20221115PAC to Staff 1-24.pdf

ROCKY MOUNTAIN
PiOWER
i.iICE IVED
il:? t{0V 15 Ptl hr I I
,,',?i-i n'C##fi 18t' o*1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
November 15,2022
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
[e-mail]. eov (C)
RE:TDPAC.E.22.14
IPUC Set I (l-24)
Please find enclosed Rocky Mourtain Power's Responses to IPUC I't Set Data Requests 1-24.
Also provided is Attachment IPUC 12- I . The Confidential Attachments IIPUC I , 4, 8, and l2-2
are provided via BOX. 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.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-lsl-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request I
IPUC Data Request 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. I ". However, Table 4.2 onpage 47 of
the202l IRP Update (Update) does not match Table No. I 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 andjustiff all the updates to TableNo. l.
Response to IPUC Data Request I
(a) Please refer to Confidential Attachment IPUC l.
(b) The first five lines in Table No. I in the Application have the same numbers
as Table 4.2 onpage 47 of the 2021Integrated Resource Plan (RP) Update,
excepting that the Table No. I from the Application does not include 2022.
The available front office transactions (FOT) shown in the Application have
been grossed up by 3 percent to account for 3 percent contingency reserves
held by the counterparty to the fiansaction, which would be necessary for it to
be considered "firm". This was not accounted for in the 2021IRP Update.
The202l IRP Update also assumed that a higher level of reliance on FOTs
would not necessarily represent a deficit in the first few years of the study
period, hence no deficit was shown until 2025. For the Application, the
Company showed the capacity deficit in all years.
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.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
P AC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC DataRequest 2
IPUC Deta Roqueot 2
Please providc the L&R Excel file tlrat gereratss tho result in Table No. 2. The
Excel file should include both the summeJ defioits and the winter deficits as
required by OrderNo. 34918.
Response to IPUC Dah Request 2
Please refer to the Company's rcqrcnse to IPUC Data Request l, qpecifically
Confidmtial Attachment IPUC 1.
Recordholder: Dan ivlacNeil
Sponmr:Dan MrcNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 3
IPUC Data Request 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.
Response to IPUC Data Request 3
The Company assumes that the reference to "authorized by the Commission" is
intended to be a reference to the Idaho Public Utilities Commission (IPUC).
Based on the foregoing assumption, the Company responds as follows:
Table No. 2 primarily reflects assumptions from the202l Integrated Resource
Plan (IRP) Update. PacifiCorp's2023IRP is currently underway, and the draft
load forecast has a significant increase relative to the 2021 IRP Update
assumptions. The change in the load forecast in the 2023 IRP primarily reflects
new customer demand, and also accounts for climate change impacts which result
in higher system peak demand. Please refer to the presentational materials from
PacifiCorp's2023lRP public input meeting held on July 14,2022 I July 15,2022,
specifically slides 4 through 9. The presentational materials are publicly available
and can be accessed by utilizing the following website link:
https://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorp/enerey/i
ntesrated-resource-plan/2023-imlPacifiCorp 2023 IRP PIM Julvl4-
t5J022.pdf
Because the 2023lRP is still underway and the assumptions are preliminary, the
Company does not have an updated version of Table No. 2 at this time. However,
as the updated load forecast is projected to be higher, it would not change the
resource deficiency date proposed in the filing.
Please refer to the Company's response to IPUC Data Request l, specifically
Confidential Attachment IPUC l, which provides updated resource information,
specifically areas with green highlighting within that file, and the totals in rows 8l
through 84 of the summer and winter load and resource summary tabs. None of
the recently signed resources require the approval of the IPUC. While the
Company has acquired resources for 2023, it is not sufficient to eliminate the
deficiency shown in 2023.
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 4
IPUC Data Request 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.
3491 8.
Response to IPUC Data Request 4
Because of the immediate timing of the proposed deficiency period, the
Company's filing reflects the actual status of current Public Utility Regulatory
Policies Act of 1978 (PURPA) power purchase agreements (PPA), i.e. whether it
is currently effective in2023, rather than a projection of renewals through a future
deficiency date.
For a list of contracts that have been entered or renewed since the Company's
filing, please refer to the Company's response to IPUC Data Request I and
Confidential Attachment IPUC l, tab "Adjustments".
For a list of additional PURPA PPAs that could potentially renew and provide
capacity during the summer of 2023, please refer to Confidential Attachment
IPUC 4. Note: this list does not include resources that have typically entered non-
firm (NF) contracts and thus do not commit to providing capacity. The Company
would also note that the aggregate nameplate capacity of these resources is less
than20 megawatts (MW), and that the capacity contribution would be
proportionately less, such that it would not impact the proposed deficiency period
timing.
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.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 5
IPUC Data Request 5
Please explain whether the L&R Excel file that generates the result in Table No. 2
uses "the appropriate derate adjusfrnents for each year" as required by Order No.
34918.If so, please identiff the derate adjustnents in the Excel file.
Response to IPUC Data Request 5
Please refer to the Company's response to IPUC Data Request 1, specifically
Confidential Attachment IPUC l. The derated coal plant capacrty by year is
shown in columns E through L of tab "2IIRPU CONF".
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 6
IPUC Data Request 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 identifo 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 I 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 justify
the changes.
(d) Please explain what changes to the end-of-life retirement dates are being made
to Craig and Hayden in the 2023lRP and justiff 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.
Response to IPUC Data Request 6
(a) Confirmed. Please refer to the Company's response to IPUC Data Request l,
specifically Confidential Attachment IPUC l, columns C through E in tab
"Adjustments" for the list of retirements that were removed.
PacifiCorp's2021Integrated Resource Plan (lRP) Update used the same coal
retirement dates as the 2021 IRP. For details, please refer to PacifiCorp' s 2021
IRP, Volume I, Chapter I (Executive Summary), page 15. PacifiCorp's2021
IRP is publicly available and can be accessed by utilizing the following
website link:
lrttps://www.pacificorp.com/content/dam/pcom/documents/en/pacificom/ener
sy/intesrated-resource-olanl2O2l -irp/Volum e%o20lYo20-
%209 . I 5 .202 lYo2lF inal.pdf
Note: the Company has limited flexibility to negotiate retirement dates for
minority owned units and did not evaluate altematives to the dates listed. As a
result, the Company's IRP modeling does not contemplate an end-of-life
retirement date for these units, they were extended indefinitely in the results
shown in Table No. 2.
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 6
Among the Company's majority-owned units, only Naughton Unit I and
Naughton Unit 2 had what might be considered a retirement in the 2021 IRP,
as these units are required to cease coal-fired operation by 2025 due to
obligations related to their coal combustion residual (CCR) ponds. Naughton
Unit I and Naughton Unit 2 are candidates for gas conversion in PacifiCorp's
2023 IRP and are assumed to be able to continue operating in2026 through as
late as 2036.
All of the other coal retirement dates identified in the 2021 IRP that were not
already mentioned reflect end-of-life assumptions used in the 2021 IRP.
(b) Please refer to the Company's response to subpart (a) above.
(c) Confirmed. In the 2021IRP Update, the conversion of Jim Bridger Unit I and
Jim Bridger Unit 2 from coal to gas was not expected to result in a change in
the capacity of the plants.
(d) For details on the proposed coal resource options and assumptions for the
2023 IRP, please refer to the presentational materials from PacifiCorp's2023
IRP public input meeting held on September 1,2022 / September2,2022,
specifically slides 19 through 31. The presentational materials are publicly
available and can be accessed by utilizing the following website link:
https://www.pacificom.com/content/dam/pcorp/documents/en/pacificorp/ener
ev/inteerated-resource-plan/2023-irpllRP PIM Sept%20 I -2 2022.pdf
As discussed in the Company's response to subpart (a) above, Table No. 2 in
this case reflects the capacity from Craig and Hayden indefinitely.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 7
IPUC Data Request 7
Please confirm that all the resources and contacts included in the L&R Excel file
that generates the results in Table No. 2 have been approved by the Commission.
Ifnot please identiff the resources and contracts that have not been approved.
(Staffs 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).
Response to IPUC Data Request 7
The Company assumes that the reference to "approved by the Commission" is
intended to be a reference to the Idaho Public Utilities Commission (IPUC).
Based on the foregoing assumption, the Company responds as follows:
Please refer to the Company's response to IPUC Data Request l, specifically
Confidential Attachment IPUC l. Each of the contracts which are required to be
prospectively approved by the tdaho Public Utilities Commission (IPUC), have
received approval in final orders, as indicated in column F on tab "Adjustments."
This only applies to qualiffing facility (QF) power purchase agreements (PPA)
delivering to the Company within the state of ldaho. Details on these and other
signed contracts are included on that same tab.
For other confact types, the Company is not clear what constitutes "approval by
the Commission". The Company will not seek to include new owned resources in
retail rates until the resources are scheduled to go into service, potentially within a
forecasted test period, but generally much more than a year into the future.
Besides the aforementioned ldaho QFs, other new contacts would not be
reflected in rates or have costs approved by IPUC until filed as part of an Idaho
general rate case (GRC) or included in actual net power costs (NPC) in an Idaho
energy cost adjustment mechanism (ECAM) filing.
The load and resource balance from Table No. 2 includes recently signed
contracts and resources selected to the final shortlist (FSL) in PacifiCorp's2020
All-Source Request For Proposals (2020AS RFP), including both owned and
contracted resources which, because of their expected start dates, would not yet
have been subject to IPUC approval. These projects include 1,792 megawaffs
(MW) of wind, 1,150 MW of solar additions, and 639 MW of battery storage
capacity - 439 MW paired with solar and a 200 MW standalone battery. For
details on the capacity provided by these resources, please refer to the Company's
response to IPUC Data Request l, specifically Confidential Attachment IPUC l,
tab "2IIRPU CONF".
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 8
IPUC Data Request 8
The L&R Excel file that generates the result in Table No. 2 includes demand
response programs selected as part of the 2021 Demand 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.
Response to IPUC Data Request 8
Please refer to Confidential Attachment IPUC 8, specifically tab "Energy-
Limited". Programs are listed in column C, maximum capacity is listed in column
M, and the summer and winter contribution values are listed in columns Z and
AA, respectively.
Confidential information is provided subject to protection under TDAPA
31.01.01.067 and 31.01 .01.233, the ldatro Public Utilities Commission's Rules of
Procedure No. 67 - lnformation Exempt from Public Review, and furttrer subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 9
IPUC Data Request 9
Please respond to the following regarding the existing demand response
proglams:
(a) Please confirm that the capaclty values of the existing demand response
programs are based on a L24-megawatt ('MW') residentiaUsmall commercial
air conditioner load control program, a 205-MW inigation load management
program, and l9l-MW intemrptible conffacts, as described on page 147 of the
2021 IRP.
(b) Please explain why Page 45 of the Update states the Company has had
intemrptible contacts for approximately 177 MW of load intemrption
capability for many years. Please reconcile the l9l MW and the 177 MW.
(c) Please confirm that the capacrty values of the existing demand response
programs include projected growth in those progfttms over time. If so, please
explain how projected growth is determined for each program. If not, please
explain how the capacity values ofthe existing demand response progftrms 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.
Response to IPUC Data Request 9
The Company has not yet completed a reconciliation of the capacity values for
individual resources in PacifiCorp's 2021Integrated Resource Plan (IRP) and the
2021 IRP Update. The Company would also note that the distinction between
nameplate or maximum capacity and capacity contibution is not always clearly
identified. The Company will supplement this response when the reconciliation
has been completed.
Capacity values identified in the load and resource balance are intended to reflect
each resource's contribution to reliable system operation. With increasing reliance
on variable energy resource and duration-limited storage resources, the periods of
greatest system reliability risks have moved away from periods of peak system
load, for example, from sunny summer aftemoons to dark sufilmer evenings. As a
result while solar resources may be providing capacity during the aftemoon,
other resources such as batteries will be necessary to ensure reliable operation in
the evening when the net load peak (load net of wind and solar generation) is
highest, when solar output is lower. Both groups of resources are necessary and
there is no conclusive methodology for allocating the capacity value between
solar resources with a high contribution during the coincident peak (CP) and other
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 9
resources with a high contribution during the net load peak.
In both the202l IRP and the202l IRP Update, the contribution from thermal
resources is based on their derated availability, i.e. their maximum output during
periods when they are not experiencing forced outages. This is expected to be
uniform across a day, and thus is not dependent on the composition of the rest of
the portfolio.
For the 2021 IRP, the remaining capacity, up to the achieved planning reserve
margin (PRM), was allocated among other resource types on an hourly basis, with
the proportion of capacity need in excess of the thermal unit contribution in ttre
numerator, and the availability of all resources in that hour in the denominator.
Based on this methodology, the total capacity need in the peak load hour (on a
surnmer aftemoon) is higher than in the net load peak hour (on a summer
evening), however, it is spread among a relatively large quantity of available
resources, as there is a relative excess of solar at that time. During the net load
peak hour, there are generally just enough resources available to ensure reliable
system operation, so the contribution of each is proportionately higher.
For the 2021 IRP Update, the allocation of capacity was more closely aligned
with the resource capacity allocation methodology proposals in the Western
Resource Adequacy Program (WRAP), which included an allocation based on
average availability during the top 5 percent of net load hours. The WRAP
allocation methodology also uses a number of Effective Load Carrying Capability
(ELCC) studies, which are very resource intensive, to delineate capacity values
for different resource Wpes, including wind, solar, and run-of-river hydro. As a
proxy for the ELCC results, the 2021IRP Update used average availability in the
top 5 percent of load hours (i.e. starting the CP), to allocate the capacity need
between the CP and the net load peak to those resources whose output was higher
during the top 5 percent load hours than during the top 5 percent net load hours,
which primarily applies to solar.
Details on the WRAP capacity allocation methodology are publicly available and
can be accessed by utilizing the following website link:
https://www.westempowemool.ore/private-med ialdocuments/202 I - I 2-
2I_MPC Minutes.pdf
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request l0
IPUC Data Request 10
In the 2019 IRP, the existing demand response progfttms were split into two parts:
the intemrptible programs and the remaining Class I 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.
Response to IPUC Data Request 10
The distinction between programs included as credits to the obligation and those
included on the resource side is that those included as credits to the obligation will
not have ttre planning reserve margin (PRM) applied.
ln PacifiCorp's2021Integrated Resource Plan (lRP), the PRM represents the
cumulative impact of the following requirements:
Contingency reserve requirements (spinning and non-spinning), equivalent to
approximately 6 percent of load, as 3 percent of the requirement is applied to
the generation necessary to serve load, except to the extent it is held by a
counterparty to support the Company's firm market purchases.
Load uncertainty: stochastic variation in load, which may be higher or lower
than normal or median conditions.
Hydro uncertainty: stochastic variation in streamflow that can increase or
decrease hydro generation, relative to normal or median conditions.
Thermal forced outage uncertainty: stochastic thermal unit outages result in
periods with above or below average thermal availability.
Regulation reserve requirements: additional operating reserves necessary to
compensate for uncertainty and intra-hour variation in load and resources.
Other than the contingency reserve obligation of 6 percent, each of the other
requirements that contribute to the PRM requirement are related to uncertainty
and do not tanslate into a single percentage value. Any one of these other
categories may drive a need for a 13 percent PRM in some circumstances, while
in other circumstances, it may reduce the overall requirements, for example,
higher forced outages will sometimes occur during periods with below normal
loads. Demand response (DR) programs reduce load, which results in reduced
contingency reserve obligations while the programs are being called. Those
programs may also provide greater benefits when load is unexpectedly high, for
example during a period of high air conditioner (A/C) demand, A/C control
a
a
a
a
a
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request l0
programs will have more demand to curtail and a greater effective impact. To the
extent a DR program has a short notice time and can be called within an hour, it
could also reduce regulation reserve requirements. These categories likely
represent the majority of the risk mitigation addressed via the PRM, though not all
of it. The level of risk mitigation will also vary with the type of load in the
program - programs that control loads that are weather dependent are likely to
have a larger benefit on load uncertainty than programs that contol loads that are
always on or volatile but not impacted by weather.
With increasing penetration of energy-limited resources, including DR and battery
storage, the effective contribution from such resources is diminished. For
example, as more four-hour duration resources are added, the probability of
outage events lasting one or two hours will go down, but the probability of outage
events lasting five hours or more will likely go up. This is particularly true if the
energy-limited resources are replacing retiring thermal resources which do not
have any duration limits. The 2021 IRP only includes the capacity contribution of
DR as a credit to the obligation, based on its effective duration, and including
existing DR, as shown in the Company's response to IPUC Data Request 8,
specifically Confidential Attachment IPUC 8. This reduces the contribution from
DR resources but means that inclusion prior to accounting for the PRM is more
reasonable, as the estimate is not overstated as it was in the past when it did not
account for duration limits of DR resources.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request I I
IPUC Data Request 11
ln Case No. PAC-E-20-13, planning reserves are calculated as l3o/o* (Load -
Private Generation- Energy Efficiency). However, nthe202l IRP, planning
reserves are calculated as l3%* (Load - Private Generation- Existing Demand
Response -New Energy Efficiency). In addition, Response to Staffs Production
Request No. 8 in Case No. PAC-E-20-13 stated l3o/o* (Load - Private Generation
- Energy Efficiency) was correct and ttre 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 13% planning
reserve margin" and how it affects the calculation.
Response to IPUC Data Request 11
Please refer to ttre Company's response to IPUC Data Request 10.
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 12
IPUC Data Request 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.
Response to IPUC Data Request 12
The capacity value for private generation @G) is equal to the forecasted load
reduction at the time of the system coincident peak (CP). This method was used in
both PacifiCorp's 2021 Integrated Resource Plan (lRP) and the 2021 IRP Update.
For details, please refer to the tab "Peak Loads" of the following files on the data
disks supporting the 2021 IRP and 2021 tRP Update filings:
2021 IRP - non-confidential data disk; specifically folder "Chapters and
Appendices\Chapter 6 - Load and Resource Balance", file "Table 6.12-6.13 Fig
6.2,6.5-6.8.x1sx".
2021 IRP Update - confidential data disk; specifically folder "Chapters and
Appendices CONF\Chapter 4 - Load and Resource Balance Update CONF", file
"Fig4.3,4.4,Tbl4.24.3, 57252 LandR Figures and Tables CONF.xlsx".
For ease of reference, copies of the above referenced 2021 IRP 12021IRP Update
work papers are provided herewith as Attachment IPUC l2-l and Confidential
Attachment IPUC l2-2.
The PG forecast only reflects the load impacts of new participants, while the load
forecast reflects the load of existing customers, inclusive of the effects of their
PG. For the202l IRP Update, actual participants in2020 and their associated
load impacts were incorporated in the underlying load forecast. As a result, the
forecast of new PG participants was rolled forward to start in 2021, rather than
2020.
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.
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 13
IPUC Data Request 13
Page 151 of the 2021 IRP states that the existing energy efficiency is 73 MW.
Response to Staffs Production Request No. 22 (e) in CaseNo. PAC-E-21-19
states that 73 MW is incorrect and should have been 68 MW. However, page M
of the Update states that 73 MW is used in the Update. Please explain whether it
should have been 68 MW in the Update.
Response to IPUC Data Request 13
Please refer to the Company's response to IPUC Data Request 9.
Note: the Company will supplement its response to IPUC Data Request 9 (and its
response to this data request if deemed necessary) when the reconciliation of
individual items in he 2021 Integrated Resource Plan (RP) and 2021 Integrated
Resource Plan (IRP) Update has been completed.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC DataRequest 14
IPUC Data Request 14
Please explain how the capacrty values of Sales are determined and if the capacity
values of Sales in the Update match those in the 2021IRP. If not, please elplain
what causes the difference.
Response to IPUC Data Request 14
Please refer to the Company's response to IPUC Data Request 9.
Note: the Company will supplement its response to IPUC Data Request 9 (and its
response to this data request if deemed necessary) when the reconciliation of
individual items in the 2021 Integrated Resource Plan (IRP) and 2021 lntegrated
Resource Plan QRP) Update has been completed.
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 15
IPUC Data Request 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?
Response to IPUC Data Request 15
(a) "Ancillary Services" represents the provision of operating reserves by
PacifiCorp to wholesale customers in accordance with its Open Access
Transmission Tariff(OATT). For example, the Company is required to
provide spinning and non-spinning reserves to generators and loads within its
balancing authority areas (BAA) in Schedule 5 and Schedule 6 of its tariff.
Because it represents capacity held on behalf of a third-party, this is
comparable to a wholesale sale.
(b) "Ancillary Services" were not broken out in PacifiCorp's 2021 Integrated
Resource Plan (lRP), and as a result were effectively part of the effective
planning reserve margin (PRM) used to identify the total system capacity
Breaking out this category slightly increases both the obligation and the
resources by an equivalent amount.
(c) Please refer to the Company's response to subpart (a) above. Yes.
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 16
IPUC Data Request 16
Please respond to the following regarding "Contracts" line item in the Update:
(a) Please defure "Contracts" in the Update and explain what types of conffacts
are included in "Contacts" (such as long-term firm contracts and short-term
firm confracts.)
(b) Please explain if all the contracts have been approved by the Commission
(c) Are they the same as "Purchase" nthe202l IRP? If so, please explain what
causes their capacity values to change between the202l IRP and the Update.
Response to IPUC Data Request 16
Please refer to the Company's response to IPUC Data Request 9.
Note: the Company will supplement its response to IPUC Data Request 9 (and its
response to this data request if deemed necessary) when the reconciliation of
individual items in the 2021 lntegrated Resource Plan (IRP) and202l Integrated
Resource Plan (RP) Update has been completed.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request l7
IPUC Data Request 17
Please confirm whether the line item "Thermal" in the 2021 IRP should bethe
sum of the Iine item "Coal" and the line item uGasu in the Update. If so, please
explain why the capacity values of "Thermal" are not always the sum of "Coal"
and "Gas".
Response to IPUC Data Request 17
Please refer to the Company's response to IPUC Data Request 9.
Note: the Company will supplement its response to IPUC Data Request 9 (and its
response to this data request if deemed necessary) when the reconciliation of
individual items in the 2021 Integrated Resource Plan (IRP) nd 2021 Integrated
Resource Plan (RP) Update has been completed.
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request l8
IPUC Data Request 18
Please explain what causes the difference between the capacity values of
"Hydroelectric" in the 2021 IRP and those in the Update.
Response to IPUC Data Request 18
Please refer to the Company's response to IPUC Data Request 9.
Note: the Company will supplement its response to IPUC Data Request 9 (and its
response to this data request if deemed necessary) when the reconciliation of
individual items in the202l Integrated Resource Plan (IRP) and202l Integrated
Resource Plan (IRP) Update has been completed.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 19
IPUC Data Request 19
Please confirm whether the line item "Renewable" in the202l IRP should be the
sum of the line item "Solar," "Wind," and "Geothermal" in the Update. If so,
please explain why the capacrty values of "Renewable" are not the sum of
"Solar," 'Win{' and "Geothermal" for all the years in the planning horizon.
Response to IPUC Data Request 19
Please refer to the Company's response to IPUC Data Request 9
Note: the Company will supplement its response to IPUC Data Request 9 (and its
response to this data request if deemed necessary) when the reconciliation of
individual items in $e2021Integrated Resource Plan (IRP) and202l Integrated
Resource Plan (IRP) Update has been completed.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 20
IPUC Data Request 20
Response to Staffs Production Request No. 13 in CaseNo. PACE- 20-13 defined
"uncommitted [Front Office Transactions ("FOTs")] to meet remaining need" as
the amount of FOTs up to the "available front oflice 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. 2 I
(b) in Case No. PAC-E-21-19 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 ttre 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?
(b) Please explain why in the202l 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 Staffs Production Request No. 2l(b) in
Case No. PAC-E-21-19?
Response to IPUC Data Request 20
(a) Yes. Both resource procurement and transmission interconnection processes
limit the Company's ability to bring on new resources in the first few years.
(b) Reliable operation requires that the Company have resources sufficient to
serve all retail load at all times, as well as additional resources necessary to
meet all of its operating reserve requirements. While the load and resource
figure could show a deficiency in the near term, the Company would
necessarily need to have sufficient resources, and only market resources
would be available for that purpose. The Integrated Resource Plan (tRP) load
and resource balance is primarily focused on long-term resource decisions
over the entire 20-year study horizon and does not have options to address
requirements in the first few years, as indicated in the Company's response to
subpart (a) above.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 2l
IPUC Data Request 21
Table No. 2 in the Application shows that the summer FOT limit is 515 MW,
instead of 500 MW shown inthe202l 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 Staffs Production Request No. l8 (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 Staffs Production Request No. l8 (2) in
Case No. PAC-E-2 I - I 9 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.
Response to IPUC Data Request 21
(a) The updated winter front office transaction (FOT) limig inclusive of the 3
percent increment associated with the avoided contingency reserve obligation
when making firm market purchases, is 1,030 megawatts (MW), as shown in
the Company's response to IPUC Data Request l, specifically Confidential
Attachment IPUC l, tab *Wtr Peak L&R".
(b) The development of the FOT limis is discussed in chapter 5 of PacifiCorp's
2021Integrated Resource Plan (lRP), Volume I, Chapter 5 (Reliability and
Resiliency). FOT limits cannot exceed PacifiCorp's physical delivery
constraints and are further reduced to the extent regional resource adequacy
concerns indicate potential risks in market liquidity and market depth.
(c) Transmission rights are considered in the FOT limits. Specifically, the
Company's IRP modeling includes firm transmission rights (generally
consistent with PacifiCorp energy supply management's (ESM) existing
reservations) that are greater than or equal to the FOT limit and which allow
market purchases to be delivered to serve the Company's retail load.
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC DataRequest 2l
(d) Transmission access is necessary, but not sufficient to enable FOTs to
contibute to the reliable operation of PacifiCorp's system. As an example, the
Califomia-Oregon Border (COB) limit of 250 MW is less than the Company's
firm scheduling rights because derates on the Califomia-Oregon Intertie (COI)
frequently reduce the Company's ability to import from the COB market. The
Company's firm rights to the other markets points are generally higher than
the FOT limits because resource considerations are of greater concem. In
actual operations, the availability of tansmission and ofwilling sellers
determines the volume and location of market purchases. Price, inclusive of
short-term transmission costs, is also a consideration to extent there are
multiple options.
Note: PacifiCorp's 2021 IRP is publicly available and can be accessed by utilizing
the following website link:
Inteerated Resource Plan (pacificorp.com)
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 22
IPUC Data Request22
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 commiued 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.
(c) Please confirm that the reason the FOT limit is not used for 2023 is because
the Committed FOTs (567 MW) are greater ttran the limit (515 MW).
Response to IPUC Data RequqtZ2
(a) The referenced fransactions are short-term firm (STF) physical purchases. For
details, please refer to the Company's response to IPUC Data Request l,
specifically ConfidentialAttachment IPUC l, tab "STF CONF".
(b) PacifiCorp's hedging policy calls for reductions in open positions over time,
and for electricity this generally begins 12 months to 18 months in advance.
As shown, on tab "STF CONF" referenced in the Company's response to
subpart (a) above, since the Company's filing was prepared, it has begun
entering transactions for Ql 2024.
(c) Confirmed. While the Company expects to acquire short-term resources to
meet any remaining load obligations in all periods, the calculated load and
resource balance would require more front office transactions (FOT) than the
limit assumed in PacifiCorp's 2021lntegrated Resource Plan (lRP).
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 23
IPUC Data Request 23
Please explain if Capacity Benefit Margin (CBiO, which is used to lower flre
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 capacity amounts and explain why they should not be
included in the L&R.
Response to IPUC Data Request 23
Generally, "Capacity Benefit Margin" (CBM) refers to additional transmission
transfer capability reserved to ensure generation can reach load to maintain
system reliability. For example, immediately after a generator forced outage,
other generators holding contingency reserves must be able to deploy that
capacity, increasing their output so as to replace all lost generation. Congestion on
the transmission system that prevents those deployments would create reliability
issues. Transmission outages or derates could also create congestion that would
create reliability issues.
PacifiCorp's2021 Integrated Resource Plan (IRP) and202l tRP Update do not
explicitly identiff benefits associated with CBM. The modeling for the IRP
reflects existing firm scheduling rights of PacifiCorp's energy supply
management (ESM) (i.e. merchant / generation) function, and projections of
future rights following transmission upgrades. Transmission outages and derates
are not modeled, nor is CBM that could be deployed during such conditions.
Because the incremental resource requirements associated with restricted
transmission availability are not included, further reductions in resource needs
associated with CBM are not appropriate.
Recordholder:Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-14 / Rocky Mountain Power
November 15,2022
IPUC Data Request 24
IPUC Data Request24
The FOT availability limits in the2019IRP were increased by 3%o, while fte
2021 IRP did not include these increases. Please erylain whether 3% should be
used to determine the FOT availability limits in ttre L&R Excel file that generates
the result in Table No. 2.
Response to IPUC Data Request24
It is reasonable to account for avoided contingency reserve obligation of3 percent
associated wittr firm market purchases, and ttrat increment was included in the
results presented in Table No. 2. Please refer to the Company's response to IPUC
Data Request l, specifically Confidential Attachment IPUC l, tab "Smr Peak
L&R', row 65.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil