20141216IPC to Staff 5.pdf

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DONOVAN E. WALKER
Lead Counsel
[e-mail]
December 16,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-28
Clark 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 files is provided. The files
provided on the externa! hard drive are confidential and should be handled in
accordance with the Protective Agreement in this matter.
DEW:csb
Enclosures
1221 W. ldaho 5t. (83702)
P.O. Box 70
Boise. lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
CLARK SOLAR 1, LLC FOR THE SALE
AND PURCHASE OF ELECTRIC ENERGY.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-14-28
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 Idaho Powe/s
lnitial Comments. Please compare the 20-year levelized rates under both scenarios
and calculate the difference in the tota! 20-year contractual obligation. With your
answer, please provide copies of a!! AURORA 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 lntegrated Resource Plan ("lRP") model in the incremental pricing
too!. One input into the AURORA model that is required to establish 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. !n 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 local 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 !RP 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. Idaho Power has
included the applicable information for the revised incremental cost IRP mode! runs with
this response. A comparison of the 20-year Ievelized rates under both scenarios is
listed below.
Clark Solar 1
Clark Solar 1
1st
Production
Request
20-year Level ized Rateslst 3rdProduction Production DifferenceRequest Request
$60.22 $5e.e7 ($o.Zs;
Below is the difference in the total 20-year contractual obligation.
20 -year Gontractual Obl i gation-l ncl ud i ng I nteg ration
3rdProduction Difference
Request
$243,784,875 $242,390,161 ($1,404,714)
Please see the directory titled "aPC-E-14-26 thru 29 IPUC Staffs Third
Production Request" and the confidential subdirectory titled "CONFIDENTIAL-IPC-E-14-
28-Clark Solar 1-IPUC 3rd PROD Request-Response 5" on the external hard drive for
the Excel files used for the analysis. In addition, please see the directory titled "|PC-E-
14-26 thru 29 IPUC Staffs Third Production Request" and the confidential subdirectory
titled "CONFIDENTIAL-IPC-E-14-26 thru 29-AURORA Change SeI-IPUC 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 extema! 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 subdirectories are
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
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. AIIphin, Energy
Contracts Coordinator Leader, ldaho Power Company.
DATED at Boise, tdaho, this 16h 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
I 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 Genera!
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Clark Solar 1, LLC
Dean J. Miller
McDEVITT & MILLER, LLP
420 West Bannock
Boise, ldaho 83702
Mark van Gulik
Clark Solar 1, LLC
P.O. Box 7354
Boise, Idaho 83707
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IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5