20250430APPLICATION.pdf

RECEIVED
April 30, 2025
IDAHO PUBLIC
_ ROCKY MOUNTAIN 1407 W.NorthUTILlTIES TempleCOMMISSION30
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
April 30, 2025
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
RE: IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF A CAPACITY DEFICIENCY PERIOD TO BE USED FOR
AVOIDED COST CALCULATIONS
Attention: Commission Secretary
Please find for filing Rocky Mountain Power's Application in the above-referenced matter. The
confidential and non-confidential workpapers will be provided via BOX.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313.
Very truly yours,
A 9�z a_,_D
Joelle Steward
Senior Vice President, Regulation

Joe Dallas (ISB# 10330)
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone No. [phone]
j oseph.dallas(&,pacificorp.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. PAC-E-25-08
OF ROCKY MOUNTAIN POWER FOR )
APPROVAL OF A CAPACITY ) APPLICATION OF
DEFICIENCY PERIOD TO BE USED FOR ) ROCKY MOUNTAIN POWER
AVOIDED COST CALCULATIONS )
Rocky Mountain Power, a division of PacifiCorp ("the Company"), in accordance with
Idaho Code §61-502, §61-503, RP 052, Order Nos. 32697 and 32802 in Case No. GNR-E-11-03,
Order No. 35810 in Case No. PAC-E-17-09, and Order Nos. 35834 and 35882 in Case No. PAC-
E-22-14, hereby respectfully submits this application("Application")to the Idaho Public Utilities
Commission ("Commission") for approval of the capacity deficiency period determination to be
used in avoided cost calculations using the Surrogate Avoided Resource ("SAR") methodology
applicable to small qualifying facilities ("QFs") eligible for standard pricing (known as "SAR-
Based Contracts") and in the Integrated Resource Plan ("IRP") methodology applicable to larger
QFs eligible for project-specific pricing (known as "IRP-Based Contracts"). This application is
intended to establish the capacity deficiency period for both SAR-Based Contracts and IRP-Based
Contracts.' As more fully described below, this update identifies Rocky Mountain Power's
'See In the Matter of Rocky Mountain Power's Application for Approval of a Capacity Deficiency Period to be
Used for Avoided Cost Calculations, Case No.PAC-E-22-14,Order No. 35834,p.5"The Commission has
previously ordered that public utility companies use the capacity deficiency period to determine capacity payments
for IRP-and SAR-based contracts to ensure QF's are only compensated for costs they avoid in the Company's

capacity deficiency period in the summer of 2028 and explains how the deficiency period was
identified. In support of its Application, Rocky Mountain Power states as follows:
1. Rocky Mountain Power is authorized to do and is doing business in the state of
Idaho. The Company provides retail electric service to approximately 91,000 customers in the
state and is subject to the jurisdiction of the Commission.Rocky Mountain Power is a public utility
in the state of Idaho pursuant to Idaho Code § 61-129.
I. BACKGROUND
3. Commission Order No. 32697 directed the utilities to initiate a case outside of their
IRP filing to establish the capacity deficiency period to be used in the utility's SAR methodology:
"We find it reasonable and fair to subject each utility's determination of capacity deficiency
to further scrutiny. Therefore, when a utility submits its Integrated Resource Plan to the
Commission, a case shall be initiated to determine the capacity deficiency to be utilized in
the SAR Methodology. The capacity deficiency determined through the IRP planning
process will be the starting point, and will be presumed to be correct subject to the outcome
of the proceeding."2
4. In Order No. 32697, the Commission acknowledged that "some determinations
made within the IRP process have an impact on calculations under the SAR and IRP
methodologies. Specifically, the IRP process determines when the utility will experience a need
for new capacity."3 The Commission ordered that payments to QFs should recognize the utility's
capacity needs, stating:
"In calculating a QF's ability to contribute to a utility's need for capacity, we find it
reasonable for the utilities to only begin payments for capacity at such time that the utility
becomes capacity deficient. If a utility is capacity surplus, then capacity is not being
avoided by the purchase of QF power. By including a capacity payment only when the
system. See Order Nos.33377,33159,33898,and 33933. The Commission reiterates the need for the Company to
do so in this case through a compliance filing".
2 In the Matter of the Commission's Review of PURPA QF Contract Provisions Including the Surrogate Avoided
Resource(SAR)and Integrated Resource Planning(IRP)Methodologies for Calculating Avoided Cost Rates, Case
No. GNR-U-11-03,Order No. 32697,p.23.
s Order No.32697,p.23.
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utility becomes capacity deficient, the utilities are paying rates that are a more accurate
reflection of true avoided cost for the QF power."4
5. In Order No. 35415,the Commission stated that"all future L&R Balances included
in the capacity deficiency date update for avoided costs must contain the most up-to-date
information available at the time of filing."5
6. In Order No. 34918, the Commission indicated that early retirement of coal-fired
thermal resources should not be reflected in the load and resource balance, "Unless and until this
Commission evaluates and approves an early retirement date..."6
7. On January 19,2024,the Company filed an application for approval of the capacity
deficiency period to be used for avoided cost rates and in Order No. 36304 the Commission
established July 2025 as the capacity deficit date for avoided cost determinations under the SAR
methodology, for both SAR-Based Contracts and IRP-Based Contracts.
8. In Order No. 35810, the Commission ordered Avista, Idaho Power, and Rocky
Mountain Power to each file its capacity deficiency case within 30 days of filing its respective
Integrated Resource Plan(`IRP").
II. REQUEST TO ESTABLISH AVOIDED COST DEFICIENCY PERIOD
9. On March 31, 2025, Rocky Mountain Power filed its 2025 IRP with the
Commission. The 2025 IRP includes the results of the Company's Capacity Loads and Resources
without Resource Additions for the summer season in Table 6.14 on pages 132-133 and for the
winter season in Table 6.15 on pages 134-135.7 The capacity need is generally highest for summer
a Order No.32697,p.21.
5 In the matter of Idaho Power Company's Application for Approval of the Capacity Deficiency to be Utilized for
Avoided Cost Calculations, Case No.IPC-E-21-09,Order No.35415,p.10.
6 In the Matter of Rocky Mountain Power's Application for Approval of a Capacity Deficiency Period to be Used for
Avoided Cost Calculations, Case No.PAC-E-20-13,Order No. 34918,p.5-6.
7 See workpaper titled "(P)_Fig 6.2-6.7,Tbl 6.14-6.15,9.12-15,2025 IRP Final March-L&R.xlsx"accompanying
this application.
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peak loads, with the summer peak occurring annually in July, as the Company is expected to be
deficient in the summer prior to becoming deficient in the winter. The capacity balance is
developed by determining firm resource capacity available based on the expected capacity
contribution of resources within the Western Resource Adequacy Program (WRAP) less the
system obligation and a planning reserve margin of 14.4 percent in the summer and 16.8 percent
in the winter, also based on values from WRAP.
10. Prior to the start of WRAP in 2028,the capacity balance the Company's firm access
to imports from the wholesale market ("Front Office Transactions" or "FOTs"), but because
standard market products are not expected to count toward WRAP compliance the FOT limit is
assumed to be zero in 2028 and beyond. To ensure reliable system operations, the transmission
system operator of each balancing authority area ("BAA") within the Western Interconnect is
required to maintain contingency reserves equal to three percent of its load and three percent of its
generation, as discussed within the 2023 IRP in Appendix F (Flexible Reserve Study). When the
Company purchases power from counterparties whose generation resources are outside of its
BAAs, which is typical, the three percent contingency reserve obligation associated with
generation remains in the source BAA, and the counterparty remains responsible for it as one of
the ancillary services provided by the transmission system operator for the BAA in which their
generator resides.Because the Company avoids the contingency reserve obligation associated with
such purchases, which would otherwise be required if it generated the associated power itself, the
effective capacity value of market purchases is three percent higher than the equivalent quantity
of generation capacity.
11. The 2025 IRP shows that the Company's load and existing resource balance is less
than the Front Office Transaction limit in 2025 through 2027, but results in a shortfall in the
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summer of 2028 when the market purchase limit is assumed to drop to zero; however, several
inputs must be modified to account for changes since the 2023 IRP was prepared as well as the
treatment of certain resources identified in Commission orders. The 2025 IRP shows shortfalls in
the winter starting in 2030,prior to accounting for changes from previous Commission orders.
12. The following adjustments were made to account for committed and uncommitted
resource impacts, relative to the representation in the 2025 IRP, specifically:
• Removing all uncommitted early coal retirements, consistent with Order No.
36246, specifically:
o Dave Johnston 3 (assumed retirement 2027)
o Colstrip (minority-owner, assumed PacifiCorp exit, 2029)
o Craig (minority-owner, assumed retirement, 2025/2028)
o Hayden(minority-owner, assumed retirement, 2027/2028)
o Jim Bridger 3&4 (after installing carbon capture and sequestration
equipment in 2030, retirement selected upon end of tax credits at end of
2042)
o Naughton 1 (after gas converting in 2026,early retirement selected end of
2042)
• Adding contracts signed since the 2025 IRP was prepared, and removing contracts
that have terminated or expired.
• Adjusting QF renewal assumptions:In the 2025 IRP,QFs in all states were assumed
to have a 75%probability of renewal at the end of their current contract term, and
at the end of the current contract the modeled capacity and energy of each QF
continues at 75% of its prior level. For the avoided cost deficiency period
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determination, the load and resource balance has been adjusted so that all Idaho
QFs renew at 100% of their current contracted levels, while QFs in all other states
remain unchanged. These assumptions are consistent with consistent with Order
No. 36246.
• Adding demand response programs that have received Commission approval,
including projected growth in those programs over time, and delineating existing
Demand Response ("DR") programs, growth of existing DR programs, approved
future DR programs, and growth of approved future DR programs.
• Adding FOTs that have already been contracted.
13. After accounting for the adjustments described above, the first capacity deficiency
of 1,077 megawatts occurs in the summer of 2028,as shown in Table No. 1 below. The first winter
capacity deficiency of 115 megawatts occurs in 2031 as shown in Table No. 2 below$. Summer
capacity deficiencies continue to be somewhat larger than winter capacity deficiencies through
most of the IRP study horizon.
8 See confidential workpaper titled"CONF Workpapers_2025 04_30-PAC-E-25-08 RMP Load and Resource"
accompanying this application.
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Table No. 1
Updated Summer Peak Loads and Resources
System 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034
Total Resources 10,680 11,773 11,697 11,624 11,549 11,345 11,323 11,248 11,177 11,102
Obligation 11,160 11,036 11,084 11,102 11,121 11,153 11,265 11,203 11,278 11,343
Planning Reserves(14.4%) 1,607 1,589 1,596 1,599 1,601 1,606 1,622 1,613 1,624 1,633
Obligation+Reserves 12,767 12,625 12,680 12,701 12,723 12,759 12,887 12,817 12,902 12,977
System Position (2,087) (852) (982) (1,077) (1,174) (1,414) (1,565) (1,569) (1,725) (1,874)
Available Market Purchases 3,196 3,196 3,196 0 0 0 0 0 0 0
Committed Market Purchases
with Reserves 1,133 129 0 0 0 0 0 0 0 0
Uncommitted FOTs to meet
remaining Need 954 723 982 0 0 0 0 0 0 0
Sufficiency/(Deficiency) 0 0 0 (1,077) (1,174) (1,414) (1,565) (1,569) (1,725) (1,874)
System 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045
Total Resources 11,031 10,948 10,849 10,765 10,696 10,625 10,529 10,504 10,433 10,356 10,297
Obligation 11,438 11,637 11,721 11,863 12,019 12,211 12,388 12,753 13,099 13,349 13,612
Planning Reserves(14.4%) 1,647 1,676 1,688 1,708 1,731 1,758 1,784 1,836 1,886 1,922 1,960
Obligation+Reserves 13,085 13,313 13,409 13,572 13,750 13,969 14,172 14,589 14,985 15,272 15,573
System Position (2,053) (2,365) (2,560) (2,807) (3,054) (3,344) (3,643) (4,085) (4,552) (4,916) (5,275)
Available Market Purchases 0 0 0 0 0 0 0 0 0 0 0
Committed Market Purchases 0 0 0 0 0 0 0 0 0 0 0
with Reserves
Uncommitted FOTstomeet 0 0 0 0 0 0 0 0 0 0 0
remaining Need
Sufficiency/(Deficiency) (2,053) (2,365) (2,560) (2,807) (3,054) (3,344) (3,643) (4,085) (4,552) (4,916) (5,275)
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Table No. 2
Updated Winter Peak Loads and Resources
System 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034
Total Resources 11,031 11,830 11,731 11,644 11,550 11,246 11,084 10,997 10,912 10,813
Obligation 9,281 9,296 9,397 9,490 9,544 9,636 9,789 9,888 10,049 10,207
Planning Reserves(16.8%) 1,336 1,339 1,353 1,367 1,374 1,388 1,410 1,424 1,447 1,470
Obligation+Reserves 10,617 10,635 10,750 10,857 10,918 11,024 11,199 11,312 11,497 11,677
System Position 414 1,195 981 787 632 222 (115) (315) (584) (863)
Available Market Purchases 3,196 3,196 3,196 0 0 0 0 0 0 0
Committed Market Purchases
with Reserves 0 52 0 0 0 0 0 0 0 0
Uncommitted FOTs to meet
remaining Need 0 0 0 0 0 0 0 0 0 0
Sufficiency/(Deficiency) 414 1,247 981 787 632 222 (115) (315) (584) (863)
System 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045
Total Resources 10,726 10,637 10,544 10,443 10,359 10,276 10,110 10,033 9,956 9,869 9,787
Obligation 10,321 10,493 10,732 10,973 11,205 11,398 11,596 11,957 12,334 12,637 12,666
Planning Reserves(16.8%) 1,486 1,511 1,545 1,580 1,614 1,641 1,670 1,722 1,776 1,820 1,824
Obligation+Res erves 11,807 12,003 12,278 12,553 12,819 13,039 13,265 13,678 14,110 14,456 14,490
System Position (1,081) (1,366) (1,733) (2,110) (2,460) (2,763) (3,155) (3,646) (4,154) (4,588) (4,703)
Available Market Purchases 0 0 0 0 0 0 0 0 0 0 0
Committed Market Purchases 0 0 0 0 0 0 0 0 0 0 0
with Reserves
Uncommitted FOTs to meet 0 0 0 0 0 0 0 0 0 0 0
remaining Need
Sufficiency/(Deficiency) (1,081) (1,366) (1,733) (2,110) (2,460) (2,763) (3,155) (3,646) (4,154) (4,588) (4,703)
14. Based on these updates, the Company requests that the Commission find the
summer of 2028 as the first capacity deficiency period when capacity payments should be made
to QFs under the SAR and IRP avoided cost methodologies.
15. Rocky Mountain Power submits this Application to establish the capacity
deficiency period as set forth in Commission Orders Nos. 32697 and 32802, and requests that the
Commission approve the capacity deficiency period to be used in its SAR and IRP-method
calculations.
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III. COMMUNICATIONS
16. Communications regarding this Application should be addressed to:
Mark Alder
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
Email: mark.alderkpacificorp.com
Joe Dallas (ISB# 10330)
Senior Attorney
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:Loseph.dallas(a,pacificorp.com
In addition, Rocky Mountain Power requests that all data requests regarding this
Application be sent in Microsoft Word to the following:
By email (preferred): datarequest&pacificorp.com
By regular mail: Data Request Response Center
PacifiCorp
825 Multnomah, Suite 2000
Portland, Oregon 97232
Informal questions may be directed to Mark Alder, Idaho Regulatory Affairs Manager at
[phone].
IV. MODIFIED PROCEDURE
17. Rocky Mountain Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed under Modified
Procedure; i.e., by written submissions rather than by hearing. RP 201 et seq. If, however, the
Commission determines that a technical hearing is required, the Company stands ready to prepare
and present its testimony in such hearing.
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V. CONFIDENTIAL INFORMATION
18. This filing, specifically the Confidential Workpapers, contain confidential
information including trade secret and other Company confidential information exempt from
public review under Idaho Code §§ 74-104-109 and Idaho Public Utilities Commission's Rule of
Procedure 67.
VI. CONCLUSION
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission issue
an order authorizing this Application be processed under Modified Procedure and approving the
capacity deficiency period beginning July 2028, be used in the Company's avoided cost
determinations under the SAR methodology, for both SAR-Based Contracts and IRP-Based
Contracts, as shown in Table No. 1 above.
DATED this 301h day of April, 2025.
ROCKY MOUNTAIN POWER
Joe Dallas
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone No. [phone]
j oseph.dallaskpacificorp.com
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