20221004Application.pdf

Y ROCKY MOUNTAIN
Fo\AIER
i'itCilVED
?[?I0tT -lr Pl{ h: 58
lrr,:r.:1O FULILIC
: .i : I l- ti' I I s-c0M[l lss lott
'1407 W. North Temple, Suite 310
Salt Lake City, Utah 84116
October 4,2022
ELECTRONIC DELIVERY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden BIvd
Building 8 Suite 20lA
Boise,ID 83714
RE: CASE NO. PAC-EA2-14
IN TIIT', MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF A CAPACITY DEFICIENCY PERIOD TO BE USED FOR AVOIDED
COST CALCT]LATIONS
Attention: Jan Noriyuki
Commission Secretary
Please find for filing Rocky Mountain Power's Application in the above-referenced matter along
with confidential work papers.
Informal inquiries may be directed to Ted Weston,Idaho Regulatory Manager at
[phone].
V truly yours,
Joelle Steward
SVP of Regulation, Customer, and Community Solutions
Joe Dallas (lSB# 10330)
825 NE Multnomah, Suite 2000
Portland, OR97232
Telephone No. [phone]
j oseph.da I las(@pac i fi corp.com
Attorneyfor Roclry Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMIVIISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF A CAPACITY DEFICIENCY
PERIOD TO BE USED FOR AVOIDED COST
CALCULATIONS
CASE NO. PAC-E-22-14
APPLICATION
Rocky Mountain Power, a division of PacifiCorp ("the Company"), in accordance with
Idaho Code $61-502, $61-503, and RP 052, hereby respectfully submits this application
("Application") to the Idaho Public Utilities Commission ("Commission") in accordance with
Order Nos. 32697 and 32802 in Case No. GNR-E-I 1-03, for approval of the capacity deficiency
period determination to be used in avoided cost calculations using the Surrogate Avoided Resource
("SAR") methodology. As more fully described below, this update identifies Rocky Mountain
Power's capacity deficiency period in the summer of 2023 and explains how the deficiency period
was identified. In support of its Application, Rocky Mountain Power states as follows:
l. Rocky Mountain Power is authorized to do and is doing business in the state of
Idaho. The Company provides retail electric service to approximately 86,500 customers in the
state and is subject to the jurisdiction ofthe Commission. Rocky Mountain Power is a public utility
in the state of Idaho pursuant to Idaho Code $ 6l-129.
COMMUNICATIONS AND SERVICE OF PLEADINGS
2 Communications regarding this Application should be addressed to:
Ted Weston
1407 West North Temple, Suite 330
Salt Lake city, utah 841l6
Telephone : (80 l) 220 -29 63
Email: [e-mail]
Ron Scheirer
825 NE Multnomah, Suite 600
Portland, Oregon 97232
Telephone: (503) 8 I 3-6484
Email: ron.scheirer@pacifi corp.com
In addition, the Company respectfully requests that all data requests regarding this matter
be addressed to one or more of the following:
By e-mail (preferred) [e-mail]
By regular mail Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
BACKGROUND
3. Commission OrderNo.32697 directed the utilities to initiate a case outside of their
Integrated Resource Plan ("lRP") filing to establish the capacity deficiency period to be used in
the utility's SAR methodology:
"We find it reasonable and fair to subject each utility's determination of capacity deficiency
to further scrutiny. Therefore, when a utility submits its Integrated Resource Plan to the
Commission, a case shall be initiated to determine the capacity deficiency to be utilized in
the SAR Methodology. The capacity deficiency determined through the IRP planning
process will be the starting point, and will be presumed to be correct subject to the outcome
of the proceeding."l
I In the Matter of the Commission's Review of PURPA QF Contract Provisions Including the Surrogate Avoided
Resource (SAR) and Integrated Resource Planning (IRP) Methodologiesfor Calculating Avoided Cost Rates, Case
No. GNR-U-I l -03, Order No. 32697, p. 23.
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4. In Order No. 32697, the Commission acknowledged that "some determinations
made within the IRP process have an impact on calculations under the SAR and IRP
methodologies. Specifically, the IRP process determines when the utility will experience a need
for new capacity."2 The Commission ordered that payments to qualiffing facilities ("QFs") should
recognize the utility's capacity needs, stating:
"In calculating a QF's ability to contribute to a utility's need for capacity, we find it
reasonable for the utilities to only begin payments for capacity at such time that the utility
becomes capacity deficient. If a utility is capacity surplus, then capacity is not being
avoided by the purchase of QF power. By including a capacity payment only when the
utility becomes capacity deficient, the utilities are paying rates that are a more accurate
reflection of true avoided cost for the QF power."3
5. In Order No . 35415, the Commission stated that "all future L&R Balances included
in the capacity deficiency date update for avoided costs must contain the most up-to-date
information available at the time of filing."a
6. In Order No. 34918, the Commission indicated that early retirement of coal-fired
thermal resources should not be reflected in the load and resource balance, ooUnless and until this
Commission evaluates and approves an early retirement date..."5
REOUEST TO ESTABLISH SAR DEFICIENCY PERIOD
7. On September l, 2021, Rocky Mountain Power filed its 2021 IRP with the
Commission. The 2021 IRP includes the results of the Company's Capacity Loads and Resources
without Resource Additions in Table 6.ll on page 154. The capacity balance is calculated for
summer peak loads, with the summer peak occurring annually in July, as the Company is expected
2 OrderNo. 32697,p.23.
3 OrderNo.32697,p.Zl.
a In the matter of ldaho Power Comparry's Application for Approval of the Capacity De/iciency to be Utilized for
Avoided Cost Calculations, Case No. IPC-E-21-09, Order No. 35415, p.10.
s In the Matter of RoclE Mountain Power's Applicationfor Approval of a Capacity Deficiency Period to be Usedfor
Avoided Cost Calculations, Case No. PAC-E-20-13, Order No. 34918, p.5-6.
aJ
to be deficient in the summer prior to becoming deficient in the winter. The capacity balance is
developed by determining firm resource capacity available, including the Company's firm access
to imports from the wholesale market Front Office Transactions ("FOTs"), less the system
obligation and a l3 percent planning reserve margin.
8. In light of the risks associated with the evolving resource mix across the west, the
2021 IRP included a reduced FOTs limit of 500 megawatts in the summer, relative to the
2019 IRP limit of 1,425 megawatts, as shown in Table 5.8 on page I14.
9. At the updated Front OfIice Transaction limit, the 2021 IRP shows that the
Companyos load and existing resource balance is capacity deficient throughout the planning
horizon; however, several inputs have changed between the preparation of the 2021 IRP and the
present.
10. On April 4,2022, Rocky Mountain Power filed its 2021 IRP Update with the
Commission. The 2021 IRP Update includes the results of the Company's Capacity Loads and
Resources without Resource Additions in Table 4.2 on page 47 and is provided as Table No. l.
The 2021 IRP Update included a higher load forecast as well as updates to contracted resources,
and also shows that the Company's load and existing resource balance is capacity deficient
throughout the planning horizon.
Table No. I
2021 IRP Update - Summer Peak Loads and Resources without Additions
Crhn&rYerr 2023 2V24 2925 m26 2t27 2028 2029 2ql0 2oll
System
Totrl Resources
OHigation
Phnniry Resewes (137o)
Obligation + Resewes
System Posithn
Avaihbh r0Ts
Net Surptus(Defrcit)
9,472
9,803
t274
ll,w7
( 1.605 )
8,850
9,880
t2u
I 1,165
(2.31 5 )
9,287
9,87t
1,283
I t,155
( I .867)
8,623
9,7U
1,269
I 1,034
(2.4rr)
8,516
9,63
1,256
10,919
(2,403)
7,831
9541
12s3
I0,894
(3.063)
7,753
9,799
1,274
I 1,073
( 3.320)
7,482
9,799
1274
I 1,073
(l.s9l)
7,210
9,821
t,277
I 1,098
( 3,888)
515 515 515 5t5 515 515 515 515 5t5
(r.090) (r.800) (r.352) (1.896) (r.888) (2.548) (2.805) (3.076) (3.373)
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I l. Certain adjustments are appropriate to account for committed and uncommitted
resource impacts, relative to the representation in the 2021 IRP Update, specifically:
a. Removing uncommitted early coal retirements, consistent with Order 34918.
b. Adding contracts signed since the 2021 tRP Update was prepared, as well as
resources identified on the final shortlist of the Company's 2020 All-Source
Request For Proposals, whose contracts are currently being finalized.
c. Adding demand response programs selected as part of the 2021Demand Response
Request For Proposals, including projected growth in those programs over time.
d. Adding FOTs that have already been contracted.
12. After accounting for the adjustments described above, the first capacity deficiency
of 296 megawatts occurs in the summer of 2023, as shown in Table No.2. After a larger deficiency
in 2024, a period of sufficiency occurs from 2025 through 2027 .
Table No.2
Updated Summer Peak Loads and Resources
CelendrrYeer 2U23 2U24 2Ullj 2026 2t27 2MA 2lJi29 20310 20:ll
System
Srtrf iciency/Ihf iciency Position
+Uncommitted Coal Retircments
+Si$ed Contrrcts & 2lM AllSource RtrP
+21D1 Demnd Response RFP
U@ted Position Before trlOTs
+Conmitted fl0Ts
+Remaining FOTs (rp to 2021 IRP Limit)
Srdlicie ncy(Deficiency)
l,896)
550
758
331
,090)
0
7
221
.800)
0
55
268
,888)
550
760
348
(3.076)
699
782
294
699
576
283
( r.3s2) ((3,373)( 2.80s)(2,548)
0
889
312
699
832
307
5U
883
371
(863) (1.476\ (r5l) (2s6) (22e\ (712) (e66) (1.301) (l,8ls)
0
515
567
0
0
515
0 0 0
5ls 515 515 5t5
0 00
515 515
(2e6\ (e6l) 3il 259 286 (197) (4sl) (786) (r,300)
13. Based on these updates, the Company requests that the Commission find the
sunrmer of 2023 as the first capacity deficiency period when capacity payments should be made
to a QF under the SAR calculation.
14. Rocky Mountain Power submits this Application to establish the capacity
deficiency period as set forth in Commission Orders No. 32697 and No. 32802, and requests that
the Commission approve the capacity deficiency period to be used in its SAR calculations.
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MODIFIED PROCEDURE
15. Rocky Mountain Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed under Modified
Procedure; i.e., by written submissions rather than by hearing. RP 201 et seq. If, however, the
Commission determines that a technical hearing is required, the Company stands ready to prepare
and present its testimony in such hearing.
CONCLUSION
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission issue
an order authorizing this Application be processed under Modified Procedure and approving the
capacity deficiency period beginning July 2023, to be used in the Company's avoided cost
determinations under the SAR methodology, as shown in Table No. 2 above.
DATED this 4ft day of October2022.
ROCKY MOUNTATN POWER
Joe Dallas
825 NE Multnomah, Suite 2000
Portland, OR97232
Telephone No. [phone]
j oseph.dal las@pacifi corp.com
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