20230502PAC 1-7 to Staff.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
May 2, 2023 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C) RE: ID PAC-E-23-09
IPUC Set 1 (1-7) Please find enclosed Rocky Mountain Power’s Responses to IPUC 1st Set Data Requests 1-7. Also provided is Attachment IPUC 7. Provided via BOX are Confidential Responses IPUC 1 and 6 and Confidential Attachments IPUC 2, 4, and 5. 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 protective agreement executed in this proceeding. If you have any questions, please feel free to call me at [phone]. Sincerely, ____/s/____
Mark Alder
Manager, Regulation Enclosures
RECEIVED
Tuesday, May 2, 2023 3:11:05 PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-09 / Rocky Mountain Power May 2, 2023 IPUC Data Request 1
IPUC Data Request 1 Please explain the Company's acceleration toward dispatching natural gas fueled generation in late 2022 (i.e. Sep, Oct, Nov, and Dec) compared to its coal fired
generation, when considering the higher dispatch cost of natural gas generation
relative to coal generation during this period. Confidential Response to IPUC Data Request 1

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: Paul Wood / Brent Snyder
Sponsor: Paul Wood
PAC-E-23-09 / Rocky Mountain Power May 2, 2023 IPUC Data Request 2
IPUC Data Request 2 Please provide the duration and amount of generation (in MWh(s)) lost for forced downtime (unscheduled) that Company-owned generation facilities/units
experienced each month during the deferral period. For each forced downtime,
please explain the cause and resolution of the downtime. Response to IPUC Data Request 2

Please refer to Confidential Attachment IPUC 2 which provides the Company’s hydro, thermal and wind generation outage logs for calendar year 2022. Note: the provided outage logs include both planned / maintenance outages and forced outages.
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: Gavin Mangelson / Tom Hickey / Devin Hutchinson Sponsor: To Be Determined

PAC-E-23-09 / Rocky Mountain Power May 2, 2023 IPUC Data Request 3
IPUC Data Request 3 For each of the Company's coal plants, please describe the typical timeline experienced for placing an order for coal to receiving the coal delivery at the
plant.
Response to IPUC Data Request 3
Orders are not placed for individual coal deliveries at the Company’s plants.
Instead, coal is delivered to plants throughout the year based on short-term and long-term contract terms that typically target specific annual volumes. Recordholder: Dan Moody

Sponsor: Dan Moody
PAC-E-23-09 / Rocky Mountain Power May 2, 2023 IPUC Data Request 4

Despite PacifiCorp's diligent efforts, certain information protected from disclosure by the attorney-client privilege or other applicable privileges, or law may have been included in its responses to these data requests. PacifiCorp did not intend to waive any applicable privileges or rights by the inadvertent disclosure of protected information, and PacifiCorp reserves its right to request the return or destruction of any privileged or protected materials that may have been inadvertently disclosed. Please inform PacifiCorp immediately if you become aware of any inadvertently disclosed information.
IPUC Data Request 4 For all Company coal plants, please describe the Company's guidelines for maintaining adequate coal supplies and quantify, for each unit, the supply of coal held on-site for
fueling the unit. Please provide this information in the following units: ton(s), MMBtu(s),
and equivalent MWh(s). Response to IPUC Data Request 4

PacifiCorp maintains system and plant inventory ranges which are reviewed and evaluated periodically by its fuel resources department to determine if the ranges are adequate to provide an economic and reliable supply of fuel to the generating units. These determinations take into account such factors as:
• Potential supply or transportation disruptions
• Coal quality requirements
• Coal market conditions
• Potential labor disruptions
• New environmental laws and regulations
• Uncertainties in weather and carrying costs, etc. Please refer to Confidential Attachment IPUC 4 which provides the targeted coal inventory levels in tons and million British thermal units (MMBtu). The values are provided on a total plant basis instead of individual generating units because coal
inventories are maintained at the plant level and are not assigned to individual units.
Additionally, coal inventory is not tracked in megawatt-hours (MWh) because the MWhs produced when coal is consumed varies depending on factors such as operational characteristics of individual generating units and how the units are dispatched over a
given period of time.
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 Moody
Sponsor: Dan Moody

PAC-E-23-09 / Rocky Mountain Power May 2, 2023 IPUC Data Request 5

Despite PacifiCorp's diligent efforts, certain information protected from disclosure by the attorney-client privilege or other applicable privileges, or law may have been included in its responses to these data requests. PacifiCorp did not intend to waive any applicable privileges or rights by the inadvertent disclosure of protected information, and PacifiCorp reserves its right to request the return or destruction of any privileged or protected materials that may have been inadvertently disclosed. Please inform PacifiCorp immediately if you become aware of any inadvertently disclosed information.
IPUC Data Request 5 For each of the Company's coal units, please provide the average coal supply held for generation per month from 2017 through 2022. Please provide these values in units of
ton(s), MMBtu(s), and MWh(s).
Response to IPUC Data Request 5
Please refer to Confidential Attachment IPUC 5 which provides inventory levels (in tons
and million British thermal units (MMBtu)) for calendar years 2017 through 2022. Coal inventory is not typically tracked in megawatt-hours (MWh) because the number MWhs produced when coal is consumed varies depending on factors such as operational characteristics of individual generating units and how the units are dispatched over a given period of time.
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 Moody
Sponsor: Dan Moody

PAC-E-23-09 / Rocky Mountain Power May 2, 2023 IPUC Data Request 6

Despite PacifiCorp's diligent efforts, certain information protected from disclosure by the attorney-client privilege or other applicable privileges, or law may have been included in its responses to these data requests. PacifiCorp did not intend to waive any applicable privileges or rights by the inadvertent disclosure of protected information, and PacifiCorp reserves its right to request the return or destruction of any privileged or protected materials that may have been inadvertently disclosed. Please inform PacifiCorp immediately if you become aware of any inadvertently disclosed information.
IPUC Data Request 6 Please provide details of any coal supply issues in 2022 that prevented the economic dispatch of a Company coal unit.
Confidential Response to IPUC Data Request 6

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 Moody
Sponsor: Dan Moody

PAC-E-23-09 / Rocky Mountain Power May 2, 2023 IPUC Data Request 7

Despite PacifiCorp's diligent efforts, certain information protected from disclosure by the attorney-client privilege or other applicable privileges, or law may have been included in its responses to these data requests. PacifiCorp did not intend to waive any applicable privileges or rights by the inadvertent disclosure of protected information, and PacifiCorp reserves its right to request the return or destruction of any privileged or protected materials that may have been inadvertently disclosed. Please inform PacifiCorp immediately if you become aware of any inadvertently disclosed information.
IPUC Data Request 7 Please provide the supporting documentation for the Wind Availability Liquidated Damages on line 27 of Exhibit No. 1.
Response to IPUC Data Request 7 Please refer to Attachment IPUC 7.

Recordholder: Jack Painter
Sponsor: Jack Painter