20210129PAC to Staff 17-25.pdf

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1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
January 29, 2021 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C)
RE: ID PAC-E-20-14 IPUC 2nd Set Data Request (17-25) Please find enclosed Rocky Mountain Power’s 1st Revised Response to IPUC Data Request 21. If you have any questions, please feel free to call me at [phone].
Sincerely, ____/s/____ J. Ted Weston Manager, Regulation Enclosures

RECEIVED
2021January 29, PM 4:36
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-20-14 / Rocky Mountain Power January 29, 2021 IPUC Data Request 21 – 1st Revised
IPUC Data Request 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? 1st Revised Response to IPUC Data Request 21 In reviewing the Company’s response to IPUC Data Request 21 dated January 27,
2021, the Company became aware that the concluding sentence of subpart (a) was
incomplete. The Company provides this 1st Revised response which, replaces in its entirety, the Company’s original response. The Company has marked the incomplete sentence in strikeout and marked the completed sentence the in gray
highlight.
(a) Qualifying facilities (QF) in external balancing authority areas (BAA) are responsible for all charges associated with the transmission service up until the point where output is delivered to the Company, as the Company is not obligated to take QF power unless it is delivered to its system. Most BAAs
have various ancillary service requirements for generators, and those same
requirements would apply to a transmission service customers regardless those requirements are Most BAAs have various ancillary service requirements for generators, and those same requirements would apply to a transmission service customer’s generation exports regardless of whether the
power purchase agreement (PPA) for delivery in another BAA is for a QF or not. (b) Transfers between BAAs are primarily fixed hourly schedules. To the extent the QF provides the Company with a fixed hourly schedule of output, the
Company would not need to carry reserves to account for unexpected changes
PAC-E-20-14 / Rocky Mountain Power January 29, 2021 IPUC Data Request 21 – 1st Revised
in the QF’s output across an hour. To provide a fixed hourly schedule, the source BAA would need to make up any intra-hour imbalance, and would likely charge the QF for that service in accordance with its transmission tariff. As a result, the Company would not incur an integration cost in that instance.
Because the published rate is adjusted by the wind or solar integration charge,
as applicable, wind or solar QFs that do not incur integration charges would receive rates that are higher than the published rate by the amount of the integration charge.

(c) The Company’s contracts for off-system resources delineate the obligations of the QF, and a wind or solar QF that receives an avoided cost price without integration charges would be obligated to provide firm hourly schedules at its designated point of delivery to the Company, consistent with standard transmission processes.

(d) No, energy at an intertie may not be a firm hourly schedule. Energy scheduled on non-firm (NF) transmission can be cut by the transmission provider in a variety of circumstances. Energy can also be scheduled in 15-minute
increments and adjusted up until shortly before the operating interval. Finally,
under a pseudo-tie arrangement, a generator can be moved from one BAA to another “electrically”, despite its physical location. With a pseudo-tie, a resource is effectively within the importing BAA, rather than the source BAA. Transmission service on the source BAA would still be necessary, and additional costs or studies would likely be necessary to arrange the pseudo-tie,
but this arrangement can avoid most ancillary service charges from the source
BAA. The ancillary services would instead be provided by the importing BAA, i.e. the Company in this example. As discussed in the Company’s response to subpart (c) above, the Company’s contracts for off-system
resources would ensure output was provided on a firm basis.

Recordholder: Dan MacNeil
Sponsor: To Be Determined