20210318Comments.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
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Street Address for ExPress Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY
MOUNTAIN POWER'S 2021
INTEGRATED RESOURCE PLAN
CASE NO. PAC-E.21-03
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COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Pubtic Utilities Commission, by and through its Attorney of record,
Edward Jewell, Deputy Attorney General, submits the following comments.
BACKGROUND
On February 12,202l,Rocky Mountain Power, a division of PacifiCorp ("Rocky Mountain
power,, or.oCompany,,) petitioned the Commission to extend the filing date for its202l Integrated
Resource Plan ("IRP") from March 31,2021, to no later than September 1, 2021'
The Company stated it has held 12 public-input meetings on its 2021 IRP in which it has
discussed topics such as 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.
The Company has been working since the summer of 2020 to implement new modeling
software for the 2021 IRp but as of the time of filing its Petition, it has not successfully completed
any model runs to establish resource portfolios and evaluate costs and risks'
STAFF COMMENTS MARCH I8,2O2I1
The Company also stated it is currently conducting its 2020 All Source Request for
Proposals ("2020AS RFP") and will have a final shortlist by June 1, 2021. The proposed IRP
extension would allow the results of the 2020AS RFP to be incorporated in the 2021 IRP.
STAFF ANALYSIS
Staff evaluated aspects of the Company's filing and determined that permitting an extension
to the IRP deadline would allow the Company time to resolve issues with new power system
modeling software and include the 2020AS RFP. Staff believes there will be limited impact to
upcoming filings that utilize results of the IRP, but Staff recommends that if the Load and Gas
Forecast Update will be delayed past its October t5,2021filing deadline or if the IRP will be
further delayed, that the Company notiff the Commission as soon as it is known. Staff
recommends that the Commission grant the Company's requested 5-month extension for filing the
2021 rRP.
Forecast Modeling
Staff supports the thorough development and analysis of a least-cost, least-risk integrated
resource plan which further extends analysis to support the Multi-State Protocol ("MSP"). In the
February IO,202l IRp public-input meeting, the Company disclosed it was continuing to'oaddress
modeling functionality and performance issues associated with implementation of new and
advanced modeling software," and that they were behind in performing model runs that would
establish resource portfolios needed for cost and risk analysis. Staff believes it is appropriate to
permit the IRP extension to allow the Company time to resolve issues with the new software'
Request for Proposals
During the IRP delay, Staff finds it reasonable for the Company to include results from the
2020AS RFp while also making necessary adjustments to optimize modeling functionality and for
updating input parameters used by the model.
Related IRP Cases
Considering the proposed five-month IRP filing delay, Staff believes there would be
minimal impact to the load and gas forecast update case that is used to develop the IRP avoided cost
STAFF COMMENTS MARCH I8,2O2I2
model. In the Company's prior case, PAC-E-19-01 which was submitted to extend the 2019 IRP
filing,l the Company was able to file the Load and Gas Forecast Update within 23 days of the
regular October 15th filing date.2
Staff recognizes that the IRP delay will lead to a delayed update of the First Capacity
Deficiency Date usedfor avoided cost pricing under both the Surrogate Avoided Resource Method
and the IRP Method because the First Capacity Deficiency Date case is filed after the
acknowledgement of each IRP. See Order Nos. 33917 and34649. This will result in using the
currently approved First Capacity Deficiency Date for a longer period.
STAFF RECOMMENDATIONS
Staff recommends the Commission grant a 5-month extension for filing the 2021IRP from
March 3l,2}2l to September 1,2021and that the Company inform the Commission, if the Load
and Gas Forecast (lpdate will be delayed past its October t5,202I filing deadline or if the IRP
frling will be further delayed as soon as it is known.
Respectfully submitted this 'Fo& day of Mar ch202l.
Deputy General
Technical Staff: Rachelle Farnsworth
Richard Keller
i:umisc/comments/pace2 l.3ejrkrf comments
I In the case to extend the 2019 IRP filing, the Company filed the IRP on October 18, 2019. Case No. PAC-E-19-01
2 Case No. PAC-E-19-18,
STAFF COMMENTS MARCH I8,2O2I
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISTH DAY OF MARCH 2021,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO. PAC-E-21-03, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@pacifi corp.com
idahodockets@pacifi corp. com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@paci fi corp.com
SECRETARY
CERTIFICATE OF SERVICE