20180613IPC to Idahydro, Shorock, REC 1-2.pdf

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DONOVAN E. WALKER
Lead Counsel
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June 13,2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
47 2 \N esl Wash ington 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 Answers and
Responses to ldahydro and Shorock Hydro, lnc.'s First Set of lnterrogatories,
Requests for Admission, and Requests for Production of Documents
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 Idahydro and Shorock Hydro, Inc.'s First
Set of lnterrogatories, Requests for Admission, and Requests for Production of
Documents.
Also, enclosed are four (4) copies of non-confidential disks containing information
responsive to these requests.
Very urs,
novan E lker
DEW:csb
Enclosures
122I W ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
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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 FACILITIES
R C T IVED
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CASE NO. IPC-E-18-07
IDAHO POWER COMPANY'S
ANSWERS AND RESPONSES
TO IDAHYDRO AND SHOROCK
HYDRO, INC.'S FIRST SET OF
I NTERROGATORI ES, REQU ESTS
FOR ADMISSION, AND REQUESTS
FOR PRODUCTION OF
DOCUMENTS
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COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?ny"), and in
answer and response to ldahydro and Shorock Hydro, Inc.'s First Set of lnterrogatories,
Requests for Admission, and Requests for Production of Documents to ldaho Power
Company dated May 23,2018, herewith submits the following information:
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 1
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REQUEST FOR ADMISSION
REQIIEST FOR ADMISSION NO. 1: Please admit the purpose of charges by
you under Schedule 72lor 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.
RESPONSE TO REQUEST FOR ADMISSION NO. 1: Deny. The purpose of
the operations and maintenance ("O&M") charge under Schedule 72 is to hold retail
customers of ldaho Power neutral by charging Public Utility Regulatory Policies Act of
1978 (.PURPA") projects a reasonable rate for what the Company may expect to spend
on O&M over the life of the interconnection facilities required by the Qualifying Facility
('QF') projects.
The response to this Request for Admission is sponsored by Mark Annis, Senior
Regulatory Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 2
INTERROGATORIES
INTERROGATORY NO. 1: lf you denied RFA 1, please define exactly what is
the purpose of the O&M charges.
ANSWER TO INTERROGATORY NO. 1: Please see ldaho Power's response
to ldahydro and Shorock Hydro, lnc.'s ("ldahydro and Shorock") Request for Admission
No.1.
The answer to this lnterrogatory is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS.3
INTERROGATORY NO. 2: Please identify how you calculated the O&M
charges.
ANSWER TO INTERROGATORY NO. 2: As described in Section 3 of the
Company's Schedule 72 tarifi, O&M charges are "equa! to a percentage of the
Construction Cost and Transfer Cost paid by the Seller." The percentage changes
annually on the anniversary of the First Energy Date in accordance with Tables 1 and 2
in Schedule 72, p.72-18. Please see the Company's response to Renewable Energy
Coalition's ("REC") Request for Production No. 1.2 lor additional information about the
calculation of the percentages in Tables 1 and 2.
The answer to this lnterrogatory is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 4
INTERROGATORY NO. 3: Please ide ntify how the O&M charges correspond to
actual cost to you of operation and maintenance of PURPA interconnection facilities.
ANSWER TO INTERROGATORY NO. 3: As stated in ldaho Power's response
to J.R. Simplot Company's Request for Production 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 answer to this lnterrogatory is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 5
INTERROGATORY NO. 4: Please define "original interconnection investment"
and what components are incorporated in original interconnection investment as the
phrase is used in ScheduleT2.
ANSWER TO INTERROGATORY NO. 4:For purposes of the O&M charge,
original interconnection investment represents the sum of the Construction Cost and
Transfer Cost paid by the Seller. Please also see the Company's response to REC's
Request for Production No. 1.6. Per Schedule 72, p. 72-17, "For all projects not
interconnecting as a Schedule 6, Schedule 8, or Schedule 84 customer, the Seller will
pay the Company a monthly operation and maintenance charge equal to a percentage
of the Construction Cost and Transfer Cost paid by the Seller."
The answer to this lnterrogatory is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS .6
INTERROGATORY NO. 5: Because "original interconnection investment" is the
multiplicand in the calculation of O&M, please identify how each component of "original
interconnection investment" identified in lnterrogatory 4 relates to the actual cost to you
of operation and maintenance of interconnection facilities.
ANSWER TO INTERROGATORY NO. 5: Please see ldaho Power's response
to ldahydro and Shorock's lnterrogatory No. 3.
The answer to this lnterrogatory is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 7
INTERROGATORY NO. 6: Please identify how you track or account for both
payments taken in for O&M and actual cost to you for O&M.
ANSWER TO INTERROGATORY NO. 6: The Company tracks O&M payments
received through an internally developed software system that manages all information
related to generators from whom the Company purchases energy. Once construction
for an interconnection is complete, the costs are reconciled and reviewed by a project
manager. These reconciled costs then become the basis for the O&M charge
calculation, which is input into the sofhruare and automatically calculated/tracked each
month.
Please also see ldaho Power's response to ldahydro and Shorock's lnterrogatory
No. 3.
The answer to this lnterrogatory is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 8
INTERROGATORY NO. 7: For each Project since its inception, please identify
for each project all payments made to you by the Projects for O&M by year and all costs
expended by you for each Project for O&M by corresponding year.
ANSWER TO INTERROGATORY NO. 7: Please see the Company's response
to ldahydro and Shorock's lnterrogatory No. 8.
The answer to this lnterrogatory is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 9
INTERROGATORY NO. 8: For all PURPA projects since 1978, inclusive of the
Projects, please identifo 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 corresponding year.
ANSWER TO INTERROGATORY NO. 8: Please see the Exce! spreadsheet
provided on the enclosed CD for the amount collected by ldaho Power for O&M
payments made by PURPA projects since 1978. Please note that these collections also
include O&M charges collected from coptracts that were signed prior to the
implementation of Schedule 72. Also, please note that there are several Projects listed
in Exhibit A attached to ldahydro and Shorock's First Set of lnterrogatories, Requests
for Admission, and Requests for Production of Documents to ldaho Power Company
that are not directly interconnected to ldaho Power and therefore are not included in the
Excel spreadsheet.
For costs expended for all PURPA projects for O&M, please see ldaho Power's
response to ldahydro and Shorock's lnterrogatory No. 3.
The answer to this lnterrogatory is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 1O
INTERROGATORY NO. 9: Does any prohibition or impediment exist preventing
or inhibiting you from charging actual O&M costs as they occur? lf so, please identify
those prohibitions or imped iments.
ANSWER TO INTERROGATORY NO. 9: Yes. Charging actual O&M costs for
QF projects would mean that an entirely separate system of work order preparation and
billing would have to be established just for QF projects. ldaho Power believes that
such a requirement is both unreasonable and unnecessary. The present system of
charging a percentage of construction costs reasonably approximates ldaho Power's
O&M costs and provides the QF with a high level of predictability as to what its O&M
costs will be over the life of the project. Further, ldaho Power is required to follow ldaho
Public Utilities Commission ("Commission") orders and approved tariff schedules. ldaho
Power charges the O&M fees authorized and required by the Commission through
Schedule 72. Please also see ldaho Power's response to ldahydro and Shorock's
lnterrogatory No. 3.
The answer to this lnterrogatory is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 11
INTERROGATORY NO. 10: Please identify those persons in your company with
actual knowledge which will either support or contradict your answers to this discovery.
ANSWER TO INTERROGATORY NO. 10: Each of ldaho Power's "answers to
this discovery" identify the person sponsoring that response. See RP 228.02.
The answer to this Interrogatory is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 12
INTERROGATORY NO. 11: Please identify those persons in your company
whom you will identify at this time to depose in an l.R.C.P. Rule 30(b)(6) deposition to
discuss each issue presented by this discovery.
ANSWER TO INTERROGATORY NO. 11: Please see ldaho Power's response
to ldahydro and Shorock's lnterrogatory No. 10.
The answer to this lnterrogatory is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 13
REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST FOR PRODUCTION NO. 1: Please identify and produce all
documents which track or account for both payments taken in by you for O&M of the
Projects and the actuat cost to you for O&M of the Projects.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: P|ease see |daho
Power's responses to ldahydro and Shorock's lnterrogatories Nos. 3 and 6.
The response to this Request for Production is sponsored by Mark Annis, Senior
Regulatory Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 14
REQUEST FOR PRODUCTION NO. 2: Please identify and produce those
documents in your possession or control or to which you have access which will support
or contradict your answers to this discovery.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Any requested
documents were or will be produced in response to their related discovery requests.
The response to this Request for Production is sponsored by Donovan E.
Walker, Lead Counsel, ldaho Power Company.
DATED at Boise, ldaho, this 13th day of June 2018.
E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 15
CERT!FICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of June 2018 I served a true and
correct copy of IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO
IDAHYDRO AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES,
REQUESTS FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF
DOCUMENTS 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
47 2 W est Wash ington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Gompany
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
ldahydro and Shorock Hydro, lnc.
C. Tom Arkoosh
ARKOOSH IAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
David H. Arkoosh
Law Office of David Arkoosh
P.O. Box 2817
Boise, ldaho 83701
Renewable Energy Coalition
J. Kahle Becker
Attorney at Law
223 North 6th Street, Suite 325
Boise, ldaho 83702
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q req @ richardso nad ams. com
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IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS. 16
lrion Sanger
SANGER LAW, P.C.
1117 SW 53rd Avenue
Portland, Oregon 97215
Tamarack Energy Partnership
Michael C. Creamer
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
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[e-mail]
-:-
Christa Bearry, Legal
IDAHO POWER COMPANY'S ANSWERS AND RESPONSES TO IDAHYDRO
AND SHOROCK HYDRO, INC.'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR ADMISSION, AND REQUESTS FOR PRODUCTION OF DOCUMENTS - 17