The URL can be used to link to this page

Home My WebLink About20130621IIPA 1-4 to IPC.pdfLA\/v OFFICES OF RACINE OLSON NYE BUDGE CHARTERED 20I EAST CENTER STREET POST OFFTCE BOX r39t POCATELLO, TDAHO 432()4-t 39t TELEPHONE (2Oa) 232-6t Ot FACS|MtLE (2Oa) 232-6 r 09 www.racinelaw.net sEN DER's E-MArL AoDREss: 9!9@b9!!W! June 19,2013 & BAILEY lY. 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. LEr,vIS ERIC L. OLSEN CONRAD J. AIKEN RICHAROA. 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 CANOICE 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 @IOI 3OUTH CAPITOL BOULEVARD, SUITE 3OOlol3E, IDAHO 13702 TILEPHONE: (2Oa) 393-ml I FAC3IMILE: (2Ol) 433-0167 !-@477 3HOUP AVENUESU|TE t 07 PO3T OFFTCE IOX tOrga IDAHO FALLs, ID A3'O5 TELEPHONE: (2Ot) 52t-alOl FAC8IMILE: (2Oa) 524-al09 &@(477) 242-ar Or LOU|3 F. RACTNE (rer7-2@5) WLLIAT D. OL$N, OF COUN3EL Jean J. Jewell, Secretary Idaho Public Utilities Commission P.O. Box 83720 Boise, Idatro 83720-0084 Re: Dear Mrs. Jewell: Case No. IPC-E-|3-14 Enclosed for filing in the captioned case please find the original and seven copies of IDAIIO IRRIGATION PUMPERS ASSOCIATION,INC.'S FIRST DATA REQUEST TO IDAIIO POWER COMPAI{Y. Thank you for your assistance. ELO:tjl Enclosuresc: Service List (Via Email) Eric L. Olsen (ISB#: 481l) RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 Pocatello, Idaho 83204-1391 Telephone : (208)232-61 0l Fax: (208)232-6109 Email: elo@racinelaw.com Attorneys for the ldaho Irrigation Pumpers Association, Inc. IN THE MATTER OF THE CONTINUATION OF IDAHO POWER COMPANY'S A/C COOL CREDIT, IRRIGATION PEAK REWARDS, AND FLEXPEAK DEMAI\D RESPONSE PROGRAMS FOR 2014 AND BEYOND j"'1 r-- .-. . -j-:-i. ' ?fl i -- tl :rr ,: r,_.-,. +.:_.;I t"_ i : '.'.,^ '." - j; '" ':i,:1j- '.. CASE NO.IPC-E-13.14 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO rDAHO POWER COMPAI{Y ;'ii i;: 5; BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION 1. Please provide the following information for each gas fired unit (not by facility) in the Company's generation resource mix: A. The name plate rating of the unit. G. The net 60-minute demand on the unit during the summer of 2012- The date and time of the maximum net 60-minute demand on the unit during the summer of2012. Total cost of the unit. Net non-depreciated value of the unit. Average cost (commodity and delivery) of fuel bumed during the summer of 2012 (in $a4MBTU). Fuel cost ($) of plant start-up and shut-down, based upon average cost of fuel bumed during the summer of 2012. H. Incremental costs of starting-up or shutting-down for expenses other than fuel. IDAIIO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPAIIY B. C. D. E. F. I.Average cost ($/kWh) of fuel per kWh generated during the summer of 2012. MWH per day used for plant purposes. K. Gross and net MWH per day generated during each day of the summer of 2012. 2. Please answer the following questions regarding the operation of the Company's gas fired units on August 4,2012 during the hours ending 1600 thru 1900: J. A.There were four Real Time purchases during these hours that resulted in 75 MW being purchased each hour at $30/N4WH. Was there more power generally available in the market than what the Company purchased? Is so, how much and at what price? Where were these purchases made and how did they get to the Idaho Power system? Did transmission constraints limit the amount of RT purchases during these hours? Why didn't the Company purchase more power at $3O/IvIWH, instead of operating all of its gas fired generation units? B. C. D. E. There were two Day Ahead purchases of 25 MW's each for the on-peak hours at a rate of $26 per MWH. Why didn't the Company buy more of this day ahead power at this price, as opposed to running its gas fired units? 3. Please answer the following questions regarding the operation of the Company's gas fired units on August 6,2012 during the hours ending 1200 thru 2100: A. There were five Real Time purchases during these hours that resulted in 50-100 MW being purchased each hour at rates between $30/lvIWH and $58/IvIWH. Was there more power generally available in the market than what the Company purchased? If so, how much and at what price? Where were these purchases made and how did they get to the Idatro Power system? Did transmission constraints limit the amount of RT purchases during these hours? Why didn't the Company purchase more power at $30ilvIWH to $57lIvIWH, instead of operating all of its gas fired generation units? IDAHO IRRIGATTON PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPAI\IY B. C. D. E. There were four Day Ahead purchases of 25 MW's each for the on-peak hours at a rate of $28--29 per MWH. Why didn't the Company buy more of this day ahead power at this price, as opposed to running its gas fired units? 4. Please answer the following questions regarding the operation of the Company's gas fired units on August 7,2012 during the hours ending 1800 thru 2100: A. There were five Real Time purchases during these hours that resulted in 45-75 MW being purchased each hour at rates between $37A4WH and $45lIrrIWH. Was there more power generally available in the market than what the Company purchased? If so, how much and at what price? Where were these purchases made and how did they get to the Idaho Power system? Did transmission constraints limit the amount of RT purchases during these hours? Why didn't the Company purchase more power at $37l\zIWH to $45lIvIWH, instead of operating all of its gas fired generation units? There were two Day Ahead purchases of 25 MW and 40 MW respectively for the on- peak hours at arate of $32-35 per MWH respectively. Why didn't the Company buy more of this day ahead power at this price, as opposed to running its gas fired units B. C. D. E. DATED U" Pl Myof June, 2013.f---+- IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY RACINE OLSON NYE BUDGE CERTIFICATE OF SERVICE I HEREBY CERTIFY that on tfri, -dlday of June ,2Ol3I served a true, correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Third Data Request to Idaho Power Company to each of the following, via U.S. Mail or private courier, e-mail or hand delivery, as indicated below: 4.5. Mail/Postage Prepaid E-Mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid t-,--E-Mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid tzB-Mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid u.'E-Mail Facsimile Ovemight Mail Hand Delivered Jean D. Jewell, Secretary Idaho Public Utilities Commission P.O. Box 83720 472 W . Washington Street Boise, Idatro 837 20-007 4 ij ewell@puc. state.id.us Lisa D. Nordstrom Regulatory Dockets Idaho Power Company P.O. Box 70 Boise,lD 83707 lnordstrom@idahopower. com dockets@ idahopower. com Courtney Waites Tim Tatum Idaho Power Company P.O. Box 70 Boise,ID 83707 cwaites@idahopower. com ttatum@ idahopower. com Donald L. Howell,II Deputy Attorney General Idaho Public Utilities Commission 472 W . Washington (83702) P.O. Box 83720 Boise,lD 83720-0074 don.howell@Fuc.idaho. sov Benjamin J. Otto Idatro Conservation League 710 N Sixth Street Boise,ID 83702 botto@ idahoconservation.ore -u.S. Mail/Postage Prepaid--7p,-vuit Facsimile Ovemight Mail Hand Delivered IDAHO IRRIGATION PUMPERS ASSOCIATIONN INC''S FIRST DATA REQUEST TO IDAHO POWER COMPAI\IY Ken Miller Snake River Alliance P.O. Box l73l Boise,ID 83701 kmi ller@ snakeriveralliance.org Melanie Gillette Director, Regulatory Affairs EnerNOC,Inc. I l5 Hazelmere Drive Folsom, CA 95630 m gillette@enernoc. com Teresa A. Hill K&LGates,LLP 222 Cohxrbia Street, Su ite 1400 Portland, OR 97201 teresa.hill @kl gates. com Peter J. Richardson Richardson & O'Leary 515 N.27ft Street Boise,ID 83616 peter@richardsonandoleary.com Dr. Don Reading 6070 Hill Road Boise,ID 83703 dreadin e@.mindspring.com U. S. Mail/Postage Prepaid ',/E-INf.atl'--"--? Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid , - E-Mail -#-Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid ,,/E-Marl Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid v-E,-Matl Facsimile Overnight Mail Hand Delivered _ !.S. Mail/Postage Prepaid1e-uuit Facsimile Overnight Mail Hand Delivered IDAHO IRRIGATION PIIMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO rDAHO POWER COMPAI\IY