20180117Teply Exhibit 32 - Redacted.pdf

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Case No.PAC-E-17-07
Exhibit No.32
Witness:Chad A.Teply
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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ROCKY MOUNTAIN POWER
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Exhibit Accompanying Supplemental Direct Testimony of Chad A.Teply
January 2018
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Rocky Mountain Power
Exhibit No.32 Page 1 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
Information and Subpart Exhibits
For the TB Flats I and II Wind Energy Project
Idaho Statue 61-526 and IPUC Rule 112
In support of its application,the Company provides the following information and
subpart exhibits for TB I and II Wind Project.
(A)The name and address of the applicant:
This information was provided in the application on June 30,2017.
(B)The type of plant,property,or facility proposed to be constructed or acquired:
PacifiCorp proposes to construct a 500-megawatt (nominal)project designated as the TB
Flats I and II project.The project is located on a site that consists of approximately 50,000 acres
of leased private and state land located in Wyoming s Carbon and Albany Counties.
(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 II wind energy project 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,
permanent meteorological towers,wind-measurement equipment,and supervisory control and
operating status data acquisition ("SCADA")control equipment.For the TB Flats I and II project,
this facility includes an interconnecting 230 kV transmission tie-line,and the anticipated point of
interconnectionwill be at the Shirley Basin substation.The WTG supply and balance of project
engineer,procure,and construct ("EPC")contracts were competitively bid,and negotiations
continue toward reaching final contract terms.
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Witness:Chad A.Teply
Updated maps of the WTG placement across the proposed project sites is presented in
Confidential Exhibit No.32-1.WTG placement will continue to evolve based on several factors,
including:land acquisition,field identified sensitive environmental and cultural areas,landowner
commentary received from future WTG placement reviews,definitive geotechnical site studies,
aviation /air space impact reviews,site access availability,and wind resource characteristics.
Confidential Exhibit No.2-2 was provided previously as an example of a WTG purchase
agreement,including specifications.(Exhibits that have not been updated are not resubmitted in
this CPCN filing supplement.)
Confidential Exhibit No.2-3 was provided previously 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 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").
(E)State the estimated total cost of the proposed construction or acquisition:
At the time of the supplemental filing,updated estimated project cost details are
summarized in Confidential Exhibit No.35.
(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
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facilities,capital contributions and other sources.The fmancial impact of the pro sed
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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 fmancial 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.
(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.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.
The approximate operational,maintenance,and ongoing capital costs expected as a result
of each project are presented in previously provided Confidential Exhibit No.2-5.Wind lease
related costs are included in these amounts.Routine maintenance of the WTG 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 on each WTG.Substations,step-up transformers,and
pad-mounted transformers will be maintained as part of normal operating activities.Periodic
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Witness:Chad A.Teply
maintenance of underground collection lines will also be required.No substantial quantities of
industrial materials will be broughtonto 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 aboveground.During operation,it is also
anticipated that hazardous waste generation will be 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 ofthe project in June 2018,but
with only limited construction activities occurring in 2018.The proposed project commercial
operation operating date is November 1,2020,under normal construction circumstances,weather
conditions,labor availability,materials delivery,and permit/agreement processing durations.An
indicative project execution schedule for the project was previously 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:
The site footprint spans Township ("T")27 North ("N")and Range ("R")78 West ("W")
of the sixth principle meridian in the north direction;T 23 N and R 78 W in the south direction;T
26 N and R 78 W and T 25 N and R 78 W in the west direction;and to east direction,extending
into Albany County at parcel T 25 N and R 77 W.The town of Medicine Bow is located
approximately five miles to the south of the project south boundary.The project site varies in
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Witness:Chad A.Teply
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.Updated Confidential Exhibit No.
32-7)presents a map of area surface ownership.
(K)A geological report of the proposed site,including foundation conditions,
groundwater conditions;operating mineral deposits within a one-mile radius and a
topographical map showing the area within a five-mile radius:
Confidential Exhibit No.32-8,previously provided,is a geotechnical report for the Dunlap
Ranch Wind Energy facility and was provided as proxy geological and foundation information for
the TB Flats I and Il 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.
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.
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PacifiCorp will continue to assess he 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 topographicalmap showing the terrain of the surrounding area within a five-mile radius
of the facility was provided previously as Confidential Exhibit No.2-9.
(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.2-10,provided previously,presents information on nearby area
scenic byways,recreational locations,national parks,and state parks.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 Arapahoand
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 project will
be sited adjacent to existing wind projects with similar visual impacts.The WTGs are not
anticipated to significantly degrade the surrounding scenic quality of the area.
PacifiCorp has preliminarily sited project components to avoid and /or minimize potential
environmentaland natural resource impacts in the project area.This effort will continue as details
for each project emerges.
Confidential Exhibit No.2-11,provided previously,presents information on known
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Witness:Chad A.Teply
cultural and paleontologicalresources at the project sites.The preliminary project layout has been
arranged to avoid and /or minimize impacts to 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 required by the State Historic Preservation Office in the
event of a discovery 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 permanent
losses of 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,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,mountain mahogany,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 vegetative communities are documented
or have been currently 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,pronghorn antelope,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
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observed.Construction of the project will potentially cause temporary displacement of individuals
for some wildlife species that may relocate in response to project activities,and lead to permanent
impacts to wildlife.
Wildlife impact studies are on-going and PaciñCorp will utilize recommendations from
existing U.S.Fish and Wildlife Service and Wyoming Game and Fish Department guidance
documents to implement appropriate avoidance,minimization,and mitigation practices.
No currently occupied greater sage-grouse leks are located within project area.
PaciñCorp will continue to collect bat use data within the proposed project area.
Wildlife and plant species of potential concern that continue to be assessed are presented
in previously provided Confidential Exhibit No.32-12,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.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
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
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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:
Prevention of safety hazards and impacts from failure of the project's components will be
achieved by a combination of planningand controlled site access.By followingindustry guidelines
and WTG certification processes,the most safe and reliable facilitywill 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 WTGs,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
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 to provide a high degree of
confidence in the structural adequacy of the towers.The WTG have been preliminarily sited 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 a failure.In addition,certification of the WTG to the requirements of the
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International Electrotechnical Commission ("IEC")61400-1 standard to ensure that the static,
dynamic,and defmed-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 WTG 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:(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 previously provided 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 collaborationwith 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
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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 operations /
maintenance 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,right-of-way,fuel and
water requirements:
Property and right-of-way acquisition status was mentioned previously.There are no fuel
acquisition requirements for these projects.A groundwater use application will be applied 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 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
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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.The Company plans to approach any active minerals extraction
company with operating facilities,permits secured,or planned activities to secure appropriate
agreement(s),which would detail the manner in which both the Wind Project and the subject
minerals activitycould coexist.
(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 forward
looking generation planningactivities 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.
(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'sand 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.An updated large
generator interconnection "Facilities Study Report"is provided as Confidential Exhibit No.32-14
that summarizes the expected impact for the TB Flats I facility.
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ExhibitNo.32 Page 13 of 13
Case No.PAC-E-17-07
Witness:Chad A.Teply
An updated large generator interconnection "Facilities Study Report"is provided as
Confidential Exhibit No.32-14 that summarizes the expected impact for the TB Flats II facility.
It is further reported that the transmission provider will be further revising the updated TB
Flats "Facilities Study Reports."
(U)The status of satisfying local,state,Tribal or federal governmental agency
requirements.The applicant shall 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 ofeach project is listed,along with their timing and status,in previously
provided Confidential Exhibit No.32-16.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 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,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.32 are confidential in their entirety:
Confidential TB Flats I and II WTG Layout
Exhibit No.32-l
Confidential TB Flats I and II Landowner Map
Exhibit No.32-7
Confidential TB Flats I and II Large Generator InterconnectionReport
Exhibit No.32-14
The confidential exhibits listed above are provided on CD.
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