20100930Staff 1-10 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION'
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
RECEiVED
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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 A FIRM ENERGY SALES AGREEMENT )
FOR THE SALE AND PURCHASE OF )
ELECTRIC ENERGY BETWEEN IDAHO )
POWER COMPANY AND ROCKLAND WIND )PROJECT LLC. )
)
)
CASE NO. IPC-E-I0-24
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbur, Deputy Attorney General, requests that Idaho Power Company (Idaho Power;
Company) provide the following documents and information as soon as possible, but no later
than THURSDAY, OCTOBER 21,2010.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that wil 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 at hearing.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Idaho Power is reminded that responses pursuant
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 SEPTEMBER 30, 2010
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Please provide a copy of the following interconnection and
transmission documents when available:
a. Feasibilty study
b. Facilty Study
c. Generation Interconnection Agreement
d. Transmission Service Request and the corresponding response from Idaho
Power's Transmission group that transmission capacity is available.
REQUEST NO.2: Please provide a copy of the Aurora project and output fies
supporting the levelized Aurora energy price result of $56.21 per MWh as referred to on page 6
of the Application. Please provide computations showing how the price of $56.21 was computed
using the Aurora results.
REQUEST NO.3: The Application states that the 25-year levelized price in the
Agreement calculates to be $71.29 per MWh. Please explain in detail how the Company got
from a 25-year levelized Aurora price of $56.21 per MWh to a negotiated 25-year levelized rate
of $71.29 per MWh. Please identify and quantify each additional benefit that Idaho Power
believes is not captured in the Aurora price.
REQUEST NO.4: The Agreement provides that all Renewable Energy Credits (RECs)
wil be provided to Idaho Power after year 2021. Has Idaho Power attempted to quantify the
value of these RECs? If so, please state the estimated value and show how it was derived.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 SEPTEMBER 30, 2010
REQUEST NO.5: The contract term specified in the Agreement is 25 years. Does
Idaho Power have any evidence that the project will be able to perform for the full 25 years?
Can Idaho Power cite other contracts in the U.S. with a term of25 years for projects utilzing
similar wind turbines as are proposed to be used for the Rockland project?
REQUEST NO.6: Many of the terms of the Agreement are different than in standard
PURP A contracts for projects smaller than 10 aMW (parial completion damages, simplified
MAG, IPCo ownership ofRECs, increased security, more forecasting). How do these unique
terms and conditions compare to the terms and conditions that were being negotiated with a
different project in the Company's 2012 Wind RFP wherein no contract was awarded?
REQUEST NO.7: Please explain the rationale for the Signing Security ($300,000) and
Operational Security ($1,500,000) required under the Agreement. What damages is each type of
security intended to recompense?
REQUEST NO.8: Please provide computations showing how the negotiated prices in
the Agreement equate to a levelized rate of$71.29 per MWh.
REQUEST NO.9: Please compare the rates in the Rockland contract to the prices that
were bid in Idaho Power's 2012 Wind RFP wherein no contract was awarded. Please list the
total energy price by year for each of the bids received in the 2012 Wind RFP.
REQUEST NO. 10: Appendix E ofthe Agreement states that Idaho Power will make
use of a Wind Energy Production Forecasting model to forecast the energy production from the
Rockland facilty and other wind QF resources. Has Idaho Power acquired or developed such a
model? If so, is Idaho Power currently using the model? What is the estimated cost to Idaho
Power of using and maintaining such a model?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 SEPTEMBER 30, 2010
DATED at Boise, Idao, this :;'fdaY of September 2010.
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/ipcelO.24swrps prl
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 SEPTEMBER 30, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30TH DAY OF SEPTEMBER 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER, IN CASE NO. IPC-E-I0-24, BY MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOV AN E WALKER
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalker(iidahopower.com
lnordstromCiidahopower.com
RANDY C ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphinCiidahopower.com
DENNIS MEANY PRESIDENT
ROCKLAND WIND PROJECT
1300 N NORTHLAKE WAY
2ND FLOOR
SEATTLE W A 98103
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SECRETARY
CERTIFICATE OF SERVICE