20140116Simplot 1-6 to IPC.pdf

Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27ft Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
Peter@rishardsonadamt..t,,,
gre g@richardsonadams. com
Attorneys for the J. R. Simplot Company
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CASE NO. IPC.E.13-21
FIRST PRODUCTION REQUESTS
OF THE J. R. SIMPLOT COMPANY
TO IDAHO POWER COMPANY
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER THE APPLICATION OF )IDAHO POWER COMPANY FOR )APPROVAL OF SARMETHODOLOGY )
)
)
)
)
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), J.R. Simplot Company hereby requests that Idaho Power Company ("Idaho
Power" or "Company") provide responses to the following with supporting documents, where
applicable, as soon as possible, but no later than February 5r2014.
This production request is to be considered as continuing, and ldaho Power is requested
to provide by way of supplementary responses additional documents that it or any person acting
on its behalf may later obtain that will augment the responses or documents produced.
Please provide physical copies of your responses, and electronic copies, if available, to
Mr. Adams at the address noted above, and to Dr. Don Reading at6070 Hill Road, Boise, Idaho
83703, [e-mail] . Please begin each response on a separate page and provide
FrRST PRODUCTTON REQUEST OF J.R. STMPLOT CO.
CASE NO. IPC-E-13.21
PAGE I
page numbers on responses longer than one page.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REQUEST X'OR PRODUCTION NO. l:
Please provide, in electronic format where possible with formulas intact the models and
spreadsheets that were used to produce Table 2,page 3 of the Application in this docket (IPC-E-
13-2t).
REQUEST FOR PRODUCTTON NO. 2:
Please provide, in electronic format where possible and with formulas intact, the models and
spreadsheets that were used to produce Table 3, page 4 of the Application in this docket (IPC-E-
t3-2r).
REQUEST FOR PRODUCTTON NO. 3:
Please provide on an annual basis for the years 2013 through2020,the expected MW reduction
in peak and projected cost of each of the Company's demand response progftlms (A/C Cool
Credit,Inigation Peak Rewards, FlexPeak Management) used to find the peak-hour surpluses
displayed in Table 3, page 4 of the Application in this docket (IPC-E-l3-21). Please display the
projections for each progftrm separately.
REQUEST X'OR PRODUCTION NO. 4:
Refer to Idaho Power's 2013 IRP atp.40, stating:
Figure 4.3 shows the annual demand response program capacity between 2004 and 2012.
The large jump in demand response capacity from 61 MW in 2008 to 218 MW in 2009
was a result of transitioning the majority of the Irrigation Peak Rewards program to a
dispatch program. The demand response capacrty in 201I and2012 included 320 and 340
MW of capacity from the Inigation Peak Rewards program, respectively, which was not
used based on the lack of need and the cost to dispatch.
FrRST PRODUCTION REQUEST OF J.R. STMPLOT CO.
CASE NO. IPC.E-13-21
PAGE 2
a. Please provide the percentage of overall demand response capacity and the amount in
MW reduction in peak that "was not used based on the lack of need and the cost to dispatch," as
noted in the above passage from the IRP.
b. Please provide the annual demand response capacity (MW) of Idaho Power's lrrigation
Peak Rewards progftrm that was assumed to derive the peak-hour surpluses displayed in Table 3,
page 4 of the Application in this docket (IPC-E-13-21).
c. For the figures supplied in subpart b. regarding the Irrigation Peak Rewards for the years
2013 through2033, does the Company expect there will be any change in the demand response
capacity (MW) that will not be use based on oothe lack of need and the cost to dispatch"? [f so,
please provide the change in percentage for each year for the years 2013 through 2033.
REQUEST FOR PRODUCTTON NO.5:
Refer to Table 3, page 4 of the Application in this docket (IPC-E-13-21).
Please provide the assumed on-line date for the Boardman to Hemingway transmission
line for purposes of producing this table.
b. Please provide the current expected on-line date of the Boardman to Hemingway
transmission line and identifu the source of the current projection.
c. If the on-line date Boardman to Hemingway transmission line is delayed beyond current
expected on-line date, how does the Company expect to meet the peak-hour deficits that would
occur due to the delay?
REQUEST FOR PRODUCTTON NO. 6:
Assuming the Commission accepts the peak-hour deficits filed by Idaho Power in this docket and
using the currently approved inputs for all other variables, please provide the levelized and non-
FrRST PRODUCTION REQUEST OF J.R. STMPLOT CO.
CASE NO. IPC-E-13-21
PAGE 3
levelized avoided costs rates for contract lengths I through 20 years for:
Wind projects (100 kW or smaller),
Solar projects (100 kW or smaller),
Non-Seasonal Hydro projects (smaller than 10 aMW),
Seasonal Hydro projects (smaller than l0 aMW),
Other projects (smaller than l0 aMW)
DATED this 15th day of January,zll4.
RICHARDSON ADAMS, PLLC
FIRST PRODUCTION REQUEST OF J.R. SIMPLOT CO.
CASE NO. IPC.E-13-21
PAGE 4
a.
b.
c.
d.
e.
Of Attorneys for the J.R. Simplot Co.
CERTIF'ICATE OF SERVICE
I HEREBY CERTIFY that on the l5th day of January,2014, a tnre and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST BY THE J. R. SIMPLOT
COMPANY , Case No. IPC-E-13-21, was served by electronic mail and U.S. Mail, postage
prepaid, to:
Donovan Walker
Idaho Power Company
l22l West ldatro Street (83702)
PO Box 70
Boise, Idalro 83707 -0070
E-mail: [e-mail]
dockets @ idatropower. com
Randy Allphin
Tess Park
Idaho Power Company
1221 West Idatro Street (83702)
PO Box 70
Boise, Idaho 83707-0070
E-mail : [e-mail]
tpark2 @idahopower. com
Jean Jewell, Secretary
Idaho Public Utilities Commission
472West Washington
Boise,lD 83702
[e-mail]. gov
Or,.*(Lx<r:
Nina Curtis
Legal Assistant
FIRST PRODUCTTON REQUEST OF J.R. SIMPLOT CO.
CASE NO. IPC-E-13.21
PAGE 5