20220315PAC to Sierra Club 3-9.pdf

ROCKY MOUNTAIN
POWER
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March 15,2022
Rose Monahan
Sierra Club Environmental Law Program
2l0l Webster Street, Suite 1300
Oakland, CA946l2
rose.monahan@ sierraclub.org (C)
Ana Boyd
Sierra Club Environmental Law Program
210l Webster Street, Suite 1300
Oakland, CA946l2
[e-mail] (C)
RE ID PAC-E.21.19
Sierra Club Set 2 (3-9)
Please find enclosed Rocky Mountain Power's Responses to Sierra Club's 2nd Set Data
Requests 3 -9. Also provided are Attachment Sierra Club 3-1. Provided via BOX is
Confidential Attachments Sierra CIub 3-2, Sierra Club 4, and Sierra Club 6.
Confidential information is provided subject to protection under IDAPA 31.01.01.067 and
31.01.01.233, 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.
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)
Riley Newton/IPUC ri [e-mail]
Benjamin J. OttoflCL [e-mail]
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
Emily L. Wegener (ISB #l l614)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Facsimile No. [phone]
Emai I : emi ly.wegener@pacifi corp.com
Attorneyfor Roclry Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PACIFICORP'S
APPLICATION FOR
ACKNOWLEDGEMENT OF THE 2O2I
TNTEGRATED RESOURCE PLAN
CASE NO. PAC.E-21.19
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
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I, Emily L. Wegener, represent Rocky Mountain Power in the above captioned matter. I
am a senior attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staffdiscovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response, is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code SectionT4-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the attachments provided with the Company's responses to Sierra Club Set 2 contain
Company proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential information that the information contains Company proprietary information.
I am of the opinion that this information is 'Confidential," as defined by Idaho Code
Swtion 7+101, et seq. and 48-801, and should therefore be protected from public inspectiorL
examination and copying and should be utilized only in ascordance with the terms of the
Prrorcctive Agreement in this proceeding.
DATED this 15th day of March, 2022.
Reqpectfu lly submitted,
!
Emily Wege,net
SeniorAttomey
RockyMountain Power
2
PAC-E-21-19 / Rocky Mountain Power
March 15,2022
Sierra Club Data Request 3
Sierra Club Data Request 3
Please provide an unredacted copy of PacifiCorp's responses to Administrative
Law Judge Mapes and Administrative Law Judge Rowe's Bench Request issued
on February 17,2022 in PacifiCorp's2021IRP filing in Oregon, DocketNo. LC-
77.
Response to Sierra Club Data Request 3
The Company objects to this request as being overly broad, unduly burdensome
and irrelevant. The data request responses produced by the Company in other
jurisdictions are based on information and issues specific to the regulatory
mechanisms approved in those jurisdictions. Notwithstanding the foregoing
objection, the Company responds as follows:
Please refer to Attachment SC 3-l and Confidential Attachment SC 3-2 which
provides copies of PacifiCorp's non-confidential and confidential responses to
ALJ Bench Request Set I (l through 7) in Oregon DocketNo. LC-77 (2021
Integrated Resource Plan (IRP)).
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01 .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.
Recordkeeper:
Sponsor:
Not Applicable
Not Applicable
PAC-E-21-19 / Rocky Mountain Power
March 15,2022
Sierra Club Data Request 4
Sierra Club Data Request 4
Please provide an unredacted copy, including associated work papers, of the
sensitivity model run PacifiCorp conducted on behalf of Oregon Commission
Staffin DocketNo. LC-77, which nemoved minimum take requirements at certain
coal plants and was titled "ST OR Study no JB Minimum".
Response to Sierra CIub Data Request 4
Please refer to Confidential Attachment Siena Club 4.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01 .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.
Recordkeeper:
Sponsor:
Dan Swan
Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 15,2022
Sierm Club Data Request 5
Sierra Club Data Request 5
What is the maximum amount of coal that can be currently stockpiled at both the
Bridger Coal Company mine and at the Jim Bridger plant?
Response to Sierra Club Data Request 5
BCC's existing air quality permit is changing and the new air quality permit has
an effective date of April1,2022. The new permit has lower fugitive dust
emissions than the existing permit and was adjusted to reflect changes associated
with the underground mine closure. Effective April l, 2022, BCC's maximum
stockpile coal storage is 675,000 tons and the maximum sealed stockpile coal
storage is 1,900,000 tons.
The Jim Bridger Plant's existing air quality permit limits coal stockpile inventory
to a maximum of 1.5 million tons of coal at any one time, with the plant annual
average tonnage no more than 1.331 million tons.
Recordkeeper:
Sponsor:
Brad Davis / James Doak
Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 15,2022
Sierra Club Data Request 6
Sierra Club Data Request 6
Please refer to attachment ALJ Bench Request I - I CONF. Please refer to tabs
"ST OR Study no JB Minimum", "ST P02-MM",'oST P02-MM-CETA". Using
the same template, please provide the nameplate and firm capacity provided by
each resource.
Response to Sierra Club Data Request 6
The Company interprets "nameplate" capacity to be the maximum output of a
resource and oofirm capacity" to be the marginal contribution of a resource to
system reliability. Based on the foregoing interpretations, the Company responds
as follows:
Please refer to Confidential Attachment Sierra Club 6 which provides the
maximum capacity (i.e. "nameplate") and derated capacity (i.e. firm capacity) of
each of the Company's existing thermal resources, as identified in the Company's
response to ALJ Bench Request l, specifically Confidential Attachment ALJ
Bench Request l-l in Oregon Docket LC-77 (2021lntegrated Resource Plan
(lRP).Note: A copy of ALJ Bench Request I is provided with the Company's
response to Sierra Club Data Request 3. The derated capacity is calculated as the
maximum capacity multiplied by the quantity of 100 percent minus the forced
outage rate (FOR). In addition to being provided in the attachment, these
modeling inputs are contained on the Company's confidential data disk
accompanying Pacifi C orp' s 2021 IRP, folder "Plexos Inputs CONF.zip". This
formula is also applicable to other resources whose output is not duration-limited
and is available at the same level output in all hours, for instance non-emitting
peaking resources.
Confidential information is provided subject to protection under IDAPA
31.01.01 .067 and 31.01.01 .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.
Recordkeeper:
Sponsor:
Dan MacNeil
Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 15,2022
Sierra Club Data Request 7
Sierra Club Data Request 7
Please explain whether any of the operating characteristics of the Jim Bridger
units were changed for the Oregon sensitivity run ("ST OR Study no JB
Minimum"). Please provide a list of any changes and detailed explanation of each.
Response to Sierra Club Data Request 7
The Jim Bridger units' operating characteristics, such as heat rates, minimum up,
minimum down, and ramp rates, were not changed in the Oregon sensitivity run.
The Bridger fuel was changed from take-or-pay to no minimum fuel requirement.
Recordkeeper:
Sponsor:
Dan Swan
Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 15,2022
Sierra Club Data Request 8
Sierra Club Data Request 8
Please explain whether the ST OR Study no JB Minimum required additional
adjustments for the LT portfolio due to unserved energy. If so, please provide a
list of any resources that were added to the final portfolio.
Response to Sierra Club Data Request 8
This data request assumes that the Oregon sensitivity study only included the
change to Bridger fuel by removing the take-or-pay and replacing with no fuel
minimum. Other changes included additional coal endogenous options for Jim
Bridger Unit 3, Jim Bridger Unit 4, Naughton Unit l, Naughton Unit2,
Huntington Unit I and Huntington Unit 2. Based on the foregoing clarification,
the Company responds as follows:
The proxy resources added to meet reliability after the long-term (LT) initial
study and short-term (ST) initial study run to measure reliability are as follows
and not specific to removing must take fuel requirements:
Reliability shortfalls appear starting in 2033 and have shifted from summer to
winter months:
2033o The longest shortfalls in March and April ran for I I to 13 consecutive hours.
o As a result long duration proxy resources are needed to cover these shortfalls:
The size and duration result in the addition of two non-emitting peakers
and 1,100 megawatts (MW) of sola$storage in Utah South originally
selected inthe 2021 Integrated Resource Plan (tRP) preferred portfolio in
2033.
2036o Shortfalls occur on both the East and West sides of the system:
Restoring the Portland North Coast, Central Oregon and Southern Oregon
proxy resources timing from the 2021 IRP preferred portfolio.
2037o Shortfalls on the West:
Restore the Portland North Coast battery build from the 2021 IRP
preferred portfolio.
2038o Swap Bridger wind for 2021 IRP preferred portfolio Bridger brownfield
builds.
PAC-E-21-19 / Rock,, Mountain Power
March 15,2022
Sierra Club Data Request 8
o Maintain the Hermiston non-emitting pealrer upon Hermiston nanral gas plant
retiroment.
2040o Add non-emitting peaker at Wyodak brcwnlield location
o AddPurnped Storageon West
Rooordkeeper:
Sponsor:
Dan Swan
Shay LaBray
PAC-E-21-19 / Rocky Mountain Power
March 15,2022
Sierra Club Data Request 9
Sierra Club Data Request 9
Please refer to Response to ALJ Bench Request l, which states that coal units
were allowed to retire endogenously. Please provide the revenue requirement,
FOM, and VOM costs that were used for the two units in the same format as the
"Plexos lnput_Existing coal cost 2 I IRP_JB # ]0## ]021 0601 CONF" type of
files from the Master Assumptions work papers.
Response to Sierra Club Data Request 9
The Company assumes that the reference to "two units" is intended to be a
reference to Jim Bridger 3 and Jim Bridger 4. Based on the foregoing assumption,
the Company responds as follows:
Please refer to the confidential work papers accompanying PacifiCorp's2021
Integrated Resource Plan (IRP), specifically folder "Input AssumptionsWlaster
Assumptions\BaseCase", file "Plexos Input Existing coal cost
2IIRP Base 20210602.x1sx".
Recordkeeper:
Sponsor:
Dan Swan
Shay LaBray