20130710IPC to IIPA.pdf

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An IDACORP Company
JULIAA. HILTON
Corporate Gounsel
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July 10,2013
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VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-14
Continuation of Demand Response Programs - ldaho Power Company's
Response to the ldaho Inigation Pumpers Association, lnc.'s, First Data
Request to ldaho Power Company
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to the ldaho lrrigation Pumpers Association, lnc.'s, ("llPA")
First Data Request to Idaho Power Company. Also, enclosed are an original and three (3)
copies of ldaho Power Company's confidential Response to llPAs First Data Request to
ldaho Power Company.
ln addition, enclosed are four (4) copies of a non-confidential disk containing data
responsive to llPAs Data Request No. 1.J and 1.K.
Very truly yours,
JAH:evp
Enclosures
1221 W ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
JULIA A. HILTON (lSB No. 7740)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
I no rd [e-mail]
Attorneys for ldaho Power Company
IN THE MATTER OF THE
CONTINUATION OF IDAHO POWER
COMPANY'S A/C COOL CREDIT,
IRRIGATION PEAK REWARDS, AND
FLEXPEAK DEMAND RESPONSE
PROGRAMS FOR 2014 AND BEYOND
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. !PC-E-13-14
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
!RRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST
DATA REQUEST TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("ldaho Powe/' or "Company"), and in
response to the ldaho lrrigation Pumpers Association, lnc.'s, First Data Request to
ldaho Power Company dated June 19,2013, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGAT]ON PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 1
REQUEST NO. 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.
B. The net 60-minute demand on the unit during the summ er of 2012.
C. The date and time of the maximum net 60-minute demand on the unit
during the summer ol2012.
D. Total cost of the unit.
E. Net non-depreciated value of the unit.
F. Average cost (commodity and delivery) of fuel burned during the summer
of 2012 (in $/MMBTU).
G. Fuel cost ($) of plant start-up and shut-down, based upon average cost of
fuel burned during the summer of 2012.
H. lncremental costs of starting-up or shutting-down for expenses other than
fuel.
L Average cost ($/kwh) of fuel per kWh generated during the summer of
2012.
J. MWH per day used for plant purposes.
K. Gross and net MWH per day generated during each day of the summer of
2012.
RESPONSE TO REQUEST NO. 1:
A. Please see the table below.
Unit
Danskin 1
Danskin 2
Generator Nameplate Gross kW
179,100
45,900
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 2
Facilitv
Danskin
Langley Gulch
Danskin 3
Bennett Mountain
Langley Gulch
Dates
612212012
611612012
611912012
Time
Hr ending 20
Hr ending 11
Hr ending 20
Hr ending 8
Meqawatt
("MW")
251
167
167
311
45,900
172,800
318,452
B. Idaho Power does not track production values by individual gas-fired unit.
However, can provide daily production values for each gas plant facility (please see
ldaho Power's Response to 1.J).
C. ldaho Power does not track production values by individual gas-fired unit.
However, the date and time of maximum plant output during the summer of 2012 is
included in the table below.
Bennett Mountain 61812012
D. The response to this request is confidential and will be provided to those
parties that have executed the Protective Agreement in this proceeding.
E. The response to this request is confidential and will be provided to those
parties that have executed the Protective Agreement in this proceeding.
F. The response to this request is confidential and wil! be provided to those
parties that have executed the Protective Agreement in this proceeding.
G. ldaho Power does not distinguish between fuel costs for plant start-up and
shut-down versus other modes of operation in its financial records. Please see ldaho
Powe/s Response to the ldaho lrrigation Pumpers Association, Inc.'s, Request No. 1.1.
H. ldaho Power does not distinguish between operating costs for plant start-
up and shut-down versus other modes of operation in its financial records.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 3
L The response to this request is confidential and will be provided to those
parties that have executed the Protective Agreement in this proceeding.
J. Please see the attached Excel file.
K. Please see the attached Excel file.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 4
REQUEST NO. 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:
A. There were four Real Time purchases during these hours that resulted in
75 MW being purchased each hour at $30/MWH. Was there more power generally
available in the market than what the Company purchased? ls [sic/ so, how much and
at what price?
B. Where were these purchases made and how did they get to the Idaho
Power system?
C. Did transmission constraints limit the amount of RT purchases during
these hours?
D. Why didn't the Company purchase more power at $30/MWH, instead of
operating all of its gas fired generation units?
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?
RESPONSE TO REQUEST NO. 2:
A. ldaho Power does not maintain data regarding the availability of power in
the RealTime Market.
B. The energy was purchased at the AVA.BPAT Point-of-Receipt and an
AvistaMWP third-party wheel was purchased to get the energy from the AVA.BPAT to
LOLO. The Company then provided its own wheeling from LOLO to its system.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 5
C. Transmission constraints did not Iimit the amount of Real Time purchases
during these hours.
D. ldaho Power dispatched the gas fired units because the dispatch costs of
these units were below the delivered cost of any additional power available for purchase
at the time.
E. The Langley Gulch and Danskin No. 1 units were prescheduled because
the dispatch cost was less than the delivered cost of power for the time period in
question. These dispatch decisions are based on the time frame for which the power is
needed and the total cost of dispatch for the resource during the entire heavy load
period the gas units were dispatched. Running the gas units allows the operators
flexibility to run the units for a select few hours to cover the peak.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 6
REQUEST NO. 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 21OO:
A. There were five Real Time purchases during these hours that resulted in
50-100 MW being purchased each hour at rates between $30/MWH and $58/MWH.
Was there more power generally available in the market than what the Company
purchased? lf so, how much and at what price?
B. Where were these purchases made and how did they get to the ldaho
Power system?
C. Did transmission constraints limit the amount of RT purchases during
these hours?
D. Why didn't the Company purchase more power at $30/MWH to $57IMWH,
instead of operating all of its gas fired generation units?
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?
RESPONSE TO REQUEST NO. 3:
A. ldaho Power does not maintain data regarding the availability of power in
the RealTime Market.
B. The Company purchased transactions HE 14 thru 16 for 75 megawatt-
hours ('MWh') at Borah, transaction HE 18 for 100 MWh's at McNary, transaction HE
19 for 75 MWh's at MCNary and 100 MWh's at Borah and transaction HE 20 for 50
MWh's at McNary. The energy at Borah was delivered to the Company's border with
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 7
the Company wheeling the energy to its system to serve load. A!! energy purchased at
McNary required third-party wheeling through PacifiCorp from McNary to Enterprise
(ENPR), where the Company wheeled the energy to its system to serve load.
C. Transmission constraints did not limit the amount of Real Time purchases
during these hours.
D. The Langley Gulch and Danskin No. 1 units were prescheduled and the
Danskin Nos. 2 and 3 units were dispatched in rea! time. The Company purchased all
the energy available at a price below the cost to dispatch these units, then dispatched
them when this energy was exhausted.
E. Langley Gulch and Danskin No.1 were dispatched to serve load along with
the energy purchases. Additional energy was not purchased on a day-ahead basis
because the cost to import the energy, including third-party transmission costs, would
have been higher than the cost of running the Danskin No. 1 unit. These purchases,
however, were cheaper than the dispatch cost of Danskin Nos. 2 and 3.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 8
REQUEST NO. 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 21OO:
A. There were five Rea! Time purchases during these hours that resulted in
45-75 MW being purchased each hour at rates between $37IMWH and $45/MWH. Was
there more power generally available in the market than what the Company purchased?
If so, how much and at what price?
B. Where were these purchases made and how did they get to the ldaho
Power system?
C. Did transmission constraints limit the amount of RT purchases during
these hours?
D. Why didn't the Company purchase more power at $37IMWH to $45/MWH,
instead of operating all of its gas fired generation units?
E. There were two Day Ahead purchases ol25 MW and 40 MW respectively
for the on-peak hours at a rate 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.
RESPONSE TO REQUEST NO. 4:
A. ldaho Power does not maintain data regarding the availability of power in
the RealTime Market.
B. The energy purchased at La Grand Bonneville Power (LGBP) was
delivered to the Company's border and then wheeled by the Company to its system for
load service. The energy purchased at the other points required third-party wheeling to
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 9
the Company's border and then the Company wheeled the energy to its system to serve
load.
C. Transmission constraints did not limit the amount of Real Time purchases
during these hours.
D. The Company had purchased all the energy that was available in the
market at a price below the dispatch price of Danskin Nos. 2 and 3. ln addition, the
Company had dispatched all its available gas units and still needed additional energy to
serve its load. As a result, the Company acquired additional energy from the market to
fulfill its needs at a cost exceeding the dispatch price of Danskin Nos. 2 and 3. During
this same timeframe Danskin No. 2 was unavailable and did not get dispatched in real
time.
E. The Company dispatched Langley Gulch, Danskin No. 1, and Bennett
Mountain on day ahead. These units were dispatched because their dispatch cost was
less than the cost of purchasing from the market. Additional energy was needed to
serve load so the Company made purchases from the market because it was cheaper
than dispatching Danskin Nos. 2 or 3.
DATED at Boise, Idaho, this lOth day of July 2013.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 1O
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1Oth day of July 2013 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Gommission Staff
Kar! T. Klein
Deputy Attomey General
Idaho Public Utillties Commission
47 2 W estWashington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, ldaho 83204-1 391
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Snake River Alliance
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
X Hand Delivered_U.S. Mail
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_FAXX Email tonv@vanke!.net
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Email [e-mail]
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IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 11
lndustrial Gustomers of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
EnerNOG, lnc.
Teresa A. Hill
K&L GATES, LLP
222 Columbia Street, Suite 1400
Portland, Oregon 97201
Melanie Gillette, Director Regulatory Affairs
EnerNOC, Inc.
115 Hazelmere Drive
Folsom, Califomia 95630
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FAXX Email oete r@ richa rd so nad a m s. co m
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FAXX Email [e-mail]
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Ovemight Mail
FAX
Email teresa.hi!!@kloates.com
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U.S. Mai!
Ovemight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S, FIRST DATA REQUEST TO IDAHO POWER COMPANY - 12
CERTIFICATE OF ATTORNEY .'.:..:'i..:.-:
ASSERT.N rHAr MATERTALS RE.,ESTED AND pRouDE#HuAlritrti t+' l+5
couRSE oF AN IDAHO PUBLTC UTtLtTtES COMMTSSTON PROCFEDING , i
ARE PROTECTED FROM PUBLIC INSPECTIONi,l'Iii iiiJ-'- ,
Gase No. IPC-E-13-14
The undersigned attorney, in accordance with RP 233, hereby certifies that the
responses provided in ldaho Power Company's response to the ldaho lrrigation
Pumpers Association, lnc.'s Data Request No. 1.D, 1.E, 1.F, and 1.1 contain information
that is a trade secret or privileged or confidential as described in ldaho Code $ 9-340, ef
seg., and S 48-801, ef seg., and as such are exempt from public inspection,
examination, or copying.
DATED this lOth day of July 2013.
Counselfor ldaho Power Company