20220225Staff 39-46 to PAC.pdf

- .: / _ i'\
' t *'-RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
Street Address for Express Mail:
I I331 W CHINDEN BVLD, BLDG 8, SUITE 201-4
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S FILING FOR
ACKNOWLEDGEMENT OF ITS 2021
INTEGRATED RESOURCE PLAN
CASE NO. PAC.E.ZI-Ig
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCI(Y MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
MARCH 11,2022.r
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.
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I FEBRUARY 25,2022
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
the person preparing the documents. Please identiff 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. 39: Please answer the following regarding the advanced nuclear
NatriumrM demonstration proj ect :
a. Please list and explain the risks of selecting the advanced nuclear NatriumrM
demonstration project as a resource in the Preferred Portfolio, noted in the Updated
2021 IRP, Volume I, Chapter I - Executive Summary,202l IRP Roadmap.
b. For each of the risks listed above, please provide the Company's plans to mitigate
each of the identified risks, including the need for any contingencies.
c. What are the potential risks that could cause the 500 MW advanced nuclear
NatriumrM demonstration project, scheduled to come online by summer 2028, to be
delayed?
d. Please provide the specific checkpoints in the project schedule and the criteria that
would trigger a contingency in case of a potential delay.
REQUEST NO.40: The Company indicates that no new natural gas proxy resources
were made available for selection in any of the Initial Portfolios due to the risk of stranded-costs
associated with planning a system that is reliant on new natural gas resources having a
depreciable life of between 30 to 40 years as noted on page 245, in the Updated 2021 IRP -
Volume I, Chapter 8 - Modeling and Portfolio Evaluation Approach, Initial Portfolios. Please
provide the following:
a. Please identiff the specific resources categorized as "natural gas proxy resources."
b. Did the Company consider an approach where over time the natural gas proxy
resource would transition initially from natural gas as the fuel, to a fuel blend of
natural gas and hydrogen, and then ultimately hydrogen as the final fuel recognizing
SECOND PRODUCTION REQUEST
TO ROCKY MOI-INTAIN POWER 2 FEBRUARY 25,2022
some need for plant upgrades or retrofits2 to the resource over time? If not, why not?
Please explain.
REQUEST NO.41: Please provide the Company's analysis and supporting
documentation used to determine the "line loss factors" contained in section "System Losses"
referenced on page 13, in the Updated 2021 IRP - Volume /d Appendix A - Load Forecast
Details.
REQUEST NO.42: Please list the "consideration of risks" in section "General
Compliance" referenced on page24, in the Updated 2021 IRP - Volume Id Appendix B - IRP
Regulatory Compliance, and explain how they were addressed.
REQUEST NO. 43: Please list the "uncertainties" referenced on page24 of the Updated
2021 IRP - Volume 11, Appendix B - IRP Regulatory Compliance, and explain how they were
addressed.
REQUEST NO.44: Please explain how the Company determined the timeframe (hours,
months, seasons, etc.) that the Company's demand response programs can be dispatched. For
example, did the Company base the timeframe on hours with the highest loss of load probability,
peak load, or some other method? If each program used a different requirement for determining
dispatch timeframes or if the dispatch timeframes are different, please explain the reason for the
differences.
REQUEST NO.45: Please provide the following details for each of the Company's
demand response programs:
a. Jurisdiction
b. Name
c. Directed customer class (i.e. residential, commercial, industrial, or irrigation)
2 https://www.qe.com/content/dam/gepower-new/global/en_US/downloads/sas-new-site/future-of-enerey/hydroeen-
fu el-for-gas-turbines- gea34979.pdf
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J FEBRUARY 25,2022
d. Nameplate capacity (MW)
e. Program Season (summer, winter, year-round)
f. Yearly program cost ($/MW nameplate capacity)
g. Dispatchable periods (i.e. season dates, days of the week, and hours of the day)
h. Dispatch limitations
i. Number of participants
j. Company required notification to participant prior to dispatch (hours)
k. Participant incentive (fixed ($/kW), variable ($&Wh))
l. Participant penalties for opt-out (fixed ($/kW), variable ($/kwh))
m. Program contribution to operating reserves by type (spin, non-spin, frequency, .
etc.)
REQUEST NO.46: Please explain the differences in the capacity factor approximation
method used in the 2019 IRP as compared to the methods used in the 2021 IRP (refer to Volume
11, Appendix K - Capacity Contribution). How does the method used in the202l IRP compare
to the methods contained in the NERC report: Methods to Model and Calculate Capacity
Contributions of Variable Generation for Res ource Adequacy P lanning!
DATED at Boise, Idaho, this 25+A day of Febru ary 2022
/,1,
Riley ewton
Deputy Attorney General
i:umisc:prodreq/pace2 I . I 9tbrk prod req 2
A/ralReliabili
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 FEBRUARY 25,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF FEBRU AF(Y 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSTON STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-21-19, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOLINTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@paci fi corp. com
[e-mail]
ROSE MONAHAN
ANA BOYD
SIERRA CLUB
2IOI WEBSTER ST STE I3OO
OAKLAND CA934I2
E-MAIL: [e-mail]
[e-mail]
EMILY WEGENER
ROCKY MOI.INTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
,,)n/1"O,^,4
SECRETARY
CERTIFICATE OF SERVICE