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Home My WebLink About20150218IIPA 1-11 to IPC.pdfEric L. Olsen (ISB#: 4811) RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 Pocatello, Idaho 83204-1391 Telephone : (208)232-61 0l Fax: (208)232-6109 Email : elo@racinelaw.com Attorneys for ldaho lrrigation Pumpers Association, Inc. IN THE MATTER OF IDAHO POWER COMPANY'S PETITION TO MODIFY TERMS AND CONDITIONS OF PROSPECTIVE PURPA ENERGY SALES AGREEMENTS .-1,'l'-' ?fi15 f lB l0 Pl{ 12: 23 ili.i,.. i , i-:'i iLl , 1 .. p ii l;,1 , :..,i , r,,, , BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO.IPC.E.15.O1 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S F'IRST DATA REQUEST TO rDAHO POWER COMPAI\Y 1. Please supply a copy of all of the Company responses to interrogatories/requested made by the Staff or any other party in this case. 2. Assuming that the Mid-C historic prices on Exhibit l0 of Mr. Allphin's testimony are derived from each day's "Intercontinental Exchange ("ICE") daily firm Mid-C prices", please supply the raw data that was used develop the historic figures portrayed on that exhibit. Also supply any formulas or other data used to develop the historical figures portrayed. 3. Please provide an explanation regarding the appropriateness of using "Intercontinental Exchange ("ICE") daily frrm Mid-C prices" data in the Company's Schedule 86 (Cogeneration and Small Power Production Non-Firm Energy): Are the "Intercontinental Exchange ("ICE") daily firm Mid-C prices" based on hourly data? For the purposes of Mr. Allphin's Exhibit 10, was the "Intercontinental Exchange ("ICE") daily firm Mid-C prices" data simply arithmetically averaged for the pufpose of the exhibit? IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPAI\"Y - Page 1 b. c. Are the "Intercontinental Exchange ("ICE") daily firm Mid-C prices" calculated "after the fact", or are they use as "day ahead" or some other forward pricing mechanism? d. Why has the Company chosen to use the "Intercontinental Exchange ("ICE") daily firm Mid-C prices" as a proxy for costs on the Idaho Power system? e. How accurate do the "Intercontinental Exchange ("ICE") daily firm Mid-C prices" reflect the prices that the Company faces in the open market or of the cost of its own generation? 4. If the Mid-C historic prices on Exhibit l0 of Mr. Allphin's testimony are not "Intercontinental Exchange ("ICE") daily firm Mid-C prices", please indicate what index was used, and supply the raw data that was used develop the historic figures portrayed on that exhibit. Also supply any formulas or other data used to develop the historical figures portrayed. 5. If Mr. Allphin's Exhibit 10 was not based upon "Intercontinental Exchange ("ICE") daily firm Mid-C prices" data, please provide the similar answers to Request 3 above for the index that was used. 6. Assuming that there are times when the Company's access to Mid-C is limited, when would those times generally occur? 7. Assuming that there are times when the Company's access to Mid-C is limited, why would Mid-C be a good index of the prices that the Company faces in the open market or of the cost of its own generation. 8. How will access to Mid-C be impacted by the Boardman to Hemmingway Transmission line? 9. On pages 4-5 of the Application, there is listed eight items thatokarrant additional examination and possible revision". For each of the eight items listed, please provide any swnmary documents developed by or for the Company that describe why the Company believes that each of these eight items may be helpful and thus, "warrant additional examination and possible revision". 10. Please provide from January 2011 through the most recent data available, hourly data similar to that provided in response to Irrigator Request 8 in Case IPC-E-I1-08. IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPAI\IY -Page2 11. For each PURPA contract where the price was set (or to be set) using an IRP Methodology, please provide the following: The date that the QF originally submitted a request for contract approval; The date that the contract was approved by the Commission; The Commission case number; The nameplate capacity; The type of project (wind, solar, cogeneration, etc.); and f. The contracted price for the purchase of the output of the facility. DATED thi, 'Aday of Februttry, 2015. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - Page 3 a. b. c. d. e. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on ,^" l&rof February ,2015I served atrue, correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s First Data Request to Idaho Power Company to each of the following, via U.S. Mail or private courier, e-mail or hand delivery, as indicated below: Jean D. Jewell, Secretary Idaho Public Utilities Commission P.O. Box 83720 472 W . Washington Street Boise, Idaho 83720-007 4 ij ewel l@puc. state. id.us Donovan E. Walker Regulatory Dockets Idaho Power Company P.O. Box 70 Boise, ID 83707 d wal ker@J i d ahono wer. c om dockets@idahopower. com Peter J. Richardson Gregory M. Adams RICHARDSON ADAMS, LLP 515 n 7ffi Street P.O. Box 7218 Boise, ID 83702 peter@richardsonadams. com greg@ri chardsonadams.com Dr. Don Reading 6070 Hill Road Boise,ID 83703 dreadine@mindsprinq.com Benjamin J. Otto Idaho Conservation League 710 N. 6tr Street Boise,lD 83702 bo tto (4).idah o c on servati o n I e a gue. or g U. S. MaillPostage Prepaid E-mail Facsimile Overnight Mail X Hand Delivered U.S. Mail/Postage PrepaidX E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage PrepaidX E-mail Facsimile Ovemight Mail Hand Delivered U.S. Mail/Postage PrepaidX E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage PrepaidX E-mail Facsimile Overnight Mail Hand Delivered IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -Page 4 Dean J. Miller McDevitt & Miller LLP 420W. Bannock Street P.O. Box 2564-83701 Boise,ID 83702 j oe@mcdevitt-miller.com Leif Elgethun, PE, LEED AP Intermountain Energy Partners, LLC P.O. Box 7354 Boise,ID 83707 leif'@sitbasedenergy. com Kelsey Jae Nunez Snake River Alliance 223 N. 66 Street, Suite 317 P.O. Box 1731 Boise,ID 83701 kn unez@snakeri veralliance.org x x U.S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U. S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail Hand Delivered x ERIC L. OLS IDAHO IRRIGATTON PUMPERS ASSOCIATION, INC.'S FIRST DATA REQIIEST TO IDAHO POWER COMPAI\tY-Page 5