20180117Teply Exhibit 33 - Redacted.pdf

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Case No.PAC-E-17-07
Exhibit No.33
Witness:Chad A.Teply
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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ROCKY MOUNTAIN POWER
REDACTED
Exhibit Accompanying Supplemental Direct Testimony of Chad A.Teply
January 2018
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Rocky Mountain Power
ExhibitNo.33 Page 1 of 15
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Witness:Chad A.Teply
Information and Subpart Exhibits
For the McFadden Ridge II Wind Energy Project
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 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 l 10 megawatts (nominal)of wind energy generation
capacity adjacent to its existing High Plains/McFadden Ridge I wind energy generation facility.
This lateral expansion project (named McFadden Ridge II)is located to the south,and exclusively
consists of approximately 5,500 acres of wind lease private and state of Wyoming land in Carbon
and Albany Counties.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 McFadden Ridge II facility will consist of wind turbine generators ("WTGs"),an
electrical collector system,a collector substation,access roads,WTG foundations,fiber optic
and/or microwave communication equipment,supervisory control and operating status data
acquisition ("SCADA")control equipment,permanent meteorological towers with wind
O measurement equipment,and an interconnecting 230 kilovolt ("kV")transmission line tap to the
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McFadden Ridge I/High Plains substation radial tie-line from the existing Foote Creek Rim
substation.The WTG supply and the balance of project engineer,procure,and construct ("EPC")
contracts were competitively bid,and negotiations to reach final contract terms continue.
An updated map of the proposed project area is presented in Confidential Exhibit No.33-1,
which presents an overview of WTG placement across the site.WTG placement will continue to
evolve based on several factors,including: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.33-2 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.3-3 was provided previously 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 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.
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(F)State the manner by which the proposed construction or acquisition will be financed:
The Company intends to finance the proposed wind project through its normal sources of
capital,both internal and external,including net cash flow from operating activities,public and
private debt offerings,the issuance of commercial paper,the use of unsecured revolving credit
facilities,capital contributions and other sources.The financial impact of the proposed investment
will not impair the Company's ability to continue to provide safe and reliable electricity service at
reasonable rates.In addition,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 in Commission Rule Section 32 and
through RMP's semi-annual earnings reports.The Company is financially capable 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 alternative to serve customer loads.
The approximate operational,maintenance and ongoing capital costs expected as a result
of this project were presented in previously provided Confidential Exhibit No.3-5.Wind lease
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related costs 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 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 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 of the project in June 2018,but
with only limited 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 and agreement processing durations.An
indicative project execution schedule was previously provided as Confidential Exhibit No.3-6.
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(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 across Township ("T")20 North ("N")and Range ("R")77
West ("W")of the sixth principle meridian and T 19 N and R 77 W.The town of McFadden is
located approximately two miles to the west of the project area.The western side of the proposed
project is located in Wyoming's 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
throughoutthe site ranges from approximately 7,100 to 7,400 feet above mean sea level.
Confidential Exhibit No.3-7,previously provided,presents a map of area surfaceOownership,along with a table that provides the legal description ofthe project location.The project
will be located on leased private fee lands owned by the Dunmire Ranch Company and Sims Land
and Livestock,Inc.and on lands owned by the state of Wyoming.PacifiCorp has obtained 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
topographical map 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 valley situated
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between the Medicine Bow Mountainsto the west and the Laramie Mountainsto the east.Bedrock
geology in the project area consists of gravel,pediment,and fan deposits;Lewis shale;the Hanna
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 depositional
sequences that 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,
O 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,previously provided,presents preliminary geotechnical
reports for the McFadden Ridge I and High Plains wind energy facilities that were provided as
proxy foundation information for the McFadden Ridge II wind energy facility.
The primary aquifer systems used in the project area are described as quaternary (alluvial
deposits)and late cretaceous aquifer systems in the northern area and early tertiary aquifer systems
in the southern area.The direction of groundwater movement 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.
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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
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 was provided previously as Confidential Exhibit No.3-9.
(L)A description of and plans for protecting the surrounding scenic,historical,
archeological and recreational locations;natural resources;plant and 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,provided previously,presents 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.Impacts to visual resource
concerns should be minimal because of the rural setting of the project and the existing WTGs
located adjacent to the project.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 project
details emerge.
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Confidential Exhibit No.3-11,provided previously,presents information on known
cultural and paleontological resources at the project site.The preliminary project layout has been
arranged to avoid and /or minimize impacts to 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 in the event of a discovery during
design and construction.
A wetland delineation report is presented in previously provided Confidential Exhibit No.
3-12.Based on the preliminary site layout,it is anticipated that all potential impacts on
jurisdictional waters of the U.S.and wetlands are currently associated with the construction of
access roads.Therefore,it is concluded that the project will likely qualify for use of U.S.Army
Corps of Engineers Nationwide Permit 12 for utility line construction activities,including access
roads.Any impact to wetlands and the waters ofthe 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,interruptedby 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 ofthe canopy cover contributed by shrubs).Additional vegetative
community cover types include Wyoming big sagebrush,irrigated cropland,dry-land crop,
greasewood,and basin rock soil.Riparian areas are a mosaic of riparian shrubland on Dutton Creek
and small inclusion of riparian forest along Rock Creek.A small area of saltbush community
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occurs along the southern boundary.No known threatened or endangered plant species or rare
vegetative communities exist within the project area;therefore,the project will not contribute to
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 Il expansion area.
See Confidential Exhibit No.3-13,provided previously,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 facility located in the western U.S.
where observed bird collision mortality has 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 confirmed the presence of one active bald
eagle nest along Rock Creek and northwest of the project area.
Wildlife impact studies are on-going and PacifiCorp will utilize recommendations from
existing U.S.Fish and Wildlife and Wyoming Game and Fish Department guidance documents to
implement appropriate avoidance,minimization,and mitigation practices.
Surveys for greater sage-grouse were conducted concurrently with avian baseline surveys
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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
mature sagebrush,and therefore,suitable cover for greater sage-grousethrough most of the project
area.Due to the low occurrence date and low flight path,greater sage-group mortality due to
collisions with WTG 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 in previously provided Confidential
Exhibit No.3-14;and the avian baseline use report is presented in previously provided
Confidential Exhibit No.3-15.O PacifiCorp is continuing to collect bat use 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.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.
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During construction,each on-site contractor will be expected to develop,publish and
orchestrate a site and project specific environmentalprotection plan.
Site specific wildlife management plans will be developed and implemented.
(M)A description of any potential safety hazards:
Prevention of safety hazards and impacts from failure of the project's components will 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 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
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 to 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 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
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could lead to failure.In addition,certification ofthe WTGs to the requirements ofthe International
Electrotechnical Commission ('TEC")61400-1 standard 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 infrequent 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 WTG will be grouped in strings,and some of the WTG 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.
(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
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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
provided at the shared existing facilities.
(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 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
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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 activity could 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 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.
(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'stability and
reliability:
This 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 High Plains
proxy large generator interconnection "Facilities Study Report"and McFadden Ridge II status
application was provided previously as Confidential Exhibit No.3-16 that summarizes the
expected impact.
A large generator interconnection agreement was submitted by RMP on May 18,2017
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(referencing queue position Q0863).PacifiCorp Transmission reportedlybegan its study sequence
in October 2017,and is anticipated to deliver a "System Impact Study"in February 2018.A
backfeed source is anticipated to be available to the project in June 2020 to accommodate
commissioning and testing of up to two WTGs at a time.
(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 of the project is listed,along with their timing and status,in previously
provided 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,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 and Albany County
Planning 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 followingdocument included in Exhibit No.33 is confidential in its entirety:
Confidential McFadden Ridge 11 Updated WTG Site Layout
Exhibit No.33-1
The confidential exhibits listed above are provided on CD.
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