20230712Rocky Mountain Power Waiver of Compliance.pdf

July 12, 2023

VIA ELECTRONIC FILING

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714

RE: CASE NO. PAC-E-22-14
IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION FOR
APPROVAL OF A CAPACITY DEFICIENCY PERIOD TO BE USED FOR AVOIDED
COST CALCULATIONS

On June 29, 2023, the Idaho Public Utilities Commission (“Commission”) issued Order No. 35834 in
the above referenced case directing Rocky Mountain Power, a division of PacifiCorp (“the Company”),
to make a compliance filing to address several of the matters arising from Commission Staff's comments
(“Staff”). The following are the items raised by Staff in their comments:

1. Use the capacity deficiency period . . . to determine when capacity payments begin for both
IRP-based and SAR-based contracts;
2. Provide the load and resource balance (“L&R”) using the 20-year IRP planning horizon, instead
of the 9-year timeframe submitted with the Company’s filing;
3. Provide the L&R reflecting both summer and winter peaks;
4. Use the 2021 IRP method, instead of the 2021 IRP Update method, to determine capacity
contributions of all resources;
5. Assume renewal of PURPA projects located in the State of Idaho, unless the Company has
information from specific QFs to the contrary;
6. Update the L&R to include all contracts executed by the date of the Commission order that are
eligible for rate recovery;
7. Include the additional 3% contingency reserves above the Front Office Transaction (“FOTs”)
limit only if it increases the amount of available FOTs that the Company can rely on to meet its
load obligations;
8. Include projected growth in existing Demand Response (“DR”) programs;
9. Only include DR programs from the 2021 Request for Proposals (“RFP”), that are approved
programs in the L&R;
10. Include existing DR programs and approved new DR programs consistently in the L&R such that
they are both treated either as a decrement to load or as a resource; and
RECEIVED
Wednesday, July 12, 2023 11:30:00 AM
IDAHO PUBLIC
UTILITIES COMMISSION
Idaho Public Utilities Commission
July 12, 2023
Page 2

11. Verify the value of the existing Energy Efficiency (“EE”) in the load forecast, ensuring 68 MW
is used.

The Commission found in Order No. 35834 that items 10 and 11 listed above were satisfied in the
Company’s reply to Staff comments. For item 7, the Company is to provide clear evidence in its next
filing that the that the Company can reliably count on the additional 3 percent contingency reserves
above the Front Office Transactions (“FOT)” limit to provide contingency reserves. The Commission
found that the remainder of the items raised by staff be addressed in a compliance filing within 21 days
of the order.

On June 8, 2023, the Idaho Public Utilities Commission (“Commission”) issued Order No. 35810
directing the utilities, including the Company, to “file its capacity deficiency case within thirty (30) days
of filing its respective IRP.”1 On March 31, 2023, the Company filed its 2023 integrated resource plan
(“2023 IRP”). The Company plans to submit its capacity deficiency filing for the 2023 IRP after the
2023 IRP is acknowledged in accordance with Order Nos. 32697 and 32802 in Case No. GNR-E-11-03,
since Order No. 35810 was issued more than 30 days after the filing of the 2023 IRP.

The Company respectfully requests a waiver of the compliance filing requirement as outlined in Order
No. 35834. The waiver would provide the Company with an opportunity to address the compliance
filing items in its application for the 2023 deficit date, subsequent to the acknowledgement of the 2023
IRP. It is important to note that this waiver does not release the Company from its obligations to address
the issues raised by the order. However, it would reduce duplicate work for both the Company and Staff,
as the items in the compliance filing would not impact the deficiency date associated with the 2021 IRP.

In further support of the Company’s waiver request, with regard to item 3, the Company notes that it
provided the L&R for both summer and winter peak in an attachment provided in response to Staff data
request 1. The associated winter peak results are provided in Tables 1W and 2W below. With regard to
item 2, the Company’s forecasted system shortfall in the summer in year nine is expected to continue to
grow through the end of the twenty-year IRP forecast; however, the value in year nine already exceeds
the Company’s peak Idaho load, and modification to the QF purchase obligation would be necessary
well before the year nine capacity shortfall level was reached.

1 See In the Matter of Commission Staff’s Application to Alter the Filing Date of the Capacity Deficiency Case. Case No.
GNR-E-23-01

Idaho Public Utilities Commission
July 12, 2023
Page 3

Table No. 1W
2021 IRP Update - Winter Peak Loads and Resources without Additions

Table No. 2W
Updated Winter Peak Loads and Resources

The Company appreciates the Commission’s consideration of this proposal. Informal questions related
to this matter may be directed to Mark Alder at [phone].

Sincerely,

Joelle Steward
Senior Vice President of Regulation and Customer/Community Solutions

Calendar Year 2023 2024 2025 2026 2027 2028 2029 2030 2031
System
Total Resources 9,061 8,651 8,730 7,899 7,900 7,358 7,386 7,142 6,809
Obligation 8,672 8,644 8,703 8,663 8,662 8,703 8,939 8,989 9,033
Planning Reserves (13%)1,127 1,124 1,131 1,126 1,126 1,131 1,162 1,169 1,174
Obligation + Reserves 9,800 9,767 9,834 9,789 9,788 9,835 10,101 10,157 10,207
System Position (739) (1,117) (1,104) (1,890) (1,889) (2,477) (2,716) (3,016) (3,398)
Available FOTs 1,030 1,030 1,030 1,030 1,030 1,030 1,030 1,030 1,030
Net Surplus/(Deficit)0 (87) (74) (860) (859) (1,447) (1,686) (1,986) (2,368)
Calendar Year 2023 2024 2025 2026 2027 2028 2029 2030 2031
System
Sufficiency/Deficiency Position 0 (87) (74) (860) (859) (1,447) (1,686) (1,986) (2,368)
+Uncommitted Coal Retirements 0 0 0 550 550 582 699 699 699
+Signed Contracts & 2020 All-Source RFP 7 55 889 758 760 883 832 782 576
+2021 Demand Response RFP 165 220 276 305 323 353 294 284 272
Updated Position Before FOTs 172 189 1,090 754 775 372 139 (221) (821)
+Committed FOTs 232 0 0 0 0 0 0 0 0
+Remaining FOTs (up to 2021 IRP Limit)798 1,030 1,030 1,030 1,030 1,030 1,030 1,030 1,030
Sufficiency/(Deficiency)1,202 1,219 2,120 1,784 1,805 1,402 1,169 809 209