The URL can be used to link to this page

Home My WebLink About20170810Tamarack 3-5 to IPC.pdf",..:i",;:I!/i:Li : "1 : ' i'i Pli 12: 0:Michael C. Creamer (ISB No. 4030) Preston N. Carter (ISB No. 8462) Givens Pursley LLP 601 W. Bannock St. Boise, ID 83702 Telephone: (208)-388-1 200 Facsimile: (208) -388-1 300 mcc@ givenspursley. com pnc@ givenspursley. com 13833781_1 18822-4) Attorneys for Tamarack Energy Partnership 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 PUBLISIIED AVOIDED COST RATES Case No. GNR-E-17-02 TAMARACK ENERGY PARTNERSHIP'S SECOND INTERROGATORIES AND REQUESTS FOR PRODUCTION TO IDAHO POWER COMPANY Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission"), Tamarack Energy Partnership, by and through its counsel of record, Givens Pursley LLP, requests that Idaho Power Company ("Idaho Power") provide the following documents and responses to interrogatories. These requests are 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 maylater obtain that will augment the document produced. 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. TA]\4AIL{CK ENERGY PARTNERSHIP'S SECOND INTERROGATORIES AND REQUESTS FOR ORIGINAL PRODUCTION TO IDAHO POWER COMPA}ry - I INrnnnocAToRrES Interrosatorv No. 5: Idaho Power in response to Commission Staff s First Production Request, Response to Request No. 6, stated: Whereas, Sumas is a robustly traded market, both physically and financially, with daily forward pricing settlements provided by the Intercontinental Exchange ("ICE") where Idaho Power can derive future price forecasts. Please define what Idaho Power means by its statement that Sumas is a 'financially' traded market and a "physically" traded market. Rrqunsrs FoR PRoDUCTToN Request for Production No. 3 Idaho Power in response to Commission Staff s First Production Request, Response to Request No. 6, stated: Whereas, Sumas is a robustly traded market, both physically and financially, with daily forward pricing settlements provided by the Intercontinental Exchange ("ICE") where Idaho Power can derive future price forecasts. Please provide, annually, for the years 2008 through 2016, the natural gas volumes Idaho Power has purchased and sold both "financially" and "physically'' at the Sumas hub. Please clearly indicate whether each volume was purchased, sold, or otherwise exchanged "financially''or "physically'' and the dollar amount for each transaction. Request for Production No. 4 Idaho Power in response to Commission Staff s First Production Request, Response to Request No. 6, stated: Consistent with the transportation assets that Idaho Power owns, per the data included in the Company's response to Staff s Request No. 5, Idaho Power purchases much of its natural gas supply either at Sumas or at various other supply hubs using Sumas pricing (Huntingdon, Pacific Pool, and Jackson Prairie). Please provide, annually, for the years 2008 through 2076, the natural gas volumes Idaho Power has purchased and sold "financially'' and "physically" for each of the Huntingdon, Pacific Pool and Jackson Prairie hubs. Please also provide the dollar amounts annually, for the years 2008 TAT4AIL{CK ENERGY PARTNERSHIP'S SECOND INTERROGATORIES AND REQUESTS FOR PRODUCTION TO IDAHO POWER COMPA}IY - 2 through 2016,Idaho Power has purchased and sold "financially'' and "physically" for each of the Huntingdon, Pacific Pool and Jackson Prairie hubs. Dated: August 10,2017. GIVENS PURSLEY LLP /--< Michael C. Creamer Preston N. Carter Attorneys for Tamarack Energy Partnership TAI\4AIL{CK ENERGY PARTNERSHIP,S SECOND INTERROGATORIES AND REQUESTS FOR PRODUCTION TO IDAHO POWER COMPANY - 3 CERTIFICATE OF SERVICE I certify that on August 10, 2017 , a true and correct copy of TaUARACK ENERGv PARTNERSHIP'S SECOND INTERROGATORIES AND REQUESTS FOR PRODUCTION TO IDAHO PowER COMPAI.IY, in Docket No. GNR-E-17-02 was served via electronic mail to the following: TAMARACK ENERGY PARTNERSHIP'S SECOND INTERROGATORIES AND REQUESTS FOR PRODUCTION TO IDAHO POWER COMPA].ry - 4 Commission Secretary Diane Holt Idaho Public Utilities Commission P.O. Box 83720 Boise, D 83720-0074 diane.holt@puc.idaho. gov Daphne Huang Idaho Public Utilities Commission 47 2 W est Washington Street Boise, D 83702 Daphne.huang@f'uc. idaho. eov Donovan E. Walker Idaho Power Company l22lW. Idaho Street PO Box 70 Boise,ID 83707 dwalker@ idahopower. com dockets@idahopower.com Michael Darrington Idaho Power Company l22lW.Idaho Street PO Box 70 Boise,ID 83707 mdarrinston@ idahopower.com Yvonne Hogle Ted Weston PacifiCorp d/b/a Rocky Mountain Power 201 S. Main Street, Suite 2300 Salt Lake City, UT 84116 Yvonne.ho gle@pacifi corp.com Ted.weston@pacfi corp.com Daniel MacNeil PacifiCorp d/b/a Rocky Mountain Power 825 NE Multnomah Street Portland, OR 97232 Daniel.macneil@pacifi corp.com Jeffrey K. Larsen, V.P. Regulation & Gov. Affairs PacifiCrop d/b/a Rocky Mountain Power 201 S. Main Street, Suite 170 Salt Lake City, UT 84116 Jeff. larsen(@paci fi corp. con J.R. Simplot Company c/o Peter J. Richardson Richardson Adams, PLLC 515 N. 27th Street PO Box 7218 Boise,ID 83702 peter@richardsonadams. com Dr. Don Reading 6070 Hill Road Boise,ID 83703 dreading@mindspring.com Idahydro clo C. Tom Arkoosh Arkoosh Law Offices PO Box 2900 Boise,ID 83701 Tom. arkoosh@arkoosh. com Renewable Energy Coalition c/o Gregory M. Adams Richardson Adams, PLLC 515 N.27ft Street P O Box 7218 Boise,ID 83707 gre g@richardsonadams. com Renewable Energy Coalition c/o lrion Sanger Sanger Law, PC 1117 SE 53'd Avenue Portland, OR 97215 irion@sanger-law.com f /r. 'Z Preston N. Carter TAMARACK ENERGY PARTNERSHIP'S SECOND INTERROGATORIES AND REQUESTS FOR PRODUCTION TO IDAHO POWER COMPAI{Y - 5 Clint Kalich, Manager Resource Planning & Analysis Avista Corporation l4l I East Mission Street, MSC-7 Spokane, WA 99202 Clint.kalich@avistacorp.com Michael Andrea, Senior Counsel Avista Corporation l4l I East Mission Street, MSC-33 Spokane, WA99202 Michael.andrea@avistacorp.com \