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Home My WebLink About20120403Canal Companies to IPC 1-19.pdfCpitol Law Group, PLLC RECEIVED C. Tom Arkoosh www.capitollawgroup.com • tarkooshcapitollawgroup.com 2012 APR-3 AM 8:33 2AVK0 FUt U1]LIT!ES COMMSSON April 2, 2012 Idaho Public Utilities Commission P.O. Box 83720 Boise, Idaho 83720-0074 Re: Our Client: Twin Falls Canal Company and North Side Canal Company CLG File No. 6417.000 Dear Commissioners: Enclosed please find an original and three copies of First Production Requests of Twin Falls Canal Company and North Side Canal Company to Idaho Power. If you have any questions or comments, please do not hesitate to contact me. Sincerely, Capitol Law Group, PLLC yq\"~ 30V~ Lori Thomas Paralegal to C. Tom Arkoosh CTA/lbt Enclosures 205 North 10th Street, 4' Floor, P0 Box 2598, Boise, ID 83701-2598 • Tel: (208) 424.8872 • Fax: (208) 424.8874 C. Thomas Arkoosh, ISB No. 2253 CAPITOL LAW GROUP, PLLC 205 N. 10th 4" Floor P.O. Box 2598 Boise, Idaho 83701-2598 Telephone: (208) 424-8872 Facsimile: (208) 424-8874 e-mail: tarkoosh@capitollawgroup.com C F I !C r 202 APR -3 AM 8: 33 I'- l r-.L - Attorneys for Twin Falls Canal Company, Inc. and North Side Canal Company, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE COMMISSION'S REVIEW OF PURPA QF CONTRACT PROVISION INCLUDING THE SUBROGATE AVOIDED RESOURSE (SAR) AND INTEGRATED RESOURCE PLANNING (IRP) METHODOLOGIES FOR CALCULATING PUBLISHED AVOIDED COST RATES. Case No. GNR-E-1 1-03 FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER ANK 0 Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission"), Twin Falls Canal Company and North Side Canal Company hereby request that Idaho Power provide responses to the following with supporting documents, where applicable, as soon as possible, but no later than April 16,2012.This production request is to be considered as continuing, and Idaho Power is requested to provide by way of supplementary responses additional documents that it or any person acting on its behalf may later obtain that will augment the responses or documents produced. FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -1 Please provide one physical copy of your responses to the address above, and electronic copies, if available, to Mr. Arkoosh at the addresses noted above, Please begin each response on a separate page and provide page numbers on responses longer than one page. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness at hearing who can sponsor the answer. REQUEST FOR PRODUCTION NO. 1: Please provide an electronic copy in the original software with all formulae intact of all supporting workpapers and documents used to calculate the values, tables, charts and exhibits in the prefiled testimony of Idaho Power Company witnesses Stokes, Park and Bokenkamp. REQUEST FOR PRODUCTION NO. 2: Please provide complete electronic copies of all data responses provided in response to data requests from all other parties to Idaho Power Company. Please consider this an ongoing data request for the remainder of this proceeding. REQUEST FOR PRODUCTION NO. 3: With regard to the testimony of Mr. E. Mark Stokes, page 4, lines 15-20 and Exhibit No. 1 pages 1-2, please provide an electronic EXCEL file containing the term of each power purchase agreement (beginning and end dates) and the hourly kilowatt amount purchased by IPC (net of station service and self-served load) for the years 2008, 2009, 2010 and 2011 for each of the 96 QF projects currently online. (if hourly k)Xblhr data is not available, please provide the most disaggregated data available for each project for the four year period.) REQUEST FOR PRODUCTION NO. 4: With regard to the testimony of Mr. E. Mark Stokes, page 4, lines 15-20 and Exhibit No. 1 page 3, please provide an electronic EXCEL file indicating the expected on-line date (month and year), the term of each power purchase agreement FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -2 (years or expected end date) and the projected annual energy purchases (kWhs) for each of the 23 QF projects. REQUEST FOR PRODUCTION NO. 5: Please provide an electronic EXCEL file containing IPC's native system hourly loads for the years 2008, 2009, 2010 and 2011. REQUEST FOR PRODUCTION NO. 6: With regard to the testimony of Mr. E. Mark Stokes, page 46, lines 17-21, please provide an explanation and copies of any workpapers or other documents the Company is relying upon to support the proposal to reduce the maximum contract term from 20 to just 5 years. REQUEST FOR PRODUCTION NO. 7: With regard to the testimony of Mr. E. Mark Stokes, page 46, lines 17-21, does the Company have any views on how the 5 year term will impact the ability of a QF to finance a facility or execute a purchase power agreement with the Company? REQUEST FOR PRODUCTION NO. 8: With regard to the testimony of Mr. E. Mark Stokes, page 46, lines 17-21, please provide an explanation and copies of any workpapers or other documents the Company is relying upon to support this assertion. REQUEST FOR PRODUCTION NO. 9: With regard to the testimony of Ms. Tessia Park, page 14, lines 6-8, please provide a complete copy of the study including any supporting appendices or workpapers when it is completed. REQUEST FOR PRODUCTION NO. 10: With regard to the testimony of Ms. Tessia Park, page 25, lines 22-25, please provide a listing of the QF projects ("Applicable QFs") along with the associate size (similar to Stokes Exhibit No. 1) the Company believes would be subject to the proposed Schedule 74 curtailment procedures. FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -3 REQUEST FOR PRODUCTION NO. 11: With regard to the testimony of Ms. Tessia Park, page 25, lines 22-25, please explain and provide the basis for the Company's belief that it can apply proposed Schedule 74 to an existing QF. As part of this response, please provide examples of existing contracts with a specific cite that provides the Company with this curtailment right. REQUEST FOR PRODUCTION NO. 12: With regard to the testimony of Mr. Karl Bokenkamp, page 7, lines 11-16, please provide a complete copy of the Company's Energy Risk Management Policy and Standards. REQUEST FOR PRODUCTION NO. 13: With regard to Exhibit Nos. 7 and 8, if not apparent from the workpapers, please explain the hydro assumption used in the AURORA analysis for both the Company owned hydro resources and the other resources used in the simulation. REQUEST FOR PRODUCTION NO. 14: With regard to Exhibit Nos. 7 and 8, if not apparent from the workpapers, please provide the historical hydro generation by hour by water year the Company uses in performing its AURORA based planning or risk analysis. REQUEST FOR PRODUCTION NO. 15: Please provide a copy of the most recent loss of load probability study or similar reliability or planning reserve margin analysis the Company has conducted. REQUEST FOR PRODUCTION NO. 16: With regard to Exhibit No. 8, please provide a comparable exhibit using all the same assumptions but include the expected case carbon cost adder starting in 2015 as was done in the Company's most recent June 2011 IRP study in the analysis. Please provide all workpapers used to compile the response to this data request. FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -4 REQUEST FOR PRODUCTION NO. 17: With regard to the testimony of Dr. William Hieronymus, page 32, lines 6-8, please provide a complete copy of all documents relied upon to support the assertions in these two sentences. REQUEST FOR PRODUCTION NO. 18: With regard to the testimony of Dr. William Hieronymus, page 76, the sentence on lines 6-7, please provide a complete explanation including references to specific documents to support the assertion the QFICHP settlement is also "about non- QF renewables." REQUEST FOR PRODUCTION NO. 19: With regard to the testimony of Dr. William Hieronymus, page 106, lines 17-19, please provide a complete list of all the "numerous examples of EWGs" that have been built without an executed bilateral contract along with copies of all supporting documentation. DATED thiday of April, 2012. CAPITOL LAW GROUP, PLLC By C. Thomas Arkoosh, Of the Firm Attorneys for Twin Falls Canal Company, Inc. and North Side Canal Company, Inc. FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on thi)-lay of April, 2012, I served a true and correct copy of the foregoing upon each of the following individuals by causing the same to be delivered by the method and to the addresses indicated below: Jean Jewell, Commission Secretary U.S. Mail, postage prepaid Idaho Public Utilities Commission Hand-Delivered 427 W. Washington St. Overnight Mail Boise, Idaho 83702 Facsimile X_ Via E-Mail jean.iewe11puc.idaho.gov Daniel Solander U.S. Mail, postage prepaid Rocky Mountain Power Hand-Delivered 201 S. Main St., Ste. 300 Overnight Mail Salt Lake City, UT 84111 Facsimile _X_ Via E-Mail daniel.solaner@pacificorp.com Ronald L. Williams U.S. Mail, postage prepaid Williams Bradbury PC Hand-Delivered 1015 W. Hays St. Overnight Mail Boise, Idaho 83702 Facsimile X Via E-Mail ron(williamsbradbury.com Robert A. Paul U.S. Mail, postage prepaid Grand View Solar II Hand-Delivered 15690 Vista circle Overnight Mail Desert Hot Springs, CA 92241 Facsimile _X_ Via E-Mail robertpaul08(gmail.com R. Greg Ferney U.S. Mail, postage prepaid Mimura Law Offices, PLLC Hand-Delivered 2176 E. Franklin Rd., Ste. 120 Overnight Mail Meridian, Idaho 83642 Facsimile _X_ Via E-Mail greg(mimuralaw.com Bill Piske, Manager U.S. Mail, postage prepaid Interconnect Solar Development, LLC Hand-Delivered 1303 E. Carter Overnight Mail Boise, Idaho 83706 Facsimile X Via E-Mail billpiske@cableone.net FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -6 Robert D. Kahn, Executive Director U.S. Mail, postage prepaid Northwest and Intermountain Power Hand-Delivered Producers Coalition Overnight Mail 1117 Minor Ave., Ste. 300 Facsimile Seattle, WA 98101 _X_ Via E-Mail rkahn(nippc.org Michael G. Andrea U.S. Mail, postage prepaid Avista Corporation Hand-Delivered 1411 East Mission Ave. Overnight Mail Spokane, WA 99202 Facsimile X Via E-Mail michael.andrea@avistacorp.com Dean J. Miller U.S. Mail, postage prepaid McDevitt & Miller, LLP Hand-Delivered P.O. Box 2564 Overnight Mail Boise, Idaho 83701 Facsimile _X_ Via E-Mail jçmcdevitt-miller.com Don Sturtevant, Energy Director J.R. Simplot Company P.O. Box 27 Boise, Idaho 83707 James Carkulis, Managing Member Exergy Development Group of ID, LLC 802 W. Bannock St., Ste. 1200 Boise, Idaho 83702 M.J. Humphries Blue Ribbon Energy LLC 4515 S. Ammon Rd. Ammon, Idaho 83406 Brian Olmstead, General Manager Twin Falls Canal Company P.O. Box 326 Twin Falls, Idaho 83303 U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile X Via E-Mail don.sturtevan@simplot.com U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile _X_ Via E-Mail j carkulis(exergydevelopment.com U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile Via E-Mail blueribbonenergy(gmai1.com U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile X Via E-Mail olmstead@fcanal.com FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -7 Ted Sorensen PE Birch Power Company 5203 South 11th East Idaho Falls, Idaho 83404 U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile X Via E-Mail jravenesanrnarcos@yahoo.com U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile X Via E-Mail dwalker@idahopower.com jwilliamsidahopower.com U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile X Via E-Mail ted@tsorenson.net John R. Lowe Consultant to Renewable Energy Coalition 12050 SW Tremont St. Portland, OR 97225 Donovan E. Walker Jason B. Williams Idaho Power Company P.O. Box 70 Boise, Idaho 83707-0700 Bill Brown, Chair U.S. Mail, postage prepaid Board of Commissioners of Adams Hand-Delivered County, ID Overnight Mail P.O. Box 48 Facsimile Council, Idaho 83612 _X_ Via E-Mail bdbrown@frontiernet.net Anon F. Jepsen Blue Ribbon Energy, LLC 10660 South 540 East Sandy, UT 84070 U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile Via E-Mail don.howel1(puc.idaho.gov kris. sasser(puc.idaho.gov U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile X_ Via E-Mail kmillersnakerivera1liance.org U.S. Mail, postage prepaid Hand-Delivered Overnight Mail Facsimile _X_ Via E-Mail anones@aol.com Donald L. Howell, II Kristine A. Sasser Deputy Attorneys General Idaho Public Utilities Commission 472 W. Washington St. Boise, Idaho 83702 Ken Miller Snake River Alliance P.O. Box 1731 Boise, Idaho 83701 FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -8 Wade Thomas, General Counsel U.S. Mail, postage prepaid Dynamis Energy, LLC Hand-Delivered 776 W. Riverside Dr., Ste. 15 Overnight Mail Eagle, Idaho 83616 Facsimile Via E-Mail wthomas(dynamisenergv.com Glenn Ikemoto U.S. Mail, postage prepaid Margaret Rueger Hand-Delivered Idaho Windfarms, LLC Overnight Mail 672 Blair Ave. Facsimile Piedmont, CA 94611 X Via E-Mail gleunienvisionwind.com margaretenvisionwind.com Ted Diehl, General Manager U.S. Mail, postage prepaid North Side Canal Company Hand-Delivered 921 N. Lincoln St. Overnight Mail Jerome, Idaho 83338 Facsimile Via E-Mail nscanal@cableone.net Megan Walseth Decker U.S. Mail, postage prepaid Senior Staff Counsel Hand-Delivered Renewable Northwest Project Overnight Mail 917 SW Oak St., Ste. 303 Facsimile Portland, OR 97205 _X_ Via E-Mail megan(rnp.org Peter J. Richardson U.S. Mail, postage prepaid Gregory M. Adams Hand-Delivered Richardson & O'Leary, PLLC Overnight Mail P.O. Box 7218 Facsimile Boise, Idaho 83702 _X_ Via E-Mail peter@richardsonandolearv.com gregcrichardsonando1earv.com Mary Lewallen U.S. Mail, postage prepaid Clearwater Paper Corporation Hand-Delivered 601 W. Riverside Ave., Ste. 1100 Overnight Mail Spokane, WA 99201 Facsimile Via E-Mail marv.lewallen@clearwaterlDaper.com Benjamin J. Otto U.S. Mail, postage prepaid Idaho Conservation League Hand-Delivered P.O. Box 844 Overnight Mail Boise, Idaho 83701 Facsimile X Via E-Mail botto@idahoconservation.org FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER -9 Thomas H. Nelson U.S. Mail, postage prepaid Attorney at Law Hand-Delivered P.O. Box 1211 Overnight Mail Weiches, OR 97067-1211 Facsimile Via E-Mail nelson@thnelson.com C. Thomas Arkoosh FIRST PRODUCTION REQUESTS OF TWIN FALLS CANAL COMPANY AND NORTH SIDE CANAL COMPANY TO IDAHO POWER - 10