20170705Teply Direct - Redacted.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NO.PAC-E-17-07OFROCKYMOUNTAINPOWERFORA)CERTIFICATE OF PUBLIC )DIRECT TESTIMONY OFCONVENIENCEANDNECESSITYAND)CHAD A.TEPLYBINDINGRATEMAKINGTREATMENT)REDACTEDFORNEWWINDANDTRANSMISSION)FACILITIES )
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ROCKY MOUNTAIN POWER
CASE NO.PAC-E-17-07
June 2017
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l Q.Please state your name,business address,and present position.
2 A.My name is Chad A.Teply.My business address is 1407 West North Temple,Suite 310,
3 Salt Lake City,Utah 84116.My position is Vice President of Strategy and Development
4 for Rocky Mountain Power ("Company"),a division of PacifiCorp.
5 QUALIFICATIONS
6 Q.Briefly describe your education and business experience.
7 A.I have a Bachelor of Science Degree in Mechanical Engineering from South Dakota
8 State University.I joined MidAmerican Energy Company (a Berkshire Hathaway
9 Energy afYiliate company)in November 1999,and held positions of increasing
10 responsibility within the generation organization,including serving as project manager
11 for a new 780 megawatt ("MW")supercritical coal-fueled generation resource placed
12 in service in 2007.In April 2008,I moved to Northern Natural Gas Company (aO13BerkshireHathawayEnergyaffiliatecompany)as Senior Director of Engineering.
14 I joined PacifiCorp in February 2009.In my current role as Vice President of Strategy
15 and Development,my responsibilities encompass strategic planning,regulatory
16 support,stakeholder engagement,development and execution of major generation
17 resource additions,major environmentalcompliance projects,and major transmission
18 projects.
19 PURPOSE AND SUMMARY OF TESTIMONY
20 Q.What is the purpose of your testimony?
21 A.I am testifying in support of the Company's Application for Certificates of Public
22 Convenience and Necessity and Binding Ratemaking Treatment for Wind and
23 Transmission Facilities ("Application").The Company's 2017 Integrated Resource
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l Plan ("2017 IRP")preferred portfolio identified a time-limited opportunity to procure
2 approximately 1,100 MW of cost-effective wind facilities and construct transmission
3 facilities to relieve existing congestion and allow interconnection of those new wind
4 facilities,while providing all-in customer savings.To capture the substantial customer
5 benefits resulting from this time-limited opportunity,the Company filed the
6 Application,including request for certificates of public convenience and necessity
7 ("CPCNs")for the construction or acquisition of approximately 860 megawatts
8 ("MW")of new wind facilities ("Wind Projects").'The Company has secured
9 development and implementation rights for the Wind Projects,which consist of four
10 individual wind facilities located in the state of Wyoming.The Wind Projects rely upon
11 the construction of the Aeolus-to-Bridger/Anticline transmission line and other
12 associated network upgrades (collectively,the "Transmission Projects"),which willO13relieveexistingcongestionandallowinterconnectionoftheWindProjects.2 In turn,
14 the benefits generated by the Wind Projects-zero-fuel-costgeneration that lowers net
15 power costs and ten years of federal productions tax credits ("PTCs"),support cost-
'None of the four wind facilities are qualifyingfacilities under the Public UtilityRegulatory Policies Act.See 18
C.F.R.§292.204 (defining criteria for qualifyingfacilities).
2 As more specifically described in the testimony of Mr.Rick A.Vail,the Transmission Projects include:(1)a
new 140-mile,500 kilovolt (kV)transmission line segment and associated infrastructure running from the new
Aeolus substation near Medicine Bow,Wyoming,to the new Anticline substation located near the existing Jim
Bridger substation,which includes construction of the new Aeolus and Anticline substations;(2)a new five-mile
345 kV transmission line that will extend from the proposed Anticline substation to the existing Jim Bridger
substation,which includes modifications at the existing Jim Bridger substation to allow termination of the new
345kV line;(3)installation of a voltage control device at the Latham substation (items 1 through 3 collectively
referred to as the "Aeolus-to-Bridger/Anticline line");(4)a new 16-mile,230 kV transmission line running from
the Company's existing Shirley Basin substation to the proposed Aeolus substation,which requires modifications
to the Shirley Basin substation and interconnection facilities in the new Aeolus substation to accommodate the
new line;(5)reconstruction of four miles of an existing 230 kV transmission line between the proposed Aeolus
substation and the Freezeout substation,which requires modifications to the Freezeout substation and
interconnection facilities in the new Aeolus substation to accommodate the rebuilt line;and (6)reconstruction of
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14 miles of an existing 230 kV transmission line between the Freezeout substation and the Standpipe substation,
which requires modifications to the Freezeout and Standpipe substations to accommodate the rebuilt line (items
4 through 6 collectively referred to as the "230 kV Network Upgrades").
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l effective development of the Transmission Projects.Together,the Wind Projects and
2 the Transmission Projects provide significant savings to customers over the lives of the
3 resources.
4 The Company is now conducting a competitive market renewables request for
5 proposals ("2017R RFP").Upon conclusion of the 2017R RFP,the Company will
6 confirm the specific wind facilities that it plans to construct or acquire.In the
7 Application,the Company provides detailed information on four wind facilities to meet
8 the CPCN requirements established by the Idaho Public Utilities Commission
9 ("Commission").The Company is submitting these four wind facilities as benchmark
10 resources in the 2017R RFP and proxy resources in the Application,pending the final
11 results of the 2017R RFP.My testimony and exhibits provide the information required
12 by Rule 112 of the Commission's Rules of Procedure ("RP"),related to the applicationO13forCPCNsfortheWindProjects.
14 Q.Please summarize your testimony.
15 A.My testimony demonstrates that the Company's proposals to construct or acquire
16 approximately 860 MW of new Wind Projects and construct the Transmission Project
17 (collectively"Combined Projects"or "Projects")is in the public interest and in the best
18 interest of customers.Together,the Projects provide substantial customer benefits as
19 long as both achieve commercial operation by the end of 2020.My testimony explains
20 how the Company intends to further develop and procure the Wind Projects and why it
21 is necessary to submit the Wind Projects as "proxy"facilities at this time while the
22 Company conducts the 2017R RFP in parallel with this CPCN proceeding.
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l Q.Why is the Company pursuingthe Wind Projects?
2 A.As further described in the testimonies of Ms.Cindy A.Crane and Mr.Rick T.Link,
3 the Company is pursuing the acquisition and development of the Combined Projects to
4 deliver a time-sensitive opportunity for customers that is identified in the Company's
5 2017 IRP preferred portfolio (i.e.,addition of approximately 1,100 MW of new wind
6 resources and the associated new transmission infrastructure by 2020).The Company
7 has executed the necessary agreements and engaged in the appropriate development
8 activities to ensure that viable Wind Projects to support the Transmission Projects are
9 available and positioned to ensure competitive market engagement,and have directly
10 controllable implementation plans.The Wind Projects support both this CPCN
11 proceeding and the Company's parallel path 20l7R RFP process.
12 GENERAL DESCRIPTION OF THE WIND PROJECTSO13Q.Please describe the Wind Projects.
14 A.The Wind Projects information incorporated into the Company's Application is
15 intended to allow the Commission to review the need,economic analyses,and customer
16 benefit of the Wind Projects while the Company's 20l7R RFP is pending.The Wind
17 Projects include three nominal 250 MW facilities in Wyoming (referred to as Ekola
18 Flats,TB Flats I,and TB Flats II)that a third-party is currentlydeveloping.Each facility
19 will consist of the commensurate number of 2.0 MW to 4.2 MW wind turbine
20 generators to achieve up to a nominal 250 MW nameplate capacity,an electrical
21 collection system,a 34.5 kV to 230 kV collector substation,230 kV breakers,a 230 kV
22 tie-line between the wind project and the point of interconnection substation,
23 meteorologicaltowers,access roads,an operations and maintenance ("O&M")building
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l and required communication and control facilities (e.g.,metering,hardware,software,
2 and associated communication circuits and other equipment).
3 The Wind Projects also include a fourth nominal 110 MW wind facility
4 (McFadden Ridge II),which the Company is currentlydeveloping on a Company-
5 controlled site in Wyoming.McFadden Ridge II is expected to consist of approximately
6 forty-four2.3 MW to 2.5 MW wind turbine generators and similar project infrastructure
7 as those described for the 250 MW facilities.
8 The Wind Projects incorporated into the Application total 860 MW nominally,
9 and represent facilities for which the Company has secured the rights to carry forward
10 through development.The Company will submit the Wind Projects into the 2017R RFP
11 as benchmark proposals,and will construct these facilities if they are the winning bids
12 in the 2017R RFP.O 13 The proposed Wind Projects are estimated to cost approximately .
14 Q.Why does the Company's Application seek a CPCN for only 860 MW of wind
15 facilities,when the 2017 IRP identified a resource opportunityof approximately
16 1,100 MW of wind facilities?
17 A.The Company is seeking CPCNs for only those facilities for which it has development
18 and implementation rights.
19 Q.Does the Company's economic analysis supporting the CPCNs for the
20 Transmission Projects include approximately1,100 MW of new wind facilities?
21 A.Yes.As the testimony of Mr.Link explains,the Company's economic analysis includes
22 certain known qualifyingfacilities ("QFs")now in development that are located in the
23 Aeolus area,hold preferential interconnectionqueue positions,have executed power
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l purchase agreements contracts,and are reasonably expected to be in service by year-
2 end 2021.When these QFs are considered in conjunction with the nominal 860 MW of
3 secured development opportunities,the total generating capacity equate to the 1,180
4 MW of new wind facilities analyzed in support of this Application.
5 Q.Please describe the time-sensitive nature of the Combined Projects.
6 A.The time-sensitive nature of the Combined Projects is primarilydriven by the pending
7 phase-out of the federal PTC for new wind resources.In Internal Revenue Code
8 ("IRC")section 45,the U.S.Internal Revenue Service ("IRS")provides for a PTC at
9 the 2017 full rate of 2.4 cents per kilowatt hour of electrical energy production by a
10 wind facility.The PTC is available for a 10-year period that begins when the facility is
11 placed in service.The Protecting Americans from Tax Hikes Act of 2015 ("the PATH
12 Act")extended the availability of the PTC for wind facilities under construction beforeO13January1,2020.The PATH Act extension,however,also provides for a phase-out of
14 the PTC.Wind facilities that began construction before January 1,2017,will realize
15 the full PTC credit,which is the case for the Wind Projects.If a wind facility begins
16 construction in 2017,the PTC is reduced by 20 percent.The PTC is reduced by
17 40 percent if construction begins in 2018,and by 60 percent if construction begins in
18 2019.The PTC is not available for wind facilities that begin construction after
19 December 31,2019.
20 To receive the "safe-harbor"PTCs,the facilities must be placed into
21 commercial operationby the end of the fourth calendar year following the year in which
22 construction began (the "start-of-construction"standard)or otherwise meet specific
23 IRS requirements for demonstrating the "continuity requirement"throughout the
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l implementation timeline.To mitigate the risk of interpretation of IRS's "continuity
2 requirement,"the Wind Projects (or other wind facilities selected in the 2017R RFP
3 that rely on (i)the Transmission Projects and (ii)also began construction prior to
4 January 1,2017)must be reviewed,approved,implemented,and placed in service by
5 year-end 2020 in accordance with the "start-of-construction"standard and meeting the
6 "safe-harbor"with respect to the "continuity requirement"to be eligible for the full
7 PTC.The Company's CPCN Application is designed to meet this schedule and provide
8 customers the full economic benefit of the Combined Projects.
9 Q.Do the Wind Projects meet the IRS's "start of construction"criteria?
10 A.Yes.To meet the "start of construction"definition for tax purposes,the Company has
11 acquired,or has the rights to,sufficient and adequate wind turbine generator equipment
12 and other facility-specific components for the Wind Projects purchased beforeO13December31,2016.These transactions satisfy the "safe harbor"requirements under
14 the PTC guidance issued by the U.S.Internal Revenue Service.
15 Q.How does the Company plan to procure the Wind Projects,or other new wind
16 facilities?
17 A.As discussed in the testimony of Mr.Link,concurrent with the CPCN proceeding,the
18 2017R RFP will be issued to the competitive market requesting up to 1,270 MW of
19 wind facilities to align with the new resource interconnections enabled by the Aeolus-
20 to-Bridger/Anticline facilities and to facilitate assessment of a wider range of market
21 responses.The Company will submit the Wind Projects as Company benchmark
22 proposals in the 2017R RFP in October 2017.The Company anticipates that the 2017R
23 RFP final shortlist of bids will be determined by mid-January 2018.
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l The Company will supplement its CPCN filing at that time to incorporate the
2 results of the 2017R RFP.Depending on the outcome,the results will:(1)confirm the
3 selection of winning Wind Projects and validate their benefits;(2)identify winning
4 wind facilities that are in addition to the Wind Projects and request a CPCN for those
5 projects;or (3)identifywinning wind facilities that have been selected instead of one
6 of the Wind Projects and request a CPCN for those facilities.In any scenario,this will
7 result in final wind facility decisions that are assessed as equal to or better than the
8 Wind Projects in the CPCN Application.
9 Q.Why is the Company providing facility-specificinformation for the Wind Projects
10 in the CPCN Application and also planning a supplemental filing in the CPCN
11 docket to incorporatethe results of the 2017R RFP?
12 A.The Company's request for a CPCN for the Projects is driven by the time-sensitivityO13andscaleofthefiling.If the Company waited until the anticipated conclusion of the
14 2017R RFP process in early 2018 to begin the CPCN review process,the Company
15 would not receive the requested Transmission CPCN and could not complete the
16 Transmission Projects by year-end 2020.The critical path schedules of the
17 Transmission Projects are the driving components of the CPCN procedural schedule,
18 and the Company needs a CPCN by March 30,2018,to maintain the development
19 schedule.Critical path schedule activities for the Transmission Projects are further
20 described in the testimony of Mr.Rick Vail.
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l Q.On a stand-alone basis,would the Company's ability to construct the Wind
2 Projects by year-end 2020 be in jeopardy if the Company was prevented from
3 submittinga CPCN Application until after completion of the 2017R RFP?
4 A.No.On a stand-alone basis,the critical path schedule for the Wind Projects could
5 accommodate a CPCN process that follows the 2017R RFP.As noted before,however,
6 the economics of the Wind Projects are onlyviable with the Transmission Projects,and
7 vice versa;the Transmission Projects are the critical path.
8 Q.How did the Company develop the Wind Projects?
9 A.The Company investigated the transmission interconnection queue in the area of the
10 Transmission Projects and engaged a third-party wind facility developer to identify
11 facilities that held preferred interconnectionqueue positions,are commercially viable,
12 and reasonably likely to achieve commercial operation by the end of 2020.The WindO13Projectshaveundergonepreliminaryvettingforinterconnectionstatus,permitting,
14 constructability,wind resource performance,and equipment supply.
15 Q.Does the Company anticipate that it will develop additional information for the
16 Wind Projects presented in the CPCN Application?
17 A.Yes.The Company will continue to work on the Wind Projects to ensure that the
18 Company makes the most competitive benchmark proposals available to customers.
19 The Company will supplement its CPCN filing as necessary.
20 Q.Does the Company's proposed proceduralprocess allow the Company to support
21 its CPCN filing with market-based information?
22 A.Yes.The Company will demonstrate the economic benefits of the Combined Projects
23 with all available competitive market-based information.The concurrent development
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l of the Wind Projects and the 2017R RFP process will enable the Company to validate
2 the reasonableness of the winning facilities based on current market information.
3 Q.Does the Company's submittal of benchmark resources in the 2017R RFP
4 preclude other competitive market proposals from being selected for
5 implementation?
6 A.No.The Company has assessed and identified only a portion of the competitive market
7 wind facilities that are reasonably assumed to be viable from an interconnection,
8 permitting,construction,performance,and implementationperspective.The Company
9 expects robust competitive market response to the 2017R RFP,and selection of any
10 facility that is successful in that process.
I 1 Q.Has the Company filed applications with the WyomingIndustrial Siting Council
12 for the Wind Projects?O 13 A.No.The Company intends to submit applications to the Wyoming Industrial Siting
14 Council ("ISC")for any Company benchmarks selected as successful bids in the
15 2017R RFP following completion of that process.The Company expects that the ISC
16 review process and hearings will proceed through October 2018.The ISC is required
17 to hold a hearing within ninety days of application per W.S.§35-12-109.
18 DEVELOPMENT OF WIND PROJECTS
19 Q.Has the Company performed preliminary evaluations of the wind potential at
20 each Wind Project site?
21 A.Yes.Studies completed by the Company indicate that the each of the Wind Project sites
22 are suitable for a wind facility.The Ekola Flats and TB Flats I and II sites are adjacent
23 to the Company's existing Dunlap and Seven Mile Hill wind projects.The McFadden
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1 Ridge II facility is an expansion of the Company's High Plains/McFadden Ridge wind
2 facility.Wind data collected from existing operations and the area of the Wind Projects
3 indicate that these sites have favorable wind regimes suitable for high performance
4 wind resources.
5 Q.Has the Company determined who will be responsible for construction of the
6 Wind Projects?
7 A.No.The Company has not currently identified who will be responsible for constructing
8 the Wind Projects.The Company will issue a competitive procurement request for
9 proposals to obtain firm fixed pricing to engineer,procure,construct and commission
10 each wind facility.The Company will do this as part of its development process for the
11 benchmark proposals.
12 Q.Has the Company determined who will supplythe wind turbine generators for the
13 Wind Projects?
14 A.Not entirely.As discussed above,the Company has acquired or has rights to acquire
15 "safe harbor"wind turbine generator equipment and other project-specific components,
16 which it proposes to use at the Wind Projects as required to meet the "start of
17 construction"criteria established by the Internal Revenue Service.The Company
18 intends to secure rights to procure "follow on"wind turbine generator equipment
19 through a competitive procurement request for proposals.As with the Company
20 benchmark contractor solicitation process,this effort will be performed as part of the
21 developmentprocess for the benchmark proposals.
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l Q.Will the Company seek confidential treatment of specific information regarding
2 the Wind Projects,including cost,performance,technical and commercial
3 information?
4 A.Yes.The Wind Projects represent onlya portion of the wind resources that the Company
5 expects to investigate for possible acquisition and/or development in response to the
6 2017R RFP.Information specific to the Wind Projects includes pricing and
7 performance data from wind turbine generator equipment suppliers and third-party
8 project developers that is commercially sensitive and is considered proprietary and
9 highly confidential.As such,project-specific cost,performance,technical and
10 commercial information,and other data,must be maintained as proprietary and highly
11 confidential information.This is in the best interest of customers because potential
12 counterparties may use such information to the disadvantage of customers in theO13bi-lateral proposals and negotiations for other wind resource assets,sites,equipment,
14 services (i.e.,construction,operation,or maintenance services)or in competitive
15 request for proposals processes.
16 Q.How did the Company generate the cost information for construction,operation,
17 and maintenance of the individual wind facilities through their useful life?
18 A.The Company prepared its capital cost estimates for the Wind Projects using
19 information from a variety of sources.The Company obtained wind turbine costs from
20 a competitive procurement process that was held in 2016 to procure the Company's
21 "safe harbor"wind turbine generator equipment.
22 Development costs reflect negotiated fees with the third-party project developer
23 for Ekola Flats and TB Flats I and II.The Company developed the balance of plant
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l engineering,procurement,construction,and commissioning costs using a cost model
2 similar to that used to develop supply side resource capital costs for the 2017 IRP.
3 The Company took the transmission interconnectioncosts from the respective
4 wind facility's transmission studies.Internal project management and permitting costs
5 were estimated based upon the Company's experience with construction of past wind
6 facilities and other recent generation resource additions.
7 The Company applied contingencies in various cost categories to account for
8 project uncertainties given the current stage of development of the Wind Projects.
9 O&M cost estimates were developed based upon the Company's experience with wind
10 resource O&M budgets and third-party contracts for the Company's existing wind
11 facilities.Ongoing capital costs were estimated based upon the Company's experience
12 and indicative costs provided by wind turbine generator suppliers for critical capital
13 components.
14 Q.Does the Company have any incentive to inflate the costs of the Wind Projects
15 incorporatedinto the CPCN Application?
16 A.No.As discussed earlier in my testimony,and in the testimony of Mr.Link,the purpose
17 of the Company's CPCN Application is to demonstrate the overall customer benefit of
18 the Combined Projects,and to further substantiate that benefit with the results of the
19 2017R RFP.With the inherent competitive market comparison to the RFP bids
20 underlying the process,there is no incentive or way for the Company to inflate the
21 costs,with recognition of the need for certain contingencies due to the current state of
22 developmentof the Wind Projects.
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l Q.Will the Wind Projects'wind turbine generators or associated infrastructure be
2 built in Wyoming's Greater Sage Grouse Core area?
3 A.No.The Wind Projects'wind turbine generators and associated infrastructure,
4 including the associated 230 kV interconnection tie-lines,will not be located within the
5 current boundaries of Wyoming's Greater Sage Grouse Core area.
6 Q.Will the Company collaborate with the WyomingGame and Fish Department,the
7 U.S.Fish and Wildlife Service,and other environmental agencies in developing
8 and implementingthe Wind Projects?
9 A.Yes.The Company has already initiated discussions with the Wyoming Game and Fish
10 Department and the U.S.Fish and Wildlife Service regarding developing and
11 implementing the Wind Projects.The Company,or in some instances the third-party
12 developer,has begun pre-construction usage surveys for various avian,bat,and wildlife
13 species utilizing recommendations from applicable state and federal guideline
14 documents,including the 2012 Land Based Wind Energy Guidelines.The Company
15 will coordinate with county,state,and federal agencies that have jurisdiction over
16 development,permitting,and operations to ensure appropriate environmental and
17 safety measures are implemented throughout the life of the Wind Projects.The
18 Company is committed to establishing development and implementation schedules and
19 protocols that recognize potential environmental impacts and strive to mitigate them.
20 Q.How will potential visual and lighting impacts from the Wind Projects be
21 addressed?
22 A.Wyoming state and county permitting regulations contain requirements that recognize
23 and address potential visual and lighting impacts.The Company will incorporate those
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l applicable measures into the siting,construction,and operations of the Wind Projects
2 as part of the permitting process.Such measures may include:down shielded lighting
3 on project infrastructure,Federal Aviation Administration approved/recommended
4 turbine lighting protocols,active aviation light management,and use of approved
5 turbine paint color schemes.
6 Q.What is the expected operational life of the Wind Projects?
7 A.The anticipated operationallife of the Wind Projects has been assessed at 30 years for
8 the purposes of this CPCN Application,which aligns with the Company's currently
9 approved depreciable life for wind resources.The operationallife may be reviewedand
10 extended based on advances in turbine technologies and/or improvements in
11 maintenance processes through the course of the Company's regular depreciation
12 studies and filings.O 13 Q.Will the Wind Projects be decommissioned or repowered at the end of their
14 operational life?
15 A.The Company may dismantle and reclaim the Wind Projects at the end of their
16 operationallife based upon operating permit requirements.Typically,county and state
17 agencies identify the decommissioning requirements during the permitting process,
18 including expected reclamation efforts and overall decommissioning costs and security
19 requirements.The Company may also consider replacing or upgrading the existing
20 infrastructure at the end of the operationallife if conditions (i.e.,economics,permitting,
21 customer load needs,etc.)are conducive to reinvestment in the Wind Projects.
22 Q.When will construction of the Wind Projects begin and end?
23 A.As described in detail in the exhibits attached to my testimony,site construction of the
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l Wind Projects will begin as soon as the fourth quarter of 2019.The Company will not
2 begin construction,however,until it has received all of the necessary regulatory
3 approvals and applicablepermits and authorizations from other local,state,Indian or
4 federal governmental agencies that have jurisdictionover the construction or operation
5 of the Wind Projects,including approval from the ISC and conclusion of the
6 2017R RFP to ensure that the projects ultimatelyselected are in the best interest of
7 customers.The Company anticipates that substantial completion,under normal
8 construction circumstances,weather conditions,labor availability and materials
9 delivery,will be achieved by November 15,2020.
10 Q.Please explain why the Wind Projects are required for the public convenience and
11 necessity.
12 A.As explained by Mr.Link,the Company's 2017 IRP shows that the Wind Projects are
13 a reasonable means of meeting present and future public convenience and necessity.In
14 this Application,the Company demonstrates that the Wind Projects are in the public
15 interest because:(l)they will become an essential element of the Company's
16 diversified resource portfolio that is needed to serve customers;(2)the facilities are
17 desirable due to location-specific attributes;and (3)the Wind Projects will benefit
18 customers as a whole.
19 REQUIREMENTSOF RP 112
20 Q.Please summarize how the Company's Application meets the requirements for a
21 CPCN application.
22 A.RP l12 describes what must be included in an application for a CPCN.As such,I have
23 incorporated exhibits to my testimony that include the required information for the
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1 Wind Projects.
2 Q.Please describe your exhibits for the nominal 250 MW Ekola Flats facility that are
3 responsive to RP 112.
4 A.The required information for the nominal 250 MW Ekola Flats facility is included in
5 Confidential Exhibit No.1 to my testimony.Confidential Exhibit No.1 Subparts are
6 identified as follows:
7 Highly Confidential Exhibit No.1-1-Wind Turbine Generator ("WTG")Site
8 Layout
9 Highly Confidential Exhibit No.l-2-WTG Scope of Supply Example
10 Confidential Exhibit No.1-3-Balance of Plant Scope of Work Template
11 Confidential Exhibit No.l-4-Capital Costs Detail
12 Confidential Exhibit No.1-5-Incremental Operational and MaintenanceandO13OngoingCapitalCostsDetail
14 Confidential Exhibit No.l-6-Indicative Project Execution Schedule
15 Highly Confidential Exhibit No.1-7-Preliminary Project Map
16 Confidential Exhibit No.1-8-Geotechnical Report
17 Confidential Exhibit No.1-9-Preliminary Topographical Map
18 Confidential Exhibit No.l-10-PreliminaryScenic Byways,Recreational Areas,
19 National Parks,and State Parks Review
20 Highly Confidential Exhibit No.1-11-PreliminaryCultural and Paleontological
21 Resources Review
22 Confidential Exhibit No.1-12-PreliminaryWildlife and Plant Species of
23 Potential Concern Review
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l Confidential Exhibit No.l-13-PreliminaryAviation and Airspace Review
2 Confidential Exhibit No.l-14-Interconnection Facilities Study
3 Confidential Exhibit No.1-15-PreliminaryLocal,State,Federal,and Tribal
4 Requirements Review
5 Q.Please describe the exhibits to your testimonyfor the nominal 250 MW TB Flats I
6 wind facility and the nominal 250 MW TB Flats II wind facility that are responsive
7 to RP 112.
8 A.The required information for the nominal 250 MW TB Flats I wind facility and the
9 nominal 250 MW TB Flats II wind facility is included in Confidential Exhibit No.2 to
10 my testimony.Confidential Exhibit No.2 Subparts 2-1 through 2-16 are provided with
11 the similar reference material designations as the Exhibit No.1 Subparts listed above.
12 The required information for these two facilities is incorporated into one set of exhibits
13 due to the contiguous development and adjacent locations of the facilities.
14 Q.Please describe the exhibits for the nominal 110 MW McFadden Ridge II wind
15 facility that are responsive to RP 112.
16 A.The required information for the nominal 110 MW McFadden Ridge II wind facility is
17 included in Confidential Exhibit No.3 to my testimony.Confidential Exhibit No.3
18 Subparts 3-1 through 3-17 are provided with similar reference material designations as
19 the Exhibit No.1 and Exhibit No.2 Subparts listed above.
20 Q.Do you propose to file supplemental testimony and exhibits upon completion of
21 the 2017R RFP?
22 A.Yes.The Company anticipates that the 2017R RFP final shortlist will be determined by
23 mid-January2018.I will file supplemental testimony and exhibits as soon as the results
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l of the 2017R RFP are final and the winning bids are known.In any scenario,the
2 winning bids will result in final wind facility decisions that are as beneficial to
3 customers or better than the Wind Projects described in my testimony and in the CPCN.
4 CONCLUSION AND RECOMMENDATION
5 Q.Please summarize your recommendation to the Commission.
6 A.I recommend that the Commission determine that the Wind Projects,or the alternative
7 or additional wind facilities that result from the 2017R RFP,are in the public interest.
8 Based on this conclusion,I recommend that the Commission grant the Company the
9 CPCNs for the Wind Projects,or alternatives that result from the 2017R RFP,at the
10 conclusion of these proceedings.
11 Q.Does this complete your direct testimony?
O 12 A.Yes.
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