20170818Application.pdf

ROCKY MOUNTAIN
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1407 W. North Temple, Suite 310
Salt Lake City, Utah 84116
August 18,2017
OVERNIGHT DELIVERY
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise,lD 83702
RE: CASE NO. PAC-E-17-09
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
FOR APPROVAL OF CAPACITY DEFICIENCY PERIOD TO BE USED FOR
AVOIDED COST CALCULATIONS
Attention: Diane Hanian
Commission Secretary
Please find enclosed for filing an original and seven copies of Rocky Mountain Power's
Application in the above-referenced matter along with a disc containing Confidential work papers.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at [phone].
Very truly yours,
Jeffrey K. Larsen
Vice President, Regulation
Enclosure
'lil-l)
Yvonne R. Hogle (ISB# 8930)
1407 West North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone No. [phone]
Facsimile No. [phone]
vvonne.hosle@nacfi corp.com
Attorneyfor Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF ROCKY MOUNTAIN
POWER FOR APPROVAL OF CAPACITY
DEFICIENCY PERIOD TO BE USED FOR
AVOIDED COST CALCULATIONS
CASE NO. PAC.E-17.09
APPLICATION
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
from the Idaho Public Utilities Commission (the "Commission") of the capacity deficiency period
determination to be used 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 2028 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 75,000 customers in the state
and is subject to the jurisdiction of the Commission. Rocky Mountain Power is a public utility in
the state ofldaho pursuantto 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 City, Utah 841l6
Telephone: [phone]
Email: [e-mail]
yvonne.ho gle@oacifi corp.com
Ron Scheirer
825 NE Multnomah, Suite 600
Portland, Oregon 97232
Telephone: (503) 8 I 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)datarequest@pac i fi corp.com
Data Request Response CenterBy regular mail
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
BACKGROUNI)
3. Commission Order No. 32697 directed the utilities to initiate a case outside of their
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
4. In Order No. 32697, the Commission acknowledged that 'osome 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
2
I Order No. 32697, p.23
for new capacity."2 The Commission ordered that payments to qualifying facilities ("QFs") should
recognize the utility's capacity needs, stating:
In 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.3
REOUEST TO ESTABLISH SAR DEFICIENCY PERIOD
5. On April 4,2017, Rocky Mountain Power filed its 2017 IRP with the Commission.
The 2017 IRP includes the results of the Company's capacity balance in Table 5.14 on page 91.
The capacity balance is calculated for summer peak 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
l3 percent planning reserye margin. The 2017 IRP shows that the Company first becomes capacity
deficient in2028. A summary of the system capacity loads and resources are provided in Table l.
2 OrderNo. 32697,p.23
3 OrderNo. 32697,p.21
J
Table 1
2017IRP - System Capacity Loads and Resources without Resource Additions
Calendar Year 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028
Svstcnr (\l\\ )
Total Resources
OHigation
Reserrrcs
OHigation + Reserrts
System Position
Transactions
10,493
9,730
L29o
n,a0
(s27)
1,670
t0,494
9,743
t,2E2
I 1,035
(s4r)
t,670
10,109
9,743
t,292
I 1,036
(e27)
t,670
t0,t94
9,758
1,294
1 1,052
(8s8)
1,670
10,069
9,793
1,298
n,0y2
(r,023)
1,670
10,062
9,829
1,303
tt,132
(1,070)
1,670
10,M3
9,8s0
1,306
1 1,156
(1,1 13)
1,670
9,920
9,892
1,311
1t,203
(1,28r'.)
1,670
9,912
9,831
1,303
I 1,135
(t,n3)
1,670
9,869
9,8s1
1,306
tt,t57
(1,288)
1,670
9,@9
9,861
1,307
1 1,168
(2,068)
1,670
SAR Resource S ulliciency /
@eficiency) 1,142 1,129 742 812 647 524 599 556 386 447 381 (399)
6. After accounting for power purchase agreements ("PPAs") with QFs signed since
the preparation of the 2017 IRP, and the termination of a QF PPA originally included in the
2017IRP, the first capacity deficit still first occurs in the summer of 2028, as shown in detail in
Table 2. Accordingly, the Company requests Commission approval establishing the summer of
2028 as the first capacity deficiency period when capacity payments should be made to a QF under
the SAR calculation.
Table 2
Updated System Capacity Loads and Resources
Calendar Year 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028
Srstcnr (\l\\ )
SignedPPAs not inIRP 0 4 4 85 U 134 134 134 133 133 132 132
(3) (3) (3) (3) (3) (3)Terminated PPAs in IRP (3) (3) (3) (3) (3) (3)
U@tedResources 12,159 12,7& 11,779 11,945 11,820 11,781 11,862 11,843 ll,7l9 ll,7l1 11,667 10,898
Updated SAR Resource
Sufficiency/ (Deliciency) 1,139 1,129 743 893 728 655 730 687 516 576 510 (270\
7. Table 2 shows the first capacity deficiency of 270 MW occurring in the summer of
2028. The updated system capacity loads and resources in Table 2 includes the capacity
contribution from nine additional QF contracts (six located in Wyoming, two in Utah, and one in
Idaho), with a total nameplate capacity of 460 MW. One QF PPA located in Oregon was
4
9,980
9,824
1,302
n,126
(r,146)
1,670
terminated, with a nameplate capacity of 5 MW. In2028 these updates contribute a net of 129 MW
to system capacity.
8. Rocky Mountain Power submits this Application to establish the capacity
deficiency period meets the requirements set forth in Commission Orders No. 32697 and
No. 32802, and requests that the Commission approve the capacity deficiency period to be used 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 authorizing this Application be processed pursuant to Modified Procedure and approving
the capacity deficiency period beginning in the summer of 2028, to be used in the Company's
avoided cost determinations under the SAR methodology, as shown in Table 2 above.
DATED this lSth day of August,2\l7.
ROCKY MOI.]NTAIN POWER
R. Ho
West North Temple, Suite 320
Lake city, Utah 841l6
No. [phone]
wonne.hogle@pacifi com.com
5