20210430IPC to Staff 1-3.pdf

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April 30,2021
VlA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, ldaho 83714
Case No. IPC-E-21-07
Reynolds lrrigation Hydro Project
ldaho Power Company'sApplication re the Energy SalesAgreement
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Response to the First
Production Request of the Commission Staff regarding the above entitled matter. lf you
have any questions about the attached document, please do not hesitate to contact me.
Very truly yours,
DONOVAN E. WALKER
Lead Counse!
dwal [e-mail]
DEW:cld
Enclosures
:i; i Iif'R 30 PH 3: ?9
Donovan E. Walker
2dalQ
Re
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO PO\A'ER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
REYNOLDS IRRIGATION DISTRICT, FOR
THE SALE AND PURCHASE OF ELECTRIC
ENERGY FROM THE REYNOLDS
IRRIGATION HYDRO PROJECT.
CASE NO. !PC-E-21-07
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
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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 April22,2A21, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
REQUEST NO. 1: Has the Maximum Capacity Amount for the facility been 300
kW since the construction of the project? lf not, when was the 300-kW step-up
transformer installed? ln addition, please list the capacities of al! former transformers and
when they were installed.
RESPONSE TO REQUEST NO. 1: Yes, the Maximum Capacity Amount for the
Reynolds lrrigation Hydro Project ("Project") has been 300 kilowatts ("kW') since the
facility was originally constructed. As described in Appendix B of the Energy Sales
Agreement ("ESA") between ldaho Power and the Reynolds lrrigation District that was
executed on March 31,2021,
The originalfirm energy sales agreement was signed on April
1, 1985 but the project did not start generating electricity until
May 1986. The description of the facility in the 1985
agreement calls for a single GE induction generator with a
nameplate rating of 270 kW. However, at the time of
construction, a generator with a 350 kW nameplate was
installed. In February 2021, a representative of Reynolds
lrrigation District who has been with the district since before
1986, confirmed that the generator at the project is the original
350 kW generator installed in 1986. The generator step-up
transformer is rated at 300 kW so the generator nameplate is
reported as 350 kW and the Maximum Capacity Amount is
300 kW because of the transformer limitation.
The 300 kilowatt ("kW') transformer was manufactured in October 1985 and
installed at the same time that the 350 kW generator was installed in 1986. The 1985
Reynolds lrrigation Firm Energy Sales Agreement does not state a Maximum Capacity
Amount. Based on the transformer and generator ratings that were installed in 1986 and
the information from the Chairman of the Board of Reynolds lrrigation District, the
project's capacity has been 300 kW since 1986.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST NO. 2: Page 39 of the Energy Sales Agreement states that the First
Energy Date and the Operation Date for this Agreement will be at hour beginning 00:01
on May 1, 2021, provided that the Commission approves the replacement Agreement,
and the Seller completes all of the Article lV and Article V requirements prior to May 1,
2021. Please confirm that the First Energy Date and the Operation Date in the statement
should have been the Scheduled First Energy Date and the Scheduled Operation Date.
RESPONSE TO REQUEST NO. 2: The title of Appendix B-3 on page 39 of the
Energy Sales Agreement ("ESA") between ldaho Power and the Reynolds lrrigation
District is "Scheduled First Energy Date and Operation Date". A First Energy Date is
normally needed for a new project under an original ESA in order to go online, perform
testing and ensure proper operation before requesting an Operation Date. Because this
ESA is a replacement agreement for an existing project, it is anticipated that the expiration
of the previous contract and the First Energy Date and Operation Date of the replacement
ESA will occur simultaneously. However, as this ESA will not be approved or rejected by
the ldaho Public Utilities Commission ("Commission") by the Scheduled First Energy Date
and Operation Date identified in Appendix B-3, ldaho Powerwill be unable to grant a First
Energy Date or Operation Date as described in Article lV and Article V of the ESA until
such time as the ESA has been approved by the Commission.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMIS$ON STAFF - 3
REQUEST NO. 3: The original contract will expire April 30, 2021. The Scheduled
First Energy Date and the Scheduled Operation Date is May 1 ,2021. Given that a final
order is unlikely to issue in this proceeding by May 1,2021. Please answer the following
questions:
a. Appendix B of the ESA states that ldaho Power cannot accept or pay for
generation from this Facility if the Facility has not achieved the status of being an ldaho
Power Designated Network Resource (DNR). This Facility is an ldaho Power DNR
pursuant to an existing energy sales agreement. The DNR status will continue if this
Agreement is 1) executed and approved by the Commission, 2) a Generator
lnterconnection Agreement ('GlA') has been executed by both parties and, 3) the Seller
is in compliance with all requirements of that GlA. Please answer the following questions:
3.a.1. Will the QF be designated as a DNR between May 1, 2021 and
Commission approval of the ESA?
3.a.2. Will ldaho Power accept generation from this Facility during this period?
3.a.3. \Mll ldaho Power pay for generation from this Facility during this period?
b. ls the QF planning to deliver energy between May 1 ,2021 and the actual
Operation Date granted by ldaho Power after the Commission approves the ESA?
c. Have the parties agreed to the rates the Seller will receive for energy
generated and delivered to ldaho Power between May 1 ,2021 and the actual Operation
Date granted by ldaho Power after the Commission approves the ESA? lf so, please
provide the agreement between the QF and the Company.
RESPONSE TO REQUEST NO. 3:
3.a.1. Yes, the Reynolds lrrigation Hydro Project will be a Designated Network
Resource ("DNR') between May 1, 2021, and ldaho Public Utilities Commission
("Commission") approval or rejection of the Energy Sales Agreement ("ESA") between
ldaho Power and the Reynolds lrrigation District.
3.a.2.ldaho Power has agreed to accept generation from the Reynolds lrrigation
Hydro Project during the interim period of May 1,2021, and when the Commission either
approves or rejects the ESA.
3.a.3. Yes, ldaho Power has agreed to purchase generation provided by the
Reynolds lrrigation Hydro Project during the interim period of May 1,2021, and when the
Commission either approves or rejects the ESA at the Surplus Energy Price as defined
in Article 7 .2 ot the ESA.
b. Yes.
c. Yes, please see the attached letter agreement.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader of ldaho Power Company.
DATED at Boise, ldaho, this 30th day of Apral2021.
O*,€a&/4-
DONOVAN E. WALKER
Attorney for Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 3Othday of April 2021, ! 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:
Dayn Hardie
Idaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Jerry Hoagland
Reynolds lrrigation District
P.O. Box 12
Melba, ID 83641
_Hand Delivered
_U.S. Mail
_Overnight Mai!
_FAXX Email Dayn Hardie
davn. ha rd ie@puc. idaho.qov
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email Jerry Hoagland,
[e-mail]
Christy Davenport, Legal Assistant
ntDilos!FoirER"
An DICORP Comp.ny
RE
April29,202l
Bmd Huf{, Jerry Hoagland
Reynol ds Irrigation Diskict
P.O. Box 12
Melba" ID 83641
MA: E-mail Copy: Brad Huff, bhufD@.speedyquick.net; Ierry Hoagland. shrjhwhy@.gmail.corn
Reynolds lrrigation Hydro Project
I*trcr Agrcanent - As-Delivercd Generation
Project Contract Number 21415120
Dear Brad and Jerry,
Idatro Powcr Company ("Idaho Power" or'the Corrpany') and Reynolds Irrigation District ("Seller')
entered into a replacerrent Energy Sales Agreement ("ESA') on March 31,2021. The ESA replaces an
expiring contract that the Seller's Reynolds Irigation Hydro Project ('?roject') has delivered
generation under for thirly-five (35) y€ars. In accordance with Article 2l.l of the ESA, "This
Agreement shall only bccsme finally effective upon the ldaho Public Utilities Commission's
("Commission") approval of all tcrms and provisions hereof without change or condition and
declaration that all payrrerrts to be made to Seller hcreundcr shall be allowcd as pnrdeirtly incurred
exponscs for rateuraking purposes."
Due to the timing of when the ESA was fully orecuted by both parties and srrbmittedto ttre
Cornrnission for its approval or rejection of the ESA, it is not possible for the Commission to complete
its review of the ESA before the existing agreement expires and the replacerrent ESA's First Energy
Date is scheduled to ocqr (May l, }AZD. However, due to operational circumstances, and that the
existing facility has delivered generation to Idaho Power for 35 years, and that Seller has entered into a
fully executed Generator Interconnection Agreemcnt with the Cornpany, Seller dcsires to continue
providing generation during the interim period from May l,2O2l, until such timc as thc Commission
has issued an order approving or rejecting the ESA ("Interim Period").
Therefore, pursuant to this letter agreement, Idaho Power will accept delivery of generation from ttre
Seller's facility from May l,2A2l, until the Commission has eittrer approved or rcjected the ESA. For
any generation dclivcred duing the Interim Period, tdatro Power shall pay the Surplus Energy Price a.s
defined in Article 7.2 of the ESA subject to any tnr€-up, adjusftnent, or rcjection of terms and
provisions. or the contract itsett, by the Commission.
P.O. Bor 70 (Er704
l22l W. ldaho 5t.
Boise, lD t3702
Page2 of?Apil29,2O2l
Idaho Power rcserv€s the rightto terminate ttris lerer agreement at any time. Should this tetter
agreement be terminated by the Company, Seller shall immcdiately stop making any deliveries of
geoeration to Idaho Power.
If you agee and accept this offer, please sign in the appropriate location below and retum a copy to me
no laterthan April 30,2021,atijardine@idahopower.c .
Understood...A. greg-d and Acc spted :
Reynolds lrrigetion Distrlct
By:
Print Name and Titlc:
Z Lo;.
Dated:4 /za,/zorr
Sincerely,
fu"1 /a,ultu
Energ5r Confracls