20090504IIPA 2-29 to IPC.pdf

LAW OFFICES OF
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT O. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
LANE V. ERICKSON
DAVID E. ALEXANDER
PATRICK N. GEORGE
SCOTT J. SMITH
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
BRENT L. WHITING
JONATHON S. BYINGTON
DAVE BAGLEY
CAROL TIPPI VOLYN
THOMAS J. BUDGE
CANDICE M. MCHUGH
JONATHAN M. VOLYN
MARK A. SHAFFER
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
ww.radnelaw.net
SENDER'S E-MAIL ADDRESS:elo(§racinelaw.net
May 1,2009
Jean D. Jewell, Secretar
Idaho Public Utilities Commission
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-09-11
Dear Ms. Jewell:
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702TELEPHONE:. (208) .395-0011
FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE203A
IDAHO FALLS, ID 83402
TELEPHONE: [phone]
FACSIMILE: (208) 52S.6109
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE tOSACOEUR ~ALENE. lD 83814
TELEPHONE: [phone]
LOUIS F. RACINE (1917.2005)WILLIAM D. OLSON, OF COUNSEL
ALL OFFICES TOLL FREE
[phone]
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Enclosed for fiing in the captioned matter, please find the original and thee copies of Idaho
Irrigation Pumpers Association, Inc. 's Second Data Requests to Idaho Power Company.
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Enclosures
cc: Service List
Eric L. Olsen ISB# 48 I I
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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Attorneys for Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
COST ADJUSTMENT ("PCA") RATES
FOR ELECTRIC SERVICE FROM JUNE I,
2009, THROUGH MAY 31, 2010
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CASE NO. IPC-E-09- I I
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA
REQUESTS TO IDAHO POWER COMPANY
IDAHO IRRGATION PUMPERS ASSOCIATION, INC. ("IIPA"), by and
through its attorneys, hereby submits this First Data Requests to Idaho Power Company
("IPC"), pursuant to Rule 225 of the Idaho Public Utilty Commission's Rules of
Procedure, IDAPA 31.01.01, the following questions relate to information that IPC
previously supplied in response to IIPA's Data Request No.8, in IPC-E-08-1O:
2. The data for April 1,2008 lists Day Ahead "Buys" from BPA (Sources: 229989,
229990,229991, and 229992) at a price of zero. What tye of purchases are these, and
why are they priced at zero?
3. The data for April I, 2008 lists Day Ahead "Buy" from PacifiCorp (Source: 230771)
at a price of zero. What type of purchase is this, and why is it priced at zero?
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
SECOND DATA REQUESTS TO IDAHO POWER COMPAN - 1
4. The data for April I, 2008 lists Day Ahead "'Sells" to BPA, PacifiCorp, and Sierra
Pacific (Sources: 229997, 229994, and 229996) at a price of zero. What type of sales are
these, and why are they priced at zero?
5. The data for April 1,2008 lists a Term "'Sell" to PacifiCorp (Source: 229995) at a
price of zero. What type of sale is this, and why is it priced at zero?
6. For each gas fired generator owned by the Company please indicate the minimum
market price for which it is economical to generate energy from the generator, given the
cost of natural gas and the heat rate of the unit. Assuming that this rate varies with the
price of natual gas, please provide this information in relationship to the natual gas
prices faced by the Company durng each day of the April 1, 2008 through March 3 I,
2009 timeframe.
7. For Bridger and Valmy, please indicate the minimum market price for which it is
economical to generation energy from the facility, given the cost of coal and the heat rate
of the unts. If that rate vares with the price of coal, please provide this information in
relationship to the coal prices faced by the Company durng each day of the April I, 2008
through March 3 I, 2009 timeframe.
8. What is the minimum generation level for Bridger and Valmy? What is the cost per
MWH of operating these units at this level?
9. Why was Danskin operating on May 19,2008 at the same time that there were Real-
time sales to BP A at $20 per MWH?
10. Durng what hours of the day are "'Day Ahead" salesluys made? Are Saturday and
Sunday "'Day Ahead" saleslbuys make on Friday?
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
SECOND DATA REQUESTS TO IDAHO POWER COMPAN - 2
i I. Can it generally be assumed that the six digit "Source" numbers that are listed for
each transaction in the Company's data are in chronological order?
12. What is meant by the May 20, 2008 sale to NorthWestern Energy (Source 234753) as
"Default"? Why is it priced at zero?
13. What is the rational for the "Balance of the Month" off-peak purchases from Morgan
Stanley Capital Group (Sources 234460, 234464, 234459) at $27 per MWH that began on
May 15, 2008?
14. What is the rational for the "Day Ahead" off-peak sales to Cargil, Iberdrola, and
Powerex (Sources: 23477 I, 234772, and 234770) at $ i 7 per MWH when these sales are
merely offsetting the "Balance of the Month" purchases from Morgan Stanley priced at
$27 per MWH?
15. On May 19,2008 the Company began on-peak "Balance of the Month" purchases
from eight different Sources. The daily purchases amounted to 3,200 MWH at a price of
$194,600 or an average cost of$60.81 per MWH. On May 23, 2008 the Company began
on-peak "Balance of the Month" sales to eight different Sources. The daily sales also
amounted to 3,200 MWH and were sold at a price of $1 i 8,660. This relationship
continued for the rest of the month. What caused the Company to enter into these
"Balance of the Month" purchases and subsequent "Balance of the Month" sales at such
different prices?
16. There are four "Buy" contracts with BPA (Sources: 229989, 229990, 229991, and
229992) as well as two "Sell" contracts (Sources: 229994 and 229997) that are at a price
of $0 and amount to very little if any energy being transferred in any given hour:
a. When were each of these contracts initiated?
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
SECOND DATA REQUESTS TO IDAHO POWER COMPAN - 3
b. When is each contract suppose to end?
c. Why are these contracts at a price of $O?
d. Why does the energy transferred from hour to hour var?
e. What is the purse of each of these contracts?
f. How are these contracts related?
g. Why are these contracts considered to be "Day Ahead" as opposed to "Term"?
17. There is a Sierra Pacific "Sell" contract (Source: 229996) that sequentially is very
near to the BPA contacts referenced in "16" above. This contract is also for small
transactions at a rate of $0. What is the purpose of this contract, and how does it relate to
the contacts addressed in "16" above?
I 8. There is a PacifiCorp "Buy" contract (Source: 230771) that is also priced at $0.
What is the purpose of this contact, and how does it relate to the contracts addressed in
"16" and "17" above?
I 9. Why are there three different entres listed for the PacifiCorp "Sell" contract (Source
233890) for May I, 2008 of 50, 50, and 25 MW levels as opposed to one entr of 125
MW?
20. Please explain why the Powerex Corp "Buy" contract (Source 233970) for May 6,
2008 has two entries with one entry essentially at 25 MW and the other at 0 MW except
for HRl2 where one entry is for 19 MW and the other is for 6.
2 I. As par of the transactions on May 6, 2008, Source contacts 233971 and 233972
were issued to each buy 25 MW of on-peak energy at $78 per MWH. Source contracts
233973 and 233974 followed and each sold 25 MW of on-peak energy at $78.75 per
MWH. This was followed by Source contract 233975 to sell an additional 25 MW of on-
IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUESTS TO IDAHO POWER COMPAN - 4
peak energy at $79 per MWH. Following that, Source contract 233976 was issued that
bought 50 MW of on-peak energy at $82.50 per MWH.
a. What was the date and time that each of the above Source contracts was
issued?
b. Whch, if any, of these contracts were entered as a package?
c. There were a number of additional Source contacts for May 6, 2008 (Sources:
233977 thr 233983) for on-peak '"Buys". Why did the Company sell on-peak
energy under Sources 233973-233975 at prices that were less than the prices
paid for additional purchases later in the day?
22. Between May 8 and May 9,2008 there was a jump in the sequence numbers for
contract '"Sources" from 234 167 to 234206. What other entity or affiiate used these
missing Source codes?
23. On May 12,2008 there is a BPA contract Source 234286. Why is this contract for a
'"Buy" at a price of$O and for many, but not all of the on-peak hours?
24. On May 14,2008 contracts were issued for Sources 234439-234527. Please
answer the following:
a. What was the date and time each contract was issued?
b. Why are there gaps in the Source sequence values?
c. Why was on-peak power in the market on that day priced at between $81-92
per MWH?
d. Why didn't the Company plan to use any of its gas fired units on May 14,
2008?
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
SECOND DATA REQUESTS TO IDAHO POWER COMPAN - 5
e. Why did the Company sell 1,200 MWH at $83 per MWH when it had been
purchasing power for this time frame at prices between $80-92 per MWH?
25. For each Source value listed in the data for April 1,2008 through March 31,2009,
please provide the date and time that the contract was executed.
26. On May 23, 2008 there was a sale to Powerex Corp. (Source 234819) of 1,600 MWH
at $6 per MWH. Both Bridger and Valmy were operating durng the time of this sale.
Please explain why the Company made this sale and its value/profit to the Company.
27. On Sunday May 25, 2008 there was a sale of 150 average MW (3,600 MWH) to
Lehman Brothers Commodity Services (Source 234863) for $3.50 per MWH. Both
Bridger and Valmy were operating durng the time of this sale. Please explain why the
Company made this sale and its value/profit to the Company.
28. On May 27,2008 there was listed a sale to Puget Sound Energy of200 MWH
(Source 234895) for a negative $3 per MWH. There is also listed a sale to Powerex Corp
of 400 MWH (Source 234896) for a negative $2.50 per MWH.
a. If these negative prices are not a misprint, then explain why something would
be sold to these entities at a net cost to Idaho Power.
b. Both Bridger and Valmy were operating durng the time of this sale. Please
explain why the Company made this sale and its value/profit to the Company.
29. On May 27,2008 there was listed a purchase from PPL EnergyPlus (Source 234897)
of 560 MWH for a price of negative $2 per MWH. If these negative prices are not a
misprint, then explain why something would be purchased from this entity at a negative
cost to Idaho Power.
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
SECOND DATA REQUESTS TO IDAHO POWER COMPAN - 6
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DATED this lJ-day of May, 2009.
RACINE, OLSON, NY, BUDGE &
BAILE , TERED
ERIC L. OLSEN, Attorney for
Idaho Irrgation Pumpers
Association, Inc.
CERTIFCATE OF MAING
I HEREBY CERTIFY that on this i~t day of May, 2009, I served a true,
correct and complete copy of the foregoing document, to each of the following, via the
method so indicated:
Jean D. Jewell, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
472 W . Washington Street
Boise, Idaho 83720-0074
i i ewell (ipuc. state.id. us
Baron L. Kline
Donovan E. Walker
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
bkline(iidahopower .com
dwalker(iidahopower .com
U.S. Mail/Postage Prepaid
and E-mail
.S. Mail/Postage Prepaid
dE-mail
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
SECOND DATA REQUESTS TO IDAHO POWER COMPAN -7