20170628IPC to Simplot 1-15.pdf

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DONOVAN E. WALKER
Lead Counsel
[e-mail]
June 28,2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington
Boise, ldaho 83702
Re Case No. GNR-E-17-02
Review of Surrogate Avoided Resource (SAR) Methodology - ldaho
Power Company's Response to the First Production Request of J. R.
Simplot Company
Dear Ms. Hanian:
Enclosed for filing in the above matter please find an original and three (3) copies
of Idaho Power Company's Response to the First Production Request of J. R. Simplot
Company.
Also enclosed are four (4) copies of a non-confidential disk containing
information responsive to J. R. Simplot Company's production requests.
Very yours,
Donovan E. Walker
DEW:csb
Enclosures
1221 W. rdaho st. (83702)
PO. Box 70
Boise, lD 83707
sI l{.i;'r
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
l;1LiL,illV[:U
'. , ':Z$ Pii h:l+Z
,i!1. . *1 ,.,, r ' i't i;''i] |: ,, J !..1 ',.'1 1
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
REVIEW THE SURROGATE AVOIDED
RESOURCE (SAR) METHODOLOGY
FOR CALCULATING PUBLISHED
AVOIDED COST RATES
CASE NO. GNR.E-17.02
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
J. R. SIMPLOT COMPANY
)
)
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)
)
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COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?[y"), and in
response to the First Production Request of J. R. Simplot Company to ldaho Power
dated June 7,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 1
REQUEST FOR PRODUCTION NO. 1:Please provide copies of all
correspondence between Idaho Power and the staff or commissioners of the ldaho 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. lnclude copies of both
formal written correspondence as well as informal and electronic communications.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the PDF
provided on the enclosed CD.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 2
REQUEST FOR PRODUCTION NO. 2: At page 2 of the Company's "Response
and Objection of ldaho Power Company"l dated May 24,2017, the Company states
[F]or avoided cost rates based upon the lncremental Cost
IRP ("!CIRP') methodology, ldaho 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
ldaho City Gate.
Please provide a list of a!! PURPA contracts filed with the ldaho PUC that utilize avoided
cost rates calculated pursuant to the referenced forecast.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2:ln its 2015 lntegrated
Resource Plan ("lRP"), ldaho Power utilized the natural gas price forecast titled "ElA
Reference Case: Natural Gas Spot Price at Henry Hub." This forecast has been
updated annually in October pursuant to ldaho Public Utilities Commission ("lPUC" or
"Commission") Order Nos. 32697 and 32802 for use in the lCIRP methodology. In the
Company's filing dated May 24,2017,|daho Power explains that a different U.S. Energy
lnformation Administration's ('ElA") forecast, the High Oil and Gas Resource and
Technology: Natura! Gas Spot Price at Henry Hub, is a more appropriate and
applicable forecast that has been used in the development of the 2017 lRP.
Notwithstanding the foregoing, ldaho Power has submitted a correction to page 2 of the
Company's Response and Objection that now reads:
[F]or avoided cost rates based upon the lncremental Cost
IRP ('lClRP') methodology, ldaho Power utilizes EIA's
Annual Energy Outlook from a different EIA Reference Case
subset: the
(nom
$/MMBtu) forecast, adjusted for pricing at Sumas and ldaho
City Gate.
I Hereinafter referred to as the "Company's Filing."
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 3
Since the Company provided an updated natural gas price forecast for use in the
ICIRP methodology, which was approved on November 6,2016, in Order No. 33646,
there have been no Public Utility Regulatory Policies Act of 1978 ('PURPA") contracts
that have been filed with the IPUC that utilize avoided cost rates calculated with the EIA
Reference Case: Natural Gas Spot Price at Henry Hub, nor have any PURPA contracts
been filed with the IPUC that utilize avoided cost rates calculated with the EIA High Oil
and Gas Resource and Technology: Natural Gas Spot Price at Henry Hub forecast, as
that forecast is not currently being utilized in the ICIRP methodology.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY.4
REQUEST FOR PRODUCTION NO. 3: Please provide all avoided cost
calculations prepared for PURPA contracts that have not been filed with the ldaho PUC
that use the forecast referenced in Request No. 2. For each calculation please provide
a copy of the QF's Application to ldaho Power (and all other 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The prices in the table
below have been calculated for a proposed project located in Oregon using the ICIRP
methodology with the load and natural gas inputs approved on November 6, 2016, in
IPUC Order No. 33646. lnformation associated with the proposed project's application
has not been the subject of a commission proceeding, nor does ldaho Power have
permission from the project to disclose project-related information to another party.
Therefore, ldaho Power cannot share the project's qualifying facility ("QF') application
and correspondence.
Month/Year
Dec-19
Jan-20
Feb-20
Mar-20
Apr-20
May-20
Jun-20
Jul-20
Aug-20
Sep-20
Oct-20
Heavy Load
Price
(Mills&Wh)
$44.30
$38.66
$39.08
$32.23
$31.21
$30.68
$s3.91
s62.77
$66.79
$67.s4
$49.44
Light Load
Price
(Mills/kWh)
$4s.44
s37.24
$32.00
$34.70
$24.14
$28.s9
s50.86
s61.66
ss7. I 8
$ss.61
$43.49
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 5
Nov-20
Dec-20
Jan-21
Feb-21
Mar-21
Apr-21
May-21
Jun-21
Jul-21
Aug-21
Sep-21
Oct-Z1
Nov-21
Dec-21
Jan-22
Feb-22
Mar-22
Apr-22
May-22
Jun-22
Jul-22
Atg-22
Sep-22
Oct-22
Nov-22
Dec-22
Jan-23
Feb-23
Mar-23
Apr-23
May-23
Jun-23
Jul-23
Aug-23
Sep-23
Oct-23
Nov-23
Dec-23
Ian-24
Feb-24
Mar-24
$49.37
$s 1.1s
$37.07
s41.17
$23.64
$2.33
$8.26
ss3.74
$66.29
s68.66
s70.40
$4s.20
$48.r I
ss l.89
$44.66
$44.s4
s27.tt
$ 1.83
$8.31
$s3.07
$67.27
$71.03
$s9.89
$42.s8
$48.36
$s3.73
$40.97
$42.71
$27.2s
$1.01
$8.22
$s0.24
s63.39
$66.22
s60.74
s40.77
$s0.89
$s8.03
$44.51
$41.61
$33.01
$46.58
$42.2s
$27.36
$27.64
$t6.72
$0.02
$0.41
$39.67
$s9.22
$ss.83
$s r.8s
$43.s7
$49.60
$4s.07
$28.91
$31.65
$29.08
s0.02
$9.9s
$44.69
$s9.63
$s3.69
$s9.31
s37.s0
$s4.04
$55.69
$46. l l
s28.21
$33.86
$0.00
$1r.7s
$49.26
$s6.82
$s6.3s
$50.78
$47.0s
$49.68
$s3.90
$3s. I 7
$3s.s2
$19.ss
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY.6
Apr-24
May-24
Jun-24
Jul-24
Aug-Z4
Sep-24
Oct-24
Nov-24
Dec-24
Jan-25
Feb-25
Mar-25
Apr-25
May-25
Jun-25
Jul-25
Aug-25
Sep-25
Oct-25
Nov-25
Dec-25
Jan-26
Feb-26
Mar-26
Apr-26
May-26
Jun-26
Jul-26
Ntg-26
Sep-26
Oct-26
Nov-26
Dec-26
Jan-27
Feb-27
Mar-27
Apr-27
May-27
Jtn-27
Jul-27
Ntg-27
$1.30
$13.61
$ss.74
$66.1 2
$69.69
$6s.44
$44.01
$s0.64
ss l. l4
$46.27
$41.83
$33.04
$s.27
$18.22
$s3.21
$s9.61
$60.67
$64.19
$41.11
s47.83
$s 1.94
$49.34
$40.69
$32.6s
$2.s6
$1 3.1 0
$46.3s
$61 .1 s
$63.87
$s9.03
$45.34
$49.99
$62.81
$s0.30
$44.s2
$33.27
$2.6s
sr4.47
$46.8s
$8s.74
$88.86
$0.00
$18.10
$ss.26
s76.67
$60.26
$s9.74
$49.80
$43.36
$42.97
s41.s2
s40.37
$37.08
$0.37
s8.86
$46.84
$51.7s
$s6.0e
$54.61
$47.77
$s 1.79
$48.94
$43.10
$34.t2
$33.48
$0.03
$12.23
$43.63
$s 1.06
$62.18
$44.07
$41.12
$47.00
$s4.00
$39.3e
s34.49
s23.88
$0.03
$5.7s
$37.18
$82.06
$88.80
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 7
Sep-27
Oct-27
Nov-27
Dec-27
Jan-28
Feb-28
Mar-28
Apr-28
May-28
Jun-28
Jul-28
Aug-28
Sep-28
Oct-28
Nov-28
Dec-28
Jan-29
Feb-29
Mar29
Apr-29
May-29
Jun-29
ld-29
Aug-29
Sep-29
Oct-29
Nov-29
Dec-29
Jan-30
Feb-30
Mar-30
Apr-30
May-30
Jun-30
Jul-30
Aug-30
Sep-30
Oct-30
Nov-30
Dec-30
Jan-3 1
$81.90
$69.34
$74.30
s90.60
979.41
s68.99
s6l.l I
$30.30
$4r.66
$72.s8
$86.17
$90.s 1
$73. I l
$69.80
$76. l 3
$91.87
$80.08
$72.15
$60.90
$33.75
$43.89
$66.s0
s8s.37
s91.20
$78.12
$72.98
$84.93
$91.12
$80.02
$74.32
$63.96
$29.03
s44.75
$68. l 9
s87.98
s91.06
$80.47
s73.33
$79.69
$94.38
$86.60
s68.94
s62.36
$71.30
$92.21
$69.70
$s2.78
$s8.33
$2s.s6
842.66
$64.76
$81.27
$90. l 3
$67.21
$68.32
s70.70
s90.20
$79.88
$63.63
$61.20
$2s.90
$46.s4
$62.99
$71.73
$83.36
$70.34
$71.1 5
$78.87
$91.49
$79. I I
s63.66
$50. I 8
s2s.87
$41.9s
$63.51
$89.05
$82.70
$74.73
$72.1r
$74.13
s90.07
s66.81
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 8
Feb-3 1
Mar-31
Apr-31
May-31
Jun-3 I
Jul-31
Aug-31
Sep-3 I
Oct-31
Nov-31
Dec-31
Jan-32
Feb-32
Mar-32
Apr-32
May-32
Jun-32
Jul-32
Aug-32
Sep-32
Oct-32
Nov-32
Dec-32
Jan-33
Feb-33
Mar-33
Apr-33
May-33
Jun-33
Jul-33
Aug-33
Sep-33
Oct-33
Nov-33
Dec-33
Jan-34
Feb-34
NIar34
Apr-34
May.34
Jun-34
s67.73
$68.38
$32.28
$sL.22
$7s.00
$e0.39
$91.26
$79.63
$78.14
s81.87
$100.31
s78.90
$68.1 3
$70.00
$3s.s8
$s3.1 6
$71.01
$92.41
$98.83
$82.20
$77.98
$94.06
$102.79
$83.38
$67.91
$71.61
$39.88
$58. l0
$7s.8s
$99.37
$100.37
$83. I s
$79.92
$86.96
$107.r3
$82.ss
$72.60
$73.7s
s41.76
$60.23
$7s.20
$64.87
$68.36
s28.76
$44.23
$64.84
$79.72
$80.4s
$83. I 3
$72.02
$78.42
$100.31
s70.31
s67.7s
$69.9s
$27. I 0
$47.01
$66.83
$84.84
$93.71
$76.64
$73.76
$76.72
$r03.62
s69.7s
$67.62
$71.30
s3s.06
$s9.39
$75.12
$87.82
$84.s 1
$71.68
$7s.34
$83.73
$107.13
$80.46
$70.60
$72.73
$32.08
$s8.93
$76. I 8
]DAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 9
Jul-34
Aug-34
Sep-34
Oct-34
Nov-34
Dec-34
$10s.31
$106.47
$76.24
$76.90
$88.19
$110.6s
$100.28
$104.81
$73.s0
$7s,48
s76.80
$l10.6s
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 1O
REQUEST FOR PRODUCTION NO. 4: Please provide a copy of all ldaho PUC
orders, correspondence or other communication upon which ldaho Power relies as
authority to use the forecast for calculating avoided cost rates in the ICIRP Methodology
referenced in Request No. 2.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see IPUC Order
Nos. 32697,32737, and 32802, which are publicly available from the Commission.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 11
REQUEST FOR PRODUCTION NO. 5: At page 3 of the Company's Filing,
Idaho Power states that, "ln accordance with Commission Orders, the ICIRP
methodology used for larger projects subject to negotiated rates and contracts, utilizes
the natural gas price forecast that ldaho Power uses in its IRP process." Please provide
a list of the referenced Commission Orders, with specific page references, that provide
that the 'lClRP methodology . . . utilizes the natura! gas price forecast that ldaho Power
uses in its !RP process."
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the
Company's response to J. R. Simplot Company's ("Simplot") Request for Production
No.4.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 12
REQUEST 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Neither the Public
Utility Commission of Oregon nor the ldaho Public Utilities Commission has directed
ldaho Power to use a specific natural gas forecast in the Company's IRP filings. Over
the years, ldaho Power has used a number of different gas price forecasts in
determining which forecast consists of a more accurate expectation of long-term natural
gas prices that are accessible to ldaho Power. The Company's current IRP model uses
the EIA natural gas price forecast for Henry Hub, adjusted for pricing at Sumas and
ldaho City Gate, where ldaho Power holds firm pipeline capacity and does perform
natural gas transactions. The specific EIA natural gas forecast used in the 2017 IRP is
the High Oil and Gas Resource and Technology: Natural Gas Spot Price at Henry Hub.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J, R. SIMPLOT COMPANY - 13
REQUEST 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. PIease identify the supply basin in which ldaho Power
"holds firm pipeline capacity and performs natural gas transactions."
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The reference to "the
Mountain Region forecast" relates to EIA's Reference Case - Mountain Region, which
assumes a delivered natural gas price forecast based on regional prices (i.e., spot
prices), with an added markup based on averaged historical values. The states in EIA's
Mountain Region are ldaho, Montana, Wyoming, Nevada, Utah, and Colorado.
Examples of some of the supply basins and liquid trading hubs that are in EIA's
Mountain Region that could supply pricing data for the Mountain Region forecast are
Kern River-Opal located in Wyoming; CIG Rockies located in Wyoming, Colorado, and
Montana; Kern Delivery (price derived from SoCal border pricing) located in Nevada;
and NWP Rocky Mtn. located in Utah. Per the lntercontinental Exchange ("lCE"), all of
those hubs previously mentioned trade at a premium to the supply basins/liquid trading
hubs Sumas located in Washington and Stanfield (price derived from Alberta/AECO)
located in Oregon. Although Idaho is listed as being in EIA's Mountain Region, Idaho
Power holds firm interstate pipeline capacity from the lower priced, previously
mentioned supply basins/liquid trading hubs residing outside of the Mountain Region,
located in Sumas, Washington, and Stanfield, Oregon. ln addition, ldaho Power does
not hold firm interstate pipeline capacity from any of the given supply basins residing
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 14
within the Mountain Region states. Thus, ldaho Power purchases the majority of its
natural gas supply outside of the higher cost Mountain Region, at the lower cost Sumas
and Stanfield supply points.
The response to this Request is sponsored by Michael Polito, Power Supply
Operations Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J, R. SIMPLOT COMPANY - 15
REQUEST FOR PRODUCTION NO. 8: Please provide the "actual natural gas
trading prices from the lntercontinental Exchange ("!CE') referred to on page 3 of ldaho
Power's Filing. Please provide actual natural gas trading prices from the ICE for the
most recent four-year period available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The ICE natural gas
prices referred to on page 3 of ldaho Power's filing are provided on the enclosed CD.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 16
REQUEST FOR PRODUC.IION iLO. 9: On pages 3 to 4, the ldaho Power Filing
references an "analysis" that "compared the reference case forecast with actual future
trading prices from lCE."
a. Please provide a copy of said analysis along with all supporting
workpapers.
b. ldentify 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 lRPs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
a. PIease see the Excel file provided with the Company's response to
Simplot's Request for Production No. 8 for the analysis that compares the reference
case forecast with ICE prices.
b. The author of the analysis was Scott Wright, Senior Planning Analyst, in
the Power Supply Planning group. The analysis was performed to evaluate IRP inputs
and provide the best inputs for the plan.
c. The analysis was performed in this IRP cycle because the reference case
EIA natural gas forecast has been historically high over the last two IRP cycles. As with
every lRP, the Company evaluates all inputs that go into the IRP to provide the best
possible plan.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 17
REQUEST FOR PRODUCTION NO. 10: Please provide an electronic copy of
the graph that appears on page 4 of ldaho Power's filing with a!!formulae intact. Please
provide all documents and workpapers used to produce said graph.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Please see the
attachment provided with the Company's response to Simplot's Request for Production
No. 8 for the graph that appears on page 4 of ldaho Power's filing.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 18
REQUEST FOR PRODUGTION NOJ 1: Please explain, and document, the
impact of the use of ldaho Power's proposed natural gas forecast will have on the
determination of cost-effective conservation, demand-side management and energy
efficiency programs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: The natura! gas price
forecast ldaho Power proposes be used in the Commission's determination of the
published avoided cost rates using the surrogate avoided resource (SAR) methodology
will not change the determination of cost-effective conservation, demand-side
management, and energy efficiency programs.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 19
REQUEST FOR PRODUCTION NO. 12: Please provide a copy of all ICE price
forecasts in the company's possession for the past four years.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: ldaho Power's access
to ICE is through a paid subscription, which prohibits the Company from sharing this
data. Contact information for ICE can be found at the following web address:
https ://www. theice. com/i ndex.
The response to this Request is sponsored by Michael Polito, Power Supply
Operations Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 20
REQUEST FOR PRODUCTION NO. 13: 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 lCE." Please
provide the actual future trading prices, including as separately itemized information:
(a) dates of delivery, (b) volume of gas traded per delivery date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
a. Please see the PDF provided on the enclosed CD. Henry Hub futures
settfement as of November 28,2016.
b. Please see the PDF provided on the enclosed CD. Henry Hub volume
expressed as open interest as of June 12,2017.
The response to this Request is sponsored by Michael Polito, Power Supply
Operations Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 21
REQUEST FOR PRODUCTION NO. 14: Reference ldaho 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 ldaho Power currently fuels any plants with natural gas
purchased and delivered from Henry Hub. ldentify all such plants and specify 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 lRP. lf not,
please explain why it is reasonable to assume that the existing tariff rates escalated at
the rate proposed by ldaho Power in its filing is reasonable without incurring costs to
expand existing pipeline capacity.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
a. ldaho Power does not currently deliver gas from Henry Hub to its plants in
ldaho.
b. Idaho Power does not currently hold pipeline capacity from Henry Hub to
its existing natural gas generation and the location of the IRP proposed resources have
not been identified. lt is reasonable to use Henry Hub as a basis for forecast natural
gas pricing as it is the official delivery location for futures contracts on the NYMEX. lt is
appropriate to use the NYMEX futures contracts as a basis to predict the future delivery
prices to ldaho Power. The NYMEX Henry Hub natural gas contract is a common
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 22
hedging point throughout the industry. !t is also common for both producers and end-
users of natural gas to use financial "basis" products to lock in the price differential
between Henry Hub and the physical location that is of interest to the party. ldaho
Power does much of its forward price hedging using swaps at Henry Hub, as well as
Sumas basis swaps to lock in prices at Sumas, Washington, where a majority of the
physical natura! gas is procured for ldaho Power's plants. ldaho Power adjusts the
Henry Hub forecast price for typical seasonal and regional variations that ldaho Power
pays for natural gas for delivery to its existing natural gas generation as compared to
the Henry Hub delivered price.
The response to this Request is sponsored by Rick Haener, Power Supply
Planning Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY.23
REQUEST FOR PRODUCTION NO. 15: Reference ldaho Power's fili ng at page
6-7 discussing replacement ESAs that have been requested and ldaho Power expects
to be requested. Please identify all of the referenced projects that have or are expected
to request a replacement ESA, including:
a. project name, resource type;
b. interconnected utility;
c. operation date of current ESA;
d. expiration date of current ESA;
e. basis for ldaho Power's expectation that the project will request a
replacement ESA;
f. whether ldaho Power has alerted the project regarding ldaho Power's
request in this docket.
g. last known contact information for the project, including email, physical
address, and telephone.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
a-d. Please see the following table:
a. a. b. c. d.
Proiect Name
Rock Creek #1
Tamarack CSPP
Curry Cattle Company
Clear Springs Trout
Box Canyon
Simplot - Pocatello
Kasel & Witherspoon
Koyle Small Hydro
Black Canyon #3
Malad River
Cedar Draw
Pigeon Cove
Birch Creek
Snake River Pottery
Resource
Tvpe
Hydro
Biomass
Hydro
Hydro
Hydro
CoGen
Hydro
Hydro
Hydro
Hydro
Hydro
Hydro
Hydro
Hydro
Interconnected
Uti!atv
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
Operation
Date
9/1 6/1 983
6t1t1983
6/16/1983
11t21',t983
2t1111984
3t1t2016
3t4t1984
4tzt't984
4116t1984
5t1t1984
6t1t1984
10t31t1984
11t111984
11t30t1984
ESA Exoiration
Date
1t15t2018
5t31t2018
6t16t2018
11t212018
2t11t2019
3t1t2019
3t4t2019
4t2t2019
4t16t2019
5t1t2019
6t1t2019
10t31t2019
11t1t2019
11t30t2019
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 24
Snedigar
Little Wood Rvr Res
Low Line Canal
Pristine Springs #1
Pristine Springs #3
Bettencourt Dry Creek
Biofactory
Lateral # 10
Jim Knight
Lemoyne
Hailey Cspp
86 Anaerobic Digester
Marco Ranches
White Water Ranch
Sagebrush
Briggs Creek
Pocatello Waste
Hydro
Hydro
Hydro
Hydro
Hydro
ldaho Power
ldaho Power
ldaho Power
ldaho Power
ldaho Power
111t1985
2124t1985
511t1985
5t1t2015
5t1t2015
1t1t2020
2t24t2020
5t1t2020
5t1t2020
5t1t2020
Biomass
Hydro
Hydro
Hydro
Hydro
Biomass
Hydro
Hydro
Hydro
Hydro
Biomass
ldaho
ldaho
ldaho
ldaho
ldaho
ldaho
ldaho
ldaho
ldaho
ldaho
ldaho
Power
Power
Power
Power
Power
Power
Power
Power
Power
Power
Power
5t3t2010
5t4t1985
6/1 0/1 985
6t23t1985
6t25t1985
8t1t2010
8/1/1 985
8t1t1985
9/1/1 985
1 0/1 0/1 985
12t31t1985
5t3t2020
5t4t2020
6t10t2020
6122t2020
6t25t2020
8t1t2020
8t1t2020
8t1t2020
9t1t2020
10t10t2020
12t31t2020
e. !n ldaho Power's cogeneration and small power production operational
forecast, the Company assumes that all non-wind QF projects will request replacement
Energy Sales Agreements and continue operating as PURPA QFs, unless otheruise
notified by the project.
f . ldaho Power initially made its filing as a response and objection in IPUC
Case No. IPC-E-17-07, which is a publicly available docket and proceeding that any
entity or individual can participate. This case, GNR-E-17-02, also is a publicly available
proceeding that any entity or individual can participate. ln fact, an organization called
"ldahydro," which states it represents 27 hydro QF projects that may be affected by the
outcome of this proceeding, has intervened in this case. Idaho Power has not
individually alerted projects regarding this matter.
g. This request is not relevant to an avoided cost rate update and ldaho
Power does not have permission from individual projects to share the requested
information.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 25
DATED at Boise, ldaho, this 28th day of June 2017
NOVAN E.
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 26
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of June 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W esl Wash ington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Company
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-33
Spokane, Washington 99202
Clint Kalich
Avista Corporation
1411 East Mission Avenue, MSC-7
Spokane, Wash ingto n 99202
!dahydro
C. Tom Arkoosh
ARKOOSH tAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
X Hand Delivered
_U.S. Mail
_Overnight Mail
FAX
x Email daohne.hua idaho.qov
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF J. R. SIMPLOT COMPANY - 27
Renewable Energy Coalition
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
lrion Sanger
SANGER LAW, P.C.
1117 SW 53'd Avenue
Portland, Oregon 97215
Tamarack Energy Partnership
Michael C. Creamer
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, Idaho 83702
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mai!
_FAXX Email [e-mail]
Christa Bearry, Lega!
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF J. R. SIMPLOT COMPANY - 28