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Home My WebLink About20150702Application.pdfSEffi*. An IDACORP Companv DONOVAN E. WALKER Lead Counsel dwal ker@idahooower.com July 2, 2015 DEW:csb Enclosures irrlli .iUl. *Z pit 3: ilg iil,,',, , i,'t ll-l l'r,:i: i; -:;,li,i;;..1r t, VIA HAND DELIVERY Jean D. Jewell, Secretary ldaho Public Utilities Commission 472 West Washington Street Boise, ldaho 83702 Re: Case No. IPC-E-15-20 Capacity Deficiency to be Utilized for Avoided Cost Calculations - ldaho Power Company's Application Dear Ms. Jewel!: Enclosed for filing in the above matter please find an original and seven (7) copies of ldaho Power Company's Application.WDonovan E. Walker 1221 W. ldaho 5t. (83702) P.O. Box 70 Boise, lD 83707 DONOVAN E. WALKER (lSB No. 5921) ldaho Power Company 1221 West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwal ker@ id a hopower. com Attorney for Idaho Power Company IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR APPROVAL OF THE CAPACITY DEFICIENCY TO BE UTILIZED FOR AVOIDED COST CALCULATIONS. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. !PC-E-15-20 APPLICATION ldaho Power Company ("ldaho Power'or "Company"), in accordance with RP 52, the applicable provisions of the Public Utility Regulatory Policies Act of 1978 ('PURPA'), and ldaho Public Utilities Commission ("Commission") Order Nos. 32697, 33084, and 33159, hereby respectfully submits this Application requesting an order for approval of the capacity deficiency period to be utilized for the Company's avoided cost calculations. ldaho Powe/s 2015 lntegrated Resource Plan ("lRP") indicates a first capacity deficit of July 2025, as shown in Table 1 below. Due to the termination of four PURPA solar contracts, ldaho Power asks for Commission approval of the capacity deficiency period shown in Table 2 below, with a first deficit occurring in July 2024. ln support of its Application, ldaho Power states as follows: APPLICATION.l I. INTRODUCTION 1. ln Order No.32697, the Commission directed that a case be initiated outside of each utility's IRP filing for the establishment of the capacity deficiency period to be utilized in the utility's Surrogate Avoided Resource (.SAR") methodology: ffie find it reasonable and fair to subject each utility's determination of capacity deficiency to further scrutiny. Therefore, when a utility submits its lntegrated Resource Plan to the Commission, a case shall be initiated to determine the capacity deficiency to be utilized in the SAR Methodology. The capacity deficiency determined through the IRP planning process will be the starting point, and will be presumed to be correct subject to the outcome of the proceeding. Order No. 32697, p.23. 2. In Order No. 33159, the Commission found it just and reasonable to utilize the same first capacity deficit determination for purposes of the incremental cost IRP methodology. The Commission stated: ln 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. lf 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. Order No. 32697 at21. Order No. 33159 at 7. II. CAPACITY DEFICIENCY PERIOD 3. The Company currently utilizes a first capacity deficit of July 2021, as directed by the Commission in Order Nos. 33084 and 33159. ldaho Power filed its 2015 IRP (Case No. IPC-E-15-19) with the Commission on June 30, 2015. ldaho Power's 2015 lRP identifies the first capacity deficit occurring in July 2025, as shown in Table 1 APPLICATION - 2 below. This table also appears on page 70 oi the 2015 lRP, Appendix C - Technical Report. As described in the 2015 IRP, peak-hour load deficits are determined using 90th percentile water and 95th percentile peak-hour load conditions. ldaho Power 2015 lRP, p.93. TABLE 1 Peak-hour monthly deficits with existing DSM and existing resources (400) ==(6oo) C, Fl N ftl It 1,| tO t\ O Cl C Gl N dl t.{ N .\a |{ N r{ N N N N dt d! n) an lrtoo00000000()000c,NNNNNdNNNNNNNNN\. \, \. \. \. \. \, \, \, \. \. \, \. \ \.d Fl Fl d Gl F{ d F{ rl rl r{ r{ r{ rl rl000crcoooocroctctoo 4. Table 1 shows a first capacity deficiency of 14 megawatts ("MW") occurring in July 2025. This includes 461 MW of PURPA solar that was under contract when the analysis of Table 1 was completed for the 2015 IRP. Subsequent to the development of Table 1 in the 2015 lRP, four PURPA Energy Sales Agreements (.ESA') were terminated due to failure of the projects to perform in accordance with certain terms and provisions of the ESAs. See Case No. !PC-E-14-28 (Clark Solar 1, LLC); IPC-E-14-29 (Clark Solar 2, LLC); IPC-E-14-30 (Clark Solar 3, LLC); and IPC-E-14-31 (Clark Solar 4, LLC). The total amount of capacity for these four raroFoorFaGaFa?adoocrooNNNN6'\. \, \. \. \,FlFlHcldoocoo APPLICATION .3 terminated ESAs was 141 MW. An updated peak-hour surplus/deficit chart that includes removal ol 141 MW of PURPA solar is presented below in Table 2. TABLE 2 Peak-hour monthly deficits with existing DSM and existing resources (141 MW of PURPA solar removed) (2oo) (4oo) 3 =(600) (8oo) (1,000) 5. Removal of the 141 MW of terminated PURPA solar projects results in a first capacity deficit of 47 MW in July 2024, one year earlier than that shown in Table 1 and the 2015 lRP. See 2015 lRP, Technical Appendix C, p. 119. ldaho Power requests that a first capacity deficit of July 2024 be utilized for avoided cost calculations for both the SAR and IRP methodologies. III. MODIFIED PROCEDURE 6. ldaho Power believes that a hearing is not necessary to consider the issues presented herein and respectfully requests that this Application be processed under Modified Procedure; i.e., by written submissions rather than by hearing. RP 201 ef seg. lf, however, the Commission determines that a technical hearing is required, the Company stands ready to prepare and present its testimony in such hearing. APPLICATION - 4 ra lo F O gr O cl a\a avl t la tO h O gi O G{ N m tca Ga d d d rY N N N a{ N N N N |{ atl an ('l aYt d!attaataltattaatataaaCgCCCCCCCECCCCCCTCCCl! .! l!! O ll l! G .! l! .! (! .! .! l! al l! l! .! .g l.--------------a- IV. COMMUNICATIONS AND SERVICE OF PLEADINGS 7. Communications and service of pleadings with reference to this Application should be sent to the following: 1221West ldaho Street (83702) 1221\Nest ldaho Street (83702) Donovan E. Walker Regulatory Dockets P.O. Box 70 Boise, ldaho 83707 dwa lker@ id ahopower. com d ockets@ idahopower. com Randy Allphin Tess Park P.O. Box 70 Boise, ldaho 83707 ral lph in@ idahopower. com tpark2@ idahopower. com v. coNcLustoN 8. ldaho Power respectfully requests that the Commission issue an order approving the capacity deficiency period to be utilized in the Company's avoided cost determinations under the SAR and IRP methodologies as shown in Table 2 above, with a first deficit occurring in July 2024. DONOVAN E. WALKER Attorney for ldaho Power Company APPLICATION - 5