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Home My WebLink About20101129IPC to NIPPC 1-4.pdfÆ;IDA~POR~ An IDACORP Company DONOVAN E. WALKER Senior Counsel dwalkertiidahopower.com November 29,2010 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilties Commission 472 West Washington Street P.O. Box 83720 Boise, Idaho 83720-0074 Re: Case No. GNR-E-10-04 IN THE MATTER OF THE JOINT PETITION OF IDAHO POWER COMPANY, AVISTA CORPORA TlON, AND ROCKY MOUNTAIN POWER TO ADDRESS AVOIDED COST ISSUES AND JOINT MOTION TO ADJUST THE PUBLISHED A VOIDED COST RA TE ELIGIBILITY CAP Dear Ms. Jewell: Enclosed for filng please find an original and three (3) copies of Idaho Power Company's Response to the First Production Request of the Northwest and Intermountain Power Producers Coalition to Joint Utilties in the above matter. Also enclosed are four (4) copies of a non-confidential disk containing documents being produced in response to the production requests. ¿v/ onovan E. Walker -- DEW:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, 10 83707 DONOVAN E. WALKER (ISB No. 5921) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalkercmidahopower.com Inordstromcmidahopower.com Attorneys for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 ~ r: t=~oç~r:,,\,"_.C'- LûlU NOV 29 PM 2: \\ BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE JOINT PETITION OF IDAHO POWER COMPANY, AVISTA CORPORATION, AND ROCKY MOUNTAIN POWER TO ADDRESS AVOIDED COST ISSUES AND JOINT MOTION TO ADJUST THE PUBLISHED AVOIDED COST RATE ELIGIBILITY CAP. ) ) CASE NO. GNR-E-10-Q4 ) ) IDAHO POWER COMPANY'S ) RESPONSE TO THE FIRST ) PRODUCTION REQUEST OF THE ) NORTHWEST AND ) INTERMOUNTAIN POWER ) PRODUCERS COALITION TO JOINT ) UTILITIES ) COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in response to the First Production Request of the Northwest and Intermountain Power Producers Coalition to Joint Utilties dated November 8, 2010, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 1 REQUEST NO.1: Reference Joint Petition and Joint Motion, at p. 7, stating Idaho Power is experiencing an "influx of requests for contracts" which are occurring on a "nearly daily basis." Please provide documentation and evidence supporting these claims for requests initiated in the past month. RESPONSE TO REQUEST NO.1: The quoted language in the Northwest and Intermountain Power Producers Coalition's ("NIPPC") Production Request NO.1 from page 7 of the Joint Petition is taken out of context. The entire passage is as follows: As the Commission is well aware, in the past, when the Commission has investigated and examined avoided cost rates and issues, there occurs a "race" to the door of the utilties with projects attempting to position themselves for a claim to "grandfathering" and entitlement to the previously effective rates, terms, conditions, etc. Idaho Power continues to get such requests from projects on a nearly daily basis. In fact, one of the driving forces behind the Parties' requests in this case is just such an influx of requests for contracts. Idaho Power has seen a steadily increasing number of PURPA project inquiries and requests since late 2009. These inquiries come in various forms, many of them being telephone contact to discuss the process and options and other inquiries in the form of written inquires or requests. After the initial inquiries, many projects do not continue the process. Other inquiring parties are silent for quite some time then reappear later with more serious inquiries. Stil other parties move very quickly from inquiry to purchase power contract requests. Since late 2009, Idaho Power has seen a steady increase in the number of inquires and requests for various PURPA contracts. Some of those requests have resulted in signed PURPA contracts. Many of the inquiries and requests have not yet resulted in executed PURPA contracts; however, the parties continue to contact Idaho Power on contract, interconnection, transmission, IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 2 or other issues related to taking their proposal from inquiry to contract. Currently, Idaho Power has approximately 726 megawatts ("MW") of inquiries or requests for PURPA contracts that are mature enough in the process to be tracked. Of those, there is approximately 621 MW of wind projects (including the recently executed wind contractsi for Cold Springs, Two Ponds, Ryegrass, Mainline, Desert Meadows, and Hammett Hil), 80 MW of solar projects, and 25 MW of other resource types. Please see the attached list (with the confidential information redacted) of these projects. In addition to the numerous informal and ongoing inquiries, from October 2010 to mid-November 2010, Idaho Power received inquiries and requests for PURPA contracts totaling approximately 270 MW from 12 projects. These inquiries and requests are shown on the attached list. After the last change in the published avoided cost rate by the Idaho Public Utilties Commission in March of 2010, Idaho Power received frequent and numerous calls, contacts, and inquiries from those projects that had pending requests for contracts somewhere in the system. This resulted in the filng of seven cases seeking a grandfathered rate, one of which, Case No. IPC-E-10-11 - AgPower Jerome, is stil pending. Additionally, subsequent to the filing of this case, GNR-E-10- 04, on Friday November 5,2010, by Monday, November 8,2010, there were 8 formal Complaints filed against Idaho Power, four Petitions to Intervene, and two Answers in Opposition of the Petition filed with the Commission. There have been four more Petitions to Intervene and one more Answer in Opposition filed since. The response to this Request was prepared by Randy C. Allphin, Senior Energy Contract Coordinator, Idaho Power Company, in consultation with Donovan E. Walker, Senior Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 3 REQUEST NO.2: Reference Joint Petition and Joint Motion, at p. 4, stating Idaho Power has over 570 MW of new wind contract requests. a. Please provide a list of all such requests, including the name of the requesting entity, nameplate capacity of the wind project, point of initial contact with Idaho Power, and date and nature of the last communication between the parties. b. For each requesting entity, please provide supporting evidence that the project is stil being pursued. Such evidence may include a recent correspondence from the requesting entity requesting a contract. c. If the documents and information requested in items (a) and (b) are unavailable, please explain the basis for assertion regarding 570 MW of new wind contract requests. RESPONSE TO REQUEST NO.2: a. Please see the attachment provided in the Company's Response to NIPPC's Production Request No. 1 which shows the nameplate capacity and approximate date of contact for the tracked requests for PURPA contracts currently pending at Idaho Power. Since the date of this filng, the 570 MW value from page 4 of the Joint Petition has now grown to 621 MW. The name of the requesting entity and correspondence between Idaho Power and the proposed wind projects is confidential information between Idaho Power and each of those individual parties. b. Since the filng of the Joint Petition on November 5, 2010, five PURPA contracts totaling 120 MW of the 570 MW referenced on page 4 of the Joint Petition have now been executed and filed with the Commission for approvaL. Case Nos. IPC- E-10-38, IPC-E-10-39, IPC-E-10-40, IPC-E-10-41, IPC-E-10-42, and IPC-E-10-43. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 4 In addition, please see the "Generation Interconnection Queue" spreadsheet included on the enclosed CD. This spreadsheet is a publically available data page from the Idaho Power OASIS site. It shows that PURPA wind projects have outstanding interconnection requests totaling 536 MW. Additionally, a 177 MW project identified as a NRIER project is believed to be a single interconnection request by a party that has now proposed to divide this single non-PURPA project into five smaller separate PURPA projects. This information shows that there are at least 713 MW of PURPA wind projects active in Idaho Powets interconnection queue, which Idaho Power views as evidence that the projects are stil being pursued. c. Not applicable. The response to this Request was prepared by Randy C Allphin, Senior Energy Contract Coordinator, Idaho Power Company, in consultation with Donovan E. Walker, Senior Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 5 REQUEST NO.3: Reference Joint Petition and Joint Motion, at p. 4, stating Rocky Mountain Power has 358 MW of new wind contract requests. a. Please provide a list of all such requests, including the name of the requesting entity, nameplate capacity of the wind project, point of initial contact with Rocky Mountain Power, and date and nature of the last communication between the parties. b. For each requesting entity, please provide supporting evidence that the project is stil being pursued. Such evidence may include a recent correspondence from the requesting entity requesting a contract. c. If the documents and information requested in items (a) and (b) are unavailable, please explain the basis for assertion regarding 358 MW of new wind contract requests. RESPONSE TO REQUEST NO.3: This information is not available to Idaho Power. Please see Rocky Mountain Powets response to NIPPC's Production Request NO.3. The response to this Request was prepared by Randy C Allphin, Senior Energy Contract Coordinator, Idaho Power Company, in consultation with Donovan E. Walker, Senior Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 6 REQUEST NO.4: Reference Joint Petition and Joint Motion Attachment NO.1. a. Please provide, in electronic format where possible, all work papers, spreadsheets, and data used in the generation of this chart. b. Please state the name of the person who can sponsor this attachment at a hearing. RESPONSE TO REQUEST NO.4: a. Please see the Excel file included on the enclosed CD which contains the input data for the graph that was attached to the Joint Petition. In review of this information, three insignificant errors in the PURPA non-wind projects data were discovered. The first graph included in the Excel file is a copy of the graph as filed with the Joint Petition. The second graph included in the Excel file is a corrected graph with the three corrections, highlighted in yellow. b. Randy C. Allphin. The response to this Request was prepared by Randy C. Allphin, Senior Energy Contract Coordinator, Idaho Power Company, in consultation with Donovan E. Walker, Senior Counsel, Idaho Power Company. DATED at Boise, Idaho, this 29th day of November 2010./) r7 fJ ~ALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 29th day of November 2010 I served a true and correct copy of the IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Scott Woodbury Deputy Attorney General Idaho Public Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Avista Corporation Michael Andrea Clint Kalich Avista Corporation 1411 East Mission Avenue - MSC-23 P.O. Box 3727 Spokane, Washington 99220-3727 Rocky Mountain Power d/b/a PacifiCorp Daniel E. Solander J. Ted Weston Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Bruce Griswold PacifiCorp 825 NE Multnomah Portland, Oregon 97232 Exergy, Grand View Solar, J. R. Simplot, & Northwest and Intermountain Power Producers Coalition Peter J. Richardson Greg Adams RICHARDSON & O'LEARY, PLLC 515 North 2th Street P.O. Box 7218 Boise, Idaho 83702 .lHand Delivered U.S. Mail _ Overnight Mail FAX ~ Email scott.woodburycmpuc.idaho.gov Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email michael.andreacmavistacorp.com clint. kalich(ëavistacorp. com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email daniel.solander(ëpacificorp.com ted. weston(ëpacificorp.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email bruce.griswold(ëpacifiCorp.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email peter(ërichardsonandoleary.com greg(ërichardsonandoleary.com IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 8 Exergy Development Group James Carkulis, Managing Member Exergy Development Group of Idaho, LLC 802 West Bannock Street, Suite 1200 Boise, Idaho 83702 Grand View Solar II Robert A. Paul 15960 Vista Circle Desert Hot Springs, California 94221 J.R. Simplot Company Don Sturtevant, Energy Director J.R. Simplot Company One Capital Center 999 Main Street, P.O. Box 27 Boise, Idaho 83707-0027 Northwest and Intermountain Power Producers Coalition Robert D. Kahn, Executive Director Northwest and Intermountain Power Producers Coalition 1117 Minor Avenue, Suite 300 Seattle, Washington 98101 Renewable Energy Coalition Thomas H. Nelson Renewable Energy Coalition P.O. Box 1211 Welches, Oregon 97067-1211 John R. Lowe Renewable Energy Coalition 12050 SW Tremont Street Portland, Oregon 97225 Cedar Creek Wind, LLC Ronald L. Willams WILLIAMS BRADBURY, P.C. 1015 West Hays Street Boise, Idaho 83702 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email jcarkulis(ëexergydevelopment.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email robertapaul(ëgmail.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email don.sturtevant(ësimplot.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email rkahn(ënippc.org Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email nelson(ëthnelson.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email jravenesanmarcos(ëyahoo.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email ron(ëwiliamsbradbury.com IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 9 Scott Montgomery, President Cedar Creek Wind, LLC 668 Rockwood Drive North Salt Lake, Utah 84054 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email scott(ëwesternenergy.us Dana Zentz, Vice President Summit Power Group, Inc. 2006 East Westminster Spokane, Washington 99223 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email dzentz(ësummitpower.com Idaho Windfarms, LLC Glenn Ikemoto Margaret Rueger Idaho Windfarms, LLC 672 Blair Avenue Piedmont, California 94611 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email glenni(ëEnvisionWind.com Margaret(ëEnvisionWind .com Interconnect Solar Development, LLC R. Greg Ferney MIMURA LAW OFFICES, PLLC 2176 East Franklin Road, Suite 120 Meridian, Idaho 83642 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email greg(ëmimuralaw.com Bil Piske, Manager Interconnect Solar Development, LLC 1303 East Carter Boise, Idaho 83706 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email billpiske(ëcableone.net Milk Producers of Idaho J. Brent Olmstead, Director Milk Producers of Idaho P.O. Box 2751 Boise, Idaho 83701 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email brent(ëmpidaho.com ~.#cV Donovan E. Walker IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES -10 BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION CASE NO. GNR-E-10-04 IDAHO POWER COMPANY RESPONSE TO NIPPC'S PRODUCTION REQUEST NO.1 Idaho Power Company Proposed PURPA Projects Resource type Project Name MW Nameplate Project location Approximate contact date Wind Project 1 20.0 10 Jul-10 Wind Project 2 20.0 10 Jul-10 Wind Project 3 20.0 10 Jul-10 Wind Project 4 20.0 10 Jul-10 Wind Project 5 20.0 10 Jul-10 Wind Project 6 20.0 10 Jul-10 Wind Project 7 30.0 UT May-10 Wind Project 8 21.0 UT May-10 Wind Project 9 19.0 WY Oct-10 Wind Project 10 19.0 WY Oct-10 Wind Project 11 20.0 10 Aug-10 Wind Project 12 20.0 10 Aug-10 Wind Project 13 20.0 10 Aug-10 Wind Project 14 20.0 10 Nov-10 Wind Project 15 20.0 10 Nov-10 Wind Project 16 20.0 10 Mar-10 Wind Project 17 20.0 10 Mar-10 Wind Project 18 20.0 10 Mar-10 Wind Project 19 20.0 10 Mar-10 Wind Project 20 40.0 10 Jul-10 Wind Project 21 33.0 MT Aug-10 Wind Project 22 30.0 10 Nov-10 Wind Project 23 30.0 10 Nov-10 Wind Project 24 28.0 10 Nov-10 Wind Project 25 30.0 10 Nov-10 Wind Project 26 30.0 10 Nov-10 Wind Project 27 8.0 10 Sep-10 Wind Project 28 3.0 OR Jun-09 621.0 Solar Project 29 20.0 10 Oct-10 Solar Project 30 20.0 10 Oct-10 Solar Project 31 10.0 10 Jul-10 Solar Project 32 10.0 10 Jul-10 Solar Project 33 10.0 10 Jul-10 Solar Project 34 10.0 10 Jul-10 80.0 Biomass Project 35 3.2 10 Jan-09 Biomass Project 36 10.0 10 Jun-09 Hydro Project 37 7.7 10 Jun-10 Hydro Project 38 0.5 10 Jun-09 Hydro Project 39 3.6 10 Oct-10 25.0 Total 726.0