20190228Comments.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83]20-0074
[phone]
IDAHO BAR NO. T0446
(l
Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S PETITION FOR AN EXTENSION
TO FILE ITS 2OT9INTEGRATED RESOURCE
PLAN
CASE NO. PAC.E.19-01
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Edward Jewell, Deputy Attorney General, submits the following comments.
BACKGROUND
On January 28,2019, Rocky Mountain Power ("Company") filed a Petition seeking an
extension of the March 29,2019, filing date for the Company's 2019 Integrated Resource Plan
("IRP"; to a date no later than August 1,2019.
The Company states its economic analysis of its coal units has identified potential
reliability challenges that must be resolved before the coal studies can be completed. Petition at
2. The coal studies will inform the Company's preferred resource portfolio in the Company's
2019 IRP. Id. The Company asks to extend its filing deadline so it has adequate time to
complete its economic analysis of its coal units while appropriately accounting for system
reliability and additional portfolio analysis. 1d
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STAFF COMMENTS FEBRUARY 28,2019
The Company intends to use the extra time, if granted, to complete the economic analysis
of its coal units in a manner that incorporates system reliability needs and perform additional
portfolio analysis. The Company states that if the extension is approved, the Company will
continue to hold monthly public-input meetings up to the extended filing date.
STAFF ANALYSIS
Staff recommends that the Commission approve PacifiCorp's request to delay the
submission of the 2019 Integrated Resource Plan to a date no later than August 1, 2019. Staff
believes the Company's request for a delay provides the Company time to further analyze and
report on the effects of early coal unit retirements on system costs and reliability. To ensure a
robust evaluation, the Company is identifying risks to system reliability caused by reductions in
operating reserves, some of which are supplied by coal plants. This analysis has not been
performed in previous IRPs. PacifiCorp is making progress, but more work is necessary to
develop a least-cost, least-risk resource plan that satisfies the Company's reliability mandate.
A better understanding of the effects of plant closures can inform negotiations taking
place to change the Company's Multi-State Protocol (MSP), the method the Company uses to
allocate costs and revenues among the jurisdictions served by PacifiCorp. The new protocol
must consider the removal of coal-fired generation from rates in jurisdictions where it is required
by state law. Risks to each jurisdiction stemming from the re-allocation of coal plants costs will
continue to be evaluated.
One effect of early coal unit retirement may be to advance the deficiency date used to
begin capacity payments to new Public Utility Regulatory Policies Act of 1978 (PURPA)
projects. Staff considered the effect of delaying the Company's IRP filing on PURPA filings.
This includes the capacity deficiency update that the Company files after acknowledgment of
every IRP (see Order No. 33917) and the load and gas forecast update that the Company files
every year by October 15. The capacity deficiency filing, which is based on the load and
resource balance in the IRP, is used to develop avoided cost pricing for Surrogate Avoided
Resource (SAR)-based qualifying facility (QF) contracts. If the results of the coal study
accelerate coal plant closings, the deficiency date will come sooner and capacity payments for
new contracts will begin earlier. Consequently, new contracts signed during the four-month
2STAFF COMMENTS FEBRUARY 28,2019
delay period will not reflect the updated (and most likely earlier) deficiency date in the final
acknowledged IRP.
Even with the requested delay in the IRP filing, Staff believes the load and gas update
used in determining avoided cost pricing for IRP-based contracts can still be filed by October l5
of the current year per Commission Order No. 32802. This would be similar to updates that
occur during years that IRPs are not filed.
The IRP delay could potentially affect the Company's depreciation case (PAC-E-l8-08),
which was filed in September 2018. However, the Company has requested a January 1,2021
effective date for updating depreciation rates, so Staff does not believe that a four-month delay in
the IRP will unduly impact the depreciation case. Staff believes that recommendations in the
depreciation case will benefit from the thorough analysis the Company intends to conduct if the
IRP extension is granted.
In addition to its request to the Idaho Public Utilities Commission to delay the IRP filing,
PacifiCorp has requested IRP filing extensions at the Utah Public Service Commission and the
Washington Utilities and Transportation Commission, and provided notice of delayed filings to
the Oregon Public Utility Commission and Wyoming Public Service Commission. California
does not require a filing requesting approval of the delay nor notice of delayed filing.
STAFF RECOMMENDATION
Staff believes that a more rigorous 20 1 9 IRP plan presented by August 1 , 201 9 is
preferable to an incomplete plan presented by April 1,2019. Therefore, Staff recommends that
the Commission approve PacifiCorp's request to delay the submission of the 2019 Integrated
Resource Plan to a date no later than August 1,2019.
Respectfully submitted this ?,Sv day of Febr uary 2019.
L(
Edward
Deputy General
Technical Staff: Bentley Erdwurm
Rick Keller
i:umisc/comments/pace 19. I ejberk comments
JSTAFF COMMENTS FEBRUARY 28,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF FEBRUARY 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC.E-I9-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E,MAIL ONLY:
datareq uest@pacifi com. com
YVONNE HOGLE
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: Yvonne.hosle@f'acificorp.com
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SECRETARY 7
CERTIFICATE OF SERVICE