20180711Staff 5-10 to Idahydro.pdf

EDITH PACILLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5430
IN THE MATTER OF THE PETITION OF
TDAHYDRO, SHOROCK HYDRO, INC., J.R.
SIMPLOT COMPANY, AND RENEWABLE
ENERGY COALITION FOR MODIFICATION
OF THE 9O/T1O PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITES.
RECTIVED
2010 JUL I I Pi{ 3: lr I
CASE NO.IPC.E-I8.07
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHYDRO
C
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILTTIES COMMISSION
)
)
)
)
)
)
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edith Pacillo, Deputy Attorney General, request that Idaho Hydroelectric Power Producers, an
Idaho Trust (Idahydro) provide the following documents and information as soon as possible, by
WEDNESDAY, AUGUST 1, 2018.
This Production Request is continuing, and Idahydro is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question and supporting workpapers that provide detail or
are the source of information used in calculations. Idahydro is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. IDAPA 31.01.01.228.
SECOND PRODUCTION REQUEST
TO IDAHYDRO I JULY I I,2OI8
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 5: Has the 90/l l0 performance band restricted your access to capital?
If so, please provide specific examples.
REQUEST NO. 6: How many times has your facility fallen outside the performance
band over the duration of your power purchase agreement? By how much as a percentage?
REQUEST NO. 7: What sort of expenditure in time and resources does it require to
comply with and provide the estimate requirement on a monthly basis?
REQUEST NO. 8: What is the reduced dollar difference, over the term of your power
purchase agreement, you received because your power sales fell outside the performance band in
any given month? What percent is this of your annual gross revenue?
REQUEST NO. 9: How do you define "firm energy" in regards to QF energy sales in
Idaho? How does this definition differ from what you consider the industry definition standard
of"firm energy?"
REQUEST NO. 10: At the time the legally enforceable obligation is incurred, do you
know whether you will receive published avoided costs or Surplus Energy Price for the
electricity you sell to the utility?
SECOND PRODUCTION REQUEST
TO IDAHYDRO 2 JULY 1I, 2OI8
Dated at Boise, Idaho, this t t't1^-' day of July 2018.
Pacillo
Deputy Attorney General
i : umisc:prodreq/ipce I 8. Tepejep prod req2 ldahydro
SECOND PRODUCTION REQUEST
TO IDAHYDRO aJ JULY I I, 20I8
CERTIFICATE OF SERVICB
I HEREBY CERTIFY THAT I HAVE THIS llth DAY OFJULY2018, SERVED
THE FOREGOING SCOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHYDRO IN CASE NO. IPC-E-18-07, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
DAVID H ARKOOSH
LAW OFFICE OF DAVID
ARKOOSH
PO BOX 2817
BOISE ID 83701
E-mail : [e-mail]
J KAHLE BECKER
ATTORNEY AT LAW
223 N 6TH STREET #325
BOISE TD 83702
E-mail: [e-mail]
TAMARACK ENERGY PARTNERSHIP
c/o MICHAEL C CREAMER
PRESTON N CARTER
601 W BANNOCK
BOISE ID 83702
E-mail: [e-mail]
pnc@ givenspursley. com
CLINT KALICH, MANAGER
RESOURCE PLANNING & ANALYSIS
AVISTA CORPORATION
14I I E MISSION AVE, MSC-7
SPOKANE WA992O2
E-mail: [e-mail]
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 8370I
E-mail: [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
gre g@richard sonadams.com
IRION SANGER
SANGER LAW PC
1117 SE 53RD AVE
PORTLAND OR 97215
E-mail: [e-mail]
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
1411 E MISSION AVE, MSC-23
SPOKANE W A 99202
E-mail: [e-mail]
CERTIFICATE OF SERVICE