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Home My WebLink About20101222NIPPC 13-22 to Joint Utilities.pdfPeter J. Richardson (ISB # 3195) Gregory M. Adams (ISB # 7454) Richardson & O'Lear, PLLC 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peterigrichardsonandolear.com gregigrichardsonandolear.com RECE!V ZOlODEC 22 PM 2= 45 Attorneys for Nortwest and Intermountan Power Producers Coalition 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-1O-04 ) )) THIR PRODUCTION REQUEST OF THE NORTHWEST AND ~ INTERMOUNTAIN POWER ) PRODUCERS COALITION TO THE ) JOINT UTILITIES ) ) ) Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utìlties Commssion (the "Commssion"), the Northwest and Intermountain Power Producers Coalition ("NIPPC") hereby requests that Idaho Power Company ("Idaho Power"), Rocky Mountan Power, and Avista Corporation (collectively the "Joint Utilities") provide responses to the followig with supporting documents, where applicable. Because the subject matter of these requests is relevant to Joint Utìlties' Joint Motion for expedited Commission determination of the eligibìlty cap for published avoided cost rates, NIPPC requests expedited processing of these production requests. Page 1- THI PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAI POWER PRODUCERS COALITION - GNR-E-10-04 This production request is to be considered as continuing, and the Joint Utìlties are requested to provide by way of supplementary responses additional documents that they or any person acting on their behalf may later obtain that will augment the responses or documents produced. Please provide one physical copy and electronic copies, if available, of your anSWer to Mr. Richardson and Mr. Adams at the address noted above. For each item, please indicate the name of the person(s) preparng the answers, along with the job title of such person(s) and the witness at hearng who can sponsor the answer. Some of the following requests may include disclosures deemed by the Joint Utilities to be confidentiaL. Counsel for NIPPC is prepared to sign any such agreement to obtain the materials relevant to this proceeding, and expects that executing such a confidentiality agreement will not delay the responses to these Requests for Production. Page 2 - THIR PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-1 0-04 REQlJSTFOR PRODUCTION NO. 13 Reference Avista's Intial Comments, page 3 (stating "Avista is now receiving proposals for utility scale projects" under PURP A). (a) Please admit or deny that Avista has submitted no evidence in this docket supporting tIDSclai. (b) If Avista's response in (a) is to deny, please explain what evidence in the record supports ths clai. (c) Please define "utìlty scale." REQUEST FOR PRODUCTION NO. 14 Reference Avista's Initial Comments, page 5 (stating "Today's published rates have attacted 450 MW of new development to Avista's system; 90% was received over the past year, and nearly half over the past 3 months"). (a) Please admt or deny that Avista has submitted no evidence in tIDS docket supporting this claim. Please explain. (b) Please adit or deny that Avista has not entered into any PURP A PP As in the time frame referenced. (c) If Avista's response in (b) is to deny, please provide a copy of the PPA and identify the IPUC case number where Avista sought approval. (d) If Avista's response in (b) is to admit, please explain why none of the 350 MWof requested PUR A PPAs were executed. (d) Please admit or deny that prior to fiing of Avista's Intial Comments on December 22, 2010, Avista and/or the Joint Utilities had not specified in a fiing in this docket any amount of PURPA development requests to Avista in the last year. REQUEST FOR PRODUCTION NO. J5 Reference A vista's Initial Comments, page 5 (stating that the published avoided cost rates are $15/MWh higher than Avista's avoided costs). (a) Does Avista believe ths is an accurate estimate of the value of the capacity not provided by wind projects? (b) Please identify the pleading and Case number where the Joint Utilities "proposed recently" that the Commission adopt this $15/MWh capacity reduction. Page 3 - THIR PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-1O-04 (c) Would tIDS capacity reduction of $151MWh include wind integration, or would the utìlties also reduce the avoided costs paid to wind QFs by wind integration in addition to the $151MWh capacity reduction. (d) Does Avista believe that $151MWh is an accurte estimate of the value ofRECs? Please provide supporting evidence. REQUEST FOR PRODUCTION NO. 16 Reference Avista's Initial Comments, page 6 (stating Avista canot guarantee system reliabìlty at the levels of PURP A project output being offered). (a) Please explain the level of wid output (nameplate MW) Avista believeS it could safely integrate with existing resources. (b) Please explai the level of wid output A vista believes would require it to obtan new generating resources. Please identify the tye and amount (nameplate MW) of resources needed at varying wind penetration levels (nameplate MWs). (c) Please identify the page number(s) in Avista's most recent wid integration study supporting the levels cited in (a) and (b). Ifnone is available, please explain the basis for the levels asserted in (a) and (b), and provide any supporting work papers or other evidence. REQUEST FOR PRODUCTION NO. 17 Reference Avista's Initial Comments, page 6 (stating that projects above 100 kw can negotiate contract rates). This question is directed at all three utilities individually. NIPPC requests that Idaho Power, RMP, and Avista each provide separate answers to this request. (a) Please identify each PURPA PPA contaning negotiated rates entered into in the last five years, including the case number for Commssion approval of the PP A. (b) Please identify and explain and document the average lengt of time of negotiation from initial contact to final executed PPA for each PPA listed in response to (a). (c) Please explain how many QF requests for PPAs contaning negotiated rates have not resulted in an executed PP A during that same time period. (d) Please identify all wind QF PP As that were executed durng the period of the reduction in the eligibility cap to 100 kw in Case No. IPC-E-05-22. Page 4 - THIR PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAI POWER PRODUCERS COALITION - GNR-E-10-04 REQUEST FOR PRODUCTION NO. 18 Reference Avista's Initial Comments, page 7 (stating that non-wind projects have the ability to "break their facìlties into smaller pieces with the express intent of obtaning a rate that in many cases will not equa avoided costs"). (a) Please explai how the following resources would break their facìlties into smaller pieces, as described in the fiing: (i) small hydropower, (ii) biomass, (iii), co-generation, (iv) anaerobic digester, (v) solar. Does Avista believe these pieces oflarger facìlties for each of these resource tyes could have generation equipment separated by one mile yet remain finacially viable? Please provide examples of projects that have done so or other evidence supportng the claim that any of these resources could do so. (b) If none of these resources listed in (a) could be split into smaller pieces separated by one mile, please explain what non-wind QF resources could do so and explain how. REQUEST FOR PRODUCTION NO. 19 Reference Avista's Initial Comments, page 7 (stating that QF resources do not provide capacity). (a) Pleae explain how much Avista would pay to a QF for capacity though the curent published rates. (b) Please explai whether Avista's curent published rates would compensate a QF at times when it is not delivering en.ergy. (c) Does Avista provide capacity payments to any QFs at times when no energy is delivered? Please explain. (d) In the past five years, has Avist made capacity payments to any generation resources owned by independent producers at times when no energy is delivered? If yes, pleae provide the contract under which such payments were made. (e) Please provide the Lancaster Plant agreement effective Janua 1, 2010, referenced in Direct Testiony of Randy Lobb, Commission Sta, Cas Nos. AVU-E-09-1 and A VU-G-09-1, pp.l7-18 (May 29,2009). (t) Are the cost estimates to ratepayers for the Lancaster plant agreement in that case stil accurate? If not please provide updated estimates with supporting work papers. Reference Direct Testimony of Randy Lobb, Case Nos. A VU-E-09-1 and AVU-G-09-1, at p. 22 (estimating 2010 fixed costs of $20.87 per MWh, and a projected generation cost raige of from $58 to $72 per MWh). REQUEST FOR PRODUCTION NO. 20 Page 5 - THIR PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR.E-10-04 Reference Avista's Initial Comments, footnote 3 (stating Avista is concered about non-wind varable resources for which the wind integration charge would not apply). (a) Please identify the resource tye(s) that would be non-wind and impose integration costs on Avista's system. (b) Please provide supporting evidence for Avist's concern regarding ths resource type(s), such as requests or inquiries for PUR A PP As from developers of such resource types in the last year. REQUEST FOR PRODUCTION NO. 21 Reference Avista's Initial Comments, page 9 (stating tht QF wind projects taing the published rates will force ratepayers to pay higher rates than they would for similar projects built by utìlties ). (a) Please explain the constrction status of Avista's Reardon wid far. Will the project be online in 2012 as projected in the most recent IRP? When will the project be online, and what will its nameplate capacity be at that time. (b) If the Reardon project will not aCIDeve the online date projected in the IRP, will Avista'.s customers incur damages? Please estimate those damages and explain the basis for the estimate. Does A vista believe that $45/kw is an accurate estimate of potential daages? If so, wil Avista issue a ratepayer refund.in that amount? (b) Please provide an accounting of the amounts A vista has spent on the project to date. (c) Please explain the amount A vista will charge to its ratepayers for the Reardon project. (d) Please provide a cost estimate (of$IMWh) to ratepayers for the future output of this project. Please provide supporting work papers. (e) Please explain whether Avista selected the Reardon project in an RFP. If the RFP included a PP A template, please provide it. Did the ipUC approve the RFP? Please explain. Has the IPUC authorized any activity related to Reardon? Please explain. REOUEST FOR PRODUCTION NO. 22 If A vista is permitted to negotiate the avoided cost rate with QFs larger than 100 kw, what role will the curent SAR methodology play in determining that rate? Sincerely yours,~~~p~~ Greg Adams RICHARSON & O'LEARY, PLLC Page 6 - THIRD PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAIN POWER PRODUCERS COALITION - GNR~E-1 0-04 CERTIFICATE OF SERVICE I HEREBY CERTIFY tht on the~ay of December, 2010, a tre.and correct copy of the within and foregoing THIR PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES was served by ELECTRONIC MA and US MAIL, to: DonovanE.Walker Danel E. Solander Lisa Nordstrom Rocky Mountan Power Idaho Power Company 201 South Main 1221 West Idaho Street Salt Lake City, UT 84111 Boise, Idaho 83707-0070 Daniel.solanderafacificorp.com dwalkerigidaopower.com Inordstromigidahop9wer.com Michael G. Andrea Jean Jewell A vista Corporation Commission Secreta 1411 East Mission Avenue -- MSC-23 Idaho Public Utilities Commission Spokane, W A 99202 472 West Washigton Michael.andreaigavistacorp.com Boise, Idaho 83702 Jean. jewelltmPuc.idaho. gov Don Stuevant Scott Montgomery Energy Director President, Cedar Creek Wind, LLC J. R. Simplot Company 668 Rockwood Drive ONE CAPITAL CENTER Nort Salt Lake, Utah 84054 999 Mai Street, P.O. Box 27 scottigwestemenergy. us Boise, Idaho 83707-0027 Don.sturevant(ásimnlot.com Ronad L.Wiliams Dana Zentz Wiliams Bradbur,P.C.Vice President,Sumit Power Group, Inc. 1015 W. Hays St.2006 E. Westminster Boise ID,83702 Spokane, W A 99223 ron($willamsbradbury.com dzentz($summitpower.com Scott Woodbur Robert A. Paul Idaho Public Utilities Commssion Grand View Solar 472W.Washington (zip: 83702)15960 Vista Circle P.O. Box 83720 Desert Hot Springs, CA Boise, ID 83720-0074 robertpaul($gmail.com Scott. Woodburigipuc.idaho. gov Page 7 -- THI PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION -- GNR.E-1 0-04 Thomas H. Nelson James Carkulis Renewable Energy Coalition Managing Member PO Box 1211 EXERGY DEVELOPMENT GROUP OF Welches, OR 97067 IDAHO,LLC nelson~thnelson.com 802 West Banock Street, Ste.1200 Boise, Idaho 83702 jcarkulis(ßexergydevelopment.com , Glenn Ikemoto R. Greg Ferney Margaret Rueger Mimur Law Offces, PLLC Idaho Windfars, LLC 2176 E. Franin Rd., Suite 120 glenni~Envision Wind. com Meridian, ID 83642 MargaretúùEnvision Wind. com gregúùmimuralaw.com Bil Piske, Manager Dean J. Miler, Esq. Interconnect Solar Development, LLC McDEVITT & MILLER LLP 1303 E. Carer P.O. BOX 2564-83701 Boise, ID 83706 Boise, Idaho 83702 bilpiske(icab leone.net ioe(ßmcdevitt -miler.com Paul Marin Intermountain Wind LLC P.O. Box 353 Boulder, Colorado oaulmarinúùintermountainwind.com By: .~ W\1i\. Nina Curis Page 8 - THI PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-10-04