20120423IPC to Canal Companies 1-19.pdf

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DONOVAN E. WALKER
Lead Counsel
dwalker(idahopower.com
April 23, 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 First Production Requests of Twin Falls Canal Company and
North Side Canal Company ("Canal Companies") to Idaho Power in the above matter.
Also enclosed are four (4) copies of a non-confidential disk and four (4) copies of a
confidential disk provided in response to the Canal Companies' First Production Request.
Please handle the confidential information in accordance with the Protective Agreement
executed in this matter.
Ve uly yours,
onovan Iker
DEW:kkt
Enclosures
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]
dwaIkeridahopower.com
jwiIIiams(ãidahopower.com
RECE'' V U
2C12 APR 23 PH t:55
DAHC PU3i
UTILITIES COMM i8SIO
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 FIRST
PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY
AND NORTH SIDE CANAL
COMPANY TO IDAHO POWER
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Requests of Twin Falls Canal Company and North Side
Canal Company ("Canal Companies") to Idaho Power dated April 2, 2012, herewith
submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -1
REQUEST FOR PRODUCTION NO. 1: Please provide an electronic copy in the
original software with all formulae intact of all supporting workpapers and documents
used to calculate the values, tables, charts and exhibits in the prefiled testimony of
Idaho Power Company witnesses Stokes, Park and Bokenkamp.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Idaho Power objects to
this Request, as written, as it is overly broad, unduly burdensome, expansive, and
oppressive.
The response to this Request was prepared by Jason B. Williams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -2
REQUEST FOR PRODUCTION NO. 2: Please provide complete electronic
copies of all data responses provided in response to data requests from all other parties
to Idaho Power Company. Please consider this an ongoing data request for the
remainder of this proceeding.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: A copy of Idaho
Power's response to the First Production Request of Exergy Development Group of
Idaho Power to Idaho Power Company is provided on the non-confidential CD. The
confidential chart provided in the Company's response to Exergy's Production Request
No. 4 is provided on the confidential CD. The confidential CD will be provided to those
parties that have executed the Protective Agreement in this proceeding.
The above-mentioned production response was provided to the Canal
Companies' counsel, Shelley M. Davis, at the time of service. All other production
responses provided by Idaho Power have been served on the Canal Companies'
current counsel, C. Thomas Arkoosh.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -3
REQUEST FOR PRODUCTION NO. 3: With regard to the testimony of Mr. E.
[sic] Mark Stokes, page 4, lines 15-20 and Exhibit No. I pages 1-2, please provide an
electronic EXCEL file containing the term of each power purchase agreement
(beginning and end dates) and the hourly kilowatt amount purchased by IPC (net of
station service and self-served load) for the years 2008, 2009, 2010 and 2011 for each
of the 96 QF projects currently on line. (if hourly kWh/hr data is not available, please
provide the most disaggregated data available for each project for the four year period.)
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see the Excel
spreadsheet provided on the non-confidential CD.
The response to this Request was prepared by Randy C. Allphin, Energy
Contracts Coordinator Leader, Idaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -4
REQUEST FOR PRODUCTION NO. 4: With regard to the testimony of Mr. E.
[sic] Mark Stokes, page 4, lines 15-20 and Exhibit No. I page 3, please provide an
electronic EXCEL file indicating the expected on-line date (month and year), the term of
each power purchase agreement (years or expected end date) and the projected annual
energy purchases (kWhs) for each of the 23 QF projects.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the Excel
spreadsheet provided on the non-confidential CD.
The response to this Request was prepared by Randy C. Allphin, Energy
Contracts Coordinator Leader, Idaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -5
REQUEST FOR PRODUCTION NO. 5: Please provide an electronic EXCEL file
containing IPC's native system hourly loads for the years 2008, 2009, 2010 and 2011.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the Excel
file provided on the non-confidential CD. The hourly system load reported is the
megawatt ("MW") load with no demand response resources in effect.
The response to this Request was prepared by Tessia Park, Director of Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -6
REQUEST FOR PRODUCTION NO. 6: With regard to the testimony of Mr. E.
[sic] Mark Stokes, page 46, lines 17-21, please provide an explanation and copies of
any workpapers or other documents the Company is relying upon to support the
proposal to reduce the maximum contract term from 20 to just 5 years.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: In the Direct Testimony
of M. Mark Stokes, on pages 14-26, Mr. Stokes discusses the harm that will come to
Idaho Power's customers as a result of the obligation to purchase Qualified Facility
("QF") energy over the next 20 years when avoided cost rates are not appropriately set.
Reducing the required contract term from 20 years to five years reduces the additional
risk Idaho Power customers would face if unforeseen circumstances create a similar
situation in the future. A detailed discussion of the risk associated with QF contracts,
non-indexed power purchase agreements, and utility-owned resources was provided in
Idaho Power's response to the Idaho Public Utilities Commission ("Commission") Staff's
Production Request No. 14.
In addition, William H. Hieronymus addresses this topic on page six of his Direct
Testimony as follows:
While some methods of setting avoided costs are better than
others and may reduce the range of forecast error, no
method of setting avoided cost can prevent the potential for
large forecast errors. The only way to limit the difference
between the actual value of QF power and prices paid for it
is to keep contracts short and/or severely limit the period for
which prices are fixed. This can be done in a number of
ways, including reopeners and indexation.
Furthermore, on page 11 of his Direct Testimony, Dr. Hieronymus recommends
that any adopted avoided cost methodology should:
Limit customers' exposure to long-term price risk by such
mechanisms as not offering fixed prices, using formula rates
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -7
indexed to actual energy or fuels prices, and shortened
contract lengths. It is particularly important that consumers
not take on price risk for QF power that is not even used to
serve them, but rather is sold into the interchange market.
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 FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -8
REQUEST FOR PRODUCTION NO. 7: With regard to the testimony of Mr. E.
[sic] Mark Stokes, page 46, lines 17-21, does the Company have any views on how the
5 year term will impact the ability of a QF to finance a facility or execute a purchase
power agreement with the Company?
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: Idaho Power objects to
this Request on the grounds that it calls for speculation and requests a statement of
opinion or policy proscribed by RP 225.01 (a).
The response to this Request was prepared by Jason B. Williams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -9
REQUEST FOR PRODUCTION NO. 8: With regard to the testimony of Mr. E.
[sic] Mark Stokes, page 46, lines 17-21, please provide an explanation and copies of
any workpapers or other documents the Company is relying upon to support this
assertion.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Using Idaho Power's
proposed application of the Integrated Resource Plan ("IRP") methodology, only one
AURORA model run is needed to determine the hourly displaceable incremental or
avoided cost of energy for each hour, and these same numbers are used as part of
providing avoided cost of energy rates for any QF project. The hourly avoided cost of
energy from this analysis is used in conjunction with a QF's supplied hourly generation
profile, in a separate Excel spreadsheet, to determine monthly heavy load and light load
pricing. The proposed methodology results in reduced administrative burden because
the hourly incremental costs determined by the single AURORA model run can be used
for determining QF contract rates until significant changes in modeling inputs would
warrant an updated AURORA model run.
Please see Idaho Power's response to Commission Staff's Production Request
No. 2 where the AURORA results and hourly incremental costs were provided in an
Excel spreadsheet along with the subsequent Excel spreadsheets used to calculate
pricing for four sample projects.
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 FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -10
REQUEST FOR PRODUCTION NO. 9: With regard to the testimony of Ms.
Tessia Park, page 14, lines 6-8, please provide a complete copy of the study including
any supporting appendices or workpapers when it is completed.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Idaho Power will
provide the study results to the public as soon as the final report is completed. At this
time, it is difficult to estimate the date it will be available as the Company is currently
working with an external technical review team to determine if any modifications to the
modeling will be required. This report will be available at:
www.idahopower.com/AboutUs/PlanningForFuture/WindStudy.
A public workshop on the wind integration study was conducted by Idaho Power
on April 6, 2012, and the materials presented are currently available at the same
website referenced above.
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 FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -11
REQUEST FOR PRODUCTION NO. 10: With regard to the testimony of Ms.
Tessia Park, page 25, lines 22-25, please provide a listing of the QF projects
("Applicable QFS") along with the associate size (similar to Stokes Exhibit No. 1) the
Company believes would be subject to the proposed Schedule 74 curtailment
procedures.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Please see Idaho
Power's response to Commission Staffs Production Request No. 7.
The response to this Request was prepared by Randy C Aliphin, Energy
Contracts Coordinator Leader, Idaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -12
REQUEST FOR PRODUCTION NO. 11: With regard to the testimony of Ms.
Tessia Park, page 25, lines 22-25, please explain and provide the basis for the
Company's belief that it can apply proposed Schedule 74 to an existing QF. As part of
this response, please provide examples of existing contracts with a specific cite that
provides the Company with this curtailment right.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: Please see Idaho
Power's response to Exergy Development Group of Idaho Power to Idaho Power
Company's Production Request No. 12(c).
The response to this Request was prepared by Jason B. Williams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -13
REQUEST FOR PRODUCTION NO. 12: With regard to the testimony of Mr. Karl
Bokenkamp, page 7, lines 11-16, please provide a complete copy of the Company's
Energy Risk Management Policy and Standards.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Please see the two
confidential documents provided in PDF format 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 Karl Bokenkamp, Director of
Operations Strategy, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -14
REQUEST FOR PRODUCTION NO. 13: With regard to Exhibit Nos. 7 and 8, if
not apparent from the workpapers, please explain the hydro assumption used in the
AURORA analysis for both the Company owned hydro resources and the other
resources used in the simulation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The following is taken
from pages 64-65 of Idaho Power's 2011 IRP which can be found at:
www.idahopower.com/AboutUs/PlanningForFuture/irp/2O Il/default. cfm.
The timing and necessity of future generation resources are
based on a 20-year forecast of surpluses and deficits for
monthly average load (energy) and peak-hour load. For both
of these areas, one set of criteria has been chosen for
planning purposes; however, additional scenarios have been
analyzed to provide a comparison.
Table 6.3 provides a summary of the six planning scenarios
analyzed for the 2011 IRP, and the criteria used for planning
purposes are shown in bold. Median water and median load
forecast scenarios were included to enable comparison of
the 2011 IRP with plans developed during the 1990s. The
median forecast is no longer used for resource planning,
although the median forecast is used to set retail rates and
avoided cost rates during regulatory proceedings. The
planning criteria used to prepare Idaho Power's 2011 IRP
are consistent with the criteria used in the 2009 IRP.
Table 6.3 Planning criteria for average monthly and peak-hour load
Average monthly load/energy (aMW) 50th Percentile Water, 50th Percentile Average Load
70th Percentile Water, 70th Percentile Average Load
90th Percentile Water, 70th Percentile Average Load
Peak-hour load (MW) 50" Percentile Water, 90th Percentile Peak-Hour Load
70th Percentile Water, 95th Percentile Peak-Hour Load
90th Percentile Water, 95th Percentile Peak-Hour Load
The planning criteria used for energy or average load are
70th percentile water and 70th percentile average load. In
addition, 50th percentile water and 50th percentile average
load conditions are analyzed to represent a median
condition, and 90th percentile water and 70th percentile
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -15
average load are analyzed to examine the effects of low
water conditions.
Peak-hour load planning criteria consist of 90th percentile
water and 95th percentile peak-hour load conditions,
coupled with Idaho Powers ability to import additional
energy on its transmission system. A median condition of
50th percentile water and 50th percentile peak-hour load are
also analyzed, as well as 70th percentile water and 95th
percentile peak-hour load. Peak-hour load planning criteria
are more stringent than average load planning criteria
because Idaho Power's ability to import additional energy is
typically limited during peak-hour load periods. Surpluses
and deficits for the average and peak-hour load scenarios
can be found in Appendix C—Technical Appendix.
While the median water and load forecasts are not used for IRP resource
adequacy assessments, these forecasts are used in AURORA modeling performed for
the IRP and for QF avoided cost modeling. A further explanation of the AURORA
hydroelectric modeling is provided in Idaho Power's response to the Canal Companies'
Production Request No. 14 below.
Natural gas and coal resources are economically dispatched within the AURORA
model. Long-term power purchase agreements from dedicated resources are included
based on historical generation amounts, and the AURORA model has the ability to
interact with the electric power market based on economics and transmission
constraints.
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 FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -16
REQUEST FOR PRODUCTION NO. 14: With regard to Exhibit Nos. 7 and 8, if
not apparent from the workpapers, please provide the historical hydro generation by
hour by water year the Company uses in performing its AURORA based planning or risk
analysis.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: In the AURORA-
based planning and risk analysis, Idaho Power uses monthly average hydroelectric
generation for the median water condition as calculated from a normalized streamflow
record for the Snake River Basin. The derivation of the normalized streamflow record is
described on page 66 of the 2011 IRP, which can be found at:
http://www.idahopower.com/AboutUs/PlanningForFuture/irp/201 I /default.cfm.
The calculation of hydroelectric generation from the median water condition is
performed using an internal generation model (PDR580) as described on page 67 of the
2011 IRP. The calculated 2011-2030 monthly average hydroelectric generation for
Idaho Power-owned hydroelectric resources is provided on pages 96-105 of Appendix C
- Technical Appendix of the 2011 IRP. The calculated monthly average hydroelectric
generation is then used in the AURORA model.
In simulating Idaho Power's system, the AURORA model has settings that allow
the monthly average generation from the Hells Canyon Complex to be shaped to follow
load in a manner intended to reflect actual operation. The AURORA model has the
capability to output hourly generation figures; however, this is not typically done as it
significantly increases modeling time. Therefore, hourly AURORA hydro generation
figures are not available. The remaining Company-owned hydroelectric projects are
modeled in AURORA as run-of-river generators, and consequently have hourly
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -17
generation in AURORA equal to their input monthly average generation. Hourly
generation from QF hydroelectric generators is included in the AURORA model
according to either the projected monthly average production as provided by the QF
developer (for newer projects) or based on historical production figures when sufficient
historical information is available.
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 FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -18
REQUEST FOR PRODUCTION NO. 15: Please provide a copy of the most
recent loss of load probability study or similar reliability or planning reserve margin
analysis the Company has conducted.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: A loss of load
expectation analysis was done as part of preparing Idaho Power's 2011 IRP. The
results of this study are presented on page 119 of the IRP, which can be found at:
http://www.idaho power.com/AboutUs/PlanningForFuture/irp/201 I /default.cfm.
Additional details and data regarding this study are presented on pages 186 and
187 of Appendix C - Technical Appendix, which can also be found using the link
provided above.
A capacity planning reserve analysis is presented in the 2011 IRP on pages
115-118 and can also be found using the link provided above.
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 FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -19
REQUEST FOR PRODUCTION NO. 16: With regard to Exhibit No. 8, please
provide a comparable exhibit using all the same assumptions but include the expected
case carbon cost adder starting in 2015 as was done in the Company's most recent
June 2011 IRP study in the analysis. Please provide all workpapers used to compile
the response to this data request.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: In Idaho Power's
response to Commission Staff's Production Request No. 12, the Company provided the
avoided cost rates, with the IRP carbon adder assumption, under the IRP methodology
in place and used for the December 15 presentation to the parties in this case. Idaho
Power has not done the AURORA model run with the carbon adder that would be
required to provide the requested data for Exhibit No. 8 under the alternate IRP
methodology being proposed by Idaho Power.
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 FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -20
REQUEST FOR PRODUCTION NO. 17: With regard to the testimony of Dr.
William Hieronymus, page 32, lines 6-8, please provide a complete copy of all
documents relied upon to support the assertions in these two sentences.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: These statements do
not rely primarily on specific documents but on Dr. Hieronymus's recollection and
experience. Dr. Hieronymus's testimony cites to the suspension of Standard Offers 2
and 4 in California. Dr. Hieronymus also recalls the suspension of the 6 cent rule in
New York. More generally, he recalls that many states that adopted lRPs in the late
1 980s and early 1990s subsumed QF procurement in them. He also recalls that states
that adopted retail access and, in particular, those that eliminated rate of return
compensation for utility-owned generation ceased QF procurement except, presumably,
for the statutory standard offers to very small Us. The National Economic Research
Associates, Brattle/Edison Electric Institute and Elefant papers cited in Dr.
Hieronymus's Direct Testimony in this matter provide partial confirmation of his
recollection. These papers are provided on the non-confidential CD.
The response to this Request was prepared by William H. Hieronymus, Vice
President of Charles River Associates, Inc., in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -21
REQUEST FOR PRODUCTION NO. 18: With regard to the testimony of Dr.
William Hieronymus, page 76, lines 6-7, please provide a complete explanation
including references to specific documents to support the assertion the QF/CHP
settlement is also "about non-QF renewables."
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: See the presentation
concerning the settlement on the non-confidential CD. As described therein, the
settlement establishes contracts for QFs, which are prospectively limited to projects less
than 20 MW. It provides for the state's investor-owned utilities to apply to the Federal
Energy Regulatory Commission for exemption from the Public Utility Regulatory Policies
Act of 1978 for projects larger than 20 MW. It provides a vehicle for procurement of
energy from QFs larger than 20 MW based on transitional rates and for establishing
other procurement methods, including a quantity-limited competitive procurement of
non-QF power.
The response to this Request was prepared by William H. Hieronymus, Vice
President of Charles River Associates, Inc., in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -22
REQUEST FOR PRODUCTION NO. 19: With regard to the testimony of Dr.
William Hieronymus, page 106, lines 17-19, please provide a complete list of all the
"numerous examples of EWG5" that have been built without an executed bilateral
contract along with copies of all supporting documentation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: Dr. Hieronymus has
not compiled a "complete list" and is unaware of any such compilation. His knowledge
of such exempt wholesale generators arises from various consulting assignments.
Some examples based on his current recollection are Harquahala, Panda I & 2,
Redhawk I & 2, Silver Hawk, Mystic 8 & 9, Kendall, Astoria 2, Redbud, McCain, West
Deptford (under construction), Bayonne, York, Empire, Southhaven, and Caledonia.
The response to this Request was prepared by William H. Hieronymus, Vice
President of Charles River Associates, Inc., in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 23rd day of April 2012.
DONAVON E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23rd day of April 2012 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSES TO THE FIRST
PRODUCTION REQUEST OF TWIN FALLS CANAL COMPANY AND NORTH SIDE
CANAL COMPANY TO IDAHO POWER 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. howelkpuc.idaho.cov
kris. sasser(iuc. idaho.qov
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email michael. and reaavistacorD.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email daniel.solandercpacificorp.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email peterrichardsonandolearv.com
qrecrichardsonandoIearv.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 FIRST PRODUCTION REQUESTS OF
TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -24
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hill Road
Boise, Idaho 83703
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
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Renewable Energy Coalition and Dynamis
Energy, LLC
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Renewable Energy Coalition
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 6 th Avenue, Suite 1125
Portland, Oregon 97204
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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 11th 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
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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
Snake River Alliance
350 North 9th Street #136110
P.O. Box 1731
Boise, Idaho 83701
Energy Integrity Project
Energy Integrity Project
do Tauna Christensen
769 North 1100 East
Shelley, Idaho 83274
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
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