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HomeMy WebLinkAbout20101227NIPPC 23-54 to Joint Utilties.pdf, Peter J. Richardson (ISB # 3195) Gregory M. Adams (ISB # 7454) Richardson & O'Lear, PLLC 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938..7901 Fax: (208) 938-7904 peter~richardsonadolear.com greg~richardsonandolear.com Rt=rr:~ ~~~~.--= 20m DEC 27 AM 10= 32 Attorneys for Nortwest and Intermountain Power Producers Coalition BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE JOINT PETITION ) OF IDAHO POWER COMPANY, AVISTA ) CASE NO. GNR-E-I0-04 CORPORATION AND ROCKY MOUNTAIN ) POWER TO ADDRESS AVOIDED COST ~ FOURTH PRODUCTION REQUEST OF ISSUES AN JOINT MOTION TO ADJUST ) THE NORTHWEST AND THE PUBLISHED AVOIDED COST RATE ) INTERMOUNTAIN POWER ELIGIBILITY CAP ) PRODUCERS COALITION TO THE ) JOINT UTILITIES ) ) ) Pursuat to Rile 225 of the Riles of Procedure of the Idaho Public Utilities Commssion (the "Commission"), the Nortwest and Intermountan Power Producers Coalition (''NIPPC'') hereby requests that Idaho Power Company ("Idaho Power"), Rocky Mountan Power ("RMP"), and A vista Corpration ("A vista" and collectively the "Joint Utilities") provide responses to the following with supporting documents, where applicable. Because the subject matter of these requests is relevant to Joint Utilities' Joint Motion for expedited Commission determination of Page 1 .. FOURTH PRODUCTION REQUEST OF TH NORTHWEST AN INRMOUNTAI POWER PRODUCERS COALITION - GNR-E-l 0-04 t the eligibilty cap for published avoided cost rates, NIPPC requests expedited processing of these production requests. This production request is to be considered as continuing, and the Joint Utilities are requested to provide by way of supplementa responses additional documents that they or any person acting on their behalf may later obtai that wil augment the responses.or documents produced. Please provide one physical copy and electronic copies, if available, of your anwer to Mr. Richardson and Mr. Adas at the address noted above. For each item, please indicate the name of the person(s) preparg the anwers, along with the job title of such person(s) and the witness at hearng who can sponsor the answer. Some of the followig requests may include disclosures deemed by the Jaint Utilties to be confidential. Counsel for NIPPC is prepared to sign any such agreement to obtan the materials relevant to ths proceedig, and expects that executig such a confdentiality .agreement will not delay the responses to these Requests for Production. Page 2 - FOURTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04 , REQUEST FOR PRODUCTION NO. 23 Reference Avista's Initial Comments, page 9 (stating "Proposals for larger utilty-scale projects, where the developers have both the means and sophistication to negotiate a QF rate, should be subjected to a negotiated rate"). (a) Please provide, in electronic format, the economic model Avista proposes to use to negotiate with developers of larger projects. (b) Please provide a copy of the gudelines A vista proposes to use in sad negotiations. (c) Please explain what safeguards Avist will employ to insure tht all QFs are trated in a non discriminatory maner. REQUEST FOR PRODUCTION NO. 24 Reference Avista's Initial Comments, page 4 (stating "utilty customers are paying developers too much under the published rates"). Reference Rocky Mountan Power's Intial Comments, page 5 (stating "Rocky Mounta Power is prarly concerned with the increase in power supply costs, and the resulting increase in rates to its customers that the curent published avoided cost using the SARmethodology causes...") Reference Idaho Power's Intial Comments, page 7 (stating "Idaho Power is deeply concerned with the increase in power supply costs due to these contracts, and the resulting increase in rates to its customers, that the curent published avoided cost, SAR methodology, causes.") (a) Pleae admit or deny that each utilty is required to pay QFs its ful avoided cost. (b) Please adit or deny that each utilty is required to pay QFs its ful avoided cost - even if doing so places upward pressure on its retail rates. (c) If your response in (a) is to deny, pleas explai the circumstaces under which your utility is excused from paying QFs your full avoided cost. (d) If your response in (b) is to deny, please explain the circumstaces under which your utility is excused from payingQFs ful avoided cost. REQUEST FOR PRODUCTION NO. 25 Reference Rocky Mountan Power's Initial Comments, page 8 (stating "The Commission should balance the desire to stimulate QF development with the mandate that customers not pay more for QF power than for other resources." Page 3.. FOURTH PRODUCTION REQUEST OF THE NORTHWEST AND INRMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04 t (a) What is Rocky Mountan Power's understanding of the phrase "desire to stimulate QF Development"? (b) Please identify the source of that understading in Commission orders or otherwse. (c) Please admit or deny that the Commission has a mandate to stimulate QF development. (d) If you deny that the Commission has a mandate to stimulate QF development please explain the source of your denial in Commission orders or otherwse. REQUEST FOR PRODUCTION NO. 26 Reference Rocky Mountain Power's Initial Comments, page 8 (stating "The rationale for stadard rates is to minimize tranaction costs for small projects."). Reference Avista's Intial Comments, page 8 (stating "Published rates are intended for smaller projects, in large par to ease the adinistrative burden of the developer in negotiating the economic component of the QF contract.") Reference Idaho Power's Intial Comments, page 9 (statig "The more prescriptive SAR-based published avoided cost methodology was developed and intended for smaller projects and the more unsophisticated developers in par to ease the admstrative burden on the developer and to 'level the playing field' in negotiating the economic components of a Q F contract.") (a) Please explain the basis for the statements and provide supportg documentation. (b) Are you aware of any other rationale or intent for stadard rates? If so, please pròvide documentation for that understding. (c) Please document, by category (e.g. legal, engineering, accounting) the transaction costs associated with negotiating a power purchase agreement with your utility. (d) Please quantify and document the difference in cost to a developer to negotiate a power purchase agreement with your utility for a i OOkw power purchase agreement and the following: (i) alSO kw power purchase agreement (ii) a 500 kw power purchase agreement (iii) a i, 000 kw power purchase agreement (iv) a 5,000 kw power purchase ageement (v) a 10,000 kw power purchase agreement (d) Please provide copies of all internal company manuals, gudes, correspondences, policy statements of whatever form that instrcts company personnel in how to negotiate a power purchase agreement with a QF. Identify the company personnel who are assigned to such negotiations. Page 4 - FOURTHPRODUCTION REQUEST OF TH NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04 , (e) Please identify and document all efforts (if any) your utility has taen to streamline and/or mae the QF contrct negotiatiòn process as inexpensive, transparent and effcient as possible. REQUEST FOR PRODUCTION NO. 27 Reference Idaho Power's Intial Comments, page 9 (stating, "historical 'unsophisticated' QF project developers...") (a) Pleas identify the source of the quotation. (b) Pleas define how Idao Power uses the term ''usophisticated.'' (c) Pleas provide a list of the QF projects with which Idaho Power has an executed power purchase agrement that it views as being "unophisticated." REQUEST FOR PRODUCTION NO. 28 Reference RMP's Initial Comments, page 5 (referencing QF acuisition though a competitive bidding process). (a) Please admit or deny that the Idao PUC has never promulgated competitive bidding ries or gudelines applicable to utilty resource acquisitions. REQUEST FOR PRODUCTION NO. 29 Reference Idaho Power's Initial Comments, page 7 (stating "The additional 678MW of signed QF wind contracts that have been submittd to the Commssion represent a tota payment amount of over $3.9 bilion over the 20-year term of the agreements. . . . For comparison, Idaho Power's tota approved rate base is just over $2 bilion.") (a) Please explain the relationship between Idaho Power's rate base and payments to wind QFs. (b) Please admit or deny tht a more logical comparson would be between Idaho Power's revenue requirement over the sae period? (c) What is Idaho Power's curent anua revenue requiement? Please compare Idao Power's estimated revenue requiement over the next twenty years, assuming a 1.5% rate of infation with the $3.9 bilion number referenced above. (d) Pleas identify the dollar amount Idao Power will have avoided paying the identified QFs due to the wid integration discount from its ful avoided cost rate, over the 20 year life the agreements. Page 5 - FOURTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04 . (e) Please explain whether Idao Power's revenue requirement over the 20 year period may increase or decrease with changes in maket factors, such as gas prices and futue environmental regulation. Please explain whether the rates owed to the wind QF developers may change over the 20 year life the agreements due to market factors. REQUEST FOR PRODUCTION NO. 30 Reference Idao Power's Initial Comments, page 10 (stating" A system specific analysis, such as the IR-based methodology, that considers the characteristics of the specific resource under question is necessar to determine a more accurate assessinent of the costs avoided aSa result of adding a specific PURP A resource. A tre avoided cost determination which would be appropriate for renewable projects that generate renewable energy certificates ("RECs"), would consider the cost to the utility to develop and operate a similar project over a 20-year period. This would tae into account the RECs, governent ta incentives, accelerated depreciation allowances, and other similar cost incentives that the utility, and its customers, wouldhavethe advantage of if the utility were to build the resource, and that curently generate a double recovery windfall for the QF developer."). (a) Please reconcile the first sentence's assertion that the IRP methodology considers the "characteristics of a specifc resource" using a "system specific analysis" with the apparent assumption in the second and thrd sentences that a "tre avoided cost determination" assumes that the utility itself is the developer of the project. (b) Is it Idaho Power's position that its ''te avoided costs" are the costs to it to constrct a renewable project takng into account the RECs, etc.? (c) Under the scenaro posited under the ''te avoided" cost assertion, would the power purchase agreement discount from payments to the developer the value of the RECs, governent tax incentives, accelerated depreciation and other similar cost incentives? (d) Please explain what is meant by the phrase "double recovery widfall."Please provide documentation of the windfall and quantify it. (e) Is it Idaho Power's position that federal and state authorized tax incentives are inappropriate? If not, then please explain the use of the phrase "double recovery windfall"? (f) If RECs were provided by a QF and RECs were needed by th utility, would the utility be avoiding the cost of acquiring the RECs elsewhere? W ould it be appropriate to set the PUR A avoided cost rate at a level that reflected the avoided cost of the RECs delivered to the utility? Reference California Public Utilities Commission, 133 FERC ir 61,059, ir 26 (Oct. 21,2010) (order denying rehearing). (g) Is the curent SAR methodology (including the discount for wind integration) designed to compensate wind QFs for the value of the RECs, or just the value of the energy and capacity provided? Page 6 - FOURTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04 , (h) Admit or deny that the value of the avoided cost rate generated in Stas strawman wid SAR was higher than the curent published avoided cost rates authorized in Order No. 31025. REQUEST FOR PRODUCTION NO. 31 Reference Idao Power's Intial Comments, page 10 (stating that a "Problem" with the SAR methodology is that it is "essentially static" and that "The published avoided cost rates are updated infequently at best. . . "). (a) Please identify the constraints preventing Idaho Power from seeking more frquent updtes of the SAR. (b) Admit or deny that any Idaho utilty may file a petition to update the avoided cost rates at any time. (c) Please explai why Idaho Power, A vista and RMP are seeking to overhall the Commssion's PURPA implementation methodology rather than seeking an update of the SAR rates? REOUEST FOR PRODUCTION NO. 32 Reference Idaho Power's Initial Comments, page 12 (stting "The curent state ofPURPA development in Idao has created a situation where the IRP plang process is being circumvented in order to benefit independent developers wanting to build genertion projects in Idaho Power's service terrtory."). (a) Please explai why Idaho Power's IRP process is not robust enough to adopt to changing circumstaces. (b) Wht is Idaho Power's policy on incorporating potential futue PURP A projects into its IRP load and resource planng process? Please document. (b) Is it Idaho Power's position that the IRP is a mandate from the Commssion as to how it will develop futue resources? Please explain. REQUEST FOR PRODUCTION NO. 33 Reference Idaho Power's Initial Comments, page 13 (stating "Actual performance of the wid projects under contract to Idaho Power durng the sumer of2010 suggests that a 5 percent capacity expectation is accurate.") (a) Please provide documentation, including workpapers supportng that asserion. REQUEST FOR PRODUCTION NO. 34 Page 7 -FOURTH PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 , Reference Idaho Power's Intial Comments, page 13 (stating "However, the quantity ofPURPA development curently being seen in Idaho was never contemplated when the PURP A rules were established by the Commission") (a) What was the quantity of PUR A development contemplated by the Commission when the PURP A rules were established by the Commission? Please provide supporting documentation. REQUEST FOR PRODUCTION NO. 35 Reference Idaho Power's Initial Comments, page 14. (a) Please provide a copy of the Operating Plan for the entire year. REQUEST FOR PRODUCTION NO. 36 Reference Idaho Power's Initial Comments, page 15. (a) Please provide all supporting documentation and workpapers used to prepare Figue 2. REQUEST FOR PRODUCTION NO. 37 Reference Idaho Power's Initial Comments, page 16. (a) Please provide all supporting documentation and workpapers used to prepare the table on that page. REQUEST FOR PRODUCTION NO. 38 Reference Idaho Power's Initial Comments, page 17. (a) What is the expected impact of the planed Hemmngway to Boardmantransinssion project on the transfer rights identified on that page. Please provide documentation and workpapers supporting your response. REQUEST FOR PRODUCTION NO. 39 Reference Idao Power's Initial Comments, page 18. ( a) Please provide copies of the heavy and light load hour forward market forecasts for the time frame referenced in Figure 3. REQUEST FOR PRODUCTION NO. 40 Reference RMP's Attchment to NIPPC Request 3(b), at p. 2 of 12 (stating that Mr. Bruce Grswold stated that he "wish( ed) we (private developers) would all just go away"). Page 8 - FOURTH PRODUCTION REUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04 I (a) Please admt or deny tht Mr. Grswold made the statement, or a substatially similar statement. (b) Has Mr. Grawold ever made such a statement, or a substatially similar statem.ent? (c) Does Mr. Grswold wish private developers would just go away? (d) Would Mr. Grswold prefer that Rocky Mountain Power build all of its own generatingresources, rather than contract with private developers? (e) Please provide Mr. Griswold's Job description and describe Mr. Grswold'sresponsibilities with regard to PURP A contracts and developments. (f) Was Mr. Grswold speaking on behalf of Rocky Mounta Power when he made that statement? (g) If Rocky Mountan Power objects to (a) of ths question on grounds of hearsay or denies the staement, please provide the name, address, and phone number of the person who sent the emaiL. REQUEST FOR PRODUCTION NQ. 41 Reference Idaho Power's Intial Comments, at page 19 (stating transmission upgrades for PUR A wind. projects "may actuly increase the cost to customers even more"). (a) Admit or deny that PURPA developer pay for interconnection costs. (b) Admt or deny that PURPA developers in the past have paid for 75% of up front network upgrades, and receive no refud for 25% of the costs. Reference Order No. 32136. (c) If the response to (b) is to admit, admt or deny that under ths approved framework ratepayers never pay for 25% of the network upgrades caused by a PURP A development. Admt or deny that ratepayers defer payment of 50% of such Network Upgrades. (d) Admt or deny that ratepayers pay for 100% of interconnect facilties and network upgrades necessar to bring a Company-owned generation to load. REQUEST FOR PRODUCTION NO. 42 Reference Idao Power's Initial Comments, at page 23 (stating that the average bid into the 2012 RFP was between $85/MWh and $ 1501MWh, compared to the curent $82.38/MWh tate being "put" to Idaho Power by wind QFs). (a) Admt or deny that the $82.38/MWh figue does not include a reduction for the $6.50IMWh wind integration rate. Page 9 - FOURTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 i (b) Provide the 20-year levelized rate contaning an adjustment for the wind intergration charge curently approved by the Commission. (c) Admt or deny that the published rates being "put" to Idaho Power by QFs is lower than any bids made into the RFP. If the response is to deny, please provide your estimate for value of the RECs that may have been included, and supporting documentation for that REC value estimate, and the redacted bid. REQUEST FOR PRODUCTION NO. 43 Reference the wesbsite for Ida West Energy, describing the company's 50% ownership of several hydropower resources, available online at http://02e5106.netsolhost;comltablehyd.htm . (a) Admit or deny that Ida West Energy is a subsidiar ofIdaho Power's parent company, IdaCorp. Admit or deny the Idaho Power and IdaWest Energy are affiliates. (b) Are any of the eight hydropower projects listed curently sellng their electcal output under PURP A contracts? If so, identify which project and the purchasing utility. Please provide the contracts. (c) Does Idaho Power believe that these QF projects are among the QF projects for which ratepayers are overpaying? (d) Are the rates in these contrcts above or below the Mid-C rates as projected on Idaho Power's graph on page 18 of its Intial Comments. REQUEST FOR PRODUCTION NO. 44 Reference Idaho Power's investment relations presentation dated April 1,2010, at slide 30 (stating Langley Gulch wil be "Capable of integrating intermittent, alternative resources such as wind and solar':'), available online at htt://ww.idacorpinc.comlpdfs/presentationsIMW_Analyst_Pres_3_1 0 _IlL pdf. (a) Admit or deny that Langley Gulch increases the level of wind penetration the Company can safely integrate. (b) Admit or deny that the Company's gas peakg plants (Bennet Mountain and Danskin) can be used to integrate wind. Has the Company used Bennet Mountan or Danskito integrate wind? (c) Admit or deny that Idaho Power believed in its 2007 Wind Study that it couldsaely integrate 600 to 900 MW of wind. (d) Which of the following resources did Idaho Power consider in its 2007 Wind Study in its determination that it could safely integrate 600 to 900 MW of wind: Page 10- FOURTH PRODUCTION REQUEST OF TH NORTHWST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 (i) Langley Gulch. (ii) Bennet Mountan. (ii) Danki. (e) Considering all of the resources in (d), what level of wind penetration does Idao Power believe it can safely integrate? REQUEST FOR PRODUCTION NO. 45 Referençe Id.o Power's Iitial Comments at page 18 (contaning a graph of Mid C prices and light load PURPA rates). (a) Did Id.o Power adjust the amount of wid online for the online dates set in the contrcts before the Comiission, many of which ar not projected to come online until 2013 or 2014? Provide supporting documentation. (b) Explain how Id.o Power generated the Mid-C price profile. Can Idao Power enter into a 20-year contract today for energy and capacity at the rates contaned for Mid-C prices? (c) Admt or deny that Idaho Power concluded in its most recent wind integration study that wid integration chages decrease as market prices decrease. (d) Please explai why in Idao Power's 2007 wind integration study, Idaho Power proposed to use "historic" Mid-C prices, includig average prices from 2000 at 132/MWh but in the graph in Idaho Power's Intial Comments it uses the Mid-C prices from 2010. Reference Enernex 2007 Idao Power Wind Study, at p. 5. (e) Admit or deny that Mid-C prices between now and 2020, or 2031, are unpredictable, and could 'be signficatly higher than those in Idaho Power's graph. (f) Please generate the same graph with a Mid-C price cure from the dates used in Idao Power's 2007 wind study -- 1998,2000, and 2005. Reference Enernex 2007 Idaho Power Wind Study, at p. 5. Pleae also adjust the PURPA rate to include the wid integration charge. REQUEST FOR PRODUCTION NO. 46 Reference Order No. 30892, p. 6 (estimating that Langley Gulch will cost $126/MWh); see also Comments o/the Commission Staff Case No. IPC-E-09-34, p. 9 (May 3, 2010) (stating Lagley Gulch's levelized cost will be $111.13/MWh). (a) Provide updted levelized price estimates for Langley Gulch in $/MWh ratepayers will pay for its output. If the estimate is substatially different from those quoted above, please explain why. Page 11 ~ FOURTH PRODUCTION REQUEST OF TH NORTHWEST AN INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-1O-04 (b) Please explain whether the estiate in (a) is greater or less than the curent, published avoided cost rates. (c) Please explain whether the estimate in (a) is greater or less than the rates that would be generated for a QF project in the IR method. (d) Please use the inputs for the Langley Gulch plant into the IRPmethodology, and provide the avoided cost rate that the IRP methodology would generate for Langley Gulch. (e) If the rates customers will pay for Langley Gulch are higher than the rates generated in either (or both) of the two PURPA methodologies approved by the Idao Commission, is it fair to say that ratepayers are paying a premium for a Company-owned resource? Please explai. (f) Why would the rates generated in a surogate model fora CCCT be different from the rates charged to ratepayers for Idaho Power's own CCCT it is curently building? (g) With regard to Avista, why are the rates different in the SAR than for the Lancaster Plant? Are the Lancaster rates greater or lower than the SARrates? Please explai. REQUEST FOR PRODUCTION NO. 47 (a) Admit or deny that QF contracts impose no fuel cost risk on the utility or its ratepayers. (b) Admit or deny that the fuel cost for Bridger increased in the 2010 NPSE and PCA filings, and that the Commission authorized recovery for that increase from ratepayers. (c) Admit or deny that PGE estimated that the Boardman coal plant will need $510 milion in upgrades to operate in environmental compliance until 2040. (d) Please provide the cost to Idao Power for upgrades to Boardman PGE has proosedunder Bar III, for operation though 2020. Admt or deny that Boardman could shut down before 2020 if the Sierra Club lawsuit in federal cour is successfu. (e) Wil Idaho Power ratepayers pay for Boardman expenses and pollution control upgrades necessar to operate until 2020? Wil Idaho Power ratepayers pay for any capitalized expenses associated with Boardman regardless of whether the plant closes in 2020, or some earlier date? REQUEST FOR PRODUCTION NO. 48 Is it possible that Boardman Bridger, Valmey, or any ofRMP's coal plants could experience increased costs as a result of ongoing EPA rulemakng proceedigs regarding coal wase, or hazardous air pollutants, or any other new environmenta reguations? Wil your utility pass any increased costs onto ratepayers? Provide all internal studies regarding risk analysis for such future reguations. Page 12 - FOURTHPRODUCTlON REQUEST OF THE NORTHWEST AN INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04 REQUEST FOR PRODUCTION NO. 49 If a wid Q F were forced to face increased costs, or cease or curl operation for envionmenta compliance reasons, do the wind QF contracts allow for wid QFs to increase the rates collected from the utility and its ratepayers? Please explain how ths compares to the Company~owned theral, hydro, and renewable resources of each utilty. REQUEST FOR PRODUCTION NO. 50 Please explai how the avoided cost rate relates to the cost of new resources built by the utilty. Is it reasonable and prudent for the utilitiy to build a new resource when the cost of tht resource will exceed the avoided cost it would pay to a QF? Should the Commission ever approve a non- PURP A resoure that has a higher cost than the avoided cost at the time of approval of CPCN? Please explain. REQUEST FOR PRODUCTION NO. 51 When your utility analyzes new resources in its IRP process, does it compare the cost to the PUR A avoided costs? Does it use the published avoided cost rate schedule, or does it ru the "IR method" for the utilty's proposed resource to deterine if the resource is cost~effective? Please explain and provide supporting documents of instances where the utility has compared the cost of its proposed resources to the avoided cost provided to QFs under and above 10 aMW in size. REQUEST FOR PRODUCTION NO. 52 Considering all applicable Commission Orders, what were the published avoided cost rates in effect for the time period from December 14,2010, to the date of this production request? What is the eligibility cap for availabilty of those rates during the same time period - 10 aMW, 100 kw, or some other amount? Is the response different for different QF resource tys? Please explain. REQUEST FOR PRODUCTION NO. 53 What is the curently filed rate for published avoided cost rates curently in effect, as contemplated in 18 CFR 292.304(c) (1) & (2)? What is the eligibilty cap for that rate for your utilty? REQUEST FOR PRODUCTION NO. 54 Reference Avista (Initial Comments page passim) RMP (Intial Comments passim) Idaho Power (Initial Comments passim) to the effect that the curent SAR methodology and rate eligibilty cap requirement is causing the utilities to incur higher power supply costs that they otherwse would incur. Page. 13 - FOURTH PRODUCTION REQUEST OF TH NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E~10-04 (a) Please explain why it is reasonable for your utilty to insiston a $45 delay liquid securty deposit that is designed to prevent developers from delaying the on line date in their power purchase agreements. (b) Please provide all workpapers, studies, notes memorada or any other documents that were used; (i) to calculate the $45 delay liquid securty number and (ii) in the decision making process to insert it in your draf power purchase agreements with developers. (c) Please identify damages your utility would incur per MW were the QFs referenced in your Intial Comments were to delay their on line date by one year, by two years and by thee years. S~t!s Pdk iuch~.lon Greg Adams RICHASON & O'LEARY, PLLC Page 14 - FOUR'FH PRODUCnON REQUEST OF THE NORTHST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-lO~04 J Bil Piske, Manager Interconnect Solar Development, LLC 1303 E. Carer Boise, ID 83706 E-mai: biliskecableone.net Paul Marin Intermountan Wind, LLC PO Box 353 Boulder, CO 80306 E-mail: aulmarin Wade Thomas General Counsel Dynamis Energy, LLC 776 W. Riverside Dr., Suite 15 Eagle, ID 83616E-mail: wtomas.com Brian Olmstead General Manager Twin Falls Canal Company PO Box 326 Twin Falls, ID 83303 E-mail: olmstead.tfcanal.com Bil Brown, Chair Board of Commissioners of Adams County, ID PO Box 48 Council, ID 83612 E-mail: bdbrownfrontiernet.net Donovan E. Waler Lisa D. Nordstrom Idaho Power Company PO Box 70 Boise,ID 83707-0070 E-mail: dwalker~idahopower.com lnordstrom idao Wer.com Data Request Center PacifiCorp 825 NE Multnomah, Ste. 2000 Portand, 0 9723 By: Dean J. Miler McDevitt & Miler, LLP PO Box 2564 Boise, ID 83701 E-mail: .oecdevitt-miler.com Ronald L. Wiliams Wiliams Bradbur, P.C. 1015 W. Hays Street Boise,ID 83702 E-mail: ronwiliamsbradb.com Shelley M. Davis Barker Rosholt & Simpson, LLP 1010 W. Jefferson St. (83702) PO Box 2139 Boise, ID 83701 E-mail: smdidahowåters.com Ted Diehl General Manager Nort Side Canal Company 921 N. Lincoln St. Jerome, ID 83338 E-mail: nscanalcableone.net Ted S. Sorenson, P.E. Birch Power Company 5203 South 11 th East Idao Falls, ID 83404 E-mail: tedtsorenson.net Michael G. Andrea A vista Corporation 1411 E. Mission Ave. Spokane, VV A 99202 E-mail: michael.andrea~avistacorp.com Page 16-FOURTHPRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-IO-04 \ CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 24th day of December, 2010, a tre and correct copy of the withn and foregoing FOURTH PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES WàS served by ELECTRONIC MAL and US MAL, to: PACIFICORP, dba ROCKY COMMISSION STAFF:MOUNTAIN POWER: Donald L. Howell, IIDanel Solander Krstine A. Sasser PacifiCorpl dba Rocky Mounta Power Deputy Attorneys General 201 S. Main St., Suite 2300 Idaho Public Utilties Commission Salt Lake City, UT 8411 1 472 W. Washington (83702) E-mail: danieL.solanderí1acificom.com PO Box 83720 Boise, ID 83720-0074 E-mail: don.howellí1uc.idaho.gov krs.~-;seru.nuc.idao.g;ov Don Stuevant Energy Director J.R. Simplot Company PO Box 27 Boise,ID 83707-0027 E-mail: don.stuevant($simplot.coin Robert D. Kah Executive Director Nortwest and Intermountan Power Producers Coalition 117 Minor Ave., Suite 300 Seatte, WA 98101 E-mail: rkah(â.niooc.onr Robert A. Paul Grand View Solar II 15690 Vista Circle Desert Hot Springs, CA 92241 E-mail: robertapauio8~gmaii.com Ronald L. Willams Wiliams Bradbur, P.e. 1015 W. Hays Street Boise,ID 83702 E-mail: ron~willamsbradbur.com James Carkulis Managing Member Exergy Development Group of Idaho, LLC 802 W. Banock St., Suite 1200 Boise, ID 83702 E-mail: icarkulistâexeriivdeveloriment.com Scott Montgomery, President Cedar Creek Wind, LLC 668 Rockwood Dr. Nort Salt Lae, UT 84054 E-mail: scott($westernenergy.us Dan Zentz, Vice President Sumit Power Group, Inc. 2006 E. Westmster Spokane, W A 99223 E-mail: dzentz~sunitpower.com Thomas H. Nelson, Attorney PO Box 1211 Welches, OR 97067-1211 E-mail:n~l~fi~elson.c9ø""", . .:\....;: John R. Lowe, Consultat Renewable Energy Coalition 12050 SW Tremont St. Portland, OR 97225 E-mail: iravensanarcostâvahoo.com R. Greg Ferney Mimura Law Offces, PLLC 2176 E. Franin Rd., Suite 120 Meridian, ID 83642 E-mail: iireiilÕmimuralaw.com Page 15 -FOURTH PRODUCTION REQUEST OFTHE NORTHWEST AND INTERMOUNTAI POWER PRODUCERS COALITION - GNR-E-IO-ö4