20191218IPC to Staff 1.pdf

3Effi
An TDACOPP ComDarry
TTECEIVED
:0i9 Otc t8 PH 2: 35
OONOVAN E. WALKER
Lead Counlel
[e-mail]
l(-
,t SSION
December 18,2019
ELECTRONICALLY FILED
Diane M. Hanian, Secretary
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 837't4
Re Case No. IPC-E-19-35
Little Wood lrrigation District - Little Wood River Reservoir Hydro Project
ldaho Power Company's Response to the First Production Request of
Commission Staff
Dear Ms. Hanian:
Attached for filing in the above matter please find ldaho Power Company's
Response to the First Production Request of the Commission Staff.
truly yours,
Donovan E. Walker
DEWKh
Attachment
Very
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]'17
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
LITTLE WOOD IRRIGATION DISTRICT,
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE LITTLE
WOOD RIVER RESERVOIR HYDRO
PROJECT.
)
)
)
)
)
)
)
)
)
)
CASE NO. TPC-E-I9-35
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 December 4, 2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF . 1
REQUEST NO. 1: Order 32802 states that 'the appropriate and reasonable
definition of a "seasonal hydro" project is a hydro generation facility that produces at least
55% of its annual generation during the months of June, July, and August." According to
this definition, the Little Wood River Reservoir Hydro Project qualifies as a'seasonal
hydro" project, because the facility is estimated to produce 55.2% of its annual generation
during the months of June, July, and August. However, avoided costs for non-seasonal
hydro projects are used in the Agreement, Please explain why avoided costs for seasonal
hydro projects are not used.
RESPONSE TO REQUEST NO. 1: The Little Wood River Reservoir Public Util itv
Regulatory Policies Act of 1978 ('PURPA) Qualifying Facility ("QF") has been selling
generation to ldaho Power under a PURPA Energy Sales Agreement f ESA') since '1985
that expires on February 29, 2020. On April 3, 2019, the Company received a Schedule
73 Qualifying Facility Energy Sales Agreemenl Application ("Application") for a
replacement ESA applicable to the QF. The Application requested nonJevelized prices
for a "hydro" QF but did not specify whether it wanted seasonal or non-seasonal hydro
published avoided cost prices. ldaho Power provided the QF with a link to the seasonal
and non-seasonal published avoided cost prices and provided an explanation of how a
project could qualify for the seasonal hydro published avoided cost prices.
A hydro QF that is eligible for published avoided cost rates is free to choose
seasonal or non-seasonal pricing at its sole discretion. lf a QF chooses to request an
ESA with seasonal prices, the QF must produce at least 55 percent of its annual
generalion during the months of June, July, and August, based on actual deliveries of
generation and not the estimates of generation provided by the QF.
ldaho Power reviewed the historical generation that the QF has been delivering to
ldaho Power and discovered that the QF would not comply with the requirements of an
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF .2
ESA containing seasonal hydro published avoided cost prices on an ongoing basis
without making changes to the operation of the facility. ldaho Power contacted the QF
and discussed the seasonal hydro and non-seasonal hydro options and the QF elected
to move fomrard with non-seasonal hydro prices. The QF confirmed in writing by letter
dated May 1, 2019, (Attachment 1 to this response), that ldaho Power "proceed with
preparing a draft Non-Seasonal Hydro ESAforthe Project."
The Company and the QF fully executed the ESA containing non-seasonal hydro
published avoided cost prices on Oc{ober 15, 201S, and submitted it to the ldaho Public
Utilities Commission ("Commission') on November 8, 2019.
When ldaho Power received Commission Straffs Production Request No. 1, ldaho
Power called the QF's Project Manager on December 9, 2019, and again discussed the
seasonal and non-seasonal hydro price options. During that call, the QF Project Manager
re-stated the QF's desire to continue with the non-seasonal hydro ESA that is currently
under review by the Commission. Attachment 2 to this response is an email string dated
December 9 and 10, 2019, confirming that the QF wants to continue with a non-seasonal
hydro ESA.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
DATED at Boise, ldaho, this 18th day of December 2019.
E. WALKER
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
GERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18h day of December 2019, I served a true and
conec't copy of the within and foregoing IDAHO POWER COMPANYS RESPONSE TO
THE FIRST PRODUCTION REQUEST OF COMMISSION STAFF upon the following
named parties by the method indicated below, and addressed to the following:
Commission Stafr
Dayn Hardie
Depu$ Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
_Hand Delivered
_U.S. Mail
_Ovemight Mail
_FAXX Email [e-mail]
Llttle Wood lnigation Dittsict
Bretl Van Wagoner
P.O. Box 5083
Twin Falls, ldaho 83303
_Hand Delivered
_U.S. Mail
_Ovemight Mail_FN(X [e-mail]
[e-mail] Peck
20478 N Main Street
Carey, ldaho 83320
0
Ki Towel Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. !PC-E-19-35
IDAHO POWER COMPANY
ATTACHMENT 1
Little Wood Rivor lrrigation District
Little Wood River Hydro
c/o Brttt Vrn Wegoner
P. O. Box 5083
Twin Falls, Idsho 83303-5083
May 1,2019
Jerry Jardine
Power Supply Planning
ldaho Power Company
P. O. Box 70
Boise, ldaho 83707
Re: Little Wood Hydroelectric Project, ProjectNo.31615105, Schedule 73 Application
Dear Mr. Jardine:
We are in receipt of your letter dated April 18, 2019 regarding our application form for a
Schedule 73 Cogeneration and Small Power hoduction Schedule- Idaho.
We have reviewed the "current indicative pricing" that was attached to your letter and would like
you to proceed with preparing a draft Non-Seasonal Hydro ESA for the Project. We understand that
there will be a rate change prior to the final Agreement.
Pleasc feel free to call me at 208-736-7363 if you have questions-
Sincerely,
S\M
Brett Van Wagoner, Project Manager
Little Wood Reservoir Hydro
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. !PC-E-19-35
IDAHO POWER COMPANY
ATTACHMENT 2
Darrington, Michael
From:
Senti
To:
Cc:
Subject:
Brett Van Wagoner < [e-mail]>
Tuesday, December 10, 2019 12:09 AM
Jardine,.,erry
Danington, Michael
IEXTERNAL]Re: Little Wood River Reservoir Hydro Project ESA
KEEP IDAHO POWER SECUREI Externalemails may request informatlon or contain malicious links or attachments. Verify
the sender before proceeding, and check for additional warning messages below.
.lerry,
Yes, please proceed with the Non-Seasonal Energy Sales Agreement ("ESA') that was fully executed on October 15,
2019.
Thank you,
Brett Van Wagoner, Project Manager
Little Wood Hydro
on Mon, Dec 9, 2019 at 3:59 PM Jardine, lerry <[e-mail]> wrote:
8re$ Van Wagoner
Little Wood River Reservoir Hydro Proiect Manager
B rett,
Michael Darrington and I wanted to follow-up on our phone conversation this afternoon about the Non-Seasonal
Energy Sales A8reement ("EsA") that was fully executed on october 15, 2019 and sent to the ldaho Public Utilities
Commission ("lPUC") on November 8, ?019 for their review. During our phone conversation today, we discussed the
requirements for Seasonal Hydro and Non-Seasonal Hydro rate contracts that are the Sellers option to select and at the
end of our conversation you elected to continue with the Non-Seasonal Hydro ESA that is currently being reviewed by
the tPUc.
Could you please reply to this email and confirm that you would like to continue to proceed with the Non-Seasonal
Hydro ESA for the Little Wood River Reservoir Hydro Project.
Thank you,
I
Jerry Jardine
Energy Contracts
ldaho Pow€r Company
IDAHO POWER tEGAt DISCTAIMER
This transmission may contain information that is privileged, confidential and/or exempt from disclosure
under applicable law. lf you are not the intended recipient, you are hereby notified that any disclosure,
copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY
PROHIBITED. lf you received this transmission in error, please immediately contact the sender and destroy
the material in its entirety, whether in electronic or hard copy format. Thank you.
2