20221025Staff 1-24 to PAC.pdf

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i .1- i,-' r- 'MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. II7I4
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Street Address for Express Mail:
1 I33I W CHINDEN BLVD, BLDG 8, SUITE 20I-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF A CAPACITY DEFICIENCY
PERIOD TO BE USED FOR AVOIDED COST
CALCULATIONS
CASE NO. PAC-E-22.I4
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Rocky Mountain Power ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, NOVEMBER 15, 2022.
This Production Request is to be considered as continuing, and the Company 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 telephone number of
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER
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I ocroBER 25,2022
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.
REQUEST NO. 1: The Application states "[t]he 2021 IRP Update includes the results
of the Company's Capacity Loads and Resources without Resource Additions in Table 4.2 on
page 47 and is provided as Table No. 1." However, Table 4.2 on page 47 of the 2021 IRP
Update ("Update") does not match Table No. 1 in the Application. Please respond to the
following.
a. Please provide the complete load and resource balance ("L&R") Excel file that
generates the result in Table No. l.
b. Please explain why Table 4.2 onpage 47 of the Update does not match Table
No. I in the Application and justifu all the updates to Table No. l.
REQUEST NO. 2: Please provide the L&R Excel file that generates the result in Table
No. 2. The Excel file should include both the summer deficits and the winter deficits as required
by Order No. 34918.
REQUEST NO.3: Please explain if there have been any updates on the obligation side
and on the resource side of the L&R since the result in Table No. 2 was generated. If yes, please
describe all the updates and provide the associated workpapers. For the updates on resource
side, please only provide the ones that have been authorized by the Commission.
REQUEST NO. 4: Please explain whether the L&R Excel file that generates the result
in Table No. 2 assumes "all current PURPA contracts will be renewed unless the Company has
information about specific contracts to the contrary," as required by Order No. 34918.
REQUEST NO. 5: Please explain whether the L&R Excel file that generates the result
in Table No. 2 uses "the appropriate derate adjustments for each year," as required by Order
No. 34918. If so, please identiff the derate adjustments in the Excel file.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 ocToBER 25,2022
REQUEST NO. 6: Please respond to the following regarding removals of early coal
retirements.
a. Please confirm the L&R Excel file that generates the result in Table No. 2 reflects
the removals of early coal retirements, consistent with Order No. 34918. If so,
please identifu the removals in the Excel file.
b. Please provide the end-of-life retirement dates of each coal plant in the L&R
Excel file that generates the result in Table No. 2 and explain how the dates were
determined.
c. Please confirm whether or not the conversion of Jim Bridger Unit 1 and Unit 2 to
natural gas plants is reflected in the L&R. If the conversion is reflected, please
explain if the capacity amounts of the plants have changed and justifu the
changes.
d. Please explain what changes to the end-of-life retirement dates are being made to
Craig and Hayden in the 2023 IRP and justifu the changes. In addition, please
confirm that these changes are not reflected in the L&R Excel file that generates
the result in Table No. 2 in this case.
REQUEST NO. 7: Please confirm that all the resources and contracts included in the
L&R Excel file that generates the results in Table No. 2 have been approved by the Commission.
If not, please identiff the resources and contracts that have not been approved. (Staff s default
standards in Case No. PAC-E-20-13 stated that resources and contracts, such as Company-owned
resources and long-term generation contracts, should be included in an L&R when authorized.)
REQUEST NO. 8: The L&R Excel file that generates the result in Table No. 2 includes
demand response programs selected as part of the 2021Demand Response Request for
Proposals, including projected growth in those programs over time. Please list these programs
and the amount of capacity each is "projected" to add capacity to the system each year over the
planning horizon.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J ocroBER 25,2022
REQUEST NO. 9: Please respond to the following regarding the existing demand
response programs.
a. Please confirm that the capacity values of the existing demand response programs
are based onaL24-megawatt ("MW") residential/small commercial air
conditioner load control program, a 205-MW irrigation load management
program, and 191-MW interruptible contracts, as described on page 147 of the
2021 IRP.
b. Please explain why Page 45 of the Update states the Company has had
intemrptible contracts for approximately 177 MW of load interruption capability
for many years. Please reconcile the l9l MW and the 177 MW.
c. Please confirm that the capacity values of the existing demand response programs
include projected growth in those programs over time. If so, please explain how
projected growth is determined for each program. If not, please explain how the
capacity values of the existing demand response programs are determined over
the planning horizon.
d. Please explain what causes the difference between the existing demand response
capacity in the 2021 IRP and the existing demand response capacity in the
Update.
REQUEST NO. 10: In the 2019 IRP, the existing demand response programs were split
into two parts: the intemrptible programs and the remaining Class 1 DSM. The intemrptible
programs were used to adjust load on the obligation side, while the remining Class I DSM was
included on the resource side. However, in the 2021 IRP, all the existing demand response
programs were included on the obligation side. Please explain what caused the change and
provide justifications for the change.
REQUEST NO. 11: In Case No. PAC-E-20-13, planning reserves are calculated as
l3o/o* (Load - Private Generation - Energy Efficiency). However, in the 2021 IRP, planning
reserves are calculated as l3olo* (Load - Private Generation - Existing Demand Response - New
Energy Efficiency). In addition, Response to Staff s Production Request No. 8 in Case No.
PAC-E-20-13 stated l3o * (Load - Private Generation - Energy Efficiency) was correct and the
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 4 ocToBER 25,2022
intemrptible load should not be used in the calculation, because these contracts do not carry the
13% planning reserve margin. Please reconcile the two methods and explain why intemrptible
load, as part of the existing demand response, is used in the 2021 IRP. Also, please explain in
detail what is meant by, "these contracts do not carry the l3o/o planning reserve margin" and how
it affects the calculation.
REQUEST NO. 12: Please explain what causes the difference between the capacity
values of Private Generation in the 2021 IRP and the capacity values of Private Generation in the
Update.
REQUEST NO. 13: Page 151 of the 2021 IRP states that the existing energy efficiency
is 73 MW. Response to Staff s Production Request No. 22 (e) in Case No. PAC-E-21-19 states
that73 MW is incorrect and should have been 68 MW. However, page 44 of the Update states
that73 MW is used in the Update. Please explain whether it should have been 68 MW in the
Update.
REQUEST NO. 14: Please explain how the capacity values of Sales are determined and
if the capacity values of Sales in the Update match those in the 2021 IRP. If not, please explain
what causes the difference.
REQUEST NO. 15: The Update combines Sales and Ancillary Services into one line
item. Please respond to the following.
a. Please explain why Sales and Ancillary Services are combined.
b. Please explain why Ancillary Services are not included as a line item in the 2021
IRP. Are they captured in the planning reserve margin? If so, please explain why
they are separated out from the planning reserve margin in the Update.
c. Please define Ancillary Services, describe their role, and explain how their
capacity values are determined. Are they the same as Non-Owned Reserves in
Case No. PAC-E-20-13?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 ocroBER 25,2022
REQUEST NO. 16: Please respond to the following regarding'oContracts" line item in
the Update.
a. Please define "Contracts" in the Update and explain what types of contracts are
included in "Contracts" (such as long-term firm contracts and short-term firm
contracts.)
b. Please explain if all the contracts have been approved by the Commission.
c. Are they the same as "Purchase" in the 2021 IRP? If so, please explain what
causes their capacity values to change between the 2021 IRP and the Update.
REQUEST NO. 17: Please confirm whether the line item "Thermal" in the 2021 IRP
should be the sum of the line item "Coal" and the line item "Gas" in the Update. If so, please
explain why the capacity values of "Thermal" are not always the sum of "Coal" and "Gas."
REQUEST NO. 18: Please explain what causes the difference between the capacity
values of "Hydroelectric" in the 2021 IRP and those in the Update.
REQUEST NO. 19: Please confirm whether the line item "Renewable" in the 2021 IRP
should be the sum of the line item "Solar," "Vy'ind," and "Geothermal" in the Update. If so,
please explain why the capacity values of "Renewable" are not the sum of "Solar," "Wind," artd
"Geothermal" for all the years in the planning horizon.
REQUEST NO. 20: Response to Staff s Production Request No. 13 in Case No. PAC-
E-20-13 defined "uncommitted [Front Office Transactions ("FOTs")] to meet remaining need"
as the amount of FOTs up to the "available front office transactions" that could be used to meet a
capacity deficit. However, both the 2021 IRP and the Update allowed "uncommitted FOTs to
meet remaining Need" to exceed "Available Front Office Transactions." In addition, Response
to Staff s Production Request No. 2l (b) in Case No. PAC-E-2l-19 states that because there are
no proxy resources allowed in the period 2021 through2023, the Company will be reliant on a
higher level of FOTs in the near term. Please respond to the following.
a. Please explain why no proxy resources were allowed in the period from202l
through 2023. Is it due to lack of lead times for resource acquisition?
FTRST PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER 6 ocroBER 25,2022
b. Please explain why in the 2021 IRP the Company had to rely on a higher level of
FOTs in the near term, instead of letting the deficit occur in the near term. Why
did the Company have to "balance the system" in the near term in the 2021 IRP,
as described in Response to Staff s Production Request No. 2l(b) in Case No.
PAC-E-21-19?
REQUEST NO.2l: Table No. 2 in the Application shows that the summer FOT limit is
515 MW, instead of 500 MW shown in the 2021 IRP and the Update. Please respond to the
following.
a. Please provide the updated winter FOT limit.
b. Please explain how the updated summer FOT limit and the winter FOT limit are
determined and provide related workpapers.
c. Please explain whether transmission rights are considered in developing the FOT
limits.
d. Supplemental Response to Staff s Production Request No. 18 (3) in Case No.
PAC-E-21-19 states that, for peak months, the FOT limit is lower than the
transmission limit and is the limiting factor; for non-peak months, the
transmission limit is lower and is the limiting factor. This shows the transmission
limit does not seem to be used in determining the FOT limit. However,
Supplemental Response to Staff s Production Request No. l8 (2) in Case No.
PAC-E-21-19 states that 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. Please reconcile the two statements in terms of the use of transmission
rights in determining the FOT limits.
REQUEST NO.22: Table No. 2 in the Application shows there are 567 MWs of
"Committed FOTs" in2023. Please respond to the following.
a. Please define "Committed FOTs" and describe each of the committed FOT
contracts (i.e., capacity size, parties that the Company contracted with,
timeframes, etc.).
b. Please explain why Committed FOTs are only used for 2023.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 ocToBER 25,2022
c. Please confirm that the reason the FOT limit is not used for 2023 is because the
Commiued FOTs (567 MW) are greater than the limit (515 MW).
REQUEST NO.23: Please explain if Capacity Benefit Margin ("CBM"), which is used
to lower the Company's need for planning reserve margin to cover emergencies, is included in
the L&R Excel file that generates the result in Table No. 2. If not, please provide the Company's
CBM capacrty amounts and explain why they should not be included in the L&R.
REQUEST NO.24: The FOT availability limits in the 20l9IRP were increased by 3%,
while the 2021 IRP did not include these increases. Please explain whether 3% should be used to
determine the FOT availability limits in the L&R Excel file that generates the result in Table No. 2
DATED at Boise,Idatro, this ZC"duy of october2o22
Deputy Attomey General
i:umisc:prodreq/pac*2.L4mdyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOI.]NTAIN POWER 8 ocToBER 25,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF OCTOBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIM COMMISSION
STAFF TO ROCKY MOUNTATN POWER, IN CASE NO. PAC-E-22-14, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi corfcom
RON SCHEIRER
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST, SUITE 2OOO
PORTLAND OR97232
E-MAIL : ron.scheirer@pacifi corp.com
CERTIFICATE OF SERVICE