20210324Reply Comments.pdf

Y ROCKY MOUNTAIN
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Salt Lake City, Utah &4116
March 24,2021,
VIA ELECTRONIC DELIWRY
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Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
I1331 W. Chinden Blvd
Building 8 Suite 20IA
Boise,lD 83714
Re:CASE NO. PAC.EAI{3
IN THE MATTER OF ROCKY MOUNTAIN POWER'S 2O2I INTEGRATED
RESOURCE PLAN
Dear Ms. Noriyuki:
Please find attached Rocky Mountain Power's reply comments in the above referenced matter.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at(801)220-
2963.
Very truly yours,
.^.'D
Vice President, Regulation
Emily Wegener
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
FAX: [phone]
Email : emil)r.weeener@oacifi corp.com
Attorneyfor Roclry Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S 2021 INTEGRATED RESOURCE
PLAI\
) CASE NO. PAC-E-20-03
)) REPLY COMMENTS OF
) ROCKY MOUNTAIN POWER
Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission"), Rocky Mountain Power, a division of PacifiCorp (the'oCompany")
hereby submits reply comments in the above-referenced case.
L BACKGROUND
l. On February 12,2021, the Company filed a petition requesting an extension to the
filingdate of the 2021 lntegrated Resource Plan ("2021IRP") to provideadditional time: l) to
complete implementation of new modeling software; 2) for robust and inclusive public process
once modeling results are known; and 3) to allow for inclusion of short list results from the
Company's 2020 All-Source Request for Proposals ("2020 AS RFP") once those results are known.
2. On March 18,2021, stakeholders to this proceeding filed comments in response to
the Company's petition, with Staff of the Idaho Public Utilities Commission ("Staff')
recommending the Commission approve the Company's request to file the 2021IRP no later than
September l, 2021, and Sierra Club also recommending an extension be granted, but only to
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July 1 5, 2021 . The Company appreciates Staff's support of the September l, 2021, extension as
described in their comments. These reply comments are specifically in response to Sierra Club.
II. REPLY COMMENTS
7. Sierra Club recommends the Company file the 2021 IRP by July 15,2021, instead
of Septemb er I , 2021, as requested by the Company. In exchange for this extension, Sierra Club
recommends the Company be required to provide additional model run information associated
with certain hypothetical federal requirements.
8. Following the 20|9IRP, PacifiCorp began a transition to Energy Exemplar's Plexos
model. This model provides multiple improvements to the IRP process, including greater
granularity, greater ability to model reliability outcomes through inclusion of loss of load
probability and planning reserve margin, the ability to include endogenous transmission modeling
without including topology additions or other complex setups, and the ability to include greater
analysis of resource retirement options.
9. PacifiCorp presented the benefits of the Plexos model to stakeholders during the
June 2020 public-input meeting, and the model transition has been ongoing throughout the 2021
IRP development cycle.
10. HoweveE the transition to the new model and the necessary setup activities to
ensure model functionality have encountered challenges, which could not have been foreseen until
the inputs were set up in the model and the Company could start the portfolio development phase
of the 2021 IRP. If granted, the extension to the filing date for the 2021 IRP would provide the
Company time to implement and optimize the model and produce model outcomes while allowing
for stakeholder review and input.
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ll. As of today, the Company has been unable to produce any 2021 IRP portfolio
results for cost and risk analysis and as such hasn't been able to receive stakeholder input on any
modeling results. Extending the filing date for the 2021 IRP to no later than September 1,2021,
allows the Company to incorporate the updated inputs that will occur from the 2020 AS RFP final
shortlist with the least disruption possible to the IRP process.
12. As the Company continues to setup the new modeling software and work toward a
final shortlist in the 2020 AS RFP, there are variables that stakeholders will need an opportunity to
provide input on. As summarizedinThble l, the Company plans to have the first modeling outputs
ready to share by late April, with modeling refinements and inputs updated throughout the summer.
13. A filing date of no later than September 1, 202I, for the 2021 IRP will enable
stakeholder input on portfolio modeling. The Company could continue the public-input process
throughout spring and summer of 2021 and schedule additional public-input meetings. Table 1
reflects the steps the Company will take to achieve a2021IRP filing by no later than September
1,2021.
Table l:2021IRPU Public-t Sched
Date Activity Tentative Detail
April22-23,2021 April Public-Input Meeting Initial discussion of modeling results;
opportunity for stakeholder feedback.
May 27-28,2021 May Public-Input Meeting Continued discussion of modeling results and
opportunity for stakeholder feedback.
June24-25,2021 June Public-Input Meeting Discussion of portfolios with incorporation
of 2020AS RFP final short list results,
discussion of cost and riskportfolio analysis;
other scenarios / sensitivities; opportunity for
stakeholder feedback
July 29-30,2021 July Public-Input Meeting Discuss preferred portfolio/cost and risk
analysis; remaining scenarios / sensitivities;
opportunity for stakeholder feedback.
Ausust 12.2021 Ausust Public-Inout Meetine Ifneeded
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14. Sierra Club's recommendation for a seven-week extension to July 15,2021, would
not provide adequate time to work through modeling and incorporate the 2020 AS RFP final
shortlist while allowing for meaningful stakeholder consideration and feedback. The Company
needs adequate time to work as expediently as possible to develop the IRP, seek stakeholder
feedback, and file the IRP with the regulatory commissions. The Company further notes that
imposing additional modeling requirements would only result in more time constraints
and could funher delay development of the 2021 IRP.
M. CONCLUSION
The Company's petition for an extension to the filing date of the 2021 IRP to on or before
September l,2Uzl,balances the need to expediently prepare and file the 2021 IRP with the
opportunity for stakeholders to continue to provide robust and inclusive feedback. The Company
appreciates Staff's recommendation that the extension be granted as requested. The Company also
appreciates Sierra Club's recommendation that an extension be granted but as noted a seven-
week extension, recommended by Siena Club, would not be sufficient to develop and complete
the 2021IRP nor would it allow for meaningful stakeholder participation or feedback. Therefore,
PacifiCorp respectfully requests that the Commission grant a filing date for the 2021 IRP of no
later than September 1,2021.
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Dated this 24e day of Marchz0zt.
Respectfully submitted by,
ROCKYMOI,'NTAIN POWER
fl,^e Liler"r ,
Emily wdener O
Rocky Mountain Power
1407 WestNorth Temple, Suite 320
Salt Lake City, Utatr 84116
Telephone: [phone]
Email: emil]r.weeener@oacifi corp.com
Attorruyfor Rocky Mountain Power
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