20200721Fall River to Staff 1.pdf

Gregory M. Adams (ISB No. 7454)
Peter J. Richardson (ISB No. 3195)
Richardson Adams, PLLC
515 N. 27ft Street
Boise,Idaho 83702
Telephone: [phone]
Fax [phone]
greg@richardsonadams. com
peter@richardsonadams. com
RECEIV&O
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Attomeys for Fall River Rural Electric Cooperative, [nc.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
FOR APPROVAL OF TTTE POWER
PURCHASE AGREEMENT BETWEEN
PACIFICORP AND FALL RTVER RURAL
ELECTRIC COOPERATIVE, INC.
CASE NO. PAC-E-2O-IO
FALL RTVER RURAL ELECTRIC
COOPERATIVE, INC.' RESPONSE
TO STAFF'S FIRST SET OF
PRODUCTION REQUESTS
Fall River Rural Electric Cooperative, Inc. ("Fall River") hereby provides its Response to
the Idaho Public Utilities Commission Staff s First Set of Production Requests, as follows:
FALL RIVER RURAL ELECTRIC COOPERATIVE, [NC.' RESPONSE TO STAFF'S FIRST
SET OF PRODUCTION REQUESTS
PAC-E-2o-10
PAGE I
Staffs Production Request No. 1:
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 #1's capacity is 1,950 kW; (3)
Powerhouse#Z'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 return it to service; and (5) Powerhouse #2
was constructed in 1986 and is currently operating.
Please provide the following:
a. Please confirm Powerhouse #1has not operated since 2006.
b. Please provide the date that Powerhouse #l will be returned to full operation.
c. Please confirm Powerhouse#2has always been in operation since initially
constructed.
Fall River Rural Electric Cooperative Inc.'s Response to Request No. 1:
a. Confirmed.
b. Work to return Powerhouse #l to service is ongoing at this time, and Fall River
Rural Electric Cooperative, Inc. expects that Powerhouse #1 will be retumed to service on or
before the month of January 2021. Thus, it is expected that Powerhouse #l will be returned to
service before the expiration of the existing power purchase agreement on April 1,2021, and,
before corrmencement of sales from the Felt Project under the renewal power purchase
agreement submitted for approval in this proceeding.
c. Confirmed. Both Powerhouse #l and Powerhouse #2 were operational and
performing from commencement of sales in the existing power purchase agreement in 1986 until
the point in time in 2006 when flooding damaged Powerhouse #1, precluding safe operation of
Powerhouse #1. From that point in 2006 until the present time, Powerhouse #Zhas remained in
FALL RIVER RURAL ELECTRIC COOPERATIVE, [NC.' RESPONSE TO STAFF'S FIRST
SET OF PRODUCTION REQUESTS
PAC-E-2O-10
PAGE 2
regular operatiorl subject to available water flows to power the generators and nonnally
expected maintenance outages.
This response was prepared by Bryan Case, CEO/General Manager of Fall River Rural
Electric Cooperative, Inc., and Gregory M. Adams, attorney for Fall River Rural Electric
Cooperative, Inc. The factual content ofthe response is sponsored by Bryan Case.
DATED: Jru/ry 21,2020.
RICHARDSON ADAMS, PLLC
By /sl Gresoq/ M. Adams
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N.276 Sneet
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Fall River Rural Electric
Cooperative, Inc.
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.' RESPONSE TO STAFF'S FIRST
SET OF PRODUCTION REQUESTS
PAC-E-2o-10
PAGE 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 21st day of July 2020,I delivered true and correct copies
of the foregoing FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.' RESPONSE
TO STAFF'S FIRST SET OF PRODUCTION REQUESTS to the following parties via
electonic mail:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, D 83720-0074
diane.hanian@puc. idaho. gov
Edward Jewell
Dayne Hardie
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
edward j ewell@puc. idaho. gov
dayne. hardie@puc. idaho. gov
Jacob A. McDermoff
Senior Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
Jacob. mcdermo tt@p acifrc orp. com
Adam Lowney (158#10456)
McDowell Rackner Gibson PC
419 SW 1lft Avenue, Suite 400
Portland, OR 97205
[e-mail]
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake ciry, uT 84116
ted.weston@pacificorp. com
IdahoDockets@pacifi corp. com
Dated: July 21,2020
lsl Greeoq) M. Adams
Gregory M. Adams (ISB No. 7454)
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.' RESPONSE TO STAFF'S FIRST
SET OF PRODUCTION REQUESTS
PAC-E-20-r0
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