20180516IPC to JR Simplot 21-22.pdf

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RECEIVED
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DONOVAN E. WALKER
Lead Counsel
[e-mail]
t/
SSION
May 16,2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho 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 Second Set of 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 Response to J.R. Simplot Company's Second Set of Requests for
Production to ldaho Power Company
Also, enclosed are four (4) copies of non-confidential disks containing information
responsive to these production requests.
Very truly yours,
Donovan E. Wa r
DEW:kkt
Enclosures
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@ id a hopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
2fi!$ FIAY I 6 Pt'l lr: 35
iL:rEilti i'iJBLlC
I t.i 1i Ii'l i:s t'JtEfu{lssloN
IN THE MATTER OF THE PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC.,
J.R. SIMPLOT COMPANY, AND
RENEWABLE ENERGY COALITION FOR
MODIFICATION OF THE 9O/110
PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITIES
CASE NO. IPC.E-18.07
IDAHO POWER COMPANY'S
RESPONSE TO J.R. SIMPLOT
COMPANY'S SECOND SET OF
REQUESTS FOR PRODUCTION TO
IDAHO POWER COMPANY
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COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to J.R. Simplot Company's Second Set of Requests for Production to ldaho
Power Company dated April 30, 2018, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT COMPANY'S
SECOND SET OF REQUESTS FOR PRODUCTION TO IDAHO POWER COMPANY - 1
REQUEST FOR PRODUCTION NO. 21: Please provide ldaho Power's monthly
system load (in MWh) in Excel spreadsheet format for each month from January 2008
through the most recent month available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: Please see the Excel
spreadsheet for the requested information.
The Response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT COMPANY'S
SECOND SET OF REQUESTS FOR PRODUCTION TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 22: Please provide ldaho Power's system
load for each hour (in MWh) in Excel spreadsheet format for the three years preceding
the date of production requests 12, 13, and 14, i.e. the same dates as used for the data
supplied in response to those production requests.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: Please see the Excel
spreadsheet for the requested information.
The Response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
DATED at Boise, ldaho, this 16th day of May 2018.
DON E
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT COMPANY'S
SECOND SET OF REQUESTS FOR PRODUCTION TO IDAHO POWER COMPANY - 3
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 RESPONSE TO J.R. SIMPLOT'S SECOND SET
OF 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, ldaho 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@riehardsonadams. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email tom.a arkoosh.com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email kahle@kahlebeckerlaw-com
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT COMPANY'S
SECOND SET OF REQUESTS FOR PRODUCTION TO IDAHO POWER COMPANY - 4
lrion Sanger
SANGER LAW, P.C.
1117 SW 53'd Avenue
Portland, Oregon 97215
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
0
, Executive AssistantKi
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT COMPANY'S
SECOND SET OF REQUESTS FOR PRODUCTION TO IDAHO POWER COMPANY - 5