20180329PAC to Staff UT OCS Set 16 (1-11) (2).pdf

1407 W.NorthTemple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DMSt0N OF PACIFICORP
March 26,2018
Béla Vastag
Office of Consumer Services
160 East 300 South
Salt Lake City,Utah 84111
bvastag@utahgov (C)
RE:UT Docket No.17-035-40
OCS 16th Set Data Request (1-11)
Please find enclosed Rocky Mountain Power's Responses to OCS 16th Set Data Requests 16.1-
16.6 and 16.9.The remaining response will be provided separately.Provided on the enclosed
Confidential CD is Confidential Attachment OCS 16.9 and Confidential Responses OCS 16.2
and 16.9.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 d&(C)(W)
Aliea Afnan/DPU [e-mail] (W)
jbowe_r@glayniake_a.com (W)
Philip Hayet/OCS p_hay_et@j]senn.com (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/UIEC [e-mail](W)
Chad C.Baker/UIEC [e-mail] (W)
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.1
OCS Data Request 16.1
Refer to OCS 12.21 and the Company's Corrected Second Supplemental Work Paper,
"PROPRIETARY RMP Corrected EV2020 Second Supp Results Summary File -VOM
adjusted 2-23-2018.xlsx".
(a)Please explain the impacts of the Variable O&M,integration cost,and wind tax cost
correction in the solar sensitivity case and identify the resources for which corrections
were made.
(b)Please explain the impacts of the Variable O&M,integration cost,and wind tax cost
correction in the repowering sensitivity case and identify the resources for which
corrections were made.
(c)Please explain the impacts of the Variable O&M,integration cost,and wind tax cost
correction in the IE sensitivity case and identify the resources for which corrections
were made.
Response to OCS Data Request 16.1
The Company prefaces its response with the followingclarifying explanation and
example regarding the correction to the Planning and Risk (PaR)model reporting of
variable operations and maintenance (VOM)related costs:
No corrections were made to resource costs or to any inputs to the models relative to the
VOM adjustment.The error was limited to the application of resource integration costs
and the Wyoming wind tax applicable to the portfolio of selected bids in the reporting of
final results.Per the cover letter dated February 23,2018 that accompanied the
Company's Corrected Second SupplementalTestimony and specifically confidential
work paper,"EV2020 Second Supp Results Summary File -VOM adjusted CONF",
integration costs were correctly reported in the System Optimizer model (SO model)
results,but incorrectlyreported in the PaR annual results.
The impacts of the correction are included in the "Results Tables"worksheet and the
supporting PaR annual results worksheets.In the "Results Table"worksheet,the amount
of the adjustment to the levelized 2017 through 2036 results is given in column G.
The followingexample of levelized and nominal impacts refers to the confidential work
paper "EV2020 Second Supp Results Summary File -VOM adjusted",specifically the
"PaR -RFP FSLW Studies"worksheet,rows 7 through 121.
Levelized 2017 through 2036 Impact:
The PaR model results include costs associated with holding incremental regulation
reserves for the proposed new wind resources.Because PaR nativelyassesses these
integration costs,the wind integration cost component of VOM should not have been
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.1
separately included as a cost in the PaR levelized results.The inclusion of the integration
component of VOM essentially counted wind integration costs twice (by capturing the
assumed cost included in VOM and by capturing the incremental cost of holding
additional regulation reserves).
The PaR "Total Mean System Cost"present value of revenue requirements (PVRR)of
$21,202 million reported in cell C65 includes the full integration cost in the "SO Sub-
Total Fixed Costs"reported in cell C48.The inclusion of integration costs in the PaR
PVRR means that the $333 million present value of revenue requirements differential
(PVRR(d))benefit in cell D307 is understated by $24 million,the amount of the SO
integration costs.
This is corrected by removing the integration costs from the "Cost of Project"
calculations in row 70,thereby eliminating the double-counting effect.The resulting
impact to the net (benefit)/cost reported in cell C78 is a $24 million increase in benefits.
The updated result for this case is given on the "Results Tables"worksheet in cell Dl0,
reporting a corrected PVRR(d)of $357 million in benefits.
Nominal 2017 through 2050 Impact:
In tracing through the double-counting of the integration component of VOM,the
Company also determined that the cost of the Wyoming wind tax component of VOM
was missing from the nominal economic analysis for years 2017 through 2050.This was
corrected by incorporating the wind tax cost into row 102,relabeled as "O&M/Wind Tax
-New Wind".Whereas the correction to the levelized results reports increased benefits of
$24 million,the inclusion of the Wyoming wind tax in the nominal results reduces
benefits through 2050 by $29 million.
(a)Please refer to the explanation and example given above.
(b)Please refer to the explanation and example given above.
(c)Please refer to the explanation and example given above.
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.2
OCS Data Request 16.2
Refer to the Company's Corrected Second Supplemental Work Paper,"PROPRIETARY
RMP Corrected EV2020 Second Supp Results Summary File -VOM adjusted 2-23-
2018.xlsx".
(a)Did the Company's solar RFP sensitivity and cost evaluation change in any way
between the supplemental direct and second supplemental filing?If so,please
explain.
(b)Did the company's solar RFP sensitivity and cost evaluation change in any way
between the second supplemental and corrected second supplemental filing?If so,
please explain.
(c)It appears that the solar bids selected for some portfolios are different between the
second supplemental and the corrected second supplemental filing.On the "Solar
Costs"tab,please explain why there is a change in selected solar bids between the
cases,given that the Company indicated the SO model was not affected by the
correction.Specifically,see the bid in row 12 of the "Solar Costs"tab in the above
referenced file.
(d)Similarly,on the "PaR -RFP Solar Sensitivity"tab,explain why row 59 (to-2050
GWh)is different between the second supplemental and the corrected second
supplemental filing.
(e)Please explain what cost components are included/excluded in the "new Solar VOM"
row 56 in the "PaR -RFP Solar Sensitivity"tab.
Confidential Response to OCS Data Request 16.2
(a)Please refer to the second supplemental direct testimony of Company witness,Rick T.
Link,specifically lines 405 through 408.Between the original supplemental direct
testimony and the second supplemental direct testimony filings,the 2017 Renewable
Request for Proposals (2017R RFP)final shortlist of wind bid selections changed,
and on February 1,2018,best-and-final pricing for the 2017 Solar RFP (2017S RFP)
bids became available.The Company recognized that these changes could affect the
optimized selection of both solar and wind bids in the solar sensitivity cases,
necessitating a re-run of the models.
(b)No,the Company did not change its modeling,methodology or inputs relative to the
solar sensitivity for the corrected second supplemental testimony filing.
(c)
the
work paper,consistent with the portfolio selected by System Optimizer model (SO
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.2
model)in the solar-only medium gas,medium carbon dioxide (CO2)"FSSR-MM"
sensitivity for the 2050 nominal calculation.In further review of the "Solar Costs"
tab,it was also found that the "FSSR-MM"solar-only present value of revenue
requirements (PVRR)did not include costs for the
aid costs in the solar-only,medium gas,medium CO2
2050 nominal results is that the PVRR benefit of the solar bids is overstated by $119
million,and should have been $350 million in benefits instead of $469 million.
(d)The bid inclusion issue described in subpart (c)above (affecting the 2050 nominal
Planning and Risk (PaR)model results of the solar-only medium gas,medium CO2
"FSSR-MM"sensitivity)also impacts the total generationof the solar bids in that
same case.
(e)Row 56 of the referenced "PaR -RFP Solar Sensitivity"tab includes the real
levelized network integration costs associated with the final short list solar bids.
Althoughrow 56 is categorically labeled as "Net New Solar Tax and Integration
Costs",there are no applicable solar taxes.
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 26,2018
OCS Data Request 16.3
OCS Data Request 16.3
Refer to the Company's Corrected Second SupplementalWork Paper,"PROPRIETARY
RMP Corrected EV2020 Second Supp Results Summary File -VOM adjusted 2-23-
2018.xlsx""Solar Costs"tab.Please provide all network upgrade costs (rows 4 through
13)extended through 2082.
Response to OCS Data Request 16.3
Due to the ongoing nature of the 2017 Renewable Request for Proposals (2017R RFP),
the financial models associated with the 2017R RFP that contain the derivation of inputs
used in the System Optimizer model (SO model)and the Planning and Risk (PaR)model
are considered commercially sensitive and highly confidential.The Company does not
typically permit access to commercially sensitive 2017R RFP documentationuntil the
RFP has been concluded.Please contact Jana Saba at [phone] or Yvonne Hogle at
[phone] to make arrangements for review.
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.4
OCS Data Request 16.4
The Company's response to OCS 12.10 indicates that wind resources with queue
positions higher than 712 could have been selected in the Solar Sensitivity cases.
However,the Company's response to DPU 22.22 indicates that only wind resources with
queue positions less than 712 could have been selected in cases.How did the Company
account for the interconnection queue positions in developing the portfolio for the
"SenWS"wind and solar sensitivity case?Please reconcile these DR responses.
Response to OCS Data Request 16.4
OCS Data Request Set 12 was received between the filing of the Company's
supplemental direct and rebuttal testimony (January 16,2018),and the Company second
supplemental direct testimony (February 16,2018),such that the Company's response to
OCS Data Request 12.10 refers to the set of eligible wind bids prior to the
interconnection restudy.Please refer to the second supplemental direct testimony of
Company witness,Rick T.Link,specifically page 4,line 20 through page 8,line 13.
DPU Data Request Set 22 was received subsequent to the filing of the Company's second
supplemental direct testimony,and therefore the Company's responses reflects the
impacts of the interconnection restudy.
Please refer to Mr.Link's second supplemental direct testimony,lines 136 through 170,
describing the benefits and outcomes of the initiallyexpanded pool of bids and its
reduction followingthe interconnection restudy.
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.5
OCS Data Request 16.5
Refer to the Company's response to DPU 22.22.Since the Company determinedthat up
to 1,510 MW of wind capacity could be added in the transmission constrained area,why
did the Company indicate in this response that it set the constraint in the SO model to
1,270 MW?
Response to OCS Data Request 16.5
Please refer to the second supplemental direct testimony of Company witness,Rick T.
Link,specifically lines 119 through 135.As described,the Company must reserve
sufficient interconnection capacity for this 240 megawatts (MW)capacity qualifying
facility (QF)customer,reducing the 1,510 MW total interconnection limit to a modeled
limit of 1,270 MW.
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.6
OCS Data Request 16.6
Refer to the Company's response to DPU 21.1,in which the Company was asked to
provide the updated studies concluding that the Company can interconnect up to 1,510
MW of incremental wind generationbehind the TOT 4A/TOT 4B constraint.
(a)See footnote 2,which states that "Subsequent to the initial announcement,technical
studies have demonstrated that as high as 1,510 MW can be integratedeast of
Bridger/Anticline."Provide an explanation of the step-by-step process that the
Company conducted to determine that as much as 1,510 MW could be integrated.
(b)Provide copies of the technical studies indicating as much as 1,510 MW could be
integrated.
(c)How did it even come to PacifiCorp's attention that nearly 250 MW more capacity
could be integrated,when the Company had originally thought just 1,270 MW could
be integrated?
(d)Refer to Appendix A of that same report at Section 1.3.The last sentence prior to the
start of Section 1.4 states the path rating is 2,670 MW East to West based on the full
Gateway project.Explain what the 2,670 MW path rating means and how it relates to
the 1,510 MW transfer limit.
(e)Explain why the analysis assumed the full Gateway Project would be completed.
Also,explain what the path rating would have been if it had only been based on the
D2 portion of the Gateway project.
(f)Explain what this means at the start of section 1.3 -"New:Aeolus West replaces
TOT 4A."Also,explain the fact that Section 1.2 defines Path TOT 4A,and then
Section 1.3 states that it is replaced.
(g)The Conclusion section of the Assessment report at page 3 states that the path can
transfer up to 1,792 MW.What is the relationship between this amount of transfer
capacity and the 1,510 MW that Mr.Link said can now be integrated?Should Mr.
Link have in fact stated that up to 1,792 MW could have been integrated?
(h)Explain why the SO analyses did not use 1,792 MW as the constraint for the amount
of wind that could be integrated.
Response to OCS Data Request 16.6
(a)The referenced study report (Aeolus West Transmission Path Transfer Capability
Assessment,Revision 2.0,February 2018)included 1,510 megawatts (MW)of new
wind resources upstream of the Aeolus West transmission path.Table 1,indicates
that 1,731 MW of new generation was added in Wyoming,of which 1,270 MW was
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.6
added in southeast Wyoming (Aeolus,Shirley Basin,Windstar)and 240 MW was
added in northern Wyoming (Bighorn Basin).The southeast Wyoming plus Bighorn
Basin resources (1,270 MW +240 MW)total 1,510 MW,and are located upstream of
the Aeolus West path.The 1,510 MW resource level referenced is the total resources
integrated east of the Aeolus West transmission path to achieve Aeolus West path
flows of 1792 MW,with only D.2 Project facilities added.The referenced study
report provides the step-by-step process that the Company used to determine that this
level of generationcould be integrated.
(b)Please refer to the Company's response to subpart (a)above.
(c)As stated in subpart (a),the 1,270 MW of new generationnoted was integrated in
southeast Wyoming while an additional 240 MW of generationwas integrated in the
Bighorn Basin.Both of these areas are geographically upstream of the Aeolus West
transmission path.
(d)The full Energy Gateway Project includes Energy Gateway West,Energy Gateway
Central and Energy Gateway South project facilities.With all of these facilities
constructed,the total transfer capability (TTC)of the Aeolus West transmission path
will be 2,670 MW.As a sub-segment of the Energy Gateway West project,
PacifiCorp will be constructing the D.2 Project (Bridger/Anticline-Aeolus),which
will result in the formation of the Aeolus West transmission path (see footnote 1 in
referenced study report above).The 1,510 MW resource level referenced is the total
resources integratedeast of the Aeolus West transmission path to achieve an Aeolus
West TTC of 1,792 MW,with only D.2 Project facilities added.This TTC level
reflects an effective increase in transfers east to west across Wyoming of 914.5 MW
(e)Appendix A includes an excerpt from the most recent Western Electricity
Coordinating Council (WECC)Path Rating Catalog and is included to provide path
definitions.While Appendix A did note the Aeolus West path rating for the full
Energy Gateway Project,this is provided as a reference only.The main body of the
subject report focused on the assessment Aeolus West Transmission Path Transfer
Capability once the D.2 Project is completed.
(f)As noted in paragraph 2 of the Executive Summary of the subject report:The Aeolus
West transmission path is a new path that will be formed by adding the D.2 Project in
parallel with the TOT 4AI (Path 37)transmission path facilities.With the addition of
the Aeolus West transmission path,the TOT 4A path will be redefined as the lines
that emanate south and west from the Windstar/Dave Johnston area.
(g)The modeled capacity of 1,510 MW correctly reflects considerations such as stiffness
factor,proposed resource locations and modeling granularity.Please refer to the
1 The existing TOT 4A (Path 37)transmission path is comprised of the Riverton*-Wyopo 230 kV,Platte -
Standpipe*230 kV and Spence*-Mustang 230 kV transmission lines.(*meter location)
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.6
Company's response to subparts (a)and (b)above,and also the Company's response
to OCS Data Request 15.2,and DPU Data Request 25.7.
(h)Please refer to the Company's response to subpart (g)above.
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.9
OCS Data Request 16.9
CONFIDENTIAL REQUEST-On pages 26 and 27 of Mr.Link's Second
Supplemental Direct Testimony,he discusses the possibility that low stiffness may still
exist after adding the shortlist projects,even after constructing the 500 kV D2 segment
and 230 kV upgrades.
(a)When did the Company first discover that low stiffness may still exist with the final
shortlist projects?Also,explain the studies that were performed that led to this
conclusion,and provide the analyses and work papers performed that led to this
conclusion.
(b)See line 522 of Mr.Link's Second Supplemental Direct Testimony containing the
range of incremental in-service transmission upgrade costs associated with adding a
synchronous condenser at the Aeolus substation.Please provide the analysis and
work papers,electronically,that the Company performed to determine the maximum
capital investment that would still lead to the shortlist projects being economic.
(c)Please describe all studies the Company will have to perform to determine whether a
synchronous condenser will be required along with the shortlist projects,and state
when the Company expects those studies will be completed.As a continuing request,
please provide those studies when they have been completed.
(d)If in fact it turns out that the cost of the synchronous condenser actually exceeds the
maximum capital investment cost that would still lead to the shortlist projects being
economic,will the Company pursue the Sensitivity projects instead?If so,how will
the Company do that,and if not why not?
Confidential Response to OCS Data Request 16.9
(a)Based on industryfeedback relative to system stiffness factor implications seen in
Texas and guidelines of the North American Electric Reliability Corporation (NERC)
Reliability Guideline previously provided with the Company's response to OCS Data
Request 1.24,specifically Attachment OCS 1.24,transmission planning has been
aware of stiffness factor implications for a number of years.
Wide area short circuit ratios (WSCR)are used as a rule of thumb for preliminary
assessment of a transmission system to accommodate renewable generation.In the
WSCR work performed by Electranix,the low ratios raised warning flags.
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.9
Subsequently,power system computer aided design (PSCAD)modeling,which
simulates power system transients in greater detail were performed using detailed
General Electric (GE)wind turbine generator (WTG)models to more accurately
assess the D.2 Project transmission system as proposed in the Energy Vision 2020
project.For these simulations all new generationmodeled as GE WTGs,the results
were favorable,even with very low WSCR values.PSCAD studies are currently
being redone to evaluate the changes in the Energy Vision 2020 project generation
identified in the 2017 Renewable Request for Proposals (2017R RFP)Shortlist,which
includes both Vestas and GE WTGs.Depending on the results of the follow-on
PSCAD modeling,the need for additional facilities including the addition of a
synchronous condenser could be identified.The technical findings of the PSCAD
modeling will be made available in a report prepared by Electranix,which will be
provided to the various state commissions and stakeholders upon completion.
(b)The $55 million to $95 million tolerance for incremental in-service transmission
upgrade cost is determined by a ratio established as the net present value (NPV)of
real levelized network upgrade costs divided by the flat $10 million investment.This
ratio is then used to calculate the transmission investment cost necessary to reduce
NPV benefits to zero in the low gas,zero carbon dioxide (CO2)and medium gas,
medium CO2 cases.Please refer to Confidential Attachment 16.9.
(c)Please refer to the Company's response to subpart (a)above.
(e)
The
referenced letter is considered commercially sensitive and highly confidential.The
Company requests special handling.Please contact Jana Saba at [phone] or
Yvonne Hogle at [phone] to make arrangements for review.
17-035-40 /Rocky Mountain Power
March 26,2018
OCS Data Request 16.9
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.