20180329PAC to Staff UT OCS Set 15 (1-20) (2).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PACIFICORP
March 8,2018
Béla Vastag
Office of Consumer Services
160 East 300 South
Salt Lake City,Utah 84111
1bvastag@utah ov (C)
RE:UT Docket No.17-035-40
OCS 15th Set Data Request (1-20)
Please find enclosed Rocky Mountain Power's Responses to OCS 15th Set Data Requests l15.1,
15.3-15.9,and 15.12.The remaining responses will be provided separately.Also provided are
Attachments OCS 15.3 and 15.6.Provided on the enclosed Confidential CD is Confidential
Attachment OCS 15.4.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,
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)
Phillip Russell/UAE [e-mail] (C)
Kevin Higgins/[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 8,2018
OCS Data Request 15.1
OCS Data Request 15.1
Refer to Mr.Vail's Second SupplementalTestimony at line 14,in which he states that
"the Company's transmission function fmalized a broader open access transmission tariff
restudy process,which included producing system impact restudy ("SISs")reports for the
followingthree Wind Projects".
(a)What does Mr.Vail mean by a "broader open access transmission tariff restudy
process"?
(b)If the study process is broader,why were system impact restudy reports still produced
for the three wind projects?
(c)At line 80,Mr.Vail stated,"The Company's transmission function did not perform
the restudies in conjunctionwith the 2017R RFP process."What is significant about
the fact that restudies were performed,justnot in conjunction with the 2017R RFP
process,and using a broader process?
Response to OCS Data Request 15.1
(a)The phrase "broader open access transmission tariff restudy process"was used to
indicate that the restudy process was not specific to the 2017R Request for Proposals
shortlist.
(b)The three wind projects were among the generator interconnection requests whose
interconnection studies were impacted by the updates to the Company's long-term
transmission plan to include construction of the Energy Gateway Aeolus-to-
Bridger/AnticlineD.2 segment to come online by 2020.
(c)The statement by Mr.Vail was in response to a question as to why the restudies were
not performed earlier so they could be analyzed earlier in the 2017 Renewable
Request for Proposals (2017R RFP)process.Mr.Vail was clarifyingthat PacifiCorp
transmission performed the restudies in accordance with the procedures in its Open
Access Transmission Tariff (OATT),not due to the request for proposals.
17-035-40 /Rocky Mountain Power
March 8,2018
OCS Data Request 15.3
OCS Data Request 15.3
At line 35,Mr.Vail states,"In accordance with its OATT,the Company's transmission
function performed restudies in serial queue order to determine whether the acceleration
of Energy Gateway segment D.2 would impact the cost or timing of interconnection of
projects that had not yet executed interconnection agreements and that had previous
studies dependingon Energy Gateway West in its entirety".
(a)Please provide a copy of the queue as it existed at the time that the Company
performed the transmission restudies.
(b)Please provide a complete list of projects that had previous studies dependingon
Energy GatewayWest in its entirety.
(c)Why was it important whether the projects had already executed interconnection
agreements?
(d)Why in Direct Testimony did the Company reserve 320 MW of capacity for a QF that
had executed PPAs with PacifiCorp (Mr.Link's Direct Testimony,line 484),and had
preferential positions in the transmission queue?How and why has consideration of
and treatment of that QF changed in this Second Supplemental Testimony,given
when Direct was filed the 320 MW QF did not have an executed interconnection
agreement?
(e)How did PacifiCorp differentiate between those projects that would only require the
D2 segment upgrade and those projects that required additional Gatewayprojects to
be completed before they could be interconnected?
Response to OCS Data Request 15.3
(a)Please refer to Attachment OCS 15.3.
(b)Please refer to the Company's response to subpart (a)above.
(c)Executed interconnection agreements are not subject to ongoing restudies.
(d)This 320 megawatt (MW)qualifying facility (QF)project was used as a proxy
resource in the Company's initial economic analysis.At that time,the 2017
Renewable Request for Proposals (2017R RFP)had not yet been released to the
market,and it was not clear whether this project would participate in the 2017R RFP.
This project was not included in the 2017R RFP final shortlist,it requires
interconnection facilities beyond the Aeolus-to-Bridger/Anticlinetransmission line
that cannot be built until 2024,and it is no longer included in the Company's
economic analysis of the Combined Projects.
17-035-40 /Rocky Mountain Power
March 8,2018
OCS Data Request 15.3
A 240 MW QF project that has an executed LGIA that does not require the
construction of the Aeolus-to-Bridger/Anticlinetransmission project was instead
included.
(e)As noted in the quoted passage,PacifiCorp transmission performed restudies in serial
queue order to determine whether the acceleration of Energy Gateway segment D.2
would impact the cost or timing of interconnection of projects that had not yet
executed interconnection agreements and that had previous studies depending on
Energy GatewayWest in its entirety.If a project could interconnect with only
Energy Gateway segment D.2 (as opposed to Energy GatewayWest in its entirety),
then PacifiCorp transmission reflected this updated interconnection requirement in
the project's interconnection restudy report.PacifiCorp transmission continued this
evaluation in serial queue order until the interconnection capability of Energy
Gateway segment D.2 was exhausted,at which point requests for interconnection in
that constrained area of PacifiCorp's transmission system require additional Gateway
projects beyond just Energy Gateway segment D.2.
17-035-40/Rocky Mountain Power
March 8,2018
OCS Data Request 15.4
OCS Data Request 15.4
At line 39,Mr.Vail noted that the Company posted SIS reports on January 29,2018 and
on February 9th
(a)Please provide and identify the reports that were posted on January 29th
(b)Please provide and identify the reports that were posted on February 9th
Response to OCS Data Request 15.4
Please refer to Confidential Attachment OCS 15.4.
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 8,2018
OCS Data Request 15.5
OCS Data Request 15.5
Refer to line 56 of Mr.Vail's testimony.How was the point in the interconnection queue
determined (projects after Q0712)at which point more than justthe D2 upgrades would
have to be implemented to allow additional projects to be interconnected?
Response to OCS Data Request 15.5
Through transmission planning studies completed for the interconnection system impact
study (SlS)that showed that PacifiCorp transmission could not interconnect the project to
the system with only Energy Gateway segment D.2 and still maintain a safe reliable
operating transmission system.
17-035-40 /Rocky Mountain Power
March 8,2018
OCS Data Request 15.6
OCS Data Request 15.6
At line 100,Mr.Vail refers to exhibit RAV-lSS,which provides additional detail on the
network upgrades.It seems that RAV-1SS was some work product taken from another
report or document that the Company produced.If so,please provide that other report or
document.
Response to OCS Data Request 15.6
The network upgrades are a compilation of improvements identified through the
interconnection study process and refinement of the substation layouts.Please refer to
Attachment OCS 15.6,which provides copies of the system impact studies (SIS)
performed for Ekola Flats (Q0706),TB Flats I (Q0707),TB Flats II (Q0708),Cedar
Springs I (Q0712),Uinta I (Q0715)and Uinta II (Q0810).
17-035-40 /Rocky Mountain Power
March 8,2018
OCS Data Request 15.7
OCS Data Request 15.7
Refer to RAV-2SS at page 3 of 35.
(a)Is the Midway-Jordanelle 138 kV line under construction?What impact would occur
if the Company were to proceed to interconnect the Uinta I project,but the Midway-
Jordanelle 138 kV line was not in fact completed by 2019?
(b)What would have to happen if in fact the point of interconnection were moved farther
away than .3 miles?
Response to OCS Data Request 15.7
(a)No,the Jordanelle-Midway line is not yet under construction.Should the line not be
in-service prior to interconnecting the Uinta I project,modifications to the Naughton
remedial action scheme (RAS)may be required.
(b)Studies are conducted with the information provided by the customer.If the point of
interconnection (POI)were to move the new location,it would need to be reviewed
and a determination made if there are any impacts.At this time there is no
information concerning possible changes or the impacts.
17-035-40 /Rocky Mountain Power
March 8,2018
OCS Data Request 15.8
OCS Data Request 15.8
Refer to RAV-2SS at page 30 and 32 of 35.
(a)Why was the request for Uinta II dependent on Q0786 being completed?What
happens to Uinta II if that project is not completed before Uinta II is completed?
(b)Why wasn't the request for Uinta I dependent on Q0786 being completed?
(c)Why was the Commercial Operation date specified for Uinta II as July2019,but the
Commercial Operation date for Uinta I as October 2020?
Response to OCS Data Request 15.8
(a)Uinta II is assigned Q0810 in PacifiCorp's generation interconnection queue,which
means Q0786 has a higher priority.Certain requirements for the Q0786 project are
also required for the Q08 10 project.In accordance with the open access transmission
tariff (OATT)interconnection study process,the interconnection study for the Q0810
project assumes the interconnection requirements of the Q0786 project are in-service,
and the Q810 would be responsible for the requirements (and associated costs)
identified in Q786's studies if those requirements are not completed by Q0786
project.
(b)Uinta I is assigned Q0715 in PacifiCorp's generationinterconnection queue,which
means Q0715 has a higher priority and is not dependent on the lower-priority
requirements of Q0786.
(c)The dates were requested by the interconnection customer.
17-035-40 /Rocky Mountain Power
March 8,2018
OCS Data Request 15.9
OCS Data Request 15.9
Refer to RAV-3SS at pages 6 and 15 of 40.
(a)Explain what this means in detail:"Remedial Action Scheme (RAS)that will arm
approximately 640 MW of generation for the followingoutages is assumed to be in
service."Be sure to discuss and explain about the 640 MW of generation.
(b)Please explain why the latest report cannot confirm that the project will be complete
by November 1,2020 in a more definitive manner.It states that this report "may
support"the November 1,2020 date.
(c)When will the Facilities Report be conducted and when is it expected to be
completed?If the schedule will further be developed and optimized then,what
potentiallycould be detennined to the cost and schedule in that study?
Response to OCS Data Request 15.9
(a)In support of the D.2 Project (Bridger/Anticline-Aeolus)transmission facilities and
subsequent creation of the Aeolus West transmission path,a remedial action scheme
(RAS)is planned that will trip up to 640 megawatts (MW)of generationin southeast
Wyomingfor outage of the D.2 project facilities between Bridger and Aeolus.The
amount of generationthat will be tripped will be a function of the flow on the Aeolus
West path justprior to the loss of one of the D.2 elements and could be less than 640
MW and is in adherence to North American Electric Reliability Corporation (NERC)
reliabilityguidelines.
(b)PacifiCorp's Transmission system impact study (SIS)reports include a preliminary
indication of the length of time that would be necessary to correct any problems
identified in the analysis and is not binding.The actual commercial operations date
(COD)will be agreed to between the parties and documented in the interconnection
agreement.
(c)PacifiCorp anticipates that the facilities study report will be completed in June 2018.
A detailed schedule will be developed by PacifiCorp's construction project
management team as part of that study.
17-035-40 /Rocky Mountain Power
March 8,2018
OCS Data Request 15.12
OCS Data Request 15.12
Refer to RAV-4SS at page 3 and 17 of 23.
(a)Why does this indicate Cedar Springs I is a 520 MW project,while Mr.Link's
testimony indicates that the project is 400 MW.What happened to the other 120
MW,did the developer only bid in 400 MW of the 520 MW project to the RFP?If
so,does PacifiCorp know why only 400 MW was bid in?
(b)Was the entire network upgrade cost of $51.8 million included in the economic
evaluation Mr.Link performed?If not,what amount was included and why was that
amount included?
(c)How could the Company include this project if it requires 24 -36 months,and may
not be completed by the requested commercial operation date of December 31,2020?
(d)When will the Facilities Study be completed?If the schedule will further be
developed and optimized then,what potentiallycould be determined to the cost and
schedule in that study?
Response to OCS Data Request 15.12
(a)In the 2017R Request for Proposals (2017R RFP),the customer bid the project in as a
400 megawatt (MW)project with no explanation of why 400 MW was chosen.
(b)Referencing Exhibit RMP_(RAV-4SS),page 17 of 23,the network upgrade cost for
Cedar Springs was $48.74 million.This cost was included in the economic
evaluation,which assumed 88 percent of the network upgrade would be recovered
through rates and included in the revenue requirement,while the remainder would be
recovered through transmission usage charges and not included in the revenue
requirement.
(c)Please refer to the Company's response to OCS Data Request 15.9 subpart (b).
(d)PacifiCorp anticipates that the facilities study report will be completed in June 2018.
A detailed schedule will be developedby PacifiCorp's construction project
management team as part of that study.