20151013Application.pdf

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October 12,2015
VIA OVERNIGHT DELIVERY
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702
Re: CASE NO. PAC-E-15-12
IN THE MATTER OF THE APPLICATION OF ROCKY MOI]NTAIN
POWER FOR APPROVAL OF CAPACITY DEFICIENCY PERIOD TO BE
USED FOR AVOIDED COST CALCULATIONS
Dear Ms. Jewell:
Please find enclosed for filing an original and seven (7) copies of Rocky Mountain Power's
Application in the above-referenced matter. Workpapers are included on the enclosed CD.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
Jtil/\*1 14 Lrur.*/q
Jeffrey K. Larsen
Vice President, Regulation
Yvonne R. Hogle (ISB# 8930)
1407 West North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone No. [phone]
Facsimile No. [phone]
vvonne.ho gle@pacfi corp.com
Attorneyfor Roclqt Mountoin Power
IN THE MATTER OF THE
APPLICATION OF ROCKY MOUNTAIN
POWER FOR APPROVAL OF CAPACITY
DEFICIENCY PERIOD TO BE USED FOR
AYOIDED COST CALCULATIONS
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. PAC-E-15-12
APPLICATION OF ROCKY
MOUNTAIN POWER
Comes now, Rocky Mountain Power ("Company") and in accordance with Order Nos.
32697 and 32802 in Case No. GNR-E-l l-03, respectfully submits this Application for approval
by the Idaho Public Utilities Commission (the "Commission") of the capacity deficiency period
determination to be utilized in avoided cost calculations using the Surrogate Avoided Resource
("SAR") methodology. As more fully described below, this update identifies Rocky Mountain
Power's capacity deficiency period of summer 2024 and explains how the deficiency period was
identified.
In support of its Application, Rocky Mountain Power states as follows:
l. Rocky Mountain Power is authorized to do and is doing business in the state of
Idaho. The Company provides retail electric service to approximately 75,400 customers in the
state and is subject to the jurisdiction of the Commission. Rocky Mountain Power is a public
utility in the state of Idaho pursuant to Idaho Code $ 6l-129.
COMMUNICATIONS AIID SERVICE OF PLEADINGS
2. Communications regarding this Application should be addressed to:
Ted Weston
Yvonne R. Hogle
1407 West North Temple, Suite 330
Salt Lake Ciry, Urah 841l6
Te lephone : (80 l) 220 -29 63
Email : ted.weston@nacifi corp.com
wonne.ho gle@pacifi corp.com
Brian Dickman
825 NE Multnomah, Suite 600
Portland, Oregon 97232
Telephone: (503) 8l 3-6484
Email: [e-mail]
In addition, the Company respectfully requests that all data requests regarding this matter
be addressed to one or more of the following:
By e-mail (preferred): [e-mail]
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
BACKGROUNI)
3. In Order No. 32697 the Commission directed that a case be initiated outside of
each utility's Integrated Resource Plan ("IRP") filing to establish the capacity deficiency period
to be used in the utility's SAR methodology:
"We find it reasonable and fair to subject each utility's determination of capacity
deficiency to further scrutiny. Therefore, when a utility submits its Integrated Resource
Plan to the Commission, a case shall be initiated to determine the capacity deficiency to
be utilized in the SAR Methodology. The capacity deficiency determined through the IRP
planning process will be the starting point, and will be presumed to be correct subject to
the outcome of the proceeding."l
rOrderNo. 32697,p.23.
4. [n Order No. 32697, the Commission acknowledged that "some determinations
made within the IRP process have an impact on calculations under the SAR and IRP
methodologies. Specifically, the IRP process determines when the utility will experience a need
for new capacity."2 The Commission ordered that payments to qualiffing facilities ("QFs")
should recognize the utility's capacity needs, stating:
"ln calculating a QF's ability to contribute to a utility's need for capacity, we find it
reasonable for the utilities to only begin payments for capacity at such time that the utility
becomes capacity deficient. If a utility is capacity surplus, then capacity is not being
avoided by the purchase of QF power. By including a capacity payment only when the
utility becomes capacity deficient, the utilities are paying rates that are a more accurate
reflection of true avoided cost for the QF power."'
REOUEST TO ESTABLISH SAR DEFICIENCY PERIOD
5. On March 31, 2015, Rocky Mountain Power filed its 2015 IRP with the
Commission. The 2015 IRP includes the results of the Company's capacity balance in Table 5.14
on page 81. The capacity balance is calculated for summerpeak loads only, with the summer
peak occurring annually in July. The capacity balance is developed by determining firm
resource capacity available at the annual system peak load hour, including the Company's firm
access to imports from the wholesale market (or "Front Office Transactions"), less the system
obligation and a 13 percent planning reserve margin. The 2015 IRP shows that the Company
first becomes capacity deficient in2020. Available system capacity is increased in the summer
of 2021 with the expiration of a legacy exchange contract, and the system falls short again in
2023. A summary of the system capacity loads and resources are provided in Table I below.
2 OrderNo. 32697,p.23.
' Order No. 32697, p.21.
Table I
2015 IRP - System Capacity Loads and Resources without Resource Additions
Calendar Yer 2015 2015 2011 2018 2019 2020 2021 2022 2023 2024 2025
Totrl RelNrce! 10,56E 1q043 1q143 10,217 10,144 10,124 10,486 10,446 10,458 10,425 lq3l0
OHigation 10,104 9,930 1q089 10,225 1q333 10,452 1q569 10,6'14 10,788 10,832 1q897
Rereres 1,333 1,310 1,331 1,349 1,363 1,378 1,393 l,&7 \4n 1,424 \46
OHigrtion+Rqcret 11,437 ll,2& ll,420 11,573 11,696 11,830 I1,3 lXo8t l\210 12,259 l\333
System Poitior (869) (l,l9o Q,2'7't) (1,357) (l,ss2) (1,706) (1,477t (1,635) (1,752) (1,834) (2,023\
AuilaHe Front Office Tranractions 1,6'10 1,6'10 1,6'10 1,670 1,6'10 1,670 1,670 1,670 1,670 1.670 1,670
SARRerourceSulficiency/(Dcliciency) 801 472 393 313 ll7 (36) 192 34 (82) 065) (354)
6. After accounting for: a) additional power purchase agreements ("PPAs") with
QFs signed since preparation of the 2015 IRP, b) termination of QF PPAs originally included in
the 2015 IRP, and c) changes to the Company's load forecast, the updated capacity deficit first
occurs in the summer of 2025. Details are provided in Table 2 below. Accordingly, the
Company requests the Commission approve a capacity deficiency period for use in the SAR of
summer 2025.
Table 2
Updated System Capacity Loads and Resources
Calendu Yeu 2015 2016 2017 201E 20t9 2020 202t
[hdrtedlddFordstlEFct (25) (51) (56) (16) 26 15 20 t4
fhdrt€dOHigrtion+R$ere3 ll,4l2 ll,l89 11,364 11,557 ll,12.
SignedPPAs Dotinclr&diDlRP 0 0 213 216 214
TerminatedPPAr inclu&dir IRP (l) (12) (12). (\A (12)
n,E45 11,983
2t3 2t2(L2\ 02'l
tzuo 12,263 r234o
2@ 208 206
fi2\ 02) (r21
t2,@4
2t0
(12'l
UpdatcdR€lource! 12,237 11,700 lZ0l3 12,089 12,015 11,994 l\3Y la3l3 12,324 12,2m 0,173
IhdstcdSARRsqrce Sulficicncy/ (Deficiency) E2S 5ll 649 S!2 294
7. Table 2 shows the first capacity deficiency of 167 MW occurring in the summer
of 2025. Compared to the loads and resources included in the 2015 IRP, changes in the updated
load forecast are offset by additional resources from QF PPAs. The updated system capacity
loads and resources in Table 2 includes the capacity contribution from23 additional QF contracts
(six located in Utah and 17 in Oregon), with atotal nameplate capacity of 564 MW. In2024
these additional PPAs contribute 206 MW to system capacity. Two QF PPAs that were included
(r67)219
in the 2015 IRP have since been terminated, eliminating 82 MW of nameplate capacity and
approximately 12 MW of system capacity contribution.
8. Rocky Mountain Power submits that this Application to establish the capacity
deficiency period meets the requirements set forth in Commission Order Nos. 32697 and 32802,
and requests that the Commission approve the capacity deficiency period to be utilized in its
SAR calculations.
MODIFIED PROCEDURE
9. Rocky Mountain Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed under
Modified Procedure; i.e., by written submissions rather than by hearing. RP 201 et seq. If,
however, the Commission determines that a technical hearing is required, the Company stands
ready to prepare and present its testimony in such hearing.
CONCLUSION
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission issue
an order:
l) authorizing this Application be processed pursuant to Modified Procedure; and
2) establishing the capacity deficiency period beginning in the summer of 2025, to be
utilized in the Company's avoided cost determinations under the SAR methodology, as shown in
Table 2 above.
DATEDthis 126 day of Octobcr,2015.
Respectfu lly submitted,
ROCKY MOTJNTAIN POWER
ed&
vonne R. Hogle
407 WestNorth Temple, Suite 320
salt Lake city, utah 841l6
Telephone No. [phone]
wonne.hosle@.oacifi com. oom
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