20150326ICL&Sierra Club 1-9 to IPC.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6tr Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
botto@idahoconservation. org
Matt Vespa
CA Bar #222265 (Pro Hac Vice pending)
Sierra Club
85 Second St., 2nd Fl.
San Francisco, CA 94105
Ph:415-977-5753
Fax: [phone]
matt.vespa@sierraclub. org
Attorneys for the ldaho Conservation League and the Sierra Club
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO MODIFY
TERMS AND CONDITIONS OF
PROSPECTIVE PURPA ENERGY SALES
AGREEMENTS.
CASENO. IPC-E-Ts-OI
FIRST PRODUCTION REQUEST OF
THE IDAHO CONSERVATION
LEAGUE AND THE SIERRA CLUB
The Idaho Conservation League (ICL) and the Sierra Club 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: For the 461 MW of PURPA solar contracts that the Idaho PUC has approved, ICL
understands that a portion of the Renewable Energy Credits (RECs) associated with this
generation will be transferred to Idaho Power:
a. For the most recent five calendar years (2010-2014), please provide Idaho Power's annual
MWhs of REC sales and the annual revenues from these sales. To the extent that the data
is available to Idaho Power, please indicate in which state(s) the purchasers of Idaho
Power's RECs used those RECs for RPS compliance.
IPC-E-15-01 I March 26,2015
ICL/SC First Production Request to Idaho Power
b. Does Idaho Power's indicative pricing for solar contracts include any consideration of the
REC revenues that Idaho Power will receive from REC sales?
l. If yes, please describe how the IRP methodology incorporates potential REC
revenues Idaho Power may receive from QFs.
2. If no, please explain why Idaho Power does not include potential REC revenues to
Idaho Power in avoided cost calculations.
Request No 2: Please reference pages 17-20 of Idaho Power's Petition, as well as Mr. Allphin's
testimony and exhibits referenced therein, discussing Idaho Power's "long history with active
PURPA QF projects.":
a. Based on this history, what is the historical "success rate" for QFs with signed and
approved contracts to actually bring their projects on-line? Please express this as a
percentage of the historical MWs of signed QF contracts that have resulted in on-line
MWs of QF projects.
b. Of the 521 MWs of QFs under contract, but not on-line, how many MWs does Idaho
Power expect will be successful at bringing their projects on-line?
c. Please provide the historical on-line dates for the on-line PURPA QF projects listed in
Mr. Allphin's Exhibit No. 2.
d. Please provide the MWh data for the QF and renewable resources, and for Idaho Power's
total retails loads, that Mr. Allphin used to construct the RPS percentages shown in his
Exhibit No. 5.
Request No 3: Please reference page 7 of Idaho Power's Petition discussing the "surrogate
avoided resource (SAR)" pricing methodology for QFs below the published rate eligibility cap:
a. Please provide a list of the 2}-year SAR prices for QFs below the published rate eligibility
cap that Idaho power has offered from 2002 when the 20-year contract term was first
established - see Petition, at p. 8, referencing Order No. 29029, until today.
b. Please provide a list of QFs under contract to Idaho Power today whose contracts use the
SAR pricing method. If this contract-specific information is confidential, please provide
the number and nameplate MW of SAR contracts, by technology (wind, hydro, biomass,
solar, etc.).
Request No 4: Please reference pageT of Idaho Power's Petition, which discusses the "Schedule
86" pricing methodology for as-available QFs:
IPC-E-15-0r
ICL/SC First Production Request to Idaho Power
March 26,2015
a. Please provide a list of the monthly Schedule 86 prices for as-available QFs that have
applied on Idaho Power's system from 2000-2014.
b. Please provide a list of as-available QFs under contract to Idaho Power today whose
contracts use the Schedule 86 pricing method. If this contract-specific information is
confidential, please provide the number and nameplate MW of Schedule 86 contracts, by
technology (wind, hydro, biomass, solar, etc.).
Request No 5: Please reference the Direct Testimony of Mr. Allphin Exhibit No. 8 that shows
certain FERC account expenses for the years 2010, 2012, and20l3:
a. Do FERC Account Nos. 501 (coal) and547 (gas) include either fixed O&M costs,
incremental capital additions, or the costs associated with the return on rate base and
associated taxes for Idaho Power-owned coal and gas plants?
b. Please provide the fixed O&M costs, incremental capital additions, and the revenue
requirements associated with the return on rate base and associated taxes for Idaho
Power-owned coal and gas plants for the years 2010, 2012, and 2013. For gas plants,
please also include gas pipeline capacity or reservation costs if not included in Account
547.
c. If available, please provide the data in Exhibit No. 8, plus the data requested in Part (a) of
this question, for the years 20ll and2014.
Request No 6: Please reference page 26 of Idaho Power's Petition that lists certain percentages of
hours in2016-2017 in which the minimum must-run and must-take generation available to
Idaho Power is expected to exceed Idaho Power's loads:
Please provide these percentages for all cases assuming no generation from Idaho Power's
share of the Valmy coal plant.
Request No 7: Please reference pages 25-26 of Idaho Power's petition describing the "15
reliability events', and Idaho Power's confidential response to I.R. Simplot Production Request
No. 6, describing the number of "reliability events that resulted in wind generation output
reductions". For each such event, please also provide:
a. The cause of the event, including the multiple issues that may have contributed to the
event. (See response to J.R. Simplot Question No. 6(c)).
b. The total cost to Idaho Power for the MWhs of wind generation curtailed during these
events. If there was no cost, please so speciff.
IPC-E-ls-oI 3
ICL/SC First Production Request to Idaho Power
March 26,2015
Request No 8: Please reference Idaho Power's Response to J.R. Simplot Production Request No.
a(d) and specifically the tables with 2O-year (2017-2036) indicative pricing provided to potential
solar QFs (Projects Al, A2,81, 82, and Cl through C10). Please provide:
a. The data in those tables in Excel format, or, alternatively, please provide the 2O-year
levelized HLH and LLH pricing, in $/MWh, for each project.
b. Please define which hours of the year constitute Idaho Power's Heavy Load hours and
Light Load hours, as used in this indicative pricing.
Request No 9: Please reference Idaho Power's response to I.R. Simplot Production Request No.
5(b) that indicates an expected cost of $210 to $250 million for Idaho Power's share of the
Boardman-to-Hemingway transmission line. Please provide:
a. The year for this cost estimate (i.e. 2015 dollars, 2014 dollars, 2013 dollars, etc.).
b. Idaho Power's real economic carrying charge (RECC) for converting transmission capital
costs into annual costs.
c. The expected first-year revenue requirement for Idaho Power's share of the Boardman-
to-Hemingway transmission line, assuming a capital cost of $230 million.
d. The expected utilization (capacity factor) for Idaho Power's share of the Boardman-to-
Hemingway transmission line.
Respectfully submitted this 26'h day of March 2015,
Benjamin I. Otto
Idaho Conservation League
rPC-E-ls-Or 4
ICL/SC First Production Request to Idaho Power
March 26,2015
CERTIFICATE OF SERVICE
I hereby certiff that on this 26th day of March 2015, I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST TO IDAHO POWER the following persons via
the method of service noted:
Hand Delivery:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
42TW.Washington St.
Boise,ID 83702-5983
(Original and three copies provided)
Electronic Mail:
Idaho Power
Donovan E. Walker
Regulatory Dockets
Idatro Power Company
l22l West Idaho Street
P.O. Box 70
Boise,ID 83707
[e-mail]
dockets@idahopower. com
Avista
Michael G. Andrea, Senior Counsel
Clint Kalich
Avista Corporation
1411 E. Mission Ave, MSC-23
Spokane, WA99202
[e-mail]
[e-mail]
Roclqt Mountain Power
Daniel Solander
Ted Weston
Rocky Mountain Power
201 S. Main Street, Ste 2400
Salt Lake City, UT 841l1
D aniel. sol and er @pacifrcorp. c om
Ted. weston@pacifi corp. com
datarequest@pacifi corp. com
IPC-E-15-01 5
ICL/SC First Production Request to Idaho Power
J.R. Simplot Corp & Clearwater Paper
Peter J. Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N. 27ft Street
Boise, lD 83702
peter@richardsonadams. com
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dreading@mindspring. com
Carol Haugen, Clearwater Paper
Carol.haugen@clearwater. com
Twin Falls Canal, Northside Canal,
American Falls Reservoir District No 2.
C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock St Ste. 900
P.O. Box 2900
Boise,ID 83701
Tom. arkoosh@arkoo sh. com
[e-mail]
Intermountain Ener gt P artners
Dean J. Miller
March 26,2015
McDevitt & Miller LLP
420 W. Bannock Street
PO Box 2564-83701
Boise,lD 83702
j [e-mail]
Leif Elgethun, PE, LLE AP
Intermountain Energy Partners
PO Box 7354
Boise,lD 83707
leif@sitebasedenergy. com
Idaho lrrigation Pumpers Association
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey,
Chartered
P.O. Box 1391
201E. Center
Pocatello,ID 83204
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
[e-mail]
Idaho Conservation League & Sierua Club
Benjamin J. Otto
Idaho Conservation League
710 N.6th St.
Boise,Idaho 83702
botto@idahoconservation. org
Matt Vespa
Sierra Club
85 Second St., 2nd Fl.
San Francisco, CA 94105
matt. vespa@sierraclub. org
Micron Technology
Richard Malmgren
Assistant General Counsel
Micron Technology Inc.
800 South Federal,Way
Boise,ID 837L6
remalmgren @micron. com
IPC-E-rs-0t 6
ICL/SC First Production Request to Idaho Power
Frederick I Schmidt
Pamela S Howland
Holland & Hart LLP
377 S. Nevada St.
Carson City, NV 89703
fschmidt@hollandhart. co m
phowland@holandhart. com
Amalgamated Sugar
Scott Dale Blickenstaff
Amalgamated Sugar Co
1651 S. Saturn Way, STE 100
Boise,Idaho 83702
sblickenstaff@amalsugar. com
Renew able En er gy C o alitio n
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise,Idaho 83702
ron @williamsbradbury. com
Irion Sanger
Sanger law, P.C.
1117 SW 53'd Avenue
Portland, OR972l5
[e-mail]
Benjamin J. Otto
March 26,2015