20210826PAC to Staff 139-160-Redacted .pdf

ROCKY MOUNTAIN
POWER
:- - :i : \.j.?rrr!,-E lvrr
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 26,2021
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian. norivuki@puc. idaho. sov (C)
RE:ID PAC.E-21.07
IPUC Set 5 (139-160)
Please find enclosed Rocky Mountain Power's Responses to IPUC 5h Set Data Requests 139-
150 and 153-158. The remaining response will be provided under separate cover. Provided via
e-mail is non-confidential Attachment IPUC 139 and provided via encryption and BOX are the
Confidential Attachments and Confidential Responses. Confidential information is provided
subject to protected under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities
Commission's Rules of Procedure No. 67 - Infomration 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,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Ronald L. Williams/PIIC ron(iDwilliamsbradburv.com
Bradley G. Mullins/PIIC bmrul I ins@.mwanalvtics. corn
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA [e-mail] (C)
Randall C. Budge/Bayer randy @racineolson. com (C)
Thomas J. Budge/Bayer ti @racineolson.com (WXC)
Brian C. Collins/Bayer bcol lins(D,consul tbai. com (WXC)
Maurice B rubaker/B ayer mbrubaker@c onsultba i. c o m (C)
Kevin Higgins/Bayer [e-mail] (C)
Lance KaufinanlBayer lance@ae eisinsiehl com (C)
James R. Smittt/Bayer iim.r. smith@icloud. com (C)
Brad Purdy [e-mail] (C)
Ben Otto/ICL [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 139
IPUC Data Request 139
Regarding the Company's response to Production Request No. 2, please provide a
list of all fransactions booked n2020 that were allocated or directly assigned to
the Company's Idaho jurisdiction for the following FERC accounts:
(a) 1513940: Employee Travel - Other;(b) 1513990: Miscellaneous General Expense;(c) 1515890: Miscellaneous General Expense;(d) 3034900: Misc - Miscellaneous;(e) 3168000: LeasedMiscellaneous;(0 3980000: Miscellaneous Equipment;(g) 3996000: Miscellaneous General Equipment;(h) 4081990: Miscellaneous Taxes - Other;(i) 9160000: Miscellaneous Sales Expenses;
0) 9302000: Misc General Expenses - Other;(k) 9040000: UncollectibleAccounts;(l) 9041000: Uncollectible Accounts;
(m) 9050000: Misc Customer Accounts Expenses; and(n) 9051000: Misc Customer Accounts Expenses.
Response to IPUC Data Request 139
Please refer to Attachment IPUC 139.
Recordholder:Aaron Rose
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 140
IPUC Data Request 140
Please explain the Company's method and calculations for determining Idaho's
allocation of line losses in this case and for actual line losses in the Company's
most recent ECAM. Please explain how the line losses for electricity transmitted
through the state and consumed outside ldaho are excluded from Idaho's
allocation of line losses. Please include supporting work papers in electronic
format with formula intact.
Response to IPUC Data Request 140
PacifiCorp does not have a calculation for aggregating all transmission system
losses and then allocating the losses to each state. Idaho's responsibility for net
power costs (NPC) is based upon Idaho's pro-rata share of load at input. State
level system loads at input are calculated in a manner similar to control area
loads, but include components necessary to determine PacifiCorp customer load
in each state. Load components for determining state-level system loads include
generation from plants connected to PacifiCorp's transmission system,
interchange with other conftol areas, borderline loads served from PacifiCorp's
transmission system, PacifiCorp's borderline loads served from other utilities'
systems, interstate transfer of power on intemal transmission lines, and tansfer
losses. Loads by state are calculated by assigning each load component
(generating plant, interchange point, borderline load, interstate transfer) to the
state in which it is physically located, and aggregating all components by state. In
this way, the net of power input into the transmission system within each state is
determined by the aggregate of generation, interchange, and interstate tansfers,
and is then adjusted to exclude foreign borderline customer load and to include
PacifiCorp borderline load not captured by the fiansmission inputs. Each state
load is determined in this way, with consistency of methodology applied across
all states. Thfud party contactual transfer losses are calculated from loss
schedules, and may be additive or subtractive depending on whether the loss is
owed or owing. These transfer losses are aggregated at the system level and
allocated to each state based upon its contribution to system load for each
hour. Transmission system losses associated with moving power through Idaho to
serve PacifiCorp load in Utah would be included as a part of Idaho load at
input. Losses associated with moving power through Utah to serve PacifiCorp
load in Idaho would be included as a part of Utah load at input.
Recordholder:Jack Painter I Matt Hastings
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 141
IPUC Data Request 141
CONFIDENTIAL REQUEST - Page 2 of Mr. Wilding's Confidential Exhibit
shows that the cost of from the Cedar Wind IIINo.37
ffi;Testimony Support CONF" shows that the cost of from
the Cedar Wind III
. Please
Confidential Response to IPUC Data Request 141
Referencing the direct testimony of Company witness, Michael G. Wilding,
Confidential Exhibit No. 37, page2 cost of
from the Cedar Wind III ect at
paper
file "ID GRC21 Testimony Support
CONF", tab "LTC" is in error as it incorrectly repeats the cost of energy
purchased from the Cedar Springs Wind project (row l0) to the Cedar Springs
Wind III project (row 1l). For further clarification, the calculation for dollars per
megawaff-hour ($/\uIWh) for new long-term contracts in file "ID GRC2I
Testimony Support CONF", tab "LTC", row 19 was impacted by the error, and
with the correct Cedar Springs Wind III values applied, the $/lvlWh for new long-
term contracts would be $19.94llvlWh. Please refer to Confidential Attachment
IPUC l4l which shows the corrected values for Cedar Springs Wind III, and the
resulting $A4Wh value for new long-term contracts more generally.
Note: file "ID GRC2I Testimony Support CONF" is a reference fiIe created after
net power costs are calculated, therefore, the values do not impact the net power
costs (NPC) calculation in this proceeding.
Confidential information is provided subject to protection under IDAPA
31.01 .01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Lori Oathes
Michael G. Wilding
I
Sponsor:
PAC'E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 142
IPUC Data Request 142
Please list all qualiffing facilities subject to situs allocation per the 2020 Protocol
and provide costs allocated to Idaho. Please provide the work papers that calculate
the costs in electronic format with formula intact.
Response to IPUC Data Request 142
Please refer to the direct testimony of Company witress, Steven R. McDougal,
specifically Exhibit No. 40, page 5.1.4 which provides a list of all quali$ing
facilities (QF) subject to situs allocation to Idaho. Please refer to Confidential
Attachment IPUC 142 for the calculation of costs that are situs assigned to Idaho
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Aaron Rose
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 143
IPUC Data Request 143
Please define Trapped Energy and describe the role it plays in the GRID model.
Response to IPUC Data Request 143
The Generation and Regulation Initiative Decision Tool (GRID) logic uses linear
optimization to determine thermal dispatch, market transactions, and transmission
tansfers. Trapped Energy (excess resources) occurs when the thermal resources
in an area are backed down to minimum and the output from the resources net of
load in the area still exceeds available hansmission capacity out of the area.
Recordholder: Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 144
IPUC Data Request 144
Please define Emergency Purchases and describe the role it plays in the GRID
model.
Response to IPUC Data Request 144
Emergency Purchases (resource shortages) occur when resources in an area are
fully dispatched and transmission into the area is insufficient to meet the load in
that bubble. They are a resource of last resort included in the Generation and
Regulation Initiative Decision Tool (GRID) to allow the GRID linear program to
solve in the event that there are insufficient resources in a given hour and within a
given transmission bubble to balance loads and resowces. GRID calculates
emergency purchases based on available resources, requirements, and consfraints.
Recordholder:Eshwar Rao
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 145
IPUC Data Request 145
Please describe how Long-Term Firm Purchases on Page2 of Confidential
Exhibit No. 37 are determined and provide the work papers in elecfionic format
with formula intact that calculate their costs.
Response to IPUC Data Request 145
Referencing Confidential Exhibit No. 37, page2, the "Long Term Firm
Purchases" include several different types of resources. Total costs are determined
based on individual confract terms, and calculations vary by resource type.
Please refer to the confidential work papers supporting the direct testimony of
Company witress, Michael G. Wilding, specifically files "ID GRC2I_Demand
CONF', "ID GRC2I EOR CONF", "ID GRC2I_Other Costs (2103) APR21
CONF", and "ID GRC2I Contacts CONF".
Recordholder: Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 146
IPUC Data Request 146
Please describe operations under the PSCo Exchange. Please provide work papers
in electonic format with formula intact that calculate o'PSCo Exchange" listed on
Page 4 of the Confidential Exhibit No. 37.
Response to IPUC Data Request 146
PacifiCorp and the Public Service Company of Colorado (PSCo) are parties to an
Energy Exchange Agreement dated December 20,2011 (Exchange Agreement).
The Exchange Agreement provides that, for the period January 1,2015, through
October 31,2022, the parties will engage in simultaneous exchanges of 150
megawatts (MW) of energy and capacity at different and various specified
locations in the Western Interconnection. PacifiCorp delivers 150 MW all hours
to PSCo at the Craig and Hayden switchyards, and PacifiCorp and PSCo mutually
agree to alternative delivery points in the event of forced outages of their Craig
and Hayden units shares. PacifiCorp further pays PSCo $3/kw-mn for each month
of the term. PSCo delivers to PacifiCorp 150 MW all hours at Palo Verde (PV).
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Michael G. Wilding, specifically files "ID GRC2l_Demand
CONF", tab "I-GRID Demand", and "ID GRC21 Demand Charge CONF".
Recordholder:Jim Schroeder / Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 147
IPUC Data Request 147
CONFIDENTIAL REQUEST PAgE 4 of Confidential Exhibit No. 37 shows that
Short Firm Purchases from Palo Verde is
103 APR2I CONF (2020-
2023 shows the
Confidential Response to IPUC Data Request 147
The difference between Confidential Exhibit No. 37 and the confidential work
paper supporting the direct testimony of Company witress, Michael G. Wilding,
specifically file "ID GRC2I STF APR21 CONF 2023
2A21. The source of the data provided in file "ID
GRC2I_STF (2103) APR2I CONF Q020-2023)", hb "Calculation Verification"
is the Company's system of record, ENDUR, which considers daylight savings
time @ST). The source of the data provided for the short-term firm (STF)
purchases from PV on page 4 of Confidential Exhibit No. 37 is the Generation
and Regulation Initiative Decision Tool (GRID), which does not consider DST.
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 the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Eshwar Rao / Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 148
IPUC Data Request 148
CONFIDENTIAL REQUEST - Page 6 of ExhibitNo.3 shows
that Firm for the Test Period is
, whereas
Costs" of the Excel File "ID GRC2I
Wheeline CONF" is
Confidential Response to IPUC Data Request 148
The naming convention in Confidential Exhibit No. 37, and the confidential work
paper supporting the direct testimony of Company wifiress, Michael G. Wilding,
specifically file "ID GRC2I Wheeling CONF" are different, so while the two
values referred to in this request are labeled similarly, the values are not
comparable.The calculation of the "Firm 6of
sum expense
on-expense from the "Wheeling Costs" tab of file "ID
GRC2I Wheeling CONF" (row 209 and 210), less the "EIM GMC BID TRNS
FEE-, and the "EIM GMC TRNSACT CHRG" charges (row 45 and 46). Note:
the sum of the "EIM GMC BID TRNS FEE", and the "EIM GMC TRNSACT
CHRG" costs have been listed as a separate line item labeled *C&T EIM Admin
fee" on page 6 of Confidential Exhibit No. 37.
To reconcile the files, the sum of "Firm" wheeling expense (row 210) and'Non-
firm" wheeling expense (row 209) on the "Wheeling Costs" tab of file "ID
GRC21 Wheeling CONF" equals the sum of "Firm Wheeling" and "C&T EIM
Admin fee" on page 6 of Confidential Exhibit No. 37.
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 the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder Eshwar Rao
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 149
IPUC Data Request 149
CONFIDENTIAL REQUEST - Page 6 of Confidential Exhibit No. 37 shows
that ST Firm & Non-Firm for the Test Period is
, whereas the
Costs"
of the Excel File
Response to IPUC Data Request 149
The naming convention in Confidential Exhibit No. 37, and the confidential work
paper supporting the direct testimony of Company witress, Michael G. Wilding,
specifically file "ID GRC2I Wheeling CONF" are different, so while the two
values referred to in this request are labeled similarly, the values are not
comparable. The "ST Firm 6of
Confidential Exhibit No. 37
and Regulation Initiative Decision Tool
(GRrD)
Please refer to the Company response to IPUC Data Request 148 which details
that the'Non-firm" Wheeling Expense shown on tab "Wheeling Costs" of file
"ID GRC2I_Wheeling CONF" is included in the "Firm Wheeling Expense" on
page 6 of Confidential ExhibitNo.37.
Confidential information is provided subject to protection under IDAPA
31.01.01 .067 and31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Eshwar Rao
Sponsor Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 150
IPUC Data Request 150
Please define 'C&T EIM Admin Fee" and explain why it is included in the
wheeling expenses. Please provide the work paper in electronic format with
formula intact that calculates the fee.
Response to IPUC Data Request 150
The "C&T EIM Admin Fee" is the charge PacifiCorp pays to the California
independent System Operator (CAISO) for administering the energy imbalance
market (EM. This charge is the same as the scheduling, control and dispatch
(Schedule 2) tariffcharges PacifiCorp pays to other tansmission providers, all of
which roll up to wheeling expenses.
Recordholder:Doug Young
Michael WildingSponsor
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 153
IPUC Data Request 153
CONFIDENTIAL REQUEST - From Page 6 of Confidential Exhibit No. 37,
please explain why the gas plants in the table below have no Gas Fuel Burn
Expense in the months indicated:
Response to IPUC Data Request 153
The resources listed in the table above have no gas fuel bum expense in the
months indicated because they are oflline during these periods, therefore
incurring no fuel burn expense. With the exception of Little Mountain, which is
no longer apafi of the Company's system, the resources are off-line for various
outage types such as planned, forced, and economic. In some cases, a resource
may be scheduled off-line for part of a month, or period, but based on inputs such
as system load, market conditions, startup costs, or other variables, the Generation
and Regulation Initiative Decision Tool (GRID) optimization may determine it is
more economical for the resource to remain off-line for a longer period of time,
than to retum to service on the original return date.
Recordholder: Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Roclcy Mountain Power
August 26,2021
IPUC Data Request 154
IPUC Data Request 154
Please define and describe "Gas Physical", "Gas Swaps", "Clay Basin Gas
Storage", and "Pipeline Reservation Fees" and explain what negative values and
positive values represent.
Response to IPUC Data Request 154
"Gas Physicals" - The net cost of gas purchased from suppliers and sold to
markets used for power production and stored/withdrawn from Clay Basin
inventory. Purchases are positive and sales are negatives.
"Gas Swaps" - Financial transaction paying or receiving the difference between
an index price and a fixed (or occasionally different index) price for a specified
financial (not physical) quantity. Gains are negative and losses are positive.
"Clay Basin Gas Storage" - The value of physical gas injections (receipts) to Clay
Basin Gas Storage netted against the value of physical gas withdrawal (deliveries)
from Clay Basin Gas Storage. Injections are negative and withdrawals are
positive.
"Pipeline Reservation Fees" - The fixed amount paid to pipeline to reserve a
specific daily quantity that PacifiCorp reserves the right to tansport. Costs are
positive and revenues are negative.
Recordholder:Doug Young
Michael WildingSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 155
IPUC Data Request 155
Please provide the work papers in electronic format with formula intact that
calculates the costs of the Blundell project.
Response to IPUC Data Request 155
The Company assumes that the reference to "the costs of the Blundell project" is
intended to be a reference to the costs in the net power costs (NPC) report
associated with Blundell. Based on the foregoing assumption, the Company
responds as follows:
Please refer to the confidential work papers supporting the direct testimony of
Company witress, Michael G. Wilding, specifically file "ID GRC2I EOR
CONF", and links within that file. As a reference, the nameplate capacity for the
Blundell plant is stored in Generation and Regulation Initiative Decision Tool
(GRID) in the'oResources" section under ooResource Type", "Thermal Unit". The
equivalent outage rate @OR) and nameplate capacity are used to calculate a
generation forecast for Blundell, and the cost per megawatt-hours ($/IvIWh) is
indicated in file "ID GRC2I_Fuel Price (2103) CONF.xlsm", specifrcally at cell
E53 in tab *4 GRID Coal 2019+". The generation forecast and $/\uIWh basis
should resolve to the projected cost forecast.
Recordholder Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 156
IPUC Data Request 156
CONI'IDENTIAL REQIIEST - Page 11 of Mr. Wilding's Confidential Direct
states that the CAISO used to calculate the scalars are
between
are papers
format with formula intact that calculate the values.
Response to IPUC Data Request 156
The values are determined by intemal discussions between the Company's net
power costs (NPC), energy supply management (ESM) and risk management
groups. There are no supporting work papers specific to the scalar caps used;
however, there is a price data file that is compiled to inform the above reference
internal discussions. The referenced price data file is highly confidential and
commercially sensitive. The Company requests special handling. Please contact
Ted Weston at [phone] to make arrangements for review.
Recordholder:Alex Lee
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 157
IPUC Data Request 157
CONFIDENTIAL REQT EST - Page 24 of lvk. Wilding's Confidential Direct
that NPC
in EIM
revenue.papers ul
intact that calculate these two values
Response to IPUC Data Request 157
Please refer to Confidential Attachment IPUC 157. The work papers used to
constuct the energy imbalance market (EIM) benefit forecast includes a script
from the softurare program R, which is a programming language and free software
environment for statistical computing. R can be downloaded for free from the R
website (https : /iwww.r-proi ect. oreA.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Christopher White
Michael G. WildingSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 26,2021
IPUC Data Request 158
IPUC Data Request 158
Does the recent BPA rate case have an impact on the wheeling costs and the
NPC? If so, please quantiff the impact and provide an updated "ID
GRC2l_Wheeling CONF" work paper in elechonic format with formula intact.
Confidential Response to IPUC Data Request 158
The Company objects to this request as overly broad and unduly burdensome. The
Company assumes that the reference to the "recent BPA rate case" is intended to
be a reference to the Bonneville Power Administration @PA) consolidated power
and tansmission rate proceeding (BP-22), in which BPA issued its final record of
decision on July 28,2021. Based on the foregoing assumption, and without
waiving its objection, the Company responds as follows:
BPA's BP-22 rate proceeding included rate increases effective October 1,2021
The forecasted impact of the new rates, on a total
2021 is an increase to costs of
ompany additional analysis
concerning the impact of the BPA BP-22 rate case.
Confidential information is provided subject to protection under IDAPA
31.01.01 .067 md 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and firther subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Lori Oathes
Sponsor:Michael G. Wilding