20150512notice_of_filing_order_no_33299.pdf

Office of the Secretary
Service Date
May 12,2015
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA
ROCKY MOUNTAIN POWER’S 2015 )CASE NO.PAC-E-15-04
INTEGRATED RESOURCE PLAN )
)NOTICE OF FILING
)
)NOTICE OF
)MODIFIED PROCEDURE
)
)NOTICE OF
)INTERVENTION DEADLINE
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_____________________________
)ORDER NO.33299
On March 31,2015,PacifiCorp dba Rocky Mountain Power (“Rocky Mountain”or
“Company”)filed its 2015 Integrated Resource Plan (‘IRP”)with the Commission pursuant to
the Commission’s rules and in compliance with the biennial IRP filing requirements mandated in
Order No.22299.
NOTICE OF IRP FILING
YOU ARE HEREBY NOTIFIED that Rocky Mountain’s 2015 IRP represents its 13th
comprehensive plan submitted to state regulatory commissions.
YOU ARE FURTHER NOTIFIED that the Company states that its IRP Application
was developed with participation from numerous public stakeholders,including regulatory staff,
advocacy groups,and other interested parties,and focuses on a 10-year period,2015-2024
(hereinafter “planning horizon”).
YOU ARE FURTHER NOTIFIED that Rocky Mountain’s projected load forecast
continues to decline beyond 2019 in relation to projected loads used in the Company’s 2013 IRP
and 2013 IRP Update.
YOU ARE FURTHER NOTIFIED that the Company cites reduced residential class
load forecast due to increased energy efficiency,including continued phase-in of the Energy
Independence and Security Act federal lighting standards,and lower energy response to
economic growth as the main drivers of lower forecasted load.
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YOU ARE FURTHER NOTIFIED that Rocky Mountain claims that Class 2 DSM,or
energy efficiency,savings in the 2015 IRP preferred portfolio exceeds energy efficiency savings
from the 2013 IRP preferred portfolio by 59%by 2024.The Company says that acquisition of
incremental energy efficiency resources increases by 59%over its estimate in its 2013 IRP and
meets 86%of the Company’s forecast load growth from 2015 through 2024.
YOU ARE FURTHER NOTIFIED that Rocky Mountain’s base case wholesale
power and natural gas price estimates are significantly lower than the estimates found in its
previous (2013)IRP.The Company asserts that the estimates found in its 2013 IRP Update are
more closely aligned to its 2015 IRP estimates.
YOU ARE FURTHER NOTIFIED that Rocky Mountain remarks that growth in
natural gas supplies,primarily from prolific shale plays in North America,have continued to
outpace expectations and exert downward pressure on natural gas prices.
YOU ARE FURTHER NOTIFIED that Rocky Mountain believes that while the
market for front office transactions (FOTs)is favorable,growth in energy efficiency savings
mitigate the need for FOTs through the front ten years of the planning horizon.The Company
says that,on average,2015 IRP preferred portfolio FOTs are down 16%from the 2013 IRP
Update and down 29%when compared to the 2013 IRP preferred portfolio.
YOU ARE FURTHER NOTIFIED that Rocky Mountain’s 2015 IRP preferred
portfolio includes the addition of 816 MW of energy from power purchase agreements for 36
qualifying wind and solar projects coming on-line by the end of 2016.The Company says that
these projects are necessary in order to mitigate the cost of state renewable portfolio standard
(RPS)compliance in its California,Oregon,and Washington service areas.Rocky Mountain
believes that its preferred portfolio meets the Utah 2025 state target of 20%,and has a significant
bank to sustain continued future compliance in Utah.
YOU ARE FURTHER NOTIFIED that Rocky Mountain’s analysis of near-term
Regional Haze compliance requirements led the Company to convert some of its coal plants to
natural gas by 2018 and install emissions control equipment at its Wyodak,Dave Johnston Unit
3,and Cholla Unit 4.Rocky Mountain believes that this will potentially save its (PacifiCorp)
customers hundreds of millions of dollars.
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YOU ARE FURTHER NOTIFIED that Rocky Mountain noted the impact of the U.S.
Environmental Protection Agency’s (EPA)issuing Rule §111(d)of the Clean Air Act
establishing state emission rate targets for existing resources.According to the Company,its
2015 IRP preferred portfolio meets PacifiCorp’s share of state emission rate targets among those
states in which PacifiCorp serves retail customers and owns existing fossil generation potentially
affected by the proposed rule.
YOU ARE FURTHER NOTIFIED that Rocky Mountain continues to support
transmission permitting efforts for Energy Gateway West (Segments D and E),Energy Gateway
South (Segment F),Boardman to Hemingway (Segment H),and a line from Walla Walla to
McNary.The Company expects to complete construction of the Walla Walla to McNary project
by 2017.
YOU ARE FURTHER NOTIFIED that Rocky Mountain described several
“supplemental studies”the Company relied upon in order to develop its 2015 IRP.
YOU ARE FURTHER NOTIFIED that,regarding potential future resource
acquisition,Rocky Mountain claims that it will exceed its 13%target planning reserve margin
through 2019 and falls just short of its target planning reserve margin in 2020.The Company
believes that the expiration of an existing exchange contract will increase system capacity and
allow the Company to exceed its 13%target planning reserve margin in 2021 and 2022.Rocky
Mountain estimates that it will be at least 82 MW and 165 MW below its target planning reserve
margin in 2023 and 2024,respectively.
YOU ARE FURTHER NOTIFIED that Rocky Mountain expressed a commitment
toward assessing current market conditions and dispatch or sell its system resources in an
economic manner to the benefit of customers.The Company believes that the economic dispatch
of system resources is critical to how the Company manages net power costs.
YOU ARE FURTHER NOTIFIED that the Company estimates that its first on-peak
energy shortfall will occur in July 2020,totaling 5 GWh.In July 2024,the Company states that
the on-peak monthly load deficit will increase to 189 GWh.Rocky Mountain does not forecast
an energy shortfall during off-peak periods through the 2024 planning horizon.
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YOU ARE FURTHER NOTIFIED that Rocky Mountain’s 2015 IRP Action Plan
reveals the Company’s planned actions during the ten-year planning horizon (20 15-2024):
1.Renewable Resource Actions
-Pursue unbundled REC request for proposals (RFP)to meet its state
RPS compliance requirements.
-Issue annual RFPs seeking current-year or forward-year vintage
unbundled RECs to meet Washington and California renewable
portfolio standard targets through 2017.
-Defer issuance of RFPs seeking unbundled RECs that will qualify in
meeting Oregon renewable portfolio standard targets until states begin
to develop implementation plans under EPA’s draft 111(d)rule.The
Company asserts that it has a projected bank balance extending out
through 2027.
-Issue quarterly reverse RFPs through 2016 to sell 2016 vintage or older
RECs that are not required to meet state RPS compliance obligations.
-Secure bids from 2013 Request for Proposals (RFP)seeking up to 7
MW of capacity from qualifying solar systems to meet Oregon’s 2020
solar capacity standard.
2.Firm Market Purchase Actions
-Acquire short-term on-peak firm market purchase deliveries from 2015
through 2017.
-Balance month and day-ahead competitive price brokered transactions.
-Balance month,day-ahead,and hour-ahead transactions executed
through an exchange,such as Intercontinental Exchange (ICE).
-Prompt month forward,balance of month,day-ahead,and hour-ahead
non-brokered transactions.
3.DSM Actions
-Class 1 DSM:Pursue a west-side irrigation load control pilot beginning
2016.Class 2 DSM:Acquire the following cost-effective Class 2 DSM
resources targeting annual system energy and capacity selections from
the preferred portfolio:2015 —551 MW of Annual Incremental Energy
(GWh)and 133 MW of Annual Incremental Capacity;2016—584 MW
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of Annual Incremental Energy and 139 MW of Annual Incremental
Capacity;2017—616 MW of Annual Incremental Energy and 146 MW
of Annual Incremental Capacity;2018 —634 MW of Annual
Incremental Energy and 146 MW of Annual Incremental Capacity.
4.Coal Resource Actions
-Naughton Unit 3:Issue RFP to procure gas transportation and resume
engineering,procurement,and construction (EPC)contract
procurement activities for the Naughton Unit 3 natural gas conversion
in the first quarter of 2016.Possibly update its economic analysis of
natural gas conversion in conjunction with the RFP processes to align
gas transportation and EPC cost assumptions with market bids.
-Dave Johnston Unit 3:Wyoming currently appealing 10 Circuit ruling
the portion of EPA’s final Regional Haze Federal Implementation Plan
(FIP)requiring the installation of selective catalytic reduction (SCR)at
Dave Johnston Unit 3,or a commitment to shut down Dave Johnston
Unit 3 by the end of 2027.If EPA’s final FIP is upheld,the Company is
committed to shutting down Dave Johnston Unit 3 by the end of 2027.
If EPA’s final FTP is or will be modified,the Company will evaluate
alternative compliance strategies.
-Wyodak:Continue appeal of the portion of EPA’s final Regional Haze
FIP that requires the installation of SCR at Wyodak.Compliance
deadline for SCR under the FIP is currently stayed by the court.If
EPA’s final FTP is upheld (with a modified schedule that reflects the
final stay duration),the Company will update its evaluation of
alternative compliance strategies that will meet Regional Haze
compliance obligations.
-Cholla Unit 4:Continue permitting efforts in support of an alternative
Regional Haze compliance approach that avoids installation of SCR
with a commitment to cease operating Cholla Unit 4 as a coal-fueled
resource by April 2025.
5.Transmission Actions
-Continue permitting for the Energy Gateway transmission plan.Near-
term targets for Segments D,E,and F include the continued funding of
the required federal agency permitting environmental consultant;
continue to support the federal permitting process by providing
information and participating in public outreach.For Segment H
(Boardman to Hemingway),continue to support the project under the
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conditions of the Boardman to Hemingway Transmission Project Joint
Permit Funding Agreement.
-Complete to follow Walla Walla to McNary project construction plan
with 2017 expected in-service date.Continue to support permitting
process.
NOTICE OF MODIFIED PROCEDURE
YOU ARE FURTHER NOTIFIED that the Commission has reviewed the Company’s
filing in Case No.PAC-E-15-04 and finds that the public interest may not require a formal
hearing in this matter and will proceed under Modified Procedure pursuant to Rules 201 through
204 of the Idaho Public Utilities Commission’s Rules of Procedure,IDAPA 31.01.01.201
through .204.The Commission notes that Modified Procedure and written comments have
proven to be an effective means for obtaining public input and participation.
YOU ARE FURTHER NOTIFIED that any person desiring to state a position
concerning Rocky Mountain’s 2015 IRP may file a written comment in support or opposition
with the Commission.The comment must contain a statement of reasons supporting the
comment.Persons desiring a hearing must specifically request a hearing in their written
comments.Written comments concerning Rocky Mountain’s TRP Filing shall be filed with the
Commission no later than August 7,2015.Written comments concerning this filing should be
mailed to the Commission and Rocky Mountain at the addresses reflected below:
Commission Secretary Yvonne Hogle
Idaho Public Utilities Commission Regulatory Counsel
P0 Box 83720 Rocky Mountain Power
Boise,ID 83720-0074 201 S.Main,One Utah Center,23 Floor
Salt Lake City,UT 84111
Street Address for Express Mail:
Ted Weston
472 W.Washington Street Idaho Regulatory Affairs Manager
Boise,ID 83702-59 18 Rocky Mountain Power
201 S.Main,One Utah Center,23rd Floor
Salt Lake City,UT 84111
These comments should contain the case caption and case number shown on the first page of this
document.Persons desiring to submit comments via e-mail may do so by accessing the
Commission’s home page located at y iuiidahoo.Click the “Case Comment or Question
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Form’under the “Consumers”tab.and complete the comment form using the case number as it
appears on the front of this document.
YOU ARE FURTHER NOTIFIED that the Company may file reply comments,if
necessary,no later than August 14,2015.
YOU ARE FURTHER NOTIFIED that if no written comments or protests are
received within the time limit set,the Commission will consider this matter on its merits and
enter its Order without a formal hearing.If written comments are received within the time limit
set,the Commission will consider them and,in its discretion,may set the same for formal
hearing.
YOU ARE FURTHER NOTIFIED that Rocky Mountain’s 2015 IRP filing has been
filed with the Commission and is available for public inspection during regular business hours at
the Commission offices and Rocky Mountain Power Headquarters,201 S.Main,One Utah
Center,Salt Lake City,UT 84111.The Application is also available on the Commission’s web
site at ww u1Jiov.Click on the “File Room”tab at the top of the page,scroll down to
“Electric Cases,”and then click on the case number as shown on the front of this document.
YOU ARE FURTHER NOTIFIED that the Idaho Public Utilities Commission has
jurisdiction over Rocky Mountain,its filing and the issues pertaining to this case pursuant to
Title 61 of the Idaho Code and specifically Idaho Code §61-401.
YOU ARE FURTHER NOTIFIED that all proceedings in this matter will be
conducted pursuant to the Commission’s Rules of Procedure,IDAPA 31.01.01.000 et seq.
NOTICE OF INTERVENTION DEADLINE
YOU ARE FURTHER NOTIFIED that persons desiring to intervene in Case No.
PAC-E-15-04 for the purpose of becoming a party must file a Petition to Intervene with the
Commission pursuant to Rules 72 and 73 of the Commission’s Rules of Procedure,IDAPA
3 1.01.01.072 and .073.Persons desiring to acquire intervenor rights of participation must file a
Petition to Intervene no later than 14 days from the service date of this Order.
ORDER
IT IS HEREBY ORDERED that this Application be processed under Modified
Procedure,Rules 201-204,IDAPA 31.01.01 .201 -.204.Persons interested in submitting written
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comments must do so no later than August 7,2015.The Company may file a reply no later than
August 14,2015.
IT IS FURTHER ORDERED that persons desiring to intervene in this case shall file a
Petition to Intervene with the Commission no later than 14 days from the service date of this
Order.
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this
IONER
-
KR INE RAPER,COMMISSIONER
day of May 2015.
ATTEST:
JI /1Ad
Jan D.Jewell 0ommissionSecretary
O:PAC-E-15-04_np
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MACK A.REDFORD,
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