20180329PAC to Staff WY WIEC Set 22 (1-38) (1).pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
March 20,2018
Abigail C.Briggerman,#7-5476
Holland &Hart LLP
6380 South Fiddlers Green Circle,Suite 500
Greenwood Village,CO 80111
[e-mail](C)
RE:Wyoming Docket 20000-520-EA-17
WIEC 22nd Set Data Request (1-38)
Please find enclosed Rocky Mountain Power's Responses to WIEC 22nd Set Data Requests
22.13,22.15-22.16,and 22.31-22.34.The remaining responses will be provided separately.
Also provided are Attachments WIEC 22.32,22.33,and 22.34.Provided on the enclosed
Confidential CD is Confidential Attachment WIEC 22.13.Confidential informationis provided
subject to the terms and conditions of the protective agreement in this proceeding.
If you have any questions,please call me at [phone].
Sincerely,
Stacy Splittstoesser,
Manager,Regulation
Enclosures
C.C.:Meridith Bell/WPSC [e-mail](C)
Lori L.Brand/WPSC [e-mail] (W)
John Burbridge/WPSC [e-mail] (W)
Michelle Bohanan/WPSC [e-mail] (W)
Kara Seveland/WPSC [e-mail](W)
Morgan Fish/WPSC [e-mail] (W)
Dave Walker/WPSC [e-mail] (W)
Perry McCollom/WPSC (W)
Patti Penn/WIEC [e-mail](W)
Thor Nelson/WIEC [e-mail] (C)(W)
Emanuel Cocian/WIEC [e-mail](W)
Adele Lee/WIEC [e-mail] (W)
Nik Stoffel/[e-mail] (C)(W)
Christopher Leger/OCA [e-mail] (C)
Crystal J.McDonough/[e-mail] (C)
Callie Capraro/NLRA [e-mail]
Lisa Tormoen Hickey/[e-mail] (C)
Brandon L.Jensen/RMSC [e-mail] (C)
Roxane Perruso/TOTCO [e-mail]
Jane M.France/TOTCO jfrance(äispkm.ore (C)
Constance E.Brooks/Anadarko [e-mail](C)
Danielle Bettencourt/Anadarko [e-mail](C)(W)
Paul Kapp/Anadarko [e-mail] (C)
Lisa Christian/TOTCO [e-mail] (C)
J.Kenneth Barbe/Southland [e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.13
WIEC Data Request 22.13
Please provide the results of the nominal revenue requirements analysis for the low gas,
zero CO2 case for the new sensitivity analysis discussed in Mr.Link's Supplemental
Rebuttal Testimony for the Solar PPA Option and the Combined Projects through 2036
and through 2050.
Response to WIEC Data Request 22.13
Please refer to Confidential Attachment WIEC 22.13.
Confidential information is provided subject to the terms and conditions of the protective
agreement in this proceeding.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.15
WIEC Data Request 22.15
Please provide the PVRR(d)for all nine price policy scenarios resulting from the nominal
revenue requirements analysis though 2036 for the Solar PPA Option
Response to WIEC Data Request 22.15
The Company has not performed the requested analysis.For those price-policy scenario
in which the Company has performed sensitivity analysis of solar power purchase
agreement (PPA)bids submitted into the 2017 Renewable Request for Proposals (2017R
RFP),the WyomingIndustrial Energy Consumers (WIEC)is in possession of the
required information to perform this calculation on its own.
Please refer to the confidential work papers supporting the second supplemental direct
testimony of Company witness,Rick T.Link,specifically the work paper "EV2020
Second Supp Results Summary File -VOM adjusted".The worksheet "PaR -RFP Solar
Sensitivity"includes the annual change in nominal revenue requirement associated with
sensitivities that include solar PPA bids over the 2017 through 2050 timeframe (rows
121,242,363,and 484).
Please also refer to the confidential work papers supporting Mr.Link's supplemental
rebuttal testimony,specifically the work paper "Solar Portfolio 2 ONLY Analysis Detail
Summary File".The worksheet "PaR -SR CO2,Scalars +0.5Cap"includes the annual
change in nominal revenue requirement associated with a sensitivity that includes solar
PPA bids over the 2017 through 2050 timeframe (rows 117).
Please also refer to the Company's response to WIEC Data Request 22.13,specifically
Confidential Attachment WIEC 22.13.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.16
WIEC Data Request 22.16
Please provide the PVRR(d)for all nine price policy scenarios resulting from the nominal
revenue requirements analysis though 2050 for the Solar PPA Option
Response to WIEC Data Request 22.16
Please refer to the Company's response to WIEC Data Request 22.15.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.31
WIEC Data Request 22.31
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at page 30,
lines 7-12.
(a)Did either of the IEs compare the standalone benefits of the solar resources included
in the solar sensitivity to the standalone benefits of the Combined Projects?If yes,
please identifythe specific section of the IE report(s)that address the comparative
benefits of the solar PPAs and Combined Projects on a standalone basis.
(b)Please describe the scope of the Oregon IE's responsibilities regarding the
Company's analysis of the 2017S RFP.
(c)Please describe the scope of the Utah IE's responsibilities regarding the Company's
analysis of the 2017S RFP.
Response to WIEC Data Request 22.31
(a)The Company cannot speak on behalf of the independentevaluators (IE).However,
the Company provided the IEs with solar sensitivity results as summarized in the two
IE presentations provided with the corrected second supplemental direct testimony of
Company witness,Rick T.Link,specifically HighlyConfidential Exhibit
RMP_(RTL-8SS).An additional highly confidential IE presentation is available.
This highly confidential presentation is highly confidential and commercially
sensitive.The Company requests special handling.Please contact Stacy Splittstoesser
at [phone] or Yvonne Hogle at [phone] to make arrangements for
review.
(b)The Oregon and Utah IEs retained to monitor the 2017 Renewable Request for
Proposals (2017R RFP)did not monitor implementation of the 2017 Solar RFP
(2017S RFP).However,both IEs were aware of the 2017S RFP,and as noted in the
Company's response to subpart (a)above,the Company provided the IEs solar
sensitivitystudies develop during the 2017R RFP bid-evaluation and selection
process.
(c)Please refer to the Company's response to subpart (b)above.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.32
WIEC Data Request 22.32
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at page 39.
(a)Was Table 1-SR based on a levelized or nominal analysis?
(b)If Table 1-SR was based on a levelized analysis,please provide a version of Table 1-
SR using a nominal analysis.
Response to WIEC Data Request 22.32
(a)This analysis was performed using the Company's System Modeling methodology
through 2036,with nominal application of production tax credits (PTC),as
applicable,and levelized application of revenue requirement from capital
investments,as applicable.
(b)Please refer to Attachment WIEC 22.32.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.33
WIEC Data Request 22.33
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at page 41.
(a)Was Table 2-SR based on a levelized or nominal analysis?
(b)If Table 2-SR was based on a levelized analysis,please provide a version of Table 1-
SR using a nominal analysis.
Response to WIEC Data Request 22.33
(a)This analysis was performed using the Company's System Modeling methodology
through 2036,with nominal application of production tax credits (PTC),as
applicable,and levelized application of revenue requirement from capital
investments,as applicable.
(b)Please refer to Attachment WIEC 22.33.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.34
WIEC Data Request 22.34
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at page 42.
(a)Was Table 3-SR based on a levelized or nominal analysis?
(b)If Table 3-SR was based on a levelized analysis,please provide a version of Table 1-
SR using a nominal analysis.
Response to WIEC Data Request 22.34
(a)This analysis was performed using the Company's System Modeling methodology
through 2036,with nominal application of production tax credits (PTC),as
applicable,and levelized application of revenue requirement from capital
investments,as applicable.
(b)Please refer to Attachment WIEC 22.34.
Respondent:Rick Link
Witness:Rick Link