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Home My WebLink About20071102Staff to IPC 14-28.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BAR NO. 1895 RECEi\/E~ ZUDI NOY -2 PH 3: 32 IDAHO PUBliC UTILITIES COfvH\1!SSIO, Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION 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 ENERGY FROM RAFT RIVER ENERGY I LLC IN THE COMPANY'S POWER COST ADJUSTMENT. CASE NO. IPC-07- SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that Idaho Power Company (Company; IPC) provide the following documents and information as soon as possible, but no later than FRIDAY, NOVEMBER 23,2007. This Production Request is to be considered as continuing, and Idaho Power Company is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced. For each item, please indicate the name ofthe person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY NOVEMBER 2, 2007 REQUEST NO. 14: Idaho Power s 2006 IRP anticipated that the 100 MW geothermal RFP would be concluded in 2007 and that 50 MW of geothermal resource would be online by 2009. In its bid, u.s. Geothermal proposes to offer a total of 45.5 MW of geothermal energy to Idaho Power and to have those facilities online between October 2007 and January 2011. Given that U.S. Geothermal's proposal represents only 45.5 MW of the 100 MW sought under the RFP and given that the preferred portfolio in the 2006 IRP calls for 150 MW of geothermal energy, what plans does Idaho Power have to acquire more geothermal energy in the future? REQUEST NO. 15: Please explain why Idaho Power in November of2006 determined that it would not pursue ownership of a geothermal resource. REQUEST NO. 16: The executed Power Purchase Agreement (PPA; Agreement) is for approximately 13 MW of the 45.5 MW bid by u.S. Geothermal under the RFP. Idaho Power states that agreements for the remaining 32.5 MW of power will be submitted to the Commission separately from the initial filing. Will the terms and conditions, including the price for power, be the same for the remaining 32.5 MW as for the initial 13 MW? Will the Company request similar recovery of all related expense in its PCA mechanism? REQUEST NO. 17: Are Idaho Power and u.S. Geothermal currently negotiating power sales agreements for the remaining 32.5 MW? If so, when does Idaho Power expect that the agreements will be filed with the Commission? If not, what things have to take place before these negotiations can begin? REQUEST NO. 18: Please provide any analysis performed by Idaho Power or u.s. Geothermal comparing the cost and value of the existing 10 aMW PURP A contract to the new 13 MW Agreement over the term of the agreements. For any numerical analysis performed using Excel, please provide executable electronic copies of the spreadsheets with formulas intact. REQUEST NO. 19: Under the Agreement, the price paid by Idaho Power for all energy delivered includes the value of RECs associated with 3 MW of geothermal generation for the first 10 years of the agreement, and for the remaining 15 years of the PP A, Idaho Power will SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY NOVEMBER 2, 2007 receive 51 % of the RECs associated with 13 MW of geothermal generation. Was this distribution ofRECs between Idaho Power and U.S. Geothermal purely the result of negotiation or is there some rationale to it? Please explain any rationale. REQUEST NO. 20: Please explain why Idaho Power is requesting 100% cost recovery in the PCA for the Raft River I LLC Agreement when it did not ask for similar treatment for the Telocaset (Elkhorn) wind PP A. REQUEST NO. 21: Please provide a copy of any interconnection agreements, transmission agreements, transmission arrangements and Idaho Power Delivery Business Unit approvals, including proof that firm transmission capacity has been acquired that enables the facility to deliver energy to Idaho Power equal to the Maximum Capacity. REQUEST NO. 22: Please provide an estimate of the amount and cost to Idaho Power of Inadvertent Energy that may be produced and purchased under the terms of the Agreement. Does Idaho Power expect that Inadvertent Energy will be produced? Given the executed PP A, is there an understanding that Idaho Power will accept all Inadvertent Energy up to 13 MW? REQUEST NO. 23: Please explain the rationale behind the contract provisions requiring detailed, frequent production forecasts, given that the facility is expected to have a very high capacity factor and very predictable output. REQUEST NO. 24: Has a Seller Guaranty, similar to the sample included as Appendix C to the PP A, been executed? If so, please provide a copy. If not, when does Idaho Power expect that one will be executed? REQUEST NO. 25: Please explain any rationale for the $750 000 amount required as Performance Assurance as required by Section 16.2 of the Agreement. Discuss whether and how the amount of the Performance Assurance is related to the amounts Idaho Power expects to pay over the term of the Agreement for power purchases. Why is the amount of the required Performance Assurance so much less than the amount required for the Telocaset wind contract? SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY NOVEMBER 2, 2007 REQUEST NO. 26: Please explain the basis for the amounts ofthe Net Energy Shortfall Damages caps as shown on page 3 of Appendix E to the Power Purchase Agreement. Were the amounts shown derived based on calculations of estimated damages or were they based purely on negotiation between the parties? REQUEST NO. 27: Has Idaho Power estimated the value ofRECs it will receive under the terms of the Agreement? Ifso, what is the estimated value and how was it determined? REQUEST NO. 28: Please provide any evidence or documentation supporting the likelihood that RECs that to be received by Idaho Power can be certified under any existing certification programs or by certification entities. Can RECs be certified in advance in order provide some assurance that they will be marketable should Idaho Power wish to sell them or that they will have value should Idaho Power need to retain them in the future? DATED at Boise, Idaho, this day of November 2007. ma!ZScott oodbury Deputy Attorney General Technical Staff: Rick Sterling i:umisc:prodreq/ipceO7.17swrps prod req 2 SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY NOVEMBER 2, 2007 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF NOVEMBER 2007 SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-07- BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: LISA D NORDSTROM BARTON L KLINE IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 MAIL: lnordstrom~idahopower.com bkline~idahopower.com RIC GALE VP - PRICING AND REGULATORY IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 MAIL: rgale~idahopower.com CERTIFICATE OF SERVICE