20040609Reading Direct.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
BOB LEWANDOWSKI AND MARK
SCHROEDER
IDAHO POWER COMPANY CASE NO. IPC-O4-
DIRECT TESTIMONY AND EXHIBITS OF
DR. DON READING
ON BEHALF OF
MARK SCHROEDER AND BOB LEWANDOWSKI
READING
IPC- E-O4-1 0
PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
My name is Don Reading and my business address is Ben Johnson Associates
6070 Hill Road, Boise, Idaho.
WHAT IS YOUR OCCUPATION?
I am a principal with Ben Johnson Associates.
HAVE YOU PREP ARED AN EXHIBIT OUTLINING YOUR
QUALIFICATIONS AND BACKGROUND?
Yes. Exhibit No. 51 serves that purpose.
ARE YOU SPONSORING ANY EXHIBITS WITH THIS TESTIMONY?
Yes. I am sponsoring Exhibit Nos.51 through 53.
WHY ARE YOU TESTIFYING IN THIS CASE NO.IPC-O4-10?
I have been retained by Mr. Lewandowski and Mr. Schroeder to testify as to the
advisability of several terms in a standard offer purchase agreement tendered to my clients by
Idaho Power for the purchase of the output from their proposed wind projects. Idaho Power is
insistent on several contract terms that make it impossible for my clients to develop their
respective projects.
PLEASE DESCRIBE HOW YOUR TESTIMONY IS ORGANIZED.
I will outline the contract provisions at issue in this case and will then discuss
why they are so problematic to a developer of QF projects such as the two wind projects being
proposed by Mr. Lewandowski and Mr. Schroeder. I will then discuss why, in my professional
judgment, theses contract provisions are not necessary to protect the interests of the ratepayers or
1 The parties informally agreed to assign exhibit numbers 51 through 100 to Mr.
Lewandowski and Mr. Schroeder s testimony.
READING
IPC-04-
Idaho Power s shareholders.I conclude by observing some of the many benefits Idaho Power
and its ratepayers would enjoy if Idaho did have a robust and healthy QF industry.
COULD YOU PLEASE BRIEFLY DESCRIBE THE TWO
PROJECTS PROPOSED BY MR. LEWANDOWSKI AND MR. SCHROEDER?
The two projects are quite distinct. However, they both need to have certainty
in their agreement that they will be paid for all of the power they produce. Mr. Lewandowski'
project will, for the current phase, have a total capacity of 325 kw and will consist of three
refurbished 108 kw Micon turbines. Mr. Schroeder s project will consist of eleven 900 kw NEG-
Micon turbines.
WHAT ARE THE CONTRACT TERMS YOUR CLIENTS OBJECT TO?
A. In a nutshell, Idaho Power is requiring my clients to provide an estimate of the
power they intend to produce each month. The draft contract refers to this amount at the "Net
Energy Amount" (Section 1.1).While that has been a standard practice for QF contracts in
Idaho, Idaho Power s proposed agreement provides a penalty if the QF fails to produce 90%
the Net Energy Amount in any given month or if it produces more than 110% of the Net Energy
Amount.
Q. WHAT IS THE PENALTY?
A. If a QF fails to produce 90% of the Net Energy Amount in any given month, then
the amount of energy NOT DELIVERED below the 90% floor is defined by the proposed
contract as "Shortfall Energy" (Section 1.24). If the Market Energy Cost (essentially 85% of
Mid-C) for that month is less than the Base Energy Purchase Price, then the QF owes Idaho
Power nothing. However, if the Market Energy Cost for that month is greater than the Base
Energy Purchase Price, then the QF owes Idaho Power the difference between the market price
and the Base Energy Purchase Price. Essentially, this means that the QF is paYing Idaho Power
for power not produced at eighty five percent of the Mid-C price.
READING
IPC-04-
Q. WHAT IS THE "MID-
A. The Mid-C is a market index for wholesale electricity prices in the Pacific
Northwest. It is a transparent market that reflects energy prices in general and is influenced by
national and international events. For example, Mid-C prices are influenced by the price of oil
and natural gas, ambient air temperatures in Southern California and have even been affected by
the market manipulations of the recent past. The Mid-market produces prices that are
inherently unpredictable and that can spike rather dramatically. For example at the height of the
California Energy Crisis" Mid-C prices actually exceeded $5 000 per Mwh. Today Mid-C is
trading around $30 to $40 per Mwh. My clients understandably objected to a provision in their
contracts that would impose Mid-C liability on them for power they do not produce.
Q. WHAT IS THE BASIS FOR YOUR CLIENTS' OBJECTIONS?
First, they believe, and I concur, that under the Federal Law known as PURP A
they are entitled to be paid full avoided cost rates for all of their production and that requiring
them to PAY FOR POWER NOT PRODUCED is a concept not provided for in PURPA -
however that is an issue that I will leave to the lawyers to argue. However, fundamentally this is
a penalty that has no limit, making these projects impossible to finance or build. No rational
individual would expose himself to the unlimited liability of a penalty tied to a market price that
can be as high as $5 000 a Mwh when they are only being paid approximately $50 a Mwh.
PURPA was meant to provide a 'level plaYing field' between a QF facility and the Company
generating units. As recent events have shown, Idaho Power was able to recover the major
portion of high market rates through the PCA. As structured in the draft contract, there is no way
for the QF developer to recoup any of this proposed penalty. That is why my clients objected to
the Shortfall Energy concept and the Shortfall Energy Price in the draft contract they were
presented with by Idaho Power.
READ IN G
IPC- E-04-1 0
Q. HAS IDAHO POWER RESPONDED TO YOUR CLIENTS' CONCERNS
RELATIVE TO SHORTFALL ENERGY AND THE SHORTFALL ENERGY PRICE?
A. The Company did slightly change its position as noted in a letter sent after our
complaint was filed. A copy of that letter is attached as Exhibit No 52. It essentially places a cap
on the Shortfall Energy Price at 150% of the Base Energy Purchase Price multiplied by the
amount of Shortfall Energy.
DOES THAT CAP SOLVE YOUR CLIENTS' CONCERNS ABOUT
SHORTFALL ENERGY?
While it is a step in the right direction it is still unacceptable.
Q. WHY IS IT STILL UNACCEPT ABLE, ISN'T THE CONCEPT OF
UNLIMITED LIABILITY THE ISSUE WITH YOUR CLIENTS' INABILITY TO
FINANCE A PROJECT WITH IDAHO POWER?
A. There is simply too much uncertainty associated with a QF having to pay Idaho
Power 150% of the purchase price multiplied by the amount not produced for a failure to
produce. Prudent lenders and financial backers would balk at the risk that these developers
might be faced, at any time, with such a liability. Just as importantly, there is no need for such a
liquidated damages" clause in a QF PURP A contract.
Q. WHY DO YOU USE THE PHRASE "LIQUIDATED DAMAGES" IN YOUR
ANSWER?
A. That is the phrase used by Idaho Power in its letter offering to cap the Shortfall
Energy payments at 150% of the contract price. In his letter of May 21 , 2004, which is attached
27\\
as Exhibit No. 52, Mr. Kline makes the following statement:
Idaho Power has considered this concern further and is hereby
offering to place a cap on Developers' liquidated damages exposure if
Developers fail to provide 90% of the agreed-upon energy in any month.
READ IN G
IPC- E-04-1 0
, it is apparent that Idaho Power is viewing this penalty as liquidated damages. I am
an economist and often testify on damages and how to measure damages. So, I understand the
concept of liquidated damages. It is designed for parties to a contract to define damages, in
advance of a possible breach, so that if a breach occurs there is no dispute over either the level of
damages or the methodology used to measure those damages. I looked up the definition of
liquidated damages and have confirmed that this is the common understanding of why such
clause is inserted into contracts.The approach taken by the Company shifts the risk
generation downtime to the QF. Idaho Power has the PCA that allows it to recover 90% of its
power supply costs (and keep 10% of power supply benefits for its shareholders) and thus
mitigates against open-ended liability should it need to purchase market energy to compensate for
an off-line generation unit. In my opinion, it is completely inappropriate to use any liquidated
damages clause in a Q F contract.
Q. WHY?
A. First, the underlYing reason for a liquidated damages clause is missing. If a power
supplier breaches its commitment to deliver power to an investor owned utility such as Idaho
Power, that IOU has tools readily at its disposal for calculating whether, and by how much, it is
damaged. Second, the liquidated damages provision makes it extremely difficult or next to
impossible to finance a QF project. PURP A charges the Commission with the duty to encourage
the development of QF - not place insurmountable roadblocks in their path. Third, when a QF
facility is down - the QF doesn t get paid. That is incentive enough to for QFs to be reliable and
to do all in their power to insure that their plants are reliable. In addition, and importantly, it
places an asymmetrical burden of risk on the QF.
READING
IPC- E-04-1 0
Q. WHAT DO YOU MEAN BY AN ASYMMETRICAL BURDEN OF RISK ON
THE Q
A. When a utility s own plant fails to produce or has an unscheduled outage, the
ratepayers cover the costs associated with replacing the expected output from that plant. The
shareholders are held harmless. Idaho Power wants to have the best of both worlds by placing
the risk of unscheduled outages on QF developers while enjoYing the advantage of placing the
risk of unplanned outages at their own plants on the ratepayers. That strikes me as fundamentally
unfair and a violation of the principles of PURP A. I doubt the financial community would look
with favor on Idaho Power if this Commission ruled that in drought years Idaho Power
shareholders would be responsible for all of the excess power supply costs it would incur to
replace the reduced generating capacity from its hydro system. In fact, if that were the case, I
would expect the finance community to completely stay away from any investment in Idaho
Power - the same is true for QFs
ARE THERE OTHER EXAMPLES OF ASYMMETRICAL RISKS
CAUSED BY IDAHO POWER INSISTENCE ON CONCEPTS SUCH AS SHORTFALL
ENERGY?
A. Yes. For example, Section 14.3.1 states that the company does not pay the project
during times when there is " . . . line construction or maintenance requirements, emergencies
electrical system operating conditions
. .
" Hence, when Idaho Power stops accepting and
paYing for the production due to "operating conditions" on its system it simply stops doing so
with no compensation to the QF developer. That is another example of asymmetrical risks
imposed by this proposed contract.
READ IN G
IPC- E-04-1 0
Q. IS THERE A LEGITIMA TE CONCERN ON IDAHO POWER'S PART
RELATIVE TO THE FAILURE OF A QF TO DELIVER CONTRACTED FOR
POWER?
A. Absolutely not. Idaho Power has approximately 70 QF contracts in place that are
currently delivering power to the company. None of those producing agreements has a shortfall
energy provision. It is only since the Commission returned to the 20-year contract and
megawatt threshold for entitlement to published rates that the company came up with the concept
of shortfall energy. I understand that there are three agreements that have been signed with this
provision, however the Commission made it clear that these contracts should not be considered
as setting a precedent. (Idaho Public Utilities Commission Order NO. 29232, April 15, 2004).
In addition two of those agreements are for facilities located in Montana making them unique in
terms of having to preschedule their deliveries for wheeling purposes.
HISTORICALLY, WHAT HAS BEEN IDAHO POWER'S EXPERIENCE
WITH THE RELIABILITY OF THE QF INDUSTRY?
Looking at the report published by Idaho Power on cogeneration and small power
production, it is apparent that the QF industry is, in fact, quite reliable. For instance, that report
shows that for the year to date ending December 2003, the QF industry had produced and
delivered 71.47 percent of the amount of energy it had contracted to deliver and for the year 2002
that figure was 75.65 percent. See Exhibit No. 53. That is remarkable especially in light of the
fact that 2002-03 was close to a record drought year and that the vast majority of Idaho Power
QF contracts are hydro based. Taken as a whole, the QF industry is extremely reliable and
dependable. There is no need to single out new QF contracts to impose this penalty clause. The
industry has a proven track record that can be relied upon by Idaho Power and its ratepayers.
READING
IPC- E-04-1 0
WHAT ELSE DO YOU LEARN FROM THE STATISTICS SHOWING
THAT THE QF INDUSTRY AS A WHOLE GENERATED APPROXIMATELY 70%
Idaho Power is proposing a 90 percent band knowing full well that the industry
average is 70 percent. This is further evidence that Idaho Power is actually attempting to prevent
the development of new QFs.
Q. SINCE THE INDUSTRY AS A WHOLE HAS A PROVEN AND RELIABLE
TRACK RECORD ABO UTSHOULDIDAHOPOWER CONCERNED
INDIVIDUAL DEVELOPERS FAILING TO PRODUCE THEIR CONTRACTED
AMOUNT?
A. Again, absolutely not. First, as I noted above, individual developers are already
highly motivated to make sure their projects produce - if they don t produce they don t get paid.
However, from the perspective of Idaho Power, no individual developer s project is large enough
to cause concern from an operations standpoint. QF standard contracts are limited to ten
megawatts - a mere drop in the bucket to a utility the size of Idaho Power. Again, I need to
strongly emphasize, the system has worked for twenty-five years with no need to impose a
shortfall clause in any of the existing 70 QF contracts. Nothing has changed that suggests there is
a problem with QF reliability and nothing has changed that suggests a need to impose a
draconian penalty for failure to deliver.
Q. WHAT ARE YOUR CONCERNS RELATED TO THE CONCEPT OF
SURPLUS ENERGY"
A. The Company proposes to pay for energy delivered that is in excess of 110% of the
contracted amount at the LOWER of either 85% of Mid-C or the contract price. Obviously,
Idaho Power is overreaching here with a heads they win and a tails the QF loses pricing scheme.
Assuming the QF has not increased the size above the ten megawatt threshold for entitlement to
published rates, Idaho Power should be required to pay the contract price for all energy produced
READING
IPC-04-
and delivered by a QF. The Company is simply attempting to hold the QF industry to an
unattainable standard. Not even Idaho Power can guarantee the output of its own system within a
90-110% band. One need only to look to the Danskin plant with its $13 per kWh cost to see an
example of the uncertainties inherent in developing generating projects. Despite the failure of
that project to provide cost effective energy, Idaho Power is still recovering all of the costs
associated with it from the ratepayers.
Idaho Power should be mandated by this Commission to stay with the form of contract
used prior to this "generation" of contracts under which the QF is paid for power delivered and
not paid for power not delivered. It is a simple and fair arrangement for the ratepayers, Idaho
Power and the QF developer.
Q. DO YOU HAVE ANY OBSERVATIONS ON THE "REGULATORY OUT"
LANGUAGE IN THE PROPOSED CONTRACTS?
A. I do. Tucked away under a heading entitled "Governmental Authorization" is a
clause that provides that Idaho Power may terminate the agreement at its sole discretion if "Idaho
law is modified to allow persons. . . other than Idaho Power to sell electric capacity or energy at
retail in Idaho Power s exclusive service territory, and . . . such change in law results in Idaho
Power being unable to fully recover all costs associated with this Agreement." This seemingly
innocuous clause is fraught with ambiguity, danger, uncertainty and inaccuracies.
Q. PLEASE EXPLAIN.
A. First there is no such thing as "exclusive service territories" for utilities operating
in Idaho. As I understand it, I could start a cooperative utility today anywhere in Idaho Power
service territory as long as my customer is more than ~ of a mile from an existing Idaho Power
service line.Then I could extend my lines through Idaho Power s service areas and, if
legitimately extended, would be able to serve all new customers that are closer to my lines than
READING
IPC-04-
they are to Idaho Power s lines. Although prohibited from pirating another utility s existing
customers, I could legitimately invade Idaho Power s service territory.
Second, the phase "fully recover all costs associated with this Agreement" is very
problematic. In a deregulation scheme IOU', such as Idaho Power, would likely be expected to
net out their stranded costs from their stranded benefits resulting in an overall settlement of who
is owed what. I would anticipate that QF contracts would be lumped together as a single line
item and other company-owned generating assets would likewise be a line item cost and or
benefit. Who is to say, in such a global settlement which specific agreement had its costs
covered? It might be like a global settlement of a general rate case for a specific dollar amount
without deciding which specific rate base item is included or excluded. I fear such a scenario is
extremely likely in the event deregulation comes to Idaho. If Idaho Power felt it did not recover
all of its stranded costs, it could point to the QF industry and claim they were the cause of their
shortfall.
Third, who would make the call relative to whether or not Idaho Power had recovered
all of its costs? Would the Commission do so or would the parties have to go to court? This
clause is simply too problematic for Idaho Power to insist on its inclusion in QF agreements.
Idaho Power already has a clause requiring this Commission s approval of the agreement for
ratemaking purposes - nothing more is needed from their reasonable perspective.
Q. YOUR CLIENTS ARE PROPOSING WIND PROJECTS. DO YOU HAVE
ANY CO MMENTS SPECIALWHETHERTHEYSHOULDRECEIVE
TREATMENT RELATIVE TO ESTIMATING PRODUCTION?
A. As long as Idaho Power is required to purchase all output from the QF project with
no 90-110% band for determining shortfall or surplus energy prices, I do not see any need to treat
wind differently from other projects. Wind is a variable product in much the same way hydro is a
variable product. In fact, Idaho Power is seriously considering including wind as a major part of
READING
IPC- E-04-1 0
its resource portfolio in its upcoming Integrated Resource Plan. It is a legitimate QF resource
that deserves to be treated the same as all other legitimate resources.
Q. DOES THIS CONCLUDE YOUR TESTIMONY?
A. Yes, it does.
READ IN G
IPC- E-04-1 0
EXHIBIT
Present position
Education
Professional
and business
history
Don C. Reading
Don C. Reading
Consulting Economist with 8en Johnson Associates. Inc.
S.. Economics - Utah State University
S.. Economics - University of Oregon
Ph.D.. Economics - Utah State University
Idaho Public Utilities Commission:
1981-86 EconomisUDirector of Policy and Ad ministration
Teaching:
1980-81 Associate Professor, University of Hawaii-Hilo1970-80 Associate and Assistant Professor, Idaho State University
1968-70 Assistant Professor, Middle Tennessee State University
Dr. Reading provides expert testimony concerning economic and
regulatory issues. He has testified on more than 25 occasions before
utility regulatory commissions in Alaska, California, Colorado, the District
of Columbia, Idaho, Nevada, Texas, Utah. and Washington.
His areas of expertise include demand forecasting, long-range planning,
price elasticity. marginal pricing, production-simulation modeling, and
econometric modeling. He has also provided expert testimony in casesconcerning loss of income resulting from wrongful death, injury, oremployment discrimination.
Dr. Reading has more than 30 years experience in the field of economics.
He has participated in the development of indices reflecting economic
trends. GNP growth rates. foreign exchange markets, the money supply,stockmarket levels, and inflation. He has analyzed such public policy
issues as the minimum wage, federal spending and taxation, and
imporUexport balances. Dr. Reading is one of four economists providing
yearly forecasts of statewide personal income to the State of Idaho for
purposes of establishing state personal income tax rates.
Dr. Reading s areas of expertise in the field of energy include demand
forecasting, long-range planning, price elasticity, marginal and average
cost pricing, production-simulation modeling. and econometric modeling.
Among his recent cases was an electric rate design analysis for the
Industrial Customers of Idaho Power.
While at Idaho State University, Dr. ReadinQ performed demoQraphic
Exhibit 51
Don C. Reading
studies using a cohorUsurvival model and several economic impact
studies using inpuUoutput analysis. He has also provided expert
testimony in cases concerning loss of income resulting from wrongful
death, injury, or employment discrimination.
Among Dr. Reading s current projects are a FERC hydropower
relicensing study (for the Skokomish Indian Tribe) and an analysis of
Northern States Power's North Dakota rate design proposals affecting
large industrial customers (for J.R. Simplot Company). Dr. Reading has
also recently completed an analysis for the Idaho Governor's Office of the
impact on the Northwest Power Grid of various plans to increase salmon
runs in the Columbia River Basin.
Publications
The Economic Impact of Steelhead Fishing and the Return of Salmon
Fishing in Idaho, Idaho Fish and Wildlife Foundation, September, 1997.
Cost Savings from Nuclear Regulatory Reform, Southern Economic
Journal, March, 1997, with R. Canterbery and B. Johnson.
A Visitor Analysis for a Birds of Prey Public Attraction, Peregrine Fund,
Inc., November, 1988.
Investigation of a Capitalization Rate for Idaho Hydroelectric Projects
Idaho State Tax Commission, June, 1988.
Post-PURPA Views," In Proceedings of the NARUC Biennial Regulatory
Conference, 1983.
An Input-Output Analysis of the Impact from Proposed Mining in the
Challis Area (with R. Davies). Public Policy Research Center, Idaho State
University, February 1980.
Phosphate and Southeast: A Socio Economic Analysis (with J. Eyre, et
al). Government Research Institute of Idaho State University and the
Southeast Idaho Council of Governments, August 1975.
Estimating General Fund Revenues of the State of Idaho (with S.
Ghazanfar and D. Holley). Center for Business and Economic Research
Boise State University, June 1975.
A Note on the Distribution of Federal Expenditures: An Interstate
Comparison, 1933-1939 and 1961-1965." In The American Economist,
Vol. XVIII, No.2 (Fall 1974), pp. 125-128.
New Deal Activity and the States, 1933-1939." In Journal of Economic
History, Vol. XXXIII (December 1973), pp. 792-810.
Exhibit 51
EXHIBIT
IDAHO IDAHO !'OWER COMPANY
.... ,.
POWER O. BOX 70~ BOISE, IDAHO 83707
An IDACORP Company
BARTON L. KLINE
Senior Attorney
May 21 2004
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Peter J. Richardson
Richardson & O'Leary, PLLC
99 E. State Street, Suite 200
O. Box 1849
Eagle , ID 83616
Re:Case No. I PC-04-1 0
Lewandowski and Schroeder v. Idaho Power Company
Dear Peter:
The purpose of this letter is to advise you and your clients of a change
Idaho Power is proposing to make to respond to one of the concerns raised in your
complaint. Idaho Power will present this change as a part of its case in the above- '
referenced proceeding, and I wanted to advise you of this change so that you can take
it into consideration in preparing your testimony.
In its complaint, Lewandowski-Schroeder ("Developers ) object to Idaho
Power s proposed contract provisions that require Developers to pay Idaho Power
liquidated damages based on additional market purchase expenses Idaho Power may
incur if Developers do not deliver 900/0 of the energy they have agreed to provide in any
month ("Shortfall Energy
).
Developers have expressed concern that this liquidated
damage obligation could be prohibitively expensive.
Idaho Power has considered this concern further and is hereby offering to
place a cap on Developers' liquidated damages exposure if Developers fail to provide
900/0 of the agreed-upon energy in any month. Idaho Power proposes to limit
Developers' exposure in any month to a dollar per MWh amount equal to 1500/0 of the
net energy price for the month in which the shortfall occurs multiplied by the shortfall
amount.
As an example of how, this cap would operate, assume hypothetically that
Developers had agreed to provide 6MW (4 464 MWh) during the month:of J.uly.
. .
Further assume the contract price for net energy delivered in the month of July was $50
per MWh and the weighted average Mid-C market price in July was a highly abnormal
$200 per MWh. If Developers only delivered 2 MW (1 488 MWh) in the month of July
Exhibit 52
Telephone [phone] Fax [phone], E-mail BK/inefij)idahopower.com
Peter J. Richardson
Page #3
May 21 2004
Idaho Power realizes this is just one item in your complaint. Nevertheless
the Company thought it was appropriate to advise you ahead of time as to the position
Idaho Power will take on this issue in its testimony in this case.
ve~(!rtL-
Barton L. Kline
BLK:jb
cc:John Prescott
Scott Woodbury
Exhibit 52
EXHIBIT
This report is only for "P!-JR~A" projects and does not include "Net Metering" Projects.
Contracted Kwh
Actual vs
Contract
75.85%
75.65%
IIJAHO
POWER
An I DACO RP Company
Cogeneration and Small Power Production
As of Month ending: December 2002.
Current Month
Year to Date
Inception to Date
Net Kwh
616 289
692,413 504
948,450 165
Mills/Kwh
68.
63.45
60.
Energy Payment
$2,442 079
$43 931 661
$660 665,936
Kwh
959 205
915 236 175
Projects Under Contract
Wood Waste
Biomass
Hydro
Wind
Natural Gas
Industrial Waste
Total Projects under contract:
Number of Projects
Nameplate RatinL-Kw
. 9 500 9.
640
127 587 127.
100 000 25.000 12.
174,827 174.
Proposed Projects
These are new projects / proposals to Idaho Power Company that have gone beyond an initial simple inquiry and are in various
stages of more advanced research and/or planning:
Proposals
Final Contracts
PendingContract Review
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Current Contract Parameters available
~i~~;~:€.~~~r~:~t~;'i.
: :: .:~:. .
~on"
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~:H
~~,
~~~ct
::::,,:..., ,. .
-Published. Avoided cost
: :'
h&dule(86 :ild:;~to; Mw
. .:'~~~~..
ag~~~1~~t~:' Pcn~=85:%!~r~~~tket-
No;:.genera.tiQ:~::;~qm.tr1"itment .
ApP'r(:));(!;'4;:a.c~i1t$t'per ;:Kwh No:$ettern1"cWcol1tract
All OF's greater then 1 0 Mw, contracts are negotiated individually.
'Net,Meterin~r::(Schedul~d,84).
: .
i . "
'JR~~lg~riti~~;::~:HpJi!S:t)')~JEComm~rcial:: Les$.;t~err25;, Kw.
Larg e::Cbmro~rqi 81(I'tr i 9 ~tio n ;:etc:::' Less in en.tOO.. KW Exhibit 53
. ..
n~('pmh~r ?nn? r.!=:PP c:t";,, Ie ronnri for f!j. f17/?nn~
An IDACORP company
Cogeneration and Small Power Production
As of Month ending: December 2003
This report is only for "PURPA" projects and does not include "Net Metering" Projects.
Current Month
Y ear to Date
Inception to Date
Net Kwh
34~333 926
654,131,414
602 581 579
Ener9Y ment
068,573
$38~ 186 005
..
$698;6.51,941
Mills/Kwh
60.
58.
60.
Contracted Kwh
Actual vsKwh Contract
46,959 205
915 235,545
73.11 %
71.47%
Projects Under Contract
'..'.
, NameplaterRating
Number of Projects
500
640
127 787 127.
100
25;000 25.
000 12.
175 027 175.
Projects Online
Wood Waste
Biomass
Hydro
Wind
Combined Heat and Power
Industrial Waste
Total Projects under contract:
Note - Online date for the project under contract but not on line is May 2004.
. Nameplate Rating
Number of Projects Mw'
. 9 500
640 0:64
134 787 134.
100.
25iOOO 25.
000 12.
182 027 182.
Proposed Pro ects
These are new projects proposals to Idaho Power Company that have gone beyond an initial simple inquiry and are in various
stages of more advanced research and/or planning:
Proposa s Contract Review Fmal ontracts
Developer ~c:isrequested
Developer is exploring Draft Energy Sales Energy. S~les;,Agreenient has.
contract options and Agreement and is been finalized arid is. pending Total' Nameplate
potential opportunitities currently reviewing signatures and various approvals'Rating
Projects Projects.Projects
Wood Waste 000 17,000 17.
Biomass 000 000 000 14.
Hydro 000 250 . 12 250 12.
Wind
"'
600 000 600
Geothermal . 1 1 00 000 1 0 000 110 000 110.
Industrial Waste . 10 000 500 .16,500 16.
Combined Heat and Power 000 000 25.
Total Proposed Projects:to.147 000 850 500 204 350 204.
Current Contract Parameters available
Firm Contracts"Non Firm Contracts
Published Avoided cost Schedule 86. UP 10.10 Mw
to to'Mw units Price ::'85 % of Market:
. Up: to .20 years '. No generation comr:nitment
Ap rox:SAcents per Kwh No.setlerm of. contract
I AII.Of's greater then 10 Mw, contracts are negotiated iridiVidualty;:.
et Meter edule 84.1
, ,
, Residential. and Small Commercial: Less then 25 KW:'
Lar e'Commercial, Irri atian, etc:tessthen'100Kw.Exhibit 53
Dee 2003 CSPP Status.xls / RCA /1/14/2004
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this4lbday of June, 2004, I caused a true and
correct copy of the foregoing DI~CT TESTIMONY AND EXHIBITS OF DR. DON
READING ON BEHALF OF MARK SCHROEDER AND BOB LEWANDOWSKI to be
served by the method indicated below, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
( ) U.S. Mail, Postage Prepaid
(X) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( )
Electronic Mail
Monica B. Moen, Attorney II
Barton L. Kline, Seniior Attorney
Idaho Power Company
PO Box 70
Boise, ID 83707-0070
bkline~idahopower. com
mmoen~idahopower. com
(X) U.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
Randy C. Allphin, Contract Admin.
Power Supply Planning
Idaho Power Company
Post Office Box 70
Boise, Idaho 83707-0070
raIl phin~idahopower. com
(X) U.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
John Prescott
Vice-President - Power Supply
Idaho Power Company
Post Office Box 70
Boise, Idaho 83707-0070
prescott~idahopower. com
(X) U.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
Conley E. Ward
Givens Pursley LLP
601 West Bannock
Po Box 2720
Boise, Idaho 83701-2720
cew~gi venspurslev. com
(X) U.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
IPC-O4-10 & IPC-O4-
CERTIFICATE OF SERVICE -
Doug Glaspey
S. Geothermal
1509 TYrell Lane
Boise, Idaho 83706
dglaspey~us geothermal. com
(X) U.S. Mail, Postage Prepaid
. ( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
Signed
Nina Curtis
IPC-O4-10 & IPC-O4-
CERTIFICATE OF SERVICE - 2