20210901PAC to Staff 151-160.pdf

ROCKY MOUNTAIN
POWER / hr: l^ ,tr '_i
I I li iL L'-1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 1,2021
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.norivuki@nuc. idaho. eov (C)
RE ID PAC.E.2I-07
IPUC Set 5 (139-160)
Please find enclosed Rocky Morurtain Power's Responses to IPUC 56 Set Data Requests l5l-
152 and 159-160.
If you have any questions, please feel free to call me at [phone]
Sincerely,
-!sl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC brmull ins@mwanalvtics. com
Adam GardnerlPIIC [e-mail] (W)
Kyle WilliamslPllC [e-mail] (W)
Val Steiner/PIIC val. steiner@ itafos. com (w)
Eric L. OlsenflIPA [e-mail] (C)
Anthony Yankel/IPA [e-mail] (C)
Randall C. Budge/Bayer [e-mail] (C)
Thomas J. Budge/B ayer ti @.rac ineo I son. com (W)(C)
Brian C. Collins/Bayer [e-mail] (WXC)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer khissins@.enereystrat.com (C)
L ance Kaufrnan/B ayer lance @ae eisinsi eht. com (C)
James R. SmithlBayer iim.r. [e-mail] (C)
Brad Purdy [e-mail] (C)
Ben Otto/ICL [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
September 1,2021
IPUC Data Request 151
IPUC Data Request 151
Please provide work papers in electonic format with formula intact for
calculating each coal plant's Coal Fuel Burn Expense from Page 6 of Confidential
Exhibit No. 37.
Response to IPUC Data Request 151
The dispatch of resources, and resultant fuel consumption forecast are determined
by the Generation and Regulation Initiative Decision Tool (GRID) using
incremental prices. The coal fuel burn expense is also determined within GRID
based on coal burn volumes and costing tier prices. Because both the generation
forecast and the coal fuel burn expense are calculated within GRID, there are no
supporting work papers to the calculation. Please refer to confidential work
papers supporting the direct testimony of Company witress, of Michael G.
Wilding, specifically file "ID GRC2I_Fuel Price Ql03) CONF.xlsx" for the fuel
price inputs to GRID.
Please also refer to the Company's response to PIIC Data Request 88
Recordholder:Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
September 1,2021
IPUC Data Request 152
IPUC Data Request 152
Please provide work papers in electronic format with formula intact for
calculating each gas plant's Gas Fuel Bum Expense from Page 6 of Confidential
Exhibit No. 37.
Response to IPUC Data Request 152
The dispatch of resources, and resultant fuel consumption forecast are determined
by the Generation and Regulation Initiative Decision Tool (GRID) usrng
incremental prices. The gas fuel burn expense is also determined within GRID
based on gas bum volumes and costing tier prices. Because both the generation
forecast and the gas fuel burn expense ile calculated within GRID, there are no
supporting work papers to the calculation. Please refer to confidential work
papers supporting the direct testimony of Company witness, of Michael G.
Wilding, specifically file "ID GRC2I_Fuel Price (2103) CONF.xlsx" for the fuel
price inputs to GRID.
Recordholder:Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Roclcy Mountain Power
September 1,2021
IPUC Data Request 159
IPUC Data Request 159
Please quantiff the impact of using the latest OFPC on the NPC and provide
updated ID GRC2I_Fuel Price (2103) CONF" and "ID GRC2I_Market Price
Index (2103) CONF" work papers in electonic format with formula intact.
Response to IPUC Data Request 159
The Company objects to this data request as unduly burdensome and not likely to
lead to the discovery of admissible evidence. The Company has not performed the
requested study or analysis. To update the net power costs (NPC) in this
proceeding using a different offrcial forward price curve (OFPC) would require
updating the majority of the supporting input data files, converting and importing
the data into Generation and Regulation Initiative Decision Tool (GRID), and
performing new GRID scenario runs. A different OFPC would change GRID
optimization and dispatch results and subsequently change many components of
NPC. A diflerent OFPC also would potentially warrant updates to coal costs and
natural gas screening which would require further updates to the supporting input
data files, GRID, and running additional GRID scenario runs.
Recordholder:Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 31,2021
IPUC Data Request 160
IPUC Data Request 160
Please update the following work papers in electronic format with formula intact
to reflect the use of the latest OFPC and the recent BPA rate case.
(a) Exhibit No. 37 - GRID Model NPC Report CONF.
(b) Confidential ExhibitNo. 37 - GRID Model NPC Report
(c) ID GRC2I Testimony Support CONF
Response to IPUC Data Request 160
The Company objects to this request because it is 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:
With regard to BPA's BP-22 rate proceeding, please refer to the Company's
response to IPUC Data Request 158. The Company has not performed any
additional analysis.
With regard to the official forward price curve (OFPC), please refer to the
Company's response to IPUC Data Request 159.
Recordholder:Lori Oathes
Sponsor:Michael G. Wilding