20231016Staff 14-38 to PAC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11714
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 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 )THIRD PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than
MONDAY,NOVEMBER 6,2023.
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
telephonenumber of the record holder.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER 16,2023
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.14:Please explain the basis the Company used to decide which terms it
included in the On-Site Generation Study ("Study")glossary.
REQUESTNO.15:Please provide all 2021 Integrated Resource Plan ("IRP")
workpapers used to support the Study appendices.
REQUESTNO.16:Table 2.1 provides a breakdown of the on-site generationtypes.
Please identifyhow many of the systems include battery storage.
REQUESTNO.17:In section 3.0 of the Study,the Company explains the effects of
monthly,hourly,and instantaneous netting intervals.However,Table 3.4 presents a fourth
option,'Traditional Net Metering.'Please explain the difference between Monthly Netting and
Traditional Net Metering.
REQUESTNO.18:Table 3.4 presents the bill impacts for customers with different
average consumptions (the "Average Bill"column).Please clarify if the average consumption
categories are average monthlyconsumption,or annual consumption.Please clarify if the
average consumption categories are net imports or full imports.Please provide a breakdown of
how many customers are in each of the groups.
REQUESTNO.19:Please describe any alternative means considered by the Company
for determining the value of customer-exportedenergy besides the IRP energy forecast and the
Energy Imbalance Market hourly historic pricing.If there were any,please list the reason(s)the
Company rejected those alternatives.
REQUESTNO.20:Please describe any alternative means considered by the Company
for distributing the value of customer-exported energy on a seasonal time variant basis,as
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 16,2023
opposed to a flat annual rate.If there were any alternatives,please list the reason(s)the
Company rejected them.
REQUESTNO.21:Please describe any alternative means considered by the Company
for determining the value of avoided generation capacity costs besides the Capacity Factor
approximation method.If there were any alternatives,please list the reason(s)the Company
rejected them.
REQUESTNO.22:Please describe the Company's policies regarding the use of
Effective Load Carrying Capability calculations for generationresources.
REQUESTNO.23:Please explain why the Company proposes using 2030 as the test
yearn.
REQUESTNO.24:In its response to Production Request No.8,the Company declined
to provide the avoided capacity valuation for 2022 because "[t]he Company does not have an
estimate of actual export contributions for 2022."AlthoughStaff is aware that Idaho customer
export data was not available for 2022,please provide the following:
a.The avoided capacity valuation for 2022 using the same Utah proxy data that the
Company used for the Study in this case;and
b.An overview of how much avoided capacity valuation can change (and why)
depending on the test period.
REQUESTNO.25:In section 5.0 of the Study,the Company provided justification for
leaving the existing Project EligibilityCap in place for residential customers.However,the
Company did not address the other classes with on-site generation,especially those with a 100-
kilowatt cap,as requested by the Commission.Please provide the pros and cons for the omitted
classes.
REQUESTNO.26:In section 6.0 of the Study,the Company states that its
"...evaluation of energy efficiency measures includes assumed deferraloflocal transmission
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 OCTOBER 16,2023
and distribution upgrades."(Emphasis added).Staff interprets this to mean that the energy
efficiencyprogram uses a value for avoided transmission and distribution ("T&D")costs.
However,the report does not provide this value,and the ensuing comments discuss other issues,
leaving this possibility unanswered.Please clarify this section of the report.
REQUESTNO.27:In section 6.0 of the Study,the Company states that the avoided
T&D cost is "likelyto differ"from the avoided generation cost.However,the Company applies
the avoided generation capacity contribution of 3.0 percent anyway,without explanation.Please
clarify why this is appropriate.Also,the Company provides a final value of $1.10/MWh without
identifying where the reader can find the underlyingcalculations.Please describe where to find
the calculations.
REQUESTNO.28:Please describe any alternative means considered by the Company
for distributing the value of avoided T&D costs on a seasonal time variant basis,as opposed to a
flat annual rate.If there were any alternatives,please list the reason(s)the Company rejected
them.
REQUESTNO.29:In section 7.0 of the Study,the Company refers to its 2018 Line
Loss Study.Please provide a searchable version of that study.
REQUESTNO.30:In section 7.0 of the Study,the Company omits consideration of
transformer core losses.Please explain whether the Company intends to adjust the line loss
factors for transformer core losses or not.Please explain the Company's reason(s)for either
includingor excluding them.
REQUESTNO.31:Please explain why the Company included pages in Appendix 8.2
beyond the first two pages because they appear to be unreadable and not relevant to the Study.
REQUESTNO.32:In section 9.1.1 of the Study,the Company describes the Wattsmart
Batteries program in effect in Utah.Please discuss the impact this program might have on the
proxy Utah export profile.Please provide any supporting analysis.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 OCTOBER 16,2023
REQUESTNO.33:Please clarify the Company's position regarding Schedule 135 -
Net Metering Service customers with respect to section 11.0.
REQUESTNO.34:In section 11.1.1 of the Study,the Company recommends seasonal
export credit pricing,but not time-of-day pricing.Please provide the following:
a.Examples of how pricing would vary under different seasonal scenarios and time-
of-day scenarios;
b.A description of the advantages and disadvantages of each scenario;and
c.The underlyingworksheets for these examples.
REQUESTNO.35:In section 11.1.2 of the Study,the Company's input does not
address the Commission's order,which states,"[p]lease explain how customer-generators will
have accurate and adequate information to make informed choices about the economics of on-
site generation over the expected life of the system."Order No.34753.Please discuss any
informational assistance the Company may offer to help customers evaluate the economics of
on-site generation.Please discuss the trade-offs of a fixed export credit rate versus one that
varies,either frequentlyor infrequently.
REQUESTNO.36:In section 11.2.2 of the Study,the Company's input misinterprets
the Commission's order,which states,"[q]uantify the impact to customers of a 2-year,5-year,
and 10-year expiration periods [sic]."Please answer this same question with the understanding
that the expiration periods are projecting forward into the future,and not backward into the past.
Please discuss whether kilowatt-hour credits should expire or not.
REQUESTNO.37:In section 11.2.3 of the Study,the Company discusses export credit
expiration policy.Please answer the following:
a.Both the Commission Order and the Company's response are ambiguous about
the term "credits."Please clarify if the Company's response contemplates
kilowatt-hour credits or financialcredits;
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 OCTOBER 16,2023
b.If the Company is proposing that financialcredits expire,please explain why they
should expire.Please explain why the Company should not pay the customer for
any unused financial credits;
c.Please discuss how customers can utilize their financial credits,and if customers
can be paid for fmancial credits;and
d.Please clarify the Company's proposed timing for the use and expiration of both
kilowatt-hour credits and financial credits.
REQUESTNO.38:In section 11.3 of the Study,the Company recommends that it
update the ECR annually.Please provide a table that lists all the components of the ECR,the
proposed source of data for determining each component,and the proposed update frequency for
each component.Please discuss the reasons for each proposed update frequency.
DATED at Boise,Idaho,this (9 day of October 2023.
Michael Duval
Deputy AttorneyGeneral
i:umisc:prodreq/pace23.17 prod req 3
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 OCTOBER 16,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF OCTOBER 2023,
SERVED THE FOREGOING THIRD 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 aegisinsight.com
E-MAIL:elo echohawk.com
SECRETARY
CERTIFICATE OF SERVICE