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HomeMy WebLinkAbout20180410PAC to Staff UT OCS Set 16 (1-11).pdf1407 W.NorthTemple ROCKY MOUNTAIN Salt Lake City,UT 84116 POWER A DIVISION OF PAC1FICORP March 28,2018 Béla Vastag Office of Consumer Services 160 East 300 South Salt Lake City,Utah 84111 bvastag@utaakgov (C) RE:UT Docket No.17-035-40 OCS 16*Set Data Request (1-11) Please find enclosed Rocky MountainPower's Response to OCS 16th Set Data Request 16.10. If you have any questions,please call me at (801)220-2823. Sincerely, Jana Saba Manager,Regulation Enclosures C.c.Erika Tedder/DPU dpudatarequest utah.gov etedder@utah.gov(C) Dan Kohler/DPU dkoehler@daymarkea.com(C) Dan Peaco/DPU dpeaco@davmarkea.com (C)(W) Aliea Afnan/DPU aafnan@daymarkea.com (W) ibower@daymarkea.com (W) Philip Hayet/OCS phayet@jkenn.com (C) Gary A.Dodge/UAE adodge@hidlaw.com (C) Phillip Russell/UAE prussell@hidlaw.com (C) Kevin Higgins/UAE khiggins@eneravstrat.com (C) Neal Townsend/UAE ntownsend@energystrat.com(C)(W) Kate Bowman/UCE kate@utahcleanenergy.org(C) Emma Rieves/UCE emma@utahcleanenergy.ora(C)(W) Lisa Tormoen Hickey/Interwestlisahickey@newlawaroup.com (C) Mitch Longson/Interwest mloneson mc2b.com (C) Nancy Kelly/WRAnkellv@westernresources.org(C) Jennifer Gardner/WRA jennifer.gardner@westernresources.org(C) Penny Anderson/WRA penny.anderson@westernresources.org (W) Peter J.Mattheis/Nucor pjm@smxblaw.com (C) Eric J.Lacey/Nucor ejl@smxblaw.com (C)(W) William J.Evans/UIEC bevans@parsonsbehle.com Vicki M.Baldwin/UIEC vbaldwin@parsonsbehle.com(W) Chad C.Baker/UIEC ebaker@parsonsbehle.com (W) 17-035-40 /Rocky Mountain Power March 28,2018 OCS Data Request 16.10 OCS Data Request 16.10 Refer to the Company's response to DPU 14.10. (a)Is it accurate to state that the 4 reasons provided in this response are reasons PacifiCorp believes it is obligated to complete the D2 segment by 2024?If this characterization is not completely accurate,please clarify. (b)PacifiCorp states that it has to ensure its OATT network transmission customers can deliver their designated resources to their designated network loads on a firm basis. Why does the Company believe that it is required to meet this obligation by 2024? Why not earlier/later? (c)Isn't it true that right now there are times when designated network resources are unable to deliver to network loads due to transmission limits?Can't the Company continue to rely on RAS schemes even after 2024 without having to construct the D2 segment?Please explain,and if this is not a proper characterization of PacifiCorp's position,please clarify. (d)Is there anything specific that will occur by 2024 such as expected load growth or anything else that has led PacifiCorp to assume it is required to complete the D2 upgrades by 2024?Why not earlier/later?Please discuss. (e)Please explain in detail PacifiCorp's obligation through its OATT requirements that leads to PacifiCorp's retail customers having to pay nearly $700 million to ensure that PacifiCorp can accommodate generator requests to interconnect under PacifiCorp's OATT.Essentially,this is what the Company is expecting by stating that it would have to construct the D2 segment by 2024. (f)Please explain why reasons 2,3,and 4 would obligate retail customers to pay for the construction of the line Response to OCS Data Request 16.10 (a)The characterization is not accurate.As discussed in more detail in the Company's response to DPU Data Request 14.10,PacifiCorp's long-term transmission plan calls for the construction of multiplesegments of Energy Gateway,includingthe Aeolus- to-Bridger/AnticlineLine,by an estimated outer-range date of 2024. (b)As discussed in more detail in the Company's response to DPU Data Request 14.10, firm deliveryof designated network resources to designated network loads is one of several factors that contribute to the estimated 2024 date in PacifiCorp's long-term transmission plan. 17-035-40 /Rocky Mountain Power March 28,2018 OCS Data Request 16.10 (c)A generationtripping remedial action scheme (RAS)does not create new transmission capacity,but rather is a tool employed for system reliability under outage scenarios,which can minimize the need to construct even more new transmission.PacifiCorp will rely on the new Aeolus RAS beyond 2024 in order to minimize even greater new transmission needs.The Company has also previously taken steps to increase transmission capacity by upgrading the existing transmission system or implementing alternative transmission technologies.Since 2013,the Company has completed several important projects to enhance the transmission system in southeast Wyoming,includingthe dynamic line rating of the Miners (Standpipe)-Platte 230 kilovolts (kV)(2013);Southern Wyoming Voltage Control Scheme,which coordinated wind generationreactive output to stabilize local area voltages (2015);and construction of the Standpipe substation and (60 megavolt ampere reactive (MVAr))synchronous condenser for voltage control (2016).These projects allowed the Company to delay the Transmission Projects,but are not a long- term substitute for the Transmission Projects. (d)Please refer to the Company's response to subpart (a)above,as well as the Company's response to DPU Data Request 14.10. (e)Please refer to the Company's response to subpart (a)above,as well the Company's response to DPU Data Request 14.10. (f)While the reasons identified are all valid,at this point the principal need is driven by deliverabilityof designated network resources.To the extent that other transmission rights can be sold,it serves as an offset to retail customers.Also,please refer to the Company's response to OCS Data Request 16.11.