20180710REC 2.1-2.17 to IPC.pdf

N[C EIVED
BEFORE rHtr rDAHo puBl,rc urtl,rry coMMrss$$ lu r n pH 3: 25
IN THE MATTER OF PETITION OF
IDAHYDRO. SHOROCK HYDRO, INC].,
.I.R. SIMPLOT CIOMPANY. AND
RL,NEWABLE ENERGY COALI'|ION ITOR
MODIIIICA'I'ION OI; I'IIE, 9OI I IO
PERFORMANCE BAND ANI)
CAI,CUI,ATION OF OPERATION AND
MAINTENANC]E CHARGES FOR PI.JRPA
QI.JALIFYING FACILITIES
Clase No. lPCI-E-18-07
RENEWABLE ENERGY COALI'I'ION'S
SEC]OND REQUEST FOR
PRODUCTION
TO IDAHO POWER
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Dated: July 10,2018
I. DEFINITIONS
"D<louments" refers to all writings and records of every type in your possessicln, control,
or custody. whether or not claimed to be privileged or otherwise excludable {iom
discovery, including but not limited to: testimony and exhibits, memoranda. papers,
correspondence. letters, reports (including drafts. prelinrinary, intermediate, and final
reporls). surveys. analyses, studies (including econornic and rnarket str"rdies), summaries,
comparisons, tabulations, bills, invoices, statements of services rendered. chafts, books.
pamphlets" photographs. maps, bulletins. corporate or other minutes. notes. diaries. log
sheets, ledgers, transcripts, microlilm, rnicrofiche. computer data (including E-rnail),
cotxputer Iiles, compuler tapes, compLrter inputs. computer outputs and printouts,
vouchers. accounting staternents. budgets, workpapers, engineering diagrams (including
"one-line" diagrams), mechanical and electrical recordings, telephone and telegraphic
comnrunications. speeches, and all other records. written. electrical. mechanical. or
otherwise, and drafts of any of the above.
"Documents"'includes copies ol'documents, where the originals are not in your
possession. custody or cotrtrol.
'"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.
ool)ocuments" also includes any attachments or appendices to any document.
2. "ldentification" and "identify" mearl:
When used with respect to a clocument, stating the nature of the clocument (e.g., letter,
memorandum. corporate minutes); the date. il'anv. appearing thereon; the date. il'known.
on n,hich tlre document was prepared; the title of the document; the general sub.iect
rnatter of the docunrent: the rrurnber of pages comprising tlre document;the identity of
PAGE r * SECOND REQUEST rrOR PRODUCTTON TO IDAI{O POWER
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each person r,vlro wrote, dictated. or otherwise participaled in the preparation of the
document; the identity of each person r,vho signed or initiated the document; the identity
of each person to rvhom the docurnent was addressed: the identity of each person who
received the document or revierved it: the location of thc document; and the identity of
each person lTavirrg possession. custody" or control of the document.
When used rvith respect to a person. stating his or her lirlI name; his or her most recently
knon,n home anel business addresses and telephone uurnbers: his or her present title and
position; and his or her present and prior conrrections or associations w,ith any parlicipant
or party to this proceeding.
"ldaho Pclwer" ref-ers to ldah<l Power Company. any aftiliated company, or an)'officer.
clirectol or ernployee ol'lclaho Power. or any al'liliated company.
"'Persorl" ref'ers to, rvithout limiting the generality of its meaning, every natllrai person,
corporation, pafinership, association (whether fbrmally organized or ad hoc),.ioint
venture. unit <lperation. cooperative. municipality'. commissiorl. governmental bocly or
agency, or any other group or organization.
"Studies" or'ostLrdy" includes, r.vithout limitation, reports. reviews, analyses and audits.
The terrns u'and" and "or" shall be construed either dis.ir"rnctively or conjunctively
rvhenever appropriate in order to bring within the scope of this discovery any information
or documents whicli might othervvise be considered to be beyond their scope.
The singular fonn of a word shall be interpreted as plural. and the plural fbrm of arvord
shall be interpreted as singular, whenever appropriate in order to bring within the scope
of this discovery request any infbnnation <lr doouments which might othenvise be
considered to be beyond their scope.
II. INSTRUCTIONS
These requests call ftrr all infonnation. including inforrnation contained in documents.
lvhich relate to the subject matter of the Request and whioh is known or available to yoLr.
Where a Request has a number of separate subdivisiolls or related pafts or portions. a
cormplete response is required to each such subdivision, parl or pofiion. Any objection to
a Request should clearl-v indicate the subdivision. part. or portion of the Request to whiclr
it is directed.
'l'he time periocl encompassed by these Requests is liom 2002 to the present unless
otherwise specified.
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Each response should be {urnished on a separate page. ln addition to hald copy.
electronic versions ol'the document. including studies and analyses, r'nust also be
f urnished if available.
If you cannot answer a Request in tull. after exercising due cliligence to secure the
information necessary to do scl. state the answer to the extent possible. state why yoLt
cannot answer the Request in hrll. and state what inlbrmation or knowledge you have
concerning the unanswered portior s.
If, in ansrverirrg any of these Requests. you feel tlrat any Request or deflnitiorr or
instruction applicable thereto is ambiguous. set forth the language you feel is ambiguous
and the interpretatir)n vou are using irr responding to the Request.
If a document requested is unavailable, identily the documerrt. describe in detail the
reasons the document is unavailable. state where the docunrent carr be obtained. and
specify' the number of pages it contains.
If 1.'ou asseft that any clocument has been destroyed, state when and why it was destroyed
and identify'the person who directed the clestruction. If the documenl was destroyed
pursuant to your document destruction program, identily and produce a copy ol'the
guideline. policy', or cornpany manual describing such document destruction prograrn.
lf you refuse to respond to any Request by reason of a clairn of privilege, confiderrtiality.
or for any other reason, state irr writing the type of privilege claimed and the fbcts and
circumstances you rely upon to supporl the claim of privilege or the reason lbr relusing to
respond. With respect to requests fcrr documents to wtich you refuse to respond, identify
each such document. and specifr'tlre number of pages it contains. Please provide: (a) a
brief description of the document; (b) date of docunrent; (c) narne of eacl'r author or
preparer; (d) narne of each person who received the document; arld (e) the reason fbr
withholding it and a statement of fhcts constituting the justilication and basis lbr
r.vithholding it.
Identifl.'the person fl'om whom the infbrmation and documerrts supplied in response to
each Request were obtained. the person r,vho prepared each response, the persorr who
reviewed each response, and the person r.l,ho rvill bear ultinrate responsibility fortlre truth
ofeach response.
I l. If no document is responsive to a Request that calls fbr a docurnent. then so state.
12.These reqllcsts for docLrments and responses are continuing in character so as to require
you to file supplemental answers as soon as possible if you obtairr further or different
information. Any supplemental answer should ref'er to the date and use the number ol'the
original request or subpaft tlrereof.
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PAGE 3 - StsCrOND REQUES'I'[;OR PRODUCI'rON 1'O IDAI'{O POWL,R
13.Whenever these Requests specifically request an answer rather than the identillcation of
documents. the answer is required and the production of documents in lieu thereol'will
not sr.rbstitr"rte fbr an ans\,!'er.
t4 Wherever these requests ask tbr a formula. if the formula is contained in an excel or other
workbook please provide arr electronic cop.v of the workbook with all fonnulas intact.
l5 Wherever these requests ask for a specitic number or input fbr a fbrmula. Idaho Power
rray respond by- providing the underlving documents that contain the specific number or
input r.vith an explanation of where the requested infonnation can be found.
t6 'l'o the extent that the Company believes it is burdensome to produce specilic inlbrmation
requested, please contact RHC to discuss the problem prior to filing an answer ob.iecting
on that basis to determine is the request can be modified to pose less ditliculty in
responding.
tt 'l'o the extent the Cornpany objects to any of'the requests please contact REC to
determine il'the request can be modilied to produce a less ob.iec.tionable request.
III. SECOND [{EOL]EST FOR PRODIJC]]"ION:
2.t In response to REC's request number 1.2. ldaho Power indicated that tl-re workpapels
applying the methodolog.v to arrive at the escalating rates on 'l'able I and 2 on Schedule
72 arc not available. Idaho Power produced in Attachment 2 a document rvith the header..WORKPAPER IDAHO POWER COMPANY QUAI,IFYING FACII-ITIES
INTERCONNECTION O&M SCHEDTJLE Schedule No. T2" detailing the final results
in the table arrd the inputs used. Please apply these irrputs to tlre rnetlrodology and show
how the rates in Table I and 2 were reached.
2.2 In response to REC's request number 1.3. Idaho Porver did not provide updated values
fcrr calculatior, of the appropriate ()&M rate for interconnections I38 kV and above.
Please provide tlie updated values necessary to perfbrm a calculation for interconnections
1 38 kV and above.
:. -1 Docs the Operations and Maintenance charge cover the cost of replacenrent facilities
once the t-acilities have reached the end of their usefirl life? If not. wlro covers the cost of
replacernent laci lities'/
2.4 Please rcfcr to Idaho Power's rcsponses to REC's Requests for Production Nos. 1.4 and
1.5.
a. Does ldaho Power continue to charge O&M rates on previous interconnection
faci I ities indefi n itely?
PAGE 4 - SHCOND RHQUESl'FOR PRODUC"|ION t'O IDAr'rO POWER
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b. Clonsider an interconnection agreement ,uvith a lenglh o{' 35 years anc-l that provicles fbr
construction o{'a lacility with a uselirl lif'e of 32 years. Does the O&M charge still
continue tbr.vears 32-35 even thouglr the t'acility actually constructed is no lorrger
r"rseful?
l)oes ldaho Power charge FERC-.lurisdictional interconnections under its OATT for
actual operations and nraintenancc cltarges or does ldaho Porver use the sarne Schedule
72 forrnula fbr recovering operations ancl maintenance cliarges?
l;ol'each QF listecl in Idaho Power's Response to .1.R. Sinrplot's Request {br Production
No. 16. please provide an itemization ol'the interconnection lacilities that were
constructed includin g:
a. Description o{'the l'acilities consructed (i.e. overhead lines, substations, poles.
breakers. meters, etc.)
b. Cost of each facility, andc. Whether each t-acility constructed is a transmission f-acility subject to the rates in
Table I of SchediileT2 (138 kV ancl l6l kV) or a distribution facility subject to the
rates in'l'able 2 ol'Schedule 72 (llelow 138 kV)
For cach QF listed in ldalro Power's Response to .l.R. Siurplot's Request fcrr Production
No. 16. please provide tlre original interconnection costs. the portion of the original
interconnection cost that is subjecl to the rates in 'l'able I ol'Schedrile 72 (138 kV and
l6l kV), the portion o{'the original interconnection cr:sts that is subject to the rates in
Table 2 of Schedule 72 (Below I 38 kV), and the O&M charges collected per year for
each year since I 990.
lior the last 3 years, please list all O&M expenses incurecl by tdaho Power in the
operalions and maintenance o{'ldaho Por.ver's distribution facilities of trelow 138 kV
inch.rding thc tbl lowing i nfbrmation :
a. Description o{.the expense
b. Date the e.xpense was itrcurred
c. Cost of the experlse
d. The O&M expense category fiom categories listed in Idaho Power's response to
RECI's Request for Production No. 1.2 Attac,hment I
e. The type <lf facility upon which the maintenance is perftrrmed (i.e. overhead lines,
substations, poles. breakers. meters, etc.)
{. 'l'he location o1'the l'acility where maintenance is per{bnned
g. Whether the maintenance was perfbr:med in an ernergent situation and why it w'as
emergent (i.e. to repair outages resulting t}om stonns, etc.)
h. l{'the expense was not incurred on an erlergent basis, please provide the date Idaho
Porver identi{it:d the need {br rr,aintenance work and the date(s) the work r,r,as actually
perf'ormed
PAGE 5 * SECOND RHQUHSI'r;OR PRODUC"I"ION 't'O IDAI{O POWER
2.9 I]or the lasl 3 years" please list all O&M expenses incurred hy ldaho Power in the
operations and rnaintenance ol'ldaho Power's transmission facilities of 138 kV and l6l
kV including the tblloiving infbrmation:
a. Descriptiori of the expense
b. Date the expense was incurred
c. Cost of the expense
d. The equivalcnt O&M transmission expense category to the categories listed in Idaho
Porver's response to REC's ReqLrest fbr Production No. 1.2 Attachment I for
d istribution faci I ities
e. 'l'he type ol'facility upon which the maintenance is perlbnned (i.e. overhead lines,
substations, poles. breakers" meters, etc.)
f.. The location of the fhcility where maintenance is perfcrrmed
g. Whether the maintenance w'as pertbrmed in an enrergent situation and why it was
emergent (i.e. to repair outages resulting from storms. etc.)
h. ll'the experrse was not incurred on an emergent basis, please provide the date Idaho
Power identifled the need for nraintenance work and the date(s) the work was actually
pcrtbrmed
2.10 For eaoh value ldalro Power provided in response to REC's Request frlr Production No.
1.2 in Attachment l, please provide an iternization o1'all the expenses that are inclLrded
within that value.
2.11 For each of tlre categories listed in the attachment to Idalro Power's response to REC's
Recluest firr Procluction No. 1.10. please detail what kincls of facilities are included are
included in that category and tl-re dollar value.
2.12 Please list the types of facilities (poles, wires. meters. etc.) that ldaho Power uses in its
clistribution (below 138 kV) systern. For each tacility type, please provicle:
a. 'l'he total capital cosl fbr all {acilities of'that type
b. The percentage of the capital cost to the total capital cost fbr the distribution system
c. The portion of the capital cost for all facilities of that type that are constructed
pursuant to an interconnection agreement governed by and subject to the Schedule 72
O&M fees
d. The percentage of the vahle produced in response to 2.12{c) to the total fbr all
facilities are constructed pursuant to an interconnection agrcenrent governed by and
subject to the Schedule 72 O&M fees
2.13 Please list the types ol'lacilities (poles, wires. meters. e1c.) that ldaho Power uses in its
transmission (138 kV and l6l kV) system. For each facility type. please provide:
a. The total capital cost firr all facilities of that type
b. 'l'he percentage ol'the capital cost to the totalcapitalcost lbrthe transmission system
c. The porlion of the capital cost fbr all tbcilities of that type that are constructed
pursuant to an interconnection agreement govemed b.v and subject to the Schedule 72
0&M tbes
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d. 'l'he percentage ol'the value produced in respollse to 2.13(c) to the total lor all
facilities are constructed pursuant to an interconnection agreement governed by and
subject to the Schedule 72 O&M f'ees
2.14 What is the average age of all of ldaho Power's clistribution facilities?
7.15 What is the average agc of the distribution facilities constructed pursuantto an
irrtcrconnection agreement govcnred by and sub.iect to the Schedule 72 O&M t'ees?
2.16 What is the average age of all of Idaho Power's transmissiorr facilities?
2.17 What is the average age of the transmission l'acilities constructed pursuant to an
interconnection agreement governed by and subiect to the Schedule 72 O&M f'ees?
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