20180516IPC to JR Simplot 1-20.pdf

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I I I ." ';-r tLliiluDONOVAN E. WALKER
Lead Counsel
[e-mail]
May 16, 2018
VIA HAND DELIVERY
Diane Hanian, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-18-07
Petition for Modification of 901110 Performance Band and Calculation of
O&M Charges for PURPA QFs - ldaho Power Company's Response to J.R.
Simplot Company's First lnterrogatories, Requests for Admission, and
Requests for Production to ldaho Power Company
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Answers and Responses to J.R. Simplot Company's First
lnterrogatories, Requests for Admission, and Requests for Production to ldaho Power
Company
Also, enclosed are four (4) copies each of confidential and non-confidential disks
containing information responsive to the production requests.
Very truly yours,
XP-e-72,^
Donovan E. Walker
DEW:kkt
Enclosures
ft
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
Z0lB H,&Y l6 Pl'l lr: 33
iD.r,i'-i-; PUBLIC
,i-i i i- iTi ::l C0iitl,{ ISS l0N
IN THE MATTER OF THE PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC.,
J.R. SIMPLOT COMPANY, AND
RENEWABLE ENERGY COALITION FOR
MODIFICATION OF THE 9O/1 1O
PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACIL!T!ES
CASE NO. !PC-E-18-07
IDAHO POWER COMPANY'S
ANSWERS AND RESPONSES TO
J.R. SIMPLOT'S FIRST
I NTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS
FOR PRODUCTION TO !DAHO
POWER COMPANY
)
)
)
)
)
)
)
)
)
)
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
answer and response to J.R. Simplot's First lnterrogatories, Requests for Admission,
and Requests for Production to ldaho Power Company dated April 25, 2018, herewith
submits the following information:
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.l
INTERROGATORIES
INTERROGATORY NO. 1: ldentify the employees at ldaho Power who are
responsible for forecasting the output of hydro, wind, solar and other QFs for month-
ahead and day-ahead power supply planning purposes. List the employees in
descending order of decision-making hierarchy and list the job title of each such
employee.
ANSWER TO INTERROGATORY NO. 1: Please see Idaho Power's response
to Interrogatory No. 2.
The Answer to this Interrogatory is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
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 - 2
INTERROGATORY NO. 2: ldentify the employees at Idaho Power who are
responsible for forecasting the output of ldaho Power's company-owned hydro, wind,
solar and other generation projects for month-ahead and day-ahead power supply
planning purposes. List the employees in descending order of decision-making
hierarchy and list the job title of each such employee.
ANSWER TO INTERROGATORY NO. 2: Estimates of generation on a monthly
basis from ldaho Power-owned projects used to determine long-term estimated monthly
energy deliveries to ldaho Power are derived from the monthly Operating Plan as part of
the Company's risk management process. The process used to develop the Operating
Plan forecast is a multi-step, coordinated process that involves a number of separate
analyses prepared by multiple subject matter experts within the Company. The
Operating Plan forecast reflects an economic dispatch of the Company's resources on a
monthly basis segmented into Heavy Load ("HL") and Light Load ("LL') hours. The
following is a summary describing the development of the Operating Plan and the
employees whose responsibilities include the development of the listed components.
1. Market Price Forecast - The market price forecast is the starting point for the
economic dispatch of Company resources. To start, the 18-month load forecast
is divided into monthly HL and LL hours. Two plans are then created: a HL
forecast and a LL forecast. Hub prices are from the Mid-Columbia (Mid-C) and
Palo Verde energy markets and are then developed based upon the forward
price curves published by the lntercontinental Exchange ("lCE"). Border prices
are at the edge of ldaho Power's system and are based on Hub prices, adjusted
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 - 3
for seasonality and transmission to and from the Company's system. Prepared
by Andy Husted, Senior Risk Analyst; Reviewed by Jill Sprenger, Risk Manager.
2. Resource Sfack Development - Once the market price forecast is created, the
resource stack is developed. This process is followed for both the HL and LL
forecast.
a. Public Utility Regulatory Policies Act of 1978 ('PURPA) and Purchased
Power Agreemenfs - The bottom of the "resource stack" begins with the
Company's must run resources: PURPA and Purchased Power
Agreements. ldaho Power's cogeneration and small power production
('CSPP') forecast, which includes all qualifying facility ("QF") projects
under contract, is developed for each project based on a number of
factors including contract estimated generation amounts, most recent 12-
month history, five-year rolling average, project-adjusted estimated net
energy amounts, and any previous or current adjustments. Generally, the
starting point is the rolling five-year historical average of monthly
generation (or shorter if the project has operated less than five years). lf a
project has operated less than one year, the generation estimates from
the project's energy sales agreement ("ESA") are used. The forecasted
generation is adjusted as necessary due to information known to ldaho
Power or by changes in adjusted monthly net energy amounts provided by
the projects. The goal is to create the most accurate estimate as possible
of the actual energy deliveries from each project. Prepared by Michael
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 - 4
Darrington, Energy Contracts Leader; Reviewed by Mike Polito, Power
Supply Operations Senior Manager.
b. Gas - The dispatch price for each unit is determined using gas prices,
including transportation and operations and maintenance ('O&M')
charges, and ambient monthly temperature and unit efficiencies. The
dispatched prices are compared to the market price (the border prices),
and modified to include transmission wheeling costs. lf a unit is
economical, it is shown as being available. Later in the process, the gas
units are compared to the coal units to provide the most economical
dispatch of resources. Prepared by Darren Anderson, Term Transaction
Specialist ll; Reviewed by Eric Race, Gas Transaction Leader.
c. Hydro - Next, the hydro model is run. The hydro model optimizes the use
of water during individual months of the water year. The model uses
updated inflows, market prices, and an updated position (surplus or deficit)
for all components except coal. The model includes any unit constraints,
reservoir levels, flood requirements and minimum flow requirements,
maintenance schedules, and unit generation capacities. The results of the
hydro model are added to the resource stack and an updated position
(surplus or deficit) is passed to the coal forecast. Prepared by Frank
Gariglio, Senior Engineer; Reviewed by Tim Brewer, Principal Engineer,
and Jeff Connor, Engineering Leader.
d. Coal - Following the hydro model run, the coal generation forecast is
prepared. The system HL and LL energy positions are determined using
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 - 5
the current month portfolio. The dispatch price for each plant may be
based on an incremental price of coal or an average price of coal in
inventory, depending on forecast burn levels and contract flexibility
existing at each plant. The dispatch price for each plant is calculated and
compared to the market price forecast, which is modified to include
transmission wheeling costs. Each unit that is economic and included in
the production forecast reduces the system position prior to the next unit
being evaluated. The Bridger and Valmy unit forecasts include estimates
of operations to provide operational system reliability and flexibility. The
reliability energy forecast is not evaluated via the economic dispatch
process. The reliability forecast forms the minimum output levels of the
units and is the starting place for the economic unit dispatch process
described above. The results of the coal generation forecast are added
to the resource stack. Prepared by Elizabeth Finley, Senior Mine
Operations Coordinator; Reviewed by John Carstensen, Joint Projects
Leader.
e. Load Forecast - Once the portfolio of resources has been developed
according to an economic dispatch, it is compared to the system load
forecast. At this point, any new hedging transactions are added to the
resource stack. They are valued at the actual hedge price at that time, not
the market price. The resulting surplus or deficit position translates to
surplus sales or purchased power using a forward market curve.
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 - 6
Prepared by Barr Smith, Lead Planning Analyst; Reviewed by Jordan
Prassinos, Load Research and Forecasting Leader.
f. Hydro Model Rerun - The hydro model is run again prior to the final
portfolio using updated gas and coal forecasts to optimize the water with
the constraints. Because the constraints are fairly severe in most months,
the rerun of the hydro model typically does not significantly change the
outcome of the hydro positions in the portfolio; however, significant
changes in the coal forecast can change the outcome of the portfolio.
Prepared by Karen Flynn, Lead Planning Analyst, and Phil DeVol, Lead
Planning Analyst; Reviewed by Rick Haener, Power Supply Planning
Leader.
3. Final Portfolio - The completion of the resource stack signals the final portfolio to
be used for the Operating Plan. Prepared by Karen Flynn, Lead Planning
Analyst, and Scott Wright, Lead Planning Analyst; Reviewed by Rick Haener,
Power Supply Planning Leader.
Data from the Operating Plan is used by ldaho Power's Load Serving Operations
department in the development of short-term forecasts, to determine trends and
expectations for energy deliveries on a long-term and near-term basis, including day-
ahead. Throughout the month, this process compares balance of month purchases and
sales with ldaho Power available generation, the CSPP forecast and load forecast to
derive a preliminary plan for the day. This process can be performed up to daily if
system generation and loads are changing rapidly. Any time the preliminary plan is
outside of limits of the balance of the month by amounts as small as 1 megawatt
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. T
('MW"), decisions to purchase or sell are made, so the accuracy of the inputs to the
process is critical. The preliminary plan is then forwarded to the day-ahead process,
where the forecasting process updates the preliminary plan to correct short or long
positions, based on three-day trending of average output from generation resources, to
estimate expected deliveries for the upcoming day. Actual deliveries from ldaho Power
available generation resources, CSPP projects, the latest load forecast, and the latest
wind and solar forecasts are all used to determine if the Company is within balancing
limits or if orders need to be filled to balance the system. Prepared by Shaun Jensen -
Term Balancing Operator, Reviewed by Perry Kerfoot, Day Ahead Balancing
Operations Leader.
Generation from wind and solar resources is forecasted using physical and
statistical modeling approaches. ldaho Power uses data output from high resolution
numeric weather prediction models that the Company runs in its operations. These
models are run in one hour incremental output and produce a broad range of
meteorological parameters. For wind, once the initial model output is produced,
statistical methods use the difference between previous predicted and actual wind
speeds to adjust model output parameters. Once model output has been refined, it is
fed into an established power curve designed for each wind project to produce the
generation forecast. The statistical adjustments are applied for the first six hours of the
forecast in a weighted manner so the first hour receives the most adjustment and the
sixth hour receives the least adjustment.
For solar generation forecasting, ldaho Power uses historical solar intensity
observations and forecasts to derive a function that computes future solar intensity for a
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 - 8
given time horizon from a set of forecasted weather metrics. The model formulas are
based on linear least squares regression. Once the initial model output is produced,
statistical methods use the difference between previous predicted and actual solar
intensity to adjust model output parameters. The statistical adjustments are applied for
the first four hours of the forecast in a weighted manner so the first hour receives the
most adjustment and the fourth hour receives the least adjustment. Prepared by the
Power Supply Technical Applications Support group, Ron Tarkowski, Technical
Application Support Leader, and Mel Kunkel, Meteorologist.
The Answer to this lnterrogatory is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
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- 9
INTERROGATORY NO. 3: ldentify the employees at ldaho Power who receive
the monthly adjusted estimated net energy amounts supplied by QFs with the 90/110
Performance Band contract provision. List the employees in descending order of
decision-making hierarchy and list the job title of each such employee.
ANSWER TO INTERROGATORY NO. 3: The monthly estimated net energy
amounts supplied by QFs that are submitted as directed in each QF's ESA are received
by the Energy Contracts team consisting of Michael Darrington, Energy Contracts
Leader, Jerry Jardine, Lead Energy Contracts Coordinator, and Toby Wilson, Lead
Energy Contracts Coordinator.
The Answer to this lnterrogatory is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
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- 1O
INTERROGATORY NO. 4:ldentify the employees at ldaho Power engaged in
accounting of operations and maintenance expenses and assessment of operation and
maintenance charges to interconnection customers that take service under FERC-
jurisdictional interconnections under the Open Access Transmission Tariffs Large
Generator lnterconnection Agreement and Small Generator lnterconnection Agreement.
List the employees in descending order of decision-making hierarchy and list the job title
of each such employee.
ANSWER TO INTERROGATORY NO. 4:The Financial Accounting team is
responsible for calculating and assessing O&M charges to interconnection customers
that take service under FERC-jurisdictional interconnections. The employees involved in
this process in descending order of decision-making hierarchy are Aubrae Sloan,
Accounting Manager, Amber Moody, Accountant ll, and lrene Fewkes, Accountant ll.
The Answer to this lnterrogatory is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
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. 11
INTERROGATORY NO. 5: ldentify the employees at ldaho Power engaged in
accounting of operations and maintenance expenses and assessment of operation and
maintenance charges to interconnection customers that take service under Schedule
72. List the employees in descending order of decision-making hierarchy and list the job
title of each such employee.
ANSWER TO INTERROGATORY NO. 5: The Financial Accounting team is
responsible for calculating and assessing O&M charges to interconnection customers
that take service under Schedule 72. The employees involved in this process in
descending order of decision-making hierarchy are Aubrae Sloan, Accounting Manager,
Amber Moody, Accountant ll, and lrene Fewkes, Accountant ll.
The Answer to this lnterrogatory is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
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 - 12
INTERROGATORY NO. 6:Explain how ldaho Power uses the monthly adjusted
estimated net energy amounts supplied by QFs under their energy sales agreements in
ldaho Power's month-ahead and day-ahead power supply planning activities. lnclude
examples of specific instances where ldaho Power has adjusted its power supply
planning based upon the QF's monthly
adjusted estimated net energy amounts.
ANSWER TO INTERROGATORY NO. 6: ldaho Power's CSPP forecast, which
includes all QF projects under contract, is developed for each project based on a
number of factors including contract estimated generation amounts, most recent 12-
month history, five-year rolling average, project adjusted estimated net energy amounts,
and any previous or current adjustments. Generally, the starting point is the rolling five-
year historical average of monthly generation, or shorter if the project has operated less
than five years. !f a project has operated less than one year, the generation estimates
from the project's ESA are used. ldaho Power uses the monthly adjusted net energy
amounts supplied by QF's to verify information and make adjustments in its preparation
of the CSPP forecast. This forecast is used by the Company as an input to its monthly
Operating Plan forecast and risk management process, which then is integrated with the
Company's day-ahead balancing operations processes.
As described in ldaho Power's answer to Simplot's lnterrogatory No. 2, data from
the Operating Plan is used by ldaho Power's Load Serving Operations department in
the development of short-term forecasts, to determine trends and expectations for
energy deliveries on a long-term and near-term basis, including day-ahead. Throughout
the month, this process compares balance of month purchases and sales with ldaho
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 - 13
Power available generation, any updates to the CSPP forecast, and load forecast to
derive a preliminary plan for the day. This process can be performed up to daily if
system generation and loads are changing rapidly. Any time the preliminary plan is
outside of limits of the balance of the month by amounts as small as 1 MW, decisions to
purchase or sell are made, so the accuracy of the inputs to the process is critical. The
preliminary plan is then fonruarded to the day-ahead process where the forecasting
process updates the preliminary plan to correct short or long positions, based on three-
day trending of average output from generation resources, to estimate expected
deliveries for the upcoming day. Actual deliveries from ldaho Power available
generation resources, CSPP projects, the latest load forecast, and the latest wind and
solar forecasts are all used to determine if the Company is within balancing limits or if
orders need to be filled to balance the system.
The monthly adjusted net energy amounts are used to determine if the
Company's monthly forecasted generation is reasonable, or if adjustments should be
applied based on updated information from the individual QF's. For example, on April
28, 2016, the Simplot-Pocatello QF provided notice to ldaho Power to change the
monthly net energy amount for June 2016, from 5,040,000 kilowatts ("kwh") to
2,181,000 kwh. Based on this adjustment and subsequent energy deliveries during
June, ldaho Power reduced the amount of expected energy deliveries from the Simplot-
Pocatello project in its CSPP forecast. ln another example, multiple times throughout
the past year, the majority of solar QF projects that came online in late 2016 and 2017
submitted adjusted monthly net energy amounts that were generally reductions in
estimated generation from the values contained in the projects' ESAs. ldaho Power has
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- 14
reduced the forecast generation for solar generation in its CSPP forecasts to more
closely align with the adjusted estimates provided by the projects.
The Answer to this lnterrogatory is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
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- 15
INTERROGATORY NO. 7:Explain how ldaho Power forecasts the energy
deliveries made under ESAs that do not contain the 901110 Performance Band. lnclude
description of all differences between the practices used to forecast energy deliveries
from hydro QFs providing monthly adjusted estimated net energy amounts under the
90/1 10 Performance Band and hydro QFs that do not provide monthly adjusted
estimated net energy amounts under the 90/110 Performance Band.
ANSWER TO INTERROGATORY NO. 7: Please see ldaho Power's Response
to Simplot's lnterrogatory No. 6. The process is the same for QF projects that have
ESAs without 90%l11Oo/o requirements, except that projects without 90o/ol110o/o
provisions lack the additional information provided by projects that supply adjusted
amounts, which reduces the accuracy of the CSPP forecast as future adjustments may
not be recognized in the forecast and significant changes to generation amounts may
not be known to ldaho Power until actual historical information is collected and included.
The Answer to this lnterrogatory is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
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.l6
INTERROGATORY NO. 8: For intermittent (wind and solar) QFs that operate
under a mechanical availability guarantee in lieu of the 901110 Performance Band,
explain how ldaho Power forecasts generation from such QFs without receiving monthly
adjusted estimated net energy amounts supplied by the QF.
ANSWER TO INTERROGATORY NO. 8: Please see ldaho Power's response
to Simplot's lnterrogatory No. 6. ln addition, generation from wind and solar resources is
forecasted using physical and statistical modeling approaches. ldaho Power uses data
output from high resolution numeric weather prediction models that the Company runs
in its operations. These models are run in one hour incremental output and produce a
broad range of meteorological parameters.
For wind, once the initial model output is produced, statistical methods use the
difference between previous predicted and actual wind speeds to adjust model output
parameters. Once model output has been refined, it is input into an established power
curve designed for each wind project to produce the generation forecast. The statistical
adjustments are applied for the first six hours of the forecast in a weighted manner so
the first hour receives the most adjustment and the sixth hour receives the least
adjustment.
For solar generation forecasting, ldaho Power uses historical solar intensity
observations and forecasts to derive a function that computes future solar intensity for a
given time horizon from a set of forecasted weather metrics. The model formulas are
based on linear least squares regression. Once the initial model output is produced,
statistical methods use the difference between previous predicted and actual solar
intensity to adjust model output parameters. The statistical adjustments are applied for
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 - 17
the first four hours of the forecast in a weighted manner so the first hour receives the
most adjustment and the fourth hour receives the least adjustment.
The Answer to this lnterrogatory is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
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- 18
INTERROGATORY NO. 9:Explain why ldaho Power does not use the formula-
based operation and maintenance charge in Schedule 72 to assess interconnection
costs to customers that take service under FERC-jurisdictional interconnections under
the Open Access Transmission Tariffs Large Generator lnterconnection Agreement and
Small Generator lntercon nection Agreement.
ANSWER TO INTERROGATORY NO. 9: The Large Generator lnterconnection
Agreement states, " lnterconnection
Customer shall be responsible for all reasonable expenses including overheads,
associated with (1) owning, operating, maintaining, repairing, and replacing
lnterconnection Customer's lnterconnection Facilities; and (2) operation, maintenance,
repair and replacement of Transmission Provider's lnterconnection Facilities." Similarly,
the Small Generator !nterconnection Agreement states, "The !nterconnection Customer
shall be responsible for its share of all reasonable expenses, including overheads,
associated with (1) owning, operating, maintaining, repairing, and replacing its own
lnterconnection Facilities; and (2) operating, maintaining, repairing, and replacing the
Transmission Provider's lnterconnection Facilities." This language does not mandate,
nor prohibit, the use of either actual costs or the "formula-based operation and
maintenance charge in ScheduleT2" as referenced in the above question.
The Answer to this Interrogatory is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
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 - 19
INTERROGATORY NO. 10: ls ldaho Power aware of any other utility in the
United States that assesses operation and maintenance expenses to interconnection
customers based on a formula that assesses a percentage of the initial construction
costs similar to the structure of the formula in Schedule 72. lf so, please identify the
utility, explain the structure of its charge, and location of information available to ldaho
Power on this topic.
ANSWER TO INTERROGATORY NO. 10: No. ldaho Power does not know if
any other utility does, or does not, have similar Operation and Maintenance Obligations
and Expenses provisions as those contained in ldaho Power's Schedule 72.
The Answer to this lnterrogatory is sponsored by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
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.20
REQUESTS FOR ADMISSION
REQUEST FOR ADMISSION NO. 1: Admit or deny that ldaho Power does not
use the monthly adjusted estimated net energy amounts supplied by QFs under their
energy sales agreements for purposes of balancing load and resources on its system
on a day-ahead basis.
RESPONSE TO REQUEST FOR ADMISSION NO. 1:The monthly adjusted
estimated net energy amount estimates are relevant and used for estimates on a
monthly basis. As described in ldaho Power's Response to Simplot's lnterrogatory No.
2, 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.
The Response to this Admission Request is sponsored by Donovan E. Walker,
Lead Counsel, ldaho Power Company.
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 - 21
REQUEST FOR ADMISSION NO. 2: Admit or deny that ldaho Power does not
use the monthly adjusted estimated net energy amounts supplied by QFs under their
energy sales agreements for purposes of balancing load and resources on its system
on a week-ahead basis.
RESPONSE TO REQUEST FOR ADMISSION NO. 2: Deny. The monthly
adjusted estimated net energy amount estimates are relevant and used for estimates on
a monthly basis. As described in ldaho Power's Response to Simplot's lnterrogatory
No. 2, 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 feed are used.
The Response to this Admission Request is sponsored by Donovan E. Walker,
Lead Counsel, ldaho Power Company.
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 - 22
REQUEST FOR ADMISSION NO. 3: Admit or deny that ldaho Power does not
use the monthly adjusted estimated net energy amounts supplied by QFs under their
energy sales agreements for purposes of balancing load and resources on its system
on a two-week-ahead basis.
RESPONSE TO REQUEST FOR ADMISSION NO. 3:Deny. The monthly
adjusted estimated net energy amount estimates are relevant and used for estimates on
a monthly basis. As described in ldaho Power's Response to Simplot's lnterrogatory No.
2, 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.
The Response to this Admission Request is sponsored by Donovan E. Walker,
Lead Counsel, ldaho Power Company.
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 - 23
REQUEST FOR ADMISSION NO. 4: Admit or deny that ldaho Power does not
use the monthly adjusted estimated net energy amounts supplied by QFs under their
energy sales agreements for purposes of power supply planning on its system on a
month-ahead basis.
RESPONSE TO REQUEST FOR ADMISSION NO. 4: Deny. The monthly
adjusted estimated net energy amount estimates are relevant and used for estimates on
a monthly basis. As described in ldaho Power's Response to Simplot's lnterrogatory
No. 2, 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.
The Response to this Admission Request is sponsored by Donovan E. Walker,
Lead Counsel, ldaho Power Company.
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 - 24
REQUEST FOR ADMISSION NO. 5: Admit or deny that ldaho Power assesses
interconnection operations and maintenance expenses to interconnection customers
that take service under FERC-jurisdictional interconnections under the Open Access
Transmission Tariffs Large Generator lnterconnection Agreement and Small Generator
lnterconnection Agreement on a basis of actual costs incurred.
RESPONSE TO REQUEST FOR ADMISSION NO. 5:Deny. The Large
GeneratorlnterconnectionAgreementstates,...
lnterconnection Customer shall be responsible for all reasonable expenses including
overheads, associated with (1) owning, operating, maintaining, repairing, and replacing
lnterconnection Customer's lnterconnection Facilities; and (2) operation, maintenance,
repair and replacement of Transmission Provider's lnterconnection Facilities." Similarly,
the Small Generator lnterconnection Agreement states, "The !nterconnection Customer
shall be responsible for its share of all reasonable expenses, including overheads,
associated with (1) owning, operating, maintaining, repairing, and replacing its own
lnterconnection Facilities; and (2) operating, maintaining, repairing, and replacing the
Transmission Provider's lnterconnection Facilities." This language does not mandate,
nor prohibit, the use of either actual costs or the "formula-based operation and
maintenance charge in Schedule 72" as referenced in Simplot's lnterrogatory No. 9 in
this case.
The Response to this Admission Request is sponsored by Donovan E. Walker,
Lead Counsel, ldaho Power Company.
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 - 25
REQUEST FOR ADMISSION NO. 6: Admit or deny that ldaho Power does not
assess interconnection operations and maintenance expenses to interconnection
customers that take service under FERC-jurisdictional interconnections under the Open
Access Transmission Tariffs Large Generator lnterconnection Agreement and Small
Generator lnterconnection Agreement on the basis of the formula contained in Schedule
72.
RESPONSE TO REQUEST FOR ADMISSION NO. 6: Deny. The Large
GeneratorlnterconnectionAgreementstates,,..
lnterconnection Customer shall be responsible for all reasonable expenses including
overheads, associated with (1) owning, operating, maintaining, repairing, and replacing
lnterconnection Customer's lnterconnection Facilities; and (2) operation, maintenance,
repair and replacement of Transmission Provider's lnterconnection Facilities." Similarly,
the Small Generator lnterconnection Agreement states, "The lnterconnection Customer
shall be responsible for its share of all reasonable expenses, including overheads,
associated with (1) owning, operating, maintaining, repairing, and replacing its own
lnterconnection Facilities; and (2) operating, maintaining, repairing, and replacing the
Transmission Provider's lnterconnection Facilities." This language does not mandate,
nor prohibit, the use of either actual costs or the "formula-based operation and
maintenance charge in Schedule 72" as referenced in Simplot's lnterrogatory No. 9 in
this case.
The Response to this Admission Request is sponsored by Donovan E. Walker,
Lead Counsel, ldaho Power Company.
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 - 26
REQUESTS FOR PRODUCTION
REQUEST FOR PRODUCTION NO. 1: Please provide a list of all QFs that
supplied power to ldaho Power at any time after January 1, 2008 or that have energy
sales agreements but have not yet started to make deliveries. For each of these QFs,
please provide the following information: name, contract capacity, nameplate capacity
(if known and different than contract capacity), primary fuel (e.9, hydro, wind, solar,
geothermal, cogeneration, etc.), point of interconnection, commercial operation date,
date of last generation (if not still in operation) and whether the energy sales agreement
contains the 90/1 10 Performance Band.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1 The following table
provides the requested information
Project Name
Contract/
Nameplate
Capacity
Facility
Tvpe
Operation
Date
Date of
Last
Generation
ESA
Contains
90ILLO
Point of
lnterconnection
American Falls Solar ll, LLC
American Falls Solar, LLC
Arena Drop
86 Anaerobic Digester
Baker City Hydro
Baker Solar Center
Bannock County Landfill
Barber Dam
Bennett Creek Wind Farm
Benson Creek Windfarm
Bettencourt Dry Creek Biofactory
Big Sky West Dairy Digester (DF-AP #1,
LLC)
Birch Creek
Black Canyon #3
Black Canyon Bliss Hydro
Blind Canyon
Box Canyon
Briggs Creek
Brush Solar
Burley Butte Wind Park
Bypass
Camp Reed Wind Park
Canyon Springs
Cassia Wind Farm LLC
Cedar Draw
Clear Springs Trout
20.00
20.00
0.45
2.28
0.24
15.00
3.20
3.70
21.00
10.00
2.2s
1.50
0.05
0.14
0.03
1.53
0.36
0.60
2.75
21.30
9.96
22.s0
0.13
10.50
1.55
0.52
Solar
Solar
Hydro
Biomass
Hydro
Solar
Biomass
Hydro
Wind
Wind
Biomass
-t12.7439
-112.7439
-116.9613
-7L4.6234
-117.854r
-t17.7553
-772.3730
-115.1213
-175.4776
-177.3440
-174.2273
42.8270
42.8270
43.7L93
42.7L56
44.7672
44.7L55
42.7830
43.5613
43.0518
44.3670
42.4256
Biomass
Hydro
Hydro
Hydro
Hydro
Hydro
Hydro
Solar
Wind
Hydro
Wind
Hydro
Wind
Hydro
Hydro
-t74.7982
-1L4.8984
-LL4.7279
-tt4.9532
-tr4.8223
-LI4.8253
-tL4.82LO
-ttB.2057
-113.9125
-114.0586
-11s.0555
-L14.4772
-115.0131
-114.6585
-1L4.828L
42.8523
42.8534
43.0340
42.905t
42.6998
42.7003
42.6775
44.4664
42.5003
42.5589
42.8t81
42.6056
42.8777
42.6267
42.7049
3hl2Ot7
3l!2017
slLlaOLO
shlzOtO
9ltl2OLs
Not Online
s/Ll2OL4
4ltoh989
t2/rs/2008
3l23l2OL7
s/3l20LO
TlLslzo0s
tuLlLss4
4/t6/t984
tols/201s
72lt6l2OL4
217L17984
101101t98s
Not Online
2lllIOLL
6lt8hs88
t2l31l20LO
70/7h984
3/2412009
6/Llt984
7112h983
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
No
Yes
Yes
No
No
Yes
Yes
No
No
No
No
No
No
No
Yes
No
No
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- 27
Pro.iect Name
Contract/
Nameplate
Capacity
Facility
Type
Operation
Date
Date of
Last
Generation
ESA
Contains
90lrLO
Point of
lnterconnection
co-GEN CO
Cold Springs Windfarm
Crystal Springs
Curry Cattle Company
Desert Meadow Windfarm
Dietrich Drop
Double A Digester Project
Durbin Creek Windfarm
Eightmile Hydro Project
Elk Creek
Falls River
Fa rgo Drop Hydroelectric
Faulkner Ranch
FightinB Creek Landfill Gas to Energy
Station
Fisheries Dev.
Fossil Gulch Wind
Geo-Bon #2
Golden Valley Wind Park
Grand View PV Solar Two
Grove Solar Center, LLC
Hailey Cspp
Hammett Hill Windfarm
Hazelton A
Hazelton B
Head of U Canal Project
Hidden Hollow Landfill Gas
High Mesa Wind Project
Horseshoe Bend Hydro
Horseshoe Bend Wind
Hot Springs Wind Farm
Hyline Solar Center, LLC
lD Solar 1
Jett Creek Windfarm
Jim Knight
Kasel & Witherspoon
Koyle Small Hydro
Lateral # 10
Lemoyne
Lime Wind Energy
Little Wood River Ranch ll
Little Wood Rvr Res
Littlewood / arkoosh
Low Line Canal
Low Line Midway Hydro
Lowline #2
Magic Reservoir
Magic Valley
Magic West
Mainline Windfarm
Malad River
Marco Ranches
MC6 Hydro
Mile 28
Mill Creek Hydroelectric
-Lt8.7'1,44
-tt'.4022
-114.5495
-114.5505
-115.4408
-1L4.2682
-114.4655
-1t7.3230
-1,t3.4872
-1 16.3162
-1 1 1.3367
-116.8997
-115.0255
44.4620
43.03s9
42.6366
42.5444
43.0s39
42.8361
42.857t
44.3530
44.736L
45.2r18
44.0623
43.6250
42.9523
10.00
23.00
2.44
0.22
23.00
4.50
4.50
10.00
0.35
2.00
9.10
L.27
0.87
3.05
0.26
10.50
0.93
12.OO
80.00
5.00
0.06
23.00
8.10
1.60
L.28
3.20
40.00
9.s0
9.00
21.00
9.00
40.00
10.00
0.34
0.90
r.25
2.06
0.08
3.00
1.25
2.8s
0.87
7.97
2.s0
2.79
9.07
10.00
10.00
23.00
0.62
t.20
2.L0
1.50
0.80
Biomass
Wind
Hydro
Hydro
Wind
Hydro
Biomass
Wind
Hydro
Hydro
Hydro
Hydro
Hydro
Biomass
Hydro
Wind
Hydro
Wind
Solar
Solar
Hydro
Wind
Hydro
Hydro
Hydro
Biomass
Wind
Hydro
Wind
Wind
Solar
Solar
Wind
Hydro
Hydro
Hydro
Hydro
Hydro
Wind
Hydro
Hydro
Hydro
Hydro
Hydro
Hydro
Hydro
Thermal
Thermal
Wind
Hydro
Hydro
Hydro
Hydro
Hydro
-115.9300
-LL4.8739
-Lt4.9452
-tr4.4630
-113.9069
-115.0150
-117.3840
-114.3142
-1-15.4604
-114.0599
-r-14.0930
-114.3903
-LL6.2866
-1r-5.0286
-Lt6.2442
-ttt.4707
-115.4594
-LL6.9870
-1 16.3 193
-r17.2740
-114.6089
-LLA.4345
-r14.7955
-114.8905
-114.8839
-LLl.2682
-LL4.5275
-Lt4.0254
-1t4.5744
-tt4.3097
-LL4.3223
-tt4.3796
-LL4.3742
-1 13.6805
-LLs.2932
-1L5.4120
-7t4.8292
-11_4.5573
-116.3581
-1,14.t6t7
-177.7637
41 .5320
42.8239
42.8580
42.9544
42.4455
43.0250
43.9350
43.5562
43.0113
42.5870
42.605t
42.7628
43.6981
42.8802
43.9047
47.5064
43.0287
44.1520
43.4332
44.4250
42.9277
42.5923
42.9451
42.6475
42.7598
44.4004
42.96t7
43.4252
42.9604
42.4940
42.49LL
42.4773
43.2393
42.6069
42.9539
43.0481
42.8700
42.638L
43.48Lt
42.7398
45.283t
4lu2Ot4
713/L990
9l30lzOOs
LL/Ls/1986
217l2O1.r
r2113/20L6
tol22/2OL6
6l2s/t98s
1.2/812072
3/7lzOLt
slsltee3
6/2lZots
Llr/2007
t2/2712012
9lr3hsss
2128/2006
r2lLs/2OO8
rthgl2016
8l1612076
312312077
6lL0lt98s
3141L984
4/2/t984
sl4/L98s
6123h98s
t2l9/z1tt
LO19l20ts
2/241L98s
8l8hs86
sltlt98s
8/L7l2OO7
4/291t988
6lLhsss
7112u1996
t2/2/1e96
12/8/2012
s/t|1984
8/LlL98s
Not Online
6ltlt9s4
r0lll2oLL
7lrl2077
t2l8/20L2
41111986
6lL6lL983
L2/8l2Ot2
8/291L988
7lrl2012
3/2312Or7
LOl28l2074
slt6lLe86
8/221L993
4128/2013
slLs/L987
t2l3L/2OtL
LLl2tl20L6
t2l3t/2009
No
No
No
Yes
No
No
Yes
No
Yes
No
No
Yes
No
No
No
Yes
No
No
No
No
No
No
Yes
No
Yes
Yes
No
No
Yes
Yes
No
Yes
No
No
No
No
No
No
No
Yes
No
No
No
Yes
No
No
No
No
No
No
No
Yes
No
No
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 - 28
6/30/2017
Project Name
Contract/
Nameplate
Capacity
Facility
Type
Operation
Date
Date of
Last
Generation
ESA
Contains
90ltto
Point of
lnterconnection
Milner Dam Wind
Mitchell Butte
Mora Drop Small Hydroelectric Facility
Morgan Solar
Mt. Home Solar 1, LLC
Mud Creek S and S
Mud Creek/White
Murphy Flat Power, LLC
North Gooding Main Hydro
Ontario Solar Center
Open Range Solar Center, LLC
Orchard Ranch Solar, LLC
Oregon Trail Wind Park
Owyhee Dam Cspp
Payne's Ferry Wind Park
Pigeon Cove
Pilgrim Stage Station Wind Park
Pocatello Waste
Pristine Springs #1
Pristine Springs #3
Prospector Windfarm
Railroad Solar Center, LLC
Reynolds lrrigation
Rock Creek #1
Rock Creek #2
Rock Creek Dairy
Rockland Wind Farm
Ryegrass Windfarm
5agebrush
Sahko Hydro
Salmon Falls Wind
Sawtooth Wind Project
Schaffner
Shingle Creek
Shoshone #2
Shoshone CSPP
Simcoe Solar, LLC
Simplot - Pocatello
SISW LFGE
Snake River Pottery
Snedigar
Tamarack CSPP
Tasco - Nampa
Tasco - Twin Falls
Thousand Springs Wind Park
Thunderegg Solar Center, LLC
Tiber Dam
Trout-Co
Tuana Gulch Wind Park
Tuana Springs Expansion
Tunnel #1
Two Ponds Windfarm
Vaagen Brothers
Vale Air Solar Center, LLC
Vale I Solar
79.92
2.09
1.85
3.00
20.00
0.52
0.21
20.00
1.30
3.00
10.00
20.00
13.50
5.00
21.00
1.89
10.50
0.46
0.10
0.20
10.00
4.50
0.26
2.r7
1.90
4.00
80.00
23.00
0.43
0.s0
22.00
22.00
0.s3
0.22
0.s8
0.36
20.00
15.90
s.00
o.o7
0.54
5.00
2.00
3.00
12.00
10.00
7.50
0.24
10.50
35.70
7.OO
23.00
4.50
10.00
3.00
Wind
Hydro
Hydro
Solar
Solar
Hydro
Hydro
Solar
Hydro
Solar
Solar
Solar
Wind
Hydro
Wind
Hydro
Wind
Biomass
Hydro
Hydro
Wind
Solar
Hydro
Hydro
Hydro
Biomass
Wind
Wind
Hydro
Hydro
Wind
Wind
Hydro
Hydro
Hydro
Hydro
Solar
CoGen
Biomass
Hydro
Hydro
Biomass
Thermal
Thermal
Wind
Solar
Hydro
Hydro
Wind
Wind
Hydro
Wind
Biomass
Solar
Solar
-114.0106
-117.1555
-tL6.4727
-117.0730
-7t5.7364
-1_14.82L1
-71,4.7916
-tt6.4347
-114.5534
-rL7.0277
-1 17.0610
- 115.2899
-LL4.9943
-tt7.2428
-115.0045
-114.5945
-115.0031
-112.5t78
-r14.4879
-114.5003
-1t7.2550
-tr7.Lo20
-116.6007
-114.5358
-114.5330
-1r4.6187
-Lt2.8750
-115.4449
-774.5923
-114.6383
-114.9979
-115.3939
-113.6514
-116.4035
-114.4539
-1.74.453t
-115.9438
-1.12.5278
-114.0093
-114.9185
-774.7568
-115.3871
-776.5744
-114.4316
-114.9595
-116.9870
-1 1 1.0932
-114.9031
-tt4.9778
-1 15.0333
-tL7.24tL
-tts.4922
-1 17.9 153
-t17.2580
-Lt7.4432
42.4740
43.77L6
43.4601
43.9510
43.1299
42.5055
42.6518
43.2t3L
43.0256
44.LT33
43.7970
43.4595
42.8409
43.6418
42.8258
42.6383
42.7959
42.9t50
42.6L38
42.62t5
44.4L80
43.9990
43.3420
42.6315
42.6204
42.5057
42.6899
43.0417
42.9472
42.65\8
42.6886
42.9883
45.0754
4s.3538
42.9522
42.9s22
43.2837
42.9093
42.4663
42.8834
42.6615
44.9547
43.5055
42.5326
42.8730
43.93s0
48.3233
42.8398
42.8406
42.8452
43.6420
43.0252
48.5459
43.9530
44.L578
2lLl2OLL
5/].8/1989
elLsl2006
Not Online
3121120L7
2/20/20t7
1l10lt986
4lLl2O77
70l8l2016
Not Online
to/t2/2076
3ltl2OL7
r/2sl2or]-
8/tohess
72137/zOtO
1013L11984
LltT/2O1.L
1213L1198s
sl!2ors
shl2oLs
3/23120L7
12/6/2016
slL9/t986
LlL6120L8
4/21]-989
8lt3/20t2
72lsl20rr
1218120L2
elrhsss
2117l20tt
4l22l20LL
7]-l7l20Lr
8/8/7986
8/rl2017
sltl1996
2l16l2OL7
3/tl2017
3/tl2OL6
Not Online
tLl30lt984
rlrlt98s
6lthe83
e/r/2oo3
8lt]-l2OOL
7h7l2ltr
tLl29/2OL6
6lrl2004
L2/L/1986
t/2s/2017
s11.4/2OtO
6l8lLes3
t2/8l2Or2
9lLlt99s
ttl9/2016
Not Online
ru3t/2009
No
No
Yes
No
Yes
Yes
No
Yes
Yes
No
No
Yes
No
No
No
No
No
No
Yes
Yes
No
No
No
Yes
No
Yes
No
No
No
Yes
No
No
No
Yes
No
Yes
Yes
Yes
Yes
No
No
Yes
No
No
No
No
Yes
No
No
No
No
No
No
No
No
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 - 29
Project Name
Contract/
Nameplate
Capacity
Facility
Type
Point of
lnterconnection
Operation
Date
Date of
Last
Generation
ESA
Contains
90ltto
White Water Ranch
Willow Spring Windfarm
Wilson Lake Hydro
Yahoo Creek Wind Park
0.16
10.00
8.40
21.00
Hydro
Wind
Hydro
Wind
-r-14.91-00
-7L7.2730
-114.1860
-114.9991
42.8763
44.3820
42.6309
42.7740
811/t98s
3/2312017
s/t8l1ss3
t2/31/20L0
No
No
No
No
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, Idaho Power Company.
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 - 30
REQUEST FOR PRODUCTION NO. 2: Please provide a list of all hydro projects
owned by ldaho Power that generated power at any time between January 1, 2008 and
the present. For each of these hydro projects, please provide the following information:
name, water source (e.9., Snake River), nameplate capacity, planning capacity (if
different than nameplate capacity), water flow at nameplate/planning capacity (in cfs), at
site storage (in sfd), upstream storage controlled by ldaho Power (in sfd) and upstream
storage controlled by entities other than Idaho Power (in sfd).
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The following table
includes the requested information; however, storage is reported in acre-feet rather than
sfd to match standard water management reporting units. The table does not include
planning capacity or water flow at planning capacity as ldaho Power does not use a
single planning flow or capacity because flows can vary significantly throughout the
year. Not all upstream storage is reflected in the table as unreported volume is generally
confined to small reservoirs that are privately held.
Proiect Water Source
Nameplate
Capacity
(Mw)
Water Flow
at
Nameplate
(cfs)
At Site
Storage,
ldaho
Power
Controlled
(ac-ft)
At Site
Storage,
Non-ldaho
Power
Controlled
(ac-ft)
Upstream
Storage,
ldaho
Power
Controlled
(ac-ft)"
Upstream
Storage, Non-
ldaho Power
Controlled
(ac-ft)'
American Falls
Milner
Twin Falls
Shoshone Falls
Clear Lakes
Thousand Springs
Upper Salmon B
Upper Salmon A
Lower Salmon
Upper Malad
Lower Malad
Bliss
C.J. Strike
Swan Falls
Cascade
Brownlee
Oxbow
Hells Canyon
Snake River
Snake River
Snake River
Snake River
Clear Lake
Thousand Springs
Snake River
Snake River
Snake River
Malad River
Malad River
Snake River
Snake River
Snake River
NF Payette River
Snake River
Snake River
Snake River
L,628,3L5
34,000
0
0
0
0
0
0
0
0
0
0
0
0
5s3,200
0
0
0
44,275
44,275
45,L70
45,544
0
0
45,659
45,659
0
0
50,974
87,774
94,519
0
L,069,837
t,o75,o37
1,086,837
4,445,855
4,575,055
4,575,055
4,575,O55
0
0
4,575,055
4,S7S,Oss
4,575,055
222,O@
222,OO0
4,797,055
4,797,O55
4,797,Oss
6s3,200
7,88L,295
7,88t,295
7,88L,295
15,000
5,640
4,935
876
475
560
6,s00
6,s00
16,000
800
L,200
16,800
15,000
15,000
2,300
34,700
26,000
30,000
44,275
0
895
374
0
0
115
0
4,100
0
0
L,215
36,800
6,745
0
975,318
5,200
11,800
49,759
" Reported upstream storage includes the at site storage listed for each project
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 - 31
92.34
59.448
52.897
L2.5
2.5
6.8
16.5
18
60
8.27
13.5
7S
89
27.L7
L2.42
585.4
190
391.5
The Response to this Production Request is sponsored by Frank Gariglio, Senior
Engineer, ldaho Power Company.
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 - 32
REQUEST FOR PRODUCTION NO. 3: For each QF listed in the response to
Production Request 1 whose energy sales agreement contains the 90/110 Performance
Band, please provide a copy of the energy sales agreement and any amendments.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The ESA and any
amendments containing 90/1 10 requirements that are listed in the Company's response
to Simplot's Production Request No. 1 are publicly available from the ldaho Public
Utilities Commission website.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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 - 33
REQUEST FOR PRODUCTION NO. 4: Has ldaho Power allowed any QFs
whose energy sales agreements contain the 90/110 Performance Band to adjust their
net energy amounts other than as specifically permitted under the express terms of the
ESAs and any applicable amendments? lf so, please describe the terms allowed for
these adjustments and provide any communications with QFs pertaining to these
adjustments.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: No. Any adjustments
to net energy amounts as allowed in ESAs have been made in accordance with the
terms and conditions of the ESAs; however, certain conditions have occurred where
ldaho Power has agreed to allow adjustments to monthly net energy amounts prior to a
project's first energy date or operation date. For example, two instances were for solar
projects that requested to adjust the monthly estimated net energy amount prior to
making any deliveries to ldaho Power under a First Energy Date or an Operation Date.
The changes were allowed under the specific circumstances that occurred at the time
the requests were made and were specific to the discussions between the parties to the
individual ESAs. Please see Attachments 1 and 2 for communications between ldaho
Power and the QF's.
Aside from contract provisions for making claims of Seller Declared Suspensions
of Energy Deliveries or Force Majeure events, ldaho Power administers and enforces
the terms of its ESAs with QFs and does not allow Seller adjustments of estimated net
energy amounts that are not permitted according to the schedules and terms in each
applicable ESA.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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- 34
REQUEST FOR PRODUCTION NO. 5: For each non-wind/non-solar QF listed
in the response to Production Request 1, please provide monthly generation (in MWh)
in Excel spreadsheet format for each month from January 2008 through the most recent
month available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the
confidential Excel spreadsheet provided on the confidential CD.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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- 35
REQUEST FOR PRODUCTION NO. 6: For each non-wind/non-solar QF listed
in the response to Production Request 1 whose ESA contains the 90/110 Performance
Band, please provide the monthly adjusted estimated net energy amounts (in MWh) in
Excel spreadsheet format used to determine compliance with the 90/1 10 Performance
Band for each applicable month from January 2008 through the most recent month
available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please see the
confidential attachment provided in response to Simplot's Request for Production No. 5.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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 - 36
REQUES:Foreachnon-wind/non-solarQFlisted
in the response to Production Request 1 whose ESA contains the 90/110 Performance
Band, please indicate whether the monthly adjusted estimated net energy amounts
were below (<90%), within (90- 110%) or above (110Yo) the 90/110 Performance Band
for each month from January 2008 through the most recent month available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: ln order to provide an
answer to this request, ldaho Power assumes that this request is asking if actual
monthly energy deliveries from non-wind/non-solar QFs were below 90% within g0-
110o/o or above 110o/o of monthly adjusted net energy amounts, rather than estimated. lf
this is the case, please see the confidential attachment provided in response to
Simplot's Request for Production No. 5.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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- 37
REQUEST FOR PRODUCTION NO. 8: For each wind or solar QF listed in the
response to Production Request 1 whose ESA contains the 90/110 Performance Band,
please provide monthly generation (in MWh) in Excel spreadsheet format for each
month from January 2008 through the most recent month available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: P|ease see thE
confidential attachment provided in response to Simplot's Request for Production No. 5.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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 - 38
REQUEST FOR PRODUCTION NO. 9: For each wind or solar Q F listed in the
response to Production Request !whose ESA contains the 90/110 Performance Band,
please provide the monthly adjusted estimated net energy amounts (in MWh) in Excel
spreadsheet format used to determine compliance with the 90/1 10 Performance Band
for each applicable month from January 2008 through the most recent month available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Please see the
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- 39
confidential attachment provided in response to Simplot's Request for Production No. 5.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
REQUEST FOR PRODUCTION NO. 10: For each wind or solar QF listed in the
response to Production Request 1 whose ESA contains the 90/110 Performance Band,
please indicate whether the monthly generation was below (<90%), within (90-1 10%) or
above (110o/o) the 90/110 Performance Band for each month from January 2008
through the most recent month available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Please see the
confidential attachment provided in response to Simplot's Request for Production No. 5.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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 - 40
REQUEST FOR PRODUCTION NO. ,t:t: For each hydro project owned by Idaho
Power, please provide monthly generation (in MWh) for each month from January 2008
through the most recent month available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: Please see the
confidential Excel spreadsheet provided on the confidential CD for the requested
information.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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 - 41
REQUEST FOR PRODUCTION NO. 12: Provide total generation (MWh) of all
non-intermittent QFs selling to ldaho Power for each hour for the past 3 years, in excel
spreadsheet format. For purposes of this request, "intermittent" means wind or solar
powered QF.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Please see the
confidential attachments provided in response to Simplot's Requests for Production
Nos. 13and 14.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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 - 42
REQUEST FOR PRODUCTION NO. 13: Provide total generation (MWh) of all
hydropower QFs selling to ldaho Power for each hour for the past 3 years in excel
spreadsheet format.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: Please see the
confidential Excel file provided on the confidential CD. The data provided is for each
hydro QF that hourly data is available. The data is provided in kWh, as that is the level
of measure for generation read at the meter. Negative values represent generation
while positive values represent consumption. For other hydro QFs that are not included,
meter data is based on end of month customer meter reads.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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 - 43
REQUEST FOR PRODUCTION NO. 14: Provide total generation (MWh) of all
QFs that would be categorized as "other" on ldaho Power's published rate schedules
selling to ldaho Power in for each hour for the past 3 years excel spreadsheet format.
RESPONSE TO REOUEST FOR PRODUCTION NO. 14: Please see the
confidential Excel file provided on the confidential CD. The data provided is for each
"other" QF that hourly data is available. The data is provided in kWh, as that is the level
of measure for generation read at the meter. Negative values represent generation
while positive values represent consumption. For other QFs that are not included, meter
data is based on end of month customer meter reads.
The Response to this Production Request is sponsored by Michael Darrington,
Energy Contracts Leader, ldaho Power Company.
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 - 44
REQUEST FOR PRODUCTION NO. 15: For each year since 1990, provide: (i)
an accounting of the total amount collected by ldaho Power under the Schedule 72
operation and maintenance charges, and (ii) an accounting of the total cost incurred by
ldaho Power for operation and maintenance expenses on QF interconnections.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Please see the
attached Excel spreadsheet for the total amount collected by ldaho Power under the
Schedule 72 O&M charges since 2002. These amounts represent actual revenue
recorded to the general ledger, which may be different than the data provided in
Simplot's Request for Production No. 16 due to timing differences. General ledger data
from 1990 through 2001 is not readily available, due to both a change in general ledger
accounting systems used and a change in the level of detail that these transactions
were recorded and identified at. Please note that these collections also include O&M
charges collected from contracts that were signed prior to the implementation of
Schedule 72.
ldaho Power does not separately track actual costs incurred for O&M expenses
on QF interconnections. Once these projects are placed into service, they are deemed
a part of ldaho Power's plant the same as any other plant that is non-customer funded
and the cost of maintaining (or replacing) this equipment is paid for by all ldaho Power
customers, with an offsetting revenue credit for the amounts collected through the O&M
charge assessed to QF interconnections.
The Response to this Production Request is sponsored by Aubrae Sloan,
Accounting Manager, ldaho Power Company.
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 - 45
REQUEST FOR PRODUCTION NO. 16: For each QF project listed in the
response to Production Request 1, please provide: (i) the amount collected by ldaho
Power for Schedule 72 interconnection O&M charges and (ii) the actual interconnection
O&M expenses incurred by ldaho Power for each year that the QF project was in
operation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Please see the
attached Excel spreadsheet for the amount collected by ldaho Power for Schedule 72
interconnection O&M charges. Please note that these collections also include O&M
charges collected from contracts that were signed prior to the implementation of
Schedule 72.
As stated in ldaho Power's Response to Simplot's Production Request No. 15,
ldaho Power does not separately track actual costs incurred for O&M expenses on QF
interconnections. Once these projects are placed into service, they are deemed a part
of ldaho Power's plant the same as any other plant that is non-customer funded and the
cost of maintaining (or replacing) this equipment is paid for by all ldaho Power
customers, with an offsetting revenue credit for the amounts collected through the O&M
charge assessed to QF interconnections.
The Response to this Production Request is sponsored by Aubrae Sloan,
Accounting Manager, ldaho Power Company.
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 - 46
REQUEST FOR PRODUCTION NO. 17: Provide an accounti ng of actual
operation and maintenance costs incurred by ldaho Power for the interconnection
facilities used for the QF at the J.R. Simplot Company's Don Plant. For each amount
incurred by ldaho Power, please include the date, the work performed, equipment
supplied, or description of other expenses, with supporting documents.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: As stated in ldaho
Power's Response to Simplot's Production Request No. 15, ldaho Power does not
separately track actual costs incurred for O&M expenses on QF interconnections. Once
these projects are placed into service, they are deemed a part of ldaho Power's plant
the same as any other plant that is non-customer funded and the cost of maintaining (or
replacing) this equipment is paid for by all ldaho Power customers, with an offsetting
revenue credit for the amounts collected through the O&M charge assessed to QF
interconnections.
The Response to this Production Request is sponsored by Aubrae Sloan,
Accounting Manager, ldaho Power Company.
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 - 47
REQUEST FOR PRODUCTION NO. 18: Provide an accounti ng of all the
payments made by the J.R. Simplot Company to ldaho Power under Schedule 72
organized chronologically for each month J.R. Simplot Company has paid ldaho Power
under its ESA and/or Schedule 72for the QF at the J.R. Simplot Company's Don Plant.
RESPONSE TO REQUEST FOR PRODUCTION NO. {8: Please see the
attached Excel spreadsheet for all payments made by J.R. Simplot Company to ldaho
Power under Schedule 72 for the Don Plant. Please note that the dates included in the
attachment are the generation month that the O&M was assessed, not the dates the
payments were made.
The Response to this Production Request is sponsored by Aubrae Sloan,
Accounting Manager, ldaho Power Company.
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 - 48
REQUEST FOR PRODUCTION NO. 19: Provide an accounti ng of actual
operation and maintenance costs incurred by ldaho Power for the interconnection
facilities used for the QF at the Magic Reservoir Hydroelectric Plant. For each amount
incurred by ldaho Power, please include the date, the work performed, equipment
supplied, or description of other expenses, with supporting documents.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: As stated in ldaho
Power's Response to Simplot's Production Request No. 15, ldaho Power does not
separately track actual costs incurred for O&M expenses on QF interconnections. Once
these projects are placed into service, they are deemed a part of ldaho Power's plant
the same as any other plant that is non-customer funded and the cost of maintaining (or
replacing) this equipment is paid for by all ldaho Power customers, with an offsetting
revenue credit for the amounts collected through the O&M charge assessed to QF
interconnections.
The Response to this Production Request is sponsored by Aubrae Sloan,
Accounting Manager, ldaho Power Company.
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.49
REQUEST FOR PRODUCTION NO. 20: Provide an accounting of all the
payments made by the Magic Reservoir Hydroelectric to ldaho Power under Schedule
72 organized chronologically for each month under its energy sales agreement and/or
Schedule 72 for the QF at the Magic Reservoir Hydroelectric Plant.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Please see the
attached Excel spreadsheet for all payments made by Magic Reservoir Hydroelectric to
ldaho Power under Schedule 72 for the Magic Reservoir Hydroelectric Plant. Please
note that the dates included in the attachment are the generation month that the O&M
was assessed, not the dates the payments were made.
The Response to this Production Request is sponsored by Aubrae Sloan,
Accounting Manager, ldaho Power Company.
DATED at Boise, ldaho, this 16th day of May 2018.
DONOVAN E R
Attorney for ldaho Power Company
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 - 50
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 16th day of May 20181 served a true and correct
copy 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 upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Edith L. Pacillo
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Company
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
ldahydro and Shorock Hydro, lnc.
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
Renewable Energy Coalition
J. Kahle Becker
Attorney at Law
223 North 6th Street, Suite 325
Boise, ldaho 83702
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
q req@ richa rdsonadams. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email dreadinq(@mindspring.com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
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 - 51
lrion Sanger
SANGER LAW, P.C.
1117 SW 53'd Avenue
Portland, Oregon 97215
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email irion r-law.com
,r^4/10
T l, Executive Assistant
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- 52