20200807Redacted Comments.pdf

Street Address for Express Mail:
1133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-O3s7
IDAHO BAR NO. 5470
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMBNT WITH BIG
WOOD CANAL COMPANY FOR THE SALE
AND PURCHASE OF ELECTRIC ENERGY
FROM THE SAGEBRUSH HYDRO
PROJECT.
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CASE NO.IPC.E.19-38
REDACTED COMMENTS OF
THE COMMISSION STAFF ON
THE FIRST AMENDMENT TO
THE ENERGY SALES
AGREEMENT
The Staff of the Idaho Public Utilities Commission ("Staff') submits the following
comments regarding the above referenced case.
BACKGROUND
On December 9, 2019,Idaho Power Company ("Company") filed an Application seeking
approval or rejection of an Energy Sales Agreement ("ESA") between the Company and Big
Wood Canal Company ("Seller"), for the Sagebrush hydro project ("Facility"). See Application at
L The Facility is a 575- kilowatt ("kW") nameplate capacity qualifying facility ("QF") near
Gooding, Idaho under the Public Utility Regulatory Policies Act of 1978 ("PURPA"). Id. at 2.
The Facility previously delivered energy to the Company under a PURPA energy sales agreement
executed on April 1, 1985. Id. at2. In that agreement the nameplate capacity of the Facility was
430 kw.
ISTAFF COMMENTS AUGUST 7 ,2020
On January 10,2020, the Commission issued its Notice of Application and Notice of
Modified Procedure. Staff filed written comments on January 3I,2020. Wood Hydro, LLC
("Wood Hydro") filed reply comments on February 5,2020. The Company filed reply comments
on February 21,2020. On March 17,2020, Wood Hydro filed supplemental reply comments.
On May 28,2020, the Commission issued Order No. 34677 approving the ESA contingent
upon certain modifications to it being implemented. In Order No.34677, the Commission found
it reasonable for the Seller to continue to be paid for capacity up to only 430 kW for the full term
of the renewal ESA. Order No. 34677 at 5; see also Order No. 32697 at 2l-22. However, the
Commission also found that the 145-kW increase in nameplate capacity for the Facility should
not receive capacity payments until the Company becomes capacity deficient. Order No.34677 at
6.
On June 18,2020, the Company filed a Motion for Approval of the First Amendment to
Energy Sales Agreement in Compliance with Order No.34677 or Alternatively for Clarification
and./or Reconsideration ("Motion"). On June 25,2020, Staff filed an Answer to the Company's
Motion. on June 30,2020, wood Hydro filed an Answer to staff's Answer.
On July 23,2020, the Commission issued Order No.34727 granting the Company's
request for clarification to consider whether the new provisions proposed in the First Amendment
to the ESA ("Amended ESA") are consistent with Order No. 34677. Order No.34727 at 3. The
Commission also found it prudent to allow the parties in the case to conduct discovery and to file
additional written comments on the proposed Amended ESA and the issues raised by Staff in its
Answer before the Commission issues a final order on clarification. Id.
STAFF REVIEW
Staff has reviewed the proposed Amended ESA. The objective of Staff s discovery and
analysis was focused on "whether the new provisions proposed in the Amended ESA are
consistent with Order No. 34677," and on issues Staff identified in its Answer to the Company's
Petition. Specifically, Staff s analysis focused on three issues: (l) whether the proposed method
in the Amended ESA ensures that the "seller shall not receive capacity payments for the 145 kW
increase to the nameplate capacity of the Facility until the Company becomes capacity deficient"
(Order No. 34677 at 6); (2) if the Company has a reasonable method to determine the amount of
payment to the QF when monthly generation falls outside of the 90/l 10 band, given that the QF
2STAFF COMMENTS AUGUST 7 ,2020
could be paid two separate rates during the performance period; and (3) if the Amended ESA
provisions comply with past Commission orders. After careful review of these issues, Staff has
reached the following conclusions:
1. The proposed method in the Amended ESA will likely result in the QF receiving capacity
payments from the incremental 145 kW of new capacity before the Company becomes
capacity deficient if the hourly eligibitity limit for capacity payments ("eligibility limit")
is based on nameplate capacity instead of maximum historical actual generation.
2. The method described in number 1 above, even with Staffls revisions, should not be
generally applied to other cases. QF's under similar circumstances that seek approval of
contracts requiring different avoided cost rates with capacity payments that use different
capacity deficiency dates, and whose output is measured through a single meter, should be
evaluated on a case-by-case basis.
3. The Company's method for determining the amount to pay the QF when outside of the
901lrc band is fair and reasonable.
4. The all-hours rates included in Appendix H of the Amended ESA includes the incorrect
all-hours energy prices and needs to be corrected.
Limiting Capacity Payments to Generation from Original Capacity
In Order No. 34677, the Commission found "the Seller shall not receive capacity
payments for the 145 kW increase to the nameplate capacity of the Sagebrush Facility until the
Company becomes capacity deficient." Order No. 34677 at 6. In response to Order No.34677
the parties filed the Amended ESA "to provide for payment of a different rate (no capacity) for
any hourly delivery of generation in excess of 430 kW." Motion at 2. Staff notes this capped rate
schedule will only be in effect until the Company's current first capacity deficiency date of 2026.
From 2026 until the end of the Amended ESA's term, the Company will be paid both capacity
and energy for all generation from the Facility. Staff believes that the parties' method with an
eligibility limit set at 430 kW does not meet the Commission's intent and the Seller will likely
receive capacity payments for generation from the 145 kW of new incremental capacity prior to
the deficiency date.
For purposes of the rest of these comments, Staff needs to make clear an important
inconsistency in the Parties' method for ensuring that the QF does not earn capacity payments for
3STAFF COMMENTS AUGUST 7 ,2020
the new 145 kW of capacity until the deficit date has passed. Although the proposed ESA states
the capacity payment eligibility limit ("eligibility limit") in terms of kWs. Units expressed as
kWs is a measurement of instantaneous capacity. However, the eligibility limit is measured over
each hour of time, so what is being measured is the amount of energy and not capacity. For this
reason, Staff must assume the 430 kW eligibility limit for each hour should be measured in
kilowatt-hours (kWh) and not kW because of the inherent structure of the proposed method.
Idaho's Published Rate Methodfor Capacity Payments
The method for paying QFs for avoided cost of capacity in published rates is strictly based
on the amount of actual generation on a $ per kWh basis, and not the nameplate capacity of a QF.
The $/kWh rate structure is designed to reward QFs for the avoided cost of capacity for energy
delivered, not its nameplate capacity. The Surrogate Avoided Cost ("SAR") model that calculates
these rates are based on this method and has been reviewed and the rates authorized in a filing that
occurs every year since at least 20L3. See Order Nos. 32817,3304t,33305, 33538, 33773,
34062, 34350, and 34683.
This SAR method accomplishes two objectives. First, it provides a publishable standard
rate schedule that can apply to any QF of a certain type (wind, solar, seasonal hydro, non-seasonal
hydro, etc.), regardless of the nameplate capacity of the QF as long as it qualifies for published
rates under the eligibility cap. In this case the Seller is compensated using the published rate
schedules for Seasonal Hydro shown in Appendix E of the original ESA. These rates will be no
different than any other Seasonal Hydro QF that has a fully executed contract while these rates are
in effect. Second, it holds the QF accountable, requiring it to generate energy to earn the capacity
value for the cost of capacity that it avoids for the utility.
Setting the Appropriate Eligibility Limit for Capacity Payments
In Order 34677 the Commission found "it reasonable for the Seller to be paid for capacity
up to 430 kW for the full term of this renewal ESA. . . . [and] that the Seller shall not receive
capacity payments for the 145 kW increase to the nameplate capacity of the Sagebrush Facility
until the Company becomes capacity deficient." Order No. 34671 at 5-6. Staff believes had
published rates been designed to pay for capacity on a $ per kW of nameplate capacity basis,
regardless of the amount of generation produced by the Facility, the Commission's Order in this
4STAFF COMMENTS AUGUST 7 ,2020
case could have been implemented without requiring the Amended ESA. However, because of
how published rates were developed and are applied, Staff believes the only way to implement
Order No.34677 is to separate the original 430 kW of capacity from the 145 kW of new
incremental capacity based on the actual amount of historical generation produced by the Facility
Through Staff Production Request No. 2, Staff received the actual amount of generation
for each hour from the Facility for 2018 and 2019. The data is reflected in the graph below.
Except for hours when there was very little generation (less than 20 kWhs), the data shows
that the Facility mostly generated between I *d ! t Wt s for any given hour over the two-
year period. The frequency of hours that the Facility generated greater than ! kWhs decreased
rapidly to a maximum of about ! tcWtr.t Because 100 percent of the Facility's generation fell
I In the hourly generation data provided in response to Staff Production Request No. 2, there was a generation amount
of 363.612 kWhs that occurred in hour 14:00 on 7l3\l2ol9 that the Company determined in response to Staff
Production Request No. 3 was based on an estimated interval and would have been adjusted to approximately
267.876 kWh based on the previous hourly value and the next hourly value.
5STAFF COMMENTS AUGUST 7 ,2020
below the maximum of ! kwh, Staff believes that the eligibility limit for generation eligible for
capacity payments should be based on this maximum generation amount.
If the hourly eligibility limit is set at 430 kWhs as proposed in the Amended ESA, any
hourly generation over maximum historical levels of I kWhs up to 430 kWhs will receive
capacity payments. Staff believes future generation above ! t<Wtrs is highly likely because the
nameplate capacity of the generating unit has increased by 145 kW. Therefore, paying capacity
on generation above ! t Wt r will violate the Commission's intent to prevent the Seller from
receiving capacity payments for the 145 kW increase to the nameplate capacity of the Facility
until the Company becomes capacity deficient. Order No. 34677 at 6.
Staff questions whether there could be issues of potential discrimination with other QFs
that replace their generating unit, but instead replace its original unit with a new unit that has the
same nameplate capacity as the original. However, there are multiple ways to describe capacity
other than through its nameplate. Nameplate capacity is a theoretical maximum that the
manufacturer rates a generating unit under optimum conditions without exceeding thermal
limitations. However, the actual maximum output is typically less than the nameplate capacity
based on the specific installation, the condition of the unit, the design of the unit, and other factors
that can affect its overall efficiency. As a result, a new replacement unit could have a realized
capacity based on output that is different than the old unit, even with the same nameplate
capacity.
Hypothetically, had the QF replaced the generating unit with another unit with a 430 kW
nameplate, it is unlikely that the need for a bifurcated rate would have arose. However, in
considering this hypothetical situation, Staff does not believe this eliminates the problem of QFs
earning capacity payments for incremental generation from a newer more efficient unit.
Installation of a new unit is reason enough to assume that the amount of generation will be
higher than the old unit it replaces. But the Company bases its need for capacity by determining
the QF's contribution of capacity primarily based on historical generation from the old,less
efficient generating unit.2 This would create a discrepancy between the amount the QF receives
for its contribution of capacity by generating with the new unit and the amount the Company
2 See footnote in2Ol7 Integrated Resource Plan ("IRP"), Appendix C, p. I 13, included as Atrachment A which
describes how the Company uses actual historical generation, and other factors in its IRP, rather than nameplate
capacity which is an unreasonable estimate.
6STAFF COMMENTS AUGUST 7,2020
assumes the QF is contributing based on actual historical generation from the old unit. However,
if the Commission determines that discrimination is an issue, Staff believes that a lo%o efficiency
adjustment could be applied to Staffls proposed 304 kwh eligibility limit resulting in a ! t Wt
eligibility limit.
Staff believes that a combination of the Amended ESA's proposed method to establish an
hourly eligibility limit and Staff s modifications to the eligibility limit based on the maximum
hourly amount of actual generation addresses concerns made by Wood Hydro in their
Supplemental Comments dated March 17 ,2020. Staff believes that this solution ensures that the
QF will not be "shortchanged" capacity payments for generation that it would have produced
under the original amount of capacity while not compensating it for the new nameplate capacity
added to the Facility. See Order No. 34677 at 5-6.
Method Should Not Be Applied to other ESAs
Staff believes it is important that the method for limiting capacity payments, if authorized
by the Commission in this case, should not be applied to other cases under similar circumstances.
Rather, those cases should be evaluated based on the facts in those cases. Applying the method
employed in this case for other types of QFs under seemingly similar circumstances, provides an
opportunity for gaming the system allowing a QF to receive benefits more than its value to the
utility violating PURPA's Customer Indifference Standard [18 C.F.R. 5 292.304(a)(2)).
Staff believes the method being proposed, with Staff s recommendations for setting the
eligibility limit, are appropriate for this case. Further, Staff asserts that QF's that appear to be
under similar circumstances that seek approval of contracts requiring different avoided cost rates
with capacity payments that use different capacity deficiency dates, and whose output is measured
through a single meter may require anywhere from minor adjustments to a completely new
method.
In this case, Staff believes it is appropriate to consider the replacement of the original
generating unit with a larger unit as two hypothetical separate units in a serial configuration due
to potential water flow limitations through the canal. By assuming that the maximum amount of
water that can be diverted through what is analogous to the original430 kW unit, and any
remaining water allowed to flow through what is analogous to the new 145 kW unit, the Seller
can receive at least the amount of "capacity payment entitlement of the old capacity". Wood
7STAFF COMMENTS AUGUST 7 ,2020
Hydro's Supplemental Comments at 2. However, the method used in this case may not be
appropriate for a QF that increases its capacity using additional units of capacity and./or has a
sufficient supply of fuel (water, solar energy, wind, landfill gas, etc.) that is best characterized as
separate units of capacity that operate in a parallel manner. In such cases, an average of the
different per kWh rates weighted by nameplate capacity as described in Staff s Comments may be
more appropriate.3
Method to Determine Payments Outside the 90/110 performance Band
Staff evaluated the Company's proposed method for determining avoided cost payments,
when monthly generation falls outside of the 90/1 10 performance band, which the Company
provided in response to Staffls Production Request No. 1. See also Attachment B to these
comments. Staff believes this method is reasonable and appropriate, but recommends the parties
incorporate this calculation method into the Amended ESA through an additional amendment to
it.
Currently, QFs provide a monthly estimate of the amount of energy they expect to
produce. If the QF delivers more than 1 10 percent of the estimated amount, energy delivered in
excess of I 10 percent is priced at the lesser of 85 percent of the market price or the contract price.
If the QF delivers less than 90 percent of the estimated amount, total energy delivered is priced at
the lesser of 85 percent of the market price or the contract price. Sea Order No. 29632.
However, from2020 through 2025, there are two sets of contract rates, one with capacity
payments and one without, depending on whether each hour's generation is below or above the
eligibility limit. The Company has proposed to blend the rates for purposes of 90/110. First, for
each month, the Company will determine the total generation amount (MWh) generated below
430 kW at the hourly level and multiply the corresponding All Hours Energy Price. Then, the
Company will determine the total generation amount (MWh) generated above 430 kW at the
hourly level and multiply the corresponding All Hours Energy Price in Appendix H. The sum of
the two items will be divided by the total generation for that month to calculate a single, blended
3 Staff s description of its weighted-average method in its first set of Comments in this case used the nameplate
capacity for two purposes: (l) to identify the different blocks of capacity between the original that was eligible for
immediate capacity payments, and the new block of capacity ineligible for capacity payments until the deficit date,
and (2) to weight the different rates attributed to each block. The different rates for each block are based on the
amount of generation from each block based on a $/kWh rate. The amount of capacity payment would be the product
of the $/kWh weighted-average rate and the amount of kWhs of generation from the overall project.
8STAFF COMMENTS AUGUST ],2020
All Hours Energy Price. Last, the blended rate will be compared against 85 percent of the market
price, and the lower number will be applied to the energy generated outside the 90/110 band in
that month. Beyond 2026, there will be only one set of rates, so no blending is needed.
Although the Commission rejected the use of Staff s proposal for blended rates in Order
No. 34677 for payment within the 90/1 10 band, Staff does not believe that payments outside of
the band can avoid some type of blending. This is because the authorized method requires
comparisons based on monthly amounts of market price against contract price and of the amount
of committed energy against actual generation. See Order No. 29632.
Analysis of Rates
Staff believes it is appropriate to use the avoided cost rates effective when the parties
signed the original ESA.4 However, rates listed in the All Hours Energy Price section of
Appendix H are incorrect. Staff has included the correct rates for the All Hours Energy Price
included as Attachment C to these comments.
RECOMMENDATIONS
Staff recommends approval of an amended ESA based on the Amended ESA that includes
the following additional amendments:
l. Modify the eligibility limit for capacity payments from 430 kWs to ! tWt,
based on actual maximum hourly generation.
2. lncorporate the method described in the Company's Response to Staff Production
Request No. 1 for determining payments outside of the gDlll0 performance band
into the final ESA.
3. Correct the rates for the All Hours Energy Price in the Amended ESA to those
included as Attachment C to these comments.
Finally, Staff recommends that the method establishing an eligibility limit be limited to
this case and not applied in future cases.
aThe original ESA was signed by the Seller on November 18, 2Ol9 andby the Company on
November 22,2019.
9STAFF COMMENTS AUGUST 7 ,2020
fo,,Respectfully submitted this
Technical Staff: Michael Iouis
Yao Yin
i:umisc:comrrents/ipel9.3Sjhyysdrf amendnrcnt comnrcnb
of August 2020.
Iohn
General
STAIIF COMMENTS 10 AUGUST 7,2020
Existing Resource Data ldaho Power Company
Qualifying Facility Data (PURPA)
Cogeneration and Small Power Production Projects
Status as of April 1,2A17.
Contract
On-line Date End Date Project
Contract
MW On-line Date End DateProjectMW
Hydro Projects
Arena Drop 0.45 Sep-2010
Baker City Hydro 0.24 Sep-2015
Barber Dam 3.70 Apr-1989
Birch Creek 0.05 Nov-1984
Black Canyon #3 0.14 Apr-1984
Black Canyon Bliss Hydro 0.03 Nov-2014
Blind Canyon 1 .63 Dec-2014
Box Canyon 0.36 Feb-1984
Briggs Creek 0.60 Oct-1985
Bypass 9.96 Jun-1988
Canyon Springs 0.13 Oct-1984
Cedar Draw 1.55 Jun-1984
Clark Canyon Hydroelectric 7.55 Jun-2017
Clear Springs Trout 0.52 Nov-1983
Crystal Springs 2.44 Apr-1986
Curry Cattle Company 0.22 Jun-1983
Dietrich Drop 4.50 Aug-1988
Eightmile Hydro Project 0.36 Oct-2014
Elk Creek 2.00 May-1986
Falls River 9.1 0 Aug-1993
Fargo Drop Hydroelectric 1.27 Apr-2013
Faulkner Ranch 0.87 Aug-1987
Fisheries Dev. 0.26 Jul-1990
Geo-Bon #2 0.93 Nov-1986
Hailey Cspp 0.06 Jun-1985
Hazelton A 8.10 Ma(2011
Hazelton B 7.60 May-1993
Head of U Canal Project 1.28 May-2015
Horseshoe Bend Hydro 9.50 Sep-1995
Jim Knight 0.34 Jun-1985
Kasel & Witherspoon 0.90 Mar-1984
Koyle Small Hydro 1.25 Apr-1984
Lateral # 10 2.06 May-1985
Lemoyne 0.08 Jun-1985
Little Wood River Ranch ll 1.25 Jun-2015
Total Hydro Nameplate Rating 155.32 MW
Sep2030
Sep-2030
Apr-2024
Nov-2019
Apr-2019
Oct-2035
Dec-2034
Feb-201 9
Oct-2020
Jun-2023
As delive
Jun-201 9
Estimated
Nov-201 8
Apr2O2'l
Jun-20'18
Aug-2023
Oct-2034
May-2021
Aug-2028
Apr-2033
Aug-2022
Jul-2040
Nov-2021
Jun-2020
Mar-2026
May-2028
Jun-2035
Sep-2030
Jun-2020
Mar-2019
Apr-2019
May-2020
Jun-2020
Oct-2035
Little Wood Rvr Res
Littlewood/Arkoosh
Low Line Canal
Low Line Midway Hydro
Lowline #2
Magic Reservoir
Malad River
Marco Ranches
Mile 28
Mill Creek Hydroelectric
Mitchell Butte
Mora Drop Small Hydro Fac
Mud CreeUS&S
Mud CreekMhite
North Gooding Main
Owyhee Dam Cspp
Pigeon Cove
Pristine Springs #1
Pristine Springs #3
Reynolds lrrigation
Rock Creek #1
Rock Creek #2
Sagebrush
Sahko Hydro
Schaffner
Shingle Creek
Shoshone #2
Shoshone Cspp
Snake River Pottery
Snedigar
Tiber Dam
Trout-Co
Tunnel #1
White Water Ranch
Wilson Lake Hydro
2.85
0.87
7.97
2.50
2.79
9.07
0.62
't.20
1.50
0.80
2.09
1.85
o.52
0.21
1.30
5.00
1.89
0.13
o.20
0.26
2.05
1.90
0.43
0.50
0.53
0.22
0.58
0.37
0.07
0.54
7.50
0.24
7.OO
0.16
8.40
Feb-1 985
Aug-1986
May-l985
Au9-2007
Apr-l988
Jun-1989
May-1984
Aug-1985
Jun-1 994
Oct-201 1
May-1989
Sep2006
Feb-1 982
Jan-1 986
Oct-2016
Aug-1 985
Oct-1984
May-2005
May-2005
May-1986
Sep-1 983
Apr-1989
Sep-1 985
Feb-2011
Aug-1 986
Aug-1983
May-1996
Jun-'1982
Nov-1 984
Jan-'1985
Jun-2004
Dec-1 986
Jun-1 993
Aug-1985
May-1993
Feb-2420
Aug-2021
May-2020
Aug-2027
Apo2023
Jun-2024
May-2019
Aug-2020
Jun-2029
Jun-2017
Dec-2033
Sep-2026
Jan-20'17
Jan-2021
Oct-2036
May-2033
Oct-2019
May-2015
May-2015
May-2021
Sep-2018
A9r-2024
Sep2020
Feb-2021
Au9-2021
Aug-2017
May-2031
FeV2017
Nov-20'19
Jan-2020
Jun-2024
Dec-2021
Feb-2035
Aug-2020
May-2028
Thermal Projects ltTW On-line Date
Simplot Pocatello Cogen 15.90 Mar-2013
TASCG-Nampa Natural Gas 2 Sep-2003
TASCG-Twin Falls Natural Gas 3 Aug-2001
Total Thermal Nameplate Rating 20.90 MW
End Date
Feb-201 6
As Delivered
As Delivered Attachment No. A
Case No. IPC-E-19-38
Staff Comments
08107120 Page 1 of2
Page 112 2017 lntegrated Resource Plan-Appendix C
ldaho Power Company Existing Resource Data
Project
Biomass Projects
86 Anaerobic Digester 2.28 Aug-2010
Bannock County Landfill 3.20 May-2014
Bettencourt Dry Creek BioFactoq 2.25 May-2010
Big Sky West Dairy DigestelI .50 Jan-2009
Double A Digester Project 4.50 Jan-2012
Fighting Creek Landfill 3.06 Apr-2A14
Total Biomass Nameplate Rating 34.45 MW
Solar Projects
American Falls Solar ll, LLC 20.00 Mar-2017
American Falls Solar, LLC 40.00 Mar-2017
Brush Solar 2.75 Oct-2019
Grand View PV Solar Two 80.00 Dec-20'16
Grove Solar Center, LLC 6.00 Oct-20'16
Hyline Solar Center, LLC 9.00 Nov-2016
lD Solar 1 40.00 Aug-20'16
Morgan Solar 3 00 Oct-2019
Mt. Home Solar 1, LLC 20.00 Mar2017
Total Solar Nameplate Rating 298.25 MW
Wind Projects
Bennett Creek Wind Farm 21.00
Benson Creek Windfarm 10.00
Burley Butte Wind Park 2'l .30
Camp Reed Wind Park 22.50
Cassia Wind Farm LLC 10.50
Cold Springs Windfarm 23.00
Desert Meadow Windfarm 23.00
Durbin Creek Windfarm 10.00
Fossil Gulch Wind 10 50
Golden Valley Wind Park 12.00
Hammett Hill Windfarm 23.00
High Mesa Wind Project 40.00
Horseshoe Bend Wind 9.00
Hot Springs Wind Farm 21 .00
Jett Creek Windfarm 10.00
Lime Wind Energy 3.00
Total Wind Nameplate Rating 625.92 MW
Contract
MW On-line Date End Date
Aug-2020
May-2034
May-2020
Jan-2029
Jan-2032
Apr-2029
Mat-2037
Mar-2037
Estimated
Dec-2036
Oct-2036
Nov-2036
Jan-2036
Estimated
Mar-2037
Dec-2008
Mar-2017
Feb-201 1
Dec-201 0
Mar-2009
Oec-2012
Dec-2012
Mar-2017
Sep-2005
Feb-201 I
Dec-2012
Dec-2012
Feb-2006
Dec-2008
Mar-2017
Dec-201 1
Dec-2028
Mai2037
Feb-203'l
Oec-2030
Mar-2029
Dec-2032
Dec-2032
Mar-2037
Sep-2025
Feb-2031
Dec-2032
Dec-2032
Feb-2026
Dec-2028
Mar-2037
Dec-2031
Project
Hidden Hollow Landfill Gas
Pocatello Waste
Rock Creek Dairy
SISW LFGE
Tamarack CSPP
Murphy Flat Power, LLC
Open Range Solar Center, LLC
Orchard Ranch Solar, LLC
Railroad Solar Center, LLC
Simco Solar, LLC
Thunderegg Solar Center, LLC
Vale Air Solar Center, LLC
Vale 1 Solar
Contract
irTW On-lin6 Date End Date
3.20
0.46
4.00
5.00
5.00
Jan-2007
Dec-1 985
Aug-2012
Oct-2018
Jun-'1983
Jan-2027
Dec-2020
Au9-2027
Estimated
Jun-201 8
Mainline Windfarm
Milner Dam Wind
Oregon Trail Wind Park
Payne's Ferry Wind Park
Pilgrim Stage Station Wind Park
Prospector Windfarm
Rockland Wind Farm
Ryegrass Windfarm
Salmon Falls Wind
Sawtooth Wind Project
Thousand Springs Wind Park
Tuana Gulch Wind Park
Tuana Springs Expansion
Two Ponds Windfarm
Willow Spring Windfarm
Yahoo Creek Wind Park
20.00
20.00
10.00
4.50
20.00
10.00
10.00
3.00
Mar-2017
Mar-2017
Oct-20'16
Dec-2016
Mar-2417
Nov-201 6
Nov-201 6
Oct-2019
Dec-20'12
Feb-201 1
Jan-201 1
Dec-2010
Jan-201 1
Mar-2017
Dec-201 '1
Dec-2412
Apr-2011
Nov-201 1
Jan-201 1
Jan-2011
May-2010
Dec-2012
Mar-2017
Dec-201 0
Mar-2037
Mar-2037
Oct-2036
Dec-2036
Mar-2037
Nov-2036
Nov-2036
Estimated
Dec-2032
Feb-2031
Jan-2031
Dec-2030
Jan-2031
Mar-2037
Dec-2036
Dec-2032
Apr-203'l
Nov-2031
Jan-2431
Jan-2031
May-2030
Dec-2032
Mar-2037
Dec-2030
23.00
19.92
13.50
21.00
10.50
10.00
80.00
23.00
22.A0
22.04
12.00
10.50
35.70
23.00
10.00
21.00
Total Nameplate Rating 1,135.84 MW
The above is a summary of the Nameplate rating for the CSPP projeas under conlract with ldaho Power as of April 1 , 2017. ln the case of CSPP proiecls,
Nameplate rating of the aclual generation units is not an accurate or reasonable estrmate ofthe actual energy these projects will deliver to ldaho Power.
Historical generation information, resource specrfic industry standard capacity factors, and other known and measurable operating characteristics are accounted
for in determining a reasonable estimate of the energy these projects will produce
Attachment No. A
Case No. IPC-E-t9-38
Staff Comments
08107 /20 Page 2 of 2
2017 lntegrated Resource Plan-Appendix C Page 113
REQUEST NO. 1: Under ldaho Power's hourly methodology to establish the
proper rate, there will be two sets of contract rates for the period 2020 through 2025
depending on the amount of generation in each hour and whether or not it exceeds 430
kWh. Please explain how the Company plans to pay the QF when the amount of energy
in any given month is outside of the 90/110 performance band and when there are hours
both above and below the 430 kWh threshold.
RESPONSE TO REQUEST NO. 1: As described in Article 7 .1 of the Sagebrush
Hydro Energy Sales Agreement ('ESA"), Surplus Energy is defined as: (1) Net Energy
produced by the Seller's Facility and delivered to the ldaho Power etectrical system during
the month which exceeds one hundred ten percent (111a/o) of the monthly Adjusted
Estimated Net Energy Amount for the conesponding month specified in paragraph 6.2,
or (2) if the Net Energy produced by the Seller's Facility and delivered to the ldaho Power
electrical system during the month is less than ninety percent (90%) of the monthly
Adjusted Estimated Net Energy Amount for the conesponding month specified in
paragraph 6.2, then all Net Energy delivered by the Facility to the ldaho Power electrical
system for that given month, or (3) all Net Energy produced by the Seller's Facility and
delivered by the Facility to the ldaho Power electrical system prior to the Operation Date,
or (4) all monthly Net Energy that exceeds the Monthly Nameplate Energy. Article 7.2
describes the Surplus Energy Price as: for all Surplus Energy, ldaho Power shall pay to
the Seller the current month's Market Energy Reference Price or the applicable All Hours
Energy Price, whichever is lower.
The First Amendment to the ESA, A(icle 7.6, defines the All Hours Energy Price
as: the price to be used in the calculation of the Surplus Energy Price and Delay Price
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REOUEST OF THE
COMMISSION STAFF - 2 Affachment No. B
Case No. IPC-E-19-38
Staff Comments
08107/20 Page I of 2
shall be the monthly non-levelized All Hours Energy Price in Appendix E or F for
generation received up to 430 kW, and the All Hours Energy Price in Appendix H for
generation received between 431 and 575 kW for calendar years 2020-2025. For
calendar years 2026 through the remaining term of the ESA, the price to be used in the
calculation of the Surplus Energy Price and Delay Price shall be the monthly non-levelized
All Hours Energy Price in Appendix E or F.
For calendar years 2A20-2A25, ldaho Power will determine an actual total All Hours
Energy Price by multiplying the monthly total of hourly generation up to 430 kW by the
applicable All Hours Energy Price in Appendix E or F and by multiplying the monthly total
of hourly generation over 430 kW by the applicable All Hours Energy Price in Appendix
H. The sum of these payment amounts will be divided by the total genera[on received for
the month to calculate a single All Hours Energy Price based on actual generation and
ldaho Public Utilities Commission-approved avoided cost rates. As described in Article
7.2 of the ESA, ldaho Power shall pay to the Seller the current month's Market Energy
Reference Price or the applicable All Hours Energy Price, whichever is lower. During
calendar years 2026 through the remaining term of the ESA, the All Hours Energy Price
to be used in the calculation of the Surplus Energy Price shall be the monthly non-
levelized All Hours Energy Price in Appendix E or F. The payment to the QF will be the
monthly Surplus Energy amount multiplied by the applicable Surplus Energy Price.
The response to this Request is sponsored by Michael Danington, Energy
Contracts Leader, of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REOUEST OF THE
COMMISSION STAFF - 3 Attachment No. B
Case No. IPC-E-19-38
Staff Comments
08/07 /20 Page 2 of 2
SEASONALAND NON.SEASONAL HYDRO FACILITY ENERGY PRICES WITHOUT
CAPACIW, YEARS 2020THROUGH 2025 (AllHours Enerry Price)
Year Season 1(Mills/kwh) Season 2 (Mills/kwh) Season 3 (Mills/kwh)
2020 21.15 34.53 28.78
202L 21,37 34.89 29.07
2022 22.4L 35.58 30.48
2023 24.L4 39.41 32.842024 26.28 42.9t 35.76
2025 28.39 46.35 38.62
AfiachmentNo. C
Case No. IPC'E-19-38
StaffComments
08107120
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7M DAY OF AUGUST 2020, SERVED
TIIE FOREGOING REDACTED COMMENTS OF THE COMMISSION STAFF OF
THE FIRST AMENDMENT TO THE ENERGY SALES AGREEMENT, IN CASE NO.
IPC-E-I9-38, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets @ idahopower.com
DAVID STEPTMNSON
BIG WOOD CANAL CO
409 N APPLE ST
SHOSHONE ID 83352
E-MAIL: davidsteohenson @cableone.net
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
TED SORENSON
WOOD HYDRO LLC
1032 GRANDVIEW DR
TVINS UT 84738
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE