20120515Avista 1-4 to Clearwater, Simplot, Exergy.pdf

RECEIVED
MICHAEL G. ANDREA (JSB No. 8308)
Avista Corporation
1411 E. Mission Ave., MSC-23
Spokane, WA 99202
Telephone: [phone]
[e-mail]
Attorney for Avista Corporation
2012 MAY 15 PH L:56
LJAHCUBLiG UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S )
REVIEW OF PURPA QF CONTRACT ) CASE NO. GNR-E-11-03
PROVISIONS INCLUDING THE SURROGATE )
AVOIDED RESOURCE (SAR) AND ) FIRST PRODUCTION
INTEGRATED RESOURCE PLANNING (IRP) ) REQUEST OF A\TISTA
METHODOLOGIES FOR CALCULATING ) CORPORATION To
PUBLISHED AVOIDED COST RATES. ) CLEARWATER PAPER
CORPORATION, J.R. SIMPLOT
COMPANY, AND EXERGY
) DEVELOPMENT GROUP OF
IDAHO. I.LC
)
Pursuant to Rule 225 of the Idaho Public Utilities Commission's ("Commission") Rules
of Procedure, Avista Corporation requests that Clearwater Paper Corporation, J.R. Simplot
Company, and Exergy Development Group of Idaho, LLC ('Pxergy") (each individually a
"Company" and collectively, the "Companies") provide the following documents and
information on or before Tuesday:, June 5, 2012.
This Production Request is to be considered as continuing, and the Companies are
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 documents produced.
FIRST PRODUCTION REQUEST TO
ci .EARWATFR PAPER CORPORATION,
J R. SIM PLOT COMPANY, AND
EXERGY DEVELOPMENT GROUP OF
IDAHO, LLC May 15, 2012
Please provide answers to each question and any supporting workpapers that provide
detail or are the source of information used in calculations. Responses must include the name
and phone number of the person preparing the document, and the name, location and phone
number of the record holder and if different the witness who can sponsor the answer at hearing if
need be See IDAPA 31.01.01.228. Unless expressly indicated in a specific request, all requests
are directed to each of the Companies individually. To the extent that the Companies provide
individual as opposed to ajoint response to any request or any subpart of a request, please
identify each Company's response, including the name and phone number of the person
preparing the response for each Company and, if different, the witness for each Company who
can sponsor such response.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated. Please send all responses to the
address above.
REQUEST NO. 1: On page 7, beginning at line 7 of the direct testimony of Dr. Don
Reading, Dr. Reading states: "The SAR methodology has been robust through all of those
changes and has produced avoided cost rates that have proven to be remarkably accurate in
hindsight."
a)Please provide all analysis and data supporting this statement.
b)Please provide the Companies' positions on whether Idaho's published avoided cost
rates available to wind PURPA developers from January 1, 2010 through December
14, 2010 were "remarkably accurate in hindsight"?
c)Please explain the basis for the response(s) to subpart b of this request and provide
any analysis or data supporting such response(s)
FIRST PRODUCTION REQUEST TO
CLEARWATER PAPER CORPORATION,
J.R.SIMPLOT COMPANY, AND
EXERGY DEVELOPMENT GROUP OF
IDAHO, LLC 2 May 15, 2012
REQUEST NO. 2: On page 34 of the direct testimony of Dr. Don Reading, Chart 1 is used
to explain the difference between the proposed Idaho I1RP method rates in this case and those
for the current Idaho IRP method, the Idaho 2011 IRP, and the Langley Gulch project.
a)Please provide all analysis supporting the data contained in Chart 1 in an Excel
spreadsheet with all formulas intact.
b)Does the data used to create Chart 1 include any adjustments to the gas prices to
reflect current prices?
c)If the answer to subpart b of this request is "no", please explain why no adjustment to
gas prices was used in preparing Chart 1.
d)If the answer to subpart b of this request is "yes," please explain and provide any
supporting analysis and data for any adjustment to the gas prices that was made in
preparing Chart 1.
e)If the answer to subpart b of this request is "no", please explain the purpose of Chart
1 and its relevance to this proceeding.
REQUEST NO. 3: on Page 35 of the direct testimony of Dr. Don Reading, starting at line
16, Dr. Reading states: "For projects over 10 aMW, what is called the 'IRP Method' should
be used only when each utility's IRP is frilly considered and approved through the hearing
process."
a)Did any of the Companies attend or otherwise participate Avista's 2011 IRP
proceedings? If so, please list the Companies that have attended or participated in
an Avista IRP proceeding and provide dates that such Company(ies) attended or
participated in an Avista IRP proceeding and the names of any representatives of
such Company(ies) that participated for or on behalf of such Company(ies).
b)Please explain each Company's understanding of the present oversight and
participation of Commission staff in utility IRP proceedings.
c)What steps, if any, are the Companies (or, if the Companies have different
positions or proposals, any Company) proposing to meet Dr. Reading's criteria
that an "IRP is fully considered and approved"?
REQUEST NO. 4: On page 43, beginning at line 7, of Dr. Reading's direct testimony, Dr.
Reading explains that "for many types of generation projects, it could take much longer than
two years to complete construction alone."
FIRST PRODUCTION REQUEST TO
CLEAR WATER PAPER CORPORATION,
J.R. SIMPLOT COMPANY, AND
EXERGY DEVELOPMENT GROUP OF
IDAHO, LLC 3 May l5,2012
a)Based on the statement above are the Companies stating categorically that solar
and projects cannot be constructed in two years or less?
b)Do the Companies believe that the construction timelines of different sized wind
and solar QFs might take less or more time for construction? Please discuss the
impacts on construction timelines of varying sizes of these two resources: 100
kW, 1 MW, 10 MW, 100 MW.
c)This request is directed only to Exergy. Please provide a list of each PURPA
facility in Idaho that Exergy has developed or participated in the development of
during the last five years.
d)This request is directed only to Exergy. For each PURPA facility listed in the
response to subpart a of this request, please provide a detailed construction
timeframe for the facility, including when the facility commenced major
construction and when it went commercial. Where any construction timeframes
exceeded two years, please provide a detailed description of the causes of the
delay.
e)Langley Gulch will be constructed in approximately two years. Do any or all of
the Companies acknowledge that the construction of a large resource like Langley
Gulch might be more complicated and take longer to obtain commercial operation
than a PURPA resource? Please explain.
f Is it any of the Companies' positions that a firm contract for the sale of the output
of a PURPA facility with pricing is required before any development expenses are
incurred or any development timeline can commence for a PURPA facility? If so,
please list which of the Companies holds such position and explain each such
Company's rationale for its position.
g) Is it any of the Companies' positions that a firm contract for the sale of the output
of a PURPA facility with pricing is required before any preliminary financing
efforts for such facility are completed? If so, please list which of the Companies
holds such position and explain each such Company's rationale for its position.
Dated this 15th day of May 2012.
Michael G. Andrea
Senior Counsel
FIRST PRODUCTION REQUEST TO
CLEAR WATER PAPER CORPORATION,
J.R. SIMPLOT COMPANY, AND
EXERGY DEVELOPMENT GROUP OF
IDAHO, LLC May 15, 2012
CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of May 2012, true and correct copies of the
foregoing First Production Request of Avista Corporation to Clearwater Paper
Corporation, J.R. Simplot Company, and Exergy Development Group of Idaho, LLC
were delivered to the following persons via Email (unless otherwise indicated).
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Email: jean.jewellpuc.idaho.gov
Donald L. Howell, 11
Kris Sassar
Deputy Attorneys General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Email: [e-mail]
kris.sassar(i.•puc.idaho.go'
Dean J. Miller, Esq.
McDevitt, & Miller, LLP
P0 Box 2564
Boise, ID 83701-2564
joemcdevitt-milier.com
Daniel E. Solander
Senior Counsel
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
Email: [e-mail]
Donovan E. Walker
Jason B. Williams
Idaho Power Company
P0 Box 70
Boise, ID 83707-0070
Email: [e-mail]
jwilliamsidahopowcr.com
Peter Richardson
Gregory M. Adams
Richardson & O'Leary
515 N. 27th St.
P0 Box 7218Boise, ID 83702
Email: [e-mail]
[e-mail]
Magan Walseth Decker
Senior Staff Counsel
Renewable Northwest Project
917 SW Oak St, Suite 303
Portland, OR 97205
Email: [e-mail]
R. Greg Ferney
Mimura Law Offices, PLLC
2176 E. Franklin Rd., Suite 120
Meridian, ID 83642
Email: [e-mail]
Page 1—CERTIFICATE OF SERVICE
Ted S. Sorenson, P.E.
Sorenson Engineering, Inc.
5203 South 11 " East
Idaho Falls, ID 83404
Email: [e-mail]
Glenn Ikemoto
Margaret Ruger
Idaho Windfarms, LLC
672 Blair Ave.
Piedmont, CA 94611
E-mail: glennienvisionwind.com
Margaretenvisionwind.com
Shelley M. Davis
Barker Rosholt & Simpson, LLP
1010W. Jefferson St, Ste, 102
P.O. Box 2139
Boise, ID 83701-2139
Email: [e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
Email: [e-mail]
Ronald L. Williams
Williams IBradbury, P.C.
1011 5 W. lays St.
Boise ID, 83702
Email: ron(wii1iamsbradbury.com
Dana Zentz
VP, Summit Power Group, Inc.
2006 E Westminster
Spokane, WA 99223
Email: [e-mail]
Robert D. Kahn
Executive Director
Northwest and Intermountain Power
Producers Coalition
1117 Minor Ave., Suite 300
Seattle, WA 9810
Email: rkalmnippc.org
Thomas H. Nelson
Attorney for Renewable Energy Coalition
P0 Box 1211
Weiches, OR 97067-1211
Email: [e-mail]
Bill Piske, Manager
Interconnect Solar Development, LLC
1303 E. Carter
Boise, ID 83706
Email: [e-mail]
Bill Brown, Chair
Board of Commissioners of Adams County,
Idaho
P0 Box 48
Council, ID 83612
Email [e-mail]
Scott Montgomery
President, Cedar Creek Wind, LLC
668 Rockwood Drive
North Salt Lake, Uta 84054
Email [e-mail]
Wade Thomas
General Counsel, Dynainis Energy
776 E. Riverside Drive, Suite 15
Eagle, ID 83616
Email [e-mail]
Page 2—CERTIFICATE OF SERVICE
James Carku I is
Managing Member
EXERGY DEVELOPMENT GROUP OF
IDAHO, LLC
802 West Banock Street, Ste. 1200
Boise, Idaho 83702
Email [e-mail] is2icxcrgydevelopmcnt.com
Robert A. Paul
Grand View Solar Ii
15960 Vista Circle
l:esci-t Hot Springs, CA
Email: robcrtapaul08gmai Lcom
John R. Lowe
Consultant to Renewable Energy
Coalition
12050 SW Tremont Street
Portland, OR 97225
Email: [e-mail]
Twin Falls ('anal Company
do Brian Olmstead, General Manager
P.O. Box 326
Twin Falls, Idaho 83303-0326
Email: oImsteac!ticanaLconi
E. Thomas Arkoosh
Capitol Law Group, PLLC
205 North 10' th Floor
P0 Box 2598
Boise, ID 83701-2598
Email: tarkooshcapitollawgroup.com
Anon F. Jepson
Blue ribbon Energy LLC
10660 South 540 East
Sandy, UT 84070
Email: arronesqaol.com
Don Sturtevant
Energy Director
J. R. Simplot Company
ONE CAPITAL CENTER
999 Main Street, P.O. Box 27
Boise, Idaho 83707-0027
Email: [e-mail]
North Side Canal Company
do Ted Diehl, General Manager
921 N. Lincoln St.
Jerome, Idaho 83338
Email: [e-mail]
TVIJ Humphries
Blue Ribbon Energy LLC
4515 S. Ammon Road
Ammon, II) 83406
Email: [e-mail] .com
Mary I ,cwallen
Clearwater Paper Corporation
601 W. Riverside Ave.. Suite I 100
Spokane, WA 99201
Email: rnarv.le'allencicarvatcrpaper.corn
Page 3—CERTIFICATE OF SERVICE
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
P.O. Box 844
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
Email: [e-mail]
Don Schoenbeck
RCS
900 Washington St., Suite 780
Vancouver, WA 98660
Email: dws@r -c-s-inc.com
Lori Thomas
Capitol Law Group, PLLC
P0 Box 2598
Boise, ID 83701-2598
Email [e-mail]
Liz Woodruff
Ken Miller
Clean Energy Program Director
Snake River Allance
Box 1731
Boise, 10 83701
Email: [e-mail]
kmil1erstakeriveralliancc.org
Energy Integrity Project
do Tauna Christensen
769 North 1100 East
Shelley, ID 83274
Email: [e-mail]
Tauna Christensen
Enerty Integrity Project
769 N 1100 E
Shelley, ID 83274
Email: [e-mail]
Deborah E. Nelson
Kelsey J. Nunez
Givens Pursley LLP
601 W. Bannock Street
Boise, ID 83702
Email: [e-mail]
kjngivenspursley.com
l\1ichael G. Andrea
Page 4—CERTIFICATE OF SERVICE