20110308NIPPC 1-10 to Joint Utilities.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson & O'Leary, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peteriirichardsonandoleary.com
gregiirichardsonandoleary .com
R.EC:F~t
qUH ~fAR, -1 .p~A L: 1:3LUii fit'!."' 1'1 ll ~_
Attorneys for Nortwest and Intermountain
Power Producers Coalition
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S )
INVESTIGATION INTO DISAGGREGATION) CASE NO. GNR-E-II-0l
AND AN APPROPRIATE PUBLISHED )
AVOIDED COST ELIGIBILITY CAP ~ FIRST PRODUCTION REQUEST OF THE
STRUCTURE FOR PURPA QUALIFYING ) NORTHWEST AND INTERMOUNTAIN
FACILITIES ) POWER PRODUCERS COALITION TO
) IDAHO POWER COMPANY, AVISTA
) CORPORATION AND ROCKY
) MOUNTAIN POWER
)
)
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Northwest and Intermountain Power Producers Coalition ("NIPPC")
hereby requests that Idaho Power Company ("Idaho Power"), Rocky Mountain Power, and
Avista Corporation (collectively the "Joint Utilities") provide responses to the following with
supporting documents, where applicable.
This production request is to be considered as continuing, and the Joint Utilities are
requested to provide by way of supplementary responses additional documents that they or any
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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) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
Some of the following requests may include disclosures deemed by the Joint Utilties to
be confidentiaL. Counsel and the expert witness for NIPPC have signed the protective agreement
in the related matter, Case No. GNR-E-IO-04. To the extent an additional protective agreement
may be necessar for this docket, NIPPC's representatives are prepared to sign any such
agreement to obtain the materials relevant to this proceeding, and NIPPC expects that executing
such a confidentiality agreement wil not delay the responses to these Requests for Production.
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REQUEST FOR PRODUCTION NO.1
For the purose of this request please refer to the "IRP Methodology" as approved by the Idaho
Public Utilties Commission in Order No. 26576 in Docket No. IPC-E-95-09.1 The IRP
Methodology approved in Order No. 26576 is embodied in Exhibit 101 to Staffs technical
testimony(Exhibit 101). In the time since Order No. 26576 was issued, please provide a list of
each project for which the IRP Methodology has been used to set avoided cost rates for QF
projects. For each project, please identify the Idaho PUC order approving the project.
REQUEST FOR PRODUCTION NO.2:
Pages 7 and 8 of Exhibit 101 state that semianual updates of the IRP Methodology must be
approved by the Commission for the following variables before they are to be used to determine
avoided cost rates:
a. Escalation rates for capital costs,
b. Escalation rates for O&M expenses,
c. Escalation rates for fuel prices,
d. Fuel prices,
e. Wholesale power prices
f. Wholesale power prices escalation rates
g. Wholesale power available for purchase
Please provide the docket numbers for all such semianual updates since Order No. 26756 was
issued. If no docket numbers exist, please explain how your utility has otherwise obtained the
requisite semi-anual Commission approval.
REQUEST FOR PRODUCTION NO 3:
Page 9 of Exhibit 101 provides that "utilties be allowed to publish avoided cost rates for
hypothetical projects. The rates should be published semianually at the time changes in
variables are submitted to the Commission. The rates should be for hypothetical 10 MW, 20
MW and 40 MW" projects. Exhibit 1 0 1 also provides that utilities "may forego publishing
hypothetical rates if they can provide, within 10 working days of receiving a request,
approximate rates based on IRP model rus."
(a) Has your utility ever fied hypothetical avoided cost rates for 10 MW, 20 MW and 40 MW
projects? Please provide copies of all such filings.
1 Although docketed as an Idaho Power case, IPC-E-95-09 was, pursuant to Order No. 25884, a
generic docket and the Washington Water Power Company (Avista Corporation) and PacifiCorp
(Rocky Mountain Power) were also paries and are hence bound by its terms.
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(b) Please provide avoided cost rates for a hypothetical 10 MW, 20 MW and 40 MW gas-fired,
non-dispatchable projects with 100 % capacity factors.
(c) How many working days does it take your utility to provide avoided cost rates based on IRP
model runs? Please document your response.
REQUEST FOR PRODUCTION NO.4:
Exhibit No. 101 provides that the following variables not be changed except during the biennial
IPR process:
Plant capita costs
Operation and maintenance costs
Heat rates
Generation capacities
Plant factors
Economic life
Load forecasts, except for known and measurable changes
Does your utility use the identical data for these varables in its most recent IRP fiing as it uses
in setting avoided cost rates under the IRP methodology? Ifnot, please provide the PUC docket
number in which the change was authorized.
REQUEST FOR PRODUCTION NO.5:
For the purose of the following request assume guaranteed minimum capacity of 50 MW wind
project over 20 year period, with an on-line date of Janua 1,2012, that would be added to your
system using the "IRP Methodology" as approved by the Idaho Public Commission in Order No.
26576 in Docket IPC-E-95-09. Please calculate the estimated avoided costs, in the following
format:
(a) on a $/MWh basis levelized over the 20 year contract period
(b) on a non-Ievelized $/MWh basis anually over the 20 year contract period,
(c) on a $/MWh basis seasonal rates over the 20 year contract period,
(d) for (a) through (c), separate the avoided cost between the capital and energy components.
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REQUEST FOR PRODUCTION NO.6:
In support of the last response, please provide supporting data, in electronic format where
possible, the source of the values assumed, workpapers, notes, and an explanation why paricular
values were assumed. Specifically, please provide:
(a) The inputs to the power supply model used, including but not limited to:
(i) Fuel costs for each year of the 20 years for: Coal, Natural Gas, and Other.
(ii) Fixed and Variable O&M costs for each year of the 20 years,
(iii) Capacity factors,
(a) For existing resources,
(b) For the modeled wind resource.
(iv) Heat rates for existing resources
(v) System loads for each year of the 20 years, including On-peak by season, and Off-
peak by season.
(vi) DSM MWh for each year of the 20 years
(b) The output values used in the energy supply model, including but not limited to the
following:
(i) Off system purchases for each year of the 20 years, including MWh, and Price per
MWh.
(ii) Off system sales for each year of the 20 years, including MWh, and Price per MW.
(iii) Capacity factors, including each existing resource, and the modeled wind resource.
(c) For the financial model used to find the present value of the revenue requirement
(PVRR), please provide the input values used, including but not limited to the following: (i) the
resource used to for the capital cost, (ii) the cost of capital, (iii) the capital caring cost, (iv) tax
rate assumptions - (state, federal, local), (v) economic life of the system resources.
(d) The levelization model used including all assumptions.
REQUEST FOR PRODUCTION NO.7
For Avista, please use the "IRP Methodology" as approved by the Idaho Public Commission in
Order No. 26576 in Docket IPC-E-95-09 to calculate the estimated avoided costs for the Reardan
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Wind project based on available wind data and projected electrical output of the project, if the
project were to have an online date of Januar 1,2012, in the following format:
(a) on a $/MWh basis levelized over the 20 year contract period
(b) on a non-Ievelized $/MWh basis anually over the 20 year contract period,
(c) on a $/MWh basis seasonal rates over the 20 year contract period,
(d) for (a) through (c), separate the avoided cost between the capital and energy components.
REQUEST FOR PRODUCTION NO.8
In support of the last response, please provide supporting data, in electronic format where
possible, the source of the values assumed, workpapers, notes, and an explanation why particular
values were assumed. Specifically, please provide:
(a) The inputs to the power supply model used, including but not limited to:
(i) Fuel costs for each year of the 20 years for: Coal, Natural Gas, and Other.
(ii) Fixed and Varable O&M costs for each year of the 20 years,
(iii) Capacity factors,
(a) For existing resources,
(b) For the modeled wind resource.
(iv) Heat rates for existing resources
(v) System loads for each year of the 20 years, including On-peak by season, and Off-
peak by season.
(vi) DSM MWh for each year of the 20 years
(b) The output values used in the energy supply model, including but not limited to the
following:
(i) Off system purchases for each year ofthe 20 years, including MWh, and Price per
MWh.
(ii) Off system sales for each year of the 20 years, including MWh, and Price per MWh.
(iii) Capacity factors, including each existing resource, and the modeled wind resource.
(c) For the financial model used to find the present value of the revenue requirement
(PVRR), please provide the input values used, including but not limited to the following: (i) the
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resource used to for the capital cost, (ii) the cost of capital, (iii) the capital caring cost, (iv) tax
rate assumptions - (state, federal, local), (v) economic life ofthe system resources.
(d) The levelization model used including all assumptions.
REQUEST FOR PRODUCTION NO.9
For Rocky Mountan Power, please use the "IRP Methodology" as approved by the Idaho Public
Commission in Order No. 26576 in Docket IPC-E-95-09 to calculate the estimated avoided costs
for the Rollng Hils wind far in Wyoming, based on actual production data if the project were
to have an online date of Janua 1,2012, in the following format:
(a) on a $/MWh basis levelized over the 20 year contract period
(b) on a non-Ievelized $/MWh basis anually over the 20 year contract period,
(c) on a $/MWh basis seasonal rates over the 20 year contract period,
(d) for (a) through (c), separate the avoided cost between the capital and energy components.
Request No.
REQUEST FOR PRODUCTION NO. 10
In support of the last response, please provide supporting data, in electronic format where
possible, the source of the values assumed, workpapers, notes, and an explanation why paricular
values were assumed. Specifically, please provide:
(a) The inputs to the power supply model used, including but not limited to:
(i) Fuel costs for each year of the 20 years for: Coal, Natual Gas, and Other.
(ii) Fixed and Variable O&M costs for each year of the 20 years,
(iii) Capacity factors,
(a) For existing resources,
(b) For the modeled wind resource.
(iv) Heat rates for existing resources
(v) System loads for each year of the 20 years, including On-peak by season, and Off-
peak by season.
(vi) DSM MWh for each year of the 20 years
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(b) The output values used in the energy supply model, including but not limited to the
following:
(i) Off system purchases for each year of the 20 years, including MWh, and Price per
MWh.
(ii) Off system sales for each year of the 20 years, including MWh, and Price per MWh.
(iii) Capacity factors, including each existing resource, and the modeled wind resource.
(c) For the financial model used to find the present value of the revenue requirement
(PVRR), please provide the input values used, including but not limited to the following: (i) the
resource used to for the capita cost, (ii) the cost of capital, (ii) the capital caring cost, (iv) tax
rate assumptions - (state, federal, local), (v) economic life of the system resources.
(d) The levelization model used including all assumptions.
S' ncerely yours,~et Richardson
egory Adams
RICHARDSON & O'LEARY, PLLC
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of March, 2011, a tre and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST OF THE NORTHWEST AND
INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES
was served as shown to the following paries:
Jean Jewell
Idaho Public Utilties Commission
472 W. Washington
Boise, ID 83702
jean. j ewelliiuc. idaho. gov
Donald L. Howell II
Kristine Sasser
Idaho Public Utilties Commission
472 W. Washington
Boise,ID 83702
don.howelliiuc.idaho. gov
krs.sasseriipuc.idaho. gov
Donovan E. Walker
Lisa D. Nordstrom
Idaho Power Company
POBox 70
Boise, ID 83707-0070
dwalkeriiidahopower.com
lnordstromiiidahopower .com
Michael G. Andrea
A vista Corporation
1411 E. Mission Street
Spokane, W A 99202
michael.andreaiiavistacorp.com
Daniel Solander
PacifiCorp/dba Rocky Mountan Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84111
danieL. solanderiipacificorp.com
lL Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
L Electronic Mail
lL Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
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_ Hand Delivery
lLU.S. Mail, postage pre-paid
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_ Hand Delivery
-lU.S. Mail, postage pre-paid
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_ Hand Delivery
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Ronald L. Wiliams
Wiliams Bradbur PC
1015 W. Hays Street
Boise,ID 83702
roniiwiliamsbradbur .com
_ Hand Delivery
X-U.S. Mail, postage pre-paid
Facsimile
lL Electronic Mail
Scott Montgomery
President, Cedar Creek Wind, LLC
668 Rockwood Dr.
North Salt Lake, UT 84054
scottiiwesternenergy. us
_ Hand Delivery
..U.S. Mail, postage pre-paid
Facsimile
lL Electronic Mail
DanaZenta
Sumit Power Group, Inc.
2006 E. Westminster
Spokane, W A 99223
dzentziisummitpower .com
_ Hand Delivery
-lU.S. Mail, postage pre-paid
Facsimile
lL Electronic Mail
Thomas H. Nelson
PO Box 1211
Welches, OR 97067
nelsoniithnelson.com
_ Hand Delivery
-lU.S. Mail, postage pre-paid
Facsimile
~ Electronic Mail
JohnR. Lowe
Renewable Energy Coalition
12050 SW Tremont St
Portland, OR 97225
jravensanarcosiiyahoo .com
_ Hand Delivery
XU.S. Mail, postage pre-paid
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Don Stuevant
J.R. Simplot Company
PO Box 27
Boise, ID 83707-0027
don. sturevantiisimplot. com
_ Hand Delivery
lLU.S. Mail, postage pre-paid
Facsimile
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Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Springs, CA 92241
robertpauI08~gmail.com
_ Hand Delivery
lLU.S. Mail, postage pre-paid
Facsimile
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James Carkulis
Exergy Development Group of Idaho,
LLC
802 W. Banock, Ste 1200
Boise, ID 83702
j carkulisiiexergydevelopment.com
R. Greg Ferney
Mimura Law Offices, PLLC
2176 E. Franlin Rd., Ste 120
Meridian, ID 83642
gregiimimuralaw.com
Bil Piske
Interconnect Solar Development, LLC
1303 E. Carer
Boise, ID 83706
bil piskeiicab leone .net
Dean J Milere
McDevitt & Miler, LLP
PO Box 2564
Boise, ID 83701
joeiimcdevitt -miler. com
Paul Marin
Intermountain Wind, LLC
PO Box 353
Boulder, CO 80306
paulmariniiintermountainwind.com
Ronald L. Wiliams
Willams Bradbur, PC
1015 W. Hays Street
Boise, ID 83702
roniiwiliamsbradbur.com
Wade Thomas
Dynamis Energy, LLC
776 W. Riverside Dr., Ste. 15
Eagle, ID 83616
wtomasiidynamisenergy .com
_ Hand Delivery
lLU.S. Mail, postage pre-paid
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lLU.S. Mail, postage pre-paid
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lLU.S. Mail, postage pre-paid
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lLU.S. Mail, postage pre-paid
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Shelley M. Davis
Barker Rosholt & Simpson, LLC
PO Box 2139
Boise,ID 83701
smdiiidahowaters.com
_ Hand Delivery
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Brian Olmstead
Twin Falls Canal Company
PO Box 326
Twin Falls, ID 83303
olmsteadiitfcanal.com
_ Hand Delivery
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Ted Diehl
North Side Canal Company
921 N. Lincoln St.
Jerome, ID 83338
nscanaliicableone.net
_ Hand Delivery
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Bil Brown
Board of Commissioners of Adams
County,ID
PO Box 48
Council, ID 83612
bdbrowniifrontiernet.net
_ Hand Delivery
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Glen Ikemoto
Margaret Rueger
Idaho Windfars, LLC
672 Blair Avenue
Piedmont, CA 94611
glenniiienvisionwind.com
margaretiienvisionwind.com
_ Hand Delivery
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Jeffrey S. Lovinger
Lovinger Kaufman LLP
825 NE Multnomah, Suite 925
Portland, OR 97232
lovingeriiLKLaw.com
_ Hand Delivery
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Kenneth E. Kaufman
Lovinger Kaufman LLP
825 NE Multnomah, Suite 925
Portland, OR 97232
KaufmaniiLKLaw.com
Benjamin J Otto
Idaho Conservation League
710 N 6th Street
Boise ID 83702
bottoiiidahoconservation.org
Gar Seifert
Kur Myers
Idaho National Laboratory
Conventional Renewable Energy Group
2525 Fremont Ave
Idaho Falls, ID 83415
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Signed
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