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HomeMy WebLinkAbout20120312Allphin Affidavit.pdfDONOVAN E. WALKER (ISB No. 5921) JASON B. WILLIAMS (ISB No. 8718) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker((idahopower.com jwilliams((idahopower.com Attorneys for Idaho Power Company RECEtVEO 'Inn tîM~ \ 2 PM 4: 5 , BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE COMMISSION'S ) REVIEW OF PURPA QF CONTRACT ) PROVISIONS INCLUDING THE ) SURROGATE AVOIDED RESOURCE ) (SAR) AND INTEGRATED RESOURCE ) PLANNING (IRP) METHODOLOGIES FOR ) CALCULATING PUBLISHED AVOIDED )COST RATES. ) ) ) ) ) STATE OF IDAHO) ) ss.County of Ada ) CASE NO. GNR-E-11-03 AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES I, Randy C. Allphin, having been duly sworn to testify truthfully, and based upon my personal knowledge, state the following: 1. I am an employee of Idaho Power Company ("Idaho Powet'). I am employed by Idaho Power as Senior Energy Contracts Coordinator. AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 1 2. I have personal knowledge of the inquiries Idaho Power receives from developers who are considering or intend to build Qualifying Facilties ("QF") under the Public Utility Regulatory Policies Act of 1978 ("PURPA") and sell their output to Idaho Power. Over the last several years, Idaho Power has received, and continues to receive, on a regular and steady basis, some form of inquiry from a developer or individual with some idea for a proposed QF project. Attachment No. 1 hereto is a list of inquires from developers of QFs that have moved beyond just a phone call and onto more serious inquiries within the last six months. This list does not include projects that have made inquires and have already negotiated and executed firm energy sales agreements ("FESA") with Idaho Power during this time frame; this is only the "outstanding" serious inquiries that are seeking FESAs with Idaho Power. 3. Altogether, Attachment No. 1 lists a total of 27 projects for a total of approximately 595 megawatts ("MW") nameplate capacity currently exploring FESAs with Idaho Power. Seventeen of those projects (519.7 MW nameplate rating) are inquiring into Idaho QF agreements and 10 projects (75.25 MW nameplate rating) are inquiring into QF agreements with Idaho Power in accordance with state of Oregon rules and regulations. This 595 MW of inquires is in addition to the 989 MW nameplate capacity of QF projects Idaho Power already has under contract. 4. The right column of Attachment No. 1 lists the estimated total energy payments Idaho Power would potentially make to these proposed projects over the full term of their respective FESAs. The assumptions used to calculate these estimates are included in Attachment No.1. As indicated in Attachment No.1, the estimated total cost of these potential new QF FESA's is estimated to be approximately AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 2 $2.7 billon over the life of the agreements. The vast majority of these potential obligations ($2.5 bilion) are located in the Company's Idaho jurisdiction. 5. As mentioned above, Idaho Power is contacted by QF developers on a constant basis with proposed QF projects. Thus, it is likely that even more developers with proposed projects other than those shown on Attachment No. 1 wil also contact Idaho Power and seek to enter into FESAs prior to the conclusion of Phase ILL of Case No. GNR-E-11-03, which wil not likely conclude until late summer or early fall of 2012. 6. Attachment No. 2 hereto is a graph prepared at my direction showing the existing 989 MW of QF projects under contract and the magnitude (in MW of nameplate capacity) of the recent QF inquires. The shaded areas above the 989 MW horizontal line is a graphical representation of the recent QF inquires (595 MW) that potentially could request final QF FESAs with Idaho Power at any time and prior to the conclusion of Phase III of this proceeding unless the Idaho Public Utilties Commission ("Commission") grants Idaho Powets motion for a stay. 7. Idaho power has no Idaho QF contracts that are due to expire in 2012. Therefore, a Commission order suspending Idaho ~gVlets Idaho PURPA ",,~ purchase obligation for the duration of its investigation wil not narm exiStlngJ~aho QFs under contract with Idaho Power. t ,.~ +";'''...A;:-~ , , 8. Idaho Power's direct testimony in this ;¡rna\ter:,~tallishês that it.' .~ currently has 119 Commission-approved QF power purchase agr~ments that represent nameplate capacity of 989 MW and with a contractual obligation of more than $3.6 bilion. Stokes, Direct, Ex. Nos. 1 and 2. The large increase in QF projects on-line and under contract since 2004 is expected to increase the power supply expense AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 3 passed on to customers through the Company's annual Power Cost Adjustment from approximately $40 millon in 2004 to approximately $60 milion in 2009, and wil increase to more than $120 millon in 2012. Stokes, Direct, p. 9-10. The 27 QF projects that are currently seeking power purchase agreements with Idaho Power represent an additional 595 MW of generation at a monetary obligation to customers of an additional $2.7 bilion over the numbers submitted in Idaho Powets direct testimony in this case. A stay on Idaho Powets duty to enter into new fixed-price PURPA contracts (or one of the alternative forms of relief sought in the Motion) is necessary in order to protect customers and avoid further results which are contrary to PURPA during the pendency of this case. FURTHER YOUR AFFIANT SAYETH NAUGHT DATED this 1th day of March 2012. Ji p. a~YC.ALLPÌÑ SUBSCRIBED AND SWORN to before me this 12th day of March 2012. ..............".'. ....,,....... ~1~ s. IJlJ ~##~,~ -fA '\~ ~ "'r; ~¡ (J ~OT -'Ill- ., \= :.* *:. ." :\~ I~ :¡ AO ~"~ -f1' ..v ~.. ~####. 11 0 P \~ ~,..,,,...........,",' CÀ~hgQQ¿~Notary Public for Idaho ~ Residing at: 1S \SE1 rdúXìo ' My commission expires: 021l)~ \5 AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 1th day of March 2012, pursuant to RP 256.02, that Idaho Power Company contacted one representative from each party listed below by telephone, as indicated below, and informed said party of the filing of IDAHO POWER COMPANY'S MOTION FOR, MEMORANDUM IN SUPPORT OF, AND AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES. Each party's representative, as indicated below, was informed by telephone of the filng requesting expedited, immediate relief, and of the procedure set forth in RP 256.02 to inform the Commission Secretary, either in writing personally delivered to the Secretary or by telephone, within the next two business days, whether they support or oppose the Motion and whether they desire to be heard on the Motion in person, in writing, or by telephone. Additionally, I HEREBY CERTIFY that on the 12th day of March 2012 I served a true and correct copy of: 1. Idaho Power Company's Motion for a Temporary Stay of its Obligation to Enter Into New Power Purchase Agreements with Qualifying Facilties; 2. Memorandum in Support of Idaho Power Company's Motion for a Temporary Stay of its Obligation to Enter Into New Power Purchase Agreements with Qualifying Facilties; and 3. Affidavit of Randy C. Allphin in Support of Idaho Power Company's Motion for a Temporary Stay of its Obligation to Enter Into New Power Purchase Agreements with Qualifying Facilties. upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Donald L. Howell, II Kristine A. Sasser Deputy Attorneys General Idaho Public Utilties Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 -- Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email don.howell((puc.idaho.gov kris.sasser((puc. idaho.gov -- Telephonic Notice to Kristine A. Sasser at (208) 334-0357, at 11 :25 a.m. AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 5 Avista Corporation Michael G. Andrea Avista Corporation 1411 East Mission Avenue, MSC-23 P.O. Box 3727 Spokane, Washington 99220-3727 PacifiCorp d/b/a Rocky Mountain Power Daniel E. Solander PacifiCorp d/b/a Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Exergy Development, Grand View Solar II, J.R. Simplot, Northwest and Intermountain Power Producers Coalition, Board of Commissioners of Adams County, Idaho, and Clearwater Paper Corporation Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 2ih Street (83702) P.O. Box 7218 Boise, Idaho 83707 Exergy Development Group James Carkulis, Managing Member Exergy Development Group of Idaho, LLC 802 West Bannock Street, Suite 1200 Boise, Idaho 83702 Grand View Solar II Robert A. Paul Grand View Solar II 15690 Vista Circle Desert Hot Springs, California 92241 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email michael.andrea((avistacorp.com -- Telephonic Notice to Michael G. Andrea at (509) 495-2564, at 12:24 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email daniel.solander((pacificorp.com -- Telephonic Notice to Daniel E. Solander at (801) 220-4014, at 11 :15 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email peter((richardsonandoleary.com greg((richardsonandoleary.com -- Telephonic Notice to Peter J. Richardson at (208) 938-7901, at 2:58 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email jcarkulis((exergydevelopment.com -- Telephonic Notice to Peter J. Richardson at (208) 938-7901, at 2:58 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email robertapaul08((gmail.com -- Telephonic Notice to Peter J. Richardson at (208) 938-7901, at 2:58 p.m. AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 6 J.R. Simplot Company Don Sturtevant, Energy Director J.R.Simplot Company One Capital Center 999 Main Street P.O. Box 27 Boise, Idaho 83707-0027 Northwest and Intermountain Power Producers Coalition Robert D. Kahn, Executive Director Northwest and Intermountain Power Producers Coalition 1117 Minor Avenue, Suite 300 Seattle, Washington 98101 Board of Commissioners of Adams County, Idaho Bil Brown, Chair Board of Commissioners of Adams County, Idaho P.O. Box 48 Council, Idaho 83612 Clearwater Paper Corporation Marv Lewallen Clearwater Paper Corporation 601 West Riverside Avenue, Suite 1100 Spokane, Washington 99201 Renewable Energy Coalition and Dynamis Energy, LLC Ronald L. Wiliams WILLIAMS BRADBURY, P.C. 1015 West Hays Street Boise, Idaho 83702 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email don.sturtevant((simplot.com -- Telephonic Notice to Peter J. Richardson at (208) 938-7901, at 2:58 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email rkahn((nippc.org -- Telephonic Notice to Peter J. Richardson at (208) 938-7901, at 2:58 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email bdbrown((frontiernet.net -- Telephonic Notice to Peter J. Richardson at (208) 938-7901, at 2:58 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email marv.lewallen((clearwaterpaper.com -- Telephonic Notice to Peter J. Richardson at (208) 938-7901, at 2:58 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email ron((willamsbradburv.com -- Telephonic Notice to Ronald L. Willams at (208) 344-6633, at 1 :46 p.m. AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 7 Renewable Energy Coalition Thomas H. Nelson, Attorney P.O. Box 1211 Welches, Oregon 97067-1211 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email nelson((thneslon.com -- Telephonic Notice to Ronald L. Wiliams at (208) 344-6633, at 1 :46 p.m. John R. Lowe, Consultant Renewable Energy Coalition 12050 SW Tremont Street Portland, Oregon 97225 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email jravenesanmarcos((yahoo.com -- Telephonic Notice to Ronald L. Willams at (208) 344-6633, at 1 :46 p.m. Dynamis Energy, LLC Wade Thomas, General Counsel Dynamis Energy, LLC 776 East Riverside Drive, Suite 150 Eagle, Idaho 83616 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email wthomas((dynamisenergy.com -- Telephonic Notice to Ronald L. Willams at (208) 344-6633, at 1 :46 p.m. Interconnect Solar Development, LLC R. Greg Ferney MIMURA LAW OFFICES, PLLC 2176 East Franklin Road, Suite 120 Meridian, Idaho 83642 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email greg((mimuralaw.com -- Telephonic Voice Mail to R. Greg Ferney at (208) 639-4592, at 2:52 p.m. Bil Piske, Manager Interconnect Solar Development, LLC 1303 East Carter Boise, Idaho 83706 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email billpiske((cableone.net -- Telephonic Voice Mail to R. Greg Ferney at (208) 639-4592, at 2:52 p.m. AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 8 Renewable Northwest Project and Idaho Windfarms, LLC Dean J. Miler Chas. F. McDevitt McDEVITT & MILLER LLP 420 West Bannock Street (83702) P.O. Box 2564 Boise, Idaho 83701 Megan Walseth Decker Senior Staff Counsel Renewable Northwest Project 917 SW Oak Street, Suite 303 Portland, Oregon 97205 Idaho Windfarms, LLC Glenn Ikemoto Margaret Rueger Idaho Windfarms, LLC 672 Blair Avenue Piedmont, California 94611 Twin Falls Canal Company and North Side Canal Company C. Thomas Arkoosh CAPITOL LAW GROUP, PLLC 205 North 10th Street, 4th Floor P.O. Box 2598 Boise, Idaho 83701-2598 Twin Falls Canal Company Brian Olmstead, General Manager Twin Falls Canal Company P.O. Box 326 Twin Falls, Idaho 83303 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email joe((mcdevitt-miler.com chas((mcdevitt-miller.com -- Telephonic Notice to Dean J. Miler at (208) 343-7500, at 1 :03 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -2 Email megan((rnp.org -- Telephonic Notice to Dean J. Miler at (208) 343-7500, at 1 :03 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email glenni((envisionwind.com margaret((envisionwind .com -- Telephonic Notice to Dean J. Miler at (208) 343-7500, at 1 :03 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email glenni((envisionwind.com margaret((envisionwind .com -- Telephonic Voice Mail to C. Thomas Arkoosh at (208) 424-8872, at 2:55 p.m. Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email olmstead((tfcanal.com -- Telephonic Voice Mail to C. Thomas Arkoosh at (208) 424-8872, at 2:55 p.m. AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 9 North Side Canal Company Ted Diehl, General Manager North Side Canal Company 921 North Lincoln Street Jerome, Idaho 83338 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email nscanal((cableone.net -- Telephonic Voice Mail to C. Thomas Arkoosh at (208) 424-8872, at 2:55 p.m. Birch Power Company Ted S. Sorenson, P.E. Birch Power Company 5203 South 11 th East Idaho Falls, Idaho 83404 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email ted((tsorenson.net -- Telephonic Notice to Ted S. Sorenson at (208) 522-8069, at 3:04 p.m. Blue Ribbon Energy LLC M.J. Humphries Blue Ribbon Energy LLC 4515 South Ammon Road Ammon, Idaho 83406 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email blueribbonenergy((gmail.com -- Telephonic Notice to M.J. Humphries at (208) 524-2414, at 1 :34 p.m. Arron F. Jepson Blue Ribbon Energy LLC 10660 South 540 East Sandy, Utah 84070 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email arronesq((aol.com -- Telephonic Notice to M.J. Humphries at (208) 524-2414, at 1 :34 p.m. Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street (83702) P.O. Box 844 Boise, Idaho 83701 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -2 Email botto((idahoconservation.org -- Telephonic Notice to Benjamin J. Otto at (208) 345-6933 ext. 12, at 1 :12 p.m. AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 10 Snake River Allance Ken Miller, Clean Energy Program Director Liz Woodruff, Executive Director Lisa Young, Clean Energy Organizer Snake River Allance 350 North 9th Street #B610 P.O. Box 1731 Boise, Idaho 83701 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -2 Email kmiller((snakeriverallance.org Iwoodruff((snakeriveralliance.org Iyoung((snakeriveralliance.org -- Telephonic Notice to Lisa Young at JI:03P.m. Donovan E. Walker Attorney for Idaho Power Company AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 11 BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION CASE NO. GNR-E-11-03 IDAHO POWER COMPANY ATTACHMENT NO.1 RECENT QF DEVELOPER INQUIRIES Idaho Power Company Cogeneration and Small Power Production Project Inquires Estimated Total Assumed Contract Term Contract Nameplate MWH Estimated Total State Project (MW)Production Contract Payments 1 Idaho Biomass 3.20 515,789 $40,080,222 2 Idaho CHP 20.00 3,223,680 $245,219,478 3 Idaho CHP 97.00 15,634,848 $1,137,010,026 4 Idaho Hydro 0.50 29,765 $2,381,556 5 Idaho Solar 20.00 796,960 $47,565,909 6 Idaho Solar 20.00 796,960 $48,629,052 7 Idaho Solar 20.00 796,960 $48,629,052 8 Idaho Solar 20.00 796,960 $47,565,909 9 Idaho Solar 20.00 796,960 $47,565,909 10 Idaho Solar 20.00 796,960 $47,565,909 11 Idaho Solar 35.00 1,394,680 $83,240,341 12 Idaho Solar 40.00 1,593,920 $95,238,397 13 Idaho Solar 60.00 2,390,880 $159,605,164 14 Idaho Wind 20.00 1,204,158 $59,589,612 15 Idaho Wind 20.00 1,204,158 $59,589,612 16 Idaho Wind 24.00 1,444,990 $74,253,360 17 Idaho Wind 80.00 4,816,634 $247,511,200 Subtotal Idaho 519.70 38,235,262 $2,491,240,709 1 )Oregon Hydro 1.50 66,971 $6,033,649 2 Oregon Hydro 1.50 66,971 $6,033,649 3 Oregon Hydro 2.25 100,456 $9,050,473 4 Oregon Wind 10.00 451,643 $34,398,183 5 Oregon Wind 10.00 451,643 $34,398,183 6 Oregon Wind 10.00 451,643 $34,398,183 7 Oregon Wind 10.00 451,643 $34,398,183 8 Oregon Wind 10.00 451,643 $34,398,183 9 Oregon Wind 10.00 451,643 $34,398,183 10 Oregon Wind 10.00 451,643 $34,398,183 Subtotal Oregon 75.25 3,395,900 $261,905,048 Total 594.95 41,631,162 $2,753,145,757 Assumptions Idaho Contract Term Oregon Contract Term 20 year contract term assumed 15 year contract term assumed to match with the 15 year fixed price eligibilty as specified in the current Schedule 85 CHP Idaho Contracts estimated pricing IRP pricing model as presented in December 15,2012 IPUC presentation. The proposed projects are greater than 10aMW, thus IRP pricing model as presented in December 15, 20121PUC presentation. Current IPUC approved published avoided costs. Solar and Wind Biomass and Hydro Oregon Contracts estimated pricing All Projects Current Schedule 85 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. GNR-E-11-03 IDAHO POWER COMPANY ATTACHMENT NO.2 EXISTING QF PROJECTS UNDER CONTRACT AND RECENT QF DEVELOPER INQUIRIES