20180329PAC to Staff UT OCS Set 15 (1-20) (6).pdf

1407 W.NorthTemple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PAciF1CORP
March 21,2018
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*Set Data Request (1-20)
Please find enclosed Rocky Mountain Power's 16'Revised Responses to OCS 15*Set Data
Requests 15.15 and 15.18.Provided on the enclosed Confidential CD is Confidential Response
OCS 15.15 16t Revised and Confidential Attachment OCS 15.18 16'Revised.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)
Philip Hayet/OCS [e-mail] (C)
Gary A.Dodge/UAE [e-mail] (C)
Phillip Russell/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 [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/[e-mail](W)
Chad C.Baker/UIEC [e-mail] (W)
17-035-40 /Rocky Mountain Power
March 21,2018
OCS Data Request 15.15 -16t Revised
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 equipmentto 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.
1"Revised Response to OCS Data Request 15.15(c)
The Company is providing this revised response to correct inadvertently redacted
language in subpart c to the Company's original response to OCS 15.15,dated March 12,
2018.
(c)Please refer to Confidential Attachment OCS 15.15,which provides written
documentation received from Invenergydiscussing safe harbor equipment purchases.
The Company advised Invenergythat it would not require their equipment pursuantto
the developmenttransfer agreement DTA Invenergy.
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 21,2018
OCS Data Request 15.18 -1st Revised
OCS Data Request 15.18
Please provide all written communication including emails,letters,etc to and from Ekola
Flats between January 1,2018 and February 18,2018.
16*Revised Response to OCS Data Request 15.18
Upon further review,the Company concluded that some of the attached emails included
in the original OCS 15.18 response were not relevant in the case or were relevant but
deemed highly confidential.As such,some of the attached emails were pulled or
reclassified as highly confidential.The following1"Revised Response replaces the
Company's originalresponse to OCS 15.18,sent March 12,2018,in its entirety.
The Company objects to the request on the basis that it is vague,overly broad 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,Attach OCS 15.18-1 16'REVISED CONF,for
Company written communications with Invenergyrelated to the Ekola Flats project
between January 1,2018 and February 18,2018.
The Company has additional written communication which contains commercially
sensitive informationand is considered highly confidential.Please contact Jana Saba at
[phone] or Yvonne Hogle at [phone] to make arrangements for review.
Confidential information is provided subject to Public Service Commission of Utah Rule
746-1-602 and 746-1-603.