20171117PAC to Staff 16-18 - Redacted.pdf

RECEIVED
ROCKY MOUNTAIN 20\l NOV 17 PM 4:43POWER
A OlmON OF WOW
!C 1407 W North Temple,Suite 330
i "t!LIT SS ON Salt Lake City,Utah 84116
November 17,2017
Ronald L.Williams,ISB No.3034
802 W.Bannock Street,Suite 900
Boise,ID 83702
ron williamsbradbury.com (C)
RE:ID PAC-E-17-07
PIIC 3'd Set Data Request (16-18)
Please find enclosed Rocky Mountain Power's Responsesto PIIC 3rd Set Data Requests 16-18.
Also provided are Attachments PIIC 16-1,16-2,and 17-1.Provided on the enclosed CD are
Confidential Attachments PIIC 17-2,17-3,17-4,and 18.
Confidential information is provided subject to the terms and conditions of the protective
agreement in this proceeding.
If you have any questions,please feel free to call me at [phone].
Sincerely,
J.Ted Weston
Manager,Regulation
Enclosures
C.c.:Brad Mullins/PIIC [e-mail] (C)
Jim Duke/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/[e-mail] (W)
Brian C.Collins/Brubaker&Associates [e-mail] (C)(W)
James R.Smith/Monsanto [e-mail] (C)(W)
Maurice Brubaker/[e-mail] (C)(W)
Katie Iverson/[e-mail] (C)
Eric Olsen/IIPA [e-mail] (C)
AnthonyYankel/IIPA tony vankel.net (C)
Randall C.Budge/Monsanto [e-mail] (C)
Thomas J.Budge/Monsanto [e-mail](C)(W)
Diane Hanian/[e-mail] (C)
PAC-E-l7-07 /Rocky Mountain Power
November 17,2017
PIIC 3rd Set Data Request 16
PHC Data Request 16
Reference the accuracy of Company's Official Forward Price Curve (OFPC):
(a)Has the Company ever performed an analysis to quantify the forecast error
associated with previously-issued long-term official forward price curves?If
yes,please provide any such analyses.
(b)Please provide each OFPC the Company issued over the period December
2006 through January 2017 (inclusive),including all power and natural gas
hubs where the Company transacts.Please include forward prices for each
month and year for which the forecast was prepared.Please providethis data
in format similar to the Company's response to ICNU Data Request 001 in
OR.PUC Docket No.UE 307.
(c)Please provide actual spot market prices,on a monthly basis over the period
January 2007 through September 2017 (inclusive),including all power and
natural gas hubs where the Company transacts.
(d)When evaluating the forecast error associated with previously issued Official
Forward Price Curves,does the Company agree that such an analysis may be
reasonably performed using price curves issued over the period 2007 through
2017?If no,please identify the period which the Company believes would
provide the most reasonable basis for measuring the forecast error associated
with previously issued OFPCs.
(e)If the Company believes that the forecast error associated with its OFPCs
would be more reasonably measured over a longer period of time than 2007
through 2017,please provide each OFPC issued and monthly spot market
prices,in the same manner as identified subparts (b)and (c)to this request,
over the period the Company believes would be more reasonable for
measuring the forecast error of previously issued OFPCs.
Response to PIIC Data Request 16
(a)No,PacifiCorp has not conducted this type of analysis.
(b)The Company objects to this request on the basis that it is overly broad and
unduly burdensome.Without waiving the objection,the Company generally
issues its official forward price curve (OFPC)on a quarterly basis.In addition,
for the Oregon transition adjustment mechanism (TAM)indicative and final
filings,the Company develops two 10-year forward price curves (starting in
Oregon Docket UE 296)or three-year forward price curves.These 10-year
curves or three-year curves are then used to supersedethe initial years of the
most recent quarterly OFPC.
PAC-E-17-07 /Rocky Mountain Power
November 17,2017
PIIC 3rd Set Data Request 16
Please refer to Attachment PIIC 16-1,which provides the quarterly OFPCs
and the final TAM OFPCs covering December 2006 through January 2017.
(c)The Company objects to this request on the basis that it is overly broad and
unduly burdensome.Without waiving the objection,please refer to
Attachment PIIC 16-2,which provides the monthly average market prices
derived from the day-ahead price from archived proprietarysources (where
available)for each month covering January 2007 through September 2017.
(d)The Company objects to the request on the basis that it assumes facts not in
evidence.Please refer to the Company's response to subpart (a)above.
(e)Please refer to the Company's responseto subpart (d)above.
Recordholder:Connie Clonch /Debi Baker /Cecil Nembhard
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
November 17,2017
PIIC 3rd Set Data Request 17
PIIC Data Request 17
Reference the long-term gas contracts executed pursuant to the Company's 2012
Gas RFP,as discussed in UT.PSC Docket 12-035-102:
(a)Does the Company agree that it ultimately executed two gas transaction
pursuant to the referenced 2012 Gas RFP?If yes,please provide a brief
overview of these transactions.
(b)Please identify the counterparty associated the referenced transactions.
(c)Does the Company agree that the referenced transactions were subject to a
requirement that the levelized price of the gas contracts not exceed the
levelized market price in the Company's forward price curve (just as the
economics of the Company's Energy Vision 2020 project are highly
dependent upon the prices in the Company's OFPC)?
(d)How accurate has the OFPC that the Company relied upon when executing the
referenced transactions been?
(e)Please identify the OFPC the Company relied upon when executing the
referenced transactions,and if not already provided in response to another
request,please provide a copy of the OFPC.
(f)Please provide the actual monthly settlements data associated with the
referenced transactions over the period 2013 (including the earliest month
where settlements were made)through the most recent month with available
settlement data.Please provide the settlement data in the same format as
provided in "Attach ECAM MFR 3 -3 CONF"in the ongoing Energy Cost
Adjustment Mechanism Proceeding before the Wyoming Public Service
Commission (Docket No.20000-514-EA-17).
(g)Please provide the deal tracking data from the Company's energy trading
system over the period August 2017 through the term of the referenced
agreements (based on a ten-year term,approximately2023).Please provide
the deal tracking data in a manner substantially similar to the Company's
GRID modeling Gas Swaps work paper (See e.g."ORTAM18w_Gas Swaps
(1612)FEBl7 CONF").
(h)If not readily apparent from the data provided in responseto this request
please identify the monthly fixed prices associated with the referenced
transactions over the term of the transactions.
PAC-E-17-07 /Rocky Mountain Power
November 17,2017
PIIC 36 Set Data Request 17
Confidential Response to PIIC Data Request 17
The Company objects to this request on the basis that the requested information
will not likely lead to the discovery of admissible evidence and is beyond the
scope of this case.Without waiving the objection,the Company states as follows:
(b)Please refer to the Company's response to subpart (a)above.
(c)Please refer to Attachment PIIC 17-1 for the order in the referenced docket.
The order provides requirements ordered by the Public Service Commission
of Utah.
(d)The Company's official forward price curve (OFPC)is updated and validated
by the Company's risk management group within the energy supply
management (ESM)business unit against other published price curves at the
end of each quarter (with the exception of the two OFPCs issued specifically
for the Company's annual Oregon Transition Adjustment Mechanism (TAM))
to assure its accuracy at that given point in time.The OFPC is an indication to
where parties could reasonably trade for a specific term and price as of the
date the OFPC is produced.In addition to the quarterly OFPC,the Company
produces a daily forward price curve (FPC)that is an indication of where
parties could reasonably trade for a specific term and price as of the date the
FPC is produced.The Company monitors the daily exposure of all fixed price
deals against a daily produced FPC,which is an accurate representation of
forward prices at a given point in time.
(e)At the time of the transaction execution,the Company relied on the daily FPC
of August 12,2013 and the daily FPC of August 22,2013 for the two
identified transactions executed as a result of the 2012 Natural Gas RFP).
Please refer to Confidential Attachment PIIC 17-2.
(f)Please refer to Confidential Attachment PIIC 17-3,which provides actual
monthly settlements data from September 1,2013 through September 30,
PAC-E-17-07 /Rocky Mountain Power
November 17,2017
PIIC 3rd Set Data Request 17
2017 for transaction 1250444 and transaction 1256734 (the natural gas swap
transactions executed as a result of PacifiCorp's 2012 Natural Gas RFP).
(g)Please refer to Confidential Attachment PIIC 17-4,which provides the deal
tracking data from the Company energy trading system (ETS)record over the
period August 2017 through August 2023.
Confidential information is provided subject to the protective agreement in tlus
proceeding.
Recordholder:Stephen Fendrich /John Akiyama /Teresa Tang
Sponsor:To Be Determined
PAC-E-17-07/Rocky Mountain Power
November 17,2017
PIIC 3rd Set Data Request 18
PIIC Data Request 18
Reference the Company's wind shaping methodology:
(a)When modeling the new wind resources in the System Optimizer and PaR
models,did the Company use the same hourly wind shaping methodology that
it uses in the GRID model for forecasting net power costs in general rate case,
and other related,proceedings?
(b)Please provide a description of how the hourly wind profiles for the new wind
resources were modeled in the SO and PaR models.
(c)Please provide the hourly wind profiles for each of the new wind resources as
input into the System Optimizer and PaR models.
Response to PIIC Data Request 18
(a)In general rate cases (GRC),the Company uses a wind shaping methodology
based on a single calendar year of hourlyenergy output from each owned and
purchased wind facility.The actual generation levels are scaled up or down so
that the average output over the course of a day and a month is the same as the
forecasted level.This methodology is applied to all wind resources for which
data is available during the historical period.The proposed wind resources do
not have historical data so this methodology would not apply.
The Company recognizes that a reasonably correlated hourly shape is
important to evaluate wind resources,particularly when they are constrained
areas.To this end,an hourlyshape for new wind resources is prepared based
on a blend of the hourlyoutput of two existing wind projects.The two
existing projects which are closest to the new resource's location are used,but
smaller existing projects are excluded as the reported hourlyoutput is rounded
to the nearest megawatt (MW)and thus has less precision.This also
eliminates duplicativeresults,as many of the small existing resources are next
to larger existing resources.
The historical hourlyshapes of the two closest existing wind resources are
blended together,with the hourly shape of the closer resource receiving a
higher weighting,based on their relative distances.The un-repowered shapes
are used becauserepowering capacity and large generator interconnection
agreement (LGIA)limits may not be aligned.The adjusted rather than actual
shape is used because it has been aligned with the characteristic week used in
the Planning and Risk (PaR)model.The resulting hourly shape is adjusted
such that the result matches the 12-month by 24 hour (12x24)generation
profile of the future wind resource.This adjustment is comparable to that
PAC-E-17-07/Rocky Mountain Power
November 17,2017
PIIC 3rd Set Data Request 18
performed to align historical hourly shapes with median generation forecasts
for existing resources.
(b)The wind profiles for new wind resources are modeled in the System
Optimizer model (SO model)and the PaR model as an index,using annual
hourlypattern data (365 days by 24 hours).The annual pattern represents the
hourly capacity factor.
The SO model internally calculates "time of day"blocks from the hourly data,
representing summer and winter peak,off-peak and super-peak patterns.SO
model generation is reported in gigawatt hours (GWh).
PaR is similar to SO except a sample week is selected each month to
determine wind generation levels,which is then scaled within PaR for the
relevant month.To eliminate the unintended distortion of monthly wind
shapes due to relying on a sample week,the PaR inputs are recast such that
every week of a given month has the same pattern but preserves the expected
monthly and annual generation.PaR generation is also reported in GWh.
(c)Please refer to Confidential Attachment PIIC 18,which provides the hourly
new wind profiles referenced in the Company's response to subpart (b)above.
Confidential information is providedsubject to the protective agreement in this
proceeding.
Recordholder:Dan MacNeil and Dan Swan
Sponsor:Rick Link