200405121st Response of ID Power to Staff.pdf

,.- '" .
r ! I r.
..
G t. I 'if
:.. .
rY'l~J
BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Phone: [phone]
FAX: [phone]
FiLED
ZOUltT1A1 It Pitt ~: 58
.. .."" .. ....
(. c
\ C;
' _::,!,~! :?
\- \ t
; .
~T Ii IT!
' ~ \. "
" f'lf'i \5 S tONv tiLl! IL-V v
Attorneys for Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY
Complainant
CITY OF EAGLE , IDAHO
Respondent.
CASE NO. IPC-04-
IDAHO POWER COMPANY'
RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and , in response to the First Production Requests of the Commission Staff dated
April 27 , 2004, herewith submits the following information:
REQUEST NO.1: Please provide the number of Idaho Power customers
within the city limits of Eagle, Idaho, by customer class , for the year 2003.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF Page
RESPONSE TO REQUEST NO.1: As illustrated in the following table
Idaho Power served 6 616 customers within the city limits of Eagle , Idaho for the year
2003.
CUSTOMER
RATE SCHEDULE KWH USED AMOUNT COUNT
Schedule 1 Total 79,773,826 989,019.884
Schedule 7 Total 018,568 298,169.371
Schedule 9 Total 129 880 625 914.242
Schedule 15 Total 28,886 043.
Schedule 24 Total 270,447 119.
Schedule 40 Total 981 975 631.45 106
Schedule 41 Total 121 812 822.
Schedule 42 Total 184 804 703.
GRAND TOTAL 119,510 198 021,423.616
The Response to this Request was prepared by Dennis Trumble
Manager, Capital Region , Idaho Power Company, in consultation with Monica B. Moen
Attorney for Idaho Power Company.
REQUEST NO.2: Please provide the total energy consumed by Idaho
Power customers within the city limits of Eagle, Idaho, by customer class, for the year
2003.
RESPONSE TO REQUEST NO.2: Please refer to the table included in
the Response to Request No.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF Page 2
The Response to this Request was prepared by Dennis Trumble
Manager, Capital Region , Idaho Power Company, in consultation with Monica B. Moen
Attorney for Idaho Power Company.
REQUEST NO.3: Please provide the total revenue generated by Idaho
Power customers within the city limits of Eagle , Idaho, by customer class , for the year
2003.
RESPONSE TO REQUEST NO.3: Please refer to the table included in
the Response to Request No.
The Response to this Request was prepared by Dennis Trul"Dble
Manager, Capital Region , Idaho Power Company, in consultation with Monica B. Moen
Attorney for Idaho Power Company.
REQUEST NO.4: Please provide the estimated incremental capital cost
of Alternative Alignment No.1 (as described in the Company s Complaint at Exhibit
assuming a buried transmission line from Edgewood Street south, then to the west side
of the Highway 44 (Eagle Bypass)/Eagle Road intersection.
RESPONSE TO REQUEST NO.4: Applying the same approach and
methodology described in the Direct Testimony of David Sikes in this case (beginning
on page 20 , line 20 of said testimony), the costs may be estimated by assuming an
underground line length of 1.25 miles for a portion of Alternative Alignment No.1 as
described above.To approximate the distance-related costs of this underground
portion , the Company employed the methodology described in lines 1 - 4 of page 20 of
Sikes' Direct Testimony and arrived at an approximate cost of $5.57 million. That figure
is derived as follows:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF Page 3
(1.25 miles/1.6 miles)(.75 for the distance-related costs)($9.5 million) = $5.57 million
The fixed costs related to the required terminations associated with the
underground portions can be assumed to be similar to the $2.375 million, as noted on
page 19, lines 26-28 of the Direct Testimony of David Sikes. The total incremental
capital costs would be the sum of $5.57 million distance-related costs plus $2.375
million fixed costs less $0.5 million of the Alternative Alignment No.1 overhead costs
or $7.44 million.
As calculated in Sikes' Direct Testimony, a simple ratio of the entire $9.
million costs multiplied by 1.25 of the 1.6 miles would yield an estimated cost of $7.
million. This method would produce a total incremental capital cost of $7.42 million less
the $0.5 million of the overhead section as above , yielding an estimate of $6.92 million.
Without hiring an engineering firm to produce another study, while not
precise, these two methods produce a reasonable estimate between $6.92 million and
$7.44 million for the incremental capital cost of Alternative Alignment No.(as
described in the Company s Complaint at Exhibit 3) assuming a buried transmission line
from Edgewood Street south, then to the west side of the Highway 44 (Eagle
Bypass)/Eagle Road intersections.
The Response to this Request was prepared by "Kip" David L. Sikes, P.
Distribution Planning Team Leader, Idaho Power Company, in consultation with Monica
B. Moen , Attorney for Idaho Power Company.
REQUEST NO.Please provide the estimated incremental , Idaho
Power Company annual revenue requirement for the buried Alternative No.1 described
in Request No.4 above. Use Amortization periods of 5 , 10 and 20 years.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF Page 4
RESPONSE TO REQUEST NO.The estimated range for the
incremental cost of $6.92 million to $7.44 million provided in the answer to Request No.
represents the amount of investment that the Company believes would be
inappropriately included in its rate base and corresponding revenue requirement. For
purposes of this Response , the midpoint of the range , $7.18 million, was used. If $7.
million is the appropriate incremental cost, $7.18 million should be collected from the
City of Eagle as a contribution in aid of construction (CIAC).
Based upon prior conversations with the Staff and the City of Eagle , the
Company believes that Staff is using the term "annual revenue requirement" when it
actually means annual cost of having Idaho Power finance a CIAC for the City of Eagle.
If the Company were to finance a $7.17 million CIAC for the City of Eagle the annual
payments from the City of Eagle would be as follows:
Number of Years Interest Loan Annual
.Ejnancect .Bate Amount
199 $7. 18 M 855 465
199 $7.18 M 128 607
199 $7. IBM 797 729
As stated in Mr. Said's Direct Testimony, the Company believes it would
be inappropriate to fund a CIAC for longer than 5 years.
A methodology for isolating "revenue requirement" for separate recovery
from an individual customer has been formalized within the facilities charge
computations utilized for certain Schedule 19 customers.In that methodology,
Schedule 19 customers pay 1.7 percent per month times the amount of investment that
would otherwise be rate based. There is no fixed amortization period.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF Page 5
The Response to this Request was prepared by Gregory W. Said , Director
of Revenue Requirement, Idaho Power Company, in consultation with Monica B. Moen
Attorney for Idaho Power Company.
REQUEST NO.Please provide the estimated incremental , Idaho
Power Company annual revenue requirement to construct Alternative No.4 rather than
Alternative No.(as described in the Company s Complaint at Exhibit 3) using
amortization periods of 5, 10 and 20 years.
RESPONSE TO REQUEST NO.6: Please see the Response to Request
No.5. If the Company were to finance a $1 946 000 CIAC (the incremental difference
between Alternative 4 and Alternative 2) for the City of Eagle the annual payments from
the City of Eagle would be as follows:
Number of Years Interest Loan Annual
.Ejnancect .Bate Amount
199 946 000 $502 888
199 946 000 $305 887
199 946 000 $216 209
As stated in testimony, the Company believes it would be inappropriate to
fund a CIAC for longer than 5 years.
This Response to this request was prepared by Gregory W. Said , Director
of Revenue Requirement, Idaho Power Company, in consultation with Monica B. Moen
Attorney for Idaho Power Company.
REQUEST NO.7: Idaho Power indicated on April 19 that Alternative Nos.
, 3 and 4 as described in the Company s Complaint at Exhibit 3 are still possible but at
higher cost. Please provide the updated cost estimate and describe the reasons for the
price escalation(s).
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF Page 6
RESPONSE TO REQUEST NO.7: Please refer to page 15 , lines 4-, of
the Direct Testimony of David Sikes filed in this case. Alternative No.2 would likely
have no additional costs above the original estimate if work can begin and proceed in a
timely manner. The costs to compress the construction schedules of Alternative Nos. 3
and 4 have not been developed at this time and would be dependant upon the certainty
of an allowed start date to meet the required in-service period.
The Response to this Request was prepared by "Kip" David L. Sikes , P.
Distribution Planning Team Leader, Idaho Power Company, in consultation with Monica
B. Moen, Attorney for Idaho Power Company.
REQUEST NO.8: Idaho Power indicated on April 19 that Alternative Nos.
5 and 6 as described in the Company s Complaint at Exhibit 3 are not viable
transmission upgrade options. Please explain why these options are not viable.
RESPONSE TO REQUEST NO.8: Please refer to the Direct Testimony
of David Sikes filed in this case on pages 14 and 15 , beginning at line 3 of page 14. As
noted therein , significant amount of time would likely be required to acquire the rights-
of-way needed for these two alternatives. Sufficient time does not exist to pursue those
options at this time given the required in-service date.
The Response to this Request was prepared by "Kip" David L. Sikes , P.
Distribution Planning Team Leader, Idaho Power Company, in consultation with Monica
B. Moen , Attorney for Idaho Power Company.
REQUEST NO.9: Please indicate the height of the poles or structures
and the necessary amount of vertical clearance for the 138-kV transmission line for the
aerial portion of Alternative No.1 in Exhibit 3.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF Page 7
RESPONSE TO REQUEST NO.9: The poles for the bypass section of
the project will be designed for one 138-kV circuit and one 12.kV circuit. Pole height
will be controlled by the clearance required from the ground to the 12.kV distribution
circuit. The minimum vertical clearance from the distribution circuit to the ground will be
22 feet at maximum sag condition of 2120 Fahrenheit at final sag. The minimum
vertical clearance from the distribution circuit to streetlights (at Eagle Road , for
example) is 6.feet. Both of these clearances are slightly greater than the NESC
minimum.
Assuming the height of streetlights at traffic signals to be at 40 feet above
grade, the minimum height of poles needed to achieve a crossing at said streetlight
would be 88 feet above grade.
Where there are no streetlights to cross , the poles could be a minimum of
60 feet above grade.
The Response to this Request was prepared by Marc Patterson , Project
Leader, Idaho Power Company, in consultation with Monica B. Moen , Attorney for Idaho
Power Company.
REQUEST NO. 10: Please specify what table or section of the 2002
National Electric Safety Code the Company uses to calculate the necessary vertical
clearance for the 138-kV transmission line if it were to be aligned as proposed in
Alternative No.1 in Exhibit 3.
RESPONSE TO REQUEST NO. 10: Section 232 of the NESC governs
vertical clearance of wires, conductors, cables , and equipment above ground, roadway,
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF Page 8
rail , or water surfaces. Idaho Power standard clearances include an elevation adder
and a maximum over-voltage adder.
The Response to this Request was prepared by Marc Patterson, Project
Leader, Idaho Power Company, in consultation with Monica B. Moen, Attorney for Idaho
Power Company.
DATED at Boise, Idaho, this 11th day of May, 2004.
(j).
MONICA B. MOEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION
REQUEST OF COMMISSION STAFF Page 9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11th day of May, 2004, I served true and
correct copies of the above and foregoing IDAHO POWER COMPANY'S RESPONSE
TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF to the following parties:
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
Susan Buxton
Moore Smith
225 N. 9th Street, Suite 420
Boise, Idaho 83702
Hand Delivered
S. Mail
Overnight Mail
FAX
City of Eagle
O. Box 1520
Eagle , Idaho 83616
Hand Delivered
S. Mail
Overnight Mail
FAX
(fj~
MONICA B. MOEN
CERTIFICATE OF SERVICE