20120516REC 1-3 to Staff.pdf

Williams • Bradbury
ATTORNEYS AT LAW RECEVFD
2I2t1AYI6 PM2td
May 16, 2012
UTILITIE8 COMMISSION'
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Re: GNR-E-11-03
Dear Ms. Jewell:
Please find enclosed an original and three copies of the First Set of Data Requests to
the Idaho Public Utilities Commission of the Renewable Energy Coalition for filing in the
above referenced case.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,
Ronald L. Williams
RLW/jr
Enclosures
1015 W. Hays Street - Boise, ID 83702
Phone: [phone] - Fax: [phone] - www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
RECEIVED
22 MAY I6 PM2:Id
iDAHOPUEJ
'o-T111-1 t-r 4
Attorneys for Renewable Energy Coalition
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE COMMISSION'S)
REVIEW OF PURPA QF COTRACT )
PROVISIONS INCLUDING THE )
SURROGATE AVOIDED RESOURCE (SAR))
AND INTEGRATED RESOURCE )
PLANNING (IRP) METHODOLOGIES FOR )
CALCULATING AVOIDED COST RATES )
Case No. GNR-E-1 1-03
FIRST SET OF DATA REQUESTS
FROM RENEWABLE ENERGY
COALITION TO COMMISSION
STAFF
Renewable Energy Coalition ("REC"), by and through its attorney of record, Ronald L.
Williams, requests that Idaho Public Utilities Commission (the "Commission"), provide the
following documents and information on or before Wednesday, June 6, 2012.
I. DEFINITIONS
"Documents" refers to all writings and records of every type in your possession, control,
or custody, whether or not claimed to be privileged or otherwise excludable from
discovery, including but not limited to: testimony and exhibits, memoranda, papers,
correspondence, letters, reports (including drafts, preliminary, intermediate, and final
reports), surveys, analyses, studies (including economic and market studies), summaries,
comparisons, tabulations, bills, invoices, statements of services rendered, charts, books,
pamphlets, photographs, maps, bulletins, corporate or other minutes, notes, diaries, log
sheets, ledgers, transcripts, microfilm, microfiche, computer data (including E-mail),
computer files, computer tapes, computer inputs, computer outputs and printouts,
vouchers, accounting statements, budgets, workpapers, engineering diagrams (including
"one-line" diagrams), mechanical and electrical recordings, telephone and telegraphic
communications, speeches, and all other records, written, electrical, mechanical, or
otherwise, and drafts of any of the above.
PAGE 1- REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
"Documents" includes copies of documents, where the originals are not in your
possession, custody or control.
"Documents" includes every copy of a document which contains handwritten or other
notations or which otherwise does not duplicate the original or any other copy.
"Documents" also includes any attachments or appendices to any document.
2."Identification" and "identify" mean:
When used with respect to a document, stating the nature of the document letter,
memorandum, corporate minutes); the date, if any, appearing thereon; the date, if known,
on which the document was prepared; the title of the document; the general subject
matter of the document; the number of pages comprising the document; the identity of
each person who wrote, dictated, or otherwise participated in the preparation of the
document; the identity of each person who signed or initiated the document; the identity
of each person to whom the document was addressed; the identity of each person who
received the document or reviewed it; the location of the document; and the identity of
each person having possession, custody, or control of the document.
When used with respect to a person, stating his or her full name; his or her most recently
known home and business addresses and telephone numbers; his or her present title and
position; and his or her present and prior connections or associations with any participant
or party to this proceeding.
3."REC" refers to Renewable Energy Coalition.
4."Person" refers to, without limiting the generality of its meaning, every natural person,
corporation, partnership, association (whether formally organized or ad hoc), joint
venture, unit operation, cooperative, municipality, commission, governmental body or
agency, or any other group or organization.
"Studies" or "study" includes, without limitation, reports, reviews, analyses and audits.
6.The terms "and" and "or" shall be construed either disjunctively or conjunctively
whenever appropriate in order to bring within the scope of this discovery any information
or documents which might otherwise be considered to be beyond their scope.
7.The singular form of a word shall be interpreted as plural, and the plural form of a word
shall be interpreted as singular, whenever appropriate in order to bring within the scope
of this discovery request any information or documents which might otherwise be
considered to be beyond their scope.
PAGE 2- REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
II. INSTRUCTIONS
These requests call for all information, including information contained in documents,
which relate to the subject matter of the Data Request and which is known or available to
you.
2.Where a Data Request has a number of separate subdivisions or related parts or portions,
a complete response is required to each such subdivision, part or portion. Any objection
to a Data Request should clearly indicate the subdivision, part, or portion of the Data
Request to which it is directed.
3.The time period encompassed by these Data Requests is from 2008 to the present unless
otherwise specified.
4.Each response should be furnished on a separate page. In addition to hard copy,
electronic versions of the document, including studies and analyses, must also be
furnished if available.
5.If you cannot answer a Data Request in full, after exercising due diligence to secure the
information necessary to do so, state the answer to the extent possible, state why you
cannot answer the Data Request in full, and state what information or knowledge you
have concerning the unanswered portions.
6.If, in answering any of these Data Requests, you feel that any Data Request or definition
or instruction applicable thereto is ambiguous, set forth the language you feel is
ambiguous and the interpretation you are using in responding to the Data Request.
7.If a document requested is unavailable, identify the document, describe in detail the
reasons the document is unavailable, state where the document can be obtained, and
specify the number of pages it contains.
8.If you assert that any document has been destroyed, state when and why it was destroyed
and identify the person who directed the destruction. If the document was destroyed
pursuant to your document destruction program, identify and produce a copy of the
guideline, policy, or company manual describing such document destruction program.
9.If you refuse to respond to any Data Request by reason of a claim of privilege,
confidentiality, or for any other reason, state in writing the type of privilege claimed and
the facts and circumstances you rely upon to support the claim of privilege or the reason
for refusing to respond. With respect to requests for documents to which you refuse to
respond, identify each such document, and specify the number of pages it contains.
Please provide: (a) a brief description of the document; (b) date of document; (c) name
of each author or preparer; (d) name of each person who received the document; and (e)
the reason for withholding it and a statement of facts constituting the justification and
basis for withholding it.
PAGE 3- REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
10.Identify the person from whom the information and documents supplied in response to
each Data Request were obtained, the person who prepared each response, the person
who reviewed each response, and the person who will bear ultimate responsibility for the
truth of each response.
11.If no document is responsive to a Data Request that calls for a document, then so state.
12.These requests for documents and responses are continuing in character so as to require
you to file supplemental answers as soon as possible if you obtain further or different
information. Any supplemental answer should refer to the date and use the number of the
original request or subpart thereof.
13.Whenever these Data Requests specifically request an answer rather than the
identification of documents, the answer is required and the production of documents in
lieu thereof will not substitute for an answer.
14.Please provide the responses to these Data Requests by Wednesday, June 6, 2012, to:
Ronald L. Williams John R. Lowe
Williams Bradbury, P.C. Consultant to Renewable Energy Coalition
1015 W. Hays St. 12050 SW Tremont Street
Boise ID, 83702 Portland, OR 97225
Telephone: [phone] jravenesanmarcosyahoo.com
Facsimile: 208-344-0077
E-mail: ronwilliamsbradbury.com
III. DATA REQUESTS
REQUEST NO. 1: As shown on Staff Exhibit No. 303, Staff witness McHugh
calculates SAR based avoided cost rates for Idaho Power, Avista and PacifiCorp, for "Baseload,
Canal Drop, Fixed PV Solar, and Wind" resources, based on "Staff's understanding of the
utilities' positions," but which calculations also include Staff's proposed changes to the SAR
model. (Reference McHugh testimony, page 12). Based on this same "understanding of the
utilities' positions" and using the same Staff proposed changes to the SAR methodology, please
make the same computation for each of the three utilities for a run-of-river hydro facility? For
purposes of making this calculation, assume the surrogate run of river hydro unit is a 10 aMW
generating station with an assumed monthly generation regime identical to that of Idaho Power's
PAGE 4- REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
Swan Falls Generating station, as shown in Idaho Power's 2011 IRP Appendix C (data), starting
on page 96.
http://www.idahonower.com/pdfs/AboutUs/p1a1mjngForFutur/jrf2Ø 1/2011 IRPAppendixCTechnicalAnnendix.pdf
As part of this response, please explain the basis for the capacity value you have included for
each utility, and provide all workpapers supporting the development of Exhibit 303 for all types
of resources modeled.
REQUEST NO. 2: As shown on Staff Exhibit No. 304, Staff witness Sterling
calculates IRP based avoided cost rates for Idaho Power, Avista and PacifiCorp, for "Baseload,
Canal Drop, Fixed PV Solar, and Wind" resources, based on "Staffs understanding of the
utilities' results," but which calculations also include Staffs proposed changes to the IRP model.
(Reference Sterling testimony, pages 19 —20). Based on this same "understanding of the
utilities' results" and using the same Staff proposed changes to the IRP methodology, please
make the same computation for each of the three utilities for a run-of-river hydro facility? For
purposes of making this calculation, assume the surrogate run of river hydro unit is Idaho
Power's Swan Falls Generating station, as shown in Idaho Power's 2011 IRP Appendix C (data),
starting on page 96.
http://www.idahoDower.comlpdfs/Aboutus/plannjngForFuture/jrp/201 1/20 1 1IRPApendixCTechnica1Aynendixjxif
As part of this response, please explain the basis for the capacity value you have included for
each utility, and provide all workpapers supporting the development of Exhibit 304 for all types
of resources modeled.
PAGE 5— REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
REQUEST NO. 3: Please explain the factors that lead to different results, as between
Staff Exhibit 303 and Staff Exhibit 304, for all five types of resources and for all three utilities?
DATED: This o day of May, 2012
Ronald L. Williams
PAGE 6- REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 16 day of May, 2012, I caused to be served a true and
correct copy of the foregoing document upon the following individuals in the manner indicated
below:
Donovan E. Walker
Jason B. Williams
Idaho Power Company
P0 Box 70
Boise, ID 83707-0070
dwalkeridahopower.com
[e-mail]
LI Hand Delivery
LI US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express
Electronic Transmission
Michael G. Andrea LI Hand Delivery Avista Corporation
1411 E. Mission Avenue - MSC-23 LI US Mail (postage prepaid)
Spokane, WA 99202 LI
LI
Facsimile Transmission
[e-mail] Federal Express
Electronic Transmission
Daniel E. Solander LI Hand Delivery
PacifiCorp dba Rocky Mountain Power LI US Mail (postage prepaid)
201 South Main, Suite 2300 LI Facsimile Transmission
Salt Lake City, UT 84111 LI Federal Express
daniel.solanderpacificorp.com Z Electronic Transmission
Donald L. Howell, II
Kristine A. Sasser
Idaho Public Utilities Commission
472 W. Washington (zip: 83702)
P0 Box 83720
Boise, ID 83720-0074
don.howellpuc.idaho.gov
[e-mail]
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
P0 Box 7218
Boise, ID 83702
peterrichardsonandoleaiy.com
[e-mail]
Attorneys for NIPPC, J.R. Simplot Co.,
Grand View, Exergy Development Group,
Board of County Commissioners of
Adams County, Idaho and Clearwater
Paper Corporation
LI Hand Delivery
LI US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express
Electronic Transmission
LI Hand Delivery
LI US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express
Electronic Transmission
PAGE 7- REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
Robert D. Kahn LI Hand Delivery NIPPC, Executive Director LI US Mail (postage prepaid) 1117 Minor Ave., Suite 300 LI Facsimile Transmission Seattle, WA 98101 LI Federal Express rkahnnippc.org Electronic Transmission
Don Sturtevant LI Hand Delivery Energy Director US Mail (postage prepaid) J.R. Simplot Company LI Facsimile Transmission P.O. Box 27 LI Federal Express Boise, ID 83707-0027 Electronic Transmission [e-mail]
Robert A. Paul LI Hand Delivery Grand View Solar II LI US Mail (postage prepaid) 15690 Vista Circle LI Facsimile Transmission Desert Hot Springs, CA 92241 LI Federal Express robertapau108gmail.com Electronic Transmission
James Carkulis LI Hand Delivery Managing Member LI US Mail (postage prepaid) Exergy Development Group of Idaho, LLC Facsimile Transmission 802 West Bannock Street, Suite 1200 LI Federal Express Boise, ID 83702 Electronic Transmission jcarkulisexergydevelopment.com
Don Reading LI Hand Delivery Exergy Development Group of Idaho, LLC LI US Mail (postage prepaid) 6070 Hill Road LI Facsimile Transmission Boise, ID 83703 LI Federal Express dreadingmindspring.com Electronic Transmission
Bill Brown, Chair LI Hand Delivery Board of Commissioners of Adams County LI US Mail (postage prepaid) P0 Box 48 LI Facsimile Transmission Council, ID 83612 LI Federal Express [e-mail] Electronic Transmission
Mary Lewallen LI Hand Delivery Clearwater Paper Corporation LI US Mail (postage prepaid) 601 W. Riverside Ave., Suite 1100 LI Facsimile Transmission Spokane, WA 99201 LI Federal Express [e-mail] Electronic Transmission
PAGE 8— REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
John R. Lowe
Consultant to Hand Delivery
Renewable Energy Coalition US Mail (postage prepaid)
12050 SW Tremont Street fl Facsimile Transmission
Portland, OR 97225 Federal Express
[e-mail] Electronic Transmission
R. Greg Ferney
Mimura Law Offices, PLLC LI Hand Delivery
2176 E. Franklin Road, Suite 120 [=1
LI
US Mail (postage prepaid)
Facsimile Transmission Meridian, ID 83642 LI [e-mail] Federal Express
Electronic Transmission Attorneys for Interconnect Solar
Bill Piske, Manager LI Hand Delivery Interconnect Solar Development, LLC US Mail (postage prepaid) 1303 E. Carter
Boise, ID 83706 1 Facsimile Transmission
[e-mail] LI Federal Express
Electronic Transmission
Wade Thomas F-1 Hand Delivery General Counsel
Dynamis Energy, LLC LI US Mail (postage prepaid)
776 E. Riverside Drive, Suite 150 LI
LI
Facsimile Transmission
Eagle, ID 83616 Federal Express
Electronic Transmission [e-mail]
C. Thomas Arkoosh F-1 Hand Delivery Capitol Law Group, PLLC
205 N. 10 th St., 4th Floor [:1 US Mail (postage prepaid)
P0 Box 2598 LI Facsimile Transmission
Boise, ID 83701 LI Federal Express
Electronic Transmission tarkooshcapitollawgroup.com
Attorneys for Twin Falls Canal Company
And North Side Canal Company
Brian Olmstead
General Manager LI Hand Delivery
Twin Falls Canal Company E] US Mail (postage prepaid)
Facsimile Transmission PO BoxBox 326 LI Twin Falls, ID 83303 Federal Express
Electronic Transmission [e-mail]
PAGE 9- REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
Ted Diehl
General Manager
North Side Canal Company
921 N. Lincoln St.
Jerome, ID 83338
[e-mail]
D Hand Delivery
F-1 US Mail (postage prepaid)
L1 Facsimile Transmission
fl Federal Express
Electronic Transmission
Ted S. Sorenson 0 Hand Delivery Birch Power Company
5203 South 11 th East 0 US Mail (postage prepaid)
Idaho Falls, ID 83404 Facsimile Transmission
[e-mail] Federal Express
Electronic Transmission
Dean J. Miller
McDevitt & Miller, LLP 0 Hand Delivery
420 W. Bannock Street (zip: 83702) 0
US Mail (postage prepaid)
Facsimile Transmission P0 Box 2564
Boise, ID 83701 Federal Express
Electronic Transmission [e-mail]
Attorneys for Idaho Windfarms, LLC and
Renewable Northwest Project
Glenn Ikemoto r-1 Hand Delivery Margaret Rueger
Idaho Windfarms, LLC fl US Mail (postage prepaid)
672 Blair Avenue F] Facsimile Transmission
Piedmont, CA 94611 0 Federal Express
Electronic Transmission [e-mail]
margaretenvisionwind.com
Megan Walseth Decker
Senior Staff Counsel
Renewable Northwest Project
421 SW 6th Avenue, Suite 1125
Portland, OR 97204
meganrnp.org
0 Hand Delivery
0 US Mail (postage prepaid)
F-1 Facsimile Transmission
fl Federal Express
Electronic Transmission
M. J. Humphries R Hand Delivery Blue Ribbon Energy LLC
4515 S. Ammon Road LI US Mail (postage prepaid)
Ammon, ID 83406 E]
Facsimile Transmission
blueribbonenergygmail.com Federal Express
Electronic Transmission
PAGE 10— REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF
Anon F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, UT 84070
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. Sixth Street (zip: 83702)
P0 Box 844
Boise, ID 83701
[e-mail]
Liz Woodruff
Ken Miller
Snake River Alliance
P0 Box 1731
Boise, ID 83701
lwoodruffsnakeriveralliance.org
kmillersnakeriveralliance.org
Tauna Christensen
Energy Integrity Project
769N. 1100E.
Shelley, ID 83274
taunaenergyintegrityproject.org
LI Hand Delivery
LI US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express
Electronic Transmission
LI Hand Delivery
US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express
Electronic Transmission
LI Hand Delivery
LI US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express
Electronic Transmission
LI Hand Delivery
LI US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express
Electronic Transmission
Ronald L. Williams
PAGE 11— REC'S FIRST SET OF DATA REQUESTS TO COMMISSION STAFF