20180307PAC to Staff WY WIEC Set 17 (1-9).pdf

1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
February 28,2018
Abigail C.Briggerman,#7-5476
Holland &Hart LLP
6380 South Fiddlers Green Circle,Suite 500
Greenwood Village,CO 80111
[e-mail](C)
RE:Wyoming Docket 20000-520-EA-17
WIEC 17th Set Data Request (1-9)
Please find enclosed Rocky Mountain Power's Responses to WIEC 17th Set Data Request 17.1-
17.7 and 17.9.The response to WIEC 17.8 will be provided separately.Provided on the
enclosed Confidential CD are Confidential Attachments WIEC 17.1 and 17.2.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)
Crystal J.McDonough/[e-mail] (C)
Callie Capraro/NLRA [e-mail]
Lisa Tormoen Hickey/[e-mail] (C)
Brandon L.Jensen/RMSC [e-mail](C)
Roxane Perruso/TOTCO [e-mail]
Jane M.France/TOTCO [e-mail] (C)
Constance E.Brooks/Anadarko [e-mail](C)
Danielle Bettencourt/Anadarko [e-mail](C)(W)
Paul Kapp/Anadarko [e-mail] (C)
Lisa Christian/TOTCO [e-mail] (C)
J.Kenneth Barbe/Southland [e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
February 28,2018
WIEC Data Request 17.1
WIEC Data Request 17.1
For each wind project selected as part of the Company's Final Short List please provide:
(a)A copy of the interconnection request,including any amendments to the
interconnection request;
(b)All feasibility studies;
(c)All system impact studies;
(d)All facilities studies.
If the Company updates the Final Short List,please update your response.
Response to WIEC Data Request 17.1
Please refer to Confidential Attachment WIEC 17.1
Note that the interconnection studies for the Ekola Flats project do not reflect updated
assumptions regarding PaciflCorp's long-term transmission plan (i.e.,the acceleration of
segment D.2 of Energy Gateway West).Given the timing of the interconnection
agreement negotiation,PacifiCorp transmission and the interconnection customer decided
to reflect the updated long-term transmission plan assumptions in the interconnection
customer's interconnection agreement rather than to issue a revised interconnection
study.
Please refer to Confidential Attachment WIEC 17.1 for a copy of the Ekola Flats
interconnection agreement.
Confidential information is provided subject to the terms and conditions of the protective
agreement in this proceeding.
Respondent:Kris Bremer
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
February 28,2018
WIEC Data Request 17.2
WIEC Data Request 17.2
Please refer to the Company's Response to WIEC 12.1,and Confidential Attachment
12.1.For each wind project identified for purposes of runningthe IE Sensitivity (at Tab
"Bid Portfolio Comparison"),please provide:
(a)A copy of the interconnection request,includingany amendments to the
interconnection request;
(b)All feasibility studies;
(c)All system impact studies;
(d)All facilities studies.
Response to WIEC Data Request 17.2
Please refer to the Company's response to WIEC Data Request 17.1 and Confidential
Attachment WIEC 17.2
For the McFadden Ridge II and Como Bluff projects,no studies have been conducted.
Confidential information is provided subject to the terms and conditions of the protective
agreement in this proceeding.
Respondent:Kris Bremer
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
February 28,2018
WIEC Data Request 17.3
WIEC Data Request 17.3
When will the IndependentEvaluator issue its report on the Final Short List project
portfolio?Please provide your answer with respect to the currentlyexisting Final Short
List (i.e.,the projects presented in the Company's January 16,2017 SupplementalDirect
Testimony)and any updated version of the Final Short List project portfolio.Please
provide copies of such reports once issued.
Response to WIEC Data Request 17.3
The Utah IndependentEvaluator (IE)issued draft comments on the final short list (FSL)
on January 15,2018 and a Final Short List report was issued on February 15,2018,
which is included in highly confidential exhibit RMP_(RTL-5SS)filed with the Public
Service Commission on February 16,2018.
The Oregon IE released a final report on February 16,2018,which is included in highly
confidential re lacement exhibit RMP (RTL-8SS)filed with the Public ServiceP
Commission on February 23,2018.
Due to the ongoing nature of the 2017 Renewable Request for Proposals (2017R RFP),
the IE documentation associated with the 2017R RFP is considered commercially
sensitive and highly confidential and the Company requests special handling.The
Company does not typically permit access to commercially sensitive 2017R RFP
documentation until the RFP has been concluded.Please contact Stacy Splittstoesser at
[phone] or Yvonne Hogle at [phone] to make arrangements for review.
Respondent:Bruce Griswold
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
February 28,2018
WIEC Data Request 17.4
WIEC Data Request 17.4
Please refer to the Company's Response to WIEC 12.1.Has the IndependentEvaluator
requested the Company run a sensitivity on any other or additional project portfolios?If
so,please provide copies of those sensitivities,and copies of any correspondence or
presentations by the Company on those sensitivities.
Response to WIEC Data Request 17.4
Due to the ongoing nature of the 2017 Renewable Request for Proposals (2017R RFP),
the IE sensitivities associated with the 2017R RFP are considered commercially sensitive
and highly confidential and the Company requests special handling.The Company does
not typically permit access to commercially sensitive 2017R RFP documentation until the
RFP has been concluded.Please contact Stacy Splittstoesser at [phone] or
Yvonne Hogle at [phone] to make arrangements for review.
Respondent:Bruce Griswold
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
February 28,2018
WIEC Data Request 17.5
WIEC Data Request 17.5
Please describe the circumstances under which a project may advance in or "jump"the
interconnection queue.Are there any costs to the project developer to advance in or
"jump"the queue?In your response,please refer to all tariff provisions discussing queue
advancement or "jumping."
Response to WIEC Data Request 17.5
PacifiCorp's open access transmission tariff (OATT)allows an interconnection customer
to request the advancement of the construction of interconnection-service network
upgrades under two scenarios:(1)when the network upgrades are the obligation of a
different interconnection customer;and (2)when the network upgrades are part of the
transmission provider's long-term expansion plan.Depending on the circumstances,the
requesting interconnection customer may be responsible for expediting costs or the
advanced network upgrade costs,subject to refund or transmission credits.See
PacifiCorp's OATT,sections 47.2.2 and 47.2.3,which mirror the Federal Energy
Regulatory Commission's pro forma OATT,sections 12.2.2 and 12.2.3.
Respondent:Kristopher Bremer
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
February 28,2018
WIEC Data Request 17.6
WIEC Data Request 17.6
Please refer to the Company's Response to WIEC 12.1,and Confidential Attachment
12.1.Please refer specifically to page 19 of the presentation.Please identify all projects
in the interconnection queue that have signed interconnection agreements to interconnect
to Segment D.2 based on a 2024 or later Segment D.2 in service date.Please indicate
whether the Company will re-study these projects,and if not,please explain why not.
Response to WIEC Data Request 17.6
There are no projects with an executed interconnection agreement that require only
Segment D.2 to be completed to allow interconnection and that have a scheduled in-
service date of Segment D.2 in 2024 or later.
Respondent:Kris Bremer
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
February 28,2018
WIEC Data Request 17.7
WIEC Data Request 17.7
Please refer to the Supplemental Direct Testimony of Mr.Rick Link at page 7,lines 5-14.
(a)Please identify the referenced qualifying facilities,includingthe project
interconnection queue numbers.
(b)Are there any other qualifying facilities that have identified a point of interconnection
on Segment D.2 that are higher in the queue than those wind facilities identified in the
Final Short List?If so,please identify the project interconnection queue numbers,
indicate the capacity of each project (MW),and explain how the Company has
accounted for the transmission capacity necessary to bring such qualifyingfacilities
online.
(c)Are there any other qualifyingfacilities that have identified a point of interconnection
on Segment D.2 that have signed interconnection agreements,but that have not yet
come online?If so,please identify the project interconnection queue numbers,
indicate the capacity of each project (MW),and explain how the Company has
accounted for the transmission capacity necessary to bring such qualifying facilities
online.
Response to WIEC Data Request 17.7
(a)Mud Springs Project LLC,Horse Thief Project LLC,and Pryor Caves Project LLC.
The project interconnection queue numbers are Q0542A,Q0542B,and Q0542C.
(b)Yes.Project interconnection queue numbers Q0409A,Q0409B,Q0409C,and
Q409D.Each project associated with the identified queue numbers is 80 megawatts
(MW).The system impact studies (SIS)for these qualifyingfacility (QF)projects
require elements of Energy Gateway beyond justthe Aeolus-to-Bridger/Anticline
Segment D.2.Consequently,the Company does not need to reserve interconnection
capacity enabled by the Aeolus-to-Bridger/AnticlineSegment D.2 line for these
specific QF projects.
(c)Please refer to the Company's response to subpart (b)above.
Respondent:Bruce Griswold
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
February 28,2018
WIEC Data Request 17.9
WIEC Data Request 17.9
For purposes of the requests below,please hypothetically assume selection of the
McFadden Ridge II project (110 MW)is replaced with the selection of the Ekola Flats
benchmark project (250 MW).
(a)Please provide the Company's best dollar estimate of how such a change would
impact the estimated network upgrade costs identified in Confidential Table 1 on
page 4 of Rick Vail's SupplementalDirect testimony of January 2018.Please
provide this information for each item listed in Confidential Table 1.
(b)Please provide a detailed description of the changes to the network upgrades that the
Company believes would be necessary in order to accommodate Ekola Flats in place
of McFadden Ridge II.
(c)Please provide a detailed description of all of the additional power system analysis
studies that would need to be completed by the Company,or on the Company's
behalf,in order to accommodate replacing the selection of McFadden Ridge II with
the selection of Ekola Flats.In responding to this request,please also identify the
expected completion date of each additional study that needs to be completed.To the
extent these studies have already been completed,please provide a complete copy of
them.
If the Company updates its Final Short List with a project other than the Ekola Flats
benchmark project,please update this response to reflect the new Final Short List
projects.
Response to WIEC Data Request 17.9
The Company did replace the McFadden Ridge II project with the Ekola Flats benchmark
project.Please see the Company's Second Supplemental filing dated February 16,2018,
as corrected February 23,2018.
Respondent:Kris Bremer
Witness:Rick Vail