20200701Staff 1 to Fall River.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03r2
IDAHO BAR NO. 9917
RTfiEIVEB
-i$?0 JUL - I PH 2: 0l
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDC 8, SUITE 201.A
BOISE,ID 837I4
Attorneys for the Commission Staff
BEFORE THE IDAHO PIJBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION FOR
APPROVAL OF THE POWER PURCHASE
AGREEMENT BETWEEN PACIFICORP AND
FALL RMR ELECTRTC COOPERATM,INC.
CASE NO. PAC.E-20-IO
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO FALL RIVER ELECTRIC
cooPERATM,INC.
The Staffof the Idaho Public Utilities Commission, by and through its anorney of record,
Dayn Hardie, Deputy Attorney Ceneral, requests that Fall River Electric Cooperative, Inc
provide the tbllowing documents and information as soon as possible, but no later than
WEDNES DAY, JULY 22, 2020.
This Production Request is to be considered as continuing, and Fall River Electric
Cooperative, Inc is requested to provide, by way of supplementary responses, additional
documents that it, or any person acting on its behalf, may later obtain that will augment the
documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identi$ the name, job title, location, and
telephone number of the record holder,
FIRST PRODUCTION REQUEST
TO FALL RIVER ELECTRIC
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ruLY 1,2020
In addition to the written copies provided as response to the reguests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. lt Felt Hydro's FERC Form 556 (the self-recertification form) states
the following: (l) The project has a total installed capacity of 7,450 kW; (2) Powerhouse #l's
capacity is 1,950 kW; (3) Powerhouse #2's capacity is 5,500 kW; (a) Powerhouse #l is in
disrepair and has not operated since 2006 due to floor damage, but there are plans to retum it to
service; and (5) Powerhouse #2 was constructed in 1986 and is cumently operating.
Please provide the following:
a. Please confirm Powerhouse #l has not operated since 2006.
b. Please provide the date that Powerhouse #l will be returned to full operation.
c. Please confirm Powerhouse #2 has always been in operation since initially
constructed.
$rDATED at Boise,ldaho, this day ofJuly 2020.
Hardie
Deputy Attorney General
i umisc prodrcqrpacc2O l0dh;y prod rcq I folt rivcr
FIRST PRODUCTION REQUEST
TO FALL RIVER ELECTRIC 2 JULY I,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I'I DAY OF ruLY 2020, SERVED
THE FOREGOTNG FIRST PRODUCTTON REQUEST OF THE COMMISSION
STAFF TO FALL RMR ELECTRIC COOPERATIVE, IN CASE NO. PAC-E-20-10,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOT'NTATN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
idahodoc kets@oaci fi corp.com
ADAM LOWNEY
McDOWELL RACKNER GIBSON
4I9 SW I ITI-I AVE SUITE 4OO
PORTLAND OR 97205
E-MAIL: adam(@mrq:law.com
GREGORY M ADAMS
PETER J RICHARDSON
zuCHARDSON ADAMS PLLC
5I5 N 27T}I STREET
BOISE ID 83702
E-MAIL: [e-mail]
oeterdrichardsonadams.com
JACOB A McDERMOTT
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: Jacob.mcdermott(Dpacificom.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@pac i fi corp.com
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CERTIFICATE OF SERVICE