20180329PAC to PIIC Supplemental 30-34.pdf

RECEIVED
ROCKY MOUNTAINPOWER '20\S E 29 AM ll:42
A OfV1SION OF PACŒlCORP 1407 W North Temple,Suite 330
SSION Salt Lake City,Utah 84116
March 29,2018
Ronald L.Williams,ISB No.3034
802 W.Bannock Street,Suite 900
Boise,ID 83702
[e-mail](C)
RE:ID PAC-E-17-07
PIIC 5*Set Data Request (21-42)
Please find enclosed Rocky Mountain Power's 1"Supplemental Responsesto PIIC 5*Set Data
Requests 30,31,and 34.Provided on the enclosed Confidential CD is Confidential Attachment
PIIC 34 1"Supplemental and Confidential Response to PIIC 30 1"Supplemental.
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/Monsanto [e-mail] (C)(W)
Katie Iverson/[e-mail] (C)
Eric Olsen/IIPA [e-mail] (C)
AnthonyYankel/IIPÀ[e-mail](C)
Randall C.Budge/Monsanto [e-mail] (C)
Thomas J.Budge/Monsanto [e-mail] (C)(W)
Diane Hanian/IPUC [e-mail] (C)
PAC-E-17-07 /Rocky Mountain Power
March 29,2018
PIlC 5th Set Data Request 30 -l"Supplemental
PIIC Data Request 30
Is PacifiCorp required to submit independently balanced EIM Base Schedules for
PACE and PACW balancing area pursuant to the CAISO's EIM tariff or
PacifiCorp Transmission's EIM tariff?If yes,please provide a citation to the tariff
corresponding to the requirement.If no,please explain how the EIM base
schedules are determined for the respective balancing areas.
1"Supplemental Confidential Response to PIIC Data Request 30
Further to the Company's response to PIIC Data Request 30 dated March 19,
2018,and pursuant to the PacifiCorp Idaho Industrial Customers'(PIIC)Motion
to Compel dated March 26,2018,PacifiCorp continues to object to this request as
not reasonably calculated to lead to the discovery of relevant or admissible
evidence.Without waiving this objection,PacifiCorp responds as follows:
PacifiCorp submits a balanced schedule for both of its balancing authority areas
(BAA)separately,but these schedules consider the resource positions in both the
PacifiCorp East (PACE)and PacifiCo West (PACW)BAAs.For example,
PacifiCo will schedule the
which is in the PACW BAA,into the PACE BAA to
facilitate energy transfers for economic or reliability purposes.Similarly,
PacifiCorp will schedule energy or reserves to the PACW BAA from resources in
the PACE BAA if it is economic or for reliability reasons.The final balanced
schedules that are submitted for the PACE and PACW BAAs are "independently"
balanced,but they use resources across both BAAs.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Kelcey Brown
Sponsor:To Be Determined
PAC-E-17-07 /Rocky Mountain Power
March 29,2018
PIIC 5th Set Data Request 31 -1"Supplemental
PIIC Data Request 31
Does the EIM provide PacifiCorp with the ability to schedule firm energy
between balancing areas in an amount exceeding the firm transmission rights that
PacifiCorp possesses between the two balancing areas?If yes,please explain,
with references to specific tariff provision,how transfers of such firm energy
transfers may be accomplished.
1"Supplemental Response to PIIC Data Request 31
Further to the Company's response to PIIC Data Request 31 dated March 19,
2018,and pursuant to the PacifiCorp Idaho Industrial Customers'(PIIC)Motion
to Compel dated March 26,2018,PacifiCorp continues to object to this request as
not reasonably calculated to lead to the discovery of relevant or admissible
evidence.Without waiving this objection,PacifiCorp responds as follows:
No.
Based on information received in PIIC's brief in support of its Motion to Compel,
the Company clarifies that the economic analysis in this docket does not assume
that additional 300 megawatts (MW)of transmission capability that will be
available when Idaho Power Company (IPC)joins the energy imbalance market
(EIM)is "firm"transmission,nor does PacifiCorp assert that it can "use the EIM
to achieve new,firm transmission rights on another EIM participants'system[.]"
Recordholder:Kelcey Brown
Sponsor:To Be Determined
PAC-E-17-07/Rocky Mountain Power
March 29,2018
PIIC 50'Set Data Request 34 -1"'Supplemental
PIIC Data Request 34
Please provide uninstructed imbalance charges for the following wind facilities on
a monthly basis (or the greatest level of granularityavailable)over the period
January 1,2015 through June 30,2017:
(a)Glenrock.
(b)Glenrock III.
(c)Foote Creek.
(d)McFadden Ridge.
(e)Seven Mile Wind.
(f)Seven Mile II Wind.
(g)Top of the World Wind.
(b)Dunlap Wind.
(i)High Plains Wind.
(j)Mountain Wind I.
(k)Mountain Wind II.
(1)Rock River I.
(m)Rolling Hills Wind
1"Supplemental Response to PIIC Data Request 34
Further to the Company's responseto PIIC Data Request 34 dated March 19,
2018,and pursuant to the PacifiCorp Idaho Industrial Customers'(PIIC)Motion
to Compel dated March 26,2018,PaciflCorp continues to object to this request as
not reasonably calculated to lead to the discovery of relevant or admissible
evidence.Without waiving this objection,PacifiCorp responds as follows:
Consistent with PIIC's Motion to Compel narrowing the scope of the request to
PIIC Data Request 34 subparts (d)and (h),please refer to Confidential
Attachment PIIC 34 1"Supplemental,which provides the requested information
for subparts (d)and (h)above.
PAC-E-17-07/Rocky Mountain Power
March 29,2018
PIIC 50'Set Data Request 34 -1"Supplemental
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Ray Zacharia
Sponsor:To Be Determined