20230705PAC to Staff 1-10_REDACTED.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
July 5, 2023 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C) RE: ID PAC-E-23-10
IPUC Set 1 (1-10) Please find enclosed Rocky Mountain Power’s Responses to IPUC 1st Set Data Requests 1-10. Provided via BOX is Confidential Response IPUC 8 and Confidential Attachment IPUC 8. 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
2023 JULY 5, 2023 1:13PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 1
IPUC Data Request 1 Please provide avoided cost work papers for each energy efficiency and demand response program and measure in Excel format with formulas
enabled and intact.
Response to IPUC Data Request 1
The Company assumes that this request relates to PacifiCorp’s 2023 Integrated
Resource Plan, filed with the Idaho Public Utilities Commission (IPUC) on May 31, 2023, and therefore the avoided cost work papers for each energy efficiency and demand response program and measure considered and included in PacifiCorp’s 2023 IRP. Based on the foregoing assumptions, the Company responds as follows:

The IRP model, PLEXOS, selects bundles of demand response (DR) and energy efficiency (EE) measures based on optimization around least cost, least risk planning. The Company has not yet prepared the requested information by
measure for EE or DR as these are produced exogenously to the IRP model.
Recordholder: Peter Schaffer Sponsor: Thomas R. Burns

PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 2
IPUC Data Request 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 following questions:
(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.
Response to IPUC Data Request 2 Referencing PacifiCorp’s 2023 Integrated Resource Plan (IRP), filed with the
Idaho Public Utilities Commission (IPUC) on May 31, 2023, the Company
responds as follows: (a) The Company has launched the following programs based on the 2021 IRP preferred portfolio:
Commercial and Industrial Curtailment – Idaho, Utah, Washington, Oregon,
Wyoming (pending approval) WattSmart Batteries – Idaho, Wyoming (pending approval)

Irrigation Load Control – Washington and Oregon Residential Smart Thermostats and Water Heater Load Control – Oregon and Washington (pending approval)
(b) In the 2021 IRP, the Company modeled demand response (DR) offerings
solicited in the 2021 demand response request for proposals (2021 DR RFP) and resources modeled in the Conservation Potential Assessment (CPA). While program design offerings for DR differ in IRP modeling, the capacity derived from a given end use in the RFP has interaction or overlap with other resources and programs characterized in the CPA. For example, a bring your own (BYO) smart thermostat DR program and a residential heating, ventilation, and air conditioning (HVAC) direct load control (DLC) program are different programs with different pricing and performance characteristics, however, both rely on similar electric end-uses for DR services. As both
PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 2
volumes come from two different sources, the RFP and CPA, overlap between programs and end-uses occurred. (c) Please refer to the table below which provides a list of overlapping resources
between the 2021 DR RFP and the CPA:

State Sector CPA Program Bundles Analogous RFP Resource
CA Residential Battery DLC Active Battery
CA Residential HVAC DLC BYO Thermostat
CA C&I C&I Curtailment
ID Residential Battery DLC Active Battery
ID C&I C&I Curtailment
OR Residential Battery DLC Active Battery
OR Residential Water Heater DLC
OR C&I C&I Curtailment
OR Irrigation Irrigation DLC Irrigation DLC
UT C&I C&I Curtailment
WA Residential Water Heater - DLC Water Heater DLC
WA C&I C&I Curtailment
WA Irrigation Irrigation DLC Irrigation DLC
WY Residential Battery DLC Active Battery
WY C&I C&I Curtailment

Recordholder: Peter Schaffer Sponsor: Thomas R. Burns
PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 3
IPUC Data Request 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 following questions
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.
Response to IPUC Data Request 3 Referencing PacifiCorp’s 2023 Integrated Resource Plan, filed with the Idaho Public Utilities Commission (IPUC) on May 31, 2023, the Company responds as follows:

(a) The reference to Table 6.12 (Winter Peak System Capacity Loads and Resources without Resource Additions) in Table 6.10 footnote 3, should have stated Table 6.11 (Summer Peak – System Capacity Loads and Resources
without Resource Additions East). Adding the year 2023 summer Existing –
Energy Efficiency, east 70 megawatts (MW) plus west 31 MW rounds to 100 MW. (b) Please refer to the Company’s response to subpart (a) above.
(c) Please refer to the confidential work papers accompanying PacifiCorp’s 2023
Integrated Resource Plan (IRP), specifically confidential folder “Chapters, Shortfalls - Part 1\ CH6 - Load and Resource Balance”, confidential file “CONF_Fig 6.2-6.7, Tables 6.11-6.12, 2023 IRP - L&R.xlsx”. Recordholder: Dan Swan Sponsor: Thomas R. Burns
PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 4
IPUC Data Request 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.
Response to IPUC Data Request 4
Referencing PacifiCorp’s 2023 Integrated Resource Plan, filed with the Idaho Public Utilities Commission (IPUC) on May 31, 2023, the Company responds as follows:
The solar resource 200 megawatts (MW) proxy size modeled in PLEXOS for the
2023 IRP is unchanged from the 2021 IRP. The PLEXOS model can select a different proxy MW size due to transmission limitations or solar projects related to request for proposals (RFP) that was included in the 2021 IRP but not present
in the 2023 IRP. The supply side table in the 2021 IRP included a 100 MW solar
project not modeled in PLEXOS, and the 2023 IRP included a 20 MW solar option in PLEXOS for Oregon small scale resources. Recordholder: Dan Swan

Sponsor: Thomas R. Burns

PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 5
IPUC Data Request 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.
Response to IPUC Data Request 5
Referencing PacifiCorp’s 2023 Integrated Resource Plan, filed with the Idaho
Public Utilities Commission (IPUC) on May 31, 2023, the Company responds as follows: From the 2021 IRP to the 2023 IRP, Jim Bridger was moved from the west control area (WCA) to the east control area (ECA) for operational purposes. The
transmission to move Jim Bridger east to west is still available in the 2023 IRP.
The reality is the west reserve margin negative values are reported before transferring Jim Bridger east to west which would mitigate the negative reserve margin reported. Please refer to the confidential work papers accompanying
PacifiCorp’s 2023 IRP filed on May 31, 2023, specifically folder “Chapters\CH9
- Modeling and Portfolio Selection Results”, confidential work paper “CONF_Fig 9.60 Tables 9.32-9.33, 2023 IRP - L&R.xlsx”. Recordholder: Dan Swan / Dan MacNeil

Sponsor: Thomas R. Burns

PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 6
IPUC Data Request 6 Please explain why the DNV's Private Generation Study assumed Idaho's net billing structure to be the same net billing structure as Utah. Please provide
supporting work papers.
Response to IPUC Data Request 6
The Company assumes that this request relates to PacifiCorp’s 2023 Integrated
Resource Plan, filed with the Idaho Public Utilities Commission (IPUC) on May 31, 2023. Based on the foregoing assumptions, the Company responds as follows: DNV’s private generation (PG) study was developed in the summer of 2022. At the time of modeling, the IPUC had ordered the Company to study the different
components of exported energy in Case No. PAC-E-19-08. However,
modifications to the previous net energy metering (NEM) tariff had not yet been adopted. In anticipation of future changes to export rates, the Company elected to align with export credit rates used in Utah since system sizes, monthly exports,
and modeled production are similar.
Recordholder: Peter Schaffer Sponsor: Peter Schaffer

PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 7
IPUC Data Request 7 Please explain how modeling private generation with Idaho's current net billing structure would change the forecasted solar adoption.
Response to IPUC Data Request 7 The Company assumes that this request relates to PacifiCorp’s 2023 Integrated
Resource Plan, filed with the Idaho Public Utilities Commission (IPUC) on May
31, 2023. Based on the foregoing assumptions, the Company responds as follows: It is expected that using the current net billing export rate would lead to an increase in solar adoption and a decrease in solar + battery adoption compared to the current study. This is because the current export rate is more favorable
towards energy export.
Recordholder: Peter Schaffer

Sponsor: Peter Schaffer
PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 8
IPUC Data Request 8 Please explain the Company's participation in Western Resource Adequacy Program (WRAP). Please provide any supporting electronic work papers.

(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 qualifying resource 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. Confidential Response to IPUC Data Request 8
The Company assumes that this request relates to PacifiCorp’s 2023 Integrated
Resource Plan, filed with the Idaho Public Utilities Commission (IPUC) on May 31, 2023. Based on the foregoing assumptions, the Company responds as follows:
(a) Currently PacifiCorp intends . This is subject to change. With regard to PacifiCorp’s 2023 Integrated Resource Plan (IRP), please refer to the Company’s response to subpart (b) below. Additional information
regarding the relationship between PacifiCorp’s IRP and the WRAP is
provided in PacifiCorp’s 2023 IRP, Volume II, Appendix B (IRP Regulatory Compliance), page 41. (b) PacifiCorp’s 2023 Integrated Resource Plan (IRP) did not specifically
consider the Western Resource Adequacy Program (WRAP) as the program details are still under development. While the WRAP could influence how PacifiCorp secures specific market products, PacifiCorp’s IRP load and resource balance over the 20-year forecast horizon is based on access to generic proxy market options (sometimes referred to as front office
transactions (FOT)). WRAP could provide another mechanism for
PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 8
maintaining system reliability during potential shortfalls but this has not been quantified. (c) Please refer to Confidential Attachment IPUC 8.

(d) The 2023 IRP did not forecast the WRAP infrastructure cost, program participation costs and benefit for the reasons stated in the Company’s responses to subpart (b) above, and subpart (e) below.

(e) The Company’s 2023 IRP did not estimate a change in the planning reserve margin (PRM) as a result of the WRAP during the non-binding and binding years. PacifiCorp would note that PRM can vary depending on the capacity contribution identified for specific resource types. For example, a higher PRM that is met with higher capacity contributions for wind and solar resources
would achieve the same level of reliability as a lower PRM with lower
capacity contributions for wind and solar resources. If the two portfolios of resources are identical, the reliability will be the same regardless. This can limit the comparability of PRM values identified in the IRP and for the
WRAP.
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 Swan / Dan MacNeil / Randy Baker / Benjamin Faulkinberry
Sponsor: Thomas R. Burns
PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 9
IPUC Data Request 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?
Response to IPUC Data Request 9
The Company objects to this request as outside the scope of this proceeding and
not reasonably calculated to lead to the discovery of admissible information. Without waiving the foregoing objection, Rocky Mountain Power (RMP) responds as follows: PacifiCorp has made an operational decision to participate in the Western
Resource Adequacy Program (WRAP) based on the expected reliability benefits
to customers. Since the decision does not trigger any pre-approval requirements in any state, including Idaho, the Company has not sought pre-approval. PacifiCorp’s participation in WRAP can be evaluated by the Idaho
Public Utilities Commission (IPUC) and all state commissions through normal
ratemaking processes. Recordholder: Mark Alder
Sponsor: Mark Alder
PAC-E-23-10 / Rocky Mountain Power July 5, 2023 IPUC Data Request 10
IPUC Data Request 10 Please explain the strategies and contingencies the Company has considered if the Boardman to Hemingway transmission line (B2H) is delayed beyond the 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.
Response to IPUC Data Request 10 The Company assumes that this request relates to PacifiCorp’s 2023 Integrated Resource Plan, filed with the Idaho Public Utilities Commission (IPUC) on May 31, 2023. Based on the foregoing assumptions, the Company responds as follows:

PacifiCorp’s 2023 IRP did not contemplate a delay in the Boardman-to-Hemingway (B2H) transmission line in the preferred portfolio (P-MM). The P-16 study looked at removing B2H transmission segments associated with the B2H
transmission project along with 600 megawatts (MW) (interconnection capability)
of enabled resources. Recordholder: Dan Swan
Sponsor: Thomas R. Burns