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Home My WebLink About20240920PAC to Staff 230 - 1st Supplemental.pdf RECEIVED Friday, September 20, 2024 IDAHO PUBLIC UTILITIES COMMISSION _ ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP 1407 W North Temple, Suite 330 Salt Lake City, Utah 84116 September 20, 2024 Monica Barrios-Sanchez Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A Boise, ID 83714 monica.barrio ssanchez(apuc.Idaho.gov S ecretarygpuc.idaho.gov RE: ID PAC-E-24-04 IPUC Set 12 (217-240) Please find enclosed Rocky Mountain Power's I"Supplemental Response to IPUC 12th Set Data Request 230. The Confidential Attachment IPUC 230 1" Supplemental is provided via BOX. 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(801) 220-2313. Sincerely, /s/ Mark Alder Manager, Regulation Enclosures C.c.: Eric L. Olsen/IIPA elo(&echohawk.com(C) Lance Kaufman/IIPA lancekae.isg insi hg t.com(C) Matthew Nykiel/ICL matthew.nykiel&gmail.com Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org Thomas J. Budge/Bayer ti(&racineolson.com(C) Brian C. Collins/Bayer bcollins(&consultbai.com Greg Meyer/Bayer gmeyerkconsultbai.com Kevin Higgins/Bayer khig gins kenergystrat.com(C) Neal Townsend/Bayer ntownsendkenergystrat.com (C) Ronald L. Williams/PIIC rwilliams(&hawleytroxell.com Brandon Helgeson/PIIC bhelgeson(&hawleytroxell.com Bradley Mullins/PIIC brmullinskmwanalytics.com Val Steiner/PIIC val.steiner(a-)itafos.com Kyle Williams/PIIC williamsknasbyui.edu PAC-E-24-04/Rocky Mountain Power September 20, 2024 IPUC Data Request 230— I`Supplemental IPUC Data Request 230 Please re-run Aurora model and provide updated work paper "ID—GRC-2025-2023 Normalized Load.xlsm" and updated McCoy's work paper "5.1 —NPC.xlsx" to reflect the result of each scenario below: Scenario Modifications 1 • Remove the CCA allowance cost from the dispatch cost of the Chehalis plant in the Aurora model;and • Remove the post-modeling CCA costsz,which were calculated based on the multiplication of Chehalis's generation amounts and the CCA allowance cost. 2 • Use the official forward price curve(OFPC)dated on June 28,2024,from Response to Production Request No. 107 in the Aurora model; • Remove the CCA allowance cost from the dispatch cost of the Chehalis plant in the Aurora model;and • Remove the post-modeling CCA costs,which were calculated based on the multiplication of Chehalis's generation amounts and the CCA allowance cost. 3 • Use the OFPC dated on June 28,2024,from Response to Production Request No. 107 in the Aurora model; • Remove the CCA allowance cost from the dispatch cost of the Chehalis plant in the Aurora model; • Remove the post-modeling CCA costs,which were calculated based on the multiplication of Chehalis's generation amounts and the CCA allowance cost. • Production Request No. 184(e). 4 • Use the OFPC dated on June 28,2024,from Response to Production Request No. 107 in the Aurora model; • Remove the CCA allowance cost from the dispatch cost of the Chehalis plant in the Aurora model;and • Remove the post-modeling CCA costs,which were calculated based on the multiplication of Chehalis's generation amounts and the CCA allowance cost. • Production Request No. 185(f). 5 • Use the OFPC dated on June 28,2024,from Response to Production Request No. 107 in the Aurora model; • Remove the CCA allowance cost from the dispatch cost of the Chehalis plant in the Aurora model;and • Remove the post-modeling CCA costs,which were calculated based on the multiplication of Chehalis's generation amounts and the CCA allowance cost. 9 Production Request No. 186. PAC-E-24-04/Rocky Mountain Power September 20, 2024 IPUC Data Request 230— I`Supplemental Vt Supplemental Response to IPUC Data Request 230 The Company continues to object to this request as unduly burdensome, requesting the creation of a new analysis or report, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objection, the Company responds as follows: Please refer to Confidential Attachment IPUC 230 1st Supplemental. For Scenario 1,please refer to confidential net power costs (NPC) report "Scenario 1 CONF". The removal of the Washington Climate Commitment Act (CCA) costs are on tab "NPC", row 282. The impact of this removal is a reduction to NPC of approximately $5 million total-company. This reduction is calculated as the difference in NPC from confidential NPC report "ID—GRC-2025-2023 Normalized Load" and confidential NPC report"Scenario 1 CONF". For Scenario 2,please refer to confidential NPC report "Scenario 2 CONF". The removal of the Washington CCA costs are on tab "NPC", row 282. The impact of this removal is a reduction to NPC of approximately $22 million total-company. This reduction is calculated as the difference in NPC in confidential NPC report "0624 OFPC ID—GRC-2025 Update-2023 Normalized Load CONF" (provided with the Company's response to IPUC Data Request 107, specifically Confidential Attachment IPUC 107-2) and confidential NPC report"Scenario 2 CONF". 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: Eshwar Vyakarna Raj shekar Rao /Andy Schroder Sponsor: Ramon Mitchell Joe Dallas (ISB# 10330) Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 97232 Telephone: 3 60-5 60-193 7 Email:joseph.dallas@pacificorp.com Attorney for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. PAC-E-24-04 IN THE MATTER OF THE ) APPLICATION OF ROCKY ) ATTORNEY'S CERTIFICATE MOUNTAIN POWER FOR ) CLAIM OF CONFIDENTIALITY AUTHORITY TO INCREASE ITS ) RELATING TO DISCOVERY RATES AND CHARGES IN IDAHO ) RESPONSES AND APPROVAL OF PROPOSED ) ELECTRIC SERVICE SCHEDULES ) AND REGULATIONS ) I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a senior 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 the Company's first supplemental response IPUC 230 contains Company proprietary information that could be used to its commercial disadvantage. 1 Rocky Mountain Power herein asserts that the aforementioned responses contain confidential in 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 20th day of September, 2024. Respectfully submitted, By Joe Dallas Senior Attorney Rocky Mountain Power 2