20180720Staff 11-12 to JR Simplot.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 T'OR MODIFICATION
OF THE 9OIILO PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTBNANCE CHARGES F'OR PURPA
QUALIFYING FACILITES.
CASE NO. IPC-E-18-07
THIRD PRODUCTION
RE,QUEST OF THE
COMMISSION STAFF TO
J.R. SIMPLOT COMPANY
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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 FRIDAY, AUGUST 10,2018.
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.
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 J,R. SIMPLOT COMPANY 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 Paragraph 20 that 'o...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 J.R.
Simplot Company 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, tnis )Op-day of July 2018
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Deputy Attorney General
i:umisc:prodreq/ipcel8.7epyy prod req3 J.R. Simplot
THIRD PRODUCTION REQUEST
TO J.R. SIMPLOT COMPANY 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 J.R. SIMPLOT COMPANY 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 : dwalker@idahopower. com
dockets@idahopower. com
DAVID H ARKOOSH
LAW OFFICE OF DAVID
ARKOOSH
PO BOX 2817
BOISE ID 8370I
E-mail: davrd@ar .com
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: mcc@,givenspursley.com
pnc@ sivenspursley. com
CLINT KALICH, MANAGER
RESOURCE PLANNING & ANALYSIS
AVISTA CORPORATION
141I 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: tom.arkoosh@,arkoosh.com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARSON ADAMS PLLC
515 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: irion@sanger-law,co4
MICHAEL G ANDREA
SENIOR COUNSEL
AVISTA CORPORATION
14I1 E MISSION AVE, MSC-23
SPOKANE WA992O2
E-mail: [e-mail]
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SECRETARY
CERTIFICATE OF SERVICE