20140618Staff 1-7 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03s7
BAR NO. 6618
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OR REJECTION OF AN ENERGY SALES
AGREEMENT WITH WILLIAM ARKOOSH
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE LITTLE
WOOD RIVER RANCH II PROJECT.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E.I4-06
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,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company)
provide the following documents and information on or before WEDNESDAY, JULY 9,2014.
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.
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. Reference IDAPA 31.01.0L228.
ln addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST .
TO IDAHO POWER COMPANY 1 JUNE 18,2OI4
In PURPA contracts, QFs are required to provide utilities with monthly kWh production
estimates, and the estimated amount is the QF's generation delivery commitment. According to
Order No. 29632, QF opportunities for estimate revisions begin at the end of month three and every
three months thereafter for the forward period beginning the fourth month out through the end of the
estimate period (see Table 1).
Table 1 Opportunities to Make an Estimate Revision according to Order No. 29632
However, in this Energy Sales Agreement Idaho Power proposes a new timeframe for making
revisions. Paragraph 6.2.3 of the Agreement states that after the Operation Date the Seller may revise
any future monthly Net Energy Amounts by providing written notice no later than 5 PM Mountain
Standard time on the last business day of the Notification Month (see Table 2).
Table 2 Method to Make Estimate Revisions Proposed by ldaho Power and its QFs
Notilication Month Future Monthlv Net Energv Amounts Elieible to Be Revised
November January and any future months
December Februarv and anv future months
Januarv March and any future months
Februan Aoril and anv future months
March Mav and anv future months
Aoril June and any future months
May July and any future months
June Aueust and anv future months
July Seotember and anv future months
Ausust October and anv future months
September November and anv future months
October December and any future months
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Month 2 -t 4 5 6 7 8 9 l0 ll t2 I 2 3 4 5 6 7 8 9
I't opportunity at the end of month
3 allows revision for July, Aug,
and Sen
2"" opportunity at the end of month
6 allows revision for Oct, Nov, and
Dec
3no opportunity at the end of month
9 allows revision for Jan, Feb, and
March
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JLINE 18,20t4
In order to compare the two methods effectively, Staff created Table 3 to visually illustrate
what it believes is Idaho Power's proposal.
Table 3 Opportunities to Make an Estimate Revision Proposed by ldaho Power and its QFs
REQUEST NO. 1: Please conf,rrm whether Staff s graphical depiction of paragraph 6.2.3 as
shown in Table 3 above accurately represents the terms of the proposed Agreement. If Staff s
depiction is not accurate, please explain why.
REQUEST NO. 2: On page 6 of the Amended Application, Idaho Power states "However,
with the proposed change, the Seller must still provide 12 months of estimated Net Energy Amounts,
and still cannot revise the immediate three months of estimated Net Energy Amounts." Please
reconcile this statement with paragraph 6.2.3 of the Agreement.
REQUEST NO.3: The Amended Application states that under the new method "the Seller
gains more clarity and flexibility in adjusting its estimated energy deliveries, and Idaho Power
maintains the stability in the estimates necessary for its planning and operation". Please describe
what kind of "clarity" the new method allows the Seller to gain. Please list the implications, if any,
of the new method to Idaho Power's planning and operation processes, and explain why the
implications would not affect Idaho Power's "stability" in the estimates.
REQUEST NO. 4: Please identifu the pros and cons of the new method with regard to each
party, compared to the current method specif,red in Order No. 29632.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Month I 2 J 4 5 6 7 8 9 l0 ll t2 2 J 4 5 6 7 8 I
Notification made in Nov allows
revision for Jan and any future
months
Notification made in Dec allows
revision for Feb and any future
months
Notification made in Jan allows
revision for March and any future
months
JUNE I8,2OI4
REQUEST NO.5: Please explain why Idaho Power believes the Commission should allow
use of its proposed method, instead of utilizing the existing framework as outlined in Order No.
29632.
REQUEST NO. 6: Order No. 29632 was born out of cases IPC-E-04-08 and IPC-E-04-10 in
2004. Back then, Idaho Power proposed to allow QFs to revise their energy estimates three times
during the first year of operation and every two years thereafter. Idaho Power reasoned that a two-
year interval allows the Company to more easily integrate the QF resource into its biennial IRP
planning process. Please discuss whether this is still the Company's position and how Idaho Power's
proposal in this case aligns with the Company's previously stated position.
REQUEST NO. 7: Please state whether Idaho Power intends to utilize its proposed
estimation method for all new hydro QF projects.
Dated at Boise, Idaho, tms l(1C day of June 2014.
Technical Staff: Yao Yin
i:umisc:prodreq/ipcel4.6ksyy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4
ifiine A. Sasser
Deputy Attorney General
JUNE I8,2OT4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18th DAY OF JUNE 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OT' THE
CoMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.IPC-E-I4-06,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E. WALKER
IDAHO POWER COMPANY
P.O. BOX 70
BOISE,ID 83707
E-MAIL: [e-mail]
[e-mail]
RANDY C. ALLPHIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE