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Home My WebLink About20150325IIPA 12-16 to IPC.pdfEric L. Olsen (ISB#: 481l) RACINE, OLSON, NYE, BI'DGE & BAILEY, CHARTERED P.O. Box l39l Pocatello, Idaho 83204-1391 Telephone : (208)232-61 0l Fa,x: (208)232-6109 Email : elo@racinelaw.com Attorneysfor Idaho lrrigation Pumpers Association, Inc. IN THE MATTER OF IDAHO POWER COMPANY'S PETITION TO MODIFY TERMS AND CONDITIONS OF PROSPECTTVE PURPA ENERGY SALES AGREEMENTS ?I::l u t nLL,'l il.il\ I iT M'l"i:.: r-/ti-ttt:-.- CASE NO. IPC.E.15.O1 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQIIEST TO IDAHO POWER COMPANY t5 Pti k:L7 J ,Z ,(9 & () BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF AVISTA CORPORATION'S PETITION TO MODIFY TERMS A].{D CONDITIONS OF PURPA PURCHASE AGREEMENTS cAsE NO. AVU-E-15-01 IN THE MATTER OF ROCKY MOUNTAIN POWER COMPANY'S PETITION TO MODIFY TERMS AND CONDITIONS OF PURPA PT]RCHASE AGREEMBNTS CASE NO. PAC.E.15-03 12. With respect to Attachment I (Tab 0411) to the Company's response to IIPA Request 10, please answer the following: What is the specific source for the items listed in lines 56, 60, and 62? What is the classification of the source listed on line 63 (Company-owned, PURPA, etc.X What is represented on line 64? IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQITEST TO IDAHO POWER COMPAI\IY - Page I What is represented on line 65? Are the sources in lines 67,68, and 69 PURPA related? What is the distinction between the data on lines 67,68, and 69? Are there any other lines between lines 9 and 67 that contain PLJRPA purchases? If so, please identifu them and explain what they are. With respect to the data in lines 54-69, would the designation (source data) in each of these lines be repeated in the s,ame order for each day of each month of this year? If not, please explain how to differentiate this source data for the various days and/or months. With respect to the operation of Bridger, Valmy, and Boardman: if the facility is being operated, can IPCo decline to take the energy being produced and have the operating partner or some other entity responsible for the Company's generation share? 13. Please answer the following with respect to the operation of the IPCo system on April 14, 2011, based upon the data provided in Attachment I (Tab 041l) to the Company's response to IIPA Request l0: On Mr. Allphin's Exhibit 6, it is stated that the must-run level of the Company's coal plants is266 MW. Please break this number down by coal facility. The data from April l4,20ll indicates that the coal plants were operated significantly below 266 MW for the first five hours of the day. What was the energy generated from each of the Company's coal facilities during these hours? By hour 7 on April 14,2011, the energy output from the coal facilities was significantly higher than266 MW. What was the energy generated from each of the Company's coal facilities during each hour from hour 7 through hotx22? Why did the energy output of the coal facilities fall significantly below the 266 MW level for hor.rs 23 and 24 on April 14, 20ll? What was the energy generated from each of the Company's coal facilities during hours 23 and24? f. PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. FOR LEAVE TO INTERVENE- Page 2 Sales for Resale energy was significantly higher between hours 10-19 than they were between hours l-9 as well as hours 20-24. Additiondly, there was a significant amount of real-time sales that took place between hours I l-19. These real-time sales between hours l1-19 were at low rates. Why did the Company make these sales at low rates, as opposed to reducing some of its own generation or taking other steps to reduce the amount of energy on the system? Under Column R of Tab 0411 on Attachment I of the Company's response to IIPA Request 10 is listed "Source" codes 21090,21076, and 21086. What were the terms of these sales? 14. Simplot's Request 5 in this case sought information regarding "reliability events". Please answer the following with respect to events 15, 16, 17, and 2l : With respect to each incident, please supply, for all hours in each day, the Tab number and the line number in Attachment 2 or 3 to the Company's response to IIPA Request l0 that corresponds to the system inputs from all generation resources (Company-owned, PURPA, and non-PURPA resources, but excluding Term, DA, and RT purchase). For each line listed, please provide a description (name) of the source and indicate if it is a PURPA or non-PURPA resource. With respect to each incident, please supply for all hours in each day, the reason why each Company owned-generation and Company controlled generation as well as specific purchases and sales for resale were maintained at the levels listed in the associated Tab number and the line number in Attachment 2 or 3 to the Company's response to IIPA Request 10. The information sought here is to understand the bounds/constraints faced by the Company to balance its resowces with its demand. With respect to each incident, for all hours in each day, please explain why additional sales for resale could not have been used to prevent thc "reliability event". With respect to each incident, for all hours in each day, what was the Mid-C price for energy? 15. If there have been additional "reliability events" since December 2014, please provide similar data to that listed in the response to Simplot Request No. 6. b. d. PETITION OF IDAHO INRIGATION PI,MPERS ASSOCIATION,INC. FOR LEAVE TO INTERVEITIE. Page 3 16. Given the fact thafz4 "rcliability eveots" have becn recorded, what stcps has the Company taken to reduce the amormt of events and the length of thesc events? How successful have thesc attempts been? DATEDff, Z# day of Marc\ 2015. RACINE, BAILEY By PETIIIONOFIDAEOIRRIGATIONPITMPBSASSOCHTION,INC.FORLEAYETOINTDRVET{E Prge{ CBRTIFICATE OF SERVICE I HEREBY CERTIFY that on tn"&uyof March, 2Ol5lserved a true, correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Second 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: Intermountain Energy Parurers, LLC X E-mail P.O. Box 7354 Boise,lD 83707 leif@ sitebascdener gy. com Kelsey Jae Nunez Snake River Alliance 223 N.6h Street, Suite 317 P.O. Box 1731 Boise,ID 83701 kntrnez@snakeri veral li ance. org Ken Miller Snake River Alliance kmill er@snakeriverall i ance. ore Dean J. Miller McDevitt & Miller LLP 420 W. Bannock Street P.O. Box 2564-83701 Boise,ID 83702 i oe@ mcdevitt-miller.com Leif Elgethun, PE, LEED AP Ted Weston ID Reg Affairs Manager Rocky Morurtain Power 201 S. Main St., Ste 2300 Salt lake City, UT 84111 ted.weston@pacifi corp.com U.S. Mail/?ostage Prepaid E-mail Facsimile Ovemight Mail X Hand Delivered U.S. Mail/Postage Prepaid Facsimile Ovemight Mail Hand Delivered U.S. Mail/Postage PrepaidX E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/?ostage PrepaidX E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage PrepaidX E-mail Facsimile Ovemight Mail Hand Delivered PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FOR LEAVE TO INTERVENFT Page 5 Michael G. Andrea Avista Corporation 1411 E. Mission Ave. MSC-23 Spokane, WA 99202 michael. andrea@avi stacorp.com Matt Vespa Sierra Club 85 Second St 2od Floor San Francisco, CA 94105 matt.vespa@siemaclub. org Frederick J. Schmidt Pamela S. Howland Holland & Hart LLP 377 S Nevada St. Carson City, NV 89703 fschmidt@holl andhart. com Scott Dale Blickenstaff Amalgamated Sugar Co. 1951 S. Saturn Way, Ste 100 Boise,lD 83702 sbl ickenstaft@arnal suear. com Andrew Jackura Sr. VP North America Devl Camco Clean Energy 9360 Station St., Ste 375 Loan Tree, CO 80124 andrew j ackura@camsocleanenergy. com Peter J. Richardson Gregory M. Adams Richardson Adams, PLLC 515 North 276 Street P.O. Box 7218 Boise,ID 83707 peter@richardsonadam s. com gre g@richardsonadarns.com 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 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 x x x x x PETITION OF IDAIIO IRRIGATION PUMPERS ASSOCIATION, INC. FOR LEAVE TO INTERYEM- Page 6 Michael G. Andrea Avista Corporation 14ll E. Mission Avenue, MSC-23 Spokane, WA 99202 Clint Kalich Avista Corporation 141I E. Mission Ave., MSC 7 Spokane, WA 99202 Frederak J. Schmidt POamela S. Howland Holland & Hart, LLP 377 South Nevada Sheet Carson City, NV 89701 fschmidt6hollandhart.com phowland@holl andhart. com Daniel S. Solander Yvonne R. Hogle Rocky Mountain Power 201 S. Main Street, Ste 2400 Salt Lake City, UT 84l l l daniel. solander@pacifi corp. com yvonne.ho gel @pacificcorp.com Ronald Williams Williams Bradbury PC l0t5 W. Hays Street Boise,ID 83702 ron@.willi amsbradbury. corn Jean D. Jewell, Secretary Idatro public Utilities Commissions P.O. Box 83720 Boise,lD 83720-0074 i j ewell@puc.state.id.us x x x x x U.S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. MaitlPostage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. MaillPostage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. MaillPostage Prepaid E-mail Facsimile Ovemight Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Ovemight Mail PETITION OF IDAHO IRRIGATION PIIMPERS ASSOCHTION,INC. FOR LEAYB TO INTERYENE- Page 7