20200901Fall River to Staff 2-5.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]
gre g@richardsonadams. com
p eter@richardsonadams. com
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Attorneys for Fall River Rural Electric Cooperative, Inc.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
FOR APPROVAL OF THE POWER
PURCHASE AGREEMENT BETWEEN
PACIFICORP AND FALL RIVER RURAL
ELECTRIC COOPERATIVE, INC.
)
CASENO. PAC-E-20-10
FALL RTVER RURAL ELECTRIC
COOPERATIVE, INC.'S RESPONSE
TO STAFF'S SECOND SET OF
PRODUCTION REQUESTS
Fall River Rural Electric Cooperative, Inc. ("Fall River") hereby provides its Response to
the Idaho Public Utilities Commission Staff s Second Set of Production Requests, as follows:
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-2o-10
PAGE I
Staffs Production Request No. 2:
There are two generators at Powerhouse #l and two generators at Powerhouse #2.
Please respond to the following:
a. Please provide a diagram of the facility labeling the different Powerhousesand
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?
Fall River Rural Electric Cooperative Inc.'s Response to Request No. 2:
a. See the diagram provided in Attachment to Staff s Production Request No. 2(a).
b. Fall River Rural Electric Cooperative, Inc. (or "Fall River") objects to this request
because it is vague and calls for speculation as to how the qualiffing facility's four generation
units might be operated in all circumstances, which is not possible to predict or forecast.
Without waiving that objection, Fall River responds as follows:
Generally speaking, Fall River would operate the four generation units to maximize
generation potential from available water flows, subject to necessary maintenance and forced
outages of the four individual generation units and further subject to any applicable limitations
imposed by the Federal Energy Regulatory Commission hydropower license. The general
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-20-10
PAGE 2
operating plan for the qualiffing facility under normal conditions is currently as follows: With
water flows from 100 to 250cfs, Fall River will generally operate Powerhouse #2, turbinl
generator #1. With flows from 251to 500 cfs, Fall River will generally operate Powerhouse #2
turbine generators #1 and #2. With flows from 501 to 720 cfs, Fall River will generally operate
Powerhouse #2 turbine generators #l and #2, and Powerhouse #l turbine generator #1. With
flows from 721 to 940 cfs, Fall River will generally operate Powerhouse #2 turbine generators #1
and#2 and Powerhouse #l turbine generators #l and#2.
c. Fall River objects to this request because it requests information Fall River does not
possess. Fall River does not possess the requested efficiency curves. Additionally, Fall
River does not possess hourly waterflow data depicting water available at the plant; the only
waterflow gauges are far removed from the Powerhouses and do not reliably indicate the
water available for the purposes of generation of electric energy at the Powerhouses on an
hourly basis or otherwise. Similarly, Fall River does not possess hourly generation data for
individual units or for the aggregated output of the entire qualiffing facility. Each
individual unit has a generation meter, but these meters must be manually read and are not
automatically recorded on an hourly basis. In recent years, after Fall River took over
operation of the qualiffing facility in20l7, Fall River's operator has read and recorded the
generation on a daily basis per generation unit. Prior to that time, however, Fall River only
possesses data on a monthly basis for most years, and in many years not for each individual
generator or even individual Powerhouses. For the years 1998, 7999,2000, and2OO2,Fall
River possesses no generation data. On the whole, this generation data is not sufficient to
reliably develop the type of analysis Staff requests here even if waterflow data were
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-20-10
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available.
This response was prepared by Bryan Case, CEO/General Manager of Fall River Rural
Electric Cooperative, Inc., David Peterson, Engineering Manager of Fall River Rural Electric
Cooperative, Inc., and Gregory M. Adams, attorney for Fall River Rural Electric Cooperative,
Inc. The factual content of the response is sponsored by Bryan Case and David Peterson.
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-2O-10
PAGE 4
Staffs Production Request No.3:
Historically, what is the maximum amount of generation that each generator can
produce. For each generator, please identiff 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.)
Fall River Rural Electric Cooperative Inc.'s Response to Request No. 3:
Fall River objects to this request because it requests information Fall River does not
possess. Please see Fall River's response to Request No. 2(c) for more information on the lack
of detailed data relevant to this production request. Without historical hourly waterflow and
generation data for each of the four generation units, it is not possible to answer this request
with empirical evidence.
Without waiving the above objections, Fall River responds as follows:
Fall River is supplying in affached excel spread sheets the available data in its
possession as Attachments Nos. 7 , 2, 3 , 4, and 5 to Response to Request No. 3. The data for
years prior to 2017 was recorded by the prior operator of the plant and supplied to Fall
River, and the data for years since 2017 was recorded by Fall River.
In response to the specific questions, Powerhous e #2 has its nameplate capacity of
5,500 kW, and based on available data it appears that Powerhouse #2 has likely operated at
or near its nameplate capacity on an hourly basis at certain points since 1986. For example,
on July 5,2020, Fall River's data shows that Powerhouse #2 generated gross production of
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-20-r0
PAGE 5
127,000 kwh, which would equate to average hourly generation over that 24-hour period of
5,292 kwh. It is reasonable to assume that generation in one or more of the hours exceeded
that amount and was thus closer to the full nameplate capacity of the plant. Similarly, over
the month of August 2011, the data demonstrate gross generation at Powerhouse #2 of
3,753,000 kWh, which equates to a monthly average hourly generation of 5,044 kWh. Again, it
is reasonable to assume that the plant would have generated at levels higher than that amount
during certain hours in the month.
With respect to Powerhouse #1, the available data and Fall River's experience with the
qualiffing facility suggest that it is unlikely there would be enough water available for
Powerhouse #l to also operate at capacity simultaneous to Powerhouse #2. As the data
reflects and the plans for operation provided in Fall River's Response to Request No. 2(a)
suggest, Powerhouse #l mainly seryes to increase the plant's overall capacity factor, and it
can supplement generation to a certain extent at high waterflows. However, as the data
demonstrate, the qualiffing facility has been capable of producing similar annual amounts of
generation even without Powerhouse #l being used since 2006. The average annual
generation for the qualiffing facility has in fact been higher from the beginning of calendar
year 2007 through the end of 2019 (28,446,568 kwh) than it was for years with data
available from the beginning of calendar year 1987 through the end of 2006 (26,952,514
kwh). This is displayed below:
Total Annual
Generation kWh
1986 25,506,890
1987 22,135,890
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-2O-10
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1988
1989
1990
t99l
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
24,103,440
29,494,700
21,657,900
27,479,400
20,674,000
31,114,412
23,300,866
31,16r,451
36,228,226
39,165,179
No Data
No Data
No Data
20,828,000
No Data
22,582,120
25,526,710
27,296,690
29,936,870
22,194,000
28,488,000
30,257,000
FALL RIVER RURAL ELECTRIC COOPERATIVE,INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-2o-10
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2010
2011
2012
20t3
2014
20ts
201,6
2017
2018
2019
25,606,000
28,299,000
28,682,000
25,684,000
32,316,000
26,576,000
25,327,000
37,061,395
29,903,000
29,412,000
Average 1986-2006
Average 2007-2019
26,952,514
28,446,569
This response was prepared by Bryan Case, CEO/General Manager of Fall River Rural
Electric Cooperative, Inc., David Peterson, Engineering Manager of Fall River Rural Electric
Cooperative, Inc., and Gregory M. Adams, attorney for Fall River Rural Electric Cooperative,
Inc. The factual content of the response is sponsored by Bryan Case and David Peterson.
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-20-r0
PAGE 8
StafPs Production 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. )
Fall River Rural Electric Cooperative Inc.'s Response to Request No. 4:
Fall River does not possess hourly generation data for any years. For the data within Fall
River's possession, see Fall River's Response to Staffls Production Request No. 3.
This response was prepared by Bryan Case, CEO/General Manager of Fall River Rural
Electric Cooperative, Inc., David Peterson, Engineering Manager of Fall River Rural Electric
Cooperative, Inc., and Gregory M. Adams, attomey for Fall River Rural Electric Cooperative,
Inc. The factual content of the response is sponsored by Bryan Case and David Peterson.
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-2o-10
PAGE 9
StafPs Production Request No. 5:
On what date in 2006 did Powerhouse #1 stop operating?
Fall River Rural Electric Cooperative Inc.'s Response to Request No. 5:
Fall River does not possess any records demonstrating the last day in 2006 that
Powerhouse #l operated. As the data supplied in Fall River's Response to Staf?s Production
Request No. 3 demonstrates, July 2006 was the last month for which production data was
recorded by the prior operator of the plant and supplied to Fall River.
This response was prepared by Bryan Case, CEO/General Manager of Fall River Rural
Electric Cooperative, Inc., David Peterson, Engineering Manager of Fall River Rural Electric
Cooperative, Inc., and Gregory M. Adams, attorney for Fall River Rural Electric Cooperative,
Inc. The factual content of the response is sponsored by Bryan Case and David Peterson.
DATED: September I, 2020.
RICHARDSON ADAMS, PLLC
By: lsl Gregory M. Adams
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27n Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Fall River Rural Electic
Cooperative, Inc.
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQI.'ESTS
PAC-E-20-10
PAGE 10
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1st day of September 2020,ldelivered true and correct
copies of the foregoing FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'
RESPONSE TO STAFF'S SECOND SET OF PRODUCTION REQUESTS to the following
parties via electronic mail:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
j an.noriyuki@puc. idaho. gov
Jacob A. McDermott
Senior Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
salt Lake city, uT 84116
Jacob. mcde rrnott@p acifi corp. com
Edward Jewell
Dayne Hardie
Deputy Attomey General
Idaho Fublic Utilities Commission
P.O. Box 83720
Boise,lD 83720-0074
edward j ewell@puc. idaho. gov
dayne.hardie@puc. idaho. gov
Adam Lowney (15B#10456)
McDowell Rackner Gibson PC
419 SW 1Ift 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@pacifi corp. com
IdahoDockets@pacifi corp. com
Dated: September l, 2020
ls/ Gregoqt M. Adams
Gregory M. Adams (ISB No. 7454)
FALL RIVER RURAL ELECTRIC COOPERATIVE, INC.'S RESPONSE TO STAFF'S
SECOND SET OF PRODUCTION REQUESTS
PAC-E-20-10
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