20170705Teply Exhibit 2 - Redacted.pdf

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Case No.PAC-E-17-07
Exhibit No.2
Witness:Chad A.Teply
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
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Exhibit Accompanying Direct Testimony of Chad A.Teply
June 2017
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Rocky Mountain Power
Exhibit No.2 Page 1 of 14
Case No.PAC-E-17-07
Witness:Chad A.Teply
Information and Subpart Exhibits
For the TB Flats I and TB Flats II Proxy Projects
Pursuant to Idaho Statue 61-526 and IPUC Rule 112
In support of its application,the Company provides the following information and subpart
exhibits for the TB Flats I and TB Flats II proxy projects.
(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 two separate approximately 250-megawatt wind
generation facilities,designated as TB Flats I and TB Flats II,located on a site that consists of
approximately 41,000 acres of leased private and state land located in Carbon and Albany
Counties,Wyoming.At the time of filing,division of the site into the specific areas for the TBOFlatsIandTBFlatsIIprojectshasnotoccurred.
(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 TB Flats I and TB Flats II facilities will each consist of wind turbine generator(s)
("WTGs"),an electrical collector system,a collector substation,access roads,tower foundations,
an operations/maintenance building,fiber optic and/or microwave communicationequipment,and
supervisory control and operating status data acquisition ("SCADA")control equipment.For the
TB Flats I project,the facility includes approximately four miles of an interconnecting230 kilovolt
("kV")transmission tie-line.The anticipated point of interconnectionwill be at a new substation
on the Shirley Basin-Freezeout transmission line at 230 kV in Carbon County.For the TB Flats II
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Exhibit No.2 Page 2 of 14
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Witness:Chad A.Teply
project,the facility includes approximately four miles of an interconnecting230 kV transmission
tie-line.The anticipated point of interconnectionwill be at the Shirley Basin substation at 230 kV
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.
An overview of WTG placement across the proposed project sites is presented in Highly
Confidential Exhibit No.2-1.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.2-2 is provided as an example of certain extractions from
a WTG purchase agreement.
Confidential Exhibit No.2-3 is provided as an example of a technical specification for the
scope of work included in a balance of project EPC 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 TB Flats I facility is
approximately ,including capital surcharge and allowance for funds used during
construction.This total estimated project cost includes the associated directly assigned
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Exhibit No.2 Page 3 of 14
Case No.PAC-E-17-07
Witness:Chad A.Teply
transmission costs,but does not include incremental interconnection network upgrade costs that
are assumed to be the responsibility of the transmission provider.
At the time of filing,the total estimated project cost for the TB Flats II 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 incremental interconnection network upgrade costs that
are assumed to be the responsibility of the transmission provider.
Project cost details for each site are summarized in Confidential Exhibit No.2-4.
(F)State the manner by which the proposed construction or acquisition will be
financed:
The Company intends to finance the proposed wind projects and transmission facilities
through its normal sources of capital,both internal and external,including net cash flow from
operatmg 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 wind and transmission facilities are a significant investment on the part of
the Company,the financial impact will not impair the Company's ability to continue to provide
safe and reliable electricity service at reasonable rates.In addition,preapproval of 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
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this project.
Witness:Chad A.Teply
(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:
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 each project are presented in Confidential Exhibit No.2-5.Wind lease royaltycosts are included
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
mamtenance 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.Incremental O&M
costs reported include labor,employee expenses,materials,and contracts.
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Witness:Chad A.Teply
(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)operating date is November 2020,under
normal construction circumstances,weather conditions,labor availability,materials delivery,and
permit/agreement processing durations.An indicative project execution schedule for each project
is provided as Confidential Exhibit No.2-6.
(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:
For both projects,the site footprint spans
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.The town of Medicine Bow
is located to the south of the project south boundary.The project site
varies in elevation,with a representative elevation of approximately 6,700 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.2-7 presents a map of area surface ownership,along with a table that provides the legal
description of the project location.
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Exhibit No.2 Page 6 of 14
Case No.PAC-E-17-07
Witness:Chad A.Teply
(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.2-8 is a geotechnical report for the Dunlap Ranch Wind Energy
facility and is provided now as proxy geological and foundationinformation for the TB Flats I and
TB Flats II facilities.Regional geologicconditions 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.
The project area is anticipated to be within the Lower Cretaceous aquifer.Groundwater
wells in the area varies 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.2-9.
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Case No.PAC-E-17-07
Witness:Chad A.Teply
(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.2-10 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 ofOtheruralsettingoftheproject.The WTGs are not anticipated to significantly degrade the
surrounding scenic quality of the area.
PacifiCorp has preliminarilysited project components to mitigate potential environmental
and natural resource impacts in the project area.This effort will continue as details for each project
emerges.
Highly Confidential Exhibit No.2-11 provides information on known cultural and
paleontological resources at the project sites.The preliminary project layout has been arranged to
avoid impacts to cultural resources.Additionally,no project-relatedfeatures 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.
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Exhibit No.2 Page 8 of 14
Case No.PAC-E-17-07
Witness:Chad A.Teply
Each project has the flexibility to "microsite"major project features to avoid or
significantlyreduce impacts to jurisdictional waters of the U.S.and wetlands.More importantly,
no adverse impacts to wetland and water resource bodies are anticipated for these projects.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,juniperand 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,mountainmahogany,bunchgrasses,forbs,and prickly pear /pincushion cacti 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 unique vegetativecommunities are documented
or have been currentlymapped 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 these projects 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
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Exhibit No.2 Page 9 of 14
Case No.PAC-E-17-07
generation facilities located in the area.
Witness:Chad A.Teply
No currentlyoccupied greater sage-grouse leks are located within each project area.
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.2-12,including U.S.Fish and Wildlife Service listed species,Wyoming
Game and Fish Department species of greatest conservation need,and Bureau of Land
Management sensitive 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.Grounddisturbance 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
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 affiliated personnel 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 potentialsafety hazards:
Prevention of 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
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Case No.PAC-E-17-07
Witness:Chad A.Teply
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 applicable building 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
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.
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Exhibit No.2 Page 11 of 14
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Witness:Chad A.Teply
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 ice
throw injury has been reported from existing wind generation projects.Icing is a rare event,and
the turbines for these projects 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 each project site from an aviation and airspace point of view is presented
in Confidential Exhibit No.2-13.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.
(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 projects will be constructed in the vicinity and above the Medicine Bow River
drainage.
At the time of this filing,it is anticipated that during construction of the projects,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
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Case No.PAC-E-17-07
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operations/maintenance building,and is anticipated to be limited to consumption in restrooms,
sinks,washing station(s),showers,internal/externalhose 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 these projects.Groundwateruse applications will be applied from the
Wyoming State Engineer's Office for each 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 these projects.
(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 completed 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.
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Case No.PAC-E-17-07
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(R)A statement setting forth the need for the facility in meeting present and future
demands for service in Idaho and other states:
Development of the proposed wind generation facilities 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 IRP 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.
(T)A statement of the facilities effect on the applicant's and other systems'stabilityand
reliability:
Each project is not expected to adversely affect the quality,stability,and reliability of the
Rocky Mountain Power ("RMP")transmission system or that of other entities.A large-generator
interconnection "Facilities Study Report"is provided as Confidential Exhibit No.2-14 that
summarizes the expected impact for the TB Flats I facility.
A large-generator interconnection "Facilities Study Report"is provided as Confidential
Exhibit No.2-15 that summarizes the expected impact for the TB Flats II facility.
(U)The status of satisfying local,state,tribal or federal governmental agency
requirements.The applicant shall immediatelyfill 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 each project is listed,along with their timing and status,in
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Case No.PAC-E-17-07
Witness:Chad A.Teply
Confidential Exhibit No.2-16.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,pursuant to 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 storm water pollution prevention control,
compliance with building regulations through the Carbon County Planning and Zoning
Commission,Albany 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.
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The following documents included in Exhibit No.2 are confidential or highly confidential in their
entirety:
Highly Confidential TB Flats Proxy WTG Site Layout
Exhibit No.2-1
Highly Confidential WTG Scope of Study Example
Exhibit No.2-2
Confidential Balance of Plant Scope of Work Template
Exhibit No.2-3
Confidential TB Flats I and TB Flats II Proxy Capital Costs Detail
Exhibit No.2-4
Confidential TB Flats I and TB Flats II Proxy Incremental O&M and Ongoing
Exhibit No.2-5 Capital Costs Detail
Confidential TB Flats Indicative Project Execution Schedule
Exhibit No.2-6
Highly Confidential TB Flats Preliminary Projcet Map
Exhibit No.2-7
Confidential TB Flats Proxy Geotechnical Report
Exhibit No.2-8
Confidential TB Flats Preliminary Topographical Map
Exhibit No.2-9
Confidential TB Flats Preliminary Scenic Byways,Recreational Areas,National
O Exhibit No.2-10 Parks,and State Parks Review
Highly Confidential TB Flats Preliminary Cultural and PaleontologicalResources
Exhibit No.2-11 Review
Confidential TB Flats Preliminary Wildlife and Plant Species of Potential
Exhibit No 2-12 Concern Review
Confidential TB Flats Preliminary Aviation and Airspace Review
Exhibit No.2-13
Confidential TB Flats I InterconnectionFacilities Study
Exhibit No.2-14
Confidential TB Flats II InterconnectionFacilities Study
Exhibit No.2-15
Confidential TB Flats Preliminary Local,State,Federal,and Tribal Requirements
Exhibit No.2-16 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 [phone] to make arrangements to review.
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