20190319final_order_no_34275.pdf

Office of the Secretary
Service Date
March 19,2019
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )CASE NO.PAC-E-19-01
POWER'S PETITION FOR AN EXTENSION )
TO FILE ITS 2019 INTEGRATED )
RESOURCE PLAN )ORDER NO.34275
On January 28,2019,Rocky Mountain Power ("Company")filed a Petition seeking to
extend the March 29,2019 filing date for the Company's 2019 Integrated Resource Plan ("IRP").
BACKGROUND
The IRP is "a status report on the utility's ongoing,changing plans to adequatelyand
reliably serve its customers at the lowest system cost and least risk over the next 20 years."Order
No.34018.The Commission has required the Company to file a planning document biennially
since 1987 when the Commission ordered the Company to file its Resource ManagementReport-
a precursor to the IRP-beginningin March of 1989.Order No.22299.The Company's 2019
IRP will be its 15th comprehensive planning document submitted to the Commission.
THE PETITION
The Company requests an extensionofits March 29,2019 IRP filingdeadlineto a date
no later than August 1,2019.The Company,through its economic analysis of its coal units,has
identified potential reliability challenges that must be resolved before the Company's coal studies
can be completed.The coal studies will inform the Company's preferred resource portfolio put
forth in its IRP.According to the Company,"This extension will enable PacifiCorp to complete
its economic analysis of coal units,appropriately accounting for system reliability,and necessary
additional portfolio analysis."Petition at 2.The Company states that if the Commission approves
the extension,the Company will continue to hold monthly public-input meetings up to the
extended filing date.The Company also states it communicated to stakeholders its intent to file
this request for an extension.
COMMENTS
Staff and the Idaho Conservation League ("ICL")filed the only comments,and
recommended that the Commission grant the Petition.
ORDER NO.34275 1
A.Commission Staff
Staff recommended the Commission approve the Company's request to delay
submission of its 2019 IRP.Staff stated its belief that providing the Company more time would
allow the Company to better evaluate how its reduced operating reserves from coal plants could
affect system reliability.Further,Staff indicated that a better understanding of the system
reliability effects of coal plant closures might inform negotiations taking place around the
Company's Multi-State Protocol ("MSP").The MSP is being revised to remove coal-fired
generation from rates in jurisdictionswhere removal is required by state law.Staff also stated its
belief that follow-on delays from a delay to the IRP filing,such as updates to capacity deficiency
dates under the Public Utility Regulatory Policies Act of 1978,or impacts to the Company's
ongoing depreciation case,PAC-E-18-08,would be minimal.
B.Idaho Conservation League.
ICL filed comments in support of the Company's request to delay the filing date of its
2019 IRP.ICL suggested the Commission not set a filing date for the 2019 IRP,but direct the
Company to file its IRP when it contains a complete analysis of relevant issues.
COMMISSION FINDINGS AND DECISION
The Company is an electrical corporation and public utility as defined in Idaho Code
§§61-119,61-129.The Commission has jurisdiction over the Company and the issues in this case
under Title 61 of the Idaho Code,includingIdaho Code §61-501.
The Commission has reviewed the Company's Petition and the comments of
Commission Staff and ICL.Based on our review of the record,we find it reasonable to approve
the Company's request for an extension of its IRP filing deadline until a date no later than August
1,2019.We believe the additional time will provide the Company better opportunity to analyze
potential reliability impacts associated with the findings of its coal economic analysis and to
integrate its reliability analysis into its preferred resource portfolio.
We decline to adopt ICL's recommendation to not set a deadline and allow the
Company to file its IRP when its analysis is complete.IRP analyses are never truly complete.It
is an iterative process.As we have stated previously,"We realize that integratedresource planning
is an ongoing,changing process.Thus,we consider the [IRP]to be similar to an accounting
balance sheet,i.e.,a 'freeze-frame'look at a utility's fluid process."Order No.22299.We have
also stated that "an IRP is a working document that incorporates many assumptions and projections
ORDER NO.34275 2
at a specific point in time.It is a plan,not a blueprint."Order No.34018.In keeping with our
longstanding conception of an IRP as a freeze-frame look at a fluid process,we find it useful to
set a deadline.If the Company requires more time to conduct a thorough analysis based on the
results of its studies,it can request another extension.Conversely,if the Company completes a
thorough analysis before August 1,2019,it can submit its IRP upon completion.
ORDER
IT IS HEREBY ORDERED that the Company's Petition for Extension of Time is
granted.The Company shall files its IRP no later than August 1,2019.
THIS IS A FINAL ORDER.Any person interested in this Order may petition for
reconsideration within twenty-one (21)days of the service date of this Order with regard to any
matter decided in this Order.Within seven (7)days after any person has petitioned for
reconsideration,any other person may cross-petition for reconsideration.See Idaho Code §61-
626.
ORDER NO.34275 3
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this
day of March 2019.
PAUL K LLAN ,,PRESIDENT
KRIS/WERAPER,CO MISSIONER
ERIC ANDERSON,COMMISSIONER
A
Diane M.Hanian
Commission Secretary
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