20230825Staff 1-12 to PAC.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 1 0
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )POWER'S APPLICATION TO COMPLETE )CASE NO.PAC-E-23-17
THE STUDY REVIEW PHASE OF THE )COSTS AND BENEFITS OF ON-SITE )CUSTOMER GENERATION )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy Attorney General,requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than FRIDAY
SEPTEMBER 15,2023.
This Production Request is to be considered as continuing,and the Company 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
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 25,2023
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:For each Appendix that the Company submitted as an Excel
spreadsheet,please provide an index of the worksheets,with a narrative description of the
purpose(s)of each worksheet.If the worksheet contains raw data,please characterize the data
set.For example,describe which class or classes the Company included in the data,the period
covered by the data,and other unique identifiers.
REQUESTNO.2:Please explain the Company's plan to publish its final version of the
On-Site Generation Study ("Study"or "Attachment No.1"),and appendices,in a format that will
be understandableby its customers and easily referenced for any subsequent discussion of an
export credit rate ("ECR")structure.
REQUESTNO.3:The narrative and tables in the Study,Section 3.2 (Class Revenue
Requirement),are not clear and difficult to follow.Please provide the following:
a.Please re-design the explanatory narrative and the tables to better explain the
information,so that a typical customer can understand it;
b.Please provide a unique identification number for each table;
c.Please define more clearly the columns of Table 3.1,especially column "d"
(Generation);and
d.Please restructure Table 3.2 to present the Traditional Net Metering revenue first,
followed by the hypothetical revenue for the different netting intervals.
REQUESTNO.4:Please explain how the Company determined a single Integrated
Resource Plan ("IRP")energy value and a single Energy Imbalance Market ("EIM")energy
value for each calendar year in Table 4.1 of the Study.Please provide the data and calculations
the Company used to determine these values.
REQUESTNO.5:Please recalculate Table 4.1 annual energy values using the 2023
IRP forecast energy values.Please include the underlyingdata and calculations.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 25,2023
REQUESTNO.6:Please confirm that the "LOLP Gen Capacity"column in Table 4.1
of the Study is the avoided capacity value.Please explain why the Company assigns zero value
to the "LOLP Gen Capacity"for 2021 through 2025.If this is due to a system-wide capacity
deficiency date ("CDD"),please identify the source of the CDD determination and provide
supporting documentation.
REQUESTNO.7:The Company explains in Section 4.4.3 that spreading capacity
compensation across the hours with capacity shortfalls is reasonable,but doing so is more of a
rate design exercise.Study at 22.The Company therefore proposes spreading capacity value
evenly across all exports.The Commission's order requested hourly time-differentiated capacity
values.Please propose an alternative method that allocates the avoided capacity value only to
critical capacity hours.
REQUESTNO.8:The Company's determination of avoided capacity value uses a
weighted Loss of Load Probability ("LOLP")distribution based on a forecasted 2030 test period.
Please replicate the avoided capacity valuation using the LOLP for 2026,the first CDD year.
Please replicate the avoided capacity valuation using actual export contributions for 2022.
REQUESTNO.9:In the Study section on netting period,the Company considers the
administrative costs of data processing at a 15-minute netting interval.Please answer the
followingquestions:
a.Please explain if the Company considered the administrative burden under other
netting intervals.
i.If yes,please provide the corresponding netting interval and estimate for
hours of Company activity.
ii.If not,why not?
b.Please explain if the Company quantified the administrative benefit that the
Company expects under an instantaneous billing export credit rate structure.
REQUESTNO.10:Please answer the followingquestions regarding the Model
Validation section of the Company's Study:
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 25,2023
a.The Company describes that Idaho customer-generators have shifted from wind
systems to solar photovoltaic ("PV")systems.Please provide the current
distribution of customer-generators by technology type (i.e.,solar,solar plus
battery,wind,etc.)for the residential,small commercial,large commercial,and
irrigation sectors separately for both Idaho and the Northern Utah Proxy group;
b.Please explain if the Company examined any other potential sources of bias (i.e.
systematic difference between the Utah proxy and Idaho on-site generation
population)and describe why the Company did not include them in the study;
c.On page 15,the Company states that its analysis indicates that the overall
difference in hourly export profiles between northern Utah customers and Idaho
will be small.Please provide this analysis and accompanyingworkpapers;
d.If not shown in the analysis,please describe how the Company uses identified
sources of bias to adjust the model and provide supporting workpapers that show
the calculation;and
e.Please explain what state and regulatory policy considerations the Company
accounted for when comparing the Utah proxy group.
REQUESTNO.11:Please answer the followingquestions regarding chapter five of the
Study:
a.The Company states that it "...estimated maximum non-coincident peak is
8.4kW for the typical residential customer taking service on Schedule 1 and 11.5
kW for the typical residential customer taking service on Schedule 1."Study at
23.Please clarify to which schedule the provided non-coincident peaks are
referring;
b.Please provide any analysis that the Company performed when considering
demand-based project eligibilitycap;
c.Please describe what peak load data the Company considered to determine a
hypothetical demand-based project eligibilitycap;
d.Please describe what alternative methods the Company considered to determine a
hypothetical demand-based project eligibilitycap if appropriate historical demand
data is unavailable;and
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 25,2023
e.Please explain if the Company considered any alternate project eligibilitycap
structure other than demand-based and/or current caps.
REQUESTNO.12:In chapter six of the Study,the Company establishes that the
capacity contribution for Transmission and Distribution ("T&D")system deferral is different
from the generation capacity contribution based on system LOLP.Please answer the following
questions:
a.Please explain if the Company considered other methodologies to determine the
value of avoided T&D costs.If yes,please describe these methodologies and why
the Company did not include them in Study;
b.Please identify the specific information that the Company expects it would need
to estimate the avoided T&D costs based on T&D capacity needs;
c.Please explain if the Company considered new small commercial,large
commercial,or irrigation projects as it did for new residential projects;and
d.Please describe if the Company analyzed past Idaho specific T&D project costs to
estimate the value of avoided T&D cost.
DATED at Boise,Idaho,this day of August 2023.
Deputy AttorneyGeneral
i:umisc:prodreq/pace23.17 prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF AUGUST 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTTO ROCKY
MOUNTAIN POWER,IN CASE NO.PAC-E-23-17,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]
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:lance aeg,isinsig,ht.com
E-MAIL:elo echohawk.com
SECRETARY
CERTIFICATE OF SERVICE