20180703IPC Answer to JR Simplot 11-13.pdf

SIffi*
DONOVAN E. WALKER
Lead Counsel
dwal [e-mail]
DEW:csb
Enclosures
P.ECEIVED
IfllB J{"lL *3 PH 2: l8
::r!i t,-lli,, | -. iriit-ltr
, jrii , l'l .::t {_lij:*ii,,llSSl0l{
July 3, 2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington 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 Answer to J.R.
Simplot Company's Second Set of Interrogatories and ldaho Power
Company's Response to J.R. Simplot Company's Third Set of Requests for
Production
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and three (3) copies each of
ldaho Power Company's Answer to J.R. Simplot Company's Second Set of lnterrogatories
and Idaho Power Company's Response to J.R. Simplot Company's Third Set of Requests
for Production.
Very truly yours,
n E. Walker
@
An IDACORP Company
1221 W' ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
Z
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ida opower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
TiECEIVED
?0l8.lUL -3 Pl{ 2' lB
i[.];i,l-:a: fUELIC
i-i il i ii :;--i COlll,llSSl0N
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
CASE NO. tPC-E-18-07
IDAHO POWER COMPANY'S
ANSWER TO J.R. SIMPLOT
COMPANY'S SECOND SET OF
INTERROGATORIES
)
)
)
)
)
)
)
)
)
)
COMES NOW, Idaho Power Company ("ldaho Power"), and in answer to J.R.
Simplot Company's Second Set of lnterrogatories dated June 13, 2018, herewith
submits the following information:
IDAHO POWER COMPANY'S ANSWER TO J.R. SIMPLOT
COMPANY'S SECOND SET OF INTERROGATORIES - 1
INTERROGATORY NO. 11: Please describe ldaho 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.
ANSWER TO INTERROGATORY NO. 11:ldaho Power does not currently
calculate operation and maintenance charges for any customers under either the small
generator interconnection agreement ("SGlA") or large generator interconnection
agreement ('LGIA").
The answer to this lnterrogatory is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWER TO J.R. SIMPLOT
COMPANY'S SECOND SET OF INTERROGATORIES - 2
INTERROGATORY NO. 12: lf ldaho Power's currently-used method of
calculating operation and maintenance charges to interconnection customers under
FERC-jurisdictiona! small generator interconnection agreements and large generator
interconnection agreements is the same as its method for calculating such charges
under Schedule 72 interconnections, please describe in detail how ldaho Power notified
FERC of this method of calculating the charge and describe the manner in which FERC
approved of use of the charge.
ANSWER TO INTERROGATORY NO. 12: Please see ldaho Power's answer to
J.R. Simplot Company's lnterrogatory No. 11.
The answer to this Interrogatory is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWER TO J.R. SIMPLOT
COMPANY'S SECOND SET OF INTERROGATORIES - 3
INTERROGATORY NO. 13: Please identify all of ldaho Power's currently
effective FERC-jurisdictional small generator interconnection agreements and large
generator interconnection agreements including such agreements for ldaho Power-
owned generation. lnclude 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) section of the interconnection agreement that explains
the method of calculating the operation and maintenance charges to the interconnection
customer under the agreement.
ANSWER TO INTERROGATORY NO. 13:
(i) ldaho Power currently has six Federal Energy Regulatory Commission
jurisdictional, non-Public Utility Regulatory Policies Act of 1978 (PURPA) gene.rator
interconnection agreements with the following entities: Elkhorn Valley Wind Project;
U.S. Geotherma!, lnc.; City of Seattle, Lucky Peak Project; Caribou, lnc.; ldaho Power
Company Power Supply, Evander Andrews; ldaho Power Company Power Supply,
Langley Gulch.
(ii) All generator interconnection agreements for the above-referenced entities
are the pro forma documents from ldaho Power's Open Access Transmission Tariff, and
do not contain a method of calculating the operation and maintenance charges to
interconnection customers.
(iii) While both the SGIA and LGIA contain statements that the interconnection
customer shall be responsible for reasonable expenses associated with operating and
maintaining interconnection facilities, neither the SGIA nor the LGIA contain methods of
calculating operation and maintenance charges. See LGIA S 10.5; SGIA S 4.1.2.
The answer to this Interrogatory is sponsored by Jeremiah Creason, Operations
Analyst ll, ldaho Power Company.
IDAHO POWER COMPANY'S ANSWER TO J.R. SIMPLOT
COMPANY'S SECOND SET OF INTERROGATORIES - 4
DATED at Boise, Idaho, this 3'd day of July 2018.
E.R
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S ANSWER TO J.R. SIMPLOT
COMPANY'S SECOND SET OF INTERROGATORIES - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 3rd day of July 2018 I served a true and correct
copy of IDAHO POWER COMPANY'S ANSWER TO J.R. SIMPLOT COMPANY'S
SECOND SET OF INTERROGATORIES 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 i ngton (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
Idahydro and Shorock Hydro, lnc.
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, Idaho 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
IDAHO POWER COMPANY'S ANSWER TO J.R. SIMPLOT
COMPANY'S SECOND SET OF INTERROGATORIES - 6
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
q reg @ ri ch a rd sonadams.qem
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mai!
_Overnight Mail
_FAXX Email [e-mail]
Irion Sanger
SANGER LAW, P.C.
1117 SW 53'd Avenue
Portland, Oregon 97215
Tamarack Energy Partnership
Michae! C. Creamer
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Avista Corporation
Michael G. Andrea, Senior Counsel
Avista Corporation
1411 East Mission Avenue, MSC-23
Spokane, Washington 99202
Clint Kalich
Manager, Resource Planning and Analysis
Avista Corporation
1411 East Mission Avenue, MSC-7
Spokane, Washington 99202
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
pnc@givenspursley. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
C Bearry,
IDAHO POWER COMPANY'S ANSWER TO J.R. SIMPLOT
COMPANY'S SECOND SET OF INTERROGATORIES - 7