20220310PAC to Staff Supplemental Responses.pdf

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Salt Lake City, Utah 84116
March 10,2022
Jan Noriyuki
[e-mail]. gov (C)
Riley Newton
riley.newton@puc. idaho. gov
RE: tD PAC-E-21-19
IPUC Set I (l-38)
Please find enclosed Rocky Mountain Power's Supplemental Responses to IPUC's l$ Set Data
Requests 18-22,29,and36. Also provided are Attachment IPUC 20 I't Supplemental.
If you have any questions, please feel free to call me at [phone]
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Rose Monahar/Sierra Club rose.monahan@,sierraclub.org (C)
Ana Boyd/Sierra Club ana. boyd @ s ierraclub.org (C)
Benjamin J. Otto/ICL botto@ idahoconservation.org
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request 18 - ls Supplemental
IPUC Data Request l8
2021 lntegrated Resource Plan (IRP)
Please answer the following questions regarding Table 5.8
(a) Please explain how the Front Office Availability Limits values at each hub in
both Summer and Winter inthe202l IRP are determined and provide work
papers 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 tntegrated 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 in2024. Does the Availability Limit
assumption for Mona hub consider the Gateway South transmission line?
Please explain.
(d) Page 253 of the 2021 lntegrated Resource Plan Volume I states that the
preferred portfolio includes Boardman-to-Hemingway transmission line,
which will come online n2026. Does the Availability Limit assumption for
Mid-C consider the Boardman-to-Hemingway transmission line? Please
explain.
(1) Please clari$ the response to IPUC l8: How are the Front Oflice Availability
Limits values calculated? Is there a work paper that calculates the values? If
so, please provide the work papers that calculate the Front Office Availability
Limits. If no work papers are available, please describe in detail how these
limits are determined. Why does the Available Front Offrce Transaction in
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PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request l8 - I't Supplemental
the Load and Resource Balance inthe202l IRP not receive the 103%o
treatment, whereas that item in the 2019 IRP did? Please confirm that
transmission limits are always greater than the FOT limits.
(2) Please clariff the response to IPUC l8 subpart (c): It states that "Front Office
Availability Limits" does not consider PacifiCorp transmission rights related
to specific transmission projects, as these availability limits are based on an
assessment of market depth and liquidity at the markets. However,Page ll4
of the 2021 IRP states that in developing FOT limits physical delivery
constraints is considered. Please reconcile these two statements.
(3) Please clariff the response to IPUC l8 subpart (c): It states that FOTs are
defined for the peak months of June and December and do not change over the
2D-year horizon in those months, and that transmission changes can impact
purchases and sales limits in non-peak months, which are otherwise not
subject to the FOT limits and are constrained by available transmission. Why
are peak months subject to FOT limits, and why are the non-peak months
subject to transmission limits?
(4) Please clari$ the response to IPUC 18 subpart (d): It states that B2H
transmission addition does not connect to the Mid-C market in PacifiCorp's
2021 IRP topology and does not affect market depth. Please explain why it
doesn't.
I't Supplemental Response to IPUC Data Request 18
Further to the Company's response to IPUC Data Request l8 dated February 9,
2022, and the request for clarification received from the Idaho Public Utilities
Commission (IPUC) Staffon March 3,2022,the Company provides the following
supplemental response:
(l) The Company did not prepare a work paper for the transmission limits but did,
inthe202l lntegrated Resource Plan (IRP), Volume 5 (Reliability and
Resiliency), page I l4 provide Table 5.8 (Maximum Available Front OfIice
Transaction Quantity by Market Hub) for the discussion on determining
"Front Office Availability Limits". The following is quoted.
In developing FOT limitsfor the 2021 IRP, PacifiCorp reviewed the
studies described in the sections above as part of its assessment of marlcet
reliance in addition to consideration of its active participation in
wholesale power markets, its view of physical delivery constraints, ond
marlret liquidity and market depth. The 2021 IRP FOT limtts are 1,000
MW in the winter, and 500 MW in the summer, reducedfrom 1,425 MW in
the 2021 IW. These reductions are due to an assumption of zero summer
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request 18 - I't Supplemental
liquidity at COB, NOB, ond Mono, as well as decreased liquidity at Mid-C
in both Flot Annual and Heavy Lood Hour.
The 3 percent adder to front office transactions (FOT) was not reported in the
load and resource balance for the 2021 IRP that reflects the seller holding 3%
percent reserves on FOT purchases. The Company confirms that its modeled
transmission rights are always equal to or greater than the assumed FOT
limits.
(2) The statement "Front Office Availability Limits" does not consider PacifiCorp
transmission rights related to specific transmission projects as the 2021 IRP
transmission projects did not connect directly to the markets. Transmission
rights are considered in developing the FOT limits in order to move the FOT
energy on a firm basis into the Company's system.
(3) Limits to transmission rights are applied to all months. For peak months the
FOT limit is lower than the transmission limit so is the limiting factor. Non-
peak months are limited by the transmission rights.
(4) The Company's existing access from the Mid-Columbia (Mid-C) market to its
system already exceeds the modeled FOT limit. In order for the FOT limit to
increase at the Mid-Columbia (Mid-C) market more resources would need to
be added by other companies that are deliverable to this location. Because the
Boardman-to-Hemingway (B2H) transmission project does not connect the
Company's system directly into the Mid-C market, there is no additional
transmission to access energy from the market and move into the Company
system.
Recordholder:Dan Swan
Sponsor:Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request 19 - l't Supplemental
IPUC Data Request 19
2021 lntegrated Resource Plan (IRP)
Page 135 of the 2021lntegrated 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 following questions:
(a) Please confirm that the seasonal PRM is identified and used in the 2021 IRP
to determine the minimum l3 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.
Request for Clarification (received March 3. 2022) - as follows:
(l) Please clari$ the response to IPUC 19 and IPUC 36: Given the differences
between the 20l9IRP and the202l IRP, such as the load difference and the
FOT limit difference, is it appropriate to apply the l3% planning reserve
margin identified in the 2019IRP to the modeling process in the 2021 IRP?
How does the Company ensure its reliability target is met for the top
performing portfo I ios ?
(2) Please clari$ the response to IPUC l9: How is the "4.5Yo to 5.5%o"
determined? Does the 4.5%oto 5.5Yo of resources in reserve as regulating
margin correspond to 0.5 loss of load hours per year due to regulation reserve
shortage discussed on Page 129 of Appendix F of the 2021 IRP. Does this*4.5yoto 5.5o/o" correspond to the study result of Flexible Reserve Study in
Appendix F of the 2019 IRP?
I't Supplemental Response to IPUC Data Request 19
Further to the Company's response to IPUC Data Request l9 dated February 9,
2022, and the request for clarification received from the Idaho Public Utilities
Commission (IPUC) Staffon March 3,2022,the Company provides the following
supplemental response:
(l) Yes, is it appropriate to apply the 13 percent capacity reserve margin which
was carried over from PacifiCorp's 2019 lntegrated Resource Plan (IRP) and
applied to the 2021 tRP in the PLEXOS long-term (LT) model as a starting
position. This l3 percent margin is considered a floor, or minimum, which is
not generally subject to change. To measure reliability, a short-term (ST)
initial study was performed using the LT portfolio to account for energy not
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request 19 - I't Supplemental
served (ENS) that was used for reporting reliability. This informed the
additional megawatt (MW) proxy resources are required to be added to the
portfolio to meet reliability. Depending on the length of the ENS events,
resources added are solar*storage, non-emitting peakers, and nuclear. The LT
study was then re-run with the reliability resource additions to finalize the
portfolio as well as the ST study that ensure reliability is met. Please also see
the response to IPUC Data Request 19 - subpart b, below.
(2) PacifiCorp must hold approximately six percent of its resources in reserve to
meet contingency reserve requirements and 4.5 percent to 5.5 percent of its
resources in reserve, depending upon system conditions at time of peak load,
to meet regulating margin. This sums to 10.5 percent to I 1.5 percent of
operating reserves before even considering longer term uncertainties such as
extended outages (transmission or generation) and customer load growth. The
4.5 percent to 5.5 percent was calculated from the 10.5 percent to I 1.5 percent
planning reserve margin (PRM) less the 6 percent contingency reserves. The
4.5 percent to 5.5 percent represents the incremental PRM to cover changes in
loads, change in thermal generation, and changes in hydro generation.
Recordholder:Dan Swan / Adam Kennedy
Shay LaBraySponsor
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request 20 - l$ Supplemental
IPUC Data Request 20
2021 lntegrated Resource Plan (IRP)
Page 154 and Page 155 show the Summer Peak System Capacity Loads and
Resources without Resource Additions. Please answer the following questions:
(a) Please explain how capacity contribution for each of the different types of
resources are determined for purposes of identiffing the 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.
Reouest for Clarification (received March 3.2022) - Please clariff the response
to IPUC 20: [t states that the analysis of capacity contribution is hourly and based
on the portfolio as a whole. What is the portfolio? Please describe this process in
detail and provide examples to illustrate the process. [s the capacity contribution
of existing resources based on additional resources added to meet a deficit?
lst Supplemental Response to IPUC Data Request 20
Further to the Company's response to IPUC Data Request 20 dated February 9,
2022, and the request for clarification received from the tdaho Public Utilities
Commission (IPUC) Staffon March 3,2022,the Company provides the following
supplemental response:
The load and resource balance analysis described in the Company's response to
IPUC Data Request 20 and presented in PacifiCorp's2021Integrated Resource
Plan (tRP), Volume I, Chapter 6 (Load and Resource Balance) reflects the
Company's 2021 IRP preferred portfolio, P02-MM-CETA. For details on the
resources in that portfolio, please refer to the confidential data disk accompanying
the 2021 IRP, specifically folder "LT studies CONF.zip\LT studies\LT Plan
Summary\CETA", file "18609 2ltRP 20yr_P02-MM-CETA .xlsx".
For a description of the process used in the load and resource balance analysis and
presented inthe202l IRP, Volume I, Chapter 6 (Load and Resource Balance),
please refer to the page 150 in that chapter. A simplified example is provided in
Attachment IPUC 20 I't Supplemental. [n the example, the "Peak Load" hour has
a large difference between load (including the 13 percent planning reserve margin
(PRM) and derated thermal availability), however this is spread across a
relatively large quantity of resources that are available in that hour, particularly
solar, so the attribution to each megawatt (MW) of resources is reduced. In the
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request 20 - I't Supplemental
'Net Load Peak" hour, the difference between load and thermal availability is
smaller, but there are relatively few resources available, so the attribution to each
MW of resources in that hour is slightly higher. In the "Mid Load" hour, the
difference between load and thermal availability is small, and there many
resources available, both of which make the attribution to each MW of resources
in that hour small. In the "Low Load" hour, thermal resource availability exceeds
load, so there is no capacity allocation to other resources.
Under the method used in the load and resource balance analysis and presented in
the202l IRP, Volume I, Chapter 6 (Load and Resource Balance), after capacity
attributed to thermal resources is removed (based on their derated availability, i.e.
after accounting for forced outages), all remaining capacity, up to the lesser of the
minimum hourly reserve margin or 13 percent, was spread among all other
resource types, including both existing commitments and proxy resources
identified as part of the preferred portfolio. As a result, the capacity identified for
existing resources is impacted by the composition of the rest of the portfolio in a
given year. For the purposes of reporting the "existing" commitments, the
quantities attributed to proxy resources are removed from the figures and no
changes were made to the capacity attributed to existing resources.
Recordholder:Dan MacNeil
Sponsor Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request 2l - I't Supplemental
IPUC Data Request 21
2021 lntegrated Resource Plan (IRP)
Please answer the following questions regarding Front Office Transactions in
Table 6.1l, Table 6.12, and Table 6.13:
(a) Please confirm that "Available Front Office Transactions" are based on the
values of the Availability Limits in Table 5.8.
(b) Response to StaffProduction Request No. l3 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 oflice transactions" that could be
used to meet a capacity deficit in the initial load and resource balance. Please
explain why "Uncommiued FOTs to meet remaining Need" in the summers of
2021,2022, and2023 are greater than "Available Front Office Transactions"
as shown in Table 6.1I in the202l Integrated Resource Plan Volume [.
Reouest for Clarification (received March 3.2022) - The response to IPUC 2l
subpart (a) states the "Available Front Office Transactions" limits are used in the
PLEXOS model. The response to IPUC 2l subpart (b) states that the
"Uncommitted FOTs to meet remaining need" in202l through 2023 arc greater
than "Available Front Office Transaction" limits due to need to balance the
system and that the Company will be reliant on a higher level of FOT in the near
term. Please answer the following questions:
(l) How can the Company be reliant on a higher level of FOT in the near term,
when the market cannot provide the amount of energy that the Company
needs? In other words, how can the Available Front Office Transaction limits
be exceeded?
(2) ln the PLEXOS model, can the limits be exceeded?
l't Supplemental Response to IPUC Data Request 21
Further to the Company's response to IPUC Data Request 2l dated February 9,
2022, and the request for clarification received from the Idaho Public Utilities
Commission (IPUC) Staffon March 3,2022, the Company provides the following
supplemental response:
(l) The FOT limits are a planning assumption and reflect a long-term view of the
appropriate level of reliance markets over 20 years. Based on the results of
past [RPs, the Company's ponfolio currently reflects a higher level of reliance
on markets. [n actual operations, the Company always attempts to procure the
least-cost resources to serve customers and may make purchases in excess of
the long-term FOT limits assumed in the IRP to balance the system.
PAC-E-21-19 /Rocky Mourfiain Power
March 10,2022
IPUC Data Request 2l - ls Supplenrental
(2) The PLD(OS model was set-up withthe 2021 Integrated Resourco Plan (RP)
FOT limits, therefore PLEXOS will not make market prohases in excoss of
the FOT limits. When insufficient resouroes are available to serve load and
meet reserve requiroments, the PLEXOS model rcports ehortfall amounts as
"Energy Not Served" or "Reserre Shortfalls" and assigns a high price to the
associated volumes
Recordholder: Dan Swan
Sponsor:Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request22 - I't Supplemental
IPUC Data Requst22
2021 lntegrated Resource Plan (IRP)
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 following questions:
(a) What Class 2 DSM program corresponds to the 68 MW program?
(b) Is the program reflected in Line "Existing - Energy Efficiency" in Table 6.1l,
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 including it in the Line "Load"? Please explain.
(e) Page l5l 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.ll,Table 6.12,
and Table 6.13 represents energy efficiency programs selected in the portfolio
development process as resource options.
(g) Please explain why new demand response programs are not included in Table
6.1 l, Table 6.12, and Table 6.13, while "New Energy Efficiency is included.
Request for Clarification (received March 3. 2022) - The response to IPUC 22
subpart (c) states this timing issue occurs because 2020 is the first year of forecast
within the load forecast used in the2021lRP. EE potential selections are made
for the 2021 through 2040 timeframe in the IRP planning process, and therefore,
the existing 2020E,8 selections must be accounted for in the IRP. Please answer
the following questions:
(l) The load forecast in the 2021 IRP starts in year 2021. Please explain why
2020 is the first year of the load forecast.
(2) What does "existingZ020 EE selections" mean? Does it refer to EE selected
in2020 that will last for the entire planning horizon?
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request22 - l't Supplemental
l't Supplemental Response to IPUC Data Request22
Further to the Company's response to IPUC Data Request 22 dated February 9,
2022, and the request for clarification received from the Idaho Public Utilities
Commission (IPUC) Staffon March 3,2022, the Company provides the following
supplemental response:
(l) The original response should have stated that because of the timing for
locking down assumptions in Pacifi Corp' s 2021 Integrated Resource Plan
(IRP), the load forecast does not include an adjustment for the 2020 historical
energy efliciency (Class 2 Demand-Side Management (DSIO).That is why
the Company included the2020 forecasted energy efficiency @xisting -
Energy Efficiency) in the 2021 IRP.
(2) Yes, the existing energy efficiency represents the forecasted2OzO energy
efliciency that will last for the entire planning horizon.
Recordholder: Brian Osborn
Sponsor:Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request}4 - I't Supplemental
IPUC Data Request}4
2021 lategrated Resource PIan (IRP)
Please explain whether PURPA contracts are assumed to be renewed in the load
and resource balances in Table 6.1l, Table 6.12, and Table 6.13 and why.
Request for Clarification (received March 3.2022) - The response to IPUC 24
states that inthe 2021IRP the only existing qualiffing facility that the Company
assumes will renew their contracts are cogeneration facilities associated with large
industrial loads. Please answer the following questions:
(l) Are all cogeneration facilities associated with the large industrial loads?
(2) If not, please confirm that the cogeneration facilities without large industrial
loads will not renew in the load and resource balance.
(3) Order No. 34918 states that all current PURPA contracts will be renewed
unless the Company has information about specific contracts to the contrary,
Please explain why the load and resource balance does not follow this order.
l't Supplemental Response to IPUC Data Request24
Further to the Company's response to IPUC Data Request 24 dated February 9,
2022, and the request for clarification received from the Idaho Public Utilities
Commission (IPUC) Staffon March 3,2022,the Company provides the following
supplemental response:
(l) No. The Company has some small cogeneration QFs for which no separate
treatment to extend contracts consistent with their load has been applied.
Only those QFs associated with large industrial loads, which are separately
identified in the Company's load forecasting process, were extended.
(2) Confirmed, other than those associated certain large industrial loads, no other
QFs were assumed to renew in the load and resource balance.
(3) Idaho Public Utilities Commission OrderNo.349l8 directed the Company to
assume all current PURPA contracts will be renewed unless the Company has
information about specific contracts to the contrary in its next capacity
deficiency case. The Company will comply with the Commission's order in
that filing, which is expected to be filed following the acknowledgement of its
2021 IRP.
Recordholder:Dan Swan
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request24 - I't Supplemental
Sponsor:Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request2g - I't Supplemental
IPUC Data Request 29
202llntqrated Resource Plan (IRP)
Page 152 of the 2021lntegrated Resource Plan Volume I discusses Demand
Response in the load and resource balances. Please answer the following
questions regarding Demand Response:
(a) Besides "intemrptible contracts", what other programs are included in
"Existing - Demand Response" category in Table 6.1l, Table 6.12, and Table
6.13?
(b) What category is energy storage included in the load and resource balances in
Table 6.1l, 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 intemrptible contracts for
approximately 177 MW of load interruption capability for many years. Please
provide capacity valuesof intemrptible contracts for each year for summer and
winter and explain how the values are determined.
(e) Please explain why Demand Response (Class I DSM) is listed as a resource in
the 2019 IRP but is listed as a reduction to load in the 2021 IRP.
Request for Clarification (received March 312022) - Please clarifications the
response to IPUC 29 (the attachment) that shows Intemrptible Load amounts from
the preferred portfolios.
(l) Please confirm that the amounts used in the load and resource balance in
Table 6.1I and Table 6.l2,that do not breakout Intemrptible Load Amounts
from DR, are the same amounts in the attachment.
(2) Please confirm that these forecasts in the attachment are based on existing
intemrptible load customers.
(3) Please confirm that the intemrptible load contracts are assumed to renew in
the load and resource balance.
I't Supplemental Response to IPUC Data Request 29
Further to the Company's response to IPUC Data Request 29 dated February 9,
2022, and the request for clarification received from the Idaho Public Utilities
Commission (IPUC) Staffon March 3,2022, the Company provides the following
supplemental response:
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request2g - I't Supplemental
(l) Yes. As stated in the Company's original response, the amounts in
Attachment IPUC 29 represent the Summer Peak megawatts (MW) and
Winter Peak MW for intemrptible contracts that are reported as a component
of the demand response (DR) in Table 6.1 I (Summer Peak - System Capacity
Loads and Resources without Resource Additions) and Table 6.12 (Winter
Peak - System Capacity Loads and Resources without Resource Additions).
(2) Yes, the amounts in Attachment IPUC 29 represent existing intemrptible load
customers.
(3) Yes, for the 2021 Integrated Resource Plan (IRP) planning horizon, the
Company assumed the existing intemrptible contracts renew.
Recordholder:Brian Osborn
Sponsor:Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 10,2022
IPUC Data Request 36 - I't Supplemental
IPUC Data Request 36
2021 lntegrated Resource Plan (IRP)
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-year
planning horizon for the top three portfolios.
Request for Clarification (received March 3.2022) - Please clariff the response
to IPUC l9 and IPUC 36: Given the differences between the 2019 IRP and the
2021 IRP, such as the load difference and the FOT limit difference, is it
appropriate to apply the l3o/o planning reserve margin identified in the 20l9IRP
to the modeling process inthe202l IRP? How does the Company ensure its
reliability target is met for the top performing portfolios?
l't Supplemental Response to IPUC Data Request 36
Further to the Company's response to IPUC Data Request 36 dated February 9,
2022, and the request for clarification received from the Idaho Public Utilities
Commission (IPUC) Staffon March 3,2022, the Company provides the following
supplemental response :
Please refer to the Companyos l" Supplemental response to IPUC Data Request
19.
Recordholder Dan Swan / Adam Kennedy
Shay LaBraySponsor: