20120411IPC to Exergy 8-40.pdf

IDAHO
WPIVER®
R>EC An IDACORP Company
'2U2 APJ 0 PM tt:
DONOVAN E WALKER
Lead Counsel
dwalkeriThudahopower corn C OM
April 10, 2012
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. GNR-E-11-03
IN THE MATTER OF THE COMMISSION'S REVIEW OF PURPA QF
CONTRACT PROVISIONS INCLUDING THE SURROGATE AVOIDED
RESOURCE (SAR) AND INTEGRATED RESOURCE PLANNING (IRP)
METHODOLOGIES FOR CALCULATING PUBLISHED AVOIDED COST
RATES
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Response to the Second Production Request of Exergy Development Group of
Idaho ("Exergy") to Idaho Power Company in the above matter.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information provided in response to Exergy's Second Production Request.
Please handle the confidential information in accordance with the Protective Agreement
executed in this matter.
Very truly yours
Donovan E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
t f , '?
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS (ISB No. 8718)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwaIker(äidahoDower.com
jwiIliams(idahopower.com
1 Jl
1fl1?Y? n P LUI i
2'
JT1L!T1S CJMM13STON
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
REVIEW OF PURPA QF CONTRACT
PROVISIONS INCLUDING THE
SURROGATE AVOIDED RESOURCE
(SAR) AND INTEGRATED RESOURCE
PLANNING (IRP) METHODOLOGIES FOR
CALCULATING PUBLISHED AVOIDED
COST RATES.
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
EXERGY DEVELOPMENT GROUP
OF IDAHO TO IDAHO POWER
COMPANY
COMES NOW, Idaho Power Company ("Idaho Power'), and in response to the
Second Production Request of Exergy Development Group of Idaho ("Exergy") to Idaho
Power Company dated March 20, 2012, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -1
t r
REQUEST FOR PRODUCTION NO. 8: For the PowerPoint presentation the
Company made at the meeting to present and discuss IRP Models at the Idaho Public
Utilities Commission on December 15, 2011, and attached as Exhibit No. 3, to Mark
Stokes's Direct Testimony, please provide all work papers, spreadsheets in electronic
format with formulas intact, and model outputs used in producing Exhibit 3.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Please see the
following information included on the non-confidential CD:
Exhibit No. 3 Page
Description Number Supporting File/Data on CD
Peak-Hour Capacity Factor Pages 18 and 19 Idaho Power Peak Hour Capacity
Benchmarking
Sample Project - Solar PV Pages 22 thru 27 Idaho Power 2011 Sample Solar
Project
Sample Project - Wind Pages 28 thru 33 Idaho Power 2011 Sample Wind
Project
Sample Project - Base Pages 34 thru 39 Idaho Power 2011 Sample
Load Baseload Project
Sample Project - Canal Pages 40 thru 45 Idaho Power 2011 Sample Canal
Drop Drop Project
Sample Project Results Page 46 Summary of data contained within
the spreadsheets provided
The response to this Request was prepared by Randy C. Allphin, Energy
Contract Coordinator Leader, Idaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -2
REQUEST FOR PRODUCTION NO. 9: Reference the four QF configurations
analyzed in Exhibit No. 3 of Mark Stokes's Direct Testimony. Please list for each of
Company's gas-fired generation plants the annual capacity factor, by year, beginning in
2013 through the end of the 20 year analysis period.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: The value of a
proposed Public Utility Regulatory Policies Act of 1978 ("PURPA") project's energy
shape is modeled in AURORA by determining the impact of creating surplus sales or
displacing market purchases in Idaho Power's resource portfolio. Therefore, for all four
qualifying facility ("QF") configurations analyzed, the annual capacity factor for each of
the Company's gas-fired resources is the same. A chart listing the annual capacity
factor by year has been provided on the confidential CD. The confidential CD will be
provided to those parties that have executed the Protective Agreement in this
proceeding.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -3
t t P I
REQUEST FOR PRODUCTION NO. 10: Reference the Company's 2011 IRP's
near-term action plan milestones (Table 1.2, p. 8), stating plans to secure an 83 MW
PPA for the summer of 2015 from the east side. Please provide the prices the
Company would offer a QF (at 80 MW) that would provide power in the same
configuration sought by Idaho Power.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: In the 2011 Integrated
Resource Plan ("IRP"), the 83 megawatt ("MW") power purchase agreement ("PPA")
was necessary to fill a deficit in the summer of 2015 due to the scheduled completion
date of the Boardman to Hemingway transmission project changing from 2015 to 2016.
If in fact Idaho Power needs to pursue this option, a request for proposal ("RIFF)
process would be conducted most likely in 2014 and a PPA would be signed with the
lowest cost provider. Therefore, Idaho Power cannot estimate at this time what the
actual cost of the energy would be as it will depend on the responses to the RFP.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -4
! )
REQUEST FOR PRODUCTION NO. 11: According to the Commission's
accepted "IRP Methodology' [sic] (IPUC Order No. 26576, IPC-E- 95-9) and IPUC Staff
Witness Rick Sterling's direct testimony Exhibit 101, "the avoided cost of the QF project
is the difference in the present value of the revenue requirements (PVRR) between the
base case resource plan and a modified resource plan that includes the QF resource."
(Exhibit 101, IPC-E-95-9, R. Sterling, page 14.) Under the existing IRP Methodology in
place on the date of this request, please explain in detail how the Company
incorporates the "revenue requirement" as it would in filing for a certificate of public
convenience and necessity (CPCN, i.e. return of and on investment, all taxes, etc.), in
the calculation of rates offered in contracts to QFs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: Idaho Power objects
on the grounds that the request is vague, ambiguous, imprecise, or utilizes terms that
are subject to multiple interpretations but are not properly defined or explained.
The response to this Request was prepared by Jason B. Williams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -5
REQUEST FOR PRODUCTION NO. 12: Reference the Direct Testimony of
Tessia Park, p 18, discussing the Company's proposed Tariff Schedule 74 (Exhibit No.
5).
(a)Please identify the provision of Idaho Power's proposed Tariff Schedule
74 that would compensate QFs for curtailments occurring without providing the required
notice, or where the basis for the curtailment was not supported by the circumstances
described in 18 C.F.R. § 292.304(f). If no such provision is included, please explain
why.
(b)Please explain Idaho Power's basis for only proposing to provide QFs
one-hour notice prior to such curtailments. Is Idaho Power aware of any FERC or state
commission order that has authorized advance notice of one hour or less to QFs in
implementing 18 C.F.R. § 292.304(f)?
(c)Does Idaho Power believe that it has the right to curtail QFs to under 18
C.F.R. 292.304(f) even when the applicable QF contract provides for no such
curtailment? If so, please explain the basis for this position.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
(a)Tariff Schedule 74 does not contemplate curtailing QFs without providing
the required notice. Since it is not Idaho Power's intent to curtail QFs pursuant to
Schedule 74 without prior notice, no such provision was included.
(b)Because wind is intermittent and because QFs do not provide Idaho
Power with schedules for their generation, Idaho Power has no way of knowing how
much wind generation it is going to have on its system until usually the hour or even
minutes before a scheduled period. While Idaho Power is not aware of any Federal
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -6
Energy Regulatory Commission ("FERC") or state commission order that has authorized
advance notice of one hour or less to QFs in implementing 18 C.F.R. § 292.304(f),
there is nothing in the FERC rules which prohibits providing only one-hour notice.
(c) Yes, Idaho Power believes it has the right to curtail QFs under 18 C.F.R. §
292.304(f) even if the applicable QF contract provides for no such curtailment. It is
Idaho Powers position that all FERC rules related to PURPA, including 18 C.F.R. §
292.304(f), apply to QF projects regardless of whether or not those rules are specifically
mentioned in the firm energy sales agreements Idaho Power has with PURPA
developers.
The response to this Request was prepared by Tessia Park, Load Serving
Operations Director, Idaho Power Company, in consultation with Jason B. Williams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -7
REQUEST FOR PRODUCTION NO. 13: Reference the Direct Testimony of
Tessia Park, p. 11, stating, "Based upon the current price of natural gas, dispatch costs
of Langley Gulch will be approximately $22."
(a)What is the current price of gas used to calculate the $22 Langley Gulch
dispatch cost?
(b)What is the price of gas Idaho Power expects to pay when Langley Gulch
comes on line the summer of 2012, and the expected dispatch cost at that gas price?
(c)What price of gas does Idaho Power expect to pay for Langley Gulch, and
what is the associated expected dispatch cost annually over the next 20 years?
(d)What is the fixed cost of Langley Gulch in $/MWh? What is the fixed cost
of a QF to the Company?
RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
(a)A natural gas price of approximately $3/MMBtu results in an estimated
Langley Gulch dispatch cost of $22/megawatt-hour ("MM").
(b)Current forward gas prices for July 2012 indicate a cost of $2.40/MMBtu.
This would result in a Langley Gulch dispatch cost of $1 7.62/MWh.
(c)The 2011 IRP low-case, natural gas price forecast is currently viewed as
the best long-term forecast Idaho Power has available, although this forecast reflects
near-term gas prices that are higher than near-term forward market prices. This
forecast is relatively close to the most recent natural gas price forecast issued by the
Northwest Power and Conservation Council. The 2011 IRP low-case gas price forecast
and the resulting dispatch cost of Langley Gulch are provided through 2030, the end of
the 20-year planning horizon in the 2011 IRP, in the table below.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -8
I I
Langley Gulch
Gas Price Dispatch Cost
Year ($/MMBtu) ($/MWh)
2012 $4.60 $32.59
2013 $5.09 $35.89
2014 $5.43 $38.20
2015 $5.72 $40.22
2016 $6.03 $42.31
2017 $6.32 $44.27
2018 $6.59 $46.10
2019 $6.84 $47.83
2020 $7.14 $49.82
2021 $7.43 $51.85
2022 $7.57 $52.78
2023 $7.81 $54.42
2024 $8.10 $56.41
2025 $8.43 $58.65
2026 $8.76 $60.89
2027 $9.10 $63.17
2028 $9.47 $65.69
2029 $9.85 $68.30
2030 $10.24 $70.96
(d) The annual fixed costs of Langley Gulch over a 30-year life are presented
in the Excel file, Langley Gulch Fixed Costs, provided on the non-confidential CD.
Although the second part of the question does not specify or define what should
be considered a "fixed" cost for a QF contract, Idaho Power is assuming the fixed cost
of a QF contract would be the fixed rate contained in the contract. As presented on
page 8 of Company witness Stokes's testimony, the remaining future fixed cost of the
119 signed and approved contracts will be $3.6 billion throughout the term of the
agreements. Based on estimated generation of 44,414 GWh from these projects
throughout the term of the agreements, the average rate paid for this energy would be
$81 .06/MWh.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -9
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -10
REQUEST FOR PRODUCTION NO. 14: Reference the Direct Testimony of
Tessia Park, pp. 11-12, stating, "For example, the Company currently pays in the range
of low-$50 per MWh up to $85 or more per MWh for PURPA generation." Please
provide the rate ($/MWh) currently paid by Idaho Power, in electronic format, to its on-
line PURPA projects.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: Listed in the table
below are the 96 projects that were on-line as of the end of 2011, including the actual
generation received and actual payments made followed by a mathematical calculation
of the average price paid to each project (actual payments divided by actual generation
received).
As some projects may have received partial payments based on Mid-C pricing
rather than full contract price due to individual project performance issues, the on-line
date occurring during the year, and/or any other terms within the individual contracts
that trigger use of the Mid-C pricing. Therefore, these mathematical calculations may
understate the actual contract pricing contained within each contract.
Idaho Power Company
Cogeneration and Small Power Production
Calendar Year 2011 Data
kWh
Received Total Payment Mills/kWh
Project 1 1,087,372 $15,461.22 $14.22
Project 24,731,818 $1,214,017.11 $49.09
Project 3 4,033,251 $288,572.11 $71.55
Project 4 26,958,400 $1,191,124.31 $44.18
Project 14,119,755 $695,076.92 $49.23
Project 6 45,166,852 $2,483,799.85 $54.99
Project 7 9,890,645 $325,915.82 $32.95
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -11
Project 8 364,079 $24,628.86 $67.65
Project 9 1,538,523 $105,818.54 $68.78
Project 10 32,724,927 $2,799,414.85 $85.54
Project 11 8,994,362 $504,286.12 $56.07
Project 12 1,457,876 $106,175.29 $72.83
Project 13 3,517,162 $255,172.57 $72.55
Project 14 3,501,508 $233,620.57 $66.72
Project 15 2,294,728 $79,728.87 $34.74
Project 16 12,375,983 $933,162.37 $75.40
Project 17 1,486,296 $113,045.44 $76.06
Project 18 341,791 $27,169.23 $79.49
Project 19 336,320 $22,006.99 $65.43
Project 20 5,503,876 $498,645.89 $90.60
Project 21 1,663,687 $109,772.81 $65.98
Project 22 27,865,971 $1,494,915.55 $53.65
Project 23 60,803,541 $5,025,973.56 $82.66
Project 24 816,556 $11,516.21 $14.10
Project 25 24,118,463 $1,079,423.66 $44.76
Project 26 792,791 $54,830.57 $69.16
Project 27 26,287,291 $1,022,302.80 $38.89
Project 28 6,630,826 $423,980.39 $63.94
Project 29 3,490,406 $294,206.33 $84.29
Project 30 3,715,563 $248,306.49 $66.83
Project 31 45,701,096 $1,880,362.71 $41.14
Project 32 10,047,996 $976,820.13 $97.22
Project 33 11,237,377 $764,612.21 $68.04
Project 34 584,373 $43,327.90 $74.14
Project 35 15,516,564 $847,439.28 $54.62
Project 36 173,052 $3,741.38 $21.62
Project 37 4,026,261 $298,796.42 $74.21
Project 38 57,414,000 $3,696,680.41 $64.39
Project 39 3,138,705 $238,020.26 $75.83
Project 40 57,614 $4,045.76 $70.22
Project 41 4,293,599 $306,445.29 $71.37
Project 42 28,067,300 $2,009,237.53 $71.59
Project 43 8,950,184 $536,979.35 $60.00
Project 44 9,688,877 $520,129.13 $53.68
Project 45 23,842,171 $1,224,987.29 $51.38
Project 46 22,984,323 $1,569,319.74 $68.28
Project 47 20,582,000 $1,003,804.08 $48.77
Project 48 288,440 $24,467.97 $84.83
Project 49 8,737,146 $619,500.23 $70.90
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -12
Project 50 44,465,350 $2,454,027.64 $55.19
Project 51 1,322,861 $89,759.66 $67.85
Project 52 3,276,000 $251,301.96 $76.71
Project 53 632,707 $35,123.36 $55.51
Project 54 28,256,695 $1,469,467.90 $52.00
Project 55 79,969,152 $5,012,242.12 $62.68
Project 56 0 ($16,370.88) $0.00
Project 57 5,021,915 $333,058.32 $66.32
Project 58 327,000 $25,892.74 $79.18
Project 59 26,647,643 $1,823,974.37 $68.45
Project 60 59,971,693 $4,942,689.26 $82.42
Project 61 39,112,163 $1,790,026.90 $45.77
Project 62 1,172,709 $17,306.88 $14.76
Project 63 10,247,302 $842,404.14 $82.21
Project 64 7,076,157 $166,006.65 $23.46
Project 65 4,692,062 $279,048.53 $59.47
Project 66 1,614,796 $116,959.68 $72.43
Project 67 459,360 $31,239.64 $68.01
Project 68 33,717,881 $1,382,867.14 $41.01
Project 69 25,600,706 $485,901.38 $18.98
Project 70 58,964,236 $4,846,168.63 $82.19
Project 71 7,373,836 $667,546.37 $90.53
Project 72 30,261,229 $1,371,176.92 $45.31
Project 73 1,532,171 $110,714.59 $72.26
Project 74 855,725 $48,791.15 $57.02
Project 75 849,624 $18,180.39 $21.40
Project 76 784,438 $59,078.40 $75.31
Project 77 9,574,754 $471,800.48 $49.28
Project 78 24,934,140 $525,383.80 $21.07
Project 79 1,328,826 $90,186.77 $67.87
Project 80 1,421,621 $80,643.42 $56.73
Project 81 21,263,452 $820,345.93 $38.58
Project 82 1,014,648 $70,108.71 $69.10
Project 83 2,634,240 $171,410.61 $65.07
Project 84 23,680,433 $1,357,140.78 $57.31
Project 85 41,990,891 $2,788,303.77 $66.40
Project 86 1,940,769 $153,670.09 $79.18
Project 87 77,630,560 $4,454,338.67 $57.38
Project 88 143,348 $2,167.57 $15.12
Project 89 0 $0.00 $0.00
Project 90 30,023,728 $1,283,708.48 $42.76
Project 91 29,729,000 $1,520,184.75 $51.13
Project 92 82,103,275 $5,270,517.80 $64.19
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -13
Project 93 3,840,929 $313,304.57 $81.57
Project 94 9,204,697 $599,368.32 $65.12
Project 95 25,062,870 $2,752,182.42 $109.81
Project 96 679,086 $44,716.61 $65.85
Total 1,494,348,375 $89,674,855.76 $60.01
The response to this Request was prepared by Randy C. Allphin, Energy
Contract Coordinator Leader, Idaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -14
, , I S
REQUEST FOR PRODUCTION NO. 15: Reference the Direct Testimony of
Tessia Park, p. 23, stating, "The following example is based upon an actual generation
day in October 2011." Please provide in electronic format:
(a)The date of the referenced day in the example,
(b)The hourly (or less) load profile for the day,
(c)The hourly (or less) output of each of the resources used to meet the load
for the day,
(d)The dispatch cost of each of the resources used to meet the load for the
day,
(e)The heavy load cost of purchase power for the day,
(f)The cost of gas peaking units, if they were to be used, for the day.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
(a)The date of the referenced example is October 18, 2011.
(b)Please see the Excel file provided on the non-confidential CD.
(c)Please see the Excel file provided on the non-confidential CD.
(d)The response to this Request is confidential and will be provided in a
separate, confidential pleading to those parties that have executed the Protective
Agreement in this proceeding.
(e)There were no heavy load purchases of power in pre-schedule at market
prices of $27.44. The Company purchased 100 MW at $32.00 per MWh in real time to
meet the morning peak load requirements.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -15
(f) The response to this Request is confidential and will be provided in a
separate, confidential pleading to those parties that have executed the Protective
Agreement in this proceeding.
The response to this Request was prepared by Tessia Park, Director Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -16
REQUEST FOR PRODUCTION NO. 16: Reference the Direct Testimony of
Tessia Park, p. 23, stating, "The Company is proposing to apply this policy to all PURPA
contracts, both existing and new, that are projects which contain generator output
control limiters ("GOCLs") and are 10 MW or larger in size." Please provide a list of all
existing PURPA projects and identify those that have "GOCLs" and those that do not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: The response to this
Request is confidential and will be provided to those parties that have executed the
Protective Agreement in this proceeding.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -17
REQUEST FOR PRODUCTION NO. 17: Reference the Direct Testimony of
Tessia Park, p. 7, stating, the "limiting conditions on the amount of variable generation
from PURPA resources which Idaho Power can accommodate are not apparent during
periods of relatively high customer demand."
(a)Please define "relatively high customer demand" as used in this
statement.
(b)Please estimate the level of demand at which Idaho Power believes there
will be no limiting conditions for existing and contracted QFs.
(c)For the years 2010 and 2011, please provide the hours and days of the
year that Idaho Power's load fell below the level described in item (b).
RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
(a)Relatively high customer demand is not defined by a specific numerical
value but rather when conditions exist such that load demands exceed the minimum
hydro and thermal generation on the system.
(b)Idaho Power is unable to forecast the level of demand at which time there
will be no limiting conditions for existing and contracted Us as the level of demand is
dependent on factors which the Company does not control, output of various Us, delta
between minimum and maximum load on a given day, and the hydro conditions.
(c)The Company has not prepared the analysis requested.
The response to this Request was prepared by Tessia Park, Load Serving
Operations Director, Idaho Power Company, in consultation with Jason B. Williams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -18
REQUEST FOR PRODUCTION NO. 18: Reference the Direct Testimony of
Tessia Park, p. 14, stating, "Idaho Power has been working on an update to its wind
integration study for some time. However, difficulties in modeling Idaho Power's
electrical system and generation resources in the model used by the consultant hired to
perform the study, have delayed the completion of the study."
(a)Please describe the modeling errors referenced.
(b)Please provide any correspondence between Idaho Power and the
consultant describing the modeling errors.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
(a)Idaho Power has never characterized the reason for the delay in the
completion of the wind integration study as being due to "modeling errors." The
difficulties referenced are related to the setup and calibration of the model and the
validation of the results, which is a necessary process to ensure the model simulates
the operation of Idaho Power's resources in a manner consistent with real world
operations.
(b)No correspondence exists between Idaho Power and the consultant that
references "modeling errors."
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -19
REQUEST FOR PRODUCTION NO. 19: Reference the Direct Testimony of
Tessia Park, p. 20, stating, "Pursuant to FERC licenses Idaho Power has for its run-of-
river hydro electric projects, the Company is obligated to take whatever generation flows
through them; it does not have the ability to decrease or increase the generation."
(a)Please identify each of the run-of-river hydro plants and provide the
capacity of each.
(b)Please provide the FERC license for each project (in electronic format if
available).
(c)Please identify the provision (page number, section number, as
applicable) in each FERC license that Idaho Power relies on to determine it does not
have the ability to decrease or increase the generation.
(d)For each plant, please explain whether the plant has the operational
capability to spill water without generating electricity, and any restrictions on Idaho
Power's ability to do so.
RESPONSE REQUEST FOR PRODUCTION NO. 19:
(a) Following are the run-of-river hydro plants and their capacity:
Milner - 59.45 MW
Twin Falls - 52.74 MW
Shoshone Falls - 12.5 MW
Upper Salmon Falls A - 18 MW
Upper Salmon Falls B - 16.5 MW
Lower Salmon Falls —60 MW
Upper Malad - 8.27 MW
Lower Malad - 13.5 MW
Bliss —75 MW
Swan Falls —25 MW
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -20
(b)Electronic versions of the licenses identified above are provided in the
non-confidential CD.
(c)Mil ner. A complete reading of the Milner license shows that the Milner
project is designed to generate with flows that are not used for irrigation as they pass
through the project (run-of-river).
Twin Falls. A complete reading of the Twin Falls license shows that the
Twin Falls project is designed to generate with flows as they pass through the project
(run-of-river).
Shoshone Falls. A complete reading of the Shoshone Falls license shows
that the Shoshone Falls project is designed to generate with flows as they pass through
the project (run-of-river). See Article 401.
Upper Salmon Falls A. A complete reading of the Upper Salmon Falls
license shows that the Upper Salmon Falls project is designed to generate with flows as
they pass through the project (run-of-river). See Article 401.
Upper Salmon Falls B. A complete reading of the Upper Salmon Falls
license shows that the Upper Salmon Falls project is designed to generate with flows as
they pass through the project (run of river). See Article 401.
Lower Salmon Falls. A complete reading of the Lower Salmon Falls
license shows that the Lower Salmon Falls project is designed to generate with flows as
they pass through the project (run-of-river). See Article 401.
Upper Malad. A complete reading of the Malad license shows that the
Malad project is designed to generate with flows as they pass through the project (run-
of-river). See Article 401.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -21
Lower Malad. A complete reading of the Malad license shows that the
Malad project is designed to generate with flows as they pass through the project (run of
river). See Article 401.
Bliss. A complete reading of the Bliss license shows that the Bliss project
is designed to generate with flows as they pass through the project (run-of-river). See
Article 401.
Swan Falls. A complete reading of the Swan Falls license shows that the
Swan Falls project is designed to generate with flows as they pass through the project
(run-of-river).
In addition, the non-confidential CD contains a copy of a Settlement Agreement
between Idaho Power and the U.S. Fish and Wildlife Service which contains certain
environmental provisions that place constraints around how the Company operates the
Mid-Snake hydro projects (e.g.), Shoshone Falls, Bliss, Upper Salmon, and Lower
Salmon).
At run-of-river projects, generation increases as flow increases and generation
decreases as flow decreases.
(d) Each licensed facility has the physical capability to spill water without
generating electricity. The proposed operations in the applications for FERC licenses
and state water quality certifications did not include spill except when flows exceeded
plant capacity or when generators tripped off-line in emergency situations. To the
contrary, operations may require an amendment to the FERC licenses and/or state
water quality certifications.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -22
The response to this Request was prepared by Lewis Wardle, Senior Biologist,
Idaho Power Company, in consultation with Donovan E. Walker, Lead Counsel, Idaho
Power Company.
* *
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -23
.1 .,
REQUEST FOR PRODUCTION NO. 20: Reference the Direct Testimony of
Tessia Park, p. 23, stating, "the Company must maintain constant flows below Hells
Canyon dam for environmental compliance, thus limiting the ability to curtail generation
out of the Hells Canyon Complex to no less than approximately 350 MW."
(a)Please identify the individual plants/dams at the Hells Canyon Complex
and the MW capacity of each.
(b)Please explain the environmental compliance requirement for each that
limits the ability to curtail generation and provide the minimum generation of each
individual project. Please identify the government agency imposing the compliance
requirement.
(c)For each plant, please explain whether the plant has the operational
capability to spill water without generating electricity. Please explain why generation
cannot be curtailed to 0 MW by spilling, or to any cumulative output below 350 MW for
the Complex.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20:
(a)The Hells Canyon Complex consists of three projects: Brownlee, Oxbow,
and Hells Canyon. The nameplate MW ratings for the aforementioned projects are as
follows: Brownlee-585.40, Oxbow-1 90.00, and Hells Canyon-391.50
(b)FERC:
Brownlee, Oxbow, Hells Canyon
. Minimum reservoir level
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -24
Hells Canyon Dam
• Minimum flow 13,000 cubic feet per second ("cfs") at Lime
Point 95 percent of the time (flows less than 13,000 cfs
must be negotiated with Corps of Engineers)
• Maximum ramp rate 1 ft. / hour
• Minimum instantaneous flow 5,000 cfs
Corps of Engineer ("COE"):
Hells Canyon Dam - Requested 13,000 cfs variance
• Minimum instantaneous flow 8,500 cfs (measured at Snake
River at Hells Canyon) when previous 3-day moving
average Brownlee Reservoir inflow is at or above 8,500
cfs.
• Minimum instantaneous flow 11,500 cfs (measured at
Snake River below McDuff Rapids) unless it would require
drafting Brownlee Reservoir.
• When the previous 3-day moving average for Brownlee
Reservoir inflow is less than 8,500 cfs, the instantaneous
minimum Hells Canyon flow shall not fall below the
previous 3-day moving average for Brownlee Reservoir
inflow.
National Ocean Atmospheric Administration ("NOAA") - National Marine
Fishery Services: (Endangered Species ACT)
• Provide stable Hells Canyon outflow for salmon spawning
and establish minimum flow level for spring emergence.
• Provide minimum flow level for spring emergence.
• Perform entrapment surveys for spring emergence salmon
to mitigate 4" ramp rate.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -25
Environmental Protection Agency ("EPA") - State Department of
Environmental Quality:
• Maintain total dissolved gases ("TOG") below Hells Canyon
Dam below 110 Parts Per Million ("PPM")
United States Fish and Wildlife Service:
• Maintain TDG below 110 PPM to protect Endangered
Species Bull Trout.
(c) Power plants in the Hells Canyon project are not able to decrease
generation to 0 and spill water without generating electricity for the following reasons, as
per regulatory standard requirements:
North American Electric Reliability Corporation ("NERC") - Western
Electric Coordinating Council ("WECC"):
• NERC Standard BAL-002-1 Disturbance Control Standard
("DCS" ) - utilize contingency reserve to balance resources
and demand and return interconnection frequency within
defined limits following a reportable disturbance.
• WECC Standard BAL-002-WECC-1 Contingency Reserve
- provide reliable operation of the interconnected power
system. Adequate generating capacity must be available at
all times to maintain scheduled frequency, and avoid loss
of firm load following transmission or generation
contingencies.
• NERC Standard BAL-005-0.2b Automatic Generation
Control ("AGC") - provide necessary AGC to calculate
Area Control Error ("ACE") and to routinely deploy the
Regulating Reserve.
• WECC Standard BAL-STD-002-0 Operating Reserve -
provide adequate generating capacity to be available at all
times to maintain scheduled frequency and avoid loss of
firm load following transmission or generation
contingencies. This generating capacity is necessary to
supply requirements for load variations, replace generating
capacity and energy lost due to forced outages of
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -26
generation or transmission equipment, meet on-demand
obligations, and replace energy lost due to curtailment of
interruptible imports.
FERC:
. Maintain generation MW levels for undesignated sales.
Hells Canyon Dam TDG will elevate over 110 PPM for spill above 3000 cfs.
The response to this Request was prepared by Tessia Park, Director Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -27
REQUEST FOR PRODUCTION NO. 21: Reference the Direct Testimony of
Tessia Park, p. 1, stating dispatch costs for the Company's coal units are approximately
$30/MWh and for Langley Gulch are $22/MWh.
(a)Please explain why the Company would not take its coal plants offline and
instead run Langley Gulch during times when it expects to have light loading periods.
(b)For Langley Gulch, the run-of-river hydro projects, and the Hells Canyon
Complex, please provide the minimum and maximum output for each that Idaho Power
could reasonably expect to obtain during periods of the year that Idaho Power expects
to experience light loading events. Please explain the basis for the estimates for each
category.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21:
(a)Coal plants cannot be shutdown and restarted on a daily basis and,
consequently, they can only be turned down to minimum generating levels during light
load periods in order to have their capacity available for the next days' heavy load
period.
(b)When on-line, Langley Gulch will typically be operated during light loading
events between its minimum and maximum generating levels. It is expected that
Langley Gulch will be dispatched somewhere between its minimum and maximum
levels depending primarily on system load, actual wind generation, and plant
economics. The minimum and maximum levels vary seasonally, but are reasonably
expected to be about 160 MW and 300 MW, respectively.
The minimum and maximum output for the run-of-river hydro projects during light
loading events is dependent on water conditions in the Snake River Basin as no
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -28
significant reservoir storage is available at any of Idaho Power's projects. The water
conditions are very predictable with respect to short-term planning; however, a longer-
term basis review of Snake River Basin streamflow records indicates pronounced
season-to-season and year-to-year variability. Therefore, expected minimum and
maximum output levels depend on the type of water year. For capacity planning
purposes, under median water, Idaho Power expects to get 285 MW from the run-of-
river plants (see 2011 IRP, page 117)
For light loading events occurring during the nearly eight month period from mid-
October through May, the minimum output for the Hells Canyon Complex is driven by
Idaho Power's efforts to maintain flow levels suitable for Snake River fall Chinook
salmon spawning, rearing, and emergence. Idaho Power manages its operations to
provide stable flows during the approximately two month spawning period (mid-October
to mid-December) and, after spawning, maintains the Hells Canyon Complex outflows
at or above the stable spawning flow level through rearing and emergence (mid-
December through May). The spawning flow level varies from year-to-year depending
on water supply in the Snake River Basin, but, in the past, has ranged from about 8,500
cfs to 14,000 cfs. While minimum output can vary from hour-to-hour depending on
water management for the three dam complex, it is reasonable to estimate minimum
output of about 300 MW during years when spawning flows of 8,500 cfs are provided,
and about 550 MW during years when spawning flows of 14,000 cfs are provided.
Outside of the mid-October through May period, Idaho Power maintains minimum
Hells Canyon Complex outflows in compliance with downstream navigation
requirements. These requirements depend on several factors, including inflow to
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -29
I & , *
Brownlee Reservoir and Salmon River discharge, but generally Idaho Power maintains
Hells Canyon Complex outflows of 6,500 cfs or higher during this period (June to mid-
October). High Brownlee inflow conditions, particularly during the early summer, may
necessitate Hells Canyon Complex outflows substantially greater than 6,500 cfs.
Minimum output during these high flow periods is variable, and typically quite high.
During periods when Hells Canyon Complex outflows can be reduced to levels of
approximately 6,500 cfs, it is reasonable to estimate minimum output levels of about
1IIYATi
With respect to maximum output, Idaho Power manages the Hells Canyon
Complex such that maximum output during light loading periods is typically only
nominally higher than the minimum output obtained. Capacity during these periods is
not needed, and the flexible generators of the Hells Canyon Complex can vary their
output accordingly.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -30
REQUEST FOR PRODUCTION NO. 22: Reference the Direct Testimony of
Tessia Park, p. 24, describing conditions where the Company has sufficient base load
generation to service 1,100 MW of load.
(a)For the years 2010 and 2011, please provide the hours and days of the
year that Idaho Power's load was at or below 1,100 MW.
(b)Please provide the number of hours, days, weeks, or months in advance
that Idaho Power can accurately predict that reaching loads this low will occur.
(c)For each such occurrence, please provide the maximum load within the 7
days following the light loading event.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22:
(a)There were 89 hours in the years 2010 and 2011 where the Idaho Power
system load was 1100 MW or less (data from P1 Series AGC_TOTALL). Idaho Power
experienced load of 1100 MW or less in the months of April, May, June, October, and
November of 2010 and in the months of April, May, and October of 2011. Table 22.1
provided on the non-confidential CD lists the hours when the system load was 1100 MW
or less during the years 2010 and 2011.
(b)Because the term "accurately predict" is subject to a number of
interpretations and is not clearly defined in this Request, Idaho Power is unable to
provide the requested information.
(c)Table 22.2 provided on the non-confidential CD lists the Idaho Power
system load for every hour in the months of 2010 and 2011 where there was at least
one hour during the month when the system load was 1100 MW or less (data from P1
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -31
Series AGC_TOTALL). June 2011 data is included to meet the requirements specified
in question 22(c) of this Request.
The response to this Request was prepared by Thomas A Noll, Ph.D., Senior
Planning Analyst, Idaho Power Company, in consultation with Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -32
REQUEST FOR PRODUCTION NO. 23: Reference the Direct Testimony of
Tessia Park, p. 24, describing the minimum base generation (300 MW thermal, 817 MW
hydro, and 50 MW non-intermittent PURPA) to be near 1,100 MW. Please explain why
Idaho Power could not plan for an expected light loading period coinciding with possible
excess QF generation by un-designating the network resource status of a specified
quantity of this base generation, and using its fast-ramping, remaining Hells Canyon
capacity to serve load in the event that intermittent QF generation did not occur as
predicted.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: The particular network
resource that is undesignated must be used to supply energy for a sourced sale. If
Idaho Power undesignates and sells power from a baseload resource, that resource
must be able to supply the system sale. In order to sell firm resources into the market,
Idaho Power limits the amount of generation from the baseload resources to 50 percent
of that resource's available generation capacity to ensure sufficient generation exists
from that facility to supply the firm sale and to comply with Idaho Power's Open Access
Transmission Tariff ("OATT"). Additionally, Hells Canyon is limited in ramping ability
due to downstream river level changes of one foot per hour. This severely limits the
ability for Hells Canyon units to ramp to support large deviations in outflow. Idaho
Power sets aside capacity in the pre-schedule or day ahead to cover reserve
requirements and meet load demands. Idaho Power's procedures require the Company
to sell or buy energy to balance the system in pre-schedule based on generation and
load forecasts, this takes into account wind forecasts, as well as limitations on hydro
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -33
' 0
stream flows and the ability to ensure compliance with FERC requirements and the
OAU.
The response to this Request was prepared by Tessia Park, Director Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -34
REQUEST FOR PRODUCTION NO. 24: Reference the Direct Testimony of
Mark Stokes, p. 7, presenting a figure titled "Idaho Power Compared to Regional RPS
Standards."
(a)Please explain which state or proposed federal RPS or RES standard
Idaho Power used to determine whether the generation from the QFs included in the..
graph would qualify under the applicable standard.
(b)Please provide Idaho Power's work papers used to generate the 19%
RPS compliant generation figure.
(c)Please list generation facilities that comprise the 19% RPS compliant
generation, including their generation type for each (wind, small hydropower,
cogeneration, etc.), nameplate capacity, assumed annual generation, and whether the
Company will receive any REC's from the QF.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24:
(a)The federal Renewable Electricity Promotion Act of 2010 ("RES") standard
referenced on pages 6 and 7 in the Direct Testimony of Company witness Stokes is the
same RES assumed in Idaho Powers 2011 IRP. The following paragraph is from page
17of the 2011 IRP:
For the 2011 IRP, the portfolios being analyzed are designed
to substantially comply with the Renewable Electricity
Promotion Act of 2010 (S. 3813) introduced in Congress in
September 2010, by Senator Jeff Bingaman (D—New
Mexico). Under the proposed bill, an initial renewable
requirement of 3 percent would begin in 2012 and would
increase to 15 percent by 2021.
(b)Please see the Excel file, PURPA Comparison to State RPS
Requirements, provided on the non-confidential CD.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -35
C C
(c) Please see the worksheet titled "PURPA Contracts" which is included in
the Excel file responding to Request 24(b) above. As pointed out on page 7 of the
Direct Testimony of Company witness Stokes:
This comparison is done only to show the magnitude of QF
development compared to various mandatory RPS
requirements. Because Idaho Power does not receive the
renewable energy certificates ("REC") from most of its QF
generation, PURPA generation cannot be used to meet any
potential RPS requirements and Idaho Power cannot
represent to customers they are receiving renewable energy
from the QFs for which it does not receive the REC5.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -36
REQUEST FOR PRODUCTION NO. 25: Reference the Direct Testimony of
Mark Stokes, p. 14, "Because a vast majority of the new PURPA contracts are for wind
projects, Idaho Power will still have to build new resources in order to meet projected
growth in peak-hour demand." Please indicate the new resources, by type of resource,
the Company assumes it will need to build, and the year it expects to need these
resources.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25: Below is an excerpt
from page 16 of Company witness Grow's testimony in the current Langley Gulch rate
case (IPC-E-1 2-1 4):
Q. . . . does Idaho Power's current load and resource
balance indicate Langley Gulch is still needed in the summer
of 2012?
A. Yes. The peak-hour load and resource balance from the
2011 IRP was updated to include the Company's latest load
forecast, which accounts for reduced Hoku load based on
the recently proposed terms of a restated contract currently
before the Commission for approval, an updated forecast of
Public Utility Regulatory Policies Act of 1978 generation
taking into account recent contracts and expected on-line
dates, and updated estimates of transmission capacity
available for July market purchases from the Pacific
Northwest. Without Langley Gulch, the updated peak-hour
load and resource balance shows July deficits of 28 MW in
2012, 169 MW in 2013, and 224 MW in 2014. With the
Langley Gulch plant being available this summer, Idaho
Power will be able to reliably meet the summer peak needs
of customers.
The addition of large quantities of PURPA wind generation has not delayed the
need for the Langley Gulch plant in the summer of 2012, nor has it delayed the need for
the Boardman to Hemingway transmission project, the other major resource identified in
the Company's 2011 IRP. Because wind resources only provide a peak-hour capacity
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -37
9k U I
factor of 5 percent, Idaho Power continues to face summertime capacity shortages in
the future.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
U
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -38
REQUEST FOR PRODUCTION NO. 25Fsicl: Reference the Direct Testimony of
Mark Stokes, p. 16, presenting a figure titled "Average PURPA Price Compared to Mid-
C Index, 2002-2022."
(a)Please provide the average annual energy cost and capacity cost
($/MWh) of each of the Company's thermal resources (Bridger, Valmy, Boardman,
Danskin, Bennett Mountain, and Langley Gulch) over the same time frame.
(b)Please provide the figures for the average Mid-C Index compared and the
PURPA Price from 1980 to 2002, or as far back as available. Please also include the
energy and capacity costs for the coal plants listed in item (a) for years where those are
available prior to 2002.
(c)Is the Mid-C Index price used in the figure a spot market price or the price
of firm power? If it is a spot price, please provide an estimate in the difference in cost
($/MWh) of the Average Mid-C Index and the cost to secure firm market purchases from
Mid-C, and explain the basis for the estimate.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25Isicl:
(a) Please see the confidential Excel file, Thermal Resource Costs.xlsx,
provided on the confidential CD for the requested information pertaining to the
Company's thermal resources. The confidential CD will be provided to those parties
that have executed the Protective Agreement in this proceeding. The workbook on the
confidential CD contains separate worksheets showing historical and forecast costs.
Please note, Idaho Power does not track the capacity cost of resources that are in
operation; therefore, historical capacity cost information is not available. The forecast
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -39
information is taken from the AURORA model, which does not include capacity cost
information.
(b)Please see the confidential Excel file, PURPA Cost Mid C
Comparison.xlsx, provided on the confidential CD for the prices used to create the chart
on page 16 of Company witness Stokes's testimony. The confidential CD will be
provided to those parties that have executed the Protective Agreement in this
proceeding. Idaho Power only compiled Mid-C Index pricing back to January 2001 in
order to create the chart.
(c)The Mid-C index prices used to create the historical figures are monthly
average heavy and light load Dow Jones Index prices for firm energy. Intercontinental
Exchange ("ICE") and broker quotes were used for the Mid-C forward price curve
The cost of firm transmission from Mid-C to Idaho Power's system varies, but is
approximately $4/MWh when the transmission system is not experiencing any
constraints, which is during most months of the year. In the summer months of July and
August, when the transmission system does experience constraints, the costs can
increase to approximately $6-$7/MWh as the use of alternate paths (if available) may be
required to deliver the energy to Idaho Power's system.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -40
REQUEST FOR PRODUCTION NO. 26[sicl: Reference the Direct Testimony of
Mark Stokes, p. 18, describing the differential between what Idaho Power will pay for
PURPA generation in 2012 and the amount it would pay to purchase the same amount
of generation as a "firm" product in the Mid-C market.
(a)Please provide a detailed definition and an example of a "firm" product,
including the maximum term (years and months) for which Idaho Power could secure a
firm market purchase in 2012. Does this cost include the cost of firm transmission from
Mid-C to Idaho Power's system?
(b)Please estimate the amount of firm transmission (MW) Idaho Power
possesses or could secure from Mid-C to Idaho Power's loads.
(b)[sic] Using the same figures for the cost of firm market product used in
the testimony, please provide the differential for the cost for Langley Gulch (including all
variable and fixed costs passed onto customers through rates) for each year from 2012
to 2021, in dollars and in $/MWh. Please prorate the costs of market purchases for
2012 to account for the date Idaho Power estimates Langley Gulch costs will be
incurred by customers in that year.
(c)Please provide a detailed explanation of the assumptions used in the
calculation in the testimony and in the calculations in response to this request.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26[sicl:
(a) The following is taken from the Western Systems Power Pool ("WSPP")
website (www.wspi.orq) which includes information regarding energy trading in the
western United States:
The Current WSPP Agreement effective October 21, 2011, is
the most commonly used standardized power sales contract
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -41
in the electric industry. It is approved by the FERC and used
by jurisdictional and non-jurisdictional entities. Once signed,
the Agreement allows instant access to power trading within
the membership.
The mission of the organization is to provide a catalyst for an
efficient and robust wholesale electric power market. WSPP
accomplishes this by constantly facilitating refinements to the
Agreement and promoting trading relationships.
Under the WSPP Agreement, a "firm" product is defined as a firm capacity and/or
energy transaction whereby the Seller has agreed to sell or exchange and the
Purchaser has agreed to buy or exchange for a specified period available capacity with
or without associated energy which may include a Physically-Settled Option and a
capacity transaction in accordance with the Agreement, including Service Schedule C,
and any applicable Confirmation. The current maximum term at Mid-C on the ICE is
through the 2015 calendar year. The cost does not include transmission from Mid-C to
Idaho Power's system.
(b)Each month, the Idaho Power Delivery business unit notifies Idaho
Power's Power Supply business unit of the transmission allocations set aside to serve
network load for the next 14 months. Monthly amounts vary, but July has historically
been the most constrained month. The most recent report from Delivery indicates a
total of 134 MW of firm transmission capacity between Mid-C and Idaho Power is set
aside to serve network load in July 2012.
(b)[sic] Idaho Power has not performed this analysis or compiled the data
that would be required.
(c)The comparisons between the cost of PURPA generation and firm
purchases from the Mid-C market are based on the fixed contract price of PURPA
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -42
4 I
generation multiplied by the expected generation from each project on a monthly basis.
The Mid-C market comparison was done by taking the same amount of energy and
multiplying it by the same long-term forward price curve provided in the Company's
response to Exergy's Production Request No. 25[sic].
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -43
REQUEST FOR PRODUCTION NO. 27[sicl: Reference the Direct Testimony of
Mark Stokes, p. 21, stating, "There are several times when QF generation has and will
generate at or close to nameplate capacity. For example, on December 21, 2011,
Idaho Power received 7,028 MWh (293a aMW) from the 20 PURPA wind projects on-
line (nameplate rating of398 MW)." Please provide the same figures and date where
wind QFs have generated closest to nameplate capacity.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27Isicl: The hourly MWh
output and nameplate capacity factor for all PURPA wind projects for the period 2010-
2011 is provided in the Excel file, PURPA Wind Data.xlsx, provided on the non-
confidential CD. Please note that a few dates have been highlighted as having possible
erroneous data (August 21, 2010, through August 23, 2010, and October 20, 2010)
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -44
' 4 4 i
REQUEST FOR PRODUCTION NO. 28[sicl: Reference the Direct Testimony of
Mark Stokes, p. 21, comparing the cost of wind QF output on December 21, 2011 to the
cost of the short-term, daily average Mid-C market price.
(a)Please provide the MWh output and capacity factors for each of the
Company's thermal units on December 21, 2011.
(b)Please provide the MWh cost, including both energy and capacity of the
Company's thermal resources on December 21, 2011.
(c)Please provide the long-term, firm Mid-C market price for the same date,
and please add to the cost for firm transmission from Mid-C to Idaho Power's system.
Please explain any assumption used in providing these costs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 28Fsicl:
(a)Please see the Excel file provided on the non-confidential CD which
includes the requested data.
(b)Please see the Excel file provided on the non-confidential CD which
includes the available requested data. Please note, Idaho Power does not track the
capacity cost of resources that are in operation; therefore, that information is not
available. In addition, dispatch costs for each of the three units at the Danskin Project
are provided; however, variable operations and maintenance and fuel costs are tracked
at the plant level and more detailed, unit specific information is not available.
(c)On December 20, 2011, the day-ahead price for December 21 was
approximately $30/MWh. During real-time on December 21, the price was
approximately $22/MWh. The cost of firm transmission from Mid-C to Idaho Power's
system varies, but is approximately $4/MWh when the transmission system is not
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -45
experiencing any constraints, which is during most months of the year. In the summer
months of July and August, when the transmission system does experience constraints,
the costs can increase to approximately $6-$7/MWh as the use of alternate paths (if
available) may be required to deliver the energy to Idaho Power's system.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -46
REQUEST FOR PRODUCTION NO. 29Isicl: Reference the Direct Testimony of
Mark Stokes, p. 39, stating, "The estimated 20-year, levelized cost of Langley Gulch is
$68.55 per MWh using a 90 percent capacity factor assumption (to be consistent with
the SAR capacity factor assumption), and Idaho Powers current natural gas price
forecast."
(a)Please provide work papers and all cost assumptions for the $68.55 per
MWh figure for Langley Gulch, including interconnection and transmission costs, gas
price and transportation/storage costs, heat rate, assumed heat rate degradation,
equivalent availability factor, capital cost, variable O&M, fixed O&M, O&M escalation
rates, and inflation, as well as any other cost assumptions. Please provide the basis for
each assumption for each of the listed items.
(b)Please provide the levelized $/MWh cost of Langley Gulch for both energy
and capacity at the 84% capacity the Company expects the facility will have available
for planning purposes. Reference IPUC Order 30392, p. 17.
(C) Please provide the levelized $/MWh cost of Langley Gulch for both energy
and capacity at the 20 year average 49% capacity factor provided in Karl Bokenkamp's
Direct Testimony, p. 23.
(d) Please explain if Idaho Power will commit to pass onto its customers a 20-
year levelized cost for Langley Gulch that will not exceed the estimates above (allowing
for adjustment to customers' rates only to account for different capacity factors).
RESPONSE TO REQUEST FOR PRODUCTION NO. 29Isicl:
(a) For questions (a), (b), and (c), please see the appropriate confidential file
provided on the confidential CD. The confidential CD will be provided to those parties
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -47
that have executed the protective agreement in this matter. Calculations in each of the
three confidential spreadsheets include assumptions for all of the factors listed in
question (a) with the exception of heat rate degradation, which has no material impact
on the levelized production cost, and equivalent availability factor which is not
necessary to calculate the levelized cost of production. For question (a), please see the
confidential file, PURPA CCCT 90%.pdf, provided on the confidential CD.
(b)Please see the confidential file, PURPA CCCT 84%.pdf, provided on the
confidential CD. The confidential CD will be provided to those parties that have
executed the protective agreement in this matter.
(c)Please see the confidential file, PURPA CCCT 49%, provided on the
confidential CD. The confidential CD will be provided to those parties that have
executed the protective agreement in this matter.
(d)No.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -48
REQUEST FOR PRODUCTION NO. 30Fsicl: Please provide all of the current
assumptions for the gas SAR model for all inputs used to generate the 20-year
levelized, non-fueled, published avoided cost rate of $70.92 per MWh, discussed in Mr.
Stokes' Direct Testimony, p. 39.
RESPONSE TO REQUEST FOR PRODUCTION NO. 30Fsicl: Seventy Dollars
and Ninety-two Cents ($70.92) per MWh is the levelized price for a 20-year contract
coming on-line in 2013 as stated in the attachment to Idaho Public Utilities Commission
("Commission) Order No. 32337 titled, Idaho Power Company, Avoided Cost Rates for
Non-Fueled Projects, August 30, 2011, $IMWh.
Please see Commission Order No. 32337 for the information requested.
The response to this Request was prepared by Randy C. Aliphin, Energy
Contract Coordinator Leader, Idaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
.1
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -49
REQUEST FOR PRODUCTION NO. 31Isicl: Reference the Direct Testimony of
Mark Stokes, p. 32, lines 5-8. Please provide the solar integration study relied upon by
Idaho Power. If no such study exists, please explain the basis for the assumptions
regarding solar integration, and steps the Company plans to take to accurately compute
that alleged cost.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31Fsicl: The issue of
applying an integration charge to solar QF projects was raised by Commission Staff in
the recent Interconnect Solar QF contract case (Case No. IPC-E-1 1-10, Order No.
32384). Idaho Power agrees with Commission Staff comments on the Interconnect
Solar case in the belief that solar integration costs are material and potentially
comparable to wind integration costs. When the issue of solar integration was raised as
part of the Interconnect Solar case, Idaho Power did some informal research to see
what kind of work had been completed by others related to the cost of integrating solar
resources on electrical systems and found very limited work on this topic. A study
report released by the Ernest Orlando Lawrence Berkeley National Laboratory in
September 2010 titled The Implications of Wide-Area Geographic Diversity for Short-
Term Variability of Solar Power concludes that "the cost of accommodating the short-
term variability of similarly sited solar and wind plants is expected to be comparable in
the Southern Great Plains region." -
Idaho Power is nearing the completion of its updated wind integration study and
as soon as the results of that study are vetted through a public and technical expert
review process, the Company plans to use the same model to study solar integration.
Delays in completing the wind integration study were related to model calibration and
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -50
'I
performance issues, which Idaho Power believes have been resolved. Therefore, the
expectation is that the solar integration study could be completed in a shorter time
frame than has been necessary for the wind study. Based on the informal research
conducted for the Interconnect Solar case, Idaho Power believes it is reasonable to use
the $6.50/MWh stipulated wind integration charge for solar QF projects until a specific
solar integration charge is established.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -51
REQUEST FOR PRODUCTION NO. 32Fsicl: Reference the Direct Testimony of
Mark Stokes, p. 45, recommending implementation of "a PURPA QF contraction
process and negotiation tariff schedule." Please provide Idaho Power's proposed
negotiation tariff. If no proposed tariff exists, please describe the procedures Idaho
Power recommends, and when Idaho Power plans to file the tariff.
RESPONSE TO REQUEST FOR PRODUCTION NO. 32Fsicl: Idaho Power is
still developing the specific tariff referenced. The Company's intentions are that it will
be similar to the Rocky Mountain Power proposed schedule 38 attached as Exhibit 202
to the direct testimony of Paul H. Clements submitted in this case. Any such proposed
tariff would be filed at an appropriate time during the course of this case.
The response to this Request was prepared by Randy C. Allphin, Energy
Contract Coordinator Leader, Idaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -52
REQUEST FOR PRODUCTION NO. 33[sicl: Reference the Direct Testimony of
Karl Bokenkamp, p. 25, describing Idaho Power's proposed assumption that each
thermal unit will assigned an incremental cost based on full load operation.
(a)Is it true that when a thermal unit is operated at less than full load that the
incremental cost per MWh increases?
(b)For each of the Company's thermal units, please provide: (1) heat rate at
maximum output, (2) heat rate at minimum operating output, (3) incremental energy
cost at the heat rate in (1) and (2).
(c)For each of the Company's thermal units, please provide the number of
hours per year in the years 2008 through 2011 that the unit operated at full load
operation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 33Fsicl:
(a)It is true that when a thermal unit is operated at substantially less than full
load, the incremental cost per MWh does increase. This is because the efficiency of a
generating unit decreases when it is operated at substantially below its design loading.
However, depending on design of the individual unit, the highest operating efficiency
(the best or lowest heat rate) may occur at less than full load. This is similar to fuel
efficiency for your car - your car may be capable of running at 70 miles per hour, but
your best fuel efficiency may occur at 55 miles per hour.
(b)Please see the Excel file provided on the non-confidential CD.
(c)Please see the Excel file provided on the non-confidential CD. In addition
to providing the requested information, another analysis has been conducted to
determine the number of hours that each unit operated at or above 90 percent of full
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -53
4
1 4 I
load. The number of hours of operation at or above 90 percent of full load provides a
good indication of the number of hours the units were operated at high loads.
The response to this request was prepared by Karl Bokenkamp, Director
Operations Strategy, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -54
REQUEST FOR PRODUCTION NO. 34[sicl: Reference the Direct Testimony of
Karl Bokenkamp, p. 15, stating, "As an example, out of a total of 157,776 hours in an
AURORA simulation for a 22 megawatt ("MW") wind project, the new methodology
assigned an avoided cost of $0/MWh in 1,563 hours. This works out to about 1 percent
of the time, or 87 hours per year." Please provide the complete AURORA output from
this simulation run along with a full explanation of the how the new methodology is
implemented.
RESPONSE TO REQUEST FOR PRODUCTION NO. 34Fsicl: Please see the
Company's Response to Staff's Production Request No. I for the requested
information. More specifically, please see the file, Alternative IRP Methodology _2011
IRP no carbon no gas & load_2013-2030.xdb, provided on the AURORA non-
confidential CD
For another presentation of the AURORA analysis results, please see the first
tab of Excel file, IPCO Hourly Incremental Cost Wrkbk.xlsx, provided on the non-
confidential CD provided in the Company's response to Staff's Production Request No.
2.
The proposed new methodology and its implementation are described in detail
beginning on page 10 of Company witness Bokenkamp's direct testimony. Discussion
of the proposed new methodology and examples of its implementation for determining
the avoided cost of energy are discussed on pages 11 through 22. Discussion of
AURORA inputs and assumptions used to determine the avoided cost of energy are
covered on pages 24 through 28. The Company is proposing no changes to the
methodology it is currently using to determine the avoided cost of capacity — this is
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -55
b
discussed briefly on pages 22 through 24. The IRP methodology and the methodology
the Company is currently using to determine the avoided cost of capacity is discussed in
detail beginning on page 29 of Company witness Stokes's direct testimony.
The response to this Request was prepared by Karl Bokenkamp, Director
Operations Strategy, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -56
REQUEST FOR PRODUCTION NO. 35[sicl: Reference the Direct Testimony of
Karl Bokenkamp, p. 15, stating,
Idaho Power can look at several different hypothetical cases
to illustrate how the methodology will assign incremental
costs. For example, in case I load is 2,000 MW, the system
is balanced, Idaho Power has one or more thermal units in
operation, and there are no purchases; in case 2, identical
conditions exist with the following exception, a "new" QF
generates and delivers one MWh of energy to Idaho Power's
system. One of two things must happen for the system to
remain balanced either Idaho Power's resources must
reduce output by one MWh or one MWh is sold into the
market.
Please provide the complete AURORA outputs from the case I and case 2 runs along
with a full explanation of the how the new methodology is implemented to produce the
values reported for each case in Mr. Bokenkamp's testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 35Fsicl: The hypothetical
cases referenced in Company witness Bokenkamp's testimony are simply examples to
illustrate how the proposed new methodology determines the incremental costs to Idaho
Power for energy which, but for purchase from the QF, Idaho Power would generate
itself or purchase from another source. There is no AURORA analysis or AURORA
output associated with these hypothetical examples.
The first hypothetical situation illustrates how the proposed new methodology for
determining the avoided cost of energy works when Idaho Power is not making market
purchases. The second hypothetical situation illustrates how the proposed new
methodology for determining the avoided cost of energy works when Idaho Power I
making market purchases.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -57
The response to this request was prepared by Karl Bokenkamp, Director
Operations Strategy, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -58
REQUEST FOR PRODUCTION NO. 36Isicl: Reference the Direct Testimony of
Karl Bokenkamp, p. 24, proposing to continue using the peak-hour capacity factor
calculation that is currently utilized. Please explain fully the "peakhour capacity factor"
and demonstrate how it is used in the calculation of avoided costs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 36[sicl: A complete
description and example is contained in the Idaho Power Company testimony provided
by Mark Stokes in this, case. Specifically Exhibit No. 3, beginning on page 16.
The response to this Request was prepared by Randy C. Aliphin, Energy
Contract Coordinator Leader, Idaho Power Company, in consultation with Donovan E
Walker, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -59
REQUEST FOR PRODUCTION NO. 37Fsicl: Reference the Direct Testimony of
Karl Bokenkamp, p. 29, "Idaho Power proposes that any QFs with signed contracts and
any 'queued' QFs be included in Idaho Power's resource portfolio for purposes of
calculating future avoided costs because they can impact future avoided costs. For
purposes of calculating avoided costs, Idaho Power proposes that upon its receipt of a
written request from a QF for contract pricing, the QF is designated as 'queued."
(a)For the years 2008 through 2012, please identify the QFs from whom
Idaho Power has received a written request for contract pricing with IRP methodology
rates (using numbers or other identifiers to preserve confidentiality if necessary).
(b)For each of the projects listed in response to (a), please provide the date
of the request for pricing, and whether the QF executed a PPA with Idaho Power for the
project, and whether the IPUC has approved the PP A for which pricing was requested.
RESPONSE TO REQUEST FOR PRODUCTION NO. 37[sicl:
(a) - (b) Idaho Power does not keep detailed historical records of all
requests received that do not evolve into a completed purchase power agreement.
However, below is a list of projects that Idaho Power has recollection of making these
requests in recent years.
Resource
Type
Proposed
MW
Individual Project Detail
Date of Request Contract status
Cogen 97.00 Nov-Il
Hydro 2.25 Feb-12
Solar 20.00 Sep-1 1
Solar 60.00 2008, 2010 and 2012
Solar 20.00 Mar-Il
Solar 20.00 Mar-1 I
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -60
4
Solar 20.00 Nov-1 1
Solar 20.00 Nov-1 I
Solar 20.00 Nov-1 1
Solar 40.00 Jun-1 I
Solar 35.00 Sep-1 I
Wind 80.00 Sep-1 I
Wind 38.00 Sep-08 Approved Contract,
Project on-line
Wind 80.00 Jan-10 Approved Contract,
Project on-line
Wind 60.00 Sep-1 1
Biomass 3.00 Nov-1 0 Approved Contract
Biomass 22.00 Jul-1 I Approved Contract
Solar 20.00 Oct- I 0 Approved Contract
Wind 40.00 Jan-1 I Approved Contract
Wind 24.00 Sep-11
Total 721.25
The response to this Request was prepared by Randy C. Allphin, Energy
Contract Coordinator Leader, Idaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -61
14, 4.
REQUEST FOR PRODUCTION NO. 38[sic]: Reference the Direct Testimony of
Karl Bokenkamp, pp. 12-13, discussing Idaho Powers proposal to include Longer-term
firm purchases such as the PPL EnergyPlus Power Purchase Contract in the IRP
Methodology calculations as a must run resource. Please identify each of the Longer-
term firm purchases, and for each please provide:
(a)Quantify of energy supplied to Idaho Power;
(b)Term;
(c)The basis to assume that the resource is "must run," with explanation of
applicable contractual requirements.
RESPONSE TO REQUEST FOR PRODUCTION NO. 38Fsicl: At present, the
only contract Idaho Power has in place that would be classified as a longer-term firm
purchase under the proposed methodology is the PPL EnergyPlus Power Purchase
Contract.
(a)The quantity of energy supplied to Idaho Power for the remaining term of
this contract is 83 MW during heavy load hours of July and August 2012.
(b)In 2009, Idaho Power contracted with PPL EnergyPlus LLC for 83 MW of
heavy load energy for July and August 2012. The delivery term listed in the
confirmation is July 1, 2012, through August 31, 2012.
(c)The basis for assuming that longer-term firm contracts are treated as
"must run" resources is because (1) longer-term firm purchases are typically made
pursuant to the terms and conditions of the WSPP Agreement, as described under its
Service Schedule C, Firm Capacity/Energy Sale or Exchange Service, and (2) under the
WSPP Agreement the Purchaser is liable for damages if it does not schedule or receive
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -62
the applicable hourly contract quantity This is detailed in Section 21.3(a)(1) of the
current WSPP Agreement follows:
If the amount the Purchaser scheduled or received in any
hour is less than the applicable hourly Contract Quantity,
then the Purchaser shall be liable for (a) the product of the
amount (whether positive or negative), if any, by which the
Contract Price differed from the Resale Price (Contract Price
- Resale Price) and the amount by which the quantity
provided to the Purchaser was less than the hourly Contract
Quantity; plus (b) the amount of transmission charge(s), if
any, for firm transmission service upstream of the delivery
point, which the Seller incurred to achieve the Resale Price,
less the reduction, if any, in transmission charge(s) achieved
as a result of the reduction in the Purchaser's schedule or
receipt of electric energy (based on Seller's reasonable
commercial efforts to achieve such reduction). If the total
amounts for all hours calculated under this paragraph (1) are
negative, then neither the Purchaser nor the Seller shall pay
any amount under this Section 21.3(a)(1).
Additional details are available in the current version of the WSPP Agreement,
which is available on-line at: http://www.wspp.org/current_effective_agreement.php.
The response to this request was prepared by Karl Bokenkamp, Director
Operations Strategy, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -63
Year Danskin
2008 106
2009 86
2010 77
2011 85
Bennett Mountain
45
62
32
44
REQUEST FOR PRODUCTION NO. 39[sicl: Reference the Direct Testimony of
Karl Bokenkamp, p. 22, proposing that an SCCT replace a CCCT for purposes of
calculating the capacity component of the IRP Methodology calculation.
(a)For the years 2008 through 2011, please provide the number of days per
year that Idaho Power operated its gas peakers (Bennett Mountain or Danskin) to meet
load.
(b)Please provide the number of days per year that Idaho Power forecasts to
use Langley Gulch to meet load requirements, as assumed in Idaho Power's load and
resource balance from its IRP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 39Fsicl:
(a) The number of days that Idaho Power operated its gas peakers to meet
load for the years 2008 through 2011 is as follows:
(b) Idaho Power's Monthly Average Energy Load and Resource Balance
(2011 IRP Appendix C, pages 22 through 41) and Idaho Power's Peak-Hour Load and
Resource Balance (2011 IRP Appendix C, pages 44 through 63) do not forecast the
number of days that Langley Gulch will be used to serve load. These resource
balances primarily compare the amount of forecast monthly energy (or peak-hour
capacity) available from each specific resource to serve the forecast monthly average
load (or peak-hour load).
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -64
For the number of days that Langley Gulch operates as determined in an
AURORA analysis which models the 2011 IRP preferred portfolio under 50I percentile
(median) water condition and load conditions with updated natural gas and load
forecasts and no carbon taxes, please see the Excel file provided on the non-
confidential CD.
The response to this request was prepared by Karl Bokenkamp, Director
Operations Strategy, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -65
REQUEST FOR PRODUCTION NO. 40[sicl: Reference the Direct Testimony of
Karl Bokenkamp, p. 21, describing Idaho Powers proposed IRP Methodology's focus
on the incremental cost from Idaho Powers generating resources.
(a)Is Idaho Power proposing to not consider projected market prices as the
possible next incremental unit used to meet load in its IRP Methodology?
(b)Please provide the number of days per year that Idaho Power engaged in
market purchases in 2009,2010, and 2011.
RESPONSE TO REQUEST FOR PRODUCTION NO. 40Isicl:
(a)No. Idaho Power's proposed new methodology for calculating the avoided
cost of energy does allow use of market purchases, purchased at the market clearing
price as modeled in the AURORA analysis, to meet its load. If the AURORA analysis
utilizes a market purchase to serve Idaho Powers load, and if the cost of that market
purchase is greater than the highest incremental cost Idaho Power is incurring to
operate its coal or natural gas-fired thermal units during that hour, then the incremental
cost for that hour is set by the market purchase at the market clearing price determined
in the AURORA analysis.
(b)The number of days per year that Idaho Power engaged in physical
market purchases during 2009, 2010, and 2011 are listed below:
Year No. of Days
2009 356
2010 330
2011 344
The response to this request was prepared by Karl Bokenkamp, Director
Operations Strategy, Idaho Power Company, in consultation with Donovan Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -66
DATED at Boise, Idaho, this 10th day of April
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -67
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of April 2012 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF EXERGY DEVELOPMENT GROUP OF IDAHO TO
IDAHO POWER COMPANY 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 Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
P.O. Box 3727
Spokane, Washington 99220-3727
PacifiCorp dibla Rocky Mountain Power
Daniel E. Solander
PacifiCorp d/b/a Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Exergy Development, Grand View Solar II,
J.R. Simplot, Northwest and Intermountain
Power Producers Coalition, Board of
Commissioners of Adams County, Idaho,
and Clearwater Paper Corporation
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
_Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email don. howell(uc.idaho.gov
kris.sassercãpuc. idaho.gov
_Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email michael.andreaavistacorp.com
_Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email daniel .solanderpacificorp.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email peter(ãrichardsonandoIeary.com
qreqcrichardsonandoleary.com
Exergy Development Group Hand Delivered
James Carkulis, Managing Member U.S. Mail
Exergy Development Group of Idaho, LLC Overnight Mail
802 West Bannock Street, Suite 1200 FAX
Boise, Idaho 83702 X Email jcarkulisexerqydevelopment.com
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -68
Grand View Solar II
Robert A. Paul
Grand View Solar II
15690 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
Board of Commissioners of Adams
County, Idaho
Bill Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
Clearwater Paper Corporation
Mary Lewallen
Clearwater Paper Corporation
601 West Riverside Avenue, Suite 1100
Spokane, Washington 99201
Renewable Energy Coalition and Dynamis
Energy, LLC
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
_Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email robertapaul08ci mail. com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email don.sturtevantsimpIot.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email rkahnnipDc.orq
_Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email bd brown (frontie met. net
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email mary. IewaIIen(cIearwaterpaDer.com
Hand Delivered
___U.S. Mail
Overnight Mail
FAX
X Email roncwiIIiamsbradburv.com
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -69
Renewable Energy Coalition
Thomas H. Nelson, Attorney
P.O. Box 1211
Welches, Oregon 97067-1211
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 150
Eagle, Idaho 83616
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Bill Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Renewable Northwest Project and Idaho
Windfarms, LLC
Dean J. Miller
Chas. F. McDevitt
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, Idaho 83701
Megan Walseth Decker
Senior Staff Counsel
Renewable Northwest Project
421 SW 6th Avenue, Suite 1125
Portland, Oregon 97204
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email nelsonthnesIon.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email iravenesanmarcosyahoo.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email wthomas(dynamisenerqy.com
_Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email qrecmimuralaw.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email billpiskecabIeone.net
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email joe(ämcdevitt-miller.com
chas(mcdevift-miller.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email meqanrnp.orQ
A-
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -70
4* -
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Twin Falls Canal Company and North Side
Canal Company
C. Thomas Arkoosh
CAPITOL LAW GROUP, PLLC
205 North 10th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
Twin Falls Canal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
North Side Canal Company
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 1 1 th East
Idaho Falls, Idaho 83404
Blue Ribbon Energy LLC
M. J. Humphries
Blue Ribbon Energy LLC
4515 South Ammon Road
Ammon, Idaho 83406
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email iIennienvisionwind.com
margaretcenvisionwind .com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email tarkooshccapitoIIawqroup.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email oImstead(tfcanaI.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email nscanakcabIeone.net
_Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email tedtsorenson.net
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email bIueribbonenerqycgmaiI.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email arronespaol.com
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -71
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
Snake River Alliance
Ken Miller, Clean Energy Program Director
Liz Woodruff, Executive Director
Lisa Young, Clean Energy Organizer
Snake River Alliance
350 North 9th Street #13610
P.O. Box 1731
Boise, Idaho 83701
Energy Integrity Project
Energy Integrity Project
do Tauna Christensen
769 North 1100 East
Shelley, Idaho 83274
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email bottoidahoconservation.org
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email kmillercsnakeriveraIIiance.orq
Iwood ruff(snakeriveralliance.orci
lyounc(äsnakeriveraIIiance.orq
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email tau naenergyinteqrityproiect.orq
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -72