20250731Staff Comments.pdf

RECEIVED
JEFFREY R. LOLL July 31, 2025
DEPUTY ATTORNEY GENERAL IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11675
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION FOR APPROVAL ) CASE NO. PAC-E-25-08
OF A CAPACITY DEFICIENCY PERIOD TO )
BE USED FOR AVOIDED COST )
CALCULATIONS ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Jeffrey R. Loll, Deputy Attorney
General, submits the following comments.
BACKGROUND
On April 30, 2025, Rocky Mountain Power, a division of PacifiCorp ("Company"),
applied to the Commission for approval of the capacity deficiency period determination to be
used for both Surrogate Avoided Resource-based contracts and Integrated Resource Plan-based
contracts.
The Company represents that after accounting for adjustments, the first capacity
deficiency of 1,077 megawatts occurs in the summer of 2028, and the first winter capacity
deficiency of 115 megawatts occurs in 2031. Application at 6.
STAFF COMMENTS 1 JULY 31, 2025

STAFF ANALYSIS
Staff reviewed the load forecast, the planning reserve margin("PRM"), and the existing
resources included in the proposed load and resource balance ("L&R"), which identifies the
Company's capacity deficiency over a 20-year planning horizon based on the difference between
load with PRM and existing resources. The time when the first deficits occur in the L&R
determines when new qualifying facilities start receiving capacity payments. The Company
proposed a capacity deficiency date of 2028.
Staff s comments focused on four areas after its review: the PRM determined by the
Western Resource Adequacy Program ("WRAP"), Available Market Purchases, contract
updates, and Demand Response ("DR"). Staff recommends that the Commission order the
Company to do the following:
1. File an updated L&R and updated capacity deficiency dates through a compliance
filing to include Available Market Purchases throughout the entire planning horizon and
incorporate contract updates contained in the Company's Response to Staff Production Request
No. 22;
2. Meet with Staff to explore a possibility of developing an Idaho-specific portfolio for
the purpose of determining the capacity deficiency date before the next IRP process starts; and
3. Break DR into three DR categories in future capacity deficiency filings: existing DR,
growth of existing DR, and approved future DR to clearly show the level of each category.
WRAP PRM
The Company used the L&R from the integrated preferred portfolio of the 2025
Integrated Resource Plan ("IRP") as a starting point to develop the proposed L&R in this case for
determining the amounts and the timing of capacity deficiency. Because the purpose of this case
is to determine when the Company has insufficient capacity, reliability should be the only
consideration. However, the integrated preferred portfolio in the 2025 IRP was driven by several
considerations in addition to reliability, such as environmental requirements of other jurisdictions
and economic reasons to reduce resource costs. To remove the impact of the effects the
Company proposed to use the minimum WRAP PRM' in the proposed L&R, instead of the
'A PRM represents an incremental capacity requirement above the load forecast to ensure that there will be
sufficient capacity available on the system to meet a Company's reliability target.
STAFF COMMENTS 2 JULY 31, 2025

original PRM of the integrated preferred portfolio, to reduce the impact of these non-reliability
considerations. Ist Supplemental Response to Staff Production Request No. 4(b).
Staff believes it is acceptable to use the minimum WRAP PRM in the proposed L&R for
this filing, because Staff believes the minimum WRAP PRM better reflects capacity needs driven
by reliability to determine when the Company's reliability target will not be met by the
Company's existing resources.
The Company started with three jurisdictional portfolios (i.e. the Oregon jurisdiction, the
Washington jurisdiction, and the Utah/Idaho/Wyoming/California jurisdiction) in the IRP
process to arrive at the system integrated preferred portfolio. Staff would like to explore the
possibility of developing an Idaho-specific portfolio for the next capacity deficiency case.
Therefore, Staff recommends that the Commission order the Company to meet with Staff to
explore such a possibility for the purpose of determining the capacity deficiency date before the
next IRP process starts.
Available Market Purchases
The Company proposed that the L&R exclude "Available Market Purchases" starting in
2028 when WRAP starts, because WRAP only allows specified sources to count towards its
compliance, and most of the standard market purchases come from unspecified sources. lst
Supplemental Response to Staff Production Request No. 13. This treatment deviates from the
Company's traditional treatment of Available Market Purchases in previous L&Rs filed in
capacity deficiency filings. Staff believes that the deficit date should be determined by including
capacity contribution of expected amounts of market purchases, which will delay the deficit date
further into the future. Therefore, Staff recommends that the Company file an updated L&R
through a compliance filing to include Available Market Purchases throughout the entire
planning horizon.
Staff believes that compliance with WRAP does not affect the Company's capabilities
and opportunities to pursue market purchases. On Page 178 of the 2025 IRP, the Company states
that"[w]hile the 2025 IRP does not allow FOTs to meet WRAP compliance requirements,
PacifiCorp expects to continue pursuing economic short-term and intermediate-term market
opportunities that assist with WRAP compliance and/or balancing." Also, the Company states
that it remains open to short-term market products when long-term resources are not available or
STAFF COMMENTS 3 JULY 31, 2025

when there is not sufficient time to bring new resources online. Response to Staff Production
Request No. 15. Therefore, Staff believes that it is not reasonable to completely exclude
Available Market Purchases in the L&R. If the amount of Available Market Purchases decreases
due to higher capacity needs and fewer resources in the Western Interconnection, Staff believes
that the Company should adjust the amounts of Available Market Purchases accordingly to
reflect the trend, instead of excluding all the Available Market Purchases completely. Therefore,
Staff recommends that the Commission order the Company to file an updated L&R to include
Available Market Purchases throughout the entire planning horizon.
Contract Updates
There have been several contract updates since the proposed L&R was prepared.
Response to Staff Production Request No. 22. Staff recommends that the Commission order the
Company to file an updated L&R to incorporate these contract updates contained in Response to
Staff Production Request No. 22.
DR
The proposed L&R includes all the DR programs as one line item. Order No. 35834
required that the Company should clearly label the growth in existing DR programs. Staff
recommends that the Commission order the Company to break DR into three DR categories in
future capacity deficiency filings: existing DR, growth of existing DR, and approved future DR
to clearly show the level of each category.
STAFF RECOMMENDATION
Staff recommends that the Commission order the Company to do the following:
1. File an updated L&R and updated deficiency dates through a compliance filing, which
includes Available Market Purchases throughout the entire planning horizon and incorporates
contract updates contained in Response to Staff Production Request No. 22;
2. Meet with Staff to explore a possibility of developing an Idaho-specific portfolio for
the purpose of determining the capacity deficiency date before the next IRP process starts; and
3. Break DR into three DR categories in future capacity deficiency filings: existing DR,
growth of existing DR, and approved future DR to clearly show the level of each category.
STAFF COMMENTS 4 JULY 31, 2025

Respectfully submitted this 31 st day of July 2025.
1 d4o;�I)�4
ffrey oll
Deputy Attorney General
Technical Staff. Yao Yin
I:\Utility\UMISC\COMMENTS\PAC-E-25-08 Comments.docx
STAFF COMMENTS 5 JULY 31, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31sT DAY OF JULY 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-25-08, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTER
ROCKY MOUNTAIN POWER E-MAIL ONLY:
1407 WEST NORTH TEMPLE STE 330 datarequest(d),pacificorp.com
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH, SUITE 2000
PORTLAND, OR 97232
E-MAIL:[e-mail]
PATRICIA JORD. , SECRETARY
CERTIFICATE OF SERVICE