20180706REC 1-13 to Avista.pdf

nrt EtvtD
BEFORB THtr IDAHO PUBLIC UTILITY COMMISSIONiilii.il.tl -6 pH Z: tZ
IN THE MATTER OF PETITION OF
IDAHYDRO. SHOROC]K HYDRO, INC."
J.R. SIMPLOT C]OMPANY, AND
RENtsV/AI]LE EN ERGY C]OALTfION [:OR
MODIFICATION OF THE 9OIIIO
PERFORMANCE BAND ANI)
CALCTJLATION OF OPERATION AND
MAINTENANCE CHARCES FOR PIJRPA
QUALIFYING IrAC ILlllES
Case No. IPC-E-18-07
RENEWABLH ENHRGY COAI,ITION'S
FIRST REQUEST FOR PRODUCTION
TO AVISTA
)
)
)
)
)
)
)
)
)
)
Dated: .luly 6,2018
I. DEFINITIONS
"l)ocuments" relers to all writings and records of'every type in yoLlr possession, control,
or custody, whether or not claimed to be privileged or othenvise excludable {}om
discovery, including but not limited to: testimony and exhibits" memoranda, papers,
correspondence. letters. repofts (including drafts. prelinrinary, intermediate, and final
repclrts), sLrrveys, analyses. studies (inoluding ecernomic and market studies). summaries,
cornparisons, tabulaticxs, bills, invoices, statements of services rendered. chafts, books.
paniphlets, photographs. maps, bulletins, corporate or other minutes" notes. diaries, log
sheets, ledgers, transcripts, microfilm, microliche, computer data (including E-mail),
computer files, conrputer tapes, computer inputs, computer outpnts and printouts,
vouchers. accounting statcurents. budgets, workpapers, engineering diagrams (including
"one-line" diagrams). meclianical and electrical recordings, teleplione and telegraphic
communications. speeches. and all other reoords. r.vritten. electrical. meohanical. or
otherlvise, and dra{ls of any ol'the above.
"'Documents" includes copies of documents, where the originals are not in your
possession, custody or cotrtrol.
"Documents" inclucles every copy of a document r,vhich contains lrandwritten or other
notations or r.vliich otherwise does not duplicate the original or any other cr:py.
"Docunrents" also includes any atlachments or appendices to any docunrent.
2. "ldentification" and "identify'" mean
When Lrsed with respect to a document, stating tlie nature ol'the document (e.g., letter,
memorandum. corporate minutes); the date. if'any, appearing thereon; the date, i{'known.
on wlrich tlre doclrr'Ilent was prepared; tlre title of tlre documcnt; the general sub.iect
matter of the document: the rrurnber of pages conrprisir-rg the document;the identity of
each person who wrote. dictated, or otherrvise participated in the preparation of the
PAGI: I * FIRS'I'RL,QUES'f [;OR PRODL]CI'ION'fO AVIS'I'A
5.
6.
document: the identity of each person rvho signed or initiated the document; the identitl.'
of each person to rvhom the document was addressed; the identity of eaclr person who
receivcd the docurnent or revieu,ed it;the location of the docurnent: and the identity of
eaclr person having possession, custody, or control of the document.
When used rvith respect to a person. stating his or her f'ull 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 rvith any parlicipant
r:r party to this proceeding.
"Avista" refers to Avista Corporation, Washington Water Power. any affiliated company,
or any cll'llcer. director or employee o{'Avista, or any af'l'iliated company.
"Pcrson"'ref'ers to. w'ithout limiting the generality of its meaning. every llatural person,
corporatiorr. partnership. association (whcther fcrrrnally organized or ad hoc), joint
veuture, unit operation" cooperative, municipality, comnrission, governmental body or
agency, or any other group or organization.
"Studies" or "'study" ir-rcludes. without lirnitation, reports, reviervs. analyses and audits.
The ternrs "and" and "or" shall be construed either disjunctively or coniunctively
whenever appropriate in order to bring within the scope of this discovery any infonnation
or documents vvhich might otherrvise be considered to be beyond tlreir scope.
The singular fbrm of a rvord shall be interpreted as plural, and the pluralform of a word
shall be irrterpreted as singular. w'lrenever appropriate in order to bring rvithin the scope
of this cliscovery reqLrest any information or documents which rnight otherwise be
corrsiclered to be beyond their soope.
These recluests call for all intbrnration, inch"rding inftrrmation c'ontained in documents.
which relate to the sutrject matter of the Request and which is knolvn or available to you.
Where a Request has a nurnber o1'separate subdivisions or related parts or portions, a
complete response is required to each surch subdivision. part or portion. Any objection to
a Request should clearly indicate the subdivision, paft, or portion of the Request to which
it is clirected.
'l'lre tirne period encompassed by these Requests is fn:m 2002 to the present unless
otherrvise speciIied.
Each response should be furnished on a separate page. In addition to hard copy.
electronic versions of the document. including studies and analyses, must also be
fumished if available.
J
1.
-')
1
7
2
PACE 2 - IIIRS]'REQUES'I'FOR PRODUCI'ION 1'O AVIS"|A
II. INS'TRTJCTIONS
5 If'you cannot answer a Request in {ull, aller exercising due diligence to secure the
information necessary to do so, state the answer to the extent possible, state why you
cannot ans\.ver the Request in full. and state what infonnation or knorvledge you have
concerning the unansrvered poftions.
ll. in answering any o{'these Requests, you l'eel that any Request or delinition or
instruction applicable thereto is anrbiguous, set fbrth the language you I'eel is ambigr-ror-rs
and the interpretation you are using in responding to the Reqr"rest.
If a clocurnent requested is unavailable, identify the document. describe in detail the
reasons the document is unavailable, state where the document can be obtained, and
specitl, the trutnber ol'pages it contains.
If you assert that any document has been destroyed. state wherr and why it was destroyed
and identitl.'the person who directed the destnrction. If the docurrent was destroyed
pursuant to your docurlent destruction program. iclentify and produce a copy of the
guideline, polic,y, or company manual describing such document destruction prograrn.
11'you refuse to respond to any Request b.v reason ol'a claim ol'privilege. conlidentiality,
or tbr any other reason, state in rvriting the type of privilege clairned and the facts and
circumstances you rely upon to sLrpport the clainr of privilege or the reason fbr refusing to
responcl. With respect to requests firr documents to which you refuse to respond. identify
each such document. and specifvthe numtrerof pages itcontains. Please provide: (a) a
briel'description ol'the document; (b) date ol'document: (c) name ol'each author or
preparer; (d) narne of each person who received the document;and (e) the reason for
withholding it and a statement of f-acts constitlrting the.iustification and basis for
r,vithholding it.
Identify the person lrom rvhom the infonnation and documents supplied in response to
eacl'r Request lvere obtained, the person r.vho prepared each response. the person who
revierved each response, and the person i.vho will bear ultimate responsibility fbr tlre truth
ofeach response.
I 1. If no docurnent is responsive to a Request that calls for a document. then so state
12.'l'hese requests fbr documents and responses are continuing in character so as to require
.vou to file supplernental answers as soorl as possible if ,vou obtain further or different
inforrnation. Any supplemental answer should ref-er to the date and use the number of the
original request or subpaft thereof.
I -'r Whenever these Requests specifically request an answer rather than the identification of
documents. the answer is required and the production of documents in lieu thereol'will
not substitute fbr an answer.
11.Wherever these requests ask for a formula, if tlie formula is corrtained in an excel or other
rvorkhook please provide an electronic copy of the workbook with all firrmulas intact.
6
1
8
9
10
PACE, 3 - I;IRS'| REQUES'f I;OR PRODUC]'ION 'IO AVIS'I'A
t5
l6
t7
1.2
1.3
1.4
t.5
1.6
t./
Wherever these requests ask lbr a specilic nurnber or input {br a lbrmula, Avista may
respond by providing the underlying docr"unents that contain the specific nurlber or input
with an explanatiorr of'where the requested infirrmation can be fbund.
To the extent that the Company believes it is burdensome to produce specific infi:rmation
requested, please contact REC to discuss the problem prior to liling an answer ob.iecting
on that basis to determine is the request can be modilied to pose less difliculty in
responding.
To the extent the Cornpany objects to any of the requests please contact RECI t<r
cletermine if the request can be modified to produce a less obiectionable requcst
III. FIRST REQUEST FOR PRODUCTION
Please provide copies of Avista's responses to all other parties requests fbr production of
documents. This is an ongoing request.
Please provide the methodology that Avista uses to calculate and cliarge qualifying
facilities ("QFs") fbr operations and nraintenance ("O&M") expenses fbr the QF's
interconnection faci I ities.
Please provide the melhodology that Avista uses to calculate and charge all non-QF
senerators for O&M expenses {br the generator's interconnection I'acilities.
In order No. 24025. the ldaho Public Utility Conrrnission ("IPUC") approved O&M
charges to be paid by QFs to ldaho Power Cornpany on QF-provided. utility-owned
interconnectionfacilitiesassetforthinldahoPower'sScheclule 72. lnthatorder,itwas
noted that Idaho Power's methodology was "a common methodology used by other Idaho
and northrvest utilities, r.vith the exception o1'Washinglon Water Power Company.'" Since
Avista is the successor to Washington Water Porver Comparry. please provide the
methoclology that Waslrington Water Power Comparry used at the time Orcler No. 24025
came out on December l. I991. if known.
Does Avista have a Schedule approved by the IPUC that govems Interconnections to
Non-Utility Generation that is akin to Idaho Power's Sclredule 72. lf so, please provide
the most recerrt version of this Schedule.
Does Avista charge O&M expenses to QFs for the operation and maintenance ol'
interconnection fbcilities that rvere corrstructed under a prior agreement? If so. please
describe the rnethodology.
When a QIr or other electricity generator that historically operated under an
interconnection agreement with Avista seeks to enter a new interconnectiou agreement,
how does Avista accolrnt fbr prior O&M payments under the new agreement?
PAGE 4 - IIIRS'I'REQUESI- FOR PRODUC'|ION 1"O AVISI'A
t.1
t.8 At present, what is Avista's current average O&M costs fbr its distribution and
transmission facilities? Please also provide the total O&M costs and total capital costs
upon w'hich that average is based and/or any other inputs Avista used to arrive at the
average 0&M costs.
1.9 Please provide a list ol'all QFs that have an interconnection agreement with Avista. For
each {acility please provie'le an accounting of the amount collected by Avista each year
for O&M of tlre interconnection facilities and the actual O&M expenses incurred b-v
Avista each year to operate and rnaintain the intcrconnection facilities.
I .10 I'or each electric utility in the Pacific Norlhwest, please identi{y rvhether interconnection
O&M costs are recovered through a fbrmula rate. actual costs incurred by the utility, or
sonre other methodology.
I .1 1 Dr:es Avista's O&M charge cover the cost ol replacement lacilities once the
interconnection facilities have reached the end ol' their uselirl lil'e? I{'not. who covers the
cost of replacement facilities?
I .12 Hor.v cloes Avista charge FERC-Jurisdictional interoonnections uncler its OATT frlr 0&M
expenses? ls this the same or clifferent than tlre rnethodology usecl to charge QFs for
O&N4 ol' gp provided. utility-owned interconnection Iac.ilities ?
L I3 For eaclr QF listcd in response to Request fbr Production No. L9, please provide an
itemization of the interconnection facilities that rvere constructed including:
a. Desc,ripticln clf the facilities constructed (i.e. overhead lines. substatiorrs, poles.
breakers" meters, etc.)
b. Clost of each f'acility, andc. Whether each ftrcility constructed is a transmission facility sub-iect to the rates in
T'able 1 of Schedule 72 (138 kV and 161 kV) or a distribution facility subject to tire
rates in l'able 2 o{'Schedule 72 (l}elor.v 138 kV)
Dated: .luly 6" 2018
SANGER I,AW, P.C
PAGE 5 - FrRS't'REQUL,S'I FOR PRODUC'|ION 1'O AVIS',I'A
irion Sanger
Attorney for Petitioner
Renewable Energy Coalition
CERTIF'ICA OF SERVICE
I HEREBY CERTIf'Y that on the 6th day of July 2018, a true and corrcct copy of the within and
foregoing RIINIIWABLA IlNIIRCY COALITION'S FIRST RIIQL]EST fOR PRODLJCTION
1"O AVIS'['A in Case No. IPC-E-18-07 rvere de livered via electronic mailto the follorving:
Diane l'laniau
Clonrm ission Sccretaty
Idaho Public t.ltilities Conrnrissiort
472 West Washington Street
Boise. ldaho 83702
Diane.ho l ti(lpuc. i daho. qov
Michael C. Andrea
Sen ior Counsel. Av i sta Corporation
l,1l I E. Mission Ave. MSC-23
Spokane. WA 99242
M i chael. iutd rea(ilavi stacorp. cotn
"laurarack Iiuergy Partrtership
Michael Crcanr and Prestort Carter
601 W. Banrtock
Boise, Iclaho 83702
rl ccill-i g i v en sp u rs lel-. com
pnc (l) g i ve lt s rr urs I ey.corn
Peter.l. Richarclson
Gregory M. Adartrs
Richarclscln Aclam s, PLI,C
P.O. Box 72ltl
515 N. 276 Street
Boise. lD 83702
rrctcrrr? r'ichardsottadntns.cor tt
qre gaA'i chaldsonadants. coln
Clint Kalich
Manager. Resource Planning ancl Analysis
Avista Corporation
l4l I E. Mission Ave, MSC-7
Spcrkane, W A 99242
c lin t. kal ich ()av i stacorp.c<im
Donovan Walker
Idaho Power C)ompany
l22l Wesl ldaho Street
Boise. ldaho 83702
dwa I kerldi dahopower. c om
clockets@)idahopower.corn
C. Tont Arkoosh
Arkoosh Larv Offlces
I'}.O. Box 2900
Boise, Idalro tt370l
tom.arkoosh(0arkoosh.com
J. Kahle Becker
223 North 6th St, #325
Boise, Idaho 83702
kahlefu) ka hl e bec kerl aw. cont
David H. Arkoosh
Law Office of David Arkoosh
PO Ilox 2817
Boise,lD 83701
[e-mail]
Edith I']acillo
Deputy AttonlLry Gcneral
Iclaho Publ ic LJtil ities Commission
172 W. Washington (83702)
P0 Bcrx 113720
Boise. ID 83720-0074
edith.paciI Io(0puc.idaho.gov
Min Hu
RIiNEWABI,L, IINIIRGY COALITION'S FIRST REQUEST FOR PRODUCTION TO AVISTA
rPC'-E-l 8-07
CERI"IF ICA'|E OI" SHRVICE