The URL can be used to link to this page

Home My WebLink About20150325IIPA 1-14 to PAC.pdfEric L. Olsen (ISB#: 48l l) RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 Pocatello, Idaho 83204-1391 Telephone : (208)232-61 0l Fax: (208)232-6109 Email : elo@racinelu*..o. Attorneysfor ldaho lrrigation Pumpers Association, Inc. IN THE MATTER OF IDAHO POWER COMPANY'S PETITION TO MODIFY TERMS A}ID CONDITIONS OF PROSPECTIVE PURPA ENERGY SALES AGREEMENTS IN THE MATTER OF AVISTA CORPORATION'S PETITION TO MODIFY TERMS AND CONDITIONS OF PURPA PURCHASE AGREEMENTS IN THE MATTER OF ROCKY MOUNTAIN POWER COMPANY'S PETITION TO MODIFY TERMS AND CONDITIONS OF PURPA PURCHASE AGREEMENTS l-.,1 ,:', iLlTi;:5; {",i cAsE NO. rPC-E-1s-01 CASE NO. AVU.E-Is-OI CASE NO. PAC-E-15.03 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S nRST DATA REQIJEST TO PACIFICORP 't",r l . J Z (D c\'c) BEFORE TIIE IDAIIO PTJBLIC UTILITIES COMMISSION l. Please provide system hourly data similar to that provided in response to Idaho Irrigation Pumpers' Request No. 8 in Case PAC-E-08-08 for the years 201I throudb20l4. 2. In Foofirote 4 of the Company's Petition in this case, it states: "PacifiCorp's 2013 IRP Updated filed with the Commission shows.that new long-temr resources are not required wn12027. PacifiCorp's 2015 IRP, which is scheduled to be filed in March 2015, witl show no new resource need until 2028." Please answer the following: Will the Company be capacity or energy deficient in2028? IDAHO IRRIGATION PI'MPERS ASSOCHTION, INC.'S FIRST DATA REQUEST TO PACIFICORP - Page 1 b. What resource was forecasted to be needed by the 2013 Updated IRP for 2027? c. What resource will be forecasted to be needed by the 2015 IRP for 2028? d. The footnote states that "new long-term resources" will be needed in2027 ard presumably in2028. Please explain what other types of resources are expected to be needed before "new long-term resources" will be required. 3. Onpage 4 of the Petition, the Company requests a "modification of the Company's avoided cost methodology''. Please provide an overview of the Company's entire avoided cost methodology (not simply from the aspects surrounding the change that is desired). 4. On page 1l of the Petition, the Company states: "The incremental cost standard is intended to leave customers economically indifferent to the source of a utility's energy by ensuring that the cost to the utility of purchasing power from a QF does not exceed the cost the utility would incur in the absence of the QF purchase." a. By "incremental cost standard" is the Company referring to only variable costs or both fxed and variable costs? b. On page 2l of Ms. Grow's testimony in Idaho Power Case IPC-E-15-01 (the present case), it is stated that over the last several years there have been reliability curtailments of PURPA generation on the Idaho Power system? If similar curtailments have taken place on the PacifiCorp system, please speciff the dates, times, and level of each such curtailment. c. For each month between January 201I and December 2074, what was average cost of all PURPA contracts, as well as wind only and solar only? d. During each hour of January 201I through December2014, did the cost of either purchase power or the price of sales for resale exceed either the average monthly price of PURPA contacts, as well as wind only, or solar only? e. For each hour between fanuary 2011 and December 2014, how much power was purchased from all PURPA contacts, as well as wind only, and solar only? f. For the period January 2011 through December 2014, which days/trours had either purchase power costs or sale for resale prices at or below $20 per M!VH? rDAHO IRRIGATTON PUMPBRS ASSOCHTION, INC.',S F'IRST DATA REQUEST TO PACIFICORP-Page? g. For the period January 201I thLrough December 2014, which days/hours had either purchase power costs or sale for resale prices at or below $10 per MWH? h. For the period January 201I through December 2014, which days/trours had either purchase power costs or sale for resale prices at or below $0 per MWH? By month between January 201I and December 2014, what was the nameplate rating of all PURPA contracts on the system, as well as wind only and solar only? By month between January 2011 and December 2014, what was the arnount of energy purchased from all PURPA contracts on the system, as well as wind only and solar only? On page 21 of the Petition it is stated that PacifiCorp has 3,641 MW of proposed PURPA contracts. Please provide by jurisdiction the amount (nameplate rating) of solar, wind, and "other" PURPA that is projected to be added in 2015, 2016, and20l7. What is the projected cost in each jurisdiction for new solar, wind, and other PURPA contracts that are to be added in 2015, 2016, and20l7? 9. As of the end of 2014, how much (nameplate rating) solar, wind, and other PURPA contracts were in each of the Company's jurisdictions and what was the cost of each type by jurisdiction in 2014. 10. On pages 27 and 28 of the Petition, the Company addresses how (for transactions that exceed 36 months) it does an analysis that looks for the "lowest cost least risk way to meet the identified need". Assuming that solar projects were one option being reviewed, where would this fall in the rankings of other options that are reviewed in the Company's IRP? 11. On pages 27 and 28 of the Petition, the Company addresses how (for transactions that exceed 36 months) it does an analysis that looks for the "lowest cost least risk way to meet the identified need". Assuming that wind projects were one option being reviewed, where would this fall in the rankings of other options that are reviewed in the Company's IRP? 12. With respect to page l8 lines 20 and 2l of Mr. Clements' testimony, what is meant by the words 'tnequivocally commit" and "at around the same time"? IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO PACIFICORP-Page 3 5. 6. 7. 8. I 3. With respect to line I 0 on page 2l of Mr. Clements' testimony, what portion of the Monsanto load does this include? 14. On page 30 lines 19 through 23 of Mr. Clements' testimony there is a discussion of long- tenn resources vs. "lower-cost, lower-risk short-term resoruce[s]". What are the specific "lower-cos! lower-risk short-term resource[s]", the magnitude of those resources, and the projected acquisition dates prior to the need for a new long-term resource ia2028? DATED tni, 2#4day ofMarch,2ol5. NYE, BI.'DGE & ERIC L. OLSEN IDNIO IRRTGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUTST TO PACFICORP - Page 4 CERTIF'ICATE OT' SERVICE I IIEREBY CERTIFY that on,*oe'5** of March, 2015 I served atrue, correct and complete copy of the Idaho Irigation Pumpers Association, fnc.'s First Data Request to Pacificorp to each of the following, via U.S. Mail or private courier, e-mail or hand delivery, as indicated below: Dean J. Miller McDevitt & Miller LLP 420W. Bannock Steet P.O. Box 2564-83701 Boise,lD 83702 i oe@mcdevitt-miller.com Leif Elgethun, PE, LEED AP Intennountain Energy Partners, LLC P.O. Box 7354 Boise,ID 83707 leifl@ sitebasedenergy. com Kelsey Jae Nunez Snake River Alliance 223 N. 6ft Street, Suite 317 P.O. Box 1731 Boise,ID 83701 knunez@.snakeriveral liance. org Ken Miller Snake River Alliance kmi ll er@.snakeriveral I iance.ore Ted Weston ID Reg Affairs Manager Rocky Mountain Power 201 S. Main St., Ste 2300 Salt Lake City, UT 841I I ted.westonOoacifi com.com x x x x x U.S. Mail/Postage Prepaid E-mail Facsimile Ovemight Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Ovemight Mail Hand Delivered U.S. MaillPostage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Ovemight Mail Hand Delivered IDAHO IRRTGATION PUMPERS ASSOCIATION, rNC.'S FIRST DATA REQUEST TO PACIFICORP-Page 5 Michael G. Andrea Avista Corporation l41l E. Mission Ave. MSC-23 Spokane, WA 99202 michael. andrea@ avi stacom. com Matt Vespa Sierra Club 85 Second St 2nd Floor San Francisco, CA 94105 matt. vespa@sieraclub. org Frederick J. Schmidt Pamela S. Howland Holland & Hart LLP 377 S Nevada St. Carson City, NV 89703 fs chrnidt (0hollandhart. corn Scott Dale Blickenstaff Amalgamated Sugar Co. l95l S. Saturn Way, Ste 100 Boise,lD 83702 sblickenstaff@amal suqar. com Andrew Jackura Sr. VP North America Devl Camco Clean Energy 9360 Station St., Ste 375 Loan Tree, CO 80124 andrew j ackura@camcocleanenergy.com Peter J. Richardson Gregory M. Adams Richardson Adams, PLLC 515 North 276 Street P.O. Box 7218 Boise,ID 83707 peter@richardsonadams. com gre g@richardsonadarn s. com U.S. MaitPostage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. MaiYPostage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. MaiUPostage Prepaid E-mail Facsimile Ovemight Mail Hand Delivered U.S. MaiUPostage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. MaiYPostage Prepaid E-mail Facsimile Ovemight Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail Hand Delivered x x x x x IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTTO PACIFICORP-Page 6 Michael G. Andrea Avista Corporationl4ll E. Mission Avenue, MSC-23 Spokane, WA 99202 Clint Kalich Avista Corporation l4ll E. Mission Ave., MSC 7 Spokane, WA 99202 Frederak J. Schmidt Poamela S. Howland Holland & Hart, LLP 377 South Nevada Street Carson City, NV 89701 fschmi dt@hollandhart. com phowland@holl andhart. com Daniel S. Solander Yvonne R. Hogle Rocky Mountain Power 201 S. Main Street, Ste 2400 salt Lake ciry, uT 841I I daniel.solander@oaci fi com.corn Yvonne. ho eel@pacifi ccorp.com Ronald Williams Williams Bradbury PC l0l5 W. Hays Street Boise,ID 83702 ron@williamsbradbury.com Jean D. Jewell, Secretary Idaho Public Utilities Commissions P.O. Box 83720 Boise, lD 83720-0074 ijewell@l''uc. state.id.us x x x x x U.S. Mail/?ostage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail passimile Overnight Mail Hand Delivered U. S. MailPostage Prepaid E-mail Facsimile Overright Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Ovenright Mail Hand Delivered U.S. Mailtrostage Prepaid E-mail Facsimile IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTTO PACIFICORP-Page 7