20210329PAC to Staff 1-6.pdf

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1407 W Noilh Temple, Suite 330
Salt Lake City, Utah E4116
I\darch 29,2021
JanNoriyuki
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
i an.norivuki@nuc. idaho. eov (C)
RE: ID PAC-E-21-05
IPUC Set I (1{)
Please find enclosed Rocky Mountain Power's Responses to IPUC ls Set Data Requests l-6.
If you have any questions, please feel fr,ee to call me at (801)220A9$.
Sincerely,
-Jsl-J. Ted Weston
lvlanager, Regulation
Enclosures
PAC-E-21-05 / Rocky Mountain Power
March 29,2021
IPUC Data Request I
IPUC Data Request I
The original contact expired on March 1,2021, and the Application in PAC-E-
2l-05 was filed on March 3,2021 Please explain why the Application was filed
late.
Response to IPUC Data Request I
The new power purchase agreement (PPA), between PacifiCorp and Commercial
Energy Managemen! Inc. (CEM), was executed on February 26,2021, shortly
before the end of the original PPA's contact term, which was a Friday. The
Company then proceeded to file the newly executed PPA with the Idaho Public
Utilities Commission (IPUC) as quickly as possible, the following Wednesday
(March 3,2021).
Recordholder:
Sponsor:
Kyle Moore
To Be Determined
PAC-E-21-05 / Rocky Mountain Power
March 29,2021
IPUC Data Request 2
IPUC Data Request 2
The QF is currently not under an approved confract since the original contract
expired on March 1,2021. Has the QF been operating and supplying energy to the
Company since the contract expired? If so, whatprices is the Company planning
to pay the QF during this period without an approved confract?
Response to IPUC Data Request 2
The Company will not provide a payment to the qualifting facility (QF) until the
Idaho Public Utilities Commission (IPUC) approves the new power purchase
agreement (PPA) executed on February 26,2021. Regardless of energy delivery
by the QF to the Company prior to an order by the [PUC, the Company will not
begin making purchases until the date that the IPUC has determined, pursuant to a
final and non-appealable order, that the prices to be paid for energy and capacity
are just and reasonable, and in the public interest, as set forth in the PPA. Should
the IPUC order that ttre Company make payments retroactive to March 1,2021,
the Company will make payments based on energy received back to that date,
based on the prices set forth in the contract term, so long as any energy was
delivered to the Company during that period.
Recordholder:
Sponsor:
Kyle Moore
To Be Determined
PAC-E-21-05 / Rocky Mountain Power
March 29,2021
IPUC Data Request 3
IPUC Data Request 3
The Application states that the Facility's estimated annual net output over the term
is2,187 megawatt-hours per year. Page 3 of the proposed Power Purchase
Agreement (PPA) states Expected Net Output is 2,300 MWh. Page 15 of the
proposed PPA shows the monthly estimates, which results in an estimated annual
amount of 2,310 MWh. Please explain why there is a difference between each of
these amounts and which of these amounts should be used as the Expected Net
Output for the QF.
Response to IPUC Data Request 3
The2,l87 megawatt-hours (MWh) per year (MWVyear) stated in the Company's
Application was stated in error. The 2,310 MWh/year is derived from summing
the figures in the new power purchase agreement (PPA) executed on February 26,
2021, specifically Section 4.9 @nergy Delivery Schedule) is the correct forecast
of annual MWh as represented by the qualiffing facility (QF). The 2,300
MWh/year was inadvertently rounded down to 2,300 MWh/year from 2,310
MWh/year.
Recordholder:
Sponsor:
Kyle Moore
To Be Determined
PAC-E-21-05 / Rocky Mountain Power
March 29,2021
IPUC Data Request 4
IPUC Data Request 4
The Company listed 3 mechanisms for updating the estimated amount of
generation in the PPA. The first mechanism is detailed on page 3 of the definition
for "Expected Net Output" based on the "Contract Year" starting on April 1,2021
and included in Exhibit A-1. The second mechanism is detailed on page 16,
Section 4.9.2, which requires 3 months of additional updates on a 3-month rolling
schedule. The third mechanism allows the QF to update changes to monthly
estimates 5 to l0 days in advance of the next month. Please answer the following
questions:
(a) What is the purpose of each of the 3 mechanisms and explain why each of
these mechanisms is necessary?
(b) The first mechanism references Exhibit A-1, which is also used to define the
Maximum Delivery Rate. The PPA does not contain an Exhibit A-1. If it
should be included, please provide the exhibit.
(c) Please provide the value for the Maximum Delivery Rate. Also, please explain
how Maximum Delivery Rate is determined, what is meant by Actual
Nameplate Capacity Rating, and whether each or both consider water
availability.
Response to IPUC Data Request 4
(a) Each of the mechanisms is expected to refine the forecast from the one
previous.
i. The "Expected Net Output" definition is the initial forecast of generation,
meant to inform expectations of generation at the time of contracting. This
forecast is not updated after contracting.
ii. The forecast in Section 4.9.2 of the new power purchase agreement (PPA),
executed February 26,2021, is meant to provide the utility with a
quarterly update of forecasting from which to help manage its system for
each subsequent three month period and allows the qualiffing facility
(QF) to reflect any known or forecasted changes from the initial forecast
to the utility.
iii. The forecast in Section 4.9.3 of the new PPA is meant to provide the QF
the opportunity to further refine its forecast up to l0 days in advance of
each month. This provides the QF the opportunity to best forecast
generation for purposes of the conforming/non-conforming energy
payment, and provides the utility with best available forecast data from
PAC-E-21-05 / Rocky Mountain Power
March 29,2021
IPUC Data Request 4
which to plan its system.
(b) The new PPA, executed February 26,202I, does contain an Exhibit A-l
@xpected Monthly Net Output). It is located on page 53 of 89 of the
Company's filed submission to the Idaho Public Utilities Commission (IPUC).
Note: this has been verified by checking the version posted to the IPUC
website under Case PAC-E-21-05.
(c) The 'oMaximum Delivery Rate" is stated in Exhibit A-l as 900 kilowatts
(kW). The "Maximum Delivery Rate" is determined as the maximum hourly
rate of delivery ofNet Output in megawatt-hours (MWh) from the Facility to
the Point of Delivery eOD), calculated on the basis of the Net Output
delivered in a single hour. "Actual Nameplate Capacity Rating" means the
capacrty rating as stated on the generator itself representing its maximum
generating capability in a single hour. Both terms assume maximum water
availability.
Recordholder
Sponsor:
Kyle Moore
To Be Determined
PAC-E-2I-05 / Rocky Mountain Power
March 29,2021
IPUC Data Request 5
IPUC Data Request 5
Page 21 of the proposed PPA requires the QF to provide a 12X24 generation
profile. Please explain why this provision is a requirement given that the PPA
utilizes published avoided cost rates.
Response to IPUC Data Request 5
The Company uses a 12x24 generation profile to enter forecasted generation into
the Company's tading/operating systems to estimate hourly generation of the
qualiffing facility (QF) estimated on a month-by-month basis.
Recordholder:
Sponsor:
Kyle Moore
To Be Determined
PAC-E-21-05 / Rocky Mountain Power
March 29,2021
IPUC DataRequest 6
IPUC Data Request 6
Page 2l ofthe proposed PPA requires day-ahead forecasts and updates. Please
explain why this provision is needed.
Response to IPUC Data Request 6
Section 6.7.2 (Day-,Ahead Forecasts and Updates) of the new power purchase
agreement (PPA), executed February 26,202l,requires that the qualiffing facility
(QF) reimburse the Company for day-ahead forecasting services used for
compliance with applicable Elechic System Authority procedures, protocols, rules
and testing. These services are essential for the Company to be able to forecast
and manage all variable resource power flows on a day-ahead basis.
Recordholder:
Sponsor:
Kyle Moore
To Be Determined