20210212Petition for Extension.pdf

Y ROCKY MOUNTAIN
BP,yy,E#*,
Irrfr'\
J', -- 1'' * i ! Lrn +'
r,,; ; t[] l2 Pi{ 3: i a
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
February 12,2021
VIA ELE C TRO NIC D E LIYE RY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 20lA
Boise,lD 83714
Re:CASE NO. PAC-E-21.03
IN TI{E MATTER OF ROCKY MOUNTAIN POWER'S 2O2I INTEGRATED
RESOURCE PLAI\
Dear Ms. Noriyuki:
Please find attached Rocky Mountain Power's Petition in the above referenced matter.
Informal inquiries may be directed to Ted Weston,Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
Emily Wegener
Rocky Mountain Power
1407 West North Tenlple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
FAX: (80r)220-3299
Email: emily.we gener@f'acifi corp.com
Attorneyfor Rocly Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMNdISSION
IN TIIE MATTER OF ROCKY
MOT]NTAIN POWER'S 2021
INTEGRATED RESOURCE PLAI\
)
)
)
)
)
CASE NO. PAC.E-2I.03
PETITION FOR EXTENSION
COMES NOW Rocky Mountain Power, a division of PacifiCorp ("Rocky Mountain
PoweC' or the "Company"), in accordance with Rule 53 of the Idaho Public Utilities Commission's
Rules of Procedure ("RP"), hereby petitions the Idaho Public Utilities Commission
("Commission") for an extension of the March 31,2021I filing date of the Company's
2021lntegrated Resource Plan ("IRP"). In support of this request Rocky Mountain Power states
as follows:
I. BACKGROUND
Per Commission OrderNo.22299 issued in CaseNo. U-l500-165, Rocky Mountain Power
biennially files an IRP. That filing requirement was reaffirmed in Order No.27835 issued in
Case No. UPL-E-98-4 when the Commission directed the Company to file an IRP in
December 2000, and biennially thereafter. That requirement was later modified in
Order No. 30262 issued in Case No. PAC-E-07-03 when the Commission granted the Company's
request to file all future IRPs by the last business day of March biennially beginning in 2009.
I The IRP is due on the last business day of March which, in this case, is March 31,2021
IPETITION OF ROCKY MOI.JNTAIN POWER
Rocky Mountain Power has been diligently working on development of its 2021 IRP
through a robust, transparent and thorough public-input process. This stakeholder process began
in January 2020 with a series of technical workshops focused on energy efficiency assumptions
being developed from an updated conservation potential assessment. PacifiCorp began a series of
more general public-input meetings in June 2020, which addressed a range of topics describing
Pacificorp's modeling methodology, inputs and assumptions for the 2021 IRp.
Agenda items covered topics including, but not limited to, resource cost-and-performance
assumptions, model function and overview, load forecast, price-policy assumptions, market price
assumptions, and transmission options considered as part of the 2021 IRP. In addition, PacifiCorp
has been working since the summer of 2020 to implement new modeling sofLware for the 2021
IRP. To date, PacifiCorp has held 12 public-input meetings. All public-input meeting materials,
available studies conducted and stakeholder feedback forms to date can be found at:
www.pac i fi corp.com/es/im.htm l.
II. TIMING OF 2021 IRP
Given the current status of the 2021 IRJ and the timeline of the on-going 2020 All Source
Request for Proposals ("2020AS RFP"), PacifiCorp respectfully requests an extension to file the
2021 IRP from March3l,202l to no later than September l, 202l.The 2020AS RFP is on
schedule to have a final shortlist by June 1,2021. The extension will ensure that the 2021 IRP is
aligned with the results of the 2020AS RFP, which can have implications on the Company's
resource plan over both the near and long term. Considering that the current filing schedule of
March 31,2021 would require filing the 2021 IRP just two months ahead of establishing a final
shortlist in the 2020AS RFP, PacifiCorp believes it is reasonable to delay filing the 2021 IRP so
that the results of the 2020AS RFP can be accounted for in the current planning cycle.
PETITION OF ROCKY MOI.'NTAIN POWER 2
At the time of this filing, PacifiCorp has not been able to successfully complete any model
runs to establish resource portfolios and to evaluate costs and risks. Consequently, the filing
extension will not only ensure the202l IRP captures the results of the 2020AS RFP, it will enable
PacifiCorp time to: make necessary adjustments to optimize the modeling functionality of its new
systems; complete the necessary analysis to develop a least-cost, least-risk preferred portfolio; and
allow sufficient time for stakeholder review and input.
PacifiCorp will continue its robust and transparent public-input process with additional
monthly public-input meetings to be scheduled up to the extended filing date to provide
stakeholders continued opportunity to participate in the 2021 IRP development process focused on
the Company's analysis and overall progress. The Company discussed this extension request with
stakeholders and provided future public-input meetings dates, including scheduling additional
public-input meetings up to the proposed file date extension, during its February 10,2021public-
input meeting.
III. COMMUNICATIONS
Service of pleadings, exhibits, orders, and other documents relating to this proceeding
should be served on the following:
Ted Weston
Manager, Idaho Regulatory Affairs
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake city, uT 84111
Ted.Weston@Pacifi Corp.com
Emily.Weeener@pacifi corp.com
In addition, it is respectfully requested that all formal correspondence and Staff requests
regarding this material be addressed to:
By E-mail (preferred): [e-mail].
PETITION OF ROCKY MOI.JNTAIN POWER
Emily Wegener
Senior Attorney
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84111
J
By Fax:
By regular mail
(s03) 813-6060
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
IV. MODIFIED PROCEDURE
Rocky Mountain Power believes that consideration of this petition does not require an
evidentiary proceeding, and accordingly the Company requests that this Application be processed
under RP 201 allowing for consideration of issues under Modified Procedure, i.e., by written
submissions rather than by an evidentiary hearing.
V. CONCLUSION
WHEREFORE, based on the foregoing, the Company respectfully requests a five-month
extension of the filing of its 2021 IRP from March 31,2021., to no later than September l, 2021.
Respectfully submitted this 12ft day of February,2}2l.
By ,,*e^ UJr*"^, "
Emily w"gin"/o
Attorney for Rocky Mountain Power
4PETITTON OF ROCKY MOUNTAIN POWER