20200917Randald Bartlett Declaration.pdf

Crregory M. Adams (SB No. 7454)
Peter J. Richardson (ISB No. 3195)
RichardsonAdams, PLLC
515 N. ZZft Street
Boise,Idaho 83702
Telephone: [phone]
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Attorneys for Enel Crreen Power North Americ4 Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
WOOD FIYDRO, LLC,)
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COMPLAINAhIT CASE NO.IPC.EAOAS
vs.
DECLARATION OX' RAI\IDALD
BARTLETT IN ST}PPORI OX'CROSS.
RESPONDENT EIIEL GREEN POWER
NORTII AMERICA INC.'S MOTION TO
DISMISS
IDAHO POWERCOMPAIVY,
RESPONDENT/CROSS.
COMPLAINA}IT,
vs.
ENEL GREEN POWER NORTH AIVIERICA,
[NC.,
CROSS.RESPONDENT
vs.
CENTRAL RIVERS POWER US, LLC,
CROSS-RESPONDENT
DECLARATION OF RA}.IDALD BARTLETT IN SUPPORT OF CROSS.RESPONDENT
ENEL GREEN POWERNORTH AMERIC,A" INC.'S MOTION TO DISMISS
IPC.EAOAS _ PAGE I
I, Randdd Bartlett, declare as follows:
l. This declaration is based on my personal knowledge an4 if called to testiry to the
following facts and expert opinion, I could and would compete,nfly do so. I submit this declaration
in support of Cross-Respondent Enel Green Power North America Inc.'s Motion to Dismiss in
this proceeding before the Idaho Public Utilities Cornnrission (*Commission').
2. I am employed by Enel Green Power North America, Inc. as Senior Director, Hydro
Operations and lvlaintenance. As part of my rcponsibilities, I overs@ the operations of the Rock
Creel#2 hydroelectric project and the mles of power from the facility to Idaho Power Company
under the Firm Energy Sales Agrwment with Idabo Power Company ('Idaho Power') at issue in
this proceeding. I have 6 years of experience administering or overseing electric generation
facilities' operations and sales ofpower under power purchase agreements.
3. For puposes of this declaration, I have reviewed the available information and
calculated a reasonable approximation of the revenue that Idaho Power would likely owe for the
electric energy and capacity deliverd from the Rock Creek #2 faciltty for the remainder of the
term of the Firm Energy Sales Agreement
4. My anatysis assumes that the last day of sales under the Finn Enerry Sales
Agreeme,nt will be April 1, 20U. Article 5.1 of The Firm Energy Sales Agreement states the
agreement remains in effect for 35 Contrast Years. The Rock Creek#2 facility began commercial
operation for sales to Idaho Power on April 2,1988, and therefore the Contract Years run from
April 2 through April I each year - making ttre last day of sales under the 35-year agreement April
1,2024.
DECLARATION OF RAI{DALD BARTLETT IN SI.JPPORT OF CROSS.RESPONDENT
ENEL GREEN POWERNORTH AIvIERICA INC.'S MOTION TO DISMSS
TPC-E-20.28 _ PAGE 2
5. For purposes of this analysis, I have calculated the likely revenrrc that would be
owed by Idaho Power under the Firm Energy Sales Agreement after the date that Idaho Power
filed its cross complaint agaiost Enel Green Power North America, Inc. iu this matter, which was
August 3, 202A. Thus, my aoalysis calculates the likely rev€,nue from August 3,2020 through
April 1,2024.
6 . To forecast the likely generation of the Rock Creek #2 facihty from August 3 , 20ZO
to April 1,2024,I have relied on past generation data in the possession of Enel Green Power North
America, Inc. and my reasonable expoctation of the likely generation to calculare a high estimate
of the likely revenue. The average annual generation for the lifetime of the project is
approximately 7,654 MWhs. Based on the I0 most recent Contract Years QArcA}]9, Contact
Years 2l-30) the average generation was 7,050 lvflilhs. This average of the tast l0 years is
reasonably likely to reflect genemtion for the remainder ofthe term as it is representative of current
conditions. However, the highest generation within the t0 most recent Contract Years was 9,582
MWhs in Contact Ye,ar 23 Q0ll-2012). If facility were to perform at that level of g,S8Z
MWhVyear, then it would produce a total of 35234 MWhs for remainder of the term. This is a
high estimate of generation forthe remainder of the term I will use for the purposes of providing
an estimate on the high side of the likely revenue rmder the agreeme,nt for the remainder of its
term.
7. For purposes of calculating the likely revenue, I have used the currently effective
rates paid underthe Firm Energy Sales Agreemen! which are as follows:
DECLARATION OF RA}.IDALD BARTLETT IN SUPPORT OF CROSS.RESPONDENT
ENEL GREEN POWER NORTI{ AI\{ERICA, INC.'S MOTION TO DISMISS
TPC.E-20.28 _ PAGE 3
Month Base
($/]vrwh)
Adj. as ofJune 2014
($/]vrwh)
Current Total Rate
($/lvtwh)
January $40.10 $9.94 $s0.04
Febnrary $.m.10 $9.e4 $s0.M
ldarch $30.10 $7.31 s37.41
April $30.10 $7.31 $37.4r
May $30.10 $7.31 837.4r
June $48.r0 $l1.93 $60.03
July $48.10 $l1.93 $60.03
August $48.10 $l1.93 s60.03
September $48.r0 $r 1.93 $60.03
October $40.10 $9.94 $s0.04
November $40.10 $9.94 $s0.04
December $40.10 s9.94 $50.M
8. Based on the foregoing inputs, I have calculated that a hig[ estimate of the likely
revenue Idaho Power will owe for sales of energy and c4acity under the agreement for the
remainder of its term is $1,780,205.60 based onthe assumption of 35,234 MWhs of generation.
As can be seeq this arnount is far less than &e amorurt that Idaho Power asks the Commission to
order Enel Green Power North Americq Inc. to pay Idatro Power in its cross corrplaint, which is
$4,059,472.
DECLARATION OF RA},.[DALD BARTLETT IN SUPPORT OF CROSS-RESPONDENT
ENEL GREEN POWERNOR]II AMERICA" INC.',S MOTION TO DISMISS
IPC-E-20-28 _ PAGE 4
I dsclarc und€r p€osffy of p€rjrry ferant b fts larn, of the Stde of ldaho &at the
forcgoing istuedomect
DATED &isgdry of September zWO.
By:e+qM
Raudald Bartleffi
DECI"ARAIION OF RAT.IDAID BARTLETT IN sI]PPORTOF CROSS.RESPONDENT
ENEL GREEN PO$ER NORTII AII{ERICA INC.'S MOTION TO DISMISS
IPC.E.2E28-PAGE 5