20171101Renewable Energy Coalition 3-11 to IPC.pdf

Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N.27m Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
greg@richardsonadams. com
RECE IVED
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Attorney for the Renewable Energy Coalition
BEFORE TFM
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 201 7 INTEGRATED
RESOURCE PLAN CASE NO. IPC-E-I7-II
SECOND SET OF PRODUCTION
REQUESTS OF RENEWABLE
ENERGY COALITION TO IDAHO
POWER COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Renewable Energy Coalition by and tluough its attorney of record,
Gregory M. Adams, hereby requests that ldaho Power Company ("Company") respond to the
following set of production requests.
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 one electronic copy, if available, of your answer to
Mr. Adams at the address noted above.
For each item, please indicate the name of the person(s) preparing the answers, along
Renewable Energy Coalition's Second Set of Production Requests to Idatro Power
IPC-E-17-11
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with the job title of such person(s) and the witness at hearing who can sponsor the answer.
If some of the following requests include disclosures deemed by Idaho Power to be
confidential, the Renewable Energy Coalition is prepared to enter into an appropriate
confi dentiality agreement.
REOUEST FOR PRODUCTION NO. 3
Please refer to page 84 of the IRP where Idaho Power states that it is using the Energy
lnformation Administration's ("EIA") High Oil and Gas Resource and Technology Case from
EIA's 2016 Annual Energy Outlook ("AEO") for its Natural Gas Price Forecast because "this
case is more consistent with recent price trends than the reference case."
a. What were the other EIA forecasts that Idatro Power could have used? Please
provide a fuller explanation of why each of the alternatives was rejected in favor of the
High Oil and Gas Resource and Technology Case.
b. Please explain why "recent price trends" are relevant to Idaho Power's Natural
Gas Price Forecast?
c. What "recent price trend" datadid ldaho Power review? Please provide this data.
d. Please explain how the High Oil and Gas Resource and Technology Case is more
consistent with recent price trends?
e. Please explain how the'orecent price trendo'data is more reliable at predicting
long-term natural gas forecasts than the EIA's Reference Case.
f. What (if any) are the actual natural gas prices Idaho Power has paid during the
last two years and contracted for in the future (and explain how they are calculated)?
Renewable Energy Coalition's Second Set of Production Requests to ldaho Power
IPC-E-17-11
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REOUEST FOR PRODUCTION NO. 4
Please refer to the graph on page 84 of 2017 IRP where ldatro Power shows the EIA Reference
Case forecast, and the EIA High Oil and Gas Resource and Technology Case forecast. Please
also refer to ldaho Power's 2015 IRP on page 85 where ldaho Power also included the Low case.
a. Please explain why Idaho Power has not considered the low case in the 2017 IRP?
If the low case was considered in the2017IRP, please explain why it has not been
displayed on this graph as it was in the 2015 IRP.
b. What are the assumptions used in the EIA's Reference Case, High Oil and Gas
Resource and Technology Case, and Low Oil and Gas Resource and Technology Case?
c. Please explain why EIA chose the EIA Reference Case over the others, and why
EIA did not choose the EIA High Oil and Gas Resource and Technology Case?
d. What makes Idaho Power different such that it should not use the EIA's
Reference Case?
REOUEST FOR PRODUCTION NO. 5
Please refer to page 85 where ldaho Power states that it applies a Sumas basis adjustment and
transportation cost to the Henry Hub price to derive an Idaho Citygate price. What is the
formula Idaho Power uses to adjust for the Sumas basis and transportation cost? Please provide
any spreadsheets used for this analysis with all formulas intact.
Renewable Energy Coalition's Second Set of Production Requests to Idaho Power
IPC-E-17-11
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REOUEST FOR PRODUCTION NO. 6
Please refer to page 112, Figure 9.1 of the IRP.
a. Does this graph reflect that Idaho Power has selected the lowest of all gas
scenarios as the planning case, and only analyzed price sensitivities above that of the
planning case?
b. Why has Idaho Power not analyzed any sensitivities below the planning case?
c. Why has Idaho Power chosen to use low gas prices in its planning case scenario?
d. Is this the same gas price assumptions Idatro Power has used for its energy
efficiency analysis?
REOUEST FOR PRODUCTION NO. 7
Please refer to pages ll2-ll3 where table 9.4 shows the portfolio relative costs under increasing
levels of gas prices. With increasing gas price forecasts, portfolio costs increase for Pl, P3, P4,
P6, P9, P10, and Pl2. Please explain why the portfolio costs did not increase for P2, P5, P7, P8,
and Pl1.
REOUEST FOR PRODUCTION NO.8
Please refer to page 114 of the IRP.
a. Please explain what ldaho Power means by "adjusted upward from the planning
case gas price forecast." Please explain why Idaho Power used this approach.
b. Please explain how ldaho Power estimated the black dashed line in figure 9.2 and
why the Company chose a lower estimation for natural gas prices while it did not choose
Renewable Energy Coalition's Second Set of Production Requests to ldaho Power
IPC-E-17-11
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a lower estimation for the other two stochastic variables (customer load sampling or
hydro generation sampling).
REOUEST FOR PRODUCTION NO. 9
Please refer to page 109 of Appendix C to the IRP where ldaho Power shows the historic EIA
Henry Hub natural gas spot price forecasts for 2010 through20l6. Are these all based on the
EIA's Reference Case in each year or the High Oil and Gas Resource and Technology Case?
REOUEST FOR PRODUCTION NO. TO
Please refer to page 108 of Appendix C to the IRP where Idaho Power shows the Idaho Citygate
Natural Gas, Coal, and Nuclear Price Forecasts. Please also refer to Idaho Power's 2015 IRP on
page 129 of Appendix C, where Idaho Power also included the Idaho Citygate Natural Gas prices
based on the High Case and the Low Case. Please explain why Idaho Power has chosen to only
analyze the Idaho Citygate natural gas price forecast for its planning case (the High Oil and Gas
Resource and Technology Case), and not also compare the Idaho Citygate natural gas prices
based on EIA's Reference Case and Low Oil and Gas Resource and Technology Case?
REOUEST FOR PRODUCTION NO. 11
What data did Idatro Power use for gas prices in its energy effrciency analysis? What data did
Idaho Power use for gas prices in its load-resource balance analysis?
Renewable Energy Coalition's Second Set of Production Requests to Idaho Power
IPC-E-17-l I
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DATED this t day of November 2017.
By:
M. Adams (ISB No. 7454)
Adams, PLLC
515 N 27ft Street
Boise,Idaho 83702
Telephone: 208.938.223 6
Fax: [phone]
gre g@richardsonadams. com
Renewable Energy Coalition's Second Set of Production Requests to Idaho Power
IPC-E-17-11
Page 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on th" !fiuyof Novemb er2017,a true and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST OF THE RENEWABLE ENERGY
COALITION TO IDAHOHO POWER COMPANY, in DocKet No. IPC-E-L7-II was served
VIA ELECTRONIC MAIL and UNITED STATES MAIL, postage prepaid. to the following:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472West Idaho Street
Boise, Idaho 83702
diane.holt@puc. idatro. gov
Timothy Tatum
Michael Youngblood
Idaho Power Company
1221 West Idatro Street
Boise, Idaho 83702
[e-mail]
myoungblood@idahopower. com
Peter Richardson
Industrial Customers of Idaho Power
PO Box 7218
Boise,Idatro 83702
pete@richardsonadams. com
C. Tom Arkoosh
IDAHYDRO
PO Box 2900
Boise,Idaho 83702
tom. arkoo sh@arkoo sh. com
[e-mail] (email only)
Gloria D. Smith
Sierra Club
2101 Webster St, Suite 1399
Oakland, California 94612
gloria. smith@sierraclub. com
Lisa Nordstrom
Idaho Power Company
1221 West Idaho Street
Boise,Idaho 83702
lnordstrom@idahopower. com
dockets@idahopower. com
Eric Olsen
Idaho Irrigation Pumpers Assn
PO Box 6119
Pocatello,Idaho 83205
[e-mail]
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Don Reading
6070 Hill Road
Boise, Idaho 83702
[e-mail]
Pete Bennett
Micron Technology, Inc
8000 South Federal Way
Boise, Idaho 83706
[e-mail]
Brad M. Purdy
STOP B2H
2019 N. l7s Street
Boise, Idaho 83702
[e-mail]
Renewable Energy Coalition's Second Set of Production Requests to Idaho Power
IPC-E-17-l r
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Thorvald A. Nelson
Emanuel T. Cocian
Kim Stanger
Holland & Hart, LLP
6380 South Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
tnel son@hollandhart. com
etcocian@hollandhart. com
kcstanger@hollandhart. com
[e-mail]
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
472 W est Washington Street
Boise, Idaho 83702
sean.costello@puc. idaho. gov
Adams
Renewable Energy Coalition's Second Set of Production Requests to Idaho Power
IPC-E-17-11
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