20180329PAC to Staff UT OCS Set 15 (1-20) (3).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PACIFICORP
March 12,2018
Béla Vastag
Office of Consumer Services
160 East 300 South
Salt Lake City,Utah 84111
[e-mail] (C)
RE:UT Docket No.17-035-40
OCS 15 h Set Data Request (1-20)
Please find enclosed Rocky Mountain Power's Responses to OCS 15th Set Data Requests 15.2,
15.10,15.13,15.16,and 15.18-15.19.The remaining responses will be provided separately.
Also provided is Attachment OCS 15.2.Provided on the enclosed Confidential CD are
Confidential Responses and Attachments OCS 15.15 and 15.18.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)
PhillipRussell/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])
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)
1407 W.NorthTemple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PAC1FICORP
March 12,2018
Béla Vastag
Office of Consumer Services
160 East 300 South
Salt Lake City,Utah 84111
b_vastag@utahgov (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 15.2,
15.10,15.13-15.16,and 15.18-15.19.The remaining response will be provided separately.Also
provided is Attachment OCS 15.2.Provided on the enclosed Confidential CD are Confidential
Responses and Attachments OCS 15.15 and 15.18.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)
PhillipRussell/UAE [e-mail] (C)
Kevin Higgins/UAE [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 jennifer.gardner@westernresourcesorg (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 12,2018
OCS Data Request 15.2
OCS Data Request 15.2
Concerning the Company's determination that as much as 1,510 MW could now be
interconnected.
(a)For some time,the Company has been assuming that up to 1,270 MW of new
capacity could be interconnected.What has changed to allow such a dramatic
increase in capacity?Is the Company,for example,now willingto accept a greater
number of remedial action schemes?
(b)If the Company was able to determine that it can accept another 240 MW of capacity
being interconnected,was it able to determinethat another 240 MW could be
connected in the base case without the transmission upgrades?If so,was this
modeled in base case analyses,and if not,please explain whythis additional capacity
could not be associated with the base case.
(c)How was the Company able to confirm that there is sufficient stiffness factor to
connect up to 1,510 MW?Please provide the analysis and any reports that led the
Company to reach this conclusion.
Response to OCS Data Request 15.2
(a)The variation in generation levels that can be supported by the proposed transmission
facilities have ranged between 1,270 megawatts (MW)to 1,510 MW,dependingon
the assumed location of the generationinterconnections.With the selection of
resources identified in the 2017 Renewable Request for Proposals (2017R RFP),the
location of new resources have finalized supporting the 1,510 MW.
(b)The 1,510 MW identified east of the Aeolus West transmission path included the 240
MW referenced.The 240 MW wind facility was included in the base case.
Transmission upgrades associated with the projects making up the 1,510 MW are
included in the generation interconnection studies and/or the interconnection
agreements.
(c)Please refer to Attachment OCS 15.2 for a copy of the Aeolus West Transmission
Path Transfer Capability Assessment report.In parallel to the developmentof this
preliminary report,dynamic stabilitystudies 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 stability studies have
provided the confirmation that there is sufficient stiffness factor to integrate the wind
resources outlined in 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 12,2018
OCS Data Request 15.10
OCS Data Request 15.10
Refer to RAV-3SS at page 17 of 40.
(a)Please explain what the impact of the assumption that the Q0720 (80 MW Solar
project at Ravens Substation)was considered in the TB Flats SIS study?What would
happen if the solar project was not built?
(b)Why in the Solar project's SIS report did it note that the Midway-Jordanelle 138 kV
line was not assumed to be in-service?Contrast that to the fact that it had to be in-
serve in the Uinta I study.
Response to OCS Data Request 15.10
(a)Q0720 was considered in the TB Flats system impact study (SIS)because it has an in-
service date in 2018.However,it will have no material impact on the TB Flats project
whether it is constructed or not.
(b)The Q0720 project was anticipated to be in-service prior to the planned in-service
date of the of Midway-Jordanelle 138 kilovolt (kV)line.Therefore,the Q0720
project was studied assuming the line was not in-service to identify any issues that
may need to be mitigated.In contrast,the most recent study for the Uinta I project
anticipated that the project would be in-service after the anticipated 2019 in-service
date of the Midway-Jordanelle 138 kV line,and therefore,the line was assumed to be
in-service for study purposes.
17-035-40 /Rocky Mountain Power
March 12,2018
OCS Data Request 15.13
OCS Data Request 15.13
Refer to RAV-4SS at page 18 of 23.It states that QO706 was assumed to be in-service
before this project.
(a)What is the status of that project and who will be paying for the upgrades associated
with that project?
(b)A Final Facilities Study Report was included in RAV-5SS for the QO706 project.
From the Q&A at line 177 of Mr.Vail's testimony,the network upgrade costs for that
project was included in Mr.Vail's confidential Table 1,which was included in the
economic evaluation that Mr.Link conducted.Why would costs associated with a
project not selected as part of the RFP be included in the study costs?
Response to OCS Data Request 15.13
(a)The Q0706 project has executed an interconnection agreement that provides details
on the project timelines and cost responsibility for required facilities.
(b)The project was selected in the RFP final short-list and,therefore,the costs were
appropriately included.
17-035-40 /Rocky Mountain Power
March 12,2018
OCS Data Request 15.15
OCS Data Request 15.15
CONFIDENTIAL REQUEST-Refer to Mr.Teply's Second Supplemental Testimony
at line 132,which states,"The company has acquired or has rights to acquire safe-harbor
wind turbine generator equipment which it proposes to use at the Ekola Flats project as
required to meet the IRS's start-of-construction criteria for PTC eligibility".
(a)Please explain how the Company has acquired the safe harbor equipment to use at
Ekola Flats.
(b)Refer to the Company's response to OCS 8.12.The Company's confidential response
states,
Please reconcile this
statement with Mr.Teply'stestimony at line 132.
(c)Please provide any written documentation sent to or received from
discussing
safe harbor equipment purchases.
Confidential Response to OCS Data Request 15.15
(a)The Company acquired safe harbor wind turbine equipment in 2016 in order that the
McFadden Ridge II wind project would qualify for 100 percent production tax credit
(PTC)benefits.The safe harbor equipment PacifiCorp owns can be apportioned in
such a way that it qualifies the Ekola Flats and McFadden Ridge II projects for full
PTC benefits.
(b)
(c)Please refer to Confidential Attachment OCS 15.15,which provides written
documentation received from
discussing safe harbor equipmentpurchases.The Company
advised Invenergythat it would not require their equipment pursuant to the
development transfer agreement DTA
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 12,2018
OCS Data Request 15.16
OCS Data Request 15.16
Refer to Mr.Teply's testimony at line 46,which states that the Ekola Flats project is
substantively identical to the project described in direct testimony.Please explain what is
meant by "substantively",and identify any changes between the original and current
renditions of the project.
Response to OCS Data Request 15.16
The Ekola Flats new wind benchmark project described in Mr.Teply's original direct
testimony,along with all associated exhibits and sub-part exhibits,and his second
supplemental direct testimony,and along with all associated exhibits and sub-part
exhibits,presents the same project.The second supplemental filing differs only in
presentation of (1)additional and (2)updated information that has emerged between from
the date of the original filing in June 2017 and the date of the supplemental filing on
February 16,2018.Specifically,in the second supplemental filing,the wind turbine
generator (WTG)layouthas evolved and is updated;the Project area has been adjusted to
reflect property updates;the in-service capital cost was reduced;wind assessment
information was provided;the large generator interconnection agreement (LGIA)
information is now more definitive;and additional mineral rights information was
reported.
17-035-40 /Rocky Mountain Power
March 12,2018
OCS Data Request 15.18
OCS Data Request 15.18
Please provide all written communication includingemails,letters,etc to and from Ekola
Flats between January 1,2018 and February 18,2018.
Response to OCS Data Request 15.18
The Company objects to the request on the basis that it is vague,overlybroad and
ambiguous.Without waiving the objection,the Company responds as follows:
The Company is acquiring the Ekola Flats project from InvenergyWind Global,LLC.
Please refer to Confidential Attachment OCS 15.18 for written communications with
Invenergyrelated to the Ekola Flats project.
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 12,2018
OCS Data Request 15.19
OCS Data Request 15.19
CONFIDENTIAL REQUEST-Refer to page 16 of RTL-18SS containing the February
12,2018 IE Updated Final Shortlist presentation.
(a)What is the final decision as to whether
(b)Please provide the analyses and all work papers that were used to perform the
analyses discussed on page 16.
(c)
would be installed,transmission upgrades required,etc.
(d)Since PacifiCorp has committed to the Vectrin turbines,please rovide an updated
economic analysis including all costs associated
Please provide
all work papers.
Confidential Response to OCS Data Request 15.19
(a)
(b)Please refer to the Company's response to subpart (a)above.
(c)Please refer to the Com.any's response to subpart (a)above.
(d)The Company assumes that the reference to "Vectrin"was intended to be a reference
to "Vestas".Based on the foregoing assumption,the Company responds as follows:
Please refer to the Company's response to subpart (a)above.
17-035-40 /Rocky Mountain Power
March 12,2018
OCS Data Request 15.19
Confidential information is provided subject to Public Service Comrnission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.