20200810PAC to Staff 8-11.pdf

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August 10,2020
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washinglon
Boise,ID 83702-5918
ian. nori)ruki@f uc. idaho. gov
RE:ID PAC-E-20-10
IPUC 2d Set Data Request (8-14)
Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests 8-l l. The
remaining resporses will be provided separately.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclostrres
PAC-E-20-10 / Rocky Mountain Power
August 10,2020
IPUC Data Request 8
IPUC Data Request 8
Please provide the full rate schedule for Fixed Energy Rates listed in the
Appendix B of the 1984 confiact. The full schedule should include different
online yea6.
Response to IPUC Data Request 8
Please refer to the Company's response to IPUC Data Request 2 dated July 14,
2020,and to the Company's lo Supplemental response dated July 31,2020.
Recordholder:
Sponsor:
Kyle Moore
To BeDetermind
PAC-E-20-10 / Rocky Mountain Power
August 10,2020
IPUC Data Request 9
IPUC Date Request 9
Please provide the OrderNumber and Case Number that approved the rate
schedule mentioned above.
Response to IPUC Data Rcquest 9
The Coryany assumes that the referenced to "mentioned above" is intended to be
a reference to IPUC Data Request 8. Based on the foregoing assumptiorl the
Cornpany responds as follows:
Please refer to the Company's response to IPUC Data Request 3 dated July 14,
2020.
Recordholder:
Sponsor:
Kyle Moore
To Be Determined
PAC-E-20-10 / Rocky Mountain Power
August 10,2020
IPUC Data Request 10
IPUC Data Request l0
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:
(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/l l0 requirement? Please provide an example.
Response to IPUC Data Request 10
(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 l6-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 Califomia 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-20-10 / Rocky Mountain Power
August 10,2020
IPUC DataRequest l0
(c) PacifiCorp's Idaho service tenitory is located within the PacifiCorp East
(PACE) balancing authority area (BBA), which is more closely connected to
Palo Verde (PV) than Md-Columbia (Mid-C).
(d) "DGAP_PACE-APND" refetrs 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 forpurposes of the 90/ll0 require,me,nt ffs simFly an average of all
hourly prices over the month as reported by the Firm Market Price Index.
Recordholder:DanMacNeil/Kyle Moore
To Be DetermindSponsor:
PAC-E-20-10 / Rocky Mountain Power
August 10,2020
IPUC Data Request 1l
IPUC Data Request 11
Exhibit K of the Power Purchase Agreement states that Mid-C-85 is equal to*85yo of weighted average of the average Firm Market Price Index for the month,
or portion of month, of Net Output". Please reconcile the use of Mid-C in Exhibit
K and the use of Palo Verde in the definition of Firm Market Price Index.
Response to IPUC Data Request 11
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 "Firm Market Price Index". Therefore. no further
reconciliation should be necessary.
Recordholder:
Sponsor:
Kyle Moore
To Be Determined