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Home My WebLink About20130415IPC to Staff 1.pdf-,0 • -kA 1 r-rfv An IDACORP Company JULIA A. HILTON Corporate Counsel jhiIton(didahopower.com 2e13045 Pt42 51 Li i ' April 15, 2013 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-13-07 Clark Canyon Hydro, LLC - Idaho Power Company's Response to the First Production Request of the Commission Staff Dear Ms. Jewell: Enclosed for filing in the above matter are an original and three (3) copies of Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power Company. Also enclosed are four (4) copies of a disk containing information responsive to Staffs production request. Very truly yours, Julia A. Hilton JAH:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, ID 83707 DONOVAN E. WALKER (ISB No. 5921) JULIA A. HILTON (ISB No. 7740) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwaIker(äidahoDower.com ihiIton(idahoDower.com X3 APR 15 PM 2:51 mi.' - U ILL Ei (MMISS10N Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE AMENDMENT TO THE FIRM ENERGY SALES AGREEMENT BETWEEN IDAHO POWER COMPANY AND CLARK CANYON HYDRO, LLC. CASE NO. IPC-E-13-07 IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Commission Staff to Idaho Power Company dated April 2, 2013, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -1 REQUEST NO. 1: On page 3 of the Company's Application, it states: The Amendment is a fair and equitable resolution to this matter, and is in the public interest. The avoided cost rates contained in Clark Canyon's FESA are substantially similar to the avoided cost rates the project would receive in a new contract today. In addition, Idaho Power and its customers receive half of the Renewable Energy Credits associated with the project with the current FESA. a.Please provide analysis supporting the statement that the avoided cost rates contained in Clark Canyon's FESA are substantially similar to the avoided cost rates the project would receive in a new contract today. Please quantify the net present value difference between the rates in 2013 dollars. b.Please estimate in 2013 dollars the net present value of the Renewable Energy Credits Idaho Power will receive over the life of the amended FESA. RESPONSE TO REQUEST NO. 1: a. The Excel file provided on the enclosed CD contains a summary worksheet ("Summary" tab) comparing avoided costs prices contained within the existing Clark Canyon Hydro, LLC, Qualifying Facility ("QF") contract (labeled "NPV of Current Contract") and the Canal Drop Avoided Cost prices established in Idaho Public Utilities Commission ("Commission") Order No. 32697 (labeled "NPV for Hypothetical Contract"). Additional calculation worksheets are included within the provided Excel file. In preparing this analysis, Idaho Power used the Canal Drop Avoided Costs established in Commission Order No. 32697 because they were the approved published avoided costs at the time this analysis was done and because the project identifies itself as a Canal Drop project and met the definition provided in Commission Order No. 32697. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -2 In summary, the Net Present Value ("NPV") of the estimated energy payments within the current contract is $16,386,424. However, the amendment provides that the project must pay $211,500 in liquidated damages; deducting this amount estimated NPV results in an adjusted NPV value of the current contract payments of $16,174,924. The NPV of the estimated energy payments for this project using the Canal Drop Avoided Costs as specified in Commission Order No. 62697 is equal to $16,012,007. b. Idaho Power does not specifically forecast or estimate the future value of Renewable Energy Credits ("RECs"). However, under the current agreement, Idaho Power receives half of the RECs from this project, whereas, in accordance with Commission Order No. 32697, Idaho Power would not receive any of the RECs associated with this project under a new QF contract. The response to this Request was prepared by Randy C. Allphin, Energy Contract Coordinator Leader, Idaho Power Company, in consultation with Julia A. Hilton, Corporate Counsel, Idaho Power Company. DATED at Boise, Idaho, this 15th day of April 2013. JUL A. HI Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -3 CERTIFICATE OF MAILING I HEREBY CERTIFY that on the 15 th day of April 2013 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Kristine A. Sasser Deputy Attorney General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Clark Canyon Hydro, LLC Kim L. Johnson Executive Vice President, Business Development Clark Canyon Hydro, LLC do Symbiotics, LLC 2000 South Ocean Boulevard #703 DeIRay Beach, Florida 33438 Peter Clermont, Director Aquila Infrastructure Management Inc. Hand Delivered U.S. Mail Overnight Mail FAX X Email kris.sassercpuc.idaho.qov Hand Delivered U.S. Mail Overnight Mail FAX X Email kim.iohnsonriverbankpower.com Hand Delivered U.S. Mail Overnight Mail FAX X Email pclermont(theapuilaqroup.com Christa Bearry, Legal Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -4