20180607Staff 1-6 to IPC.pdf

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 RE,NEWABLE
ENERGY COALITION FOR MODIFICATION
OF THE 9O/T1O PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITES.
Estor'l
CASE NO. IPC.E.18,O7
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
REC EIVED
?018..!Ull -7 PH 2: 38
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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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 Idaho Power Company (Idaho Power or
Company) provide the following documents and information as soon as possible, by FRIDAY,
JUNE 28,2018.
This Production Request is continuing, and Idaho Power 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. Idaho Power 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.
FIRST PRODUCTION REQUE,ST
TO IDAHO POWER 1 JLINE 7,2078
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-59T8
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Does Idaho Power believe 90/l l0 contributes to more accurate
avoided costs? If so, please explain why. If not, why not?
REQUEST NO. 2: Please explain how the 90/l l0 contract provision relates to the cost
of integrating variable resources.
REQUEST NO. 3: Please explain how the 90lll0 contract provision relates to the cost
of holding system reserves.
REQUEST NO. 4: Is it practical and feasible to conduct an integration study on hydro
QFs on the Idaho Power system?
REQUEST NO. 5: The current monthly operation and maintenance (O&M) service
charges for QF interconnection facilities are based upon a percentage of actual interconnection
investment:0.7o/o for distribution facilities (below 138kV) and0.4Yo for transmission facilities
(l38kV and 161Kv) See Case No. IPC-E-90-20. Does Idaho Power believe this methodology is
still reasonable and appropriate today? Please explain.
REQUEST NO. 6: Please update the percentages mentioned above (0.7% and 0.4Yo)
used to calculate the current O&M levelized raGs by using the most recent input data (i.e.12
months ending December 31,2071), and provide worksheets (with formula intact) to show the
calculation steps.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 7,2018
Dated at Boise,Idaho, this 4ft day of June 2018
A-
Pacillo
Deputy Attorney General
Technical Staff: Yao Yin (1-6)
i:umisc:prodreq/ipce I 8.7epyy prod req I ipc
FIRST PRODUCTION REQUEST
TO IDAHO POWER J JLrNE 7,2018
CERTIFICATB OF SBRVTCE
I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OF JUNE 2018, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-18-07, 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(@idehaparryqr.ca!0
dockets@idahopower. com
DAVID H ARKOOSH
LAW OFFICE OF DAVID
ARKOOSH
PO BOX 2817
BOISE ID 8370I
E-mail : david(@arkooshlaw.cam
J KAHLE BECKER
ATTORNEY AT LAW
223N 6TH STREET #325
BOISE ID 83702
E-mail : kahle@,kahlebeckerlaw.com
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
5I5 N 27TH STREET
BOISE TD 83702
E-mail: [e-mail]
gre g@richardsonadams. com
IRION SANGER
SANGER LAW PC
1I I7 SE 53RD AVE
PORTLAND OR 97215
E-mail: [e-mail]
ARY
CERTIFICATE OF SERVICE