20200915PAC to Staff 1st Supplemental Response.pdf

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Salt Lake City, Utah 84116
September 15,2020
JanNoriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
i an.noriyuki@puc. idaho. gov (C)
RE: ID PAC-E-20-10
IPUC 3'd Set Data Request (15-23)
Please find enclosed Rocky Mountain Power's ls Supplemental Responses to IPUC Data
Requests 15, 17, 19, 20, and 23.
If you have any questions, please feel free to call me at [phone].
Sincerely,
--1sl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Greg Adams/Fall River [e-mail] (C)
PAC-E-20-10 / Rocky Mountain Power
September 15,2020
IPUC Data Request 15 - l't Supplemental
IPUC Data Request 15
Please describe how the Company processes payments when a QF produces
energy outside the monthly 90/110 band. In addition, please answer the following:
(a) Does the Company examine every hour that falls outside the 90/110 band and
determine its contract price depending on whether that hour is an On-Peak
hour or an Off-Peak hour? If yes, does the Company do this before comparing
against the 85%o of the market price of that month?
(b) Please provide examples to illustrate how the Company identifies hours
outside the 90/110 band and processes payment for these hours, with contract
prices that are below 85% of the market price and when they are above 85%
of the market price.
Supplemental Request
fni following supplemental request was received from the Idaho Public Utilities
Commission (IPUC) staffon September 3,2020:
The Company's response to IPUC 15 states that the energy generated outside the
90/110 band will be paid "at the lower pricing". Order 29632 requires that price to
be the lower of 85 percent of the market price or the contract price. Please advise
how PacifiCorp determines the contract price for each month for the 90/110
purpose. Currently all the contracts only include an annual price and heavy load
hour (HLH) / light load hour (LLH) adjusting factors, and an average monthly
price is not available.
I't Supplemental Response to IPUC Data Request 15
Further to the Company's response to IPUC Data Request 15 dated September 1,
2020 andthe supplemental request received from Idaho Fublic Utilities
commission (IPUC) staffon September 3,2020, the company responds as
follows:
The Company states that the existing qualiffing facility (QF) power purchase
ugree-ent (PPA) between PacifiCorp and CDM Hydroelectric Company Limited
Partnership (CDM Hydro) i Fall River Rural Electric Cooperative,Inc. (Fall
River), also referred to as Felt Hydro, does not include energy payments based on
a90 I ll0 band. However, the QF PPA between PacifiCorp and Fall River
executed in May 2020 andthe subject of this proceeding does include energy
payments based on a 90 / 110 band. The effective date for the new May 2020
agreement is April l,2O2l. The settlements in 2019 did not have a90 I 1'10 band.
Therefore, for the purposes of responding to this supplemental data request, the
Company will discuss how energy payments based on a 90 i 110 band would be
calculated based on the May 2020 contract terms.
PAC-E-20-10 / Rocky Mountain Power
September 15,2020
IPUC Data Request 15 - l't Supplemental
The contract price for each month is determined as follows:
If the energy is conforming energy, it is paid at the annual conforming energy
price multiplied by the monthly on-peak / off-peak multipliers.
a
o If the energy is non-conforming (outside the 90 / 110 band) the eF is paid at
the lower of (a) the conforming energy price, or (b) 85 percent of the Firm
Market Price Index adjusted by 82.4 percent to account for the non-firm
nature of the power. Note: while the 82.4 percent factor is not in the contract
presently before the IPUC for approval, the company expects to execute an
amended and restated contract with Fall River including this term based on
comments from IPUC staffprior to final IPUC approval.
In addition, while IPUC staffhas stated a concern that the contract did not state
monthly conforming energy payments ("contract price" as used in the
supplemental data request), applying the monthly on-peak / off-peak multipliers
to the annual conforming energy price produces monthly conforming energy
prices.
Recordholder:
Sponsor:
Debbie Blake lKyle Moore
To Be Determined
PAC-E-20-10 / Rocky Mountain Power
September t5,2020
IPUC Data Request l7 - l't Supplemental
IPUC Data Request 17
Please describe the capabilities of the Company's Accounts Payable system to
process payments to QFs using different rates depending on the amount of
generationover set intervals. Specifically, can the system process payments by
applying different rates based on different ranges of MWhs generated in each
hour?
Supplemental Request
Thiiollowing supplemental request was received from the Idaho Public Utilities
Commission (IPUC) staffon September 3,2020:
The Company's response to IPUC 17 describes the Settlecore system, which "sets
up all the calculations specific to the contract parameters and produces the
statement for the vendor at each rate and range of megawatt hours generated for
the calendar month". Does the current "settlecore" system have the capability to
apply different rates based on different ranges of megawaff-hours (NfWh)
generated in each hour. Can the "settlecore" system accommodate this at the
hourly level?
l't Supplemental Response to IPUC Data Request 17
Further to the Company's response to IPUC Data Request l7 dated September l,
2020 atdthe supplemental request received from Idaho Public Utilities
commission (IPUC) staffon September 3,2020, the company responds as
follows:
Yes, the current "settlecore" system does have the capability to apply a rate based
on different ranges of megawatt-hours (MWh) generated in each hour.
Recordholder:
Sponsor:
Debbie Blake
To Be Determined
PAC-E-20-10 / Rocky Mountain Power
September t5,2020
IPUC Data Request l9 - lst Supplemental
IPUC Data Request L9
In calculating the Load and Resource Balance to identitr the first capacity deficit
date in the IRP process, how does the company determine an existing eF's
resource contribution at peak to meet the company's need for capacity?
Supplemental Request
The following supplemental request was received from the Idaho Public Utilities
Commission (IPUC) staffon September 8,2020:
The Company's response to IPUC l9 states that the capacity balance counts
resources at maximum system srunmer peak availability. How is the capacity
availability of hydro qualifring facilities (QF) determined? Is it based on some
historic data? If so, what kind of historic data is used? Or is a capacity factor
applied (determined in a separate analysis) to hydro eF nameplates?
I't Supplemental Response to IPUC Data Request 19
For planning pu{poses, the capacity in the summer peak and winter peak is
determined by using the monthly energy forecast data and converting it to average
megawatt (MW) for each qualiffing facility (QF) bV state. This is done by taking
the QF generation megawatt-hours (MWh) and dividing by the number of hours
in each month. The maximum capacity by month is input into the Integrated
Resource Plan (IRP) model and a capacity planning contribution of 1 is applied.
This is transferred into the capacrty load and resource balance report.
Recordholder:
Sponsor:
Dan Swan
To Be Determined
PAC-E-20-10 / Rocky Mountain Power
September 15,2020
IPUC Data Request 20 - l't Supplemental
IPUC Data Request 20
Please provide the amount of generation in each hour from the Felt Hydro QF for
the past five years (from 2015 to 2019) and indicate how far above or below each
year is to normal water conditions. If hourly meter data are not available, please
provide the data at the minimal time interval available.
Supplemental Request
The following supplemental requests were received from the Idaho Public
Utilities Commission (IPUC) staff on September 4,2020 and September 8,2020:
(1) The Company's response to IPUC 20 provided the amount of generation in
each hour from the Felt Hydro project for the past five years from 2015 to
2019. lt looks like there are some anomalies in the data for years 2016, 2017 ,
and 2018. Please refer to IPUC provided attachment "IPUC 20 - IPUC
Provided Attachment - Anomalies 20200908 CONF". There are three types of
anomalies: negative generation amounts, zeros, and numbers greater than the
5,500 kilowatt-hour (kwh) nameplate of PowerHouse#Z. Please advise what
caused the anomalies, whether zeros represent no generation or unavailable
data, and what are the best estimates to replace the anomalies.
(2) Please advise why the data for January 2017 through April2017, January
2018 and February 2018, and February 2019 through December 20l9have
only one amount of generation across the entire month, instead of hourly data?
Please refer to IPUC provided attachment "IPUC 20 - IPUC Provided
Attachment - Anomalies 20200908 CONF".
(3) For the generation amounts for year 2017 which occurred on hour ending 2 of
April 1, 2017. Please refer to IPUC provided attachment "IPUC 20 - IPUC
Provided Attachment - Anomalies 20200908 CONF". For this particular hour,
it is 5,025 kWh. This appears to be another anomaly in the data that requires
explanation. The hours proceeding this data point for the entire month of
March 2017 is 4,321 kwh, and the hours after this data point for the rest of
April2017 is 4,686 kWh. Please advise.
l't Supplemental Response to IPUC Data Request 20
Further to the Company's response to IPUC Data Request 20 dated September 3,
2020 andthe supplemental requests received from Idaho Public Utilities
Commission (IPUC) staffon September 4,2020 and Septembet 8,2024,the
Company responds as follows:
(1) Referencing the Company's response to IPUC Data Request 20, and
specifically Confidential Attachment IPUC 20:
PAC-E-20-10 i Rocky Mountain Power
September t5,2020
IPUC Data Request 20 - I't Supplemental
servrce.
The company disagrees with the characteization that the data provided
contained "anomalies". The items that IPUC staffrefers to as "anomalies,, are
not "anomalies" but rather situations that occur with typical generation
production and metering. There is no replacement estimated data. As long as
delivered energy meets the contractual obligations, the counterparty is deemed
to have met its generation obligations. Note: the cDM Hydro / Fall River
Rural Electric cooperative / Felt Hydro project is not a pacificorp owned
project, therefore Pacificorp does not have specific knowledge of the inner
workings of the facility's generational output.
Negative amount hours are hours in which there was no generation, however
station service was taken by counterparty in that hour in which generation did
not occur.
Zero amount hours are hours in which there was no generation and no station
The counterparty was not paid by hourly generation but rather a monthly total.
As long as the total kilowatt-hour (kwh) nameplate generation was not
exceeded for a month, the counterparty was paid based on the monthly total.
Note: A facility's generation can exceed a nameplate rating.
(2) There is only one total per month because the monthly data reflected what was
actually booked. This counterparty is not paid by hourly data, but by a
monthly total register read.
(3) As stated in the company's response to subpart (l) above, The company
disagrees with the characteization that the provided data contained
"anomalies". The items that IPUC staff refers to as "anomalies" are not
"anomalies" but rather situations that occur with normal generation
production and metering. The counterparty was paid on a monthly register
read, not hourly data. The accounting system used by PacifiCorp for invoicing
at the time had a requirement to post hourly data when the monthly
calculation was booked. Since the Company did not receive hourly data, the
company was required to take the total read and spread it as evenly as
possible across all the hours of the month so all hours were mostly the same,
with one hour that was used to make up any differences when pacificorp
could not divide the generation evenly among the available hours.
Recordholder:
Sponsor:
Debbie Blake
To Be Determined
PAC-E-20-10 / Rocky Mountain Power
September 15,2020
IPUC Data Request23 - l't Supplemental
IPUC Data Request 23
powerhouse #1 has been offline since 2006. Please answer the following:
(a) When and how did the Company find out that Powerhouse #t was offline?
(b) What does the Company do to ensure that QFs operate normally?
(c) What actions does the Company usually take, when the Company finds out
that QFs do not operate normallY?
(d) Has the Company updated Felt Hydro's contribution at peak in its IRP to
reflect the fact that Powerhouse #1 has been offline since 2006? If so, when
did the Company update it? If not, why not?
Supplemental Request
the following supplemental request was received from the Idaho Public Utilities
Commission (IPUC) staffon September 8,2020:
The Company's response to IPUC 23 subpart (d) states that the Company updates
the qualifuing facility (QF) forecast used in each published Integrated Resource
Plan(RP) to reflect the latest Company available information. How is the hydro
QF forecast updated in each IRP? IPUC staffwould like to understand the amount
of capacity from QF projects included in the Company's load and resource
balance [potential telephone conference with representatives of the IRP group].
l't Supplemental Response to IPUC Data Request 23
When updating the modeling inputs in an Integrated Resource Plan (IRP), the
Company pulls the latest monthly small qualifring facility (QF) hydro forecast
fromthe Company's ENDUR system of record. That monthly data is used to
update the IRP models. Please refer to the Company's original and l't
Supplemental responses to IPUC Data Request 19. Referencing PacifiCorp's 2019
mp, votume I, chapter 8 (Modeling Results), the QF is reported in the capacity
load and resource balance in Table 8.19 through Table 8.22, andpages 259
through 262.PacifrCorp's 20l9IRP is publicly available and can be accessed by
utilizing the following website link:
https : //www.pacifi corp. com/enerelr/intesrated-resource-plan. html
Recordholder:
Sponsor:
Dan Swan
To Be Determined