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Home My WebLink About20250814Reply Comments.pdf RECEIVED August 14, 2025 IDAHO PUBLIC UTILITIES COMMISSION _ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330 POWER. Salt Lake City,UT 84116 A DIVISION OF PACIFICORP August 14, 2025 VIA ELECTRONIC DELIVERY Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd Building 8 Suite 201A Boise, ID 83714 RE: CASE NO.PAC-E-25-08 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 Pursuant to Commission Order No. 36614 authorizing the processing of the Application by Modified Procedure and establishing the procedural schedule, please find Rocky Mountain Power's Reply Comments in the above referenced matter. Due to its large file size, Confidential Attachment A will be sent via BOX. Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313. Very truly yours, a,1�0 Joe Steward 9L Senior Vice President, Regulation Joe Dallas (ISB# 10330) PacifiCorp,Assistant General Counsel 825 NE Multnomah Street, Suite 2000 Portland, OR 97232 Email:joseph.dallaskpacificorp.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 ) REPLY COMMENTS OF DEFICIENCY PERIOD TO BE USED FOR ) ROCKY MOUNTAIN POWER AVOIDED COST CALCULATIONS ) Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities Commission("Commission")and the Commission's February 15,2024,Notice of Application and Notice of Modified Procedure, Rocky Mountain Power a division of PacifiCorp (the "Company") hereby submits reply comments in the above-referenced case. I. BACKGROUND 1. On April 30, 2025, the Company applied for approval of the capacity deficiency period beginning July 2028 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 using the Integrated Resource Plan ("IRP")methodology applicable to larger QFs eligible for project-specific pricing(known as"IRP- Based Contracts"). 2. On May 29, 2026, Commission Order No. 36614 provided public notice of the Company's application and also a notice of modified procedure establishing the procedural REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page l schedule allowing persons who would like to file written comments to have until July 31, 2025, and the Company having until August 14, 2025, to file reply comments. 3. On July 31,2025, Commission Staff filed comments.No other party has intervened or filed comments. II. REPLY COMMENTS 4. Staff recommends that the Commission order the Company to: • 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; • 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 • Break Demand Response("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. 5. The Company appreciates Staff's comments and is willing work with Staff on all three of their recommendations. The L&R update will be discussed in more detail, but as a preliminary matter,the Company would welcome the opportunity to meet with Staff to explore the possibility of developing an Idaho-specific portfolio for the purpose of determining the capacity deficiency date before the next IRP. In addition, the Company will break down demand response into existing DR, growth of existing DR, and approved future DR in its next capacity deficiency filing. 6. The Company is not opposed to including Available Market Purchases in a compliance filing. The 2025 Integrated Resource Plan assumed zero reliance on market purchases for capacity beginning in 2028, in part because the nature of short-term contracts was expected to change to meet compliance requirements under the Western Resource Adequacy Program and the REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page 2 California Independent System Operator's Extended Day-Ahead Market. These evolving requirements make the availability, structure, and cost of short-term resource opportunities to meet resource adequacy and reliability requirements uncertain, but some short-term resource opportunities are likely to exist in the future as various utilities and market participants are likely to have excess supply in some periods and insufficient supply in others. 7. Keeping this perspective in mind and to address Staff's recommendation to include Available Market Purchases throughout the planning horizon,PacifiCorp has updated the load and resource balance to include the long-term market purchase limits identified in its 2023 IRP Update, which allowed for market purchases for capacity of up to 1,000 megawatts in the summer and 1,500 megawatts in the winter.' The market purchase limit is intended to balance the risk of reliance on short-term supply with the shorter commitment, lower cost, and flexibility it can provide. After incorporating this change in the Available Market Purchase limit along with the updates identified in Response to Staff Production Request No. 22, the first summer deficiency period remains in 2028, but the size of the shortfall is reduced significantly, to 47 megawatts.2 In the Company's initial filing,the first winter deficiency occurred in 2031,and the updated Available Market Purchase limit delays the first winter deficiency to 2037, with a value of 188 megawatts. III. CONFIDENTIAL INFORMATION 8. This filing, specifically Confidential Attachment A, contains 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. 1 PacifiCorp's 2023 IRP Update. Chapter 5 (Modeling and Assumptions),Table 5.1.Available at: https://www.pacificorp.com/content/dam/pcorp/documents/epZpacificorp/energy/integrated-resource- plan/2023 IRP Update.pdf 2 See Confidential Attachment A. REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page 3 IV. REQUEST FOR RELIEF 9. Based on the foregoing, the Company respectfully requests that the Commission accept Confidential Attachment A as complying with the items raised by Staff in their comments and issue an order 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. DATED this 14t'day of August 2025. Respectfully submitted, ROCKY MOUNTAIN POWER Joe Dallas (ISB# 10330) PacifiCorp,Assistant General Counsel 825 NE Multnomah Street, Suite 2000 Portland, OR 97232 Email:joseph.dallas&pacificorp.com Attorney for Rocky Mountain Power REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page 4 CONFIDENTIAL ATTACHMENT A IS PROVIDED SEPARATELY IN EXCEL FORMAT