20220119Staff 1-38 to PAC.pdf

RILEY NEWTON.
DEPUTY ATTORNEY GENERAL -ryIDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11202
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )POWER'S FILING FOR )CASE NO.PAC-E-21-19
ACKNOWLEDGEMENT OF ITS 2021 )INTEGRATED RESOURCE PLAN )
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Riley Newton,Deputy AttorneyGeneral,requests that Rocky Mountain Power provide the
followingdocuments and information as soon as possible,but no later than WEDNESDAY,
FEBRUARY 9,2022.
This Production Request is to be considered as continuing,and Rocky Mountain Power 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 telephonenumber of
the person preparing the documents.Please identify the name,job title,location,and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JANUARY 19,2022
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.
REQUESTNO.1:Please provide a copy of the most current transitional cluster study.
(Volume I -Chapter 4,page 86).
REQUESTNO.2:Please describe in detail the direct benefits to Idaho customers that
are identified in the transitional cluster study.
REQUESTNO.3:The Aeolus-to-Mona transmission line ("Gateway South"),will
provide delivery of new renewable energy resources across the West.Please provide how
Gateway South will connect Idaho customers to the renewable resources when the said
transmission line runs north-south between Wyoming and Utah?(Volume I -Chapter 4,page
86).
REQUESTNO.4:The 2021 preferred portfolio includes "near-term transmission
upgrades"when discussing Boardman-to-Hemingway ("B2H")transmission line.Are the
transmission upgrades necessary prior to B2H coming online?(Volume I -Chapter 4,page 88).
Please explain.
REQUESTNO.5:Please provide the date and times in the last five years when the
Midpoint-to-Summer Lake pathway was capacity constrained for east to west and west to east
directions justifying the need for B2H.
REQUESTNO.7:Please provide an update as to the completion date of the Advanced
Metering Infrastructure currentlybeing deployed in Idaho.Also include when real-time data will
be available to Idaho customers.
REQUESTNO.8:Please provide the financial impact on Idaho from removing Bridger
1 and 2 from Washington's allocation by the end of Q4 2023.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JANUARY 19,2022
REQUESTNO.9:Please provide the projected cost of the Populus-to-Hemingway
transmission project and explain why the project is the least-cost,least-risk alternative for Idaho
ratepayers.
REQUESTNO.10:Please provide the projected cost of the Goshen area projects and
explain why the project is the least-cost,least-risk alternative for Idaho ratepayers.
REQUESTNO.11:Please describe and quantify "ongoing investment in transmission
infrastructure in Idaho".(Volume I -Chapter 4,page 83).
REQUESTNO.12:Please describe in detail project specifics and costs of pumped
hydro listed in the New Storage Resources section of the IRP.(Volume I -Chapter 9,page
295).
REQUESTNO.13:Please provide the "expert third-partynatural gas price forecast"
used in Aurora.(Volume I -Chapter 8,page 227).
REQUESTNO.14:Please provide the source of data used in Figure 8.5 for Natural Gas
Prices.(Volume I -Chapter 8,page 228).
REQUESTNO.15:Please explain the benefits and differences in costs for the new
Itron Riva AMI meters and software to be installed in Idaho.
REQUESTNO.16:Please provide information regarding the source of natural gas for
the converted Jim Bridger units 1 and 2 and copies of any pipeline or futures contracts that are in
place to supply the converted units with natural gas.
REQUESTNO.17:Please provide a copy of the Company's risk management policy
and specifics on natural gas hedging.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JANUARY 19,2022
REQUESTNO.18:Please answer the followingquestions regarding Table 5.8:
Table 5.8 -Maximum Available Fron Office Transactions by Market Hub
Availability Limit (MW)
Market Hub/Proxy FOT Product Type 2021 2019
Summer Winter Summer Winter
(July)(December)(July)(Decernber)
Mid-Columbia (Mid-C)
Flat Anmial or Heavy Load Hour 350 350 Reduced froin 400
Heavv Load Hour 150 0 Reduced from 375
California Oregon Border (COB)
Flat Annual or Heavy Load Hour 0 250 Removedin stuniner only
Nevada OregonBorder (NOB)
Heavy Load Hour 0 100 Removedin summer only
Mona
Heavv Load Hour 0 300 Removedin siumner only
Total 500 1,000 1,425 1,425
a.Please explain how the Front Office AvailabilityLimits values at each hub in both
Summer and Winter in the 2021 IRP are determined and provide workpapers to
support the explanation.
b.Please explain why these availability limit assumptions remain the same throughout
the entire IRP horizon.
c.Page 253 of the 2021 Integrated Resource Plan Volume I states that the preferred
portfolio includes the Energy Gateway South transmission line.Page 133 states the
transmission line can connect into the Mona market hub.Page 324 states that
construction of the transmission line is expected to be completed and placed in
service in 2024.Does the AvailabilityLimit assumption for Mona hub consider the
Gateway South transmission line?Please explain.
d.Page 253 of the 2021 IntegratedResource Plan Volume I states that the preferred
portfolio includes Boardman-to-Hemingway transmission line,which will come
online in 2026.Does the AvailabilityLimit assumption for Mid-C consider the
Boardman-to-Hemingway transmission line?Please explain.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JANUARY 19,2022
REQUESTNO.19:Page 135 of the 2021 Integrated Resource Plan Volume I states that
PacifiCorp evaluated the resources available relative to the expected load in every hour,and the
hour with the lowest resources as a percentage of the hourly load each season determines the
planning reserve margin (PRM)achieved for that season in that year.Page 135 also mentions a
minimum 13 percent PRM target.Please answer the followingquestions:
a.Please confirm that the seasonal PRM is identified and used in the 2021 IRP to
determine the minimum 13 percent PRM target.If not,please explain how the
seasonal PRM is used in the 2021 IRP.
b.Also,please explain step by step how a 13 percent PRM target is determined.
REQUESTNO.20:Page 154 and Page 155 show the Summer Peak System Capacity
Loads and Resources without Resource Additions.Please answer the followingquestions:
a.Please explain how capacity contribution for each of the different types of resources
are determined for purposes of identifyingthe capacity deficiency date.
b.Please explain the purpose of the CF Methodology discussed in Appendix K and how
the results are used in the IRP.
c.Please confirm that the CF Methodology discussed in Appendix K is not used in
determining the first deficit year.
REQUESTNO.21:Please answer the followingquestions regarding Front Office
Transactions in Table 6.11,Table 6.12,and Table 6.13:
a.Please confirm that "Available Front Office Transactions"are based on the values of
the AvailabilityLimits in Table 5.8.
b.Response to Staff Production Request No.13 in Case No.PAC-E-20-13 states that
the term "uncommitted FOTs to meet remaining need"refers to the amount of FOTs,
up to the "available front office transactions"that could be used to meet a capacity
deficit in the initial load and resource balance.Please explain why "Uncommitted
FOTs to meet remaining Need"in the summers of 2021,2022,and 2023 are greater
than "Available Front Office Transactions"as shown in Table 6.11 in the 2021
Integrated Resource Plan Volume I.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JANUARY 19,2022
REQUESTNO.22:The footnote of Table 6.10 states "[d]ue to the timing of the 2021
IRP load forecast,there is a small amount of (68 MW)of existing Class 2 DSM in Table 6.12
(System Capacity Loads and Resources without Resource Additions)."Please answer the
followingquestions:
a.What Class 2 DSM program corresponds to the 68-MW program?
b.Is the program reflected in Line "Existing -Energy Efficiency"in Table 6.11,Table
6.12,and Table 6.13?If so,why are the values in Line "Existing -Energy
Efficiency"smaller than 68 MW and why do the values vary every year?
c.Please explain the timing issue that caused the 68 MW program to not be included in
the load forecast.
d.Would listing the 68 MW existing energy efficiency as a separate line achieve the
same effect as includingit in the Line "Load"?Please explain.
e.Page 151 states that due to timing issues with the vintage of the load forecast,there is
a level of 2020 energy efficiency (73 MW)that is not incorporated in the forecast.
Please reconcile the 68 MW and the 73 MW.
f.Please confirm that Line "New Energy Efficiency"in Table 6.11,Table 6.12,and
Table 6.13 represents energy efficiency programs selected in the portfolio
developmentprocess as resource options.
g.Please explain why new demand response programs are not included in Table 6.11,
Table 6.12,and Table 6.13,while "New Energy Efficiency is included.
REQUESTNO.23:Page 148 of the 2021 Integrated Resource Plan Volume I states that
PacifiCorp obtains the remainder of its capacity and energy requirements through long-term firm
contracts,short-term firm contracts,and spot market purchases.Please explain whether long-
term firm contracts and short-term firm contracts are assumed to be renewed in the load and
resource balances in Table 6.11,Table 6.12,and Table 6.13 and why.
REQUESTNO.24:Please explain whether PURPA contracts are assumed to be
renewed in the load and resource balances in Table 6.11,Table 6.12,and Table 6.13 and why.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 JANUARY 19,2022
REQUESTNO.25:Page 149 of the 2021 Integrated Resource Plan Volume I states that
the hourly system load is reduced by hourly private generationprojections to determine the net
system coincident peak load for each of the first ten years (2021 -2030)of the planning horizon.
Please explain why the hourly system load is reduced by hourlyprivate generationprojections
only for the first ten years,instead of for the entire planning horizon.
REQUESTNO.26:Page 149 of the 2021 IntegratedResource Plan Volume I states the
load and resource balances use assumed coal unit retirements from the preferred portfolio.
Please answer the followingquestions:
a.Please confirm that Table 6.11,Table 6.12,and Table 6.13 are based on the assumed
coal unit retirements from the preferred portfolio.
b.Please list the early retirement dates of each coal unit.
c.Please list the original retirement dates of each coal unit if early retirements are not
assumed and the sources of the determinations.
REQUESTNO.28:Page 149 of the 2021 Integrated Resource Plan Volume I states that
the energy balance shows the average monthlysurplus or deficit of energy over the first ten years
of the planning horizon (2021-2030).Please explain why only the first ten years,instead of the
entire planning horizon,is included.
REQUESTNO.29:Page 152 of the 2021 Integrated Resource Plan Volume I discusses
Demand Response in the load and resource balances.Please answer the followingquestions
regarding Demand Response:
a.Besides "interruptiblecontracts",what other programs are included in "Existing -
Demand Response"category in Table 6.11,Table 6.12,and Table 6.13?
b.What category is energy storage included in the load and resource balances in Table
6.11,Table 6.12,and Table 6.13?
c.How are the values in Line "Existing-Demand Response"determined?
d.Page 152 states that PacifiCorp has had interruptible contracts for approximately 177
MW of load interruptioncapability for many years.Please provide capacity values of
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 JANUARY 19,2022
interruptible contracts for each year for summer and winter and explain how the
values are determined.
e.Please explain why Demand Response (Class 1 DSM)is listed as a resource in the
2019 IRP but is listed as a reduction to load in the 2021 IRP.
REQUESTNO.30:Table 5.12 of the 2019 IRP shows that Planning Reserve =(Load -
Private Generation-Energy Efficiency)x 13%,in which InterruptibleLoad is not used in the
calculation.However in the 2021 IRP,Table 6.11,Table 6.12,and Table 6.13 shows that
Planning Reserve =(Load -Private Generation-Existing Demand Response -Existing Energy
Efficiency -New Efficiency)x 13%where,according to Page 152 in the 2021 IRP,the
interruptible loads are contained in Existing Demand Response and therefore is used in
determining the Planning Reserve.Please reconcile the two ways of calculating planning margin
reserves and explain why netting of the additional items from load is appropriate.
REQUESTNO.31:Page 161 of the 2021 Integrated Resource Plan Volume I lists that,
for energy balance,Existing Resources =Thermal +Hydro +Renewable +Firm Purchases +QF
-Sales;and Obligation =Load +Firm Sales.What is the difference between "Sales"and "Firm
Sales"?
REQUESTNO.32:Page 222 of the 2021 Integrated Resource Plan Volume I states
that,in developing resource portfolios for the 2021 IRP,PacifiCorp included modeling to
endogenouslyselect transmission options in consideration of relevant costs and benefits.Page
242 states that the base transmission topology shown in Figure 8.3 is used in each of the three
Plexos models,and any transmission upgrades selected by LT and ST model processes that
provide incremental transfer capability among bubbles in this topology are part of the portfolio.
Please answer the followingquestions:
a.Please explain whether Boardman-to-Hemingway,Gateway South,and Gateway
West in the preferred portfolio are all selected by models or are assumed in the base
transmission topology.
b.What categories of transmission upgrades are selected by models?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 JANUARY 19,2022
REQUESTNO.33:Page 219 of Appendix K states that the hourlyweighting factors
are applied to the capacity factors of fixed profile resources in the correspondinghours to
determine the weighted capacity contribution value in those hours.Page 218 lists the formula to
calculate CV,which is the overall weighted capacity value of the resource.Please explain the
purposes of weighted capacity contribution value in specific hours and the overall CV,
respectively.
REQUESTNO.34:Page 221 of Appendix K states that the CF Method results are from
a one-year study period of 2030.Please explain why 2030 is selected and if the one-year results
are extrapolatedto other years in the IRP planning horizon.Please explain how it was done.
REQUESTNO.35:Page 129 of Appendix F states that the regulation reserve
forecasting methodology that results in 0.5 loss of load hours per year due to regulation reserve
shortage is appropriate for planning and ratemaking purposes,and that this is in addition to any
loss of load resulting from transmission or distribution outages,resource adequacy,or other
causes.Please explain why 0.5 loss of load hours per year due to regulation reserve shortage is
appropriate.
REQUESTNO.36:What did the Company use as a reliability target,such as LOLE,
LOLH,or LOLP,to ensure the amount of resources are adequate to meet load across the
planning horizon?Then please explain how the Company ensured this reliability target was
measured and met through the Company's modeling methodology and provide the resulting
modeled reliability measurements across the 20-yearplanning horizon for the top three
portfolios.
REQUESTNO.37:Please explain in detail how the Company verified that the final
Portfolios meet the reliability (LOLE,LOLH,or LOLP)target identified in the above target.
REQUESTNO.38:On page 242,the IRP states that "The CRM is a portfolio selection
driver adequate to the capabilities of the LT model.Consistent with past IRPs use of a PRM,the
CRM is not used once the initial portfolio is established.This is because ST reliability
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 JANUARY 19,2022
modifications to the portfolio rely on hourlyresource availability and system requirements to
directly determine reliability shortfalls and any additional resource need at the hourly level."
Please explain the logic used to determine shortfalls and resource additions at an hourlylevel in
the ST model and explain what is included for load obligation and resource capacity amounts
when the ST model performs the hourlycomparisons.
DATED at Boise,Idaho,this I day of January 2022.
Riley Newton
Deputy AttorneyGeneral
i:umise:prodreq/pace21.19tbrk prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 10 JANUARY 19,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF JANUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION
STAFF ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-21-19,BY E-MAILING A
COPY THEREOF,TO THE FOLLOWING:
TED WESTON EMILY WEGENER
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116 SALT LAKE CITY UT 84116
E-MAIL:[e-mail] E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER BENJAMIN J OTTO
E-MAIL ONLY:ID CONSERVATION LEAGUE
[e-mail] 710 N 6TH ST
[e-mail] BOISE ID 83702
E-MAIL:botto idahoconservation.org
ROSE MONAHAN
ANA BOYD
SIERRA CLUB
2101 WEBSTER ST STE 1300
OAKLAND CA 93412
E-MAIL:[e-mail]
[e-mail]
SECRETAR
CERTIFICATE OF SERVICE