20140210Simplot 1-15 to IPC.pdf

Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
Peter@richardsonadarrt..o*
gre g@richardsonadams. com
Attorneys for the J. R. Simplot Company
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMTSSION
IN THE MATTER OF TARIFF ADVICE NO. )
13-05 oF rDAHO POWER COMPANY FOR ) CASE NO. IPC-E-13-25
AUTHORITY TO UPDATE SCHEDULE 86. )) FIRST PRODUCTION REQUESTS
) oF THE J. R. STMPLOT COMPANY
) TO IDAHO POWER COMPANY
)
)
Pursuant to Rule 225 of the Rules of Procedure of the ldaho 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 March 312014.
This production request is to be considered as continuing, and Idaho 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. Please begin each response on a separate page and
provide page numbers on responses longer than one page.
rPC-E-13-25
FIRST PRODUCTION REQUEST
PAGE I
. 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 FOR PRODUCTTON NO. 1:
Reference the tariff application, stating:
In addition, this tariff advice adds the word "volume" before the words "weighted
average" to provide additional clarity. This calculation has always used the
volume-weighted average of the daily on-peak and off-peak Mid-C Index prices
for non-firm energy to determine the Avoided Energy Cost. This tariff advice
clarifies that the weighted average used to determine the Avoided Energy Cost is
the volume-weighted average and inserts the term "volume" before "weighted
average" to add clarity to Schedule 86.
Please explain in detail Idatro Power's methodology for volume weighting described in the
quoted passage. Specifically, describe the steps Idatro Power follows to use the data provided by
the index to calculate the market energy price used for the Avoided Energy Cost. Please provide
an example of the calculation for a month by also providing the documents provided to Idatro
Power by the index for that month.
REQUEST FOR PRODUCTION NO. 2:
Please explain whether the Dow Jones Index has provided a volume with the non-firm Mid-C
index at all times since the IPUC approved use of the Dow Jones Index in Schedule 86 in 1999 in
Order No. 28033. If Dow Jones did not always provide a volume with the non-firm index prices
for Mid-C, please provide the date that Dow Jones began providing a volume.
REQUEST FOR PRODUCTTON NO. 3:
Reference the tariff application, stating:
ln addition, this tariff advice adds the word "volume" before the words "weighted
average" to provide additional clarity. This calculation has always used the
volume-weighted average of the daily on-peak and off-peak Mid-C lndex prices
IPC-E-13-25
FIRST PRODUCTION REQUEST
PAGE 2
for non-firm energy to determine the Avoided Energy Cost. This tariff advice
clarifies that the weighted average used to determine the Avoided Energy Cost is
the volume-weighted average and inserts the term "volume" before "weighted
average" to add clarity to Schedule 86.
Please state whether or not ldaho Power has employed the described "volume-weighting"
methodology at all times since the IPUC approved use of the Dow Jones Index in Schedule 86 in
1999 in Order No. 28033. If not, provide the date that Idaho Power began volume-weighting the
index prices.
REQUEST FOR PRODUCTTON NO.4:
Please provide a list the QFs selling to ldaho Power for which Idaho Power has employed the
proposed volume-weighting methodology either under Schedule 86 contract or under surplus
energy or other market pricing provisions in an Idaho Power PURPA contract. If there are any
QFs for which Idaho Power does not employ the volume weighting methodology to calculate a
market price, please list those QFs and explain the basis for the different treatment.
REQUEST FOR PRODUCTION NO. 5:
Please provide the IPUC order Idaho Power relies upon to implement its proposed methodotogy
of volume weighting in Schedule 86 or other PURPA contracts.
REQUEST FOR PRODUCTTON NO. 6:
Please explain what Mid-C Price Index Idaho Power uses in provisions of its Open Access
Transmission Tariff addressing Energy Imbalance Service, on file with FERC. If Idaho Power
has used different indexes throughout time, please list each index used and the effective dates of
use for each index. Please also provide the FERC docket numbers where Idaho Power requested
approval of use of each index for purposes of Energy Imbalance Service.
IPC-E-13-2s
FIRST PRODUCTION REQUEST
PAGE 3
REQUEST FOR PRODUCTTON NO. 7:
Reference the response to Request No. 6, regarding Energy Imbalance Service. When Idaho
Power calculates a market price under its OATT, does ldaho Power use its volume weighting
methodology as proposed for use in the tariff in this case? If no, please describe the
methodology used to derive market prices under the OATT. [f yes, please provide the FERC
filing seeking approval of the volume-weighting methodology and the FERC order granting use
of Idaho Power' s volume-weighting methodology.
REQUEST FOR PRODUCTTON NO. 8:
Reference Idaho Power's filing in FERC Docket Nos. ELO1-l l8-000 and ER97-1481-000, dated
August 17,2005, stating: "Idaho Power does not engage in the reporting of transactions to
publishers of electricity or natural gas indices."
a. Please provide any subsequent filings made in any FERC docket by Idaho Power
updating the status of whether Idaho Power reports to any electricity indices, or any filing
otherwise made as a compliance filing under FERC's Market Behavior Rule 4, 105
FERC 1T61,218 at PP 116-119, or l8 C.F.R. $$ 284.288(b) or 284.403(b).
b. Please provide a list of electricity indices to which Idaho Power reports and the
dates during which Idaho Power reported at all times since the 2005 filing quoted above.
For all such indices, include at a minimum the following specifics about the index: index
name; firm or non-firm; day-ahead, hour-ahead, daily, monthly, etc.; and trading hub.
c. Please explain the reason Idaho Power chose not to report to electricity indices
and provide any supporting non-privileged internal memoranda on the topic.
REQUEST FOR PRODUCTTON NO. 9:
IPC-E-13-25
FIRST PRODUCTION REQUEST
PAGE 4
Provide a list of all daily heavy load or light load periods since 2005 where the Dow Jones daily
non-firm index reported a volume of zero trades or zero MWh traded.
REQUEST FOR PRODUCTTON NO. r0:
Provide a list of days beginning in September 2013 where the Platts daily non-firm index
reported a volume of zero trades or zero MWh traded.
REQUEST F'OR PRODUCTION NO. 11:
Provide a list of all days where Idaho Power made non-firm electricity sales at Mid-Columbia
since 2005, and provide the volume of the sales in MWh for such days. For purposes of this
question "non-flrm" has the same definition as used by the Dow Jones Index or the Platts lndex
at the relevant time.
REQUEST FOR PRODUCTTON NO. 12:
Provide a list of all days where Idaho Power made non-firm electricity purchases at Mid-
Columbia since 2005, and provide the volume of the purchases in MWh for such days. For
purposes of this question'hon-fum" has the same definition as used by the Dow Jones lndex or
the Platts Index at the relevant time.
REQUEST FOR PRODUCTTON NO. 13:
Are there any days since 2005 where the Dow Jones daily non-firm index reported a volume of
zero for the daily heavy load or light load period and where Idaho Power either made a non-firm
purchase or sale of electricity at Mid-Columbia during the corresponding daily heavy load or
light load period? [f yes, please list such days and the volume of heavy load and light load trades
made by Idaho Power.
REQUEST FOR PRODUCTTON NO. 14:
IPC-E-13-25
FIRST PRODUCTION REQUEST
PAGE 5
Are there any days since discontinuation of the Dow Jones daily non-firm Mid-C index in
September 2013, where the Platts daily non-firm index reported a volume of zero for the daily
heavy load or light load period and where Idaho Power either made a non-firm purchase or sale
of electricity at Mid-Columbia during the corresponding daily heavy load or light load period? If
yes, please list such days and the volume of heavy load and light load trades made by Idaho
Power.
REQUEST FOR PRODUCTTON NO. 15:
Reference the letter from Dow Jones attached to the tariff application in this docket, stating o'The
full Platts Methodology Guide is available here." Please provide the Platts Methodology Guide
referenced in the hyperlink. Please also provide all other information in Idaho Power's
possession regarding Platts's methodology for calculating electricity index prices.
DATED this l0th day of February,2Dl4.
RICHARDSON ADAMS, PLLC
Gregory M. Adams
Of Attorneys for the J.R. Simplot Co.
IPC-E-13-25
FIRST PRODUCTION REQUEST
PAGE 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the l0th day of February,2}l4, a true and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST BY THE J. R. SIMPLOT
COMPANY, Case No. IPC-E-13-25, was served by electronic mail and U.S. Mail, postage
prepaid, to:
Donovan Walker
Idaho Power Company
1221 West Idatro Street (83702)
PO Box 70
Boise, Idalro 83707 -007 0
E-mail : [e-mail]
dockets @ idahopower. com
Megan Beauregard
Associate General Counsel
Enel Green Power North America, Inc.
One Tech Dr., Suite 220
Andover, MA 01810
E-mail: megan.beauregard@.enel.com
PaulAckerman
Assistant General Counsel
Exelon Business Services Corporation
100 Constellation Way
Baltimore, l\tfD 21202
Kris Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 W, Washington (83702)
P0 Box 83720
Boise, lD 83720-0074
E-mail : l<ris. sasser@puc. idaho. eov
Jean Jewell, Secretary
Idatro Public Utilities Commission
472West Washington
Boise, ID 83702
E-mail : [e-mail]. gov (^,1
IPC-E-13-25
FIRST PRODUCTION REQUEST
PAGE 7
Gregory . Adams