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IDAHO~POWER~
An IDACORP Company
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Monica B. Moen
Attorney II
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February 1 , 2007
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-
In the Matter of the Application of Idaho Power Company for an Accounting
Order Authorizing the Inclusion of Power Supply Expenses Associated With
the Purchase of Capacity and Energy From Telocaset Wind Power Partners
LLC in the Company s Power Cost Adjustment
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of Idaho Power
Company s First Supplemental Response to the First Production Request of Commission
Staff regarding the above-described case.
I would appreciate it if you would return a stamped copy of this transmittal letter to
me in the enclosed self-addressed stamped envelope.
Very truly yours
t6-
Monica B. Moen
MBM
Enclosures
O. Box 70 (B3707)
1221 W. Idaho St.
Boise. ID 83702
MONICA MOEN ISB # 5734
BARTON L. KLINE ISB # 1526
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-2682
Facsimile: (208) 388-6936
Attorneys for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise , Idaho 83702
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR APPROVAL OF A
POWER PURCHASE AGREEMENT
WITH TELOCASET WIND POWER
PARTNERS, LLC AND TO INCLUDE
THE ASSOCIATED EXPENSES IN
THE COMPANY'S ANNUAL POWERCOST ADJUSTMENT.
CASE NO. IPC-06-
IDAHO POWER COMPANY'
FIRST SUPPLEMENTAL
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and, in response to the First Production Request of the Commission Staff to Idaho
Power dated January 19, 2007, herewith submits the following supplemental
information:
IDAHO POWER COMPANY'S FIRST SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF -
REQUEST FOR PRODUCTION NO. 29: What does Idaho Power intend to
do with the Environmental and Renewable Energy credits from the project? What
is the estimated value of the credits?
RESPONSE TO REQUEST NO. 29: The issue of Idaho Power s intentions
concerning any Environmental and Renewable Energy credits it obtains from the
Telocaset wind project is addressed in the Company s 2006 Integrated Resource
Plan ("2006 IRP"). In particular, the 2006 IRP affirms that the Company "believes it
should purchase and retain green tags (aka, Environmental and Renewable Energy
credits) from any renewable resource built or purchased by Idaho Power for the
supply of energy to its customers," 2006 IRP at 7. As stated in the IRP , Idaho
Power recognizes that the acquisition and retention of green tags is necessary to
accurately fulfill the renewable energy component of Idaho Power s resource
portfolio. "Acquiring and retaining green tags assures Idaho Power s customers it
has acquired the energy from renewable resources,Id. Consistent with this
policy, it is the Company s intention to retain any Environmental and Renewable
Energy credits associated with the Telocaset project.
By retaining the Environmental and Renewable Energy credits associated
with energy generated by the Telocaset wind project, the Company would also
stand prepared should future federal or state law impose renewable energy
requirements on the Company. However, should the Commission determine that it
is not in the immediate interest of the Company s customers for the Company to
retain these energy credits , Idaho Power could, as an interim step, consider selling
the green tags associated with the Telocaset project on a short-term basis until
IDAHO POWER COMPANY'S FIRST SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 2
those credits were required as a result of either federal or state legislation. The
Company would propose that revenue from any green tag sales flow through the
Company s PCA mechanism. However, that action would , until the green tags
were reacquired, temporarily strip the Telocaset wind project of its status as a
renewable energy resource.
The value of any environmental and renewable energy credits would be
determined at the time those credits were marketed. Any federal or state legislation
enacted that imposed renewable energy requirements on Idaho Power and other
utilities would likely increase the value of those credits.
The response to this request was prepared by James C, Miller, Senior
Vice President, Power Supply, Idaho Power Company, in consultation with
Monica Moen , Attorney II , Idaho Power Company.
IDAHO POWER COMPANY'S FIRST SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 33: Please discuss the basis for the
Delay Damage amounts as contained in Section 21.4 of the Agreement.
RESPONSE TO REQUEST NO. 33: Delay damages in the amount of
$100/day for each MW of installed capacity at the Telocaset wind facility that has
not satisfied certain conditions was negotiated between the parties to the PPA and
will be assessed Telocaset if Telocaset fails to achieve the Operation Date on or
before the Guaranteed Operation Date.The concept of delay damages is a
provision the Company has included in its recently-filed PURPA wind agreements.
The response to this request was prepared by Randy Allphin , Contract
Administrator, Idaho Power Company, in consultation with Monica Moen
Attorney II , Idaho Power Company,
DATED at Boise, Idaho, this 1st day of February 2007.
(;t-
MONICA B. MOEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S FIRST SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1st day of February 2007, I served a true
and correct copy of the within and foregoing upon the following named parties by
the method indicated below , and addressed to the following:
Donovan E. Walker
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
) U,S. Mail , Postage Prepaid
(X) Hand Delivered
) Overnight Mail
) Facsimile
(X) Email donovan,walker(Q1 puc.idaho.qov
Monica B. Moen
IDAHO POWER COMPANY'S FIRST SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5