16A-0396E
ON BEHALF OF
TABLE OF CONTENTS
LIST OF ATTACHMENTS
3 I. SUMMARY OF TESTIMONY
7 10, 2018.
11 Company of Colorado’s (“PSCO”) modeling methodology for the “Colorado Energy Plan
14 A. Staff recommends that the baseline Strategist run used to evaluate bids in Phase II be
15 optimized using gas, wind, and solar resources through the entire planning period and
16 that pricing for generic renewable resources be updated using pricing from the bids
17 received on November 28, 2017.1 Staff states that PSCO’s decision not to let the model
18 select renewable resources in the model planning period after the Resource Acquisition
19 Period (“RAP”) may create a bias in favor of the CEP Portfolio.2 I explain in my Cross
20 Answer testimony that Staff has identified a reasonable concern with PSCO’s model
21 insofar as the model’s exclusion of renewable resources in the post-RAP period of the
3 I also explain that, even if the Commission were to adopt Staff’s recommendation, this
4 would not remedy all of PSCO’s biases in the modeling. Staff’s concern about the bias in
5 the modeling relates to the variable energy savings of the CEP Portfolio. My Answer
6 Testimony also addresses biases in the modeling, but my concerns relate to biases in the
7 fixed costs of the business-as-usual Baseline Portfolio run and the CEP Portfolio run —
8 e.g., PSCO’s decision to, among other problems, (1) ignore recovery of Comanche Units
9 1 and 2 sunk costs in the CEP Portfolio, (2) hard code an expensive combined-cycle gas
10 turbine in the Baseline Portfolio run that is uniquely loaded with $100 million of
11 transmission costs, and (3) allocate a significant amount of zero-cost long-term purchase
12 power capacity to the CEP Portfolio run. I explain that Staff’s recommendation is in
14 Further, I point out that the need for a rulemaking to examine how the Commission
15 should examine the costs and benefits of early retirement of generation units is further
16 supported by the revelation that Staff and PSCO are in private negotiations around how
17 best to model the CEP Portfolio. In response to discovery,3 Staff states that it “intends to
19 solutions.”4 Given that the hearing is occurring in less than two weeks, it is unclear how
20 other parties will be able to adequately analyze and vet whatever modeling solutions, if
21 any, Staff and PSCO agree upon. Therefore, before committing ratepayers to pay up to
2 660 MW of coal generation, there is a need for a public process to ensure that the solution
4 Finally, I note that Staff’s testimony does not address or in any way change my
6 provisions and to include all of the hold harmless provisions in my Supplemental Answer
7 Testimony if the Commission decides to proceed with the evaluation of the CEP
8 Portfolio.
14 A. Staff witness Sharon Podein recommends that the Commission adopt an alternative
15 methodology for creating a baseline Strategist modeling run for the CEP.5 Staff objects
16 to PSCO’s approach for modeling resources in the years subsequent to the Resource
17 Acquisition Period (“RAP”) because PSCO hardcoded the model so that it would not
18 select renewable resources to fill capacity need for the years outside the RAP. Staff
19 recommends that the baseline Strategist run that will be used to evaluate bids and create
20 portfolios for Commission consideration be optimized to permit gas, wind, and solar
21 resources for the entire planning period, not just the RAP.6
2 The Company has proposed to evaluate bids to the competitive solicitation over a
3 planning period extending from June 1, 2016 through June 1, 2054 (“Planning Period”),
4 so the years outside the RAP are 2025 through 2054.8 This period after the RAP is also
7 A. Relative to a portfolio optimized with renewable resources, it can drive up the overall
8 energy costs for the Planning Period and, as a result, artificially inflates the energy cost
9 savings associated with the addition of zero-fuel-cost renewable resources during the
10 RAP. Put another way, it makes it likely the energy cost savings from the CEP look
12 Q. PLEASE EXPLAIN.
13 A. If the Strategist model chooses only thermal resources to fill PSCO’s resource needs in
14 the resource tail period (i.e., 2025 – 2054), the avoided energy cost on the system will
15 likely be higher relative to a model that allows renewable resources in the resource tail
16 period. This is because thermal resources have energy costs and renewable resources do
17 not have any fuel costs. Thus, by artificially driving up energy costs for the resource tail,
18 PSCO drives up the overall avoided energy cost for the entire Planning Period. As a
19 result, the CEP will look like it saves more in energy costs than is reasonable considering
20 that, in reality, renewable power can be considered for future resource needs after the
21 RAP.
5 A. Generally, yes, but for more reasons than stated by Staff. Staff states that it is important
6 that “the analysis of any cost savings associated with the CEP is conducted in a rational,
7 transparent, and unbiased manner.”10 I agree with Staff’s sentiment. PSCO should not
8 be allowed to analyze the costs and benefits of the CEP using a model that biases the
9 results of the Strategist optimization runs in favor of the CEP. However, Staff did not
13 A. Staff notes that PSCO only built the “fixed tail of generic resources”11 with generic
14 thermal resources, rather than optimizing the generation outside the RAP using thermal
15 and renewable resources. Staff notes that a “consistent resource tail ensures that different
16 competitive bids will be evaluated on a level playing field with similar assumptions
17 regarding the future resource mix on the Public Service System.”12 Staff’s concerns go to
18 the energy savings that would accrue to resources added in the RAP.
19 I share Staff’s concern about biases introduced into the modeling and the need for the
20 Commission to use consistent resource tails in the models to avoid these biases. It is
21 important, however, for the Commission to understand that modeling biases can impact
2 Testimony relate to biases in the fixed costs used by PSCO, not energy costs. The
3 modeling errors and biases I discuss in my Answer Testimony are therefore incremental
5 As I stated in my testimony, PSCO biases the fixed costs comparison of the cases by
6 failing to account for the recovery of the sunk cost of Comanche Units 1 and 2 in the CEP
7 Portfolio. PSCO also biases the costs of the business-as-usual case (called the Baseline
9 unreasonably expensive combined-cycle gas turbine (“CCGT”) in the resource tail. The
10 CEP model run, on the other hand, did not include the CCGT and instead filled the CEP’s
11 resource tail with a significant amount of zero-cost long-term power purchases and higher
12 energy cost combustion turbines. PSCO further biases the costs of the Baseline Portfolio
13 run by adding $100 million of transmission cost to the CCGT unit, whereas no other
14 resource type in the modeling runs gets assigned transmission costs. Since the CCGT
15 does not exist in the CEP modeling run, this fixed cost bias in favor of the CEP Portfolio
19 ENERGY SAVINGS?
20 A. Yes. Because of its relatively low heat rate and variable operations and maintenance
21 expense, a CCGT is the only other potentially competitive resource that can lead to lower
22 energy costs in the resource tail period. If PSCO hardcodes the model so that the generic
2 heat rate combustion turbines are more likely to be selected in the optimization for the
3 resource tail. This leads to higher energy costs in the Baseline Portfolio, and therefore
8 A. Yes. The heat rate of a combustion turbine is approximately 10 MMBtu/MWh while the
9 heat rate of a new CCGT is approximately 6.8 MMBtu/MWh, so the heat rate differential
10 is 3.2 MMBtu/MWh.13 Thus, during any period that the CCGT could have displaced the
11 combustion turbine, the avoided energy cost is inflated by 47%.14 Put another way, at
12 $4/MMBtu gas, if the combustion turbine were the unit setting the avoided energy cost
13 instead of the CCGT, the avoided energy cost would be inflated from $27.2/MWh to
14 $40/MWh.15
17 A. Yes. As I noted in my Answer Testimony, PSCO split the retirement of Comanche Units
18 1 and 2 across the RAP and introduced utility ownership requirements on gas-fired
19 resources, thereby making it difficult for a modern CCGT to economically bid (e.g., the
first years after the RAP period for the base gas price forecast.
Cross Answer Testimony of Charles S. Griffey
Page 9
1 need that a third-party CCGT can fill is considerably lower than the size of a new, low
2 heat rate CCGT). This means that renewable resources are the only low cost resources
3 that can capture the potentially inflated energy savings that Staff highlighted.
6 A. While I have no theoretical issue with optimizing the tail end resources by including
7 renewable resources as suggested by Staff, I think there are realistic limitations that
8 deserve a fuller airing than can be provided in the short-time available in this case. For
9 instance, Staff does not suggest how to address the issue of how much thermal generation
10 needs to be on the system in the resource tail period after the RAP to ensure reliability,
12 case, how to uniformly include transmission interconnection costs among thermal and
13 renewable generation, and how to force the model to ensure such constraints are met.
14 The point of having a long-term resource tail end is to allow the energy savings of
15 resources in the RAP to be reasonably estimated on a level playing field. The long-term
16 resource tail should not allow the utility to control the outcome of the analysis by
17 inserting different fixed costs in the various portfolios, nor by inflating energy cost
18 savings. If the issues raised above (and the ones raised in my Answer Testimony) are not
19 appropriately resolved, then the Commission should have no confidence in the cost
20 analyses being performed as part of the CEP proposal. That is why the Commission
2 generation.
4 A. Apparently not yet. For instance, PSCo 4-2 asks Staff how it proposes the Company
5 impose flex resource limits or similar reliability metrics in the creation of the “baseline”
14 A. Yes. That response was filed January 23, 2018, or only two weeks before the hearing in
15 this case. That does not leave time for there to be a transparent and full discussion of
16 whatever modeling solution that Staff and PSCO negotiate, if any, and it certainly leaves
17 no time for third party analysis of any modeling solution. The CEP Portfolio, if
18 approved, will commit ratepayers to paying billions of dollars. The decision will not be
19 sound if it is based on modeling that is cobbled together between two parties as the clock
20 runs down.
23 A. No. Staff does not address utility ownership percentages, the need to hold PSCO to its
2 close to those used by PSCO in its Low Cost Renewables case, and do not change my
3 findings that the correction of the biases in PSCO’s analysis shows that adoption of the
5 III. CONCLUSION
7 A. The CEP Portfolio as it has been presented by PSCO is harmful to the ratepayers of
8 Colorado. The proposed early retirement of Comanche Units 1 and 2 allows the utility to
9 make numerous assumptions that dramatically bias the evaluation of potential resources
10 in favor of the CEP Portfolio. These biases I address in my Answer Testimony concern
11 inflated fixed costs that favor the CEP Portfolio. Staff’s concern is that a lack of
12 renewable resources after the RAP will inflate the energy savings associated with
13 renewable resources added during the RAP, thereby inflating the purported energy
14 savings of the CEP Portfolio. Similarly, the inflated cost of the generic CCGT results in
15 more combustion turbines in the resource tail, which also inflates the purported energy
16 savings of the CEP Portfolio. Any inflated energy savings are in addition to the $429
18 Combined with the utility ownership targets, it appears that the CEP Portfolio is simply a
19 way for the stipulating parties to advantage themselves at the expense of customers. In
20 order to mitigate the potential harm to ratepayers, I recommend the Commission not
21 consider the CEP Portfolio or any proposal like the CEP Portfolio until after it conducts a
22 rulemaking on how to properly evaluate the costs and benefits of early retirement of
2 in my Answer Testimony.
4 A. Yes.