20150204Staff 1-33 to IPC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER AND IDAHO POWER COMPANY FOR )
AN ORDER AUTHORIZING THE EXCHANGE )
oF CERTATN TRANSMTSSION ASSETS. )
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NOS. IPC.E-14.41
PAC-E-14-11
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Daphne Huang, Deputy Attorney General, requests that Idaho Power Inc. (Company, Idaho
Power) provide the following documents and information as soon as possible, but no later than
WEDNESDAY, FEBRUARY 25, 2015.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different, the witness who can sponsor the
answer at hearing if need be. IDAPA 31.01.01.062,31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power 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.
FIRST PRODUCTION REQUEST
TO IDAHO POWER FEBRUARY 4,2015
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.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: What are the average monthly operation and maintenance expenses
currently associated with the plant in service that is proposed to be transferred to PacifiCorp
from Idaho Power Company?
REQUEST NO. 2: What are the average monthly operation and maintenance expenses
estimated to be associated with the plant in service that is proposed to be transferred to Idaho
Power Company from PacifiCorp?
REQUEST NO.3: Will there be any financial gain or loss associated with the transfer
of assets? If so, please provide the specific details and associated assets.
REQUEST NO.4: Please provide the proposed journal entries associated with the
transfer of assets.
REQUEST NO. 5: Please quantify the financial benefits to Idaho Power customers for
the transparency, flexibility, and reliability accomplished by this asset transfer.
REQUEST NO.6: What future anticipated projects, including capital, maintenance, and
operational, will no longer be needed as a result of this transfer of assets? Please list each project
that will not be undertaken or revised as a result of this asset transfer.
REQUEST NO. 7: Please provide a schedule showing the plant in service by specific
plant account, original cost, current book value, current depreciation expense and accumulated
depreciation for the assets to be transferred to PacifiCorp.
FIRST PRODUCTION REQUEST
TO IDAHO POWER FEBRUARY 4,20T5
REQUEST NO. 8: The Joint Purchase and Sale Agreement (JPSA) requires Idaho
Power to be responsible for the 230 kV Upgrades necessary to provide PacifiCorp with 510 MW
of long-term firm point-to-point transmission service on Idaho Power's transmission system.
(Application, JPSA, p9.27, Section 2.9(b)(xiv).) Please specify the specific equipment
purchased or upgraded, and the location of these required investments along with an explanation
of whether there will be any impacts to path ratings, the flexibility of transmission transfers, or
transmission capacity.
REQUEST NO. 9: Lisa Grow's testimony says that the manual transmission scheduling
process will be replaced by a more efficient automatic process through the execution of the Joint
Ownership and Operations Agreement (JOOA). (Application, Grow DI, pg. 12, lines 12-14.)
Please provide a detailed description of the automatic scheduling process, including the
implementation timing and details regarding any capabilities for inter-hour dispatch or dynamic
transfers of energy. Further, please explain if the automated transmission scheduling
functionality will increase with future automation outside of Idaho Power's Balancing Authority
Area.
REQUEST NO. 10: Lisa Grow's testimony says that the Parties are to create a method
to determine and allocate losses for the use of the transmission system within the other Party's
Balancing Authority Area. (Application, DI Grow, pg. 13, lines 8-12.) Please provide a
description of the previous method, the new method, and the associated implementation time
line.
REQUEST NO. 11: Please provide copies of the Phase 1, and if available the Phase II,
Environmental Site Assessments for the properties proposed to be transferred to PacifiCorp
under the JPSA.
REQUEST NO. 12: Please provide a list of the FERC accounts used in the calculations
presented in Exhibit No. 1 of Lisa Grow's testimony.
FIRST PRODUCTION REQUEST
TO IDAHO POWER FEBRUARY 4,2015
REQUEST NO. 13: How will the asset exchange impact the cunent Power Cost
Adjustment (PCA) and/or Fixed Cost Adjustment (FCA) mechanisms?
REQUEST NO. 14: Please explain how the transmission expenses and revenues are
expected to change as a result of the asset exchange, by FERC account or other tracking method.
REQUEST NO. l5: Please clarify the facilities, the load locations, and potential
customers that may use the 100 MW of the Jim Bridger Transmission System eastbound rights.
(Application, Angels DI, pg. 11, lines 3-6.) Further, please clarify if these eastbound rights will
primarily add redundancy, or serve future land growth.
REQUEST NO. 16: Please provide supporting cost estimates associated with Dave
Angel's testimony regarding elimination of the need for the Brady - Antelope 230 kV line.
(Application, Angels DI, pg. 12, lines 13-17.)
REQUEST NO. 17: Please provide supporting documentation for the load forecasts and
the projected date of the future service requirements, plus the current transmission use by retail,
wholesale, and generation customers served in the Blackfoot area.
REQUEST NO. 18: Please provide supporting cost estimates associated with Dave
Angel's testimony regarding the benefits of ownership in the American Falls - Malad line.
(Application, Angels DI, pg. 13, lines 23-24.)
REQUEST NO. 19: Please provide supporting documentation for the load forecasts and
the projected date of the future service requirements, plus the current transmission use by retail,
wholesale, and generation customers served in the Arbon Valley area.
REQUEST NO. 20: Regarding the benefits related to the Midpoint - Hemingway
acquisition of 700 MW of eastbound capacity, please describe whether this acquisition through
the proposed asset exchange eliminates the need for additional transmission investments.
(Application, Angel DI, pg. l5,lines 22-23.)
FIRST PRODUCTION REQUEST
TO IDAHO POWER FEBRUARY 4,2015
REQUEST NO. 21: Please provide supporting data for current transmission use by
retail, wholesale, and generation customers served by Idaho Power via the westbound
reservations made on the Hemingway - Summer Lake line. Further, please provide supporting
documentation for the projected increased transmission use and date(s) of the future service
requirements for this same line and westbound direction. (Application, Angel DI, pg. 17, lines
2-18.)
REQUEST NO. 22: Please provide an explanation of how the Bonneville transmission
wheeling expense will be reduced or eliminated from Idaho Power's acquisition of the Walla
Walla - Hurricane transmission line. (Application, Angel DI, pg. 18, lines 24, 18-19.)
REQUEST NO.23: What are the estimated changes to the Idaho-Northwest path ratings
following the anticipated Walla Walla - Hurricane line upgrades? (Application, Angel DI, pg.
18, lines 12-14.)
REQUEST NO.24: Please explain whether Idaho Power is currently prepared to
implement an Energy Imbalance Market or Security Constrained Economic Dispatches, or
whether there are specific areas within Idaho Power's Balancing Authority Area where short
term balancing is not able to be implemented. Please also explain how the proposed acquisition
of assets may create new opportunities or improved functionality for load balancing within
shortened intervals (i.e., 5 minute). Please provide a general overview of additional investments
that may be required in the future in order to increase this type of dispatch functionality.
REQUEST NO. 25: Please explain whether the asset exchange will cause any increases
or decreases in retail customer rates.
REQUEST NO.26: The JPSA includes Planned Improvements (Application, JPSA) to
be completed by both Idaho Power (Schedule 1 1(e)) and PacifiCorp (Schedule 1.1(f)). Please
explain whether there will be any impacts to path ratings, the flexibility of transmission transfers,
or transmission capacity as a result of the listed improvements.
FIRST PRODUCTION REQUEST
TO IDAHO POWER FEBRUARY 4,2015
REQUEST NO. 27: Please provide the current OATT formula Excel spreadsheet and
calculations, and the anticipated revised OATT formula Excel spreadsheet as a result of the
elimination of the various legacy agreements.
REQUEST NO. 28: Please provide supporting data for current transmission use by
retail, wholesale, and generation customers served by Idaho Power's 161 kV transmission line
between Goshen and Jefferson.
REQUEST NO.29: Please provide a copy of the responses submitted to the Western
Electricity Coordination Council (WECC) for the 2AI4 Operational Practices Survey Report
along with an explanation of whether any of the practices are anticipated to be revised during
2015, including as a result of the proposed asset exchange.
REQUEST NO.30: Please explain how the Parties plan to coordinate compliance with
NERC- or State-required physical and cyber security program requirements given the proposed
asset exchange.
REQUEST NO. 31: Please explain how the Parties currently ensure the accuracy and
sharing of near term studies and whether the current methods will be revised following the
proposed asset exchange. If current methods will be revised, please further explain how the
Parties will ensure the interconnection-model and near-term-studies are accurate in the future.
REQUEST NO.32: Please explain how the Parties plan to ensure the accuracy and
sharing of long-term operation studies, including shoulder periods, relay settings, remedial action
scheme impacts, and outage coordination following the proposed asset exchange.
REQUEST NO.33: Please explain how the asset exchanges and upgrades to the Idaho -
Northwest Transmission (Hemmingway - Summer Lake 500 kV, Walla Walla - Hurricane230
kV, and Midpoint - Hemmingway 500 kV) and associated substations revise the costs and
benefits of the proposed Boardman to Hemmingway transmission expansion.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6 FEBRUARY 4,2015
DATED at Boise,Idaho, this ''f C day of February 2015.
Technical Staff: Kathy Stockton/l-7
Johanna BelUS-33
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FIRST PRODUCTION REQIJEST
TO IDAHO POWER 7
Deputy Attomey General
FEBRUARY 4,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF FEBRUARY 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NOS.
IPC-E-14-41 /PAC-E-14.1I, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
JULIA A HILTON
IDAHO POWER CO
PO BOX 70
BOISE ID 83707
E-MAIL: [e-mail]
INDUSTRIAL CUSTOMERS OF IDAHO
POWER
C/O PETER J. zuCHARDSON
RICHARDSON ADAMS PLLC
515 N. 27TH ST
BOISE, IDAHO 83702
E-MAIL: [e-mail]
DANIEL SOLANDER
TED WESTON
ROCKY MOI-]NTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 8411I
E-MAIL: [e-mail]
ted.weston@pacifi corp. com
DR. DON READING
6070 HILL ROAD
BOISE,IDAHO 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE