20090616IPC to ICL 7, 10-11, 21.pdf

ReCE\VEO
~ i.i 5\
1SIDA~PORQÐ
An IDACORP Company
LISA D. NORDSROM
Senior Counsel
June 15, 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 filng are an original and three (3) copies of Idaho Power Company's
Response to the First Production Request of the Idaho Conservation League (Third Batch)
in the above matter. In addition, four (4) copies of a disk containing information responsive
to the Idaho Conservation League's Requests are enclosed.
Also, enclosed are an original and three (3) copies of Idaho Power Company's
Confidential Response to the Idaho Conservation League's First Production Request.
Please handle this confidential information in accordance with the Protective Agreement
and Nondisclosure Agreement in place between the parties.
Very truly yours,;t~4~
Lisa D. Nordstrom
LDN: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
bkline~idahopower.com
Inordstrom~idahopower.com
RECEIVED
2099 JUN 15 PHi.: 51
IQAHOlYBiH~" 1".',
UTlLll IES COi\;.¡~,livöivr.
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 Power" 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. 7 (sic): Please provide' the following
information regarding IPC's residential customers on a monthly basis beginning with
2008 and through the latest available month of 2009:
A. The number of idle residential meters (meters that exist with no customers
taking service).
B. The number of residential meters with usage of less than 50 kWh per
month.
C. The number of residential customers in arrears by more than 30 days, 60
days, and 90 days.
D. The number of disconnection notices served in each month,
E. The number of actual disconnections for non -payment in each month.
F. The number of reconnections in each month.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7(sic):
A.
~an-OS Feb-OS Mar-OS Apr-OS May-OS Jun-OS Jul-OS Aug-OS Sep-OS Oct-OS Nov-OS Dec-OS Jan-09 Feb-09 Mar-09
5,577 5,826 6,228 6,595 6,491 6,552 6,689 6,691 6,856 7,003 6,951 6,720 6,879 7,232 7,669
B.
!Jan-OS eb-OS Mar-oS ~pr-OS Mav-OS Jun-oS Uul-oS Aua-oS Sep-OS Oct-OS "'ov-OS Dec-OS Jan-09 Feb-09 Mar-09
16,090 16,117 20,903 16,681 17,119 16,460 5,133 14,680 14,194 14,252 14,405 13,515 12,665 13,000 13,481
C.
30+60+90+
days days days
Jan-08 59,154 22,964 10,012
Feb-08 59,938 22,430 10,044
Mar-08 58,382 20,895 7,827
Apr-08 54,717 19,247 6,941
May-08 58,871 19,278 6,705
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 2
Jun-08 57,067 21,096 6,576
Jul-08 57,235 20,308 7,156
Aua-08 62,057 19,834 6,677
Sep-08 62,803 20,126 6,262
Oct-08 60,315 20,711 6,260
Nov-08 60,546 22,417 7,497
Dec-08 63,068 24,599 9,600
Jan-09 64,260 26,083 12,134
Feb-09 66,620 25,391 11,834
Mar-09 62,504 23,711 9,194
D.
Jan-OS Feb-OS Mar-OS Apr-OS May-OS Jun-OS Jul-OS ~ug-OS Sep-OS Oct-OS Nov-OS Dec-OS Jan-09 Feb-09 Mar-09
15,772 17,121 22,230 19,259 20,028 20,682 18,236 19,966 23,337 25,634 17,517 19,021 17,548 17,174 25,929
E.
Jan-OS eb-OS Mar-OS Apr-OS Mav-OS Jun-OS Jul-OS ~ua-OS Sep-OS Oct-OS Nov-OS Dec-oS Jan-09 Feb-09 Mar-09
1,091 1,151 2,173 2,638 2,182 2,158 2,030 1,964 1,878 2,060 1,465 1,008 1,059 1,245 2,439
F.
Jan-08 "eb-oS Mar-OS Apr-oS May-OS Jun-OS Jul-oS ,ug-oS Sep-oS Oct-OS Nov-OS Dec-oS Jan-09 Feb-09 Mar-09
820 891 1,551 1,968 1,751 1,566 1,491 1,519 1439 1,659 1,241 865 800 1,124 1,961
Because the most recent data for April and May 2009 is material non-public
information under SEC Regulation FD and is considered confidential information, it has
been provided separately to those parties that have executed the Protective Agreement
in place in this matter.
The response to this Request was prepared by Bradford L Snow, 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 - 3
REQUEST FOR PRODUCTION NO. 10(sic): In regard to the Request for
Production NO.8 and 9, for the peak summer month of July 2012 and the peak summer
month of 2013 - 2016, for the data entry of "Monthly Surplus/Deficit" under the category
"Existing Resources" please provide the following information:
A. Hourly load distribution curve of the projected monthly deficit: Le.,
disaggregating the monthly figure into 744 hours.
B. Geographic location (or distribution) of the projected monthly deficit,
disaggregated by hour if available.
RESPONSE TO REQUEST FOR PRODUCTION NO.10(sic):
A. Included on the enclosed CD is an Excel spreadsheet which contains the
projected hourly deficits for the month of July in years 2012 through 2016. The deficits
are calculated based on the accepted planning criteria - 70th percentile average load,
95th percentile peak load, and 90th percentile water. Additional assumptions used in the
calculation of the deficits include: (1) monthly aMW for Idaho Power's coal facilities and
mid-Snake hydroelectric projects for all hours, (2) Hells Canyon Complex generation
shaped to match hourly load shape, (3) all wind resources are included at a capacity
factor of 5 percent for peak-hour, (4) simple-cycle peaking units are at full capacity, and
(5) full use of available import capacity from the Pacific Northwest.
B. Idaho Power does not calculate monthly deficits by geographic location
and therefore this information is not available.
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.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 4
REQUEST FOR PRODUCTION NO. 11 (sic): In regard to IPC's February 2009
Addendum for the Boardman to Hemingway Transmission Project, Appendix B - Load
and Resource Balance, in the year 2012 through 2020, IPC assumes Total Power
Purchase Agreements of 47 MW in the month of July. Given the downward pressure on
electricity demand in the Western region from the recession, please provide the results
of all analysis conducted by or for IPC of increasing Power Purchases in 2012 through
2020 above the 47 MW included in IPC's February 2009 Addendum.
A. If no such analysis has been conducted, please provide IPC's opinion as
to the increased availability of purchased power given the downward pressure on
electricity demand in the Western region from the recession.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11(sicl: The referenced
47 MW of purchases for the month of July for 2012 through 2020 is a summation of the
expected monthly average output from the Elkhorn Valley Wind Project, the Raft River
Geothermal Project, and a power purchase agreement Idaho Power has with PPL
Montana. The question contained in this production request is referencing a number
(47 MW) from the average monthly energy pages of the load and resource balance
contained in the IRP Addendum. However, the critical issue for the month of July is
Idaho Power's peak-hour load and the transmission constraints that exist on the Pacific
Northwest path in the summertime. For peak-hour analyses for the month of July, the
load and resource balance includes assumed purchases on all available firm
transmission on the Pacific Northwest path.
Idaho Power has historically maintained 75 MW of firm transmission capacity on
the east side of its system to use in the event of an emergency. However, since the IRP
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 5
Addendum was published in F~bruary 2009, Idaho Power issued an RFP and has
signed contracts to purchase energy in the summer months that wil utilize the available
transmission capacity to the east. These purchases are shown on the updated load and
resource balance sheet contained in the Company's Response to Staffs Production
Request No. 84 and were necessary due to projected near-term deficits that exist until
the Langley Gulch project becomes available. In signing these recent contracts, Idaho
Power is fully utilizing all available firm transmission capacity, including the capacity
historically held for emergency use.
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.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 6
REQUEST FOR PRODUCTION NO. 21 (sic): Please describe what preparations
Idaho Power is making in anticipation of federal cap and trade system, specifically:
A. Please provide information on Idaho Power's carbon dioxide emissions,
specifically total tons emitted and the amount of carbon emissions expected from the
Langley Gulch plant.
B. Please provide an analysis of how the additional carbon emissions from
Langley Gulch will affect Idaho Power and its ratepayers under the proposed cap and
trade system in the American Clean Energy and Security Act of 2009 or other proposed
cap and trade systems.
C. If an analysis has not been conducted please explain in detail and 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 cap and trade system.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21 (sic):
A. Hourly rates for carbon dioxide emissions for the Langley Gulch plant are
estimated at 862 Ib/MWh at minimum load (60 percent) and 804 Ib/MWh at maximum
load (100 percent), ISO conditions. This correlates to approximately 435,000 tons at a
capacity factor of 45 percent and 580,000 tons at a capacity factor of 60 percent.
Idaho Power's historical carbon emissions are published on Idaho Power's
website at: http://ww.idahopower.com/NewsCommunityOurEnvironmentlco2Ten Year.cfm.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE-7
B. The targets and timetables proposed in H.R. 2454, The American Clean
Energy and Security Act of 2009 (Waxman-Markey) are:
3 percent below 2005 levels by 2012
17 percent below 2005 levels by 2020
42 percent below 2005 levels by 2030
83 percent below 2005 levels by 2050
Other recent proposals have included the following targets and timetables:
U.S. CAP proposal
3 percent below to 2 percent above 2005 levels by 2012
14-20 percent below 2005 levels by 2020
42 percent below 2005 levels by 2030
80 percent below 2005 levels by 2050
Boucher-Dingell discussion draft (11 Oth Congress)
6 percent below 2005 levels by 2020
44 percent below 2005 levels 2030
80 percent below 2005 levels by 2050
Obama FY 2010 budget proposal
14 percent below 2005 levels by 2020
83 percent below 2005 levels by 2050
Markey bil (11 Oth Congress)
2005 levels by 2012
20 percent below 2005 levels by 2020
85 percent below 2005 levels by 2050
Waxman (110th Congress)
2009 levels by 2010
1990 levels by 2020 (roughly 20 percent below 2005 levels by
2020)
80 percent below 1990 levels by 2050
If some form of carbon regulation is passed in Congress, Idaho Power
anticipates near term reductions in carbon emissions wil be driven by market
economics. In the Pacific Northwest market, abundant hydropower in the spring months
has typically suppressed market energy prices. In addition, during the spring and fall
months, moderate weather typically results in reduced loads for Northwest utilities,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 8
which translates into lower market prices. Idaho Power anticipates initial reductions in
carbon emissions will take place during these times of the year when market prices fall
below the dispatch cost of coal resources.
Carbon emissions from Langley Gulch wil be approximately 60 percent less than
the carbon emissions from a conventional coal facility. If Idaho Power's coal facilities
are curtailed in the future due to the regulation of carbon emissions, Langley Gulch is a
resource that wil be dispatched ahead of coal facilities as dictated by the cost of
emitting carbon. In addition, Langley Gulch wil provide additional operational flexibility
and operating reserves necessary to integrate renewable resources necessary to
comply with a federal renewable energy standard. The ability to integrate additional
renewable resources will also be a key part of Idaho Power's strategy to reduce future
carbon emissions.
There is stil much uncertainty in what form carbon regulation wil be enacted. If
allowances end up being the tool chosen, whether the allowances are allocated or
auctioned could have a substantial impact on the cost for utilities to reduce carbon
emissions. Technology issues also continue to present much uncertainty. The
availability of carbon capture and sequestration technology wil playa major part in
future carbon reductions. However, until more certainty is available regarding actual
carbon regulations and technology, the analysis of reducing carbon emissions is best
handled in the integrated resource planning (UIRP") process as detailed in the response
below.
C. Idaho Power has been closely following draft federal carbon legislation
throughout the preparation of the 2009 IRP which began in the summer of 2008.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 9
Numerous presentations and updates have been conducted and discussed with the IRP
Advisory CounciL. Idaho Power expects some form of federal carbon regulation to be
passed in the future and accordingly the analyses being done for the 2009 IRP account
for the cost of emitting carbon. Idaho Power first began incorporating a carbon "adder"
or tax in its IRP process in 1993 as a way to account for the cost of carbon emissions
given the uncertainty of what form the cost might actually be implemented.
For the 2009 IRP, an expected case carbon adder of $43/ton is being used. As
part of the risk analysis for the 2009 IRP, a low case of $O/ton (status quo) and a high
case in the range of $75 to $100 will be used. The exact adder for the high case wil be
determined by using the AURORA model to analyze the impact of high carbon adders
at a level where Idaho Power's coal facilities begin to be curtailed due to economics.
Information presented at the IRP Advisory Council meetings can be found in the
presentation slides, and the meeting minutes contain a summary of the discussion and
comments from the meetings. This information is available on Idaho Power's website
at: http://ww.idahopower.com/AboutUs/PlanningForFuture/irp/2009/2009I RPAC Schedule.cfm.
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 15th day of June 2009.
~û~
LISA D. NÕST OM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE -10
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th 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 Attorney General
Idaho Public Utilities 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 2th Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
Snake River Allance
Ken Miler
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
-2 Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email Scott.Woodbury~puc.idaho.gov
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email peter~richardsonandoleary.com
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email dreading~mindspring.com
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email kmiler~snakeriverallance.org
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email elo~racinelaw.net
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 11
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Hand Delivered
-L U.S. Mail
_ Overnight Mail
FAX
-L Email tony~yankel.net
Idaho Conservation League
Betsy Bridge
Idaho Conservation League
71 0 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
Hand Delivered
-L U.S. Mail
_ Overnight Mail
FAX
-L Email bbridge~wildidaho.org
Northwest and Intermountain
Power Producers Coalition
Susan K. Ackerman
9883 NW Nottage Drive
Portland, Oregon 97229
Hand Delivered
-L U.S. Mail
_ Overnight Mail
FAX
-L Email Susan.k.ackerman~comcast.net
Community Action Partnership
Association Of Idaho
Brad M. Purdy
Attorney at Law
2019 North 1th Street
Boise, Idaho 83702
Hand Delivered
-L U.S. Mail
_ Overnight Mail
FAX
-L Email bmpurdy~hotmail.com
4¡Q~khLisa D. Nordstrom
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 12