20130325Comments.pdf

ARKOOSH
C. Tom Arkoosh
LAw OFFICES 7U13 MAR 25 pj i:
[e-mail]
JTi!T: cAMISSO.
March 25, 2013
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Re: GNR-E-11-03 - Filing of Confidential Information Pursuant to Rule 67
Dear Ms. Jewell:
Accompanying this letter please find enclosed an original and seven copies of our
Comments in the above matter containing confidential information pursuant to the Protective
Agreement between Avista Corporation, Idaho Power Company, Pacific Corp, Idaho Public
Utilities Commission staff, and Intervenors to be filed pursuant to Rule 67 of the IPUC Rules of
Procedure. Such information is labeled "Confidential" because the same was provided to us in
discovery under that label, pursuant to the Agreement.
Further find enclosed an original and seven copies of our Comments for filing with the
confidential information redacted.
Sincerely,
ARKOOSH LAW OFFICES
C. Tom Arkoosh
CTA/emc
Enclosures
Cc: Client
802 West Bannock Street, Suite 900, P.O. Box 2900, Boise, ID 837011 Tel: [phone] Fax: [phone]
2iJ!3MR25 P11 h: 13
J-K) 'r i:' --r;
C. Tom Arkoosh, ISB No. 2253
ARKOOSH LAW OFFICES
802 W. Bannock Street, Suite 900
Z P.O. Box 2900
Boise, Idaho 83701-2598
Telephone: [phone]
O Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Twin Falls Canal Company, North
Side Canal Company, Big Wood Canal
Company and American Falls Reservoir District
No. 2
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
COMMISSION'S REVIEW OF PURPA
QF CONTRACT PROVISION
INCLUDING THE SUBROGATE
AVOIDED RESOURCE (SAR) AND
INTEGRATED RESOURCE
PLANNING (IRP) METHODOLOGIES
FOR CALCULATING PUBLISHED
AVOIDED COST RATES.
Case No. GNR-E-1 1-03
COMMENTS OF NORTH SIDE CANAL
COMPANY, TWIN FALLS CANAL
COMPANY, BIG WOOD CANAL
COMPANY, AND AMERICAN FALLS
RESERVOIR DISTRICT NO.2
COME NOW Twin Falls Canal Company, North Side Canal Company, Big Wood Canal
Company, and American Falls Reservoir District #2 (collectively, "Canal Companies"), by and
through their counsel of record, C. Tom Arkoosh of Arkoosh Law Offices, and hereby submit
these Comments.
These Comments are submitted on behalf of the Canal Companies pursuant to Order No.
32737, which provides parties the opportunity to address certain issues under reconsideration by
the Commission: the definition of a canal drop hydro project and the appropriate capacity factor
to use for canal drop and other hydro projects for deriving avoided cost prices under the SAR
COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2— Page 1
methodology. These comments will only address the appropriate capacity factor to use in
deriving canal drop avoided cost prices under the SAR methodology. As will be explained in
the following comments, the Commission should use a 100% on-peak capacity factor for
deriving avoided cost prices for canal drop projects.'
In its post-hearing pleadings, Idaho Power Company ("IPC") advocated using a canal
drop capacity factor of 67.1% based upon "actual data from existing projects." (See IPC's
Response to Petitions and Cross-Petition for Reconsideration, dated January 15, 2013, page 11.)
Based upon the extensive data provided in response to Staffs Data Request No. 22 and the Canal
Companies Requests No. 33 and 34, we now know that IPC's calculation was flawed for a
number of reasons. These reasons are: 1) it was based on an extremely limited subset of canal
drop projects, 2) it was based on a limited period of time, 3) it was based on imprecise metered
data, 4) it appears no attempt was made to correct the accuracy of the data for the sampled
projects even knowing there were substantial inaccuracies, 5) the IPC value is based on the 90%
exceedance value of deliveries instead of the expected delivery value, 6) it used the nameplate
capacity for each project instead of the project's dependable on-peak capability.
In response to Staff Request No. 22, IPC provided a listing of all QF projects as of
December 31, 2012 (confidential Attachment 1). This attachment lists N projects currently
operating with E designated as being hydro projects. Confidential Attachment 2 provided in
response to this same request provides the monthly generation of each project since it began
operating. This attachment contains E projects of which E are identified as being hydro
projects. This attachment also indicates for each hydro project a "facility category" identified
1 The Canal Companies' consultant Mr. Schoenbeck received copies of the Staff avoided cost EXCEL spreadsheet
model ("Updated Avoided Cost Model Version 2.0.xlsm) on June 14, 2012 and again on June 22, 2012. In both
versions, he noted the on-peak canal drop capacity factor of 100%. This was one of the reasons Mr. Schoenbeck
endorsed the use of this model in his rebuttal testimony filed on June 28, 2012 in this proceeding.
COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2— Page 2
as being: canal drop (U projects), river (I projects), creek (U projects), or spring (U projects).
Confidential Attachment 3 to this response provides a listing of projects with available hourly
metered data. Attachment 3 also identifies the source of the hourly data. This attachment
indicates that only U projects have hourly data of which E are canal drop projects. For these
• canal drop projects, hourly data for = projects is listed as being a "P1" meter while the
remaining = projects data is based on a "MV90" meter. The IPC data response to Staff
explains the difference in hourly data source:
• .MV9O data is generation information provided hourly by the actual meter
located at each project measured in kilowatts ("kW"). . .PI data is hourly
generation information that is accessed through the Idaho Power SCADA
system measured in megawatts ("MW") for each project. The MV90
data is measured per kW, whereas the P1 data is measured per MW.
Therefore, the more accurate MV90 data was used in preparing this
information when it was available.
The IPC response to Canal Companies Requests 33 and 34 provides the workpapers used
to calculate the on-peak capacity factors indicated on prefiled Exhibit 3, page 18 of 47. An
analysis of these workpapers shows the IPC proposed 67.1% on-peak capacity factor was
calculated using P1 meter data for each of only W canal drop projects for only
A cursory review of these spreadsheet workpapers raises
serious questions regarding the accuracy of the P1 data for these 0 projects. In particular, for
each sampled project, the spreadsheet contains a check based on the summation of the hourly P1
data versus the actual "booked" generation amount for each project. These comparisons show
substantial deviations between the two sources as shown by the following illustrative table for
one of the M sampled projects:
COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2—Page 3
Illustration of Data Problems - (MWhs)
Summation of Difference
Hourly Pt IPC Booked (Hourly P1 v
Year Data Data Booked) • • - - - . • • - - .
For two of the other sampled projects, the P1 data summation is less than the booked
amounts by for . As shown by the following table:
Illustration of Data Problems
(MWhs)
Summation
of IPC IPC Difference
Hourly P1
Data
Booked
Data
(Hourly P1 v
Booked) • - - • - - - - • - -
It appears no attempt was made by IPC to correct the P1 data for the substantial
differences—in most cases under statements--between the two data sources, and yet, this is the
very data relied on by IPC to advocate for a 67.1% on-peak capacity factor for canal drop
projects.
The Canal Companies believe there are two more shortcomings with the IPC calculation
method that should be corrected as well. First, the IPC 67.1% value is based on a 90%
exceedance calculation. This means that 90% of the time, the projects will actually be
2 Based on daily records at this facility, we believe the value should actually be= MWh. The difference is
attributable to a known meter problem at this facility during this time.
COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2— Page 4
providing a larger amount of capacity than is indicated by the 90% value. This is inappropriate.
The capacity that is being avoided is the expected on-peak deliveries for the canal drop projects.
Even based on IPC's suspect sampled data, the expected on-peak deliveries for the four projects
is actually 78% as shown by IPC Exhibit 3, page 18 of 47. Second, the IPC capacity factor
calculation is based on the on-peak deliveries and the assumed nameplate capacity of the facility.
The use of the nameplate capacity may or may not be the appropriate value for a particular
project as the facility may never be able to operate at this level due to other restrictions. This is
the exact same reason why nameplate capacity is not used to rate the capability of any utility
owned resources. In actuality, the dependable or maximum deliverability during the on-peak
hours is the more important or proper metric for establishing the on-peak capacity factor.
The Canal Companies have undertaken the substantial task of analyzing the hourly data
of the IPC identified canal drop projects. Of the = canal drop projects with MV90 meters,
one of the projects appears to have highly questionable hourly values given the IPC identified
nameplate capacity. Of the remaining 0 projects, E projects have provided a high level of
on-peak deliverability based on all the years of hourly data. In fact, allowing for an 8% outage
rate for the avoided resource (92% deliverability), = of the projects should be paid 100% of
the avoided capacity cost as their deliverability is comparable to, or superior than, the avoided
resource and is within 0 of this value (• deliverability). This analysis
supports the Staff assumption that canal drop projects can and do provide a very high level of
capacity during the peak hours. As such, under the current "rolled-in" pricing approach, the
Commission should use a 100% on-peak capacity factor for canal drop projects to ensure
projects providing this level of high deliveries are paid the full avoided resource value. The
only other approach--which would appear to be outside the scope of this reconsideration—would
COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2—Page 5
be to unbundle the SAR avoided cost price into separate demand and energy components. By
so doing, each and every canal drop project would be appropriately paid for the capacity need it
is displacing based on its actual deliveries.3
Federal regulation 18 CFR 292.101(6) provides in pertinent part regarding capacity:
Avoided costs means the incremental costs to an electric utility of electric ... capacity ... which,
but for the purchase from the qualifying facility or qualifying facilities, such utility would
purchase from another source.
From this, the Commission determined in Order No. 32697, page 21 that:
In calculating a QF 's ability to contribute to a utility's need for capacity, we find
it reasonable for the utilities to only begin payments for capacity at such time that
the utility becomes capacity deficient. If a utility is capacity surplus, then
capacity is not being avoided by the purchase of QF power. By including a
capacity payment only when the utility becomes capacity deficient, the utilities
are paying rates that are a more accurate reflection of true avoided cost for the QF
power.
This conclusion, in turn, arose from the pre-filed testimony of staff member C. McHugh:
In the recommended model, capacity payments are specific to the resource used
by the QF. If a utility is deficient in capacity, then the recommended model
examines whether the utility is deficient in summer only, in winter only, or in
both seasons. If the utility is deficient in only one season, then the model bases a
resource-specific capacity payment on the ability of that resource to contribute
during the deficient season's peak. However, if a utility is deficient in both
seasons, then the model bases the resource-specific capacity payment on the
ability of that resource to contribute during both seasons' peaks. This is the
same methodology suggested by Avista.
To clarify matters, consider canal drop QFs. Canal drops can contribute 100
percent of their capacity during the summer peak and 0 percent of their capacity
So long as Idaho uses a combined energy/capacity price calculated on a "one size fits all" basis for published
rates, great care should be given to pay for all the project capacity actually delivered to avoid a regulatory taking of
a OF's capacity by failing to pay for 100% of what is provided. See Penn. Central Transp. Co. v. City of New York,
438 U.S. 104, 98 S.Ct. 2646, 57 L.Ed. 2d 631 (1978), as cited in Boise Tower Associates, LLC v. Hogland, 147 Idaho
774, 215 P.3d 494 (2009). If a system of statistical quantification of capacity combining a blend of several plants
is to be used, this suggests the importance and equity of pegging the amount of capacity payments to the plants
delivering the highest percentage of capacity in order to protect those OF's right to be paid the whole avoided
cost.
COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2—Page 6
during the winter peak. If a utility is only capacity deficient during the summer,
then a canal drop QF receives the full capacity payment. However, if a utility is
capacity deficient in only the winter or in both the summer and winter, then the
canal drop receives no capacity payment. Allowing capacity payments to differ
by resource should encourage development of QFs with characteristics of value to
the utilities (such as QFs that provide generation during peak hours).
McHugh, C. (Di) page 9, line 21 to page 10, line 20.
This in turn follows from the pricing constraints found in the federal regulations.
Section 292.304 sets the pricing paradigm. Avoided costs must be just and reasonable to the
consumer and in the public interest. Section 292.304(b)(2) directs application of the factors in
92.304(2)(e), entitled: Factors affecting rates for purchases, directing that "[i]n determining
avoided costs, the following factors shall, to the extent practicable, be taken into account:"
Subsection one requires consideration of certain utility data. Of importance here are:
The estimated capacity costs at completion of the planned capacity additions and
planned capacity firm purchases, on the basis of dollars per kilowatt, and the
associated energy costs of each unit, expressed in cents per kilowatt hour. These
costs shall be expressed in terms of individual generating units and of individual
planned firm purchases.
Subsection 2 directs the Commission to consider the availability of capacity from a
qualifying facility during the system daily and seasonal peak periods, and directs consideration
of various factors, such as the ability of the utility to dispatch the QF; expected reliability of the
QF; contract terms; ability to coordinate scheduled outages of the QF; usefulness of the capacity
during system emergencies; individual and aggregate value of the capacity from the QF on the
utility's system; and change in capacity increments and lead times with addition of capacity from
the QF. In short, subsection 2 asks, "how much of the QF capacity can the utility use to avoid
the incremental cost of capacity from another source?" In the canal drop hydro case, the
answer for Idaho Power is "all of it."
Thus, for canal drop hydro, which the canal companies contribute to Idaho Power during
COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2— Page 7
the summer peak season, the canal drop hydro projects should be compensated for 100% of "the
incremental costs to an electric utility of electric ... capacity ... which, but for the purchase from
the qualifying facility or qualifying facilities, such utility would ... purchase from another
source."
Currently, Idaho combines energy and capacity into a combined kilowatt per hour rate for
legally enforceable obligations entered from a published rate for certain types of QF ' s under 10
average megawatts (aMW) in size. For instance, if a canal drop hydro under 10 aMW in size
were to enter a 20 year contract this year (2013), the Second Errata to Order No. 32697 provides
for 68.14 cents per kilowatt hour for both energy delivered and capacity contributed for that
incremental unit. Although it is unclear to this writer what proportion of this discrete unit
figure is for energy and what proportion is for capacity, a hypothetical split will work for this
example so long as it is understood that the capacity portion is 100% of the incremental cost to
the utility for contribution of summer capacity as set out in the Commission's Order and the staff
testimony. Arbitrarily, then, allow the split to be 48.14 cents for energy and 20 cents for
capacity. A canal drop hydro should then be paid 20 cents for every unit of capacity delivering
a unit of energy to the utility.
Idaho Power, in its Petition for Reconsideration, appears to be arguing that they are not
avoiding all the capacity made available to their system during the summer because some canal
drop hydro plants do not operate at 100% of their named or licensed capacity. In view of the
above example, however, where all capacity payments are melded with delivered energy
payments, whether a project can supply its full nameplate or licensed capacity should make no
difference because the capacity payment calculation is not tied to nameplate, but instead is
proofed against the actual energy delivered and the actual capacity in production to deliver that
COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2— Page 8
energy.
Respectfully submitted,
DATED this '2 day of March, 2013.
ARKOOSH LAW OFFICES
C. Tom Arkoosh
Attorneys for Twin Falls Canal Company, North Side
Canal Company, Big Wood Canal Company and American
Falls Reservoir District No. 2
COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2— Page 9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on thisday of March, 2013, I served a true and correct
copy of the foregoing upon each of the following individuals by causing the same to be delivered
by the method and to the addresses indicated below:
Jean Jewell, Commission Secretary U.S. Mail, postage prepaid
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CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2—Page 10
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CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO.2 - Page 13
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COMMENTS OF NORTH SIDE CANAL COMPANY, TWIN FALLS CANAL COMPANY, BIG WOOD
CANAL COMPANY, AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2— Page 14