20200520Comments.pdf

DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa I ker@ ida hopower. com
Attomey for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COM PANY'S APPLICATION FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
WHITE WATER POWER COMPANY lNC
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE WHITE
WATER RANCH HYDRO PROJECT
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CASE NO. IPC.E.20.13
COMMENTS OF IDAHO POWER
COMPANY
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ldaho Power Company ("ldaho PoweC'or "Companf), in accordance with RP 201,
ef seg., and the applicable provisions of the Public Utility Regulatory Policies Act of 1978
("PURPA"), as well as the ldaho Public Utilities Commission's ("lPUC" or "Commission")
Notice of Modified Procedure in this mafter, Order No. 34641, hereby respectfully submits
the following Comments.
ldaho Power appreciates Commission Staffs ('Staff") thoughtful comments
regarding their recommendations regarding the ESA applicable to the White Water Ranch
Hydro Project ("Project"). Staff recommends the Commission approve the Energy Sales
ldaho Power Company
Comments - 1
Agreement ('ESA"), but also recommends that when the Company determines the
generator nameplate capacity for a motor used as a generator, the Company should
identiff the proper horsepower ("hp") units on the motor and use 0.7457 hp per kW for
converting from lmperia! hp to kW and 0.7355 hp per kW for converting from metric hp to
kW. Idaho Power agrees with Staff that when an electric motor is being used as a
generator, and where the motor only specifies output capability in horsepower, then a
conversion from hp to kW must be made. However, the Company has concerns about
Staffs recommendation that would require the Company to independently obtain
technical manufacturing specifications that neither the Company or the Project may have
access to, and to do such calculation/conversion in every instance.
A PURPA Qualifying Facility's ("QF') Nameplate Capacity is a standard
requirement identified in PURPA ESAs. The Nameplate Capacity applies to several
terms and provisions, including the amount of Security Deposit (if required), the lnitial
Capacity Determination to verify the QF will not exceed the threshold to be eligible for the
avoided cost prices contained in the ESA, and in the calculation of Surplus Energy.
Another important application of the Nameplate Capacity is that it is used as an input to
the Commission's Surrogate Avoided Resource ("SAR') avoided cost methodology for
calculating published avoided cost prices available to QFs.
As described in Article 4.1.5 Nameplate Capacity of the ESA submitted in this
proceeding, the Project is required to:
Submit to ldaho Power manufacture/s and engineering
documentation that establishes the Nameplate Capacity of
each individual Generation Unit that is included within this
entire Facility. The sum of the individual Generation Unit
capacity ratings shal! be equalto Facility Nameplate Capacity.
ldaho Power Company
Comments - 2
Upon receipt of this data, ldaho Power shall review the
provided data and determine if the Nameplate Capacity
specified is reasonable based upon the manufacturer's
specified generation ratings for the specific Generation Units.
Nameplate Capacity is traditionally and commonly identified by a physical name
plate that is attached to a generation unit. Often, the nameplate rating is stamped with a
measurement of kW output. Idaho Power believes that whenever the generator
manufacturer nameplate is available it should be used as the source of Nameplate
Capacity. However, the Company recognizes there are resources and project
configurations that may require other relevant and applicable methods to determine
Nameplate Capacity. For example, solar projects generate electricity using direct current,
but alternating current (.AC') must be delivered to the utility. To do that, the electricity
generated at the photovoltaic modules must pass through inverters and collectors, and
the fina! AC nameplate is determined through engineering estimations and calculations.
With regard to hydro projects, some QFs have been developed using motors as the
source of generation. ln these instances, there may be a need to determine nameplate
capacity using engineering calculations or conversion of motor capability or hp to kW
output.
ldaho Power appreciates Staffs interest in determining an accurate Nameplate
Capacity as it is a direct input to the SAR methodology for determining avoided cost. This
is especially important for QFs that have modified or installed new equipment that has
resulted in an increase to the Nameplate Capacity. Under this circumstance, it may result
in a need to weight the avoided cost prices applicable to an ESA to account for the
incremental portion of increased Nameplate Capacity and the eligibility for capacity
ldaho Power Company
Comments - 3
payment for the increased amount. See Case No. IPC-E-19-38. ldaho Power believes it
has the flexibility and necessary provisions it needs to make reasonable assessments of
Nameplate Capacity based on the terms and conditions contained in its ESAs with QFs.
Staff comments in Case No. IPC-E-20-16, recognize that ldaho Power has included
provisions in PURPA ESAs that would require a review of the ESA terms, conditions and
pricing should any modifications be made to the Facility, including a change to Nameplate
Capacity. Staff states, "...this provision in future agreements will prevent inaccurate rates
and violations of Commission orders or Federal Energy Regulatory Commission rules due
to changes to the facility."
ldaho Power understands that a reasonably accurate determination of Nameplate
Capacity is important but requiring the Company to verify manufacturer specifications and
separately calculate Nameplate Capacity is beyond what is necessary in each and every
instance to determine Nameplate Capacity for hydro QFs. ln this case, the Project
consistsof two generating units, a 75 hp unitand a 115 kW unit. The 75 horsepower
generation unit converts to 55.93 kW assuming lmperial hp and 55.16 hp assuming Metric
hp, or a difference of less than 1 kW.
ldaho Power believes its is important that the Company continue to base its
determinations of Nameplate Capacity on relevant and applicable data available from the
QFs., and manufacturers. ln caseswhere a hp to kW conversion is required, ldaho Power
will follow Staffs recommendation assuming the information is available. However, the
Company does not believe that it should be required to independently calculate such
conversion in every instance and needs to retain the ability to determine Nameplate
Capacity in accordance with the terms and conditions in its ESAs with QFs, which in some
ldaho Power Company
Comments - 4
instances involves reliance on the manufacture's nameplate.
Respectftrlly submitted this 20h day of May, 2020.
4,,*?.det4-
DONOVAN E. WALKER
Attomeyfor ldaho Power Company
ldaho Povrer Company
Comments - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20h day of May,2020, I served a true and conect
copy of the within and foregoing COMMENTS upon the following named parties by the
method indicated below, and addressed to the following:
Commission Secretary
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
_Hand Delivered
_U.S. Mail
_Ovemight Mail
_FAXX Email [e-mail]
Lorettia Standal, President
White Water Power, Inc.
609 River Road
Bliss, !D 83314
_Hand Delivered
_U.S. Mail
_Ovemight Mail
_FAXX Email [e-mail]
Christy Davenport, Legal Assistant
ldaho Power Company
Comments - 6