20210430IPC to Staff 1-4.pdf

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Donovan E. Walker
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An IDACORP Comparry
DONOVAN E. WALKER
Lead Counsel
[e-mail]
April 30, 2021
VIA 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-21-08
Elk Creek Hydro Project
ldaho Power Company'sApplication re the Energy SalesAgreement
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Response to First
Production Request of Commission Staff regarding the above entitled matter. If you have
any questions about the attached documents, please do not hesitate to contact me.
Very truly yours,
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Enclosures
DONOVAN E. WALKER (lSB No. 5921)
Idaho 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 POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
HYDROIAND OMEGA LLC, FOR THE
SALE AND PURCHASE OF ELECTRIC
ENERGY FROM THE ELK CREEK HYDRO
PROJECT.
CASE NO. !PC-E-21-08
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
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COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compary"), and in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated April 23, 2021, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF THE
COMMISSION STAFF .1
REQUEST NO. {: Please provide a copyof the 1984firm energysales agreement
that Hydroland Omega LLCaI (the'QF') has operated under.
RESPONSE TO REQUEST NO. 1: Please see the attached firm energy sales
agreement applicable to the Elk Creek Hydro project.
The response to this Request is sponsored by Michael Danington, Energy
Gontracts Leader of ldaho Power Company.
IDAHO POVI/ER COMPANYS RESPONSE TO THE FIRST PRODUCTION REQUESTS OF THE
COMMISSION STAFF .2
REQUEST NO. 2: Page 39 at B-3 of Appendix B to the Energy Sales Agreement
("ESA') 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 this section should be 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 Hydroland Omega LLC
is "Scheduled First Energy Date and Operation Date". A First Energy Date is normally
needed for a new project under an origina! 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
Idaho Public Utilities Commission ("Commission") by the Scheduled First Energy Date
and Operation Date identified in Appendix B-3, ldaho Power will 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 REQUESTS OF THE
COMMISSION STAFF - 3
REQUEST NO. 3: The 1984 firm ene rgy sales agreement will expire on 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 be issued in this proceeding by May 1,2021.
Please answer the following questions:
a. Appendix B at page 38, Section B-7 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 Idaho Power Designated Network Resource ('DNR'). This
Facility is a Company DNR pursuant to an existing energy sales agreement. Section
B-7 also provides that" [t]he DNR status will continue if this Agreement is 1) executed
and approved by the Commission, and 2) a [Generator lnterconnection Agreement
('GlA')] has been executed by both parties and 3) the Seller is in compliance with al!
requirements of that GlA. Please answer the following questions:
i. Willthe QF be designated as a DNR between May 1 ,2021and Commission
approval of the ESA?
ii. \Mll ldaho Power accept generation from this Facility during this period?
iii. Wll ldaho Power pay for generation from this Facility during this period?
b. ls the QF planning to deliver energy to the Company after May 1 ,2021 even
if the Commission has not approved the ESA by that date?
c. Have the parties agreed to the rates the QF will receive for energy
generated and delivered to the Company between May 1, 2021 and the actual
Operation Date if the Commission approves the ESA after May 1,2021? lf so, please
provide the agreement between the QF and the Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF THE
COMMISSION STAFF -4
RESPONSE TO REQUEST NO. 3:
3.a.1. Yes, the Elk Creek Hydro Project will be a Designated Network Resource
('DNR') between May 1 ,2021, and Idaho 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 Elk Creek 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 Elk Creek
Hydro Project during the interim period of May 1,2021, and when the Commlssion either
approves or rejects the ESA at the Surplus Energy Price as defined in Article 7.2 of 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.
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUESTS OF THE
COMMISSION STAFF - 5
REQUEST NO.4: Section 6.2.1 of the ESA liststhe Monthly Estimated Net Energy
Amounts. Please explain why the generation amount is zero in months of January,
February, August, September, October, November, and December.
RESPONSE TO REQUEST NO.4: The Monthly Estimated Net Energy Amounts
are provided by Qualiffing Facilities ('QF") when an Energy Sales Agreement ("ESA") is
being developed and negotiated between ldaho Power and the QF. They are the project's
own estimates of generation deliveries during the months of each calendar year. ln the
ESA between Idaho Power and Hydroland Omega LLC for the Elk Creek Hydro Project
("Project"), the Project has indicated that it does not intend to provide generation during
the months of January, February, August, September, October, November, and
December. This is consistent with historical generation provided by the Project under the
expiring firm energy sales agreement. According to Article 6.2 of the ESA, after the
Operation Date the Project may adjust future Monthly Estimated Net Energy Amounts if
it intends to deliver different amounts of monthly generation than what are listed in the
ESA.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader of ldaho Power Company.
Respectfully submitted this 30th day of April 2021.
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DONOVAN E. WALKER
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 30th day of Apr.l2021, I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TO THE
FIRST PRODUCTION REQUESTS OF THE COMMISSION STAFF upon the following
named parties by the method indicated below, and addressed to the following:
John R. Hammond, Jr.
Deputy Attomey General
Idaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Pete Blanchfield
Hydroland Omega LLC
403 Madison Ave. North #240
Bainbridge lsland, WA 98110
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email John R. Hammond
iohn. hammond@puc. idaho.qov
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email Pete Blanchfield,
pete@ hvd rolandcorp. com
Christy Davenport, Legal Assistant