20140919ICL 1-7 to IPC.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 66 Street
Boise,ID 83701
Ph: [phone] xt2
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY CONFIRMING USE OF
THE CAPAPCITY DEFICIENCY
PERIOD FOR THE INCREMENTAL
COST, INTEGRATED RESOURCE
PLAN, AVOIDED COST
METHODOTOGY.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-I4-22
\( IDAHO CONSERVATION LEAGUE( FIRST PRODUCTION REQUEST TO
i rDAHO PowER
)
The Idaho Conservation League (ICL) requests the following information from Idaho
Power. Please provide any documents, workpapers, calculations, or information sources that
support any answer. As required by IDAPA 31.01.01.228.02, please indicate the witness who can
answer questions regarding the response and who will sponsor the response at any potential
hearing. If any responses include Excel spreadsheets or other electronic files, please provide them
with all formulas intact and activated. This production request is ongoing. Accordingly, we ask
Idaho Power to provide additional documents and information that may supplement any initial
resPonses.
Request No l:
Please reference pageT of Idaho Power's Application, which states:
In addition, Idaho Power currently has just over 529 MW of proposed new solar QF
projects seeking pricing and contracts. Of this 529 MW, eight proposed projects (just over
208 MW) had previously received initial indicative pricing that included capacity
payments for the entire term of the contract sent prior to the Commission's )uly 2021 first
capacity deficit determination. Each of these projects has received superseding and
updated indicative pricing runs with the capacity portion of the rates removed through
Itne of202l.
a. Please provide a list of each of the solar projects included in the 529 MW of proposed new
solar QF projects that includes;
i. Name of the project
LPC-E-I4-22
ICL First Production Request to Idaho Power
September 19,2014
ll.
iii.
iv.
Nameplate MW
Location of the Project
Estimated on-line date
b. Please indicate which of the above-proposed projects are the eight that received initial
indicative pricing along with the initial avoided cost of energy and the capacity payment
offered to the QF.
Request No 2:
Please reference pages 7 and 8 of Idaho Power's Application, which states:
The difference in avoided cost rates for those eight projects that received revised
indicative pricing is approximately $65 million. The difference in price for all529 MW of
proposed solar projects is just about $170 million.
Please provide all workpapers, spreadsheets, and documents used to calculate the $65
million cost of the eight projects and the $170 million cost for all of the 529 MW proposed solar
projects.
Request No 3:
Based on Idaho Power's representations, submitted April 29,2014, the Commission
found the Company had enrolled 403 MW of demand response capacity across three programs
for the summer of 2014. Order No. 33084 at 4 - 5.
For April 2014 through August 2014, please provide for each of the three demand
response programs the actual MW reduction, the dates each program was dispatched, and the
duration of the dispatch.
Request No 4:
Please reference Idaho Power's Application at page 4, where the Company describes the
capacity deficiency resulting from Case No IPC-E-13-21.
a. Please confirm or deny if tdaho Power represented in that docket that when including 440
MW of demand response the first capacity deficient was 36 MW in luly of 2021.
b. Please confirm or deny if Idaho Power represented in that docket that without demand
response programs Idaho Power forecast a 414 MW capacity deficient in fuly of 2020.
LPC-E-I4-22
ICL First Production Request to Idaho Power
September 19,2014
Please explain whether Idaho Power's confirmed demand response capacity of 403 MW is
sufficient to meet the forecast 414 MW of deficiency in July of 2020.
d. Please describe Idaho Power's ability to retain at least 403 MW of demand response
capacity each year throughout the 2O-year IRP forecast period.
Request No 5:
Has Idaho Power experienced any erosion in the participation rate of any of the three DR
programs over the summer of 2014? If so please indicate which program and the degree of the
erosion in terms of megawatts and participants or service points.
Request No 6:
Idaho Power's 2013 Integrated Resource Plan, on page 36, states the Company "is
planning on the additional capacity from the Shoshone Falls upgrade being available in2019".
Please provide any documentation establishing that the Shoshone Falls upgrade will in fact be
online in 2019 and provide the expected MW of additional capacity. For example, please provide
copies of any permits or other approvals received, water rights secured, and economic analysis
completed.
Request No 7:
Please refer to page 6l of Idaho Power's 2013 Integrated Resource Plan, which states the
Company includes existing energy efficiency into the peak-hour load and resource balance.
a. Please confirm whether Idaho Power's actual energy efficiency savings in20l4 match the
forecasted energy savings for 2014 included in the load and resource balance. If actual
and planned saving do not match please indicate whether actual loads were higher or
lower than forecast.
b. Please provide the capacity contribution of energy efficiency programs for each year of the
peak-hour load and resource balance in the 2013 IRP.
LPC-E-I4-22
ICL First Production Request to Idaho Power
September 19,2014
CERTIFICATE OF SERVICE
I hereby certifr that on this 19th day of September 2014,I delivered true and correct
copies of the foregoing ICL FIRST PRODUCTION REQUEST TO IDAHO POWER to the
following persons via the method of service noted:
Hand delivery:
Jean Iewell - Commission Secretary (Original and three copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Donovan E. Walker
Regulatory Dockets
RandyC. Allphin
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise, ID 83707
dwalker@idahopower. com
dockets@idahopower. com
[e-mail]
rPC-E-14-22
ICL First Production Request to Idaho Power
Benjamin Otto
September 19,2014