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 EIGHTMILE ITYDRO
CORPORATION FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY FROM
THE EIGHTMILE HYDRO PROJECT.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E,-14-I2
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 Attomey 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 31.0I.01.228.
In 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 I JLINE I8,2OI4
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. 29532
However, in this Energy Sales Agreement Idaho Power proposes to 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
Notification Month Future Monthlv Net Enersy Amounts Elieible to Be Revised
November January and any future months
December Februarv and anv future months
January March and anv future months
February April and any future months
March May and any future months
Aoril June and anv future months
May Julv and anv future months
June Ausust and anv future months
Julv September and any future months
Ausust October and anv future months
Sentember November and anv future months
October December and any future months
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Month I 2 J 4 5 6 7 8 9 l0 II t2 2 .,4 5 6 7 8 9
I " opportunity at the end of month
3 allows revision for July, Aug,
and Sep
2"o opportunity at the end of month
6 allows revision for Oct, Nov, and
Dec
3"" opportunity at the end of month
9 allows revision for Jan, Feb, and
March
JUNE 18,2014
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 confirm whether StafPs 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 identify the pros and cons of the new method with regard to each
pafiy, compared to the current method specified in Order No. 29632.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Month I 2 3 4 5 6 7 8 9 l0 ll t2 2 J 4 5 6 7 8 9
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
JLINE 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, this l#Ourof June 2014.
Technical Staff: Yao Yin
i:umisc:prodreq/ipce 14. l2ksyy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Deputy Attorney General
JUNE 18,2OI4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18S DAY OF JUNE 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-14-12,
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]
dockets@ idahopower. com
RANDY C. ALLPHIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE