20210930PAC to Staff 199.pdf

ROCKY MOUNTAIN
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 30,2021
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
jan.noriyuki@puc. idaho. gov (C)
RE ID PAC-E.2I.07
IPUC Set 8 (196-199)
Please find enclosed Rocky Mountain Power's Responses to IPUC 8ft Set Data Request 199.
The remaining response will be provided under separate cover.
lf 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 [e-mail]
Bradley G. Mullins/PIIC brmullin cs.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)
Randall C. Budge/Bayer rand),@racineo I son.com (C)
Thomas J. BudgeiBayer tj @.racineolson.com (WXC)
Brian C. Collins/Bayer bco I I in s@con su ltbai.com (WXC)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer khi geins@.energystrat.com (C)
Lance Kaufrnan/Bayer I ance@.aeqi sinsi eht.com (C)
James R. Smith/Bayer i im.r. sm ith @i c loud.com (C)
Brad Purdy [e-mail] (C)
Ben Otto/ICL [e-mail] (C)
PAC-E-2I-07 / Rocky Mountain Power
September 30,2021
IPUC Data Request 199
IPUC Data Request 199
Please provide data and any analyses showing the following tansmission
categorized capital investments are directly beneficial to PacifiCorp's Bulk
Electric System (NERC definition - Bulk Electric System (BES)
wivw.nerc. com/palRAPA/Page s/BES. aspx. P lease al so prov ide an expl anation
with specific examples for how these investments are beneficial to Idaho
customers for each project listed below:
a. APR 24000998 Mona-Oquirrhline
b. APR 24000926 Sigurd Red Butte Crystal345kV Line
c. APR 2400l854Vantage Pomona Heights 230kV Line
d. APR 24004106 Snow Goose 500-230kV Sub TPLOO2
e. APR 24001I I I Union Gap Add 230-l l5kv Capacity
f. APR 24005440 Purgatory Flat New l38kv (UAMPS)
g. APR 24002551Whetstone 230-l l5kv Sub Phase I
h. APR 24005792 Troutdale Sub 230kV Swtchyd ll5kv Rg Bus
i. APR 24006434 Sams Valley 500-230kV New Substation
j. APR 24005218 Fry Sub Instl I 15 kV Capacitor Bank TPL2
k. APR 24006772N8 Portland Trans Upgrade
l. APR 24009285 Q0092 Cowlitz PUD Interconnection
m. APR 14000046 Cameron Milford l38kv Trns 138-46 Tmsfm
n. APR 24002099 Southwest WY Silver Creek Build l38kV Ln
o. APR 14000051 Black Rock New 230-69kV Substation
p. APR 14000042 Carbon County System Reinforcement
q. APR 24003424 Tooele Sub: Rpl Xfmr I & 3, Add l38kV So
r. APR 24001816 West Point-New 138 kV Line & 40 MVA Sub
Response to IPUC Data Request 199
PacifiCorp's transmission system, including the assets identified in the data
request, provides direct benefits to the Company's Idaho customers by enhancing
the reliability of the interconnected transmission system, ability to dispatch
resources, and access to energy markets. PacifiCorp's transmission system is
designed to reliably transport electricity from a broad array of generation
resources to load across both of its Balancing Authority Areas (BAA).
Transmission investments are analyzed based on engineering requirements,
PacifiCorp's legal and regulatory obligations, and the ability to enhance service
across the transmission system. PacifiCorp's transmission system is operated as
an interconnected grid, allowing for the dispatch of various resources to serve
PAC-E-21-07 / Rocky Mountain Power
September 30,2021
IPUC Data Request 199
load. Accordingly, PacifiCorp's various allocation methodologies, including the
current 2020 PacifrCorp Inter-Jurisdictional Allocation Protocol, have specifically
allocated all transmission assets based on a system generation allocation factor.
The dynamic allocation of transmission costs ensures that PacifiCorp's customers
in each state pay an appropriate share ofthe costs based on the usage ofthe
system.
As a balancing authority, PacifiCorp is required under North American
Reliability Corporation (NERC) reliability standards to balance loads and resources
in real-time. This is primarily accomplished by dispatching resources physically
interconnected to the BAA that are not scheduled for export. lmported energy from
generation facilities located outside the BAA generally cannot be dispatched by the
balancing authority to balance its BAA in real-time.
On April l, 2005, NERC established a set of transmission operations
reliability standards. A subset of the transmission reliability standards are the
transmission planning standards (TPL Standards). The purpose of the TPL
Standards is to "establish Transmission system planning performance requirements
within the planning horizon to develop a Bulk Electric System (BES) that will
operate reliably over a broad spectrum of System conditions and following a wide
range of probable Contingencies." The TPL Standards, along with regional
planning criteria (i.e., regional planning criteria established by the Western
Electricity Coordinating Council (WECC)) and utility-specific planning criteria,
define the minimum transmission system requirements to safely and reliably serve
customers.
Compliance with the reliability standards is not optional. The reliability
standards are a federal requirement, subject to oversight and enforcement by
WECC, NERC, and the Federal Energy Regulatory Commission (FERC).
PacifiCorp is subject to compliance audits every three years and may be required
to prove compliance during other NERC or WECC reliability initiatives or
investigations. Failure to comply with the reliability standards could expose the
Company to penalties of up to $l million per day, per violation.
PAC-E-21-07 / Rocky Mountain Power
September 30,2021
IPUC Data Request 199
The Company plans, designs, and operates its transmission system to meet
NERC Standards for BES and WECC Regional standards and criteria. To ensure
compliance with applicable TPL Standards, PacifiCorp conducts an annual system
assessment to evaluate the performance of the Company's transmission system and
to identify system deficiencies. The annual system assessment is comprised of
steady-state, stability, and short circuit analyses to evaluate peak and off-peak load
seasons in the near term (one-, two-, and five year) and long term (10 year) planning
horizons. The assessment is performed using power flow base cases maintained by
WECC and developed in coordination among all transmission planning entities in
the Western Interconnection. These base cases include load and resource forecasts
along with planned transmission system changes for each of the future year cases
and are intended to identifu future system deficiencies to be mitigated.
As part of the annual system assessment, corrective action plans are
developed to mitigate identified deficiencies, and may prescribe construction of
transmission system reinforcement projects or, as applicable, adoption of new
operating procedures. In certain instances, operating procedures prescribing action
to change the configuration of the transmission system can prevent deficiencies
from occurring when there are two back-to-back (N-l-l) (or concurrent)
transmission system events. However, the use of operating procedure actions has
limitations. Actions taken in connection with operating procedures that are
designed to protect the integrity of the larger integrated transmission system in the
Western Interconnection of the United States can lead to large numbers of
customers being at risk of an outage upon the occurrence of the second oftwo back-
to-back (N-l-l) events. An effective corrective action plan is critical to ensuring
system reliability so that large numbers of customers are not subjected to avoidable
outage risk.
In addition to the reliability standards, there are several other drivers that
inform whether PacifiCorp will build new distribution and transmission facilities,
including increased demand for transmission capacity, requests for transmission
service, increased demand for distribution capacity, and the age and condition of
PAC-E-21-07 / Rocky Mountain Power
September 30,2021
IPUC Data Request 199
existing distribution and transmission facilities.
PacifiCorp's geographic diversity, access to adjacent transmission
providers and BAAs, and access to regional energy market hubs allows
PacifiCorp to economically dispatch units across its system and transfer energy
from other systems as facilitated by the Company's participation in the Energy
Imbalance Market (EIM). As the result of PacifiCorp's expansive footprint,
PacifiCorp is also uniquely situated to access some of the nation's best wind and
solar resources to serve load throughout PacifiCorp's service territories.
PacifiCorp also takes advantage of its transmission system to minimize
operation costs related to generation reserve requirements and generator blackstart
capability. Per the Company's Open Access Transmission Tariff PacifiCorp is
required to carry reserves to ensure system reliability in the event ofchanges in
load or system events. Instead ofbeing required to carry reserves and generator
blackstart capability in each individual BAA, PacifiCorp can operate its
transmission as a collective system and use resources that are geographically
remote to meet the system requirements in all areas that PacifiCorp serves. This
allows the Company to engage in the most economic dispatch to lower costs for
its customers. PacifiCorp often meets its reserve requirements in PACE with
resources located in PACW. While meeting the reserve requirements in the
reliability standards is not a transmission function, PacifiCorp's transmission
system provides flexibility for PacifiCorp to meet its reserve requirements.
The ability to flexibly use a diverse set of energy resources is significantly
dependent on the strength and reliability of PacifiCorp's transmission system
connecting those resources to PacifiCorp's retail customers in all six states that
PacifiCorp seryes customers in. PacifiCorp's entire transmission system facilitates
access to some of the best wind resources in the nation located in Wyoming as well
as access to solar resources in Utah and the desert southwest. Additionally, dispatch
benefits from the EIM include access to CAISO markets. PacifiCorp's entire
transmission system facilitates these benefits. Transmission system outages and
other real-time operation constraints place additional burden on the remainder of
PAC-E-21-07 / Rocky Mountain Power
September 30,2021
IPUC Data Request 199
the transmission system as corrective action plans are implemented to maintain
compliance with NERC and WECC standards and guidelines and ensure the
reliability of service to all PacifiCorp customers.
A summary of the project drivers is listed below for reference:
Recordholder: Richard A. Vail
Sponsor: Richard A. Vail
Proiect Proiect Driver
a. APR 24000998 Mona-Oquirrh Line Load srowth and reliabiliW
b. APR 24000926 Sigurd Red Butte Crystal 345kV Line Load growth, reliability, and access to markets
c. APR 24001854Vantage Pomona Heiehts 230kV Line NERC TPL-OO1-4
d. APR 24004105 Snow Goose 500-230kV Sub TPLOO2 NERC TPL.OO2
e. APR 24001111 Union Gap Add 230-115kV Capacity NERC TPL-OO2
f. APR 24005440 Purgatory Flat New 138kV (UAMPS)OATT transmission service request
e. APR 24002551Whetstone 230-l l5kV Sub Phase I NERC TPL-OO2
h. APR 24005792 Troutdale Sub 230kV Swtchyd ll5kV Rg Bus NERC TPL-OO2
i. APR 24006434 Sams Valley 500-230kV New Substation NERC TPL-OO2
j. APR 24005218 Fry Sub lnstl 115 kV Capacitor Bank TPL2 NERC TPL-002 / BPA reactive penalties
k. APR 24006772NE Portland Trans Upgrade Load srowth and reliabilitv
1. APR 24009285 Q0092 Cowlitz PUD lnterconnection OATT transmission service request
m. APR 14000046 Cameron Milford 138kV Trns 138-45 Trnsfm Load growth and reliability
n. APR 24002099 Southwest WY Silver Creek Build 138kV Ln ReliabiliW
o. APR 14000051 Black Rock New 230-59kV Substation Load erowth and reliability
p. APR 14000042 Carbon CounW System Reinforcement Load srowth and reliabiliW
q. APR 24003424 Tooele Sub: Rpl Xfmr 1 & 3, Add 138kV So Load growth and reliabiliW
r. APR 24001815 West Point-New 138 kV Line & 40 MVA Sub Load growth and reliabilitv