20141216IPC to Staff 5.pdf

3Effi*.
An IDACORP Companv
Pt{ tr: 56
DONOVAN E. WALKER
Lead Counsel
[e-mail]
December 16,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W est Wash i ngto n Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-27
Pocatello Solar 1, LLC - ldaho Power Company's Response to the Third
Production Request of the Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of
ldaho Power Company's Response to the Third Production Request of the Commission
Staff.
An external hard drive containing the requested
provided on the external hard drive are confidential
accordance with the Protective Agreement in this matter.
DEW:csb
Enclosures
files
and
is provided. The files
should be handled in
.r/L
'1221 W. ldaho 5t
PO. Box 70
Boise, lD 83707
onovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@idahopower. com
Attomey for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
POCATELLO SOLAR 1, LLC FOR THE
SALE AND PURCHASE OF ELECTRIC
ENERGY.
2illtr0[C l6 PFI h:57
rt1 F, I Il!ri\r i"-' , !- .i,
tlT I L lTl l; $ C0i'l i'{ i [i$ i t.]i'l
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. |PC-E-14-27
IDAHO POWER COMPANY'S
RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powef'), and in response to the
Third Production Request of the Commission Staff to ldaho Power Company dated
December 10, 2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 5: Please re-calculate the rates for the project by using in
AURORA the exact generation quantities and hourly and monthly shapes as are
represented in Appendix I of the Agreement. Please compare the resulting rates to
those contained in Replacement Appendix E included as Attachment 1 to ldaho Powe/s
lnitial Comments. Please compare the 2O-year levelized rates under both scenarios
and calculate the difference in the total 20-year contractual obligation. With your
answer, please provide copies of all AUROM and Excel files used for the analysis.
RESPONSE TO REQUEST NO. 5: ldaho Power already uses the exact
generation quantities and hourly and monthly shapes as contained within Appendix I in
the incremental cost Integrated Resource Plan ("lRP") model in the incremental pricing
tool. One input into the AURORA model that is required to establlsh the hourly
generation resource stack of existing resources (not including the proposed qualifying
facility ('QF') project) is the estimated hourly generation from all available resources
that exist prior to the addition of the proposed QF project. ln many cases, ldaho Power
does not have specific hourly energy estimates from the various QF projects; instead,
ldaho Power only has monthly energy estimates. Therefore, to create an hourly energy
shape of these QF resources, ldaho Power shapes the monthly energy estimates by
using generic information related to the resource types. ln the case of solar projects,
this hourly shaping has been based upon industry and loca! information with regards to
solar radiation and the expected energy deliveries from generic solar projects. Because
some solar projects are now providing hourly energy estimates, a potential
enhancement to the incremental cost IRP model will be to include the project specific
hourly energy estimates (when available) in the cumulative solar hourly energy shapes
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
that are used in establishing the hourly generation resource stack. ldaho Power has
included the applicable information for the revised incremental cost IRP model runs with
this response. A comparison of the 20-year levelized rates under both scenarios is
listed below.
20-year Levelized Rates1st 3rdProduction ProductionPocatello Solar 1 Request
$61.52
Request
$61.33
Difference
($o.t s1
Below is the difference in the total 2O-year contractual obligation.
20-year Gontractual O bl i gation-l ncl ud i ng I nteg ration
Pocatello Solar 1
lst 3rdProduction Production Difference
Request Request
$75,034,621 $74,734,154 ($300,467)
Please see the directory titled "IPC-E-14-26 thru 29 IPUC Staffs Third
Production Request" and the confidential subdirectory titled "CONFIDENTIAL-IPC-E-14-
27-Pocatello Solar 1-IPUC 3rd PROD Request-Response 5" on the external hard drive
for the Excel files used for the analysis. ln addition, please see the directory titled "lPC-
E-14-26 thru 29 IPUC Staff's Third Production Request" and the confidential
subdirectory titled 'CONFIDENTIAL-IPC-E-14-26 thru 29-AURORA Change Set-!PUC
3rd PROD Request-Response 5" for the AURORA files. Because of the very large size
of the requested files, they are being provided to Staff on the accompanying external
hard drive. The files and data contain non-public, confidential, and proprietary dispatch
costs or project generation of ldaho Power resources and should be handled in
accordance with the Protective Agreement. The external hard drive and file
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
subdirectories are marked .CONFIDENTIAL.' However, to maintain the integrity of the
files, the files themselves are not further marked or identified as confidential.
The response to this Request is sponsored by Randy C. Allphin, Energy
Contracts Coordinator Leader, ldaho Power Company.
DATED at Boise, ldaho, this 16th day of December 2014.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this 16th day of December 2014 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Pocatello Solar 1, LLC
Dean J. Miller
McDEVITT & MILLER, LLP
420 West Bannock
Boise, ldaho 83702
Mark van Gulik
Pocatello Solar 1, LLC
P.O. Box 7354
Boise, ldaho 83707
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Emai! [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email ioe@mcdevitt-miller. com
Hand Delivered
U.S. Mail
Ovemight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5