20180216Vail 2nd Supp Direct - Redacted.pdf

Idaho Public Utilities CommissionOfficeoftheSecretaryRECElVED
FEB 1 6 2018OBoise,idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NO.PAC-E-17-07
OF ROCKY MOUNTAIN POWER FOR A )CERTIFICATE OF PUBLIC )SECOND SUPPLEMENTAL DIRECT
CONVENIENCE AND NECESSITY AND )TESTIMONY OF RICK A.VAIL
BINDING RATEMAKING TREATMENT )REDACTED
FOR NEW WIND AND TRANSMISSION )FACILITIES )
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ROCKY MOUNTAIN POWER
CASE NO.PAC-E-17-07
February2018
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l Q.Are you the same Rick A.Vail who previously provided testimony in this case on
2 behalf of PacifiCorp dba Rocky Mountain Power (the "Company")?
3 A.Yes.
4 PURPOSE AND SUMMARY OF SECOND SUPPLEMENTAL DIRECT TESTIMONY
5 Q.What is the purpose of your second supplemental direct testimony in this
6 proceeding?
7 A.My testimony provides an update on the network upgrade costs associated with the TB
8 Flats I and II,Cedar Springs,and Uinta projects,which are three of the four new wind
9 resources ("Wind Projects")included on the updated final shortlist of the 2017R
10 Request for Proposals ("RFP").My testimony also contains the information required
11 under the voluntary request for approval of a resource decision to construct the Aeolus-
12 to-Bridger/Anticline line and network upgrades ("Transmission Projects").O 13 Q.Please summarize your testimony.
14 A.Since filing supplemental direct testimony on January 16,2018,the Company's
15 transmission function finalized a broader open access transmission tariff ("OATT")
16 restudy process,which included producing system impact restudy ("SISs")reports for
17 the followingthree Wind Projects:TB Flats I and II,Cedar Springs,and Uinta.Based
18 on the completed SISs,the network upgrade costs have increased to .In
19 addition,the Company's updated studies indicate that with the construction of the
20 Aeolus-to-Bridger/Anticline transmission line,the Company can interconnect 1,510
21 MW of new wind capacity behind the transmission constraint in southeastern
22 Wyoming.Thus,the Company has confirmed that there is sufficient stiffness factor
23 and transfer capability to interconnect the three Wind Projects located in southeast
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l Wyoming (i.e.,TB Flats I and II,Cedar Springs,and Ekola Flats),as well as the fourth
2 Wind Project located in western Wyoming (i.e.,Uinta).
3 UPDATE ON NETWORK UPGRADE COSTS
4 Q.Why has the Company updated the network upgrade costs associated with the
5 Wind Projects?
6 A.The Company's transmission function updated the interconnection network upgrade
7 costs associated with three of the four Wind Projects as part of a broader OATT restudy
8 process.More specifically,after the Company announced its plan to construct the
9 Energy Gateway Aeolus-to-Bridger/Anticline D.2 segment to come online by 2020,the
10 Company's transmission function initiatedan interconnection restudy processto ensure
11 its interconnection studies reflected the most current long-term transmission plan
12 assumptions.In accordance with its OATT,the Company's transmission function
13 performed restudies in serial queue order to determine whether the acceleration of
14 Energy Gateway segment D.2 would impact the cost or timing of interconnection of
15 projects that had not yet executed interconnection agreements and that had previous
16 studies depending on Energy Gateway West in its entirety.The Company's
17 transmission function posted the SIS reports to OASIS on January 29,2018,as well as
18 certain updated reports on February 9,2018,after the Company filed its January 16,
19 2018,supplemental direct testimony.Three of the four Wind Projects (TB Flats I and
20 II,Cedar Springs,and Uinta)were among the interconnection projects to receive
21 restudies.
22 Q.Did the Company restudy the McFadden Ridge H project's interconnection?
23 A.No.Because of its position in the queue,the McFadden Ridge II project had not yet
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l received even an initial SIS;therefore,it was not included in the projects that were
2 restudied.McFadden Ridge II's queue position and location in the constrained area of
3 PacifiCorp's transmission system in eastern Wyoming indicate that its future SIS will
4 require the construction of additional Energy Gateway segments beyond just the D.2
5 segment to allow the project to interconnect,which Mr.Link explains contributed to its
6 removal from the final shortlist.
7 Q.How does McFadden Ridge II's queue position and location indicate its future SIS
8 will require construction of additional Energy Gateway segments?
9 A.PacifiCorp transmission can never guarantee the result of a future SIS because of the
10 many factors that can affect it (e.g.,changes to the queue,as I discussed above).Here,
11 however,there is a specific point in the interconnection queue where projects located
12 in the constrained area of PacifiCorp's eastern Wyoming transmission system will
13 require more than just the D.2 segment to interconnect,and that point in the queue is
14 before McFadden Ridge II's queue position.More specifically,the restudy reports
15 incorporatingthe updated assumption regarding the staging of Energy Gateway West
16 showed that interconnection projects located in eastern Wyoming with an
17 interconnection-queue position greater than Q0712 trigger the need for Energy
18 Gateway South,which is not planned to be placed in service by the end of 2020.All
19 other bids originally selected to the final shortlist can secure interconnection either
20 because they hold an interconnection queue position that does not require Energy
21 Gateway South (Ekola Flats,TB Flats I and II,and Cedar Springs);or because their
22 project location is not in the constrained area of the Company's eastern Wyoming
23 transmission system (Uinta).
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1 Q.Why can Uinta interconnect with just the D.2 segment even though it has an
2 interconnection-queue position higher than Q0712?
3 A.Uinta is located in western Wyoming where it (and other projects in the same area)can
4 secure interconnection without triggering additionalEnergy Gateway segments.
5 Q.Why did the Company not restudy the interconnection for the Ekola Flats
6 project?
7 A.Ekola Flats executed a Large Generator Interconnection Agreement ("LGIA")in
8 November 2017 and therefore did not require restudy.
9 Q.Why didn't the Company complete these interconnection studies earlier so they
10 could be analyzed earlier in the 2017R RFP process?
11 A.The Company's transmission function did not perform the restudies in conjunction with
12 the 2017R RFP process.Rather,as noted above,the Company's transmission function
13 followed its OATT process to perform a broader restudy of the interconnection queue
14 to assess whether and to what extent the cost or timing of certain interconnection
15 projects was impacted by the Company's change to its long-term transmission plan,
16 i.e.,the staging of the Energy Gateway West project.
17 In addition,and as discussed by Mr.Link,at the request of the Utah independent
18 evaluator,the 2017R RFP did not require that bidders have a completed SIS when bids
19 were submitted.This allowed bidders to participate in the 2017R RFP regardless of
20 their position in the interconnection queue--a queue that can change over time as
21 generator-interconnection customers change project details,request commercial
22 operation date extensions or suspension,or withdraw from the queue altogether.As a
23 result,while the restudies were performed independent of the 2017R RFP process,
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1 performing restudies to reflect an updated long-term transmission plan assumption
2 close-in-time to the selection of the final shortlist allowed the Company's transmission
3 function to incorporate the most current queue-based assumptions into restudies as
4 well.
5 Q.Based on the SISs,what are the updated costs for the network upgrades?
6 A.Confidential Table 1 summarizes the updated costs for the network upgrades:
7 CONFIDENTIAL TABLE 1
230kV &138kV Network Upgrades
ITEM VALUE
Transmission Line
Substation
Engineering
Right of Way Acquisition
PM/Environmental/Support
IndirectsOTOTAL
8 In addition,Exhibit No.48 provides greater detail on the network upgrades required
9 for each of the Wind Projects and the SIS for each Wind Project is included in Exhibit
10 Nos.49 through 52.
11 Q.How do the updated network upgrade costs compare to the estimate included in
12 your supplemental direct testimony of January 16,2018?
13 A.Network upgrade costs have increased by approximately .
14 This increase is due primarily to the fact that the completed SISs indicate additional
15 facilities are required to interconnect some of the Wind Projects.
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l Q.How have the network upgrades changed since those identified in your
2 supplemental direct testimony of January 16,2018?
3 A.The Cedar Springs project no longer requires the rebuild of a 56-mile portion of the
4 Dave Johnston-Amasa-Difficulty-Shirley Basin 230-kV line.The rebuild can be
5 deferred because another interconnection project (Q0409)will not be online by 2020.
6 The Cedar Springs project will require a rebuild of the Standpipe-Freezeout-Aeolus
7 230 kV line with a larger conductor,approximately 15 miles,and a rebuild of the
8 existing Aeolus-ShirleyBasin #1 line,approximately 16 miles.Both of these upgrades
9 were identified as network upgrades in previous testimony.
10 In addition,the Uinta project no longer requires the reconductoring of
11 approximately 13.7 miles of the Q0715-Railroad 138-kV line becausethe most recent
12 line ratings,which are continually upgraded as new information is available,does not
13 indicate exceedance of the emergency rating on the line.The Uinta project will,
14 however,need to eliminate the credible N-2 outage of the Ben Lomond-Birch Creek
15 and Ben Lomond-Naughton230 kV transmission lines,which share common structures
16 for approximatelyeight miles as they exit Ben Lomond substation.This will require
17 the construction of a 230 kV single circuit transmission line beginning approximately
18 one mile outside of Ben Lomond substation and continuingto structure 525 for the Ben
19 Lomond-Naughton#1 line.This line segment will replace the current Ben Lomond-
20 Naughton #1 circuit,which resides on the north side of the 7-mile-long lattice tower
21 double circuit with the Ben Lomond-Birch Creek 230 kV transmission line.The
22 facilities identified for TB Flats I and 11 remain the same.
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1 Q.Has the Company performed any additional technical studies since the filing of
2 supplemental direct testimony on January16,2018?
3 A.Yes.The Company's updated studies indicate that it can interconnect 1,510 MW of
4 incremental wind generation behind the TOT4A/TOT4B constraint.With the addition
5 of the Ekola Flats project to the final shortlist,the Wind Projects will utilize 1,150 MW
6 of the incremental capacity,which will leave 360 MW for other projects,including a
7 240 MW qualifying facility ("QF")that has an executed interconnection agreement that
8 does not require the construction of Energy Gateway West and South to accommodate
9 the QF's interconnection.
10 Q.In your supplemental direct testimony,you testified that the Company was in the
11 process of testing a new tower design for the Transmission Projects (Vail Rebuttal,
12 page 2 lines 16-23 and page 3 lines 1-23.Is that process ongoing?
13 A.Yes,although the results of that testing will not impact the decision on the tower design.
14 As described in my rebuttal testimony,the Company will use the new tower.The tower
15 testing will verifythe tower design and will not impact the cost of the project.
16 Q.Have you provided additional information that describes the proposed resource
17 decision?
18 A.Yes.My supplemental direct and second supplemental direct testimony provide an
19 updated description of the network upgrades required to interconnect the Wind
20 Projects.Exhibit Nos.36,37 and 48 through 52 provide additional descriptions of the
21 network upgrade facilities.Because the Aeolus-to-Bridger/Anticline transmission line
22 has remained the same throughout this proceeding,the information included in my
23 direct testimony fully describes that component of the Transmission Projects.
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l Examples of pro-forma contracts are attached as Exhibit No.53.The Company has not
2 executed the final contracts for the Transmission Projects.
3 Q.Does this conclude your second supplemental direct testimony?
4 A.Yes.
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