20210106Staff 17-25 to PAC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-O3s7
IDAHO BAR NO. 5470
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORIZATION TO UPDATE THE WINDAND SOLAR INTEGRATION RATE FOR
SMALL POWER GENERATION QUALIFYINGFACILITIES
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Street Address for Express Mail:
I133I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. PAC.E.aO.IA
SECOND 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, Jr., Deputy Attorney General, requests that Rocky Mountain power
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, JANUARY 27, 2021.
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
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JANUARY 6,2021I
the person preparing the documents. Please identify 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. 17: Tab "wind 2030" of File "App F-Flex Study paR results,,
submitted by the Company in Response to Staff s Production Request No. 2 includes generation
data of the incremental, 500 MW wind energy and its associated reserve amount. Please answer
the following questions.
a. The annual 500 MW wind generation amount in Row 54 is calculated as
((100x0.413)+(100x0.38)+(100x0.31)+(10ex0.38)+(100*0.:8y;x9.37. please
verify that the amounts 0.413,0.38, 0.31,0.38, and 0.38 are the annual capacity
factors of the five wind farms. What does 8.87 represent and how was it
determined?
b. Are the costs associated with the incremental, 500-MW wind energy reflected in
the Wind 500 NtW Reserves Case (I19-FxWD500-MM_Det)? If not, does this
case only consider costs of reserye resources?
c. Row 74 reflects the cost difference between the scenarios with and without
incremental wind. Please explain why all the cost difference between the two
scenarios (e.g., Change in NPC, Change in Emissions, and Change in VOM)
should be categorized as reserve costs and be used for calculating wind
integration charges.
REQUEST No. L8: Tab "Solar 2030" of File "App F-Flex Study paR results,,
submitted by the Company in Response to Staff s Production Request No. 2 includes generation
data for the incremental, 500-MW solar energy and its associated reserye amount. The
associated annual reserve amount for the 500-MW solar plants is 2I4 GWh, which is equivalent
to 24.4 aMW. Please explain why the escalator percentages determined based on 50 MW in
Row 77 in Tab "50 MW Reserve" can be applied to escalate the reserve cost of theZ4.4 aMW
reserve in Row 78 in Tab "Solar 2030".
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JANUARY 6,20212
REQUEST NO. 19: In reference to the File "App F-Flex Study PaR results" submitted
by the Company in Response to Staff s Production Request No. 2. please response to the
following:
a. The base scenario on Tab "50 MW Reserve" (I19_FxBase_MM_Det) is different
than the base scenario used in Tabs "wind 2030" and ..Solar 2030,,
(I19-FxBasehr-MM-Det). The difference between the two base scenarios in
Total Mean System Cost is one million dollars. Why do the three cases not use
the same base scenario?
b. Please provide the SO and PaR portfolio files including the resources in each
portfolio and the cost for each year for the following portfolios: (1)
I 1 9-FxB ase-MM-Det; (2) I 1 9-Fx50Res-MM_Det; (3) I 1 9_FxB asehr_MM_Det;
(4) I19_FxWD500_MM_Det; and (5) I19_FxSR500_MM Det.
REQUEST No.20: please describe the purpose of rab .,sccr study,', Tab ,.Bat
study", and rab "sccr Bat" in the File "App F-Flex Study paR results,, submitted by the
Company in Response to Staff s Production Request No. 2. How are they used in determining
the integration charges?
REQUEST NO.21: Response to Staff s Production Request No. 12 describes a
situation where a QF is in another balancing authority area ("BAA") and chooses to wheel its
generation to the Company. The Company states that the QF will be subject to charges for
ancillary services from its source BAA that would include the Company's integration cost and
that the Company would receive firm output at an intertie with the source BAA consistent with
the QF's transmission schedules. Please answer the following questions.
a. Why will the QF be subject to charges for ancillary services from its source
BAA?
b. why would the charge include the company's integration cost?
c. Who decides whether the charge should include the Company's integration cost?
d. Is energy received at an intertie always firm? If not, why does the Company
believe the output received would be firm?
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JANUARY 6,20213
REQUEST NO.22: Response to Staff's Production Request No. 16 states that
integration charges for IRP-based contracts will be portfolio specific and will be embedded
within the overall results. Please answer the following questions and provide explanations.
a. Please explain how the integration charges for IRP-based contracts are embedded
in the overall results.
b. Are the integration charges included as part of the avoided cost of energy or
avoided cost of capacity or both? Please explain if and how the avoided costs
would reflect the integration charges.
c. How does the Company build a portfolio to be used under the IRP-based method?
Is it the preferred portfolio from the latest acknowledged IRP? If not, please
explain which portfolio is used and how the resources are determined for
inclusion.
REQUEST NO.23: In reference to Figure F.15 on page 109 of the Flexible Reserve
Study, please explain why the regulation reserve cost for wind and solar are decreasing the first
three years when the Company has: (1) a large amount of renewable resources coming on to the
system during this time frame; (2) coal unit retirements and continued load growth during this
time frame; and (3) limited amounts of new dispatchable resources coming on to the system
during this time frame. Please provide any evidence available to support the explanation.
REQUEST NO.24: In reference to Table F.10 on page 107 of the Flexible Reserve
Study. Please respond to the following:
a. Why is the wind capacity (3,l96lvfD for the 2019 Forecast Case lower than the
existing wind resources capacity (3,908 MW) found on page 99 of PacifiCorp's
2019 IRP, Volume I? Please provide a list of wind resources with individual
capacity amounts included in the 2019 Forecast Case wind capacity column.
b. Why is the solar capacity (2,201MW) for the2OIg Forecast Case higher than the
existing solar resources capacity (1,759 MW) found on page 101 of PacifiCorp's
2019 IRP, Volume I? Please provide a list of solar resources with individual
capacity amounts included in the 2019 Forecast Case solar capacity column.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JANUARY 6,20214
c. Please provide a list of the wind and solar resources with individual capacity
amounts that make up the wind and solar capacity columns for the 2019 Base
Case.
REQUEST NO. 25: Please provide the work papers in Excel format with formulae
intact and enabled used to create Tables F .7 , F .g , and F. 10 of the Flexible Reserve Study.
DATED at Boise,Idaho, this (f{^rof January zozt.
Hammond, Jr.
Attorney General
i:umisc:prodreq/pace20.l4jhme prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JANUARY 6,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY oF JANUARY 2021, SERVEDTHE FOREGOING SECOND PRODUCTION REQUEST OF TIIE COMMISSIONsrAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-20-14, By E-MAILINGA COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston @pacificom.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: emily.wegener@pacificor?.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest @ pacificorp.com
Y
CERTIFICATE OF SERVICE