20090507IIPA 30-88 to IPC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTEREDW. 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
Jean D. Jewell, Secretar
Idaho Public Utilties Commission
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-09-11
Dear Ms. Jewell:
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
ww.racinelaw.net
SENDER'S E-MAIL ADDREss:elo\\racinelaw.net
May 5, 2009
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD~ SUITE.208
BOISE~ IDAHO 83702
TELEPHONE: [phone]
FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 203AIDAHO FALLS, ID 83402
TELEPHONE: [phone]
FACSIMILE: [phone]
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD~ SUITE 10GA
COEUR D'ALENE, ID 83814
TELEPHONE: [phone]
ALL OFFICES TOLL FREE
[phone]
LOUISF. RACINE 0917-2005)
WILLIAM D. OLSON. OF COUNSEL
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Enclosed for filing in the captioned matter, please find the original and three copies of Idaho
Irrigation Pumpers Association, Inc. 's Third Data Requests to Idaho Power Company.
ELO:nj
Enclosures
cc: Service List
Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
1"'-. ..:1 l"...i ,'.
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Attorneys for Idaho Irrgation 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 JUE 1,
2009, THROUGH MAY 31, 2010
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CASE NO. IPC-E-09-11
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.dS THIRD DATA
REQUESTS TO IDAHO POWER COMPANY
IDAHO IRRGATION PUMPERS ASSOCIATION, INC. ("LIP A"), by and
through its attorneys, hereby submits this Third Data Requests to Idaho Power Company
("IPC"), pursuant to Rule 225 of the Idaho Public Utility 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-08-10:
30. On May 27,2008 there was listed a purchase from Iberdrola Renewables (Source
234898) of 400 MWH for a price of negative $0.80 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.
31. On May 27, 2008 there was listed a sale to Puget Sound Energy of 200 MWH (Source
234895) for a negative $3 per MWH. Both Bridger and Valmy were operating during the
time of this sale. Please explain why the Company made this sale and its value/profit to
the Company.
32. On May 26, 2008 Bridger operated in the range of 132-154 MW between midnight and
11 in the morning. From about noon on, it operated in a range of 193-326 MWH.
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
THRD DATA REQUESTS TO IDAHO POWER COMPAN - 1
When were the day-ahead sales under Sources 234895, 234896, and 234901
conceived/developed? Why didn't Bridger stay at the a.m. operating level instead of
increasing durng the p.m. and then sellng off the increased generation beginning at
midnight under these three contracts?
33. On May 29,2008 there was listed a sale to Powerex Corp of 1,400 MWH (Sources:
234978-234984) for a negative $0.50 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.
34. On May 29, 2008 at HR10 there were two real-time purchases from Arizona Public
Service (Sources: 235042 and 235043) for $37.50 per MWH. During that same hour,
there was a real-time sale to BPA (Source 235034) at $18.40 per MWH.
a. Why were there real-time purchases and sales durng the same hour?
b. What was the basis for making the real-time sale to BP A?
c. What was the basis to follow-up the BPA real-time sale with a purchase from
Arizona?
35. Please explain how the real-time sales to BPA (Source 234932) and Snohomish County
(Source 234931) on May 26, 2008 came about at a price of zero.
36. Please explain the reason for the designation of "Default" associated with the Morgan
Standley sale (Source 234327) on May 1 0, 2008.
37. Please explain the reason for the designation of "Default" associated with the
NorthWestern Energy agreements (Sources 234753,234797, and 234798) and why they
were priced at zero.
38. Please explain the reason for the designation of "Default" associated with several
agreements (Sources 235091, 235092, 235093, 235099 and 235100) on May 30, 2008.
39. On June 1,2008 there is a real-time purchase from Arizona Public Service (Source
236704) for approximately 25 MW per hour that begins on HR15 for $6 per MWH. This
seems to be offset by a Real-time sale to Avista (Source 236701) for $27.50 per MWH.
a. How did these two transactions come about?
b. How are these two transactions related?
c. The Source numbers for these two transactions are out of sequence with June 1,
2008 and suggest that the contracts were wrtten after June 2008. Please explain
when these contracts were wrtten and why.
40. Regarding the PacifiCorp Term sale agreement (Source 229995) on June 2, 2008, and
assuming that these "sales" are provided as payment for losses on the PacifiCorp system~
with which transactions are these losses associated?
41. Please explain why the Company paid A vista a negative $2 per MWH for off-peak
energy on June 2, 2009 (Source 235068).
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
TB DATA REQUESTS TO IDAHO POWER COMPAN - 2
42. Please explain why during HR 11 through HR14 on June 2, 2008 that the Company paid
Morgan Stanley (Sources: 235163 and 235164)$115 per MWH for real-time energy,
while it paid Arzona Public Service (Sources: 235208 and 235211) $15 per MWH
during the same timeframe, as well as a host of other transactions during HRll at $15
and below per MWH. Also, please explain the relatively large gap in the sequence
numbers between the Arzona deal and the Morgan Stanley deal.
43. Please explain why both Bennett Mountain and Danskin were operated on June 2,2008
as opposed to other forms of power being utilized (purchased or generated).
44. Please explain why Danskin was operating between HR 15 and HR22 when the
Maximum price the Company was paying for real-time energy was $15 per MWH.
45. Why was day-ahead, off-peak power sold to CitiGroup (Source 235141) and Powerex
(Sources 235139 and 235140) for a negative $1.75 per MWH on June 3, 2008?
46. Why was day-ahead, off-peak power sold to Arizona Public Service (Source: 235142)
and others for $5 per MWH on June 3, 2008?
47. On June 3, 2008, why was the Company making $5 per MWH sales when it was
operating Bridger and Valmy?
48. On June 3, 2008, why was the Company making a real-time purchase from Shell Energy
(Source 235238) during HR16 for $51 per MWH, while at the same time it was making a
real-time sale to Shell Energy (Source 235239) at $47 per MWH?
49. What is the minimum operating level of Bridger and what is the variable cost of
production at this minimum level? If this level vares significantly by month, please
provide the information for each month from April 2008 through March 2009.
50. What is the minimum operating level of Valmy and what is the varable cost of
production at this minimum level? If this level varies significantly by month, please
provide the information for each month from April 2008 through March 2009.
51. What is the minimum operating level of Boardman and what is the variable cost of
production at ths minimum level? If this level vares signficantly by month, please
provide the information for each month from April 2008 though March 2009.
52. Please explain the rationale for selling real-time energy on June 7, 2008 between HR17
and HR20 for between $1 and $5 per MWH when Bridger and Valmy were operating.
53. One June 9, 2008, why was the Company operating Bennett Mountain and Danskin at
the same time that it was makng day-ahead sales in the $26.50 to $38 per MWH price
range?
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
TIl DATA REQUESTS TO IDAHO POWER COMPAN - 3
54. One June 9, 2008, why was the Company operating Bennett Mountain and Danskin at
the same time that it was making real-time purchases in the $20 to $35 per MWH price
range?
55. One June 9, 2008, why was the Company operating Bennett Mountain and Danskin at
the same time that the maximum it paid for real-time energy during only three hours of
that operation was $73 per MWH?
56. On June 9, 2008, why was the Company operating Danskin after HR16 when it appears
that the hydro generation appeared to be backed-off?
57. On June 10,2008, why was the Company purchasing real-time energy from Sierra
Pacific for $27 per MWH (Source 235553) while at the same time purchasing real-time
energy from Cargil (Sources: 235552,235554,235557, and 235559) at $10 per MWH?
58. On June 10,2008, why was the Company purchasing real-time energy from Sierra
Pacific for $27 per MWH (Source 235553) while at the same time sellng real-time
energy to PPL EnergyPlus (Sources: 235555, 235556, 235558, 235560, and 235563) at
$10 per MWH?
59. Please explain why between June 11 and June 14,2008 that there were a number of day-
ahead off-peak sales for a negative value.
60. On June 14, 2008, there was a real-time buy from Cargil at $10 per MWH for HR16
through HR21 (Source 235679) and an offsetting sale for $10 during the same hours and
for the same amount to PPL EnergyPlus (Source 235678).
a. How are these two transactions related?
b. Why were these transactions initiated?
c. What cost did Idaho Power incur because of losses associated with these
transactions?
61. Why was the Company making real-time sales to PPL EnergyPlus on June 14, 2008
when Bridger and Valmy were operating?
62. Why was approximately 175 MW per hour of energy sold at between $2 and $4 per
MWH on June 15,2008 when both Bridger and Valmy were operating?
63. Why did the Company by day-ahead off-peak energy on June 16,2008, but it did not
buy day-ahead on-peak energy?
64. Why did the Company run Danskin on June 16, 2008 as opposed to getting energy from
other sources?
65. If the Company was buying real-time power from Powerex (Sources: 235705, 235706,
235708) durng HR17 through HR22 for $110 per MWH, why didn't it choose to ru
Bennett Mountain instead?
IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S
THI DATA REQUESTS TO IDAHO POWER COMPAN - 4
66. On June 16, 2008, the Company made a number of day-ahead purchases durng HRI
through HR 7 in the $2-$8 per MWH range. How much real-time power was available
and at what price, beginning at HR 7?
67. Why was Boardman not operating between April 25 and June 15, 2008?
68. Why was Bennett Mountain ru on June 17,2008 and not Danskin? Why was Danskin
ru on June 16,2008 and not Bennett Mountain?
69. When was the decision made to ru Bennett Mountain on June 17,2008 and on what
basis?
70. There is a day-ahead sale to Barclays Ban (Source 235032) for 1,200 MWH of on-peak
energy at $38 per MWH. This contract was in effect every day in June 2008 except
Sundays. What was the rationale for selling this much on-peak energy everyday in June
at this price?
71. While Bennett Mountain was ruing on June 17,2008, BPA sold the Company real-
time energy at $32 per MWH. Was there any more energy at the same or a similar price
that could have been purchased from BP A durng those hours?
72. Durng HR15 and HR16 Sierra Pacific (Source 235741) sold power to the Company for
$140 per MWH and durng HRI7, Public Service of New Mexico (Source 235745) sold
power to the Company for $165 per MWH. Why didn't the Company sta Danskin and
thus avoid these purchases while at the same time selling the excess energy into the
market at prices in the range of $140-$160?
73. Why were there no day-ahead purchases made for June 17, 2008?
74. Why were there day-ahead off-peak sales on June 18,2008 in the range of $2-$5 per
MWH when Boardman, Bridger, and Valmy were operating?
75. For June 19,2008 the Company made several day-ahead purchases at or above $83 per
MWH. These included PacifiCorp (Source 235755) at $95 per MWH, Sempra Energy
(Source 235751) at $95 per MWH, and Citigroup Energy (Source 235753) at $97 per
MWH. Based upon the sequence of Source numbers, it would appear that afer these
purchases were made, the Company made the following day-ahead sales: PacifiCorp
(Source 235769) at $83 per MWH and Morgan Stanley (Source 235757) at $92 per
MWH. Why did the Company buy energy at one price and then tum around and sell it
for a lower price?
76. On June 19,2008, what was the variable operating cost of Danskin and Bennett
Mountain?
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
TH DATA REQUESTS TO IDAHO POWER COMPAN - 5
77. Of the operating cost of Bennett Mountain was less than the day-ahead prices that the
Company paid for on-peak power on June 19,2008, why wasn't Bennett Mountain used
instead of these purchases being made?
78. Why was Bennett Mountain operated on June 19,2008 between HR10 and HR17 when
it appears that the Company's hydro was operated below potential?
79. On June 21, 2008 the Company bought 200 MW of on-peak power between $63 and $74
per MWH. On that same day, it bought real-time on-peak power (HRI5-HRI9) for $15
per MWH. Why was the Company's projections of day-ahead costs so much higher than
the resulting real-time price?
80. On June 21, 2008 there was 100 MWH of energy bought on a real-time basis over the
five hour period HRI5-HRI9.
a. How much other real-time power was available (offered to the Company) on
that day and at what price?
b. If the Company had not bought this real-time power, where would it have
gotten the additional 100 MWH of energy it needed each of these five hours?
c. If the Company could have bought 100 MWH during other hours, or could have
bought additional power during these five hours, which sources would it have
backed-off and by how much?
81. Please explain the basis for the fact that the Company was purchasing from DB Energy
(Source 235846) at a negative $9 per MWH on June 22, 2008.
82. On June 24, 2008 Shell Energy (Source 235911) sold 600 MWH of off-peak energy at
$0. Over this same timeframe, the Company sold to Shell Energy (Source 235905) 200
MWH at $0.50 per MWH.
a. Are these transactions related, and if so, how?
b. Why was the Company sellng power at $0.50 per MWH?
c. How, if at all are these transactions related to the purchase of 200 MWH of off-
peak energy from Shell Energy (Source 235949) on June 25, 2008?
83. On June 24, 2008 why was TransAlta Energy (Source 235909) sellng 400 MWH of off-
peak energy to the Company at $0, aswell as sellng (Source 235908) 600 MWH of off-
peak energy to the Company at $025 per MWH?
84. On June 26, 2008 all of the off-peak day-ahead purchases are at either $0 per MWH or a
negative value. Please explain what circumstances and terms allow this much power to
be obtained for either free or to be paid to take it. It this power was to be paid back at a
later date, please indicate when it was returned, to whom, and at what price.
85. On June 27, 2008 there were five real-time purchases during on-peak hours from Sierra
Pacific (Source 236126 et. aL.) at either $0 per MWH or a negative $20 per MWH.
Please explain what circumstances and terms allow this much power to be obtained for
either free or to be paid to take it.
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
THRD DATA REQUESTS TO IDAHO POWER COMPAN - 6
86. On June 28, 2008 Danskin was run.
a. What on-peak day-ahead power was offered to the Company, at what price, that
was not purchased? Why?
b. On-peak day-ahead purchases ranged in price from $52 to $72.50 per MWH.
Looking at the sequence of Source values, it would appear that the last on-peak
day-ahead purchase made was from Barclays Bank (Source 236085) at $52 per
MWH. When was the decision made to ru Danskin in relationship to when the
Company was making day-ahead and real-time purchase decisions?
c. Durng the hours when Danskin was operating, the Company was making real-
time purchases from BP A (Sources 236209 and 236210) for $8 per MWH. It was
also making real-time purchases from PacifiCorp (Sources 236229 et. aL.) for $45
per MWH. Why did the Company choose to operate Danskin instead of making
additional real-time purchases?
87. June 29, 2008 was a Sunday and Danskin ran.
a. For the three days previous to this, the Company had purchased 425 MW of on-
peak capacity on a day-ahead basis. Why did the Company only purchase 300
MW of on-peak capacity on a day-ahead basis for June 29, 2008?
b. Durng the hours that Danskin was operating, the Company was purchasing real-
time power from BPA (Sources 236238 and 236239) for $8 per MWH, from BPA
(Source 236247) for $15 per MWH, and from PacifiCorp (Sources 236258 et. al.)
for $45 to $55 per MWH. Why did the Company choose to operate Danskin
instead of makng additional real-time purchases?
c. When was the decision made to ru Danskin in relationship to when the Company
was making day-ahead and real-time purchase decisions?
88. Durng hours HRl1 through HR15 on June 30, 2008, the Company's hydro was
operating at 1,217-1,335 MW. Why was hydro only producing 1,021 MWH durng
HR16 and 967 MWH on that day?
-fttDATED this L day of May, 2009.
RACINE, OLSON, NYE, BUDGE &
BAILEY, C ERED
B
IDAHO IRRGATION PUMERS ASSOCIATION, INC.'S
TH DATA REQUESTS TO IDAHO POWER COMPAN -7
, ,
CERTICATE OF MAING
I HEREBY CERTIFY that on this 5fI day of May, 2009, I served a tre,
correct and complete copy of the foregoing document, to each of the following, via the
method so indicated:
Jean D. Jewell, Secreta
Idaho Public Utilities Commission
P.O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
i i ewell (fuc. state.id. us U.S. Mail/Postage Prepaid
and E-mail
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
IDAHO IRGATION PUMERS ASSOCITION, INC.'S
THI DATA REQUESTS TO IDAHO POWER COMPAN - 8