20170731IPC to Clark Canyon 1-5.pdf

-" -,-.i"-ttI-l\
:ili; "Jiil- 3 | Pil lrr t+2
3Iffi*@
An IDACORP CompanY
DONOVAN E. WALKER
Lead Counsel
dwal [e-mail]
July 31 ,2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
47 2 W est Wash i ngton Street
Boise, ldaho 83702
Re Case No. IPC-E-14-15
Clark Canyon Hydro, LLC - ldaho Power Company's Response to Clark
Canyon Hydro, LLC's First Set of Production Requests
Dear Ms. Hanian:
Enclosed for filing in the above matter please find an origina! and three (3) copies
of ldaho Power Company's Response to Clark Canyon Hydro, LLC's First Set of
Production Requests.
ln addition, enclosed are four (4) copies each of non-confidentia! and
confidential disks containing information responsive to Clark Canyon Hydro, LLC's
production requests. Please handle the confidentia! information in accordance with the
Protective Agreement executed in this matter.
Very truly yours,
Donovan E. Walker
DEW:csb
Enclosures
'1221 W. ldaho 5t. (83702)
PO. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa I ke r@ id a hopqluercqn
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
APPROVE OR REJECT ENERGY SALES
AGREEMENT W]TH CLARK CANYON
HYDRO, LLC FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY
FROM THE CLARK CANYON PROJECT
Pl{ L: ['2
CASE NO. IPC-E-14-15
IDAHO POWER COMPANY'S
RESPONSE TO CLARK CANYON
HYDRO, LLC'S FIRST SET OF
PRODUCTION REQUESTS
"'I f:i A !l"l't.-JiJ. t^l
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to Clark Canyon Hydro, LLC's First Set of Production Requests to ldaho
Power Company dated July 10,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 1
REQUEST NO. 1: Please provide all materials provided to any party in response
to any requests for production, interrogatories or other forms of discovery, formal or
informal, in this case (IPC-E-14-15), as well as in IPC-E-13-07, and IPC-E-11-09.
RESPONSE TO REQUEST NO. 1: Please see the enclosed non-confidential
disk for copies of ldaho Power Company's Response to the First Production Request of
the Commission Staff to ldaho Power Company in Case No. !PC-E-11-09 and ldaho
Power Company's Response to the First Production Request of the Commission Staff to
ldaho Power Company in Case No. IPC-E-13-07. No discovery has previously been
conducted in Case No. IPC-E-14-15.
The response to this Request is sponsored by Christa Bearry, Legal
Administrative Assistant, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 2
REQUEST NOI: Please provide the work papers in ldaho Power's possession
supporting any calculations of the rate differential between the present value revenue
requirement of the purchase of Clark Canyon's output under the ESA proposed for
approval in this case with an ESA that would be available under the seasonal rates in
effect at the time of this request. lf not apparent from the work papers, please describe
the basis for the major inputs, including rate assumptions, REC values, output
projections, operation date, etc.
RESPONSE TO REQUEST NO. 2: Please see the Excel file provided on the
enclosed non-confidential disk.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 3
REQUEST NO. 3: For each of ldaho Power's sales of renewable energy
certificates (RECs) over the past 10 years, please provide the sales prices ($/MWh),
quantity of RECs sold in the transaction, year of sale, and whether the sales were of
bundled or unbundled RECs.
RESPONSE TO REQUEST NO. 3: ldaho Power did not start selling RECs until
2010. Therefore, only eight years of data is available. Please see the confidential
spreadsheet provided on the enclosed confidential disk. The confidential disk will only
be provided to those parties that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 4
REQUEST NO. 4: Reference the renewable energy certificate (REC) price
forecast in the 2017 lRP, Appendix C, at p. 107, attached hereto as Exhibit A of these
production requests. Please explain the basis for this REC forecast and provide all
supporting data and documents used to develop the forecast.
RESPONSE TO REQUEST NO. 4: The REC market can be generally divided
into a compliance market, such as to fulfill a state Renewable Portfolio Standard
('RPS'), and a voluntary market, such as private companies wishing to be green in their
energy consumption or utility green power programs for their retail customers. The
state compliance market depends on state legislatures' decisions to expand the RPS
percentages. The voluntary program (needs to have Green-e certification) depends on
how willing companies and retail customers are to purchase RECs.
ln general, for the voluntary market, prices for geothermal, wind, and solar RECs
are priced higher than small hydro RECs. ln the compliance market, buyers will not
favor one technology over a different type of technology. However, the qualification for
the state RPS program could be different for different technologies. !n most cases,
wind, solar, and geothermal are relatively easy to qualify. Hydro and biomass projects
have greater difficulty attaining eligibility from the states.
The 2017 lntegrated Resource Plan ("lRP") REC price forecast was based on
discussions with market participants, especially with REC brokers about prices in the
future for different products and vintages. ln general, the REC market is not liquid.
Prices for the same product and vintage could be quite different when executed within
relatively short periods. ln the 2017 IRP REC price forecast, ldaho Power considered
prices for California Compliance REC Category 3 (tradable RECs), Green-e product
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 5
(voluntary RECs), California Compliance REC Category 2 (bundled RECs), Oregon
Compliance RECs, and Washington Compliance RECs. The final 2017 IRP composite
REC price forecast was calculated from the forecast prices for each product and the
percentages of RECs ldaho Power could sell for each product. Please note that REC
prices forecast for 2035 ($11.32) and 2036 ($11.79) for the 2017 IRP were found by
extrapolation.
The table below shows the price forecasts for each product.
CEC 83 G/e
CEC 82
delivered
outside OR RPS WA RPS
2017 $
2018 $
2019 $
2020 $
2021 $
2022 $
2023 $
2024 $
2025 $
2026 $
2027 $
2028 $
2029 $
2030 $
2031 $
2032 $
2033 $
2034 $
250 $
2s0 $
2.50 $
2.50 $
4.00 $
4.25 $
450 $
4.75 $
500 $
5.25 $
5.50 $
575 $
6.00 $
6.25 $
650 $
675 $
7.00 $
7.25 $
$ 5.00
$ 5.25
$ 5.25
$ 5.75
$ 6.25
$ 6.75
$ 7.25
$ 7.75
$ 8.25
$ 8.75
$ 9.25
$ 9.75
$ 10.25
$ 10.75
$ 1 1.25
$ 1 1.75
$ 12.25
$ 12.75
$ 5.00
$ 5.50
$ 5.75
$ 6.00
$ 6.50
$ 700
$ 7.50
$ 8.00
$ 8.50
$ 9.00
$ 9.50
$ 10 00
$ 10.50
$ 1 1.00
$ 11.50
$ 12.00
$ 12.50
$ 13.00
4.75
5.00
5.00
5.25
5.25
5.51
5.79
6.08
6.38
6.70
7.04
7.39
7.76
8.14
8.55
8.98
9.43
9.90
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 6
1.25 $
1.25 $
1.25 $
1.50 $
1.50 $
1.50 $
1.50 $
1.50 $
1.50 $
1.75 $
1.75 $
1.75 $
1.75 $
1.75 $
1.75 $
2.00 $
2.00 $
2.00 $
The table below shows the weighted REC prices
CEC 83 or G/e
10%
$ 0.19
$ 019
$ 0.19
$ 0.20
$ 0.28
$ 0.29
$ 0.30
$ 0.31
$ 0.33
$ 035
$ 0.36
$ 0.38
$ 0.39
$ 040
$ 0.41
$ 0.44
$ 0.45
$ 0.46
CEC 82
40%
$ 1.90
$ 2.00
$ 2.00
$ 2.10
$ 2.10
$ 2.21
$ 2.32
$ 2.43
$ 25s
$ 268
$ 2.81
$ 2.95
$ 310
$ 326
$ 3.42
$ 359
$ 3.77
$ 3.96
OR RPS
30%
$ 150
$ 158
$ 1.58
$ 1.73
$ 188
$ 203
$ 218
$ 2.33
$ 2.48
$ 2.63
$ 2.78
$ 2.93
$ 3.08
$ 3.23
$ 3.38
$ 3.53
$ 368
$ 3.83
WA RPS
20Yo
$ 100
$ 1.10
$ 1.15
$ 1.20
$ 1.30
$ 1.40
$ 1.50
$ 1.60
$ 1.70
$ 1.80
$ 190
$ 200
$ 2.10
$ 2.20
$ 2.30
$ 2.40
$ 250
$ 2.60
Total
$ 4.s9
$ 4.86
$ 4.91
$ 5.23
$ 5.55
$ 5.92
$ 6.29
$ 6.67
$ 7.05
$ 7.46
$ 7.85
$ 8.25
$ 8.67
$ 9.08
$ 9.51
$ 9.95
$ 10.40
$ 10.85
CEC = California Energy Commission
83 = only RECs are traded. No energy is involved.
G/e = Green-e certified
82 = Energy and RECs bundled together. RECs can be firmed and shaped within a calendar
year and the renewable energy can be used outside California and a substitute energy can be
bundled with the RECs. lmporters must have firm transmission to the loads in California.
OR RPS = Oregon Renewable Portfolio Standards
WA RPS = Washington Renewable Portfolio Standards
The response to this Request is sponsored by Nengjin Liu, Wholesale
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 7
Transaction Leader, ldaho Power Company.
REQUEST NO. 5: Reference ldaho Power's 2013 lRP, Appendix C, at p. 99;
2015 !RP, Appendix C, at p. 132 and 2017 lRP, Appendix C, at p. 112, each listing
Clark Canyon Hydro, LLC as an existing resource.
a. Please confirm that Clark Canyon Hydro, LLC was included as an existing
resource for purposes of calculating ldaho Power's load and resource balance in ldaho
Power's 2013,2015, and 2017 lRPs. For purposes of this request, "load and resource
balance" has the same meaning as used in IPUC Order No., 32697 al p. 16, in the
sentence that states: "We further find it appropriate to identify each utility's capacity
deficiency based on load and resource balances found in each utility's lRP.'
b. Please provide the work papers from the referenced lRPs calculating the
capacity deficiency date and identifying the capacity contributions of each existing
resource. !f the work papers do not demonstrate ldaho Power's response in subpart a.,
please explain the basis for ldaho Power's response.
RESPONSE TO REQUEST NO. 5:
a. As noted above, Clark Canyon Hydro, LLC ("Clark Canyon") was included
on the list of Qualifying Facility Data (PURPA) with all other Qualifying Facility ("QF')
projects that had signed Energy Sales Agreements ("ESA") with ldaho Power as of June
17, 2013, on page 99 of ldaho Power's 2013 lRP, Appendix C - Technical Report.
Estimated generation provided by the Clark Canyon project from the 2011 ESA was
included in the Cogeneration and Small Power Production ('CSPP') (PURPA) forecast
that was used in ldaho Power's Load and Resource Balance Data beginning on page
31 of the Company's 20131RP, Appendix C - Technical Report.
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 8
ln the Company's 2015 lRP, Clark Canyon was again included on the list of
Qualifying Facility Data (PURPA) with all other QF projects that had signed ESAs with
ldaho Power as of May 26,2015, on page 132 of ldaho Power's 2015 lRP, Appendix C
- Technical Report. However, no generation from Clark Canyon was included in the
CSPP (PURPA) forecast used in ldaho Power's Load and Resource Balance Data
beginning on page 29 of the Company's 2015 lRP, Appendix C - Technical Report.
Therefore, the Clark Canyon project did not contribute to the capacity sufficiency period
identified in the 20151RP.
Similar to the 20151RP, Clark Canyon is included on the list of Qualifying Facility
Data (PURPA) with all other QF projects that have signed ESAs with ldaho Power, on
page 112 of ldaho Power's 2017 lRP, Appendix C: Technical Report. No generation
from Clark Canyon was included in the CSPP (PURPA) forecast used in ldaho Power's
Load and Resource Balance Data beginning on page 19 of the Company's 2017 lRP,
Appendix C: Technical Report. Therefore, the Clark Canyon project did not contribute
to the capacity sufficiency period identified in the 2017 lRP.
Project generation was not included in the 2015 or 2017 lRPs due to the fact that
the 2011 ESA had been terminated and, although Clark Canyon and ldaho Power had
signed a new ESA in 2014, the 2014 ESA has not been approved by the ldaho Public
Utilities Commission, the project did not have a Federal Energy Regulatory Commission
license applicable to the project during the development of either lRP, and the project
has never been constructed or generated any electricity throughout the development of
the 2015 or 2017 lRPs.
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 9
b. Please see the Company's response to subpart a, above.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
DATED at Boise, ldaho, this 31st day of July 2017.
OVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 1O
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 31't day of July 2017 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO CLARK CANYON HYDRO,
LLC'S FIRST SET OF PRODUCTION REQUESTS upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attorney General
!daho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Clark Canyon Hydro, LLC
Gregory M. Adams
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
pete r@ richa rd so n ad a ms. com
C
IDAHO POWER COMPANY'S RESPONSE TO CLARK
CANYON HYDRO, LLC'S FIRST SET OF PRODUCTION REQUESTS - 11
->