20230120Staff 34-53 to PAC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL ggIDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 SSiON
[phone]
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF ROCKY MOUNTAIN POWER FOR )CASE NO.PAC-E-22-13
AUTHORITY TO IMPLEMENT A )COMMERCIAL AND INDUSTRIAL )DEMAND RESPONSE PROGRAM )THIRD PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than
FRIDAY,FEBRUARY 3,2023.1
This Production Request is to be considered as continuing.The Company,or any person
acting on its behalf,is requested to provide,by way of supplementary responses,additional
documents that the Company or its representatives may later obtain that will augment the
documents or information produced.
'Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER l JANUARY 20,2023
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 also identify 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.
REQUESTNO.34:For the Commercial and Industrial ("C&I")Demand Response
("DR")program,please describe the Company's intended practices regarding the use of the
Integrated Resource Plan ("IRP")avoided cost data to evaluate the cost-effectiveness of its
programs for a given year and for program planning for the next year (i.e.,use the avoided cost
available at program planning for evaluating the cost-effectiveness for that given year,use the
most current avoided cost at time of evaluation,etc.).
REQUESTNO.35:In response to Production Request No.7,the Company states the
mega-watt amounts committed for participation in the C&I DR program provides value as a
contingency reserve even when events are not actively being called.In review of the Company's
response to Production Request No.26,Staff notes the value provided to non-event hours is
attributed to "5 Regulation Reserve"which on average during the year is significantlyhigher
than either spin or non-spin contingent reserves.With respect to the valuation differences please
address the following:
a.Please fully explain the differences (i.e.benefits and/or constraints)between
contingent spin and non-spin reserves compared to regulation reserves.
b.In actual system operation how are contingent spin and non-spin reserves
dispatched compared to regulation reserves.
c.Please fully explain the Company's justification for valuingthe C&I DR program
during non-event hours using regulation reserves.
REQUESTNO.36:Please recalculate the C&I DR program's avoided cost provided in
response to Production Request No.26 using the hourly contingent spin reserve amounts instead
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JANUARY 20,2023
of the hourlyregulation reserve amounts and show the difference.Further,please provide
justification for using the higher amount.
REQUESTNO.37:Please explain the Plexos Preferred Portfolio baseline forecast
model data and how it is used to determine the C&I DR program avoided cost in response to
Production Request No.26.
REQUESTNO.38:Please explain the Company's approach for considering the C&I
DR program benefit in the baseline forecast model specific to Idaho versus:1)the PACE
Balancing Authority Area and 2)the total PacifiCorp system.
REQUESTNO.39:Please explain how the baseline model data provided in response to
Production Request No.26 includes the proposed C&I DR program specific to Idaho.
REQUESTNO.40:In reference to the workpapers provided in Response to Production
Request No.26,please provide the basis,supporting calculations,and an explanation of how the
Company isolated the Transmission &Distribution ("T&D")avoided costs specific to Idaho.
REQUESTNO.41:In reference to the workpapers provided in Response to Production
Request No.26,please explain how the "Goshen"shadow market price is representative of the
avoided cost of energy for the entire Idahojurisdiction.
REQUESTNO.42:In reference to the workpapers provided in Response to Production
Request No.26,please explain how the "East 3 spinning"and "East 5 Regulation"reserves
classified as "System"in the "Reserve"input sheet are representative of the Idahojurisdiction.
REQUESTNO.43:In reference to the workpapers provided in Response to Production
Request No.26,please explain how the calculation isolates the avoided cost value of contingent
reserves from spinning and regulation reserve inputs.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JANUARY 20,2023
REQUESTNO.44:In reference to the workpapers provided in Response to Production
Request No.26,shown on the "Calc"tab,please confirm that there are no "non-spinning"
reserve values and provide an explanation why they are not used in the calculations.
REQUESTNO.45:In reference to the workpapers provided in Response to Production
Request No.26,shown on the "Calc"tab,why are spinning reserves and non-spinning reserves
included in the "Total Hourly Value of Event"calculation and not the "Total Hourly Value of
Event Reserves"calculation?
REQUESTNO.46:In reference to the workpapers provided in Response to Production
Request No.26,please provide the Company's defmition of the reserve type associated with
"East 3 Spinning"reserve,the relevant North American Electric Reliability Corporation
("NERC")standard it is based on,and how the proposed program function provides that benefit.
REQUESTNO.47:In reference to the workpapers provided in Response to Production
Request No.26,please provide the Company's definition of the reserve type associated with
"East 5 Regulation"reserve,the relevant NERC standard it is based on,and how the proposed
program function provides that benefit.
REQUESTNO.48:In reference to the workpapers provided in Response to Production
Request No.26,please explain how the "Operating reserves"and "SCCT EIM Benefit"in sheet
"Capacity"differ from the reserves accounted for by the "Reserves"sheet?Where are these
numbers sourced,supported,and calculated?Please explain why "Operating Reserves"are
removed in this way,but reserves are added to the avoided cost using hourlydata from the
"Reserves"sheet.Please further explain whether the "Operating reserves"and "SCCT EIM
Benefit"values of the "Capacity"sheet overlap with the reserves accounted for by the
"Reserves"sheet.
REQUESTNO.49:In reference to the workpapers provided in Response to Production
Request No.26,please explain the source and reasoning for removing the "Operating Reserves"
and "SCCT EIM Benefit"shown on tab "Capacity."
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JANUARY 20,2023
REQUESTNO.50:In reference to the workpapers provided in Response to Production
Request No.26,please explain the basis for using the "Avoided generation capacity costs -2019
IRP,Bayer Contract"in the spreadsheet.
REQUESTNO.51:Please explain the basis for using "30 hours"in the top 30 high
energy price hours in the model,while the other 30 hours are assumed to be on hand for potential
reserve dispatch.
REQUESTNO.52:Are all costs shown on tabs "Energy"and "Reserve"devoid of any
capacity cost?Please explain.
REQUESTNO.53:The yearly program avoided cost provided in Production Request
No.26 show a clear downward trend for both "E+C"and reserve components over the forecasted
5-year period.While these numbers will be updated in subsequent IRP's,the downward trend is
concerning.How does the Company plan to retain the program benefit as it experiences the
predicted decrease in avoided costs over the coming years?
DATED at Boise,Idaho,this day of January 2023.
Michael Duval
Deputy Attorney General
i:umisc:prodreq/pace22.13mdrkjjt prod req 3
THIRD PRODUCTIONREQUEST
TO ROCKY MOUNTAIN POWER 5 JANUARY 20,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF JANUARY 2023,
SERVED THE FOREGOING THIRD PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.
PAC-E-22-13,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER JOE DALLAS
MICHAEL S SNOW ROCKY MOUNTAIN POWER
ROCKY MOUNTAIN POWER 825 NE MULTNOMAH ST,SUITE 2000
1407 WEST NORTH TEMPLE STE 330 PORTLAND OR 97232
SALT LAKE CITY UT 84116 E-MAIL:[e-mail]
E-MAIL:[e-mail]
[e-mail]
DATA REQUEST RESPONSE CENTER THOMAS J.BUDGE
E-MAIL ONLY:RACINE,OLSON PLLP
[e-mail] 201 E.CENTER
PO BOX 1391
POCATELLO,ID 83204-1391
E-MAIL:ti racineolson.com
BRUBAKER &ASSOCIATES ERIC L.OLSEN
BRIAN C.COLLINS ECHO HAWK &OLSEN PLLC
GREG MEYER 505 PERSHING AVE.,SUITE 100
16690 SWINGLEY RIDGE RD.,#140 PO BOX 6119
CHESTERFIELD,MO 63017 POCATELLO,ID 83205
E-MAIL bcollins consultbai.com E-MAIL:elo echohawk.com
ameyer consultbai.com
LANCE KAUFMAN,PH.D.
2623 NW BLUEBELL PLACE
CORVALLIS,OR 97330
E-MAIL:lance aegisinsight.com
SECRETARY
CERTIFICATE OF SERVICE