20200623Staff 6-24 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 l4
IDAHO BAR NO. 10446
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Street Address for Express Mail:
1133I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER'S
PETITION TO ESTABLISH AVOIDED COST
RATES AND TERMS FOR ENERGY
STORAGE QUALIFYING FACILITIES
UNDER PURPA
CASE NO.IPC-E-20-02
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that ldaho Power Company (Company) provide
the following documents and information as soon as possible, or by TUESDAY,
JULY 14,2020.
This Production Request is continuing, and the Company is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may later
obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
SECOND PRODUCTION REQUEST
TO IDAHO POWER
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In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 6: How many requests for indicative pricing has Idaho Power received for
energy storage QFs?
REQUEST NO. 7: How many IRP-based solar QFs and wind QFs have signed ESAs since
the Commission reduced the IRP-based contract term to two years? How many solar QFs and wind
QFs have signed published ESAs since the Commission reduced the IRP-based contract term to two
years? What other factors, in addition to the reduced contract term, likely contributed to this
amount of wind and solar QF contracts being executed with the Company?
REQUEST NO. 8: Please provide all indicative pricing furnished to QFs for lRP-based
rates for the last ten years.
REQUEST NO. 9: What are the standard contract terms currently included in a published
contract for projects under the applicable eligibility cap? Please provide a standard published
contract for wind QFs, solar QFs, and all other QFs. Please describe any and all changes to the
standard contract terms over the last ten years.
REQUEST NO. 10: What are the standard contract terms included in ESAs for QFs above
the applicable eligibility cap? What contract terms are typically subject to negotiation between QFs
and the Company for QFs above the applicable eligibility cap? Please provide an ESA that serves
as the starting point for negotiations with wind QFs, solar QFs, and all other QFs above the
respective eligibility caps.
REQUEST NO. 11: Other than the rates and the contract term, what are common
differences between ESAs for projects above the applicable project eligibility cap and projects
below the applicable project eligibility cap?
RE,QUEST NO. 12: Where and how can a QF developer locate a standard ESA?
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 JLINE 23,2020
REQUEST NO. 13: l8 C.F.R $ 292.302 requires electric utilities such as Idaho Power to
provide to their state commissions such as the Idaho Public Utilities Commission, and maintain for
public inspection, the data from which avoided costs may be derived and the estimated avoided cost
on the electric utility's system'oon a cents per kilowatt-hour basis, during daily and seasonal peak
and off-peak periods, by year, for the current calendar year and each ofthe next 5 years[.]" l8
C.F.R. 5 292.302 also requires the electric utility to file its plan for the addition of capacity and the
estimated capacity costs and planned capacity firm purchases for the next 10 years. In what format
does the Company file this with the Commission and where does the Company make this
information publicly available? Please describe how the Company complies with this provision.
REQUEST NO. 14: Please describe how the model used to calculate IRP-based rates
values energy produced by a QF based on the time of day the energy is produced. Please describe
how the model used to calculate SAR-based rates values energy produced by a QF based on the
time of day the energy is produced.
REQUEST NO. 15: How many hours during 2018 and for 2019 and what percentage of
the time for each year was the Langley Gulch CCCT plant used as a marginal resource in Idaho
Power's actual dispatch?
REQUEST NO. 16: If the ICIRP model is run for the first two years of a new contract,
how many hours of these two years and what percentage of the time is Langley Gulch CCCT plant
used as the marginal resource?
REQUEST NO. 17: Which wind or solar projects between 100 kW and 10 aMW were
approved between February 20,2008 and December 14,2010 when the eligibility cap was set to
lOaMW per month in Order No. 30488? In addition, please provide the following for each of the
projects:
a. The project names, case numbers, nameplate capacities, pricing methodologies, and
approved dates.
b. Identifu the wind and solar projects that were grandfathered with the prior eligibility
cap of 100 kW.
SECOND PRODUCTION REQUEST
TO IDAHO POWER -)JLINE 23,2020
REQUEST NO. 18: Which wind or solar projects between 100 kW and 10 aMW were
approved on or after December 14,2010 when the eligibility cap was set to 100 kW in Order
No. 32176? In addition, please provide the following for each of the projects:
a. The project names, case numbers, nameplate capacities, pricing methodologies, and
approved dates.
b. Identiff the wind and solar projects that were grandfathered with the prior eligibility
cap of 10 aMW per month.
REQUEST NO. 19: Please provide the model used to determine incremental cost IRP-
based avoided cost rates.
REQUEST NO. 20: Please provide indicative pricing based on the Black Mesa 1 and2
proposals.
REQUEST NO.21: Please provide the average difference between non-levelized, non-
fueled, published rates for the "other" SAR category and IRP-based avoided cost rates for a 10 MW
project over 20 years.
REQUEST NO. 22: Please describe any differences between contracts that fall under the
eligibility cap and those that are over the eligibility cap within the Company's Schedule 73
Contracting Procedures. Please include differences in information requirements including the
amount, resolution, and importance of specific information provided by a developer, and the
amount of resources in staff-hours required by the Company to process each step.
REQUEST NO. 23: Please provide the total actual cycle time (i.e. the amount of days from
the time a developer submits the Quali$ing Facility Energy Sales Agreement Application until the
ESA is signed by both the Company and the Developer) for each original contract (non-renewal
contract) developed under Schedule 73 Contracting Procedures established in Case No. IPC-E-14-24
that was under the eligibitity cap using published rates and for each contract that was over the
eligibility cap that used IRP-based rates. For each contract, please list the date that the initial
application was submitted and the date the contract was signed by both parties, the nameplate
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 JI-INE 23,2020
capacity of the QF and whether it was below the eligibility cap using published rates or over the
eligibility cap using IRP-based rates. Please put into spreadsheet format.
REQUEST NO.24: Please describe any differences and similarities between the output
characteristics of a battery QF and the output characteristics of each of the resources listed in the
'oothero'category of 20-year published rates (ie. Biomass, Biogas, Landfill Gas, Geothermal, Waste-
to-Energy, Non-fossil Fueled Cogen). For any differences, please indicate how it might change the
calculation of the avoided energy and/or capacity cost over the 2O-year contract period.
DATED at Boise,Idaho, this 23'>day ofJune 2020.
Edward J
Deputy General
i:umisc:prodreq/ipce20.2ejyyml prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER
(
5 JLINE 23,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF JUNE 2020, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
srAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-02, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. corn
CERTIFICATE OF SERVICE