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Home My WebLink About20120706Exergy 59-67 to IPC.pdfRECEIVED 2012JUL6PM3 24 iu • ATTO R NEYS AT LAW JAri JT(LiTES CO.MM1SSIOk Tel: 208-938-7900 Fax 208-938-7904 P.O.Box 7218 Boise ID 83707 - 515 N 27th St Boise ID 83702 July 6, 2012 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702 RE GNR-E-11-03 - SIXTH PRODUCTION REQUEST OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY Dear Ms Jewell Enclosed please find the prepared sixth production request of Exergy Development Group of Idaho to Idaho Power Company, submitted for filing in the above-referenced docket on behalf of Clearwater Paper Corporation, J R Simplot Company, and Exergy Development Group of Idaho, LLC. Per the Commission's Rules of Procedure, we have enclosed and original and three (3) copies Sincerely, Chynna C. Tipton Richardson & O'Leary PLLC end. Peter J Richardson ISB # 3195 Gregory M. Adams ISB # 7454 Richardson & O'Leary, PLLC 515N 21' Street P.O.Box 7218 Boise, Idaho 83702 Telephone (208) 938-7901 Fax (208) 938-7904 peter@Lnchardsonandolega.co greg@,dchardsonandoleM.co Attorneys for Exergy Development Group of Idaho, LLC BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE COMMISSION'S ) REVIEW OF PURPA QF CONTRACT ) CASE NO. GNR-E-1 1-03 PROVISIONS INCLUDING THE ) SURROGATE AVOIDED RESOURCE SIXTH PRODUCTION REQUEST OF PLANNING (IRP) METHODOLOGIES FOR EXERGY DEVELOPMENT GROUP CALCULATING PUBLISHED AVOIDED ) OF IDAHO TO IDAHO POWER COST RATES COMPANY Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission"), Exergy Development Group of Idaho, LLC hereby requests that Idaho Power Company ("Idaho Power" or "Company") provide responses to the following with supporting documents, where applicable, as soon as possible 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 Please provide one physical copy of your responses to the address above, and electronic copies, if available, to Mr. Richardson and Mr. Adams at the addresses noted above, and one copy to Dr. Reading at 6070 Hill Road, Boise, Idaho 83703. Please provide Dr. Reading's copy in electronic format, if available, to dreadingmindspring.com . 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. 59: At page 13 of her rebuttal testimony, Ms. Parks states, "As a result of the large amount of PURPA requests on Idaho Power's system, the Company has to complete interconnection and transmission system upgrades that it otherwise would not need to serve load." Please identify all network transmission system upgrades paid for, in full or in part, by PURPA QFs on Idaho Power's transmission system. Please provide maps and studies and all work papers and supporting documents used preparing your response. REQUEST FOR PRODUCTION NO. 60: Ms. Parks then states on page 13 of her rebuttal testimony, in reference to the PURPA caused transmission system upgrades, "Because these system upgrades do not serve any other purpose or need required to provide serve to Idaho Power's customers, it would be not be appropriate to require customers to pay for interconnection and transmission system upgrades that are not needed to serve load." (a)Please provide all work papers and supporting documents relied upon by Ms. Parks supporting the assertion that "these system upgrades do not serve any other purpose." (b)Does Idaho Power grant QFs paying for such upgrades the exclusive use for such facilities? REQUEST FOR PRODUCTION NO. 61: At page 6 of Mr. Stokes' rebuttal testimony he states: "historically there has been a significant difference between the prices paid to QF resources on Idaho Power's system and the Mid-C market index." Please explain the relationship, as Mr. Stokes' understands it, between the Mid-C market index and avoided cost rates. Please explain whether Idaho Power can secure a twenty- year strip of electricity at Idaho Power's forecasted Mid-C market price index. Page 2— SIXTH PRODUCTION REQUEST OF EXERGY TO IDAHO POWER - GNR-E-1 1-03 REQUEST FOR PRODUCTION NO. 62: Please identify the estimated levelized cost approved by the Commission when it issued the order for approval/construction of each resource Idaho Power has built and placed into ratebase since PURPA was first adopted. REQUEST FOR PRODUCTION NO. 63: Please reference Mr. Stokes' rebuttal testimony page 19 beginning on line 20 through page 20 end line 29 Mr. Stokes. Please specifically identify what it is in Staff witness Sterling's direct testimony that is being rebutted in this passage. REQUEST FOR PRODUCTION NO. 64: At page 23 of his rebuttal testimony, Mr. Stokes states that "if the capital and fixed costs of an SCCT were used to determine the capacity portion of the avoided cost rate. The energy component would still require using the heat rate and other variable operations and maintenance assumptions appropratiate for a CCCT." What is the source of the 'requirement' that a CCCT heat rate be used when the SAR is a SCCT. REQUEST FOR PRODUCTION NO. 65: At page 39 of his rebuttal testimony, Mr. Stokes makes reference to the IRP Advisory Council. Please provide all documents relating to the selection of the current IRP Advisory Council. Are the council members provided with independent, technical staff? REQUEST FOR PRODUCTION NO. 66: On page 46 of his rebuttal testimony Mr. Stokes states that "The Commission has specifically found this [liquidated damages] requirement to be in the public interest and a just and reasonable requirement of the contracting process." Please provide copies of, or citations to, where the Commission "specifically" made those findings. REQUEST FOR PRODUCTION NO. 67: At page 47 of his rebuttal testimony Mr. Stokes, speaking of liquidated damages states that, "In addition to the system operation and planning problems that failure to bring generation units on- line in a timely manner and when they are scheduled to come on line, there is the substantial value that the QF gets by locking in a price, and a pricing stream with a contract." Please quantify and specify each system operation and planning problem Mr. Stokes is referring to and please specify and quantify the damage incurred by Idaho Power when a QF locks in a price. Page 3— SIXTH PRODUCTION REQUEST OF EXERGY TO IDAHO POWER— GNR-E-11-03 DATED: July 6, 2012 Peter J. Richardso Gregory M. Adams RICHARDSON & O'LEARY PLLC Page 4— SIXTH PRODUCTION REQUEST OF EXERGY TO IDAHO POWER— GNR-E-1l-03 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 6th day of July, 2012, a true and correct copy of the within and foregoing SIXTH PRODUCTION REQUEST OF EXERGY DEVELOPMENT GRUP OF IDAHO TO IDAHO POWER COMPANY ON BEHALF OF EXERGY DEVELOPMENT GROUP OF IDAHO, LLC, J. R. SIMPLOT COMPANY AND CLEARWATER PAPER CORPORATION was served as shown to: Jean D Jewell, Secretary X Hand Delivery Idaho Public Utilities Commission U S Mail, postage pre-paid 472 West Washington - Facsimile Boise, Idaho 83702 - Electronic Mail jean.jewell@guc.idaho.gov Donald Howell X Hand Delivery Kris Sasser _U S Mail, postage pre-paid Idaho Public Utilities Commission - Facsimile 472 West Washington - Electronic Mail Boise, Idaho 83702 donald.howell@puc.idaho.gov krisine.sasser@,puc.idaho.gov Donovan E Walker - Hand Delivery Jason B Williams —U .S. Mail, postage pre-paid Idaho Power Company - Facsimile P0 Box 70 X Electronic Mail Boise, ID 83707-0070 dwalker@idahopower.com jwilliams @idahopower.com Michael G Andrea - Hand Delivery Avista Corporation _U.S. Mail, postage pre-paid P.0. Box 3727 - Facsimile Spokane, WA 99220 X Electronic Mail michael.andrea@avistacoEp.com Daniel Solander - Hand Delivery PacifiCorp/dba Rocky Mountain Power —U .S. Mail, postage pre-paid 201 5 Main St Ste 2300 - Facsimile Salt Lake City, UT 84111 X Electronic Mail dame! so1ander(i)yacificorp corn Dean J Miller - Hand Delivery McDevitt & Miller, LLP _U S Mail, postage pre-paid 420 W Bannock St Facsimile Boise, ID 83702 X Electronic Mail oemcdevitt-mi11er.com Tauna Christensen Energy Integrity Project - Hand Delivery 769 N 1100 E _U.S. Mail, postage pre-paid Shelley ID 83274 Facsimile taunaenergyintegrityproject.org X Electronic Mail John R. Lowe - Hand Delivery Consultant _U.S. Mail, postage pre-paid Renewable Energy Coalition - Facsimile 12050 SW Tremont St X Electronic Mail Portland, OR 97225 jravenesanmarcos@yahoo.com R. Greg Femey Hand Delivery Mimura Law Offices PLLC _U.S. Mail, postage pre-paid Interconnect Solar Development, LLC - Facsimile 2176 E Franklin Rd Ste 120 X Electronic Mail Meridian, ID 83642 greg@jmimuralaw.com Bill Piske, Manager - Hand Delivery Interconnect Solar Development, LLC _U.S. Mail, postage pre-paid 1303 E. Carter - Facsimile Boise, ID 83706 X Electronic Mail billpiske@cableone.net Ronald L. Williams - Hand Delivery Williams Bradbury, PC _U.S. Mail, postage pre-paid 1015 W. Hays Street - Facsimile Boise, ID 83702 X Electronic Mail ron@williamsbradburv.com Wade Thomas - Hand Delivery General Counsel _U.S. Mail, postage pre-paid Dynamis Energy, LLC - Facsimile 776 W. Riverside Dr., Ste 15 X Electronic Mail Eagle, ID 83616 wthomas@dynamisenergv.com C Thomas Arkoosh - Hand Delivery Capitol Law Group PLLC _U.S. Mail, postage pre-paid 205 N 10th St 4th Floor Facsimile P0 Box 2598 X Electronic Mail Boise ID 83701 CERTIFICATE OF SERVICE GNR-E-1 1-03 tarkooshcanito1lawnrouD.com - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail Hand Delivery —U .S. Mail, postage pre-paid Facsimile X Electronic Mail - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail Brian Olmstead General Manager Twin Falls Canal Company P0 Box 326 Twin Falls, ID 83303 o1msteadffcanal.com Robert A. Paul Grand View Solar II 15690 Vista Circle Desert Hot Springs, CA 92241 robertaDaul08(mail.com James Carkulis Exergy Development Group of Idaho, LLC 802 W. Bannock, Ste 1200 Boise, ID 83702 jcarkulisexergydevelopment.com Arron F. Jepson Blue Ribbon Energy, LLC 10660 South 540 East Sandy, UT 84070 arronesgaol.com M.J. Humphries Blue Ribbon Energy, LLC 4515 S. Ammon Rd. Ammon, ID 83406 blueribbonenerv(gmail.com Ted Diehl General Manager North Side Canal Company 921 N. Lincoln St. Jerome, ID 83338 nscanal@cableone.net Bill Brown Adams County Board of Commissioners P0 Box 48 Council, IT 83612 bdbrownfrontiernet.net CERTIFICATE OF SERVICE GNR-E-1 1-03 Ted S. Sorenson, PE - Hand Delivery Birch Poer Company _U.S. Mail, postage pre-paid 5203 South 11th East - Facsimile Idaho Falls, ID 83404 X Electronic Mail ted@tsorenson.net Glenn Ikemoto - Hand Delivery Margaret Rueger _U.S. Mail, postage pre-paid Idaho Windfarms, LLC - Facsimile 6762 Blair Avenue X Electronic Mail Piedmont, CA 94611 glenni(àenvisionwind.com margaret@envisionwind.com Megan Walseth Decker - Hand Delivery Senior Staff Counsel —U .S. Mail, postage pre-paid Renewable Northwest Project - Facsimile 917 SW Oak Street Ste 303 X Electronic Mail Portland, OR 97205 megan(rnp.org Benjamin J Otto - Hand Delivery Idaho Conservation League _U S Mail, postage pre-paid 710 N. Sixth Street (83702) - Facsimile P0 Box 844 X Electronic Mail Boise, ID 83701 botto@idahoconservation org Ken Miller - Hand Delivery Liz Woodruff _U.S. Mail, postage pre-paid Snake River Alliance - Facsimile P0 Box 1731 X Electronic Mail Boise, ID 83701 kmiller@snakeriveralliance.org 1woodruff(snakeriveral1iance.org Robert D. Kahn - Hand Delivery Executive Director _U.S. Mail, postage pre-paid Northwest & Intermountain Power Producers - Facsimile Coalition X Electronic Mail 1117 Minor Ave., Ste 300 Seattle, WA 98101 rkahnnippc.org CERTIFICATE OF SERVICE GNR-E-1 1-03 Don Sturtevant Energy Director J.R. Simplot Company P0 Box 27 Boise, ID 83707-0027 don.sturtevant(simp1ot.com Mary Lewallen Clearwater Paper Corporation 601 W Riverside Ave Ste 1100 Spokane WA 99201 marv.lewallen(clearwaterpaper.com Don Schoenbeck RCS 900 Washington St., Suite 780 Vancouver, WA 98660 dws2ir-c-s-inc.com Lori Thomas Capital Law Group, PLLC P0 Box 2598 Boise, ID 83701-2598 lthomascapita1lawgrou.com Deborah E. Nelson Kelsey J. Nunez Givens Pursley LLP 601 W. Bannock Street Boise, ID 83702 den(givenspursley.com kjngivensvurs1ev.com - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail - Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail Chynna C. Tipton CERTIFICATE OF SERVICE GNR-E-1 1-03