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Home My WebLink About20110204NIPPC 67-68 to Joint Utilities.pdfPeter J. Richardson (ISB # 3195) Gregory M. Adams (lSB # 7454) Richardson &. O'Lear, PLLC 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 93~-7904 peter~,rchardsonandolear.coni greg~chardSQnandolear.com R r. 2011 FEB -4 PM h,= 14 Attorneys for Nortwest and Intermounta Power Producers Coalition BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE JOINT PETITION OF IDAHO POWER COMPANY, A VISTA CORPORATION AND ROCKY MOUNTAIN POWER TO ADDRESS AVOIDED COST ISSUES AND JOINT MOTION TO ADJUST THE PUBLISHED AVOIDED COST RATE ELIGIBILITY CAP ) ) CASE NO. GNR-E-IO-04 ) j SIXTH PRODUCTION REQUEST OF THE NORTHWEST AND j INTERMOUNTAIN POWER ) PRODUCERS COALITION TO THE ) JOINT UTILITIES ) ) ) Pursuat to Rile 225 of the Rules of Procedure of the Idaho Public Utilties Commission (the "Commission"), the Nortwest and Intermountai Power Producers Coalition ("NIPPC") hereby requests that Idaho Power Company ("Idaho Power"), Rocky Mounta Power, and A vista Corporation (collectively the "Joint Utilties") provide responses to the following with supporting documents, where applicable. Please refer to NIPPC's prior Production Requests for instrctions and definitions applicable to ths production request. Page 1 - SIXTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 REQUEST FOR PRODUCTION NO. 67 Reference the transcript of oral argument before the Idaho Public Utilities Commissions on Janua 27,2011 at pages 18 - 19, wherein Mr. Walker asserted: Idaho Power in its reply comments disclosed that the softare provider for its modeling program, AURORA, had advised us that there may be some kind of modeling problems with that softare for vey small projects under two megawatts in size and we disclosed that in our reply comments, and prior to that time Idaho Power has not been required to ru AURORA on projects that small and in fact, we have not ru projects smaller than two megawatts though the AURORA modeling, and for several of the reasons that we've outlined in our documents, we had received no requests from anyone to ru AURORA pricing for avoided costs for projects that low either. However, since the tie, since Janua 19th at the time when we filed our reply comments, obviously, we've been workig on ths issue, we consulted with Avista and found out that Avista routinely rus their AURORA modeling for 100 kilowatt projects as par of their IRP process. Also the Company's analysts also ran several test modelings at 100 kilowatt levels and the Company is confdent that the modeling does result in accurate and usable results for projects smaller than two megawatts.. . Also reference id at page 20, wherein Mr. Walker asserted: Well, :frst of all, Madam Commissioner, the Company never did state anywhere tht the AURORA modeling was flawed, so we object to that characterization. . . (a) Please reconcile the assertion quoted above that the "Company never did state anywhere that the AURORA modeling was flawed" with Idaho Power's Reply Comments at p. 13 stating: If the project is small enough that it does not trgger changes in the base model operations, i.e., it is lost in the rounding to MWs or MWhs, then the base model results cou1d be identical to the modeled resu1ts that include the project. This would result in an AURORA pricing of zero. While Idaho Power believes using the IR-based methodology for any project above i 00 kW is the right answer, there are some limitations to modeling projects below a certn size. To remedy this sitution, Idaho Power proposes to work with Staf to reach an appropriate solution... (b) Please identify the "Company's analysts" who "also ran several test modelings" and provide the models they ran along with all supporting work papers. (c) For Avista, please identify the individuals at the company who were "consu1ted with" by Idaho Power, the dates of said consultations and provide a sumary of the consu1tations. Please provide copies of all information, studies or models provide to Idaho Power regarding AURORA and its abilty to estimate avoided costs for projects larger than 100 kW Page 2 - SIXTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 (d) For Idaho Power please identify the individuas at the company who "ran several test modelings" and provide a copy of the results of the test modelings along with supporting work papers. (e) For Idaho Power, please identify the individuals at the company who "consulted with" A vista, the dates of said consu1tations and provide a sumar of the consu1tations. Please provide copies of all information, studies or models provide to Idaho Power by A vista regarding AURORA and its abilty to estimate avoided costs for projects larger than 100 kW. (f) For Avista and Idaho Power, please provide copies of and supporting work papers for the thee most recent iterations of Avista's "routin(e)... rus (of) their AURORA modeling for 100 kilowatt projects as par of their IRP process." (g) Has Idao Power had any communcations "with Staf to reach an appropriate solution"? If so, please sumarize those communications, identify and provide copies of any documents exchanged as par of those communcations. (h) For Idaho Power, please provide all additional evidence supportg the claim in Mr. Walter's oral argument that AURORA yields accurate results forQF projects smaller than 2 MW. REQUEST FOR PRODUCTION NO. 68: Please reference the transcript of Counsel for Avista's oral arguent before the Idaho Public Utilities Commission on Janua 27, 2011 at page 29 wherein Mr. Andrea stated: I do want to address just really quickly Idaho Power's concerns about the AURORA program working for two megawatts or less. As Mr. Walker noted, Idaho Power has worked with A vista over the past week or so to work on that issue and I thnk they've come to the conclusion that they're comfortble that it does in fact work. (a) Please identify the personnel at Avista who "worked" with Idaho Power in the two weeks prior to oral argument. Please also identify the personnel from Idaho Power who they worked with. (b) Please provide all documentation related to the work referenced in Mr. Andrea's statement, including AURORA model rus, work papers and correspondence.Si~~~. iar Rrchar son Gregory Adams RICHASON & O'LEARY, PLLC Page 3 - SIXTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAI POWER PRODUCERS COALITION - GNR-E-IO-04 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the ~of Febru, 201 i, a tre and correct copy of the withn and foregoing SIXTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION was served as shown to the following paries: Jean Jewell Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702 jean. j eweU(ipuc.idaho. gov lL Hand Delivery _U.S. Mail, postage pre-paid Facsimile lL Electronic Mail Donald L. Howell II Kristine Sasser Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702 don.howell(ipuc.idaho. gov krs.sasserCfuc.idaho.gov X- Hand Delivery _U.S. Mail, postage pre-paid Facsimile lL Electronic Mail Donovan E. Walker Lisa D. Nordstrom Idaho Power Company POBox 70 Boise, ID 83707-0070 dwalker(iidahopower.com lnordstrom(iidahopower.com .. Hand Delivery _U.S. Mail, postage pre-paid Facsimile lL Electronic Mail Michael G. Andrea A vista Corporation i 4 i 1 E. Mission Street Spokane, W A 99202 michael.andrea(iavistacorp.com _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile X Electronic Mail Daniel Solander PacifiCorp/dba Rocky Mountan Power 201 S. Main St., Suite 2300 Salt Lake City, UT 841 i 1 daniel.solander(ipaci:fcorp.com Ronald L. Wiliams Wiliams Bradbur PC 1015 W. Hays Street Boise, ID 83702 ron(iwillamsbradbyr.com _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile lL Electronic Mail _ Hand Delivery LU.S. Mail, postae pre-paid Facsimle X Electronic Mail Page 4 - SIXTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 Scott Montgomery President, Cedar Creek Wind, LLC 668 Rockwood Dr. Nort Salt Lake, UT 84054 scott(iwesternenergy. us _ Hand Delivery X-U.S. Mail, postae pre-paid Facsimile X Electronic Mail DanaZenta Sumt Power Group, Inc. 2006 E. Westminster Spokane, W A 99223 dzentz(isumitpower.com _ Hand Delivery -LU.s. Mail, postae pre-paid Facsimile lL Electronic Mail Thomas H. Nelson PO Box 1211 Welches, OR 97067 nelson(fthelson.com _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile X Electronic Mail JohnR. Lowe Renewable Energy Coalition 12050 SW Tremont St Portland, OR 97225 jravensanarcos(iyahoo.com _ Hand Delivery iU.S. Mail, poste pre-paid Facsimile lL Electronic Mail Don Sturevant J.R. Simplot Company POBox 27 Boise, ID 83707-0027 don.stuevant(isimplot.com _ Hand Delivery XU.S. Mail, postae pre-paid Facsimile lL Electronic Mail Robert A. Paul Grand View Solar II 15690 Vista Circle Desert Hot Springs, CA 92241 robertapaul08CÐgmaiLcom _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile lL Electronic Mail James Carkulis Exergy Development Group of Idaho, LLC 802 W. Baiock, Ste 1200 Boise, ID 83702 jcarkulis(fexergydevelopment.com _ Hand Delivery X U.S. Mail, postage pre-paid Facsimle lL Electronic Mail R. Greg Ferney Mimura Law Offices, PLLC 2176 E. Franlin Rd., Ste 120 Meridian, iD 83642 greg(imimuralaw.com Page 5 - SIXTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAI POWER PRODUCERS COALITION - GNR-E-l 0-04 _ Hand Delivery LU.S. Mail, postage pre-paid Facsimile lL Electronic Mail Bil Piske Interconnect Solar Development, LLC 1303 E. Carer Boise, ID 83706 bilpiske(icableone.net Dean J Milere McDevitt & Miler, LLP PO Box 2564 Boise, ID 83701 joe(imcdevitt -miler. com Paul Marin Intermountain Wind, LLC PO Box 353 Boulder, CO 80306 paulmarin(iintermountainwind.com Ronald L. Wiliams Wiliams Brabur, PC 1015 W. Hays Street Boise, ID 83702 ron(iwiliamsbradbur.com Wade Thomas Dynams Energy, LLC 776 W. Riverside Dr., Ste. 15 Eagle, ID 83616 wtomas(idynamisenergy.com Shelley M. Davis Barker Rosholt & Simpson, LLC PO Box 2139 Boise, ID 83701 smd(iidahowaters.com Brian Olmstead Twin Falls Canal Company POBox 326 Twin Falls, ID 83303 olmstead(ftfcanal.com _ Hand Delivery LU.S. Mail, postage pre-paid Facsimile lL Electronic Mail _ Hand Delivery i U.S. Mail, postae pre-paid Facsimile lL Electronic Mail _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile lL Electronic Mail _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile lL Electronic Mail _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile X Electronic Mail _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile X Electronic Mail _ Hand Delivery LU.S. Mail, postae pre-paid Facsimile lL Electronic Mail Page 6 - SIXTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION - GNR-E-l 0-04 Ted Diehl Nort Side Canal Company 921 N. Lincoln St. Jerome, ID 83338 nscan(fcableone.net ~ Hand Delivery L U.S. Mail~ postage pre-paid Facsimile lL Electronic Mail Bil Brown Board of Commissioners of Adams County, ID PO Box 48 Council, ID 83612 bdbrown(ifrontiemet.net ~ Hand Delivery X U.S. Mail, postage pre-paid Facsimile lL Electronic Mail Glen Ikemoto Margaret Rueger Idaho Windfars, LLC 672 Blair Avenue Piedmont, CA 9461 1 glenni1envisionwind.com margaret(fenvisionwind.com _ Hand Delivery LU.S. Mail, postage pre-paid Facsimile lL Electronic Mail Ted Sorenson, P.E. Birch Power Company 5203 South 11 th East Idaho Falls, ID 83404 ted(itsorenson.net _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile lL Electronic Mail Signed_~ Peter Ric äson ~ Page 7 - SIXTH PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION -- GNR-E-IO-04