20201021Staff 1-13 to PAC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
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Street Address for Express Mail:
I 133I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR APPROVAL
OF A CAPACITY DEFICIENCY PERIOD TO BE
USED FOR AVOIDED COST CALCULATIONS
CASE NO. PAC.E.2O.13
F'IRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Matt Hunter, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than MONDAY'
NOVEMBER 9, 2020.r
This Production Request 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.
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney
at (208) 334-03 I 8.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I ocroBER 21,2020
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please identiS the name, job title, location, and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide the summer peak hours and the winter peak hours
important for establishing the capacity deficiency date. Please explain how they are identified
REQUEST NO. 2: Please explain how QF's capacity contribution at peak is
determined. Do all QF technologies use the same method? If not, please describe the method
for each QF technology type.
REQUEST NO.3: Please describe how PURPA contracts are represented in the load
and resource balance regarding contract renewals. Does the Company treat different types of QF
technologies or contracts differently? Please provide the Company's rationale justiffing its
answer
REQUEST NO. 4: Please describe how non-PURPA contracts are represented in the
load and resource balance regarding contract renewals. Does the Company treat different types
of contracts differently? Please provide the Company's rationale justifuing its answer.
REQUEST NO. 5: Page 4 of the Application states that four QF power purchase
agreements located in Oregon were terminated, with a nameplate capacity of 38 megawatts
Please explain the circumstances for their termination and whether they are assumed to be
permanently terminated.
REQUEST NO. 6: Do Tables 2 and 3 in the Application reflect the latest contract
information (both PURPA contracts and non-PURPA contracts) for summer peak as of the date
of the Application? If not, please provide updates to the tables as of the Application date.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER ocToBER 21,20202
REQUEST NO. 7: Please provide tables with updated contract information as of the
date of the Application, similar to Tables 2 and 3 in the Application for winter peak.
REQUEST NO. 8: Page 97 of the 2019 IRP states that for capacity expansion planning,
PacifiCorp uses a 13 percent target planning reserve margin (PRM) applied to the Company's
obligation, which is calculated as projected load less private generation, less energy efficiency
savings, and less intenuptible load. However, planning reserves in System East are not l3Yo of
East obligation, whereas planning reserves in System West are 13% of West obligation for both
summer peak and winter peak. Please explain the inconsistency and whether planning reserves
in System East are correct.
RB,QUEST NO. 9: Page 105 of the 2019 IRP states that Class I DSM (Demand
Response) program examples include residential and small commercial central air conditioner
load control programs, irrigation load management, and intemrptible or curtailment programs.
During the summer peak, please explain why Class I DSM's value of System West is "3" in
2020but "0" afterwards.
REQUEST NO. 10: When was the load forecast used in the 20l9IRP created? How
often is PacifiCorp's load forecast updated? Please provide the most recent load forecasts for
both winter peak and summer peak, if available, and describe causes in differences between the
most recent load forecasts and the 2019 IRP load forecasts.
REQUEST NO. 11: Table 5.11 on Page 107 of the 2019 IRP describes existing DSM
resources. Table 5.12 on page 115 and Table 5.13 on page I l7 show summer peak and winter
peak's capacity loads and resources without resource additions. Please answer the following
questions:
a. Table 5.11 shows 0 MW Class 2 DSM (Energy Efficiency), but the footnote states
that there is 8l MW of existing Class 2 DSM. What is the current capacity of
existing Class 2 DSM?
b. Table 5.1I states that Class 2 DSM is not'oincluded as existing resources for 2019-
2038 period," because they are "modeled as resource options in the portfolio
development process and included in the preferred portfolio." However, Table 5.12
FIRST PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER ocroBER 21,20203
and'lable 5.13 still include thcm as existing resources. Flease reconcile and explain
the trvo treatments.
REQUEST NO. 12: Page 107 of the 2019 IRP states that customer-sited Private
Generation includes solar PV, small-scale rvind. srnall-scale h-vdro. and combined heat and
pot\€r fbr reciprocating engines and micro-turbines. Please ans\\rer the follorving questions:
a. What is the relationship betrveen Private Cieneration and the Compan-v's net metering
program'?
b. Why is the Private Generation forecast included in Table 5. 1 2 and l'able 5 ' I 3 that
focus on load and resources rvithout resource additions?
c. Which scenario do the values of Private Generation in I'able 5.12 and'fable 5.13
corne front (i.e. base case scenario, lou'scenario, or high scenario)?
REeUEST NO. 13: Table 5.12 and Table 5.13 include tu,o items: "available front
office transactions" and "uncofirmitted IrO f 's to meet remair-ring need." Please provide the
def'rnitions of the trvo terms ancl describe the diff'erence betrveen the tr.vo as they relate to their
capability to contribute to capacity.
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DATED at Boise. Idaho, this ) l*du>' of October 2020
N,Iatt I{unter
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FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER ocToBER 21.20204
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF OCTOBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E.20.13, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
EMILY WEGENER
ROCKY MOLTNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@pasificorp. com
emil)''we gener@Pacificom' com
RON SCHEIRER
PACIFICORP
825 NE MULTNOMAH STE 600
PORTLAND OR 97232
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@f acifi corp.com
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CERTIFICATE OF SERVICE