20240906PAC to Bayer 51 1st Revised.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116

September 6, 2024

Thomas J. Budge
[e-mail] (C)

Brian C. Collins [e-mail]
Greg Meyer [e-mail]
Kevin Higgins [e-mail] (C)
Neal Townsend [e-mail] (C)

RE: ID PAC -E-24-04
Bayer Set 3 (49-56)

Please find enclosed Rocky Mountain Power’s 1st Revised Redacted Response to Bayer 3rd Set
Data Request 51. Provided via BOX is Confidential Response Bayer 51 1st Revised.
Confidential information is provided subject to protection under IDAPA 31.01.01.067 and
31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information
Exempt from Public Review, and further subject to the non-disclosure agreement (NDA)
executed in this proceeding.

If you have any questions, please feel free to call me at [phone].

Sincerely,

____/s/____
Mark Alder
Manager, Regulation

Enclosures
C.c.: Eric L. Olsen/IIPA [e-mail] (C)
Lance Kaufman/IIPA [e-mail] (C)
Matthew Nykiel/ICL [e-mail]
Brad Heusinkveld/ICL [e-mail]
Ronald L. Williams/PIIC [e-mail]
Brandon Helgeson/PIIC [e-mail]
Bradley Mullins/PIIC [e-mail]
Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]
Monica Barrios-Sanchez/IPUC [e-mail]
[e-mail]
RECEIVED
Friday, September 06, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-24-04 / Rocky Mountain Power
September 6, 2024
Bayer Data Request 51 – 1st Revised

Bayer Data Request 51

Fuel Stock - Exhibit No. 48 Page 8.6.1: What were the causes of the major increases
and decreases to the fuel stock balance, by generator unit, from December 2023 to the
Test Year request for each of the specific plants outlined in Exhibit No. 48 Page 8.6.1.
Specifically:

(a) Jim Bridger
(b) Cholla
(c) Colstrip
(d) Craig
(e) Hayden
(f) Hunter
(g) Huntington
(h) Dave Johnston
(i) Naughton
(j) Rock Garden

1st Revised Confidential Response to Bayer Data Request 51

Further to the Company’s response to Bayer Data Request 51 dated August 21, 2024, the
Company has become aware that the provided response did not contain the confidential
disclosure to protect the confidential information provided in that response. The
Company therefore provides this 1st Revised response which replaces, in its entirety, the
Company’s original response:

PacifiCorp maintains coal fuel stock inventory target ranges that support the short-term
and long-term fueling needs of each plant and the total system. These targets are
reviewed and evaluated periodically by the Company in order to determine if the ranges
are adequate to provide an economic and reliable supply of fuel to the generating stations.
These evaluations consider such factors as transportation, coal quality, market conditions,
potential disruptions, laws and regulations, and uncertainties in weather.

(a) The fuel stock level at Jim Bridger plant at the end of 2023 was well below historical
levels due to coal supply disruptions resulting from a force majeure event. The coal
fuel stock for Jim Bridger plant is forecast to increase throughout 2024 as the plant
builds inventory

The Jim Bridger plant has been historically supplied by
three local mines, the Bridger Coal Company (BCC) underground mine and surface
mine, as well as the Black Butte mine. The underground mine at BCC ceased
operations in 2021, and

With fewer coal supply options, the Jim Bridger plant has a higher risk of coal supply
disruption. The other available coal source is the Powder River Basin (PRB) which is
PAC-E-24-04 / Rocky Mountain Power
September 6, 2024
Bayer Data Request 51 – 1st Revised

located approximately 550 miles away from the plant. The volume of PRB coal that
the plant can manage by rail is limited. Note that as recently as 2023, Jim Bridger
plant generation was constrained due to unreliable coal supply. The conversion of Jim
Bridger Units 1 and 2 from coal to natural gas operations in 2024, does not change
the plant’s coal supply or delivery risk profile for Jim Bridger Units 3 and 4 in 2024.

(b) PacifiCorp ceased operating Cholla Unit 4 as of December 2020.

(c) The fuel stock for Colstrip plant had no major changes from 2023 to the test year.

(d) The fuel stock level at Craig ended below target in 2023. Therefore, forecasted
amounts reflect the planned stockpiling of coal to optimize coal deliveries from the
Trapper mine and ensure supply reliability based upon thermal generating station
requiremen ts.

(e) The fuel stock level at Hayden ended below target in 2023 due to an unexpected
outage in the fourth quarter of 2023 at the Twentymile mine which supplies the plant.
Therefore, forecasted amounts reflect the planned stockpiling of coal to optimize coal
deliveries and increase the coal inventory to near targeted range.

(f) The decrease to the Hunter balance is primarily due to changes to the 2024 beginning
balance after 2024 source data was prepared.

(g) The fuel stock level at Huntington ended below target in 2023. Therefore, forecasted
amounts reflect the planned stockpiling of coal to optimize coal deliveries and ensure
supply reliability based upon thermal generating station requirements.

(h) The decrease to fuel stock for Dave Johnston plant reflects the planned reduction in
deliveries during 2024 to lower the coal inventory to within the target range.

(i) The decrease in Naughton plant is due to the planned closure of the Naughton plant
December 31, 2025, the fuel stock forecast reflects a zero balance in December 2025
to reflect the closure.

(j) There is no forecasted change in fuel stock balances for the Rock Garden from
December 2023 to the test year.

Confidential information is provided subject to protection under IDAPA 31.01.01.067
and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 –
Information Exempt from Public Review, and further subject to the Non-Disclosure
Agreement (NDA) executed in this proceeding.

Recordholder: Heather Garcia

Sponsor: Brian Greer
1
Joe Dallas (ISB# 10330)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: [e-mail]

Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF ROCKY
MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS
RATES AND CHARGES IN IDAHO
AND APPROVAL OF PROPOSED
ELECTRIC SERVICE SCHEDULES
AND REGULATIONS

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CASE NO. PAC-E-24-04

ATTORNEY’S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES

I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response, is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the first revised response to Bayer Set Data Request No. contains Company proprietary
information that could be used to its commercial disadvantage.
2
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential information that the information contains Company proprietary information.
I am of the opinion that this information is “Confidential,” as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.

DATED this 6th day of September, 2024.

Respectfully submitted,

By__________________________
Joe Dallas
Attorney
Rocky Mountain Power