20240918PAC to Staff 223_225-228.pdf

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

September 18, 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-24-04
IPUC Set 12 (217-240)

Please find enclosed Rocky Mountain Power’s Responses to IPUC 12th Set Data Requests 223
and 225-228.

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]
Thomas J. Budge/Bayer [e-mail] (C)
Brian C. Collins/Bayer [e-mail]
Greg Meyer/Bayer [e-mail]
Kevin Higgins/Bayer [e-mail] (C)
Neal Townsend/Bayer [e-mail] (C)
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]
RECEIVED
Wednesday, September 18, 2024
IDAHO PUBLIC
UTILITIES COMMISSION

PAC-E-24-04 / Rocky Mountain Power
September 18, 2024
IPUC Data Request 223

IPUC Data Request 223

Regarding the Company’s REC Option Program, please answer the following:

(a) Please explain if there are any controls that prevent program participants from
being able to retire more RECs than they currently receive in the form of REC
revenue.

(b) Please explain if there are any controls that prevent non-participants from
receiving less REC revenue than they currently receive.

Response to IPUC Data Request 223

(a) As described in the direct testimony of Company witness, Craig M. Eller for
the proposed renewable energy credit (REC) Option Program, the Company
plans to retire RECs on behalf of REC Option Program participants. Where
the Company has entitlement to RECs, the Company allocates the RECs to the
states based on the system generation (SG) allocation factor. Once the Open
Enrollment period for the REC Option Program closes, the Company will be
able to calculate the exact number of RECs to be retired on behalf of the
participants and the needed number of RECs will be set aside for future
retirement before any RECs sales are conducted. This will keep the
participants’ share of RECs separate from the share of RECs to be marketed
on behalf of Idaho customers not participating in the REC Option. Therefore,
the retirement of RECs for REC Option Program participants would not
receive more RECs than they would in the form of REC revenue.

(b) The Company does not anticipate any adverse impact to non-participating
customers because Idaho’s remaining share of RECs that are not used for the
proposed REC Option Program will continue to be marketed and sold on
behalf of non-participating customers. The Company has designed the REC
Option Program to minimize any impact on the volume of RECs sold. For
example, the Company retains the right to determine which renewable
resource RECs will be retired on behalf of the program participants. This
allows the Company to optimize the RECs to preserve the Company’s ability
to monetize RECs for the non-participating customers.

Recordholder: Teri Ikeda / Justin Waterman

Sponsor: Craig Eller

PAC-E-24-04 / Rocky Mountain Power
September 18, 2024
IPUC Data Request 225

IPUC Data Request 225

Regarding the Company’s REC Option Program, please provide the Company’s
method of calculating the percentage of participants’ load available for REC
retirement each Program Year. Please describe how the Company plans to update
the calculation as the Company’s resource portfolio changes.

Response to IPUC Data Request 225

As described in the direct testimony of Company witness, Craig M. Eller,
customers interested in participating in the renewable energy credit (REC ) Option
Program would sign up during the Open Enrollment Period. After the Open
Enrollment Period closes, the Company will calculate the prior year's load of the
participants enrolled in the REC Option Program and multiply the aggregated
load by 20 percent. The 20 percent is based on the amount of renewables in the
Company’s resource portfolio.

Note: The Company set the initial REC Option Program percentage to 20 percent
for the first program year and will review the REC Option Program percentage if
the amount of renewables in the Company’s resource portfolio change
significantly.

Recordholder: Teri Ikeda

Sponsor: Craig Eller

PAC-E-24-04 / Rocky Mountain Power
September 18, 2024
IPUC Data Request 226

IPUC Data Request 226

Referring to proposed Electric Service Schedule No. 74, Special Condition No. 2,
please explain the Company’s criteria and processes for selecting RECs to be
retired on behalf of the Program.

Response to IPUC Data Request 226

As described in the direct testimony of Company witness, Craig M. Eller, the
Company’s renewable energy mix includes various technology types such as
wind, solar, hydro, geothermal, biogas and biomass. The Company will determine
which renewable energy credits (REC) it will retire from a balanced portfolio of
renewable resources within its system and the REC distribution within the
categories will be done in a manner that is efficient and minimizes administrative
burden on the REC Option Program. For example, instead of choosing a few
RECs from every wind facility, the Company may select RECs from one or two
wind facilities. If certain resource categories lack sufficient RECs, other resource
categories may be utilized and adjusted as needed. The total number of RECs to
be retired for the REC Option Program will remain unchanged.

Recordholder: Teri Ikeda

Sponsor: Craig Eller

PAC-E-24-04 / Rocky Mountain Power
September 18, 2024
IPUC Data Request 227

IPUC Data Request 227

Page 4 of Eller’s Direct Testimony states that the Company has been approached
by customers that are interested in making renewable energy claims and the
retirement of RECs. Please provide the results of any surveys administered by the
Company for customers seeking out REC retirement programs, if any.

Response to IPUC Data Request 227

The Company has not conducted any surveys for customers seeking out
renewable energy credit (REC) retirement programs.

Recordholder: Craig Eller

Sponsor: Craig Eller

PAC-E-24-04 / Rocky Mountain Power
September 18, 2024
IPUC Data Request 228

IPUC Data Request 228

Regarding the Company’s REC Option Program, please explain the Company’s
criteria and processes for selecting RECs that are sold on behalf of Idaho
customers.

Response to IPUC Data Request 228

For the proposed renewable energy credit (REC ) Option Program, the RECs
selected for the REC Option Program will be based on a percentage of the
participating customers’ aggregated load data in the calendar year immediately
preceding the REC Option Program year. Additionally, the volume of RECs
selected will include resources from each fuel type in the Company’s marketable
portfolio.

Recordholder: Marcie Hundis

Sponsor: Craig Eller