20181102McCollum Enterprises Reply Comments.pdf

II:f;IVEDOWEN H. ORNDORFF
ORNDORFF LAW OFFICES
1087 West River Street, Ste.. 230
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
E-Mail : orndorffl aw@aol. com
ISB No. 1648
Attorney for McCollum Enterprises
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
:$If ilfiv -2 Pflt2:02
;-"irn i ,.;i_ii,-ti,. ir .: ,-:ni,iiJlSSl0i!
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
MCCOLLUM ENTERPRISES, LIMITED
PARTNERSHIP, FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY
FROM THE CANYON SPRINGS HYDRO
PROJECT.
CASE NO. IPC-E-18-12
COMMENTS OF CANYON
SPRINGS HYDRO PROJECT
)
)
)
)
)
)
)
)
)
)
COMES NOW McCollum Enterprises, Limited Partnership seeking a Sale and Purchase
of Electrical Energy for the Canyon Springs Hydro Project through its attorney, Owen H. Orndorff,
in response to certain comments of the Commission Staff and Idaho Power Company's (IPCO)
Response to the First Production Request and submits the following comments:
l. Schedule 86 Capacity Rates. There is quite an interesting history of capacity rates
inclusion in Schedule 86 starting in Case No. P-300-12 in which the Commission ultimately
included 3 mill adder for capacity on energy to reflect expected " ...aggregation of nonfirm energy
resources..." (Order 26750, p.2, Jan.22, 1997).
In Order 26750, January 22,1997, the Commission eliminated the 3 mill capacity payment
accepting IPCO's argument "... that nonfirm energy purchases under Schedule 86 have never
provided any actual capacity to Idaho Power System..." (Order 26750, p.2, Jan.22, 1997).
Canyon Springs Hydro Project for approximately 100 kwh has been on Schedule 86 since
2004 andhas provided continuous and reliable resources to the IPCO's system such that IPCO has
included Canyon Springs Hydro in the IPCO's "...cogeneration and small power production
forcast and is therefore included in the load and resource balance contained in Idaho Power's 2017
Integrated Resource Plan.... (PCO Response to the First Production Request on the Commission
Staff, p. 2,Dated Oct. 17,2018) Prior to 2004, Canyon Springs had a long term contract and was
similarly included (presumably) in IPCO's historical resources stack.
McCollum Enterprises Comments - Pg. 1
2. Commission Staff Comments. The Commission Staff is simply wrong that IPCO
has not been able to "...count on the project to supply capacity during peak periods..." (Pg. 3,
Staffs Oct. 30, 2018 Comments) because IPCO through its own statements has continuously
counted capacity from Canyon Springs in its Integration Resource Plans including the most recent
2017 IRP. Canyon Springs should be allowed to include in its contract rates capacity benefits just
as any other QF which has reliably and continuously provided capacity to IPCO since any projects'
inception based on the benefits ratepayers derived from avoiding additional capacity as every other
QF provides.
There is a certain degree of equity that needs to be addressed if Canyon Springs is denied
any capacity payments until 2026, given Canyon Springs has been included in the IPCO resource
plans since 2004 and otherwise paid substantially less than other QF's included in the resource
plans. The ratepayers have received bargain prices on Canyon Springs energy and capacity while
receiving all the benefits of a longterrn resource based on the inclusion in the IRP. To reflect the
foregoing, the most reasonable and fair outcome is to allow Canyon Springs to receive capacity
payments going forward and the ratepayers retain the benefits of Schedule 86 in the past including
reduced energy and no capacity payments since 2004.
Respectfully submitted this 2 auy of November,20r8
Owen H. Orndorff
Attorney for McCollum
McCollum Enterprises Comments - Pg. 2
CERTIFICATE OF SERVICE
I hereby certify that on this 2 day of November, 2018,I served a true and correct copy
of the within and foregoing document upon the following named parties by the method indicated
below, and addressed to the following:
Donovan E. Walker
Idaho Power Company
P.O. Box 70
Boise,ID 83707
Energy Contracts
Idaho Power Company
P.O. Box 70
Boise,ID 83707-0070
Edward J. Jewell
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
David McCollum
McCollum Enterprises
P.O. Box 5492
Twin Falls, ID 83303
Joseph McCollum
1110 Warm Springs Ave.
Boise, ID 83712
Delivered
U.S. Mail
Overnight Mail
_ Fax
_ E-Mail
(dwalker@idahopower. com)
_ Hand Delivered
tz-U.S. Mail
_ Overnight Mail
_ Fax
_ E-Mail
(energycontracts@idahopower. com)
Hand Delivered-7 u.s.tutuit
_ Ovemight Mail
_ Fax
E-Mail
_ Hand Delivered
IzU.S. Mail
_ Overnight Mail
_ Fax
_ E-Mail
(dave@canyonsprings golf. com)
Hand Delivered
-y'u.s.tvtuit_ Overnight Mail
Fax
Owen
McCollum Enterprises Comments - Pg. 3