20180613JR Simplot 24-25 to IPC.pdf

Peter J. Richardson, ISB No. 3195
Gregory M. Adams, ISB No. 7454
RICHARDSON ADAMS, P.L.L.C.
515 N. 27th Street
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
Email : peter@richardsonadams. com
Emai I : [e-mail]
Attomeys for Petitioner J.R. Simplot Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
20lB JUt{ I3 pt 3: 30
r i r Li !riii$i,i,l I8s r oar
TN THE MATTER OF PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC.,
J.R. SIMPLOT COMPANY, AND
RENEWABLE ENERGY COALITION FOR
MODIFICATION OF THE 9OlI IO
PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYTNG FACILITIES
Case No. IPC-E-18-07
J.R. SIMPLOT COMPANY'S THIRD
SET OF REQUESTS FOR
PRODUCTION TO IDAHO POWER
COMPANY
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Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "IPUC" or "Commission"), the J.R. Simplot Company ("Simplot") by and through its
attorneys of record, Gregory M. Adams and Peter J. Richardson, hereby requests that Idaho
Power Company ("ldaho Power" or the "Company") provide responses to the following
discovery requests. Please use the definitions and instructions supplied with the J.R. Simplot
Company's First Set of Interrogatories, Requests for Admission, and Requests for Production.
THIRD REQUESTS FOR PRODUCTION
Production Request 23: Please provide all documents filed with the Federal Energy
Regulatory Commission requesting approval of Idaho Power's currently-used method of
calculating operation and maintenance charges to interconnection customers under FERC-
jurisdictional small generator interconnection agreements and large generator interconnection
agrcements.
J.R. SIMPLOT COMPANY'S THIRD SET OF REQUESTS FOR PRODUCTION TO TDAHO
POWER COMPANY
IPUC-E-18-07
PAGE I
Production Request 24: Please provide all orders issued by the Federal Energy
Regulatory Commission approving of Idaho Power's currently-used method of calculating
operation and maintenance charges to interconnection customers under FERC-jurisdictional
small generator interconnection agreements and large generator interconnection agreements.
Production Request 25: Please provide all documents made available in Idaho
Power Open Access Transmission Tariff and its Open Access Same-time Information System
website, for prospective interconnection customers, describing Idaho Power's currently-used
method of calculating operation and maintenance charges to interconnection customers under
FERC-jurisdictional small generator interconnection agreements and large generator
interconnection agreements.
Dated: June 13,2018.
RIC ADAMS, P.L.L.C
M. Adams, ISB No. 7454
Attorneys for Petitioner J.R. Simplot
Company
J.R. SIMPLOT COMPANY'S THIRD SET OF REQUESTS FOR PRODUCTION TO IDAHO
POWER COMPANY
IPUC-E-I8.07
PAGE 2
/I\
CERTFICATE OF SERVICE
I HEREBY CERTIFY that on the l3thday of June 2018, a true and correct copy of the within and
foregoing THIRD SET OF REQUESTS FOR PRODUCTION of the J.R. Simplot Company to
Idaho Power Company in Case No. IPC-E-I8-07 were delivered via electronic mail to the
following:
Diane Hanian
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise, Idaho 83702
[e-mail]. gov
C. Tom Arkoosh
Arkoosh Law Offices
P.O. Box 2900
Boise,Idaho 83701
tom. arkoosh@arkoosh. com
Irion Sanger
Sanger Law, P.C.
I I l7 SE 53d Avenue
Portland, Oregon 97215
[e-mail]
Walters
Administrative Assistant
Donovan Walker
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
dwalker@idahopower. com
J. Kahle Becker
Attorney at Law
223 North 6th Street, #325
Boise, Idaho 83702
kahle@kahlebeckerlaw. com
Tamarack Energy Partnership
c/o Michael C. Creamer and
Preston N. Carter
601 W. Bannock
Boise, Idaho 83702
mcc@ givenspursley. com
pnc@ givenspursley. com