20210920PAC to Bayer 111-130-Redacted.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 20, 2021
Randall C. Budge/Bayer [e-mail] (C) Thomas J. Budge/Bayer [e-mail] (W)(C) Brian C. Collins/Bayer [e-mail] (W)(C)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer [e-mail] (C) Lance Kaufman/Bayer [e-mail] (C) James R. Smith/Bayer [e-mail] (C)
Mike Veile/Bayer [e-mail] Courtney Higgins/Bayer [e-mail] Milli Picharo/Bayer [e-mail] Neal Townsend/Bayer [e-mail]
RE: ID PAC-E-21-07
Bayer Set 10th (111-130)
Please find enclosed Rocky Mountain Power’s Responses to Bayer 10th Set Data Requests 115, 119-121, and 122-123. Also provided are Attachments Bayer 117-1, 117-3, and 123. Alsoprovided via BOX are Confidential Attachments Bayer 115, 117-2, 118, 122-1, and 122-2 andConfidential Responses Bayer 117-118 and 123. Confidential information is provided subject toprotection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public UtilitiesCommission’s Rules of Procedure No. 67 – Information Exempt from Public Review, andfurther subject to the Non-Disclosure Agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
____/s/____ J.Ted WestonManager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)Ronald L. Williams/PIIC [e-mail] Bradley G. Mullins/PIIC [e-mail] Adam Gardner/PIIC [e-mail] (W) Kyle Williams/PIIC [e-mail] (W) Val Steiner/PIIC [e-mail] (W) Eric L. Olsen/IIPA [e-mail] (C)
RECEIVED
2021 SEP 20 PM 4:24
IDAHO PUBLIC
UTILITIES COMMISSION
Anthony Yankel/IIPA [e-mail] (C) Ben Otto/ICL [e-mail] (C) Ronald L. Williams/PIIC [e-mail] Bradley G. Mullins/PIIC [e-mail]
Adam Gardner/PIIC [e-mail] (W) Kyle Williams/PIIC [e-mail] (W) Val Steiner/PIIC [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA [e-mail] (C) Brad Purdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 115
Bayer Data Request 115 Coal Costs. Please provide the Bridger Coal Company coal prices assumed in the net power cost forecast. Please include all supporting documentation used to
calculate such prices, including depreciation expense. Please identify the portion
of depreciation expense associated with assets used in the underground mining operation.
Response to Bayer Data Request 115
Please refer to Confidential Attachment Bayer 115 which provides Bridger Coal Company (BCC) coal prices. Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Dan Moody Sponsor: To Be Determined

PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 117
Bayer Data Request 117 Pryor Mountain. Please refer to the Direct Testimony of Rick T. Link, Section V.

(a) Please identify all transmission used to move energy from Pryor Mountain to and through PacifiCorp’s system.
(b) Did the addition of Pryor Mountain increase transmission congestion on
PacifiCorp’s system in any of the years modeled? (c) How did PacifiCorp account for the cost of transmission or transmission constraints due to Pryor Mountain?
(d) Please provide all transmission studies performed by or on behalf of
PacifiCorp related to Pryor Mountain, including any studies performed prior to PacifiCorp’s acquisition of the project.
(e) Please provide the GRID model results for 2021 with and without Pryor
Mountain. Please include energy curtailments by transmission bubble and the value of curtailed energy. Please also include a graphic representation of the GRID transmission topology. If the company declines to provide such data, please provide access to the 2021 GRID model.
(f) Please provide a graphic representation of the transmission topology modeled
in PaR analysis of the referenced testimony. Please explain how the PaR analysis accounts for transmission constraints.
Confidential Response to Bayer Data Request 117
(a) Power from the Pryor Mountain wind facility can use any of PacifiCorp’s Wyoming, southeastern Idaho and northern Utah transmission facilities necessary to deliver the power to load. PacifiCorp’s transmission map is publicly available and located on PacifiCorp’s Open Access Same-Time
Information System (OASIS) website:
www.oasis.oati.com/woa/docs/PPW/PPWdocs/16089_PAC_TXM_System_Map_w_WECC_Path_Ratings_--_Roholt.pdf
(b) PacifiCorp merchant (energy supply management (ESM)) elected to use its Network Operating Agreement (NOA) Section 8.1 to designate the Pryor Mountain wind facility as a network resource (NR). As such, resources are dispatched to remain within existing transmission rights until future transmission improvements can be constructed and placed in service. While
utilization of the transmission system changes somewhat with power provided
PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 117
from the Pryor Mountain facility due to its location within the PacifiCorp system, congestion across constrained transmission is essentially unchanged due to the use of the NOA re-dispatch.
(c) The Company’s current transmission formula rate (included in PacifiCorp’s
Open Access Transmission Tariff (OATT)) was approved by the Federal Energy Regulatory Commission (FERC) in Docket ER11-3643. The Company’s transmission formula rate is updated annually with the annual
transmission revenue requirement (ATRR) that represents the annual total cost
of providing firm transmission service over the test year. The ATRR calculation incorporates all transmission system investments by the Company, a return on rate base, income taxes, expenses, and certain revenue credits, among other specific elements and adjustments. Transmission assets, including new transmission capital and transmission network upgrades, are
included in the ATRR, weighted by months in service. The ATRR is
converted into a rate by dividing the ATRR by firm transmission demand (this demand includes PacifiCorp ESM). All third party revenues for transmission service (along with third party revenues for ancillary services) are included as
revenue credits in the calculation of rates in each of the Company’s state retail
jurisdictions. (d) Please refer to Attachment Bayer 117-1, specifically:
• file “1_140819 Q0542 Bowler Flats LGI SIS Final to Cust” which provides a copy of the August 19, 2014 the interconnection system impact study (SIS) prepared for Q0542 (formerly Bowler Flats).
• file “2_140820 Q0542 -Transient Stability Study Report” which provides a copy of the August 20, 2014 transient stability study performed for Q0542.
• file “3_150406 Q0542 Bowler Flats LGI FS FINAL” which provides a
copy of the April 6, 2015 facility study performed for Q0542.
• file “4_190926 Q0542 SIS Report_Rev1” which provides a copy of the
revised September 26, 2019 interconnection SIS prepared for Q0542.

• file “5_TSRQ2687SIS” which provides a copy of the redacted transmission service request (TSR) SIS prepared for PacifiCorp ESM requesting that the Pryor Mountain wind facility to be designated as a NR.
(e) Please refer to the confidential work papers supporting the direct testimony of Company witness, Michael G. Wilding, specifically file “Exhibit No. 37 - GRID Model NPC Report CONF” which provides the Generation and Regulation Initiative Decision Tool (GRID) results for calendar year 2021 that
PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 117
includes the Pryor Mountain wind project. Please refer to Confidential Attachment Bayer 117-2 which provides the GRID results that exclude the Pryor Mountain wind project, specifically file “ID GRC21_NPC_CY2021_No Pryor Mtn CONF.xlsx”. The impact of removing the Pryor Mountain wind
project from the available GRID resources increases the net power costs
(NPC) forecast for calendar year 2021 by approximately , on a total company basis. GRID is not capable of curtailing wind, and utilizes the trapped energy
market for any excess energy. However, there was no change to trapped
energy costs between the original scenario including the Pryor Mountain wind project, and the scenario without the Pryor Mountain wind project, which indicates no energy curtailments were impacted by this resource. Please refer to the confidential work papers supporting Mr. Wilding’s direct testimony, specifically file “ID GRC21_Transmission Topology CONF.xlsx”, tab
“Bubble Map” tab which provides a copy of the GRID transmission topology.
If P4 Production, LLC / Bayer Corporation (Bayer) would like to be provided access to a GRID instance, uploaded with the GRID project associated with
the Company’s Idaho general rate case (GRC) proceeding, please contact Ted
Weston at [phone]. Access to GRID and the associated GRID project(s) require the individual user to have executed the relevant confidentiality agreement / non-disclosure agreement (NDA) applicable to this proceeding. In order to set up external access to GRID, the individual user will need access to a device capable of downloading “Apps”. The Company
will also need to be provided with the following details of the individual user:
(a) Name, (b) Mailing Address, (c) Email, and (d) Telephone Number. (f) Please refer to Attachment Bayer 117-2 which provides the Company’s
relevant Integrated Resource Plan (IRP) topology map from PacifiCorp’s
2019 IRP. The map display lines between topology bubbles representing available firm transmission. The Planning and Risk (PaR) model optimizes transfers between bubbles using these transmission paths up to the modeled transmission limit of each path. Transfers are made to optimally meet load requirements at each bubble and to move energy to markets for.

Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Randy Baker / Lori Oathes/ Lori Holland Sponsor: Rick T. Link
PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 118
Bayer Data Request 118 Pryor Mountain. Please refer to the Direct Testimony of Rick T. Link, Section V.

(a) Please provide the annual capital expenditure assumed by year in the analysis presented in the referenced testimony.
(b) Did PacifiCorp perform any sensitivity analysis evaluating economic
performance of Pryor Mountain under a shorter economic life, such as 20 or 25 years? If no why not? (c) Do the values in Table 3 and Figure 4 reflect the cost increases noted in the Direct Testimony of Robert Van Engelenhoven? If no, please provide these
tables updated to reflect actual costs or provide the data necessary to perform
such updates. (d) Does the PVRR analysis performed by Mr. Link reflect additional AFUDC
associated by the early procurement of turbines to qualify for production tax
credits? If no, why not? Confidential Response to Bayer Data Request 118 Referencing the direct testimony of Company witness, Rick T. Link, specifically
Section V (Pryor Mountain Wind Project), the Company responds as follows:
(a) Please refer to Confidential Attachment Bayer 118 which provides the annual capital expenditure assumed by year in the Pryor Mountain wind project
analysis.
(b) The economic analysis of Pryor Mountain is based on its expected life of 30 years. The Company did not prepare sensitives assuming a shorter life because 30-years is the standard asset life for wind facilities consistent with recent depreciation studies.

(c) The decision to proceed with the Pryor Mountain wind project was based on the September 2019 analysis which was based on an estimated project cost of . The values in Table 3 (Net Benefits from the Pryor Mountain Wind Project),
and Figure 4 ((Reduction)/Increase in Total-1 System Annual - Revenue Requirement from the Pryor Mountain Wind Project) are based on that analysis. The updated forecasted cost of
referenced in the Direct Testimony of Company
PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 118
witness, Robert Van Engelenhoven was the most recent forecast available when the testimony was prepared. Please refer to the Company’s response to Bayer Data Request 134, specifically Confidential Attachment Bayer 134. This file will allow P4 Production, LLC / Bayer Corporation (Bayer) to
perform its own sensitivities analyses.
(d) Two General Electric (GE) safe harbor wind turbine generators (WTG) originally purchased by the Company in 2016 were transferred to the Pryor
Mountain wind project. The cost of these WTGs, including accumulated
allowance for funds used during construction (AFUDC) since 2016, was transferred to the Pryor Mountain wind project and continued to accrue AFUDC until the turbines were placed in service. The Company acquired 78 Vestas safe harbor WTGs nacelles from Berkshire
Hathaway Energy Renewables (BHER) in July 2020. The purchase price
included: (1) the original cost, (2) sales tax, and (3) storage and maintenance, (4) delivery changes, and (5) insurance. AFUDC costs on this equipment began accruing when these turbines were transferred to the Company and
accrued until the turbines were placed in service.
Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Mark Paul
Sponsor: Rick T. Link
PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 119
Bayer Data Request 119 Pryor Mountain. Please refer to the Direct Testimony of Rick T. Link, Section V Figure 4.

(a) Please explain why the change in revenue requirement decreases substantially in 2028.
(b) Please explain why the change in revenue requirement increases substantially
in 2031. (c) Please explain why the change in revenue requirement decreases substantially in 2050.
(d) Do the values in Figure 4 reflect declining plant balances?
Response to Bayer Data Request 119
(a) The revenue requirement decreases substantially in 2028 as the system value
of the Pryor Mountain generation increases from $28.44 per megawatt-hour ($/MWh) in 2027 to $49.98/MWh in 2028. Please refer to the confidential work papers supporting the direct testimony of Company witness, Rick T. Link, specifically folder “FC1 and PM”, file “Table 4, Figure 3-4, FB_PryorMtn_Analysis_2019-12-06 v3.xlsx” tab “System Value”, and row
23 “Net (Benefit)/Cost (2034-2050) w/ '34-'38 Extrap”. The retirement of the
Dave Johnston coal plant at the end of 2027 reduces resource supply in eastern Wyoming, resulting in fewer instances of congestion and higher marginal benefits from Pryor Mountain, relative to prior years.

(b) The revenue requirement increases substantially in 2031 due to the expiration of the production tax credits (PTC). Please refer to file “Table 4, Figure 3-4, FB_PryorMtn_Analysis_2019-12-06 v3.xlsx”, tab “Pryor Mountain Economics”, row 17 “PTCs”.
(c) The revenue requirement decreases substantially in 2050 due to the assumed
terminal value of the land, development rights and remaining value of the transmission assets interconnecting the project to the transmission provider’s system. (d) Yes, the values in Figure 4 reflect declining plant balances. Recordholder: Mark Paul / Dan MacNeil
Sponsor: Rick T. Link
PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 122
Bayer Data Request 122 Generation. Please provide PacifiCorp’s hourly generation, including PPAs and QFs, from January 1, 2019 to present, separately for dispatchable and non-
dispatchable resources.
Response to Bayer Data Request 122
The Company interprets “dispatchable” resources and “non-dispatchable”
resources to mean generating resources (owned or contracted), excluding non-generating resources, such as demand-side management (DSM) programs. Based on the foregoing interpretation, the Company responds as follows: Please refer to Confidential Attachment Bayer 122-1 which provides actual hourly
owned generation data for PacifiCorp’s owned resources for calendar years 2019
and 2020. Please also refer to Confidential Attachment Bayer 122-1 which provides actual hourly data for qualifying facility (QF) power purchase agreements (PPA) and non-QF PPAs for calendar years 2019 and 2020. The
Company will supplement the response to this data request shortly with available
calendar year 2021 data. Please refer to Confidential Attachment Bayer 122-2 which provides a list of generating resources (as defined above) and included in the data provided in Confidential Attachment Bayer 122-1, with an indication of whether the
generating resource is “dispatchable”, has “limited dispatch capability”, or is
“non-dispatchable”. Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement (NDA) executed in this proceeding. Recordholder: Ray Zacharia / Mary Kelly / Cato Wagner, III / Tom Burns

Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 123
Bayer Data Request 123 Wind Generation. Please refer to https://www.justice.gov/opa/pr/utility-company-sentenced-wyoming-killing-protected-birds-wind-projects-0

(a) Please provide copies of the court orders and rulings for the cases referenced. Please also provide copies of any written briefs, expert reports, and expert testimony that were submitted in the case record.

(b) Does PacifiCorp agree with the referenced article’s assertion that compliance costs were estimated at $600,000? If no, why not? (c) Please provide the 2020 compliance costs associated with this plea agreement by FERC account.

(d) Does the amounts in subpart (c) reflect wind curtailment to avoid avian deaths? If no, please provide the change in 2021 Net Power Costs if avian related curtailments are eliminated from the wind generation profile for
Dunlap.
Revised subpart (d) received from P4 Production, LLC / Bayer Corporation (Bayer) on September 8, 2021 – subpart (d) is replaced, in its entirety and now reads:
Does the amounts in subpart (c) reflect wind curtailment to avoid avian
deaths? If no, please provide the change in 2021 Net Power Costs if avian related curtailments are eliminated from the wind generation for effected facilities.
Confidential Response to Bayer Data Request 123 (a) Please refer to Attachment Bayer 123. (b) Yes.

(c) The 2020 compliance costs were , and were charged to FERC Account 5530000. (d) No, the 2020 compliance costs provided in subpart (c) do not include lost
generation associated with avian curtailments. The 2020 compliance costs provided in subpart (c) are not included in the modeling of net power costs (NPC). Note: there are no avian wind curtailments included in the Company’s wind generation used to calculate
forecast NPC in this proceeding.
PAC-E-21-07 / Rocky Mountain Power September 20, 2021 Bayer Data Request 123
Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to the Non-Disclosure Agreement (NDA) executed in this
proceeding.
Recordholder: Travis Brown / Gary Tawwater / Lori Oathes

Sponsor: Tim Hemstreet