The URL can be used to link to this page

Home My WebLink About20070709IPC Amended to Staff 15-18.pdfIDAHO~POWER~ An IDACORP Company Barton L. Kline Senior Attorney Idaho Public Utilities Commission Office of the SecretaryRECEIVED JUL 6 - 2007 July 6, 2007 Boise, Idaho Jean D. Jewell , Secretary Idaho Public Utilities Commission 472 West Washington Street P. O. Box 83720 Boise, Idaho 83720-0074 Re:Case No. IPC-06- Cassia Gulch Wind Park LLC and Cassia Wind Farm LLC v. Idaho Power Company Dear Ms. Jewell: Please find enclosed an original and two (2) copies of Idaho Power s Amended Response to the Second Production Request of the Commission Staff in the above- referenced matter. On July 5, Idaho Power filed its response to the Second Production Request of the Commission Staff. The document that was filed was not the intended final document, but a draft response. Idaho Power is filing this Amended Response to the Second Production Request of the Commission Staff to correct that error. They only substantive change made has been to Request No. 15. We are replacing the entire document so that all the responses will be together and the pagination is correct. I have included a "red-line" of the response to number 15 showing the substantive changes. I would appreciate it if you would return a stamped copy of this transmittal letter in the enclosed self-addressed , stamped envelope. Very truly yours Barton L. Kline BLK:sh Enclosures o. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 REQUEST FOR PRODUCTION NO. 15:If all projects in the queue commit to redispatch , participate in the network upgrade and obtain full refund within the ten year period , what is the estimated Idaho Power transmission investment subject to rate base for the Twin Falls cluster? What is the estimated additional cost per kWh incurred by Idaho Power to provide transmission for these PURPA projects over the ten-year period? RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Responding to this request requires the Company to make several assumptions. First , the Twin Falls cluster has one large generation project which is subject to FERC transmission reimbursement regulations and as a result, this project has been removed for purposes of responding to this production request. Second , the remaining projects in the cluster are PURPA projects and if the Commission accepts the Stipulation , Idaho Power would eventually rate base $4.9 million for these PURPA projects. The PURPA projects' 25% contribution in aid of construction has already been deducted to determine the $4.million amount. Third, utilizing a generation capacity factor of 30% for all projects, the PURPA projects in the cluster are assumed to produce 631 000 MWh annually. Fourth , because the projects are assumed to receive full reimbursement within the first year of operation, no interest is applied to the unpaid balance and the calculation does not consider the effects of depreciation. Based on the above-described assumptions , the estimated transmission I cost associated with the incremental $4. 9 million investment for one year would be $0.0078 per kWh. It is impossible for Idaho Power to be certain as to when the projects will actually come on-line , or how long it will take to fully reimburse the projects because reimbursement is based on performance . The Company also cannot predict and currently the unknO\j\.'n FERC interest rate that would be applied to any unamortized refund balance over the term of the reimbursement period. a result, the Companv cannot compute the ten-year, per kWh cost but it is almost certain to be less than the $0.0078 one year amount set out above. The response to this request was prepared by Dave Angell, Manager Delivery Planning, Idaho Power Company, in consultation with Barton L. Kline Senior Attorney, Idaho Power Company. Idaho Public Utilities Commission Office of the Secretary RECEIVED Barton L. Kline (ISB No. 1526) Lisa D. Nordstrom (ISB No. 5733) IDAHO POWER COMPANY 1221 West Idaho Street O. Box 70 Boise , ID 83707 Tel: 208-388-2682 Fax: 208-338-6936 JUL 6 - 2007 Boise, Idaho Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASSIA GULCH WIND PARK LLC AND CASSIA WIND FARM LLC Case No. IPC-06- Complainants IDAHO POWER'S AMENDED RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFFIDAHO POWER COMPANY Respondent COMES NOW, Idaho Power Company ("Idaho Power" or "the Company ) and , in response to the Second Production Request of the Commission Staff to Idaho Power Company dated June 20 2007, herewith submits the following amended response: IDAHO POWER'S AMENDED RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - Page REQUEST FOR PRODUCTION NO. 15 If all projects in the queue commit to redispatch , participate in the network upgrade and obtain full refund within the ten year period , what is the estimated Idaho Power transmission investment subject to rate base for the Twin Falls cluster? What is the estimated additional cost per kWh incurred by Idaho Power to provide transmission for these PURPA projects over the ten-year period? RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Responding to this request requires the Company to make several assumptions. First, the Twin Falls cluster has one large generation project which is subject to FERC transmission reimbursement regulations and as a result, this project has been removed for purposes of responding to this production request. Second, the remaining projects in the cluster are PURPA projects and if the Commission accepts the Stipulation, Idaho Power would eventually rate base $4. million for these PURPA projects. The PURPA projects' 25% contribution in aid of construction has already been deducted to determine the $4.9 million amount. Third, utilizing a generation capacity factor of 30% for all projects, the PURPA projects in the cluster are assumed to produce 631 000 MWh annually. Fourth , because the projects are assumed to receive full reimbursement within the first year of operation , no interest is applied to the unpaid balance and the calculation does not consider the effects of depreciation. Based on the above-described assumptions , the estimated transmission cost associated with the incremental $4.9 million investment for one year would be $0.0078 per kWh. IDAHO POWER'S AMENDED RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 2 It is impossible for Idaho Power to be certain as to when the projects will actually come on-line, or how long it will take to fully reimburse the projects , because reimbursement is based on performance. The Company also cannot predict the FERC interest rate that would be applied to any unamortized refund balance over the term of the reimbursement period. As a result, the Company cannot compute the ten-year, per kWh cost but it is almost certain to be less than the $0.0078 one year amount set out above. The response to this request was prepared by Dave Angell, Manager, Delivery Planning, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power Company. IDAHO POWER'S AMENDED RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 3 REQUEST FOR PRODUCTION NO. 16: How does Idaho Power s investment commitment in Network upgrades with redispatch change if only Cassia commits to participate? RESPONSE TO REQUEST FOR PRODUCTION NO. 16: The cost allocation would be similar to that shown in Table B-3, Exhibit B to the Stipulation because the Cassia projects alone will not allow enough dispatch capability to avoid the transmission network improvements associated with the no-dispatch option. This scenario would result in Idaho Power investing about $52 million for the transmission associated with cluster PURPA projects. The response to this request was prepared by Dave Angell , Manager, Delivery Planning, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney, Idaho Power Company. IDAHO POWER'S AMENDED RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 4 REQUEST FOR PRODUCTION NO. 17: Under what circumstances would a project developer not receive a full refund of the transmission cost advance at the end of the ten-year refund period? RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Idaho Power can think of two examples of circumstances where the QF project developer would not receive a full refund of the transmission costs advanced at the end of the first ten-year period. First, if a QF project defaults on either the Interconnection Agreement or the Firm Energy Sales Agreement and the default results in either or both contracts being terminated , the project developer would not receive a full refund of the transmission costs advanced. Second, if a QF developer failed to maintain the minimum mechanical availability specified in the Interconnection Agreement, the developer would not receive a transmission refund for that month. This could result in a QF developer receiving less than a full refund over the ten-year period. The response to this request was prepared by Barton L. Kline, Senior Attorney, Idaho Power Company. IDAHO POWER'S AMENDED RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 5 REQUEST FOR PRODUCTION NO. 18 How will transmission network upgrade costs be allocated (including those borne by Idaho Power) if projects in the queue continue to request firm network interconnection services but do not commit to redispatch? RESPONSE TO REQUEST FOR PRODUCTION NO. 18: If a QF project chooses not to be subject to redispatch , it would be responsible for paying the full cost of the transmission network upgrade required to accommodate its capacity. Those amounts are shown on Table B-, Exhibit B to the Stipulation. As a condition of interconnection , the project would also be required to post liquid security to cover the full cost of the upgrade until such time as the full network upgrade was completed. The sharing of costs would be the same as for the QFs that choose the redispatch option. The response to this request was prepared by Dave Angell, Manager, Delivery Planning, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney, Idaho Power Company. DATED at Boise, Idaho, this day of July, 2007. BARTON L. KLINE Attorney for Idaho Power Company IDAHO POWER'S AMENDED RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 6 CERTIFICATE OF SERVICE .l- k.I HEREBY CERTIFY that on this day of July, 2007, I served a true and correct copy of the within and foregoing document upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington (83702) O. Box 83720 Boise, Idaho 83720-0074 ---X-Hand Delivered - U.S. Mail Overnight Mail FAX ---X. Email scott.woodburv(g)puc.idaho.qov Industrial Customers of Idaho Power Peter J. Richardson, Esq. Richardson & 0' Leary 515 N. 2ih Street O. Box 7218 Boise, Idaho 83702 Hand Delivered ---.2LU.S. Mail Overnight Mail FAX..x Email peter(g) richardsonandolearv.com Don Reading Ben Johnson Associates 6070 Hill Road Boise, Idaho 83702 Hand Delivered ---.2L U.S. Mail Overnight Mail FAX..x Email dreadinq (g) mindsprinq.com Cassia Joe Miller McDevitt & Miller, LLP 420 W. Bannock Street O. Box 2564-83701 Boise , Idaho 83702 Hand Delivered ---.2LU.S. Mail Overnight Mail FAX..x Email ioe (g) mcdevitt-miller.com A vista David J. Meyer Senior Vice President Avista utilities O. Box 3727 Spokane, VVA 83702 Hand Delivered ---.2LU.S. Mail Overnight Mail FAX..x Email david.meyer(g)avistacorp.com Jeff Schlect Manager, Transmission Services A vista Corporation O. Box 3727 Spokane, VVA 83702 Hand Delivered ---.2LU.S. Mail Overnight Mail FAX..x Email ieff.schlect(g)avistacorp.com IDAHO POWER'S AMENDED RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 7 R. Blair Strong Paine Hamblen et al 717 W. Sprague Ave. Spokane, VVA 99201 Hand Delivered ---2LU.S. Mail Overnight Mail FAX -X Email rbstronq (g) painehamblen.com John Deere Credit Ronald K. Arrington Assoc. Chief Counsel John Deere Credit 6400 NW 86th Street Johnston, IA 50131 Hand Delivered ---2L U.S. Mail Overnight Mail FAX-X Email arrinqtonronaldk(g) iohndeere.com Rocky Mountain Power Brian Dickman Dean S. Brockbank Rocky Mountain Power 201 S. Main Street, Suite 2300 Salt Lake City, UT 84111 Hand Delivered ---2LU.S. Mail Overnight Mail FAX-X Email brian.dickman (g) pacificorp.com dean.brockbank (g) pacificorp.com Exergy Development Group Robert Paul Lawrence R. Lieb Exergy Development Group of Idaho LLC 910 W. Main Street, Suite 310 Boise, Idaho 83702 Hand Delivered ---2LU.S. Mail Overnight Mail FAX ---2L Email rapaul-exerqy(g)pobox.com Irllal (g) sbcqlobaLnet GJJ0 Barton L. Kline IDAHO POWER'S AMENDED RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF - Page 8