20200805PAC to Staff 9-12.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
August 6, 2020
Jan Noriyuki
Yao Yin Idaho Public Utilities Commission
472 W. Washington Boise, ID 83702-5918 [e-mail]
[e-mail]
RE: ID PAC-E-20-07
IPUC 2nd Set Data Request (9-12)
Please find enclosed Rocky Mountain Power’s Responses to IPUC Data Requests 9-12.
If you have any questions, please feel free to call me at [phone].
Sincerely,
____/s/____
J. Ted Weston Manager, Regulation
Enclosures
RECEIVED
2020 August 5, PM 4:02
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-20-07 / Rocky Mountain Power August 6, 2020
IPUC Data Request 9 IPUC Data Request 9 Please provide the full rate schedule of Fixed Energy Rates listed in the Restated
Appendix B of the Second Amended Power Purchase Agreement. The full schedule should include different online years. Response to IPUC Data Request 9 Please refer to the Company’s response to IPUC Data Request 2 dated July 14, 2020 and the Company’s 1st Supplemental response to IPUC Data Request 2
dated July 29, 2020. Recordholder: Kyle Moore
Sponsor: To Be Determined
PAC-E-20-07 / Rocky Mountain Power August 6, 2020
IPUC Data Request 10 IPUC Data Request 10 Please provide the order number and case number that approved the rate schedule
mentioned above. Response to IPUC Data Request 10 The Company assumes that “mentioned above” is intended to be a reference to IPUC Data Request 9. Based on the foregoing assumption, the Company responds as follows:
Please refer to the Company’s response to IPUC Data Request 3 dated July 14, 2020, and the Company’s 1st Supplemental response to IPUC Data Request 3 dated July 29, 2020.
Recordholder: Kyle Moore Sponsor: To Be Determined

PAC-E-20-07 / Rocky Mountain Power August 6, 2020
IPUC Data Request 11 IPUC Data Request 11 Firm Market Price Index is defined on Page No. 4 of the Power Purchase
Agreement as “the hourly value calculated based on the average prices reported by the Intercontinental Exchange, Inc. (ICE) Day-Ahead PV On-Peak Index and the ICE Day-Ahead PV Off-peak Index (each an ICE Index) for a given day, weighted by the count of hours for each ICE Index on such day, multiplied by the hourly CAISO day-ahead market locational marginal price for the ‘PACE.
DGAP_PACE-APND’ location and divided by the average of the same CAISO index over all hours in such day”. Please answer the following questions: (a) The definition uses Day-Ahead PV On-Peak Index and Off-Peak Index. Does PV refer to Palo Verde Hub?
(b) Please explain why the index prices adjusted by the locational marginal prices in the CAISO represent the best market price relative to the utilities avoided cost.
(c) Please explain why the Mid-Columbia Hub is not used to determine index prices. (d) What location is PACE. DGAP_PACE-APND?
(e) How are the hourly prices under this method averaged at the monthly level for the purposes of the 90/110 requirement? Please provide an example. Response to IPUC Data Request 11
(a) Yes. “PV” refers to the Palo Verde hub. (b) The Intercontinental Exchange, Inc. (ICE) reports day-ahead prices for up to two periods each day: a heavy-load hour (HLH) or on-peak period from 6:00
a.m. to 10:00 p.m. Pacific Prevailing Time (PPT), and a light-load hour (LLH)
or off-peak period from 12:00 a.m. to 6:00 a.m. and 10:00 p.m. to 12:00 a.m. ICE prices are a good representation of the Company’s costs for these blocks of hours, as the Company frequently transacts with counterparties using ICE indexes. However, the 16-hour block of hours within the HLH period in
particular spans a wide range of conditions that are not adequately represented
by an average value. The California Independent System Operator’s (CAISO) day-ahead market index is publically available and provides hourly granularity, but it has limited
volumes at the market points where the Company frequently transacts. By
combining the shape from the CAISO index, and the overall price from ICE, the Company’s proposal combines the best features of each.
PAC-E-20-07 / Rocky Mountain Power August 6, 2020
IPUC Data Request 11 (c) PacifiCorp’s Idaho service territory is located within the PacifiCorp East (PACE) balancing authority area (BBA), which is more closely connected to
Palo Verde (PV) than Mid-Columbia (Mid-C). (d) “DGAP_PACE-APND” refers to the Default Generation Aggregate Price for the PACE BAA. The “APND” indicates this price is an Aggregated Price Node, i.e. not a specific point. This price reflects an average of PACE
generation resources. (e) Prices for purposes of the 90/110 requirement are simply an average of all hourly prices over the month as reported by the Firm Market Price Index. Please refer to the Company’s response to IPUC Data Request 12 subpart (a)
for the correct definition for “Index Price”. Recordholder: Dan MacNeil / Kyle Moore
Sponsor: To Be Determined
PAC-E-20-07 / Rocky Mountain Power August 6, 2020
IPUC Data Request 12 IPUC Data Request 12 Exhibit K of the Power Purchase Agreement states that Mid-C-85 is equal to
“85% of weighted average of the average Index Price for the month, or portion of month, of Net Output”. Please answer the following questions: (a) The Agreement does not provide a definition of Index Price. Please define Index Price.
(b) Please reconcile the use of Mid-C in Exhibit K and the use of PV (assumed to be Palo Verde) in the definition of Firm Market Price Index. Response to IPUC Data Request 12
(a) In the power purchase agreement (PPA) between Birch Power Company and PacifiCorp executed May 19, 2020, the term “Index Price” in Exhibit K was used in error; it should be a reference to the “Firm Market Price Index”.
(b) The naming convention in the formula for “Non-Conforming Energy Purchase Price” included the term “Mid-C-85”. While this naming convention is confusing and for clarity’s sake should have been changed to “PV-85”, the formula/definition itself does not refer to the Mid-Columbia (Mid-C) market,
but rather refers back to the “Index Price” which, as identified in the Company’s response to subpart (a) above, should have referenced “Firm Market Price Index”. Therefore, no further reconciliation should be necessary.
Recordholder: Kyle Moore Sponsor: To Be Determined