20110121NIPPC 55-66 to Joint Utilities.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson & O'Lear, PLLC
S15 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~chardsonmolea.com
gregtScbnanolear.com
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Attorneys for Nortwest and Interounta
Power Producers Coalition
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION )
OF IDAHO POWER COMPANY, AVISTA ) CASE NO. GNR..E-IOo.4
CORPORATION AND ROCKY MOUNTAIN )
POWER TO AaDRESS AVOIDED COSTj FIFTH PRODUCTION REQUEST OF
ISSUES AN JOINT MOTION TO ADJUST THE NORTHWEST AN
THE PUBLISHED AVOIDED COST RATE j INTERMOUNTAI POWER
ELIGIBILITY CAP ) PRODUCERS COALITION TO THE
) JOINT UTILITIES
)
)
)
Pusuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilties Commsion
(the "Commission"), the Nortwest and Intermountan Power Producers Coalition ("NIPPC")
herebyreuests that Idao Power Company ("Idao Power"), Rocky Mountai Power, and
A vista Cotpration (collectively the "Joint Utilities") provide responses to the followig with
support documents, where applicable. Please refer to NIPPC's prior Procluction Requests for
instrctions and definitions applicable to this production request.
Page 1 .. FIFH PROI)UC'lION REQUEST OF THE NORTHWST AN INTERMOUNAIN
POWER PRODUCERS COALITION - GNR-E-l 0-'04
REQUEST FOR PRODUCTION NO. 55
Reference Dir. Test. of Bruce Griswold, p. 3, lines 7-9. Please provide supportng
documentation, with identities redacted to protect confdentiality, of the "alterntive ,offers which
Rocky Mountan Power receives." For each provided offer, please identify whether Rocky
Mountan Power received the offer though the RFP process or the IRP Methodology. Pleae
also identify the location of the offer, and costs necessa to tranmit the power to loadsfor
which Rocky Mounta Power would otherwse serve with the Idaho QF projects discussed on
page 8, lines 11-18. If Rocky Mountain Power objects to providing a response to any component
of ths request due to confidentiality concerns despite the protective agreement in this case,
please stil respond to the remaining components of the request.
REQUEST FOR PRODUCTION NO. 56
Reference Dir. Test. of Bruce Griswold, p. 3, lines 13-14.
(a) Please provide the most curent documents or studies regarding the maximum level of
wind penetration Rocky Mountai Power can integrate. Please include explanion of the
maximum number of megawatt Rocky Mountain Power can integrte.
(b) Please provide or identif with a website link, Rocky Mountan Power' smost recent
wid integration study approved by the Idaho Commssion.
(c) Please identify the upper limit of the level of wid penetration allowed for in your wind
integration study indentified in (b) of ths request.
REQUEST FOR PRODUCTION NO. 57
Reference Dir. Test. of Bruce Grswold, p. 4, lines 13-14. What was the size (nameplate MW) of
the single wid project bid into the RFP before the developer applied for two 21.8 MW QF
PPAs?
REQUEST FOR PRODUCTION NO. 58
Reference Dir. Test. of Bruce Grswold, p. 5, lines 2-4: What was the unsuccessfu price bid into
the RFP for a 151 MW project? What was the price provided for two 78 MW QFs though the
IRP Methodology? How does the IRP Methodology price compare to the winnngbicl price in
the RFP? If Rocky Mounta Power objects to providig a response to any component of this
request due to confidentiality concern despite the protective agreement in ths case, please stll
respond to the remaing components of the request.
Page 2,. FIFTH PRQPUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAI
POWER PRODUCERS COALITION - GNR.E-IO-04
REQUEST FOR PRODUCTION NO. 59
ReferenceOir. Test. ofBrue Griswolcl p. 5, lines 20-21. Did the developer ever formally
request a PPA for a second project? Pleae explai what is meant by "discussin the option" to
brea theinuncipal was project into two separate QFs. Please explai how two muncipal
waste QFs could be commonly owned and separted by one mile to "disaggregate" their project
over 1 0 aM an still comply with Commssion orders.
REQUEST FOR PRODUCTION NO. 60
Reference Dir. Test. of Bruce Griswolcl p. 6, lines 12-13.
(a) Please explai for which load center(s) Rocky Mountan Power would use the proposed
Idao QF projectsdes.cribe on page 8, lines 11-18.
(b) Please explai the anual load profile and the hourly load profiles for the load center(s)
described in (a). Whatis the. "off-peak" period of the year and day for the loadcenter(s)? What
is the "miU'lo:ad." Pleae p:iovide supporting documents or sties if available.
REQUEST FOR PRODUCTION NO. 61
Reference Dir. Test. of Bruce Grswold, p. 7, line 1. Please adt or deny that Rocky Mounta
Power's Idaho PURP A PPAsgive Rocky Mountan Power the right to curl aQF wid project
if necssar to ensure system reliabilty. If deny, please identify the Idaho PVR A PP A which
does not allow for such curailment.
REQUEST FOR PRODUCTION NO. 62
Reference Dit. Test. of:Jruce Grswold, p. 9, lines 2-7.
(a) Please provide the work paprs supportng ths cal.culation.
(b) Please adt or deny that, for one 78 MW project included in the calculation of the $12
milion anua differnce betweenIR Methodology rates and published rates, the developer has
only requested IRP Metodology rates, and not published rates. Please explain the basis for
including ths project in the caculation. Does Rocky Mounta Power believe ths project could
be split into separat 10 aMW projects and stil be a cumulative 78 MW project?
(c) Please provide the calculation without the 78 MW project.
(d) Pleae explai why Rocky Mountai Power used the IR Methodology rates instea of
rates bid into. its RFPs adjusted for the cost to transmit the output to the applicable load centers
that would otherwse be served by the Idao QF projects.
Page 3 - FIF PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNAI
POWER PRODUCERS COALITION - GNR-E-l 0-04
REQUEST FOR PRODUCTION NO. 63
Refernce Reply Comments ofIdao Power, p. 13, sttig "in reseching the AURORA
modeling capabilties, the softare provider ha advised tht there may be some issues with the
softe produciag dependable results for projects that are less that. 2 MW." Ancl "if the project
is small enough that it does not trgger changes in the bae model operations, Le., it is lost in the
rounding to MW s or MWhs, then the base model results could be identical to the modeled results
tht include the project. This would result in an AURORA pricing of zero."
(a) Please provide copies of all communcations with the softare provider that relates to
the use of AURORA model for settg avoided cost rates including the communcation
referenced above.
(b) Please provide all documents and studies including work papers used by the softare
provider regarding modeling for smaller projects.
(c) Please explain what is meant by "lost in rounding".. Please quantify the amount(s) that
are lost in rounding and identify the rounding errors that are expected in rung the softare for
projects that are 2 MW, 5 MWand 10 MW in size respectively.
(d) Please explai the circumstaces by which the softare provider made Idaho Power
aware of the "issues" referenced in Idao Power Reply Comments quoted above. Include date(s)
and pleae identify the individuas who were made aware of the "issues."
(e) In light of AURORA's inabilty to estimate avoided cost rates for projects 2MW and
smaller, please explain whether Idao Power now believes the AURORA model is a reliable
estimate of Idaho Power's avoided cost rates for projects greater that 2 MW.
(f) To Idaho Power's knowledge has the softare provider made the ~~issues" with the model
known to other utilty customers tht use the AURORA model for setting avoided cost rates? If
so what other utilities were made aware of the "issues" and please explain how Idao Power
leamed that information.
(g) Please explai the circumstaces that caused the softare provider to begin the procss of
"researching the AURORA modeling capabilties." Was the referencedreseach.done atIdao
Power's request? If so what was the purose of the research? Pleae provide supportng
documentation.
REQUEST FOR PRODUCTION NO.. 64
Reference Reply Comments of Idao Power, p. 13, statig "in researchig the AURORA
modeling capabilties, the softare provider ha advised that there may be some issues with the
softare producing dependable results for projects that are less that 2 MW." And "If the project
is small enough that it does not trgger changes in the base model operations, Le., it is lost in the
roundig to MW s or MWhs, then the base model results could be identical to the modeled results
that include the project. This would result in an AURORA pricing of zero."
Page 4 - FIFTH PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAI
POWER PRODUCERS COALITION - GNR~E-IO-04
(a) Did Avista know about the "issues" referenced above?
(b) If the anwer to (a) above is yes, please explaiii the circumtaces sU,ottding its
learng of the identified issues. Please provide copies of all communcations regardig the
"issues" between the sQftare provider (or other entity) and Avista and please explai the
circumstaces by which the softare provider (or other entity) made Avista aware of the "issues"
referenced in Idao Power Reply Comments quoted above. Include date(s) and please identify
the individuals who were mad aware of the "issues."
(c) If the anwer to. (a) above is yes, please explai why Avista did not ìnformthe
Commssion of the referenced "issues."
(d) If the answer to (a) above is no, then in light ofIdaho Power's admission that AURORA
is incapable of estimating avoided cost rates for projects 2 MW and smaller, please explain
whether Avist now believes the AURORA model is a reliable estimate of Avista's avoided cost
rates for projects greater than 2 MW and please document how A vista came to that belief.
(e) Please provide all communcations between AURORA and 'any entity related-to
AURORA and Avista dealing with AURORA's capabilities in settng avoided cost rates.
RPQUlEST FOR PRQDUCTION NO. 65
Referece Reply Comments ofIdao Power, p. 13, stating "in reseching the AURORA
modeling capabilties, the softare provider has advised that there may be some issues with the
softare producing dependable results for projects that are less tht 2 MW." And "If the project
is small enough that it does not trgger changes in the base model operations, Le., it is lost in the
rounding to MW s or MWh, then the base model results could be identical to the modeled results
that include the project. Ths would result in an AURORA pricing of zero."
(a) Has Rocky Mounta Power investigated its Grd Model to determine if it sufers from
the sae inirties as the AURORA model? If yes, please explai under what circumstaces
the investigation took place and provide copies of the results with supporting work papers. If no,
then in light ofIdaho Power~s admission that AURORA is incapable of calculating avoided cost
rates for smaller projects, whether Rocky Mountan Power plans to conduct such an investigation
and provide the time line for the same.
(b) In light of Idaho Power's admssion regarding the infities with AURORA please
explai why the Idaho Commission should have continued confdence in the Grid Model as an
accurate measure of avoided cost rates.
REQUEST FOR PRODUCTION NO. 66
Reference Idao Power's Reply Comments at p. 8, stating, "Thus, ths Commission has
both the statutory authonty and wen-established precedent from the state and federal judiciar to
Page 5 - FIFH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAI
POWER PRODUCERS COALITION - GNR-E-IO-04
invoke the Commission's authority to anul, supersede, or reform contracts with public utilties
so that the public interest is served." And at p. 7, statig, "to invoke and authorie the
Commssion - in the exercise of its legislative, state police power and authority to protect the
public in the contractual rates that it sets and the public utility contracts that it reviews for the
purchase of energy from QF projects under PUR A"
(a) Does Idao Power intend to ask the Commssion to anul, supersede or reform any
contracts it has executed with a PURPA developer?
(b) If the answer to (e) is yes, please identify each such contrac Idaho Power will seek to
have anulled or superseded. For each contract Idaho Power win seek to have reformed please
identify said contract and the maner in which Idao Power will seek to have it reformed.
Sincerely yours,t:.. '
~t= Richardson
Greg Adams
RICHARSON & O'LEARY, PLLC
Page 6 - FIFH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN
POWER PRODUCERS COALITIQN - GNR-E-IO-04
CERTIFICATE OF SERVICE~I HEREBY CERTIFY th on the ~ day of Janua, 2011, a tre and corroot copy of
the with and foregoing FlF'l'HPRODUCTION REQUEST OF THE NORTHWST AND
INERMOUNT Al POWER. :PRODUCERS COALITION was sered as shown to the
followig paries:
Jean Jewell
Idaho Public Utilities Commission
472 W. Wasngton
Boise, ID 83702
jean. jewell(guc.idaho. gov
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Donald L. Howell II
Krstine Sasser
Idao Public Utilties Commssion
472 W. Washigton
Boise, ID 83702
don.howell(guc.idao.gov
krs.saser(guc.idaho. gov
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Donovan.E. Waler
Lisa D. Nordstrom
Idao Power Company
POBox 70
Boise, ID 83707..0070
dwalker~idabowwer.com
lnordstrom(~idaowwer.com
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Michal G. Andrea
A vista Corpration
1411 E. Mission Stret
Spokane, W A 99202
michael.andrargavistacorp.coin
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Daniel Solander
PacifiCorp/dba Rocky Mountain Power
201 S. Mai St., Suite 2300
Salt Lae City, UT 841 1 1
daiel.soiander~liacificorp.com
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Ronald L. Williams
Wiliams Bradbur PC
101S W.Hays Strt
Boise, ID 83702
ron~wiliatsbradbur.com
Page 7 - FIFTH PRODUCTION REQUEST OF TH NORTHWST AN INTERMOUNTAIN
POWER PRODUCERS CQALITION - GNR-E-IO-04
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Scott Montgomery
President, Cedar Creek Wind, LLC
668 Rockwood Dr.
Nort Salt Lake, UT 84054
scott(iwestemenergy. us
DanaZenta
Sumit Power Group, Inc.
2006 E. Westminster
Spokane, W A 99223
dzentz(isumtpower.com
Thomas H. Nelson
PO Box 1211
Welches, OR 97067
nelson(ithelson.com
JohnR. Lowe
Renewable Energy Coalition
12050 SW Tremont St
Portland, OR 97225
iravensaarcos(iyahoo .com
Don Stuevant
lR. Simplot Company
PO Box 27
Boise,ID 83707-0027
don.sturevant(isimplot.com
Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Sprigs, CA 92241
robertpauI08(ggmail.com
James Carkulis
Exergy Development Group of Idao, LLC
802 W. Banock, Ste 1200
Boise,ID 83702
icarkulisCiexergydevelopment.com
R. Greg F erney
Mimura Law Office, PLLC
2176 E. Frann Rd., Ste 120
Meridian, ID 83642
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Page 8 -. FIFTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN
POWER PRODUCERS COALITION - GNR-E-IO-04
grg(ämimyaw.com
Bil Piske
Interconnect Solar Development, LLC
1303 E. Carer
Boise, ID 83706
bHlpisk.e(äcllPl§2e.llet
Dean J Milere
McDevitt & Miller, LLP
PO Box 2564
Boise, ID 83701
ìoe(ämcdevitt-miiieu~Qm
Paul Mar
Intermountan Wind, LLC
PO Box 353
Boulder, CO 80306
paulpin(äintermmltainwind.com
Ronad L. Wiliam
Williais Brabur~ PC
1015 W. Hays Stret
Boise, ID 83702
ron(äwilliambradpii.com
Wade Thomas
DynansEnergy, LLC
776 W. Riverside Dr., Ste. 15
Eale,ID 83616
wtoma(ädyiamisenergy.com
Shelley M. Davis
Barker Rosholt & Simpson, LLC
PO Box 2139
Boise, ID 83701
smd(äidaowaters.com
Brian Olmstead
Twi Falls Canal Company
PO Böx 326
Twi Falls, ID 83303
olmstead(ätfcanal..com
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Page 9 -- FIFH PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAIN
POWER PRODUCERS COALITION -- GNR-E-l 0-04
Signed
Ted Diehl
North Side Canal Company
921 N. Lincoln St.
Jerome, il 83338
nscanalcmcableone.net
Bil Brown
Board of Commissioners of Adas County, ID
PO Box 48
Council, il 83612
bdbrowncmfrontiemet.net
Glen Ikemoto
Margaret Rueger
Idaho Windfars, LLC
672 Blair Avenue
Piedmont, CA 94611
glennr'envisionwind.com
margaretcmenvisionwind.com
Jeffey S. Lovinger
Lovinger Kaufm LLP
825 NE Multnomah, Suite 925
Portanø. OR 97232
lovingercmLKLaw.com
Kenneth E. Kaufan
Lovinger Kaufman LLP
825 NE Multnomah, Suite 925
Portand, OR 97232
Kaufman~LKLaw.com
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Page 10 - FIFTH PROPUCTION REQUEST OF TH NORTHWEST AND INTERMOUNTAI
POWER PRODUCERS COALITION - GNR-E-1O-04