Rocky Mountain Power's Petition To The Wyoming Public Service Commission

1407 West North Temple, Suite 310
Salt Lake City, UT 84116
May 31, 2017
VIA ELECTRONIC FILING

AND OVERNIGHT DELIVERY
Wyoming Public Service Commission

2515 Warren Avenue, Suite 300
Cheyenne, Wyoming 82002
Attn: Chris Petrie, Chief Counsel Docket No. 20000-___-EA-17

Record No._____
RE: IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER

FOR APPROVAL OF SCHEDULE 37 STANDARD RATES FOR PURCHASES OF
POWER FROM QUALIFYING FACILITIES
Dear Mr. Petrie:
Enclosed for filing are an original and four (4) copies of Rocky Mountain Powers (Company)
Application requesting approval of standard rates for purchases of power from qualifying
facilities with a design capacity within the limits designated in Tariff Schedule 37.
The Company has also provided this Application to the Wyoming Public Service Commission
(Commission) pursuant to its electronic filing requirements and has also enclosed a check in
the amount of $5.00 for the Commissions filing fee.
All formal correspondence and Staff requests regarding this matter should be addressed to:
By E-mail (preferred): datarequest@pacificorp.com
By regular mail: Data Request Response Center

PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
with copies to: Stacy Splittstoesser

Wyoming Regulatory Affairs Manager
Rocky Mountain Power
1807 Capitol Ave., Suite 200A
E-mail: stacy.splittstoesser@pacificorp.com
Wyoming Public Service Commission
May 31, 2017
Page 2
Yvonne R. Hogle
Assistant General Counsel
Salt Lake City, Utah 84116
E-mail: yvonne.hogle@pacificorp.com
Daniel E. Solander
Senior Attorney
E-mail: daniel.solander@pacificorp.com
Informal inquiries related to this filing may be directed to Stacy Splittstoesser, Wyoming
Regulatory Affairs Manager, at (307) 632-2677.
Sincerely,
Jeffrey K. Larsen
Vice President, Regulation
Enclosures
Yvonne R. Hogle
Daniel E. Solander
1407 W. North Temple, Suite 320
Telephone No.: (801) 220-4014
Facsimile No.: (801) 220-3299
daniel.solander@pacificorp.com
Attorneys for Rocky Mountain Power
BEFORE THE WYOMING PUBLIC SERVICE COMMISSION
IN THE MATTER OF THE APPLICATION )

OF ROCKY MOUNTAIN POWER FOR )
APPROVAL OF SCHEDULE 37 ) Docket No. 20000-______-EA-17
STANDARD RATES FOR PURCHASES OF )
POWER FROM QUALIFYING FACILITIES ) Record No. _______
APPLICATION FOR APPROVAL OF SCHEDULE 37
Comes now Rocky Mountain Power (RMP or Company), a division of
PacifiCorp, with an original and four copies of the following Application for Approval of
Schedule 37 (Application) including supporting testimony, exhibits, and proposed
revisions to tariff Schedule 37, Standard Rates for Purchases of Power from Qualifying
Facilities applicable in the state of Wyoming. Rocky Mountain Power respectfully requests
that the Public Service Commission of Wyoming (Commission) approve the standard
rates included in this Application for the purchase of power from qualifying cogeneration
and small power production facilities that qualify under the terms and conditions of
Schedule 37.
In support of this Application, Rocky Mountain Power represents as follows:
1
1. PacifiCorp is an Oregon corporation that provides electric service to retail
customers through its Rocky Mountain Power division in the states of Wyoming, Utah, and
Idaho, and through its Pacific Power division in the states of Oregon, California, and
Washington.
2. Rocky Mountain Power is a public utility in the state of Wyoming subject
to the Commissions jurisdiction with respect to its prices and terms of electric service to
retail customers in Wyoming. Rocky Mountain Powers principal place of business in
Wyoming is 2840 East Yellowstone Highway, Casper, Wyoming 82602.
3. Communications regarding this application should be addressed to:
Stacy Splittstoesser
Wyoming Regulatory Affairs Manager
1807 Capitol Ave, Suite 200A
Telephone No.: (307) 632-2677
E-mail: stacy.splittstoesser@pacificorp.com
Yvonne R. Hogle
Assistant General Counsel
Telephone No.: (801) 220-4050
Daniel E. Solander
Senior Attorney
Telephone No.: (801) 220-4014
In addition, Rocky Mountain Power requests that all data requests regarding this
application be sent in Microsoft Word or plain text format addressed to:
2
By e-mail (preferred): datarequest@pacificorp.com
or by regular mail to: Data Request Response Center

PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
Informal questions may be directed to Stacy Splittstoesser at (307) 632-2677.
4. This Application is filed pursuant to Chapter 3, Section 35 of the
Commissions Rules, which sets forth the Commissions regulations regarding
arrangements between electric utilities and qualifying cogeneration and small power
production facilities (Qualifying Facilities) pursuant to Sections 201 and 210 of the Public
Utility Regulatory Policies Act of 1978 (PURPA), 16 USC 796 and 824a-3. Chapter 3,
Section 35 (f) of the Commissions Rules requires each electric utility in Wyoming to
prepare and file standard rates for purchases from Qualifying Facilities having a design
capacity greater than 100 kilowatts. Chapter 3, Section 35 (c)(i) of the Commissions Rules
requires system data from which avoided costs may be derived to be filed not less often
than every two years.
5. The Avoided Cost Study prepared in support of this Application results in
a proposed avoided cost price of $31.48/MWh on a 20-year (2018-2037) nominal levelized
basis for a base load QF, which is a reduction of $20.67/MWH from rates currently in effect
which were last approved in a written order issued by the Commission on August 26, 2015.
The proposed avoided cost prices are $25.64/MWh, $29.65/MWh, and $31.51/MWh on a
20-year (2018-2037) nominal levelized basis for a wind, fixed solar, and tracking solar
QFs, respectively. The lower avoided cost reflected in this Application is primarily due to
3
the March 31, 2017 Official Forward Price Curve that includes lower wholesale power and
natural gas market prices.
6. In addition to the updated Official Forward Price Curve, the Company used
the wind and solar integration costs, the capacity contributions for both wind and solar
resources, and the resource sufficiency and deficiency periods that relate to capacity
contribution costs consistent with the 2017 Integrated Resource Plan that was submitted on
April 4, 2017, for the preparation of the Avoided Cost Study and the updated Schedule 37.
7. Exhibit 1, Avoided Cost Study Tables 1-10, attached to this Application, is
a detailed set of calculations and work papers showing the avoided cost calculations.
8. Exhibit 2, Standard Rates for Avoided Cost Purchases from Qualifying
Facilities That Qualify for Schedule 37, attached to this Application, is a detailed
description of the methods and assumptions used to produce the Avoided Cost Study.
9. Exhibit 3 includes first revised tariff sheets number 37-1, 37-2, 37-3, 37-4,
37-5, 37-6, and 37-7, which reflect the updated the avoided cost calculations.
10. Exhibit 4 is the direct testimony of Daniel J. MacNeil, Resource and
Commercial Strategy Adviser, which describes in greater detail the updates made to the
avoided cost calculations.
11. Exhibit 5 is the petition for confidential treatment and protective order for
the confidential workpapers that are included in the enclosed data disc.
WHEREFORE, Rocky Mountain Power requests Commission approval of the
standard rates for purchase of power from qualifying cogeneration and small power
production facilities that qualify under the terms and conditions of Schedule 37, as
contained in the Exhibits attached to this Application, subject to the tariff provision that
4
the standard rates are applicable until 10 megawatts of system-wide resource capacity is
acquired.
DATED this 31st day of May 2017.
Respectfully submitted,
__________________________
Daniel E. Solander
Senior Attorney
Telephone No.: (801) 220-4014
5
Exhibit 1
ROCKY MOUNTAIN POWER
AVOIDED COST STUDY TABLES 1-10
WYOMING May 2017

Table 1
2017 IRP Preferred Portfolio
Excerpt from 2017 IRP Table 8.17
Capacity (MW) Resource Totals 1/

Resource 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 10-year 20-year
East Expansion Resources
CCCT - DJohns - J 1x1 - - - - - - - - - - - - - - - - 477 - - - - 477
Total CCCT - - - - - - - - - - - - - - - - 477 - - - - 477
SCCT Frame DJ - - - - - - - - - - - - - - - - 200 - - - - 200
SCCT Frame UTN - - - - - - - - - - - - 200 - - - - - - - - 200
Wind, Djohnston - - - - - - - - - - - - - - 85 - - - - - - 85
Wind, GO - - - - - - - - - - - - - - - - - - - 774 - 774
Wind, WYAE - - - - 1,100 - - - - - - - - - - - - - - - 1,100 1,100
Total Wind - - - - 1,100 - - - - - - - - - 85 - - - - 774 1,100 1,959
Utility Solar - PV - Utah-S - - - - - - - - - - - - - - 79 167 210 41 291 13 - 800
DSM, Class 1 Total - - - - - - - - - - - 123.8 90.5 4.8 - 3.4 3.1 3.7 3.1 11.6 - 243.8
DSM, Class 2 Total 97 74 79 75 81 77 85 85 82 84 82 77 73 73 74 62 55 47 44 44 819 1,450
FOT Mona - SMR - - - - - - - - - 27 27 300 300 291 300 300 300 300 300 300 3 137
West Expansion Resources
CCCT - WillamValcc - G 1x1 - - - - - - - - - - - - - 436 - - - - - - - 436
Total CCCT - - - - - - - - - - - - - 436 - - - - - - - 436
Utility Solar - PV - Yakima - - - - - - - - - - - 11 97 - 38 70 16 8 - - - 240
DSM, Class 1 Total - - - - - - - - - - - 69.1 49.1 - 3.3 - - - - - - 121.5
DSM, Class 2 Total 57 53 52 46 42 37 33 33 29 27 27 25 23 23 22 21 20 19 19 18 410 627
Geothermal, Greenfield - West - - - - - - - - - - - - 30 - - - - - - - - 30
FOT COB - SMR - - 3 - - 41 - 10 167 76 137 400 400 400 400 400 400 400 400 364 30 200
FOT MidColumbia - SMR 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400
FOT MidColumbia - SMR - 2 - 21 375 307 299 375 344 375 375 375 375 375 375 375 375 375 375 375 375 375 285 330
FOT NOB - SMR 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100
FOT MidColumbia - WTR 281 332 273 307 - 308 - 287 295 - - - 400 41 390 351 - 377 4 291 208 197
FOT MidColumbia - WTR2 - - - - 319 - 306 - - 297 289 312 51 375 - - 337 - 375 375 92 152
FOT NOB - WTR - - - - - - - - 53 54 8 100 100 100 100 100 100 100 100 100 11 51
Existing Plant Retirements/Conversions - - (257) - (387) - - - - (82) - (762) (354) (357) (78) - (717) - (82) -
Annual Additions, Long Term Resources 154 128 131 122 1,223 114 118 118 112 111 109 306 563 536 303 323 980 117 356 861
Annual Additions, Short Term Resources 781 853 1,151 1,115 1,118 1,223 1,150 1,172 1,390 1,329 1,336 1,987 2,126 2,081 2,065 2,026 2,012 2,052 2,054 2,305
Total Annual Additions 935 981 1,282 1,236 2,341 1,337 1,268 1,289 1,501 1,440 1,445 2,293 2,688 2,618 2,368 2,349 2,992 2,169 2,411 3,166
The 2017 IRP was prepared using a 13% planning reserve margin. See 2017 IRP, page 10.
Page 1 of 26
Exhibit 1
NPC Group - WY Sch 37 2017 - Exhibit 1 - AC Study _2017 05 26.xlsx ( Table 1 ) 5/30/2017 4:04 PM
Table 2A
Avoided Costs for Base Load QF
Avoided Energy - $/MWH
Year Winter Season Summer Season Winter Season

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
GRID Production Cost Model Study

2017 $15.13 $18.48 $19.13 $13.58 $14.19 $9.94 $14.27
2018 $10.11 $13.91 $14.87 $15.01 $13.54 $14.97 $18.87 $19.74 $16.32 $13.39 $9.98 $10.99
2019 $10.49 $12.71 $13.41 $14.33 $12.68 $15.13 $19.38 $20.03 $17.19 $14.57 $9.97 $11.33
2020 $12.28 $13.67 $15.67 $15.08 $14.90 $14.98 $20.23 $20.34 $16.77 $16.40 $12.97 $16.85
2021 $2.92 $9.07 $11.00 $13.14 $14.26 $14.60 $20.21 $20.14 $16.60 $13.91 $7.64 $6.53
2022 $6.89 $11.15 $13.58 $14.80 $15.49 $15.87 $22.40 $22.35 $18.29 $15.84 $9.55 $5.72
2023 $8.20 $11.66 $13.68 $15.39 $17.73 $17.59 $24.12 $23.11 $20.20 $17.87 $10.68 $9.12
2024 $7.66 $10.68 $15.79 $16.80 $22.83 $19.60 $25.81 $24.28 $25.30 $18.61 $11.10 $9.58
2025 $8.78 $12.67 $16.84 $18.33 $21.69 $20.65 $26.40 $27.83 $23.99 $19.20 $9.26 $9.67
2026 $10.06 $25.83 $17.95 $19.54 $22.14 $20.90 $27.67 $29.53 $25.10 $21.09 $12.53 $8.93
2027 $11.05 $16.56 $19.68 $21.93 $23.72 $23.11 $30.19 $30.90 $24.71 $22.33 $14.20 $9.64
2028 $30.11 $31.66 $30.66 $28.20 $29.61 $28.79 $38.03 $42.13 $33.96 $33.81 $31.13 $30.36
Annual Seasonal Average

Year Winter Season Summer Season Annual Average
2017 $12.14 $13.41 $12.14

2018 $12.45 $16.15 $14.32
2019 $12.03 $16.50 $14.28
2020 $14.43 $17.28 $15.86
2021 $8.35 $16.63 $12.53
2022 $10.25 $18.39 $14.35
2023 $11.44 $20.11 $15.81
2024 $11.93 $22.74 $17.36
2025 $12.58 $23.30 $17.98
2026 $15.64 $24.42 $20.07
2027 $15.46 $25.85 $20.70
2028 $30.35 $34.42 $32.39
Source: GRID Production Cost Computer Model Study

Page 2 of 26
Exhibit 1
WY Sch 37 2017 - Exhibit 1 - AC Study _2017 05 26.xlsx

Table 2A

GRID Production Cost Model Study_OnPeak (1)

2017 $17.26 $21.77 $21.91 $14.60 $14.80 $10.46 $14.79
2018 $10.54 $14.25 $15.61 $16.01 $15.03 $16.57 $22.21 $22.45 $18.18 $13.92 $10.47 $11.38
2019 $10.72 $13.15 $13.76 $16.30 $16.31 $19.73 $21.86 $22.22 $19.74 $15.23 $10.54 $11.80
2020 $12.88 $14.38 $16.39 $16.74 $18.56 $18.49 $23.88 $23.79 $20.11 $17.03 $13.65 $17.41
2021 $3.03 $9.42 $11.33 $14.47 $17.50 $17.79 $23.69 $23.41 $19.75 $14.34 $7.93 $6.69
2022 $7.18 $11.61 $14.04 $16.03 $18.53 $18.92 $25.95 $25.30 $21.27 $16.03 $9.74 $5.76
2023 $8.57 $12.19 $14.19 $15.67 $19.64 $19.57 $27.38 $25.85 $22.65 $18.48 $11.08 $9.37
2024 $7.99 $11.12 $16.27 $17.27 $23.80 $20.52 $28.63 $26.91 $27.59 $19.54 $11.67 $10.00
2025 $9.16 $13.16 $17.23 $19.03 $22.51 $21.82 $29.28 $31.10 $26.30 $20.18 $9.75 $10.13
2026 $10.52 $26.87 $18.34 $20.16 $23.09 $22.09 $30.66 $32.89 $27.38 $22.10 $13.20 $9.34
2027 $11.48 $17.18 $19.98 $22.67 $24.60 $24.31 $33.23 $34.32 $26.76 $23.43 $14.97 $10.01
2028 $31.25 $32.75 $31.20 $29.16 $30.68 $30.30 $41.92 $46.46 $36.40 $35.39 $32.71 $31.38
Annual Seasonal Average, OnPeak

2017 $12.66 $15.05 $12.66

2018 $13.02 $18.07 $15.57
2019 $12.70 $19.18 $15.96
2020 $15.25 $20.32 $17.80
2021 $8.78 $19.42 $14.14
2022 $10.69 $21.01 $15.89
2023 $11.82 $22.27 $17.09
2024 $12.38 $24.50 $18.47
2025 $13.06 $25.21 $19.19
2026 $16.23 $26.39 $21.35
2027 $16.00 $27.80 $21.95
2028 $31.40 $36.90 $34.16
(1): On-peak prices have been shaped by the relationship of Palo Verde On-peak market price to Palo Verde market price.
On-Peak Price = [GRID Production Cost Model Avoided Cost Price] x [Monthly On-Peak Palo Verde Market Price] / [Monthly Palo Verde Market Price]
Page 3 of 26
Exhibit 1

Table 2A

GRID Production Cost Model Study_OffPeak (2)

2017 $12.22 $14.64 $15.29 $12.30 $13.42 $9.29 $13.67
2018 $9.56 $13.45 $13.84 $13.76 $11.65 $12.77 $15.00 $15.99 $14.20 $12.67 $9.38 $10.55
2019 $10.20 $12.14 $12.97 $11.63 $8.08 $9.39 $16.23 $16.99 $14.28 $13.65 $9.26 $10.78
2020 $11.51 $12.72 $14.74 $12.81 $10.64 $10.17 $15.61 $15.97 $12.58 $15.51 $12.20 $16.13
2021 $2.80 $8.61 $10.54 $11.31 $10.50 $10.24 $15.79 $16.01 $12.66 $13.38 $7.27 $6.34
2022 $6.57 $10.53 $12.95 $13.11 $11.94 $11.70 $18.27 $18.27 $14.55 $15.59 $9.33 $5.67
2023 $7.78 $10.97 $12.97 $15.04 $15.31 $14.88 $20.32 $19.31 $17.13 $17.09 $10.18 $8.83
2024 $7.24 $10.09 $15.17 $16.15 $21.61 $18.44 $22.22 $20.64 $22.68 $17.34 $10.38 $9.10
2025 $8.30 $12.02 $16.35 $17.36 $20.65 $19.17 $22.75 $23.67 $21.09 $17.85 $8.70 $9.10
2026 $9.49 $24.44 $17.45 $18.69 $21.04 $19.26 $23.88 $25.25 $22.25 $19.70 $11.76 $8.42
2027 $10.55 $15.74 $19.26 $20.91 $22.69 $21.46 $26.32 $26.57 $22.15 $20.94 $13.23 $9.17
2028 $28.79 $30.18 $29.92 $27.00 $28.24 $26.73 $33.50 $36.13 $30.92 $31.81 $29.16 $29.16
Annual Seasonal Average, OffPeak

2017 $11.51 $11.30 $11.51

2018 $11.73 $13.71 $12.73
2019 $11.16 $13.12 $12.14
2020 $13.37 $13.44 $13.40
2021 $7.78 $13.11 $10.47
2022 $9.66 $15.07 $12.39
2023 $10.94 $17.36 $14.18
2024 $11.35 $20.49 $15.94
2025 $11.96 $20.87 $16.45
2026 $14.88 $21.91 $18.43
2027 $14.77 $23.37 $19.11
2028 $29.03 $31.25 $30.15
(2): Off-peak Prices have been shaped by the relationship of Palo Verde Off-peak market price to Palo Verde market price.
Off-Peak Price = [GRID Production Cost Model Avoided Cost Price] x [Monthly Off-Peak Palo Verde Market Price] / [Monthly Palo Verde Market Price]
Page 4 of 26
Exhibit 1

Table 2B
Avoided Costs for Wind QF
Avoided Energy reduced for Wind Integration Costs - $/MWH

GRID Production Cost Model Study (Average Energy Costs less Integration Costs)
2017 $14.54 $17.89 $18.54 $12.99 $13.60 $9.35 $13.68
2018 $9.51 $13.31 $14.27 $14.41 $12.94 $14.37 $18.27 $19.14 $15.72 $12.79 $9.38 $10.39
2019 $9.88 $12.10 $12.80 $13.72 $12.07 $14.52 $18.77 $19.42 $16.58 $13.96 $9.36 $10.72
2020 $11.66 $13.05 $15.05 $14.46 $14.28 $14.36 $19.61 $19.72 $16.15 $15.78 $12.35 $16.23
2021 $2.28 $8.43 $10.36 $12.50 $13.62 $13.96 $19.57 $19.50 $15.96 $13.27 $7.00 $5.89
2022 $6.24 $10.50 $12.93 $14.15 $14.84 $15.22 $21.75 $21.70 $17.64 $15.19 $8.90 $5.07
2023 $7.53 $10.99 $13.01 $14.72 $17.06 $16.92 $23.45 $22.44 $19.53 $17.20 $10.01 $8.45
2024 $6.98 $10.00 $15.11 $16.12 $22.15 $18.92 $25.13 $23.60 $24.62 $17.93 $10.42 $8.90
2025 $8.08 $11.97 $16.14 $17.63 $20.99 $19.95 $25.70 $27.13 $23.29 $18.50 $8.56 $8.97
2026 $9.35 $25.12 $17.24 $18.83 $21.43 $20.19 $26.96 $28.82 $24.39 $20.38 $11.82 $8.22
2027 $10.32 $15.83 $18.95 $21.20 $22.99 $22.38 $29.46 $30.17 $23.98 $21.60 $13.47 $8.91
2028 $29.36 $30.91 $29.91 $27.45 $28.86 $28.04 $37.28 $41.38 $33.21 $33.06 $30.38 $29.61

2017 $11.55 $12.92 $11.55

2018 $11.85 $15.55 $13.72
2019 $11.42 $15.89 $13.67
2020 $13.81 $16.66 $15.24
2021 $7.71 $15.99 $11.89
2022 $9.60 $17.74 $13.70
2023 $10.77 $19.44 $15.14
2024 $11.25 $22.06 $16.68
2025 $11.88 $22.60 $17.28
2026 $14.93 $23.71 $19.36
2027 $14.73 $25.12 $19.97
2028 $29.60 $33.67 $31.65
Source: GRID Production Cost Computer Model Study

Wind Integration Costs - See Table 10
Page 5 of 26
Exhibit 1
Table 2B


2017 $16.67 $21.18 $21.32 $14.01 $14.21 $9.87 $14.20
2018 $9.94 $13.65 $15.01 $15.41 $14.43 $15.97 $21.61 $21.85 $17.58 $13.32 $9.87 $10.78
2019 $10.11 $12.54 $13.15 $15.69 $15.70 $19.12 $21.25 $21.61 $19.13 $14.62 $9.93 $11.19
2020 $12.26 $13.76 $15.77 $16.12 $17.94 $17.87 $23.26 $23.17 $19.49 $16.41 $13.03 $16.79
2021 $2.39 $8.78 $10.69 $13.83 $16.86 $17.15 $23.05 $22.77 $19.11 $13.70 $7.29 $6.05
2022 $6.53 $10.96 $13.39 $15.38 $17.88 $18.27 $25.30 $24.65 $20.62 $15.38 $9.09 $5.11
2023 $7.90 $11.52 $13.52 $15.00 $18.97 $18.90 $26.71 $25.18 $21.98 $17.81 $10.41 $8.70
2024 $7.31 $10.44 $15.59 $16.59 $23.12 $19.84 $27.95 $26.23 $26.91 $18.86 $10.99 $9.32
2025 $8.46 $12.46 $16.53 $18.33 $21.81 $21.12 $28.58 $30.40 $25.60 $19.48 $9.05 $9.43
2026 $9.81 $26.16 $17.63 $19.45 $22.38 $21.38 $29.95 $32.18 $26.67 $21.39 $12.49 $8.63
2027 $10.75 $16.45 $19.25 $21.94 $23.87 $23.58 $32.50 $33.59 $26.03 $22.70 $14.24 $9.28
2028 $30.50 $32.00 $30.45 $28.41 $29.93 $29.55 $41.17 $45.71 $35.65 $34.64 $31.96 $30.63
Annual Seasonal Average, OnPeak (1)

2017 $12.07 $14.56 $12.07

2018 $12.42 $17.47 $14.97
2019 $12.09 $18.57 $15.35
2020 $14.63 $19.70 $17.18
2021 $8.14 $18.78 $13.50
2022 $10.04 $20.36 $15.24
2023 $11.15 $21.60 $16.42
2024 $11.70 $23.82 $17.79
2025 $12.36 $24.51 $18.49
2026 $15.52 $25.68 $20.64
2027 $15.27 $27.07 $21.22
2028 $30.65 $36.15 $33.41
Page 6 of 26
Exhibit 1
Table 2B


2017 $11.63 $14.05 $14.70 $11.71 $12.83 $8.70 $13.08
2018 $8.96 $12.85 $13.24 $13.16 $11.05 $12.17 $14.40 $15.39 $13.60 $12.07 $8.78 $9.95
2019 $9.59 $11.53 $12.36 $11.02 $7.47 $8.78 $15.62 $16.38 $13.67 $13.04 $8.65 $10.17
2020 $10.89 $12.10 $14.12 $12.19 $10.02 $9.55 $14.99 $15.35 $11.96 $14.89 $11.58 $15.51
2021 $2.16 $7.97 $9.90 $10.67 $9.86 $9.60 $15.15 $15.37 $12.02 $12.74 $6.63 $5.70
2022 $5.92 $9.88 $12.30 $12.46 $11.29 $11.05 $17.62 $17.62 $13.90 $14.94 $8.68 $5.02
2023 $7.11 $10.30 $12.30 $14.37 $14.64 $14.21 $19.65 $18.64 $16.46 $16.42 $9.51 $8.16
2024 $6.56 $9.41 $14.49 $15.47 $20.93 $17.76 $21.54 $19.96 $22.00 $16.66 $9.70 $8.42
2025 $7.60 $11.32 $15.65 $16.66 $19.95 $18.47 $22.05 $22.97 $20.39 $17.15 $8.00 $8.40
2026 $8.78 $23.73 $16.74 $17.98 $20.33 $18.55 $23.17 $24.54 $21.54 $18.99 $11.05 $7.71
2027 $9.82 $15.01 $18.53 $20.18 $21.96 $20.73 $25.59 $25.84 $21.42 $20.21 $12.50 $8.44
2028 $28.04 $29.43 $29.17 $26.25 $27.49 $25.98 $32.75 $35.38 $30.17 $31.06 $28.41 $28.41

2017 $10.92 $10.81 $10.92

2018 $11.13 $13.11 $12.13
2019 $10.55 $12.51 $11.53
2020 $12.75 $12.82 $12.78
2021 $7.14 $12.47 $9.83
2022 $9.01 $14.42 $11.74
2023 $10.27 $16.69 $13.51
2024 $10.67 $19.81 $15.26
2025 $11.26 $20.17 $15.75
2026 $14.17 $21.20 $17.72
2027 $14.04 $22.64 $18.38
2028 $28.28 $30.50 $29.40
Page 7 of 26
Exhibit 1
Table 2C
Avoided Costs for Fixed Solar QF
Avoided Energy reduced for Solar Integration Costs - $/MWH

2017 $14.52 $17.86 $18.52 $12.97 $13.58 $9.32 $13.66
2018 $9.48 $13.28 $14.24 $14.38 $12.91 $14.34 $18.25 $19.11 $15.69 $12.77 $9.35 $10.36
2019 $9.85 $12.07 $12.77 $13.69 $12.04 $14.49 $18.73 $19.39 $16.55 $13.93 $9.33 $10.69
2020 $11.62 $13.02 $15.01 $14.43 $14.24 $14.32 $19.58 $19.69 $16.11 $15.74 $12.31 $16.19
2021 $2.25 $8.40 $10.33 $12.47 $13.59 $13.93 $19.54 $19.47 $15.93 $13.24 $6.97 $5.86
2022 $6.21 $10.46 $12.90 $14.11 $14.80 $15.19 $21.71 $21.67 $17.60 $15.15 $8.87 $5.03
2023 $7.50 $10.96 $12.98 $14.69 $17.03 $16.89 $23.42 $22.41 $19.49 $17.17 $9.98 $8.42
2024 $6.94 $9.96 $15.07 $16.08 $22.11 $18.88 $25.09 $23.56 $24.58 $17.90 $10.38 $8.87
2025 $8.04 $11.94 $16.11 $17.59 $20.96 $19.91 $25.67 $27.09 $23.25 $18.47 $8.53 $8.94
2026 $9.31 $25.08 $17.20 $18.79 $21.39 $20.14 $26.92 $28.77 $24.35 $20.34 $11.78 $8.18
2027 $10.29 $15.79 $18.91 $21.16 $22.95 $22.34 $29.42 $30.14 $23.94 $21.56 $13.43 $8.87
2028 $29.33 $30.87 $29.88 $27.41 $28.82 $28.01 $37.24 $41.34 $33.18 $33.03 $30.34 $29.57

2017 $11.52 $12.90 $11.52

2018 $11.83 $15.52 $13.69
2019 $11.39 $15.86 $13.64
2020 $13.78 $16.63 $15.21
2021 $7.68 $15.96 $11.86
2022 $9.56 $17.70 $13.66
2023 $10.73 $19.41 $15.11
2024 $11.21 $22.02 $16.65
2025 $11.84 $22.57 $17.25
2026 $14.89 $23.67 $19.31
2027 $14.70 $25.08 $19.93
2028 $29.56 $33.63 $31.61
Source: GRID Production Cost Computer Model Study - Dated

Solar Integration Costs - See Table 10
Page 8 of 26
Exhibit 1
Table 2C


2017 $16.65 $21.16 $21.30 $13.99 $14.19 $9.85 $14.18
2018 $9.91 $13.62 $14.98 $15.38 $14.40 $15.94 $21.58 $21.82 $17.55 $13.29 $9.84 $10.75
2019 $10.08 $12.50 $13.12 $15.66 $15.67 $19.08 $21.22 $21.58 $19.10 $14.59 $9.90 $11.16
2020 $12.22 $13.72 $15.73 $16.09 $17.90 $17.83 $23.22 $23.13 $19.46 $16.38 $12.99 $16.75
2021 $2.36 $8.75 $10.66 $13.80 $16.83 $17.12 $23.02 $22.74 $19.08 $13.67 $7.26 $6.02
2022 $6.49 $10.93 $13.36 $15.34 $17.85 $18.24 $25.26 $24.61 $20.59 $15.34 $9.05 $5.08
2023 $7.87 $11.48 $13.49 $14.97 $18.94 $18.87 $26.68 $25.15 $21.95 $17.78 $10.38 $8.67
2024 $7.27 $10.40 $15.55 $16.56 $23.08 $19.81 $27.92 $26.19 $26.87 $18.82 $10.95 $9.28
2025 $8.42 $12.43 $16.50 $18.30 $21.78 $21.09 $28.54 $30.37 $25.57 $19.44 $9.02 $9.39
2026 $9.77 $26.12 $17.59 $19.40 $22.34 $21.34 $29.91 $32.14 $26.63 $21.35 $12.45 $8.59
2027 $10.72 $16.41 $19.21 $21.91 $23.83 $23.55 $32.46 $33.55 $25.99 $22.67 $14.20 $9.24
2028 $30.46 $31.97 $30.41 $28.37 $29.90 $29.52 $41.13 $45.67 $35.61 $34.61 $31.92 $30.60

2017 $12.05 $14.54 $12.05

2018 $12.39 $17.44 $14.94
2019 $12.05 $18.53 $15.32
2020 $14.60 $19.66 $17.15
2021 $8.11 $18.75 $13.46
2022 $10.00 $20.33 $15.21
2023 $11.12 $21.57 $16.39
2024 $11.67 $23.79 $17.78
2025 $12.33 $24.48 $18.44
2026 $15.48 $25.64 $20.60
2027 $15.23 $27.03 $21.18
2028 $30.61 $36.11 $33.38
Page 9 of 26
Exhibit 1
Table 2C


2017 $11.60 $14.03 $14.67 $11.69 $12.80 $8.67 $13.05
2018 $8.93 $12.82 $13.22 $13.13 $11.02 $12.14 $14.37 $15.36 $13.57 $12.04 $8.75 $9.92
2019 $9.56 $11.49 $12.33 $10.99 $7.43 $8.74 $15.58 $16.34 $13.64 $13.01 $8.62 $10.14
2020 $10.86 $12.06 $14.09 $12.15 $9.98 $9.52 $14.95 $15.32 $11.93 $14.86 $11.54 $15.47
2021 $2.13 $7.94 $9.87 $10.64 $9.83 $9.57 $15.12 $15.34 $11.99 $12.71 $6.60 $5.67
2022 $5.88 $9.84 $12.26 $12.42 $11.26 $11.01 $17.58 $17.59 $13.86 $14.91 $8.64 $4.98
2023 $7.08 $10.27 $12.27 $14.34 $14.61 $14.18 $19.62 $18.61 $16.43 $16.39 $9.48 $8.12
2024 $6.53 $9.37 $14.46 $15.43 $20.89 $17.72 $21.51 $19.92 $21.96 $16.62 $9.67 $8.38
2025 $7.56 $11.29 $15.61 $16.63 $19.91 $18.44 $22.02 $22.94 $20.36 $17.12 $7.96 $8.37
2026 $8.74 $23.69 $16.70 $17.94 $20.29 $18.50 $23.13 $24.50 $21.50 $18.95 $11.01 $7.67
2027 $9.78 $14.97 $18.49 $20.14 $21.92 $20.69 $25.55 $25.80 $21.38 $20.17 $12.46 $8.40
2028 $28.00 $29.40 $29.13 $26.21 $27.46 $25.94 $32.71 $35.34 $30.13 $31.03 $28.37 $28.38

2017 $10.90 $10.79 $10.90

2018 $11.10 $13.08 $12.10
2019 $10.51 $12.47 $11.50
2020 $12.72 $12.78 $12.75
2021 $7.12 $12.44 $9.79
2022 $8.98 $14.39 $11.70
2023 $10.24 $16.65 $13.47
2024 $10.64 $19.77 $15.24
2025 $11.22 $20.14 $15.71
2026 $14.13 $21.16 $17.68
2027 $14.00 $22.60 $18.34
2028 $28.24 $30.46 $29.36
Page 10 of 26
Exhibit 1
Table 2D
Avoided Costs for Tracking Solar QF

2017 $14.52 $17.86 $18.52 $12.97 $13.58 $9.32 $13.66
2018 $9.48 $13.28 $14.24 $14.38 $12.91 $14.34 $18.25 $19.11 $15.69 $12.77 $9.35 $10.36
2019 $9.85 $12.07 $12.77 $13.69 $12.04 $14.49 $18.73 $19.39 $16.55 $13.93 $9.33 $10.69
2020 $11.62 $13.02 $15.01 $14.43 $14.24 $14.32 $19.58 $19.69 $16.11 $15.74 $12.31 $16.19
2021 $2.25 $8.40 $10.33 $12.47 $13.59 $13.93 $19.54 $19.47 $15.93 $13.24 $6.97 $5.86
2022 $6.21 $10.46 $12.90 $14.11 $14.80 $15.19 $21.71 $21.67 $17.60 $15.15 $8.87 $5.03
2023 $7.50 $10.96 $12.98 $14.69 $17.03 $16.89 $23.42 $22.41 $19.49 $17.17 $9.98 $8.42
2024 $6.94 $9.96 $15.07 $16.08 $22.11 $18.88 $25.09 $23.56 $24.58 $17.90 $10.38 $8.87
2025 $8.04 $11.94 $16.11 $17.59 $20.96 $19.91 $25.67 $27.09 $23.25 $18.47 $8.53 $8.94
2026 $9.31 $25.08 $17.20 $18.79 $21.39 $20.14 $26.92 $28.77 $24.35 $20.34 $11.78 $8.18
2027 $10.29 $15.79 $18.91 $21.16 $22.95 $22.34 $29.42 $30.14 $23.94 $21.56 $13.43 $8.87
2028 $29.33 $30.87 $29.88 $27.41 $28.82 $28.01 $37.24 $41.34 $33.18 $33.03 $30.34 $29.57

2017 $11.52 $12.90 $11.52

2018 $11.83 $15.52 $13.69
2019 $11.39 $15.86 $13.64
2020 $13.78 $16.63 $15.21
2021 $7.68 $15.96 $11.86
2022 $9.56 $17.70 $13.66
2023 $10.73 $19.41 $15.11
2024 $11.21 $22.02 $16.65
2025 $11.84 $22.57 $17.25
2026 $14.89 $23.67 $19.31
2027 $14.70 $25.08 $19.93
2028 $29.56 $33.63 $31.61
Source: GRID Production Cost Computer Model Study - Dated

Solar Integration Costs - See Table 10
Page 11 of 26
Exhibit 1
Table 2D


2017 $16.65 $21.16 $21.30 $13.99 $14.19 $9.85 $14.18
2018 $9.91 $13.62 $14.98 $15.38 $14.40 $15.94 $21.58 $21.82 $17.55 $13.29 $9.84 $10.75
2019 $10.08 $12.50 $13.12 $15.66 $15.67 $19.08 $21.22 $21.58 $19.10 $14.59 $9.90 $11.16
2020 $12.22 $13.72 $15.73 $16.09 $17.90 $17.83 $23.22 $23.13 $19.46 $16.38 $12.99 $16.75
2021 $2.36 $8.75 $10.66 $13.80 $16.83 $17.12 $23.02 $22.74 $19.08 $13.67 $7.26 $6.02
2022 $6.49 $10.93 $13.36 $15.34 $17.85 $18.24 $25.26 $24.61 $20.59 $15.34 $9.05 $5.08
2023 $7.87 $11.48 $13.49 $14.97 $18.94 $18.87 $26.68 $25.15 $21.95 $17.78 $10.38 $8.67
2024 $7.27 $10.40 $15.55 $16.56 $23.08 $19.81 $27.92 $26.19 $26.87 $18.82 $10.95 $9.28
2025 $8.42 $12.43 $16.50 $18.30 $21.78 $21.09 $28.54 $30.37 $25.57 $19.44 $9.02 $9.39
2026 $9.77 $26.12 $17.59 $19.40 $22.34 $21.34 $29.91 $32.14 $26.63 $21.35 $12.45 $8.59
2027 $10.72 $16.41 $19.21 $21.91 $23.83 $23.55 $32.46 $33.55 $25.99 $22.67 $14.20 $9.24
2028 $30.46 $31.97 $30.41 $28.37 $29.90 $29.52 $41.13 $45.67 $35.61 $34.61 $31.92 $30.60

2017 $12.05 $14.54 $12.05

2018 $12.39 $17.44 $14.94
2019 $12.05 $18.53 $15.32
2020 $14.60 $19.66 $17.14
2021 $8.11 $18.75 $13.47
2022 $10.00 $20.33 $15.21
2023 $11.12 $21.57 $16.39
2024 $11.66 $23.79 $17.76
2025 $12.33 $24.48 $18.45
2026 $15.48 $25.64 $20.60
2027 $15.23 $27.03 $21.18
2028 $30.61 $36.11 $33.38
Page 12 of 26
Exhibit 1
Table 2D


2017 $11.60 $14.03 $14.67 $11.69 $12.80 $8.67 $13.05
2018 $8.93 $12.82 $13.22 $13.13 $11.02 $12.14 $14.37 $15.36 $13.57 $12.04 $8.75 $9.92
2019 $9.56 $11.49 $12.33 $10.99 $7.43 $8.74 $15.58 $16.34 $13.64 $13.01 $8.62 $10.14
2020 $10.86 $12.06 $14.09 $12.15 $9.98 $9.52 $14.95 $15.32 $11.93 $14.86 $11.54 $15.47
2021 $2.13 $7.94 $9.87 $10.64 $9.83 $9.57 $15.12 $15.34 $11.99 $12.71 $6.60 $5.67
2022 $5.88 $9.84 $12.26 $12.42 $11.26 $11.01 $17.58 $17.59 $13.86 $14.91 $8.64 $4.98
2023 $7.08 $10.27 $12.27 $14.34 $14.61 $14.18 $19.62 $18.61 $16.43 $16.39 $9.48 $8.12
2024 $6.53 $9.37 $14.46 $15.43 $20.89 $17.72 $21.51 $19.92 $21.96 $16.62 $9.67 $8.38
2025 $7.56 $11.29 $15.61 $16.63 $19.91 $18.44 $22.02 $22.94 $20.36 $17.12 $7.96 $8.37
2026 $8.74 $23.69 $16.70 $17.94 $20.29 $18.50 $23.13 $24.50 $21.50 $18.95 $11.01 $7.67
2027 $9.78 $14.97 $18.49 $20.14 $21.92 $20.69 $25.55 $25.80 $21.38 $20.17 $12.46 $8.40
2028 $28.00 $29.40 $29.13 $26.21 $27.46 $25.94 $32.71 $35.34 $30.13 $31.03 $28.37 $28.38

2017 $10.90 $10.79 $10.90

2018 $11.10 $13.08 $12.10
2019 $10.51 $12.47 $11.50
2020 $12.71 $12.78 $12.75
2021 $7.11 $12.44 $9.80
2022 $8.98 $14.39 $11.70
2023 $10.24 $16.65 $13.47
2024 $10.63 $19.77 $15.23
2025 $11.22 $20.14 $15.72
2026 $14.13 $21.16 $17.68
2027 $14.00 $22.60 $18.34
2028 $28.25 $30.46 $29.36
Page 13 of 26
Exhibit 1
Exhibit 1
Page 14 of 26
Table 3
Capitalized Energy Costs
Combined Simple Capitalized

Year Cycle CT Cycle CT Capitalized Energy Costs
Fixed Costs Fixed Costs Energy Costs 70.3% CF
($/kW-yr) ($/kW-yr) ($/kW-yr) ($/MWH)
(a) (b) (c) (d)
((a) - (b)) (c)/(8.760 x 70.3%)
Avoided Energy
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
CCCT Proxy Resource

2029 $207.03 $139.17 $67.86 $11.02
2030 $211.93 $142.49 $69.44 $11.28
2031 $217.05 $145.92 $71.13 $11.55
2032 $222.28 $149.41 $72.87 $11.83
2033 $227.66 $153.02 $74.64 $12.12
2034 $233.17 $156.73 $76.44 $12.41
2035 $238.79 $160.50 $78.29 $12.71
2036 $244.62 $164.40 $80.22 $13.03
2037 $250.59 $168.39 $82.20 $13.35
2038 $256.71 $172.51 $84.20 $13.67
2039 $262.98 $176.74 $86.24 $14.00
2040 $269.38 $181.05 $88.33 $14.34
Columns
(a) Table 8 Column (f) - Table 8 Page 2
(b) Table 8 Column (f) - Table 8 Page 1
(d) 70.3% CCCT Energy Weighted Capacity Factor - Table 8 Page 3
Exhibit 1
Page 15 of 26
Table 4
Total Avoided Energy Cost
Capitalized Total
Year Gas Fuel Costs Energy Cost Energy Costs Avoided
Delivered 70.3% CF Energy Cost
($/MMBtu) ($/MWH) ($/MWH) ($/MWH)
(a) (b) (c) (d)
(a) x 6.410 (b) + (c)
Avoided Energy
2017 $12.14
2018 $14.32
2019 $14.28
2020 $15.86
2021 $12.53
2022 $14.35
2023 $15.81
2024 $17.36
2025 $17.98
2026 $20.07
2027 $20.70
2028 $32.39
CCCT Proxy Resource

2029 $4.51 $28.91 $11.02 $39.93
2030 $4.88 $31.28 $11.28 $42.56
2031 $5.11 $32.76 $11.55 $44.31
2032 $5.38 $34.49 $11.83 $46.32
2033 $5.76 $36.92 $12.12 $49.04
2034 $6.02 $38.59 $12.41 $51.00
2035 $6.29 $40.32 $12.71 $53.03
2036 $6.80 $43.59 $13.03 $56.62
2037 $7.05 $45.19 $13.35 $58.54
2038 $7.46 $47.82 $13.67 $61.49
2039 $7.75 $49.68 $14.00 $63.68
2040 $8.03 $51.47 $14.34 $65.81
Columns
(a) Table 8 Page 2 Column (g)
(b) Table 8 Page 2 Column (g) Heat rate 6.410 MMBtu/MWh
(c) Table 3 Column (d)
(d) For 2017-2028 - Table 2A
Exhibit 1
Page 16 of 26
Table 5
Total Avoided Cost
Avoided Firm Total Total Avoided Costs

Year Capacity Avoided At Stated Capacity Factor
Costs Energy Cost 75% 85% 95%
($/kW-yr) ($/MWH) ($/MWH) ($/MWH) ($/MWH)
(a) (b) (c) (d) (e)
(b)+(a)/(8.76 x 0.75) (b)+((a)/(8.76 x 0.85) (b)+((a)/(8.76 x 0.95)
Avoided Energy
2017 $0.00 $12.14 $12.14 $12.14 $12.14
2018 $0.00 $14.32 $14.32 $14.32 $14.32
2019 $0.00 $14.28 $14.28 $14.28 $14.28
2020 $0.00 $15.86 $15.86 $15.86 $15.86
2021 $0.00 $12.53 $12.53 $12.53 $12.53
2022 $0.00 $14.35 $14.35 $14.35 $14.35
2023 $0.00 $15.81 $15.81 $15.81 $15.81
2024 $0.00 $17.36 $17.36 $17.36 $17.36
2025 $0.00 $17.98 $17.98 $17.98 $17.98
2026 $0.00 $20.07 $20.07 $20.07 $20.07
2027 $0.00 $20.70 $20.70 $20.70 $20.70
2028 $0.00 $32.39 $32.39 $32.39 $32.39
CCCT Proxy Resource

2029 $139.17 $39.93 $61.11 $58.62 $56.65
2030 $142.49 $42.56 $64.25 $61.70 $59.68
2031 $145.92 $44.31 $66.52 $63.91 $61.84
2032 $149.41 $46.32 $69.06 $66.39 $64.27
2033 $153.02 $49.04 $72.33 $69.59 $67.43
2034 $156.73 $51.00 $74.86 $72.05 $69.83
2035 $160.50 $53.03 $77.46 $74.59 $72.32
2036 $164.40 $56.62 $81.64 $78.70 $76.37
2037 $168.39 $58.54 $84.17 $81.15 $78.77
2038 $172.51 $61.49 $87.75 $84.66 $82.22
2039 $176.74 $63.68 $90.58 $87.42 $84.92
2040 $181.05 $65.81 $93.37 $90.13 $87.57
Columns
(a) Table 3 Column (b)
(b) Table 4 Column (d)
Exhibit 1
Page 17 of 26
Table 6A
Base Load - On- & Off Peak- Avoided Cost Prices
Base Load QF
Avoided Firm Capacity Cost Total On-Peak Off-Peak
Year Capacity Allocated to Avoided 4,993 Hours 3,767 Hours
Costs On-Peak Hours Energy Cost
($/kW-yr) ($/MWH) ($/MWH) ($/MWH) ($/MWH)
(a) (b) (c) (d) (e)
(a) /(8.76 x 100.0% x 57%)
Avoided Energy
2017 $0.00 $0.00 $12.14 $12.66 $11.51
2018 $0.00 $0.00 $14.32 $15.57 $12.73
2019 $0.00 $0.00 $14.28 $15.96 $12.14
2020 $0.00 $0.00 $15.86 $17.80 $13.40
2021 $0.00 $0.00 $12.53 $14.14 $10.47
2022 $0.00 $0.00 $14.35 $15.89 $12.39
2023 $0.00 $0.00 $15.81 $17.09 $14.18
2024 $0.00 $0.00 $17.36 $18.47 $15.94
2025 $0.00 $0.00 $17.98 $19.19 $16.45
2026 $0.00 $0.00 $20.07 $21.35 $18.43
2027 $0.00 $0.00 $20.70 $21.95 $19.11
2028 $0.00 $0.00 $32.39 $34.16 $30.15
CCCT Proxy Resource

2029 $139.17 $27.87 $39.93 $67.80 $39.93
2030 $142.49 $28.54 $42.56 $71.10 $42.56
2031 $145.92 $29.22 $44.31 $73.53 $44.31
2032 $149.41 $29.92 $46.32 $76.24 $46.32
2033 $153.02 $30.65 $49.04 $79.69 $49.04
2034 $156.73 $31.39 $51.00 $82.39 $51.00
2035 $160.50 $32.14 $53.03 $85.17 $53.03
2036 $164.40 $32.92 $56.62 $89.54 $56.62
2037 $168.39 $33.72 $58.54 $92.26 $58.54
2038 $172.51 $34.55 $61.49 $96.04 $61.49
2039 $176.74 $35.40 $63.68 $99.08 $63.68
2040 $181.05 $36.26 $65.81 $102.07 $65.81
Columns
(a) Table 3 Column (b)
(b) Table 8 100.0% is the on-peak capacity factor of the Proxy Resource
(c) Table 4 Column (d)
Exhibit 1
Page 18 of 26
Table 6B
Wind- On- & Off- Peak - Avoided Cost Prices
Wind QF
Capacity Cost Total Wind On-Peak Off-Peak
Year Allocated to Avoided Integration 4,993 Hours 3,767 Hours
On-Peak Hours Energy Cost Cost
($/MWH) ($/MWH) ($/MWH) ($/MWH) ($/MWH)
(a) (b) (c) (d) (e)
Table 6A (b) * 15.8% Table 6A (c)
Avoided Energy
2017 $0.00 $12.14 $0.59 $12.07 $10.92
2018 $0.00 $14.32 $0.60 $14.97 $12.13
2019 $0.00 $14.28 $0.61 $15.35 $11.53
2020 $0.00 $15.86 $0.62 $17.18 $12.78
2021 $0.00 $12.53 $0.64 $13.50 $9.83
2022 $0.00 $14.35 $0.65 $15.24 $11.74
2023 $0.00 $15.81 $0.67 $16.42 $13.51
2024 $0.00 $17.36 $0.68 $17.79 $15.26
2025 $0.00 $17.98 $0.70 $18.49 $15.75
2026 $0.00 $20.07 $0.71 $20.64 $17.72
2027 $0.00 $20.70 $0.73 $21.22 $18.38
2028 $0.00 $32.39 $0.75 $33.41 $29.40
CCCT Proxy Resource

2029 $4.40 $39.93 $0.77 $43.56 $39.16
2030 $4.51 $42.56 $0.78 $46.29 $41.78
2031 $4.62 $44.31 $0.80 $48.13 $43.51
2032 $4.73 $46.32 $0.82 $50.23 $45.50
2033 $4.84 $49.04 $0.84 $53.04 $48.20
2034 $4.96 $51.00 $0.86 $55.10 $50.14
2035 $5.08 $53.03 $0.88 $57.23 $52.15
2036 $5.20 $56.62 $0.90 $60.92 $55.72
2037 $5.33 $58.54 $0.93 $62.94 $57.61
2038 $5.46 $61.49 $0.95 $66.00 $60.54
2039 $5.59 $63.68 $0.97 $68.30 $62.71
2040 $5.73 $65.81 $1.00 $70.54 $64.81
Columns
(a) Table 6A Column (b) multiplied by Capacity Contribution of 15.8%
(b) Table 6A Column (c)
(c) Table 10 Column (c)
Capacity Contribution
Wind QF 15.8%
Source: 2017 IRP: Appendix N
Exhibit 1
Page 19 of 26
Table 6C
Solar (Fixed) - On- & Off- Peak - Avoided Cost Prices
Solar-Fixed QF
Capacity Cost Total Solar On-Peak Off-Peak
(a) (b) (c) (d) (e)
Table 6A (b) Table 6A (c)
Avoided Energy
2017 $0.00 $12.14 $0.62 $12.04 $10.89
2018 $0.00 $14.32 $0.63 $14.94 $12.10
2019 $0.00 $14.28 $0.64 $15.32 $11.50
2020 $0.00 $15.86 $0.66 $17.14 $12.74
2021 $0.00 $12.53 $0.67 $13.47 $9.80
2022 $0.00 $14.35 $0.69 $15.20 $11.70
2023 $0.00 $15.81 $0.70 $16.39 $13.48
2024 $0.00 $17.36 $0.72 $17.75 $15.22
2025 $0.00 $17.98 $0.73 $18.46 $15.72
2026 $0.00 $20.07 $0.75 $20.60 $17.68
2027 $0.00 $20.70 $0.77 $21.18 $18.34
2028 $0.00 $32.39 $0.79 $33.37 $29.36
CCCT Proxy Resource

2029 $10.57 $39.93 $0.80 $49.70 $39.13
2030 $10.82 $42.56 $0.82 $52.56 $41.74
2031 $11.08 $44.31 $0.84 $54.55 $43.47
2032 $11.34 $46.32 $0.86 $56.80 $45.46
2033 $11.62 $49.04 $0.88 $59.78 $48.16
2034 $11.90 $51.00 $0.91 $61.99 $50.09
2035 $12.19 $53.03 $0.93 $64.29 $52.10
2036 $12.48 $56.62 $0.95 $68.15 $55.67
2037 $12.78 $58.54 $0.97 $70.35 $57.57
2038 $13.10 $61.49 $1.00 $73.59 $60.49
2039 $13.42 $63.68 $1.02 $76.08 $62.66
2040 $13.75 $65.81 $1.05 $78.51 $64.76
Columns
Solar-Fixed QF 37.9%
Exhibit 1
Page 20 of 26
Table 6D
Solar (Tracking) - On- & Off- Peak - Avoided Cost Prices
Solar-Tracking QF
Capacity Cost Total Solar On-Peak Off-Peak
(a) (b) (c) (d) (e)
Table 6A (b) Table 6A (c)
Avoided Energy
2017 $0.00 $12.14 $0.62 $12.04 $10.89
2018 $0.00 $14.32 $0.63 $14.94 $12.10
2019 $0.00 $14.28 $0.64 $15.32 $11.50
2020 $0.00 $15.86 $0.66 $17.14 $12.74
2021 $0.00 $12.53 $0.67 $13.47 $9.80
2022 $0.00 $14.35 $0.69 $15.20 $11.70
2023 $0.00 $15.81 $0.70 $16.39 $13.48
2024 $0.00 $17.36 $0.72 $17.75 $15.22
2025 $0.00 $17.98 $0.73 $18.46 $15.72
2026 $0.00 $20.07 $0.75 $20.60 $17.68
2027 $0.00 $20.70 $0.77 $21.18 $18.34
2028 $0.00 $32.39 $0.79 $33.37 $29.36
CCCT Proxy Resource

2029 $16.63 $39.93 $0.80 $55.76 $39.13
2030 $17.03 $42.56 $0.82 $58.77 $41.74
2031 $17.44 $44.31 $0.84 $60.91 $43.47
2032 $17.85 $46.32 $0.86 $63.31 $45.46
2033 $18.29 $49.04 $0.88 $66.45 $48.16
2034 $18.73 $51.00 $0.91 $68.82 $50.09
2035 $19.18 $53.03 $0.93 $71.28 $52.10
2036 $19.64 $56.62 $0.95 $75.31 $55.67
2037 $20.12 $58.54 $0.97 $77.69 $57.57
2038 $20.62 $61.49 $1.00 $81.11 $60.49
2039 $21.12 $63.68 $1.02 $83.78 $62.66
2040 $21.64 $65.81 $1.05 $86.40 $64.76
Columns
Solar-Tracking QF 59.7%
Table 7
Comparison between Proposed and Current Avoided Costs
BASE LOAD WIND SOLAR FIXED SOLAR TRACKING
Year Proposed (1) Current Difference Proposed (1) Current Difference Proposed (1) Current Difference Proposed (1) Current Difference
Avoided Costs Avoided Costs Avoided Costs Avoided Costs Avoided Costs Avoided Costs Avoided Costs Avoided Costs
($/MWH) ($/MWH) ($/MWH) ($/MWH) ($/MWH) ($/MWH) ($/MWH) ($/MWH) ($/MWH) ($/MWH) ($/MWH) ($/MWH)
(a) (b) (c) (a) (b) (c) (a) (b) (c) (a) (b) (c)
(a) - (b) (a) - (b) (a) - (b) (a) - (b)
2017 $12.79 $27.64 ($14.86) $12.05 $24.08 ($12.03) $13.09 $29.41 ($16.32) $13.15 $29.50 ($16.35)
2018 $14.32 $30.93 ($16.61) $13.11 $27.16 ($14.05) $14.84 $33.10 ($18.26) $15.01 $33.22 ($18.21)
2019 $14.29 $32.30 ($18.01) $12.94 $28.35 ($15.41) $15.16 $34.53 ($19.37) $15.37 $34.68 ($19.31)
2020 $15.87 $34.15 ($18.28) $14.82 $30.28 ($15.46) $16.81 $36.26 ($19.45) $16.93 $36.38 ($19.45)
2021 $12.53 $37.88 ($25.35) $10.46 $34.06 ($23.60) $13.62 $39.31 ($25.70) $14.01 $39.42 ($25.42)
2022 $14.35 $42.18 ($27.83) $12.30 $38.52 ($26.22) $15.36 $42.96 ($27.60) $15.74 $43.02 ($27.28)
2023 $15.81 $43.21 ($27.40) $13.63 $38.99 ($25.36) $16.64 $44.25 ($27.61) $17.05 $44.44 ($27.39)
2024 $17.38 $43.50 ($26.12) $14.80 $38.11 ($23.32) $18.22 $45.13 ($26.92) $18.71 $45.61 ($26.90)
2025 $17.99 $52.01 ($34.03) $15.40 $48.54 ($33.13) $18.86 $53.32 ($34.46) $19.35 $53.29 ($33.94)
2026 $20.07 $53.73 ($33.67) $17.83 $49.38 ($31.55) $20.84 $55.41 ($34.57) $21.24 $55.59 ($34.35)
2027 $20.70 $63.09 ($42.39) $18.15 $43.99 ($25.83) $21.55 $53.51 ($31.96) $22.02 $54.73 ($32.71)
2028 $32.41 $65.11 ($32.71) $31.00 $45.64 ($14.63) $33.14 $55.35 ($22.20) $33.32 $56.59 ($23.28)
2029 $55.56 $67.39 ($11.83) $41.72 $47.55 ($5.83) $48.16 $57.44 ($9.27) $53.16 $58.71 ($5.55)
2030 $58.56 $69.68 ($11.12) $44.40 $49.46 ($5.06) $50.99 $59.54 ($8.55) $56.10 $60.84 ($4.73)
2031 $60.69 $71.00 ($10.30) $46.20 $50.39 ($4.20) $52.94 $60.65 ($7.71) $58.18 $61.98 ($3.80)
2032 $63.10 $72.32 ($9.22) $48.25 $51.32 ($3.07) $55.15 $61.78 ($6.63) $60.52 $63.13 ($2.61)
2033 $66.23 $73.74 ($7.52) $51.02 $52.32 ($1.31) $58.09 $63.00 ($4.90) $63.59 $64.37 ($0.78)
2034 $68.60 $75.15 ($6.55) $53.03 $53.32 ($0.29) $60.27 $64.19 ($3.92) $65.90 $65.59 $0.30
2035 $71.05 $76.66 ($5.61) $55.11 $54.39 $0.72 $62.53 $65.49 ($2.96) $68.28 $66.92 $1.37
2036 $75.08 $78.22 ($3.14) $58.75 $55.51 $3.23 $66.34 $66.84 ($0.50) $72.24 $68.29 $3.95
2037 $77.45 $79.74 ($2.30) $60.71 $56.58 $4.14 $68.50 $68.12 $0.37 $74.54 $69.61 $4.94
20 Year (2018 to 2037) Levelized Prices (Nominal) @ 6.570% Discount Rate Discount Rate - 2017 I
$/MWH $31.48 $52.15 ($20.67) $25.64 $41.51 ($15.86) $29.65 $49.03 ($19.38) $31.51 $49.65 ($18.13) 6.570%
Columns
(a) Table 5 Column (d)
(b) Avoided Costs approved by the Commission - August 2015
Note: Discount Rate - 2017 IRP Discount Rate
hours Generation Profile_Baseload Generation Profile_Wind* Generation Profile_Solar*

on-peak Summer (May- 2,480 28% 19% 49% 52%
on-peak Winter (Jan-A 2,432 28% 56% 39% 37% 33%
off-peak Summer 1,936 22% 13% 8% 10%
off-peak Winter 1,912 22% 44% 29% 6% 6%
15 Year (2018 to 2032) Levelized Prices (Nominal) @ 6.570% Discount Rate

$/MWH $24.69 $47.99 ($23.31) $20.56 $39.33 ($18.76) $23.99 $46.24 ($22.25) $25.19 $46.72 ($21.53)
Page 21 of 26
Exhibit 1
Exhibit 1
Page 22 of 26
Table8
TotalCostofDisplaceableResources
Page1of3
FixedCapital Total
Estimated CostatReal O&Mat Total
Capital Levelized Fixed Variable Expected Resource
Year Cost Rate O&M O&M CF FixedCosts
$/kW $/kWyr $/kWyr $/MWH $/kWyr $/kWyr
(a) (b) (c) (d) (e) (f)
UTN200MWSCCTFrame"F"x1EastSideResource(5,050')
2016 $702 $51.76 $30.66 $7.53 $52.42 $104.18
2017 $52.90 $31.33 $7.70 $53.59 $106.49
2018 $54.05 $32.01 $7.87 $54.76 $108.81
2019 $55.13 $32.65 $8.03 $55.86 $110.99
2020 $56.31 $33.35 $8.20 $57.05 $113.36
2021 $57.57 $34.10 $8.38 $58.32 $115.89
2022 $58.87 $34.87 $8.57 $59.64 $118.51
2023 $60.23 $35.67 $8.77 $61.02 $121.25
2024 $61.62 $36.50 $8.97 $62.43 $124.05
2025 $63.05 $37.35 $9.18 $63.89 $126.94
2026 $64.50 $38.21 $9.39 $65.35 $129.85
2027 $65.99 $39.10 $9.61 $66.88 $132.87
2028 $67.53 $40.01 $9.83 $68.43 $135.96
2029 $69.13 $40.96 $10.06 $70.04 $139.17
2030 $70.78 $41.93 $10.30 $71.71 $142.49
2031 $72.48 $42.94 $10.55 $73.44 $145.92
2032 $74.22 $43.97 $10.80 $75.19 $149.41
2033 $76.02 $45.03 $11.06 $77.00 $153.02
2034 $77.86 $46.12 $11.33 $78.87 $156.73
2035 $79.74 $47.23 $11.60 $80.76 $160.50
2036 $81.68 $48.38 $11.88 $82.72 $164.40
2037 $83.66 $49.55 $12.17 $84.73 $168.39
2038 $85.70 $50.76 $12.47 $86.81 $172.51
2039 $87.80 $52.00 $12.78 $88.94 $176.74
2040 $89.94 $53.27 $13.09 $91.11 $181.05
Source:(a)(c)(d) PlantCosts2017IRPTable6.2
(b) =(a)x0.0737263117964292PaymentFactor
(e) =(d)x(8.76x33%)+(c)
(f) =(b)+(e)
UTN200MWSCCTFrame"F"x1EastSideResource(5,050')
200 MWPlantcapacity
2016$ $702 Plantcapacitycostin$/kW
2016$ $16.02 FixedO&M&CapitalizedO&M
2016$ $14.64 FixedPipeline
$30.66 FixedO&MincludingFixedPipeline&CapitalizedO&M($/kWYr)
2016$ $7.53 VariableO&MCosts&CapitalizedVariableO&M($/MWh)
7.373% PaymentFactor
33% CapacityFactor
Exhibit 1
Page 23 of 26
Table8
Page2of3
FixedCapital Total
Estimated CostatReal O&Mat Total Total Total
Capital Levelized Fixed Variable Expected Resource Resource Resource
Year Cost Rate O&M O&M CF FixedCosts FuelCost EnergyCost Costs
$/kW $/kWyr $/kWyr $/MWH $/kWyr $/kWyr $/MMBtu $/MWh $/MWh
(a) (b) (c) (d) (e) (f) (g) (h) (i)
436MWWestSideCCCT
2016 $1,363 $98.90 $43.70 $2.02 $56.14 $155.04
2017 $101.08 $44.67 $2.06 $57.36 $158.44
2018 $103.27 $45.64 $2.10 $58.57 $161.84
2019 $105.34 $46.55 $2.14 $59.73 $165.07
2020 $107.60 $47.55 $2.19 $61.04 $168.64
2021 $110.02 $48.62 $2.24 $62.41 $172.43
2022 $112.50 $49.72 $2.29 $63.82 $176.32
2023 $115.09 $50.87 $2.34 $65.28 $180.37
2024 $117.75 $52.05 $2.39 $66.77 $184.52
2025 $120.48 $53.26 $2.45 $68.35 $188.83
2026 $123.24 $54.48 $2.51 $69.94 $193.18
2027 $126.09 $55.74 $2.57 $71.57 $197.66
2028 $129.02 $57.04 $2.63 $73.24 $202.26
2029 $132.07 $58.39 $2.69 $74.96 $207.03 $4.51 $28.91 $62.53
2030 $135.21 $59.78 $2.75 $76.72 $211.93 $4.88 $31.28 $65.69
2031 $138.46 $61.22 $2.82 $78.59 $217.05 $5.11 $32.76 $68.01
2032 $141.79 $62.69 $2.89 $80.49 $222.28 $5.38 $34.49 $70.58
2033 $145.22 $64.21 $2.96 $82.44 $227.66 $5.76 $36.92 $73.89
2034 $148.74 $65.77 $3.03 $84.43 $233.17 $6.02 $38.59 $76.45
2035 $152.34 $67.36 $3.10 $86.45 $238.79 $6.29 $40.32 $79.10
2036 $156.04 $69.00 $3.18 $88.58 $244.62 $6.80 $43.59 $83.31
2037 $159.83 $70.68 $3.26 $90.76 $250.59 $7.05 $45.19 $85.88
2038 $163.73 $72.41 $3.34 $92.98 $256.71 $7.46 $47.82 $89.51
2039 $167.74 $74.18 $3.42 $95.24 $262.98 $7.75 $49.68 $92.38
2040 $171.84 $75.99 $3.50 $97.54 $269.38 $8.03 $51.47 $95.21
Source:(a)(c)(d) PlantCosts2017IRPTable6.2
(b) =(a)x0.0725628795024555PaymentFactor
(e) =(d)x(8.76x70.3%)+(c)
(f) =(b)+(e)
(g) Table9NaturalGasPriceDeliveredtoPlant
(h) =6,410MMBtu/MWHx(g)
(i) =(f)/(8.76x'CapacityFactor')+(h)
436MWWestSideCCCT
CCCTStatistics MW Percent CapCost Fixed

CCCT Dry "G/H", 1x1 - Turbine 385 88.3% $1,484 $44.50
CCCT Dry "G/H", 1x1 - Duct Firing 51 11.7% $443 $37.67
CapacityWeighted 436 100.0% $1,363 $43.70
CCCTStatistics MW CF aMW Percent Variable HeatRate

CCCTDry"G/H",1x1Turbine 385 78.0% 301 98.0% $2.06 6,362
CCCTDry"G/H",1x1DuctFiring 51 12.0% 6 2.0% $0.15 9,012
EnergyWeighted 436 70.3% 307 100.0% $2.02 6,410
Rounded
Exhibit 1
Page 24 of 26
Table8
Page3of3
Sources,InputsandAssumptions
436MWWestSideCCCT
PlantCosts2017IRPTable6.2
385 51 MWPlantcapacity
2016$ $1,484 $443 Plantcapacitycost
2016$ $21.71 $5.39 FixedO&M&CapitalizedO&M
2016$ $22.79 $32.28 FixedPipeline
$44.50 $37.67 FixedO&MincludingFixedPipeline&CapitalizedO&M($/kWYr)
$2.06 $0.15 VariableO&MCosts&CapitalizedVariableO&M($/MWh)
6,362 9,012 HeatRateinbtu/kWh
7.256% 7.256% PaymentFactor
78.0% 12.0% CapacityFactor
70.3% EnergyWeightedCapacityFactor
100.0% CapacityFactorOnpeak70.3%/56%(percentofhoursonpeak)
CompanyOfficialInflationOfficalMarketPriceForecastdatedMarch2017
2017 2.2% 2024 2.3% 2031 2.4% 2038 2.4%
2018 2.2% 2025 2.3% 2032 2.4% 2039 2.4%
2019 2.0% 2026 2.3% 2033 2.4% 2040 2.4%
2020 2.1% 2027 2.3% 2034 2.4%
2021 2.2% 2028 2.3% 2035 2.4%
2022 2.3% 2029 2.4% 2036 2.4%
2023 2.3% 2030 2.4% 2037 2.4%
Exhibit 1
Page 25 of 26
Table 9
Natural Gas Price - Delivered to Plant
$/MMBtu
Year West Side
2029 $4.51
2030 $4.88
2031 $5.11
2032 $5.38
2033 $5.76
2034 $6.02
2035 $6.29
2036 $6.80
2037 $7.05
2038 $7.46
2039 $7.75
2040 $8.03
Source
Offical Market Price Forecast dated March 2017
Exhibit 1
Page 26 of 26
Table 10
Integration Costs
$/MWh
Inter-hour Intra-hour Wind Total Wind Intra-hour Solar Solar Integration Inflation
Year Integration Costs Integration Costs Integration Costs Integration Costs Costs Forecast
$/MWh $/MWh $/MWh $/MWh $/MWh
(a) (b) (c) = (a) +(b) (d) (e)=(a)+(d) (e)
2016 $0.145 $0.429 $0.570 $0.458 $0.603 1.3%

2017 $0.148 $0.438 $0.590 $0.468 $0.616 2.2%
2018 $0.151 $0.448 $0.600 $0.478 $0.629 2.2%
2019 $0.154 $0.457 $0.610 $0.488 $0.642 2.0%
2020 $0.157 $0.467 $0.620 $0.498 $0.656 2.1%
2021 $0.161 $0.477 $0.640 $0.509 $0.670 2.2%
2022 $0.164 $0.488 $0.650 $0.521 $0.685 2.3%
2023 $0.168 $0.499 $0.670 $0.533 $0.701 2.3%
2024 $0.172 $0.511 $0.680 $0.545 $0.717 2.3%
2025 $0.176 $0.522 $0.700 $0.558 $0.734 2.3%
2026 $0.180 $0.534 $0.710 $0.571 $0.751 2.3%
2027 $0.184 $0.547 $0.730 $0.584 $0.768 2.3%
2028 $0.189 $0.560 $0.750 $0.598 $0.786 2.3%
2029 $0.193 $0.573 $0.770 $0.612 $0.805 2.4%
2030 $0.198 $0.586 $0.780 $0.626 $0.824 2.4%
2031 $0.202 $0.601 $0.800 $0.641 $0.844 2.4%
2032 $0.207 $0.615 $0.820 $0.657 $0.864 2.4%
2033 $0.212 $0.630 $0.840 $0.673 $0.885 2.4%
2034 $0.217 $0.645 $0.860 $0.689 $0.906 2.4%
2035 $0.223 $0.661 $0.880 $0.706 $0.928 2.4%
2036 $0.228 $0.677 $0.900 $0.723 $0.951 2.4%
2037 $0.234 $0.693 $0.930 $0.740 $0.974 2.4%
2038 $0.239 $0.710 $0.950 $0.758 $0.998 2.4%
2039 $0.245 $0.728 $0.970 $0.777 $1.022 2.4%
2040 $0.251 $0.745 $1.000 $0.796 $1.047 2.4%
Exhibit 2
Page 1 of 6

AVOIDED COST CALCULATION
STANDARD RATES FOR AVOIDED COST PURCHASES FROM

QUALIFYING FACILITIES THAT QUALIFY FOR
SCHEDULE NO. 37
WYOMING May 2017

Exhibit 2
Page 2 of 6
WYOMING May 2017
The starting point for the avoided cost calculation is the Companys 2017 Integrated
Resource Plan (2017 IRP) dated April 4, 2017. It should be noted that many of the
input assumptions for the 2017 IRP were fixed in late 2016, in order to enable filing in
April 2017. Due to the age of the input assumptions, certain inputs have been updated for
known changes for purposes of this avoided cost calculation. All table references listed
in this document refer to the tables included in Exhibit 1 to the application.
Table 1 presents the timing of deferrable resources as listed in Table 8.17 of the Companys
2017 IRP. Table 1 shows that the preferred portfolio includes two combined cycle
combustion turbines (CCCTs) and two simple cycle combustion turbines (SCCTs)
during the IRP planning period. The Companys next deferrable resource in the 2017 IRP
is a SCCT in 2029, which marks the start of the avoided cost resource deficiency period.
Avoided Cost Calculation
Based on the timing of the next deferrable resource shown in Table 1, the avoided cost
calculation is separated into two distinct periods: (1) the Short Run a period of resource
sufficiency (2017 through 2028); and (2) the Long Run a period of resource deficiency
(2029 and beyond).
1. Short Run Avoided Costs
During periods of resource sufficiency, the companys avoided energy costs are based on
the displacement of purchased power and existing thermal resources as modeled by the
Companys GRID model.
To calculate short-run avoided costs, two production cost studies are prepared. The only
difference between the two studies is the inclusion of an assumed 50 aMW resource, at
zero running cost. The 50 aMW resource serves as a proxy for qualifying facility (QF)
Exhibit 2
Page 3 of 6
WYOMING May 2017
generation. The avoided energy cost could be viewed as the highest variable cost
incurred to serve total system load from existing and non-deferrable resources. The
outputs of the production cost model run are provided as Table 2A. Table 2B, 2C, and
2D are provided for wind, fixed and tracking solar QF types, respectively, which include
the impact of integration costs during short-run period.
2. Long Run Avoided Costs
During the resource deficiency period (2029 and beyond), avoided costs are the fixed and
variable costs of a proxy resource that could be avoided or deferred. The current proxy
resource is a combined cycle combustion turbine (CCCT).1
Since CCCTs are similar to base load units that provide both capacity and energy, it is
appropriate to split the fixed costs of this unit into capacity and energy components. The
fixed cost of a SCCT, which is predominantly a capacity resource, defines the portion of
the fixed cost of the CCCT that is assigned to capacity.2 Fixed costs associated with the
construction of a CCCT which are in excess of SCCT costs are assigned to energy and
are added to the variable production (fuel) cost of the CCCT to determine the total
avoided energy costs. Table 3 shows the capitalized energy costs.
The fuel cost of the CCCT defines the avoided variable energy costs. The gas price
forecast used as the basis for the CCCT fuel cost is discussed later in this document.
1
A 436 MW West Side, CCCT - Dry "G/H", 1x1 from 2017 IRP, Table 6.2. Fuel costs are from the
Companys March 2017 Official Forward Price Curve.
2
SCCT Frame "F" x 1 - East Side Resource (5,050') as modeled for the 2017 IRP.
Exhibit 2
Page 4 of 6
WYOMING May 2017
Table 4 shows the CCCT fuel cost, the addition of capitalized energy costs at an assumed
70.3%3 capacity factor, and the total avoided energy costs.
Avoided energy costs can be differentiated between on-peak and off-peak periods. To
make this calculation, the Company assumed that all capacity costs are incurred to meet
on-peak load requirements. On an annual basis, approximately 57% of all hours are on-
peak and 43% are off-peak. Table 6A, 6B, 6C, and 6D show the calculation of on-peak
and off-peak avoided cost prices for a base load, wind, fixed and tracking solar,
respectively. Avoided costs are adjusted for wind and solar QFs to reflect the capacity
contribution of each QF type. Capacity contribution values are based on the Companys
Wind and Solar Capacity Contribution Study completed as part of the 2017 IRP.4 Solar
resources are differentiated between fixed tilt projects (Fixed Solar) and single axis
tracking projects (Tracking Solar). Avoided costs are also adjusted for wind and solar
QFs to reflect integration costs. Integration costs are based on the Companys Flexible
Reserve Study included as Appendix F in Volume II of the 2017 IRP.5 Table 10 provides
the details of the integration costs for wind and solar resources.
For informational purposes, Table 7 shows a comparison between the avoided costs
currently in effect in Wyoming and the proposed avoided costs in this filing.
Table 8 shows the calculation of the total fixed costs and fuel costs of the CCCT and SCCT
that are used in Table 3 and Table 4. The Companys next major deferrable thermal
3
The 70.3% capacity factor is the combined energy weighted capacity factor of the proxy CCCT, including
the duct firing unit, as included in the 2017 IRP. See Table 6.2 in the 2017 IRP.
4
2017 Integrated Resource Plan. Volume II. Appendix N: Wind and Solar Capacity Contribution Study.
Available online at:
http://www.pacificorp.com/content/dam/pacificorp/doc/Energy_Sources/Integrated_Resource_Plan/2017_I
RP/2017_IRP_VolumeII_2017_IRP_Final.pdf
5
2017 Integrated Resource Plan. Volume II. Appendix F: Flexible Reserve Study. Available online at:
http://www.pacificorp.com/content/dam/pacificorp/doc/Energy_Sources/Integrated_Resource_Plan/2017_I
RP/2017_IRP_VolumeII_2017_IRP_Final.pdf
Exhibit 2
Page 5 of 6
WYOMING May 2017
resource in the 2017 IRP preferred portfolio is a SCCT in 2029; however, the operating
costs of a SCCT are not a reasonable proxy for the avoided energy value from either a
baseload QF delivering in all or most hours, or an intermittent QF delivering on an as-
available basis. Instead, the 2030 CCCT in the 2017 IRP preferred portfolio is used as a
proxy, but with a deficiency period and capacity payments starting in 2029. Costs and
payment factors for these resources are listed in Tables 6.1 and 6.2 of the 2017 IRP.
Electricity and Gas Price Forecast
The electricity and natural gas prices used in this filing are from the Companys Official
Forward Price Curve dated March 31, 2017. Both the electricity and natural gas prices are
inputs to the Companys GRID model in the calculation of the proposed avoided costs in
this filing. Natural gas prices are also used to calculate the fuel costs of the CCCT proxy
resource for the deficiency period avoided costs, as shown in Table 9. Proxy natural gas
prices are based upon a West side gas index, consistent with the location of the 2030
CCCT.
Cost Comparison
Avoided costs have declined since the Commission approved Schedule 37 avoided costs
in August 2015. One of the primary drivers for this decline is the drop in the electric market
and natural gas price forecast. Electricity market and gas prices from March 2017 dated
OFPC are about 35% lower than those from September 2014 dated OFPC used in current
rates.
The chart below shows the change in electric market and natural gas prices.
Exhibit 2
Page 6 of 6
WYOMING May 2017
Official Forward Price Curve Comparison

90 9
Electricity Price (Average of Palo Verde and Mid-
80 8
Natural Gas Price (Opal) ($/MMBTU)

70 7
60 6
Columbia) ($/MWh)
50 5
40 4
30 3
20 2
Power9/30/14 Power3/31/17
10 1
OpalGas9/30/14 OpalGas3/31/17
0 0
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
Exhibit 3
PROPOSED TARIFFS
CLEAN AND REDLINE VERSIONS
WYOMING May 2017

First Revision of Sheet No. 37-1
Canceling Original Sheet No. 37-1
P.S.C. Wyoming No. 16
Avoided Cost Purchases from

Qualifying Facilities
Schedule 37
Available
To owners of Qualifying Facilities in all territory served by the Company in the State of
Wyoming.
Applicable
Applicable to the purchase by the Company of all non-firm energy produced by
Qualifying Facilities over which the Commission has jurisdiction, prior to commercial
operation and subject to a power sales contract. After commercial operation is
achieved, Qualifying Facilities will receive firm power prices.
For firm power purchases from all Qualifying Facilities over which the Commission has
jurisdiction with a historic or projected annual capacity factor of seventy percent or
below up to 1 MW design capacity or up to a maximum of 10 MW of average monthly
capacity and associated energy when the historic or projected annual capacity factor is
greater than seventy percent. Owners of these Qualifying Facilities shall be required to
enter into a written power sales contract with the Company.
Rates for Purchases

Non-firm Energy
The prices shown below are subject to change from time to time to reflect
changes in the Company's determination of avoided costs. The prices
applicable to a Wyoming Qualifying Facility over which the Commission has
jurisdiction shall be those in effect at the time the power is delivered.
Base Load QF Non-Firm Energy Prices

Deliveries Peak Energy Prices Off-Peak Energy Prices
Year Winter Summer Winter Summer
/kWh /kWh /kWh /kWh
2017 1.27 1.51 1.15 1.13

2018 1.30 1.81 1.17 1.37
2019 1.27 1.92 1.12 1.31
2020 1.53 2.03 1.34 1.34
(continued)
Issued by
Jeffrey K. Larsen, Vice President, Regulation
Issued: May 31, 2017 Effective: With service rendered

on and after November 1, 2017
WY_37-1.REV Dkt. No. 20000-___-EA-17


Schedule 37
Rates for Purchases
Non-firm Energy (continued)
Wind QF Non-Firm Energy Prices
/kWh /kWh /kWh /kWh
2017 1.21 1.46 1.09 1.08

2018 1.24 1.75 1.11 1.31
2019 1.21 1.86 1.06 1.25
2020 1.46 1.97 1.28 1.28
Fixed Solar QF Non-Firm Energy Prices

/kWh /kWh /kWh /kWh
2017 1.21 1.45 1.09 1.08

2018 1.24 1.74 1.11 1.31
2019 1.21 1.85 1.05 1.25
2020 1.46 1.97 1.27 1.28
Tracking Solar QF Non-Firm Energy Prices

/kWh /kWh /kWh /kWh
2017 1.21 1.45 1.09 1.08

2018 1.24 1.74 1.11 1.31
2019 1.21 1.85 1.05 1.25
2020 1.46 1.97 1.27 1.28
(continued)
Issued by

WY_37-2.REV Dkt. No. 20000-___-EA-17


Schedule 37
Firm Power Time of Delivery
The prices shown below are subject to change from time to time to reflect changes in
the Company's determination of Wyoming avoided costs. The prices applicable to a
Qualifying Facility over which the Commission has jurisdiction shall be those in effect at
the time a written contract acceptable to the Company is signed on behalf of the
Qualifying Facility and received by the Company at 825 N. E. Multnomah Street,
Portland, Oregon, 97232, or such other address as the Company shall designate.
These prices will only be applied to Qualifying Facility resources over which the
Commission has jurisdiction that enter into contracts with the Company until 10
megawatts of system resources are acquired.
Base Load QF Firm Energy Prices

/kWh /kWh /kWh /kWh
2017 1.27 1.51 1.15 1.13

2018 1.30 1.81 1.17 1.37
2019 1.27 1.92 1.12 1.31
2020 1.53 2.03 1.34 1.34
2021 0.88 1.94 0.78 1.31
2022 1.07 2.10 0.97 1.51
2023 1.18 2.23 1.09 1.74
2024 1.24 2.45 1.14 2.05
2025 1.31 2.52 1.20 2.09
2026 1.62 2.64 1.49 2.19
2027 1.60 2.78 1.48 2.34
2028 3.14 3.69 2.90 3.13
2029 6.78 6.78 3.99 3.99
(continued)
Issued by

WY_37-3.REV Dkt. No.20000-___-EA-17


Schedule 37
Rates for Purchases

Firm Power Time of Delivery (continued)

/kWh /kWh /kWh /kWh
2030 7.11 7.11 4.26 4.26

2031 7.35 7.35 4.43 4.43
2032 7.62 7.62 4.63 4.63
2033 7.97 7.97 4.90 4.90
2034 8.24 8.24 5.10 5.10
2035 8.52 8.52 5.30 5.30
2036 8.95 8.95 5.66 5.66
2037 9.23 9.23 5.85 5.85
2038 9.60 9.60 6.15 6.15
2039 9.91 9.91 6.37 6.37
(continued)
Issued by

WY_37-4.REV Dkt. No. 20000-___-EA-17


Schedule 37
Rates for Purchases

Wind QF Firm Energy Prices

/kWh /kWh /kWh /kWh
2017 1.21 1.46 1.09 1.08

2018 1.24 1.75 1.11 1.31
2019 1.21 1.86 1.06 1.25
2020 1.46 1.97 1.28 1.28
2021 0.81 1.88 0.71 1.25
2022 1.00 2.04 0.90 1.44
2023 1.12 2.16 1.03 1.67
2024 1.17 2.38 1.07 1.98
2025 1.24 2.45 1.13 2.02
2026 1.55 2.57 1.42 2.12
2027 1.53 2.71 1.40 2.26
2028 3.07 3.62 2.83 3.05
2029 4.36 4.36 3.92 3.92
2030 4.63 4.63 4.18 4.18
2031 4.81 4.81 4.35 4.35
2032 5.02 5.02 4.55 4.55
2033 5.30 5.30 4.82 4.82
2034 5.51 5.51 5.01 5.01
2035 5.72 5.72 5.22 5.22
2036 6.09 6.09 5.57 5.57
2037 6.29 6.29 5.76 5.76
2038 6.60 6.60 6.05 6.05
2039 6.83 6.83 6.27 6.27
(continued)
Issued by

WY_37-5.REV Dkt. No. 20000-___-EA-17


Schedule 37
Rates for Purchases

Fixed Solar QF Firm Energy Prices

/kWh /kWh /kWh /kWh
2017 1.21 1.45 1.09 1.08

2018 1.24 1.74 1.11 1.31
2019 1.21 1.85 1.05 1.25
2020 1.46 1.97 1.27 1.28
2021 0.81 1.88 0.71 1.24
2022 1.00 2.03 0.90 1.44
2023 1.11 2.16 1.02 1.67
2024 1.17 2.38 1.06 1.98
2025 1.23 2.45 1.12 2.01
2026 1.55 2.56 1.41 2.12
2027 1.52 2.70 1.40 2.26
2028 3.06 3.61 2.82 3.05
2029 4.97 4.97 3.91 3.91
2030 5.26 5.26 4.17 4.17
2031 5.45 5.45 4.35 4.35
2032 5.68 5.68 4.55 4.55
2033 5.98 5.98 4.82 4.82
2034 6.20 6.20 5.01 5.01
2035 6.43 6.43 5.21 5.21
2036 6.81 6.81 5.57 5.57
2037 7.03 7.03 5.76 5.76
2038 7.36 7.36 6.05 6.05
2039 7.61 7.61 6.27 6.27
(continued)
Issued by

WY_37-6.REV Dkt. No. 20000-___-EA-17


Schedule 37
Rates for Purchases

Tracking Solar QF Firm Energy Prices

/kWh /kWh /kWh /kWh
2017 1.21 1.45 1.09 1.08

2018 1.24 1.74 1.11 1.31
2019 1.21 1.85 1.05 1.25
2020 1.46 1.97 1.27 1.28
2021 0.81 1.88 0.71 1.24
2022 1.00 2.03 0.90 1.44
2023 1.11 2.16 1.02 1.67
2024 1.17 2.38 1.06 1.98
2025 1.23 2.45 1.12 2.01
2026 1.55 2.56 1.41 2.12
2027 1.52 2.70 1.40 2.26
2028 3.06 3.61 2.83 3.05
2029 5.58 5.58 3.91 3.91
2030 5.88 5.88 4.17 4.17
2031 6.09 6.09 4.35 4.35
2032 6.33 6.33 4.55 4.55
2033 6.64 6.64 4.82 4.82
2034 6.88 6.88 5.01 5.01
2035 7.13 7.13 5.21 5.21
2036 7.53 7.53 5.57 5.57
2037 7.77 7.77 5.76 5.76
2038 8.11 8.11 6.05 6.05
2039 8.38 8.38 6.27 6.27
(continued)
Issued by

WY_37-7.REV Dkt. No. 20000-___-EA-17


Schedule 37
Available
To owners of Qualifying Facilities in all territory served by the Company in the State of
Wyoming.
Applicable
Applicable to the purchase by the Company of all non-firm energy produced by
Qualifying Facilities over which the Commission has jurisdiction, prior to commercial
operation and subject to a power sales contract. After commercial operation is
achieved, Qualifying Facilities will receive firm power prices.
For firm power purchases from all Qualifying Facilities over which the Commission has
jurisdiction with a historic or projected annual capacity factor of seventy percent or
below up to 1 MW design capacity or up to a maximum of 10 MW of average monthly
capacity and associated energy when the historic or projected annual capacity factor is
greater than seventy percent. Owners of these Qualifying Facilities shall be required to
enter into a written power sales contract with the Company.
Rates for Purchases

Non-firm Energy
The prices shown below are subject to change from time to time to reflect
changes in the Company's determination of avoided costs. The prices
applicable to a Wyoming Qualifying Facility over which the Commission has
jurisdiction shall be those in effect at the time the power is delivered.
Base Load QF Non-Firm Energy Prices

/kWh /kWh /kWh /kWh
20142017 2.791.27 1.51 2.331.15 1.13

20152018 2.891.30 3.171.81 2.371.17 2.251.37
20162019 2.781.27 3.191.92 2.231.12 2.291.31
20172020 2.871.53 3.342.03 2.281.34 2.391.34
(continued)
Issued by
Issued: December 28, 2015May 31, 2017 Effective: With service rendered
on and after January 1, 2016 November 1, 2017
WY_37-1.EREV Dkt. No. 20000-469___-EREA-1517


Schedule 37
Rates for Purchases
Non-firm Energy (continued)
Wind QF Non-Firm Energy Prices
/kWh /kWh /kWh /kWh
20142017 2.491.21 1.46 2.031.09 1.08

20152018 2.591.24 2.861.75 2.071.11 1.951.31
20162019 2.471.21 2.881.86 1.921.06 1.981.25
20172020 2.551.46 3.021.97 1.961.28 2.071.28
Fixed Solar QF Non-Firm Energy Prices

/kWh /kWh /kWh /kWh
20142017 2.791.21 1.45 2.261.09 1.08

20152018 2.821.24 3.091.74 2.291.11 2.181.31
20162019 2.701.21 3.111.85 2.151.05 2.211.25
20172020 2.791.46 3.261.97 2.201.27 2.311.28
Tracking Solar QF Non-Firm Energy Prices

/kWh /kWh /kWh /kWh
20142017 2.721.21 1.45 2.261.09 1.08

20152018 2.821.24 3.091.74 2.291.11 2.181.31
20162019 2.701.21 3.111.85 2.151.05 2.211.25
20172020 2.791.46 3.261.97 2.201.27 2.311.28
(continued)
Issued by
on and after January 1, 2016November 1, 2017


Schedule 37
Firm Power Time of Delivery
The prices shown below are subject to change from time to time to reflect changes in
the Company's determination of Wyoming avoided costs. The prices applicable to a
Qualifying Facility over which the Commission has jurisdiction shall be those in effect at
the time a written contract acceptable to the Company is signed on behalf of the
Qualifying Facility and received by the Company at 825 N. E. Multnomah Street,
Portland, Oregon, 97232, or such other address as the Company shall designate.
These prices will only be applied to Qualifying Facility resources over which the
Commission has jurisdiction that enter into contracts with the Company until 10
megawatts of system resources are acquired.

/kWh /kWh /kWh /kWh
20142017 2.791.27 1.51 2.331.15 1.13

20152018 2.891.30 3.171.81 2.371.17 2.251.37
20162019 2.781.27 3.191.92 2.231.12 2.291.31
20172020 2.871.53 3.342.03 2.281.34 2.391.34
20182021 3.190.88 3.771.94 2.500.78 2.691.31
20192022 3.291.07 3.952.10 2.600.97 2.851.51
20202023 3.491.18 4.102.23 2.861.09 2.991.74
20212024 3.811.24 4.352.45 3.421.14 3.412.05
20222025 4.241.31 4.632.52 4.021.20 3.872.09
20232026 4.211.62 4.882.64 3.971.49 4.092.19
20242027 3.921.60 5.272.78 3.701.48 4.352.34
20252028 5.343.14 5.683.69 5.072.90 4.543.13
20262029 5.296.78 6.096.78 5.023.99 4.903.99
(continued)
Issued by
on and after January 1, 2016November 1, 2017
WY_37-3.EREV Dkt. No.20000-469___-EREA-1517


Schedule 37
Rates for Purchases


/kWh /kWh /kWh /kWh
20272030 7.727.11 7.727.11 4.514.26 4.514.26

20282031 7.957.35 7.957.35 4.684.43 4.684.43
20292032 8.207.62 8.207.62 4.874.63 4.874.63
20302033 8.467.97 8.467.97 5.074.90 5.074.90
20312034 8.628.24 8.628.24 5.165.10 5.165.10
20322035 8.788.52 8.788.52 5.265.30 5.265.30
20332036 8.958.95 8.958.95 5.365.66 5.365.66
20342037 9.129.23 9.129.23 5.465.85 5.465.85
20352038 9.319.60 9.319.60 5.576.15 5.576.15
20362039 9.509.91 9.509.91 5.696.37 5.696.37
2037 9.68 9.68 5.80 5.80
2038 9.87 9.87 5.91 5.91
(continued)
Issued by


Schedule 37
Rates for Purchases

Wind QF Firm Energy Prices

/kWh /kWh /kWh /kWh
20142017 2.491.21 1.46 2.031.09 1.08

20152018 2.591.24 2.861.75 2.071.11 1.951.31
20162019 2.471.21 2.881.86 1.921.06 1.981.25
20172020 2.551.46 3.021.97 1.961.28 2.071.28
20182021 2.870.81 3.451.88 2.180.71 2.361.25
20192022 2.971.00 3.622.04 2.280.90 2.521.44
20202023 3.161.12 3.772.16 2.531.03 2.651.67
20212024 3.471.17 4.012.38 3.071.07 3.071.98
20222025 3.891.24 4.282.45 3.671.13 3.522.02
20232026 3.861.55 4.532.57 3.621.42 3.732.12
20242027 3.561.53 4.912.71 3.341.40 3.982.26
20252028 4.973.07 5.313.62 4.702.83 4.173.05
20262029 4.924.36 5.724.36 4.643.92 4.533.92
20272030 4.594.63 4.594.63 4.134.18 4.134.18
20282031 4.764.81 4.764.81 4.294.35 4.294.35
20292032 4.965.02 4.965.02 4.474.55 4.474.55
20302033 5.155.30 5.155.30 4.664.82 4.664.82
20312034 5.255.51 5.255.51 4.755.01 4.755.01
20322035 5.355.72 5.355.72 4.845.22 4.845.22
20332036 5.456.09 5.456.09 4.935.57 4.935.57
20342037 5.556.29 5.556.29 5.025.76 5.025.76
20352038 5.676.60 5.676.60 5.126.05 5.126.05
20362039 5.786.83 5.786.83 5.236.27 5.236.27
2037 5.89 5.89 5.33 5.33
2038 6.01 6.01 5.44 5.44
(continued)
Issued by
WY_37-5.E REV Dkt. No. 20000-469___-EREA-1517


Schedule 37
Rates for Purchases

Fixed Solar QF Firm Energy Prices

/kWh /kWh /kWh /kWh
20142017 2.721.21 1.45 2.261.09 1.08

20152018 2.821.24 3.091.74 2.291.11 2.181.31
20162019 2.701.21 3.111.85 2.151.05 2.211.25
20172020 2.791.46 3.261.97 2.201.27 2.311.28
20182021 3.110.81 3.691.88 2.420.71 2.611.24
20192022 3.211.00 3.872.03 2.520.90 2.771.44
20202023 3.411.11 4.022.16 2.781.02 2.901.67
20212024 3.731.17 4.262.38 3.331.06 3.331.98
20222025 4.151.23 4.542.45 3.931.12 3.792.01
20232026 4.121.55 4.792.56 3.881.41 4.002.12
20242027 3.831.52 5.182.70 3.611.40 4.252.26
20252028 5.253.06 5.593.61 4.982.82 4.453.05
20262029 5.204.97 6.004.97 4.923.91 4.813.91
20272030 5.515.26 5.515.26 4.424.17 4.424.17
20282031 5.705.45 5.705.45 4.584.35 4.584.35
20292032 5.915.68 5.915.68 4.774.55 4.774.55
20302033 6.125.98 6.125.98 4.974.82 4.974.82
20312034 6.246.20 6.246.20 5.065.01 5.065.01
20322035 6.356.43 6.356.43 5.155.21 5.155.21
20332036 6.486.81 6.486.81 5.255.57 5.255.57
20342037 6.607.03 6.607.03 5.355.76 5.355.76
20352038 6.737.36 6.737.36 5.466.05 5.466.05
20362039 6.877.61 6.877.61 5.576.27 5.576.27
2037 7.00 7.00 5.68 5.68
2038 7.14 7.14 5.79 5.79
(continued)
Issued by


Schedule 37
Rates for Purchases

Tracking Solar QF Firm Energy Prices

/kWh /kWh /kWh /kWh
20142017 2.721.21 1.45 2.261.09 1.08

20152018 2.821.24 3.091.74 2.291.11 2.181.31
20162019 2.701.21 3.111.85 2.151.05 2.211.25
20172020 2.791.46 3.261.97 2.201.27 2.311.28
20182021 3.110.81 3.691.88 2.420.71 2.611.24
20192022 3.211.00 3.872.03 2.520.90 2.771.44
20202023 3.411.11 4.022.16 2.781.02 2.901.67
20212024 3.731.17 4.262.38 3.331.06 3.331.98
20222025 4.151.23 4.542.45 3.931.12 3.792.01
20232026 4.121.55 4.792.56 3.881.41 4.002.12
20242027 3.831.52 5.182.70 3.611.40 4.252.26
20252028 5.253.06 5.593.61 4.982.83 4.453.05
20262029 5.205.58 6.005.58 4.923.91 4.813.91
20272030 5.675.88 5.675.88 4.424.17 4.424.17
20282031 5.866.09 5.866.09 4.584.35 4.584.35
20292032 6.076.33 6.076.33 4.774.55 4.774.55
20302033 6.296.64 6.296.64 4.974.82 4.974.82
20312034 6.416.88 6.416.88 5.065.01 5.065.01
20322035 6.537.13 6.537.13 5.155.21 5.155.21
20332036 6.667.53 6.667.53 5.255.57 5.255.57
20342037 6.787.77 6.787.77 5.355.76 5.355.76
20352038 6.928.11 6.928.11 5.466.05 5.466.05
20362039 7.068.38 7.068.38 5.576.27 5.576.27
2037 7.20 7.20 5.68 5.68
2038 7.34 7.34 5.79 5.79
(continued)
Issued by

Docket No. 20000-___-EA-17
Witness: Daniel J. MacNeil
BEFORE THE WYOMING PUBLIC SERVICE

COMMISSION
____________________________________________
Direct Testimony of Daniel J. MacNeil
May 2017
1 Q. Please state your name, business address, and present position with PacifiCorp
2 dba Rocky Mountain Power (the Company).
3 A. My name is Daniel J. MacNeil. My business address is 825 NE Multnomah Street,
4 Suite 600, Portland, Oregon 97232. My present position is Resource and Commercial
5 Strategy Adviser.
6 QUALIFICATIONS
7 Q. Briefly describe your education and professional experience.
8 A. I received a Master of Arts degree in International Science and Technology Policy from
9 George Washington University and a Bachelor of Science degree in Materials Science
10 and Engineering from Johns Hopkins University. Before joining the Company, I
11 completed internships with the U.S. Department of Energys Office of Policy and
12 International Affairs and the World Resources Institutes Green Power Market
13 Development Group. I have been employed by PacifiCorp since 2008, first as a member
14 of the Net Power Costs group, then as manager of that group from June 2015 until
15 September 2016. In my current role, I provide analytical expertise on a broad range of
16 topics related to PacifiCorps resource portfolio and obligations, including oversight of
17 the calculation of avoided cost pricing in the Companys jurisdictions.
18 PURPOSE OF TESTIMONY AND RECOMMENDATION
19 Q. What is the purpose of your testimony?
20 A. My testimony is provided in support of the Companys May 31, 2017 filing to update
21 Schedule 37, Avoided Cost Purchases from Qualifying Facilities. The Companys
22 filing provides updated Schedule 37 prices and incorporates several updates related to
23 the assumptions and results of the Companys 2017 Integrated Resource Plan (IRP),
Page 1 Direct Testimony of Daniel J. MacNeil

1 filed on April 4, 2017. My testimony provides support for each update incorporated in
2 the avoided cost price calculation proposed by the Company.
3 Q. What Qualifying Facilities (QF) resources qualify for Schedule 37 pricing?
4 A. Published rates under Schedule 37 are available to QFs up to 1 MW capacity and with
5 an annual capacity factor of seventy percent or lower, or to QF projects up to 10 MW
6 and with a capacity factor higher than seventy percent.
7 Q. Please describe the specific updates to the calculation of Schedule 37 rates as
8 proposed by the Company.
9 A. The Company proposes the following updates to the calculation of avoided cost rates
10 in Schedule 37:
11 Market prices for electricity and gas have been updated to reflect the
12 Companys March 31, 2017 Official Forward Price Curve (1703 OFPC).
13 Sufficiency period avoided costs are based on the Generation and Regulation
14 Initiative Decision (GRID) model runs incorporating these market prices.
15 Integration costs for wind and solar QFs are updated consistent with the 2017
16 IRP.
17 Capacity contribution values for intermittent QF resources are updated
18 consistent with the 2017 IRP.
19 The resource deficiency period is updated to reflect the timing of the next
20 deferrable major thermal resource identified in the 2017 IRP preferred
21 portfolio.
22 Avoided capacity and energy costs during the deficiency period are based on
23 the characteristics of the next combined cycle combustion turbine (CCCT)

1 identified in the 2017 IRP preferred portfolio.
2 Q. Is the Company required to update the Schedule 37 avoided cost rates irrespective
3 of the proposed changes?
4 A. Yes. The Company is required to file updated system data and avoided cost rates in
5 order to be in compliance with Chapter 3, Section 35 of the Commissions Rules, which
6 cover arrangements between electric utilities and QFs within the meaning of Sections
7 201 and 210 of the Public Utility Regulatory Policies Act of 1978 (PURPA).
8 Specifically, Chapter 3, Section 35(c)(i) requires system data from which avoided costs
9 may be derived to be filed not less often than every two years.
10 Q. When were the rates currently in effect approved by the Commission?
11 A. Wyoming Schedule 37 rates were last approved in a written order in Docket No. 20000-
12 458-EA-14, issued by the Commission on August 26, 2015.
13 Q. What is the impact of updating Schedule 37 avoided cost rates?
14 A. Table 1 below shows the current Schedule 37 rates and the updated rates proposed in
15 this filing. Exhibit 1 included with the application contains the supporting calculations
16 and workpapers used to develop the updated rates.
17 Table 1
20 Year (2018 to 2037) Nominal Levelized Prices ($/MWh)
Current Rates Proposed Change
Base Load $52.15 $31.48 ($20.67)
Wind $41.51 $25.64 ($15.86)
Fixed-Tilt Solar $49.03 $29.65 ($19.38)
18 Tracking Solar $49.65 $31.51 ($18.13)
19 Q. What is the primary driver of the reduction in the updated avoided cost rates?
20 A. As shown in Table 2 below, the biggest impact to avoided costs is the update to the
21 1703 OFPC, including updated sufficiency period avoided costs calculated in GRID.

1 In the following sections, I provide background on the Schedule 37 methodology and
2 discuss each of the proposed updates.
3 Table 2
Impact on 20 Year (2018 to 2037) Nominal Levelized Prices ($/MWh)
Capacity Deficiency,
1703 OFPC Integration
Contribution Capacity, and Other
Base Load ($21.01) $0.00 $0.00 $0.35
Wind ($21.28) $3.01 $0.10 $2.30
Fixed-Tilt Solar ($21.53) $0.17 $0.44 $1.53
4 Tracking Solar ($21.43) $0.17 $2.35 $0.78
5
6 SCHEDULE 37 BACKGROUND
7 Q. Please provide a brief history of Schedule 37 pricing in Wyoming.
8 A. The framework for the calculation of rates under Schedule 37 was first approved by the
9 Commission in Docket No. 20000-ET-92-45 and Docket No. 20000-ET-92-18.
10 Schedule 37 prices have been reviewed and updated in several subsequent dockets,
11 including most recently in Docket No. 20000-458-EA-14.
12 Q. Please describe the currently-approved method for calculating avoided costs for
13 small QFs qualifying for published rates under Schedule 37.
14 A. The determination of avoided costs is divided into two periods: resource sufficiency
15 and resource deficiency. During the sufficiency period, avoided energy costs are
16 calculated using GRID, the Companys production cost model. Net power costs
17 (NPC) are calculated in GRID using two system dispatch simulations; one without
18 any new QF resources and one with an additional 50 average megawatt (aMW)
19 resource included at zero cost. The difference in NPC between the two GRID runs
20 divided by the energy produced by the 50 aMW QF resource determine the avoided
21 energy cost. During the deficiency period, avoided costs are equal to the fixed and
22 variable costs of a proxy resource, currently a combined cycle combustion turbine

1 (CCCT).
2 Q. Is this same method used to calculate avoided costs for large QFs under Schedule
3 38?
4 A. No. Avoided costs for large QFs under Schedule 38 are calculated using the Partial
5 Displacement Differential Revenue Requirement (PDDRR) method. The methods
6 are similar in that both utilize the GRID model to determine avoided costs during the
7 sufficiency period and both include capacity costs of a CCCT in the deficiency period.
8 The PDDRR method, however, continues to use a combination of the GRID model to
9 determine energy costs and partial displacement of a CCCT to determine capacity costs
10 during the deficiency period rather than basing avoided costs solely on the proxy CCCT
11 capacity and energy costs. Furthermore, the PDDRR method accounts for the specific
12 characteristics of a proposed QF, including geographic location and any transmission
13 constraints, and prices are prepared for individual QF projects using project specific
14 generation profiles rather than providing the same published prices for all QFs.
15 Q. Is the same GRID model used as a starting point for avoided costs under Schedule
16 37 as is currently used under Schedule 38?
17 A. Yes. While the avoided cost calculations are slightly different, as described above, the
18 base scenario is the same and includes the Companys 2017 IRP preferred portfolio,
19 with adjustments for resources displaced by signed QFs.

1 PROPOSED UPDATES
2 Official Forward Price Curve
3 Q. Has the Companys Official Forward Price Curve changed significantly since
4 current Schedule 37 prices were prepared?
5 A. Yes. The current Schedule 37 prices reflect the Companys September 30, 2014 OFPC,
6 which is now more than two and a half years old. In that time, market prices for
7 electricity and natural gas have both fallen dramatically, as shown in Figure 1 below.
Figure 1
Official Forward Price Curve Comparison

90 9
Electricity Price (Average of Palo Verde and Mid-
80 8
Natural Gas Price (Opal) ($/MMBTU)

70 7
60 6
Columbia) ($/MWh)
50 5
40 4
30 3
20 2
Power9/30/14 Power3/31/17
10 1
OpalGas9/30/14 OpalGas3/31/17
0 0
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
8 Q. How do market prices impact avoided costs?
9 A. As described above, avoided costs during the sufficiency period are based on two GRID
10 runs. When the avoided cost resource is added in the GRID model, it can support

1 incremental wholesale market sales, avoid wholesale market purchases, or displace the
2 Companys resources. When electricity prices drop, the value of incremental wholesale
3 sale and avoided wholesale purchases also drops. Similarly, when gas prices drop, the
4 avoided fuel cost from displacing the Companys gas resources also drops. Because the
5 Company has limited transmission from Wyoming to market hubs, avoided cost
6 resources located in Wyoming are more likely to displace the Companys resources
7 rather than impact market transactions. Avoided costs during the deficiency period are
8 directly tied to the forward prices for natural gas based on the heat rate of the proxy
9 resource.
10 Integration Costs
11 Q. What does the Company propose with regard to integration costs in Schedule 37?
12 A. The Company proposes that wind and solar integration costs be updated to reflect the
13 values calculated and utilized in its 2017 IRP. The values in the current Schedule 37
14 reflect values calculated and utilized as part of the 2015 IRP.
15 Q. How are integration costs calculated?
16 A. The Company has prepared studies to calculate wind integration costs in the last several
17 IRPs. For the first time, the study for the 2017 IRP also calculated solar integration
18 costs. The Flexible Reserve Study was included as Appendix F in Volume II of the
19 2017 IRP.1
20 Wind and solar integration studies are performed to estimate the operating
21 reserves required to maintain PacifiCorps system reliability and comply with North
1
2017 Integrated Resource Plan. Volume II. Appendix F: Flexible Reserve Study. Available online at:
http://www.pacificorp.com/content/dam/pacificorp/doc/Energy_Sources/Integrated_Resource_Plan/2017_IRP/2
017_IRP_VolumeII_2017_IRP_Final.pdf

1 American Electric Reliability Corporation (NERC) reliability standards. The
2 Company must provide sufficient operating reserves to allow the Balancing Authority
3 to meet NERCs control performance criteria at all times. These incremental operating
4 reserves are necessary to maintain area control error within required parameters due to
5 sources outside the direct control of system operators including intra-hour changes in
6 load demand and wind generation. The study results in a volume of operating reserves
7 and the associated cost of these operating reserves required to manage the variation of
8 load and resources in PacifiCorps Balancing Authority Areas. In addition, the Flexible
9 Reserve Study determines the system balancing costs required to manage load, wind,
10 and solar resources. System balancing costs capture the costs associated with the need
11 to commit resources on a day-ahead basis, but operating those resources against actual
12 conditions that occur the next day. In the current Schedule 37 filing, the Company used
13 the costs calculated in its 2017 Flexible Reserve Study to adjust the avoided costs for
14 wind and solar QFs.
15 Q. What is the impact of updating integration costs?
16 A. As shown in Table 3 below, wind and solar integration costs in the 2017 IRP are lower
17 than the costs currently reflected in Schedule 37. The reduction in integration costs is
18 partly driven by declining market prices as discussed above. The 2017 Flexible Reserve
19 Study also reflects a revised NERC reliability standard and includes benefits from
20 managing a diverse portfolio including load, wind, solar, and other non-dispatchable
21 resources.

Table 3
2017 IRP 2015 IRP

Integration Cost
(2017$/MWh) (2015$/MWh)
Wind $0.57 $3.06
Solar $0.60 $0.77
1 Capacity Contribution
2 Q. What does the Company propose with regard to capacity contribution in Schedule
3 37?
4 A. The Company proposes that capacity contribution values for wind and solar resources
5 be updated to reflect the values calculated and utilized in its 2017 IRP. The values in
6 the current Schedule 37 reflect values calculated and utilized in its 2015 IRP.
7 Q. What is capacity contribution?
8 A. The capacity contribution of wind and solar resources, represented as a percentage of
9 a resources nameplate capacity, is a measure of the ability of these resources to reliably
10 meet demand. For purposes of calculating Schedule 37 avoided cost prices, the capacity
11 contribution of a QF resource is applied to the fixed costs of the deferred proxy CCCT
12 to determine the capacity costs that can be avoided due to the addition of the QF
13 resource.
14 Q. How is the capacity contribution of wind and solar resources calculated?
15 A. The Company completed a capacity contribution study in support of its 2017 IRP. The
16 Company calculated peak capacity contribution values for wind and solar resources
17 using the capacity factor approximation method (CF Method) as outlined in a 2012
18 report produced by the National Renewable Energy Laboratory.2 The Wind and Solar
2
Madaeni, S. H.; Sioshansi, R.; and Denholm, P. Comparison of Capacity Value Methods for Photovoltaics in
the Western United States. NREL/TP-6A20-54704, Denver, CO: National Renewable Energy Laboratory, July
2012 (NREL Report). http://www.nrel.gov/docs/fy12osti/54704.pdf

1 Capacity Contribution Study was included as Appendix N in Volume II of the 2017
2 IRP.3 Table 4 below shows the capacity contribution levels for wind, fixed-tilt solar,
3 and tracking solar resources based on the 2017 IRP and the 2015 IRP.
Table 4
East BAA West BAA

Single Axis Single Axis
Peak Capacity Fixed Tilt Fixed Tilt
Wind Tracking Solar Wind Tracking Solar
Contribution Solar PV Solar PV
PV PV
2017 IRP Results 15.8% 37.9% 59.7% 11.8% 53.9% 64.8%
2015 IRP Results 14.5% 34.1% 39.1% 25.4% 32.2% 36.7%
4 Q. What is the impact of updating capacity contribution?
5 A. For resources in Wyoming, the capacity contribution results from the 2017 IRP are
6 higher than the levels reflected in the current Schedule 37 rates. As previously shown
7 in Table 2, the higher capacity contribution increases avoided cost prices for wind and
8 solar resources, however it only has an impact during the deficiency period.
9 Resource Sufficiency/Deficiency and Capacity Costs
10 Q. What does the Company propose with regard to the resource
11 sufficiency/deficiency period?
12 A. The next deferrable major thermal resource in the Companys 2017 IRP preferred
13 portfolio is a 200 MW simple cycle combustion turbine (SCCT) added in Utah North
14 in 2029. Therefore, the Company proposes that the deficiency period for calculating
15 Schedule 37 rates begin in 2029.
3
2017 Integrated Resource Plan. Volume II. Appendix N: Wind and Solar Capacity Contribution Study.
Available online at:
http://www.pacificorp.com/content/dam/pacificorp/doc/Energy_Sources/Integrated_Resource_Plan/2017_IRP/2
017_IRP_VolumeII_2017_IRP_Final.pdf

1 Q. Are the energy costs associated with the 2029 SCCT appropriate for setting
2 avoided energy rates?
3 A. No. An SCCT has a relatively low expected capacity factor as it is generally dispatched
4 to meet requirements in the highest load hours. In addition, an SCCT can be dispatched
5 on short notice to compensate for variations in load, wind generation, and solar
6 generation, or the output from resource that experience unplanned outages. This
7 flexibility allows an SCCT to provide value and contribute to reliable system operation
8 even when the unit is offline. As a result, the operating costs of an SCCT are not a
9 reasonable proxy for the avoided energy value from either a baseload QF delivering in
10 all or most hours, or an intermittent QF delivering on an as-available basis.
11 Q. What proxy resource do you propose using to set avoided cost rates?
12 A. During the deficiency period, the current Schedule 37 rates reflect the fixed and
13 variable costs of a 423 MW CCCT scheduled to come online in 2027, as this was the
14 next deferrable major thermal resource at the time of the 2014 Schedule 37 avoided
15 cost proceeding, based on the Companys 2013 IRP Update. In the updated Schedule
16 37 rates, the Company proposes that the 436 MW CCCT scheduled to come online in
17 2030 in the 2017 IRP preferred portfolio be used to set the fixed and variable costs for
18 Schedule 37. Consistent with the resource deficiency period established above, avoided
19 cost prices reflect the fixed and variable costs of this CCCT beginning in 2029.
20 Q. What is the impact of updating the deficiency period and capacity costs?
21 A. Updating the resource deficiency period from 2027 to 2029 delays the start of payments
22 for capacity and reduces avoided cost prices in 2027 and 2028. On the other hand, the
23 2029 fixed capacity costs from the 2017 IRP are higher than the fixed capacity costs

1 currently reflected in Schedule 37 rates, resulting in higher avoided cost prices in 2029
2 and beyond. As previously shown in Table 2, the combined effect of updating the
3 resource deficiency period and capacity costs is an increase in avoided costs over a 20-
4 year term.
5 Q. Does this conclude your direct testimony?
6 A. Yes.

BEFORE THE PUBLIC SERVICE COMMISSION OF WYOMING
IN THE MATTER OF THE )

APPLICATION OF ROCKY )
MOUNTAIN POWER FOR APPROVAL ) DOCKET NO. 20000- -EA-17
OF SCHEDULE 37 STANDARD RATES ) (RECORD NO.-~
FOR PURCHASES OF POWER FROM )
QUALIFYING FACILITIES )
AFFIDAVIT, OATH AND VERIFICATION
Daniel MacNeil (Affiant) being oflawful age and being first duly sworn, hereby deposes
and says that:
Affiant is a Resource and Commercial Strategy Adviser for PacifiCorp, which is a

party in this matter.
Affiant prepared and caused to be filed the foregoing testimony. Affiant has, by all
necessary action, been duly authorized to file this testimony and make this Oath
and Verification.
Affiant hereby verifies that, based on Affiant's knowledge, all statements and
infom1ation contained within the testimony and all of its associated attachments are
true and complete and constitute the recommendations of the Affiant in his official
capacity as Resource and Commercial Strategy Adviser.
Further Affiant Sayeth Not.
Dated this
Daniel MacNeil
Resource and Commercial Strategy Adviser
825 NE Multnomah Ave
Portland, OR 97232
503-813-552
STATE of\j_l) \"hi L'Nt~ b- )
) SS:
coUNTYOF )
The foregoing was acknowledged before me by Daniel MacNeil on this 3u"day of
f0 A"'/ , 2017. Witness my hand and official seal.
My Commission Expires: l
OFFICIAL STAMP
PATRICIA ANN DEAS
NOTARY PUBLIC-OREGON
COMMISSION NO. 937208
MY COMMISSION EXPIRES MARCH 12, 2019
Exhibit 5
PETITION FOR CONFIDENTIAL TREATMENT
WYOMING May 2017

Yvonne R. Hogle
Daniel E. Solander
1407 W. North Temple, Suite 320
Telephone No. (801) 220-4014
Facsimile No. (801) 220-3299
yvonne.hogle@pacificorp.com
daniel.solander@pacificorp.com
Attorneys for Rocky Mountain Power
BEFORE THE WYOMING PUBLIC SERVICE COMMISSION
)
IN THE MATTER OF THE APPLICATION OF ) DOCKET NO. 20000-___-EA-17
ROCKY MOUNTAIN POWER FOR APPROVAL ) (Record No. ______)
OF SCHEDULE 37 STANDARD RATES FOR )
PURCHASES OF POWER FROM QUALIFYING ) PETITION FOR CONFIDENTIAL
FACILITIES ) TREATMENT AND
) PROTECTIVE ORDER
)
Rocky Mountain Power, pursuant to Chapter 2, Section 30 of the Rules of Practice &
Procedure of the Public Service Commission of Wyoming and Rule 26 of the Wyoming Rules of
Civil Procedure, hereby submits its Petition for Confidential Treatment of certain workpapers to
the Wyoming Public Service Commission (Commission). Rocky Mountain Power
(Company) hereby requests the Commission approve the Companys confidential designation
of the workpapers provided in this proceeding based on the explanations set forth below. The
workpapers and supporting files were filed May 31, 2017, with the Commission and were properly
labeled as confidential at the time of the filing.
In addition, the Company files with this Petition, as required by Chapter 2, Section 30(d)
of the Rules, a proposed Protective Order, attached hereto, with the appropriate form to be signed
by parties who wish to use information that is designated, and approved by the Commission to be
treated, as confidential, including confidential information that is subsequently designated as

confidential during the course of the above-captioned case.
Support for Confidentiality Designation
1. The workpapers contain information from the Generation and Regulation Initiative
Decision (GRID) model runs, which are deemed by the Company to be trade secret,
commercially sensitive, confidential business information or otherwise sensitive in nature such
that the disclosure of the information would jeopardize the interest of and cause irreparable injury
to the Company. Disclosure of this information would also cause harm to the Companys
customers by raising prices and increasing the cost for the Company to provide safe, reliable
service. Furthermore, the disclosure of certain cost information could be used by other companies
to gain a competitive advantage in the future.
2. Accordingly, the Company has designated certain workpapers that contain the
GRID modeling information as confidential and respectfully requests that the Commission
approve such designation.
WHEREFORE, Rocky Mountain Power respectfully requests the following:
1. That the Commission approve the Companys Petition.
2. That the Commission designate certain workpapers as confidential and provide
that the use of such confidential information must be made pursuant to the protective order.
3. That the Commission issue a protective order in substantially the same form as the
proposed protective order attached hereto.
2
DATED this 31st day of May, 2017.
Respectfully submitted,
__________________________
Daniel E. Solander
Attorney for Rocky Mountain Power
3
PUBLIC SERVICE COMMISSION OF WYOMING
IN THE MATTER OF THE APPLICATION OF ) DOCKET NO. 20000-___-EA-17

ROCKY MOUNTAIN POWER FOR APPROVAL ) (Record No. _______)
OF SCHEDULE 37 STANDARD RATES FOR )
PURCHASES OF POWER FROM QUALIFYING
FACILITIES
PROTECTIVE ORDER
(Issued _____ __, 2017)
This matter is before the Wyoming Public Service Commission (Commission) upon Rocky
Mountain Powers (Rocky Mountain of the Company) Petition for Confidential Treatment and
Protective Order (Petition) in the above-captioned matter. The Commission, having reviewed the
Petition, Rocky Mountain Powers application, its files regarding Rocky Mountain, applicable
Wyoming utility law, and otherwise being fully advised in the premises, FINDS and
CONCLUDES:
1. Rocky Mountain Power is a public utility as defined by W.S. 37-1-101(a)(vi)(C)

and, as such, is subject to the Commissions jurisdiction under W.S. 37-2-112.
2. On May 31, 2017, Rocky Mountain filed a Petition for Confidential Treatment and
Protective Order, in support whereof it alleged that certain workpapers in this matter contain
confidential information and that parties to this matter might, during discovery, seek the production
of trade secrets, commercially sensitive or confidential business information, or information that
is otherwise so sensitive in nature that disclosure would jeopardize the interests of the party that
has been requested to disclose the information, and the unlimited disclosure of which could result
in economic harm to the disclosing party. The Company also asserted that a protective order would
facilitate a full and timely review of the above-captioned application.
3. Rocky Mountains Petition was heard by the Commission pursuant to due notice at
its open meeting of June___, 2017. Commission Advisory Staff recommended the Commission
approve Rocky Mountains Petition as being generally compliant with Chapter 2, Section 30 of
the Commissions Rules. We find there exists a potential body of information which is of such a
sensitive nature that its unlimited disclosure could result in economic harm to Rocky Mountain or
another disclosing party but which should be shared with the parties to this proceeding. The
Commission finds and concludes that Rocky Mountain has supported its request for confidential
treatment of such documents and information under Chapter, 2 Section 30 of the Commissions
Rules. The Commission also finds and concludes that the proposed documents offered by Rocky
Mountain, suitably expressing the Commissions prerogatives in the matter and ensuring the
4
necessary references to Chapter 2, Section 30 of the Commissions Rules, should be approved in
the public interest as a useful and efficient method of dealing with confidential information in this
case. The Commission finds that sufficient grounds exist for entry of a protective order under
Chapter 2, Section 30 of the Commissions Rules, generally as sought by Rocky Mountain in its
Petition.
IT IS THEREFORE ORDERED THAT:
1. Pursuant to open meeting action taken on June __, 2017, Rocky Mountain Powers
Petition for Confidential Treatment and Protective Order is granted.
2. The confidential information in this proceeding shall be dealt with according to the
terms of the ensuing paragraphs 3 through 16.
3. The parties to this proceeding shall allow each of the authorized parties, under
Chapter 2, Section 30 of the Commissions Rules and the terms of this Protective Order, to have
access to and to review data and information claimed by each to be of a confidential nature. The
parties have designated or may in the future designate documents filed with the Commission or
produced in discovery as confidential for the reason that such documents contain confidential
information, trade secrets, proprietary information or commercially sensitive information.
4. Definitions. For purposes of this Protective Order, the following terms shall mean:
a. Documents shall mean and include all written, recorded or electronic

graphic matters of any kind or nature whatsoever, within the meaning of Rule 34(a) W.R.C.P., or
Rule 1001 W.R.E., and shall extend to any subsequent compilation, summary, quotation, or
reproduction thereof prepared at any subsequent time in any subsequent form or proceeding, in
whole or in part and shall include computer software, computer models and information generated
by computer software and models. The reference to Rule 1001 W.R.E. is for definitional
purposes only and is not intended to suggest that the Wyoming Rules of Evidence are applicable
to Commission proceedings. Further the reference to W.R.C.P. is not intended to suggest that any
of the Wyoming Rules of Civil Procedure are applicable to Commission proceedings, except those
specifically made applicable to Commission proceedings by the Wyoming Administrative
Procedure Act.
b. Confidential Information shall mean and include any Documents and all
contents thereof which are marked CONFIDENTIAL by the party producing the information
(Producing Party), including information prepared, presented, typed or copied on yellow paper.
c. Authorized Person(s) shall mean and be limited to the employees,

attorneys and expert witnesses or consultants of the party receiving the information (Receiving
Party) who are necessary to assist counsel in preparation for the proceedings in this docket.
5
Authorized Person(s) shall not include individuals responsible for marketing or other
competitive activities or who could use the information in the normal course of their employment
to the competitive disadvantage of the Producing Party except upon prior approval of the
Commission. No person, with the exception of the Commissioners, members of the Commission
Staff and the Wyoming Office of Consumer Advocate, shall be considered an Authorized Person
under this Protective Order unless such person is qualified as such under paragraph 5 below.
d. Authorized Use shall mean and be limited to use only for purposes of this
docket in addressing the issues arising in this proceeding over which the Commission has
jurisdiction.
e. Disclose, make disclosure of, or disclosure shall mean and include

the dissemination to any person, firm, corporation or other entity of the contents of a Document,
whether that dissemination is by means of the transmittal or transfer of the original or a copy of
that document or any verbal or other dissemination of the contents of the Document.
5. Restrictions on Disclosure of Confidential Information. All Confidential

Information and the disclosure thereof shall be subject to the following restrictions:
a. A Producing Party or Receiving Party may submit Confidential Information

to the Commission, the Commission Staff, and the staff of the Wyoming Office of Consumer
Advocate for the purposes of this proceeding, provided that the information is submitted, identified
and maintained as Confidential Information subject to Chapter 2, Section 30 of the Commissions
Rules. Other than the disclosures described in the previous sentence, the Receiving Party shall not
disclose any Confidential Information to anyone other than its Authorized Person(s) for the sole
purpose of the Receiving Partys review and analysis of this filing.
b. Whether Confidential Information has been produced in hard copy or in

some other form, the Receiving Party shall make no copies or reproductions of any kind or nature
whatsoever of the Confidential Information so supplied, except that copies or reproductions may
be made when necessary for use by Authorized Persons in preparation for the proceedings on the
filing or the presentation of the partys case.
c. The foregoing notwithstanding and with the exception of the Commission,

Commission Staff, or the staff of the Wyoming Office of Consumer Advocate, the Receiving Party
may not receive Confidential Information until they have signed a Nondisclosure Agreement in
the form attached hereto, marked as Exhibit A and incorporated herein by reference. Upon
execution of Exhibit A, the signed originals shall be furnished to counsel of record for the
Producing Party and copies thereof shall be filed with the Commission. Furthermore, a Receiving
Party may not disclose Confidential Information to an Authorized Person unless, prior to the
disclosure of such Confidential Information, the Authorized Person has signed and furnished an
Exhibit A Nondisclosure Agreement as required above.
6
d. Counsel for the Receiving Party shall be responsible for designating
Authorized Persons to whom disclosure of Confidential Information is deemed necessary to assist
counsel in the preparation for proceedings in this docket. The names of authorized persons shall
be provided to the Producing Party at least five (5) business days prior to any disclosure to enable
the Producing Party to challenge the right of an individual to review Confidential Information for
any reason prior to disclosure to that individual, unless the Producing Party waives this right. In
the event the Parties cannot resolve a challenge between themselves, the challenge will be resolved
by the Commission. During the pendency of the challenge, no disclosure shall be made to the
individual in question and the Commission shall retain its specific authority to extend or adjust
deadlines as, in its opinion, justice may require due to delays caused by the exercise of rights under
this provision or otherwise.
6. Protective measures for Highly Sensitive Confidential Information. A Producing

Party may claim that additional protective measures, beyond those otherwise required under this
Protective Order, are warranted for certain Confidential Information referred to as Highly
Sensitive Confidential Information. A Producing Party making such a claim shall identify such
Highly Sensitive Confidential Information and shall inform the Receiving Party of their claimed
highly sensitive nature as soon as possible.
a. General procedure. As to documents designated as Highly Sensitive

Confidential Information, the Producing Party shall have the right, at its option, not to provide
copies thereof to other parties, their counsel, experts or other representatives. In the event a
Producing Party does not provide copies of Highly Sensitive Confidential Information, such
Highly Sensitive Confidential Information, if discoverable, may be made available for inspection
and review by counsel or experts for the Receiving Party at a mutually agreed upon place and time.
Inspection may occur at all times during normal business hours upon request made not later than
fifteen (15) business days before inspection is to occur, and within such time as is allowed by the
Commission under its Rules or the Wyoming Rules of Civil Procedure applicable to responses to
discovery requests under the Wyoming Administrative Procedure Act. Failure of the Producing
Party to make information available for inspection at the agreed place after timely request has been
made shall constitute a waiver of the restrictions contained in this subparagraph and the Receiving
Party may demand and shall be provided a copy of the information, subject to Chapter 2, Section
30 of the Commissions Rules and the other terms of this Protective Order. Where copies are not
provided, counsel and experts reviewing the Highly Sensitive Confidential Information may make
notes regarding the highly sensitive Confidential Information for reference purposes only. Such
notes shall not consist of a verbatim or substantive transcript of the highly sensitive Confidential
Information and shall be themselves Confidential Information subject to Chapter 2, Section 30 of
the Commissions Rules and the terms of this Protective Order.
b. Additional protection. In the event that any party believes a different level
of protection than that provided for above in this paragraph is appropriate for any Highly Sensitive
Confidential Information, the parties shall first attempt to reach agreement on the appropriate level
of protection. If agreement cannot be reached, any party may request that the Commission resolve
7
the disagreement. The concerned party may petition the Commission for an order granting
additional protective measures which the petitioner believes are warranted for the claimed Highly
Sensitive Confidential Information that is to be produced. The petition shall set forth the particular
basis for: the claim, the specific additional protective measures requested, the need therefore, and
the reasonableness of the requested additional protection. A party who would otherwise receive
the documents and information under the terms of this Protective Order may respond to the
petition and oppose or propose alternative protective measures to those requested by the provider
of the claimed Highly Sensitive Confidential Information. In disputes brought to the Commission
for resolution under this subparagraph, the petitioning party shall have the burden to prove that the
additional protections it proposes should be approved.
7. Disputes in general. In the event the Receiving Party objects to the Producing
Partys designation of a document or its contents as Confidential Information, the materials shall
be treated as Confidential Information until a contrary ruling by the Commission, or, if appropriate,
a court of competent jurisdiction. Prior to the time any objection to a designation of Confidential
Information is brought before the Commission or, if appropriate, a court of competent jurisdiction,
for resolution, the parties shall attempt to resolve the objection by agreement. If the parties are
unable to reach an agreement, then either of them may bring the objection before the Commission
or, if appropriate, a court of competent jurisdiction in accordance with the applicable rules of that
forum. In disputes brought to the Commission for resolution under this paragraph, the Producing
Party shall have the burden under Chapter 2, Section 30 of the Commissions Rules to prove that
the protections it proposes should be approved. The parties recognize that the Commission has
the authority to extend or adjust deadlines as, in its opinion, justice may require due to delays
caused by the exercise of rights under this provision or otherwise. For purposes of resolving
disputes concerning Highly Sensitive Confidential Information, references in this paragraph to
Confidential Information shall include Highly Sensitive Confidential Information. All resolutions
shall be made by order of the Commission.
8. General procedures for the use of Confidential Information.
a. Receipt into Evidence. Confidential Information may be received into

evidence in this proceeding under seal. Unless the Commission requires or allows a different time
period, at least ten (10) days prior to the use of, or substantive reference to any Confidential
Information as evidence, the party intending to use such Confidential Information shall provide
notice of that intention to the counsel for the Producing Party. The Requesting Party and the
Producing Party shall make a good faith effort to reach an agreement so that the information can
be used in a manner which will not reveal Confidential Information. If such efforts fail, the
concerned parties shall within five (5) days, unless the Commission requires or allows a different
time period, designate which portions, if any, of the documents to be offered, or referred to on the
record contain Confidential Information. The portions of the documents so designated shall be
placed in the sealed record. Only one (1) copy of documents designated by the Producing Party
to be placed in the sealed record shall be made and only for that purpose. Any required additional
copies of the record shall receive the same treatment. Otherwise, parties shall make only general
8
references to Confidential Information in these proceedings, except as may be provided for in
subparagraph c below. Notwithstanding the foregoing, the Commission may make and retain such
copies of this Confidential Information as it sees fit for the efficient disposition of the proceeding.
b. Seal. While in the custody of the Commission or any member of its staff,
these materials shall be marked CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER IN
DOCKET NO. 20000-________, and shall be immediately entitled to be treated as Confidential
Information under Chapter 2, Section 30 of the Commissions Rules, pending any further order of
the Commission.
c. In Camera Hearing. Any Confidential Information which must be orally

disclosed by any person shall be part of the sealed record in this proceeding and shall be offered
only in an in camera hearing, attended only by persons authorized to have access to the
Confidential Information under Chapter 2, Section 30 of the Commissions rules and this
Protective Order. Similarly, cross-examination on, or substantive references to, Confidential
Information, as well as that portion of the record containing references thereto, shall be marked
and treated as provided herein.
d. Appeal. Sealed portions of the record in this proceeding may be forwarded

to any court of competent jurisdiction on appeal in accordance with applicable rules and
regulations, but under seal as designated herein, for the information and use of the court only.
e. Return. Unless otherwise ordered, Confidential Information, including

transcripts of any depositions to which a claim of confidentiality is made, shall remain under seal,
shall continue to be subject to the protection of Chapter 2, Section 30 of the Commissions Rules
and the requirements of this Protective Order, and shall, within 30 days after final settlement, or
other conclusion of this matter, including any administrative or judicial review thereof, be either
[i] returned to counsel for the Producing Party or [ii] destroyed by the Receiving Party.
Compliance with this paragraph shall be evidenced by an affidavit of counsel for the Receiving
Party in the form attached hereto as Exhibit B. The Commission may retain such Confidential
Information as it deems necessary subject to Chapter 2, Section 30 of its Rules. Counsel who are
provided access to Confidential Information pursuant to the terms of this Protective Order may
retain their notes, work papers or other documents that would be considered the attorneys work
product created with respect to their use and access to Confidential Information in this docket. An
expert witness, accorded access to Confidential Information pursuant to this Protective Order,
shall provide to counsel for the party on whose behalf the expert was retained or employed, the
experts notes, work papers or other documents pertaining or relating to any Confidential
Information. Counsel shall retain these experts documents with counsels documents.
f. Redacted public versions of Confidential Information. It is the

Commission's policy that its proceedings be as open and transparent as possible, so members of
the public may have the greatest possible access to and understanding thereof. Therefore, whenever
only a portion of a Document is considered Confidential Information hereunder, the confidential
9
portion shall be clearly identified and treated as such in accordance with this Protective Order.
However, the Producing Party shall restrict its designation of confidential status to the end that as
much of the Document as possible shall remain nonconfidential and open to public inspection.
When a Producing Party submits such a partially confidential Document, it shall simultaneously
submit a redacted version thereof with the Confidential Information blacked out or otherwise
rendered indecipherable. The identification of Confidential Information in any partially
confidential Document shall be restricted to those portions thereof which are actually confidential
(e.g., if only two pages of a Document contain Confidential Information, only those pages should
be reproduced on yellow paper). The public redacted version of any such document shall be clearly
marked on its face "Redacted Nonconfidential Public Version.
9. Use by Parties. Where reference to Confidential Information in the sealed record

is required in pleadings, cross-examinations, briefs, argument, motions or otherwise, it shall be, to
the extent possible, only by citation or title, or exhibit number, or by some other non-confidential
description. Any other use of, or substantive references to, Confidential Information, shall be
placed in a separate section of the pleading or brief and submitted to the Commission under seal,
on yellow paper, and identified as provided for in paragraph 8b above. This sealed section shall
be served only on counsel of record (one copy each), who have signed a Nondisclosure Agreement
(Exhibit A). All the protections afforded by this Protective Order, the Commissions Rules and
its orders with respect thereto shall apply to materials prepared and distributed under this
paragraph.
10. Use in Decisions and Orders. The Commission will attempt to refer to Confidential
Information in only a general or conclusory manner and will avoid reproduction in any decision
of Confidential Information to the greatest possible extent. If the Commission deems it necessary
to discuss Confidential Information specifically, it will treat the Confidential Information in a
manner consistent with the treatment of Confidential Information in paragraph 9 above.
11. Removal of confidential status.
a. Voluntary disclosure. Nothing in this Protective Order shall preclude a

Producing Party from using or disclosing any of its own Confidential Information for any purpose
or to any person. If any information for which Confidential Information status is sought in this
case has been previously filed by a party as public information with a court or any federal or state
agency, the party seeking to have the designation continue to apply thereto shall petition the
Commission for such a designation.
b. Petition for removal of confidential status. Any party at any time upon ten
(10) days prior notice may seek by appropriate pleading to the Commission to have documents
that have been designated as Confidential Information or Highly Sensitive Confidential
Information, or which were accepted into the sealed record in accordance with this Protective
Order, removed from the protective requirements of this Protective Order, or from the sealed
record and placed in the public record. If the confidential nature of such information is challenged,
the Commission will resolve the issue in an in camera hearing at which only those persons duly
10
authorized hereunder to have access to such Confidential Information or Highly Sensitive
Confidential Information shall be present. If the Commission finds that no party would be
prejudiced thereby and the case continues to proceed in an orderly manner, it may provide in such
order that its decision will not take effect for a period of ten (10) days or such other time period as
may be deemed advisable by the Commission to protect the rights of parties to seek further relief
and to provide for the efficient and orderly conduct of the case.
12. Limitations. Nothing in this Protective Order shall prohibit or limit any party as to
any objections it may otherwise have to the disclosure of any Confidential Information to which
this Protective Order applies.
13. Filing of Discovery Requests and Responses. In dealing with Confidential

Information, the parties are reminded of Chapter 2, Section 17 of the Commissions Rules
regarding discovery-related filings which states:
(a) The taking of depositions and discovery shall be in accordance with Wyoming Statute 16-3-
107(g).
(b) Unless the hearing officer or adjudicative agency orders otherwise, parties shall not file discovery
requests, answers, and deposition notices with the hearing officer or adjudicative agency.
14. Protection to survive after end of proceeding. The provisions of this Protective
Order, insofar as they restrict the disclosure and use of Confidential Information governed
by this Protective Order, shall, without the written agreement of the parties or further order
of the Commission, or if appropriate, a court of competent jurisdiction, continue to be
binding after the conclusion of the case.
15. Commission authority retained. This Protective Order does not diminish or limit
the Commissions authority to deal with Confidential Information in this case under applicable
Wyoming laws and rules, including, without limitation, Chapter 2, Section 30 of the Commissions
Rules. Nothing in this Protective Order shall prevent a party from placing before the Commission
its desire for relief with respect to any issue arising with regard to any information alleged to be
covered by this Protective Order, including disputes arising in the event that information is not
disclosed to a party under this Protective Order.
16. Commission jurisdiction not limited hereby. Nothing in this Protective Order shall
be construed as limiting the Commissions jurisdiction in this case or the prerogatives of the
Commission regarding the orderly governance and disposition of this case, the use and disposition
of Confidential Information or its prerogatives to make and enter all orders it deems necessary in
the public interest, giving careful regard to the interests of the parties and the commercially
sensitive nature of the information involved.
17. This Protective Order is effective immediately.
11
MADE and ENTERED at Cheyenne, Wyoming, on _____ __, 2017.
PUBLIC SERVICE COMMISSION OF WYOMING
__________________________________________
(SEAL)
Attest:
12
EXHIBIT A TO PROTECTIVE ORDER
NONDISCLOSURE AGREEMENT:
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR

APPROVAL OF SCHEDULE 37 STANDARD RATES FOR PURCHASES OF POWER FROM
QUALIFYING FACILITIES - DOCKET NUMBER 20000-___-EA-17
I hereby agree that I have been furnished a copy of and have read and understand the
Protective Order issued by the Wyoming Public Service Commission in Docket No. 20000-___-
EA-17 with respect to the review and use of Confidential Information. I understand the Protective
Order and the definition of Confidential Information contained herein, and agree to comply with
the terms and conditions of the Protective Order with respect to all Confidential Information
covered thereby. I also have read, understand and agree to be bound by and to comply with Chapter
2, Section 30 of the Commissions Rules, a copy of which is attached hereto.
Name
Employer or Firm
Business Address
Party With Whom Associated
Date
Signature
13
ATTACHMENT TO EXHIBIT A -- NONDISCLOSURE AGREEMENT:
Commission Rule Chapter 2, Section 30: Confidentiality of Information.
(a) Upon petition, and for good cause shown, the Commission shall deem confidential any
information filed with the Commission or in the custody of the Commission or staff which is shown to be
of the nature described in Wyoming Statute 16-4-203(a), (b), (d) or (g). All information for which
confidential treatment is requested shall be treated as confidential until the Commission rules whether, and
to what extent, the information shall be given confidential treatment.
(b) Any person requesting confidential treatment of information (except as directed by the
Commission in investigative and discovery matters) shall file a petition that includes the following
information:
(i) The assigned docket, if applicable.
(ii) Title the filing as: Petition for Confidential Treatment of ______________________..
(iii) Numbered listings and explanations in adequate detail to support why confidentiality
should be authorized for each item, category, page, document or testimony. Each item, category or page of
proposed confidential information shall be attached to the Petition and numbered in the right hand margin
so that numbering corresponds with the numbering and detailed explanation(s) in the Petition. If only part
of a page, or intermittent parts of pages, are requested to be kept confidential, these should be set off by
brackets identified with an item number or numbers. Each page containing information for which
confidential treatment is requested shall be printed on yellow paper and marked or stamped at the top in
capital letters: CONFIDENTIAL INFORMATION.
(iv) A request for return or other final disposition of the information.
(c) All information deemed confidential under this Rule shall be retained in secure areas of the
Commissions offices.
(d) If the person petitioning for confidential treatment of information intends that parties in a case
have access thereto, upon signing a statement that the information shall be treated as confidential, the
petitioner shall prepare a proposed protective order for the Commissions approval with an attached form
to be signed by the parties and made part of the Commissions permanent case file.
(e) Information in the Commissions confidential files shall be retained for the period determined
by the Commission. On an appeal of a Commission final order, any confidential information included in
the record shall be sealed and delivered to the court pursuant to the W.A.P.A.
(f) The Commission may consider oral petitions for confidential treatment of information when the
public interest requires.
14
EXHIBIT B TO PROTECTIVE ORDER
AFFIDAVIT OF COUNSEL:

[Counsel] being of lawful age and being first duly sworn, hereby deposes and says that:
Alternative 1 (to be used if documents returned). I have obtained the original copies of
all Confidential Information provided to [Receiving Party] by [Producing Party] in the Wyoming
Public Service Commissions proceedings in Docket No. 20000-____________ concerning Rocky
Mountain Power and all such documents are being returned to [Producing Party] together with this
Affidavit. Furthermore, I have obtained all copies and reproductions of such Confidential
Information known to me to exist in the custody or control of [Receiving Party], its employees,
attorneys, experts, consultants and agents and all such documents are being returned to [Producing
Party] together with this Affidavit.
Alternative 1 (to be used if documents destroyed). I have obtained the original copies of
all Confidential Information provided to [Receiving Party] by [Producing Party] in the Wyoming
Public Service Commissions proceedings in Docket No. 20000-__________ concerning Rocky
Mountain Power and all such documents have been destroyed. Furthermore, I have obtained all
copies and reproductions of such Confidential Information known to me to exist in the custody or
control of [Receiving Party], its employees, attorneys, experts, consultants and agents and all such
documents have been destroyed.
2. I have made diligent inquiry of all persons known to me to have had access to the
Confidential Information received from [Producing Party] in the captioned proceeding and have
otherwise diligently endeavored to identify and locate all copies of such Confidential Information
in the custody or control of [Receiving Party], its employees, attorneys, experts, consultants and
agents. Other than myself, the employees attorney, experts, consultants, and agents who have had
access to the Confidential Information together with their current address are listed below.
[LIST PERSONS WHO HAVE HAD ACCESS.]
Alternative 3 (to be used if documents returned). I am not aware of the existence of any
copies or reproductions of the Confidential Information provided to [Receiving Party] by
[Producing Party] in the captioned proceeding that are not included and returned to [Producing
Party] with this Affidavit.
Alternative 3 (to be used if documents destroyed). I am not aware of the existence of any
15
copies or reproductions of the Confidential Information provided to [Receiving Party] by
[Producing Party] in the captioned proceeding that have not been destroyed.
Further Affiant Sayeth Not.
DATED this _____ day of ________________,
Counsel for [Receiving Party]
STATE OF )
)SS
COUNTY OF )
The foregoing was acknowledged before me by _____________ on this ____ day of

_______________, . Witness my hand and official seal.
___________________________________
Notary Public
My commission expires: .
16

Rocky Mountain Power's Petition To The Wyoming Public Service Commission

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Rocky Mountain Power's Petition To The Wyoming Public Service Commission

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1407 West North Temple, Suite 310

Salt Lake City, UT 84116

May 31, 2017

VIA ELECTRONIC FILING

Wyoming Public Service Commission

Attn: Chris Petrie, Chief Counsel Docket No. 20000-___-EA-17

RE: IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER

Dear Mr. Petrie:

By E-mail (preferred): datarequest@pacificorp.com

By regular mail: Data Request Response Center

with copies to: Stacy Splittstoesser

Attorneys for Rocky Mountain Power

BEFORE THE WYOMING PUBLIC SERVICE COMMISSION

IN THE MATTER OF THE APPLICATION )

APPLICATION FOR APPROVAL OF SCHEDULE 37

Comes now Rocky Mountain Power (RMP or Company), a division of

Schedule 37 (Application) including supporting testimony, exhibits, and proposed

In support of this Application, Rocky Mountain Power represents as follows:

2. Rocky Mountain Power is a public utility in the state of Wyoming subject

retail customers in Wyoming. Rocky Mountain Powers principal place of business in

Wyoming is 2840 East Yellowstone Highway, Casper, Wyoming 82602.

3. Communications regarding this application should be addressed to:

application be sent in Microsoft Word or plain text format addressed to:

or by regular mail to: Data Request Response Center

Informal questions may be directed to Stacy Splittstoesser at (307) 632-2677.

4. This Application is filed pursuant to Chapter 3, Section 35 of the

Commissions Rules, which sets forth the Commissions regulations regarding

than every two years.

5. The Avoided Cost Study prepared in support of this Application results in

a proposed avoided cost price of $31.48/MWh on a 20-year (2018-2037) nominal levelized

natural gas market prices.

7. Exhibit 1, Avoided Cost Study Tables 1-10, attached to this Application, is

8. Exhibit 2, Standard Rates for Avoided Cost Purchases from Qualifying

10. Exhibit 4 is the direct testimony of Daniel J. MacNeil, Resource and

avoided cost calculations.

WHEREFORE, Rocky Mountain Power requests Commission approval of the

DATED this 31st day of May 2017.

ROCKY MOUNTAIN POWER

AVOIDED COST STUDY TABLES 1-10

WYOMING May 2017

Capacity (MW) Resource Totals 1/

Year Winter Season Summer Season Winter Season

GRID Production Cost Model Study

Annual Seasonal Average

2017 $12.14 $13.41 $12.14

Source: GRID Production Cost Computer Model Study

WY Sch 37 2017 - Exhibit 1 - AC Study _2017 05 26.xlsx

Year Winter Season Summer Season Winter Season

GRID Production Cost Model Study_OnPeak (1)

Annual Seasonal Average, OnPeak

2017 $12.66 $15.05 $12.66

WY Sch 37 2017 - Exhibit 1 - AC Study _2017 05 26.xlsx

Year Winter Season Summer Season Winter Season

GRID Production Cost Model Study_OffPeak (2)

Annual Seasonal Average, OffPeak

2017 $11.51 $11.30 $11.51

WY Sch 37 2017 - Exhibit 1 - AC Study _2017 05 26.xlsx

Year Winter Season Summer Season Winter Season