20150720Staff 8-11 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION ..rir i: ipoBox g3720 *",,, ,ijl Aij fli t: 57
BOISE, IDAHO 83720-0074 li, , , ,(208)334-03t4 -Tilti. : 1,.; ..1
ISB NO. 6864
Street Address for Express Mail:
472 W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER'S 2015
INTEGRATED RESOURCE PLAN.
) CASE NO. PAC-E-15-04
)) SECOND PRODUCTTON
) REQUEST OF THE COMMISSION) srAFr ro Rocr(Y MoUNTAIN
) POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power,
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than MONDAY, AUGUST 3,2015r.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01101.228.
' Staffis requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY
MOUNTAIN POWER I JULY 2O,2OI5
This Production Request is to be considered as continuing, and Rocky Mountain is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identiff the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 8: In Order No. 32890, the Commission directed the Company to
increase its efforts toward achieving higher levels of cost-effective DSM, and to present clear
and quantifiable metrics regarding decisions to implement or decline to implement energy
efrficiency programs. Please describe the Company's efforts to comply with this order.
REQUEST NO. 9: In its Capacity Balance Determination, the Company explains that it
determines its annual system peak obligation by subtracting Existing Class 2 DSM (Volume I
pages 79 and 136). This was not done in the Company's previous IRPs. Please explain the
rationale, methodology, and potential impacts of this change. In particular, please explain:
a) How does the Company derive 110 MW of Class 2 DSM capacity reduction (page79)
from its 2014 Class 2 DSM energy savings?
b) How was this reduction allocated between the East and West control areas (page 81)?
c) Volume II Table D.3. shows a total nameplate capacity reduction of 565 MW. According
to Footnote No. 8, this is not a coincident peak reduction (page 66). What coincident
peak reduction is associated with this 565 MW capacity reduction? How was this vaiue
determined, and how does it relate to the 110 MW capacity reduction described earlier?
d) According to Table 5.14, the Company anticipates that Class 1 DSM and Class 2 DSM
capacity contributions will remain constant through 2024. According to Figures 8.20 and
8.24,the Company anticipates substantial increases in Class 2 DSM load contributions.
Please explain the differences between the anticipated DSM load contributions in
Chapters 5 and 8.
SECOND PRODUCTION REQUEST OF
THE COMMTSSION STAFF TO ROCKY
MOL]NTAIN POWER 2 JULY 20,2OI5
REQUEST NO. 10: Please describe the process for validating the Company's System
Benefits Tool (SBT) model. Please provide the results of any validation work that has already
been completed. How will the SBT model be validated as more information becomes available?
REQUEST NO. 11: The peak capacity contribution values for wind and solar energy
presented in Tables N.1 and N.2 differ substantially from those presented in Appendix O of the
Company's 2013 IRP. Please explain these differences, and explain why the Company believes
the 2015 IRP methodology to be preferable to that used in the 2013 IRP.
DATED at Boise, Idaho, thir}Dhyof July 20t5.
Technical Staff: Mike Morrison (8-11)
i:umisc:prodreq/pacel5.4npjbmmsd prod req2
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY
MOUNTAIN POWER
Deputy Attorney General
ruLY 20,20t5
CERTIFICATE OF SERVICE
I HEREBy CERTIFy rHAT I HAVE THIS 20'h DAy oF JULy 2015,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSTON STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E.I5-04, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-MAIL : ted.weston@f'acifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@f acifi com.com
[e-mail]
WONNE HOGLE
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84I11
E-MAIL: fvonne.hoeel@pacifi corp.com
CERTIFICATE OF SERVICE