HomeMy WebLinkAbout082295.docxSCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0320
ATTORNEY FOR THE COMMISSION STAFF
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE WASHINGTON )
WATER POWER COMPANY’S 1995 ) CASE NO. WWP-E-95-2
ELECTRIC INTEGRATED RESOURCE )
PLAN.)
)FIRST PRODUCTION
)REQUEST OF THE
)COMMISSION STAFF
)TO WASHINGTON _____________________________________________)WATER POWER
The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests Washington Water Power Company provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before TUESDAY, SEPTEMBER 12, 1995.
This production request is to be considered as continuing, and Washington Water Power Company is requested to provide by way of supplementary responses, additional documents that you or any person acting on your behalf may later obtain that will augment the documents produced.
Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder.
Request No. 1: For each of the firm contracts for either purchase or sale of capacity or energy, provide a brief explanation of how the contract benefits WWP.
Request No. 2: Explain the entry entitled "Restoration" on line 17 of the Tabulation of Firm Requirements and Resources (4 MWa from 1994-2002).
Request No. 3: Explain why contract hydro on line 15 and cogeneration on line 20 of the Tabulation of Firm Requirements and Resources decreases between 1995 and 1996.
Request No. 4: Does the Company expect monthly energy deficits to occur in any year in which an energy deficit is not anticipated on an annual basis?
Request No. 5: Provide a summary of the July 1994 bid proposals including the costs and delivery schedules for capacity and energy.
Request No. 6: What assumptions are made with regard to renewal of PURPA hydro and thermal plant contracts?
Request No. 7: Provide any updated information, as available, on the effects of the Endangered Species Act on flow releases and generation at hydropower plants which provide output to WWP.
Request No. 8: What is the source for the cost and performance data for wind, solar, various coal, and the gas-fired technologies listed in the Appendices?
Request No. 9: What is the basis for allowing 8% specifically as a cost credit for T&D benefits for conservation/DSM and allowing a 10% cost credit for renewables to recognize environmental benefits? Provide a more detailed description of how the cost credit is applied in the selection of resources.
Request No. 10: Provide workpapers or other information showing how the rate of 2.85 cents/kWh was calculated by the SRPM model as a 20 year levelized cost of new resources. (See Appendix, pg. 123)
Request No. 11: Reference the source of the SRPM Input Assumptions shown on page 131.
Request No. 12: Provide additional explanation regarding the content and use of Table 1I on page 132. Also reference the source of the information. What assumptions were used to arrive at the numbers shown? How were the secondary energy purchase prices determined?
Request No. 13: Why does the capacity factor used in the SRPM differ from the maximum availability factors for the CCCT as shown on page 133?
Request No. 14: Explain how the fixed and variable O&M escalation factors shown in Tables 2I and 3I on pages 133-135 were derived.
Request No. 15: For the 100 MW 10 year Power Sale Scenario, what sales prices were assumed and how were they calculated? What would be the expected terms of the sale?
What is the rationale for considering this scenario?
Request No. 16: Relate the Tabulation of Firm Requirements and Resources on page 45 to one of the scenarios summarized at the end of the Appendix.
Request No. 17: Provide an explanation of the Washington Avoided Cost figures on page 132. To what projects do they apply and how do they relate to resources and prices acquired through the Washington RFP process?
Request No. 18: Does the Company expect to increase the capacity of any hydro projects scheduled for relicensing between 1995-2008 (Cabinet Gorge, Noxon Rapids, Spokane River)?
DATED at Boise, Idaho, this day of August 1995.
______________________________________
Scott Woodbury
Deputy Attorney General
______________________________________
Rick Sterling
sw:umisc/prodeq/wwpe952.swrStaff Engineer