20201113Staff 1-16 to PAC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
l;''J-=l\/rnr'j-,-,;*lYE-lJ
-'--r; lil,',' l3 Pffi 2: ?0
Street Address for Express Mail:
1133I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORIZATION TO UPDATE TIIE WINI)
AND SOLAR INTEGRATION RATE FOR
SMALL POWER GENERATION QUALIFYINGFACILITIES
CASE NO. PAC.E,.aO-I4
FIRST 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, John R. Hammond, Deputy Attorney General, requests that Rocky Mountain Power
provide the following documents and information as soon as possible, but no later than
FRTDAY, DECEMBER 4, 2020.
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.
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
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
, t-1. i..i i .1 ijll. ' ,. ; .' .;'::L i!. '. .1,. r),+',i:iSltii
NOVEMBER 13,2020
)
)
)
)
)
)
)
)
)
I
the person preparing the documents. Please identiff 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 and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide an explanation and the mechanics for the derivation
of the wind integration rate of $1.11 per MWh for wind powered QFs; and the solar integration
rate of $0.85 per MWh for solar powered QFs.
a. Please provide all inputs and assumptions used in these calculations. Please
include the Excel spreadsheet with formulae intact and enabled.
b. Please identi$ the key driver(s) for the difference in the increase in the wind
integration rate (increase of $0.54lMWh; 95oh inqease) and the solar integration
rate (increase of $0.25lMWh; 42Yoinuease).
REQUEST NO. 2: Please provide all workpapers in Excel format with formulae intact
and enabled that was used in the Flexible Reserve Study. Please also include the following:
a. A detailed description of each workpaper and how it was used in the study; and
b. The SO and PaR portfolio/scenario files used in the study. A list of all the
assumptions and inputs included in each portfolio/scenario, and a summary of the
parameters that were changed for each portfolio/scenario analysis performed.
REQUEST NO.3: The Flexible Reserve Study discusses the Regulation Reserve Cost
on pages 107-108. Please respond to the following:
a. For the Wind Reserve Case, what year(s) was the 500 MW of proxy wind
resources added to the portfolio and why this is appropriate;
b. For the Wind Reserve Case, describe how the 5 locations where chosen and why
this is appropriate;
c. For the Wind Reserve Case, provide the proxy wind resource input assumptions
(i.e., capacity factor, capacity factor at peak, etc.) used at each location and why
this is appropriate;
FIRST PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER 2 NOVEMBER 13,2020
d. For the Wind Reserve Case, please explain why the case was evaluated for the
study period2030, how the year 2030 was chosen, and why this is appropriate;
e. For the Solar Reserve Case, what year(s) were the 500 MW of proxy solar
resources added to the portfolio and why this is appropriate;
f. For the Solar Reserve Case, describe how the 3 locations were chosen and why
this is appropriate;
g. For the Solar Reserve Case, provide the proxy solar resource input assumptions
(i.e., capacity factor, capacity factor at peak, etc.) used at each location and why
this is appropriate; and
h. For the Solar Reserve Case, please explain why the case was evaluated for the
study period2030, how the year 2030 was chosen, and why this is appropriate.
REQUEST NO. 4: If not provided in response to Request No. 2, please provide the data
used to estimate the quantile regression model referenced on page 4, line 3 of the Application
and on page 93 of the Flexible Reserve Study. Please provide in Microsoft Excel with formulae
intact and enabled. In addition, please provide the following:
a. Please provide copies of the quantile regression results for model(s) the Company
estimated for its Flexible Reserve Study and identify the Company's preferred
model if more than one model was estimated. Results should include statistics
and diagnostics applicable to quantile regression and coefficient estimates with
associated standard errors, t-statistics, p-values, and confidence intervals;
b. Please explain how regulation reserve requirements are co-optimized in the
quantile regression model; and
c. Please provide descriptions of all variables used in the regression modeling.
REQUEST NO. 5: Paragraph 14 of the Application states that inter-hour system
balancing integration cost was not included in the 2019IRP "based on the minimal impact of the
calculated cost in the study and possible interaction with EIM." Please explain how inter-hour
system balancing integration cost was determined in the 2017 Flexible Reserve Study. In the
explanation, please include the following:
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J NOVEMBER 13, 2O2O
a. What is the significance of gas plants "dispatched in the EIM to meet regional
demand, not just the PacifiCorp demand reflected in the PaR model"; and
b. Why did the Company use "sub-optimal gas plant commitment based on day-
ahead load, wind, and solar forecasts, rather than actuals"?
REQUEST NO. 6: Please provide the inter-hour integration cost impacts for the 2019
IRP. If the cost impacts are not available, please provide an estimated amount and describe the
method used to determine the estimate.
REQUEST NO. 7: Please explain why possible interaction with EIM is a rationale for
not including inter-hour integration costs?
REQUEST NO. 8: Page 101 of the 2019 Flexible Reserve Study states that while
substantial EIM imports do occur in some hours, it is only appropriate to rely on PacifiCorp's
diversity benefit associated with EIM participation as these are derived from the structure of the
EIM rather than resources contributed by other participants. Please define "diversity benefit
associated with EIM participation" and "resources contributed by the other participants" and
explain the difference between the two.
REQUEST NO. 9: Please provide a description of each portfolio in each case listed in
Table F.10 on page 107 of the Flexible Reserve Study. Please describe each portfolio, how it
was determined, its source (example: 2019 IRP preferred portfolio), and why the portfolio was
appropriate for each case.
REQUEST NO. 10: Please explain the purpose of the 50 MW Reserve Case on Page
108, how the escalation of wind and solar results was conducted, and why an additional 50 MW
reserve requirement was included in every hour from 2018 through2036.
REQUEST NO. 11: Page 102 of the 2019 Flexible Reserve Study states that the
Company has applied the historical distribution of EIM diversity benefits from March 2018
through the beginning of this study in July 2018, and relatively small incremental EIM diversity
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER NOVEMBER 13, 2O2O4
benefits are expected going forward as additional entities participate in the EIM, but operational
data on new participants were not available at the time the study was prepared. Does the study
assume EIM diversity benefits are constant throughout the study period? If so, what are the
assumed values? If not, how do they vary?
REQUEST NO. 12: Page 1 of the Application states that the integration charges will be
applied against published avoided cost rates except in those circumstances where the QF
developer specifies in the PPA to deliver the QF output to Rocky Mountain Power on a firm
hourly schedule. Please explain how the Company plans to hold a QF accountable for "a flrm
hourly schedule".
REQUEST NO. 13: The Application proposes one charge for wind and one charge for
solar in 2018 dollars to be used in the SAR model throughout the life of a QF contract. Please
explain why the Company does not consider inflation in the cost of integrating wind and solar
over a 20-year contract term.
REQUEST NO. 14: Please explain why the Company does not consider different
penetration levels of wind and solar to determine integration charges in PURPA contract rates.
REQUEST NO. 15: If the cost of integrating PURPA wind and solar increases due to
inflation and increasing levels of solar and wind penetration, please provide rate schedules out to
year 2045 to account for inflation and to account for different penetration levels. Please provide
workpapers with formula intact in the Company's derivation.
REQUEST NO. 16: The Application states that the integration charges will be applied
to wind and solar under published avoided cost rates. Does the Company plan to apply these
integration charges for determining PURPA rates in the Integrated Resource Planning (IRP)
method? Please explain.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER NOVEMBER 13, 2O2O5
DATED at Boise, Idaho, tnrs / faayof Novemb er 2020
Jr.
Attorney General
i:umisc:prodreq/pace20.l4jhme prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOI-JNTAIN POWER 6 NOVEMBER 13, 2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF NOVEMBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-2O-14, By E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CMY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
dat areque st @ pacific orp.com
SECRETAR
CERTIFICATE OF SERVICE