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HomeMy WebLinkAbout20070201IPC to Staff 29, 33.pdf;::;;::("'1'.::\,;",-CJl. IDAHO~POWER~ An IDACORP Company 7fj f) f"\'.'-l D - ;II ~: LJ Monica B. Moen Attorney II iDAH(,' f;U;:~Llc;;iTi '~"- r:.:;:'I..J i(;:I-:!u(:)i; 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 FlECE\\/~ 7JjGl rE8 - \ PH 4: 2'3 " . "" ,,' ~ ! (' \\iCi\-' ):':;:\""", r'I"J.)iU. \;:"~ ! -,VVld;! C. \ \ \ t~ 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