20190228IPC to Staff 1-3.pdf

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DONOVAN E. WALKER
Lead Counsel
[e-mail]
February 28,2019
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-19-03
Koyle Hydro !nc. - Koyle Small Hydro Project
ldaho Power Company's Response to the First Production Request of the
Commission Staff
Dear Ms. Hanian:
Enclosed for filing in the above matter please find an original and three (3) copies
of ldaho Power Company's Response to the First Production Request of the
Commission Staff.
Very tru yours,
E. Walker
DEW:csb
Enclosures
PO. Box 70 (83707)
1221 W. ldaho St.
Boise, lD 83702
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ida power.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
THE APPLICATION OF ]DAHO POWER
FOR CONSIDERATION OF AN ENERGY
SALES AGREEMENT WITH KOYLE
HYDRO
CASE NO. IPC-E-19-03
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated February 15,2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
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REQUEST NO. 1: Please describe how adjustments to Estimated Net Energy
Amounts reported to ldaho Power from a QF are used by the Company.
RESPONSE TO REQUEST NO. 1: There are two ways Estimated Net Energy
Amounts provided from a Qualifying Facility ("QF") are used by ldaho Power. First, they
are used in the determination of whether a QF's actual monthly generation is within 90
percent to 110 percent of the QF's Estimated Net Energy Amount for the applicable
month for purposes of determining if the QF is eligible to be paid the "firm" avoided cost
price from the Energy Sales Agreement ('ESA') applicable to the QF.
The other use of a QF's Estimated Net Energy Amount is in the Company's
preparation of the cogeneration and small power production (CSPP) forecast where the
monthly adjusted Net Energy Amounts supplied by QFs may be used to verify forecast
monthly generation from individual QFs and adjust the forecast if necessary.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: Please explain why ldaho Power believes adjustments to
Estimated Net Energy Amounts at least one-month in advance are not required for the
Koyle Hydro project.
RESPONSE TO REQUEST NO. 2: The Koyle Small Hydro QF has been
delivering generation to ldaho Power under a Public Utility Regulatory Policies Act of
1978 (PURPA) ESA since 1983. As that ESA is scheduled to expire on March 31,
2019, the QF and ldaho Power entered into a new "replacement" ESA on January 30,
2019. The original ESA did not require the QF to submit Estimated Net Energy
Amounts, whereas the new ESA contains 90/110 provisions that require the QF to
provide 12 months of Estimated Net Energy Amounts and allows the QF to change the
Estimated Net Energy Amounts during the term of the ESA.
During draft contract discussions, the QF requested that it have the ability to
change its Estimated Net Energy Amounts by the earlier of the 25th day of the month or
the last business day before the 25th day prior to the upcoming month with the changed
Estimated Net Energy Amount. ldaho Power agreed that this was reasonable as it
would provide the Company with a more accurate estimate of the generation scheduled
to be delivered during the upcoming month and it would allow the QF to make
adjustments to its estimate of generation deliveries closer to the month of the actual
deliveries.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 3: Please describe how lack of adjustments to Estimated Net
Energy Amounts at least one-month in advance in the Koyle Hydro project affects ldaho
Power's month-ahead or longer-term ahead planninq process. Please also discuss its
impacts on ratepayers.
RESPONSE TO REQUEST NO. 3: Allowing the Koyle Small Hydro QF to adjust
its Estimated Net Energy Amounts to the earlier of the 25th day of the month or the last
business day before the 25th day prior to the upcoming month does not change in any
way the manner and process used by ldaho Power to estimate future QF generation.
The Company will have historical generation information, 12 months of Estimated Net
Energy Amounts from the QF's ESA, and will utilize the same processes currently in
place to make estimates of QF generation from a monthly basis through real-time
operations.
Assuming the ESA is approved by the ldaho Public Utilities Commission, ldaho
Power and its customers will be required to pay the avoided cost prices contained in the
ESA for generation received from the QF. ldaho Power will pay the contracted avoided
cost prices for all generation received that falls within 90 percent to 110 percent of the
monthly Estimated Net Energy Amounts provided by the QF. ldaho Power will pay the
lower of the Market Energy Reference Price or the A!! Hours Energy Price, as defined in
the ESA, for generation delivered by the QF that is less than 90 percent or the portion of
generation that exceeds 1 10 percent of the QF's monthly Estimated Net Energy
Amount.
It is not possible for ldaho Power to predict the number of times the QF will
supply Estimated Net Energy Amounts that are within 90 percent to 110 percent of
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
actual deliveries of generation for upcoming months. However, if the QF is able to
provide a change to its Estimated Net Energy Amounts closer to the time of actual
deliveries, it is possible the Estimated Net Energy Amounts will be more accurate,
resulting in fewer months during the term of the ESA the QF would be paid the Market
Energy Reference Price.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, Idaho Power Company.
DATED at Boise, ldaho, this 28th day of February 2019.
OVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of February 2019 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Edward Jewell
Deputy Attorney General
!daho Public Utilities Commission
47 2 W est Wash ington Street (837 02)
P.O. Box 83720
Boise, ldaho 83720-007 4
X Hand Delivered
_U.S. Mai!
_Overnight Mail
_FAXX Email edward.iewel idaho.oov
Koyle Hydro lnc.
Alan L. Koyle
Koyle Hydro lnc.
1505 South 1800 East
Gooding, ldaho 83330
_Hand Delivered
X U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
ch
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6