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Home My WebLink About20241022PAC to PIIC 31-39_42_46_49-50.pdf RECEIVED Tuesday, October 22, 2024 IDAHO PUBLIC _ ROCKY MOUNTAIN UTILITIES COMMISSION POWER A DIVISION OF PACIFICORP 1407 W North Temple, Suite 330 Salt Lake City, Utah 84116 October 22, 2024 Ronald L. Williams Brandon Helgeson Attorneys For PIIC rwilliams(&hawleytroxell.com(C) bhel eg son&hawleytroxell.com(C) Bradley Mullins brmullins(c�mwanalytics.com(C) Val Steiner val.st einer nitafo s.com Kyle Williams williamsk(&byui.edu RE: ID PAC-E-24-04 PIIC Set 2 (29-50) Please find enclosed Rocky Mountain Power's Responses to PIIC 2nd Set Data Requests 31-39, 42, 46 and 49-50 and Attachments. The remaining responses will be provided under separate cover. Provided via BOX are the Confidential Attachments. 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.: Monica Barrios-Sanchez/IPUC monica.barriossanchez(ii),puc.idaho.gov (C) S ecretary(a,Duc.Idaho.gov Eric L. Olsen/IIPA elo(&echohawk.com(C) Lance Kaufman/IIPA lancena,ae isg insi hg t.com(C) Matthew Nykiel/ICL matthew.nykielkamail.com Brad Heusinkveld/ICL bheusinkveld(a�idahoconservation.org Thomas J. Budge/Bayer tj racineolson.com(C) Brian C. Collins/Bayer bcollins(&consultbai.com Greg Meyer/Bayer gme erkconsultbai.com Kevin Higgins/Bayer khia gins&energystrat.com(C) Neal Townsend/Bayer ntownsend(u-benergystrat.com (C) PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 31 PIIC Data Request 31 Reference witness Meredith work paper"ID GRC Blocking 2024,"Tab"BD-9:" Please identify the specific timeframes used for the two different peak and off- peak KWh values in the referenced work paper. Response to PIIC Data Request 31 The identifications are as followings: TKWH-SON: total on-peak kilowatt-hour (kWh) sales from the summer months June to October; TKWH-SOFF: total off-peak kWh sales from the summer months June to October; TKWH-WON: total on-peak kWh sales from the winter months November to May; TKWH-WOFF: total off-peak kWh sales from the winter months November to May. Recordholder: James Zhang Sponsor: Robert Meredith PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 32 PIIC Data Request 32 Please identify the FERC accounts where insurance costs proposed to be included in the Insurance Adjustment Mechanism are recorded and identify the amount recorded to each FERC account. Response to PIIC Data Request 32 The excess liability insurance premiums included in the Insurance Cost Adjustment(Schedule 92), would be included in FERC Account 925. Please refer to Exhibit 52 for the amount of excess liability insurance premiums proposed in the Test Period. Recordholder: Laura Miller Sponsor: Shelley McCoy PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 33 PIIC Data Request 33 For each FERC account where insurance costs are recorded,please specify how insurance costs would be functionalized in the absence of the Insurance Adjustment Mechanism. Response to PIIC Data Request 33 Insurance costs are booked to FERC Account 925. If these costs had been included in the class cost of service (COS) study, they would have been functionalized on the "PTD" functional factor which is approximately 45.3 percent to the Production function, 27.2 percent to the Transmission function, and 27.5 percent to the Distribution function. Recordholder: Robert Meredith Sponsor: Robert Meredith PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 34 PIIC Data Request 34 Reference witness Mitchell work paper GNw—Market Price Index CONF:Please provide updated versions of the referenced work paper based on the official forward price curve issued on or around June 30, 2024 and September 30, 2024. Please provide the response in two separate files. Response to PIIC Data Request 34 Please refer to Confidential Attachment PIIC 34. 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 Sponsor: Ramon Mitchell PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 35 PIIC Data Request 35 Reference witness Mitchell work paper"Aurora GN Market Prices CONF," Tab "OFPC:"Please provide updated versions of the referenced work paper based on the official forward price curves issued on or around June 30, 2024 and September 30, 2024. Please provide the response in two separate files. Response to PIIC Data Request 35 Please refer to Confidential Attachment PIIC 35. 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 Rajshekar Rao Sponsor: Ramon Mitchell PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 36 PIIC Data Request 36 Please provide non-confidential versions of the official forward price curves issued on or around June 30, 2024 and September 30, 2024. Response to PIIC Data Request 36 Please refer to the Company's response to IPUC Data Request 107, specifically Attachment IPUC 107-1, which provides the Company's June 30, 2024 official forward price curve (OFPC). Please refer to Attachment PIIC 36 which provides the Company's September 30, 2024 OFPC. Recordholder: Elaine Biggs Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 37 PIIC Data Request 37 Reference Witness Mitchell work paper"Aurora GN Regulating Margin CONF:" Please specify the hourly MWs of reserves included in the referenced work paper that are attributable to the following: (a) Non-Native resources (i.e. resources not used to serve PacifiCorp's retail requirements). (b) Non-Native loads. (i.e. retail and wholesale loads not served by PacifiCorp). Response to PIIC Data Request 37 The Company assumes that references to "non-native" are references to "third- parry". Based on the foregoing assumption, the Company responds as follows: Please refer to the Company's response to Bayer Data Request 96, specifically Confidential Attachment Bayer 96. (a) For the third-party resources, zero out the values in cells C2 and D2 on tab "Area vs System Capacities" in each of the templates. (b) For the third-party loads, zero out the value in cell B2 on tab "Area vs System Capacities" in each of the templates. Once the changes are made to the templates, compare the megawatt(MW) requirements in column D of tab "Results" in each of the templates to the MW requirements provided in confidential work paper"Aurora GN Regulating Margin CONF" for the 2025 forecast period. Recordholder: Eshwar Vyakarna Rajshekar Rao Sponsor: Ramon Mitchell PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 38 PIIC Data Request 38 Reference witness Mitchell work paper"Aurora GN Regulating Margin CONF:" Please provide fully functional work papers used to calculate the reserve values in the referenced work paper. Response to PIIC Data Request 38 Please refer to the Company's response to Bayer Data Request 96. Recordholder: Isaiah Zacharia Sponsor: Ramon Mitchell PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 39 PIIC Data Request 39 Reference witness Mitchell work paper"Aurora GN Regulating Margin CONF:" Please provide step-by-step instructions for how to recalculate the reserves in the work papers used to calculate the reserve values in the referenced work paper. Specifically, please explain how to modify the assumed levels of loads and resources included in the reserves calculation. Response to PIIC Data Request 39 Please refer to the Company's response to Bayer Data Request 96. In each of the templates, navigate to tab `BAA Reserve Requirements". The levels of loads and resources can be adjusted by changing the values in the columns with"Peak Factor", "Capacity Factor" and"Capacity" (columns H through M). Recordholder: Eshwar Vyakarna Rajshekar Rao Sponsor: Ramon Mitchell PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 42 PIIC Data Request 42 Does PacifiCorp currently have a requirement under NERC or WECC requiring operating (i.e. contingency)reserves to be held on spinning versus non-spinning resources? If no, please describe the changes that have occurred with respect to that requirement and identify the date that the change occurred. Response to PIIC Data Request 42 No. North American Electric Reliability Corporation (NERC)BAL-002-WECC-3 Requirement 1.2 does not specify a requirement to provide contingency reserve obligations by specific type, or ratio of specific type of resource. This change was adopted by NERC on August 15, 2019. Recordholder: Janice Bacon Sponsor: To Be Determined PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 46 PIIC Data Request 46 Please explain how PacifiCorp estimated the non-owned loads included in the Aurora model. Response to PIIC Data Request 46 The Company assumes that references to "non-owned" are references to "third- party". Based on the foregoing assumption, the Company responds as follows: The Company calculates third-party load as the difference between control area (balancing area) load and the Company's retail load. The test period third-party load is calculated as the 48-month average of actual third-party loads. Please refer to the confidential work papers supporting the direct testimony of Company witness, Ramon J Mitchell, specifically confidential file "GNw Load Cont CONF". Recordholder: Eshwar Vyakarna Rajshekar Rao Sponsor: Ramon Mitchell PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 49 PIIC Data Request 49 Please provide PacifiCorp's calculation of the Idaho ECAM balance for calendar year 2024 through the most recent month available. Response to PIIC Data Request 49 Rocky Mountain Power objects to this request as outside the scope of this proceeding and not reasonably calculated to lead to the discovery of admissible information. Without waiving any objection, the Company responds as follows: The information requested is included with the Q2 2024 energy cost adjustment mechanism(ECAM) report filed with the Idaho Public Utilities Commission (IPUC) on August 30, 2024. For ease of reference, a copy of the Q2 2024 ECAM report is provided as Attachment PIIC 49-1 and Confidential Attachment PIIC 49.2. 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: Jack Painter Sponsor: Jack Painter PAC-E-24-04/Rocky Mountain Power October 22, 2024 PIIC Data Request 50 PIIC Data Request 50 Please provide actual net power costs for calendar years 2023 and 2024 to date, including the supporting transactional and fuel databases. Response to PIIC Data Request 50 The Company objects to this request as overly broad and not reasonably calculated to lead to the discovery of admissible evidence. Notwithstanding the foregoing objections, the Company responds as follows: Please refer to Attachment PIIC 50-1 and Confidential Attachment PIIC 50-2 which provide PacifiCorp's total-Company actual net power costs (NPC) reports for calendar year 2023 and calendar year 2024 to-date (January 2024 through July 2024) together with the actual NPC database entries, along with their mapping and fuel supply cost calculations for calendar year 2023 and calendar year 2024 to-date (January 2024 through July 2024). 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: Jack Painter Sponsor: Jack Painter