20221116PAC to Staff 1-6.pdf

Y ROCKY MOUNTAIN
POIAIER
frECE IVED
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lii,\iic i"'usLIC; TIIiTIES COMMISSION
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
November 16,2022
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
ian.norivuki@nuc. idaho. eov (C)
RE ID PAC.E-22.16
IPUC Set I (l-6)
Please find enclosed Rocky Mountain Poweros Responses to IPUC I't Set Data Requests l-6.
Also provided are Attachments IPUC 2 and 3.
If you have any questions, please feel free to call me at [phone].
Sincerely,
--Jsl-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-22-16 / Rocky Mountain Power
November 16,2022
IPUC Data Request 1
IPUC Data Request I
Please explain what the UFERC' column represents in Table No. I in the
Application, how its values are determined, and why the values should be part of
the Company's load forecast.
Response to IPUC Data Request 1
*FERC" sales are sales to wholesale customers generally served under tariffs set
by the Federal Energy Regulatory Commission (FERC) instead of retail rate
schedules. These customers' forecasts are based on historical sales and current
contractual tenns. The load is part ofthe Company's system load served and
therefore part of the Company's system load forecast.
Recordholder:Lee Elder
Sponsor:Lee Elder
PAC-E-22-16 / Rocky Mountain Power
November 16,2022
IPUC Data Request 2
IPUC Data Request 2
Please confirm whether the years are misaligned with the load data in the "Load
Forecast - May 2021" section of Table No. I in the Application. For example,
should the total load for 2022have been 60,810 GWh?
Response to IPUC Data Request 2
Confirmed. The year labels in the May 2021load forecast section in TableNo. I
should have matched the years listed in the May 2022load forecast section. The
load forecast numbers are not affected and are unchanged. Please refer to
Attachment IPUC 2 which provides a corrected version of TableNo. I @ocky
Mountain Power Load Forecast Annual GWh). The Company will file an enatum
to replace page 3 ofthe application with the corrected Table No. l.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-16 / Rocky Mountain Power
November 16,2022
IPUC Data Request 3
IPUC Data Request 3
The following graph compares the 2021 load forecast and the 2022load forecast:
Rocky Mountain Power Load Forecast
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(a) Please provide a breakdown of the 2021 andthe2022 forecasts by customer
class (residential, commercial, and industrial, etc.) in Excel format.
(b) Please explain the method and basis used to determine the2022 forecast for
each customer class.
(c) Please explain why the 2022 energy forecast is higher than the 2021 forecast.
In the explanation, please identifu the major drivers or causes for each
customer class affecting the change.
Response to IPUC Data Request 3
(a) Please refer to Attachment IPUC 3 which provides the202l and2022
forecasts by customer class (residential, commercial, and industrial, etc.).
(b) The Company's methodology consists of first developing a forecast of
monthly sales by customer class and monthly peak load by state. This sales
forecast becomes the basis of the load forecast by adding line losses, meaning
kilowatt-hour (kWh) sales levels are grossed-up to a generation or "input"
level. The monthly loads are then spread to each hour based on the peak load
forecast and typical hourly load pattems to produce the hourly load forecast.
(c) The 2022 energy forecast is higher than the 2021 forecast due to increased
cooling loads and increased load from vehicle electrification in the residential
class. Commercial and industrial loads are higher primarily due to increased
load from large customers.
Recordholder: Lee Elder
Sponsor:Lee Elder
PAC-E-22-16 / Rocky Mountain Power
November 16,2022
IPUC Data Request 4
IPUC Data Request 4
Table No. 3 lists the start and end date for the Georgetown Irrigation Company
contract being April 1,2022, and March 31,2042, respectively. Please explain
why the contract has a 2l-year term, while the maximum published rate contract
term of PURPA contacts is 20 years.
Response to IPUC Data Request 4
Georgetown Inigation Company contracted dates of April l,2022through March
31,2042 is a 20-year term contract calculated as follows:
Period Covered Contract Year Count
Aoril l. 2022throush March 31.2023 I
Aoril 1.2023 throueh March3l.2024 2
Aoril 1. 2024 throueh March 31. 2025 J
April l, 2025 through March 31, 2026 4
April 1,2026 through March3l,2027 5
April 1, 2027 throush March 31,2028 6
April 1,2028 through Mwch31,2029 7
April 1,2029 through March 31,2030 8
April l, 2030 through March 31, 2031 9
April 1.2031 throueh March3l.2032 l0
April 1.2032 throueh March 31.2033 ll
April l,2033 throueh March 31,2034 t2
April l, 2034 throueh March 31. 2035 l3
April 1.2035 throush March 31.2036 t4
April 1.2036 throush March 31.2037 l5
Aoril l. 2037 throush March 3 l. 2038 t6
April 1.2038 throueh March 31.2039 t7
April l, 2039 through March 3 l, 2040 l8
April l, 2040 through March 31, 2041 t9
April l,2041 through March3l,2042 20
No misstatement of the term of Georgetown Irrigation Company power purchase
agreement (PPA) in Table No. 3 has occurred.
Recordholder:Irene Heng
Craig EllerSponsor:
PAC-E-22-16 / Rocky Mountain Power
November 16,2022
IPUC Data Request 5
IPUC Data Request 5
Order No. 33357 requires utilities to create a queue to track the order in which QF
projects have entered negotiations with a utility to ensure proposed prices
(indicative pricing in the IRP Methodology) are more accurate. Please respond to
the following:
(a) Please describe the types of projects in Rocky Mountain Power's queue.
Specifically, which of the following are included:
o PURPA projects with contracts in negotiation.o Non-PURPA projects with confracts in negotiation.o PURPA projects with signed contracts but not yet Commission approved.o Non-PURPA projects with signed contracts but not yet Commission
approved.o PURPA projects with Commission-approved contracts.
(b) Please describe in detail how Rocky Mountain Power manages its queue
Specially, what criteria are used to determine additions and removals of
projects in the queue?
(c) Please describe in detail how Rocky Mountain Power determines the sequence
of projects in the queue.
(d) Please describe in detail how a QF's position in the queue determines its
indicative pricing.
Response to IPUC Data Request 5
(a) The queue of resources includes two categories:
l. Signed contracts - both Public Utility Regulatory Policies Act of 1978
(PURPA) and non-PURPA, including signed contracts pending
commission approval.
2. Proposed PURPA projects - contracts not yet executed.
(b) Management of the PURPA pricing queue for projects requesting indicative
pricing under the Integrated Resource Plan (lRP) methodology is described in
the Company's Schedule 38 tariff(Qualifying Facility Avoided Cost
Procedures). Information on Schedule 38 is publicly available and can be
accessed by utilizing the following website link:
https://www.rockvmountainpower.net/contenVdam/pcorp/documents/en/rockv
mountainpower/rates-
PAC-E-22-16 / Rocky Mountain Power
November 16,2022
IPUC Data Request 5
regulation/idaho/rates/038_Qualifoinq_Facility_Avoided_Cost_Procedures.pdf
When a PURPA pricing request is received and confirmed to be complete in
accordance with Schedule 38 sections 1.8.2-3, it is added to the end of the
proposed PURPA project queue. Any PURPA pricing requests received and
confirmed complete at a later date are added to the end of the queue. PURPA
projects are removed from their position in the QF pricing queue in
accordance with Schedule 38 section I.B.l0 based on a failure to timely
proceed forward with contracting or specified significant modifications to the
project proposal, including location, project capacity, or scheduled online
date.
PURPA projects with signed but not yet approved contracts are included
ahead of queued PURPA projects, however, such projects would generally
otherwise be higher in the QF pricing queue, so there would not be any net
impact on indicative pricing provided in accordance with Schedule 38 section
I.8.4.
(c) Please refer to the Company's response to subpart (b) above.
(d) Energy costs under the IRP methodology are based on production cost model
results. Optimized dispatch of the Company's resources within the model
means that the highest cost resources are displaced first when an additional
zero-cost resource like a QF is added. When the highest cost resource that is
currently operating above its minimum becomes fully displaced in certain
hours, i.e. when it is backed down to its minimum operating level, the next
highest cost resource will be displaced. As a result, each successive QF
displaces resources with a cost that is less than or equal to previous QFs,
resulting in lower avoided costs to the extent more QFs are included ahead of
the QF being priced.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil
PAC-E-22-16 / Rocky Mountain Power
November 16,2022
IPUC Data Request 6
IPUC Data Request 6
Please confirm that the final IRP-based avoided cost rates used in a signed
contract (not the initial indicative pricing) are determined based on projects
approved by the Commission at the time when the lRP-based contract is signed,
which do not include "projects in negotiation" or "projects with a signed conffact
but not yet Commission approved".
Response to IPUC Data Request 6
In accordance with the approved Schedule 38 qualifying facility (QF) avoided
cost procedures, developers may execute a contact incorporating their initial
indicative pricing results, so long as it occurs within six months of that pricing
being provided (see section I.8.9). The initial pricing would include "projects in
negotiation" or "projects with a signed contract but not yet Commission
approved".
Projects are not removed from the queue until they fail to proceed timely through
the process, as identified in sections I.B.5, I.B.7, and I.B.l0. If a developer
requests updated pricing, or a pricing update prior to execution is required in
accordance with Schedule 38, only those prior-queued proposals that continue to
timely proceed through the process would be included in the updated pricing
calculation. This can result in updated pricing that continues to include projects
which are not yet commission approved. For example, if the Company receives
two complete pricing requests on the same day, and both continued through the
process on the same schedule, the first request would be included in any pricing
update for the second request all the way through execution.
Recordholder: Dan MacNeil
Sponsor:Dan MacNeil