HomeMy WebLinkAbout20110225IPC to NIPPC 67-68.pdfLISA D. NORDSTROM
Lead Counsel
Inordstromcæidahopower.com
esIDA~POR~
An IDACORP Company
February 25, 2011
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 MA ITER OF THE JOINT PETITION OF IDAHO POWER COMPANY,
AVISTA CORPORATION, AND PACIFICORP DBA ROCKY MOUNTAIN
POWER TO ADDRESS AVOIDED COST ISSUES AND TO ADJUST THE
PUBLISHED AVOIDED COST RATE ELIGIBILITY CAP
Dear Ms. Jewell:
Enclosed for filng please find an original and three (3) copies of Idaho Power
Company's Response to the Sixth Production Request ofthe Northwest and Intermountain
Power Producers Coalition to the Joint Utilties in the above matter.
Very truly yours,
~A/j)Y¿~
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 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
dwalker(âidahopower.com
Inordstrom(âidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
REeF:;
zon FEB 25 Pr1 3= 51
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
PETITION OF IDAHO POWER
COMPANY, AVISTA CORPORATION,
AND PACIFICORP DBA ROCKY
MOUNTAIN POWER TO ADDRESS
AVOIDED COST ISSUES AND TO
ADJUST THE PUBLISHED AVOIDED
COST RATE ELIGIBILITY CAP.
)
) CASE NO. GNR-E-10,.04
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE SIXTH
) PRODUCTION REQUEST OF THE
) NORTHWEST AND
) INTERMOUNTAIN POWER
) PRODUCERS COALITION TO THE
) JOINT UTILITIES
)
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Sixth Production Request of the Northwest and Intermountain Power
Producers Coalition to the Joint Utilties dated February 4, 2011, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 1
REQUEST NO. 67: Reference the transcript of oral argument before the Idaho
Public Utilties Commissions on January 27,2011 at pages 18 -19, wherein Mr. Walker
asserted:
Idaho Power in its reply comments disclosed that the
softare provider for its modeling program, AURORA, had
advised us that there may be some kind of modeling
problems with that softare for vey (sic) small projects under
two megawatts in size and we disclosed that in our reply
comments, and prior to that time Idaho Power has not been
required to run AURORA on projects that small and in fact,
we have not run projects smaller than two megawatts
through the AURORA modeling, and for several of the
reasons that we've outlined in our documents, we had
received no requests from anyone to run AURORA pricing
for avoided costs for projects that low either.
However, since the time, since January 19th at the time when
we filed our reply comments, obviously, we've been working
on this issue, we consulted with Avista and found out that
Avista routinely runs their AURORA modeling for 100
kilowatt projects as part of their IRP process. Also the
Company's analysts also ran several test modelings at 100
kilowatt levels and the Company is confident that the
modeling does result in accurate and usable results for
projects smaller than two megawatts . . .
Also reference ¡d. at page 20, wherein Mr. Walker asserted:
Well, first of all, Madam Commissioner, the Company never
did state anywhere that the AURORA modeling was flawed,
so we object to that characterization . . .
(a) Please reconcile the assertion quoted above that the "Company never did
state anywhere that the AURORA modeling was flawed" with Idaho Power's Reply
Comments at p. 13 stating:
If the project is small enough that it does not trigger changes
in the base model operations, i.e., it is lost in the rounding to
MWs 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.
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 2
While Idaho Power believes using the I RP-based
methodology for any project above 100 kW is the right
answer, there are some limitations to modeling projects
below a certain size. To remedy this situation, Idaho Power
proposes to work with Staff to reach an appropriate solution
(b) Please identify the "Company's analysts" who "also ran several test
modelings" and provide the models they ran along with all supporting work papers.
(c) For Avista, please identify the individuals at the company who were
"consulted with" by Idaho Power, the dates of said consultations and provide a summary
of the consultations. Please provide copies of all information, studies or models provide
(sic) to Idaho Power regarding AURORA and its abilty to estimate avoided costs for
projects larger than 100 kW.
(d) For Idaho Power please identify the individuals at the company who "ran
several test modelings" and provide a copy of the results of the test modelings along
with supporting work papers.
(e) For Idaho Power, please identify the individuals at the company who
"consulted with" Avista, the dates of said consultations and provide a summary of the
consultations. Please provide copies of all information, studies or models provide (sic)
to Idaho Power by Avista regarding AURORA and its abilty to estimate avoided costs
for projects larger than 100 kW.
(f) For Avista and Idaho Power, please provide copies of and supporting work
papers for the three most recent iterations of Avista's "routin(e) . . . runs (of) their
AURORA modeling for 100 kilowatt projects as part of their IRP process."
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 3
(g) Has Idaho Power had any communications "with Staff to reach an
appropriate solution"? If so, please summarize those communications, identify and
provide copies of any documents exchanged as part of those communications.
(h) For Idaho Power, please provide all additional evidence supporting the
claim in Mr. Walter's (sic) oral argument that AURORA yields accurate results for QF
projects smaller than 2 MW.
RESPONSE TO REQUEST NO. 67:
(a) The quoted language in Northwest and Intermountain Power Producers
Coalition's ("NIPPC") Request No. 67(a) from Idaho Power's Reply Comments does not
state that the AURORAmpCI ("AURORA") modeling was flawed; thus, NIPPC's request
to "reconcile" the statements is unclear, as the two statements are consistent with each
other.
(b) Richard Pagoaga, Senior Power Supply Planning Analyst; Tom Noll,
Senior Power Supply Planning Analyst; and Philp DeVol, Power Supply Planning
Leader, were involved with running AURORA test models. Attached is a table summary
of the analysis showing the AURORA avoided cost of energy results run at 100
kilowatts ("kW"), 2 megawatts ("MW"), 1 0 MW, and 80 MW. This table shows only the
avoided cost of energy modeled by AURORA, and does not contain the avoided cost of
capacity component, which is added to the value of the energy in determining the total
avoided cost rate. As can be seen in the table, the avoided cost of energy modeled at
100 kW did not give consistent annual results, just as disclosed by Idaho Power in its
Comments. However, Idaho Power is confident that AURORA can be utilized to
appropriately determine an avoided cost of energy for any potential PURPA generation
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 4
project. From Idaho Power's review of the "base case vs. study case" approach, on a
per megawatt-hour ("MWh") basis, a project's avoided cost of energy can be assumed
to be comparable independent of nameplate capacity. Modeling suggests that the
avoided cost of energy for same type resources with identical operating characteristics
is comparable on a per MWh basis for projects sized from 10 MW to 80 MW. The
Company believes the avoided cost of energy on a per MWh basis determined for a 10
average megawatt ("aMW") project could be applied to all projects of the same type
producing less than 1 0 aMW.
(c) As this question is directed to Avista only, please see Avista's response to
NIPPC's Request No. 67(c).
(d) Please see the Company's Response to NIPPC's Request No. 67(b)
above.
(e) Richard Pagoaga, Senior Power Supply Planning Analyst; Tom Noll,
Senior Power Supply Planning Analyst; and Randy Allphin, Senior Power Supply
Energy Contracts Coordinator, from Idaho Power consulted with Clint Kalich and Mr.
Gall from Avista regarding the use of AURORA modeling for projects smaller than 2
MW. The first such consultation was on January 21, 2010, with a second consultation
on January 26, 2010. Idaho Power described how it used AURORA to calculate the
avoided cost of energy for PURPA projects and Avista described how it used 100 kW
resources in AURORA for its Integrated Resource Plan ("IRP") modeling. There were
no materials provided or exchanged.
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 5
(f) Idaho Power was not provided with nor does it possess copies of, and/or
supporting work papers for, the three most recent iterations of Avista's runs of their
AURORA modeling for 100 kW projects as part of their IRP process.
(g) No.
(h) There are two methods in the AURORA electric market model to value the
avoided cost of energy using the IRP methodology. First, there is the "mark-to-market"
approach where the hourly market price calculated in AURORA is multiplied by the
PURPA project's hourly generation to derive the avoided cost of energy. Second, there
is the "base case vs. study case" approach (the method Idaho Power currently uses)
where, in the study case, AURORA is used to simulate how the energy received from
the proposed PURPA project would displace the cost of other resources in the preferred
portolio from Idaho Power's IRP. The total cost of the study case is then compared to
the total cost of the preferred portolio from the IRP (the base case), with the difference
being the gross avoided cost of energy. On an annual basis, the gross avoided cost of
energy is divided by the forecasted annual generation from the proposed PURPA
project in order to derive an annual avoided cost for the energy. A capacity (fixed) cost
credit using a combined cycle combustion turbine as a surrogate resource is then added
and any applicable deductions are subtracted to calculate an adjusted avoided cost for
each year of the contract. The fixed cost credit is based upon the PURPA project's
capacity factor during the July hours from 3:00 p.m. to 7:00 p.m. For intermittent and
variable wind and solar PURPA projects, the 90 percent exceedance capacity factor
from these respective existing projects in Idaho Power's service territory is used.
Finally, the stream of avoided costs is uniformly escalated and then discounted using
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 6
Idaho Power's weighted average cost of capital to establish a levelized avoided cost
rate for the proposed PURPA project.
Idaho Power is confident that AURORA can be utilzed to appropriately
determine an avoided cost of energy for any potential PURPA generation project. From
Idaho Power's review of the "base case vs. study case" approach, on a per MWh basis,
a project's avoided cost of energy can be assumed to be comparable independent of
nameplate capacity. Modeling suggests that the avoided cost of energy for same type
resources with identical operating characteristics is comparable on a per MWh basis for
projects sized from 10 MW to 80 MW. The Company believes the avoided cost of
energy on a per MWh basis determined for a 10 aMW project could be applied to all
projects of the same type producing less than 10 aMW.
The response to this Request was prepared by Richard Pagoaga, Senior Power
Supply Planning Analyst, Idaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 7
REQUEST NO. 68: Please reference the transcript of Counsel for Avista's oral
argument before the Idaho Public Utilties Commission on January 27,2011 at page 29
wherein Mr. Andrea stated:
I do want to address just really quickly Idaho Power's
concerns about the AURORA program working for two
megawatts or less. As Mr. Walker noted, Idaho Power has
worked with Avista over the past week or so to work on that
issue and I think they've come to the conclusion that they're
comfortable that it does in fact work.
(a) Please identify the personnel at Avista who "worked" with Idaho Power in
the two weeks prior to oral argument. Please also identify the personnel from Idaho
Power who they worked with.
(b) Please provide all documentation related to the work referenced in Mr.
Andrea's statement, including AURORA model runs, work papers and correspondence.
RESPONSE TO REQUEST NO. 68:
(a) & (b)As this question is directed to Avista only, please see Avista's
responses to NIPPC's Requests Nos. 68(a) and (b).
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 25th day of February 2011.
DONOVAN E. W
Attorney for Idah
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of February 2011 I served a true and
correct copy of the IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH
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
Donald L. Howell, II
Kristine A. Sasser
Deputy Attorneys General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
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-2 Email don.howell(âpuc.idaho.gov
kris.sasser(âpuc.idaho.gov
Avista Corporation
Michael G. Andrea
Clint Kalich .
Avista Corporation
1411 East Mission Avenue - MSC-23
P.O. Box 3727
Spokane, Washington 99220-3727
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-2 Email michael.andrea(âavistacorp.com
clint. kalich(âavistacorp. com
PacifiCorp d/b/a Rocky Mountain Power
Daniel E. So lander
J. Ted Weston
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
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-2 Email daniel.solander(âpacificorp.com
ted. weston(âpacificorp.com
Kenneth Kaufmann
LOVINGER KAUFMANN, LLP
825 NE Multnomah, Suite 925
Portland, Oregon 97232
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Bruce Griswold
PacifiCorp
825 NE Multnomah
Portland, Oregon 97232
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IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 9
Exergy, Grand View Solar, J. R. Simplot,
Northwest and Intermountain Power
Producers Coalition, & Board of
Commissioners of Adams County, Idaho
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
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
Grand View Solar II
15960 Vista Circle
Desert Hot Springs, California 92241
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, Attorney
P.O. Box 1211
Welches, Oregon 97067-1211
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gregcærichardsonandoleary.com
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-2 Email don.sturtevantcæsimplot.com
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-2 Email rkahncænippc.org
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-2 Email nelsoncæthnelson.com
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES -10
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Cedar Creek Wind, LLC, & Dynamis
Energy, LLC
Ronald L. Wiliams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Cedar Creek Wind, LLC
Scott Montgomery, President
Cedar Creek Wind, LLC
668 Rockwood Drive
North Salt Lake, Utah 84054
Dana Zentz, Vice President
Summit Power Group, Inc.
2006 East Westminster
Spokane, Washington 99223
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 15
Eagle, Idaho 83616
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
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-2 Email glennicæEnvisionWind.com
MargaretcæEnvisionWind .com
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IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 11
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Intermountain Wind LLC
Dean J. Miler
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564
Boise, Idaho 83701
Paul Martin
Intermountain Wind LLC
P.O. Box 353
Boulder, Colorado 80306
North Side Canal Company and Twin
Falls Canal Company
Shelley M. Davis
BARKER ROSHOLT & SIMPSON, LLP
1010 West Jefferson Street, Suite 102
P.O. Box 2139
Boise, Idaho 83701-2139
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
Board of Commissioners of Adams
County, Idaho
Bil Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
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IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 12
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11 th East
Idaho Falls, Idaho 83404
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Blue Ribbon Energy LLC
M. J. Humphries
Blue Ribbon Energy LLC
4515 South Ammon Road
Ammon, Idaho 83406
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Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
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£i2i¡~1kDonovan E. WaÎr. ~
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES -13
BEFORE THE
\
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. GNR-E-10-04
IDAHO POWER COMPANY
RESPONSE TO NIPPC'S REQUEST NO. 67
Avoided Cost of Energy Modeled in AURORA (Biomass Project)
Annual average $/MWh, non-/evelized, using Idaho Power's IRP methodology
1'(ll.tCi2012 $140.14 $42.54 $33.43 $36.90
2013 $281.06 $52.30 $49.34 $39.64
2014 $940.06 $11.06 $38.67 $40.33
2015 $724.27 $17.82 $48.20 $41.41
2016 ($5.42) $35.54 $39.88 $41.75
2017 $1,308.52 $128.33 $52.57 $44.30
2018 $765.88 $80.47 $51.98 $44.27
2019 $69.57 $33.47 $46.31 $45.32
2020 $84.01 $49.86 $47.14 $47.22
2021 $166.71 $67.83 $46.95 $48.18
2022 $201.75 $63.21 $42.16 $48.79
2023 $726.17 $102.83 $63.55 $54.23
2024 $320.91 $110.42 $63.37 $55.92
2025 ($302.05) $38.38 $55.79 $56.30
2026 ($60.21) $47.76 $55.28 $58.38
2027 $218.70 $27.12 $70.38 $58.60
2028 $1,275.93 $77.44 $57.81 $62.93
2029 ($1,093.74) $38.59 $61.88 $61.58
Average
($/MWh)$320.12 $56.94 $51.37 $49.22
Note: This analysis does not include the avoided cost of capacity, which is added to the
value of the energy in determining the total avoided cost rate.