20211012PAC to Bayer Supplemental 117.pdf

ROCKY MOUNTAIN
HFHy,e*n*,1407 W North Temple, Suite 330
Salt Lake Ci$, Utah 84116
October ll,202l
Randall C. Budge/Bayer randy@rac ineolson.com (C)
Thomas J. Budge/Bayer tj @racineol son. com (WXC)
Brian C. Collins/Bayer bco I lins@.consu ltbai.com (WXC)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer kh i g gins@.energystrat. com (C)
Lance KaufmanlBayer I ance @.ae e i s i n s i sht. com (C )
James R. Smith/Bayer [e-mail] (C)
Mike Veile/Bayer [e-mail]
Courtney Higgins/Bayer [e-mail]
Milli PicharolBayer m p [e-mail]
Neal Townsend/Bayer [e-mail]
RE: ID PAC-E-21-07
Bayer Set loth (l I l-130)
Please find enclosed Rocky Mountain Power's l't Supplemental Response to Bayer lOs Set Data
Request I17. Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, the ldaho Public Utilities Commission's Rules of Procedure No.
67 - Information Exempt from Public Review, and further subject to the Non-Disclosure
Agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC brmu I I ins@mwan alyti c s.com
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val. ste iner@.itafos.com (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA [e-mail] (C)
Ben Otto/ICL [e-mail] (C)
Ronald L. Williams/PtrC [e-mail]
Bradley G. Mullins/PlC [e-mail]
Adarn Gardncr/PtrC [e-mail] (qry
Kyle lYilliams/PtrC [e-mail] (tV)
Val StoincrlPtrC [e-mail] (1V)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony YankeUIIPA [e-mail] (C)
Brad Pudy bmpurdy@hotnailsom (C)
PAC-E-21-07 / Rocky Mountain Power
October ll,202l
Bayer Data Request I l7 - I't Supplemental
Bayer Data Request 117
Pryor Mountain. Please refer to the Direct Testimony of Rick T. Link, Section
V.
(a) Please identi$ all transmission used to move energy from Pryor Mountain to
and through PacifiCorp's system.
(b) Did the addition of Pryor Mountain increase transmission congestion on
PacifiCorp's system in any of the years modeled?
(c) How did PacifiCorp account for the cost of transmission or transmission
constraints due to Pryor Mountain?
(d) Please provide all transmission studies performed by or on behalf of
PacifiCorp related to Pryor Mountain, including any studies performed prior
to PacifiCorp's acquisition of the project.
(e) Please provide the GRID model results for 2021with and without Pryor
Mountain. Please include energy curtailments by transmission bubble and the
value of curtailed energy. Please also include a graphic representation of the
GRID transmission topology. If the company declines to provide such data,
please provide access to the 2021 GRID model.
(f) Please provide a graphic representation of the transmission topology modeled
in PaR analysis of the referenced testimony. Please explain how the PaR
analysis accounts for transmission constraints.
l't Supplemental Raponse to Bayer Data Request 117
Further to the Company's response to Bayer Data Request I l7 dated September
20,2A2l,the Company provides the following supplemental response relevant to
subpart (e):
On October 6,2021, the Company provided Lance Kaufinan of Aegis [nsight,
(consultant to the P4 Production, L.L.C., an affiliate of the Bayer Corporation)
access to the Generation and Regulation Initiative Decision Tool (GRID) via the
internet and access to the GRID project relevant to the Company's direct
testimony filing, specifically supporting the Direct Testimony of Company
witness, Michael G. Wilding in this proceeding.
Please refer to the confidential work papers supporting Mr. Wilding's direct
testimony for copies of the supporting GRID work papers. In addition to the
confidential GRID work papers, there are also highly confidential GRID work
papers which are deemed commercially sensitive. The Company requests special
PAC-E-21-07 / Rocky Mountain Power
October ll,202l
Bayer Data Request I l7 - l't Supplemental
handling. Please contact Ted Weston at [phone] to make arrangements for
review.
The Company also provided access to the GRID project associated with the
Company's original response to Bayer Data Request I l7 subpart (e).
Access to GRID and its inputs are provided subject to the terms and conditions of
the protective order in this proceeding and may only be disclosed to qualified
persons as defined in that order.
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:Lori Oathes
Sponsor:Michael G. Wilding