HomeMy WebLinkAbout20180711Staff 5-10 to REC.pdfEDITH PACILLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0318
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
QUALIFYING FACILITES.
RECEIVED
t8i8 JIJL I I PH 3: lr0
CASE NO.IPC.E.18.O7
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
RENEWABLE ENERGY
COALITION
ol't
.UILIC
i)1,{Mtssl
Street Address for Express Mail
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BBFORE THB IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edith Pacillo, Deputy Attorney General, request that Renewable Energy Coalition (REC) provide
the following documents and information as soon as possible, by WEDNESDAY,
AUGUST 1,2018.
This Production Request is continuing, and REC 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. REC 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 31.0I.01.228.
SECOND PRODUCTION REQUEST TO
RENEWABLE ENERGY COALITION JULY 11, 2018I
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 access of your members
to capital? If so, please provide specific examples.
REQUEST NO. 6: How many times have your members' facilities fallen outside the
performance band over the duration of their respective power purchase agreements? By how
much as a percentage of total months?
REQUEST NO. 7: What sort of expenditure in time and resources does it require of
each individual QF subject to the 90/110 performance band 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 the respective
power purchase agreements, your member QFs received because their power sales fell outside
the performance band in any given month? What percent is this of their annual gross revenue?
REQUEST NO. 9: How does your organization define "firm energy" in regards to QF
energy sales in Idaho? How does this definition differ from what your organization considers the
industry definition standard of "firm energy?"
REQUEST NO. 10: At the time the legally enforceable obligation is incurred, do your
member QFs know whether they will receive published avoided costs or Surplus Energy Price
for the electricity they sell to the utility?
SECOND PRODUCTION REQUEST TO
RENEWABLE ENERGY COALITION 2 JULY 11, 2018
Dated at Boise,Idaho, tfris I V O*of July 2018.
Pacillo
Deputy Attorney General
i:umisc:prodreq/ipcel 8.7epejep prod req2 Renewable Energy Coalition
SECOND PRODUCTION REQUEST TO
RENEWABLE ENERGY COALITION aJ JULY I I, 2OI8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS llth DAY OF JULY 2018, SERVED
THE FOREGOING SCOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO RENEWABLE ENERGY COALITION IN CASE NO. IPC-E-18-07, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
DONOVAN WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail: dwalker@idahopower.com
dockets@idahopower.com
DAVID H ARKOOSH
LAW OFFICE OF DAVID
ARKOOSH
PO BOX 2817
BOISE ID 8370I
E-mail: david@arkooshlaw.com
J KAHLE BECKER
ATTORNEY AT LAW
223 N 6TH STREET #325
BOISE TD 83702
E-mail : kahle@kahlebeckerlaw.com
TAMARACK ENERGY PARTNERSHIP
c/o MICHAEL C CREAMER
PRESTON N CARTER
60I W BANNOCK
BOISE TD 83702
E-mail : mcc@givenspursley.com
pnc@ givenspursley.com
CLINT KALICH, MANAGER
RESOURCE PLANNING & ANALYSIS
AVISTA CORPORATION
I4I I E MISSION AVE, MSC-7
SPOKANE W A 99202
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-mail : torn.arkoosh@arkoosh.com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARSON ADAMS PLLC
5I5 N 27TH STRE,ET
BOISE TD 83702
E-mail: peter@richardsonadarns.com
gre g@richardsonadams.com
IRION SANGER
SANGER LAW PC
I I I7 SE 53RD AVE
PORTLAND OR 97215
E-mail: irion@sanger-law.com
MICHAEL G ANDREA
SENIOR COLTNSEL
AVISTA CORPORATION
1411 E MISSION AVE, MSC-23
SPOKANE WA992O2
E-mail: michael.andrea@avistacorp.com
Y
E-mail: clint.kalich@a vistacorp.com
CERTIFICATE OF SERVICE