20120605IPC to Exergy 52-58.pdf

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DONOVAN E. WALKER OAHO PUCi.
Lead Counsel UT:L!TtES COMMiSSO
dwalkeridahopower.com
June 5, 2012
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. GNR-E-11-03
PURPA SAR and IRP Methodologies - Response to Exergy Development
Group of Idaho's Fifth Production Request
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Response to the Fifth Production Request of Exergy Development Group of
Idaho ("Exergy") to Idaho Power Company in the above matter.
Also, enclosed in a separate envelope are four (4) copies of the confidential
documents provided in response to Exergy's Request for Production No. 53. Please
handle the confidential information in accordance with the Protective Agreement executed
in this matter.
Very truly yours,
Donovan E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS (ISB No. 8718)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwaIker(idahopower.com
jwilIiamsidahopower.com
P E (' :- I '
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Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
REVIEW OF PURPA QF CONTRACT
PROVISIONS INCLUDING THE
SURROGATE AVOIDED RESOURCE
(SAR) AND INTEGRATED RESOURCE
PLANNING (IRP) METHODOLOGIES FOR
CALCULATING PUBLISHED AVOIDED
COST RATES.
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY'S
RESPONSE TO THE FIFTH
PRODUCTION REQUEST OF
EXERGY DEVELOPMENT GROUP
OF IDAHO TO IDAHO POWER
COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Fifth Production Request of Exergy Development Group of Idaho
("Exergy") to Idaho Power Company dated May 15, 2012, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -1
REQUEST FOR PRODUCTION NO. 52: Reference Idaho Power's Response to
Exergy Production Request No. 44. Please list the names and job titles of the
individuals involved in developing the confidential Schedule 72 policy. Please provide
all work papers and supporting documents used in development of the policy. Please
identify QFs to which Idaho Power has provided the policy.
RESPONSE TO REQUEST FOR PRODUCTION NO. 52: As Idaho Power
described in its response to Exergy's Request for Production No. 44, the Schedule 72
"policy was developed following internal discussions among Idaho Power's operations
and legal personnel . . . ." Accordingly, Idaho Power objects to this Request on the
grounds that the requested material is or may be privileged and protected by the
attorney-client privilege as well as the attorney-work product doctrine
Idaho Power also objects to this Request on the grounds of relevance. Schedule
72 is an existing, Idaho Public Utilities Commission- ("Commission") approved tariff
schedule and the current version has been on file and in place since 2008. Idaho
Power is not proposing any modifications to Schedule 72 related to its right to curtail as
stated therein. Accordingly, information related to Idaho Power's curtailment rights
under Schedule 72, including the names of the individuals and the workpapers used to
develop the Schedule 72 policy, are irrelevant in this proceeding.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -2
REQUEST FOR PRODUCTION NO. 53: Reference Idaho Power's Response to
Exergy Production Request No. 45, containing a list of curtailments implemented under
Schedule 72. For each event, please explain why the Company's Schedule 72 policy
applied. Please document each decision to implement curtailment, including all internal
communications regarding the curtailment. Please explain why the Company continued
generating at its own plants at the specific generation levels provided. For example, the
explanation should include why the Company was generating at far above its minimum
hydroelectric generation level at 1434 MW during the curtailment on April 6, 2012.
RESPONSE TO REQUEST FOR PRODUCTION NO. 53: Idaho Power objects
to this Request on the grounds of relevance. Schedule 72 is an existing, Commission-
approved tariff schedule and the current version has been on file and in place since
2008. Idaho Power is not proposing any modifications to the currently-approved
Schedule 72 related to its right to curtail generators as stated therein. Accordingly,
information related to Idaho Power's curtailment rights under Schedule 72, including all
internal communications regarding curtailment, are irrelevant in this proceeding.
Idaho Power also objects to this Request on grounds that the Request is overly
broad and unduly burdensome.
Idaho Power further objects to this Request on the grounds that the requested
material is or may be privileged and protected by the attorney-client privilege as well as
the attorney-work product doctrine.
Without waving the foregoing objections, Idaho Power provides additional
information below.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -3
Curtailments have been initiated under Schedule 72 for different reasons. In the
cases provided in the Company's response to Exergy's Request for Production No. 45,
Idaho Power implemented curtailments under Schedule 72 for two reasons. First, the
curtailments implemented on May 3, 2011; June 2, 2011; June 9, 2011; March 26,
2012; March, 28, 2012; April 1, 2012; and April 4, 2012, were due to Idaho Power being
unable to meet North American Electric Reliability Corporation (NERC) mandatory
reliability standards for balancing. The Company was unable to maintain sufficient
control room and its Area Control Error within required limits. Idaho Power reduced all
Company-owned generation to operational minimums during these events.
Second, during the curtailment events under Schedule 72 on April 6, 2012; April
8, 2012; April 11, 2012; and April 12, 2012, Idaho Power implemented the generation
output limit controls (GOLC) due to actual transmission overloads. In these events,
Idaho Power curtailed generation across the path pro rata, as required under Idaho
Power's Open Access Transmission Tariff (OATT). Idaho Power did not curtail
generation at facilities that were not impacting the overloaded transmission path.
Please see Idaho Power's confidential internal communications regarding these
events. The confidential communications will be provided to those parties that have
signed the Protective Agreement in this proceeding.
The response to this Request was prepared by Tessia Park, Director of Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -4
REQUEST FOR PRODUCTION NO. 54: Reference Idaho Power's Response to
Exergy Production Request No. 45, containing a list of curtailments implemented under
Schedule 72. During the time of each curtailment event, please provide the level of off-
system sales (in MWh). For each off-system sale, please provide:
(a)the Network Resource from which the Company made the sale;
(b)the estimated dispatch cost of the resource at the time of the sale;
(c)the quantity of the sale (in MWh); and
(d)the sale price ($/MWh) and location of the sale (e.g. Mid-C, etc.).
RESPONSE TO REQUEST FOR PRODUCTION NO. 54:
(a)-(d) Please see below for the information requested.
Date (a)NR (c)Quantity (d)Sale Price
Per Hour
5/31/11 HE2 OBPLR 75MW/h $4.501M345
HCPR 175 $4.00/1-AGRANDE
MNHM 25 $4.50/130RA
MDSK 50 $5.00/M345
6/2/11 HE2, 3, 4 MNHM 25 $3.50/130RA
MDSK 100 $3.50/M345
MDSK 50 $3.50/M345
6/9/11 HE4,5,6 MNHM 25 $3.50I130RA
MDSK 150 $3.50/M345
OBPLR 25 $4.00/13RDY
HE6 HCPR 90 $0.10/1-AGRANDE
3/26/12 HE2,3,4,5 OBPLR 25 $19.60/1-AGRANDE
OBPLR 25 $8.46/1-AGRANDE
MDSK 75 $19.801M345
OBPLR 25 $19.80/M345
OBPLR 100 $7.50/13RDY
MDSK 50 $11.00/M345
MDSK 50 $23.50/M345
MNHM 25 $11.00/M345
OBPLR 75 $19.50/1-AGRANDE
OBPLR 75 $19.25/1-AGRANDE
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -5
3/28/12 HE2 OBPLR *148 $6.00/BORA
OBPLR *36 $19.60/BORA
HCPR 125 $1.00/LAGRANDE
OBPLR *23 $19.25/BORA
HE3 OBPLR *200 $6.00/BORA
OBPLR 50 $19.60/BORA
OBPLR *16 $19.25/LAGRANDE
HE4 OBPLR *200 $6.00/BORA
OBPLR *16 $19.25/LAGRANDE
HE5 OBPLR *16 $19.25/LAGRANDE
OBPLR *200 $6.00/BORA
HE6 OBPLR *16 $19.25/LAGRANDE
OBPLR *200 $6.00/BORA
HE 2, 3, 4, 5, 6 OBPLR 25 $0.80/ LAG RANDE
HCPR 50 $10.00/M345
MDSK 50 $19.80/M345
MNHM 50 $19.80/M345
MDSK 50 $23.25/M345
MDSK 50 $20.00/M345
MDSK 25 $6.00/M345
4/1/12 HE3,4,5 HCPR 50 $3.00/LAGRANDE
MDSK 25 $2.40/BRDY
HCPR 125 $7.00/M345
HCPR 100 $2.80/LAGRANDE
OBPLR 50 $3.00/BORA
OBPLR 50 $6.00/BORA
MDSK 100 $10.00/M345
MNHM 32 $7.00/M345
HCPR 5 $1 .00/LAGRANDE
HE3 HCPR 93 $1.00/BRDY
HE4 HCPR 30 $1.00/BRDY
HE HCPR 47 $1.00/BRDY
4/4/12 HEI,2 MNHM 25 $11.00/BORA
HCPR 25 $3.00/BORA
MDSK 25 $6.15/BRDY
HCPR 30 $7.00/M345
HCPR 75 $2.80/M345
OBPLR 100 $11.00/M345
MDSK 50 $11.00/M345
OBPLR 50 $3.00/BORA
MDSK 100 $10.00/M345
HCPR 25 $3.00/LAGRANDE
MNHM 23 $11.00/M345
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -6
HE2 HCPR 42 $1.00/LAGRANDE
HCPR 25 $7.00/LAGRANDE
4/6/12 HE 12-19 HCPR 75 $20.00/LAGRANDE/M345
MDSK 25 $17.90/M345
HCPR 25 $20.00/LAGRANDE
HCPR 30 $7.00/M345
OBPLR 75 $2.80/M345
MDSK 50 $2.80/M345
OBPLR 25 $19.50/M345
MDSK 25 $19.50/M345
HCPR 50 $20.00/LAGRANDE
MDSK 75 $28.25/M345
MNHM 25 $19.50/M345
HEI2, 12, 14 HCPR 100 $3.00/LAGRANDE
4/8/12 HE 9, 10 OBPLR 25 $12.00/BORA
HCPR 50 $3.00/BORA
MDSK 25 $7.79/BRDY
HCPR 30 $5.00/M345
HCPR 100 $2.80/LAGRANDE
MNHM 25 $11.00/M345
MDSK 50 $11.00/M345
OBPLR 75 $11.00/M345
HCPR 100 $2.00/BRDY
OBPLR 50 $3.00/BORA
MDSK 100 $10.00/M345
MNHM 25 $12.00/M345
4/11/12 HEI6,17, 18 MDSK 25 $17.50/M345
HCPR 48 $6.00/ M345
MDSK 50 $17.50/M345
MNHM 25 $17.75/M345
OBPLR 25 $17.75/M345
OBPLR 100 $18.50M345
HCPR 100 $2.00/BRDY
MDSK 75 $28.25/M345
MNHM 23 $18.50/M345
4/12/12 HE 23 OBPLR 50 $3.00/BORA
MDSK 25 $0.00.BRDY
HCPR 30 $6.00/M345
HCPR 100 $2.80/LAGRANDE
HCPR 75 $7.00/M345
OBPLR 50 $3.00/BORA
MDSK 100 $10.00/M345
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -7
MNHM 34 $9.00/.M345
OBPLR 25 $3.00./LAGRANDE
HCPR 80 $2.00 /LAGRANDE
*During these hours, the original sales were curtailed for transmission constraints limiting the
total prescheduled sales, resulting in sinking additional energy into the balancing area beyond
Idaho Power's control.
OBPLR stands for Oxbow Brownlee power plant
HCPR stands for Hells Canyon power plant
MNHM stands for Mountain Home power plant
MDSK stands for Mid-Snake power plant
(b) As provided in Company witness Tessia Park's direct testimony, "there is
effectively no Incremental cost associated with running these resources. Thus, their
dispatch cost is very low." As the Network Resources used to supply the off-system
sales were sourced from Network Points of Receipt made up of primarily hydro facilities,
Idaho Power has not provided a dispatch cost.
(d) Idaho Power delivers physical energy to counterparties and not to a
specific market; thus, the data does not reflect which market but a Point of Delivery as
they have requested on Idaho Powers transmission system. The Network Resource
identifiers are available on Idaho Power's Open Access Same-Time Information System
(OASIS) site.
The response to this Request was prepared by Tessia Park, Director of Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -8
REQUEST FOR PRODUCTION NO. 55: Reference Idaho Power's Response to
Exergy Production Request No. 45, containing a list of curtailments implemented under
Schedule 72. The list of QFs appears to be missing some online wind QFs. Please
confirm the list is a complete and accurate list of QFs curtailed during each event, and
provide any corrections necessary.
RESPONSE TO REQUEST FOR PRODUCTION NO. 55: The list of Qualifying
Facilities ("QFs") curtailed in each instance depended on the type of curtailment that
was initiated. For all curtailments initiated prior to April 6, 2012, the list of QFs curtailed
is accurate and would have applied to all on-line wind QFs. For curtailments
implemented between April 6 and April 12, 2012, the list does not include all wind QFs
because the only QFs curtailed were those impacting the transmission path that was
overloaded at that time.
The response to this Request was prepared by Tessia Park, Director of Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -9
REQUEST FOR PRODUCTION NO. 56: Reference Idaho Power's Response to
Exergy Production Request Nos. 19 and 47. Please provide all studies or analyses
conducted by the Company to determine whether the Company could use its identified
run-of-river hydroelectric projects to spilt in order to maintain system reliability. Please
include all communications with FERC, fish and wildlife agencies, or other governmental
authorities supporting the assertion in Response No. 47: "If the amount of spill required
at these projects to maintain system reliability were to increase significantly above
historic levels, an amendment to the FERC licenses and/or state water quality
certifications would likely be required, including Endangered Species Act consultation in
some cases." If no such communication exists and this statement is supported by Idaho
Power's belief alone, please so state.
RESPONSE TO REQUEST FOR PRODUCTION NO. 56: The above-referenced
assertion in the Company's response to Exergy's Request for Production No. 47 is
supported by the licenses and license orders issued by the Federal Energy Regulatory
Commission ("FERC") and the water quality certifications issued by the State of Idaho
for each project. The following is taken from the August 4, 2004, FERC Mid-Snake
Consent Order (Idaho Power Company, 108 FERC 61,127 at p. 9) and is representative
of the types of operational restrictions with which the Company must comply in
operating these projects:
28. Under the consent order, Idaho Power must: (1)
monitor dissolved oxygen and temperature at each
project; (2) install equipment at the Upper Salmon Falls,
Lower Salmon Falls, and Bliss Projects to remove aquatic
vegetation from the intake structures; (3) maintain a
minimum flow of 50 cfs in the North Channel at Upper
Salmon Falls; and (4) operate the projects so as not to
increase water level fluctuations beyond those that
reflect the project's historic mode of operation ranges.29 [footnote omitted]
(Emphasis added.)
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -10
While the passage from the license order above does not specifically address
switching between generation and spill, doing so on a regular operational basis would
make it very difficult to comply with the license requirements that are contained in the
order.
The Company believes the following issues present significant hurdles in being
able to change how these projects are operated:
1.License Requirements. As stated in the Company's response to
Exergy's Request for Production No. 47, if the amount of spill required at these projects
to maintain system reliability were to increase significantly above historical levels, an
amendment to the FERC licenses and/or state water quality certifications would likely
be required, including Endangered Species Act ("ESA") consultation in some cases.
License amendments, changes in state water quality certification, and ESA consultation
would likely require detailed environmental studies and could take a significant amount
of time to complete.
2.Environmental Concerns. One of the largest risks of spilling, rather
than generating, is a change in water quality and water temperature. Spilled water
creates higher levels of dissolved gases, which poses risks to fish downstream, and
longer durations of spill further compounds the effect on aquatic resources. In addition,
water used for generation is drawn from lower, cooler levels of the reservoir, while water
that is spilled comes from higher, warmer levels of the reservoir. Therefore, spilled
water will likely increase downstream water temperatures, which will have a negative
impact on water quality.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -11
3. Impact to Customers. Because of their high-level of dependability
and typical flat operation, Idaho Power's run-of-river hydroelectric projects are
frequently used to source off-system sales, in compliance with FERC rules, during
periods where surplus energy can be sold in the market. Revenue from these surplus
sales benefits customers in the form of lower power supply expenses. Spilling water at
these projects in order to integrate variable resources would likely preclude such
opportunity sales from occurring and have a negative impact on customer rates.
Company witness Tessia Park, in her direct testimony, provides a discussion on the
effect of the FERC rules, including a description of the difficulties encountered in using
Public Utility Regulatory Policies Act of 1978 ("PURPA") network resources to source
off-system sales.
4. Better Alternatives. To accommodate PURPA energy, coal and
gas plants are dispatched down or off and the Hells Canyon Complex, which has more
flexibility than the run-of-river plants due to its reservoir system, is adjusted as much as
possible. Idaho Power utilizes these alternatives as much as possible to accommodate
PURPA energy without jeopardizing system reliability. Company witness Tessia Park
describes in her direct testimony how the dispatching down or off of thermal resources
must be judiciously managed to ensure capacity is available when needed.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -12
REQUEST FOR PRODUCTION NO. 57: Reference Idaho Power's Response to
Exergy Production Request No. 47(b). For each individual plant identified in Response
to Request 19, please provide an estimate of the duration of time from spill to full
operation (given available water flow). Please describe the steps that must be taken at
each individual plant to transition from spill to full operation (given available water flow).
Please note this request requires an itemized and unique response for each individual
plant, not a generic statement as provided in Response No. 47(b).
RESPONSE TO REQUEST FOR PRODUCTION NO. 57: Please see the
information provided below regarding individual plants.
Milner
Bypass Below Milner Dam
FERC Article 410
Year-Round Operations
- Maximum up ramp rate less than or equal to 300 cfs/15 min at bypass flows less than 5000
cfs
- Maximum up ramp rate less than or equal to 1200 cfs/hour at bypass flows greater than
5000 cfs
- Maximum down ramp rate less than or equal to 1200 cfs/hour between bypass flows of
3000 and 5000 cfs
*Note: Article 410 ramping limitation shall not apply during flow transfers for whitewater boating made in
accordance with Article 415, except down ramp is to be 1200 cfs/hour when flows are between 5000 and
3000 cfs
FERC Article 415
April 1 through June 30
- If flows are between 10,000 and 12,500 cfs (in excess of irrigation demand) and
whitewater flows are requested, releases are to be made through the Milner bypass reach
for recreational boating for up to 4 weekend days each year (including observed Memorial
Day holiday).
Units I and 2 below Milner Power Plant
FERC Article 410
Year-Round Operations
- Maximum up ramp rate less than or equal to 300 cfs/15 min when combinedflows are less
than 5000 cfs
• Maximum up ramp rate less than or equal to 1200 cfs/hour when combinedflows are
greater than 5000 cfs
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -13
Bypass Plus Milner Power Plant
Year-Round Operations
- Maximum up ramp rate less than or equal to 300 cfsI15 min when combinedflows are less
than 5000 cfs
- Maximum up ramp rate less than or equal to 1200 cfs/hour when combined flows are
greater than 5000 cfs
*Note special condition: Plant flow may be greater than 5000 cfs with the bypass still less than 5000 cfs
Milner Dam has five spill gates, two of which can be operated remotely. The
dam and spillway section are located approximately one mile upstream of the
powerhouse. A siren and flashing strobe will alarm for 60 seconds below the dam prior
to opening of any gates.
Due to the very tight restrictions on flow deviations at Milner, the plant is
equipped with two Free Discharge Valves ("FDV"), one for each main powerhouse
generator, which can be operated remotely. In order to pass water through the FDVs,
the generation dispatcher would activate the water control shutdown sequence and
programming at the plant would automatically calculate the amount of water being used
for generation, then open the FDV while simultaneously backing down the generation to
match flows. To reinstate generation, the generation dispatcher would increase
generator output while simultaneously closing the FDV.
Assuring accuracy and compliance with FERC mandated flow operations can
take anywhere from 30 minutes to over an hour on both spill and return to normal
operations. If this spill operation were to coincide with whitewater requirements (FERC
Article 410), or any other change in flow requirements, it would become difficult to not
violate FERC mandated ramp rates (FERC Article 410 and 415) due to the mile long
separation of the spill section of the dam and the location of the powerhouse. It is
important to note that whitewater requirements are most likely to occur during spring
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -14
runoff, which coincides with the times when wind generation re-dispatch is most likely.
It takes approximately 20 minutes for any changes to be registered at the river gauge
used for compliance due to its location downstream. Even after a change is made, the
generation dispatcher must monitor for a minimum of 30 minutes after any change.
Twin Falls
Twin Falls Dam (Normal Full Elevation 3511.4 ft-msl)
Year-Round Operations
- Maintain an instantaneous minimum headwater elevation of 3510.4 ft-msl when minimum
flows are not met
Snake River below Twin Falls Dam
FERC Article 410
April 1 through August 31 (viewing hours only 8 a.m. through 30 minutes past sunset)
- - Maintain minimum average flow of 300 cfs measured at the Outlet Works Valve
September 1 through March 31 (viewing hours only 8 a.m. through 30 minutes past sunset,
weekends and holidays only)
- Maintain minimum average flow of 300 cfs measured at the Outlet Works Valve
Year-Round Operations (specified viewing hours only)
- Maintain minimum instantaneous flow of 270 cfs measured at the Outlet Works Valve or
inflow, whichever is less.
Twin Falls consists of a flashboard spill section and contains no spill gates.
If generation were to be re-dispatched for a reduction event, the reservoir would
continue to fill until excess water spills over the flashboards and through the natural
waterfall. To reinstate generation, the generation dispatcher would increase the
generator output from the power plant. Re-dispatching or reinstating generation at the
Twin Falls power plant can be done in five minutes.
Water spilling over the flashboards in the past has hampered the effectiveness of
the flashboards themselves. Following times of spill over the flashboards, re-sealing is
a time consuming manual labor project. If enough water is allowed to go over the spill
section, the flashboards are engineered to fail, meaning they will collapse over,
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -15
reducing the overall reservoir elevation. Following these circumstances, it is a several-
day project to rebuild the flashboard section of the dam.
Shoshone Falls
Shoshone Falls Dam (Normal Maximum Elevation 3355 ft-msl)
FERC Article 401
Year-Round Operations
- Maintain an instantaneous minimum headwater elevation of 3353.5 ft-msl (2)
Snake River below Shoshone Falls Dam
FERC Article 402
April 1 through September. Labor Day weekend (viewing hours only sunrise through sunset)
- Maintain minimum average flow of 300 cfs and an instantaneous flow of 270 cfs calculated
as plant flow minus flow measured at Snake River below Shoshone Falls gauge.
Shoshone Falls has 18 spill gates, although it is engineered to allow water to spill
over sections of the dam without having to open spill gates until river flow exceeds
40,000 cubic feet per second ("cfs")
If generation were to be re-dispatched for a reduction event, the reservoir would
continue to fill until excess water spills over the spillway section and through the natural
waterfall. Shoshone Falls consists of three generators, including two that cannot be
operated remotely. During normal or high river flows, the generation dispatcher can
decrease or increase the generator output of the remotely controllable unit, which can
be done in five minutes. In instances of low river flow, the two generators that cannot
be remotely controlled may be the only generation on-line. Changing output of these
generators would require dispatching on-call personnel to the plant. In this
circumstance, it would take up to 60 minutes for on-call personnel to arrive at the plant
and another 15 minutes to re-dispatch generation from Shoshone Falls.
If river flows exceed 40,000 cfs, it is necessary to lift the spill gates to prevent
compromising the dam structure. Spill gates can only be controlled by field personnel
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -16
manually using a chain hoist to lift one of the eighteen gates at a time. If this were to
happen outside of normal operating hours, it would take up to 60 minutes for on-call
personnel to arrive and could take several more hours to lift all gates.
Upper Salmon Falls "B"
Upper Salmon Falls Dam (Normal Maximum Elevation 2878.2 ft-msl)
FERC Article 401
Year-Round Operations
- Maintain an instantaneous minimum headwater elevation of 2877.8 ft-msl as measured at
Owsley Bridge
North Channel Snake River at Upper Salmon Falls Dam
*Note: North Channel Snake River is used as a bypass reach for the upstream "B" plant
Doleman Rapids, an excavated channel, is used as the overflow section for the downstream
"A" plant
FERC Article 401
Year-Round Operations
- Maintain minimum average flow of 50 cfs and minimum instantaneous flow of 40 cfs
measured at
North Channel Snake River at Upper Salmon Falls Dam
Dolman Rapids at Upper Salmon Falls Dam
FERC Article 402
Year-Round Operations
- Maintain minimum average flow of 200 cfs and minimum instantaneous flow of 175 cfs
over the rapids
- Monitored by headwater elevation measured at the Dolman Rapids weir
- Target headwater elevations: 200 cfs = 2840.4 ft-msl and I 75cfs = 2839.8 ft-msl
Upper Salmon Falls "B" plant consists of two reject gates and six tainter gates.
The two reject gates are tied to a generator unit trip and are not used for spill. Two of
the six tainter gates can be operated remotely to compensate for a re-dispatch of
generation. A siren and flashing strobe will alarm for 60 seconds below the dam prior
to opening of any gates.
To compensate for the loss of generation during a re-dispatch event, the
generation dispatcher would need to calculate the appropriate tainter gate opening
correlating to the amount of water lost due to decreased generation and then open the
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -17
tainter gate to the determined set point while simultaneously decreasing generator
output. When reinstating generation, the dispatcher would need to increase generator
output while simultaneously closing the tainter gate. This process would take about 15
minutes.
There are considerable concerns when changing flows at Upper Salmon Falls
"B." Largest is the change in the way the water flows from the plant. When water is
spilled at Upper Salmon Falls "B," the flow from the spillway goes into the river channel
and not into the diversion canal as it does when generating. If the river bed is dry, it can
take a considerable amount of time to fill prior to flowing downstream. FERC Article 402
requires that Dolman Rapids must average 200 cfs and a minimum instantaneous value
of 175 cfs. Dolman Rapids is located directly downstream of Upper Salmon Falls "B"
and any fluctuation in water from the plant can negatively impact the flow over the
rapids. Upper Salmon Falls "A" is located downstream on a diversion canal fed from the
"B" plant. Any changes in flows from the "B" plant directly impact the "A" plant. Due to
the fact that Upper Salmon Falls "B" spills into the natural river channel and not directly
into the diversion canal as it does when generating, any deviation from generator use to
spill will have a direct impact on Upper Salmon Falls "A," Lower Salmon, and Bliss as
well, making it difficult to not violate FERC Article 403.
Upper Salmon Falls "A"
Upper Salmon Falls "A" is built on a diversion canal directly downstream of Upper
Salmon Falls "B." It contains an overflow apron that does not consist of any spill gates.
Any excess water will fill the canal and flow over the apron into the natural river channel.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -18
In a re-dispatch event, the generation dispatcher would lower generation by the
required amount, allowing the canal to fill to the point it would spill over the apron. To
reinstate the generation, the generation dispatcher would increase the output of the
generators. This process would take five minutes.
Lower Salmon Falls
FERC Article 401
Run-of-River Year
- Operate to minimum headwater boundary of 2797.0
Load-Following Year
- Operate to minimum headwater boundary of 2796.0
*Note: Project operation type will be determined March 31, and operating year consists of time
between April 1 and March 31.
Snake River below Lower Salmon Falls Reservoir
FERC Article 401
Run-of-River Year
- Maintain minimum instantaneous flow of 3500 cfs measured at Snake River below
- Lower Salmon Falls Dam
FERC Article 403
Run-of-River Year
- Maximum hourly ramp rate of 1 ft/hr measured at Snake River below Lower Salmon
Falls Dam
Load-Following Year
- Maintain minimum instantaneous flow of 3500 cfs measured at Snake River below
Lower Salmon Falls Dam
- Maximum hourly ramp rate of 2.5 ft/hr measured at Snake River below Lower Salmon
Falls Dam
- Maximum daily ramp rate of 5 ft/day measured at Snake River below Lower Salmon
Falls Dam
*Note: Project operation type will be determined March 31, and operating year consists of time
between April 1 and March 31.
Lower Salmon Falls has eight spill gates and an overflow flashboard section.
Two of the eight spill gates can be operated remotely. A siren and flashing strobe will
alarm for 60 seconds below the dam prior to opening of any gates.
To compensate for the loss of generation during a re-dispatch event, the
generation dispatcher would need to calculate the appropriate spill gate opening
correlating to the amount of water lost due to decreased generation and then open a
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -19
spill gate to the determined set point while simultaneously reducing generator output.
To reinstate generation, the generation dispatcher would need to increase generator
output while simultaneously lowering the spill gate. While the re-dispatch or
reinstatement of generation would take 15 minutes, the generation dispatcher must
verify that the FERC Article 403 mandated one foot per hour ramp rate is strictly
adhered to. This can take up to an additional 30 minutes following any change in flows
from Lower Salmon Falls.
Upper Malad
FERC Article 403
April 1 through April 30 and October 15 through November 30 (Maintenance Schedule)
- Upper Malad power plant is only available for planned maintenance outages for protection
of rainbow trout spawning and emergence
FERC Article 404
Ramp Rate
When ramping down for maintenance, the maximum hourly ramping rate is 300 cfs/hour.
Upper Malad has three tainter gates, none of which can be controlled remotely.
A siren and flashing strobe will alarm for 60 seconds below the dam prior to opening of
any gates.
Upper Malad generation is not controllable remotely. For a generation re-
dispatch event, the generation dispatcher would need to call out two site on-call
personnel. The dispatcher would need to communicate to the first on-site operator to
raise the spill gate from the spillway as the second on-site operator simultaneously
reduces generator output in the powerhouse. To reinstate generation, the dispatcher
would need to communicate to the first on-site personnel to lower the spill gate from the
spillway while the second operator increases the generator output in the powerhouse. It
would take up to 60 minutes for on-call personnel to arrive and an additional 30 minutes
to either re-dispatch or reinstate generation.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -20
As shown in FERC Article 403 and 404, there are considerable impacts to
rainbow trout spawning and emergence to take into consideration April 1 through April
30 and October 15 through November 30. Due to the absence of any remotely
operated generator and spill gates, it would be nearly impossible to achieve a
simultaneous change from generation to spill, making it difficult to not violate FERC
Article 403.
Lower Malad
Lower Malad Canal (Full Elevation 2876.6 ft-msl)
FERC Article 403
April 1 through April 30 (Maintenance Schedule)
- Lower Malad power plant is only available for planned maintenance outages for protection
of Rainbow Trout spawning and emergence.
FERC Article 404
Ramp Rate
- When ramping down for maintenance, the maximum hourly ramping rate is 300 cfs/hour.
Malad River below Lower Malad Canal Diversion
FERC Article 402
Year-Round Operations
- Maintain minimum instantaneous bypass flow of 90 cfs, and a daily minimum of 100 cfs
measured at Malad River near Bliss or inflow to the lower development reservoir whichever is
less
-The average daily minimum flow requirement may be reduced by up to 5 percent for no
more than one day (24-hour period) per event in order to allow the licensee the flexibility to
respond to changes in inflow
Lower Malad has three spill gates, none of which can be controlled remotely. A
siren and flashing strobe will alarm for 60 seconds below the dam prior to opening of
any gates.
For a generation re-dispatch event, the generation dispatcher would need to call
on-site on-call personnel. The dispatcher would need to communicate to the on-site
personnel to raise the spill gate as the dispatcher simultaneously reduces generator
output. To reinstate generation, the dispatcher would need to communicate to the on-
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -21
site personnel to lower the spill gate while the dispatcher increases the generator
output. It would take up to 60 minutes for on-call personnel to arrive and an additional
30 minutes to either re-dispatch or reinstate generation.
As shown in FERC Article 403, there are considerable impacts to rainbow trout
spawning and emergence to take into consideration April 1 through April 30. Due to the
absence of any remotely operated spill gates, it would be nearly impossible to achieve a
simultaneous change from generation to spill, making it difficult to not violate FERC
Article 403.
Bliss
Bliss Reservoir (Normal Maximum Elevation 2654 ft-msl)
FERC Article 403
Run-of-River Year
- Operate to minimum headwater boundary of 2652.5
Load-Following Year
- Operate to minimum headwater boundary of 2652
*Note: Project operation type will be determined March 31 and operating year consists of time between April 1
and March 31.
Snake River below Bliss Reservoir
FERC Article 401
Run-of-River Year
- Maintain minimum instantaneous flow of 4500 cfs measured at Snake River below Bliss Dam
(limit also serves to protect local irrigators)
FERC Article 403
Run-of-River Year
- Maximum hourly ramp rate of 1 ft/hr measured at Snake River below Bliss Dam
Load-Following Year
- Maintain minimum instantaneous flow of 4500 cfs measured at Snake River below Bliss Dam
- Maximum hourly ramp rate of 3 ft/hr measured at Snake River below Bliss Dam
- Maximum daily ramp rate of 6 ft/day measured at Snake River below Bliss Dam
*Note : Project operation type will be determined March 31 and operating year consists of time between April 1
and March 31.
Bliss has five spill gates, four of which can be operated remotely. A siren and
flashing strobe will alarm for 60 seconds below the dam prior to opening of any gates.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -22
To compensate for the loss of generation during a re-dispatch event, the
generation dispatcher would need to calculate the appropriate spill gate opening
correlating to the amount of water lost due to decreased generation and then open a
spill gate to the determined set point while simultaneously reducing generation. To
reinstate generation, the generation dispatcher would need to increase generation while
simultaneously lowering the spill gate. While the re-dispatch or reinstatement of
generation would take 10 minutes, the generation dispatcher must verify that the FERC
Article 403 mandated one foot per hour ramp rate is strictly adhered to. Any changes at
Bliss are not recorded for 30 minutes due to the downstream location of the river gauge
used for compliance. This means that additional monitoring and verification of
compliance can take up to an additional 60 minutes following any change in flows from
Bliss.
Swan Falls
Swan Falls Reservoir (Full Elevation 2314 ft-msl)
April 1 through October 31
- Operate to minimum headwater boundary of 2310.6 (limit set for irrigators)
FERC Exhibit A
Year-Round Operations
- Operate to minimum headwater boundaries of 2310
FERC Addition to Article 39
- Operations under Stream Flow Gauging Plan (in effect when minimum flows of 5000 cfs
cannot be maintained between April 1 and September 30 downstream due to lack of
available upstream water).
- Maximum daily headwater change less than 0.4 feet
Snake River below Swan Falls Dam
FERC Article 39
April 1 through September 30
- Minimum flow 5000 cfs measured at Snake River near Murphy
October 1 through March 31
- Minimum flow 4000 cfs measured at Snake River near Murphy
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -23
Year-Round Operations
- Maximum hourly ramp rate of 1 ft/hr measured at Snake River below Swan Falls (Idaho
Power maintained ramping gauge)
- Maximum daily ramp rate of 3 ft/day measured at Snake River below Swan Falls (Idaho
Power maintained ramping gauge)
Swan Falls has 12 spill gates, all of which can be operated remotely. A siren and
flashing strobe will alarm for 60 seconds below the dam prior to opening of any gates.
To compensate for the loss of generation during a re-dispatch event, the
generation dispatcher would need to calculate the appropriate spill gate opening
correlating to the amount of water lost due to decreased generation and then open a
spill gate to the determined set point while simultaneously reducing generator output.
To reinstate generation, the generation dispatcher would need to increase generator
output while simultaneously lowering the spill gate. While the re-dispatch or
reinstatement of generation would take 15 minutes, the generation dispatcher must
verify that the FERC Article 39 mandated one foot per hour ramp rate is strictly adhered
to. This can take up to an additional 30 minutes following any change in flows from
Swan Falls. Also necessary to take into consideration at Swan Falls is the FERC Article
39 mandated Gauging Plan when minimum flows of 5,000 cfs cannot be maintained
(between April 1 and September 30). If a generation re-dispatch event were to include
Swan Falls, it would become extremely difficult to not violate FERC Article 39 due to the
wave action resulting from changing the physical location the reservoir water is drawn
from.
The response to this Request was prepared by Tessia Park, Director of Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -24
REQUEST FOR PRODUCTION NO. 58: Other than curtailment, please
document all other efforts Idaho Power is/has considered or analyzed to address
periods of oversupply. For example, has the Company considered load shifting,
resistive load, or rate design to encourage customers to shift load? Please provide all
documents supporting the response.
RESPONSE TO REQUEST FOR PRODUCTION NO. 58: In the early 1990s,
Idaho Power utilized long-term contracts to supply firm energy to off-system customers.
Long-term contracts were contracts with durations greater than one year and included
sales to Colton, California, Washington City, and Utah Associated Municipal Power
Systems ("UAMPS"). However, after 1995 off-system loads began to decline through
2004. The off-system contracts and their corresponding energy requirements expired
as the Company's projection of surplus energy diminished due to retail load growth.
During the past decade, the emphasis of the Company's Integrated Resource
Planning process has not been focused on periods of oversupply but rather on meeting
the Company's summer peak capacity requirements. Nevertheless, on a seasonal
basis, the Company does experience periods when more generation is available than
needed in order to meet retail load. During those times, when it is economically
feasible, the Company will make surplus sales transactions, which provides a benefit to
the Company's retail customers as a revenue off-set to the Company's net power
supply expenses.
From the supply-side perspective, Idaho Power operates its fleet of hydro and
thermal generators to minimize aggregate production during periods of oversupply.
These actions to reduce production at Company-owned generators are taken for the
purpose of maintaining system reliability and to reserve resources for periods of greater
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -25
need. The extent to which production from Company-owned generators can be
reduced is limited by a variety of factors. For example, management of the Hells
Canyon Complex needs to account for flood control requirements, dissolved gas levels,
and minimum flow and ramping rate restrictions. Thermal generators need to be
managed to ensure their capacity is available if needed for periodically recurring heavy
load periods.
On the demand-side perspective, in addition to the Company's peak reduction
programs which encourage customers to curtail their load (A/C Cool Credit for
residential customers, Irrigation Peak Rewards for agricultural customers, and FlexPeak
Management for commercial and industrial customers), the Company has implemented
time variant pricing strategies to encourage customers to shift their daily and seasonal
usage in response to price signals. Currently, the Company's Schedule 9, Large
General Service, customers and Schedule 19, Large Power Service, customers have a
time-of-day pricing structure with on-peak, mid-peak, and off-peak usage blocks, which
use pricing as a signal to encourage customers to shift their on-peak usage to the lower
cost mid-peak and off-peak periods. Recently, the Company has begun an expansion
of its Schedule 5, Residential Service Time-of-Day Pilot Plan, which uses a peak and
off-peak pricing structure to encourage residential customers to shift their energy
consumption to off-peak periods when the supply of energy is lower cost and more
readily available.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, and Michael Youngblood, Regulatory
Projects Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -26
DATED at Boise, Idaho, this 5th day of June 2012.
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -27
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 5th day of June 2012 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Donald L. Howell, II
Kristine A. Sasser
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
P.O. Box 3727
Spokane, Washington 99220-3727
PacifiCorp dibla Rocky Mountain Power
Daniel E. Solander
PacifiCorp d/b/a Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Exergy Development, Grand View Solar II,
J.R. Simplot, Northwest and Intermountain
Power Producers Coalition, Board of
Commissioners of Adams County, Idaho,
and Clearwater Paper Corporation
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
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IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -28
Exergy Development Group of Idaho, LLC
James Carkulis, Managing Member
Exergy Development Group of Idaho, LLC
802 West Bannock Street, Suite 1200
Boise, Idaho 83702
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Dr. Don Reading Hand Delivered
Ben Johnson Associates, Inc. U.S. Mail
6070 Hill Road Overnight Mail
Boise, Idaho 83703 FAX
X Email drbeniohnsonassociates.com
Grand View Solar II
Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Springs, California 92241
JR. Simplot Company
Don Sturtevant, Energy Director
J.R. Simplot Company
One Capital Center
999 Main Street
P.O. Box 27
Boise, Idaho 83707-0027
Northwest and Intermountain Power
Producers Coalition
Robert D. Kahn, Executive Director
Northwest and Intermountain Power
Producers Coalition
1117 Minor Avenue, Suite 300
Seattle, Washington 98101
Board of Commissioners of Adams
County, Idaho
Bill Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
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IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -29
Clearwater Paper Corporation
Mary Lewallen
Clearwater Paper Corporation
601 West Riverside Avenue, Suite 1100
Spokane, Washington 99201
Renewable Energy Coalition and Dynamis
Energy, LLC
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Renewable Energy Coalition
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 150
Eagle, Idaho 83616
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Bill Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Renewable Northwest Project, Idaho
Windfarms, LLC, and Ridgeline Energy LLC
Dean J. Miller
Chas. F. McDevitt
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, Idaho 83701
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IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -30
Megan Walseth Decker
Senior Staff Counsel
Renewable Northwest Project
421 SW 6th Avenue, Suite 1125
Portland, Oregon 97204
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Twin Falls Canal Company and North Side
Canal Company
C. Thomas Arkoosh
CAPITOL LAW GROUP, PLLC
205 North I 0th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
ELECTRONIC SERVICE ONLY
Lori Thomas
CAPITOL LAW GROUP, PLLC
205 North 10th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
ELECTRONIC SERVICE ONLY
Donald W. Schoenbeck
RCS, Inc.
900 Washington Street, Suite 780
Vancouver, Washington 98660
ELECTRONIC SERVICE ONLY
Twin Falls Canal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
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IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -31
ELECTRONIC SERViCE ONLY
North Side Canal Company
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11th East
Idaho Falls, Idaho 83404
Blue Ribbon Energy LLC
M.J. Humphries
Blue Ribbon Energy LLC
3470 Rich Lane
Ammon, Idaho 83406-7728
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
Snake River Alliance
Liz Woodruff, Executive Director
Ken Miller, Clean Energy Program Director
Snake River Alliance
350 North 9th Street #13610
P.O. Box 1731
Boise, Idaho 83701
Energy Integrity Project
Tauna Christensen
Energy Integrity Project
769 North 1100 East
Shelley, Idaho 83274
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IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -32
Idaho Wind Partners I, LLC
Deborah E. Nelson
Kelsey J. Nunez
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
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Christa Bearry,
th
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IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -33
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY
RESPONSE TO EXERGY'S
REQUEST FOR PRODUCTION NO. 53
THIS ATTACHMENT IS
CONFIDENTIAL
AND WILL BE PROVIDED
TO THOSE PARTIES THAT
HAVE SIGNED THE
PROTECTIVE
AGREEMENT