20200723IPC to Staff 1-2.pdf

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July 23, 2020
ELECTRONIC FILING
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-19-38
South Forks Joint Venture - Sagebrush Hydro Project
ldaho Power Company's Application Regarding Energy Sales Agreement
Dear Ms. Hanian
Attached for electronic filing is ldaho Power Company's Response to the First
Production Request of the Commission Staff. Please handle the confidential information in
accordance with the Protective Agreement executed in this matter. lf you have any
questions about the attached documents, please do not hesitate to contact me.
Very truly yours,
DONOVAN WALKER
Lead Gounsel
dwal [e-mail]
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Attachments
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Donovan 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]
dwa lker@ idahopower. com
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 BIG
WOOD CANAL COMPANY FOR THE SALE
AND PURCHASE OF ELECTRIC ENERGY
FROM THE SAGEBRUSH HYDRO
PROJECT
CASE NO. |PC-E-19-38
IDAHO POWER COMPANY'S
RESPONSE TO FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
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COMES NOW, ldaho Power Company ("!daho Powe/' or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated July 9, 2020, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMM]SSION STAFF - 1
REQUEST NO. 1: Under ldaho Power's hourly methodology to establish the
proper rate, there will be two sets of contract rates for the period 2020 through 2025
depending on the amount of generation in each hour and whether or not it exceeds 430
kWh. Please explain how the Company plans to pay the QF when the amount of energy
in any given month is outside of the 901110 performance band and when there are hours
both above and below the 430 kWh threshold.
RESPONSE TO REQUEST NO. 1: As described in Article 7.1 of the Sagebrush
Hydro Energy Sales Agreement ('ESA"), Surplus Energy is defined as: (1) Net Energy
produced by the Seller's Facility and delivered to the ldaho Power electrical system during
the month which exceeds one hundred ten percent (110Yo) of the monthly Adjusted
Estimated Net Energy Amount for the corresponding month specified in paragraph 6.2,
or (2) if the Net Energy produced by the Seller's Facility and delivered to the ldaho Power
electrical system during the month is less than ninety percent (90%) of the monthly
Adjusted Estimated Net Energy Amount for the corresponding month specified in
paragraph 6.2, then all Net Energy delivered by the Facility to the Idaho Power electrical
system for that given month, or (3) al! Net Energy produced by the Seller's Facility and
delivered by the Facility to the ldaho Power electrical system prior to the Operation Date,
or (4) all monthly Net Energy that exceeds the Monthly Nameplate Energy. Article 7.2
describes the Surplus Energy Price as: for all Surplus Energy, ldaho Power shall pay to
the Seller the current month's Market Energy Reference Price or the applicable All Hours
Energy Price, whichever is lower.
The First Amendment to the ESA, Article 7.6, defines the All Hours Energy Price
as: the price to be used in the calculation of the Surplus Energy Price and Delay Price
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
shall be the monthly non-levelized All Hours Energy Price in Appendix E or F for
generation received up to 430 kW, and the All Hours Energy Price in Appendix H for
generation received between 431 and 575 kW for calendar years 2020-2025. For
calendar years 2026 through the remaining term of the ESA, the price to be used in the
calculation of the Surplus Energy Price and Delay Price shall be the monthly non-levelized
All Hours Energy Price in Appendix E or F.
Forcalendaryears 2020-2025, ldaho Powerwilldetermine an actualtotalAll Hours
Energy Price by multiplying the monthly total of hourly generation up to 430 kW by the
applicable All Hours Energy Price in Appendix E or F and by multiplying the monthly total
of hourly generation over 430 kW by the applicable Al! Hours Energy Price in Appendix
H. The sum of these payment amounts will be divided by the total generation received for
the month to calculate a single All Hours Energy Price based on actual generation and
ldaho Public Utilities Commission-approved avoided cost rates. As described in Article
7.2 of the ESA, ldaho Power shall pay to the Seller the current month's Market Energy
Reference Price or the applicable All Hours Energy Price, whichever is lower. During
calendar years 2026 through the remaining term of the ESA, the All Hours Energy Price
to be used in the calculation of the Surplus Energy Price shall be the monthly non-
levelized All Hours Energy Price in Appendix E or F. The payment to the QF will be the
monthly Surplus Energy amount multiplied by the applicable Surplus Energy Price.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST NO. 2: Please provide the hydrological data associated with the
water flows over the past five years and answer the following questions.
a. ldentify the years that have normal water conditions.
b. Provide the amount of generation in each hour from the Sagebrush QF
for the years that have normal water conditions.
c. lf such hydrological data are not available to identify normal water years,
please provide the amount of generation in each hour from the Sagebrush QF for
years 2018 and 2019.
RESPONSE TO REQUEST NO. 2: ldaho Power does not have data to provide
answers to subpart a. or b.
c. Please see the aftached Confidential Excel worksheet. Column B of the
worksheet contains the hourly net generation from Sagebrush Hydro. Negative values
represent net generation received by ldaho Power.
The response to this Request is sponsored by Michae! Darrington, Energy
Contracts Leader, ldaho Power Company.
DATED at Boise, ldaho, this 23rd day of July 2020
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23'd day of July 20201 served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
John R. Hammond, Jr.
Deputy Attomey General
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
_Hand Delivered
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FAX
XEmail [e-mail]
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5