20120423IIPA 13-19 to IPC.pdf

LAW OFFICES OF
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. 0000ELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT 0. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
LANE V. ERICKSON
FREDERICK J. HAHN, III
PATRICK N. GEORGE
SCOTT J. SMITH
JOSHUA D. JOHNSON
DAVID E. ALEXANDER
STEPHEN J. MUHONEN
CANDICE M. MCHUGH
CAROL TIPPI VOLYN
JONATHON S. BYINGTON
JONATHAN M. VOLYN
THOMAS J. BUDGE
BRENT L. WHITING
DAVE BAGLEY
JASON E. FLAIG
FERRELL S. RYAN, III
AARON A. CRARY
JOHN J. BULGER
BRETT R CAHOON
JEFFREY A. WARR
Jean J. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0084
I/'c
Re: Case No. Ci 2C'2 1-1
Dear Mrs. Jewell:
RACINE OLSON NYE BUDGE & BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
www.radnelaw.net
SENDER'S E-MAIL ADDRESS: [e-mail]
April 20, 2012
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 300
BOISE, IDAHO $3702
TELEPHONE: [phone]
FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 107
POST OFFICE BOX 50688
IDAHO FALLS, ID $3405
TELEPHONE: [phone]
FACSIMILE, [phone]
ALL OFFICES TOLL FREE
(877) 232-6*01
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON, OF COUNSEL
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- Enclosed for filing in the captioned case please find the original and three copies of Idaho
Irrigation Pumpers Association, Inc. '5 SecondData Requests to Idaho Power Company. Thank you
for your assistance.
ERIC L.OLSE
ELO:t!
Enclosures
cc: Service List (Via Email)
Eric L. Olsen ISB# 4811 RECEIVED
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED 2012 APR 23 AM 8 147
P.O. Box 1391; 201 E. Center 1DAH0 PUBLiC Pocatello, Idaho 83204-1391 [JTILmr:S C01 MSS0C4
Telephone: [phone]
Fax: [phone]
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR )
AUTHORITY TO INCREASE ITS RATES )
AND RATE BASE TO RECOVER ITS )
INVESTMENT IN THE LANGLEY )
GULCH POWER PLANT )
)
CASE NO. IPC-E-12-14
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD
DATA REQUEST TO IDAHO
POWER COMPANY
13. Attachment 1 to ICIP Request 2 at Tab "Fuel Inputs" lists for the Henry Hub a price of
$5.79 and for Danskin a price of $5.50. Given that natural gas prices at Henry Hub are
running less than $2.00, please answer the following:
a.What price of natural gas is the company using for its present, internal,
planning purposes?
b.What price does the company plan to pay for natural gas this summer?
c.What price does the Company plan to pay for natural gas next winter?
d.It is assumed that the prices for natural gas listed in a-c above, as well as the
$5.79 and the $5.50 values, were all for the price of the commodity and did
not include a delivery charge. If this assumption is incorrect, please clarify.
e.Please provide the outputs for each year as well as the summary sheet from
an Aurora run that is the same as generally described in the Response to
ICIP Request 2, except using the Company's present assumptions for the
price of natural gas. Please provide a copy of this output in Excel format.
f.If the Company's present assumptions for the price of natural gas at Henry
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD
DATA REQUESTS TO IDAHO POWER COMPANY
g. Hub are greater than $2.00, then also provide an Aurora run using the price
of $2.00 for natural gas. Please provide a copy of this output in Excel
format.
14. Attachment 1 to ICIP Request 2 at Tab "Portfolio Contracts" lists Montana PPL as the
only contract and it is/was scheduled to have already terminated. Please answer the
following:
a.Has this contract terminated or has it been extended in some way?
b.If there is a contract in place that provides some level of firm energy/demand on a
going forward basis, please provide the relevant terms similar to those found in
Attachment 1 to ICIP Request 2 at Tab "Portfolio Contracts".
1 5. Attachment 1 to ICIP Request 2 at Tab "PPA" lists two wind projects; Elkhorn Wind and
Raft River.
a.Were these the only wind project contained in this run of the Aurora model? If
not, please explain.
b.Please update Attachment I to ICIP Request 2 at Tab "PPA" for all wind projects
that are expected to be operational by the end of 2012.
16. Please provide the outputs for each year as well as the summary sheet from an
Aurora run that updates all inputs for conditions as they are expected to exist at the
end of 2012. Please provide a copy of this output in Excel format. Please provide a
copy of these updated input assumptions similar to those provided in Attachment 1
to ICIP Request 2.
17. Please provide in a: manner similar to Company Exhibit 26 in Case No. IPC-E-11-
08, the actual 2011 values. These values should include all similar
assumptions/adjustment that were originally incorporated in Exhibit 26.
18. Over the last several years, there have been times when Idaho Power has either sold
or purchased electricity at a negative price.
a.During the hours when purchases are being made at a negative price, what
are generally the Company resources that are being backed-down?
b.During the hours when sales are being made at a negative price, what are
generally the resources that are have been backed-down to a minimum and
what resources are completely off?
c.Do the present runs of the Aurora model ever develop similar times of
negative pricing as have been occurring in the market? If not, why not?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD
DATA REQUESTS TO IDAHO POWER COMPANY 2
d.Under what conditions would the Aurora model produce similar times of
negative pricing as have been occurring in the market?
e.During times of negative pricing in the market, what steps has the Company
taken to reduce costs by completely or partially shutting-off units? Please
provide a detailed explanation.
19. Please provide from June 2011 through the most recent data available, hourly
data similar to that provided in response to Irrigator Request 8 in Case IPC-E-
11-08.
DATED this 20th day of April, 2012.
RACINE OLSON NYE BUDGE
& BAILEY, CHARTERED
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD
DATA REQUESTS TO IDAHO POWER COMPANY 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 2Wh day of April, 2012, 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, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
472 WI Washington Street
Boise, Idaho 83720-0074
[e-mail]
Lisa D. Nordstrom
Julia A. Hilton
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0072
[e-mail]
ihilton(idahopower.com
Greg W. Said
Courtney Waites
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0071
gsaid(äidahpower.com
[e-mail]
[e-mail]
Donald L. Howell, II
Karl Klein
Deputy Attorneys General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Don.howell(puc.idaho.gov
Karl.klein(puc.idaho.gov
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD
DATA REQUESTS TO IDAHO POWER COMPANY 4
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary
P0 Box 7218
Boise, ID 83702
[e-mail]
gregrichardsonandoleary.com
Don Reading
6070 Hill Road
Boise, ID 83703
dreading(mindspring.com
Thorvald a. Nelson
Frederick J. Schmidt
Sara K. Rundell
Holland & Hart, LLP
6380 S. Fiddlers Green Circle, Ste 500
Greenwood Village, CO 80111
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Richard E. Malmgren
Micron Technology, Inc.
800 S. Federal Way
Boise, ID 83716
remalthgrenmicron.com
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
[e-mail]
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD
DATA REQUESTS TO IDAHO POWER COMPANY