20120511IPC to IIPA 13-19.pdf

IDAHO
90POMIZe RECEIVE An IDACORP Company
LISA D. NORDSTROM
Lead Counsel UTILT1ES
Inordstrom(idahoDower.com Ikk
May 11, 2012
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-12-14
Langley Gulch Recovery - Response to the Idaho Irrigation Pumpers
Association, Inc.'s Third Data Request
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") Third
Data Request to Idaho Power Company in the above matter.
Also, enclosed in a separate envelope are four (4) copies of a confidential
document provided in response to a portion of IIPA's Request No. 13.
Lastly, enclosed are four (4) copies each of non-confidential and confidential disks
containing information being produced in response to IIPA's Third Data Request.
Please handle the enclosed confidential information in accordance with the
Protective Agreement executed in this matter.
Very truly yours,
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (ISB No. 5733)
JULIA A. HILTON (ISB No. 7740)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstrom(äidahopower.com
jhiIton(äidahopower.com
RECEIVED
7012 MAY I I PM 4: 48
DAHOELL
I OMISS1C'
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND ITS RATE BASE TO RECOVER ITS
INVESTMENT IN THE LANGLEY GULCH
POWER PLANT.
CASE NO. IPC-E-12-14
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD
DATA REQUEST TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Idaho Irrigation Pumpers Association, Inc.'s Third Data Request to
Idaho Power Company dated April 20, 2012, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -1
REQUEST NO. 13: Attachment I 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
g.[sic] 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.
RESPONSE TO REQUEST NO. 13: The Company's responses to paragraphs
a-d of this Request are confidential and will be provided separately. The confidential
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -2
response will be provided to those parties that have executed the Protective Agreement
in this matter.
e.Please see the attached Excel file (Attachment 1) containing the AURORA
output, which was calculated based upon the inputs used in Case No. IPC-E-10-01,
which established the Company's current base level power supply expenses, updated
with natural gas prices that are used in the Company's most current Operations Plan.
f.Please see the attached Excel file (Attachment 2) containing the AURORA
output, which was calculated based upon the inputs used in Case No. IPC-E-10-01,
which established the Company's current base level power supply expenses, updated
with a $2.00 Henry Hub natural gas price that was specified in the Request.
The response to this Request was prepared by Michael Polito, Power Supply
Operations Manager, Idaho Power Company, and Scott Wright, Regulatory Analyst II,
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -3
REQUEST NO. 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 I to ICIP Request 2 at Tab
"Portfolio Contracts".
RESPONSE TO REQUEST NO. 14:
a.This contract has terminated and has not been extended.
b.Please see the attached Excel file.
The response to this Request was prepared by Mike Polito, Manager of Power
Supply Operations, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -4
REQUEST NO. 15: 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.
RESPONSE TO REQUEST NO. 15:
a.No. The Power Purchase Agreements ("PPA") for Elkhorn Wind and Raft
River were the Company's only two PPAs that the Company had during the 2010 test
period. Elkhorn Wind is a wind PPA, while Raft River is a geothermal PPA. The
Company's Public Utility Regulatory Policies Act of 1978 ("PURPA") wind is included in
the Company's response to the Industrial Customers of Idaho Power's ("ICIP") First
Request for Production No. 2, under the worksheet tab "PURPA".
b.Wind projects, with the exclusion of Elkhorn Wind are all considered
PURPA projects. Please see the Company's response to the Idaho Irrigation Pumpers
Association, Inc.'s ("IIPA") Request No. 16 below, located under the "PURPA"
worksheet for an updated PURPA forecast, which includes all PURPA projects that are
expected to be operational by the end of 2012.
The response to this Request was prepared by Scott Wright, Regulatory Analyst
II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -5
REQUEST NO. 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 I to ICIP Request 2.
RESPONSE TO REQUEST NO. 16: Please see the attached Excel file
(Attachment 1) containing the AURORA output for a 2012 test period analysis. Please
see the confidential Excel file (Attachment 2) provided on the confidential CD containing
the AURORA inputs that were used for the 2012 test period analysis. The confidential
CD will be provided to those parties that have executed the Protective Agreement in this
matter. Please note that the Aurora output net power supply expenses ("NPSE") were
calculated using the Company's expected generation capacity during 2012, including
generation from PURPA resources. However, the Aurora output NPSE does not
include the expenses associated with PURPA resources.
The response to this Request was prepared by Scott Wight, Regulatory Analyst
II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -6
REQUEST NO. 17: Please provide in a manner similar to Company Exhibit 26 in
Case No. IPC-E-1 1-08, the actual 2011 values. These values should include all similar
assumptions/adjustment that were originally incorporated in Exhibit 26
RESPONSE TO REQUEST NO. 17: Please see the attached Excel file that
contains a copy of the 2011 Jurisdictional Separation Study ("JSS"). The JSS is similar
to the Company's Exhibit No. 26 in Case No. IPC-E-11-08 but is based on actual 2011
values.
The response to this Request was prepared by Courtney Waites, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -7
REQUEST NO. 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?
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.
RESPONSE TO REQUEST NO. 18:
a.During times of low or negative market prices, typically all of the thermal
units would be either off or dispatched to minimum levels to maintain adequate
regulating margin for reliable operation of the system. Hydro generation would also be
backed down to minimum levels factoring in elevation targets for flood control and other
license requirements.
b.Idaho Power applies a dispatch procedure that is based on economics
which considers factors such as reliability and prices when planning generation dispatch
in the near, mid, and long term. Please see the Company's response to Request No.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -8
18.a. above regarding specific resource dispatch decisions during times of negative
prices. The Company's practice has been to avoid, when possible, sales transactions
at negative prices; however, there are rare instances when the Company has made
sales at negative prices for balance of power transactions.
C. No. The AURORA model is an economic dispatch model that balances
demand, supply, and transmission to forecast market prices. By balancing demand and
supply, excess generation that typically creates negative pricing does not occur;
therefore, negative market pricing does not occur in the model.
d.Please see the Company's response to Request No. 18.c. above.
e.Idaho Power economically dispatches its resources available to serve load
with consideration of factors such as system reliability and market prices. Idaho Power
considers factors such as reliability and prices when planning generation dispatch in the
near, mid, and long term. When possible, maintenance is scheduled to coincide with
months of least demand and lowest prices, typically the spring months.
Idaho Power has a partial ownership interest in three coal facilities: Jim Bridger,
Valmy, and Boardman. In each of these cases, there are partnership agreements that
limit Idaho Power's ability to reduce output from these plants below minimum levels
without agreement of the other owners. The decision to turn a coal unit off to avoid non-
peak pricing will typically make that unit unavailable during peak hours when prices may
be much higher, or when there is insufficient transmission to import energy to match
load requirements. Another factor to consider is that maintenance costs rise as coal
units are cycled up and down
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -9
Hydro generation may also be reduced to minimum levels during low price hours.
In doing so, issues such as target elevation levels for flood control, spill rates, and
license requirements must be considered.
Natural gas unit output may be reduced or dispatched to zero during low price
hours. Similar to coal units, but not to the same extent, cycling gas generation units in
this manner may impact availability during peak hours and also increase maintenance
costs.
The response to this Request was prepared by Michael Polito, Power Supply
Operations Manager, Idaho Power Company, and Scott Wright, Regulatory Analyst II,
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -10
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 19: This response refers to the following
subparts a-y contained in IIPA's Request No. 8 in Case No. IPC-E-1 1-08:
(a)Total system input;
(b)System input from Company owned generation (stating hydro, coal, and
other generation separately);
(c)System input from firm purchases, stating each purchase separately by
source and type of purchase (LF, IF, SF, etc.)
(d)The cost of each firm purchase listed in "c" above;
(e)System input from non-firm and/or economy purchases, stating each
purchase separately;
(f)The cost of each non-firm and/or economy purchase listed in "E" above;
(g)System input from exchanges into the system, stating each exchange
separately;
(h)System input from Unit purchases;
(i)Other system inputs, stating for each "other" input the type and the source
of the input;
(j)Jurisdictional (Idaho and Oregon) sales;
(k)System losses;
(I) Requirements Wholesale sales (RQ);
(m)Long-term firm Wholesale sales (LF), stating each on separately;
(n)Intermediate-term firm Wholesale sales (IF), stating each one separately;
(o)Short-term Wholesale sales (SF), stating each one separately;
(p)Unit sales, Wholesale (LU) or otherwise, stated separately;
(q)Non-firm and/or economy Wholesale sales (OS), stated separately;
(r)The revenue collected each hour from each non-firm and/or economy
purchased listed in "P" above.
(s)Exchanges out of the system, stating each exchange separately;
(t)Other system outputs, stating for each "other" output the type and
recipient of the output;
(u)Inadvertent power flows into or out of the system;
(v)The power available (at input level) to supply retail load once Wholesale,
Exchange, Wheeling, and Inadvertent has been subtracted;
(w)Losses assigned to each retail jurisdiction;
(x)Losses assigned to Wholesale sales;
(y)Total retail load by jurisdiction.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -11
a-k and rn-v. Please see the attached Excel file (Attachment 1). To use
the Excel file to view the various data associated with the above-listed subparts, utilize
columns A-Q and the drop down menus found on line 6. For instance, clicking on the
arrow on line 6 of column A will show the drop down menu for inputs asked for in
subpart (a). To view the inputs, check only the box by "inputs" from the menu. This
selection will bring up the hourly data starting in column Y. For requests related to
pricing, such as in subpart (d), the total cost is in column V and total megawatts in
column T.
The data requested in subpart (r) is unavailable on an hourly basis.
This portion of the response to the Request was prepared by Nancy
Grzadzieleski, Accountant II, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
1. Please see the confidential Excel file (Attachment 2) containing hourly
wholesale sales data fOr June 1, 2011, through September 30, 2011, provided on the
confidential CD. As of October 1, 2011, the wholesale customer is no longer a
Company customer.
W.Hourly losses assigned to each retail jurisdiction are not available. Loss
factors for peak demand and energy by voltage for each jurisdiction are contained in the
"RefTables" tab of the confidential Excel file (Attachment 3) provided on the confidential
CD. These are system loss factors by voltage level and are not calculated on an hourly
basis.
X.Hourly losses assigned to wholesale sales are not available. Loss factors
for peak demand and energy by voltage are contained in the "Reflables" tab of the
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -12
confidential Excel file (Attachment 3) provided on the confidential CD. These are
system loss factors by voltage level and are not calculated on an hourly basis.
Hourly retail load by jurisdiction is not available. Please see the
confidential Excel file (Attachment 3) containing the monthly unadjusted energy and
coincident demand information for 2011 with and without losses. Historical monthly
information for 2012 is not finalized until the completion of the January through
December calendar year, and a forecast of 2012 information is not available at this time;
therefore, data has only been provided through December 2011.
Please note the data provided in this response is not comparable to the monthly
energy and coincident demand information provided for the 2011 test year utilized in the
Company's last general rate case, Case No. IPC-E-1 1-08 ("2011 Rate Case"). The
2011 Rate Case utilized forecasted weather normalized usage that had been adjusted
for cost allocation purposes, while the data provided herein is based on unadjusted
actual historical load research data.
All above-referenced confidential Excel files contained on the confidential CD will
be provided to those parties that have executed the Protective Agreement in this matter.
This portion of the response to this Request was prepared by Mary Graesch,
Load Research Leader, Idaho Power Company, in consultation with Mall Larkin,
Regulatory Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
DATED at Boise, Idaho, this 1 1 th day of May 2012.
/
tfSA D. NORDSflOM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -13
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11 th day of May 2012 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Donald L. Howell, II
Karl T. Klein
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hill Road
Boise, Idaho 83703
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
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IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -14
Micron Technology, Inc.
Thorvald A. Nelson
Frederick J. Schmidt
Sara K. Rundell
HOLLAND & HART, LLP
6380 South Fiddlers Green Circle, Suite 500
Greenwood Village, Colorado 80111
Richard E. Malmgren
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Micron Technology, Inc.
800 South Federal Way
Boise, Idaho 83716
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ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY -15