20180329PAC to Staff WY WIEC Set 22 (1-38) (2).pdf

ROCKY MOUNTAIN
POWER
A DIVlSION 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
GreenwoodVillage,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 22.6-
22.12,22.14,22.17-22.21,22.24-22.30,22.36,and 22.38.The remaining responses will be
provided separately.
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 [e-mail] (W)
Patti Penn/WIEC [e-mail](W)
Thor Nelson/WIEC tnels_o_n@h_olllandhart.com (C)(W)
Emanuel Cocian/WIEC [e-mail](W)
Adele Lee/WIEC Re_e@holllan_dharLeom (W)
Nik Stoffel/WIEC [e-mail] (C)(W)
Christopher Leger/OCA [e-mail] (C)
Crystal J.McDonough/NLRA (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 [e-mail] (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/[e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.6
WIEC Data Request 22.6
Please provide a full executable copy of all work papers relied upon by Mr.Link to
perform his new solar analysis presented in his Supplemental Rebuttal Testimony with all
formulae and links intact includinga no solar,no wind case.
Response to WIEC Data Request 22.6
Please refer to the confidential and non-confidential work papers supporting the
supplemental rebuttal testimony of Company witness,Rick T.Link,which were provided
with the Company's filing on March 14,2018.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.7
WIEC Data Request 22.7
Admit that the results of the nominal revenue requirements analysis performed in
conjunctionwith Mr.Link's second supplemental direct testimony demonstrate that the
Solar PPA option without the Combined Projects provides greater ratepayerbenefits
through 2036 in the medium gas,medium CO2 scenario compared to The Combined
Projects only,or the combination of the Combined Projects with the Solar PPA.If the
response to this request is anything other than a simple,unqualifiedadmission please
explain your response in detail and include the PVRR(d)resulting from the nominal
revenue for each of the three alternativesunder the medium gas,medium CO2 case
through 2036.
Response to WIEC Data Request 22.7
The Company denies that the nominal revenue requirement analysis demonstrates that the
solar power purchase agreements (PPA)associated with bids submitted into the 2017
Solar Request for Proposals (2017S RFP)provide greater customer benefits through 2036
when compared to the Combined Projects through 2036.
The comparative results of these sensitivitystudies vary by year.For instance,the
Combined Projects produce a change in annual revenue requirement that is more
favorable relative to the solar PPA bids in some years,and in other years,this trend is
reversed.Further,any present value of revenue requirements differential (PVRR(d))
calculated off of the nominal revenue requirement results through 2036 is not appropriate
because it does not capture any potential benefits from capital investments beyond 2036.
Finally,the solar sensitivitystudies summarized in the second supplemental direct
testimony of Company witness,Rick T.Link,were performed before the bid-evaluation
and selection process for the 2017S RFP was completed.
As summarized in Mr.Link's supplemental rebuttal testimony,this bid-evaluation and
selection process has now been completed.Based on valuation risks unique to solar
resources that are not factored into the solar sensitivities summarized in Mr.Link's
second supplemental direct testimony,continued availability of investment tax credits
(ITC)for solar resources,and anticipated price reductions for solar projects,the
Company has not selected any of the solar PPA bids that were offered into the 2017S
RFP to the final shortlist.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.8
WIEC Data Request 22.8
Admit that the results of the nominal revenue requirements analysis performed in
conjunctionwith Mr.Link's second supplemental direct testimony demonstrate that the
Solar PPA option without the Combined Projects provides greater ratepayerbenefits
through 2036 in the low gas,zero CO2 scenario compared to the Combined Projects only,
or the combination of the Combined Projects with the Solar PPA.If the response to this
request is anything other than a simple,unqualifiedadmission please explain your
response in detail and include the PVRR(d)resulting from the nominal revenue for each
of the three alternativesunder the low gas,zero CO2 case through 2036.
Response to WIEC Data Request 22.8
Please refer to the Company's response to WIEC Data Request 22.7.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.9
WIEC Data Request 22.9
Admit that the results of the nominal revenue requirements analysis performed in
conjunctionwith Mr.Link's second supplemental direct testimony demonstrate that the
Solar PPA option without the Combined Projects provides greater ratepayerbenefits
through 2050 in the medium gas,medium CO2 scenario compared to The Combined
Projects only.If the response to this request is anything other than a simple,unqualified
admission please explain your response in detail and include the PVRR(d)resulting from
the nominal revenue for both alternativesunder the medium gas,medium CO2 case
through 2050.
Response to WIEC Data Request 22.9
The Company denies that the nominal revenue requirement analysis demonstrates that the
solar power purchase agreements (PPA)associated with bids submitted into the 2017
Solar Request for Proposals (2017S RFP)provide greater customer benefits through 2050
when compared to the Combined Projects through 2050.
The comparative results of these sensitivitystudies vary by year.For instance,the
Combined Projects produce a change in annual revenue requirement that is more
favorable relative to the solar PPA bids in some years,and in other years,this trend is
reversed.The present value of revenue requirements differential (PVRR(d))calculated
off of the nominal revenue requirement results through 2050 for the Combined Projects is
$167 million.The PVRR(d)for the solar PPA bids calculated off of the nominal revenue
requirement results through 2050 is $424 million.When analyzed together,the PVRR(d)
calculated off of the nominal revenue requirement results through 2050 is $435 million.
The solar sensitivitystudies summarized in the second supplemental direct testimony of
Company witness,Rick T.Link,were performed before the bid-evaluation and selection
process for the 2017S RFP was completed.
As summarized in Mr.Link's supplemental rebuttal testimony,this bid-evaluation and
selection process has now been completed.Based on valuation risks that are unique to
solar resources that are not factored into the solar sensitivities summarized in Mr.Link's
second supplemental direct testimony,continued availability of investment tax credits
(ITC)for solar resources,and anticipated price reductions for solar projects,the
Company has not selected any of the solar PPA bids that were offered into the 2017S
RFP to the final shortlist.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.10
WIEC Data Request 22.10
Admit that the results of the nominal revenue requirements analysis performed in
conjunctionwith Mr.Link's second supplemental direct testimony demonstrate that the
Solar PPA option without the Combined Projects provides greater ratepayerbenefits
through 2050 in the low gas,zero CO2 scenario compared to the Combined Projects only,
or the combination of the Combined Projects with the Solar PPA.If the response to this
request is anything other than a simple,unqualifiedadmission please explain your
response in detail and include the PVRR(d)resulting from the nominal revenue for each
of the three alternativesunder the low gas,zeroCO2 case through 2050.
Response to WIEC Data Request 22.10
Please refer to the Company's response to WIEC Data Request 22.9.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.11
WIEC Data Request 22.11
Admit that the results of the nominal revenue requirements analysis performed in
conjunctionwith Mr.Link's March 14,2018 supplementalrebuttal testimony
demonstrate that the Solar PPA option without the Combined Projects provides greater
ratepayer benefits through 2036 in the medium gas,medium CO2 scenario compared to
the Combined Projects only.If the response to this request is anything other than a
simple,unqualified admission please explain your response in detail and include the
PVRR(d)resulting from the nominal revenue for both alternatives under the medium gas,
medium CO2 case through 2036.
Response to WIEC Data Request 22.11
The Company denies that the nominal revenue requirement analysis demonstrates that the
solar power purchase agreements (PPA)associated with bids submitted into the 2017
Solar Request for Proposals (2017S RFP)provide greater customer benefits through 2036
when compared to the Combined Projects through 2036.
The comparative results of these sensitivitystudies vary by year.For instance,the
Combined Projects produce a change in annual revenue requirement that is more
favorable relative to the solar PPA bids in some years,and in other years,this trend is
reversed.Further,any present value of revenue requirements differential (PVRR(d))
calculated off of the nominal revenue requirement results through 2036 is not appropriate
because it does not capture any potential benefits from capital investments beyond 2036.
Finally,the solar sensitivitystudies summarized in the second supplemental direct
testimony of Company witness,Rick T.Link,were performed before the bid-evaluation
and selection process for the 2017S RFP was completed.
As summarized in Mr.Link's supplemental rebuttal testimony,this bid-evaluation and
selection process has now been completed.Based on valuation risks that are unique to
solar resources that are not fully factored into the solar sensitivities summarized in Mr.
Link's supplemental rebuttal testimony,continued availabilityof investment tax credits
(ITC)for solar resources,and anticipated price reductions for solar projects,the
Company has not selected any of the solar PPA bids that were offered into the 2017S
RFP to the final shortlist.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.12
WIEC Data Request 22.12
Admit that the results of the nominal revenue requirements analysis performed in
conjunctionwith Mr.Link's March 14,2018 supplementalrebuttal testimony
demonstrate that the Solar PPA option without the Combined Projects provides greater
ratepayer benefits through 2050 in the medium gas,medium CO2 scenario compared to
the Combined Projects only.If the response to this request is anything other than a
simple,unqualified admission please explain your response in detail and include the
PVRR(d)resulting from the nominal revenue for both alternatives under the medium gas,
medium CO2 case through 2050.
Response to WIEC Data Request 22.12
The Company denies that the nominal revenue requirement analysis demonstrates that the
solar power purchase agreements (PPA)associated with bids submitted into the 2017
Solar Request for Proposals (2017S RFP)provide greater customer benefits through 2050
when compared to the Combined Projects through 2050.
The comparative results of these sensitivitystudies vary by year.For instance,the
Combined Projects produce a change in annual revenue requirement that is more
favorable relative to the solar PPA bids in some years,and in other years,this trend is
reversed.The present value of revenue requirements differential (PVRR(d))calculated
off of the nominal revenue requirement results through 2050 for the Combined Projects,
when calculated using nominal carbon dioxide (CO2)price assumptions and when
accounting for potential price-profile risks is $127 million.The PVRR(d)for the solar
PPA bids,when calculated using nominal CO2 priCC RSsumptions and when accounting
for price-profile and capacity-contribution risks calculated off of the nominal revenue
requirement results through 2050 is $149 million.
Based on valuation risks that are unique to solar resources that are not factored into the
solar sensitivities summarized in Mr.Link's second supplemental direct testimony,
continued availability of investment tax credits (ITC)for solar resources,and anticipated
price reductions for solar projects,the Company has not selected any of the solar PPA
bids that were offered into the 2017S RFP to the final shortlist.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.14
WIEC Data Request 22.14
Please provide the PVRR(d)for all nine price policy scenarios resulting from the nominal
revenue requirements analysis though 2036 for the Combined Projects.
Response to WIEC Data Request 22.14
The WyomingIndustrial Energy Consumers (WIEC)is in possession of the information
required 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 FSLW Studies"includes the annual change in
nominal revenue requirement associated with the Combined Projects for all nine price-
policy scenarios over the 2017 through 2050 timeframe (rows 121,242,362,etc.).
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.17
WIEC Data Request 22.17
At Page 2 of Mr.Link's March 14,2018 supplementalrebuttal testimony,Mr.Link states
that "During the evaluation of bids in the 2017S RFP,PacifiCorp analyzed valuation risks
that are unique to the procurement of solar resources and determined that solar resource
costs are likely to continue to fall.Given these solar resource-valuation risks,expected
cost declines,and availability of the 30-percent investment tax credit (ITC)for solar
projects coming online as late as 2021,PacifiCorp does not need to act now and has
decided not to select any of the solar power-purchase agreement (PPA)bids to the 2017S
RFP final shortlist."
Please provide the company's expectation of future solar prices for each year through
2021.
Response to WIEC Data Request 22.17
The Company has not established a definitive projection of solar prices at this time.The
referenced statement in the supplemental rebuttal testimony of Company witness,Rick T.
Link,is based on trends in solar pricing and a recent market environment characterized
b uncertainties in tariff and tax-reform risks (see Confidential Exhibit RMP (RTL-
2SR,page 25).
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.18
WIEC Data Request 22.18
Has the Company explored the economics of pursuing a solar PPA option (without the
combined projects)based on its expected lower future solar pricing?If yes,please
provide a full and detailed discussion of the analysis and all results and supporting work
papers.If not,please explain in detail why not.
Response to WIEC Data Request 22.18
No.The Company has chosen not to pursue solar power purchase agreement (PPA)bids
at this time for a number of reasons,as stated in the second supplemental rebuttal
testimony of Company witness,Rick.T.Link (Link Sup.Rebuttal,page 2 lines 17-page
3,line 1,page 30-page 31,line 19,and Confidential Exhibit RMP_(RTL-2SR),page
26).PacifiCorp has not analyzed sensitivities specific to future solar pricing because
there are other valuation risks that can be considered in the 2019 Integrated Resource
Plan (IRP)with full stakeholderengagement.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.19
WIEC Data Request 22.19
Admit that the Company is still a summer peaking utility and that Solar provides greater
accredited capacity toward meeting PacifiCorp's summer peak than does wind.If the
response to this request is anything other than a simple,unqualifiedadmission please
explain your response in detail
Response to WIEC Data Request 22.19
For planning purposes,PacifiCorp's coincident peak (CP)is expected to occur in the
summer.Based on assumed capacity contribution values developed for the 2017
Integrated Resource Plan (IRP),it is assumed that solar resources have a greater capacity
contribution value than wind resources.However,the capacity contribution value is not
entirelydriven by peak load.Rather,capacity contribution reflects the availability of
resources at times when the loss of load probability (LOLP)is highest.
As noted in the supplemental rebuttal testimony of Company witness,Rick T.Link,as
highly correlated solar resources are added to the system,the energy output from solar
resources is more likelyto shift the timing of loss of load events,which would reduce the
capacity contribution value of solar resources (Link Sup.Rebuttal,page 36,lines 6-page
38,line 5).This same effect is not expected for wind resources (Link Sup.Rebuttal,page
41,line l l-page 42,line 2).
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.20
WIEC Data Request 22.20
Admit that Table 1.2 &1.3 of the Company's 2017 IRP shows that the Company will
remain significantlyabove its planning reserve margin through 2026 for both its summer
and winter peak and that these calculations include load growth,and coal retirement but
exclude any new incremental generation resources.If the response to this request is
anything other than a simple,unqualified admission please explain your response in
detail
Response to WIEC Data Request 22.20
PacifiCorp denies that the referenced tables in the 2017 Integrated Resource Plan (IRP)
show the Company will remain significantlyabove its planning reserve margin (PRM)
through 2026.As labeled in the referenced tables,the capacity position shown includes
available front office transactions (FOT).These capacity and energy resources are
uncommitted and can be displaced by other lower-cost resource alternatives.This was
ultimatelythe case in the 2017 IRP preferred portfolio,which included 1,100 megawatts
(MW)of Wyomingwind at the end of 2020 and significantlyfewer FOTs than the
amount of available FOTs shown in the referenced tables.Eliminatingthe uncommitted
available FOTs from these tables shows that the capacity contribution from existing
resources (i.e.,10,493 MW for 2017 in Table 1.2)is less than what is required (i.e.,
11,020 MW of Obligation +13 percent Planning Reserves for 2017)throughoutthe first
10 years of the planning horizon.Consequently,PacifiCorp has an immediate need to
procure capacity and energy resources as demonstrated in the 2017 IRP.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.21
WIEC Data Request 22.21
Admit,that from a capacity need basis,the Company does not need to pursue the
Combined Projects immediately to meet a capacity need but rather the timing of the
project is driven by the availabilityof PTCs.If the response to this request is anything
other than a simple,unqualifiedadmission please explain your response in detail.
Response to WIEC Data Request 22.21
The Company denies that it does not need to pursue the Combined Projects immediately.
As identified in the 2017 Integrated Resource Plan (IRP)and confirmed by on-going
analysis throughout this proceeding,without the Combined Projects,the Company would
need to procure other resource alternatives to meet its load and reserve obligations and
that these other alternatives are higher cost and higher risk than the Combined Projects.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.24
WIEC Data Request 22.24
Admit that Table 5.13 in the Company's 2017 IRP shows that the Company uses a 59.7%
capacity contribution for single axis tracking solar pv.If the response to this request is
anything other than a simple,unqualified admission please explain your response in
detail.
Response to WIEC Data Request 22.24
Yes.Please refer to the supplemental rebuttal testimony of Company witness,Rick T.
Link (Link,Sup.Rebuttal,page 36,line 12-16).
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.25
WIEC Data Request 22.25
Admit that the Company updated its Capacity Contribution for Solar in its 2017 IRP
based on hours having the highest loss of load probability study.If the response to this
request is anything other than a simple,unqualifiedadmission please explain your
response in detail.
Response to WIEC Data Request 22.25
The Company developed its capacity contribution value for solar resources in the 2017
Integrated Resource Plan (IRP)using the capacity factor approximation method,which
relies on hourly loss of load probability(LOLP)calculated from stochastic Planning and
Risk (PaR)model simulations.The analysis developed for the 2017 IRP is summarized in
Appendix N,Volume II,of the 2017 IRP,which is publicly available and can be accessed
by utilizingthe followingwebsite link:
http://www.pacificorp.com/es/irp.html
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.26
WIEC Data Request 22.26
Admit that the Company used the Solar Capacity Contribution listed in Table 5.13 in its
2017 IRP for each of the years included in its IRP analysis.If the response to this request
is anything other than a simple,unqualified admission please explain your response in
detail.
Response to WIEC Data Request 22.26
This is correct.The same capacity contribution value was applied to all years in the 20-
year planning period.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.27
WIEC Data Request 22.27
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at page 9,lines
10-14.Was the Oregon IE referring to a levelized analysis or nominal analysis of the
costs and benefits of a PPA portfolio as compared to the Combined Projects?
Response to WIEC Data Request 22.27
Given the Oregon independentevaluator's (IE)reference to analysis through 2050,and
the fact that the Company did not perform levelized analysis over this time frame,it is the
Company's position that the quoted statement refers to nominal analysis of a 2017
Renewable Request for Proposals (2017R RFP)bid portfolio containing power purchase
agreement (PPA)bids with a 2017R RFP bid portfolio that contained the original final
shortlist of 2017R RFP bids identified in the Company's second supplemental direct
testimony in this docket.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.28
WIEC Data Request 22.28
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at page 10,
lines 6-10.Was the Utah IE referring to a levelized analysis or nominal analysis of the
costs and benefits of a PPA portfolio as compared to the Combined Projects?
Response to WIEC Data Request 22.28
Given the Utah independentevaluator's (IE)reference to a 30-year analysis,and the fact
that the Company did not perform levelized analysis over this time frame,it is the
Company's position that the quoted statement refers to nominal analysis of a 2017
Renewable Request for Proposals (2017R RFP)bid portfolio containing power purchase
agreement (PPA)bids with a 2017R RFP bid portfolio that contained the original final
shortlist of 2017R RFP bids identified in the Company's second supplemental direct
testimony in this docket.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.29
WIEC Data Request 22.29
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at page 11,line
24 through page 12,line 3.Please explain in detail how an inflation-adjusted real-
levelized analysis of capital costs is consistent with how the capital costs are treated in
ratemaking.
Response to WIEC Data Request 22.29
The referenced testimony of Company witness,Rick T.Link,explains that net present
value (NPV)benefits of utility-ownedresources versus power purchase agreement (PPA)
alternatives corresponds to how productiontax credit benefits pass through to customers.
This statement stands on its own.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.30
WIEC Data Request 22.30
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at pages 22-24.
Please explain how the terminal value benefit associated with the Combined Projects will
be allocated to Wyoming in 2050.
Response to WIEC Data Request 22.30
Terminal value benefits represent the potential avoided cost for not having to procure
certain elements of a wind project that have longer useful lives (i.e.,transmission
facilities and developmentrights).These benefits would flow through to Wyomingby not
having to incur incremental costs for these elements of a wind facility that are not
retained via a traditional power purchase agreement (PPA)structure.
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.36
WIEC Data Request 22.36
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at page 51,
lines 17-21.
(a)What is the "higher-cost"resource that the Combined Projects are deferring in the
2028 timeframe?
(b)Please identify all of the generation resources will be allocatedto Wyoming
ratepayers in 2028.
(c)Based on the generationresources that will be allocated to Wyomingin 2028,please
identify whether Wyomingwill have a resource need in 2028.
Response to WIEC Data Request 22.36
(a)Displacement of higher cost resources varies among price-policy scenarios,and can
be determined by comparing differences in the resources in the portfolios with and
without the Combined Projects for any given price-policyscenario.Resources that are
in the resource portfolio without the Combined Projects and not included in the
resource portfolio with the Combined Projects,for any given year,are displaced or
deferred.
The WyomingIndustrial Energy Consumers (WIEC)is in possession of the
information required to assess changes in the resource portfolio due to the Combined
Projects.For instance,please refer to the confidential work papers provided with the
second supplemental testimony of Company witness,Rick T.Link,specifically the
files included in the folder "SO Summary Reports".The "Portfolio"worksheet in
each of these files summarizes the resource portfolio selected by the System
Optimizer model (SO model)for any given simulation.Those files with the term
"Base"in the file name contain the resource portfolios without the Combined
Projects.Those files with the term "FSLW"contains the resource portfolios with the
Combined Projects.
For each of these files,the two characters in the file name that followingthe term
"Base"or "FSLW"designate the natural gas price assumptions (L =low,M =
medium,and H =high)and the carbon dioxide (CO2)price assumptions (N =zero,M
=medium,and H =high).
Note:none of the new resources in the portfolios developed from the SO model are
committed.Consequently,the resources in each of these portfolios may or may not be
procured,and therefore may or may not be allocated to Wyomingcustomers in 2028.
Actual resource procurement for 2028 will be informed by future integrated resource
plans (IRP)and subsequent competitive bidding processes,as applicable.
(b)Please refer to the Company's response to subpart (a)above.
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.36
(c)Each resource portfolio developedusing the SO model meets projected load
obligations inclusive of a planning reserve margin (PRM).
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 20,2018
WIEC Data Request 22.38
WIEC Data Request 22.38
Referring to Joelle Steward's March 14,2018 supplemental rebuttal testimony at page 5,
lines 22-23.Please define "the nature of the resource decision at issue in this case."
Response to WIEC Data Request 22.38
The Company's 2017 Integrated Resource Plan (IRP)identified new wind and
transmission as an element of its least-cost,least-risk plan.The extensive economic
analysis produced by the Company in this proceeding affirms that these resources,now
known as the Combined Projects,are lower cost and lower risk than other resource
alternatives.Consequently,it is the Company's position that the WyomingPublic Service
Commission (WPSC)should approve prudentlyincurred costs to deliver this element of
PacifiCorp's least-cost,least-risk resource plan.
Respondent:Rick Link
Witness:Joelle Steward