20230622IPC to Staff 1-3.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]

June 22, 2023

VIA ELECTRONIC FILING

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-23-19
Dietrich Drop Hydro Project
Idaho Power Company’s Application for Approval or Rejection of an
Energy Sales Agreement with American Falls Reservoir District No. 2

Dear Ms. Noriyuki:

Attached for electronic filing, please find Idaho Power Company’s Response to the
First Production Request of the Commission Staff to Idaho Power Company in the above-
entitled matter.

Please feel free to contact me directly with any questions you might have about
this filing.

Very truly yours,

Donovan E. Walker
DEW:cd
Enclosures
RECEIVED
Thursday, June 22, 2023 11:35:22 AM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 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 OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
AMERICAN FALLS RESERVOIR DISTRICT
NO. 2 FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE DIETRICH
DROP HYDRO PROJECT.

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CASE NO. IPC-E-23-19

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) dated June 1, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
STAFF REQUEST FOR PRODUCTION NO. 1: Page 6 of the Application states
that the project nameplate capacity is 4,770 kW and that this amount is the nameplate in
the 1987 Agreement. However, the copy of the 1987 agreement Staff has in its records
shows the nameplate capacity at 4,500 kW. Please respond to the following:
a. Was the 1987 agreement amended to reflect the 4,770-kW nameplate
capacity? If so, please provide a copy of the 1987 amended agreement; and
b. If it wasn't amended, please reconcile and explain the discrepancy.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 1:
a. Yes. Please see the attached First Amendment to Firm Energy Sales
Agreement, executed August 5, 1988, that included an amendment to Appendix B,
Description of Facility, listing the nameplate capacity as 4,770 kW.
b. Please see the response to part (a).
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 PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
STAFF REQUEST FOR PRODUCTION NO. 2: What various impacts would the
new proposed annual period (starting on June 1 for this QF's calculation of the 55%
requirement) have on the Company for this contract? Please provide an analysis that
includes, but is not limited to, the impacts on the following:
a. How these timeframes affect resource and operational planning;
b. The administrative burden to track contracts with different timeframes;
c. The ability of the Company's accounting systems to accommodate different
timeframes; and
d. Other hydro QFs that may want to change the annual period.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 2:
a. Idaho Power’s resource and operational planning relies on a QFs historical
performance to forecast future generation (based on five years of historical data if
available and, if not, recent generation data and the initial estimates of generation
provided by the QF). The time period for evaluation of whether a QF has met the
requirements to qualify for the seasonal hydro rate has no impact on these forecasts or
on resource and operational planning generally.
b. There is no significant contract administrative burden to track contracts with
different timeframes. Idaho Power’s contract tracking system can accommodate differing
evaluation periods and dates for performing the analysis of whether a project has met the
seasonal hydro requirements.
c. The Company’s accounting systems can accommodate differing
timeframes for the seasonal hydro evaluation period. The accounting systems use the
same timeframes for all generation regardless of resource type. If a rate change is needed

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
due to a QF not meeting the seasonal hydro requirements, such a change could be
implemented in the accounting systems regardless of whether the evaluation period was
based on a calendar year or a June-May 12-month period, and regardless of whether
different QFs have different evaluation periods.
d. There are eight other seasonal hydro QFs that potentially could have
interest in a revised annual evaluation period if approved in this proceeding: Black
Canyon #3, Curry Cattle Company, Head of U Canal Project, Jim Knight, Low Line Canal,
North Gooding Main Hydro, Sagebrush, and Lowline #2.
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 PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
STAFF REQUEST FOR PRODUCTION NO. 3: Page 3 of Sorenson Engineering,
Inc. and IdaHydro's Comments state that the QF does not receive the accounting
information for August "until well into September." Please respond to the following:
a. When does the Company currently provide its accounting information for
generation delivered in August?
b. When is the earliest the Company can provide the accounting information
for August to the QF?
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 3:
a. Currently, Idaho Power generally is able to provide a QF with accounting
information for generation delivered the prior month (for example, August) by the 20th day
of the following month (for example, September), assuming timely receipt of generation
data as required by contract. See, e.g., Appendix A of the proposed Agreement.
b. Before accounting information can be provided and payments issued to
projects, a number of steps and processes must occur. In order for generation and
payment statements to be prepared: meter data must be imported into the Company’s
accounting systems, Sarbanes-Oxley Act (SOX) compliance testing must be applied to
all booked generation, and previous monthly payments and planned future payments
must be reconciled. Additionally, before payment can be issued, Idaho Power must
receive documentation from the QF of monthly energy actually delivered to Idaho Power
as required by contract. See, e.g., Appendix A of the proposed Agreement. Given the
large number of projects with which Idaho Power has contracts, these processes take
some time and result in the data being available and delivered to the projects generally
by the 20th day of the month following the month of generation.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning, and Coordination Manager, Idaho Power Company.

Respectfully submitted this 22nd day of June 2023.

DONOVAN WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 7
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 22nd day of June 2023, 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 TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:

Michael Duval
Deputy Attorneys General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

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Dietrich Drop Hydro Project
Miriah R. Elliott
711 E Turtle Point Drive
Ivins, UT 84738

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IdaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 w. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
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________________________________
Christy Davenport, Legal Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-19

IDAHO POWER COMPANY

ATTACHMENT 1