20201106PAC to Staff 14-17.pdf

Y ROCKY MOUNTAIN
POWER
A DMSION OF PACIFICORP
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'1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
November 6,2020
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.noriyuki@nuc. idaho. gov (C)
RE: ID PAC-E-20-13
IPUC 2nd Set DataRequest (14-17)
Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests 14-17
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request 14
IPUC Data Request 14
Tab: "Tbl 5.12" of the Excel file named "PAC-E-20-13 RMP Workpapers
CONFIDENTLAL 10-6-20" submitted electronically with the Application
includes an item "Adjustment for Derates" for all the coal plant early shutdowns.
Please describe the purpose of this adjustment relative to establishing the capacrty
deficiency date and explain how it is determined. In addition, please answer if all
coal plants included in the Load and Resource Balance are adjusted for derates.
Response to IPUC Data Request 14
A resource with a forced outage rate of 20 percent will be less likely to be
available during peak conditions than a resource with a forced outage rate of l0
percent. Therefore, the capacity values shown in Table 5.12 in PacifiCorp's 2019
Integrated Resource Plan (IRP), and replicated in the Application in this
proceeding, are reporting not nameplate capacity, but rather the resource
availability after accounting for forced outages. This is sometimes referred to as
"pure capacity". In Table 5.l2in the 2019 IRP, the pure capacity of east thermal
resources in202l is listed as 5,634 megawatts MW). The nameplate capacity of
the associated resources is 5,993 MW, and is not shown in the table. All coal
plants in the load and resource balance are adjusted for derates.
Referencing confidential work paper "PAC-E-20-I3 RMP Workpapers
CONFIDENTLAL 10-6-20", tab "Tbl 5.12" is calculating how coal retirements
would impact the pure capacity balance reported in the load and resource balance
The coal plant capacity values listed are the Company's share of plant nameplate
and a separate adjustment is necessary to account for the risk of forced outages at
these units. The forced outage adjustment for each unit reflects the assumptions
used in the 2019IRP and underlying the aggregate values reported in Table 5.12
of the 2019 IRP. An aggregate derate for forced outages was listed because the
unit-specific values were considered confidential.
Recordholder:
Sponsor:
Dan MacNeil
To Be Determined
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request 15
IPUC Data Request 15
Tab: "Tbl 5.12" ofthe Excel file named "PAC-E-20-13 RMP Workpapers
CONFIDENTIAL 10-6-20" submitted electronically with the Application shows
that the Company has removed early coal plant retirements (see rows 72 through
79), which were originally included in rows 7 and29. Please explain the
discrepancy in the amount of capacity that was originally included in rows 7 andg
and the amounts that were removed (see rows 72 through 79). If accurate, please
explain why the Company believes the amounts backed out of existing resources
are appropriate. For example, the change in the amount of thermal capacity from
year 2023 to 2024 for both East (row 7) nd West (row 29) regions in total is
equal to 312 MW; however, the amount deducted in year 2024 (rowsT2through
79) was 351 MW. Similarly, the change in the amount of thermal capacity from
year 2025 to 2026 for both East (row 7) and West (row 29) regions in total is
equal to 416 MW; however, the amount deducted in year 2026 (rows T2through
79) was 439 MW.
Response to IPUC Data Request 15
Please refer to the Company's response to IPUC Data Request 14 for a discussion
of the adjustnent for forced outages in the load and resource balance. The
Company treated the unit-specific forced outage rates as confidential and did not
show any derates until the adjusted deficiency year occurred in 2029. As
discussed above, the derated capacity associated with Jim Bridger Unit I can be
inferred as 312 megawatt (MW) by the change from the prior year, so it appears
this particular value cannot be considered confidential. The actual increase in
capacity in2024 would be slightly smaller than what is shown as a result, but this
would not impact the adjusted deficiency year of 2029, when the cumulative
impact of derates is incorporated. In 2026,the aggregate nameplate capacity of
Craig Unit l, Naughton Unit 1, and Naughton Unit 2 is 439 MW, while the
aggregate derated capacity of those units is 416 MW.
Recordholder:
Sponsor:
Dan MacNeil
To Be Determined
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request l6
IPUC Data Request 16
Please explain why the Company has included ooSales" in the Load and Resource
Balance for determining the capacity deficiency date for avoided cost rates.
Response to IPUC Data Request 16
The Company includes executed wholesale sales obligations (long-term firm
(LTF) contracts for capacity and energy), as part of its load and resource balance.
The Company must plan for and meet these confractual obligations through the
contract term. For example, the appreciable drop in east sales in the load and
resource balance from2020to202l reflects the expiration of the ArizonaPublic
Service Company (APS) exchange agreement. The sales category in the capacity
load and resource balance does not include balancing transactions that could be
entered based on economics at a future point in time.
Recordholder:
Sponsor:
Dan MacNeil
To Be Determined
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request 17
IPUC Data Request 17
Please explain why the Company has included'Non-owned Reserves" in the load
and resource balance for determining the capaclty deficiency date for avoided cost
rates.
Response to IPUC Data Request 17
The Company is obligated to provide ancillary services to transmission customers
with loads and resource in PacifiCorp's balancing authority areas @AA). For
example, PacifiCorp's Open Access Transmission Tariff (OATT) has rates
approved by the Federal Energy Regulatory Commission (FERC) for Schedule 5
(Operating Reserve - Spinning Reserve Service) and Schedule 6 (Operating
Reserve - Supplemental Reserve Service). The'Tllon-owned Reserves" modeled
in PacifiCorp's 2019Integrated Resource Plan (RP) represent reserve obligations
consistent with historical requirements, as the Company expects that it will
continue to be obligated to provide these ancillary services in the future.
Recordholder:
Sponsor:
Dan MacNeil
To Be Determined