950822.docx

BRAD PURDY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
Street Address for Express Mail:
472 W. Washington
Boise, Idaho  83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION)
OF IDAHO POWER COMPANY FOR AN)CASE NO. IPC-E-95-9
ORDER APPROVING THE METHODOLOGY)
FOR AVOIDED COST RATE )
NEGOTIATIONS WITH QUALIFYING)FIRST PRODUCTION
FACILITIES LARGER THAN 1 MEGAWATT)REQUEST OF THE
)COMMISSION STAFF
)TO IDAHO POWER
                                                                   )COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Brad Purdy, Deputy Attorney General, requests that Idaho Power Company provide the following documents and information on or before TUESDAY, SEPTEMBER 12, 1995.
This Production Request is to be considered as continuing, and Idaho Power Company is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing.
1.Please provide Proscreen/Proview model runs in response to the following:
A.Demonstrate that the methodology fairly values dispatchability.  Perhaps two model runs, one in which the project is dispatchable and one in which it is not, would demonstrate this.
B.Demonstrate the effect of deferring the on-line date of a project.
C.Demonstrate how the value of a QF project may be decreased if another QF signs a contract first, thus displacing higher cost generation.
D.Show that the model is correctly calibrated by calculating the value of a QF with characteristics identical to one of the resources selected in the IRP.  
E.Demonstrate that the model works equally well for a small hydro project as for a large gas-fired project.
For each of the model runs, show how the timing and/or quantity of base case resources are changed as a result of the proposed QF.  For example, for the 10 MW example provided with the filing, the calculated rate should be based on displacement or deferral of some combination of resources, both the timing and size of which can vary.
2.Provide a sensitivity analysis of avoided cost rates for the hypothetical 10 MW project identified in the Company's filing for the following combinations of load and gas price:
A.Base case load forecast, base case gas price
B.Base case load forecast, high gas price
C.Base case load forecast, low gas price
D.Mid-low load forecast, base case gas price
E.High load forecast, base case gas price
3.Identify which resources in the base case plan are non-deferrable and explain the reason for non-deferrability.
4.What interest rate is used to calculate rates once the avoided cost present value is determined?
5.What is the proposed turn around time for developers to get rates after submitting project information?
6.Provide information to support the monthly generation figures provided in Table 2 for Borah and Shoshone Falls.
7.How would gas prices be periodically adjusted?  On what would the adjustments be based?  How often would the adjustments be made?
8.On what basis would the "other factors" mentioned on page 10 be applied to rates? Could they be both positive or negative?
9.What would be the result in the example provided if the gas supply is non-firm instead of firm?
10.What would be the consequences if a project didn't meet its guaranteed minimum capacity or produce its expected seasonal energy?
11.What is the source of the preferred equity rate of 6.77% on page 6?
12.Why was 12.25% used for common equity when the approved rate is 11%?
13.Why is an assumed capital structure used rather than the Company's current capital structure?
14.Demonstrate that 22.1 mills escalated at 3.7% is equivalent to the total capacity and energy differences shown on Attachment 2 pg. 3 of 6.
15.Provide a breakdown of firm off-system loads which are included in the total company load as shown in Table 1.  What assumptions have been made about renewal of any of the agreements?  The IRP Technical Appendix on page 50 says that the UAMPS and Washington City contracts renew automatically for five year terms.  Are these renewals included in the load tabulation?
16.Are exchange agreements reflected in Table 1?  If so, how?
17.Provide a breakdown by year of the individual DSM programs and their associated savings which are subtracted from the load in Table 1.
18.Are loss reductions associated with transformer and capacitor replacements reflected in Table 1?  If so, where?
19.Explain why the level of QF purchases shown in Table 1 declines beginning in the year 2002.
20.Provide workpapers or other information showing how the average MW figures for the thermal plants listed in Table 1 were derived.
21.What are the Company's expected winter purchases of capacity and energy by month for the years 2003 through 2014?
22.What are the standards that must be met to maintain resource adequacy and system reliability as referred to in section 5 on page 3?
23.Will known and measurable changes in IRP data, such as listed on page 8, change the size and/or timing of resources selected as the "base case", or will the changes simply be reflected as differences in the cost of resources which were already selected as the "base case"?  In other words, could the choice of resources that constitute the "base case" change between IRP filings as a result of known and measurable changes?   
DATED  at Boise, Idaho, this            day of August 1995.
______________________________________
Brad Purdy
Deputy Attorney General
umisc/prodreq/ipce959.bpr