20180329PAC to Staff UT UAE Set 5 (1-29) (3).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PACIFICORP
March 16,2018
Gary A.Dodge
PhillipRussell
HATCH,JAMES &DODGE
10 West Broadway,Suite 400
Salt Lake City,Utah 84101
gdodge@hidlaw._co_m (C)
Kevin Higgins
Neal Townsend
ENERGY STRATEGIES
215 S.State Street,#200
Salt Lake City,UT 84111
[e-mail] (C)
[e-mail](C)(W)
RE:UT Docket No.17-035-40
UAE 5th Set Data Request (1-29)
Please find enclosed Rocky Mountain Power's Response to UAE 5th Set Data Request 5.19.
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 Peac/DPU [e-mail] (C)(W)
Aliea Afnan/DPU [e-mail] (W)
jbower@gay_markea.com (W)
Philip Hayet/OCS [e-mail]_m (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 16,2018
UAE Data Request 5.19
UAE Data Request 5.19
Reference the SupplementalDirect and Rebuttal Testimony of Rick V.Vail,lines 767
through 770:Mr.Vail states that "[t]he 12 percent figure represents the current level of
ATRR funded by OATT customers."
(a)Please confirm that PacifiCorp assumed that the proportion of ATRR funded by retail
customers will not increase as a result of acquiring the Wind Projects and
Transmission Projects?If no,please explain.
(b)Please explain how PacifiCorp Transmission ATRR costs are allocated between
Network Integration Transmission Service and Point-to-Point transmission
customers?
(c)Please identifybillingdeterminants used for Network Integration Transmission
Service and Point-to-Point transmission customers,and explain why the billing
determinants are appropriately used for the respective services?
(d)Please identify the transmission service PacifiCorp plans to use with respect to the
Wind Projects (i.e.Network Integration Transmission Service or Point-to-Point
Transmission Services).
(e)Pursuant to its OATT,is PacifiCorp allowed to designate front office transactions as a
network resource?If no,please explain why not,and identify the transmission service
used to deliver front office transactions to load?
(f)Does PacifiCorp intend to terminate any Point-to-Point transmission rights,in the
event that the Transmission Projects and Wind Projects are constructed?If yes,please
identify each reservation,which PacifiCorp intends to tenninate.
(g)Please explain how PacifiCorp loads served by Point-to-Point transmission are
considered in the determination of PacifiCorp's MonthlyNetwork Load for purposes
of PacifiCorp's Network Integration Transmission Services.
(h)Does PacifiCorp agree that its MonthlyNetwork Load will increase if the
Transmission Projects and Wind Projects are constructed due to the fact that a greater
portion of its load will be served by Network Resources (i.e.the Wind Projects),
rather than through Point-to-Point transmission (i.e.Front Office Transactions).If no,
please explain.
(i)Does PacifiCorp agree that,if its MonthlyNetwork Load were to increase as a result
of constructing the Transmission Projects and Wind Projects,and assuming no
changes to reserved Point-to-Point transmission rights,that the proportion of ATRR
funded by retail customers would also increase?If no,please explain.
17-035-40 /Rocky Mountain Power
March 16,2018
UAE Data Request 5.19
(h)No.Construction of the Transmission Projects and Wind Projects by itself and
designatingthe resources as network resources does not alone increase PacifiCorp's
Monthly Network Load.The total cost of transmission is dependent on retail
consumption and the relative share of any increase or decrease in load compared to
third-partytransmission use.In addition,if energyis required to serve load through
importing energy into PacifiCorp's BAAs then the cost of that transmission would
include both the utilization of PacifiCorp's transmission as well as any third-party
transmission necessary to wheel the energy to serve load.
(i)No.Construction of the Transmission Projects and Wind Projects would not alone
indicate or lead to an increase in PacifiCorp's MonthlyNetwork Load.As described
in responses to other subparts,the cost of transmission is based on system loads and
reservations of long-term and short-term PTP transmission.
17-035-40 /Rocky Mountain Power
March 16,2018
UAE Data Request 5.19
Response to UAE Data Request 5.19
The Company objects to these requests as overlybroad and not reasonably calculated to
lead to the discovery of admissible or relevant evidence.Without waiving these
objections,the Company responds as follows:
(a)The analysis assumes that the added cost of transmission is allocated based on
estimates of the current allocation between retail and third-partycustomers.The cost
of transmission is allocated between customers based on peak coincident loads,long-
term point-to-point(PTP)contract capacity,and short-term reservations purchased.
The allocation of transmission depends on the future mix of loads and long-term and
short-term capacity.Therefore,the additional wind generation added in Wyoming
does not directlycorrelate to additional transmission costs.These resources could be
added and designated as additional network resources and optimized in real-time as
part of the energy imbalance market (EIM).Therefore,no determination has been
made that additional generation results in additional transmission cost.
(b)Transmission costs are allocated to transmission customers based on the customer's
relative share of peak loads,long-term PTP capacity,as well as short-term
reservations purchased on the Open Access Same-Time Information System
(OASIS).A transmission customer with network integration transmission service is
assessed transmission charges based upon the customer's load at time of the system's
coincident peak.
(c)The billingdeterminant for network service is transmission customer network load
grossed up for stated losses in PacifiCorp's Open Access Transmission Tariff
(OATT).Long-term PTP transmission capacity is assessed on customer contract
capacity plus the capacity loss factor as stated in PacifiCorp's OATT.These billing
determinants are appropriatebecause they are comparable and represent the
utilization of the transmission system.
(d)Network Integration Transmission Service (NITS).
(e)PacifiCorp may designate front office transactions (FOT)as a network resources
provided they meet the designation requirements of the OATT.
(f)No.
(g)This question appears to assume that PacifiCorp's merchant function is utilizingon-
system resources under PTP contracts to serve load in other balancing authorityareas
(BAA).In this case,PacifiCorp is allocated a share of PacifiCorp's transmission cost
based on the capacity of these long-term PTP contract rights.PacifiCorp also pays
third-partytransmission service providers for load service outside of PacifiCorp's
transmission system.