20180523Idahydro and Shorock 1-2 to IPC.pdf

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MAY 2 3 20tg
Boise,ldahoC. Tom Arkoosh. ISB No.2253
ARKOOSH LAW OFFICES
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
David H. Arkoosh, ISB No. 8742
Law Office of David Arkoosh
PO Box 2817
Boise,lD 83701
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attomeys for Petitioners, Idahydro and Shorock Hydro, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
TN THE MATTER OF PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC.,
J.R. SIMPLOT COMPANY, AND
RENEWABLE ENERGY COALITION FOR
MODIFICAT'ION OF'THE 9O/I IO
PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITIES
IDAHYDRO AND SHOROCK
HYDRO, INC.'S FIRST SET OF
INTERROGATORIES, REQUESTS
FOR ADMISSION AND REQUESTS
FOR PRODT]CTION OF
DOCUMENTS TO IDAHO POWER
COMPANY
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Pursuanl to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "lPUC" or "Commission"), Idahydro and Shorock Hydro. lnc.. ("Petitioners") by and through
their counsel of record. C. Tom Arkoosh of Arkoosh Law Oflices and David lI. Arkoosh of Law
Oflice of David Arkoosh, hereby request that ldaho Power Company ("ldaho Power" or the
"Company") provide responses to the following interrogatories. requests for admission and
production requests.
IDAHYDRO AND SHOROCK HYDRO, INC.'S FIRST SET OI. INI'ERROGA]'ORIES,
REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION OF DOCUMENTS
TO IDAHO POWER COMPANY - Page I
Case No. IPC-E-18-07
DEFINITIONS
Unless otherwise specified in an individual reques! the followingwords have the following
meanings in these interrogatories, requests for admission and production requests:
l. "Documents' refers to all writings and records of every type in your possession,
control, or custody, whether or not claimed to be privileged or othenrrise excludable
from discovery, including but not limited to: testimony and exhibits, memorandq
papers, correspondence, letters, reports (including drafu, preliminary, intermediate,
and final reports), suryeys, analyses, studies (including economic and market studies),
summaries, comparisons, tabulations, bills, invoiccs, statements of services rendered,
charts, books, pamphlets, photographs, maps, bulletins, corporate or other minutes,
notes, diaries, log sheets, ledgers, tanscripts, microfilm, micnrfiche, computer data
(including E-mail), computer files, computer tapes, computer inputs, computer ouQuts
and printouts, vouchers, accounting statements, budgets, work papers, engineering
diagrams (including oone-linen' diagrams), mechanical and electrical recordings,
telephone and telegraphic communications, speeches, and all other records, written,
electrical, mechanical, or otherwise, and drafts of any of the above.
"Documents" includes copies of documents, where the originals are not in your
possession, custody or control.
"Documents" includes every copy of a document which contains handwritten or other
notations or which otherwise does not duplicate the original or any other copy.
"Documents" also includes any attachments or appendices to any document.
2. "Identification" and "identiff" mean:
When used with respect to a document, stating the naturc of the document (e.g., letter,
IDAHYDRO AND SHOROCK HYDRO,INC.'S FIRST SET OF INTERROGATORIES,
REQT.JESTS FOR ADMISSION AND REQUESTS FOR PRODUCTTON OF DOCT.JMENTS
TO IDAHO POWER COMPAI.IY -Page2
memorandum, minutes); the date, if any, appearing thereon; the date, if known, on
which the document was prepared; the title of the document; the general subject matter
of the document; the number of pages comprising the document; the identity of each
person who wrote, dictated, or otherwise participated in the preparation of the
document; the identity of each person who signed or initiated the document; the identity
of each person to whom the document was addressed; the identity of each person who
received the document or reviewed it; the location of the document; and the identity of
each person having possession, custody, or control of the document.
When used with respect to a person, stating his or her full name; his or her most recently
known home and business addresses and telephone numbers; his or her present title and
position; and his or her present and prior connections or associations with any
participant or party to this proceeding.
3. 'Idaho Power Companyn and nthe Company" and "ldaho Power'refer to Idaho Power
Company, any affiliated company, orany officer, director oremployee of Idaho Power
Company or any affiliated company.
4, "You" refers to Idaho Power Company.
5. nPerson" refers to, without limiting the generality of its meaning, every natural person,
corporation, partrership, association (whether formally organized or ad hoc), joint
venture, unit operation, cooperative, municipality, commission, governmental body or
agency, or any other group or organization.
6. The singular form of a word shall be interpreted as plural, and the plural form ofa word
shall be interpreted as singular, whenever appropriate in order to bring within the scope
of this discovery request any information or documents which might otherwise be
IDAIIYDRO AND SHOROCK HYDRO,INC.'S FIRST SET OF INTERROGATORIES,
REQLTESTS FOR ADMTSSTON AND REQT.TESTS FOR PRODUCTION OF DOCT.TMENTS
TO IDAI{O POWER COMPANY - Page 3
considered to be beyond their scope.
7. "{C&M" charges arc the operation and maintenance of interconnection charges
identified in Idatro Power Company's Schedule 72.
8. *PURPA" is the federal Public Utilities and Regulatory Policy Act of 1978.
9. *Projects" means Petitioner's projec8 specifically identified in footnote l.l
REQUF-STS FOR N)IVtrSSION
REOIJEST FOR ADMISSION NO. 1: Please admit the purpose of charges by you rurder
Schedule 72 for O&M is to reimburse you for the cost to you of the actual cost to you of the
operation and maintenance of interconnection facilities of PURPA projects.
INTERROGATORIES
INTERROGATORY NO. l: If you denied RJA l, please define exactly what is the
purpose of the O&M charges.
INTERROGATORY NO.2: Please identifu how you calculated the O&M charges.
INTERROGATORY NO.3: Please identifr how the O&M charges correspond to actual
cost to you of operation and maintenance of PURPA interconnection facilities.
IN?ERROGATORY NO. 4: Please define "original interconnection investment" and
what components are incorporated in original interconnection investment as the plrase is used in
Schedule 72.
INTERROGATORY NO. 5: Because "original interconnection investment" is the
multiplicand in the calculation of O&M, please identiff how each component of "original
interconnection investrnent" identified in lnterrogatory 4 relates to the actual cost to you of
operation and maintenance of interconnection facilities.
I List of Projccts: Plcasc scc Erhibit.{.
IDAHYDRO A}.ID SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES,
REQLTESTS FOR ADMTSSION AI.rD REQT.JESTS FOR PRODUCTTON OF DOCUMENTS
TO IDAI{O POWER COMPA}.IY - Page 4
INTERROGATORY NO. 6: Please identiS how you track or account for both payments
taken in for O&M and actual cost to you for O&M.
INTERROGATORY NO. 7: For each Project since its inccption, please identifr for
each project all payments made to you by the Projects for O&M by year and all costs exp€nded by
you for each Project for O&M by corresponding year.
INTERROGATORY NO. 8: For all PURPA projects since 1978, inclusive of the
Projects! please identifu the sum of all payments made for O&M by all PURPA projects inclusive
of the Projects by year and all costs expended by you for all PURPA projects inclusive of the
Projects for O&M by conesponding year.
INTERROGATORY NO. 9: Does any prohibition or impediment exist preventing or
inhibiting you from charging actual O&M costs as they occur? If so, plcase identifu those
prohibitions or impediments.
INTERROGATORY NO. l0: Please identify those persons in your company with actual
knowledge which will either support or contadict your answers to this discovery.
INTERROGATORY NO. 11: Please identiS those persons in your company whom you
will identify at this time to depose in an [.R.C.P. Rule 30(bX6) deposition to discuss each issue
prcsented by this discovery.
REQLTESTS FOR PRODUCTTON OF DOCUMENTS
REOUEST FOR PRODUCTION NO. l: Please identiff and produce all documents
which tack or account for both payments taken in by you for O&M of the Prcjects and the actnal
cost to you for O&M of the Projects.
IDAI{YDRO AI{D SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORJES,
REQT.TESTS FOR ADMTSSTON AND REQUESTS FOR PRODUCTION OF DOCUMENTS
TO IDAHO POWER COMPAI.IY - Page 5
REOUEST FOR PRODUCTION NO. 2: Please identity and produce those documents
in your possession or control or to which you have access u,hich will support or contradict your
answers to this discovery. n
^^(duDATED this ')) day of May, 2018.
ARKOOSH I-AW OFFICES
C. Tom
Attorney for ldahydro & Shorock Hydro, Inc.
IDAHYDRO AND SHOROCK HYDRO, INC.'S FIRST SET OF' INTERROGATORIES,
REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION OF DOCUMENTS
TO IDAHO POWER COMPANY - Page 6
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the23rd day of May,20l8,I served a true and correct copy
of the foregoing document(s) upon the following person(s), in the manner indicated:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, lD 83702
Donovan Walker
Idaho Power Company
PO Box 70
Boise,ID 83707
Irion Sanger
Sanger Law, P.C.
I I l7 SE 53'd Avenue
Portland, OR972l5
J. Kahle Becker
Afforney at Law
223 North 6th Street, #325
Boise, lD 83702
Peter J. Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N.27th Street
Boise, lD 83702
Edith Pacillo
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702
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E-mail diane. holt(rupuc. idaho. gov
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E-mail dwal ker(a)i dahopowcr, qo4
x
x
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x
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E-mail irion(ii)sanser-law.cont
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kah I eGzkah lebeckerlaw. c orn
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peter(D richardsonadams. com
gre g@richardsonadams. com
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edithpaci I lo(n)puc. idaho. eov
IDAHYDRO AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES,
REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION OF DOCUMENTS
TO IDAHO POWER COMPANY -Page 7
David [I. Arkoosh
Law Office of David Arkoosh
PO Box 2817
Boise, ID 83701
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Overnight Courier
Hand Delivered
Via Facsimile
X [e-mail]
C. Tom
IDAHYDRO AND SHOROCK HYDRO, INC.'S FIRST SET OF INI'ERROGATORIES,
REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION OF DOCUMENTS
TO IDAHO POWER COMPANY - Page 8
EXHIBIT A
(List of Projects)
Bypass
Hazelton A
Hazelton B
Wilson Lake
Hd. of u
Low Line Midway
Low Line #2
South Forks
Birch Power
Dry Creek
Pancheri
I.f,rnhi
Marsh Valley
St. Anthony
Rock Creek Joint Venture
Shorock Hydro
Lateral No. l0
Briggs Creek
BC Hydro - Kaster Riverview
HK Hydro - Mud Creek
Crystal Springs Hy&o
Mink Creek
Little Wood #l
Little Wood #2
Marco
Koyle Hydro
GeoBon II
Little Mac
Dietrick Drop
Barber Dam
Elk Creek
Rock Creek #2