20180720Staff 11-12 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
IDAHYDRO, SHOROCK HYDRO, INC., J.R.
SIMPLOT COMPANY, AND RENEWABLE
ENERGY COALITION FOR MODIF'ICATION
OF THE 90/110 PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITES.
CASE NO. IPC.E.18-07
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHYDRO
REC T IVE D
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIBS 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 Idaho Hydroelectric Power Producers, an
Idaho Trust (Idahydro) provide the following documents and information as soon as possible, by
FRTDAY, AUGUST 10, 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.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
THIRD PRODUCTION REQUEST
TO IDAHYDRO I JULY 2O,2OI8
REQUEST NO. 11: In "Idahohydro, Shorock Hydro, Inc., J.R. Simplot Company and
Renewable Energy Coalition's Petition," the Petitioners state in Paragraph20 that "...actual
O&M costs for QF interconnected interests instructs that annual, percentage-based charges in
most, if not all, cases far exceed the actual O&M expenses for QF interconnection facilities, thus
indicating that the average O&M on IPCo system-wide transmission and distribution facilities is
either inapplicable or inaccurate as a reflection of the cost of O&M actually performed on QF
interconnection facilities." Please answer the following questions :
a. Please provide evidence that supports "the average O&M on IPCo system-wide
transmission and distribution facilities is either inapplicable or inaccurate as a
reflection of the cost of O&M actually performed on QF interconnection facilities".
b. Please define "actual O&M costs for QF interconnected interests."
c. Please provide a list and a detailed description of the types of O&M costs that
Idahhydro believes a QF should be responsible for paying.
REQUEST NO. 12: If Idaho Power offers the option of charging actual O&M costs for
interconnections used by QF projects, please explain how QFs would financially cope with
catastrophic events that may cause significant damage to interconnection facilities?
Dated at Boise, Idaho, thi, 201Q*ey of July 2018
Deputy Attorney General
i:umisc:prodreq/ipcel8.7epyy prod req3 ldahydro
THIRD PRODUCTION REQUEST
TO IDAHYDRO 2 JULY 2O,2OI8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF JULY 2018,
SERVED THE FOREGOING THIRD 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 COLINSEL
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail : dwalker@,idahopower. com
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: kahle@,kahlebeckerlaw.com
TAMARACK ENERGY PARTNERSHIP
c/o MICHAEL C CREAMER
PRESTON N CARTER
601 W BANNOCK
BOISE TD 83702
E-mail: [e-mail]
pnc@si collt
CLINT KALICH, MANAGER
RESOURCE PLANNING & ANALYSIS
AVISTA CORPORATION
14I I E MISSION AVE, MSC-7
SPOKANE W A 99202
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
1117 SE 53RD AVE
PORTLAND OR 97215
E-mail: [e-mail]
MICHAEL G ANDREA
SENIOR COLTNSEL
AVISTA CORPORATION
I41I E MISSION AVE, MSC-23
SPOKANE W A 99202
E-mail: [e-mail]
J /,a**.*Try
CERTIFICATE OF SERVICE