CITY OF LOS ANGELES DEPARTMENT OF WATER AND POWER 2017 REFORM OF ELECTRIC TRANSMISSION TARIFF AND ELECTRIC TRANSMISSION RATES

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1 ing 1 DWP 104 Tab: Control Sheet Cells: H25-H27 - Please provide the studies and documentation that yielded the Receiving Station Study Reclassifications. [The studies relied on by Jennifer Tripp are attached as IR1a (RS Reallocation Memo.pdf) and IR1b (IR1b RS Study_Final_ ). The Table of CBs and Transformers at Receiving Stations (RS) was compared against facilities in the LADWP provided FY14/15 power flow model to: Compare the number of transformer at each RS reported in the RS Reallocation Memo to the FY14/15 power flow model Compare the aggregate MVA for the transformers at each station reported in the RS Reallocation Memo to the FY14/15 power flow model For any difference identified, nfront discussed the differences with LADWP and LADWP provided updated information in the IR1b RS Study_Final_ nfront also reviewed with LADWP the methodology used to allocate high voltage equipment associated with the RS transformers, e.g., breakers and switches to protect the transformer. LADWP confirmed it allocated those costs to distribution for all transformers classed as distribution in the LADWP Transmission Facility Determination Assessment To understand the cost allocation, nfront reviewed the costs estimates for transformers and circuit breakers as shown IR1_a and IR1b and determined that the costs were reasonable. nfront has no other studies or documentation except as provided in 1

2 ing Testimony DWP-500 and Exhibit DWP Tab: Gen AS Matrix Cells C15-AB22 - Please provide the studies and documentation that yielded the information on which generating resources provide which ancillary services. There are no studies or documentation that yield the information on which generating resources provide which ancillary services as shown in Tab: Gen AS Matrix. The information is based upon the input of LADWP Power System staff based upon their knowledge of which generating stations provide which ancillary service. 3 DWP 104 Tab AD, section G.3. Cell C360 - Please provide a copy of LADWP s Receiving Station study, including all supporting documentation. [See response to IR1] 4a Tab AH Cell H67 - Which tab does H67 point to? Cell H67 in tab AH ($296.4 M) is literally carried forward to Statement BK cell F143 which is a check number for O&M. It should be noted that the two components of the $296.4 million are shown in tab AH in cells AF67 (Hoover purchased power: $14.5 million) and cell BE 67 (IPP purchased power: $281.9 million). Cell AF67 in tab AH is carried forward to cell V134 in tab BK. Cell BE67 in tab AH is carried forward to cell AE133 in tab BK. 2

3 ing 4b Tab AH Cells D55-D64 Please provide documentation that shows the classification of IPP Minimum Costs (IPP Share) to Production, Transmission and any other functions. Please see Attachment 4b_Purchased Power.xlsx. More specifically, please see the yellow highlighted cells in the OATT Purchased Power tab and the IPP Minimum Costs tab. The IPP Minimum Costs are classified as Production only. 4c Tab AH Row 65: Please provide documentation that shows the classification of Purchase Power Hoover to Production, Transmission and any other functions. Please see Attachment 4b_Purchased Power.xlsx. More specifically, please see the blue highlighted cell (D12) in the OATT Purchased Power tab. Hoover Purchased Power costs are classified as Production only. 4d Tab AH Section D.2: Please provide an explanation for the reclassification of hydro O&M costs to Owens Valley. Owens Valley Common Costs (See cells N135:N144 of tab AH): LADWP s GL tracks a category of O&M costs that are related to the Owens Valley hydro production stations as a group but are not specifically tracked by production station. As such, these costs are allocated to each Owens Valley hydro production station. Miscellaneous (FERC 543) (See cells O135:O144 of tab AH): LADWP s GL FERC 543 includes a subcomponent (Miscellaneous) of costs that are not specifically tracked by production station. A review of these costs 3

4 ing 4e Tab AH Section G.3: Please provide copies of all contracts that provide LADWP transmission rights that are posted on the LADWP OASIS. Please provide data for FY14-15 showing the total MWs or MWhs or both that LADWP transmitted for others using these contract rights. by LAWP staff determined that that these costs are related to the Owens Valley hydro production stations. 5a Tab AL Cells C Please provide all documentation referenced as IPP Summary of Power Sales. Please see Attachment 5a_IPP Summary of Power Sales and IPA Trueup.pdf 5b Tab AL Cell Please provide a copy of the IPA True-up Statement. Please see Attachment 5a_IPP Summary of Power Sales and IPA Trueup.pdf 4

5 ing 5c Tab AL Cells B211-B223 - Please provide references to FERC decisions in support of including fuel stocks in OATT rates. Southern California Edison Company, Opinion 359, 53 FERC 61,408 at pp. 62,418 62,419 (1990). 5d Tab AL Section B.5, rows Please provide documentation for the $35.5 million of prepaid energy. whom was the energy purchased? For how long? Please provide the relevant contract(s) for the purchase of such prepaid energy. For the GL amounts supporting the $35.5 million please see Attachment 5d_Prepaid Energy Query. Per Section B.5, of the $35.5 million, $22.4 million is related with non- OATT service. The remaining $13.1 million is related to OATT service and is prepaid energy associated with LADWP s entitlement to IPP per the GL. 5e Tab AL Section D. Please provide documentation for fuel stock. For the GL query related to fuel stock, please see Attachment 5e_Fuel Stock.xlsx Fuel stock in BL comes from the GL and is related to LADWP s fuel oil and coal stock inventory. 5

6 ing 6a Tab AU Cells G24-P29 Please provide documentation for all revenue credits, by source, type of service and specific amount of revenues. 6b Tab AU Please provide relevant contracts that support the sale of services that yield such credits. 7a 7b Tab BB Tab BB Cells C27-D38 - Please provide documentation for all amounts. For Long- Term Firm PTP amounts, please provide copies of service agreements Column D - Are non-oatt or pre-oatt contract loads included in column D? If so, please provide copies of service agreements. If not, please explain why not. 6

7 ing 7c Tab BB Please provide a definition of LA s Peak Load. Please confirm that this is LADWP s retail load. If not, please explain any differences between Peak Load and LADWP s retail load. 7d Tab BB Please provide copies of all PTP contracts used to calculate amounts in Column D. 7e Tab BB Please identify which PTP contract demand went away on January 1 of the test year. 7f 8a Tab BB Please affirm that non- OATT contract demands are included in the PTP contract summary. If not, please explain why not Cell F294 - Please provide documentation for all 7

8 ing Tab BK revenue credits received from LADWP Wholesale Marketing Short-term, including but not limited to internal memoranda and e- mail records. 8b Tab BK Cell F297 - Please provide documentation for all OATT Service Short- Term revenue credits. 8c Tab BK Cells F339, F385, F430 - Please explain the lack of revenue credits from LADWP Wholesale Marketing Short-Term. 8d Tab BK Cells F342 - Please explain the lack of revenue credits from OATT Service Short-Term. 8e Cells F388, F433 - Please provide documentation for OATT Service Short- 8

9 ing Tab BK Term revenue credits. 8f 8g Tab BK Tab BK Cells F477-F482 - Please provide documentation for all revenue credits Please provide documentation for revenues received from the Southern California Public Power Authority (SCPPA) for services provided to SCPPA, including queries to LADWP s GL. Please identify where such revenues appear as credits to the revenue requirements. 9a Tab BL Cell E168 - Please provide a copy of the Reserve Requirement for 2014 VER Integration Study for LADWP (January 2017). Please see Attachment 9a_Reserve Requirements for 2014 VER Integration.pdf 9

10 ing 9b Tab BL Cell E211 - Please provide a copy of BAL-002-WECC- 2 Contingency Reserve Requirements, and documentation showing LADWP s translation or application of BAL- 002 to LADWP s system to derive specific MW amounts in cell F211, F257. Please see Attachment 9b_BAL-002-WECC-2.pdf Based upon the attached WECC guidelines, LADWP s system has maintained an Operating Reserve Spinning Reserve capacity of 300 MW to comply with the attached based upon its most severe single contingency requirement of 600 MW of which 50% or 300 MW is spinning reserve capacity. The other 50% or 300 MW is used to maintain an Operating Reserve Supplemental Reserve a Tab BM Tab 7 Factor Summary Please provide Statement BM as a stand-alone Word document. Cells D86-89, D127, D , D144, D Please provide a copy of the referenced LADWP Workpaper(s). Please see Attachment 10_Statement BM.docx. 1) Cells D86-89: Please see the Lines Gross Plant_End Bal tab in Attachment 11a_7 Factor Olive and Lines.xlsx 2) Cell D127: Please see the Olive Station Costs tab in Attachment 11a_7 Factor Olive and Lines.xlsx 3) Cells D : Please see the Olive P-T Allocation and Olive Station Costs tabs in Attachment 11a_7 Factor Olive and Lines.xlsx. 10

11 ing 4) Cell D144: Please see the Olive Station Costs tab in Attachment 11a_7 Factor Olive and Lines.xlsx. 5) Cells D Please see the Olive P-T Allocation and Olive Station Costs tabs in Attachment 11a_7 Factor Olive and Lines.xlsx. 11b Tab 7 Factor Summary Cell Please provide a copy of documentation or information provided by LADWP. (c) Cells D27-31, E177, E47-49, E53, E55-56, E59, E , G Please provide documentation. Please see Attachment 11b_FERC Depreciation Rates.pdf 11c Tab 7 Factor Summary Cells D27-31, E177, E47-49, E53, E55-56, E59, E , G Please provide documentation. 1) Cells D27-31: Please see to the Lines-GP,Accum Dep,O&M tab in Attachment 11a_7 Factor Olive and Lines.xlsx. 2) Cell E177: Please see Attachment 11.c.1_Trans Assets Subject to Property Tax.xlsx. 3) Cell E47-49: Please see Attachment 11.c.2_Transmission Miles.xlsx 4) E53: Please see Attachment 11.c.2_Transmission Miles.xlsx 11

12 ing 5) E55-56: Pending 6) E59: Please see Attachment 11.c.2_Transmission Miles.xlsx 7) E : See the Olive Station Costs tab in Attachment 11a_7 Factor Olive and Lines.xlsx. 12a 12b Tab Unit Tab Unit Cell B81 - Please provide data and documentation referenced in note [1]. Cell D94 - Please provide the basis for the estimate. 8) G : See the Olive Station Costs tab in Attachment 11a_7 Factor Olive and Lines.xlsx. The unit nameplate data and ratings were based on information included in the Gen AS Matrix tab of the model which was provided by LADWP. Financial information was sourced from the Source Investment tab of the model and is based on information included in LADWP s general ledger, except for the amounts shown for Intermountain Generating Station (IPP). The IPP amounts represent the 13 month average plant balances based on LADWP s share (66.79%) of IPP balances and are based on amounts from LADWP s IPP general ledger (see IPP Balances from LADWP IPP GL Attachment 12a.pdf). Cell D94 represents the estimated allocation factor of 35% used by LADWP in its reactive power rate calculation for prior years (see, e.g., Exhibit IX, Los Angeles Department of Water and Power, Allocation of Generators & Exciters to Reactive Supply & Voltage Control, FY (Test Year)) for the generator/exciter portion of its hydro resources that provide reactive power. As explained in the testimony supporting the calculation of LADWP s current investment in reactive power capability, 12

13 ing 13a Tab Fixed Charge Rate & VAR Alloc Cells C82-D83 - Please provide documentation. Mitsubishi Heavy Industries (MHI) information was used as a proxy to determine the 32% allocation factor for the generator/exciter portion of LADWP s steam turbine technology. Because a greater portion of the hydro unit s turbine generator/exciter costs would likely be attributable to the generator/exciter of a hydro unit as compared to a steam unit, the reactive investment calculation utilizes the estimated 35% allocation factor for LADWP s hydro units. Columns C82-83 are based on the table titled DWP Reactive Capability FY , Column X for each referenced unit or plant. The DWP Reactive Capability FY table was provided by LADWP and is attached with this data request response (see attached DWP Reactive Capability FY Attachment 13.xlsx). Columns D82-83 are based on the Gen AS Matrix tab, Column J, of the model for each of the units depicted. 13b Tab Fixed Charge Rate & VAR Alloc Cells C87-D93 - Please provide documentation. Columns C87-93 are based on the table titled DWP Reactive Capability FY , Column X for each referenced unit or plant. The DWP Reactive Capability FY table was provided by LADWP and is attached with this data request response (see attached DWP Reactive Capability FY Attachment 13.xlsx). Columns D87-D93 are based on the Gen AS Matrix tab, Column J, of the model for each of the units depicted. 13

14 ing 14a 14b 14c Transmission Planning Standards Transmission Planning Standards Transmission Planning Standards Please provide LADWP s most recent long-term transmission planning study. Please include a statement of LADWP s planning standards for transmission facilities. Please provide the most recent version of LADWP s Long-Term Transmission Assessment. The cost of service study and proposed rates are based on historical fiscal year The information requested was not used in a cost of service study or any analyses that produced the proposed rates. The cost of service study and proposed rates are based on historical fiscal year The information requested was not used in a cost of service study or any analyses that produced the proposed rates. The cost of service study and proposed rates are based on historical fiscal year The information requested was not used in a cost of service study or any analyses that produced the proposed rates. 15 Exhibit 200 Please provide an explanation and supporting documentation for the use of a hypothetical capital structure. A complete explanation for the use of a hypothetical capital structure begins on page 6, line 14 and continues through page 9, line 4 of Dr. Habr s direct testimony. 14

15 ing 16a Exhibits 300 and b Exhibits 300 and 400 Please provide explanations for all differences in depreciation rates between Exhibit 404 and Exhibit 302, page 6, Table 1-1. Please provide all workbooks, documentation, workpapers, and studies not already made public. Exhibit 404 is offered to demonstrate the recommended changes in depreciation rates based upon the NewGen Depreciation Study, as compared to the depreciation rates that were recommended in the 2003 Depreciation Study. The first column in Exhibit 404 shows the rates that were recommended in the 2003 Depreciation Study performed by Deloitte. The existing rates shown in Exhibit 302, page 6, Table 1-1 are composite rates which are calculated in Exhibit 302, pages 79-90, Schedule 3. The existing depreciation rates shown in Exhibit 302, Schedule 3 were calculated based on the actual depreciation accruals recorded by LADWP expressed as a percentage of gross plant in service for fiscal year ended June 30, These rates may differ from the depreciation rates recommended in the 2003 Depreciation Study because 1) LADWP did not adopt all of the recommendations in the 2003 Depreciation Study (e.g., the 2003 Depreciation Study recommended negative net salvage rates for production plant which LADWP did not implement), and 2) the existing depreciation rates shown in Exhibit 302, page 6, Table 1-1 reflect new plant assets installed since the 2003 Depreciation Study. Workpapers for the 2016 Depreciation Study (Exhibit 302) are attached. A copy of the 2003 Depreciation Study is also attached. 15

16 ing 17 Exhibit 400 Please provide the equivalent of Exhibit 403 for transmission facilities. Provided below is a similar graph to Exhibit 403 for transmission facilities. Please see attachment IR17 for complete answer. 18a Exhibit 500 Please provide an explanation for any differences between LADWP s Receiving Station Study and FERC s 7-Factor and Mansfield tests. [There are no differences between IR1b RS Study_Final_ and the results of the FERC 7-Factor and Mansfield tests.] 18b Exhibit 500 Page 15, lines 10-12: Please provide information that LADWP represented to nfront. [After nfront performed the OASIS query of transmission service offerings, nfront provided the list to LADWP and via a phone call LADWP told nfront that transmission service was offered over the same facilities in FY14/15. nfront has no additional documentation.] 16

17 ing 18c Exhibit 500 Page 20, lines 13, 15: Please provide copies of the 2000 RS Reallocation and Updated RS Reallocation studies. [See response to IR1. The studies are provided as IR1_a and IR1_b] 18d Exhibit 500 Page 22, line 15: Please provide a copy of nfront s Transmission Facility Determination. [See page 4 lines 6-9 of Exhibit DWP-500.] Study is available subject to NDA. 18e Exhibit 500 Page 27, lines 9-10: Please provide documentation for the reclassification of ANPP facilities from production to transmission. [Table S-1 of Exhibit DWP-503 lists the physical facilities associated with ANPP and nfront s determination that the ANPP facilities are integrated supported by the results of the power flow analyses and the related Seven Factor and the Mansfield Tests. 18f Exhibit 500 Please provide Exhibit DWP-503. [See response to IR18 (d)] 18g Exhibit In the OATT Transmission and Ancillary Services Rate Model (specifically, Tab AH of Exhibit DWP- 104), LADWP reclassifies LADWP s general ledger does not track gross plant, accumulated depreciation, O&M, depreciation expense, labor, or property taxes by the specific transmission line segments that were removed from transmission as a result of the 7 Factor test. As a result, a cost per mile methodology was used to develop the line segment costs that were 17

18 ing certain facilities based on the application of the 7- Factor and Mansfield tests. The costs of such reclassified facilities are shown in Tab AH. seek the same level of granularity regarding gross and net plant values that LADWP used in Exhibit to reclassify certain costs, for all distribution, transmission and production facilities. Please provide this information, in Excel format, for the test period, both gross and net of accumulated depreciation. Please provide documentation that non-la facilities have been properly excluded (e.g., Burbank s and removed from transmission and reclassified to other functions. The cost per mile calculations are shown in the 7 Factor Summary tab in Exhibit. Regarding jointly owned facilities, please refer to the attached PDF document entitled FY14-15 Power System Financial Statements Notes 5 & 6.pdf. Note (5), Jointly Owned Utility Plant, provides that the Power System has direct interests in several electric generating stations and transmission systems, which are jointly owned with other utilities. As of June 30, 2015 and 2014, utility plant includes the following amounts related to the Power System s ownership interest in each jointly owned utility plant (amounts in thousands, except as indicated). (emphasis added). The note goes on to assert that the Power System s proportionate share of the operating costs of the joint plants is included in the corresponding categories of operating expenses. Thus, LADWP s audited financial statements which are the basis for the general ledger values used to populate the cost of service model provided as Exhibit - do not record plant balances associated with the interests of third parties in jointly owned facilities but rather only the Power System s ownership interest in each jointly owned utility plant. Likewise, only the Power System s share of operating expenses associated with jointly owned facilities are included in the corresponding categories of operating expenses. Accordingly, there is no need to manually exclude or reallocate plant balances or expense associated with, for example, Burbank s and s shares of the PDCI, because such plant 18

19 ing s shares of the PDCI). balances and expenses are not recorded on LADWP s financial statements or general ledger in the first place. 18h Exhibit 500 Please provide the inservice dates of the Haskell Switching Station and the second Barren Ridge-Haskell Line. Haskell Switching Station September 2016 Barren Ride-Haskell Line October i Exhibit 500 Please provide all power flow studies used in the classification exercise. [The base and the fifteen power flow cases are provided in epc format. The results are also provided as well. This information is subject to NDA. 18j Exhibit 500 Please provide copies of any maps, diagrams, or similar materials provided by LADWP and relied on in the preparation of this testimony, included but not limited to: LADWP s transmission system map (34.5 kv and above) and LADWP s Blackstart Print (BS-1). The map provided by LADWP and used in the Transmission Facility Determination Assessment is subject to NDA for release. 19

20 ing 19a LADWP Tariff Section 13.5 Please explain why LADWP has excluded the following language from the pro forma OATT in the proposed LADWP OATT Section 13.5: To the extent the Transmission Provider can relieve any system constraint by redispatching the Transmission Provider's resources, it shall do so. Generation redispatch will be address with the February 21, 2017 tariff posting. 19b LADWP Tariff Section 13.5 Will LADWP redispatch its resources to relieve system constraints? Will redispatch be provide to some or all customers and/or loads? Please explain your answers and provide redispatch plans, formulas, studies, and related documentation. Generation redispatch will be address with the February 21, 2017 tariff posting. 19c LADWP Does LADWP redispatch its resources in any way to Generation redispatch will be address with the February 21, 2017 tariff posting. 20

21 ing Tariff Section 13.5 relieve system constraints for the benefit of its loads? Please explain your answer and provide redispatch plans, formulas, studies, and related documentation. 20a LADWP Tariff Section 15.4 Please explain why LADWP has exclude the following language from the pro forma OATT in the proposed LADWP OATT, Section 15.4: If the Transmission Provider determines that it cannot accommodate a Completed Application for Long-Term Firm Point-To- Point Transmission Service because of insufficient capability on its Transmission System, the Transmission Provider will use due diligence to provide redispatch from Generation redispatch will be address with the February 21, 2017 tariff posting. 21

22 ing its own resources until (i) Network Upgrades are completed for the Transmission Customer, (ii) the Transmission Provider determines through a biennial reassessment that it can no longer reliably provide the redispatch, or (iii) the Transmission Customer terminates the service because of redispatch changes resulting from the reassessment. A Transmission Provider shall not unreasonably deny self-provided redispatch or redispatch arranged by the Transmission Customer from a third party resource.(c) If the Transmission Provider determines that it cannot accommodate a 22

23 ing Completed Application for Long-Term Firm Point-To- Point Transmission Service because of insufficient capability on its Transmission System, the Transmission Provider will offer the Firm Transmission Service with the condition that the Transmission Provider may curtail the service prior to the curtailment of other Firm Transmission Service for a specified number of hours per year or during System Condition(s). If the Transmission Customer accepts the service, the Transmission Provider will use due diligence to provide the service until (i) Network Upgrades are completed for the Transmission Customer, 23

24 ing (ii) the Transmission Provider determines through a biennial reassessment that it can no longer reliably provide such service, or (iii) the Transmission Customer terminates the service because the reassessment increased the number of hours per year of conditional curtailment or changed the System Conditions. 20b LADWP Tariff Section 15.4 Please provide and explain any established protocols or published Business Practices showing how LADWP will incorporate self-supplies of redispatch or redispatch arranged by the Transmission Customer from a third party resource. If no such Generation redispatch will be address with the February 21, 2017 tariff posting. 24

25 ing protocols or Business Practices exist, please so state. 21a LADWP Tariff Section 19 Please explain why LADWP has excluded the following language from the pro forma OATT in the proposed LADWP OATT Section 19: Once informed, the Eligible Customer shall timely notify the Transmission Provider if it elects to have the Transmission Provider study redispatch or conditional curtailment as part of the System Impact Study. Generation redispatch will be address with the February 21, 2017 tariff posting. 21b LADWP Tariff Section 19 Will LADWP allow an Eligible Customer to request that LADWP study redispatch and conditional curtailment as part of the System Impact Study? If Generation redispatch will be address with the February 21, 2017 tariff posting. 25

26 ing not, please so state, and please provide documentation or justification for this position. 22a LADWP Tariff Section 19.3 Please explain why LADWP has excluded the following language from the pro forma OATT in the proposed LADWP OATT Section 19.3: The System Impact Study shall identify (1) any system constraints, identified with specificity by transmission element or flowgate, (2) redispatch options (when requested by an Eligible Customer) including an estimate of the cost of redispatch.... Generation redispatch will be address with the February 21, 2017 tariff posting. 22b LADWP Will LADWP identify system constraints by Generation redispatch will be address with the February 21, 2017 tariff posting. 26

27 ing Tariff Section 19.3 transmission element or flowgate in its System Impact Study? Please explain why or why not. 22c LADWP Tariff Section 19.3 If LADWP offers redispatch options will it include an estimate of the cost of redispatch in its System Impact Study? Please explain why or why not. Generation redispatch will be address with the February 21, 2017 tariff posting. 23 LADWP Tariff Section 19.7 Please explain why LADWP has excluded the following italicized language from the pro forma OATT in the proposed LADWP OATT Section 19.7: If the Transmission Provider determines that it will not have adequate transfer capability to satisfy the full amount of a Completed Application for Firm Point- To-Point Transmission Generation redispatch will be address with the February 21, 2017 tariff posting. 27

28 ing Service, the Transmission Provider nonetheless shall be obligated to offer and provide the portion of the requested Firm Point- To- Point Transmission Service that can be accommodated without addition of any facilities and through redispatch. 24 LADWP Tariff Section 5.2 Please explain why LADWP has excluded the following language from the pro forma OATT in the proposed LADWP OATT Section 5.2: 5.2 Alternative Procedures for ing Transmission Service: (i) If the Transmission Provider determines that the provision of transmission service requested The tariff was revised so that transmission service did not violate the private use restrictions associated with outstanding municipal bonds. 28

29 ing by an Eligible Customer would jeopardize the taxexempt status of any local furnishing bond(s) used to finance its facilities that would be used in providing such transmission service, it shall advise the Eligible Customer within thirty (30) days of receipt of the Completed Application. (ii) If the Eligible Customer thereafter renews its request for the same transmission service referred to in (i) by tendering an application under Section

30 ing of the Federal Power Act, the Transmission Provider, within ten (10) days of receiving a copy of the Section 211 application, will waive its rights to a request for service under Section 213(a) of the Federal Power Act and to the issuance of a proposed order under Section 212(c) of the Federal Power Act. The Commission, upon receipt of the Transmission Provider's waiver of its rights to a request for service under Section 30

31 ing 213(a) of the Federal Power Act and to the issuance of a proposed order under Section 212(c) of the Federal Power Act, shall issue an order under Section 211 of the Federal Power Act. Upon issuance of the order under Section 211 of the Federal Power Act, the Transmission Provider shall be required to provide the requested transmission service in accordance with the terms and conditions of this Tariff. 31

32 ing 25a LADWP Tariff Section Please provide studies and documentation for the increase in the Real Power Loss factors for the various facilities in Section The Real Power Loss factors have not changed since the last OATT revision. These Loss Factors were simply moved from business practice into the OATT document. 25b LADWP Tariff Section Please describe any changes in LADWP s system conditions that warrant these increases. See response to 25 (a) 26a LADWP Tariff Schedule 12. Please provide studies and documentation for the increase in the Generator Regulation and Frequency Service purchase requirement in Schedule 12. There is no Schedule 12 that requires a Generator Regulation and Frequency Service purchase requirement. However, if this question applies to Schedule 10, the study that supports the purchase requirement is the Reserve Requirement for 2014 VER Integration Study for LADWP (January 2017) table 5 that is provided in response to Information 9 (a). 26b LADWP Tariff Schedule 12. Please describe any changes in LADWP s systems conditions that support these increases in purchase requirements. 27a 12 CP Please explain the The Generator Regulation and Frequency Service purchase requirement in Schedule 10 is based upon the recent study mentioned in response to 26 (a) above. 32

33 ing proposed use of 12 CP loads in formulating proposed OATT rates, including ancillary service rates. 27b 12 CP Please provide any and all documents supporting LADWP s proposal to use 12 CP. 28a Ancillary Service Purchase Obligations Please provide all studies and documentation for the proposed ancillary service purchase obligations. 1. Schedule 3 - Regulation and Frequency Service Purchase Obligation: See Reserve Requirement for 2014 VER Integration Study for LADWP (January 2017) table 5 provided in response to Information 9 (a). 2. Schedule 5 - Operating Reserve-Spinning Reserve Service Purchase Obligation: See response to Information 9 (b). 3. Schedule 6 - Operating Reserve-Supplemental Reserve Service Purchase Obligation: See response to Information 9 (b). 4. Schedule 10 A - Generator Regulation and Frequency Service Purchase Obligation (Non dispatchable Generation): See Reserve Requirement for 2014 VER Integration Study for LADWP (January 2017) table 5 provided in response to Information 33

34 ing 9 (a). 28b Ancillary Service Purchase Obligations Please describe each ancillary service purchase obligation that has changed from the current LADWP OATT and rate schedules, and explain why these changes have occurred. 5. Schedule 10 B - Generator Regulation and Frequency Service Purchase Obligation (Dispatchable Generation). See Reserve Requirement for 2014 VER Integration Study for LADWP (January 2017) table 5 provided in response to Information 9 (a). The proposed ancillary service purchase obligations indicated in tab BL of the OATT model are based upon the responses to Information 28 (a). 28c Ancillary Service Purchase Obligations Exhibit, Tab BL. Please provide studies and documentation for the following cells: F44, F49, F54, F63, F67, F168, F211, F257, F334, F335, and F368. All the percentages and amounts indicated below are based upon the responses to Information 28 (a). F44 shows 3.496% and reflects the Schedule 3 Regulation and Frequency Service Purchase Obligation. F49 - shows 6.027% and reflects the Purchase obligation for Schedule 5 Operating Reserve-Spinning Reserve Service. F54 shows 6.027% Purchase obligation for Schedule 6 Operating Reserve-Supplemental Reserve Service. 34

35 ing F63 shows 9.278% Purchase Obligation for Schedule 10 Generator Regulation and Frequency Service (Non dispatchable Generation). F67 shows 3.496% Purchase Obligation for Schedule 10 B Generator Regulation and Frequency Service (Dispatchable Generation). F168 shows 174 MW Purchase Obligation for Schedule 3 Regulation and Frequency Purchase Obligation. F211 shows 300 MW and reflects the Purchase Obligation for Schedule 5 Operating Reserve-Spinning Reserve Service. F257 shows 300 MW and reflects the Purchase Obligation for Schedule 6 Operating Reserves -Supplemental Reserve. F334 shows 63 MW and reflects the Purchase Obligation for Schedule 10 A Generator Regulation and Frequency Service (Non dispatchable Generation). F335 shows 679 MW and reflects the incremental nameplate VER capacity used in Schedule 10 A Generator Regulation and Frequency and comes from the Reserve Requirement for 2014 VER Integration Study for LADWP (January 2017). F368 shows 174 MW and reflects the Purchase Obligation for 35

36 ing Schedule 10 B Regulation and Frequency Purchase Obligation (dispatchable generation). 29 Rate Design (, Tab BL) Please provide studies and documentation for the divisor of 4,160 in cells F103, F138, F185, F195, F229, F239, F275, F285, F318, F352, F362, F386, and F396. The divisor of 4,160 hours is discussed in Dave Cohen/Ed Lucero testimony for statement BL and reflects the number of On-Peak hours during the year. The use of the 4,160 hours for On-Peak service is recognized by FERC in: Northeast Utilities Service Company, 89 FERC 61,184, (1999). 30a Exhibit 104 Tab Gen AS Matrix Follow-up to response 2 Please identify the LADWP Power System staff who provided information on the provision of ancillary services by individual generating stations. Please provide any memoranda or internal communications related to this issue. 36

37 ing 30b Exhibit 104 Tab Gen AS Matrix Follow-up to response 2 For production plants not owned by LADWP, please provide copies of the contracts between LADWP and the plant owner in support of the assumptions that the plant provides specified ancillary services. 31a Exhibit Please identify the location and amounts of the following revenue credits in Exhibit 104: Payments to LADWP by the Intermountain Power Agency (IPA) to LADWP for services provided by LADWP as Operating Agent for the Intermountain 37

38 ing Power Plant (IPP). Payments to LADWP by longterm OATT customers, including Pasadena and Anaheim. Payments to LADWP by the Southern California Public Power Authority for services provided by LADWP associated with any facilities included in the revenue requirements for OATT rates, including ancillary service rates. Payments to LADWP by non- 38

39 ing LADWP owners of the Pacific Direct Current Intertie (PDCI) for services provided by LADWP as Operating Agent on the PDCI. 31b Exhibit Please provide documentation for each revenue credit, including amounts recorded in LADWP s GL or other system of accounts. 32 Exhibit 104 Tab AH Please provide invoices received from the Intermountain Power Agency (IPA) for all costs associated with the Intermountain Power Plant (IPP) that are included in the revenue requirement for any OATT rate in the test year. 39

40 ing 33a Exhibit 104 Tab BB Please confirm that the MW values in Column C are LADWP s retail load, and exclude the retail loads of. 33b Exhibit 104 Tab BB Please provide copies of the OATT transmission contracts associated with the amounts in Column D. 34 Exhibit 104 Tab Control Sheet Follow-up to response 1b: Please provide a copy of the September 9, 2016 study referenced in the December 20, 2016 memorandum from Neil Guglielmo to Michael Webster and Andrew Kendall. 35a Exhibit 104 Tab AL Follow-up to response 5d Please provide the name(s) of the energy suppliers, the amounts of energy 40

41 ing supplied, and the relevant contracts, per the original request. 35b Exhibit 104 Tab AL 35c Exhibit 104 Tab AL 35d Exhibit 104 Tab AL Follow-up to response 5d Please explain how prepaid energy was determined to be related to non-oatt service Follow-up to response 5d What is non-oatt service? Please provide the definition that LADWP uses to define this term, as opposed to a definition that another OATT provider may use Follow-up to response 5d Please explain how prepaid energy costs were allocated between OATT 41

42 ing and non-oatt services. 35e Exhibit 104 Tab AL Follow-up to response 5d Please explain how the $13.1 million prepaid to IPP is related to OATT service. 36a N/A Follow-up to 1b Please reconcile (i) the following statement from unnumbered page 5 of 1b and (ii) Table 1 in Tripp, Exhibit 500. Transformer within a RS connected to a high voltage line or bus (230kv < or 138kv) on the high side and connected to low voltage bus (34.5kv) on the low side is directly assigned to Distribution. 36b N/A

43 ing Follow-up to 1b Please identify, list and state the location of each transformer with a low-side voltage of 34.5 kv that was assigned to Transmission. 37 N/A Follow-up to 5e Please reconcile the statement in cell B147, Tab AL, with section D. (Allocation of Fuel Stock, rows of Tab AL). 38a Exhibit DWP Follow-up to responses 9a, 9b and 26a Tab BL Please explain the use of a document dated February 9, 2017 in the preparation of rates posted in January b Exhibit DWP Follow-up to responses 9a, 43

44 ing 104 9b and 26a Tab BL Please identify the specific location in the response to 9a that shows 174 MW of regulating reserves (see cell F168), or the data in the response to 9a that was used to derive 174 MW. If the latter, please provide both the required data and formulas. 38c Exhibit DWP Follow-up to responses 9a, 9b and 26a Tab BL In the response to 9a, please provide any studies and documentation that demonstrates that 50 MW is no longer the correct MW amount for Schedule 3. Please distinguish Schedules 3 and 10 in your response. Please provide any documentation that 44

45 ing LADWP was sanctioned by WECC/NERC for failure to meet reliability criteria using 50 MW during the test year. 38d Exhibit DWP Follow-up to responses 9a, 9b and 26a Tab BL Please identify the specific location in the response to 9a that shows 63 MW of generator regulating reserves (see cell F334), or the data in the response to 9a that was used to derive 63 MW. If the latter, please provide both the required data and formulas. 38e Exhibit DWP Follow-up to responses 9a, 9b and 26a Tab BL Please explain how WECC Standard BAL-002-WECC-2 was used to develop

46 ing MW of spinning reserve requirements and 300 MW of supplement reserve requirements. 38f Exhibit DWP Follow-up to responses 9a, 9b and 26a Tab BL Please explain why the values in cells F168 and F368 are the same, and provide supporting data, studies, and documentation that demonstrate that the RFR services provided are the same for OATT transmission customers and dispatchable generators. 38g Exhibit DWP Follow-up to responses 9a, 9b and 26a Tab BL Please explain why the 46

47 ing value in cell F334 for nondispatchable resources is less than the value in cell F368 for dispatchable resources, and provide supporting data, studies and documentation. 39a LADWP Tariff Section Please explain why LADWP has removed from the definition of Third- Sale, in proposed Tariff Section 1.41, the reference to a sale for resale to a Power Purchaser that is not designated as part of Network, which is included in pro forma Tariff Section b LADWP Tariff Section Does LADWP view BWP and GWP as being part of the LADWP network? Please explain your answer: if so, why; if not, why not. 47

48 ing 40a LADWP Tariff definitions Please explain why LADWP has not included in its proposed tariff a definition of the Transmission Provider's Monthly Transmission System Peak, which is defined in the pro forma Tariff Section 1.51 as [t]he maximum firm usage of the Transmission Provider's Transmission System in a calendar month. 40b LADWP Tariff definitions Has LADWP calculated its Monthly Transmission System Peak as defined in the pro forma tariff? If so, please provide the calculation for each month in the test year. If not, please explain why not. 40c LADWP If LADWP does calculate the equivalent of its 48

49 ing Tariff definitions Monthly Transmission System Peak, please describe what that calculation includes. How does LADWP s definition of this concept differ from the pro forma OATT? 41a LADWP Tariff Section Please explain why LADWP has not included in its proposed tariff the following language from Section 2.1 of the pro forma OATT. 2.1 Initial Allocation of Available Transfer Capability: For purposes of determining whether existing capability on the Transmission Provider's Transmission System is adequate to accommodate a request for firm service under this Tariff, all 49

50 ing Completed Applications for new firm transmission service received during the initial sixty (60) day period commencing with the effective date of the Tariff will be deemed to have been filed simultaneously. A lottery system conducted by an independent party shall be used to assign priorities for Completed Applications filed simultaneously. All Completed Applications for firm transmission service received after the initial sixty (60) day period shall be assigned a priority pursuant to Section b LADWP Tariff Section Please explain how LADWP initially allocates Available Transfer Capability ( ATC ) in lieu of the language 50

51 ing quoted above from Section 2.1 of the pro forma OATT and provide all documents, data, and analyses that support or explain this allocation. 41c LADWP Tariff Section Please explain how LADWP calculates Total Transfer Capability ( TTC ) and provide all documents, data, and analyses that support or explain this calculation for each posted path. 41d LADWP Tariff Section Please explain how LADWP calculates Capacity Benefit Margin ( CBM ) and provide all documents, data, and analyses that support or explain this calculation for each posted path. 51

52 ing 41e LADWP Tariff Section Please explain how LADWP calculates Transmission Reliability Margin ( TRM ) and provide all documents, data, and analyses that support or explain this calculation for each posted path. 41f LADWP Tariff Section Please provide references in LADWP s Tariff documents where ATC, TTC, CBM, and TRM are defined and/or addressed. 41g LADWP Tariff Section Please provide all data used in calculating ATC for each posted path, including TTC, existing transmission commitments, CBM and/or TRM, and provide a table showing ATC on all posted paths for as many years into the future as possible, on monthly basis as available. 52

53 ing This request does not mean that LADWP should calculate new amounts or projections of ATC, but that LADWP should provide what has already been calculated but is not posted. 42 LADWP Tariff Please explain why LADWP has not included in its proposed tariff the following language from Section 5.2 of the pro forma OATT. 5.2 Alternative Procedures for ing Transmission Service: (i) If the Transmission Provider determines that the provision of transmission service requested by an Eligible 53

54 ing Customer would jeopardize the tax-exempt status of any local furnishing bond(s) used to finance its facilities that would be used in providing such transmission service, it shall advise the Eligible Customer within thirty (30) days of receipt of the Completed Application. (ii) If the Eligible Customer thereafter renews its request for the same transmission service referred to in (i) by tendering an 54

55 ing application under Section 211 of the Federal Power Act, the Transmission Provider, within ten (10) days of receiving a copy of the Section 211 application, will waive its rights to a request for service under Section 213(a) of the Federal Power Act and to the issuance of a proposed order under Section 212(c) of the Federal Power Act. The Commission, upon receipt of the Transmission 55

56 ing Provider's waiver of its rights to a request for service under Section 213(a) of the Federal Power Act and to the issuance of a proposed order under Section 212(c) of the Federal Power Act, shall issue an order under Section 211 of the Federal Power Act. Upon issuance of the order under Section 211 of the Federal Power Act, the Transmission Provider shall be required to provide the requested transmission service in accordance with the terms and conditions of this Tariff. 43 LADWP Tariff Sections 7.2, 17.3, 17.4, Please explain why LADWP requires customers to pay interest on delinquent amounts but LADWP is not required to pay interest on 56

57 ing 17.6, 19.1, 19.4, and amounts customers pay for deposits in Sections 17.3, 17.4, 17.6, 19.1, 19.4, and a LADWP Tariff Section Please explain why LADWP has not included in its proposed tariff Section 19.9 the following language from Section 19.9 of the pro forma OATT Penalties for Failure to Meet Study Deadlines: Sections 19.3 and 19.4 require a Transmission Provider to use due diligence to meet 60-day study completion deadlines for System Impact Studies and Facilities Studies. (i) The Transmission Provider is required to file a notice with the Commission in the event that more than twenty (20) percent of non- Affiliates 57

58 ing System Impact Studies and Facilities Studies completed by the Transmission Provider in any two consecutive calendar quarters are not completed within the 60-day study completion deadlines. Such notice must be filed within thirty (30) days of the end of the calendar quarter triggering the notice requirement. (ii) For the purposes of calculating the percent of non-affiliates System Impact Studies and Facilities Studies processed outside of the 60-day study completion deadlines, the Transmission Provider shall consider all System Impact Studies and Facilities Studies that it completes for non-affiliates during the calendar quarter. The 58

59 ing percentage should be calculated by dividing the number of those studies which are completed on time by the total number of completed studies. The Transmission Provider may provide an explanation in its notification filing to the Commission if it believes there are extenuating circumstances that prevented it from meeting the 60-day study completion deadlines. (iii) The Transmission Provider is subject to an operational penalty if it completes ten (10) percent or more of non-affiliates System Impact Studies and Facilities Studies outside of the 60-day study completion deadlines for each of the two calendar quarters immediately 59

60 ing following the quarter that triggered its notification filing to the Commission. The operational penalty will be assessed for each calendar quarter for which an operational penalty applies, starting with the calendar quarter immediately following the quarter that triggered the Transmission Provider s notification filing to the Commission. The operational penalty will continue to be assessed each quarter until the Transmission Provider completes at least ninety (90) percent of all non- Affiliates System Impact Studies and Facilities Studies within the 60-day deadline. (iv) For penalties assessed in accordance with 60

61 ing 44b LADWP Tariff Section 19.9 subsection (iii) above, the penalty amount for each System Impact Study or Facilities Study shall be equal to $500 for each day the Transmission Provider takes to complete that study beyond the 60-day deadline Please explain why LADWP has not included any penalties for its failure to meet study deadlines. 44c LADWP Tariff Section What recourse will transmission customers have if LADWP fails to meet the 60 day study completion for a System Impact Study and Facilities study? 45a Exhibit DWP- 500 page 19, lines : LADWP provided a power flow case representative of its FY14/15 configuration. 61

62 ing 9-13 nfront reviewed and modified the case, as necessary, to approximate the transmission system outside of the LADWP Balancing Authority Area ( BAA ) (e.g., validating the portions of the Colorado River to Devers transmission line which were in service during that time period). Please describe in general non-ceii terms the LADWP provided case in comparison to standard WECC cases. For example, did LADWP provide a WECC case that had been modified to include lower voltage? Please note that this is not a request for CEII information. 62

63 ing 45b Exhibit DWP- 500 page 19, lines : LADWP provided a power flow case representative of its FY14/15 configuration. nfront reviewed and modified the case, as necessary, to approximate the transmission system outside of the LADWP Balancing Authority Area ( BAA ) (e.g., validating the portions of the Colorado River to Devers transmission line which were in service during that time period). Does approximate mean something other than the typical representation of the transmission system outside of the LADWP Balancing Authority Area found in standard WECC 63