20171130PAC to Staff 4th Suppl UT - UAE Set 2 (1-3).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OF PACIFICORP
November 17,2017
Gary A.Dodge
HATCH,JAMES &DODGE
10 West Broadway,Suite 400
Salt Lake City,Utah 84101
[e-mail] (C)
Kevin Higgins
Neal Townsend
ENERGY STRATEGIES
215 S.State Street,#200
Salt Lake City,UT 84111
[e-mail](C)(W)
RE:UT Docket No.17-035-40
UAE 2nd Set Data Request (1-3)
Please find enclosed Rocky Mountain Power's Responses to UAE Data Requests 2.1-2.3.Also
provided are Attachments UAE 2.1-(1-2)and UAE 2.2-1.Provided on the enclosed
Confidential CD is Confidential Attachment UAE 2.2-(2-4)and UAE 2.3.
Confidential informationis provided subject to Public Service Commission of Utah (UPSC)
Rules 746-1-602 and 603.
If you have any questions,please call me at [phone].
Sincerely,
Jana Saba
Manager,Regulation
Enclosures
C.c.Erika Tedder/DPU [e-mail]@utah ov (C)
Dan Kohler/DPU [e-mail] (C)
Dan Peac/DPU [e-mail] (C)(W)
Aliea Afnan/DPU [e-mail] (W)
jbower@daymarkeeaso_m (W)
Philip Hayet/OCS p_hayet@j};ennn.co_m (C)
Béla Vastag/OCS [e-mail] (C)
Sophie Hays/UCE [e-mail](C)
Kate Bowman/UCE [e-mail](C)(W)
Emma Rieves/UCE [e-mail](C)(W)
Lisa Tormoen Hickey/[e-mail] (C)
Mitch Longson/Interwest [e-mail] (C)
Nancy Kelly/[e-mail](C)
Jennifer Gardner/WRA [e-mail](C)
Penny Anderson/WRA [e-mail] (W)
Peter J.Mattheis/Nucor [e-mail] (C)
Eric J.Lacey/Nucor [e-mail] (C)(W)
17-035-40 /Rocky Mountain Power
November 17,2017
UAE Data Request 2.1
UAE Data Request 2.1
Reference the accuracy of Company's Official Forward Price Curve (OFPC):
(a)Has the Company ever performed an analysis to quantifythe 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 provide this 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 monthlybasis 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 monthlyspot 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 UAE Data Request 2.1
(a)No,PacifiCorp has not conducted this type of analysis.
(b)The Company objects to this request on the basis that it is overlybroad 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-yearcurves are then
used to supersede the initial years of the most recent quarterly OFPC.
Please refer to Attachment UAE 2.1-1,which provides the quarterly OFPCs and the
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November 17,2017
UAE Data Request 2.1
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 UAE 2.1-2,
which provides the monthlyaverage market prices derived from the day-ahead price
from archived proprietary sources (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 response to subpart (d)above.
17-035-40 /Rocky Mountain Power
November 17,2017
UAE Data Request 2.2
UAE Data Request 2.2
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 ultimatelyexecuted 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 executingthe referenced
transactions,and if not already provided in response to another request,please
provide a copy of the OFPC.
(f)Please provide the actual monthlysettlements data associated with the referenced
transactions over the period 2013 (includingthe 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,approximately 2023).Please provide the deal tracking data in a manner
substantially similar to the Company's GRID modeling Gas Swaps work paper (See
e.g."ORTAMl8w Gas Swaps (1612)FEBl7 CONF").
(h)If not readily apparent from the data provided in response to this request please
identify the monthlyfixed prices associated with the referenced transactions over the
term of the transactions.
Confidential Response to UAE Data Request 2.2
17-035-40 /Rocky Mountain Power
November 17,2017
UAE Data Request 2.2
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 UAE 2.2-1 for the order in the referenced docket.The
order provides requirements ordered by the Public Service Conunission of Utah
(UPSC).
(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 (withthe
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 representationof
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 UAE 2.2-2.
(f)Please refer to Confidential Attachment UAE 2.2-3,which provides actual monthly
settlements data from September 1,2013 through September 30,2017 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 UAE 2.2-4,which provides the deal tracking
data from the Company energy trading system (ETS)record over the period August
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November 17,20 17
UAE Data Request 2.2
2017 through August 2023.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.
17-035-40 /Rocky Mountain Power
November 17,2017
UAE Data Request 2.3
UAE Data Request 2.3
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 hourlywind 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 UAE Data Request 2.3
(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 generationlevels 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,particularlywhen they are constrained areas.To this end,an
hourly shape for new wind resources is prepared based on a blend of the hourly
output 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 hourly output is rounded to the nearest megawatt (MW)and thus has less
precision.This also eliminates duplicative results,as many of the small existing
resources are next to larger existing resources.
The historical hourly shapes 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 because
repowering 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)generationprofile of the future wind resource.This adjustment is
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November 17,2017
UAE Data Request 2.3
comparable to that 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 internallycalculates "time of day"blocks from the hourlydata,
representing summer and winter peak,off-peak and super-peak patterns.SO model
generationis reported in gigawatt hours (GWh).
PaR is similar to SO except a sample week is selected each month to determine wind
generationlevels,which is then scaled within PaR for the relevant month.To
eliminate the unintended distortion of monthlywind 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 monthlyand annual generation.PaR
generationis also reported in GWh.
(c)Please refer to Confidential Attachment UAE 2.3,which provides the hourlynew
wind profiles referenced in the Company's response to subpart (b)above.
Confidential information is provided subject to Public Service Commission of Utah
(UPSC)Rule 746-1-602 and 746-1-603.