20210920PAC to Bayer 131-134.pdf

Y ROCKY MOUNTAIN
B*YE#*"
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'..:i': - u. /',-..'q' .:;'l;1.i 1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 20,2021
Randall C. Budge/Bayer randy@rac ineolson.com (C)
Thomas J. Budge/Bayer ti @racineo I son. com (WXC)
Brian C. Collins/Bayer bco I lins@consu ltbai. com (WXC)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin HigginVBayer kh i gsins@energy strat.com (C)
Lance Kauftran/Bayer I an ce @.ae e i si n si eht. com (C)
James R. Smith/Bayer i im. r. smi th @ic loud. com (C)
Mike Veile/Bayer [e-mail]
Courtney Higgins/Bayer chigsins@enersy strat. com
Milli Picharo lBay er mpichardo@enersl/strat.conr
Neal Townsend/Bayer [e-mail]
RE: ID PAC-E-21-07
Bayer Set I lm (l3l-134)
Please find enclosed Rocky Mountain Power's Responses to Bayer I lff Set Data Requests l3l-
134. Also provided via encryption and BOX is Confidential Attachment Bayer 134.
Confidential information is provided subject to protection under IDAPA 3 I .0 I .01 .067 and
31.01.01.233, the Idaho Public Utilities Commission's Rules of Procedure No. 67 - Information
Exempt from Public Review, and furttrer subject to the Non-Disclosure Agreement (NDA)
executed in this proceeding.
lf you have any questions, please feel free to call me at [phone].
Sincerely,
lsl
J. Ted W-eston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC ian.norivuki6Dpuc.idaho.eov (C)
Ronald L. Williams/PIIC ron@wi ll iamsbradburv. com
Bradley G. Mullins/PIIC brmu I I ins@mwanalyt ics. com
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)
Ban Ofio/ICL [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Bmdley G. MullinslPtrC [e-mail]
Adam Gardner/PtrC [e-mail] (W)
Kyle WilliamslPtrC [e-mail] (W)
Val St€incr/PtrC [e-mail] (W)
Eric L. OlsEn/IIPA elo@echohawkcom (C)
Adhony YaTIkGUIIPA tonv(Oyankel.n* (C)
Brad Putdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
September 20,2021
Bayer Data Request l3l
Bayer Data Request 131
Follow-Up to RMP Response to Bayer Data Request No. 34. With respect to
Rocky Mountain Power's Response to Bayer's 2nd Set Data RequestNo. 34,
please provide the following GRID runs:
(a) Please provide a GRID analysis for a calendar year with no Bayer
intemrptions associated with an operating reserve event. Assume Bayer is in
place to provide 95 MW of operating reserve. Please provide the GRID
analysis results in electonic native format. This format should be identical to
the GRID results format used in the response to Bayer Data Request No. 34.
(b) Please provide a GRID analysis for a calendar year where Bayer is intemrpted
by 95 MW for operating reserve events that total 188 hours in the months of
July through September. Please maintain the same inputs as were used to run
the GRID analysis in subpart (a) above. Please provide the GRID analysis
results in electronic native format. This format should be identical to the
GRID results format used in the response to Bayer Data Request No. 34.
(c) Please provide a GRID analysis for a calendar year where a new aero
derivative simple cycle combustion turbine (SCCT) is put in place of Bayer's
95 MW intemrptible load and only responds to operating reserve events that
total 188 hours in the months of July through September. Assume Bayer does
not provide any curtailment products and its load is firm. Please maintain the
same inputs as used to run the GRID analysis in subpart (b) above and assume
the same 188 hours of intemrption for operating reselve events as was
modeled in the GRID analysis in subpart (b) above. Please provide the GRID
analysis results in electonic native format. This format should be identical to
the GRID results format used in the response to Bayer Data Request No. 34.
Response to Bayer Data Request 131
(a) The Generation and Regulation lnitiative Decision Tool (GRID) only
identifies capability on sufficient resources to cover modeled reserve
requirements and does not include any energy dispatch or intemrptions in
response to outages or resource imbalance that would trigger operating
reserves to be called upon in acfual operations, as these events either do not
occur, or occur at known intervals that the model sees with perfect foresight
within the algorithm. As a result, the GRID results provided with the
Company's response to Bayer Data Request 34 are essentially responsive to
this request, excepting that they evaluate 100 megawaus (MW) of incremental
operating reserve, rather than the requested 95 MW. The difference in size is
expected to have a de minimus impact on the valuation on a per kilowatt
($/kW) basis.
PAC-E-21-07 / Rocky Mountain Power
September 20,2021
Bayer Data Request l3l
(b) The Company has not performed the requested analysis. Please refer to the
Company's response to subpart (a) above with regard to the limitations of
GRID.
(c) The Company has not performed the requested analysis. Please refer to the
Company's response to subpart (a) above with regard to the limitations of
GRID.
If P4 Production, LLC lBayer Corporation @ayer) would like to be provided
access to a GRID instance, uploaded with the GRID project associated with ttre
Company's Idaho general rate case (GRC) proceeding, please contact Ted Weston
at [phone]. Access to GRID and the associated GRID project(s) require
the individual user to have executed the relevant confidentiality agreement / non-
disclosure agreement (NDA) applicable to this proceeding. In order to set up
external access to GRID, the individual user will need access to a device capable
of downloading'Apps". The Company will also need to be provided with the
following details of the individual user: (a) Name, (b) Mailing Address, (c) Email,
and (d) Telephone Number.
Recordholder:Dan MacNeil / Lori Oathes
Sponsor:Craig Eller
PAC-E-21-07 / Rocky Mountain Power
September 20,2021
BayerDataRequest 132
Bayer Data Request 132
Interruptibility of Bayer. [n reference to PacifiCorp's 2019 Integrated Resource
Plan (IRP), please describe how the intemrptibility of the Bayer load is
recognized in the IRP.
Response to Bayer Data Request 132
The 2019Integrated Resource Plan (RP) models capture two parts of the existing
P4 Production / Monsanto Company lBayer Corporation (Bayer) intemrptible
contact - a 67 megawatt (MW) curtailment and a 47.5 MW operating reserve. For
planning putposes, the contact capacity is considered a resource in the load-and-
resource balance. A small amount of contact energy is modeled at 12 megawatt-
hours (MWh) per year.
Recordholder:Dan Swan
Sponsor:Rick T. Link
PAC-E-21-07 / Rocky Mountain Power
September 20,2021
Bayer Data Request 133
Bayer Data Request 133
Interruptibility of Bayer. In reference to PacifiCorp's 2021 Integrated Resource
Plan (IRP), please describe how the intemrptibility of the Bayer load is
recognized in the IRP.
Response to Bayer Data Request 133
Please refer to the Company's response to Bayer Data Request l32.The202l
Integrated Resource Plan (IRP) uses the same model assumptions as implemented
in the 2019 IRP.
Recordholder:Dan Swan
Sponsor:Rick T. Link
PAC-E-21-07 / Rocky Mountain Power
September 20,2021
Bayer Data Request 134
Bayer Data Request 134
Pryor Mountain. Please refer to RMP Witness Rick Link's Confidential work
paper "Table 4, Figure 3-4, FB_PryorMtn_Analysis_20 I 9- I 2-06 v3.xlsx":
(a) In row l0 of the'?ryor Mountain Economics" worksheet RMP provides
values that represent the generation for the Pryor Mountain wind project for
each year of the project's life. Please identiff the work paper(s) where these
generation values are developed. If RMP failed to provide the work paper(s)
with its filing, or in response to previously propounded discovery, please
provide the work paper(s) supporting these generation values. Please provide
the work paper(s) in Excel format with formulas intact to allow a complete
understanding of how the annual values were determined.
(b) In rows l6 through 2l of the "Pryor Mountain Economics" worksheet RMP
provides values for the project cost (separated by Capital Rev. Req., PTCs,
O&M, Gen. Tax, Property Tax, and Transmission Upgrades) for the Pryor
Mountain wind project for each year ofthe project's life. For each project cost
category, please identiff the work paper(s) where these various project costs
are developed. If RMP failed to provide the work pape(s) with its filing, or in
response to previously propounded discovery, please provide the work
paper(s) supporting the development of these various cost categories. Please
provide the work paper(s) in Excel format with formulas intact to allow a
complete understanding of how the annual values were determined.
Response to Bayer Data Request 134
(a) Please refer to Confidential Attachment Bayer 134. Annual generation is
shown in column U on tab "Results Overview" based on the hourly generation
profile for each month on tab "Wind_Input".
(b) Referencing the confidential work papers supporting the direct testimony of
Company witness, Rick T. Link, specifically folder "FCl and PM", file
"Table 4, Figure 34, FB_PryorMtn_AnalysisJ0l9-12-06 v3", tab "Pryor
Mountain Economics", rows 16 through 2l are based on data on tab
"Generic" of Confidential Attachment Bayer 134. The source of this data is as
follows:
(l) Row l6'Capital Rev. Req." is the sum of rows 321 and323 ontab
"Generict'.
(2) Row 17 "PTCs" is equal to row 363 on tab "Generic",
(3) Row 18 "O&M" is equal to row 340 on tab "Generic"
PAC-E-2147 / RockyMountain Power
September 20,2021
BayerDataRequest 134
(4) Row 19 *Gen. Tax" is equal to row 340 ontab "Crenetric".
(5) Row 20 *Property Talr" is equal to row 341 on tab "Generic".
(6) Row 2l "Transmission Upgrades" is the zum of rows 322 dfr 325 on tab
"Generid'.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233,the Idatro Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further zubjct
to the Non-Disclozure Agreement (NDA) executed in this proceeding.
Recordholder: lvlark Paul
Sponsor:RickT. Link