20100114Staff 1-20 to IPC.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL )
OF AN AGREEMENT TO PURCHASE )
CAPACITY AND ENERGY FROM USG )
OREGON LLC AND AUTHORIZE RECOVERY )
IN THE COMPANY'S POWER COST )ADJUSTMENT. )
)
CASE NO. IPC-E-09-34
FIRST 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,
Weldon B. Stutzman, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
THURSDAY, FEBRUARY 4, 2010.
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 of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer åt hearing.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JANUARY 14,2010
REQUEST NO.1: Please provide a copy of all bids received by Idaho Power in the
2006 and 2008 geothermal Requests for Proposals (RFPs).
REQUEST NO.2: Please provide a copy of all supplemental information submitted by
bidders in either the 2006 or 2008 geothermal RFPs that was not par of the bidders' original
bids. For U.S. Geothermal, please provide a copy of all revisions to its original bid, including
revised price offers.
REQUEST NO.3: Please provide a copy of all geothermal proposals submitted to
Idaho Power outside of the 2006 and 2008 RFP processes.
REQUEST NO.4: On page 3 of its Application, Idaho Power states "However after
further review of escalating construction costs, U.S. Geothermal concluded that its fixed-price
bid was not viable and withdrew its offer to sell power from the Neal Hot Springs site as
submitted." Please provide all information submitted by U.S. Geothermal relating to the
withdrawal of its Neal Hot Springs offer.
REQUEST NO.5: On page 3 of its Application, Idaho Power states "U.S. Geothermal
included additional geothermal projects in its successful 2006 bid, including additional
generation at Raft River and a new project at Neal Hot Springs." Please explain the status of the
"additional generation at Raft River." Has U.S. Geothermal also withdrawn its offer from its
2006 RFP bid to sell additional generation at Raft River? If so, please provide documentation of
the withdrawal of the offer. If U.S. Geothermal's offer has not been withdrawn, please discuss
,
the status of any contract negotiations for Idaho Power to purchase additional generation from
Raft River.
REQUEST NO.6: Please provide a copy of any information provided by Idaho Power
to U.S. Geothermal notifying U.S. Geothermal that it was selected as the successful bidder in the
2006 geothermal RFP.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 JANUARY 14,2010
REQUEST NO.7: Please provide a copy of all analysis completed by Idaho Power (or
any experts or consultants hired by the Company) of bids from either the 2006 or 2008 RFPs and
for any other proposals received outside of the RFP process. For any spreadsheets used in the
analysis, please provide copies with formulas intact.
REQUEST NO.8: On page 3 of its Application, Idaho Power states "This 2008 RFP
received three responses, two of which were shortly withdrawn by the bidders prior to Idaho
Power fully evaluating the bids." Please provide documentation demonstrating that two bids
were withdrawn.
REQUEST NO.9: On page 3 of its Application, in discussing the 2008 RFP bids, Idaho
Power states "Idaho Power concluded that the third bid was too speculative and therefore
unacceptable." Please provide documentation of any analysis, reports or other information
prepared or obtained by Idaho Power or other experts confirming the speculative and
unacceptable nature of the proposal.
REQUEST NO. 10: Does Idaho Power believe that bids submitted in an RFP represent
binding commitments on behalf of the bidders? If not, please discuss the circumstances under
which bids may be withdrawn or modified.
REQUEST NO. 11: Please provide a copy of any analysis completed by Idaho Power or
others intended to quantify the value of Environmental Attributes and Renewable Energy Credits
that wil be received from the project. Please provide a copy of any broker quotes or forecasts of
Renewable Energy Credits (RECs) value used in the analysis, or where no outside information
was used, provide information showing REC values assumed by Idaho Power.
REQUEST NO. 12: Has Idaho Power attempted to sell any RECs that may be produced
by the Neal Hot Springs project? If so, provide a copy of any sales agreements consummated or
offers received. If not, when does Idaho Power expect to begin trying to sell the RECs?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 JANUARY 14,2010
REQUEST NO. 13: The proposed Agreement allows Idaho Power to curtail energy
deliveries in an amount up to 1,620 MWh per contract year. If the expected capacity of the
project is 22 MW, the curailment could occur approximately 73.6 hours per year. Given that the
amount of possible curtailment is so small, are there reasons other than economic dispatch for
including curailment terms in the Agreement? Please explain.
REQUEST NO. 14: The energy prices in the Agreement are seasonally adjusted similar
to the seasonal adjustments applied to PURP A contracts. However, the seasonal adjustment
factors are slightly different (0.733, 1.0, and 1.2 in the Agreement vs. 0.735, 1.0 and 1.2 for
PURPA contracts). Is this difference intentional? Please explain.
REQUEST NO. 15: Assume hypothetically that the Neal Hot Springs project was
proposed as a greater than 10 aMW PURP A project. Please perform analysis using Aurora to
compute the annual value of power that is expected to be received from the Neal Hot Springs
project. In other words, compute the difference in the 25-year power supply costs of two Idaho
Power portfolios -- one without the Neal Hot Springs project and one with the Neal Hot Springs
project included as a no-cost resource.
REQUEST NO. 16: Please provide a copy of the signed Large Generator
Interconnection Agreement for the Neal Hot Springs project as discussed on page 7 of the
Company's Application.
REQUEST NO. 17: Please compare on an anual basis the net cash flow streams
between power expected to be purchased from the Neal Hot Springs project and the estimated
cost of power to be produced by the Langley Gulch project using current estimates for the price
offuel. Please compare the levelized net present value of both projects using reasonable
assumptions to account for differing project lives.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 JANUARY 14,2010
REQUEST NO. 18: On page 5 of the Application, Idaho Power states that the estimated
online date for the project is late 2012 and that the Agreement requires an online date no later
than 2016. However, i¡i.55 of the Agreement states that the Scheduled First Energy Date shall
be 30 months from receipt of notice to proceed, which in turn must be no later than 12/31/2014.
In addition, i¡1.57 states that the Scheduled Operation Date shall be 6 months after the First
Energy Date. By Staffs calculation, according to the Agreement, the actual First Energy Date
could be as late as 12/31/2017. Which is correct, the required online date stated in the
Application or the required online date computed by Staff?
REQUEST NO. 19: The rates shown in Appendix A to the Agreement extend for 25
years from Jan. 2012 - Dec 2036. If the project comes online later than 2012, does the contract
stil expire in 2036 even though energy deliveries would be for a term of less than 25 years?
REQUEST NO. 20: i¡26.5.2 allows the Seller to terminate the agreement without
penalty if the Seller can demonstrate its inabilty to negotiate an EPC contract due to "unforeseen
Facility financing or construction costs." How much higher than expected can financing or
construction costs be before U.S. Geothermal would be allowed to terminate the Agreement?
DATED at Boise, Idaho, this ll.~ay of January 2010.
r-~
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/ipce09.34wsrps prod reql
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 5 JANUARY 14,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF JANUARY 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-09-34,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
DONOV AN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bklinecmidahopower.com
dwalker(iidahopower .com
RANDY C ALLPHIN
CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphin(iidahopower.com
CERTIFICATE OF SERVICE