20150116ICIP 1-23 to IPC.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
Attorneys for the Industrial Customers of Idaho Power
IN THE MATTER OF THE
APPLICATION OF PACIFICORP DBA
ROCKY MOUNTAIN POWER AND
IDAHO POWER COMPANY FOR AN
ORDER AUTHORIZING THE
EXCHANGE OF CERTAIN
TRANSMISSION ASSETS
JfPi l5 Ahlll: l0
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
) CASE NOS. TPC-E-14-41
) PAC-E-14-11
)
)) FIRST PRODUCTION REQUEST OF
) THE INDUSTIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "IPUC" or "Commission"), the Industrial Customers of Idaho Power ("ICIP") by and
through their attorneys of record, Gregory M. Adams and Peter J. Richardson, hereby requests
that Idaho Power Company ("Idaho Power" or the "Company") provide the following
documents.
This production request is to be considered as continuing, and the Company 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 produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
IPC-E-14-41, PAC-E-14- 1 1
ICP'S FIRST SET OF PRODUCTION REQUESTS TO IDAHO POWER
PAGE I
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone]l l; [e-mail].
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer at an
evidentiary hearing.
If some of the following requests include disclosures reasonably deemed by Idaho Power
to be confidential, the ICIP will enter into Idaho Power's standard confidentiality agreement.
REQUEST FOR PRODUCTION NO. 1:
Please provide copies of all material provided to the Commission Staffregarding the Company's
application that were provided other than through formal discovery, both prior to, and after, the
filing of the Application.
REOUEST FOR PRODUCTION NO. 2:
Reference direct testimony of Lisa Grow at pp. 4-6. Please provide the Legacy Agreements
discussed and all amendments thereto.
REOUEST FOR PRODUCTION NO.3:
Please provide all work papers and supporting documents used or referred to in preparation of
the Company's Application.
REOUEST FOR PRODUCTION NO. 4:
Please provide copies of all materials provided to any party in Federal Energy Regulatory
Commission DocketNos. ERl5-680; ERl5-683; ER15-681; ERl5-682 and EC15-54 (including
informal discovery or materials provided to FERC Staff or any other parties).
REOUEST FOR PRODUCTION NO.5:
Please explain, and document, the impact of the asset exchange on existing generator
interconnection agreements and arrangements.
REOUEST FOR PRODUCTION NO. 6:
What is the impact of the asset exchange on the need, or lack of need, for the Hemmingway to
Boardman Transmission project? Please explain whether the transaction, if approved, will delay
IPC-E-14-41, PAC-E-14-l I
ICP'S FTRST SET OF PRODUCTION REQUESTS TO IDAHO POWER
PAGE 2
the need for or size of the Hemmingway to Boardman Transmission project.
REOUEST FOR PRODUCTION NO. 7:
Exhibit No. 1 attached to the direct testimony of Idaho Power witness Lisa Grow displays the
Idaho Jurisdictional Present Value Revenue Requirement Impact for the years 2015 -2024, please
provide:
a) A functioning electronic copy of Exhibit No. I with formulas intact;b) The work papers used to derive the values in Exhibit No. l;c) The assumptions used in the 10 year projections for the values in Exhibit No. l;d) For the purposes of Exhibit No. 1, does Idaho Power assume it will not file a general rate
case that would impact the values such as the authorizedrate of retum, revenues, expenses, etc.
overthe l0 yearperiod?
REOUEST FOR PRODUCTION NO. 8:
Reference Exhibit 8,p.2, attached to the testimony of Richard Vail and providing elements of
PacifiCorp's projected annual retail revenue requirement for each year through 2025 under the
status quo and with the proposed transaction consummated.
a) Why is an identical chart not provided for tdaho Power?b) Please produce an identical chart for Idaho Power.c) Please provide all supporting work papers and documents for the chart provided in
response to subpart b.
REOUEST FOR PRODUCTION NO. 9:
Reference the direct testimony of David Angell at page 15, stating:
Throughout spring, conditions regularly exist where transfers from the Northwest
into ldaho Power's system, coupled with generation out of the Hells Canyon
complex, can substantially exceed ldaho Power's west side load. In these cases,
eastbound capacity is needed across Midpoint West path to source southern and
eastern load and reduce thermal coal generation in the east and serve load with
low-cost hydro power from the northwest. With the acquisition of Hemingway -
Midpoint eastbound capacity, this constraint will be alleviated.
Please provide any studies tdaho Power has undertaken that support the above statement and
indicate which thermal coal generation units would be expected to be ramped down and the
degree of reduced coal generation as well as projected revenue requirement impacts.
REOUEST FOR PRODUCTION NO. IO:
Reference the direct testimony of David Angell at page 15, stating:
IPC-E-14-41, PAC-E-14-1 I
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO TDAHO POWER
PAGE 3
Furthermore, the Hemingway - Midpoint eastbound capacity will be necessary to
completely and economically integrate the Boardman - Hemingway 500 kV
transmission project (*82H"). When completed, B2H will increase the amount of
power that ldaho Power can purchase from the northwest by 500 MW during
spring and summer months.
a) Please provide any studies Idaho Power has undertaken that support the above statement
and indicate the quantity of the purchases from the Northwest and the savings in power costs
expected.
b) When does ldaho Power expect the Boardman-Hemingway transmission line to be
operational?
REOUEST FOR PRODUCTION NO. II:
Reference the direct testimony of Lisa Grow at pp. 16-17, indicating that replacing the Legacy
Agreements with the JPSA and JOOA will change Idaho Power's OATT formula rate that will
be reflected in future annual updates.
a) Please provide the current OATT formula rate calculations along with the sources of the
inputs.
b) Please provide any calculations or studies Idaho Power has undertaken indicating what
the future OATT formula rates would be if the transfer of assets is approved.
REOUEST FOR PRODUCTION NO. 12:
Reference the direct testimony of Lisa Grow at p. I l, indicating the transaction may help
facilitate development of the Energy Imbalance Market.
a) Please provide all studies and analysis conducted by Idaho Power regarding the benefits
of Idaho Power joining the Energy lmbalance Market.
b) Does Idaho Power intend to ever join the Energy Imbalance Market? Please explain why
or why not.
REOUEST FOR PRODUCTION NO. 13:
Reference the direct testimony of Lisa Grow at p. 18, stating that by entering into the Legacy
Replacement, ldaho Power's Idaho-jurisdictional revenue requirement will be reduced by $55.9
million.
a) Does Idaho Power's Application seek to reduce its retail rates to pass this reduced
revenue need onto its Idaho retail customers? If not, please explain why not.
b) When and how would ldaho retail customers experience a reduction in rates
corresponding with the $55.9 million benefit of the transaction?
IPC-E-14-41, PAC-E-14-1 I
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO IDAHO POWER
PAGE 4
REOUEST FOR PRODUCTION NO. 14:
On what date did ldaho Power and PacifiCorp begin discussing the proposed transaction and on
what date were the terms finalized?
REOUEST FOR PRODUCTION NO. 15:
Please provide all internal reports or memoranda presenting the terms and/or benefits of the
transaction to (a) Idaho Power's board of directors and (b) Idaho Power's senior officers.
REOUEST FOR PRODUCTION NO. 16:
Reference the direct testimony of Richard Vail, at p. 10, stating that following the transaction
PacifiCorp will have an ownership interest and all three transmission lines in the Jim Bridger
area and thus be able to use its rights on all three lines to serve load. Will PacifiCorp pay Idaho
Power for the newly acquired transmission capacity rights through point-to-point or network
transmission rights? If no, why not?
REOUEST FOR PRODUCTION NO. 17:
Reference the direct testimony of Richard Vail, at p. I l, stating that PacifiCorp will acquire 5 l0
MW of OATT service and will have 1,090 MW of "ownership rights" to make transfers across
the thee Jim Bridger lines.
a) Please explain how "ownership rights" in 1,090 MW confers the right to transfer capacity
on a point-to-point or network service basis under the OATT and/or the applicable Legacy
Agreement(s).b) [s the proposal to grant PacifiCorp a perpetual right to transfer across these lines simply
by virtue of selling ownership in the lines? [f so, please explain how this is more advantageous
to Idaho Power than charging PacifiCorp or other eligible transmission customers for service
under the applicable Legacy Agreement(s) and/or the OATT.c) Why are the 510 MW needed to be purchased under the OATT, while 1,090 MW need
not be purchased under the OATT?d) Please provide the projected lost revenue for the next ten years from transmission rates
associated with the 1,090 MW under the proposed transaction, and explain how that lost revenue
is factored into the analysis provided in Exhibit No. I attached to the direct testimony of Lisa
Grow.
REOUEST FOR PRODUCTION NO. 18:
Please explain if it is the Applicants' understanding that a transfer of ownership of a transmission
line also necessarily results in a corresponding transfer of transmission capacity or rights in the
line corresponding to the share of ownership. Please provide the basis for the answer.
IPC-E-14-41, PAC-E-14-1 I
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO TDAHO POWER
PAGE 5
REOUEST FOR PRODUCTION NO. 19:
Reference the direct testimony of Richard Vail, p. 12, stating "under the new joint ownership
arrangements, costs for future upgrades would be shared in accordance with the JOOA,
potentially resulting in lower upgrade costs to PacifiCorp's customers."
a) Please provide a list of the lines referenced and for each line: (i) the upgrade cost
responsibility between Idaho Power and PacifiCorp prior to the proposed transaction, and (ii)
after the proposed transaction.
b) Please provide all plans or studies, including any cost estimates, regarding upgrades that
will be necessary in the next ten years on the lines referenced in this portion of Mr. Vail's
testimony.
c) Please explain where the increased cost to Idaho Power associated with any upgrades to
these and all other facilities acquired by Idaho Power are factored in the analysis of the revenue
requirement impacts set forth in Exhibit No. I attached to Lisa Grow's direct testimony.
REOUEST FOR PRODUCTION NO. 20:
Reference the direct testimony of Richard Vail, p. 13, at lines 14-17 , indicating the transaction
includes a provision that ldaho Power and PacifiCorp will share the costs of upgrading the l6l
kV Goshen to Jefferson line.
a) What is the estimated cost of this upgrade?
b) What was the allocation of cost responsibility prior to the proposed transaction?
c) Is ldaho Power seeking cost recovery for this upgrade with the Application?
REOUEST FOR PRODUCTION NO. 21:
Reference the direct testimony of Richard Vail, p. 14, lines 11-15, stating that the value of the
assets being exchanged is nearly equal and the ongoing expenses "will be similar to expenses
incurred today."
a) Provide all studies, analyses and reports estimating the ongoing expenses for the next ten
years.
b) Will Idaho Power's ongoing expenses by higher or lower than prior to the proposed
transaction?
c) If Idaho Power's ongoing expenses will increase, please explain how retail rates will not
increase.
REOUEST FOR PRODUCTION NO. 22:
Reference the direct testimony of David Angell, p. 9, lines 12-19, discussing reallocation of
responsibilities with regard to operation of the lines impacted by the proposed transaction.
IPC-E-14-41, PAC-E-14-l I
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO IDAHO POWER
PAGE 6
a) Under the Legacy Agreements, for each line involved in the proposed transaction, please
identifu the utility responsible for (i) physical operation and maintenance, (ii) interconnection
requests, (iii) design of the line, (iv) capital upgrades and improvements on the line, (v) repair
and reconstruction, (vi) security, (vii) outage restoration, (viii) and retirement and
decommissioning.b) If the proposed transaction is approved, for each line involved in the proposed
transaction, please identiff the utility responsible for (i) physical operation and maintenance, (ii)
interconnection requests, (iii) design of the line, (iv) capital upgrades and improvements on the
line, (v) repair and reconstruction, (vi) security, (vii) outage restoration, (viii) and retirement and
decommissioning.c) Please explain how this reallocation of responsibilities will impact Idaho Power's
revenue requirement and provide all supporting analyses and studies.
REOUEST FOR PRODUCTION NO. 23:
Idaho Power's October 24,2014 SEC Form 8-K states that the JOOA "terminates in the event
the transmission facilities are destroyed and the parties determine not to repair or rebuild the
facilities or if the transmission facilities are retired and decommissioned (as to those specific
facilities only), by mutual agreement of the parties, or upon the occurrence of certain uncured
events of default described in the Joint Operating Agreement."
a) Please list the "certain uncured events of default described in the Joint Operating
Agreement." Does the JOOA allow for termination based on these uncured events at some point
after receiving regulatory approvals of the agreement and consummation of the asset exchange?
b) If the answer to subpart a) is o'yes," how far into the future could such a termination
occur?
c) Please provide any analysis or studies on the potential effect on rates in the event of such
a termination of the JOOA after consummation of the asset exchange.
DATED this 16fr day of January,2}l5.
RICHARDSON ADAMS PLLC
Of Attorneys for the Industrial
Customers of Idaho Power
IPC-E-14-41, PAC-E-14-l I
ICP'S FIRST SET OF PRODUCTION REQUESTS TO IDAHO POWER
PAGE 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16ft day of January,2}l1,atrue and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST OX'THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER was served:
By hand delivery and electronic mail to the following individuals:
Julia A. Hilton
Idaho Power Company
P.O. Box 70
Boise,ID 83707
j [e-mail]
Daphne Huang
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington
Boise,Idaho 83702
daphne.huang@puc. idaho. gov
Don Howell
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington
Boise, Idaho 83702
don.howell@puc. idaho. gov
By U.S. Mail and electronic mail to the following individuals:
Daniel Solander
Ted Weston
Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake city, UT 84111
daniel. solander@pacifi corp. com
ted. weston@pacificorp. com
IPC-E-14-41, PAC-E-14- 1 1
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO IDAHO POWER
PAGE 8