20170404ICL&Sierra Club 1.1-1.7 to IPC.pdf

Benjamin Otto,ISB No. 8292
Idaho Conservation League
710 N 6th St., Boise,ID 83701
[phone],ExL 12
botto@idahoconservation. org
David Bender, WI Bar# 1046102
Earthjustice
3916 Nakoma Road
Madison, WI 5371I
(4ts) 977-s727
dbender@earthj ustice. org
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
)
IN THE MATTER OF TIIE PETTTION OF ) CASE NO. IPC-E-17-01
IDAHO POWER COMPANY FOR )A DECLARATORY ORDER REGAtPryg ) FIRST SET OF DATA REQUESTS BY
ft$lto*r, tffJT;"rDEDrEm i tg:coNSERVATIoNLEAcuEpRICIN6 FOR BATTERy SrOnaOp ) AND SIERRA CLUB TO IDAHO
FACILITIES ) POWER
Idaho Conservation League (*ICL") and Sierra Club hereby serve their first set of data requests
regarding the above-mentioned docket. ICL and Sierra Club request that Idaho Power Company
provide responses as expeditiously as possible, but not later than the deadline of 2l days.
INSTRUCTIONS
1. Please provide copies of responses to the following contacts:
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 5371I
dbender@,earthj ustice.org
Ben Otto
Idaho Conservation League
710 N 6th St.
Boise,ID 83701
bgttq.@ idahoc onservato n. otg
2. Whenever possible, Sierra Club and ICL prefer to receive electronic copies of data responses
either by email or on CD.
3. Responses to any and all of Sierra Club and ICL's data requests should be supplied to Siera
Club and ICL as soon as they become available to Idaho Power.
4. The requests herein shall be deemed to be continuing in nature and ldaho Power is requested
to supplement its responses as necessary and as additional information becomes available.
5. In responding to each data request, please consult every document source which is in your
possession, custody, or control, including all documents in the possession of experts or
consultants.
6. For each response, identifr the person who prepared the answer to the data request as well as
his or her position with Idaho Power or any Idaho Power affiliate or parent.
7. Please reproduce the data request being responded to before the response.
8. If the responses include computer modeling input and output files, please provide those data
files in electronic machine readable or txt format
9. If the responses include spreadsheet files, please provide those spreadsheet files in useable
electronic Excel readable format.
10. In responses providing computer files, list the file names with cross-reference to the data
request, and ifnecessary to the understanding ofthe data, provide a record layout ofthe
computer files. Computer files provided with a response must be in or compatible with the
current version, or the immediately prior version, of Microsoft Office.
I l. For each dollar amount provided in response to a discovery request please state if the amount
is in nominal or constant dollars and what years dollars.
ICLISC 1.1
ICL/SC I.2
ICL/SC 1.3
ICLISC I.4
DATA REQUESTS
Please identify each Qualified Facility ("QF") from which you expect or anticipate
purchasing electricity (capacity andlor energy) during 2017 and for each Qualified
Facility identified, please provide each of the following:
(l) The fuel and/or generation source for the QF;
(2) The approximate location of the QF generation;
(3) The date on which the QF first delivered electricity to you;
(a) The date on which the QF obligation (contract or legally enforceable obligation)
occurred for the QF;
(5) The projected capacity factor of the QF during 2017;
(6) The total generation expected from the QF during 2017;
(7) The expected capacity value of the QF during your system peak during 20171'
(8) The expected pricing for capacity and energy from the QF during 2017.
Please provide an updated version of Allphin Exhibits 2,3,4,6,8,9, and 10 filed in
Docket No.IPC-E-15-01, based on data cunent through the date of your response (for
Exhibit 8, please include at leastyears 2014,2015 and 2016).
For each of the projects identified in Allphin Exhibit 3 filed in Docket No. IPC-E-15-01,
please state the current status of the project, including but not limited to:
(l) whether the project proponent obtained a contract or legally enforceable obligation;
(2) the date of the conEact or legally enforceable obligation; and
(3) The date on which the project either first.produced electricity transferred to Idaho
Power or is projected to first produce electricity to transfer to Idaho Power.
Please provide the following for the Langley Gulch natural gas fired power plant for
2015,2016, and projected for 2017:
(l) Total annual generation in Megawatt Hours (MWh);
(2) The generation for each hour ofthe year;
(3) The fuel cost in dollars per MWh of net production for each hour of the year;
(4) The variable operation and maintenance (O&M) costs in dollars per net MWh for
each year;
{ .'r:r''.1
TCL/SC I.5
ICL/SC I.6
(5) The categories of costs that were included in your calculation of variable O&M
costs.
Please provide the following for 2015, 2016, and projected for 2017:
(l) The marginal energy cost for each hour of the year;
(2) The marginal generation resource for each hour of the year-
Please provide the following:
(t) Each potential QF that has requested an energy sales agreement since February 5,
20t5;
(2) The fuel or generation source for each potential QF that requested an energy sales
agreement since February 5, 2015;
(3) The nameplate generation size of each potential QF that requested an energy sales
agreement since February 5,2015;
(4) Each potential QF that submiued a written request for indicative pricing since
February 5,2015;
(5) The fuel or generation source for each potential QF that subrnitted a written request
foi indicative pricing since February 5,2015;
(6) The nameplate generation size of each potential QF that submitted a written request
for indicative pricing since February 5,2Al.5;
(7) Each potential QF that has requested an energy sales agreement since August 20,
2015;
(8) The fuel or generation source for each potential QF that requested an energy sales
agreement since August 20,2015;
(9) The nameplate generation size of each potential QF that requested an energy sales
agreement since August 20,2015;
(10) Each potential QF that submitted a written request for indicative pricing since
August 20,2015;
(l l) The fuel or generation source for each potential QF that submitted a written request
for indicative pricing since August 20,2015;
(12) The nameplate generation size of each potential QF that submitted a written request
for indicative pricing since August 20,2015; and
(13) The approximate location of each QF identified in response to subparts l-12,
.".\\I
above.
ICL/SC 1.7 Please provide the spreadsheets, workpapers, and/or analyses conducted and/or relied on
in any way for your response to the foregoing requests.
Dated:
lsl David C. Bender
7
David Bender
Eartffustice
3916 Nakoma Road
Madison, WI 5371I
[e-mail]
&ck-
Ben Otto
Idaho Conservation League
710 N 6th St.
Boise,ID 83701
botto@.idatroqo{rssrvalion. or g
CERTIFICATE OF Sf,,RVICE
I hereby certiry that on this 4th day of Aprilz}lT,I delivered true and correct
copies of the foregoing FIRST SET OF DATA REQUESTS BY IDAHO CONSERVATION
LEAGUE AND SIERRA CLUB TO IDAHO POWER to the following persons via the method
of service noted:
ELECTRONIC MAIL ONLY:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
427 W. Washinglon St.
Boise,ID
[e-mail]. gov
Camille Christen
Daphne Huang
Deputy Attorneys General
Idaho Public Utilities Commission
427 W. Washington St.
Boise,lD 83702
camille.chdsten@puc. idaho.gov
[e-mail]. gov
Idaho Power
Donovan Walker
Lead Counsel
Idaho Power Company
P.O. Box 70
Boise,ldaho 83707
dwalker@idahopower. com
dockets@idahopower. com
Franklin Enerry Storage One through
Four, LLC
Peter Richardson
Richardson Adams, PLLC
515 North 27ft Street
PO Box 7218
Boise,ID 83707
[e-mail]
IPC-E-17-01
l'l Data Request of SCiICL to Idaho Power
Black Mesa Enerryn LLC
Brian Lynch
Black Mesa Energy,LLC
PO Box 2731
Palo Verdes, CA 90274
[e-mail]
Benjamin J. Otto
ri:l