20200818Staff 2-6 to Fall River.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03t2
IDAHO BAR NO. 9917
Street Address for Express Mail:
1 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OT-A
BOISE, ID 8371,4
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIBS COMMISSION
IN THE MATTER OF THE APPLICATION FOR )
fTfiCEIV[D
:N?i:,1IiG IB PH 3: 56
.r: ft.1ar i^:i-UIJLitr," :-, 1-r i-i0liifuilS-qi0l'l
APPROVAL OF THE POWER PURCHASE
AGREEMENT BETWEEN PACIFICORP AND
FALL RIVER ELECTRIC COOPERATIVE, INC.
)
)
)
)
)
)
)
CASE NO. PAC-E.20.10
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO FALL RIVER ELECTRIC
cooPERATM,INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Fall River Electric Cooperative, Inc
provide the following documents and information as soon as possible, but no later than
TUESDAY, SEPTEMBER 1, 2020.r
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
t Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
SECOND PRODUCTION REQUEST
TO FALL RTVER ELECTRIC 1 AUGUST I8,2O2O
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO.2: There are two generators at Powerhouse #1 and two generators at
Powerhouse #2. Please respond to the following:
a. Please provide a diagram of the facility labeling the different powerhouses and
generators;
b. Please describe the configuration of the two powerhouses and generators in each
powerhouse and how the four generators will be operated under different
situations regarding water availability; and
c. Please provide an efficiency curve (water flow in cubic feet/second vs.
Megawatts) for each generator under variations of water availability using actual
generation data. What are the high and low operational limits of each generator in
terms of cubic feet per second and in terms of Megawatts?
REQUEST NO. 3: Historically, what is the maximum amount of generation that each
generator can produce. For each generator, please identify ayear when there was sufficient
water flow such that the generator was able to operate for periods of time at maximum capacity
For the year identified, please also provide the amount of kWhs in each hour over that year's
periods of time. (If hourly meter data are not available, please provide the data at the minimal
time interval available.)
REQUEST NO.4: If available, please provide the amount of hourly generation from
each of the two generators in Powerhouse #2 over the past five years. (If hourly meter data are
not available, please provide the data at the minimal time interval available.)
REQUEST NO.5: On what date in 2006 did Powerhouse #1 stop operating?
SECOND PRODUCTION REQUEST
TO FALL RIVER ELECTRIC 2 AUGUST I8,2O2O
REQIIEST NO.6: Will the repairs to Powerhouse #l change the nameplate capacity or
the efficiency of the powerhouse?
DATED at Boise,Idatro, this IE rL
day ofAugust 2020.
Dayn Hardie
Deputy Attorney General
i:umisc:prodre{pace20.lOdhyy ptod rcq 2 fall river
SECOND PRODUCTION REQUEST
TO FALL RTVER ELECTRIC 3 AUGUST I8,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18M DAY OF AUGUST 2020, SERVED
THE FOREGOTNG SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO FALL RTVER ELECTRIC COOPERATIVE, IN CASE NO. PAC-E-2O.IO,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOTINTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston @pacificorp.com
idahodockets @ paci ficorp.com
JACOB A McDERMOTT
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
ADAM LOWNEY
McDOWELL RACKNER GIBSON
419 SW 1lTH AVE SUITE 4OO
PORTLAND OR 91205
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequ est @ p ac i fic or?. c o m
GREGORY M ADAMS
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: grcg @richardsonadams.com
peter @ richardsonadams.com
SECRET Y
CERTIFICATE OF SERVICE