20170607Simplot 1-15 to IPC.pdf

Peter J. Richardson (ISB No. 3195)
Richardson Adams, PLLC
515 N. 27s Street
P.O. Box 7218
Boise,Idatro 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attorneys for J. R. Simplot Company
IN THE MATTER OF THE ANNUAL
I.IPDATE TO PUBLISHED AVOIDED
COST RATES TO REFLECT AN
UPDATED NATURAL GAS PRICE
FORECAST OF THE U.S. ENERGY
INFORMATION ADMINISTRATION
(ErA)
BEFORE THE
IDAHO PUBLIC UTILTTIES COMMISSION
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CASE NO. GNR.E-L7-02
FIRST PRODUCTION
J. R. SIMPLOT COMP
IDAHO POWER
Pi'l -1: l:8
REQUEST OF
ANY TO
Pursuant to Rule 225 of the Rules of Procedure of the tdaho Public Utilities Commission
(the "Commission"), J. R. Simplot Company by and through its attorney of record, Peter J.
Richardson, hereby requests that Idaho Power Company ("Company") provide the following
documents.
This production request is to be considered as continuing, and the Company 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 documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional copy to Dr. Reading at
[e-mail].
For each item, please indicate the name of the person(s) preparing the answers, along
Simplot First Production Request to ldaho Power - GNR-E- l 7-02 1
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
If some of the following requests include disclosures deemed by Idaho Power to be
confidential, the J. R. Simplot Company is prepared to enter into an appropriate confidentiality
agreement.
REOUEST FOR PRODUCTION NO. I
Please provide copies of all correspondence between Idaho Power and the staffor
commissioners of the Idaho PUC regarding the appropriate natural gas forecast to be used in
setting ldaho Power's avoided cost rates over the course of the last twelve months. Include
copies of both formal wriffen correspondence as well as informal and electronic
communications.
REOUEST FOR PRODUCTION NO. 2
At page 2 of the Company's "Response and Objection of Idaho Power Company"l dated
May 24,2017, the Company states:
[F]or avoided cost rates based upon the Incremental Cost IRP ("ICIRP") methodology,
Idaho Power utilizes EIA's Annual Energy Outlook from a different EIA subset: the
Henry Hub: High Oil and Gas Resource and Technology (nom $/MMBtu) forecast,
adjusted for pricing at Sumas and Idaho City Gate.
Please provide a list of all PURPA contracts filed with the ldaho PUC that utilize avoided cost
rates calculated pursuant to the referenced forecast.
REOUEST FOR PRODUCTION NO.3
Please provide all avoided cost calculations prepared for PURPA contracts that have not
been filed with the Idaho PUC that use the forecast referenced in Request No. 2. For each
calculation please provide a copy of the QF's Application to Idaho Power (and all other
I Hereinafter referred to as the "Company's Filing."
Simplot First Production Request to ldaho Power GNR-E- l 7-01 z
correspondence to and from ldaho Power) associated with each PURPA project for which ldaho
Power has utilized the forecast methodology referenced in Request No. 2.
REOUEST FOR PRODUCTION NO. 4
Please provide a copy of all ldaho PUC orders, correspondence or other communication
upon which Idaho Power relies as authority to use the forecast for calculating avoided cost rates
in the ICIRP Methodology referenced in Request No. 2.
REOUEST FOR PRODUCTION NO.5
At page 3 of the Company's Filing, Idaho Power states that, "[n accordance with
Commission Orders, the ICIRP methodology used for larger projects subject to negotiated rates
and contracts, utilizes the natural gas price forecast that Idaho Power uses in its IRP process."
Please provide a list of the referenced Commission Orders, with specific page references, that
provide that the *ICIP.P methodology . . . utilizes the natural gas price forecast that Idaho Power
uses in its IRP process."
REOUEST FOR PRODUCTION NO 6
Please explain, and document, whether either the Oregon PUC or the ldaho PUC has ever
specifically approved the use of any specific natural gas forecast for use in the Company's IRP
filings. Please cite to specific orders and page references to support your answer, and reproduce
a quotation of the statement in the order that supports the answer.
REOUEST FOR PRODUCTION NO. 7
Page 3 of ldaho Power's Filing provides that "the Mountain Region forecast is not a
representative forecast . . . as it represents pricing in a higher priced supply basin than where
Idaho Power holds firm pipeline capacity and performs natural gas transactions." Please identify
the "higher priced supply basin" referenced above. Please identify the supply basin in which
Simplot First Production Request to ldaho Power GNR-E- l 7-01 3
Idaho Power "holds firm pipeline capacity and performs natural gas transactions."
REOUEST FOR PRODUCTION NO. 8
Please provide the "actual natural gas trading prices from the Intercontinental Exchange
("lCE") referred to on page 3 of tdaho Power's Filing. Please provide actual natural gas trading
prices from the ICE for the most recent four-year period available.
REOUEST OF PRODUCTION NO. 9
On pages 3 to 4, the [daho Power Filing references an "analysis" that "compared the
reference case forecast with actual future trading prices from ICE."
a. Please provide a copy of said analysis along with all supporting workpapers.
b. Identify the author of the analysis, the qualifications of the author, the employer
of the author, and the reason the analysis was undertaken.
c. Please explain why this analysis was not performed in support of the prior three
IRPs.
REOUEST FOR PRODUCTION NO. TO
Please provide an electronic copy of the graph that appears on page 4 of [daho Power's
filing with all formulae intact. Please provide all documents and workpapers used to produce
said graph.
REOUEST FOR PRODUCTION NO. 11
Please explain, and document, the impact of the use of Idaho Power's proposed natural
gas forecast will have on the determination of cost-effective conservation, demand-side
management and energy efficiency programs.
REOUEST FOR PRODUCTION NO. T2
Please provide a copy of all tCE price forecasts in the company's possession for the past
Simplot First Production Request to ldaho Power GNR-E-17-01 4
four years.
REOUEST FOR PRODUCTION NO. T3
Reference ldaho Power's filing at p. 4, asserting that the Company's proposed use of the
High Oil and Gas Resource and Technology "tracks much closer to actual future trading prices
from ICE." Please provide the actual future trading prices, including as separately itemized
information: (a) dates of delivery, (b) volume of gas traded per delivery date.
REOUEST FOR PRODUCTION NO. 14
Reference Idaho Power's filing at page 4, asserting that the Company "adjusts the Henry
Hub price to geographically deliver the natural gas to its service territory." Reference also the
filing at page 5 note 3, describing the proposed method of calculating the delivery charges.
a. Please explain if Idaho Power currently fuels any plants with natural gas
purchased and delivered from Henry Hub. Identify all such plants and specifu the proportion of
natural gas served from Henry Hub and the number of years into the future the Company plans to
continue to do so.
b. Please explain if ldaho Power holds capacity on the gas delivery system to deliver
natural gas from Henry Hub for (i) all of its existing natural gas generation, and (ii) its next
planned natural gas generator identified in the most recent tRP. If not, please explain why it is
reasonable to assume that the existing tariff rates escalated at the rate proposed by Idaho Power
in its filing is reasonable without incurring costs to expand existing pipeline capacity.
R-EOUEST FOR PRODUCTION NO. 15
Reference Idaho Power's filing at page 6-7 discussing replacement ESAs that have been
requested and Idaho Power expects to be requested. Please identify all of the referenced projects
that have or are expected to request a replacement ESA, including:
Simplot First Production Request to [daho Power CNR-E-17-01 5
a.
b.
c.
d.
e.
ESA;
f.
this docket.
oE'
and telephone.
prolect narne, resource type;
interconnected utility;
operation date of current ESA;
expiration date of current ESA;
basis for Idaho Power's expectation that the project will request a replacement
whether Idaho Power has alerted the project regarding Idaho Power's request in
last known contact information for the project, including email, physical address,
DATED this 7th day of June 2017.
Richardson Adams, PLLC
By
Peter J. Richardson Attomey for
J. R. Simplot Company
Simplot First Production Request to ldaho Power GNR-E-I7-01 6
a
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of June,2Ol7,a true and conect copy of the
within and foregoing FIRST PRODUCTION REQUEST OF THE J. R. SIMPLOT COMPANY
TO IDAHO POWER COMPANY, in Docket No. GNR-E-17-02 was served VIA
ELECTRONIC MAIL and UNITED STATES MAIL, postage prepaid. to the following:
Commission Secretary
Idatro Public Utilities Commission
P O Box 83720
Boise ID 83720-0074
secetae,@puc. idaho. gov
Michael Andrea
Avista Corporation
l4l I East Mission St.
Spokane, WA99220-3727
Michael.andrea@avistacorp. com
Cline Kalich
Avista Utilities
l4l I East Mission St.
Spokane, WA99220-3727
C I int. kal ich@avistacorp. com
Daniel MacNeil
PacifiCorp
825 NE Multnomatr St.
Portland, Oregon 97232
Daniel.macneil@ pacifi com. com
Donovan E. Walker
Idaho Power Cornpany
l22l West ldaho Street
Boise, Idaho 83702
dwalker@idahopower. com
dockets@idahopower. com
Daphne Huang
Camille Christen
Idaho Public Utilities Commission
472 W est Washington Street
Boise, Idaho 83702
Daphne.haung@puc. idaho. gov
Camille. christen@puc. idaho. eov
Yvonne Hogle
Ted Weston
Rocky Mountain Power
1407 West North Temple, Ste. 330
Salt Lake City, Utah 84116
Yvonne.ho ele@pacifi corp.com
Ted. we ston @pac i fic orp. co m
Kandi Walters
Simplot First Production Request to ldaho Power GNR-E-I7-01 7