20241003PAC to Staff 230 - 3rd Supplemental.pdf

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

October 3, 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 3rd Supplemental Response to IPUC 12th Set Data
Request 230. Also provided is Attachment IPUC 230 3rd Supplemental.

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
Thursday, October 03, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-24-04 / Rocky Mountain Power
October 3, 2024
IPUC Data Request 230 – 3rd 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 costs2, 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.
• Production Request No. 186.

PAC-E-24-04 / Rocky Mountain Power
October 3, 2024
IPUC Data Request 230 – 3rd Supplemental

3rd 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:

Further to the Company’s prior responses to IPUC Data Request 230, the
Company provides the following additional information:

Please refer to Attachment IPUC 230 3rd Supplemental which provides the
updated work paper “5.1 – NPC.xlsx” based on scenario 2. This attachment has
been corrected for a sum formula error that inadvertently excluded cells.

Recordholder: Nick Highsmith

Sponsor: Shelley McCoy