20141104Staff to Grand View 1-8.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
llrTCf !1,ri- il
?$liiH*y -|l p}{ l: rrg
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL ) CASE NO. rPC-E.-14-19
OR REJECTION OF AN ENERGY SALES )
AGREEMENT WITH GRAND VIEW PV ) STAFF'S RESPONSE TO
SOLAR TWO, LLC, FOR THE SALE AND ) GRAND VIEW PV SOLAR
PURCHASE OF ELECTRIC ENERGY. ) TWO, LLC'S FIRST
) PRODUCTION REQUEST
)
The Staff of the Idaho Public Utilities Commission, by and through its afforney of
record, Kristine A. Sasser, Deputy Attorney General, responds as follows to Grand View PV
Solar Two, LLC's First Production Request to Commission Staff.
REQUEST NO. 1: Please provide copies of Idaho Power's responses to all production
requestg from Staff in this docket.
STAFF RESPONSE NO. 1: A copy of the written portion of Idaho Power's Response
to the First Production Request of the Commission Staff is attached. A copy of the electronic
files is included on the accompanying dvd. Those files are contained in the folder titled "IPC-E-
14-19." Finally, files used by Staff for Aurora analysis, because they are too large to fit on a
dvd, will be provided to Grand View on a flash drive provided by Grand View.
STAFF' S PRODUCTION RESPONSE
TO GRAND VIEW PV SOLAR TWO 1 NOVEMBER 4,2014
REQUEST NO. 2: Please provide copies of all the Commission's workpapers and notes
used in preparing Staff s Comments in this docket.
STAFF RESPONSE NO. 2z All workpapers and notes used by the Commission Staff in
preparing its Comments are electronic, and a copy of all files used by Staff is included on the
accompanying dvd.
REQUEST NO. 3: Please provide a copy of all documents referred to by the
Commission in preparation of Staff s Comments in this docket.
STAFF RESPONSE NO.3: Aside from prior Commission orders, which are available
on the Commission's public website, Staff referred to only two other documents in its
Comments. The first reference was to the Direct Testimony of tdaho Power witness Karl
Bokenkamp in Case No. GNR-E-I1-03. That testimony is accessible on the Commission's
public website. The other document referenced was a recent decision of the Idaho Supreme
Court in the case ldaho Power Company v. Idaho Public Utilities Commission and Grouse Creek
l4/ind Park, 155 Idaho 780, 316 P.3d 1278 (2013). That document is attached.
REQUEST NO. 4: Please provide the information from Table I of Staff s Comments
for every hour of the term of the contract.
STAFF RESPONSE NO. 4: The information requested is contained in the Excel file
titled "GV Staff incremental cost calculations," a copy of which is included on the
accompanying dvd.
REQUEST NO. 5: Please provide documentation supporting Figure One on pageT of
Staff s Comments and for Figure Two on page 8.
STAFF'S PRODUCTION RESPONSE
TO GRAND VIEW PV SOLAR TWO NOVEMBER4,2OI4
STAFF RESPONSE NO. 5: Documentation supporting Figure One is contained in the
file titled "IIRP Methodology20l3IRP_no carbon_ElA 2013 NG_Oct20l3 Load_CSPP
20140529.xdb." A copy of that file is included on the flash drive provided to Grand View.
Documentation supporting Figure Two is contained in the file titled "GV Staff incremental cost
calculations." A copy of that file is included on the accompanying dvd.
REQUEST NO. 6: Please provide data for all hours for the term of the contract with
data for the l5 columns displayed in Table I along with the calculations for the avoided cost of
energy for each hour as displayed in the formula on page 6 below Table 1.
STAFF RESPONSE NO. 6: The information requested is contained in the Excel file
titled "GV Staff3rice calculations NEW," a copy of which is included on the accompanying
dvd.
REQUEST NO. 7: Was 80 MW used for Grand View in each hour for the calculations
in the formula found on page 6?
STAFF RESPONSE NO. 7: Yes.
REQUEST NO. 8: Was 80 MW used for Grand View for each hour of the 20 year
contract period in the AURORA calculations of avoided energy cost rather than the output
profile provided by Grand View to Idaho Power in the calculations of avoided costs? Please
explain why or why not.
STAFF RESPONSE NO. 8: 80 MW was used for each year of the contract because that
is the nameplate capacity as specified in Appendix B of the contract and because it is the
capacity used by Idaho Power in its analysis. Staff did not modify the output profile provided by
Idaho Power in its response to Staff production requests. Staff does not know what output
profile Grand View may have provided to Idaho Power.
STAFF' S PRODUCTION RESPONSE
TO GRAND VIEW PV SOLAR TWO 3 NOVEMBER 4,2014
Dated at Boise, Idaho, ,hi, +fl day of Novernber 2014.
Technical Staff: Rick Sterling
Yao Yin
i:umircpodreq/lpcal4.l9ksrpsry rcspousc to Grand View prod rcq
STAFF'S PRODUCTION RESPONSE
TO GRAND VIEW PV SOLAR TWO NOVEMBER 4, 2OI4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4,H DAY OF NOVEMBER 2014,
SERVED THE FOREGOING STAFF'S RESPONSE TO GRAND VIEW PV SOLAR
TWO, LLC'S FIRST PRODUCTION REQUEST, IN CASE NO. IPC-E-14-19, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E. WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
P.O. BOX 70
BOISE,ID 83707
E-MAIL: [e-mail]
dockets@idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH ST
BOISE ID 83702
E-MAIL: [e-mail]
RANDY C. ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE