20180703IPC to JR Simplot 23-25.pdf

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DONOVAN E. WALKER
Lead Counse!
dwal ker@i dahopower. com
DEW:csb
Enclosures
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ovan E. Walker
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An IDACORP Company
1221 W. ldaho 5t. (83702)
P.O. Box 70
Boise, lD 83707
July 3, 2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
47 2 W est Wash i ngton 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 lnterrogatories 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 ldaho Power Company's Response to J.R. Simplot Company's Third Set of Requests
for Production.
Very truly yours,
Z
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]
dwalker@ idahopower. com
!N 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
QUALIFY!NG FACILITIES
RE C E IVED
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CASE NO. tPC-E-18-07
IDAHO POWER COMPANY'S
RESPONSE TO J.R. SIMPLOT
COMPANY'S THIRD SET OF
REQUESTS FOR PRODUCTION
COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?ny"), and in
response to J.R. Simplot Company's Third Set of Requests for Production to ldaho
Power Company dated June 13,2018, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT
COMPANY'S THIRD SET OF REQUESTS FOR PRODUCTION - 1
PRODUCTION REQUEST NO. 23: Please provide all documents filed with the
Federal Energy Regulatory Commission requesting approval of 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.
RESPONSE TO PRODUCTION REQUEST NO. 23: Idaho Power is not aware
of any Federal Energy Regulatory Commission ("FERC") documents, or Idaho Power
filings with FERC, specifically addressing a method of calculating operation and
maintenance charges to interconnection customers under either the small generator
interconnection agreement ("SGIA") or large generator interconnection agreement
("LG!A"). Neither the SGIA nor the LGIA contain methods of calculating operation and
maintenance charges. See ldaho Power's answer to J.R. Simplot Company's
("Simplot") lnterrogatory No. 13 subparts (ii) and (iii). The pro forma SGIA and LGIA
were approved by FERC as part of Idaho Power's Open Access Transmission Tariff
("OATT'), which was part of the process from FERC Order Nos. 888, 2003, etc. FERC
orders and dockets are publicly available to search via FERC's website.
The response to this Production Request is sponsored by Jeremiah Creason,
Operations Analyst ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT
COMPANY'S THIRD SET OF REQUESTS FOR PRODUCTION - 2
PRODUCTION REQUEST NO. 24: Please provide all orders issued by the
Federal Energy Regulatory Commission approving of 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 ag reements.
RESPONSE TO PRODUCTION REQUEST NO. 24: Please see ldaho Power's
response to Simplot's Production Request No. 23.
The response to this Production Request is sponsored by Jeremiah Creason,
Operations Analyst ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT
COMPANY'S THIRD SET OF REQUESTS FOR PRODUCTION - 3
PRODUCTION REQUEST NO. 25: Please provide all documents made
available in ldaho Power Open Access Transmission Tariff and its Open Access Same-
time lnformation System website, for prospective interconnection customers, describing
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.
RESPONSE TO PRODUCTION REQUEST NO. 25: The pro forma SGIA and
LGIA are both publicly available as part of ldaho Power's OATT via the Company's
Open Access Same-Time lnformation System ("OAS|S") website, as are the Company's
small and large generator interconnection procedures (SGIP and LGIP). Beyond what
is set forth in the OATT, Idaho Power is not aware of any other specific information
regarding methods of calculating operation and maintenance charges that is available
on the OASIS website.
The response to this Production Request is sponsored by Jeremiah Creason,
Operations Analyst ll, ldaho Power Company.
DATED at Boise, ldaho, this 3rd day of July 18
E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT
COMPANY'S THIRD SET OF REQUESTS FOR PRODUCTION - 4
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 RESPONSE TO J.R. SIMPLOT COMPANY'S
THIRD SET OF REQUESTS FOR PRODUCTION 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
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Company
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, Inc.
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
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ams.com
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IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT
COMPANY'S THIRD SET OF REQUESTS FOR PRODUCTION - 5
lrion Sanger
SANGER !.AW, 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
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
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pnc@q ivenspu rslev. com
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c Bearry, LegalAssistant
IDAHO POWER COMPANY'S RESPONSE TO J.R. SIMPLOT
COMPANY'S THIRD SET OF REQUESTS FOR PRODUCTION - 6