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Home My WebLink About20120427IPC to Canal Companies 20-29.pdfRECEIVPrD An IDACORP company 3:28 DONOVAN E. WALKER !DAH Lead Counsel UTILITIES dwalker(idahopower.com April 27, 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 CONTRACT PROVISIONS RESOURCE (SAR) AND IA METHODOLOGIES FOR Ci RATES Dear Ms. Jewell: SI COMMISSION'S REVIEW OF PURPA QF INCLUDING THE SURROGATE AVOIDED TEGRA TED RESOURCE PLANNING (IRP) LCULATING PUBLISHED AVOIDED COST Enclosed for filing please find an original and three (3) copies of Idaho Power Company's Response to the Second Production Requests of Twin Falls Canal Company and North Side Canal Company to Idaho Power and an original and three (3) copies of Idaho Power Company's Confidential Response to the Second 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 containing information responsive to the Canal Companies' Second Production Request. Please handle the confidential information in accordance with the Protective Agreement executed in this matter. Very lyyours, DEW:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, ID 83707 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: (208) 388-5317 Facsimile: (208) 388-6936 dwaIkercidahopower.com iwiIIiamsidahopower.com RECEIVED APR 21 1M 3:28 ftr ¶JTUTE3 COMMC' 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 REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Power"), and in response to the Second Production Requests of Twin Falls Canal Company and North Side Canal Company to Idaho Power dated April 6, 2012, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -1 REQUEST FOR PRODUCTION NO. 20: In the prefiled testimony of Ms. Park describing the Company's proposed Schedule 74, references are made to "must run" resources and the following sentences describe hydro and coal resources (see page 20 line 5 through page 22 line 6). However, Exhibit 5, Schedule 74 lists Langley Gulch as a "Base Load Resource." Please provide copies of all available Siemens documents showing the operating parameters and specifications for the Langley Gulch configuration (SGT6-5000F gas turbine and SST-700 and SST-900 steam turbines) including cold start, warm start, and hot start times, minimum up times, minimum down times, minimum capacity levels and planned maintenance parameters (for example, number of start-ups or running time hours). RESPONSE TO REQUEST FOR PRODUCTION NO. 20: The response to this Request is confidential and will be provided separately to those parties that have signed the Protective Agreement in this proceeding. 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 REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -2 REQUEST FOR PRODUCTION NO. 21: With regard to Exhibit 5, please provide a complete explanation on why IPC has included Langley Gulch in the list of Base Load Resources. RESPONSE TO REQUEST FOR PRODUCTION NO. 21: Langley Gulch power plant ("Langley Gulch") will be operated as a base load resource similar to Boardman, Bridger, and Valmy thermal resources, with the exception that it has the ability to ramp up to maximum output and ramp down to minimum outputs much quicker than the remaining thermal base load resources on Idaho Power's system. Langley Gulch is expected to be dispatched to meet load needs during both heavy and light load periods, and not ramped solely for emergency conditions or during peak load hours. 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 REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -3 REQUEST FOR PRODUCTION NO. 22: With regard to the confidential EXCEL file provided as Attachment I in response to Commission Staffs First Production Request, Request No. 2 (partial title: "IPCO Hourly Incremental Cost Wrkbk.xlsx"), please provide copies of all documents relied upon by the Company in determining the minimum load value for the Langley Gulch resource used in this analysis. RESPONSE TO REQUEST FOR PRODUCTION NO. 22: A minimum load value of 204 megawatts ("MW") was used for Langley Gulch in the AURORA model. The AURORA model allows a monthly capacity shape to be defined to reflect the effect of ambient temperature on capacity for a natural gas resource. In general, capacity is highest in cold weather months and lowest in hot weather months. The monthly capacity shaping values and corresponding minimum load levels used in AURORA are provided in the table below. JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Mthly Capacity Shape 1.0564 1.0564 1.03389 1.03389 1.01138 1.01032 1.0155 0.97504 1.01032 1.01032 1.01138 1.0564ANN VG Minimum capacity (MW) 211 211 206 206 202 201 203 194 201 201 202 211 204 I LANGLEY GLJLCHI Minimum AURORA also has inputs for a natural gas resource for nameplate capacity (MW) and minimum capacity (as a percentage of nameplate). The values used in AURORA for Langley Gulch are also provided in the above table. Please note that these values are the same values used for Idaho Power's 2011 Integrated Resource Plan ("IRP") and IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -4 assume a minimum load level of 65 percent. Siemens, the manufacturer, indicates minimum load levels of 60 percent should be achievable. Actual operating experience of Langley Gulch following the summer 2012 plant commissioning will most likely lead to small adjustments of these values. In fact, the current estimates have already changed from the values used in the 2011 IRP. Idaho Power anticipates the final minimum load level for the plant will be between 60 percent and 65 percent. The above table calculates for each month a minimum capacity (MW) equal to the product of the monthly capacity shape, the nameplate capacity (MW), and the minimum capacity (%). The annual average of the monthly values is equal to 204 MW, which is the basis for the minimum load for Langley Gulch used in the referenced Excel file. 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 REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -5 REQUEST FOR PRODUCTION NO. 23: Please provide an EXCEL workbook file containing the hourly net generation level for each gas-fired resource--Bennett Mountain, Evander Andrews Unit No. I (Danskin 1), Evander Andrews Unit No. 2 (Danskin 2) Evander Andrews Unit No. 3 (Danskin 3)--for the past four years (2008, 2009, 2010 and 2011). RESPONSE TO REQUEST FOR PRODUCTION NO. 23: The hourly net generation level for each gas-fired resource—Bennett Mountain, Evander Andrews Unit No. I (Danskin 1), Evander Andrews Unit No. 2 (Danskin 2) Evander Andrews Unit No. 3 (Danskin 3)—for the past four years (2008, 2009, 2010, and 2011) is provided in the attached Excel file. Please note that there are a few instances in 2008 for which the plant information ("P1") system returns an error message, which indicates no data was available for that hour. 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 REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -6 REQUEST FOR PRODUCTION NO. 24: For each of the existing gas-fired units and Langley Gulch, please describe and provide all the specific input parameters on how each unit was modeled within AURORA. RESPONSE TO REQUEST FOR PRODUCTION NO 24: The input parameters for each Idaho Power gas unit modeled in AURORA are provided in the confidential Excel file provided on the confidential CD. The confidential CD will be provided to those parties that have executed the Protective Agreement in this proceeding. The top column of the Excel file contains the names of the various input parameters from the AURORA Resource Table. 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 REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -7 REQUEST FOR PRODUCTION NO. 25: With regard to each of the existing gas- fired units, please provide copies of all available manufacturer documents showing the operating parameters and specifications for the unit including cold start, warm start, and hot start times, minimum up times, minimum down times, minimum capacity levels and planned maintenance parameters (for example, number of start-ups or running time hours). RESPONSE TO REQUEST FOR PRODUCTION NO 25: The response to this Request is confidential and will be provided separately to those parties that have signed the Protective Agreement in this proceeding. The response to this Request was prepared by Donovan E. Walker, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -8 REQUEST FOR PRODUCTION NO. 26: With regard to the AURORA simulation used to create the confidential EXCEL workbook file provided as Attachment I in response to Commission Staffs First Production Request, Request No. 2 (partial title: "IPCO Hourly Incremental Cost Wrkbk.xlsx"), please provide an EXCEL file containing the IPC hourly loads at the generation level (including losses) for each of the planning years (2013-2030). RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Please see the confidential Excel file provided on the confidential CD containing Idaho Powers hourly loads at the generation level (including losses) for each of the planning years (2013- 2030). 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 REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -9 REQUEST FOR PRODUCTION NO. 27: With regard to the EXCEL files provided as Attachments 3-6 in response to Commission Staffs First Production Request, Request No. 2 (partial title: "PURPA Project Pricing . . . MW.xlsx"), please provide all workpapers and other supporting documents for the values contained in the worksheet entitled Capacity Cost 2016. RESPONSE TO REQUEST FOR PRODUCTION NO. 27: Please see the confidential document provided on the confidential CD. The confidential CD will be provided to those parties that have executed the Protective Agreement in this proceeding. Please note that the values in this workbook are calculated in 2011 dollars. The capital, tax, and insurance amounts from this spreadsheet are escalated to 2016 dollars before being used in the avoided cost rate calculations. 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 REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -10 REQUEST FOR PRODUCTION NO. 28: With regard to the EXCEL files provided as Attachments 3-6 in response to Commission Staffs First Production Request, Request No. 2 (partial title: "PURPA Project Pricing . . . MW.xlsx"), the worksheet entitled Notes references the fact that the avoided capacity values exclude the value of RECs. Please provide IPC's most recent projection of the value of RECs for each planning year (2013-2030). RESPONSE TO REQUEST FOR PRODUCTION NO. 28: Idaho Power's 2011 IRP included a 20-year forward price curve for Renewable Energy Credits/Certificates, along with a high and low case, which was prepared in the fall of 2010. This information can be found on page 74 of the 2011 IRP via the following link: http://www.idahopower.com/AboutUs/PlanninqForFuture/irp/2011 /default.cfm 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 REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -11 REQUEST FOR PRODUCTION NO. 29: With regard to the EXCEL files provided as Attachments 3-6 in response to Commission Staffs First Production Request, Request No. 2 (partial title: "PURPA Project Pricing . . . MW.xlsx"), the worksheet entitled Cost of Capacity distributes the avoided capacity value across all expected generation for an equal $/MWh rate. Please explain if other alternative methods were considered for assigning the avoided capacity cost to time periods (such as assigning the avoided capacity cost to just heavy load hours) and why IPC believes the proposed method is the most reasonable. RESPONSE TO REQUEST FOR PRODUCTION NO. 29: Idaho Power did not consider any other alternative methods for assigning the avoided cost of capacity. Idaho Power believes applying the avoided cost of capacity to all hours of generation most closely approximates the way the costs of a utility-owned resource would be allocated. 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. DATED at Boise, Idaho, this 27th day of April 2012. C~ ~ alc DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -12 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 27th day of April 2012 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS 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. howelkDuc.idaho.c1ov kris.sasser(äDuc. idaho.ciov Hand Delivered U.S. Mail Overnight Mail FAX X Email michael. and reaavistacorp.com Hand Delivered U.S. Mail Overnight Mail FAX X Email daniel.solanderD-Dacificorp.com Hand Delivered U.S. Mail Overnight Mail FAX X Email peter(ärichardsonandolearv.com qreq(richardsonandolear -y.com IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -13 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 icarkulisexerqydeveloDment.com 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 _Hand Delivered U.S. Mail _Overnight Mail FAX X Email dr(benjohnsonassociates.com Hand Delivered U.S. Mail Overnight Mail FAX X Email robertapau108cimail.com Hand Delivered U.S. Mail Overnight Mail FAX X Email don.sturtevantCsimplot.com Hand Delivered U.S. Mail Overnight Mail FAX X Email rkahn(niDDc.orq Hand Delivered U.S. Mail Overnight Mail FAX X Email bdbrown(frontiernet.net IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -14 Clearwater Paper Corporation Hand Delivered Mary Lewallen U.S. Mail Clearwater Paper Corporation Overnight Mail 601 West Riverside Avenue, Suite 1100 FAX Spokane, Washington 99201 X Email marv.lewallenclearwaterpaper.com 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 McDEVITT & MILLER LLP 420 West Bannock Street (83702) P.O. Box 2564 Boise, Idaho 83701 Hand Delivered U.S. Mail Overnight Mail FAX X Email ronwilliamsbradbury.com Hand Delivered U.S. Mail Overnight Mail FAX X Email iravenesanmarcosyahoo.com _Hand Delivered U.S. Mail _Overnight Mail FAX X Email wthomasdynamisenergy.com Hand Delivered U.S. Mail Overnight Mail FAX X Email qreq(ämimuralaw.com Hand Delivered U.S. Mail Overnight Mail FAX X Email biIlDiskecableone.net Hand Delivered U.S. Mail Overnight Mail FAX X Email ioe(mcdevitt-miller.com IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -15 Megan Walseth Decker Senior Staff Counsel Renewable Northwest Project 421 SW 6th Avenue, Suite 1125 Portland, Oregon 97204 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 Hand Delivered U.S. Mail Overnight Mail FAX X Email meganmD.orc Hand Delivered U.S. Mail Overnight Mail FAX X Email glen nicenvisionwind.com marqaretenvisionwind .com Hand Delivered U.S. Mail Overnight Mail FAX X Email tarkooshcapitollawgroup.com _Hand Delivered U.S. Mail _Overnight Mail FAX X Email olmstead(tfcanaI.com Hand Delivered U.S. Mail Overnight Mail FAX X Email nscanakcableone.net Hand Delivered U.S. Mail Overnight Mail FAX X Email ted(tsorenson.net Blue Ribbon Energy LLC Hand Delivered M. J. Humphries U.S. Mail Blue Ribbon Energy LLC Overnight Mail 3470 Rich Lane FAX Ammon, Idaho 83406-7728 X Email blueribbonenemyQmaiI.com IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -16 Arron F. Jepson Hand Delivered Blue Ribbon Energy LLC U.S. Mail 10660 South 540 East Overnight Mail Sandy, Utah 84070 FAX X Email arronesQaol.com Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street (83702) P.O. Box 844 Boise, Idaho 83701 Snake River Alliance Liz Woodruff, Executive Director Ken Miller, Clean Energy Program Director Snake River Alliance 350 North 9th Street #13610 P.O. Box 1731 Boise, Idaho 83701 Energy Integrity Project Tauna Christensen Energy Integrity Project 769 North 1100 East Shelley, Idaho 83274 Hand Delivered U.S. Mail Overnight Mail FAX X Email bottoidahoconservation.ora Hand Delivered U.S. Mail Overnight Mail FAX X Email lwoodruffsnakeriveralliance.orq kmillersnakeriveraIliance.orp _Hand Delivered U.S. Mail _Overnight Mail FAX X Email taunacenerqyinteqntyproiect.orq CA Christa Bearry, Legal Assistan\ IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -17