20120305Grow Direct.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES )CASE NO.IPC-E-12-14
AND CHARGES FOR ELECTRIC SERVICE
DUE TO THE INCLUSION OF THE
LANGLEY GULCH POWER PLANT
INVESTMENT IN RATE BASE.
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
LISA A.GROW
1 Q.Please state your name and business address.
2 A.My name is Lisa A.Grow and my business
3 address is 1221 West Idaho Street,Boise,Idaho 83702.
4 Q.By whom are you employed and in what capacity?
5 A.I am employed by Idaho Power Company (“Idaho
6 Power”or “Company”)as the Senior Vice President of Power
7 Supply.
8 Q.Please describe your educational background
9 and work experience with Idaho Power.
10 A.I graduated from the University of Idaho in
11 1987 with a Bachelor of Science degree in Electrical
12 Engineering.I received an Executive Masters of Business
13 Administration from Boise State University in 2008.I
14 began my career at Idaho Power after graduating from the
15 University of Idaho in 1987,and have held several
16 engineering positions before moving into management in
17 2005.In 2005,I was named Vice President of Delivery
18 Engineering and Operations.In 2009,I was appointed to my
19 current position as Senior Vice President of Power Supply.
20 My current responsibilities include overseeing the
21 operation and maintenance of Idaho Power’s generation
22 fleet,power plant engineering and construction,
23 environmental affairs,water management,power supply
24 planning,and wholesale electricity and gas operations.
25
GROW,DI
Idaho Power Company
1 Q.Please outline the major topics you will
2 address in your testimony in this proceeding.
3 A.I will briefly discuss the historical process
4 involved with the identification of the need for a baseload
5 generating resource,the ultimate selection for the power
6 plant now known as Langley Gulch,the Idaho Public
7 Utilities Commission’s (“Commission”)authorization and
8 binding commitment to provide rate base treatment for the
9 Company’s investment in Langley Gulch pursuant to Idaho
10 Code §61-541,and the expected completion and in—service
11 date for the Langley Gulch power plant.
12 Q.Please describe the Langley Gulch power plant.
13 A.The Langley Gulch power plant is a natural
14 gas-fired combined cycle combustion turbine (“CCCT”)
15 generating plant with a nameplate capacity of approximately
16 300 megawatts (“MW”).The project is constructed on a
17 parcel of land on the south side of Interstate 84 in
18 Payette County approximately five miles south of the town
19 of New Plymouth,Idaho.The project is a baseload
20 generating resource of the size and type identified in the
21 preferred resource portfolio in the Company’s Integrated
22 Resource Plans that have been accepted by the Commission.
23 Q.When was the Langley Gulch power plant first
24 identified as a needed resource?
25
GROW,DI 2
Idaho Power Company
1 A.What is now known as Langley Gulch power plant
2 was first identified as a needed resource in the
3 Commission-accepted 2004 Integrated Resource Plan (“IRP”)
4 In the 2004 IRP,the Company identified a need for a
5 generic 500 MW baseload pulverized coal—fired resource in
6 2011.Two years later in its Commission-accepted 2006 IRP,
7 the Company reassessed when it would need to add a coal—
8 fired resource and adjusted its long-term resource plan to
9 include a 250 MW pulverized coal—fired resource in 2013 and
10 a 250 MW advanced coal—fired resource in 2017.In June of
11 2008,Idaho Power filed an update to its 2006 IRP in which
12 it notified the Commission that due to uncertainties
13 associated with permitting new coal-fired generation,the
14 Company had decided not to proceed with the previously
15 planned coal-fired resource.These concerns coupled with
16 the possibility of new large loads locating in Idaho
17 Power’s service territory and the anticipated shift of flow
18 augmentation releases of water from the federal dams on the
19 Snake River above Brownlee Dam from July and August to May
20 and June prompted the Company to (1)revise the 250 MW
21 coal-fired resource to a natural gas—fired baseload
22 resource,(2)increase the size of the baseload resource to
23 approximately 300 MW,and (3)accelerate the on-line date
24 of the baseload resource to 2012.
25
GROW,DI 3
Idaho Power Company
1 While the identification for the need of a baseload
2 resource was first identified in the 2004 IRP,the result
3 of the changes in the 2006 IRP and the 2008 IRP Update ±5
4 what is now known as the Langley Gulch power plant.
5 Q.Based upon the need for a new baseload
6 resource as identified in the Company’s previous IRP5,did
7 the Company begin a request for proposals (“RPP”)process?
8 A.Yes.On April 1,2008,Idaho Power issued an
9 RET to solicit competitive proposals for up to
10 approximately 600 MW of dispatchable energy.The quantity
11 sought was revised on June 25,2008,to 300 MW.The
12 identified product was a d±spatchable,first-call,non-
13 recallable,physically delivered firm or unit contingent
14 energy dedicated solely to Idaho Power’s use.As stated in
15 the RET,this product requirement could be met through a
16 Purchase Power Agreement where the seller supplies fuel and
17 fuel transportation or a Tolling Agreement (“TA”)where the
18 Company supplies the fuel and fuel transportation.The
19 prescribed term required for bids was 15 years with at
20 least one five-year contract renewal option.
21 The RET also advised potential bidders that to
22 ensure the availability of baseload resources in 2012,the
23 Company would include a Company-developed CCCT in the
24 competitive bidding process as one of the resource
25 alternatives,referred to as the Benchmark Resource.
GROW,DI 4
Idaho Power Company
1 Q.Did the Company engage an independent third-
2 party to review the Company’s competitive request for
3 proposals and bid evaluation process?
4 A.Yes.The Company retained R.W.Beck,an
5 independent consulting firm offering a complete range of
6 consulting and engineering services to the utility
7 industry,to assist with and participate in the RPP
8 process.Specifically,R.W.Beck was retained to assist
9 with preparation of the RFP,the draft power purchase and
10 tolling agreements,development of the evaluation criteria
11 and manual,evaluation of the proposals received in
12 response to the RFP,including a self—build alternative as
13 a benchmark,and to provide assurance to the Commission and
14 bidders that the Company evaluated all proposals submitted
15 in response to the Company’s RFP in a reasonable,fair,and
16 equitable manner.
17 Q.Why did the Company ultimately select the
18 Langley Gulch project as the preferred bidder?
19 A.Ultimately,based on a comparison of the price
20 and non-price attributes of each of the proposals,the
21 Company concluded that the self—build alternative used as
22 the benchmark provided the greatest value for customers.
23 The Company’s decision to select the Langley Gulch project,
24 based on the results of the REP,was primarily dictated by
25 its substantially lower price.The differential between
GROW,DI 5
Idaho Power Company
1 the 20-year net present value (“NPV”)of the revenue
2 requirements of the Langley Gulch and the closest TA for a
3 combined cycle project showed the second place project was
4 approximately $108 million more expensive,and the NPV
5 analysis for the TA for the third-place combined cycle
6 project was $220 million more expensive than the Langley
7 Gulch project.
8 Q.Following the conclusion of the RFP process,
9 did the Company apply to the Commission for a Certificate
10 of Public Convenience and Necessity (“CPCN”)?
11 A.Yes,on March 6,2009,in Case No.IPC-E-09-
12 03,the Company applied for a CPCN authorizing construction
13 of the Langley Gulch power plant.
14 Q.Did the Commission issue an order in Case No.
15 IPC-E-09—03 approving the Company’s application for a CPCN
16 for the Langley Gulch power plant?
17 A.Yes.The Commission,in Order No.30892,
18 issued on September 1,2009,approved the Company’s
19 application for a CPCN.Subsequently,the Commission
20 issued Certificate No.486 for the Langley Gulch power
21 plant.
22 Q.Did the Company make any other requests in
23 Case No.IPC—E--09-03 other than the request for a CPCN?
24 A.Yes.In addition to requesting a CPCN which
25 enabled the Company to begin the construction of the
GROW,DI 6
Idaho Power Company
1 Langley Gulch power plant,the Company also requested that
2 the Commission order authorization and binding commitment
3 to provide rate base treatment for the Company’s capital
4 investment in the Langley Gulch power plant and related
5 facilities.The Company made this request because it felt
6 it was necessary in order to attract capital and finance
7 the project at reasonable rates and terms.
8 Q.Did the Commission grant the Company’s request
9 for authorization and binding commitment rate base
10 treatment for the Company’s capital investment in the
11 Langley Gulch power plant and related facilities?
12 A.Yes.In Order No.30892,the Commission found
13 that Idaho Power had satisfied the statutory requirements
14 of Idaho Code §61—541 and provided Idaho Power with
15 authorization and binding commitment to provide for rate
16 base treatment of the Company’s capital investment in the
17 Langley Gulch power plant and related facilities in the
18 amount of $396,618,473 at such time as the plant was placed
19 in commercial operation.
20 Q.Did the Commission direct the Company to
21 submit quarterly progress reports in consideration of the
22 ratemaking assurance it granted pursuant to Idaho Code §
23 61—541?
24 A.Yes.In consideration of the ratemaking
25 assurance the Commission granted pursuant to Idaho Code §
GROW,DI 7
Idaho Power Company
1 61—541,the Commission directed the Company to submit
2 quarterly progress reports to the Commission describing the
3 status of the Langley Gulch power plant in reasonable
4 detail.The quarterly reports were to include information
5 showing the actual progress against the project schedule,
6 estimates of cost to complete,and changes to the
7 construction schedule and any other notations of importance
8 to the Commission’s understanding of deviations or
9 adjustments to the project schedule initiated between
10 quarterly reports.The reports were to also include a
11 budget update showing the total amount expended and billed
12 to date and remaining contract dollars.
13 Q.Has the Company complied with the Commission’s
14 directive to file quarterly progress reports describing the
15 Langley Gulch power plant project?
16 A.Yes.The Company filed its first Langley
17 Gulch quarterly progress report on December 17,2009,and
18 has continued to file a progress report each quarter
19 through the present.The last Langley Gulch quarterly
20 progress report was filed February 29,2012.
21 Q.What is the current status of the Langley
22 Gulch power plant and related facilities?
23 A.To date,the overall project for the Langley
24 Gulch power plant remains on schedule and the Company
25 expects total project costs to be very close to the
GROW,DI 8
Idaho Power Company
1 Commission-approved binding amount of $396,618,473,which
2 was approved in Order No.30892 (“Binding Pre—approved
3 Amount”).Construction ±5 complete on the water pipeline
4 and pump station and water is available to the plant site.
5 Construction of the gas lateral pipeline from the Williams
6 Northwest main to the site was completed in July 2011.
7 Construction of the tap and metering station was
8 substantially completed in October 2011.Williams
9 Northwest will perform final checkout of its system prior
10 to delivering gas in April 2012.
11 The construction of the 2.8 mile 230 kilovolt (“kV”)
12 line to the west of the power plant was completed in March
13 2011 and is currently in operation.The 16.3 mile 138 kV
14 line is under construction and planned to be completed by
15 May 2012.
16 All permits for air,water,conditional use,and the
17 National Environmental Policy Act are completed and in the
18 construction compliance phase.The Company continues to
19 monitor the permit requirements and is coordinating with
20 the regulatory agencies as needed.
21 Q.Has the Company made use of local labor forces
22 in the construction of the Langley Gulch power plant?
23 A.Yes.In fact,on September 12,2011,the
24 Company filed a Langley Gulch supplemental quarterly
25 progress report which responded to an inquiry about Idaho
GROW,DI 9
Idaho Power Company
1 Power’s use of local construction labor.That report,
2 which has now been included in more recent quarterly
3 reports,identifies nearly 150 local businesses which have
4 been utilized from Ontario,Oregon,to Rupert,Idaho.
5 Idaho Power bias requested its contractors use local labor
6 forces as much as possible.Nearly 30 percent of Idaho
7 Power’s general contractor’s staff is local hires.Idaho
8 Power made a conscious decision to bid the other ancillary
9 projects locally (i.e.,water pipeline,substation,gas
10 pipeline,etc.).All of those projects were awarded to
11 local companies except for the gas pipeline because no
12 local bids were received.
13 Q.Has the Langley Gulch power plant project
14 created additional job opportunities?
15 A.Yes,the Langley Gulch power plant has created
16 both short—and long-term job opportunities.The
17 construction work force has averaged over 150 workers over
18 the last 18 months,including qualified local electricians,
19 pipefitters,steelworkers,excavators,carpenters,concrete
20 workers,and laborers.Additionally,in the third quarter
21 of 2011,the Company completed the hiring of 17 new full
22 time positions stationed at the Langley Gulch power plant.
23 Q.Are you sponsoring an exhibit that shows the
24 Company’s total expected investment for the Langley Gulch
25 plant?
GROW,DI 10
Idaho Power Company
1 A.Yes,Exhibit No.1 details the Company’s total
2 expected investment for the Langley Gulch project when the
3 project is finally completed.The total investment will be
4 $401,416,575,which is $26 million less than the Company’s
5 originally filed commitment estimate of $427,366,739
6 (“Commitment Estimate”).Also shown on Exhibit No.1 is
7 the Company’s actual spend through January 2012,the
8 remaining dollars to be spent by the end of June,and the
9 Company’s total estimated spend through June 2012 of
10 $398,133,778.In addition,Exhibit No.1 shows,for
11 comparison purposes,the Commission—approved binding cost
12 estimate of $396,618,473.
13 Q.How does the total expected investment in
14 Langley Gulch of $401 million compare to the Binding Pre—
15 approved Amount of $396 million approved in Case No.IPC—E
16 09—03?
17 A.The Company’s total investment for the Langley
18 Gulch project will be $26 million less than the Company’s
19 originally filed Commitment Estimate,and approximately
20 $4.8 million greater than the Commission’s Binding Pre
21 approved Amount of $396 million.The Company has kept the
22 Commission notified of the various deviations and
23 adjustments to cost estimates and project schedule
24 contained in the original estimate through the Company’s
25
GROW,DI 11
Idaho Power Company
1 filing of the quarterly progress reports as directed by the
2 Commission.
3 Q.Please identify some of the reasons why the
4 total expected cost of $401 million for the Langley Gulch
5 project is $26 million below the Company’s originally filed
6 cost commitment.
7 A.There are several notable reductions from the
8 cost estimates included in both the Company’s originally
9 filed Commitment Estimate and the pre-approved $396
10 million.Most notably,the Engineering,Procurement,and
11 Construction contract will come in $5.7 million less than
12 the pre—approved amount.In addition,Capitalized Property
13 Taxes will be $1.4 million less,allowance for funds used
14 during construction will be $2.7 million less,and the gas
15 turbine will be $37,823 less than the amounts included in
16 the $396 million.
17 Q.While the Company’s expected investment in
18 Langley Gulch is $26 million less than its original
19 Commitment Estimate,you stated that ±t is $4.8 million
20 greater than the Binding Pre-approved Amount.Please
21 explain why.
22 A.One of the primary reasons for the differences
23 between the Company’s total investment of $401 million and
24 the pre-approved $396 million has to do with some of the
25 individual cost components that were included in the pre
GROW,DI 12
Idaho Power Company
1 approved amount.In Order No.30892,the Commission
2 separated costs that were known with greater certainty and
3 competitively procured from amounts that were based on more
4 uncertain estimates and contingencies.This approach
5 resulted in a $30.7 million reduction to the Company’s
6 filed Commitment Estimate of $427 million and resulted in
7 the Commission establishing a pre—approved amount of $396
8 million.Any costs the Company incurs above the pre
9 approved $396 million are subject to a prudency review for
10 Commission approval.
11 Q.Please describe at a high level any
12 significant variations in the cost components included in
13 the $396 million and the Company’s total expected
14 investment of $401 million.
15 A.As is expected with any project of this
16 magnitude,the actual costs for the Langley Gulch project
17 were higher than estimated in some individual cost
18 categories and lower than estimated in other cost
19 categories.Three of the Company’s projected investments
20 that are expected to be significantly higher are
21 expenditures related to the gas line construction,REP
22 pricing components,and transmission.With regard to the
23 gas line construction,the Company’s total investments are
24 twice as much as stated in the $396 million.However,this
25 is primarily due to the fact I just described above.Due
GROW,DI 13
Idaho Power Company
1 to uncertain estimates included in the Company’s original
2 cost commitment,the Commission established the gas line
3 construction cost estimate at only 50 percent of the
4 Company’s anticipated costs.The Company’s original
5 estimate for gas line construction was $3,100,000.The
6 actual total spend will be $3,170,000,just $70,000 above
7 Idaho Power’s original estimate.However,by only
8 including 50 percent of Idaho Power’s original estimate,
9 the actual costs incurred appear to be much greater than
10 the pre-approved amount.
11 Q.Please describe the increase incurred between
12 cost estimates for the RFP pricing.
13 A.The expected RFP pricing component costs of
14 $5,574,298 are $5 million higher than the costs included in
15 the $396 million.Most of this deviation comes from a
16 combination of higher than anticipated required fuel usage
17 during project commissioning and a lower than expected
18 surplus energy sales offset value.In the Company’s
19 original estimate,it was expected that commissioning would
20 occur during the spring of 2012 when market energy prices
21 were higher;i.e.,April or May,allowing the Company to
22 offset the incurred gas costs.Now the commissioning of
23 the plant is expected to occur during June when market
24 energy prices are typically lower,resulting in less of an
25 offset than was originally anticipated.
GROW,DI 14
Idaho Power Company
1 Q.What variation in costs estimates has occurred
2 with transmission?
3 A.While actual transmission costs are $4 million
4 above the pre-approved amount,the Commission-approved
5 estimate did not include some of the Company’s original
6 contingency estimates and upgrades,resulting in a pre
7 approved amount that was a fraction of the original
8 Commitment Estimate.Actual total transmission costs
9 incurred are $22 million,which is $9.5 million below the
10 Company’s original Commitment Estimate.
11 Q.Does the Company’s request in this docket
12 include its total investment of $401 million in the Langley
13 Gulch project?
14 A.No,not at this time.While the $401 million
15 is $26 million less than the Company’s originally filed
16 Commitment Estimate,the Company is only requesting
17 recovery of the amount of investment that will be closed to
18 books by June 30,2012,or $398,133,778.Company witness
19 Timothy E.Tatum details the development of the incremental
20 revenue requirement associated with Langley Gulch in his
21 testimony,as it relates to the $398 million.
22 Q.When does the Company expect the Langley Gulch
23 power plant to be in commercial operation?
24
25
GROW,DI 15
Idaho Power Company
1 A.The Langley Gulch power plant is expected to
2 be in commercial operation on or before July 1,2012.The
3 first fire of the plant is expected in April 2012.
4 Q.Although it would be inappropriate to re—
5 litigate need for the plant in this proceeding,which the
6 Commission affirmed when it issued Order No.30892,does
7 Idaho Power’s current load and resource balance indicate
8 the Langley Gulch is still needed in the summer of 2012?
9 A.Yes.The peak-hour load and resource balance
10 from the 2011 IRP was updated to include the Company’s
11 latest load forecast,which accounts for reduced Hoku load
12 based on the recently proposed terms of a restated contract
13 currently before the Commission for approval,an updated
14 forecast of Public Utility Regulatory Policies Act of 1978
15 generation taking into account recent contracts and
16 expected on-line dates,and updated estimates of
17 transmission capacity available for July market purchases
18 from the Pacific Northwest.Without Langley Gulch,the
19 updated peak-hour load and resource balance shows July
20 deficits of 28 MW in 2012,169 MW in 2013,and 224 MW in
21 2014.With the Langley Gulch plant being available this
22 summer,Idaho Power will be able to reliably meet the
23 summer peak needs of customers.
24 Q.In your opinion,will the Langley Gulch power
25 plant be used and useful on July 1,2012?
GROW,DI 16
Idaho Power Company
1 A.Yes.The need for a new baseload power plant
2 was first identified in Idaho Power’s 2004 and 2006 IRP5 in
3 order to meet system reliability and load growth within
4 Idaho Power’s service territory.The Langley Gulch power
5 plant will be immediately used and useful once it is in
6 commercial operation in order to help meet the Company’s
7 summer peak demand requirements and provide additional
8 system reliability needed year-round due to the increased
9 challenges of integrating variable and intermittent
10 renewable generation resources.
11 Q.Does this conclude your direct testimony in
12 this case?
13 A.Yes,it does.
14
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GROW,DI 17
Idaho Power Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC-E-12-14
IDAHO POWER COMPANY
GROW,DI.
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