20180329PAC to Staff WY WIEC Set 22 (1-38) (3).pdf

ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
March 21,2018
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
22.22,22.23,22.35,and 22.37.The remaining responses will be provided separately.Provided
on the enclosed Confidential CD is Confidential Attachment WIEC 22.22.Confidential
information is 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,
S c
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/[e-mail] (C)(W)
Emanuel Cocian/WIEC [e-mail] (W)
Adele Lee/WIEC [e-mail] (W)
Nik Stoffel/WIEC [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 [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/Southland [e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
March 21,2018
WIEC Data Request 22.22
WIEC Data Request 22.22
Provide the source of and all supporting work papers used to derive the capacity credit
forecast for solar discussed by Mr.Link in his March 14,2018 supplemental rebuttal
testimony.
Response to WIEC Data Request 22.22
Please refer to Confidential Attachment WIEC 22.22,which provides the 2017 Integrated
Resource Plan (IRP)peak capacity contribution for wind and solar.The capacity
contribution sensitivityreferenced in the supplemental rebuttal testimony of Company
witness,Rick T.Link,was derived by applying a 50 percent reduction to the capacity
contribution value developedfor the 2017 IRP.
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 21,2018
WIEC Data Request 22.23
WIEC Data Request 22.23
Referring to the Figure SR-3 in Mr.Link's March 14,2018 supplemental rebuttal
testimony,please provide the current PV PenetrationPercent of Annual Energy and the
timeline each of the reported report case plotted on the figure expects the PV Penetration
to reach the various levels indicated on the X-Axis.
Response to WIEC Data Request 22.23
Please refer to Attachment WIEC 22.23.This attachment calculates solar energy as a
percentage of load both with and without the 1,320 megawatts (MW)of solar power-
purchase agreement (PPA)bids included in the 2017 Solar Request for Proposals (2017S
RFP)bid portfolio as summarized in the supplemental rebuttal testimony of Company
witness,Rick T.Link.
In the case with the Combined Projects but without solar PPA bids from the 2017S RFP,
total solar energy includes solar energy from committed resources (i.e.,where there is an
executed PPA),from committed resources where a PPA was executed after existing
resource assumptions were locked down for the 2017 Integrated Resource Plan (IRP),
and from solar resources included in the resource portfolio over time.The same type of
data is included in the calculation for the case without the Combined Projects but with
1,320 MW of solar PPA bids.In this instance,the energy from the solar PPA bids is also
included.Because the two resource portfolios (one with the Combined Projects without
solar PPA bids and one without the Combined Projects but with the solar PPA bids)
differ,the amount of solar energy varies over time.
Because incremental energy efficiencyresources are not included in forecasted loads and
are unique to any given resource portfolio,the load forecast net of incremental energy
efficiencyalso varies between the two cases (one with the Combined Projects without
solar PPA bids and one without the Combined Projects but with the solar PPA bids).
Respondent:Rick Link
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 21,2018
WIEC Data Request 22.35
WIEC Data Request 22.35
Referring to Rick Link's March 14,2018 supplemental rebuttal testimony at page 43.
(a)Was Table 4-SR based on a levelized or nominal analysis?
(b)If Table 4-SR was based on a levelized analysis,please provide a version of Table 1-
SR using a nominal analysis.
Response to WIEC Data Request 22.35
(a)Table 4-SR is based on levelized analysis with nominal treatment of production tax
credits (PTC)applicable to wind projects.
(b)Please refer to Attachment WIEC 22.35.
Respondent:Randy Baker
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
March 21,2018
WIEC Data Request 22.37
WIEC Data Request 22.37
Referring to Joelle Steward's March 14,2018 supplemental rebuttal testimony at page 1,
lines 21-22.
(a)Please identify the Wyoming Public Service Commission precedent supporting the
use of the RTM to match the costs and benefits on a more timely basis than a general
rate case.
(b)Please identify the Wyoming Public Service Commission precedent supporting the
Company's alternative proposal (if the RTM is denied)to deny its customers the
benefit of new generation before that generationis added to rate base.
Response to WIEC Data Request 22.37
(a)The RTM is not being proposed because it has been used before,but because it is a
reasonable approach to give the Company an opportunityto recover its prudently
incurred costs.
(b)The Company's proposal is meant to match the benefits and costs of the new projects.
Adjustments to net power costs are not unprecedented and are contained or proposed
in every Energy Cost Adjustment Mechanism filing.Please see,for example,the
reference in Ms.Steward's supplemental rebuttal testimony at page 3,starting at line
18.If the RTM is not approved,the Company is proposing an adjustment to net
power costs to fairly match the costs paid by customers and the benefits they receive.
Respondent:Steven McDougal
Witness:Joelle Steward