20190124Staff 1-14 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATION OF
IDAHO POWER FOR APPROVAL OR
REJECTION OF AN ENBRGY SALES
AGREEMENT WITH J.R. SIMPLOT COMPANY
_ POCATELLO COGENERATION AND SMALL
PURCHASED POWER PROJECT
CASE NO. IPC-E-19-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (Company)
provide the following documents and information as soon as possible, or by TUESDAY,
FEBRUARY 5,2019.r
This Production Request is 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 answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
t Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 JANUARY 24,2019
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Page 3 of the Application states that "Under the terms of this ESA,
Simplot elected to contract with Idaho Power for a three-year term using the nonJevelized, non-
seasonal hydro published avoided cost rates as currently established by the Commission in Order
No. 34062 dated May 16,2018, for replacement contracts and for energy deliveries of less than
l0aMW." Please confirm whether the term "non-seasonal hydro" is correct. Please provide an
explanation.
REQUEST NO. 2: Order No. 29632 requires a 48-hour minimum forced outage
requirement to discourage unreasonable numbers of forced outage declarations that could result
in a burdensome amount of accounting and contract administration activities. Please confirm
that parties agree to apply the 48-hour minimum requirement to both forced outage and force
majeure events even though the Commission order only requires it to be applied to forced
outages.
REQUEST NO.3: Page 5 of the Application states, "Simplot requested that the
notification of Net Energy Amount monthly adjustments described in paragraph 6.2.3 be reduced
from one-month advanced notice to five business days' notice prior to the upcoming
month...Idaho Power agrees that these are reasonable modifications that can be accommodated
with Idaho Power's operations." Please provide justification and evidence to support why Idaho
Power believes (1) it is a reasonable modification, and (2) it can be accommodated with Idaho
Power's operations.
REQUEST NO. 4: Please describe and quantify the benefit that the Company will lose
by reducing notification of Net Energy Amount monthly adjustments from one-month advanced
notice to five-day advanced notice prior to the delivery month for the Simplot project at issue in
this case.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JANUARY 24,2019
REQUEST NO. 5: Does Idaho Power believe it is reasonable and/or appropriate to
reduce notification of Net Energy Amount monthly adjustments from one-month advanced
notice to five-day advanced notice prior to the delivery month for all existinq "other" category of
PURPA projects when they renew their contracts? Please explain why or why not.
REQUEST NO. 6: Does Idaho Power believe it is reasonable and/or appropriate to
reduce notification of Net Energy Amount monthly adjustments from one-month advanced
notice to five-day advanced notice prior to the delivery month for all new "other" category of
PURPA projects? Please explain why or why not.
REQUEST NO. 7: Does Idaho Power believe it is appropriate to reduce notification of
Net Energy Amount monthly adjustments from one-month advanced notice to five-day advanced
notice prior to the delivery month for all new seasonal hydro, non-seasonal hydro, solar, and
wind PURPA projects? Please explain why or why not.
REQUEST NO. 8: Does Idaho Power believe it is appropriate to reduce notification of
Net Energy Amount monthly adjustments from one-month advanced notice to five-day advanced
notice prior to the delivery month for all existing seasonal hydro, non-seasonal hydro, solar, and
wind PURPA projects when they renew their contracts? Please explain why or why not.
REQUEST NO. 9: Please describe and quantify the benefits that the Company will lose
by reducing notification of Net Energy Amount monthly adjustments from one-month advanced
notice to five-day advanced notice prior to the delivery month for both new contracts and
existing contracts of all resource types.
REQUEST NO. 10: Does Idaho Power believe it should allow existing PURPA
contracts that are not up for renewal to reduce notification of Net Energy Amount monthly
adjustments from one-month advanced notice to five-day advanced notice prior to the delivery
month, as it did in Case Nos. IPC-E-I5-l l, IPC-E-I5-21, and IPC-E-I5-22? Please explain why
or why not.
J JANUARY 24,2019
FIRST PRODUCTION REQUEST
TO IDAHO POWER
REQUEST NO. 11: In Idaho Power's view, what effect, if any, do the clauses found in
the Applications in Case Nos. IPC-E-17-14, IPC-E-18-04, and IPC-E-18-09 have on the need for
a QF to request an amendment to the 90-110 provisions in the QFs' contracts from Idaho Power?
In Idaho Power's view, would Idaho Power need to file an amendment with the Commission in
order to effectuate the five-day notice provision in these contracts?
REQUEST NO. 12: Is Idaho Power aware of any other Applications that contain similar
language as referenced in the above Request No. 11?
REQUEST NO. 13: The "Answer to Interrogatory No. 2" of "Idaho Power Company's
Answers and Responses to J.R. Simplot's First Interrogatories, Requests for Admission, and
Requests for Production to Idaho Power Company" in Case No. IPC-E-I8-07 describes how
estimates of generation on a monthly basis are used in the monthly Operating Plan, which is part
of the Company's risk management process. Please describe how reducing notification of Net
Energy Amount monthly adjustments from one-month advanced notice to five-day advanced
notice prior to the delivery month would affect the monthly Operating Plan and the risk
management process in general.
REQUEST NO. 14: The "Response to Request for Admission No. 1" of "Idaho Power
Company's Answers and Responses to J.R. Simplot's First Interrogatories, Requests for
Admission, and Requests for Production to Idaho Power Company" in Case No. IPC-E-I8-07
states that "there is an entire process of estimating generation from the month-ahead through the
day-ahead, and into real time required to serve load and balance the system, for which a QF's
monthly estimates are used." Please describe the impacts of reducing notification of Net Energy
Amount monthly adjustments from one-month advanced notice to five-day advanced notice prior
to the delivery month on the month-ahead level, the day-ahead level, and the real-time level.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 JANUARY 24,2019
Dated at Boise, Idaho, this 7 qr aaV of January 2llg.
J*l @,/% 4,
Edward Jewell
Deputy Attorney General
i:umisc:prodreq/ipce I 9. I ejyyrf prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 JANUARY 24,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF JANUARY 2019,
SERVED THE FOREGOING F'IRST PRODUCTION REQUEST OF' THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC.E.I9-01,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
DONOVAN WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : dwalker@idahopower. com
dockets@idahopower. com
DON STURTEVANT
GENERAL COUNSEL
J R SIMPLOT CO
PO BOX 27
BOISE ID 83707
E-mail: i [e-mail]
don. sturtevant@,sirnplot. com
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
GREGORY M ADAMS
RICHARSON ADAMS PLLC
PO BOX 7218
BOISE ID 83707
E-mail: [e-mail]
SECRET
CERTIFICATE OF SERVICE