20230614Staff 1-10 to PAC.pdf

CHRIS BURDIN O
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP'S )APPLICATION FOR ACKNOWLEDGEMENT )CASE NO.PAC-E-23-10
OF THE 2023 INTEGRATED RESOURCE )PLAN )
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Rocky Mountain Power provide the
followingdocuments and information as soon as possible,but no later than
WEDNESDAY,JULY 5,2023.
This Production Request is to be considered as continuing,and Rocky Mountain Power is
requested to provide,by way of supplementaryresponses,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
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER l JUNE 14,2023
the person preparing the documents.Please also identify 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 with formulas intact and enabled.
REQUESTNO.1:Please provide avoided cost workpapers for each energy efficiency
and demand response program and measure in Excel format with formulas enabled and intact.
REQUESTNO.2:Pages 16-17 of the Amended IRP Volume I describe the difference
in demand response capacity selected by the 2021 and 2023 IRP preferred portfolios.Please
answer the followingquestions
a.Please list any demand response programs that were launched based on the 2021
IRP preferred portfolio.
b.Please describe the improvements made to account for demand response
resources.
c.Please provide a list of identified overlaps between demand response end-uses
and programs.
REQUESTNO.3:In the Amended IRP Volume I,Table 6.10 footnote 3 describes 100
MW of existing energy efficiency in Table 6.12.Please answer the followingquestions
regarding this statement.
a.Please reconcile the difference between the sum of "Existing -Energy
Efficiency"lines for "East"and "West"in Table 6.12 and the 100 MW of existing
energy efficiency described in footnote 3 of Table 6.10.
b.Please explain why Table 6.10 footnote 3 states that the existing energy efficiency
is accounted for in Table 6.12 but does not include table 6.11,despite it having
the same "Existing -Energy Efficiency"line.
c.Please provide workpapers that demonstrate how the 100 MW of existing energy
efficiency is accounted for in Table 6.12 in Excel format with formulas intact and
enabled.If applicable,please provide similar work papers for Table 6.11.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JUNE 14,2023
REQUESTNO.4:Please explain why the 2023 IRP planning process changed the scale
of the solar resource included as a supply-side resource for selection into portfolios from 50 MW
to 200 MW.Please provide supporting workpapers.Amended IRP Volume I at 194.Please
also explain if the change to 200 MW solar changed the 2023 preferred portfolio's planned solar
selection.
REQUESTNO.5:In reference to Table 9.32,please explain why the West Reserve
Margin is negative starting in 2026.Amended IRP Volume I at 327.Please provide supporting
workpapers with formulas enabled.
REQUESTNO.6:Please explain why the DNV's Private Generation Study assumed
Idaho's net billingstructure to be the same net billingstructure as Utah.Please provide
supporting workpapers.
REQUESTNO.7:Please explain how modeling private generationwith Idaho's current
net billing structure would change the forecasted solar adoption.
REQUESTNO.8:Please explain the Company's participation in Western Resource
Adequacy Program ("WRAP").Please provide any supporting electronic workpapers.
a.Please explain if/when the Company plans to enter the binding phase of
participation in WRAP and if the Company has modeled this in the 2023 IRP.
b.Please explain how much the Company plans to utilize WRAP by year in the 20-
year planning horizon.
c.Please provide a list of resources the Company may use as a qualifyingresource
in the WRAP programs.
d.Please provide the estimated infrastructure costs,program participation costs,cost
per MW,and benefits by year over the planning horizon.For each,please include
system and Idaho's share of costs and benefits.
e.Please explain the overall impact to the Company's planning reserve margin by
participating in WRAP.Please explain if this is different for non-binding and
binding years.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JUNE 14,2023
REQUESTNO.9:Please explain if the Company will seek approval from the
Commission to participate in WRAP.If not,why not?If so,when does the Company expect to
file with the Commission?
REQUESTNO.10:Please explain the strategies and contingencies the Company has
considered if the Boardman to Hemingway transmission line ("B2H")is delayedbeyondthe
expected in-service date of 2026 using the same format contained in Amended Volume 1,Table
10.3,p.368.Please include the near term resource strategies if the project is delayed for 1 year,
2 years,or 5 years.Please provide any supporting worksheets in electronic format with formula
enabled.
DATED at Boise,Idaho,this day of June 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umise:prodreq/pace23.10cbrk prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JUNE 14,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF JUNE 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE
NO.PAC-E-23-10,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL:[e-mail] PORTLAND OR 97232
E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE