20150407PAC to Staff 1-4.pdf

ROCKY MOUNTAIN 201 South Main,suite 2300
m,m"* ' ' iJ t": I: i ' salt Lake citv' utah 84lll
April6,2015
Jean Jewell
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
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RE: ID PAC-E-I5-03
IPUC Data Request (1-4)
Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests 1-4. Also
provided are Attachments IPUC 2 -{l-2). Provided on the enclosed Confidential CD are
Confidential Attachments IPUC 2 <3-7) and 3. Confidential information is provided subject to
the terms and conditions of the protective agreement in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J Tzc{ {1r6;Tctr- i, ,,
J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-15-03 / Rocky Mountain Power
April6,20l5
IPUC Data Request I
IPUC Data Request I
Please clarify whether PacifiCorp's request to limit PURPA contract length to a
maximum of 3 years is limited to IRP-based contracts only, or whether it is
intended to include published rate contracts. If it is limited to only IRP-based
contracts, please explain why published rate contracts do not present the same
price risk as discussed in the Company's Petition, and why PacifiCorp is not
requesting to limit contract length for published rate contracts.
Response to Data Request I
The Company intended for the three-year maximum term length to only apply to
the Integrated Resource Plan (IRP) based contracts at this time. The Company
does not believe the published rate contacts pose as great aprice risk for two
reasons:
(1) there is a 100 kilowatt (kW) cap on project size for wind and solar which
mitigates price exposure under published rates for these two technologies
which have been the majority of qualiffing facility (QF) development for
PacifiCorp in [daho, and
(2) the Company has not had any base-load QF project (i.e., combined heat and
power (CHP), geothermal, biomass, etc.) contract requests over a two-year
term on published rates nor does the Company expect ffiBny, if any.
Should the Company receive multiple requests for base-load published rate QF
contract requests, the Company would revisit the issue.
Recordholder: Paul Clements
Sponsor: Paul Clements
PAC-E-I5-03 / Rocky Mountain Power
April6,2015
IPUC Data Request 2
IPUC Data Request 2
On page 10, lines 7-15 of Brian Dickman's direct testimony, Mr. Dickman
discusses the impact on avoided cost rates if proposed QFs are included in the
calculation of the IRP-based avoided cost rates. Please provide spreadsheets,
analysis, models or other documentation supporting calculation of the $18 per
MV/h difference between including and not including approximately 3,000 MW
of proposed QFs in the pricing queue.
Response to Data Request 2
Please refer to Attachment IPUC 2-1 and Attachment IPUC 2-2,whichprovide
the high level support for the $18 per megawatt-hour ($AvIWh) avoided cost
difference.
Please refer to Confidential Attachment IPUC 2-3 through Confidential
Attachment IPUC 2-6, which provides the detailed support of the avoided cost
calculations,
The $18/]vIWh study was prepared with approximately 3,000 megawatts (MW) of
proposed qualifying facility (QF) projects, as discussed in the Direct Testimony of
Company witness, Brian S. Dickman, although the QF queue contained over
3,600 MW of potential QFs as discussed in Direct Testimony of Company
witness, Paul Clements. The current QF queue contains almost 4,000 MW of
potential QF including 10 new Idaho projects totaling 260 MW. Please refer to
Confidential Attachment IPUC 2-7, which provides a listing of the current QF
queue.
Confidential information is provided subject to the terms and conditions of the
protective order in this proceeding.
Recordholder: Laren Hale
Sponsor: Brian Dickman
PAC-E-I5-03 / Rocky Mountain Power
April6,2015
IPUC Data Request 3
IPUC Data Request 3
Please provide a list of proposed Idaho PURPA projects currently seeking
contracts with PacifiCorp. For each project, please indicate the following: name
of the project, developer, project location, the utility service territory in which the
proposed project is located, nameplate capacity, technology type (e.g., solar PV,
hydro, wind, etc.), proposed online date, date of indicative pricing request, and
date on which indicative prices were provided to the project developer.
Response to Data Request 3
Please refer to Confidential Attachment IPUC 3, which provides the requested
list. Please also refer to the Company's response to IPUC Data Request 2, which
provides a discussion of the potential QF queue.
Confidential information is provided subject to the terms and conditions of the
protective order in this proceeding.
Recordholder: Laren Hale
Sponsor: Brian Dickman
PAC-E-15-03 / Rocky Mountain Power
April6,20l5
IPUC Data Request 4
IPUC Data Request 4
If the Commission were to approve PacifiCorp's request to include proposed QFs
in the calculation of the indicative pricing to be provided QFs in the queue, has
the Company developed criteria to address management of the queue? For
example, what criteria would be applied to determine such things as when
projects enter the queue, when projects drop out ofthe queue, when recalculation
ofprices occurs, which projects are subject to re-pricing, etc?
Response to Data Request 4
Yes, the Company would utilize pricing queue management criteria similar to that
used in PacifiCorp's other states where the indicative prices are based on projects
in a pricing queue. This includes, at a high level, inclusion in the pricing queue
only when all the information necessary to calculate the indicative pricing has
been provided by the potential qualifying facility (QF). Once indicative pricing
has been delivered to the QF, the QF must make reasonable timely progression
towards execution of a power purchase agreement (PPA) in order to maintain its
position in the pricing queue. Furthermore, if the QF changes significant details
about the project (such as site location, online date, or project size), the QF is
removed from the queue and then re-enters the queue at the bottom as a new
request with the new project description.
Recordholder: Paul Clements
Sponsor: Paul Clements