20210929Staff 213-228 to PAC-Redacted.pdf

DAYN HARDIE (ISB No. 9917)
JOHN R. HAMMOND, JR. (lSB No. 5470)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attomeys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE STATE OF
IDAHO
CASE NO. PAC.E.21-07
REDACTED TENTH
PRODUCTION REQUEST OF
THE COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and John R. Hammond, Jr., Deputy Attorneys General, request that Rocky
Mountain Power ("Company") provide the following documents and information as soon as
possible, but no later than THURSDAY, OCTOBER 7, 2021.r
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
I Stuffir requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at [phone].
REDACTED TENTH PRODUCTION
REQUEST TO ROCKY MOUNTAIN POWER I
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SEPTEMBER2g,2O2I
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
EXCEL spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 213: Page 13 of Mr. Eller's Confidential Direct Testimony states that
the Company' s 2019 IRP preferred portfolio includes and that as
evidenced by its selection in the IRP preferred portfolio, this resource is cost-effective and thus
best represents the Company's current cost of meeting its capacity needs. In addition , the 2019
IRP shows that the Company's load and resource balance first becomes capacity deficient in
2028 after early coal plant retirements. Please answer the following questions:
a. Please explain why this resource best represents the Company's current cost of
meeting its capacity needs in the context of valuing both operating reserves and
economic curtailment, compared to other resources selected in the preferred
portfolio?
b. Please explain why
I. Specifically, is it due to economic reasons, need for capacity, or a
combination of reasons?
c. Is this resource a reasonable surrogate to price
Please
explain.
REQUEST NO. 214: In Order No. 32196, the Commission "blends the current
condition with the longer-term capacity view that corresponds with[P4]'s demonstrated long-
term intemrptible commitment." Please explain
is a reasonable surrogate.
REDACTED TENTH PRODUCTION
REQUEST TO ROCKY MOUNTAIN POWER 2 SEPTEMBERZg,2O2I
REQUEST NO. 215: Please list the resource(s) on the Company's system or those in
the 2019 IRP Prefened Portfolio menu of resources that best (the least expensive resources that
meet the performance criteria needed for each service) provide operating reserves and economic
curtailment (list resources for each service separately). Please provide the workpapers for these
interruptible credits for each resource and for each service in the same format as Confidential
Exhibit No. 36 - Interruptible Product Value Updote.
REQUEST NO. 216: Please describe what the energy values
in context to how they are determined in the GRID model. Also, please
describe the steps involved to determine them.
REQUEST NO. 217: Please answer the following regarding the calculation of I
I,
a. Please define
determined.
b. Please define
E"ndexplaintro'rE
was determined.
was
and explain the purpose of
and how it is used to determine the
adjustment.
c. Please provide the original and complete supporting workpapers shown in the
and identifu the specific
section that it refers to
d. Please explain how the
REQUEST NO.218: Page 13 of Mr. Eller's Confidential Direct Testimony states, !
REDACTED TENTH PRODUCTION
REQUEST TO ROCKY MOUNTAIN POWER 3 SEPTEMBER29,2O2I
Please answer the following:
a. Please confirm that the
describes the amount of
b. Is the incremental value I
I can provide to the Company's system that
and cannot provide? Please explain.
c.Please explain the rationale behind the formula contained in
d. Please explain why are not used to adjust the
capacity value of operating reserves.
e. Please provide an example to illustrate how the energy benefits
I reflect the value of the operating reserves it provides AND the margin
between its operating cost and that of the higher-priced altematives.
REQUEST NO. 219: Page 13 of Mr. Eller's Confidential Direct Testimony states,
Please answer the following questions.
a. At what granularity does
b. Please explain why the granularity is not suitable for
modeling operating reserve demand.
REQUEST NO. 220: Page 14 of Mr. Eller's Confidential Direct Testimony states,
Order No. 32196 ordered
the parties to use GRID and Front Office model runs to estimate the value of the Economic
Curtailment product. What has changed in the operation of the Company's system since Order
No. 32196 that justifies Is there
REDACTED TENTH PRODUCTION
REQUEST TO ROCKY MOUNTAIN POWER 4 SEPTEMBER2g,2O2I
any remaining validity to using
Please explain.
REQUEST NO. 221: Regarding
please answer the following:
a. Please define and describe what
in context to how they are calculated. Also,
please provide the data and workpapers used to determine these amounts in Excel
format with formula intact.
b. Why are there months in both tables with missing data?
REQUEST NO.222: Currently, the Economic Curtailment Product can be called upon
at any time,
Page 8 of Mr. Eller's Confidential Direct
Testimony indicates under the proposed construct,
!, please explain how is considered in determining the value of the EIM prices
used to determine the value of
REQUEST NO.223: Page 5 of Mr. Eller's Confidential Direct Testimony states I
Please explain if tf," f
is only for contingency reserves. Can it be used for any other type of ancillary
service? Please explain.
REQUEST NO. 224: Is the EIM ever used for the type of events that the Operating
Reserve product is designed to mitigate? Please explain.
REDACTED TENTH PRODUCTION
REQUEST TO ROCKY MOUNTAIN POWER 5 SEPTEMBER29,2O2I
REQUEST NO.225: Page 14 of Mr. Eller's Confidential Direct Testimony states,
Please answer the following questions:
a. What specific changes does refer to?
b. Please explain in detail why and how the
used as a resource I based on proposed changes, and why
cannot be used as a resourceI
can be
be used as a resour..I? Pleasec. Can the
explain.
REQUEST NO.226: Page 15 of Mr. Eller's Confidential Direct Testimony states, !
Please justiff this proposal and explain in detail why the I
should include the value of operating reserves.
REQUEST NO.227z Order No. 32196 states that the Commission does not believe that
an additional capacity value is appropriate for the Please explain
in detail why
REQUEST NO.228: Page 15 of Mr. Eller's Confidential Direct Testimony indicates,
the following questions:
a. Please explain the meaning
how it is used in the calculations.
b. Please explain the rationale for adjusting
Please answer
rn context to
REDACTED TENTH PRODUCTION
REQUEST TO ROCKY MOI-INTAIN POWER 6 SEPTEMBER29,2O2I
tqbDATED at Boise,Idaho, this day of September 2021
Dayu
Deputy Attorney General
trriniss:pro&Eq/pac€2l.7dhnlit prod rcq l0
REDACTED TENTII PRODUCTION
REQUEST TO ROCKY MOLINTAIN POWER 7
\
SEPTEMBER29,2A2I
CERTIFICATE OF SERVICB
I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF SEPTEMBER 202T,
SERVED THE FOREGOING REDACTED TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE NO. PAC-E-21-07
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@pacifi corp.com
idahodockets@pac ifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pac i fi corp.corn
ANTHONY YANKEL
I27OO LAKE AVE
uNrT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
BRIAN C COLLINS
MAURICE BRUBAKER
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD #I4O
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
[e-mail]
LANCE KAUFMAN
AEGIS INSIGHT
E-MAIL: [e-mail]
EMILY L WEGENER
MATTHEW D McVEE
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL : emil),.wegener@pacif'rcorp.com
matthew.mcvee@pacifi corp.com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON
PO BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
[e-mail]
JAMES R SMITH
MIKE VEILE
BAYER CORPORATION
E-MAIL: iim.r.smi cloud.com
mi ke. vei I e@ ba),er. com
KEVIN HIGGINS
COURTNEY HIGGINS
MILLI PICHARO
NEAL TOWNSEND
ENERGY STRATEGIES
E-MAIL: [e-mail]
chie gi [e-mail]
[e-mail]
ntownsend@energystrat. com
CERTIFICATE OF SERVICE
RONALD L WILLIAMS
MLLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL: [e-mail]
ADAM GARDNER
IDAHOAN FOODS
E-MAIL: [e-mail]
VAL STEINER
ITAFOS CONDA LLC
E-MAIL: val.steiner@,itafos.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N ITTH ST
BOISE ID 83702
E-MAIL: [e-mail]
BRADLEY G MULLINS
MW ANALYTICS ENERGY
E-MAIL: [e-mail]
KYLE WILLIAMS
BYt] IDAHO
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE TD 83702
E-MAIL : [e-mail]
CERTIFICATE OF SERVICE