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Home My WebLink About20141001Sierra Club 15-20 to IPC.pdfMcDevitt & Miller r-rr Lauyers 42) West Bannock Strcet P.O. Bo:r 25tu83701 Boiser ldaho 83702 Chas. F. McDwftr DeanJ. (oe) Miller Celeete K. Miller (208) 34&7s00 (208) 3#69t2 Gax) DJM/hh Endosutes Octobet l,20l4 Viellaad Deliuery JeanJewe[ Secetary Idaho hblic Utilities Commission 472W. Washington St. Boise,Idaho 83720 Re Siera Club/ IPGE-14-18 Dear Ms.Jewell: Eoclosed f6s f,ling in the above mettet please find as otiginal and three (3) copies of Siera Club's Second Discovery Requesb to Idaho Powet Company. An additional copy of the doctrment and this letter is included for rctum to me with your file starnp thereon. Very Tdy Yours, McDevitt & MIIcTLLP C, ,\,-rq7_ .cEcrofrffi,e ti irtafi. 1 C) Itl5P2Hp,3 E-u#:' 5 .* -O.nz. t)t^n \,\l\UD*J'Mrler bJ*\s Dean J. Miller (ISB No. 1968) MoDEVITT & MILLER LLP 420 West Bannock Street P.O. Box 2564-83701 Boise, D 83702 Tel: 208.343.7500 Fax: 208.33 6.6912 j oe@mcdevitt-miller.com Matt Vespa CA Bar #222265 (Pro Hac Vice) Siena Club 85 Second St., 2"d Fl. San Francisco, CA 94105 matt.vespa@ sierraclub. ore Tel: 415.977 .5753 Fax: 415.977 .5793 Attorneys for Sierra Club IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION TO IMPLEMENT SOLAR INTEGRATION RATES AND CHARGES. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION ORIGINAL PH lr: l+5 CASE NO.IPC.E.14.18 SECOND DISCOVERY REQUESTS OF SIERRA CLUB TO IDAHO POWER COMPAI\Y Pursuant to RP 221.02 and221.03, Sierra Club propounds the following Discovery Requests to Idaho Power Company ("Company"). Sierra Club requests that the Company make best efforts to provide responses as soon as possible but not later than October 15,2014. These Discovery Requests are to be considered as continuing, and the Company is requested to provide, by way of supplementary responses, additional documents or information that it or any person acting on its behalf may later obtain. SECOND DISCOVERY REQUESTS OF SIERRA CLUB TO IDAHO POWER COMPA}IY -1 Pursuant to Commission Rules of Procedure a response to a request for production of documents must include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder and, if different, the witness who can sponsor the answer at hearing. See IDAPA 31.01.01.228. The term as used in these requests, TRC, means the Technical Review Committee described in the Direct Testimony of P. DeVol. DISCOVERY REOUESTS Numbering of discovery requests continues from Sierra Club's First Discovery Requests. For Requests 15-16, please reference the Direct Testimony of Phil DeVol, as well as Exhibit I to that Testimony, the Idaho Power Company Solar Integration Report (Solar Report). REOUEST NO 15: Please reference the Direct Testimony of Philip DeVol at page t 1 and Solar Report atpage 9. a. Please provide the hourly (8760) solar production forecast for each solar location by scenario, and the aggregate for each scenario, used for the production cost model. b. Please also provide the hourly (8760) aggregate wind production forecast and the hourly load data. c. With regard to the solar production forecast, as noted in the study, 'oThe results of the forecast are a unique set of values (average production, upper bound, and lower bound) for every hour in the year." Please include this set for each location and scenario as well as the aggregate solar production. d. Please also provide the total wind and solar energy per hour (8760) as a percentage of load. sEcoND DrscovERY REQUESTS OF SIERRA CLrrB TO rDAHO POWER COMPANY -2 REOUEST NO 16: With regard to the proposed Phase 2 of the Solar Report, with potential topics listed on page 18 of the Report, please answer the following questions: a. Qualitatively, do you expect that solar integration costs will increase or decrease for the analyses described in the bullet points on pg. 18, addressing each bullet point individually. Please provide some explanation of your assessment. b. Given the qualitative judgments in (a), what should the implications be for solar projects with PURPA contracts negotiated prior to Phase 2? F'or Requests 17-18, please reference the First Production Request to Idaho Power from Idaho Conservation League (ICL Request). REOUEST NO 17: Please reference ICL Request No. 7, and answer the additional question: a. Does the Company agree that participating in an EIM would reduce the cosl of providing balancing services (independently of whether it would also reduce the quantity of the capacity reserve requirement)? REOUEST NO 18: Please reference ICL Request No. 10 bullets (b) and (c) as excerpted below and add our request as shown in italics. a. Please provide all spreadsheets and other work papers used to derive the "integration cost per MWh for solar" figures in Table 8. Please provide hourly (8760) data if available. b. Please provide all spreadsheets and other work papers used to derive the "incremental integration cost per MWh for solar" figures in Table 9. Please provide hourly (8760) data if available. SECOND DISCOVERY REQUESTS OF SIERRA CLUB TO IDAHO POWER COMPAI{Y -3 REOUEST NO 19: What capability will Idaho Power have to accept bids from PURPA solar plants, or include such capabilities in contract terms, to mitigate system integration requirements particularly in high integration cost hours, e.g., through ramp controls? Has Idaho Power evaluated whether such bids will ever result in production cost savings above the PURPA avoided cost rate, at least for brief periods of time? REOUEST NO. 20: Please submit any dataon forecast solar curtailment from the production cost runs for each solar scenario, by hour. Dated this day of October,2074 w4 Dean J. Miller (ISB No. 1968) McDEVTIT & MILLER LLP Matt Vespa (CA Bar #222265) (Pro Hac Vice) SIERRA CLUB Attorneys for Sierra Club SECOND DTSCOyERY REQUESTS OF STERRA CLT]B TO IDAHO POWER COMPA}IY -4 I hereby certifu that on tfre -$aay of October ,2014,I caused to be served, via the method(s) indicated below, true and correct copies of the foregoi upon: Jean Jewell, Secretary Idaho Public Utilities Commission 47 2 W est Washington Street P.O. Box 83720 Boise,lD 83720-0074 ij ewell@puc. state.id.us Donovan E. Walker Greg Said Michael f. Youngblood Regulatory Dockets Idaho Power Company 1221 West Idaho Street P.O. Box 70 Boise,ID 83707 dwalker@idahopower. com esaid@idahopower.com myoun sblood@idahopower. com dockets@i dahopower. com Idaho Conservation League c/o Benjamin J. Otto 710 N. 6th St. Boise,Idaho 83702 botto@idahoconservation. ore Ken Miller Snake River Alliance Boise,ID kmiller@snakeriveralliance. ore CERTIFICATE OF SERVICE Hand Delivered U.S. Mail Fax Fed. Express Email Hand Delivered U.S. Mail Fax Fed. Express Email Hand Delivered U.S. Mail Fax Fed. Express Email Hand Delivered U.S. Mail Fax Fed. Express Email ng document, V ql (-! !(l (l !-t &ql (l K_ &(l (J (l !r(-a X &(-t &(l tl L MCDEVITT & MITTTn SECOND DISCOVERY REQUESTS OF SmRRA CLLIB TO IDAHO POWER COMPANY -s