20110803Staff 142-151 to Idaho Power.pdf

DONALD L. HOWELL, II
KARL T. KLEIN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 12
IDAHO BAR NOS. 3366/5156
RECEIVED
LOll AUG -3 AM 10: 43
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE IN IDAHO. )
)
)
)
CASE NO. IPC-E-11-8
SEVENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorneys of
record, Donald L. Howell, II and Karl T. Klein, Deputy Attorneys General, requests that Idaho
Power Company (Company; IPC) provide the following documents and information as soon as
possible, but no later than WEDNESDAY, AUGUST 24, 2011.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil 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 identify the name, job title, location and telephone
number of the record holder.
SEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 AUGUST 3, 2011
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic fies on CD with formulas activated.
Request No. 142: Does the Company establish a benchmark for the following reliabilty
measures?
1. System Average Interrption Duration Index (SAID I),
2. System Average Interrption Frequency Index (SAIFI), and
3. Momentary Average Interrption Frequency Index (MAIFI).
If so: (a) What is the objective of the established standard?
(b) What is the benchmark for each of the past seven years (2003 -2010)?
Please provide a comparison of the actual measure to the established
benchmark set internally by the Company.
(c) How frequently is the benchmark revised?
(d) Please provide an analysis of the specific events that contributed to any major
deviation from the established benchmark.
(e) Please provide a summar of how the reliabilty performance benchmarks are
established by the Company.
Request No. 143: Does the Company attempt to identify its worst-performing circuits?
If so, please identify the five worst-performing circuits for each of the past three years and
describe how the worst-performing circuits are identified. For each of the circuits identified,
please describe any work performed or projects completed to improve the circuit's pedormance.
Request No. 144: Please provide a list of measurements and reports generated by the
Outage Management System. Please provide examples of the reports.
Request No. 145: Please provide a list of all major new and rehabiltation transmission
projects completed within the past three years that were under taken for purposes of meeting
NERC Reliabilty Standards. For each project, please identify the NERC standard(s) that each
project was intended to satisfy, the cost of each project assigned to Idaho, and the date of
completion of each project.
SEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 3, 2011
Request No. 146: Please list and summarize the cause for any NERC/WECC penalties
or fines imposed, either through audit or self-reporting, during the past three-year period.
Request No. 147: Has the Company performed or completed a business case
analysis/benefit-cost study for the AMI project? If so, please provide a current status report.
Request No. 148: Please list dates, SAIDI, and primary cause for all Major Events as
defined by Reliability Standard IEEE 1366-2003 for the past three years.
Request No. 149: Does the Company categorize distribution level outages by
controllable and uncontrollable events? If so, please provide the definitions the Company
utilzes to identify these types of outages.
Request No. 150: For the prior three years, please list significant projects and their
associated costs for upgrades to distribution substations, including the installation of SCADA or
other distribution automation systems. Please identify if the projects were to increase capacity
meet reliabilty standards, or both.
Request No. 151: Please provide any cost!enefit analysis and/or other justification for
each transmission project provided in response to Request No. 145.
DATED at Boise, Idaho, this 3 r. day of August 201 1.
.1tj¿ £-
Karl T. Klein
Deputy Attorney General
Technical Staff: Doug Cox/142-151
i:umisc:prodreq/ipce1 1.8dhkk prod req 7
SEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 AUGUST 3, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF AUGUST 2011,
SERVED THE FOREGOING SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-11-08, BY
E-MAILING AND MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
DONOV AN E WALKER
JASON B WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrom(fidahopower.com
dwalker(fidahopower .com
jwillams(fidahopower .com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(frichardsonandolear.com
greg(frichardsonandolear.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204
E-MAIL: elo(fracinelaw.net
ARTHUR PERRY BRUDER
ATTORNEY -ADVISOR
US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: Arthur.brudertihg.doe.gov
GREGORY W SAID
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: gsaid(fidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(fmindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tonytiyankel.net
DWIGHT ETHERIDGE
EXETER ASSOCIATES
10480 LITTLE PATUZENT PKWY
STE 300
COLUMBIA MD 21044
E-MAIL: detheridgetiexeterassociates.com
CERTIFICATE OF SERVICE
E-MAIL ONLY:
STEVE A PORTER
US DEPT OF ENERGY
E-MAIL: steven.portertihg .doe. gov
KURT JBOEHM
BOEHM KURTZ & LOWERY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: kboehm(fbkllawfrm.com
E-MAIL ONLY:
RICHARD E MALMGREN
SR ASST GENERAL COUNSEL
MICRON TECHNOLOGY INC
E-MAIL: remalmgren(fmicron.com
E-MAIL ONLY:
THORV ALD A NELSON
MARK A DAVIDSON
FRED SCHMIDT
HOLLAND & HART LLP
E-MAIL: tnelson(fhollandhar.com
madavidson(fhollandhar.com
fschmidt(fhollandhart.com
lnbuchanan(fhollandhar.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710N 6TH ST
BOISE ID 83702
E-MAIL: botto(fidahoconservation.org
NANCY HIRSH
POLICY DIRECTOR
NW ENERGY COALITION
811 1 ST AVE., SUITE 305
SEATTLE WA 98104
E-MAIL: nancy(fnwenergy.org
E-MAIL ONLY:
JOHN R HAMMOND JR
BATT FISHER PUSCH
& ALDERMAN LLP
E-MAIL: jrh(fbattfisher.com
KEVIN HIGGINS
ENERGY STRATEGIES
215 S. STATE ST SUITE 200
SALT LAKE CITY UT 841 1 1
E-MAIL: khiggins(fenergystrat.com
ELECTRONIC/ CD/ PAPER SERVICE
MARY V YORK
HOLLAND & HART LLP
101 S. CAPITAL BLVD., SUITE 1400
BOISE, ID 83702
E-MAIL: myork(fhollandhar.com
BRAD MPURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmail.com
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: kmiler(fsnakeriveralliance.org
SECRETARY
CERTIFICATE OF SERVICE