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Home My WebLink About20160519Comments.pdfPeter J. Richardson ISB # 3195 Gregory M. Adams ISB # 7454 RICHARDSON ADAMS, PLLC 515 N. 27th Street Boise, Idaho 83702 Telephone: (208) 938-2236 Fax: (208) 938-7904 peter@ richardsonadams. com gre g@richardsonadams. com Attorneys for the Industrial Customers of Idaho Power i.ICEIVED ifii* li'iY l9 PH 3: 38 , ' l/\. i-'r -t ,, i. i i,r^^!Atl. 1 r:r,'i :-rl5)lUN BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO IMPLEMENT POWER COST ADJUSTMENT ("PCA") RATES FOR ELECTRIC SERVICE FROM JUNE 1, 2016 THROUGH MAY 31.2017 COMES NOW, The Industrial Customers of ldaho Power ("ICIP") by and through their attomey of record, Peter J. Richardson, and pursuant to that Notice of Application and Notice of Modified Procedure issued by the Idaho Public Utilities Commission ("Commission") in Order No. 33518 and hereby lodges its Comments on Idaho Power Company's ("Idaho Power" or "Company") 201 6-201 7 annual Power Cost Adj ustment ("PCA") Application. THE COMPANY'S PCA SHOULD ACCOUNT FOR KNOWN ANTICIPATED CHANGES IN PURPA POWER SUPPLY EXPENSES As the Commission observed in Order No. 33518, "The Company attributes the proposed [PCA] rate increase primarily to costs associated with power purchase agreements under PURPA, specifically, the addition of new solar contracts." Recent media reports indicate that the Energy Sales Agreement ("ESA") between Idaho Power and Pocatello Solar 1, LLC, (a ) CASE NO. TPC-E-16-08 )) COMMENTS OF THE INDUSTRIAL ) cusToMERS OF IDAHO POWER ) ) ) PURPA agreement)l has been terminated. [f true, accounting for this reduction in Idaho Power's PURPA cost obligations will have a downward impact on the proposed PCA increase this year. The ICIP has served discovery on Idaho Power seeking to confirm the media reports. Currently, however, it is unclear how (and whether) the Company is planning to update the forecast power supply cost component of this year's PCA to account for this possible (and if accurate) anticipated known and measurable change. The ICIP understands the possible termination of the Pocatello Solar l, LLC ESA will result in a twenty megawatt reduction in forecast power supply cost obligations.2 Given the short amount of time before the2016-2017 PCA is to take effect, the ICIP respectfully asks the Commission to require the Company to, when it files its updated PCA to document and, if the media reports are accurate, to account for this change in the final rates to become effective on June 1,2016. DATED this 19th day of May,20l6 Richardson Adams, PLLC By Industrial Customers of Idaho Power I See Applicationfor Energt Sales Agreement with Pocatello Solar I, Order No. 33207 issued on November 21,2014. 2 A copy of the ICIP's production request is attached hereto as Exhibit COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IPC-E-16-08 PAGE 2 LLC in Docket No. IPC-E-14-2. Approved by t. TDAHO POWER CERTIFICATE OF SERVICE I hereby certify that on this 19th day of May 20l6,copies of the foregoing Comments of the Industrial Customers of Idaho Power in Docket No. IPC-E-I6-08 was served electronically and by HAND DELIVERY, to: Lisa Nordstrom Idaho Power Company 1221 West Idatro Boise,Idaho 83702 lnordstrom@ idahopower. com Timothy E. Tatum Idaho Power Company 1221 West ldaho Boise,Idaho 83702 ttatum@ idahopower. com Jean Jewell Secretary Idaho Public Utilities Commission 472West Idatro Boise, Idaho 83702 Jean jewell@puc.idaho. gov Kandi Walters Administrative Assistant COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER IPC-E-16-08 PAGE 3 cAsE NO. IPC-E-16-O8 COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER EXHIBIT # 1 Peter J. Richardson tSB # 3195 Gregory M. Adams ISB # 7454 RICHARDSON ADAMS, PLLC 515 N. 27ft Steet Boise,Idaho 83702 Telephone : Q08) 938-2236 Fax: (208) 938-7904 peter@richardsonadams. com ere u@richardsonadams. com Attorneys for the Industrial Customers of Idaho Power BET'ORE THE IDAHO PUBLIC UTILITIES COMMISSION rN THE MATTER OF TIIE ) CASE NO. rPC-E.16-0E APPLICATION OF IDAHO POWER ) COMPA}IY FOR AUTHORITY TO ) SECOND PRODUCTION REQUEST TMPLEMENT POWER COST ) OF THE INDUSTRIAL CUSTOMERS ADruSTMENT ('PCA',) RATES FOR ) OF IDAHO POWER ELECTzuC SERVICE FROM JUNE 1, ) 2016 THROUGH MAY 3I,2OI7 Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission"), The Industial Customers of Idaho Power ("ICIP") by and through their attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ('Company") provide the following docurrents. This production request is to be considered as continuing, and the Company is requested to provide by way of supplementary respomes additional documents that it or any person acting on its behalf may later obtain that will augment the docunrents produced. Please provide one physical copy and one electronic copy, if available, of your answer to Mr. Richardson at the address noted above, Please provide an additional elechonic copy, or if unavailable a physical copy, to Dr. Don Reading aI 6070 Hili Road, Boise, Idaho 83703, Tel: (208) 3 42-1700; Fax : (208) 3 84- I 5 1 I ; dreading@dndspring.com COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER . EXHIBIT #1 tPc-E-16-08 PAGE,I For each item, piease indicate the name of the person(s) preparing the answers, along with the job title of such personG) and the witness at hearing who can sponsor the answer. REOUEST FOR PRODUCTION NO. 10 On page 10 of the Direct Testimony of ldaho Power witness Matthew Larkin he statcs this year's PCA forecast anticipates an increase of 257,857 MWh of PLIRPA generation over last year's forecast. This increase is largely due to theexpected 320 MW of solar projects. The Pocatello Airport on May 16,2016 announced tle solar project planned on their property has been withdrawn. Please fully answer the following; a) Was the Pocatello Airport solar project included in this year's PCA forecast? b) If so what was the size of the solar project at the Pocatello Airport? c) If so what should be the reduction in the projection of MWh from this year's PCA forecast? d) If so what should be the dollar reduction in the Account 555, PURPA that is included in this year's PCA request by the Company? e) Does the Company inteud to update its Application in this mattq to reflect this change? Why or why not? DATED this 18th day of May,20l6 Industrial Customers of Idaho Power SECOND PRODUCTION REQUEST OF THE INDUSTRTAL CUSTOMERS OF IDAHO POWER rPc-E-16-08 PAGE 2 COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO PO\A/ER - EXHIBIT #1 tPc-E-16-08 PAGE 2 CERTIFICATE OF SERVICE I hereby c€rtiry that on May 3rd, 2016, copies of the foregoing First Production Request of the Indushial Customers of [daho Power in DocketNo. IFC-E-16-08 were served electonically and by HAND DELIVERY, to: \ LisaNordsrom Idaho Power Compaoy l22l West ldaho Boise,Idaho 83702 Timothy E. Tatum Idaho Power Company l22l West ldaho Boise, Idaho 83702 Jean Jewel Soorctary Idaho Public Utilities Com'n 472 West ldatrc Boise, Idaho 83702 C€:e"e/- Administative Assistant SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER IPC-E-16-08 PAGE 3 COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO PO\A/ER - EXHIBIT #1 rPc-E-16-08 PAGE 3 CERTIFICATE OF SERVICE I hereby certift that on May 18, 2016, copies of the foregoing Second Production Request of the Industial Customers of ldatro Power in Docket No. IPC-E-16-08 were served electronically and by HAND DELIVERY, to: \ Lisa Nordstrom Idatro PowerCompany 1221 West ldaho Boise,Idatro 83702 lnordstrom@.idahopower. com Timothy E. Tatum Idaho PowEr Company 1221 West Idaho Boise, tdaho 83702 ttatum@ idahopower. com Jean Jewell Secretary Idaho Public Utilities Commission 472 West Idaho Boise,Idaho 83702 Jean. i ewell@.ouc. idaho. covW Kandi Walters Administative Assi stant SECOND PRODUCTION REQUEST OF TTIE INDUSTRTAL CUSTOMERS OF TDAHO POWER rPC-E-16-08 PAGE 3 COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO PO\A/ER. EXHIBIT#1 rPc-E-16-08 PAGE 4