20141202IPC to Staff 3-4.pdf

December 2,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
!daho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-36
Orchard Ranch Solar, LLC - ldaho Power Company's Response to the
Second 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 Second Production Request of the
Commission Staff.
DONOVAN E. WALKER
Lead Gounsel
DEW:csb
Enclosures
3Effi*.
An IDACORP Company
Donovan E. Walker"b
Very fuly yours,
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwal ker@ idahopower.com
Attorney for ldaho Power Company
;; :rri.- r, ,i\.-(.,r.rl
iflit 0tt -2 P,Y t?: 50
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
oF TDAHO POWER COMPANY FOR ) CASE NO. !PC-E-14-36
APPROVAL OR REJECTTON OF AN )
ENERGY SALES AGREEMENT WITH ) IDAHO POWER COMPANY'S
ORCHARD RANCH SOLAR, LLC FOR THE ) RESPONSE TO THE SECOND
SALE AND PURCHASE OF ELECTRIC ) PRODUCTTON REQUEST OF THE
ENERGY.) coMMrssloN STAFF To |DAHO
) POWER COMPANY
)
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
Company dated November 20,2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 3: ldaho Poweds application states under Paragraph 15 that
"[c]onsistent and material deviations from the hourly energy estimates in the generation
profile will be considered by ldaho Power to be a material breach of the agreement--
meaning that the entire pricing is fundamentally flawed as a result of an inaccurate
generation profile". PIease discuss how consistent and material the deviations need to
be before the entire pricing can be considered fundamentally flawed, and before ldaho
Power would consider this to be a material breach of the agreement.
RESPONSE TO REQUEST NO. 3: A key input of the ldaho Public Utilities
Commission-approved avoided cost calculation (ldaho Power incremental cost
lntegrated Resource Plan methodology) for this Energy Sales Agreement ("Agreement")
is the hourly energy estimates provided by the project (Appendix I of the Agreement).
As described in paragraph 15 of the Application, the Agreement contains various price
adjustment mechanisms and material deviation clauses to provide a level of assurance
that the hourly energy shape provided by the project and the resulting avoided cost
calculation is an accurate estimate of the project's expected energy production.
Evaluation of material deviations will be on a case-by-case basis for each project.
Numerous factors will be considered in determining the impact of material deviations,
some of those factors being time, magnitude, and frequency of the deviations, as we!!
as whether the pricing adjustments within the Agreement are adequately addressing the
deviations, etc.
The response to this Request is sponsored by Randy C. Allphin, Energy Contract
Coordinator Leader, ldaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 4: lf the entire pricing is considered fundamentally flawed, what
actions would ldaho Power take?
RESPONSE TO REQUEST NO. 4: ldaho Power would determine the most
appropriate action on a case-by-case basis and at the time the material breach
occuned. Please see the Company's response to Staffs Request No. 3 above. The
action taken will be intended to protect ldaho Power customers' interests and ldaho
Power will seek the ldaho Public Utilities Commission's approval of the action at the
time it is required. Some examples of actions that could be taken are termination of the
Agreement, recalculation of future contract year avoided cost payments, collection of
damages, etc.
The response to this Request is sponsored by Randy C. Allphin, Energy
Contracts Coordinator Leader, ldaho Power Company, in consultation with Donovan E.
Walker, Lead Counsel, Idaho Power Company.
DATED at Boise, ldaho, this 2nd day of
DONOVAN E. WALKER
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 2nd day of December 20141 served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
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
Orchard Ranch Solar, LLG
Ron Williams
Williams Bradbury, P.C
1015 West Hays Street
Boise, ldaho 83702
Ben Fairbanks
Director, Development
First Wind
Hand Delivered
U.S. Mail
Ovemight Mail
FAX
Emai! [e-mail]
Hand Delivered
U.S. Mail
Ovemight Mail
FAXX Email [e-mail]
_Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4