20201008IPC to Staff 1-4.pdf

RECEIVED
2020 October 08 AMl1:19
IDAHO PUBLIC
UTILITIES COMMISSION
rem.
An IDACORp Company
DONOVAN E. WALKER
Lead Counsel
dwal [e-mail]
October 8,2020
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretiary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 2O1-A
Boise, ldaho 83714
Re Case No. IPC-E-20-34
Shawpatin AgCap, LLC/Mud Creek White Hydro Project
ldaho Power Company's Application Regarding the Energy Sales Agreement
Dear Ms. Noriyuki:
Aftached for electronic filing is ldaho Power Company's Response to the First
Production Request of the Commission Staff in the above entitled matter. lf you have any
questions about the attached documents, please do not hesitate to contact me.
Very truly yours,
Zddtl<-
Donovan E. Walker
DEW:cld
Enclosures
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa lker@ idahopower.com
Aftorney 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
SHAWPATIN AGCAP, LLC, FOR THE SALE
AND PURCHASE OF ELECTRIC ENERGY
FROM THE MUD CREEK WHITE CREEK
HYDRO PROJECT.
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CASE NO. IPC-E-20-34
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Powef or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated September 18,2020, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUESTS OF THE COMMISSION STAFF - 1
REQUEST NO. 1: The nameplate capacity of Mud Creek White Hydro Project
stated in the Energy Sales Agreement is 268.6 kW. However, the Company's Quarterly
Cogeneration and Small Power Production Report ending March 31,2020 shows that the
nameplate capacity is 205 kW. Please explain and reconcile the difference.
RESPONSE TO REQUEST NO. 1: ldaho Power's Quarterly Cogeneration and
Small Power Production Report lists a legacy value of 205 kW for the Mud Creek White
Hydro Project based on a May 30, 1984, intra-company memo (provided as Attachment
1 to this Request) relating to interconnection studies applicable to the Mud Creek White
Hydro Project.
The total nameplate capacity of 268.6 kW for the facility as listed in the
replacement Energy Sales Agreement ('ESA") is based on documentation provided by
the project as part of the replacement ESA process. The facility has two generator units-
-one is identified as223.8 kW and the other is 60 hp, which is equivalent to approximately
44.75 kW, bringing the total to 268.6 kW. Photos of the actual nameplates associated
with the facility are provided as Attachment 2 to this Request.
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 REQUESTS OF THE COMMISSION STAFF - 2
REQUEST NO. 2: The nameplate capacity described in the 1985 contract was
178 kW. Please list all the nameplate changes throughout the history of the project and
discuss actions taken by the Company, including amending the contract, obtaining
approval of a new contract, etc. Please provide documentation or other forms of evidence
for actions taken.
RESPONSE TO REQUEST NO. 2: The nameplate capacity as Iisted in the
original 1985 Firm Energy Sales Agreement was revised pursuant to an updated
Appendix B dated September 26,1985, that had provisions allowing for a total nameplate
capacity of up to 308 kW. (See attached revised Appendix B).
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 REQUESTS OF THE COMMISSION STAFF - 3
REQUEST NO. 3: Please provide the project resource capacity contribution in the
Ioad and resource balance during the last five Company lntegrated Resource PIans, and
how was the contribution determined? Please provide any calculations in Excel format
with formula enabled.
RESPONSE TO REQUEST NO. 3: Please see the attached confidential Excel
file.
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 REQUESTS OF THE COMMISSION STAFF - 4
REQUEST NO. 4: Please provide all available hourly generation data for the
project. For periods when hourly generation data is not available, please provide the data
for the smallest time interval available.
RESPONSE TO REQUEST NO.4: ldaho Power does not have hourly generation
data for the Mud Creek White Hydro Project under the original 1985 Firm Energy Sales
Agreement ('FESA'). The attached confidential Excel file contains historical monthly
generation data based on end-of-month meter reads as required by the FESA and
provided by the project.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
Respectfully submitted this 8th day of October 2020
fuzdat4-
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUESTS OF THE COMMISSION STAFF - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8th day of October 2020, I served a true and
correct copy of the within and foregoing 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:
Leslie lversen
P.O. Box 446
Twin Falls, lD 83303
208-293-9110
_Hand Delivered
_U.S. Mail
_Ovemight Mail
_FAXX Email
ShawpatinAq Cap@qma i l. com
Commission Staff
Matt Hunter
Deputy Attomey General
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX Email [e-mail]
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUESTS OF THE COMMISSION STAFF - 6