20180307PAC to Staff WY WIEC Set 18 (1-7).pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
February 27,2018
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 18*Set Data Request (1-7)
Please find enclosed Rocky Mountain Power's Responses to WIEC 18th Set Data Request 18.3,
18.4,and 18.7.The remaining responses will be provided separately.Provided on the enclosed
Confidential CD is Confidential Attachment WIEC 18.7.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/[e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
February 27,2018
WIEC Data Request 18.3
WIEC Data Request 18.3
Please admit that if the wind output is less than expected during the first 10 years of a
Company owned wind project that produces PTCs,the effects of the less than expected
wind generationis worse for customers than if the wind output is less in years when
PTCs are not available.If your answer is anything other than an unequivocal admission,
please explain your response.
Response to WIEC Data Request 18.3
If Company-owned wind generationis lower than expected in the first 10 years,the
production tax credits (PTC)generated are lower than expected and less favorable to
customers.Conversely,if Company-owned wind generation is higher than expected,the
PTCs generated are higher than expected,and is more favorable to customers.It is
uncertain whether lower-than-expected-wind output for Company-owned wind during the
first 10 years is worse for customers than lower-than-expected-wind output after the first
10 years.Similarly,it is uncertain whether better-than-expected-wind output for
Company-ownedwind during the first 10 years is better for customers than better-than-
expected-wind output after the first 10 years.This temporal trade-off depends upon the
incremental benefits of PTCs,energy,and capacity in the first 10 years relative to the
value of energy and capacity after the first 10 years.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
February 27,2018
WIEC Data Request 18.4
WIEC Data Request 18.4
Please admit that if the Company pursued PPAs,either solar or wind,PTC risk is not
borne by ratepayers.If your answer is anything other than an unequivocal admission,
please explain your response.
Response to WIEC Data Request 18.4
Project developers bidding power purchase agreement (PPA)structures for wind projects
bear production tax credit (PTC)risk.However,under a PPA structure PTC benefits are
not passed directlythrough to customers.Consequently,any potential customer upside
associated with PTCs generated from a project are withheld from customers.Moreover,
for a PPA offered with flat or escalating pricing,any PTC benefits factored into the
bidders'price,if any,is spread out over the PPA term rather than being monetized over
the first 10 years of operation.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
February 27,2018
WIEC Data Request 18.7
WIEC Data Request 18.7
Please provide a copy of the Company's hedging and risk management policies.
Response to WIEC Data Request 18.7
Please refer to Confidential Attachment WIEC 18.7,which provides the most current
versions of PacifiCorp's Energy Risk Management Policy (approvedJanuary 12,2017)
and the PacifiCorp Energy's Commercial and Trading (C&T)Front Office Procedures
and Practices (approvedMay 22,2012).
Confidential information is provided subject to the terms and conditions of the protective
agreement in this proceeding.
Respondent:John Fritz /Paul Wood
Witness:To Be Determined