20240223Staff 1-18 to PAC.pdf

CHRIS BURDIN 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
• I :
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR APPROVAL OF A CAPACITY DEFICIENCY PERIOD TO BE USED FOR A VOIDED COST CALCULATIONS
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) ) CASE NO. PAC-E-24-01
)
) ) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF ) TO ROCKY MOUNTAIN ) POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Rocky Mountain Power ("Company")
provide the following documents and information as soon as possible, but no later than
FRIDAY, MARCH 15, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, 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 FEBRUARY 23, 2024
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.
REQUEST NO. 1: Please explain whether the load forecast used in the proposed Load
and Resource Balance ("L&R") is the Company's latest load forecast. Also, please explain when
this load forecast was created.
REQUEST NO. 2: Please explain why Public Utility Regulatory Policies Act of 1978
("PURP A") contracts in other states are assumed to expire at the end of their current contracts,
instead of assuming a 79% probability of renewal based on the 2023 IRP.
REQUEST NO. 3: Please confirm that non-PURPA contracts are assumed to expire at
the end of their contract terms in the L&R.
REQUEST NO. 4: Please explain whether projected growth is included in the existing
Demand Response ("DR") programs and how projected growth is determined. Also, please
explain how this is reflected in the L&R.
REQUEST NO. 5: Please explain how approved future DR programs with their growth are
reflected in the L&R and how the growth associated with approved future DR programs is
determined.
REQUEST NO. 6: Please provide an example to compare DR as a resource versus DR as a
load decrement, explain which method is used in the proposed L&R, and explain whether both
will result in the same capacity position.
REQUEST NO. 7: Please confirm whether contracts included in the L&R have sufficient
regulatory certainty. Specifically, contracts that require pre-approval have been approved, and
contracts that do not require pre-approval have been executed and are eligible for recovery.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 FEBRUARY 23, 2024
REQUEST NO. 8: Page 8 of the Application states that the L&R includes all contracts
executed through December 31, 2023. Please provide contract updates between then and the
time the response is provided to this request. For contract additions, please only include those
with regulatory certainty.
REQUEST NO. 9: Page 6 of the Application states that Front Office Transactions ("FOTs")
that have already been contracted are included in the L&R. Please respond to the following.
a.Please list each FOT's contracting party, delivery amount, and delivery time.
b.Please confirm that the contracted FOTs are reflected on the line labeled "Committed
Market Purchases with Reserves" in the L&R.
c.Please explain the rationale behind the sum of "Max Market Purchases Target with
Reserves" and "Committed Market Purchases with Reserves" that represents the total
FOTs.
d.Please explain why "Committed Market Purchases with Reserves" should not be subject
to the "Max Market Purchases Target with Reserves" FOT limit.
e.In 2024, the 1,282-MW "Committed Market Purchases with Reserves" is greater than the
515-MW "Max Market Purchases Target with Reserves" FOT limit. Please explain
whether that shows the FOT limit is not accurate.
f.Please confirm that determination of "Max Market Purchases Target with Reserves" FOT
limit considers both market availability and transmission availability. If yes, between
these two factors, which one is more limiting to the Company?
g.Does the 1,282-MW "Committed Market Purchases with Reserves" have corresponding
transmission availability to allow the transactions? Has the Company reserved the
transmission capacity?
REQUEST NO. 10: Page 8 of the Application states that "[t]he same methodology has been
used for resources included in the 2023 IRP and for resources added after the 2023 IRP." Please
respond to the following.
a.Please describe the methodology.
b.Please explain why the methodology is reasonable.
FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 3 FEBRUARY 23, 2024
c.Please explain the advantages of the methodology compared to the previous
methodology.
d.Does the methodology match the one used in the 2021 IRP or the one used in the 2021
IRP Update?
REQUEST NO. 11: In terms of 3% FOT contingency reserves, Order No. 35834 required
the Company to "provide the Commission with clear evidence in its next filing that these
reserves can be reliably counted upon to provide contingency reserves." Please explain whether
and how the Company has complied with this requirement.
REQUEST NO. 12: Please explain whether all Energy Efficiency ("EE"), both existing EE
and new EE, in the L&R is cost-effective.
REQUEST NO. 13: Please confirm that no early coal retirements or gas conversions are
assumed in the L&R. Also, please confirm that in removing early coal retirements, each derate
adjustment was done independently in the appropriate year in compliance with Order No. 34918.
REQUEST NO. 14: Please explain whether the Company has made a binding commitment
to join the Western Resource Adequacy Program ("WRAP"). Please explain whether the WRAP
capacity is included in the L&R. If so, please explain how the amount is determined.
REQUEST NO. 15: Please explain why Capacity Benefit Margin is not considered in the
L&R.
REQUEST NO. 16: Please explain whether Private Generation includes both the existing
level and the projected growth. If so, please explain how the projected growth is determined.
REQUEST NO. 17: Please explain how the 13% Planning Reserve Margin is determined
and why it is reasonable for the purpose of determining the first deficit period for PURP A
contracts.
FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 4 FEBRUARY 23, 2024
REQUEST NO. 18: Please respond to the following questions regarding the confidential
workpaper in the Application.
a.Please explain what Tab "Smr Peak L&R (No Proxy, Update)" represents. Specifically,
what does "Update" in the Tab name mean?
b.Please explain what Tab "Wtr Peak L&R (No Proxy, Update)" represents. Specifically,
what does "Update" in the Tab name mean?
c.Please explain what Tab "Smr Peak L&R (No Proxy DELTA)" represents. Specifically,
how is the "DELTA" calculated?
d.Please explain what Tab "Wtr Peak L&R (No Proxy DELTA)" represents. Specifically,
how is the "DELTA" calculated?
DATED at Boise, Idaho, this 23rd day of February 2024.
I:\Utility\UMISCIPRDREQIPAC-E-24-01 PR/I 1.docx
FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 5
Chris Burdin
Deputy Attorney General
FEBRUARY 23, 2024
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HA VE THIS 23 DAY OF FEBRUARY 2024, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK.ALDER ROCKY MOUNTAIN POWER 1407 WEST NORTH TEMPLE STE 330 SALT LAKE CITY, UT 84116 E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER E-MAIL ONLY:[e-mail]
RON SCHEIRER
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST STE 600 PORTLAND OR 97232 E-MAIL: [e-mail]
Secretary
CERTIFICATE OF SERVICE