20180711Staff 5-10 to JR Simplot.pdf

EDITH PACILLO
DEPUTY ATTORNEY GENERAI,
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5430
IN THE MATTER OF THE PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC., J.R.
SIMPLOT COMPANY, AND RENEWABLE
ENERGY COALITION FOR MODIFICATION
OF THE 90/110 PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIF'YING FACILITES.
CASE NO. IPC.E.18.O7
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
J.R. SIMPLOT COMPANY
iIEC EIVED
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edith Pacillo, Deputy Attorney General, request that J.R. Simplot Company (Simplot) provide
the following documents and information as soon as possible, by WEDNESDAY,
AUGUST 1,2018.
This Production Request is continuing, and Simplot 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. Simplot 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 J.R. SIMPLOT COMPANY I JULY 1I, 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 90/110 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 J.R. SIMPLOT COMPANY 2 JULY II,2OI8
Dated at Boise, Idaho, this
i:umisc:prodreq/ipcel 8.7epejep prod req2 J.R. Simplot
SECOND PRODUCTION REQUEST
TO J.R. SIMPLOT COMPANY
llgdav orJulv 2018.
Deputy Attorney General
J JULY II,2OI8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS llth DAY OFJULY 2018, SERVED
THE FOREGOING SCOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO J.R. SIMPLOT COMPANY TN CASE NO. IPC-E-18-07, BY MAILING A
COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN WALKER
LEAD COLINSEL
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : dwalker(E idahopower. com
dockets@ idahopower. com
DAVID H ARKOOSH
LAW OFFICE OF DAVID
ARKOOSH
PO BOX 2817
BOISE ID 8370I
E-mail : [e-mail]
J KAHLE BECKER
ATTORNEY AT LAW
223 N 6TH STREET #325
BOISE ID 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]
.coln
CLINT KALICH, MANAGER
RESOURCE PLANNING & ANALYSIS
AVISTA CORPORATION
1411 E MISSION AVE, MSC-7
SPOKANE WA992O2
E-mail: [e-mail]
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
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@richardsonadams. com
IRION SANGER
SANGER LAW PC
I I I7 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]
SE T
CERTIFICATE OF SERVICE
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