HomeMy WebLinkAbout20170705Teply Exhibit 1 - Redacted.pdfREDACTED
Case No.PAC-E-17-07
Exhibit No.1
Witness:Chad A.Teply
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
REDACTED
Exhibit Accompanying Direct Testimony of Chad A.Teply
June 2017
O
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 1 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
Information and Subpart Exhibits
For the Ekola Flats Proxy Project
Idaho Statue 61-526 and IPUC Rule 112
In support of its application,the Company provides the followinginformation and subpart
exhibits for the Ekola Flats proxy project.
(A)The name and address of the applicant:
This information is provided in the application.
(B)The type of plant,property,or facility proposed to be constructed or acquired:
PacifiCorp proposes to construct an approximately 250 megawatt wind generation facility
located on a site that consists of approximately 17,000 acres of leasedprivate and state land located
in Carbon County,Wyoming.
(C)A description of the facilities proposed to be constructed or acquired,including
preliminaryengineering specifications in sufficient detail to properly describe the principal
systems and components,and final and complete engineering specifications when they
become available:
The Ekola Flats facility will consist of wind turbine generators ("WTGs"),an electrical
collector system,a collector substation,access roads,tower foundations,an
operations/maintenance building,fiber optic and/or microwave communication equipment,
supervisory control and operating status data acquisition ("SCADA")control equipment,and an
approximately seven-mile interconnecting 230 kilovolt ("kV")transmission tie-line.The
anticipated point of interconnectionwill be at the proposed Aeolus 230 kV substation in Carbon
County.The WTGs are anticipated to be purchased from competing suppliers,and the balance of
project work will be competitively bid and executed under an engineer,procure and construct
("EPC")contract.
Page 1
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 2 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
An overview of WTG placement across the proposed project site is presented in Highly
Confidential Exhibit No.1-1.WTG placement will continue to evolve based on several factors,
including:land acquisition,field-identified sensitive environmentalareas,field-identified cultural
areas,landowner commentary received from future WTG placement reviews,definitive
geotechnical site studies,aviation/air space impact reviews,and wind resource characteristics.
Highly Confidential Exhibit No.1-2 is provided as an example of certain extractions from
a WTG purchase agreement.
Confidential Exhibit No.1-3 is provided as an example of a technical specification for the
scope of work included in a balance-of-projectEPC contract.
(D)List the rates,if any,proposed to be charged for the service that will be rendered
because of the proposed construction or acquisition:
The rates proposed to be charged for the service rendered as a result of the project are the
applicable standard service schedules,rules,and regulations in the Company's Idaho tariffs,and
as may be modified and approved by the Commission in the future.
(E)State the estimated total cost of the proposed construction or acquisition:
At the time of filing,the total estimated project cost for the Ekola Flats facility is
approximately ,including capital surcharge and allowance for funds used during
construction.This total estimated project cost includes the associated directly assigned
transmission costs,but does not include any incremental interconnection network upgrade costs
that are assumed to be the responsibility of the transmission provider.Project cost details are
summarized in Confidential Exhibit No.1-4.
O
Page 2
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 3 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
(F)State the manner by which the proposed construction or acquisition will be financed:
The Company intends to finance the proposed wind project through its normal sources of
capital,both internal and external,including net cash flow from operating activities,public and
private debt offerings,the issuance of commercial paper,the use of unsecured revolving credit
facilities,capital contributions and other sources.The financial impact of the proposed investment
will not impair the Company's ability to continue to provide safe and reliable electricity service at
reasonable rates.In addition,preapprovalof the Company's resource decision provides important
regulatory support for the Company's current credit rating.This is described in more detail in
Ms.Cindy A.Crane's testimony.
(G)Documentation of the financial condition of the applicant:
Rocky Mountain Power's ("RMP")current financial condition is on file with the
Commission in response to the annual reporting requirements and through RMP's semi-annual
earnings reports or its general rate case application.PacifiCorp is financiallycapable of funding
this project.
(H)The estimated annual operating revenues and expenses that are expected to accrue
from the proposed construction or acquisition,including a comparison of the overall effect
on the applicant's revenues and expenses:
To address this requirement of the Commission's rules,PacifiCorp provides the economic
analysis presented in Mr.Link's testimony and exhibits,which show the revenue stream and
expenses associated with the proxy wind projects and demonstrates that the project is a risk-
adjusted,least-cost alternativeto serve customer loads.
The approximate operational,maintenance and ongoing capital costs expected as a result
of this project are presented in Confidential Exhibit No.1-5.Wind lease royaltycosts are included
O
Page 3
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 4 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
in these amounts.Routine maintenance of the WTGs will be necessary to maximize performance
and detect potential malfunctions.Operational and maintenance ("O&M")procedures will be
established in accordance with the WTG manufacturer's recommendations.Scheduled
maintenance will be conducted approximately every six months on each WTG.Substations,step-
up transformers,and pad-mounted transformers will be maintained as part of normal operating
activities.Periodic maintenance of underground collection lines will also be required.No
substantial quantities of industrial materials will be brought onto or removed from the site during
execution of O&M tasks.Project operation will use lubricants,oils,grease,antifreeze,degreasers,
and hydraulic fluids,which will be stored in approved containers and located above ground.
During operation,it is also anticipated that hazardous waste generation will be either zero or
minimal.A minimal amount of energy will be required to operate the project.O&M costs reported
include labor,employee expenses,materials,and contracts.
(I)The estimated start and completion dates of the proposed construction or date of
acquisition:
PacifiCorp proposes to begin engineering and construction of the project in April 2018.
The proposed project commercial operation (in-service)date is November 2020,under normal
construction circumstances,weather conditions,labor availability,materials delivery,and permit
and agreement processing durations.An indicative project execution schedule is provided as
Confidential Exhibit No.1-6.
(J)A description of the proposed site,including the county or counties in which the
facility will be located,with a metes and bounds description,and a description of the terrain
where the facility will be constructed:
The project footprint spans
O
Page 4
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 5 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teoly
.The town of Medicine Bow is located
to the southeast of the project area.The project site varies in elevation,
with a representative elevation of approximately 6,550 feet above mean sea level.Mountain
elevations in the area rise to approximately 8,300 feet.The site drainage follows the path of Muddy
Creek and tributaries,which are tributary to the Medicine Bow River that joins the North Platte
River at the Seminoe Reservoir located to the northwest.Highly Confidential Exhibit No.1-7
presents a map of area surface ownership,along with a table that provides the legal description of
the project location.
(K)A geological report of the proposed site,including foundation conditions,
groundwater conditions;operating mineral deposits within a one-mile radius and a
topographicalmap showing the area within a five-mile radius:
Confidential Exhibit No.1-8 is a geotechnical report for the Dunlap Ranch Wind Energy
facility and is provided as proxy geological and foundationinformation for the Ekola Flats facility.
Regional geologic conditions are summarized within the Dunlap geotechnical report.
Also,according to the U.S.Geological Survey Digital Geologic Map of Wyoming,the
project area intersects fifteen geologic formations.These include:the Chugwater Formation,
Clovery Formation,Ferris Formation,Frontier Formation,Goose Egg Formation,Lewis Shale,
Medicine Bow Formation,Mesaverde Formation,Mowry Shales,Niobrara Formation,Steele
Shale,Wind River Formation,Sundance Formation,Tensleep Sandstone Formation,and Amsden
Formation.
O
Page 5
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 6 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
The project area is anticipated to be within the Lower Cretaceous aquifer.Groundwater
wells in the area vary in depth from 45 to 99 feet below ground surface ("bgs"),with well static
water levels ranging from three to 20 feet bgs.
PacifiCorp will continue to assess the impacts of any operating mineral deposits
approximately within a one-mile radius of the facility.This project is not expected to affect
operating mineral deposits or oil and gas leases.
A topographical map showing the terrain of the surrounding area within a five-mile radius
of the facility is provided as Confidential Exhibit No.1-9.
(L)A description of and plans for protecting the surrounding scenic,historical,
archeological and recreational locations;natural resources;plantand animal life;and land
reclamation,including:(I)A general description of the devices to be installed at the major
utility facility to protect air,water,chemical,biological and thermal qualities;(II)The
designed and tested effectiveness of such devices;and (III)The operational conditions for
which the devices were designed and tested:
Confidential Exhibit No.1-10 provides information on nearby area scenic byways,
recreational locations,national parks,and state parks;and visual simulation photos of the
completed project area.To the east of the project site,located along Wyoming Highway 487,is the
historic Sand Creek Massacre Trail.The trail was dedicated on August 16,2006.The trail exists
in Wyoming as a memorial to the Arapaho and Cheyenne who lost their lives at the Sand Creek
Massacre in Colorado in 1864.Impacts to visual resource concerns should be minimal because of
the rural setting of the project.The WTGs are not anticipated to significantly degrade the
surrounding scenic quality of the area.
O
Page 6
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 7 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
PacifiCorp has preliminarilysited project components to mitigate potential environmental
and natural resource impacts in the project area.This effort will continue as project details emerge.
Highly Confidential Exhibit No.1-11 provides information on known cultural and
paleontological resources at the project site.The preliminary project layout has been arranged to
avoid impacts to cultural resources.Additionally,no project related features will be developed in
close proximity to known cultural resources.As part of PacifiCorp's plan for protecting the
environment,sensitivity practices would be adhered to and any cultural resources would be
afforded appropriateprotection if discovered during design and construction.
The project has the flexibilityto microsite major project features to avoid or significantly
reduce impacts to jurisdictional waters of the U.S.and wetlands.More importantly,no adverse
impacts to wetland and water resource bodies are anticipated for this project.Any impact to
wetlands and the waters of the U.S.,should they arise,will be minimized using best management
practices.
The project area lies within the Rolling Sagebrush Steppe,Foothill Shrublands,and Low
Mountains Ecoregions.Within these areas,Wyoming big sagebrush,rabbitbrush,prickly pear,
wheatgrass,and fescues are common.In rock outcrop areas,juniper and mountain mahogany are
also expected.The lowland plain zones,a variable brush layer of tall big sagebrush,greasewood,
bunchgrasses,forbs,and prickly pear have been observed.In upland areas,mountain big
sagebrush,mountain mahogany,bunchgrasses,forbs,and pricklypear/pincushioncacti have been
observed.Occasionally,more diverse riparian communities are present along spring-fed draws,
where red willow,chokecherry,currants,various tall grasses,various reeds,forb varieties,thistle,
Indian paintbrush are present.Currently,no rare or uniquevegetativecommunities are documented
O
Page 7
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 8 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
or have been mapped within the project area.Therefore,it is not anticipated that the project will
contribute to degradation of these resources.
Wild animals including mule deer,whitetail deer,pronghornantelope,coyotes,chipmunks,
prairie dogs,ground squirrels,and rattlesnakes have been observed.Birds including red-tailed
hawks,golden eagles,bald eagles,nighthawks,sparrows and various songbirds have been
observed.Construction of the project will potentially cause temporary displacement of individuals
for some wildlife species that would move on in response to project activities,and lead to
permanent impacts to wildlife.
Estimated bird mortality at the site would likely be similar to,or less than,other wind
generation facilities located in the area.
Two occupied greater sage-grouse leks are located within the project footprint.The
occupied leks are located in .
PacifiCorp will continue to collect bat data within the proposed project area.
Wildlife and plant species of potential concern that continue to be assessed are presented
in Confidential Exhibit No.1-12,including U.S.Fish and Wildlife Service listed species,Wyoming
Game and Fish Department species of greatest conservation need,and Bureau of Land
Managementsensitive species.
At the end of project life,PacifiCorp will have reserved funds in its asset retirement
obligation ("ARO")account and will use ARO funding to restore the site to near natural conditions.
Lands disturbed during construction would be reclaimed to current conditions to the extent
practicable.Ground disturbance would be minimized and best management practices employed by
the construction contractors to minimize environmental impacts.PacifiCorp would also employ
an environmental inspector(s)to ensure that environmental considerations,and any unforeseen
O
Page 8
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 9 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
environmental incidents,are appropriately addressed.This individual would ensure prompt and
appropriate response to any identified non-compliance situations and ensure environmental
protections are appropriately implemented.Periodic environmental audits of the site will also be
conducted by PacifiCorp afHliatedpersonnel that are independent of the project team.
During construction,each on-site contractor will be expected to develop,publish and
orchestrate a site-and project-specific environmentalprotection plan.
Site specific wildlife management plans will be developed and implemented.
(M)A description of any potential safety hazards:
Preventionof safety hazards and impacts from failure of the project's components will be
achieved by a combinationof planning and controlled site access.By followingindustry guidelines
and WTG certification processes,the most safe and reliable facility will be constructed.WTGs are
equipped with multiple safety systems as standard equipment.For example,rotor speed is
controlled by a redundant pitch control system and a backup disk brake system.Critical
components have multiple temperature sensors and a control system to shut the system down and
take it off-line if overheating conditions are detected.Lightning protection is a standard feature on
the WTG,and a specially engineered lightning protection and site grounding system will be
installed for the project.
Turbine towers,tower foundations,and above-ground transmission line support structures
will be designed according to applicablebuilding codes and nationally accepted design standards
to avoid failure or collapse.The selected WTG and tower combination will be subjected to
engineeringreview to ensure that the design and construction specifications are appropriate for the
project.This review will include consideration of code/nationally accepted design standard
requirements under various anticipated worst-case loading conditions and provide a high degree
O
Page 9
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 10 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
of confidence in the structural adequacy of the towers.The WTGs have been preliminarilysited at
locations which exceed a reasonable set-back of over one tip-height.
During active construction,PacifiCorp will follow the manufacturers'recommended
handling instructions and erection procedures to prevent material damage to towers or blades that
could lead to failure.In addition,certification of the WTGs to the requirements of the International
Electrotechnical Commission ("IEC")61400-1 standard will ensure that the static,dynamic,and
defined-life fatigue stresses in the blades will not be exceeded under the combined load
combinations expected at the project site.The standard includes safety factors for normal,
abnormal,fatigue,and construction loads.This certification,together with regular periodic
inspections,will give a high level of assurance against blade failure during operation.
The WTGs will be sited at locations that exceed a reasonable set-back distance to safeguard
against ice throw.Ice throw over long distances has not been documented as a hazard,and no iceOthrowinjuryhasbeenreportedfromexistingwindgenerationprojects.Icing is a rare event,and
the turbines for this project will be situated in a remote area.
During construction,planned construction safety controls include (1)a "PacifiCorp Safety
Plan,"and (2)the EPC contractor's "Site Specific Safety Plan."
The feasibility of the project site from an aviation and airspace point of view is presented
in Confidential Exhibit No.1-13.The WTGs will be grouped in strings,and some of the WTGs
will include aviation warning lights,as required by the Federal Aviation Agency ("FAA").The
number of WTGs with lights and the lighting pattern of the WTGs will be determined through
collaboration with the FAA.
O
Page 10
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 11 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
(N)A description of the real property,fuel and water requirements,including any source
of water along which the majorutility facility will be constructed or from which it will obtain
or return water:
There are no fuel,minerals,or process water requirements for this project.
The project will be constructed in the vicinity and above the Medicine Bow River drainage.
At the time of this filing,it is anticipated that during project construction,water will be
obtained from a municipal water source,an existing senior water rights holder and trucked to the
site,or a new well with a permit issued by the Wyoming State Engineer's Office to appropriate
groundwater.Once availableon-site,water will either be put to immediate use or placed in an on-
site temporary water storage tank.Once the project is in operation,only minimal daily domestic
water use will be required.The primary domestic water requirement will occur at the O&M
building,and is anticipated to be limited to consumption in restrooms,sinks,washing station(s),
showers,internal/external hose use,and as dishwater.
A septic system and drain field for sanitary sewer waste disposal will be provided once the
project is operational.
(O)The acquisition status,source and location of real property,rights-of-way,fuel and
water requirements:
Property and rights-of-way acquisition status was mentioned previously.There are no fuel
acquisition requirements for this project.A groundwater use application will be applied from the
Wyoming State Engineer's Office for a new extraction well.
(P)The proposed means of transportingfuel and water requirements:
There is no process-related requirement to transport material quantities of fuel and water
for this project.
O
Page 11
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 12 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
(Q)A description of all mineral rights associated with the facility and plans for addressing
any split-estate issues:
PacifiCorp will not own any of the subsurface rights at the site.The Company does not
believe that any subsurface right holder will be able to unreasonably displace the resource or any
portion of the resource.
PacifiCorp has done prudent legal research on its rights as a surface lease holder,as
compared to those of subsurface right holders,and is comfortable that the law does not allow
subsurface right holders to unilaterallydisplace the Company's facilities and that any subsurface
right holder would be required to enter into good faith negotiations to reasonably accommodate its
subsurface extraction objective.
(R)A statement setting forth the need for the facility in meeting present and future
demands for service in Idaho and other states:O Development of the proposed wind generation facility in compliance with regulatory
requirements is the risk-adjusted,least-cost alternative to meet service obligations in Idaho and
other states as represented in the Company's testimony and exhibits.The Company's prospective
generation planning activities are further described in the Company's 2017 Integrated Resource
Plan,which was submitted to the Commission in compliance with Commission Rules.
(S)A description of the commodityor service the facility will make available:
The project will generate electricity using wind as the renewable energy source.Fossil fuel
consumption and waste residual disposal obligations will be avoided.
O
Page 12
REDACTED
Rocky Mountain Power
Exhibit No.1 Page 13 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
(T)A statement of the facilities effect on the applicant's and other systems'stabilityand
reliability:
This project is not expected to adversely affect the quality,stability,and reliability of the
PacifiCorp transmission system or that of other entities.A large-generator interconnection
"Facilities Study Report"is provided as Confidential Exhibit No.1-14 that summarizes the
expected impact.
(U)The status of satisfying local,state,tribal or federal governmental agency
requirements.The applicantshall immediately fill all agencies'final orders:
A list of the local,state,tribal,and federal governmental agencies having requirements
known at the time of this application,which PacifiCorp must meet in connection with the
construction and operation of the project is listed,along with their timing and status,in
Confidential Exhibit No.1-15.Any unforeseen permit requirements will be adequately addressed.
By applying to and working with the various agencies for the construction/operation
permits and the Commission,in accordance with Commission rules,the major regulatory
requirements and critical reviews for the project are being addressed.PacifiCorp's contractors may
provide certain permits including permits for construction stormwater pollution prevention
control,compliance with building regulations through the Carbon County Planning and Zoning
Commission,sanitary sewer extensions,and requirements of the Wyoming Department of
Transportation.PacifiCorp will monitor and audit the successful completion,maintenance and
closeout of all contractor supplied permits.
O
Page 13
The following documents included in Exhibit No.1 are confidential or highlyconfidential in their
entirety:
Highly Confidential Ekola Flats Proxy WTG Site Layout
Exhibit No.1-1
Highly Confidential WTG Scope of Supply Example
Exhibit No.1-2
Confidential Balance of Plant Scope of Work Template
Exhibit No.1-3
Confidential Ekola Flats Proxy Capital Costs Detail
Exhibit No.1-4
Confidential Ekola Flats Proxy Incremental O&M and Ongoing Capital Costs
Exhibit No.1-5 Detail
Confidential Ekola Flats Indicative Project Execution Schedule
Exhibit No.1-6
Highly Confidential Ekola Flats Preliminary Project Map
Exhibit No.1-7
Confidential Ekola Flats Proxy Geotechnical Report
Exhibit No.1-8
Confidential Ekola Flats Preliminary TopographicalMap
Exhibit No.1-9
Confidential Ekola Flats Preliminary Scenic Byways,Recreational Areas,
O Exhibit No.1-10 National Parks,and State Parks Review
Highly Confidential Ekola Flats Preliminary Cultural and PaleontologicalResources
Exhibit No.1-11 Review
Confidential Ekola Flats Preliminary Wildlife and Plant Species of Potential
Exhibit No 1-12 Concern Review
Confidential Ekola Flats Preliminary Aviation and Airspace Review
Exhibit No.1-13
Confidential Ekola Flats InterconnectionFacilities Study
Exhibit No.1-14
Confidential Ekola Flats Preliminary Local,State,Federal,and Tribal
Exhibit No.1-15 Requirements Review
The confidential exhibits listed above are provided on CD.
The highly confidential exhibits listed above contain commercially sensitive information which is
considered business confidential information.The Company requests special handling.Please
contact Ted Weston at (801)220-2963 to make arrangements to review.
O