20170718Staff 1-15 to IPC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail
472 W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY TO REVIEW THE
SURROGATE AVOIDABLE RESOURCE (SAR)
METHODOLOGY FOR CALCULATING
PUBLISHED AVOIDED COST RATES.
CASE NO. GNR.E-I7.02
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Idaho Power Company (ldaho Power or
Company) provide the following documents and information as soon as possible, or by
TUESDAY, AUGUST 8, 2017.
This Production Request is 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 documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Idaho Power is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. IDAPA
3 I .01 .01 .228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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JULY 18,20171
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the Natural Gas Spot Price at Henry Hub forecast
data and the website where it is located as referenced on page 2 of the Amended Application.
REQUEST NO. 2: Please provide the Sumas and Idaho City Gate differentials to the
Henry Hub forecast as referenced on page 2 of the Amended Application. Please include the
source of the differential data (and links to website if applicable), and worksheets that show how
the calculation of the resulting forecast is derived. Please provide all worksheets with formulas
intact.
REQUEST NO. 3: Please provide the 20 year EIA Mountain Region forecasts and the
20 year Natural Gas Spot Price at Henry Hub forecasts adjusted for pricing at Sumas and Idaho
City Gate published each year over the past twenty years. Please provide all worksheets with
formulas intact.
REQUEST NO. 4: Please provide the actual annual natural gas prices for Idaho Power
over the past twenty years and explain how they are calculated. Please provide all worksheets
with formulas intact.
REQUEST NO. 5: Please provide the annual amounts, prices, and percentages of
natural gas for each hub from which Idaho Power purchased gas over the last five years. Please
provide all worksheets with formulas intact.
REQUEST NO. 6: Please explain why Idaho Power proposes to adjust the forecast at
Sumas instead of other hubs.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY I8,2OI7
REQUEST NO. 7: The Company states that it "holds firm pipeline capacity and
actually performs natural gas transactions" (Response at 3). Please describe the business
relationship with Northwest Pipeline and provide copies of contracts/agreements including a
description of all services provided by Northwest Pipeline.
REQUEST NO. 8: Please update the graph on page 4 of the Company's Application to
include historical average monthly natural gas ICE transaction prices for 1997 through 2017 and
explain how the average was calculated.
REQUEST NO. 10: Please describe how the Company participates in ICE transactions,
including the types of transactions it conducts on ICE.
REQUEST NO. 11: Please describe how the Company uses ICE data and information.
REQUEST NO. 12: Please provide 5 years of monthly reports for each the following
forms: EIA Form - 423, FERC Form - 423, and EIA Form - 923.
REQUEST NO. 13: The Company states that it used the EIA's Natural Gas Spot Price
at Henry Hub: High Oil and Gas Resource and Technology forecast and that this was presented
to the IRP Advisory Council (Application at 3). Please describe the IRP Advisory Council's
general response to the use ofthis forecast.
REQUEST NO. 14: Please explain why the graph on page 4 of the Company's
application showing the ICE transaction price does not extend beyond 2023.
REQUEST NO. 15: Please provide the actual future trading prices of natural gas from
ICE, including dates of delivery and volume of gas per delivery date for 2029 through 2037 as of
June 12, 2017.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY aJ JULY 18,2077
Dated at Boise, Idaho, this day of July 2017.
Deputy
ls9
General
Technical Staff: Yao Yin (1-6)
Kevin Keyt(7-12)
Stacey Donohue (13-15)
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FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JULY 78,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18th DAY OFJULY 2017, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER, IN CASE NO. GNR-E-77-02, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MICHAEL ANDREA
SENIOR COUNSEL
AVISTA UTILITIES
PO BOX 3727
SPOKANE WA9922
E-mail : [e-mail]
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 8370]
E-mail: [e-mail]
dockets@ idahopower. com
YVONNE HOGLE
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 330
SALT LAKE CITY UT 841I6
E-mail: wonne.hoele@pacifi corp.com
ted. weston@,pac i ficorp. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail: peter@,richardsonadams.com
CLINT KALICH MANAGER
RESOURCE PLANN & ANALYSI
AVISTA UTILITIES
PO BOX3727
SPOKANE WA9922O
E-mail: [e-mail]
MICHAEL DARRINGTON
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707
E-mail : mdarrin gton@ idahooower. com
DANIEL MacNEIL
ROCKY MOT]NTAIN POWER
825 NE MULTNOMAH ST
PORTLAND OR 97232
E-mail : daniel.macniel(@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareque st@paci ficorp. c om
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
CERTIFICATE OF SERVICE
JEFFREY K LARSEN VP
REGULATION & GOV AFFAIRS
ROCKY MOUNTAIN POWER
i4O7 WN TEMPLE STE 170
SALT LAKE CITY UT 841 16
E-mail : jeff larsen@,pacifi corp. com
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 8370I
E-mail : [e-mail]
IRION SANGER
SANGER LAW PC
I I I7 SW 53RD AVE
PORTLAND OR 972I
E-mail: [e-mail]
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W BANNOCK STREET
BOISE ID 83702
E-mail: [e-mail]
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W BANNOCK STREET
BOISE ID 83702
E-mail: [e-mail]
CERTIFICATE OF SERVICE