20050718Grover direct and exhibit.pdf

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Dean J. Miller ISB #1968
McDEVITT & MILLER LLP
420 West Bannock Street
O. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: 208.336:6912
ioe~mcdevi11:miJ1er .com
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UflLlTlES COr'1f~1ISSION
Attorneys for Magic Wind LLC, Cassia
Wind Farm LLC and Cassia Gulch
Wind Park LLC (Magic and Cassia)
OR' GI NAL
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR AN
ORDER TEMPORARILY SUSPENDING
IDAHO POWER'S PURPA OBLIGATION TO
ENTER INTO CONTRACTS TO PURCHASE
ENERGY GENERATED BY WIND-
POWERED SMALL POWER PRODUCTION
FACILITIES.
Case No, IPC-O5-
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
DIRECT TESTIMONY OF JARED GROVER
Please state your name and business address.
My name is Jared Grover and my business address is 3635 Kingswood
Drive, Boise, Idaho 83704.
What is your association with or relation to Cassia Wind Farm LLC and
Cassia Gulch Wind Park LLC (collectively Cassia Wind) interveners
this case?
I am the owner and manager.
Please describe your professional and business background.
I received my Masters of Accountancy -Taxation from Boise State
University. I am a farmer in the Hagerman Idaho area. Because of high
power rates in 2004, I could not afford to irrigate, and moved to Boise.
With power rates high and not expected to substantially be reduced, I
decided I would not be able to afford to irrigate another season and I sold
my water rights on my farm. Now, the best use of my farm, and those
around me, is to develop wind. I am currently working full-time
developing these wind projects.
Please describe the wind generation projects Cassia Wind is proposing to
develop.
Cassia Wind is developing two wind projects in Twin Falls County. One
is located on my farm, and the other is on another local farmer s land who
has also sold his water rights. The wind projects total capacity will be
18.9MWand 10.5MW.
What is the intended date for the project to achieve commercial operation?
Grover, Di
Magic Wind LLC
We intend to have the first project (18.9 MW) operational by year-end
2005.
Is there a benefit to achieving commercial operation by year end 2005?
Under the current tax legislation, a Production Tax Credit (PTC) is given
to new wind projects over the first 10 years of operation. The PTC credit
provides an incentive for investors to invest in wind projects and makes
the projects economically feasible. The PTC is set to expire at the end of
the 2005. Because of the upcoming expiration, investors are putting their
money into projects that can be completed before year end. If a project is
not likely to be completed before the PTC credits expire, the investors will
go elsewhere.
Another benefit of completing a project before 2005 is that turbines are
scarce and increasing in price. Most manufacturers have filled orders
through the middle to 3rd quarter of2006. If a project is postponed, it is
difficult to convince the manufacturers to hold the turbines instead of
simply selling them to other willing and able buyers. Based on what has
happened in the last year, more delay before taking delivery of turbines
will mean increased costs.
Please describe the activities Cassia Wind has undertaken with a view
toward achieving commercial operation by year end 2005.
Many activities have been, and are being done to have the project
completed in time to be eligible for the PTC's. I have purchased a 50
Meter anemometer tower, and also have a percentage ownership of 4 other
Grover, Di
Magic Wind LLC
anemometers within 10 miles of the project. We have been collecting data
from some of the towers for several years. From these anemometers, I
have spent significant amounts of time and money compiling and
analyzing the data. I have negotiated land lease contracts, and initiated the
local permitting process. I have personally invested tens of thousands of
dollars into the project. To facilitate achieving commercial operation by
year end I traveled in and out of the state to meet with equipment
manufacturers and potential investors. Long term financial projections
have been created for the projects using the wind data, current turbine
prices, financing rates, construction costs, and PURP A rates. Using these
projections, private investors and bank loans have been found for
financing. The investors are requiring a signed PP A before money is
spent on further development such as ground preparation, or paying the
large down payment required for delivery of the wind turbines. I have met
with Idaho Power Co.s engineers as part of the interconnection study.
am currently waiting for a completed interconnection agreement and a
power purchase agreement.
Has Cassia Wind submitted an Interconnection Applications to Idaho
Power Company?
Yes. Attached to my testimony as Exhibit No. 602 is a correct copy of our
submitted Interconnection Applications.
Does submission of an Interconnection Application carry with it a
financial commitment?
Grover, Di
Magic Wind LLC
Yes, according to Idaho Power Company procedures, a feasibility analysis
fee of $10 000 or $2000, depending on size, for each project must be paid
at the time the Application is submitted.
Did Cassia Wind pay the required fees?
Yes it did.
Would Cassia Wind have submitted the Interconnection Applications and
paid the analysis fee if it did not seriously intend to complete the project?
Absolutely Not. Submission of an Interconnection Application is a
substantial milestone in the development process. If the project was not
viable we would have abandoned the project at an earlier stage, perhaps
even before spending money on additional anemometer towers, meetings
and seminars to meet with and work with manufacturers and investors.
am working full-time on these projects and I assure you that Cassia Wind
is very serious about making these projects a reality.
Has Cassia Wind requested to receive Firm Energy Sales Agreement from
Idaho Power Company?
Yes. I have requested to receive Firm Energy Sales Agreement from
Idaho Power but have not yet received one. Upon submittal of my first
interconnection study application I followed the instructions outlined on
the Generation Interconnection Application. It says "Upon receipt of these
items, Idaho Power Company will notify you in writing of the applicable
contract application date and begin the process of drafting the appropriate
energy sales agreement for your review." (see page 2 of the application
Grover, Di
Magic Wind LLC
instructions) I submitted the items and expected to receive a draft of an
energy sales agreement. One application was submitted on 5/26/2005 and
the other on 6/15/2005 (accepted by Idaho Power on 6/16/2005).
6/17/2005 I emailed my Idaho Power Contact Randy Alphin and again
requested my PP A be started. I later called and left another message to
which Randy called me back shortly. He explained that Idaho Power
would not be signing any new contracts until the PUC had decided on this
issue. Upon my request by email I was sent an email summarizing that
part of our conversation.
Have you had any other conversations relating to your Power Purchase
Agreement?
Yes. I talked to Randy Alphin again and asked him if it were possible to
negotiate a contract, even considering a lower price because my investors
are wanting to continue with the project, or move on to other projects.
wanted to know if there was any way that I could get a signed contract.
We discussed the possibility of negotiating a contract with a lower Rate in
exchange for excluding or substantially reducing the 90/110 rule from the
contract. The next day Randy called me and told me Idaho Power has
decided to wait until after the PUC has decided on this case.
In undertaking the development activities you have described, did Cassia
Wind rely on the Commission s policies and procedures being stable and
predictable?
Grover, Di
Magic Wind LLC
Yes. Much preparation on my part has been put into getting these projects
through the preliminary stages of data collection and economic feasibility.
Investors, manufacturers, and contractors have placed good faith in the
completion of these projects. All of us rely on the Commission
maintaining stable and predictable policies.
If the Commission were to grant Idaho Power s requested "temporary
suspension" could not Cassia Wind simply temporarily halt its
development efforts and then resume after the suspension terminated?
No. It is important for the Commission to understand that although the
Company s request is phrased in terms of "temporary suspension" it is, in
effect, a death sentence for our projects. It would be very difficult to
restart these projects. The loss of the investors and turbines on this project
would not only leave a bad name on the Cassia Wind projects, but the very
economic fundamentals will change substantially. As explained earlier
turbine prices continue to rise due to high demand and high steel prices.
Investors will be turned off by projects that look risky because it has
stopped before, and they will also not be interested it the PTC tax credits
are not available. In addition, part of the project financing is planned to be
based on bank loans. If interest rates continue to rise, as they are expected
, the higher rates will substantially increase the expenses of the project
which will also discourage investors.
Does this conclude your testimony?
Yes it does.
Grover, Di
Magic Wind LLC
CERTIFICATE OF SERVICE
I hereby certify that on the y of July, 2005 , I caused to be served, via the
methodes) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
i iewell(fYpuc.state.id. us
Barton L. Kline
Monica B. Moen
Idaho Power Company
1221 West Idaho Street
O. Box 70
Boise, ID 83707
BKline(fYidahopower. com
MMoen(fYidahopower.com
Linda Nordstrom
Pacifi Corp
825 NE Multnomah, Suite 1800
Portland, OR 97232
lisa.nordstrom(fYpacificorp. com
Fax: [phone] '
Bob Lively
Pacificorp
One Utah Center, 23rd Floor
201 S. Main Street
Salt Lake City, UT 84140
bob .li vel y(fYpacificorp. com
Fax: [phone]
William J. Batt
John R. Hammond, Jr.
Batt & Fisher, LLP
U S Bank Plaza, 5th Floor
101 South Capital Boulevard
O. Box 1308
Boise, ID 83701
Fax: [phone]
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Hand Delivered
S. Mail
Fax
Fed. Express
Email
Grover, Di
Magic Wind LLC
Michael Heckler Hand Delivered
Director of Marketing & Development S. Mail
Windland Incorporated Fax
7669 West Riverside Drive, Suite 102 Fed. Express
Boise, ID 83714 Email
mheckler(fYwindland. com
Fax: [phone]
Peter J. Richardson Hand Delivered
James T. Carkulis S. Mail
Richardson & O'Leary PLLC Fax
99 East State Street Fed. Express
O. Box 1849 Email
Eagle, ID 83616
peter(fYrichardsonandoleary .com
Fax: [phone]
Glenn Ikemoto Hand Delivered
Principal S. Mail
Energy Vision, LLC Fax
672 Blair Avenue Fed. Express
Piedmont, CA 94611 Email
lenni (illpac bel 1. net
Fax: [phone]
Richard L. Storro Hand Delivered
Director, Power Supply S. Mail
1411 E. Mission Ave.Fax
O. Box 3727, MSC- 7 Fed. Express
Spokane, WA 99220-3727 Email
dick. storro(fYavistacorp. com
Fax: [phone]
R. Blair Strong Hand Delivered
Paine, Hamblen, Coffin, Brooke &S. Mail
Miller LLP Fax
717 West Sprague Ave., Suite 1200 Fed. Express
Spokane, W A 99201-3505 Email
r. blair .strong(fYpainehamblen.com
Fax: [phone]
Grover, Di
Magic Wind LLC
Date received by Idaho Power Company
Interconnection Application
for Small Generators -(20 MW
1. Project Name
A55 r/f 11
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pa. ('
An IDACORP Company
2. Description of Project
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3. Proposed In-Service Date
LO CL-C- 1 () 0
4. Total Project Name Plate Rating
(in kW or MW) (If multiple units at same location, add name plate ratings of each unit together)
5. Energy Output (current intention)
Sell energy output to Idaho Power Company (If this is a PURPA, Qualifying Facility (QF), please attach a copy of the FERC-QF certification)
Transport energy output outside of the Idaho Power Company Service Territory
Net Metering Other (Please describe)
6. Initial Feasibility Analysis Fee
Based upon Total Project Name Plate Rating (kW), the initial feasibility analysis fee will be:
D less than 1 000 kW-$100 D 1 000 thru 10,000 kW-000 ~. Greater than 10,000 kW-$10,000
This fee will be applied to the costs of processing this application for interconnection and for the initial feasibility analysis. In the event the actual
costs of the initial feasibility analysis exceed this fee, the applicant will be responsible to pay all additional costs. If after the initial feasibility analysis
is completed, the applicant decides to proceed with this project, additional detailed system impact study costs, all interconnection costs, and any
other a licable rocessin fees will be the obli ation of the a Ii cant.
7. Project location (Please provide sketc" or map)
General Location el e rvv, c\,..,
State
Range
OR Street Address
Township
Section f1/1 a
Nearest Intersection ~ee
8. Project Owner/Developer
Company
Contact
City
Phone
(2f) 1 )
State
Fax
70"-
(2-0%
Note: This application is an interconnection request, not a request for transmission service. This application does not address the requirements
for additional studies and/or upgrades for any transmission services that might be required for delivery of energy to a purchaser other than Idaho
Power Company. Under our Open Access Transmission Tariff rules, procedures for obtaining transmission service are posted on our OASIS
site at: http://oasis.idahopower.com.
Owner/Authorized Agent
Name (Type o~t)
Title and Company
Signature:
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Date received by Idaho Power Company
Project Description Questionnaire
for Small Generators -=:20 MW
1. Project Name
I C65~f4 0-1/ w.~J Pc.rl
2. Description of Energy SourceHydro FERC License No. or FERC exemption No.
IXr Wind
Geothermal
Biomass or Waste
Unit Size(s)Number of Units
Type of Fuel Source of Fuel
Thermal
Other
Fuel
3. Generation Data
Estimated Annual Generation ((kWh)Estimated Project Capacity (kW)
(If th~ Estimated Project Capacity is less than 100 kW
proceed to item 5 of this questionnaire)
Non-Dispatchable Plant:Expected Energy Deliveries (kWh)
Jan Feb Mar Apr May Jun
Heavy Load
Light Load
Jul Aug Sep Oct Nov Dec
Heavy Load
Light Load
(Heavv load hours are 7:00 a.m. to 11 :00 p.m., Monday-Saturday. All day Sunday are light hours)
Dispatchable Plant: Project Capacity Dispatchability (kW)
Jan Feb Mar Apr May Jun
...
Total kW
Dispatchable kW
Jul Aug Sep Oct Nov Dec
Total kW
Dispatchable kW
Minimum Baseload Energy to be Delivered (kWh)
Jan Feb Mar Apr May Jun
Heavy Load
Light Load
Jul Aug Sep Oct Nov Dec
Heavy Load
Light Load
(Heavy load hours are 7:00 a.m. to 11 :00 p.m., Monday-Saturday. All day Sunday are Light load hours)
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4. Generation Facilities
Maximum Capabilities kVa kVAR
A) Type
Synchronous Total Capacity kW (Unity Power Factor)
Power Factor Range
Induction Total Capacity kW (At Power Factor)
DC Generator with Inverter Total Capacity
B) Generator Data
Make Model
Number of Units Winding Delta Wye
Voltage
Note: In multiple unit installations, if all generators are not of the same type, capacity, etc., list each unit separately.
C) Inverter (Wave form data must be provided)
Make Model
Voltage Rating Output Rating kVA
Number of Phases
D) Step Up Transformers: Idaho Power will specify the connection and high-side voltage.
Will Idaho Power supply, own, and maintain the step up transformers?Yes
Size kVA Voltage
Pad Mount Pole Mount
5. Single Line Diagram
Provide a generation facility single-line diagram showing all unit protection and control equipment with this application.
6. Other pertinent data (Please list and attach additional pages)
Submitted by
Name (Type or Print)
t:i;.f
Title and Company
Crover Signature
Date
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Interconnection Application
for Small Generators c::20 MW
Date "'
An IDACORP Company
1. Project Name
I C \;/ ; Ifil Pet rfl/
2. Description of Project
3. Proposed In-Service Date
/Yl 100
4. Total Project Name Plate Rating
JC"())YIn kW or MW) (If multiple units at same location, add name plate ratings of each unit together)
5. Energy Output (current intention)
8:( Sell energy output to Idaho Power Company (If this is a PURPA, Qualifying Facility (QF), please attach a copy of the FERC-QF certification)
Transport energy output outside of the Idaho Power Company Service Territory
Net Metering Other (Please describe)
6. Initial Feasibility Analysis Fee
Based upon Total Project Name Plate Rating (kW), the initial feasibility analysis fee will be:
Less than 1 000 kW-$1 00 ~ 1 000 thru 10,000 kW-OOO Greater than 10,000 kW-$10,OOO
This fee will be applied to the costs of processing this application for interconnection and for the initial feasibility analysis. In the event the actual
costs of the initial feasibility analysis exceed this fee, the applicant will be responsible to pay all additional costs. If after the initial feasibility analysis
is completed, the applicant decides to proceed with this project, additional detailed system impact study costs, all interconnection costs, and any
other a licable rocessin fees will be the obli ation of the a licant.
State
Quarter
Township
Section
7. Project Location
General Location
Range
OR Street Address
Nearest Intersection
8. Project Owner/Developer
Company
Contact
n-J.l..
(2 0'1; )
Fax
()oS) 323
City
Phone
State
Note: This application is an interconnection request, not a request for transmission service. This application does not address the requirements
for additional studies and/or upgrades for any transmission services that might be required for delivery of energy to a purchaser other than Idaho
Power Company. Under our Open Access Transmission Tariff rules, procedures for obtaining transmission service are posted on our OASIS
site at: http://oasis.idahopower.com.
Owner/Authorized Agent
Name (Typeprint)J .
Title and Company Date
Signature:
f0cOPY
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The Idaho Department of Water Resources is maintaining this web site as a public service. Persons using information from this site for official purposes
completeness are required, are hereby notified that they should first verify the information with the public records or other primary sources from which tt
http://maps.idwr.idaho.gov/ servletl com.esri.esrimap.Esrimap ?ServiceN ame=overviewmap...5/23/2005
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Date received by Idaho Power Company~_R
An IDACORP Company
Project Description Questionnaire
for Small Generators -(20 MW
1. Project Name
CJ.5)/Cl vJl,:;J ~rrv1
2. Description of Energy SourceHydro FERC License No. or FERC exemption No.j& Wind Unit Size(s)
Geothermal
Biomass or Waste
k-\Al.Number of Units '(
Type of Fuel Source of Fuel
Thermal Fuel
Other
3. Generation Data
Estimated Annual Generation ((kWh)Estimated Project Capacity (kW)
(If the Estimated Project Capacity is less than 100 kW
proceed to item 5 of this questionnaire)
Non-Dispatchable Plant:Expected Energy Deliveries (kWh)
Jan Feb Mar Apr May Jun
Heavy Load
Light Load
Jul Aug Sep Oct Nov Dec
Heavy Load
Light Load
(Heavy load hours are 7:00 a.m. to 11 :00 p., Monday-Saturday. All day Sunday are liQht hours)
Dispatchable Plant: Project Capacity Dispatchability (kW)
Jan Feb Mar Apr May Jun
Total kW
Dispatchable kW
Jul Aua SeD Oct Nov Dec
Total kW
Dispatchable kW
Minimum Baseload Energy to be Delivered (kWh)
Jan Feb Mar Apr May Jun
Heavy Load
Liaht Load
Jul Aua Sep Oct Nov Dec
Heavy Load
Light Load
(Heavy load hours are 7:00 a.m. to 11 :00 p., Monday-Saturday. All day Sunday are LiQht load hours)
)!.
8/02 CPC
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4. Generation Facilities
Maximum Capabilities kVa kVAR
A) Type
Synchronous Total Capacity kW (Unity Power Factor)
Power Factor Range
Induction Total Capacity kW (At Power Factor)
DC Generator with Inverter Total Capacity
B) Generator Data
Make Model
Number of Units Winding Delta Wye
Voltage
Note: In multiple unit installations, if all generators are not of the same type, capacity, etc., list each unit separately.
C) Inverter (Wave form data must be provided)
Make Model
Voltage Rating Output Rating kVA
Number of Phases
D) Step Up Transformers: Idaho Power will specify the connection and high-side voltage.
Will Idaho Power supply, own, and maintain the step up transformers?Yes
Size kVA Voltage
Pad Mount Pole Mount
5. Single Line Diagram
Provide a generation facility single-line diagram showing all unit protection and control equipment with this application.
6. Other pertinent data (Please list and attach additional pages)
Submitted by
Name JJ1.pe or Pri t)
.J ,,
Title and Company
Signature
i..
Date
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