Apparently, folks love them threads on utility dockets. So here is another one you might have missed you beautiful energy nerds: The issue of self-commitment coal has gone west and comes up in this PacifiCorp case in CA!
(Docket No. A.19-08-002)
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(Docket No. A.19-08-002)
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The @SierraClub hired @StrategenNews to review the fuel cost recovery request from PacifiCorp. Now I'm not that familiar with the rules of the wild west but so far as I can tell this isn't much different than a regulated fuel cost recover docket for an IOU in a reg state... 2/
Quick lay of the land: Several coal plants have FUEL costs over $25/MWh (Cholla, Jim Bridger, and Naughton). That's even before you start taking on enviro controls! For comparison, mrk purchases are about $25, Pacificorp's gas plants cost about $20/MWh, and wind: $17/MWh! 3/ 
@eburgess of Strategen does a good job of explaining Pacificorp wouldn't have to replace every MW of coal with a MW of wind, but that current economics mean that replacing some of those MWh's will translate into reduced costs. 4/
Love that Ed also points out that PacifCorp's most expensive coal plant has the highest capacity factor. I can't remember, but is that how merit order is supposed to work? 5/
The testimony also brings up an important issue of how PacifiCorp is operating in the CAISO EIM; The testimony indicates that the company may be artificially lowering its bid to the EIM which translates to over-generation of Coal. 6/
This testimony also does the best job of documenting and walking through the disconnect between how the utility seems to take on different accounting practices in different settings which produces some unintuitive results (like overgeneration of coal). 7/
But by far, my favorite part is the recommendation that since the cost recovery docket only allows for the recovery of variable costs and the fact that the utility is treating some fuel costs as fixed means they shouldn't be able to recover the costs. Brilliant. 8/
Anyways a lot in there is redacted and the case but it isn't the specific numbers that makes this so exciting it is the notion that this issue is expanding into new regions. 9/
Uneconomic commitment practices were easy to document in the ISO/RTOs b/c the data was readily available, that doesn't mean it isn't happening in non-RTO states. This reaffirms the need for experts in those proceedings where the data (system lambdas) aren't general public. 10/10
p.s. Probably worth noting that in a recent GRC decision California signaled that it wants PacifiCorp to retire all its coal plants...
