20090612IPC to ICL 1-20.pdf

esIDA~POR(I
An IDACORP Company
'\..M
BARTON L. KLINE
Lead Counsel
June 11, 2009
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-09-03
LANGLEY GULCH POWER PLANT
Dear Ms. Jewell:
Enclosed for filing are an original and three (3) copies of Idaho Power Company's
Response to the First Production Request of the Idaho Conservation League in the above
matter. In addition, also enclosed are four (4) copies of a disk containing information
responsive to the Conservation League's requests. The remaining responses to the
Conservation League's requests wil be provided as soon as they are completed.
If you have any questions about the enclosed information, please let me know.v~
Barton L. Kline
BLK:csb
Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
BARTON L. KLINE, ISB #1526
LISA D. NORDSTROM, ISB #5733
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: 208-388-6936
bklineCâidahopower.com
Inordstromcæidahopower.com
RECEIVED
2909 JUN II PH It: 51
IDAHO PUBLIC
UTILITIES COMMISSION
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY FOR
THE LANGLEY GULCH POWER PLANT.
)
) CASE NO. IPC-E-09-03
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE FIRST
) PRODUCTION REQUEST OF THE
) IDAHO CONSERVATION LEAGUE
COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in
response to the First Production Request of the Idaho Conservation League dated June
4, 2009, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 1
REQUEST FOR PRODUCTION NO.1: According to Response to Staff Request
# 6, since the selection of the Langley Gulch project there have been no changes to the
Company's load projections that have either accelerated or deferred the on-line dates
need for this resource. Please provide an updated 10-year load forecast, which
incorporates the impacts of the economic downturn.
RESPONSE TO REQUEST FOR PRODUCTION NO.1: The requested
information is contained in the Company's Responses to Staffs Requests Nos. 84 and
85. Copies of those responses have been provided to ICL. These responses
demonstrate that the Company's most recent load forecast has incorporated current
economic conditions as they relate to Idaho Powets sales and loads and load and
resource balance.
The response to this Request was prepared by Barr Smith, Planning Analyst, and
Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 2
REQUEST FOR PRODUCTION NO.2: Provide the updated load forecast data
in equivalent form as shown IPC's 2008 IRP Update, Section 3. Planning Period
Forecasts:
A. Table 2. Range of System Load Growth Forecasts (aMW) 2008 IRP
Update, page 11.
B. Table 3. Change in System Load Growth (aMW) 2008 IRP Update vs.
2006 IRP, page 12. Please modify the table to compare the requested updated load
forecast with the 2008, not 2006 IRP.
C. Figure 2. Forecasted Firm Load - 70th Percentile, page 12.
D. Table 4, Range of System Peak Growth Forecasts (MW) 2008 IRP
Update, page 13.
E. Table 5, Change in System Peak Growth (MW) 2008 IRP Update, page
13.
F. Figure 3. Forecasted Firm Summer Peak - 95th Percentile, page 13.
RESPONSE TO REQUEST FOR PRODUCTION NO.2: Idaho Power objects to
this Request for the following reasons:
1. Under the Commission's Rules of Practice and Procedure and the
Idaho Rules of Civil Procedure, discovery may be used to obtain copies of documents in
the Company's possession. This production request goes beyond the scope of the
Rules and asks Idaho Power to perform a new analysis and put this new analysis in a
form dictated by ICL. Idaho Power has not performed this analysis and it does not
possess documents that contain the information as requested by ICL.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 3
2. Providing the information as requested would be extremely
burdensome. It would require the expenditure of many man-hours in order to provide
the information to ICL in the form it has requested. This is ICL's first production request
and it was not made until one day before the discovery cutoff date. The Company could
not complete this effort in time for ICL to use it to prepare its testimony in this case.
These objections notwithstanding, Idaho Power believes it has provided the
information that is necessary for ICL to develop the data it is requesting. ICL's requests
indicate that it has copies of the Company's 2008 IRP Update and its February 2009
Addendum filed in Oregon for the B2H project. If ICL takes the information the
Company has provided in response to Staffs Production Request No. 84 and compares
it to the same information contained in Idaho Powets 2008 IRP Update and 2009
Addendum, ICL will have much of the data it has requested and ICL can organize the
data into the requested categories.
The response to this Request was prepared by Barr Smith, Planning Analyst,
and Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 4
REQUEST FOR PRODUCTION NO.3: Please provide a summary worksheet
that indicates for the 2008 IPR Update and the requested load forecast update by the
years 2008, 2012, and 2016, the data for the key variables that underlie the load
forecast including but not limited to the following data listed as follows in (A), (B), and
(C).
A. Residential, Commercial, Industrial, Agricultural, and Additional Firm Load,
and Contract Off System Load (i.e. the input data in Appendix A - Sales and Load
Forecast, IPC 2006 Load Forecast).
B. Employment by Nonagricultural, Mining, Construction, Manufacturing,
Transportation I Communications I Utilties, Wholesale and Retail Trade, Finance I
Insurance I Real Estate, Services, and Government (i.e. the input data in Appendix C -
Economic Forecast, IPC 2006 Load Forecast).
C. Total Personal Income, Per Capita Personal Income, Population (i.e. the
input data in Appendix C - Economic Forecast, IPC 2006 Load Forecast).
RESPONSE TO REQUEST FOR PRODUCTION NO.3: Idaho Power is unable
to respond to Request for Production No. 3 because the Request is vague, ambiguous,
and requires clarification. For example, the first sentence asks that the Company to ". . .
provide a summary worksheet that indicates for the 2008 IPR (sic) Update and the
requested load forecast update. . . ." The Company is uncertain as to which requested
load forecast update the Request is referring.
In addition, Idaho Power objects to the Request on the grounds that under the
Commission's Rules of Practice and Procedure and the Idaho Rules of Civil Procedure,
discovery may be used to obtain copies of documents in the Company's possession.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 5
This production request goes beyond the scope of the Rules and asks Idaho Power to
perform a new analysis and put this new analysis in a form dictated by ICL. Idaho
Power has not performed this analysis and it does not possess documents that contain
the information as requested by ICL.
The response to this Request was prepared by Barr Smith, Planning Analyst,
Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 6
REQUEST FOR PRODUCTION NO.4: Please provide the source data for each
of the items (a), (b), and (c) listed in Request for Production NO.3 above.
RESPONSE TO REQUEST FOR PRODUCTION NO.4: See the Company's
Response to ICL's Request for Production NO.3.
The response to this Request was prepared by Barr Smith, Planning Analyst,
Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE-7
REQUEST FOR PRODUCTION NO.5: IPC's 2006 IRP Appendix A - Sales and
Load Forecasts at pages 7 - 9 the section entitled "Load Forecasts Based on Economic
Uncertainty", provides the results of two additional load forecasts for the Idaho Power
service area that provide a range of possible load growths for the 2005-2025 planning
period due to variable economic and demographic conditions. As stated in the 2006
IRP Appendix A page 7: "The average growth rates for the high and low growth
scenarios were derived from the historical distribution of one-year growth rates over the
period 1979 - 2005." The result is Firm Load Growth Rate per year 2005 - 2025 of
1.9% for the Expected Scenario, and 2.4% and 1.5% for the High and Low Scenarios,
respectively.
A. If there is a similar load forecast sensitivity analysis for IPC's 2008 IRP
Update, please provide the results of that analysis in a format similar to the 2006 IRP.
B. If there was not a load forecast sensitivity analysis conducted for IPC's
2008 IRP Update, please explain why.
C. If there is a similar load forecast sensitivity analysis for IPC's February
2009 IRP Addendum using IPC's August 2008 load forecast, please provide the results
of that analysis in a format similar to the 2006 IRP.
D. If there is not a load forecast sensitivity analysis conducted for IPC's
February 2009 IRP Addendum using IPC's August 2008 load forecast, please explain
why.
RESPONSE TO REQUEST FOR PRODUCTION NO.5:
A. A load forecast sensitivity analysis was not conducted for IPC's 2008 IRP
Update.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 8
B. The 2008 IRP Update was an informational filing. The Company did not
request acknowledgement. The uncertainty analysis has typically been prepared as a
part of the separate Sales and Load Forecast document prepared for an Integrated
Resource Plan filng in which the Company is seeking acknowledgment. A separate
Sales and Load Forecast document was not prepared for the 2008 IRP Update.
C. The document included on the enclosed CD, Load Forecasts Based on
Economic Uncertainty.docx, contains the requested information. The sales and load
forecast figures illustrated and shown in the document are the Expected Case and 70th
Percentie sales and load forecasts that were done on October 7, 2008.
D. See response to C above.
The response to this Request was prepared by Barr Smith, Planning Analyst, and
Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 9
REQUEST FOR PRODUCTION NO.6: IPC's 2008 IRP Update, Section 3.
Planning Period Forecasts, page 10, states that "The recent cyclical slowdown in
customer growth, as indicated in the total number of customers for year end 2007 is
approximately three tenths of a percent lower than forecast (0.3%). The effect of the
cyclical downturn on the longer term trend wil be evaluated for the 2009 IRP." Please
provide the results of all analyses in preliminary, intermediate, or final form conducted
by or for IPC concerning the effect of the cyclical downturn on the IPC's most recent
published forecast.
A. If no such analyses in preliminary, intermediate, or final form have been
conducted, please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO.6: The requested
information is contained in the material provided in the Company's Response to Staffs
Requests Nos. 84 and 85.
The response to this Request was prepared by Barr Smith, Planning Analyst, and
Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE -10
REQUEST FOR PRODUCTION NO.7: Concerning IPC's August 2009 load
forecast, please provide all preliminary, intermediate, or final results.
A. If no preliminary or intermediate results are available, please indicate
when such results wil be available.
B. Please provide all preliminary or intermediate results when available.
RESPONSE TO REQUEST FOR PRODUCTION NO.7: The requested
information is contained in the material provided in the Company's Response to Staff's
Requests Nos. 84 and 85.
The response to this Request was prepared by Barr Smith, Planning Analyst, and
Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 11
REQUEST FOR PRODUCTION NO. a(sicl: Please provide an equivalent
"Average Energy Load and Resource Balance" spreadsheet per IPC's 2008 Updated
IRP Appendix C, page 96, "70th Percentile Water and 70th Percentile Average Load" on
a monthly basis January 2012 through December 2012" based on the requested load
forecast update in Request for Production No. 1 above.
RESPONSE TO REQUEST FOR PRODUCTION NO. a(sicl: The requested
information is contained in the material provided in the Company's Response to Staff's
Requests Nos. 84 and 85.
The response to this Request was prepared by Barr Smith, Planning Analyst, and
Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE -12
REQUEST FOR PRODUCTION NO. 9(sicl: Please provide additional "Average
Energy Load and Resource Balance" spreadsheets per IPC's 2008 Updated IRP
Appendix C, page 96, "70th Percentile Water and 70th Percentile Average Load" for
2013 and beyond until the need for the proposed 330 MW Langely Gulch Power Plant is
demonstrated based on the requested load forecast update in Request for Production
NO.1 above.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9(sicl: The requested
information is contained in the material provided in the Company's Response to Staffs
Requests Nos. 84 and 85.
The response to this Request was prepared by Barr Smith, Planning Analyst, and
Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE -13
REQUEST FOR PRODUCTION NO. 12(sicl: Idaho Public Utilities Commission
Order No. 30171 approved significant changes to IPC's Irrigation Peak Rewards
Program. The changes authorized a new dispatchable curtailment program that is
expected to increase avoided peak demand from the 35 MW realized during the
summer of 2008 to an estimated 144 MW in 2009, 186 MW in 2010, and 232 MW in
2011. Please provide the results of all analysis on the change in the forecasted
"Monthly Surplus I Deficit" for the peak summer month of July 2012 and the peak
summer month of 2013 - 2016 for the:
A. IPC 2008 IRP Update.
B. IPC February 2009 IRP Addendum.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12(sicl: The requested
information is contained in the material provided in the Company's Response to Staff's
Requests Nos. 84 and 85.
The response to this Request was prepared by Barr Smith, Planning Analyst, and
Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 14
REQUEST FOR PRODUCTION NO. 13(sicl: On March 13, 2009, Idaho Power
filed Case No. IPC-E-09-05 with the IPUC to increase the Idaho Rider from 2.5 percent
of base rate revenues to 4.75 percent. Please provide the results of all analysis
including preliminary and intermediate estimates of projected increase in IPC
incremental energy efficiency and demand response annual energy and peak demand
savings by year beginning with 2010 through 2016. Please provide the results of all
analysis on the change in the forecasted "Monthly Surplus I Deficit" for the peak
summer month of July 2012 and the peak summer month of 2013 -2016 for the:
A. IPC 2008 IRP Update.
B. IPC February 2009 IRP Addendum.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13(sicl: The requested
information is contained in the material provided in the Company's Response to Staffs
Requests Nos. 84 and 85.
The response to this Request was prepared by Barr Smith, Planning Analyst, and
Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE -15
REQUEST FOR PRODUCTION NO. 14(sicl: As mentioned in the Response to
Staff Request #53, in 2008 IPC contracted with Nexant Consulting to produce a DSM
Potential Study. Preliminary results and computer models provided by Nexant are being
used to identify new DSM potential for the 2009 IRP. Please provide the preliminary
results from the Nexant DSM Potential Study.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14(sicl: In February
2008, as the result of a RFP process, Idaho Power Company contracted with Nexant,
Inc., to provide a DSM potential study to help identify new DSM potential to be included
in the 2009 IRP. In September, the Company received a draft copy of Nexants report
along with proposed models for review. As a result of both Idaho Powets review and
peer review, the Company and Nexant have jointly concluded that Nexants analysis
was not complete and that significant changes to the initial draft and accompanying
models were needed. Because of these required modifications to the draft, Idaho
Power does not currently have valid preliminary results from the consultant. At this
point, Idaho Power is waiting for a new draft with valid preliminary results. Nexants
potential study and model wil be completed and available for Idaho Power to use to
prepare the 2009 IRP, which wil be filed by year end.
The response to this Request was prepared by Peter Pengily, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE -16
REQUEST FOR PRODUCTION NO. 16(sicJ: As mentioned in Response to
Staff Request #55, in 2009 IPC plans to expand its effort in energy effciency in a
number of areas, including via IPUC Case No. IPC-E-09-02, a demand response
program to its commercial and industrial customers through a third-party demand
response aggregator. Please provide the results of all preliminary analysis indicating
the projected increase in IPC incremental energy efficiency and demand response
annual energy and peak demand savings by year beginning with 2010 through 2016.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16(sic): The requested
information is contained in the material provided in the Company's Response to Staff's
Requests Nos. 84 and 85.
The response to this Request was prepared by Barr Smith, Planning Analyst, and
Karl Bokenkamp, General Manager Power Supply Operations and Planning, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE-17
REQUEST FOR PRODUCTION NO. 17(sicl: As mentioned in Response to
Staff Request #55, in 2009 IPC has been transitioning from traditional flat rate designs
towards more time differentiated pricing for a number of years, and that the Company
envisions widespread use of dynamic pricing across the system. Please provide the
results of all preliminary analysis indicating the projected decreases in customer peak
demand requirements from differentiated pricing and dynamic pricing by year beginning
with 2010 through 2016.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17(sicJ: With the
deployment of Advanced Metering Infrastructure throughout the Company's service
territory, the abilty to offer time-differentiated pricing to our customers wil be possible.
However, today time-differentiated rates are only possible with the Company's Large
General Service customers - Schedule 9 Primary and Transmission Service levels and
the Company's Large Power Service customers - Schedule 19. The Company has not
performed any analysis indicating the projected decreases in customer peak demand
requirements from differentiated pricing and dynamic pricing by year for the years 2010
through 2016.
The response to this Request was prepared by Michael Youngblood, Manager of
Rate Design, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE -18
REQUEST FOR PRODUCTION NO. 1S(sicl: As mentioned in Response to
Staff Request #55, since 2005, IPC has operated a successful Critical Peak Pricing
program in the Emmett Valley with customers who piloted its Advanced Metering
Infrastructure (AMI) system. Please provide the results of the projected decreases in
customer peak demand requirements from the Emmett Valley AMI program from 2005
through 2008.
A. Please provide the projected decreases in customer peak demand
requirements from the Emmett Valley AMI program for 2009 through 2016.
B. Please indicate all plans to expand the successful Emmett Valley Critical
Peak Pricing program to other parts of IPC's service territory.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1S(sic): The results of the
decreases in customer peak demand requirement from the Emmett Valley AMI program
are contained in each of the annual Energy Watch and Time-of-Day Programs Annual
Reports that were filed with the Idaho Public Utilities Commission for the years 2005,
2006,2007, and 2008.
A. The Company has not performed an analysis of the projected decreases
in customer peak demand requirements from the Emmett Valley AMI program for the
years 2009 through 2016 in Case Nos. IPC-E-05-02, 06-05, and 07-05.
B. The Company does intend to extend its current or a variation of its time
variant pricing programs, Schedule 4 (Residential Service Energy Watch Program) and
Schedule 5 (Residential Service Time-Of-Day Program), throughout the Company's
service territory once AMI, and all associated and necessary back-office systems, are in
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE -19
place. In addition, the Company intends to evaluate and provide time variant pricing
options for its other rate schedules as appropriate.
The response to this Request was prepared by Michael Youngblood, Manager of
Rate Design, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 20
REQUEST FOR PRODUCTION NO. 19(sicl: When estimating future customer
loads, how does Idaho Power Company account for reductions in customer demand
due to increases in electricity prices?
A. How does the Company estimate this price elasticity?
B. Provide any studies conducted by or for IPC or relied upon by IPC to
estimate price elasticity.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19l:: Fuel prices, in
combination with service area economic data, impact long-term trends in electricity
sales. Changes in relative fuel prices can have significant impacts on the future
demand for electricity. Short-term and long-term nominal electricity price increases are
generated internally from Idaho Power financial models. The nominal price estimates
are adjusted for projected inflation by applying the appropriate economic deflators to
arrive at real fuel prices.
Regression analysis is used to determine the relationship between residential and
commercial use-per-customer and retail electricity prices. Regression analysis is also
used to determine the relationship between irrigation and industrial class sales and
electricity prices. Since both use-per-customer and electricity sales vary inversely with
retail electricity prices, the forecast of future retail electricity prices is a factor in
determining the results of a regression equation or modeL.
A. Price elasticity is estimated with the use of regression analysis.
Regression analysis is used for weather adjusting historical electricity sales and sales
forecasting. Retail electricity price terms are used as explanatory variables in the
residential and commercial use-per customer regression models and the irrigation and
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 21
industrial sales forecasting regression models. In the residential and commercial
regression models, use per customer is a function of the retail price of electricity. In the
irrigation regression model, electricity sales to the irrgation class are a function of the
price of electricity paid by irrigators. In the industrial sector, regression models were
developed for 16 industry groups to determine the relationship between historical
electricity sales and historical employment or population and other relevant explanatory
variables, including electricity prices if the regression results were significant.
B. Price elasticity results are shown in the table below. In addition, copies of
the relevant regression formulas are provided on the enclosed CD.
Price Elasticity
Price Elasticity
January
February
March
April
May
June
July
August
September
October
November
December
-1.2%
-2.0%
-1.7%
-1.4%
-1.9%
-1.5%
-1.5%
-1.5%
-1.4%
-1.4%
-1.2%
-1.2%
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 22
Price Elasticity
January
February
March
April
May
June
July
August
September
October
November
December
-0.2%
-0.7%
-0.5%
-0.4%
-0.8%
-0.3%
-0.4%
-0.5%
-0.4%
-0.7%
-0.5%
-0.5%
Irrigation Sector Sales
Price Elasticity
Not significant
Price Elasticity
Food Processing Sales
Government Sales
-4.7%
-3.1%
The response to this Request was prepared by Barr Smith, Planning Analyst,
Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 23
REQUEST FOR PRODUCTION NO. 20(sicJ: Please describe what preparations
Idaho Power is making in anticipation of federal renewable electricity standard ("RES"),
specifically:
A. Please describe how the acquisition of renewable energy to meet a
federal RPS affects the need for the Langley Gulch project.
B. If Idaho Power must meet an RES that requires 20 percent of electricity
generated for retail customers to come from renewable sources by 2020 how many
megawatts of renewable energy must be brought online with Langley Gulch and without
Langley Gulch?
C. If an analysis has not been conducted please explain in detail how the
company believes it is prudent to go forward with this project without the analysis.
Please provide any and all memos and documentation of discussion regarding an
anticipated RES.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20(sicl: Idaho Power has
been closely following draft federal RES/RPS legislation throughout the preparation of
the 2009 IRP, which began in the summer of 2008. Numerous presentations and
updates have been conducted and discussed with the IRP Advisory CounciL. Idaho
Power expects some form of federal RES to be passed in the near future and,
accordingly, the analyses being done for the 2009 IRP account for the value of RECs
generated from qualifying renewable resources.
A. Idaho Power has long recognized the value of a diverse resource portolio.
As the Company continues to add renewable resources to its portolio, whether due to a
federal RES or not, the variable and intermittent nature of renewable resources wil
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 24
require greater levels of operating reserves in order to keep the system balanced and to
maintain reliability. A combined-cycle combustion turbine such as Langley Gulch wil
provide operational flexibilty and, more specifically, additional operating reserves
necessary for the integration of intermittent renewable resources.
B. Two current federal RES bills are being discussed in Congress: (1) H.R.
2454: The American Clean Energy and Security Act of 2009 (Waxman-Markey) and (2)
the Senate Majority RES Proposal (Bingaman). Both bils are similar in most respects
with the major difference being the renewable percentage requirement. The Waxman-
Markey bil requires 20 percent by 2020 while the Bingaman bil requires 15 percent by
2021. These bils along with earlier proposed legislation have all allowed generation
from existing hydro projects to be subtracted from the sales base used to determine the
renewable requirement.
Because the renewable percentage requirement is calculated based on a utility's
sales base, the inclusion or exclusion of Langley Gulch in Idaho Powets resource
portolio wil not impact how a federal RES requirement is calculated. However, Idaho
Power anticipates that load growth between now and the year 2020 will allow the
Company to add suffcient renewable resources to its portolio in order to meet a federal
RES requirement.
C. As previously mentioned, Idaho Power has been following proposed
federal RES legislation for some time and has presented and discussed the topic on
numerous occasions with the 2009 IRP Advisory CounciL. The following table presents
a summary of the key components of the Waxman-Markey bil and the Bingaman
proposal:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 25
Active Federal Renewable Electricity Standard (RES) Legislation
As of June 8, 2009
ii,i,ii u//J.a
Soonsor Waxman ID-MA) & Markev ID-MA)Binnaman ID-NM)
Chamber House Senate
Summarv 20% bv2020 15% bv 2021
Status In committee lintroduced Mav 2009)In committee lintroduced Mav 2009)
Treatment of Existinn Hvdro Excluded frm the sales base used to calculate Excluded frm the sales base used to calculate
Required Annual Percentaqe 2012 - 6%2011 - 3%
2013 - 6%2014 - 6%
2014- 9.5%2017 - 9%
2015 - 9.5%2019 -12%
2016 -13%2021 -15%
2017 -13%
2018 -16.5%
2019-16.5%
2020 - 20%
2021-2039 - 20%
Resources Eligible to Meet RES Wind, solar, geothermal, renewable biomass,Wind, solar, gethermal, ocean, biomass, landfill
biogas and biofuels derived exclusively from gas, incrementl hydropower (effciency
renewable biomass, marine and hydrokinetic and improvements or capacit additions), hydrokinetic
qualified hydropower (effciency improvements or and new hydropower at existing dams with no
capacity additions).generation.
Qualifying Date for Resources Qualified hydropower (placed in servce on or Incremental hydropower (placed in servce on or
Eligible to Met RES after January 1, 1992), no qualifng date for othr after January 1, 2001), other eligible resources
eligible resources.(placed in servce on or after January 1, 2006).
Shelf life of federal RECs Unlimited bankina of RECs 3 vears frm date of issuance of the REC.
Alternative Compliance $251MWh (infation adjusted).$21.1 O/MWh (inflation adjusted) if the electric
utility does not elect to petition the Secretary to
waiv the requirement.
Non-Compliance Penalty $50/MWh (inflation adjusted) or twice the 200% of the value of the alternative compliance
Alternative Compliance payment.payment (adjusted for inflation)
Use of funds from Alternative Paid directly to state in which electric supplier is State grants for development of renewable
Compliance Payments and Penalties located to be used for deploying renewable resources or to offet increases in customers
technologies and cost-effctive energy efciency bils.
measures and programs.
Energy Effciency Utiltis can meet up to 25% of their requirements Utilties can meet up to 26.67% of their
through energy effciency savings: customer requirements through energy effciency savings:
facility savings, reductions in distrbution system customer facilty savings, electricity savings,
losses, combined heat and power (CHP) savings recycled energy combined heat and power
and fuel cell savings. Governr can petition (CHP).
FERC to increase the energy effciency savings
proporton to not more than 40%.
Cost Recoverv Not Addressed Not Addressed
Exemption from RES Electric utilites with less than 4 milion MWh of Electric utilites with less than 4 million MWh of
retail sales.retail sales and the State of Hawaii.
Power Sales Contracts If not addressed in the contract, RECs belong to Not Addressed
the supplier.
Coordination with State Policies States can have hiaher standards.States can have hiaher standards.
Renewable Genertion Facilties Not Addressed DoubleRECs
Distributed Generation Facilit Trinle RECs Ineneration oe 2 MW)Triole RECs (aeneration oe 1 MW)
Mixed Renewable Resource (ex.RECs based upon porton attbutable to the Not Addressed
combined solar and gas plant)renewable energy resource.
Waiver from Compliance Not Addressed Secretary may wave requirements for 5 years
because of natural disasters or acts of god.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 26
In addition to following the proposed federal legislation, Idaho Power has
calculated the amount of renewable generation that would be required under each of
the current proposals. Similar calculations were prepared and presented at IRP
Advisory Council meetings, but the presented information has become outdated as the
proposals being discussed in late 2008 and early 2009 have been superseded by the
Waxman-Markey Bil in the House and the Bingaman proposal in the Senate. The table
on the following page presents the calculated amount of renewable generation Idaho
Power would need for each year under each of the proposals.
Information presented at the IRP Advisory Council meetings can be found in the
presentation slides. In addition, the meeting minutes contain a summary of the
discussion and comments from the meetings. This information is available on Idaho
Powets website at:
http://ww.idahopower.com/AboutUs/PlanningForFuture/irp/2009/20091 RPAC _ Schedule.cfm
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 27
Estimated Impact of Proposed Federal RES Requirements
Median Load Forecast (aMW, May 2009 Update, No DSM)
Hydro Generation to Subtrct from Sales Base (aMW, Median Water)
Load (Sales Base) Used to Calculate RES Requirement (aMW)
H.R. 2454: The American Clean Energy and Securit Act of 2009 (Waxman-Markey)
2012 2014
2,044 2,122
964 957
1,080 1,165
RES Requirem ent (%)
RES Requirement (aMW)
DSM Cap (DSM can meet up to 25% of requirem ent)
Total DSM (aMW)
Qualifyng DSM (aMW)
Existing Resources and DSM Eligible to meet RES
DSM(aMW)
Elkhorn Valley Wind (aMW)
Raft River Geothermal (aMW)
Total
Remaining RE Requirement (aMW)
able Resource RE Requirement
32% CF) or
erm al (92% CF)
rabolic Trough, 6 hours storage (28% CF) or
Anaerobic Digester (75% CF)
Senate Majority RES Proposal (Bingaman)
Median Load Forecast (aMW, May2009 Update, No DSM)
Hydro Generation to Subtract from Sales Base (aMW, Median Water)
Load (Sales Base) Used to Calculate RES Requirement (aMW)
RES Requirement(%)
RE Requirement (aMW)
DSM Cap (DSMcan meet up to 26 2/3% of requirement)
Total DSM (aMW)
Qualifyng DSM (aMW)
Existing Resources and DSM Eligible to meet RES
DSM(aMW)
Elkhorn Valley Wind (aMW)
Raft River Geothermal (aMW)
Total
Remaining RE Requirement (aMW)
2%
Geothermal
Solar- Para
Biogas -Ana
or
Trough, 6 hours storage (28% CF)
ic Digester (75% CF)
6.0%9.5%
65 111
16 28
54 77
16 28
2016 2018 2020
2,187 2,247 2,312
958 957 958
1,229 1,290 1,354
13.0%16.5%20.0%
160 213 271
40 53 68
99 120 140
40 53 68
16 28 40 53 68
34 34 34 34 34
QJ QJ 0.1 §.§.
50 62 74 92 107
15 49 86 121 164
Nameplate (MW) for Each Resource Type45 153 268 377 51316 53 17852 175 58619 219
2011 2014 2017 2019 2021
1,995 2,122 2,211 2,278 2,356
966 957 957 957 957
1,029 1,165 1,254 1,321 1,399
3.0%6.0%9.0%12.0%15.0%
31 70 113 159 210
8 19 30 42 56
41 77 11 130 il
8 19 30 42 56
8 19 30 42 56
34 34 34 34 34
QJ QJ QJ §.§.
42 53 64 81 95
(11 )17 49 77 115
Nameplate (MW) for Each Resource Type
(36) 54 152 241 359(12) 19 53 84 125
(41) 61 174 276
(15) 23 65 103
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 28
The response to this Request was prepared by M. Mark Stokes, Manager, Power
Supply Planning, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 11th day of June 2009.
G~
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 29
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11 th day of June 2009 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Scott Woodbury
Deputy Attomey General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho
Power and Northwest and
Intermountain Power Producers
Coalition
Peter J. Richardson, Esq.
RICHARDSON & O'LEARY PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
Snake River Allance
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
Idaho Irrigation Pumpers
Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE
& BAILEY, CHARTERED
P.O. Box 1391
201 East Center
Pocatello, Idaho 83204-1391
-l Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email Scott.Woodburvcæpuc.idaho.gov
Hand Delivered
-l U.S. Mail
_ Overnight Mail
FAX
-l Email petercærichardsonandolearv.com
Hand Delivered
-l U.S. Mail
_ Overnight Mail
FAX
-l Email dreadingcæmindspring.com
Hand Delivered
-l U.S. Mail
_ Overnight Mail
FAX
-l Email kmillercæsnakeriveralliance.org
Hand Delivered
-l U.S. Mail
_ Overnight Mail
FAX
-l Email elocæracinelaw.net
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 30
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Hand Delivered
-. U.S. Mail
_ Overnight Mail
FAX
-. Email tonycæyankel.net
Idaho Conservation League
Betsy Bridge
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
Hand Delivered
-. U.S. Mail
_ Overnight Mail
FAX
-. Email bbridgecæwildidaho.org
Northwest and Intermountain
Power Producers Coalition
Susan K. Ackerman
9883 NW Nottage Drive
Portland, Oregon 97229
Hand Delivered
-. U.S. Mail
_ Overnight Mail
FAX
-. Email Susan.k.ackermancæcomcast.net
Community Action Partnership
Association Of Idaho
Brad M. Purdy
Attorney at Law
2019 North 17th Street
Boise, Idaho 83702
Hand Delivered
-. U.S. Mail
_ Overnight Mail
FAX
-. Email bmpurdycæhotmail.com
~
Barton L. Kline
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 31