20230920Investigation Responses 1-4.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 20, 2023 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C) RE: ID PAC-E-23-09
IPUC Investigation Set 1 (1-4) Please find enclosed Rocky Mountain Power’s Responses to IPUC Investigation 1st Set Data Requests 1-4. Provided via BOX are Confidential Attachments IPUC Investigation 2 and 3. 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
Wednesday, September 20, 2023 12:51:53 PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-09 / Rocky Mountain Power September 20, 2023 IPUC Investigation Data Request 1
IPUC Investigation Data Request 1 For each of the Company’s coal plant units, provide the actual amount of time in hours each unit was producing and the actual amount of megawatt hours (MWh)
each unit produced for each month during the 2022 deferral year in the ECAM.
Response to IPUC Investigation Data Request 1
The Company assumes that the reference to “2022 deferral year in the ECAM” is
intended to be a reference to the 2023 energy cost adjustment mechanism (ECAM) filed in Case PAC-E-23-09, for deferral calendar year 2022 (January 2022 through December 2022). Based on the foregoing assumption, the Company responds as follows:
Please refer to the Company’s response to IPUC Audit 3, specifically Confidential
Attachment IPUC Audit 3, which provides actual hourly generation data (the Company’s hourly owned-generation logs for calendar year 2022 for all the Company’s owned generating resources (hydro, thermal and wind), including the
Company’s coal units. Note: the information provided has not changed.
Recordholder: Mary Kelly Sponsor: To Be Determined
PAC-E-23-09 / Rocky Mountain Power September 20, 2023 IPUC Investigation Data Request 2
IPUC Investigation Data Request 2 For each of the Company’s coal plant units, provide the hourly dispatch price for each unit and corresponding locational market price ($/MWh).
Response to IPUC Investigation Data Request 2 The Company assumes that this data request is intended to ask for the hourly
dispatch price for the 2023 energy cost adjustment mechanism (ECAM) filed in
Case PAC-E-23-09, for deferral calendar year 2022 (January 2022 through December 2022). Based on the foregoing assumption, the Company responds as follows: Please refer to Confidential Attachment IPUC Investigation 2 which provides
energy imbalance market (EIM) data for calendar year 2022. This attachment
includes EIM dispatch prices (bid prices) and EIM prices (real-time dispatch (RTD) locational marginal prices (LMP) for PacifiCorp East (PACE) and PacifiCorp West (PACW) (EIM load aggregation point (ELAP) prices)).

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: Lynn Pham Sponsor: To Be Determined
PAC-E-23-09 / Rocky Mountain Power September 20, 2023 IPUC Investigation Data Request 3
IPUC Investigation Data Request 3 For each of the Company’s coal plant units for each month of the 2022 deferral year in the ECAM, please provide the actual number of hours each unit was not
producing, and the amount of MWh that could have been produced, broken down
by the following categories:
(a) Unforced outages (planned downtime), i. Provide a short description of the reason for each unforced outage.
(b) Forced outages (unplanned downtime),
i. Provide a short description of the reason for each outage over 24 hours. (c) Unit was uneconomical to dispatch,

(d) Lack of transmission capacity, (e) Partner plant contractual constraints, (f) Regulatory constraints, and

(g) Insufficient coal supply.
In addition, explain the criteria used in providing the breakdown for each of the categories. If there are additional causes, please provide a breakdown using additional categories. Also please provide all results and work papers in Excel
format with all formula enabled.
Response to IPUC Investigation Data Request 3 Rocky Mountain Power (RMP) objects to this request as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible
information. RMP also objects to this request as it seeks analysis that has not been conducted by the Company. Specifically, this request would require the Company to conduct separate analyses of various hypothetical scenarios that did not transpire during the calendar year 2022 and therefore are not pertinent to this proceeding. Notwithstanding the foregoing objections, the Company responds as follows: The Company assumes that the reference to “2022 deferral year in the ECAM” is intended to be a reference to the Company’s 2023 energy cost adjustment
mechanism (ECAM) filed in Case PAC-E-23-09, for deferral calendar year 2022
(January 2022 through December 2022). Based on the foregoing assumption, the Company responds as follows: Please refer to Confidential Attachment IPUC Investigation 3 which provides the Company’s outage log for calendar year 2022 coal unit outages, organized
according to North American Electric Reliability Corporation (NERC) Generating
PAC-E-23-09 / Rocky Mountain Power September 20, 2023 IPUC Investigation Data Request 3
Availability Data System (GADS) standards. The Company notes that copies of the Company’s hydro, thermal and wind generation outage logs for calendar year 2022 were already provided with its
response to IPUC Data Request 2 in this proceeding. For ease of reference, the
Company provides the thermal outage log again, limited to report coal units only. 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

Sponsor: To Be Determined
PAC-E-23-09 / Rocky Mountain Power September 20, 2023 IPUC Investigation Data Request 3
IPUC Investigation Data Request 4 For each month of the 2022 deferral year in the ECAM and using the actual data and the same categorization of non-producing categories in the above requests as a
baseline, please provide the difference in the amount of hours, the difference in the
amount of MWh, and the system and Idaho dollar impact independently for each of the Company’s coal plant units for each of the following:
(a) If the amount of unforced downtime was the same as assumed in current base
rates; (b) If the amount of forced downtime was the same as assumed in current base rates; (c) If there were no coal supply constraints and coal prices were the same as those
assumed in current base rates;
(d) If the amount of transmission was the same as those assumed in base rates;
(e) If regulatory constraints were the same as those assumed in base rates; and
(f) If the contractual constraints were the same as those assumed in base rates.
Please provide all results and work papers in Excel format with all formula enabled.
Response to IPUC Investigation Data Request 4
The Company assumes that the reference to “2022 deferral year in the ECAM” is
intended to be a reference to the Company’s 2023 energy cost adjustment mechanism (ECAM) filed in Case PAC-E-23-09, for deferral calendar year 2022 (January 2022 through December 2022). The Company further assumes that the reference to “the above requests” is intended to be a reference to IPUC Investigation Data Request 1 through IPUC Investigation Data Request 3. Based on the foregoing assumptions, the Company responds as follows: Rocky Mountain Power (RMP) objects to this request as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible
information. RMP also objects to this request as it seeks analysis that has not been conducted by the Company. Specifically, this request would require the Company to conduct separate analyses of various hypothetical scenarios that did not transpire during the calendar year 2022 and therefore are not pertinent to this proceeding. Recordholder: Counsel Sponsor: Counsel
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Joe Dallas (ISB# 1033) Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 97232
Telephone: [phone] Email: [e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION REQUESTING APPROVAL OF NET

-E-23-09

I, Joe Dallas , represent Rocky Mountain Power in the above captioned matter. I am an
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response, is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the Company’s responses to IPUC Investigation Data Request request 1, 2, and 3,
contain Company proprietary information that could be used to its commercial disadvantage.
Rocky Mountain Power herein asserts that the aforementioned response contains
confidential in that the information contains Company proprietary information.
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I am of the opinion that this information is “Confidential,” as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.

DATED this 20th day of September, 2023.

Respectfully submitted,

By__________________________
Joe Dallas Senior Attorney Rocky Mountain Power