20131227IPC to Staff No.1.pdf

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Lead Counsel ‘;-
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December 23,2013
VIA HAND DELIVERY
Jean D.Jewell,Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise,Idaho 83702
Re:Case No.IPC-E-13-25
Schedule 86 Update —Idaho Power Company’s Response to the First
Production Request of the Commission Staff
Dear Ms.Jewell:
Enclosed for filing in the above matter are an original and three (3)copies of Idaho
Power Company’s Response to the First Production Request of the Commission Staff to
Idaho Power Company.
In addition,enclosed are four (4)copies of a confidential disk containing
information responsive to Staff’s Production Request No.1.Please handle the confidential
information in accordance with the Protective Agreement executed in this matter.
Sincerely,
Donovan E.Walker
DEW:csb
Enclosures
1221 W.Idaho St.(83702)
P.O.Box 70
Boise,ID 83707
DONOVAN E.WALKER (ISB No.5921)
JULIA A.HILTON(ISB No.7740)fl.‘—“r I’rIdahoPowerCompany
1221 West Idaho Street (83702)
P.O.Box 70
Boise,Idaho 83707
Telephone:[phone]
Facsimile:[phone]
dwalkeridahopower.com
jhilton(idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TARIFF ADVICE NO.)
13-05 OF IDAHO POWER COMPANY FOR )CASE NO.IPC-E-13-25
AUTHORITY TO UPDATE SCHEDULE 86.)
)IDAHO POWER COMPANY’S
)RESPONSE TO THE FIRST
)PRODUCTION REQUEST OF
)THE COMMISSION STAFF TO
)IDAHO POWER COMPANY
COMES NOW,Idaho Power Company (“Idaho Power”or “Company”),and in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated December 12,2013,herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -1
REQUEST NO.1:Please provide a copy of any analysis prepared by the
Company comparing the Dow Jones Mid-C Non-Firm Index to any other indexes,
including other indices produced by Dow Jones (e.g.,DJ Firm Index),Plaffs,
Intercontinental Exchange (ICE),NYMEX,and Powerdex.Please provide a full
descriptive name for each index and a brief description of the index (e.g.,firm,non-firm,
day-ahead,real-time,hourly,daily,historic,etc.).Along with the analysis,please
provide all data used in performing the analysis.Please provide the data and analysis
in an electronic Excel format with all formulas intact.
RESPONSE TO REQUEST NO.1:Idaho Power has been unable to find any
reported Mid-C non-firm index except for the Dow Jones/Platts Mid-C non-firm index.
In 2012,Idaho Power did a comparison of the ICE reported Mid-C firm prices with the
Dow Jones/Platts reported Mid-C non-firm prices.This comparison is provided on the
confidential CD.The confidential CD will be provided to those parties that have
executed the Protective Agreement in this mailer.Idaho Power found that there was
not a consistent identifiable relationship between the firm ICE index and the non-firm
Dow Jones index.
In July 2012,Idaho Power subscribed to the Powerdex,Inc.(“Powerdex”)Mid-C
index service and reviewed the definition of its various indexes.Powerdex does not
offer a non-firm index.One index it does offer is an hourly firm index.This hourly firm
index includes the high,low,and volumetrically-weighted average prices of the reported
actual firm energy transactions in each hour,along with the total volume done for that
hour.The energy product being bought and sold is a firm energy product for the given
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -2
hour.As the Powerdex index is an ‘hourly firm”price,just as in the case of the ICE firm
index,it is not a true non-firm index value.
The response to this Request is sponsored by Michael Darrington,Senior Energy
Contracts Coordinator,in consultation with Donovan E.Walker,Lead Counsel,Idaho
Power.
DATED at Boise,Idaho,this 23td day of December 2013.
OVAN E.WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23(1 day of December 2013 I served a true and
correct copy of IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below,and
addressed to the following:
Commission Staff X Hand Delivered
Kristine A.Sasser
____U.S.
Mail
Deputy Attorney General
____Overnight
Mail
Idaho Public Utilities Commission
____FAX
472 West Washington (83702)X Email kris.sasser(äpuc.idaho.qov
P.O.Box 83720
Boise,Idaho 83720-0074
Ck\A&k iQoChristaBearry,Legal AssistãiIr
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -4