20221207Staff 25-34 to PAC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II7I4
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Street Address for Express Mail:
I 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-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
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attomey 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
MONDAY, DECEMBER 12, 2022.1
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
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I DECEMBER7,2022
the person preparing the documents. Please also identifu 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.
REQUEST NO. 25: The Company's response to Production Request Nos. 1,10, and24
discussed the 3%o being applied to Front Offrce Transactions ("FOTs"). Please respond to the
following.
a. Please confirm that this 3oh is required by NERC.
b. Please confirm that the 3Yo contained in the Planning Reserve Margin is intended
to cover the Company's generator outage, while the 3Yo applied to FOTs is
intended to cover third partv's generator outage.
c. Please explain in detail why it is reasonable to apply the 3Yo to FOTs for the
purpose of Load and Resource Balance ("L&R").
REQUEST NO. 26: Response to Production Request No. 3 discussed the load forecast.
Please confirm that the 2021lntegrated Resource Plan ("lIU"'; Update used the same
methodology to determine the load forecast as the 2021 IRP, which did not use the Bureau of
Reclamation Study. If not, please explain what methodology was used to determine the load
forecast in the 2021 IRP Update.
REQUEST NO. 27: The Company's response to Production Request No. 3 discussed
the green highlighted area within Confidential Attachment IPUC l. Please respond to the
following.
a. Please explain whether the contracts in the green highlighted areas need to be
approved by their corresponding Commission(s).
b. For those that need approval, have they been approved yet? Please explain.
c. Generally, do PURPA projects in all territories of the Company need approval
from their corresponding Commissions? Please explain.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 DECEMBER7,2022
REQUEST NO. 28: Response to Production Request No. 4 discussed PURPA renewals
In the L&R, does the Company assume PURPA project renewals in other states' jurisdictions?
Please explain.
REQUEST NO. 29: Response to Production Request No. 4 stated that non-firm
contracts do not commit to providing capacity. Please respond to the following:
a. Please define "non-firm" contracts and provide examples.
b. Please explain why non-firm contracts do not provide any capacity on the
resource side of the L&R. Specifically, from a statistical perspective, do non-firm
contracts provide capacity less than firm contracts but greater than zero? Please
explain.
REQUEST NO.30: Page 15 of the 2021 IRP stated Dave Johnston Units 1-4 will be
retired at the end of 2027. Please respond to the following.
a. 1s2027 an early retirement year for Dave Johnston?
b. If so, what is each unit's end-of-life schedule?
c. lf 2027 is an early retirement year, please explain why Dave Johnston does not
show on Tab "Adjustments" of the Excel File of "Attach IPUC I CONF".
REQUEST NO.3l: Which coal plants are assumed to last indefinitely in the L&R,
besides Craig and Hayden?
REQUEST NO. 32: The Company's response to Production Request No. 8 states that
the L&R includes demand response programs selected as part of the 2021 Request for Proposals.
Please respond to the following.
a. Which selected programs are going to be implemented by the third parties? Are
these programs signed with the Company yet? Do they need Commission
approval in their states?
b. Which selected programs are going to be implemented by the Company? Do they
need Commission approval in their states?
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J DECEMBER7,2022
REQUEST NO. 33: The Company's response to Production Request Nos. 9, 13,14, 16,
17, 18, and 19 discussed reconciliation between the202l IRP and 2021 IRP Update. Also,
response to Production Request No. 9 states that the capacity contribution in the 2021 IRP
Update uses a method closely aligned with the Western Resource Adequacy Program
("WRAP"). Please respond to the following.
a. How is the method used in the202l IRP Update closely aligned with the WRAP
method?
b. What is the difference between the two methods?
c. What needs to be reconciled?
d. Why do they need to be reconciled?
e. How are they being reconciled?
f. When will the reconciliation effort be completed?
REQUEST NO.34: In the 2021 IRP, Ancillary Services are captured in the Planning
Reserve Margin, while, in the 2021 IRP Update, Ancillary Services are broken out as a line item
in the L&R. Response to Production Request No. l5 (b) states breaking out Ancillary Services
slightly increases both the obligation and the resources by an equivalent amount. Please respond
to the following.
a. Please use an example to illustrate "[b]reaking out this category slightly increases
both the obligation and the resources by an equivalent amount."
b. If Ancillary Services is broken out from the Planning Reserve Margin, should
there be an adjustment to the Planning Reserve Margin? Please explain.
DATED at Boise, Idaho, ,ni, f
+q
day of December 2022.
Michael Duval
Deputy Attorney General
i :umisc:prodreq/p ace22.l 4md1ry prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOT]NTAIN POWER 4 DECEMBER7,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OF DECEMBER 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQI]EST OF THE
CoMMISSION STAFF TO ROCKY MOUNTATN POWER, N 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 : ted.weston@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL OIILY:
datarequest@f ac ifi corp.com
RON SCHEIRER
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST, SUITE 2OOO
PORTLAND OR 97232
E-MAIL: [e-mail]
-1",/D-,-,
sECRErA"u/ -
CERTIFICATE OF SERVICE