20231127PAC to Staff 11-14.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
November 27, 2023 Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C) RE: ID PAC-E-23-20
IPUC Set 2 (11-14) Please find enclosed Rocky Mountain Power’s Responses to IPUC 2nd Set Data Requests 11-14. If you have any questions, please feel free to call me at [phone].
Sincerely, ____/s/____ Mark Alder Manager, Regulation Enclosures

RECEIVED
2023 November 27, PM 3:21
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-23-20 / Rocky Mountain Power November 27, 2023 IPUC Data Request 11
IPUC Data Request 11 Response to Staff Production Request No. 1 states "[a]ll customers are expected to stop taking wholesale service under Federal Energy Regulatory Commission
(FERC) tariffs by July 1, 2027. Please respond to the following:
(a) Please list all the customers that are currently taking wholesale service under the FERC tariffs;

(b) Please explain the difference between customers under FERC tariffs and customers under retail tariffs; (c) Please explain why all customers are expected to stop taking wholesale service by July 1, 2027;

(d) Please explain the significance of July 1, 2027; and (e) Table 1 of the Application shows that there is a small amount of FERC
wholesale load after 2027 in last year's load forecast. Please explain why there
is still some amount of FERC wholesale load after 2027 in last year's load forecast, but not in the most recent proposed load forecast, and explain how that amount is determined. Response to IPUC Data Request 11

(a) The Company objects to this request as it asks for customer-specific information that is highly confidential and potentially commercially sensitive and cannot be provided without the express permission of the individual
customers.
(b) Federal Energy Regulatory Commission (FERC) customers are wholesale customers that have the ability to re-sell the energy purchased from PacifiCorp to a different retail end user. Whereas customers under retail tariffs purchase energy for their own use.

(c) All existing FERC customers have indicated their intention to stop taking service by July 1, 2027. (d) July 1, 2027 is the first day after all existing FERC customers have indicated their intention to stop taking service. (e) Customers have changed their elections since the previous year’s forecast, which impacted the most recent FERC forecast. The FERC forecast is based on the historical sales and current contractual terms of each customer who is
taking service under the tariff.
PAC-E-23-20 / Rocky Mountain Power November 27, 2023 IPUC Data Request 11
Recordholder: Lee Elder / Doug Young
Sponsor: Lee Elder / Doug Young
PAC-E-23-20 / Rocky Mountain Power November 27, 2023 IPUC Data Request 12
IPUC Data Request 12 Response to Staff Production Request No. 3 states that one of the reasons why the 2023 load forecast is lower than the 2022 load forecast is due to lower
expectations for a large customer. Please respond to the following:
(a) Please provide the identity of the large customer; and
(b) Please explain why there is a lower expectation for its load.
Response to IPUC Data Request 12 (a) The Company objects to this request as it asks for customer-specific information that is highly confidential and potentially commercially sensitive
and cannot be shared without the express permission of the individual
customer. Without waiving the foregoing objection, the Company responds as follow:
The Company has discussed this request with Idaho Public Utilities
Commission (IPUC) staff counsel and has agreed that, if requested by IPUC staff, the Company can contact this specific customer to seek express permission to disclose their identity and reasoning for lower expectation of load and then supplement this data request response.
(b) Please refer to the Company’s response to subpart (a) above.
Recordholder: Counsel

Sponsor: Counsel
PAC-E-23-20 / Rocky Mountain Power November 27, 2023 IPUC Data Request 13
IPUC Data Request 13 Response to Staff Production Request No. 5 (a) states that secondary prices use a basis estimate to the most relevant primary curve in the market period. Please
respond to the following.
(a) Please define "secondary prices"; and
(b) Please explain the purposes of developing "secondary prices" and how
"secondary prices" are used for each purpose. Response to IPUC Data Request 13 (a) Secondary prices are prices for secondary market locations. A primary market
is a market location which serves as a major pricing point with many
participants and transactions and thus significant liquidity. Secondary markets are all other markets with limited liquidity.
(b) Secondary market pricing identifies the expected cost differential across
various market points. This allows the Company’s natural gas traders to manage the natural gas fuel supply from day to day, by helping to identify the effective cost at other market points, for example, by allowing them to take advantage of lower cost opportunities when they arise, or to identify alternative sources of supply during pipeline maintenance. The Company also
incurs some variable costs transporting natural gas to its natural gas units.
This cost is also accounted for in its dispatch models to accurately represent unit fueling cost.

Recordholder: David Rubenstein Sponsor: To Be Determined

PAC-E-23-20 / Rocky Mountain Power November 27, 2023 IPUC Data Request 14
IPUC Data Request 14 Response to Staff Production Request No. 5 (c) states that the Company uses a basis differential to a nearby market point to derive the prices of less liquid
market points. Please respond to the following:
(a) Please define "market points" and list all the "market points";
(b) Please define "less liquid market points" and list all the "less liquid market
points"; (c) Please explain how a basis differential is determined; and (d) Please provide an example to illustrate how the Company uses a basis
differential to a nearby market point to derive the prices of less liquid market
points. Response to IPUC Data Request 14

(a) A “market point” is any point in the natural gas system where trading can occur. (b) In general, a market point where trading is limited to day-ahead transactions with limited available counterparties is considered a “less liquid market
point”. The Company considers the markets listed in Table 2 of its
Application to be liquid primary markets. All other points the Company may transact at are considered secondary markets, or “less liquid market points”.
(c) Basis differentials are not relevant in this proceeding as all provided market
prices are for primary hubs. Notwithstanding, the basis differentials in the Company’s forecasts for less liquid market points reflect the experience of its traders from historical patterns of activity for those points. In general, a basis differential can result from variable costs for transfers between points, such as losses or compression charges, or from congestion between those points, i.e.
limits in available transfer capability between those points. Supply and
demand in the respective areas is also a factor, as is the firm pipeline transfer rights of the respective counterparties. (d) Please refer to the Company’s response to subpart (c) above. Recordholder: David Rubenstein Sponsor: To Be Determined