20141001IPC to Sierra Club 1-14.pdf

DONOVAN E. WALKER
Lead Counsel
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An IDACORP Companv
October 1,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-14-18
Solar lntegration Rates and Charges - ldaho PowerCompany's Responses
to the First Discovery Requests of Siena Club
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Responses to the First Discovery Requests of Siena Club.
Also enclosed are four (4) disks containing information responsive to the Siena
Club's discovery requests.
DEW:csb
Enclosures
1221 w. ldaho 5t. (83702)
P.O. Box 70
Boise, lD 83707
onovan E. Walker
DONOVAN E. WALKER (lSB No. 59211 RiC[lV[ti
ldaho Power Company
1221West ldaho Street (83702) 20ll{ OCT - | PH lr: 36
P.O. Box 70
Boise, ldaho g3707 li:)r:ri;::,t-;"..-. , ..
Tetephone: (208) 388-s317 l"iilLlTl:s c0F'{i'{lsjslol"l
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF IDAHO POWER )
coMpANy's AppLtcATIoN To ) CASE NO. !PC-E-14-18
IMPLEMENT SOLAR INTEGMTION )
RATES AND CHARGES.) TDAHO POWER COMPANY'S
) RESPONSES TO THE FIRST
) DISCOVERY REQUESTS OF
) STERRA CLUB
)
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compofly"), and in
response to the First Discovery Requests of Sierra Club to ldaho Power Company
dated September 10,2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 1
For Requests Numbers 1-12, please reference Exhibit No. 1 to the Direct
Testimony of P. DeVo!.
REQUEST NO. 1: Please provide copies of presentations (power point or the
like) and other materials provided by ldaho Power to the TRC at or in advance of the
TRC meeting of August 15,2013.
RESPONSE TO REQUEST NO. 1: The requested information is attached (all
parties provided with electronic PDF attachments and disks provided to the Idaho Public
Utilities Commission ("Commission")).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 2
REQUEST NO. 2: Please provide copies of minutes or similar summaries of the
TRC meeting of August 15,2013.
RESPONSE TO REQUEST NO. 2: Officia! meeting minutes were not taken.
However, attached is a meeting summary (all parties provided with electronic PDF
attachments and disks provided to the Commission).
The response to this Request is sponsored by Phil DeVo!, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 3
REQUEST NO. 3: Please provide copies of presentations (power point or the
like) and other materials provided by Idaho Power to the TRC at or in advance of the
TRC meeting of September 19,2013.
RESPONSE TO REQUEST NO. 3: The requested information is attached (al!
parties provided with electronic PDF attachments and disks provided to the
Commission).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERM CLUB - 4
REQUEST NO. 4: Please provide copies of minutes or similar summaries of the
TRC meeting of September 19,2013.
RESPONSE TO REQUEST NO. 4: Official meeting minutes were not taken.
However, attached are Mr. DeVol's e-mails referencing build-out scenarios, which were
a topic at the September 19,2013, meeting (all parties provided with electronic PDF
attachments and disks provided to the Commission).
The response to this Request is sponsored by Phi! DeVol, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 5
REQUEST NO. 5: Please provide copies of presentations (power point or the
like) and other materials provided by ldaho Power to the TRC at or in advance of the
TRC meeting of January 6,2014.
RESPONSE TO REQUEST NO. 5: The requested information is attached (all
parties provided with electronic PDF attachments and disks provided to the
Commission).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REOUESTS OF SIERRA CLUB.6
REQUEST NO. 6: Please provide copies of minutes or similar summaries of the
TRC meeting of January 6,2014.
RESPONSE TO REQUEST NO. 6: Official meeting minutes were not taken.
However, attached are e-mail communications from Mr. DeVol regarding the subject
matter at the January 6, 2014, meeting (all parties provided with electronic PDF
attachments and disks provided to the Commission).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 7
REQUEST NO. 7: Please provide copies of presentations (power point or the
like) and other materials provided by ldaho Power to the TRC at or in advance of the
TRC meeting of May 16,2014.
RESPONSE TO REQUEST NO. 7: The requested information is attached
parties provided with electronic PDF attachments and disks provided to
Commission).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 8
(all
the
REQUEST NO. 8: Please provide copies of minutes or similar summaries of the
TRC meeting of May 16,2014.
RESPONSE TO REQUEST NO. 8: Official meeting minutes were not taken.
However, attached is an e-mail from Mr. DeVol (all parties provided with electronic PDF
attachments and disks provided to the Commission).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 9
REQUEST NO. 9: Please provide copies of presentations (power point or the
like) and other materials provided by ldaho Power to the TRC at or in advance of the
TRC meeting of May 29, 2014.
RESPONSE TO REQUEST NO. 9: The requested information is attached (all
parties provided with electronic PDF attachments and disks provided to the
Commission).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 1O
REQUEST NO. 10: Please provide copies of minutes or similar summaries of
the TRC meeting of May 29,2014.
RESPONSE TO REQUEST NO. 10: Official meeting minutes were not taken.
However, attached are e-mails from Mr. DeVol (all parties provided with electronic PDF
attachments and disks provided to the Commission).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 11
REQUEST NO. 11: To the extent not covered by the preceding requests please
provide copies of all communications (memorandums, letters, email transmittals and the
!ike) from company representatives to any member of the TRC between the summer of
2013 and the filing of the present Application.
RESPONSE TO REQUEST NO. 11: The requested information is attached (all
parties provided with electronic PDF attachments and disks provided to the
Commission).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 12
REQUEST NO. 12: To the extent not covered by the preceding requests please
provide copies of all communications (memorandums, letters email transmittals and the
like) from any member of the TRC to the Company relating to the Solar lntegration
Study between the summer of 2013 and the filing of the present Application.
RESPONSE TO REQUEST NO. 12: The requested information is attached (a!!
parties provided with electronic PDF attachments and disks provided to the
Commission).
The response to this Request is sponsored by Phil DeVo!, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 13
For requests Numbers 13-14, please refer to page 6 of the Direct Testimony of P.
DeVol and the document entitled Principles for technical Review lnvolvement in
Sfudres of Variable Generation into Electrical Power Systems.
REQUEST NO. 13: Did ldaho Power provide to the TRC an assurance that
project sponsors will describe the project as having the benefit of expert review by a
TRC only if the TRC has clearly expressed its acceptance of and agreement with the
results of the study?
A. lf your answer is yes, please provide a copy of said assurance.
B. lf your answer is no, please explain why not.
RESPONSE TO REQUEST NO. 13: As described in the Direct Testimony of
Philip DeVol, the Technical Review Committee ("TRC") was formed at the study outset
with the purpose of providing input, review, and guidance for the study. The TRC was
successful in serving this purpose, and the study benefitted as a result. To help the
TRC understand its role and to help ldaho Power facilitate the TRC's fulfillment of its
role, the Utility Variable-Generation lntegration Group ("UVIG") document referenced on
page 6 of Mr. DeVol's testimony was shared and discussed with the TRC. The UVIG
document provides the important functions of an effective TRC, and ldaho Power's
conduct of the study allowed the TRC to perform these functions. ldaho Power's
characterization of TRC involvement is consistent with the functions provided in the
UVIG document. While ldaho Power has not provided the assurance about which
Sierra Club inquires, the Company also has not characterized the TRC involvement as
an expression of TRC acceptance of and agreement with the results of the study.
ldaho Power has long sought stakeholder involvement for projects similar to the
solar integration study-the IRP Advisory Council as an example-and seldom expects
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 14
full stakeholder acceptance of or agreement with the project outcome. However, the
stakeholder involvement remains a critical part of the process, and ldaho Power is not
precluded from describing the role stakeholders play in the process.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REOUESTS OF SIERRA CLUB - 15
REQUEST NO. 14: Did ldaho Power provide to the TRC an assurance that in
the event agreement is not reached by the TRC and other project participants, any
reference to the TRC will be removed from the final report and any associated
documents or publicity?
A. lf your answer is yes, please provide a copy of said assurance.
B. If your answer is no, please explain why not.
RESPONSE TO REQUEST NO. 14: Idaho Powe/s response to this Request is
similar to what was provided in the Company's response to Sierra Club's Request No.
13 above. The Company believes that involvement of an advisory council such as the
TRC is critical to the process for projects such as the solar integration study, and that
failure to reach agreement by the advisory council does not invalidate its involvement
and preclude the Company from reporting on its involvement.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
DATED at Boise, ldaho, this 1" dry of October 2014.
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 16
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1"t day of October 2014 ! served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSES TO THE FIRST
DISCOVERY REQUESTS OF SIERRA CLUB upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, ldaho 83701
Snake River AIIiance
Kelsey Jae Nunez
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
Sierra Glub
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, ldaho 83701
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 17
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Matt Vespa
Siena Club
85 Second Street, Second Floor
San Francisco, California 94105
IDAHO POWER COMPANY'S RESPONSES TO THE
FIRST DISCOVERY REQUESTS OF SIERRA CLUB - 18
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Christa Bearry, Legal Assistant