelle Steward and Rick Link
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.16
WIEC Data Request 14.16
Referring to Rick Link's rebuttal testimony at page 10,line 21 through page l1,line 5.
(a)Please identify the Commission decision(s)where the Commission approvedthe
1,698 MW of existing contracted and owned renewable resources included in rates
today "because they were demonstrated to be least-cost,least-risk,displaced FOTs,
and were acquired well before any thermal capacity or state renewable portfolio
standard need".
(b)Did PacifiCorp receive innovate or nontraditional ratemaking for the 1,698 MW of
existing contracted and owned renewable resources?Please explain your answer in
detail and identify any Commission decisions referred to or relied upon in responding
to this request.
Response to WIEC Data Request 14.16
(a)Please refer to the WyomingPublic Service Commission (WPSC)orders from the
followingdockets:
Docket 20000-469-ER-15,Record 14076
Docket 20000-446-ER-14,Record 13816
Docket 20000-405-ER-11,Record 13034
Docket 20000-384-ER-10,Record 12702
Docket 20000-352-ER-09,Record 12310
Docket 20000-333-ER-08,Record 11824
Docket 20000-277-ER-07,Record 11249
Docket 20000-230-ER-05,Record 10196
Docket 20000-ER-03-198,Record 8310
Docket 20000-ER-02-184,Record 7475
(b)No.
Respondent:Craig Larsen
Witness:Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.20
WIEC Data Request 14.20
Referring to Rick Link's rebuttal testimony at page 14,lines 17-23.Does Mr.Link agree
that the Combined Projects will increase customer rates in the near term?Please explain
why or why not.
Response to WIEC Data Request 14.20
Customer rate impacts,beginning with the first full year of operation for the Combined
Projects in 2021,will depend on the ratemaking mechanisms employed.First year
impacts are expected to be less than 2 percent.Please refer to the supplemental direct
testimony of Company witness,Joelle R.Steward,for the estimated annual rate impact.
Respondent:Randy Baker
Witness:Rick Link and Joelle Steward
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.26
WIEC Data Request 14.26
Referring to Rick Link's supplemental direct testimony at page 13,lines 16-17.
(a)Please identify each of the network upgrades required for each of the shortlist projects
to interconnect to the Company's transmission system.
(b)Please identify the cost of each of the network upgrades required for each of the
shortlist projects to interconnect to the Company's transmission system.
Response to WIEC Data Request 14.26
(a)For each of the projects included in the 2017R Request for Proposals (2017R RFP)
final shortlist (FSL),the followingnetwork upgrades have been identified:
1.Q707/708 (Shirley Basin)
A new bay and three new breakers along with associated switches at the
existing Shirley Basin 230 kilovolt (kV)substation.
Two new line terminations at Shirley Basin substation,one to interconnect the
interconnection project and the other to connect the new Shirley Basin -
Aeolus 230 kV line required by the Project.
Addition of two new breakers along with associated switches on the existing
bay that connects Dunlap wind farm to Shirley Basin in order to convert the
Shirley Basin 230 kV bus to full breaker and half configuration.
Construction of a new approximately 16.5-mile Shirley Basin -Aeolus 230
kV line with 2-1557 ACSR (Potomac).
2.Q712 (Windstar)
Two -230 kV (3,000 ampere)breakers and two line positions with associated
switches at Windstar substation.
Installation of high speed relaying to switch off the shunt capacitor banks at
Riverton 230 kV are required for high voltage conditions.
3.Q863 (Foote Creek area)
Construct a new three breaker 230 kV POI ring bus substation on the High
Plains -Foote Creek 230 kV line,~2 miles southwest of High Plains
substation.
Rebuild the Aeolus -Freezeout -Standpipe 230 kV line (3 miles and 11.7
miles,respectively)on single tower 2-1272 ACSR/Phase (Bittern)
4.Q715 (UintaCounty)
Construct a new three breaker 138 kV POI ring bus substation southwest of
the WhitneyCanyon Tap (near structure 116),with associated switches and
line terminations.
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.26
Reconductor approximately 13.7 miles of the Q0715 -Railroad 138 kV line
with 1-1272 ACSR/phase (line has 1-795 ACSR/phase).
Modify the existing Naughton RAS to integrate the Q0715 project.
(Redundant communication to the project is required.)
(b)Please refer to Confidential Attachment WIEC 14.26,which describes the cost of the
network upgrades for each project.
Confidential information is provided subject to the protective order issued in this
proceeding.
Respondents:Craig Quist /Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.27
WIEC Data Request 14.27
Please refer to the SupplementalDirect Testimony of Mr.Rick T.Link at page 14,lines
19-21.
(a)For each of the winningbids of the 2017R RFP,please indicate how that project has
demonstrated site control.
(b)For each of the winningbids of the 2017R RFP,please provide the referenced
permitting timeline.
(c)Could the collection of avian data lead to changes in the siting of the proposed
projects or otherwise cause a delay in the development of the projects?
(d)Do any of the winning bids of the 2017R RFP warrant an Eagle Take Permit?If so,
please indicate where each project is in the process of obtaining such a permit.
(e)Please provide all studies or analyses regarding the advisability of an Eagle Take
Permit.
(f)Have any avoidance,minimization,or mitigation measures been incorporated in to
the project design to account for avian impacts?
(g)Please provide all correspondence the Company has obtained between the winning
bids to the 20 17R RFP and the Fish and Wildlife Service,or the WyomingGame and
Fish Department.
Confidential Response to WIEC Data Request 14.27
(a)Please refer to the confidential table below:
(b)McFadden Ridge II -the permitting requirements are included in Confidential
Exhibit RMP_(CAT3-17)of Mr.Teply's direct testimony,and further informed by
the indicative ro ect schedule in Confidential Exhibit RMP (CAT3-6).P J
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.27
TB Flats I and II -the permitting requirements are included in Confidential Exhibit
RMP_(CAT2-16)of Mr.Teply's direct testimony,and further informed by the
indicative ro ect schedule in Confidential Exhibit RMP (CAT2-6).P J
Cedar Springs -the permitting requirements are included in Confidential Exhibit
RMP_(CAT-1SD-9)of Mr.Teply's supplemental direct testimony,and further
informed b the indicative ro ect schedule in Confidential Exhibit RMP (CAT-y PJ
1SD-3 .
Uinta -the permitting requirements are included in Confidential Exhibit CAT-4SD-4-
H of Mr.Teply's supplemental direct testimony,and further informed by the
indicative ro ect schedule in Confidential Exhibit RMP (CAT-4SD-6).P J
A brief update to the timeline of the projects is also included in the timeline table on
page 8-9 of Mr.Teply's supplemental direct testimony.The permits for these
facilities are in progress and will be obtained if a CPCN is approvedby the
Commission.
(c)Results of avian data collection could affect the ultimate project wind turbine layout
or project schedule,however bidders have built avian data collection into their
proposed development schedule.
(d)An eagle take permit is a voluntarypermit.Bidders have indicated they are in various
stages of developing their eagle conservation plans and will be applying for an eagle
take permit.
(e)Due to the ongoing nature of the 2017R RFP,bid information,studies and analysis
associated with the 2017R RFP 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
Stacy Splittstoesser at [phone] or Yvonne Hogle at [phone] to make
arrangements for review.
(f)Projects are currentlyin various stages of assessing avian impacts includingdata
collection,initiation of discussions with the appropriate agencies,and development of
mitigation plans.Bidders did not submit a formal mitigation plan document as part of
their bid package.
(g)Due to the ongoing nature of the 2017R RFP,bid information,studies and analysis
associated with the 2017R RFP 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
Stacy Splittstoesser at [phone] or Yvonne Hogle at [phone] to make
arrangements for review.
Confidential information is provided subject to the protective order issued in this
proceeding.
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.27
Respondent:Bruce Griswold
Witness:Rick Link and Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.30
WIEC Data Request 14.30
Referring to Rick Link's supplemental direct testimony at page 27,Table 2-SD.
(a)What portion of the benefits identified in Table 2-SD are associated with the
transmission facilities?
(b)What portion of the benefits identified in Table 2-SD are associated with PTCs?
(c)What portion of the benefits identified in Table 2-SD are associated with avoided
FOTs?
Confidential Response to WIEC Data Request 14.30
(a)Three of the bids in the final short list,totaling 1,009 megawatts (MW),are located
behind the TOT 4A transmission constraint.These three bids are enabled by the
Aeolus-to-Bridger/Anticlineline.The remaining 161 MW bid (Uinta)is not
dependent on the Aeolus-to-Bridger/Anticlinetransmission line.
Because the benefits of the 1,009 MW of new wind behind the TOT 4A constraint are
enabled by the Aeolus-to-Bridger transmission line,the Company has not
independently analyzed the benefits of this transmission line without this new wind.
Nonetheless,the Company has evaluatedhow the present value of revenue
requirements differential (PVRR(d))is impacted if the Uinta project were removed
from the final shortlist.With medium natural gas and medium carbon dioxide (CO2)
price assumptions,removing Uinta decreases customer net benefits by approximately
.Please refer
to Confidential Attachment WIEC 14.30-1.
(b)Please refer to the Confidential Supplementalwork paper "Table 2-SD,Table 3-SD,
Figure 5 FSL Results Summary File.xlsx",specifically the "PaR -RFP WFSL
Studies"worksheet,row 103.The net present value (NPV)of production tax credits
is $687 million in all price-policy scenarios.
(c)Please refer to Confidential Attachment WIEC 14.30-2,which calculates the avoided
front office transactions (FOT)costs in three price-policyscenarios:Low Gas No
CO2,Medium Gas No CO2,and Medium Gas Medium CO2.
Confidential information is provided subject to the protective order issued in this
proceeding.
Respondent:Randy Baker
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.31
WIEC Data Request 14.31
Please refer to the Company's Response to WIEC 11-1.
(a)Please provide copies of all drafts of the EPC contracts for the Combined Projects.
(b)Does the Company anticipate that any of the terms of the draft EPC contracts could
change prior to execution?If so,please explain your answer.
(c)When does the Company anticipate executing each of the EPC contracts?
(d)Please provide copies of all EPC contracts upon execution.This is an ongoing
request.
Response to WIEC Data Request 14.31
(a)As reported in the Company's response to WIEC Data Request 11.1,no engineer,
procure,construct (EPC)contracts for the Combined Projects have been executed at
this time.The Company is currentlyfinalizing its 2017 Renewable Request for
Proposals (2017R RFP)final shortlist interconnection re-study work and assessment
of transmission system dynamics impacts of particular wind turbine generator (WTG)
equipment associated with individual shortlisted projects.When available,the
Company will supplement this data request response to provide pro-forma /draft EPC
contracts,as applicable to the selected benchmark wind projects,following
completion of the activities described above.For non-benchmark new wind projects
included in the 2017R RFP final shortlist,the pro-forma build transfer agreement
(BTA)and power purchase agreement (PPA)are publicly available on PacifiCorp's
website and can be accessed by utilizingthe website link provided below:
http://www.pacificorp.com/sup/rfps/2017-
rfp/2017R RFP Doc and Appendices.html
(b)As with negotiations of any definitive agreement,it is likelythat the language of
individual terms and conditions incorporated as part of the pro-forma contract and
exhibits will change prior to execution;however,the Company does not anticipate
material deviations from the pro-forma wind benchmark EPC contract concepts and
risk mitigation measures addressed by competitive market respondents during the
Company's competitive solicitations for wind benchmark EPC contractors.The
Company is currentlyengaged with shortlisted wind benchmark EPC contractors in
negotiation of final EPC terms and conditions,should those projects ultimately be
selected followingcompletion of the activities described in the Company's response
to subpart (a)above.
Similarly,the Company is currentlyinitiating discussions with shortlisted non-
benchmark BTA counterparties to facilitate detailed negotiation of final BTA terms
and conditions.The Company does not anticipate material deviations from the pro-
forma BTA concepts and risk mitigation measures addressed by competitive market
respondents during the Company's 2017R RFP competitive solicitation for wind
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.31
build transfer projects.
(c)The Company currentlyanticipates executing the EPC contracts for any benchmark
projects selected to the 2017R RFP final shortlist in alignment with receipt of
regulatory approvals for those projects;currentlytargeting May 31,2018.
The Company also currentlyanticipates executing the BTA for any build transfer
projects selected to the 2017R RFP final shortlist in alignment with receipt of
regulatory approvals for those projects;currentlytargeting May 31,2018.
Notwithstandingthe above,pursuant to the 2017R RFP process,the Company will
engage in detailed negotiations of definitive EPC and BTA with the intent of having
executable agreements negotiated by April 16,2018.
(d)Please refer to the Company's response to subpart (c)above.The Company will
supplement the response to subpart (d)as additional information becomes available.
Respondent:Richard Goff
Witness:Chad Teplyand Rick Vail
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.32
WIEC Data Request 14.32
Please refer to the SupplementalDirect Testimony of Mr.Rick.A.Vail at page 6,line 15
through page 7,line 2.Assume the Company needs to initiate condemnationproceedings
against landowners in order to obtain the necessary rights of way to place the Combined
Projects into service by December 31,2020.Please indicate when those proceedings will
be initiated and how long it will take to receive a final decision permitting the Company to
acquire the rights of way.
Response to WIEC Data Request 14.32
In the event negotiations fail with a landowner the Company would need to initiate
condemnationproceedings to meet the construction schedule,the landowner would be
notified of the Company's intent in mid to late summer of 2018 to provide sufficient time
for the necessary steps required to complete the legal proceedings.Timing for a final
decision from the courts is dependent on several factors and can take several months.
Respondent:Shawn Graff
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.33
WIEC Data Request 14.33
Please refer to the SupplementalDirect Testimony of Mr.Rick A.Vail at page 6,lines 2-
7.
(a)Please detail how the additional network upgrades have changed the Company's
timeline and process for finalizing the EPC contracts.
(b)Please describe the purpose and scope of the Line Service Agreements.Please also
describe the relationship between the Line Service Agreements and EPC contracts.
Response to WIEC Data Request 14.33
(a)The additional network upgrades have not changed the Company's timeline or
process for finalizing the engineer procure and construct (EPC)contracts.The scope
of these upgrades is not included in the EPC contracts.
(b)Line service agreements are contracts where agreed terms and conditions have been
negotiated between the Company and a range of qualified contractors in a previously
competed request for proposal (RFP)event for procurement and construction
services.Project engineering work is performed by either PacifiCorp engineering
resources or a contracted Owners Engineer.The purpose of such line service
agreements is to have a suite of available qualified contractors available to expedite
projects typically less than $50 million in value,thus reducing the time to establish
contracts to execute projects while preserving the competitive bidding element of the
procurement process.Currently,Rocky Mountain Power has 12 such contractors
available in Wyoming.Qualified line service agreement contractors are invited to
submit a competitivelysourced fixed price bid for a qualifyingproject.For Energy
Vision 2020 the line service agreement contractors will be invited to submit bids for
the network upgrades scope of work including;138 kilovolt (kV)transmission
upgrades,230 kV transmission upgrades and 230 kV substation construction
packages.There is no direct relationship between the line service agreements and
EPC contracts.
Respondent:Todd Jensen /Stuart Smith
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.34
WIEC Data Request 14.34
Please refer to the SupplementalDirect Testimony of Mr.Rick A.Vail at page 6,lines 8-
14.Please list and describe all additional studies and technical analyses that the
Company has not finalized.Please also include the expected date of completion of the
same studies and analyses,and provide copies upon completion.This is an ongoing
request.
Response to WIEC Data Request 14.34
Please refer to Confidential Attachment WIEC 14.34,which contains a summary of
technical studies that are necessary to support the D.2 Project.Some of the steps within
the document reflect a hand-off of technical information or recommendations between
PacifiCorp and consultants,while other steps reflects the completion of technical efforts
that result in the issuance of a study report.
To date,the followingtechnical reports have been completed and are provided in
Confidential Attachment WIEC 14.34:
Aeolus West Transmission Path Transfer Capability Assessment,October 2017
Transmission Assessment of Dave Johnston Plant Retirement Impacts to New
WyomingWind Generation Integration,November 2017
Gateway West D.2 Project SSR/SSCI Study by General Electric Energy
Consulting Group,October 24,2017.
Upon completion,other reports will be made available.
Confidential information is provided subject to the protective order issued in this
proceeding.
Respondent:Craig Quist
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.36
WIEC Data Request 14.36
Please refer to the Rebuttal Testimony of Mr.Chad A.Teplyat page 15,lines 19-24.Please
provide a copy of the referenced agreement.If no agreement exists,please describe in detail
the agreement with Commission Staff.
Response to WIEC Data Request 14.36
The agreement between the Company and Commission staff is described in an internal
Company compliance document and is also outlined in the confidential rebuttal testimony
and exhibits of Mark Tallman in Docket 20000-405-ER-11.These documents are
provided in Confidential Attachment WIEC 14.36.
Confidential information is provided subject to the protective order issued in this
proceeding.
Respondent:Stacy Splittstoesser
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.37
WIEC Data Request 14.37
Please refer to the Rebuttal Testimony of Mr.Chad A.Teply at page 16,line 1.Please
provide the actual capacity factor for each project listed on a year by year basis,starting
from the year of the project's COD.
Response to WIEC Data Request 14.37
The chart of wind project net capacity factors (NCF)at page 16,line 1 in the rebuttal
testimony of Company witness,Chad A.Teply,refers to the average annual NCF of the
wind projects beginning in year 2010,the year the most recent project was completed,
through 2016,the latest complete year of data available when the testimony was
prepared.Please refer to Attachment WIEC 14.37,which provides actual annual capacity
factors for the followingCompany owned wind resources from commercial operation
date (COD)year through calendar year 2017:
Dunlap
High Plains
McFadden Ridge
Seven Mile Hill I
Seven Mile Hill II
Note:the Seven Mile Hill I and Seven Mile Hill II wind projects went into commercial
operation on December 31,2008.The NCF data for the Seven Mile Hill projects begins
January 1,2009.
Respondent:Devin Hutchinson and Ken Clark
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 14.38
WIEC Data Request 14.38
Referring to Rick Link's supplemental direct testimony at page 35,line 14 through page
36,line 13.
(a)Please provide a rate impact analysis of the portfolio containing the solar PPAs
without the Combined Projects consistent with that provided in Table 1 of Exhibit
JRS-2SD.
(b)Please provide a rate impact analysis of the portfolio containing the Combined
Projects with the solar PPAs consistent with that provided in Table 1 of Exhibit JRS-
2SD.
Response to WIEC Data Request 14.38
(a)Please refer to Attachment WIEC 14.38 for a comparison of solar power purchase
agreements (PPA)without Combined Projects,solar PPAs with Combined Projects,
and the Combined Projects for years 2020 through 2030.
(b)Please refer to the Company's response to subpart (a)above.
Respondent:Terrell Spackman
Witness:Joelle Steward and Rick Link