20110926_3471.pdf

WILLIAMS. BRADBURY
ATTORNEYS AT LAW RECE
ZOll SEP 23 PH 2: 32
September 23,2011 iDr\I1C¡
UT!LiTli:S
Ms. Jean Jewell
Commission Secreta
Idaho Public Utilties Commission
472 W. Washington
Boise,ID 83702
Re: IPC-E-I1-10
Dear Ms. Jewell:
Please find enclosed an original and seven copies of the Motion for Extension of Time
of Interconnect Solar Development, LLC for filing in the above referenced case.
Than you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,~~tJ~
..
Ronald L. Wiliams
RLW/jr
Enclosures
1015 W. Hays Street - Boise, ID 83702
Phone: [phone] - Fax: [phone] - ww.wiamsbradbur.com
Ronald L. Wiliams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise,ID 83702
Telephone: [phone]
Fax: [phone]
ron~wiliamsbradbur.com
RECEI r-L~
lUll SEP 23 PM 2= 32
Attorneys for Interconnect Solar
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR A )
DETERMINATION REGARDING THE FIRM )
ENERGY SALES AGREEMENT WITH )
INTERCONNECT SOLAR DEVELOPMENT, )
LLC, FOR THE SALE AND PURCHASE OF )ELECTRIC ENERGY. )
)
Case No. IPC-E-11-10
MOTION FOR EXTENSION OF
TIME
COMES NOW, Interconnect Solar Development, LLC ("Interconnect Solar" or
"ISD"), by and through its counsel of record, Wiliams Bradbur, PC, and fies this
Motion for Extension of Time for Interconnect Solar and Idaho Power Company to
resubmit a Firm Energy Sales Agreement ("FESA") to the Idaho Public Utilities
Commission ("Commission"), for the reasons stated below.
1. Order No. 32361 issued September 20, 2011 gave ISD and Idaho Power
seven days, or until September 27,2011, to resubmit the FESA with rates corrected for a
computational error related to the escalation of the capacity component of avoided costs,
after which the Commission would proceed with deliberations regarding approval or
disapproval of the Agreement.
2. Interconnect Solar and Idaho Power have also identified a second
computational error related to the capacity value of the Murhy Flats solar project,
ANSWER TO STAFF'S MOTION FOR EXTENSION OF TIME, Page 1
resulting from a failure to correctly model sumer hourly generation based on shift to
daylight savings time. This error appears to largely accounts for the difference between
the 36% capacity factor assigned by Idaho Power to the Project at the June 2010 system
peak hour of 7:00 P.M, versus the 55% capacity valuation derived by Siemens for the
same hour, using the PVSYST solar modeling program.
3. Correcting for this daylight savings time error requires Idaho Power to re-
ru its avoided cost model which the Company has agreed to do, on an expedited basis,
with results expected on Monday, September 26,2010.1 However, there is the possibilty
that ISD and Idaho Power will not be able to tum the new modeled prices into a revised
and fully executed FESA by September 27,2010.
4. Following a meeting between Interconnect Solar and Idaho Power on
Thursday, September 22, 2011 in which scheduling was discussed, ISD believes that a
revised and executed FE SA can be presented to the Commission on Thursday, September
29,2010.
WHREFORE, Interconnect Solar requests that the Commission issue an order
extending by two days, until September 29, 2011, the date by which Idaho Power and
ISD resubmit their Firm Energy Sales Agreement with accurate avoided cost calculations.
DATED: This ~ 1,J day of September, 2011.
f¿,li L V JklsI ~L.\I~
Ronald L. Wiliams
Wiliams Bradbur P.C
Attorneys for Interconnect Solar Development, LLC
1 This new mode ru wil also continue to correct for the capacity escalation error previously identified.
ANSWER TO STAFF'S MOTION FOR EXTENSION OF TIME, Page 2
CERTIFICATE OF SERVICE
I hereby certify that on this _ day of August, 2011, a tre and correct copy of
the foregoing was served by the method indicated below, and addressed to the following:
Donovan E. Walker D us Mail
Lead Counsel D Facsimile
Idaho Power Company D Hand Delivery
PO Box 70 D Overnght Mail
Boise,ID 83707-0070 ~E-Mail Address
E- Mail: dwalker~idahopower.com
Randy C. Allphin D us Mail
Energy Contract Admin.D Facsimile
Idaho Power Company D Hand Delivery
POBox 70 D Overnght Mail
Boise,ID 83707-0070 ~E-Mail Address
E- Mail: rallphin~idahopower.com
Kristine A. Sasser D US Mail
Deputy Attorney General D Facsimile
Idaho Public Utilties Commission D Hand Delivery
PO Box 83720 D Overnght Mail
Boise,ID 83720-0074 ~E-Mail Address
E-Mail: kris.sasser~puc.idaho.gov
Randy Hemmer, Manager D US Mail
Interconnect Solar Development, LLC D Facsimile
3777 Twilight Drive D Hand Delivery
Boise,ID 83703 D Overnght Mail
E- Mail: randyhemmer~clearre.net ~E-Mail Address
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ANSWER TO STAFF'S MOTION FOR EXTENSION OF TIME, Page 3