20230530IPC to Staff 1-2.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

May 30, 2023

VIA ELECTRONIC MAIL

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-15
SISW LFGE Project
Idaho Power Company’s Application for Approval of First Amendment to
the Energy Sales Agreement

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the First and
Second Production Requests of the Commission Staff in the above-entitled matter. If you
have any questions about the attached documents, please do not hesitate to contact me.

Very truly yours,

Megan Goicoechea Allen

MGA:cld
Enclosures
RECEIVED
Tuesday, May 30, 2023 4:53:26 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST AND SECOND PRODUCTION REQUEST
OF THE COMMISSION STAFF – 1
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OF A FIRST AMENDMENT TO
THE ENERGY SALES AGREEMENT WITH
THE SISW LFGE PROJECT.
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-15

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST AND
SECOND PRODUCTION
REQUESTS OF THE
COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) to Idaho Power Company dated May 9, 2023, and the Second Production Request
of the Commission Staff to Idaho Power Company dated May 19, 2023, herewith submits
the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST AND SECOND PRODUCTION REQUEST
OF THE COMMISSION STAFF – 2
STAFF’S REQUEST FOR PRODUCTION NO. 1: The Energy Sales Agreement
allows a subsequent unit to be installed within sixty months of the Operation Date. Please
provide the original Operation Date and explain when the subsequent unit was installed.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 1:
The Operation Date of the generation units initially installed under the Energy
Sales Agreement was September 1, 2018. Thus, the 60-month timeframe for installation
of the additional unit, as described in Appendix B-1 of the Agreement, ends September
1, 2023. The Seller was initially targeting May 8, 2023, to begin operating the subsequent
generation unit but has adjusted that date to June 2, 2023. Idaho Power will update the
response to this Request if this date is delayed.
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning, and Coordination Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST AND SECOND PRODUCTION REQUEST
OF THE COMMISSION STAFF – 3
STAFF REQUEST FOR PRODUCTION NO. 2: According to page 39 (Appendix
B: Section B-1) of the ESA, the Energy Sales Agreement requires the Nameplate
Capacity rating and VAR Capability (both leading and lagging) of all generation units.
a. Please explain whether the Company requires these generator requirements to be
listed in the Contract and why?
b. Please provide the VAR Capability (both leading and lagging) of the two initially
installed generation units (1.307 MW/each).
c. Please provide the VAR Capability (both leading and lagging) of the subsequent
or 3rd generation unit (1.307 MW).
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 2:
a. As a general matter, Appendix B to the ESA describes the generation facility
whose output is the subject of the ESA. The Company has traditionally listed the
nameplate capacity rating of the generation unit(s) as one of those key identifying
attributes. From a non-exhaustive survey of existing ESAs, it appears some of the
ESAs list the VAR capability of the units as well, although some ESAs do not.
Regardless, reactive power requirements are addressed more fully in the
Generation Interconnection Agreements, and do not have an impact on the rates,
payments, or other terms of the ESA. Idaho Power believes the VAR capability
description could be removed from Appendix B with no impact to substantive
provisions of the ESA.
b. According to the Seller, the units operate independently and have the same VAR
capability value (both leading and lagging). In further discussions with the Seller
regarding this Request for Production, the Seller has indicated that the VAR

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST AND SECOND PRODUCTION REQUEST
OF THE COMMISSION STAFF – 4
capability (both leading and lagging) of all three units is 0.9, not 0.8 as indicated in
Appendix B, Section B-1.
c. Please see response to (b).
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning, and Coordination Manager, Idaho Power Company.
Respectfully submitted this 30th day of May 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST AND SECOND PRODUCTION REQUEST
OF THE COMMISSION STAFF – 5
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 30th day of May 2023, I served a true and correct
copy of the within and foregoing Idaho Power Company’s Response to the First and
Second Production Request of the Commission Staff upon the following named parties
by the method indicated below, and addressed to the following:

Commission Staff
Michael Duval
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Nate Francisco
Executive Director and CEO
Southern Idaho Solid Waste
[phone]

Hand Delivered
U.S. Mail
Overnight Mail
Fax
X Email: [e-mail]

________________________________
Christy Davenport, Legal Assistant