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Home My WebLink About20150407Simplot 19-22 to IPC.pdfPeter J. Richardson (ISB No. 3195) Gregory M. Adams (ISB No. 7454) Richardson Adams, PLLC 515 N. 27th Street Boise,Idaho 83702 Telephone: (208) 938-7900 Fax: (208) 938-7904 peter@richardsonadams. com greg@richardsonadams. com Attorneys for the J. R. Simplot Company IN THE MATTER OF IDAHO POWER COMPANY'S PETITION TO MODIFY TERMS AND CONDITIONS OF PROSPECTIVE PURPA ENERGY SALES AGREEMENTS. BEFORE THE IDAHO PUBLIC UTILITTES COMMISSION , t, , i ';:,. ,",:- i 20i5 APn - j t'rt t\ tllTii_iTl':i : . Pl'{ ?: 10t tt w. LJ L l,!', '|\r-.,.. r!luJ.! . CASE NO. IPC.E.15.O1 SECOND PRODUCTION REQUESTS OF THE J. R. STMPLOT COMPANY Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "IPUC" or o'Commission"), the J.R. Simplot Company ("Simplot") by and through its attorneys of record, Gregory M. Adams and Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho Power" or the "Company") provide responses to the following requests for production. This production request is to be considered as continuing, and the Company 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 documents produced. Please provide one physical copy and electronic-mail copies of the responses to Mr. Richardson and Mr. Adams at the addresses noted above. Please provide an additional J.R. SIMPLOT COMPANY'S SECOND PRODUCTION REQUEST IPC-E-15-01 PAGE I electronic copy, or if unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel: (208) 342-1700; Fax: (208) 384-l5l l; dreading@mindspring.com. 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 who can sponsor the answer at an evidentiary hearing. REOUEST FOR PRODUCTION NO. 19 Reference the Company's response to IPUC Staff s production request no. 14, indicating that the Company's single-run methodology does not take into account instances where the Company makes off-system sales at a loss and instead if there are no displaceable resources available in a specific hour, the energy rate is set to $0 in that hour. a. Please explain if modifications could be made to the single-run methodology that would accurately account for instances when the Company makes off-system sales at a loss due to PURPA generation. Please explain what modifications could be made. b. Please recalculate the avoided cost rates provided in response to J.R. Simplot Co.'s request for production no. a(d) and (e) using the modification. REOUEST FOR PRODUCTION NO. 20 Reference the Company's response to IPUC StafPs production request no. 14, indicating that the Company's single-run methodology does not take into account instances where the Company makes off-system sales at a loss and instead if there are no displaceable resources available in a specific hour, the energy rate is set to $0 in that hour. a. Please explain whether the double-run tRP methodology in effect prior to adoption of the single run methodology would account for instances when the Company makes off-system sales at a loss due to PURPA generation. If not, please explain why not and provide an illustrative example with supporting work papers. b. Please recalculate the avoided cost rates provided in response to J.R. Simplot Co.'s request for production no. a(d) and (e) using the double-run methodology. J.R. STMPLOT COMPANY'S SECOND PRODUCTION REQUEST rPC-E-15-01 PAGE 2 e. f. REOUEST FOR PRODUCTION NO. 2I For each of the QF projects that make up the 461 MW of executed solar contracts, please provide the following information: a. The date by which the project was required to provide delay default security in the FESA.b. Any extensions in the date specified in subpart a. granted by Idaho Power. Whether the project provided the delay default security by the dates specified in a. and b. Whether Idaho Power has issued a notice of default of the FESA. Whether ldaho Power has issued a notice of termination of the FESA. lf notices specified in subparts (d) and (e) have been supplied, explain the bases upon which ldaho Power relies to conclude the project is likely to be brought online. REOUEST FOR PRODUCTION NO. 22 Reference the Company's response to J.R. Simplot Co.'s production request no. 4(a)-(c), indicating that of the 48 prospective solar QFs comprising the 885 MW of solar QFs that were in the queue at the time Idaho Power filed the application in this case, 23 had not even provided enough information to obtain indicative pricing and only one project had provided enough information to Idaho Power to obtain a draft FESA under the IPUC tariff. a. Please provide an update to the table supplied in response to request no. 4(a)-(c) and for the projects that have not provided enough information to even obtain indicative pricing please also explain what information was supplied to Idaho Power that leads it to believe the project was likely to be constructed and sell its output to Idaho Power. Please also provide an update of the number of projects and MW capacity that are still in the PURPA queue and actively seeking FESAs. b. Please state the number of projects and MW of capacity that have provided Idaho Power with evidence that they possess site control in the form of real property rights to develop the project. c. Does Idaho Power agree that there is insuffrcient information to conclude that the 880 MW of projects are likely to be built and sell their output to Idaho Power? If not, please explain what information or basis Idaho Power relies upon and provide all supporting documents. REQUEST FOR PRODUCTION NO. 23 Reference the Company's response to IPUC Staff s production request no. 18, indicating that Idaho Power does not believe long-term, locked-in price estimates could potentially benefit Idaho Power in some circumstances. Please explain why long-term locked-in prices that are below the actual avoided costs for energy and capacity at the time of delivery would not benefit customers. J.R. SIMPLOT COMPANY'S SECOND PRODUCTION REQUEST IPC-E-15-01 PAGE 3 REOUEST FOR PRODUCTION NO. 22 Reference the Company's response to J.R. Simplot Co.'s production request no. 11, providing a non-responsive answer to the request that Idaho Power provide Mid-Columbia index prices for the years 1999, 2000, 2001, and 2002. a. Does lda]ro Power possess information or data regarding the Mid-Columbia index prices for the years I 999, 2000, 2001, and 2002? b. Please provide all data in Idaho Power's possession regarding Mid-Columbia index prices for the years 1999, 2000, 2001, and2002. DATED thisfta day of April, 2015. Of Attomeys for the J.R. Simplot Company J.R. SIMPLOT COMPANY'S SECOND PRODUCTION REQUEST IPC-E-15-01 PAGE 4 N ADAMS, PLLC CERTIFICATE OF SERVICE I HEREBY CERTIFY, that, in accordance with IPUC Order 33253, on theffrday of April, 2015, a true and correct copy of the within and foregoing SECOND PRODUCTION REQUEST OF THE J.R. SIMPLOT COMPANY was served as one printed copy upon the Commission and by electronic mail to the following individuals: Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Boise, Idaho 83702 jean j ewell@puc.idaho. gov Donald L. Howell, II Daphne Huang Idaho Public Utilities Commission 472West Washington Boise,Idaho 83702 don.howell@puc. idaho. gov daphne. huan g@puc. idaho. gov C. Tom Arkoosh Twin Falls Canal Company North Side Canal Company American Falls Reservoir District #2 Arkoosh Law Offices 802 W Bannock Ste 900 Boise ID 83702 tom. arkoosh@arkoosh. com Erin Cecil (Electronic Copies Only) erin.cecil@arkoosh.com Ben Otto Idaho Conservation League 710 N 6th Boise ID 83702 botto@ idahoconservation.ors Matt Vespa Sierra Club 85 Second St., 2nd Floor San Francisco, CA 94105 matt. vespa@ sierraclub. ore X Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile -_ Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail T x J.R. SIMPLOT COMPANY'S SECOND PRODUCTION REQUEST IPC-E-15-01 PAGE 5 Leif Elgethun, PE, LEED AP Intermountain Energy Partners, LLC PO Box 7354 Boise, ID 83707 lei f@sitebasedenergy. com Dean J Miller McDevitt & Miller LLP PO Box 2564 Boise ID 83702 ioe@mcdevitt-miller.com Daniel E Solander Rocky Mountain Power 201 South Main Street Ste 2400 Salt Lake City UT 841I I daniel. solander@pacifi corp. com datarequest@pacifi corp. com Ted Weston Rocky Mountain Power 201 South Main Ste 2300 Salt Lake City UT 84111 ted. weston@paci fi com. com Kelsey Jae Nunez Snake River Alliance PO Box l73l Boise ID 83701 knunez@snakeriveralliance.org Donovan E. Walker Idaho Power Company l22l West Idaho Street Boise,ID 83702 dwalker@ idahopower. com dockets@ idahopower. com Clint Kalich Avista Corporation l4l I E Mission Ave MSC-7 Spokane WA99202 clint. kalich@avistacom. com _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail J.R. SIMPLOT COMPANY'S SECOND PRODUCTION REQUEST IPC-E-15-01 PAGE 6 Michael Andrea Avista Corporation l41l E Mission Ave MSC-23 Spokane WA99202 michael.andrea@avistacorp.com Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Ch. PO Box 1391 Pocatello, ID 83204-1 391 elo@racinelaw.net Anthony Yankel 29814 Lake Road Bay Village, OH 44140 tony@yankel.net Ronald L. Williams Williams Bradbury, PC l0l5 W. Hays Boise, lD 83702 ron@.williamsbradbury. com Irion Sanger Sanger Law, PC I117 SW 53'd Ave Portland, OR 97215 irion@sanqer-law.com Andrew Jakura Camco Clean Energy 9360 Station St, Suite 375 Lone Tree, CO 80124 andrew j akura@camcocleanenergy. com _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid _ Facsimile X Electronic Mail J.R. SIMPLOT COMPANY'S SECOND PRODUCTION REQUEST IPC-E-15-01 PAGE 7