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HomeMy WebLinkAbout20140331Redacted Update.pdfY ROCKY MOUNHIN HP,yy,E*.B."., March 31,2014 VA OWRNIGHT DELIWRY Ted Weston Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake City, Utah 84111 201 South Main, Suite 2300 Salt Lake City, Utah 84111 Jean D. Jewell Commission Secretary Idaho Public Utilities Commission 472W. Washington Boise, ID 83702 RE: Case No. PAC-E-13-05 In the Matter of the Filing of Roclry Mountain Power of its 2013 Integrated Resource PIan Dear Ms. Jewell: Please find enclosed an original and nine (9) copies, along with a CD of PacifiCorp's 2013 Integrated Resource Plan ("IRP") Update. Confidential information in the 2013 IRP Update will be provided to parties who have signed a non-disclosure agreement in the referenced Case. Rocky Mountain Power requests that interested parties contact the state manager listed below for a copy pf the non-disclosure agreement that must be executed and submitted prior to obtaining a copy of the confidential information. The main changes included in the 2013 IRP Update include:l) updated load forecast with a320 MW average reduction to forecasted system peaks, 2) updated the power and natural gas forward price curve to incorporate lower prices, 3) updated Energy Gateway in-service dates to coincide with revised permitting dates, generation facility needs and load growth assumptions, 4) updated to incorporate recent EPA rulings on the Wyoming Regional Haze state implementation plan (SIP) and federal implementation plan (FIP). With a reduced coincident system peak forecast and lower market prices, the updated resource portfolio continues to show that customer loads over the front ten years of the planning horizon will be met with front office transactions (firm market purchases) and through energy efficiency. PacifiCorp continues to pursue acceleration of cost-effective energy effrciency consistent with its 2013 IRP Action Plan. All formal correspondence and regarding this filing should be addressed to: Daniel E. Solander Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 841I I Telephone: (80 I ) 220-2963 Fax (801) 220-2798 Email : ted.weston@pacifi corp.com Telephone: (801) 220-4014 Fax: (801) 220-3299 Email : daniel. solander@racifi com. com Communications regarding discovery matters, including data requests issued to Rocky Mountain Power, should be addressed to the following: By E-mail (preferred): By regular mail: datarequest@oacifi corp. com Data Request Response Center PacifiCorp 825 NE Multnomah St., Suite 2000 Portland, OR97232 Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220- 2963. Very Truly Yours, )#tr r /"",,,"a/duT Y Jeffref K. Larsen Vice President, Regulation & Govemment Affairs Enclostres cc: Terrie Carlock, Idaho Public Utilities Commission Rick Sterling, Idaho Public Utilities Commission Jim Yost, State of Idaho - Governor's Office Mark Stokes, Idaho Power Company Nancy Kelly, Western Resource Advocates Randall Budge, Racine, Olson, Nye, Budge & Bailey Benjamin J. Otto, Idaho Conservation League Megan Walseth Decker, Renewable Northwest Project 20r3 lntegrated ResouFEe Plan Updete REDACTED YPectnConp Rocky Mounain Power hcific Power fucifiC-orp Enerry onswers on.D%reh 31, 2&]4 Let's turn the This 2013 Integrated Resource Plan Update Report is based upon the best available information at the time of preparation. The IKP action plan will be implemented as described herein, but is subject to change as new information becomes available or as circumstances change. It is PacifiCorp's intention to revisit and refresh the IRP action plan no lessfrequently than annually. Any refreshed IRP action plan will be submitted to the State Commissions for their information. For more information, contact: PacifiCorp IRP Resource Planning 825 N.E. Multnomah, Suite 600 Portland, Oregon 97232 (s03) 813-s245 im@nacificorp.com http ://www. pac i fi corp. com This report is printed on recycled paper Cover Photos (Top to Bottom): Transmission: Sigurd to Red Butte Transmission Segment G Hydroelectric: Lemolo I on North Umpqua River Wind Turbine: Leaning Juniper I Wind Project Thermal-Gas: Chehalis Power Plant Solar: Black Cap Photovoltaic Solar Project PecrrrConp- 2013 IRP UPDATE TeeI-s Or CoNrsNrs Taglp oF CONTENTS TABLE OF CONTENTS INDEX OF TABLES INDEX OF FIGURES EXECUTIVE SUMMARY CHAPTER 1 _ INTRODUCTION CHAPTER 2 - PLANNING ENVIRONMENT BUSTNESS PI-aN DpvslopMENT...... .........................9 Cnolle UNrr 4 UPDATE ......................9 T}D FUTURE OF FEDERAL ENVIRONMENTAL REGULATION AND LEGISLATION ................ IO Federal Climate Change Legislation ................. l0 Federal Renewable Portfulio Standards ... ......... 11 EPA REGULAToRY UPDATE _ GREENHOUSE GAS EMISSIONS.. ..................... I I New Source Review / Prevention of Significant Deterioration Q,{SR / PSD) ............ ..... I I Guidancefor Best Available Control Technologt (BACD ........................ 12 New Source Performance Standards QIISPS) for Greenhouse Gqses .......... .................. 12 EPA REGULAToRY UPDATE-NoN-GREENHOUSE GAS EMISSIoNS.. ...,........13 Clean Air Act Criteria Pollutants - National Ambient Air Quality Standards .............. 13 CleanAir Transport Ru1e............ ....................... 14 Regional Ha2e........... ..................... 14 Mercury and Hazardous Air Pollutants............ ..................... /5 Coal Combustion Residuals................. .............. 16 Water Quality Standards ................ 16 Cooling Water Intake Structures ...........................16 SrarE Cr-ruere CHaNcs REGULATToN ................. 17 Oregon and 11ashington.................. ................... 18 Greenhouse Gas Emission Performance Standards .............. 19 ENERGY GeTsway TRANSMISSION PROGRAM PLAI.INTNG.. ..,,,.19 Energt Gateway Transmission Project Updates....... ............. 20 CHAPTER 3 - RESOURCE NEEDS ASSESSMENT UPDATE IV V 7 9 )a PACIFICoRP _ 20 I3 IRP Upoarg TABLE OF CoureNrs PacifiCorp West ............ ................. 37 CHAPTER 4 - MODELING ASSUMPTIONS UPDATE. ..................39 GBNSRAT- AssuMprroNs ................. .......................39 NaruRel Gas eNo PowER MARKET PRrcE UPDATES.............. ....................39 Natural Gas Market Prices............ ....................39 Power Market Prices........ ..............40 CansoN DroxDE EMrssroN Cosrs AND CoMpLrANCE.......... .......................42 TRANSMTSSIoN Topolocy................. ....................43 SuppLy-sros RESoURCES ...................43 CHAPTER 5 - PORTFOLIO DEVELOPMENT...... .........45 INTRoDUCTToN ............... ....................45 WrND RESoURcES AND RENEwABLE PoRtrolro STANDARD CouplnNcE ........................................45 Renewable Energt Credit Value ........... .............45 ll'ind Resources................ .............. 46 Renewable Portfulio Standard Compliance. ......47 2013 IRP UPDATE REsouRcB PoRTFoLro .............51 BusrNESs Pr-aN RrsouRCE PoRTFoLro.............. .......................55 SBNSIUvITY STUDIES ARoI.]ND PERFoRMANCE oF RENEWABLE RESoURCES............ .......59 CHAPTER 6 _ ACTION PLAN STATUS UPDATE .........69 APPENDIX A - ADDITIONAL LOAD FORECAST DETAILS APPENDIX B - COMBINED HEAT AND POWER EXECUTIYE SUMMARY................87 EXECUTTVE SUMMARY .......................87 BACKGRoUND................. ....................87 Forest Thinnings ........89 Market Barriers...... ........................ 89 Air Permitting Requirements ...........90 Lack of Financial Recognition of Environmental Benefits .........90 Cost of Fuel Transportation,.......,........... ...............90 APPENDIX C - ENERGY AIIALYSIS REPORT 9t PACIFICoRP _ 20 I 3 IR.P UPDATE TABLE OF CoxrsNrs Hyntington P1ant........... .................97 Potentially Cost-Effective Projects...... ..................97 Systems Requiring Further Research ....................97 Unlikely to be Cost-Effective.............. ..................98 Currant Creek Plant .......................98 Potentially Cost-Effective Projects...... ..................98 Systems Requiring Additional Research ...............98 Unlikely to be Cost-Effective.............. ..................98 Hunter Unit 3 .............99 Potentially Cost-Effective Projects...... ..................99 Systems Requiring Further Research ................... .......................99 Unlikely to be Cost-Effective.............. ..................99 Lakeside P1ant........... ................... 100 Potentially Cost-Effective Projects...... ................100 Systems Requiring Further Research ..................100 Unlikely to be Cost-Effective.............. ................100 Blundell P1ant........... .................... 100 Potentially Cost-Effective Projects...... ................100 Systems Requiring Further Research ...,.,....,.......100 Unlikely to be Cost-Effective.............. ................101 Gadsby P1ant........... ..................... l0l APPENDIX D - ACCELERATED CLASS 2 DSM DECREMENT STUDY......................103 MoDELTNG APPROACH ..................... 103 Generation Resource Capacity Deferral Bene/it Methodologt ............... 103 CLASS 2 DSM DECREMENT VALUE RESULTS ...... 104 APPENDIX E - IRP TABLE A.7 CORRECTION ............111 CONFIDENTIAL APPENDIX F _ BREAKEYEN ANALYSIS ................1 13 lll PACIFICoRP _ 20 I3 IRP Upoerg INDEX oF TABLES INnpx OF TABLES Table ES.l - Comparison of 2013 IRP Update with 2013 IRP Prefened Portfolio ..........5 Table 3.1 - October 2013 (2013IRP Update): Forecasted Annual Load Growth, 2014 through 2023 (Megawatl- Table 3.2 - October 2013 (2013IRP Update): Forecasted Annual Coincident Peak Load (Megawatts). ...................24 Table 3.3 - June 2013 (Business Plan): Forecasted Annual Load Growth, 2014 through2023 (Megawatt-hours)....25 Table 3.4 - June 2013 (Business Plan): Forecasted Annual Coincident Peak Load (Megawatts). ........25 Table 3.5 - June 2012 (2013 IRP): Forecasted Annual Load Growth, 2014 through2023 (Megawatt-hours)...........26 Table 3.6 - June 2012 (2013 IRP): Forecasted Annual Coincident Peak Load (Megawatts). ...............26 Table 3.7 - Annual Load Growth Change: October 2013 (2013IRP Update) Forecast less June 2012 (2013 IRP) Forecast (Megawatt-hours) ............... ...............26 Table 3.8 - Annual Coincidental Peak Growth Change: October 2013 (2013IRP Update) Forecast less June 2012 (2013 IRP) Forecast (Megawatts). ...................27 Table 3.9 - Annual Load Growth Change: June 2013 (Business Plan) Forecast less June 2012 (2013 IRP) Forecast Table 3.10 - Annual Coincidental Peak Growth Change: June 2013 (Business Plan) Forecast less June 2012 (2013 IRP) Forecast (Megawatts) ........27 Table 3.1 I - Load and Resource Balance, 2013 IRP Update (Megawatts). ............,.......30 Table 3.12 - Load and Resource Balance, Business Plan (Megawatts) .............. ............31 Table 3.13 - Load and Resource Balance, 2013 IRP (Megawatts) ...........32 Table 3.14 - Load and Resource Balance, 2013 IRP Update less 2013 IRP (Megawatts)..........................................33 Table 3.15 -Load and Resource Balance, Business Plan less 2013 IRP (Megawatts) .........................34 Table 4.1 - Updated Cost of Solar Resources, 2013$ - (50 MW AC)............... ..............43 Table 5.1 - Wind Additions, 2013 IRP Preferred Portfolio, Business Plan, 2013 IRP Update... ..........47 Table 5.2 - Renewable Portfolio Standard Targets, Requirements, and Initial Eligible Existing RECs by State for 2013 IRP, Business Plan, and 2013 IRP Update.......... ..........48 Table 5.3 - Comparison of 2013 IRP Update with 2013 IRP Preferred Portfolio....... ..........................52 Table 5.4 -2013 IRP Update Capacity Load and Resource Balance......... .....................53 Table 5.5 -20I3IRP Update, Detail Portfo1io................... .......................54 Table 5.6 - Comparison of Business Plan with 2013 IRP Preferred Portfolio ................56 Table 5.7 -Business Plan Capacity Load and Resource Balance ..............57 Table 5.9 - Peak Contribution of Renewable Resources, sensitivity study............. ........59 Table 5.10-Updated Costs of SolarResources, sensitivity study (50 MW AC)....... ...........................59 Table 5.12 -Portfolio Comparison of Case EG2-C0I and Peak Contribution Sensitivity Study ...............................61 Table 5.13 - Portfolio Comparison of Case EG2-C07 and Solar Cost Sensitivity Study........ ..............64 Table 5.14 -Portfolio Comparison of Case EG2-Cl0 and Solar Cost Sensitivity Study........ ..............65 Table 5. I 5 - Comparison of Risk-Adjusted PVRR between Cases EG2-C07 and the Capacity Contribution Table 6.1 - IRP Action Plan Status Update.......... ...............70 Table A.l -2013IRP Update Annual Retail Sales Forecast in Megawatt-hours by State..........................................85 Table A.2 - Change in Annual Retail Sales Forecast in Megawatt-hours by State compared to the 2013 IRP ..........85 Table A.3 - System Annual Retail Sales Forecast in Megawatt-hours by Class.....,....... ......................86 Table A.4 - Change in System Annual Retail Sales Forecast in Megawatt-hours by Class Compared to the 2013 Integrated Resource Plan .............. ...................86 Table B.l - PacifiCorp's existing Biomass QF Power Purchase Agreements by State. .......................88 Table B.2 - Woody Biomass Generation on PacifiCorp's System...... ............................88 Table D.l - Nominal Levelized Accelerated Class 2 DSM Avoided Costs (2013-2032) ...................105 Table D.2 - Difference - Nominal Levelized Class 2 DSM Avoided Costs (2013-2032) ..................106 Table D.3 - Annual Nominal Accelerated Class 2 DSM Avoided Costs, 2013-2032.... .....................107 Table D.4 - Annual Nominal Accelerated Class 2 DSM Avoided Costs, 2013-2032 (continued)............................108 Table D.5 - Portfolio Difference - Appendix N (Non-Accelerated DSM) ...................109 Table D.6 - Portfolio Difference - Non-Accelerated DSM .................... I l0 lv PACIFICoRP_2013 IRP UpoArr INDEX oF TABLES AND FIGURES Table E.l - Jurisdictional Contribution to Coincident Peak 1997 through 2012............. ...................1I I Confidential Table F.l - Hunter I APR Emission Control PVRR(d) Analysis Results, 2026 SCR ......................... I 16 Confidential Table F.2 - Bridger 3 and 4 CPCN Emission Control PVRR(d) Analysis Results ..,.....1 l9 Confidential Table F.3 -Naughton 3 CPCN Emission Control PVRR(d) Analysis Results.......... .....120 INoex oF FIGURES Figure ES.2 - Power and Natural Gas Price Comparisons. .......---...............2 Figure ES.3 - Capacity Position Comparison, 2013 IRP versus Business Plan versus 2013 IRP Update ....................4 Figure 3.1 - Capacity Position Comparison, 2013 IRP versus Business Plan versus 2013 IRP Update .....................29 Figure 3.2 -2013IRP Update, System Capacity Position Trend............ .....................'..35 Figure 3.3 -20|3IRP Update, West Capacity Position Trend........... ............................36 Figure 3.4 - 2013 IRP Update, East Capacity Position Trend............ .......36 Figure 4.1 - Henry Hub Natural Gas Prices (Nominal)..... ........................40 Figure 4.2 - Average Annual Flat Palo Verde Electricity Prices ..............41 Figure 4.3 - Average Annual Heavy Load Hour Palo Verde Electricity Prices..... .........41 Figure 4.4 - Average Annual Flat Mid-Columbia Electricity Prices....... ..........-.............42 Figure 4.5 - Average Annual Heavy Load Hour Mid-Columbia Electricity Prices........... ...---.............42 Figure 5.1 -20I3IRP Update RPS Compliance Position.. .......................49 Figure 5.2 - Business Plan RPS Compliance Position ........50 Figure 5.3 -20I3IRP RPS Compliance Position ...............50 Figure F.l - Natural Gas Price Forecast for 2013 IRP Update... .............1l5 Confidential Figure F.2 - Relationship between Gas Prices and the PVRR(d) (Benefit/Cost of the Baghouse and LNB Investments at Hunter Unit I ........... .....117 Confidential Figure F.3 - Relationship between CO2 Prices and the PVRR(d) (Benefit)/Cost of the SCR Investments Confidential Figure F.4 - Relationship between Gas Prices and the PVRR(d) (Benefit/Cost of the SCR Investments at Jim Bridger Units 3 & 4 ............... ..............1l9 Confidential Figure F.5 - Relationship between CO2 Prices and the PVRR(d) (Benefit)/Cost of the SCR Investments at Jim Bridger Units 3 &.4............ .................120 Confidential Figure F.6 - Relationship between Gas Prices and the PVRR(d) (Benefit/Cost of the SCR and Baghouse Investments at Naughton Unit 3........... ...............121 Confidential Figure F.7 - Relationship between CO2 Prices and the PVRR(d) (Benefit/Cost of the SCR and Baghouse Investments at Naughton Unit 3 ........... ...............122 PACIFICoRP _2013 IRP UPDATE EXECUTIVE SUN,IN,IARY ExpCUTIVE SUVTVTARY PacifiCorp submitted its 2013 Integrated Resource Plan (2013 IRP) to state regulatory commissions in April 2013. That plan provides a framework for future actions that PacifiCorp will take to provide reliable, reasonable-cost service with manageable risks for customers. This 2013 IRP Update describes resource planning and procurement activities that occurred subsequent to the filing of the 2013 IRP, presents an updated resource needs assessment, an updated resource portfolio consistent with changes in the planning environment, and provides an IRP Action Plan status update. In presenting the updated resource needs assessment and updated resource portfolio, PacifiCorp shows changes relative to the 2013 IRP and relative to PacifiCorp's fall 2013 ten-year business plan, which covers the 2014 to 2023 planning horizon. ln this update PacifiCorp also addresses recommendations and requirements identified by its state regulatory commissions during the 2013 [RP acknowledgement process. PacifiCorp's long-term planning process involves balanced consideration of cost, risk, uncertainty, supply reliability/delivery, and long-run public policy goals. The following summarizes the key highlights of PacifiCorp's 2013 IRP Update: . As shown in Figure ES.l the Company's most recent coincident system peak load forecast is down relative to the 2013 IRP, and the intervening fall 2013 ten-year business plan. The coincident peak forecast decreased through the planning period. Driving the reduction in peak load are a reduced residential class load forecast relative to the 2013 IRP due to increased energy efficiency and continued phase in of the Energy Independence and Security Act federal lighting standards. [n addition, recent history has seen low growth in the peak, which in turn reduces the long-term forecast peak load growth expectations. With a reduced coincident system peak forecast, the need for new resources is pushed further out in the planning horizon as compared to the 2013 IRP. In the 201 3 IRP Update resource portfolio, a new thermal resource is not neede d until 2027 . Figure ES.l - Load Forecast Comparison 12,000 I 1,500 I t,000 t0,500 10,000 9,500 9,000 Forecasted Annual System Coincident Peak (MW) 20t6 2017 2018 20t9 2020 2021 +.2013 IRP *Business Plan +-20|3IRP Updste 20152014 PACIFICoRP _ 2OI3 IRP UPDATE ExECUTTvE Suvnraanv o Figure ES.2 shows that forecast natural gas and energy prices have declined from those assumed in the 2013 IRP and the fall 2013 ten-year business plan. Domestic gas price forecasts continue to be driven down by growth in unconventional shale gas plays. This in turn (combined with lower forecast regional loads) impacts forward market power prices. Figure ES.2 - Power and Natural Gas Price Comparisons Eenty Eub Nrturrl Grs Prlccs s8 r/ !E-s6-a It"z 04 lli !h9FOO9-dO8888R88R88 +Bod!6Pte (ScD2013) +2013 IRP(S@2O!2)..,il-2013 IRPUDAI (Dc 80 70 f,a-ar50.IIZn 30 20 Avenge of Mld C/Pdo Verde Fht Power Prlcec thsFaOe-dO888RRRR8R8 +BDdo6 Pt& (S.! 2013) +2013 IRP (S.p 2012) +2013 IRP UpAb (Dc 2013) o With a reduced coincident system peak forecast and lower market prices, the updated resource portfolio continues to show that customer loads over the front ten years of the planning horizon will be met with front office transactions (firm market purchases) and through energy efficiency. PacifiCorp continues to pursue acceleration of cost-effective energy efficiency consistent with its 2013 IRP Action Plan. The Energy Gateway transmission project continues to play an important role in the Company's commitment to provide safe, reliable, reasonably priced electricity to meet the needs of our customers. Several Energy Gateway developments have occurred since the Company's 2013 IRP was filed, including reaching construction and permitting milestones, adjusting in-service dates for future segments, and developing activities on joint-development projects. Accordingly, in-service dates have been updated relative to those assumed for the 2013IRP. These date adjustments coincide with revised permiuing dates, generation facility needs and updated load growth assumptions. The Environmental Protection Agency (EPA) partially approved and partially rejected the Wyoming Regional Haze state implementation plan (SIP) and issued a federal implementation plan (FIP) to cover those areas of SIP disapproval in January 2014. This action established compliance requirements and schedules for specific Wyoming coal units under the Regional Haze program, including a requirement for installation of selective catalytic reduction (SCR) at Wyodak by early March 2019. For purposes of the 2013 IRP Update, the resource needs assessment and updated resource portfolio reflects the continued operation of Wyodak as a coal-fired generating asset through the planning PACIFICORP _ 20 I 3 IRP UPDATE Executrve SutwteRv horizon. PacifiCorp will be analyzing the Wyodak SCR investment and alternatives to this investment in its 2015 IRP. In EPA's action on the Wyoming SIP in January 2014, it explicitly stated its support for the natural gas conversion of Naughton Unit 3, but noted that because the Wyoming SIP documentation did not include a natural gas conversion option, EPA has no basis to disapprove the Wyoming SIP requirement for low NOx burners/overfired air, SCR, and baghouse, with its authority and obligation to take action on the SIP as submitted by the state. PacifiCorp has since been working with the state of Wyoming Division of Air Quality to identiff amendments necessary to support the Naughton Unit 3 natural gas conversion and to clearly document the compliance requirements and timeline for implementation of the project under the RegionalHaze program. In the 2013 IRP Update, the resource needs assessment and updated resource portfolio continues to reflect a gas conversion completed by summer 2015. Since 2010, no significant activity has occurred with respect to the development of a federal renewable portfolio standard (RPS). In addition, current political environments are shifting focus from items such as the extension of federal incentives for renewables and portfolio standards to EPA's development of greenhouse gas standards. Accordingly, the 2013 IRP Update assumes no federal RPS requirement over the course of the planning horizon. With the removal of the federal RPS assumptions requirements, the updated resource portfolio shows a reduced need for renewable resources required solely to meet state RPS obligations in2024 and2025. After PacifiCorp filed the 2013 IRP, President Obama issued a Presidential Memorandum in June 2013 directing EPA to issue standards, regulations, or guidelines, as appropriate that address greenhouse gas emissions from modified, reconstructed, and existing power plants. The proposed standards, regulations, or guidelines are to be issued by June l, 2014, finalized by June 1,2015, with implementation of regulations as proposed in SIPs required by June 30,2016. EPA would then review the implementation plan proposed by each state, and the effective compliance dates for these standards, regulations, or guidelines would become applicable sometime thereafter. Absent information on how EPA intends to proceed with its rule-making process, and without any information on how individual states will propose to implement those regulations through a SIP, there is currently no means to develop a specific CO2 price assumption that accurately reflects potential CO2 regulation. PacifiCorp's review of current third-party CO2 price forecasts shows that despite issuance of the Presidential Memorandum, these forecasters have not materially altered either their assumed COz start date or price level. In the 2013 IRP Update, PacifiCorp continues to assume a COz price signal beginning 2022 at $16/ton escalating at three percent plus inflation thereafter, and expects to update its COz policy assumptions and scenarios in the 2015 IRP, taking into consideration the proposed standard, regulation, or guidelines expected to be issued by EPA later this year. Figure ES.3 shows the 2013 tRP Update resource need, prior to acquiring any new resources, alongside the resource need from the 2013 IRP and the fall2013 ten-year business plan. Overall, PACIFICoRP - 2OI 3 IRP UpoIre E)GCI.].ITVE SUT.tr\,IARY the forecasted need has declined with the most recent needs assessment. Primarily driven by an updated load forecast, the most recent resource needs assessment shows an average reduction in peak resource need of approxim ately 320 megawatts (MUD as compared to the 20 I 3 IRP for the period 2014-2023. Relative to the fall 2013 ten-year business plan, the most recent projection of resource need is reduced by approximately 135 MW over the same period. Figure ES.3 - Capacity Position Comparison, 2013 IRP versus Business Plan versus 2013 IRP Update (Lm0) a $ooolT Gm) (4s) (3,m) r 2013 IRP t BuCnc.s Ph[ Table ES.l reports the 2013 IRP Update resource portfolio and a comparison of portfolio changes relative to the 2013 IRP Preferred Portfolio.l The table shows the resource mix targeted to fill the resource need summarized above with resource capacities at time of coincident system peak reported in the years for which the resources are available to meet summer peak loads. As compared to the 2013 IRP Preferred Portfolio, the changes in resource mix for the 2014-2023 planning period are minor. Relative to the 2013 IRP Preferred Portfolio, which did not include any significant new thermal resources in the front ten years of the planning horizon, the updated resource portfolio shows a reduction in front office transactions (FOTs), consistent with a reduced resource need. As was the case in the 2013 IRP Preferred Portfolio, PacifiCorp continues to plan to meet its customers' needs largely through acquisition of cost effective energy efficiency resources and FOTs over the next ten years. Considering the relatively small changes in energy efficiency resources between the 2013 IRP and 2013 IRP Update portfolios, PacifiCorp has not modified its 2013 IRP Action Plan and continues to target accelerated energy efficiency savings. I A comparison ofthe portfolio changes relative to the fall 2013 ten-year business plan is presented in Chapter 5. PecnrConp - 2013 IRP Uppers E)ccunvE Sumaanv Table ES.l - Comparison of 2013 IRP Update with 2013 IRP Preferred Portfolio FrcIi Ofice Tretbre h rcmme total ue lo-yer awnge. r Less 2013 IRP Prtferrtd Portfolio Frcrn Oftr Tmrctiru h resuce total ue I Gyer amge. t PacifiCorp has not modified its 2013 IRP Action Plan, which remains consistent with the updated resource needs assessment and resource portfolio as summarized above. Chapter 6 of this IRP Update provides a status update of PacifiCorp's 2013 IRP Action Plan action items. A variety of action items have been completed and are noted as such, while other action items will continue forward into the 2015 IRP process. PACIFICoRP _ 2OI3 IRP UPDATE CHAPTER I . INTRoDUCTION Cueprpn 1 - INTnoDUCTIoN This 2013 Integrated Resource Plan Update (2013 IRP Update) describes resource planning activities that occurred subsequent to the filing of the 2013 Integrated Resource Plan (2013 tRP) in April 2013, presents an updated resource needs assessment, an updated resource portfolio consistent with changes in the planning environment, and provides an IRP Action Plan status update. In presenting the updated resource needs assessment and updated resource portfolio, PacifiCorp shows changes relative to the 2013 IRP and relative to PacifiCorp's fall 2013 ten-year business plan (Business Plan), which covers the 2014 to 2023 planning horizon. In this update PacifiCorp also addresses recommendations and requirements identified by its state regulatory commissions during the 2013 IRP acknowledgement process. In support of its business planning process, PacifiCorp refined the 2013 IRP Preferred Portfolio to reflect updates to forecasted loads, resources, market prices, and other model inputs. PacifiCorp's business planning process also considers capital expenditure and operating cost constraints with input from the PacifiCorp business units (PacifiCorp Energy, Pacific Power, and Rocky Mountain Power). Consideration of both capital and operating cost constraints is critical to ensure that PacifiCorp's business plan is financially supportable and affordable to customers. The 2013 IRP Preferred Portfolio served as the primary basis in establishing the resource portfolio for the Business Plan, and as summarized herein, differences between the two resource portfolios are minor. A similar process has been completed to develop the resource needs assessment and resource portfolio for this 2013 IRP Update, which considers updates to forecasted loads, resources, market prices, and other model inputs since the intervening Business Plan resource portfolio was developed. For purposes of assessing an updated resource needs assessment and updated resource portfolio in this 2013 IRP Update, PacifiCorp has not completed new financial analysis of pending environmental compliance decisions applicable to specific coal units on its system. PacifiCorp will analyze specific environmental compliance decisions applicable to Cholla Unit 4, Wyodak, and Dave Johnston Unit 3 in its 2015 IRP, with the full engagement of PacifiCorp's diverse stakeholder group. PacifiCorp will also provide an update on its efforts working with the Wyoming Division of Air Quality to identify amendments necessary to support the Naughton Unit 3 natural gas conversion and to clearly document the compliance requirements and timeline for implementation of the natural gas conversion under the RegionalHaze program. In this 2013 IRP Update, PacifiCorp continues to assume the Naughton Unit 3 natural gas conversion is completed by summer 2015. The 2013 IRP Update also addresses recommendations and requirements identified by its state regulatory commissions during the 2013 acknowledgement process. This includes presentation of solar resource modeling sensitivities developed in response to a request by the Public Service Commission of Utah (PSCU) of and analysis of how CO2 price and natural gas price assumptions affect the analysis of environmental compliance decisions for specific coal units as requested by the Washington Utilities and Transportation Commission. This report first describes the current planning environment, load updates, resource updates, emissions/climate change regulatory outlook, and Energy Gateway transmission planning and PACIFICoRP - 2OI3 IRP Upmrr Cueprsn I - INrnooucrron project completion forecast (Chapter 2). Next, Chapters 3 and 4 describe the changes to key inputs and assumptions relative to those used for the 2013lRP. The updated resource portfolio is then presented along with a status update on the 2013 IRP Action Plan (Chapters 5 and 6, respectively). Appendices include the following: . Appendix A - Additional Load Forecast Details. Appendix B - Executive Summary of the CHP Study. Appendix C - Energy Analysis Report. Appendix D - Accelerated DSM Decrement Study. Appendix E - Correction to 2013 IRP Table A.7o Redacted Appendix F - Breakeven Analysis for Select Coal-Fired Plants PACTFICoRP - 20 13 IRP UpNErg CHAPTER 2 - PLANNTNG ENVIRONMENT CHapTER 2 _ PTEUNING ENVINONMENT The 2013 IRP Preferred Portfolio served as the basis for the resource assumptions used in PacifiCorp's fall 2013 ten-year business plan @usiness Plan), which covers the 2014 to 2023 planning horizon. Changes in the portfolio reflect updates to forecasted loads, resources, market prices, and other model inputs. PacifiCorp's business planning process also considers capital expenditure and operating cost constraints to ensure that the resulting business plan is financially supportable and affordable to customers. As it relates to PacifrCorp's resource plan, differences between the 2013 IRP Prefened Portfolio and the Business Plan portfolio are minor and consistent with an updated load forecast. The Business Plan portfolio also considers updated assumptions for the Energy Gateway transmission project, which continues to play an important role in the Company's commitment to provide safe, reliable, reasonably priced elqctricity to meet the needs of our customers. Several Energy Gateway developments have occurred since the Company's 2013 IRP was filed, including reaching construction and permitting milestones, adjusting in-service dates for future segments, and developing activities on joint-development projects. Accordingly, in-service dates have been updated relative to those assumed for the 2013 IRP. These date adjustments coincide with generation facility needs and load growth assumptions. ln March 201I, the state of Arizona submitted its RegionalHaze state implementation plan (SIP) to the Environmental Protection Agency (EPA) for review. The SIP requires currently installed low NOx burners (LNB) as best available retrofit technology (BART) for NOx emissions at Cholla Unit 4. By final rule dated December 5,2012, EPA disapproved portions of the Arizona Regional Haze SIP and issued a federal implementation plan (FIP). The FIP requires, among other things, installation of selective catalytic reduction (SCR) on Cholla Unit 4 by January 4, 2018. The FIP also institutes an averaged NOx emissions rate of 0.055 lbA,tMBtu for Cholla Units 2, 3 and 4. In January and February 2013, PacifiCorp, the state of Arizona and other Arizona utilities filed separate appeals of EPA's FIP with the U.S. Ninth Circuit Court of Appeals. In February 2013, PacifiCorp and other Arizona utilities filed petitions for reconsideration at the EPA and requests for administrative stay of the FIP until judicial appeals are completed. In March 2013, PacifiCorp and other Aizona utilities filed motions for judicial stay of the FIP with the U.S. Ninth Circuit Court of Appeals until the appeals are complete. On April 3,2013, the court consolidated the various appeals into a single docket before a single judicial panel. On April 9, 2013, EPA granted various petitions for reconsideration for the averaged NOx emissions rate only, but has taken no further action to date. Although EPA may propose a new NOx rate at some time in the future, which will undergo public comment, it is not under any timing requirement to do so. EPA did not address the various requests for administrative stay in its April 9,2013 action. PaCrICOnp - 20 13 IRP UPDATE CHAPTER 2 - PLA}{NTNG ENVIRoNMENT On April 23,2013, the court set the following case schedule: o June 2013 - briefing on motions for judicial stay to be completedo January 2014 - briefing on the merits of appeals to be completed On September 9, 2013, the court denied the motions for stay. The court is now expected to issue a final decision on the appeals in 2015. However, there are no mandatory dates by which the court must issue decisions. With the denial of requests for administrative stay and judicial stay, the January 4, 2018 compliance deadline for installing SCR at Cholla Unit 4 remains in place. PacifiCorp continues to work closely with the state of Arizona and the other Arizona utilities in connection with the now consolidated appeals. Various environmental groups have intervened in the appeals in support of EPA's FIP. With the ongoing activities outlined above, PacifiCorp continues to explore potential alternatives to the installation of SCR at Cholla Unit 4, and consequently, the Company has not finalized an analysis of compliance alternatives nor made a decision on this pending investment. The Company intends to finalize its analysis in 2014 and will file its analysis in a future IRP filing.2 For purposes of the 2013 IRP Update, PacifiCorp assumes Cholla Unit 4 continues to provide both system capacity and energy through the planning horizon. PacifiCorp faces a continuously changing environment with regard to electricity plant emission regulations. Although the exact nature of these changes remains uncertain, they are expected to impact the cost of future resource alternatives and the cost of existing resources in the Company's generation portfolio. PacifiCorp monitors these regulations to determine the potential impact on its generating assets. PacifiCorp also participates in the rulemaking process by filing comments on various proposals, participating in scheduled hearings, and providing assessment of such proposals. Federal Climate Change Legislation PacifiCorp continues to evaluate the potential impact of climate change legislation at the federal level. The impact of a given legislative proposal can vary significantly depending on selection of key design criteria (i.e., level of emissions cap, rate of decline of the cap, the use of carbon offsets, allowance allocation methodology, the use of safety valves, etc.) and macro-economic assumptions (i.e., electricity load growth, fuel price impacts - especially natural gas, commodity prices, new technologies, etc.). To date, no federal legislative climate change proposal has successfully been passed by both the U.S. House of Representatives and the U.S. Senate for consideration by the President. The two most prominent legislative proposals introduced for attempted passage through Congress have ' The Public Utility Commission of Oregon's draft 2013 IRP acknowledgement order outlines a requirement for PacifiCorp to make a supplemental IRP filing on Cholla Unit 4 in 2014. With the appropriate protections in place, PacifiCorp intends to summarize the information from this filing for its broader stakeholder group during the 2015 IRP public process and summarize this same analysis in a confidential volume of the 2015 IRP. 10 P,6\CFTCORP - 20 13 IRP UPDATE CH.npTsn 2 _ PLANNTNG ENVIRoNMENT been the Waxman-Markey bill in 2009 and the Kerry-Lieberrnan bill in 2010; neither measure was able to accumulate enough support to pass. The l13ft Congress was challenged by the President to pursue a bipartisan, market-based solution to climate change. The President stated that if Congress did not act soon, then he would direct his Cabinet to implement executive action to reduce greenhouse gas (GHG) emissions. To date, such bipartisan action has not occurred. ln 2013, a bill was introduced by the Energy & Power Subcommittee Chairman Whitfield (R-KY) called the Electricity Security and Affordability Act, which provides direction to EPA regarding the establishment of standards for GHG emissions from fossil-fueled generating facilities. This bill is expected to pass the House of Representatives but not the Senate. On June 25,2013, President Obama directed the EPA to complete GHG standards for both new and existing power plants. With regard to existing sources, EPA was directed to issue "standards, regulations, or guidelines, as appropriate" that address GHG emissions from modified, reconstructed, and existing power plants.3 The proposed standards, regulations, or guidelines are to be issued by June 1,2014, finalized by June 1,2015, with implementation of regulations as proposed in state implementation plans required by June 30,2016. EPA would then review the implementation plan proposed by each state. The June 25, 2013 directive did not include detail with respect to how EPA will approach GHG regulation or what the resulting standards, regulations, or guidelines will ultimately entail. Federal Renewable Portfolio Standards Since 2010, no significant activity has occurred with respect to the development of a federal renewable portfolio standard (RPS). In addition, current political environments are shifting focus from items such as the extension of federal incentives for renewables and portfolio standards to EPA's development of greenhouse gas standards. Accordingly, the 2013 IRP Update assumes no federal RPS requirement over the course of the planning horizon. New Source Review / Prevention of Significant Deterioration (NSR / PSD) On May 13, 2010, the EPA issued a final rule that addresses GHG emissions from stationary sources under the Clean Air Act (CAA) permitting programs, known as the "tailoring" rule. This final rule sets thresholds for GHG emissions that define when permits under the New Source Review (NSR) / Prevention of Significant Deterioration (PSD) and Title V Operating Permit programs are required for new and existing industrial facilities. This final rule "tailors" the requirements of these CAA permitting programs to limit which facilities will be required to obtain PSD and Title V permits. The rule also establishes a schedule that will initially focus CAA permitting programs on the largest sources with the most CAA permiuing experience. Finally, the rule expands to cover the largest sources of GHGs that may not have been previously covered by the CAA for other pollutants. 3 Presidential Memorandum - Power Sector Carbon Pollution Standards, June 25, 2013. ll PecrrConp - 2013 IRP Upners CHAPTER 2 - PLANNING ENVIRONMENT Guidance for Best Available Control Technology (BACT) On November 10, 2010, the EPA published a set of guidance documents for the tailoring rule to assist state permitting authorities and industry permitting applicants with the Clean Air Act PSD and Title V permitting for sources of GHGs. Among these publications was a general guidance document entitled "PSD and Title V Permitting Guidance for Greenhouse Gases," which included a set of appendices with illustrative examples of Best Available Control Technology (BACT) determinations for different types of facilities, which are a requirement for PSD permitting. The EPA also provided white papers with technical information conceming available and emerging GHG emission control technologies and practices, without explicitly defining BACT for a particular sector. In addition, the EPA has created a "Greenhouse Gas Emission Strategies Database," which contains information on strategies and control technologies for GHG mitigation for two industrial sectors: electricity generation and cement production. The guidance does not identiff what constitutes BACT for specific types of facilities, and does not establish absolute limits on a permitting authority's discretion when issuing a BACT determination for GHGs. Instead, the guidance emphasizes that the five-step top-down BACT process for criteria pollutants under the CAA generally remains the same for GHGs. While the guidance does not prescribe BACT in any area, it does state that GHG reduction options that improve energy effrciency will be BACT in many or most instances because they cost less than other environmental controls (and may even reduce costs) and because other add-on controls for GHGs are limited in number and are at differing stages of development or commercial availability. Utilities have remained very concerned about the NSR implications associated with the tailoring rule (the requirement to conduct BACT analysis for GHG emissions) because of great uncertainty as to what constitutes a triggering event and what constitutes BACT for GHG emissions. New Source Performance Standards (NSPS) for Greenhouse Gases On December 23,2010, in a settlement reached with several states and environmental groups in New York v. EPA, the EPA agreed to promulgate emissions standards covering GHGs from both new and existing electric generating units under Section 1l I of the CAA by July 26,2011 and issue final regulations by May 26,2012.4 NSPS are established under the CAA for certain industrial sources of emissions determined to endanger public health and welfare and must be reviewed every eight years. While NSPS were intended to focus on new and modified sources and effectively establish the floor for determining what constitutes BACT, the emission guidelines will apply to existing sources as well. In September2013, the EPA issued a revised NSPS proposal for new fossil-fueled generating facilities and withdrew its April 2012 NSPS proposal. The new proposal would limit emissions of carbon dioxide to 1,000 pounds per megawatt hour (MWh) for large natural gas plants and 1,100 pounds per MWh for smaller natural gas plants. The revised proposal continues to largely exempt simple cycle combustion turbines from meeting the standards. The standard for new coal units would be set based on the availability of partial carbon capture and sequestration technology. The public comment period will close in May 2014 and, a final rule is expected in June 2014. 4 The deadlines for EPA to take proposed and final actions have since been extended. EPA also entered into a similar settlement the same day to address GHG emissions from refineries with proposed regulations by December l5,20ll and final regulations by November 15,2012. t2 PACIFICoRP _ 2OI3 IRP UPDATE CHAPTER 2 _ PLANNING ENVIRoNMENT In January 2014, Senate Minority Leader Mitch McConnell (R-KY) filed a resolution of disapproval in an attempt to block EPA's NSPS for GHG emissions from new fossil-fueled power plants. A vote has not yet been scheduled on this resolution. In addition, in January 2014 the State of Nebraska sued the EPA in federal district court arguing that the rule's requirements for carbon capture and sequestration wrongfully rely on federally funded and unviable control technology. In support of this claim Nebraska relies on a provision of the Energy Policy Act of 2005 which restricts reliance on technology developed with federal assistance when setting performance standards. The EPA is also under a consent decree obligation to establish GHG NSPS for modified and existing sources. Consistent with the presidential directive mentioned above, EPA has indicated that it will issue a proposed rule for existing sources in June 2014.The proposed rule to be issued by the EPA for modified and existing sources is to be used by states to develop plans for reducing emissions and/or emissions intensity and may include targets based on demonstrated controls, efficiency related emission reductions, or even beyond the fence-line compliance alternatives intended to meet best system of emissions reduction parameters. States are expected to be required to submit their implementation plans to the EPA by June 2016 pursuant to the President's direction. States are expected to have the ability to apply less sffingent standards or longer compliance schedules if they demonstrate that following the federal guidelines is unreasonably cost-prohibitive, physically impossible, or that there are other factors that reasonably preclude meeting the guidelines. States may also impose more stringent standards or shorter compliance schedules. Several categories of EPA regulations for non-GHG emissions are discussed below: Clean Air Act Criteria Pollutants - National Ambient Air Quality Standards The CAA requires the EPA to set National Ambient Air Quality Standards (NAAQS) for certain pollutants considered harmful to public health and the environment. For a given NAAQS, the EPA and/or a state identifies various control measures that once implemented are meant to achieve an air quality standard for a certain pollutant, with each standard rigorously vetted by the scientific community, industry, public interest groups, and the general public. Particulate matter (PM), sulfur dioxide (SOz), ozone (O3), nitrogen dioxide (NOz), carbon monoxide (CO), and lead are often grouped together because under the CAA, each of these categories is linked to one or more NAAQS. These "criteria pollutants", while undesirable, are not toxic in typical concentrations in the ambient air. Under the CAA, they are regulated differently from other types of emissions, such as hazardous air pollutants and GHG. Within the past few years, the EPA established new standards for particulate matter, sulfur dioxide, and nitrogen dioxide. The EPA is currently tasked with reviewing ozone standards, as well. l3 PACIFICoRP _ 20I3 IRP UpoarE CHAPTER 2 -PLANNTNG ENVIRoNMENT Clean Air Transport Rule In July 2009, EPA proposed its Clean Air Transport Rule (Transport Rule), which would require new reductions in SOz and nitrogen oxide (NOa) emissions from large stationary sources, including power plants, located in 31 states and the District of Columbia beginning in 2012. The Transport Rule was intended to help states attain NAAQS set in 1997 for ozone and fine particulate matter emissions. The rule replaced the Bush administration's Clean Air Interstate Rule (CAIR), which was vacated in July 2008 and rescinded by a federal court because it failed to effectively address pollution from upwind states that is hampering efforts by downwind states to comply with ozone and PM NAAQS. While the rule was finalized as the Cross-State Air Pollution Rule (CSAPR) in July 2011, litigation in the D.C. Circuit Court of Appeals resulted in a stay on the implementation of the CSAPR in December 2011. Ultimately, in August 2012,the D.C. Circuit Court of Appeals vacated the CSAPR in a 2-l decision after it determined the rule exceeded the EPA's statutory authority. The EPA sought a full review of the CSAPR ruling by the entire D.C. Circuit; however, in January 2013, the court denied the request. In June 2013, a petition for certiorari filed by EPA was granted by the U.S. Supreme Court, meaning until the Supreme Court issues a decision or a replacement rule is adopted and implemented, the CAIR remains in place. PacifiCorp does not own generating units in states identified by the CAIR or CSAPR and thus will not be directly impacted; however, the Company intends to monitor amendments to these rules closely in the event that the scope of a replacement rule extends the geographic scope of impacted states. Regional Haze EPA's rule to address Regional Haze visibility concerns will drive additional NO* reductions particularly from facilities operating in the Western United States, including the states of Utah and Wyoming where PacifiCorp operates generating units, in Arizona where PacifiCorp owns but does not operate a coal unit, and in Colorado and Montana where PacifiCorp has partial ownership in generating units operated by others, but nonetheless subject to the Regional Haze Rule. On June 15,2005, EPA issued final amendments to its July 1999 RegionalHaze rule. These amendments apply to the provisions of the Regional Haze rule that require emission controls known as BART, for industrial facilities meeting certain regulatory criteria that with emissions that have the potential to impact visibility. These pollutants include PMz.s, NOx, SOz, certain volatile organic compounds, and ammonia. The 2005 amendments included final guidelines, known as BART guidelines, for states to use in determining which facilities must install controls and the type of controls the facilities must use. States were given until December 2007 to develop their implementation plans, in which states were responsible for identifying the facilities that would have to reduce emissions under BART as well as establishing BART emissions limits for those facilities. The state of Utah issued a regional haze state implementation plan (SIP) requiring the installation of SOz, NO* and particulate matter (PM) controls on Hunter Units I and2 and Huntington UnitsI and2.In December 2012, the EPA approved the SOz portion of the Utah Regional Haze SIP and disapproved the NO* and PM portions. Certain groups have appealed the EPA's approval of t4 PecruConp - 2OI3 IRP UPDATE CHAPTER 2 _PLANNING ENVIRONMENT the SOz SIP. PacifiCorp and the state of Utah appealed EPA's disapproval of the NO* and PM SIP. In addition, and separate from the EPA's approval process and related litigation, the Utah Division of Air Quality is undertaking an additional BART analysis for each of Hunter Units I and2 and Huntington Units I and2, which will be provided to the EPA as a supplement to the existing Utah SIP. It is unknown whether and how the Utah Division of Air Quality's supplemental analysis will impact the EPA's approval and disapproval of the existing SIP. The state of Wyoming issued two regional haze SIPs requiring the installation of SOz, NO, and PM controls on certain PacifiCorp coal-fueled generating facilities in Wyoming. The EPA approved the SOz SIP in December 2012, but initially proposed to disapprove portions of the NO* and PM SIP and instead issue a FIP. However, in 2013, the EPA issued a re-proposal of a NO* and PM FIP which included substantial changes to the control equipment required in the original proposal. On January 10,2014, the EPA issued a final action which largely approved the original Wyoming SIP. Ultimately, EPA's final determination requires installation of the following NO* and PM controls at PacifiCorp facilities: SCR equipment and a baghouse at Naughton Unit 3 by December 31, 2014; SCR equipment at Jim Bridger Unit 3 by December 31, 2015; SCR equipment at Jim Bridger Unit 4 by December 31, 2016; SCR equipment at Jim Bridger Unit I by December 31, 2022; SCR equipment at Jim Bridger Unit 2 by December 31, 2021; SCR within five years or a commitmentto shut down in 2027 at Dave Johnston Unit 3; and SCR at Wyodak within 5 years. With respect to Naughton Unit 3, EPA indicated its support for the conversion of the unit to natural gas and that it would expedite action relative to consideration of the gas conversion once the state of Wyoming submiued the requisite SIP amendment. The EPA action became final on March 3,2014.In the meantime, certain groups have appealed the EPA's approval of the Wyoming SOz SIP which, consistent with the Utah SO2 SIP, required emission reductions of SOz to be enforced through a three-state milestone and backstop trading program. EPA's final action on the Wyoming NO* and PM SIP may also be appealed. The state of Arizona issued a Regional Haze SIP requiring, among other things, the installation of SO2, NO* and PM controls on Cholla Unit 4, which is owned by PacifiCorp but operated by Arizona Public Service. The EPA approved in part, and disapproved in part, the Arizona SIP and issued a FIP for the disapproved portions. PacifiCorp filed an appeal in the Ninth Circuit Court of Appeals regarding the FIP as it relates to Cholla Unit 4, and the Arizona Department of Environmental Quality and other affected Arizona utilities filed separate appeals of the FIP as it relates to their interests. Mercury and Htzardous Air Pollutants In March 2005, the EPA issued the Clean Air Mercury Rule (CAMR) to permanently limit and reduce mercury emissions from coal-fired power plants under a market-based cap-and-trade program. However, the CAMR was vacated in February 2008, with the court finding the mercury rules inconsistent with the stipulations of Section I l2 of the CAA. The vacated CAMR was replaced by EPA with the more extensive Mercury and Air Toxics Standards (MATS) with an effective date of April 16, 2012. The MATS rule requires that new and existing coal-fueled facilities achieve emission standards for mercury, acid gases and other non-mercury hazardous air pollutants. Existing sources are required to comply with the new standards by April 16,2015. tndividual sources may be granted upto one additional year, atthe l5 PACIFICORP - 20 13 IRP UPDATE CHaprsn 2 - PLANNING ENvIRoNMENT discretion of the Title V permitting authority, to complete installation of controls or for transmission system reliability reasons. While the final MATS requirements continue to be reviewed by PacifiCorp, the Company believes its emission reduction projects completed to date or currently permitted or planned for installation, including the scrubbers, baghouses and electrostatic precipitators required under other EPA requirements, are consistent with achieving the MATS requirements and will support PacifiCorp's ability to comply with the final standards for acid gases and non-mercury metallic hazardous air pollutants. PacifiCorp will be required to take additional actions to reduce mercury emissions through the installation of controls or use of sorbent injection at certain of its coal-fueled generating facilities and otherwise comply with the standards. PacifiCorp continues to plan for retirement of its Carbon facility in early 2015 as the least-cost alternative to comply with MATS and other environmental regulations. Implementation of the transmission system modifications necessary to maintain system reliability following disconnection of the Carbon facility generators from the grid are underway. CoaI Combustion Residuals Coal Combustion Residuals (CCRs), including coal ash, are the byproducts from the combustion of coal in power plants. CCRs are currently considered exempt wastes under an amendment to the Resource Conservation and Recovery Act (RCRA); however, EPA proposed in 2010 to regulate CCRs for the first time. EPA is considering two possible options for the management of CCRs. Both options fall under the RCRA. Under the first option, EPA would list these residual materials as special wastes subject to regulation under Subtitle C of RCRA with requirements from the point of generation to disposition including the closure of disposal units. Under the second option, EPA would regulate coal combustion residuals as nonhazardous waste under Subtitle D of RCRA and establish minimum nationwide standards for the disposal of coal combustion residuals. Under either option for regulation, surface impoundments utilized for coal combustion byproducts would have to be closed unless they could meet more stringent regulatory requirements. PacifiCorp operates 16 surface impoundments and six landfills that contain coal combustion byproducts. The public comment period on EPA's proposal to regulate coal combustion byproducts closed in November 2010 and the EPA has indicated that the rule will be finalized in2014.In a preamble to the recently proposed effluent guideline limitations discussed herein, EPA stated that non- hazardous management of CCRs may be adequate. Water Quality Standards Cooling Water Intake Structures The federal Water Pollution Control Act ("Clean Water Act") establishes the framework for maintaining and improving water quality in the United States through a program that regulates, among other things, discharges to and withdrawals from waterways. The Clean Water Act requires that cooling water intake structures reflect the "best technology available for minimizing adverse environmental impact" to aquatic organisms. In July 2004, the EPA established significant new technology-based performance standards for existing electricity generating l6 PACIFICoRP _ 2013 IRP UpONrg CH.q,prEn 2 - PLANTNTNG ENVTRoNMENT facilities that take in more than 50 million gallons of water per day. These rules were aimed at minimizing the adverse environmental impacts of cooling water intake structures by reducing the number of aquatic organisms lost as a result of water withdrawals. [n response to a legal challenge to the rule, in January 2007, the Court of Appeal for the Second Circuit remanded almost all aspects of the rule to the EPA without addressing whether companies with cooling water intake structures were required to comply with these requirements. On appeal from the Second Circuit, in April 2009, the U.S. Supreme Court ruled that the EPA permissibly relied on a cost-benefit analysis in setting the national performance standards regarding best technology available for minimizing adverse environmental impact at cooling water intake structures and in providing for cost-benefit variances from those standards as part of the $316(b) Clean Water Act Phase II regulations. The Supreme Court remanded the case back to the Second Circuit Court of Appeals to conduct further proceedings consistent with its opinion. In March 2011, the EPA released a proposed rule under $316(b) of the Clean Water Act to regulate cooling water intakes at existing facilities. The proposed rule establishes requirement for electric generating facilities that withdraw more than two million gallons per day, based on total design intake capacity, of water from waters of the U.S. and use at least 25 percent of the withdrawn water exclusively for cooling purposes. PacifiCorp's Dave Johnston generating facility withdraws more than two million gallons per day of water from waters of the U.S for once-through cooling applications. Jim Bridger, Naughton, Gadsby, Hunter, Carbon and Huntington generating facilities currently utilize closed cycle cooling towers but withdraw more than two million gallons of water per day. The proposed rule includes impingement (i.e., when fish and other aquatic organisms are trapped against screens when water is drawn into a facility's cooling system) mortality standards to be met through average impingement mortality or intake velocity design criteria and entrainment (i.e., when organisms are drawn into the facility) standards to be determined on a case-by-case basis. The standards are required to be met as soon as possible after the effective date of the final rule, but no later than eight years thereafter. While the rule was required to be finalized by the EPA by July 2012, the rule is now expected to be finalized in the second quarter of 2014. Assuming the final rule in that timeframe, PacifiCorp's generating facilities impacted by the final rule will be required to complete impingement and entrainment studies by mid-2015. Elfluent Limit G uidelines EPA first issued effluent guidelines for the Steam Electric Power Generating Point Source Category (i.e., the Steam Electric effluent guidelines) in 1974 with subsequent revisions in 1977 and 1982. On April 19,2013, EPA proposed revised effluent limit guidelines and is required, under the terms of a stipulated extension to a consent decree, to finalize the rule by May 2014. Until the technology-based effluent limitation guidelines are frnalized, PacifiCorp is incorporating proxy compliance costs for certain units reasonably likely to be impacted by the rule into its business plans and analyses. Of importance to note, the effluent limit guidelines will also apply to gas-fired generation. While national GHG legislation has not been successfully adopted, state initiatives continue with the active development of climate change regulations that will impact PacifiCorp. t7 PACFICoRP - 2013 IRP Upnlrs CHApTER 2 - Pr-a.N[.trNc E]wTRoNMENT California An executive order signed by California's governor in June 2005 would reduce GHGs emissions in that state to 2000 levels by 2010, to 1990 levels by 2020 and 80 percent below 1990 levels by 2050. In 2006, the California Legislature passed, and Governor Schwarzenegger signed, Assembly Bill 32, the Global Warming Solutions Act of 2006, which set the 2020 GHG emissions reduction goal into law. It directed the California Air Resources Board (CARB) to begin developing discrete early actions to reduce GHG while also preparing a scoping plan to identifu how best to reach the 2020 limit. Pursuant to the authority of the Global Warming Solutions Act, in October 201l, CARB adopted a GHG cap-and-trade program with an effective date of January 1,2012; compliance obligations were imposed on regulated entities beginning in 2013. The first auction of GHG allowances was held in California in November 2012 and the second auction in February 2013. PacifiCorp is required to sell, through the auction process, its directly allocated allowances, and purchase the required amount of allowances necessary to meet its compliance obligations. In October 2013, CARB kicked off an Assembly Bill 32 scoping plan update designed to build upon the initial scoping plan. The scoping plan update defines climate change priorities for the next five years and sets the groundwork for post-2020 climate goals. A proposed first update issued in February 2014 indicated a post-2020 GHG reduction goal of 80 percent below 1990 levels by 2050. Oregon and Washington ln2007,the Oregon Legislature passed HB 3543 Global Warming Actions which establishes GHG reduction goals forthe state that (i) bV 2010, cease the growth of Oregon greenhouse gas emissions; (ii) by 2020, reduce greenhouse gas levels to l0 percent below 1990 levels; and (iii) by 2050, reduce greenhouse gas levels to at least 75 percent below 1990 levels. In 2009, the Legislature passed SB 101 which requires the Oregon Public Utility Commission (OPUC) to report to the Legislature before November I of each even-numbered year on the estimated rate impacts for Oregon's regulated electric and natural gas companies associated with meeting the GHG reduction goals of 10 percent below 1990levels by 2020 and l5 percent below 2005 levels by 2020. The OPUC submitted its most recent report November 1,2012. On July 3 2013, the Oregon Legislature passed Senate Bill 306 which directs the legislative revenue officer to prepare a report examining the feasibility of imposing a clean air fee or tax as a new revenue option. The report is to include an evaluation of how to treat imported and exported energy sources. A final report is expected November 1,2014. In 2008, the Washington State Legislature approved the Climate Change Framework E2SHB 2815, which establishes state GHG emissions reduction limits. Washington's emission limits are to (i) by 2020, reduce emissions to 1990 levels; (ii) by 2035, reduce emissions to 25 percent below 1990 levels; and (iii) by 2050, reduce emissions to 50 percent below 1990 levels, or 70 percent below Washington's forecasted emissions in 2050. The Washington Legislature established the Climate Legislative and Executive Workgroup to develop recommendations to achieve the state's GHG emission limits. The workgroup issued two reports in January 20141' both reports included recommendations to continue workgroup efforts through 2014. l8 PACTICoRP - 2OI3 IRP UPDATE Csaprsn 2 - PLANNTNG ENVTRoNMENT Greenhouse Gas Emission Performance Standards California, Oregon and Washington have all adopted GHG emission performance standards applicable to all electricity generated within the state or delivered from outside the state that is no higher than the GHG emission levels of a state-of-the-art combined-cycle natural gas generation facility. The standards for Oregon and California are currently set at 1,100 pounds of carbon dioxide equivalent per MWh, which is defined as a metric measure used to compare the emissions from various GHG based upon their global warming potential. In March 2013, the Washington Department of Commerce issued a new rule, effective April 6,2013,lowering the emissions performance standard to 970 pounds of carbon dioxide per MWh. As discussed in the 2013 IRP, the Energy Gateway transmission project continues to play an important role in the Company's commitment to provide safe, reliable, reasonably priced electricity to meet the needs of our customers. Energy Gateway's design and extensive footprint provides needed system reliability improvements and supports the development of a diverse range of cost-effective resources required for meeting customers' energy needs. The IRP has incorporated Energy Gateway as part of a solution for delivering the least cost resource portfolio for multiple IRP planning cycles. PacifiCorp continues to develop methods, in parallel with current industry best practices and regional transmission planning requirements, to beffer quantiff all the benefits of transmission that are essential to serve customers. For example, Energy Gateway is designed to relieve operating limitations, increase capacity, and improve operations and reliability in the existing electric transmission grid. Several Energy Gateway developments have occurred since the Company's 2013 IRP was filed, including reaching construction and permitting milestones, adjusting in-service dates for future segments, and developing activities on joint-development projects. Also, in response to feedback from interested stakeholders, the Company has completed its 2013 IRP Action Plan item to solicit feedback from stakeholders regarding the System Operational and Reliability Benefit Tool (SBT) that identifies and quantifies a range of transmission benefits. Please see Chapter 6 for status updates on the 2013 IRP Action Plan. An updated Energy Gateway map is provided below as Figure 2.1. t9 20r3 lntegrated ResounEe Plan Update REDACTED SPaqnConp Rocky Mountain Power Pacific Porm hcifiC-orp Enerry dnswers on.Mareh 31, 2ql4 Let's turn the This 201i Integrated Resource Plan Update Report is based upon the best available information at the time of preparation. The IRP action plan will be implemented as described herein, but is subject to change as new information becomes available or os circumstances change. k is PacifiCorp's intention to revisit and refresh the IkP action plan no lessfrequently than annually. Any refreshed IRP action planwill be submitted to the State Commissionsfor their information. For more information, contact: PacifiCorp IRP Resource Planning 825 N.E. Multnomah, Suite 600 Portland, Oregon 97232 (s03) 813-5245 im@oacificorp.com http ://www.pac i fi corp.com This report is printed on recycled paper Cover Photos (Top to Bottom): Transmission: Sigurd to Red Butte Transmission Segment G Hydroelectric: Lemolo I on North Umpqua River Wind Turbine: LeaningJuniper I Wind Project Thermal-Gas: Chehalis Power Plant Solar: Black Cap Photovohaic Solar Project PACIFICoRP _ 20 I3 IRP Upoarg TABLE OF CoNTENTS Teglp oF CONTENTS TABLE OF CONTENTS INDEX OF TABLES INDEX OF FIGURES EXECUTIVE SUMMARY CHAPTER I - INTRODUCTION CHAPTER 2 - PLAI\INING ENYIRONMENT BusrNESs PLAN DEVELoPMENT...... .........................9 CHor-la UNrr 4 UpoarB ......................9 THE FUTURE oF FEDERAL ENVIRoNMENTAL REGULATIoN AND LEGISLATIoN ................ IO Federal Climate Change Legislation. ................ l0 Federal Renewable Portfolio Standards... ......... 11 EPA REcULAToRy UPDATE-GREENHoUSE GAS EMrssroNS.................. ......................... I I New Source Review / Prevention of Signfficant Deterioration Q,{SR / PSD) ................. 11 Guidancefor Best Available Control Technologt (BACD ........................ 12 New Source Performance Standards QI{SPS) for Greenhouse Gases .......... .................. 12 EPA REGULATORY UPDATE - NON-GREENHOUSS GAS EMISSIONS .. ............ I 3 Clean Air Act Criteria Pollutants - National Ambient Air Quality Standards .............. 13 Clean Air Transport Ru1e............ ....................... 14 Regional Haze ............14 Mercury and Hazardous Air Po||utants............... .................. 15 Coal Combustion Residuals................. .............. 16 Water Quality Standards... .............16 Cooling Water Intake Structures ...........................16 Srarr Cluarp CHANGE REGULATToN .................17 Oregon and Washin9ton.................. ................... /8 Greenhouse Gas Emission Performance Standards .............. 19 ENERGY GATBWAY TRANSMISSION PROGRAM PLANNING.. ...... 19 Energt Gateway Transmission Project Updates....... ............. 20 CHAPTER 3 - RESOURCE NEEDS ASSESSMENT UPDATE ry 7 9 23 PACIFICoRP _ 20 13 IRP Upoerg TABLE OF CoNTENTS CHAPTER 4 - MODELING ASSUMPTIONS UPDATE CHAPTER 5 _ PORTFOLIO DEVELOPMENT...... .........45 INTRoDUCTroN.............. .....................45 WIND RESoURCES AND RENEWABLE PoRTFoLro SraNoaRo CoMPLTANCE ........................................45 Renewable Energt Credit Value ........... ............. 45 Wind Resourcer................ ..............46 Renewable Portfolio Standard Compliance. ......47 20 I 3 IRP UPDATE RESoURCE PoRTFoLIo ............. 5 I BUSTNESS PLAN RESoURCE PoRTFoLro.............. .......................55 SBNSITIVITy SruoIpS ARoI.]ND PERFoRMANCE oF RENEwABLE RESoURCES............ .......59 CHAPTER 6 _ ACTION PLAI\ STATUS UPDATE .........69 APPENDIX A - ADDITIONAL LOAD FORECAST DETAILS APPENDIX B - COMBINED HEAT AI\D POWER EXECUTIYE SUMMARY................87 EXECUTTVE SUMMARY .......................87 Mill Waste ..................88 Forest Thinnings ........89 Market Barriers...... ........................ 89 Air Permitting Requirements ...........90 Lack of Financial Recognition of Environmental Benefits .........90 Cost of Fuel Transportation.................... ...............90 APPENDIX C - ENERGY AIIALYSIS REPORT 9l PACIFICoRP _ 20 13 IRP UpOArg TABLEOF CoNTENTS Huntington P1ant........... .................97 Potentially Cost-Effective Projects...... .....,............97 Systems Requiring Further Research ....................97 Unlikely to be Cost-Effective.............. ..................98 Currant Creek Plant ....................... 98 Potentially Cost-Effective Projects...... ..................98 Systems Requiring Additional Research....... ........98 Unlikely to be Cost-Effective.............. ..................98 Hunter Unit 3 .............99 Potentially Cost-Effective Projects...... ..................99 Systems Requiring Further Research ....................99 Unlikely to be Cost-Effective.............. ..................99 Lakeside P1ant........... ................... 100 Potentially Cost-Effective Projects...... ................100 Systems Requiring Further Research ..................100 Unlikely to be Cost-Effective.............. ................100 Blundell P1ant........... .................... 100 Potentially Cost-Effective Projects...... ........,.......100 Systems Requiring Further Research ..................100 Unlikely to be Cost-Effective.............. ................101 Gadsby P1ant........... ..................... 101 APPENDIX D _ ACCELERATED CLASS 2 DSM DECREMENT STUDY......................103 MoDELTNG APPROACH ..................... 103 Generation Resource Capacity Deferral Bene/it Methodologt ............... 103 CLASS 2 DSM DBcRpNreNt VALUE ITEST]LTS ...... IO4 APPENDIX E _ IRP TABLE A.7 CORRECTION CONFIDENTIAL APPENDIX F _ BREAKEVEN ANALYSIS 111 113 lll PACIFICoRP _ 20 I3 IRP Upnerg INDEX OF TABLES INnpx OF TABLES Table ES.l - Comparison of 2013 IRP Update with 2013 IRP Preferred Portfolio ..........5 Table 3.1 - October 2013 (2013IRP Update): Forecasted Annual Load Growth, 2014 through2023 (Megawatt- Table 3.2 - October 2013 (2013IRP Update): Forecasted Annual Coincident Peak Load (Megawatts). ...................24 Table 3.3 - June 2013 (Business Plan): Forecasted Annual Load Growth, 2014 through2023 (Megawatt-hours).,,.25 Table 3.4 - June 2013 (Business Plan): Forecasted Annual Coincident Peak Load (Megawatts). ........25 Table 3.5 - June2012 (2013 IRP): Forecasted Annual Load Growth, 2014 through2023 (Megawatt-hours)...........26 Table 3.6 - June2012 (2013 IRP): Forecasted Annual Coincident Peak Load (Megawatts). ...............26 Table 3.7 - Annual Load Growth Change: October 2013 (2013IRP Update) Forecast less June 2012 (2013 IRP) Forecast (Megawatt-hours) ............... ...............26 Table 3.8 - Annual Coincidental Peak Growth Change: October 2013 (2013IRP Update) Forecast less June 2012 (2013 IRP) Forecast (Megawatts). ...................27 Table 3.9 - Annual Load Growth Change: June 2013 (Business Plan) Forecast less June 2012 (2013IRP) Forecast Table 3.10 - Annual Coincidental Peak Growth Change: June 2013 (Business Plan) Forecast less June 2012 (2013 IRP) Forecast (Megawatts) ........27 Table 3.ll -Load and Resource Balance,2013 IRP Update (Megawatts). ....................30 Table 3.12 -Load and Resource Balance, Business Plan (Megawatts) .............. ............31 Table 3.13 -Load and Resource Balance,2013 IRP (Megawatts) ...........32 Table 3.14 - Load and Resource Balance, 2013 IRP Update less 2013 IRP (Megawatts)..........................................33 Table 3.15 -Load and Resource Balance, Business Plan less 2013 IRP (Megawatts) .........................34 Table 4.1 - Updated Cost of Solar Resources, 2013$ - (50 MW AC)............... ..............43 Table 5.1 - Wind Additions, 2013 IRP Prefened Portfolio, Business Plan, 2013 IRP Update... ..........47 Table 5,2 - Renewable Portfolio Standard Targets, Requirements, and Initial Eligible Existing RECs by State for 2013 IRP, Business Plan, and 2013 IRP Update.......... ..........48 Table 5.3 - Comparison of 2013 IRP Update with 2013 IRP Preferred Portfolio....... ..........................52 Table 5.4 -2013 IRP Update Capacity Load and Resource Balance.,....... .....................53 Table 5.5 -2013IRP Update, Detail Portfo1io................... .......................54 Table 5.6 - Comparison of Business Plan with 2013 IRP Preferred Portfolio ................56 Table 5.7 -Business Plan Capacity Load and Resource Balance ..............57 Table 5.9 - Peak Contribution of Renewable Resources, sensitivity study............. ........59 Table 5.10 - Updated Costs of Solar Resources, sensitivity study (50 MW AC)....... ...........................59 Table 5.12 - Portfolio Comparison of Case EG2-C0l and Peak Contribution Sensitivity Study ...............................61 Table 5.13 - Portfolio Comparison of Case EG2-C07 and Solar Cost Sensitivity Study....... ...............64 Table 5.14 - Portfolio Comparison of Case EG2-Cl0 and Solar Cost Sensitivity Study....... ...............65 Table 5.15 - Comparison of Risk-Adjusted PVRR between Cases EG2-C07 and the Capacity Contribution Table 6.1 - IRP Action Plan Status Update.......... ...............70 Table A.l -2013IRP Update Annual Retail Sales Forecast in Megawatt-hours by State..........................................85 Table A.2 - Change in Annual Retail Sales Forecast in Megawatt-hours by State compared to the 2013 IRP ..........85 Table A.3 - System Annual Retail Sales Forecast in Megawatt-hours by Class............. ......................86 Table A.4 - Change in System Annual Retail Sales Forecast in Megawatt-hours by Class Compared to the 2013 Integrated Resource Plan .............. ...................86 Table B.l - PacifiCorp's existing Biomass QF Power Purchase Agreements by State. .......................88 Table B.2 - Woody Biomass Generation on PacifiCorp's System...... ............................88 Table D.l - Nominal Levelized Accelerated Class 2 DSM Avoided Costs (2013-2032) ...................105 Table D.2 - Difference - Nominal Levelized Class 2 DSM Avoided Costs (2013-2032) ..................106 Table D.3 - Annual Nominal Accelerated Class 2 DSM Avoided Costs, 2013-2032.... .....................107 Table D.4 - Annual Nominal Accelerated Class 2 DSM Avoided Costs, 2013-2032 (continued)............................108 Table D.5 - Portfolio Difference - Appendix N (Non-Accelerated DSM) ........... ........109 Table D.6 - Portfolio Difference - Non-Accelerated DSM ....................1 l0 lv PACIFICORP _20I3 IRP UPOETE INDEX OF TABLES AND FIGURES Table E.l - Jurisdictional Contribution to Coincident Peak 1997 through 2012.............. ...................1I I Confidential Table F.l -Hunter I APR Emission Control PVRR(d) Analysis Results, 2026 SCR.........................1l6 Confidential Table F.2 - Bridger 3 and 4 CPCN Emission Control PVRR(d) Analysis Results ........1 l9 Confidential Table F.3 -Naughton 3 CPCN Emission Control PVRR(d) Analysis Results.......... .....120 INngx oF FIGURES Figure ES.2 - Power and Natural Gas Price Comparisons. .........................2 Figure ES.3 - Capacity Position Comparison, 2013 IRP versus Business Plan versus 2013 IRP Update ....................4 Figure 3.1 - Capacity Position Comparison, 2013 IRP versus Business Plan versus 2013 IRP Update .....................29 Figure 3.2 -2013 IRP Update, System Capacity Position Trend............ ........................35 Figure 3.3 -2013IRP Update, West Capacity Position Trend ........... ...........................,36 Figure 3.4 - 2013IRP Update, East Capacity Position Trend............ .......36 Figure 4.1 - Henry Hub Natural Gas Prices (Nominal)...., ........................40 Figure 4.2 - Average Annual Flat Palo Verde Electricity Prices ..............41 Figure 4.3 - Average Annual Heavy Load Hour Palo Verde Electricity Prices..... .........41 Figure 4.4 - Average Annual Flat Mid-Columbia Electricity Prices....... ........................42 Figure 4.5 - Average Annual Heavy Load Hour Mid-Columbia Electricity Prices........... ...................42 Figure 5.1 -20I3IRP Update RPS Compliance Position.... ....,................49 Figure 5.2 - Business Plan RPS Compliance Position ........50 Figure 5.3 - 2013 IRP RPS Compliance Position ...............50 Figure F.l - Natural Gas Price Forecast for 2013 IRP Update... ............. 1 l 5 Confidential Figure F.2 - Relationship between Gas Prices and the PVRR(d) (Benefit)/Cost of the Baghouse and LNB Investments at Hunter Unit I ........... .....117 Confidential Figure F.3 - Relationship between CO2 Prices and the PVRR(d) (Benefit)/Cost of the SCR Investments at Hunter Unit I ........... ............1l8 Confidential Figure F.4 - Relationship between Gas Prices and the PVRR(d) (Benefit/Cost of the SCR Investments at Jim Bridger Units 3 & 4............ .................1l9 Confidential Figure F.5 - Relationship between CO2 Prices and the PVRR(d) (Benefit/Cost of the SCR Investments at Jim Bridger Units 3 &. 4............ .................120 Confidential Figure F.6 - Relationship between Gas Prices and the PVRR(d) (Benefit/Cost of the SCR and Baghouse Investments at Naughton Unit 3........... ...............121 Confidential Figure F.7 - Relationship between CO2 Prices and the PVRR(d) (Benefit)/Cost of the SCR and Baghouse Investments at Naughton Unit 3 ........... ...............122 PecruConp - 20 I 3 IRP Upoers EXECUTwE SutvIt\4ARY ExgcurIVE Suutr,tARY PacifiCorp submitted its 2013 lntegrated Resource Plan (2013 IRP) to state regulatory commissions in April 2013. That plan provides a framework for future actions that PacifiCorp will take to provide reliable, reasonable-cost service with manageable risks for customers. This 2013 IRP Update describes resource planning and procurement activities that occurred subsequent to the filing of the 2013 IRP, presents an updated resource needs assessment, an updated resource portfolio consistent with changes in the planning environment, and provides an IRP Action Plan status update. In presenting the updated resource needs assessment and updated resource portfolio, PacifiCorp shows changes relative to the 2013 IRP and relative to PacifiCorp's fall 2013 ten-year business plan, which covers the 2014 to 2023 planning horizon. In this update PacifiCorp also addresses recommendations and requirements identified by its state regulatory commissions during the 2013IRP acknowledgement process. PacifiCorp's long-term planning process involves balanced consideration of cost, risk, uncertainty, supply reliability/delivery, and long-run public policy goals. The following summarizes the key highlights of PacifiCorp's 2013 IRP Update: o As shown in Figure ES.l the Company's most recent coincident system peak load forecast is down relative to the 201 3 IRP, and the intervening fall 2013 ten-year business plan. The coincident peak forecast decreased through the planning period. Driving the reduction in peak load are a reduced residential class load forecast relative to the 2013 IRP due to inmeased energy efficiency and continued phase in of the Energy Independence and Security Act federal lighting standards. In addition, recent history has seen low growth in the peak, which in turn reduces the long-term forecast peak load growth expectations. With a reduced coincident system peak forecast, the need for new resources is pushed further out in the planning horizon as compared to the 2013 IRP. In the 2013IRP Update resource portfolio, a new thermal resource is not needed until2027 . Figure ES.l- Load Forecast Comparison 12,000 I 1,500 I 1,000 10,500 10,000 9,500 9,000 F'orecasted Annual System Coincident Peak (MW) 2016 2017 2018 20t9 2020 2021 .-(>2013 IRP *Buiness Plan -r-2013 IRP Update 20152014 PECTTICONT _ 20 13 IRP UPDATE E)GCUTIVE SUMMARY o Figure ES.2 shows that forecast natural gas and energy prices have declined from those assumed in the 2013 IRP and the fall 2013 ten-year business plan. Domestic gas price forecasts continue to be driven down by growth in unconventional shale gas plays. This in turn (combined with lower forecast regional loads) impacts forward market power prices. Figure ES.2 - Power and Natural Gas Price Comparisons Eenry Eub Netural Glr Prlcer s8 s, Ba!Xs6 EI" 5z t4 t3 i69FO6O-da8888888RRR +BuiEPla (scp 2013) +mr3 RP(S?20!2) +20t3 Averrge of MId C/Prlo Verde Flat Power Prlcer 80 70 ,& E l50IE* 30 20 +Bdoa Pta (S? 2013) +ml3 IRP (S.D 2012) +2013 lnP Up.l! (Dc 2Or3) !69FO6a-dORRR8888RRR With a reduced coincident system peak forecast and lower market prices, the updated resource portfolio continues to show that customer loads over the front ten years of the planning horizon will be met with front office transactions (firm market purchases) and through energy efficiency. PacifiCorp continues to pursue acceleration of cost-effective energy efficiency consistent with its 2013 IRP Action Plan. The Energy Gateway transmission project continues to play an important role in the Company's commitment to provide safe, reliable, reasonably priced electricity to meet the needs of our customers. Several Energy Gateway developments have occurred since the Company's 2013 IRP was filed, including reaching construction and permitting milestones, adjusting in-service dates for future segments, and developing activities on joint-development projects. Accordingly, in-service dates have been updated relative to those assumed for the 2013IRP. These date adjusfrnents coincide with revised permitting dates, generation facility needs and updated load growth assumptions. The Environmental Protection Agency (EPA) partially approved and partially rejected the Wyoming Regional Haze state implementation plan (SIP) and issued a federal implementation plan (FIP) to cover those areas of SIP disapproval in January 2014. This action established compliance requirements and schedules for specific Wyoming coal units under the Regional Haze program, including a requirement for installation of selective catalytic reduction (SCR) at Wyodak by early March 2019. For purposes of the 2013 IRP Update, the resource needs assessment and updated resource portfolio reflects the continued operation of Wyodak as a coal-fired generating asset through the planning PACFICoRP - 2OI 3 IRP UPDATE E)<rcurrvE Suunaenv horizon. PacifiCorp will be analyzing the Wyodak SCR investment and alternatives to this investment in its 2015 IRP. In EPA's action on the Wyoming SIP in January 2014, it explicitly stated its support for the natural gas conversion of Naughton Unit 3, but noted that because the Wyoming SIP documentation did not include a natural gas conversion option, EPA has no basis to disapprove the Wyoming SIP requirement for low NO1 burners/overfired air, SCR, and baghouse, with its authority and obligation to take action on the SIP as submitted by the state. PacifiCorp has since been working with the state of Wyoming Division of Air Quality to identiff amendments necessary to support the Naughton Unit 3 natural gas conversion and to clearly document the compliance requirements and timeline for implementation of the project under the RegionalHaze program. In the 2013 IRP Update, the resource needs assessment and updated resource portfolio continues to reflect a gas conversion completed by summer 2015. Since 2010, no significant activity has occurred with respect to the development of a federal renewable portfolio standard (RPS). [n addition, current political environments are shifting focus from items such as the extension of federal incentives for renewables and portfolio standards to EPA's development of greenhouse gas standards. Accordingly, the 2013 IRP Update assumes no federal RPS requirement over the course of the planning horizon. With the removal of the federal RPS assumptions requirements, the updated resource portfolio shows a reduced need for renewable resources required solely to meet state RPS obligations in2024 and2025. After PacifiCorp filed the 2013IRP, President Obama issued a Presidential Memorandum in June 2013 directing EPA to issue standards, regulations, or guidelines, as appropriate that address greenhouse gas emissions from modified, reconstructed, and existing power plants. The proposed standards, regulations, or guidelines are to be issued by June 1, 2014, finalized by June 1,2015, with implementation of regulations as proposed in SIPs required by June 30,2016. EPA would then review the implementation plan proposed by each state, and the effective compliance dates for these standards, regulations, or guidelines would become applicable sometime thereafter. Absent information on how EPA intends to proceed with its rule-making process, and without any information on how individual states will propose to implement those regulations through a SlP, there is currently no means to develop a specific CO2 price assumption that accurately reflects potential CO2 regulation. PacifiCorp's review of current third-party CO2 price forecasts shows that despite issuance of the Presidential Memorandum, these forecasters have not materially altered either their assumed COz start date or price level. In the 2013 IRP Update, PacifiCorp continues to assume a COz price signal beginning 2022 at $16/ton escalating at three percent plus inflation thereafter, and expects to update its COz policy assumptions and scenarios in the 2015 IRP, taking into consideration the proposed standard, regulation, or guidelines expected to be issued by EPA later this year. Figure ES.3 shows the 2013 IRP Update resource need, prior to acquiring any new resources, alongside the resource need from the 2013 IRP and the fall 2013 ten-year business plan. Overall, PACFICORP - 20 13 IRP UPDATE D{ECUTTVE SUMMARY the forecasted need has declined with the most recent needs assessment. Primarily driven by an updated load forecast, the most recent resource needs assessment shows an average reduction in peak resource need of approximately 320 megawatts (MW) as compared to the 2013 IP.P for the period 2014-2023. Relative to the fall2013 ten-year business plan, the most recent projection of resource need is reduced by approximately 135 MW over the same period. Figure ES.3 - Capacity Position Comparison, 2013 IRP versus Business Plan versus 2013 IRP Update (Lm) I Itr,ml- (4m) (1m; (3,m0) r 2013 IRP r Burbocr Plrn Table ES.l reports the 2013 IRP Update resource portfolio and a comparison of portfolio changes relative to the 2013 IRP Preferred Portfolio.l The table shows the resource mix targeted to fill the resource need summarized above with resource capacities at time of coincident system peak reported in the years for which the resources are available to meet summer peak loads. As compared to the 2013 IRP Preferred Portfolio, the changes in resource mix for the 2014-2023 planning period are minor. Relative to the 2013 IRP Preferred Portfolio, which did not include any significant new thermal resources in the front ten years of the planning horizon, the updated resource portfolio shows a reduction in front office transactions (FOTs), consistent with a reduced resource need. As was the case in the 2013 IRP Preferred Portfolio, PacifiCorp continues to plan to meet its customers' needs largely through acquisition of cost effective energy efficiency resources and FOTs over the next ten years. Considering the relatively small changes in energy efficiency resources between the 2013 IRP and 2013 IRP Update portfolios, PacifiCorp has not modified its 2013 IRP Action Plan and continues to target accelerated energy efficiency savings. I A comparison ofthe portfolio changes relative to the fall 2013 ten-year business plan is presented in Chapter 5. 4 PACIFICoRP - 2013 IRP UPDATE EXECUTIVE SutrmaeRv Table ES.l - Comparison of 2013IRP Update with 2013 IRP Preferred Portfolio Frcnt Ofice TMtbE h rcsue total re I Glsr a]wge. * Lcss 2013 IRP Prcferred Portfolio Frcrt Ofto Tffietbrc il resuce total re 10-yeu awnge. * PacifiCorp has not modified its 2013 IRP Action Plan, which remains consistent with the updated resource needs assessment and resource portfolio as summarized above. Chapter 6 of this IRP Update provides a status update of PacifiCorp's 2013 IRP Action Plan action items. A variety of action items have been completed and are noted as such, while other action items will continue forward into the 2015 IRP process. PecmrConp - 2013 IRP Upoere CHAPTER I - INTRoDUCTION CuaprER 1 - INTNODUCTION This 2013 Integrated Resource Plan Update (2013 IRP Update) describes resource planning activities that occurred subsequent to the filing of the 2013 Integrated Resource Plan (2013 IRP) in April 2013, presents an updated resource needs assessment, an updated resource portfolio consistent with changes in the planning environment, and provides an IRP Action Plan status update. In presenting the updated resource needs assessment and updated resource portfolio, PacifiCorp shows changes relative to the 2013 IRP and relative to PacifiCorp's fall 2013 ten-year business plan (Business Plan), which covers the 2014 to 2023 planning horizon. In this update PacifiCorp also addresses recommendations and requirements identified by its state regulatory commissions during the 2013 IRP acknowledgement process. In support of its business planning process, PacifiCorp refined the 2013 IRP Preferred Portfolio to reflect updates to forecasted loads, resources, market prices, and other model inputs. PacifiCorp's business planning process also considers capital expenditure and operating cost constraints with input from the PacifiCorp business units (PacifiCorp Energy, Pacific Power, and Rocky Mountain Power). Consideration of both capital and operating cost constraints is critical to ensure that PacifiCorp's business plan is financially supportable and affordable to customers. The 2013 IRP Preferred Portfolio served as the primary basis in establishing the resource portfolio for the Business Plan, and as summarized herein, differences between the two resource portfolios are minor. A similar process has been completed to develop the resource needs assessment and resource portfolio for this 2013 IRP Update, which considers updates to forecasted loads, resources, market prices, and other model inputs since the intervening Business Plan resource portfolio was developed. For purposes of assessing an updated resource needs assessment and updated resource portfolio in this 2013 tRP Update, PacifiCorp has not completed new financial analysis of pending environmental compliance decisions applicable to specific coal units on its system. PacifiCorp will analyze specific environmental compliance decisions applicable to Cholla Unit 4, Wyodak, and Dave Johnston Unit 3 in its 2015 IRP, with the full engagement of PacifiCorp's diverse stakeholder group. PacifiCorp will also provide an update on its efforts working with the Wyoming Division of Air Quality to identiff amendments necessary to support the Naughton Unit 3 natural gas conversion and to clearly document the compliance requirements and timeline for implementation of the natural gas conversion under the RegionalHaze program. In this 2013 IRP Update, PacifiCorp continues to assume the Naughton Unit 3 natural gas conversion is completed by summer 2015. The 2013 IRP Update also addresses recommendations and requirements identified by its state regulatory commissions during the 2013 acknowledgement process. This includes presentation of solar resource modeling sensitivities developed in response to a request by the Public Service Commission of Utah (PSCU) of and analysis of how CO2 price and natural gas price assumptions affect the analysis of environmental compliance decisions for specific coal units as requested by the Washington Utilities and Transportation Commission. This report first describes the current planning environment, load updates, resource updates, emissions/climate change regulatory outlook, and Energy Gateway transmission planning and PACTFTCoRP - 201 3 IRP Upoarp CrnpreR I - INTRoDUCTIoN project completion forecast (Chapter 2). Next, Chapters inputs and assumptions relative to those used for the 2013 then presented along with a status update on the 2013 respectively). Appendices include the following: . Appendix A - Additional Load Forecast Details. Appendix B - Executive Summary of the CHP Study. Appendix C - Energy Analysis Report. Appendix D - Accelerated DSM Decrement Studyo Appendix E - Correction to 2013 IRP Table A.7 3 and 4 describe the changes to key IRP. The updated resource portfolio is IRP Action Plan (Chapters 5 and 6, o Redacted Appendix F - Breakeven Analysis for Select Coal-Fired Plants PecrrICoRp - 20 13 IRP UPDATE Crupren 2 -Prer.rNnrc ENvIRoNMENT CHapTER 2 - PTANNING ENvTnONMENT The 2013 IRP Preferred Portfolio served as the basis for the resource assumptions used in PacifiCorp's fall 2013 ten-year business plan (Business Plan), which covers the 2014 to 2023 planning horizon. Changes in the portfolio reflect updates to forecasted loads, resources, market prices, and other model inputs. PacifiCorp's business planning process also considers capital expenditure and operating cost constraints to ensure that the resulting business plan is financially supportable and affordable to customers. As it relates to PacifiCorp's resource plan, differences between the 2013 IRP Preferred Portfolio and the Business Plan portfolio are minor and consistent with an updated load forecast. The Business Plan portfolio also considers updated assumptions for the Energy Gateway transmission project, which continues to play an important role in the Company's commitment to provide safe, reliable, reasonably priced electricity to meet the needs of our customers. Several Energy Gateway developments have occurred since the Company's 2013 IRP was filed, including reaching construction and permitting milestones, adjusting in-service dates for future segments, and developing activities on joint-development projects. Accordingly, in-service dates have been updated relative to those assumed for the 2013 IRP. These date adjustments coincide with generation facility needs and load growth assumptions. ln March 2011, the state of Arizona submitted its RegionalHaze state implementation plan (SIP) to the Environmental Protection Agency (EPA) for review. The SIP requires currently installed low NOx burners (LNB) as best available retrofit technology (BART) for NOx emissions at Cholla Unit 4. By final rule dated December 5,2012, EPA disapproved portions of the Arizona Regional Haze SIP and issued a federal implementation plan (FIP). The FIP requires, among other things, installation of selective catalytic reduction (SCR) on Cholla Unit 4 by January 4, 2018. The FIP also institutes an averaged NOx emissions rate of 0.055 lb/MMBtu for Cholla Units 2, 3 and 4. In January and February 2013, PacifrCorp, the state of Arizona and other Arizona utilities filed separate appeals of EPA's FIP with the U.S. Ninth Circuit Court of Appeals. In February 2013, PacifiCorp and other Arizona utilities filed petitions for reconsideration at the EPA and requests for administrative stay of the FIP until judicial appeals are completed. In March 2013, PacifiCorp and other Arizona utilities filed motions for judicial stay of the FIP with the U.S. Ninth Circuit Court of Appeals until the appeals are complete. On April 3,2013, the court consolidated the various appeals into a single docket before a single judicial panel. On April 9, 2013, EPA granted various petitions for reconsideration for the averaged NOx emissions rate only, but has taken no further action to date. Although EPA may propose a new NOx rate at some time in the future, which will undergo public comment, it is not under any timing requirement to do so. EPA did not address the various requests for administrative stay in its April 9,2013 action. PACIFICoRP - 2OI3 IRP UPDATE CHAPTER 2 -PLANNING ENVIRONMENT On April 23,2013, the court set the following case schedule: o June 2013 - briefing on motions for judicial stay to be completedo January 2014 - briefing on the merits of appeals to be completed On September 9, 2013, the court denied the motions for sky. The court is now expected to issue a final decision on the appeals in 2015. However, there are no mandatory dates by which the court must issue decisions. With the denial of requests for administrative stay and judicial stay, the January 4, 2018 compliance deadline for installing SCR at Cholla Unit 4 remains in place. PacifiCorp continues to work closely with the state of Arizona and the other Arizona utilities in connection with the now consolidated appeals. Various environmental groups have intervened in the appeals in support of EPA's FIP. With the ongoing activities outlined above, PacifiCorp continues to explore potential alternatives to the installation of SCR at Cholla Unit 4, and consequently, the Company has not finalized an analysis of compliance alternatives nor made a decision on this pending investment. The Company intends to finalize its analysis in20l4 and will file its analysis in a future IRP filing.2 For purposes of the 2013 IRP Update, PacifiCorp assumes Cholla Unit 4 continues to provide both system capacity and energy through the planning horizon. PacifiCorp faces a continuously changing environment with regard to electricity plant emission regulations. Although the exact nature of these changes remains uncertain, they are expected to impact the cost of future resource alternatives and the cost of existing resources in the Company's generation portfolio. PacifiCorp monitors these regulations to determine the potential impact on its generating assets. PacifiCorp also participates in the rulemaking process by filing comments on various proposals, participating in scheduled hearings, and providing assessment of such proposals. Federal Climate Change Legislation PacifiCorp continues to evaluate the potential impact of climate change legislation at the federal level. The impact of a given legislative proposal can vary significantly depending on selection of key design criteria (i.e., level of emissions cap, rate of decline of the cap, the use of carbon offsets, allowance allocation methodology, the use of safety valves, etc.) and macro-economic assumptions (i.e., electricity load growth, fuel price impacts - especially natural gas, commodity prices, new technologies, etc.). To date, no federal legislative climate change proposal has successfully been passed by both the U.S. House of Representatives and the U.S. Senate for consideration by the President. The two most prominent legislative proposals introduced for attempted passage through Congtess have 'The Public Utility Commission of Oregon's draft 2013 IRP acknowledgement order outlines a requirement for PacifiCorp to make a supplemental IRP filing on Cholla Unit 4 ir,20l4. With the appropriate protections in place, PacifiCorp intends to summarize the information from this filing for its broader stakeholder group during the 2015 IRP public process and summarize this same analysis in a confidential volume of the 2015 IRP. l0 PaCrrICOnp _ 20 13 IRP UPDATE Cseprsn 2 - PLANNTNG ENvTRoNMENT been the Waxman-Markey bill in 2009 and the Kerry-Lieberrnan bill in 2010; neither measure was able to accumulate enough support to pass. The ll3ft Congress was challenged by the President to pursue a bipartisan, market-based solution to climate change. The President stated that if Congress did not act soon, then he would direct his Cabinet to implement executive action to reduce greenhouse gas (GHG) emissions. To date, such bipanisan action has not occurred. ln 2013, a bill was introduced by the Energy & Power Subcommittee Chairman Whitfield (R-KY) called the Electricity Security and Affordability Act, which provides direction to EPA regarding the establishment of standards for GHG emissions from fossil-fueled generating facilities. This bill is expected to pass the House of Representatives but not the Senate. On June 25,2013, President Obama directed the EPA to complete GHG standards for both new and existing power plants. With regard to existing sources, EPA was directed to issue "standards, regulations, or guidelines, as appropriate" that address GHG emissions from modified, reconstructed, and existing power plants.3 The proposed standards, regulations, or guidelines are to be issued by June l, 2014, finalized by June I , 2015, with implementation of regulations as proposed in state implementation plans required by June 30,2016. EPA would then review the implementation plan proposed by each state. The June 25, 2013 directive did not include detail with respect to how EPA will approach GHG regulation or what the resulting standards, regulations, or guidelines will ultimately entail. Federal Renewable Portfolio Standards Since 2010, no significant activity has occurred with respect to the development of a federal renewable portfolio standard (RPS). In addition, current political environments are shifting focus from items such as the extension of federal incentives for renewables and portfolio standards to EPA's development of greenhouse gas standards. Accordingly, the 2013 IRP Update assumes no federal RPS requirement over the course of the planning horizon. New Source Review / Prevention of Significant Deterioration (NSR / PSD) On May 13,2010, the EPA issued a final rule that addresses GHG emissions from stationary sources under the Clean Air Act (CAA) permiuing programs, known as the "tailoring" rule. This final rule sets thresholds for GHG emissions that define when permits under the New Source Review (NSR) / Prevention of Significant Deterioration (PSD) and Title V Operating Permit programs are required for new and existing industrial facilities. This final rule "tailors" the requirements of these CAA permitting programs to limit which facilities will be required to obtain PSD and Title V permits. The rule also establishes a schedule that will initially focus CAA permiuing programs on the largest sources with the most CAA permitting experience. Finally, the rule expands to cover the largest sources of GHGs that may not have been previously covered by the CAA for other pollutants. 3 Presidential Memorandum - Power Sector Carbon Pollution Standards, June 25, 2013. ll PACIFICoRP _ 20 I3 IRP Upoerg CHAPTER 2 _PLANNTNG ENVIRONMENT Guidance for Best Available Control Technology (BACT) On November 10, 2010, the EPA published a set of guidance documents for the tailoring rule to assist state permitting authorities and industry permiuing applicants with the Clean Air Act PSD and Title V permitting for sources of GHGs. Among these publications was a general guidance document entitled "PSD and Title V Permitting Guidance for Greenhouse Gases," which included a set of appendices with illustrative examples of Best Available Control Technology (BACT) determinations for different types of facilities, which are a requirement for PSD permitting. The EPA also provided white papers with technical information concerning available and emerging GHG emission control technologies and practices, without explicitly defining BACT for a particular sector. In addition, the EPA has created a "Greenhouse Gas Emission Strategies Database," which contains information on strategies and control technologies for GHG mitigation for two industrial sectors: electricity generation and cement production. The guidance does not identiff what constitutes BACT for specific types of facilities, and does not establish absolute limits on a permitting authority's discretion when issuing a BACT determination for GHGs. lnstead, the guidance emphasizes that the five-step top-down BACT process for criteria pollutants under the CAA generally remains the same for GHGs. While the guidance does not prescribe BACT in any area, it does state that GHG reduction options that improve energy efficiency will be BACT in many or most instances because they cost less than other environmental controls (and may even reduce costs) and because other add-on controls for GHGs are limited in number and are at differing stages of development or commercial availability. Utilities have remained very concerned about the NSR implications associated with the tailoring rule (the requirement to conduct BACT analysis for GHG emissions) because of great uncertainty as to what constitutes a triggering event and what constitutes BACT for GHG emissions. New Source Performance Standards (NSPS) for Greenhouse Gases On December 23,2010, in a settlement reached with several states and environmental groups in New York v. EPA, the EPA agreed to promulgate emissions standards covering GHGs from both new and existing electric generating units under Section I I I of the CAA by July 26,2011 and issue final regulations by May 26, 2012.4 NSPS are established under the CAA for certain industrial sources of emissions determined to endanger public health and welfare and must be reviewed every eight years. While NSPS were intended to focus on new and modified sources and effectively establish the floor for determining what constitutes BACT, the emission guidelines will apply to existing sources as well. In September 2013, the EPA issued a revised NSPS proposal for new fossil-fueled generating facilities and withdrew its April2012 NSPS proposal. The new proposal would limit emissions of carbon dioxide to 1,000 pounds per megawatt hour (MWh) for large natural gas plants and 1,100 pounds per MWh for smaller natural gas plants. The revised proposal continues to largely exempt simple cycle combustion turbines from meeting the standards. The standard for new coal units would be set based on the availability of panial carbon capture and sequestration technology. The public comment period will close in May 2014 and a final rule is expected in June 2014. 4 The deadlines for EPA to take proposed and final actions have since been extended. EPA also entered into a similar settlement the same day to address GHG emissions from refineries with proposed regulations by December 15,2011 and final regulations by November 15,2012, t2 PecrICoRp _ 20 13 IRP UPDATE CHAPTER 2 _PLA}.INTNG ENVIRoNMENT In January 2014, Senate Minority Leader Mitch McConnell (R-KY) filed a resolution of disapproval in an attempt to block EPA's NSPS for GHG emissions from new fossil-fueled power plants. A vote has not yet been scheduled on this resolution. In addition, in January 2014 the State of Nebraska sued the EPA in federal district court arguing that the rule's requirements for carbon capture and sequestration wrongfully rely on federally funded and unviable control technology. In support of this claim Nebraska relies on a provision of the Energy Policy Act of 2005 which restricts reliance on technology developed with federal assistance when setting performance standards. The EPA is also under a consent decree obligation to establish GHG NSPS for modified and existing sources. Consistent with the presidential directive mentioned above, EPA has indicated that it will issue a proposed rule for existing sources in June 2014.The proposed rule to be issued by the EPA for modified and existing sources is to be used by states to develop plans for reducing emissions and/or emissions intensity and may include targets based on demonstrated controls, efficiency related emission reductions, or even beyond the fence-line compliance alternatives intended to meet best system of emissions reduction parameters. States are expected to be required to submit their implementation plans to the EPA by June 2016 pursuant to the President's direction. States are expected to have the ability to apply less stringent standards or longer compliance schedules if they demonstrate that following the federal guidelines is unreasonably cost-prohibitive, physically impossible, or that there are other factors that reasonably preclude meeting the guidelines. States may also impose more stringent standards or shorter compliance schedules. Several categories of EPA regulations for non-GHG emissions are discussed below: Clean Air Act Criteria Pollutants - National Ambient Air Quality Standards The CAA requires the EPA to set National Ambient Air Quality Standards (NAAQS) for certain pollutants considered harmful to public health and the environment. For a given NAAQS, the EPA and/or a state identifies various control measures that once implemented are meant to achieve an air quality standard for a certain pollutant, with each standard rigorously vetted by the scientific community, industry, public interest groups, and the general public. Particulate matter (PM), sulfur dioxide (SOz), ozone (O3), nitrogen dioxide (NOz), carbon monoxide (CO), and lead are often grouped together because under the CAA, each of these categories is linked to one or more NAAQS. These "criteria pollutants", while undesirable, are not toxic in typical concentrations in the ambient air. Under the CAA, they are regulated differently from other types of emissions, such as hazardous air pollutants and GHG. Within the past few years, the EPA established new standards for particulate matter, sulfur dioxide, and nitrogen dioxide. The EPA is currently tasked with reviewing ozone standards, as well. t3 PecrrConp - 2013 IRP Upoere CHAPTER 2 _PLANNING ENVIRoNMENT Clean Air Transport Rule In July 2009, EPA proposed its Clean Air Transport Rule (Transport Rule), which would require new reductions in SOz and nitrogen oxide (NOy) emissions from large stationary sources, including power plants, located in 3l states and the District of Columbia beginning in 2012. The Transport Rule was intended to help states attain NAAQS set in 1997 for ozone and fine particulate matter emissions. The rule replaced the Bush administration's Clean Air Interstate Rule (CAIR), which was vacated in July 2008 and rescinded by a federal court because it failed to effectively address pollution from upwind states that is hampering efforts by downwind states to comply with ozone and PM NAAQS. While the rule was finalized as the Cross-State Air Pollution Rule (CSAPR) in July 2011, litigation in the D.C. Circuit Court of Appeals resulted in a stay on the implementation of the CSAPR in December 201 I . Ultimately, in August 2012, the D.C. Circuit Court of Appeals vacated the CSAPR in a 2-l decision after it determined the rule exceeded the EPA's statutory authority. The EPA sought a full review of the CSAPR ruling by the entire D.C. Circuit; however, in January 2013, the court denied the request. In June 2013, a petition for certiorari filed by EPA was granted by the U.S. Supreme Court, meaning until the Supreme Court issues a decision or a replacement rule is adopted and implemented, the CAIR remains in place. PacifiCorp does not own generating units in states identified by the CAIR or CSAPR and thus will not be directly impacted; however, the Company intends to monitor amendments to these rules closely in the event that the scope of a replacement rule extends the geographic scope of impacted states. Regional Haze EPA's rule to address Regional Haze visibility concerns will drive additional NO* reductions particularly from facilities operating in the Western United States, including the states of Utah and Wyoming where PacifiCorp operates generating units, in Arizona where PacifiCorp owns but does not operate a coal unit, and in Colorado and Montana where PacifiCory has partial ownership in generating units operated by others, but nonetheless subject to the Regional Haze Rule. On June 15, 2005, EPA issued final amendments to its July 1999 Regional Haze rule. These amendments apply to the provisions of the Regional Haze rule that require emission controls known as BART, for industrial facilities meeting certain regulatory criteria that with emissions that have the potential to impact visibility. These pollutants include PMz.s, NOx, SOz, certain volatile organic compounds, and ammonia. The 2005 amendments included final guidelines, known as BART guidelines, for states to use in determining which facilities must install controls and the type of controls the facilities must use. States were given until December 2007 to develop their implementation plans, in which states were responsible for identiffing the facilities that would have to reduce emissions under BART as well as establishing BART emissions limits for those facilities. The state of Utah issued a regional haze state implementation plan (SIP) requiring the installation of SOz, NO* and particulate matter (PM) controls on Hunter Units I and 2 and Huntington Units I and 2.In December 2012, the EPA approved the SOz portion of the Utah Regional Haze SIP and disapproved the NO* and PM portions. Certain groups have appealed the EPA's approval of t4 PecnrConp - 2013 IRP Upoare CHAPTER 2 _PLAI.INING ENVIRoNMENT the SOz SIP. PacifiCorp and the state of Utah appealed EPA's disapproval of the NO* and PM SIP. In addition, and separate from the EPA's approval process and related litigation, the Utah Division of Air Quality is undertaking an additional BART analysis for each of Hunter Units I and2 and Huntington Units I and2, which will be provided to the EPA as a supplement to the existing Utah SIP. It is unknown whether and how the Utah Division of Air Quality's supplemental analysis will impact the EPA's approval and disapproval of the existing SIP. The state of Wyoming issued two regional haze SIPs requiring the installation of SOz, NO* and PM controls on certain PacifiCorp coal-fueled generating facilities in Wyoming. The EPA approved the SOz SIP in December 2012, but initially proposed to disapprove portions of the NO" and PM SIP and instead issue a FIP. However, in 2013, the EPA issued a re-proposal of a NO* and PM FIP which included substantial changes to the control equipment required in the original proposal. On January 10,2014, the EPA issued a final action which largely approved the original Wyoming SIP. Ultimately, EPA's final determination requires installation of the following NO* and PM controls at PacifiCorp facilities: SCR equipment and a baghouse at Naughton Unit 3 by December 31,2014; SCR equipment at Jim Bridger Unit 3 by December 31, 2015; SCR equipment at Jim Bridger Unit 4 by December 31, 2016; SCR equipment at Jim Bridger Unit I by December 31, 2022; SCR equipment at Jim Bridger Unit 2 by December 31, 2021; SCR within five years or a commitment to shut down in 2027 at Dave Johnston Unit 3; and SCR at Wyodak within 5 years. With respect to Naughton Unit 3, EPA indicated its support for the conversion of the unit to natural gas and that it would expedite action relative to consideration of the gas conversion once the state of Wyoming submitted the requisite SIP amendment. The EPA action became final on March 3,2014.In the meantime, certain groups have appealed the EPA's approval of the Wyoming SOz SIP which, consistent with the Utah SO2 SIP, required emission reductions of SOz to be enforced through a three-state milestone and backstop trading program. EPA's final action on the Wyoming NO* and PM SIP may also be appealed. The state of Arizona issued a Regional Haze SIP requiring, among other things, the installation of SOz, NO* and PM controls on Cholla Unit 4, which is owned by PacifiCorp but operated by Arizona Public Service. The EPA approved in part, and disapproved in part, the Arizona SIP and issued a FIP for the disapproved portions. PacifiCorp filed an appeal in the Ninth Circuit Court of Appeals regarding the FIP as it relates to Cholla Unit 4, and the Arizona Department of Environmental Quality and other affected Arizona utilities filed separate appeals of the FIP as it relates to their interests. Mercury and Hazardous Air Pollutants ln March 2005, the EPA issued the Clean Air Mercury Rule (CAMR) to permanently limit and reduce mercury emissions from coal-fired power plants under a market-based cap-and-trade program. However, the CAMR was vacated in February 2008, with the court finding the mercury rules inconsistent with the stipulations of Section I l2 of the CAA. The vacated CAMR was replaced by EPA with the more extensive Mercury and Air Toxics Standards (MATS) with an effective date of April 16, 2012. The MATS rule requires that new and existing coal-fueled facilities achieve emission standards for mercury, acid gases and other non-mercury hazardous air pollutants. Existing sources are required to comply with the new standards by April 16, 2015. Individual sources may be granted up to one additional year, at the t5 PACFICoRP _ 20 13 IRP UPDATE CHAPTER 2 _ PLANNING ENVIRoNMENT discretion of the Title V permitting authority, to complete installation of controls or for transmission system reliability reasons. While the final MATS requirements continue to be reviewed by PacifiCorp, the Company believes its emission reduction projects completed to date or currently permiued or planned for installation, including the scrubbers, baghouses and electrostatic precipitators required under other EPA requirements, are consistent with achieving the MATS requirements and will support PacifiCorp's ability to comply with the final standards for acid gases and non-mercury metallic hazardous air pollutants. PacifiCorp will be required to take additional actions to reduce mercury emissions through the installation of controls or use of sorbent injection at certain of its coal-fueled generating facilities and otherwise comply with the standards. PacifiCorp continues to plan for retirement of its Carbon facility in early 2015 as the least-cost altemative to comply with MATS and other environmental regulations. lmplementation of the transmission system modifications necessary to maintain system reliability following disconnection of the Carbon facility generators from the grid are underway. Coal Combustion Residuals Coal Combustion Residuals (CCRS), including coal ash, are the byproducts from the combustion of coal in power plants. CCRs are currently considered exempt wastes under an amendment to the Resource Conservation and Recovery Act (RCRA); however, EPA proposed in 2010 to regulate CCRs for the first time. EPA is considering two possible options for the management of CCRs. Both options fall under the RCRA. Under the first option, EPA would list these residual materials as special wastes subject to regulation under Subtitle C of RCRA with requirements from the point of generation to disposition including the closure of disposal units. Under the second option, EPA would regulate coal combustion residuals as nonhazardous waste under Subtitle D of RCRA and establish minimum nationwide standards for the disposal of coal combustion residuals. Under either option for regulation, surface impoundments utilized for coal combustion byproducts would have to be closed unless they could meet more stringent regulatory requirements. PacifiCorp operates 16 surface impoundments and six landfills that contain coal combustion byproducts. The public comment period on EPA's proposal to regulate coal combustion byproducts closed in November 2010 and the EPA has indicated that the rule will be finalized in2014.In a preamble to the recently proposed effluent guideline limitations discussed herein, EPA stated that non- hazardous management of CCRs may be adequate. Water Quality Standards Cooling Water Intake Structures The federal Water Pollution Control Act ("Clean Water Act") establishes the framework for maintaining and improving water quality in the United States through a program that regulates, among other things, discharges to and withdrawals from waterways. The Clean Water Act requires that cooling water intake structures reflect the "best technology available for minimizing adverse environmental impact" to aquatic organisms. In July 2004, the EPA established significant new technology-based performance standards for existing electricity generating l6 PecHCoRp - 2013 IRP Upoers CHAPTER 2 _PLANNING ENVIRoNMENT facilities that take in more than 50 million gallons of water per day. These rules were aimed at minimizing the adverse environmental impacts of cooling water intake structures by reducing the number of aquatic organisms lost as a result of water withdrawals. In response to a legal challenge to the rule, in January 2007, the Court of Appeal for the Second Circuit remanded almost all aspects of the rule to the EPA without addressing whether companies with cooling water intake structures were required to comply with these requirements. On appeal from the Second Circuit, in April 2009, the U.S. Supreme Court ruled that the EPA permissibly relied on a cost-benefit analysis in setting the national performance standards regarding best technology available for minimizing adverse environmental impact at cooling water intake structures and in providing for cost-benefit variances from those standards as part of the $316(b) Clean Water Act Phase II regulations. The Supreme Court remanded the case back to the Second Circuit Court of Appeals to conduct further proceedings consistent with its opinion. In March 2011, the EPA released a proposed rule under $316(b) of the Clean Water Act to regulate cooling water intakes at existing facilities. The proposed rule establishes requirement for electric generating facilities that withdraw more than two million gallons per day, based on total design intake capacity, of water from waters of the U.S. and use at least 25 percent of the withdrawn water exclusively for cooling purposes. PacifiCorp's Dave Johnston generating facility withdraws more than two million gallons per day of water from waters of the U.S for once-through cooling applications. Jim Bridger, Naughton, Gadsby, Hunter, Carbon and Huntington generating facilities currently utilize closed cycle cooling towers but withdraw more than two million gallons of water per day. The proposed rule includes impingement (i.e., when fish and other aquatic organisms are trapped against screens when water is drawn into a facility's cooling system) mortality standards to be met through average impingement mortality or intake velocity design criteria and entrainment (i.e., when organisms are drawn into the facility) standards to be determined on a case-by-case basis. The standards are required to be met as soon as possible after the effective date of the final rule, but no later than eight years thereafter. While the rule was required to be finalized by the EPA by July 2012, the rule is now expected to be finalized in the second quarter of 2014. Assuming the final rule in that timeframe, PacifiCorp's generating facilities impacted by the final rule will be required to complete impingement and entrainment studies by mid-2015. El/luent Limit G uidelines EPA first issued effluent guidelines for the Steam Electric Power Generating Point Source Category (i.e., the Steam Electric effluent guidelines) in 1974 with subsequent revisions in 1977 and 1982. On April 19,2013, EPA proposed revised effluent limit guidelines and is required, under the terms of a stipulated extension to a consent decree, to finalize the rule by May 2014. Until the technology-based effluent limitation guidelines are finalized, PacifiCorp is incorporating proxy compliance costs for certain units reasonably likely to be impacted by the rule into its business plans and analyses. Of importance to note, the effluent limit guidelines will also apply to gas-fired generation. While national GHG legislation has not been successfully adopted, state initiatives continue with the active development of climate change regulations that will impact PacifiCorp. t7 PACIFICoRP _ 20 13 IRP Upoerr Cueprgn 2 -PLANTNTNG ENvTRoNMENT California An executive order signed by California's governor in June 2005 would reduce GHGs emissions in that state to 2000 levels by 201 0, to I 990 levels by 2020 and 80 percent below I 990 levels by 2050. In 2006, the California Legislature passed, and Governor Schwarzenegger signed, Assembly Bill 32, the Global Warming Solutions Act of 2006, which set the 2020 GHG emissions reduction goal into law. It directed the California Air Resources Board (CARB) to begin developing discrete early actions to reduce GHG while also preparing a scoping plan to identiS how best to reach the 2020 limit. Pursuant to the authority of the Global Warming Solutions Act, in October 2011, CARB adopted a GHG cap-and-trade program with an effective date of January 1,2012; compliance obligations were imposed on regulated entities beginning in2013. The first auction of GHG allowances was held in California in November 2012 and the second auction in February 2013. PacifiCorp is required to sell, through the auction process, its directly allocated allowances, and purchase the required amount of allowances necessary to meet its compliance obligations. In October 2013, CARB kicked off an Assembly Bill 32 scoping plan update designed to build upon the initial scoping plan. The scoping plan update defines climate change priorities for the next five years and sets the groundwork for post-2020 climate goals. A proposed first update issued in February 2014 indicated a post-2020 GHG reduction goal of 80 percent below 1990 levels by 2050. Oregon and Washington [n2007, the Oregon Legislature passed HB 3543 Global Warming Actions which establishes GHG reduction goals forthe state that (i) bV 2010, cease the growth of Oregon greenhouse gas emissions; (ii) by 2020, reduce greenhouse gas levels to l0 percent below 1990 levels; and (iii) by 2050, reduce greenhouse gas levels to at least 75 percent below 1990 levels. In 2009, the Legislature passed SB l0l which requires the Oregon Public Utility Commission (OPUC) to report to the Legislature before November I of each even-numbered year on the estimated rate impacts for Oregon's regulated electric and natural gas companies associated with meeting the GHG reduction goals of I 0 percent below 1990 levels by 2020 and 1 5 percent below 2005 levels by 2020. The OPUC submitted its most recent report November 1,2012. On July 3 2013, the Oregon Legislature passed Senate Bill 306 which directs the legislative revenue officer to prepare a report examining the feasibility of imposing a clean air fee or tax as a new revenue option. The report is to include an evaluation of how to treat imported and exported energy sources. A final report is expected November 1,2014. In 2008, the Washington State Legislature approved the Climate Change Framework E2SHB 2815, which establishes state GHG emissions reduction limits. Washington's emission limits are to (i) by 2020, rcduce emissions to 1990 levels; (ii) by 2035, reduce emissions to 25 percent below 1990 levels; and (iii) by 2050, reduce emissions to 50 percent below 1990 levels, or 70 percent below Washington's forecasted emissions in 2050. The Washington Legislature established the Climate Legislative and Executive Workgroup to develop recommendations to achieve the state's GHG emission limits. The workgroup issued two reports in January 2014; both reports included recommendations to continue workgroup efforts through 2014. l8 PACIFICoRP _ 20 13 IRP UPDATE Cueprsn 2 - PLANNTNc ENVTRoNMENT Greenhouse Gas Emission Performance Standards California, Oregon and Washington have all adopted GHG emission performance standards applicable to all electricity generated within the state or delivered from outside the state that is no higher than the GHG emission levels of a state-of-the-art combined-cycle natural gas generation facility. The standards for Oregon and California are currently set at 1,100 pounds of carbon dioxide equivalent per MWh, which is defined as a metric measure used to compare the emissions from various GHG based upon their global warming potential. In March 2013, the Washington Department of Commerce issued a new rule, effective April 6,2013,lowering the emissions performance standard to 970 pounds of carbon dioxide per MWh. As discussed in the 2013 IRP, the Energy Gateway transmission project continues to play an important role in the Company's commitment to provide safe, reliable, reasonably priced electricity to meet the needs of our customers. Energy Gateway's design and extensive footprint provides needed system reliability improvements and supports the development of a diverse range of cost-effective resources required for meeting customers' energy needs. The IRP has incorporated Energy Gateway as part of a solution for delivering the least cost resource portfolio for multiple IRP planning cycles. PacifiCorp continues to develop methods, in parallel with current industry best practices and regional transmission planning requirements, to better quantiff all the benefits of transmission that are essential to serve customers. For example, Energy Gateway is designed to relieve operating limitations, increase capacity, and improve operations and reliability in the existing electric transmission grid. Several Energy Gateway developments have occurred since the Company's 2013 IRP was filed, including reaching construction and permitting milestones, adjusting in-service dates for future segments, and developing activities on joint-development projects. Also, in response to feedback from interested stakeholders, the Company has completed its 2013 IRP Action Plan item to solicit feedback from stakeholders regarding the System Operational and Reliability Benefit Tool (SBT) that identifies and quantifies a range of transmission benefits. Please see Chapter 6 for status updates on the 2013 IRP Action Plan. An updated Energy Gateway map is provided below as Figure 2.1. l9 PACIFICoRP _ 20 I3 IRP UPDATE CHapren 2 - PLANNTNG ENvTRoNMENT Figure 2.1 - Energy Gateway Map WASHINGTON *ag Jr..tril MONTANA tg-! I/sG o IDAHO MING CALIFORN IA !t.(fl-l-t<rloul NEVADA cotoRADo ff PrdffCorp retatl scrvk€ arca Na tranrmirsirn lhcr: - Sfi) kV mlninum rolage - 3{5 kV mlnimum volage - 230 kV mhrnrm rolage O Existhg srlstetbn O Ncrv sub.ai:o Enerry Gateway Transmission Project Updates Wallula to McNary (Seernent A): The OPUC issued a Certificate of Public Convenience and Necessity (CPCN) in September 20ll.In2013, the project was delayed to allow customers to determine their need as it pertains to ongoing projects and ability to move resources to their markets. Once the customer need decision is made the future of the project will be determined and communicated to landowners and stakeholders. Mona to Oquirrh (Segment C): Project construction is complete and the line was placed into service in May 2013. Mona to Oquirrh is the second major segment of Energy Gateway to be constructed, following Populus to Terminal (Segment B) which was placed in service in November 2010. Timing of Oquirrh to Terminal continues to be evaluated and the in-service date adjusted accordingly. Please see Table 2.1 below. Gateway West (Segments D and E): Under the National Environmental Policy Act, the Bureau of Land Management (BLM) has completed the Environmental Impact Statement (EIS) for the Gateway West project. The BLM released its final EIS on April 26, 2013, followed by the Record of Decision (ROD) on November 14,2013, providing a right-of-way grant for all of Segment D and part of Segment E. The agency chose to defer its decision on the western-most portion of the project located in Idaho in order to perform additional review of the Morley Nelson Snake River Birds of Prey Conservation Area. Specifically, the sections of Gateway West that were deferred for a later ROD include the sections of Segment E from Midpoint to Hemingway and Cedar Hill to Hemingway. Given delays in the permitting activity and the 20 PACIFICoRP _ 2OI3 IRP UPDATE CHAPTER 2 - PLANNING ENVIRONMENT bifurcation of the ROD, the in-service dates for Gateway West have been adjusted accordingly. Please see Table 2.1 below for updated segment in-service dates. Gateway South (Segment F): The BLM's Notice of Intent was published in the Federal Register in April 2011, followed by public scoping meetings throughout the project area. Comments on this project from agencies and other interested stakeholders were considered as the BLM developed the draft EIS, which was issued in February 2014. Sigurd to Red Butte (Segment G): The BLM issued a final record of decision in December 2012. ln March 2013, a CPCN was issued by the PSCU. Construction began in May 2013 and the project is on track to be placed into service in June 2015. West of Hemingway (Seement H): Energy Gateway Segment H represents a significant improvement in the connection between PacifiCorp's east and west control areas and will help deliver more diverse resources to serve PacifiCorp's Oregon, Washington and California customers. Originally planned as a single circuit 500 kV line from the Hemingway substation south of Boise, Idaho, to the Captain Jack substation near Klamath Falls, Oregon, the Company has continued to pursue alternative joint-development opportunities on other proposed lines west of Hemingway. In January 2012, the Company signed a permitting agreement with Idaho Power and the Bonneville Power Administration (BPA) on the proposed Boardman to Hemingway project. PacifiCorp further notes that it had a memorandum of understanding with Portland General Electric Company (PGE) with respect to the development of Cascade Crossing that terminated by its own terms. PacihCorp had continued to evaluate potential partnership opportunities with PGE once it announced its intention to pursue a Cascade Crossing solution with BPA. However, because PGE decided to end discussions with BPA and instead pursue other options, PacifiCorp will not be actively pursuing this development. PacifiCorp will continue to look to partner with third parties on transmission development as opportunities arise. able 2.1 - Enersv Gatewav Sesment In-Sr rvice Dates Segment A: Wallula to McNary 2013-20r4 Sponsor driven* Segment C: Mona to Oquirrh May 2013 Completed May 2013 Segment C: Oquirrh to Terminal June 2016 May 2017* Segment D: Windstar to Populus 2019-2021 2021-2024* Segment E: Populus to Hemingway 2020-2023 2020-2024* Segment F: Aeolus to Mona 2020-2022 2020-2022 Segment G: Sigurd to Red Butte June 2015 June 2015 Segment H: West of Hemingway Sponsor driven stnce 21 PACIFICoRP - 20 I 3 IRP Upo.IrE CHAPTER 3 _ RESoT,RCE NEEDS ASSESSMENT UpoaTT CHAPTER 3 _ RBSOURCE Npgos ASSpSSMENT Upoars This chapter presents the update to PacifiCorp's resource needs assessment, focusing on the 2014-2023 planning period covered by the fall 2013 ten-year business plan (Business Plan). Updates to the Company's long-term load forecast, resources, and capacity position are presented and summarized. Load Forecast PacifiCorp's Business Plan reflected an updated load forecast finalized in June 2013. Relative to the load forecast prepared for the 2013 IRP, PacifiCorp system sales initially decrease in the short term and then increase over the planning period. The primary driver of the changes in the forecast are an increase in the industrial forecast due to improving economic conditions and a decrease in the residential forecast due to changes in energy efficiency and lower average-use per customer. The coincident peak forecast decreased through the planning period due to decreases in forecast residential loads and a relatively flat peak load growth over the last five years. The coincident peak forecast decreased even though overall loads are increasing due to industrial and commercial class loads increasing relative to the decreasing residential loads and historically flat peak load growth over the last five years, which in turn reduces the long-term forecast peak load growth expectations. In October 2013, the Company updated the load forecast for the residential class loads. Due to lower than expected weather normalized residential usage in the summer of 2013, the Company incorporated February through August 2013 actual loads for the residential class. The change between the October 2013 forecast and the June 2013 forecast reflects the changes in the residential forecast. The October 2013 load forecast is used for the 2013 IRP Update resource needs assessment. Tables 3.1 and 3.2 rcport the October 2013 Q0l3lRP Update) annual load and coincident peak load forecasts, respectively. Note that these forecast data exclude load reduction projections from new energy efficiency measures (Class 2 DSM), since such load reductions are included as resources in the resource portfolio. 23 PecrrConp - 20 13 IRP Upnars Cgeprgn.3 -RrsoURCE NEEDs AssessugNT UPDATE Table 3.1 - October 2013 Q0l3 IRP Update): Forecasted Annual Load Growth, 2014 through 2023 (Megawatt-hours) 2014 61.671.810 14.y23.3ffi 4.486.7W 893.190 25.045.480 0.363.830 3.718.360 22q.890 2015 63220.770 15.189220 4.518200 8%.110 25.029.690 0.579.850 3.744.330 2263.370 2016 63.s43.020 15.330.480 4.567.610 902.370 27.06/..tw 0.799.120 3-777-310 l-l0l-950 2017 63.426.044 15.523.770 4-592.920 903.900 27-ffi1-650 0.943.s00 3.800.300 2018 64.379.000 15.654.580 4.630.880 907.500 28-254.680 1.103.180 3.828.180 2019 65.325.3ffi 15.794210 4.668.890 9tt.2N 28.825.4n 1.268.210 3.857.430 2020 65.909.690 15.958.3,10 4.715.380 915.940 29.n3.s20 1.456.530 3.889.9E0 2021 6?.6r.5.770 16.038.280 4.736.y70 916.E50 30.487.500 r.572.410 3.9t3.7fi 2022 68.636.570 16.176.320 4.772.sfi v20,630 31.103.380 1.719.810 3-943-8,0 2023 69-701-V20 16.336.850 4809.360 EA-510 3l^783-990 1.870.410 3.95.900 2014-2023 1.37o/o l.0lo/o 0.77o/o 0.38%2.6Eo/o 1.52o/o 0.75o/o Table 3.2 - October 2013 (2013 IRP Update): Forecasted Annual Coincident Peak Load (Megawatts) 20r4 9.984 229s 733 t45 4.505 t.3ll 67 327 2015 10.152 2.338 738 147 4.574 1.335 691 330 2016 10,u2 2,3s7 7M 149 4.729 1,358 7M 2017 10.210 2,395 749 149 4-828 1.378 7tt 2018 10.3s2 2.416 759 50 4.915 1.3l)6 716 2019 10.483 2.438 7ffi 5l 4.98 1.415 721 2020 10,777 2,465 767 50 s243 t-433 718 2021 t0-929 2.488 773 5l 5-334 1.4s0 733 2022 11.076 2.s12 778 52 5.426 r.467 7q 2023 11.232 2.538 7U 53 5.527 1.485 746 2014-2023 l32o/o l.l2o/o 0.74o/o 0.52o/o 230o/o 1.39o/o 1.25o/o Tables 3.3 and 3.4 report the June 2013 @usiness Plan) annual load and coincident peak load forecasts, respectively. Note that these forecast data exclude load reduction projections from new energy efficiency measures (Class 2 DSM), since such load reductions are included as resources in the resource portfolio. 24 PACFICoRP - 20 13 IRP UpoErS Cuarrsn 3 - RESoURCE NEEDs ASSESSMENT UpDATE Table 3.3 - June 2013 (Business Plan): Forecasted Annual Load Growth,2014 through 2023 (Megawatt-hours) 2014 62-L71-830 15.005.950 4.489.050 891.410 2s.394.530 0.375.030 3.727.y70 2"240"8n 2015 63.611.520 t5.276.2N 4.s21.040 893,660 26.333.s90 0.578.830 3.74"830 2.263.370 2016 63.973.4q 5.423.510 4.570,970 899,510 27-40t-880 0.797.7ffi 3.777.860 1,r01,950 2017 63.890.800 5-621-740 4.59('.860 900-720 28-028.7s0 0.941.880 3.800.850 2018 &.876.7N 5-757-330 4.635.330 904.040 28.&9.9s0 1.101.360 3.828.730 2019 6s.851.820 5.898.700 4.673.860 907.350 29.247"&0 L26.2n 3.857.980 2020 67.4U.070 6.074.530 4.7n.800 912.030 30.431.910 1.4s4.2n 3.890.510 2021 68.27t.540 6.157.930 4.742.870 912.560 30.973"840 1.570.050 3.914.2n 2022 69"273.920 6.29.700 4,778,9N 916.100 31,617,430 1.717.390 3.944.m 2023 70.368"520 6-M2.710 4.816.130 919.800 32.325.530 1.867.930 3.976.420 2014-2023 1.39o/o 1.03o/o 0.7Eo/o 0.35o/o 2.72o/"l.50Vo 0.72o/o Table 3.4 - June 2013 (Business Plan): Forecasted Annual Coincident Peak Load (Megawatts) 2014 10,086 2.314 735 146 4.586 -312 68 327 2015 l0-u:8 2"358 740 147 4.&9 .335 690 330 2016 0"t44 2.379 746 148 4.810 .357 705 2017 0.317 2.418 752 149 4,911 .377 710 2018 0.463 2.m 761 149 5.001 396 7ts 2019 0-597 2.M3 763 50 5.086 .414 720 2020 0.898 2"492 770 49 5.338 .433 717 2021 1.054 2.515 776 50 5.431 .450 732 2022 1"205 2.540 782 5l 5.s26 .M7 739 2023 1.365 2,s67 787 52 s.a9 .4U 745 2014-2023 1.33o/o l.160/o 0.77o/o 0.48o/"2.30o/"1.38%1.22o/o Tables 3.5 and 3.6 report the June 2012 (2013 IRP) annual load and coincident peak load forecasts, respectively. Note that these forecast data exclude load reduction projections from new energy efficiency measures (Class 2 DSM), since such load reductions are included as resources in the resource portfolio. 25 PACTFICoRP _ 20 13 IRP UpoIrp CHAPTER 3 - RESOTIRCE NEEDS ASSESSMENT UPDATE Table 3.5 - June 2012 (2013IRP): Forecasted Annual Load Growth,2014 through 2023 (Megawatt-hours) Tables 3.7 and 3.8 show the October 2013 (2013 IRP Update) forecast changes relative to the June 2012 (2013IRP) load forecast for loads and coincident system peaks, respectively. Table 3.7 - Annual Load Growth Change: October 2013 (2013 IRP Update) Forecast less Julne 2012 (2013 IRP) Forecast (Megawatt-hours) 2014 4.698.447 15.150.179 4.479"U8 905.134 25.7t8.951 10.408.489 3.779.47 2.257.219 201s 63.527.998 15.371.tt4 4.510.405 m8.752 26.010.382 10.626.524 3.8r9.y27 2"280.894 2015 63.431.505 l5^638.182 4-s6t-49s 916004 26.478252 r0.856.135 3.868.348 l.l 13.089 2017 63.2M.311 15.821.900 4.587.861 918237 n.0rc.0D 11.012.432 3.895.86r 2018 &.219.328 16.003.367 4.630.2fi7 923.755 n.542.259 11.188259 3.%1.482 2019 6s.183.187 16.181.469 4.672.594 y28,941 28.073.t52 tt-3ffi-999 3.965.432 2020 6.226-672 t6-377-833 4-722-54 935-083 28-622-538 11.563.805 4-004.870 2021 6.917.769 16.491.188 4.746.086 935.580 29.02L169 11.698.580 4.V25.t65 2022 67.814.244 16.652.789 4.7U.Ut 938.914 29.514"5n ll.866.488 4.0s6.614 2023 68.781288 16838-823 4.&25.0s8 942.144 30-M9-623 1L039-497 4086.143 2014-2023 1,030/o 1.180 0.83%0.45o/o L.740h 1.630/o 0.E70h Table 3.6 -June 2012 Q0L3IRP): Forecasted Annual Coincident Peak Load (Megawatts) 2014 0-331 2.377 79 t4 4,74s 1,3u2 6U 33r 2015 0-494 2-n8 758 t4t 4-826 t-326 701 334 20t6 0.359 2.457 765 t43 4.%0 1.349 714 2017 0.513 2.492 772 t4 5.014 1.371 721 2018 0 687 2-522 803 145 5.100 l-390 7n 2019 0.815 2.547 76 t6 5.194 1.410 732 2020 o-972 2,576 795 144 5,2n LAg 737 2021 1.133 2-ffi 801 145 5-387 1.448 748 2022 1.280 2.631 807 146 5.475 t.67 7il 2023 t-42'l 2,6s9 813 147 5,556 1.487 758 2013-2022 l.l2o/o 1.25o/o 0.87o/o 0.s5%1.77o/o 1.49o/"l.lsYo 2014 0.026.637 (226.819\7.652 11.94 673.471\(4.6s9 /61.067,(16.329) 20ls $a7228\081.8%)7.795 (r2.&2',19.308 (6.674,(75-sET (r7-524 2015 I I l-515 (307-7U2)6.115 fl3.6341 585.1128 (57.01t (91.0381 r 1.139) 2017 179.729 (298.130')5.059 (L4.337 651.631 (68.932 (95.561' 2018 159.672 G48.787)673 (16.2s5',7D,At (85.0791 fl03.302' 2019 to-173 G87-259'G.7M (r7-741'7st-6r,8 (92-789 fl08.0021 2020 683.018 Ar9.493\(7.1&(r9.143 1.3s0.982 0u7.27s'14.8901 2021 748,001 (4s2.908)(9.116 (l8.7301 1.ffi.331 /,126-17o',ll1.405' 2022 822.325 @76-M9',12.281 fl82M.1.s88.783 (L46,-678',12.74 2023 919.732 (s01.973)(l5.698 (r7.634 1.734.367 (l69.087 n0.243 26 PACIFICoRP _ 20 13 IRP UPDATE CHAPTER 3 _RESoURCE NEEDS ASSESSMENT UPDATE Table 3.8 - Annual Coincidental Peak Growth Change: October 2013 (2013 IRP Update) Forecast less June 2012 Q0l3IRP) Forecast (Megawatts) Finally, Tables 3.9 and 3.10 show the June 2013 (Business Plan) forecast changes relative to the June 2012 (2013IRP) load forecast for loads and coincident system peaks, respectively. Table 3.9 - Annual Load Growth Change: June 2013 (Business PIan) Forecast less June 2012 Q0l3 IRP) Forecast (Megawatt-hours) EEII/16.329)2014 (573.617 /r44,229,10.002 /L3.724 G24.42r',(33.4s9 (s1.457) 201s 83,522 (94-914'10.635 rLs.w2'323-208 47.694 05.wn (r7.524 2016 s4t-935 (214.672\9-475 /16.494 y23.628 (58.375](90.488)I 1.139) 2011 644.489 (200.160)8.999 17.517'1.018.731 (70.ssz\(95.011 2018 6s7.412 (246.037's.123 (19.715 1.107.691 (86.899)fi02.752\ 2019 6r,8.633 (282.769)1.26 (2l.s9l 1,173.888 04.7W)0u.4s2' 2020 t-2s7-398 (303,303)1.744 Q3,0s3 1.809-372 (09.515 1r4-360 2021 t-353-771 1333.258.)(3.216 Q3-020't-952-671 (28.s30'I 10.875 2022 t-459-676 (353.089)6.94t Q2.814 2-102-833 (49.098'tt2.2t4 2023 1.587.232 G76.tt3'(8.928'Q2.344 2"275.W (71.567)0w.723 Table 3.10 - Annual Coincidental Peak Growth Change: June 2013 (Business Plan) Forecast less June 2012 Q0L3IRP) Forecast (Megawatts) 2014 (347 (82 09 6 (240)9 1V (3 201s (342)(70)(20)6 (253)9 (l0 (5' 2016 (3rT 000)02)6 (201'8 o 2017 (303'(e7 (23 5 (186 7 (0 2018 (33s'(06 (44',5 (185'6 I 2019 (333)(09 06)5 nq')5 (I 2020 (195)l1 (28 5 (47 4 (8l 2021 QM\(t6 (28^6 (s3 2 (5 2022 (2M'l8 Q9 6 (49 (01 (4 2023 fl89 (2l 09 6 (29 o (2 2014 o45'rc4 /r7'5 (59)t0 (L7',(3 2015 Q46 (50 081 6 (77)9 l1 (5' 2016 (2rs (7&'./L9'6 (2t 8 001 20r7 fi96 (73 e0 5 (03'7 001 2018 o24 (811 (42'4 (99)6 (L2' 2019 (219 (u (23',,4 008'5 /L2' 2020 (74 (85 (25 5 47 J (20', 2021 (78'(88 os 5 M I (161 2022 0s (90'(2s 5 5l I fl5t 2023 (561 (v2'QO,5 73 G (l3' See also Appendix A for further load details. PlcrrConp - 20 13 IRP Uponrr CHAPTER 3 _ T{ESoURCE NsTnS ASSESSN,IENT UPDATE Existing and Firm Resources The availability and capacity contribution from existing resources have been reviewed and updated to reflect changes since the inputs were locked down for the 2013 IRP. The most recent results of this review process are summarized for the 2013 IRP Update and for the intervening Business Plan, aligning with updates made to PacifiCorp's load forecast since filing of its 2013 IRP as discussed above. Updates to existing and firm resources are presented in two steps - from the 2013 IRP to the Business Plan and from the Business Plan to the 2013 tRP Update. Updates applied in each of these steps include: Business Plan o Added new, and updated existing contracts to reflect changes between the 2013 IRP and the Business Plan. Adjustnents to existing firm contracts and inclusion of new sales contracts result in a net increase of firm sales that average 54 MW annually over the 2014 to 2024 period. Since filing the 2013 IRP, there is also an inuemental 25 MW purchase in2014. o The peak contribution of wind resources was updated from 4.2% (2013 IRP) to 4.0% (Business Plan). The update reflects inclusion of 2011 and20l2 historical data using the same methodology as described in Volume [[, Appendix O of PacifiCorp's 2013 IRP.5 Updated wind generation profiles. . Updated reserve obligations for non-owned generation is reduced by 106 MW by 2015. o The hydro generation forecast is updated to reflect the forecast developed in support of Business Plan, reflecting then current projections for hydro operations accounting for planned water conditions, availability, and market prices. Over the 2014 to 2024 period, the average peak contribution of hydro generation is reduced by l6 MW annually. 2013 IRP Update o Included ten new quali$ing facility contracts representing approximately l0 MW of peak capacity that were entered into following development of the Business Plan. These contracts are scheduled to come online in 2015 and2016. o Included a new 25 MW sale contract that was entered into following development of the Business Plan. The contract expires year-end 2014. Figure 3.1 shows the 2013 IRP Update resource need, prior to acquiring any new resources, alongside the resource need from the 2013 tRP and the Business Plan. Overall, the forecasted s PacifiCorp includes a set of sensitivity studies showing resource portfolio impacts of using alternative capacity contribution assumptions for both wind and solar resources in Chapter 5. 28 PlcnrConp - 2013 tRP Upplre CHAPTER 3 _ ResouRce NEEDS ASSESS}VG,NT UPDATE need has declined with the most recent needs assessment. Primarily driven by an updated load forecas! the most recent resource needs assessment shows an average reduction in peak resource need of approximately 320 MW as compared to the 2013 IRP for the period 2014-2023. Relative to the Business Plan, the most recent projection of resource need is reduced by approximately 135 MW over the same period. Figure 3.1 - Capacity Position Comparison, 2013 IRP versus Business Plan versus 2013 IRP Update r 2013 IRP I BudnogPtrn Tables 3.ll through 3.13 reportthe capacity load and resource line items from the 2013 IRP Update, Business Plan, and 2013 IRP respectively. Differences between the line items for the 2013 IRP and 2013 IRP Update are in Table 3.14, while differences between the line items for the 2013 IRP and Business Plan are in Table 3.15. 29 PACFICORP - 20 13 IRP Upoers CmpTsR 3 - RESoURCE NEEDS ASSESSMENT UPDATE Table 3.11 - Load and Resource Balance, 2013 IRP Update (Megawatts) CCcadarYcr IheoC q626 6460 Hydrodcctric lll ll0 Rcaem$le 92 82 hrctesc 62 ffi, QeffyhgFrlities 79 A Sdc 063) (R8) lfro0rmedRcscn'es (38) (3CI DertErirtirg Rrrarca 5J69 5,621 Lrd 6810 q930 Edrtia3 Rcrorcer: hteaupSle (159 (159 Qass I DSM (319 G29 ErtoUi3rtia 6322 6A12 Haahg Rcscrves (13%) 822 837 EertR:rcrru 822 t37 I:nOtlig*ior+Rrlrrr ll{4 7]19 EatPcitic (375) (658) DatRalcrotr&gh 7.1% Le,r 20la 2015 ,016 2017 20lE 2019 2020 2021 2022 6,4v q454 t25 t25 82 82 425 312 93 9? o30 (663) (39 G06/403 6365 6,7n 6.916 4454 6.454 q454 6454 4454 6,4v 122 125 D5 125 U5 t25 82 82 82 81 8l 79 312 312 312 283 283 283 939t93n8888 (663) (663) (6' (r83) (183) (r83) 08) (38) (30 G8) (39 G06362 5?6s 6r6s 6tr. 6110 6'g)8 7,9)8 7,t3t 7.?95 7,317 7,635 1ln (r80 o8o (l8o 086) (l8o 086') (l8o (l8o (329) G29 (329 (32e) (32s) (32e) (32e) (329 6)71 6,.01 6Jr3 5rr8 6Xr0 7,002 7120 7)a2 816 ts2 47 80 894 910 926 941u6 83' eU 860 89a 910 926 9at 7,093 7,233 7 160 1,a7e 1,77a 7912 8pa6 t,183(690) (868) (eer) (r,rl3) o,.oe) Gpes) (r:s6) (1379 2.0/o (0.8.i) (23?0 G.8Pr6) C1.f,6) @7lo) (4.4qO G.eh) Thcod Hydmdectic Rraqr$lc hrctasc Qatifyhg Fectitier Snb I$a€nacdRcscwcs WrtErirtirg Rercrcc l,od Bistiag Rcsorccr: Intenop$le Cbss I DSM N'etoUigrtic 3,17a Haahg Rcsaves (1370) WctRscu al3 IT'ortOtiSeior*Rrrer 35e7 $rtPcitic (27f) TfcatRererroll&3ir 4.596 \324 n7 38 187 99 (300 (3) 3r16 3,t74 0 0 L1A n5 38 190 86 (207) (3) 3,403 3,2r 0 0 3,22r d19 1t9 3,6a0 (237) 3-7./o 25c[, 774 38 2t 16 (157) (3) 3,255 t23t 0 0 3,2Sr 4ts 123 3,67a (1r9} 0.lort 1503 n4 38 21 76 (r56) (3) 3153 3,29.1 0 0 \303 747 38 2t 7t (150 (3) 3,22r 3,325 0 0 2543 7n 38 t 7t (157) (3) 3,rt5 3349 0 0 1503 7y 38 3 7t (r57) (, 3J19 3,382 0 0 2,503 641 38 3 7t 053) (3) 3,r00 3.4U 0 0 2.500 62 2t ? 7t 000) (3) 3Iaa 1,42 0 0 2.4n 652 2l 3 61 (104 (3) 3"t35 1.473 0 0 3,.75 452 as2 3927 Qe2' (e.F..0 413 tl91 3125 428 432 128 a32 3J22 3;t57 (46e) (sso (t."li) (3-1c..) 3ra, 3382 3,aU 3112 435 440 M U7(35 a{0 au a17 3,7t4 3,.22 3156 3rt9(see) (633) (7s6) Cr.s) (4.9/o) (5.P/o) (9.1'ln) (8,77") TcdRrrcrce 10.G5 10,@4 OUig*ic 9,496 9.64 Rrlrrrr 1,ts4 1,256 olligric +Rrecw 10.R0 10,919 Syr3erPcitic (64, (89t Rrmnr!&3ir 6.rh 3.TA 9,658 9,618 9,583 9150 9.554 9,914 9.954 9943 9J28 9,695 9,838 9961 ro,E r0,4r,l 10,562 r0:1r7 1239 1.260 \n9 r,295 r.334 r.354 r.373 1393 10.767 10.955 1t,ll7 u263 11.596 u.768 u.985 l2,ll0(r.ls) 0.337) 0.ro (1.713) (lorD 0,854) o.e8r) (2.16, l.4r,i (0.8,c,O G.6e6) @.n/o\ (6.90 (4.8p6) (5.8C,0 Q.!,6) 30 PACIFICoRP - 2013 IRP UpoArg CHAPTER 3 _ RESoURCE NEEDS ASSESSTVGNT UPDATE Table 3.12 - Load and Resource Balance, Business Plan (Megawatts) CCcaderYcar Ilecd Hydrodecttic Rrlcndle hrrctarc QueIfuhg Frliticr S.te l$a-Oq'!ed Rcccrvca lDd BistiagRaorcer: htcnupSlc Cbg IDSM 6,626 Affi tll ll0 92 82 62 662 79S (738) (730 (3D G8) Xaohg Rcscrver (13c../o) 833 847 EertR:lcs t33 t17 Elrt ()lliador +Xmerrrr 7 )17 7r6t EntPaitic (aa3) Oas) DrtRrecrutrfu:ir 6.loh Len 20ta 2015 20t6 2017 20lt 2019 2020 6ls4 4454 6454 6.4y q454 A4s4 q454 6.454 r25 125 122 125 t25 rB n5 l2382 82 82 82 82 81 8l 79 425 312 3r2 3U 3t2 2A A3 283 8383838}$827878(73S (663) (663) (663) (663) (183) (183) 0a)(38) (38) (30 (38) (30 (38) (38) (3S 6193 6rs5 6rs2 6155 6r5s 6por 6100 6,79t 6En 7.m0 7,113 7221 7.81 7,6n 7,7rt 78'p 08o (l8o o8o (186) (r8o (186) (18o (l8o ary G2e) 429 02e) 42, (3D) Q2' (329 6357 6,at5 6591 6J06 6972 7,097 12t6 73.1 826 843 858 8n 906 n3 938 955t26 tts tst n2 906 923 93t 955 7'rl3 732t 7,t36 7,57t 7,7t 3p20 tlsa tlrg oeo) (e73) o,10.) or23) GJ23) (r,2r5) Grs.) oJor) 0S'/c (20'6) (3.7c6) (5."h') (8,Pn) (4.10,6) (5-8q,o) Q.4W ErtErirtr3Rlrcrcr 6;191 6,6ft q892 7.m4 o59 (r5' Q2e) (329 E toUig.lic 61011 6i5f6 TIeod Hydrodcctric Rcaer$lc hrcbese Qalfyhg Frlitics S.L ISo0rlrredRcscn'cc L.rd Birtiag Rcrorccr: IatcmrpSlc Chsr IDSM \524 \54n7 n3 38 38 187 190 99 86 (30o @7)(, (1) W'rtDrirdr;Rrlcrcc 3rf6 3/a03 25c5 1J03 1103 25ts 2.103 \fl3 2,500 2,4n774 n4 747 7n 7A At 62 652 38 38 38 38 38 38 21 2t 212t2133331 1616117t7t7t71O ofD (l5o (r5o G57) (157) (153) (l0o) (1oI)(3) (3) C,, (3) G) G) (3) (3) 3JS5 3,253 3lrr 3,rt5 3,r$ 3J00 3la4 lJ35 32n 3318 3,350 *n ?,412 3,42 3.473 3J6 00000000 00000000 3J72 3rrt 3rs0 3377 3{t2 ',.12 '173 3F08 .125 43t 436 419 W 41 45t 4X 125 a3l a36 t39 lU a17 a5l aS6 3,697 t,7a9 3j786 3116 3rs6 3rr9 392a 3r6a(u2) (.e6) (s6s) (63r) (667) Ore) CrEo) (82e) (0J%) QOh) (3Jo6) (5.7.6) (6 506) (996) (9.5s6) 00.e/o) 1,t95 3,244 00 00 l,Vctollfurtic aJrS 3314 Iaahg Rcocrver (13%)4t5 4n WctRrcru 415 422 ltVct Otll3dor iR:rcrrcr trf0 3,666 IYgtPcitic (294) (263)lWctRrrcrnllhgir 1.9;L 4.rn IolBrlcrcr lqtl0 10.021 9,648 9,608 9,573 95.O 9.344 9,qX 9,944 9933 Ollfietic 9,99 9.7O 9S?9 9,S3 9,948 10.04 1q384 10,539 1q,689 10152 R;rrrrr 1248 \NB 1252 \n4 L293 lSll 1,350 1,370 1,390 llll Otli3ric +Rrarrs 10.847 11.08 10381 ll,tl1 ll,2A I lt3g{ ll.R4 11,909 l\Og U:A sptcrPcitia (R7) (Lm) (1233) (r,469) (1,660 (l,8tl) (2.r9 (2,mS1 (2.13' (2J30) Eacrel&rir 5.?h L?rt 02rh (LOh) (3.8%) (5.+h> (8.106) (6.0.6) Q.@h> G.f,| 3l PACTICoRP _ 20 13 IRP Upoarg CHApTER 3 - RESoURCE NEEDS ASSESSMENT UpDATE Table 3.13 - Load and Resource Balance,2013 IRP (Megawatts) Calendar Year 2014 2015 2016 2017 201t 2019 Thenml 6,626 6,m 6,454 6A54 Hydroelectric 14 140 135 135 RenewableS5ABS3 Purchase 611 611 398 285 Qualifring Facilities 73 73 73 73 Sale (732) (730) (724) (638) Non0wned Reserves (103) (138) (138) (138) frEt &isting Resources 6;100 6499 6,28f 6254 load 7,61 7,188 6,94 7,105 2021 6,454 6,4il 6,4il 6,4* 6,4v 6,4v 132 135 135 135 t35 135 8383839,$80 285 285 285 257 257 2s7 73 73 73 7l 25 25 (638) (638) (63e) (158) (158) (ls8) (138) (138) (138) (r38) (r38) (138) 6251 6254 6253 6;tO5 6,655 6,655 7,217 7,337 7,455 7,5U 7,697 7,W2 Existing Resources: Intemrptible (143) (lss) (ls, (15, (15, (ls, (ls, (15, (lss) (15, Class I DSM (37e) (37e) Q7e) Q7e) Q7e) Q1e) (37e) (37e) (t7e) Q7e) Erst ouigation 6,539 6$54 6460 6,571 6,683 6103 6921 7p50 7,163 7268 Plannin g Reserves (l 3%)850 865 840 854 869 884 900 9t7 931 Ets &stReserres 850 865 840 854 869 884 900 917 931 945 Erst OHigetion + Reserrrs 7389 7,519 7 3OO 7,425 7,552 7,687 1$21 7967 E,094 t2l3 nrst Paition (6E9) (1,020) (1,0r9) (l,t7l) (1,301) (1,433) 0568) (t262t (1139) 05s8) &st Resene ltrlrrgin T/o e/") (3o/o) (5%) (60/o) (g/o) (|ff/o) (5o/o) (T/o) (e/o) Thenral Hydroelectric Renewable Purchase Qualifring Facilities Sale NonOwned Reserves West Risting Resources toad 2,5Vt 751 x aa< I (?-60) (e) 3166 ),2@ 2,524 n6 'i6 BI I (r60) (e) tA91 3,W7 \s03 7n % l3 89 (l l0) (e) 33O2 3,470 2,503 723 '36 ) 88 (1 l0) (e) 3233 3,4n 2,fi3 n6 % ) 89 (110) (e) 3237 3,516 2,503 a7 % 2 89 (l0e) (e) 3,159 3,v9 x500 6s0 l9 ) 89 (103) (e) 3,14E 3,s83 \4s7 648 l9 2 85 (103) (e) 3,139 3,6n zs$ 782 % l3 89 (110) (e) 332t 3,X5 \fi3 780 x l3 89 (1 10) (e) 3302 3,q7 00 (28) (28) 3337 3319 434 439 434 4t9 t;771 3rlr (4s0) (sl6) (tr/o) (yh) Enisting Resources: Interruptible 0 0 Class I DSM (28) (28) WestoHigation 3241 3279 Planning Reserves (13%) Al 426 WestResen$ 421 426 West OHigetion + Resents 3$62 3,705 WestPmition (296) (20t) West Resenr llhrgin 4% T/o 00 (28) Q8)3442 34sr 47 49 447 449 3,t89 3800 (s87) (667) (4o/o) (6/0) 0000 (28) (28) (28) (28) 3,4EE 3,521 3555 3,592 453 458 42 M? 453 45E 462 467 3p41 3p79 4,017 4,059 (7041 (820) (r6e) (e20) (Th) (|tr/o) (l l%) (t3o/o) Total Resourcec OHigetion Resencc OHigation + Reserrcs Syrtem Position Resene *Argin rq066 9,96 9,78 9,933 \n\ \Dt 11,0s1 1122,4 (e8, (t228) 3% 1o/o 9,ff2 9,5$ q5s3 9lC7 9,490 9,W 9,803 9,7Et 9,7v1 9,9s0 10,125 10254 t0,&9 l0,s7l lq7l8 10,860 \n4 \D4 1,316 1,333 1,3s3 1,374 1,3% rAr2 11,071 112A4 l,4t 11,587 1r,762 11,945 12,111 Dm (r.46e) (1,688) (1,888) (2100) Q2n) (2,081) (2,308) Q.478)(T/o) (4%) (6vo) (V/o) (91A) (T/") (9 ) (tw/o) 32 PACFICoRP _ 20 I 3 IRP UPDATE CHAPTER 3 _RESoURCE NEEDS AssESsIt{ENT UPDATE Table 3.14- Load and Resource Balance,20l3lRP Update less 2013IRP (Megawatts) CCco&rYca 20la 2015 2016 2017 20tt 2019 2020 2021 2022 Ttead Ilydrodetric Rcncndlc hrctrsc QuaIShg Frlitie: Sale l$oOnncd Rcscrycs frtErirtirg Rrrarcce lod Erirtiag Rsorces: IatctnpSlc DSM (lo (4) 50 50 Ertolllgrtia eU) eU) 0000 (10 (10) (lo) (10) (l) (l) (l) (l) n272?nm2020n(14) (2' (2' (2' 100 t00 100 l0t22 rll llt lll (20?) (189 089 e04) (3r) (3r) 0r) (31) 50 50 50 50(rtS) (r70) (u0) (1r5) (2O QZ) 8x) {a)(21) (22> (22) (24) (207) (re2) (re2) (20e) 329 30' 303 320 50$ 4% 4'6 4!6 00 (2' (30) 70) 3l 5l 610 (31) (0 65 lmg, t22 (251) (258) 00 (10) (10) o) (l) 27?5?o19 Q4) (25) lm lmlu l(l9 (60) (67) (31) (3r) 50 50({r) ({E} (, (q (s) (6) (.6) (s.) lst 163 li v,6 00(10 00I (1)?sx 6363 (2' (2' 100 lo155 tss (64 (4' (31) (3r) 50 50 (4s) (26) (o (3) (5) (3) (.e) (2e, 20a 182 1.h 2ch Eaohg Rcsorer (13!6)(2D GO EatRarerrar (2E) (28) Eut Olli3lior +Rrrrrcr (245) (240) EeatPcitia 3la 362 EatRrlcrrclhgir 9,6 }16 Thcod Hydrodcctric RcaewSle Purciasc Qalfyhg Frlitir:s Srh l$a0uncd Rcscrves IVertErirtrj Rracrcc Lod &isdl3 Rcsourccs: Iatcrruptblc Chss IDSM ItrrctoHigrtic Eaahg Rcccmcg (13-%) Sctf,mcru Sert Ollfutior *Rrrrrrs W'ctPcitic WcltRarrrrlfugir 00 26 0) al (30 (41) 0 (lo (40 $7) 66(s0) (er) (e, (80 0 28 0 n (86) (ll) (rr) (e7) 3l t% 0 28 (67' (9 (e) (76) ,5 fh (r.r) 0(0 (q at 88 03) 03)(47) (4O 66 (66} (1e) (rlo (ll3) 00 24 22 tl (10 08,3t 66 (4) (4) (141) 04' 00 28 28(rs) GrD G02) (106) (roe) G13) Gu) (11) 0, (13) oo (14) (1, o,ol) (ro (r3) Gl) (14) (ts) (ro (e6) (r32) Grs) o20) (rx) G2E) (r32) 11 5l 67 72 6a L21 12r lvo lc6 l.h lc6 lo,6 9/o 3o6 0000 G3) 7 8 (6) ,1rt 8l1l (18) (17) O0 (18) (4O (47) (47) (44) 6566(Er) (4r) (.r) (se) (14, 030) (13O (137) 0000 28?82828 0 28 (58) (9 (r) (65) (28) o%) Tcel Rercrccr OUi;etic R:ccrra Olligric +Rcrcea SyrtaPaitic Raoru!&3ir 19?8 (284) @0)(37) €'(321) (30' 340 333 ?6 vfr fi62 (26e) (2r' (3t (33) (304) (280 3A 3J0 3% lh 304(nT e87) G7, (37) (324) €2r) 35{ 3C' !'/o 3!6 64 50 (147) (157) (re) (20) (160 Qm 230 Et Di T/o 151 t49(r5o o43)(2o) (19(r7o (l6a 127 31r !n6 1q. 33 PacnrConp - 20 13 IRP Upoare CHAPTER 3 -RESoURCE NEEDS ASSESS}I4ENT UPDATE Table 3.15 - Load and Resource Balance, Business Plan less 2013 IRP (Megawatts) CdcadrYccr 20la 2015 2016 2017 20tt 2019 2020 2021 2022 2023 IlcoC Hy&odcctric Rracv*lc Arrcbesc Qrlfyhg F*litics Sde l$o€*lcd Rcrctves ErrtErirdr3 Rorcrcer IDd Birting Rcsourccs IlterupSle DSM oo (o 50 50 EertoEigetic G35) G3t) 000(10) 00 (10)(l) (1) 0)2127n l0 l0 10(2' (2t (25) 100 100 lm lot l0l rot 00, (l0o 016) (3r) 6l) (31) 5050fi(86) (8t (e7) (11) 0l) (13) or) (1r) 03) (e7) (eo Gr0) 198 t97 2lt 396 30h ?h 00 (29 (30) 7 (l) 5t 5l 67 (6) (9 65 tm 9a ll9 (169 (18O 0 (10) (l) n l0 (14) 1m ll2 (r?c) (3t) 50 o0s) (t3) o3) (uo 228 loh 0 (10) o) )1 10 (20 lm 102 32 0 (10) (l) x 9 (25) tm 99 28 00(r0) (r0) I (l) 2626 53 53 (2' (2' 100 lm las las 14 51 Hoahg Rcscrvcs (13%)08) (18) ErtRrrrrr (tB) GB) FrrtOlli3lior+Rsm (I53) (f 56) ErltPcltic 211 215 ErtR:rcrc!&3ir M 476 (31) (3r) (31) (31) 50$5050 51 17 53 76 76710 76710 5E 53 60 t6 u,6t557 l.h 1.,6 l.h 196 Thcod I{ydrodcaric Rcacw$lc Purc,Lase QdiBhgFdities &h IilooOrmed Rcccrveg NctErirdr3 Rlrarcc Ird Bistiog Rcsorccs: Iatemp$lc Class I DSM Scatoili3etic Eaahg Rrsew* (B7o) IYctRsrcrr IYcrt 0Ui3lior *Rercu IYstPcitic lWctRrorrlbgir 0004)0 26 0) (0 (0 2222 (30 (41) 8 8 0 (1, (r3) (13) (4O W) (4?) (4O 6666(s0) (e1) (66) ({e) (74) (63) (e3) (89 0 €3), 8 (18) (40 6 (tr) (120, 0 a t I 00 3 6 (4) (1lo) (e3) t9 D6 0 4 1 I (18) I 6 (.) 0lD 0 7, I (17) (10 (18) (47) (47) (44) 666(.r) (.r) (se) 002) (r0o (107) 000?82828 o.) 05) (lel (10) o0, (10)(r0) (ro) G0) 00 8 (6) 1) ll 00 28 28 (82) (8.) (lr) (lD(rr) (rr) 000002828?82828({6) (3s) (6s) (6r) (e2) (o (t (8) (0 Ga(6) (5) (8) (8) (r2) (et 9l 2.h (s2) (.0) 2 (s4) (Vr6) (2P,O (6e) (r0.) (E.) 20 23 36 W. @/c l'i o3) 7 (0".,.) (16) 38 l.h CIe) 30 ah Tdel Rrrcrcr Otllrtic Rerrr Olligric+Rerrr SyrtrrPcilic Roecrntr&3ir 44?5(r8r) 073)(24) QD(20t 0e,u9u T/o Z% 52 20 (147) (177) (19 e3) 060 (?0o) 218 D0 Z.tr'o 2'/o 141 t3!) (29 (8) (4) (1) (33) (9 t74 148 No l% 4 o68,(9 oe0 2X 2Vo 53 (l7l) (D) 0e3) 2$ T16 54 {0 (2' (32) (, (4) (20 (36) 82 76 l',6 lt/o 34 PACIFICORP _ 20 I 3 IRP UpOarA CHAPTER 3 _ RESoURCE NEEDS ASSESSMENT UpoaIe Figures 3.2 through 3.4 summarize for the 2013 IRP Update annual capacity position for the system, west balancing area, and east balancing area, respectively. Figure 3.2 -2013IRP Update, System Capacity Position Trend rilert Erbtln3 Rerourcer 35 PacrlConp _ 2OI 3 IRP UPDATE CHaprgn 3 - RSSoURCE NEEDS ASSESSMENT UpOere Figure 3.3 - 2013 IRP Update, West Capacity Position Trend r.roc llX r0,0I t.a aaas-6,044 4,0.t 1,0a4 0 Figure 3.4 -2013IRP Update, East Capacity Position Trend 36 PacrICOnp _ 2OI3 IRP UPDATE CHAPTER 3 _RESoURCE NEEDS ASSESSMENT UPDATE On a total Company basis, the Business Plan sensitivity shows that the peak resource need has fallen by over 200 MW through 2019 and approximately 100 MW in the later years as compared to the 2013 IRP. On a total Company basis, the 2013 IRP Update shows further reduction in resource needs from the Business Plan. This is mainly due to a further reduction in the load forecast. As compared to the 2013 IRP, changes to the resource needs assessment are driven by the following: PaciliCorp East o Average annual peak loads are forecast 215 MW lower over the 2014-2019 timeframe and 59 MW lower over the 2020-2024 timeframe.. Updates to existing resources and additions of new sale and purchase contracts net to an average increase in system capacity of approximately 2l MW over the 2014-2023 timeframe.. Updates to non-owned reserves reduce PacifiCorp's planning obligation by 65 MW in 2014 and 100 MW over the20l5-2023 timeframe. PacifiCorp West o Average annual peak loads are forecast 124 MW lower over the 2014-2023 timeframe.. Updates to existing resources and additions of new sale and purchase contracts net to an average decrease in system capacity averaging 66 MW over the 2014-2021timeframe and l0 MW in 2022 and2023.. Updates to non-owned reserves reduce PacifiCorp's planning obligation of 6 MW in each year of the 2014-2023 planning period. System o Primarily driven by lower forecast peak load, the average annual system obligation plus planning reserves is reduced by 3ll MW over the 2014-2019 timeframe and by 177 MW over the 2020-2023 timeframe.o After accounting for updates to existing resources, additions of new sale and purchase contracts, an updated non-owned reserves, the average system capacity position required to achieve a l3o/o planning reserve margin has improvedby 352 MW over the 2014-2019 period and by 274MW over the 2020-2023 timeframe. 37 PACTICoRP - 2OI3 IRP UPDATE Cseprsn 4 - MooELTNG AssuNprroNs UpDATE CrMprER 4 - MOPELING ASSUIT,TPTIONS UPnATB In line with the 2013 IRP, the study period for both the fall 2013 ten-year business plan (Business Plan) sensitivity and the 2013 tRP Update studies is 2013 through 2032, with a focus on the 2014-2023 planning horizon. Updated resource portfolios were developed assuming a l3o/o planning reserve margin consistent with the stochastic loss of load probability study included in the 2013 IRP. PacifiCorp has not made any changes to general inflation assumptions (1.9%) and has not modified its discount factor (6.882%) in this 2013 IRP Update. PacifiCorp continues to assume federal production tax credits are expired and that federal investment tax credits for qualifring renewable resources will expire at the end of 2016. The Business Plan portfolio modeling was based upon PacifiCorp's September 30,2013 official forward price curve (OFPC). Portfolio modeling for the 2013 IRP Update was prepared using PacifiCorp's December 31, 2013 OFPC. All OFPCs in the 2013 IRP and IRP Update are composed of market forwards for the ftst 72 months, followed by 12 months of blended prices which tansition to a market fundamentals-based forecast, starting in month 85. An OFPC is produced for both natural gas and power prices by point of delivery. The fundamentals forecast for natural gas is selected from three expert third-party sources with consideration given to underlying supply/demand assumptions, forecast documentation, peer-to-peer forecast price comparisons, date of issuance, location granularity, and forecast horizon. Natural gas price forecasts are a key driver of electricity price forecasts, as produced by MIDAS, a production cost simulation model. Natural Gas Market Prices The fundamentals portion of the September 2013 natural gas OFPC is based on expert third-party long-term gas price forecasts issued between May 2013 and September 2013 with short-term updates in August 2013. The fundamentals portion of the December 2013 natural gas OFPC was based on expert third-party long-term gas price forecasts issued between October 2013 and December 2013 with short-term updates in November and December 2013. Both the September 2013 and December 2013 natural gas OFPCs reflect a fundamentals-based forecast heavily influenced by cost-effective domestic supply opportunities largely due to growth in unconventional shale gas plays. The September 2012 natural gas OFPC, which was used in the 2013 [RP, was based on an expert third-party long-term natural gas forecast issued May 2012 with a short-term update in August 2012. The September 2012 OFPC also reflects a considerable portion of domestic natural gas demand being met by unconventional shale production. 39 PacrrConp - 2013 IRP Upoers CgapTgn 4 _ MoDELING ASSUMPTIONS UPDATE In summer 2012, surveyed expert third-party natural gas price forecasters expected 50% -58% of 2020 production to come from shale, by summer 2013 expectations had increased to 50% - 67Yo, and by winter 2013 expectations ranged from 50% - 7l%. In the course of one year alone, 2012 to 2013, Marcellus production increased from approximately seven billion cubic feet per day (BCF/D) to over l1 BCF/D. Figure 4.1 compares the nominal annual Henry Hub natural gas prices from the September 2012 (2013IRP), September 2013 (Business Plan), and December 2013 OFPCs (2013IRP Update). Figure 4.1 - Henry Hub Natural Gas Prices (Nominal) EE EO , E oz 10.00 9.00 8.00 7.00 6.00 5.00 4.00 3.00 $ u1 \O r- @ O\ a F-r N (v) e 'ln A t-- A q a - N- - - ; 6l N N N d 6t 6l N 6l al (rl (n (noooooooooeoooooaoooc\l 6l (\t Ft N N N N t\l N N 6l N ol c.l (\| (\| N N - 2013 IRP (Sep 2012) +-Bushess Pbn (Sep 2013) + ZOl3 IRP Updsb (Dec 2013) Power Market Prices The natural gas fundamentals forecast described above was a key input to the MIDAS model, and consequently, the gas curve shape is reflected in the electricity prices from the September 2012, September 2013, and December 2013 OFPCs. Figures 4.2 through 4.5 compare the average annual electricity prices for the Palo Verde and Mid-Columbia market hubs from the September 2012, September 2013, and December 2013 OFPCs. 40 PACIFICoRP _ 20 I 3 IRP UPDATE CHAPTER 4 _ MoDELING ASSUN{PTIoNS UPDAIE Figure 4.2 - Average Annual Flat Palo Verde Electricity Prices 90.@ 80.00 E 70.m E *.* E ,.*E 2 q.m 30.00 20.m S 'f.) \O t\ 6 O\ e n e{ cQ t Q A h a q Q E cJ--NNNCINNNNNN(n(n(nooooooooooooooooooo({l d 6t (\r ol at N N N Gl o| 6r N N et N cl 6l (\ +2013 IRP(Sep2012) +gudaessPlm (Sep2013) +2013 IRPUpdate @cc2013) Figure 4.3 - Average Annual Heavy Load Hour Palo Verde Electricity Prices 90.00 80.00 70.00 E *.* E3 so.ooI E m.ooz 30.00 20.00 $ r \o r\ & o\ Q n ol (') { ra \Q F a o\ Q E clF 61 6l N N 61 6l N N 6l (\l (n (n (noooooooooooooooooooOl N N N 6I N N N N N 6I (\l 6t N fi 61 6I d 6I +2013 IRP (Sep 20 12) ...r-Bueiness Plan (Sep 201 3) *20 I 3 IRP Update @cc 20 13) 4t PecnrConp - 201 3 IRP Upoars CHAPTER 4 _ MoDELING ASSUMPTIoNS UPDATE Figure 4.4 - Average Annual Flat Mid-Columbia Electricity Prices $ Y.) \o r- 6 o\ a E d (a1 { ra \o F a 6 a E ol- 6l N N C| e{ N N 6t 61 6t (n (n (noooooooooooooooooooN t\ 6I N 6l 6l 6l 6l N N N 6I N N t\I 6l CI N N --2013IRP (S€p 2012) +BusiaessPhn(S€p 2013) a26l3 IRPUpdsb@ec2013) 60.00 d!u $ so.m E ** Z m.m 20.00 Figure 4.5 - Average Annual Heavy Load llour Mid-Columbia Electricity Prices 70.00 E *.* EG E 50.m E ao.ooZ 30.00 20.00 t u.) \o r- o o\ Q n cl (Q t rr1 \o .> a o Q E doooooooooooooooooooN N N N t\ N N 6I N 61 61 6I 6l N (\l 6I N 6I N <-2013 IRP (SeP 2012) ---BusircasPha (Sq 20Il) .a-2pljl IRP Up&E @ec 2013) After PacifiCorp filed the 2013 [RP, President Obama issued a Presidential Memorandum in June 2013 directing EPA to issue standards, regulations, or guidelines, as appropriate that address greenhouse gas emissions from modified, reconsffucted, and existing power plants. The proposed standards, regulations, or guidelines are to be issued by June 1,2014, finalized by June 1,2015, with implementation of regulations as proposed in SIPs required by June 30, 2016. EPA would then review the implementation plan proposed by each state, and the effective compliance 42 PacruCoRp - 2013 IRP Upoars Cuaprsn 4 -MooELING Assutv{prroNs UpDATE dates for these standards, regulations, or guidelines would become applicable sometime thereafter. Absent information on how EPA intends to proceed with its rule-making process, and without any information on how individual states will propose to implement those regulations through a SIP, there is currently no means to develop a specific CO2 price assumption that accurately reflects potential CO2 regulation. PacifiCorp's review of current third-pafty CO2 price forecasts shows that despite issuance of the Presidential Memorandum, these forecasters have not materially altered either their assumed COz start date or price level. In the 2013 IRP Update, PacifiCorp continues to assume a COz price signal beginning 2022 at $16/ton escalating at three percent plus inflation thereafter, and expects to update its COz policy assumptions and scenarios in the 2015 IRP, taking into consideration the proposed standard, regulation, or guidelines expected to be issued by EPA later this year. The topology used in the Business Plan sensitivity and the 2013 IRP Update studies are consistent with what was used for Energy Gateway Scenario 2 in the 2013 IRP, except the changes in timing of Energy Gateway Segment D as noted in Chapter 2 of the 2013 IRP Update. The supply side resource costs and performance parameters did not change from the 2013 IRP, except that the costs of utility scale solar photovoltaic resources are updated based on a Company commissioned study completed by Black & Veatch in December 2013. Updated costs are summarized in Table 4.1, along with those included in the 2013 IRP. The costs of solar reduced by over l0%o for both single tacking and fixed tilt. Table 4.1 - Updated Cost of Solar Resources, 20f3$ - (50 MW AC) For this filing, PacifiCorp performed two sensitivity studies around the performance of renewable resources and costs of the solar resources. The first sensitivrty study changed the peak contribution of wind resource to 20.5Yo, and solar resources to 68Yo and 84Yo for fixed tilt and single axis tracking, respectively. This sensitivity study was requested by the PSCU in its order acknowledging the Company's 2013 IRP. The second sensitivity was performed using updated the costs consistent with those shown above, in addition to changes to the peak contributions consistent with those requested by the PSCU. Both sensitivities are discussed in Chapter 5. 43 PACIFICoFJ - 201 3 IRP UPDATE CHAPTER 5 _PoRTFoLIo DEVELoPMENT Crnprsn 5 - PonrFoLIo DBvpToPMENT PacifiCorp used the System Optimizer (SO) capacity expansion optimization model to develop resource portfolios based on inputs and assumptions updated throughout its business planning proc€ss. Similarly, the SO model was used to develop resource portfolios for the 2013 IRP Update consistent with its most recent resource needs assessment as described in Chapter 3. As was done in the 2013 IRP, the Company devised minimum wind resource acquisition targets for renewable portfolio standards using the RPS Scenario Maker model and treated these targets as a minimum fixed resource schedule in the capacity expansion modeling. The Company also maintained the natural gas resources and the combined heat & power (CHP) resources from the 2013 IRP Preferred Portfolio. Consequently, the Business Plan resource portfolio was developed by allowing demand side management programs and front office transactions (FOTs) to balance system capacity and energy. The 2013 IRP Update study was developed by allowing for a fully optimized selection of resource alternatives. This chapter first describes the development of the wind resource addition timing, and then presents the 2013 IRP Update and Business Plan portfolios along with comparisons to the 2013 IRP Preferred Portfolio. Renewable Enerry Credit Value Parties in Utah questioned PacifiCorp's treatment of renewable energy credits (RECs) in the 2013 IRP; as such the PSCU requested the Company address two specific issues in this IRP Update. These were the risks of relying on unbundled RECs as opposed to physical resources, and inclusion of the value of a REC as an offset to the cost of a renewable resource. The Company expressly addressed the risk of relying on unbundled RECs in the 2013 IRP. Specifically, the determination of the preferred portfolio was made after calculating the cost and financial risk of meeting incremental renewable portfolio standard (RPS) compliance in Washington using physical resources.u This analysis showed that on an expected value basis, unbundled REC prices would need to exceed $514/twh before the unbundled REC strategy would prove to be higher cost than meeting Washington RPS obligations with physical resources. Similarly, when the stochastic risk benefits of physical wind resources were factored into this analysis, PacifiCorp's study showed that unbundled REC prices would need to exceed $48/I{Wh for the physical supply strategy to be more cost effective. Based on its participation in the REC market, PacifiCorp does not expect unbundled REC prices to reach, let alone exceed, these levels and that pursing a physical compliance stategy would increase costs for Washington customers. In fact, PacifiCorp has already been using unbundled REC purchases to satisff Washington RPS requirements. 6 PacifiCorp notes that existing physical resources have been and will continue to be used to meet Washington RPS requirements. Use of unbundled RECs is planned for meeting incremental Washington RPS needs as the target grows over time. 45 PacrICoRp _ 20 13 IRP UPDATE Cseprsn 5 -Ponrrolro DEVELoPMENT PacifiCorp's experience in the REC market leads it to believe that it is unlikely it will be unable to purchases sufficient tradable RECs to cover its Washington and California RPS compliance obligations. As identified in the 2013 IRP Action Plan, PacifiCorp has identified the steps it will take to procure unbundled RECs required for RPS compliance, including issuance of requests for proposals (RFPs) seeking both current-year and forward-year vintage unbundled RECs. By continuing to monitor REC availability and pricing through these competitive solicitation process, PacifiCorp can readily observe potential, yet unlikely, changes in the REC market that would limit opportunities to purchase unbundled RECs as needed for the Washington RPS. Considering that PacifiCorp does not have an incremental need for Washington RPS RECs until 2016, and further considering that this incremental need can be deferred using flexible banking provisions allowed in the Washington RPS, the Company has the flexibility to pursue alternative compliance strategies, including compliance with physical supply, should circumstances change. PacifiCorp continues to assume in its 2013 IRP Update that incremental Washington RPS requirements will be met with unbundled REC purchases. As to the inclusion of a REC value as an offset to renewable resource costs, this assumption would ascribe a monetary value that PacifiCorp could not realize, and is therefore, inappropriate as a means to justify acquiring physical renewable resources. The recommended approach is not suitable for renewable resources that are being added to the preferred portfolio for purposes of complying with a RPS. This is not practical for a load serving entity having to meet an RPS obligation, which effectively requires that a REC be "retired" when used for RPS compliance, making that REC unavailable for sale, and therefore, eliminating the ability to monetize the unbundled REC as a means to offset project costs. If a renewable resource is added for a reason other than RPS compliance, given current REC market conditions, it is not appropriate to assume REC revenues can offset the cost of the renewable project over the life of the asset. The REC market lacks transparency, and while the Company is comfortable assessing the upper limits of REC prices going forward, the lack of transparency makes it inappropriate to assume a pre- determined REC revenue stream that can offset renewable resource costs over a 25 to 30 year period. Moreover, the sale of unbundled RECs can limit the use of the underlying "green attributes" associated with the REC, limiting its potential use for meeting future environmental compliance obligations to reduce greenhouse gas emissions. PacifiCorp has not assumed a REC value as an offset to renewable resource costs in the 2013 IRP Update. Wind Resources Table 5.1 presents a comparison of the wind additions from the 2013 IRP Preferred Portfolio, Business Plan, and 2013 IRP Update. The projected wind capacity additions declined somewhat from the 2013 IRP to the Business Plan, and again from the Business Plan to the 2013 IRP Update. The main drivers include updated regulatory assumptions, decline in forecasted load, and an overall increase in forecasted generation from current renewable resources. The capacity additions decrease in2024, but those decreases are partially offset by 2025 increases. As was the case in the 2013 IRP, wind resources included in the resource portfolio are not economic and are included to meet state RPS obligations. The capacity additions in the IRP assumed implementation of a Federal RPS standard. The assumed federal RPS requirements were applied to retail sales, with a target of 4.5 percent beginning in 2018, 7.1 percent in 2019-2020,9.8 percent in 2021-2022, 12.4 percent in 2023- 2024, and 20 percent in 2025. However, since 2010, no significant activity has occurred with 46 PACFICORP _ 20 I 3 IRP UPOETE CHAPTER 5 - PORTFOLIO DEVELOPIVIENT respect to the development of a federal renewable portfolio standard. In addition, current political environments are shifting focus from items such as the extension of federal incentives for renewables and portfolio standards to EPA's development of greenhouse gas standards. Accordingly, at this time the Company does not have a basis to make assumptions regarding any future federal renewable portfolio standard. Table 5.1 - Wind Additions,2013IRP Preferred Portfolio, Business Plan,2013 IRP Update Renewable Portfolio Standard Compliance Table 5.2 summarizes the forecasted state annual RPS targets as defined by each state's RPS program, the forecasted annual megawatt-hour RPS requirements, and the quantity of megawatt- hours available from existing eligible renewable resources. The RPS Scenario Maker model is used to ensure compliance with RPS requirements through the planning period. The RPS Scenario Maker model uses retail sales forecast inputs, state-specific targets, state specific banked REC balances, forecasted generation from existing RPS-eligible renewable resources and cost and performance assumptions for potential new resources to optimize the type, timing, and location of additional renewable resources needed to meet future RPS compliance obligations. The RPS Scenario Maker model considers compliance flexibility mechanisms specific to any give RPS program including unbundled REC rules and banking rules that cannot be configured in the SO model to establish a least cost renewable resource mix that meets RPS requirements. This RPS compliant wind schedule is shown above in Table 5.1. Note that acquisition of an incremental 549 MW and 480 MW of wind for the Business Plan and 2013 IRP Update respectively, is needed to comply with RPS requirements through the planning period. An overview of the RPS compliance picture for each state is provided below. 47 oo+ I I I I , ,, i a I x I I r F i i t , * ; t t t t ; ,d , , t t x T -E:e-^i ir55 aotf & 0.& cooc.l - 9E -gi"E eISE E c, Fi thct)9, aa EE IE E!tcI c gEsg ) !l t i J I , J t I I ! I t ; I J x I t J * J 9.gi "EtgE Fr& ('l r{ L€ o do E aoUri& b0 aa Xf-l es BO E] cn Etr6l q2 o q)L 5oil thoo0L6lF LclE 6lor,)ct^E o-)Fn,dil o9 tFBlc(l)Etr6r gqr-its= E-tsgI - ;',ta,)ci"r Aia8 &OE ='6 ca 6t= ;Htr X F2EI oJEI trlooI trFdo0i Iin &FrFA Q t!F aA Oril c4 oN Io-& Urr() A p Ih c PaCTTICORp _ 20 13 IRP UPDATE CHAPTER 5 _PoRTFoLIo DEVELoPMENT For reference, Figure 5.1 indicates how RPS compliance is forecasted to be met through2022 using current tRP Update assumptions. Figure 5.2 shows the compliance forecast for the Business Plan. These two sets of graphs are limited to the compliance forecast for the states, as the federal RPS assumption has been dropped. For comparison purposes, Figure 5.3 has the RPS compliance forecast as included in the 2013 IRP. Figure 5.1 - 2013 IRP Update RPS Compliance Position Oregon RPS Compliance Outcome 12,(m lOpm t(I)o 5,(trO a,(I)o 2,mo 0 2013 2014 2015 2m5 20t7 20ra 2019 2020 -Ul$ddbdltcsq..ld.rd slNkr&da.nt$miH IGrrcil Yrtuffi Sumddrd -Yr.d lulld g.*Llm @Y-.d Urtud.d EC hnl &lm -Aill ne&ffd Washington RPS Gompllance Outcome 7m 6(I, 50) a /rmit9:m 2m 1q) o 2013 2014 2015 2m6 2017 20,tA 2019 2@O 2021 2Ut7 rurtrniditcCrrfitrad Nlurdadlst$rhdand Icumd Ya G6..h9-riid.d IYtld &rdhd 3r*8dre @Yr+rd Callfornla RPS Compllance Outcome 3(I) 2v, 2q) E] rso(, 1m 50 0 2073 2011 2015 2016 2071 70tA 2019 2020 20rt rurtondbdrCcsrsir.d N&rd.d!.nlsomnd.rtd -CumnYrhdlmsfirJ-rd rY*+dEutiLd&il&l@ @!Y{ird Ur$und.d REC 8.nl hlmo -Arul Redr.mnl Fcdcral RPS Compllance Outcomc l{ot Appllcable PACTFICoRP - 2013 IRP Upnnrs CHAPTER 5 _Ponrror-Io DBwLopw,Nr Figure 5.2 - Business Plan RPS Compliance Position Oregon RPS Compllance Outcome 10,(m 9,(m 8,(m 7,m I 6.(I)0 = s,mo9 l,m 3,(m 21I! 1,(m 0 2013 2014 2m5 2016 2077 2(nA 2019 2@0 2g21 2gt2 IurtendLd lEC SE6d.nd NBurd.d a.nltorrrd-.d Ivorcri torihd &nlhLno EYr{dUtunnd Washlngton RPS Compllanc€ Outcome 7(n 6(x) 5(D a 4(n =93m 2@ 1(I) 0 2013 2014 2015 2015 2017 2018 2019 2(n0 2s2.1 2422 I(fitu.dbdnEcsuodrld Ntund.dhl$mid.r.d ICudil Y*GanaEtldlrMdafld lYfraid luidLd Bol( lds6 @Y.rr{rd Unbund.d l[C bk Bdr6 -Amol &qdr.m6t Callfornla RPS Compliance Outcome 3(I) 250 2(I, E = rso(t 1@ so o 2013 2(n4 2(ns 2016 2st7 20tA 2Ct9 zqn 2C2t 2022 rudoidadltcirrEdarad N*r.d.dblhdrrd IClmiYu (lEffi lrridr.d rY*{d MH hl&Lno Federal RPS Compllance Outcome l{ot App!lcable Figure 5.3 -2013IRP RPS Compliance Position Oregon RPS Compllance Outcome 12,00 10,0@ 8,@0 5 .,.0(, '1,O0 2,O0 0 2013 2014 2m5 2016 2017 2018 2019 2(20 2021 2022 ruilondlditcsurrnd.nd Sllund.dLnls'rdaffi romnY-hl&hfu rYr{dHHHbh @Yd{d thrd.d EC Int 3&u -h0.1 Rqtut WashlnSlon RPS Compllance Outcome 2013 2O1,t 2015 2015 20d7 zota 2019 2o2O 2o2t 2022 -U&ndldffiffird N8lll#b*ffid.d 7(I, 6{r, vn a4m3t, :,(I, 2m 1(D o @Yr{d Utufr d E hl &LE -tuI hdrmnr Callfiornla RPS Gompllance Outcome :!{D 250 2(I, ! rsootq, 50 0 2013 20t1 2015 20t6 20tf 20ta 2019 2(,20 2021 2@,2 rurtq|dbd8Esurtd.od @&ndhlsafu -cmilYr&mtu$mnddd rYdtd hLd 8r*bh EYAand trtqdadn€c httrt@+hud Sqll@nr Federal RPS @mpllance Outcome 12pq, topm 8,(nO Ei s,ool, 4,(m 2,(m 0 2013 2014 2015 2(}16 2017 2018 2019 2(n0 2027 2(p2 -t,ffiffi$rilrtr N&ndhl$nrlffi ImnYshdbslmdrtd IYr.d k ildSr*Dlrc @Yo{d thmd.dllc htLbr-bud t{dffi 50 PecnrConp - 2013 IRP Uppare CHAPTER 5 _PoRTFoLIo DEVELoPMENT The 2013 IRP Update focuses on changes that occurred after PacifiCorp filed its 2013 IRP and includes comparisons to the resource portfolio developed for the Business Plan. These primarily involve updates to load forecasts, and any additions to the Company's contract assortment. Table 5.3 summarizes the annual megawatt capacity, timing and differences in resources for the 2013 IRP Update and 2013 IRP preferred portfolios for the comparative lO-year period of 2014 through 2023. Consistent with the reduction in resource need, driven primarily by a lower load forecast, the addition of new resources was reduced in the Business Plan and again in the 2013 IRP Update resource portfolios. This is primarily evident with reduced reliance on FOTs, and given the relatively minor changes in demand side management (DSM) resource selections, PacifiCorp has not modified its 2013 IRP Action Plan and continues to target accelerated acquisition of cost-effective energy efficiency. Outside of the first ten years, the first major thermal resource is deferred from 2024 (2013 IRP Preferred Portfolio) to 2027 (2013 IRP Update), and as discussed above, wind resource needs in the 2024-2025 timeframe have been lowered by 170 MW. Table 5.4 summarizes the 2013 IRP Update load and resource balance for 2014-2023, and Table 5.5 displays the detailed 2013 IRP Update resource portfolio through 2032. 5l PACIFICORP _ 20 I3 IRP Uponrs CHeprrn 5 -Ponrrolro DEVELoPMENT Table 5.3 - Comparison of 2013 IRP Update with 2013 IRP Preferred Portfolio fiod Ofu tcrtirns irresorc oal art lGltu nragr. ' 2013 IRP - Prefcmrd Portfofio lm ItI, 2altt ilu ,I3 ,0ta 'ot7 ^,,ola frb tctl t*at lrrr I-l 6{5 613 k:- Perkir Efti6'115 ll7 103 l0l 91 9:o0 81 80 ll 68 otD {6 - flidnill S.il,I t{l8 11 t.{l4 li l5 l5 l$ :odrirdllcet& Pmu I I I ll 7fl0 L I IJ I l0l ta7 It, hrhIntb. larlF*'RaimC (50:RM DL*Fd-^er# ;oal H:r Gls Collrrioo Addibls l3E 338 Iirtin l-iomdcs 14 forll ?91 l-t86 m,1.102 lllS l-1lt l-!21 lJlS l:87 l-fin lslt Fro[ Ofu Trcrtbos bresqJrcc oEl ert l01trr ltnge. t 52 PACFICoRP - 2OI3 IRP UPDATE CHAPTER 5 -PoRTFoLIo DEVELoPMENT Table 5.4 - 20[3IRP Update Capacity Load and Resource Balance 2016 2011 201t 2019 2020 2021 Theml Ilydmelecuic Raewble Purchce Quali$ing Frcilitics Sale l.IotrOmed Rcscryos Tmsftn EEt &i!6n8 R.!uct! 1162 1,132 Corbined heat md Forcr 0 I Frcnt Offce Tmsrctions 0 0 &s00 Wild 0 0 Sole 2 4 Other 0 0 btPl.ednd@rca 2 5 DttTocd n luccr 7551 1.111 6454 6.454 6,4v 6,454125 t25 tn n5 82 g2 82 82 425 3t2 312 3t2 93 93 93 (R8) (663) (653) (663) (38) (38) (38) (38) 491 615 6n 5M 6195 5pr0 69t9 6949 6,454 6,4y 6,4y 6,454 tE t25 t25 tU 8a818179 3t2 2s3 A3 83 v) 8t 88 (653) 083) (183) (183) (38) (38) (38) (38) 903 650 7& 1 125t 1464 75s0 7506 4466 1010043 0000 0000 13 15 t8 2'0000 llt t9 21 59 1)85 lAEa 7F14 7675 1,395 7,511 7,635 1,757 6,626 6,460 lll ll0 v) a2 62 62 7983 Q63\ (738) (38) (38) zEt 5ll 33 00 00 00 6E00 911 33 a t7t 00 00 l0 t200 77 tt6 5105 6191 1066 7,t35 6,N2 6,916 7,028 7,1336,8t0 6,%0 Erdsting REsourc$ : Intemptiblc (lse) (159) (186) (186) 086) (186) (186) 08O (l8O (186) Class I DSM (3?9\ (32e) (32e) (3ze) (32e) Qze) Q2e) Oze') Q2e) (3ze) NwRaourccs: ClasslDBM 0 0 0 0 0 0 0 0 0 0 Class 2D8M (105) (152) (l%) (u4') (28e) (330) (370) $aD (443) (478) EEtouitdi@ 6217 5290 5rtl 6'ls7 6221 6rEE 6510 6595 5$71 6J64 PfanoingResencs (137o) 808 818 791 800 809 817 8,16 857 868 879 EltRscro tot ElE 791 t00 t09 tl7 t45 t57 E5t 479 trrtouig.tio+n lcre! 1P25 7'l0E 6812 5951 7'033 7'105 7356 7452 7541 1543 ErtP6itim 39 29 33 34 33 30 30 31 29 12 ht RBGru l&rtitr 14% l3o/o l4o/o l4yo l4/o l3'/o l3o/o l3o/o l3o/o 13% Themrl \5U 2,5U 2,506 $drcelectric m T5 n4 Rcnemble 38 38 38 Purch$e lE7 190 2l Qualifying Frcilities 99 86 76 Sale (306) (M 05, Nonomed Reservcs (3) (3) (3) Tmsftn (29i) (512) (493) WcltHldr8 nBrucB 3P2a 2r9l 2J52 Codbined hest ud Fowr | 2 2 FDnt Oftc Tmsrctions 503 659 Tn G6000 Wind000 Solsr 0 0 0 Other 0 0 0 WcltPlredRtlarcGr 504 551 795 W.ltTotrl Rdarcd t521 3552 3557 load 3,174 3Pl 3,251 L503 2,503 2,503 2,fi3 Zflt 2,500 2.91 v4 70 730 734 st 652 652 3E 38 38 38 38 2t 2t 212t3 133r76 7t 7t 7t 7t 7t 61 056) (156) (r57) (157) (r53) (100) (ro2) (3) (3) (3) (3) (3) (3) (3)(516) (52e) (585) (eos) (651) (740) (800) 2517 2592 2599 22t1 2A49 2AO1 2135 3344556939 989 989 1.325 I,178 t24t 1,325 0000 0000 0000 0000 00 00 00 00942 992 993 t)29 1,113 1215 rrSr t57e 35E4 3F92 3613 '5t2 3650 3666 3,294 3,325 3,349 3,382 3tt2 3,442 3,475 Eiistirg R6ourcs : Inremptible0000000000 ChsslDSM 0 0 0 0 0 0 0 0 0 0 New R6ources: ClasslDSM 0 0 0 0 0 0 0 0 0 0 o8s 2DsM (60) (84) (loe) (13, (158) (175) (187) Qa]) (218) (240\ WcltoBitdio 3,11,1 3,111 3,142 3'159 t,161 3,114 3'195 3109 1221 3r3S Plming Reserues (137o) 405 ,lO8 ,tO8 4ll 412 413 4t5 417 419 Al WcltRrlcmr 405 il0t 40t 4ll 412 ,413 il15 411 419 421 Wcltouitdio + R.lcru! 3519 3,545 3550 3570 3F19 3,5t7 3,510 3626 1513 3,556 W6tP6ilioa71955367l0 Wst Rtlcru l}turitr lv/o l3yo l!/o 13% l!/o l!/. l3o/o l!/o 13% l!/o Toad n loreq 10,591 10,68!) Ouigaio q33l 9,427 Rcrcro l2l3 1,26 OHit.lio + Rsrru! 10,544 1q653 S}lbDP6iiio 47 36 n lcru li,tu8ltr le/. l3o/o t0,62 10,570 1q650 to,7n 10,999 ll,ll5 ltp{ ll,341 9,U 9,316 9,391 9,$2 9,705 9,8& q90t 9,999 I,l9 t?ll t,Dl t,Bo 1,262 1275 t,287 l,3m rc,4n rc,s27 10,612 t0,92 1q967 il,o79 n,lE8 n,299,10 43 38 35 32 36 36 42 t30/o 13% t30/o t3% tT/o 130/o 130/o t3% 53 =rr) I E E a I d t nl 3 T U g l I I l l 1 ! E Lonr cl q)a o 6l tril-tnoN Iiala q) E6l Fr FzE o ..1IJ] qao.] F& Or I &IJ]k () t!F o A{/^ N I doU t() o. PACFICoRP _ 2OI3 IRP UPDATE CHAPTER 5 _PoRTFoLIo DEVELoPMENT The Business Plan expansion resource portfolio is similar to the 2013 IRP Preferred Portfolio with the exception of DSM and FOTs. The DSM values are slightly different from what were in the 2013 IRP Preferred Portfolio due to updated and slightly lower load forecast, and the changes in FOTs reflect the change in resource need as described in Chapter 3. Table 5.6 summarizes the annual megawatt capacity, timing and differences in resources for the Business Plan resource portfolio and the 2013 IRP Preferred Portfolio during the comparative ten-year period of 2014 through 2023. Major changes within the ten-year period include reduction of FOTs and DSM. Outside of the front ten-years is a reduction in wind resources by 248megawattin2024, partially offset by an increase of 147 megawatts in 2025. Table 5.7 shows the capacity load and resource balance for 2014-2023. A more detailed table of portfolio resources is provided as Table 5.8. PACIFICoRP _ 20I 3 IRP UPDATE CHAPTER 5 - PoRTFoLIo DEVELoPMENT Table 5.6 - Comparison of Business Plan with 2013 IRP Preferred Portfolio 2014 Business Plan Portfolio Frcrt Oftce Tmrctbre in resowe total tre lo-yeil arerage. * Differrnce - 2014 Business Plan Pofifolio Less 2013 IRP Prtferrtd Pofifolio Frort Offce Tmactbre h resouce total ae I o-yeil average. * 2013 IRP - Prtferrtd Portfolio Reroure Iilbllrd ..rm.itu- Mttr,t lLw..r 2013 2014 2015 2016 2017 2018 2019 2ff20 2Al 20,2 2l}23 Tot l ernubnOotiom la - CCCT 645 645 ia- Peakim )SM - Ferw Fficiprw u5 103 t0t 97 92 90 8l 80 82 68 909 )SM-Inr.laotr^l tenemble - Wid lerewble - Utilitv Solar 4 3 6 tereMble - D6trbued Sohr 7 ll l4 l6 l8 t4 l4 t4 l5 l5 t5 147 lombired Heat & Power I I I I 1l ;rom Ofice Tm*tbro *650 709 845 983 I l02 )09 1 1)1 1 4)O I 19 I ji?1.421 1.154 Erbtim Unit Ctruei loal Early Retirenrerr/Corenbro (502 (502 lleml Plam End-ofllift Rairements loal Phrr Gc Conersbn Addtom 338 338 lubire Uosades t4 fob I 191 I.4A6 8t2 r.102 1218 t3l5 l.a7 1.515 1287 1.,tilt l.5l I INtrled Crmcitv. MW lGyeer 20t3 2014 2011 2n16 2017 20t8 2019 2$2n 2tD1 2m2 2(D!Tnfil lrmroirn ootiou ias - ('(-("I ias- Peakip )QM - Fero FfrrGmt 2 (0 (o II II fl (o (o (4 t4 (14 )SM - load Corrol 21 2l -not!/akla \l/mi lerewable - lltiliru Solar 12 3 II 2 kremble - Dbttrued Solar lombred Heat & Power rrofr ()llice Tmnectbns ll71 093 (l76 fl86 (r71 |'7'7 fl98 (80 (69 fl55 ( 133 o54 hirtinc lJnit (lercer loal Eah Retrererr;/Coruersinro :tEtml Plarf Erd-of life Retftmenls 'oal Plafr Ges Cowersnn Additnns lubire ljooades lotsl lt1l (190 (fi4 (r87 (172 (174'(198',459'.(70 (r59 (r37 Frort Ofice Trcactbre ir resorce total ue l0-yeil average. * 56 PlcnrConp - 20 I 3 IRP Upnnrs CHAPTER 5 - PoRTFoLIo DEVELoPMENT Table 5.7 -Business Plan Capacity Load and Resource Balance Yes Thcmd 6,626 6,m 6,454 6,4Y 6,4Y 6A5r'. 6A54 6,454 6,4s4 6,4Y Hydrcel€ctdc lll ll0 125 125 ln D5 125 125 125 125 Rencuable C2 A n g2 82 tZ 82 81 8l 79 Purchse 62 62 425 112 312 312 312 283 253 83 QuafiryingFrcilitios D 80 83 83 83 83 83 82 78 ?8 Salc (R8) (28) (738) (663) (663) (653) (66, (183) (183) (183) Ilon.O^dedRoscrvg (38) (38) (18) (38) (38) (38) (38) (38) (38) (38) Tmsfes 353 5&7 578 A2 fi3 562 906 742 &25 801 htEdtlitrtn6oret 7'147 72oS 697t 6997 6955 6917 725t 1;16 7S2s 7599 Cor$iaedhcatmdPowr 0 I 3 3 3 3 4 4 6 6 Fmnt Omce Tmsetions 0 0 0 63 178 2A 190 o 7 138 &s0000000000 wbd0000000000 Sohr2168t01213l5l820 Other0000000000 FltPlmdR.lNcct 2 5 9 74 l9l 297 201 19 3l l6il htTotdRB@cc! 1,149 12to 6p80 1,P71 7,116 1214 7A6E 7'555 15s6 1J63 Load 6,89 7,W 6872 7,000 1,113 1,221 7,4W 7,612 7,731 7,t59 Edstirg Resourcd : htenptible Class I DSM New Resources : Clas I DSM Class 2DSM 00000000 (2{B') (256) (304) (34e) (3ez) (431) (468) (5o4) 6,r{1 5229 6294 5)51 5510 6565 5J1t 6110 Tr9 810 8t8 826 855 U7 8n 889 799 Elo 81E E26 E55 867 811 EE9 Plmning Rcsewes (l 37o)8t8 826 EBtRclcm! EIE t26 htouitdiil+ndcrut 7'll0 7,1E0 FstP6itim 39 30 EltnrtcreltlrrtiD le/o Bo/o 6911 7039 7,112 7,tE3 7435 7533 7$25 1J29 33 '2 31 3t 33 32 3l 34 t{/o t{/o te/. B% t3% t!/o r30/. t!/o (r59) O5e) (186)(32e\ (329\ (32e\ (lE6) (186) (186)(32e\ Qze\ (32e) (186) (32e) (185) (329\ (r85) (32e) 00 (ll2) (152) EltoHitdio 5392 6r5a Corbined hcat md Powr Frcnt Office TEsrctions &s whd Sohr Other Thcrnnl Ilydrcelectric RacEbk hrrchse Quali&ing Facilities Sde l.Ion-OMed Rrscryos Tmsfere Lord Bbting Resoure: Intcmptftla Class I DSM New Res ourccs : Class I DSM Class 2 DSM Phaning Reserucs (137o) W6tEirdogx.lwca 2963 2rl7 \su \54m Tl5 38 38 187 190 986(305) (201) (3) (3) (353) (586) I 583 0 0 0 0 WcltPl@dRssrcc! sEl 758 WcltTo(ll R.!0rcct 3547 3575 \503 \s03 15m 2,497 734 At 652 652 38 38 2t 2l 3333 7t 7t 71 67(ls7) 053) (rm) 002)(3) (3) (3) (3) (e06) (142) (8m G03)22E 2r5r 2)t7 2332 4566 t,325 1,258 1,325 t,325 0000 0000 0000 0000 1329 1273 rJ31 rr31 \s06 7t4 38 2t 76 (ls7) (3) (su) 2,F11 2 901 0 0 0 0 903 \58 n4 38 2l 76 (r56) (3) (64,\ 2$tt 3 989 0 0 0 0 992 \sca 747 38 2t 7t (156) (3) (605) 2$t5 3 989 0 0 0 0 992 \so3 730 38 3 7l (l5a (3) (564) 2621 4 9B9 0 0 0 0 993 WdtRB.rur 407 411 wdtoHitdim +nBcre! 3,54f 3569 Wdt Pdilio 5 6 Wst Rdcre lt&rtio lT/o l1o/o 3,5E0 3,60J 3,60E 4,514 3512 3,531 3,6{E 3$6' 3,272 3,318 3350 $n 3,412 3,442 3,473 3,508 00000000 00000000 0 0 0 0 (2r) (21) (21) (21\ (n3) (r3e) (162) (180) (le4) (214) (231) (2s4) 3,159 t,119 3,ttt t,197 3,197 t)07 3221 3133 4ll 413 414 416 416 4t7 419 42n 'lll 413 114 416 115 117 119 420 3570 t592 3502 3,613 t613 3524 t64O 3,65tl0 116lo)7410 l3% l!/o l3y. 13% 1!/o l3o/o l3% l!/o 2 756 0 0 0 0 3.195 3244 00 00 00 (61) (86) Wqtouildio 3'134 3'15t 407 4lt Totrl RBUcrr 10,696 10,?85 OniSrdm 9,426 9,512 f,.!.re! lzs lP1 Ouitrlio + Rscru! 10,651 10,749 SyIEE Pcili[ 45 36 Rcrcru lllrgir l3o/o l3o/o 10,560 10,04 to,1y 10,828 ll,0m ll,l% 11,304 |,4?n 93A7 9,,$8 9,4U q554 9,m 9,873 9,969 lqoRr2l0 1,223 1,233 I,A2 \nt 1,283 t2s6 1,309 10,517 10,631 lq15 rq796 11,048 ll,156 t, s 11,382 43413932324o394/ r!/" l3yo t30/o t3% 13y. 11% t30/o t!/o oolal I " lat l-l 8 ul 'i I ul E E =l ul !It -l * r a 6t € , 6 c 1 , Z 6 E: b Fz IJ.] -]q.l lI)H J ,rFd,o0r I &rllFo. (J E L Fr 6l (l)o 6l A anv)o rA !a Ia ra €)EclF tr.lF F Ad co oal I d (-) ll U PACIFICoRP - 20 I 3 IRP UponrS CHAPTER 5 _PoRTFoLIo DEVELoPMENT In its order acknowledging the Company's 2013 IRP, the PSCU directed the Company to perform a sensitivity case with stochastic analysis using the capacity contribution of wind and solar resources applied to determine avoided costs in Utah. The peak contributions, represented as percentage of resource nameplate, for avoided costs are shown in Table 5.9. Table 5.9 - Peak Contribution of Renewable Resources, sensitivity study 2013 IRP Uodate 20.5o/o 69/o 84o/o 2OI3IRP 4.2o/o 13.60/o 13.6% In addition, the Company has performed studies addressing the impact of reduced costs of solar resources while also applying the capacrty contribution assumptions shown above. The updated costs of solar resources are shown in Table 5.10. The Company performed sensitivity studies using the SO model to determine the impact on resource portfolio composition, and using the Planning and Risk model (PaR) to determine the performance of the portfolio against stochastic risk. The case definitions assumed for the sensitivity studies are based on Case EG2-C01, Case EG2-C07 and Case EG2-CIO as defined in the Company's 2013 IRP. The cases all relied on the Energy Gateway 2 build-out, assuming segments C, D, and G are constructed. The variable assumptions for the core cases analyzed are summarized in Table 5.11. Table 5.12 is a portfolio comparison between Case EG2-C01 from the 2013 IRP and the comparable sensitivity study using the capacity contribution assumptions from Table 5.9. In the sensitivity study, the peak conffibutions for both existing and potential renewable resources are revised to match what are in Table 5.9. The purpose of this sensitivity study is to demonstrate Table 5.10 - Updated Costs of Solar Resources, sensitivity study (50 MW AC) Table 5.11- Core Case Definitions 59 PACIFICORP _ 20 13 IRP UPDATE CHAPTER 5 - PORTFOLIO DEVELOPMENT whether there would be more renewable resources selected on an economic basis if their peak contributions are assumed to be higher than what the Company assumed in the 2013 [RP. Note, with higher capacity contribution assumptions, the resource need is deferred, as evidenced by the overall reduction in resource additions. The sensitivity shows that relative to Case EG2-C01, an additional 52 megawatt Wyoming wind resource in 2024 and an additional 598 megawatt wind resource is added in 2032. No additional utility scale solar resources were added in the sensitivity, and no incremental renewable resources were added in the front ten years of the planning period. 60 ItiILIi I a:G C T F t a .!644 q. c E :E! I I NN Nr a e G! E ui FI F c r F F t F IY c F a I N F d a{ c € Q N 6 o rE a c ! o , c a 6 ! c 5 F o r I I c N a c q F I o €i Uaa T I d .9d4 E ,5 ,q ! f I s3 3- ,9a t|) I .C d I IF .t c I t 3 I 1 ?3 E E , E ,9 ,9 o € R Ic Utc.l E] 0)(A6() a .A q)a o E L oU 6lo!r 6l cUIN(J H eahctU rAL6l U E t IN ia eE6lF FzE ..1I! El t-a -] lLF I & FrF U IJ.]F e 0.& c.t N I doQ Il U I I! I I ? T 6s r tr i I .! ii tr J I1i F r € s N N 5 Fg 5 E I6 tr Ed 5 dd ! r F 5 u I I ?.o o !g i e F F g A EUc rE c ,l.t E ri .a o 'i 6 f 9 4? E o I s ,q r {I a)o C)Lr,oE l-lo € o I!F n o.& co N I d (-) It() Pr Fzql 2o. -.1El tr.l ! -]o d 0. I q.] F U PACIFICoRP _ 2OI3 IRP Upoerr CHAPTER 5 _PORTFOLIO DEVELOPMENT Table 5.13 is a comparison between Case EG2-C07 in the 2013 IRP and the sensitivity study using higher capacity contribution and updated costs of solar resources. Results of this sensitivity study show that there are no additional renewable resources added beyond what were added in the 2013 IRP Prefened Portfolio. However, the higher capacity contribution reduces resource need resulting in the elimination or deferral of other resources that were included in the 2013 IRP Preferred Portfolio. Table 5.14 is a comparison between Case EG2-CIO in the 2013 IRP and the sensitivity study using higher capacity contribution and updated costs of solar resources. Results of this sensitivity are similar to those discussed above; however, an additional 52 megawatt Wyoming wind resource is added in2024. 63 +\o EtI J iT J ?:d dI 6 I o d a c II, ! t a I I d a! I I Ii r N F Irj o o tr *9 I F d o II c €r F a t F c rI r a E € -N a k o N F dr (k v F c 6 €Ed o Y I d =a € 5,N 6 a tr d c a o F c a c r 6 F qF! c o F i 8 .q ,9 ,ed ? E a 6 9 ,! t F E s ,9 I -e Y I +d =3 ,9 o ,q g a I '! .!tE tts f- Uto.l trl C)(, cqU a o o(h o UL GI oa r- (J Iol rd !)o6lU Eh licl oU o LoFr I(a rao 6lF FzrJl A ..1q.l IJ] ..] F& o. Ih &l!F (J rI]F p d c.l e.l IA O E U EJ I iI Ih F ts !aa c i I .! II I a I IJ t a J c r F 6 E v F F! € 6 6! 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PecnrConp - 2013 IRP Upoare CHAPTER 5 -Ponrrorlo DEVELoPMENT At the request of the PSCU, a Planning and Risk (PaR) study was completed on the Case EG2- C07 sensitivity that assumes higher capacity contribution inputs for wind and solar resources (i.e. the sensitivity resource portfolio shown in Table 5.12). Table 5.15 compares the risk-adjusted PVRR between Case EG2-C07 and the sensitivity case. Table 5.15 - Comparison of Risk-Adjusted PYRR between Cases EG2-C07 and the Capacity Contribution Sensitivity 67 PACFICORP - 2OI3 IRP UPDATE CHAPTER 6 _ ACTIoN PLAN UpoeTe CuaprER 6 - AcuoN PreN Srarus Upoare This chapter provides an update to the 2013 IRP Action Plan. The status for all action items is provided in Table 6.1 below. Related to the Action Plan is the Acquisition Path Decision Mechanism, included as Table 9.2 in the 2013 IRP. The PSCU noted that this was a "very useful table." The acquisition path analysis focused on load trigger events, and combinations of environmental policy and market price trigger events that would require alternative resource acquisition strategies. For each trigger event, there were potential ramifications to both short-term (2013-2022) and long-term (2023- 2032) resource strategies. The PSCU encouraged expansion of the table going forward. The analysis contained herein looked at updates as included in Chapter 3 (load); and Chapter 4 (modeling updates). Specific updates were provided for gas costs, solar costs and capabilities, as well as specific resources. Sensitivities focused on the changes in solar cost and capabilities. Overall with all of the updates, the major finding is that resource acquisitions are pushed further out, mainly due to the decline in load forecasts. For the 2015 IRP PacifiCorp will work with Stakeholders on more fully developing the acquisition path decision mechanism. 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PeCrIConp - 20 13 IRP UPDATE AppsNolx A - ADDITIoNAL LoAD FoRECAST DETAILS ApppNDIx A - AooIUONAL LOen FonpcAST Dprans The load forecast presented in Chapter 3 represents the data used for capacity expansion modeling, and excludes load reductions from incremental energy efficiency resources (Class 2 DSM). To arrive at the retail sales forecast, the initial load forecast is reduced by total Class 2 DSM as well as line losses. Table A.1 shows the retail sales forecast by state that is consistent with the 2013 tRP Update load forecast. Table A.2 shows the change in the load forecast as compared to the 2013 IRP. Table A.1 - 2013 IRP Update Annual Retail Sales Forecast in Megawatt-hours by State 2014 13.01l.l2l 3.971,s79 769.s97 D.,&ffi.795 9.705269 3.389.r70 53.707.529 2015 13.t6271 3.%7.n7 767,691 n.671.994 9.877.707 3.N2.45 s4.80322s 2016 13.13.018 3.979,083 768.813 24.536.991 0.04925r 3.421.656 55.868.812 2017 13.67.161 3.%9219 765,290 24.8V2.3@ 0.147.190 3,431.597 56.282.76 2018 l3 78,870 3-975-811 7&,323 25.076.147 0.257.657 3,4/'3,919 56.6%.727 20t9 13206..4U 3.983-129 763,62 25.421246 o-371.679 3.457.402 57.203.@2 2020 13267.439 3,999,8s4 763.991 26.333407 0-50'7.412 3.474"599 58.34r.703 2021 t3-258-936 3.991.501 7@.W 26.6il.633 0.572.081 3-483.313 58.7243M 2022 13.302.688 4.001.736 760.086 27.W6.817 0.653.730 3.4y7,362 59302-4,9 2023 13.3il.939 4.0r6.918 7fi.m 27.ffi2.U1 0.7il257 3.s16.168 ffi.44-723 2014-2023 030%0.130/"4.13o/"2.12V"l.l6Yo 0.4lYo l24Yo Table A.2 - Change in Annual Retail Sales Forecast in Megawatt-hours by State compared to the 2013 IRP 2014 /L56.999\,27,583 4.491\@ss.637)(16.052)(41.1 10)(ffi.70s) 2015 o17.fiv 27,720 (4.70r)279,ffi fl6.8s2)(54.378'114.31s 2016 Q29.8ts)26.734 rs.138)%r,49 Q5.728\(68.4s61 598.566 2017 o2t-3&\26,M9 (s.774)859.171 (36.0s9)(f1.2a'550,14 2018 o59-135)22.1@ (7.4r',9\819-281 (50.663)(79.sssl w,587 2019 Q93,60/.)18.755 (8.720\856.91I (57-516\$3.734i 432.W3 2020 822.ffi)16.2N (l0.Vzz^.4r9.8v2 (70.559)(90.0021 942.9M 2021 (350.931)15.136 0.Ms .528.901 (86.64s)(.86.72t\,1.010274 2022 (363.r39)t32so (8.84e1 .ffi.430 004.lro (87.9091 1.w3.ffi 2023 (378,659)I 1,100 (8,136 ,781,7n (123,375)(85,636)1,197,04 Tables A.3 shows the retail sales forecast by class that is consistent with the 2013 IRP Update load forecast. Table A.4 is the change in the retail sales forecast as compared to the 2013 IRP. 85 PACFICORP - 2OI 3 IRP Upoare APPENDX A -ADDIIONAL LOAD FORECAST DETAI.S Table A.3 - System Annual Retail Sales Forecast in Megawatt-hours by Class 2014 5,425,806 t7,252,5M t9,346,275 1,262,775 143,080 277,050 53,707,529 201s s-419.29 17-578.512 20.126-314 r.252-W 143.090 n4-w 54-W3.225 2016 5.503.658 17.865.986 20.819.565 t-261-233 143.630 274-740 55.868.812 2017 5-520.233 18.102.730 20.982.24 1.260.301 t43-2ffi 274.M 56.282.76 2018 5.607.m6 t8-2ffi.895 2t-146.431 t-259.ffi 143.330 n4-w 56-696-727 2019 5.7W.357 18.405.178 2t.413.K5 t.257.8t3 143,390 274.m s7.203-fi2 2020 5.814.139 18.fi6,427 22,250.818 1.256.749 143,830 274,740 58.346.703 2021 5.86r..n9 18.704.7%22.480.323 r.255,459 143.500 274,000 58.724.307 2022 5.982.47E 18.865.953 22.782.n1 1.254.177 143.540 274,W 59.3W.4t9 2023 6"t26.149 19.095.913 23.131.650 1.253.4[143.600 274.000 fi.04.723 2014-2023 0.49V"l.llo/"2.Olo/"4.08%O.O4Y"4.lzYo l24o/o Table A.4 - Change in System Annual Retail Sales Forecast in Megawatt-hours by Class Compared to the 2013Integrated Resource Plan 20r4 (6s.322\(52.058)/L49-0tr6'7.761 1.430 550 (ffi-705' 201s (541.943',(825)639-445 7.630 1.370 n.360 lt4.3l5 20t6 (6ls.7w\9.042 1.186.215 7.489 1.430 100 598.566 2017 (657.851)65.756 t-123.761 7.il1 1.430 40 550-782 2018 (713-482 88.712 l-050-177 7.300 1.450 430 444-587 2019 (758.034 lL9.254 1.051.546 7.137 LM 730 432.W3 2020 (817.@9\l53-562 t^587-063 5.888 1.450 1.590 94L9M 2021 (823.357 t90-01I la4-571 6-519 l-450 1.080 t-010-274 2022 (838.930 235-713 1.678.009 6-233 1.450 1.190 t.@3-ffi 2023 (861.821)280.156 1.759.975 6.053 1,450 1.270 t.tEt-082 The change in the retail sales forecast is driven by a decrease in residential loads, due to increases in energy efficiency and slowing $owth in central air-conditioning saturation, and an increase in commercial and industrial loads due to changes in self-generation assumptions as well as continued economic recovery. 86 PlcrrrConp - 2OI 3 IRP UPDATE APPENDX B _ CoN{BINED HEAT & PowER EXECUTIVE SUTTIUARY APPENDIX B - COTT,TSINED HPATAND POWEN Exe c url vE S utr,ttrteny Action ltem 2b in the 2013 IRP Action Plan states that PacifiCorp will pursue combined heat and power (CHP) opportunities primarily through the Public Utilities Regulatory Policies Act (PURPA) qualiffing facility (QF) contracting process and states that the Company will complete a market analysis of combined heat & power (CHP) opportunities in the 2013 IRP Update. This appendix summarizes CHP opportunities consistent with Action Item 2b. This study covers opportunities across PacifiCorp's jurisdictions with a focus on PacifiCorp's western balancing authority area covering the states of Oregon, California and Washington due to available woody biomass fuel supply across those states. Among these states, Oregon is the most progressive and supportive of the development of biomass CHP projects with specific state initiatives and task forces to encourage the development of biomass generation. The use of biomass across PacifiCorp's territory to generate electrical power has stagnated as a result of the decline in home construction caused by the recession and uncertainty related to the control of federal forestland for harvesting. The reduction in wood products production due to mill closures has reduced the availability of lower cost and clean woody biomass fuel for thermal and power generation as well as the thermal processing need that supports the base load operation of a steam turbine for power generation. [n addition, changing market value and conditions for environmental attributes under the available renewable portfolio standards (RPS), decreasing avoided cost prices for QF regulation, and reduced or uncertainty around tax credits or incentives in the western states served by PacifiCorp have contributed to a pull-back by independent developers of biomass CFIP facilities as well as the forest products businesses whose core strengths are the management and acquisition of timber for production as well as supply of energy for use on-site or sale to the electric utility. Results of this evaluation suggest that the Company should continue being responsive to independent or customer developed new generation opportunities through PURPA projects and assisting those developments on their decisions as they determine the use of the generation for off-setting on-site load or selling to the utility. The Company should also continue to participate with organizations in their effort to develop the appropriate legislative, governmental and regulatory incentives for biomass projects within the Pacific Northwest. Biomass energy is derived from four distinct energy sources: garbage, wood, waste, and landfill gases. Of these four fuels, garbage and landfill gas are generally not applicable as a CHP and the most prevalent in PacifiCorp's territory is the use of woody biomass. Table B.1 summarizes PacifiCorp's existing QF power purchase agreements by state that are biomass and operate as CHP. 87 PACIFICoRP _ 20 13 IRP Upmre AppENDx B - CorIBTNED HEAT & PowER Er<ecurNr Suuu.qny Dairy and plant waste (Methane) There are two major fuel sources for biomass power generation, mill waste and forest thinnings. A minor, but growing, source is urban waste wood which is generally a source procured by forest products firms and is treated in this report as inclusive with mill waste. Mill Waste Forest products manufacturing produces waste including bark, sawdust and planer shavings. Chips are sold to pulp mills. Mill waste is consumed by plants to produce steam for internal use. Table B.2 summarizes the existing, proposed and potential biomass generation on PacifiCorp's system based on the four generation methods. These generation plants are fueled mainly by mitl waste, either generated internally or purchased, and to a much smaller extent, fuel purchases in the market (i.e., urban wood waste). No projects were found on PacifiCorp's system in ldaho. Of the existing projects below, PacifiCorp is the purchaser of the output from the plants as QFs and owns the turbine asset at Georgia Pacific in Camas Washington. All are directly interconnected to PacifiCorp's transmission system. Approximately 114 MW are currently under contract to PacifiCorp or self-supplying their load. More and more QFs are moving to self-supply of their load first and selling excess due to the price differential between retail rates and avoided cost prices. Table B.2 - Woody Biomass Generation on PacifiCorp's System * Roseburg Forest Products @illard) - 20 MW is exported to PacifiCorp** Georgia Pacific Corporation - currently operating at 14 MW 7 There are six landfill gas plants with a total capacity of 14.6 MW, three each in Oregon and Utah which are not considered for this analysis. CA Rosebure Forest Products Weed OF - Self suoolv first and sell excess 10.0 OR Roseburs Forest Products *Dillard OF - Selfsupply first and sell excess 4s.0 OR Biomass One Medford QF 32.0 OR Warm Sprines Warm Sorinss Self-suoplv 9.0 OR Douslas County Forest Products Roseburg OF - Selfsupply first and sell excess 6.3 OR Roueh & Readv Lumber Cave Junction QF 1.5 OR Freres Lumber Mill Citv QF 10.0 WA Georsia Pacific Corporation **Camas PacifiCom Asset 52.0 TOTAL 166 88 PACIFICoRP_20I3 IRP UPDATE AppgT.IoIx B _ CoNasINeo Heer & Powrn EXECUTIVE SUMMARY Forest Thinnings Forest thinnings represents a significant amount of fuel and electricity potential. However, it is inaccessible in the current market environment in the near or mid-term. The Energy Trust of Oregon and Oregon Forest Resources Institute suggest that up to 300 to 500 MW might be produced given available forest fuel, but is greatly dependent on workable and efficient supply and contracting mechanisms. Forest residue, if collected, represents the largest potential source of biomass energy in Oregon. Depending on the generation facility or facilities, the total electricity production could be 300 to 500 MW or more for approximately l0 years, if all of the residue could be collected and used. None of this potential is available in the near or mid-term. There is no infrastructure to gather forest residue, and costs to gather that material alone are estimated at $40-504{Wh, which is comparable to current wholesale market electricity prices. There are also significant administrative and regulatory barriers to gathering and using forest thinning. No generation projects exist today that use forest thinnings as their source of fuel to the plant. Current air regulations make it extremely difficult to permit such an operation, and contracts for supply, which must be made with the U.S. Forest Service, are limited at this time. These issues are beyond PacifiCorp's control at this point in time and therefore this market segment, while potentially promising in the long term, does not present near- or mid-term opportunities for PacifiCorp. Consequently, PacifiCorp is focusing on real project opportunities at a known customer's site and will continue to work with government agencies and/or private business to develop further incentives at the federal and state level to encourage the development of biomass generation. Market Barriers Low Electricity Prices Current wholesale market electricity prices do not support the development of new biomass power plants. Even the current standard QF avoided cost prices do not support the development of a stand-alone QF project. Most of the standard QF projects under development are utilizing the available incentives and low-cost financing to incrementally construct the generation portion of a boiler up-grade or replacement project. In particular, the price of electricity is not suffrcient to support the total cost of building and operating a plant including any fuel transportation costs. Low retail prices in the Pacific Northwest also limit the value of self-generation. Low wholesale prices limit the opportunities for selling electricity. There are a limited number of QF projects being developed at operating mills because natural gas costs have remained at a level whereby biomass fuel is not competitive. 89 PaCrrCOnp _ 20I3 IRP UPDATE AppgNoIx B _ CoTT,TsINeo HEAT & POWER EXECUTIVE SUMMARY High Installation Costs The capital cost of developing biomass-based generation systems is high, especially in smaller- scale operations. The estimated capital cost of a greenfield biomass cogeneration plant is in excess of $3,500 per installed kilowatt. This is because the project consists of designing, siting, and constructing an entirely new power plant with all ancillary facilities and grid interconnection, not just installing new equipment at an existing site. Many forest products firms indicate that capital costs often contribute to unfavorable internal rates of return, and that this limits generation projects from moving forward. In other cases (in particular, wood burning plants) the inability to guarantee a long-term fuel supply has kept companies from obtaining financing. Air Permitting Req uirements Obtaining required air quality approvals increases the project development costs and, in some cases, the operating costs of biomass projects. The smaller projects run by end-users are not familiar with air quality requirements and many cannot afford the cost of compliance. Lack of Financial Recognition of Environmental Benetits Although renewable energy credits (RECs) provide benefits to biomass-produced energy, the value of RECs in the market is low whether for compliance or the voluntary market. Many developers are unfamiliar with how to pursue the sale of RECs in the market. There are other benefits that are not accounted for as yet in the market such as greenhouse gas emission reduction. For the forest residue resources, an added benefit is reduced emissions from controlled combustion with emissions controls as compared to the open forest slash burn practice. However, these benefits have not been quantified. The biomass industry would benefit from policies and assistance that recognize that biomass offers superior benefit related to greenhouse gas emissions. Cost of Fuel Transportation The cost of collecting and transporting hard biomass fuels is expensive. This is especially true for forest residue. In addition, any regional plant that collects waste from nearby forest sites and delivers it to a central processing facility will face high transportation costs. The cost to ship the fuel 100 miles needs to be evaluated against transmission costs for the electricity. In general, for projects less than 5 MW, it is impractical to transmit electricity for long distances because the costs associated with the required transaction costs, wheeling charges, and line losses are not offset by the value received for the electricity. In the case of some larger projects, the economies of scale of developing a larger project can offset the cost of wheeling electricity from the site to the host utility. These larger projects, however, are limited in number. With a mature fuel market and transportation network in place, it is expected that mill waste would flow to the projects within the PacifiCorp service areas. 90 PaCnICOnp - 20 I 3 IRP UPDATE AppsNDx C-ENERGy ANALYSTS REpoRT ApppNDIx C - ENBNCY ANIALYSIS RBponT ENERGY ANALYSIS REPORT A mdti-plant anatysis ofpotoutid €oqgf msurntion opporflrnitiee at cfiolty onmed PeciffCorp Energy gwatioo frcilities. PngnCoRP ENERGY ADTVE|oXOf Actn@e' PacnrConp - 201 3 IRP Upoare APPENDX C _ ENERGY ANALYSIS REPORT TABLE OF CONTENTS EXECUTIVE SUMMARY PROJECTS BY PLAI\T Potentially Cost-Effective Projects ....................95 Systems Requiring More Research. ....................95 Unlikely to be Cost-8ffective............ ..................95 Potentially Cost-Effective Projects ....................96 Systems Requiring More Research. ....................96 Unlikely to be Cost-8ffective............ ..................97 HUNTTNGTON PLANT ,..,,,97 Potentially Cost-Effective Projects ....................97 Systems Requiring Further Research.................. ...................97 Unlikely to be Cost-Effective............ ..................98 CURRANTCREEK PLANT ....................98 Potentially Cost-Effective Projects ....................98 Systems Requiring Additional Research........... ...................... 98 Unlikely to be Cost-Effectiye............ ..................98 HUNTER UNrr 3 ............. .....................99 Potentially Cost-Effective Projects ....................99 Systems Requiring Further Research. ................99 Unlikely to be Cost-Effective............ ..................99 LAKESTDE PLANT......... ..................... 100 Potentially Cost-Effective Projects .................. 100 Systems Requiring Further Research. .............. 100 Unlikely to be Cost-Effective............ ................ 100 BLUNDELL PLANT......... .................... 100 Potentially Cost-Effective Projects .................. 100 Systems Requiring Further Research. .............. 100 Unlikely to be Cost-Effective............ ................ 101 GADSBYPTaNT ............101 92 93 95 92 PACIFICoRP _ 20 I3 IRP UPDATE APPENDIX C - E}.TERGY ANALYSIS RgponT Background The 2013 [RP Action Plan calls for an assessment of the wholly owned PacifiCorp Energy generation facilities to determine possible areas for energy effrciency improvements. This assessment was to be done in light of the results of the studies completed for the Washington Initiative 937 (I-937). In response to this action item, PacifiCorp completed inspections at the following eight plants: Dave Johnston Plant - Glenrock, Wyoming Naughton Plant - Kemmerer, Wyoming Huntington Plant - Huntington, Utah Currant Creek Plant - Mona, Utah Hunter Unit 3 - Castle Dale, Utah Lakeside Plant - Lindon, Utah Blundell Plant - Milford, Utah Gadsby Plant - SLC, Utah The purpose of this report is to outline the methods used to identi$ potential systems and equipment providing cost-effective energy efficiency improvements, summarize the outcomes of the inspections and rank the identified systems and equipment according to cost-effective analysis. The systems identified will be separated into three categories for each plant: (1) Having a high potential to be cost-effective, (2) needing further study to determine cost- effectiveness, or (3) as being unlikely to be cost-effective. Methodology Using the experience gained from energy efficiency studies for l-937 that were performed at Jim Bridger and Chehalis, systems and equipment at each plant were evaluated for potential to investigate. This was done by reviewing the operating characteristics of major plant systems using the plant distributive control system (DCS) information. Load dependent systems and equipment were evaluated at or near full plant capacity. The amount of wasted energy at full load is an indicator of the potential for cost-effective energy savings. Once the most likely candidates were identified, the systems and equipment were inspected to gather additional data and to discuss the operation with plant personnel. Systems not controlled through the plant DCS, typically load independent (lighting, compressed air, etc.), were also reviewed. Summary of Results The following systems and equipment were generally found to hold a high potential for cost- effective energy savings improvements: o Compressed Air Controls and Dyer Upgrades/Controls - Huntington (-l,800MWh/yr), Hunter (-l,000MWh/yr) o Heat Trace Thermostatic Control - Huntington (-80MWh/yr), Naughton (-l00MWh/yr), Dave Johnston (-l 20MWh/yr) o RO Water Treatment Systems -Naughton (-200Mwh/yr), Dave Johnston (-l90MWh/yr) o Lighting Controls - All plants* 93 PecrnConp - 20 13 IRP UPDATE APPENDIX C - E}.TERGY ANALYSIS REPoRT * Lighting retrofits to accomplish production efficiency gains do not meet the cost effective test due to the initial cost of preferred LED lighting technologies. Two opportunities for lighting efficiency improvements exist generally at each plant: l. All plants can use new or upgraded controls for lighting to save energy. A common theme at each plant was that exterior lighting is on during daylight hours. The controls for these types of fixtures tend to malfunction or become inoperable quickly due to the harsh environment. These controls should be replaced and/or upgraded. Another commonality is that many outbuildings and unoccupied areas had lighting on at all times. Areas like this that use fluorescent lighting would benefit from occupancy sensors. 2. Emergency lighting is typically left on at all times. In some plants, emergency lighting consists almost entirely of incandescent lights. Upgrading these lights to CFL or LED and ensuring that they only turn on in loss of power has potential to be a cost-effective way to save energy. The following systems show potential but require further study:o ID Booster Fan - Huntington Unit I o Coal Conveyors - Huntington Plant . Condensate Pumps - Hunter Unit 3, Naughton, Lakeside, and Currant Creek Plants o Compressed Air System - Naughton Plant o PA Fans - Hunter Unit 3, Dave Johnston Planto Boiler Water Feed Pumps - Dave Johnston Units I & 2 o Demineralization Water Pumps - Lakeside, Currant Creek Plants 94 PACIFICoRP _ 20 I 3 IRP UPDATE APPENDIX C_ENERGY ANALYSIS REPoRT Dave Johnston The systems inspected during the site visit to Dave Johnston Power Plant include the following: Boiler Feed Water Pumps FD and ID Fans PA Fans Condensate Pumps Potentially Cost-Effeaive Proj ects Compressed Air System Reverse Osmosis (RO) Water Treatment Lighting Reverse Osmosis (RO) Water Treatment Svstem: The RO system at Dave Johnston has a high potential for energy efficiency upgrades to be cost-effective. This system has new motors which are inverter duty rated. Also, there is space available to install VFD's. The control valves were mostly closed making the installation of VFD's worth considering. The projected savings would be approximately 125 MWh per year for stage one and approximately 75 MWh per year for stage two. Heat Trace Controls: There are potential opportunities for efficiency improvements by fixing or upgrading the thermostatic controls on the heat trace runs around the plant. Liehtine Controls: There are opportunities for efficiency improvements through lighting control upgrades. Systems Requiring More Research Boiler Feedwater Pumns: The boiler feed water pumps for units I & 2 are electric driven pumps. At near full load the control valve was only 25o/o open for unit I and 33Yo open for unit 2. T"he cost of this project would be high due to the voltage of the pumps, the need to purchase new motors, the size of the motors being replaced (2500 hp), the cost of the VFD's for the voltage/size of the motors and the lack of space nearby. A detailed analysis of the energy savings as well as the costs of the project would need to be conducted to determine cost effectiveness. The Feedwater pumps for Units 3 & 4 do not have sufficient potential for cost- effective energy savings as they are configured differently than I & 2. Primarv Air (PA) Fans: The PA Fans for units I & 2 represent another potential opportunity. There are six 200 hp motors providing primary air for units I & 2. These are smaller motors which would bring costs down for replacement, however space for the VFD's would be a major factor. The fan dampers are about 50% closed or slightly more. The energy saved on this project may not be sufficient to offset the cost. The PA Fans for units 3 & 4 have two large motors each and run with less damping at full load. Due to the large size of the motors and the more efficient configuration, potential for cost-effective energy savings is very low. Unlikely to be Cost-Effec'tive Comnressed Air: The compressed air system at Dave Johnston Plant did not contain any cost- effective energy effi ciency measures. Forced Draft (FD) & Induced Draft flD) Fans: The FD and ID fans were not damped enough to provide cost-effective energy efficiency measures. Lishtine Retrofit: The following table shows the cost-effective calculation for the lighting at Dave Johnston Plant. The cost and energy savings numbers are taken from the Evergreen study 95 PeCrICOnp -2013 IRP UPDATE APPENDIX C - ENERGY ANALYSIS REPORT included in the appendix8. The columns under "Net" show the cost-effective ratio for the project based on the depreciation life. Any project with a ratio under I is not cost-effective. Naughton The systems inspected during the site visit to the Naughton Power Plant include the following: Reverse Osmosis Water Treatment System Booster Fan Condensate Pumps Boiler Feed Water Pumps FD & ID Fans Cooling Tower Compressed Air Lighting Reverse Osmosis Water Treatment System Potentially Cost-Effective Projects Reverse Osmosis (RO) Water Treatment Svstem: The RO system at Naughton has a high possibility for energy efficiency upgrades to be cost-effective. There are two separate RO systems, one acting as a backup for the other. The valves were only about l0% open. The motors are new 480 volt, inverter-duty rated motors. There is room nearby for VFD placement. The costs to implement the energy savings on this system should be relatively low. The projected savings would be approximately 190 MWh per year for each unit. Heat Trace Controls: There are potential opportunities for efficiency improvements by fixing or upgrading the thermostatic controls on the heat trace runs around the plant. Lightins Controls: There are opportunities for efficiency improvements through lighting control upgrades. Systems Requiring More Research Condensate Pumps: The costs of upgrading the condensate pumps will be high. However, there is enough potential in energy savings (a high-level estimate of 3,500 MWh per year) to justiff further researching the costs to evaluate cost-effectiveness. The motors are large, 1000 - 1500 hp, at the medium voltage level and space will be an issue. Compressed Air: There may be potential at Naughton to save energy on the compressed air system. The system requires more research because all the compressors were not running. The system needs to be operating in the normal condition in order to determine how much potential there is in the project. Boiler Feed Water Pumns: The boiler feed water pumps for Naughton 1 & 2 are electric driven. The control valves areTTYo open, which means the potential for energy savings is small. This system may still warrant more research before being discarded as a potential cost-effective energy efficiency project. I Appendices to the Energy Analysis Report have been included on a CD with the 2013 IRP Update filing. 2014 IRP Cola Efiec{ye Lighling Cost and Bsnsfit Revonus Roqulr€mont C.lculatons PDj*t Cct in O$mtrt Cost Cure 2014 $s MWh Sa\,inos Used PV Rev Rdt Bs€fits PV Rev Rot (Costs)Net Nm OR OR Non OR OR Non OR OR NmOR OR )€preciable Depreciable Lib Lib )eE Johnston M.711.8O0 4.89i Wst CommeEial Liohtino S1.lo2 949 STrA 154 (S2.805.147\ $2.il2.35o'0.50 o.2a 2M7 2024 96 PACIFICoRP _ 2OI3 IRP UpperE AppsNnrx C - ENERGy ANALysrs REpoRT Unlikely to be Cost-Effective Coolins Tower: The cooling towers for units I & 3 do not have VFD control. The operating procedure of the plant is to keep the water temperature as low as possible. The installation of VFD"s would not provide much in the way of saved energy. Booster Fan: The booster fan damper was not closed enough to make project cost-effective. For a VFD, this project would require a new motor as well as long runs for the wire making project costs too high. FD & ID Fans: The FD & [D fans were not damped enough to offset the potential costs of the upgrade. There were considerable space restrictions as well as the need for new motors along with the other costs of VFD installation. Lishtine Retrofit: The following table shows the cost-effective calculation for the lighting at Naughton Plant. The cost and energy savings numbers are taken from the Evergreen study included in the appendix. The columns under "Net" show the cost-effective ratio for the project based on the depreciation life. Any project with a ratio under 1 is not cost-effective. Huntington Plant The systems inspected at Huntington Plant include the following: Raw Water Supply Coal Conveyor (Reddler Deck) Motors Heat Trace Controls Reverse Osmosis Water Treatment Potentiolly Cost-Effective Proj ects Compressor Controls: The compressed air system at Huntington Plant is comprised of 4 new Cameron compressors. During the site inspection one of the compressors was running unloaded. Also, the dryers were not efficient and the dew points settings were aggressive. The proposed upgrades to this system include new dryer, upgraded controls for the dryers and a central control system for the compressors and dryers with only two compressors running at a time. Two of the existing dryers would not be needed and turned off. The potential energy savings with this configuration would be 1,800 MWh per year. The plant compressed air load requirements would need to be confirmed before implementing the proposed configuration. Heat Trace Controls: There are potential opportunities for efficiency improvements by fixing or upgrading the thermostatic controls on the heat trace runs around the plant. The plant has a large amount of heat trace. The amount of heat trace not currently on thermostatic control needs to be identified and quantified. There appears to be potential to capture savings in this area. Lishtins Controls: There are opportunities for efficiency improvements through lighting control upgrades. Systems Requiring Further Research RO Water Treatment Svstem: The RO system flow is controlled with a manual control valve. This system has potential for saving energy but more research is needed to determine cost- Compressor Controls ID Booster Fans Lighting 2014 IRP Colt Efiac0v6 Llghting Colt lnd Bonoft Rovonue Requirsmont Calculatons 97 PacmrConp - 20 13 IRP UPDATE ApppNoIx C _ ENgncy ANALYSIS REPORT effectiveness. There wasn't as much throttling on the valve and therefore the benefit will be lower at Huntington than at other plants in the fleet. ID Booster Fan: The Unit I booster fan is a system which is comprised of two 5,000 hp,4160 volt fans. There was a significant amount of damping at full load. This project is on the border of being unlikely to be cost-effective but it does warrant a further look. Unit 2 was damped less at full load and will be considered after the cost-effective calculation for unit 1 is finished. Unlikely to be Cost-Effective Raw Water Svstem: The raw water system was wasting energy. However, the potential costs of the upgrade would have been high due to the size and location of the pump motors. Also, upgrading the controls for the system would have a high cost. Liehtins Retrofit: The following table shows the cost-effective calculation for the lighting at Huntington Plant. The cost and energy savings numbers are taken from the Evergreen study included in the appendix. The columns under "Net" show the cost-effective ratio for the project based on the depreciation life. Any project with a ratio under I is not cost-effective. Currant Creek Plant The systems inspected during the visit to Currant Creek Plant include the following: Condensate Pumps Compressed Air Reverse Osmosis Water Treatment Water Storage Tank Recirculation Pumps Boiler Feed Pumps Lighting Potentially Cost-Effective Proj ects Liehtine Controls: During the site visit there were unoccupied buildings and open areas that had lights on unnecessarily. These areas would benefit from motion sensor control of the lighting. Also, there were a number of exterior lights that were on during the day. These lights need to have the photo sensors fixed or replaced. Systems Requiring Additional Research Condensate Pumps: The condensate pumps at Currant Creek were wasting a high amount of energy across the control valve. The costs to upgrade this system will be high, though, so it requires additional study to determine cost-effectiveness. It has the potential to save roughly 2,000 MWh of energy per year if installed. Compressed Air: The compressed air system was running efficiently. However, there did seem to be an opportunity to make improvements in the air drying controls. This system will need further scrutiny. Unlikely to be Cost-Effective RO Water Treatment: The RO system already had VFD's installed. This system was inspected due to the high potential for savings at the other plants. No opportunity available to save energy. 2014 IRP Cost Efiac{ivs Lighling Cost and Eanoft Rovenuo Roquircmont Calculatons 98 PecrRConp-20l3 IRP UPDATE APPENDIX C_ENERGY ANALYSIS REPoRT Water Storase Tank Recvcle: At Currant Creek the pumps did not appear to be recycling as much as at Lakeside. Also, the valves were automatic and not manual. This allows for less waste than the manual valves. Boiler Feed Pumps: This system did have a high amount of throttling that wastes energy. However, the piping system feeds a number of other loads besides the boiler. This means that the control valve would still need to be used reducing the amount of benefit derived from installing VFDs. Hunter Unit 3 The Hunter plant is unique in the fact that only one unit is wholly owned by PacifiCorp. This removes general systems like the RO water treatment from the list of potential projects. It also complicates the compressed air system study. The systems inspected at Hunter Unit 3 include the following: Lighting Compressed Air PA Fans Pote ntially Cost-Effective Proj ects Compressed Air: The compressors at Hunter were running inefficiently. As this project only pertains to Unit 3, only the compressor for that unit is considered. However, there is still potential for cost-effective energy saving opportunities for this as a stand-alone system. Liehting Controls: There are opportunities for efficiency improvements through lighting control upgrades. Systems Requiring Furlher Reseurch Condensate Pumps: There is a significant pressure drop across the control valve in the condensate piping system. However, project costs could prove to be prohibitive. One of the major impacts to cost would be finding room nearby to house the VFD's. PA Fans: Up review of this system there appeared to be enough energy wasted to warrant a deeper look into actual project costs and savings. Unlikely to be Cost-Effective FD & ID Fans: The wasted energy does not appear to be great enough for this project to be cost- effective. Cooling Tower Fans: The operating procedure of the plant is to keep the water temperature as low as possible. The installation of VFD"s would not provide much in the way of saved energy. Lishtine Retrofit: The following table shows the cost-effective calculation for the lighting for Hunter Unit 3. The cost and energy savings numbers are taken from the Evergreen study included in the appendix. The columns under "Net" show the cost-effective ratio for the project based on the depreciation life. Any project with a ratio under I is not cost-effective. ID & FD Fans Cooling Towers Condensate Pumps 2014 IRP Cod Efioc{ive Lighong CoC and Bonofrt Rsvonue Rsquir.ment C.lculatons 99 Lakeside Plant The systems inspected at Lakeside Plant include the following: Condensate Pumps Boiler Feed Water Pumps Water Storage Tank Recirculation Pumps Heat Trace Lighting Controls Potentially Cost-Effective Projects Liehtins Controls: There is an opportunity to save energy with lighting controls. Ensuring buildings and other general spaces have occupancy sensors and photo-cells in working order would likely be a cost-effective measure. Systems Requiring Further Research Water Storage Tank Recirculation: The water storage tank recirculation pumps were running during the inspection. There was a manual control valve that was partially closed. Since this system didn't have inputs to the plant control system, we could not get good data on the amount of time that it was running and how often the valve was in that position. There is a possibility that this system could be improved to save energy in a cost-effective way. However, more data needs to be gathered. Condensate Pumps: The condensate pumps discharge is heavily regulated at Lakeside Plant. There is also recirculation in the system that appears to be a source of wasted energy. This process configuration needs additional research to determine potential energy savings. Heat Trace: The heat trace does not have thermostatic control in most cases. The circuits are turned on and off manually. More investigation is needed to determine the energy savings potential and cost. Unlilcely to be Cost-Effective Boiler Feed Water Pumps: This system does not appear to have potential to be cost-effective. Blundell Plant Blundell is a geothermal power plant. The systems and processes used in this plant were unique enough to require a more thorough look to make sure potential savings weren't missed. Systems investigated during the Blundell site visit include the following: Aux Cooling Water Blowdown Pumps Brine Transfer Condensate Pumps Compressed Air Circulating Water Pumps Unit2 Feed Pumps Lighting Controls P o te nti a I ly C o s t - Effe ct iv e Pr oj e ct s Liehtine Controls: There is an opportunity to save energy with lighting controls. Ensuring buildings and other general spaces have occupancy sensors and photo-cells in working order would likely be a cost-effective measure. Systems Requiring Further Research Comnressed Air: The dew point controls at many of our plants are set very aggressively. Making changes to the dew point controls to eliminate wasted energy is a very inexpensive way to conserve energy. The drying system at Blundell did not get reviewed, however, so this is one system that still needs to be reviewed. 100 PACTFICORP - 20 13 IRP UPDATE APPENDIX C _ ENERGY ANALYSIS REPORT PecrrCoRp - 201 3 IRP Uppars APPENDIX C_ENERGY ANALYSIS REPoRT Unlikely to be Cost-Effective The remaining projects studied are unlikely to be cost-effective. The systems listed largely produce wasted energy related to recirculation. Projects in general with this type of wasted energy have not been found to have a positive pay-out. Gadsby Plant The Gadsby Plant consists of three gas steam units converted from coal and three gas "peaker" combustion turbine units. The three steam units are part of the old plant and would provide the most potential for energy savings projects. However, the steam units are intermittently run. They have a large amount of downtime. This makes the cost-effective test much harder to meet. The only potentially cost-effective project identified at this point would be lighting controls. This project will be investigated fuither. l0l PACFICoRP _ 2OI3 IRP UPDATE APPENDIX D - ACCELERATED DSM DECREMENTANALYSIS ApppNDIx D - ACCPTERATEN CIASS 2 DSM DpcnEMENT Sruoy This section presents the methodology and results of the energy efficiency, Accelerated Class 2 demand-side management (DSM) decrement study. The same methodology is used for this study as that presented in Volume II, Appendix N of the 2013 IRP, with one exception. For this analysis the amount of Class 2 DSM is re-optimized incorporating accelerated ramp rates that were inputs to Cases C-14, C-15 and C-18 in the 2013 IRP. This portfolio is used as the base portfolio to calculate the decrement value ("avoided cost") of various types of Class 2 DSM resources. To align with the resource costs applied for resource portfolio development using the System Optimizer (SO) capacity expansion model, cost credits are applied to the Accelerated Class 2 DSM decrement values reflecting (l) a transmission and distribution (T&D) investment defenal benefit, (2) a generation capacity investment deferral benefit, and (3) a stochastic risk reduction benefit associated with clean, no-fuel .esou.ces.n The modeling approach is the same as explained in Appendix N of the 2013 IRP report. For this sensitivity, the generation capacity investment deferral benefit is recalculated using the portfolio created with accelerated DSM assumptions. The avoided cost values are calculated for the same l7 Class 2 DSM measure shapes, each at 100 megawatts (MW) maximum capacity and available starting in 2013 and for the duration of the 20-year IRP study period. The production cost differences with and without each of the Class 2 DSM resources are derived using the Planning and Risk (PaR) model, which are then added to the capacity value calculated by the SO model and added to the cost credits as outlined above. The PaR decrement values are determined for one CO2 tax scenario: medium (starting at $16/ton in2022 and escalating to $26lton by 2032). Generation Resource Capacity Deferral Benefit Methodology PacifiCorp used the SO model to determine the generation resource capacity deferral benefit. A single capacity benefit is calculated for an aggregate Class 2 DSM resource. This is accomplished by running SO with a resource portfolio that excludes 100 MW of zero cost Class 2 DSM resource (Change Case), and then comparing the fixed portfolio costs against the cost of the portfolio derived by the SO model that includes the Class 2 DSM program at zero cost (Base Case). The simulation period is 20 years. As a simpliffing assumption, PacifiCorp applies the East "system" aggregate Class 2 DSM load shape for the generic DSM resource, because the next deferrable resource is located in the east side of PacifiCorp's system. The aggregate Class 2 DSM load shape has a capacity planning contribution of 94 percent and a capacity factor of 70 percent. The resource deferral fixed cost benefit is comprised of the deferred capital recovery ' Refer to Volume I, page 147 of the 2013 IRP for a summary of the T&D investment defenal and stochastic risk reduction cost credits applied to the SO energy efficiency resource options. 103 PACIFICoRP _2013 IRP Upnerg APPENDTX D - ACCELERATED DSM DECREMENTANALYSB and fixed operation and maintenance costs of a "next best alternative" resource-a combined- cycle combustion turbine (CCCT). The difference in the portfolio fixed cost represents the resource deferral benefit of the DSM program. Note that the SO model production cost benefits are not taken into account to avoid double-counting the benefit extracted from stochastic PaR model results. Since a 100 MW Class 2 DSM resource is not sufficiently large enough to defer a full-sized CCCT, the SO model is configured to allow fractional CCCT unit sizes for both the Base Case and the Change Case. This allows the Class 2 DSM resource to partially displace the CCCT. Deferral of CCCT capacity may start as early as 2017.t0 Note that Class 2 DSM resources can also defer front office transactions (a market resource representing a range of forward firm market purchase products). The resource capacity deferral benefit is calculated in two steps: l. Fixed Cost Deferral Benefit Determination Fixed cost benefits are obtained by calculating the differences in annual fixed and capital recovery costs (millions of 2012 dollars) between the base portfolio and the portfolio with the Class 2 DSM program removed. The stream of annual benefits is then converted into a net present value (NPV) using the 2013 IRP discount rate (6.882 percent). 2. Levelized Value Calculation The fixed cost resource deferral benefit value obtained from step I is divided by the Class 2 DSM program energy in megawatt-hours (also calculated as a present value) to yield a value in nominal levelized dollars per megawatt-hour ($AvIWh). This value, along with the T&D investment deferral credit and stochastic risk reduction credit, are added to the PaR model decrement values to yield the final adjusted values. Table D.l reports the nominal levelized avoided costs by DSM resource for 2013 through2032, along with a breakdown of the three cost credits (capacity deferral, T&D investment deferral, and stochastic risk reduction) for the Accelerated Class 2 DSM decrement study. Table D.2 reports the differences between Table D.l and Table N.l from Appendix N of the 2013 IRP, Volume II (Non-Accelerated DSM deuement study). 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The lower avoided cost values are attributed to a lower capacity resource deferral credit ($18.4944Wh for Non-Accelerated DSM, $13.33lIvIWh for Accelerated DSM). The capacity resource deferral value is determined based on the fixed cost, size and timing of the resources that are deferred in the Change Case due to removal of the 100 MW of Class 2 DSM at zero cost. In the Change Case for the Non-Accelerated Class 2 DSM analysis, the fractional CCCT is selected in2020 and2023, while in the Change Case of the current Accelerated Class 2 DSM decrement study, the first CCCT is selected in 2024 because more DSM resources are available due to accelerated ramp rates. As a result the timing of the CCCTs that could be defened by the 100 MW of zero cost Class 2 DSM is different in the two decrement studies. Table D.5 shows the differences in expansion resource portfolios between the Change Case and the Base Case of the Non-Accelerated DSM decrement study presented in Appendix N of the 2013 IRP. Table D.5 - Portfolio Difference - Appendix N (Non-Accelerated DSIVI) For the Change Case in the Non-Accelerated DSM decrement study, prior to 2020 the only resources defened are FOTs, which have no fixed costs, and provide no capacity deferral benefits. Capacity benefits materialize beginning 2020, with the partial displacement of a fractional CCCT resource. The incremental DSM from the Accelerated DSM case results in CCCTs being eliminated, reduced and delayed (starting with fractional CCCTs) beginning in 2020, as compared to the Non Accelerated DSM case, which results in reduced capacrty benefits. Table D.6 shows the differences in expansion resource portfolios between the Change Case and the Base Case for the Accelerated DSM study. For this Change Case, the deferral resources in the front years continue to be FOTs, but the partial displacement of CCCTs starts later, in 2024. ]CCTJ 96 8 395 (190 147 u5 ,OTMm03 23 93 94 l5 16 14 8 (263 (159 (38 I ,oTcoB 03 63 93 69 (51 ,OT tvlidColmbh 03 l3 tOT Mitcotunbh 03 - 2 225 94 3I 109 PACTICoRP - 201 3 IRP Upnare ApprNox D - Accsr-eRATEo DSM DEcREMENT ANALysrs Table D.6 - Portfolio Difference - Non-Accelerated DSM Overall, the delay in timing of the defened CCCT reduces the net present value of savings in fixed costs, which lowers capacrty deferral credits from $l8.49Adwh in Appendix N to $13.334{Wh in the Accelerated DSM study. Consistent with the results for the 2013 IP.P, the residential air conditioning decrements produce the highest value for both the east and west locations. The water heating, plug loads, and system load shapes provide the lowest avoided costs. Much of their end use shapes reduce loads during a greater percentage of off-peak hours than the other shapes and during all seasons, not just the summer. PaCrICoRp _ 2OI3 IRP UPDATE APPENDIX E - IRP Table A.7 Correction AppgNDIx E - IRP TAgrg 4.7 COnnpCTIoN The following table was included as part of PacifiCorp's response to Wyoming Public Service Commission Staff Data Request 2.5 (Docket No. 20000-424-EA-13). This is the corrected version of Table A.7 from the 2013 IRP. Table E.l - Jurisdictional Contribution to Coincident Peak 1997 through 2012 peak's do not include sales for resale or ldaho exchange llt PACIFICoRP _ 20 13 IRP Upparr CONFIDENTIAL APPENDIX F - BREAKEvEN ANAIySIS CoNpIDENTIAL APPENDIX F - BNPATEVEN ANarvsrs On November 25, 2013 the Washington Utilities and Transportation Commission (WUTC) acknowledged PacifiCorp's 2013 IRP. In Docket UE-120416 the WUTC stated the 2013 tRP "meets the requirements of Revised Code of Washington 19.280.030 and Washington Administrative Code 480- I 00-23 8." The WUTC further provided "suggestions and requests for future IRP filings", which included a request to update PacifiCorp's coal analysis as part of the 2013 IRP Update and include various price curves for carbon regulation and price curves for natural gas where it would be more economical to operate a given unit using natural gas as opposed to coal. This Confidential Appendix is included in the 2013 IRP Update to satisfu the WUTC requested update. Carbon Regulation In their memo the WUTC specifically mentioned two carbon related items: (l) The September 20, 2013 EPA proposed regulations on new coal and natural gas-fired generating plants, and (2) the June 25, 2013 Presidential Memorandum directing the Environmental Protection Agency (EPA) to propose regulations on existing coal plants by June 2014. PacifiCorp recognizes there is uncertainty around the potential costs resulting from pending regulation of COz emissions applicable to existing natural gas and coal resources. Additionally, despite issuance of the June 2013 Presidential Memorandum, there is tremendous uncertainty about the regulatory mechanisms that might be used in EPA's pending rule-making process, and consequently there continues to be uncertainty in the cost for future regulations on COz emissions from existing sources. This uncertainty is the reason that PacifiCorp evaluated a range of COz price scenarios in the 2013 IRP and in the financial analyses included within Confidential Volume III. PacifiCorp has reviewed the June 2013 Presidential Memorandum in which President Obama directed the EPA to complete greenhouse gas (GHG) standards for both new and existing power plants. For existing sources, EPA was directed to issue "standards, regulations, or guidelines, as appropriate" that address GHG emissions from modified, reconstructed, and existing power plants.r' The Presidential Memorandum did not explicitly set forth regulations for existing coal plants. The proposed standards, regulations, or guidelines are to be issued by June l, 2014, finalized by June 1,2015, with implementation of regulations as proposed in SIPs required by June 30, 2016. EPA would then review the implementation plan proposed by each state. Accordingly, even if EPA follows the President's aggressive schedule, the effective compliance dates for these standards, regulations, or guidelines are a number of years into the future. I I Presidential Memorandum - Power Sector Carbon Pollution Standards, June 25, 2013 . 113 PACIFICORP -2013 IRP Upnarg CONFIDENTIAL APPENDIX F _ BREAKEVEN ANALYSIS The June 2013 Presidential Memorandum did not detail how EPA will approach CO2 regulation or what the resulting standards, regulations, or guidelines will ultimately entail for existing resources. Absent any information on how EPA intends to proceed with its rule-making process, and without any information on how individual states will propose to implement those regulations through a SIP, there is currently no,means to develop a specific CO2 price assumption that accurately reflect potential CO2 regulation.'' As such the COz assumptions used in the 2013 IRP remain reasonable. The IRP assumptions already represent a wide range of policy mechanisms that might be used to regulate COz emissions in the power sector at some point in the future. The range of assumptions are based upon independent third- party price projections, with a high scenario that is consistent with prominent legislative proposals, and with even higher scenarios developed consistent with stakeholder input during the pre-frling public input process for this IRP. This approach was taken because, as of today, there are a wide range of potential future policy tools that may be employed to regulate COz emissions. Because the June 2013 Presidential Memorandum does not direct a particular type of regulatory approach, it does not make one particular approach more or less likely and therefore does not change the IRP assumptions. Similarly, because there is no detail on which to base an analysis, it does not make a particular CO2 price forecast used in the IRP more or less reasonable. Given the timeline set forth in the Presidential Memorandum, the Company will have multiple opportunities to re-evaluate its CO2 price assumptions incorporating new information with issuance of proposed regulations in June 2014. As assumptions are developed forthe 2015 [RP, the Company will re-evaluate current market conditions and policy developments along with current forecasts from external sources in establishing updates, if any, to its CO2 price assumptions. At this point however there is no reason to believe the assumptions contained in the 2013 IRP are not reasonable. Natural Gas Prices The WUTC also pointed to changes in gas prices, and suggested that "...a more detailed analysis that focuses on the gaps between various projections that the Company used and identifies the price level at which it would become cost effective to switch an existing coal plant to natural gas is required to beffer inform the Company's decision making process".l3 Again, the Company posits that the analysis already provided in Confidential Volume III is sufficient to find breakeven points. Figure F.l below includes a shaded area representing the spread between the high and low gas forecasts used in the 2013 IRP. The two lines on the graph are the September and December 2013 forecasts used in the IRP Update. As shown, the current forecasts are within the range analyzed for the 2013 IRP. As such, analysis contained within the IRP is applicable to find the breakeven points as requested. t2 While some groups have made recommendations to EPA, EPA has provided no indication of how it plans to proceed through its rulemaking process. 13 PacifiCorp IRP Acknowledgment Letter - Attachment, Washington Utilities and Transportation Commission, Docket UE-120416 atpage 3, tt4 PaCrICOnp - 201 3 IRP UPDATE CONFIDENTIAL AppgwoX F - BREAKEVEN AUAI-YSTS Figure F.l - Natural Gas Price Forecast for 2013 IRP Update $a tr 3U 3ra 3l 3a ta 3r I -.-S€p' 13 OFPC - Opd +Dcc'13 OFPC - OPtrl 2011 20ts 20,.6 zut 20rt 2m9 ,ofi 2u2t ML 20a3 2@a 2l02S 20,,6 2@7 2@A 2o,' 2@ Confidential Volume III Analysis As discussed above, PacifiCorp malyzed investnent decisions contained in Confidential Volume III of the 2013 IRP across a wide range of gas and COz price assumptions. There is not any additional information to suggest the range tested for the two variables is applicable today as it was then. Given that, results from PacifiCorp's analysis for Hunter Unit 1, Bridger Units 3 and 4 and Naughton Unit 3 shown in Confidential Volume III can be used to address the requests from the WIITC. That is, the analysis can be used to estimate valid breakeven points as requested. Methodology As discussed in the 2013 IRP, present value revenue requirement differential (PVRR(d)) analyses are used to quantifr the benefit or cost of completing coal unit environmental investnents by legally binding compliance deadlines as compared to the next best alternative. The PVRR(d) for any given environmental investnent is calculated as the difference in system costs between two System Optimizer simulations. In one System Optimizer simulation, the costs for near-term and prospective future environmental invesfrnents required for a unit to continue operating as a coal- fueled facility are included as incremental system costs. In a second System Optimizer simulation, it is assumed that coal-fueled operations cease at the compliance deadline, allowing the model to choose the next best compliance alternative where incremental environmental investnent are avoided. In this second simulation, the System Optimizer model evaluates 115 PACIFICoRP _ 20 13 IRP Upoare CONFIDENTIAL APPENDIX F - BnTaxTwn ANALYSIS converting a unit to operate as a gas-fueled facility and early retirement as potential alternatives to the installation of emissions control equipment.'o The second System Optimizer simulation also considers how cost and performance assumptions are affected when one or more units at a plant convert to natural gas or retire early. The PVRR(d) analyses for the resources in questions (Hunter Unit l, Jim Bridger Units 3 and 4, and Naughton Unit 3) were performed on broad range of different market scenarios pairing varying levels of natural gas prices and COz costs. These scenarios looked at high, base, and low gas prices as well as high, low, and base COz costs. One can interpolate breakeven points for both gas and COz costs using these study results, as shown below. To find the breakeven point for a single factor, the other factors must be held constant. That is, to isolate the effects of COz prices for instance, the natural gas price relationship with PVRR(d) results is shown for the natural gas price scenarios in which the base case COz price assumption is used. Holding CO2 costs fixed at the base case assumption allows for finding an estimate for the breakeven natural gas price. Likewise, the COz breakeven points are found using scenarios with base gas price forecasts. Hunter Unit I The Hunter Unit I baghouse and low NOl burner (LNB) breakeven analysis relies on an PVRR(d) analysis completed to support the appropriations request (APR), which was approved in May 2012, and summarized in Confidential Volume III of the 2013 IRP. Table F.l shows the PVRR(d) results among five different scenarios analyzed in support of the APR which can be used to find the breakeven points for gas and COz prices, as discussed above. Confidential Table F.l - Hunter I APR Emission Control PYRR(d) Analysis Results, 2026 SCR Figure F.2 graphically displays the relationship between the nominal levelized natural gas price at the Opal market hub over the period 2015 through 2030 and the PVRR(d) benefit/cost of the incremental investments required for continued coal operation of Hunter Units I with the additional baghouse and SCR. To isolate the effects of COz prices, the natural gas price relationship with PVRR(d) results is shown for the natural gas price scenarios in which the base case COz price assumption is used. The result is a predicted breakeven value of f per MMBtu before gas conversion would be considered. ra In the case of an early retirement altemative, the System Optimizer model can fill the resource need by selecting from the full suite of supply side resources used in the IRP portfolio development process. Current new resource options are summarized in Volume l, Chapter 6 of the 2013 IRP. ll6 Redacted PACIFICoRP _ 20 I 3 IRP UPDATE CONFIDENTIAL APPENOIX F _ BREAKEVEU ANELYSIS Confidential Figure F.2 - Relationship between Gas Prices and the PYRR(d) (Benefit)/Cost of the Baghouse and LNB Investments at Hunter Unit I The results of a similar analysis for the breakeven value for COz are shown in Figure F.3. Here, it is the relationship between the nominal levelized COz cost over the 2015 to 2030 period and the PVRR(d) of continued coal operation of Hunter Units I with the additional baghouse and LNB that is shown. In this case, to isolate the effects of gas price changes, base case natural gas prices assumptions are maintained. As shown, COz cost would have to be at a levelized rutr. if ! per ton or greater to consider gas conversion for this unit. tt7 Redacted PecmICOnp - 20 13 IRP UPDATE CONFIDENTIAL APPENDIX F _ BREAKEVEN ANALYSIS Confidential Figure F.3 - Relationship between COz Prices and the PYRR(d) @enefit/Cost of the SCR Investments at Hunter Unit I Jim Bridger 3 and 4 Breakeven analysis for Jim Bridger Units 3 and 4 can be completed relying on the analysis provided to support two regulatory filings: (l) Application for a Certificate of Public Convenience and Necessity (CPCN) filed with the Wyoming Public Service Commission on August 7,2012's, and (2) Voluntary Request for Approval of Resource Decision filed with the Public Service Commission of Utah on August 24,201216. The Company used the same analysis to support the Wyoming and Utah filings, and the base case natural gas, power, and COz price assumptions are the same as the medium price assumptions used in the 2013 IRP. Table F.2 shows the PVRR(d) results for five of the nine different scenarios analyzed in support of the Jim Bridger Unit 3 and Unit 4 CPCN analysis (and provided in Confidential Volume III of the 2013 IRP). These five represent the cases for the base gas, or CO2 price scenarios. 15 See Wyoming Docket No. 20000-418-EA-12. The Wyoming Public Service Commission approved the Company's CPCN application in a public deliberation on April 10, 2013. 16 See Utah Docket No. 12-035-92. ll8 PACTICORP -2013 IRP UPDATE CONFIDENTIAL APPENDD( F _ BREAKEVEN ANALYSIS Confidential Table F.2 - Bridger 3 and 4 CPCN Emission Control PyRR(d) Analysis Results These points can be used to perform analysis similar to that shown above for Hunter Unit l. Figure F.4 shows the relationship benveen gas prices and the PVRR(d) of benefit/cost of the incremental investments required for continued coal operation of Jim Bridger Units 3 and 4. Again, to isolate the impact of changes in gas prices, thglq value was held constant at the base level. As shown in the figure, a breakeven price of I per MMBtu would be needed to consider gas conversion. Confidential Figure F.4 - Relationship between Gas Prices and the PyRR(d) @enefit/Cost of the SCR Investments at Jim Bridger Units 3 & 4 Figure F.5 below shows the relationship between COz prices and the PVRR(d) of benefit/cost of the incremental investments required for continued coal operation of Jim Bridger Units 3 and 4. Here the gas prices were held constant at the base level assumed. As shown, the breakeven levelized Co2 p.ice is I/ton. Redacted 119 PncrrConp - 2013 IRP Upoare CONFIDENTIAL APPENDX F _ BREAKEVEN ANALYSIS Confidential Figure F.5 - Relationship between COz Prices and the PVRR(d) @enefit)/Cost of the SCR Investments at Jim Bridger Units 3 & 4 Redacted Naughton Unit 3 PacifiCorp completed an Emission Control PVRR(d) analysis in its evaluation of SCR and baghouse investments required by December 31, 2014 to meet Regional Haze regulations at Naughton Unit 3. The analysis was completed in support of the Company's Application for a Certificate of Public Convenience and Necessity (CPCN) filed with the Wyoming Public Service Commission on September 16, 2OlIr7. Information from this filing is used for the breakeven analysis requested. Table F.3 shows the PVRR(d) results for five different scenarios analyzed in support of the Naughton Unit 3 CPCN analysis. These are the scenarios relying on base assumptions for gas, or COz prices. Confidential Table F.3 - Naughton 3 CPCN Emission Control PyRR(d) Analysis Results r7 Wyoming Docket No. 20000-400-EA-l I t20 Redacted PacrICOnp _ 20 I 3 IRP UPDATE CONFIDENTIAL AppsNorx F - BnraxrveN ANlr.ysrs Figure F.6 below shows a very strong linear relationship between the nominal levelized price of Opal natural gas prices and the PVRR(d) benefit/cost of the incremental environmental investments required at Naughton Unit 3. Based upon this trend, levelized natural gas prices would need to increase from $6.00 per mmBtu as was in the base case forward price curve to I per mmBtu to achieve a breakeven PVRR(d). Confidential Figure F.6 - Relationship between Gas Prices and the PVRR(d) (Benefit)/Cost of the SCR and Baghouse Investments at Naughton Unit 3 Higher CO2 price assumptions improve the PVRR(d) in favor of the gas conversion alternative, and lower CO2 prices erode the benefits of the gas conversion alternative; however, PVRR(d) results remain favorable to the gas conversion alternative when CO2 prices are zero and paired with the base case natural gas price assumptions, as shown in Figure F.7. As with the trend described in the relationship between natural gas prices and the PVRR(d) results, the relationship between CO2 prices and the PVRR(d) benefit/cost of the incremental environmental investments at Naughton Unit 3 is intuitive. Because the COz content of coal is nearly double the COz content of natural gas, higher CO2 prices lowers the cost of emissions for the gas conversion alternative and lowers the fuel cost ofother natural gas-fueled system resources used to offset any generation lost from the coal-fueled Naughton Unit 3 asset. t2l PACIFICoRP _ 20 I 3 IRP UPDATE CONFIDENTIAL APPENDIX F _ BREAKEVEN A.,{, Confidential Figure F.7 - Relationship between COz Prices and the PyRR(d) (Benefit)/Cosr of the SCR and Baghouse Investments at Naughton Unit 3 Redacted 122