BEFORE THE PUBLIC UTILITIES COMMISSION OF NEVADA Application ofNevada Power Company d/b/a NV Energy for ) approval ofthe first amendment to the 2013-2032 Integrated ) Resource Plan and the Energy Supply Plan Update for 2015 to ) include an initial emissions reduction and capacity replacement ) plan. )



## _________________________________________ ) Application ofNevadaPower Company d/b/a NV Energy for ) approval ofthe second amendment to the 2013-2032 Integrated ) Resource Plan and Action Plan as itrelates to a new ) 500kV/230kV autotransformer at the existing Harry Allen ) substation. )

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### ) Docket No. 14-05003

Docket No. 14-06022

At a general session ofthe Public Utilities Commission ofNevada, held at its offices on October 27, 2014. PRESENT: Chairman Alaina Burtenshaw CommissionerRebecca D. Wagner Commissioner David Noble Assistant Commission Secretary Breanne PotterDOCUMENT REVIEWAND APPROVALROUTING DRAFTED BY: 

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### TABLE OF CONTENTS 

### I. INTRODUCTION•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••

### 3 

### II. SUMMARY •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••

### 3 III. PROCEDURAL HISTORY••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••

### 3 IV. ENERGY SUPPLy

**~AN** UPDATE•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••

### 7 A. LegalFramework........................................................................................................7 B. Energy SupplyPlanUpdate Stipulation...................................................................S 

# v. FIRSTAMENDMENT TO THE

### 2013-2032IRP..........................................................................ll 

### A. Background .................................................................................................................11 B. 

### LoadForecastandFuel and Purchased PowerPrice Forecasts ............................11 C. SupplyPlan andERCRAction Plan.........................................................................13 i. Legal Framework............................................................................................13 ii. Emissions Reduction.......................................................................................14 iii. CapacityReplacement....................................................................................22 VI. SECONDAMENDMENT TO THE

### 2013-2032IRP......................................................................81 

### A. Background.................................................................................................................81 B. HarryAllen Autotransformer...................................................................................82Docket Nos. 14-05003 & 14-06022 Page 3 

### ORDER The Public Utilities Commission ofNevada ("Commission") makes the following findings offact and conclusions oflaw: 

### I. INTRODUCTION Nevada Power Company d/b/a NV Energy ("NevadaPower" or "Company") filed an Application with the Commission, designated as Docket No. 14-05003, for approval ofthe first amendment to the Action Plan ofthe 2013-2032 Integrated Resource Plan ("IRP") and the Energy Supply Plan ("ESP") Update for 2015 to include an initial emissions reduction and capacity replacement plan ("ERCRPlan1") ("First Amendment Application"). Subsequently, Nevada Powerfiled an Application, designated as Docket No. 14-06022, for approval ofthe second amendment to the 2013-2032 IRP and Action Plan as it relates to a new 500-kilovolt ("kV")/230kV autotransformer ("Harry Allen Transformer") at the existing Harry Allen substation ("Second Amendment Application"). 

### II. SUMMARY The Commission accepts the Stipulation, attached hereto as Attachment 1, and grants the 2015 ESP Update portion ofthe First AmendmentApplication as modifiedby the Stipulation. The Commission deems certain portions ofthe ERCRPlan inadequate and recommends to Nevada Powermodifications to the Plan as presented in this Order. The Commission grants the Second Amendment Application as providedin this Order. 

### III. PROCEDURAL HISTORY

• On May 1, 2014, NevadaPower filed an Application, designated as Docket No. 14-05003, for approval ofthe first amendment to the Action Plan ofthe 2013-2032 IRP and the ESPUpdate for 2015 to include an initial ERCR Plan. The Application was filed pursuant to Chapters 703 and 704 ofthe Nevada Revised Statutes ("NRS") and the NevadaAdministrative Code ("NAC"), including, but not limited to, NRS 704.7311 et seq., NRS 704.736 et seq., NAC 704.9005 et seq., and Regulation LCB File No. R131-13. Pursuant to NRS 703.196 and NAC 703.5274, Nevada Powerrequests that certain information ithas filed under seal be deemed confidential and not be publically disclosed for a period offive (5) years.
• The Regulatory Operations Staffofthe Commission ("Staff') participates as a matter ofright pursuantto NRS 703.301. Ill

1TheERCRPlan is also referred to as the Plan, the Preferred Plan and Case C.Docket Nos. 14-05003 & 14-06022 Page4

• On May 8, 2014, the Commission issued a Notice ofApplication and Notice ofPrehearing Conference in DocketNo. 14-05003.

• OnMay 8, 2014, the Attorney General's Bureau ofConsumerProtection ("BCP") filed a Notice ofIntent to Intervene pursuant to NRS 228.360 in Docket No. 14-05003.
• On May 15, 2014, the Presiding Officerissued a Procedural Orderin DocketNo. 14-05003.
• OnMay 16, 2014, Nevada Power, in response to the Procedural Order, provided the Commission with a USB electronic drive containing one electronic copy ofthe unredacted confidential informationpreviously filed inDocketNo. 14-05003.
• On May 28, 2014, Interwest Energy Alliance ("lnterwest") filed a Petition for Leave to Intervene ("PLTI") in Docket No. 14-05003.
• On May 29, 2014, Federal Executive Agencies ("FEA") filed a Notice ofIntent to Intervene in DocketNo. 14-05003.

• On May 30, 2014, Nevada Powerfiled an Addendum to the Application containingredacted and revised confidential versions ofseveral confidential exhibits previously filed in Docket No. 14-05003.

• On May 30, 2014, Abengoa Solar, LLC ("Abengoa") filed a PLTI in Docket No. 14-05003.
• On June 2, 2014, Bombard Renewable Energy, a division ofBombardElectric LLC ("Bombard"), Sierra Club ("Sierra"), Enel Green Power North America, Inc. ("EGPNA"), Nevadans for Clean Affordable Reliable Energy ("NCARE"), Griffith EnergyLLC ("Griffith"), and Switch, Ltd. ("Switch") filed PLTis; Boyd Gaming Corporation, Las Vegas Sands Corp., MGM Resorts International, Station Casinos, Caesars Entertainment Corporation, and Wynn Las Vegas, LLC (collectively, the "Southern Nevada Hotel Group" or "SNHG") filed a Joint PLTIin Docket No. 14-05003.

• On June 10, 2014, Interwest filed a Request to BeExcused from Prehearing Conference; Ormat Technologies, Inc. and Ormat Nevada Inc. ("Ormat") filed a Late-Filed PLTIin Docket No. 14-05003.

• On June 11, 2014, the Presiding Officerheld a prehearing conference in DocketNo. 14-05003, in which Nevada Power, FEA, Abengoa, Bombard, BCP, Sierra, EGPNA, NCARE, Griffith, Switch, SNHG, Staff, and Ormat participated; Interwest filed a Notice ofNon-Resident Counsel Pursuantto NAC 703.510.

• On June 16, 2014, NevadaPowerfiled its Second Amendment Application with the Commissionrequesting approval ofthe second amendment to its 2013-2032 IRP including approval ofthe construction ofthe Harry Allen Transformer at the existing Harry Allen Substation. The Application was filed pursuant to Chapters 703 and 704 ofthe NRS and the NAC, including, but not limited to, NRS 704.7311 et seq., NRS 704.736 et seq., and NACDocket Nos. 14-05003 & 14-06022 704.9005 et seq. In the SecondAmendment Application, NevadaPower also seeks to consolidate Docket No. 14-06022 with Docket No. 14-05003. Page 5

• OnJune 17, 2014, the Commission issued a number oforders granting all the PLTis filed in Docket No. 14-05003.

• On June 18, 2014, the Commission issued a Notice ofApplication and Notice ofPrehearing Conference in Docket No. 14-06022 and Procedural Order No.2 in Docket No. 14-05003.
• On June 27, 2014, Nevada Powerfiled First Amendment to the Application to Approve Amendment to Resource Plan and Energy Supply Plan Update to Recognize Emissions Reduction and Capacity Replacement Plan- Revised Prayer for Reliefin Docket No. 14-05003.
• On June 30, 2014, the Attorney General's Bureau ofConsumer Protection ("BCP") filed a Notice ofIntent to Intervene pursuant to Chapter 228 ofthe NRS in Docket No. 14-06022.
• On July 1, 2014, BCP, Sierra, Staff, Nevada Power, and Interwest filed with the Commission DataRequest Status Reports in accordance with the Procedural OrderNo.2 in Docket No. 14- 05003.

• On July 2, 2014, Griffith, SNHG, Abengoa, and Ormatfiled with the Commission Data Request Status Reports in accordance with the Procedural Order No.2 in Docket No. 14-05003.
• On July 3, 2014, NCARE filed with the Commission a Data Request Status Report in accordance with the Procedural OrderNo.2 in Docket No. 14-05003. Nevada Power filed Second Addendum to the Application in Docket No. 14-05003 containingpreviously omitted exhibits to the ERCR filing.

• On July 8, 2014, Stafffiled two identical letters with the Commission in Docket Nos. 14-05003 and 14-06022 advising that it has no objection to NevadaPower's request for consolidation of Docket Nos. 14-05003 and 14-06022. Griffith filed a letter in Docket No. 14-05003 informing the Commission that it does not intend to file comments in response to Nevada Power's request for consolidation. Bombard filed a letterin Docket No. 14-05003 containing a datarequest status report in accordance with the Procedural Order No.2in Docket No. 14-05003. Ormat filed a PLTI in Docket No. 14-06022.

• On July 16, 2014, the Presiding Officerheld aprehearing conference in DocketNo. 14-06022, in which Staff, BCP, Nevada Power, and Ormat participated.
• On July 21, 2014, the Presiding Officerissued Procedural Order No.3 consolidating Docket Nos. 14-05003 and 14-06022 and adopting the procedural schedule previously established for Docket No. 14-05003.

• On July 28, 2014, FEA filed a Substitution ofCounsel notice with the Commission.
• OnJuly 29, 2014, the Commission issued a Notice ofHearing.Docket Nos. 14-05003 & 14-06022 Page 6

• On July 31, 2014, BCP filed a DataRequest Status Report.

• On August 1, 2014, SNHG, Staff, Nevada Power, Ormat, Griffith, FEA, Sierra, and Abengoa filed DataRequests Status Reports.

• On August4, 2014, Bombard, Interwest, and NCARE filed Data Requests Status Reports.

• On August 5, 2014, Switch filed a DataRequest Status Report.

• On August 8, 2014, Nevada Powerfiled Third Addendum to Docket No. 14-05003 Application withdrawing its earlier request for confidential treatment ofpage 215 ofvolume 4 ofthe Application and providing an unredacted version ofthe page.
• On August 22, 2014, Griffith filed Prepared Direct Testimony ofTina C. Lee.

• On August 25,2014, BCP filed Prepared DirectTestimonies ofDale Stransky, PatrickMorton, and Jerry Mendl; Sierrafiled Comments; NCARE filed Prepared DirectTestimony ofNancy Kelly; SNHG filed Prepared DirectTestimony ofMark Garrett; Ormat filed Prepared Direct Testimony ofWilliamMonsen; and Stafffiled Prepared Direct Testimonies ofFredBuck, Percival Lucban, Gary Cameron, AdamDanise, Paul Maguire, Yasuji Otsuka, SwethaVenkat, Anita Castledine, and Karen Olesky.

• On September 2, 2014, Nevada Power, Sierra, NCARE, Switch, BCP, SNHG, Ormat, Griffith, and Stafffiled DataRequest Status Reports.

• On September 3, 2014, Interwest filed a DataRequest Status Report.

• On September 8, 2014, Nevada Power filed Prepared Rebuttal Testimonies ofDavid Harrison, BrianWhalen, James Doubek, Robert Kocour, Anita Hart, Kevin Geraghty, Stacey Kusters, and Shawn Elicegui.

• On September 12, 2014, Stafffiled Revised DirectTestimonies ofPaul Maguire and Adam Danise; BCPfiled Erratas to Prepared Direct Testimonies ofDale Stransky and PatrickMorton. Nevada Powerfiled a Stipulation resolving all ESP issues in Docket No. 14-05003.2

• On September 15, 2014, Ormat filed an Errata to Prepared DirectTestimony ofWilliam Monsen, andNevada Power filed an additional signatory page to the Stipulation. 

### Ill

2 Nevada Power, BCP, and Staffare the only parties who have filed testimony regarding the ESP Update. Staff, BCP, Nevada Power, NCARE, Griffith, SNHG, Ormat, Switch, and Abengoa signed the Stipulation. FEA, Interwest, and Bombard represented at the September 15, 204, hearing, on the record, that they did not oppose the Stipulation. (Transcript at 19.) Nevada Power represented on the record, at stated EGPNA's request, thatEGPNA did not oppose the Stipulation either. (!d. at 17.) Sierra did notparticipate in the hearing. (!d. at 19.)Docket Nos. 14-05003 & 14-06022 Page7

• On September 15-17,2014, the Commission held a hearing. Abengoa, BCP, Bombard, FEA, Griffith, NCARE, NevadaPower, Ormat, SNHG, and Staffmade appearances. Atthe conclusion ofthe hearing, the Presiding Officer granted an oral motion to accept Exhibit Nos. 1- 94 and C1-15 into the record as evidencepursuant to NAC 703.730.

• On September 23,2014, NevadaPowerlate-filed Exhibit Nos. 72 and C-10.

• On September 29, 2014, NevadaPowerlate-filed Exhibit No. 34.

• On October 1, 2014, Abengoa, BCP, Griffith, NevadaPower, Ormat, SNHG, and Switch filed DataRequest Status Reports.

• On October 10, 2014, Nevada Power late-filed ExhibitNos. 60 and C-16.
• On October 17, 2014, NevadaPower late-filed CorrectedExhibit Nos. 60 and C-16. 

### IV. ENERGY SUPPLY PLAN UPDATE 

### A. Legal Framework 1. Pursuantto NAC 704.9506, NevadaPoweris obligated to file an ESPupdate with the Commission in the first and second years after the action plan ofthe utility is filed. Nevada Powerfiled an application, designated as Docket No. 12-06053, seeking approval ofits 2013- 2032 Triennial IRP and 2013-2015 ESP on June 29, 2012. NevadaPowerincludes its second yearESP update to the 2013-2015 ESP with the FirstAmendment Application. 2. Because the ESP is part ofan integratedresource plan filing, NevadaPower's inclusion oftheESPUpdate in the FirstAmendment Application containing the ERCR Plan also allows NevadaPowerto comply with the NRS 704.7316(1) mandate offiling the ERCR Plan as
a part ofan IRP filing. In other words, NevadaPower'sESP Update filing serves a dual purpose ofproviding an update to the 2013-2015 ESP and contributing the ESPportion ofthe amendment to the 2013-2032 IRP. 3. Pursuant to NRS 704.7316(2)(d), the ERCRPlanmust include a strategy for the commerciallyreasonable physical procurement offixed-price natural gas ifthe Plan includes theDocketNos. 14-05003 & 14-06022 Page 8 construction or acquisition ofone or more natural gas-fired plants. NAC 704.9453(5) sets out requirements for the gas procurement strategy. The ESPUpdate contains a section devoted to natural gas procurement. 4. NAC 704.9508 requires this ESP Update to be processed within 120 days after the filing, with a hearing taking place within 60 days ofthe filing. However, the gas procurement portion ofthe ESP Update reflects aspects ofNevada Power's proposedERCR Plan and is responsive to NAC 704.9453(5). Accordingly, Nevada Powerrequests that the Commission waive the 120-dayrequirement and, instead, consider and approve this ESPUpdate concurrently with the ERCR Plan. (Ex. 13 at 5.) B. Energy Supply Plan Update Stipulation Parties' Position 5. Parties to the Stipulation request that the Commission accept the Stipulation. 6. The parties recommend that the Commission find the short-term load forecast contained in the ESP Update meets the requirements ofNAC 704.9321, 704.9482, and 704.922, and is suitable for making planning decisions during the ESP Update period. The parties further recommend that the Commission accept and approve the following: the Power Procurement Plan and the constituent elements ofthe plan, including the portfolio optimization plans, but not Nevada Power's "Portfolio Optimization Manual"; the Coal Procurement Plan; the Physical Gas Procurement Plan; and the Gas Transportation Plan, with the proviso that Nevada Power will not issue a request for proposals ("RFP") and award economic bids for up to 40,000 million cubic feet per day ofnatural gas transportation capacity during the ESPUpdate period. The parties recommend the Commission approve and accept NevadaPower's Gas Hedging Strategy as it currently exists, until an updated hedging strategy is approved, and find that Nevada PowerhasDocket Nos. 14-05003 & 14-06022 Page9 satisfied the directive contained in Docket No. 12-06053 and should continue to conduct quarterly hedging workshops. The parties recommend the Commission accept and approve Nevada Power's Risk Management Strategies. The parties recommend that the Commission make the prudence findings pursuant to NAC 704.9494(3). 7. The parties recommend the Commission accept NevadaPower's plan to continue quarterly workshops with Staffand BCP to review the implementation ofthe constituent elements ofthe ESP Update and the approved hedging strategy. 8. Finally, the parties agree that the Commission should grant Nevada Power's request for confidential treatment ofcertain portions ofthe ESP Update pursuant to NAC 704.7272. 3 Commission Discussion and Findings 9. The Commission finds that the Stipulation is a consensus resolution ofthe issues pursuant to the Parties' negotiations and is a reasonable recommendation and resolution ofthe issues in this proceeding. The Commission finds that, pursuant to the requirements ofNAC 703.845, this Stipulation settles only issues relating to the instant proceeding and does not seek reliefthat the Commission is not otherwise empowered to grant. Therefore, the Commission finds that it is in the public interest to approve the Stipulation. 10. The Commission finds that Nevada Power's ESP Update shouldbe approved as modified bythe Stipulation. The Commission finds that the short-termload forecast contained in the ESP Update meets the requirements ofNAC 704.9321, 704.9482, and 704.922, and is suitable for making planning decisions during the ESPUpdate period. Pursuant to NAC 704.9494, the Commission accepts and approves the following: the Power Procurement Plan and

3 The Stipulation references NAC 704.7272 in error. The applicable regulation is NAC 703.5274.DocketNos. 14-05003 & 14-06022 Page 10 the constituent elements ofthe plan including the portfolio optimization plans, butnot Nevada Power's "Portfolio Optimization Manual"; the Coal Procurement Plan; the Physical Gas Procurement Plan; and the Gas Transportation Plan, with the proviso that Nevada Power will not issue an RFP and award economic bids for up to 40,000 million cubic feet per day ofnatural gas transportation capacity during the ESP Update period. The Commission approves and accepts Nevada Power's Gas Hedging Strategy as it currently exists, until an updated hedging strategy is approved, and the RiskManagement Strategies. The Commission finds that the elements ofthe ESP Update, as modified by the Stipulation, are prudentpursuant to NAC 704.9494(3). 11. The Commission finds that Nevada Powerhas complied with the directive contained in the Commission's November 12, 2012, Phase I Order in Docket Nos. 12-06052 and 12-06053, which requires Nevada Powerto continue to conduct quarterly gas hedging workshops as described in the stipulation approved in Docket No. 11-09003. The Commission accepts Nevada Power's plan to continue such workshops with Staffand BCPto review the implementation ofthe elements ofthe ESPUpdate and the approved hedging strategy. 12. The Commission grants Nevada Power's request for confidential treatment of certain portions ofthe ESP Update pursuant to NAC 703.5274. 13. NAC 704.0097 permits deviation from regulations if: (1) good cause appears for the deviation; (2) the person requesting the deviation provides a specific reference to each provision from which the deviation is requested; and (3) the Commission finds that the deviation is in the public interest and is not contrary to statute. The Commission finds that good cause exists to deviate from NAC 704.9508 in this instance to allow the Commission the full180 days to issue an order addressing portions ofthe ERCR Plan reflected in the ESP Update. The Commission further finds that the deviation is in the public interest and is not contrary to statute.DocketNos. 14-05003 & 14-06022 

### V. FIRST AMENDMENT TO THE 2013-2032 IRP A. Background Page 11



### 14. The ERCR Plan originates from Senate Bill ("SB") 123, signed into law on June 11, 2013. The law, subsequently codified as NRS 704.7311 et seq., provides for the retirement
or elimination ofnot less than 800 megawatts ("MW") ofcoal-fired electric generating capacity and replacement ofsuch capacity with renewable or non-coal conventional generation. NRS 704.7316(1) prescribes that NevadaPower file the ERCRPlan with the Commission as part ofan IRP filing. Pursuant to NAC 704.9156, an IRP filing consists ofa load forecast, a demand side plan, a supply plan, a financial plan, an energy supply plan, and an action plan. 15. To supplement NRS 704.7311 et seq., the Commission adopted aregulation, LCB File No. R131-13 ("ERCR Regulation"), subsequently codified within NAC Chapter 704, establishing provisions governing the Plan. NAC 704.9453(1) ofthe ERCR Regulation mandates that the initial Plan be filed by May 1, 2014, and be included with Nevada Power's supply plan portion ofan amendment to the IRP. NAC 704.94893(1) further obligates Nevada Power to file an initial ERCR action plan ("ERCR Action Plan") by May 1, 2014, as an amendment to the approved IRP. NAC 704.94893(2) contemplates that the ERCR Action Plan will cover only one year, 2015. 16. On May 1, 2014, Nevada Power filed an application to amend its 2013-2032 IRP and to update its ESP. The application contains the initial ERCR Plan and ERCRAction Plan. B. Load Forecast and Fuel and Purchased Power Price Forecasts Nevada Power 17. Nevada Power seeks approval ofthe load forecast provided in the Load Forecast, Market Fundamentals, and Fuel and Purchase Power volume, Exhibit 4. Nevada Power alsoDocketNos. 14-05003 & 14-06022 Page 12 seeks approval ofthe loads and resources tables for 2015 presented in the ESPUpdate volume, Exhibit 13, andEconomic Analysis and Financial Plan volume, Exhibit 4. (Exhibit 27 at 1.) Nevada Powerrequests a finding that the load forecast is based on substantially accurate data that has been adequately demonstrated and defended and has been adequately documented and justified. NevadaPower also requests a finding that the load forecast is appropriate for resource planning decision-making through the Action Plan period. (Ex. 2 at 20; Ex. 27 at 1-2.). 18. Nevada Power seeks approval ofthe fuel and purchasedpowerprice forecasts presented in the LoadForecast and Market Fundamentals volume, Exhibit4, and seeks a finding that the fuel and purchased powerprice forecasts are based on substantially accurate data that has been adequately demonstrated and defended and has been adequately documented andjustified. Nevada Power also requests a finding that the fuel and purchased powerforecasts are appropriate for resource planning decision-making through the Action Plan period. (Ex. 2 at 20; Ex. 27 at 2.) Staff 19. Staffrecommends that the Commission approve NevadaPower's load forecast, as it is based on substantially accurate data, and find that the load forecast is appropriate for
resource planning decision-making through the Action Plan period. (Ex. 69 at 2.) 20. Staffrecommends that the Commission approve Nevada Power's loads and
resources tables for 2015, but only ifthe Commission accepts Staff'srecommendation regarding the acquisition ofthe Las Vegas Cogeneration Unit 2 ("LV Cogen 2") station contained in Staff Witness Maguire's testimony, Exhibit 79. (Ex. 75 at 3.) Staffstates that Nevada Powerincluded LV Cogen 2 as a generation resource for 2015. (!d.) Staffadds that Nevada Power's original purchase power agreement for this unit expired in December 2013, and Nevada Power executed
a summer-only amendment to the contract for 2014. (!d.) Staffargues that ifthe CommissionDocket Nos. 14-05003 & 14-06022 Page 13 does not accept Staff's recommendation to approve the Preferred Plan, which includes the acquisition ofLV Cogen 2, then the loads and resources tables are no longer correct and Nevada Power's open position would increase by an additional224 MW. (ld. at 3-4.) 21. Staffrecommends that the Commission approve Nevada Power's fuel and purchased powerprice forecasts, as they are based on substantially accurate data, and find that these forecasts are appropriate for resource planning decision-making through the Action Plan period. (Ex. 69 at 2.) 

### Commission Discussion and Findings 22. The Commission approves Nevada Power's load forecast provided in the Load Forecast, Market Fundamentals, and Fuel and Purchased Power volume and loads and resources tables for 2015 that are presented in the ESP Update volume and the Economic Analysis and Financial Plan volume. The Commission finds that the load forecast is based on substantially accurate data and is appropriate for resource planning decision-making through the Action Plan period. 23. The Commission approves Nevada Power's fuel and purchased powerprice forecasts, as they are based on substantially accurate data, and finds that these forecasts are appropriate for resource planning decision-making through the Action Plan period. 

### C. Supply Plan and ERCRAction Plan i. Legal Framework 24. To replace the retired oreliminated coal-fired electric generation, NRS 704.7316(2)(c) contemplates construction or acquisition of550 MW ofnon-technology-specific generation to be ownedby Nevada Power. The replacement capacity must be constructed or acquired in an orderly and structured manner.Docket Nos. 14-05003 & 14-06022 Page 14 25. NRS 704.7316(2)(b) requires the ERCRPlan to provide for the construction and acquisition of, orcontracting for, 350 MW ofrenewable electric generating capacity. Under the Plan, Nevada Powerhas to issue three RFPs of 100 MW each for nameplate capacity from renewable energyfacilities. The remaining 50 MW ofrenewable nameplate capacity must come from Nevada Power either constructing or acquiring a portion ofnew renewable energy facilities. 26. NAC 704.94893 directs Nevada Powerto specify within the initial ERCRAction Plan all ofthe actions that are to take placebefore the filing ofits 2016-2035 IRP and provide a budget for planned expenditures suitable for comparing planned and achieved expenditures. 

### ii. Emissions Reduction Applicable Authorities 27. Under NRS 704.7316(2)(a), the ERCR Plan mustprovide for retirement or elimination ofat least 300MW ofcoal-fired electric generating capacityby December 31, 2014, 250 MWby December 31,2017, and another250 MWby December 31,2019. NAC 704.9453(2) mandates that the Plan include a schedule specifying the tiered retirement or elimination ofcoal-fired generation outlined in NRS 704.7316(2)(a). Under NAC 704.9453(2), the Plan must also identify each coal-fired generation facility to be retired oreliminated, the amount ofplanning capacity associated with such facilities as well as the unamortized balance of investment, decommissioning and remediation costs, and lingering contractual liabilities associated with the facilities. 28. Paragraph (e) ofsubsection 2 ofNRS 704.7316 further prescribes that the ERCR Plan provide "aplan for tracking and specifying the accounting treatment for all costs associated with the decommissioning" ofthe coal-fired generating plants. NAC 704.9453(6) elaborates thatDocketNos. 14-05003 & 14-06022 Page 15 such costs, including undepreciated amount ofeach coal-firedplant to be retired or eliminated, mustbe placed in separate regulatory asset orliability accounts. Nevada Power 29. Nevada Power seeks the Commission's approval to retire, decommission, and remediate coal-fired generating units. Nevada Powerrequests approval to retire Reid Gardner Generating Station, units 1- 3, 300 MW ofplanning capacity, byDecember 31, 2014, and Reid Gardner Generating Station, unit 4, 257 MW ofplanning capacity, by December 31, 2017. (Ex. 4 at 149.) Nevada Power also plans to eliminate its interest in the Navajo Generating Station, which supplies 255 MW ofplanning capacity, byDecember 31, 2019. (ld.) The total planning capacity thus retired and eliminated would equal812MW. (!d.) 30. Nevada Power estimates the demolition costs for Reid Gardner units 1-4 at $45.4 million, adjusted for approximately $10 million in asset recovery/salvage credits. (ld. at 151.) The amount does not include approximately $1.5 million in transmission costs associated with the demolition. (!d.) Nevada Power proposes a decommission and demolition schedule, which includes demolition ofunits 1-3 between March 1, 2015, and December 31,2016, and unit 4 demolition between January 1, 2018, and December 31, 2019. (!d. at 152.) NevadaPower expects to complete base-case corrective remediation actions bythe end of2022 with maintenance and performance monitoring continuing for up to 30 years thereafter. 4 (!d. at 154.) 31. With exit negotiations among participants in the Navajo Project ongoing, Nevada Power is unable to provide information regarding decommissioning, demolition, and remediation costs for the Navajo Generating Station. (!d. at 155.) 32. Nevada Power presents the following netbook values for Reid Gardner units 1-4:

4 Nevada Powerrequested confidential treatment ofthe remediation costs.Docket Nos. 14-05003 & 14-06022
Unit
Unit 1 Unit 2 Unit 3 Units 1, 2, and 3 Common Unit4 Units 1-4 Common Unit 4 Acquisition Adjustment Total (/d.; See also Ex. 2 at 254.) Retirement Date
12/31114 12/31114 12/31114 12/31114 12/31117 12/31117 12/31117 Page 16
Net Book Value (as of retirement date in millions ofdollars) $26.6 $24.4 $25.6 $57.9 $53.3 $33.8 $25.7 $247.3

33. Nevada Powerpresents the following netbook values for the Navajo Generating Station: Unit
Unit 1 Unit 2 Unit 3 Units 1, 2, and 3 Common Navajo Coalhaul Railroad Total (!d. at 156; See also Ex. 2 at 254.) Retirement Date
12/31/19 12/31/19 12/31/19 12/31/19 12/31/19 NetBook Value (as of retirement date in millions ofdollars) $3.2 $5.6 $8.5 $9.9 $1.6 $28.9

34. NevadaPowerproposes to accumulate the costs ofretirement, decommissioning, demolition, and remediation for the Reid Gardner and Navajo units in separate regulatory assetDocket Nos. 14-05003 & 14-06022 Page 17 subaccounts. (!d.) Nevada Powerproposes that a separateregulatory asset accountbe establishedfor the net book value ofeach unit and related electric investments on the date ofthe retirement. (!d.) 35. Nevada Power states that the majority ofcontractual and regulatory obligations for the Reid Gardner Generating Station pertain to remediation costs. (!d. at 157.) Nevada Power anticipates liability for the Navajo Station decommissioning costs proportionate to its ownership share. (!d.) NCARE 36. NCARE recommends that the Commission approve Nevada Power's ERCR proposal for the retirement and elimination of812 MW ofcoal-fired generating units. (Ex. 56 at 4.) Staff 37. Staffrecommends that the Commission approve NevadaPower's request to retire, decommission, and remediate the coal-fired generating assets per the dates outlined. (Ex. 79 at 2- 3.) However, Staffrequests that the Commission specify that it is not approving the specific timeline and cost estimates ofdecommissioning and remediation because it is Nevada Power's responsibility to prudently manage the work and to present the costs for review in the appropriate general rate case application. (!d. at 3.) 38. Staffrecommends that the Commission order Nevada Powerto accumulate the test year certified level ofoperations and maintenance ("O&M") expenses related to 29 Reid Gardner units 1-3 employees in a regulatory liability or, alternatively, to use these accumulated expenses as an offset against the regulatory asset for O&M costs that will be establishedpursuant to NRS 704.7317. (Ex. 78 at 1.)Docket Nos. 14-05003 & 14-06022 Page 18 39. Staffnotes that the payroll costs ofReid Gardner units 1-3 employees are embedded in certification period O&M expenses ofNevada Power's general rate case filing, Docket No. 14-05004, and thus will berecoverable in rates for the next three years despite the Reid Gardner units 1-3 closure on December 31,2014. (/d. at 2.) At the same time, according to Staff, Nevada Powerplans on using the employees to conduct decommissioning work at Reid Gardner or transfer them to other generating facilities. (!d. at 3.) Staffcontends that either scenario will result in double recovery ofpayroll costs for the 29 employees. (!d. at 3-4.) Staff predicts that payroll costs ofthe employees to be involved in decommissioning activities or to be transferred to newly-acquired generation facilities will be accumulated in a regulatory asset pursuant to NRS 704.7317 and recovered in the next general rate case. (!d.) Staffclaims that, alternatively, payroll costs ofthe employees to be transferred to existing generation facilities will also be double-recovered because payroll costs ofthose stations, which may have been fully staffed in the test year, have already been reflected in test year O&M expenses (/d. at 4.). 40. Thus, to prevent double recovery ofthe payroll costs, Staffrecommends that a rate case adjustment or an accounting order. (!d.) Staffcontends that the recommendation is consistent with the Commission's mandate ofsettingjust and reasonable rates and NAC 704.9453(6)(b)(5), which states that the ERCR Plan "mustprovide for salvage and any other appropriate offsets." (!d. at 5.) Nevada Power Rebuttal 41. Nevada Power disagrees with Staff's recommendation not to approve specific decommissioning and remediation timelines and cost estimates. (Ex. 93 at 17.) Nevada Power agrees with Staffthat the Companyhas not yet completed a detailed remediation plan for the Reid Gardner Stationbecause such aplan must be developed in coordination with the NevadaDocket Nos. 14-05003 & 14-06022 Page 19 Division ofEnvironmental Protection. (!d.) Nevada Power also agrees with Staffthat the Companyhas not yet completed a detailed decommissioning and remediation plan for the Navajo Stationbecause NevadaPowerhas yet to negotiate an exit agreement with co-owners of the Navajo Station. (!d.) However, Nevada Power disagrees with Staff's assertion that the Reid Gardner decommissioning plan is not sufficiently developed to merit approval in this case. (/d. at 17-18.) Nevada Powerreferences its initial filing to demonstrate that it supplied specific timeframes to begin decommissioning ofReid Gardner units 1-3 and that a study included as Technical Appendix GEN-3 provides the basis for the detailed estimates for decommissioning and demolition costs and a detailed decommissioning timeline. (!d. at 18.) Nevada Powerfurther notes that it is unaware ofany deficiencies in the Reid Gardner decommissioning plan. (!d.) Nevada Powerrecognizes that it is responsible for prudent management ofdecommissioning and remediation work and is mindful that the Commission's acceptance ofthe plan does not predetermine NevadaPower's ability to recover the estimated costs through rates. (!d. at 18-19.) 42. Nevada Power counters Staff's assertions regarding over-recovery ofpayroll costs by stating that double recovery is not possible in one ofthe three circumstances described by Staffand that the existingregulatory environment already protects against the other two double recovery scenarios without requiring the deferral or accumulation ofrevenue into aregulatory liability. (Ex. 93 at 4.) 43. With respect to the scenario where the employees transfer to another generating station to fill positions at those plants, Nevada Power asserts that double recovery cannot occur because the payroll costs associated with those positions are not eligible for recovery under an alternative ratemaking mechanism such as the one established pursuant to NRS 704.7317. (!d.)DocketNos. 14-05003 & 14-06022 Page 20 44. Withrespect to the scenarios in which the payroll costs couldbe recovered through annual revenue requirement during the rate-effective period and could also be included in costs accumulated in an ERCRPlan regulatory asset, Nevada Power cites to NAC 704.9453(6)(b)(5), which already prevents such double recovery. (!d. at 5.) Nevada Power references Staff's observation that NAC 704.9453(6)(b)(5) requires that costrecovery through the ERCR Plan regulatory asset established for collecting the costs ofdecommissioning Reid Gardner units 1-3 provide for "salvage and any other appropriate offsets." (!d.) Nevada Power represents that it will track costs as required by the regulations and will present sufficient information in the next rate case for the Commission to determine whether an offset is necessary and the amount ofthe offset. (!d. at 6; Tr. at 630-31.) Accordingly, Nevada Power argues that the establishment ofa regulatory liability account orother means ofdeferring and accumulating the costs ofthe redeployed employees is unnecessary and predetermines the Commission's decision in a future ratemaking proceeding. (Ex. 93 at 6.) 45. Additionally, Nevada Power states that the acceptance ofStaff's recommendation to accumulate $3.9 million in annual general rate revenues would upset the careful balance struck when NevadaPower agreed in Docket No. 14-05004, its recent general rate case, to no change in annual revenue requirement for the next three years. (!d. at 6-8.) Under the settlement agreement reached in Docket No. 14-05004, Nevada Power assumed that all ofits revenue will be available to fund operations. (Transcript at 631.) Thus, Nevada Power opposes the creation of
aregulatory liability to collect the payroll costs, which will likely result in reduction ofO&M expenses. (!d. at 631-32; Ex. 93 at 7.) 

### Ill IllDocketNos. 14-05003 & 14-06022 Page 21 Commission Discussion and Findings 46. The Commission approves the components ofNevada Power's ERCRPlan related to the retirement and elimination of812 MW ofcoal-fired generating capacity. Nevada Powerhas adequately demonstrated its plan to retire the Reid Gardner units 1-3, consisting of 300 MW ofplanning capacityby December 31, 2014; the Reid Gardner unit 4, consisting of257 MW ofplanning capacity byDecember 31, 2017; and eliminate its interest in the Navajo facility, consisting of255 MW ofplanning capacitybyDecember 31, 2019. No party objected to the retirement and elimination of812 MW ofcoal-fired generation. 47. The Commission approves the components ofNevada Power's ERCR Plan related to the decommissioning and remediation of812 MW ofcoal-fired generating capacity. Nevada Powerhas adequately demonstrated its plan for the decommissioning and remediation of the generating plants based on the information available at this time. The Commission agrees with Staffthat while the Commission is approving the decommissioning andremediation plan, it acknowledges that specific timelines and estimated costs are likely to change. Nevada Power remains obligated to prudently manage the timelines and costs ofdecommissioning and remediation and to minimize costs and maximize salvage value ofthe retired equipment. The costs ofdecommissioning and remediation will be subject to review for reasonableness in the appropriate general rate case application. 48. The Commission finds that while the potential for double recovery ofthe payroll costs exists, establishment ofa regulatory liability is not necessary to prevent double recovery. The processes for tracking savings realized from reduced payroll expenses at the decommissioned portion ofthe Reid Gardner facilities are identical regardless ofwhether a regulatory liability is established, as proposedby Staff, orifthe ERCRregulatory asset amountDocketNos. 14-05003 & 14-06022 Page 22 is offset at the time ofthe next general rate case, as proposed byNevada Power. The keyto avoiding the double collection is tracking. NevadaPower'sproposal is consistent with NAC 704.9453(6)(b)(5) and the Commission's prior practice. 

### See e.g., Docket Nos. 03-10001 and 03- 10002, March 26, 2004, Order, paragraphs 640-42. Accordingly, the Commission adopts NevadaPower's approach oftracking the payroll savings and offsetting the appropriate regulatory asset account at the time ofthe next general case. 49. Based on the foregoing, the Commission accepts the emission reduction portion ofNevada Power's ERCRPlan and finds that Nevada Powerhas met the requirements ofNRS 704.7316(2)(a) and NAC 704.9453(2)(a-l). iii. Capacity Replacement Applicable Authorities Non-Technology-Specific Capacity Replacement 50. NRS 704.7316(c) provides for NevadaPowerto construct or acquire and own 550 MW ofnon-technology-specific generating capacity, which mustbe constructed or acquired to replace the coal-fired generating capacity to be retired or eliminated, in an orderly and structured
manner. 51. NAC 704.9453(4) requires the ERCRPlan to include a description ofthe plants Nevada Powerproposes to construct or acquire with a budget for each such plant, the dates of initiation and completion ofplant construction(s) orthe dates ofacquisition(s), as applicable, a description ofthe ancillary utility facilities necessary to operate or interconnect the plant(s), and the performance and reliability standards to which the electric generating plant(s) will be subject and a statement ofhow those standards compare to standards that the utility has mandated from other electric generating plants with which the utilityhas executed PPAs. NAC 704.9453(4) alsoDocket Nos. 14-05003 & 14-06022 Page 23 allows for the ERCR Plan to include a request for approval to construct or acquire ancillary utility facilities necessary for the operation orinterconnection ofthe plant(s). 52. NAC 704.9453(7) requires the ERCR Plan to include (1) a schedule ofthe information described in NAC 704.945 that identifies the amount ofplanning capacityrequired to replace the coal-fired capacity to be retired or eliminated and the time at which such capacity will be added, (2) an analysis ofall applicable resource planningregulations, and (3) an analysis ofthe economic effectin Nevada ofeach alternative plan presented by Nevada Power. 53. NAC 704.9453(8) requires the ERCR Plan to include a proposed RFP process that will be used to provide a comparative analysis ofthe alternatives available for the 550MW of non-technology-specific replacement capacity. 54. NAC 704.95245 provides for the creation ofregulatory asset and liability accounts for each new facility acquired orconstructed pursuant to the ERCR Plan. Renewable Generation Capacity Replacement 55. NRS 704.7316(2)(b) requires the ERCR Plan to provide for the construction or acquisition of, or contracting for, 350 MW ofelectric generating capacity from renewable energy facilities. Underthe Plan, Nevada Powermust issue three RFPs for 100 MW ofrenewable nameplate capacity each with the first RFP on orbefore December 31, 2014, the second RFP on
orbeforeDecember 31, 2015, and the third RFP on or before December 31, 2016. Nevada Poweris tasked with identifying the proposals that provide the greatest economic benefit to Nevada, the greatest opportunity for the creation ofnewjobs in Nevada, and the best value to Nevada Power customers. Once identified, NevadaPoweris to negotiate in good faith to construct, acquire, or contract with the new renewable energy facilities and file with theDocketNos. 14-05003 & 14-06022 Page 24 Commission an amendment to the ERCR Plan each time the utility wishes to construct, acquire,
or contract with such facilities. 56. To fulfill the remaining 50 MW ofrenewable generation, Nevada Power must begin the construction or acquisition ofa portion ofa new renewable energyfacility orfacilities by December 31, 2017, to be owned and operatedby Nevada Power, and complete the constructionbyDecember 31, 2021. 57. NAC 704.9453(3)(a) mandates that Nevada Power include a schedule for the issuance ofthe RFPs specifying the date ofpublic notice release for each RFP and identifying the approximate date by which Nevada Power anticipates announcing the winners ofthe RFPs, concluding negotiations with the winners, and filing an amendment to the ERCR Plan.5 58. NAC 704.9453(3()(b) further elaborates that, with respect to the 50MW renewable facility(ies) to be ownedby NevadaPower, the ERCRPlan must provide a reasonable description ofsuch facility(ies), a budget for the new renewable energy facility(ies), the date of the construction commencement or acquisition and the date ofthe construction completion, a description ofthe ancillary utility facilities, and the performance and reliability standards to which the new renewable energy facility(ies) will be subject with a statement ofhow those standards compare to standards Nevadapowerhas mandated from its counterparties to the renewable energy PP As. 59. NAC 704.9453 further provides that the first RFP mustbe completedprior to Nevada Power accepting proposals responsive to second or third RFPs. NAC 704.9453 also contains a provision requiring Nevada Powerto retain an independent evaluator ifit orits affiliate submits a proposal in response to any ofthe three RFPs.

5 The Commission is conducting an ongoing rulemaking centered on the RFPs in Docket No. 13-06023.Docket Nos. 14-05003 & 14-06022 Page 25 

### Nevada Power Non-Technology-Specific Capacity Replacement 60. NevadaPowerproposes the acquisition of496 MW ofnatural gas-fired existing generation and construction of200 MW ofnameplate solarphotovoltaic ("PV") generation. (Ex. 3 at 4.) More specifically, NevadaPowerplans to acquire 224 MWLV Cogen 2, 50MW Las Vegas Cogeneration Unit 1 ("LV Cogen 1"), and 222 MW Sun-Peak generating unit ("SunPeak") and construct 200MWMoapa Solar generating station ("Moapa" or "MoapaProject").6 (/d. at 3-4.) LVCogen 1 and2 61. NevadaPowerproposes to purchase LV Cogen 1 and 2, which are natural gasfired combined-cycle generating plants. (Ex. 4 at 158.) LV Cogen 1is a 1x1 combined cycle facility, which commenced operation in June 1994. (!d.) LV Cogen 2 is a dual2x1 combined cycle facility, which commenced operation in January 2003. (!d. at 159.) Both facilities are located in an industrial section ofthe City ofNorth Las Vegas. (ld. at 158.) After conducting due diligence on the facilities, Nevada Powerconcluded that, in general, the planthas been adequately maintained and shouldperformin areliable manner. (!d. at 160.) 62. NevadaPowernegotiated a $129.92 million purchase price for both facilities with
an estimated $900,000 in transaction costs adding up to $130.82 million as the initial capital cost ofthe acquisition. (/d. at 161.) LV Cogen units enter Nevada Power's generation fleet on January 1, 2015, for LV Cogen 2, and October 1, 2017, for LV Cogen 1, when the existing powerpurchase agreement ("PPA") with Nevada Powerterminates. (/d. at 160.)

6 Moapahas a planning capacity ofapproximately 76 MW (Exh. 3 at4.).Docket Nos. 14-05003 & 14-06022 Page 26 63. Nevada Power states that both units are interconnected to its 138 kV transmission system through a substation located on the property. (/d. at 159.) The City ofNorth Las Vegas provides approximately 510 acre-feet ofwaterper year consumedby the facilities. (!d.) Natural gas is supplied from the Kern River pipeline with subsequent distribution via Southwest Gas Corporation's ("SWG") infrastructure. (ld.) Sun-Peak 64. Nevada Powerproposes to purchase Sun-Peak, which is a simple cycle peaking electric plant. (Ex. 4 at 161.) The facility consists ofthree 74 MW combustion turbines. (/d.) The units are dual-fuel capable, natural gas and diesel oil, buthave not been run on diesel oil since 1999. (!d.) Sun-Peakcommenced operation in June 1991. (!d.) The facility is located under a site lease agreement on Nevada Powerproperty adjacent to what was formerly the Sunrise Generating Station. (ld.) The facility's Title V air permit limits operation to 3,495 hours
on all three units combined during any 12-month rolling period while burning natural gas. (/d.) The three units have quick-start capability. (!d.) Nevada Power observes that, generally, the plant has been adequately maintained and should performin a reliable manner. (/d. at 163.) Nevertheless, Nevada Poweridentified several issues that may have to be remedied before the plant can be integrated. (!d.) Nevada Power estimated the remedial costs at $4.53 million. (!d.) 65. Nevada Power estimates the initial capital cost ofthe acquisition at $15.83 million. (/d.) The sumconsists of$11million purchase price, $4.53 million integration costs, and $300,000 transaction costs. (!d.) 66. Nevada Power states that Sun-Peak will become a part ofits generation portfolio beginning June 1, 2016, when the current PPAbetween Nevada Power and Sun-Peak's present ownership expires. (ld. at 162.)Docket Nos. 14-05003 & 14-06022 Page 27
67. Nevada Power states that Sun-Peak is interconnected to the Nevada Power 138 kV transmission system via two 138 kV transmission lines. (!d. at 161.) Las Vegas ValleyWater District supplies water to the facility at an approximate rate of27 acre-feet per year. (/d. at 162.) Sun-Peakreceives natural gas offofthe Kern River pipeline fed to the facility through the SWG distribution system. (!d.) Ancillary FacilitiesRequired forLVCogen andSun-Peak 68. In response to NAC 704.9453(4)(e), Nevada Power states that LV Cogen and Sun-Peak do not require additional ancillary utility facilities to operate orinterconnect. (Ex. 4 at 165.) Moapa 69. Nevada Powerproposes to acquire the development assets and to construct and, ultimately, operate the Moapa Solar Project. (Ex. 4 at 205.) Moapa will be a 200 MW nameplate capacity solar PV electric generating facility located on reservation lands ofthe Moapa Band of Paiutes, approximately 45 miles northeast ofLas Vegas, Nevada. (ld.) The plant will have 76 MW ofplanning capacity. (Ex. 3 at 4.) The facility is expected to produce approximately 420,000 megawatt hours ("MWh") ofenergy annually overits 30-yearexpected life. (Ex. 4 at 206.) Nevada Powerplans to interconnect the facility directly to its 230 kV transmission system at the Harry Allen substation. (/d. at 214.) 70. Nevada Power estimates the capital cost ofMoapa at $438.1 million, excluding an allowance for funds used during construction ("AFUDC") (/d. at 205.) The overall cost for the project will be offsetby the 30percent federal Investment Tax Credit ("lTC"), representingDocket Nos. 14-05003 & 14-06022 Page 28 $124.8 million in savings, as long as Moapais placed in servicebefore December 31,2016.7 (!d. at 216.) NevadaPowerexpects the construction to commence no laterthan March 15, 2015, and for the facility to be in commercial operation by December 31,2016. (!d. at 213.) 71. As an ancillary facility to Moapa, Nevada Powerrequests approval of$1.7 million investment in networkupgrades at the Harry Allen substation to interconnect Moapato Nevada Power's transmission system. (!d. at 217.) The investment will cover site metering and communication, substation entrance work, permit assistance, environmental work, and protection review. (!d.) Peiformance andReliability StandardsforLVCogen, Sun-Peak, andMoapa Facilities 72. Nevada Power states that the generating units NevadaPower proposes to purchase will be subject to objective performance standards through Nevada Power's general obligation to prudentlymanage and operate its generating units. (Ex. 36 at 23-24.) In addition, similar to the existing generation, reliability for LV Cogen and Sun-Peak will be demonstrated by participating in and complying with the required North American Electric Reliability Corporation ("NERC"), Federal Energy Regulatory Commission ("FERC"), and Western Electricity Coordinating Council ("WECC") programs and provisions. (Ex. 4 at 164.) With respect to the Moapaplant, Nevada Power states ithas secured a number ofprotections from RES, project developer, and First Solar, solarpanels supplier, including liquidated damages should RES fail to deliver the contracted-for capacity, a design and defect warranty with RES, and a separate warranty agreement with First Solar. (Ex. 45 at 25-26.)

7 Nevada Power has negotiated with the Moapa developer aprovision awarding Nevada Power the amount oflTC savings as damages ifMoapais notin service by December 31, 2016. (Exh. 4 at 216.)DocketNos. 14-05003 & 14-06022 Page 29 73. Nevada Power further notes that the generating units within its fleet are subject to performance standards different than generating units ownedbyindependentpowerproducers because Nevada Power does not control the operations and maintenance of, and the Commission has no continuing oversight authority over, the latter category. (Ex. 36 at 24 and Ex. 4 at 164.) NAC 704.945 Schedule andAlternativePlans Evaluation 74. NevadaPowerpresents a number oftables and graphs responsive to NAC 704.945 and NAC 704.9453(7)(a). Nevada Powerprovides loads and resources tables for each alternative planresponsive to NAC 704.945(1),(4). (See Ex. 4 at 156-59 and Ex. 11 at 161-222.) Nevada Powerprovides three graphs, responsive to NAC 704.945(2), for the proposed ERCR Plan depicting the excess orrequired capacity with and without demand side management and with and without the additional planned resources. (Ex. 4 at 150-51.) 75. NevadaPower states that, in addition to the proposed ERCR Plan, it analyzed three alternative plans to build or acquire capacity outlined in NRS 704.7316(2)(b)(6) and (c) in accordance with NAC 704.937(1). (Ex. 4 at 134.) Case A consists ofapproximately 597 MW of gas-fired base load 2xl combined-cycle generation to be operational by summer 2018. (!d.) Case B includes approximately 568 MW ofgas-fired lxl simple-cyclepeaking capacity to be operational by summer 2018. (/d.) Case Cis the proposed ERCR Plan. CaseD consists ofthe acquisition of274 MW ofexisting gas-fired generation by January 2015, the construction of200 MW ofsolar PV generation by October 2016, and construction of500MW ofsolar PV generation byJanuary 2018 for a total planning capacity of540 MW. (!d. at 135.) Each case contains a 15 MW self-build solar PV projectbeginningJune 2016. (/d.) Cases A, B, and C include the construction ofa 35 MW solar PV generator in 2021. (/d.) According to Nevada Power, the 35 MW generator, combined with the 15 MW PV generator, meets the SB 123Docket Nos. 14-05003 & 14-06022 Page 30 requirement ofat least 50 MW ofreplacement capacity in the form ofutility-owned renewable generation. (/d.) 76. Nevada Powerhas chosen Case Cas the Preferred Plan and Case A as the Alternate Plan. (!d. at 276.) Nevada Power states that the primary factors for selecting the Preferred Plan were total present worth ofrevenue requirements ("PWRR") and resource diversification. (!d.) Secondary factors included reliability and the flexibility to address volatilities around load; fuel, purchasedpower, and carbon prices were also factors in selecting the Preferred and Alternate Plans. (!d.) Cases A and C consistentlyprovidedthe lowest PWRR among various loads; carbon, fuel, and purchasedpowerprice environments; and 10-year, 20- year, and 30-yearplanning periods. (ld.) Nevada Powerfurther states that the difference in PWRRbetween scenarios where Case Cis more expensive than Case A is insignificant across all planning periods. (!d.) Nevada Power considers Case C preferable to Case A because the overall capital cost ofreplacement capacity in Case C, at $584.7 million, is lower than the estimated cost ofCase A at $711 million. (!d. at 276-77.) Additionally, Case A would not receive the 30 percent lTC for which the Moapa Project from Case C qualifies. (!d. at 149.) Another important factor that Nevada Power weighs in favor ofCase C is resource diversification, which includes factors such as fuel diversity and capacity diversity in producing electricity. (ld.) When compared to Case A, Case C provides more fuel diversity and more capacity diversity. (ld.) The combined-cycle unit in Case A is gas-fired base load capacity only, whereas the replacement capacityin Case C provides 224 MW ofgas-fired intermediate capacity, 272 MW ofgas-fired peaking capacity, and 76 MW ofintermittentrenewable planning capacity. (!d.) 77. In addition to the PWRR analysis, Nevada Power applies a number of econometrics to the four alternative resource plans to conduct the analysis responsive to NACDocket Nos. 14-05003 & 14-06022 Page 31 704.9453(7()(b). Nevada Powercalculatedthe present worth ofsocietal costs ("PWSC"), which includes the PWRR and environmental costs, for each Case. Inboth "No 

### COz price" and "Mid C02price" scenarios, Case A has the lowest PWSC, Case C has the second lowest PWSC, and CaseDhas the highest PWSC. (/d. at 297.) Nevada Power also compared the present values of total relevant expenditures for each Case for the economic impact analysis. Nevada Power states that the totals exclude certain categories ofexpenditures that would not generate positive economic impacts in Nevada. (/d. at 298.) Nevada Power calculates that Case C has the lowest relevant expenditures because it includes the purchase ofexisting natural gas and cogeneration plants rather than new facilities construction. (/d. at 299.) Nevada Powerprovides present values ofNV Energy's electricityrevenue requirements for 2015-2034, apportioned by customer class. (/d.) The electricity revenues differ from total relevant expenditures for a number of reasons, the return on capital investments in the electricityrevenue requirements among them. (/d.) Nevada Powerprojects electricityrevenue requirements to be smallest for Case A and second highest for Case C in total and with respect to residential, commercial, and industrial classes individually. (/d. at 300.) Nevada Power observes that, in general, relatively larger electricitypayments will have negative consequences on the Nevada economy, including a negative effect onjob creation within the State. (/d.) Foreach ofthe four resource plans, Nevada Powercompiled annual estimates ofchanges data in future Nevada gross state product, personal income, state tax revenue, and employment. (/d.) Nevada Power observes that growth is projected to be robust and very similarunder each ofthe four resource plans, with Case D showing smaller growth over time, mostly due to the higher electricitypayments ofcustomers. (/d. at 301, 305.) Nevada Powernotes that although each ofthe alternatives provides a positive economic effect to Nevada, Case Coffers a distinct advantage overits least-cost competitor,DocketNos. 14-05003 & 14-06022 Page 32 Case A, by providing a sizeablepositive economic impact starting earlyin 2015, whereas the construction ofa combinedcycle unit under Case A cannotbeginuntil the permitting is complete. (/d. at 310-11.) 78. In response to NAC 704.9453(7)(c), Nevada Power states that it engaged in customer and stakeholder outreach efforts in connection with this filing, including providing a regulatory briefing to members ofthe Southern Nevada Hotel Group and transmitting a simple surveyto representatives ofits 20 largest customers. (/d. at 309-10.) Renewable Generation Capacity Replacement 79. Nevada Powerrequests the Commission approve the issuance ofthe three 100 MW RFPs as part ofthe proposed ERCR Plan. (Ex. 4 at 62.) Nevada Power attaches the following RFP schedule: RFP Schedule EVENT 

### 2014 2015 2016 Release Public Notice 10/01114 12114115 11115116 Initial Short List 01/13115 02/11/16 01124117 Final Short List 02113115 03/11/16 02/24117 Negotiations 03/30115 04/22/16 04/07117 Management Approvals 04/30115 05/23116 05/08117 IRP (Amendment) Approval Filing 07/01115 06/15116 06/01/17 PUCN Approval Timeline 12/28/15 10/28/16 10/13117 (Ex. 4 at 191.)Docket Nos. 14-05003 & 14-06022 Page 33 80. Inresponse to NAC 704.9453(3) prohibition on accepting proposals until the previous RFP is complete, Nevada Powerpoints out that proposals responding to the 2015 RFP will not be due until February 2016. (!d.) 81. In response to NRS 704.7316(b)(6), Nevada Powerincluded in its proposed ERCR Plan construction ofa 15 MW solar PV facility at Nellis Air Force Base, ("Nellis AFB"), the Nellis Solar Array II project ("Nellis Project"). (Ex. 4 at 173, 192.). Nevada Powerplans to construct or acquire 35 MW ofadditional renewable nameplate capacity at a later time. (Ex. 36 at 6.) Nellis Project is a 15 MW alternating current facility utilizing 440 kW PV panels mounted
on a ballasted single axis tracker. (Ex. 4 at 198.) The Project's generation outputis estimated at 42,000 MWh peryear for 25 years. (!d.) 82. Nevada Power estimates the Nellis Project's cost at approximately $54.5 million, excluding AFUDC. (!d. at 192.) The amount includes the total EPC contract price of$41.9 million, new distribution interconnection facilities to interconnect the new PV generating facility with the Company's Nellis 69112 kV substation at a cost of$4.6 million, and new distribution interconnection facilities to interconnect the PV generating facility and Nellis Air Force BaseAFB to the Company's Lincoln 138112 kV substation and a new Clinton 69112 kV substation at a cost of$3.2 million. (!d. at 192, 197.) With Nellis AFB committed to paying tariffed rates to Nevada Powerfor 31 years, Nevada Power's costs ofconstructing the Nellis Project are offset byNellis AFB providing land for the PV facilities, valued at $3.36 million, for
a minimal rental cost of$10permonth. (!d. at 196, 205.) Nevada Power also notes that the Nellis Project should qualify for a 30 percent lTC, equating to approximately $16.3 million the in further benefits to ratepayers. (!d. at 202.)Docket Nos. 14-05003 & 14-06022 Page 34 83. Nevada Power anticipates starting the construction on March 30, 2015, and contracted for the Nellis Project to be fully-operational by December 1, 2015. (/d. at 196-97.) 84. Nevada Power states that the Nellis Project will be subject to objective performance standards through Nevada Power's general obligation to prudently manage and operate its generating units. (Ex. 36 at 23-24.) 8 Nevada Power further notes that the generating units within its fleet are subject to performance standards different than generating units owned by independent powerproducers because Nevada Power does not control the operations and maintenance of, and the Commission has no continuing oversight authority over, the latter category. (Ex. 36 at 24 and Ex. 4 at 164.) 85. Nevada Power seeks Commission approval to spend $1.9 million ofa $4.4 million development initiative on initial siting activities for one or more proposed new solar PV generating facilities northeast ofLas Vegas. (Ex. 4 at 217.) Nevada Power considers the siting activities essential to meet the renewable portfolio standard ("RPS") and the additional renewable energyrequirements ofSB 123. (/d.) Renewable Energy Plan 86. Nevada Power's Renewable Energy Plan lists renewable generating facilities contributing to its RPS, sets forth renewable energy planning, provides schedule and process for the three 100 MWrenewable RFPs, provides detailed descriptions ofthe Nellis and Moapa Projects, provides information about Clark County solar site development, and supplies an update on renewable PPA development activities. 87. Nevada Power states that it developed renewable expansionplans for each scenario evaluated in the ERCR expansion plans that assume full compliance with an escalating

8 Nevada Power executed with SunPower, Nellis Project developer, a Performance Guaranty Agreement whereby SunPower guaranties the energy output ofthe facility for a ten-year period. (Exh. 4 at 198.)DocketNos. 14-05003 & 14-06022 Page 35 RPS based on the forecasted load. (Ex. 4 at 181.) Nevada Powerfirst calculatedthe annual RPS creditrequirements in compliance with NRS 704.7821 and then determined the expected portfolio credit ("PC") supply starting with the current portfolio ofapproved projects adjusted for supply reduction based on a Monte Carlo analysis. (!d. at 181-82.) The RPS compliance analysis included a number ofassumptions, including the addition of350 MW ofrenewable generation pursuant to NRS 704.7316(2)(b), Nevada Power's repayment ofPCs to Sierra PacificaPower Company d/b/aNV Energy, and phasing out ofenergy efficiency and conservation measures as contributors toward portfolio standard compliance. (!d. at 181-82.) After developing the renewable baseline forecast described, Nevada Power added generic placeholderprojects to achieve full RPS compliance throughout the 30-yearplanning period for each case. (!d. at 183.) Nevada Powerincluded 178.5 MW ofadditional geothermal capacity and 450MW ofadditional solar PV capacity, modeled as being completedbetween 2033 and 2044, as placeholders for the Preferred Plan. (Ex. 12 at 237.) NevadaPowerincluded 280.5 MW ofadditional geothermal capacity and 400MW ofadditional solar PV capacity, modeled as being completedbetween 2027 and 2044, as placeholders for the Alternate Plan. (!d. at 232.) For the ERCR component ofrenewable generation, Nevada Powerincludes 15 MW PV Nellis Project, 200 MW PV Moapa Project, 10 MW PV and 25 MWPV to be completed in 2021, and 250 MWPV and 51 MW geothermal resulting from the three 100 MW RFPs for the Preferred Plan. (!d. at 237.) The ERCRrenewable inputs for the Alternate Plan modeling are the same, minus the Moapa Project. (!d. at 232.) 88. Nevada Power expects to remain RPS compliantuntil 2020 without any additional renewable resources and without extending existing PPAs. (Ex. 4 at 185.) Ifthe Preferred Plan is approved, Nevada Power expects to remain RPS compliant until2033. (Ex. 12Docket Nos. 14-05003 & 14-06022 Page 36
at 237.) Ifthe Alternate Plan is approved, Nevada Power expects to remain RPS compliant into 2027. (Ex. 12 at 232.) 89. Nevada Power states that it is not presenting any new renewable PPAs for approval as part ofthis filing. (Ex. 4 at 220.) Transmission Plan 90. Nevada Powerprovides information regarding its 20-year transmission plan in this filing pursuant to NAC 704.9385(3). (Ex. 4 at 221.) Nevada Power's transmission plan ERCR analysis identifies transmission projects necessary to maintain reliability ofthe grid following the retirement and addition ofgenerating resources pursuant to each ofthe alternative plans. (/d. at 234-36.) Nevada Power identifies eight transmission projects that will ultimately become necessary ifthe Preferred Plan is approved. (/d. at 236.) Nevada Powerrequests approval ofonly the Harry Allen 230 kV Network Upgrades in this filing. 9 (/d. at 237.) Deviationfrom NAC 704.9453(8) Request 91. Nevada Powerrequests the Commission allow the proposed ERCRPlan to deviate from NAC 704.9453(8).). Nevada Power states that the Plan has been put together over
a short period oftime according to the rules adopted by the Commission in mid-February 2014. (Ex. 2 at 15.) Nevada Powerfurther states that three key elements ofthe plan are opportunistic acquisitions ofSun-Peak, LV Cogen units, and the Moapafacility. (/d.) Nevada Power states that time was ofthe essence in identifying, investigating, and negotiating for these acquisitions. (/d. at 15-16.) Nevada Powerclaims that its economic analysis submitted to the Commission confirms that the pricing terms ofthe Sun-Peak and LV Cogen acquisitions are extremely favorable for the purchaser. (/d. at 16.) Similarly, Nevada Powerclaims that, with the Moapa

9 Nevada Power's request for approval ofthe Harry Allen 500/230 kV autotransformer filed in DocketNo. 14-06022 is discussed in Section VI ofthis order.Docket Nos. 14-05003 & 14-06022 Page 37 Projectbeing shovel-ready, Nevada will immediatelybeginto realize associated economic benefits, and Nevada Power's customers will benefitfrom the 30percent ITC, which expires December 31, 2016. (!d.) Nevada Power argues that these opportunistic acquisitions would not benefit from the information resulting from the RFPs described in NAC 704.9453(8). (!d.) Moreover, Nevada Power suspects these opportunistic acquisitions would not have been available ifNevada Power did not timely pursue negotiations with the owners ofthese resources. (/d.) ERCRAction Plan Budget 92. Nevada Powerpresents a budget for planned expenditures totaling $451.17 million for the initial2015 ERCR Action Plan. (Ex. 2 at 28.) The budgetprovides for $146.65 million in outlays for Sun-Peak and LV Cogen 1and 2purchases; $248.56 million in expenditures for the Nellis Project, Moapa Project, and Clark County site development; $2.91 million oftransmission upgrades, including Harry Allen network upgrades and Harry Allen initial transformer investment; and $53.5 million for DSM programs. (/d.) Griffith 93. Griffith asks that the Commission not approve, either implicitly orexplicitly, any Nevada Power assumptions or analyses beyond those specifically delineated in the revised prayer for relief. (Ex. 59 at 11.) Specifically, Griffith, which operates a combined cycle gas-powered 570 MW powerplant in Arizona, is concerned that the load and resource table associated with NevadaPower's Preferred Plan shows the PPA between Griffith and Nevada Power as a resource only through 2017 and eliminates Griffith as a resource beyond expiration ofthe Griffith PPA in 2017. (/d. at 10-11.) Griffith notes that, to close the resulting openposition, Nevada Power proposes to build and own a 597 MWcombined cycle powerplant to be operational by 2020.Docket Nos. 14-05003 & 14-06022 Page 38 (!d. at 11.) Griffith asserts that no proposal involving the approval ofthe Griffith PPA expiration and its replacement with a new plant to be ownedby NevadaPowercan take place in this proceeding as it would side-step the normal IRP process and grant reliefnot requested by Nevada Power. (ld. at 11-12.) NCARE 94. NCARE recommends that the Commission approve Nevada Power's ERCR Plan, with corresponding capacityretirement, elimination, acquisition, construction, RFP issuances, and initial siting activities related to one or more proposed new solar generating facilities in Clark County. (Ex. 59 at 24-25.) NCARE supports the ERCR Plan because it aims to further reduce C02emissions byretiring higher-emission coal and natural gas units and replacing them with lower-emission natural gas and zero-emission renewable energyresources. (!d. at 24.) In addition, NCARE supports the ERCR Plan because it provides for continued development of zero-emission new renewable energyresources in Nevada. (!d.) NCARE also notes that the coal plant retirement and elimination portion ofthe ERCR Plan places NV Energy in a strong position to comply with EPA's Proposed Carbon Rule ("lll(d) Draft Regulations"). (!d.) Finally, NCARE observes that the ERCR Plan accomplishes these desirable environmental and regulatory objectives in a manner that provides greater resource diversity and with lower costs to ratepayers than any ofthe alternative plans developed by Nevada Power. (!d. at 18, 24.) SNHG95. SNHGrecommends that the Commission modify Nevada Power'sproposed Preferred Plan byexcluding the MoapaProject as a company-owned facility. (Ex. 54 at 21.) SNHGconsiders LV Cogen and Sun-Peak acquisitions to be reasonable; however, SHNG raises
a number ofconcerns with regard to the MoapaProject. (ld. at 9.)DocketNos. 14-05003 & 14-06022 Page 39 96. First, SNHG contends that the Moapa Project shouldbe a part ofcompetitivelybidrenewable replacement capacity rather than a part ofNevada Power's utility-owned 550 MW ofnon-technology-specific replacement capacity. (/d.) SNHG states that generating projects that
are part ofthe 550 MW company-owned capacity come in at firm generating capacity, while projects that are a part ofthe 350 MWrenewable capacity come in at nameplate capacity. (/d. 9- 10.) With the Moapa Project coming in at only 76 MWfirm capacity as part ofthe 550MW package, although it could be added at 200 MW nameplate capacity as part ofthe 350 MW package, SNHG is convinced that such a scenario ofadding costly company-ownedrenewable generation was not contemplated, nor required, by SB 123. (/d. at 10.) 97. Second, SNHG contends that the Moapa Project is not the least-cost approach to meeting the 550 MW ofnon-technology-specific capacity. (/d.) With the Sun-Peak and LV Cogen acquisitions supplying 496 MW ofreplacement capacity, SNHG suggests filling the remaining 54 MW with a combustion turbine instead offilling it with 200 MW ofsome ofthe most expensive power available. (/d.) SNHGcontrasts an estimated $85 million cost ofsuch a turbine with the $438 million MoapaProject price tag. (/d.) To support its proposition, SNHG cites to a scenario proposedby BCP, which replaced the MoapaProject with a 71 MW combustion turbine coming on-line in 2018. (/d. at 11-12.) SNHGreports that the present value savings from the BCP's scenario, compared to the Preferred Plan, are $121 million after 10 years, $79 million after 20 years, and $64 million after 30 years. (/d. at 12.) 98. SNHG further observes that, according to Nevada Power's PROMOD 10 output report including the 71 MWcombustion turbine, the facility would run only one hour, in the year 2040, and thus would be practicallyunnecessary. (/d. at 12.) With the 71 MW combustion

10 PROMOD is a production cost model and a proprietary software product that Nevada Power licenses from Ventyx, an ABB Company. (Exhibit 4 at 257.)Docket Nos. 14-05003 & 14-06022 Page40 turbine removed, SNHG finds the Preferred Plan even more expensiveby comparison: $180 million after 10 years, $173 million after 20 years, and $163 million after 30 years. (/d. at 13.) SNHG calculates that leaving the MoapaProject in the ERCRPlan will result in a $50 million rate increase in NevadaPower's 2017 general rate case. (/d. at 14.) 99. Third, SNHG contends that the Moapaplant addition is too costly to ratepayers as Nevada retail electric rates are already secondhighest among the 22 contiguous western states. (/d. at 15-17.) 100. Fourth, SNHG contends that the MoapaProject is premature as a company-owned project. (/d. at 18.) SNHG asserts that the marketprice for independent solarprojects maybe lower than theprice ofa utility-owned project due to the requirement that utilities must normalize the lTC over the life ofthe project while independent powerproducers can take the credits up front. (/d.) SNHG further states that competitivebids for the first 100 MW of renewable energy to be opened in January 2015 will likely show that the MoapaProject would costless ifit were competitivelybid as a PPA contract. (/d.) 101. SNHG also notes that Nevada Power will have sufficient credits to meet its RPS
even without the MoapaProject. (/d. at 17.) 102. SNHG concludes thatthe Preferred Plan cannot satisfy the NRS 704.746(8) criteria. (ld at 18.) SNHG asserts that the Preferred Plan carries too high ofa cost to ratepayers. (/d. at 19.) SNHG finds that the Preferred Plan does not provide the greatest economic benefit to Nevadabecause all ofthe economic benefits that might result from the construction and operation ofthe Moapaplant can be realizedjust as well ifthe MoapaProjectis a part ofthe 350 MWrenewable capacityreplacement. (/d.) Furthermore, SNHG asserts that it is more expensive for the State to add 550MW ofrenewables overthe next few years than it would be tojustaddDocket Nos. 14-05003 & 14-06022 Page 41 the 350 MW ofrenewables expressly provided for in NRS 704.7316(b). (/d. at 20.) SNHGfinds that the Moapaplant does not provide for the greatestjob opportunities in Nevadabecause those
samejobs would still exist even ifthe Company did not own the Moapa Project and because the electric rate increases associated with the plant will hamperjob growth. (/d. at 20.) Finally, SNHG states that the Moapa Project does not represent the best value to Nevada Power customers because they would have to pay an extra $311 million overthe first ten years ifthe plant is brought in as a company-ownedresource rather than as a competitively-bidresource. (/d. at 14, 20.) Ormat 103. Ormattakes an issue with Nevada Power's proposal to recover $1.9 million of development costs for siting activities near the Harry Allen substation. (Ex. 61 at 8-9.) Based on Nevada Power's filing in Docket No. 13-06023, Ormat contends that Nevada Powerplans to offer the lands it acquires from the Bureau ofLand Management ("BLM") to third-party developers ofsolarprojects in the upcoming RFPs. (/d. at 9.) Ormat states that such projects could ultimately be ownedby Nevada Power under a "build-transfer" option. (/d.) Ormat asserts that renewable RFP solar bidders using Nevada Power sites may have less risk to develop their projects and, thus, may have an unfair advantage over wind, geothermal, biomass, andbiogas projects that cannot take advantage ofNevada Power's sites. (/d. at 10.) To level the playing field, Ormatproposes that bidders thatuse Nevada Power's sites internalize the costs ofland in theirbids, including Nevada Power's development costs in obtaining the rights to those lands, and, ifabidderis successful, ratepayers should receive a refund for the development costs approved under Nevada Power's proposal. (/d. 10-11.)DocketNos. 14-05003 & 14-06022 Page 42 104. Ormat advocates fair bidevaluation in the upcoming annual competitive renewable RFPs. Ormatproposes evaluation that reflects the full costs, benefits, and risks of different renewable resources. Ormatproposes that consideration shouldbe given to (1) incremental system costs, including ancillary services and integration costs inherent in different
resource types, (2)job creationbenefits, (3) varying degrees ofoperational flexibility renewable
resources provide, ( 4) ratepayer risks stemming from different procurement models, such as greater uncertainty in costs associated with utility-owned generators versus a PPA, and (5)
measures to prevent utility affiliate bids, orbids that ultimately result in utility ownership, getting an unfair advantage. (!d. at 11.) To address these considerations, Ormat proposes specific bid rules, including requiring Nevada Powerto incorporate integration costs of$10/MWh in its evaluation ofsolar PV bids in the upcoming renewable RFPs and setting out special conditions for utility-owned projects. (!d. at 22-39.) BCP 105. BCPrecommends that the Commissionfind that the economic impact analysis providedbyNevada Poweris unclear in its benefits and negative attributes to the State of Nevada. (Ex. 64 at 3.) BCP addresses Nevada Power's economic analysis filed in response to NAC 704.9357 and NAC 704.9453(7), which consists ofthe analysis for the four alternative
cases providedbyNERA Economic Consulting and the Moapa analysis preparedbyApplied Analysis. (ld. at 3-4.) 106. BCPfinds the NERA economic analysis flawed because the inputs analyzed by NERA differ from the modeling results included in the ERCRfiling. (ld. at 4-5.) According to BCP, Nevada Power continued to negotiate various agreements and further develop the Preferred Plan subsequent to providing its modeling inputs to NERA on March 19, 2014. (ld. at 4.) BCPDocket Nos. 14-05003 & 14-06022 Page 43 cites Moapa construction costs as an example ofdiscrepancy. (!d. at 7.) According to BCP, the construction expenditures provided to NERA equal $577.7 million (includes $43.3 million AFUDC) while the construction expenditures in the ERCR Plan filing equal $471.6 million (includes $33.5 million AFUDC). (!d. at 7.) Such discrepancy affects Nevada gross domestic product ("GDP"), employment, personal income, and state/local tax impact calculations and potentiallybelies Nevada Power's conclusion that Case C is preferable to the other cases because ofits more direct and immediate economic impacts in 2015 and 2016. (!d. at 5-7.) Other input differences involve the amount ofenergy produced, changes regarding the timing ofplant, lower capital expenditures for certain plant, and higher expenditures for others. (!d. at 5-6.) 107. BCP also finds flaws with the economic analysis ofthe Moapa Project conducted by Applied Analysis. BCP observes that the analysis does not compare the cases and instead analyzes only the MoapaProject, thereby limiting the usefulness ofthe analysis for IRP decisions. (!d. at 8.) BCP also disagrees with Applied Analysis's thejob creation calculation method and the inputs Applied Analysis used. BCP asserts that the Moapa Project will create 2,082job years over 30 years, as it counts the netjobs created, not the 2,434 grossjob years calculatedby Applied Analysis without accounting for thejobs lost early in the life ofthe Project due to the overall energyprice increase. (!d. at 8, 9, 11.) BCP notes that the offered analysis suffers from a timing problem and from the use ofan improper discount rate. (!d. at 10.) Having recalculated the net economic impact using properinputs, BCP estimates total economic output for the Project at $161 million, rather than $181.5 million, and total wages at $50.2 million, rather than $60.5 million. (ld. at 11.) 108. BCP further states that it is unclear how NevadaPower weighed the many other factors outlined inthe regulations in arriving at the selection ofCase Cas the Preferred Plan.Docket Nos. 14-05003 & 14-06022 Page 44 (!d.) Finally, BCP is concerned that the survey provided to the 20 largest employers pursuant to NAC 704.9453(7)(c) raises questions because it contained generalities and lacked information that would produce informedresponses. (!d. at 12.) 109. BCPrecommends that the Commission approve Nevada Power's request to acquire the Sun-Peak facility, LV Cogen 1, and LV Cogen 2 and reject Nevada Power's request to construct and own the MoapaProject. (Ex. 66 at 8-9, 21.) BCP considers the Nevada Powerowned Moapa Project too costly and unnecessary and disagrees with Nevada Power's assertion that the project provides resource diversity. BCP asserts that spending nearly a half-billion dollars on a project intended to fulfill only 54 MW ofnon-technology-specific 550 MW of capacity is excessive. (!d. at 9.) BCP states that the goal can be met more economicallyby constructing a 71 MW combustion turbine in 2018, for a $64 million 30-yearPWRR difference. (!d. at 9, 11.) However, BCP notes that the combustion turbine also appears unnecessary, as it
was not dispatched in production cost modeling except for two hours in 2040. (!d. at 11-12.) Without the 71 MWcombustion turbine, BCP calculates even greater savings for ratepayers in the form ofa $108 million 30-year PWRR difference. (Ex. 67 at 3.) BCP states that the differential between the Preferred Plan and the Preferred Plan without the Moapa Project is even greater ifthe integration costs ofthe Moapa Project are taken into account; the result is a $143 million 30-yearPWRR difference with $2/MWh integration cost. (Ex. 66 at 15-16; Ex. 67 at. 5.) BCP concludes that, for every one dollar in economic benefitrelated to Moapa, ratepayers are subsidizing three dollars ofcosts. (Ex. 67 at 6.) 110. BCP also provides the results ofa levelized cost ofenergy ("LCOE") analysis it performed. BCP calculates the MoapaProject's LCOE at $111 perMWh, while the LCOE ofa hypothetical combined cycle is approximately $70 perMWh underbase fuel and purchasedDocket Nos. 14-05003 & 14-06022 Page 45
power conditions and $103 per MWh under high fuel and purchased power conditions. (Ex. 66 at 16-17.) BCP argues that this result also illustrates that the MoapaProject does not offer a hedge to natural gas volatility and undermines the resource diversity that Nevada Power credits the Preferred Plan with achieving. (/d.) BCP's comparison ofMoapa's LCOE with the LCOE ofan approved renewable PPA and renewable placeholderLCOE for the RFPs also shows that Moapa's LCOE is high. (/d. at 17-18.) BCPexplains that Moapa's high LCOE is attributable to NevadaPower's inability to take the entire amount oflTC in the first year, as non-utility
resource owners can. (/d. at 19.) The LCOE ofMoapa would drop to $89 perMWh ifNevada Power were able to take the entire lTC in the first year. (/d. at 19.) 111. BCPprovides data on anticipated efficiencyimprovements and cost decreases of First Solar'spanels to argue that, ifa project similar to Moapais to beconstructed with First Solarpanels in 2018, the system cost couldbe similar to or lower than the current systems using the 30 percent lTC advantage. (/d. at 20.) Thus, BCP argues the Moapa Project, which is to use current, less-efficient First Solarpanels, should not be rushed to attain the 30percent lTC. (/d.) 112. Finally, BCP argues thatthe MoapaProject is unnecessary. BCP states that the plant is unnecessary for RPS compliance because the Preferred Plan, which effectively provides 550 MW ofrenewable resources, would extend the RPS compliance into 2033 under base load conditions while the Alternate Plan or the Preferred Plan minus Moapa would extend RPS compliance until2027. (/d. at 10.) BCP argues that SB 123 did not contemplate the addition of 550MW ofrenewable generating capacity. BCP states that the Legislature, havingbeen supplied with BCP's analysis showing RPS compliance until2030 with 600 MW ofrenewable, chose to reduce the original NV Energyproposal for 600 MW ofrenewable capacity to 350 MW. (/d.)Docket Nos. 14-05003 & 14-06022 Page 46 113. Noting the comparativelyhigh LCOE ofthe Nellis Project, BCPdoes not oppose the Nellis Project and recognizes the value to ratepayers from the 2.4 multiplier for renewable credits. (ld. at 21-22.) Staff 114. Staffrecommends the Commission approve the acquisition and construction of the generation and transmission assets presented in NevadaPower's Preferred Plan. (Ex. 76 at 3.) However, Staffrecommends the Commission deem the economic analysis performedby Nevada Power inadequate and order modifications to the Plan. (!d. at 4.) 115. Staffstates that the rushed preparation ofthe First Amendment Application led to the inclusion ofinaccurate orunreliable information within the Application, such as inaccurate PWRR and PWSC calculations. (ld. at 6.) Additionally, Staffasserts that the Preferred Plan and the resources within it were pre-selectedbefore any PWRR and PWSC databecame available. (!d.) One ofthe examples Staffprovides to support its assertion is that Nevada Power committed to First Solar supplying equipment for the MoapaProject on April4, 2014- before PWRR analysis was completed andbefore the PWSC data was received from NERA. (!d. at 7.) 116. Reflecting on whether the Preferred Plan comes at an attractive costto the customers ofNevadaPower and represents the best value to them, 11 Staffdisagrees with Nevada Power's PWRR analyses and its statements that the Preferred Plan delivers the lowest 20-year PWRRin six ofthe 12 scenarios. (Ex. 79 at 18-19.) Staffcontends that Nevada Power made at least seven major modeling errors that skew the PWRR analyses in favor ofthe Preferred Plan. (ld. at 19.) First, Staffstates that Nevada Power overestimated capital costs ofCase A by including the cost ofan unnecessary water treatment facility. (ld. at 19-20.) Staffstates that the

11 NRS 704.746 items (a) and (d).Docket Nos. 14-05003 & 14-06022 Page 47

errorresulted in an overestimation ofCase A's 20-year PWRRby $20 million. (ld. at 20.) Second, Staffnotes that Nevada Powerfailed to include $37.3 million ofadditional capital upgrades for LV Cogen units within its CER analysis. (/d.) Staffcalculates correction ofthis
error results in the 20-year and 30-yearPWRRs ofthe Preferred Plan being understated by $35 to $45 million. (ld.) Third, Stafffinds that Nevada Powerhas loaded the Alternate Plan with more expensive geothermal renewable placeholders while allocating comparatively more PV renewable placeholders to the Preferred Plan. (ld. at 21.) Staffcalculates correcting this issue would lower the 20-year PWRR ofCase A by $9 million and the 30-yearPWRRby $28 million. (ld.) Fourth, Staffnotes that Nevada Power overestimatedthe MoapaProject annual output because it used its consultants' estimates rather than the manufacturer's performance guarantee figure. (ld.) Staff's adjustment ofthe annual output increases the 20-year PWRR for the Preferred Plan by approximately $4 million and the 30-yearPWRRby approximately $5 million. (ld. at 22.) Fifth, Stafffinds that Nevada Powerunderestimated O&M costs for the Moapa Projectbecause it used lower preliminary O&M costs as opposed to the actual O&M figures provided in the contracts. (ld.) Staff's adjustment increases the 20-year PWRRfor the Preferred Plan by $3 million and the 30-yearPWRRby $4 million. (ld.) Sixth, Staffstates that Nevada Powerfailed to adequately explain the reason(s) for the necessity ofadding four additional transmission reliability improvements in Case A but not Case C. (ld. at 22-23.) These additional projects result in the 20-year PWRRfor Case A being overstatedby $27 million and the 30-year PWRRbeing overstated by $33 million. (ld. at 23-24.) Finally, Stafffinds that Nevada Power overestimatedthe cost ofCase A by applying an improperproperty tax rate. (ld. at 24.) Staff relates that Nevada Powerplans to locate the combined cycle unit at Reid Gardner and, accordingly, should use the rural property tax rate as ithas done in the past. (/d.) StaffstatesDocket Nos. 14-05003 & 14-06022 Page 48 that, instead ofthe lowerrural property tax rate of2.7 percent, Nevada Powerused a higher Clark Countyblended rate of3.03 percent, which overestimates the 20-year PWRRby about $5 million and the 30-yearPWRRby about $6 million. (/d.) Staffstates that accounting for all
seven errors results in the Preferred Planbeing approximately $105 million more expensive than the Alternate Plan on a 20-yearbasis and approximately $201 million more expensive on a 30- yearbasis under the Base Case Mid-Carbon scenario. (/d. at 25-26.) 117. Staff states that, PWRR comparisons aside, the Preferred Plan does not offer significant advantages over the Alternate Plan in terms ofresource diversification or carbon emissions. (/d. at 27.) Staffcites Nevada Power data which shows that, under the Preferred Plan, Nevada Powerreduces its natural gas exposure by only four percent and its spot market exposure by only two percent comparedto the Alternate Plan. (/d. at 26.) Stafffurther points to Nevada Power data that show the Preferred Plan performing worse than the Alternate Plan under a high carbon scenario. (/d. at 27.) Staffprovides Nevada Power's explanation for this seeming irregularity

- that less efficient conventional resources, which are used during some peak load hours, emit more carbon and perform with higher heat rates than Case A's combined cycle unit. (/d.) 118. Staffagrees with BCP that Nevada Power's failure to include an alternative plan containingLV Cogen 1, LV Cogen 2, Sun-Peak, Nellis Project, and a small combustion turbine instead ofthe Moapa Projectrepresented an omission, and such an alternative would have been
more economical. (/d. at 28-29.) 119. Nevertheless, Staffsupports the acquisition and construction ofthe individual
resources comprising the Preferred Plan as long as the Commission approves the modifications and conditions Staffis recommending. (/d. at 29-32.) Staffnotes the high cost ofthe Nellis andDocket Nos. 14-05003 & 14-06022 Page 49 MoapaProjects expressed in LCOEs of$121.92 and $111.45, respectively, but agrees with Nevada Power's assessment ofthe benefits ofthe Projects, such as retention ofNellis AFB as a Nevada Power customer, the Nellis Project eligibilityfor the 2.4 portfolio creditmultiplier, location ofboth projects within the Las Vegas valley load pocket, and eligibility ofboth projects for the federal 30percent lTC. (!d. at 30-33.) 120. Staff's first proposed ERCR Plan modification states that the Commission's approval should be contingent on Nevada Power acquiring orbuilding all the generation
resources comprising the Preferred Plan. (!d.) Staffincluded this condition to protect ratepayers in case Nevada Poweris unable to close on the acquisition ofone or more ofthe generation assets that comprise the Preferred Plan. (!d. at 37.) Staffis concerned with the cost ofthe Preferred Plan should Nevada Powerbe unable to complete opportunistic acquisitions ofLV Cogen 1, LV Cogen 2, or Sun-Peak to offset the high cost ofthe MoapaProject. (/d.) 121. Staff's second modification proposes that, with the approval ofthe Preferred Plan, the Commission should find that Nevada Powerhas fulfilled the requirement ofNRS 704.7316(2) with regard to the construction or acquisition ofthe entire 550MW companyowned, non-technology-specific capacity. (!d. at 4.) 122. Staff's third modification suggests that, with the approval ofthe Preferred Plan, the Commission should find that NevadaPowerhas fulfilled the requirement ofNRS 704.7316(2)(b)(6) with regard to the construction or acquisition ofall 50 MW ofcompanyownedrenewable generation. (!d. at 4). Staffnotes that the 15 MWnameplate capacity Nellis Project and block 1ofthe MoapaProject with 45 MW nameplate capacity exceed the 50MW requirement ofNRS 704.7316(2)(b)(6). (!d. at 38). At the same time, Staffobserves that the remaining four blocks ofthe Moapa Project, together with the conventional generation beingDocketNos. 14-05003 & 14-06022 Page 50 acquired, have planning capacity of555 MW and, thus, satisfy the 550MWrequirement ofNRS 704.7316(2)(c). (!d. at 39.) Staffasserts that NRS 704.7316 does not preclude segregation ofa
resource to fulfill more than one replacement capacity category. (!d. at 40.) Staffstates that removing the need to construct the additional35 MW ofsolar PV results in the 20-year PWRR for the Preferred Plan decreasing by approximately $53 million and the 30-yearPWRR decreasing by $61 million. (ld. at 42.) 123. Staff's fourth modification proposes that, with the approval ofthe Preferred Plan, the Commission find that Nevada Poweris obligated to protect and insulate ratepayers from any performance orwarranty issue that may arise with the Moapa orNellis Projects, which results in the annual output ofthe facilities falling below the supply table amounts used in this filing. (!d. at 4-5.) Staffdoes not agree with Nevada Powerthat the contractual protections and performance guarantees Nevada Powerreceived from the Moapa and Nellis Projects' developers adequately protects ratepayers. (ld. at 43.) Staffis concerned that Nevada Power may not vigorously pursue its contractual remedies or that the ratepayers may be subject to a lagbetween the equipment malfunction and subsequent recovery by Nevada Power. (!d.) Staffargues that company-owned resources should be subject to the same conditions as independentproducers'
resources supplying electricity to Nevada Powerunder a PPA: when energy supply falls below what was contracted for, independent producers pay for any shortfall in supply regardless of whatever recourse they may have. (Jd. at 43-44.) 124. Staff's fifth modification proposes that, with the approval ofthe Preferred Plan, the Commission find that only the initial construction and acquisition costs ofthe generating facilities within the Preferred Plan qualify for the incentivized accounting treatment outlined in NRS 704.7317. (!d. at 47.) Staffopposes Nevada Power's request to include $4.53 million ofDocket Nos. 14-05003 & 14-06022 Page 51 potential future capital investment in Sun-Peak along with the actual purchase price ofSun-Peak
as acquisition costs in the special NRS 704.7317 regulatory asset account. (Ex. 76 at 3-4.) Staff argues that, pursuant to NAC 704.95245(2)(a), only the acquisitionportion ofthe Sun-Peak investment qualifies for regulatory asset treatment. (!d. at 5.) Stafffurther notes that, although NAC 704.9453(4) allows for regulatory asset treatment ofancillary utility facilities, such facilities must be necessary for the operation or interconnection ofgenerating facilities included in the ERCR Plan. (!d. at 5-6.) Staffasserts that the $4.53 million worth ofupgrades cannotbe necessary for the operation or interconnection ofSun-Peakbecause (1) the facility is already interconnected to the Nevada Power system and has been operating reliably since 1991, and (2) Nevada Powerhas relied upon the Sun-Peak capacity in its loads and resources tables for years without the proposed upgrades. (!d. at 6.) Staffagrees with Nevada Power that the Company would not be incurring the expense ofthese upgrade projects but for the acquisition ofSun-Peak; however, Stafffinds this an insufficient qualifier for the regulatory asset treatment. (!d. at 8.) Staffargues that Nevada Power's interpretation would allow any subsequent investment in an ERCR facility to qualify for the special treatment in perpetuity and limit the Commission's review at the next appropriate general rate case for such capital expenses. (!d. at 8-9.) 125. Stafffurther states that there is no basis in the accounting rules to grant regulatory asset treatment to the Sun-Peakupgrades investment. (Ex. 78 at 10-11.) Using the FERC's Uniform System ofAccounts ("USOA") as guidance, Staffstates that the costs ofacquisition are charged to Account No. 102, Electric Plant Purchased or Sold, while any plantimprovements are accounted for in Account No. 107, ConstructionWorkin Progress. (!d. at 10.) Stafffurther references the Electric Plant Instructions for Electric Plant Purchased or Sold, which state that if
an operating unit acquired requires substantial rehabilitation to meet the standards ofthe utility,Docket Nos. 14-05003 & 14-06022 Page 52 the cost ofsuch work shall be accounted for as a part ofthe purchase price. (/d.) Staffdoes not believe such accounting treatment isjustifiedinthis case because Sun-Peak has been operatedby Nevada Powerfor many years and has apparently met Nevada Power's operating, reliability, and safety standards during thattime. (/d.) 126. Staffis concerned with the high cost ofthe land lease for the Moapa Project. (Ex. 79 at 47-48.) Staffnotes that the Moapa lease is considerably more expensive than the lease cost ofa similarproject located on BLM land. (/d. at 48.) To counteract the high cost ofthe lease, Staffproposes the Commission orders Nevada Powerto aggressively pursue two amendments to the lease agreement. (/d. at 52.) The first amendment wouldrequire the MoapaBandofPaiutes, the landowner, to agree not oppose any future action taken byNevada Powerto permit and construct new natural gas generation facilities at the existing Reid Gardner site. (/d.) The second amendment would require the Moapa Band ofPaiutes to support the use ofthe Moapa Project as
a renewable energy facility for the State's use for compliance with the EPA's 111(d) Draft Regulations. (/d.) Staffasserts that the first proposed amendment to the lease will deliver value to ratepayers by greatly reducing the costs ofplacing into operation new combined cycle gas generation at the Reid Gardner site. (/d. at 49.) Staffnotes that such facilities wouldbe located
on a potential brownfield site with both electric and natural gas transmission access. (/d.) 127. Staffrecommends that the Commission reject Nevada Power's request to spend $1.9 million on initial siting activities for one ormore proposed new solar PV facilities to meet Nevada Power's RPS and the additional renewable energy requirements ofNRS 704.7316(2)(b)(6) and NRS 704.7316(2)(c). (Ex. 75 at 4.) Staffargues thatNevadaPowerhas fulfilled the requirements ofNRS 704.7316(2)(b)(6) and NRS 704.7316(2)(c) through its Preferred Plan with regard to construction or acquisition of50 MW ofcompany-ownedDocket Nos. 14-05003 & 14-06022 Page 53 renewable nameplate capacity and 550MW ofnon-technology specific capacity. (/d. at 7.) Furthermore, Staffcontends that NevadaPower does not require any new renewable generation to comply with its RPS because, as shown in the Renewable Energy Plan, Nevada Power is projected to be compliantthrough at least 2030. (/d.) While Staffrealizes the value ofBLM land leasing, Staffnotes that Nevada Power does not have a need for additional renewable energy in the near, intermediate, or long-term planning future. (/d.) Accordingly, Staffargues against granting resource planning approval for the $1.9 million request to expend funds to develop land for potential projects that are not needed and have yet to be approved bythe Commission. (/d. at 7-8.) 128. Staffis concerned that conversion ofsolar PV nameplate capacity into planning capacity using the 38 percent factor is no longer accurate. (Ex. 74 at 3.) Staffargues that, with the introduction ofmore solar PV facilities serving NevadaPower's load and Air Conditioning LoadManagement ("ACLM") demand response program, Nevada Power's systempeakis shifting to a later time ofday. (/d. at 4-5.) With the systempeak occurring at a time ofday when solarresources are not contributing much electricity, Staffsuspects solar PV planning capacity value maybe lowerthan 38 percent. (/d. at 5) Staffproposes the Commission direct Nevada Powerto perform an analysis ofthe appropriate capacity value for PV generating resources for planning purposes moving forward. (/d. at 6.) For the updated planning capacity value to be applicable to proposals responsive to the three 100 MWrenewable RFPs, Staffsuggests that the analysis befiled as part ofthe IRP amendment filing earlyin 2015 to coincide with Nevada Power'srequest for Commission approval ofthe first 100MW ofrenewable energy. (/d. at 6.) 129. Staffrecommends that the Commission approve Nevada Power'srequest to issue three 100 MW RFPs for renewable resources pursuant to the schedule providedin the ERCRDocket Nos. 14-05003 & 14-06022 Page 54 Plan. (Ex. 73 at 2.) Staffrepresents that the schedule createdbyNevada Poweris compliant with NRS 704.7316(2)(b), reasonable, and consistent with parties' discussions. (ld. at 2-3.) Staff notes that Nevada Power is not obligated to accept the winning RFP bids, but to merely negotiate in good faith to construct, acquire, or contract with the winning RFP bidders. (/d. at 3-4.) Furthermore, Staffnotes that the Commission retains discretion to approve any and all winning bids' resulting PPAs in future IRP filings. (/d. at 5.) 130. Staffrecommends that the Commissionfind that Nevada Power's Renewable Expansion Plan is a reasonable method to comply with the RPS throughout the 30-yearplanning period. (/d. at 5.) Staffobserves that Nevada Power created an individualized Renewable Plan for each ofthe four ERCR Cases. (/d.) Staffnotes that Nevada Power added generic placeholder projects to each individualized Renewable Plan with the goals ofminimizing the overall number ofplaceholders and the amount ofsurplus PCs and without apparent regard for cost or the ability to move renewable energy producedin northernNevadato the Nevada Power service territory. (/d. at 6-7.) Staffdoes not take issue with the generic renewable placeholder selection from the perspective ofcreating a Renewable Plan to model one potential way to maintain RPS compliance. (ld. at 7.) However, Staffexpresses concern regarding the same generic placeholders influencing the ranking ofthe Cases bybeing factored in the PWRR calculation and modeled in NERA's economic impact analysis. (ld.) 131. Staffrecommends that the Commission find that the NERA report does not provide reliable information to supportthe Preferred Plan. (/d. at 10.) Staffstates that, for the purpose ofevaluating ERCR Plan alternatives according to the NRS 704.746 criteria, the NERA report shouldhave been the frontrunner tool for picking the preferredplan, as it quantifies economic benefits andpotential forjob creation for the four alternative cases. (/d. at 12.) StaffDocketNos. 14-05003 & 14-06022 Page 55 questions the usefulness ofthe report in evaluating the alternatives, observing that the report was created at the same time as the ERCR Preferred Plan, and thus couldnot have influenced the selection, and that the report was based on inaccurate and outdated inputs. (/d. at 13.) 132. Staffargues that the Commission cannot make planning decisions based upon the environmental cost analysis numbers presented in the report because the PROMOD results used
as inputs in the report differ from the final PROMODresults used in the ESP Update, and NevadaPoweris unsure whether the use ofthe final PROMOD results would have changedthe rankings ofthe four cases. (/d. at 13-14.) 133. Staffargues that the Commission cannot make planning decisions basedupon the economic impact analysis presentedin the report. (/d. at 15.) Staffnotes that, pursuant to NAC 704.9357, the NERA Report modeled the changes ineconomic activity in Nevada over the 20- yearplanning periodfor Nevada GDP, employment, personal income, and state and local tax payments. (/d. at 14.) Staffasserts that the modeling results do not provide adequate comparison ofthe impacts ofalternative cases onthe Nevadaeconomybecause the cases have different generic renewable placeholders that arbitrarily influence electricityprices among the Cases. (/d. at 15-16.) 134. Staffargues that the Commission should not make planning decisions based on the Applied Analysis' report, which examinedthe net economic impact ofthe MoapaProject. (/d. at 17.) Staffnotes that Applied Analysis compared the benefits from the MoapaProject to the benefits ofa scenario in which NevadaPowerbuys power at market rates rather than the benefits ofthe Alternate Plan, specifically,job creation and economic benefits from a new combinedcycle plant. (/d.) As such, Staffcontends that the Applied Analysis report provides little value for the Commission's decision-making. (/d.)Docket Nos. 14-05003 & 14-06022 Page 56 135. Staffsupports granting a waiver ofthe requirement contained in NAC 704.9453(8). (Ex. 79 at 15.) Staffstates that its review ofNevada Power's relevant confidential documents demonstrated that other possible opportunities to fulfill the 550MW ofcompanyowned generation were either not viable or were notripe enough to be compared against the conventional resources included in the Preferred Plan. (!d.) Staffalso notes that denying the waiver request would essentially amount to rejecting the entire ERCR filing. (!d.) Nevada Power Rebuttal 136. In response to Griffith's advocacy oflong-termbenefits ofa PPA between Nevada Power and Griffith, Nevada Power cautions against over-reliance ontolling agreements, such as the one in place with Griffith. (Ex. 93 at 30-31.) Nevada Power states that reliance on non-company-owned resources carries its own cost and riskprofile. (!d. at 31.) As an example, Nevada Power states that the payments associated with the Griffith contract are not insignificant and, without the fuel cost used for generation at the plant, will resultinpayments of$47.3 million in 2015, $48.75 million in 2016, and $50.2 million in 2017 payments. (ld.) 137. Nevada Power disagrees with SNHG's proposal to remove the Moapa Project from the Preferred Plan. (Ex. at 26-27.) First, NevadaPower disagrees with SNHG's assertion that the 200 MW capacity ofthe Moapa Project can only be counted towards renewable capacity ofthe three 100 MWRFPs, not the 550 MW ofnon-technology-specific capacity. (ld. at 27.) Nevada Powerfinds such a position inconsistent with the plain language and history ofNRS 704.7316. (ld.) Nevada Power contends the statute does not prohibit inclusion ofa solar PV facility as part ofits 550MW company-owned portion ofthe ERCRPlan. (!d.) Second, Nevada Power disagrees with SNHG's assertion that the Preferred Plan is not the least-cost capacity replacement approach. (ld. at 28-29.) NevadaPowerobserves that, in reaching its conclusion,Docket Nos. 14-05003 & 14-06022 Page 57 SNHGlooked at the PWRRs ofthe base cases only, neglecting to consider that the Preferred Planperformed equally as well as Case A across six ofthe 12 scenarios with varied load growth, fuel prices, and carbon prices, and better than Case B across the board. (!d. at 29.) Nevada Powerfurther notes that the Preferred Plan has positive attributes not present in Cases A and B, such as replacing Reid Gardnerunits 1-3 on January 1, 2015, improving fuel diversity, and diminishing exposure to natural gas markets. (/d. at 29-30.) Finally, Nevada Power does not find the two alternative expansion plans proposed by SNHG appealing because they disrupt the balanced outcome achieved by the Preferred Plan. (/d. at 30.) 138. To alleviate Ormat's concerns that PVresources will be given an unfair advantage in the upcoming NRS 704.7316(2)(b) 100MW RFPs over othertypes ofrenewable generation through availability ofNevada Power-procured sites for PV resources, Nevada Power states that the prorated land permitting and developing costs will be added to the pricebid submittedby any bidders seeking to use any portion ofsuch site. (Ex. 82 at 15-16.) With regard to the 100 MW RFP bid evaluation criteria, NevadaPower states that bid evaluation criteriarecommended by Ormat is the subject ofongoing Docket No. 13-06023 and should not be adopted as part ofthe ERCR Plan. (!d. at 16.) 139. Nevada Power disagrees with the BCP's assertion that any party canpropose a different combination ofreplacement capacity options for NevadaPower'sERCRPlan. (Ex. 93 at 24-25.) Nevada Power cites to NRS 704.741(8) for the proposition that any Commission orderrejecting ormodifying an element ofthe ERCR Plan, unless accepted byNevada Power, will result in the withdrawal and subsequentre-filing ofa new ERCR Plan. (/d. at 25.) 140. Nevada Power opposes the adoption ofthe alternative plan developed by BCP, which includes substituting the MoapaProject with a 71 MW combustion turbine. (/d. at 25-26.)Docket Nos. 14-05003 & 14-06022 Page 58 First, Nevada Power notes that such a plan does not increase fuel diversity, does little to create jobs and advance the development ofrenewable energyin Nevada, and introduces a high-heat rate peakingunit. (ld. at 26.) Second, NevadaPower asserts that the BCP-developedplan upsets the careful balance ofcustomer and Company interests achieved by combining the high-cost Moapa Project with low-cost gas acquisitions ofexisting facilities. (/d. at 26.) 141. Nevada Power claims that BCP's comparison ofthe MoapaLCOE with the published LCOE from three different solar projects is not useful. (Ex. 82 at 14-15.) Nevada Power explains that the first two comparisons are to proxyprojects that have no sites orpermits, while the third comparison is the SNWA project with vastly different physical characteristics and contractual provisions. (/d. at 15.) Nevertheless, Nevada Power concedes the validity ofBCP's discussion ofthe importance ofthe ability to monetize the lTC as a critical componentto the economics. (/d. at 15.) Nevada Power notes, however, that the PPA describedbyBCP as an alternative to the company-owned Moapa Project does not offer the same benefits of30-year
resource ownership with the unilateral option to extend production at the site for an additional 20 years. (ld.) 142. Nevada Power states that BCP's economic analysis does not represent comprehensive resource planning practices, which led BCPto draw incorrect conclusions. (Ex. 92 at 19.) NevadaPower argues thatBCP overstates the savings ofremoving the 71 MW combustion turbine from the BCP-developedplan that includes Sun-Peak, LV Cogen 1, LV Cogen 2, Nellis, and the 71 MW combustion turbine in place ofthe Moapa Project. (/d. at 17- 18.) NevadaPower observes that BCP failed to account for the capacity value providedbythe combustion turbine: $57 million over 20 years and $72 million over 30 years. (/d.) Nevada Power further states that BCP incorrectly applied case-specific renewable placeholder savings toDocket Nos. 14-05003 & 14-06022 Page 59

an unrelated case and failed to realize that the MoapaProject integration costs were already accounted for in the analysis. (!d. at 18) 143. Nevada Power disagrees with Staff's assertion that the results ofthe Company's analysis were predetermined and that modeling was performed to achieve certainresults. (Ex. 93 at 20.) Nevada Power states that the fact that its initial case matrix considered Case C, which included a generic 200 MW solar facility, does not mean the Preferred Plan was predetermined. (/d. at 21.) NevadaPowerfurther states that the modeling inputs for a generic 200 MWPV facility were refined and updated to reflect the characteristics ofthe transaction that was being negotiated for the MoapaProject. (!d. at 21.) 144. NevadaPower agrees with Staff's recommendation that the approval ofthe ERCR Plan be predicated on the Company's ability to acquire and construct all ofthe generation requested in the Preferred Plan. (!d. at 24.) 145. With respect to Staff's assertion that approval ofthe Preferred Plan satisfies the entire need for 50MW ofCompany-owned renewable generation under NRS 704.7316(2)(b)(6), Nevada Power agrees that a decision adopting such a view would obviate the need and expense associated with Nevada Power constructing and owning an additional 35 MW ofrenewable energy resources by 2021. (!d. at 32.) Nevada Powernotes that Staff's recommendation to deem the 50MWcapacityfulfilled with the approval ofthe Preferred Plan maintains the integrity of the replacement capacitypackage and produces an acceptable alteration ofthe regulatory recovery balance. (!d.) NevadaPower disagrees with Staff's calculations ofthe impact the removal ofthe 35 MW ofadditional capacity will have on Case C PWRR. (Ex. 92 at 13.) Nevada Power states that taking into account the effect ofthe removal on capacity costs, the cost ofthe replacement capacity, the removal ofthe O&M for the 35 MWPV facility, and the impactDocket Nos. 14-05003 & 14-06022 Page 60

on the future renewable placeholders results in the 20-year PWRR for Case C decreasing by only $23 million and the 30-yearPWRR decreasing by only $27 million. 12 (!d.) 146. Nevada Power disagrees with Staff's analysis ofthe seven alleged modeling
errors in Nevada Power's economic analysis. (Ex. 92 at 4.) First, Nevada Power argues thatthe $22 million wastewater treatment facility cost was properlyincluded within the $699 million cost assumedfor a new combined cycle unit ofCase A. (!d. at 5.) NevadaPower states the cost
can onlybe excluded once the project is approved, a brownfield site that negates the need for the wastewater treatment facility is selected, and site-specific engineering has been completed. (!d.) Nevada Powerfurther argues that, ifthe cost adjustment is made to Case A, then it must be made to Case C as well because Case C contemplates the addition ofa combined cycle unit at 2020, which has the same "likely" location at Reid Gardner. (!d. at 6.) Second, NevadaPower disagrees with Staff's assertion that Nevada Powerfailed to include $37.5 million ofadditional upgrades for LV Cogen units within its analysis. (!d. at 6.) Nevada Power states that such costs
are not normally included for the purposes ofresource cost modeling, and similar costs were not included in Cases A and B either, because such costs are uncertain. (!d. at 7.) Third, Nevada Power agrees with Staffthat replacing geothermal renewable placeholders with PV renewable placeholders in CaseA lowers the 20 and 30-yearPWRRs ofCase A as calculatedby Staff. (!d. at 8-9.) Fourth, Nevada Power also agrees with Staffthat the final, reduced, energy output estimates for the MoapaProject were not captured in the filed Case C. (!d. at 9.) Fifth, Nevada Power agrees with Staffthat the final, increased O&M estimates for the MoapaProject were not captured in the filed Case C. (!d.) Sixth, Nevada Power disagrees with Staff's observation that Nevada Powerincorrectly omitted costs for the four transmission upgrade projects from Case C

12 Staffcalculated the 20-year PWRRdecrease of$53 million and 30-yearPWRR decrease of$61 million.DocketNos. 14-05003 & 14-06022 Page 61 that were included in Case A. (/d. at 9-10.) Nevertheless, NevadaPower concedes that Case C should have included three ofthe four transmission upgrade projects with an in-service date of 2025 and increased the 20-year PWRRfor Case C by $16 million and the 30-yearPWRRby $22 million. (/d. at 10-11.) Seventh, NevadaPowerdisagrees with Staffthat a site-specific property tax rate should have been used for the 2018 combined cycle Unit in Case A. (/d. at 11.) Nevada Power states that a site-specific property tax rate is inappropriate until the project is approved and site-specific engineering is complete. (/d.) Nevada Power states that adjusting the relative cost data in accordance with the calculations and arguments above results in the PWRR difference between Cases A and C that is much smaller than that suggested by Staff: a $33 million difference in the 20-year PWRR and $61 million difference in the 30-yearPWRR. (!d. at 12.) 147. Taking into account the effects ofthe seven modeling points and the removal of the 35 MWPV project, Nevada Powerrecalculates that Case Cis $12 million more expensive than Case A in the 20-year term and $98 million more expensive in the 30-yearterm. (/d. at 15.) Nevada Powerpreviously calculated a 20-year PWRR difference of$2 million and 30-year PWRR difference of$64 million. (/d.) 148. Nevada Power disagrees with Staff's recommendation that Nevada Power's customers should befurther insulated from any performance orwarranty issues that may arise during the projected operating lives ofthe Moapa orNellis Projects. (Ex. 82 at 11.) Nevada Power states that ithas negotiated agreements with the developers ofboth Projects that provide for equipment warranties, tie compensation to performance, and utilize liquidated damages to enforce compliance with performance requirements. (/d.) Nevada Power acknowledges that itis accountable for enforcing the terms and conditions in the agreements negotiated in the Nellis andDocket Nos. 14-05003 & 14-06022 Page 62 Moapa Projects. (/d. at 12.) Nevada Power states that terms and conditions ofPPAs do not insulate customers from all performance issues as insinuatedby Staff. (/d. at 12-13.) Nevada Powerrepresents that, once a resource is on-line, the seller under a PPA has significant flexibility to modify its supply tables with no recourse orpenalty. (/d. at 13.) Nevada Power repeatedly states that to fully insulate customers from all performance risk, the cost provisions of the Nellis and Moapa Projects will have to be renegotiated. (!d. at 11-12.) 149. Nevada Power opposes Staff's recommendation for the Commission to order NevadaPowerto amend the Moapa Solar lease agreement as part ofthe ERCRPlan approval. (Ex. 82 at 13-14.) Nevada Power states that it is not yet a partyto the lease agreement and is not in the position to seek concessions from the Moapa Band ofPaiutes regarding future development at the Reid Gardner site. (/d.) 150. Nevada Power disagrees with Staff'srecommendation that the $4.53 million cost ofupgrades at the Sun-Peakfacility should not receive regulatory asset treatment. Nevada Power argues that Staff's recommendation does not fully recognize the plain language ofthe statutes and regulation governing the ERCR Plan. (Ex. 93 at 8.) Referencing the same FERC USOA instructions relied upon by Staff, Nevada Powerfirst states that the $250,000 environmental monitoring equipment project is necessary to bring the existing conditions at SunPeak into conformance with environmental requirements that apply to Nevada Power and should be accountedfor as part ofthe Sun-Peak acquisitionprice. (Ex. 93 at 11.) Nevada Powerfurther argues that the $3.35 million control systems replacement project and the $150,000 work management systemproject should also be included in the Sun-Peak acquisition price as NAC 704.9453(4) "facilities necessary for the operation orinterconnection ofan electric generating plant
...." (!d. at 11-12.) NevadaPower asserts that these projects make the conditions at theDocketNos. 14-05003 & 14-06022 Page 63 Sun-Peak facility conformto the uniform standards that Nevada Power applies to its generating units and allows it to operate the plant as described in the current staffing plan. (Ex. 93 at 12; Ex. 80 at 3.) Nevada Power also continues to advocate for regulatory asset treatment ofthe battery bankreplacement project at Sun-Peak. (Ex. 93 at 13.) Nevada Power claims that the project is a safety item and reflects standardpractice. (!d.) Nevada Power asserts that, for the four projects above, continued Sun-Peak operation without completion ofthese projects may present future safety, operational, or regulatory and reliability risk. (Ex. 80 at 3.) Nevada Power stresses that these projects are mandatory ifNevada Power is to own and operate Sun-Peak. (ld.) Nevada Power states that these investments were not required to have been completedbythe current
ownerbecause the facility operated under a finite contract term and under a business model different from NevadaPower's. (ld. at 4.) 151. Nevada Power agrees with Staff's point that the building enclosure project should not be accounted for as part ofthe acquisition costbecause it is not necessary for integration of the facility. (Ex. 93 at 14.) NevadaPower states that it intends to establish in a future ratemaking proceeding that the actual costs ofthe projects werejust and reasonable and that it realizes that the integration project costs presented arejustestimates. (Jd. at 14-15.) Finally, Nevada Power contends thatthe LV Cogen 1, LV Cogen 2, and Sun-Peakupgrade projects that, which develop uniform conditions across the Company's centralized generation fleet, should receive the regulatory treatment described in NRS 704.7317. (ld. at 15.) 152. NevadaPowerdisagrees with Staff's recommendation to reject $1.9 million in permitting costs for new solar generating capacity. (Ex. 82 at 7.) While NevadaPower agrees with Staffthat new solar generating capacityis not needed to comply with Nevada's RPS, NevadaPowernotes that the sites procuredby Nevada Power couldbe used to attract a largerDocket Nos. 14-05003 & 14-06022 Page 64 pool ofbidders for the three 100MW RFPs ifNevada Power can offerbidders a permitted site for theirprojects. (!d. at 7-8.) Nevada Power also notes that, alternatively, the permitted site would be available for the 35 MW ofcompany-owned renewable nameplate capacity. (/d. at 9.) 153. With regard to the accounting treatment ofthe permitting costs, Nevada Power explains that it is merely seeking a prior determination thatit is reasonable to spend $1.9 million in the 2015 period as set forth in Table AP-4, Exhibit 2 at page 24. (Transcript at 601.) Nevada Powerfurther represents that such costs would be deferred into either a construction work in progress or a study cost account and will ultimately receive enhanced ratemaking treatment only ifthe permitted site turns into an ERCRproject. (Tr. at 601-02.) 154. Nevada Power disagrees with Staff'srecommendation to order the Company to conduct a study ofappropriate planning capacity value for solar PV facilities. (Ex. 93 at 15-16.) While Nevada Power does not disagree with the direction ofthe study, it disagrees with the timing and method ofthe proposal. (!d. at 16.) Nevada Powercontends that the study submission date ofearly 2015 does not provide enough time to properly examine the issue and that the development ofa common understanding ofthe analytical approach that will be used and the scope ofthe study shouldprecede the commencement ofthe study. (!d.) 155. In response to Staff's recommendation to find that the NERA report does not provide reliable economic analysis, and also addressing BCP's criticism ofNevada Power's economic analysis, NevadaPower claims that the NERAreport provides sufficient information to assist the Commissionin determining whether to accept the Preferred Plan. (Ex. 93 at 19.) Nevada Power argues that discrepancies between the data analyzed byNERA and the data in the filing do not render the NERA report unreliable, but rather affect the evidentiary weight ofthe report. (!d. at 19-20.) NevadaPowerclaims that, even though NERAhas notperformed itsDocketNos. 14-05003 & 14-06022 Page 65 environmental cost and economic impact analyses using the final information, NERA's estimates oftotal environmental costs and total economic impacts would probably change onlyby small amounts from switching to the final information. (Ex. 44 at 3-5.) Nevertheless, Nevada Power acknowledges that determining changes in case rankings in terms ofenvironmental costs and economic impacts would not be possible without redoing the analyses because (1) the differences between the preliminary and final information are numerous and span a wide range in size, (2) the changes offset one another in various ways, and (3) the net economic impacts depend on the interplay between expenditures and revenue requirements. (I d. at 6-7.) Commission Discussionand Findings 156. NRS 704.7316 requires Nevada Powerto file with the Commission, as part ofits plan submitted pursuant to NRS 704.741, "acomprehensiveplan for the reduction ofemissions from coal-fired electric generating plants and the replacement ofthe capacity ofsuch plants with increased capacityfrom renewable energy facilities and other electric generating plants." 157. The emissionreduction component ofNevadaPower'sERCR Plan must provide for the retirement of"not less than 300 megawatts ofcoal-fired electric generating capacity on or before December 31, 2014;" "not less than 250 megawatts ofcoal-fired electric generating capacity on orbefore December 31, 2017;" and "notless than 250 megawatts ofcoal-fired electric generating capacity on orbeforeDecember 31, 2019." (NRS 704.7316(2)(a)(l)-(3), respectively). 158. Thecapacity replacement component ofNevada Power's ERCR Plan must provide "[f]orthe construction or acquisition of, orcontracting for, 350 megawatts ofelectric generating capacity from renewable energy facilities," (NRS 704.7316(2)(b)), through a staged RFP process, specifically, staged and conducted as follows:DocketNos. 14-05003 & 14-06022 Page 66 (1) Issue a request for proposals for 100 megawatts ofelectric generating capacity from new renewable energyfacilities on orbefore December 31, 2014; (2) In addition to the request for proposals issuedpursuantto subparagraph (1), issue a request for proposals for 100 megawatts ofelectric generating capacity from new renewable energyfacilities on orbefore December 31, 2015; (3) In addition to the requests for proposals issuedpursuantto subparagraphs (1) and (2), issue a request for proposals for 100 megawatts ofelectric generating capacityfrom new renewable energy facilities on orbefore December 31, 2016; (4) Review each proposal received pursuant to subparagraphs (1), (2) and (3) and identify those renewable energy facilities that will provide: (I) The greatest economicbenefit to this State; (II) The greatest opportunity for the creation ofnewjobs in this State; and (III) Thebest value to customers ofthe electric utility; (5) Negotiate, in good faith, to construct, acquire or contract with the renewable energy facilities identifiedpursuant to subparagraph (4), and file with the Commission an amendment to the plan each time the utility wishes to construct, acquire orcontract with such facilities; and (6) Begin, on orbefore December 31, 2017, the construction or acquisition ofa portion ofnew renewable energy facilities with a generating capacity of50 megawatts to be owned and operatedbythe electric utility, and complete construction of such facilities on orbefore December 31, 2021.

**~** Forthe purposes ofthis paragraph, the generating capacity ofa renewable energy facility mustbe determined by the nameplate capacity ofthe facility. (NRS 704.7316(2)(b)(l)-(6).) 159. Moreover, the capacity replacement component ofNevada Power's ERCR Plan must provide for NevadaPower "to construct or acquire and own electric generating plants with
an electric generating capacity of550 MW, which must be constructed or acquired to replace, in
an orderly and structured manner, the coal-fired electric generating capacity retired or eliminated pursuant to [NRS 704.7316(2)(a)]." (NRS 704.7316(2)(c).) Nevada Power's ERCR Plan may also include "additional utility facilities, electric generating plants, elements orprograms necessary to carry outthe plan." (NRS 704.7316(3).) 160. NRS 704.746(8) requires that the Commission"
... after a hearing, review and accept ormodify an emissions reduction and capacityreplacement plan which includes each elementrequired byNRS 704.7316." Under NRS 704.746(8), the Commission shall considerDocket Nos. 14-05003 & 14-06022 Page 67 each ofthe following in determining whetherto accept ormodify an emissions reduction and capacityreplacement plan: (a) The costto the customers ofthe electric utility to implement the plan; (b) Whether the plan provides the greatest economic benefit to this State; (c) Whether the plan provides the greatest opportunities for the creation ofnew jobs in this State; and (d) Whether the plan represents the best value to the customers ofthe electric utility. 161. NAC 704.9453 outlines the information and action items that must be included in
an ERCRfiling. One such requirement is the electric utility's proposal ofan RFP process "that will be used to provide for a comparative analysis ofthe alternatives available for the 550 megawatts ofelectric generating capacity to be constructed or acquired and ownedbythe utility pursuant to [NRS 704.7316(2)(c)]." (NAC 704.9453(8).) Specifically, NAC 704.9453(8) requires that the electric utility's proposed RFP process provide: (a) a timeline for the issuance of requests for proposals and the evaluations ofproposals; (b) a clear definition ofthe product or products sought in the request for proposals process; and (c) evaluation criteria, including, without limitation, bidder and resource criteriathat is consistent with the considerations to be assessed pursuant to NRS 704.746(8). (NAC 704.9453(8)(a)-(c).) 162. NevadaPower omits the foregoing RFP process from its ERCR Plan, instead seeking deviation from NAC 704.9453(8) because the "opportunistic acquisitions of [the three facilities identified in Nevada Power'sERCR Plan] would not benefit from the information that would result from the request for proposals process described in [NAC 704.9453(8)]." (Ex. 2 at 16.) Specifically, Nevada Power asserts that "the opportunistic acquisitions set forth in the ERCR Plan, the beneficiaries ofwhich are the customers ofNevada Power, would likely have not been available if, instead ofpursuing negotiations with the owners ofthese projects in time toDocket Nos. 14-05003 & 14-06022 Page 68 include these projects in this ERCRPlan, Nevada Powerhad merely developed and proposed the request for proposals process described in [NAC 704.9453(8)]." (Id.) 163. Under NAC 704.0097, the Commission maypermit deviation from its regulations if: (1) good cause appears for the deviation; (2) the personrequesting the deviation provides a specific reference to each provision from which the deviation is requested; and (3) the Commission finds that the deviation is in the public interest and is not contrary to statute. 164. In analyzing Nevada Power's ERCRplan, the Commission must address the emissionreduction component ofNevada Power's ERCR Plan in relation to a corresponding capacityreplacement component that is provided in the Plan. Specifically, NRS 704.751(6) requires that "[a]ny order issued bythe Commission accepting an element ofan emissions reduction and capacity replacement plan must include provisions authorizing the electric utility to construct or acquire and own electric generating plants necessary to meet the capacity amounts approved in, and carry out the provisions of, the plan." Accordingly, by approving an emission reduction, the Commission must also approve a corresponding capacityreplacement that provides the same amount ofcapacity as the retired oreliminated capacity, but the corresponding replacement capacity mustbereplaced in an "orderly and structured manner" as prescribed by NRS 704.7316(2)(c). 165. Each ofthe foregoing rules and regulations must be given due effect, as any inconsistency or ambiguity among the individual statutes and/or regulations would eliminate the ability ofthe Commission to act consistently under itsjurisdiction. In other words, effect must be given to each statute and regulation developed in response to SB 123 in order to harmonize the entire statutory and regulatory scheme that the Legislature has provided to the Commission. Therefore, the Commissionrejects the premise assertedbythe Companythat its Preferred PlanDocket Nos. 14-05003 & 14-06022 Page 69 shouldbereviewed in its entirety andjudged without reference to its individual parts. Such an interpretation prevents the Commission from carrying outits statutory duty to analyze whether the components ofNevada Power's ERCR Plan satisfy the considerations outlined underNRS 704.746(8) and prevents the Commission from approving a plan that permits Nevada Powerto replace its retired or eliminated capacity in an "orderly and structured manner" as prescribed by NRS 704.7316(2)(c). Nevada Power's interpretation ofthe statutory scheme adopted inresponse to SB 123 circumvents the Commission's authority to review and approve or modify a plan to
ensure that it is in the public interest. In other words, it limits the ability ofthe Commission to reject portions ofa plan that, standing on their own, would be considered imprudent. Such an interpretation contravenes NRS 704.7321 byrestricting, ifnot eliminating, the Commission's ability to modify an ERCRplan, thereby severely undermining the Commission's duty and authority under NRS 704.746(8) to consider customer costs, economic benefit to the State, greatest opportunity forjob creation, and best customer value. Such a result is not in the public interest.166. Accordingly, the Commission reviews the capacity replacement component of Nevada Power's ERCR Plan, which has been identified as the Preferred Plan orCase C, as it corresponds with the emission reduction component ofNevada Power'sERCRPlan approvedby the Commission inparagraph 49 ofthis Order. In assessing the merits ofeach proposed acquisition enumeratedin Nevada Power's ERCRPlan, the Commissionharmonizes the considerations outlined in NRS 704.746(8) and NRS 704.7316(2)(c) and considers the public interest in determining whether deviation from NAC 704.9453(8) is warranted for each component ofthe 550MW ofutility-owned replacement capacity. IllDocket Nos. 14-05003 & 14-06022 Page 70 LV Cogen 1and 2 and Sun-Peak 167. In its Preferred Plan, Nevada Powerproposes to acquire LV Cogen 1and 2 and Sun-Peak, rather than proposing an RFP process that couldbe used to provide for a comparative analysis ofthe alternatives available for the replacement electric generating capacity. In seeking deviation from the requirement that it propose an RFP process for this replacement capacity, Nevada Power states that deviation from NAC 704.9453(8) is warranted because ofthe "opportunistic" nature ofthese acquisitions. (Ex. 2 at 16.) The Commission agrees; good cause exists to circumvent the prescribed RFP process in favor ofacquiring these relatively inexpensive electric generating units. The Company contends, and Staffand BCPboth agree, that these units represent good value for customers when considering the cost ofacquiring these
resources compared to the costs ofnew peaking or combined cycle resources. 168. Specifically, the Commission agrees with BCP that: (1) "[b]oth facilities are located within the load pocket ofthe Las Vegas Valley which under Nevada Power ownership
assures an ongoing commitmentto Nevada loads in lieu ofthe retirement ofthe Reid Gardner coal units of550 MW electrically within the Las Vegas Valley load pocket;" (2) "the location within the load centerprovides a unique value to the system versus resources located outside;" (3) "[t]hese acquisitions at prices noted earn high marks in regard to cost to customers and offers value benefits ofbeing located in the load pocket;" and ( 4) "the acquisition ofthe Las Vegas Cogen facility assures the sustainability ofapproximately 25jobs through 2036." (Ex. 66 at 7.) 169. Moreover, the Commission agrees with Staffthat "[t]hese three generating
resources have been reliably serving Nevada Power's load for more than 12 years," and that "they provide very unique attributes that would be difficult to replace ifNevada Power were to look to capacity from other generations options." (Ex. 79 at 30.) The Commission is persuadedDocket Nos. 14-05003 & 14-06022 Page 71 by Staff's opinion that "NevadaPower appears to have performed a reasonable due diligence review on these resources," and that "Staffsees benefits in having these resources remain a part ofNevada Power's generating fleet going forward." (!d.) 170. The Commission further agrees with Staffthat "the capacity acquisition cost of these resources, $477 perkW for the LV Co-Gen bundle and $71 perkW for Sun-Peak are attractive when comparedto the current cost ofconstructing new combined cycle and peaking capacity." (!d.) Staffstates that under Nevada Power's Alternate Plan, Case A, Nevada Power "assumed the new overnight cost ofa combined cycle unit added in 2018 to be $699 million." (!d. at 19.) Indeed, based on the evidence in this Docket, the dollarperkW for LV Cogen 1and 2 and Sun-Peak should be considered a competitivepricebecause it is significantly less than the cost ofa new combined cycle unit. The Commission's analysis yields estimated capital costs of approximately $1,170 perkW for a new combined cycle resource and $1,100 per KW for new peaking resources. (See generally Exhibit 11 and Exhibit 4.) Therefore, the acquisition ofLV Cogen 1and 2 and Sun-Peak should be considered good value for Nevada Powercustomers. 171. Based onthe evidence inthis Docket, the Commission grants Nevada Power's request to deviate from NAC 704.9453(8) because the Commission agrees that the "opportunistic" nature ofthese acquisitions warrants deviation from the prescribed RFP process. Specifically, the Commission finds that good cause exists for deviation from the RFP process regarding the replacement capacity that would be fulfilled bythese three facilitates because of the low cost ofthese acquisitions relative to the high cost for construction ofsimilarreplacement capacityunits. The Commission further finds that deviation in this instance is in the public interest and not contrary to statute given that the acquisition ofthese three facilities harmonizes the considerations outlined in NRS 704.746(8) by providing Nevada Powercustomers withDocket Nos. 14-05003 & 14-06022 replacement capacity at good value without disrupting the orderly and structured process prescribedby NRS 704.7316(2)(c). Page 72

172. Consistent with the foregoing findings, the Commission approves Nevada Power's request to acquire LV Cogen units 1and 2, and the Sun-Peakfacility. The Commission finds the costs ofthese facilities reasonable when compared to the current cost ofconstructing
new combined cycle andpeaking capacity units, and notes that all parties supported, or at least did not oppose, the acquisition ofthese three replacement units. Therefore, given the evidence
on this record, the Commission agrees with Nevada Powerthat the proposedprice for LV Cogen 1and 2 and Sun-Peak are "extremely favorable for customers" 13 and fulfills the requirements of NRS 704.746(8). Moapa Project 173. Bythe Commission accepting Nevada Power's proposal to acquire LV Cogen units 1 and 2, and the Sun-Peakfacility, acquisitionsthatrepresent a total replacement capacity of496 MW, Nevada Power is statutorily authorized to own, construct and/or acquire an additional 54 MW ofelectric generating capacity to complete its 550-MW entitlement. The Commission recognizes that, ifit authorizes Nevada Powerto retire 800 MW ofcoal generation, it must then approve a plan for Nevada Powerto construct, acquire, orcontract for 800 MW of replacement capacity. As it currently stands, the emissions reduction portion ofthis plan approves the retirement of812 MW ofcapacitybetween today's date and 2019. NevadaPower's Preferred Plan proposes that the 812 MWbereplaced as follows: (1) 224 MWfrom LV Cogen 2
on January 1, 2015; (2) 222 MWfrom Sun Peak on June 1, 2016; (3) 76 MWfrom Moapa Solar
on October 1, 2016; (4) 50 MWfrom LV Cogen 1 on October 1, 2016; (5) 15 MWfrom the

13 Exhibit 2 at 14.Docket Nos. 14-05003 & 14-06022 Page 73 Nellis Project (discussed below) byDecember 31, 2015; and (6) through the issuance ofRFPs for 100MW ofrenewable energy in 2014, 100 MW ofrenewable energyin 2015, and 100 MW ofrenewable energy in 2016. The total capacity yielded from these totals is approximately 887 MW. 174. Based upon these numbers, Nevada Power'sproposal requests that the Commission allow Nevada Powerto over-fill the 550-MW "Non-Technology Specific" replacement capacitybucket. Specifically, Table S-2 in Nevada Power's Summary ofits ERCR Plan, designated as Exhibit 3in this Docket, shows that, ifthe MoapaProject was approved in conjunction with Nevada Power's acquisition ofLV Cogen 1and 2 and Sun-Peak, the total MW capacity that Nevada Power wouldbe obtaining exceeds 550MW, as the four projects total 572 MW ofreplacement capacity, or 22 MWmore than the replacement capacity contemplatedby NRS 704.7316(2)(c). (Ex. 3 at 4.) While the Commission acknowledges that its regulations allow Nevada Power to provide a "reasonable description ofthe electric generating plant or plants with a total generating capacity of

### approximately 550 megawatts that the utility proposes to construct or acquire and own" under its Preferred Plan in its ERCRPlan (NAC 704.9453(4)(a) (emphasis added)), the Commission, in adopting NAC 704.9453(4)(a), did not intend that this provision allow the utility to stretch the term "approximately" to cover a 22-MW overage. Certainly, the Commission did not contemplate that NevadaPower would use the latitude afforded byNAC 704.9453(4)(a) to propose a replacement facility that would unnecessarily, and contrarily to its entitlement under NRS 704.7316(2)(c), costratepayers upwards of$126 million. 14

14 The Commission presumes that the overage amount would come from the highest-costresource.Docket Nos. 14-05003 & 14-06022 Page 74 175. Moreover, Nevada Power's assertion that the MoapaProject is well-positioned to allow the Company to take advantage ofthe lTC is much less persuasive when considering the BCP's and SNHG's concerns that the utility would be required to take the 30 percent lTC over the life ofthe facility, while an independent power producer could utilize the entire credit up front in the first year. (Ex. 54 at 18.) According to the BCP, "
...the [lTC] of30 percent can be taken all in the first year under non-utility structure versus over the book life ofthe projectunder
a utility structure." (Ex. 66 at 18.) More specifically, BCP states that ifNevada Power could receive the whole lTC in the first year similarto an independent powerproducerunder a nonutility structure, ratepayers could save approximately 20 percent. (!d.) Therefore, it follows that Nevada Power's proposal to obtain the Moapa Project under a utility-build and ownership model is 20 percent more expensive than ifthe same project was developed by an independent power producer. 176. The Commission shares Staff's concerns regarding the high costs ofthe land lease for the Moapa project. After reviewing the confidential dataregarding the lease payment for the Moapa Project, the Commission has concerns that the lease payment is excessive, but cannot determine the extent to which the lease payment may be excessive because the Moapa Project
was not compared to other projects, a comparative process that would have occurred had Nevada Powerproposed an RFP process rather than seeking deviation from NAC 704.9453(8) for this portion ofits ERCR Plan. 177. The Moapa Project's $50.2 million increase to Nevada Power's revenue requirement in 2017 may have a significant effect on the creation ofjobs in Nevada. Nevada Power's customers, including nearly every employer in Nevada Power's service territory, already pay some ofthe highest electric rates in the region. (Ex. 54 at 15-16.) However, theDocket Nos. 14-05003 & 14-06022 Page 75 Moapa Project's 640job-years represents only the positive effect onjobs. The immediate impact tojobs in Nevadafor 2016 is a loss of292jobs. Even at the end ofthe 20-yearplanning period, thejobs lost are 12 in 2027. (Ex. 64 at 8.) The Moapa Project's effect onjob-growth is inconclusive. 178. The Moapa Project does not provide much value for Nevada Power's customers in meeting the RPS. Even without the Moapa Project, Nevada Power will have excess RPS credits through 2027. (Ex. 12 at 232; Ex. 53 at 17; Ex. 73 at 8.) 179. While the fuel-free MoapaProject mitigates Nevada Power's customers' exposure to the risk ofnatural gas volatility, the MoapaProject is not unique in this regard and would result in only a slightly larger portion ofNevadaPower's generation portfolio, both energy and capacity, not being dependent on natural gas in 2018. (Ex. 93 at 29-30; Tr. at 605-606.) The 110- MW Crescent Dunes SolarEnergy Project is scheduled to come on-line in late 2014, and the ERCR Plan's 15-MW Nellis SolarArray II is scheduled to come on-lineby December 31,2016. 15 Further, as mandated by NRS 704.7316(2)(b)(1-3), RFPs for 300 MW ofrenewable electric generating capacity will be issued on orbefore December 31, 2016. All ofthese other projects will mitigate Nevada Power's customers' exposure to the risk ofnatural gas volatility. 180. Additionally, the Commission is concerned with whether the MoapaProject, to be situated on tribal land, counts towards the State's compliance with the EPA's 111(d) Draft Regulations. The record in this Docketregarding whether the MoapaProject would count toward compliance with EPA'sproposal is nebulous and inundated with speculation, considering the fact that EPA'sproposal does not address carbon emissions ofexisting generating units on tribal lands and the fact that the 111(d) Draft Regulations have yet to be finalized and will be

15 Pursuant to NRS 704.7316(2)(b)(6), Nevada Power will be authorized to construct or acquire an additional35 MWs ofelectric generating capacity from new renewable energy facilities by December 31, 2021.Docket Nos. 14-05003 & 14-06022 Page 76 subjecttojudicialreview. In short, any proposedrenewable project not on tribal land seemingly has more value than the Moapa Projectfor purposes ofcompliance with the Ill(d) Draft Regulations. Intheir current form, NevadaPower acknowledges that there is a risk that the MoapaProject does not meet the proposed lll(d)requirements, butbelieves the risk to be small, and states that it is willing to share this risk with its customers. (ld. at 585.) However, the Commission's concerns regarding the MoapaProject's compliance with the lll(d) Draft Regulations are not assuagedby a shared riskbetween the utility and its customers, especially given that the MoapaProject may be an unnecessary risk in the first place. Additionally, the Commission is required to not only protect the interests ofNevada Power's customers, butit is charged with protecting the interests ofNevada Power's shareholders, as well. Accordingly, while NevadaPower may be willing to take a risk with the MoapaProject, the Commission will not subject Nevada Power's shareholders orcustomers to unnecessary risk. 181. Moreover, given the timing ofthe Commission's review ofthe Plan, the value of the Moapa Project cannotbe compared to the values ofotherrenewable projects. The Commission does not know the current market price ofsolar PV power or any otherrenewable power (solar thermal, geothermal, wind, biomass, etc.) in this State. Prior to this proceeding, the Commission's lastreview ofa new renewable project for Nevada Power occurred in 2011 (Docket No. 11-03014). 16 The market price for renewable power will be more establishedjust three months from now when the bids for the first 100 MW ofcompetitivelybidpower are opened in January 2015. The RFP is open to all resources and will presumably serve as the forum for comparing costs and other factors (i.e. dispatchability, load characteristics, location,

16 In Docket No. 13-11007, the Commission reviewed a geothermal PPA for Nevada Power thatreplaced a PPA approved in Docket No. 11-03014. The power and credits from the McGinness Hills geothermal generating facility were substituted for the already-approved Dixie Meadows site and included a $2.6 million termination payment for the benefit ofratepayers.DocketNos. 14-05003 & 14-06022 Page 77 etc.) ofthe various proposals. Following the RFP, the Commission will have a basis for comparison ofa company-owned solar PV project to various renewable powerprojects owned byindependent powerproducers. 17 Implementing the ERCR Plan with the inclusion ofthe Moapa Project does not appear to represent thebest value to NevadaPower's customersbecause the MoapaProject's value to Nevada Power's customers is seemingly negligible. 182. Therefore, under these facts and circumstances, the evidence on this record does not enable the Commission to adequately review the MoapaProjectunder the four considerations outlined in NRS 704.746(8). That is, it is inconclusive as to whether the Moapa Project's cost to Nevada Power's customers to implement the plan is reasonable; whether the projectprovides the greatest economic benefitto the State; whether the projectprovides the greatest opportunity for the creation ofnewjobs in this State; and whether the projectrepresents the best value to Nevada Powercustomers. Ifa finding must be made at this time given the
concerns and considerations discussed herein, the Moapa Project mustbe found to fail to meet the standards outlined in NRS 704.746(8). 183. However, as discussed earlier, the Commissionrecognizes that ifit authorizes Nevada Powerto retire 800 MW ofcoal generation, it must then approve a plan for Nevada Powerto construct, acquire or contract for 800 MW ofreplacement capacity. As it currently stands, the emissions reduction portion ofthis plan approves the retirement of812 MWbetween today's date and 2019. Nevada Power's Preferred Plan proposes that the 812 MWbe replaced as follows: (1) 224 MWfrom LV Cogen 2 on January 1, 2015; (2) 222 MWfrom Sun Peak on June

17 While Nevada Power stated that a direct comparison ofthe MoapaProject lease to a prospective BLM lease is not possible, Staffprovided information demonstrating additional annual costs for the MoapaProjectlease on tribal land compared to annual costs for a prospective lease on BLM land. (Ex. 75 at 6:9-25, Attachment AED-8.) Staff's comparison demonstrates that the lease agreement and acquisition premium for the Moapa Project appear to be expensive. (Ex. 79 at 9:5-11.)Docket Nos. 14-05003 & 14-06022 Page 78 1, 2016; (3) 76 MWfrom Moapa Solaron October 1, 2016; (4) 50MWfrom LV Cogen 1on October 1, 2016; (5) 15 MWfrom the Nellis Project (discussed below) on by December 31, 2015; and (6) through the issuance ofRFPs for 100 MW in 2014, 100MWin 2015, and 100 MWin 2016. The total capacity yielded from these totals is approximately 887 MW. 184. In orderto grant Nevada Power deviation from NAC 704.9453(8) to bypass the RFP process to construct and acquire the MoapaProject, the Commission mustfind that, based
onthe evidence provided in this Docket, good cause exists to authorize Nevada Powerto spend a significant premiumfor 76 MW ofplanning capacity. Moreover, not only mustthe Commission find that good cause exists to approve this component ofNevada Power's Plan, the Commission must find that bynot requiring NevadaPowerto propose an RFP process (that would seemingly address all ofthe Commission's concerns regarding the MoapaProject), the Commissionis acting in the public interest and consistent with statute. 185. Therefore, the Commission denies NevadaPower's request to deviate from NAC 704.9453(8) regarding the 54-MW vacancy that would have been satisfiedby the MoapaProject under Nevada Power's ERCR Planbecause approval ofthe MoapaProject to fulfill this vacancy is not in the public interest given the Commission's substantial aforementioned concerns. Moreover, Nevada Powerhas failed to show that good cause for deviation exists, as the Commission finds that the evidenceprovided in this Docket does not show that deviation regarding the project wouldbe in the public interest. Finally, considering that the Commission acknowledges that the project fails to meet the standards outlinedunderNRS 704.746(8), a Commission finding thatNevadaPowermay deviate from NAC 704.9453(8) regarding these 54 MW would be contrary to statute. Accordingly, in denying NevadaPower's request to deviateDocket Nos. 14-05003 & 14-06022 Page 79 from NAC 704.9453(8) regarding these (approximately) 54 MW, the Commission deems this portion ofNevada Power's ERCR Plan inadequate. 186. However, recognizing that it must provide NevadaPower with the authority to construct, acquire, and/or own sufficient generating capacitynecessary to meet the provisions of NRS 704.751(6) and 704.7316(2)(c), the Commission, to fulfill the 54-MW vacancy that would have been satisfiedbythe Moapa Project, orders Nevada Powerto file, byJanuary 1, 2015, an RFP process pursuant to NAC 704.9453(8) or, alternatively, an amended plan seeking approval ofa specific project that satisfies a request for deviation underNAC 704.0097 and allows the Commissionto adequately assess the proposed project under considerations listed in NRS 704.746(8). The Commission finds that these directives provide Nevada Power with the necessary authority to acquire plant necessary to meet the provisions ofits Plan. 187. This result is consistent with the Legislature's charge to this Commissionto not only allow the utility to replace its coal-fired generation fleet with similar capacity, natural gas, and/orrenewable energy generating facilities, but its charge to ensure that ratepayers are insulated from unnecessarily high costs associated with such replacement, that Nevada Power customers benefitfrom a project that represents the best value available to them, and that any emission reduction and capacity replacement plan proposed by the utility provides the greatest economic benefit and chance forjob growth in this State. Nellis Project 188. The Commission agrees with Staffthat the Nellis SolarProject "provides some unique benefits that outweigh the high cost ofthe project.
.." (Ex. 79 at 30.) Specifically, the Commission agrees with Staff'sposition that: (1) the Nellis SolarProject will allow Nevada Powerto keep Nellis AFB as a full retail requirements customer, allowing Nevada PowertoDocket Nos. 14-05003 & 14-06022 Page 80 avoid "apotential departure ofa large load customers;" (2) the projectis eligible for the 2.4 portfolio credit multiplier contained in NRS 704.7822 because it can be constructedbefore December 31, 2015; (3) the project will be electrically located within the Las Vegas valley load pocket, providing certain reliability benefits; and (4) the projectbenefits from being eligible for the 30 percent ITC because it can be constructed before December 31,2016. (!d. at 31.) Therefore, for all the foregoing reasons, the Commission approves Nevada Power'srequest in its ERCR Plan to construct the Nellis Project. Renewable RFPs 189. The Commission approves Nevada Power's request to issue three 100-MW RFPs for renewable resources based on the schedule set forth in the ERCR Plan. The issues raised by Ormat have or will be addressed in Docket No. 13-06023, the rulemaking resulting from SB 123. Siting Activities 190. The Commission approves Nevada Power's request to spend $1.9 million on initial siting activities related to one or more proposed solar PV generating facilities northeast of Las Vegas. Nevada Power acknowledges and the Commission agrees that these costs would be deferred into either a construction work in progress or a study cost account and will ultimately receive enhanced ratemaking treatment only ifthe permitted site turns into an ERCRproject. The Commission finds this expense is reasonable because it couldbe used to attract a larger pool ofbidders for the three 1 00-MW RFPs ifNevada Power can offer bidders a permitted site for their projects, resulting in lower-cost projects. Ill Ill IllDocket Nos. 14-05003 & 14-06022 Page 81 Renewable Expansion Plan 191. The Commission approves Nevada Power's Renewable Expansion Plan as set forth in Section 2.D ofthe Supply Side Plan and finds that the Renewable Expansion Plan is a reasonable method to comply with the portfolio standard throughout the 30-yearplanning period. Incentivized Accounting Treatment 192. Nevada Poweris only eligible to receive incentivized accounting treatment pursuant to NRS 704.7317 on the initial construction costs and/or acquisition price for the generating facilities approved in this Order and costs associated with upgrades to the facilities that are required by state orfederal law. This incentivized accounting treatment does not apply to any capital upgrades, additions made after the acquisition date, or costs incurred after construction ofa new generating plant is completed and the plantis placed into service. All costs will be subject to a review ofreasonableness in a general rate application.


### VI. SECONDAMENDMENT TO THE 2013-2032 IRP A. Background 193. In Docket No. 14-06022, Nevada Power seeks approval ofthe Second Amendment to its 2013-2032 IRP, which includes the request for approval ofthe Harry Allen Transformer. However, the information in support ofthis Application is included in Docket No. 14-05003. Nevada Poweris not seeking to include the Harry Allen Transformer in the regulatory asset to be established for projects included inthe ERCR Plan. Additionally, Nevada Powerrequests deviation from NAC 704.9516 (the regulation governing contents ofaction plan amendments) and seeks to consolidate these Dockets to synchronize the timing ofthe ERCR Plan (180 days) and an amendment to an IRP (135 days). IllDocket Nos. 14-05003 & 14-06022 Page 82 

### B. Harry Allen Transformer Nevada Power 194. Nevada Power seeks approval ofthe installation ofa 500kV/230kV autotransformer at the Harry Allen substation. Nevada Power contends that this project will provide it with needed additional capacity to transfer energy from its 500 kV transmission system onto the 230 kV transmission system and into or through the Las Vegas Valley load pocket. (Ex. 52 at 3.) 195. Nevada Power explains that the planning studies that were prepared for Docket Nos. 11-08011 and 12-06053 demonstrated that under the then-current load forecast and topology, there was limited ability to bringbulkenergy onto the 230kV system and into and through the Las Vegas Valley. While the studies indicated that the addition ofthe Harry Allen Transformer was the preferred solution, Nevada Power did not seek Commission approval and, instead, sought approval to implement a series ofoperating procedures that would delay the need for the project. (ld. at 4.) The procedures included the use ofthe Crystal phase shift transformer ("Crystal PST"), a Lenzie generation tripping remedial action scheme ("Lenzie Generation RAS"), and there-dispatch ofgeneration. (ld.) 196. Nevada Power contends that it can no longerrely on these operatingprocedures due to the requirements ofSB 123 to retire a total of557 MW ofgeneration on the 230 kV system that includes retirement ofthe Reid Gardner units 1-3 by the end of2014 and retirement ofthe Reid Gardner unit4 bythe end of2017. Theretirement ofthese facilities necessitates that Nevada Powerreplace that capacity and address the impacts and potential constraints on the transmission system facilities. (/d. at 5.)Docket Nos. 14-05003 & 14-06022 Page 83 197. Nevada Power acknowledges that it can serve load after the retirement ofthe Reid Gardner facilities without the Harry Allen Transformer, but notes that it will require the redispatching ofthe system out ofthe economic dispatch order. Nevada Power contends that as a result ofthe retirement ofthe Reid Gardner facilities, it is more economical to install the Harry Allen Transformerthan to operate in this mode. (/d. at 6.) 198. Nevada Power states that the project cost ofthe Harry Allen Transformer is $40.2 million and that the savings associated with optimizing system dispatch, reducing losses, and avoiding capacity costs yield a net PWRR savings of$14.2 million. (/d. at 7-8.) 199. Nevada Power states that two Transmission Service Agreements ("TSAs") pending before FERC have identified the Harry Allen Transformer as a required network upgrade to provide the requested service. These transmission customers could purchase up to 327 MW ofpoint-to-point transmission service valued at $14 million per year under the current tariff. These revenues were not included in the benefit calculation. (/d.at 8.) 200. Nevada Powerrequests deviation from NAC 704.9516, which prescribes the information that shouldbe included in a typical IRP amendment. Nevada Power explains that the information thatjustifies approval ofthis Application was provided in Docket No. 14-05003. The reason Nevada Powerfiled this Application separately is because itis not seeking the special regulatory asset treatment associated with the ERCR Plan and to reconcile the timelines for Commission approval. The Commission has 180 days to issue an order on an IRP amendment associated with an ERCRplanbut only 135 days to issue an order addressing a non-ERCR Plan IRP amendment. (Ex. 31 at 2-3.) 201. Nevada Power states that NAC 704.0097 allows for the deviation ofany provision ofNAC 704 if: 1) good cause for the deviation appears; 2) the personrequesting the deviationDocketNos. 14-05003 & 14-06022 Page 84 provides a specific reference to eachprovision ofthe chapterfrom which deviation is requested; and 3) the Commission finds that the deviation is in the public interest and not contrary to statute. Nevada Powercontends that the approach taken in Docket No. 14-06022 represents the most administratively efficient and resource-conserving means ofaccomplishing the goal of allowing 180 days for consideration ofthe Application. (ld. at 2-3.) 

### BCP 202. BCP states that it does not oppose Nevada Power's request for approval ofthe Harry Allen Transformer to be placed in-service in 2016. (Ex. 66 at 21.) Ormat203. Ormatrecommends that the Commission approve the Harry Allen Transformer. Ormat contends that the new transformer is cost-effective because the analysis shows that the PWRR savings is expectedto be $14.2 million. (Ex. 61 at 7-8.) 204. Ormat states that the Harry Allen transformer will increase deliveries on the 500 kV system into the Harry Allen substation. Further, the new transformer would allow greater powerflows from the northern part ofthe NV Energy system. This would enable renewable
resources in northern Nevadato deliver powerto NevadaPower, resulting in a diversity of renewable supply options as well as enabling the export ofpowerto neighboring states and resulting injob creation, economic activity, and otherbenefits for Nevada. (/d. at 8.) Staff 205. Staffrecommends that the Commission reject Nevada Power's request for approval ofthe Harry Allen Transformer and that the projectbe deferred until at least 2018. (Ex. 79 at 11; 61.)Docket Nos. 14-05003 & 14-06022 Page 85 206. Staffcontends that Nevada Power's cost-benefit analysis overstates the benefits associated with the project and that when the errors are corrected, the actual savings during the first two to three years following the installation are lower than the revenue requirement associated with the project. Accordingly, Staffasserts that the Harry Allen Transformer is not economicallyjustified and should be delayed until at leastJune 1, 2018, when itbecomes economicallyjustified and/or necessary for reliability purposes due to the retirement ofthe Reid Gardner unit 4. (!d. at 54.) 207. Staffstates that while Nevada Power's cost-benefit analysis is reasonable in its rationale, it includes several simple assumptions that overstate the benefits ofinstalling the project in 2016. The first assumption is the heat rate associated with the generation located on the 500kV system that NevadaPower assumes will be curtailed during peak loading hours. Nevada Power assumes that all generation curtailed on the 500 kV system will be from the Lenzie units, which have the lowest heat rates on the 500 kV system. Staffcontends that NPC's model should have curtailed the duct firing capacity connected to the 500 kV transmission systembefore the Lenzie generation because the duct firing capacityhas a higherheat rate, is
more expensive to operate, and, therefore, would be curtailedbefore the Lenzie generation. Consequently, Nevada Power's analysis overstates the energy savings ofthe first block of capacitythat would be uneconomically re-dispatched during peakload hours. Staffasserts that this change causes Nevada Power's annual re-dispatch savings to drop by almost $1.9 million per year from what is presented in the filing. (!d. at 55.) 208. Staffstates that there are other problems with the cost-benefit analysis that overstate the benefits. These problems include the assumed heat rate for the Clark combined cycle units, the losses associated with using the Crystal PST, the assumption regarding theDocket Nos. 14-05003 & 14-06022 Page 86
renewal ofthe LV Co-GenCogen contract, and the assumption regarding capacity on the ON Line. (/d. at 55-58.) 209. Staffstates that while there probably are reliability benefits associated with the Harry Allen Transformer, Nevada Poweris notjustifying the projectbased on such benefits. (/d. at 58.) 210. Staffacknowledges that ifthe 300 MW Cargill TSA request is granted and Cargill has a resource instantaneously capable ofutilizing the 300 MW ofcapacity, then this TSA would likely drive the need for the Harry Allen Transformer. However, until the TSA issue is resolved and approved byFERC, it is premature to rely on the TSA and its revenue stream tojustifythe 2016 in-service date for the Harry Allen Transformer. (/d. at 59-60.) Nevada Power Rebuttal 211. Nevada Powerupdates the cost-benefit analysis ofthe Harry Allen Transformer
as a result ofStaff's concerns and asserts that the revised analysis continues to support the 2016 installation. Nevada Power notes that Staff's testimony has led to a more definitive explanation ofincluded benefits and the removal ofless certain or less quantifiable benefits. (Ex. 86 at 2.) 212. Nevada Powerrevises its original cost estimate of$40.2 million to $33.6 million for the Harry Allen Transformer. Nevada Power asserts that this refinement reflects the benefits ofbeing part ofthe Berkshire Hathaway Energy Company. (/d. at 3.) Nevada Power explains that Staff's use of$5.6 million (or any) first year revenue requirement overstates the actual benefit ofdelaying the in-service date for the Harry Allen transformer to June 2018. Ifthe inservice date is delayed from 2016 to 2018, the revenue requirement in 2016 and 2017 will be lower. However, Nevada Power asserts that the benefit ofthe deferral is partially offset over the life ofthe project. Beginning in 2018, the annual revenue requirement will be higher than itDocketNos. 14-05003 & 14-06022 Page 87 would have been without the deferral for two reasons. First, the transformer with a 2018 inservice date has a higherinitial cost due to escalation. Second, the transformer with a 2018 inservice date will not have the benefit ofdepreciation for 2016 and 2017. (!d. at 3-4.) 213. Nevada Power asserts that on a present worth basis, a significant portion ofthe savings associated with the two-year delay in the in-service date is offsetby higher costs in each subsequent year overthe life ofthe transformer. The 2016 and 2017 net present value revenue requirement savings are less than the benefits ofinstalling the HarryAllen Transformerin 2016. As such, customers save more money (approximately $2.4 million per year) from the installation ofthe Harry Allen Transformerin 2016 than they would save from a deferral to 2018. (!d. at 4- 5.) 214. Nevada Power agrees with Staff's correction to the assumption regarding the curtailment ofduct firing capacity in place ofthe Lenzie capacity. With this correction, the analysis shows that when the higher heat rate from the duct firing capacityisincluded, theredispatch costs are reduced from $5.81 million to $3.951 million in 2016, from $5.2 million to $3.246 million in 2017, and from $4.895 million to $3.163 million in 2018. (ld. at 7.) 215. Nevada Power addresses the problems raised by Staffwith respect to the assumed heat rate for the Clarkcombined cycle units, the losses associated with using the Crystal PST, the assumption regarding the renewal ofthe LV Cogen contract, and the assumption regarding capacity on the ON Line. (!d. at 5-10.) Even though it disagrees with Staff's position regarding the cost savings associated with these assumptions, Nevada Power does not include these cost savings in its final cost-benefit analysis. 216. NevadaPowerreasserts that the Harry Allen Transformeris economically justifiedwithout consideration ofthe reliabilitybenefits associated with it. However, NevadaDocket Nos. 14-05003 & 14-06022 Page 88
Power clarifies that under certain circumstances, the system would need to be operated in a suboptimal manner even though there would be no violation ofNERC transmission planning standards. (ld. at 11-13.) 217. Nevada Power states that the economic analysis ofthe Harry Allen Transformer is not based on the receipt ofTSA revenues from Cargill. However, Nevada Power notes that under the terms ofthe NV Energy Open Access Transmission Tariff("OATT"), Cargill can redirect its point ofreceipt ifit executes a TSA andbegins paying for transmission service prior to constructing the resource. (!d. at 13.) Commission Discussion and Findings 218. The Commission approves Nevada Power's request to install the Harry Allen Transformer in 2016. By comparing the cost savings associated with a two-year delay as proposed by Staffwith the updated estimated cost of$33.6 million and the reductions associated with adjusted curtailment savings, the analysis indicates that there is a greaterbenefit to retail customers with the installation ofthe Harry Allen Transformerin 2016. The PWRR savings with delaying the installation to 2018 results is $2.4 million per year for 2016 and 2017 whereas the adjusted curtailment savings associated with an in-service date of2016 results in $3.95 million for 2016 and $3.246 for 2017. The Commission is compelledbythe reduced cost estimate providedbyNevada Power in its rebuttal testimony. 219. The Commission finds that it is in the public interest and not contrary to statute to grant Nevada Power'srequest to deviate from NAC 704.9516. Nevada Power demonstrated that there is good cause for this deviation because itresults in administrative efficiencies by avoiding the duplication ofinformation filed in each Docket. IllDocket Nos. 14-05003 & 14-06022 Page 89 

### THEREFORE, it is ORDERED that: 1. The Stipulation, attached hereto as Attachment 1, is ACCEPTED. 2. The Application ofNevada Power Company d/b/a NV Energy for approval ofthe first amendment to the 2013-2032 Integrated Resource Plan and the Energy Supply Plan Update for 2015 to include an initial emissions reduction and capacityreplacement plan, designated as Docket No. 14-05003, is GRANTED as modified by this Order. 3. Nevada Power Company d/b/a NV Energy's Energy Supply Plan Update is APPROVED, as modified by the Stipulation. 4. Nevada Power Company d/b/a NV Energy's initial emissions reduction and capacity replacement plan is ACCEPTED IN PART and DEEMED INADEQUATE IN PART as provided in this Order. 5. The Application ofNevada Power Company d/b/a NV Energy for approval ofthe second amendment to the 2013-2032 Integrated Resource Plan and Action Plan as it relates to a
new 500-kilovolt/230-kilovolt autotransformer at the existing Harry Allen substation, designated
as Docket No. 14-06022, is GRANTED. 6. All arguments ofthe parties raised in these proceedings not expressly addressed herein have been considered and either rejected or found to be non-essential for further discussion in this Order. 7. The Commission's acceptance ofthe Stipulation does not constitute precedent regarding any legal orfactual issue. Compliance: 

### 8. Within 30 days ofthe issuance ofthis Order, Nevada Power Company d/b/a NV Energy shall file in this Docket notice ofits acceptance ofthe Commission's modifications to theDocket Nos. 14-05003 & 14-06022 Page 90 emissions reduction and capacity replacement plan or notice ofits withdrawal ofthe emissions reduction and capacity replacement plan. Directives: 9. Nevada Power Company d/b/a NV Energy shall maintain adequate accounting information to inform the Commission and the parties in this Docket ofthe accounting treatment for the payroll costs attributable to the Nevada Power employees set to be redeployed following the retirement ofReid Gardner units 1-3. 10. Nevada Power Company d/b/a NV Energy shall continue to hold quarterly workshops with the Regulatory Operations Staffand the Attorney General's Bureau ofConsumer Protection to review the implementation ofthe constituent elements ofthe ESPUpdate and the approved hedging strategy. 11. Nevada Power Company d/b/a NV Energy shall maintain adequate accounting information to support the treatment ofnon-labor savings associated with the retirement ofthe Reid Gardner units 1-3. 12. ByJanuary 1, 2015, Nevada Power Company d/b/aNV Energy shall file with the Commission arequest for proposal process pursuant to NevadaAdministrative Code 704.9453(8) or, alternatively, an amendment to its emissions reduction and capacity replacement plan, therein seeking approval ofa specific project that will satisfy a corresponding request for deviation under Nevada Administrative Code 704.0097. Ill Ill Ill IllDocketNos. 14-05003 & 14-06022 Page 91 13. 

### The Commission may

### correct any errors thathaveoccurred in thedrafting or issuance ofthis Orderwithout furtherproceedings.



# Attest:~' BREANNE POTTER, Assistant Commission Secretary Dated: Carson City, Nevada



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# " (SEAL) Bythe Commission,



### ALAINABURTENSHAW, Chairman

REBECCA D. WAGNER, 

### Commissioner (Concurring in part 

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- 9/12/20141

BEFORETHEPUBLICUTU..ITIES COMMISSION OFNEVADA Application ofNevada Power Company d/b/aNV Energy Seeking Acceptance of the First Amendment to its 2013-2032 integrated resource plan and its Energy Supply Plan Update for 2015, which include an emissions reduction and capacity replacement plan filed pursuant to NRS § 704.7311 et s . DocketNo. 14-05003

STIPULATION Pursuant to Nevada Administrative Code ("NAC") § 703.750 and NAC § 703.845, Nevada Power Company (''Nevada Power" or "Company''), the Regulatory Operations Staff ("Staff') of the Public Utilities Commission of Nevada ("Commission'), the Office of the Attorney General's Bureau of Consumer Protection ("BCP"), Interwest Energy Alliance ("Interwest"), Federal Executive Agencies ("FEA"), Abengoa Solar, LLC (''Abengoaj, Bombard Renewable Energy, a division ofBombard Electric, LLC ("Bombard"), Sierra Club ("Sierra"), Enel Green PowerNorth America, Inc. (''EGPNA"), Nevadans for Clean Affordable Reliable Energy {''NCARE''), Griffith Energy ("Griffith''), Switch, Ltd. {"Switch"), and Boyd Gaming Corporation, 

### Las Vegas Sands Corp., MGM Resorts, International, station Casinos, Caesars Entertainment Corporation, and Wynn Las Vegas, LLC (collectively, the "Southern Nevada Hotel Group" or "SNHG") each individually a "Signatory'' and together the "Signatories", enter this Stipulation to resolve all issues related to the energy supplyplanupdate portionofthe above-referenceddocket SUMMARYOF STIPULATION The Parties agree that this Stipulation provides a reasonable resolution ofcertain

**~ssues** raised in the Energy Supply Plan Update ("ESP") portion ofthis docket and thatthe Stipulation isinthepublic interest. The Stipulationonlysettlesissuesrelated to this docket. The Stipulationonlyseeksrelief that the Commission is empowered to grant. Accordingly, the Signatories recommend that the

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### 'i Gil 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Commission acceptthe Stipulation, and grant certainrequests for reliefmade byNevadaPower,
as modifiedbythe Stipulation. RECITALS 1. Pursuantto NAC §704.9061, an energy supplyplanestablishes the parameters 

### of
an energy supplyportfolio for an electric utility for the 3-yearperiod covered by its action plan and balances the objectives ofminimizing the cost ofsupply, minimizing retail price volatility, and maximizing the reliability ofenergy supply over the term ofthe energy supply plan. An energy supply planis composed ofapurchasedpowerprocurementplan, fuel procurement plan, and riskmanagement strategy. 2. NAC §704.9506 provides that on orbefore September 1 ofthe first and second years afterthe actionplan ofautilityis filed, the utility shall file an update ofthe energy supply planthatwillbe applicable for eachyearremaining inthe periodcoveredbythe actionplan. 3. On May 1, 2014, Nevada Power filed with the Commission an application requesting approval and acceptance of its energy supply plan update for 2014 (the "ESP Update"). 4. Nevada Power's ESP Update was made pursuant to the applicable provisions of the NRS and the NAC, Chapters 703 and 704, including but not limited to NAC §§ 704.9506, 704.9508, 704.9482 and 704.9494. 5. Pursuant to NRS §§ 703.301 and 228.360, Staffand the BCP participate inthese 20 proceedings as amatterofright. 21 6. The Nevada Power ESP Update contains the constituent elements of Nevada 22 Power'spurchasedpower and fuel procurementplans, and its riskmanagement strategies. 23 

### 7. Staff and BCP, Interwest, PEA, Abengoa, Bombard, Sierra, EGPNA, NCARE, 24 Griffith, Switch, SNHG have investigated the ESP Update and conducted analysis of the 25 Companies' requests. 26 27 28 2**~** 

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### zoo '8 Ill 1 8. This stipulation resolves all issues related to the energy supply plan update 2 portionofthe above-referenced docket. 3 NOW THEREFORE, in light ofthe foregoing considemtions, the Signatories agree and 4 recommend the following: 5 AGREEMENT OFTHESIGNATORIES 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 

### 22 23 24 25 26 27 28 1. Load Forecast. A. The Commission should find that the short-term load forecast contained in the ESP Updatemeets therequirements of (a) NAC § 704.9321,becausethe load forecast isbasedonsubstantially accuratedataand is adequately documented,justified, demonstrated anddefended, (b) NAC § 704.9482, because the ESP Update uses the base load forecast and target planningreserve margins, and (c) NAC §§ 704.9482(7) and 704.922, becausethetechnical appendices provide sufficient detail to determine how the load forecasts were prepared and to evaluate the validity ofthe assumptions andthe accuracyofthedataused. B. The Commission should find the load forecast is suitable for making planning decisions duringthe ESP Updateperiod. 2. PowerProcurementPlan, A. The Commission should accept and approve, pursuant to NAC §704.9494(1), the Company'sPowerProcurementPlans, andthe constituent elements ofthose plans,which include theportfolio optimizationplans. 

### B. The Company acknowledges thatthe Commission approval and acceptance ofthe portfolio optimization plan does not mean that the Commission has approved the Company's "Portfolio OptimizationManual."

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## • 1 3. CoalProcurementPlans. 2 The Commission should approve and accept the Company's Coal Procurement Plan 3 pursuanttoNAC §704.9494(1). 4 **""'4.,_____,P~h~vs~i::.:cal:....:::G~as~Pro~CUI'=em~en~t:..::P~lans~.** 5 The Commission should approve and accept the Company's Physical Gas Procurement 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plan pursuant to NAC § 704.9494(1), which includes Nevada Power's plan to continue to implement the

**four~season** laddering strategy approved by the Commission in Docket No.

**10~** 09003 to procurephysicalnaturalgas. 5. Gas TransportationPlans. A. NevadaPowerwill not issue arequestfor proposals ("RFP'') and award economic bids for up to40,000 millioncubic feet per day ofnatural gas transportation capacity duringthe ESP Updateperiod. B. Pursuant to NAC § 704.9494(1), the Commission should approve and accept NevadaPower's Gas TransportationPlan as modifiedbyparagraph5A. 6. Gas Hedging Strategy. A. The Commission should fmd that Nevada Power has satisfied the Commission's directive inDocketNo. 12-06053 and that Nevada Power should continue to conduct quarterly hedging workshops. B. The Commission should approve Nevada Power continuing the gas hedging strategy currently in place, which was previously approved in Docket Nos.

**10~09003,** until an updatedhedging strategyis approvedbythe Commission. C. Pursuant to NAC § 704.9494(1), the Commission should approve and accept NevadaPower'sGas Hedging Strategy

### as modifiedbyparagraph 6B. 7. RiskManagement Strategies. The Commission should accept and approveNevadaPower's riskmanagement strategies pursuant to NAC 704.9494, and find that the strategy identifies risks inherent inprocuring and

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### 1 16 Cll 17 18 19 20 21 22 23 24 25 26 27 28 obtaining a supply portfolio and establishes the means by which the Company plans to address andbalanceorhedge the identifiedrisksrelatedto cost, pricevolatilityandreliability. 8. FindingofPrudencepursuantto NAC §704.9494(3). A The Commission should find that the ESP Update presented by the Company as modifiedbythe Stipulationbalancesthe objectives ofminimizingthe cost ofsupply, minimizing retail price volatility and maximize thereliability ofsupply overthe term ofthe plan, as required byNAC 704.9494(3)(c). B. The Commission should find that the ESP Update presented by the Company as modified bythe Stipulation optimizes the value ofthe overall supply portfolio ofthe utility for thebenefitofitsbundledretail customers, as required byNAC 704.9494(3)(b). C. The Commission should find that the ESP Update presentedbyNevadaPower as modified by the Stipulation does not contain any feature or mechanism that would impair the restoration of the creditworthiness of the utility or would lead to a deterioration of the creditworthiness ofthe Companies, as requiredbyNAC704.9494(3)(a). D. The Commission should find, pursuant to NAC §704.9494(3) thatthe constituent elements of the ESP Update presented by the Company as modified by the Stipulation are prudent. 9. Confidentiality. The Commission should grant the Company's request for confidential treatment of certainportionsofthe ESP Updatepursuantto NAC §704.7272. 10. Miscellaneous Items. The Comll)ission should accept Nevada Power's plan to continue quarterly workshops with Staffand BCP to review the implementationofthe constituent elements ofthe ESP Update and the approved hedging strategy as a directive. The Signatories agree that such meetings shouldinclude adiscussionof(a) thereliability and costconsiderationsrelatedto itsphysical gas

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# = 16 17 18 19 20 21 22 23 24 25 26 27 28 procurement process relative to a month-ahead approach and (b) the reliability and cost considerationsrelatedto theprocurementoffixed pricephysical gas. 11. General Provisions. A. This Stipulation shall not serve as precedent for the resolution ofany issue in the future by the Commission, with the exception of the adjustments enumerate herein and the findings thatfollow. B. This Stipulation is entered into for the purpose ofresolving all the issues in the Docket by and among the signatories as set forth above. This Stipulation is made upon the express understanding that it constitutes a negotiated settlement. The provisions of this Stipulation arenot severable
. C. This Stipulation represents a compromise ofthe positions ofthe Signatories. As such, conduct, statements anddocuments disclosed in the negotiation ofthis stipulation shall not be admissible as evidence inthese Dockets or any otherproceeding. Except as set forth herein, neitherthis Stipulation, nor its terms, nor the Commission's acceptance orrejection ofthe terms contained inthis Stipulationshallhave anyprecedential effect in futureproceedings. D. This Stipulation may be executed in one or more counterparts, all of which together shall constitute the original executed document. This Stipulation may be executedby Signatories by electronic transmission, which signatures shall be as binding and effective as original signatures.
This Stipulation is enteredinto byeachSignatory as ofthedate enteredbelow: REGULATORY OPERATIONS STAFF

61 OFFICEOFATIORNEYGENERAL, BUREAUOFCONSUMERPROTECTION 2

6 

## Dated:_~-·~e.____f-__ , 

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7 NEVADA POWERCOMPANYD/B/ANVENERGY



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# BT.~---- 1 0 T1tle: AssistantGeneral Counsel
Thefollowing parties do notobjecttothis Stipulation.
. 13 INTERWESTENERGYALLIANCE ("INTER WEST")

15 **By:~-.......,..,,_.,:::-----::::-;-;-::----­** Name: LisaTonnoenHickey 16 Title: Counsel 17 18 FEDERALEXECUTIVEAGENCIES 19 

### Dated:_______ **~~-**

20 By: Dated:_________ _ Name: Thomas A Jernigan, Capt. USAF 21 Title: Counsel · · 

### 22 23 ABENGOA SOLAR, LLC ("ABENGOA") 24 25 By:

**~N-=-am-e-.: Ka~thl...--ce-n""""""M.-::-::D:::-r-.ak:uli,......,....,....ch,..-----**  26 Title: Counsel 27 28 7 Dated:_________ _

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By: .,N:.-am-e-.: Martb....---:.-a-;oJ-. As·.-.--h-cra-ft..--- Title: Counsel
SIERRACLUB ("SIERRA") By:

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ENELGREEN POWERNORTH AMERICA, INC. (''EGPNA") By:

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### NEVADANS FORCLEAN AFFORDABLE RELIABLE ENERGY ("NCARE")

22 GRIFFITH ENERGY ("GRIFFITH") 23 24 By:

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SIERRACLUB ("SIERRA") By: Name: GloriaD. Sm.Hh Dated: Title: Counsel
ENELGREENPOWERNORTHAMERICA, INC. ("EGPNA") By: Dated: Name: Michael C. Tierney Title: Counsel
NEVADANS FORCLEANAFFORDABLERELIABLEENERGY (UNCARE") By: Dated: Name: Robert G. JobDStOn Title: Counsel
GRIFFITHENERGY ("ORIFFITir')



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ORMATNEVADA INC.



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__1 CERTIFICATE OF SERVICE 2 I hereby certify that I have served the foregoing NEVADA POWER COMPANY 3 D/B/A NV ENERGY'S STIPULATION filed in Docket No. 14-05003 upon the persons 4 listed belowbyelectronic mail. 5 Tammy Cordova StaffCounsel Division 6 PublicUtilities Comm. ofNevada PublicUtilities Comm. ofNevada 7 tcordova@puc.nv.gov pucn.sc@puc.nv.gov 8 Paul Stuhff Attorney General's Office Attorney General's Office Bureau ofConsumerProtection 9 Bureau ofConsumerProtection bcpserv@ag.nv.gov bcpserv@ag.nv.gov



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# z.i 00 15 

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## = Ill 16 17 18 19 20 21 22 23 24 25 26 27 28 Fred Schmidt Holland & HartLLP fschmidt@hollandhart.com Gloria Smith Sierra Club Environmental Law gloria.smith@sierraclub.org Calvin Siemer Las Vegas Sands Corp. calvin.siemer@sands.com EricDominguez Caesars Entertainment Corp. edominguez@caesars.com Katarina Tesarova Venetian Casino Resort LLC katarina.tesarova@venetian.com PaulaEylar-Lauzon Boyd Gaming Corporation paulaeylar@boydgaming.com Timothy Shuba Goodwin ProcterLLP tshuba@goodwinprocter.com Tim Lindl Keys, Fox & Wiedman LLP tlindl@kfwlaw.com

DATEDthis 12th day ofSeptember, 2014. Derek Nelson Sierra Club derek.nelson@sierraclub.org TravisRitchie Sierra Club Environmental Law travis.ritchie@sierraclub.org Dave Gildersleeve Station Casinos Inc. dave.gildersleeve@stationcasinos.com Henry Shields MGMResorts 

### Inti. hshields@mgmresorts.com Matt Reinhold Station Casinos LLC matt.heinhold@stationcasinos.com StacieMichaels Wynn Las Vegas LLC stacie.michaels@wynnlasvegas.com Jake Schlesinger Keys, Fox & Wiedman LLP jschlesinger@kfwlaw.com

Is/JaniceBaldarelli Janice Baldarelli Legal Assistant SierraPacificPowerCompany NevadaPower Company

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