20180329PAC to Staff UT DPU Set 22 (1-25) (2).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PACIFICORP
March 15,2018
Erika Tedder
Division of Public Utilities
160 E 300 S,4th Floor
Salt Lake City,UT 84114
[e-mail]
[e-mail](C)
RE:UT Docket No.17-035-40
DPU 22nd Set Data Request (1-25)
Please find enclosed Rocky Mountain Power's Responses to DPU 22nd Set Data Requests 22.2,
22.6,and 22.10-22.21.Provided on the enclosed Confidential CD are Confidential Attachments
DPU 22.13 and 22.17.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].
Sincerely,
Manager,Regulation
Enclosures
C.c.:Dan Kohler/DPU [e-mail](C)
Aliea Afnan/DPU [e-mail](W)
[e-mail] (W)
Dan Peaco/DPU [e-mail] (C)(W)
Kevin Higgins/[e-mail](C)
Neal Townsend/UAE [e-mail](C)(W)
Gary A.Dodge/UAE [e-mail] (C)
Phillip Russell/UAE [e-mail] (C)
Philip Hayet/OCS [e-mail] (C)
Béla Vastag/OCS [e-mail](C)
Sophie Hays/UCE [e-mail](C)
Kate Bowman/UCE [e-mail](C)(W)
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 15,2018
DPU Data Request 22.2
DPU Data Request 22.2
Vail Second SupplementalDirect.Refer to lines 15,30 and 82:
(a)Please defme the 'broader OATT restudy'process and the scope of this restudy.
(b)Please list the queue projects that the company restudied under this 'broader OATT
restudy'process.
(c)Please provide a list of queue projects that have a commercial operation date between
2020 and 2024 and were previously studied without the 'Energy Gateway'projects.
(d)Did the Company perform restudies for each of the projects listed in response to part
(c)?If yes,please provide copies of such restudies.If no,please provide individual
explanation on why restudies were not performed for each of these projects listed
under part (c).
(e)Please provide a list of queue projects that have a commercial operation date between
2020 and 2024 and were previously studied with both the 'Energy Gateway West'
and 'Energy Gateway South'projects assumed to be in-service.
(f)Did the Company perform restudies for each of the projects listed in response to part
(d),such that only the D.2 segment (Aeolus-to-Bridger/Anticline)of the 'Energy
Gateway West'project was included to be in-service and rest of the 'Energy
Gateway'project components were assumed to be out of service.If yes,please
provide a copy of such restudies.If no,please provide explanation on why restudies
were not performed for these projects listed under part (d).
Response to DPU Data Request 22.2
(a)The phrase "broader open access transmission tariff restudy process"was used to
indicate that the restudy process was not specific to the 2017 Renewable Request for
Proposals shortlist.
(b)The queue projects restudied are Q0707,Q0708,Q0712 and Q0713.
(c)The Company objects to this request as vague and ambiguous.Without waiving this
objection,the Company responds as follows:
The Company assumes that this request is focused on projects located in the
constrained area of PacifiCorp's eastern Wyoming transmission system.Based on the
foregoing assumption,the Company responds as follows:
There are no queue projects proposing to interconnect in PacifiCorp's eastern
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.2
Wyomingtransmission system that have been studied without the Energy Gateway
projects included as an assumption.
(d)Please refer to the Company's response to subpart (c)above.
(e)The Company objects to this request as vague and ambiguous.Without waivingthis
objection,the Company responds as follows:
PacifiCorp assumes that "projects that have a commercial operation date between 2020
and 2024"refers only to projects with executed interconnection agreements.Based on
the foregoing assumption,the interconnection studies leading up to the execution of the
interconnection agreements for the followingprojects included certain assumptions about
Energy Gateway West and Gateway South:Q0290,Q0409,and Q0706.
(f)Please refer to the Company's response to subpart (c)above.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.6
DPU Data Request 22.6
Vail Second SupplementalDirect.Exhibit RMP (RAV-2SS)Page 30 of 35:
(a)Please confirm if 101 MW from Q810 can be delivered on a firm basis assuming all
transmission modifications outlines in the report and all requirements of Q786 are
completed.
(b)Please also confirm that 101 MW is not the 'Maximum Amount of Power that can be
delivered into Network Load,with No Transmission Modifications'(as stated in the
sub-section 6.1.4 heading).
Response to DPU Data Request 22.6
(a)The information provided in sections 6.1.4 and 6.1.5 of the referenced interconnection
study report is non-binding and is for informational purposes only,providing:(1)an
estimate of what portion of the power from the interconnection customer's generator
could be delivered to network load without transmission modifications;and (2)possible
transmission system improvements that could be required to address any potential issues
with the deliverabilityof the power from interconnection customer's generator and do not
provide for transmission service.A transmission service request is required to acquire
transmission rights to move the resource to load.This request may require additional
analysis to determine specific deliverability-related requirements.
(b)Please refer to the Company's response to subpart (a)above.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.10
DPU Data Request 22.10
Vail Second SupplementalDirect.Exhibit RMP_(RAV-3SS)Page 16 of 40:
(a)Please identify all the 'the additional Transmission Provider Energy Gatewayprojects
and other system improvements'that would be necessary to deliver 100%of power
from Q707.
(b)Please confirm that network upgrade costs associated with these 'additional
Transmission Provider Energy Gateway projects and other system improvements'
have not been identified/provided in this testimony.
(c)Please provide all studies performed with respect to Q707's interconnection that
demonstrate the need for these 'additional Transmission Provider Energy Gateway
projects and other system improvements'.
(d)If no study is available,please provide reasoning behind this statement in the System
Impact Study Report.
(e)Please confirm if these 'additional Transmission Provider Energy Gateway projects
and other system improvements'would be designed,procured and constructed by
December 2020.
Response to DPU Data Request 22.10
(a)No additional improvements have been identified at this time.See PacifiCorp's
Response to DPU Data Request 22.6(a)for a description of the non-binding nature of
the referenced section of this interconnection report and what would be needed for a
more thorough analysis of the deliverability-related requirements associated with an
interconnection customer's generator.
(b)Please refer to the Company's response to subpart (a)above.
(c)Please refer to the Company's response to subpart (a)above.
(d)Please refer to the Company's response to subpart (a)above.
(e)Please refer to the Company's response to subpart (a)above.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.11
DPU Data Request 22.11
Vail Second SupplementalDirect.Exhibit RMP_(RAV-3SS)Page 35 of 40:
(a)Please identify all the 'the additional Transmission Provider Energy Gateway projects
and other system improvements'that would be necessary to deliver 100%of power
from Q708.
(b)Please confirm that network upgrade costs associated with these 'additional
Transmission Provider Energy Gateway projects and other system improvements'
have not been identified/provided in this testimony.
(c)Please provide all studies performed with respect to Q708's interconnection that
demonstrate the need for these 'additional Transmission Provider Energy Gateway
projects and other system improvements'.
(d)If no study is available,please provide reasoning behind this statement in the System
Impact Study Report.
(e)Please confirm if these 'additional Transmission Provider Energy Gateway projects
and other system improvements'would be designed,procured and constructed by
December 2020.
Response to DPU Data Request 22.11
(a)No additional improvements have been identified at this time.See PacifiCorp's
Response to DPU Data Request 22.6(a)for a description of the non-binding nature of
the referenced section of this interconnection report and what would be needed for a
more thorough analysis of the deliverability-related requirements associated with an
interconnection customer's generator.
(b)Please refer to the Company's response to subpart (a)above.
(c)Please refer to the Company's response to subpart (a)above.
(d)Please refer to the Company's response to subpart (a)above.
(e)Please refer to the Company's response to subpart (a)above.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.12
DPU Data Request 22.12
Vail Second Supplemental Direct.Exhibit RMP (RAV-4SS)Page 17 of 23:
(a)Please identify all the 'the additional Transmission Provider Energy Gateway projects
and other system improvements'that would be necessary to deliver 100%of power
from Q708.
(b)Please confirm that network upgrade costs associated with these 'additional
Transmission Provider Energy Gateway pro.jects and other system improvements'
have not been identified/provided in this testimony.
(c)Please provide all studies performed with respect to Q712's interconnection that
demonstrate the need for these 'additional Transmission Provider Energy Gateway
projects and other system improvements'.
(d)If no study is available,please provide reasoning behind this statement in the System
Impact Study Report.
(e)Please confirm if these 'additional Transmission Provider Energy Gateway projects
and other system improvements'would be designed,procured and constructed by
December 2020.
Response to DPU Data Request 22.12
(a)The Company assumes that the intended reference for this request is "Q0712".Based
on this assumption,the Company responds as follows:
No additional improvements have been identified at this time.See PacifiCorp's
Response to DPU Data Request 22.6(a)for a description of the non-binding nature of
the referenced section of this interconnection report and what would be needed for a
more thorough analysis of the deliverability-related requirements associated with an
interconnection customer's generator.
(b)Please refer to the Company's response to subpart (a)above.
(c)Please refer to the Company's response to subpart (a)above.
(d)Please refer to the Company's response to subpart (a)above.
(e)Please refer to the Company's response to subpart (a)above.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.13
DPU Data Request 22.13
Vail Second Supplemental Direct.Exhibit RMP (RAV-5SS)Page 14 of 18:
(a)The Commercial Operation date from the Final Facilities Study Report appears to be
March 28,2025.Please confirm that this is the final schedule for Q706.
(b)If not,please provide revised schedule for the project.
Response to DPU Data Request 22.13
(a)The referenced interconnection study for the Q706 project did not reflect updated
assumptions regarding PacifiCorp's long-term transmission plan (i.e.,the acceleration
of segment D.2 of Energy GatewayWest).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 DPU 22.13 for a copy
of the interconnection agreement,which lists an updated commercial operation date
of November 1,2020.
(b)Please refer to the Company's response to subpart (a)above.
Confidential information is provided subject to Public Service Commission of Utah Rule
746-1-602 and 746-1-603.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.14
DPU Data Request 22.14
Vail Second Supplemental Direct.Refer to lines 22-25,stating that the "Company has
confirmed that there is sufficient stiffness factor"to interconnect the Wind Projects.
Provide all studies,documentation,and analysis supporting this conclusion on stiffness
factor.
Response to DPU Data Request 22.14
Please refer to the Company's response to DPU Data Request 22.5,specifically
Attachment DPU 22.5,which provides copies of the updated studies referenced in Mr.
Vail's second supplemental testimony.
In parallel to the development of this preliminaryreport,dynamic stability studies are
being performed which included detailed wind turbine models for each of the proposed
wind plants and existing wind plants in southeast Wyoming.These on-going dynamic
stabilitystudies have provided the confirmation that there is sufficient stiffness factor to
integrate the wind resources outlined in Table 1 of the report.Dynamic stability study
results will be verified by a third-partyconsultant who is tasked with performing detailed
Power System Computer Aided Design (PSCAD)studies of the Wyoming transmission
system.Once dynamic stability studies are completed,they will be documented in a
technical report,which will be distributed to state regulatory agencies and stakeholders.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.15
DPU Data Request 22.15
Vail Second SupplementalDirect.Refer to lines 74-77,stating that no Ekola
interconnection restudy was conducted.
(a)Is the Company's conclusion that there will be no change to the network upgrades
needed for the Ekola Flats project due to the change in assumptions on the Energy
Gateway components included in the study?If so,please provide all analysis and
documentation supporting this conclusion.
(b)Will future studies be conducted on the network upgrades required for the Ekola Flats
project?If so,what studies will be conducted,by whom will they be conducted,and
when will the studies be completed?
Response to DPU Data Request 22.15
(a)Please refer to the Company's Response to DPU Data Request 22.13(a).
(b)No.Please refer to the Company's response to subpart (a)above.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.16
DPU Data Request 22.16
Vail Second SupplementalDirect.Refer to lines 97-103,regarding network upgrade
costs.Please provide a breakdown of network upgrade costs by project and by
component,and provide a comparison between the upgrade components and costs listed
in the Facilities Studies and SISs for each project.
Response to DPU Data Request 22.16
Publication of sensitive cost infonnation at this time may impact the ongoing overall
competitive bid process for the transmission lines.The 500 kilovolt (kV)and 230 kV
estimate model/cost information is considered commercially sensitive and highly
confidential.The Company requests special handling.Please contact Jana Saba at (801)
220-2823 or Yvonne Hogle at [phone] to make arrangements for review.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.17
DPU Data Request 22.17
Vail Second SupplementalDirect.Refer to lines 11l-113,regarding network upgrades
related to the Cedar Springs project.
(a)Please identify the Q0409 project and provide project details.
(b)Please provide a narrative explanation of the delay in in-service date for Q0409.
Provide all supporting documentation for the change.
(c)Does the Q0409 project have an executed interconnection agreement?If so,please
provide the agreement.
(d)Does the Company's testimony conclude that if Cedar Springs and Q0409 were both
in service,the rebuild of a 56-mile portion of the Dave Johnston-Amasa-Difficulty-
Shirley Basin 230-kV line would be required,but since Q0409 is delayed,the rebuild
can be deferred?If so,when the Q0409 is put in service,who will be responsible for
the cost of the 56-mile rebuild?Please provide any analysis or documentation
supporting this response.
Response to DPU Data Request 22.17
(a)The executed interconnection agreement for Q0409 has an in-service date of
December 15,2024.Please refer to Confidential Attachment DPU 22.17 for a copy
of the interconnection agreement and the PacifiCorp Open Access Same-Time
Information System (OASIS)website for the Q0409 interconnection studies:
(http://www.oasis.oati.com/PPW/PPWdocs/Q409FS.pdf).
(b)Please refer to the Company's response to subpart (a)above
(c)Please refer to the Company's response to subpart (a)above.
(d)The Company's testimony does not provide this conclusion because the Q0409
project will not be in-service by 2020.
Confidential information is provided subject to Public Service Commission of Utah Rule
746-1-602 and 746-1-603.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.18
DPU Data Request 22.18
Vail Second Supplemental Direct.Refer to lines 118-121,regarding network upgrades
related to the Uinta project.Please provide documentation supporting conclusion that the
reconductoring is not required.Include in this response the "most recent line ratings"as
well as the "new information"that led to the change.
Response to DPU Data Request 22.18
Under system normal conditions,the generationin the Uinta area flows towards Railroad
through two different 138 kilovolt (kV)lines:(1)Railroad -Painter-Long Hollow 138
kV line and (2)the Q0715 point of interconnection (POI)-Railroad 138 kV line.The
outage of either the Railroad -Painter 138 kV line or the Painter-Long Hollow 138 kV
line results in an increase of the power flow on the Q0715 POI-Railroad 138 kV line.
PacifiCorp uses the highest available emergency rating for facilities based on its weak
link data base.Duringthe recent restudy for the Uinta wind project the highest rating for
the segment in question was 256 mega-volt ampere (MVA).Study results indicated that
the loading on the Q0715 POI -Railroad 138 kV line was below its 30-minute
emergency rating and was within the reliability criteria.The availabilityof the 30 minute
line rating led to the change of results.The picture below shows the most current
available rating associated with the WhitneyCanyon Tap -Railroad 138 kV line and the
Q0715 generator project will be interconnecting to this line.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.19
DPU Data Request 22.19
Vail Second SupplementalDirect.Refer to Exhibit RAV-5SS,Q0706 Facilities Study
Report.Exhibit p.4/18 notes that the study assumed both Gateway West and Gateway
South project were in service.
(a)Why were these projects assumed in service for the purposes of this study?
(b)Who decides on assumptions used for the study?i.e.Applicant,PacifiCorp,
PacifiCorp Transmission,etc.
(c)Will there be any limitations on operation of the facility until Gateway South is done?
i.e.curtailment,etc.
Response to DPU Data Request 22.19
(a)Please refer to the Company's Response to DPU Data Request 22.13(a).In addition,
the requested point of interconnection for Q0706 project is Aeolus substation.Aeolus
substation is a portion of the Energy Gateway West project which,at the time the
referenced March 3,2017 study was performed,was not assumed to be constructed
until 2024.Energy Gateway South was also assumed to be constructed in 2024,so the
study assumed both Gateway West and Gateway South projects would be in-service.
(b)PacifiCorp Transmission determines the assumptions that will be used for each
individual study based on a variety of factors,includingload forecasts,planned
transmission projects,future transmission configuration,lower-queued generator
interconnection projects,and associated improvements.
(c)The Energy Gateway D.2 segment is a sub-segment of Energy Gateway West.Once
Energy Gateway South and Energy Gateway West (between Aeolus and Populus)are
completed,transfer capability will increase substantially.Until that time,transfer
capability will be established and limited to the Aeolus West limits which are
currentlyunder study.Please refer to the Company's response to DPU Data Request
22.5,specifically Attachment DPU 22.5,for additional information.
17-035-40 /Rocky Mountain Power
March 15,2018
DPU Data Request 22.21
DPU Data Request 22.21
Link Second SupplementalDirect.Refer to lines 136-144,regarding the incorporation of
interconnection queue position in bid selection.
(a)Did interconnection queue position take preference over bid economics in the project
selection process for bids in the constrained area of PacifiCorp's transmission
system?For example,could PacifiCorp have selected the McFadden Ridge instead of
Ekola Flats,even though it is farther down in the interconnection queue?Provide all
documentation supporting this response.
(b)If the answer to the second question of part (a)is no,why did the Company identify
McFadden in the initial shortlist instead of Ekola Flats?
Response to DPU Data Request 22.21
(a)Yes.PacifiCorp's Open Access Transmission Tariff (OATT)is a Federal Energy
Regulatory Commission-approved tariff that requires PacifiCorp transmission to
process and grant interconnection queue requests on a sequential basis and takes
precedence over bid economics.
No.PacifiCorp could not select McFadden Ridge over Ekola Flats because of OATT
interconnection queue processing rules.
(b)Both projects were selected to the 2017 Renewable Request for Proposals (2017R
RFP)initial shortlist due to bid economics.In the final shortlist evaluation using the
System Optimizer (SO model)and planning and risk (PaR)model production cost
modeling during late December2017 was also based on least-cost economics,given
the limited interconnection capability assumed at the time,and did not factor in the
interconnection queue position of the selected bids.When the interconnection-restudy
results were applied in early February 2018,it also identified that up to 1,270
megawatts (MW)of bids could be located in this area of PacifiCorp's transmission
system,after setting aside 240 MW for an interconnection customer with an executed
interconnection agreement.PacifiCorp also updated its portfolio studies which
eliminated bids located in the constrained area of PacifiCorp's transmission system in
eastern Wyomingthat have an interconnection-queueposition greater than Q0712.
This resulted in the elimination of the Company's McFadden Ridge II benchmark bid
and the addition of the Company's Ekola Flats benchmark bid.