20180607Staff 1-4 to JR Simplot.pdf

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
EDITH PACILLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5430
IN THE MATTER OF THE PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC., J.R.
SIMPLOT COMPANY, AND RENEWABLE
ENERGY COALITION FOR MODIFICATION
OF THE 90/110 PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITES.
RECTIVED
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CASE NO. IPC.E.18-07
FIRST PRODUCTION
RBQUEST OF THE
COMMISSION STAFF TO
J.R. SIMPLOT COMPANY
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edith Pacillo, Deputy Attorney General, request that J.R. Simplot Company (Simplot) provide
the following documents and information as soon as possible, by FRIDAY, JUNE 28,2018.
This Production Request is continuing, and Simplot is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question and supporting workpapers that provide detail or
are the source of information used in calculations. Simplot is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST
TO J.R. SIMPLOT COMPANY JLTNE 7,20181
REQUEST NO. 1: The footnote on Page 5 of the Petition lists five circumstances under
which the 90/110 rule was adopted. Does the Petitioner agree with any or all of these
statements? Please explain.
REQUEST NO. 2: Please provide any data and evidence that supports the three
circumstances listed on page 6, paragraph number 13, of the Petition.
REQUEST NO. 3: Please categorize the root causes that prevent QF projects from
meeting the 90/110 requirement and provide project examples that fall under each category.
REQUEST NO. 4: Please list the projects that are or should be able to consistently
comply with the 90/110 contract provisions. For each project, please provide a detailed
explanation why these projects are more predictable and more able to comply with the 901110
requirements.
Dated at Boise,Idaho, this 7h auy of June 2018
alfu4.
Pacillo
Deputy Attorney General
Technical Staff: Yao Yin (1-4)
i:umisc:prodreq/ipcel 8.7epyy prod reql J.R. Srmplot
FIRST PRODUCTION REQUEST
TO J.R. SIMPLOT COMPANY 2 JLINE 7,2018
CERTIFICATE OF SBRVICE
I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OF JTINE 2018, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO J.R. SIMPLOT COMPANY IN CASE NO. IPC-E-I8-07, BY MAILING A
COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : dwalker@idahopower. com
dockets@idahopower. com
DAVID H ARKOOSH
LAW OFFICE OF DAVID
ARKOOSH
PO BOX 2817
BOISE ID 83701
E-mail: [e-mail]
J KAHLE BECKER
ATTORNEY AT LAW
223 N 6TH STREET #325
BOISE ID 83702
E-mail : [e-mail]
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-mail : [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail: peter(D,richardsonadams.com
gre g@richard sonadam s. com
IRION SANGER
SANGER LAW PC
I I I7 SE 53RD AVE
PORTLAND OR 97215
E-mail: [e-mail]
Y
CERTIFICATE OF SERVICE