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Home My WebLink About20101206NIPPC 5-12 to Joint Utilities.pdfPeter J.Richardson (ISB # 3195) Gregory M. Adas (ISB # 7454) Richadson & O'Leary, pLLC 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter(gichardsonandolear.com greg~chardsonandolear.com ",""""C¡,t:tJ\'~ 20lnOEC -6 PM 4= 02 Attorneys for Nortwest and Intermountain Power Producers Coalition BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTR OF THE JOINT PETITION ) OF IDAHO/POWERCOMPANY, AVISTA ) CASE NO. GNR-E-IO-04 CORPORATION AND ROCKY MOUNTAI ) POWER TO ADDRESS AVOIDED COST ~ SECOND PRODUCTION REQUEST OF ISSUES AND JOINT MOTION TO ADJUST ) THE NORTHWEST AN TH PUBLISHED AVOIDED COST RATE ) INTERMOUNTAIN POWER ELIGIBILITY CAP ) PRODUCERS COALITION TO THE ) JOINT UTILITIES ) ) ) Pursuat to Rule 225 of the Rules of Procedure of the Idaho Public Utilties Commssion (the "Commssion"), the Nortwest and Intermountain Power Producers Coalition ("NIPPC") hereby requests that Idao Power Company ("Idaho Power"), Rocky Mountain Power, and Avista Corporation (collectively the "Joint Utilities") provide responses to the following with supportng documents, where applicable. Because the subject matter of these requests is relevant to Joint Utilities' Joint Motion for expedited Commission determination of the eligibility cap for published avoided cost rates, NIpPC requests expedited processing of these production requests. Page i.. SECOND PRODUCTION REQUEST OF TH NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 This production request is to be considered as continuing, and the Joint Utilties are requested to provide by way of supplementa responses additiona documents that they Or any person acting on their behalf may later obtain that will augment the responses or documents produced. Please provide one physical copy and electronic copies, if available, of your answer to Mr. Richardson and Mr. Adas at the address noted above. For each item, please indicate the name of the person(s) preparng the answers, along with the job title of such person(s) and the witness at hearg who can sponsor the answer. Some of the following requests may include disclosures deemed by the Joint Utilities to be confdential. Counsel for NIPPC is prepared to sign any such agreement to obtain the materials relevant to this proceeding, and expects tht executig such a confdentiality agreement will not delay the responses to these Requests for Production. Page 2 - SECOND PRODUCTlON REQUEST OF THE NORTHWEST AN INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04 REQUEST FOR PRODUCTION NO.5 On what basis do the Joint Utilties include Avista Corporation in the Joint Motion to reduce the eligibility cap for published avoided cost rates? REQUEST FOR PRODUCTION NO.6 Please provide copies of all documentation relied upon by the Joint Utilties in makng the decision to include A vista Corporation in the Joint Motion. Said documentation should include all studies, wrtings, documents, correspondence, notes and memoranda used or referenced in the decision makng process to include Avista Corporation in the Joint Motion. REQUEST FOR PRODUCTION NO.7 Does Avistahave any wid QFs curently online? What is the level (nameplate MWs) of wid (PURPA andnon-PURPA) tht Avista is curently integrating on its system? What is Avista's peak, mium and average load (in MWs)? Please provide workpapers supporting the response. REQUEST FOR PRODUCTION NO.8 Reference Joint Petition and Joint Motion, at p. 4, stating Rocky Mountan Power has 358 MW of new wind contract requests. Reference the Joint Petition and Joint Motion at p. 4 statig Idaho Power has over 570 MW of new wind contract requests. a. Wht is the equivalent number for A vista Corpration? b. Please provide a list of all such requests, includg the name of the requesting entity, nameplate capacity of the wid project, point of initial contact with Avista Corporation, and date and natue of the last communcation between the Utilities. c. For each requesng entity, please provide supporting evidence that the project is stil being purued. Such evidence may include a recent correspondence from the requestig entity requesting a contract. d. If the. documents and information requested in items (a) and (b) are unavailable, please explain the basis for the response to No. 7(a) above. REQUEST FOR PRODUCTION NO.9 Reference Joint Petition and Joint Motion Attchment No.1. a. Please provide equivalent data for A vista Corporation and Rocky Mountan Power. Page 3- SECOND PRODUCTION REQUEST OF TH NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 b. Please provide, in electronic format where possible, all workpapers, spreadsheets, and data used in the response to No. 8(a). c. Please state the name of the person who can sponsor ths atthment at a hearg. REQUEST FOR PRODUCTION NO. 10 Reference Joint Petition and Joint Motion at p. 7 stating, "When the utilty is forced to buy QF power in exCeSs of its tre avoided cost or in eXCeSs of its mium loads, customers are no longer indifferent." a. Is it the position of each of the Joint Utilities tht its avoided cost rates are, in fact, ìn excess of ìts tre avoìded costs? b. If the answer to 9(a) ìs yes, please provìde documentation of each of the Joint Utilities' "tre avoìded cost" and in electronic format where possìble, all work papers, spreadsheets and data used ìn response to 9(a). c. If the answer to No. 9(a) is no, please explain the relevance of the asserton relative to "tre avoìded cost" to the Joìnt Utìlties' pleading. REQUEST FOR PRODUCTION NO.1 1 Reference Joìnt Petìtìon and Joint Motion at p. 7 as quote in Request No.9. a. What is each of the Joint Utilìties' mium load? Please explain how that number ìs derived and provìde documentatìon of each of the Joint Utilities' anwer. b. Please provìde your response to No. 10(a) on both a system wide and an Idaho jurisdictìonal basìs. c. Please document the number of hours each year that each of the Joint Utìlìtìes' tota generation exceeds rrìnum load. Please provide ths ìnfomiation on both asysterr wide basìs and an Idao jursdictìonal basìs d. Please document the number of hours each year that generatìon (by type of resource e.g. hydro, coal, natual gas, etc) exceeds minimum load. Please provide ths ìnformation on both a system wide basìs and an Idaho jursdictìonal basìs. e. Please explain, on both engìneering and a fiancìal basìs, each orthe Joint Utilìtìes' response to a sìtutìon where tota generation exceeds minìmum load. Page 4 - SECOND PRODUCTION REQUEST OF TH NORTHWEST AND INTERMOUNTAI POWER PRODUCERS COALITION - GNR-E-IO-04 REOUEST FOR PRODUCTION NO. 12 Reference Joint Petition and Joint Motion at p. 7 stating "It is also importt that ths change in eligibility forpllblished avoided cost rates be applied equaly to the Utilities, as exclusion of one may aetas a "magnett attctng a dispròportionate number of proposals for that utilty." a. For Avista Corpration, please identify all possible firm transmission path into its balancing area from the other two Joint Utilties' Idao balancing areas upon which renewable resources could schedule energy and capacity to A vista. b. For each such trsmission path please identify the available fi transmission cap.acity tht renewable resources may use for delivery of energy and capacity to A vista. c. Please identify andestinate all costs to a renewable resource located in each of the other two Joint Utilties' balancing ara for delivery of energy and capacity to Avista. d. Pleae provide responses to 1 1 (a) - (c) with regard to delivery to Idaho Power from the balancing area of the other Joint Utilities. e. Pleae provide responses to 1 l(a) - (c) with regard to delivery to Rocky Mourtan Power frm the balancing area of the other Joint Utilities. Th you for your prompt attention to ths Second Request for Production. Page 5 - SECOND PRODUCTION REQUEST OF TH NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 6th day of December, 2010, a tre and correctcopypf the within and foregoing SECOND PRODUCTION REQUEST OF THE NORTHEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES was served by ELECTRONIC MAIL and US MAIL, to: Donovan E. Waler Lisa Nordstom Idaho Power Company 1221 West Idao Street Boise, Idaho 83707-0070 dwalker(fidahopower.com Inordstrom(fidahopower .com Ronald L. Wiliams Wiliams Bradbury,P.C. 1015 W. Hays St. Boise ID, 83702 ron(fwilliamsbrbur.com Danel E. Solander Rocky Mountain Power 201 South Main Salt Lake City, UT 84111 Daniel.solander(fpacificorp.com Scott Montgomery President, Ceda Creek Wind, LLC 668 Rockwood Drive Nort Salt Lake, Uta 84054 scottCIwesternenergy.us Michael G. Andrea A vista Corporation 141 1 East Mission Avenue - MSC-23 Spokane, W A 99202 Michael.andrea(favistaorp.com Dana Zentz Vice President, Sumt Power Group, Inc. 2006 E. Westminter Spokane, W A 99223 dzentz(fsummitpower.com Jean Jewell Commission Secreta Idaho Public Utilities Commission 472 West Washington Boise, Idaho 83702 Jean. jewelli$puc.idaho. gov Scott Woodbur Idao Public Utilties CommisSion 472 W. Washigton (zip: 83702) P.O. Box 83720 Boise, ID 83720-0074 Scott. Woodburi$ipuc.igaho.gov Don Stuevant Energy Director 1. R. Simplot Company ONE CAPITAL CENTER 999 Main Street, P.O. Box 27 Boise, Idaho 83707-0027 Don.sturtevant(fsimplot.com Robert A. Paul Grand View Solar 15960 Vista Circle Desert Hot Springs, CA robertpaul(fgmail.com Page 6 - SECOND PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAI POWER PRODUCERS COALITION - GNR-E-IO-04 Thomas H. Nelson Renewable Energy Coalition PO Box 1211 Welches, OR 97067 nelso~tbelson.com R. Greg Ferney Mimura Law Offces, PLLC 2176 E. Franin Rd., Suite 120 Meridian, in 83642 greg($mimuralaw.com James Carkuis Managing Member EXERGY DEVELOPMENT GROUP OF IDAHO,LLC 802 West Banock Street, Ste. 1200 Boise, Idao 83702 jcarkulis($exergydevelopment.com Bil Piske, Manager Interconnect Solar Development, LLC 1303 E. Carer Boise, ID 83706 bilpiske($cableone.net Glenn Ikemoto Margaret Rueger Idaho Windfars, LLC glenn~EnvisionWind.com Margart($EnvisionWind.com Dean J. Miler, Esq. McDEVITT & MILLER LLP P.O. BOX 2564-83701 Boise, Idaho 83702 ioe($mcdevitt-miler .com Paul Marin Intermounta Wind LLC P.O. Box 353 Boulder, Colorado paulmarin($intermountainwind.com By: iQL . e ~ ry M. Ada Page 7 - SECOND PRODUCTION REQUEST OF TH NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04