20140729RNP&AWEA Second Data Request to IPC.pdf

Teresa A. Hill
ISB No.6l75
K&L Gates LLP
One Columbia St. Suite 1900
Portland, OR 97258
Telephone: [phone]
Fax: [phone]
Attorneyfor Renewable Northwest and American Wind Energt Association
BEI.'ORE TTIE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICAI'ION OF' IDAHO POWER
COMPANY TO UPDATE ITS WIND
INTEGRATION RATES AND CHARGES.
Case No. IPC-E-13-22
Renewable Northwest and American Wind Energy
Association's Second Data Request to Idaho Power
Company
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20ll' JUL 29 pH !: I I
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I . On an hourly basis, is Idaho Power generally surplus on energy? If so, does PURPA wind cause the
Company to remarket the surplus energy? Does this remarketing of surplus energy generally occur in
the day-ahead market? How often is Idaho Power surplus on energy? (Reply Comments of ldaho
Power Company at I l.)
2. Please list the factors that go into the Company's avoided cost calculation under the IRP methodology.
(Reply Comments of Idaho Power Company at I L)
3. In determining the avoided cost for each PURPA contract under the IRP methodology, is it accurate to
say that the Company runs through a production cost simulation to determine the value, or avoided
cost, of the PURPA energy for every hour of the contract? If so, how does the simulation account for
the PURPA energy if the system was surplus on energy in a given hour? How would that
circumstance impact the value, or avoided cost, of the PURPA energy? If it does not account for this
energy surplus, please explain why. (Reply Comments of tdaho Power Company at I l.)
4. If PURPA energy causes ldaho Power to remarket energy and that remarketing incurs transactional or
operational costs, would those costs reduce the economic value that the PURPA energy provides to
the system? (Reply Comments of Idaho Power Company at 11.)
5. Does Idaho Power's 2013 Wind Integration Study account for the operational and cost differences
between using spinning and non-spinning reserves in the provision of integration services? What are
the cost differences associatedrvith using spinning reserves and non-spinning reserves? (Reply
Comments of Idaho Power Company at I 1.)
6. How does ldaho Power propose to apply its 2013 Wind Integration Study methodology and the
integration costs estimated therein (as defined by the Study) to (i) a situation in which the Company is
in an energy deficit and is comparing the costs of wind to other options available to serve the utility's
energy needs (i.e., in the integrated resource planning process); and (ii) an Open Access Transmission
Tariff rate schedule for generator imbalance-type service for third-party wind that Idaho Power's
transmission business is exporting out of its Balancing Authority Area on an hourly schedule? Does
the Company see any differences in applying its Study methodology and costs to these situations as it
does to must-lake PURPA energy when the utility is in an energy surplus? Please explain. (Reply
Renewable Northwest and American Wind Energy Association's Second Data Request to 1
Idaho Power Company
Comments of ldaho Power Company at I l.)
'l . Please explain the Company's technical justification for the decision in the 201 3 Wind Integration
Study to not net reserves for load and reseryes for generation (including wind). (Reply Comments of
Idaho Power Company at ll-12.)
DATED this 29th day of July,2014
K&L Gates LLP
Attorney for Renewable Northwest and AWEA
Renewable Northwest and American Wind Energy Association's Second Data Request to
ldatro Power Company
CERTIFICATE OF SERVICE
I hereby certiff that on the 29th day of July, 2014, a true and correct copy ofthe foregoing
RENEWABLE NORTHWEST PROJECT AND AMERICAN WIND ENERGY ASSOCI-ATION'S FIRST
DATA REQUEST TO IDAHO POWER COMPANY, Case No. IPC-E-13-22, was served by electronic mail
to:
IDAHO POWER COMPANY: Donovan E. Walker
Idaho Power Company
l22l W. Idaho St. (83'102)
P.O. Box 70
Boise, ID 83707-0070
Email: [e-mail]
dockets@id ahopower,com
Michael J. Youngblood
Greg Said
Idaho Power Company
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707-0070
Email: [e-mail]
[e-mail]
COMMISSION STAFF: Kris Sasser
Deputy Attomey General
Idaho Public Utilities Commission
47 2 W. Washington (837 02)
P.O. Box 83720
Boise,ID $72A-0074
Email: [e-mail]
IDAHO WINDS LLC: Dean J. Miller
McDevitt & Miller LLP
420W. Bannock Street
Boise, ID 83702
Email: [e-mail]
Rick Koebbe, President
Idaho Winds, LLC
5420 W. Wicher Road
Glenns Ferry, ID 83623
Email: [e-mail]
Bob Eggers, Legal Counsel
Idaho Winds, LLC
Email: re@f'owerworks.com
COLD SPRINGS WINDf,'ARM, LLC; DESERT Peter J. Richardson
MEADOW WINDFARM, LLC; HAMMETT Richardson Adams, PLLC
HILL WINDFARIYI, LLC; MAINLINE 515 N. 27th Street
WINDFARL,LLC; RYEGRASS WINDFARM, Boise, ID 83702
LLC; AND TWO PONDS WINDFARM, LLC: Email: [e-mail]
Renewable Northwest and American Wind Energy Association's Second Data Request to 3
Idaho Power Company
CASSIA WINDF'ARM LLC;
HOT SPRINGS WINDTARM LLC; BENNETT
CREEKWINDFARM LLC; CASSIA GULCH
WIND PARK LLC; TUANA SPRINGS
ENERGY, LLC; AND HIGH MESA ENERGY,
LLC:
Benjamin G. Huang, Manager
c/o Mountain Air Projects
6000 N. Foxtail Way
Glenns Ferry, ID 83623
Gregory M. Adams
RichardsonAdams, PLLC
515 N. 27th Street
Boise,ID 83702
Email: [e-mail]
Paul Ackerman
Assistant General Counsel
Exelon Business Services Corporation
100 Constellation Way
Baltimore, MD21202
DATED this 29th day of July, 2014.
Renewable Northwest and American Wind Energy Association's Second Data Request to
Idaho Power Company
K&L GATES LLP