20191121Staff 23-28 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAIIO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 l2
IDAI]O BARNO.9917
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER TO CLOSE THE
NET METERING PROGRAM TO NEW
SERVICE & IMPLEMENT A NET BILLING
PROCRAM TO COMPENSATE CUSTOMER
GENERATORS FOR EXPORTED
GENERATION.
iiECEIVED
iOY 2l Atl ll: L6
. ce lilu;sstox
CASE NO. PAC.E.I9.O8
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
1',1,
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomeys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staffof'the ldaho Public Utilities Commission, by and through its attorney ofrecord,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and inlbrmation as soon as possible. but no later than THURSDAY,
DECEMBER 9,20I9.'
This Production Rcquest is to be considered as continuing. and Rocky Mountain Power 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 or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the nan:e, job title, and telephone number of
I Staffis requesting an expedited response, Ifresponding by this date will be problematic, please call Staffs
attomey at (208) 334-03 12.
FOURTH PRODUCTION REQUES'f
TO ROCKY MOUNTAIN POWER I NOVEMBER 21,2019
REQUEST NO. 23: On page 93 of its 2019 Flexible Reserve Study (2019 IRP Volume
II, Appendix F), the Company introduces a quantile regression model for Combined Diversity
Error. For this model, please provide the following information:
a. The model, including all regression coefficients with units for each;
b. If modeling data was normalized/transtbrmed, please provide sample workpapers
showing the normalization/transfbrmation and how this was performed;
c. The standard error on each modeling coefficient;
d. The standard error ofthe whole model quantile estimate;
e. The sample quantile value (t) used in modeling, as well as an explanation ofthe
Company's rationale for selecting that particular quantile value;
f. How was this formula obtained (e.g. forward regression modeling, backward
regression modeling, mixed regression modeling, or some other method); and
g. Were interaction terms considered for inclusion in this model? Please explain
why or why not.
FOURI'H PRODUCI'ION REQUEST
TO ROCKY MOLTNTAIN POWER 2 NOVEMBER 2I.2OI9
the person preparing the documents. Please identify the name, job title, location, and telephone
number ofthe record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic filcs on CD u,ith formulas intact and enabled.
REQUEST NO.24: On pages 93 and 94 of its 2019 Flexible Reserve Study (2019 IRP
Volume II, Appendix F), the Company states that its forecast is adjusted to achieve a cumulative
Loss ofLoad Probability that corresponds to the annual reliability target. Please provide
workpapers showing how this was done.
REQUEST NO,25: The formula for Combined Diversity Enor given on page 93 of the
Company's 2019 Flexible Reserve Study (2019 IRP Volume II, Appendix F) includes terms for
Wind Forecast and Solar Forecast. Were Idaho Schedule 135 net exports included in this
forecast? If not, please explain why this study should be used as a proxy for the eltects of Idaho
Schedule 135 net exports. Ifso, please provide the regression coefficients for Schedule 135 net
exports, with standard errors fbr each coefficient.
REQUEST NO.26: Please provide the dates, times, and loads of the top 100 peaking
events for the calendar year 2017 .
REQUEST NO. 27: Please provide the results of all Loss of Load Probability studies
related to the avoided capacity value of Schedule 135 net exports.
REQUEST NO, 28: The Company proposes that the transition period would only apply
to residential customers. Please provide an estimate ofthe annual financial impact for each
Idaho Schedule 135 non-residential customer.
DATED at Boise, Idaho, this day ofNovember 2019.
Davn H
Deputy Attorney General
i:umisc prodreq/paccl9 Sdhnrmit prod .cq 4
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 NOVEMBER 2I,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY TFIAT I HAVE THIS 2I'1 DAY OF NOVEMBER 2019,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OFTHE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E.19-08,
BY MAILING A COPY THE,REOF, POSTAGE PREPAID, TO THE FOLI,OWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NOR'TH TEMPLE STE 330
SALT LAKE CITY UT 84II6
E-MAIL: ted.w'eston@pacifi corrr.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6r'H ST
BOISE ID 83702
E-MAIL: botto idahoconservation.or
ANTHONY YANKEL
I27OO LAKE AVE
t NIT 2505
LAKEWOOD OH441O7
E-MAIL: [e-mail]
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
D-MAIL: Dreston cartcr(asivensp urslev.cotn
kendrah(rDgivcnspurslEy.ca4
SECRE RY
CERTIFICATE OF SERVICE
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
YVONNE R HOGLE
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 841I6
E-MAIL: yvonne.hos.le@pacifi corp.com
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