20141209IPC to Staff 5.pdf

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DONOVAN E. WALKER
Lead Counsel
[e-mail]
December 9,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-31
Clark Solar 4, 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 extemal hard drive are confidential and should be handled in
accordance with the Prctective Agreement in this matter.
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise. lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83701
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower. com
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 4, LLC FOR THE SALE
AND PURCHASE OF ELECTRIC ENERGY.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. |PC-E-14-31
IDAHO POWER COMPANY'S
RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powed'), and in response to the
Third Production Request of the Commission Staff to ldaho Power Company dated
December 3,2014, 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
AUROM 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 20-year levelized rates under both scenarios
and calculate the difference in the total 2O-year contractual obligation. With your
answer, please provide copies of al! 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
tool. One input into the AURORA model that is required to establish the hourly
generation resource stack of existing resources (not including the proposed qualified
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 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 incrementa! 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
REOUEST 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 mode! runs with
this response. A comparison of the 2O-year levelized rates under both scenarios is
listed below.
2O-year Levelized Rates
lst Production 3rd Production
Below is the difference in the total 20-year contractual obligation.
20-year Gontractual Obl i gation-lncl ud i ng I nteg ration
lst Production 3rd Production
Clark Solar 4
Clark Solar 4 Request
$60.87
Request
$67,863,931
Request
$60.89
Request
$67,903,112
Difference
$0.02
Difference
$39.181
Please see the directory titled "!PC-E-14-31,32 IPUC Staffs Third Production
Request" and the confidential subdirectory titled "CONFIDENTIAL-|PC-E-14-31-CIark
Solar 4-IPUC 3rd PROD Request-Response 5" on the external hard drive for the Excel
files used for the analysis. !n addition, please see the directory titled "|PC-E-14-31,32
IPUC Staffs Third Production Request" and the confidential subdirectory titled
"CONFIDENTIAL-|PC-E-14-31, 32-AURORA Change Set-IPUC 3rd PROD Request-
Response 5" for the AURORA files. 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 extemal hard
drlve and file subdirectories are marked "CONFIDENTIAL." However, to maintain the
integrity of the files, the files themselves are not further marked or identified as
confidential.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
The response to this Request is sponsored by Randy C. Allphin, Energy
Contracts Coordinator Leader, ldaho Power Company.
DATED at Boise, ldaho, this th day of December 2014.D=ru
DONOVAru E. W
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this th day of December 20141 served a true and
conect 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
Glark Solar 4, LLC
Dean J. Miller
McDEVITT & MILLER, LLP
420 West Bannock
Boise, ldaho 83702
Mark van Gulik
Clark Solar 4, LLC
P.O. Box 7354
Boise, ldaho 83707
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Christa Bearry, Legal Assi
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5