20180621JR Simplot 1-16 to Avista.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
Email : [e-mail]
TN THE MATTER OF PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC.,
J.R. SIMPLOT COMPANY, AND
RENEWABLE ENERGY COALITTON FOR
MODIFICATION OF THE 9OlI IO
PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITIES
Case No. IPC-E-18-07
J.R. SIMPLOT COMPANY'S FIRST
INTERROGATORIES, REQUESTS
FOR ADMISSION AND REQUESTS
FOR PRODUCTION TO AVISTA
j1[CEtVED
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Attorneys for Petitioner J.R. Simplot Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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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 Avista
Corporation ("Avista" or the "Company'') provide responses to the following interrogatories,
requests for admission and production requests.
DEFINITIONS
Unless otherwise specified in an individual request, the following words have the
following meanings in these interrogatories, requests for admission and production requests:
1. "Documents" refers to all writings and records of every type in your possession, control,
or custody, whether or not claimed to be privileged or otherwise excludable from
discovery, including but not limited to: testimony and exhibits, memoranda, papers,
correspondence, letters, reports (including drafts, preliminary, intermediate, and final
J.R. SIMPLOT COMPANY'S FIRST INTERROGATORIES, REQUESTS FOR ADMISSION
AND REQUESTS FOR PRODUCTION TO AVISTA CORPORATION
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reports), surveys, analyses, studies (including economic and market studies), summaries,
comparisons, tabulations, bills, invoices, statements of services rendered, charts, books,
pamphlets, photographs, maps, bulletins, corporate or other minutes, notes, diaries, log
sheets, ledgers, transcripts, microfilm, microfiche, computer data (including E-mail),
computer files, computer tapes, computer inputs, computer outputs and printouts,
vouchers, accounting statements, budgets, work papers, engineering diagrams (including
"one-line" 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 "ldentification" and "identify" mean:
When used with respect to a document, stating the nature of the document (e.g., letter,
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.
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AND REQUESTS FOR PRODUCTION TO AVTSTA CORPORATION
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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.
"Avista Corporation" and "the Company" and "Avista" refer to Avista Corporation, any
affiliated company, or any officer, director or employee of Avista Corporation or any
affrliated company.
The term "monthly adjusted estimated net energy amounts" means the estimate of
monthly estimated net energy deliveries as adjusted by the qualifying facility under the
terms of the qualifying facility's energy sales agreement with Avista Corporation for
purposes of implementing the Commission-approved 90/100 Performance Band.
"Person" refers to, without limiting the generality of its meaning, every natural person,
corporation, partnership, association (whether formally organized or ad hoc), joint
venture, unit operation, cooperative, municipality, commission, governmental body or
agency, or any other group or organization.
"Studies" or "study" includes, without limitation, reports, reviews, analyses and audits.
The terms ooand" and "or" shall be construed either disjunctively or conjunctively
whenever appropriate in order to bring within the scope of this discovery any information
or documents which might otherwise be considered to be beyond their scope.
The singular form of a word shall be interpreted as plural, and the plural form of a 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
considered to be beyond their scope.
"Work papers" means documents that show the source, calculations, and details
supporting the material referenced.
INSTRUCTIONS
These interrogatories, requests for admission and production requests call for all
information, including information contained in documents, which relate to the subject
J.R. SIMPLOT COMPANY'S FIRST TNTERROGATORIES, REQUESTS FOR ADMISSION
AND REQUESTS FOR PRODUCTION TO AVISTA CORPORATION
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matter of the interrogatories, requests for admission and production requests and which is
known or available to you.
Where an interrogatory, request for admission or production request has a number of
separate subdivisions or related parts or portions, a complete response is required to each
such subdivision, part or portion. Any objection to an interrogatory, request for
admission or production request should clearly indicate the subdivision, part, or portion
to which it is directed.
Each response should be furnished on a separate page. Electronic versions of the
document, including studies and analyses, must be furnished if available.
If you cannot answer any of these interrogatories, requests for admission and production
requests in full, after exercising due diligence to secure the information necessary to do
so, state the answer to the extent possible, state why you cannot answer in full, and state
what information or knowledge you have concerning the unanswered portions.
If, in answering any of these interrogatories, requests for admission and production
requests, you feel that any request or definition or instruction applicable thereto is
ambiguous, set forth the language you feel is ambiguous and the interpretation you are
using in responding to the interrogatories, requests for admission and production
requests.
If a document requested is unavailable, identify the document, describe in detail the
reasons the document is unavailable, state where the document can be obtained, and
specify the number of pages it contains.
If you assert that any document has been destroyed, state when and why it was destroyed
and identify the person who directed the destruction. If the document was destroyed
pursuant to your document destruction program, identify and produce a copy of the
guideline, policy, or company manual describing such document destruction program.
If you refuse to respond to any interrogatories, requests for admission and production
requests by reason of a claim of privilege, confidentiality, or for any other reason, state in
writing the type of privilege claimed and the facts and circumstances you rely upon to
support the claim of privilege or the reason for refusing to respond. With respect to
J.R. SIMPLOT COMPANY'S FIRST INTERROGATORIES, REQUESTS FOR ADMISSION
AND REQUESTS FOR PRODUCTION TO AVISTA CORPORATION
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requests for documents to which you refuse to respond, identify each such document, and
specify the number of pages it contains. Please provide: (a) a brief description of the
document; (b) date of document; (c) name of each author or preparer; (d) name of each
person who received the document; and (e) the reason for withholding it and a statement
of facts constituting the justification and basis for withholding it.
Identify the person from whom the information and documents supplied in response to
each interrogatory, request for admission and production request were obtained, the
person who prepared each response, the person who reviewed each response, and the
person who will bear ultimate responsibility for the truth of each response.
If no document is responsive to an interrogatory, request for admission and production
request that calls for a document, then so state.
These requests for documents and responses are continuing in character so as to require
you to file supplemental answers as soon as possible if you obtain further or different
information. Any supplemental answer should refer to the date and use the number of the
original request or subpart thereof.
Whenever these interrogatories, requests for admission and production requests
specifically request an answer rather than the identification of documents, the answer is
required and the production of documents in lieu thereof will not substitute for an answer.
To the extent that the Company believes it is burdensome to produce specific information
requested, please contact counsel for J.R. Simplot Company to discuss the problem prior
to filing an answer objecting on that basis to determine if the request can be modified to
pose less difficulty in responding.
To the extent the Company objects to any of the requests please contact counsel for J.R.
Simplot Company to determine if the request can be modified to produce a less
obj ectionable request.
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J.R. SIMPLOT COMPANY'S FIRST INTERROGATORIES, REQUESTS FOR ADMISSION
AND REQUESTS FOR PRODUCTION TO AVTSTA CORPORATION
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FIRST INTERROGATORIES
Interrogatory l: Identify the employees at Avista who are responsible for
forecasting the output of hydro, wind, solar and other QFs for month-ahead and day-ahead power
supply planning purposes. List the employees in descending order of decision-making hierarchy
and list the job title of each such employee.
Interrogatory 2: Identify the employees at Avista who are responsible for
forecasting the output of Avista's company-owned hydro, wind, solar and other generation
projects for month-ahead and day-ahead power supply planning purposes. List the employees in
descending order of decision-making hierarchy and list the job title of each such employee.
Interrogatory 3: tdentify the employees at Avista who receive the monthly adjusted
estimated net energy amounts supplied by QFs with the 90/l l0 Performance Band contract
provision. List the employees in descending order of decision-making hierarchy and list the job
title of each such employee.
Interrogatory 4: Identify the employees at Avista engaged in accounting of
operations and maintenance expenses and assessment of operation and maintenance charges to
interconnection customers that take service under FERC-jurisdictional interconnections under
the Open Access Transmission Tariff s Large Generator Interconnection Agreement and Small
Generator lnterconnection Agreement. List the employees in descending order of decision-
making hierarchy and list the job title of each such employee.
Interrogatory 5: Identify the employees at Avista engaged in accounting of
operations and maintenance expenses and assessment of operation and maintenance charges to
interconnection customers that take service under IPUC-jurisdictional PURPA interconnections.
List the employees in descending order of decision-making hierarchy and list the job title of each
such employee.
Interrogatory 6: Explain how Avista uses the monthly adjusted estimated net
energy amounts supplied by QFs under their energy sales agreements in Avista's month-ahead
and day-ahead power supply planning activities. Include examples of specific instances where
Avista has adjusted its power supply planning based upon the QF's monthly adjusted estimated
net energy amounts.
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AND REQUESTS FOR PRODUCTION TO AVISTA CORPORATION
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Interrogatory 7z Explain how Avista forecasts the energy deliveries made under
energy sales agreements that do not contain the 90/l l0 Performance Band. Include description
of all differences between the practices used to forecast energy deliveries from hydro QFs
providing monthly adjusted estimated net energy amounts under the 90/l l0 Performance Band
and hydro QFs that do not provide monthly adjusted estimated net energy amounts under the
90/l l0 Performance Band.
Interrogatory 8: For intermittent (wind and solar) QFs and non-QF generators that
operate under a mechanical availability guarantee in lieu of the 90/l l0 Performance Band,
explain how Avista forecasts generation from such QFs without receiving monthly adjusted
estimated net energy amounts supplied by the QF.
Interrogatory 9: Please describe Avista'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.
Please identify the FERC order approving of use of the current method.
Interrogatory 10: Please describe Avista's currently-used method of calculating
operation and maintenance charges to interconnection customers under the IPUC-jurisdictional
PURPA interconnections. Please identify the IPUC order authorizing use of the current method.
Interrogatory 11: Please identify all of Avista's currently effective FERC-
jurisdictional small generator interconnection agreements and large generator interconnection
agreements including such agreements for Avista-owned generation. Include in the list: (i) name
of interconnection customer; (ii) method of calculating the operation and maintenance charges to
the interconnection customer under the agreement; and (iii) reproduce the section of the
interconnection agreement that explains the method of calculating the operation and maintenance
charges to the interconnection customer under the agreement.
Interrogatory 12: Please identify all of Avista's currently effective IPUC-
jurisdictional PURPA small generator interconnection agreements and large generator
interconnection agreements. Include in the list: (i) name of interconnection customer; (ii)
method of calculating the operation and maintenance charges to the interconnection customer
under the agreement; and (iii) reproduce the section of the interconnection agreement that
J.R. SIMPLOT COMPANY'S FIRST TNTERROGATORIES, REQUESTS FOR ADMISSION
AND REQUESTS FOR PRODUCTION TO AVISTA CORPORATION
IPUC-E-I8-07
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explains the method of calculating the operation and maintenance charges to the interconnection
customer under the agreement.
Interrogatory 13: Is Avista aware of any other utility in the United States that
assesses operation and maintenance expenses to interconnection customers based on a formula
that assesses a percentage of the initial construction costs similar to the structure of the formula
in Idaho Power's Schedule 72. lf so, please identify the utility, explain the structure of its
charge, and location of information available to Avista on this topic.
FIRST REQUESTS FOR ADMISSION
Request for Admission 1: Admit or deny that Avista does not use the monthly
adjusted estimated net energy amounts supplied by QFs under their energy sales agreements for
purposes ofbalancing load and resources on its system on a day-ahead basis.
Request for Admission 2: Admit or deny that Avista does not use the monthly
adjusted estimated net energy amounts supplied by QFs under their energy sales agreements for
purposes of balancing load and resources on its system on a week-ahead basis.
Request for Admission 3: Admit or deny that Avista does not use the monthly
adjusted estimated net energy amounts supplied by QFs under their energy sales agreements for
purposes of balancing load and resources on its system on a two-week-ahead basis.
Request for Admission 4: Admit or deny that Avista does not use the monthly
adjusted estimated net energy amounts supplied by QFs under their energy sales agreements for
purposes of power supply planning on its system on a month-ahead basis.
Request for Admission 5: Admit or deny that Avista assesses interconnection
operations and maintenance expenses to interconnection customers that take service under
FERC-jurisdictional interconnections under the Open Access Transmission Tariff s Large
Generator Interconnection Agreement and Small Generator Interconnection Agreement on a
basis ofactual costs incurred.
Request for Admission 6: Admit or deny that Avista assesses interconnection
operations and maintenance expenses to interconnection customers that take service under under
the IPUC-jurisdictional PURPA Large Generator Interconnection Agreement and Small
J.R. SIMPLOT COMPANY'S FIRST INTERROGATORIES, REQUESTS FOR ADMISSTON
AND REQUESTS FOR PRODUCTION TO AVISTA CORPORATTON
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Generator Interconnection Agreement on a basis of actual costs incurred
FIRST REQUESTS FOR PRODUCTION
Production Request l: Please provide a list of all QFs that supplied power to
Avista at any time after January l, 2008 or that have energy sales agreements but have not yet
started to make deliveries. For each of these QFs, please provide the following information:
name, contract capacity, nameplate capacity (if known and different than contract capacity),
primary fuel (e.g, hydro, wind, solar, geothermal, cogeneration, etc.), point of interconnection,
commercial operation date, date of last generation (if not still in operation) and whether the
energy sales agreement contains the 90/110 Performance Band.
Production Request 2: Please provide a list of all hydro projects owned by Avista
that generated power at any time between January l, 2008 and the present. For each of these
hydro projects, please provide the following information: name, water source (e.g., Snake River),
nameplate capacity, planning capacity (if different than nameplate capacity), water flow at
nameplate/planning capacity (in cfs), at site storage (in sfd), upstream storage controlled by
Avista (in sfd) and upstream storage controlled by entities other than Avista (in sfd).
Production Request 3: For each QF listed in the response to Production Request I
whose energy sales agreement contains the 90/l l0 Performance Band, please provide a copy of
the energy sales agreement and any amendments.
Production Request 4: Has Avista allowed any QFs whose energy sales
agreements contain the 90/l l0 Performance Band to adjust their net energy amounts other than
as specifically permitted under the express terms of the energy sales agreement and any
applicable amendments? If so, please describe the terms allowed for these adjustments and
provide any communications with QFs pertaining to these adjustments.
Production Request 5: For each non-wind/non-solar QF listed in the response to
Production Request l, please provide monthly generation (in MWh) in Excel spreadsheet format
for each month from January 2008 through the most recent month available.
Production Request 6: For each non-wind/non-solar QF listed in the response to
Production Request I whose energy sales agreement contains the 90/110 Performance Band,
J.R. SIMPLOT COMPANY'S FIRST INTERROGATORTES, REQUESTS FOR ADMISSION
AND REQUESTS FOR PRODUCTTON TO AVISTA CORPORATION
IPUC-E.I8-07
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please provide the monthly adjusted estimated net energy amounts (in MWh) in Excel
spreadsheet format used to determine compliance with the 90/l l0 Performance Band for each
applicable month from January 2008 through the most recent month available.
Production Request 7: For each non-wind/non-solar QF listed in the response to
Production Request I whose energy sales agreement contains the 90/110 Performance Band,
please indicate whether the monthly adjusted estimated net energy amounts were below
(<90o ), within (90-l l0%) or above (l l0%) the 90/l l0 Performance Band for each month from
January 2008 through the most recent month available.
Production Request 8: For each wind or solar QF listed in the response to
Production Request I whose energy sales agrcement contains the 90/l l0 Performance Band,
please provide monthly generation (in MWh) in Excel spreadsheet format for each month from
January 2008 through the most recent month available.
Production Request 9: For each wind or solar QF listed in the response to
Production Request I whose energy sales agreement contains the 90/l l0 Performance Band,
please provide the monthly adjusted estimated net energy amounts (in MWh) in Excel
spreadsheet format used to determine compliance with the 90/l l0 Performance Band for each
applicable month from January 2008 through the most recent month available.
Production Request 10: For each wind or solar QF listed in the response to
Production Request I whose energy sales agreement contains the 90/l l0 Performance Band,
please indicate whether the monthly generation was below (<90o ), within (90-110%) or above
(l l0%) the 90/l l0 Performance Band for each month from January 2008 through the most
recent month available.
Production Request 11: For each hydro project owned by Avista, please provide
monthly generation (in MWh) for each month from January 2008 through the most recent month
available.
Production Request 12: Provide total generation (MWh) of all non-intermittent QFs
selling to Avista for each hour for the past 3 years, in excel spreadsheet format. For purposes of
this request, "intermittent" means wind or solar powered QF.
Production Request 13: Provide total generation (MWh) of all hydropower QFs
J.R. SIMPLOT COMPANY'S FIRST INTERROGATORIES, REQUESTS FOR ADMISSION
AND REQUESTS FOR PRODUCTTON TO AVISTA CORPORATION
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,
selling to Avista for each hour for the past 3 years in excel spreadsheet format.
Production Request 14: Provide total generation (MWh) of all QFs that would be
categorized as "other" on Avista's published rate schedules selling to Avista in for each hour for
the past 3 years excel spreadsheet format.
Production Request 15: For each year since 1990, provide: (i) an accounting of the
total amount collected by Avista under the IPUC-jurisdictional PURPA interconnections
operation and maintenance charges, and (ii) an accounting of the total cost incurred by Avista for
operation and maintenance expenses on QF interconnections.
Production Request 16: For each QF project listed in the response to Production
Request l, please provide: (i) the amount collected by Avista for IPUC-jurisdictional PURPA
interconnections interconnection O&M charges and (ii) the actual interconnection O&M
expenses incurred by Avista for each year that the QF project was in operation.
Dated: June 20, 2018
ON ADAMS, P.L.L.C
M. Adams, ISB No. 7454
Attorneys for Petitioner J.R. Simplot
Company
J.R. SIMPLOT COMPANY'S FIRST TNTERROGATORIES, REQUESTS FOR ADMISSION
AND REQUESTS FOR PRODUCTION TO AVISTA CORPORATION
IPUC-E-18-07
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2l't day of June 2018, a true and correct copy of the within and
foregoing FIRST INTERROGATORIES, REQUESTS FOR ADMISSION AND REQUESTS
FOR PRODUCTION of the J.R. Simplot Company to the Avista Corporation in Case No.
IPC-E-18-07 were delivered via electronic mail to the following:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise, Idaho 83702
Diane.holt@puc. idaho. gov
Michael G. Andrea
Senior Counsel, Avista Corporation
l41l E. Mission Ave, MSC-23
Spokane, WA 99202
Michael. andrea@avistacorp. com
Tamarack Energy Partnership
Michael Cream and Preston Carter
601 W. Bannock
Boise, Idaho 83702
mcc@ givenspursley. com
pnc@ givenspursley. som
Irion Sanger
Sanger Law, P.C.
l1l7 SE 53'd Avenue
Portland, OR 97215
[e-mail]
Clint Kalich
Manager, Resource Planning and Analysis
Avista Corporation
l4l1 E" Mission Ave, MSC-7
Spokane, WA 99202
clint. kalich@avistacorp. com
Donovan Walker
Idaho Power Company
l22l West Idaho Street
Boise, Idaho 83702
dwalker@ idahopower. com
C. Tom Arkoosh
Arkoosh Law Offices
P.O. Box 2900
Boise, Idaho 83701
tom. arkoo sh(@arkoosh. com
J. Kahle Becker
223 North 6th St, #325
Boise, tdaho 83702
@w.com
Kandi Walters
J.R. SIMPLOT COMPANY'S FIRST INTERROGATORIES, REQUESTS FOR ADMISSION
AND REQUESTS FOR PRODUCTION TO AVISTA CORPORATION
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