20130325Reconsideration Comments.pdf

IHO PVER®
REcE!VF An IDACORP Company
DONOVAN E. WALKER
Lead Counsel £
dwalker(Wudah000wer corn L
March 25, 2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. GNR-E-11-03
PURPA SAR and IRP Methodologies - Idaho Power Company's Comments
on Reconsideration
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and seven (7) copies of Idaho
Power Company's Comments on Reconsideration.
Very truly yours,
Donovan E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalkeridahoDower.com
Attorney for Idaho Power Company
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
PLANING (IRP) METHODOLOGIES FOR
CALCULATING AVOIDED COST RATES.
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY'S
COMMENTS ON
RECONSIDERATION
Idaho Power Company ("Idaho Power" or "Company") hereby respectfully
submits to the Idaho Public Utilities Commission ("Commission") its Comments on the
reconsideration of the Canal Drop Hydro definition and the resource-specific capacity
factors of the SAR methodology for Canal Drop Hydro and the Other categories. Avista
Corporation ("Avista") has reviewed these Comments, and while the basis contained
herein is specific to Idaho Power's system, Avista has authorized Idaho Power to
represent that Avista supports Idaho Power's proposed revisions to the definition of
Canal Drop Hydro.
I. INTRODUCTION
On February 5, 2013, the Commission issued its Order on Reconsideration in the
above-captioned case. Order No. 32737. This Order was a final order as to some
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -1
issues, and either granted or denied reconsideration and clarification as to some issues.
With regard to the issues raised on reconsideration and clarification regarding Canal
Drop Hydro and the resource-specific capacity factors utilized in the SAR methodology,
the Commission directed the parties to file comments by March 25, 2013, and reply
comments by April 8, 2013. The Commission found:
After reviewing the arguments presented by the parties, we
grant reconsideration of the canal drop hydro issues raised.
We also grant reconsideration/clarification regarding the
capacity factor utilized in the SAR model for "other" projects.
Canal drop hydro has a separate, higher, set of rates
because irrigation-related projects provide capacity when the
utility most needs it - during the peak hours of the peak
days of the year (i.e., during the summer season). The
issues surrounding the definition of canal drop hydro and
resource specific capacity factors were not explored at
hearing. The parties focused on other issues. Therefore,
we find it appropriate to grant reconsideration to allow for
discovery and comments on the narrow issues of: (1)
definition of canal drop hydro, and (2) capacity factors as
they relate to "canal drop hydro" projects and "other" projects
under the SAR methodology.
Order No. 32737 at pp. 3-4.
As more fully explained below, Idaho Power proposes that the Commission adopt
changes to the definition of Canal Drop Hydro that bases the definition upon the hydro
projects' delivery of energy during peak summer load. Idaho Power also proposes the
use of a different resource-specific capacity factor for Canal Drop Hydro that is based
upon actual data from projects on Idaho Power's system and a resource-specific
capacity factor for Other that is based upon the Northwest Power and Conservation
Council's forced outage data. NPCC, 6th Northwest Power Plan, Appendix I.
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -2
II. DEFINITION OF CANAL DROP HYDRO
In Final Order No. 32697, the Commission established a system of SAR-based
published avoided cost rates that incorporate a resource-specific capacity factor in the
differentiation of published rates by resource type. In so doing, the Commission found
"that implementation of a resource-specific capacity factor is an appropriate way to
value when a QF is able to generate and deliver energy to a utility." Order No. 32697 p.
15. As part of Order No. 32697, the Commission included, as Attachments A, B, and C,
published avoided cost rate schedules for each utility. These published rate schedules
were further updated by two subsequent Erratas to Order No. 32697 on January 2 and
January 8, 2013, respectively. The published rates were divided into five resource type
categorizations: Wind, Solar, Hydro, Canal Drop Hydro, and Other.
A hydroelectric based qualifying facility ("QF"), below 10 average megawatts, is
eligible for one of two published avoided cost rate schedules: Hydro or Canal Drop
Hydro. Because of a Canal Drop Hydro project's capacity factor/peak time deliveries—
and its corresponding reduced deliveries during non-peak times, the published rate
schedule for a Canal Drop Hydro project results in much higher $/megawatt-hour prices
than a "hydro" project. The first Note on the published rate schedule for Canal Drop
Hydro defines eligibility for that rate schedule as follows:
A "canal drop hydro project" is defined as a generation
facility which produces the majority of its generation during
the irrigation season and is located on a man-made
waterway that conveys water primarily intended for irrigation
or that primarily conveys irrigation return flows.
The underlying concept of having a separate rate for a Canal Drop Hydro project
is not necessarily because of its source of water but the fact that it produces power that
is dependable, non-intermittent, and is delivered to the utility during the utility's peak
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -3
power consumption summer months. The approved incremental cost IRP pricing
methodology does a very good job of valuing these types of seasonal peak hour power
deliveries as it values the energy based on the hour in which it is delivered to Idaho
Power. However, with the Commission's directive to differentiate within the SAR
published avoided cost rates among different generation types based upon their
capacity factor, projects that both provide most or all of their power deliveries during a
utility's peak power needs, and correspondingly does not provide a lot of power
deliveries during the utility's non-peak hours, receive a higher avoided cost rate,
corresponding to the higher value of what they provide and, in concept, what they
enable the utility to avoid. Consequently, the most important part of the definition of
Canal Drop Hydro is not necessarily its source of water but when it generates and
delivers energy to Idaho Power. The definition references the source of water because
that is typically what determines when it generates power and, correspondingly, makes
deliveries to the utility.
A "true" Canal Drop Hydro project is a project that only delivers energy during the
irrigation season (during Idaho Power's peak energy needs), which is when water is in
the canal system AND correspondingly produces no generation during the non-peak
winter months as there is no water in the canal system. The rationale and concept that
a Canal Drop Project receives a higher avoided cost rate both because of its peak
deliveries and the lack of non-peak deliveries is confirmed by Commission Staffs direct
testimony in this matter. "Canal drops can contribute 100 percent of their capacity
during the summer peak and 0 percent of their capacity during the winter peak."
McHugh Direct, p. 10. "The rates for canal drop projects are considerably higher for
Idaho Power and PacifiCorp compared to other resources primarily because canal drop
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -4
projects offer capacity during peak summer hours and their capacity is spread out over
relatively few total hours." McHugh Direct, p. 12. "The capacity component is high for
canal drop hydro for two reasons. First, the capacity is provided during peak summer
hours when it is most valuable to the utility. Second, the capacity value is spread over
fewer kilowatt-hours than for other resource types because a canal drop hydro project
would be operating during the irrigation season." Sterling Direct, p. 21.
Idaho Power's main concern with the current definition of Canal Drop Hydro is
the phrase "produces a majority of its generation during the irrigation season" and, more
specifically, the use of the words "majority" and "irrigation season" in that phrase.
"Irrigation season" is only relevant because it happens to coincide with Idaho Power's
peak power demands on its system, which are June, July, and August. "Majority" is
problematic because what is really contemplated is that it would provide "all" of its
generation during peak demands, and, correspondingly, not provide deliveries when the
power is not needed in off-peak hours and seasons. For example, "majority" could
mean that the project provides 51 percent of its deliveries during the irrigation season,
but also that it delivers 49 percent during the rest of the year, when the power is not
needed, and the utility's avoided cost is much less, or even negative. In contrast to a
"true" Canal Drop Hydro that only provides generation during the peak summer season,
the project with a simple "majority" of 51 percent will have a significantly different
capacity factor and avoided cost. While recognizing that some projects may fall
somewhere in between where they do actually provide most of their generation during
the irrigation season, but still have some amount of year round off-peak generation,
Idaho Power proposes that only those Canal Drop Hydro projects whose off-season, off-
peak generation is de minimis when compared to their in-season, on-peak generation
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -5
be qualified to receive the higher capacity factor, Canal Drop Hydro published avoided
rate.
Idaho Power proposes that the definition of Canal Drop Hydro be modified to
specifically quantify the requirement that it deliver during peak load months, and not
during non-peak months, rather than simply stating "majority." Idaho Power requests
that the Commission adopt revisions to the definition of a Canal Drop Hydro project to
replace "the majority" with "55%" and replace "irrigation season" with "months of June,
July, and August." Consequently, the definition of Canal Drop Hydro would be:
A "canal drop hydro project" is defined as a generation
facility which produces 55% the majority of its generation
during the months of June, July. and August irrigation
season and is located on a man-made waterway that
conveys water primarily intended for irrigation or that
primarily conveys irrigation return flows.
Alternatively, should the Commission wish to retain the entire irrigation season
in the definition, instead of moving to the peak months of June, July, and August, Idaho
Power requests that the definition be modified to replace "the majority" with "96%" and
define "irrigation season" as the months of "April through October." This request and
these percentages are based upon actual data from all of Idaho Power's QF Canal Drop
Hydro projects and their actual delivered generation over the course of the last 10
years.
Over the last 10 years, from 2003 through 2012, Idaho Power has had between
24 and 28 Canal Drop Hydro QF generators under contract and making power
deliveries to its system. (Because of on-line dates, terminations, and renewals, the
number varied between 24 and 28 over the last 10 years). Over the course of that 10
year period, 96 percent of the monthly energy deliveries from the Canal Drop Hydro
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -6
projects on Idaho Power's system occurred during the months of April through October,
the entire irrigation season. Over that same period of time, 55 percent of the monthly
energy deliveries from Canal Drop Hydro projects occurred during the months of June,
July, and August, the Company's summer peak load season. See Attachment I hereto,
incorporated herein by this reference.' Because the intent of offering the higher
avoided cost published rate for Canal Drop Hydro projects is to account for the higher
value of the peak month deliveries, and the lack of off peak deliveries, Idaho Power
proposes to modify the current definition of Canal Drop Hydro by replacing "a majority"
with "55%" and replacing "irrigation season" with "months of June, July, and August."
Idaho Power proposes that provisions for the implementation and compliance
with the definition and qualification for the higher Canal Drop Hydro rate be contained in
the Energy Sales Agreement between the utility and the QF. Initial qualification of the
QF as a Canal Drop Hydro project would be referenced in the "Warranties" of the
contract, where the definition would be set forth, and the QF would certify that it meets
said definition and also provides estimated generation to verify its qualification. With
regard to ongoing monitoring of compliance, the actual energy deliveries for June, July,
and August (or the larger season, if implemented) would be monitored at year-end to
verify that the project meets the definition to receive the higher Canal Drop Hydro rate.
If the project failed to deliver its energy in the proper time period, its rate would be
reduced to the "hydro" published avoided cost, which is what that project would receive
if it does not meet the definition of a Canal Drop Hydro. Because the project would
1 The generation data includes all projects currently categorized as canal projects, which includes
data from five projects that provide consistent year-round generation. If those five projects are excluded
from the data, the June, July, and August average monthly deliveries goes up to 58 percent, and the April
through October goes up to 99 percent.
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -7
have already received the higher Canal Drop Hydro payments for the year, the
difference would be trued-up in the following year energy payments.
Ill. CAPACITY FACTORS FOR CANAL DROP HYDRO AND OTHER
Idaho Power recommends that the resource-specific capacity factor used in the
SAR avoided cost model for Canal Drop Hydro projects be revised from the current 100
percent to 67.1 percent and the resource-specific capacity factor used for Other projects
be revised from the current 100 percent to 92 percent. It is simply not reasonable to
include these resources at 100 percent.
Order No. 32697 directs that published rates will be differentiated based upon
resource type stating, "We find that implementation of a separate resource-specific
capacity factor is an appropriate way to value when a QF is able to generate and deliver
energy to a utility." Order No. 32697 at p. 15. Commission Staff utilized resource-
specific capacity factors derived from a combination of capacity factors provided in the
Northwest Power and Conservation Council's 6th Power Plan and on-peak capacity
factors provided in testimony to this case. The capacity factors used by Commission
Staff are:
Wind 5%
Solar 35%
Hydro 25%
Canal Drop Hydro 100%
Other 100%
Idaho Power provided the following resource-specific capacity factors in testimony:
Wind 3.9%
Solar 33.2%
Canal Drop Hydro 67.1%
Base load 92%
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -8
Stokes Direct, Ex. No. 3, P. 18. Idaho Power's capacity factors, above, for wind, solar,
and Canal Drop Hydro were calculated based upon actual data from existing and
proposed projects. Id. at pp. 24, 30, and 42. The base load capacity factor was
calculated assuming a resource that could control operations and fuel supply to enable
the project to plan to operate at 100 percent during peak hours. An 8 percent forced
outage rate for a base load resource as identified in the Northwest Power and
Conservation Council's 6th Power Plan was deducted from the 100 percent capacity
factor to establish an expected capacity factor of 92 percent for a base load project. Id.
at p. 18.
The record indicates that based upon data from projects on Idaho Power's
system, the capacity factor for Canal Drop Hydro is 67.1 percent, as opposed to the 100
percent capacity factor utilized in the present calculation. Idaho Power has provided to
the parties, in the Company's response to Commission Staffs Production Request No.
23, the data, spreadsheets, and calculation of the 67.1 percent capacity factor for Canal
Drop Hydro. In addition, over the last 10 years, the 28 Canal Drop Hydro projects that
have delivered energy to Idaho Power have a capacity factor of 68 percent over the
months of June, July, and August (aggregate actual generation/nameplate for all
projects). This confirms the more detailed hourly peak hour capacity factor calculated
for the hours of 3:00 p.m. to 7:00 p.m. during the month of July—which is the 67.1
percent capacity referenced above, and detailed in the Company's response to
Commission Staffs Production Request No. 23.
Idaho Power equates the Other category established by the Commission to be
the resources that Idaho Power has identified as "base load." These projects are
generation resources that tend to deliver the same level of energy on an hourly basis in
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -9
all hours, all days, and for the full-term of the contract. For example, wood waste,
anaerobic digesters, landfill gas, waste to energy, and geothermal projects. Idaho
Power does not disagree that these resource types tend to be continuous, flat running,
base load generation resources. However, it is not reasonable to assume that a project
will achieve a perfect 100 percent capacity factor and will never have any outages
during Idaho Power's peak energy need period during the 20-year contract term as is
implied by the suggested use of a 100 percent capacity factor. Even a well operated
and maintained facility is likely to have unexpected mechanical and forced outages
occur over the typical 20-year contractual term, and it is not reasonable to pay a 20-year
price based upon the assumption that a project has a perfect 100 percent capacity
factor.
The actual operational data for Canal Drop Hydro projects currently operating on
Idaho Power's system suggests a 67 percent capacity factor. Idaho Power asks that
the Commission direct the use of a 67.1 percent capacity factor for Canal Drop Hydro
projects in the SAR published avoided cost rate model rather than the 100 percent
presently being used. Additionally, the Northwest Power and Conservation Council's 8
percent forced outage rate is a fair, reasonable, and independent source to provide the
appropriate adjustment. Idaho Power asks that the Commission direct the use of a 92
percent capacity factor for Other, or base load, projects in the SAR published avoided
cost rate model rather than the 100 percent presently being used.
IV. CONCLUSION
For the reasons set forth above, Idaho Power requests that the Commission
adopt the proposed revisions to the definition of a Canal Drop Hydro project to replace
"a majority" with "55%" and replace "irrigation season" with "months of June, July, and
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -10
August." Alternatively, should the Commission wish to retain the entire irrigation season
in the definition, instead of moving to the peak months of June, July, and August, Idaho
Power requests that the definition be modified to replace "a majority" with "96%" and
define "irrigation season" as the months of "April through October." Further, with regard
to the resource-specific capacity factors, Idaho Power asks that the Commission direct
the use of a resource-specific capacity factor of 67.1 percent for Canal Drop Hydro
projects and a capacity factor of 92 percent for Other projects rather than the 100
percent currently used.
Respectfully submitted this 25th day March 2013.
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -11
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 25th day of March 2013 I served a true and
correct copy of IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION
upon the following named parties by the method indicated below, and addressed to the
following:
Commission Staff
Kristine A. Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
Spokane, Washington 99202
PacifiCorp dibla 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 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
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IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -12
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Grand View Solar II
Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Springs, California 92241
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
Bill Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
Clearwater Paper Corporation
Mary Lewallen
Clearwater Paper Corporation
601 West Riverside Avenue, Suite 1100
Spokane, Washington 99201
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IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -13
Renewable Energy Coalition and Dynamis
Energy, LLC
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Renewable Energy Coalition
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 150
Eagle, Idaho 83616
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Bill Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Renewable Northwest Project, Idaho
Windfarms, LLC, and Ridgeline Energy LLC
Dean J. Miller
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
421 SW 6th Avenue, Suite 1125
Portland, Oregon 97204
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IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -14
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Twin Falls Canal Company, North Side
Canal Company, Big Wood Canal
Company, and American Falls Reservoir
District No. 2
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock, Suite 900
P.O. Box 2900
Boise, Idaho 83701
ELECTRONIC SERVICE ONLY
Donald W. Schoenbeck
RCS, Inc.
900 Washington Street, Suite 780
Vancouver, Washington 98660
ELECTRONIC SERVICE ONLY
Twin Falls Canal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
ELECTRONIC SERVICE ONLY
North Side Canal Company
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11 th East
Idaho Falls, Idaho 83404
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IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -15
Blue Ribbon Energy LLC
M.J. Humphries
Blue Ribbon Energy LLC
3470 Rich Lane
Ammon, Idaho 83406-7728
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
Snake River Alliance
Liz Woodruff, Executive Director
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
Energy Integrity Project
Tauna Christensen
Energy Integrity Project
769 North 1100 East
Shelley, Idaho 83274
Idaho Wind Partners I, LLC
Deborah E. Nelson
Kelsey J. Nunez
GIVENS PURSLEY LLP
601 West Bannock Street (83702)
P.O. Box 2720
Boise, Idaho 83701-2720
Mountain Air Projects, LLC
J. Kahle Becker
The Alaska Center
1020 West Main Street, Suite 400
Boise, Idaho 83702
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IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -16
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IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION -17
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY
ATTACHMENT I