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HomeMy WebLinkAbout20240603Staff 1-6 to IPC.pdf RECEIVED Monday, June 3, 2024 12:17:23 PM IDAHO PUBLIC UTILITIES COMMISSION ADAM TRIPLETT DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334- 0318 IDAHO BAR NO. 10221 Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-20 APPROVAL OF THE FIRST AMENDMENT ) TO THE POWER PURCHASE AGREEMENT ) WITH PVS 2, LLC ) FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY Staff of the Idaho Public Utilities Commission,by and through its attorney of record, Adam Triplett, Deputy Attorney General, requests that Idaho Power Company("Company") provide the following documents and information as soon as possible, but no later than MONDAY,JUNE 244 2024. This Production Request is to be considered as continuing, and the Company is requested to provide,by way of supplementary responses, additional documents that it, or any person acting on its behalf, may later obtain that will augment the documents or information produced. Please provide answers to each question, supporting workpapers that provide detail or are the source of information used in calculations, and the name,job title, and telephone number of the person preparing the documents. Please also identify the name,job title, location, and telephone number of the record holder. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 JUNE 3, 2024 In addition to the written copies provided as response to the requests,please provide all Excel spreadsheets and electronic files with formulas intact and enabled. REQUEST NO. 1: The Application states that compared to the original Scheduled Commercial Operation Date of December 31, 2026, the proposed Scheduled Commercial Operation Date of May 31, 2026, "better aligns the new generation with Brisbie's anticipated load and Idaho Power's anticipated 2026 summer peak load." Application at 2. Please respond to the following: a. Please provide evidence supporting the Company's assertion that the proposed Scheduled Commercial Operation Date better aligns the new generation with Brisbie's anticipated load, compared to the original Scheduled Commercial Operation Date; b. What are the impacts if the capacity of PVS 2 comes online before Brisbie's load materializes and how will the Company mitigate the impacts? Please include, but not limit the explanation to: (i.) the amount of excess generation credits; (ii.) how compliance of the 110% annual energy limit in Schedule 62 will be affected; (iii.) the feasibility of curtailing PVS 2 generation to match Brisbie's load ramp, etc.; and c. What are the impacts if the capacity of PVS 2 comes online after Brisbie's load materializes? Please include, but not limit the explanation to: (i.) the sufficiency of system capacity to meet system load with Brisbie's load included; (ii.) the accuracy of Brisbie's rates for supplemental energy and demand charges due to the higher loads the Company must meet with its system resources, etc. REQUEST NO. 2: The Application states that the proposed Scheduled Commercial Operation Date of May 31, 2026, better aligns the new generation with Idaho Power's anticipated 2026 summer peak load. Please respond to the following: a. Please provide the expected amount of excess capacity of PVS 2 that can contribute to meeting the anticipated 2026 summer peak load; b. Please explain whether the proposed Scheduled Commercial Operation Date will lower the Company's summer capacity need of 2026 for other projects; and FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 JUNE 3, 2024 c. If so, does the Company plan to change the scheduled commercial operation dates of other 2026 projects? REQUEST NO. 3: Please explain whether there is a possibility that Brisbie's load grows ahead of May 31, 2026. If so, please explain whether the Company has enough resources to meet Brisbie's load. REQUEST NO. 4: Schedule 62 requires that customers pursuing the Construction option limit requests to size the Renewable Energy Facilities to 110 percent of the participating service point annual energy amounts. Please provide evidence supporting that the capacity size of PVS 2 meets this requirement. REQUEST NO. 5: Page numbers of First Amendment to the Power Purchase Agreement("First Amendment") show 3 pages. However, only 2 pages were filed with the Commission. Please file a complete First Amendment, if the third page is missing. REQUEST NO. 6: Page 2 of First Amendment states that"IN WITNESS WHEREOF, the Parties hereto have caused this Second Amendment to duly executed as of the date above written." Please confirm whether"Second Amendment" should have been "First Amendment". Idaho this day of June 2024. DATED at Boise, � y Adam Triplett Deputy Attorney General I:\Utility\UMISC\PRDREQ\IPC-E-24-20 PR#Ldocx FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 JUNE 3, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS DAY OF JUNE 2024, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-24-20, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING: DONOVAN E WALKER ENERGY CONTRACTS MEGAN GOICOECHEA ALLEN IDAHO POWER COMPANY IDAHO POWER COMPANY PO BOX 70 PO BOX 70 BOISE ID 83707-0070 BOISE ID 83707-0070 E-MAIL: energycontracts@idahopower.com E-MAIL: dwalkerAidahopower.com mgoicoecheaal len(cidahopower.coin dockets@idahopower.com PATRICIA JORDAN" SECRETARY CERTIFICATE OF SERVICE