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coMMfJl~ldilfs Co'Ht,i/isIONBEFORE THE IDAHO PUBLIC UTILITIES
IN THE MATTER OF THE
INVESTIGATION OF THE CONTINUED
REASONABLENESS OF CURRENT SIZE
LIMITATIONS FOR PURPA QF
PUBLISHED RATE ELIGIBILITY
(i. e., 1 MW) AND RESTRICTIONS
ON CONTRACT LENGTH (i. e. ,
5 YEARS)
CASE NO. GNR-E-O2-01
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COURT REPORTER
REBUTTAL TESTIMONY AND EXHIBITS OF
STUART A. T. TRIPPEL
ON BEHALF OF
INDEPENDENT ENERGY PRODUCERS OF IDAHO
TABLE OF CONTENTS
INTRODUCTION AND OVERVIEW OF TESTIMONY. . . . . . . . . . . . . . . 2
NATURAL GAS PRICE FORECAST. . . . . . . . . . . . . . . . . . . . . . . . . . . 2
CAPITAL CARRYING CHARGE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
FIRST DEFICIT YEAR
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..
RATE IMPACTS ......................................... 7
SUMMARY AND CONCLUSIONS..............................
Trippel, Di-Reb
Independent Energy
Producers of Idaho
ARE YOU THE SAME STUART TRIPPEL WHO
PREVIOUSLY FILED DIRECT TESTIMONY BEHALF THE
INDEPENDENT ENERGY PRODUCERS OF IDAHO IN THIS PROCEEDING?
Yes.
INTRODUCTION AND OVERVIEW OF TESTIMONY
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
The purpose of my testimony is to (1)recommend
an updated natural gas price forecast,in conjunction with
David Hawk, who is also testifying in rebuttal testimony on
behalf of the Independent Energy Producers of Idaho (IEPI),
(2) recommend changes to the capital carrying charge used in
the avoided cost rate model, and (3) comment on the proposal
Plummer ProductsForest and Potlatch Corporation
regarding first deficit year.
NATURAL GAS PRICE FORECAST
PLEASE SUMMARIZE YOUR POSITION ON NATURAL GAS
PRICE FORECAST AS PRESENTED IN YOUR DIRECT TESTIMONY.
In my direct testimony I presented two natural
gas price forecast series from the Northwest Power Planning
Council (NPPC)Draft Fuel Price for the 5thForecasts
Northwest Conservation and Electric Power Plan,April 25
Trippel, Di-Reb
Independent Energy
Producers of Idaho
2002 (Council 2007 -07)(hereinafter the NPPCDocument
Forecast"
) .
series directThethatpresentedtwo
testimony were the medium-high and the high.On direct
testimony I recommended the medium-high series, although
also testified that it would be entirely reasonable for the
Commission adopt forecast serieshightheNPPC'
(Trippel, Di, at 8, lines 21-23).
YOU CONT INUE TO RECOMMEND THE MEDIUM-HIGH
SERIES?
In view of recent observations of changesNo.
in the natural gas markets, as testified to on rebuttal by
David Hawk, also on behalf of the IEPI in this proceeding, I
believe that is more appropriate adopt the high,
rather than the medium-high, series of natural gas prices.
WHAT SPECIFICALLY IS YOUR CURRENT RECOMMENDATION
REGARDING THE INITIAL-YEAR NATURAL GAS PRICE AND ANNUAL
ESCALATION RATE?
indicated Exhibi t 604,which
accompanied my direct testimony, I now recommend an initial-
year natural gas price of $3.91 per MMBtu and an escalation
rate of 3.6 percent per year.This is consistent with the
testimony of Mr. Hawk.
Trippel , Di-Reb
Independent Energy
Producers of Idaho
CAPITAL CARRYING CHARGE
WHAT IS MEANING OF THE CAPITAL CARRYING CHARGE
IN THE AVOIDED COST RATE MODEL?
The capital carrying charge is used to compute
the annualized plant cost in the avoided cost model.It is
currently 12.424 percent for Idaho Power, 11.813 percent for
Avista, and 12.600 percent for Pacificorp.
WHAT THE PROBLEM WITH USING THESE CAPITAL
CARRYING CHARGES AT THIS TIME?
These capital carrying charges were developed at
a time when it was considerably easier to obtaining funding
for power plants in the financial markets.This
longer the case.
YOU HAVE ANY EVIDENCE THAT MORE
DIFFICULT FOR UTILITIES TO FINANCE POWER PLANTS NOW THAN
PREVIOUSLY?
Yes.Idaho Power Company presented,
connection with its proceeding before this Commlssion
approve the Garnet Energy plant,an affidavit dated July 22,
2002, sworn to by Darrel Anderson, Vice President and Chief
Financial Officer of IDACORP,Inc.,the parent company of
Idaho Power.copy of this affidavit is included as my
Trippel, Di-Reb
Independent Energy
Producers of Idaho
Exhibi t No.In the affidavit, Mr. Anderson states as608.
follows:
At the time that Garnet entered into the
(Power Purchase Agreement J with Idaho Power,
the financial markets were willing to providefinancing for merchant power plants
reasonable terms and conditions, and at thattime both IDACORP and Idaho Power reasonably
concluded that financing for the GarnetFacility would be readily available reasonable terms. Since that time, the
substantial turmoil in the financial marketsand the well-publicized problems with Enron,
Dynergy, Reliant, and other large merchant
power plant developers has made the financing
of merchant power plants extremely difficult.
(Exhibit No. 608, para. 3, emphasis added.
WHAT DO YOU PROPOSE WITH RESPECT TO THE CAPITAL
CARRYING CHARGES FOR THE UTILITIES?
that Commission eachadj ustproposethe
utili ty ' s capi tal carrying charge upwards by between two and
four percent to reflect difficulty in obtaining financing
for power plants in the current market.As noted by Mr.
Anderson,financial markets are currentlythe
substantial turmoil
, "
difficul t gauge
specific figure.Nonetheless, two to four percent is within
a range of reasonableness for adj usting the carrying charge.
In the avoided cost figures that I present, below at the end
of my testimony,adj ust each utility s capital carrying
charge upwards by three percent, the figure in the middle of
my recommended range.
Trippel, Di-Reb
Independent Energy
Producers of Idaho
FIRST DEFICIT YEAR
HAVE YOU REVIEWED THE DIRECT TESTIMONY OF LARRY
CROWLEY BEHALF PLUMMER FOREST PRODUCTS AND THE
POTLATCH CORPORATION REGARDING FIRST DEFICIT YEAR?
Yes.I have reviewed Mr. Crowley s testimony in
which he recommends setting the first deficit year of Avista
to the year 2000 (Crowley, Di , at 6, lines 4-6).
DO YOU AGREE WITH MR. CROWLEY'S RECOMMENDATION?
wi th Mr.andanalysisCrowleyYes,agree
recommendation.Should the Commission decide to continue
the difficul t calculatingandtimeconsumingtask
individual first deficit years for the various utilities it
regulates, then Mr. Crowley s methodology should be used by
the Commission.
DOES YOUR ANSWER SUGGEST YOU HAVE CHANGED YOUR
POSITION ON ELIMINATING THE FIRST DEFICIT YEAR CALCULATION/
In my direct testimony I argued on behalfNo.
of the IEPI that all three utilities should be deemed to be
in deficit immediately with respect to any resource under 10
megawatts.Mr. Crowley favorably alludes to this concept at
the end of his testimony (Crowley, Di, at 7 , lines 8-9).
addi tion, Rick Sterling also supports this concept on behalf
of Commission Staff (Sterling, Di, at 7 -11) .
Trippel, Di-Reb
Independent Energy
Producers of Idaho
RATE IMPACTS
HAVE YOU UPDATED YOUR CALCULATION OF THE IMPACT
OF YOUR RECOMMENDATIONS ON AVOIDED COST RATES?
format
testimony,
Yes.Exhibi t same609,which in theNo.
as my earlier Exhibit No.605,filed with direct
includes an abbreviated form of the spreadsheet
model used to calculate avoided cost non-fueled rates for
the three utili ties.In each case,the only changes made
were to the initial natural gas price (now $3.91 per MMBtu)
the natural gas escalation rate (now 3.6 percent per year),
the first
immediately
defici t (set utili tiesthattheyear are
deficit)and the capi tal carrying charge
(adj usted upwards by three percent for each utility)
variables
mode 1 ,
Other
remain the they currently thesameare
wi th the cosmetic adj ustments for purposes of this
exhibi t that I described in my direct testimony.
PLEASE SUMMARIZE THE RATES RESULTING FROM YOUR
RECOMMENDATIONS.
all ratesutilities,three resul tingForthe
range from 56 mills/kWh (for a 2002 online date) to 66 or
mills/kWh
purposes,
(for 2007 online For comparisondate) .
the current rates would be 71-93 mills/kWh for
Idaho Power, representing a decrease of 21-28 percent.
Trippel , Di-Reb
Independent Energy
Producers of Idaho
SUMMARY AND CONCLUSIONS
PLEASE SUMMARIZE YOUR TESTIMONY AND CONCLUSIONS.
view the testimony presented above,
recommend that in setting avoided cost rates the Commission
adopt a natural gas price of $3.91 for 2002, with a nominal
escalation rate of 3.6 percent per year.continue to
recommend that the Commission deem that, with respect to any
QF of less than 10 megawatts, the purchasing utility will be
considered to be deficit,and pa the fullresource
avoided cost under that assumption.Finally,I recommend
that in calculating avoided cost rates the Commission add
fourtwo its discretionpercent,the capi tal
carrying charge of each of the three Idaho utili ties who are
parties to this proceeding.
DOES THIS CONCLUDE YOUR TESTIMONY?
Yes.
Trippel, Di-Reb
Independent Energy
Producers of Idaho
EXHIBIT NO. 608
AFFIDAVIT OF DARREL ANDERSON, VICE PRESIDENT AND CHIEF
FINANCIAL OFFICER OF IDACORP, INC.
AFFIDAVIT
STATE OF IDAHO
: ss.
County of Ada
Darrel Anderson , being first duly sworn on oath , deposes and says:
I am the Vice President and Chief Financial Officer of IDACORP
Inc.
IDACORP, Inc. is the corporate parent of Ida-West Energy
Company and provides the credit support for Ida-West Energy and Ida-West'
subsidiary, Garnet Energy, LLC (Garnet). Garnet Energy, LLC and Idaho Power
Company are the signatories to the Power Purchase Agreement (PPA) which is the
subject of IPUC Case No. IPC-O1-42. Under the PPA, Garnet has agreed to sell
power to Idaho Power generated by a merchant power plant to be constructed , owned
operated and maintained by Garnet (Garnet Facility). Because of the structure of the
contract with Idaho Power, financing of the Garnet Facility must be accomplished as a
merchant power plant because only a portion of the revenues required to support the
plant's revenue stream will come from the PPA.
At the time that Garnet entered into the PPA with Idaho Power, the
financial markets were willing to provide financing for merchant power plants on
reasonable terms and conditions, and at that time both IDACORP and Idaho Power
reasonably concluded that financing for the Garnet Facility would be readily available on
reasonable terms. Since that time , the substantial turmoil in the financial markets and
the well-publicized problems with Enron, Dynegy, Reliant and other large merchant
AFFIDAVIT, Page
EXHIBIT NO. 608
Stuart Trippel
Page 1 of 3
power plant developers has made the financing of merchant power plants extremely
difficult. Within the past few weeks we have seen a further deterioration within the
capital markets. A clear indication of this has been the rapid decline of IDACORP'
common stock price. Companies much larger than IDACORP are having difficulty in
financing all types of power plants. Because this deterioration has been so rapid and so
severe, we have only recently been able to advise Idaho Power of the magnitude of the
problem and our concern that Garnet may not be able to perform the PPA as it was
presented to the Commission for approval.
IDACORP and Garnet intend to expeditiously explore alternative
financing arrangements which may make the Garnet Facility financeable under the
existing PPA. However, this will take some additional time and, candidly, in today
financial market environment may not be successful.
IDACORP cannot, in good conscience, recommend that Idaho
Power proceed with the hearing in this case in light of the significant possibility that the
Garnet Facility cannot perform within the terms of the existing PP A without jeopardizing
the financial health of IDACORP, Inc. This could also have an adverse affect on
IDACORP's credit rating and cost of money for other purposes including the cost of
money for Idaho Power Company.
~V/ Ua~
DARR ANDERSON
AFFIDAVIT, Page 2
EXHIBIT NO. 608
Stuart Trippel
Page 2 of 3
STATE OF IDAHO
) ss.
County of Ada
On this 22nd day of July, 2002 , before me, the undersigned, a Notary
Public, personally appeared DARREL ANDERSON , known or identified to me to be the
Vice President and CFO of IDACORP , Inc., the corporation that executed the within
instrument, and acknowledged to me that such corporation executed the same as the
free act and deed of said corporation.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my
official seal the day and year first hereinabove written.
(NOTARIAL SEAL)
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AFFIDAVIT, Page 3
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h--.Not Public for Idaho
Residing at Boise, Idaho
My Comm. Expires 0 - S -0 7
EXHIBIT NO. 608
Stuart Trippel
Page 3 of 3
EXHIBIT NO. 609
AVOIDED COST RATES UNDER RECOMMENDATIONS
AVOIDED COST CALCULATION MODEL
04-Aug-
DATA IPCO
TYPE DATA
FIRST DEFICIT YEAR:2000
SURPLUS ENERGY COST (mil/kWh):19.
SURPLUS COST BASE YEAR:1994
SAR" PLANT LIFE (YEARS):
SAR" PLANT COST ($/kW):$667
BASE YEAR OF "SAR" COST:1994 350
SAR" CAPACITY FACTOR (%):92%Btu/kWh
UTL TY WT'D COST OF CAPITAL (%):199%
RATEPAYER DISCOUNT RATE (%):199%$3,
SAR" FIXED O&M ($/kW):$7.43 per MMBtu
SAR" VARIABLE O&M (mil/kWh):
CURRENT YEAR FUEL COST (mil/kWh):28.
BASE YEAR, O&M EXPENSES:1994 20-year K
ESCALATION RATE; "SAR" (%):60%Levelized
ESCALATION RATE; SURPLUS (%):50%56.
ESCALATION RATE; O&M (%):21%58,
ESCALATION RATE; FUEL (%):60%60.41
ADJUSTABLE PORTION (mil/kWh):62,
CAPITAL CARRYING CHARGE (%):15.424 %64.
LEVEL CARRYING COST (mil/kWh):15.67.
TILTING" RATE (%):60%mills/kWh
TYPE OF RATES:NON-FUELED
CURRENT YEAR:2002
Online Year
2002
2003
2004
2005
2006
2007
EXHIBIT 609,
Stuart Trippel
Page 1 of 3
AVOIDED COST CALCULATION MODEL
04-Aug-
DATA A VISTA
TYPE DATA
FIRST DEFICIT YEAR:2000
SURPLUS ENERGY COST (mil/kWh):19.
SURPLUS COST BASE YEAR:1994
SAR" PLANT LIFE (YEARS):
SAR" PLANT COST ($/kW):$667
BASE YEAR OF "SAR" COST:1994 350
SAR" CAPACITY FACTOR (%):92%Btu/kWh
UTL TY WT'D COST OF CAPITAL (%):979%
RATEPAYER DISCOUNT RATE (%):979%$3,
SAR" FIXED O&M ($/kW):$7.43 per MMBtu
SAR"VARIABLE O&M (mil/kWh):
CURRENT YEAR FUEL COST (mil/kWh):28.
BASE YEAR, O&M EXPENSES:1994 20-year K
ESCALATION RATE; "SAR" (%):60%Levelized
ESCALATION RATE; SURPLUS (%):50%55.
ESCALATION RATE; O&M (%):21%57.
ESCALATION RATE; FUEL (%):60%59.
ADJUSTABLE PORTION (mil/kWh):61.
CAPITAL CARRYING CHARGE (%):14,813%64.
LEVEL CARRYING COST (mil/kWh):14.66.48
TILTING" RATE (%):60%mills/kWh
TYPE OF RATES:NON-FUELED
CURRENT YEAR:2002
Online Year
2002
2003
2004
2005
2006
2007
EXHIBIT 609
Stuart Trippel
Page 2 of 3
AVOIDED COST CALCULATION MODEL
04-Aug-
DATA PCP
TYPE DATA
FIRST DEFICIT YEAR:2000
SURPLUS ENERGY COST (mil/kWh):19.
SURPLUS COST BASE YEAR:1994
SAR" PLANT LIFE (YEARS):
SAR" PLANT COST ($/kW):$667
BASE YEAR OF "SAR" COST:1994 350
SAR" CAPACITY FACTOR (%):92%Btu/kWh
UTL TY WT'D COST OF CAPITAL (%):10.270%
RATEPAYER DISCOUNT RATE (%):10.270%$3.
SAR" FIXED O&M ($/kW):$7.43 per MMBtu
SAR" VARIABLE O&M (mil/kWh):
CURRENT YEAR FUEL COST (mil/kWh):28.
BASE YEAR, O&M EXPENSES:1994 20-year K
ESCALATION RATE; "SAR" (%):60%Levelized
ESCALATION RATE; SURPLUS (%):50%56.
ESCALATION RATE; O&M (%):21%58.
ESCALATION RATE; FUEL (%):60%60.
ADJUSTABLE PORTION (mil/kWh):62.47
CAPITAL CARRYING CHARGE (%):15.600%64.
LEVEL CARRYING COST (mil/kWh):15.41 67.
TILTING" RATE (%):60%mills/kWh
TYPE OF RATES:NON-FUELED
CURRENT YEAR:2002
Online Year
2002
2003
2004
2005
2006
2007
EXHIBIT 609
Stuart Trippel
Page 3 of 3