20170811Response to Simplots Joint Motion.pdf

ROCKY MOUNTAIN
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1407 West North Temple, Suite 310
Salt Lake City, Utah 84116
August ll,20l7
VA OVERNIGHT DELIVERY
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise,ID 83702
Re:CASE NO. GNR-E-I7-02
IN THE MATTER OF THE ANNUAL UPDATE TO PUBLISHED AVOIDED
COST RATES TO REFLECT AN UPDATED NATURAL GAS PRICE
FORECAST OF THE U.S. ENERGY INFORMATTON ADMINISTRATION
(ErA)
Dear Ms. Hanian
Please find enclosed an original and seven (7) copies of Rocky Mountain Power's Response in the
above referenced maffer.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager, at [phone].
Very truly
Jeffrey K. Larsen
Vice President, Regulation
Enclosure
sl0t,i
Yvonne Hogle (ISB# 8930)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone: (80 I ) 220-4050
Fax: [phone]
Email : Yvonne.Hogle@Pacifi Corp.com
Attorneyfor Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ANNUAL
UPDATE TO PUBLISHED AVOIDED
COST RATES TO REFLECT AII
UPDATED NATURAL GAS PRICE
FORECAST OF THE U.S. ENERGY
INFORMATION ADMINISTRATION
(ErA)
CASE NO. GNR-E-I7-02
ROCKY MOUNTAIN POWER'S
RESPONSE TO SIMPLOT'S JOINT
EXPEDITED MOTION
Rocky Mountain Power, a division of PacifiCorp, in accordance with the Idaho Public Utilities
Commission's Rules of Procedure 256, hereby respectfully submits to the Idaho Public Utilities
Commission ("Commission") the following response ("Response") to J.R. Simplot Company,
Renewables Energy Coalition, and Tamarack Energy Partnership (hereafter, "Joint Parties")
Expedited Joint Protest and Joint Motion in Opposition to Modified Procedure and Joint Motion to
Convene Technical Hearing ("Joint Protest and Motion") filed on August 4,2017.
I. INTRODUCTION AND BACKGROUND
On June 1,2017, the Commission approved an update to Avista, Idaho Power, and Rocky
Mountain Power's SAR avoided cost rates for EIA's updated natural gas forecast and opened Case
No. GNR-E-L7-02. On August 2,2017, the Commission noticed that the case would be processed
under Modified Procedure. On August 4,2017 , the Joint Parties filed a Joint Protest in opposition to
processing this case using Modified Procedure and Motion to convene a technical hearing.
I
The Joint Parties asked the Commission to vacate its Notice of Modified Procedure, and to
schedule technical hearings in this case. In arguing that Modified Procedure is inappropriate in this
case, the Joint Parties assert that the Commission's Notice of Modified Procedure did not provided the
parties with any idea of what the Commission was considering or any idea of what it proposed to do.
The Joint Parties funher assert that modified procedure in this case is not in the public interest because
the issues presented are vague, undefined, and too technical to explain and be understood in writing.
The Joint Parties attempt to broaden the scope of this proceeding by somehow concluding that this
Case raises issues with the Commission's prudency determination of Idaho Power's energy
conservation and demand response programs.
I ROCKY MOUNTAIN POWER'S RESPONSE
Idaho Power's application clearly specified the single issue to be addressed in this proceeding
was an "objection to the subset of Energy Information Administration's ("EIA") natural gas forecast
selected by Staff, and the resulting published avoided cost rates proposed thereby." The proper scope
of this proceeding is limited to the Commission determining what EIA Annual Energy Outlook natural
gas forecast should be used to calculate the SAR published avoided cost rates for the annual update.
In fact, the Notice of Modified Procedure, Order 33831, issued August 2,2017 , is clear in that regard,
stating, "YOU ARE HEREBY NOTIFIED that the issue to be decided in this case is whether the
Commission should use the EIA's Henry Hub forecost instead of the EIA's Mountain Regionforecast
to calculate published avoided cost rates each year."l [Emphasis added]
Rocky Mountain Power respectfully requests that the Commission deny the Joint Parties
request to vacate its Notice of Modified Procedure and to schedule technical hearings in this case. This
2
rOrder 33831,at2
case is narrowly focused on a single issue that can be addressed through written comments and
processed under Modified Procedure.
Respectfully submitted this I lth day of August,2077
Hogle
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake city, Utah 841l6
Telephone: [phone]
Fax: [phone]
Emai I : Yvonne.Ho gle@P acifiCorp.com
Attorneyfor Rocley Mountain Power
J
CERTIFICATE OF SERVICE
I hereby certi$ that on this I lth of August, 2Ol7,l caused to be served, via electronic
mail a true and correct copy of ROCKY MOUNTAIN POWER'S RESPONSE TO
SIMPLOT'S JOINT EXPEDITED MOTION in Case No. GNR-E-17-02to the following:
Service List
AVISTA CORPORATION
Mi chael Andrea - michael.andrea@avi stacorp. com
Clint Kal ich - [e-mail]
IDAHO POWER COMPANY
Donovan E. Walker - [e-mail]
Michael Darrington - [e-mail]
PACIFICORP, dba ROCKY MOUNTAIN POWER
Yvonne Hogle - [e-mail]
Ted Weston - ted.weston@pacifi corp.com
Dan iel MacNeil - dani el.macnei I @pacifi corp.com
Jeffrey K. Larsen - j eff. larsen @pacifi corp. com
COMMISSION STAFF
Daphne Huang - [e-mail]
J.R. SIMPLOT COMPANY
Peter J. Richardson - peter @richardsonadams.com
Dr. Don Reading - [e-mail]
IDAHO HYDROELECTRIC POWER PRODUCERS TRUST DBA HDAHYDRO
Tom Arkoosh - [e-mail]
RENEWALBE ENERGY COALITION
Gregory M. Adams - [e-mail]
Irion Sanger - [e-mail]
TAMARA CK ENERGY PARTNERSHIP
Preston N. Carter - [e-mail]
Michael C. Creamer - [e-mail]
Dated this I lth day of August,2017.
C\*i*,,-y\*rll
lerfffer Arfiell" t $
Superv isor,' Regu latory Operations
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