20240321PAC to Staff 38-39.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
March 21, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
[e-mail]
[e-mail]
RE: ID PAC -E-23-24
IPUC Set 3 (38-39)
Please find enclosed Rocky Mountain Power’s Responses to IPUC 3rd Set Data Requests 38-39.
If you have any questions, please feel free to call me at [phone].
Sincerely,
____/s/____
Mark Alder
Manager, Regulation
Enclosures
RECEIVED
Thursday, March 21, 2024 2:33:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-24 / Rocky Mountain Power
March 21, 2024
IPUC Data Request 38

IPUC Data Request 38

Please confirm that the marginal regulation reserve cost calculated by the
PLEXOS model only reflects variable production costs (such as fuel costs and
variable O&M costs) and does not reflect fixed costs (such as capital costs and
fixed O&M costs).

Response to IPUC Data Request 38

Confirmed. Fixed costs are not included in the marginal regulation reserve cost
used to calculate the proposed integration costs.

Recordholder: Dan MacNeil

Sponsor: Dan MacNeil
RECEIVED
Thursday, March 21, 2024 2:33:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-24 / Rocky Mountain Power
March 21, 2024
IPUC Data Request 39

IPUC Data Request 39

Please confirm that the proposed integration charges do not capture capital costs
and fixed O&M costs of regulation reserves. If confirmed, please explain why the
proposed integration charges should not capture capital costs and fixed O&M
costs of regulation reserves.

Response to IPUC Data Request 39

Confirmed. The proposed integration charges do not include any capital costs or
fixed operations and maintenance (O&M) costs. While the Company models a
regulation reserve requirement for each hour and schedules flexible capacity in
advance of each hour, during actual operations within an hour, regulation reserve
capability does not need to be held available and can be fully deployed to balance
load and resources for any reason. As a result, the Company does not anticipate
that regulation reserve costs will require resources in excess of those necessary to
meet capacity requirements for serving peak loads. To the extent wind and solar
resources may underperform during critical periods (such that regulation reserves
might be deployed), it would be expected to be reflected in their capacity
contribution, rather than as part of the integration cost.

Recordholder: Dan MacNeil

Sponsor: Dan MacNeil
RECEIVED
Thursday, March 21, 2024 2:33:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION