20150204Simplot 1-18 to IPC.pdf

Peter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N.27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
gr e g@richardsonadams. c om
Attorneys for the J. R. Simplot Company
'.,.|.-:!-
?0li Fti] -q Pil tr: lh
l"l ;"r';:-l-l I ::, . ji. i , :ji.j:.-i.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO MODIFY
TERMS AND CONDITIONS OF
PROSPECTIVE PURPA ENERGY SALES
AGREEMENTS.)
)
)
)
CASE NO. IPC-E-15-01
FIRST PRODUCTION REQUESTS OF
THE J. R. SIMPLOT COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the tdaho Public Utilities Commission
(the "IPUC" or'oCommission"), the J.R. Simplot Company ("Simplot") by and through its
attomeys 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 FIRST PRODUCTION REQUEST
IPC-E-15-01
PAGE I
)
)
)
)
electronic copy, or if unavailable a physical copy, to Dr. Don Reading at: 6070 Road, Boise,
Idaho 83703,(208) 342-t7oo;(208) 384-l 5 I I ; [e-mail].
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.
lf some of the following requests include disclosures reasonably deemed by Idaho Power
to be confidential, Simplot will enter into Idaho Power's standard confidentiality agreement.
REOUEST FOR PRODUCTION NO. T
Reference the direct testimony of Lisa Grow at page l5:23 to 16:3. Is Idaho Power's proposal to
limit contract terms to two years limited to QFs ineligible for standard avoided cost rates or to
limit the term for all QFs as Ms. Grow suggests?
REOUEST FOR PRODUCTION NO. 2
Reference the Company's Application at 4-5, discussing eight proposals to modifr the IPUC's
implementation of PURPA. Did the Company reach out to stakeholders to discuss the available
options prior to filing the current Application? Please provide a description of all informal
meetings or workshops where the Company sought stakeholder input on the issues identified in
the Company's Application and identift the QF parties contacted by the Company.
REOUEST FOR PRODUCTION NO.3
Reference the Company's Application at 4-5, discussing eight proposals to modify the IPUC's
implementation of PURPA.
(a) Given the influx of QFs into the queue, did the Company consider requesting that the
IPUC adjust the ability to update the avoided cost rates to account for projects that have
progressed through the queue?
(b) What would the avoided costs rates be under the IRP methodology for a solar QF
requesting pricing today if the Company updated the avoided capacity and energy cost
calculations under the approved IRP methodology to take into account as committed resources
all QFs that have an existing and current request for QF pricing and energy sales agreement that
meets all of the requirements of Schedule 73 pages 4-6, subparts a.1 . i.-xiv. and I .e.i.-iv. Use the
12x24 generation data of the project approved in Case No. IPC-E-14-19 (Grand View PV Solar
Two, LLC) to calculate the current rates as described above.
J.R. STMPLOT COMPANY'S FIRST PRODUCTION REQUEST
IPC-E-15-01
PAGE 2
REOUEST FOR PRODUCTION NO. 4
Reference Exhibit No. 3, providing an identity-blind list of the 885 MW solar QFs currently in
the queue. For each project listed:
(a) explain whether or not the project has provided all of the information necessa.ry to obtain
indicative pricing under Schedule 73 (items 1.a. i-xiv. on pages 4-5 of the schedule), and if the
project met the requirements, please provide the material supplied with the identity of the project
redacted;
(b) explain whether or not the project has provided all of the information necessary obtain a
draft energy sales agreement under Schedule 73 (items 1.e. i.-iv. on pages 5-6 of the schedule),
and if the project met the requirements, please provide the material supplied with the identity of
the project redacted;(c) explain whether the project is still in compliance with the requirement in Schedule 73 that
it timely meet all of the steps for responding to the Company, as required on page 7, subpart 1.n.
of the schedule;(d) please provide the indicative pricing for each year of a 2}-year contract term for each
project calculated in accordance with the approved IRP methodology;
(e) please provide the indicative prices for each year of a twenty-year contract term
calculated as in subpart (d) but with the energy and capacity components updated to count as
committed resources all QFs that provided all information described in items (a) and (b) prior to
the project in question;(0 identifu the interconnection queue number for each project, and please provide a copy of
the queue.
REOUEST FOR PRODUCTION NO.5
Reference the Company's Application at page3, stating, "the Company's 2013 IRP has
identified the Boardman to Hemmingway transmission line as the primary resource in the near
term action plan."
(a) Assuming the contracted-for 461 MW of solar capacity under contract comes on line as
expected, please provide documentation of the need for the Boardman to Hemmingway
Transmission line using the expected case scenarios in the 2015 tRP planning documents.(b) What is the expected cost to [daho Power to construct the Boardman to Hemmingway
Transmission line?(c) What are the expected annual operating costs to Idaho Power, each year over the next
twenty years of Boardman to Hemingway transmission [ine?(d) Please document the ratepayer impact of the Boardman to Hemmingway Transmission
line in annual revenue requirement figures for the first l0 years of operation.
REOUEST FOR PRODUCTION NO. 6
Reference the direct testimony of Lisa Grow at p. 17 , stating, "For the period from May 201 1
J.R. SIMPLOT COMPANY'S FIRST PRODUCTION REQUEST
IPC-E-15-01
PAGE 3
through December 2014, the Company had at least 15 reliability events that resulted in wind
generation output reductions in order to maintain the reliable operation of the Company's
electrical system."
(a) Why does the testimony modiff the number "l5" with the words "at least?" Provide the
true number of said "reliability events."(b) Please define what the Company means by "reliability event" in this passage.(c) For each reliability event please provide a detailed explanation of the cause.(d) For each reliability event, provide:(i) date and time of the curtailment;(ii) duration of the curtailment;(iii) a list of all generators online prior to the event;(iv) a list of demand side management programs in operation prior to the event; and(v) a list of generators (name and resource type) and demand side management
programs curtailed in whole or in part and MWs curtailed per generator or
program.
REOUEST FOR PRODUCTION NO. 7
Please provide copies of all material provided to the Commission Staff regarding the Company's
application that were provided other than through formal discovery, both prior to, and after, the
filing of the Application.
REOUEST FOR PRODUCTION NO.8
Please provide all of the Company's discovery responses to all other parties that have provided
and any future discovery responses the Company will provide in this docket.
REOUEST FOR PRODUCTION NO. 9
Reference Exhibit No. 6 attached to Randy Allphin's direct testimony.
(a) Please provide in electronic format the data used to produce the Exhibit No. 6.(b) Please include the generation units and the o'must-run minimum levels" of output of each
unit included in "IPCo Must-Run Generation."(c) Please also indentify and include the level of energy provided by "IPCo Utility Must
Take PPA's."(d) Please explain and document the basis for the large intra-day variations in the output of
the must-run resources referenced in subparts (b) and (c).
REOUEST FOR PRODUCTION NO. 10
Reference Exhibit No. 10 attached to Randy Allphin's direct testimony. Please provide, in
electronic format, the data used to produce Exhibit No. 10
J.R. SIMPLOT COMPANY'S FIRST PRODUCTION REQUEST
[PC-E-15-01
PAGE 4
REOUEST FOR PRODUCTION NO. 11
Reference Exhibit No. l0 attached to Randy Allphin's direct testimony.
(a) Please describe how the Company calculated the "PURPA Historical" prices depicted in
the solid red line. lnclude specific explanation of whether the Company used the price paid to
QFs or an average of the full contract prices and explain how the Company accounted for
reduced payments to QFs during months that the QF made deliveries outside of the 90/110
performance band.
(b) For all contracts containing a90ll10 performance band, please provide: (i) the number of
total contract months of operation thus far, and (ii) total number of contract months that a QF
made deliveries that fell outside of the 90/110 performance band.(c) For each individual year depicted in the graph and also the years 1999,2000, and 2001,
please provide the following data: (i) actual MWh of energy delivered by QFs under firm energy
sales agreements to Idaho Power, and (ii) the total payments made to such QFs in the year (in $).(d) Please provide corresponding data provided in the graph and that requested in subpart (c)
forthe years 1999,2000, and 2001.(e) Please explain why Company chose to exclude the years of the Califomia energy crisis
from its comparison of market index prices to QF prices.
REOUEST FOR PRODUCTION NO. 12
Reference Exhibit No. 10 attached to Randy Allphin's direct testimony.
(a) Please identify the index(es) used for the "Mid-C Historical" price depicted in the solid
blue line (e.g., Dow Jones, Platts, ICE, day-ahead firm, daily non-firm, monthly, annual, etc.).(b) Please explain in detail how the Company used the data supplied by the index to calculate
the data points for each year or other shorter period having a data point on the graph, including
whether the company recalculated the index prices to account for volume of trades reported to
the index or otherwise volume-weighted the index prices.
(c) If the Company volume-weighted the index prices for any year or data point, please
provide the Mid-C Historical data points depicting the prices provided by the index, without a
volume-weighting of the index prices.
REOUEST FOR PRODUCTION NO. 13
Reference Exhibit No. 8 attached to Randy Allphin's direct testimony.
(a) Please provide the work papers supporting the exhibit in electronic format.(b) Please provide for FERC Accounts 501, 547, and 555 (non-PURPA) for the years 2010
through 2013 for each generation unit, including the energy output, expense, and capacity factor
for the given year.
(c) For each year 2010 through 2013, provide the depreciated rate-base cost and authorized
J.R. SIMPLOT COMPANY'S FTRST PRODUCTION REQUEST
IPC-E-15-01
PAGE 5
return included in retail rates, for each of the Company's gas plants and coal plants, or otherwise
provide the raw data necessary to calculate the total revenue requirement associated with fixed
costs included in retail rates for the years and plants described.
(d) For each year 2010 through 2013, provide the annual amount of MWh of generation from
each of the Company's gas plants and coal plants.(e) Provide the estimated increase in the annual revenue requirement associated with costs
that will be included in retail rates for the first year the Company places in service the SCR
controls approved in Order No. 32929 for the Bridger plant.
REOUEST FOR PRODUCTION NO. 14
Reference Exhibit No. 6. Please explain why the graphs depict several over-generation events
that occur when only Company-owned resources are online - for example on page 5 of the
exhibit all of the events are caused by Company-owned generation. Is it the Company's position
that it has over-generation events due to its non-PURPA resources?
REOUEST FOR PRODUCTION NO. 15
Reference Exhibit No. 6.
(a) Please explain why the graph only includes the first week of each month.
(b) Please delineate the must-run hydro separately from the must-run coal resources on the
exhibit.
REOUEST FOR PRODUCTION NO. 16
Has the Company investigated the impacts of Idaho Power joining the PacifiCorp-Califomia ISO
energy imbalance market as a potential way to reduce costs associated with intermittent
generation or for any other reasons? If not, why not? Please provide all studies or analyses of the
impacts of Idaho Power joining the PacifiCorp-California ISO energy imbalance market.
REQUEST FOR PRODUCTION NO. 17
Reference the direct testimony of Lisa Grow at page 20:10-14, comparing the PURPA rates to
the energy-only cost ofcoal.
(a) Does Ms. Grow acknowledge that the "average cost of coal" and the cost provided for
"gas" does not include all costs included in retail rates associated with the generation of coal-
fired and gas-fired electricity, such as the remaining/depreciated fixed costs and authorized
return associated with the coal and gas plants?(b) Does Ms. Grow acknowledge that retail customers pay for the fixed costs and retum on
investment referenced in subpart (a) for the coal and gas plants regardless of how much
electricity they produce and even when they produce no electricity at all?
J.R. SIMPLOT COMPANY'S FIRST PRODUCTION REQUEST
IPC-E-15-01
PAGE 6
(c) Does Ms. Grow believe it is accurate to compare PURPA rates that include an energy and
a capacity"component to the energy-only coal costs? If yes, please explain why this comparison
in the testimony is not misleading.(d) Please provide the corresponding figures calculated with the removal of the capacity
component included in the PURPA rates and the total revenue requirement (all variable and fixed
costs, plus authorized return) for the coal and gas plants.
REOUEST FOR PRODUCTION NO. 18
Reference the direct testimony of Lisa Grow at page 9:6-8, discussing must-run resources. Does
the Company consider each of its hydro projects to be "must-run" resources? For each
Company-owned hydro resource, please provide a detailed explanation of the basis for the must-
run level for each hydro resource included in the referenced graph.
DATED rhtr{ day of February, 2015.
RICHARDSON ADAMS, PLLC
J.R. SIMPLOT COMPANY'S FIRST PRODUCTION REQUEST
rPC-E-15-01
PAGE 7
for the J.R. Simplot
Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3'd day of February, 2}l5,a true and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST OF J.R. SIMPLOT COMPANY
was served by hand delivery and electronic mail to the following individuals:
Donovan Walker
Idaho Power Company
P.O. Box 70
Boise, lD 83707
dwalker@idahopower. com
Daphne Huang
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington
Boise, Idaho 83702
daphne.huang@puc. idaho. gov
Don Howell
Deputy Attorney General
Idatro Public Utilities Commission
472W. Washington
Boise,Idaho 83702
don.howell@puc. idaho. gov
J.R. SIMPLOT COMPANY'S FIRST PRODUCTION REQUEST
IPC-E-15-01
PAGE 8