20170705Teply Exhibit 3 - Redacted.pdf

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Case No.PAC-E-17-07
Exhibit No.3
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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Exhibit No.3 Page 1 of 15
Case No.PAC-E-17-07
Witness:Chad A.Teply
Information and Subpart Exhibits
For the McFadden Ridge II Proxy Project
Pursuant to Idaho Statue 61-526 and IPUC Rule 112
In support of its application,the Company provides the followinginformation and subpart
exhibits for the McFadden Ridge II 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 additional approximately 110 megawatts of wind
generation capacity adjacent to its existing High Plains/McFadden Ridge I wind generation facility.
This lateral expansion project (McFadden Ridge II)is located to the south and consists of
approximately 6,000 acres of leased private and state of Wyoming land in Carbon and AlbanyOCounties.Note that the proposed infrastructure will not require the use of any federal public lands,
managed by the Bureau of Land Management.
(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 McFaddenRidge II facility will consist of wind turbine generator(s)("WTGs"),an
electrical collector system,a collector substation,access roads,tower foundations,fiber optic
and/or microwave communication equipment,and supervisory control and operating status data
acquisition ("SCADA")control equipment,and an approximately three-mile interconnecting230
kilovolt ("kV")transmission tie-line that will interconnect at the existing Foote Creek Rim
substation.The WTGs are anticipated to be purchased from competing suppliers,and the balance-
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of -project work will be competitively bid and executed under an engineer,procure and construct
("EPC")contract.
Maps of the proposed project area are presented in Highly Confidential Exhibit No.3-1,
along with an overview of WTG placement across the site.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.3-2 is provided as an example of certain extractions from
a WTG purchase agreement.
Confidential Exhibit No.3-3 is provided as an example of a technical specification for the
scope of work included in the 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 McFaddenRidge 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 any incremental interconnection network upgrade costs
that are assumed to be the responsibility of the transmission provider.Project cost details are
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summarized in Confidential Exhibit No.3-4.
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 projects and transmission facilities
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 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
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:
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.
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The approximate operational,maintenance and ongoing capital co e
setCehdaadsAareespulyt
of this project are presented in Confidential Exhibit No.3-5.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
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 requiredto 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)operating 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.3-6.
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Witness:Chad A.Teply
(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
.The town of McFadden is located
to the west of the project area.The western side of the proposed
project is located in Carbon County,and the eastern side in Albany County.
The project lies within the drainage system of Coalbank Creek and its tributaries,which
are tributaries to Rock Creek.Rock Creek occurs approximately three miles north of the site.
Livestock ranching operations occur on a majority of the proposed project area.The elevation
throughout the site ranges from approximately 7,100 to 7,400 feet above mean sea level.
Highly Confidential Exhibit No.3-7 presents a map of area surface ownership,along with
a table that provides the legal description of the project location.The project will be located on
leased private fee lands.PacifiCorp will obtain a Special Use Lease from the Wyoming School and
Land Board Trust for state-owned parcels within the project boundary.
(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:
The North Platte River Basin contains a wide variety of geologic formations and structural
elements.Geologic formations vary in thickness and range from crystalline bedrock to alluvial
deposits.The project is located in the Laramie Basin,which is a wide intermontane valleysituated
between the Medicine Bow Mountainsto the west and the Laramie Mountains to the east.Bedrock
geology in the project area consists of gravel,pediment,and fan deposits;Lewis Shale;the Hanna
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Witness:Chad A.Teply
Formation;and the Medicine Bow Formation.Gravel,pediment,and fan deposits in the project
area are dominated by quartzite,with cobbles,pebbles,and gravels,located close to the ground
surface.Lewis Shale is a dark gray marine deposit that crops out along the eastern margins of the
Great Divide and Washakie basins in south-central Wyoming.It consists of at least twenty
depositionalsequencesthat contain isolated sandstone and siltstone beds.Bentonite beds also are
present in the lower part of the Lewis shale.The Hanna Formation is a non-marine sedimentary
stratum that was deposited as outwash during the Laramide Orogeny and was subsequently folded
and eroded in places,forming a hogback ridge.Its composition varies from shale to sandstone and
conglomerate,but within the project area it is dominated by quartzite conglomerate.As with the
Hanna Formation,the Medicine Bow formation occurs at ground surface and is composed of coal,
carbonaceous shale,and sandstone alluvial plan deposits.
Confidential Exhibit No.3-8 presents preliminary geotechnical reports for the McFadden
Ridge I and High Plains wind generation facilities that are provided as proxy foundation
information for the McFadden Ridge II facility.
The primary aquifer systems used in the project area are described as quaternary (alluvial
deposits)and late cretaceous aquifer systems in the northernarea and early tertiary aquifersystems
in the southern area.The direction of groundwatermovement in the alluvium of the stream valleys
is generally downstream and toward the stream,and most streams in the area derive some of their
flow from groundwater.The primary source of recharge is from infiltration of snowmelt and runoff
water.The majority of groundwater use in the area is for agricultural and domestic purposes.
Groundwaterwells within the area vary in depth from 40 to 225 feet below ground surface ("bgs")
with static water levels ranging from 12 to 118 feet bgs.
PacifiCorp will continue to assess the impacts of any operating mineral deposits
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Witness:Chad A.Teply
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 topographicalmap showing the terrain of the surrounding area within a five-mile radius
of the facility is provided as Confidential Exhibit No.3-9.
(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.3-10 provides information on area scenic byways,recreational
locations,national parks,and state parks.The Edness Kimball Wilkins,Glendo,Seminoe,and
Pathfinder State Parks are located in the region,along with Ayers Natural Bridge and Pathfinder
National Wildlife Refuge recreation facilities.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
anticipatedto 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 project details emerge.
Highly Confidential Exhibit No.3-11 provides information on known cultural and
paleontological resources at the project site.The preliminary project layout has been arranged to
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avoid impacts to cultural resources.Additionally,no project-related features will be developed in
close proximity to known cultural resources.It is anticipated that no National Register of Historic
Places eligible archeological sites will be affected by the project.As part of PacifiCorp's plan for
protecting the environment,sensitivity practices would be adhered to and any cultural resources
would be afforded appropriate protection if discovered during design and construction.
A wetland delineation report is presented in Confidential Exhibit No.3-12.Based on the
preliminary site layout,it is anticipated that all potential impacts on jurisdictionalwaters of the
U.S.and wetlands are currentlyassociated with the construction of access roads.Therefore,the
project will likely qualify for use of U.S.Army Corps of Engineers Nationwide Permit 12 for
utilityline construction activities,including access roads.Any impact to wetlands and the waters
of the U.S.will be minimized using best management practices,including installation of culverts.
Cumulative impacts are not expected to be significant.
The project area lies within the Wyoming Basin ecoregion.The Wyoming Basin ecoregion
is found in portions of Colorado,Idaho,Montana,Utah,and Wyoming.This ecoregion is a broad
intermontane basin dominated by arid grasslands and shrublands supporting bunchgrasses and
sagebrush,interrupted by high hills and low mountains.Most of the uplands in the project area are
mapped as mixed-grass vegetative community cover-type (a mixture of graminoids,forbs,and
shrubs,with less than 25 percent of the canopy cover contributedby shrubs).Additional vegetative
community cover types include Wyoming big sagebrush,irrigated cropland,dry-land crop,
greasewood,and basin rock soil.Riparianareas are a mosaic of riparian shrubland on Dutton Creek
and small inclusion of riparian forest along Rock Creek.A small area of saltbush community
occurs along the southern boundary.No known threatened or endangered plant species or rare
vegetativecommunities exist within the project area;therefore,the project will not contribute to
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Witness:Chad A.Teply
cumulative degradation of these resources.Any introduction of new noxious weeds by
construction truck traffic will be controlled using best management practices.
Wild animals including mule deer,whitetail deer,pronghorn antelope,coyotes,chipmunks,
prairie dogs,ground squirrels,and rattlesnakes have been observed.Seasonal range maps indicate
that crucial winter range of the pronghorn antelope is contained within the northeastern portion of
the existing wind generation area,but not continuing into the McFadden Ridge II expansion area.
See Confidential Exhibit No.3-13 for a presentation of the antelope range map.Birds including
red-tailed hawks,golden eagles,bald eagles,nighthawks,sparrows and various songbirds have
been observed.Migrating waterfowl,passerines,shorebirds,raptors,upland game birds,and
waterbirds travel through and have been observed in the area during spring and fall migration
periods.Based on avian use studies conducted,estimated bird mortality at the site would likely be
similar or lower than other wind generation facilities located in the western U.S.where observed
bird collision mortalityhas been relatively low.
No federally listed wildlife or bat species were observed within the project area while
spring and fall 2007 baseline avian surveys and 2008 raptor nest searches were conducted.
However,the survey conducted in 2007 and spring 2008 confirmedthe presence of one active bald
eagle nest along Rock Creek and northwest of the project area.
Surveys for greater sage-grouse were conducted concurrently with avian baseline surveys
in 2007 and 2008.The proposed project area and a one mile buffer distance were surveyed by foot
and vehicle.There are no documented greater sage-grouse leks within one mile of the project area
boundary,and no leks were found during the 2007 and 2008 avian surveys of the project area.
Greater sage-grouse use of the project area appears to be very low,with only two groups totaling
13 individuals being observed.The project area has been historically grazed,and there is a lack of
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Witness:Chad A.Teply
mature sagebrush,and therefore,suitable cover for greater sage-grouse throughmost of the project
area.Due to the low occurrence date and low flight path,greater sage-group mortality due to
collisions with WTGs is not likely to occur.The incremental amount of habitat lost in the project
area should result in minimal impacts to the greater sage-grouse.
A project area avian constraints map is presented as Confidential Exhibit No.3-14;and the
avian baseline use report is presented as Confidential Exhibit No.3-15.
PacifiCorp is continuing to collect bat data within the project area.
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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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 nationallyaccepted 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 WTG 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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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 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 continues to
be reviewed.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 throughcollaboration 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 significant fuel,minerals,or process water requirements for this project.
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 shared
existing operations /maintenance building,and will be limited to consumption in restrooms,sinks,
washing station(s),showers,internal /external hose use,and as dishwater.
A shared existing septic system and drain field for sanitary sewer waste disposal will be
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provided at the shared existing facilities.
Witness:chad A.Teply
(O)The acquisition status,source and location of real property,right-of-way,fuel and
water requirements:
Property and right-of-wayacquisition status was mentioned previously.There are no fuel
acquisition requirements for this project.A groundwater use application will be applied for from
the Wyoming State Engineer's Office if a new extraction well is necessary.
(P)The proposed means of transporting fuel and water requirements:
There is no process related requirement to transport material quantities of fuel and water
for this project.
(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 unilaterally displace 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:
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
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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 which was
submitted to the Commission in compliance with Commission Rules.
(S)A description of the commodity or 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:
This project is not expected to adversely affect the quality,stability,and reliability of the
PacifiCorp transmission system or that of other entities.A High Plains proxy large-generator
interconnection"Facilities Study Report"and McFadden Ridge II status application is provided as
Confidential Exhibit No.3-16 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.3-17.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,as required by 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 and Albany County Planning
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and Zoning Commissions,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 followingdocuments included in Exhibit No.3 are confidential or highly confidential in their
entirety:
Highly Confidential McFaddenRidge Proxy WTG Site Layout
Exhibit No.3-1
Highly Confidential McFaddenRidge I Amended WTG Scope of Study
Exhibit No.3-2
Confidential Balance of Plant Scope of Work Template
Exhibit No.3-3
Confidential McFaddenRidge II Proxy Capital Costs Detail
Exhibit No.3-4
Confidential McFadden Ridge II Proxy Incremental O&M and Ongoing Capital
Exhibit No.3-5 Costs Detail
Confidential McFaddenRidge II Indicative Project Execution Schedule
Exhibit No.3-6
Highly Confidential McFaddenRidge II Preliminary Project Map
Exhibit No.3-7
Confidential McFadden Ridge II Geotechnical Report
Exhibit No.3-8
Confidential McFaddenRidge II Preliminary Topographical Map
Exhibit No.3-9
Confidential McFadden Ridge II Preliminary Scenic Byways,Recreational Areas,
O Exhibit No.3-10 National Parks,and State Parks Review
Highly Confidential McFadden Ridge II Preliminary Cultural and Paleontological
Exhibit No.3-11 Resources Review
Confidential McFaddenPreliminary Wildlife and Plant Species of Potential
Exhibit No 3-12 Concern Review
Confidential Preliminary Antelope Range Map
Exhibit No.3-13
Confidential Preliminary Avian Constraints Map
Exhibit No.3-14
Confidential Preliminary Avian Baseline Use Report
Exhibit No.3-15
Confidential McFaddenRidge II InterconnectionFacilities Study
Exhibit No.3-16
Confidential McFaddenRidge II Preliminary Local,State,Federal,and Tribal
Exhibit No.3-17 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 [phone] to make arrangements to review.
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