20180117Teply Exhibit 31 - Redacted.pdf

REDACTED
Case No.PAC-E-17-07
Exhibit No.31
Witness:Chad A.Teply
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
REDACTED
Exhibit Accompanying Supplemental Direct Testimony of Chad A.Teply
January 2018
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Rocky Mountain Power
Exhibit No.31 Page 1 of 7
Case No.PAC-E-17-07
Witness:Chad A.Teply
Information and Subpart Exhibits
For the Cedar Springs Wind Energy Project
Idaho Statue 61-526 and IPUC Rule 112
For each site located in Wyoming,the CPCN application or testimony must contain:
1.Name and address of the applicant:
This information was provided in the application filed June 30,2017.
2.Type of plant,property,or facility proposed to be constructed:
Applicant proposes to construct a nominal 400-megawatt ("MW")wind-energy
generation facility located on a site that consists of approximately 35,000 acres of leased
private land located in Converse County,Wyoming.
3.Description of facilities to be constructed including preliminary engineering
specifications in sufficient detail to properly describe the principal systems and
components:
The Cedar Springs wind energy facility will consist of wind turbine generators
("WTGs"),an electrical collector system,a collector substation,access roads,WTG
foundations,an operations and maintenance building,fiber optic and/or microwave
communication equipment,supervisory control and operating status data acquisition
("SCADA")control equipment,and an approximately 20-mile long interconnecting 230
kilovolt ("kV")transmission tie-line.The anticipated point of interconnection will be at the
Windstar substation in Converse County,Wyoming.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 site is presented in
Confidential Exhibit CAT-1SD-l.WTG placement will continue to evolve based on
several factors including:field-identified sensitive environmental areas,field-identified
cultural areas,landowner commentary received from future reviews of WTG placement,
definitive geotechnical site studies,aviation/air-space impact reviews,and wind-resource
characteristics.
A site wind-resource assessment has been completed and summary information is
presented in Confidential Exhibit No.31-2.
4.Rates to be charged because of the proposed construction:
The impact of the proposed facilities on the Company's revenue requirement and
the Company's proposed ratemaking treatment is described in the testimony of Ms.Joelle
R.Steward.In addition,the Company will provide service on the Transmission Projects
subject to the terms and conditions of its Open Access Transmission Tariff ("OATT").
5.Estimated total cost of the proposed construction:
Estimated project initial capital cost details for the Cedar Springs facility are
O summarized in Confidential Exhibit No.35.
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Witness:Chad A.Teply
6.Manner by which the project 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 contributionsand 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,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.
7.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 through RMP's annual
earnings reports.The Company is financiallycapable of funding this project.
8.Estimated annual operating revenues and expenses expected to accrue from the
project 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.Rick T.Link's testimony and exhibits,which show the
revenue stream and expenses associated with the wind projects and demonstrates that the
project is a risk-adjusted,least-cost alternativeto serve customer loads.
9.Estimated start and completion dates:
The project developer and PacifiCorp will enter into a build-transfer agreement
under which PacifiCorp will acquire 50 percent ofthe project,and the balance ofthe project
will be delivered under a power purchase agreement.The project developer will design,
permit,secure property rights,obtain critical agreements,construct,and commission the
project.The project developer proposes to complete environmental and cultural surveys in
April 2019 and transmission line construction in April 2020.The expected proposed project
commercial-operation date is December 2020,under normal construction circumstances,
weather conditions,labor availability,materials delivery,and permit and agreement
processing durations.
An indicative project schedule is presented in Confidential Exhibit No 31-3.
10.Description of the site(s)including:
a.county,
Converse County,Wyoming
b.metes and bounds description,and
See Confidential Exhibit No.3 l -4 for a project description map
indicating parcels that are proposed for leased for wind and transmission
development.A more specific metes bounds description is presented in
Confidential Exhibit No.31-5.Tie-line property information is presented in
Highly Confidential Exhibit No.31-6.
c.terrain;
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Witness:Chad A.Teply
i.The project site is located in central Converse County,at an elevationrange
of 5,000 to 5,500 feet.The terrain consists of rolling range land with a
predominant southeast -northwest ridge feature (Box Creek Divide)and a
northern plateau (Highland Flats).The land use consists of sheep and cattle
grazing,with oil and gas exploration distributedthroughout the entire site.
Habitat within the project site is predominatelyherbaceous grasslands and
scrub-shrub.Common mixed grass prairie species include needle-and-
thread (Hesperostipa comata),western wheatgrass (Pascopyrum smithii),
blue grama (Bouteloua gracilis),Sandberg's bluegrass (Poa secunda),
prairiejunegrass (Koeleria macrantha),upland sedges,and Indian ricegrass
(Oryzopsis hymenoides).The scrub habitats likely consist of sagebrush
(Artemesia tridentata)and various other shrub species.
11.Geological report including:
a.foundation and groundwater conditions,
i.The dominant wetland type is freshwater emergent wetland within the
project site,in addition to a number of scattered ponds throughout the area.
Converse County also shows a lake and a few areas mapped as riverine.
There are freshwater forested/shrub wetlands located in Converse County
within the vicinity of the site.
b.operating mineral deposits within a one-mile radius,and
i.Oil and gas operations are present throughout the site.Anschutz,
O Chesapeake and other mineral developers are active in the area.
ii.In-situ uranium mining occurs in the northwest portion ofthe site.A historic
Exxon open-cut uranium mine exists in the northwest portion of the site,
however it is no longer active.
c.A topographic map showing the area within a five-mile radius.
i.A topographical map showing the terrain of the surrounding area of the
facility is provided as Confidential Exhibit No.31-1.
d.Site geotechnical and geologic studies have not yet started.
12.Description of and plans for protecting the surrounding locations:
a.Scenic,
b.Historical,
c.Archeological,
d.Recreational,
e.Natural resources,
f.Plant and animal life,
g.Land reclamation
i.Description of devices to be installed to protect:
1.Air,
2.Water,
3.Chemical,
4.Biological,and
5.Thermal qualities.
ii.Design and tested effectiveness of protection devices to be used;and
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Case No.PAC-E-17-07
Witness:Chad A.Teply
iii.Operational conditions under which the protection devices were
designed and tested
The Cedar Springs facility is located in an area that is typical of the
landscape of the region.The WTGs are not anticipated to significantly degrade the
surrounding scenic quality of the area.
The project developer has preliminarily sited project components to
mitigate potential environmental and natural resource impacts in the project area.
This effort will continue as project details emerge.
Confidential Exhibit No.31-7 presents indicative information regarding
critical site environmentalfeatures to be addressed as the project proceeds.
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 appropriate protection 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.
At the end of project life,and in accordance with applicable permit
O conditions PacifiCorp may have reserved funds in its asset retirement obligation
("ARO")account and may use ARO funding to restore the site to near natural
conditions.
Lands disturbed during construction would be reclaimed in accordance with
applicable permit requirements.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
environmentalincidents,are appropriatelyaddressed.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
in accordance with applicable permit requirements.
Confidential Exhibit No.31-8 presents currently known raptor nest
information.
The approximate 20-mile long transmission tie-line will be included in the
Wyoming Industrial Siting Act permit application for the Cedar Springs facility.
Information regarding the status of project permitting activity is presented
in Confidential Exhibit No.31-9.
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Witness:Chad A.Teply
13.Description of potentialsafety hazards;
Prevention of safety hazards and impacts from failure of the project's components
would be achieved by a combination of planning and controlled site access.By
following industry 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,WTG 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 engineering review 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 will provide a high degree of confidence
in the structural adequacy of the towers.The WTGs have been preliminarily sited at
locations which exceed a reasonable setback of over one tip-height.
During active construction,the project developer will follow the manufacturers'
recommended handling instructions and erection procedures to prevent material
O 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 be provided to 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.No ice throw injury has been reported from existing
wind generation projects.In general,icing is an infrequentevent,and the turbines for
this project will be situated in a remote area.
During construction,planned construction safety controls include a "Site Specific
Safety Plan."
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 WTG will be determined through
collaboration with the FAA.
14.Description of real property,fuel and water requirements,including any source of
water along which the 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.
At the time of this supplemental filing,it is anticipated that during project
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Witness:Chad A.Teply
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 available on-site,
water will either be put to immediate use or placed in an onsite 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/externalhose use,and as dishwater.
A septic system and drain field for sanitary sewer waste disposal will be provided
once the project is operational.
15.Acquisition status,source and location of:
a.Real property,
b.Right-of-way,
c.Fuel,and
d.Water requirements
The Cedar Springs facility will be located on private property currently under
long-term lease,the area as described in Confidential Exhibit No.31-4.The
transmission tie-line will primarily cross private property and will avoid federal lands
to the maximum extent possible.Final transmission routing and ROW acquisition will
begin in April 2018.
There are no fuel acquisition requirements for this project.A groundwater use
O application will be applied for from the Wyoming State Engineer's Office for a new
extraction well.
16.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.
17.Description of all mineral rights associated with the facility and plans for addressing
any split-estate issues;
Mineral rights across the site are split between State and Federal governments and
third party holdings,the majority of which have been severed from the surface owner.The
State's mineral rights are generally tied to the surface rights,however there are rare
exception,predominantly near water ways,where there may be exceptions to this.
The project is expecting to enter into accommodation agreements with the mineral rights
holders across the project to resolve any split-estate issues.
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Witness:Chad A.Teply
18.Statement detailing the need for the facility in meeting present and future demands
for service in ID or 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 other states as represented in the Company's testimony and
exhibits.The Company's forward looking generation planning activities are further
described in the Company's 2017 IRP which was submitted to the Commission on April
4,2017,in Case No.PAC-E-17-03.
19.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.
20.Statement of the effect on the system stabilityand reliability;and
The 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.Large
generator interconnection "System Impact Re-Study Report"is provided as Confidential
Exhibit No.31-10 that summarizes the expected impact.
Confidential Exhibit No.31-11 presents images of the 20-mile 230 kV tie-line and
tie-line structures.
21.Status of local,state,Tribal,or federal governmentalagency requirements (must file
all agencies final orders)O a.Local -A Wind Energy Conversion System ("WECS")Use Permit is required in
Converse County.The project is anticipating filing and obtaining a WECS Use
Permit in 2018
b.State -A Wyoming Department of EnvironmentalQuality Industrial Siting Council
("ISC")Permit is required for wind energy project with 30 or more towers in all
phases.An application will be submitted to ISC in 2018 with approval anticipated
in late 2018 or 2019.
c.Federal -No NEPA approval is required for the project.
d.Tribal -No Tribal permit is required for the project.
e.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.31-9.Any unforeseen permit
requirements will be adequately addressed.
f.By applying to and working with the various agencies for the
construction/operation permits and the Commission,in accordance with
Commission rules at Section 21(c),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,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.31 are confidential or highly confidential in
their entirety:
Confidential Cedar Springs WTG Layout
Exhibit No.31-1
Confidential Cedar Sprints Site Wind Resource Data
Exhibit No.31-2
Confidential Cedar Springs Preliminary Project Schedule
Exhibit No.31-3
Confidential Cedar Springs Project Maps
Exhibit No.31-4
Confidential Cedar Springs Metes and Grounds Descriptions
Exhibit No.31-5
Highly Confidential Cedar Springs Generation Landowner Information
Exhibit No.31-6
Confidential Cedar Springs Environmental Studies
Exhibit No.31-7
Confidential Cedar Springs Raptor Nest Information
Exhibit No.31-8
Confidential Cedar Springs Permitting Matrix
Exhibit No.31-9
Confidential Cedar Springs System Impact Re-Study Q712
O Exhibit No.31-10
Confidential Cedar Springs 230 kV Tie Line Structure Details
Exhibit No.31-11
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.