20201106PAC to Staff 1-13.pdf

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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, lD 83702-5918
ian.norivuki@&uc. idaho. gov (C)
RE: ID PAC-E-20-13
IPUC I't Set Data Request (l-13)
Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests l-13. Also
provided are Attachments IPUC 6 and 10. Provided on the enclosed CD is Confidential
Attachment IPUC l. Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233,the Idaho Public Utilities Commission's Rules of Procedure No.
67 - Information Exempt from Public Review, and further subject to any subsequent Non-
Disclosure Agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
--!sl-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC DataRequest I
IPUC Data Request I
Please provide the summer peak hours and the winter peak hours important for
establishing the capacity deficiency date. Please explain how they are identified.
Response to IPUC Data Request I
A summary of the months and hours in which loss of load events (LOLE) are
expected to be most likely to occur is shown in the table below. This data comes
from the Final Capacity Contribution analysis discussed in PacifiCorp's 2019
Integrated Resource Plan (IRP), Volume II, Appendix N (Capacity Contribution
Study). The dishibution of LOLE was calculated using a 2030 study period and a
resource portfolio that was very similar to the 2019 IRP preferred portfolio. 500
stochastic variations of load, hydro, and thermal outages were modeled, and the
frequency of LOLE in each hour across those 500 studies was calculated.
In the 2019 IRP analysis, LOLE were most common in the evenings in July and
August. A smaller concenfration of LOLE occurred in January and December,
with events both in the moming and in the evening. Approximately 92 percent of
the LOLE in the analysis occurred in the months of June through September.
Hour(PPT)10 11 t2 13 L4 15 16 tT rA 19 zzB
For additional details, please refer to Confidential Attachment IPUC I which
provides a copy of file "P45CNW Contributions-20l9 l0 07 FINAL CONF.xlsx"
from the confidential data disks accompanying PacifiCorp's 20l9IRP, with
added calculations supporting the figure above.
PacifiCorp' s 2019IRP is publicly available and can be accessed by utilizing the
following website link:
https : //www. paci fi corp. com/enerey/inte grated-re source-plan. htm I
Confidential information is provided subject to protection under IDAPA
31.01.01 .067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
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PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request I
Procedure No. 67 - Information Exempt from Public Review, and further subject
to any subsequentNon-Disclosure Agreement (NDA) executed in this pro6.ding.
Recordholder: Dan MacNeil
Sponsor: Dan MacNeil
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC DataRequest 2
IPUC Data Request 2
please explain how QF's capacrty confiibution at peak is determined. Do all QF
technologies use the same method? If not, please describe the method for each
QF technology tYPe.
Response to IPUC Data Request 2
The final capacity contribution values in PacifiCorp's 2019 lntegrated Resource
plan (IRp), ionsistent with the 2019 IRP preferred portfolio, are calculated using
the capacity factor approximation methodology (CF method), as discussed in the
2019 iRp, Volume II, AppendixN (Capacity Contribution Study).
The cF method compares a resource's hourly availability to the hourly
distribution of loss oi load events (LOLE) such as that represented in the table
provided in the Company's response IPUC Data Request l'
Under the CF method, a resource which is 50 percent available during 100 percent
of the LOLE receives a 50 percent capacity contribution. A resource which is 100
percent available during 50 percent of the LOLE also receives a 50 percent
capacity contribution. For the purposes of the 2019 IRP, each resource's hourly
capacity factor (over the 8760 hours in 2030) is multiplied by distribution of
LOLE u.rost the 8760 hours in 2030, weighted such that the total sums to 100
percent. This methodology was applied to all resource types in the 2019IRP and
is applicable to all qualiffing facility (QF) types. The method js the same for
,.rou.."t with limiied energy duration that are controlled by the Company, such
as batteries, but the calculation is somewhat more complicated because the battery
storage duration is compared with the duration of LOLE in each iteration, rather
than igainst the average across all iterations. For example, abafiery with four-
hour duration is availible for 100 percent of a two hour LOLE, but only 80
percent of a five-hour LOLE.
For an example of the calculation of capacity contribution in the 2019 IRP for
wind and solar resources, please refer to the Company's response to IPUC Data
Request 1, specifically Confidential Attachment IPUC l, tab "Renewable", rows
t aidZ.The capacity contribution values for all resources in the 2019IRP are
shown on tab "Results".
pacifiCorp's20L9IRP is publicly available and can be accessed by utilizing the
following website link:
Recordholder: Dan MacNeil
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request 2
Sponsor:Dan MacNeil
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC DataRequest 3
IPUC Data Rquest 3
Please describe how PURPA contacts are represented in the load and resource
balance regarding contact renewals. Does the Company treat different types of
QF technologies or contracts differently? Please provide the Company's rationale
justiffing its answer.
Response to IPUC Data Request 3
The Company's 20lg lntegrated Resource Plan (IRP) assumes that Public Utility
Regulatory Policies Act (PURPA) power purchase agreements (PPA) expire at the
end of their current contract term. Note: the only exception is for cogeneration
facilities whose output is tied to load that is also included in the forecast. Because
the load is continuing to be modeled, the qualifying facility (QF) output
associated with those continuing operations is also modeled.
PURPA resources are not obligated to continue selling capactty and energy to the
Company beyond the end of their contract terms. At the end of a the contract
term,a PURPA resource may be decommissioned, output may be wheeled and
sold to another utility, or output may be used to offset onsite retail load, for
instance as part of a partial requirements tariff. By assuming PURPA PPAs end at
the conclusion of their committed term, the IRP is identiffing a preferred
portfolio that includes the most cost-effective resources that would be needed in
ihe absence of any additional PURPA commitments. The costs and characteristics
of the most cost-effective future resources can also inform the calculation of
avoided costs.
PacifiCorp's 2019 IRP is publicly available and can be accessed by utilizing the
following website link:
https ://www.pacifi corp. com/enersy/intesrated-re source-plan. htm I
Recordholder:
Sponsor:
Dan MacNeil
Dan MacNeil
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC DataRequest 4
IPUC Data Request 4
Please describe how non-PURPA conftacts 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 justifiing
its answer.
Response to IPUC Data Request 4
Pacificorp generally does not assume non qualifring facility (eF) power
purchase agreements (PPA) will be renewed unless it has the option to extend the
term under defined terms and conditions under the existing agreement. The one
exception is for intemrptible load contacts of short duration that have a history of
renewing. Because the load associated with these contracts continues to be
modeled, the intemrptible capability also continues to be modeled.
For details on the annual amounts of retiring and expiring resources, please refer
to Pacificorp's 2019Integrated Resource Plan (IRp), volume t, table g.lg
@acifiCorp' s 2019 IRP Prefened Portfolio).
PacifiCorp's 2019 IRP is publicly available and can be accessed by utilizing the
following website link:
https ://www.pacifi com. com/enersv/inte grated-resource-plan. html
Recordholder:
Sponsor:
Dan MacNeil
Dan MacNeil
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC DataRequest 5
IPUC Data Request 5
Page 4 ofthe 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.
Response to IPUC Data Request 5
The four qualifying facilities (QF) listed below requested termination of their
power purchase agreement (PPA) due to development issues and PacifiCorp
agreed to the termination. Under the Public Utility Regulatory Policies Act
(PURPA), the QF can request another QF PPA for the same project, however, it
would be at the then current avoided cost rates and subject to any state or federal
regulatory rules and orders.
. Merrill Solar LLC
o OR Solar 5, LLC
o Mariah Windo Orem Family Wind
Recordholder: Bruce Griswold
Sponsor:Bruce Griswold
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request 6
IPUC Data Request 6
Do Tables 2 and3 in the Application reflect the latest contact 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.
Response to IPUC Data Request 6
Since the filing, PacifiCorp has identified some slight modifications the contract
information pertaining to the summer peak. This does not impact the summer
deficiency year, which remains 2028 with the assumed early toal retirements, and
2029 without the early coal retirements. Please refer to Attachment IPUC 6 for
details.
Recordholder:
Sponsor:
Dan MacNeil
Dan MacNeil
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC DataRequest 7
IPUC Data Request 7
Please provide tables with updated contract information as of the date of the
Application, similar to Tables 2 and3 in the Application for winter peak.
Response to IPUC Data Request 7
Please refer to the Company's response to IPUC Data Request 6, specifically
Attachment IPUC 6, tab "Tbl 5.13". Note: the winter deficiency year is2029
witlr the assumed early coal retirements, and2037 without the early coal
retirements identified in PacifiCorp's 20lg Integrated Resource Plan (IRP). Note:
several coal units would likely have faced end-of-life retirements prior to 2037 if
the early retirements identified in the 2019 IRP preferred portfolio did not
expected to occur, which could bring the winter deficiency year forward.
PacifiCorp's 2019 IRP is publicly available and can be accessed by utilizing the
following website link:
html
Recordholder:
Sponsor:
Dan MacNeil
Dan MacNeil
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request 8
IPUC Data Request 8
Page 97 of the 2019 IRP states that for capacity expansion planning, pacificorp
uryl a l3 percent target planning reserve margin (PRM) applied to the Company,s
obligation, which is calculated as projected load less privati generation, less
energy efficiency savings, and less intemrptible load- However, planning
reserves in System East are not l3%o of East obligation, whereas it*"irg reserves
in System west are 13% of west obligation for both suillmer peak and *int .peak. Please explain the inconsistency and whether planning i"rerv". in System
East are correct.
Response to IPUC Data Request 8
The planning reserves calculation for System East are correct. The intemrptible
load on ttre East are removed from the East obligation in calculating the pianning
reserves in recognition these contracts do not carry the 13 percent planning
reserve margin (PRM).
PacifiCorp's 2019 IRP is publicly available and can be accessed by utilizing the
following website link:
https ://www. pacifi corp. com/enersv/intesrated-re source-olan. htm I
Recordholder: Dan Swan
Sponsor: Dan Swan
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request 9
IPUC Data Request 9
page 105 of the 2019IRP states that Class 1 DSM @emand Response) program
"*i.pl", include residential and small commercial central air conditioner load
control programs, irrigation load management, and intemrptible or clrtailment
progru1nr. -During th-. ,r*., peak, please explain why class 1 DSM's value of
System West is o'3" in 2020 but o'0" afterwards.
Response to IPUC Data Request 9
The 3 megawatts (MW) of demand response in the West represents the Oregon
test pilot irrigation program which ends after 2020'
pacifiCorp's 2019 IRP is publicly available and can be accessed by utilizing the
following website link:
Recordholder:
Sponsor:
Brian Osborn
Brian Osborn
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC DataRequest 10
IPUC Data Request 10
When was the load forecast used in the2Olg IRP 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.
Response to IPUC Data Request 10
The load forecast used in Pacificorp's 20lg lntegrated Resource Plan (IRP) was
created in September 2018. Generally, PacifiCorp's load forecast is updated once
per year.
Please refer to Attachment IPUC l0 which provides the most recent load forecast
completed in June 2020.
In the early years of the forecast, a lower load forecast is driven by adverse
economic impacts resulting from the COVID-I9 pandemic. A higher forecast in
the later years is driven by projected residential demand, transportation
electification and commercial customer demand from data centers.
PacifiCorp's 2019 IRP is publicly available and can be accessed by utilizing the
following website link:
https ://www. pacifi com.com/enerev/intesrated-resou rce-plan. htm I
Recordholder:
Sponsor:
Lee Elder
Lee Elder
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC DataRequest I I
IPUC Data Request 11
Table 5.11 on Page 107 of the 2019 IRP describes existing DSM resources. Table
5.12 onpage I l5 and Table 5.13 on page I 17 show sunmer 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 @nergy 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 "included 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.I2 andTable 5.13 still include them as existing resources.
Please reconcile and explain the two treatments.
Response to IPUC Data Request 11
Referencing PacifiCorp's 2019 Integrated Resource Plan (IRP), the Company
responds as follows:
(a) As footnote 2 states, "Due to the timing of the 2019IRP load forecast, there is
a small amount (81 MW) of existing Class 2 DSM in Table 5.14 (System
Capacity Loads and Resources without Resource Additions)". Note: the
reference to Table 5.14 should have been referring to Table 5.12 and Table
5.13. The 8l megawatts (MW) of existing Class 2 demand-side management
(DSIO is to account for the 2018 Class 2 DSM that was not included in the
2019 IRP load forecast (dated September 26,2018).
(b) As footnote I for Table 5.12 andTable 5.13 explains, "The Energy Efficiency
line includes selected Energy Efficiency from the 2019IRP preferred
portfolio".
PacifiCorp's 2019 IRP is publicly available and can be accessed by utilizing the
following website link:
https ://www. pac i fi corp. com/enerev/inteerated-resource-p lan.htm I
Recordholder:
Sponsor:
Brian Osborn
Brian Osborn
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request 12
IPUC Data Request 12
Page 107 of the 2019IRP states that customer-sited Private Generation includes
solar PV, small-scale wind, small-scale hydro, and combined heat and power for
reciprocating engines and micro-turbines. Please answer the following questions
(a) what is the relationship between Private Generation and the company,s net
metering program?
(b) WhV is the Private Generation forecast included in Table 5.12 andTable 5.13
that focus on load and resources without resource additions?
(c) Which scenario do the values of Private Generation in Table 5.12 and,Table
5.13 come from (i.e. base case scenario, Iow scenario, or high scenario)?
Response to IPUC Data Request 12
(a) Private Generation (PG) is a definition that broadly describes generating
facilities primarily used to offset the load of the owner of the facility at the
host site. The company's net energy metering (NEIO program is a set of rules
which define the economic relationship and the technical requirements for
customers that install PG that operates in parallel with the utitity system.
Thus, the company's NEM program is a tariffthat is offered to a subset of pG
facilities that meet the rules of the NEM program.
(b) PG is embedded as a reduction to the load forecast, but is separated out for
reporting in the capacity load and resource balance. pG is acquired by
customers of PacifiCorP, and is therefore considered a load reduction and not
a PacifiCorp resource addition. The load forecast would be inaccurate .. and
resource additions misaligned with capacity needs -- if pG were not
incorporated in this way.
(c) The PG forecast is included in the base case forecast in pacificorp,s 2019
lntegrated Resource Plan (IRP), specifically Table 5.r2 andrable 5.13.
PacifiCorp's 2019IRP is publicly available and can be accessed by utilizing the
following website link:
https ://www.pacifi corp. com/energy/inte grated-resource-plan. htm I
Recordholder:Dan Swan /Erik Anderson
Sponsor:Dan Swan / Erik Anderson
PAC-E-20-13 / Rocky Mountain Power
November 6,2020
IPUC Data Request l3
IPUC Data Request 13
Table 5.L2 andTable 5.13 include two items: "available front office transactions"
and ..uncommitted FOT's to meet remaining need." Please provide the definitions
of the two terms and describe the difference between the two as they relate to
their capability to confribute to capacity.
Response to IPUC Data Request 13
Front office transaction @OTs) are a representation of an o'open" capacity
position that is assumed to be met with uncommitted market purchases.
iAvailable front office transactions" refers to the amount of FOTs that is an input
assumption representing the maximum level of an open capacrty position
represinted as an FOT. Importantly, the "available front office transactions" does
not represent an economic selection of FOTs in a least-cost resource portfolio.
The term "uncommitted FOTs to meet remaining need" refers to the amount of
FOTs, up to the 'oavailable front office transactions" that could be used to meet a
"upucity
d.ficit in the initial load-and-resource balance (i.e., before new resources
are identified). As is the case with "available front offtce tansactions" the
,,uncommitted FOTs to meet remaining need" do not represent an economic
selection of FOTs in a least-cost resource portfolio'
pacifiCorp's 2019 IRP is publicly available and can be accessed by utilizing the
following website link:
Recordholder:
Sponsor:
Dan Swan
Dan Swan