20110621Staff 1-11 to IPC.pdf

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KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEIVED
20 t1 JUN 2 I PM 2: '6
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 FORA ) CASE NO. IPC-E-ll-I0
DETERMINATION REGARDING THE FIRM )
ENERGY SALES AGREEMENT FOR THE ) FIRST PRODUCTION
SALE AND PURCHASE OF ELECTRIC ) REQUEST OF THE
ENERGY BETWEEN IDAHO POWER ) COMMISSION STAFF TO
COMPANY AND INTERCONNECT SOLAR ) IDAHO POWER COMPANYDEVELOPMENT LLC. )
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company)
provide the following documents and information on or before TUESDAY, JULY 12, 2011.
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 wil augment the documents produced.
Please provide answers to each question and any supporting workpapers that provide detail or
are the source of information used in calculations. The Company is reminded that responses pursuant
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 IDAP A 31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JUE 21, 2011
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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 working copies of all input and output fies used to derive
the Aurora prices upon which the rates in the Firm Energy Sales Agreement (FESA) are based.
REQUEST NO.2: Please identify, quantify and explain the justification for all differences
between the Aurora price results from Idaho Power's analysis and the purchase prices contained in
the FESA. What factors, if any, were considered in adjusting the Aurora prices? Please explain the
rationale for all adjustments.
REQUEST NO.3: Please provide a copy of all spreadsheets and analysis used to adjust the
Aurora prices to the prices contained in the FESA. Please clearly show how Idaho Power derived the
Heavy Load Peak energy pricing for the months of July and August.
REQUEST NO.4: Do the prices contained in the FE SA include a specific component
intended to reflect the capacity value of the solar resource? If so, how big is the capacity component
and how was it derived? Does Idaho Power believe that the Facility wil provide reliable capacity
during the Company's peak summer load hours?
REQUEST NO.5: Does Idaho Power believe that it wil incur integration costs for this
facilty due to the intermittent nature of its generation? If so, has the Company attempted to quantify
those integration costs? Does Idaho Power have any plans to attempt to quantify solar integration
costs in the future?
REQUEST NO.6: Is Idaho Power currently negotiating contracts with any other solar
facilties? If so, please state the number of potential contracts and the size of each facility.
REQUEST NO.7: It is clear from the Application and the letter from Idaho Power to
Interconnect Solar that is attached to the Application that Idaho Power expects that the
interconnection and transmission process canot be completed in less than 18 months, yet the parties
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUE 21, 2011
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have agreed to a Scheduled Operation Date that is approximately only 12 months from now. Please
explain any plausible scenarios under which Interconnect Solar will not either incur delay damages or
face termination of the Agreement for failng to meet its Scheduled Operation Date.
REQUEST NO.8: Interconnect Solar and Idaho Power have agreed to terms providing for
each pary's 50 percent ownership of any Environmental Attributes, including RECs, generated by
the Facility for the full 25-year term of the FESA. Please explain why Idaho Power believes it is
entitled to 50 percent specifically of the Environmental Attributes (rather than 0 or 100 percent).
Does Idaho Power intend to seek ownership of 50 percent of Environmental Attributes in future
PURP A contracts?
REQUEST NO.9: In Section 8 ofIdaho Power's Application, on page 9, the Application
states, "Should the Facilty fail to deliver the peak load energy that its IRP-based avoided cost pricing
is based upon, it wil automatically receive the lower Heavy Load Standard price." Please identify
the specific section in the FESA where this is addressed.
REQUEST NO. 10: Section 1.34.1 of the FESA appears to define Surlus Energy using a
"701130" requirement during the first contract year rather than a "90/110" requirement typical of
other non-wind PURP A contracts. Please explain why a "70/130" definition is being used in the first
contract year of this Agreement.
REQUEST NO. 11: Section 5.2 of the FE SA defines the term "Operation Date," and
Sections 5.3-5.5 contain terms related to the imposition of liquidated damages for failure to meet the
Scheduled Operation Date. For puroses of enforcing these contract terms, what constitutes
"operation" for a facility comprised on 74,075 individual generators? Do all of the generators have to
be functioning on the Scheduled Operation Date or just some specified fraction of them?
Alternatively, is there some fraction of the Facilty's generating capacity that must be met for the
project to be deemed operational? How would Delay Liquidated Damages be assessed if only a
portion of the generators are not operational on or before the Scheduled Operation Date?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JUNE 21, 2011
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/. /!TDated at Boise, Idaho, this ~ day of June 2011.
~d'~"Ju.Kiser -
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/ipce i i. i Oksrps prod req i
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JUE 21, 2011
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF JUE 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-ll-lO, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOV AN E WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalker(ßidahopower.com
RANDY C ALLPHIN
ENERGY CONTRACT ADMIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphin(ßidahopower.com
RANDY HEMMER MGR
INTERCONNECT SOLAR
DEVELOPMENT LLC
3777 TWILIGHT DR
BOISE ID 83703
E-MAIL: randyhemmer(ßclearire.net
~\tJ&~.~
SECRETARY
CERTIFICATE OF SERVICE