20190620IPC to Staff 1-20.pdf

RECEIVED 3Iffi*.
An IDACORP Company
:019 JUI'I 20 Pt{ lr: I 7
DONOVAN E. WALKER
Lead Counsel
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June 20, 2019
VIA HAND DELIVERY
Diane M. Hanjan, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. !PC-E-19-14
Power Purchase Agreement with Jackpot Holdings, LLC - ldaho Power
Company's Response to the First Production Request of the Commission
Staff
Dear Ms. Hanian:
Enclosed forfiling in the above matter please find an originaland three (3) copies of
ldaho Power Company's Response to the First Production Request of the Commission
Staff.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information provided in response to Staffs production requests. Please handle
the confidential information in accordance with the Protective Agreement executed in this
matter.
!f you have any questions about the enclosed documents, please do not hesitate to
contact me.
very yours,
c
DEW:csb
Enclosures
1221 W. ldaho 5t. (83702)
PO. Box 70
Boise, lD 83707
Donovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
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RECEIVED
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IDAI{O PUBLICITiLI'TIES CCMMISSION
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER FOR APPROVAL OF A
POWER PURCHASE AGREEMENT WITH
JACKPOT HOLDINGS, LLC, FOR THE
SALE AND PURCHASE OF UP TO 220
MEGAWATTS OF RENEWABLE SOLAR
GENERATION
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CASE NO. IPC-E-19-14
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 May 30, 2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 1: Please provide files containing assumptions, inputs, outputs,
and summary information for all scenarios used in the Company's economic analysis
described in Larkin's direct testimony on page 11. For each scenario, provide a
summary of the parameters changed for each run.
RESPONSE TO REQUEST NO. 1: The inputs for the AURORA analysis
described on page 11 of Mr. Larkin's direct testimony are included in the confidential
Excel file provided on the confidentia! CD. The "Aurora Resources" tab includes the
inputs and assumptions from the 2017 lntegrated Resource Plan ("lRP") that were used
for the analysis. The "Jackpot Solar Scenario" tab includes the scenario inputs for the
Jackpot Solar Power Purchase Agreement ('PPA"). The only parameter that was
changed was the addition of Jackpot Solar at 120 megawatts ("MW") and 220 MW. The
output of this analysis is found in the Excel file provided with the Company's response
to the ldaho Public Utilities Commission Staffs ("Staff') Request No. 18.
The confidential CD will be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: For lhe 24 portfolio simulations analyzed in the long-term
capacity expansion (LTCE), please provide the following:
a. The existing supply-side resources information input into the model. This
should include but not be limited to: nameplate capacity, capital cost, fixed and variable
O&M, etc.
b. The future supply-side resources available for selection in the model. This
should include but not be limited to: nameplate capacity, capital cost, fixed and variable
O&M, annual capacity factor, economic life, etc.
c. A summary of the individual resources selected and retired during the 20-
year planning period for each of the 24 portfolio simulations. This should include but not
be limited to: name/ldentification of the individual resource, nameplate capacity selected
or retired, year of selection/retirement, how it was modeled (forced to retire or allowed to
float in the model), etc.
RESPONSE TO REQUEST NO. 2:
a. The existing supply-side resource information is included in the "Aurora
Existing Resources" tab of confidential Attachment 1 provided on the confidential CD.
b. The new resource information is included in the "Aurora New Resources"
tab of confidential Attachment 1 provided on the confidential CD.
c. The LTCE results included in Attachment 2 provided on the non-
confidential CD represent the addition and retirement of resources for each of the 24
portfolios. The detailed information for existing resources is the same for each portfolio
and is provided in response to subpart a above. While all units were allowed to float,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
the Jim Bridger power plant ("Jim Bridger") units could retire starting in2022 for Unit 1,
2024 for Unit 2,2026 for Unit 3, and 2028 for Unit 4.
The confidential CD will be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
REQUEST NO. 3: ln reference to lines 1-3 on page 18 of Mr. Larkin's direct
testimony, both the Jackpot Solar and Franklin Solar Facilities were not selected in 10
of the 24 portfolio simulations. Of those 10 portfolio simulations, 7 of the simulations did
not include both the solar facilities when Boardman-to-Hemingway (B2H) transmission
line was included in the portfolio. Please respond to the following:
a. For the 10 out of 24 portfolio simulations that did not include both Jackpot
Solar and Franklin Solar Facilities, please explain why the solar PPA projects were not
selected for each of the 10 portfolios.
b. lf the Company moves forward with the B2H transmission line, does the
Company stil! believe that the Jackpot Solar and Franklin Solar PPA are cost effective,
given that the 2nd, 3'd, and 4th ranked portfolios (based on least cost net present value
using planning gas and planning carbon assumptions) do not include the solar PPA's?
Please explain.
c. lf the Company chooses a preferred portfolio that includes B2H and
moves forward with the transmission line, what resource decisions wi!! need to be made
and what future conditions will need to exist in order for the Jackpot Solar and Franklin
Solar Facilities to be cost-effective? Please explain.
RESPONSE TO REQUEST NO. 3:
a. The 24 portfolios built using the AURORA LTCE function were all unique
based on various natural gas and carbon price futures, and with or without B2H. ln
each portfolio run, the need for capacity in the LTCE model is the primary consideration
for the addition of new resources to the ldaho Power portfolios. The window of
availability for the LTCE model to select the Jackpot Solar and Franklin Solar projects
was fimited to 2022 and 2023, respectively, which further drove unique portfolio results.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
Future capacity needs, system reliability, and economics are primary considerations for
the addition of new resources and future resource retirements for each portfolio. During
each iteration within a model run, the LTCE model evaluates the capacity position for all
20 future years and determines if additional capacity is needed to maintain the required
15 percent planning margin and what combination of future resources can provide the
most economical solution-within ldaho Power's zone as well as the Western Electricity
Coordinating Council.
The general iterative methodology for the LTCE logic is that for each LTCE
iteration, an updated set of candidate new resource options and retirements are placed
in the system and the mode! performs the standard chronological commitment and
dispatch logic with that configuration. The model tracks the performance of all new
resource options and resources available for retirement, tracking the resource costs and
value based on the market prices developed in the iteration. At the end of each
iteration, the LTCE logic decides how to adjust the current set of new builds and
retirements, or it determines that the model has converged on a solution. The logic
behind the LTCE model seeks to create a mix of resources that are most economic
while adhering to future capacity needs and meeting reliability constraints. The Mixed-
lnteger Program Logic for the LTCE function in AURORA uses two methods, "Maximize
Value" or "Minimize Cost." The Company used the "Maximize Value" method for the
2019 IRP process. This method creates a mix of resources that are most economic
while adhering to all of the modeling constraints. When typical planning reserve margin
targets are being used, the model will not build significantly past the planning reserve
target; however, if the model sees an abundance of economic resources, it may build
beyond the planning reserve target in order to maximize value. To prevent overbuilding
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
of resources that may be economic, the model has a switch that can be turned "on" or
"off'to prevent excess overbuilds beyond the planning reserve target. The Company
used the functionality of limiting excess overbuilds beyond the planning reserve target
during the LTCE process for the 2019 lRP. The use of the switch to prevent excess
overbuilds contributed to the Jackpot Solar and Franklin Solar projects not being
selected in all portfolios.
b. Yes, the Company still believes that the Jackpot Solar and Franklin Solar
projects are cost-effective. The price of power from these projects is generally less than
the forecasted market price of power, making the projects a cost-effective resource for
ldaho Power customers independent of B2H. Please see the Company's response to
subpart a above for more context of how the AURORA LTCE modeling selects
resources.
c. Please see Exhibit No. 4 to Mr. Larkin's direct testimony and slides 11-13
of the March 14, 2019, presentation to the lRP Advisory Council (located via the
following link: https://www.idahopower.com/enerqv/planninq/inteorated-resource-plan0
for the results of the 24 LTCE buildouts for the 2019 IRP that included B2H where the
Jackpot Solar and Franklin Solar projects were selected as resources. Each LTCE
buildout identifies the future conditions and resource decisions that would need to exist
for the solar projects to be cost-effective. Additionally, ldaho Power's preferred
portfolio, P14, includes both the Jackpot Solar and Franklin Solar projects.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF. T
REQUEST NO. 4: ln reference to Mr. Larkin's direct testi mony on page 18
where he states, "The results of the LTCE modeling show a high correlation of new
solar resources in 2022 and 2023 with a Jim Bridger unit retirement in 2022." ln
examining published results thus far in the IRP process, 6 of the portfolios that retire a
Bridger unit later than 2022 do not include either of the two solar PPAs (P21, P22, P23)
or possibly only includes one of them (P5, P9, P10), suggesting that a later retirement of
a Bridger unit makes the Jackpot Solar and Franklin Solar Facilities less economically
viable. Please respond to the following:
a. lf the Company chooses to retire a Bridger unit later than 2022, what
conditions need to exist and at what point in time does the first unit need to retire to
make the solar PPAs consistently cost effective?
b. Please provide all Jim Bridger retirement assumptions used as inputs in
the LTCE modeling for each of the 24 scenarios. This should include but not be limited
to: the individual units available for retirement, the date range the units are available for
retirement, the nameplate capacity, and all fixed and variable cost assumptions.
c. Please provide justification why the chosen Jim Bridger retirement
assumptions used in the LTCE modeling are reasonable.
RESPONSE TO REQUEST NO. 4:
a. As described in the Company's response to Staffs Request No. 3.a, the
selection of a resource in AURORA is dependent on the need for capacity due to load
growth or unit retirements. The cost-effectiveness of the contracts is not solely
dependent on the retirement of Jim Bridger coal units. Rather, the model evaluates the
comprehensive need for additional resources, with the retirement of Jim Bridger and the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. S
addition of contracts as two potential options. The Company has not performed an
analysis that specifically isolates the relationship between the retirement of the Jim
Bridger units and the selection of the solar PPAs.
b. This information is provided in the Company's response to Staff's Request
No. 2.
c. The earliest Jim Bridger unit retirement date of 2022 is based on the
earliest date that ldaho Power believes it could reasonably evaluate system impacts,
take steps to mitigate negative impacts, and negotiate and coordinate with partners and
regulators the exit of a Jim Bridger coal unit.
The modeling of possible early exit dates of the remaining units (Unit 2 could
retire starting in 2024, Unit 3 in 2026, and Unit 4 in 2028) were intended to reflect a
feasible exit. Because of the need for flexible ramping capacity needs, removal of Jim
Bridger units needs to be carefully evaluated due to potential heightened concerns with
meeting regulating reserve requirements following their removal.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
REQUEST NO. 5: ln reference to Production Request Nos. 3 and 4 above, if the
Company moves forward with the B2H transmission line and if the retirement of the first
Bridger unit happens in the 2026 timeframe, what conditions would need to exist for the
Jackpot Solar and Franklin Solar Facilities to be consistently cost effective?
RESPONSE TO REQUEST NO. 5: Please refer to the Company's responses to
Staffs Request Nos. 3 and 4.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1O
REQUEST NO. 6: For the planning gas/planning carbon scenario, portfolios 13,
14, 17 , and 18 are the lowest net present value portfolios. Three of these portfolios do
not include the Jackpot Solar PPA projects, please explain why these lowest cost
portfolios did not include the Jackpot Solar PPA.
RESPONSE TO REQUEST NO. 6: The Com pany addresses the LTCE
modeling and resource selection for the portfolios in its responses to Staffs Request
Nos. 2, 3, and 4.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
REQUEST NO. 7: Has the Com pany performed any analysis similar to the "with
and without" Jackpot Solar analysis described in Mr. Larkin's direct testimony on pages
14-15 based on the 2019 IRP assumptions? For example, selecting top ranking 2019
IRP portfolios, and running the portfolios "with Jackpot Solar" forced into the model and
"without Jackpot Solar" forced out of the model, over a range of gas/carbon to compare
how Jackpot Solar impacts the portfolio simulations. lf any analysis like this has been
performed, please provide the work papers and results of the analysis.
RESPONSE TO REQUEST NO. 7: No additional analysis has been performed
on the Jackpot Solar PPA using the 2019 !RP. Because the solar PPA was included as
a resource option in the LTCE modeling for the 2019lRP, the Company did not perform
any additional model runs in which it forced Jackpot Solar either in or out.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 12
REQUEST NO. 8: For portfolio simulations nos. 5, 9, and 10, the results reflect
100 MW of solar in year 2023. Does this represent the Franklin Solar facility, or
something else? Please explain.
RESPONSE TO REQUEST NO.8: Yes, the 100 MW of solar shown in any
portfolio in year 2023 is the Franklin Solar facility.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
REQUEST NO. 9: Please provide the financial and operating characteristics of
the Jackpot Solar PPA that were included in the AURORA New Resource Table
mentioned in Mr. Larkin's direct testimony on lines 24-25 on page 16.
RESPONSE TO REQUEST NO. 9: This information is included in Attachment 1
provided with the Company's response to Staffs Request No. 2. The Jackpot Solar and
Franklin Solar information is found on the "Aurora New Resources" tab and labeled as
"ldaho Solar 1" and "ldaho Solar 2."
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
REQUEST NO. 10: The Application on page 6 reads "the PPA allows the Seller
an adjustment of Estimated Monthly Net Output Amounts by the 25th day of the
preceding month." With the potential for a larger impact to load and resource balance
than the PURPA contracts that have been approved with a S-day notice to adjust
monthly generation estimates (Order No. 34263), and with no historic power production
data, please explain the potential costs and risks of replacing the shortfall that could
occur between projected monthly output and delivered energy.
RESPONSE TO REQUEST NO. 10: The date by which Jackpot Solar can
submit an adjustment of Estimated Monthly Net Output Amounts does not change the
manner and process used by ldaho Power to estimate future generation from the
Jackpot Solar facility. As with any new renewable generation project delivering
electricity to ldaho Power pursuant to a PPA or a Public Utility Regulatory Policies Act of
1978 ("PURPA") Qualifying Facility ('QF') Energy Sales Agreement ("ESA'), the
Company will have 12 months of Estimated Monthly Net Output Amounts from the
project's PPA and will utilize the same processes currently in place to make estimates
of generation from a monthly basis through real-time operations.
Unlike an ESA with a PURPA QF, the Jackpot Solar PPA contains provisions for
guaranteed amounts of generation output on a monthly basis and liquidated damages
must be paid if an output shortfall occurs as described in the PPA. These provisions
ensure that the initial Estimated Monthly Net Output Amounts are reasonable and
consistent with a solar production facility the size of Jackpot Solar and that future
adjustments to Estimated Monthly Net Output Amounts are reliable.
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. 15
REQUEST NO. 11: Please provide a copy of the executed Generator
lnterconnection Agreement for the 120 MW Jackpot Solar Facility mentioned on page 7
of the Application.
RESPONSE TO REQUEST NO. 11: Please see the confidential PDF provided
on the confidential CD.
The confidential CD will be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Jeremiah Creason, Operations
Analyst Il, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 16
REQUEST NO. 12: Please provide the estimated annual hourly production data
for the Jackpot Solar and Franklin Solar Facilities. lf an estimated peak hour capacity
value has been calculated for either facility, please provide the value, along with how
the value was calculated.
RESPONSE TO EST NO. 12:Please see the Excel file provided on the
non-confidential CD for annual hourly production data provided by Jackpot Solar.
Estimated peak hour contribution to peak values of 42 percent for the Jackpot
Solar facility and 33 percent for the Franklin Solar facility were calculated based on the
National Renewable Energy Laboratory 8760 methodology presented by ldaho Power
during the December 13, 2018,1RP Advisory Council meeting for the 2019 IRP.
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 - 17
REQUEST NO. 13: Please explain iflhow ldaho Power intends to pass costs
and/or benefits of Liquidated Damages for Output Shortfall on to customers.
Agreement, Section 7.12, page 40.
RESPONSE TO REQUEST NO. 13: Liquidated damages for output shortfalls
reduce the amounts ldaho Power pays for energy purchased from the seller. The net
amounts paid to sellers is recorded in purchased power expense Federal Energy
Regulatory Commission ("FERC") Account 555 and passed on to customers through
ldaho Power's Power Cost Adjustment ('PCA') mechanism.
The response to this Request is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
REQUEST NO. 14: Lines 16-17 of Mr. Larkin's direct testimo ny on page 10
discuss the additional 100 MW of Franklin Solar being "contingent upon the Generator
lnterconnection Agreement (GlA) process for the additional 100 MW and the outcome of
additional analyses." Please provide an update on the status of the GIA process. Also
provide any additional analyses the Company has completed on the Franklin Solar
option and include an explanation of the new analyses.
RESPONSE TO EST NO. 14:The GIA process for the additional 100 MW
is currently in the system impact study phase. The 100 MW is being studied for both
interconnection as a network resource as well as any required upgrades for the
associated network transmission service reservation. The system impact study results
are due on or before August 19,2019. This information will give initial and high-level
cost and feasibility information regarding any necessary facilities and upgrades to
interconnect the additional 100 MW and have it designated as a network resource to
serve ldaho Power load.
There are no additional financial analyses that have been conducted beyond that
which were described in the Company's Application and the Direct Testimony of
Matthew T. Larkin.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 19
REQUEST NO. 15: Mr. Larkin's direct testim ony lines 24-25 on page 10 states
the option to purchase the additional 100 MW of the Franklin Solar facility expires on
September 1,2019, unless otherwise agreed.
a. Has an agreement been made to differ from the September 1,2019 date?
b. When does the Company plan on making a decision on exercising this
option?
c. What factors and analysis are pending to evaluate this option? Please
explain and provide any analysis completed.
RESPONSE TO REQUEST NO. 15:
a. No.
b. The Company plans to make a final decision on exercising the option prior
to September 1,2019.
c. As stated in ldaho Power's response to Staff's Request No. 14, the
system impact study results for the network resource interconnection and network
transmission service reservation for the additional 100 MW are due on or before August
19,2019. This information will give initial and high-level cost and feasibility information
regarding any necessary facilities and upgrades to interconnect the additional 100 MW
and have it designated as a network resource to serve ldaho Power load. Because the
additional 100 MW identified as Franklin Solar was not part of the initial offer, but arose
midway through contract negotiations, it is expressed as an option in the PPA. Section
8.3.1 of the PPA states, "Contingent upon the Generator lnterconnection Process for
Franklin Solar . and the outcome of additional analysis, as we!! as the mutual
agreement of the Parties, Buyer fldaho Power] shall have the right at its option to
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.20
purchase an additional 100 MW of Expected Nameplate Capacity identified as Franklin
Solar. . . ."
ldaho Power has done the same financial analysis for both the 120 MW and the
additional 100 MW, both of which show similar results with customer benefits. Once the
interconnection and transmission service request study results are obtained, and the
estimated cost of any necessary facilities and upgrades is known, ldaho Power and
Jackpot Holdings, LLC ("Jackpot") will need to mutually agree that ldaho Power wishes
to purchase and that Jackpot can build the additional 100 MW at the price and schedule
set forth in the PPA.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 21
REQUEST NO. 16: Has the Company calculated an estimated value for the sale
of Renewable Energy Certificates (RECs) mentioned in Mr. Larkin's direct testimony
lines 6-7 on page 16? lt so, please provide the value and work papers used to calculate
the RECs value.
RESPONSE TO REQUEST NO. 16: No.
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 - 22
REQUEST NO. 17: Please provide all workpapers and spreadsheets (with
calculations and links enabled) used to develop Exhibits 4 and 5, any cost-benefit
analysis to customers, and all other analyses performed.
RESPONSE TO REQUEST NO. 17: Exhibit 4 of the PPA contains the initial
Estimated Monthly Net Output Amounts provided by Jackpot Solar. These are the
latest values provided by Jackpot Solar prior to the PPA being executed. This is
provided as Attachment 1 on the non-confidential CD.
Exhibit 5 of the PPA contains the contract prices as negotiated and agreed to by
the parties to the PPA. As stated in Mr. Larkin's direct testimony, Jackpot Solar offered
to seM20 MW of output starting at $21.7Slmegawatt-hour ("MWh') for the first year of
the contract and if the option facility is expanded by an additional 100 MW, the price
increases to $23.11lMWh for 220 MW over the first year. ln both price streams, the
parties agreed to escalate the initial prices annually by 1.5 percent, resulting in the
contract prices presented in Exhibit 5. This information is provided as Attachment 2 on
the non-confidential CD.
With regard to cost-benefit analysis, please see Idaho Power's responses to
Staffs Request Nos. 1 and 18.
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 - 23
REQUEST NO. 18: Please provide the economic analysis, with supporting
workpapers, which is stated in Larkin's Direct Testimony page 19 Line 9.
RESPONSE TO REQUEST NO. 18: The requested information is included in
the Excel file provided on the non-confidential CD.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Technical Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 24
REQUEST NO. 19: Please provide the net power cost change expected in the
PCA from the Jackpot Holdings PPA. What other cost changes are expected in the
PCA once Jackpot Holdings is included?
RESPONSE TO REQUEST NO. 19: Please see Exhibit No. 3 to Mr. Larkin's
direct testimony, which presents the cost-benefit analysis for the Jackpot Solar PPA.
Exhibit No. 3 shows the results of the 2017 IRP analysis and quantifies the benefits to
customers in the form of net power cost savings. There were three AURORA
simulations: a base run of the 2017 preferred portfolio, the 2017 preferred portfolio plus
120 MW of solar, and the 2017 preferred portfolio plus 220 MW of solar. As shown in
Exhibit No. 3, the results of the analysis indicate the addition of the Jackpot Solar PPA
are expected to result in a net customer benefit. However, actual savings to customers
through the PCA will not be determined until after the project is operating. At that time,
differences in the total net power supply costs will be passed through to customers
through the PCA. Aside from changes in net power supply expenses, the Company
does not expect the PCA to include any other cost changes not already discussed.
The response to this Request is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 25
REQUEST NO. 20: Please explain how the liquidated damages, when
appropriate, will be recorded, as mentioned in Section 7.12.2 of the Power Purchase
Agreement.
RESPONSE TO REQUEST NO. 20: Liquidated damages for output shortfalls
reduce the amounts ldaho Power pays for energy purchased from the seller. The net
amounts paid to sellers is recorded in purchased power expense FERC Account 555
and passed on to customers through ldaho Power's PCA mechanism.
The response to this Request is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
DATED at Boise, ldaho, this 20th day of June 2019.
NOVAN E R
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 26
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this 20th day of June 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
ldaho Public Utilities Commission
47 2 W est Wash ington Street (837 02)
P.O. Box 83720
Boise, ldaho 83720-0074
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.27
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
rry,