20180720Staff 22-25 to IPC.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 MODIFICATION
OF THE 9Ol110 PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITES.
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CASE NO. IPC.E-18.07
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER 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 Idaho Power Company (Idaho Power or
Company) provide the following documents and information as soon as possible, by FRIDAY,
AUGUST 10,2018.
This Production Request is continuing, and Idaho Power 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. Idaho Power 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
31.01.0r.228.
THIRD PRODUCTION REQUEST
TO IDAHO POWER I JULY 2O,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. 22: Please provide updated Schedule 72 Operation and Maintenance
(O&M) flat percentage rates for both distribution-level and transmission-level interconnections
using actual 2015 and2016 data, respectively. Please provide workpapers reflecting the
calculations with formula intact.
REQUEST NO. 23: In "Idaho Power Company's Answer and Responses to
Idahohydro and Shorock Hydro, Inc.'s First Set of Interrogatories, Requests for Admission, and
Requests for Production of Documents, Idaho Power states in "Answer to Interrogatory No. 9"
that "charging actual O&M costs for QF projects would mean that an entirely separate system of
work order preparation and billing would have to be established just for QF projects. Idaho
Power believes that such a requirement is both unreasonable and unnecessary". Please answer
the following questions:
a. For purposes of this request, please define "actual O&M costs."
b. Please list the categories of costs that go into the O&M rates and provide a
description of the types and nature of these costs.
c. For each O&M cost category, please describe how the Company could track them
as actual costs and describe the changes in the Company's business processes that
the Company would need to make.
d. For each O&M cost category, please describe and roughly quantiff investments
needed in systems, infrastructure, labor, etc. that the Company would need to make
to track them as actual costs.
REQUEST NO.24: In "Idahydro, Shorock Hydro, Inc., J.R. Simplot Company and
Renewable Energy Coalition's Petition," the Petitioners stated on Page 8 that "In fact, IPCo and
other Idaho utilities assess actual O&M costs to interconnection customers under
interconnections subject to the Federal Power Act..." Please answer the following questions:
a. Does Idaho Power agree with the statement? Please explain why or why not.
b. If Idaho Power agrees with the Petitioner's statement, please list the categories of
costs that make up actual O&M costs and describe the overall methodology for
assessing actual O&M costs to interconnection customers subject to the Federal
Power Act?
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 20,2OI8
REQUEST NO.25: In "Idaho Power's Answer and Responses to J.R. Simplot's First
Interrogatories, Requests for Admission, and Requests for Production to Idaho Power
Company," Idaho Power stated in its'oAnswer to Interrogatory No. 9" that for both large
generators and small generators "The Interconnection Customer shall be responsible for its share
of all reasonable expenses, including overheads associated with (1) owning, operating,
maintaining, repairing, and replacing its own Interconnection Facilities; and (2) operating,
maintaining, repairing, and replacing the Transmission Provider's Interconnection Facilities."
Please answer the following questions:
a. How does Idaho Power charge overheads associated with operating, maintaining,
repairing, and replacing the Transmission Provider's Interconnection Facilities
(item2 above). Please provide specific examples to support your answer.
b. What is the justification for assessing O&M interconnection costs for QF facilities
differently than interconnection customers subject to the Federal Power Act?
Dated at Boise, Idaho, this
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THIRD PRODUCTION REQUEST
TO IDAHO POWER
of July 2018
Pacillo
Deputy Attorney General
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J 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 IDAHO POWER COMPANY IN CASE NO. IPC-E.I8-07, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN WALKER
LEAD COLINSEL
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 83701
E-mail: [e-mail]
J KAHLE BECKER
ATTORNEY AT LAW
223N 6TH STREET #325
BOISE TD 83702
E-mail : kahle(Ekahlebeckerlaw.com
TAMARACK ENERGY PARTNERSHIP
c/o MICHAEL C CREAMER
PRESTON N CARTER
60I W BANNOCK
BOISE TD 83702
E-mail: mcc@si com
[e-mail]
CLINT KALICH, MANAGER
RESOURCE PLANNING & ANALYSIS
AVISTA CORPORATION
I4I 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 : tom.arkoosh@,arkoosh.com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail : peter@,richardsonadams.com
gre g@richardsonadam s. com
IRION SANGER
SANGER LAW PC
I I I7 SE 53RD AVE
PORTLAND OR 97215
E-mail: [e-mail]
MICHAEL G ANDREA
SENIOR COLTNSEL
AVISTA CORPORATION
14I I E MISSION AVE, MSC-23
SPOKANE WA99202
E-mail: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE
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